HomeMy WebLinkAbout10-5614Our File No.: 268418
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D. #38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
LVNV FUNDING, LLC
15 SOUTH MAIN STREET STE 500
GREENVILLE, SC 29601
Plaintiff,
vs.
HELEN STARNER
36 STONE LEDGE RD
NEWVILLE, PA 17241
Defendant.
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COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 10 -,5(014 Gvi Ci`em
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after this complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further notice for any money claimed in the
complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
34 S. BEDFORD ST.
CARLISLE PA 17013
717-249-3166
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Our File No.: 268418
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D. #38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
LVNV FUNDING, LLC
15 SOUTH MAIN STREET STE 500
GREENVILLE, SC 29601
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.:
Plaintiff,
VS.
HELEN STARNER
36 STONE LEDGE RD
NEWVILLE, PA 17241
Defendant.
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is LVNV FUNDING, LLC, 15 SOUTH MAIN STREET STE 500, GREENVILLE, SC
29601
2. Defendant(s) is/are HELEN STARNER, an adult individual residing at 36 STONE LEDGE RD
NEWVILLE, PA 17241.
3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending
in 6437; and said account was issued to Defendant(s) by GE CAPITAL/LOWE'S, the Original creditor.
4. Defendant received, accepted and used the account to its benefit.
5. This account is in default and Defendant(s) has an unpaid balance of $3,586.54. A true and correct
copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A".
6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are
included in Exhibit "A".
116
7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as
above.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
$3,586.54 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & SS CIATES, P.C.
Attorney for P aintiff
A Law Firm Ent aed ' Debt Collection
BY:
Dated: 8/13/2010
David I Apothem, Esquire
Our File No.: 268418
VERIFICATION
David J. Apothaker, Esquire hereby states that I am counsel for plaintiff in this action, and that I am authorized to
take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to
the best of my knowledge, information, and belief. The undersigned understands that the statements therein are
made subject to the penalties of 18 Pa.C.S.A. 4904 relating tin worn falsification to authorities.
David J. ApothAkk Esquire
Attorney for Plallnldff
DATE: 8/13/2010
LVNV FUNDING, LLC
HELEN STARNER
36 STONE LEDGE RD
NEWVILLE, PA 17241
STATEMENT OF ACCOUNT
Debtor's Name: HELEN STARNER
Account Number: ending in 6437
Original Creditor: GE CAPITAULOWE'S
Balance Due: $3,586.54
Our File No.: 268418
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson n wt= '__'- n 11TAPY
Sheriff
Jody S Smith` 2
Chief Deputy
Richard W Stewart CUM= (;CUNW
Solicitor PE.NNSYLVAN A
LVNV Funding, LLC Case Number
vs.
Helen Starner 2010-5614
SHERIFF'S RETURN OF SERVICE
09/02/2010 01:42 PM - William Cline, Corporal, who being duly sworn according to law, states that on September 2,
2010 at 1342 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Helen Starner, by making known unto herself personally, at 36 Stone Ledge Road,
Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her
personally the said true and correct copy of the same.
WILLIAM CLINE, DEPUTY
SHERIFF COST: $38.80
September 03, 2010
SO ANSWERS,
RONITY R ANDERSON, SHERIFF
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