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Home My WebLink About10-5635Our File No.: 267899 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. AMY KOCH 1875 AERONCA ST CARLISLE, PA 17013-1101 Defendant. ,? rt i 1 lPY ;r 3!11:43 PENNSYLVM A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - 6(v 35 Gvi 1 Term 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 Q 01, 01) P q pT1* A6507 ?# a y 7,5-/ / Our File No.: 2678,99 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. AMY KOCH 1875 AERONCA ST CARLISLE, PA 17013-1101 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 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 AMY KOCH, an adult individual residing at 1875 AERONCA ST CARLISLE, PA 17013-1101. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 0335; 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 $795.07. 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". 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 $795.07 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Eng,,u BY: \ V David I Apothaker, Esquire Dated: 8/20/2010 Our File No.: 267899 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 to)aIpworn falsification to authorities. David J. Apothak r, Esquire Attorney for Plaintiff DATE: 8/20/2010 LVNV FUNDING, LLC AMY KOCH 1875 AERONCA ST CARLISLE, PA 17013-1101 STATEMENT OF ACCOUNT Debtor's Name: Account Number Original Creditor: Balance Due Our File No.: 267899 AMY KOCH ending in 0335 GE CAPITAL/LOWE'S $795.07 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~~~F? luE Sheriff n~ Tt~"' r^°~~~ ~'~'~r~~ 1l ~' c~1 ~,- 1 d ~ r,~r Jody S Smith ~'°~ ~ ~~~``~` L~ ~~~ 15 ~ ~~ 52 Chief Deputy Richard W Stewart Solicitor CU~~~~ ~ ,~`~; -.;`J~t'~TY PcN~w, ~.V,~lIA LVNV Funding, LLC Case Number vs. Amy Koch 2010-5635 SHERIFF'S RETURN OF SERVICE 09/07/2010 07:57 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 7, 2010 at 1957 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Amy Koch, by making known unto herself personally, at 1875 Aeronca Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 September 10, 2010 --~ ~.:~~ DEN FRY, D U Y SO ANSWERS, ~""'-° RON R ANDERSON, SHERIFF Our File No.: 267899 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC Plaintiff VS. AMY KOCH Defendant OF THE P FILED-OFFICE ,,, Y 2011 JAN 24 PM 12: S2 CUMBERLAVp COUNTv PEI SYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5635 CIVILTERM Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, AMY KOCH, in the default of an Answer, in the amount of $795.07 computed as follows: Amount claimed in complaint: $ 795.07 Less: Amount Paid: ( 0.00) Plus: Interest from August 20, 2010 to January 13, 2011 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL $ 795.07 I certify that Defendant, AMY KOCH, last kn address is 1875 AERONCA ST CARLISLE, PA 17013-1101. David J. A aker, Esq. Attorney for Plaintiff Dated: January 13, 2011 pa. l1/. 6 11P?+ha «r 01!:V- / so 5 P/Vt dn/i3./ ,i 11,41ti YyUa,. k ij OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: AMY KOCH 1875 AERONCA ST CARLISLE, PA 17013-1101 LVNV FUNDING, LLC Plaintiff VS. AMY KOCH Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5635 CIVILTERM } Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 800-672-0215 Our File No.: 267899 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC VS. Plaintiff AMY KOCH Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5635 CIVILTERM Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dated: January 13, 2011 Attorney for Plaintiff Our File No.: 267899 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC vs. AMY KOCH Plaintiff Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5635 CIVILTERM AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS. Civil Action David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 1875 AERONCA ST CARLISLE, PA 17013-1101. We inquired with the web site of the 1 Wilson Boulevard, Suite 400, Arlington, VA branch of the military. Mary M. Snavely-Dixon, Director of the De our inquiry indicated that the Defendant(s) is/are not Data Center has sent back David J. Apothaker, Esq. Attorney for Plaintiff ipower Data Center, located at 1600 3, if the Defendant(s) is/are in any I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Depwtmmt ofDdease MaVower Dsa Ctow hNitary Stdos Repot Paiaiut su 16e Sa?rice Mambas t;;rv?i ReielAct Iae-13-2411093619 !"" G A!'! slit { KOCH AMY Bsud oa tha wk atatlaa you lrvs finished, dte DUDC• days am poasns asry dortaamioa. a flee isd'svdemi stelae- Upon sem?itts the itfastttriaat ? boats d the L'lepsroasetrt d bdeme Merpc?a Daea Certaer. breed as Ibe ie6orraatias t4et you psavidasl, ae shove is dw Catres sttaaa of toe itai'ividW as to d bnadm oftbe Lvl t Services OMWF. Nor ". Marne Corps, Ai Force, NOAA, Pubic HesW and Cead Gerd;. Mary M Saevdg-Duna. Dited- Deparitta w of a iawt . 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I SCRA proGccdoas_ Persons seekiad to rely our this wrlme cert*udim stiaeid daeeck b make we &e arders on ttr6it5 SC RA Peakeclions are based love sot bem amuadad w edead the itatlmive data of srsv m Fv rdraware some prowdiow ddw SCRA stay c owd i o petsoa vd a brve ,eoeiv+ea onalers to rq wn Err active alts or p be adactea, but wbo bare sat aawk bias witvc arty or *do* seposled &r a6wioa The Last Date an Active Dray ealry is mWortaet because a amtlw of; roaet5ooa of SCRA a sfemd beyond that brat dates daclive & ty. Those %U wadd rots our ibis a nOn tt are urged to seek heal onmasd to enure shat ad rid b porsueed to Service members ruder the SMA are p vtecsed WARNDWx Iles caMesie was pr'o'd based oe a now aced SSN provided by the regaesta- P-4img an eomaeaae saaac at SSN wice e as e rreoeaats cagraft to be }mevAA ReportM40304ABM 267899 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) AMY KOCH ) NO. 10-5635 CIVILTERM To: AMY KOCH 1875 AERONCA ST CARLISLE, PA 17013-1101 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 ASSOCIATION 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3166 BAR DAVID J. AP T R, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 Date: October 27, 2010