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Home My WebLink About10-5636 Our File No.: 268525 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. KATHY A REICHERT 231 W MAIN ST APT A MECHANICSBURG, PA 17055 Defendant. CF Tw ,? fiw ? 31 Ali 1{:43 CLUk COUNTY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 10 - 5 to 3 (p 0,-%V-, t'TF.rm 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 (0 +Qa. 00 p a AT"t ?. ?U991 Our File No.: 268525 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. KATHY A REICHERT 231 W MAIN ST APT A MECHANICSBURG, PA 17055 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 KATHY A REICHERT, an adult individual residing at 231 W MAIN ST APT A MECHANICSBURG, PA 17055. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 7039; and said account was issued to Defendant(s) by CREDIT ONE BANK, NA, 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 $879.49. 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 $879.49 and requests this Court award costs to the extent permitted by applicable law. APOTH)tR SSOCIATES, P.C. Atto ey or Plaint ff A Law Firm E g d in ' t Collection BY: David J. A?thaker, Esquire Dated: 8/23/2010 Our File No.: 268525 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 relatir o unworn falsification to authorities. David J. I Apbt1 Aer, Esquire Attoreor Plaintiff ?11_ DATE: 8/23/2010 LVNV FUNDING, LLC KATHY A REICHERT 231 W MAIN ST APT A MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: KATHY A REICHERT Account Number: ending in 7039 Original Creditor: CREDIT ONE BANK, NA Balance Due: $879.49 Our File No.: 268525 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FlLF-D--07-r,E Sheriff - Jody S Smith Chief Deputy -P _ 3 PM 1:02 Richard W Stewart CUM,.._„UNW Solicitor PENINSYLVANIA LVNV Funding, LLC vs Case Number . Kathy A. Reichert 2010-5636 SHERIFF'S RETURN OF SERVICE 09/02/2010 03:14 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1514 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kathy A. Reichert, by making known unto herself personally, at 231 W. Main Street, Apartment A, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 September 03, 2010 GERALD WORTHING N, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF !o; G0unfySLJ1 e Sheriff, Teleosoft Inc.