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Home My WebLink About10-5637Our File No.: 260468 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. VERONICA GEKAS 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 Defendant. RED-OFFCE OF THE ?3t A?}tf:43 COUNV CUt ? PENFOW" COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: fQ - 5"7 0'-W'i17e-rN NOTICF 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 4ga.00 po ATI-4 Ct AID 897 g'ay73iy e 46 Our File No.: 260468 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. VERONICA GEKAS 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 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 VERONICA GEKAS, an adult individual residing at 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 2603; and said account was issued to Defendant(s) by CITIBANK, 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 $34,864.78. 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". 46 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 $34,864.78 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATE; P.C. Attorney for Plaintiff ' A Law Firm Enga? in De Collection BY: David J. Ap4tVAer, Esquire Dated: 8/23/2010 Our File No.: 260468 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 }b bnsworn falsification to authorities. David J. Attorney for Plaintiff DATE: 8/23/2010 LVNV FUNDING, LLC VERONICA GEKAS 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 STATEMENT OF ACCOUNT Debtor's Name: VERONICA GEKAS Account Number: ending in 2603 Original Creditor: CITIBANK Balance Due: $34,864.78 Our File No.: 260468 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~'ti''~'~r,'~ Sheriff ;,~ r~1L~ ,,,~.r~QY ug~,~y~~r ~~' ~ ~' ii,~,,, r ~ , _a' Jody S Smith ~ `~ Chief Deputy t~ `,'~_~ ~ ~ ~~~ ~~~ ~B Richard W Stewart _ ..4~~-~ Solicitor ~U,~pENNSI'LVPa~IIA LVNV Funding, LLC I Case Number vs. 2010-5637 Veronica T Gekas SHERIFF'S RETURN OF SERVICE 09/10/2010 05:25 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on September 10, 2010 at 1725 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Veronica T. Gekas, by making known unto Peter Gekas, Husband of defendant at 202 Conodoguinet Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. ~ ----- MICHELLE GUT ,- SHERIFF COST: $41.50 September 13, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF Our File No.: 260468 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 VERONICA GEKAS ni yip ?, t/ VGA `I F? COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5637 CIVILTERM Civil Action Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, VERONICA GEKAS, in the default of an Answer, in the amount of $35,226.16 computed as follows: Amount claimed in complaint: $ 34,864.78 Less: Amount Paid: ( 0.00) Plus: Interest from August 23, 2010 to November 5, 2010 at the legal interest rate of 6.00% per annum 361.38 Attorney fees 0.00 TOTAL $ 35,226.16 I certify that Defendant, VERONICA GEKAS, last o address is 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114. David J. Ap( Attorney for Dated: November 5, 2010 fd-ltwpo "AI&I" mf 069 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: VERONICA GEKAS 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 LVNV FUNDING, LLC Plaintiff vs. VERONICA GEKAS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5637 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 WAIT 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.: 260468, 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. VERONICA GEKAS Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5637 CIVILTERM Civil Action Defendant 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. David J. Apothzcer, Esq. Attorney for Plai?tiff Dated: November 5, 2010 Our File No.: 260468, 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 VERONICA GEKAS Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND 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 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defens M power Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in t e m itary. /' David J. Apothaker, Esq. Attorney for Plaintiff COURT,OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5637 CIVILTERM 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. DepaltnM of Desfease Manpower Dora Center NM-0-20100&00r43 Miry Stab- Rq-d Ararat to the Service Members Chit FAdAn Lam f gap As*,* Deer So* * trivet AOWy GEKAS 1UO.NXA Based on doe i donsub a You ) av A aiskxA dse DMX does am possm say idarawwa e milic" doe =&V dni status Upm sesrrv-Lrag the aEonwa m dw bemics a(the Dgwuw st o(Ddemac Mwposw Data Ce sser. bated of the ithametim ow yw P +d?d the govt a tba esaueoE [Banos of6e itiividwi as to A braadwes of the [,va med Sesaxes (Army, Navy, iti x*w Caps, Ai Face, NOAA, Pabk HeuW mod Coast Gardj. Mary M. S es-ly-D urn, Director Department of Lldwe - Manpower Data Center 1600 A'isoo Bkd, Suite, 400 Meow VA 22209-2493 The Defame Umpaurr Dwa Ceaatr {)MDC) is an oramaatwo o(the Deparanim aCDdmse that taaiaaaias lee Dudme Emahrat and EW -) Re Kz* System (DEERS) deb6ase tti:ch is the t6od sauce of data on d®W for natory anedicai ewe and when e few systems. The DoD imports the eafiwrnaent of the Saner Mambas CrA ReW Ad (50 USC App_ §§ sal or s r% as amended) (SCRA) (fCao, db ken% as tie 5aidi a• and Seiorf CkA RtWAct d194% DUC has ismed haameds c(d otuands of 'don tot post my sfaeaa' iaicairrg dust the adivkhml is curra y an active &W vespomes, and has atpssi wed aware a?ar tree. ba t6r err rust clue iaru l.rW I rderenced above, or =Yfmly apemaber, taimari, or neptessrufive asserts in say saaaer that dw iuudisei ' 'is on active ddy, or is adwrvise cal d to the protections of the SCRA, you are sha gly mcaraged to obtain Ardw ved6aboa aids[ pe rsos s sotus by cortsmq dart pawats :orrice via dke'dafemod Lot LIM hMMII*WW Nyov hwo evidwce *c pawa is era acdw data and ym fad to obt isdtis addiliood Sa we vadficadow po iive ptovisiow tithe SCRA map be invoked a pmA yon. See 50 VSC App §521(c). !F'}roa obeait adrttiaaat iafaxsarioe start the person {+: s, as SST1, iatpraved accuacy d DQB, a radritt same). Yea tan > paw reqnst assa at dis Web site d we m1 provide a w. caliiicete fficr dot qmexy- Ths reppomrst refieds snort Amy starts mdadag date lee N&Vxk al was last on accts duty, fit was waha the ptece&g 367 days For historical efuraaabeek plase contact dw Sasice SCRA peas-af-contact- Af~ i` oWwwi ion on 'Active LNw Seam' Active dalyy ,rafts as reported in ds certfiCate is de&med in accordance with 10 UTSC § 101(4)(1) for a period of mere dun 30 coemeeaative days. Da the rise of a member of Se Naliwal Gerard, iocku es sw icr wader a cal to active service amhorittd by the Pretidw or clue Sec remy of Ddanst 6x a period of more than 30 comecow reaps ander 32 USC 15021(0 Sox purposes c( responding to a aafiaarl emegpacy declared by the Presidn* and sopp moed by Federd Funds Al Ac*e Guard Reserve (AGR) m mbess must be assiewd *gi nst an as3huute,d nwb&xmwn position it IIe unit ffiey support This adm&s Nave TARS. \J me Caps ARs sad Crust Gwrd RPAs. Active Duty stales also applies to a Untamed Service member who a an active duty cowasirsioted older c(dw U.S. Public Heakh Service or tae Nationd Ogoxn c and Aatwspbe Adookisuytion ("'fit?AA Coonassicned Caps) for a Period of more than 30 conserotivc dav-s. Coravu W L n der tke SCi@.4 tr BMOA" to Souse cow Covaagc ao3er dw SCRA is broader a some rases and xrkwks some categories ofpessom on active dhdyf r purposes aftise SCRA uto would not be reported as on Active Duty mder this catfira t. Many teats orders we amended to eibead the pemd of acfiv a duty, which would ertead SCRA protectionn- Persons sedons to rdp as the webste cerdicadw staid check to make sure Or orders an which SCRA proms are baud have not betel amended to eartaad the "wen dates of service. Fvrtermat, some proweti m aide: SCRA slay tamead to persons w1w hm receia ed ordns ao report fca active dray or [D be adadeA but w1w have sot ockWly began active duty or acnraly reed for iadaeeoa Ue Lnst Date an Active Duty every is irromaot become a aarber ofpcowthow of SCRA exLesd bevwd the ittt elates of aetve duty. Those who world rely on this certAtaee are urged to sseelt quaMed kgd counsel to ensure that at nflat gasatirteed to Slaver members wader be SCRA are protecte3 SFAR'+tlN& THs catEcaac was provided based an a same and SSW provided by the togarster- Providing as eaaaeoos saurc at SSN will cane an erroneous c+allicate to be provided. ReportID3PNDC4FI27 260468 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) VS. ) VERONICA GEKAS ) To: VERONICA GEKAS 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-5637 CIVILTERM 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 191 DAVID J. AP T ER, 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 08, 2010