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Home My WebLink About10-5638KED-OFFI OF TMF 13U+.,OTAF.Y Our File No.: 267896 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. TAMARA IRVIN 302 W MAPLE AVE CAMP HILL, PA 17011 Defendant. , ?) AM 11: 3 CUMBERLXZ COUNTY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - 51038 &-tvi l Ism 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 44a. 00 P p per( ar Iq 10891 V a y 7 Si,S- • Our File No.: 267896 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. TAMARA IRVIN 302 W MAPLE AVE CAMP HILL, PA 17011 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 TAMARA IRVIN, an adult individual residing at 302 W MAPLE AVE CAMP HILL, PA 17011. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 7044; 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 $1,127.17. 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 $1,127.17 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. A Law Firm EnOded in,IPSebt Collection BY: Dated: 8/23/2010 David J. Ap "her, Esquire Our File No.: 267896 A 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 relatinAt unsworn falsification to authorities. David J. Apot cer, Esquire Attorney for Plaintiff DATE: 8/23/2010 LVNV FUNDING, LLC TAMARA IRVIN 302 W MAPLE AVE CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: TAMARA IR.VIN Account Number: ending in 7044 Original Creditor: GE CAPITAL/LOWE'S Balance Due: $1,127.17 Our File No.: 267896 EXHIBIT "A" Our file No.: 267896 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 307949 LVNV FUNDING, LLC ) Plaintiff, ) vs. ) TAMARA IRVIN ) Defendant. ) FILED-01 F-I 21310 ScP 24 110: 0 I "0'MBERI ND COUNTi `a` PENNS 1`l k NIA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-5638 CIVILTERM Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on September 07, 2010, STIPULATED by and between Plaintiff, LVNV FUNDING, LLC, and Defendant, TAMARA IRVIN parties as follows: 1. Defendant agrees to pay the sum of $1,321.61, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $1,321.61 shall be paid by the by Defendant, TAMARA IRVIN, to the attorneys for Plaintiff in the following manner: a. $300.00 to be paid on or before the 16'b day of each month, beginning September 16, 2010 through December 16, 2010; b. $121.61 to be paid on or before January 16, 2010. All checks are to made payable to LVNV FUNDING, LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 7 Our file No.: 267896 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $1,321.61, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to TAMARA IRVIN by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Fiun Enna n Debt Collection By: Cavallaro, Esquire TAMARA IRVIN Our File No.: 267896 -3 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 vs. Plaintiff TAMARA IRVIN Defendant ACCEPTANCE OF SERVICE Civil Action I accept service of the Complaint in the above referenced matter. ?? Date: 9/9110 k1.A----- TAMARA IRVIN, Defendant Address: 302 W MAPLE AVE CAMP HILL, PA 17011 OF ONOTAR'I" 2010SFP ?'-, l"I 10: C 1 CUMBERLAND COUNTY PE 'SYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5638 CIVILTERM SHERIFF'S OFFICE OF CUMBERLAND CO, Ronny R Anderson r?F -Pad " Sheriff ??,?V At LUlp??.?,?? ? L? Jody S Smith "0t3 (V .g 1'. Chief Deputy ' (;OUNTY Richard W Stewart cu MP ?"i" Solicitor qF .mac c :, GUtF R J?&Pi LVNV Funding, LLC vs. Tamara Irvin Case Number 2010-5638 SHERIFF'S RETURN OF SERVICE 09/0212010 03:34 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1534 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Tamara Irvin, by making known unto Susan Irvin, Mother of defendant at 302 W. Maple Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 September 03, 2010 GE LD WORTHING , DEPUTY SO ANSWERS, RONRrY R ANDERSON, SHERIFF {p} CeuntySuite sheof4. Ieieosoft. fi-c A& ` Our File No.: 267896 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC Plaintiff, vs. TAMARA IRVIN Defendant. FILEJ-0 t' IC THE 0, T 2011 FF 18 PM 12: 2 ? t1hiB-RLAi,0 I, 1?re i " PYNSY[.."'1 flp' COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-5638 CIVILTERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorne for laintiff A Law Firm En aged Debt Collection By: David J Dated: 2/11/2011 Esquire