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Home My WebLink About10-5711 'Our File No.: 2673 98 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. KARI FRAZEL 1073 NEWVILLE RD CARLISLE, PA 17013-1738 Defendant. NO.: to - 5171/ Civil-TErm R t . 3 MA COUNTY CUMB-Y`AN 1A FEW j COURT OF COMMON PLEAS CUMBERLAND COUNTY NOTICE You have been sued in court. If you wish to defend against the claims set forth iii 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 s 49..00 o Arty &114-11 lot 0amol . ,_ 4-. Our File No.: 267398 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. KARI FRAZEL 1073 NEWVILLE RD CARLISLE, PA 17013-1738 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CIVIL ACTION COMPLAINT FIRST COUNT Plaintiff is LVNV FUNDING, LLC, 15 SOUTH MAIN STREET STE 500 GREENVILLE, SC 29601 2. Defendant(s) is/are KARI FRAZEL, an adult individual residing at 1073 NEWVILLE RD CARLISLE, PA 17013-1738. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest: of Account # ending in 4426; and said account was issued to Defendant(s) by GE CAPITAL/LOWE'S, the Origial 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 $1,344.44. 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". I . , . qb 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 $1,344.44 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & CIATES, P.C. Attorney or laintiff A Law Firm End e in Debt Collection BY: lv David J. Apot er, Esquire Dated: 8/24/2010 Our File No.: 267398 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 rel?n? to unworn falsification to authorities. David J. Vptkfaker, Esquire Attorney for Plaintiff DATE: 8/24/2010 LVNV FUNDING, LLC KARIFRAZEL 1073 NEWVILLE RD CARLISLE, PA 17013-1738 STATEMENT OF ACCOUNT Debtor's Name: KARI FRAZEL Account Number: ending in 4426 Original Creditor: GE CAPITAL/LOWE'S Balance Due: $1,344.44 Our File No.: 267398 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff QFe Ct; ? 'tiE ?? RiFF Jody S Smith Chief Deputy Richard W Stewart Solicitor r C,F"DI 'AD D . 0 V iZZi ? f .SS kW7 t`Y V?kl.r LVNV Funding, LLC vs. Kari Frazel Case Number 2010-5711 SHERIFF'S RETURN OF SERVICE 09/21/2010 04:50 PM - Noah Cline, Deputy Sheriff, who being duly sworn according, to law, states that on September 21, 2010 at 1650 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kari Frazel, by making known unto Kayla Barbaretta, Daughter of defendant at 1073 Newville Road, 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 23, 2010 NOAH CLINE, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF IC CountySuite .She:ft . re!eosot(. In;:. FILED-OFFICE cr THE P OTHONOTAR Our File No.: 267398 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. KARI FRAZEL Plaintiff Defendant 2011 X9 24 PM 12: 52 CUMBERLAND COUNTY PENNSYLVANIA } COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5711 CIVIL TERM Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KARI FRAZEL, in the default of an Answer, in the amount of $1,344.44 computed as follows: Amount claimed in complaint: $ 1,344.44 Less: Amount Paid: ( 0.00) Plus: Interest from August 24, 2010 to January 13, 2011 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL $ 1,344.44 I certify that Defendant, KARI FRAZEL, last kno ddress is 1073 NEWVILLE RD CARLISLE, PA 17013-1738. David J. Apothaker, Esq. Attorney for Plaintiff Dated: January 13, 2011 Pd.' Il/ DU i?t I?r ?& Is6111 PMaW i33 A li-L of Yiil,,. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KARI FRAZEL 1073 NEWVILLE RD CARLISLE, PA 17013-1738 LVNV FUNDING, LLC VS. KARI FRAZEL Plaintiff Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 1 NO.: 10-5711 CIVIL TERM 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, EN. at this telephone number: 800-672-0215 Our File No.: 267398 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. KARI FRAZEL NO.: 10-5711 CIVIL TERM 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 penalti f 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. Apothaker, Esq. Attorney for Plaintiff Dated: January 13, 2011 Our File No.: 267398 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. KARI FRAZEL Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5711 CIVIL TERM : SS. 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 1073 NEWVILLE RD CARLISLE, PA 17013-1738. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 2223, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the our inquiry indicated that the Defendant(s) is/are Data Center has sent back David J. Apothaker, Esq. Attorney for Plaintiff 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. 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Th s cettrReate was provided based our ammow and SSN pmaidead by the mgrester Pea irRuas a eaemora now or SSN suit crow m earoneoos caWleme to be provided purport U>.MXS0#FW3 267398 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) KARI FRAZEL ) NO. 10-5711 CIVIL TERM To: KARI FRAZEL 1073 NEWVILLE RD CARLISLE, PA 17013-1738 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 \7fA 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