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HomeMy WebLinkAbout10-5712Our File No.: 259424 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. STEPHEN WERNER SR 710 HOGESTOWN RD MECHANICSBURG, PA 17050 Defendant. 50 unwy PENIOLVh"A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: lo - 57101 a.%vilTerrcF NOTICE You have been sued in court. If you wish to defend against the claims set forth i? 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 defense 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 monely or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YO? DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SETIFORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BEBLE 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 0 441 oo P 0 AT1-/ 1471(0(0 ;q 7710 . Our File No.: 259424 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. STEPHEN WERNER SR 710 HOGESTOWN RD MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: to- 0'., " . I -re rM CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is LVNV FUNDING, LLC, 15 SOUTH MAIN STREET STE 500j GREENVILLE, SC 29601 2. Defendant(s) is/are STEPHEN WERNER SR, an adult individual residing at 710 HOGESTOWN RD MECHANICSBURG, PA 17050. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 5135; and said account was issued to Defendant(s) by CITIBANK/SEARS, 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 $1,129.46. 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 $1,129.46 and requests this Court award costs to the extent permitted by applicable law. APOTHAKE A OCIATES, P.C. Attorn y f Plaintiff A Law Firm E as d in Debt CollestT6 BY: David J. ANthaker, Esquire Dated: 8/24/2010 Our File No.: 259424 VERIFICATION David J. Apothaker, Esquire hereby states that I am counsel for plaintiff in this action, and ghat I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complainfare true and correct to the best of my knowledge, information, and belief understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 unworn falsification to authorities. David J. ApWhaker, Esquire Attorney for Plaintiff DATE: 8/24/2010 LVNV FUNDING, LLC STEPHEN WERNER SR 710 HOGESTOWN RD MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: STEPHEN WERNER SR Account Number: ending in 5135 Original Creditor: CITIBANK/SEARS Balance Due: $1,129.46 Our File No.: 259424 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~,~~,~p ~t ~r~+~bc~~~4 .-~_~: t~F{~~. CJF'r $ ~+aERIFF i=iE F~_QE~Fi~E Jody S Smith Chief Deputy Richard W Stewart SOIICItOr 20fa OAT -~ ~'i 2~ 27 CtI~~EFc!_~,tkaD CC1U~d i ~' ,)~~;-.Yt \tt~~al~, LVNV Funding, LLC vs. Stephen Werner, Sr. Case Number 2010-5712 SHERIFF'S RETURN OF SERVICE 10/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Stephen Werner Sr., but was unable to locate him in hi: bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Stephen Werner Sr. Request for service at 710 Hogestown Road, Mechanicsburg, PA 17050 is the defendant's brother. He has advised Deputies, Stephen Werner Sr. does not reside at this address and he is uncertain of his current whereabouts. SHERIFF COST: $42.00 October 05, 2010 SO ANSWERS, ''.+'L ""'"' RON R ANDERSON, SHERIFF (c) CountySuite Shenff, TeleosotT. Inc. Our File No.: 259424 APOTHAKER & ASSOCLATES, 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. STEPHEN WERNER SR 710 HOGESTOWN RD MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNT(Y'~ NO.. ~ 0- 571 a~ l~~ V ~ 1 ~P~1 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 aze 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 and tn. " ,otaa ilii,'P~. . ~- • ~ ;~.,~ Our File No.: 259424 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. STEPHEN WERNER SR 710 HOGESTOWN RD MECHANICSBURG, PA 17050 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 STEPHEN WERNER SR, an adult individual residing at 710 HOGESTOWN RD MECHANICSBURG, PA 17050. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 5135; and said account was issued to Defendant(s) by CTTIBANK/SEARS, 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 $1,129.46. 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 $1,129.46 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER A OCIATES, P.C. Attorn f Plaintiff A Law Firm E ag din Debt Colleen BY: David J. A~gthaker, Esquire Dated: 8/24/2010 Our File No.: 259424 VERIFICATION David J. AQothaker, 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. T'l~~ii dersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 re~!ating/to unsworn falsification to authorities. David J. A~q~haker, Esquire Attorney for Plaintiff DATE: 8/24/2010 LVNV FUNDING, LLC STEPHEN WERNER SR 710 HOGESTOWN RD MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: STEPHEN WERNER SR Account Number: ending in 5135 Original Creditor: CITIBANKISEARS Balance Due: $1,129.46 Our File No.: 259424 EXHIBIT "A" 259424 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Squaze Cazlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiffs: Court Number: LVNV FUNDING, LLC Expiration Date: Type of Action: Civil Action Defendants: STEPHEN WERNER SR Serve Upon: STEPHEN WERNER SR Address for Service: 710 HOGESTOWN RD MECHANICSBURG, PA 17050 Alternate Address for Service: Type of Service: OPersonal (X) Adult in Charge ODeputize OCertified Mail OPosting Special Service Instructions: ** If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: S20 Fellowship Road C306 Mount Laurel, NJ 08054 Tele hone: 215-634-8920 FILED-OFFICr- Our File No.: 259424 0 fl: TNF P R 0 T H 0'i l0TAf" ;, APOTHAKER & ASSOCUaff 6 PM , : BY: David J. Apothaker, Attorney I.D.# 38423 CUMBERLAND COUNTY 520 Fellowship Road C306 PENNSYLVANIA Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. STEPHEN WERNER SR NO. 10-5712 CIVILTERM Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A CIATES, P.C. Attorneys r laintiff A Law Firm Eng d Debt C ectiot By: David J. Apothaker, Esquire Dated: 12/8/2010 i?umni?nm