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Home My WebLink About10-5738a 46 Our File No.: 268046 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. SANDRA E THOMAS 400 STONEHEDGE LN MECHANICSBURG, PA 17055 Defendant. t, 9 59 COUNTY pENPNSYI?'ANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I0 - 5'138 0,wic-pim 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 4Qa.oo Pa Ar7-7 a#' lq-1547 p, ay778A w Our "ile No.: 268046. 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. SANDRA E THOMAS 400 STONEHEDGE LN MECHANICSBURG, PA 17055 Defendant. 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 SANDRA E THOMAS, an adult individual residing at 400 STONEHEDGE LN MECHANICSBURG, PA 17055. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 4072; and said account was issued to Defendant(s) by CAPITAL ONE, 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 $4,821.07. 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 $4,821.07 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS TES, P.C. Attorney for 1 ' tiff A Law Firm Engaged n ebt Colley BY: Dated: 8/26/2010 David J. Our File No.: 268046 04 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 relatinV' ?nsworn falsification to authorities. David J. Ap haker, Esquire Attorney fo ntiff DATE: 8/26/2010 4 LVNV FUNDING, LLC SANDRA E THOMAS 400 STONEHEDGE LN MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: SANDRA E THOMAS Account Number: ending in 4072 Original Creditor: CAPITAL ONE Balance Due: $4,821.07 Our File No.: 268046 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~$i~~tita dt +~~Er~brry~~~ r ~ ~J,,. ~~ a~7t ~,~~~ „t.v, , ., - ~.- ~!Ff t~ t r T r F 5!'£RIFF F1L~D-QFFICE i= c ~~ ~~~1~4~ON0 i~RY ?~ i 0 Qf~T 13 PFt I ~ 13 CUt~B~RLA~di~ C~tiP~TY PEN5Yl.V~,~lIA LVNV Funding, LLC vs. Case Number Sandra E. Thomas 2010-5738 SHERIFF'S RETURN OF SERVICE 10/12/2010 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: Sandra E. Thomas, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Sandra E. Thomas. Deputies were advised, Sandra E. Thomas has moved from 400 Stonehedge Lane, Mechanicsburg, PA 17055. To date The Mechanicsburg Postmaster has been unable to provide a good forwarding address for Sandra E. Thomas. SHERIFF COST: $37.00 SO ANSWERS, October 12, 2010 RON R ANDERSON, SHERIFF (c} CountySuite Shenff, Teleosoft. hu. Our File No.: 268046 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 vs. SANDRA E THOMAS Plaintiff, Defendant. rn sn r-- f ?=cf s? COURT OF COMMON PLEAS CUMBERLAND COUNTY - NO. 10-5738 CIVILTERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. Dated: 6/10/2011 APOTHAKER & AS ?jlCIATES, P.C. Attorneys r P aintiff A Law Firm Enga d i Debt Co ctioi By: David J. Apothaker, Esquire 11111111111111111111111 C Cn x?. rte..,..