The URL can be used to link to this page

Home My WebLink About10-6203 FILED-OFFICE Our File No.: 273123 OF THE FROTNONOTAR'I' APOTHAKER & ASSOCIATES, %0 SELP 28 N I' 27 BY: David J. Apomaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CUMBERLAND COUNTY PENNSYLVANIIA LVNV FUNDING, LLC 15 SOUTH MAIN STREET STE 500 GREENVILLE, SC 29601 Plaintiff, VS. MICHAEL SHOOP 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 17065 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. J 6 Cs 9 03 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 Our File No.: 273123 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, COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 16 - (p )- 6 3 .?r.. vs. MICHAEL SHOOP 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 17065 Defendant. 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 MICHAEL SHOOP, an adult individual residing at 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 17065. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 5413; and said account was issued to Defendant(s) by CREDIT ONE BANK, NA, 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 $1,311.25. 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 $1,311.25 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A OCIATES, Attorn fo Plaintiff / A Law Firm En aee in Deb ollf BY: Dated: 9/20/2010 David J. Aper, Esquire Our File No.: 273123 VERIFICATION David J. Anothaker, 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 signed understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relat g to worn f fication to authorities. David J. Apoth er, Esquire Attorney for Plaintiff DATE: 9/20/2010 LVNV FUNDING, LLC MICHAEL SHOOP 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 17065 STATEMENT OF ACCOUNT Debtor's Name: MICHAEL SHOOP Account Number: ending in 5413 Original Creditor: CREDIT ONE BANK, NA Balance Due: $1,311.25 Our File No.: 273123 EXHIBIT "A" 273123 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: LVNV FUNDING, LLC Expiration Date: Type of Action: Civil Action Defendant/s: MICHAEL SHOOP Serve Upon: MICHAEL SHOOP Address for Service: 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 17065 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting 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: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Fi1.El3-flFFICE sheriff r~ T~fE PR9J~Ht~?'d0i'~RY ~~~~5tti4. cT t~.n~n~~,~,~~~~ Jody S Smith ~ .., ~~ (~ ~~~ ~ ~ ~ ~ ; ~ ~ Chief Deputy Richard W Stewart f;~Ip~~[R~~,~ (~(~(J~~ 1 '~' Solicitor ~~;t;e -.v~~=_P~F~ 3~~k~dSYI..~~'~1~~~~:~: LVNV Funding, LLC Case Number vs. 2010-6203 Michael Shoop SHERIFF'S RETURN OF SERVICE 10/14/2010 08:07 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 14, 2010 at 2007 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael Shoop, by making known unto himself personally, at 24 S. Baltimore Avenue, Apartment 3, Mount Holy Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct copy of the same. AWN TS L, DEPUTY SHERIFF COST: $40.60 October 15, 2010 SO ANSWERS, RON ~ R ANDERSON, SHERIFF (c~ GountySuita ShenR, Telecsoft, tnc. Our File No.: 273123 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 OF THE FILED-OFFICE 2011 JAN 24 PM 12: c I CUMBERLAND COUgTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. MICHAEL SHOOP NO.: 10-6203 Civil Action Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, MICHAEL SHOOP, in the default of an Answer, in the amount of $1,311.25 computed as follows: Amount claimed in complaint: $ 1,311.25 Less: Amount Paid: ( 0.00) Plus: Interest from September 20, 2010 to January 13, 2011 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL /1") $ 1,311.25 I certify that Defendant, MICHAEL SHOOP, 16st wn address is 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 1706 . David J. thaker, Esq. Attorney for Plaintiff Dated: January 13, 2011 37 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: MICHAEL SHOOP 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 17065 LVNV FUNDING, LLC Plaintiff vs. MICHAEL SHOOP Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6203 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. Anothaker Esq. at this telephone number: 800-672-0215 Our File No.: 273123 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. MICHAEL SHOOP Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6203 Civil Action 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. Dated: January 13, 2011 Attorney for Plaintiff Our File No.: 273123 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. ) } MICHAEL SHOOP ) Defendant ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6203 Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 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 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 17065. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-25 , if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defe se /.pwer Data Center has sent back our inquiry indicated that the Defendant(s) is/are not i the il. David J. Apoth-*",._I 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. DMarumm ui[kieate Mampower D&A Ceater laa-13-:01108:53.48 MR-Y Stab- Rgwrt PmirMW to ilre Service Members CM FAdAct ,?-~?.? ? oa the imformaeon a?a ,} ' SHOOP idramadon Amt doe nm'rvmdaii hav?t tiaarrheet me NwMC does not pmsm my mt?aus. Upon m-hW doe ifoaaabm dnabualm oft e Depwbeear ofDrleme Mapower Duna Camm. bared Oa doe imkrmahaa dtr yea prvwAvA ebe above in tee screw sWu ofihe k& Mad as to a1 brahelees of we LFa bawd Services (Aral, Nen y. Macrae Carps, Ai Force, NOAA, Fnbi& Heww and Coact Gasrd)- 0itit Mwl M Swady-Ditoq Direc3er Dvwbw mt of Dd me - Mampovver Daea Center 1600 Whm Bl" . Satre 400 Atiallate, VA 2nM-2593 The De6mme Dan Cesar OMX') is aaotp memo a afdee Deparumm d Ddmw do atiieu m dw Defewe Eaobamt mad No I I Repar* Sysbm ONEW dadbase wMA is dw cwrial sootee of &" m tfp%k far mital nmdcal cane and odes -loft il?tearm. The DoD Arm* amts 6e "hremmd afdw Service Members CA ReW Ad (50 USC App- J§ 501 et w% as aerated) (SCRA) !Q6r wt* kam ode SoiGaf sad Sabel Cd RtWAct of 1940). DMDC ]ham bmd bw&tdt of 6omaods of 'does ant possems aq 6 mmtiaa dot The i Avi6d is cwready ca actor dory' regmm m. =d hu vVerkwed a and mm rase. Ia Ow ewmt drr WYOmd igferenced miewr, err wry fm* mmaotab , limed„ or mpmsmatatiire am m in my aaaaser Om the indiridaat is as ad ve dory, or it abervise a med to lie probxtiam of the SCRA, roe are f<t*a* awarmrisd to obgit fixdw verfip jm 4(6t person's swo by mmmm4 to pa"t Strict via doe 'gym M km:€.haww d in r i?C )f ym bvm a-Wmacm die pax* is as adive ddy and yoo fit iv obtain des adds and Se*t vrr&Mcm, paeilkm p mviiow of &e SCRA nay be i mma attest ym See 50 LW App. 1521(c). tf yatr obrtiie addieioaai iniawiort about tee pcnaa {e ?, as SSNI, iwprprrd arcvrscy cf DOB, a twiddle aante}. yroa exmo smiaasit paw rrgoeA av it at dim Web sec and we vnrl provAt a new cmta&raac fix &d 'ay- This ttwcme r elects at&* daeg stow kdm* date dw kdwidoai wan ka on active &1y, IT k w u wA im dw prece&g 36 dais For ksiarkd eformdkma pkme contact At Satire SCRA poinh-of-co t et. .htmar i4fwwadm an "derive Davy S&ww ' Aciw duty stmenas repoete4 im *k astfinme is de{nedin awxnkwe with 10 USC f 101(4'(1}kr a pe&d of nwie than 30 caeseradve dais, to the came of a member of the Nmiwd Guwd, k dudes mortice uWa a ul m artiv+e servite m&or zed by the President a die Sem*mry dDt& m for a period ofmore dw 30 ccaa mitm drn wrier 32 M § ' 02Mfar pwpomes of respoodrd to a uwkmW aoapatcp decwsed by dw Presidnat and mrpmW by Federal foods. Al Amoy- Gard R.eservx (AGR) memsbeas moat be auWed apowt art aut camd umbiueim poatb'm in ode unt &rv mtyp rt This ierdrdem Navy TARS. Mane Corp ARs sod Coast Gard RPAm_ Active Day stab- alto applies to a Lktifarmad Service umm*er wbo is as active dory rommissicaed officer oftbe U S. Pnbk 14m to Service or the Nx6orW Oceanic sad A#noapharic Admiriw*tim (\ AA Cawroi59ooed Cups) fin a period cif more dkai 30 omsecut r days. Co vane f *der die SCJU it Am*dsr in Sonar Con Coverage tuner the SCRA is bmxmim in some rases and isebdes some categomm of persons on wtive duty for purposes of the SC$A who woald not be reported as on Acione Duty under this cerlRicate. Amy tines ardK we ameaede d to amid the pmW ofacbm dry, which wooid sated SCRA pr Amtow. Pmms se dmg to redy as this webmie cmd kadm AmM deck b woke sure she orders m wbkh SCRA protaesioec are MW ham not been amended b -soot the ini-ioe does of service. Furfamare, some protectroam of due SCRA sal matxad to peesom who have rceeicved orders oo tepaR lieu score datg or m be iado6ed, bat waho Ytevw oat acioa?y bednmt aclFCe data' err aatwRy for wdscfim The Lot Date ern Atdve Duty to is' I ' eabecame a number ofprt kvtwm of SCRA-stmt belond der last dotes of aetioe 6tty. ?Lose Mw raid rely ea &% cnt&Aae are wed to seek gnafified kcal counsel to esmme that i d0ft mmuleed to Saxvice memabrsn ranter lie SC RA are pratmead. NVARNTKGr 1L'- carMcdc was presided based an anae and SSN provided by be regues/a- Provkrog an amxK m name at SSN wit care as awamom cergeaft to be pwvided. Revco IDdXTTPVN66B a 273123 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) VS. ) MICHAEL SHOOP ) To: MICHAEL SHOOP 24 S BALTIMORE AVE APT 3 MOUNT HOLLY SPRINGS, PA 17065 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-6203 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 Date: November 16, 2010 BAR S L DAVID J. AP HAKER, 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