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HomeMy WebLinkAbout10-6219IZ5 Our File No.: 267262 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. PENNY HOLLINGER 44 LIMEKILN RD CARLISLE, PA 17015 Defendant. .FILED-'OFFICE OF THE PROTHONOTARY 2010 SPP 28 PPS 3: 56, CUMBERLAND COUNTY PENNSYLti'ANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ID 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 4>9 7 . DO Cw cx'* apa3S5 Our File No.: 267262 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. PENNY HOLLINGER 44 LIMEKILN RD CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: J Q - (o.Z 19 cm,-t 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 PENNY HOLLINGER, an adult individual residing at 44 LIMEKILN RD CARLISLE, PA 17015. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 2935; and said account was issued to Defendant(s) by GE CAPITAL/WAL-MART, 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 $1,281.27. 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 $1,281.27 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS CIATES, P.C. Attorney fo 1 ' tiff A Law Firm Engag in ebt Collection BY: David J. Apot er, Esquire Dated: 9/22/2010 Our File No.: 267262 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 relating to up'"'`' rn falsification to authorities. David J. Apothe Attorney for DATE: 9/22/2010 LVNV FUNDING, LLC PENNY HOLLINGER 44 LIMEKILN RD CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: PENNY HOLLINGER Account Number: ending in 2935 Original Creditor: GE CAPITAL/WAL-MART Balance Due: $1,281.27 Our File No.: 267262 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~bti~~titr of ~ a~rab~,~,f~~~ G ,;~ '~ 1pF t jµ l j ` ~"~ ~FK ICE ~~F rr,d : "ERIFF r ~~~D-;;~ ~C QF ~'(~~~ 3°°"~~~~~~~07A~Y ~~1Q ~v~ -~ ~A~ 2~ ~7 ~~~ t"~~j'~''1 ~t/r~ ~i.i /~ LVNV Funding, LLC Case Number vs. Penny Hollinger 2010-6219 SHERIFF'S RETURN OF SERVICE 1 010 5/2 0 1 0 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: Penny L. Hollinger, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Penny L. Hollinger. Request for service at 44 Limekiln Road, Carlisle, PA 17015 has new occupants as of September 28, 2010. The Carlisle Postmaster has advised, Penny L. Hollinger has moved and left no forwarding address. SHERIFF COST: $38.40 SO ANSWERS,' October 05, 2010 RON R ANDERSON, SHERIFF (ci CountySuite Sheriff. Teleosoft Inr,. r> Our File No.: 267262 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. PENNY HOLLINGER 44 LIMEKILN RD CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY 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 r'T. __ ~ ~ '- ~~ jam- ~~" ~~'~/ ~i I Our File No.: 267262 APOTHAKER & ASSOCIATES, P.C. BY: David 3. 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. PENNY HOLLINGER 44 LIMEKILN RD CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST CUUNT 1. Plaintiff is LVNV FUNDING, LLC, 15 SOUTH MAIN STREET STE 500, GREENVILLE, SC 29601. 2. Defendant(s) islaze PENNY HOLLINGER, an adult individual residing at 44 LIMEKILN RD CARLISLE, PA 17015. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 2935; and said account was issued to Defendant(s) by GE CAPITAL/WAL-MART, 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 $1,281.27. A true and correct copy of the total due and owing is attached hereto, made a part hereof and mazked 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. Wl-IEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,281.27 and requests this Court awazd costs to the extent permitted by applicable law. APOTHAKER & AS Attorney fo A Law Firm En~a~e~ BY: Dated: 9/22/2010 ?RTES, P.C. Collection David J. Apotler, Esquire Our File No.: 267262 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 relating to ~~rn falsification to authorities. David J. Apotha Attorney for DATE: 9/22/2010 LVNV FUNDING, LLC PENNY HOLLINGER 44 LIMEKILN RD CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: PENNY HOLLINGER Account Number: ending in 2935 Original Creditor: GE CAPITAL/WAL-MART Balance Due: $1,281.27 Our File No.: 267262 EXHIBIT "A" Our File No.: 267262 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. PENNY HOLLINGER COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-6219 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. A Law Firm Enaaked in Debt Collection By: David J. Apo`ih-aker, Esquire Dated: 10/28/2010 11111111111111111111111111111111