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HomeMy WebLinkAbout10-6763¦ %. Our File No.: 281913 ' APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. 938423 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. CYDNE MARKHAM 30 MOUNTAIN ST DUNCANNON, PA 17020 Defendant. FILED-OFFICE OF THE I? Th0N0TA 111 Y 7i 0 ['T 22 r' 2, 2 C.U F ,L D C0 NI E7117 N C `( LVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Jp - ?A710? ??v i ?Terw? 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 0:55 pa. 00 Pa ATry 0 ?? dSOf?o Our File No.: 281913 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. CYDNE MARKHAM 30 MOUNTAIN ST DUNCANNON, PA 17020 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 CYDNE MARKHAM, an adult individual residing at 30 MOUNTAIN ST DUNCANNON, PA 17020. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 2544; 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 $1,130.85. 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 $1,130.85 and requests this Court award costs to the extent permitted by applicable law. Dated: 10/15/2010 APOTHAKER & Attorney A Law Firm Erjga€ i BY: David J. A OCIATES,,P.C. in , Esquire Our File No.: 281913 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 to unsworn fa4ification to authorities. David J. Apor, Esquire Attorney for Plaintiff DATE: 10/15/2010 LVNV FUNDING, LLC CYDNE MARKHAM 30 MOUNTAIN ST DUNCANNON, PA 17020 STATEMENT OF ACCOUNT Debtor's Name: CYDNE MARKHAM Account Number: ending in 2544 Original Creditor: CREDIT ONE BANK, NA Balance Due: $1,130.85 Our File No.: 281913 EXHIBIT "A"