The URL can be used to link to this page

Home My WebLink About10-6764, # Our File No.: 281214 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. DANIELLE E LONG 107 E MAIN ST APT A MECHANICSBURG, PA 17055-3854 Defendant. F1 L; ED -" THTr r 1 16 )4 2 F3 2: 2 5 COUNTY r1 - jYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 1d - Jo7(0y alvil-Fem 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 O 4ga.oo P A ATr Y I. Co P0 A-PY ct asazl Our File No.: 281214 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. DANIELLE E LONG 107 E MAIN ST APT A MECHANICSBURG, PA 17055-3854 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 DANIELLE E LONG, an adult individual residing at 107 E MAIN ST APT A MECHANICSBURG, PA 17055-3854. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 8598; 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 $3,870.79. 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 $3,870.79 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO( ES, P.C. Attorney for Plain A Law Firm Engaged in De Collection BY: David J. Apothaker, Dated: 10/15/2010 Our File No.: 281214 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 relat unworn falsification to authorities. David J. Apo gO, Esquire Attorney for Plaintiff DATE: 10/15/2010 LVNV FUNDING, LLC DANIELLE E LONG 107 E MAIN ST APT A MECHANICSBURG, PA 17055-3854 STATEMENT OF ACCOUNT Debtor's Name: DANIELLE E LONG Account Number: ending in 8598 Original Creditor: CITIBANK/SEARS Balance Due: $3,870.79 Our File No.: 281214 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson " Sheriff Jody S Smith Y Chief Deputy Richard W Stewart Solicitor'`" LVNV Funding, LLC Case Number vs. 2010-6764 Danielle Erelene Long SHERIFF'S RETURN OF SERVICE 11/19/2010 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: Danielle Erelene Long, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Danielle Erelene Long. Request for service at 107 E. Main Street, Mechanicsburg, PA 17055 appears vacant. However, The Mechanicsburg Postmaster is still delivering Danielle Erelene Long's mail to 107 E. Main Street, Mechanicsburg, PA 17055. SHERIFF COST: $42.00 SO ANSWERS, November 19, 2010 RON R ANDERSON, SHERIFF Cl) C C `v3 rh av b --r car- PQ - Qp C? hZ r Couni a .te She; 'f Tc.: ,oT. ?r:: Our File No.: 281214 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. DANIELLE E LONG Defendant. FILED-OffICE OF THE PROTHONOTARY 2011 J .!' , '' {'`i 8: 32 1CUMBEi L,', .'_' ii'OUNTY PE!"' CIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-6764-CIV ILTERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for P nti A Law Firm Engaged ' Deb Collection By: David J. Apothak , Dated: 1/10/2011 111111111111111