The URL can be used to link to this page

Home My WebLink About10-7122 Our File No.: 280685 APOTHAKER & ASSOCIATES, P'.C. BY: David J. Apothaker, Esquire Attorney LD. #38423 520 Fellowship. Road C306 Mount Laurel, NT 08054 (800) 672-0215 Attorneys for Plaintiff +~ °:`~ .` ~ . ~. c i ~ 3 p G 1 F~ ~ =mod i- k, , + ~ ~"; ~~ ~~ LVNV FUNDING,. LLC 15 SOUTH MAIN STREET STE 500 GREENVILLE, SC 29601 Plaintiff, vs. KEITH: BARTLES 245 F~E;DWOOD Lha 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. are served, by entering a written appearance personally. or by attornE;y 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 complaiirit or for any other claim or relief requested bythe 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. ][F 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 ~~ ~ ~ ~1.~ ~~~ ~ ~~~ ~2~ 25~d~~ t Our. File No.: 280685 ,' APOTI~AKER & ASSOCIATES, P.C. BY: -David J. Apothaker, Esquire Attorney LD. #38423. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC 15 SOUTH-MAIN STREET STE SC-0 GREENVILLE, SC 29601 Plaintiff, vs. KEITH BARTLES 245 REDWOOD LN CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ~ ~ G~ ~~ CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is LVNV FUNDING, LLC, 15 SOUTH MAIN STREF,T STE 500, GREENVILLE, SC 29601 2. Defendant(s) is/are KEITH BARTLES, an adult individual residing at 245 REDWOOD LN CARLISLE, PA 17015. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 3404;;. and said acc®unt was issued to Defendant(s) by CREDIT ONE BANK, NA, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. `i. This account is in default and Defendant(s) has an unpaid balance of $1,085.48. 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 $1,085.48 and requests this Court award costs to the extent permitted by applicable law. APOTIIAKER & A OC ATES, P.C. Attorney f r Plai tiff A Law Firm En~a~ d in ebt`Collecti~r EY: David J. Apoth ,Esquire Dated: 10/22/2010 -- Our File No.: 280685 ~' ~ a VERIFICATION David J. Apothaker, Es uire 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 knovaledge, information, and belief. The undersigned understands .that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relat' g o unsworn falsification to authorities. David J. ~~oth~er, Esquire DATE: 10/22/2010 LVNV FUNDING, LLC KEITF[ BARTLES 245 RFsDWOOD LN CARI,I[SLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: KEITH BARTLES Account Number: ending in 3404 Original Creditor: CREDIT ONE BANK, NA Balance Due: $1,085.48 Our File No.: 280685 EXHIBIT "A" ~' 280h85 ~ > ' Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-639 7 Plaintiff/s: Court Number: LVNV FUNDING, LLC Expiration Date: .Type of Action: -Civil Action Defendant/s: KEITH BARTLES Serve Upon: KEITH DARTLES Address for Service: 245 REDWOOD LN CARLISLE, PA 17015 Alternate Address for Service: Type of Service: OPersonal (X) Adult in Charge ODeputize O Certified Mail O.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: 215-63 4-8920 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff OF THE PROTHONOTARY Jody S Smith DEC a ?? Chief Deputy° ° `Richard W Stewart C2010 UMBERLAND COU1: 33 NTY Solicitor OFr`E hE;w -EIFF PENNSYLVANIA LVNV Funding, LLC Case Number vs. 2010-7122 Keith Bartles SHERIFF'S RETURN OF SERVICE 11/24/2010 10:40 AM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on November 24, 2010 at 1040 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Keith Bartles, by making known unto Selena Bartles, Wife of defendant at 245 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. TEPHEN BENDER, DEPUTY SHERIFF COST: $33.40 November 30, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ;Ci cointySuite Sherff, Te eosoft h?c. Our File No.: 280685 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 CF THE Ro a 0 O R Y "' I JAN 24 P, I?: CUMBERLAND C(iU;jr 4, PEN14s YLY /lo tA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. KEITH BARTLES NO.: 10-7122 Civil Action Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KEITH BARTLES, in the default of an Answer, in the amount of $1,085.48 computed as follows: Amount claimed in complaint: $ 1,085.48 Less: Amount Paid: ( 0.00) Plus: Interest from October 22, 2010 to January 13, 2011 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL _ $ 1,085.48 I certify that Defendant, KEITH BARTLES,1 wn address is 245 REDWOOD LN CARLISLE, PA 17015. David J. A aker, Esq. Attorney for P aintiff Dated: January 13, 2011 ?a, ) t/ ?? Iz) P0HI-6 e r OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KEITH BARTLES 245 REDWOOD LN CARLISLE, PA 17015 LVNV FUNDING, LLC Plaintiff vs. KEITH BARTLES Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-7122 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. Apothaker. Esq. at this telephone number: 800-672-0215 Our File No.: 280685 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. ) KEITH BARTLES ) Defendant ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-7122 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 unworn falsification to authorities. Dated: January 13, 2011 Attorney for Plaintiff Our File No.: 280685 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 vs. KEITH BARTLES Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-7122 Civil Action Defendant 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 245 REDWOOD LN CARLISLE, PA 17015. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defe se tp t er Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in he t David J. ApothakerI 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. Department of Ddtruse ?vla npowel Daft Center lan-13 2011 09:0 -M Mary Stabs Report PO MM to dire SMICe MembM CM ReWA& 'pia . ba» AcM A aARlms KErm Based me [orrm.eor: , hoc r?raislxd DNfDC does not posses nay ?cocmavow w5cating die ednirurai Wis. U" sea'ch tg tae vdana boa data bauks bete Depwbac t of Defense Manpower Data Cetaff based oO &e onwO,, ibat }va P ovided, the above is tim darrew Aat>s of the adnkb i as to al bra ltes of the LWotmed Senim (Amy, T wv7 4tariw Cups, Air Force,, NOAA, Aaic Heath„ and Coast mod). Mary 1f S--§y-Dbu m, Director Department ofDdmw - Mupowff Data Center low Wisoo Bh%L, Suite 400 AtfeOM VA-21205-2593 The Defeaw b6impowes Dm Curter (DMDC) is an oa><aniooon of doe Dgrotanent aDdeme do vani town die Ddeme E-almm and EIPW Repo" Sys (DEERS) da<abm wdich a the oCkmol source of dats an efipw for mi ary medical tare and Ober elodi systtms. The DoD strawy supports the enforcement of dw Service Members Can Raid Art (50 CTSC App- §§ SOS et seq, as amended) (MW $wax& known as Are So &= and Sa lors CM RtWAct of 19401 MM has issued h odreds oft of does not possess any a 6musaiom jaduftth d ate adividoaC a eaready an active atpr' respoesm and has cgxneuced a oral errs rate. is t6c event i6e iadiaidtvrl refaanced above, or nay fimAy member, MewA err rep rewaujive asserts a any mmarr dui the addWW is ou active duty, or is adseswise entitled to the protections of die 5CRA, you we stron* ewarraged to abtaia feather v afeaoora of the parsons stabs by coamciiag drat petsods Saviae via the "defeaseh*-mr L'RL ML*Rx If you have evidamoe tba penam is on active daily and yam far to obtain din additional Service ved6csion, pm7ive pravisiow of die SCRA may be invoked aginst yam See 50 USC App §531(t). If you obtaie atdManai in6rxmaim about doe person aw SSN. i rfe7 ed acciracy of DOA, a middle am), you can submit your regmest agaa a dis Web ske sad cv«r ul provide a odor cati6eatc be OW grer,r- dais response reelects askys Aviv watts date the iadvidtW was Mgt ou scene duty, fit was mid av the pre o&g 36? daps. For hisioncal damsbco, please contact the Service SCRA porous-of-comurct. Mm ivi?twndo r on "Aesiwe Da w Steens" Active duty status as repottmd io"-MI-ata is mined in accordance A 10 GSC § 101(41) for a period of more dmo 30 ton-UkiVe days. In dtt cast of a member of die `3a knal Canard, abc d service under a ed to aaivx ser»iet audiariml by the President or tie Secretary ofD a for a paired of am to 30 cansec 0vt days under 32 VSC § 5020) for purposes cf try to a aetit-i emervacy deriared by the president and supported by Federal ftmds. Al Agnx Guard Rcsert-e f,AGR) oiemb- aarrt be as prd against an wAouwd mobatmoo position in die met dry soppadt Tiffs i dudes'_+iavy TAR%, Marine Carps ARs and Coast Guard RPAs. Aetivae Duty auras also applies to a t ofonued Sa%,Ice member who is an active tarty roaantssiated QfktF Of doe C.S Pobhc HeaAft Senice or the-Natioaai Octane and Annospheric Ad iii anion (NOAA Cow-sioned Corps) for a period of more don 30 consecutive dais. C--Ve Under 4wr SCR.iI if Bmadtr IN Satire CQSel Coverage ?8er the SCRA is broader in some cases and ioclodes snare cffiegoiies of persons on ac[it-e&*g far puposes cf &e SCRA who wvtdd era be rgxvwd as on Activrc Duty, miley tlas certificate Many tames orders are sasmdad to emend the period of acetic day, which world dread SCRA prcoectioms. Persons seeking to rely dr this wdAke tert&A bon should check to make stye the orders an abide SCRA proh"ons we based halve not been amended to cdood die iA*&t dates of service. FuAaawce same prowc6om of dw SCitA may cmend to persons abo Wave recrivtd ardess b reyaet for active duty or to be iadaded„ bur wdp havr aot acgaaly bepm -hwe duty or tictuW vmoded fur edactlon The Last Date on Act Duty entry is iaoportaot bec ou se a amber afpro6ectioos of SCR A extend beyond tut drat dudes of act dlaty Ilrose who would rely on this certificate are urged to seek gnsl7ied ieepl counsel to come that al<rigbes Owanteed to Service memben trader the 5CRA are protected . WAR.'+iLNO' THs certdicac - Provided based an a a aw and SSN provided by the rcgwsta. Pravidng an enowous name or SW4 wi cause an etranarrt>s cert ie te, to be provided. Report 1DN8MC3A3NN 280685 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) KEITH BARTLES ) NO. 10-7122 To: KEITH BARTLES 245 REDWOOD LN CARLISLE, PA 17015 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: December 22, 2010 BAR Ise DAVID J. APOTHAKER, 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