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Home My WebLink About10-7167Our File No.: 281103 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. JEAN MORRIS 143 15TH ST APT 1 NEW CUMBERLAND, PA 17070-1100 Defendant. ~ . ~ ~,, ' r.r, ~~~pj,r h~ 8 G .t, 6~~Ce l.~f t ,~+I MJ f,.~iir~ ...,~~ ~ L~ .a ~ ~ ,,,,~ ,~~ „~ f~ ~~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ~ ~ -~ ~ ~G 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 ~p a~ ~ ~? S ~.~ a Our File No.: 281103 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. JEAN MORRIS 143 15TH ST APT 1 NEW CUMBERLAND, PA 17070-1100 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY /~ (p Co~~ 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 JEAN MORRIS, an adult individual residing at 143 15TH ST APT 1 NEW CUMBERLAND, PA 17070-1100. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 9791; 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 $1,090.92. 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 $1,090.92 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & S CIATES, P.C. Attorney or P aintiff A Law Firm End ed ' Debt Co ctio~ BY: Dated: 10/25/2010 David J. A~q~h~lCer, Esquire Our File No.: 281103 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 understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 unsworn falsification to authorities. David J. A thaker, Esquire Attorney 'tiff DATE: 10/25/2010 LVNV FUNDING, LLC JEAN MORRIS 143 15TH ST APT 1 NEW CUMBERLAND, PA 17070-1100 STATEMENT OF ACCOUNT Debtor's Name: JEAN MORRIS Account Number: ending in 9791 Original Creditor: CREDIT ONE BANK, NA Balance Due: $1,090.92 Our File No.: 281103 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ' Richard W Stewart mm - Solicitor CFF'C EC'F -DESERtFr == •c - `am :?Q Lnr - W p d t -- -? ca C) -71 LVNV Funding, LLC Caii mllr C) - vs. Jean Morris 201 1,16 SHERIFF'S RETURN OF SERVICE 11/16/2010 05:08 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on November 16, 2010 at 1708 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jean Morris, by making known unto herself personally, at 143 15th Street, Apartment 1, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.30 November 17, 2010 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF %cj GountySuite Sheriff. Telebsnft. Inc.. Our File No.: 281103 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. JEAN MORRIS Defendant C TN LPEP0 TH 0TARY 1011 "i"124 PM 12: sal r'Jj4BERl AND 001014 Y Pr NNSYLVAMA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-7167 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JEAN MORRIS, in the default of an Answer, in the amount of $1,090.92 computed as follows: Amount claimed in complaint: $ 1,090.92 Less: Amount Paid: ( 0.00) Plus: Interest from October 25, 2010 to January 13, 2011 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL $ 1,090.92 I certify that Defendant, JEAN MORRIS, last knoddress is 143 15TH ST APT 1 NEW CUMBERLAND, PA 17070-1100. / David J. Apothaker, Esq. Attorney for Plaintiff Dated: January 13, 2011 Pa. A111 _ bU 1Gfia fik OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JEAN MORRIS 143 15TH ST APT 1 NEW CUMBERLAND, PA 17070-1100 LVNV FUNDING, LLC Plaintiff VS. JEAN MORRIS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-7167 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 Esg. at this telephone number: 800-672-0215 Our File No.: 2$1103 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. JEAN MORRIS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-7167 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. David J. Apothak\er.Esq. Attorney for Plaintiff Dated: January 13, 2011 Our File No.: 2$1103 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. ) JEAN MORRIS ) Defendant ) SS. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 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 143 15TH ST APT 1 NEW CUMBERLAND, PA 17070-1100. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22n93, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the our inquiry indicated that the Defendant(s) is/are Civil Action Data Center has sent back David J. Apothaker, Esq. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-7167 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. Depa knmt ofDdeue Marpavicer D*A Cftter !an-132411 W0934 3Afiay Statta Report Par=W to & Saner Members Civil ReWAcf ------ Fatsa fta1ra Dal+ AcHrtt Aq 1Jtstitn Il?isas peg' F?rat D ffaevirma. MORRIS IE&N Based oo the iforma6m you hair fi.nisheAt me D%.IDC does not Possess any iaforuaaa>aa -c the individnat stems. L'paa terra ?e armaPin - rdaa banks of me Department of Ddeme Mae power Data Ceaw. based on file iafomamoon that Yon proridmd, Oc lAwm is the tenant status of the iod'nidwt as to 41 Wenches aftbe lint toned Senkes Oros}, Nwy, Maine Craps, Ai Face, WOAA, Pubic HcmW and Coed Guard)- ANt A. MANT M -D-on,1 Dept of nefewe - Manpower Dora Cantu 1600 When Blvd , Sole 044 Antr*13m VA 2LV9-2_493 The Defense lsdaspaaes Data Crater (DMDC) a an a[aoa ben Jibe Dep tt ow d'Ddew that aaaaatmem the Defense Faaimmt and ?Y R?SaS SY'? ?}database iviricfi is tbt a?cist saQCC of deter oo eli?iiy Soar affray medical care and odw eipbiity systrm_ T1r Dan strxm*mwyoeu dm mf=cnx t of dieSanice Mks C" Reid'Act (!H1 L'SC App- §§ - 1 et scx& Q ,)waded) (SCIW Owme1y known as the UK= i and sailors' Civil Reief Ad of 1944) DMDC bus stud hmadreds of 16uwaads of 'dm mot possess any i k mauca iodic m% Wait lbe wxSvida>ti ea cvtrcedy on active duty' respcasts and has et micaeed a samml error rata. In dw evvar dye imfaidaa rdvsuced dx", air ray f wmig atmaber, fixod, or rues n a aswu is awry manner that the iaifvAmi is on attire duty, a is othemise caused to me praoetlioas of the SCRA, you are seangb encouraged to obtain furdta icm4oa tFtha pt anal s shpn by eawwcting than persons Service via die `def ear LTRL ht?'. vsvv-a#saa:ot Asa yrnocr ant Aa I?t evidence fbe prawn is aka active daty mad wa W to obt is the lllid ra Service v>•aiSeawn, pu iiivAe pcrnisimt oflbe SCRA map beimmokedaping you See S4 L'SC App_ §521(c)_ if Yon obtain sdttiaiomai Warta stion )boat due person (e.g , m SSN, iaprov ed wcwuy of I1 B. a rairlcle ammacl Yon ran YAM* your mquestt again at dis Web site and we m7 provide a new ceatificate fur 6A goery- 71a response rvttiects sells Auty s1a ms wchad'wg doe the iadvd" was last on sctiv a day, a'f't was widin the precedag 167 dais. For histoc cd ifamation, pleme contact the Say" SCRA poets-af-contact Mara iaybrtam&n on " c iw Daptr Sam' Arum day swas as reported m this cettficafe is dd6uedin accordance with 14 USC § 141(d)(1) fir a peseod of mere dm 30 conseagim days- In the case of a member of the Nafioasitl Crowd, maiden service tayder a rail to wh-m service m9fictired by me President a the Secretary of Ddam fa a period o(wo" 6w 34 caesecWx days wider 32 USC § 9020 fox papom of responding to a madam emmVmcy dedered by @ne Pre>vAms and mg4xvted by Federal finds, Al Ar6ve Guard Resents (AGR) mambas must be assigned against an sataorzmd mobikemban position in the unit they support, lln =Ardrs'iasv TARS, Manne Corps ARs and Coast Gard RPAs ArtNv Duty stmis alga mpks to a Uniformed Service member Aha k an actkv duty sparmisskeed officer of the U S, Pubic Healdl Service or the Wooaal Oceanic and Abwspham Adammoraaim (NOAA C-ammsioned Co") £or a period of more ffim 30 raosecubve din s. GowMe L%mf" Adair SCRA it Ama4m in Saw Cssar Coverage under the SCRA is broader m some cases and mclodes some categories of persons an arrive duty;- for pv>rposes of the SCRA ato wot6d not be reported as on Active Duty under tees certificate. Many tines ardor art a icaded to txtmd the period of active duty, eta ch would rx SCRA p m&ctions- Persons stelong to retY as dais wtbsle ceAtIfim d oW check to mace sure the orders on *%& SCRA prottegoas are based have not been amended to Wend dw udmrJt daces of srtnice. Futeimae some prosecoou of the SCRA may ate d w ptxsaas rs , have rae6-d ord- to report for active day or to be w*Kted, but who here oat ac#a dy beW mcbm lots or w ha* r'ePorkd for odaction- The Last Date tan Active Duty nary is kVortm t became a nognber of probecdom of SCRA erg beyond the last dates of active date. Those who amnia ray oa this catiaticate are urged to seek QaaYed kgai comsel to cassae that al tights guaranteed to Serviec meaalms mdw the SC7tA are protected. WAP- TL Tr Tlis cati rata seas provided based as a amw and SSN provided by the tom- Providing an caaaewa name at SSN WE cause an emneeaua rertfaeate to be provrided- Report u7727CQPGPQ L 281103 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) JEAN MORRIS ) NO. 10-7167 To: JEAN MORRIS 143 15TH ST APT 1 NEW CUMBERLAND, PA 17070-1100 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 08, 2010 BAR DAVID J. 1;1kER. 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 • Our File No.: 281103 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 ) COURT OF COMMON PLEAS ) CUMBERLAND COUNTY Plaintiff, ) ' vs• ) ) JEAN MORRIS ) NO. 10-7167 ) (xi CD- r 71" Defendant. ) > ) =r- > (7';) c.r1 PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER&ASSOCIATES, P.C. Attorneys sr Plaintiff A Law Firm Eng.gec in Debt Collection By: David J. At ‘.'er, Esquire 11 111 11 11 11 1111111 1111 III 1 11 * Q 8 1 0 S S 0 J 1 - * .50 P Any g no& 0,41 61%9111