The URL can be used to link to this page

Home My WebLink About10-7388Our File No.: 286077 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. JENNY MANGANELLO 21 DERBYSHIRE DR CARLISLE, PA 17015 Defendant. F1LED-0~'F 1CE C?r 1'NE PROTtihEt~TI~~R' CUMBERl.At~~ COUNTY PENNSYLYAP~i,~~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.:~Cj•~ 3oa 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 ~ ?~ ~~ ~q2 ~' ~asi-Sia~ Our. File No.: 286077 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. JENNY MANGANELLO 21 DERBYSHIRE DR CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY 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 JENNY MANGANELLO, an adult individual residing at 21 DERBYSHIRE DR CARLISLE, PA 17015. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 5967; and said account was issued to Defendant(s) by GE CAPITAL/JC PENNEY DUAL CARD, 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 $1,341.23. 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 $1,341.23 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm En~a~ BY: '~SOCIATES, P.C. Plaintiff in Debt ollectio~ David J. Ap(cer, Esquire Dated: 11/19/2010 Our File No.: 286077 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~ating to unsworn falsification to authorities. David J~pothaker, Esquire Attorney for Plaintiff DATE: 11/19/2010 LVNV FUNDING, LLC JENNY MANGANELLO 21 DERBYSHIRE DR CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: JENNY MANGANELLO Account Number: ending in 5967 Original Creditor: GE CAPITAL/JC PENNEY DUAL CARD Balance Due: $1,341.23 Our File No.: 286077 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ? . T FILED-OFFICE Sheriff ROTHONO TI?R Jody S Smith '2010 DEC -8 PH 3: Chief Deputy Richard W Stewart CUMBERLAND CCUI TY Solicitor PENNSYLVANIA LVNV Funding, LLC vs. Case Number Jenny A. Manganello 2010-7388 SHERIFF'S RETURN OF SERVICE 12/02/2010 06:25 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010, at 1825 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jenny A. Manganello, by making known unto Thora Manganello, Daughter of defendant at 21 Derbyshire Drive, 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. NOAH CLINE, DEPUTY SHERIFF COST: $33.40 December 03, 2010 SO ANSWERS, RONW R ANDERSON, SHERIFF Our File No.: 286077 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. JENNY MANGANELLO Defendant. FILED-OFFICE €F THE F CTNC QTr}Py MOTE 28 AM B• C't3 MIMBERLA D t;Ca?1: } COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-7388 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, F.C. Attorneys fo ' tiff A Law Firm Eneaa i eht C'.nllertinr By: David J. Apoth , Esquire Dated: 12/14/2010