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Home My WebLink About10-7389 Our File No.: 285961 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. DALE E ADAMS 2551 WALNUT BOTTOM RD APT 3 CARLISLE, PA 17015 Defendant. C3F 7HE pRp7'H~~CJT'~ ~~ ~~Rz ZOtOt~~Y 30 AM T t~ CU PENNSYI~,YA OUt~i`i' ~[~ i COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: !V-~JD~ 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 ® ~~~a~ oak ~qa~ ~,.~ a r ~. Our File No.: 28596 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. DALE E ADAMS 2551 WALNUT BOTTOM RD APT 3 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 DALE E ADAMS, an adult individual residing at 2551 WALNUT BOTTOM RD APT 3 CARLISLE, PA 17015. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 5216; and said account was issued to Defendant(s) by CAPITAL ONE, 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 $2,021.99. 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 $2,021.99 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS CIATES, P Attorney fo 1 ntiff A Law Firm Engag in ebt C ect BY: David J. Apothaker, Dated: 11 / 19/2010 Our File No.: 285961 .. 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 rela~o unsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 11/19/2010 ... LVNV FUNDING, LLC DALE E ADAMS 2551 WALNUT BOTTOM RD APT 3 CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: DALE E ADAMS Account Number: ending in 5216 Original Creditor: CAPITAL ONE Balance Due: $2,021.99 Our File No.: 285961 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FfLEC-OFFICE Sheriff GIP _ THE PROTHONOTARY Jody S Smith DEC i8 + Chief Deputy PM 3. Richard W Stewart COMBERLAND COUNTY Solicitor PENNSYLVANIA LVNV Funding, LLC Case Number vs. 2010-7389 Dale E. Adams SHERIFF'S RETURN OF SERVICE 12/02/2010 08:20 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010, at 2020 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Dale E. Adams, by making known unto himself personally, at 2551 Walnut Bottom Road, Apartment 3, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him 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.: 285961 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. DALE E ADAMS FILED-OFFICE OF THE PROTHONOTARY 2011,.1,,' 6 U N, CUM BE k 1- TY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-7389 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys fninD* iff A Law Firm Engag t Collection By: David J. Apothak , Esquire Dated: 1/5/2011