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Home My WebLink About10-7652Our File No.: 288880 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. LINDA L SMITH 397 SAMPLE BRIDGE RD ENOLA, PA 17025-1022 Defendant. ~'~ TE~E~(~ ~THOi~OT~~' t(~IO OEC 13 P~ 3~ ! 3 ~i~MB~~LA~~ C~tJ~~T ~' ~CNP~SYL.VI~~~ff^. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ~b _'~ ~ SG~+ 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~ vsga ~°~ a+~~~o~~ Our File No.: 288880 APOTHAKER &~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 500 GREENVILLE, SC 29601 Plaintiff, vs. LINDA L SMITH 397 SAMPLE BRIDGE RD ENOLA, PA 17025-1022 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 LINDA L SMITH, an adult individual residing at 397 SAMPLE BRIDGE RD ENOLA, PA 17025-1022. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 6025; and said account was issued to Defendant(s) by CITIBANK/SEARS GOLD MASTERCARD, 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 $2,325.10. 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 $2,325.10 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS IATES, P.C. Attorney f P 'tiff f ~ A Law Firm Enna d i Debt C ~ tioi BY: Dated: 12/6/2010 David J. Apo~t[cer, Esquire Our File No.: 288880 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. 490ting to unsworn falsification to authorities. ~thaker, Esquire for Plaintiff DATE: 12/6/2010 LVNV FUNDING, LLC LINDA L SMITH 397 SAMPLE BRIDGE RD ENOLA, PA 17025-1022 STATEMENT OF ACCOUNT Debtor's Name: LINDA L SMITH Account Number: ending in 6025 Original Creditor: CITIBANK/SEARS GOLD MASTERCARD Balance Due: $2,325.10 Our File No.: 288880 EXHIBIT "A" Our File No.: 288880 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. LINDA L SMITH r E 2011 FEP' 18 PH 12: ^ 1 ?ENNSYg'aft NIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-7652 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys fonnD riff A Law Firm Engaged t Collection By: David J. Apotha r, Esquire Dated: 2/9/2011 1111111111111111111111111111111