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Home My WebLink About10-7654Our File No.: 241183 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. AMANDA L WERNER 515 4TH STREET. NEW CUMBERLAND, PA 17070 Defendant. c~ ~.~ ~t.~ca-aF~rc~ ~~o~~~~¢~r~4~~~ 1~~Q QEC 13 P~f 3~ 21 ~Uf~tBERL.Al~D CQ~ i ~'~1dNSYL4~AP~#;~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ~V`~l~S-I 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 A'T 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 ~~t~~ ~~ ~~~sa33`~ Our File No.: 241183 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. AMANDA L WERNER 51 S 4TH STREET NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is LVNV FUNDING, LLC, 1 S SOUTH MAIN STREET STE 500, GREENVILLE, SC 29601 2. Defendant(s) is/are AMANDA L WERNER, an adult individual residing at 515 4TH STREET NEW CUMBERLAND, PA 17070. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 1201; and said account was issued to Defendant(s) by CITIFINANCIAL, INC, 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 $4,625.41. 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 $4,625.41 and requests this Court awazd costs to the extent permitted by applicable law. APOTHAKER & A~SOCIATES,~.C. Attorney A Law Firm En~~ BY: Dated: 12/6/2010 David J. Apa~aker, Esquire Our File No.: 241183 VERIFICATION David J. Anothaker, 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 knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 reto unsworn falsification to authorities. David J pothaker, Esquire Attorn or Plaintiff DATE: 12/6/2010 LVNV FUNDING, LLC AMANDA L WERNER 515 4TH STREET NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: AMANDA L WERNER Account Number: ending in 1201 Original Creditor: CITIFINANCIAL, INC Balance Due: $4,625.41 Our File No.: 241183 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff o? ?tratfF ?4?ti?1 Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF"` "4'i;ZF: FILED-01. FILE ''7010 DEC 2 ! PM 3: C CUMBERLAND PENNSYL.'AN11 LVNV Funding, LLC Case Number vs. 2010-7654 Amanda L. Werner SHERIFF'S RETURN OF SERVICE 12/15/2010 07:15 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on December 15, 2010 at 1915 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Amanda L. Werner, by making known unto Stephanie Williams, adult in charge at 515 4th Street, 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. STEPHE BENDER, DEPUTY SHERIFF COST: $43.30 December 16, 2010 SO ANSWERS, 2' RON R ANDERSON, SHERIFF iri Gotel-yS%i(n She,ff Ted,e;: .? , Our File No.: 241183 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC Plaintiff, VS. AMANDA L WERNER Defendant. FILED-QF I~ ICi- ;.1? 20111 FEB 18 PM 12: 2 CUMBERIAI+y D t'DUr=? ", COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-7654 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys Plaintiff A Law Firm EnaVRedrin Debt Collection By: David J. aker, Esquire Dated: 2/11/2011 11111111111111111111111111 l Commonwealth of Pennsylvania PRAECIPE TO ENTER JUDGMENT/ Court of Common Pleas `° ENTRY OF JUDGMENT County of Cumberland S,$S 9th Judicial District Cumberland County Adult Probation ( ri9z) ,_„\y v. Ashley Jaye Burkett Civil Docket No: �3 `7�5'1 6'5'4 DOB: 02/01/1987 Praecipe to Enter Judgment To the Prothonotary: erittl� JCL. Lebo U.S.POSTAGI Clerk of Court 13 of Qj umbertanb c�ountp ZIP 13688 _, , .. � 02 1VY 000136884E 1 Courthouse Square, Room 205 Carlisle, PA 17013 , { �',' Q r°3'1 t,R,c Y 1 i, / 376s-y 12/30/2013 f . , LAk Date Entry of J •