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Home My WebLink About10-7773,, ~. Our File No.: 272121 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. ALEJANDRO COLON 4516 FLORENCE AVE APT B MECHANICSBURG, PA 17055 Defendant. C ~ Y ~~L~E~ ~~ Q~ 1lT~F'Y ._.: r t k .. s ~' ~ t~±10 DES f ~ PM 3' : `' r;~J4~3E~L~s-~~~~ C~llt~~'`c` COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. l~ " 7~3 ~i ~~ ~ N(~TTC'.F, 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 ~A ~ 9a~ 717-249-3166 ~"~i~r ulY ~~ l~Sl~~ Our File No.: 272121 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. ALEJANDRO COLON 4516 FLORENCE AVE APT B MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 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 ALEJANDRO COLON, an adult individual residing at 4516 FLORENCE AVE APT B MECHANICSBURG, PA 17055. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending in 8133; 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 $1,079.20. 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 $1,079.20 and requests this Court awazd costs to the extent permitted by applicable law. APOTHAKER & AS C TES, P.C. Attorney fo Pl ' 'ff A Law Firm En~a~e in D bt Collection BY: Dated: 12/8/2010 David J. A Our File No.: 272121 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 relati~ to/Gnsworn falsification to authorities. David J. ApotA~aker, Esquire Attorney for Plaintiff DATE: 12/8/2010 LVNV FUNDING, LLC ALEJANDRO COLON 4516 FLORENCE AVE APT B MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: ALEJANDRO COLON Account Number: ending in 8133 Original Creditor: CREDIT ONE BANK, NA Balance Due: $1,079.20 Our File No.: 272121 EXHIBIT "A" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY U M3 1iLA;ib 1! 3 r• 9F F, .. .. ..rRiFF I ii3 n vC..tC:i? ( `? PLDN ISY Vp?t,lalr LVNV Funding, LLC vs. Alejandro Colon SHERIFF'S RETURN OF SERVICE Case Number 2010-7773 12/28/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Alejandro Colon, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as tot the defendant Alejandre Colon. Request for service at 4516 Florence Avenue, Apartment B, Mechanicsburg, Pennsylvania 17055 the defendant was not found. Deputies were advised Alejandro Colon has never r sided at 4516 Florence Avenue, Apartment B, Mechanicsburg, Pennsylvania 17055. SHERIFF COST: $42.00 December 28, 2010 SO ANSWERS, RON R ANDS RSON, SHERIFF '.C ''7001tySuite jl'elif. TE5i3OSO 1. IM,