HomeMy WebLinkAbout11-8491LVNV Funding LLC
15 South Main Street
Greenville, SC 29601
VS.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA - Ca-n
CIVIL ACTION - = "
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Plaintiff
Bonnie Snyder
5 Buttonwood Ln
CARLISLE PA 17015-7801
No: ll- SYq I ??°iC ?i?
Defendant :
NOTICE TO DEFEND
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 to Defend are
served, by entering a written appearance personally or by an 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 ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
-50
?J, 00
C# 6310
P---d- .0-6 7/9 7
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LVNV Funding LLC
15 South Main Street
Greenville, SC 29601
VS.
Bonnie Snyder
5 Buttonwood Ln
CARLISLE PA 17015-7801
: CIVIL ACTION
Plaintiff
NO:
Defendant
COMPLAINT
Plaintiff, LVNV Funding LLC, by and through its attorneys, Edwin A. Abrahamsen &
Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, LVNV Funding LLC, (hereinafter "Plaintiff") is a Delaware corporation
with a principal place of business located at 15 South Main Street Greenville, SC 29601.
2. The Defendant Bonnie Snyder (hereinafter "Defendant") is an adult individual
residing at 5 Buttonwood Ln CARLISLE PA 17015-7801.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase
and collection.
4. Defendant applied for and received a credit card issued by GE Capital with the
account number 6044051000207140.
5. The within account was sold by GE Capital to LVNV Funding LLC for valuable
consideration and all rights under said accounts were assigned to LVNV Funding LLC.
6. Use of the GE Capital credit card was subject to the terms and conditions of the
Cardmember Agreement (hereinafter "Agreement"), a copy of which was sent along to the
Defendant with the credit card. A copy of this document has been requested from GE Capital, and
will be provided upon receipt.
7. Defendant used the GE Capital credit card with account number,
6044051000207140, for purchases, cash advances and/or balance transfers. Use of the card in this
manner constituted acceptance of the terms and conditions and subjects the Defendant to the terms
and conditions contained therein.
The Defendant was mailed monthly account statements relative to the Defendant's
use of the subject credit card.
9. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
10. The Defendant last made payment on January 24, 2008.
11. The principal amount was $$17,163.23 at the time of charge-off.
12. Pursuant to the account agreement, any unpaid balance accrues interest at the
contract rate of 13.24%.
13. The principal amount was $17,163.23 at the time it was received by Plaintiff.
14. The total amount due and owing the Plaintiff including interest, is $24,192.14.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $24,192.14 plus costs of suit and any other relief as the Court deems just and
appropriate.
Edwin A. Abrahamsen &
Michael F. Ratchford, Esi
Attorney I.D. Nos.: 8628'
120 North Keyser Ave.
Scranton, PA 18504
mratchford@eaa-law.co
Phone: 570-558-5510
Fax: 570-558-5511
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff,LVNV FUNDING LLC, am fully familiar
with the facts set forth in the within Complaint and am authorized to make this Verification on
behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to
the best of my knowledge, knowing that any false statements are punishable by law pursuant to
18 C.S.A. 4904.
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
eE p'OTHONC TA" .
2911 NOV 28 AM 8* 42
?JMBERLANO COIAT
PENNSYLVANIA
LVNV Funding, LLC Case Number
vs.
Bonnie Snyder 2011-8491
SHERIFF'S RETURN OF SERVICE
11/17/2011 03:16 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
November 17, 2011 at 1516 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Bonnie Snyder, by making known unto herself personally, at 5 Buttonwood
Lane, 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.
SHERIFF COST: $34.00
November 18, 2011
?-
GEF?ALD WORTH INGTO , EPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
David D. Buell'
Trothonotag
Office of _ - - -/
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Solicitor
"-Ogg/ CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28 DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
On'e Courthouse Square Juite100 [brriste,PA 0 None D72��95 Ta.x717240-6573