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Home My WebLink About12-6491IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV Funding LLC 15 South Main Street CIVIL ACTION Greenville. SC ?9601 Plaintiff vs. NO: ~~ d~ - ~ ~ C~ Shawn Bornes 5 WINEBERRY DF: MECHANICSBURG PA 17055-5671 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 b.y an attorney and. filing in r~7iting 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 t-e 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 c-ther rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YC-U DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 'THE OFFICE STET FORTH BELOW TO FIND OUT WHERE, YOU CAN GET LEGAL I4ELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFF:[CE MAY BI: ABLE TO PROVIDE YOU WITH INFORMATION ON AGE:[~CIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT P,EDUCED F]EE OR NO FE~;E. MIDPENN LEGAL SERVICES 401 EAST LOUTHER'STREET CARLISLE, PA 17013 717-243-9400 ~.. ~~ C ~~~ S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV Funding LLC 15 South Main Street CIVIh ACTION Greenville, SC 29601 Plaintiff vs. Shawn Bornes NO: 5 WINEBERRY DR MECHANICSBURG PA 17055-_5671 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 Shawn Bornes (hereinafte.r "Defendant") is an adult individual residing at 5 WINEB:ERRY DR MECHANICSBURG PA 1705-5671. 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 Citibank with the account number ending in 7782. 5. The within account was sold by Citibank to LVNV Funding LLC for valuable consideration and all rights under said accounts were assigned to LVNV Funding LLC. 6. Use of the Citibank 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 Citibank, and will be provided upon receipt. 7. Defendant used the Citibank credit card with account number ending in 7782, 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. 8. 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 May 21, 2009. 1 ] . The principal amount was $12,695.42 at the time of charge-off: 1 ~:. Pursuant to the account agreement, any unpaid balance accrues interest. 13. The total amount due and owing the Plaintiff including interest, is $].4,830.34. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $14,830.34 plus costs of suit and any other relief as the Court deems just and appropriate. Respectfully submit- `. ~` ~ ~ ~ y ,, ~ , . ~LL ~= ~: ~. „' Edwin A. Abral~fun~en & Assoc. Michael F. RaJ~hford, Esquire Attorney LD. JNos.: 86285 120 North K~yser Ave. Scranton, PA 18'i04 mratchford(c/r~eaa•-law.com Phone: 570-558-:5510 Fax: 570-558-5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff,LVNV FUNDII~IG LLC, am full} 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 bylaw pursuant to 18 C.S.A. 4904. ,~ ~-- `0 ~ ~ ~~-6 u'° " ---- - Michael F. Rat fdi•d, Esquire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~ttr of ~ettttbrrf~~b !OFF i fi is TAE >"~RIFF 2312 t~OV 26 PM 2y ~ CUM Et~NS tVA~ ~ ~+~ Jody S Smith Chief Deputy Richard W Stewart Solicitor t_VNV vs. Shawn E. Bornes Case Number 2012-6491 SHERIFF'S RETURN OF SERVICE 11/14/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Shawn E. Bornes, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 5 Wineberry Drive, Upper Allen Township, Mechanicsburg, PA 17055. Deputies were advised by defendant's employer, Central Penn Plumbing, that the defendant moved to Pittsburgh and provided an address of 110 Farmingdale Drive, Wexford, PA 15090. SHERIFF COST: $48.00 November 14, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF c; vcuntySuite 5hsriff: Tsiecs~~t, Inc. LVNV FUNDING LLC THD CO-BRAND MC(COMMERCI In the Court of Common Pleas of Cumberland County,Pennsylvania. Civil Division Plaintiff ~ =M vs. � urn NO: 12-6491 cor -- D � ca �o fit" Shawn Bornes ' 5 WINEBERRY DR Praecipe to Reinstate Civil Complaint —C MECHANICSBURG PA 17055-5671 Defendant To the Prothonotary of Cumberland County Pennsylvania: Please enter the above Praecipe to Reinstate the Civil Complaint. Thank you, /AMihael F. Ratchfo d,rEsquire Edwin A. Abrah sen&Associates, P.C. Lawyer ID# 862 T; SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F I L P0-(,'1°F i C Sheriff t OTHOINOTAR � I Jody S Smith 27 Chief Deputy Mly Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA LVNV Case Number vs. Shawn E. Bornes 2012-6491 SHERIFF'S RETURN OF SERVICE 04/1812013 05:52 PM-Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Shawn E. Bornes, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint&Notice as"Not Found"at 5 Wineberry Drive, Upper Allen Township, Mechanicsburg, PA 17055.The residence was vacant,this office was provided with an address of 110 Farmingdale Drive, Wexford, PA 15090 on November 14, 2012 by the defendant's employer. SHERIFF COST: $39.30 SO ANSWERS, May 16, 2013 RONNY R ANDERSON, SHERIFF (C)COLIMYSURO Sheriff, oliosoft,inc. C� � LVNV FUNDING LLC _ 15 South Main Street In the Court of Common Pleas of rn Greenville, SC 29601 Cumberland County,Pennsylvaniai Plaintiff Civil Division d i �2c:s _ vs. 3r rs = CD r-3 Shawn Bornes NO: 12-6491 , 110 FARMINGDALE RD Wexford PA 15090-7506 Defendant Praecipe to Reinstate Civil Complaint To the Prothonotary of Cumberland County Pennsylvania: Please enter the above Praecipe to Reinstate the Civil Complaint. Thank y u, ichael . Ratchfo , E quire Edwin A. Abrah sen&Associates, P.C. Lawyer ID # 862 5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �i j q T-�; Jody S Smith dfJ !�_ 2r Chief Deputy ` "�p "F 31 CUMBEiRLAND Richard W Stewart ¢" PEPs S Y L�V C€�A �l' SolicitorE fiq LVNV vs. Case Number Shawn E. Bornes 2012-6491 SHERIFF'S RETURN OF SERVICE 06/21/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Shawn E. Bornes, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Complaint& Notice according to law. 07/15/2013 The requested Complaint& Notice returned by the Sheriff of Allegheny County, the within named Defendant Shawn E. Bornes, not found. William Mullen, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, July 24, 2013 RONW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson '�'fltot+, # urhbrrT��d Sheriff Jody S Smith - Richard W Stewart Chief Deputy OFPCE OF THE$HER1FF Solicitor LVNV Case Number vs' 2012-6491 Shawn E. Bornes o '`t SERVICE COVER'SHEET N a► Service Details: _ __ _ o Category: jCivI1 Action-Complaint& Notice Zone: X Manner: IDeputize Expires: 07/19/2013 Warrant: w - Notes: Ln m a Q a ci ,Serve To: _ Final Service: Name:� 'iShawn E. Bornes Served: Personally Adult In Charge Posted Other Primary 110 Farmingdale Drive Adult In Address: Wexford, PA 15090 Charge: L } Phone: 724-713-8130 DOB: 08/25/1971 Relation: Alternate ater Time: o Address: z Phone Deputy. Mileage: u< Attorney l Originator: _ e Name: IMichael F. Ratchford I Phone: 570-558-5510 r r Service Attempts: _ -- - Bate: f 4 Time: v tD Mileage: N c Deputy: 2 3 6 N Notes/Special Instructions: pto yu¢ q fs4�Gt 78 r ui yv z ---------------------------------------- Q Now, June 21, 2013 1, Sheriff of Cumberland County, Pennsylvania do hereby deputize Sheriff of Allegheny County to vi execute service of the documents herewith and make return thereof according to law, C6 W Return To: Cumberland County Sheriffs Office COMMONWEALTH OF PENNSYLVANIA m One Courthouse Square Notarial seal Eda lean Woodward,Notary Public 6�' Carlisle, PA 17013 � City of Pittsburgh,Allegheny County Ronny R Anderson, Sheriff My Comntit9lan1VpiteVMBy 28,.F2016nc MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES LVNV FUNDING LLC .• 15 South Main Street In the Court of Common Pleas of „ -7-t Greenville, SC 29601 Cumberland County,Pennsylvania =--; Plaintiff : Civil Division ' p r 'i 5 c-) Wit. ' vs. : Vic- tv . + may' • Shawn Bornes NO: 12-6491 1� 5 WINEBERRY DR : Z i Mechanicsburg PA 17055 T' r Defendant : • . Praecipe to Reinstate Civil Complaint • • • • • • To the Prothonotary of Cumberland County Pennsylvania: Please enter the above Praecipe to Reinstate the Civil Complaint. Thank you, I ichael F. 'atchford, E •uire Edwin A. Abrahamsen Associates, P.C. Lawyer ID # 86285 6) ax),,, ,\ :1S 0 cA+S CL 6 a113 p AQ I3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheri . Sheriff cum+rr y� Jody S Smith Z�y 8 t' ` fifV 1 t,l Chief Deputy i_ �^ �{�'i a .r\L L is jr, Richard W Stewart „ Solicitor - - LVNV Case Number vs. Shawn E. Bornes 2012-6491 SHERIFF'S RETURN OF SERVICE 01/06/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Shawn E. Bornes, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Found"at 5 Wineberry Drive, Upper Allen Township, Mechanicsburg, PA 17055. Residence is vacant and per the Mechanicsburg Postmaster the defendant now resides at 110 Farmingdale Road, Wexford, PA 15090, which is located in Allegheny County. SHERIFF COST: $39.76 SO ANSWERS, January 06, 2014 RONNK ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , LVNV FUNDING LLC Plaintiff CIVIL ACTION VS. NO: 12-6491 Shawn Bornes Defendant PRAECIPE TO DISCONTINUE To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Discontinue the civil complaint without prejudice. Thank you, hael F. Ratchford, Esquire Abrahamsen Ratchford, P.C. Lawyer ID # 86285 120 N. Keyser Avenue Scranton, PA 18504