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Home My WebLink About14-6332 Supreme Court of Pennsylvania Co><it. of Colli on Pleas Civil C:o--er Sheet ForPTothonotat:p• Use Uttly: CUMBERLAND C:ou>ilt�- Docket No: The iarfot7taatiota collected on this form is used solely for court adininisl ation p aposes. lhis fiwm Moes trot supplement or replace the f ling and sevvice of pleadings or other papers as required by lenv or males of court. S Commencement of Action: E ®Complaint ❑Writ of Summons ❑Petition El Transfer from Another Jurisdiction El Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T LVNV FUNDING, LLC TITO TEP I Are money damages requested? ® Yes ❑ No Dollar Amount Requested: ®within arbitration limits Q (check one) ❑outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff/Appellant's Attorney: Apothaker and Associates,P.C. ❑ Check here if you have no attorney(are a. Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ® Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability(does not S include mass tort) ❑ Employment Dispute: Discrimination E ElSlander/Libel/Defamation EI Other: El Employment Dispute: Other C ❑Zoning Board T ❑ Other: I ❑ Other: o MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain/Condemnation ❑Declaratory Judgment B ❑ Other: ❑ Ground Rent ❑Mandamus ❑Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto PROFESSIONAL ❑ Partition ❑Replevin LIABLITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑Legal ❑Medical ❑ Other Professional: Updated 1/1/2011 Our File No.. 383377TA APOTHAKER&ASSOCIATES P.C. BY: David J. Apothaker, Esquirez,`r' ! 30 ? Attorney I.D.#38423 520 Fellowship Road C306 ;'j .�A i,ii- Mount Laurel,NJ 08054 t (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC ) COURT OF COMMON PLEAS 55 BEATTIE PLACE SUITE 110 ) CUMBERLAND C UNT GREENVILLE, SC 29601 (� 2 - y NO.: -1 - ✓�� vl Plaintiff, ) vs. ) TITO TEP ) 3627 LISBURN RD ) MECHANICSBURG, PA 17055-6710 ) Defendant. ) 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 5 S• �7 ,� P L Gail . � � e) Our File No.: 383377 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 ) COURT OF COMMON PLEAS 55 BEATTIE PLACE SUITE 110 ) CUMBERLAND COUNTY GREENVILLE, SC 29601 ) NO.: Plaintiff, ) vs. ) TITO TEP ) 3627 LISBURN RD ) MECHANICSBURG, PA 17055-6710 ) Defendant. ) CIVIL ACTION COMPLAINT FIRST COUNT I. Plaintiff is LVNV FUNDING, LLC, 55 BEATTIE PLACE SUITE 110, GREENVILLE, SC 29601. 2. Defendant(s) is/are TITO TEP ("Defendant"), an adult individual residing at 3627 LISBURN RD, MECHANICSBURG, PA 17055-6710. 3. Plaintiff is the Assignee and Successor in Interest of a credit account ("Account"). 4. The Account number ends in 9177. 5. The Account was issued to Defendant by Wells Fargo Bank, N.A./SAPPHIRE POOLS LLC,the original creditor. 6. Defendant received, accepted and used the account by making purchases, balance transfers, and/or cash advances. 7. The account is in default due to Defendant's failure to make timely payments. 8. Although demand has been made, Defendant has failed to make payment of the amount due. 9. The amount due as of this date is $8,509.45. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant for the sum of$8,509.45 and requests this Court award costs to the extent permitted by applicable law. APOTHAKE &ASSOCIATES, P.C. Attrney fo Plaintiff ALaw Firm gage in Debt Collection BY: David J. Apotha er, Esquire Our File No.: 383377 S 383377 VERIFICATION I, David J. Apothaker, Esquire, hereby verify subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities that I am counsel for Plaintiff in this action, that I make this Verification based upon the facts as supplied to me by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court, and that the facts set forth in the foregoing Civil Action Complaint are true and accurate to the best of my knowledge, information, and belief. APOTHAQngaged ATES, P.C. Atiff A Law Firbt Collection BY: David J. ApotNaker, Esquire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson • E -ii -OF H,CE Sheriff i HE PROTIMOTRIV,' Jody S Smith Chief Deputy Richard W Stewart Solicitor t OFF C4 OF riiE SitERIFF 20111 ROY 17 PH 3:03 CUMBERLAND COUNTY PENNSYLVANIA LVNV Funding, LLC vs. Tito Tep Case Number 2014-6332 SHERIFF'S RETURN OF SERVICE 11/03/2014 08:24 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Tito Tep at 3627 Lisburn Road, Lower Allen Township, Mechanicsburs PA 17055. GUTSHALL, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, November 05, 2014 RON& R ANDERSON, SHERIFF (c) CounlySuite Shentf, •teleosoft. Inc. Tito Tep, Pro Se 3627 Lisburn Road Mechanicsburg, PA 17055-6710 Tel. LVNV FUNDING, LLC 55 BEATTIE PLACE, SUITE 110 GREENVILLE, SC 29601 Vs. I- !!_LD [HE PnO T Fir 2 R NOV 18 AH IG: 53 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Plainti$ Case No. pi -,6332 Cu i TITO TEP 3627 LISBURN ROAD MECHANICSBURG, PA 17055-6710 Defendant. 1. 2. 3. 4. 5. 6. 7. 8. 9. DEFENDANT'S ANSWER TO CIVIL ACTION COMPLAINT FIRST COUNT Admitted. Admitted. Neither admitted nor denied and Defendant leaves Plaintiff to their proofs. Defendant further challenges this if Plaintiff has become an assignee or successor in interest. Neither admitted nor denied and Defendant leaves Plaintiff to their proofs. Admitted. Admitted. Denied as untrue. The account is in default due to the original creditor. The original creditor wrongfully, tortuously, and fraudulently took the funds without provided the products and/or serves promised, all the while telling Defendant that the product/services would be provided at a time after the time of sale. Admitted. Denied as untrue because the original creditors malfeasance, no funds are due. Dated: i ffS f , 2014 Tito Tep, Pro Se