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Home My WebLink About14-6983 Supreme Court of Pennsylvania Olt 445701ntin!tbii Pleas 4. C01111A For Prothonotar zivil.,Cover-Sheet y Use Only: MR Docket No: du MBERLX�D C01111t-,, v " ,� The information, collected ori thisfor?n is used solely for coin t administr-ation puipx4aS. :This forma does clot suppleinent or replace thefiling and service of pleadings or othei-papei-s as requii-ed ky Imi-or mies ofcoltrt. S Commencement of Action: E 1Z Complaint El Writ of Summons n Petition []Transfer from Another Jurisdiction F1 Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T CV]LOAN TRUST I DEBORAH A HUNSICKER I Are money damages requested? ® Yes El No Dollar Amount Requested: Z within arbitration limits 0 (check one) [I outside arbitration limits N Is this a Class Action Suit? El Yes 0 No Is this an MDJAppeal? C] Yes Z No A Name of Plaintiff/Appellant's Attorney: Apothaker and Associates,P.C. I-1 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 includeJudgments) CIVIL APPEALS n Intentional [I Buyer Plaintiff Administrative Agencies f-1 Malicious Prosecution Z Debt Collection: Credit Card n Board of Assessment M Motor Vehicle 0 Debt Collection: Other El Board of Elections El Nuisance El Dept.of Transportation n Premises Liability F1 Statutory Appeal:Other 0 Product Liability(does not El Employment Dispute: S include mass tort) Discrimination E 0 Slander/Libel/Defamation El Employment Dispute- Other El Other: [I Zoning Board C jEI Other: 0 Other: o MASS TORT n Asbestos N F1 Tobacco F1 Toxic Tort-DES REAL PROPERTY MISCELLANEOUS r-1 Toxic Tort-Implant E]Ejectment El Common Law/Statutory Arbitration 0 Toxic Waste M Eminent Domain/Condemnation El Declaratory Judgment B El Other: F1 Ground Rent 0 Mandamus E] Landlord/Tenant Dispute D Non-Domestic Relations M Mortgage Foreclosure:Residential Restraining Order F1 Mortgage Foreclosure: Commercial 0 Quo Warranto PROFESSIONAL E3 Partition E3 Replevin LIABLITY E] Quiet Title F1 Other: F1 Dental El Other: F1 Legal n Medical 0 Other Professional: Updated 11112011 Our File No.: 384155 n,fo i APOTHAKER & ASSOCIATES, P.C. Drc r BY: David J. Apothaker, Esquire 113: 02 Attorney I.D.#38423 U T 520 Fellowship Road C306 YLV14 Mount Laurel,NJ 08054 A 1 A (800) 672-0215 Attorneys for Plaintiff CV1 LOAN TRUST I COURT OF COMMON PLEAS 55 BEATTIE PLACE SUITE 110 CUMBERLAND COUNTY GREENVILLE, SC 29601 fq- U9p 6,4 NO. Plaintiff, VS. DEBORAH A HUNSICKER 1180 OYSTER MILL RD CAMP HILL, PA 17011-1058 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 CC-) DdL qt( -7 { Our File No.: 384155 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 CVI LOAN TRUST I ) COURT OF COMMON PLEAS 55 BEATTIE PLACE SUITE 110 ) CUMBERLAND COUNTY GREENVILLE, SC 29601 ) NO.: Plaintiff, ) VS. ) DEBORAH A HUNSICKER ) 1180 OYSTER MILL RD ) CAMP HILL, PA 17011-1058 ) Defendant. ) CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CVI LOAN TRUST I, 55 BEATTIE PLACE SUITE 110, GREENVILLE, SC 29601. 2. Defendant(s) is/are DEBORAH A HUNSICKER ("Defendant"), an adult individual residing at 1180 OYSTER MILL RD, CAMP HILL, PA 17011-1058. 3. Plaintiff is the Assignee and Successor in Interest of a credit account("Account"). 4. The Account number ends in 3566. 5. The Account was issued to Defendant by CITIFINANCIAL, INC.,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 $4,516.47. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant for the sum of$4,516.47 and requests this Court award costs to the extent permitted by applicable law. APOTHAKERAS OCIATES, P.C. Attorne for laintiff A Law Firm Eng ed n Debt Collection BY: David J. Apothaker, Esquire Our File No.: 384155 384155 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. APOTHAKER ASS CIATES, P.C. Attorney for P aintiff A Law Firm Eng. ged i Debt Collection BY: -zz David J. Apo ak squire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff THE P=i0THO 0 Jody S Smith Chief Deputy Richard W Stewart Solicitor 1 J1 I Hi DEC 15 PM 3: 22 CUMBERLAND COUNTY PENNSYLVANIA CV1 Loan Trust 1 vs. Deborah A. Hunsicker Case Number 2014-6983 SHERIFF'S RETURN OF SERVICE 12/09/2014 07:19 PM - Deputy Jamie DiMartile, 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: Deborah A. Hunsicker at 1180 Oyster Mill Road, East Pennsboro Township, Camp Hill, PA 17011. SHERIFF COST: $44.95 SO ANSWERS, December 10, 2014 (c) CountySuite Sherif, Teleosef, Inc. RONR ANDERSON, SHERIFF