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Home My WebLink About05-4739 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LVNV FUNDING LLC Plaintiff No: OS - '-1139 OlutlY~ vs. COMPLAINT IN CIVIL ACTION BONNIE L CROSSLEY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04209870 C A Pit KMJ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LVNV FUNDING LLC Plaintiff vs. Civil Action No BS- qf39 CuJ ~ BONNIE L CROSSLEY Defendant COMPLAINT AND 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 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 ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 . COMPLAINT 1. Plaintiff, LVNV FUNDING LLC is a corporation with offices at 15 SOUTH MAIN ST STE 700 GREENVILLE , SC 29601 . 2. Defendant is an adult individual(s) residing at the address listed below: BONNIE L CROSSLEY 3536 ROLO CT MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 92889458 . 4. Defendant made use of said credit card and has a current balance due of $2153.24 , as of July 13, 2005 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000% per annum on the unpaid balance from July 13, 2005 . A copy of Plaintiff's Statement of Acco unt is attached hereto, marked as Exhibit "I" and made a part hereof. p 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , BONNIE L CROSSLEY , individually , in the amount of $2153.24 with continuing interest thereon at the rate of 6.000% per annum from July 13, 2005 plus costs. This law firm is a debt collector a our client and any information obta L.P.A. 2718 to collect this debt for be used for that purpose. ~ ~.jj. ,.c(:IJ f lJ'\ .~ *U:f Alegis Group LP Post Office Box 10466 Greenville, South Carolina 29603 Current Owner: Sherman Acquisition II LP Original Creditor: Sears: Citi-Sears Previous Owner: Citibank Statement Closing Date: 03/14/2005 BONNIE L CROSSLEY 3536 ROLO CT MECHANICSBURG, PA 17055 Account number Purchase Balance Payments Credit adjustments Finance charges New Balance 1150126858515 $ 2,153.24 $ $ $ $ 2,153.24 TRANSACTIONS Transaction Date Description Amount This statement is not an oriQinal. EXHIBIT I This statement has been generated on behalf of Sherman Acquisition LP, account owner. Alegis Group LP is a wholly owned subsidiary of Sherman Financial Group LLC. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A. C.S. S4904 relating to unsworn falsifications to authorities, that I am Attorney in fact for, L VNV Funding LLC Plaintiff of the account of BONNIE L CROSSLEY, account number 1150126858515 herein, that I am duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his /her knowledge, information and belief. Executed this 26th day of August, 2005. L VNV Funding LLC, as assignee of, Citibank, By its: ~ C ~ (Signature) Name: Steve Hawkins Attorney in Fact Subscribed and sworn to before me This 26th day of August, 2005. Tammy E. Garrettl Notary Public . State of South Carolina I __~L<2~mm E~~_~~2-24____j WWR# Weltman Verification P A )::) (.) ~ 1f "- ~ "'- l' )..; Vl ~ }., D ~ ~ ~ (Ywr- ~~ ~ ( -) ,......, : ~ <~ ('J' -~.l (n .--l t" :-;- ~_' rn; i ~ - '''.,J ( o,j ( ,.' CJ SHERIFF'S RETURN - REGULAR CASE NO: 2005-04739 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS CROSSLEY BONNIE L VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CROSSLEY BONNIE L the DEFENDANT , at 1918:00 HOURS, on the 30th day of September, 2005 at 3536 ROLO CT MECHANICSBURG, PA 17055 by handing to RUSS YODER, BOYFRIEND, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 12.00 .00 10.00 .00 40.00 ?'~~-'~~ R. Thomas Kline me this -:1.J1., day of 10/03/2005 WELTMAN WEINBERG REIS By: Yd: 1// Deputy Sheriff Sworn and Subscribed to before A.D. Pro . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LVNV FUNDING LLC Plaintiff No,05-4739CIVIL vs, PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE BONNIE L CROSSLEY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C, WARMBRODT PA I.D#42524 WELTMAN, WEINBERG & REIS CO, L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04209870 . ' l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LVNV FUNDING LLC Plaintiff vs, Civil Action No, 05.4739CIVIL BONNIE L CROSSLEY Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid, WELTMAN, WEINBERG & REIS CO, LPA SWORN TO AND SUBSCRIBED before me this 3 ( day """ -_._~ of ;\',)1<:."" ~_. 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