HomeMy WebLinkAbout06-1584
GREGG 1. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE,PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
L VNV FUNDING, L.L.c.
Plaintiff,
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) NO. 00 - /51fY
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tdJ
v.
JOANNE CROUMER ,
Defendant(s).
COMPLAINT IN CIVIL ACTION
Filed on behalf of:
L VNV FUNDING, L.L.c.,
Plaintiff
Counsel of Record for This Party:
Gregg 1. Morris, Esquire
Pa LD. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, P A 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant.
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) NO.
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LVNV FUNDING, L.L.C.,
Plaintiff,
v.
JOANNE CROUMER ,
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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
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 S, BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
L VNV FUNDING, L.L.C.,
Plaintiff
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~ NO. (7(p- /5,/'/ G-....t. ~I.u--.
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v.
JOANNE CROUMER ,
Defendant
COMPLAINT IN CIVIL ACTION
AND NOW, comes Plaintiff, L VNV FUNDING, L.L.C., above named, the purchaser
and assignee of the obligation under suit, by and through its attomey,GREGG L. MORRIS,
ESQUIRE and the law offices of PATENAUDE & FELIX, A.P.C. and files the following
Complaint in Civil Action, and in support thereof aver as follows:
1. Plaintiff, L VNV FUNDING, L.L.C., (hereinafter L VNV) is a limited
partnership, the assignee of Shennan Originator, LLC, maintaining a place of business at 15
South Main Street, Greenville, SC 29601.
2. Plaintiff, LVNV, is the successor in interest of the obligation under suit from
Shennan Originator, LLC.
3. Defendant is JOANNE CROUMER , an adult individual, believed to currently
reside at 228 E GARFIELD ST , SHIPPENSBURG, P A 17257.
4. Defendant obtained extensions of credit, purchases or cash advances on the
following open ended credit card account number 1150021338449
issued by SEARS,
ROEBUCK AND COMPANY.
5. The Defendant made payments, but has refused to pay, and now refuses to pay
the balance due and owing on the aforesaid account in the sum of $3,284. 70, plus interest
and costs.
6. The Defendant has received monthly billing statements setting forth the nature
and amount of all charges made by Defendant, and the transactions give rise to an account
stated, upon which Plaintiff has relied.
7. By failing to object or dispute the amounts on the statements, Defendant has
assented to and agreed to the correctness of the balance due on the aforesaid credit card
account so as to constitute and account stated.
8. Despite repeated demands, Defendant has failed to make the required installment
payments when due and therefore the full amount of the account is now due and payable.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant, in the
amount of$3,284.70 with continuing interest thereon at the legal rate from the date of
Judgment plus costs. The aforesaid amount is within the jurisdictional amount requiring
compulsory arbitration.
Respectfully Submitted'
ORRIS, SQUIRE
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
...
VERIFICATION
AND NOW, GREGG 1. MORRIS, verifies the statements made in this Complaint
that are true and correct to the best of his knowledge, information and belief. I
understand that false statements herein are made subject to the penalties ofPa.C.S.
Section 4904, relating to unsworn falsification to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the Court and
the verification cannot be obtained within the time al10wed for the filing of this pleading,
the pleading is submitted by counsel having sufficient knowledge, infornlation and belief
based upon the information provided to him by the Plaintiff. The verification of the party
will be provided if requested.
Date: March 15, 2006
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GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
L VNV FUNDING, L.L.C.
Defendant(s).
)
)
) NO. 06-1584
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Plaintiff,
v.
JOANNE CROUMER ,
PRAECIPE FOR
DEFAULT JUDGMENT
Filed on behalf of:
L VNV FUNDING, L.L.C.,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa LD. #69006
Patenaude & Felix, A.P.c.
213 East Main Street
Carnegie, P A 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
LVNV FUNDING, L.L.C.,
Plaintiff
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)
) NO. 06-1584
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v.
JOANNE CROUMER ,
Defendant( s)
PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
Please enter a judgment against the Defendant(s), above named, for failure to file an Answer
to Plaintiffs complaint.
Amount claimed in Complaint
Interest from October 03,2005
Attorney's fees
TOTAL
$3,284.70
$106.75
$0.00
$3,391.45
With continuing interest on the principal amount of$3,391.45, with interest at the legal rate,
plus costs of suit.
I hereby certifY that a written notice of intention to file this praecipe was mailed to the
Defendant(s) and Defendant(s) counsel (if known), after the default had occured and at least ten (10)
days prior to the date of the filing of this praecipe. A copy of the Notice is atta ed.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
L VNV FUNDING, L.L.C.,
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) NO. 06-1584
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Plaintiff
v.
JOANNE CROUMER,
Defendant( s)
PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF
NOTICE PURSUANT TO PA.R.C.P.I037(b)
COMMONWEALTH OF PENNSYLVANIA )
)
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and State,
Personally appeared Gregg L. Morris, Attorney for and authorized representative of Plaintiff, who being
duly sworn according to law, deposes and states that the Defendant(s), JOANNE CROUMER , is not in
the military service of the United States of America to the best of his knowledge, information and belief
and certifies that Notice ofIntent to take Default Judgment was mailed in accordance with Pa.R.C.P.
237.1, as evidenced by the attached copy.
G L. S, ES UI
tenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
Sworn to and subscribed before me
this~ayof~ 20W,
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Notary Publ c
NOTARIAL SEAL
GRETA A JEWEU
Nofary Public
CARNEGIE BOROUGH, ALLEGHENY COUNTY
My Commllslan expires Nov 18, 2009
GREGG 1. MORRIS, ESQ
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE,PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff,
)
)
) NO. 06-1584
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)
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L VNV FUNDING, L.L.C.
v.
JOANNE CROUMER ,
Defendant(s).
IMPORTANT NOTICE
Filed on behalf of:
L VNV FUNDING, L.L.c.,
Plaintiff
Counsel of Record for This Party:
Gregg 1. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
LVNV FUNDING, L.L.C.,
Plaintiff
)
)
) NO.06-!584
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)
v.
JOANNE CROUMER ,
Defendant( s)
To: JOANNE CROUMER
228 E GARFIELD ST
SHIPPENSBURG, P A 17257
Date of Notice: April!!, 2006
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PEROSONALL Y OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICECAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
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 ASSOCIA nON
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
~~.
I, GREGG L. MORRIS, attorney for Plaintiff, L VNV FUNDING, L.L.C., hereby
certify that a true and correct copy ofthe foregoing document was served this day by US
First Class Mail, postage prepaid upon the following:
JOANNE CROUMER
228 E GARFIELD ST
SHIPPENSBURG, P A 17
/'-~
L. 0 squire
Patenaude & Fell, A.P.c.
Attorneys for Plaintiff
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
Date: April 11, 2006
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GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant(s).
)
)
) NO. 06-1584
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L VNV FUNDING, L.L.C.
Plaintiff,
v.
JOANNE CROUMER ,
NOTICE OF ORDER,
DECREE OR JUDGMENT
Filed on behalf of:
L VNV FUNDING, L.L.c.,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa 1.0. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant( s)
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)
) NO. 06-1584
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LVNV FUNDING, L.L.C.,
Plaintiff
v.
JOANNE CROUMER ,
NOTICE OF ORDER DECREE OR JUDGMENT
TO: ( ) Plaintiff ( X ) Defendant ( ) Garnishee ( ) Additional Defendant
You are hereby notified that the following Order, Decree, or Judgment has been entered
against you on -.fl.p;' ~, ;;Z ~ ;;. fy:>i,.,
I
( ) Decree Nisi in Equity
( ) Final Decree in Equity
( X ) Judgment of ( ) Confession
( X) Default
( ) Non-Pros
( ) Verdict () Court Order
( ) Non-suit
( ) Arbitration Award
(X) Judgment in the amount of$3,391.45, plus cost.
( ) District Justice Transcript ofJudgment in the amount of$
plus costs.
( ) Ifnot satisfied within sixty (60) days, your motor vehicle operator's license wil be
suspended by the Department of Transportation.
{2~
By
Deputy
If you have questions concerning the above, please contact:
Name of Attorney: GREGG L. MORRIS, ESQUIRE
213 E. Main Street
Carnegie, P A 15106
(412) 429-7675
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01584 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LVNV FUNDING LLC
VS
CROUMER JOANNE
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CROUMER JOANNE
the
DEFENDANT
, at 1800:00 HOURS, on the 21st day of March
, 2006
at 228 E GARFIELD STREET
SHIPPENSBURG, PA 17257
by handing to
JOANNE CROUMER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18,00 .-/?'/ /~
17.60 .r ~,,?- -<: 1'" ~
.00
10.00 R. Thomas Kline
.00
45.6011..,03/22/2006
~PATENAUDE & FELIX
Sworn and Subscribed to before By:
A.D.
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