The URL can be used to link to this page

Home My WebLink About08-1972 Our File No.: 148603 ,APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. MARY L EGAN 608 3RD ST NEW CUMBERLAND, PA 17070-2017 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ag- 1412 bVit -ter," NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must a action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by atto ey an d filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fai to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or o er rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA ER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE Y U CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuestas en las paginas s guientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparenci escrita o con un abogado v entregar a la corte en forma escrita sus objeciones a las demandas en contra de su persona. Sea avisado q e si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Adem , la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisioner de esta demanda. Usted pu de perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO IENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA FICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASI TENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 % ,. APOTHAKER & ASSOCIATES, P.C. •BY: David J. Apothaker, Esq. Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. MARY L EGAN 608 3RD ST NEW CUMBERLAND, PA 17070-2017 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant is MARY L EGAN, an adult individual residing at 608 3RD ST NEW CUMBERLAND, PA 17070-2017. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiffs and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any A true and/or leaving a balance due and owing of $2,054.54. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is WELLS FARGO FINANCIAL. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the slum of $2,054.54 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicab e law. APOTHAKER & nedin IATES, P.C. AttornenA Law Fi rm na ebt Co ction I BY: Dated: 3/13/2008 David J. Our File No.: 148603 VERIFICATION David J Apothaker, Esq. hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correc to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to n<Iorn falsification to authorities. DavidV.Apothaker 4ttorne or Plaintiff DATE: 3/13/2008 NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 MARY L EGAN 608 3RD ST NEW CUMBERLAND, PA 17070-2017 STATEMENT OF ACCOUNT Debtor's Name: MARY L EGAN Account Number: 14440711 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $2,054.54 Our File No.: 148603 EXHIBIT "A" C=D ? -rt N co (? C 00 O SHERIFF'S RETURN - REGULAR CASE NO: 2008-01972 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS EGAN MARY L ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE EGAN MARY L DEFENDANT was served upon the , at 1850:00 HOURS, on the 24th day of April , 2008 at 608 3RD STREET NEW CUMBERLAND, PA 17070 MARY EGAN by handing to 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 18.00 Service 51.00 Affidavit .00 Surcharge 10.00 / .00 1/h thV, 79.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 04/25/2008 APOTHAKERR&& ASSOCIATES By 4 / Deputy Sheriff A.D. Our File No.: 148603 APOTHAKER & ASSOCIATES, P.C. BY: David J.'Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, vs. MARY L EGAN Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1972 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, MARY L EGAN, in the default of an Answer, in the amount of $911.28 computed as follows: Amount claimed in complaint: $ 2,054.54 Less: Amount Paid: ( 1,174.00) Plus: Interest from March 13, 2008 to August 12, 2009 at the legal interest rate of 6.00% per annum 30.74 Attorney fees 0.00 TOTAL $ 911.28 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. 1 certify Defendant, MARY L EGAN, last known address is 608 3RD ST NEW CUMBERLAND, PA 17070- 2017 APOTHAKER A Law Firm By: ?OCIATES, P.C. Plaintiff in Debt Collection Dated: August 12, 2009 Our File No.: 148603 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, VS. MARY L EGAN Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1972 : SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 608 3RD ST NEW CUMBERLAND, PA 17070-2017. We inquired with the web site of the Defe Boulevard, Suite 400, Arlington, VA 22209-2593, if Mary M. Snavely-Dixon, Director of the Def n Manpower indicated that the Defendant(s) is/are not in the mili / David J. Apothaker Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. APOTHAKER&ASSOCIATES, P.C. Department of Defense NInVowe r Data Cutter Military Stag Report Pursuant to the SwAcemembers Civil Relief`Act Fi?VNrmddJe l Begi! Data Adive Die Sta#aa ATTORNEYS AT LAW AUG-12-2649 08:13:26 EGA' NUR.Y L Based on the informations you have fxnn shed, the ma)c does not po s sess any iafammfim indicating that the ' is cme * on active duty.. Upm searching the infixinabon data banes of the Department of Defense Manpower Data Centex, based on the iuoxm&on that you provided, the above is the currant status ofthe inidiuidual as to all branches of the Military, rho,, n .c..?,_c?. Mary M. Snavely-Dixon, Direct Department of Defense - Manpower Data Center 1644 Wilson Blvd.. She 444 Arlington VA 22209-2593 The Defense Manpower Data Ceder (DNIDC) its an organizatkm of the Departs of'Def=e that mks the Defense E rollment and Efigibilky Reporting System (DEERS) database which is the official source of data on a ibUy for military medical care and otter eiity systems_ The Department of Defense strongly smarts the a urorce meat of the Se r emembers Civil Rem Act [56 USCS Appx- §§ 541 et seq] (SCRA) (#'orn dy the Sears' and Sailors' Cif RAdAct of 1940). DMDC has issued hundreds of &x ands of "sloes not possess any i nfotmattnt indicating that the individuial is can vally on active duty" responses, and has experienced a small error rate. In the eve the ixfvi" referenced above, or any family member, friend, or representative asserts in any mariner that tfte inckvidumd is on active duty, or is obese entitled to the protections of the SCRA, yon we strongly encouraged to obtain firrther verification ofthe persoes active duty status by contacting that persod!s Military Service'vita the "defrusdiuk nir URL provided below. Ifyou have evidence the person is on active-day and you fail to obtain this additionalMikary Service v iilica tiara, pr+a utons of the SCRA may be kvoked against you. If you obtain further hem about the person ( e_g., an SS2, ievroved accuracy ofDOB, a noddle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical enonuatioat, please contact the Nfilitary Service SCRA points- of-contact. Se r. loo./Iwww.defms+elmk.uifmtpiw' CQ9SLDR.btni WARNING- This certificate was provided baser on a name and Social Security number (SS provided Providing an erroneous name or SSN will cause an erroneous certificate to be provided. by the requester, 148603 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) MARY L EGAN ) NO. 08-1972 To: MARY L EGAN 608 3RD ST NEW CUMBERLAND, PA 17070-2017 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: July 21, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 DA J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR. CASE NO: 2008-01972 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION APR 2 8 2008 VS EGAN MARY L ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon EGAN MARY L the DEFENDANT at 1850:00 HOURS, on the 24th day of April , 2008 at 608 3RD STREET NEW CUMBERLAND, PA 17070 MARY EGAN by handing to 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 18.00 Service 51.00 Affidavit .00 Surcharge 10.00 .00 79.00 Sworn and Subscibed to before me this day of , So Answers: +°"• ' R. Thomas Kline 04/25/2008 APOTHAKER & ASSOCIATES "?4 ?(?l 427? Deputy Sheriff A.D. R El ?,.,fi i"iTAP L 2009 AUG 27 P ? 1, L 3 t Li.. _ .; a'tir fi, ?ly oo ANy Al /? / t17 tm - iZIC'?f a7ay???' 'Lpl a 44 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: MARY L EGAN 608 3RD ST NEW CUMBERLAND, PA 17070-2017 NORTH STAR CAPITAL } COURT OF COMMON PLEAS OF ACQUISITION LLC ) CUMBERLAND COUNTY Plaintiff, vs. MARY L EGAN Defendant. NOTICE NO.: 08-1972 Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esg. at this telephone number: 215-634-8920 07/0