HomeMy WebLinkAbout08-2866Our File No.: 100250
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.
RICHARD B DORSEY
3 CARDAMON DR
MECHANICSBU:RG, PA 17050
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: M- 028(0(0 IV it TerM
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.
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 siguientes,
usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia 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 que si usted
no se defiende, la corte tomara medidas y puede continuar ]a demanda en contra suya sin previo aviso o notificacion. Ademas, la corte
puede decidir a favor del edemandante y requiere que usted compla con todas las provisiones de esta demanda. Usted puede perder
dinero o sus propiedades a otros derechos importantes pare usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL
DINERO SUFICIENTE DE PAGAR TAI, SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA
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.
RICHARD B DORSEY
3 CARDAMON DR
MECHANICSBURG, PA 17050
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 48-44' Ca ?r?
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 RICHARD B DORSEY, an adult individual residing at 3 CARDAMON DR
MECHANICSBURG, PA 17050.
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 records. A true
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 goods and/or
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 payments,
leaving a balance due and owing of $1,170.32.
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, Account Number 68479514.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
$1,170.32 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
SECOND COUNT
10. 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 records. A true
and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "B".
11. Defendant received and accepted the goods and/or services described in Exhibit "B".
12. The prices set forth in Exhibit "B" are the fair, reasonable and market prices for said goods and/or
services, and the prices which Defendant agreed to pay.
13. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "B".
14. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments,
leaving a balance due and owing of $3,006.94.
15. Although demand has been made, Defendant has failed to make payment of the amount due as
above.
16. The original creditor is WELLS FARGO FINANCIAL, Account Number 44612142.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
$3,006.94 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
$4,177.26 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER & SOCIATES, P.C.
Attorne o Plaintiff
.A Law Firm En Re in Debt Collection
BY:
Dated: 4/14/2008
Da
Our File No.: 100250
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 correct 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 ty(un?worn falsification to authorities.
David &4 othaker
Attorney Plaintiff
DATE: 4/14/2008
NORTH STAR CAPITAL ACQUISITION LLC
c/o Apothaker & Associates, P.C.
2417 Welsh Road, Suite 21 #520
Philadelphia, PA 19114
RICHARD B DORSEY
3 CARDAMON DR
MECHANICSBURG, PA 17050
STATEMENT OF ACCOUNT
Debtor's Name: RICHARD B DORSEY
Account Number: 68479514
Original Creditor: WELLS FARGO FINANCIAL
Balance Due: $1,170.32
Our File No.: 100250
EXHIBIT "A"
NORTH STAR CAPITAL ACQUISITION LLC
c/o Apothaker & Associates, P.C.
2417 Welsh Road, Suite 21 #520
Philadelphia, PA 19114
RICHARD B DORSEY
3 CARDAMON DR
MECHANICSBURG, PA 17050
STATEMENT OF ACCOUNT
Debtor's Name: RICHARD B DORSEY
Account Number: 44612142
Original Creditor: WELLS FARGO FINANCIAL
Balance Due: $3,006.94
Our File No.: 148597
EXHIBIT "B"
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02866 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NORTH STAR CAPITAL ACQUISITION
VS
DORSEY RICHARD B
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
DORSEY RICHARD B
the
DEFENDANT , at 1130:00 HOURS, on the 16th day of May 2008
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
by handing to
RICHARD B DORSEY
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Additional Comments
DEFENDANT'S ADDRESS IS 3500 COPE DRIVE MECHANICSBURG
Sheriff's Costs: So Answers:
Docketing 1.8.00
Service 10.00
Affidavit .00
i
Surcharge 10.00 R. Thomas Kline
SAI 2/0 P 7"- 0 0
38.00 05/16/2008
APOTHAKER & ASSOCIATES
Sworn and Subscibed to
By: before me this day
Deputy Sheriff
of
A.D.
Our File No.: 100250
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.
RICHARD B DORSEY
Defendant.
TO THE PROTHONOTARY:
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 08-2866
Civil Action
PRAEC1 PE FOR DEFAULT JUDGMENT
Kindly enter judgment against Defendant, RICHARD B DORSEY, in the default of an Answer, in the amount
of $4,393.04 computed as follows:
Amount claimed in complaint: $4,177.26
Amount Paid: - $(0.00)
Interest from April 14, 2008 to 04/09/09
at the legal interest rate of 6.000 per annum $215.78
Costs $0.00
Attorney fees $0.00
TOTAL $4,393.04
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.
I certify Defendant, RICHARD B DORSEY, last know address is 2500 COPE DR MECHANICSBURG, PA
17055.
Dated: 4/9/2009
APOTHAKER
A Law Firm
David J. Apothaker
CIATES, P.C.
laintiff
Debt Collection
By:
Our File No.: 100250
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
VS.
Plaintiff,
RICHARD B DORSEY
Defendant.
Civil Action
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 08-2866
. 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 2500 COPE DR
MECHANICSBURG, PA 17055.
We inquired with the web site of the Defense M ?Ipoo er Data Center, located at 1600 Wilson
Boulevard, Suite 400, Arlington, VA 22209-2593, if the D en t(s) is/are in any branch of the military.
Mary M. Snavely-Dixon, Director of the Defense an wer Data Center sent back our inquiry
indicated that the Defendant(s) is/are not in the military.
David J. A thaker
Attorney for Plaintiff
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.
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100250 OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs. )
RICHARD B DORSEY ) NO. 08-2866
To: RICHARD B DORSEY
3 CARDAMON DR
MECHANICSBURG, PA 17050
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
Date of Notice: June 17, 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
Collection
2417 Welsh Road, Suite 21 #520
Philadelphia, PA 19114
(215) 634-8920
Attorney for Plaintiff
Attorney ID #38423
DAV A Law Firm Engaged in APOTHAKER, ESQUIRE
APOT R & Debt ASSOCIATES PC
SHERIFF'S RETURN - REGULAR
CASE NO 2008-02866 P
?J COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NORTH STAR CAPITAL ACQUISITION
VS
DORSEY RICHARD B
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
DORSEY RICHARD B the
DEFENDANT , at 1130:00 HOURS, on the 16th day of May 2008
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013 by handing to
RICHARD B DORSEY
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof,
Additional Comments
DEFENDANT'S ADDRESS IS 3500 COPE DRIVE MECHANICSBURG
Sheriff's Costs:
Docketing 18.00
Service 10.00
Affidavit .00
Surcharge 10.00
.00
38.00
Sworn and Subscibed to
before me this day
of
So Answers:
R. 'Thomas Kline
05/16/2008
APOTHAKER & ASSOCIATES
By:
'Deputy Sheriff
t. ------ A. D.
20 9 ' Awl. 30
Cut ? ;.??'f ? fr R,?i.i?3•.
41 p° Qa ATIq
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
TO: RICHARD B DORSEY
2500 COPE DR
MECHANICSBURG, PA 17055
NORTH STAR CAPITAL
ACQUISITION LLC
Plaintiff,
vs.
RICHARD B DORSEY
Defendant.
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 08-2866
Civil Action
NOTICE
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. Esq. at this telephone number: 215-634-8920
Our File No.: 100250
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
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.
RICHARD B DORSEY
Defendant.
OF TH':
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2010 MAY 19 PM 3: 10
cumr? ' "jJib} fY
PEN N'SY a? VA
ti1;,N
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 08-2866
PRAECIPE TO MARK JUDGMENT SATISFIED
TO THE PROTHONOTARY:
Please mark the Judgment Satisfied against the Defendant. Judgment has been paid
in full.
APOTHAKER & ASS C TES, P.C.
Attorneys FinnDe ain ff
A Law Firm Engagt Collect;cd
By: N?'
David J. Apothaker, Esquire