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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" # ? ? ? 0 ? ? ? ? ? ? ? D v ? 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. y A,g 09-'200911.218 ?Defisse MwVOvvcrD*&CeM'er .. ,.,c. m-?.....w.????..,.. ?k1 it Repod C pad Act ft r r ?. iS•used 'ftk it Ddime DNA CAOW beaks *c 4i ?. as to S, Ugwtbes S ? D*aCa to CfI' 1600 SMae4OO *e Defeust VA 2220' ee? g We[ C-*" On-Q- 15 S Zotambw Sow':' 'nre ?? b? Sys) 501 farO&VOS gad s C, lad Act [S4 USCS 14V- " ,» docs Islavy Systems. he coforceabeat ofd 1) ?"? ? e# a? VeliencedsmAerra care e " ofDefewe9 moided, l ?, ? cur and ' ? The SERA.. ??° t3f?i. is on SC&C ddY, 019 as by COStut" 4 am Ste sac - eodYe'a' Ob? vtov 5SA, Wpmved In fag Web *e yo'r reqnst odY Fs?r VkwCOaad*cwwwY I€3 OVA &AY SUM ustolkizfa? Ibs sesp°° f Of-ContaCL - (SS14) VvOjdd WY *e rem` Ser. rra' CaVOCOUS Same oSS14vacome an XiprtJD-WXWWM 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': -'7A v .R I 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