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Home My WebLink About08-4199T Our File No.: 148526 APOTI-!AKEM & 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. EDWARD TRIMMER 4172 ANTELOPE CT APT 106 MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. d$ - 191 NOTICE (1. Lll-? 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. 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 A10THAKER & 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. EDWARD TRIMMER 4172 ANTELOPE CT APT 106 MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Of- '0911 rz4-1-- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are EDWARD TRIMMER, an adult individual residing at 4172 ANTELOPE CT APT 106 MECHANICSBURG, PA 17050. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4104140007818033; and said account was issued to Defendant(s) by CHASE CIRCUIT CITY, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $3,123.19. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,123.19 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & redipnn/Debt O IATES, P.C. Attornel ' tiff A Law Firm Enga Collection BY: David J. Dated: 7/8/2008 Our File No.: 148526 VERIFICATION David J. Anothaker, 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 to^sworn falsification to authorities. 'Apothaker for Plaintiff DATE: 7/8/2008 NORTH STAR CAPITAL ACQUISITION LLC EDWARD TRIMMER 4172 ANTELOPE CT APT 106 MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: EDWARD TRIMMER Account Number: 4104140007818033 Original Creditor: CHASE CIRCUIT CITY Balance Due: $3,123.19 Our File No.: 148526 EXHIBIT "A" mr ? vJ rt? ?? T ? SHERIFF'S RETURN - REGULAR CASE NO: 2008-04199 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION TRIMMER EDWARD ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland Cou ty,Pennsylvania, who being duly sworn according to law, says, the with 'n COMPLAINT & NOTICE was served upon TRIMMER EDWARD the DEFENDANT at 4172 ANT at 0017:20 HOURS, on the 16th day of July 2008 E COURT APT 106 MECHANICSBURG,? PA 17050 by handing to VICTORIA TRIMMER WIFE OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Coss: Docketing Service Affidavit Surcharge Sworn and Su scibed to before me th's of So Answers: 18.00 15.00 .00 10.00 R. Thomas Kline .00 43.00 07/17/2008 APOTHAKER & ASSOCIATES By: day eputy Sheriff A.D. Our File No.: 148526 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. EDWARD TRIMMER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4199 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, EDWARD TRIMMER, in the default of an Answer, in the amount of $3,273.95 computed as follows: Amount claimed in complaint: $3,123.19 Amount Paid: - $(0.00) Interest from July 08, 2008 to 06/18/09 at the legal interest rate of 6.000 per annum $150.76 Costs $0.00 Attorney fees $0.00 TOTAL $3,273.95 I hereby certify that the appropriate Notices of Default, as attached have been maile in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, EDWARD TRIMMER, last know address is 4172 ANTELOPE CT PT 106 MECHANICSBURG, PA 17050. APOTHAKER A Law Firm By: IOCtATES, P.C. Plaintiff in Debt CjAectioi Apothaker Dated: 6/18/2009 ? I 1. Our File No.: 148526 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. EDWARD TRIMMER Defendant. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4199 Civil Action : SS. David J. Apothaker, being duly sworn according to law, deposes and says that I Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 4172 ANTEI MECHANICSBURG, PA 17050. We inquired with the web site of the Defense M ower Data Center, Boulevard, Suite 400, Arlington, VA 22209-2593, if the efe dant(s) is/are in any Mary M. Snavely-Dixon, Director of the Defen npower to Center has sent indicated that the Defendant(s) is/are not in the militar . David J. AP thaker Attorney for Plaintiff The above signed understands that the statements herein are made subject to the Section 4904 relating to unsworn falsification to authorities. the attorney for 'E CT APT 106 1 at 1600 Wilson of the military. our inquiry ties of 18 Pa. C.S. Department of Defense -Manpower Data Center e-07N U \2aitary Status Report Pursuant to the Senicermembers Civil Relief Act ' . Last First[Middle Begin Date -Name TRIMMER EDWARD Active Duq' Status Based on the information =ou have furnished, the D?IDC does not possess indicating that the individual is currently on activ=e duty. Upon searching the information data banks of the Department of Defense Manpower w•er Data Center„ based you provided, the abort is the current status of the in&idual as to all branches of the'-Military, 14 Mary M. Snavely-Dixon, Director Department of Defense - ManpoNver Data Center 1600 ?7 ikon BI's°d__ Suite 400 ArlingtorL VA 22209-2593 The Defense Manpower Data Center (D--4lDC) is an organization of the Department of Defense that mar Enrolment and Ehgrbr?= Reporting System (DEERS) database which is the official source of data on elig care and other eligx'bilih systems- They Department of Defense strongly supports the enforcement of the Servicemembers Citi Rol dAct [50' et seq] (SCRA) (formerh, the Soldiers` and Sailors' Gac? Relief Act of 1940). DMDC has issued hundreds not possess any information indicating that the individual is currenth can agile duty" responses, and has exp, rate- In the event the in&idual referenced above, or any fame member, fret or representative asserts in individual is on activ=e duty. or is otherwise entitled to the protections of the SCRA, y=ou are strongly encour verification of the person's active duty std by contacting that person s Mary Service via the "defenselinl below- If you have etidence the person is on acticv-duty and you fail to obtain this additional Mitary Smia prop isions of the SCRA may be im=oked against you. If you obtain further information about the person ( e_g., an SSti, improved accuracy of DOB, a middle your request again at this N'eb site and we will prozide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Tslitary of-contact. See: :, 'u- x%r =.defenselinls .miles s PC t 9S1 f7R.k tml W.AR,\`1I?G; This certificate was prodded based on a nacre and Social Security number (SS 7) provided ProNiding an erroneous name or SSN' vv-il1 cause an erroneous certificate to be pro-,ided_ 3?-15-2049 10:5:13 i Sergi cel'4geact sass ahj ttnorrnation the information that the Defense for military medical eCS APPx- 501 thousands of "does arced a small. error v manner that the ®d to obtain further a" URL provided verification, you can submit SC RA points- the requester. 1 sport ID BXj2LLRSPWEF 148526 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON'PLEAS CUMBERLAND COUNTY vs. ) EDWARD TRIMMER ) NO. 08-4199 To: EDWARD TRIMMER 4172 ANTELOPE CT APT 106 MECHANICSBURG, PA 17050 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 19, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORT 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 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 DAVfD J\APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collectic 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 ?(( SHERIFF'S RETURN - REGULAR CASE NO: 2008-04199 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS TRIMMER EDWARD ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn accordin6 to law, says, the within COMPLAINT & NOTICE was served upon TRIMMER EDWARD the DEFENDANT at 0017:20 HOURS, on the 16th day of July 2008 at 4172 ANTELOPE COURT APT 106 MECHANICSBURG, PA 17050 by handing to VICTORIA TRIMMER WIFE OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE togeth?r with and at the same time directing ler attention to the contents Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 15.00 .00 10.00 R. Thomas Kline .00 43.00 07/17/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before e this day eputy Sheri , A.D. of thereof. ,F t 11-1,ol 14?1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: EDWARD TRIMMER 4172 ANTELOPE CT APT 106 MECHANICSBURG, PA 17050 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, VS. EDWARD TRIMMER Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4199 Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT i JUDGMENT IN REPLEVIN I 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 jj/