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Home My WebLink About08-4441Qgi File No.: 172283 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Qk- NuW I No I Tttvh DENEEN MORRIS 1096 COCKLIN ST MECHANICSBURG, PA 17055 Defendant. 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. 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 .iPOTHAKER & 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OF- 'V 9 y / 64'?7L-( 7'1? DENEEN MORRIS 1096 COCKLIN ST MECHANICSBURG, PA 17055 Defendant. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 214520, Philadelphia, PA 19114. 2. Defendant(s) is/are DENEEN MORRIS, an adult individual residing at 1096 COCKLIN ST MECHANICSBURG, PA 17055. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #5307582175495221; and said account was issued to Defendant(s) by CAPITAL ONE BANK (USA) NA, 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 $3,354.59. 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. e. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,354.59 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKE SSOCIATES, P.C. Atto ey r Plaintiff A Law Firm gag d in Debt Collection BY: Dated: 7/17/2008 David l?,Apothaker Our File No.: 172283 VERIFICATION David J. Apothaker, Esg. 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 subject to the penalties of 18 Pa.C.S.A. 4904 relating to understands that the statements therein are made falsification to authorities. David J. Apothaker Attorney for Plaintiff DATE: 7/17/2008 NORTH STAR CAPITAL ACQUISITION LLC t .1 DENEEN MORRIS 1096 COCKLIN ST MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: DENEEN MORRIS Account Number: 5307582175495221 Original Creditor: CAPITAL ONE BANK (USA) NA Balance Due: $3,354.59 Our File No.: 172283 EXHIBIT "A" ka I SHERIFF'S RETURN - REGULAR CASE NO: 2008-04441 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUSITION VS MORRIS DENEEN STEVE BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MORRIS DENEEN the DEFENDANT , at 0019:45 HOURS, on the 28th day of July , 2008 at 1096 COCKLIN ST MECHANICSBURG, PA 17055 by handing to RICH MORRIS HUSBAND OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 71wl'a 18.00 12.00 .00 10.00 .00 40.00 Sworn and Subscibed to before me this day So Answers: RThomas Klin ' I07/29/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff of A. D. \3 Our File No.: 172283 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. DENEEN MORRIS Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4441 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, DENEEN MORRIS, in the default of an Answer, in the amount of $3,440.80 computed as follows: Amount claimed in complaint: $3,354.59 Amount Paid: - $(0.00) Interest from July 17, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $86.21 Costs $0.00 Attorney fees $0.00 TOTAL $3,440.80 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, DENEEN MORRIS, last know address is 1096 COCKLIN ST MECHANICSBURG, PA 17055. APOTHAKER & Attorneys A Law Firm Enizaa By: David J. TES, P.C. Dated: 5/14/2009 r"d: ?'ll.?.???'.:'rt??*?n i ?A'V S ? • f? t ???? ??? ? ? ? ?1 ?. ?, 9 ???A,Y.1 ,` ??.? a 1 ? Jt A OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: DENEEN MORRIS 1096 COCKLIN ST MECHANICSBURG, PA 17055 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, VS. DENEEN MORRIS Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4441 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. AWthaker, Esc. at this telephone number: 215-634-8920 /? 020D 9 Our File No.: 172283 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. DENEEN MORRIS Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4441 : 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 1096 COCKLIN ST MECHANICSBURG, PA 17055. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the, Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili David Apothaker Attorney Plainti r Data Center, located at 1600 Wilson s) is/are in any branch of the military. Data 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. FILE > .( 2009 K Y 19 N "3: 2, 1 Department of Ddease Manpower Data Cep MA"Y-14.2449 093235 Upon searching the ia£ormadon daa banks of the DVaroneut of Defense Manpower Data Center, basil an the iafarnrintion that you provided, the above is the current of the iodividuat as to A branches cif the fir. AWIA Mary X Snavely Down. Director Deparkneat of Defense - Maapanver Data Center 1640 Wilson ley Suite 400 A&ngioca, VA 22249-2593 The Dele ase Manpower Data Center (DM)C) is an aqpriodw of the Department of Defuse that maintains dw Die Fsurobsent and Eligibility Rgka ong System ('SRS) database which ar the nttiM source of daft an ciplAitY for military me&A care and other :a ty systems. The Department of Ddmae strov#y supports the a afmcement of the Servieeeruea?prs Civic ReWAct [34 USCS Apps §§ 381 ct seq) (SERA) { merly the Soldiers! and Sailors' Chi R+eWAct of 1944)_ I3C has isse ed hin dr3eds of thousands of 'does not possess any inkinnation indicating that the inifivithad a eurready an acne c'log' responses, and has experienced a smd error rate. In the event the kKMkW refinmeed above, or any f w* r, MendL or representative asserts in my manner chat the ini*Adad is an active duty, or is otherwise entNed to the protections of the SCRA, you are skcia encouraged to obtain dbrther v ion ofthe persaa's active duty sodas by coubicting dot persaa"s Amory Service via the "deImse' I m' URL provided below. If you have evidence the person is an active-duty an you furl to obtain this addaitio" Military 5er ice ve feation, provisions of the' SCRA may be nvink d against you. Myou obtain iincr information about the person ( e.g., an. SSN, improved wx racy of DOB, a middle namel you can submit your regwst again at this Web site and we wit provide a new certficate ft that query. 'i'bis response relies current active duty status ady. For hatoncai xformawn. please c?oatact dw Ulkary Service SCRA points- of-contact. See.,httr.#hvww , WAR?MCr. T'bis cerulicate was provided based can a monare and Social Security der (SSN) provided by the regaestear. Providing an erroneous same or SSN wgl cause ern erroneous =tfi ute to be provided. Rsportm.m ' Arc Mlikery Status Repoet Pursoeot to the Serv eenbembera Civet RefidAct 172283 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. ) DENEEN MORRIS ) NO. 08-4441 To: DENEEN MORRIS 1096 COCKLIN ST MECHANICSBURG, PA 17055 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 28, 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 \h1 DAVID A APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 Or' THE 2009 AY 19 Fii 21 A SHERIFF'S RETURN - REGULAR CASE NO: 2008-04441 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQU,SITION VS MORRIS DENEEN STEVE BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MORRIS DENEEN the DEFENDANT , at 0019:45 HOURS, on the 28th day of July 2008 at 1096 COCKLIN ST MECHANICSBURG, PA 17055 by handing to RICH MORRIS HUSBAND OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.40 Affidavit .00 Surcharge 10.00 .00 40.00 Sworn and Subscibed to before me this day So Answers: R.• Thomas Klin 07/29/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff of , A. D. pd - ?t;Czm 't 1q. 0 Ck. !3 Y'7 L / `a,? ?, t9.4 7