Loading...
HomeMy WebLinkAbout08-4581 Our File No.: 148573 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. VICTORIA M CHRISTINE 734 HUMMEL AVE LEMOYNE, PA 17043 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: DQ - tj5-k 1 e11111 T 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 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. VICTORIA M CHRISTINE 734 HUMMEL AVE LEMOYNE, PA 17043 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D g,_qs-Tj G7v: j -fu^ 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 VICTORIA M CHRISTINE, an adult individual residing at 734 HUMMEL AVE LEMOYNE, PA 17043. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #20590206; and said account was issued to Defendant(s) by WELLS FARGO FINANCIAL, 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 $3,700.71. 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 $3,700.71 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. SOCIATES, P.C. APOTH=R 41M I Atto y fo PlaintiffZ A Law Firm E gage in De Collectioi BY: Dated: 7/23/2008 id J Our File No.: 148573 VERIFICATION David J. Auothaker, Est 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 relatingt'?nsworn falsification to authorities. Apothaker for Plaintiff DATE: 7/23/2008 NORTH STAR CAPITAL ACQUISITION LLC VICTORIA M CHRISTINE 734 HUMMEL AVE LEMOYNE, PA 17043 STATEMENT OF ACCOUNT Debtor's Name: VICTORIA M CHRISTINE Account Number: 20590206 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $3,700.71 Our File No.: 148573 EXHIBIT "A" 1-'c- c=' SHERIFF'S RETURN - REGULAR CASE NO: 2008-04581 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL AQUISITION VS CHRISTINE VICTORIA M KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CHRISTINE VICTORIA M the DEFENDANT at 1855:00 HOURS, on the 28th day of August , 2008 at 734 HUMMEL AVE LEMOYNE, PA 17043 by handing to VICTORIA CHRISTINE 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 45.00 Affidavit .00 Surcharge 10.00 .00 `??D & I (7Y L? ?/ 73.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 08/29/2008 APOTHAKER & ASSOCIATES By: A. D. a ? v Our File No.: 148573 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. VICTORIA M CHRISTINE Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4581 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, VICTORIA M CHRISTINE, in the default of an Answer, in the amount of $3,996.19 computed as follows: Amount claimed in complaint: $ 3,700.71 Less: Amount Paid: ( 0.00) Plus: Interest from July 23, 2008 to August 12, 2009 at the legal interest rate of 6.00% per annum 143.98 Attorney fees 0.00 TOTAL $ 3,996.19 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, VICTORIA M CHRISTINE, last known address is 734 HUMMEL AVE LEMOYNE, PA 17043. APOT=tto & SOCIATE ; P.C. 4 r Plainti A Law Firm E gag din D t Collection By: David J. Apothaker Dated: August 12, 2009 Our File No.: 148573 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, VICTORIA M CHRISTINE Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND 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 efendant(s) resides at 734 HUMMEL AVE LEMOYNE, PA 17043. We inquired with the web site of the Del Boulevard, Suite 400, Arlington, VA 22209-2593, i Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4581 David J. Apothaker Attorney for Plaintiff Xa Center, located at 1600 Wilson 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. APOTHAKER& ASSOCIATES, P.C. ATTORNEYS AT LAW Department of Defense ever Dees Center AUG-12-2009 08:11:30 Mfiitary Status Report pursuant to the Ser+,k s Civil Relief Act t, Lot FQaUllrGd ie Begs Date Active DWIY Sttatirs hFa?rc (;HUSuN-E VICTORIA M Based on the information you have fiirn? the DMDC does not possess any information 1 indicating dud the zj&i ual is curredly on active duty. Upon searching the ` data banks of the Departmexnt ofDefense Manpower Data Center. based on the information that o you provided, the above is the current Status of the kdividual as to all branches of the Mftau'y. of - Mary M Siumely-Dixon, Director Department of Defense - Manpower Data. Center 1600 Wison Blvd, Suite 400 AxlingtonVA 22209-2593 The Defense Manpower Data Ceder (DNIDC) is an orgati2otion of tdw Department of Defense that maintains the Defense Errolmed and F.figibr' y Reporting Systenn (DS) database which is the official source of' data on efigW for m&IffY medical care and other , ' systems- The Department of Defense; strongly suits the enforcement of the Sere embers Cni Rehef"Act [50 USCS Appx_ 0 501 et seq] (SCRA) (formerly the Soldiers' and Savors' Civi ReliefAct of 1940)_ DMDC has issued hundreds cf dxxmmsds of *does that the individual is cmyedY on active &W responsft. and has wed a small error not possess any irsf ' rate. In the event the individual referenced atom or any fan>n1y member, fiietrd_ or representatim asserts in any mama that the can active duty, or is ?e entitled to the protections of the SCRA, you are strongly encouraged to obtain fir?ther verification of the per'soes active duty status by contacting that pers&s Nikary Service via the'defimseialc.mi" URL provided below. If you have evidence the person is on active-duty and you fad to obtain this additional wry Service venificetim provisions of the SCRA wary be invoiced against yarn If you obtain further kformation about the person ( e.g., an SSN, graved accuracy of DOB. a midcHe nan ae), you can sulmad your request again at this Web she and we w3 provide a new certificate for that query. This response reflects current active duty status only. For historical xfarmabo n, please contact the may Service SCRA points- of-contact. See; httP Uwww defimselink mil Isis 09SLDR.drtml WARNING- Ibis certificate was provided based on a name and Social Security number (SSN) provided by the requester, Prvv ng an erroneous name or SSN wX cause an erroneous date to be provided, Report M: t D0YE r %' . 148573 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) VICTORIA M CHRISTINE ) NO. 08-4581 To: VICTORIA M CHRISTINE 734 HUMMEL AVE LEMOYNE, PA 17043 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 29, 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 D J. APOTHAKER, ESQUIRE APO HAKER & 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 SHERIFF'S RETURN - REGULAR CASE NO: 2008-04581 P COMMONWEALTH OF PENNSYLVANIA : T COUNTY OF CUMBERLAND N SEP 2Q0$ NORTH STAR CAPITAL AQUISITION VS CHRISTINE VICTORIA M KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CHRISTINE VICTORIA M the DEFENDANT at 2855:00 HOUR, on the 28th day of August 2008 at 734 HUMMEL AVE LEMOYNE, PA 17043 by handing to VICTORIA CHRISTINE 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 45.00 Affidavit .00 Surcharge 10.00 00 73.00 Sworn and Subscibed to before me this day of , So An ilvpo->Q? swers: 7ff A R. Thomas Kline 08/29/2008 APOTH.AKER & ASSOCIATES By: A. D. RLED-O' f jr,E ()F Tr- P ?" r `'1 T Y 2009 AUG 20 AM 8. G9 +14. cc PO ATM 114 1osaa aag47? L -)o'4t.ce. WU-" OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: VICTORIA M CHRISTINE 734 HUMMEL AVE LEMOYNE, PA 17043 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, VS. VICTORIA M CHRISTINE Defendant. COURT OF COMMON PLEAS OF } CUMBERLAND COUNTY NO.: 08-4581 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 8/ao%?