The URL can be used to link to this page

Home My WebLink About08-4638`Our-Ae No.: 169920 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 E WILSON & ELIZABETH A WILSON 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08' ?f(o38 C?vi ( ler'+?• 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 'APO?HAKER & 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 E WILSON & ELIZABETH A WILSON 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 f = 9(, 3 Q C-! 7-6e., 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 RICHARD E WILSON & ELIZABETH A WILSON, an adult individual residing at 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4185868000430057; and said account was issued to Defendant(s) by PROVIDIAIv1, 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 $5,540.60. 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". "'T 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 $5,540.60 and requests this Court award Plaintiff APOTHAKER and costs to the extent permitted by applicable law. A Law Firm BY: Debt TES, P.C. David J. Apothaker Dated: 7/24/2008 Our File No.: 169920 VERIFICATION David J. A othaker E . 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 unworn falsification to authorities. Plaintiff DATE: 7/24/2008 NORTH STAR CAPITAL ACQUISITION LLC RICHARD E WILSON & ELIZABETH A WILSON 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 STATEMENT OF ACCOUNT Debtor's Name: RICHARD E WILSON & ELIZABETH A WILSON Account Number: 4185868000430057 Original Creditor: PROVIDIAN Balance Due: $5,540.60 Our File No.: 169920 EXHIBIT "A" -6a- oj O ooo (N D c A SHERIFF'S RETURN - REGULAR CASE NO: 2008-04638 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS WILSON RICHARD E ET AL RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WILSON RICHARD E the DEFENDANT , at 0019:21 HOURS, on the 6th day of August 2008 at 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 ELIZABETH A WILSON by handing to SPOUSE 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 Costs: Docketing Service Affidavit Surcharge gli)ylDp (?, 18.00 20.00 .00 10.00 .00 48.00 Sworn and Subscibed to before me this day of , So Answers: Rjr Thomas Klin 08/07/2008 APOTHAKER & ASSOCIATES By. 02?dkl Deputy Sheriff A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-04638 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS WILSON RICHARD E ET AL RONALD E HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WILSON ELIZABETH A the DEFENDANT , at 0019:21 HOURS, on the 6th day of August , 2008 at 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 by handing to ELIZABETH A WILSON 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 Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/07/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff of A. D. Our File No.: 169920 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 E WILSON & ELIZABETH A WILSON Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4638 } Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, RICHARD E WILSON & ELIZABETH A WILSON, in the default of an Answer, in the amount of $5,952.64 computed as follows: Amount claimed in complaint: $ 5,540.60 Less: Amount Paid: ( 0.00) Plus: Interest from July 24, 2008 to August 12, 2009 at the legal interest rate of 6.00% per annum 269.54 Attorney fees 0.00 TOTAL $ 5,952.64 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 E WILSON & PENN ST SHIPPENSBURG, PA 17257-1314. / A Law Firm ASSOCIA for Pla' is TH A WILSON, last known address is 202 1-2 N P.C. Collection By: David J. Apothaker Dated: August 12, 2009 Our File No.: 169920 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 E WILSON & ELIZABETH A WILSON Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : 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 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314. We inquired with the web site of the Deft Boulevard, Suite 400, Arlington, VA 22209-2593, if Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4638 David J. Apothaker Attorney for Plaintiff 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. Department of Ddme Manpower Data Cernte r AUG-12-20091 I.W50 kary Status Report Pursuasst to the Sersicemembers Civil Rdef Act *NILast Iitaes Fira6l4fKl&[e Begin D2t* Active Duty Stateas Service/Agency s ?'?USO fUCHARD E Bated on the irrfcxmat va you have frra r idwd, dr DNIDC dDes not possess any Wbrm3Lion iodating that the^ in?l is civrently on active Upon searcining the irrforination data banks of the D afDefense'Manpower Data Centex, based on the ' `on that you pro d, the above is the current status of the dal as to all branches of the &?- )e)jjj 14 vjojj4? - Mary M. Snavely-Dixon, Director Nfikary. Deportment of Defense Manpower Data Center 1600 Wison Blvtl_, Suite 400 Arlington VA 22209-2593 The De fmse Manpower Data Center (D..MDC) is an organvatiou of the Depar4n nt of Defense dw maintains the Defense E and Ehgiba* Reporting System (DEERS) database which is the official source of data on elepW for Military medical care and other etigUity stems.. The Depar t of Defense strongly supports the enforcement of the Sere a meresbers Civil Re `Act [50 DSC S Apex. § § 501 et segj (SCRA) (fors edy the Soldiers' arnd Sai ors' Civil Re f Act of 1940)_ DNIDC has issued hundreds of t1msands of "does not possess any infonwhon ' ' that the hdividual is currently an active duty" responses, and has weed a small error rate. In the event the ` al referenced ate, cc any fa y member, fiiend? or representative asserts in any manner that the individual is on active duty or its odiam ise entitled to the protect of the SCRA, you are strongly encouraged to obtain firther venfreabou ofthe person's active duty status by contacting that pi's MNLary Service via thre'defrnselidc,mil! URi, provided below- If you have evidence the person is on active-duty and you f ti to obtain this a oval M'}= Service provers of the SCRA. may be invoked against you- If you obtain fug infornudw about the person ( e"g,, an SSN, ierproved accuracy of DOB, as middle sine), you can submit your request again at this Web site and w e will provide a new certiiicate for that query- This response reflects carent active duty status only. For historical itibnnation, please contact the Military Se nice SCRA pos&- of-contact. Seer: h&:fiwvsv;de rssdik.mi. ,'y +PtC09SLI?R. WARNING. This certificate was proms based on a name and Social Security umber (SSN) provided by tine rcqueste r? Providing an erroneous name or SSN will cause an erroneous certiticate to be p rov ect. RepvrtM__B YrSBBMGQ Department of Defense -Manpower Data Center AMtMY States Report Pursuant to the Serviccmembers Civil Relief Act < Last Name Faa#/Middie Bede Date Active DEty Shteas AUG-12-240911:0831 ServicatAgency- WILSON FLIZABETHA `Based on the ' ' You h-Ovfinished. ttx DNIDC does not possess any ieuf'oruz>aaion • - ? ?g that the dal is currently on ac tine duty. Upon searching the iG&MMdw data b= s ofthe Department of Def me Manpower Data Center. based on the if'onna Lion that you provideA the above is the current status of the iau? as to all brace of the NElkary, )6 lA- Mary M. Snavely-Dixon, Director Dept of Dose - Manpower Data Center 164 WiEson Bhld Stake 400 Wigton, VA 22209-2593 The Defense Manpower Data Ceatcr (DU DC) is an organization of the Department of Dew that mates the Defense Enrollment and BgRAMy Reg sg Sy a (DM S) database which is the official source of data on care and other ` systems. e)rga'tr y f wry mud al The Departmentof Defense Won* st ods the enibfeemmt of the Servi bees CniRe f•Act 50 USCS Apex §§ 5411 et segj (SCRA) (formerly the. Sold ! and Statues' Chi ReWAct of 1940). D dDC has. isswd hmdre& of of -does not possess any inform ie ating that the k&vidiw is currently on wive duty" respanses, and has , rate. In the event the it vie'lual re€ereraced ai , or experienced a smd error any fim* member, friend,, or representative asserts in any n=aer that the individual is on activ°e duty, or is wise entitled to the protections of the SCRA you are sir -'? on* encouraged to obtain ft>art?r ration of the person's active doily status contactog that below. If you have evidence the °n"s Nfiktary Service via the '"?ehnk..m?" T3RL provided person is on active-duty and you fail to obtain this additiorw litary Sake vertiieca d ms provWons. of the SCRA may be iced ' you. against If you obtain fir#uer ' ` about the person ( e.g., an SSN, improved accuracy ofDoB, a middle runic), YOU can sot your eVest again at this Web sate and we wi l provide a new date fsx t& aUery, This response ref acts current active duty status ou,}'• For histasieal irif please contact flue Miaar? Service SCRA points- of -contact. Ser hgR i,"www ddensd* axe s/FC09SLDR WARNING- This certificate was provided based on a name and Social Secu my number (SSs Pnn g an erroneous name or SSN wig cause an erroneous certificate to be provided, provided by the requester, Ra#pnrtM---ffXjrO FiC 69920 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) RICHARD E WILSON & ELIZABETH A WILSON ) NO. 08-4638 To: ELIZABETH A WILSON 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 09, 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 ??A DAVI . 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 438423 69920 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) RICHARD E WILSON & ELIZABETH A WILSON ) NO. 08-4638 To: RICHARD E WILSON 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 09, 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 A DA D J. APOTHAKER, ESQUIRE AP 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: 2008-04638 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS WILSON RICHARD E ET AL RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WILSON ELIZABETH A the DEFENDANT , at 0039:21 HOURS, on the 6th day of August 2008 at 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 by handing ro ELIZABETH A WILSON 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 Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of 5o Answers: 6.00 .00 .00 :?e 10.00 R. Thomas Kline .00 16.00 08/07/2008 APOTHAKER & ASSOCIATES By: day Deputy Sheriff I A.D. SHERIFF'S RETURN - REGULAR SE NO 2008-04638 P ,4 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS WILSON RICHARD E ET AL RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon. WILSON RICHARD E the DEFENDANT f at 0019:21 HOURS, on the 6th day of August 2008 at 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 by handing to ELIZABETH A WILSON SPOUSE 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 Costs: Docketing 18.00 Service 20.00 Affidavit .00 Surcharge 10.00 .00 48.00 Sworn and Subscibed to before me this day So Answers: Rt, Thomas Klin 08/07/2008 APOTHAKER & ASSOCIATES By ? 21 - Deputy Sheriff of A. D. 1-11?.lJ?JIV ?? JE THE P;- 2009 AUG 19 FM 3: 5 8 GViV• u4 j t m - 4 ) q db 09 Pit 4 q klbfi mad OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ELIZABETH A WILSON 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 NORTH STAR CAPITAL ) ACQUISITION LLC ) Plaintiff, ) vs. ) RICHARD E WILSON & ELIZABETH ) A WILSON ) Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4638 Civil Action 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 ARBITRATO 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 801o OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: RICHARD E WILSON 202 1-2 N PENN ST SHIPPENSBURG, PA 17257-1314 NORTH STAR CAPITAL ) ACQUISITION LLC ) Plaintiff, ) VS. ) } RICHARD E WILSON & ELIZABETH ) A WILSON ) Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4638 Civil Action 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 0/0