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Home My WebLink About08-4639Our'File No.: 172180 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. CATHY B GARNER 707 SANDBANK RD MOUNT HOLLY SPRINGS, PA 17065- 1140 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (7$- ?f(c3q vil 7;rr-- 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. CATHY B GARNER 707 SANDBANK RD MOUNT HOLLY SPRINGS, PA 17065- 1140 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. DF-YG 34 CL?.l - ' 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 CATHY B GARNER, an adult individual residing at 707 SANDBANK RD MOUNT HOLLY SPRINGS, PA 17065-1140. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #5291151423508652; 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 $5,337.36. 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 $5,337.36 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASS C TES, P.C. Attorney for lain 'ff A Law Firm Engaged D t Collecti6i BY: David J. Dated: 7/24/2008 Our File No.: 172180 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 understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to falsification to authorities. David J. Apothaker Attorney for Plaintiff DATE: 7/24/2008 NORTH STAR CAPITAL ACQUISITION LLC CATHY B GARNER 707 SANDBANK RD MOUNT HOLLY SPRINGS, PA 17065-1140 STATEMENT OF ACCOUNT Debtor's Name: CATHY B GARNER Account Number: 5291151423508652 Original Creditor: CAPITAL ONE BANK (USA) NA Balance Due: $5,337.36 Our File No.: 172180 EXHIBIT "A" i? 6 7? SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04639 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS GARNER CATHY B R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GARNER CATHY B but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 707 SAND BANK RD GARNER CATHY B NOT FOUND , as to MOUNT HOLLY SPRINGS, PA 17065-1140 PER EX-HUSBAND, SHE RESIDES AT 19 FAIRMONT AVENUE, WELLSVILLE, PA 17365 (717) 432-4492. Sheriff's Costs: So answer Docketing 18.00 Service 5.00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 glpc{'u? r/ 38.00 APOTHAKER & ASSOCIATES 08/06/2008 Sworn and Subscribed to before me this day of A. D. Our File No.: 172180 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. CATHY B GARNER Defendant. NO. 08-4639 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaint' A Law Firm Engaged in D t CCollectioi By: David J. A Dated: 12/8/2008 0. ?t ?i 1