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Home My WebLink About08-56074. Our File No.: 180922 ?APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.438423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. PENNY L HOLLINGER 55 FICKES RD NEWVILLE, PA 17241-9461 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 S - S1.67 L71 u 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 s ~ Our File No.: 180922 `APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 k- T&07 et 4 7;i? PENNY L HOLLINGER 55 FICKES RD NEWVILLE, PA 17241-9461 Defendant. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is NORTH STAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are PENNY L HOLLINGER, an adult individual residing at 55 FICKES RD NEWVILLE, PA 17241-9461. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100013922905; and said account was issued to Defendant(s) by WELLS FARGO, 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 $4,032.47. 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". M 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 $4,032.47 and requests this Court award Plaintiff and costs to the extent permitted by applicable law. APOTHAKER , P.C. A Law Firm En a in t Collection BY: David J. Apothaker, Esquire Dated: 9/10/2008 Our File No.: 180922 VERIFICATION David J. Apothaker, Esquire 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 ed understands that the statements therein are the best of my knowledge, information, and belief. The an70, made subject to the penalties of 18 Pa.C.S.A. 4904 relating fa lsification to authorities. David J. Apoth er, Esquire Attorney for tiff DATE: 9/10/2008 I j NORTH STAR CAPITAL ACQUISITION LLC PENNY L HOLLINGER 55 FICKES RD NEWVILLE, PA 17241-9461 STATEMENT OF ACCOUNT Debtor's Name: PENNY L HOLLINGER Account Number: 4071100013922905 Original Creditor: WELLS FARGO Balance Due: $4,032.47 Our File No.: 180922 EXHIBIT "A" cr,, h C A m° C**" N N ..D t? ca CT1 t> 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05607 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS HOLLINGER PENNY L MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOLLINGER PENNY L DEFENDANT at 55 FICKES RD the , at 0018:30 HOURS, on the 25th day of September, 2008 NEWVILLE, PA 17241-9461 PENNY HOLLINGER DEFENDANT by handing to 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 101 a p??Y So Answers: 18.00 12.00 .00 10.00 R. Thomas Kline 00 40.00 09/26/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to before me this By: day Depu y Sheriff of A. D. l Our File No.: 180922 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. PENNY L HOLLINGER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5607 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, PENNY L HOLLINGER, in the default of an Answer, in the amount of $4,183.40 computed as follows: Amount claimed in complaint: $4,032.47 Amount Paid: - $(0.00) Interest from September 10, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $150.93 Costs $0.00 Attorney fees $0.00 TOTAL $4,183.40 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, PENNY L HOLLINGER, last know address is 55 FICKES RD NEWVILLE, PA 17241- 9461. APOTHAKER & A O TES, P.C. Attorneys f r Pl ' tiff A Law Firm Engag in ebt Collection By: David J. Dated: 5/14/2009 f , Our File No.: 1i0922 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, vs. PENNY L HOLLINGER NO.: 08-5607 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 Defendant(s) resides at 55 FICKES RD NEWVILLE, PA 17241-9461. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if thq, Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. 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. DeparEnxffi of Defense Mwpoww Data Center MAY-14-200910,0139 41 Mikery Status Report Parumat to the Sere rememberS Civil RelffAct HCLLMER. + PENNY L Based on the whirmagm you have :wed, On DMDC does not possess any iimwmdm imlicd* dud the iudh+idrrat is currently on actim daty_ 1 Upon sewCh sg the i on dataib# ss of the Depertmect of Ddmse Manpower Baba Getter, barred on the ifimown tune ym Pr' "tope above is the crsreurt status af'the MW&W as to IN bra &n of the 1t y. yftvt* I.J.- 11 Mary X Samm*: Dixon. Di cta' Depatiment ofMfimse - Mappown 1 Center 16ti{I wiis n Btvri, Spite A& gtan9 VA 22209-2393 The Defense Manpower Data Ce *w O )MC) is an oc of the Depar4neut c(Defme 6d samintaims the Defense Eaawilament and El*ility Rgxcting System (DEERS) is the o sour c+e ofdata on peir* 51) for t arkary? care and odxr qty systems. The Dot ofDefiense y ads the enfo" meat of the Serviceygae nhers Cavil RefidAnt [50 USCS Apex. if 501 et segj (SCRA) y the So s' and Saiars' Cid RAdAd of 1940)_ DAM has issued hundred of diousaads of dm not possess any inf rtudion iadicadog tent the iutfMW it curready an a+cive day" responses* and has egmdmeed a small error rate. In the eva t the kdvidasl rdawiced above, or my fsnaly memuber, Mend, or reps se asserts in nary aam mer that the inifividmat is on active duty, or is add arise emceed to the pratecdoms of the SCRA, you we stm* encouraged to, obtain fitter ve on afthe persons ac& a duty states by that person's 11dfftKyr Sa vice vine idea *ddmsd hk mr iIRL provided Ifyou evidence the person is on arfive-day and you fail to obtain tens adclidonat. Military Service calim, provbmn of the SCRA may be inwoked against yom Myou obtain Farhat i*cnodm about the person (e g., an SSN. b4moved accunmy of DOB, a midcte name), you cam subnart your request spin at this Web site and we wt prate a new cer a for do query. Ties response refiecits current acve duty status only. For hisxirl wfi rma ion, pie contact the Mfftary Service SCRA pvicts- of=coultact. Sea. bttwJ/www.4 htmt WA1tN12+ Q This certficate was provided based on a n me and Social Security agar (SSN) provided by the requester. Pro+iclug our erroneous aame or SSN will cause an aroma certificate, to be provided. Rap&"ZDA E l VYY3~Y 180922 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) PENNY L HOLLINGER ) NO. 08-5607 To: PENNY L HOLLINGER 55 FICKES RD NEWVILLE, PA 17241-9461 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: November 10, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff DA J. APOTHAKER, ESQUIRE APOT R & ASSOCIATES, PC Attorney ID 438423 SHERIFF'S RETURN - REGULAR CASE NO:'2008-05607 P N COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS HOLLINGER PENNY L O CT I MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOLLINGER PENNY L the DEFENDANT , at 0018:30 HOURS, on the 25th day of September, 2008 at 55 FICKES RD NEWVILLE, PA 17241-9461 by handing to PENNY HOLLINGER 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: So Answers: Docketing 18.00 Service 12.00 ° ?? Affidavit .00 .,? .. Surcharge 10.00 R. Thomas Kline .00 40.00 09/26/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Depu y Sheriff of A.D. i?t.U- Or Tl 2 F PC( '2 0 1, I;Y : u v LOik- .* 14. oo M A"*4 co 1 &4 -15a P4aa.s`foo OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: PENNY L HOLLINGER 55 FICKES RD NEWVILLE, PA 17241-9461 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, VS. PENNY L HOLLINGER Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5607 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 3?a7.p/oy