Loading...
HomeMy WebLinkAbout08-5992Our File No.: 184315 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. STAN WOLF 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 6e -- vv'. (!";, L 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 Our File No.: 184315 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. STAN WOLF 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ©F- 59 ?- 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 STAN WOLF, an adult individual residing at 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #3088071354; and said account was issued to Defendant(s) by KAY JEWELERS, 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 $1,881.54. 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 $1,881.54 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. ApOTHAKER & SO IATES, P.C. Attorney or P 'tiff A Law Firm Eng ed - Debt Co ctioj BY: Dated: 9/29/2008 David J. ApotWer, Esquire Our File No.: 184315 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 the best of my knowledge, information, and belief. undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. to unworn falsification to authorities. David J. )FOO'thaker, Esquire Attorney for Plaintiff DATE: 9/29/2008 NORTH STAR CAPITAL ACQUISITION LLC STAN WOLF 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 184315 STAN WOLF 3088071354 KAY JEWELERS $1,881.54 EXHIBIT "A" I(CJO O_y Cfi?? o °' t -77 ?- rr) r,..l -- _. SHERIFF'S RETURN - REGULAR CASE NO: 2008-05992 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS WOLF STAN MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE WOLF STAN was served upon the DEFENDANT , at 1145:00 HOURS, on the 18th day of October , 2008 at 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111 by handing to JACKIE WOLF, WIFE 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 24.00 Affidavit .00 Surcharge 10.00 bola z/oP C;,, .00 52 . 00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/20/2008 APOTHAKER & ASSOCIA S By: Depu y Sheriff of A. D. Out- File No.: 184315 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. STAN WOLF Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5992 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, STAN WOLF, in the default of an Answer, in the amount of $911.67 computed as follows: Amount claimed in complaint: $ 1,881.54 Less: Amount Paid: ( 1,150.00) Plus: Interest from September 29, 2008 to August 18, 2009 at the legal interest rate of 6.00% per annum 49.63 Attorney fees 0.00 TOTAL $ 911.67 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, STAN WOLF, last known address is 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111. APOTHAKER Atto ey,, A Law Firm nga? By: David . ?OCIATES, P.C. laintiff in Debt Collectioi Dated: August 18, 2009 Our File No.: 184315 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. STAN WOLF Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5992 : 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 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111. We inquired with the web site of the Deft Boulevard, Suite 400, Arlington, VA 22209-2593, if Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i 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. APOTHAKER&ASSOCIATES, P.C. ATTORNEYS AT LAW Department of Dense. Dower Data Center A G-12-2009 08:29.34 Military Stave Report Pursued tD the Ser emembers Civil Relief Act <List Firatbfiddle + Begs Date Active Duty Stators SenicelAgescy Name WOLF STAN tBased on the ' 'can you have furnished, the D\MC this not possess any i iormation . that the individual is currently on active m5cating Upon searching the infimmudon data banks of the Dep nt of Defense Manpower Data Center,, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Mary M Snavely-Down, Dn ctoar Department of Defense - Manpower Data Crater 1600 Wilson BhxL, Suite: 400 Arfr g our VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Finrollment and Ekibility Reporter System (DF,FRS) database which is the official source of data on eigs'biity for military m e&9 rare and other efigibility systems, The Department ofDefense strongly mWports the enforcement of the Seniceme mbers Civil Relief Act [50 USCS Appx. §§ 501 et seo] (SCRA) (formerly the Solders' and Sags' Civil R:cfidAct of 1940)_ DMDC has issued hundreds of thousands of -sloes not possess any informal indicahng that the indivuhud currently on active duty- responses, and has wed a small error rate. In the erg the individuail referenced above, or any fm* member, fiiernd, or representative asserts in any manner that the individual is on active duty,. or otherwise entidecf to the protections of the SCRA, you are stron* encouraged to obtainfmthcr verification of the pe rsods active duty status by contacting that perso s Military Sesame via the 'defenseinic.md" URL provided below. If you have evidence the perscm is on active-duty and you fai to obtain this additional Ivlilrtary Senvkeverilicatim pro ons of the SCRA may be invoked against you If You obtam fzarthe r ieftxmation about the person ( e.g., an SSN, improved accuracy of D©B, a middle name), you can submit your request again at this Web site and we will provide a new certi6cate for that query. This response reflects current active duty status only. For historical inormatioa, pease contact the M y Sen"ice SCRA poids- contact. See- httg)-I/v wrw- dm%uelink m fi stnis/PC09SLDR WARNING- This cat&ate was provided based on a carne and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous elute to be provide& ReportM:B JCQZSW131 184315 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) STAN WOLF ) NO. 08-5992 To: STAN WOLF 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: November 18, 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 DAVID J. 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 SHERIFF'S RETURN - REGULAR 'CASE NO: 2008-05992 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND P) R ?v` NORTH STAR CAPITAL ACQUISITION VS OCT ? i ` U Q j WOLF STAN Y._ MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NnTTrF WOLF STAN DEFENDANT was served upon the , at 114.5:00 HOURS, on the 18th day of October , 2008 at 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111 by handing to JACKIE WOLF, WIFE 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 24.00 Affidavit .00 Surcharge 10.00 .00 52.00 Sworn and Subscibed to before me this day So Answers: R. Thomas line 10/20/2008 APOTHAKER & ASSOCIA S By: Depu y Sheriff of A. D. r Ffl ?G` - ,,,r xJ" >?1?F:kn?R?Y OF THE 2009 AUK 27 Pd. Diu r? ?y OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: STAN WOLF 506 MOUNT ALLEN DR MECHANICSBURG, PA 17055-6111 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, vs. STAN WOLF Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5992 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 k X10 °l