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HomeMy WebLinkAbout08-5993A. Our File No.: 184482 APOTHAKER & ASSOCIATES, P.C. v 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. LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013-1702 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: S??, (2Il 0-1, ??Q1'Yl 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.: 184482 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. LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013-1702 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 4,- S9?3 CL-4 ? 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 LARRY SLUSSER, an adult individual residing at 909 ARMSTRONG RD CARLISLE, PA 17013-1702. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100008690707; 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 $8,904.94. 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 $8,904.94 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS OC TES, P.C. Attorney fo Pl ff Zectioi A Law Firm Engag in t CBY: David J. Dated: 9/29/2008 Our File No.: 184482 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 P&C.S.A. 4904 to unworn falsification to authorities. David J. Ak6aker, Esquire Attorney o ff DATE: 9/29/2008 NORTH STAR CAPITAL ACQUISITION LLC LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013-1702 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 184482 LARRY SLUSSER 4071100008690707 WELLS FARGO FINANCIAL $8,904.94 EXHIBIT "A" D r.. O c, C=) C'9 --°i CJ) C.? Chi M? r-r7 x? t _'? C-? Y? OV) SHERIFF'S RETURN - REGULAR CASE NO: 2008-05993 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS SLUSSER LARRY 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 SLUSSER LARRY the DEFENDANT , at 0007:45 HOURS, on the 11th day of October , 2008 at 909 ARMSTRONG RD CARLISLE, PA 17013-1702 by handing to LARRY SLUSSER DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 .00 1D?14?09 ? 3 3 . 0 0 Sworn and Subscibed to before me this day So Answfers r R. Thomas Kline 10/13/20-- APOTHAKE By: of A. D. Our File No.: 184482 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. LARRY SLUSSER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 1 NO.: 08-5993 Civil Action PRAEC1 PE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, LARRY SLUSSER, in the default of an Answer, in the amount of $9,217.70 computed as follows: Amount claimed in complaint: $8,904.94 Amount Paid: - $(0.00) Interest from September 29, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $312.76 Costs $0.00 Attorney fees $0.00 TOTAL $9,217.70 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, LARRY SLUSSER, last know address is 909 ARMSTRONG RD CARLISLE, PA 17013- 1702 APOTHAKER Atto A Law Firm E ! By: RTES, P.C. Debt Dated: 5/14/2009 OF THE FE "m' r'-?CNC) APY 2009 MAY 19 Pi' 3* 59 TO: LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013-1702 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, VS. LARRY SLUSSER Defendant. NOTICE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5993 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 TIES NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920 7 9, -7v f Our File No.: 184482 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. LARRY SLUSSER NO.: 08-5993 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 909 ARMSTRONG RD CARLISLE, PA 17013-1702. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defens?Myppower Da enter has sent back our inquiry indicated that the Defendant(s) is/are not in the military/ David J. Attorney 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. Deparkwat Defimse Mimpower Data Cedw MAY-14-2009 10.1)7.47 Upon searching dw mki matiua data basics of the D pi amamt of Defense Maipowsr Data Cam, based an the &v satian that you pry, the above is the current status of the individual as to A brancs of the N%ary. 0, Mary M. Snavely Down, Dxe ckw Deparkment o(Defmse. - Manpower Dam Center 1600 Wilson BIvd., Suite 400 Ar nooo. VA 22209-2593 The Demme Mwpawver Data. Center M)C) is an crgaabation of tb c Deparmxnt of Die tw imiWains the Defense Emahneut and ` y Rep oiling System (DEERS) dose wbicb as The official source of dnm on cfgMy for wry i at care and otxr debIty sydema. Tie Departrnem cf Ddme *oo* sappartts ihe,, edwc t ofdl,- Savic s Chi R,eWAct 150 USCS ApM ff 501 et seq (SCGRA) Oxinedy the Sd&e& and Sonora' Civi! Re Act of 1 _ DMDC has issued Imak eds ofilwasoods of . not possess any ' udieating d at the a&vi&W is cnnra* an active daty' responses, and has experienced a s nil error rate. In the event the mdlvidud refi reacecl above, or any fm* nienbe r, head, or repoes" ve asserk in any awwwr dt dw sadividad is an active duty, or is odmwise enthled to the protecdous of die SCRA, you are skoay encouraged to obtain further vm'iicatim afthe perrsods active duty stxs by contacting dat person's I#iili4ry Service via the "defezsefikmir URL provided below. Nyou have evidence the person is on aefive-daty and you fid to obtain this sdftest Miltory Service vefficadon, pr ens of the SCRA may be iovaoieed against yon Kyou obtain Sather ik on about the person ( e.g., an SSN, impcaved accaracy of DOB, a middle name), you can submit your request again at dk Web site and we wB provide a new date for that query. Thh response reacts cu ree active duty stains o*. Ear historical please contact the Miitary Service SrCRA pomb-afarmabon, of-contact. See: bms ?war?v WA PN1N& Tbis cue was provided based an a name and Social. Secnnty umber (SSN) provided by the requester. Providng an erroneous wane or SSN vvA case an e ux skate to be provided. RaprrrrM°VPGEX F1VirC"to 14+Bha ry Stag Report Pur+snad to the Serviremembers Civi! lteWAct • , 184482 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) LARRY SLUSSER ) NO. 08-5993 To: LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013-1702 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: November 13, 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 1%\ DA I 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 bj"y(1(Q SHERIFF'S RETURN - REGULAR. CASE NO: 2008-05993 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS b SLUSSER LARRY # s ! ri „ (? tl C? 2? ??f)p e KENNETH GOSSERT , Sheriff or Deputy of Cumberland County,Pennsylvania, who being duly sworn accord g`C- law, says, the within COMPLAINT & NOTICE was served upon SLUSSER LARRY the DEFENDANT , at 0007:45 HOURS, on the 11th day of October , 2008 at 909 ARMSTRONG RD CARLISLE, PA 17013-1702 by handing to LARRY SLUSSER a true and attested copy of COMPLAINT & NOTICE 3 3?1 3 2008 ?gether with !>` and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 .00 33.00 Sworn and Subscibed to before me this So Answers: R. Thomas Kline day 10/13/20-" APOTHAKE By. of A. D. OF THE n°?Ry 2009 MAY {9 PH 3: S 9 r a L ?d • Amy 13y-7,tZ e,) _5 30