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Home My WebLink About08-6970 Our File No.: 188597 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 NORTHSTAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. DORETHA L WOODS & RONALD L WOODS 400 6TH ST NEW CUMBERLAND, PA 17070-1918 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CS - (0q 7D Civil 1 ere, 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 106 Our File No.: 188597 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 NORTHSTAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. DORETHA L WOODS & RONALD L WOODS 400 6TH ST NEW CUMBERLAND, PA 17070-1918 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is NORTHSTAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are DORETHA L WOODS & RONALD L WOODS, an adult individual residing at 400 6TH ST NEW CUMBERLAND, PA 17070-1918. 3. Plaintiff, NORTHSTAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #70930043; 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 $2,551.36. 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". 110. 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 $2,551.36 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & CIATES, P.C. Attorney or laintiff A Law Firm Engaa ed t Debt.Collectioi BY: David J. Apothaker, Esquire Dated: 11/18/2008 Our File No.: 188597 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. The made subject to the penalties of 18 Pa.C.S.A. 4904 understands that the statements therein are unworn falsification to authorities. David J. Ap6thaker, Esquire Attorney for Plaintiff DATE: 11/18/2008 NORTHSTAR CAPITAL ACQUISITION LLC f_ , DORETHA L WOODS & RONALD L WOODS 400 6TH ST NEW CUMBERLAND, PA 17070-1918 STATEMENT OF ACCOUNT Debtor's Name: DORETHA L WOODS & RONALD L WOODS Account Number: 70930043 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $2,551.36 Our File No.: 188597 EXHIBIT "A" O fv ? c C d Q? o a Cf1 , W - S. 1% CASE NO: 2008-06970 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTHSTAR CAPITAL ACQUISITION VS WOODS DORETHA L ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WOODS DORETHA L the DEFENDANT at 400 6TH ST , at 0012:20 HOURS, on the 6th day of December , 2008 NEW CUMBERLAND, PA 17070-1918 DORETHA L WOODS 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 /,Z,//6/0 r L-?, 18.00 15.30 .00 10.00 .00 43.30 Sworn and Subscibed to before me this day of , So Answers: R!' Thomas Klineo' 12/08/2008 APOTHAKER & C ES By: Deputy Sheriff A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-06970 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTHSTAR CAPITAL ACQUISITION VS WOODS DORETHA L ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE WOODS RONALD L was served upon the DEFENDANT , at 0012:20 HOURS, on the 6th day of December , 2008 at 400 6TH ST NEW CUMBERLAND, PA 17070-1918 by handing to RONALD WOODS 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 00 16.00 Sworn and Subscibed to before me this day So Answers: R. homas Kline 12/08/2008 APOTHAKER & AS CIAT r By: eputy Sheriff of A. D. APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff NORTHSTAR CAPITAL ACQUISITION LLC COURT OF COMMONS PLEAS CUMBERLAND COUNTY Plaintiff, VS. DORETHA L WOODS & RONALD L WOODS DOCKET NO.: 08-6970 Civil Action STIPULATION IN LIEU OF JUDGMENT Defendant. The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on this December 26, 2008, STIPULATED by and between Plaintiff, NORTHSTAR CAPITAL ACQUISITION LLC, and Defendant, DORETHA L WOODS & RONALD L WOODS parties as follows: 1. Defendant agrees to pay the sum of $2,551.36, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid shall be paid by Defendant, DORETHA L WOODS & RONALD L WOODS, to the attorneys for Plaintiff in the following manner: a. $100.00 to be paid on or before the 15th day of each month, beginning January 15, 2009 until paid in full. All checks are to made payable to NORTHSTAR CAPITAL ACQUISITION LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant, DORETHA L WOODS & RONALD L WOODS fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff must notify Defendant's attorney(s), in writing of Defendant, DORETHA L WOODS & RONALD L WOODS's default. The name and address of Defendant's attorney(s) that notice will be sent to is: Evan C. Pappas, Esquire 3425 Simpson Ferry Road Camp Hill, PA 17011 4. If the default is not cured within 15 days after written notice of Defendant's attorney(s), then Plaintiff has the right to obtain the entry of Judgment against Defendant, DORETHA L WOODS & RONALD L WOODS, ex parte, in the sum of $2,551.36, giving Defendant, DORETHA L WOODS & RONALD L WOODS credit for any sums actually paid pursuant to the terms of this Stipulation. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES Attorneys for ntiff A Law Firm EnLaged i ?L-m Scian, Esquire ORETHA L WOODS Our File No.: 188597 na Cz? r 1. Our File No.: 188597 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 NORTHSTAR CAPITAL ACQUISITION LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. DORETHA L WOODS & RONALD L WOODS Defendant. NO. 08-6970 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & Attorney A Law Firm Enots By: David J. Dated: 3/16/2011 BIIIIIIIIIIIII* TES, P.C. in Debt Collection Esquire c a ? A _= r -am ??2> w = C39 rQ =a 2p 3 ?,? ?Z - C)m ? oo