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Home My WebLink About08-6971Ab _} Our File No.: 188636 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. MARTIN V MCCARTNEY 1020 CENTERVILLE RD NEWVILLE, PA 17241-9555 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: p$ - 07) Civ: l ?pf'M 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 d& Our File No.: 188636 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. MARTIN V MCCARTNEY 1020 CENTERVILLE RD NEWVILLE, PA 17241-9555 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 MARTIN V MCCARTNEY, an adult individual residing at 1020 CENTERVILLE RD NEWVILLE, PA 17241-9555. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #98324423; 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 $2,519.90. 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". . , . above. 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,519.90 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER SSOCIATES, P.C. Atto y r Plaintiff A Law Firm E Z a t d in Debt Collection BY: David J. AVothaker, Esquire Dated: 11/18/2008 Our File No.: 188636 VERIFICATION David J. A othaker 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 unsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 11/18/2008 NORTH STAR CAPITAL ACQUISITION LLC MARTIN V MCCARTNEY 1020 CENTERVILLE RD NEWVILLE, PA 17241-9555 STATEMENT OF ACCOUNT Debtor's Name: MARTIN V MCCARTNEY Account Number: 98324423 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $2,519.90 Our File No.: 188636 EXHIBIT "A" J r,. nn 7?7 00 h? C^3 Co rV U'? -177 -i trri ! --E O SHERIFF'S RETURN - REGULAR CASE NO: 2008-06971 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS MCCARTNEY MARTIN V NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MCCARTNEY MARTIN V was served upon the DEFENDANT , at 0015:15 HOURS, on the 10th day of December , 2008 at 1020 CENTERVILLE RD NEWVILLE, PA 17241-9555 CHER BROTHERS by handing to ADULT IN CHARGE 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 Sworn and Subscibed to before me this So Answers: 18.00 9.00 .00 10.00 R. Thomas Kline .00 37.00 12/11/2008 APOTHAKER & ASSOCIATES By: `? --2 day Deputy Sheriff of A. D. (fur File No.: 188636 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. MARTIN V MCCARTNEY Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6971 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, MARTIN V MCCARTNEY, in the default of an Answer, in the amount of $2,632.63 computed as follows: Amount claimed in complaint: $ 2,519.90 Less: Amount Paid: ( 100.00) Plus: Interest from November 18, 2008 to August 12, 2009 at the legal 97 2 3 interest rate of 6.00% per annum Attorney fees TOTAL 0.00 $ 2,632.63 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, MARTIN V MCCARTNEY, last known address is 1101 CLAREMONT RD CARLISLE, PA 17013. APOTHAKElk Atto ys A Law Firm E gag By: David . SOCIATES, P.C. Plaintiff in Debt Collectioi Dated: August 12, 2009 Our File No.: 188636 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 vs. Plaintiff, MARTIN V MCCARTNEY 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 1101 CLAREMONT RD CARLISLE, PA 17013. /) We inquired with the web site of the D Boulevard, Suite 400, Arlington, VA 22209-25935 Mary M. Snavely-Dixon, Director of the E indicated that the Defendant(s) is/are not in the mi COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6971 David J. Apothaker Attorney for Plaintiff Manpower Data Center, located at 1600 Wilson )efendant(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. n] APOTHAKER&AsSOCIATES, P.C. ATTORNEYS AT LAW Department of Defense Manpower Data Center Military Status Report Pursuant to the Sen%tcemembers Civil Rely Act AVG-12-2009 0$:31:25 < Last Name Fwst/NMdle Begin Date Active Dtgy Status Service/Agency MCCARTNEY MARTIN V B ased on the irdcTwaticm %ou have fimished, flit D-XB}C does not possess any information mating that the indi"al is currently on active dat•. Upon searching the i formatio n data basks of the Department of Defense` Manpower Data Center, based on the information that you prat a the ab(nv is the current status of the ikhidual as to all branches of the Military. olotv Mary M- Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Ulson Blvd,. Suite 400 Arlingtonn, VA 22:209-2593 T'he Defense Manpower Data Center (DMDC) is an or smization of the meat € f Deftest that mains the Demise Enrollment and Eligibility Reporting System (SEERS) database which is the oflicial source of data on efigilxiity for military medical care and other eligibility systems. The Department of Defense strongly supports the ennforcemaent of the Serves s Civil ReliefAct [50 USCS Apps. §§ 501 et sewq] (SCRA) (formerly the Sores' and Sailors' Civil Relief Art of 1940)- DMDC has issued hundreds of thousmds of "does not possess any kfimmtkm indScafing &atlt the individual is currently on active duty" responses, and has wed a small error rate. In the event the individual referenced above, or any family member, friend, or re:gresentatire asserts in any manner that the individual is can active duty, or is otherwise entitled to the protections cnf the SCRA, your are stron* encouraged to obtain ftrrtlw verification of the person's active duty status by contacting that perso s Military Service, Naa the "de elink;mnr URL provided below. If you have evidence: the person is on active~-d ah- and you fail to obtain this additional Military Service vacation provisions of the SCRA may be invoked against }fort- If you obtaiahardier iofinmation about the person ( e-g_t an SSN, iatproved accuracy of DOB, a middle name), you can submit your request again at this Web she and we will provide a new certificate for that query- This response reflects current active duty status only. For historical ienformati:oan= please contact the Military Sen ice SCRA points- of-contact. See lx u-tv_defenselJr is fa ' PC09SLDRhmA WARNING.- This cert&.ate was provided based on a name and Sisal Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certi&cate to be provided Report ID, BFF-F THERA S O N 215 634.8920 215 634.8421 If 188636 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) MARTIN V MCCARTNEY ) NO. 08-6971 To: MARTIN V MCCARTNEY 1101 CLAREMONT RD CARLISLE, PA 17013 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: February 05, 2009 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 DA 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 A SHERIFF'S RETURN - REGU_:AR CASE NO: 2008-06971 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS MCCARTNEY MARTIN V NOAH CLINE s DEC 2 3 2008 .. t" y Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MCCARTNEY MARTIN V the DEFENDANT , at 0015:15 HOURS, on the 10th day of December , 2008 at 1020 CENTERVILLE RD NEWVILLE, PA 17241-9555 CHER BROTHERS by handing to ADULT IN CHARGE 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 Sworn and Subscibed to before me this So Answers: 18.00 9.00 _ ,00 10.00 R. Thomas Kline .00 37.00 12/11/2008 APOTHAKER & ASSOCIATES By- day Deputy Sheriff of , A. D. RLED-(',-FF uF OF THE FR.")P 7-C"NOTW?Y 2004 AUG 2Q AM 8: 06 41 1?. 00 PO AM--( er-* I (I (0 5'Y r alai 44o? wt.e? ua?(ac( r TO: MARTIN V MCCARTNEY 1101 CLAREMONT RD CARLISLE, PA 17013 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, vs. MARTIN V MCCARTNEY Defendant. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6971 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 8/44oy