The URL can be used to link to this page

Home My WebLink About08-7015i Our File No.: 188767 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. LEONA GIBBONEY 312 PEACH GLEN RD GARDNERS, PA 17324 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: p 9- 7 0 l S c-N -'I f tf/. 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.: 188767 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. LEONA GIBBONEY 312 PEACH GLEN RD GARDNERS, PA 17324 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0&-_-)0IS C vi"l let 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 LEONA GIBBONEY, an adult individual residing at 312 PEACH GLEN RD GARDNERS, PA 17324. 3. Plaintiff, NORTI4 STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100014865343; 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 $6,131.64. 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 $6,131.64 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER WAS$OCIATES, P.C. A Law Firm Endaaed/ in BY: Dated: 11/21/2008 David J. Apothaker, Esquire Our File No.: 188767 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 bel' The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 904 lating to Wisworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 11/21/2008 NORTH STAR CAPITAL ACQUISITION LLC LEONA GIBBONEY 312 PEACH GLEN RD GARDNERS, PA 17324 STATEMENT OF ACCOUNT Debtor's Name: LEONA GIBBONEY Account Number: 4071100014865343 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $6,131.64 Our File No.: 188767 EXHIBIT "A" ? ? ? ,- U', O ? ? ? N O(1 - - ? .--f c-, rye r?ti -,?._?- 2 ? ? \ = , -{ tJ ^f \ Y ? { h ? ?{3 f`J ?J f°J ^-< SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-07015 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS GIBBONY LEONA R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GIBBONEY LEONA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT GIBBONEY LEONA 312 PEACH GLEN RD GARDNERS, PA 17324 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO MAKE SERVICE PRIOR TO EXPIRATION OF COMPLAINT. Sheriff's Costs: Docketing 18.00 So answers:, Service 18.90 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 51.90 APOTHAKER & ASSOCIATES 01/02/2009 Sworn and Subscribed to before me this day of A. D. , s C7 z Our File No.: 188767 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 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, VS. LEONA GIBBONEY Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7015 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. tiff Attorneys f fl tiff A Law Firm Ent d in Debt Collection By: Dated: 1/7/2011 David J. ApoVu ker, Esquire * Q 1 8 8 7 6 7 D I S N 1- C ,rn mo. r- ? ?z rs ) c? a ? ? w