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HomeMy WebLinkAbout08-7016Our File No.: 188757 ,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. DIANE M HESS 295 FARM RD NEWVILLE, PA 17241 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ©g--7016 c,-o;I -It(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 ti Our File No.: 188757 APOT14AKER & 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. DIANE M HESS 295 FARM RD NEWVILLE, PA 17241 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ©8 ' 7 01 & r-" I f e l-& 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 DIANE M HESS, an adult individual residing at 295 FARM RD NEWVILLE, PA 17241. 3. Plaintiff, NORTHSTAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100013308188; 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 $3,862.24. 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 $3,862.24 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASXOCXATES, P.C. Attorney f P A Law Firm Eneaa d in BY: Dated: 11/21/2008 David J. Our File No.: 188757 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 to i{nsworn falsification to authorities. David J. Apotlaker, Esquire Attorney for Plaintiff DATE: 11/21/2008 NORTHSTAR CAPITAL ACQUISITION LLC DIANE M HESS 295 FARM RD NEWVILLE, PA 17241 STATEMENT OF ACCOUNT Debtor's Name: DIANE M HESS Account Number: 4071100013308188 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $3,862.24 Our File No.: 188757 EXHIBIT "A" ? ' J r k ss, -? (y rv c, . - °Q © .. 7 1 , ; Q =r T SHERIFF'S RETURN - REGULAR CASE NO: 2008-07016 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTHSTAR CAPITAL ACQUISITION VS HESS DIANE M MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HESS DIANE M the DEFENDANT , at 0012:21 HOURS, on the 6th day of December-, 2008 at 295 FARM ROAD NEWVILLE, PA 17241 RONALD HESS HUSBAND OF 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 Service Affidavit Surcharge i al. (S/o 18.00 10.80 .00 10.00 V .50.ou Sworn and Subscibed to before me this day by handing to So Answers: r R. Thomas Kline 12/08/2008 APOTHAKER & AS C A S ?F s ., By: , DWuty Sheri f of A. D. I Our File No.: 188757 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 Plaintiff, VS. DIANE M HESS Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7016 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A OCIATES, P.C. Attorneys r laintiff A Law Firm Enga d ' Debt Collection By: David J. Apothaker, Esquire Dated: 1/22/2009 1 ?? '"1 :? c=. =a --1 C.- `??- Sl a" . -;;" ... ? f .? w -e'} E`"'.-? 'Wi't