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HomeMy WebLinkAbout08-7017Our File No.: 188724 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.438423 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. LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 ;?, _ `7 6 ! `7 c rv; I 7 ?r 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 attomey 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.: 188724 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. LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o g,- 7 0 /1 rjv ; CIVIL ACTION COMPLAINT FIRST COUNT 4uti 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 LARRY SLUSSER, an adult individual residing at 909 ARMSTRONG RD CARLISLE, PA 17013. 3. Plaintiff, NORTHSTAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100009234133; 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 $1,846.11. 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". 9 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 $1,846.11 and requests this Court award Plaintiff attorney's APOTHAKER Attorn A Law Firm Enj BY: David J- P Dated: 11/21/2008 and costs to the extent permitted by applicable law. ASS CIATES, P for laintiff ed n Debt leci r I taker, Esquire Our File No.: 188724 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 undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relat' g to worn falsification to authorities. David J. Apo aker, Esquire Attorney for Plaintiff DATE: 11/21/2008 LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013 STATEMENT OF ACCOUNT NORTHSTAR CAPITAL ACQUISITION LLC Debtor's Name: LARRY SLUSSER Account Number: 4071100009234133 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $1,846.11 Our File No.: 188724 EXHIBIT "A" a/} cs? ? •::? - T{ tom., Fri ?_ S Co G_r: G 1 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07017 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTHSTAR CAPITAL ACQUISITION VS SLUSSER LARRY TIMOTHY R BLACK , 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 0015:40 HOURS, on the 10th day of December-, 2008 at 909 ARMSTRONG RD CARLISLE, PA 17013 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 Service Affidavit Surcharge j? So Answers: 18.00 4.50 .00 10.00 R. h 00 32.50 12/11/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to before me this of By: day Deputy Sheriff A.D. Our File No.: 188724 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 NORTHSTAR CAPITAL ACQUISITION LLC Plaintiff vs. LARRY SLUSSER Defendant 2010APR 15 AM 10: S6 r COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7017 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, LARRY SLUSSER, in the default of an Answer, in the amount of $1,985.69 computed as follows: Amount claimed in complaint: $ 1,846.11 Less: Amount Paid: ( 0.00) Plus: Interest from November 21, 2008 to March 29, 2010 at the legal interest rate of 6.00% per annum 139.58 Attorney fees 0.00 TOTAL ,,1 $ 1,985.69 I certify that Defendant, LARRY SLUSSER, last kn,6w?address is 909 ARMSTRONG Dated: March 29, 2010 RD CARLISLE, PA 17013. 1 David J. Apothaker, Esq. Attorney for Plaintiff 41+.Oo PI) A -my dg::-1'153qD P-,4 a4osga IJokee UaA.4u.( OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013 NORTHSTAR CAPITAL ACQUISITION LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. LARRY SLUSSER Defendant NOTICE NO.: 08-7017 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 THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 800-672-0215 4115110 Our File No.: 188724 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 NORTHSTAR CAPITAL ACQUISITION LLC Plaintiff VS. LARRY SLUSSER Defendant Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237. 1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the unsworn falsification to authorities. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7017 David J. Attorney of 18 Pa.C.S.A. §4904, relating to , Esq. Dated: March 29, 2010 Our File No.: 188724 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 NORTHSTAR CAPITAL ACQUISITION LLC Plaintiff VS. LARRY SLUSSER Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7017 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. 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 Def nse Manpower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not ' the military. David J. Apothaker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Depn - mt Of Ddense Manpower Data Center M -M 9-3410 07503 NfTitar: Status Report ? ' Fta,aaau? (o d7c Service 1!tmltrrs Cisit RetiefAct Last FirstiN iddle $ 5ersice ? Date Active Dttn Sununu Active Dirty }ud Date ?rgeacg dies mat prisse.a ma ?ta?s S L'S R Lr?R,' Based on the itfonn? n you ha: e fi=-hr d, the MUId' rA;:at4 die incEad" status- Up ,,a 3?d chi to "manna nt data barks ofth&Deparbuetst lx;,-, wer Data Cerra, based on the idama6oa t out pr-, Ided, The 8&-t is tie narerrt gum c'rbe iXtNic as to eI brw,,-hes, ofthe Unionned Services (Armyr,. N;rvv, Marine Cotes, As Force, NOAA; Public Heath, and Coast Guard). Mary NT Snavely-Dnton, D'aectm tiepalmeat of Deftnse --41ar +mit Data Center 1600 Wilson Bh-cL, Suite 400 Arlingtom V .A ::,.'{Iii _593 The Diverse '.i is wer Data Center (Dt-ate) is an the `D4euse d the Defeatse Enroll and L-ligxb& F porting Sy- em (DEERS) database witch a due official source Of daaa on ' dWbfor m&an medical care and Other tkciiit'r 5vsttrns. The DoD strcaid supports the rufarcement of the Stnire Members 0v4 Rr irf Act (50 nC App, Tf idi et seq, as amended) (?C'Rr1s iti=rmtrl: kmcu ax tl? Sit!k5ct ?` arm 5s' Gish RelitlFAet e€19?0 D'??G leis i4suededs t? of 'does act y> =,e sr =t idotmati % incl'ic a eag dirt the intfMi luai is currecd? On active dm.' revoo t- , and has , ed a mug error Late In the c r r the mdhadaal referstced abm-c, or any faatiily member, liiend, or t"s mtanr asserts in aav mama that t$s- itac4r wi w' i n acme dui . , or is ctia ire tntided to the protrct ems oft$x SCRA, you arr sircua, mcou r gcd to obtain fiullt? v tr6 on cif the peTs,A i Staru 5 by m ta,*ig Owl persoes Sex a Nis the ' LC i ' L tmp , .. , -to e rb cnikt IR f'I .pt"' `?Sr D hen U' :cwt laav a ewe the error it on active dui; and volt fad to obtain this a 5dui x a Scn i r v er rtalicrx pcnitn t pr risions of that SCR,i.IDaY uzc mvvaSced am' ant you. See SG i>SC App:. §331(c) .7 yon rstst. ..: -,Aitional zzE`c rm%A)n a :. r. d ..gersc. (e g an S 5\ , 43TA' -ed accuracy c:fDOR, g: middk ),you can subv it your request again at this Web sae and we will provide a new csstiticatt for dot eprerv. "1°his response ridlects active dear- states " t the ' was Itis!t active day, fit was aria the proz ` W days. For historical it9fixenabcs, phrase coast the Service SCRA pairds-of coact More ix)wwwdon on ' Acrive Dtrtr Corms" Active duty shuts as rrporttd m this c n ti£irate is defs,-d in aceocdatue with 10 USC § 101(d)(1) fix a period cimore dm 30 c one ecutive dons. In tt¢t cast 4 a mtmt}rr of the Natimai Guard, includes service under a. call to active service atxt iced be ibe F;ai lor #l Stav -,4Deftn- fora iodofaxxed=3t)conr ,?wada?, iu r32C:SCs#0.q) forPurposes 4 rc-poading to a na6oii. J m-ffgen y declared b the Fte5Arnt and supported t,:- Federal funds All 4ctu a Guard. Reserve (AGR.) umbers nag be assiped atgatrlit an mthotizrd nwbtlizati m position, in tic unit thcy support This inchtdes Nat -• TARS, Marine Carps ARs and Coast Cnx<ad RP A s .4 tr; IAay slat ss o lies tO x l'rif°xtned Service as a shay cam€siase~sd oR'i: rr of t°sr C" S Fhtblic H eahkt $crvicc ®r t6r ',? aticirzat CYmrit. epd tltrt?spsEterrc Aahssttrac d4r?,,?.A Couao?sicaged Ccrtps'7 Tor apwrieKl efmorr iharu 3Ct cortsrcu9c°c days, 6"ermge Under Zko $C&4 tr iamaikr in .Since Cases Coverage under the SCRA is broader is some rases and iochicles some categories of parsons on active chat/ for purposes m°the 5C'R.-1 ato would not be'r led as cet A t Duty, titer d is cett&ate. tiro-; titres orders am amended to rates tiwc period of active . duty, %i ieh would odcad SCRA protrctiots. Persons seeking. to rely ,n thin vaebsite certikation should check ter make sure the orders on which SCRAprotections art based time not been w tuW to e:tt and the iv)usiv a dates of semi: e F e, &me pr*Wtions of the SSA mazy extend to pet sow w1w have received orders to repot fx azttw°e dor, cc to be inthx!#ed but who hmT not actually begun active duty or actualk- rr pwrd for induction, The ` aA Datc cox A_tn c Duty rnh i= mgn°rt because a rumberof"ections; of SCRA extend b" LnA the Iasi dates 4 aeuve env. Those who would rely on this certificate are urged to seek qua Vied legal counsel to ensure that all rights guaranteed to Service members under the SCRA are prtfceted. WAPNINC This certificate seas provi&A based an a name and SSN prm dud by tit rexutnestsr_ Proviimg an erronrwas name or SS's will cause an erroneous certificate to be provided Retx-;t IT),-%fTDCVQHSCR • 188724 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTHSTAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) LARRY SLUSSER ) NO. 08-7017 To: LARRY SLUSSER 909 ARMSTRONG RD CARLISLE, PA 17013 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: January 22, 2010 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 /,S-/ DAVID 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 ti Attorney ID #38423