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"
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tom.,
Fri ?_
S Co
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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
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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
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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