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Home My WebLink About08-7018.b s Our File No.: 188788 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. JOSEPH E JIRAS 2014 LINCOLN ST CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D ?-- -?Oil? C -iv- I -f CJ A, 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.: 188788 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. JOSEPH E JIRAS 2014 LINCOLN ST CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 8 ?,-- 70I 9 6J0, / -/ u'A. 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 JOSEPH E JIRAS, an adult individual residing at 2014 LINCOLN ST CAMP HILL, PA 17011. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100018512560; 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 $1,821.44. 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 $1,821.44 and requests this Court award Plaintiff attorney's APOTHAKER & Attorney A Law Firm Eniza4 BY: Dated: 11/21/2008 David J costs to the extent permitted by applicable law. TES, P.C. Esquire Our File No.: 188788 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 understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 unsworn falsification to authorities. David J. Aotlaker, Esquire Attorney for Plaintiff DATE: 11/21/2008 NORTH STAR CAPITAL ACQUISITION LLC JOSEPH E JIRAS 2014 LINCOLN ST CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: JOSEPH E JIRAS Account Number: 4071100018512560 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $1,821.44 Our File No.: 188788 EXHIBIT "A" b° V Tom' r ' Y' 1" V n A M1 i SHERIFF'S RETURN - REGULAR CASE NO: 2008-07018 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS JIRAS JOSEPH E TIMOTHY BLACK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ,LIRAS JOSEPH E the DEFENDANT , at 1410:00 HOURS, on the 31st day of December , 2008 at 2014 LINCOLN STREET CAMP HILL, PA 17011 by handing to JOSEPH E JIRAS 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: So Answers: Docketing Service 18.00 40.50 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 68.50 01/02/2009 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: -i9 before me this day eputy Sheriff of A.D. ?, ;-:::, ?? -;? ?? _{ ,. _? ?r?, c.? _,LL, - ?? ?.. $* :-; Our File No.: 188788 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. JOSEPH E JIRAS Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7018 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JOSEPH E JIRAS, in the default of an Answer, in the amount of $1,869.55 computed as follows: Amount claimed in complaint: $1,821.44 Amount Paid: - $(0.00) Interest from November 21, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $48.11 Costs $0.00 Attorney fees $0.00 TOTAL $1,869.55 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, JOSEPH E JIRAS, last know APOTHAKER & A Law Firm By: is 2014 LINCOLN ST CAMP HILL, PA 17011. )CIATES, P.C. laintiff Debt Collection Dated: 5/14/2009 FILED-C """'E P-P 017Y', '?.;E THE E-?,L..,I,?.t,?nTARY 2009 MAY 19 Ph 3,1: 21 TO: JOSEPH E JIRAS 2014 LINCOLN ST CAMP HILL, PA 17011 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, vs. JOSEPH E JIRAS Defendant. NOTICE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7018 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: 215-634-8920 7h,?, 0/, ? I Our File No.: 188788 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 Plaintiff, VS. JOSEPH E JIRAS Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7018 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 2014 LINCOLN ST CAMP HILL, PA 17011. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the Mary M. Snavely-Dixon, Director of the Defens indicated that the Defendant(s) is/are not in the military, David J. AN Attorney for r Data Center, located at 1600 Wilson 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. Depactmant afDdwse Manpower Data Centex MAY-14-200910:13:0$ 40 I4lkary Stokes Rgpod Pnrnant to the Sesvicaatewbers Civi ReWAct JMS I I JOSEPH E Based on the won you have fornishcd they Dh= does ax pries say iaf xu alion diat the ncividnal is curraeudy an active, daty. Upon searching the : funnid n data franks of the Department of Die Maapa ww Dam Cotter, based on the ifiamatiou, that ym provided, the above is the ccarent status of the in dod as to A branches of the may. Owt A Load- ' Mary X Sir Dbwn. Director Department of Manse - Manpower Dam C:nter 1600 WE= BMI, SWe 400 A& *Ion. VA 22209-2593 Mae Vie: Nlarpower Data Canter tD 3 is as a i of ttre Dqartned of Dd a dealt aaaintains the D l o t sad W Roprarti4g System (DEERS) database which a tic offieW soarmo(deta on eligWibr volkary medcal rare and other eIgNty sysiteaos, ?1? a \ a?n e(st ? ft??e sa yer did€AAd j50 uses , §§5+ j et seq tJM) ? the ?! and Senors' CH RAdAct of 1 _ ? has issued aftousands of 'does not possess myii Mnation indicating that the k&r;&Ml is carren* an adhere reVonsm and has a imccdl a smal ecra rate. In the event the ikfiivic ml ralerenced above, air my faanily? member, fiend. at errs a asserts in any ninnuer that the in fividnal is an active duly, at is otherwise e ntMed to the protections of the SCRA, you we stroa* encouraged to obtain der vegan of the person`s adive day sea' by contacting persas Mkxy Service via the - snit" uRL provided bellow. Nyou, have evidence the person is an active-duty and you fah to obtain this adtionsl icy Service weridcatiM provisions ef ttre SCRA may be invoked again you. My+oo main timer n on about the person { e.g., an SSN, arrprcved accuracy of DOB, a nnidd{e name), you can submit your redhnest again at this Web site and we w provide a new certi6cate for that query. Ma response reelects current active duty status only. Fat habodcah • w1brinadon, please conked tie N ilitery Service SCRA paints- atIcoated. Sec: btltsjtwvvw ?R heal WARN'1NC: Tbis vccfficate was prwA&dh band an a tie and Social Security naoober (SSN) provided by the regaiester. Provid ng an erroneous some or SSN veil cue an exroneous cardlicate, to be pcavkled. OHM.-UME?73T Orr 188788 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) JOSEPH E JIRAS ) NO. 08-7018 To: JOSEPH E JIRAS 2014 LINCOLN ST CAMP HILL, PA 17011 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: February, 02, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DA I 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 #3 8423 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07018 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS JIRAS JOSEPH E JAN 14 2009 t TIMOTHY BLACK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JIRAS JOSEPH E the DEFENDANT , at 1410:00 HOURS, on the 31st day of December., 2008 at 2014 LINCOLN STREET CAMP HILL, PA 17011 by handing to JOSEPH E JIRAS 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: So Answers: Docketing 18.00 Service 40.50 ..?.t' .,?/ Affidavit .00 0 _ Surcharge 10.00 R. Thomas Kline 00 68.50 01/02/2009 APOTHAKER. & ASSOCIATES Sworn and Subscibed to By: before me this day eputy Sheriff of A.D. ()F Yr?FELElD-.( t- i(.,C _tA, V 4 ZCH MAY 19 PH G,: 21 Z- ?? CYO- /3y?yd ?? ?317 Lp