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Home My WebLink About09-0435Our tile No.: 193 049 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. CRAIG K ROSS 1183 KINGSLEY RD CAMP HILL, PA 17011-6113 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: bi- q55 0'-1V-1[ Iertt 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 Ourtile No.: 193049 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. CRAIG K ROSS 1183 KINGSLEY RD CAMP HILL, PA 17011-6113 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- y 3S 6;J 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 CRAIG K ROSS, an adult individual residing at 1183 KINGSLEY RD CAMP HILL, PA 17011-6113. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100004785261; 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 $6,355.10. 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. above. 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 $6,355.10 and requests this Court award Plaintiff attorney' lees and costs to the extent permitted by applicable law. ; P.C. APOTHAKER /din SO/tCollection Atto y PlaiA Law Firm E jaa D BY: David J. Xj;othaker, Esquire Dated: 1/15/2009 Our File No.: 193049 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 relatingf Insworn falsification to authorities. David J. A o er, Esquire Attorne or Plaintiff DATE: 1/15/2009 CRAIG K ROSS 1183 KINGSLEY RD CAMP HILL, PA 17011-6113 STATEMENT OF ACCOUNT NORTH STAR CAPITAL ACQUISITION LLC Debtor's Name: CRAIG K ROSS Account Number: 4071100004785261 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $6,355.10 Our File No.: 193049 EXHIBIT "A" 'fA- `?' ? : ?? ? ^ ? }`C- ? _' ?-, "' `'' ?: -n `r ter. y ? ? ? a ?::.-. ? . a . P?.. - r =- ?, o ? -- ?` - ? J ? ? --, ? L ? ? r? L ??C SHERIFF'S RETURN - REGULAR CASE NO: 2009-00435 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS ROSS CRAIG K 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 Pn.gq CPATC: K the DEFENDANT , at 1607:00 HOURS, on the 29th day of January , 2009 at 1183 KINGSLEY RD CAMP HILL, PA 17011-6113 CRAIG K ROSS by handing to 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 Sworn and Subscibed to before me this of So Answers: 18.00 14.40 00 10.00 R. Tomas Kline .00 42.40 01/30/2009 APOTHAKER & ASSOCIATES By. day Deputy riff A. D. ev 1 f S ` y ,'r Our file No.: 193049 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, VS. CRAIG K ROSS rte' %`'? COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-435 Civil Action STIPULATION IN LIEU OF JUDGMENT Defendant. The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on February 02, 2009, STIPULATED by and between Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, and Defendant, CRAIG K ROSS parties as follows: 1. Defendant agrees to pay the sum of $6,550.64, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $982.50 have been applied to the amount of $6,550.64, and the amount due and owing as of February 02, 2009 is $5,568.14. 3. The sum aforesaid of $5,568.14 shall be paid by the by Defendant, CRAIG K ROSS, to the attorneys for Plaintiff in the following manner: a. $982.50 to be paid on or before February 27, 2009; b. $100.00 to be paid on or before the last day of each month, beginning March 31, 2009 until paid in full. All checks are to made payable to NORTH STAR CAPITAL ACQUISITION LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 4. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $6,550.64, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to CRAIG K ROSS by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys fo222t aintiA Law Firm EngageCollection By: Scian, Esquire C?4 /Y ;Cd CRAIG ROSS c-S _ :J