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Home My WebLink About09-0437. Our File No.: 193053 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. TERRENCE S FOWLER 186 RUSTIC DR SHIPPENSBURG, PA 17257-9464 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY Clivi NO.: O9 - N37 i -Ters-. 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 Oun File No.: 193053 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. TERRENCE S FOWLER 186 RUSTIC DR SHIPPENSBURG, PA 17257-9464 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 9- Y37 Ci,;J -7Z- 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 TERRENCE S FOWLER, an adult individual residing at 186 RUSTIC DR SHIPPENSBURG, PA 17257-9464. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100008455127; 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 $3,430.25. 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 $3,430.25 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER Aedin ATES, P.C.- Attornetiff A Law Firm Erie' ns bt C4`ecti on BY: David J. Apoth cer, Esquire Dated: 1/15/2009 Our File No.: 193053 A. 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 relatin o sworn falsification to authorities. David J. Apoth Esquire Attorney for Plaintiff DATE: 1/15/2009 i .%kk NORTH STAR CAPITAL ACQUISITION LLC TERRENCE S FOWLER 186 RUSTIC DR SHIPPENSBURG, PA 17257-9464 STATEMENT OF ACCOUNT Debtor's Name: TERRENCE S FOWLER Account Number: 4071100008455127 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $3,430.25 Our File No.: 193053 EXHIBIT "A" ('l rv cob i tic Z ??rm Qo?, 00 ri 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-00437 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQUISITION VS FOWLER TERRENCE S R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT FOWLER TERRENCE S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT NOT FOUND , as to FOWLER TERRENCE S 186 RUSTIC DR SHIPPENSBURG, PA 17257-9464 DEFENDANT IS DECEASED. DOD: 10/22/08 Sheriff's Costs: So answer Docketing 18.00 lI'? ??J Service 18.00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 51.00 APOTHAKER & ASSOCIATES 02/02/2009 Sworn and Subscribed to before me this day of , A.D. lift, ?wr C ! •01 IN 9- 83360OZ RtivlVot:?ir.u 3Hi JU 3OH-11'V-9-TI A ! .w Our File No.: 193053 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 NORTH STAR CAPITAL ACQUISITION LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. TERRENCE S FOWLER Defendant. NO. 09-437 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS,SQCIATES, P.C. A Law Firm F By: David J Dated: 2/17/2009 Debt Collection Esquire 117) ?rn