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Our File No.: 193082
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 17011-3841
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
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
Mb.
Our File No.: 193082
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 17011-3841
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: O 9_ 4,5-3 C.t;-j Tom,.....
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 17011-3841.
3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in
Interest of Account #6048700003956386; 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 $5,544.91. 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
$5,544.91 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
TES, P.C.
A Law Firm Ekiaaded in Deaf Collection
BY:
Dated: 1/19/2009
David J. ,pothaker, Esquire
Our File No.: 193082
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 rel4dn4to unworn falsification to authorities.
David pot'haki5r-, Esqi
Atto ev for Plaintiff
DATE: 1/19/2009
NORTH STAR CAPITAL ACQUISITION LLC
JOSEPH E JIRAS
2014 LINCOLN ST
CAMP HILL, PA 17011-3841
STATEMENT OF ACCOUNT
Debtor's Name: JOSEPH E JIRAS
Account Number: 6048700003956386
Original Creditor: WELLS FARGO FINANCIAL
Balance Due: $5,544.91
Our File No.: 193082
EXHIBIT "A"
O .p ?.3 t , rT.
W y _ IC '
?s? ti
SHERIFF'S RETURN - REGULAR
CASE NO: 2009-00450 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NORTH STAR CAPITAL ACQUISITION
VS
JIRAS JOSEPH E
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
JIRAS JOSEPH E the
DEFENDANT , at 1830:00 HOURS, on the 30th day of January , 2009
at 2014 LINCOLN ST
CAMP HILL, PA 17011-3841
JOSEPH E JIRAS
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
13.50
"e- 00t;
00 E
10.00 R. Thomas Kline
.00
41.50 02/02/2009
APOTHAKER & ASSOCIATES
By:
day Deputy eriff
A. D.
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