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HomeMy WebLinkAbout09-1722Our File No.: 197887 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: q L / 7 1-I C?vt?ik DIANA L SUMMERS 5446 OXFORD DR MECHANICSBURG, PA 17055 Defendant. 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.: 197887 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. DIANA L SUMMERS 5446 OXFORD DR MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. C h< , 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 DIANA L SUMMERS, an adult individual residing at 5446 OXFORD DR MECHANICSBURG, PA 17055. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #32428719; 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 $3,036.39. 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 s to the extent permitted by applicable law. $3,036.39 and requests this Court award Plaintiff attorney's fees SPX APOTHAKER & ES, P.C. Attorne foA Law Firm Ena>iged iyi Debt Collection Dated: 3/11/2009 BY: David J. Apothaker, Esquire Our File No.: 197887 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 relating to unworn falsification to a ?tin'ties. David J. Apb4aker, Esquire Attorney for Plaintiff DATE: 3/11/2009 NORTH STAR CAPITAL ACQUISITION LLC DIANA L SUMMERS 5446 OXFORD DR MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: DIANA L SUMMERS Account Number: 32428719 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $3,036.39 Our File No.: 197887 EXHIBIT "A" v 'e 1 1 ? A 4k C) ° ? ' ' r n lP r ". i " _ ?t . o `per _ -ID Zzz 7 i y -.?J Sheriffs Office of Cumberland County R Thomas Kline ?.°?tr of i.u,nbrrt?g? ...?... L Solicitor Sherf Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF T"E $NSRIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/17/2009 07:05 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that on April 17, 2009 at 1905 hours that despite numerous attempts this Complaint and Notice expired before service could be made and is returned not served. SHERIFF COST: $73.00 April 21, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Docket No. 2009-1722 Northstar Capital v Diana Summers ALED --()i- f-v OF THE PR iHONOTARY 2€109 APR 27 A1411:34,