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HomeMy WebLinkAbout09-2617Our File No.: 203380 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. DEBORAH A PRINZ 456 SAMPLE BRIDGE RD ENOLA, PA 17025-1024 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - a?&17 eivil It?rN, 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.: 203380 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. DEBORAH A PRINZ 456 SAMPLE BRIDGE RD ENOLA, PA 17025-1024 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O4. 24. /T eL? clel-- 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 DEBORAH A PRINZ, an adult individual residing at 456 SAMPLE BRIDGE RD ENOLA, PA 17025-1024. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #19186814; 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 $1,305.17. 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 $1,305.17 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A O TES, P Attorney r Pl tiff A Law Firm Enaa ed in ebt QSlleci BY: Dated: 4/22/2009 David J. Apothaker, Esquire Our File No.: 203380 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 made subject to the penalties of 18 Pa.C.S.A. 4904 understands that the statements therein are unworn falsification to authorities. David J. A)yvtliaker, Esquire Attorney for Plaintiff DATE: 4/22/2009 4- DEBORAH A PRINZ 456 SAMPLE BRIDGE RD NORTH STAR CAPITAL ACQUISITION LLC ENOLA, PA 17025-1024 STATEMENT OF ACCOUNT Debtor's Name: DEBORAH A PRINZ Account Number: 19186814 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $1,305.17 Our File No.: 203380 EXHIBIT "A" 1!-r' i,;E OF T. NOTAPY 2DO9 A R 2 7 F ri 112: ? i C` _ .? T 4078.50 PA ATN ftt 161590 Sheriffs Office of Cumberland County R Thomas Kline ?jr at C'UtibcEdward L Schorpp x°11Solicitor Sheriff a. Ronny R Anderson Jody S Smith Chief Deputy oFrF it Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/01/2009 07:41 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on May 1, 2009 at 1941 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Deborah Prinz, by making known unto Deborah Prinz personally, at 456 Sample Bridge Road, Enola, Cumberland County, Pennsylvania, 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SO ANSWERS, SHERIFF COST: $37.90 May 05, 2009 Docket No. 2009-2617 North Star Capital v Deborah A. Prinz R T fSI,'SHERIFF c uty S i N C O ?ry ? ' ! ("t _ , ? om t S - - . 3