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Home My WebLink About09-2618Our File No.: 202537 APOTHAKER & ASSOCJATES, P.C. BY: Da)Pid 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. JOHN RUSSEL 172 SHIPPENSBURG MOBILE EST SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: pq - 01(018 NOTICE 0';V;t_TirW_ 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.: 202537 APOTHAKEk & ASSOCjATES, 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. JOHN RUSSEL 172 SHIPPENSBURG MOBILE EST SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o y,- a2 G/,f C-4 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 JOHN RUSSEL, an adult individual residing at 172 SHIPPENSBURG MOBILE EST SHIPPENSBURG, PA 17257. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100009800784; 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 $2,283.51. 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 $2,283.51 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS TES, P.C. Attorney PI ' tiff A Law Firm Eneaefoin ebt Collection. BY: David J. Apot er, Esquire Dated: 4/22/2009 Our File No.: 202537 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 4worn falsification to authorities. David J. Ap thaker, Esquire Attorney laintiff DATE: 4/22/2009 NORTH STAR CAPITAL ACQUISITION LLC JOHN RUSSEL 172 SHIPPENSBURG MOBILE EST SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: JOHN RUSSEL Account Number: 4071100009800784 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $2,283.51 Our File No.: 202537 EXHIBIT "A" 0 1 "'IF 2u 27 P 1 ?c IT, I 411.so Po ArrY 091* 13114 per' amaga Sheriffs Office of Cumberland County R Thomas Kline Q „v, at Cirm6rrf Edward L Schorpp Sheriff` Solicitor L> .? Ronny R Anderson Jody S Smith Chief Deputy 1r'"r ="-RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/30/2009 05:53 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: John Russel, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant John Russel. Per neighbor the defendant, John Russel moved to E. Garfield Street Sunbury, Pennsylvania a few weeks ago. The Shippensburg Postmaster has advised that mail is still delivered to 172 Shippensburg Mobile Est. Shippensburg, Cumberland County, Pennsylvania 17257 for the defendant, John Russel. SHERIFF COST: $51.00 May 07, 2009 2009-2618 North Star Capital Acquisition LLC VS John Russel SO ANSWERS r R THOMAS KLINE, SHERIFF N C) T2 t -? ^p ITT 2`a t' T t Cn rn a C-D ?a Co Our File No.: 202537 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 Plaintiff, vs. JOHN RUSSEL Defendant. OF THE FILED-OFFICE 101IMAR23 AMID 18 CUWIRNLSAND COUNTY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2618 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attome or Plaintiff A Law Firm Ed in Debt Collection By: _ / David J. othaker, Esquire Dated: 3/17/2011 111111M11111111111111