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Home My WebLink About09-2619''Our t e No.: 202523 APOTHAKER & ASSOCIATES, P.C. BY: Dav?d 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. PAUL KAUFFMAN 26 NORTH RD MECHANICSBURG, PA 17050-3142 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OOq- 02619 0,'1Vj('rerV6% 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 Fite No.: 202523 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. ) PAUL KAUFFMAN ) 26 NORTH RD ) MECHANICSBURG, PA 17050-3142 ) Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: a 5- 2 6PI C ? - 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 PAUL KAUFFMAN, an adult individual residing at 26 NORTH RD MECHANICSBURG, PA 17050-3142. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100007273992; 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 $3,068.17. 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". Alp 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as abdve. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,068.17 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & OCIATES, P.C Attome for laintiff % A Law Firm BY: Dated: 4/22/2009 David J. ApTAhaker, Esquire Our File No.: 202523 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 relat g to worn falsification to authorities. David J. Ap er, Esquire Attorney for Plaintiff DATE: 4/22/2009 . 4. 1 NORTH STAR CAPITAL ACQUISITION LLC PAUL KAUFFMAN 26 NORTH RD MECHANICSBURG, PA 17050-3142 STATEMENT OF ACCOUNT Debtor's Name: PAUL KAUFFMAN Account Number: 4071100007273992 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $3,068.17 Our File No.: 202523 EXHIBIT "A" G) .,L., .. OF THE P rk it \ 'A Y X29 Ai r, 2- P1!112,' "3 *'M .60 pA AT-rY Co 131481 Er* aagasq Sheriffs Office of Cumberland County R Thomas Kline ?xojr of ?Clrmbrr Edward L Schorpp Sheri ' 4# Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF ."G SKER!FF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/30/2009 04:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on April 30, 2009 at 1630 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Paul Kauffman, by making known unto himself personally, defendant at 26 North Road Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 May 04, 2009 2009-2619 North Star Capital Acquisition LLC SO ANSWERS, %?wra?rE,??aM R THOMAS KLINE, `SHERIFF By Deputy Sheriff VS Paul Kauffman r x? Of it "Sol _6 Our file No.: 202523 '--s APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 NORTH STAR CAPITAL ACQUISITION LLC vs. PAUL KAUFFMAN ) Defendant. ) ?p ? ? R 0 T ? Plaintiff, JUL -1 2009 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-2619 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on May 05, 2009, STIPULATED by and between Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, and Defendant, PAUL KAUFFMAN parties as follows: 1 • Defendant agrees to pay the sum of $3,253.02, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2• The sum aforesaid of $3,253.02 shall be paid by the by Defendant, PAUL KAUFFMAN, to the attorneys for Plaintiff in the following manner: a. $1,000.00 to be paid on or before May 6, 2009; b. $300.00 to be paid on or before the 6t" day of each month, beginning June 6, 2009 until paid in full. All checks are to made payable to NORTH STAR CAPITAL ACQUISITION LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Our file No.: 202523 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $3,253.02, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to PAUL KAUFFMAN by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engage in'Debt Collection By: Ki b rly F. Scian, Esquire PAUL KA F M FILED OF TH, ? 2009 SUIL 10 hi '4 r