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Home My WebLink About09-4301Our File No.: 208229 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. JANET LINDSEY 129 RUSTIC DR SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: bq _ VWJ - OVil 1 c°.rm 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.: 208229 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. ) JANET LINDSEY ) 129 RUSTIC DR ) SHIPPENSBURG, PA 17257 ) Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 6P?- x'36 ( CIVIL ACTION COMPLAINT FIRST COUNT 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 JANET LINDSEY, an adult individual residing at 129 RUSTIC DR SHIPPENSBURG, PA 17257. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #4071100002086340; 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 $7,153.37. 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". I ? ? "016 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 $7,153.37 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged' ebt Co ctioi BY: Dated: June 26, 2009 David J. Apoth er, Esquire Our File No.: 208229 k 1 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 unsworn falsification to authorities. David J. A aker, Esquire Attorney for Plaintiff DATE: June 26, 2009 ,?, 4 NORTH STAR CAPITAL ACQUISITION LLC JANET LINDSEY 129 RUSTIC DR SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: JANET LINDSEY Account Number: 4071100002086340 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $7,153.37 Our File No.: 208229 EXHIBIT "A" 0 OF Try ? .. ,? TAPY ZG04 JA 2 r s' ! 4%5D PO A'rTq el* ))v 31 Sheriffs Office of Cumberland County R Thomas Kline V of 4acarlbrri Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy oFF,f,E C.: T€ ,E s?ERIFF Civil Process Sergeant North Star Capital Acquisition LLC Case Number vs. Janet Lindsey 20094301 SHERIFF'S RETURN OF SERVICE 06/29/2009 08:50 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2009 at 2050 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Janet Lindsey, by making known unto herself personally, defendant at 129 Rustic Drive Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 June 30, 2009 SO ANSWERS, A?? R THOMAS KLINE, SHERIFF De ut Sheriff 13 C1. c- 51 -71 w <_ ` 4 Fl? 4111 Our File No.: 208229 APOTHAKER & ASSQCIATES, P.C. BY: David J. Apothaker 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. JANET LINDSEY Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4301 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JANET LINDSEY, in the default of an Answer, in the amount of $7,349.27 computed as follows: Amount claimed in complaint: $ 7,153.37 Less: Amount Paid: ( 0.00) Plus: Interest from June 17, 2009 to August 19, 2009 at the legal interest rate of 6.00% per annum 71.40 Attorney fees 0.00 TOTAL $ 7,349.27 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, JANET LINDSEY, last known address is 129 RUSTIC DR SHIPPENSBURG, PA 17257. APOTHAKER ASS CIATES, P.C. Atto s for laintiff A Law Firm E izaaed Debt Collection By: J. Apothaker Dated: August 19, 2009 Our File No.: 208229 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker 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. JANET LINDSEY Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4301 Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 129 RUSTIC DR SHIPPENSBURG, PA 17257. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if thSJ)efendant(s) is/are in any branch of the military. ns anpower Data Center has sent back our inquiry Mary M. Snavely-Dixon, Director of the Dltarl/ indicated that the Defendant(s) is/are not in the mi David J'Apothaker Attorney for Plaintiff The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. APOTHAKER & ASSOCIATES, P.C. ATTORNEYS AT LAW Dept of Ddimse Mapower Data Center Military Status Rleport Pursuant to the Servicemembers Cnil Rtkrf Act _K Last Nata? Fusva'r e I B"a Date AUG-19-2009 08:0638 Actira'Uai 8?taa SwvkxtAg=cy LLNDSEY TANET 'Based on the i you have furnished, the DNII3C does not possess any infonnation indicating dot the i mlividual is cu rrealy on active duty. Upon searching the ifimation data banks of the Department of Defense Manpower Data Center, based on the i6brmation that you mod, the above is the cured status of the dal as to aM branches of the Military. )I)IttUt IA 7(0r4j4"_ in- Mary M, Snavely-Dixon, Director Dot of Defense - Manpower Data. Cater 1600 Nilson Bhr&z Suite 400 Ac ton, VA 22209-2593 The Defense Manpower Data Corner (DMDC) is an organization of the Department of Defense that ' i the Defense EnmIment and Efigrbr`b!' y Reporting System (DEERS) database which is the official source of data on eighky for military medical care and other qty systems- The Deb's of Defense strongly supports the a focc t of the Servic bees Civil Relief Act [50 USCS Appx_ §§ 501 at seq] (SCRA) (forme€fy the Soles' and Sailors' il Re of Act of 1940)_ D DC has wed hundreds of of "does thousands not possess any z ocmation ine catang that the individual is currently on active duty" respow&--% and has otperience d a small error rate. In the event the individual referenced above, or any family member. Srienct or representative asserts in any mantiff that the individual is on active dusty, or is odierwise entitled to the protections of the SCRA, you are strongly encouraged to obtain firrther vtri6cation of the person's active duty status by contacting that person's Military Ser ice via the "defens c.mmil" URL provided be ow. If you have evidence the person is on active-day and you fag to obtain this additional Miry Service s provisions of the S CRA may be invoked against you_ If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certil cafe for that query. This response reflects current active: duty status only. For historical x formation, please contact the May Service SCRA poiuts- of-contact. See:bnp-f?,.vvrs dd:,L,;d k.r !Agt2i ?09SLDR.1 WARNING- _ 11is catifcate was provided based on a name and Social Security umba (SS NI) provided by the requester. Providing an erroneous name or SSN wil cause an aroneous cesti6ca te; to be provided. RsportM:CG VMJM 208229 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) JANET LINDSEY ) NO. 09-4301 To: JANET LINDSEY 129 RUSTIC DR SHIPPENSBURG, PA 17257 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 04, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR J DAVID . APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 6ff..???' ,??? Sheriffs Office of Cumberland County T Tomas Kline ??? of ?ttnb ?? d Edward L Schorpp Solicitor Ronny R Anderson Jody S Smith Chief lJeputy Civil Process Sergeant North Star Capital Acquisition LLC vs. Case Number Janet Lindsey 2009-4301 SHERIFF'S RETURN OF SERVICE 06/29/2009 08:50 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2009 at 2050 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Janet Lindsey, by making known unto herself personally, defendant at 129 Rustic Drive Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 June 30, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ?? De ut, Sheriff 3 E? 4 ALLD- OF THE P- I 2009 AUG 27 P1, 1: 02 4?ti (r _. :1 :1 R PEN r7j OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JANET LINDSEY 129 RUSTIC DR SHIPPENSBURG, PA 17257 NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, vs. JANET LINDSEY Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY } NO.: 09-4301 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgme as been entered against you in the above proceeding as indicated below. GUS XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker Esq_ at this telephone number: 215-634-8920 PAO