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Home My WebLink About09-4303 Our File No.: 203446 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. WILLIAM YAREMCHAK & JANICE YAREMCHAK 4084 SENECA AVE CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CA _ 4/V3 NOTICE 0, tvilT*rm 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 t. • Our File No.: 203446 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. ) WILLIAM YAREMCHAK & JANICE ) YAREMCHAK ) 4084 SENECA AVE ) CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0- q30 3 cj,;1 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 WILLIAM YAREMCHAK & JANICE YAREMCHAK, an adult individual residing at 4084 SENECA AVE CAMP HILL, PA 17011. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #98105011; 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 $3,111.65. 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 $3,111.65 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for intiff A Law Firm Engag Debt ection BY: David J. Apothaker, Esquire Dated: June 26, 2009 Our File No.: 203446 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 t nsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: June 26, 2009 NORTH STAR CAPITAL ACQUISITION LLC WILLIAM YAREMCHAK & JANICE YAREMCHAK 4084 SENECA AVE CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: WILLIAM YAREMCHAK & JANICE YAREMCHAK Account Number: 98105011 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $3,111.65 Our File No.: 203446 EXHIBIT "A" 203446 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: NORTH STAR CAPITAL Expiration Date: ACQUISITION LLC Type of Action: Civil Action Defendant/s: WILLIAM YAREMCHAK Serve Upon: WILLIAM YAREMCHAK Address for Service: 4084 SENECA AVE CAMP HILL, PA 17011 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge O Deputize O Certified Mail O Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 b:1 FILCH -?:=F-,,.: OF THE F;Kl H FARY 20019 i' NW 25 Fi. I: LL' A 1 X18-60 M ATE`/ GGw 1385(re(o ? 01,?7,73a Sheriffs Office of Cumberland County R Thomas Kline ?ojtigtp qt C1r1r1&"'f',t Sheriff Ronny R Anderson Chief Deputy OF P CE OF T"E s"ERIPF Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant North Star Capital Acquisition LLC vs. Janice Yaremchak Case Number 2009-4303 SHERIFF'S RETURN OF SERVICE 07/01/2009 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: Janice Yaremchak, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Janice Yaremchak. William Weiss, current resident at 4084 Seneca Avenue Camp Hill, PA 17011 states that he has owned this property for over a year. An exact address is not available. /l17 SHERIFF COST: $46.50 SO July 02, 2009 KLINE, SHERIFF c: Ql _? rr f3 F G) .A Our File No.: 203446 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09-4303 WILLIAM YAREMCHAK & JANICE YAREMCHAK Defendant. PRAECIPE TO REINSTATE COMPLAINT - CIVIL ACTION TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned Civil Action for an additional thirty (30) days. APOTHAKER & ASS( Attorney for P A Law Firm Enaaded in BY: IATES, P.C. Collection David J. Apothaker, Esquire Dated: 8/6/2009 RLEd-C3 _100E OF THE !' C i Fin,,IOTAARY 2009 AUG 17 PM Z: 4 7 ???. S Sheriffs Office of Cumberland County R Thomas Kline ZLED° ? ; Sheri C THE P F - -" )TARP Ronny R Anderson Chief Deputy 20119 AUG 31 Pi,l 3: 3 4 Jody S Smith ?i PCu Civil Process Sergeant QFicE of hE `"`RIFF Edward L Schorpp Solicitor North Star Capital Acquisition LLC Case Number vs. 2009-4303 Janice Yaremchak SHERIFF'S RETURN OF SERVICE 08/27/2009 03:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2009 at 1500 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Janice Yaremchak, by making known unto William Yaremchak, adult in charge at 128 S. Locust Point 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. 08/27/2009 03:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2009 at 1500 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: William Yaremchak, by making known unto himself personally, at 128 S. Locust Point 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: $53.00 SO ANSWERS August 28, 2009 R THOMAS KLINE, SHERIFF EY Deputy Sheriff r = 1• Our File No.: 203446 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. WILLIAM YAREMCHAK & JANICE YAREMCHAK COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-4303 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOC ES, P.C. Attorneys for nti A Law Firm Engaged ' Collection By: David J. Apothalq, Esquire Dated: October 1, 2009 FItE? ??=?=f?E OF THE FPS #=f?"OTARY 2009OCT -8 PH 2: 30 CU JNI