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Home My WebLink About09-4755Our File No.: 214824 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 L WENGER 203 ZION RD NEWBURG, PA 17240-9366 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 V75-5 Cram 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.: 214824 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 SPAR CAPITAL ACQUISITION LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. JANET L WENGER 203 ZION RD NEWBURG, PA 17240-9366 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09 - y uy G'u? 7-z,.- 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 JANET L WENGER, an adult individual residing at 203 ZION RD NEWBURG, PA 17240-9366. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account #34023905; 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 $1,650.45. 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 $1,650.45 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for P tiff A Law Firm EnizagedAn ebt Collection BY: Dated: 7/10/2009 David J. Apoth ' er, Esquire Our File No.: 214824 VERIFICATION David J. Anothaker, 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 tolinsworn falsification to authorities. David J. Ap&baker, Esquire Attorney for Plaintiff DATE: 7/10/2009 NORTH STAR CAPITAL ACQUISITION LLC JANET L WENGER 203 ZION RD NEWBURG, PA 17240-9366 STATEMENT OF ACCOUNT Debtor's Name: JANET L WENGER Account Number: 34023905 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $1,650.45 Our File No.: 214824 EXHIBIT "A" FILED - C, r,r THE 2GG9 Je 1 Fi 12: 22' d 1 ' i .7 F.6a C*_ / ra 3.2z- ja", ,r S. 0 ?/ n cA ft to ?i Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor k. 0 1ttN6rf u r OFFICE F THE SHERIFF FILED--041CC OF THE j 'r;H,I0TARy 7009 JUL 22 PH 3: [7 CUIVS? `:. ? , .:?? ?V?'Y Ci?t'VS?'f VA,NiIA ' North Star Capital Acquisition LLC vs. Janet L. Wenger Case Number 2009-4755 SHERIFF'S RETURN OF SERVICE 07/20/2009 05:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 20, 2009 at 1700 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Janet L. Wenger, by making known unto herself personally, defendant at 203 Zion Road Newburg, Cumberland County, Pennsylvania 17240 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 July 21, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF eputy Sheriff Our File No.: 214824 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 L WENGER Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JANET L WENGER, in the default of an Answer, in the amount of $1,675.63 computed as follows: Amount claimed in complaint: Less: Amount Paid: Plus: Interest from July 10, 2009 to October 30, 2009 at the legal interest rate of 6.00% per annum Attorney fees TOTAL I certify that Defendant, JANET L WEN NEWBURG, PA 17240-9366. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4755 David J. Apoffiaker, Esq. Attorney for Plaintiff $ 1,650.45 ( 0.00) 25.18 0.00 $ 1,675.63 is 203 ZION RD Dated: October 30, 2009 l Our File No.: 214824 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. JANET L WENGER Defendant NO.: 09-4755 Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. AL,Esq. At torney for Plaintiff Dated: October 30, 2009 It- Our File No.: 214824 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 L WENGER Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4755 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 203 ZION RD NEWBURG, PA 17240-9366. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-259 , f the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defe se anpower to Center has sent back our inquiry indicated that the Defendant(s) is/are not i the ilitary. David J. A ak Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. 4 Depart ne d ofDdrnsr lMamiower Data Center fief-34-24179 073719 0 Mlitary Staff Report Paarsa wd to the Semice %terobe" Civil ReW Art <"it F4st'3lidd6 &OR Date AttirelwkwStnfas AttivsDoty Ea Daft semice Na»e Atwrr,° 4 ?G_F. JAN T Based r t4-- < ormttri n ,ou Imes 6= hod. t}:? Milk dc es cwt posses*.",. jifdrtaxu mdtcaung die mdnwdual stains" UPcaa the ' data baatdes of the Department ofDd me Manpower Daft Otsaft, based dot flue ' am you presided, the abate is the cvrreat status oft e i kdiaidval as to al brancbes of the Vvifisrmed Senices (Amy, Na4w, ;Marine Carps, Air Farce, NOAA, Pubk liealtht„ and Coast Guard). ,Ut 14 jj60+ - Diary kl. Snnvcly-D scan, Director Department of e -,Mmpwxa Data Center 1640 Wli m WC Suite 440 AifiVon, VA 22249-2593 l1w Dddaiw Maapo-er Data C mw (MMDC) is an of the Departmes orDdtFme that mak"im to De(Me Enrolment and EkPW , Reporting Systtan (DEERS) database Which a the officud Source of data an ' for wry D]edicat care and otheP ' x}Aftm The DoD strongy mWorts art cuforcemaa or the Srnicc'NSrmbers QA Rehirf Act (rb L'SC App. § ? 501 etsoy as amended) (S A) (famed kwmu as tde Szrlt re and Sakrs' Ctvit R;eiaefAct of 1944). DMDC has isnxdhamckeds offtusands of 'saes not pmens any death the indiaidasi is eaaready cc adze dory responses, asad has experienced a until error rate. In the nvat the mat rdereared ebow, or fataiy member, SW4 or representaan c asserts is any mamtcr dart doe in&idt il' it on active duty. or is c6noise caMed to tie Pr#citiaro of the SACRA, you we stronpd ' sowaraged to oMain. firdw V cftlse Prioris stains b... dot persoes Savice via doe " :azl" t;RL ? ``u m ma rs 0'4,- II7 R you berm evidwe on person is on ac*c d-V and 3'Mi to Obtaim this adtfionA S=vka , rLmime prcnwcns cfthe SCRA maw be i mcked agaiast Pte- Sec SO L,SC App. §52.1(c). If wu obtain addainnal t 9?mt the pmt (e,g, an SSN, iaaprove4 eccwwy ofDAD, a njdcge roarer), 5'!m cats submit vow request aged at flea 4r cb site and we uil ptavyk a soar certificate for that qmv_ This respow raflects active defy states " date 11w wdsvkhW was bast on active duty. fit wft whin lbe Preceding 367 days. For historical inkanation, pkase contact thre Service SCR A points-of=contact, Momixformatitrar on active DxW Sea w ' Active duty stages as reported in thus d aw is defined in accordance with 14 USC § 101(&)(1) fkwa petiod of moire dan 34 etrtsecu&e dawn. In Oat cast ofa member of the Na" Canard, indddes seise oader a calk to active $micc audictiled by One President or the Secretry of De cam for a parik A of more dean 30 cowecwvt dap wider 32 U SC § $020 far Purposes of responding to a aafiotW - dtcwrd by the President and supported by Federal farads. AN 4crrrr Guard Rewvr (AGR) mr s aunt be assigned against an aothorizrd mwb&ufion poik on in due emit they suppom Thiis mcktles -Nmy'TARs, Marine Caps ARs and Coast Guard RPAt_ Antis e DAs stag also appfies. to a Umfonned Swhee member ulna is an at a date commissioned officer of the U. S, Paebl - Health Settice or for National Octanic and Atmosphesrk Administration NOAA Czaa issicsd Coshes) for a period of mvrt than 3 0 coasenatnr days- C'oreWe Under the SC°R9 it Smader m $axw Easer Coverage tinder she SCRA n broader in some cases and includes some catego ies of parsons on active duty for purposes c£the SCRA ware wotid not be repotted as on Actin a Dotty hander this ver freak. :Many bons orders arc awneuded to casrnd the period of active dwt}, which would extend SCRA protections. Persons seeking to rely on this dwxM check to make sot the dithers on wfi eh SCRA piottehons; are based have not been muended to cdend Our iudasive dates o(ser? ice. F , some protections of the SCRA may attend to persons who have recen,ed orders w report fir acfmv dmy or to be iraihaeferlx but Sabo have rat actual K, bcgon active duty or acts s repotted far m&xlson. the Lad Dint on Active Duty entry is important because a. nranber ofprotectnnns of SCRA CXk d beYvnd that last dates of Wfi a tom: Those who would rely on this certificate are urged to s+edt wed legal cotand to eusm,c ttuat al rights gnarantee+d to Service usembers under the, SC'RA are protected. NVAR`L3G- This date was pro ded based as ate and SSN provided by f9ic rcclncsttr? Presiding an aroneons name at SS'4 wig cause an erroaeatts certificate to be provided. Report a2GTCS5JN1! 214824 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) JANET L WENGER ) NO. 09-4755 To: JANET L WENGER 203 ZION RD NEWBURG, PA 17240-9366 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 12, 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 IZA ID J. APOTHAKER, ESQUIRE AP THAKER & ASSOCIATES, PC A w Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 PLED--(:'''wiCE. FARY 2Gul N J i 6• V V +1+•oo Pb A`nq ?,`? tb83?0 No?coe- ?? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JANET L WENGER 203 ZION RD NEWBURG, PA 17240-9366 NORTH STAR CAPITAL ACQUISITION LLC vs. JANET L WENGER Plaintiff ) Defendant NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4755 Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. 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: 800-672-0215 ///9/01