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Home My WebLink About09-5901 i` Our File No.: 218008 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. LISA M KING 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- sOd l &ia, i ?m 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.: 218008 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. LISA M KING 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS 1 CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is NORTH STAR CAPITAL ACQUISITION LLC c/o A.pothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are LISA M KING, an adult individual residing at 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account 437034463; 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 $1,037.95. 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 $1,037.95 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A O TES, P.C. Attorney f r Pl tiff A Law Firm Enga d in ebt Collection BY: it 1-11, - David J. Apo aker, Esquire Dated: 8/19/2009 Our File No.: 218008 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 orn f sification to authorities. David J. Apotha Attorney for DATE: 8/19/2009 NORTH STAR CAPITAL ACQUISITION LLC LISA M KING 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: LISA M KING Account Number: 37034463 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $1,037.95 Our File No.: 218008 EXHIBIT "A" PH F OF THE <'\C??Ap M 2004 AUG 27 PM 3: 32 Cutva ,Y ?// 4 ?j. ?-6 ?? l?C#? ly-7 & 0 1 Sheriffs Office of Cumberland County R Thomas Kline Sheriff itt„ of 4i, nbrrt ?4v ,?0 Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor OF 1Nc" P P,^iI,)TY 2009 SEP I I AN 8: 4 4 North Star Capital Acquisition LLC vs. Lisa M. King Case Nu ber 2009-501 SHERIFF'S RETURN OF SERVICE 09/04/2009 08:40 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 2040 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lisa M. King, by making known unto herself personally, at 549 Meadowcroft Circle Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 September 08, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Sheriff +t i Our File No.: 218008 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. LISA M KING Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, LISA M KING, in the default of an Answer, in the amount of $1,049.19 computed as follows: NO.: 09-5901 Civil Action Amount claimed in complaint: $ 1,037.95 Less: Amount Paid: ( 0.00) Plus: Interest from August 19, 2009 to October 30, 2009 at the legal interest rate of 6.00% per annum 11.24 Attorney fees 0.00 TOTAL /J $ 1,049.19 I certify that Defendant, LISA M KING, last kno((/ddress is 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055. David J. Apo`thaker, Esq. Attorney for Plaintiff Dated: October 30, 2009 1? :1 Our File No.: 218008 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. LISA M KING Defendant NO.: 09-5901 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 unswom falsification to authorities. Dated: October 30, 2009 Our File No.: 218008 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. LISA M KING Defendant 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 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defens our inquiry indicated that the Defendant(s) is/are not in t] David J. Apothaker, Esq. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5901 'enter has sent back 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. Depishoutof Delimse Maapovter Data Center Oct-30-2009€18:01:33 Military StaRus Report Ptrtumt to the 5enwe Wrbers M R Ace E Last TIrsNm" Baps Data Active Duty Status Active Duty Fad Dale Service Na>a* Atasry lt;`.G I?:1 \[ B• red Lr; the iri rrnarion tiou hale ?srni-teed, rbe T)%M i4a7.?i not v?>>;eis nai: vox w cm r4k=ng the MAMId t sum, U, die ithemifim data barns v€ the Depectmed o Defene Iki CY Data Cesker, based on tMe ilixtuation you proguled„ 6c above is the clam status oftrc in idLW as to 4 breacbes o t e L 'a d Sa *vs (Artery, NW-4y Marift Carps, Air Force, NOAA., Pubic Healda, and Coast [nand). Mary -Nt Saa%*-Dixon, Derector Department of Defense .. M er Data Caatdr IWOWhoaBh4Su'tA00 Arington, VA 2.2-2109-2-593 The Defense Manpower Dart Center (DWDC) is oat orpnih of#v Dqxguma rfDdme dw maktain the Nfew I nrohnert and' Reporting System (DEM) da sc vdach is the cal settee of data on clipl*y for aailtnry medical cart and Mier 66bility systems. The DoD strono supports the cafarccmeat of dw Smicar Members Civil.RrWA.ct (50 U'SC AM § § x01 at w% as amended) (SCRA) qty kno" as the Soles arad Smlx s' Cr l ReWAct of 1940). DMDC has lssted hundreds of&owAnds 'tomes possess any itficnwam iaxi wmg [brit individad a entreaty ca scive duty" r and bas experienced a use Mor rate. In thervert &a i d %id" referenced above, o Om fink Member, 6ierA or tepm r asserts ai any Mercer d w the indiviJual is on active tbs. of is othrr vvise m6ded to the protecdow oftie SCRA, you we *cm* rateouxged to obtain of the pet 3.s status by coatactiag dko persdai s Service via ate'defras LRL 'zcaiv m ta4las.At'C SI 3R Ifyou hMT C4ideud r the Person, is an active duty and ycufag to abed is ad&fiojW Service v rikstiior ; puckwe proms of the SCRA xnzy be kwoked agaion vent. See 50 L?SC App. §52I(c). yran obtain Wbcroation aunt llts pesetas (e,g., as SSN, inprm-e4 jwcm - y of17t B, a tattle amme), -)me can submit your request again at Ctrs Web site earl we R'a proem a eta ea aw for that quertr- This rents acti?a glary stattm' date the JxWW" was last on aciiv a di'ty, irk was vw*intbe preceding 367 am. for histor" idarmstirin, please contact the Sir 5CRA poets-cf=coetaet- tifom twauionon .deedAar?b°.iw " A,ctimm ,uty status as rid iu tee's ctxakate a deco edit accordw,: with I O USC § 101(d)(I) far a paaiad ofmore than 30 coesecoti+v ,darns, Is ilhe case cf a mew of ifte !Iadond Guard, iochidcs sett amder a cal to alive sen3ce to kodixed by the President or the. Secretary of Delimse for a period of more [hurt 34 m [tartar 32 USC § 50' 2((3 for putposes of responding to a zatiovA agcy deaaared by dwPresident and supported byFedeual fdraels. AX Ads Guard 11 esmv (ACR) members aunt be assigned against na w hoe zed moblizabon posbon, in the rust they support. Tears mgrs ;Navy TARS. Nlmve Carps ARs and Coast Gard [CPAs. A,`tn e Daly seahas also applies to aUnformed Service member who is an active duty ,rtutmi,simed officer of the US, kuL k Hca h Sawice or Ow'NatimW fart c aad Abnospheeic A4mi4straoion ('NOAA Couam sieved Cups) for a period o more tarn 30 consecutive d ay%. Corempr f'ndrr der SCRrt it Broad in Saar Carus On,crage under the SCRA is broader in some cases and kckwks some catescr es ofpe rsoos on active duty far paaposes of the SCRrt who wodd tart be reported as on. Activ=e Duty umder this cerEf"acate. Mean- Panes orders are aimeeciedE to extend the period ofaz t=e duty, whch wadd cdcad SCRA protections- Persons sag to re k. on *n websae ofttfic4ow sherd ebeck to make sort the orders on which SCRA protections are baud haw rat bees amended to vaeid 6e incilu ive dates of service. Frtttabe mme, sow pcottctiam of ore SCR tray exteadto peasoos who how recehvd orders to report far active dray or to be iodax t 4 but .; ho have not ectuagy began active d oty or airtudy reported for induction, 'flee Last Date on Adore Duty fttq n ` amportat becease a isaaber edprodecdiatxs of SCRA extend beyood die last dater of active d0y, Tl ow k$m wnold rely an this cerfficata are aagdrcl to seek 4oaffied leo counsel to en+swe 64 aft ri&t gnaaanteed to Senim s under the SCRA are protected NN ARN-LNG: 'ills certfitate was providedbased o n a aurae and SSN grnvi&d by tlse regwAaa. Prmv&* an tnmeaas name of SS:'? Will cause an crrotaeoats cert&ate to be Provitfed- ReportaAMA6 F 4 218008 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) LISA M KING ) NO. 09-5901 To: LISA M KING 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 29, 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 A ID J. APOTHAKER, ESQUIRE AP THAKER & 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 1 iL[_l.f ?.i f UE T r " -kf?Y 2009 s1tiOV 10 L' 'C',? r _ 414-co Pa Az N CIL^" ! s 83Co d .1am8 ?J? "" OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: LISA M KING 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055 NORTH STAR CAPITAL ACQUISITION LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. LISA M KING Defendant NOTICE NO.: 09-5901 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 II/,ojol