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HomeMy WebLinkAbout10-6040Our File No.: 264254 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC 170 NORTH POINTE PKWY AMHERST, NY 14228 Plaintiff, vs. JEROME D EVANS 326 JUNIPER ST CARLISLE, PA 17013 Defendant. I IED-O FIVE OF THE PROTHONOTARY 2010 cco 20 PM 12:2; CUMBERLAND, COUNT'f YLVlAUI A. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: /b -V-Y-16 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 jam' aye so Our File No.: 264254 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC 170 NORTH POINTE PKWY AMHERST, NY 14228 Plaintiff, VS. JEROME D EVANS 326 JUNIPER ST CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is NORTH STAR CAPITAL ACQUISITION LLC, 170 NORTH POINTE PKWY, AMHERST, NY 14228. 2. Defendant(s) is/are JEROME D EVANS, an adult individual residing at 326 JUNIPER ST CARLISLE, PA 17013. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account # ending in 7080; and said account was issued to Defendant(s) by CAPITAL ONE, 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 $931.20. 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 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 $931.20 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS OC TES, P.C. Attorney fo Plai tiff A Law Firm Engage in ebt Collection Dated: 9/9/2010 BY: David J. Apothkcer, Esquire Our File No.: 264254 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 relatipfto ?nsworn falsification to authorities. David ? Apothaker, Esquire Attorney for Plaintiff DATE: 9/9/2010 NORTH STAR CAPITAL ACQUISITION LLC JEROME D EVANS 326 JUNIPER ST CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: JEROME D EVANS Account Number: ending in 7080 Original Creditor: CAPITAL ONE Balance Due: $931.20 Our File No.: 264254 EXHIBIT "A" 264254 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: JEROME D EVANS Serve Upon: JEROME D EVANS Address for Service: 326 JUNIPER ST CARLISLE, PA 17013 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~a~;rttti, of ~rlirrl~~,f~~~~ Jody S Smith Chief Deputy Richard W Stewart Solicitor ~r~ .~ -_r ~~ w~~.,l~~ North Star Capital Acquisition LLC Case Number vs. Jerome D. Evans 2010-6040 SHERIFF'S RETURN OF SERVICE 09/27/2010 08:59 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 27, 2010 at 2059 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jerome D. Evans, by making known unto herself personally, at 326 Juniper Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. ~-f~ , NOAH CLINE, DEPUTY SHERIFF COST: $49.40 September 28, 2010 SO ANSWERS, ~/~ RON R ANDERSON, SHERIFF c~` ~ H3 ~ - .. -~ _ .,...{ ~ ''.ate (~~ ~ ~ 'T' JJ ~~ ~ i ~ ~~~ ~„ C-" F ~ i~ 1 - r~ t~ ~ ~ 3 °~ : ~ C..? ~ ~ r~ ~ ~.7 .~r~ t.~~ (c GburdySulte Sher~4f. Te~.eosotk_ lr--.. Our File No.: 264254 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. JEROME D EVANS Defendant. OF THE PROTHONOTARY 2011 J"'! t;. 04 CUmBr- ;i??? QTY t . '' A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-6040 CIVILTERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys fo tiff A Law Firm Enizaged in D bt Collection By: David J. Apothak r, Dated: 1/6/2011 IIHIIIIIHIMIIIII