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Home My WebLink About10-6162Our File No.: 264735 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. CARMEN W GRACEY 34 ESSEX RD CAMP HILL, PA 17011 Defendant. tit trJf5?7p" r tj 1/' 7' COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - (W001 alvi ( -F em 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 4q8. oo PO A77Y e" aalY00 P,lt aqT 776 Our File No.: 264735 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. CARMEN W GRACEY 34 ESSEX RD CAMP HILL, PA 17011 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 CARMEN W GRACEY, an adult individual residing at 34 ESSEX RD CAMP HILL, PA 17011. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account # ending in 3686; 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 $1,933.72. 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 $1,933.72 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & S IATES, P.C. AM for P ' ntiff A Law Firm Eng ed i Debt Co cti01 BY: Dated: 9/16/2010 David J. Apo*?iaker, Esquire Our File No.: 264735 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: 9/16/2010 NORTH STAR CAPITAL ACQUISITION LLC CARMEN W GRACEY 34 ESSEX RD CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name Account Number: Original Creditor: Balance Due CARMEN W GRACEY ending in 3686 CAPITAL ONE $1,933.72 Our File No.: 264735 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ???+,1'<r ai 4uulbrtl???b F 11 D '.l r E ?. :l(} 4910 0 " - 7 f ?r3 10: North Star Capital Acquisition LLC Case Number vs. Carmen W. Gracey 2010-6162 SHERIFF'S RETURN OF SERVICE 10/01/2010 05:03 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 1, 2010 at 1703 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Carmen W. Gracey, by making known unto herself personally, at 34 Essex Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. i DENNIS RY, DEPOTYF SHERIFF COST: $41.50 October 05, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF {ci Gp,mtySuite 5herft. le,eoso?t- Irc Our File No.: 264735 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. CARMEN W GRACEY Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY ) NO. 10-6162 CIVILTERM ) ) PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER SSOCIATES, P.C. Atto ys or Plaintiff A Law Firm gag d in Debt Collection By: _ David J. A ker, Esquire -? 3 rnW X M r- ? N ?a i co PQ ?sJ