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Home My WebLink About10-6301Our File No.: 264168 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. MARIANNA SEDLAK 41 PRICKLY PEAR DR CARLISLE, PA 17013 Defendant. FIL' D-OFFICE OF THE-- 1PROTHO NOTA€ Y 2010 OCT -4 P 2'. CL CUMBERLAND COUNTY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. )D (per l 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 D ???au s ?e Our File No.: 264168 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. ) MARIANNA SEDLAK ) 41 PRICKLY PEAR DR ) CARLISLE, PA 17013 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: J6- 6 3O ? Cvl-" 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 MARIANNA SEDLAK, an adult individual residing at 41 PRICKLY PEAR DR CARLISLE, PA 17013. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account # ending in 2347; and said account was issued to Defendant(s) by SALUTE/VISA, 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 $972.24. 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 $972.24 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & SO IATES, P.C. Attorney r Pl ntiff ?, A Law Firm Engag d in ebt Colkctim BY: David J. ApothaKT, Esquire Dated: 9/29/2010 Our File No.: 264168 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 unworn falsification to authorities. David J. Apo er, Esquire Attorney r Plaintiff DATE: 9/29/2010 NORTH STAR CAPITAL ACQUISITION LLC MARIANNA SEDLAK 41 PRICKLY PEAR DR CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: MARIANNA SEDLAK Account Number: ending in 2347 Original Creditor: SALUTENISA Balance Due: $972.24 Our File No.: 264168 EXHIBIT "A" *= 264168 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 Plaintiffs: Court Number: NORTH STAR CAPITAL Expiration Date: ACQUISITION LLC Type of Action: Civil Action Defendant/s: MARIANNA SEDLAK Serve Upon: MARIANNA SEDLAK Address for Service: 41 PRICKLY PEAR DR 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 Jody S Smith Chief Deputy ?4??tp o1 ?:u{rtGr?f??i 4 M i "I btu ',i; tCj ILI rT 12 P,'- 8: Fr Richard W Stewart Solicitor North Star Capital Acquisition LLC vs. Marianna Sedlak OFF,C€ „rF' o .-5P{FF C 1 j `i ? 9ii11) (,QU,`pN L. Sl t.' { u!V! 3'4 Case Number 2010-6301 SHERIFF'S RETURN OF SERVICE 10/07/2010 08:35 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 7 2010 at 2035 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Marianna Sedlak, by making known unto herself personally, at 41 Prickly Pear Drive, 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. SHERIFF COST: $33.40 October 08, 2010 ROB RT 81TNER, DEPUTY I SO ANSWERS, RON R ANDERSON, SHERIFF (c) COUni`,'SWIe Sheriff. Teleosoft . Inc. j ~I~.~Q~~Ji~ ~~~~. Ala ~'Ei~ PAC i ~fr~~~`I,~~t°'a, 2Df~~CT fly ~~~~9~ ~I ~'~hlNSYL~',~P~~~ Matthew R. Cover, Esquire COVER PERRY E~ SHORE 2411 North Front Street Harrisburg, PA 17110 717/232-9900 mgover@g pslawgrm.com NORTH STAR CAPITAL ACQUISITION LLC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. MARIANNA SEDLAK NO. 10-6301 CIVIL ACTION -LAW PRAECIPE FOR ENTRY OF APPEARANCE TO The PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, MARIANNA SEDLAK, with regard to the above-captioned matter. Respectfully submitted, l ~ ~ Z /a Date: COVER PERRY & SHORE By: Matth R. over, Esquire I.D. No. 47593 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this t day of October, 2010, I hereby certify that I have served the foregoing PRAEGIPE FOR ENTRY OF APPEARANCE on the following via first class mail, postage prepaid, addressed as follows: David J. Apothaker, Esquire APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C 306 Mount Laurel, NJ 08054 tthew . Gover, Esquire Matthew R. Gover, Esquire GOVER PERRY 8~ SHORE 2411 North Front Street Harrisburg, pA 17110 7171232-9900 mgover@gpslawfirm.com NORTH STAR CAPITAL ACQUISITLON LLC VS. MARIANNA SEDLAK ,;: N,, :..;. ~ . ~`t~.FD-OFF~C~ .: ~~iO~C! i9 p~-; !~ I?~t ~'9~1~i~~E~L~C3 ~~d+~~„ ~El'~lt~i~'~l..'~" ~~3 ". IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6301 CIVIL ACTION -LAW ANSWER TO COMPLAINT 1. Admitted. 2. Admitted. 3. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted. Proof is demanded at trial. 4. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted. Proof is demanded at trial. 5. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted. Proof is demanded at trial. 6. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted. Proof is demanded at trial. 7. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted. Proof is demanded at trial. WHEREFORE, Defendant would respectfully request this matter dismissed with costs. Respectfully submitted, GOVER PERRY & SHORE By ar/ Matthew R. Go er, Esquire Attorney I.D. No. 47593 2411 North Front Street Harrisburg, PA 17110 Date: ~~ ~ (717) 232-9900 VERIFICATION I, MARIANNA SEDLAK, verify .that the statements made in the foregoing ANSWER TO COMPLAINT are true and correct. I understand that false statements herein are made subject to the penalties ofi 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: fd l j O CERTIFICATE OF SERVICE AND NOW, this_~day of October, 2010, I hereby certify that I have served the foregoing ANSWER TO COMPLAINT on the following via first class mail, postage prepaid, addressed as follows: David J. Apothaker, Esquire APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C 306 Mount Laurel, NJ 08054 Matthew R. Gover, Esquire Our File No.: 264168 NORTH STAR CAPITAL ACQUISITION ) LLC ) Plaintiff ) VS. ) ORDER OF COURT MARIANNA SEDLAK ) c 1 Defendant ) o rnco PRAECIPE FOR APPOINTMENT OF ARBITRATORS ' .wJry TO THE HONORABLE, THE JUDGES OF SAID COURT: Tr c7 ? C Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfully r?p*rAenWhat; 1. The above-captioned action is at issue -c co - "' 0) 2. The claim of Plaintiff in the action is $972.24. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff 2411 N. FRONT ST. Benjamin J. Cavallaro, Esquire HARRISBURG, PA 17110 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. March 2, 2011 and as prayed for. V ?`tt t4?s?,:iC kJ z _2 :J 13en,Jaw?,r T Cc?vallaro, ?s?° P1a44ke 0 ? 6o v cr Civil Action quire pll- eta q. ev shy C/I,# t'q U10 An't,75u3w, , 20// , in consideration of the foregoing petition, Esq., and LA44QV Esq., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 10-6301 Esq., are appointed arbitrators in the above captioned action By the Court, eOp,es h+a.'Ied 31'3'111 jest NORTH STAR CAPITAL IN THE COURT OF COMMON PLEAS OF ACQUISITION, LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW rrnm C_ =-n vs. NO. 10-6301 CIVIL _j m rn C:?c MARIANNA SEDLAK, : Defendant "-' ORDER AND NOW, this day of June, 2011, the appointment of a Board of Arbitrators in the above-captioned case is VACATED. Philip Briganti, Esquire, Chairman, shall be paid the sum of $50.00. BY THE COURT, Lao 4'X1ce off' Ph;1, p C. 1.3r,p.? t; ? Philip Briganti, Esquire 7y (,,' • #0,0m rrc?- S4-. *'? /0.3/7 6arl,sle Ply /70 3 Court Administrator :rlm &6 Ma .1 ew 6110111 4641- . 4 a a Our File No.: 264168 APOTHAKER & ASSOCIATES, P.C. BY: Kimberly F. Scian, Esquire Attorney I.D.# 55140 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff NORTH STAR CAPITAL ACQUISITION LLC Plaintiff, vs. MARIANNA SEDLAK Defendant. v ? 1LL T lid 20 i I JUN 16 PM 2* 2 ` CUMBERLAND CCU PENNSYLVAN COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-6301 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection By: Kimberl F. V-San, Esquire I Dated: June 3, 2011 11111111111111111111111