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Home My WebLink About10-6302Our File No.: 270570 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. DONALD P KEENER 1615 MARKET ST CAMP HILL, PA 17011-4843 Defendant. F I L ED-OFFICE CF Tr4c F M T = tONOTARY 2010OGT -4 PM 2: G6, UMb-ERLA,ND COD NTY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: IU - Ust)a 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 0D 94j? 56 ` Our File No.: 270570 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. DONALD P KEENER 1615 MARKET ST CAMP HILL, PA 17011-4843 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 DONALD P KEENER, an adult individual residing at 1615 MARKET ST CAMP HILL, PA 17011-4843. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account # ending in 9587; 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 $5,412.03. 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 $5,412.03 and requests this Court award costs to the extent permitted by applicable law. & ASSOCIATES, P.C. A Law Firm En d in D t Collection BY: David J. Apothaker, Esquire Dated: 9/29/2010 Our File No.: 270570 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 uns orr falsification to authorities. David J. Apothaker, Attorney for Plai DATE: 9/29/2010 NORTH STAR CAPITAL ACQUISITION LLC DONALD P KEENER 1615 MARKET ST CAMP HILL, PA 17011-4843 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: DONALD P KEENER ending in 9587 WELLS FARGO FINANCIAL $5,412.03 Our File No.: 270570 EXHIBIT "A" 270570 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: DONALD P KEENER Serve Upon: DONALD P KEENER Address for Service: 1615 MARKET ST CAMP HILL, PA 17011-4843 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge O Deputize O Certified Mail O 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 ~,~titt~ U'C ~~rrtrGrr~~~i Jody S Smith ~ Chief Deputy ~ ~ = ~,, a. Richard W Stewart SOIICltOr Q!F~~CE GF'k~ crERiF~ North Star Capital Acquisition LLC vs. Donald P. Keener Case Number 2010-6302 SHERIFF'S RETURN OF SERVICE 10/18/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Donald P. Keener, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Donald P. Keener. Request for service at 1615 Market Street, Camp Hill, PA 17011 is no longer being occupied by Donald P. Keener. The Camp Hill Postmaster has confirmed Donald P. Keener is not known at 1615 Market Street, Camp Hill, PA 17011. SHERIFF COST: $46.50 October 18, 2010 SO ANSWERS, c~%~--~. RON R ANDERSON, SHERIFF ~.,., ~-~ - ~ ~ ~ --4 ~~ ~ v~.s'~ r-- --+ ~ r ~rT~ ~ -v ~ ~ ~~~ c.? ~r r --~ ~ ~' _.~; (ci CouniySuite ShFnff, Telecsott. 1+~c. Our File No.: 270570 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 FILED-OFFICE ' THE PROTHONO EAIM( 2010 DEC - 3 AN I I: 2 C CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NO. 10-6302 DONALD P KEENER Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & RTES, P.C. A Law Firm By: David J. Dated: 11/24/2010 IIIIIIIIIIIIIIII Debt Collection