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Home My WebLink About10-6304a Our File No.: 270721 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. RODNEY KRINER 607 S MOUNTAIN ESTATES RD SHIPPENSBURG, PA 17257 Defendant. FILE-D-0FF ICF 2010 OCT -4 Pill 2: 22 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 10 - U -2167 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 b c Our File No.: 270721 • APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothak?r, Esqiiire 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. ) RODNEY KRINER ) 607 S MOUNTAIN ESTATES RD ) SHIPPENSBURG, PA 17257 ) 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 RODNEY KRINER, an adult individual residing at 607 S MOUNTAIN ESTATES RD SHIPPENSBURG, PA 17257. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account # ending in 5399; 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 $6,040.15. 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 $6,040.15 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A O TES, P.C. Attorney Zi r Pl 'tiff A Law Firm Engag in A t BY: David J Dated: 9/29/2010 , Esquire Our File No.: 270721 i VERIFICATION David J. Anothaker 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 u?. worn falsification to authorities. David J. Apothaker",*?Esgi Attorney for Plaintiff DATE: 9/29/2010 ? A NORTH STAR CAPITAL ACQUISITION LLC RODNEY KRINER 607 S MOUNTAIN ESTATES RD SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: RODNEY KRINER Account Number: ending in 5399 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $6,040.15 Our File No.: 270721 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor fat»?tv o4 ?utnGrr????4 oFZ:??, -,;7 -HE r 'A U p, r" I North Star Capital Acquisition LLC vs. Rodney Kriner Case Number 2010-6304 SHERIFF'S RETURN OF SERVICE 10/07/2010 04:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 7 2010 at 1630 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Rodney Kriner, by making known unto himself personally, at JLG, 582 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 October 08, 2010 ROBE T BITNER, DEPUTY SO ANSWERS, t?4 RON R ANDERSON, SHERIFF Ci CoUntySuite S`enff, teleosofl. inc. 4 r Our File No.: 270721 APOTHAKER & ASSC By: David J. Apothaker Attorney I.D.# 38423 FILED-OFFICE OF THE PROTHONOTARY ?CIATES, P.C010 NOV 30 PM 2: 41 CU PENN5 YLDVAN A TY 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff } NORTH STAR CAPITAL ACQUISITION ) LLC ) Plaintiff ) VS. ) RODNEY KRINER ) Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6304 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, RODNEY KRINER, in the default of an Answer, in the amount of $6,040.15 computed as follows: Amount claimed in complaint: Less: Amount Paid: Plus: Interest from September 29, 2010 to November 17, 2010 at the legal interest rate of 0.00% per annum Attorney fees TOTAL I certify that Defendant, RODNEY KRINER, ESTATES RD SHIPPENSBURG, PA 17257. Dated: November 17, 2010 David J. Apothaker, Esq. Attorney for Plaintiff $ 6,040.15 { 0.00) 0.00 0.00 $ 6,040.15 is 607 S MOUNTAIN tom'';ejqo? Our File No.: 270721 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. RODNEY KRINER Defendant NO.: 10-6304 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 unworn falsification to authorities. Dated: November 17, 2010 Attorney for Plaintiff Our File No.: 270721 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. RODNEY KRINER Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6304 Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND 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 607 S MOUNTAIN ESTATES RD SHIPPENSBURG, PA 17257. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209f 3, if the Defen t(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the De our inquiry indicated that the Defendant(s) is/are not Data Center has sent back David J. Apothaker, Esq. Attorney for Plaintiff 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. 13q?amm?e of'Defenle ?KaapovaoY Daps Curter to the KMER ( RODNEY ldadbers CM RAdAct oa Ate isfteatlass yva bme fizaid d diel ? die' 9 . UPW sean3ir[ is Adwolioa drabsaics 4(t6e DqwMag d dAimse Ma Pura DdaCemm bared as dw i*rnam *a 7M Pfd lie share is Me caveat alas of tie irrividud ar to A breacies of tie t.la kuadSwim 0 my, Nsry, Maine Caps, Ai Feeer, NOAA. 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Tbase world rein err dSr aersitirsae are sled to apeelc gtsslRed beRSl twaasd to rasrste that a1 tuts dsrrtrssseed to Service ¦ ea6us"datMteSCAR wepnoasrled WARM iQ 'fib's+oerlM&OW vas par?iied based an *Now mad UN provided by tic regw0ec Ftavidog an aavoie - same, or SM %* CVw ere eet+seoas deadiale b be prwidevi Kf0ma-wmanla 270721 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) RODNEY KRINER ) NO. 10-6304 } To: RODNEY KRINER 607 S MOUNTAIN ESTATES RD SHIPPENSBURG, PA 17257 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 ASSOCIATION 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3166 BAR S DAVID J. APO R, ESQUIRE APOTHAKER & 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 Date: November 01, 2010