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HomeMy WebLinkAbout10-6306 Our File No.: 270677 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. JOHN W ROBERTSON 37 W HIGH ST APT 1 CARLISLE, PA 17013 Defendant. Ef' 0-OFFICE Dr- TIDE oTI'n*tg0TARY 20 10 0"T - 4 P'l 2= 2 S "e ME"ER{ AND COUNT` C1 .,.,r, ' ,Jant I? pR? 1 ! E i - COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I() - 1990 (P 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 a0 s 3 a Our File No.: 27067' APOTHAKER & ASSOCIATES, P.C. BY: David J. Apoth'aker, 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. JOHN W ROBERTSON 37 W HIGH ST APT 1 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 JOHN W ROBERTSON, an adult individual residing at 37 W HIGH ST APT 1 CARLISLE, PA 17013. 3. Plaintiff, NORTH STAR CAPITAL ACQUISITION LLC, is the Assignee and Successor in Interest of Account # ending in 2248; 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 $3,793.55. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". J 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 $3,793.55 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSIOCIATES, P.C. A Law Firm EnRaked In Debt BY: David J. Apo aker, Esquire Dated: 9/29/2010 Our File No.: 270677 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 tq.tinsworn falsification to authorities. David J. Apot , Esquire Attorney for lamtiff DATE: 9/29/2010 NORTH STAR CAPITAL ACQUISITION LLC JOHN W ROBERTSON 37 W HIGH ST APT 1 CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: JOHN W ROBERTSON Account Number: ending in 2248 Original Creditor: WELLS FARGO FINANCIAL Balance Due: $3,793.55 Our File No.: 270677 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sher-ff Jody S Smith Chief Deputy Richard W Stewart Solicitor North Star Capital Acquisition LLC vs. John W. Robertson ~a~,~,sr at i~tr~~6~~rr~~~ ,,_ ~ ~ . ~~ t?Ff i~E ,'F ' i :r ~ERtFF FILED'©FFiCir GF THI~ pR~3TN01~i~~A~Y ~OIQ 4CT 1 ~ PM IZ` ~~ ~i~ ~~ ~ S ~~ ~{~~1 ~`~ Case Number 2010-6306 SHERIFF'S RETURN OF SERVICE 10/12/2010 05:55 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 12, 2010 at 1755 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: John W. Robertson, by making known unto himself personally, at 37 W. High Street, Apartment 1, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. AW GU ALL, DEP SHERIFF COST: $33.40 October 13, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj CountySuite Sheriff. Te~easoft. lnc. Our File No.: 270677 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 FtLED,-OFFICE OF THE PROTHONOTAR t 2010 NOV 30 PM 3: 19 CUMBERLAND COUNTY PENNSYLVANIA NORTH STAR CAPITAL ACQUISITION LLC Plaintiff VS. JOHN W ROBERTSON Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6306 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JOHN W ROBERTSON, in the default of an Answer, in the amount of $3,793.55 computed as follows: Amount claimed in complaint: $ 3,793.55 Less: Amount Paid: ( 0.00) Plus: Interest from September 29, 2010 to November 19, 2010 0.00 at the legal interest rate of 0.00% per annum Attorney fees 0.00 TOTAL 3,793.55 I certify that Defendant, JOHN W ROBERTS , l t kno address is 37 W HIGH ST APT 1 CARLISLE, PA 17013. David J. Apo aker, Esq. Attorney for Plaintiff Dated: November 19, 2010 -DD aOn a ?,,1 erJ Our File No.: 270677 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. JOHN W ROBERTSON Defendant 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 unsworn falsification to authorities. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6306 S.A. §4904, relating to David J. Apothaker, Esq. Attorney for Plaintiff Dated: November 19, 2010 Our File No.: 270677 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. JOHN W ROBERTSON Defendant NO.: 10-6306 Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS. 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 37 W HIGH ST APT 1 CARLISLE, PA 17013. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-25 , if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defe se anpo r Data Center has sent back our inquiry indicated that the Defendant(s) is/are not i the ilit David J. Apotha- ker, 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. Deprenerrt of Ddew Mampower Doti Center la buy Subw Report Parswut to the Senke M nbers Cavii Reikf Act r ? 1Lmrk ? ? fyMr Dora... Adis. ?' ROBERTSON JOHNW Dowd onte uatowuoayouhave Arr indicating der individual slat=. Nov 19-2414 063633 ,? "4v""r' {e? arrw noon - x A due MAX does act possess my iaforraarioo Upon sea dried fe irforaa", data boors dose Depareoeet of Delmore Manpower Due Center. based or be iakoin Pion flat you provided, the above is be mm slams of foe indwAad as to al broacbes of the Vaformed Savaces (Amer, Navvy, Marine Cow, A; Forte, NOAA, Pubic H oW and Gout Guard). Allory M. 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Report U"M7V6NR468 270677 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY NORTH STAR CAPITAL ACQUISITION LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) JOHN W ROBERTSON ) NO. 10-6306 To: JOHN W ROBERTSON 37 W HIGH ST APT 1 CARLISLE, PA 17013 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. A T AKER, 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 04, 2010