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Home My WebLink About05-4416 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff No: DS - AlA/I/o {}; <.) ~ L 'j- O-h] vs. COMPLAINT IN CIVIL ACTION SHARON SANDERSON Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04323007 C A pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff vs. Civil Action No SHARON SANDERSON Defendant COMPLAINT AND NOTICE TO DEFEND 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 an 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, NORTHSTAR CAPITAL ACQ LLC is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: SHARON SANDERSON 668 STATE ST LEMOYNE, PA 17043 3. Defendant applied for and received a credit card bearing the account number 5181890003816257 . 4. Defendant made use of said credit card and has a current balance due of $1475.49 , as of August 15, 2005 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000% per annum on the unpaid balance from August 15, 2005 . A copy of Plaintiff's Statement of Acco unt is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , SHARON SANDERSON , individually , in the amount of $1475.49 with continuing interest thereon at the rate of 6.000% per annum from August 15, 2005 plus costs. This law firm is a debt collector empting to collect this debt for our client and any information obtained will be used for that purpose. CO., L.P.A. 2718 North Star Capital Acquisitions, LLC Please indicate Name, or address ',--\ -=,,)./. "':)CD=t Telephone Changes Home ( ) Work ( ) ACCOUNT NUMBER PAYMENT PAST DUE MINIMUM NEW AMOUNNT OF DUE DATE AMOUNT PAYMENT BALANCE PAYMENT ENCLOSED 5181 8900 0381 6257 04/02/2003 1125.41 498.93 1212.17 $ SHARON SANDERSON 3119 RITNER HWY NEWVILLE PA 17241-9582 1...11.,,11I...1.1,,"...1..1.1..11...11...1.11I.....11.1...11 220 JOHN GLENN DRIVE SUITE ONE AMHERST NY 14228 1...111.1..1,,1.1,,1..11...1.1..11...1.1...11..1.1...11..,,11I ACCOUNT NUMBER CREDIT CREDIT DAYS IN BILL PAYMENT MINIMUM UNE A V AUABLE BILUNG CYCLE DATE DUE DATE PAYMENT DUE 5181 8900 0381 6257 800.00 32 03/18/2003 04/02/2003 498.93 DATE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0318 0318 OVERUMlT FEE 29.00 0000 0000 LATE OlARGE-11INPYMTNOTRECDBYDATE 35.00 - FINANCE GIARGE CURRENT PURQ-IASE 22.76 PREVIOUS NEW PURCHASES DEBIT FINANCE OVERUNE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSTMENTS CHARGES AMOUNT BALANCE 1125.41 .00 .00 .00 64,00 86.76 412,17 1212,17 AN AMOUNT FOLLOWED BY A MINUS SIGN ( -) IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED $ TYPES OF CREDIT TO FINANCE DAYLY NOMINAL ANNUAL ANNUAL WHICH RATES APPLY CHARGE BALANCES PERIODlC RATE PERCENTAGE RATES PERCENTAGE RATES PURCHASES 1125.41 .06299 % 22.99 % 22.99 % ADVANCES .06299 % 22.99 % % YOU MAY AVOlD ADDITIONAL FINANCE CHARGES ON PURCHASES IF YOU PAY TIllS AMOUNT BY THE DUE DATE QUESTIONS about account? Credit Card lost or stolen? CalI Customer Service 24 hours a day 7 days a week, toll. free at 1-800-2774131 . Para Servicio al Cliente en espanol: 1~800-2774431 EXHIBIT ''It, VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A.C.S. 94904 relating to unsworn falsifications to authorities, that he/she is fYI {. L bell "to .. e j(u. r?/ (J. ~ \/ .11 fl,_,ll (Name) I of !,!odl.flw '!"f,r" A~,) Lt-'. , plaintiff herein, that (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best ofhisfher knowledge, information and belief. /U Ii. (S;_re) 1 L- WWR# 01../32. 3D\) 7 p F\l '- - ~ s. ~ ~ 'f-.! ,-. - ()J-...r: -'0.. l.I'\ lI"\ V\. \J -u r }- o ( ....' c'2, ~p ........,.. "c-: (p l".' ,9 ':~ -c.""'\"\ rn'r: ~~ \3 ~~l ';.;.:.:. ~(? <~~ ~...,) r0 SHERIFF'S RETURN - REGULAR CASE NO: 2005-04416 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH STAR CAPITAL ACQ LLC VS ANDERSON SHARON S CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ANDERSON SHARON S the DEFENDANT , at 1812:00 HOURS, on the 30th day of Auqust 2005 at 668 STATE STREET LEMOYNE, PA 17043 by handing to SHARON SANDERSON a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 12.80 .00 10.00 .00 40.80 ~~;e;-6'^c A'~/ R. Thomas Kline 08/31/2005 WETLMAN WEINBERG REIS Sworn and Subscribed to before me this )?J day of ~f~~ AD ~ P nota By: ~ - tJ . .~-v/ , I Depjty Sheri f . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITIONS, LLC Plaintiff No. 05-4416 Ys. PRAECIPE FOR DEFAULT JUDGMENT SHARON SANDERSON Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA 1.0,#47437 Weltman, Weinberg & Reis Co" L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04323007 Judgment Amount $ 1.486.65 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION NORTHST AR CAPITAL ACQUISITIONS. LLC Plaintiff vs. Civil Action No. 05-4416 SHARON SANDERSON Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, SHARON S ANDERSON above named, in the default of an Answer, in the amount of$I,486.65 computed as follows: Amount claimed in Complaint $1,475.49 Interest from August 15,2005 to October 10,2005 at the legal interest rate of 6% per annum $11.16 TOTAL $1,486.65 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with P A R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: j'0iL,J;~~ WILLIAM T. MOLCZ~&ESQUIRE PA I.D.#47437 '/ Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04323007 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P,A., 2718 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 668 STATE ST LEMOYNE,PA 17043 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHST AR CAPITAL ACQ LLC Plaintiff 05-4416-CIVIL SHARON SANDERSON Defendant IMPORTANT NOTICE TO: SHARON SANDERSON 668 STATE ST LEMOYNE,PA 17043 Date of Notice~p }-11 fl ! lLYtl(S 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION NORTHST AR CAPITAL ACQUISITIONS, LLC Case no: 05-4416 Plaintiff NON-MILITARY AFFIDAVIT vs. SHARON SANDERSON Detendant The undersigned, who tirst being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.s.C. App. ~ 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, SHARON S ANDERSON is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (OM DC), which states that the Defendant. SHARON S ANDERSON is not in the military service. Further Affiant sayeth naught. NOT PUBLI . , (I '_ /i ',./L- .'1/ .... AFFIANT / BSCR~Y ,"""re<h;'f;.., Notaf\8.l N~~ PUblIC Werdy l. Ga~\~e"l' Cou"'y CilIJ Ol PitlSburgll~JU\oi 15.2005 1I/iIJ~ :-::~OI-' .--Joo.~_ ~~'r_~ - SWORN of This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. c:: ~ P J.Q.. 7'\1:. ....{) 1- 0- Cr r-."' ~ '\) , - -cJ eXI ,; -:. ?-.> c.'.' ~ D 6""' ~ -. 1,1 <::>. - r ,: \\.l " "'Q _.v. - ---.:;, ~ f ~ ~ - . _.-- -- (,..", (. ' -------"------~------- Request for Military Status Page I of I Department of Defense Manpower Data Center OCT-IO-200505:51:27 Military Status Report Pursuant to the Service Members' Civil Relief Act -< Last Name First/Middle Begin Date Active Duty Status Service/Agency ANDERSON Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. ~w~~~ Robert 1. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx, SS 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouraged to contact us by Fax at (703-696-4156) or by phone at (703-696-6762). We will then conduct further research, Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: http://www.dcfenselink.mil/faq/pis/PC09SlJ2R.html. Report ID:PUQFMIKBAO https ://www.dmdc.osd.mil/scralowalscra.prc _Select 10/10/2005 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHST AR CAPITAL ACQUISITIONS, LLC Plaintiff vs. Civil Action No. 05-4416 SHARON SANDERSON Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on --C2c....+ 'dJ) J...coS \ (xx) Assumpsit Judgment in the amount of$I,486.65 plus costs. () Trespass Judgment in the amount of$~ plus costs. () Ifnot satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of () Court Order () Non-Pros () Confession (xx) Default () Verdict () Arbitration A ward Prothonotary By: PROT SHARON SANDERSON 668 STATE ST LEMOYNE,PA 17043 Plaintiff's address is: c/o Weitman, Weinberg & Reis Co" L.P.A., 2718 Koppers Building, 436 7'" Avenue, Pittsburgh, PA 15219 1-888-434-0085 " , --.1 "'-. ~. ---C'\ , --------