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Home My WebLink About05-4620 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff No: O!;' - IIQo C;u~l 'I-8L\ vs. COMPLAINT IN CIVIL ACTION JASON S FAHNESTOCK 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 04457440 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff vs, Ci viI Action No 0 ~- '11.,LD JASON S FAHNESTOCK 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: JASON S FAHNESTOCK 337 OLD STATE RD GARDNERS, PA 17324 3. Defendant applied for and received a credit card bearing the account number 4791060410563943 . 4. Defendant made use of said credit card and has a current balance due of $1797,51 , as of August 26, 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 of Plaintiff's Statement of Acco unt is attached hereto, marked as 6,000% per annum on the unpaid balance from August 26, 2005 , A copy 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 , JASON S FAHNESTOCK , individually , in the amount of $1797,51 with continuing interest thereon at the rate of 6,000% per annum from August 26, 2005 plus costs, 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, 7 Warmbrodt,42524 , WEINBERG & REIS CO" L,P,A, venth Avenue, Suite 2718 urgh, PA 15219 434-7955 412-338-7130 457440 C A Pit KMJ North Star Capital Acquisitions, LLC Please indicate Name, or address Telephone Changes Home ( ) Work ( ) Charge-Off Statement ACCOUNT NUMBER PAYMENT PASfDUE MINIMUM NEW AMOUNT OF DUE DATE AMOUNT PAYMENT BALANCE PAYMENT ENCLOSED 4791 0604 1056 3943 09/26/2002 1344,90 494.10 1419.50 $ JASON FAHNESTOCK 337 OLD STATE RD GARDNERS PA 17324 220 JOHN GLENN DRIVE SUITE ONE AMHERST NY 14228 ACCOUNT NUMBER CREDIT CREDIT DAYS IN BILL PAYMENT MINIMUM LINE A V AlLABLE BILLING CYCLE DATE DUE DAn: PAYMENT DUE 4791 0604 1056 3943 1000.00 32 09/11/2002 09/26/2002 494.10 DA IE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0911 0911 OVER LIMIT FEE 29,00 0000 0000 LATE CHARGE - MIN PYMT NOT REeD BY DATE 35.00 ...... FINANCE CHARGE CURRENT PURCHASE 10.60 PREVIOUS NEW PURCHASES DEBIT FINANCE OVER LINE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSTMENTS CHARGES AMOUNT BALANCE 1344.90 .00 .00 .00 64.00 74.60 419.50 1419.50 AN AMOUNT FOLLOWED BY A MINUS SIGN(-) IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED $ TYPES OF CREDIT TO FINANCE DAILY NOMINAL ANNUAL ANNUAL WHICH RATES APPLY CHARGE BA LANCES PERIODIC RATE PERCENTAGE RATES PERCENTAGE RATES PURCHASES 1344.90 .02465 % 9.00% 9,00% ADVANCES .06299% 22.99% % YOU MAY AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES IF YOU PAY THIS AMOUNT BY THE DUE DATE QUESTIONS about account? Credit Card lost or stolen? Call Customer Service 24 hours a day 7 days a week, toll- free at 1-800-277-4431. Para Servicio al Cliente en espanol: 1-800-277-4431 EXHIBIT 1 VERIFICA nON The undersigned does hereby verity subject to the penalties of 18 P A,C,S, 94904 relating to unsworn falsifications to authorities, that he/she is Nil C ~ni..) -e )(q~Jvn ' (Name) / of ;\Jovt/.h 5j..e...y' Cq/i...,..J Act. ' plaintiff herein, that (Company) I--L. 0 ~Y1+ (Title) 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 ofhislher knowledge, information and belief. (Signature) WWR# tJl/lIfj7 Wo p p iA ~ 1t if) 0 "- ~ i'- 0 "v C) rn --:[ (;..J -0 ~ ~ n ",' 0 p-: ~" .'.~~;:, -.:..n ~ 0) ~' I ~, I ~ _-l -~~ -"... (.) b o -n -l T ~~il ~-r:-~ ,','1 C' ,-,) .,.\ ::T.'" :2( SHERIFF'S RETURN - REGULAR CASE NO: 2005-04620 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTHSTAR CAPITAL ACQ LLC VS FAHNESTOCK JASON S KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FAHNESTOCK JASON S the DEFENDANT , at 1748:00 HOURS, on the 8th day of September, 2005 at 4347 CARLISLE ROAD GARDNERS, PA 17324 by handing to JASON FAHNESTOCK a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18,00 8,80 ,00 10,00 ,00 36,80 .~ /""~ ,...' .".,~ R, Thomas Kline 09/09/2005 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: /~4ft l& day of me this A,D, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH STAR CAPITAL ACQ LLC Plaintiff No, 05-4620 CIVIL TERM VS, PRAECIPE FOR DEFAULT JUDGMENT JASON S FAHNESTOCK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T MOLCZAN, ESQUIRE PA LD,#47437 Weitman, Weinberg & Reis Co.. LP,A. 2718 Koppers B1dg, 436 Seventh Avenue Pittsburgh. PA 15219 (412) 434-7955 WWR#04457440 Judgment Amount $ 1,810.11 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, PENNSYLVANIA CIVIL DIVISION NORTH STAR CAP[T AI. ACQ LLC Plaintiff Ys. Civil Action No. 05-4620 CIVI I. TERM JASON S FAHNESTOCK Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, JASON S FAHNESTOCK above named, in the default of an Answer, in the amount of$I,810.11 computed as follows: Amount claimed in Complaint $l,797.51 Interest from August 26. 2005 to October 19, 2005 at the legal interest rate of 6% per annum $12.60 TOTAL $1.810,11 I hereby certity that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices, WELTMAN, WEINBERG & REIS CO., L.PA / By: l 1// WtLLIA T. MOLCZA PA I.D.#47437 Weltman, Weinberg & Reis Co" LP,A, 2718 Koppers Bldg, 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04457440 PlaintifT"s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 152 [9 And that the last known address of the Defendant is: 337 OLD STATE RD GARDNERS,PA 17324 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH STAR CAPITAL ACQ LLC Case no: 05-4620 CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs, JASON S FAHNESTOCK Defendant The undersigned, who first 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 m accordance with the Servicemembers' Civil Relief Act (SCRA), 50 lJ,S,c, App. S 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, JASON S FAHNESTOCK is not in the military service, Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant. JASON S FAHNESTOCK is not in the military service. Further Affiant sayeth naught Iv/' AFFIANT !~-- ...-- I~ Not;}ri~IS:'-"-"- "" vlendy L ., <';.,q "eai ----. Citvnf' . bel/1ft, No - !t!Jj r>-: PttfsbtnQh 1\ I'... tary PUblic I .----.-:,~ ,,'~Irn:!,is": -,.' .,It.."ghei~I" C. I !:,~" '-----__., ...0'1 l::YDili::.,.., I . ., ...oUM\-; " . -- -~~::"-"!~_!5?~~;J 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, lJBSCRIBED in my presence this _ day IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHST AR CAPITAL ACQ LLC Plaintiff 05-4620-CIVIL JASON S FAHNESTOCK Defendant IMPORTANT NOTICE TO: JASON S FAHNESTOCK 337 OLD STATE RD GARDNERS,PA 17324 Date of Notice )(\- I-I - /'J " ',-- -....J 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 WELTMAN, WEINBERG~O., L.PA ./-" :-o:-~ '\/V/V-/ James C" 'armbrodt, Esquire PA 1.0. IIA 524 WELTMA~, WEINBERG & REIS CO., L.PA 2718,KopP.'ers Building 436 Seveiilh Avenue Pil~bur h, PA 15219 ( 2) 34-7955 #04457440 Request for Military Status Page I of I Department of Defense Manpower Data Center _ Military Status Report .. Pursuant to the Service Members' Civil Relief Act OCT-19-200511:04:21 < Last Name First/Middle Begin Date I Active Duty Status I Service/Agency FAHNESTOCK 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 J, 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://yvy,rvy,c.l~f~ill>elin1,A!1iUfaqi!lisIPC09S LD R.html. Report ID:BERIVPQIWVK https://www.dmdc.osd.mil/scralowalscra.prc_Select 10/19/2005 t xJ (:) -l4 :-D t1:- 7C. -4. D 0 ..., 0 c:~ ~:' "'" -n R ~ "'" 0 .-1 ."(.1,-; :r:-n - '\.) 0}f"c n rn-" --.:J .. .-\ --r!M ~ 0- ~ F ",.' (.,) -60 (J.l .' l. W -.: . S_~C) (lJ ~ l)'- ~'~'~ -,. -{", ~~ fi~: -" (_~:!J ~ ::;cc ;;r("") ':? c-,cn . '~/ -..-\ ~ -". --0 ~:g -' ,- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH STAR CAPITAL ACQ LLC Plaintiff vs. Civil Action No. 05-4620 CIVIL TERM JASON S FAHNESTOCK 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 Oed- ~/, ~ (xx) Assumpsit Judgment in the amount 01'$1,810.1 I plus costs. () Trespass Judgment in the amount 01'$_ 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: PROTHONOT ARY (QR QHUTY) JASON S FAHNESTOCK 337 OLD STATE RD GARDNERS,PA 17324 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., LP,A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 1-888-434-0085