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Home My WebLink About05-4621 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff No: 65 - 11..;),,/ (}{~ i__~0<-~ vs. COMPLAINT IN CIVIL ACTION AMELIA SNYDER 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 04457438 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 OS'. 'f&.2/ AMELIA SNYDER 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: AMELIA SNYDER 580 W LOUTHER ST 2 CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 4791060400830005 . 4. Defendant made use of said credit card and has a current balance due of $2475.79 , 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 6.000% per annum on the unpaid balance from August 26, 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 , AMELIA SNYDER , individually , in the amount of $2475.79 with continuing interest thereon at the rate of 6.000% per annum from August 26, 2005 plus costs. Warmbrodt,42 24 , WEINBERG & REIS CO., L.P.A. venth Avenue, Suite 2718 urgh, PA 15219 434-7955 412-338-7130 57438 C A Pit KMJ 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. North Star Capital Acquisitions, LLC Please indicate N arne, or address Telephone Changes Home ( ) Wock( ) Charge-Off Statement ACCOUNT NUMBER PAYMENT PAST DUE MINIMUM NEW AMOUNT OF DUE DATE AMOUNT PAYMENT BALANCE PAYMENT ENCLOSED 4791 0604 0083 0005 08/08/2003 2003.54 663.12 2083.33 $ AMELIA SNYDER 580 W LOUTHER ST 2 CARLISLE P A 17013 220 JOHN GLENN DRlVE SUITE ONE AMHERST NY 14228 ACCOUNT NUMBER CREDIT CREDIT DAYS IN BILL PAYMENT MINIMUM LINE AVAILABLE BILLING CYCLE DATE DUE DATE PAYMENT DUE 4791 0604 0083 0005 1500.00 32 07/24/2003 08/08/2003 663.12 DATE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0724 0724 OVERLIMIT FEE 29.00 0000 0000 LATE CHARGE - MIN PYMr NOT REeD BY DATE 35.00 ..H FINANCE CHARGE CURRENT PURCHASE 15.79 PREVIOUS NEW PURCHASES DEBIT FINANCE OVERLINE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSTMENTS CHARGES AMOUNT BALANCE 2003.54 .00 .00 .00 64.00 79.79 583.33 2083.33 AN AMOUNT ~OLLOWED BY A MINUS SIGN(-} IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED $ TYPES OF CREDlT TO FINANCE DAILY NOMINAL ANNUAL ANNUAL WHICH RATES APPLY CHARGE BALANCES PERIODIC RATE PERCENTAGE RATES PERCENTAGE RATES PURCHASES 2003.54 .02465% 9.00% 9.00% ADVANCES .06299 'X, 22.99% % YOU MAYA VOID 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 espana!: ]-800-277~4431 EXHIBIT I 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 /la ~ke J?Z; -e J< d /lIt/. vJ . i' (Name) of !Vo0!-i-t 81-o--r CVI~I A-<.t, plaintiff herein, that (Company) t.-LC 1+~M- ide) 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 of his /her knowledge, information and belief. WWR# Olfl/S7l/J'(; (:\ -6g, ~ ~ if{ 10 ?IT :ji lI't 1""-.' 0 C~ ---- .::') " c..,"" ..... ~ II( f.'"") -:::-1""1 f-',j rll-.:::; D -,_I C.-_ C) I , ~ -.J C,:l ~ '1-, ") Lv ~, c:-) - - in ~ t (;"? " _C- C'l '--L.. SHERIFF'S RETURN - NOT SERVED CASE NO: 2005-04621 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NORTHSTAR CAPITAL ACQ LLC VS SNYDER AMELIA R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: SNYDER AMELIA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT SERVED , as to the within named DEFENDANT , SNYDER AMELIA 580 W LOUTHER STREET #2 CARLISLE, PA 17013 DEFENDANT STATED THAT SHE HAD FILED BANKRUPTCY. HER ATTORNEY IS FLOYD DICKENS. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.00 .00 10.00 .00 32.00 Thoma ine riff of Cumberland County ELTMAN WEINBERG REIS 09/08/2005 Sworn and subscribed to before me this ~ day of ~~~ J.--<;u'S" A.D. r1H~ prothonotar~ ;1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC plaintiff No: O~ - 41021 (l;ul.L Y0L'J vs. COMPLAINT IN CIVIL ACTION AMELIA SNYDER 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 04457438 C A Pit KMJ TRUE COpy FROM RECORD In Testimony Whereof. I here unto set my hand ~~t~~~. ~Qmb~.~. ""~ ~f? ~~$ '---- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH STAR CAPITAL ACQ LLC Plaintiff vs. Civil Action No AMELIA SNYDER 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: AMELIA SNYDER 580 W LOUTHER ST 2 CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 4791060400830005 . 4. Defendant made use of said credit card and has a current balance due of $2475.79 , 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 6.000% per annum on the unpaid balance from August 26, 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 , AMELIA SNYDER individually , in the amount of $2475.79 with continuing interest thereon at the rate of 6.000% per annum from August 26, 2005 plus costs. Warmbrodt,42 24 , WEINBERG & REIS CO., L.P.A. venth Avenue, Suite 2718 urgh, PA 15219 434-7955 412-338-7130 57438 C A Pit KMJ 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. North Star Capital Acquisitions, LLC Please indicate N arne, or address Telephone Changes Home ( ) Work ( ) Charge-Off Statement ACCOUNT NUMBER PAYMENT PAST DUE MINIMUM NEW AMOUNT OF DUE DATE AMOUNT PAYMENT BALANCE PAYMENT ENCLOSED 4791 0604 0083 0005 08/08/2003 2003.54 663.12 2083.33 $ AMELIA SNYDER 580 W LOUTHER ST 2 CARLISLE PA 17013 220 JOHN GLENN DRlVE SUITE ONE AMHERST NY 14228 ACCOUNT NUMBER CREDIT CREDIT DAYS IN BILL PAYMENT MINIMUM LINE A V AII-ABLE BILLING CYCLE DATE DUE DATE PAYMENT DUE 4791 0604 0083 0005 1500.00 32 07/24/2003 08/08/2003 663.12 DATE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 072. 0724 OVERLIMIT FEE 29.00 ??oo 0000 LATE CHARGE- MINPYMTNOTRECDBYDATE 35.00 ....H FINANCE CHARGE CURRENT PURCHASE 15.79 PREVIOUS NEW PURCHASES DEBIT FINANCE QVERLINE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSTMENTS CHARGES AMOUNT BALANCE 2003.54 .00 .00 .00 64.00 79.79 583.33 2083.33 AN AMOUNT FOLLOWED BY A MINUS SIGN{-) IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED $ TYPES OF CREDIT TO FINANCE DAILY NOMINAL ANNUAL ANNUAL WHICH RA rES APPLY CHARGE BALANCES PERIODIC RATE PERCENTAGE RATES PERCENTAGE RATES PURCHASES 2003.54 .02465 'll, 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 Servico al Cliente en espanol: 1-800-277-4431 EXHIBIT I VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A.C.S. ~4904 relating to unsworn falsifications to authorities, that he/she is }I~c.-K-e f?"Z-; e J< d tll t1. vJ . ~ (Name) AJ,e.,d- of /Vor</-4 8~ Ccl. {J1'/-t1-.1 Ikt, plaintiff herein, that ide) (Company)' t-LC 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 of his /her knowledge, information and belief. WWR# O<-{i.fS71.0'b L2: :', ;"\ ':.1 :..:.;r~ -"-_1'-"",-, '.~ ""= ,ilf\\ '11'i) i', ;7, /Xv "''''/( v,/i). Y1~~~ 0- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH STAR CAPITAL ACQ.,LLC., Plaintiff vs. No. 05-~ 4t..;;,,/ PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE AMELIA SNYDER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA 10 #42524 WELTMAN, WEINBERG & REIS CO., LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457438 ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ.,LLC., Plaintiff vs. Civil Action No. 05-4+fi'2 ^-II..,;{{ AMELIA SNYDER Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO, L.PA // SWORN TO AND SUBSCRIBED 31 day -- -.--'--- of ,2005 --N~'~na\ 5133\ , , \ N' tar I PubliC \ Wendy L Gao t, .).' ro' .."1 < '.~tlV\.' ".~1l", City Of Pi~Sbur;~~~::~~,~!~j\Y ~; ',',. ~,~)O?_--- \__~~~~:-~~~:l_~.f__ ~~~.::~,::;-:~;;.:::; ~~~"A$fl:; ...' % c.~ -;;C S~ \ cr> q, ~\~ ~_(,rr!. ~qL": :_>~~) ':?.~~ :;:!\ '"':0 ::4 ....R cr.. cP