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Home My WebLink About05-4623 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff No: DS- - 4/""/-~ C l'u~L ~(ft."'1 vs. COMPLAINT IN CIVIL ACTION THOMAS R PREVITE AKA THOMAS PREVITE SR 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 04457443 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 05'-~;lJ THOMAS R PREVITE 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: THOMAS R PREVITE 59 GARDEN PY L102 CARLISLE, PA 17013 3, Defendant applied for and received a credit card bearing the account number 4791070100157260 , 4, Defendant made use of said credit card and has a current balance due of $5551.30 , 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 , THOMAS R PREVITE , individually in the amount of $5551,30 with continuing interest thereon at the rate of 6,000% per annum from August 26, 2005 plus costs, Warmbrodt, 42524 MAN, WEINBERG & REIS CO" L,P,A, Seventh Avenue, Suite 2718 i sburgh, PA 15219 (4 2) 434-7955 F : 412-338-7130 4457443 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 Name, or address Telephone Changes Home ( ) Wo,k( ) Charge-Off Statement ACCOUNT NUMBER PAYMENT PAST DUE MINIMUM NEW AMOUNT OF DUE DATE AMOUNT PAYMENT BALANCE PAYMENT ENCLOSED 4791 0701 0015 7260 07/23/2003 4555.95 755.75 4655.85 $ THOMAS PREVITE 59 GARDEN py Ll02 CARLISLE P A 17013 220 JOHN GLENN DRIVE SUITE ONE AMHERST NY 14228 ACCOUNT NUMBER CREDIT CREDIT DAYS IN BILL PAYMENT MINIMUM LINE AVAILABLE BtLUNG CYCLE DATE DUE DATE PAYMENT DUE 4791 0701 0015 7260 4000.00 32 07/08/2003 07/23/2003 755.75 DATE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0708 0708 OVERLIMIT FEE 29.00 0000 0000 LATE CHARGE~ MIN PYMT NOT RECDBY DATE 35.00 **u FINANCE CHARGE CURRENT PURCHASE 35.90 PREVIOUS NEW PURCHASES DEBIT FINANCE OVERLINE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSfMENTS CHARGES AMOUNT BALANCE 4555.95 .00 .00 .00 64.00 99.90 655.85 4655.85 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 BAlANCES PERIODIC RATE PERCENTAGE RATES PERCENTAGE RATES PURCHASES 4555.95 .02465% 9.00% 9.00g,{, ADVANCES .06299% 22.99% 'l(, YOU MAYA VOID ADDlTIONAL FINANCE CHARGES ON PURCHASES IFYOU 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 a1 Cliente en espanoL 1~O0-277-4431 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 U a cKeJ?2.,; c. K~Y/If ~ , (Name) of 10()~S~v L't,ol'tctl Act. , plaintiff herein, that (Company)' LL-c.. A&"rt+- (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 of his /her knowledge. information and belief 'r~ (Signature) WWR# O"/lfSNO 1 (J ~ ~ if( '-- .U( ", ~ C-;) () ~ c , 111 ~, -n ~ () (r> -I ~ ~.! :r G r(i :TJ Z; IN ,- I f~,: ~ F! -.J I ;~:) L ~. ;', -.-. . ~ l J . ) .;. :~--) n-l :--1 C) :~.h 0 .-<: SHERIFF'S RETURN - REGULAR CASE NO: 2005-04623 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTHSTAR CAPITAL ACQ LLC VS PREVITE THOMAS R AKA THOMAS PR 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 PREVITE THOMAS R AKA THOMAS PREVITE SR the DEFENDANT , at 2010:00 HOURS, on the 8th day of September, 2005 at 59 GARDEN PARKWAY L102 CARLISLE, PA 17013 by handing to THOMAS PREVITE 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 18,00 4,00 ,00 10,00 ,00 32,00 So Answers: rf;lf:~:;N~~<: ,~ R, Thomas Kline 09/09/2005 WELTMAN WEINBERG REIS Sworn and Subscribed to before A.D, By, ~ f1 ;1 / D ucy S e/ff me this .1& day of , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff No. 05-4623-CIVIL vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE THOMAS R PREVITE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA 1.0 #42524 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04457443 > . - IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHST AR CAPITAL ACQ LLC Plaintiff vs. Civil Action No, 05-4623-CIVIL THOMAS R PREVITE Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Kindly settle, discontinue and end without prejudice to ref1le the above-captioned matter upon the records of the Court and mark the costs paid, WELTMAN, WEINBERG & REIS CO., L.PA By: James PA 1.0 #42524 WELTMAN, EI BERG & REIS CO" L,PA 2718 KopperiBt' ding 436 Seven*' Av. nue Pittsburgh!P 15219 . 412) 434-7955 SWORN TO A"iD SUBSCRIBED before me this .0 l day of enJj5 NO RY PUB " r '" NOlanaJs~~i--'-- ---, . vvendy L Gault N ' I City Of "'It Cd Olary PUO"o i - --,,~~:-L~~~~~~'2~I,ii"~~~;~~~:r!.'F.'.s,jll\i i'5"~ { CJ "'" 0 ~ c = -n (;.r1 7 -::I c:> ::C-n nl-- -C -C)hl I ::::JC1 W <:J6 "'t) (~~ ::;c C:? 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