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Home My WebLink About08-1251l Our File No.: 147766 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff AFS ASSIGNEE OF PROVIDIAN NATIONAL BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08- 1a.51 Civil tern 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o con un abogado v entregar a la corte en forma escrita sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff AFS ASSIGNEE OF PROVIDIAN NATIONAL BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: d /-" 5) &u T2, JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 Defendant. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, AFS ASSIGNEE OF PROVIDIAN NATIONAL BANK, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant is JILL D MALIS, an adult individual residing at 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiffs records. A true and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said goods and/or services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, leaving a balance due and owing of $5,002.00. w ` 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is PROVIDIAN. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $5,002.00 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASS IATES, P.C. Attorney fo 1 ' tiff A Law Firm Engag in ebt Collection BY: David I Dated: 2/12/2008 Our File No.: 147766 40 . VERIFICATION David J Apothaker, Esq. 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 toorn falsification to authorities. David J ?pothaker Attorney for Plaintiff DATE: 2/12/2008 AFS ASSIGNEE OF PROVIDIAN NATIONAL BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 147766 JILL D MALIS 4559540400986677 PROVIDIAN $5,002.00 EXHIBIT "A" 'o C")a T ?` b ? r err o r 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-01251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AFS VS MALIS JILL D DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon neTT TO .TTT.T. n the DEFENDANT , at 1932:00 HOURS, on the 10th day of March at 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 by handing to JILL D MALIS 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 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 .00 311&16 ? 42.40 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 03/13/2008 APOTHAKER & ASSOCIATES By: - day Deputy Sheriff A.D. 2008 Our File No.: 147766 BY: David J. Apothaker, Esq. APOTHAKER & ASSOCIATES, P.C. Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff AFS ASSIGNEE OF PROVIDIAN NATIONAL BANK C/O David J. Apothaker, Esq. 2417 Welsh Rd., Ste. 520 #21 Philadelphia, PA 19114 Plaintiff, VS. JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1251 Civil Action PRAECIPE TO SUBSTITUTE PARTY PLAINTIFF AS PER Pa RULE 2352 (a) TO THE PROTHONOTARY: Kindly substitute as Party Plaintiff, Arrow Financial Services LLC, in this action. The right to substitution is based upon the following facts: Arrow Financial Services LLC, is the proper corporate name for Plaintiff, AFS ASSIGNEE OF PROVIDIAN NATIONAL BANK, the name that Plaintiff used when this civil action was commenced, was used as a result of a clerical error. Defendant's rights will not be prejudiced by this change. APOTHAKER & SS CIATES, P.C. Attorneys or Plaintiff By: David J. Apothaker Dated: April 22, 2008 %; tea _i r^ IN? L ? Our File No.: 1477,66 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 ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS OF Plaintiff, ) CUMBERLAND COUNTY vs. JILL D MALIS Defendant. TO THE PROTHONOTARY: NO.: 08-1251 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, JILL D MALIS, in the default of an $5,330.29 computed as follows: Amount claimed in complaint: $5,002.00 Amount Paid: - $(0.00) Interest from February 12, 2008 to 06/18/09 at the legal interest rate of 6.000 per annum $328.29 Costs $0.00 Attorney fees $0.00 TOTAL $5,330.29 I hereby certify that the appropriate Notices of Default, as attached have been Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, JILL D MALIS, last know address is 200 PENNSYLVANIA AVE 17011-5436. Dated: 6/18/2009 APOTHAKER & AS IATES, P.C. Attorneys r P intiff A Law Firm Enaa ed i Debt Collection By: Apothaker in the amount of in accordance with HILL, PA Our File No.: 147 766 ' 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 ARROW FINANCIAL SERVICES LLC VS. Plaintiff, JILL D MALIS Defendant. 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 Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 200 PENT` CAMP HILL, PA 17011-5436. We inquired with the web site of the Defense Manpower Data Center, Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any Mary M. Snavely-Dixon, Director of the Defense Man er Data Center has sent indicated that the Defendant(s) is/are not in the military. David J. Ap t er Attorney for laintiff The above signed understands that the statements herein are made subject to the pena Section 4904 relating to unsworn falsification to authorities. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1251 im the attorney for SYLVANIA AVE i at 1600 Wilson of the military. our inquiry ies of 18 Pa. C.S. Department of Defense N-lanpovver Data Center \rlilitary Status Report Pui uant to the Senicemernbers Civil Relief Act <.Last FirstAliddle Begin Date Name NSALIS JILL D Active Daft Status JL -15-200910:45::2 Servi elAgency Based can the ini[brmation v-ou have f mnished, the DIXIDC does not possess indicating that the individual is currently on active dut.v Upon searching the information data banks of the Department of Defense Manpower Data Center, based you provided, the above is the current status of the individual as to all branches of the 'NUitary. & %A %Y? fit. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Bled., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (D iDC) is an organization of the Department of Defense that Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on care and other e&gtl)i t systems- The Department of Defense strongly supports the enforcement of the Servicesmembers Civil Relief Act [50 et seq) (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940)_ DNI DC has issued hundreds not possess any information indicating that the in&idual is currently on active duty" responses, and has exp rate. In the event the individual referenced above, or any family member: frien& or representative asserts in individual is can active duty, or is otherwise entitled to the protections of the SCRA, you are strong encour verification of the. person's active duty status by contacting that person's. INTilitary Service via the "defenseiinl below- If you have evidence the person is on active-duty and you fail to obtain this additional Military Se vi provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e- ., an SS?ti, improved accuracy of DDB, a middle your request again at this Web site and we will provide a new cerfficate for that query. This response reflects current active duty status only, For historical information, please contact the Military of contact. See: h :. 'vv- v%iv.defcnsc&&-.n afa 's.-PG09SLDR.htm WAFNING: This certifeate was provided based oa a name and Social Security number (SSA) prorvided Providing an erroneous name or SSA vv-li cause an erroneous certificate to be provided. information the information that the Defense for military medical :CS Appx- § 501 thousands of "does raced a small error ty manner that the ed to obtain further zl" I. RL provided verification_ you can submit SCRA points- the requester. P partM:C4CSGRAPDGI' 147766 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) JILL D MALIS ) NO. 08-1251 To: JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAUL Date of Notice: June 17, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORT 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 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 FE . CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 DAVV J. APOTHAKER, ESQUIRE APOT AKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collectio 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR `CASE NO: 2008-01251 P X l\`" COMMONWEAL T H OF PENNSYLVANIA : / COUNTY OF CUMBERLAND AFS VS MALIS JILL D DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE _ was served upon MALLS JILL D the DEFENDANT at 1932:00 HOURS, on the 101th day of March , 2008 at 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 by handing to JILT, D MALIS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents hereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 14.40 .00 10.00 R. Thomas line 00 42.40 03/13/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to before me this day of A.D. 4 )4-oo PA ATT- 04:1 ! 34'[a S kT* aa7 9.01 1Jo,k? K laL" OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 ARROW FINANCIAL SERVICES LLC Plaintiff, vs. JILL D MALIS Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1251 Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATO JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. atthis telephone number: 215-634-8920 A/ a"J" Q I cm? 10" 1. * /o9 SHAPIRO LAW OFFICE, P.C. Kenneth S. Shapiro, Esq. Attorney I.D. #26850 P.O. Box 20 712 Darby Road Havertown, PA 19083-0210 (610) 668-0707 f fLEO—OFt tC_. F THE PROTHONO T ;a 2014 OCT 10 M12:117 CUMBERLAND COUNTY PENNSYLVANIA No. of Pages 1 ARROW FINANCIAL SERVICES LLC Plaintiff v. Jill D. Malis Defendant(s) Court Of Common Pleas CUMBERLAND County, PA CIVIL CASE NO. 2008-01251 ENTRY OF APPEARANCE TO THE DIRECTOR OF THE DEPARTMENT OF COURT RECORDS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION): Kindly enter my appearance on behalf of ARROW FINANCIAL SERVICES LLC, Plaintiff herein. I hereby certify that this change is not intended to, nor will it, delay this proceeding to the best of my knowledge, information and belief Papers may be served at the address set forth below: Dated: OCT 0 7 2014 EX203 Kenneth S. Shapiro, Esq. Attorney ID # 26850 Shapiro Law Office, PC P.O. Box 20 712 Darby Rd. Havertown, PA 19083-0210 Telephone # 610-668-0707 FAX # 610-668-1815 Respectfully submitted, SHAPIRO LAW OFFICE, Shapiro, E For the irm