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Home My WebLink About08-1681Blatt, Hasenmiller, Leibsker & Moore, LLC Steven J. Snyder, Esquire Attorney for Plaintiff Attorney #202216 P.O. Box C3800 Southeastern, PA 19398 (610) 647-5440 ARROW FINANCIAL SERVICES, LLC: c/o Blatt, Hasenmiller, Leibsker & Moore, LLC P.O. Box C3800 Southeastern, PA 19398 Plaintiff V. TRACY A RAINELLI IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. M - 1A1 N11 Term. 409 DELANCEY CT MECHANICSBURG PA 17055-4484 Defendant COMPLAINT - CIVIL ACTION 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 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 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 AVISO Le han demando a usted en la corte. Si usted quiere defenderse de estas demandadas expuestas en las paginas siguentes, usted tiente veinte (20) dias de plazo all partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrita on en persona o con un abogado y entregar a la corte enforma escritas sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se defende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notif ication. Ademas, la cone puede decidir a favor del demandante y requiere que usted cumpla con todas del las provisiones de esta demanda. Usted puede perdes dinero o us propriedadedsu otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSIGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 2040376 PPTCHDFI Blatt, Hasenmiller, Leibsker & Moore, LLC Steven J. Snyder, Esquire Attorney for Plaintiff P.O. Box C3800 Southeastern, PA 19398 (610) 647-5440 ARROW FINANCIAL SERVICES, LLC: c/o Blatt, Hasenmiller, Leibsker & Moore LLC P.O. Box C3800 Southeastern, PA 19398 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff V. TRACY A RAINELLI NO. OF- R j 1 409 DELANCEY CT MECHANICSBURG PA 17055-4484 Defendant COMPLAINT - CIVIL ACTION COUNT ONE 1. The Plaintiff herein is ARROW FINANCIAL SERVICES, LLC. 2. The Defendant herein is TRACY A RAINELLI, an adult individual located at 409 DELANCEY CT MECHANICSBURG PA 17055-4484. 3. The Defendant at all times relevant hereunder, knowingly requested the funds at issue, and knowingly and voluntarily accepted the benefits bestowed and the terms and conditions linked thereto. 4. After applying all known charges and payments to said account, the balance is $19334.73. A true and correct copy of an affidavit of account is attached hereto and marked as an Exhibit. 5. Plaintiff has in all respects fulfilled all conditions precedent to its obligations on the contract and for bringing this Complaint for damages. 6. Despite repeated demand by Plaintiff, Defendant has refused and continues in failure and refusal to pay Plaintiff. 2040376 PPTCDEAI WHEREFORE, Plaintiff demands judgment in its favor against Defendant, in the amount of $19334.73, and costs of this action. COUNT TWO Plaintiff also claims alternatively on the basis of quantum meruit or Quasi Contract. Paragraphs 1 through 6 above are incorporated herein by reference as though fully set forth. 8. Plaintiff was neither a volunteer nor an officious intermeddler. 9. Plaintiff is the owner of said credit account. 10. Plaintiff expected payment from the Defendant for said credit in the amount set forth above. 11. The amount claimed is the fair and reasonable market value for said credit. WHEREFORE, Plaintiff demands judgment in its favor against Defendant, in the amount of $19334.73, and costs of this action. Dated: N 2 &C>g BY Gregory R. Dye VERIFICATION I, Steven J. Snyder, Attorney for Plaintiff, hereby state: 1. I am the attorney for the plaintiff in this action, and I sign this Verification stating that Plaintiff is out of the jurisdiction of the Commonwealth; 2. 1 verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief; and 3. 1 understand that the statements in said complaint are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. DATED: By: . ;f Gregory R. Dye PPTXVERI STATE OF ILLINOIS COUNTY OF COOK AFFIDAVIT OF INDEBTEDNESS The undersigned, being duly sworn, deposes and states that he/she is an employee/agent of: Arrow Financial Services, LLC and has knowledge of the account balance, and is duly authorized to make this affidavit. Affiant states that the amounts shown below are taken/calculated from the original books and records of the above named plaintiff as well as from information provided to Arrow Financial Services, LLC by WELLS FARGO FINANCIAL BANK, and based on information and belief, affiant states that the amount due to Arrow Financial Services, LLC by TRACY A RAINELLI for funds advanced to defendants(s) or paid to another at defendant(s) request, or for goods or services provided to defendant(s) or to another at defendant's request, is the following: on the following account(s) as of 12-13-07: CREDITOR/ACCOUNT NUMBER CURRENT BALANCE ARROW FINANCIAL SERVICES, LLC 101442804 $19334.73 Affiant states that the amount shown above is true and correct to the best of his/her knowledge. Further affiant sayeth not. Subscribed and Swo Before me da o 0 (WI Notary Public My Commission Expires: Date of Service: / /20 Reference #: 2040376 Forwarder ID#: Account #: 101442804 BAFFAREG(11/02 )EEO ARROW FINANCIAL SERVICES LLC AM= _ Title =PUBLICSTATE OY F ILLINOIS :1 QW10 'R 7.7 .r. O SHERIFF'S RETURN - REGULAR CASE NO: 2008-01681 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS RAINELLI TRAACY A NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE RAINELLI TRACY A DEFENDANT was served upon the , at 1915:00 HOURS, on the 19th day of March , 2008 at 409 DELANCEY COURT MECHANICSBURG, PA 17055 by handing to TRACY A RAINELLI 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: So Answers: Docketing 18.00 Service 9.60 ° aca°? ti_s .-rG n a Postage .58 Surcharge 10.00 R. Thomas Kline 38.18-- 03/20/2008 BLATT HASENMILLER LEIBSKER a 7/ 68 .?,?-1 Sworn and Subscribed to By: before me this day Deputy Sheriff of A. D. 1 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci ARROW FINANCIAL SERVICES, LLC Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 ARROW FINANCIAL SERVICES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, Vs. TRACY A RAINELLI 409 DELANCEY CT MECHANICSBURG PA 17055-4484 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 2008-01681 P PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT TRACY A RAINELLI in this matter in the amount of $19344.73 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 03-19-09 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: April 28, 2009 By: Daniel Santucci 2040376 PPTJPFJI II'INIII1II1II Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci ARROW FINANCIAL SERVICES, LLC Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ARROW FINANCIAL SERVICES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. TRACY A RAINELLI 409 DELANCEY CT MECHANICSBURG PA 17055-4484 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 2008-01681 P AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MOORE, Dated: April 28, 2009 By: Daniel Santucci 2040376 PPTJCAMI III UM 11111111111111111111111111111111111111111111111111111111 ARROW FINANCIAL SERVICES, LLC Plaintiff, Vs. TRACY A RAINELLI 408 DELANCEY CT MECHANICSBURG PA 17055-4484 Defendant(s). TO: TRACY A RAINELLI Date of Notice: April 16, 2009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. IMPORTANT NOTICE 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 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 A 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 FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASEN)ILLER, LEIBSKER & MOORE, LL By: 5 GredrVailey Parkway, Suite 100 Malvern, PA 19355 800-650-1079 x 4151 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2040376 PPTNLRSI 1 U 1111111 N1111111 FILE: ED- OF T-lf?- 2c03IlAy 12 1 Ar1111: 48 4 l4. oo Po Al'r-f M* aloaz j a { l ga Rx? alas 06 Ooh? ARROW FINANCIAL SERVICES, LLC Plaintiff, vs. TRACY A RAINELLI Defendant(s). TO: TRACY A RAINELLI IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 2008-01681 P NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. PROTHON A Y Dated: 5 oZl O_ By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 2040376 PPTNDJNI