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Home My WebLink About08-2174A Our File No.: 139698 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 ARROW FINANCIAL SERVICES, LLC ) c/o Apothaker & Associates, P.C. ) 2417 Welsh Road, Suite 21 #520 ) Philadelphia, PA 19114 ) Plaintiff, ) vs. ) GREGORY LANHAM ) 421 D ST ) CARLISLE, PA 17013-1316 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Q$ - a «y 0'iva -rem 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 ARROW FINANCIAL SERVICES, LLC ) c/o Apothaker & Associates, P.C. ) 2417 Welsh Road, Suite 21 #520 ) Philadelphia, PA 19114 ) Plaintiff, } VS. ) GREGORY LANHAM ) 421 D ST ) CARLISLE, PA 17013-1316 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OP- -117V Cif IIZ".- CIVIL ACTION COMPLAINT FIRST COUNT Plaintiff, ARROW FINANCIAL SERVICES, LLC, 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 GREGORY LANHAM, an adult individual residing at 421 D ST CARLISLE, PA 17013-1316. 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 $4,096.73. 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 $4,096.73 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Atto? for Plaintiff A Law Firm g ed in Debt Collection BY: Dated: 3/28/2008 . Apothaker Our File No.: 139698 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 understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 falsification to authorities. Dav)d Apothaker Attorney for Plaintiff DATE: 3/28/2008 ARROW FINANCIAL SERVICES, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 GREGORY LANHAM 421 D ST CARLISLE, PA 17013-1316 STATEMENT OF ACCOUNT Debtor's Name: GREGORY LANHAM Account Number: 4559515000202295 Original Creditor: PROVIDIAN Balance Due: $4,096.73 Our File No.: 139698 EXHIBIT "A" " C= CID o -n -U _,,. 00 SHERIFF'S RETURN - REGULAR CASE NO: 2008-02174 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS LANHAM GREGORY MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon r.,Trnr , T the DEFENDANT , at 1255:00 HOURS, on the 9th day of April 2008 at 34 WINCHESTER GARDENS CARLISLE, PA 17013-1316 by handing to GREGORY LANHAM 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 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 .00 16? C? ? 33.00 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 04/10/2008 APOTHAKER & ASSOCIATE,Bl i By: f epu y S eriff A. D. Our File No.: 139698, APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 ARROW FINANCIAL SERVICES, LLC ) COURT OF COMMON PLEAS OF Plaintiff, ) CUMBERLAND COUNTY vs. GREGORY LANHAM Defendant. TO THE PROTHONOTARY: NO.: 08-2174 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, GREGORY LANHAM, in the default of an Answer, in the amount of $4,296.62 computed as follows: Amount claimed in complaint: $4,096.73 Amount Paid: - $(0.00) Interest from March 28, 2008 to 06/18/09 at the legal interest rate of 6.000 per annum $199.89 Costs $0.00 Attorney fees $0.00 TOTAL $4,296.62 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. in accordance with I certify Defendant, GREGORY LANHAM, last know address is 421 D ST CARLISLE, PA 17013-1316. APOTHAKER & Attorney,, A Law Firm Eng By: David J. bCIATES, P.C. laintiff Debt Collection Dated: 6/18/2009 Our File No. 13 9698 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 CUMBERLAND COUNTY Plaintiff, vs. GREGORY LANHAM NO.: 08-2174 Civil Action Defendant. 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 421 D S 17013-1316. We inquired with the web site of the Defense Manpower Data Center, Boulevard, Suite 400, Arlington, VA 22209-2593, if th Aefendant(s) is/are in any Mary M. Snavely-Dixon, Director of the De ns Manpower Data Center has sent indicated that the Defendant(s) is/are not in the mil' a _ . David' Apothaker Attorney"for Plaintiff The above signed understands that the statements herein are made subject to the penal Section 4904 relating to unsworn falsification to authorities. i the attorney for CARLISLE, PA I at 1600 Wilson of the military. our inquiry :ies of 18 Pa. C.S. APOTHAKER&ASSOCIATES, P.I - ATTORNEYS AT LAW Department of Defense' anpower Data Center RN-18-21009 10--58: 45 } _\ Chary Status Report Pursuant to the Servicemembers Cavil Relief Act '4, Last Name Firsti-N fiddle Begin Date Active Duty= Status Se icelAgency LA.N-R \I I GREGORY Based on the information you have fvaished, the DZ DC clues not possess i y i iforrnation indicating that the individual is currently on active duty=, Upon searching the information data banks of the Department of Defense Manpower Data Center, based the infornaton that you provided, the above is the current status of the individual as to all branches of the Military , A - Mary= M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd- Suite 400 Adinton, 'VA 2209-2593 The Defense Manpower Data Center (D'_'ViDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibky Reporting Sy=stem (DEERS) database which is the official source of data on elie y for military medical care and other eligr`bil - systems. The Department of Defense strongly supports the enforcement of the Sere cemembers Civil Relief Act [50 SCS Appx- §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DVIDC has issued hundreds f thousands of "does not possess any information indicating that the individual is eurrenih on active duty" responses, and has experienced a small. error rate. In the event the individual referenced above, or arse, family member, friend or representative asserts in i y manner that the individual is on active duty, or is othernvise entitled to the protections of the SCRA, you are stronr enco ed to obtain finrtlner verification of the person's active duty status by contacting that persons Military Service via the "defenseE nk mil" LRL prodded below. If you have evidence the person is on active-durty and you fail to obtain this additional Military Ser°v c . verification provisiions of the SCR.A may be invoked against you_ If you obtain firther information about the person ( e.g.. an SSt, improved accuracy of DOB, a middle e), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects current active duty= status only. For historical information, please contact the filitary S ervice SC.RA points- of=contact, See httw -,vixiv defenseisnk uxnrlfhq Pis:PC'09SLDR html WARNING.- This certificate was provided based on a name and Social Security number (SS N) provided by? the requester, Providing an erroneous name or SSN will cause an erroneous certificate to be provided ep a rt ID: B UROL I Z'Sl TIT 139698 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) GREGORY LANHAM ) NO. 08-2174 To: GREGORY LANHAM 421 D ST CARLISLE, PA 17013-1316 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAUL Date of Notice: July 16, 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 FOR 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 FOR m 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 FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 DAVI'DV. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collecti< 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 . SHERIFF'S RETURN - REGULAR CASE NO: 2008-02174 P 41 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS LANHAM GREGORY MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn accordi says, the within COMPLAINT & NOTICE was served upon LANHAM GREGORY DEFENDANT at 1255:00 HOURS, on the 9th day of Argil at 34 WINCHESTER GARDENS CARLISLE, PA 17013-1316 by handing to GREGORY LANHAM a tree and attested copy of COMPLAINT to law, the , 2008 :O_ICE together with 70- 7 - L(J and at the same time directing His attention ? to the ?ohtents hereof. Sheriff's Casts: So Answers: Docketing 18.00 Service Affidavit 00 .00A.. Surcharge 10.00 f - R. Thomas Kline 00 33.00 04/10/2008 APOTHAKER & ASSOCIATQ1 ff t Sworn and Subscibed to may, f By: _ before me this day r"'.?epu?y S eriff of r A. D. 14-oo Pp am 12T# aarIaob Q"4? wa?,j TO: GREGORY LANHAM 421 D ST CARLISLE, PA 17013-1316 ARROW FINANCIAL SERVICES, LLC Plaintiff, vs. GREGORY LANHAM Defendant. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-2174 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a ?Tudgment 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 Escp at this telephone number: 215-634-8920 (v/a5?o9