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Home My WebLink About08-2175Our File No.: 139754 < 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. JEFFREY E BAKER 142 SALEM CHURCH RD MECHANICSBURG, PA 17050-2834 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: M - a,IZ 3vi! lexm 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 provisiones 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 s 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. JEFFREY E BAKER 142 SALEM CHURCH RD MECHANICSBURG, PA 17050-2834 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: p - .t I -2S L rF.tK.C J ?.., 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 JEFFREY E BAKER, an adult individual residing at 142 SALEM CHURCH RD MECHANICSBURG, PA 17050-2834. 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 $2,399.87. -r, 8. Although demand has been made, Defendant has failed to make payment of the amount due as ` above. 9. The original creditor is BRYN MAWR. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,399.87 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER raged SOCIATES, P.C. Attorn Plaintiff A Law Firm En in Debt Collectioi BY: Dated: 3/28/2008 David J. Our File No.: 139754 i VERIFICATION David J. Apothaker, EN. 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 worn falsification to authorities. Dav. 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 JEFFREY E BAKER 142 SALEM CHURCH RD MECHANICSBURG, PA 17050-2834 STATEMENT OF ACCOUNT Debtor's Name: JEFFREY E BAKER Account Number: 6030090205213731 Original Creditor: BRYN MAWR Balance Due: $2,399.87 Our File No.: 139754 EXHIBIT "A" 3? J n 00 A? W 00 3 rv n 7a? C c, a N _v_t CCD SHERIFF'S RETURN - REGULAR CASE NO: 2008-02175 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS BAKER JEFFREY E RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BAKER JEFFREY E the DEFENDANT at 1050:00 HOURS, on the 11th day of April , 2008 was served upon at 142 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 CAITLYN KEFFER 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 11.00,° Affidavit .00 x Surcharge 10.00 R. Thomas Kline .00 yla8/0 9 39.00 04/15/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: 6f-,?egr ?? before me this day Deputy Sheriff of A.D. by handing to ADULT IN CHARGE Our File No.: 139754 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. JEFFREY E BAKER Defendant. TO THE PROTHONOTARY: NO.: 08-2175 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, JEFFREY E BAKER, in the default of an $2,502.19 computed as follows: Amount claimed in complaint: $2,399.87 Amount Paid: - $(0.00) Interest from March 28, 2008 to 06/18/09 at the legal interest rate of 6.000 per annum $102.32 Costs $0.00 Attorney fees $0.00 TOTAL $2,502.19 1 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, JEFFREY E BAKER, last know address is 142 SALEM CHURCH MECHANICSBURG, PA 17050-2834. APOTHAKER & AS C TES, P.C. Attorneys f Pl ntiff A Law Firm Em4al in ebt Collection By: David J. , in the amount of in accordance with Dated: 6/18/2009 Our File No.: 139754 APOTHAKI;R & 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, JEFFREY E BAKER Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-2175 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 142 SAL MECHANICSBURG, PA 17050-2834. We inquired with the web site of the Defense Manpower Data Center, locat, Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defe t(s) is/are in any brand Mary M. Snavely-Dixon, Director of the Defense anp er Data C er has sent indicated that the Defendant(s) is/are not in the military. David J. Apothaker Attorney for Plaintiff The above signed understands that the statements herein are made subject to the Section 4904 relating to unsworn falsification to authorities. the attorney for CHURCH RD 1 at 1600 Wilson of the military. our inquiry ties of 18 Pa. C.S. Department of Defense Manpower Data Center JUN- 18 -2009 11:00.35 i1itary Status Report Pursuant to the Senicemembers Citi-A Relief Act Last First/Middle Buis Date Active Duty Status Sergi celAgency Name BAKER JEFFREY E Based on the information you have furnished, the D-NIDC does not possess indicating that the in&idual is cunrendy on active drt;? - Upon searching the infonnat on data banks of the Department of Defense 'Manpower Data Center, based you proNided, the above is the current status of the individual as to all branches of the' itary. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data. Center 1600 Wilson Blvd_ Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (}'_VIDC) is an organization of the Department of Defense that Enrollment and Etigil.sility Reporting System (DEERS) database %hich is the official source of data on care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Sen cemembers Civil ReliefAct [50 et seq] (SCRA) (formerly the Solders' and Sailors' C MI Relief Act of 1940). D- C has issued hundreds not possess any information indicating that the individual is ctureritlc on active duty" responses, and has exp rate. In the event the ind hidtual referenced above- or any family member, friend or representative asserts in indli%idhral is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encour verification of the person's active duty status by contacting that person's.Nlilitary Sersice via the "defenselinl below. If you have e?v7dencee the person is on active-duty and you fart to obtain this additional Military Seni, prop isiororrs of the SCRA may be invoked against you. If you obtain fibrther infarmation about the person ( e-g., an SSA. improved accuracy of DOB, a middle your request again at this Web site and we NNig pro-6de a new certificate for that query. This response reflects orient active duty statics only. For historical information, please contact the' lOitary of-contact See: http-.., is'PC09SLDR.html AR.- I-NG: TUs certificate was pros•ided based on a name and Social Sec=# number (5S1 proN ded Providing an erroneous name or SSN,.NM cause an erroneous certificate to be provided inform Lion the infarmatfon that the Defense for rm'litar- medical ;CS Appx_ §§ 501 thousands of *does geed a small error w manner that the ed to obtain further rT URL prodded vel'if"tcation, you can submit SCRA points- the requester. 439754 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) JEFFREY E BAKER ) NO. 08-2175 To: JEFFREY E BAKER 142 SALEM CHURCH RD MECHANICSBURG, PA 17050-2834 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAUL'. Date of Notice: July 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 M 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DAtVID\I. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collectio 2417 Welsh Road, Suite 214520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR { CASE NO: 2008-02175 P A" 0COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC i VS BAKER JEFFREY E RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BAKER JEFFREY E DEFENDANT , at 1050:00 HOURS, on the 11th day of April 2008 at 142 SALEM CHURCH ROAD MECHANICSBURG, PA-..I..7050-2834 by handing to CAITLYN KEFFER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together ?ith and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 11.00 Affidavit .00 j Surcharge 10.00 R. Thomas Kline .00 39.00 04/1512008 APOTHAKER & ASSOCIATES Sworn and Subscibed to before me this day Deputy Sheriff of A.D. 1 I _ C ?p ATH C?* 13?1'lg8 R? aa?a?`f IJA, ? ? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JEFFREY E BAKER 142 SALEM CHURCH RD MECHANICSBURG, PA 17050-2834 ARROW FINANCIAL SERVICES, LLC Plaintiff, vs. JEFFREY E BAKER Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-2175 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 ARBITRAT 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. ARothaker, Escp at this telephone number: 215-634-8920 /,-/ aa-0 a k. ,1 0,? 6 4 s/oy