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Home My WebLink About08-3082Our-File No.: 156390 A,POTHAKER & 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. ISHMAEL PALMER 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: fl$ - ao8a C jvi ierv, 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 fizrther 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 provisions 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 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA 0 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 .6 APOTHAKER & ASSOCIATES, P.C. $,Y: 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. ISHMAEL PALMER 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o Q - 30 82 C4,-? CIVIL ACTION COMPLAINT FIRST COUNT 1. 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 ISHMAEL PALMER, an adult individual residing at 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070. 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 $1,753.51. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is SBC. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,753.51 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A IATES, P.C. Attorney r PI intiff A Law Firm Enga ed ' ebt Collecti& BY: Dated: 4/27/2008 David Our File No.: 156390 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 subject to the penalties of 18 Pa.C.S.A. 4904 relating understands that the statements therein are made falsification to authorities. David J.)tpothaker Attorney for Plaintiff DATE: 4/27/2008 ARROW FINANCIAL SERVICES LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 ISHMAEL PALMER 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: ISHMAEL PALMER Account Number: 4775803236473 Original Creditor: SBC Balance Due: $1,753.51 Our File No.: 156390 EXHIBIT "A" N CZ3 r Oo i_ C CASE NO: 2008-03082 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS PALMER ISHMAEL DENNIS FRY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PALMER ISHMAEL the DEFENDANT , at 1113:00 HOURS, on the 17th day of May , 2008 at 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070 by handing to TASHA GREEN, GIRLFRIEND ADULT IN CHARGE 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 Service Affidavit Surcharge s/a??ap So Answers: 18.00 16.00 00 10.00 R. Thomas Kline .00 44.00 05/19/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to before me this of By: day eputy /Aerilff A. D. Our File No.: 156390 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 ARROW FINANCIAL SERVICES LLC Plaintiff, VS. ISHMAEL PALMER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3082 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, ISHMAEL PALMER, in the default of an Answer, in the amount of $1,252.20 computed as f6llows: Amount claimed in complaint: $ 1,753.51 Less: Amount Paid: ( 567.00) Plus: Interest from April 27, 2008 to August 6, 2009 at the legal interest rate of 6.00% per annum 65.69 Costs 0.00 Attorney fees 0.00 TOTAL $ 1,252.20 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, ISHMAEL PALMER, last known address is 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070. APOTHAKER ? ASTCIATES, P.C. A Law Firm By: David J. Apothaker Dated: August 6, 2009 • Our File No.: 156390 , 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 Plaintiff, vs. ISHMAEL PALMER Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3082 : SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070. We inquired with the web site of the Di Boulevard, Suite 400, Arlington, VA 22209-2593, Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. Apothaker Attorney for Plaintiff Manpower Data Center, located at 1600 Wilson Defendant(s) is/are in any branch of the military. Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. APOTHAKER & ASSOCIATES, P.C. ATTORNEYS AT LAW Department of Defense Manpowar' Data Center AUG-06-2009 09-42:21 Upon sewching the w1banatiant data banks of dke of Ddmse Manpower Dseta Center, based any the skematiaa 69 you prwx ec , the &ove is the cmreat statusofilm "&i& as to all branches of $u Military. 4444" 0,21 )t it Mary M. Swrdy-Dixm Doctor Department o(Ddense - Manpower Data Center 1600 WisonBlvd., Suite 400 A *Io a, VA 22209-2593 T lie Defem Mae power Data Centex MhEX) is an orpenimfim of the Department ofD+e c that maintains the Defense Fmollment and Eftibft Reporting System (BEERS) database which a the *Sod source of data an edibility for military medical rare and ather tl 'ty systems. The Deprar ofDe fine stray supports the enforcement of the S abesrs Civet RaefAct 150 USCS App& §§ 301 et se q) (SCRA) Oormerly the Sates' and Sailors' Civil R Act of 1940)_ D?UDC has issued hm reds of 6onsandsof *does not possess any mformadw odica" that the umEmdad is cum mily an a responses, and has aqxximced a small arm rate. In the evert the iklvieinal rderenced Above, or any family member, friend, or reps re asses in any manner treat the individual a an active duty, or is cetheraise eulilled to the prolectionis of The SCRA, you are strongly enoonraged to obtain firdier verification cflhe persods fie duty status by conhicting th persoo!s Military Service via the 'drier kmil" M pronided below. If you have evidence the perms is cc active-duty and you fail to obtain ft adMond Military Service verillicadon,,. provinces of the SCRA may be invoked against yow i f you obtain about the person (+e-g., an SSK improved accuracy of DOB, a mine mute), you can submit your request again at Ibis Web site and we will proW& a new catIcale for drat quay. This response redects current active dirty stabs only. For histodcal xformahm please codact the Military Service SCRA points- at- contact See: bup flwww. aua16abis/PC09SLDR.bba WARK NQ Mis ecrtilicate was provi&d based on a name and Sock Security number (SSN) provided by the requester- Pro a% an erroneous or SSN will cause an erroneous oerificate to be prod. .tV0rt m B0WWX0WW 156390 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) ISHMAEL PALMER ) NO. 08-3082 To: ISHMAEL PALMER 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: June 18, 2008 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 -1i DA D J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR (KVCASE NO: 2008-03082 P COMMONWEALTH OF PENNSYLVANIA: rMMAAY t? COUNTY OF CUMBERLAND AR ROW FINANCIAL SERVICES LLC . 3 0 2008 VS PALMER ISHMAEL DENNIS FRY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PALMER ISHMAEL the ' s DEFENDAN'T' at 1113:04 HOURS, on the 17th day of May 200, at 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070 by handing to TASHA GREEN, GIRLFRIEND ADULT IN CHARGE 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 16.00 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 44.00 05119/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: 1-59 before me this _ __ day "deputy ?ieri? 1-11 of r A. D. ARY P ? 9 ( i 1 ? ?7 'tee ''T . 1^' _ r _ yr+ *1q.oo Po AT" C?? ??t558o?1 R a.? 114'1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ISHMAEL PALMER 1102 QUINCY CIRCLE NEW CUMBERLAND, PA 17070 ARROW FINANCIAL SERVICES LLC Plaintiff, vs. ISHMAEL PALMER Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY } NO.: 08-3082 Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a 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 4 JUDGMENT ON AWARD OF ARBITRATORS _ 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, EN. at this telephone number: 215-634-8920 8/100?