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HomeMy WebLinkAbout08-3083d1k Our File No.: 156633 AP,OTH1mXER & 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. EDMOND P SKINNER 526 SALMON ROAD MECHANICSBURG, PA 17050-2548 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 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 cone 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 41. APOTHAKER & ASSOCIATES, P.C. BYw 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. EDMOND P SKINNER 526 SALMON ROAD MECHANICSBURG, PA 17050-2548 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Of- -36" ?l 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 EDMOND P SKINNER, an adult individual residing at 526 SALMON ROAD MECHANICSBURG, PA 17050-2548. 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 $1,586.25. t 40- 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is LOWE'S CREDIT CARD. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,586.25 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER, Atto A Law Firm E BY: David SOCIATES, P.C. Plaintiff in Debt CoHie do Dated: 4/27/2008 Our File No.: 156633 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 to unsworn falsification to authorities. DATE: 4/27/2008 ARROW FINANCIAL SERVICES LLC c/o Apothaker & Associates, P.C. ' 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 EDMOND P SKINNER 526 SALMON ROAD MECHANICSBURG, PA 17050-2548 STATEMENT OF ACCOUNT Debtor's Name: EDMOND P SKINNER Account Number: C81923391353267 Original Creditor: LOWE'S CREDIT CARD Balance Due: $1,586.25 Our File No.: 156633 EXHIBIT "A" 5 iq. c C!p ' ? Q00 (? _ ?{ v 26 N ?C O SHERIFF'S RETURN - REGULAR CASE NO: 2008-03083 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS SKINNER EDMOND P MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT & NOTICE the SKINNER EDMOND P 2008 DEFENDANT , at 0830:00 HOURS, on the 17th day of May at 526 SALMON ROAD MECHANICSBURG, PA 17050-2548 ASHLEY FLECK, FRIEND by handing to 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 h - Service .00 10 :..,.? Affidavit .00 00 10 R. Thomas Kline Surcharge . 00 38 . 0 0 - 05/19/200 B & ASSOCIATES APOTHAKER Sworn and Subscibed to By: Deputy before me this day of A e A.D. riff Our File No.: 156633 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. EDMOND P SKINNER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3083 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, EDMOND P SKINNER, in the default of an Answer, in the amount of $1,668.31 computed as follows: Amount claimed in complaint: $1,586.25 Amount Paid: - $(0.00) Interest from April 27, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $82.06 Costs $0.00 Attorney fees $0.00 TOTAL $1,668.31 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, EDMOND P SKINNER, last know address is 526 SALMON ROAD MECHANICSBURG, PA 17050-2548. APOTHAKER AS TES, P.C. Attorneys&fo Pi tiff A Law Firm Engag in bt Collection By: David J. Apothaker Dated: 5/14/2009 Our File No.: 156633 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. EDMOND P SKINNER Defendant. Civil Action AFFIDAVIT OF NON-NULITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3083 : 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 526 SALMON ROAD MECHANICSBURG, PA 17050-2548. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the Mary M. Snavely-Dixon, Director of the Defens indicated that the Defendant(s) is/are not in the military, David J. Ajaker Attorney for Plaintiff Data Center, located at 1600 Wilson ) is/are in any branch of the military. 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 unworn falsification to authorities. Dqmbnmtof Defense Manpower Dats Ceta u Mary Status Report Pur a to the Services Civil Relief Act GSM Aim.. May IVL S -Dixon, Director Department of D efeuse - Manpowa Data Center 1600 Wilson Blvd- Suite 400 A:rntosi, VA 22209-2593 MAY-14-2009 09.2019 The Delem NbsWower Data Center (M is an oqpwkWm of the meat c(Definse 69 maintms, the Defense Facet and E *fky Reporting System (DEERS) database which a the official source of dam on ei*ilky fee vilitary medical corn and Odw e y systems. The Department of Defeynse *on#y supports the educe ut of the Se %keme sobs rs civil R efAct [50 USCS Appuc §§ sot et sexy (SCRA) (faddy the Soldiers' and Sailors' CM Reliief Ac t of 1940>. nADC bas, ism hundreds of thousands of -does not possess any man indicating that the individad is cnrr+eady at active duty" responses., and has experienced a saw error rate. In the event the individual ref6rwced above, or any fmaity ember, friend or representative asserts in my mama duet the ink is on active duty, or is adwwise entitled to the protections of the SCRA, you are skaq#y mad to obtain farther valicatim of the persods active duty stains by contacting person's Miitary Service via the'defimselieLmi' URL provided blow. N you have evidence the person is on active-day and you Cal to obtain thin additional liitary Service ica&wc provisions of the SCRA may be invoiced against you. Myoqu obtain fivdm information about the person ( e.g., an SSN. improved accuracy of DOB, a» name), you can submit yams request again at this Web site and we wit provide a new ovate for flat query This response reflects current active duty std only. For batx>lical " , please contact the May Service CRA poiots- of-contact. Seri htrlhyww:de.mi WARNINCr This cerfilicate was provided based on a none and Social Securky rimer (SSN) provided by the requester. Providing an e r eons name or SSN will cause an enowous certificate to be provided. RaportMA WCUPFCF" Upon Searching the i finnad n data banks of the Department of Defamse Maepavesr Data Canter, based on the x f xnmbm drat you provided, the above is the anent status of the iu>divia as to ad branches of the Icy. 156633 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) EDMOND P SKINNER ) NO. 08-3083 To: EDMOND P SKINNER 526 SALMON ROAD MECHANICSBURG, PA 17050-2548 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 DAV 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 41 CASE NO: 2008-013083 P tSl COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC MAY 3 4 z008 VS SKINNER EDMOND P MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SKINNER EDMOND P the DEFENDANT , at 0830:00 HOURS, on the 17th day of May _, 2008 at 526 SALMON ROAD MECHANICSBURG, PA 17050-2548 by handing to ASHLEY FLECK, FRIEND, 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 10.00 Affidavit 00 3...'Y Surcharge 10.00 R. Thomas Kline .00 38.00 05/19/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to BY: 1 before me this day Deputy eriff of A.D. 6 '?F "?` R LE D?Vyf C`am` r tEtrileF` `t? tv' ?ri p0 A-Tf# ao ??A r1nl OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: EDMOND P SKINNER 526 SALMON ROAD MECHANICSBURG, PA 17050-2548 ARROW FINANCIAL SERVICES LLC Plaintiff, vs. EDMOND P SKINNER Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3083 Civil Action NOTICE 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 JUDGMENT ON AWARD OF ARBITRATORS 06 _ 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. at this telephone number: 215-634-8920 5/&0/0?