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Home My WebLink About08-3715Our File No.: 167374 . 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. BRADLEY HUTCHINS 56 MIDDLE SPRING RD SHIPPENSBURG, PA 17257-8610 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: e?e - .3 71,5 l:. ii '7ZL, 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. 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 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. BRADLEY HUTCHINS 56 MIDDLE SPRING RD SHIPPENSBURG, PA 17257-8610 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 01. 3-7/5 Ct,?,-! mac-. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ARROW FINANCIAL SERVICES LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are BRADLEY HUTCHINS, an adult individual residing at 56 MIDDLE SPRING RD SHIPPENSBURG, PA 17257-8610. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185867933470321; and said account was issued to Defendant(s) by WASHINGTON MUTUAL BANK, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $2,072.60. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,072.60 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTH=R SS CIATES, P.C. Atto y for P aintiff A Law Firm E aced ' Debt Co ctiol BY: J. Dated: 6/17/2008 Our File No.: 167374 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 David J. A`plothaker Attorney for Plaintiff DATE: 6/17/2008 BRADLEY HUTCHINS ARROW FINANCIAL SERVICES LLC 56 MIDDLE SPRING RD SHIPPENSBURG, PA 17257-8610 STATEMENT OF ACCOUNT Debtor's Name: BRADLEY HUTCHINS Account Number: 4185867933470321 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $2,072.60 Our File No.: 167374 EXHIBIT "A" co a ? r? r-? OV13 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03715 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS HUTCHINS BRADLEY KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn says, the within COMPLAINT & according to law, NOTICE was served upon HUTCHINS BRADLEY DEFENDANT the at 1700 HOURS, on the 26th day of at 56 MIDDLE SPRING ROAD June 2008 SHIPPENSBURG, PA 17257-8610 GARLAND by handing to HUTCHINS, FATHER 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 Service Affidavit surcharge 17/b x1o ? 18.00 20.00 .00 10.00 .00 48.00 So Answers: R. Thomas Kline 06/27/2008 APOTHAKER & ASRnrTnrran Sworn and Subscibed to before me this day of By: ?__ A.D. 9 Our File No.: 167374 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. BRADLEY 1 UTCHINS Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3715 Civil Action PRAEC1 PE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, BRADLEY HUTCHINS, in the default of an Answer, in the amount of $2,170.00 computed as follows: Amount claimed in complaint: $2,072.60 Amount Paid: - $(0.00) Interest from June 17, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $97.40 Costs $0.00 Attorney fees $0.00 TOTAL $2,170.00 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, BRADLEY HUTCHINS, last know address is 56 MIDDLE SPRING RD SHIPPENSBURG, PA 17257-8610. APOTHAKER & Attorneys A Law Firm Emu By: David J. TES, P.C. Debt Collection Dated: 5/14/2009 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: BRADLEY HUTCHINS 56 MIDDLE SPRING RD SHIPPENSBURG, PA 17257-8610 ARROW FINANCIAL SERVICES LLC Plaintiff, VS. BRADLEY HUTCHINS Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3715 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 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 s?r??oq Our File No.: -167374 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. BRADLEY HUTCHINS NO.: 08-3715 Defendant. 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 am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 56 MIDDLE SPRING RD SHIPPENSBURG, PA 17257-8610. 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 Defense indicated that the Defendant(s) is/are not in the military. David J. Apk t} - Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. Data Cenjar 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. Department of Defense Mower Data Center MAY-14.2009 09•,36:24 Witery Std Rgxd Pursuant to the Ses vice ere Civil ReW Act -777=7717771-- V-: HUTCHINS BRADLEY Based on the it formd m you have f mashed,, the DMDC does m possess any m*xmadon that the inc vkW is +curra* m actim duty. 6 Upon searching the ifor mstim data banks of de Department of Defense Manpower Data Center, based on the iafoem ew dnd you provided, the above is the cunrert stirs of the i?di~+i %d as to al branches of the Millacy. NOV. Mary M Sam* Dutton. Director Department: of Delrmse - Manpower Data Center 1600 Wilson BML, Site 400 Aringtoo, VA 22209-2593 The Defesse Manpower Data Cesar (DMQ is as " oqpazatioa of the Dqwlmxd cf ire that maintains the Defimse Ergo aeaat and E fg ty Reporter System (!DEERS) database whKh is the +af cW some of data on e%W for mitary medical care and other a ASW systems. The Department of Demise shoogly sapparL the edweemment of the Se rvicemeniv rs Civic ROWAct [50 USCS Apps_ §§ 501 et seg] (SCRA) bane ly the Sa die& and Sailors' Chi RAdAct of 1940}_ DIM bas, issued hooclred s of dwasands of 'does not possess any is m indicating that the iddickal h curdy on active duty" re es? and has ltd a smal error ratc_ In the event the intgv dud refermced above, or any fawAy member, dead, or representative asserts in any Amer chit the ndnaided is on active duty. or is odor uioe esMed to the protections of the SCRA, you are skou* encouraged to obtain fzdmr verficadon of the person's active duty stye by rantsc ft that persva's Mlit ry Service via the'defr .nir URL p+ovk ed below. If you have evidence the person is an active-duty and you fad to obtain this addttiaasl MF&Ky Service veri6catim prcwidaas of the SCRA may be kffcked mast you. Myou obta o>ardw oformdtiart about the person ( e.g., an SSN, inproved accuracy of DOB, a nacicge name), you can subnsit your request ate at dtis Web site and we wi provide a new certif a for that query. This response reliects curra t aecbm dray std only. For historical olormation, please contact the Mikiry Service SCRA ponu- of-Conk ct. Sex: howthywWdefensefik WARN M This cesfiFicate was provided based on a rye and SocW Security number (SSN) prov;ded by the rem. ProvAng an erroneous same or SSN wN cause an earmeous cerilcate: to be provided. Rapatr,lD:B"nWW D 167374 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) BRADLEY HUTCHINS ) NO. 08-3715 To: BRADLEY HUTCHINS 56 MIDDLE SPRING RD SHIPPENSBURG, PA 17257-8610 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: July 28, 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 D I 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 CASE NO: 2008-03715 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ? JUL ARROW FINANCIAL SERVICES LLC ! 8 2008 L.1 VS_ HUTCHINS BRADLEY KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT,& NOTICE was served upon HUTCHINS BRADLEY the DEFENDANT at 1722:00 HOURS, on the 26th day of June 2008 at 56 MIDDLE SPRING ROAD SHIPPENSBURG, PA 17257-8610 by handing to GARLAND HUTCHINS, FATHER 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 20.00 Affidavit .00 Surcharge 10.00 .00 48,00 Sworn and Subscibed to before me this _ day So Answers: R. Thomas Kline 06/27/2008 APOTHAKE By: of , A.D. 2[;09 MAY Y 19 p Tl 3: 4 9 jT. y glAj. 06 -??L eKaaL / 347LS }?? a.253sp k)c.,4. f te- ma I LL