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Home My WebLink About08-3718Our File No.: 167342 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. JONATHAN F BEHRENS 2427 BUMBLE BEE HOLLOW RD MECHANICSBURG, PA 17055-5693 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Dg - 3718 0,'m t lerlk 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 r 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. JONATHAN F BEHRENS 2427 BUMBLE BEE HOLLOW RD MECHANICSBURG, PA 17055-5693 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0k- 37 /? CtA?.! -7;A- 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 JONATHAN F BEHRENS, an adult individual residing at 2427 BUMBLE BEE HOLLOW RD MECHANICSBURG, PA 17055-5693. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #044842918; and said account was issued to Defendant(s) by MCINTOSH COLLEGE INC., 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 $4,792.08. 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. V, WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of . $4,792.08 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER &/ASSIOCIATES, P.C. A Law Firm Erkaged In Debt BY: Dated: 6/17/2008 Apothaker Our File No.: 167342 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 unswopfVsification to authorities. David J. AI Attorney for DATE: 6/17/2008 JONATHAN F BEHRENS ARROW FINANCIAL SERVICES LLC 2427 BUMBLE BEE HOLLOW RD MECHANICSBURG, PA 17055-5693 STATEMENT OF ACCOUNT Debtor's Name: JONATHAN F BEHRENS Account Number: 044842918 Original Creditor: MCINTOSH COLLEGE INC. Balance Due: $4,792.08 Our File No.: 167342 EXHIBIT "A" O t W 61, -n D c- . hJ i r 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03718 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS BEHRENS JONATHAN F R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BEHRENS JONATHAN F but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , , NOT FOUND , as to the within named DEFENDANT BEHRENS JONATHAN F 2427 BUMBLE BEE HOLLOW RD MECHANICSBURG, PA 17055-5693 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO SERVE PRIOR TO EXPIRATION. Sheriff's Costs: So answers: Docketing 18.00 Service 40.00 Not Found 5.00 R. homas Kline Surcharge 10.00 S eriff of Cumberland County 00 73.00 APOTHAKER & ASSOCIATES 07/23/2008 Sworn and Subscribed to before me this day of , A. D. Our File No.: 167342 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff ARROW FINANCIAL SERVICES ) LLC ) Plaintiff, ) VS. ) JONATHAN F BEHRENS ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3718 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for4laintiff A Law Firm Enizag$fl ii Debt Collection By: David J: Dated: 7/31/2008 +v Q CID m, r,- t o d