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HomeMy WebLinkAbout08-4681Our File No.: 174566 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. HARVIE F SHRINER 114 HERSHEY RD SHIPPENSBURG, PA 17257-9485 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OB - Qo$1 NOTICE cYou 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. HARVIE F SHRINER 114 HERSHEY RD SHIPPENSBURG, PA 17257-9485 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D r.- qG Pl C a 1 ta.•? 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 HARVIE F SHRINER, an adult individual residing at 114 HERSHEY RD SHIPPENSBURG, PA 17257-9485. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account 44254490600574675; 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 $5,135.40. 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. 4 WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of V $5,135.40 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOVAIES, P.C. Attorney for A Law Finn Engaged i BY: David J. Dated: 7/29/2008 Our File No.: 174566 I a . VERIFICATION David J. Apothaker, Esa. 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 understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to falsification to authorities. David J. Apothaker Attorney for Plaintiff DATE: 7/29/2008 ARROW FINANCIAL SERVICES LLC HARVIE F SHRINER 114 HERSHEY RD SHIPPENSBURG, PA 17257-9485 STATEMENT OF ACCOUNT Debtor's Name: HARVIE F SHRINER Account Number: 4254490600574675 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $5,135.40 Our File No.: 174566 EXHIBIT "A" ? ? CTI _ '?' R' .. p ?=? ri ? $ b ? ? - rra ?? ? _ ? ? ?_ ; ? SHERIFF'S RETURN - REGULAR CASE NO: 2008-04681 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS SHRINER HARVIE F MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHRINER HARVIE F the DEFENDANT at 0018:44 HOURS, on the 12th day of August , 2008 at 114 HERSHEY ROAD SHIPPENSBURG, PA 17257 by handing to HARVIE F SHRINER DEFENDANT 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 V 48.00 Sworn and Subscibed to before me this day of , So Answers: R. 'Thomas Kline 08/13/2008 APOTHAKER & ASSOCIATES --- By: Deput Sh riff A. D. Our File No.: 174566 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. HARVIE F SHRINER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4681 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, HARVIE F SHRINER, in the default of an Answer, in the amount of $5,341.02 computed as follows: Amount claimed in complaint: $5,135.40 Amount Paid: - $(0.00) Interest from July 29, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $205.62 Costs $0.00 Attorney fees $0.00 TOTAL $5,341.02 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, HARVIE F SHRINER, last know address is 114 HERSHEY RD SHIPPENSBURG, PA 17257-9485. APOTHAKER & Attorney A Law Firm Eng By: David J. TES, P.C. Debt Collection Dated: 5/14/2009 ti OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: HARVIE F SHRINER 114 HERSHEY RD SHIPPENSBURG, PA 17257-9485 ARROW FINANCIAL SERVICES LLC Plaintiff, VS. HARVIE F SHRINER Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4681 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 TIES NOTICE, PLEASE CALL: ATTORNEY David J. Anothaker, EN. at this telephone number: 215-634-8920 s1zc%9 r_ Our File No.: 174566 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, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4681 Civil Action Defendant. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND 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 114 HERSHEY RD SHIPPENSBURG, PA 17257-9485. VS. HARVIE F SHRINER We inquired with the web site of the Del Boulevard, Suite 400, Arlington, VA 22209-2593, i Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. Apothaker Attorney for Plaintiff Data Center, located at 1600 Wilson isVare in any branch of the military. Data 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. Deparuneat of Defense Maflpower Data Center MA°Y-14-2009 0934:52 Millary Static Rgpcet Pursuant to the 5ervc s Chi ReWAct SHRVQR IRARVIEF lBasedoudw in6bumationyou h m fismished, the DUM dace not possess any ifinmetim iod g that the imiividaal is currently on active duty. Upon searching the irfanamiiam dda banks of the Depas t of Defuse Maapowe r Data Ceder, based an the wham bon that you provided, the above is the current sus ofthe indvidled as to al branches of the h i r. 0112V Mary X Sum ely DvAmk Director Depertmmt of Defense - A mpywer Data Center 1600 Wbon Blvd-, mite 400 Arm, VA 22209-2593 The Defamse Nlar er Data Coaster (MWQ is an ownimak on of the D!epet c(Delse that ammintains the Defense Enrohme t andEligt'billity Rgawcmiag System MERRS) dd&ese which. is the sow= o(datann gtyfor Mary meScal ere and other eloility systexm. The Depurknest of D?ef'ense *,om#y meta the enicree meat of the Seri icrssteioI A Creel IteliefArt [SCI USCS Affc §§ 501 et seq] (SCRA) medy the Sd&ers' and Saibts' CK ReSdAcdt of 1940}_ DMDC has issued h mdm& of thousands of *does not possess any infarrumbon k dicatiag`dw the individual a currently an active daty" oases,, and has experienced a sma error rate, In the event the imlivi&W rdmm?ed above, or any hmily der, Mend. or repel asserts in any guanner, that the individod is on active duty, or is otherwise entitled to the protections of the SCRA, you we stroo* a moused to obtain further verilication cfthe persods active duty status by contacting that person's Miktary Service via!the "ddm noT t7RL provided below. Nyon have evidence the person is on actim-duty and you fag to obtain this addItionat wry Service v+e m provisiow of the SCR A may be invoked against you,. N you obtain fxdw information about the person ( e.g., an SSN, improved ae: c wacy of DOB, a minldle tame), you can submit your request mein at this Web site and we wR provide anew cargo see for that eery . This response reflects current active duty stag,* Forbatoncal dim pipe contact the Witary Service SiCRA pelots- of-contact. See: httpdhvww t.ml WmlC09SLDR..htod WART IG This c cakc was provided base d o>n a namw and Sew Security »ber (SSN) provided by the requester. Providing an aroneoms same or SSN wit cause an arooeaus rertilicute to be provided. Rap*rrl,MMAlr WG 174566 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) HARVIE F SHRINER ) NO. 08-4681 To: HARVIE F SHRINER 114 HERSHEY RD SHIPPENSBURG, PA 17257-9485 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 15, 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 \A - DAWN. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 . SHERIFF'S RETURN - REGULAR S NO: 2008-04681 P Al/a 1 COMMO'NWEAL'TH OF PENNSYLVANIA : 1008 COUNTY OF CUMBERLAND IiJu jj ARROW FINANCIAL SERVICES LLC VS SHRINER HARVIE F MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT'& 140TICE ,was served upon SHRINER HARVIE F the DEFENDANT at 0018:44 HOURS, on the 12th day of August 2008 at 114 HERSHEY ROAD SHIPPENSBURG, PA 17257 by handing to HARVIE F SHRINER DEFENDANT 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 08/13/2008 APOTHAKER & ASSOCIATES ____- By: Deput Sh riff of A. D. FltlD-{ FiR0E OF xr C "' ; j" r,, ??TRY 4' 0 0911AY 20 A 10: 4 k GL.,,-, OV ,= y e ? ?. 'its 9 lA! • OD ?d-R4 cl?r ar7s8 ??tc. ri??CScI?