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Home My WebLink About08-4682Our File No.: 174537 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. JASON LEBEAU 37 PINE HILL AVE MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ORA1092 0'iyu-Fert, 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. JASON LEBEAU 37 PINE HILL AVE MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: DP- -it- F-Z C-0-4 7Z.- 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 JASON LEBEAU, an adult individual residing at 37 PINE HILL AVE MECHANICSBURG, PA 17050. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #0800601101028568; and said account was issued to Defendant(s) by HOUSEHOLD 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 $2,917.72. 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 $2,917.72 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & )4SSOCIATES, P.C. A Law Firm BY: Dated: 7/29/2008 J. Apothaker Our File No.: 174537 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 unsvy&r falsification to authorities. David J. aker Attorney r Plaintiff DATE: 7/29/2008 r w ARROW FINANCIAL SERVICES LLC JASON LEBEAU 37 PINE HILL AVE MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: JASON LEBEAU Account Number: 0800601101028568 Original Creditor: HOUSEHOLD BANK Balance Due: $2,917.72 Our File No.: 174537 EXHIBIT "A" 7p ? ? ? 00 g ? s ?' ??' i??? O . c cz> rT ? Z :^,» ( ?` ? C`;D T {"r': a ? ?_ ?' ,a ? - t - ms " ^ GJ ., s J .t ..?? ?. "? SHERIFF'S RETURN - REGULAR CASE NO: 2008-04682 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS LEBEAU JASON RONALD E HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LEBEAU JASON the DEFENDANT , at 0018:14 HOURS, on the 20th day of August 2008 at 37 PINE HILL AVENUE MECHANICSBURG, PA 17050 JAMES KLINEPETER a true and attested copy of COMPLAINT & NOTICE by handing to STEP-FATHER OF DEFENDANT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.00 Affidavit .00 Surcharge 10.00 .00 41b Y?IJ 8 ?,,, 38 . 00 Sworn and Subscibed to before me this day So Answers: R. 'Thomas Kline 08/21/2008 APOTHAKER & ASSOCIATES ??? By: Deputy Sheriff of A. D. Our File No.: 174537 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. JASON LEBEAU Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: . Kindly enter judgment against Defendant, JASON LEBEAU, in the default of an Answer, in the amount of $918.53 computed as follows: Amount claimed in complaint: $ 2,917.72 Less: Amount Paid: ( 2,003.00) Plus: Interest from July 29, 2008 to March 22, 2010 at the legal interest rate of 6.00% per annum 3.81 Attorney fees 0.00 TOTAL I certify that Defendant, JASON LEBEAU, MECHANICSBURG, PA 17050. Dated: March 22, 2010 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4682 Civil Action David J."Apothaker, Esq. Attorney for Plaintiff 918.53 is 37 PINE HILL AVE 414. oo PO A'r7q erg i7yyA? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JASON LEBEAU 37 PINE HILL AVE MECHANICSBURG, PA 17050 ARROW FINANCIAL SERVICES LLC Plaintiff vs. JASON LEBEAU COURT OF COMMON PLEAS OF } CUMBERLAND COUNTY NO.: 08-4682 Civil Action, Defendant 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 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 Esc. at this telephone number: 800-672-0215 )u'q 411*10 Our File No.: 174537 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 COURT OF COMMON PLEAS OF ARROW FINANCIAL SERVICES LLC ) CUMBERLAND COUNTY Plaintiff } VS. ) NO.: 08-4682 JASON LEBEAU ) Civil Action Defendant ) CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the n lties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. r'David J. Apothaker, Esq. Attorney for Plaintiff Dated: March 22, 2010 Our File No.: 174537 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. ) JASON LEBEAU ) } Defendant ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4682 Civil Action 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 37 PINE HILL AVE MECHANICSBURG, PA 17050. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 222071 93, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the De ens Manpcvwer Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in t miliU(ry. David J. Apothaker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Department of I3deruc Manpower Data Center Islar-22-2010 10:40-46 b1iLtwy Status Report PurAmut to the Smicc Mm6t" Civil Relict Act 4 last h?rstl %kUe Bb& Date Attire Dater States Attire Doh Ead Date s`r'?= 1\arre LESEAU JASON Based dm the kfatmakimyou have fiant&hnj the D'aIDC duce tic t possess an xmatiorr indicating the id6idtrat stirs UPort szardWS & infotmat an data banks of the Depatuent of Dekw Manpower Dann Center, based on the iafaa>bn !bait you provideu3 the abme is the Current status of the idnidual as to ark branches ofthe t;ruidxared Smites (Army, li'av f, h,iaci w Carps, Air Force, NOAA, Pubic Health, and Coast Guard). %AL 'Thut A Nfnrv?4f. Soav*-Dome, Director Depwtmem of Dd?nse -' tvVo%-cr Dam Center IW Wd on Rh C Swe 400 Admgtom VA 22249-2543 The Defense Magponer Data Cartes (DNMC) is an con of the D nent ofDdease that manxains due DeAm, Enrol- and Oigibility Reporting Spsum (DEERS) database veirich is the infidel source of dam can el y for military nuAcal rare and other e>r, systems. The DOD s supports the rriforeamefe of the Selvw-c Members CM REkrf Act (50 USC App- §§501 et seq, as amended) (SCRA) (formtsfy known as the Sold ers7 and Sailors' CH RCWAct of 194Q). MMDC has issued hundreds of dads of 'does to possess any i nfurma bon iodicahn that due i ul VidWal is evtrrody on Wi%V day* responses, and has elueriecced a t mut rate. In the e%vm the s>&idaal reftrm-ed ahmv,. or any fim*- member, friend, cw repres ntali? a ass eri5 in mrr manner that die individual is on actrvr darn, or z otherwise catitkd to the protections of the SCRA, you are stron8fy to coorAgrdl to Obtan firt}ter',w66cabm of the persons saxes b} coatanq dw person s Smite v- %he'defs?selark.mil" liRL wzs?= de£ensef _s i nis PC09SL1)g 1 if')w have ss dt ace the person is on active c1utiy and you failto vbraia treats additio al Service S?catiea pm3ive proviams c£ffie SCRA mazy be imokedagainst you. See M IsSC App. §52I(c)_ if you obtain meant iibtrnution about the persnss (e.;, an SSti, improved accuracy o( DOD, a middle oaaae), you Caps sukraa your rcgwst again at das Web site and we wA prrnide a new ?cat£cate for 9wry. This respoase reflects active data states itcb&q [late dw iu&id as was last on ac&e deity, fit was v6din the preceding 367 days, For historical i formation please caatact the Service SCRA points-of-contact- More ipvwwwlion on 'Active Dirt} SAM" " ? Active duty status as rested in dos certifier is defined in accordance, with 10 LSC § 10-1J(4)(1) for a period a'mere than 30 consectnvt days. In the case of a member of due :Vaboad Guard, indbdes smite under a tail to active service andrarized by die President or the S?m??eatmJ` of Defetm for a period ofstern. thou 30 coutcuttKt days tinder 32 USC § 5420 for purposes at' responding to a national emergency declared by the President and Rr44xxwd by Federal finds Al ?A.ctk r Guard ResmT (A?G?R') members rant be assigned against an authorized nxAmlzation position it the unit the) support 'Ibis includes lea -t TARS,Nfa ne Corps ARs and Coast Guard RPAs, Active DiAl status also des to a Vnifbr d Service nrrrabe'r who is an wtkv ca,rarissioaed olfiar ofc d.?i,e L. S. P*6C Heakh SMice or the National Oceanic and Atmospheric Adm istration (?£d! `OAA C sicaed Co") for a period cf acme dum 30 mutt ,r days, C4-vnwe l i skr the .SCiYA L4 ?B?r?o?ader is Sa*v Casa Cmrrar under the SCRA is brow. -r in some cases and includes some categorus ofpersons on active duty for purposes of the SCRA who awl not be reported as our Aetna h th ty trader this certidc&r. _Marx) taxes orders are amended to extend dw period of activr duty, '%ta would rut end SCRA protections- Persons seeking to rely on this u ebstt ce:t is thou should check to nuke! arc the orders on which SCRA protrctiwts are batted h2we not been amended to extend the ix-lusim dates of service. Furtherawre, save protections of the SCRA may eateod to persons %ho hate r eceitrd orders to report for settee day or to be inducted, but who have not achmAy began active duty or actm$y reported for ixfik- on. The Last Date on Active they catty is important because a number of protections of SCRA extend beyond the last date% of active duty. Those V Aso would rely en this certificate art urged to scdc gtraified kM counsel to ensue that all rights gesrrarred to Service members wul t the SCRA are protected WARND Cr T}is cnti6caoc was provirkd based on a name and SSI4 prrni lyd by the regncsta_ Pro %d ing an erroneous nemc or SS's wil cause an erroneous eertdieate to be parwided. Report ULN78CADOFT 856 780.1000 856 780.1020f 215 634.8920 215 634.8421f 174537 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) JASON LEBEAU } NO. 08-4682 To: JASON LEBEAU 37 PINE HILL AVE MECHANICSBURG, PA 17050 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 20, 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 DAVID J. A OT AKER, 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