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HomeMy WebLinkAbout08-5411Our File No.: 178625 `APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. ALBERTO L GARCIA 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OS- 5411 NOTICE ?ivil (terY?? 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 A Our File No.: 178625 "APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. ALBERTO L GARCIA 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 07-`q/i CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ARROW FINANCIAL SERVICES LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are ALBERTO L GARCIA, an adult individual residing at 250 E CRESTWOOD DR APT A 1 CAMP HILL, PA 17011-1201. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #C81923391339910; and said account was issued to Defendant(s) by GE CAPITAL, 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 $2,372.44. 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 $2,372.44 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Engz RTES, P.C. Debt BY: David J. Ap*aker, Esquire Dated: 9/5/2008 Our File No.: 178625 VERIFICATION David J. Anothaker. Esquire 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 rAa ng to unworn falsification to authorities. David J. APthaker, Esquire Attorney for Plaintiff DATE: 9/5/2008 ARROW FINANCIAL SERVICES LLC ALBERTO L GARCIA 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201 STATEMENT OF ACCOUNT Debtor's Name: ALBERTO L GARCIA Account Number: C81923391339910 Original Creditor: GE CAPITAL Balance Due: $2,372.44 Our File No.: 178625 EXHIBIT "A" * Od ? o O 3 G* 1 ?r .44 CA) N ? 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05411 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS GARCIA ALBERTO L 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 GARCIA ALBERTO L the DEFENDANT , at 1518:00 HOURS, on the 16th day of September, 2008 at 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201 by handing to RICARDO GARCIA, SON 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 15.00 Affidavit .00 Surcharge 10.00 00 Io??Z f UY ??'^ 43.00 So Answers: R. Thomas Kline 09/17/2008 APOTHAKE" & ASSOCIATES Sworn and Subscibed to By: before me this day of A.D. ' Our File No.: 178625 APOTI)AKER & ASSOCIATES, P.C. BY: David J. Apol[haker 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 Plaintiff, ) CUMBERLAND COUNTY VS. ) NO.: 08-5411 ALBERTO L GARCIA ) Defendant. ) Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, ALBERTO L GARCIA, in the default of an Answer, in the amount of $2,426.53 computed as follows: Amount claimed in complaint: $2,372.44 Amount Paid: - $(0.00) Interest from September 05, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $54.09 Costs $0.00 Attorney fees $0.00 TOTAL $2,426.53 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, ALBERTO L GARCIA, last know address is 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201. A Law Firm By: David T. SOCIATES, P.C. - Plaintiff in Debt Collection Dated: 5/14/2009 Our File No.: 178625 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. ALBERTO L GARCIA Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5411 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 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201. We inquired with the web site of the Defense er Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the efe t(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defen M power Data nter has sent back our inquiry indicated that the Defendant(s) is/are not in the milit David J. A aker Attorney for Plaintiff 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. Depub neot of Defi,wse Mupower Daft Center wry Sys Report Parsuant to die Servicemembers Civil Relief Act Awl a ?-?i-?- Mary M. Snsvely-Dixon, Director D w nneot of D&nse Ma power Data meter 1600 Nilson leis Same 400 Ardngl m VA 22209-2593 MALY-14-200910 W.14 T'he Drlease Mower Data Coma (D1 ) is eac " cf the D+ei t of Defame fat maintain &c Defense E meat and Ef y Reporting System (DEERS) die wt a Abe official source c(deft on c sty for =Iiikary me&A care and od xw elgiWk systems. The Department of De knse *m* sWods the enforcement osf the Servicedme+mbers Civil RaWAct (30 USC,S Apm if 501 et seq) (SCTtA) (I'I'armedy the Soles' and SaW Civil R:ed dAct of 1940)_ DWDC has is bani1reds cf diousands, of'doe:s not possess any iafocnation indeadog`tbat the i dWinal is coma* an acne duty' responses, and has a imced a smal errar ram. In the event the indn itio d reli reeocexd above, at any facer annul. Mwd, or representative asserts in any mower that the iiadividual is an active duty, or is of se eluded to the moos of the SCRA, you are stmu* encouraged to obtain fiffdw ve on ofthe persads, active linty staff by contacting duat pe on"s hfikory Service via the "defimiefik rte" URL provided below. Ifs have evidence the persm is on active-daty and you fid to obtain lids adiSdocal hilitary Service veri6cNion, provisions ofthe SCRA may be invoked against you. If you obtain about the person ( e.g., an SSN, improved many of DOB, a m ode name), you can subast your request again at this Neon site and we wil4prorvide anew certificalte for riot query. This response rem =rent achy a dusty stabs only. For kisoncal , pipe contact the lt+d kory Service SC RA poiats- of-eoutact. Sec; btkOlwww m ` PC09SLDRJft l WARNDI'Cr This calfiicate was provided based ion a name and Social Se ewity umber (SSN) provided bey the rewesw. Providing an enmeous same or SSN wM owe an mawous roa die to be pr iced. RapO"MjMW n V"LT Upon scorching the " inkunifton data basks of be Deartmect of Ddease Mmpower Dek Cenfex, based on the idRunation that you provid A the above is the cu iTent status of the individual as to all branches of the Afib ary. 178625 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) ALBERTO L GARCIA ) NO. 08-5411 To: ALBERTO L GARCIA 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 23, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR D I J. APOTHAKER, ESQUIRE AP T KER & 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 CCASE NO: 2008-05411 P COMMONWEALTH OF PENNSYLVANIA: ?----? COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC ' SEP 3 ? VS GARCIA ALBERTO L 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 GARCIA ALBERTO L the DEFENDANT at 1518:00 HOURS, on the 16th day of September, 2008 at 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201 by handing to RICARDO GARCIA, SON 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 15.00 Affidavit .00 Surcharge 10.00 .00 43.00 So Answers: R. Thomas Kline 09/17/2008 APOTHAKEn & ASSOCIATES Sworn and Subscibed to By: before me this day of , A. D. THE L..4Yl llf?.! 40 „t J? - Po ?,r? tay153 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ALBERTO L GARCIA 250 E CRESTWOOD DR APT Al CAMP HILL, PA 17011-1201 ARROW FINANCIAL SERVICES LLC Plaintiff, VS. ALBERTO L GARCIA Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5411 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 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 'SAU/0?