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Home My WebLink About08-5611Our File No.: 181779 ,%kPOTHAKER & 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. RODNEY HERSHEY 42 CONRAD RD CARLISLE, PA 17015-8854 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08 - ZI/ ei z L?T? 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 Our File No.: 181779 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. RODNEY HERSHEY 42 CONRAD RD CARLISLE, PA 17015-8854 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.:ov-SZli?`" 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 RODNEY HERSHEY, an adult individual residing at 42 CONRAD RD CARLISLE, PA 17015-8854. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185862648397513; 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 $4,001.09. 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 $4,001.09 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. ASSOCIATES, P.C. for Plaintiff A Law Firal Enla2ed in Debt Collection BY: Esquire Dated: 9/15/2008 Our File No.: 181779 VERIFICATION David J. Apothaker, 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. made subject to the penalties of 18 Pa.C.S.A. 4904, undersigned understands that the statements therein are to unworn falsification to authorities. Apothaker, Esquire uev for Plaintiff DATE: 9/15/2008 RODNEY HERSHEY 42 CONRAD RD CARLISLE, PA 17015-8854 STATEMENT OF ACCOUNT ARROW FINANCIAL SERVICES LLC Debtor's Name: RODNEY HERSHEY Account Number: 4185862648397513 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $4,001.09 Our File No.: 181779 EXHIBIT "A" V (y? ? ? l V C;) 'v O ^o rh ?. _ ITJ Q4 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05611 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS HERSHEY RODNEY NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HERSHEY RODNEY the DEFENDANT , at 0922:00 HOURS, on the 20th day of October , 2008 at 42 CONRAD RD CARLISLE, PA 17015-8854 RODNEY HERSHEY by handing to 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 25.00 Affidavit .00 Surcharge 10.00 00 /o/2P fog, 5 Sworn and Subscibed to before me this day So Answers: io0eaeow0eat le? R. Thomas Kline 10/21/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff of A. D. Our File No.: 181779 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. RODNEY HERSHEY Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5611 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, RODNEY HERSHEY, in the default of an Answer, in the amount of $4,122.21 computed as follows: Amount claimed in complaint: $4,001.09 Amount Paid: - $(0.00) Interest from September 15, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $121.12 Costs $0.00 Attorney fees $0.00 TOTAL $4,122.21 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, RODNEY HERSHEY, last know address is 42 CONRAD RD CARLISLE, PA 17015- 8854. APOTHAKER & AS IATES, P.C. Attorneys f r P ' tiff A Law Firm Engag d ' Debt Collection By: David J. Apothaker Dated: 5/14/2009 OF THE 2009 MAY 19 Pl,,,l 5, 54 Cf it Et ! TO: RODNEY HERSHEY 42 CONRAD RD CARLISLE, PA 17015-8854 ARROW FINANCIAL SERVICES LLC Plaintiff, vs. RODNEY HERSHEY Defendant. NOTICE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5611 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, Esc. at this telephone number: 215-634-8920 Our File No.: 181779 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. RODNEY HERSHEY Defendant. Civil Action AFFIDAVIT OF NON-NULITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5611 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 42 CONRAD RD CARLISLE, PA 17015-8854. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if thV Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. Apothaker Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. 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. DepmrUmmakof Defimse Manpower Data Center MAY-14-200910 2:44 Upon searching The banks of the Departumeot of 3sfeme Mmpawer Data Coder, bared an do i&mudm i you prov+ dedL the above is the current status of dhe individual as to A branches of the N y. ObutA. f4..-J-"-f*-- Mary M. 5mviefY: Dews. Director Dew v'D dose - Mmpower Data Center 1600 Wilm1 ; S k 400 VA 22209-2393 The Defimse Mwporwer Data Center (MM is an oqpnumdm of the Depar tueat c(Defimse dot maintains the Deftme watt and WAY Rgmding Systma (DEERS) database is the aa" ?esa` t source ofdata on c aik) far a Txy =Avg care and odx r e§gW systerms_ The Department of Definse ao r supports the edorrementof S,i*rpmL-n}xrs Cid Refie! Act _M USCS Apex §§ 381 et sect (SCRA) aamoerly the Sai&e& and Saailod Relief Act of 194tf}_ DMDC has issued huardre& of &oussrads of *does not possess any inibramaeb n indicating tube ind"n a curxeotllr an arrive dry' respooses and has experienced a smaat error rate. In the event the sorv &d referenced above, at any family uaear Aw, fiiendL at tepreseotaiive asserts is manaoer that the imliividaal its an active dirty, at is athawi m eotided to the protectim of the SCRA, you we strongly encouraapd itD obtain farthear. Sian of the persod s, active duty by coaRactiog that person's Wary Service via the "d bk-tur URL provided below. Myon have evidence the tangy is an actim- fir and you fid to obtain this add Wong Military Service verfra , provisions. the SCRA may be invoked age yam. Xyou obtain Amfiier information about the person (,e g., an SSN, improved accuracy of DOH, a middle oeaaae). you can submit yom reqmest again at this Web site and we wit pmvW a new cue far that quay. Ilms response reSCcts current active duty stems only For historical xfasmatioo, plea contact the Ailkary Service SSCRA poi ts- af=contact. See: hWJlwww: S ht WARNMCk 7b is certificate was provided bond on a nacre amd Social Security camber (SSM pravidaasd by the requester. Provii ft an rea<rone same or SSN wR cause an emoncous catilicate, to be provided. lry Status Report Purssmat tars the Searvieena hers CM Reliief'Act 181779 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) RODNEY HERSHEY ) NO. 08-5611 To: RODNEY HERSHEY 42 CONRAD RD CARLISLE, PA 17015-8854 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: December 16, 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 . 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 V'\ CASE NO: 2008-05611 P fl' COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS HERSHEY RODNEY L7 L? OC f 3 1 1?il1 NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HERSHEY RODNEY the DEFENDANT , at 0922:00 HOURS, on the 20th day of October , 2008 at 42 CONRAD RD CARLISLE, PA 17015-8854 by handing to RODNEY HERSHEY 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: So Answers: Docketing 18.00 .+.? Service 25.00 ?rrv+?•k Affidavit 00 ' Surcharge 10.00 R. Thomas Kline .00 53.00 10121/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By; before me this day Deputy Sheriff of , A.D. FILE OF THE F r, ' '.4i^ITAPY 2009 I'lAY 19 C h ": . 0 t, 14 ?c nn g 7`d . ?1 i3y?sr a ? ?-3Gy