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Home My WebLink About08-7380 Our File No.: 190840 AISOTHAKER & 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. DANIEL BUBB 3299 RITNER HWY # 2 NEWVILLE, PA 17241-9566 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08 - `1380 Cidi I -Iir v" 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 41 Our File No.: 190840 AhOTHAKER & 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. DANIEL BUBB 3299 RITNER HWY # 2 NEWVILLE, PA 17241-9566 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 f 73 96 C?;a- ??--- 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 DANIEL BUBB, an adult individual residing at 3299 RITNER HWY # 2 NEWVILLE, PA 17241-9566. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4559909700514457; 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 $3,294.11. 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. n 6. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,294.11 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS OC TES, P.C. Attorney f Pl 'tiff A Law Firm Enaaa in ebt Collectioi BY: David J. Apo'diaker, Esquire Dated: 12/15/2008 Our File No.: 190840 W 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. The and ' ed understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relatin to worn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 12/15/2008 ARROW FINANCIAL SERVICES LLC DANIEL BUBB 3299 RITNER HWY # 2 NEWVILLE, PA 17241-9566 STATEMENT OF ACCOUNT Debtor's Name: DANIEL BUBB Account Number: 4559909700514457 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $3,294.11 Our File No.: 190840 EXHIBIT "A" +# 000 4 CZ) 1 D C.) MJ T t J ^ SHERIFF'S RETURN - REGULAR CASE NO: 2008-07380 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS BUBB DANIEL 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 MTTnM nANTTVT. the DEFENDANT , at 1603:00 HOURS, on the 23rd day of December-, 2008 at 3299 RITNER HWY #2 NEWVILLE, PA 17241-9566 by handing to DANIEL BUBB 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 10.80 Affidavit .00 Surcharge 10.00 00 38.80 Sworn and Subscibed to before me this day of So Answers: ?_o R. Thomas Kline 12/24/2008 APOTHAKER & AS CIATES By: De"uty Sheriff A. D. . Our File No.: 190840 APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS OF Plaintiff, ) CUMBERLAND COUNTY vs. DANIEL BUBB Defendant. TO THE PROTHONOTARY: NO.: 08-7380 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, DANIEL BUBB, in the default of an Answer, in the amount of $3,505.40 computed as follows: Amount claimed in complaint: $ 3,294.11 Less: Amount Paid: ( 0.00) Plus: Interest from December 15, 2008 to August 12, 2009 at the legal 93.99 interest rate of 6.00% per annum Attorney fees 0.00 TOTAL $ 3,505.40 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, DANIEL BUBB, last known address is 3299 RITNER HWY # 2 NEWVILLE, PA 17241- 9566. APOTHAKER & AS O IATES, P.C. Attorneys f Pl intiff A Law Firm Engage in ebt C ectioi By: David J. Apothaker Dated: August 12, 2009 Our File No.: 190840 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 vs. Plaintiff, DANIEL BUBB Defendant. 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 3299 RITNER HWY # 2 NEWVILLE, PA 17241-9566. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if tv Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7380 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 unworn falsification to authorities. APOTHA'KE'R& ASSOCIATES, P.C. ATTORNEYS AT LAW Department of Defense'vlanpower Data Center 40 teary Status Repot Pmt to the Serxicemembers Cif Relief Act AUG-12-2009 08:36-12 < Me FrstllMiddle B Nave egin Date Active Duty States SerticelAgewcy BLEB DANIEL Based on the itf i y car have fim fished, the D%1DC does not possess any information indicating that the individual is currently on active duy, Upon searching the inibrmat on data banks of the Department of Defew -Manpower Data Center, based on the infosmatiom that you provided, the abos-c is the current status of the dal as to aM branches of the Military, Yhtu A V1 0404, * fit- &?_ Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data. Center 1600 Wilson Bhci_ Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data. Center (DMDC) is an organization of the Diem o Defense that maintains €ie Meuse Enrobxnt and Eligibility Reporting Systemi (DEM) database Which is the dal source of data on ehg'b for rear} medal care and other elegWity system. The Department of Defense strongly stets the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seg] (SCRA) (fortnerr the Soldiers' and S aiors` Civil Relief Act of 1940)_ I)MDC has issued hundreds of dKnuands of "does not possess any inf'orati€rn indicating that the in&idual is crgrendy on active d uV responses: and has experienced a small error rate. In the event the individual referenced abcrvT, or any fm* member, friend, or representative asserts in any manner that the indi%idutal is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further veritycation of the persons active duty status by contacting that pbersores Mi1itary Service ria the *defenselink.r " URL provided below. If you have evidence the person is on acme-may and you fain to obtain this additional M Service Nwiheat on, prorviskxis of the SCRA may be iced against you. If you obtain further irformation about flue person ( e.g., are SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we ui1l provide a new certificate for that query This response reflects current active duty status only. For historical motion, please contact the a `vary Service SCRA points- of-contact. See bip_j°-?-wvv.defenses,wifag'pisr'FCG9SLDR.htnal WARNIXG. This certificate liras prod based on a name and Social Security number (SSN) provided by the requester. ProN ding an erroneous carne or SSN a cause: an erroneous certificate to be provided, fa rtPt -BSX40csnu 190840 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) DANIEL BUBB ) NO. 08-7380 To: DANIEL BUBB 3299 RITNER HWY # 2 NEWVILLE, PA 17241-9566 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: January 23, 2009 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 DA I J. 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 _CASE NO: 2008-07380 F' COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS BUBB DAN I EL MICHAEL BARRICK r Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being dull- sworn according to ?aw, says, the within COMPLAINT & NOTICE was served upon BUBB DANIEL the DEFENDANT at 1603:00 HOURS, on the 23rd day of December , 2008 at 3299 RITNER H4vY #2 NEWVILLE, PA 17241-9566 by handing to DANIEL BUBB a true and attested copy of COMPLAINT & NOTICE together with and at the same tune directing His attention to the contents thereof. SYjerjf F ` s Costs: So Answers: Docketing 18.00 Service 1.0.8 0 Affidavit .00 _ s Surcharge 10.00 R. Thomas Kline .00 _ 38.80 12/24/2008 APO'THAK4&AS5?CIATT1ES Sworn and Subscibed to Bybe_ore me -- -?i s day uty - Sheri f f of k. D. RLED--l.DFrCE OF ?HIE PPOI Hl")NOT RY 2009 AUG 20 AM 8 07 + 14 . oo PO ATM CIL?' l4'(oSla(v ex's aa4?71 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: DANIEL BUBB 3299 RITNER HWY # 2 NEWVILLE, PA 17241-9566 ARROW FINANCIAL SERVICES LLC Plaintiff, VS. DANIEL BUBB Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7380 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, Esq. at this telephone number: 215-634-8920 8/.x/09