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Home My WebLink About08-7427 Our,File No.: 188163 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. RANDALL E POMEROY 62 CHERRY LN CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. e* - 7` 27 I" 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 '.t .J Our File No.: 188163 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. RANDALL E POMEROY 62 CHERRY LN CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D p_ 7 y a 7 Cc,wl T t, 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 RANDALL E POMEROY, an adult individual residing at 62 CHERRY LN CARLISLE, PA 17013 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4031130700739204; 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 $11,845.98. 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 A WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $11,845.98 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law APOTHAKER & AS TES, P.C. Attorney fo PI ' tiff A Law Firm Engag in ebt Collection BY: Dated: 12/11/2008 David J. ApoWer, Esquire Our File No.: 188163 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 relat"to worn falsification to authorities. David J. po1r, Esquire Attorne Plaintiff DATE: 12/11/2008 4• ? N ARROW FINANCIAL SERVICES LLC RANDALL E POMEROY 62 CHERRY LN CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: RANDALL E POMEROY Account Number: 4031130700739204 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $11,845.98 Our File No.: 188163 EXHIBIT "A" n V 1 C"> C? t C? cn ryl N N Y_ GJ CJ l? =-C r 0 6.) SHERIFF'S RETURN - REGULAR CASE NO: 2008-07427 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERICES LLC VS POMEROY RANDALL E BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon POMEROY RANDALL E the DEFENDANT , at 0920:00 HOURS, on the 5th day of January , 2009 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to RANDALL POMEROY 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 4.50 Poo'! 7,0 ?f .00 , 10.00 R. Thomas Kline .00 32.50 01/05/2009 APOTHAKER & ASSO TES By: day Deputy Sheriff A. D. a.. ? . c, ? _:f rt , ? .?-? _x._ °r° ° ...._ .; r, ? $ _?,. _ - f?J ?, _ ?. - +-` --z _. ';=a Our File No.: 188163 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. RANDALL E POMEROY Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7427 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, RANDALL E POMEROY, in the default of an Answer, in the amount of $12,029.77 computed as follows: Amount claimed in complaint: $11,845.98 Amount Paid: - $(0.00) Interest from December 11, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $183.79 Costs $0.00 Attorney fees $0.00 TOTAL $12,029.77 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, RANDALL E POMEROY, last know address is 62 CHERRY LN CARLISLE, PA 17013. APOTHAKER & AttorneyE A Law Firm Eng By: David TES, P.C. Debt Collection Dated: 5/14/2009 Our File No.: 188163 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. RANDALL E POMEROY Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7427 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 62 CHERRY LN CARLISLE, PA 17013. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if 0 Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David A Attorney r Data Center, located at 1600 Wilson s) is/are 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. DqmwbnW of Nfiwse 4Saepower Data Center MAY-14-2009 10.11:52 the 26000M data backs ofthe De nt of Die Manpower Turn Center, based an the atom &= o you pwYided, the above is the current sumn af*e individual as to at brand of %e Ngkwy. AMV Mary M. Snwiely-Dko, Direcbac Dqwftnw of Ddense - Manpower Data Center 16tl{1! Witte mod, Sure 400 VA 22209-2393 Mw Delesse Marker Data Cep (DM)G) is as cxrrgivication of the Department cf`Defaw drat snaintains dw Defense Enrohnea and ty Repotting System {DEERS} dot vAsch is the afrial sowce of data can a ty for sailitary scolical care and otbrr drgr"liky systems. The Departnent of Defers stroa#y wuppaets the enfircement of the Servi -!-I Civi! R Act [30 USCS Appz §§ 501 et set (SCRA) (armady the SdA rs' and Sam' Civil Reif Act of 1940). DUDC bas isswd laxodoe1s of of-does not posers inihmastion 65catiag'that the intfividrnd is cniriendy an naive duty" respoesses, mad bas a mce d a smut esrar rate- In the event the mc1'A& wst r&mK*d aubam or my fiA* aaembar, Riau, ar red teptstafive ash in r memner dw the incMdad is on active duty, at is O ise adWd to the protons of the SCRA, yore are skcng?y encouraged Id obtain far-1 vetfiadxt ofthe person's active duty status by caa'actin do pe rsan"s Mary Service vk the "de ®k-.mr M p movide d bdow. If yon bane ev;&we dre person is an aic*m-daty and you dal to obtain dais addlionst Mlwy Service +erffcj ion, provisions of dre SCRA may be invoked ageing you, If yin obtain ih rdw ` i about the person ( eag., an SS1+I, improved accuracy of DOB, a midele name}, you can wdwk yeah request: again at this Web site and we wi provide a new cer t c for that quay. Tlas response redec# current active duty status oaty. For historical iofmmatim pkme contact the Minty Service SCRA points- of-coahka Sac httslwww WAR 4M. This c 6eatc was provided based on a name and Sock Secuby nunbcr (SSM provided by the rewester. .ProvAng an caroms n me or SSN wil an enooeous cert±6caate to be provided. RaparrM rNTOW4 V piracy Staff Report Parrot to the Service bees Chi ReWAct 188163 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) RANDALL E POMEROY ) NO. 08-7427 To: RANDALL E POMEROY 62 CHERRY IN CARLISLE, PA 17013 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: February 05, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DA . 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: 2008-07427 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERICES LLC VS POMEROY RANDALL E BRIAN BARRICK JAN 1 4 ?F) .. , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon POMEROY RANDALL E the DEFENDANT at 0920:00 HOURS, on the 5th day of January _, 2009 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 1.7013 RANDALL POMEROY 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 4.50 Affidavit .00 Surcharge 10.00 .00 ^ 32.50 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline W 01/05/2009 APOTHAKER & ASSO TES By: /yo? 7 Deputy Sheriff of , A. D. FILED r= F T?-{F f 'rTP 2CC9 cli",Y "c0 - ?; 414.00 PD ATM mv t3y7`41 e as z SW' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: RANDALL E POMEROY 62 CHERRY LN CARLISLE, PA 17013 ARROW FINANCIAL SERVICES LLC Plaintiff, VS. RANDALL E POMEROY Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7427 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, Esc. at this telephone number: 215-634-8920 5la.%'?