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Home My WebLink About09-0538Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci ARROW FINANCIAL SERVICES, LLC Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ARROW FINANCIAL SERVICES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. JUSTIN GREENFIELD 4713 BRIAN RD MECHANICSBURG PA 17050-3012 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. CA- 558 Civil Terw% NOTICE TO DEFEND 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, 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 2187076 PPTCHDFI Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci ARROW FINANCIAL SERVICES, LLC Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern,PA 19355 800-850-1079 ext. 4151 ARROW FINANCIAL SERVICES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. JUSTIN GREENFIELD 4713 BRIAN RD MECHANICSBURG PA 17050-3012 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. O9- 5.32' C J ` -zw' COMPLAINT AND NOW comes Plaintiff, by its undersigned attorney, and complains against Defendant as follows: 1. The Plaintiff herein is ARROW FINANCIAL SERVICES, LLC, which has retained the services of Blatt, Hasenmiller, Leibsker & Moore, LLC located at 5 Great Valley Parkway, Suite 100, Malvern, PA 19355. 2. The Defendant is/are JUSTIN GREENFIELD, whose last known principle residence is believed to be 4713 BRIAN RD MECHANICSBURG PA 17050-3012. 3. Defendant obtained extensions of credit on the following open-ended credit account issued by WASHINGTON MUTUAL henceforth ("Original Creditor") being known as Account Number 4185861239623907 (henceforth "Account"). 4. The Plaintiff is the assignee of the Account which was originally owned by Original Creditor. 5. An extension of credit was made by Original Creditor to Defendant in reliance of the representation of Defendant for repayment of any outstanding balance on the Account. 2187076 PPTCDEBI 6. At all relevant times material hereto, Defendant has/have used the Account for the purchase of goods and/or services. The amount currently due and owing on the said Account is $3200.80, plus interest and costs associated with the Account. An affidavit of a representative of Plaintiff is attached hereto as plaintiff's Exhibit "A" and is incorporated herein by reference. 8. Despite reasonable and repeated demands for payments on the Account prior to filing this complaint, Defendant has/have refused to pay all sums due and owing on the Account. COUNT 1- BREACH OF CONTRACT 9. Plaintiff incorporates the foregoing paragraphs by reference thereto. 10. Original Creditor has performed any and all conditions precedent to the bringing of this action. 11. Defendant is/are in breach of the agreement to repay the outstanding balance on the Account. WHEREFORE, Plaintiff demands judgment in its favor against Defendant in the amount of $3200.80, plus interest at the legal rate from the date of judgment plus costs and any other remedy which this Court may deem just and proper. COUNT II - ACCOUNTS STATED 12. Plaintiff incorporates the foregoing paragraphs by reference thereto. 13. Periodic billing statements on the Account were sent by Original Creditor to the Defendant by mail on a regular basis. 14. Defendant was given reasonable opportunity to examine each of the said billing statements and did not communicate any dispute of the charges to the Original Creditor. 15. The failure of Defendant to dispute the periodic billing statements constitutes an acceptance of the balance due on the Account. WHEREFORE, Plaintiff demands judgment in its favor against Defendant in the amount of $3200.80, plus interest at the legal rate from the date of judgment plus costs and any other remedy which this Court may deem just and proper. COUNT 111- UNJUST ENRICHMENT 16. Plaintiff incorporates the foregoing paragraphs by reference thereto. 17. As a direct result of the receipt of the benefit of the extensions of credit given on the Account by the Original Creditor to the Defendant, Defendant has/have been unjustly enriched in the amount of $3200.80 to the detriment of the Original Creditor. WHEREFORE, Plaintiff demands judgment in its favor against Defendant in the amount of $3200.80, plus interest at the legal rate from the date of judgment plus costs and any other remedy which this Court may deem just and proper. Respectfully submitted, Dated: January 5, 2009 By: BLATT, HASENMILLER, LEIBSKER VERIFICATION I, DANIEL SANTUCCI, the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. PPTXVERI Exhibit "A" PPTXEXAI STATE OF ILLtNOIS COUNTY OF COOK AFFIDAVIT OF RMSTEDNESS The undersigned, being duly sworn, deposes and states that he/she is an employee/agent of: Arrow Financial Services, LLC and; has knowledge of the account balance, and. is duty authorized to make this affidavit. Affiant states that the amounts shown: below are taken/calculated from the original books and records of the above named plaintiff as well as from Information provided to Arrow f=inancial Services, LLC by WASHINGTON MUTUAL, and based on Information and belief, affiant states that the amount due to Arrow Financial Services, LLC by JUSTIN GREENFIELD for funds advanced to defendants(s) or paid to another at defendant(s) request, or for goods or services provided to defendars(s) or to another at defendant's request, is-the following on the following account(s) as of 09-23-08: CREDITOR<ACCOUNT NUMBER CURRENT BALANCE Arrow Financial Services, LLC 4185881239823907 $3200.80 Affiant states that the amount shown above is true and correct to the best of his/her knowledge. Further affiant sayeth not. Subscribed and Sworn to B re me l f _ day of W 0 (%d/ Notary Public My Commission Expires: "OFFICIAL ?? SEAL" arla A hi-, 'ke Notary?Public, .S:,r? Y? Commission E of I?linois Expires 611212011 44- ' ?! 77 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci ARROW FINANCIAL SERVICES, LLC Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ARROW FINANCIAL SERVICES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. JUSTIN GREENFIELD 4713 BRIAN RD MECHANICSBURG PA 17050-3012 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. oq- sw 0A, Y'tC-_rV-% PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF ARROW FINANCIAL SERVICES, LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Telephone Number: 1-800-850-1079 ext. 4151 Dated: January 5, 2009 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC By: D Sant c 2187076 PPTXPEAI e'? :v t- ? ?,a :??;? =r7 -: .?; , ? -; .? ?.. ? .'1i 1? e.?> SHERIFF'S RETURN - REGULAR CASE NO: 2009-00538 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS GREENFIELD JUSTIN 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 GREENFIELD JUSTIN the DEFENDANT , at 0011:46 HOURS, on the 21st day of Pebruary , 2009 at 118 N MARKET STREET, APT A MECHANICSBURG, PA 17055 by handing to JUSTIN GREENFIELD DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Additional Comments PER CURRENT RESIDENT, NO LONGER LIVES AT 4713 BRIAN ROAD. PER POST OFFICE, MOVED TO 118 N MARKET ST, APT A, MECHANICgBURG. Sheriff's Costs: So Answers: Docketing 18.00 Service 9.00 Affidavit .00 ` Surcharge 10.00 fet,-ThOFE-s K ine .00 37.00 02/23/2009 BLATT HASENMILLER LEIBSXER & M Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. r? - .,,?, --? ?`i ?; y • ? ?.? T ? ? ' --. A.,,w. .. ;_ .__ s_ . i, `T, t .?'. ?..... `w.': --L:.. ,. Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci ARROW FINANCIAL SERVICES, LLC Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 ARROW FINANCIAL SERVICES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. JUSTIN GREENFIELD 118 N. MARKET ST APT A MECHANICSBURG PA 17050-3012 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09-538 PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT JUSTIN GREENFIELD in this matter in the amount of $3200.80 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 3-19-09 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: April 2, 2009 2187076 PPTJPFJI By: I I? I?I? I) I911? ?I ) (?I ? ? ?I Respectfully submitted, 4ft Blatt, Hasenmilier, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci ARROW FINANCIAL SERVICES, LLC Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800.850-1079 ARROW FINANCIAL SERVICES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. JUSTIN GREENFIELD 118 N. MARKET ST APT A MECHANICSBURG PA 17050-3012 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09-538 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MOORE, LLW Dated: April 2, 2009 By: 2187076 PPTJCAMI Santucci I IIIIIIII 1111111111111 IIIII IIIII IIIII IIIII 11111111111111 IIIII IIII ARROW FINANCIAL SERVICES, LLC Plaintiff, JUS71N GREENFIELD 118 N. MARKET ST APT A MECHANICSBURG PA 17050.3012 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09-538 TO: JUSTIN GREENFIELD Date of Notice: March 19, 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASENMI LER, LEIBSKER & MOORE, LLC By: Daniel antucci 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 x 4151 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2187076 PPTNLRSI I 11011III 1111 C] f1L!ID 14k E OF '91F,n, 7;.tr i, ;Y 2099 APR'0 FM 2: 00 t !; CI ?,. ?,.ml t'"-i7a #14.00 00 A'r't.'! CI?•'? go3 89 aa3?s? Ar+ .r ARROW FINANCIAL SERVICES, LLC Plaintiff, VS. JUSTIN GREENFIELD Defendant(s). TO: JUSTIN GREENFIELD NOTICE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 09-538 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. Dated: #420/6? By: ROTHO ARY IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 2187076 PPTNDJNI INIfl flI I EME I11i