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Our File No.: 193186
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.
SCOTT WRIGHT
17 S SHIPPENSBURG MOBILE EST
SHIPPENSBURG, PA 17257-9528
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: (R - 1o?y 05M lec%-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
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Oug File No.: 193186
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.
SCOTT WRIGHT
17 S SHIPPENSBURG MOBILE EST
SHIPPENSBURG, PA 17257-9528
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. 0 9- t -7 t C?U 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 SCOTT WRIGHT, an adult individual residing at 17 S SHIPPENSBURG
MOBILE EST SHIPPENSBURG, PA 17257-9528.
3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of
Account #6019180307574091; and said account was issued to Defendant(s) by GE MONEY 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 $1,933.80. 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.
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WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
$1,933.80 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER ZAO?IATES, P.C.
Attornel 'tiff
A Law Firm Ene ebt Collect
BY:
David I AkthUdir, Esquire
Dated: 1/26/2009
Our File No.: 193186
do,
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.
understands that the statements therein are
unworn falsification to authorities.
David J. Apothaker, Esquire
Attorney for Plaintiff
DATE: 1/26/2009
ARROW FINANCIAL SERVICES LLC
SCOTT WRIGHT
17 S SHIPPENSBURG MOBILE EST
SHIPPENSBURG, PA 17257-9528
STATEMENT OF ACCOUNT
Debtor's Name: SCOTT WRIGHT
Account Number: 6019180307574091
Original Creditor: GE MONEY BANK
Balance Due: $1,933.80
Our File No.: 193186
EXHIBIT "A"
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SHERIFF'S RETURN - REGULAR
CASE NO: 2009-00674 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ARROW FINANCIAL SERVICES LLC
VS
WRIGHT SCOTT
GERALD N WORTHINGTON
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
WRIGHT SCOTT
was served upon
the
DEFENDANT , at 0017:45 HOURS, on the 10th day of February-, 2009
at 17 SHIPPENSBURG MOBILE EST
SHIPPENSBURG, PA 17257-9528
SCOTT WRIGHT
DEFENDANT
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 18.00
Affidavit .00
Surcharge 10.00
Z V . V V
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
02/11/2009
APOTHAKER & ASSOCIATES
By:
Deputy Sh iff
A.D.
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