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Home My WebLink About09-0676t Our File No.: 193148 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. MICHELLE E PETIT 309 OAKVILLE RD SHIPPENSBURG, PA 17257-9748 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ()q- V (p 0-AY11 1eXK, 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.: 193148 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. MICHELLE E PETIT 309 OAKVILLE RD SHIPPENSBURG, PA 17257-9748 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY C3?,v / " NO.: 0 q_ 1. 7t 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 MICHELLE E PETIT, an adult individual residing at 309 OAKVILLE RD SHIPPENSBURG, PA 17257-9748. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185864917510669; 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 $3,443.01. 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 $3,443.01 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS$OQTATES, P.C. Attorney fo V A Law Firm Engage in BY: Dated: 1/26/2009 Our File No.: 193148 David J. Apo%al&r, Esquire I 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 undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. to unworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 1/26/2009 ARROW FINANCIAL SERVICES LLC MICHELLE E PETIT 309 OAKVILLE RD SHIPPENSBURG, PA 17257-9748 STATEMENT OF ACCOUNT Debtor's Name: MICHELLE E PETIT Account Number: 4185864917510669 Original Creditor- WASHINGTON MUTUAL BANK Balance Due: $3,443.01 Our File No.: 193148 EXHIBIT "A" ,? o0 p (7 or9aC "D ? D r}- n 7' t liz rv _7 rn c SHERIFF'S RETURN - REGULAR CASE NO: 2009-00676 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS PETIT MICHELLE E GERALD N WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE PETIT MICHELLE E was served upon the DEFENDANT , at 0018:12 HOURS, on the 13th day of February-, 2009 at 309 OAKVILLE RD SHIPPENSBURG, PA 17257-9748 by handing to MICHELLE PETIT DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service 18.00 18.00 Affidavit Surcharge 00 10.00 R. Thomas Kline .00 46.00 02/13/2009 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy She ff of A.D. ?: ? = i ? ? _--f ? ? ? -, _.°, i _, . :y 5. } C::i .,-? ......- - `.Ya --4: y t syi FILED-OFFICE Our File No.: 193148 101 !HE- Ptr0l^H0N0-1 rR; APOTHAKER& ASSOCIATES, P.C. BY: David J. Apothaker, Esquire 20 i 3 AN 19 P H 1: I Attorney I.D.# 38423 CUMBERLAND COUNTY 520 Fellowship Road C306 PENNSYLVANIA Mount Laurel,NJ 08054 (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES ) COURT OF COMMON PLEAS LLC ) CUMBERLAND COUNTY Plaintiff, ) vs. ) MICHELLE E PETIT ) NO. 09-676 Defendant. ) PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER& OCIATES,P.C. Attorney for Plaintiff A Law Firm Eng ged n Debt Collection By: David J. Apothaker, Esquire * 4 1 9 3 1 4 8 S S O J 1 - 0A C U& Y135�