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Home My WebLink About09-1596Blatt, 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. JASON GOULET 228 GROVE DR SHIPPENSBURG PA 17257-8859 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. aq - 159(p Cl w Tech 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 2255216 PPTCHDFI Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, ARROW FINANCIAL SERVICES, LLC C/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. JASON GOULET 228 GROVE DR SHIPPENSBURG PA 17257-8859 Defendant(s). N THE COURT OF COMMON PLEAS UMBERLAND COUNTY, PA VIL ACTION COMPLAINT Plaintiff ARROW FINANCIAL SERVICES, LLC, claims as follows: 1. The Defendant(s), JASON GOULET, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with GE MONEY BANK, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $3948.21. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2255216 PPTCDBCI WHEREFORE, the Plaintiff, ARROW FINANCIAL SERVICES, LLC, prays for judgment in its favor and against Defendant(s), JASON GOULET in the amount of $3948.21, plus costs. Respectfully submitted, ARROW FINANCIA SERVICES, LLC vtrmQT,,Rsworneys Daniel Santucci, Attorney No. 92800 Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 (800) 850-1079 Dated: February 23, 2009 THIS COMMUNICATION IS FROM A DEBT COLLECTOR. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 Attorney for Plaintiff Exhibit "A" PPTXEXAI STATE OF ILLINOIS COUNTY OF COOK AFFIDAVIT OF INDEBTEDNESS 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 duly 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 Financial Services, LLC by GE MONEY BANK, and based on information and belief, affiant states that the amount due to Arrow Financial Services, LLC by JASON GOULET for funds advanced to defendants(s) or paid to another at defendant(s) request, or for goods or services provided to defendant(s) or to another at defendant's request, is the following on the following account(s) as of 01-15-09: CREDITOR/ACCOUNT NUMBER CURRENT BALANCE Arrow Financial Services, LLC 5218840000805388 $3948.21 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 Before me day of ,20_An!?j. 1 Notary is My Commission Expires: Affiant Title "i' Date of Service: Reference #: 2255216 Forwarder ID#: Account #: 5218840000805388 BAFFAFSL(11/02 )EEO ARROW FINANCIAL SERVICES LLC "OFFICIAL SEAL" Jennifer Lewie Notary Public, State of Illinois Commission Expires 642512012 I SIN ?M li N?? ?I ?I SIN VIII Ian I Till IIh II i II Till ,?.. _. .., ] N C_' ca ?i 7 C l ? ?' ? Sti f) 00 -- m Yy -- F j j rzi 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. JASON GOULET 228 GROVE DR SHIPPENSBURG PA 17257-8859 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09 -159(p O'Avit Tem 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: February 23, 2009 By: 2255216 PPTXPEAI BLATT, HASENMILLER, LEIBSKER i r - ? l? }C Sheriffs Office of Cumberland County R Thomas Kline Sheriff '07 THE T ,r . u Ronny R Anderson Chief Deputy ??II i Z?UJ .dw+:- lv,si = ?i P Jody S Smith Civil Process Sergeant F?frF F Tr,E $ r- rF - Edward L Schorpp Solicitor Arrow Financial Services vs. Jason Goulet Case Number 2009-1596 SHERIFF'S RETURN OF SERVICE 03/30/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Jason Goulet, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Franklin County, PA to serve the within Complaint and Notice according to law. 06/11/2009 Franklin County Return: And now, June 11, 2009 I, Dane Anthony, Sheriff of Franklin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Jason Goulet the defendant named in the within Complaint and that I am unable to find her in the County of Franklin and therefore return same NOT FOUND. SHERIFF COST: $37.00 July 10, 2009 SO ANSWERS, r ?i``!- R THOMAS KLINE, SHERIFF SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-00088 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN ARROW FINANCIAL SERVICES VS JASON GOULET BRIAN CRAMER Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GOULET JASON , to wit: but was unable to locate Him in his bailiwick. COMP CIVIL ACTION the within named DEFENDANT 228 GROVE DRIVE SHIPPENSBURG, PA 17257 He therefore returns the GOULET JASON ATTEMPTS MADE NOTICES LEFT ON DOOR NO RESPONSE NOT FOUND , as to Sheriff's Costs: So answers: Docketing .00 Service .00 Affidavit .00 BRIAN C R Surcharge .00 DANE M THONY, Sheriff .00 .00 BLATT HASENMILLER LIEBSKER AND 06/11/2009 Sworn and subscribed to before me this day of 0 A. D . COMMONWEALTH OF PENNSYLVANIA ` NOTARIAL SEAL RICHARD D. McCARTY, Notary Public Notar ambersburg 8oro., Franklin Cun ty 0 My Commission Expires Jan. 29. 2 01 1