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Home My WebLink About09-1784 2056469 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC 5996 W. Touhy Avenue, Niles, IL 60714 VS. RICHARD DORSEY 2500 COPE DR MECHANICSBURG PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. :o?-1791/ NOTICZ 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 JUDGEMENT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 t COMPLAINT IN CIVIL-ACTION 1. Plaintiff, ARROW FINANCIAL SERVICES LLC a debt buyer and successor in interest to the original creditor, HOUSEHOLD BANK. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the original creditor under the terms of which the original creditor agreed to extend to defendant(s)the use of original creditor's credit facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the original creditor for the use of said credit card. 4. The defendant(s)received and accepted goods and merchandise and/or accepted services or cash advances through the use of the credit card issued by the original creditor. A true and correct copy of the Statement of Account, if available, is attached hereto as Exhibit "A". 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of March 16, 2009 in the amount of $2,480.05. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on . . WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,480.05 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. I ERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff P01P.DB „M? a v ? I EXHIBIT "A" 1. 2056469 34024657 Arrow Financial Services, LLC RICHARD DORSITY 7021270308899664 MIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 19 Pa.C.S. §4904 which provides for certain penalties for making false statements. M4? NAM 2056469 Arrow Financial Services, LLC RICHARD DORSEY 7021270308899664 State of Illinois County of Cook AFFIDAVIT I ,?°??S being duly served sworn according to law, depose and say that: 1. I am employed as the legal outsourcing clerk for the Plaintiff herein. and I have custody and control of the files relating to this account; 2. I have personal. knowledge of the facts and circumstances in connection with this case and base this affidavit on Plaintiff's records, as well as the account information proved to PlaiAtiff by nousasozD BANK when .HOUSSaozD RANK sold the account to Arrow Financial'Services, LLC. 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is-based?on a.claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now dus,and owing from defendant to plaintiff, the amount of $2,391.59 plus interest of $33.02 at the rate of 18% less credits in the amount of $.00 totaling $2,424.61 as of January 28, 2009. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. FI Sworn to and Subscribed before me t#is /day of 009 Notary. Public OFFICIAL SEAL" W Valencia D Dob Public, state of 11 inois mmission Expires 6/10/2012 ('7 AJ v2 V t N C7 co I too Sheriffs Office of Cumberland County R Thomas Kline (060W st Cuo b",M? Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFF CE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/26/2009 07:55 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 26, 2009 at 1955 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard Dorsey, by making known unto Rachel Dorsey, wife of defendant, at 2500 Cape Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $36.10 SO ANSWE, 3 March 30, 2009 R THOMAS KLINE, SHERIFF ;; e/z X"?/ puty . iff Docket No. 2009-1784 Arrow Financial v Richard Dorsey 2056469 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 _ 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 09-1784 RICHARD DORSEY PRAECIPE FOR ENTRY OF JUDGMENT FOR'WANT OF AN ANSWER ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of,an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as :a sum .pertain from the complaint, as follows: Principal $2,391.59 Total: $2,391.59 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: ARROW FINANCIAL SERVICES LLC and that the last known address of defendant, RICHARD DORSEY, 2500 COPE-DR+.,_MECHANICSBURG PA 17055. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date pf .fi?.i,ng of this praecipe. 3. The said defendant(s). is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this 11'4' day of may 2009 Judgment is entered in favor of the plaintiff(s) and Against defendant(s) by default for want of an answer and"-damages assessed at the sum of , $2,391.59 as per the above certifitat' Pr honotary GORDON -& WEINBERG, P.C. BY: FREDERIC W NBERG, ESQUIRE JOEL M. FL K, ESQUIRE -Attorney for Plaintiff L 2056469 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 09-1784 RICHARD DORSEY TO/PARA NOTICE OF INTENTION TO TAKE DEFAULT RICHARD DORSEY 2500 COPE DR MECHANICSBURG PA 17055 DATE OF NOTICE/FECHA DEL AVISO: April 17, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN'WR!TING 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON &. ,WEINBERG, P.C. BY: FREDER . WEINBERG, ESQUIRE ,t- f JOEL FLINK, ESQUIRE PLOD-2 Orr(av OF F P ? NoTMr#W a? MAY If pm 6mo-b co PA p ?+? pO Po PCTTI Ck V+ ay 2056469 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC VS. RICHARD DORSEY 2500 COPE DR MECHANICSBURG PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-1784 NOTICE: Pursuant to Pa.R.Civ.P. 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. /X/ Judgment by Default $2,391.59 L_L Money . audgnent $ Judgment on'_-.A*ard of Arbitrators$ L-L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL' M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 P THONOTA ,4. ICE 2056469 . OF THE P ROTH ONO WR'i GORDON & WEINBERG, P.C. 2013SEP _9 PM 2: 00 BY: . FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 CUMBERLAND COUNTY A . JOEL M. FLINK, ESQUIRE pN�iSYLVANlA Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351=0500 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY VS . DOCKET NO. 09-1784 RICHARD DORSEY ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: . Kindly mark the judgment entered May 11, 2009 in the above- = captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDER C I,/WEINBERG, ESQUIRE JOEL M. LINK, ESQUIRE Attorney for Plaintiff P005 Li SOP All aq SCI 1