HomeMy WebLinkAbout09-2482Our File No.: 202660
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.
FLORENCE DEANGELIS
202 W MAIN ST
CAMP HILL, PA 17011
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: Oq- cZqU 0,*1yNTerr*
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.: 202660
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.
FLORENCE DEANGELIS
202 W MAIN ST
CAMP HILL, PA 17011
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO..
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 FLORENCE DEANGELIS, an adult individual residing at 202 W MAIN ST
CAMP HILL, PA 17011.
3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of
Account #0000000114794716; and said account was issued to Defendant(s) by HOUSEHOLD 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 $7,541.84. 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
$7,541.84 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER & ASSOCYATIES, P.C.
Attorney for P]
A Law Firm Engaged in
BY:
David J. Apothaker,
Dated: 4/7/2009
Our File No.: 202660
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 The undersigned understands that the statements therein are
made subject to the penalties of 18 Pa.C.S.A. 4904 relating to upsvo?n falsification to authorities.
David J. Apothaker; Esquire
Attorney for Plaintiff
DATE: 4/7/2009
ARROW FINANCIAL SERVICES LLC
FLORENCE DEANGELIS
202 W MAIN ST
CAMP HILL, PA 17011
STATEMENT OF ACCOUNT
Debtor's Name: FLORENCE DEANGELIS
Account Number: 0000000114794716
Original Creditor: HOUSEHOLD BANK
Balance Due: $7,541.84
Our File No.: 202660
EXHIBIT "A"
FILE}
MI ARY
200: APR 20 Pig! 1* 51,
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Sheriffs Office of Cumberland County
R Thomas Kline o'titr of cifirltirrl?,y Edward L Schorpp
Sheriff Solicitor
C Y
Ronny R Anderson Jody S Smith
Chief Deputy OFFICE r.F THE sK:RIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/22/2009 09:32 AM - 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: Florence Deangelis, but was unable to
locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the
defendant Florence Deangelis. The current tenant of 202 W. Main Street Camp Hill, Cumberland County,
Pennsylvania 17011 states he has lived there since 1996 and Florence Deangelis defendant has never
resided there. An exact address is not available.
SHERIFF COST: $46.50 SO ANSWERS,
April 23, 2009 R THOMAS KLINE, SHERIFF
2009-2482
Arrow Financial Services
VS
Florence Deangelis
y _ _ Chi; ri