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Home My WebLink About09-2552Our File No.: 202874 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.438423, 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. KEVEN T ROHER 450 HILLCREST DR CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09 - o155a 0 V it Yeah 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.: 202874 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.438423, 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. KEVEN T ROHER 450 HILLCREST DR CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Of- s5? OL-j P 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 KEVEN T ROHER, an adult individual residing at 450 HILLCREST DR CARLISLE, PA 17015. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4800115996544367; and said account was issued to Defendant(s) by FIA CARD SERVICES N.A.(BANK OF AMERICA), 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 $2,084.78. 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 $2,084.78 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER A OCIATES, P Atto y fo Plaintiff / A Law Firm E as in Deb ollec, BY: Dated: 4/17/2009 David J. )kpothaker, Esquire Our File No.: 202874 VERIFICATION David J. Ayothaker, 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 unss orn falsification to authorities. David J. Apo akZ Esq Attorney r Plaintiff DATE: 4/17/2009 ARROW FINANCIAL SERVICES LLC KEVEN T ROHER 450 HILLCREST DR CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: KEVEN T ROHER Account Number: 4800115996544367 Original Creditor: FIA CARD SERVICES N.A.(BANK OF AMERICA) Balance Due: $2,084.78 Our File No.: 202874 EXHIBIT "A" kal) FiLEL.:C'?F THE E'. "- ? l Y 2009 APR 2J A 11: 03 *qg. So Po Airy 1? li Sheriffs Office of Cumberland County R Thomas Kline 9 at cumber Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy QFFiCE OF THE s"ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/29/2009 11:51 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: Keven T. Roher, blot was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Keven T. Roher. Per defendants mother, Linda Roher the defendant Kevin T. Roher has passed away. SHERIFF COST: $37.50 SO ANSWERS, April 30, 2009 R THOMAS KLINE, SHERIFF 2009-2552 N_ Arrow Financial Services --, VS Keven T. Roher _. --> * 4l r 10, Our File No.: 202874 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC Plaintiff, vs. KEVEN T ROHER Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2552 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Ensa?fid n Debt Collection By: David J. Apothaker, Esquire Dated: 6/16/2009 r?? ?' .= !`'rid ,. ??.? ;`t'. ,