HomeMy WebLinkAbout09-3614OurYile No.: 207098
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apo'thaker, 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.
AN LIN CHANG
3512 GREEN ST
CAMP HILL, PA 17011
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 01 - 3(,o(4 alvit l errh
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 ?ile No.: 207098
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.
AN LIN CHANG
3512 GREEN ST
CAMP HILL, PA 17011
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: O q - 3 G Jy et cn.l -7"
CIVIL ACTION COMPLAINT
FIRST COUNT
11. 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 AN LIN CHANG, an adult individual residing at 3512 GREEN ST CAMP
HILL, PA 17011.
3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of
Account #4185862668398672; 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 $1,497.29. 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".
16 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
$1,497.29 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER & SOCIATES, P.C.
Attorn fo Plaintiff
A Law Firm E a2 in Debt Collecfi&
BY:
Dated: 5/22/2009
David I ApoNbaker, Esquire
Our File No.: 207098
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 relatirgIcj unworn falsification to authorities.
David J. ApN
Attorney
ker, Esquire
Plaintiff
DATE: 5/22/2009
ARROW FINANCIAL SERVICES LLC
AN LIN CHANG
3512 GREEN ST
CAMP HILL, PA 17011
STATEMENT OF ACCOUNT
Debtor's Name: AN LIN CHANG
Account Number: 4185862668398672
Original Creditor: WASHINGTON MUTUAL BANK
Balance Due: $1,497.29
Our File No.: 207098
EXHIBIT "A"
0
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LC J? VyF ?1J ?1?? ??' v Y.;
I i?` ' _.l as
419.5o Pa ATT'Y
CO 135487
W* aac. I oa
Sheriff s Office of Cumberland County
R Thomas Kline ~a~~~cr of ~"uu~brr/,~~d Edwazd L Schorpp
Sheriff ~ Solicitor
,.~. ^~
. ~` ~v
Ronny R Anderson ~` ~ ~ ~ ~ Jody S Smith
Chief Deputy aF€>cs o~ r!+~ sr+~RiFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
06/11/2009 01:50 PM - 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: An Lin Chang, but was unable to locate
him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant
An Lin Chang. The defendant is terminally ill located in a hospital in New York and is not expected to
return home.
SHERIFF COST: $60.00 SO ANSWERS,
June 12, 2009 R THOMAS KLINE, SHERIFF
2009-3614
Arrow Financial Serivices, LLC.
v
An Lin Chang
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