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Home My WebLink About09-3617Our File 140.: 297348 , 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0q- 2kl l onv;(-Fem THOMAS C FOREMAN 3815 MARKET ST CAMP HILL, PA 17011 Defendant. 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 14o.: 2Q7348 , 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. THOMAS C FOREMAN 3815 MARKET ST CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 ti - 3& 1'7 ex?d -7z' 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 THOMAS C FOREMAN, an adult individual residing at 3815 MARKET ST CAMP HILL, PA 17011. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4465611901040745; 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 $2,815.52. 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 $2,815.52 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS IATES, P.C. Attorney f PI tebt ti A Law Firm EnRal in Collection BY: Dated: 5/27/2009 David J. ApotYtxl?er, Esquire Our File No.: 207348 VERMCATION 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 )6 uroworn falsification to authorities. David J. Apc Attorney DATE: 5/27/2009 THOMAS C FOREMAN 3815 MARKET ST CAMP HILL, PA 17011 ARROW FINANCIAL SERVICES LLC STATEMENT OF ACCOUNT Debtor's Name: THOMAS C FOREMAN Account Number: 4465611901040745 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $2,815.52 Our File No.: 207348 EXHIBIT "A" 0 . r 1 Tl- 7F 4 :. j.J .'J *"18.5o Pa A'nN e*"* t3footo 7 ?T* 104 Sheriffs Office of Cumberland County R Thomas Kline =rr Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF-,E SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/08/2009 06:26 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 8, 2009 at 1826 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Thomas C. Foreman, by making known unto Georgia Lidell, adult in chajrge at 3815 Market Street Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, ?j June 09, 2009 R THOMAS KLINE, ERIF puty Sheriff 2009-3617 Arrow Financial V 'T'homas Foreman C? A C- C= Ti ? rn t--) t- --C `_) z,