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Home My WebLink About09-3619? v Our File'No.: 207324 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. EARL L YOCUM 6331 BRANDY LN LOT 3 MECHANICSBURG, PA 17050-8123 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - 3(019 0,4- vi l -rixh 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 4 Opr File No.: 207324 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. EARL L YOCUM 6331 BRANDY LN LOT 3 MECHANICSBURG, PA 17050-8123 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D9 - 3G / 9 n?c 4 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 EARL L YOCUM, an adult individual residing at 6331 BRANDY LN LOT 3 MECHANICSBURG, PA 17050-8123. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4361451200517563; 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 $1,059.89. 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". T 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 $1,059.89 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Eniza9 BY: Dated: 5/27/2009 RTES, P.C. bt Collection David J. Apb4 a cer, Esquire Our File No.: 207324 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 unworn falsification to authorities. David J., Esquire Attorney for Plaintiff DATE: 5/27/2009 ' ARROW FINANCIAL SERVICES LLC EARL L YOCUM 6331 BRANDY LN LOT 3 MECHANICSBURG, PA 17050-8123 STATEMENT OF ACCOUNT Debtor's Name: EARL L YOCUM Account Number: 4361451200517563 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,059.89 Our File No.: 207324 EXHIBIT "A" Q I` 4-M.:5C) PA ACT{ ax* aa4. 1 os Sheriffs Office of Cumberland County R Thomas Kline sw'L9 41"14'`rlIy? Solicitor Sheri C :. r Jody S Smith Ronny R Anderson Chief Deputy r,FF wE OF 'HE W-ERIFFZ Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/05/2009 03:20 PM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on June 5, 2009 at 1520 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Earl L. Yocum, by making known unto himself personally, defendant at 6331 Brandy Lane, Lot 3 Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWERS, I-0000A, 4?? - June 08, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff 2009-3619 Arrow Financial Services v Earl L. Yocum r•? C - ' O c M{p J Clj .? .?.1