HomeMy WebLinkAbout09-4008Ourlile No.: 207575
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.
KELLY L THOMSON
30 W GREEN ST
MECHANICSBURG, PA 17055
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. Oq - O08 aivit-Fe4-111
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.: 207575
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.
KELLY L THOMSON
30 W GREEN ST
MECHANICSBURG, PA 17055
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 0 9- y" 8 (iW j -;
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 KELLY L THOMSON, an adult individual residing at 30 W GREEN ST
MECHANICSBURG, PA 17055.
3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of
Account #4888937995865856; and said account was issued to Defendant(s) by FIA CARD SERVICES N.A.,
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 $1,803.05. 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
$1,803.05 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 Pl tiff
A Law Firm Engag in ebt Collection
BY:
Dated: 6/10/2009
David J. Apofti r, Esquire
Our File No.: 207575
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 relat"unsworn falsification to authorities.
David JAApntk?ker, Esquire
Atto ev for Plaintiff
DATE: 6/10/2009
46 ARROW FINANCIAL SERVICES LLC
KELLY L THOMSON
30 W GREEN ST
MECHANICSBURG, PA 17055
STATEMENT OF ACCOUNT
Debtor's Name: KELLY L THOMSON
Account Number: 4888937995865856
Original Creditor: FIA CARD SERVICES N.A.
Balance Due: $1,803.05
Our File No.: 207575
EXHIBIT "A"
Q
FILE
OF THE -AQY
2009 im ; 5 1: 5;3
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Sheriffs Office of Cumberland County
R Thomas Kline ?ptr ct 4rumtirrf Edward L Schorpp
SheriffSolicitor
Ronny R Anderson Jody S Smith
Chief Deputy OFF ;CE CF 'h= s-MrF Civil Process Sergeant
Arrow Financial Services Case Number
vs. 2009-4008
Kelly L. Thomson
SHERIFF'S RETURN OF SERVICE
06/29/2009 08:39 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
June 29, 2009 at 2039 hours, he served a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: Kelly L. Thomson, by making known unto herself personally, defendant at 30 W.
Green Street Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.00
June 30, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
Deputy Sheriff
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