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Home My WebLink About09-46572059874 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC 6418 W. Touhy Avenue Niles, IL 60714 vs. FLOYD LOUSE, JR. 808 UPLAND ST MECHANICSBURG PA 17055-4355 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO oq - 4(05'7 0,ty;1 Ter*% 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 JUDGEMENT 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, ARROW FINANCIAL SERVICES LLC a debt buyer and successor in interest to the original creditor, WELLS FARGO FINANCIAL INC. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the original creditor under the terms of which the original creditor agreed to extend to defendant(s)the use of original creditor's credit: facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the original creditor for the use of said credit card. 4. The defendant(s)received and accepted goods and merchandise and/or accepted services or cash advances through the use of the credit card issued by the original creditor. A true and correct copy of the Statement of Account, if available, is attached hereto as Exhibit "A". 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of May 12, 2009 in the amount of $11,513.74. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on 3/5/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $11,513.74 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE BERG, ESQUIRE JOEL M. FL ESQUIRE Attorney for Plaintiff P01P.DB 2059874 41205990 Arrow Financial Services, LLC FLOYD GOUSE, JR. 50237302138459001 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S., 54904 which provides for certain penalties for making false statements. EXHIBIT "A" 2059874 ARROW FINANCIAL SERVICES, LLC FLOYD GOUSE, JR. 50237302138459001 State of Illinois § County of Cook § AFFIDAVIT I J440 t lCVt ?tr Bing duly served sworn according to law, depose and say that: 1. I am employed as the legal outsourcing clerk for the Plaintiff herein" and I have custody and control of the files relating to this account; - 2. I have personal knowledge of the facts and circumstances in connection with this case and base this affidavit on Plaintiff's records, as well as the account information provided to Plaintiff by WELLS FARGO FINANCIAL INC 'when:WELLS FARGO FINANCIAL INC sold the account to Arrow Financial Services, LLC. 3.;-.Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $8,601.29 plus interest of $2,764.07 at the rate of 17.99% less credits in the amount of $.00 totaling $11,365.36 as of April 7, 2009. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. AFFI Sworn to and Subscribed ' before me this ---------------- day "OFFICIAL SEAL" of 1Lr 2009 z Patricia Wallace Notary Public, State of Illinois My Commission Expires 10/10/2012 Notary Public D Or ,U? :fay u 13 :L L 418.5 o Po ATTI cr,*S( 44S pj# aa?a i'1 , Sheriff s Office of Cumberland County R Thomas Kline ~~~~.} -t-;~-;=;'"~;= Sheri )F ~~~ t: - '~4'~Y n~ iCumb f ". . Ronny R Anderson ~°'~~ttr Y ~r~'~4 ,~~r ' ,~ Chief Deputy ..~; LU:.~~ t~,.;u ~ ~ ~.~'t ~'~ 3i:) Jody S Smith ~ ~ ~~~~ , ~,_. Civil Process Sergeant ~~F~cE cF -~F *~s~ti~~= ~"~f' + t ~' . r _-.•. bra t ~, ,~ Edward L Schorpp Solicitor Arrow Financial Services LLC vs. Case Number Floyd Gouse, Jr. 2009-4657 SHERIFF'S RETURN OF SERVICE 08/10/2009 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: Floyd Gouse, Jr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Floyd Gouse, Jr. Current resident of 808 Upland Street Mechanicsburg, PA 17055 is the defendant's mother, she stated Floyd Grouse, Jr. hasn't lived at this address in over a year, and she has not been in contact with him. The Mechanicsburg Postmaster has advised the defendant's mail is delivered to address given. An exact address is not available. SHERIFF COST: $37.44 August 10, 2009 SO ANSWERS, ~~ ~--''/ R THOMAS KLINE, SHERIFF