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Home My WebLink About09-46582059869 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 COURT OF COMMON PLEAS 6413 W. Touhy Avenue CUMBERLAND COUNTY Niles, IL 60714 vs. DOCKET NO. : 09 - q(o5$ (21Vil-Cerrk ROBERT MOYER 3 RICHLAND LN--APT # T-2 CAMP HILL PA 17011 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 $2,470.45. 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 10/16/08. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,470.45 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01P.DB 2059869 42278758 Arrow Financial Services, LLC ROBERT MOYER 50237301054299001 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. §4904 which provides for certain penalties for making false statements. iti G EXHIBIT "A" • 2059869 ARROW FINANCIAL SERVICES, LLC ROBERT MOYER 50237301054299001 State of Illinois County of Cook § AFFIDAVIT that: IV ? QA`kot? being duly served sworn according to law, depose and say 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- MILLS 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 $1,891.97 plus interest of $545.82 At the rate of 188 less credits in the amount of $.00 totaling $2,437.79 as of April 7, 2009. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. Ozu AFFI Saturn to and Subscribed before me this day of 2l ?--? 2009 Notary ?jjc?? "OFFICIAL SEAL" Z Patricia Wallace Notary Public, State of Illinois My Commission Expires 10/10/'012 Ril.E..":' t F THE= "IT M' y ri.r`nn,?f to ?? yL/ ..i J{. 1 37 Fy.? oz . 5o p o CI?'? 8t W y I , Sheriffs Office of Cumberland County R Thomas Kline 1 SOLI .. +: Sheri Ronny R Anderson 46atp ?t ?i in6rrf? Chief Deputy or? 'v L "` f i ' t Jody S Smith Civil Process Sergeant OFFICE -jF s-$Ri=F Edward L Schorpp Solicitor Arrow Financial Services LLC vs. Case Number Robert Moyer 2009-4658 SHERIFF'S RETURN OF SERVICE 07/16/2009 08:41 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on Jul} 16, 2009 at 2041 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert Moyer, by making known unto himself personally, defendant at 3 Richland Lane, Apt. T-2 Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, July 17, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff 2059869 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC VS. ROBERT MOYER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-4658 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $1,891.97 Less: Payments on Account ( $.00) Total: $1,891.97 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: ARROW FINANCIAL SERVICES LLC and that the last known address of defendant, ROBERT MOYER, 3 RICHLAND LN--APT # T-2, CAMP HILL PA 17011. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this day off 2009 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damag s assessed at the sum of , $2,683.74 as per the abov erti ica i W 1Q1 V-1.r GOW1 Pr honotary GORDON & WEINB G, P. BY: FREDERIC A NBERG, ESQUIRE JOEL M. INK, ESQUIRE Attorne for Plaintiff 2059869 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 Vs. ROBERT MOYER TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-4658 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT ROBERT MOYER 3 RICHLAND LN--APT # T-2 CAMP HILL PA 17011 DATE OF NOTICE/FECHA DEL AVISO: August 7, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 GORDON & WEINBERG, P.C. BY: FREDE C,I. WEINBERG, ESQUIRE JOEL . FLINK, ESQUIRE P10D-2 DF THE 209 SEP -2 F% 1: 5 ,; $14.oo Pry MnY &-*S8fl u I 2T* aw I I(,* A)a? laa?led 2059869 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 VS. ROBERT MOYER 3 RICHLAND LN--APT # T-2 CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. TERM : 09-4658 CIVIL NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. 1X/ Judgment by Default $1,891.97 ?L Money Judgment $ ?L Judgment on Award of Arbitrators$ L? Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 Adnq4 OTHONOTARY 9I-TI09