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Home My WebLink About09-5100Our File No.: 214353' 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.: Oq -5100 Civil lerM MARK E LYNCH 1707 PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070 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 N,o.: 214353' 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. MARK E LYNCH 1707 PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 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 MARK E LYNCH, an adult individual residing at 1707 PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5049948099144828; and said account was issued to Defendant(s) by SEARS, 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 $3,746.87. 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. ' WHEREFORI?, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,746.87 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney r laintiff A Law Firm Enga ed ' Debt Collection BY: Dated: 7/22/2009 David J. Apdcer, Esquire Our File No.: 214353 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 to W)gw? falsification to authorities. David J. Apothakel;?'L? Attorney for Plaintiff DATE: 7/22/2009 ARROW FINANCIAL SERVICES LLC MARK E LYNCH 1707 PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due MARK E LYNCH 5049948099144828 SEARS $3,746.87 Our File No.: 214353 EXHIBIT "A" 0 Yr 2 029 . i)!_ ' 7 F I : 78-50 Po A 7N cr--* 1438 (o l aasyb9 Sheriffs Office of Cumberland County R Thomas Kline Al FC l:F iCF- r r r"I'.,-(-I.r ?f. .Sheriff C't? "C ?, . . Ronny R Anderson 44 Chief Deputy 2039 AUG -3 Ali : 29 Jody S Smith Civil Process Sergeant c,? OF rnr S"ER)FF - , rr- ,' Edward L Schorpp Solicitor Arrow Financial Services LLC vs. Mark E. Lynch Case Number 2009-5100 SHERIFF'S RETURN OF SERVICE 07/29/2009 04:47 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 29, 2009 at 1647 hours, he served a true copy of the within Complaint an Notice, upon the within named defendant, to wit: Mark E. Lynch, by making known unto Pam Chalhound, adult in charge at 1707 Peyton Randolph Court New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.30 July 30, 2009 SO ANSWERS, I R THOMAS KLINE, S ERIFF V Deputy Sheriff Our File No.: 214353 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NO. 09-5100 CIVIL TERM MARK E LYNCH Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS OC TES, P.C. Attorneys f r Plai tiff A Law Firm Engag d in D t Collection By: David J. Apothaker, Esquire Dated: 10/19/2009 OF THE: PR t E - >:AYDTAPY 2009 NOV 10 Alf 10: 05 pL1 ^. 1:{ E"L )ILr?