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Home My WebLink About09-5111Our Fi18No.: 214141 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. GREGORY L JESELNICK 491 N 25TH ST CAMP HILL, PA 17011-2102 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (Q _ 6111 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.: 214141 • 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. GREGORY L JESELNICK 491 N 25TH ST CAMP HILL, PA 17011-2102 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 GREGORY L JESELNICK, an adult individual residing at 491 N 25TH ST CAMP HILL, PA 17011-2102. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4361479900011686; 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 $1,377.68. 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 $1,377.68 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enaai BY: Dated: 7/17/2009 6IATES, P.C. Debt David J. Apoth9cer, Esquire Our File No.: 214141 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 falsification to authorities. David J. A othaker, Esquire Attorne for Plaintiff DATE: 7/17/2009 ARB.OW FINANCIAL SERVICES LLC GREGORY L JESELNICK 491 N 25TH ST CAMP HILL, PA 17011-2102 STATEMENT OF ACCOUNT Debtor's Name: GREGORY L JESELNICK Account Number: 4361479900011686 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,377.68 Our File No.: 214141 EXHIBIT "A" O FILE OF THE 'CITAFY 2409 Jug. 27 Pit 2* 53 h?. SO Pa ATr`/ c l43a35 has Als7 Sheriffs Office of Cumberland County R Thomas Kline Sheriff ALED-C)FICE Ronny R Anderson 01111tr at c1flubrr11114 OF THE P``?'.`J*wTTARt Chief Deputy" 2009 AUG 19 AM 9: 13 Jody S Smith Civil Process Sergeant OFFICE OF 'HE SHERIFF ?MLJi t ? r Y f -WUNTy Edward L Schorpp PE NP %Ik4A. Solicitor Arrow Financial Services LLC vs. Case Number Gregory L. Jeselnick 2009-5111 SHERIFF'S RETURN OF SERVICE 08/14/2009 02:24 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 14, 2009 at 1424 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gregory L. Jeselnick, by making known unto Angela Jeseinick, wife of defendant,at 491 N. 25th Street,Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 August 17, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Sheriff Our File No.: 214141 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker 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 OF CUMBERLAND COUNTY Plaintiff vs. GREGORY L JESELNICK NO.: 09-5111 CIVIL TERM Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, GREGORY L JESELNICK, in the default of an Answer, in the amount of $1,399.34 computed as follows: Amount claimed in complaint: $ 1,377.68 Less: Amount Paid: ( 0.00) Plus: Interest from July 17, 2009 to October 30, 2009 at the legal interest rate of 6.00% per annum 21.66 Attorney fees 0.00 TOTAL $ 1,399.34 I certify that Defendant, GREGORY L JESELNI last known address is 491 N 25TH ST CAMP HILL, PA 17011-2102. David J. Api cer, Esq. Attorney for Plaintiff Dated: October 30, 2009 gr Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5111 CIVIL TERM Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF Our File No.: 214141 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC VS. Plaintiff GREGORY L JESELNICK PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dated: October 30, 2009 Attorney for Plaintiff %I A . I Our File No.: 214141 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC VS. Plaintiff GREGORY L JESELNICK Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5111 CIVIL TERM Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 491 N 25TH ST CAMP HILL, PA 17011-2102. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defense?& a?power Data rater has sent back our inquiry indicated that the Defendant(s) is/are not in t m i11 David J. Apo.ker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Delmatratot of Defense Manpower Data Center Oct-30-2049 0754:25 Mifitmy Status Report Prtrtasaot to to Sm%icr Members Cirg ReWA-t Last firstr a Beni Date Active Date States Attire Do" End Date Acen" 6RE60PY BSsedcadots om.-ni-, :ou ha? c fitraishett theDA,IWdoes pv ses;my ijornsajam i SFL .1C 1:: r ia3d ealne tfx ax5 aat smart Lpoa starcling tlae m6mammon banks of ate Deparkned oofDakm Manpower wer Data Carer, Eased on the rimumbon the You provided, the abmle is *e current of the i ridttal as to A bra of the L7miftmed Services (Amon,, Navy. Prilmihe Corps, Air Force, NOAA, Pubic He mW and Coast Gumd). 84t )4. V/ A 1, lilery M. Soavrty-D xom, Director Delmdated of Data Center 1600W on Blvd, Sufic 400 Attctgtom VA 22209-2593 The Defense Manpower Data Center (DUX) is an orgamizoom oftbe Departamat dD case that maintains dw DeSme Eara]hmat and . Repa:tmg Sysum (DEERS) d o which a the official soorceat'data an eligibility for nataay medical ewe and steer eligrbbty ss Aerm. The DoD strasglp supports the rsforcemeat of`di a Service Members Cn4 Rrfu f Ar;t (50 L?SC App § S 501 t3 scti as mumded) (SCRA) (format knmvn as the SoldmV roar! Sworn' Civil Relief Act of 1944). DNOC hau issued h mdreds cf thousands of "does not possess any information ndicat7ag that imlivikkud is cutready m acitivve dory" s+espon^ grad hers e4mieased a 9" creosote. ba the event the imckidual refrrewtd above, ac may famig number. friend or reps esat?ict asserts 'ores my mama dust individu al is on active duty, or is officnviso entitled to the protections of the SCRA, you are stvoaty enccu mged to obtain fnetlaer vvdfi :t;ti , a of 6t p s smui by coutmcdq do persWs S ke via the' eel" L'R2. $t ':tv ati dcfm c s SctmlfaaDat l `S 95'LDR }int. 1fyou Wv r;idmre tlst petscur is on activedury and }rou faa to obtain this asidd6ouat se l a vtrilicatioopunitive prrnisicns of the SCR'.A may be invoked againA you. See 50 L'SC App § s 21(c). If you ohnnp Wmnmfim about the pawn (e,&, as SSN, knproved accuracy cfDOB, a xmiddle amore), you can subtait your request againat this Web site and we wi l prmide a new ceatffieate for that emrny. 'this response, rests active Awy staters its rag deice the 6&vWjW wens hoar on active data, fit was wit the pmed 36'7 days. For historical please contact the Service SCRA points-of-c m mom ie#for on on "Active'Daw Sea ws" Active duty status as reported is this catficair is dcfimd in accordance with 10 USC § 10101) fax a period of more than 34 consecutive daft, In the case of amemeber: r (dw N ationd Guard, dudes service under a call to active sen ice authorizedby die president dw Secretary of Deffise, for a petltad of mofe that 30 conseauskm days trades 32 USC § 5020) for putposes of responding to a national declared by the P"44W and tnpposted by Federal fsmds. All Active Chard Rxsme (A GR) Viers min t be assigned against an ardonrized mcabal zation position in the unit they spurt This arck des Mary TARS. Marne Caps ARs and Coast Quad RPAs_ Ac my Daly also, apoks to Uni1ormed Service memberwiw is an active dirty co ssicoed o icer ofdw U, S, public Hea6 Service or Ow Watioaal Oceanic and Annosphe2 c Acitnimissradon (NOAA Co si ned Corps) Lot a period of more than -10 cousccrtmr chars Cm emgeUn*rOwSCR9it, madermWmeCam Cmvragt under the SCRA is broader n some cases and includes some categories of persons on active duty for purposes of the SCRA utto would not be reported as on Ar;tivr Duty under ttvs rertficae: Mmy times orders are amended to eatmd the period ofactim duty, which would extend SC1tA protections. Parsons staring to rehr an this webske a atim should check to make use the orders on which SCRA protections at based have no t been asnended to extend to ittdttsive dates. od strive Fstr€hftrtore, swwu of dwSCRA wAy extend to pessems have received ceders to repair for vx uitun ar to be iducted, but who have am achsaHy begin active duty t r' actually reported far induction. The Lag Date ern Active Duty euuyy is ' important because a number of ptotc bons of SCRA extend beyond test last dads of actim city. Thai who would rety on teas certificate are urged to seek quaffied:legal counsel to mome that all tights guaranteed to Service members, tamer the SCRA are prateected.. WAFUNL TG T Us ca tifice tr was proviaded based an a name and SSW prooided by the ccgoester. Prmidmg an mrouears moor at SSIV will cause an moomm certilkne to be provided- Report 1DVRIDI TAitib? - 214141 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) GREGORY L JESELNICK ) NO. 09-5111 CIVIL TERM To: GREGORY L JESELNICK 491 N 25TH ST CAMP HILL, PA 17011-2102 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 09, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR Q D ID J. APOTHAKER, ESQUIRE AP THAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 {mot i ?. { ?. ,ao? • ?t' + ? l e?'i 4: J ?t Oo .pis NTH co 16B-atob O- a43 dip OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: GREGORY L JESELNICK 491 N 25TH ST CAMP HILL, PA 17011-2102 ARROW FINANCIAL SERVICES LLC VS. Plaintiff GREGORY L JESELNICK NOTICE Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5111 CIVIL TERM Civil Action Pursuant to Rule 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. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 800-672-0215 I+/91 o