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Home My WebLink About09-5112Our File No.: 214281 , 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.: Civil 16"4 KENNETH L STINE 2 STROHM RD SHIPPENSBURG, PA 17257-9632 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 No.: 214281 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. KENNETH L STINE 2 STROHM RD SHIPPENSBURG, PA 17257-9632 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 KENNETH L STINE, an adult individual residing at 2 STROHM RD SHIPPENSBURG, PA 17257-9632. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4730680125122000; and said account was issued to Defendant(s) by HSBC, 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 $1,595.39. 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 $1,595.39 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for ntiff A Law Firm Engage in ebt Collection Dated: 7/17/2009 BY: David J. A Esquire Our File No.: 214281 VERIFICATION David J. Anothaker, 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 worn falsification to authorities. David J. Apothkeer, Esquire Attorney for Plaintiff DATE: 7/17/2009 ARROW FINANCIAL SERVICES LLC KENNETH L STINE 2 STROHM RD SHIPPENSBURG, PA 17257-9632 STATEMENT OF ACCOUNT Debtor's Name: KENNETH L STINE Account Number: 4730680125122000 Original Creditor: HSBC Balance Due: $1,595.39 Our File No.: 214281 EXHIBIT "A" 0 F'LEC s ;F; ' CF TPE 2009 J' 27 PIM 2: IS C, ?FY *,I8.5o p o AITV cj?`# ljF3a33 eo?a$4sq Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant d.°?atp cf ?. um6crl??? 'Jr OFFICE C F THE $?,ERIFF FCLBj- = L ?F THr- r '. f?T,?fiY M9JU 31 P= 2:01 Edward L Schorpp Solicitor Arrow Financial Services LLC Case Number vs. Kenneth L. Stine 2009-5112 SHERIFF'S RETURN OF SERVICE 07/28/2009 06:50 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 28 2009 at 1850 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kenneth L. Stine, by making known unto himself personally, defendant at 2 Strohm Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 July 29, 2009 SO ANSWERS, Whom. R THQMAS KI-Ok, SHERIFF ty SFieriff w Our File No.: 214281 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 Plaintiff vs. KENNETH L STINE Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KENNETH L STINE, in the default of an Answer, in the amount of $1,620.59 computed as follows: Amount claimed in complaint: Less: Amount Paid: Plus: Interest from July 17, 2009 to October 30, 2009 at the legal interest rate of 6.00% per annum Attorney fees TOTAL I certify that Defendant, KENNETH L STINE, SHIPPENSBURG, PA 17257-9632. $ 1,595.39 ( 0.00) 25.20 0.00 $ 1,620.59 address is 2 STROHM RD COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5112 CIVIL TERM David J. A'13?Qthaker, Esq. Attorney for Plaintiff Dated: October 30, 2009 Jr r Our File No.: 214281 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 KENNETH L STINE Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5112 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 PRAECIPF, 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. David J. Apothaker, Esq. Attorney for Plaintiff Dated: October 30, 2009 r N Our File No.: 214281 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. KENNETH L STINE Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO.: 09-5112 CIVIL TERM Civil Action 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 2 STROHM RD SHIPPENSBURG, PA 17257-9632. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-259 , If the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defens power Dat enter has sent back our inquiry indicated that the Defendant(s) is/are not in t e ilitary. David J. Apothaker, 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. DqmW*A of Ddeude -- utver Does Center 3dilkiffy sum Report Porsa t to Ow Shaer `-etsbees 04 ReWAct < Lasi d'rattlfrddde $a& bate Avfwo 'MF?fYM Dirty Status ST tact-30-2449 47355 22 ,Axtiva Doty Fri Date Serzire Ajewy_ ?_c\, uFH Rasedxi thrcrtxn c<<<xaTu4v= fiarr ,,theL?'t4,>K,:dcesmaposse>san?riinf6rss.:t'' L jD&CaWag the iadn*VW status- Gprem seatzbr4 ` ihwr' data baaales of ihe Departnest ofDefense Manpower Data Center. bred on she ` shat isfirtunazon you grin dw above is The curreat sutra of *e iodvidtail as to All brambes of due lasImmed Sa%ices (Amty, NarvyMmine Corps,; Air Force, NOAA, Public Fiealk and Coast *?d). -Macy M. S an dy*-Dnux , Director Departned rNbaripma Data CerAff 1bhOWjls=RKl d;Suite400 Arlingtoo, VA _209-2543 The Defense Mmipower Dam Ccow (D'wU)C) a an orgarwdoo ofibe Department o(l a are than malistams ' the Defe e Eatollment and Elillibility Reporting System (DEERS) database wdicla is de official source of data on clillibility for wady medical care and spstents. The DoD straw suppomdw m£arcemmt of the Sm r %lrmbcrs Crd Ralf Art (50 LTSC App. §§ 'Sell et serf, as aaneneled) (SCJW Oxwerly known as the Soldiers and Sagas C 1i Mief Act of 1944). D-N4DC Naas issued hisadreds of of `clues mat possess my itmastim naafi xvg duet dw indivildsol a enrre* co active dutyO'svspoases, stad hers c eased a small Ofor ratr bathe cnVo 4se mckidual refereaced abMV or any faam'ly awe aaber, fiientl, orreprestamaive asserts in my m?acr dead dh r iocli+i hip is on awe duty. or is mite ise entitled to the prokTtions ofthr SCRA, y we to obtain faw*ft of lac peewee's bus b±, coatactiq dot person's Son im via Ow "diefenseUvwr L'RL " vvXya'. - 4.g5L„-,.F,.WY Vu bane evidence the pe"cm is an active Any aew41 Yore to obtaaa this additional Service verification, punitive prov signs of di-- SCRA tae be inw*ed against you. See M USC App. §521(c), #f you a?c aboax the {c.g., err SS2+i, ia?rovYd a4 eetaey afDGtLl,,a tasac),1 can submit your request again at des W6 sae and we vkA provide anew certificate fox that query. This rewom rd" active AW staters ' ' dw the ' was Won activre 40M irk vas s tbe. Pw4ding 35' day s. For destarical information, please co tact the Service SCAA paites-rte coaitsct. Mom igforwra den an "Active DwyShusts' Active the status as. repacted is dus; catificatcis defined to accordance with lid GSC § 141(d?l) for a per od afmoce don 30 coaserwwdve daps. In the ease of $ of the Zatuaoat Guard iorhaa3es se t unifier a alto ware service aud"iredby dx PreA dm or ttwe Sa w of'Dekase nx a period ofinece dwaa 30 constcuth-t days under 32 USC § $020 for prposes o( r i to a declared by the Wesulrnt and sWpcstrd b - Federal fiands. All Active Guard Rewv r (AGR) rmembas rat be assigned Agmest as mabotized mobilization posdion m tie unit they sappott. Ibis includes Navy TARS. %wine Corps ARs and Coast Guard RPAs_ Active Ditty stams afw air es to a Vnfirmed Serve nieutber who is an active duty coumaissionad o(ker saf tine U.S. Pulahc Reatth Srrv ve or dw :.'mated 4ce is and Atmcspdwrtic Adatinistranion (NOAA Cu mrris4m=d Carps) far apes od af'mcrs ddLm3 i1 cvvsecutne days. C.r ttWe Under d w SCP-4 fiea?VOArrin FoaW Ga€es C nmrage under the SCR.A is broads so see rases and incledes some categories of persons on active deny fix purposes ofdw SCRA who would net be tepo ted as on Atl v t Duty under &s c a cate. Man bows orders ate ansended to mdood the prttod of active daty . N&A would ea cod SCRA prestechons. Persons seckng to rely on dhs webste ce tfiicatim should dueck to emadre. are the ot dens on which SCRA protections are based bane met been amended to aatead due ixlusk dates of serice. F e, soune protetfinas of tine SCRA may extend to parses wbo have rcc&-ed orders to report for active duty or to be iodacted, but who have not actually began active duty or actually reported for ioductian. The Last 1 on Active D aty ebbs- kpatact because a number 4protectious of SCRA extend beyond the Gast dates of w1mv drew Those who would tel: on Heir certificate are urged to seek 4 oaMed:legal counsel to ensure that ad n&S ga m anteed to Service uxubers tua det rho 1, CILA me protected. W AILN-L 'G_ This certi&c arc was provided based on a name and SSSN provided by ttae me te- Protidinag an earotxan name or SSN w& cause an easomeatas cerrikate to be pr4 d_ ilepottWERV30DDI r 214281 OFFICE OF THE PROTHONOTARY .r COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) KENNETH L STINE ) NO. 09-5112 CIVIL TERM To: KENNETH L STINE 2 STROHM RD SHIPPENSBURG, PA 17257-9632 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 08, 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 J I 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 PIED ?. r rn.RY e??` ? ?3e9 xssa o Nalu.?-1.?a.?l'? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KENNETH L STINE 2 STROHM RD SHIPPENSBURG, PA 17257-9632 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. KENNETH L STINE Defendant JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS _ JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS _ JUDGMENT ON WRIT OF REVIVAL NOTICE NO.: 09-5112 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 IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 800-672-0215 u/9/cl