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HomeMy WebLinkAbout09-5939* *yur Vile No.: 221726 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. PEGGY J MORRISON 5 PARKER RD NEWVILLE, PA 17241-9102 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0q--5q59 0'-wa-wrm 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 Aur l ik No.: 221726 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. PEGGY J MORRISON 5 PARKER RD NEWVILLE, PA 17241-9102 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 PEGGY J MORRISON, an adult individual residing at 5 PARKER RD NEWVILLE, PA 17241-9102. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5490355999841848; and said account was issued to Defendant(s) by FIA CARD SERVICES N.A. (BANK OF AMERICA), 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 $3,855.46. 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". .,a- . 17. 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 $3,855.46 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & OCIATES, P.C. Att orne 4din laintiff A Law Firm En g Debt Collection BY: David J. Nrpothaker, Esquire Dated: 8/26/2009 Our File No.: 221726 s *? S , 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 relatip o unworn falsification to authorities. David J Apothaker, Esquire Atto ev for Plaintiff DATE: 8/26/2009 ARROW FINANCIAL SERVICES LLC PEGGY J MORRISON 5 PARKER RD NEWVILLE, PA 17241-9102 STATEMENT OF ACCOUNT Debtor's Name: PEGGY J MORRISON Account Number: Original Creditor: Balance Due: Our File No.: 221726 5490355999841848 FIA CARD SERVICES N.A. (BANK OF AMERICA) $3,855.46 EXHIBIT "A" Q OF THE -i AF?Y 2009 A U G 31 P'li 12: Q2 .! fY t1(V. :N r . 4I8 • SO P Q ?Trl co 14tqLoq e aaga83 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant opF = F r?E? FF Edward L Schorpp Solicitor OF THE PPOTHOMARY 2009 SEP -8 AM 10: 35 CUMOEHI'lA-40 ;COUNTY PEfVMYLV'ANI.4 Arrow Financial Services LLC vs. Peggy J. Morrison Case Number 2009-5939 SHERIFF'S RETURN OF SERVICE 09/03/2009 03:58 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on September 3, 2009 at 1558 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Peggy J. Morrison, by making known unto Joe Morrison, husband of defendant at 5 Parker Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $38.80 SO ANSWERS, September 04, 2009 R THOMAS KLINE, SHERIFF it ;_1 - Deputy Sheriff Vur t't1e No."' 1l 1726 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. PEGGY J MORRISON 5 PARKER RD NEWVILLE, PA 17241-9102 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Q Q I . Plaintiff is ARROW FINANCIAL SERVICES LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. - ? 11qr e-e Not- 2. Defendant(s) is/are PEGGY J MORRISON, an adult individual residing at 5 PARKER RD NEWVILLE, PA 17241-9102. --,T 6Lq r1V- PJ41A 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5490355999841848; and said account was issued to Defendant(s) by FIIJA CARD SERVICES N.A. (BANK OF AMERICA), the Original creditor. ,/1( fjxu-??' r", 4. Defendant received, accepted and used the account to its benefit. ?d P4. 5. This account is in default and Defendant(s) has an unpaid balance of $3,855.46. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 00 pj0A 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". It da AA A ?P t ' 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. IU6 P1'A` WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of this Court award costs to the extent permitted by applicable law. and requests 174 eA-4-15. P?DA4Mi ?1. 1 eta f ?(Scrn au a W?d Qlis?64 VERIFICATION PEGGY J. MORRISON hereby states that I do not agree with this action `and I am authorized to take this verification, and the statements that I made in this foregoing Civil Action Complaint by Arrow Financial Services are not acceptable to the best of my knowledge, information, and belief. The undersigned understands the statements Arrow has made but does not agree. ?K-E,6 Date : 9/15/2009 FILE U OF THE F'' YTARY 2009 SEP 17 P 3: t; 8 Our File No.: 221726 ARROW FINANCIAL SERVICES LLC ) Plaintiff ) VS. ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-5939 PEGGY J MORRISON ) Civil Action c -p3 o 0 -n -4 Defendant ) z rn o rrn Y:F0 (nr- c N -vr" rri -: ?= t0 O© PRAECIPE FOR APPOINTMENT OF ARBITRATORS z ° o a x -'? o TO THE HONORABLE, THE JUDGES OF SAID COURT: D'a C) rn Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfully represents that 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $3855.46. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff Benjamin J. Cavallaro, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully j mitted, 1.2q. ab?a 11 cl?+ s??q November 19, 2010 Be J avallaro, Esquire .2-V o ORDER OF COURT AND NOW, and 20_, in consideration of the foregoing petition, Esq., and Esq., as prayed for. Esq., are appointed arbitrators in the above captioned action By the Court, RECEIPT FOR PAYMENT ------------------- ------------------- .. Cumberland County Prothonotary's Office Receipt Date 11/29/2010 Carlisle, Pa 17013 Receipt Time 15:30:09 Receipt No. 251692 ARROW FINANCIAL SERVICES LLC (VS) MORRISON PEGGY J Case Number 2009-05939 Received of PD APOTHAKER & ASSOCIATES IM Total Non-Cash..... + Total Cash......... + Change ............. - Receipt total...... _ 24.00 Check# .00 .00 $24.00 8534 ------------------------ Distribution Of Payment ---------------------------- Transaction Description Payment Amount APPT OF ARBITRA 24.00 CUMBERLAND CO GENERAL FUND $24.00 Our File No.: 221726 ARROW FINANCIAL SERVICES LLC Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-5939 c PEGGY J MORRISON ) Civil Action -t,3 o 0` -nn --i Defendant ) /C XM CZ M_ , E Na < r -x d 9 : PRAECIPE FOR APPOINTMENT OF ARBITRATORS -'<C:' C- v --I,4 =-n Q- ) ZO Me n Zc`? TO THE HONORABLE, THE JUDGES OF SAID COURT: 5 ^? X D Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfully represents that 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $3855.46. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff Benjamin J. Cavallaro, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully Submitted, V?1(.Obd„l( CI&? 8?? 1 November 19, 2010 Be am' J avallaro, Esquire IRA- -2-V 4.4 ORDER OF COURT AND NOW,. in consideration of the foregoing petition, Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action as prayed for. r? r.3 ,C? r- ? 1 GL&" _p ?z c+ "? tC7 By the Court, -V rri :ZI c3 nn _o 3>C N ?? CJ A<,eO tA/ r/ /?fM/U« L 5E4 ?I c 6- s L L C Plaintiff PE?? M Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 0 9 - 5-9 3 9 Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharsze the duties of our office with fidelity. Sig tore .1Ac,4?aE .,,V4 /1'1. ?6CAIC Name (Chairman) LAw OF Pie--r OF -TAC-QUg-j 1n/E M. VI-9 ME V Law Firm '=1't .$. RAn/oVG,-' S 7 Address CA,ZL-St?-4 toA- l701 3 City, Zip Award Signature /4 A L4F Name Law Firm Address cu / ? /e 0 / 70,(3 City, Zip We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the a-b folllowin award: (Note: If damages for delay are awarded, they shall be separately stated.) 4?- - T . PA4 T. 6O GLNS ? l '?` i r h A !? NO? 4 -y ; j ,e.? k g-rL ,4y6£ 4 trc AW-0 1? i n No -r ?a £ v Gu, rN ss 'o Xh,h/ -rs . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: a -/6 f/ / Date of Award: P- - i (a - / Name L4,0, Law Fir Address 1A 1704F City, Zip Notice of Entry of Award Now, the I_ day of r-ejo , 20 11 , at P/7 , .M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 350-60 By: Prothonotary Deputy FILED-OFFICE h THE PROTHONP-fpp_, j I FEB 16 PPS (: 1 -f PF NS Yj_V4 j t, f3eqjci,,, J-_ Ca vq lla ro, .1, ? PV v Morrison p; e5 yrt a , 7 ed 3? /?f l l ?? i