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Home My WebLink About09-6195Our File No.: 220519 APOTHAKER & ASSOCIATES, P.C. BY: David J.-Apothakei, 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. LINDA CHATLEY 42 BIG SPRING TERRACE NEWVILLE, PA 17241-9108 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0-401Q.5 a-tvit-Fem You have been sued in court. If you wish to defend against the claims set forth in the fol? wing 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 with ut 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 DON T HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH ELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TT 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.: 220519 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. LINDA CHATLEY 42 BIG SPRING TERRACE NEWVILLE, PA 17241-9108 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o4- 4,1? a"- -n. ) Defendant. 1 CIVIL ACTION COMPLAINT FIRST COUNT 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 LINDA CHATLEY, an adult individual residing at 42 BIG SPRING TERRACE NEWVILLE, PA 17241-9108. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor, ?n Interest of Account #4254480600572209; and said account was issued to Defendant(s) by WASHINGT41 MUTUAL BANK, the Original creditor. ?I 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 $4,847.47. A e 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 acl ?ount 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 $4,847.47 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney f 1 'ntiff A Law Firm Enga d in/Debt Collection BY: David J. Ap(k+?ker, Esquire Dated: 9/9/2009 Our File No.: 220519 f 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 truer d correct to the best of my knowledge, information, and belief. T dersigned understands that the stateme s therein are made subject to the penalties of 18 Pa.C.S.A. 4904 re ti to unsworn falsification to authorities. David J. Apo aker, Esquire Attorney for Plaintiff DATE: 9/9/2009 i LINDA CHATLEY 42 BIG SPRING TERRACE NEWVILLE, PA 17241-9108 ARROW FINANCIAL SERVICES LLC STATEMENT OF ACCOUNT Debtor's Name: LINDA CHATLEY Account Number: 4254480600572209 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $4,847.47 Our File No.: 220519 EXHIBIT "A" Q RLED-CYROE OF HLE ??'; r'1 1r f f 2009 SEP 14 PH 1: 14 $ G?°?Y F .y 4-M - So Pb ATr4 CI=A' tsoatt zr*, a W54o Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ?«tr of Curnbej,14# OFVJCE(; -.. 5"6i21t?F E; t 4. OF THE AIRY Arrow Financial Services LLC vs. Linda Chatley 20H 5i? 21 AN 8: ICU _ Case Number 2009-6195 SHERIFF'S RETURN OF SERVICE 09/17/2009 06:23 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 17, 2009 at 1823 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Linda Chatley, by making known unto herself personally, at 42 Big Spring Terrace Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.80 SO ANSWERS, September 18, 2009 R THOMAS KLINE, SHERIFF BY Deputy Sheriff Our File No.: 220519 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 ) Plaintiff, ) VS. ) LINDA CHATLEY ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-6195 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorne or Plaintiff A Law Firm Ed in Debt Collection By: DavidV. 4poth_ak6r, Esquire Dated: 10/20/2009 FILED-fir ,a OF THE PROTHONOTARY 2009 OCT 29 PM 3: 22 CUM8&%'. -,i%i - ,- OUNTY PENNSYLVANIA