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Home My WebLink About09-6269Our File No.: 220841 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. DONALD G ALEXANDER 91 ARNOLD RD ENOLA, PA 17025-2148 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - (oaco9 0"-NilTerpt 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 FORTHI? 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.: 220841 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. DONALD G ALEXANDER 91 ARNOLD RD ENOLA, PA 17025-2148 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O q. G z Co 9 04,i,l '7'-" r. 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 DONALD G ALEXANDER, an adult individual residing at 91 ARNOLD RD ENOLA, PA 17025-2148. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4559968417089302; 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 $1,171.29. 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". I , 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 $1,171.29 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS C ES, P.C. Attorney for 1 ' ff A Law Firm Engage in D bt CollecU6n BY: \1 X David I Apoth , Esquire Dated: 9/14/2009 Our File No.: 220841 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 and 1 ed understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating o orn falsification to authorities. David J. Apot aker, Esquire Attorney fo laint? DATE: 9/14/2009 DONALD G ALEXANDER ARROW FINANCIAL SERVICES LLC 91 ARNOLD RD ENOLA, PA 17025-2148 STATEMENT OF ACCOUNT Debtor's Name: DONALD G ALEXANDER Account Number: 4559968417089302 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,171.29 Our File No.: 220841 EXHIBIT "A" 0 2009 SEP 18 Pivi ( : 12 C lvlL,: ;_ 11iv v ?rov ? LNe?I' WeN. 419. Go PO AT" GL? ? 50Q0(o Sheriffs Office of Cumberland County R Thomas Kline Sheri r.,FPICE 4,c?HE S! ERIFF Fill OF THE R ; . TAR`S Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant 2009 SEP 23 AIN 9: 33 Edward L Schorpp Solicitor Arrow Financial Services LLC vs. Donald G. Alexander Case Number 2009-6269 SHERIFF'S RETURN OF SERVICE 09/21/2009 06:55 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 21, 2009 at 1855 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donald G. Alexander, by making known unto Ann Alexander, wife of defendant at 91 Arnold Road Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 September 22, 2009 SO ANSWERS, O' 4 l L 1000?? . R THOMAS KLINE, SHERIFF D f Our file No.: 220841 q APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. DONALD G ALEXANDER Defendant. DOCKET NO.: 09-6269 CIVIL TERM Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on September 30, 2009, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, apd Defendant, DONALD G ALEXANDER parties as follows: 1. Defendant agrees to pay the sum of $1,352.36, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $1,352.36 shall be paid by the by Defendant, DONALD G ALEXANDER, to the attorneys for Plaintiff in the following manner: a. $200.00 to be paid on or before October 2, 2009; b. $200.00 to be paid on or before October 16, 2009; c. $100.00 to be paid on or before the 15t' day of each month, beginning November 15, 2009 until paid in full. All checks are to made payable to ARROW FINANCIAL SERVICES LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road n Mount Laurel, NJ 0 U t5 O C T 0 7 2009 Our file No.: 220841 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $1,352.36, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parse application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to DONALD G ALEXANDER by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plajntiff A Law Firm Engaged ' ebf Collection r- By: 'm rly F. Scian, Esquire DONALD G ALEXA ER FILED FFI-mac r F ?c `7 Ry 2009 OCT 15 Ph 2: 3 2