The URL can be used to link to this page

Home My WebLink About09-6270A Our File No.: 220938 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. MELANIE S RAMOS 365 CRISWELL DR BOILING SPRINGS, PA 17007 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - (p6t% Owit Ter* 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 chimed 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.: 220938 APOTHAKER & ASSOCIATES, P.C. BY: David f. 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. ) MELANIE S RAMOS ) 365 CRISWELL DR ) BOILING SPRINGS, PA 17007 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O 9- 6 a 7 0 e-? - _F111 CIVIL ACTION COMPLAINT FIRST COUNT I. 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 MELANIE S RAMOS, an adult individual residing at 365 CRISWELL DR BOILING SPRINGS, PA 17007. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4888934999939399; 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 $7,494.78. 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 $7,494.78 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS C TES, P.C. Attorney fo 1 Ytiff A Law Firm Engage in bt Colledtioz BY: Dated: 9/14/2009 David J. ApokalZr, Esquire Our File No.: 220938 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 unde i 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. Ap haker, Esquire Attorney laintiff DATE: 9/14/2009 ARROW FINANCIAL SERVICES LLC MELANIE S RAMOS 365 CRISWELL DR BOILING SPRINGS, PA 17007 STATEMENT OF ACCOUNT Debtor's Name: MELANIE S RAMOS Account Number: 4888934999939399 Original Creditor: FIA CARD SERVICES N.A. (BANK OF AMERICA) Balance Due: $7,494.78 Our File No.: 220938 EXHIBIT "A" 0 OF THr "n^'r?T y 2009 SEP 18 PM 1: 12 *7s.50 p o A-r" cr-* 1so9oq e Awrl(03 Sheriffs Office of Cumberland County R Thomas Kline Sheriff?rtt', ofntufirrl; Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Arrow Financial Services LLC vs. Melanie S. Ramos Case Number 2009-6270 SHERIFF'S RETURN OF SERVICE 09/25/2009 04:32 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 25, 2009 at 1632 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Melanie S. Ramos, by making known unto herself personally, at 365 Criswell Drive Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 2009 1 ?.. ... iLL LJ tti?l r.• 1.1 SO ANSWER , September 28, 2009 R THOMAS KLINE, SHERIFF puty Sh ff r M Our File No.: 220938 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. MELANIE S RAMOS Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, MELANIE S RAMOS, in the default of an Answer, in the amount of $7,553.67 computed as follows: Amount claimed in complaint: $ 7.494.78 Less: Amount Paid: . ( 0.00) Plus: Interest from September 14, 2009 to November 5, 2009 at the legal interest rate of 6.00% per annum 58.89 Attorney fees 0.00 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-6270 CIVIL TERM Civil Action TOTAL / 1 $ 7,553.67 I certify that Defendant, MELANIE S RAM S, I t known address is 365 CRISWELL DR BOILING SPRINGS, PA 17007. David J. thaker, Esq. Attorney for Plaintiff Dated: November 5, 2009 Our File No.: 220938 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. MELANIE S RAMOS NO.: 09-6270 CIVIL TERM Civil Action Defendant CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF 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 of18 Pa.C.S.A. §4904, relating to Dated: November 5, 2009 unsworn falsification to authorities. f David J. Apothaker, Esq. Attorney for Plaintiff Our File No.: 220938 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. MELANIE S RAMOS NO.: 09-6270 CIVIL TERM Defendant 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 365 CRISWELL DR BOILING SPRINGS, PA 17007. We inquired with the web site of the Defense Wilson Boulevard, Suite 400, Arlington, VA 2220 branch of the military. , Mary M. Snavely-Dixon, Director of the De our inquiry indicated that the Defendant(s) is/are not Center has sent back David J. Apothaker, Esq. Attorney for Plaintiff r Data Center, located at 1600 the Defendant(s) is/are in any 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. Depa kaft t, of Defense lMaapower Data Center Mary Stator Report Pursuant to the Semite Members Civil Relief Act Nov-0.4-2009 11.05,06 Lost U& Dase Aedve Doty Stafts Atdh* Daclyfurl Dow,. htAliu M LA.tiIE Based mike afarmnoora y,w ha%e furm,bcd, the D1ID(. does" possess atr; won S 'iodicatiq;' sCC?rs. Upon seardwg; the ifinuabou data barks of the Dot ofDefease Mapawer Data Cower, based on dw riomuadon that you provided, site above is dw awr ew status of dre indr-i teal as to all branches afthe lWonned Services (Axuxy, Navy, Mum Carps, Air Force, NOAA, Pubic fieaW and Coast tel. Mary M. Saar dy-Dixon, Director Depaetmeet of Defense - Marpower Data Center IWO Wisen Blvd, Swot 490 Adasgton. NIA 22.109-2593 The Defer Manpower Daea Curter (MOC) is an *qpakabon of the Depar ment ofDekwe that; mantains the Defense Enrolhaeat and E y Repotting System ODEERS) database win& is the official some of adz an cliow fix nifitary medical ewe and odwr efigibay systems. T& Don stsamty supports The enf"arcemred of the Service Members CH Reld Act (54 USC App. §§ 541 et sm as amended) (SCRA) tag br wA%as the Soldier sad Sailtxi Cn3 RtWAd of 1949). aMDC has issued hundreds o(Sousands of 'does not possess away' iadirong shat the im& dad is a weary` an actin 4W Sees, and has experienced a amp error rats. In the ax?eat me t at refiurc d sbowe, or amxf' e* member, friend, or representative asserts in ary meaner dug Ilse inriwidstal is on active duty, or is owe ended to the ptotectioms of the SCitA, you are stro agcy mrarraged to obtain. 11rdw vefieatiae of the protean s swats by tooftaft do persons 5a+ke v a 1Me "dt efnicmF URL _= R'}?aas #mne ecidcmoe the psarsrar is on ax?vs dutir and yaofai kr ab4aiat the . additioash Service ver$cal on, pueiive provisions of the SCRA. map be invoiced s pinst yam See 541 VSC App. §,521(c) ff von obtaua about the person (tr g,, an SSN. kvrowxd ae ocy of DM a middy manor), }man can w tad you request again at d is web site and we VA provide a ww catiieate for dot query. Ilan nVoose re&cts active Arty status Wading date Ae wAvidoal was last on aotivx duty, fit's w tb preceziug 367 days. For historical ifermatioq please contact die Service SCRA poiaks-u f-co tsct- ,lt(arr i#jsraaa&x are "Acdw Daa4p Stow" ActiwSty statues as reported in this certificate is defined in accordarce with 10 USC § 141(d)(1) far a peood ofmore them 39 consecutive days. In due ease of a member of the' mioeal (Ward, i ndades service antler a calk to active senice arthea zed by the President or the Spy ofDdme for a period of more dm 30 cousecuM days under 32 USC § 'r9 purposes of responding to a national emergency declared by the President sad supported ire Federal firacls. AS Active Guard Reserve (AGR) members most be a nigaed against are and at ted mo an pos6em in the amt they rapport. This inhales Navy TARS, Marine Caryl ARs and Coast Gourd RPAs. Active Duty states aim apples to aLlyd'rxmad Service member wbo h an a chm duty commissioned officer ofdrc US. PoW Rea* Serice or doe I+latkw Ocezu is and Atmospberic Administration VNOAA Commissioned Craps) for a period of mere d= 34 consecutive days_ C~we Under dw SC14A it BraaAer is Sasser Ones Coverage under the SCRA is broader in some cases and iar3ades some categories of persons on active daty far purposes cf tr SC RA who would not be repomh as are Active Duty ender this certificate. Macey bats orders are amended to estemdthe prood ofsctive daty, vAsch world emend SCRA protectmos. Persons sceldogto rely oat di s webs" certficabrat shoedd dhe& to mace sere site orders on wbkb SCRA pcotr-c c are based hoe not bees amended w vcteod doe irshtsive dames of service. Fla!, score eons of the SERA may extend to pens= ,WW have uc,+-cd orders to report far actim Any or to be indscted, but who have sot actodly began active duty or actually reported far mdachon, The Last Date on Attlee Duty eatrv:b iafposiaat because a unr ber o(proteclians of SCRA estrod beyond dre lard dates ofactne day. Those who would rely an the certificate we urged to stet[ quaffied legal torrid to tr vs Heat al rights ga:remeed to Ser%we members under dw SCRA are potec? WARATL Q This certificate was prov dedbased on a name and SSN provided by &a rcgaw - Providing an tsromnrsas same of SIV waa cause an erronem cert6eate to be prwAded. Report M M2K9VMB81 220938 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) MELANIE S RAMOS ) NO. 09-6270 CIVIL TERM To: MELANIE S RAMOS 365 CRISWELL DR BOILING SPRINGS, PA 17007 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 19, 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 AVID J. APOTHAKER, ESQUIRE APOTHAKER & 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 np ^ i' :} 1 ?LLI ? } F oo P 04 a33coa9 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: MELANIE S RAMOS 365 CRISWELL DR BOILING SPRINGS, PA 17007 ARROW FINANCIAL SERVICES LLC Plaintiff VS. MELANIE S RAMOS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-6270 CIVIL TERM Civil Action NOTICE 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