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Home My WebLink About09-6271Our File No.: 220640 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. RONALD W BORZA 412 ALLENDALE WAY CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 0 - (pvlril 0';Vil er" 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 objgctions 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.: 220640 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. RONALD W BORZA 412 ALLENDALE WAY CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: d 4- 1 ,,2 7 / dt?-d -7-4,6- 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 RONALD W BORZA, an adult individual residing at 412 ALLENDALE WAY CAMP HILL, PA 17011. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4465691400557258; 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 $2,433.35. 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 $2,433.35 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & SS CIATES, P.C. A Law Firm Enedized in( Debt BY: Dated: 9/14/2009 David J. Apolth T er, Esquire Our File No.: 220640 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. made subject to the penalties of 18 Pa.C.S.A. undersigned understands that the statements therein are to unsworn falsification to authorities. J. Apothaker, Esquire terrmly for Plaintiff DATE: 9/14/2009 ARROW FINANCIAL SERVICES LLC RONALD W BORZA 412 ALLENDALE WAY CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: RONALD W BORZA Account Number: 4465691400557258 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $2,433.35 Our File No.: 220640 EXHIBIT "A" . f 4 ' • 220640 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: ARROW FINANCIAL SERVICES Expiration Date: LLC Type of Action: Civil Action Defendant/s: RONALD W BORZA Serve Upon: RONALD W BORZA Address for Service: 412 ALLENDALE WAY CAMP HILL, PA 17011 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 0 Flti'! IG OF THE Pf'"? ;,'..NARY 2009 SGP IS PM 1: 12 CUtYar ^ r- 4 7S-So PO ATV e_t: ` Moqoa w4 &Bogioq Sheriffs Office of Cumberland County R Thomas Kline Sher Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ?,??r>,tt+ of ? ur?6erl??? ::. J1 OFFICE C THE SHERIFF FL %RY 2G99 SEP 2B 9, r 8: 42 9 Arrow Financial Services LLC vs. Ronald W. Borza Case Number 2009-6271 SHERIFF'S RETURN OF SERVICE 09/23/2009 10:30 AM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on September 23, 2009 at 1030 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ronald W. Borza, by making known unto himself personally, at 421 Allendale Way Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $55.00 SO ANSWER , e?r September 23, 2009 R THOMAS KLINE, SHERIFF BY Deputy Sheriff r ?. Our file No.: 220640 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 Plaintiff, VS. RONALD W BORZA Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-6271 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 October 15, 2009, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, and Defendant, RONALD W BORZA parties as follows: 1. Defendant agrees to pay the sum of $2,574.65, 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 $2,574.65 shall be paid by the by Defendant, RONALD W BORZA, to the attorneys for Plaintiff in the following manner: a. $643.66 to be paid on or before the 22nd day of each month, beginning October 22, 2009 through December 22, 2009; b. $643.67 to be paid on or before January 22, 2010. All checks are to made payable to ARROW FINANCIAL SERVICES LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 w . I4, " f Our file No.: 220640 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 $2,574.65, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to RONALD W BORZA by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff P" d-- FILED-0f-'FICE )F THE P""' 2099 NOV -2 PM 3: 10 Pr P?f N S`ll_VANIA Our File No.: 220640 ARROW FINANCIAL SERVICES LLC IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. RONALD W BORZA NO.: 09-6271 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: trri �. Issue a Writ of Execution in the above matter, cf)x 4 - _ c (1) directed to the Sheriff of CUMBERLAND County; p (2) against RONALD W BORZA, defendant(s); and :z> (3) against PNC BANK 105 NOBLE BLVD CARLISLE, PA 17013 and CITIZENS BANK 665 N EAST ST CARLISLE, PA 17013, Garnishee(s); (4) and index this writ in the judgment index (a) against RONALD W BORZA, defendant(s), and (b) against PNC BANK 105 NOBLE BLVD CARLISLE, PA 17013 and CITIZENS BANK 665 N EAST ST CARLISLE, PA 17013, as Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of Garnishee(s) as follows: Bank Attachment Only - All assets and accounts, including, but not limited to, bank accounts, brokerage firm accounts, stocks, cd's, insurance, safety deposit boxes, etc. (5) Amount Due $1311.10 Interest from March 19, 2010 $170.50 Minus Payments made $0 Plus Costs $179.00 Total $1660.60 c_s„ David J. Apothaker, Esquire SS•�0 � Attorney for Plaintiff(s) I I . eo k"k SL-- `� 11 C.e • a v0Y96 83 aga,8 �r,f �� fi suecj � a a � WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2009-6271 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ARROW FINANCIAL SERVICES, LLC Plaintiff(s) From RONALD W. BORZA,412 ALALENDALE WAY,CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: PNC BANK, 105 NOBLE BLVD.,CARLISLE,PA 17013 CITIZENS BANK,665 N. EAST STREET,CARLISLE,PA 17013-ALL ASSETS AND ACCOUNTS, INCLUDING,BUT NOT LIMITED TO,BANK ACCOUNTS,BROKERAGE FIRM ACCOUNTS,STOCKS,CD'S,INSURANCE,SAFETY DEPOSIT BOXES,ETC. and to notify the garnishee(s)that: (a) an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof; (2) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$1,311.10 Plaintiff Paid$ Interest FROM MARCH 19,2010-$170.50 Attorney's Comm. % Law Library$.50 Attorney Paid$176.50 Due Prothonotary$2.25 Other Costs$179.00 Date: 7/5/2013 David D. Buell,Prothonotary _ Deputy REQUESTING PARTY: Name : DAVID J. APOTHAKER,ESQUIRE Address: APOTHAKER & ASSOCIATES,P.C. 520 FELLOWSHIP ROAD,C306 P.O.BOX 5496 MOUNT LAUREL,NJ 08054 Attorney for: PLAINTIFF Telephone: 1-800-672-0215 Supreme Court ID No. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 3: L Sheriff rr fa_M Jody S Smith , rV Chief Deputy r`C.. }; Richard W Stewart 'rt Solicitor O.°-°E OFTkE Er LI T sue. r-- < U1 Arrow Financial Services LLC Case Number vs. 2009-6271 Ronald W. Borza SHERIFF'S RETURN OF SERVICE 07/12/2013 10:59 AM -William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Brianna Nornhold, Customer Service Rep., personally three copies of interrogatories together with three true and attested copies of the Writ of Exe ti and made the contents there of known to her. ILLIAM CLINE, DEPUTY SO ANSWERS, July 19, 2013 RON R ANDERSON, SHERIFF c;CountySuite Sheriff,Teleosof,,inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY -,may. 'Yn Z C- Ronny R Anderson Sheriff 0 ::0 CON Jody S Smith fc) CD Chief Deputy Q Richard W Stewart ) ;ttZ- Solicitor C.- C:) OFFICE OF TV-�,MEPOFV r- Arrow Financial Services LLC Case Number vs, 2009-6271 Ronald W. Borza SHERIFF'S RETURN OF SERVICE 0711212013 12:44 PM-Wiliam Cline, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Citizen's Bank,665 North East Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Becky Winter,Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on July 19, 2013 t aid W. Borza at 421 Allendale Way, Camp Hill, PA 17011. ILL CL/tE,aDE1111:= SO ANSWERS, July 19, 2013 RbNO R ANDERSON, SHERIFF (c)CouraySuito Shadtf,Telcosoft,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION ARROW FINANCIAL SERVICES, LLC Plaintiff(s), VS. 20096271 c MW c i F RONALD BORZA N cF 0 y7 C3 Defendant(s), =c::> Q�; and Cn fir. Citizens Bank of Pennsylvania, Garnishee. ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 10)At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of Pennsylvania, states that it maintains no record of any deposit account in the name of the defendant, RONALD BORZA, accordingly, no funds are being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me,the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Dara Wilkerson who being duly sworn according to the law deposes and says that she is the Legal Clerk, Operations Services, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Dara Wilkerson Sworn and subscribed before me this day of JULY, 2013. )AJAA '( Lfalam�2 N ary Public COMMONWEALTH OF PENNSYLVANIA N0tarial5eal public Penny 1.Donaldson Notary Clty of Pittsburgh, 11'e heny County My Commission Ex Tres Tan.N6 2617 MEMBER,PENNSYLVANIA ASSOCtA910N OP NOTA�I€N Certificate of Service I,Dara Wilkerson,hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage n ' prepaid,this �U day of JULY, 2013. DAVID J APOTHAKER, ESQ APOTHAKER&ASSOCIATES, PC 520 FELLOWSHIP RD MOUNT LAUREL,NJ 08054 RONALD W BORZA W 'v vv Dara Wilkerson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION 20096271 ARROW FINANCIAL SERVICES, LLC, ) Answers to Interrogatories Plaintiff(s), ) Code: 200 Execution VS. ) Filed on Behalf of Garnishee, RONALD BORZA, ) Citizens Bank of Pennsylvania Defendant(s), ) Counsel of Record for vs. ) this Parry: Nicholas Deenis, Esquire Citizens Bank of Pennsylvania, ) PA I.D.No. 62378 Garnishee. ) Stradley, Ronon, Stevens& Young Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355-1481 (484) 323-1351 (610) 640-1965 fax ndeenis @stradley.com www.stradley.com Our File No.: 220640 , APOTHAKER&ASSOCIATES, P.C. X1. ,z By: David J. Apothaker,Esquire Z�Z'- G-) 520 Fellowship Road C306 -<)t> cD ;' PO Box 5496 F' ' Mount Laurel,NJ 08054 _ez) (800) 672-0215 °�' r". Attorneys for Plaintiff * ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 09-6271 CIVIL TERM RONALD W BORZA ) Civil Action Defendant ) PNC BANK ) Garnishee ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, PNC K, dissolved. David J. A thaker, Esquire Attorney for Plaintiff C�t- pwk/ 4aq %SS SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff a r Jody S Smith } Chief Deputy 0l4 FED 26 � 2: Richard W Stewart Solicitor �,�� ..�°��. ,. .,�w ��r�B�i:�.A�� i�C�(.�, PEN SYLVANIA Arrow Financial Services LLC Case Number vs. Ronald W. Borza 2009-6271 SHERIFF'S RETURN OF SERVICE 07/12/2013 10:59 AM -William Cline, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Brianna Nornhold, Customer Service Rep., personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. 07/12/2013 12:44 PM -William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Citizen's Bank, 665 North East Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Becky Winter, Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on July 19, 2013 to Ronald W. Borza at 421 Allendale Way, Camp Hill, PA 17011. 02/25/2014 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $146.15 SO ANSWERS, February 25, 2014 RON R ANDERSON, SHERIFF .2 .D._ed .C' . r 6-0 (/L/Id, jd.) i -