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Home My WebLink About09-64384 Qur Filz No.: 221551 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. TONI E MCKEE 1418 BRADLEY DR APT E112 CARLISLE, PA 17013-1264 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O9- (oy38 0-'4-v'tt L-orN- 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 $ELOW 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 46 Qur File No.: 221551 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. TONI E MCKEE 1418 BRADLEY DR APT E 112 CARLISLE, PA 17013-1264 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D 9- L H 3 8 czxr Tug 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 TONI E MCKEE, an adult individual residing at 1418 BRADLEY DR APT El 12 CARLISLE, PA 17013-1264. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5458001552360301; and said account was issued to Defendant(s) by HSBC, 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 $7,042.08. 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 $7,042.08 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney fo tiff A Law Firm Enaa d in/Debt Collection BY: Dated: 9/21/2009 David J. Aog er, Esquire Our File No.: 221551 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 relating to pr6worn falsification to authorities. David J. Plaintiff DATE: 9/21/2009 ARROW FINANCIAL SERVICES LLC TONI E MCKEE 1418 BRADLEY DR APT El 12 CARLISLE, PA 17013-1264 STATEMENT OF ACCOUNT Debtor's Name: TONI E MCKEE Account Number: 5458001552360301 Original Creditor: HSBC Balance Due: $7,042.08 Our File No.: 221551 EXHIBIT "A" 0 D } ? CE 0T Ti 2009 SEP' 25 i"d ! : 19 'I8.5o PO AT'ty 0015(555- 04 a23(O3(, Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ~a~~U' ~Y "~n+ut~Fr,Fr w ~ '`td 4th F .' G :- ~~ ,:I~. ~''r rr j ' n- ~ i ~r'j ~'~~}y ~'C . ,_~ SIT 2i~Q9 OCT 14 ~j 3~ C$ Arrow Financial Services LLC vs. Toni E. Mckee Case Number 2009-6438 SHERIFF'S RETURN OF SERVICE 10/07/2009 07:09 PM -Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 7, 2009 at 1909 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Toni E. McKee, by making known unto Mike Mckee, adult in charge at 1418 Bradley Drive, Apt. E112 Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $32.50 October 08, 2009 SO ANSWERS, ,~''.~'....~wt~..~ R THOMAS KLINE, SHERIFF E~~ Deputy Shariff -. r_ T - t ~ - 7,,,rx ,.. i 1. ,, Our File No.: 221551 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 vs. Plaintiff TONI E MCKEE Defendant 2C1Qx,~J, l3 r~ill~' w~~ .Y ; ,~;. Uivi-~: _ _ .._ i COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-6438 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, TONI E MCKEE, in the default of an Answer, in the amount of $7,241.12 computed as follows: Amount claimed in complaint: $ 7,042.08 Less: Amount Paid: ( 0.00) Plus: Interest from September 21, 2009 to March 22, 2010 at the legal interest rate of 6.00% per annum 199.04 Attorney fees 0.00 TOTAL $ 7,241.12 I certify that Defendant, TONI E MCKEE,1 t own address is 1418 BRADLEY DR APT E112 CARLISLE, PA 17013-1264. David J. Apbthaker, Esq. Attorney for Plaintiff Dated: March 22, 2010 ~I~. oo PA ATrI ~~ a~byis ~~ ~~ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: TONI E MCKEE 1418 BRADLEY DR APT E112 CARLISLE, PA 17013-1264 ARROW FINANCIAL SERVICES LLC Plaintiff vs. TONI E MCKEE Defendant NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-643 8 Civil Action 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, Esc at this telephone number: 800-672-0215 '`f~3//O Our File No.: 221551 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. TONI E MCKEE NO.: 09-643 8 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 Certifi 'on are true and correct. I understand that false statements herein are made subject to the enal ies of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. 1~ David J. Apothaker, Esq. Attorney for Plaintiff Dated: March 22, 2010 221551 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) TONI E MCKEE ) NO.09-6438 To: TONI E MCKEE 1418 BRADLEY DR APT E 112 CARLISLE, PA 17013-1264 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 30.2009 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 Isl DAVID J. APOTHt~KER, 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