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Home My WebLink About09-6505t Our File No.: 221481 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - 65o5 Oltvi i Tens BELVIN L BANKS 415 S PENN ST SHIPPENSBURG, PA 17257-8702 Defendant. 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 FORT14 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 e. ? Our File No.: 221481 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. BELVIN L BANKS 415 S PENN ST SHIPPENSBURG, PA 17257-8702 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ® rT- G 5-0 ,sr CCL?j -rzz? 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 BELVIN L BANKS, an adult individual residing at 415 S PENN ST SHIPPENSBURG, PA 17257-8702. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5440455022506532; 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 $3,416.87. 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 $3,416.87 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney, for tiff A Law Firm EnRaRe m ebt Collection BY: David J. Dated: 9/22/2009 Our File No.: 221481 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 relatir)gto David J. falsification to authorities. uire DATE: 9/22/2009 ARROW FINANCIAL SERVICES LLC BELVIN L BANKS 415 S PENN ST SHIPPENSBURG, PA 17257-8702 STATEMENT OF ACCOUNT Debtor's Name: BELVIN L BANKS Account Number: 5440455022506532 Original Creditor: HSBC Balance Due: $3,416.87 Our File No.: 221481 EXHIBIT "A" ARN , F Tl-? : ?11 n f f2659 SEP 28 PCB 3: 11 Cu' ,ter *118. so PO Ary Gc. 15 IsD3 Rx?' aall? Sheriffs Office of Cumberland County R Thomas Kline iLED-.1101 hCE Sheriff OF TH^,-..dr ,tt! ?w,tp oaurtLrp? ,.,; ?T?7 Ron RAnderson 2009 QC T -7 Chief Deputy ? Jody S Smith CuM b Civil Process Sergeants N,? L INTY Edward L Schorpp Solicitor Arrow Financial Services LLC vs. Case Number Belvin L. Banks 2009-6505 SHERIFF'S RETURN OF SERVICE 10/02/2009 03:25 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2009 at 1525 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Belvin L. Banks, by making known unto Brenda Banks, wife of defendant at 415 S. Penn Street Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 SO ANS R October 05, 2009 R THOMAS KLINE, SHERIFF By De t S eriff ?~~~K1-'z_-- ...- APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215)634-8920 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC Plaintiff, vs. BELVIN L BANKS Defendant. COURT OF COMMONS PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-6505 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 this November 02, 2009, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, and Defendant, BELVIN L BANKS parties as follows: 1. Defendant agrees to pay the sum of $2,490.00, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid shall be paid by Defendant, BELVIN L BANKS, to the attorneys for Plaintiff in the following manner: a. $800.00 to be paid on or before November 30, 2009; b. $800.00 to be paid on or before December 30, 2009; c. $890.00 to be paid on or before January 30, 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 3. In the event Defendant, BELVIN L BANKS makes all payments as stated above, this account will marked satisfied when BELVIN L BANKS pays $2,490.00. e r ~ 4. In the event Defendant, BELVIN L BANKS fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff must notify Defendant's attorney(s), in writing of Defendant, BELVIN L BANKS's default. The name and address of Defendant's attorney(s) that notice will be sent to is: Mike Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 5. If the default is not cured within 15 days after written notice of Defendant's attorney(s), then Plaintiff has the right to obtain the entry of Judgment against Defendant, BELVIN L BANKS, ex parte, in the sum of $3,562.34, giving Defendant, BELVIN L BANKS credit for any sums actually paid pursuant to the terms of this Stipulation. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES Attorneys for laintiff A Law Firm En~a~e~i~-H~ebt Collection By: ---- - ~ ~ be y F. Scian, Esquire BELVIN L BANKS Our File No.: 221481 _ ~. ~= ~i ~ F ~ ( ~`?~~~Y .... ~t.. .._ LG;19 i''~'~`~ u~ ~i 1 v' ~ •; ~ ~,~ i ; r; C-~,'_. .~ -~.7~i ~,.~1r~~.~ ...