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Home My WebLink About09-6650Our File No.: 220Q04 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. NOBALE A HUTCHINS 50 S 22ND ST APT 2 CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY ?? NO.. OQ - (p(o50 0_ N/i t -T rtrlfi 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.: 2200D4 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. NOBALE A HUTCHINS 50 S 22ND ST APT 2 CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. oq _ 4 G 6Z -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 NOBALE A HUTCHINS, an adult individual residing at 50 S 22ND ST APT 2 CAMP HILL, PA 17011. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185861037242322; 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 $1,310.21. 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 $1,310.21 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for P Oiff A Law Firm Engaged . D bt Collectioi BY: David J. Apothaker, Esquire Dated: 9/24/2009 Our File No.: 220004 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 sworn falsification to authorities. David J. Apoth er: Esquire Attorney for Plaintiff DATE: 9/24/2009 ARROW FINANCIAL SERVICES LLC NOBALE A HUTCHINS 50 S 22ND ST APT 2 CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: NOBALE A HUTCHINS Account Number: 4185861037242322 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,310.21 Our File No.: 220004 EXHIBIT "A" to) IILEIh:;FFtCE OF THE PRO ITJ DNOTARY 2009 OCT -6 Ali 10: 39 479.50 PO AITY Ck? 15x300 X31505 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Sheriffs Office of Cumberland County ALE1)--0 F E ?$?r?t? of ?u?rrbrrr? ? ?i 2069 0rT 20 AN 0, - 0 F4CE QF I -E SHERIFF Arrow Financial Services LLC vs. Nobale A. Hutchins Case Number 2009-6650 SHERIFF'S RETURN OF SERVICE 10/16/2009 07:38 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 16, 2009 at 1938 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Noble A. Hutchins, by making known unto herself personally, at 1009 Allen Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $56.80 October 19, 2009 SO ANSWERS, ??71I??? ? S ? w R THOMAS KLINE, SHERIFF ty Sheriff !~_~__~ . Our File No.: 220004 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 F, ,+~ ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. NOBALE A HUTCHINS NO.: 09-6650 Civil Action Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, NOBALE A HUTCHINS, in the default of an Answer, in the amount of $1,345.29 computed as follows: Amount claimed in complaint: $ 1,310.21 Less: Amount Paid: ( 0.00} Plus: Interest from September 24, 2009 to March 22, 2010 at the legal interest rate of 6.00% per annum 35.08 Attorney fees 0.00 TOTAL ~ $ 1,345.29 I certify that Defendant, NOBALE A HUTC~IN~, last known address is 50 S 22ND ST APT 2 CAMP HILL, PA 17011. David J. Apothaker, Esq. Attorney for Plaintiff Dated: March 22, 2010 $14. oo P ~ ArN ~'~ 17k4q~ R.~ ay oN/3 ~~~ ~ 1 Y OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: NOBALE A HUTCHINS 50 S 22ND ST APT 2 CAMP HILL, PA 17011 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. NOBALE A HUTCHINS NO.: 09-6650 Civil Action Defendant 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, Esc at this telephone number: 00-672-0215 ~f/13'lO A Our File No.: 220004 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. NOBALE A HUTCHINS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-6650 Civil Action 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 unsworn falsification to authorities. Pa.C.S.A. §4904, relating to David J. Apoth r, Esq. Attorney for Plaintiff Dated: March 22, 2010 Our File No.: 220004 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. NOBALE A HUTCHINS Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-6650 . 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 50 S 22ND ST APT 2 CAMP HILL, PA 17011. We inquired with the web site of the Defense Mz Wilson Boulevard, Suite 400, Arlington, VA 22209-25 branch of the military. Mary M. Snavely-Dixon, Director of the Def our inquiry indicated that the Defendant(s) is/are not i David J. Apotha`ker, Esq. Attorney for Plaintiff r Data Center, located at 1600 the Defendant(s) is/are in any Data Center has sent back 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. i of Bcfcnsr '~4aowes Data Ce~a 1lta-3~-2910 i 14:Ot5 y'iia~ Report Pfasuaat m the Smice F4I Civil 1te~tlFAct < 1ss! _ _ _ ~~~ Fintsariddle Betio Date AcNSe Dray 9hfas :~ctirr, Doh' Esd Dtte .. _.: Based oa time ~o you hac~ mod, the D~ doe5 not HL'ICHIIti°S NOB~i F A ;< parsecs any iron adicaong ehe mdn;3m! srahu. L~ the itfotnmaoan dnra baaits oCthe Dtparanznt ofDefenx }iat~owtr Datan Ct~ntsr, based oa the irfacnsn t9at you pcrnided, the abax is thr cwrerG sratcu of rite ivdruiNal as to a/ breaches of the Gufamtd Su;~es (rlrert, 2~ati7~, viarusc Caps, Air Farce, N4A+l. Pab6c HeaMe, sad Coast Gunrd). r~. ~,-~. ~iay li, Snavmiy-Dixon, Dirrchx Dcpartmect cd' Ikf~ - Ala~smti~er i}nta +Ctatar 1G00 ~'dsoa 13M d., Scale 400 ort ti":~ 22209-249? Ike Defense ~{aapc~wer D~a Cetetex (D?~lDC} as an orz afdse ACpart afUefcuse the ads ti~z Lkfansc Ea~cnt. and Rcpactiog Sys ~gR,g) die much is the affscir>F s~~e of data an ei~ty for n~tap mcdsa[ care atmd order ' sysieams. ~ >~ ~ ~ r~~~ of ~ s ~t~s eta i~ t~ Tr~c ~p ~~ poi ~ ; ~ a>d} l,SCRA) (i~i~rmeri±^ know3t as the Soldiers' a~ Sailor Cirvil Reaief Ari cf i9#t7}_ D~II3C has issued }>rmcireeis cFthaasaods of does a~ goxseu am infumafiaa iaic~ that the indn~iduai ~ ctxrmt}y en ae>rve duty respoo~es, and has e~rienced a ~mali crec ratr. ~ the ~~ tFse iod'isidnat :tferenced eba~+^e, or ~ f~; member, 6itud, a reixesmtaGti~ assorts >a any meaner than the mdnidaat g cm actnT dam, or is oilrniist cl~icd tor! the iacutcfiau o5 the SCRA, +;~ ore stroogfy eaxarraged to oirtam Ctrfhr~ very o£ the ixrsaa s status bt~ taacacong that geruai s Service v~ the 'delnit ma" LRl. u~ def~sc~c saYY` p~ L I DID. If :rov lmat~c ecideace i#~ pexsoa is oa gctis~ shay eqd }roe fz~ W attain his ad~ootrat Service vcri6catioa5 puce proves crFthe SC~A mad he ovodced aga~t yon. Sec SO US~C' App-. 642 i (c~ ~t'tirou+abtain sddu~td i~trnation abort dx persorm {c t, as SS".ti, iraproard accszracy dZJt]B, a t> tmaux}, }~oa core subaut Nor request aga$s at tlsis a'sb sitr ssd we ~~prcn~de s ore c~atr foe t~ query. I'luc res}rc~nse reAecta active that states B date rise iad'ni~f was }asst oo ~s~ dtn, if k w as whin tlx precedia$ ~6` dsy's. Far historical i~£namauan, please raetazt the Service Std points-oE-ca~ace ~tA~OM 7J~o/JMttlplr 07t ~fI1Vt ~t~1',StSLW~ Actier Sty slams as tcpor~ted a ~ ctza'6e~e is ~d m accordaase xvh 10 Z<5C ~ iOF~d}(i) far a perid o[ asorc than ? 0 coosecvEne days. ifl dee case of a mcmittr cd ~ tiatinaat Goad. ec7ndes sertuc rs>det a ca/ to attn~ smmcc aattkeaitrd by Usr President ar the Secretary' of Dafe¢se foe a period of tttae than 3~ cats;tat~cx da}~s trader 3. USC ~ S4~fj far putpotet et' to » aelionad rmagea~y dcd~cd by the Present and ~ b-; Federal f nds X111 Acrin~e Cnavd Rcscrv°e ~AGltj arxmtxrs xrssst be assigned against an art6orired mabiliza®en positive m the vet they sappcat This inchrdes Nary TARS. 13ari0e Caps r1Rs and ~Cosst Gerard RPAs_ Actie~e Doty stators also apples w a L~n~amed Srnticc membtr ~~ho is an ac~ve d~,° catrrissiomed office ddoe [-.5 PuEaic Hrstth Sm%ce ter the :atiooat tarrarsc and AtraospE>etic Adn<urastr~orc (*~'OAiI Canmessieaxd Corps3 flu a period cf'more than 30 ruoseculire dais C'm~~c ~ ieder thr ~CR.91 u.8rvadrs is .'fiaiaatr Casa Cmrrage ender the $CR,1 is hraadc o some rases. and inc~dcs carne categories of pasaas on actisr daty £or pssposcs of the SCRA w~ vc~ not be repdted as on Activr I7bty order this cat+fieate. unm~ Wines orders arc aauended to ezt®d the period of actn= daty, a}r~h a~arad esir~ SCRA prntrctiaos. Ferraris seclong to rely oc t6es weissiEe c+~cation shrrtdd chalk to make sere the orders oa ~,birh 5GRA protectiwts ore based hav~r eot bees amended to extend the iociasivf dates o£ serrice. Fcstlsesmore, some protecUOas of die 5CRA may extend to persons mho havt mm-ed ardas to report for aettce dory a ro be tiducicd, tot a$o hagxe eat brgrm actieT ~' or sctually reported tax iadsctiuo The Last Bate on Adz Dudp aah1- is ur{~Ottaar becartsc a usatrcr afixotcctions of SCRA ezterrd lxsoad tree last dffitt d active 3tv Ihosc who tti avid rely an this eerli$,eac ac argcd to seek qualdicd iegrd cumsei to emaar that all rights Suaaaerd to Senicx snentbears artder tlme SCRA ore protected ~'AR'V'L'v ~'r. TLis eerb'fact~tr a-as pracided based au a saw and SS'v ittosided b?' k!~ recgr~tQ- Pro+icfgg an e~-o~.,~ ~mc or 5S?r' w~ cause an errnaeoua date ha be prrnidcd keport IA 1CGTPISsGE 856 780.1000 856 780.1020f 215 634.8920 215 634.8421 f • 220004 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS • CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) NOBALE A HUTCHINS ) NO. 09-6650 } To: NOBALE A HUTCHINS 50 S 22ND ST APT 2 CAMP HILL, PA 17011 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: November 11, 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 DAVID J. OT AKER, 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 Our File No.: 220004 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC 22 F11 2*- 53 lip O R1 ?`?.1 0 COtlNT `cf4P4SYI_VA IA COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. NOBALE A HUTCHINS NO. 09-6650 Defendant PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER & ASS Attorneys fo A Law Firm En?aa it By: TES, P.C. bt Collection Esquire David J. A ,4 q,:5o