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Home My WebLink About09-6812Our File No.: 221693 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. BRUCE L GIPE 1 MIDDLE ACRES NEWVILLE, PA 17241-9601 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: N- J S61 onv; k NOTICE Ie N 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 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.: 221693 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. BRUCE L GIPE 1 MIDDLE ACRES NEWVILLE, PA 17241-9601 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 BRUCE L GIPE, an adult individual residing at 1 MIDDLE ACRES NEWVILLE, PA 17241-9601. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5488975030250909; 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 $993.53. 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 $993.53 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS? TES, P.C. Attorney for 1 ' iff A Law Firm Enmedin ebt Collection BY: Dated: 10/7/2009 David J. Our File No.: 221693 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 relatinoo "`worn falsification to authorities. David J. A* Attorney DATE: 10/7/2009 ARROW FINANCIAL SERVICES LLC BRUCE L GIPE 1 MIDDLE ACRES NEWVILLE, PA 17241-9601 STATEMENT OF ACCOUNT Debtor's Name: BRUCE L GIPE Account Number: 5488975030250909 Original Creditor: HSBC Balance Due: $993.53 Our File No.: 221693 EXHIBIT "A" 0 OCT 1 3 PM 3: 07 VA?', *98.50 00 ATM elf,-,t 158{11'1 pr's a3i8qy Sheriffs Office of Cumberland County R Thomas Kline r Sheriff OF TW RO MY Ronny R Anderson 2199 OCT 26 AM 9: 16 Chief Deputy Jody S Smith f" AZ COLM Civil Process Sergeant PENNM Edward L Schorpp Solicitor Arrow Financial Services LLC Case Number vs. Bruce L. Gipe 2009-6812 SHERIFF'S RETURN OF SERVICE 10/21/2009 01:02 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2009 at 1303 hours, he served a true copy of the within Complaint and Notcie, upon the within named defendant, to wit: Bruce L. Gipe, by making known unto Bruce L. Gipe personally, at 1 Middle Acres, Newville, Cumberland County, Pennsylvania, 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $38.80 SO October 22, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff M Our file No.: 221693 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. BRUCE L GIPE Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-6812 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 November 04, 2009, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, and Defendant, BRUCE L GIPE parties as follows: 1. Defendant agrees to pay the sum of $1,114.83, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $587.64 have been applied to the amount of $1,114.83, and the amount due and owing as of November 04, 2009 is $527.19. 3. The sum aforesaid of $527.19 shall be paid by the by Defendant, BRUCE L GIPE, to the attorneys for Plaintiff in the following manner: a. $527.19 to be paid on or before November 30, 2009. 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 ~ ~ 1~' ~ ~l~ ~I ~ i ._ i _a~a " Our file No.: 221693 4. 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 pane, in the sum of $1,114.83, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex pane application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to BRUCE L GIPE by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Pla tiff A Law Firm Ensa~ed in ebt ~~ectio~ By: F UCE L IPE ~_r r s / i! ,'~ ~~vr/.._ _ i.~l ~; ~ 11 ~i5