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Home My WebLink About09-7571.. f 41t -A Our File No.: 221623 , 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 L NO.. Oq -'7571 ?ttiL JAMES PETROU & NANCY PETROU 1810 WILLOW RD CARLISLE, PA 17013-1165 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 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 ) *ft Our File No.: 221623 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O 9 - '7s 1/ aj;,( u?- Plaintiff, vs. JAMES PETROU & NANCY PETROU 1810 WILLOW RD CARLISLE, PA 17013-1165 Defendant. 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 JAMES PETROU & NANCY PETROU, an adult individual residing at 1810 WILLOW RD CARLISLE, PA 17013-1165. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5458004614092656; 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 $5,290.39. 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. - -1% WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $5,290.39 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Pl ' i A Law Firm Engaged ' De Collection BY: David J. Ap(#haj?Z, Esquire Dated: 10/26/2009 Our File No.: 221623 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 t6 *worn falsification to authorities. David J. othaker, Esquire Attorney for Plaintiff DATE: 10/26/2009 ARROW FINANCIAL SERVICES LLC JAMES PETROU & NANCY PETROU 1810 WILLOW RD CARLISLE, PA 17013-1165 STATEMENT OF ACCOUNT Debtor's Name: JAMES PETROU & NANCY PETROU Account Number: 5458004614092656 Original Creditor: HSBC Balance Due: $5,290.39 Our File No.: 221623 EXHIBIT "A" s THc PRl ^T! R-",N0TARX 2009 NOY -2 Psi 3: Q$ J L rn vr C??? lSG8r3 ?a 3 2sZ3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 00,111, of Climb, OFFICE FTrc,?aal a Zug 101 -5 PM 2. 12 Arrow Financial Services LLC vs. James Petrou Case Number 2009-7571 SHERIFF'S RETURN OF SERVICE 11/03/2009 08:48 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on November 3, 2009 at 2048 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: James Petrou, by making known unto himself personally, at 1810 Willow Road 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. 11/03/2009 08:48 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on November 3, 2009 at 2048 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Nancy Petrou, by making known unto James Petrou, husband of defendant at 1810 Willow Road 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: $49.40 November 04, 2009 so s, R THOMAS KLINE, SHERIFF By ?eL Deputy Sheriff ;ci Count,Suite Shenff Teleosoft. Inc