HomeMy WebLinkAbout09-7581Our File No.: 220201
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire, Esq.
Attorney I.D.W38423'
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.
HEATHER ENGLE
45 W MAIN ST
NEW KINGSTOWN, PA 17072-0575
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: Oq -'75$1 04vil (e'M
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
Our File No.: 220201
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.
HEATHER ENGLE
45 W MAIN ST
NEW KINGSTOWN, PA 17072-0575
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 09- 75-P/ ct? - j 7-4z'V1
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 HEATHER ENGLE, an adult individual residing at 45 W MAIN ST NEW
KINGSTOWN, PA 17072-0575.
3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of
Account #4185864380134757; 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 $3,402.85. 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
$3,402.85 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & ASSOCIATES, P.C.
Attorney for Plaintiff -
A Law Firm Engaged in Debt Vollectioi
BY:
David J.
Dated: 10/26/2009
Our File No.: 220201
VERIFICATION
David J. Anothaker, 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 relating4oworn falsification to authorities.
David J. Apotkker, Esquire
Attorney for Plaintiff
DATE: 10/26/2009
HEATHER ENGLE
45 W MAIN ST
ARROW FINANCIAL SERVICES LLC
NEW KINGSTOWN, PA 17072-0575
STATEMENT OF ACCOUNT
Debtor's Name: HEATHER ENGLE
Account Number: 4185864380134757
Original Creditor: WASHINGTON MUTUAL BANK
Balance Due: $3,402.85
Our File No.: 220201
EXHIBIT "A"
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QF I HE pn,, L-;f NOTARY
2009 HG'S` -2 PM 3: 40
"18.50 P D ATr/
C?IL? ??801)
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R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
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Arrow Financial Services LLC
vs.
Heather Engle
Case Number
2009-7581
SHERIFF'S RETURN OF SERVICE
11/05/2009 03:26 PM -Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on
November 5, 2009 at 1526 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Heather Engle, by making known unto herself personally now known as
Heather Miller, at 45 W. Main Street New Kingston, Cumberland County, Pennsylvania 17075 its contents
and at the same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $34.30
November 06, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
-~~.~
De ty Sheriff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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