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HomeMy WebLinkAbout09-7611t THIS IS AN ASSESSMENT 2063839 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES, LLC 600 Broadhollow Road, Melville, NY 11747 COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : QQ - rl of I civit-Em MATTHEW HOCKLEY 120 BRYCE ROAD CAMP HILL PA 17011-1324 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 JUDGEMENT 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, 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 I' 1% COMPLAINT IN CIVIL-ACTION 1. Plaintiff, ARROW FINANCIAL SERVICES, LLC a debt buyer and successor in interest to the original creditor, GE MONEY BANK. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the original creditor under the terms of which the original creditor agreed to extend to defendant(s)the use of original creditor's credit facilities. 3. Defendant (s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the original creditor for the use of said credit card. 4. The defendant (s) received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the original creditor. A true and correct copy of the Statement of Account, if available, is attached hereto as Exhibit "A". 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of August 28, 2009 in the amount of $1,945.73. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 1' a 7. Defendant's last payment on account was made on 2/7/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,945.73 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff POIP.DB w 2063839 39489774 Arrow Financial Services, LLC MATTHEW HOCKLEY 6020521400041768 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. 54904 which provides for certain penalties for making false statements. EXHIBIT "A" 2063839 ARROW FINANCIAL SERVICES, LLC MATTHEW HOCRLEY 6020521400041768 State of Illinois County of Cook AFFIDAVIT being duly served sworn according to law, depose and say that: 1. I am employed as the legal outsourcing clerk for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case and base this affidavit on Plaintiff's records, as well as the account information provided to Plaintiff by Gs MONEY BANK when GE MONEY SANK sold the account to Arrow Financial Services, LLC. 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $1,305.64 plus interest of $592.29 at the rate of 24.75% less credits in the amount of $.00 totaling $1,897.93 as of July 5, 2009. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct o the best of my knowledge, information and belief. ?t ?, AFF T Sworn to and Subscribed before me this day of , 2009 Notary Public "OFFICIAL SEAL" Nicole Notary Public, State o Illinois commission Expires 4/6/2011 G) FCE OF TXHPt? OTARY 2009 NOV -4 PH 1: 00 08. SD PA I% tl t-pL RDy 03 e o23a981 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 ~Qt~~ti~T, ;~f ~ar;I~Gt~r~~~ ry -~ -~ I~~rls-.--.. ~~..~_ i"ri~w ~. ryfl ~int~ ~ '~ ~~ ~ 7 Arrow Financial Services vs. Matthew Hockley Case Number 2009-7611 SHERIFF'S RETURN OF SERVICE 11/06/2009 04:22 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 6, 2009 at 1622 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Matthew Hockley, by making known unto Erin Buffington, adult in charge at 32 Oak Avenue Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $55.00 November 09, 2009 SO ANSWERS, ~ili~/'v~riK ~..~~ R THOMAS KLINE, SHERIFF By u y Sheriff CORDON & WEINBERG, P.C. BY: FREDERTC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES, LLC vs. MATTHEW HOCKLEY 2063839 Fil.~'~y .-,-, n,- r ~r ~.~,. ~ `E i !vt t,.: y Z~lO Ja~~ t 4 P,~ 1 ~ 03 CUP,r~' s !'~r'i ai'~~1~'nLtYtll~,ffy ' COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 09-7611 PRAECIPE FOA ENTRY OF JODt~NT FOR WANT OF AN ANSWER, ASSESSMEI~TT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $1,945.73 Less: Payments on Account ( $.00) Total: $1,945.73 ~1~.00 PD AT1t/ ~~ ~o~ a~q ~.Y~ a3~as$ Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. X4904, Unsworn Falsification to ~p~„A Authorities, I verify that : T~t~- 1. The last known addresses of the parties are: ARROW FINANCIAL SERVICES, LLC and that the last known address of defendant, MATTHEW HOCKLEY, 32 OAK AVE, CAMP HILL PA 17011. 2._ The__annexed_ notice (s)__of intention to .file .this. praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this ~,1 0060 is entered in favor of~ pla nt ff(s) and against defen Judgment default for want of an answer and damages assessed at the sum (of by $1,945.73 as per the abov certification. ' Prothonotary CORDON & WEINB RG, P.C, BY: FREDERIC I WE BERG, ESQUIRE JOEL M. FL N ESQUIRE Attorney for Plaintiff CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 _- 1001 E. Hector Street, Ste 220 _ Conshohocken, PA 19428 484/351-0500 RRROW FINANCIAL SERVICES, LLC vs. MATTHEW HOCKLEY TO/PARA 2063839 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-7611 NOTICE OP INTENTION TO TARE DEFAULT MATTHEW HOCKLEY 32 OAK AVE CAMP HILL PA ] 7011 DATE OF NOTICE/FECHA DEL AVISO: December 1, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 YOll 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 CORDON & WEINBERG, P.C. _ ,~~~ %, BY : i' FREDERIQ/ I ,~ YEINBERG, ESQUIRE JOEL M./ FINK, ESQUIRE P10D-2 • 2063839 GORDON & WEINBERG, P.C, BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES, LLC vs. MATTHEW HOCKLEY 32 OAK AVE CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-7611 NOTICE Pursuant to Pa.R.Civ.P. 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. /XL Judgment by Default $1,945.73 ~ Money Judgment $ ~ Judgment on A~+ard of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 ~. PROTHONOTARY 2174020 GORDON & WEINBERG, P.C. � ` F N{ BY: FREDERIC I. WEINBERG, ESQUIRE �PROTHONOTARY iff Identification No. : 41360 � JOEL M. FLINK, ESQUIRE 2013 DEC 18 PM Z. 47 Identification No. : 41200 1001 E. Hector Street, Ste 220 CUMBERLAND COUNTY Conshohocken, PA 19428 PENNSYLVANIA 484/351-0500 =ARROW FINANCIAL SERVICES, LLC COURT OF COMMON PLEAS 511 Rhett Street CUMBERLAND COUNTY Greenville, SC 29601 VS. DOCKET NO. 09-7611 Matthew Hockley =120 Bryce Rd Camp Hill PA 17011-1324 and PNC Bank -105 Noble Blvd. Carlisle, PA 17013 GARNISHEE PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against Matthew Hockley defendant (s) and (2) against PNC Bank garnishee (s) (3) Amount Due $1, 945.73 Interest from January 14, 2010 $4 . 48 Costs Prothonotary fee Sheriff fee (4) Less: Payments on Account .00 TOTAL 0- auk �q coo 1 ss, ao Cac 4a U. Sb pd .as 'ukIC1oL0QLl JOEL MICFLINK, ESQUIREESQUIRE �Jj�aggSSp Attorney for Plaintiff ul)(L ^r T WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-7611 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ARROW FINANCIAL SERVICES,LLC Plaintiff(s) From MATTHEW HOCKLEY, 120 BRYCE ROAD,CAMP HILL,PA 17011-1324 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: PNC BANK, 105 NOBLE BLVD.,CARLISLE,PA 17013 and to notify the garnishee(s)that: (a) an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof; (2) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$1,945.73 Plaintiff Paid$ Interest FROM JANUARY 14,2010-$4.48 Attorney's Comm. % Law Library$.50 Attorney Paid$176.50 Due Prothonotary$2.25 Other Costs$ Date: 12/18/13 David D. Buell,Prothonotary By: Deputy REQUESTING PARTY: Name : FREDERIC I.WEINBERG,ESQUIRE Address: GORDON& WEINBERG,P.C. 1001 E.HECTOR STREET,SUITE 220 CONSHOHOCKEN,PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson �i Sheriff �Xt«tp 01. t Nit tr 4,4 j{ F* Jody S Smith J -2 Pi J: ° Chief Deputy Richard WStewart Solicitor , = 'E iN S Y LVA NIA Arrow Financial Services Case Number vs. Matthew Hockley 2009-7611 SHERIFF'S RETURN OF SERVICE 12/23/2013 10:16 AM-William Cline, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Natasa Torres, Banking Officer, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on December 30, 2013 t atthew Hockley at 32 Oak Avenue, Camp Hill, PA 17011. CL NE, DEPUTY SO ANSWERS, December 30, 2013 RONNY R ANDERSON, SHERIFF _ {y 2174020 :j , 7w 180,- r“)811 GORDON & WEINBERG, P. C. Cupyn�R PM C.• 37 = BY: FREDEIC 41360UIRE p - 5 N COON - JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs . DOCKET NO. : 09-7611 Matthew Hockley and PNC Bank Garnishee ° PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment against PNC Bank, as Garnishee in the above entitled matter. GORDON & WEINBERG, P. C. BY: FREDERIC I . ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;- - ;: L.)-. L r ie.-... Sheriffr .- I=E'F?C!i�xt�) !:‘i ,..ov of kr.. Jody S Smith Chief Deputy ;° l iii JUL -3 Ail IG 30 Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA OFF !CE F4`E, r''F,RIFF Arrow Financial Services vs. Matthew Hockley Case Number 2009-7611 SHERIFF'S RETURN OF SERVICE 12/23/2013 10:16 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Natasa Torres, Banking Officer, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on December 30, 2013 to Matthew Hockley at 32 Oak Avenue, Camp Hill, PA 17011. 07/02/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $89.26 SO ANSWERS, July 02, 2014 RONW R ANDERSON, SHERIFF (c) CountySuito Sheriff, Teieosoft, Inc.