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Home My WebLink About09-7626'Our File No.: 219801 APOTRAKER & 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. TINA COYLE 153 VALLEY DR CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: pq - 7(oo2( aiv I I Term 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.: 219801 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. TINA COYLE 153 VALLEY DR CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY 01 ? NO.: - 96,2G ?j ? 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 TINA COYLE, an adult individual residing at 153 VALLEY DR CARLISLE, PA 17013. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #2116041004576477; and said account was issued to Defendant(s) by HOUSEHOLD 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 $2,150.00. 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 $2,150.00 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS IATES, P.C. Attorney r PI kebt tiff A Law Firm EnV ed in Collection BY: Dated: 10/28/2009 David J. A Our File No.: 219801 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 relatingounlworn falsification to authorities. David J. DATE: 10/28/2009 ARROW FINANCIAL SERVICES LLC TINA COYLE 153 VALLEY DR CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 219801 TINA COYLE 2116041004576477 HOUSEHOLD BANK $2,150.00 EXHIBIT "A" 0 Av . 74 P? 2009140V -4 F i i 2'. 54 CU4J ryry;,3, r w, $118.60 PA WrN CV-* !5'lg64 P-T# a3sco4 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ~$~ti,tt~, at L'`a~rtj,~r~~~~~ ,.: .e~aRF~= 1 t - ~ .T . , LJV~. _ Arrow Financial Services LLC vs. Tina Coyle Case Number 2009-7626 SHERIFF'S RETURN OF SERVICE 11/13/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Tina Coyle, but was unable to locate her in his bailiwick He therefore returns the within Complaint and Notice as not found as to the defendant Tina Coyle. The Carlisle Postmaster has advised the defendant has moved and left no forwarding address. An exact address is not available. SHERIFF COST: $38.40 November 13, 2009 SHERIFF'S OFFICE OF CUMBERLAND COUNTY --- ~-, ' - __ r r SO ANSWERS, , R THOMAS KLINE, SHEf~IFF cj Ceun!ySuitr 5h=e~,f1 T[:~.asr,'t....,,