The URL can be used to link to this page

Home My WebLink About09-77932064167 THIS IS AN ARBITRATION MATTER. 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 VS. JEFFREY A BLACKBURN 220 FAITH CI CARLISLE PA 17013 ASSESSMENT OF COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : OR - 7793 ( ,ivit Tem 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 I ` a COMPLAINT IN CIVIL-ACTION 1. Plaintiff, ARROW FINANCIAL SERVICES, LLC a debt buyer and successor in interest to the original creditor, WELLS FARGO FINANCIAL INC. 2. Plaintiff, ARROW FINANCIAL SERVICES, LLC, is a business entity authorized to conduct business in the Commonwealth of Pennsylvania with its principal place of business at the above captioned address. 3. Defendant), JEFFREY A BLACKBURN is/are adult individual residing at the address above captioned. 4. Plaintiff and Defendant (s) entered into a closed end motor vehicle lease contract which required Defendant(s) to make monthly payments for the utilization of the vehicle. 5. Defendant(s), defaulted on the terms of the lease resulting in a total deficiency of $4,096.79. 6. Attached hereto and incorporated herein by reference as Exhibit "A" is a copy of the lease agreement and deficiency balance documentation. 7. Despite repeated demand Defendant(s) has/have refused, failed ans till refuses to tender payment on this outstanding obligation. 8. Defendant's last payment on account was made on 7/15/2006. WHEREFORE, plaintiff claims of the defendant(s) the sum of $5,781.10 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2064167 41199011 Arrow Financial Services, LLC JEFFREY A BLACKBURN 50237590052349001 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. §4904 which provides for certain penalties for making false statements. EXHIBIT "A" 406 2064167 ARROW FINANCIAL SERVICES, LLC JEFFREY A BLACKBURN 50237590052349001 State of Illinois § 5 County of Cook § AFFIDAVIT that: I, being duly served sworn according to law, depose and say 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 WELLS FARGO FINANCIAL INC when WELLS FARGO FINANCIAL INC 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 $4,096.79 plus interest of $1,561.41 at the rate of 17.95% less credits in the amount of $.00 totaling $5,658.20 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 corre to the best of my knowledge, information and belief. r FIANT i Sworn to and Subscribed 401 this _42?ed-day of 2009 Notary Public "OFFICIAL SEAL" W Valencia D Doty Notary Public, State of Illirnis Commission Expires 6(1012012 0 A ?iFF E ARY 2099 NOV 10 N °u:-3 0 78.sn Po A'ml W* a&3aq SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy 0"jCE ;- 'µE 1," ERi9F OF THE ?MY Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 2019 NOV 17 AM 8: «0 CUMBE??At>4ry )VA?AtpU1?Ii11 y Arrow Financial Services LLC vs. Jeffrey A. Blackburn Case Number 2009-7793 SHERIFF'S RETURN OF SERVICE 11/13/2009 04:05 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on Novembei 13, 2009 at 1605 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeffrey A. Blackburn, by making known unto Justin Blackburn, son of defendant at 220 Faith Circle 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: $33.40 November 16, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By De j-S-heriff (c) CountySuite Shenff_ Teleosoft. Inc. 2064167 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE C`~ a ,-- Identification No.: 41360 --- a JOEL M. FLINK, ESQUIRE n'~r ~• i~~ Identification No.: 81894 _ -~ m 1001 E. Hector Street, Ste 220 ~`~ ` ~ w ~>° ~ ` ~ Conshohocken PA 19428 - ~y. ~ " 484/351-0500 :~.~ - ~ ~ ~nz ~ .~ ~ ~ ARROW FINANCIAL SERVICES, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. JEFFREY A BLACKBURN DOCKET N0. 09-7793 PRAECIPE FOR ENTRY OF JtJDC~__ NT FOR WANT OF AN ANSNER ASSESSMENT 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 Less: Payments on Account Total: $5,781.10 $.00) $5,781.10 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. X4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: ARROW FINANCIAL SERVICES, LLC and that the last known address of defendant, JEFFREY A BLACKBURN, 220 FAITH CI, CARLISLE PA 17013. 2. The annexed notices} 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. $I~.oo Po A~'r`I UL~ l of 830 P_77~ a3 ~a.~/ No~hee l~lai~ed aoio ~ AND NOW, this 13`x` day of ~QlIUQ.r'y , .~A$'9' Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages ass ssed at the sum of , $5,781.10 as per the above c tif' n. ~/, Prothonotary GORDON & WEINBERG, P.C. BY: FREDERIC I{ W~INBERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff I~ 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 2064167 ARROW FINANCIAL SERVICES, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 09-7793 JEFFREY A BLACKBURN TO/PARA NOTICE OF INTENTION TO TAKE DEFAULT JEFFREY A BLACKBURN 220 FA1TH C1 CARLISLE PA 17013 DATE OF NOTICE/FECHA DEL AVISO: December 4, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY RND 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 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 GORDON & WEINBERG, P.C. BY: FREDERIC INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE P10D-2 i . ~. 2064167 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. JEFFREY A BLACKBURN 220 FAITH CI CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 09-7793 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. ~L Judgment by Default $5,781.10 ~ Money Judgment $ ~L Judgment on Aaard of Arbitrators$ ~ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ES UIRES AT THIS TELEPHONE NUMBER: 484/351-OSO,d~ ~ PROTHONOTARY