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HomeMy WebLinkAbout09-7955 2068504 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. 88= s 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 COURT OF COMMON PLEAS 600 Broadhollow Road, CUMBERLAND COUNTY Melville NY 11747 VS. DOCKET NO. 0,lvdfo-m JENNIFER JONES 835 YORK RD CARLISLE PA 17015-9253 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 . 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)tae 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 October 8, 2009 in the amount of $2,193.04. 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. -1 7. Defendant's last payment on account was made on 11/8/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,193.04 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I W NBERG, ESQUIRE JOEL M. FL , ESQUIRE Attorney for Plaintiff P01P.DB I. 2068504 42732354 Arrow Financial Services, LLC JEMIFSR JOMS 6019171200514946 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. T "r_" =`,H1E'- 11 2068504 ARRIN FINANCIAL SERVI KS , LLC JErMFZR JMS 6019171200514946 State of Illinois § § County of Cook § ?, ]?8'>EE•=VIT I, rt/i?.t 1_, 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 GE Money Bank when GE Money Bank 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 $1,651.99 plus interest of $483.92 at the rate of 24.75# less credits in the amount of $.00 totaling $2,135.91 as of August 18, 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 to the best of my knowledge, information and belief. FFIANT Sworn to and Subscribed before me this c2Y?day of 2009 Notary Public E*OFFICIAL SEAL" W tricia Wallace Public, state of Illinois IiAy ssion Expires 10/10/2012 0 71 2009 fJ P 6 F°°1 2: 2 Cam' 019.50 Po P Vry Ct,* q(4 388 e 4.33599 } J 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 4~~~}t1~, bt ~~rw(+r~,~~~~~ w s~.,_ ~ . - r, ~, ,~ ,.,~ 4.~`,`,~ '~' .. , ;,-, ~ Arrow Financial Services LLC vs. Jennifer Jones Case Number 2009-7955 SHERIFF'S RETURN OF SERVICE 11/24/2009 05:50 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 24, 2009 at 1750 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer Jones, by making known unto herself personally, at 3527 September Drive Apt. 6, 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: $46.90 November 25, 2009 SO ANSWERS, R THOMAS KLINE~S~-IERIFF gY Sher ;c?. Co i ~~.aitr S"c r..}f Tea ~s-'L b?e.