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Home My WebLink About09-7956A THIS IS AN ASSESSMENT 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 2068467 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. ARROW FINANCIAL SERVICES LLC 600 Broadhollow Road, Melville NY 11747 VS. MOLLIE SEIFERT 1727 ENGLISH DR MECHANICSBURG PA 17055-5612 NOTICE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Oq - N56 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, HSBC CARD SERVICES (III) INC. 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 merchandise 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 $2,858.81. 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. x 7. Defendant's last payment on account was made on 10/19/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,858.81 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01P.DB a 2068467 42532699 Arrow Financial Services, LLC MOLLIE SEIH'ZRT 6011301000101814 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? Alb, i F'l T "r." 2068467 ARROW FINANCIAL SERVICES, LLC MOLLIE 3ETH'6RT 6011381000101814 State of Illinois County of Cook S AF'1!" MAVIT I iP dfd?? eing 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 nsBC CARD SERVICES (III) INC when HssC CARD SERVICES (III) 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 $2,269.98 plus interest of $531.74 at the rate of 18$ less credits in the amount of $.00 totaling $2,801.72 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 Subscri ed before me this day of _ 2Q09 l/I QVJG? Notary Public "OFFICIAL SEAL" Patricia Wallace Notary Public, State of Illinois MY Commission Expires 10/10/2012 0 r +r , L ?1 (/ ?f (k. .. 418.50 PO AT14 cr* 94-'-Saco RI* a3woo0 ."511 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY ({{ t - r I ~ ~ V ~ / .. ,nr fl, ~.. E ~!rd. Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor n 9~~~~y~ Oj l`. 2UI1 tIF~~_~~~ ... w t'~ 2G~9 D~~~ ° i ~'~ i ~~ ! ~ tt ,;-, Arrow Financial Services LLC I Case Number vs. 2009-7956 Mollie Seifert SHERIFF'S RETURN OF SERVICE 11/23/2009 07:01 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 23, 2009 at 1901 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mollie Seifert n/k/a Mollie Lewis, by making known unto Tim Lewis, husband of defendant at 1727 English Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 it: contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 November 25, 2009 SO ANScWERS .~1 ~/~~~~~ R THOMAS KLIf~SHERIFF Depu y Sh (C; Cour,.yJUilr SFer`t. l~eleo.=.o1L In;;. • ? 7 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M FLINK, ESQUIRE Identification No.: 41200 1001 E. HECTOR STREET CONSHOHOCKEN, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES, LLC VS. MOLLIE SEIFERT 2068467 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0.: 09-7956 STIPULATION OF SETTLEMENT ry_' ?? m_a 3 r ii It is HEREBY STIPULATED AND AGREED that the above-entitled action is settled by agreement of the parties under the following terms and conditions: 1. Defendant and Plaintiff desire to settle the above captioned matter and stipulate that Defendant will pay to the order of Gordon and Weinberg, P. C., attorneys for the Plaintiff, at their offices at 1001 E. Hector Street, Conshohocken, Pennsylvania 19428, for the sum of One Thousand Seven Hundred Twenty and no/100 ($1,720.00)Dollars in the following matter: a. Five (5) equal and consecutive payments of Three Hundred Forty Four and 00/100 ($344.00) Dollars to be received on or before the 20 of each month beginning November 20, 2010. 2. 3. 4 5. Defendant appears ,generally herein and submits to the jurisdiction of the Court. In the event of a default of any of the above listed conditions and payments, Plaintiff may, upon 10 days notice enter judgment for the relief demanded in the Complaint filed in this matter plus judicial interest of 6% running from the date of filing. Upon full and final compliance with this stipulation, this action shall be deemed fully settled, discontinued and/or satisfied. In accordance with the terms of this agreement there appears to be a related consent order for . , judgment held in escrow which will automatically extinguish upon compliance with the above mentioned terms. Gordon and Weinberg, P.C. A ki -U, Mollie Seifert