The URL can be used to link to this page

Home My WebLink About09-8022 A 2063648 THIS IS AN ARBITRATION MATTER. ASSESSMENT 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 VS. JERRY SHEW 154 RUSTIC DR SHIPPENSBURG PA 17257-9463 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : QQ -g6;j;2, 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 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 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 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 September 30, 2009 in the amount of $2,189.74. 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. 7. Defendant's last payment on account was made on 05/04/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,189.74 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN RG, ESQUIRE JOEL M. FLI SQUIRE Attorney for Plaintiff P01P.DB 2063648 41542982 Arrow Financial Services, LLC JERRY SMW 6019180385621749 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" 2063648 AMON FINANCIAL SERVICES, LLC JERRY SHZW 6019180385621749 State of Illinois County of Cook that: I, S S S AFFIDAVIT 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 Gs MONZY BANK when GZ MONZY 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 $1,517.00 plus interest of $583.24 at the rate of 24.75% less credits in the amount of $.00 totaling $2,100.24 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 correc o the best of my knowledge, information and belief. !. IANT Sworn to and Subscribed befo th'a y of 9 Notary Public OFFICIAL SEAL WALTERINE MCELROY NOTARY PUBLIC -STATE OF ILLINOIS N!Y COMCrNSSION EXPIRES: 11120110 os? FILF??T?CE 'OF THE 2004 NOV 18 PM 2= 13 cuW ?'i L." tr?.l ?J 4`Vtn PIENNSYLVANIA. e ? 4w?rI ?- ot3 373 S R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ~~,~u+,t rrl,i~ld 20'~9~~~C °1 C~~ 2~ ~~ ~'~-j1 v~` ~..4 _ ,_ ~- _ Arrow Financial Services LLC vs. Jerry Shew Case Number 2009-8022 SHERIFF'S RETURN OF SERVICE 11/23/2009 01:12 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on November 23, 2009 at 1312 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jerry Shaw, by making known unto himself personally, at 154 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to hin- personally the said true and correct copy of the same. SHERIFF COST: $46.00 November 30, 2009 SO ANSWERS, ~.~~~ R THOMAS KLINE, SHERIFF D~ uty SYaeriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~I~E~:= -; ~ ~~t~ ., ~_ _ , ~~ ~:ii~ulr `~