The URL can be used to link to this page

Home My WebLink About09-8045Our File No.: 226347 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. RONALD KUNZ II 2800 CENTRAL AVE CAMP HILL, PA 17011-4516 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 64 - e04' 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 P. Our File No.: 226347 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. RONALD KUNZ II 2800 CENTRAL AVE CAMP HILL, PA 17011-4516 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 q - S b 4S C.,?;k -r,,,- 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 RONALD KUNZ II, an adult individual residing at 2800 CENTRAL AVE CAMP HILL, PA 17011-4516. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185861658838473; and said account was issued to Defendant(s) by WASHINGTON MUTUAL 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 $3,446.81. 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 $3,446.81 and requests this Court award costs to the extent permitted by applicable law. S, P.C. APOTHAKER fe2 AttorA Law Firm Enollection BY:David J. re Dated: 11/11/2009 Our File No.: 226347 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 undersign d understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to 7- David falsification to authorities. J. Apothake , ire Attorney for Plaintiff DATE: 11/11/2009 ARROW FINANCIAL SERVICES LLC RONALD KUNZ II 2800 CENTRAL AVE CAMP HILL, PA 17011-4516 STATEMENT OF ACCOUNT Debtor's Name: RONALD KUNZ II Account Number: 4185861658838473 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $3,446.81 Our File No.: 226347 EXHIBIT "A" QS FILED-OFFICE 2099 Nov 19 PH 1: 34 CUP, F i?iJ V I Vii?/ ) X78. r??J.- AI, CO rsQn7 T R '£ aaa8a7 R Thomas Kline Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY n -, ._ ~'= i~~ t _ '~~"~ CRY Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor j1,tr c ~.iiu:~,rr;r ~~~ ,7°le7 t+l l ' ,~ T~; Arrow Financial Services LLC vs. Ronald Kunz, II Case Number 2009-8045 SHERIFF'S RETURN OF SERVICE 11/20/2009 06:05 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 20, 2009 at 1805 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ronald Kunz II, by making known unto himself personally, at 2800 Central Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 November 30, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ~~~~~~ 11009 ~,~~ i~ ~~ Deputy Sheriff ~ ~cu~~' it 3~er~" iF ~... •~ Inc