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Home My WebLink About09-8046Our File No.: 226360 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. SETH ANDERSON 4637 ENOLA RD NEWVILLE, PA 17241-9748 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. oQ - ?bqj 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 Ouf File No.: 226360 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. SETH ANDERSON 4637 ENOLA RD NEWVILLE, PA 17241-9748 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O q- PO q(, Ct? T? 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 SETH ANDERSON, an adult individual residing at 4637 ENOLA RD NEWVILLE, PA 17241-9748. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185863099642183; 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 $1,110.57. 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 $1,110.57 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASrffiq(ebt I/kTES, P.C. Attorney for iff A Law Firm Engaged Collecji6i BY: David J. ApothEsquire Dated: 11/11/2009 Our File No.: 226360 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 and igned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating`to worn falsification to authorities. i David J. A tha r, Esquire Attorney ntiff DATE: 11/11/2009 ARROW FINANCIAL SERVICES LLC SETH ANDERSON 4637 ENOLA RD NEWVILLE, PA 17241-9748 STATEMENT OF ACCOUNT Debtor's Name: SETH ANDERSON Account Number: 4185863099642183 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,110.57 Our File No.: 226360 EXHIBIT "A" 0?__ FILED-+DrFICE OF THE P ?C' 'HOMOTARY 2004 NOV 19 PHI l : 34 3UNTY PNIINYLVAPifA v8. sv ?d R?l.? ?+ X33 808 Our File No.: 226360 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC Plaintiff, vs. SETH ANDERSON Defendant. MW .. i 70c- a COURT OF COMMON PLEAS N CUMBERLAND COUNTY r NO. 09-8046 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER &,/ASSOCIATES, P.C. A Law Firm EnjinedAn Debt By: David J. Apoth c , Dated: 4/25/2011