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Home My WebLink About09-8214S 2063925 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. MARYANN STRAHOSKY 1040 WAYNE AVE CARLISLE PA 17013-1639 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : CA - Ew4 NOTICE YOU HAVE BEEN SUEZ) 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 IMPORTA14T 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)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 22, 2009 in the amount of $2,445.59. 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 4/17/2006. WHEREFORE, pla=_ntiff claims of the defendant(s) the sum of ;2,445.59 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. 17-? BY: FREDERIC I. WE NBERG, ESQUIRE JOEL M. FA Z, ESQUIRE Attorney for Plaintiff POIP.DB 2063925 36768940 Arrow Financial Services, LLC MARYANN STRAHQSRY 6034621700446594 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 waking this verification. This verification is made subject to 18 Pa.C.S. 54904 which provides for certain penalties for making false statements. NAt? EXHIBIT "A" 2063925 ARROW FINANCIAL SERVICES, LLC MARYANN STRAHOSICY 6034621700446594 State of Illinois § County of Cook § AFFIDAVIT T that: , being duly served sworn according to lax, depose and say 1. T an 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 QE xoNay SAM when Ha xoirsy 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 $1,434.19 plus interest of $957.91 at the rate of 24.75* less credits in the amount of $.00 totaling $2,392.10 as of August 28, 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 best of my knowledge, information and belief, jo? /l. Sworn to and Subscribed before me this of- Je V I I- - nay n? ,,PublMw SEAL" ?/ 2 0 9 9 l,G i 25 2: 9 ?? 1 $18.50 Po AMY e t q5775 Ut a3y 177 GORDON&WEINBERG Fax Jan 8 2010 12:29pm P002/003 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE identification No.: 41360 JOEL I~, FLINK, ESQUIRE identification No.: 41200 1001 E. HECTOR STREET, SUITE 220 CQNSHOHOCKEN RA 7,9428 2063925 c~ - .:.. _ ~a rr: ~~ - ~.,, .~ ~~: _-~ ~~ ~ "~ 484/351-0500 `-~L ~:-, ARROW FINANCIAL SERVICES, LLC COURT OF COMMON PLEAS '' ~~~~ CUMBERLAND COUNTY vs. DOCKET N0. 2009-8214 MARYANN STRAHOSKY S'~'IPULATIQI~I OF SETTLT.MENT It is HEREBY STIPUL,A,TED AND AGREED that the above-e~txtied action is settled by agreexnent of the parties undez the following te:npas and conditions: l . De£emdaxat and PlaintifF desire to settle the above captioned zmatter and stipulate that Defendant will pay to the order of Gordon and Weinbexg, P.C., attorneys for the lalaintiff, at their oi~'iices at I OOI E. Hector Street, Suite 220, Conshohocken, Pennsylvaztia 19428, the sum of Oz~e Thousand Four Hundred and 00/100 ($1,400.00) Dollars in installments as follows: a, Five (5) equal and consecutive payments o£ Two Hundred Eighty axtd no/100 ($2$0.00) Dollars to be received fln car before the 20a' of each u~onth beginning January 20, 20I0. 2. Defendant appears generally herein anal submits to the jurisdiction of the Count. 3. ~a the event of a default of any of the above listed condXtio~as and payments, plavatiff may, upon I 0 days notice to Defendant amd,A..ttorney enter judgment for the relie£dexnanded in the Cvznplaint filed iz~ this matter less arty payments made plus judicial interest of 6% running `_.3 ~ --i .~ from the date of filing. GORDON&WEINBERG Fax Jan B 2010 12:29pm P003/003 4. Upon full and final compliance with this stipulation, this action shall be deemed fully settled, discontinued and/or satisfied and will be noted as such on any credit report fillings. 5. Spa accordance with the terms ofthis agreement there appears to be a related consent order for judgment held in escrow which will automatically extinguish upon compliance with the above meaatioz~ed terms. C~- ;.,~-~.~~. ,-, Joel . Flin`Ic, Esquire A rney far l?laintiff Date: / 'y' ~ ~- -/ J >- Micb~ael Pykosh, squire A,ttozraey for Defendant Date: 2 0 ~ 11~aryann trahosky Dater ~ `l -- l U