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HomeMy WebLinkAbout09-8218 .Our File No.: 226562 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. WILLIAM CLOUGH 70 SHIPPENSBURG MOBILE EST SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (A - $oU $ a-1V11-1&*1 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 -ft Our File No.: 226562 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. WILLIAM CLOUGH 70 SHIPPENSBURG MOBILE EST SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: © 9 /? TtcM 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 WILLIAM CLOUGH, an adult individual residing at 70 SHIPPENSBURG MOBILE EST SHIPPENSBURG, PA 17257. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4888936999073095; and said account was issued to Defendant(s) by BANK OF AMERICA, 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 $7,246.87. 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 $7,246.87 and requests this Court award costs to the extent permitted by applicable law. APOTH=R ASSOCIATES, P.C. Attorn y for Plaintiff A Law Firm E aized/fn Debt Collection BY: _ David J. A cer, Esquire Dated: 11/18/2009 Our File No.: 226562 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 under ' ed understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating t uns orn falsification to authorities. David J. Apoth r, Esquire Attorney for Pl DATE: 11/18/2009 ARROW FINANCIAL SERVICES LLC WILLIAM CLOUGH 70 SHIPPENSBURG MOBILE EST SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: WILLIAM CLOUGH Account Number: 4888936999073095 Original Creditor: BANK OF AMERICA Balance Due: $7,246.87 Our File No.: 226562 EXHIBIT "A" F1LL? ?=iCE 71 l7nRy 2009 NON 2t; Pi i 2; E. 6 4M. So PO AlTq cv,t 15R,7 (OS Pat a.34I sa i Our File No.: 226562 AILED-OFFICE APOTHAKER& ASSOCIATES, P.C. OF TH PRO T HONO to , BY: David J. Apothaker, Esquire 201.3 SEP _9 P11 2: 3 9 Attorney I.D.# 38423 CUMBERLAND COUNTY 520 Fellowship Road C306 Mount Laurel,NJ 08054 PENNSYLVANIA (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES ) COURT OF COMMON PLEAS LLC ) CUMBERLAND COUNTY Plaintiff, ) vs. ) NO. 09-8218 WILLIAM CLOUGH ) Defendant. ) PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER& S CIATES,P.C. Attorney for P aintiff A Law Firm Enga ed i Debt Collection By: David J. Ap aker, Esquire * 4 2 2 6 5 6 2 D I S M 1 -