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Home My WebLink About09-8857 2063878 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 COURT OF COMMON PLEAS 600 Broadhollow Road, Melville, CUMBERLAND COUNTY NY 11747 VS. DOCKET NO. : CA - 88,57 0i\j-tkTerfA HAI HUYNH 1427 SIMPSON FERRY RD NEW CUMBERLAND PA 17070-1559 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 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 or Affidavit 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 November 13, 2009 in the amount of $2,288.68. 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 11/19/06. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,288.68 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY FREDERIC I. I ERG, ESQUIRE JOEL M. FLI K SQUIRE Attorney for Plaintiff P01P.DB 2063878 38920862 Arrow Financial Services, LLC RAI HUYNH 6034590500755951 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 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" f A. 2063878 ARROW FINANCIAL SERVICES, LLC HAI HUYNH 6034590500755951 State of Illinois County of Cook that: I, ?t&"F S S S AFFIDAVIT being duly served sworn according to lap, 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 cs MONSY BANK when ca MONSY 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 $1,436.42 plus interest of $724.66 at the rate of 24.75$ less credits in the amount of $.00 totaling $2,161.08 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 cc rect to the beat of my knowledge, information and belief. t ANT Sworn to and Subscribed belor this /Aday of 20019 Notary Public OFFICIAL SEAL WALTERINE MCELROY NOTARY PUBLIC - STATE OF ILLINOIS MY COAAAMSSIOM EXPIRESA 1120/10 0 2 ? ?` Z 1 1 $qa. oo Pa AT'N COO, ! DO(pUO197 y(o 8 aa& a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FLED-O E Sheriff ? iF THE FPnT ,!'nTARY Jody S Smith Chief Deputy 201 JAS II QM $' , Edward L Schorpp i"j'Y Solicitor rPJx> Arrow Financial Services LLC vs. Huy Quoc Huynh Case Number 2009-8857 SHERIFF'S RETURN OF SERVICE 01/04/2010 01:49 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on January 4, 2010 at 1349 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Huy Quoc Huynh, by making known unto Hung Huynh, Brother of defendant at 1427 Simpson Ferry Road, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 January 06, 2010 SO ANSWERS, R R ANDERSON, SHERIFF By Deputy S eiiff 2063878 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 vs. HAI HUYNH 1427 SIMPSON FERRY RD NEW CUMBERLAND PA 17070-1559 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 09-8857 NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. fRj Judgment by Default $2,288.68 ~ Money Judgment $ ~ Judgment on Allard of Arbitratora$ L,L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 PROT OTARY GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES, LLC vs. HAI HUYNH t'; a ~' ~- J 206387Q.,sti. a ~' r, `~' r'~t ~ -n c~ ~~ r ~;;' rv ^~ _ ~ _'3 ^1 :yam r_ : ~4~ i e :.,-, ~~ ~ ..c COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 09-8857 PRAECIPE FOR ENTRY OF JVDC~TT _FOR MINT OF AN ANSWER. ASSES3MLNT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $2,288,68 Less: Payments on Account ( $.00) Total: $2,288.68 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. X4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: ARROW FINANCIAL SERVICES, LLC and that the last known address of defendant, HAI HUYNH, 1427 SIMPSON FERRY RD, NEW CUMBERLAND PA 17070-1559. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. • AND NOW, this --a.~~-day of 2010 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at t:he sum of , $2,288.68 as per the above certifi ation. . ti Prothon tary GORDON & WEINB P BY: FREDERIC WE BERG, ESQUIRE JOEL M. IN ESQUIRE Attorney r Plaintiff ,~/~l. DD ~cC_ h~ 1 c~ cos` cv 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 19928 484/351-0500 2063878 ARROW FINANCIAL SERVICES, LLC vs. HAI HUYNH TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 09-8857 NOTICE OF INTENTION TO TAIQ; DEFAULT HAI HUYNH 1427 SIMPSON FERRY RD NEW CUMBERLAND PA 17070-1559 DATE OF NOTICE/FECHA DEL AVISO: January 26, 2010 II~ORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 GORDON & WEINBERG, P.C. /~ `~' , ,, BY: _ :~ FREDERIC,`.I`. WEINBERG, ESQUIRE JOEL M. ,F`LINK, ESQUIRE P10D-2