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Home My WebLink About10-0314... Our File No.: 234757 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. JONATHAN E CURTIS 127 LANCASTER BLVD MECHANICSBURG, PA 17055-3548 Defendant. FILED -4,-"r !C' E op TH P''-)TI o \MARY 2010 JAN 12 AM 9: 38 CUM- a ?,`-IUN1Y F01? 151'?1l4NA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 10 - 314 NOTICE Civil lean 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 *ga.oo PO ATtY U-4 11A(PoS M* C 2.3i. l3y Our File No.: 234757 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. JONATHAN E CURTIS 127 LANCASTER BLVD MECHANICSBURG, PA 17055-3548 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I 0 Ll G }v , Ian" 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 JONATHAN E CURTIS, an adult individual residing at 127 LANCASTER BLVD MECHANICSBURG, PA 17055-3548. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5407915025401925; and said account was issued to Defendant(s) by HSBC CARD SERVICES (III) INC, 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 $1,486.86. 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 $1,486.86 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS S, P.C. Attorney for lain A Law Firm Engage in D t Collection BY: Dated: 12/31/2009 David J. Our File No.: 234757 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 undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unw11rn falsification to authorities. David J. Apo er, Esquire Attorney fo Plaintiff DATE: 12/31/2009 ARROW FINANCIAL SERVICES LLC JONATHAN E CURTIS 127 LANCASTER BLVD MECHANICSBURG, PA 17055-3548 STATEMENT OF ACCOUNT Debtor's Name: JONATHAN E CURTIS Account Number: 5407915025401925 Original Creditor: HSBC CARD SERVICES (III) INC Balance Due: $1,486.86 Our File No.: 234757 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAN ,~O_UN,]'Y Ronny R Anderson `=' ~ ~~_ ;~ _ , ;T'~'?Y Sheriff -7 Jody S Smith ~~;,,w1p of ~a~ri~r~,f~f,~ 2~~~ ~~~ ~~ ~:ii s r ~ ~ 1 Chief Deputy Edward L Schorpp ~ "`~' _ _ il' Solicitor ~F ~, ~F ~ ~~~~~ ~ ~ ,~ ~ t -,~;~;~, Arrow Financial Services LLC vs. Jonathan E. Curtis Case Number 2010-314 SHERIFF'S RETURN OF SERVICE 01/22/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jonathan E. Curtis, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Jonathan E. Curtis. Deputies were advised the defendant now resides at 2019 Center Street, Lebanon, PA 170~2j SHERIFF COST: $42.00 January 22, 2010 SO RONNyRANDERSON, SHERIFF to; CaevySuite Sheriff. re!ecsu*f 6x