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Home My WebLink About10-0365. AS Our File No.: 235838 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. CARI RUSSELL 1156 BELVEDERE ST CARLISLE, PA 17013-4003 Defendant. 0 ? THr: J?py 2010 JAN 14 P1r1 1: 08 C U m COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - 3(05 Civil IErrn 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 #?a co PA amt er?? f ?55?t, 12TH d 3(,x43 1 14 Our File No.: 235838 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. ) CARI RUSSELL ) 1156 BELVEDERE ST ) CARLISLE, PA 17013-4003 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ?o - 3(o S c w: 1 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 CARI RUSSELL, an adult individual residing at 1156 BELVEDERE ST CARLISLE, PA 17013-4003. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185863220654172; 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 $3,668.27. 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 $3,668.27 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & OCIATES, P.C. T L„ . ..- A Law Firm EnRAaedlin Debt BY: David J. AN!Iler, Esquire Dated: 1/8/2010 _ ? Our File No.: 235838 . . 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 uj4rsigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 rela ' g to sworn falsification to authorities. David J. pothaker, Esquire Attorne or Plaintiff DATE: 1/8/2010 ? ? Y S CARI RUSSELL 1156 BELVEDERE ST CARLISLE, PA 17013-4003 Debtor's Name: Account Number: Original Creditor Balance Due: Our File No.: 235838 ARROW FINANCIAL SERVICES LLC STATEMENT OF ACCOUNT CARI RUSSELL 4185863220654172 WASHINGTON MUTUAL BANK $3,668.27 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff a?1??ty. of Jrr,I L L_ L - .C4. :-r Al Jody S Smith Chief Deputy Edward L Schorpp Solicitor 2010 ,J112 1 il}°1 9: 1,2 Arrow Financial Services LLC vs. Cari Russell Case Number 2010-365 SHERIFF'S RETURN OF SERVICE 01119/2010 04:20 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2010 at 1620 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Cari Russell, by making known unto herself personally, at 1156 Belvedere Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 January 20, 2010 SO A WERS, NY R ANDERSON, SHERIFF a,dW >n f L(:AL+ Deputy Sheriff c;. ?oiultySURe ShFe,ift. lei2osoft. inc. Our File No.: 235838 --- APOTHAKER & ASSOCIATES, P.C. By: Kimberly F. Scian, Esquire Attorney I.D.# 55140 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC VS. Plaintiff CARI RUSSELL Defendant ACCEPTANCE OF SERVICE Civil Action I accept service of the Complaint in the above referenced matter. jA P) Date: CARI RU L , e endant Address: 1156 BELVEDERE ST CARLISLE, PA 17013-4003 F)LED-OFICE ()F THE PROs h1ONOTRRY 2010 FEB -s AM s: 35 CUMS" E L.lliu COUNTY PENNSYE.VANA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-365 Civil Team Our file No.: 235838 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 ARROW FINANCIAL SERVICES LLC Adow Plaintiff, vs. CARI RUSSELL BLED-?Y 1CE OF THE' FROTNr)Iti+OTMy 1010 FEB -8 AM 8: 35 Cumki-? Z ('0UNTY PE*'SYt,VAiA. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-365 Civil Team Civil Action STIPULATION IN LIEU OF JUDGMENT Defendant. The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on January 20, 2010, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, and Defendant, CARI RUSSELL parties as follows: 1. Defendant agrees to pay the sum of $3,866.81, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $3,866.81 shall be paid by the by Defendant, CART RUSSELL, to the attorneys for Plaintiff in the following manner: a. $275.00 to be paid on or before January 29, 2010; b. $275.00 to be paid on or before February 26, 2010; c. $550.00 to be paid on or before the 30'' day of each month (on agreed upon dates), beginning March 30, 2010 through July 30, 2010. All checks are to made payable to ARROW FINANCIAL SERVICES LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant, CARI RUSSELL makes all payments as stated above, this account will marked satisfied when CARI RUSSELL pays $3,300.00. 4. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $3,866.81, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to CARI RUSSELL by first-class, postage prepaid. .?.We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engag ? 4 -Collection /Kit?rly F. Scian, Esq C SSEL