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Home My WebLink About10-0727 2071500 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. 1 n EE GORDON & WEINBERG, P.C. '== BY: FREDERIC I. WEINBERG, ESQUIRE -t, Identification No.. 41360 JOEL M. FLINK, ESQUIRE N) -;c- Identification No.. 41200 -- 1001 E. Hector Street, Ste 220 ? Conshohocken, PA 19428 484/351-0500 f` ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS - 6108 W Touhy Ave, Niles IL CUMBERLAND C OUNTY 60714 VS. DOCKET NO. lp - loll Civil le?m s ROBERT RHINE 802 BALTIMORE RD SHIPPENSBURG PA 17257 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 THA T 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 I N 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 O 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 #Qa.00 PO ATW O,k-* 1013 a(P Rz*? aqj qso 4 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, ARROW FINANCIAL SERVICES LLC a debt buyer and successor in interest to the original creditor, WELLS FARGO FINANCIAL INC. 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 December 14, 2009 in the amount of $6,253.37. 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 3/15/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $6,253.37 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINK?, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01P. DB A 2071540 42265242 Arrow Financial Services, LLC ROBERT RHIM 50237595811919001 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 ar e 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" 2471500 ARROW FINIAL URVICR.S, LLC ROBERT RHIM 50237593811919001 State of Illinois County of Gook T' r that: AS'f TDl?VIT being duly served sworn according to law, depose and say 1. T am employed as the legal outsourcing clerk for the Plaintiff herein and T 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 NZLLS FARCO FINANCIAL INC when RSLLS FARGO FZNANCZAL INC 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 frog defendant to plaintiff, the aaount of $4,303.97 plus interest of $1,845.68 at the rate of 17.95* less credits in the aaount of $.00 totaling $6,149.65 as of October 26, 2009. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correc the best of my knowledge, information and belief. A Sworn to and ?Deror me thi of C-G lic -7,7777 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff d J.' ARY Jody S Smith Chief Deputy Edward L Schorpp Solicitor Arrow Financial Services LLC vs. Robert Rhine 2010 FFB 16 AH 9: 01 NTY Case Number 2010-727 SHERIFF'S RETURN OF SERVICE 02/04/2010 06:20 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on February 4, 2010 at 1820 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert Rhine, by making known unto Jean Rhine, Mother of defendant at 802 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 February 08, 2010 SO ANS ERS, 7YR ANDERSON, SHERIFF By eputy Sheriff