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Home My WebLink About10-09622071327 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. C T! BY: FREDERIC I. WEINBERG, ESQUIRE .ti 9: _= Identification No.: 41360 _ M rn a) JOEL M. FLINK, ESQUIRE -° Identification No.: 41200Y 1001 E. Hector Street, Ste 220??; Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS rn 6108 W Touhy Ave, Niles IL 60714 CUMBERLAND COUNTY VS. DOCKET NO. 10 -4(Da 3V1 GLENN SIGNOR JR 25 W PINE ST ENOLA PA 17025 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 a _ CARLISLE, PA 17013 (717) 249-3166 02, 4qa. oo Pp A"Ty GCS' I D1486 a3r7a.G(, 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 merchandise 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 18, 2009 in the amount of $2,350.21. 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 3/1/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,350.21 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. IN ,RERG, ESQUIRE JOEL M. FLIN SQUIRE Attorney for Plaintiff POIP.DB 2071327 40641477 Arrow Financial Services, LLC GLENN SIGNOR aR 6020522100155338 VERIFICATION I hereby state that I an 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 Ba.C.S. 54904 which provides for certain penalties for making false statements. 46 EXHIBIT "A" GLENN SIGNOR JR 6020522100155338 State of Illinois County of Cook § 2071327 ARROW FINANCIAL SERVICES, LLC AFFIDAVIT c I, being duly served sworn according to law, depose and say that: 1. 1 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 xomy aum when Gs monzy aunt 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 $1,524.34 plus interest of $771.09 at the rate of 24.7$$ less credits in the amount of $.00 totaling $2,295.43 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 information and belief. the beat/-gf my knowledge, Sworn to and Subs ibed before me this day t. WSW C? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILE i_? .); i;i= Sheriff r)rARY Jody S Smith Chief Deputy 201Q FEB 1N? 2: j Edward L Schorpp Solicitor , i ?F ' `QTY Arrow Financial Services LLC vs. Glenn Signor, Jr. Case Number 2010-962 SHERIFF'S RETURN OF SERVICE 02/08/2010 04:35 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on February 8, 2010 at 1635 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Glenn Signor Jr., by making known unto Mary Signor, Mother of defendant at 25 W. Pine Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 February 09, 2010 SO A ER , NY R ANDERSON, SHERIFF By.? Deputy Sheriff (n) Gnu,;?Y&A, -? Teieosuit In:: F�./L ED—OFFICE OF THE GORDON & WEINBERG, P. C. n .;, . BY: FREDERIC I . WEINBERG, ESQUIRE 7t Identification No. : 41360 JOEL -� PFD �; � JOEL M. FLINK, ESQUIRE CUMBERLAt@ COUNTY Identification No. : 41200 � EAtPdSYl.V�N1A 1001 E. Hector Street, Ste 220 ' Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY VS . DOCKET NO. : 10-962 GLENN SIGNOR JR STATEMENT OF INTENTION TO PROCEED TO THE COURT: Plaintiff intends to proceed with the above-captioned matter. GORDON & WEINBERG, P.C. BY: FREDERId I . AINBERG, ESQUIRE JOEL M. K, ESQUIRE Attorney for Plaintiff Dated: �� CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of foregoing pursuant to Pa. R.C. P. 10280) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC WE NBERG, ESQUIRE Dated: / tr P018