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Home My WebLink About10-1175i 2071174 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 c JOEL M. FLINK, ESQUIRE Identification No.: 41200 c? r ?? 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 = cx? 484/351-0500 ' ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS 6108 W Touhy Ave, Niles IL CUMBERLAND COUNTY 60714 VS. DOCKET NO. : 10 - l l75 am l Tpr*? JAMARIS LEGRAND 783 S HUMER ST ENOLA PA 17025-2623 and AWILDA LEGRAND 783 S HUMER ST ENOLA PA 17025-2623 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 $qa. 00 PO A'm/ CV_'* ioas174 z'T* 023'7 80lp T 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 December 30, 2009 in the amount of $4,890.98. 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 10/10/08. WHEREFORE, plaintiff claims of the defendant(s) the sum of $4,890.98 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EI RG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff POIP.DB G L7 2071174 42747290 Arrow Financial Services, LLC JAMARIS LEGRAND andAWILDA LEGRAND 6019180397215613 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 veri is tion is made subject to 18 Pa.C.S. 54904 which provides for certain pgnalVies for making false statements. EXHIBIT "A" 2071174 ARRAN FINANCIAL SERVICES, LLC JAMARIS LEGRAND and AWILDA LEGRAND 6019180397215613 State of Illinois § County of Cook AFFTDAVT I, ?Q " being duly served sworn according to law, depose and say that: T 1. T 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. T 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 GE Money Bank when GE honey sank 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 $3,510.95 plus interest of $1,216.93 at the rate of 24.75$ lea credits in the amount of $.00 totaling $4,735.88 as of October 26, 2009. 6. If called upon, affiant can testify at trig to the facts pertaining to this matter. The above facts are true andH rrect to the bes of my k edge, information and belief. Sw orn to and Subscribed befog me this t day "OFFICIAL SEAL" Jacqueline Younan Notary Public, State of Illinois Cornmission Expires 4/29/2012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~4t'~tx't~ of ~urrrGirri7~ ~:. _ ..~~ .3 9 ,'3, * 1'~i 4F~,r,E ~F TrE S~=r;t;=~ ;~' ~ i~3iN0~Al~1`1~'t`t ~oEO ~~ -~ A~ ~~ a2 CUM3~~~:3 e.;t)lJ~'Y ~~i Arrow Financial Services LLC I vs. Jamaris Legrand (et al.) Case Number 2010-1175 SHERIFF'S RETURN OF SERVICE 02/23/2010 09:36 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2010 at 2136 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jamaris Legrand, by making known unto Angel Legrand, Father of defendant at 783 S. Humer Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. 02/23/2010 09:36 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2010 at 2136 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Awilda Legrand, by making known unto Angel Legrand, Husband of defendant at 783 S. Humer Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $57.50 February 25, 2010 Icj CounfySuite Shenff. Telecsoft. Inc. SO ANSW , RON Y ANDERSON, SHERIFF By . Deputy Sheriff rs 2071174 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. JAMARIS LEGRAND 783 S HUMER ST ENOLA PA 17025-2623 and AWILDA LEGRAND 783 S HUMER ST ENOLA PA 17025-2623 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-1175 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. fR1 Judgment by Default $4,890.98 ~ Money Judgment $ ~ Judgment on Aaard of Arbitrators$ f~ 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: 484/351-05 PRO ONOTARY y~s~io 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 2071174 ~~~~.,, ,~ :, Ci,',vr~ , J,,.4ri y! COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET N0. 10-1175 ~.I~.oo P~ A-r'h/ JAMARI S LEGRAND C~~ ~ 1583 and ~'~ayol78 AWILDA LEGRAND I~laFi ce ~.a.~-~. ~ PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER ASSESSMErTT OF DAMAGES, VERIFICATION OF ADDRE33 AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) JAMARIS LEGRAND AND AWILDA LEGRAND above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $4,890.98 Less: Payments on Account ( $.00) Total: $4,890.98 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, 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 defendants, JAMARIS LEGRAND AND AWILDA LEGRAND, 783 S HUMER ST, ENOLA PA 17025-2623. 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 ~_ day of ~ ori~ 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 the sum of , $4,890.98 as per the above ce 'fication. J Protho ar GORDON & WEINB G, P C BY: FREDERIC NBERG, ESQUIRE JOEL M. LINK, ESQUIRE Attorne for Plaintiff ^ GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 91200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 984/351-0500 2071174 ARROW FINANCIAL SERVICES LLC vs. JAMARIS LEGRAND AWILDA LEGRAND and COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-1175 NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA JAMARIS LEGRAND 783 S HUMER ST ENOLA PA 17025-2623 DATE OF NOTICE/FECHA DEL AVISO: March 16, 2010 IMPORTANT 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;' INBERG, ESQUIRE JOEL M. ~` LINK, ESQUIRE P10D-2 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 2071174 ARROW FINANCIAL SERVICES LLC vs. JAMARIS LEGRAND AWILDA LEGRAND and COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-1175 NOTICE OF INTENTION TO TAIL DEFAULT TO/PARA AWILDA LEGRAND 783 S HUMER ST ENOLA PA 17025-2623 DATE OF NOTICE/FECHA DEL AVISO: March 16, 2010 IMPORTANT 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 W BERG, ESQUIRE JOEL M. F NK, ESQUIRE PLOD-2