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HomeMy WebLinkAbout10-12062071133 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. n ? -, BY: FREDERIC I. WEINBERG, ESQUIRE - cm Identification No.: 41360 , '`- rya JOEL M. FLINK, ESQUIRE N _ = Identification No.. 41200 1001 E. Hector Street, Ste 220 --- -'- Conshohocken, PA 19428 - rv 484/351-0500 - cry ARROW FINANCIAL SERVICES LLC 6108 W Touhy Ave, Niles IL 60714 VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. CURTIS THOMPSON 325 N WEST ST CARLISLE PA 17013-1961 NOTICE :/6 -1201. (2,uz L"tslu, 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 J ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION o) 0 32 S. BEDFORD STREET CARLISLE, PA 17013 1.: /aJ,QaY (717) 249-3166 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 31, 2009 in the amount of $3,331.85. 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 1/5/08. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,331.85 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W NBER , ESQUIRE JOEL M. FLIN , ES IRE Attorney for i.ntiff POIP.DB 2071133 42744575 Arrow Financial Services, LLC CURTIS THOMPSON 6019180383585219 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, plai.ntift,\has relied upon counsel in making this verification. This verificatioh ifs made subject to 18 Pa.C.S. 54904 which provides for certain penaltie4 Or making false statements. ... EXHIBIT "A" 2471133 ARROW FINANCIAL SERVICES, LLC CURTIS THOMPSON 6019180383585219 State of Illinois County of Cook § (? p ? p AFFIMVIT according to law, depose and say that: being duly served sworn ac 1. I 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 Ga money sank when 6a Koney Bank 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, a &Mount of $2,398.36 plus interest of $826.15 at the rate of 24.75* less cred' s n the aa?ount of $.00 totaling $3,224.51 as of October 26, 2009. 6. If called upon, affiant can testify at trial a t the facts pertaining to this matter. The above facts are true a?rect.? best oi?/ my knowledge information and belief. "OFFICIAL SEAL" Jacqueline Younan Notaublic, State of Illinois Ery ommission Expires 4/29/2012 Sworn to and Subscribed _-I Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY N~~Y .~y~~~, of ~~uiti;~~~~ ~.~ r,,~ 20ta MAR 2~ ~~ 2' ~` CU~J!~~ ~;~L~~'; ~C~ Cf3UN1Y ~.;vwSYLVAN' Arrow Financial Services LLC Case Number vs. 2010-1206 Curtis Thompson SHERIFF'S RETURN OF SERVICE 03/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on March 25, 2010 at 0925 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Curtis Thompson. After several attempts the Complaint and Notice has expired. SHERIFF COST: $38.80 March 25, 2010 SO ANSWERS, ~_ (~~ RON R ANDERSON, SHERIFF i, , t s Sam 2071133 2l10N0 12 PM I: 191 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQ6 ERLA hi D C0U1A T Y Identification No.: 413606°'SY?!Ir JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC VS. CURTIS THOMPSON 325 N WEST ST CARLISLE PA 17013-1961 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10-1206 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Plaintiffs' Complaint in Civil Action in the above-captioned matter for an additional thirty (30) days. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI B G, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff(s) a? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson C c Sheriff ma) Fi Jody S Smith Zrn © r- Chief Deputy ter- r Richard W Stewart r-= --I Solicitor d Arrow Financial Services LLC Case Numbe r"" vs. 2010-1206 Curtis Thompson SHERIFF'S RETURN OF SERVICE 12/07/2010 12:33 PM - William Cline, Corporal, who being duly sworn according to law, states that on December 7, 2010 at 1233 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Curtis Thompson, by making known unto himself personally, at 325 N. West Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. ? ? ,0 'ILLIAM CLINE, DEPUTY SHERIFF COST: $49.60 December 08, 2010 SO ANSWERS, RONNY R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC 6108 W Touhy Ave Niles Illinois 60714 r-- vs COURT OF COMMON PLEA' CUMBERLAND COUNTY DOCKET NO.: 10-1206 CURTIS THOMPSON 325 N WEST STREET CARLISLE, PA 17013-1961 NOTICE DEFENDANT, CURTIS THOMPSON WISHES TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, BY ENTERING A WRITTEN APPEARANCE AND ANSWER AS DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST ME. I AM AWARE THAT IF I FAIL TO DO SO THE CASE MAY PROCEED WITHOUT ME AND A JUDGEMENT MAY BE ENTERED AGAINST ME BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. I FURTHER UNDERSTAND THAT I COULD LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO ME. THIS NOTICE SHOULD BE ACTED UPON IMMEDIATELY. IF YOU ARE UNABLE TO DO SO CONTACT THE LEGAL SERVICES PROVIDED BELOW. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET ` ? =m K rn CARLISLE, PENNSYLVANIA 17013 - -<a (717) 249-3166 ?q IN THE COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC 6108 W Touhy Ave, Niles, Illinois 60714 vs COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-1206 CURTIS THOMPSON NOTICE OF APPEARANCE 325 N WEST STREET CARLISLE, PA 17013-1961 TO Frederic I. Weinberg, and Joel M. Flink, Esquires, Attorneys for Plaintiff and to the Court of Common Pleas Cumberland County Clerk of the Court. EACH OF YOU PLEASE TAKE NOTICE that Defendant Curtis Thompson hereby will appear in the above -entitled cause and requests that all further papers and pleadings herein, except original process, be served upon the Defendant at the address below stated, pursuant to Civil Rule 318, 305(4)(a). Dated this 3 day of January, 2011. lw?a W . (Defendant's Signature) (Print Name) (Address) C lp lk\?a\t ,? l> ??3 (City, State, Zip) IN THE COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC 6108 W Touhy Ave, Niles, Illinois 60714 vs COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-1206 CURTIS THOMPSON CERTIFICATE OF SERVICE 325 N WEST STREET NOTICE OF INTENT TO APPEAR CARLISLE, PA 17013-1961 CERTIFICATE OF SERVICE I certify under penalty of perjury under the laws of the State of Pennsylvania that , on the date stated below, l did the following: On the 3 day of January , 20111 mailed by regular U.S. Mail postage prepaid a true copy of the Notice of Intent to Appear in the above -entitled matter to Frederic I. Weinberg and Joel M. Flink, Esquires at the following address: 1001 E. Hector Street. Ste 220 Conshohocken, PA 19428. Dated this 3 day of January , 2011, in Conshohocken, PA 19428. t ?? W Curtis W. Thompson IN THE COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC 6108 W Touhy Ave, Niles Illinois 60714 i. rn CO =rn . rrn ? vs COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-1206 CURTIS THOMPSON 325 N WEST STREET r-j w 331• co DEFENDANT ANSWER, DEFENSE, CARLISLE, PA 17013-1961 COUNTERCLAIMS I. ANSWER I Curtis Thompson, defendant answer this complaint as follows: --? rs r-a M 1. Deny. Defendant, Curtis Thompson has no documentation, proof or evidence that confirms Plaintiff ARROW FINANCIAL SERVICES, LLC as a debt buyer and successor to a creditor identified as GE Money Bank. 2. Admit. 3. Admit. 4. Deny. Defendant only used credit card for dental medical services. Furthermore, Defendant is unaware of any statement of account that states otherwise. 5. Deny. Defendant used credit card to purchase dental services not covered by Defendant's dental insurance totaling $750.00. 6. Deny. Defendant does not acknowledge or recognize Plaintiff, ARROW FINANCIAL SERVICES LLC as the creditor owed any debt by Defendant, Curtis Thompson. 7. Defendant does not deny or admit any date of last payment regarding this complaint . II. AFFIRMATIVE DEFENSES Defendant's defenses are as follows: 8. Plaintiff, ARROW FINANCIAL SERVICES, LLC. knew or should have known that Defendant, Curtis Thompson was insolvent at the time the credit card was issued for dental services only. To the best of Defendants knowledge the credit card in question was used for $750 in dental services, and nothing more. 9. Plaintiff, ARROW FINANCIAL SERVICES, LLC, knew or should have known that Defendant, Curtis Thompson was at the time not creditworthy for any amount of credit. 10. Plaintiff, ARROW FINANCIAL SERVICES, LLC, knew or should have known that Defendant, Curtis Thompson was a high risk debtor and should not have been issued a credit card for any amount of money. 11. Plaintiff, ARROW FINANCIAL SERVICES, LLC, assumed all responsibilities and risk for the Defendants lack of ability to pay, knowing that any credit card debt could possibility not be paid in a timely manner. 12. Plaintiff, ARROW FINANCIAL SERVICES, LLC, knew or should have known that Defendant, Curtis Thompson's credit rating was poor at best, therefore, making him a prime target for a predatory lending scheme. 13. Plaintiff, ARROW FINANCIAL SERVICES, LLC, knew or should have known that Defendant, Curtis Thompson has a credit report that has multiple bankruptcies, delinquent credit obligations, property and tax liens, student loans, and home mortgage foreclosure sheriff sale listed on his credit report. 2 14. Plaintiff, ARROW FINANCIAL SERVICES, LLC, knew or should have known that creditor GE Money Bank exercised poor judgment advancing credit to Defendant, Curtis Thompson. 15. Plaintiff, ARROW FINANCIAL SERVICES, LLC attorneys Frederic 1. Weinberg and Joel M. Flink, Esquires have refused and failed to resolve this complaint amicably and therefore "hung" the phone up on Defendant Curtis Thompson when he called to propose a resolution 16. Plaintiff, ARROW FINANCIAL SERVICES, LLC. offers no verifiable documentation stating the terms, policy, and obligations associated with this credit card agreement. WHEREFORE, Defendant, Curtis W. Thompson prays that this Honorable Court authorize a document forensic on this credit card agreement to be paid for by the Plaintiff, ARROW SERVICES, LLC.. Defendant, Curtis Thompson, respectfully request that this Honorable Court, review this credit agreement to insure that any and all banking regulations, policies, requirements related to the Truth in Lending Act were met to authorize this credit card agreement. Defendant, Curtis Thompson respectfully request that this Honorable Court dismiss Plaintiff, ARROW FINANCIAL SERVICES, LLC claim for $3,331.85 as being unreasonable and predatory at best and reissue a claim for the original dental services of $750 plus reasonable interest. Furthermore, Defendant, Curtis Thompson request that this lawsuit be dismissed and that a judgment be entered against the plaintiff for any attorney fees. DATED this day 4 of January, 2011. Respectfully, CLO -. Curtis W. Thompson Curtis Thompson 325 North West Street Carlisle, Pennsylvania 17013 3 IN THE COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC 6108 W Touhy Ave, Niles, Illinois 60714 vs COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-1206 CURTIS THOMPSON DEFENDANTS ANSWER 325 N WEST STREET CARLISLE, PA 17013-1961 CERTIFICATE OF SERVICE I certify under penalty of perjury under the laws of the State of Pennsylvania that, on the date stated below, I did the following: On the 3 day of January , 20111 mailed by regular U.S. Mail postage prepaid a true copy of Defendants Answer in the above entitled matter to Frederic I. Weinberg and Joel M. Flink, Esquires at the following address: 1001 E. Hector Street. Ste 220 Conshohocken PA 19428. Dated this 3 day of JanuaZ, 2011, in Conshohocken. PA 19428. Curtis W. Thompson IN THE COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA ? d IN AND FOR THE COUNTY OF CUMBERLAND rnw zm c M-' ARROW FINANCIAL SERVICES LLC X? m 6108 W Touhy Ave A N c a ? o Niles Illinois 60714 C:) -? -n > 2 rn _q w V. vs COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-1206 CURTIS THOMPSON 325 N WEST STREET DEFENDANT ANSWER, DEFENSE, to CARLISLE, PA 17013-1961 Plaintiff's Reply to New Matter DEFENDANTS' OBJECTION, ASSERTION OF AFFIRMATIVE DEFENSES AND ANSWER TO PLAINTIFFS' REPLY TO NEW MATTER TO THE HONORABLE COURT OF COMMON PLEAS FOR THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND Defendant Curtis W. Thompson, files the following statement in response to Plaintiff's Reply to New Matter. OBJECTION On or about May 26. 2011, Plaintiff replied to Defendant Curtis W. Thompson's submission of New Matter to comply with the Rules of Civil Procedure within the Commonwealth of Pennsylvania. Plaintiff's response is replete with argument that contains no factual information regarding the Defendant's indebtness to Plaintiff. Specifically, the Plaintiff offers no itemized information stating that debt even exist. More specifically, the Plaintiff offers no contract agreement stating the terms of indebtness and any other applicable information necessary to show that Defendant owes Plaintiff any debt. Therefore, the Defendant objects to Plaintiffs assertion that averments contained in this complaint require not response under the applicable Rules of Civil Procedure. Subject to this objection, Defendants asserts the following affirmative defenses. ASSERTION OF AFFIRMATIVE DEFENSES Pleading further, Defendant hereby asserts the following affirmative defenses to which they may be entitled. The Defendant asserts that they tb know nothing about ARROW FINANCIAL owning any debt owed in the amount of $3,331.85. 2. The Defendant asserts that Plaintiff has not responded to Defendant's claim for validation of debt referred in Plaintiff's civil proceeding (Docket No. 10-1206). The Defendant asserts that the Federal Trade Commission, in 15 U.S.C. 1692g, requires that debt collectors cease collection of a debt until verification of that debt is mailed to Plaintiff. 4. The Defendant asserts that the Plaintiff is in violation of the Truth in Lending Act as outlined in Defendant's response to this complaint. WHEREFORE, the Defendant in this matter denies any indebtness to Plaintiff and each and every allegation outlined in this complaint. WHEREFORE, Defendant, Curtis W. Thompson prays that this Honorable Court authorize a document forensic on this credit card agreement to be paid for by the plaintiff, ARROW FINANCIAL SERVICES, LLC.. Defendant, Curtis W. Thompson, respectfully request that this Honorable Court, review this credit agreement to insure that any and all banking regulations, policies, requirements related to the Truth in Lending Act were met to authorize this credit card agreement. Defendant, Curtis W. Thompson respectfully request that this Honorable Court to demand Plaintiff, ARROW FINANCIAL SERVICES, LLC to produce an itemized proof of claim for 53,331.85. DATED this day 28 of May 2011. Respectfully, Curtis W. Thompson 325 North West St Carlisle, Pennsylvania 17013 IN THE COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC 6108 W Touhy Ave, r?l ? Niles, Illinois 60714 ? -r n ? - rrnn :n cZn? A. vrn vs COURT OF COMMON PLE° ? ?Sci 0 CUMBERLAND COUNTY DOCKET NO.: 10-1206 CURTIS THOMPSON CERTIFICATE OF SERVICE 325 N WEST STREET PLAINTIFF'S REPLY TO NEW CARLISLE, PA 17013-1961 MATTER CERTIFICATE OF SERVICE I certify under penalty of perjury under the laws of the State of Pennsylvania that , on the date stated below, I did the following: On the 28 day of May , 20111 mailed by regular U.S. Mail postage prepaid a true copy of the Defendants response to Plaintiff s Reply To New Matter in the above -entitled matter to Frederic I. Weinberg and Joel M. Flink, Esquires at the following address: 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428. Dated this 28 day of Maw, 2011, in Conshohocken PA 19428. ai;mw- qmev? Curtis W. Thompson IN THE COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND ARROW F ANCIAL SERVICES LLC 6108 W To by Ave Niles Illinois 60714 vs CURTIS T OMPSON P.O. Box 4 3 Lynchburg, irginia 24505-0403 cl?o c - v 2 rc b ?+ G a i COURT OF COMMON PLEA?p - 1-y CUMBERLAND COUNTY DOCKET NO.: 10-1206 DEFENDANT ANSWER, DEFENSE, New Matter New Matter 1. Plaintiff has not responded to Defendants notification of validation debt. Exhibit A 2. Plaintiff has violated the Truth In Lending Act by not providing following: ¦ The terms of credit were not clear and obvious to the defendant ¦ The terms of credit were not in a meaningful sequence ¦ The terms of credit were not in a form that the consumer may keep ¦ The terms of credit does not itemize the amount financed ¦ The terms of credit does not include applicable variable rate disclosures. ¦ The terms of method determining the charge, balance upon which charge is imposed. ¦ The terms of total of payments. ¦ A statement of billing rights ¦ The terms of credit did not include total sales cost, demand feature, security interest, insurance, required deposit, and reference to contract. 4. Plaintiff s Complaint is time-barred by the applicable Statute of Limitations on credit card debt in the state of Pennsylvania. 5. Def?ndant claims Lack of Privity as Defendant has never entered into any contractual or /creditor arrangements with Plaintiff. 6. Plai tiff's Complaint violates the Statute of Frauds as the purported contract or agreement falls within a class of contracts or agreements that are required to be in writing. The pu orted contract alleged in the Complaint was not in writing and not signed by or by some another person authorized by Defendant and who was to answer to the lleged debt, default, or miscarriage of the other person. 7. Plai tiff is not the real party in interest and has failed to name all necessary parties. RE, Defendant, Curtis W. Thompson prays that this Honorable Court authorize a ARROW F: that this Ho regulations, credit card Court dismi plus be d DA7 cument forensic on this credit card agreement to be paid for by the plaintiff, ANCIAL SERVICES, LLC.. Defendant, Curtis W. Thompson, respectfully request rable Court, review this credit agreement to insure that any and all banking ,licies, requirements related to the Truth in Lending Act were met to authorize this eement. Defendant, Curtis W. Thompson respectfully request that this Honorable Plaintiff, ARROW FINANCIAL SERVICES, LLC claim for $3,331.85 as being and predatory at best and reissue a claim for the original dental services of $750 le interest. Furthermore, Defendant, Curtis W. Thompson request that this lawsuit and that a judgment be entered against the plaintiff for any attorney fees. this day 5 of July 2011. Respectfully, Curtis W P.O. Box on Lynchburg, Yirginia 24505-0403 July 4, 201 Curtis W. P.O. Box Lynchburg, IVirginia 24505-0403 Arrow Fina cial Services, LLC C/O FrederiI. Weinberg, Esquire & Joel M. Flink, Esquire 1001 E. H or Street, Ste 220 Conshohocken, PA 19428 Re: Doc et NO. 10-1206 Dear Arrow) Financial Services: This comm mcation is in response to your concern regarding the collection of a debt referenced in the Cum erland County Court of Common Pleas docket no. 10-1206. I do not bell ve I owe what you say I owe therefore I dispute this debt. I am well aware of my rights under the Fair Debt Collection Practices Act (FDCPA) and Pennsylvania state law regarding t collection of delinquent debts. In view of such, I hope to save both of us a great deal of time by letting you know that not only do I dispute the validity of this debt, I have also checked wit the Pennsylvania Office of the Attorney General and verified that the Statute of Limitations or enforcing this type of debt through the courts in Pennsylvania has expired. Therefore, s ould you decide to pursue this matter in court I intend to inform the court of my dispute oft is debt and that the "statute of limitations" has expired. This letter i your formal notification that I consider this matter closed and demand that you, or anyone affiliated with your law firm, stop contacting me regarding this or any other matter except to advise me that your debt collection efforts are being terminated or that you or the creditor are aking specific actions allowed by the FDCPA or Pennsylvania state laws. Be further Practices ) State Attoj action is n Sincerely, Tised that I consider any contact not in accordance with the Fair Debt collection a serious violation of the law and will immediately report any violations to my General, to the Federal Trade Commission and, if necessary, take whatever legal ssary to protect myself. Curtis W. IN ARROW 6108 W T Niles, Illir vs COURT OF COMMON PLEAS OF THE STATE OF PENNSYLVANIA IN AND FOR THE COUNTY OF CUMBERLAND ANCIAL SERVICES LLC by Ave, s60714 n N CD rnr --i rrnn-n - ' == r UM D o0 cut --+o C MC o-n COURT OF COMMON PLEjig a4 =a C) _4 CUMBERLAND COUNTY -< o rv ? < DOCKET NO.: 10-1206 CURTIS MPSON CERTIFICATE OF SERVICE P.O. Box 4 3 NEW MATTER Lynchburg, Virginia 24505-0403 CERTIFICATE OF SERVICE I certify un er penalty of perjury under the laws of the State of Pennsylvania that , on the date stated belo , I did the following: On t e 5 day of July , 20111 mailed by regular U.S. Mail postage prepaid a true copy of the Defendants New Matter in the above -entitled matter to Frederic I. Weinberg and Joel M. Flink, Esquires at the following address: 1001 E. Hector Street. Ste 220 Conshohocken, PA 19428. Dat d this 5 day of Jul2011, in Conshohocken PA 19428. L L . Curtis W. Thompson 2071133 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs . DOCKET NO. : 10-1206 CURTIS THOMPSON TJ- w rn r � r— s PRAECIPE TO WITHDRAW COMPLAINT Cr; +±' TO THE PROTHONOTARY: = a Kindly withdraw the above-captioned action, without - prejudice . GORDON & WEINBERG, P.C. BY: FREDERIC I W INBERG, ESQUIRE JOEL M. FL , ESQUIRE Attorney for Plaintiff P006 CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Praecipe to Withdraw Complaint to Pa.R.C. P. 1028 (c) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDE"WEINBERG, ESQUIRE Dated /D(05