HomeMy WebLinkAbout10-2153 2075019
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING REQU?fED?
GORDON & WEINBERG, P.C. = n
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360 ? Q
-JOEL M. FLINK, ESQUIRE <?} v
Identification No.: 41200 C_
1001 E. Hector Street, Ste 220 +v '
a Conshohocken, PA 19428 --
484/351-0500 °r
ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS
600 Broadhollow Road, Melville CUMBERLAND COUNTY
NY 11747
VS. DOCKET NO. : 10 - 6153 C1YiI Per" n1
LEISA M RUSSELL
217 SPRINGVIEW RD
CARLISLE PA 17015
and
BILLY R RUSSELL
217 SPRINGVIEW RD
CARLISLE PA 17015-9465
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 O
s
CARLISLE, PA 17013 4qa 00 P 0 qTT/
(717) 249-3166
CIO I1o447
a3a cvo
7. Defendant's last payment on account was made on 9/27/07.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$8,658.27 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. W IN RG, ESQUIRE
JOEL M. FLINK, SQUIRE
Attorney for Plaintiff
POIP.DB
2075019
42811170
Arrow Financial Services, LLC
LEISA M RUSSaLL andBILLY R RUSSELL
50237590893509001
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 beat 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.
NJM
EXHIBIT "A"
2075019
ARROW FINANCIAL SERVICES, LLC
LEISA M RUSSELL and
BILLY R. RUSSELL
50237590893509001
State of Illinois 5
County of Cook
/ AEFIMVIT
being duly served sworn accordin to law,
that, 9 depose and say
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 saLLS rARGo rINANCIAL INC when NZLLS
rAmso rINANCIAL 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 from defendant to plaintiff, the amount of
$6,502.61 plus interest of $2,060.12 at the rate of 13.75% less credits in the amount of
$.00 totaling $8,562.73 as of January 15, 2010.
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.
AFFIANT
to the best of my knowledge,
Swain to and Subscribed
before me this day
of, 2010
Notary Public
ARA
"OFFICIAL SEAL"
Patricia Wallace
Mary Public, State of Ulinois
L.W Comm+sswn Expires 10/10/2012