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Home My WebLink About10-2154THIS IS AN ASSESSMENT 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 600 Broadhollow Road, Melville NY 11747 VS. RICKEY THOMAS 400 STONEHEDGE LN MECHANICSBURG PA 17055 2074740 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. C1 0 C ?, n l? Sys ? ' - ; 6 rn cv COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10 -01154 NOTICE a,VlI-F f l 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 0 49A.00 PO ATh/ ?? lio4c?? A 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". S. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of February 23, 2010 in the amount of $3,496.92. 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 1/18/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,496.92 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE NBE G, ESQUIRE JOEL M. FLINK, UIRE Attorney for Plaintiff P01P. DB 2074740 42647816 Arrow Financial Services, LLC RICKEY THOMAS 6019192102094266 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 verification is made subject to 18, Pa.C.S. 54904 which provides for certain penalties for making false statements. NAME EXHIBIT "A" 2074740 ARROW FINANCIAL SERVICES, LLC RICKEY THOH&S 6019192102094266 State of Illinois County of Cook / AFFIDAVIT I, being duly served sworn according to lay, depose and say that: 1. I am e_ loved 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 ca money Bank when 68 Money 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 $2,434.02 plus interest of $998.53 at the rate of 24.751 less credits in the amount of S.00 totaling $3,432.55 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 cor ect to the best of my knowledge, information and belief. AFFIANT Sworn to and Subscribed before me this day of -:? , 2010 "OFFICIAL SEAL" ,? Patricia Wallace Notary Public, State o1 Illinois MY Commission Expires 1 U/10/2012 Notary Public 2074740 GORDON & WEINBERG, P.C. BY: FREDERIC I. EINBERG, ESQUIRE Identificati n No.: 41360 JOEL M: FLIN , ESQUIRE Identificati n No.: 41200 1001 E. Hector St eet, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC vs. RICKEY THOMAS 1-8. Denied. require no resp Procedure. H thereof is dema COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-2154 {'~ G c- ~ --+ ~.. _,_ :,,P ;: _... - ; ALL: ,. ~~ ~- ~ ;.:; -~ W ;~ c~a ,+ %i ~... '-Ac . These averments are conclusions of law which e under the applicable Rules of Civil r, these averments are denied and strict proof at the time of trial. WHEREFORE, P~aintiff demands damages against the defendant(s) as s forth in plaintiff's Complaint. GORDON & WEINBERG, .C. BY: FREDERI~EINBERG, ESQUIRE JOEL M. K, ESQUIRE Attorney for Plaintiff P014 f; VERIFICATION FREDERIC I. INBERG, ESQUIRE, hereby states that he is the attorney for the plaintiff in this action and verifies that the statements made i the foregoing pleadings are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to t e penalties of 18 Pa. C.S. Section 4904 relating to unswo n falsification to authorities. FREDERIC I. WEINB SQUIRE CERTIFICATION OF SERVICE I, FREDERIC I. NEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of Plaintiff's Reply to New Matter, via First Class ail, postage pre-paid, to all other parties or their counsel of record. FREDERIC I. WE BE , ESQUIRE Dated: ~ ~~ ~~ 2074740 2: 22� CORDON & WEINBERG, P.C. ZO13 JUL 5 Pty BY: FREDERIC I . WEINBERG, ESQUIRE CUMBERLAND COUNTY Identification No. : 41360 IENNSYLVANIA 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. : 10-2154 RICKEY THOMAS °— PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. GORDON & WEINBERG, P C. BY: FREDERIC I . WEINBERG, ESQUIRE JOEL M. FLINK, 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 C ,AVEINBERG, ESQUIRE Dated � ��,