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HomeMy WebLinkAbout10-2210THIS 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 6108 W Touhy Ave, Niles IL 60714 Vs. ALISHA SHOLLY 19 LANCASTER AVE ENOLA PA 17025-2009 2074334 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : (D - aaID NOTICE %^ l W -,J m vil lean 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 G- 401-00 PA P7T*%/ 1103,20 R39 7qq w WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,792.33 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI ERG, ESQUIRE JOEL M. FLIN , ESQUIRE Attorney for Plaintiff PO1P.DB ,. 2074334 44008742 Arrow Financial Services, LLC ALISHA SHOLLY 6019171200915267 yzRIFICATION 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 peaking this verification. This verification is made subject to 18 Pa.C.S. 54904 which provides for certain penalties for making false statements. 0 EXHIBIT "A" 4 ALISHA SHOLLY 6019171200915267 State of Illinois County of Cook g 2074334 ARROW FINANCIAL SERVICES, LLC //? AFFIDAVIT being duly served sworn according to law, depose and say that: 1. Z am eageloyed 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 OR Money sank when Gs honey 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 damtges are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $2,842.20 plus interest of $876.90 at the rate of 24.75% less credits in the amount of $.00 totaling $3,719.10 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 Oct to the best of my knowledge, information and belief. AFFIANT Sworn to and Subscribed before me this day of 2010 Notary Public "OFFICIAL SEAL" Patricia Wallace Notary Public, State of imnois commission Expiry 10MOMM12 .. . . .?R,. w ry:h ?. .,y !ids e!? ?C' i (t[i 'lit '.? t 3t,16? A. j] ?+?,t?s{} 1C ' ?.atiCXaC.1 ftiliati'Yt ''7p:.; !?i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Tt ~=1Lr~[ ' " ~ t; ~~t~`11t, 9T ~.1111117f r,r~Y7'CS 1 ~,f ~ }~ ~Tk:,M T Jody S Smith Chief Deputy ~~~~ ~~~~ ~ ~ f~i~ ~; ~.~ Edward L Schorpp Solicitor ``~r~ ~ " ~' "'` -'"~~`~~ (r'~' pp i LVI'J _~,.~ 1 ~i•y~ ~i~.-~~-r .. _~:~'~c`~i ire.{ Arrow Financial Services LLC Case Number vs. 2010-2210 Alisha Sholly SHERIFF'S RETURN OF SERVICE 04/08!2010 08:14 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 8, 2010 at 2014 hours, he served a true copy of the within Complaint and Notice upon the within named defendant to wit: Alisha Sholly, by making known unto herself personally, at 19 Lancaster Avenue, 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. !,._._. NOAH CLINE, DEPUTY SHERIFF COST: $41.50 April 09, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ~:oi v' ._~ tf TE+?^..otT. Inc. ~, ~. 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 2074334 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET N0. 10-2210 ALISHA SHOLLY 19 LANCASTER AVE ENOLA PA 17025-2009 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. Judgment by Default $3,792.33 ~ Money Judgment $ .~ Judgment on Aovard of Arbitrators$ L1 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: 484/351-0500\ /1 PROTHbNOTARY s~a~~io L 1 ~ GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ARROW FINANCIAL SERVICES LLC 2074334 cn ^~ C~ c. --~c i ~ ~n ~, ? ..~, -.. ` (' COURT OF COMMON PLEAS._.~; ~_ CUMBERLAND COUNTY .. r' N ~ ;~. VS. ALISHA SHOLLY DOCKET N0. 10-2210 PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER ASSESSMENT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $3,792.33 Less: Payments on Account ( $.00) Total: $3,792.33 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. X4904, 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 defendant, ALISHA SHOLLY, 19 LANCASTER AVE, ENOLA PA 17025-2009. 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. $~~~ P~ A-~ 3. The said defendant(s) is (are) not in the military CK*r~~ service of the United States or otherwise within the coverage ofd the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age . ~ r ~~ • ,, AND NOw, this a~~ day of 2010 Judgment is entered in favor of the plaintiff(s) and a inst defendant(s) by default for want of an answer and damages assessed at the sum of , $3,792.33 as per the above ceiff~ication. A Proth e~2v ~f~ Y GORDON & W~I BERG-,~P . C . BY: i i FREDERIC INBERG, ESQUIRE JOEL M. FL , ESQUIRE Attorney for Plaintiff CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19928 484/351-0500 P.RROW FINANCIAL SERVICES LLC vs. 2074334 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-2210 ALISHA SHOLLY NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA ALISHA SHOLLY 19 LANCASTER AVE ENOLA PA 17025-2009 DATE OF NOTICE/FECHA DEL AVISO: April 29, 2010 Il~~ORTANT 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 CORDON & WEINBERG, P.C. i`I ,~ ~-` BY: FREDERIC I EII'V- G, ESQUIRE JOEL M. FL~I K, ESQUIRE P10D-2