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HomeMy WebLinkAbout10-2337O R Our ' File'No.: 247879 APP THAKER & ASSOCIATES, P.C. BY:'' David J. Apothaker, Esquire R ELI Atto rney I.D. #38423 Mr 7r?c NARY 520 Fellowship Road C306 Mou nt Laurel, NJ 08054 7 P = J (80C ) 672-0215 Atto eys for Plaintiff ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS 599 W TOUHY AVENUE ) CUMBERLAND COUNTY NIL S, IL 60714 ) NO.. 10 - a<337 evil l ?'.rm Plaintiff, ) vs. ) HENRY MUSSER ) 35 MOUNTAIN VIEW TER ) NE ILLE, PA 17241-9024 ) Defendant. ) 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 judgment 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIN OUT WHERE YOU CAN GET LEGAL HELP. 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 2 LI ERTY AVENUE CARLISLE PA 17013 717-249-3166 (2) 4ga.oo PA Arn Ce nsal3 e* 62110! YQ 0 Our File No.: 247879 APQTHAKER &?ASSOCIATES, P.C. BYE David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attrneys for Plaintiff ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS 599 W TOUHY AVENUE ) CUMBERLAND COUNTY NIL S, IL 60714 ) NO.. Plaintiff, ) VS. ) HENRY MUSSER ) 35 0UNTAIN VIEW TER ) NE ILLE, PA 17241-9024 ) Defendant. ) CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ARROW FINANCIAL SERVICES LLC, 5996 W TOUHY AVENUE, NILES, IL 60714 2. Defendant(s) is/are HENRY MUSSER, an adult individual residing at 35 MOUNTAIN VIEW NEWVILLE, PA 17241-9024. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of #4185823237753284; and said account was issued to Defendant(s) by WASHINGTON MUTUAL the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $865.37. A true and correct copy lof the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as r WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $865.37 and requests this Court award costs to the extent permitted by applicable law. APOTHAKE A OCIATES, P.C. Atto y fo Plaintiff A Law Firm EVRage in Debt CAectioi BY: 3/26/2010 David J. )?pbXaker, Esquire Our File No.: 247879 VERIFICATION uire hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. T"un ersigned understands that the statements therein are subject to the penalties of 18 Pa.C.S.A. 4904 rel4ing t4 unworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DAVE: 3/26/2010 ARROW FINANCIAL SERVICES LLC HE RY MUSSER 35 0UNTAIN VIEW TER NE ILLE, PA 17241-9024 STATEMENT OF ACCOUNT or's Name: HENRY MUSSER punt Number: 4185823237753284 nal Creditor: WASHINGTON MUTUAL BANK ice Due: $865.37 Our File No.: 247879 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~~~,C,c~~ ~i ~aany~,~,{~~~ .~ <~. ~~fFi c ...~~~,~ ~-r~Rl~l= FL's'..' 20~0~~~,~ "5 nil ~~ 1 C ,, _ _ _ ai`~~Vi~' ,,.r t _. _~~ :..~~ ~ ,'_~~. Arrow Financial Services LLC Case Number vs. Henry Musser 2010-2337 SHERIFF'S RETURN OF SERVICE 04/30/2010 01:25 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 30, 2010 at 1324 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Henry Musser, by making known unto himself personally, at 35 Mountain View Terrace, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $49.60 May 03, 2010 RONALD HOOVER, DEPUTY SO ANSWERS, -~.... i RON R ANDERSON, SHERIFF (o; Goun`ySuite Sherifr. Teleos~ft_ tr;c