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Home My WebLink About10-2339Our File No.: 247854 AP THAKER & ASSOCIATES, P.C. BY:, David J: Apothaker, Esquire FILED Attorney I.D. #38423 520 Fellowship Road C306 + : _ ?, ,? y : V Mount Laurel, NJ 08054 80 672-0215 Attorneys for Plaintiff fly ?`'' ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS 599 W TOUHY AVENUE ) CUMBERLAND COUNTY NIL S, IL 60714 ) ami NO.: 60 - a339 let'M Plaintiff, ) vs. ) PE GY LEHMAN ) 19 EIDLER DR ) SHI PENSBURG, PA 17257-9746 ) 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 clai s 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 righ s important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA YER 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 YO WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PE SONS AT A REDUCED FEE OR NO FEE. CU BERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 4U.oo P0 Art-%/ &I 1`76051 & 2qb 14 L/ Our',File No.: 247854 APOTHAKER & ASSOCIATES, P.C. BY: David J: Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (80C) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS 599 W TOUHY AVENUE ) CUMBERLAND COUNTY NIL S, IL 60714 ) NO.: Plaintiff, ) vs. ) PE GY LEHMAN ) 19 EIDLER DR ) SHI PENSBURG, PA 17257-9746 ) 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 PEGGY LEHMAN, an adult individual residing at 19 BEIDLER DR , PA 17257-9746. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of #4071930201352089; and said account was issued to Defendant(s) by FIRST NATIONAL BANK OF , 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 $2,257.01. A true and correct of 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 included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of 57.01 and requesis this Court award costs to the extent permitted by applicable law. APOTHAKER & A CIATES, P.C. Attorney f r tA Law Firm Enszas d i ebt Collectioi BY: 3/25/2010 David J. Apotr, Esquire Our File No.: 247854 VERIFICATION ire hereby states that I am counsel for plaintiff in this action, and that I am authorized to take the is Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to of my knowledge, information, and belief. The undersigned understands that the statements therein are subject to the penalties of 18 Pa.C.S.A. 4904 relatig to/unsworn falsification to authorities. David J. A th r, Esquire Attorne or Plaintiff DAVE: 3/25/2010 ARROW FINANCIAL SERVICES LLC PE GY LEHMAN 19 EIDLER DR SHI PENSBURG, PA 17257-9746 STATEMENT OF ACCOUNT Debtor's Name: PEGGY LEHMAN Number: 40719302013 52089 Creditor: FIRST NATIONAL BANK OF MARIN Due: $2,257.01 Our File No.: 247854 EXHIBIT "A" ~'' r Our file No.: 247854 APOTHAKER & ASSOCIATES, P.C. BY: Jordan W. Felzer, Esquire Attorney I.D.# 38670 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC Plaintiff, vs. PEGGY LEHMAN Defendant. Civil Action ANSWER TO NEW MATTER Plaintiff, ARROW FINANCIAL SERVICES LLC, by and through their attorney, answers the following New Matter: 8. No responsive pleading is required. 9. Denied. Plaintiff s claim is not barred by the applicable Statute of Limitations. 10. Denied. Plaintiff s Complaint brings a valid Cause of Action against Defendant. 11. Denied. Plaintiff s claim is not barred by the applicable Statute of Limitations. 12. Denied. Plaintiff s claim is not barred by the Doctrine of Laches. 13. Denied. Plaintiff s claim is not barred by the Doctrine of Estoppel. 14. Denied. Plaintiff s claim is not barred by the Doctrine of Unclean Hands. 15. Denied. Plaintiffs complaint is not barred by the Doctrine of Consent. Fib. 201 ~ Fi'''t` I $ ~'~"~ 2: riY~~~ ~ ~ 'vim COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DOCKET NO.: 10-2339 CIVIL TERM 16. Denied. Plaintiffs claim is not barred by the Doctrine of Accord and Satisfaction. 17. Denied. Plaintiff s claim is not barred by the Doctrine of Duress. 18. Denied. Plaintiff s claim is not barred by the Doctrine of Release. 19. Denied. Plaintiff s claim is not barred by the Doctrine of Waiver. WHEREFORE, Plaintiff demands that Defendant's New Matter be dismissed. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection BY: DATED: May 13, 2010 VERIFICATION Jordan W. Felzer, Esquire 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 Answer to New Matter are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities. .._- Jor W. Felzer, Esquire Att rney for Plaintiff DATE: May 13, 2010 Our file No.: 247854 APOTHAKER & ASSOCIATES, P.C. BY: Jordan W. Felzer, Esquire Attorney I.D.# 38670 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DOCKET NO.: 10-2339 CIVIL TERM vs. PEGGY LEHMAN Plaintiff, Defendant. Civil Action CERTIFICATION OF SERVICE I, Jordan W. Felzer, Esquire, attorney for Plaintiff, certify that on May 13, 2010, I mailed DOUGLAS LOVELACE JR, ESQUIRE 36 DONEGAL DRIVE CARLISLE, PA 17013 J rdan W. Felzer, Esquire ttorney for Plaintiff Date: May 13, 2010 aF uM David D. cBuefC d Renee IC, Simpson Prothonotary WiN111 1st Deputy Prothonotary Irene E. Morrow Kirks. Sohonage, ESQ i►a,q j Solicitor 7 750 2ncr Deputy Protkonotary Office of the Prothonotary Cumberland County, Pennsylvania �d -02339 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 291" DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • rFa.K,(717)240-6573