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Home My WebLink About10-2404THIS 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. MELANIE CALAMAN 6 MOUNTAIN VIEW LN NEWVILLE PA 17241-8672 NOTICE 2074453 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. C7 t' - `n ca COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10 - 0?q04 i Trarm 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 O (717) 249-3166 4ga.00 PO AT?-4 0011108(a P,4 A0-31,Z I. 16 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 merchandise 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". 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of February 25, 2010 in the amount of $1,546.63. 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 2/16/09. I • L WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,546.63 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEIN RG, SQUIRE JOEL M. FLINK, F4S QU E Attorney for Pla' tiff P01P.DB 2074453 40869703 Arrow Financial Services, LLC ANIE CAIAMAN 9180350266462 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that facts set forth in the attached Affidavit which is incorporated by in the foregoing Complaint in Civil Action are true and correct the best of my knowledge, information and belief and is based upon which plaintiff has furnished to counsel. The language in the t is that of counsel and not of plaintiff. To the extent that the tents of the Complaint are that of counsel, plaintiff has relied upon in making this verification. This verification is made subject to 1? Pa.C.S. 54904 which provides for certain penalties for making false statements. EXHIBIT "A" 2074453 ARROW FINANCIAL SERVICES, LLC 6019180350266462 S to of Illinois § C unty of Gook § C AFFIDAVIT E-1? I, Bing duly served sworn according to law, depose and say t; 1. I am employed as the legal outsourcing clerk for the Plaintiff herein I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection w th this case and base this affidavit on Plaintiff's records, as well as the a count information provided to Plaintiff by Gz KoNzY SAM when cs Kowsy BAm sold to Arrow Financial Services, LLC. 3. Plaintiff's files are maintained in the usual and ordinary course of n$ ; 4. This action is based on a claim for breach of contract and that on are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $990.08 p s interest of $529.03 at the rate of 24.75% lass credits in the amount of $.00 totaling $ ,519.11 as of January 15, 2010. 6. If called upon, affiant can testify at trial as to the facts lning to this matter. The above facts are true and correcte best of my knowledge, nation and belief. 1-.-? \ to and Subscribed me this day r "OFFICIAL SEAL." L Jacqueline Yaunan (Votary Public, State of Illinois L Commission Expires 4/29/2012 i~ , 2074453 CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Pd. ~iy~ ~ ~"~~"y Identification No.: 81894 n~# ~~~®~~~ 1001 E. Hector Street, Ste 220 t; Conshohocken, PA 19428 ~/C# arc/ (p ~ ~ 484/351-0500 ~~,~ ~~~'~l ° ~ ~ ~ Q i i ARROW FINANCIAL SERVICES LLC _ COURT OF COMMON PLEAS ~: ° -n CUMBERLAND COUNTY +~~~~:` _ ~= __ {;~"n . :_~ i r .- rr. r ~. - vs. DOCKET N0. 10-2404 `~` ~~ -" ~' MELANIE CALAMAN ~' PRAECIPE FOR ENTRY OF JUDCd4ENT 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 $1,546.63 Less: Payments on Account ( $.00) Total: $1,546.63 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, 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, MELANIE CALAMAN, 66 GOBBLERKNOB RD, APT #1, NEWVILLE PA 17241-8672. 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. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. I AND NOW, this -~ day of .~ 2010 Judgment is entered in favor of the plaintiff(s) a against defendant(s) by default for want of an answer and damages assessed at the sum of , $1,546.63 as per the above cer ication. 0 Prothono ary GORDON & WEINBERG, P.C. BY : !~ FREDERIC W NBERG, ESQUIRE JOEL M. LIN ESQUIRE Attorney r Plaintiff 2074453 CORDON & 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET N0. 10-2404 MELANIE CALAMAN 66 GOBBLERKNOB RD, APT #1 NEWVILLE PA 17241-8672 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 $1,546.63 ~ Money Judgment $ ~ Judgment on Arrard of Arbitrators$ /~ 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: 484/351-05Q0 ~l ~ ~ ro CAN T GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 91200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 4841351-0500 2074453 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET N0. 10-2909 MELANIE CALAMAN TO/PARA NOTICE OF INTENTION TO TAIL DEFAULT MELANIE CALAMAN b6 GOBBLERKNOB STREET APT fll NEWVILLE PA 17241-8672 DATE OF NOTICEIFECHA DEL AVISO: May 27, 2010 IMPORTANT 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 NIAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU N1AY 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) 299-3166 GORDON & WEINBERG, P.C. BY: FREDER I'! WEINBERG, ESQUIRE JOEL FLINK, ESQUIRE P10D-2