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Home My WebLink About10-2561A Our Ille No.: 248147 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC 5996 W TOUHY AVENUE NILES, IL 60714 Plaintiff, vs. MARY MARIS 2209 CEDAR RUN DR EXT APT B CAMP HILL, PA 17011-7462 Defendant. ALEDI -0? ,' 'E ?G '?z THE FR`"7L'T",r' TARY 2010 APR 20 AN 10: 3 7 cumb : PEfNNS'iUANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - 01% 1 0,-.v'.t7e-,m 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 FIND 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 LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 O -+qa. oo PA A7r-4 M-0 17 eqq 8 1?0 24017y -Our Ffe No.: 248147 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC 5996 W TOUHY AVENUE NILES, IL 60714 Plaintiff, vs. MARY MARIS 2209 CEDAR RUN DR EXT APT B CAMP HILL, PA 17011-7462 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ARROW FINANCIAL SERVICES LLC, 5996 W TOUHY AVENUE, NILES, IL 60714 2. Defendant(s) is/are MARY MARIS, an adult individual residing at 2209 CEDAR RUN DR EXT APT B CAMP HILL, PA 17011-7462. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185865457706328; and said account was issued to Defendant(s) by WASHINGTON MUTUAL BANK, 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 $1,018.05. A true and correct copy 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 above rWHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,018.05 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for ai tiff A Law Firm EnaaRe in ebt Collectioi BY: David J. Apot 4y , Esquire Dated: 4/13/2010 Our File No.: 248147 r VERIFICATION David J. Apothaker, 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 Civil Action Complaint 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'U/M 3rn falsification to authorities. i David J. Apotl aaker', Attorney fo Plainti DATE: 4/13/2010 0 ARROW FINANCIAL SERVICES LLC MARY MARIS 2209 CEDAR RUN DR EXT APT B CAMP HILL, PA 17011-7462 STATEMENT OF ACCOUNT Debtor's Name: MARY MARIS Account Number: 4185865457706328 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,018.05 Our File No.: 248147 EXHIBIT "A" Ly ~ L 7 Our file No.: 248147 - Z APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 38423 ~~+t ~~ 20lU JuN 21 AM iU~ Z2 pp~~YLV u~ COURT OF COMMON PLEAS ARROW FINANCIAL SERVICES LLC ) CUMBERLAND COUNTY Plaintiff; ) DOCKET NO.: 10-2561 CIVIL TERM vs. ) MARY MARIS ) Civil Action STIPULATION IN LIEU OF JUDGMENT Defendant. ) The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on June 02, 2010, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, and Defendant, MARY MARIS parties as follows: 1. Defendant agrees to pay the sum of $1,151.55, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $1,151.55 shall be paid by the by Defendant, MARY MARIS, to the attorneys for Plaintiff in the following manner: a. $421.00 to be paid on or before June 12, 2010; b. $421.00 to be paid on or before July 12, 2010. All checks aze to made payable to ARROW FINANCIAL SERVICES LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant, MARY MARIS makes all payments as stated above, this account will marked satisfied when MARY MARIS pays $842.00. p~s(~C~~dl~ III JUN 1 0 2010 D •9 A 4. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $1,151.55, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to MARY MARIS by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. ~ aro, Esquire APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged in t Collection By: Ben J. avail MARY MARIS i Our File No.: 248147 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC Plaintiff, VS. MARY MARIS Defendant. OF THELPO?HONOTAP` 1010 DEC -2 AM 11: 53 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-2561 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AWCIATES, P.C. A Law Firm En2aked iii Debt By: David J. Apo aker, Esquire Dated: 11/18/2010 I ?nmi?imm