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Home My WebLink About10-2564-+ Our`File No.: 248142 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. CHARLES W FLORY 936 BALTIMORE RD APT 3 SHIPPENSBURG, PA 17257 Defendant. FILE w0; r? 0 Tw- - F-Y7?.i -F,tin' 2010 APR 20 AM 10:: 7 PENNS`; LVANI A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 -ol&oy NOTICE &i.j a -T? 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 PO 0" r rbqu ?, ay0?7? OurTile No.: 248142 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. CHARLES W FLORY 936 BALTIMORE RD APT 3 SHIPPENSBURG, PA 17257 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 CHARLES W FLORY, an adult individual residing at 936 BALTIMORE RD APT 3 SHIPPENSBURG, PA 17257. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4185865339714805; 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 $1,722.92. 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. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,722.92 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS8MIATES, P.C. Attorney pr P aintii A Law Firm Ens ed ' Debt BY: Dated: 4/13/2010 David I Akpkttaker, Esquire Our File No.: 248142 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 made subject to the penalties of 18 Pa.C.S.A. 4904 understands that the statements therein are unworn falsification to authorities. David ?. Ap6thafer, Esquire Atto ev for Plaintiff DATE: 4/13/2010 ARROW FINANCIAL SERVICES LLC CHARLES W FLORY 936 BALTIMORE RD APT 3 SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: CHARLES W FLORY Account Number: 4185865339714805 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,722.92 Our File No.: 248142 EXHIBIT "A" Our File No.: 248142 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. CHARLES W FLORY Defendant. ri_~' -. ~1'~r ~•_ ~Ivcs-!o P~ r .~!Y Gt~~ - .~, ~, , -~ ,~ ~'~_ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-2564 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & Attorne . A Law Firm En ap By: David J. ~ Dated: 7/28/2010 SOCIATES, P.C. r Plaintiff in Debt Collection Esquire