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Home My WebLink About10-2941Our file No.: 248525 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. JASON TROLINGER 185 KUTZ RD CARLISLE, PA 17015-9426 Defendant. 2Cl0hipY -3 N 1:42 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - o14?f ??Vi l (err 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 O ?d. oo pa AT ry ck? I'RaB?J e, ay 1 y98 dur*File No.: 248525 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. JASON TROLINGER 185 KUTZ RD CARLISLE, PA 17015-9426 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 JASON TROLINGER, an adult individual residing at 185 KUTZ RD CARLISLE, PA 17015-9426. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #4559908170415880; 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 $2,281.12. 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 $2,281.12 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for tiff A Law Firm Engage m Vbt Collection BY: David J. Apoth er, Esquire Dated: 4/28/2010 Our File No.: 248525 VERIFICATION David J. Anothaker, 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 relatj4to unworn falsification to authorities. David Apothaker, Esquire Attrney for Plaintiff DATE: 4/28/2010 ARROW FINANCIAL SERVICES LLC JASON TROLINGER 185 KUTZ RD CARLISLE, PA 17015-9426 STATEMENT OF ACCOUNT Debtor's Name: JASON TROLINGER Account Number: 4559908170415880 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $2,281.12 Our File No.: 248525 EXHIBIT "A" Our file No.: 248525 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorneys for Plaintiff Attorney ID# 307949 ARROW FINANCIAL SERVICES LLC ) Plaintiff, ) vs. ) JASON TROLINGER ) Defendant. ) :'7 , ... ,~.. ~i1.~t~-+.;rrlG~ '?F THf: PA~~~F';'v~~`A,~lY ZOIO JUW -8 AM $~ 54 CUM~~.~~~~~ t;~U~jY PETII~S`ILVA.MA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-2941 CIVIL TERM Civil Action STII'ULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on May 17, 2010, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, and Defendant, JASON TROLINGER parties as follows: 1. Defendant agrees to pay the sum of $2,473.12, 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 $2,473.12 shall be paid by the by Defendant, JASON TROLINGER, to the attorneys for Plaintiff in the following manner: a. $742.00 to be paid on or before May 28, 2010; b. $100.00 to be paid on or before the 28th day of each month, beginning June 28, 2010 until paid in full. All checks are to made payable to ARROW FINANCIAL SERVICES LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Our file No.: 248525 3. 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 pane, in the sum of $2,473.12, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex pane application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to JASON TROLINGER by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plat ff A Law Fi~aged in e t Collection By: J. (a'avallaro, Esquire /~ ~^ C I/~~ JASON TROLINGER