HomeMy WebLinkAbout10-294216.
Our File No.: 248609
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.
ROBERT A SHOKES
900 BRENTWATER RD
CAMP HILL, PA 17011-1505
Defendant.
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COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: ?o - dgga
NOTICE
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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
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Our File No.: 248609
'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.
ROBERT A SHOKES
900 BRENTWATER RD
CAMP HILL, PA 17011-1505
Defendant.
NO..
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is ARROW FINANCIAL SERVICES LLC, 5996 W TOUHY AVENUE, NILES, IL
60714
2. Defendant(s) is/are ROBERT A SHOKES, an adult individual residing at 900 BRENTWATER
RD CAMP HILL, PA 17011-1505.
3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of
Account #4756984420504378; and said account was issued to Defendant(s) by HSBC CARD SERVICES (III)
INC, 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 $2,193.85. 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
$2,193.85 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & ASS(
Attorney fo?
A Law Firm Engav m
BY:
Dated: 4/28/2010
David J.
RTES, P.C.
Collection
Our File No.: 248609
•
VERIFICATION
David J. A_pothaker, 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 unworn falsification to authorities.
David J. Apot?sqi
Attorney f Plaintiff
DATE: 4/28/2010
ARROW FINANCIAL SERVICES LLC
ROBERT A SHOKES
900 BRENTWATER RD
CAMP HILL, PA 17011-1505
STATEMENT OF ACCOUNT
Debtor's Name:
Account Number:
Original Creditor:
Balance Due
ROBERT A SHOKES
4756984420504378
HSBC CARD SERVICES (III) INC
$2,193.85
Our File No.: 248609
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
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Arrow Financial Services LLC
vs. Case Number
Robert A. Shokes 2010-2942
SHERIFF'S RETURN OF SERVICE
05/10/2010 07:31 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May
10, 2010 at 1929 hours, she served a true copy of the within Complaint and Notice, upon the within namec
defendant, to wit: Robert A. Shokes, by making known unto himself personally, at 900 Brentwater Road,
Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him
personally the said true and correct copy of the same.
SHERIFF COST: $41.50
May 11, 2010
MICHELLE GUTSHALL, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
c;. Crun`~Siait~ S^:;nff.. Teieo~otl. lnc.
Our File No.: 248609
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. )
ROBERT A SHOKES )
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Defendant. )
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COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 10-2942 CIVIL TERM
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER & ASSOCIATES, P.C.
Attorneys fo laintiff
A Law Firm Enga~ di' Debt Collection
By:
David J. A cer, Esquire
Dated: 9/22/2010
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