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Home My WebLink About10-3042Our Pile No.: 248755 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. JANA L CLARK 16 S LOCUST LN MECHANICSBURG, PA 17050 Defendant. fly 20101,1i7li I i 0 nli I I. 1) 6, ?Iy COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I O - 3504ot 0-'Ivil Term 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 D 44&.00 Pb ATTV c?`? l'Ig41a Our File No.: 248755 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. JANA L CLARK 16 S LOCUST LN MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT I . Plaintiff is ARROW FINANCIAL SERVICES LLC, 5996 W TOUHY AVENUE, NILES, IL 60714. 2. Defendant(s) is/are JANA L CLARK, an adult individual residing at 16 S LOCUST LN MECHANICSBURG, PA 17050. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5155970001613823; 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 $1,440.12. 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 $1,440.12 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO ES, P.C. Attorney for ain ff A Law Firm Engage in D t Collection BY: David J. Apo aker, Esquire Dated: 4/30/2010 Our File No.: 248755 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 toxfnsVorn falsification to authorities. David J. Apothakk Esquire Attorney for Plaintiff DATE: 4/30/2010 ARROW FINANCIAL SERVICES LLC JANA L CLARK 16 S LOCUST LN MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: JANA L CLARK Account Number: 5155970001613823 Original Creditor: HSBC CARD SERVICES (III) INC Balance Due: $1,440.12 Our File No.: 248755 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FlLE~-~ t +''?= ~~-M ~~t ~,, Jody S Smith ~ ,~,~ ~t ~u,nGt~h~j~0 1)~ '~'~.~~ ~^; ~ ~ F,"~}A~Y Chief Deputy ` : ~~ I ~ ~~,~ ~ ~ ~ ~: ~~ Edward L Schorpp Solicitor ~ ~~ ~ = ~~ ~ ~~~~~ CUM~t ' '-~`w i~~.1U~#`M P~l~v~Y~V,~~~,~a Arrow Financial Services LLC Case Number vs. Jana L. Clark 2010-3042 SHERIFF'S RETURN OF SERVICE 05/11/2010 03:50 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 11, 2010 at 1548 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jana L. Clark, by making known unto Nigel Berie, Husband of defendant at 16 S. Locust Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. c Cr MICHELLE GUTSHALL, DE TY SHERIFF COST: $37.00 May 12, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF rrj Cou;itySuite Sher;ff. ieieosoff. Inc;. APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road, Suite C306 Mt. Laurel, NJ 08054 (856) 780-1000 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC Plaintiff, vs. JANA L CLARK Defendant. ,~ zo-o~ ~u~ z~' ~ ~~~ ~ P~`l~v~`~i.Vfi'~Ip COURT OF COMMONS PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-3042 CIVIL TERM Civil Action STIPULATION 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 this June 04, 2010, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, and Defendant, JANA L CLARK parties as follows: 1. Defendant agrees to pay the sum of $1,335.00, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid shall be paid by Defendant,. JANA L CLARK, to the attorneys for Plaintiff in the following manner: a. $267.00 to be paid on or before the 20'~ day of each month, beginning June 20, 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 3. In the event Defendant, JANA L CLARK makes all payments as stated above, this account will marked satisfied when JANA L CLARK pays $1,335.00. 4. In the event Defendant, JANA L CLARK fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff must notify Defendant's attorney(s), in writing of Defendant, JANA L CLARK's default. The name and address of Defendant's attorney(s) that notice will be sent to is: LAW OFFICE OF DARRELL DETHLEFS MIKE PYKOSH 2132 MARKET ST CAMP HII.,L, PA 17011 5. If the default is not cured within 15 days after written notice of Defendant's attorney(s), then Plaintiff has the right to obtain the entry of Judgment against Defendant, JANA L CLARK, ex parte, in the sum of $1,569.12, giving Defendant, DANA L CLARK credit for any sums actually paid pursuant to the terms of this Stipulation. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES Attorneys for Plaintiff A Law Firm ed in Deb llection By: Be ~ . Cav aro, Esquire JANA L LARK Our File No.: 248755 N Our File No.: 248755 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. JANA L CLARK Defendant. ILEZ)-0F ICE. 2010 N1,0 V 22 P€1 I : 4 9 PEN'1.'SY VA111A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-3042 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for tiff A Law Firm Engaged ' ebt Collection By: David J. Dated: 11/13/2010 1 11111 * Q 2 4 8 7 5 5 D I S N 1-* Esquire