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Home My WebLink About10-3043Our File No.: 248959 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. RONALD W BORZA 421 ALLENDALE WAY CAMP HILL, PA 17011-8407 Defendant. ZO?? ?ri ? ) l7 n?'I 1 ? ? .i Ty COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: la - 3043 a-, v i wr'hl 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 *ga.oo PA Al'M G-V JfM08 L>4 N 17`71 A. Our File No.: 248959 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #3$423 , 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. ) RONALD W BORZA ) 421 ALLENDALE WAY ) CAMP HILL, PA 17011-8407 ) 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 RONALD W BORZA, an adult individual residing at 421 ALLENDALE WAY CAMP HILL, PA 17011-8407. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5407915025399087; 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 $1,000.69. 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 $1,000.69 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS IATES, P.C. Attorney f Pl 'ntiff A Law Firm Engag d in ebt Collection BY: David J. Apo , Dated: 4/30/2010 Our File No.: 248959 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 ttvWworn falsification to authorities. David J. Apot cer, Esquire Attorney for Plaintiff DATE: 4/30/2010 ARROW FINANCIAL SERVICES LLC RONALD W BORZA 421 ALLENDALE WAY CAMP HILL, PA 17011-8407 STATEMENT OF ACCOUNT Debtor's Name: RONALD W BORZA Account Number: 5407915025399087 Original Creditor: HSBC CARD SERVICES (III) INC Balance Due: $1,000.69 Our File No.: 248959 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~~~-~~'• ~~':~~`~~: _ Sheriff ,. ,~- ~.a,r ~ ~ ~" "~~t~F?Y ~~~kttit~ o{ ~:I~rtGcr(r~~ Jody S Smith ~ Chief Deputy ZQ ~ Q N ~f ~ ~ ~ i~~ 2' ~ 3 -t Edward L Schorpp Solicitor , ~F ~.~ -- ;.~I~~ r , ~, ..'~ '+ ~F ~` i~„~''~ ~L~~~~~ Arrow Financial Services LLC Case Number vs. Ronald W. Borza 2010-3043 SHERIFF'S RETURN OF SERVICE 05/14/2010 06:52 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 2010 at 1849 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ronald W. Borza, by making known unto himself personally, at 421 Allendale Way, 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. MICHELLE GUTSHALL, DEPUTY SHERIFF COST: $41.50 May 17, 2010 SO ANSWERS, ~° RON ~ R ANDERSON, SHERIFF (c; GeuntpSuite Sheriff, Teleoseft, luc- ' ~ fiiL~~- Our File No.: 248959 '';` ?r ~' ~~~'`" ,~~ _~#>~y APOTHAKER cS'~ ASSCICIATES, P.C. By: David J. Apothaker ~ a ! 0 ~ ~ ~ - ~ 3i"i ~ ~ : ~ .{ Attorney I.D.# 38423 520 Fellowship Road C306 C~~l°'~ ~- ~~ ~ ~ ~ ~i,.~'NT1' Mount Laurel, NJ 08054 rf=``"'~~''~-' ~~ ~ ~~ r~ '~' (800) 672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS OF ARROW FINANCIAL SERVICES LLC ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 10-3043 CIVIL TERM RONALD W BORZA ) Civil Action Defendant ) PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, RONALD W BORZA, in the default of an Answer, in the amount of $1,000.69 computed as follows: Amount claimed in complaint: Less: Amount Paid: Plus: Interest from Apri130, 2010 to June 22, 2010 at the legal interest rate of 0.00% per annum Attorney fees TO I certify that Defendant, RONALD W WAY CAMP HILL, PA 17011-8407. $ 1,000.69 ( 0.00) 0.00 0.00 $ 1,000.69 address is 421 ALLENDALE David J. Apothaker, Esq. Attorney for Plaintiff Dated: June 22, 2010 ~ ~ y~srl ' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: RONALD W BORZA 421 ALLENDALE WAY CAMP HILL, PA 17011-8407 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. RONALD W BORZA NO.: 10-3043 CIVIL TERM Defendant NOTICE Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION _ JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq, at this telephone number: 800-672-0215 ~- Our File No.: 248959 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff' ARROW FINANCIAL SERVICES LLC ) Plaintiff ) vs. ) RONALD W BORZA ) Defendant ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-3043 CIVIL TERM Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penaltie% 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. ~f r -~. David J. Apothaker, Esq. Attorney for Plaintiff Dated: June 22, 2010 • Our File No.: 248959 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC vs. Plaintiff RONALD W BORZA Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA . SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 421 ALLENDALE WAY CAMP HILL, PA 17011-8407. We inquired with the web site of the Defe e anpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 2 20 -2593, if the Defendant(s) islare in any branch of the military. ~ Mary M. Snavely-Dixon, Director of th De ense anpower Data Center has sent back our inquiry indicated that the Defendant(s) is/are no in a military. David J. Apothaker, Esq. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-3043 CIVIL TERM I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 1$ Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dcpastrrsent as'IMa~e'kiae~urr Date Ceuta lcm-22-3410 453~3fi Mi'tav Sreims Rrpart Ftarauant ro the 5ar+ict ?riembers C"n9 Reie4'Act ?![ last F'a°sy\fTiWt B+f3~ YhtE AeBrorr Drast States Aetira ~ tai bate ~ Hserk ;L~i° RCrNAiD Based oac tbeinfaKmaeoo _ . _ SORZA y~ batix ~ the I}.3il1C does nt+t pos3ess sey a~xmaex~a R= ~~8 Wr indni~al straws upon dte inC'or~ifyo~n data barrio of dte Uepm,snetrt of Die ;vianpowar Data Ctrttdr. baud oa the rEorrrrabou ~ you provided. die abm~e a >lu cvKreat status d`tbe iadM1Vdiad as ~ ak brarxhes o[the utr~anaed Sar°ices (Amax, Larry, tiiarirre Caps, Air Farts, NOAA, Pubic Heatt6. sad Coast ~Gord). ~~ ~~ ` _ 111ay'.rl. saar^dy-Doan, larectae Department aC T3efease - i4laagorrtir bffia Center 1b40 R'~aa #.: Smite 440 Ardadmn,'~A 3:.209-359 The Drtettte MappaRer Data Center (U'•4ff?C) is sa orgar+at of the Dopermterrt aCIIdeme that atisiataias drr Ikfease ~ and ~y Res s~ tn~xs> ~ ~ s~ ~d~ a< y r~ ~,~~ tart and other ~ systxtos. 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Sege S4 L'SC Apts.. §S2I{c). 1f you obtain ad~iaoat i~'otstatiaa about the petsors (c g., atr 5S;'+I, imprm~d ar:CVfaCy oITI?C1p, a taidtiYt camel, l'oc can ~ reQoc~ agaes ~ dis tl'eb site sad a°r asi prrnide a trot- certitxate ~ that gorty. Tlrs rrspunsc r~ects actitis dory state datQe floc was kst on active dsrty, ~ it was withal for prcce~ng 367 daps Far hiatoricat ifamatiea, phase raatacs ttx Sevin S[1t.A pails-+~ caetact .ilorrc it~t~otstwtierr ox ".tetivr Derry status" Actia>• ddty s>alus u repated v dais cati6caM is d~rd in accordance a~ 14 L'SC ~ 14I{dl(1) £or a prod of naorc >hm 30 conseyctrtire days. In she rase of a nt~btr rI the 1Sational Gs;ar4 inc-rdes arnica vocia~ a eai to attnK senyer arxhcrrzed b}° the Presid~cnt or the Secreto~• at`Dtfeasr tar a period of rnarr than 34 coasectxire days fonder 32 L'SC § S42tt1 Ca paipcasts d ~ to a a~hona8 cmirgcncy der3artd by for Prrsitkant and s~at~partrd by Federal irads. AI! Acaire Quad Reserve (AGR? members nrttst be assigned against ~s ffiYhorited roan position m ~e nroi they support. This irxDtdes Nan°Ir TARS, hiariat Corps ARs and Coate t:rmrd RPAs. Actir°r Duty stators also atrpdea tQ a L't~urmed Barrier m~abrr rs3m is sn acgsr dut}• caaxnessioae3 a6icer o3the l.S Public lieatth Sttrict tx dre NaRia~eal Ckeaaic and Atrnospfrrric Adortrstrad±at {>~=O.?~"l C~s~d Carps) £or a period of more than 30 consecutirT dots. Covaraxs L'»der the SCi~.~ it Bra~ad«~ ix Sonar C'RS+es i^avcrage order ilbr SCR,S is tsoadQ u same ta3ea anet acbdes xome catc~oeies of peaatrs an acti+,~e drty for peaposes affffie St^RA also a;odd rat tx repart~ed u oa Artsti Y7trty under tlis ccvt~c°a-e. 11am' times orders tee arac~dcd to ramad thr period ofre3vt drtyr nlech acwld extts9d SGRA pratertirans~ Persons S to rtiy cm d~ websitt etrdbcataatr shosdd check to mate sore the orders ea xltich stJRA protections art board here not beast amended to ertmd the irrclutive domes of stance. Futhamorc. some prtxrctioos Mite SCRA may attend to persons trdro bare receirrd orders m report for acme door a to be Rdt><ted, bnt abo have not actuat5" beam ~ ~y ~ y repnt~d ~ s>shx4ian. Tlxe last hate on Active Dnty~ enby is ia>portarrt bexanse a ansber aipratetticnts d SCRA a Dr}ad fbe last darts d active duty. Thox alto wasidrely on iha catiGcait art urged to seek lcgtd cotmsd to eusae that e>t rights groarantecd m Strvicc ane~ers mtder the S[RA are pracected ~'AR'v`~vG_ T2ris certi5cate was pm+.ided based as a pmt and SS.'~I pronidcd hp fire rtquesia. Prrn~ rm erraneaas ~ tt SSti w~ crane ~ erraineaus eerti6caae to be prrn~ided Repot ID(."fL1t.'N5B.4L~i 248959 OFFICE OF THE PROTHONOTARY v COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC )COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) RONALD W BORZA ) NO. 10-3043 CIVIL TERM To: RONALD W BORZA 421 ALLENDALE WAY CAMP HILL, PA 17011-8407 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 ASSOCIATION 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3166 BAR icl DAVID J. APOTI~AKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 Date: June 07, 2010 Our File No.: 248959 ARROW FINANCIAL SERVICES LLC IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. RONALD W BORZA ya( 446IL40t)e NO.: 10-3043 CIVIL TERM Defendant(s) CCL�� l'�l�� f70� PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of CUMBERLAND County; ' (2) against RONALD W BORZA,defendant(s); and -<.I> co G CP (3) against PNC BANK 333 WEST SOUTH STREET CARLISLE PA 17013,Garnishee C ' 5c - --4r (4) and index this writ in the judgment index (a) against RONALD W BORZA, defendant(s), and (b) against PNC BANK 333 WEST SOUTH STREET CARLISLE PA 17013, as Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of Garnishee(s)as follows: Bank Attachment Only - All assets and accounts, including, but not limited to, bank accounts, brokerage firm accounts, stocks, cd's, insurance, safety deposit boxes, etc. (5) Amount Due $1000.69 Interest from July 01,2010 $161.87 Minus Payments made $0.00 Plus Costs $179.00 Total $1341.56 S co David J. Apoth er, Esq. SUS Attorney for Plaintiff(s) n 6.so ��- C� WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-3043 Civil COUNTY OF CUMBERLAND) CIVIL ACTION-LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ARROW FINANCIAL SERVICES LLC Plaintiff(s) From RONALD W BORZA,421 ALLENDALE WAY,CAMP HILL,PA 17011 (1) You are directed to levy upon the property of the defendant(s)and to sell (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: PNC BANK,333 WEST SOUTH STREET,CARLISLE,PA 17013-ALL ASSETS AND ACCOUNTS,INCLUDING BUT NOT LIMITED TO,BANK ACCOUNTS,BROKERAGE FIRM ACCOUNTS,STOCKS,CD'S,INSURANCE,SAFETY DEPOSIT BOXES,ETC. and to notify the garnishee(s)that:(a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. I Amount Due$1,000.69 L.L.$.50 Interest FROM JULY 1,2010-$161.87 Atty's Comm % Due Prothy$2.25 Arty Paid $176.50 Other Costs $179.00 Plaintiff Paid Date:MARCH 18,2013 David D.Buell,Prothonotary (Seal) By: Z'-9— - Deputy REQUESTING PARTY: Name: DAVID J.APOTHAKER,ESQUIRE Address:APOTHAKER&ASSOCIATES,P.C. 520 FELLOWSHIP ROAD C306 P.O.BOX 5496 MT.LAUREL,NJ 08054 Attorney for:PLAINTIFF Telephone: 856-780-1000 Supreme Court ID No. MU 'T'r Our File No.: 248959 ' -w APOTHAKER&ASSOCIATES, P.C. �<' N By: David J. Apothaker,Esquire 520 Fellowship Road C306 �w PO Box 5496 - Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 10-3043 CIVIL TERM RONALD W BORZA ) Civil Action Defendant ) PNC BANK ) Garnishee ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, PNC LEsquire David J. Ap , Attorney for Plaintiff *q.5D PQ A-rr4 rn Saco SHERIFF'S OFFICE OF CUMBERLAND COUNTY anny R Anderson Sheriff Jody S Smith Chief Deputy ' 26 P Richard W Stewart Solicitor OMCF "F TkE-�KRIFr P W 5 Ytwll ,N1,/q Arrow Financial Services LLC Case Number vs. j Ronald W. Borza 2010-3043 SHERIFF'S RETURN OF SERVICE 03/28/2013 03:21 PM -William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Tyler Negley, Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on April 2, 2013 to Ronald W. Borza at 421 Allendale Way, Camp Hill. PA 17011-8407. 09/25/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $88.40 SO ANSWERS, K'V''�' � C�V� September 25, 2013 RONNY R ANDERSON, SHERIFF P3 i