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Home My WebLink About10-3044Our File No.: 249061 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothakero EsquireRu fi' Attorney I.D. 438423 4 520 Fellowship Road C306 2II { r'lr-i ( ) AN Mount Laurel, NJ 08054 A?-? 1": ? (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC 5996 W TOUHY AVENUE NILES, IL 60714 Plaintiff, vs. DAVID A HEISHMAN 131 N SPORTING HILL RD MECHANICSBURG, PA 17050-2438 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 -Z044 L-1V i l (erM 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.00 PQ ATry e* ag177.7, a ? Our File No.: 249061 APO :HAKER & ASSOCIATES, P.C. ?BY: David J. Apothakere 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. DAVID A HEISHMAN 131 N SPORTING HILL RD MECHANICSBURG, PA 17050-2438 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 DAVID A HEISHMAN, an adult individual residing at 131 N SPORTING HILL RD MECHANICSBURG, PA 17050-2438. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5440455011296079; 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 $1,656.87. 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 $1,656.87 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Engac Dated: 4/30/2010 BY: David J. RTES, P.C. Debt Esquire Our File No.: 249061 VERIFICATION David J. A othaker Es uire 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)*wom falsification to authorities. David J. Ap squire Attorney f Plaintiff DATE: 4/30/2010 ARROW FINANCIAL SERVICES LLC DAVID A HEISHMAN 131 N SPORTING HILL RD MECHANICSBURG, PA 17050-2438 STATEMENT OF ACCOUNT Debtor's Name: DAVID A HEISHMAN Account Number: 5440455011296079 Original Creditor: HSBC CARD SERVICES (III) INC Balance Due: $1,656.87 Our File No.: 249061 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~y1~`~it, at ~tfui~r,*~~4 ~ ~{,, L t +- rr lr.a..~...-~ - ~r - v Jody S Smith Chief Deputy Edward L Schorpp SOIICItOr rv~4' " ti ~., ~~r ,~~ ~:;;~ f{~ t' _l_~ Arrow Financial Services LLC vs. David A. Heishman Case Number 2010-3044 SHERIFF'S RETURN OF SERVICE 05/24/2010 05:50 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 24, 2010 at 1756 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: David A. Heishman, by making known unto himself personally, at 131 N. Sporting Hill Road, 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. SHERIFF COST: $37.00 May 25, 2010 GE LD WORTHINGT ,DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (ci CounfySuite 5henff, Lele-csofi, t~~c. .., ~ Our File No.: 249061 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney LD.# 38423 520 Fellowship Road C306 Mount Lauret, NJ 08054 (800)672-0215 Attorney for Plaintiff ARROW FINANCIAL SERVICES LLC Plaintiff, vs. DAVID A HEISHMAN Defendant. `'fir 11~r ,~-'f .. ' '~~~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-3044 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSO IATES, P.C. Attorneys for 1 tiff A Law Firm Engage m ebt Collection By: David J. Ap ~cer, Esquire Dated: 7/17/2010