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Home My WebLink About10-3567T;',hlf Our File No.: 249054 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. KELLY A CIELO 2713 MARKET ST 1 ST FL CAMP HILL, PA 17011-4552 Defendant. 11 I ?1 i I f } f L' t ..l 2010 'i CU1Y? - i!}, 1-11COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 - 55(.7 NOTTCF. 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 $4,1•00 AP I%rN C?" ISa`?3`I ?w Iq as7(o r Our File No.: 249054 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. KELLY A CIELO 2713 MARKET ST 1 ST FL CAMP HILL, PA 17011-4552 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 KELLY A CIELO, an adult individual residing at 2713 MARKET ST 1ST FL CAMP HILL, PA 17011-4552. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5440455009125322; 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 $1,175.12. 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 $1,175.12 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER rged OCIATES, P.C. Attome laintiff A Law Firm Eng Debf Collection BY: Dated: 5/24/2010 David J. ApdgUer, Esquire Our File No.: 249054 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 relate to unsworn falsification to authorities. David J. aker, Esquire Attorn v for Plaintiff DATE: 5/24/2010 ARROW FINANCIAL SERVICES LLC KELLY A CIELO 2713 MARKET ST 1 ST FL CAMP HILL, PA 17011-4552 STATEMENT OF ACCOUNT Debtor's Name: KELLY A CIELO Account Number: 5440455009125322 Original Creditor: HSBC CARD SERVICES (III) INC Balance Due: $1,175.12 Our File No.: 249054 EXHIBIT "A" SHERfFF'S OFFICE OF CUMBERLAND COUNTY Sheri R Anderson f ~ '(~~~, ~1.~~-~~~"3~~-`,,~q`t ~~~,~tr o lp6k~~~~ r Jody S Smith ~~~ ~j: ~~ Chief Deputy t~' ;~~t;~ -g ;~~.,~, 't~~t~~~ ~~ ~~ ~tv.a Arrow Financial Services LLC vs. Kelly A. Cielo Case Number 2010-3567 SHERIFF'S RETURN OF SERVICE 06/04/2010 08:07 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 4 2010 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kelly A. Cielo, by making known unto herself personally, at 2713 Market Street 1st Floor, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 June 07, 2010 ~~~~--- STEPH N BENDER, DEPUTY SO ANSWERS, ~`'~~~ RON R ANDERSON, SHERIFF (ci Goun'ySuite Sheriff. Teiecsott, tnc. ..• .~ Our File No.: 249054 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. KELLY A CIELO Defendant ,- , 2010 .~1~~ ZD Pal ~~ 45 CU4,~ ~ '''v'!`1iY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-3567 CIVIL TERM Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KELLY A CIELO, in the default of an Answer, in the amount of $1,175.12 computed as follows: Amount claimed in complaint: $ 1,175.12 Less: Amount Paid: ( 0.00) Plus: Interest from May 24, 2010 to July 13, 2010 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL ~ ~ $ 1,175.12 I certify that Defendant, KELLY A CIELO, last o addr ss is 2713 MARKET ST 1ST FL CAMP HILL, PA 17011-4552. David J. A aker, Esq. Attorney for 'tiff Dated: July 13, 2010 ~1~.0o Pa +~'rM Ci ~ [06(0 ~~ a~5~~ ~~lt~tCe ~uQ,t~,eG~ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KELLY A CIELO 2713 MARKET ST 1ST FL CAMP HILL, PA 17011-4552 ARROW FINANCIAL SERVICES LLC Plaintiff vs. KELLY A CIELO Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-3567 CIVIL TERM Civil Action NOTICE 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. A thaker Es . at this telephone number: 800-672-0215 ~ao ~o Our File No.: 249054 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. KELLY A CIELO Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-3567 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 that false statements herein are made subject to the unsworn falsification to authorities. ific o are true and correct. I understand ~e alti of 18 P~,:C.S.A. §4904, relating to David J. Apothaker, Esq. Attorney for Plaintiff Dated: July 13, 2010 Our File No.: 249054 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. ) KELLY A CIELO ) Defendant ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-3567 CIVIL TERM Civil Action AFFIDAVIT OF NON-NIILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS. 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 2713 MARKET ST 1ST FL CAMP HILL, PA 17011-4552. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593 if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defen e M powe ata Center has sent back our inquiry indicated that the Defendant(s) is/are not in a mi itary David J. Apothaker, Esq. 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SCRA pee.ccilaas a'+e rwkd 6rve mt aatesded to ealead ~e octiaiiss d~ler dMenice, F>r~aore, dome proleetioraa d Mae SCRA ~y easatd eo papaws ~o rt-s te+ceived ocdeas to sapc>Nt ibr stir drat a a be taut >IVho hseo cot ac~asly txpa aclks d~ or w~rerlg ssporhdlisr iwrsa~^ead '2}te Last Dwac en AcEMr Uiry asYs t~ecaxe a nsaher d proseeiSoaa d Sf.'RA ealead boyawad 6e i~at daMes d acfns ~p ?boas wm wmaid rely trsAws tare6gfae are aped to seek 4ur~btl3ept toussd m assac Iha[ Q rich 6nerrreed to Seyttiiar s+4n~ben ssader ire SCRA ire }+iooett+ed WAR2+ffiSC,t lbis eat~cate seas >P~d heed aa+ a ^roe cord SSN pavtidcd b7 the raqucstu. prnvi3ol ao caareum awe ar S&TT wit ewe as etraaeau eers~t:ale to be provided Rwlyott II?.AAII)iS1~CQ 249054 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS . ~ CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC )COURT OF COMMON PLEAS )CUMBERLAND COUNTY vs. ) KELLY A CIELO ) NO. 10-3567 CIVIL TERM To: KELLY A CIELO 2713 MARKET ST 1ST FL CAMP HILL, PA 17011-4552 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 Date: June 28, 2010 BAR DAVID J. AP R, 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 Our File No.: 249054 ARROW FINANCIAL SERVICES LLC IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. L- . KELLY A CIELO Qn J3 Mar44 NO.: 10-3567 CIVIL TERM Defendant(s) F L- `� PRAECIPE FOR WRIT OF EXECgTI* To the Prothonotary: �• M--- rn ._ Issue a Writ of Execution in the above matter, u"�v no ,°4c) (1) directed to the Sheriff of BLAIR County; y n C:)=a . Orn 5cl -+v (2) against KELLY A CIELO,defendant(s); and (3) against S&T BANK 1100 LOGAN BOULEVARD ALTOONA, PA 16602, Garnishee(s); (4) and index this writ in the judgment index (a) against KELLY A CIELO,defendant(s), and (b) against S & T BANK 1100 LOGAN BOULEVARD ALTOONA, PA 16602,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 $1175.12 Interest from July 20, 2010 $191.05 Minus Payments made $0 Plus Costs $193.00 Total $1559.17 David J. X29thaker, Esquire Attorney for Plaintiff(s) l Cyr L2#A IS a �x �� WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-3567 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF 010A r COUNTY: To satisfy the debt,interest and costs due ARROW FINANCIAL SERVICES LLC Plaintiff(s) From KELLY A.CIELO,2713 MARKET STREET, lsT FLOOR,CAMP HILL,PA 17011 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEES)as follows: S&T BANK, 1100 LOGAN BOULEVARD,ALTOONA,PA 16602-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. and to notify the garnishees)that: (a)an attachment has been issued;(b)the garnishees) 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, (2) 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. Amount Due$1,175.12 Plaintiff Paid$ Interest FROM JULY 20,2010-$191.05 Attorney's Comm. % Law Library$.50 Attorney Paid$176.50 Due Prothonotary$2.25 Other Costs$193.00 Date: 4!12/13 David D. Buell,Prothonotary Deputy REQUESTING PARTY: Name:DAVID J.APOTHAKER,ESQUIRE Address: APOTHAKER&ASSOCIATES,P.C. 520 FELLOWSHIP ROAD C306 MT.LAUREL,NJ 08054 Attorney for:PLAINTIFF Telephone:800-672-0215 Supreme Court ID No. -ter- r M M" Our File No.: 249054 rr, r) c t APOTHAKER&ASSOCIATES, P.C. W o By: David J. Apothaker,Esquire 520 Fellowship Road C306 PO Box 5496 r Mount Laurel,NJ 08054 .. (800) 672-0215 Attorneys for Plaintiff ARROW FINANCIAL SERVICES LLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 10-3567 CIVIL TERM KELLY A CIELO ) Civil Action Defendant ) S & TBANK ) Garnishee ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee T BANK, dissolved. David othaker,Esquire Attorney for Plaintiff 49.50 PfJ ATr/ e'#ggqq8 0,99037