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Home My WebLink About10-3694Our File No.: 249390 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. VICTORIA PORTERFIELD 118 CONODOGUINET MOBILE EST NEWVILLE, PA 17241 Defendant. T! i'?^ri ' "? }t 2010 JUG -4 FM LI: 07 CUivi , COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 116 - 3169? 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 $9.00 ?? ?. ?/ I eK-i1 1s33o? R--tL aY3lr( Our File No.: 249390 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. VICTORIA PORTERFIELD 118 CONODOGUINET MOBILE EST NEWVILLE, PA 17241 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 VICTORIA PORTERFIELD, an adult individual residing at 118 CONODOGUINET MOBILE EST NEWVILLE, PA 17241. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5488975025467864; 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 $2,225.87. 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 $2,225.87 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A CIATES, P.C. Attorney f r P ntiff A Law Firm Ens d i Debt C?Wectinr BY: Dated: 5/28/2010 David J. Apo?*`r, Esquire Our File No.: 249390 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 to*sworn falsification to authorities. David J. A for Plaintiff DATE: 5/28/2010 ARROW FINANCIAL SERVICES LLC VICTORIA PORTERFIELD 118 CONODOGUINET MOBILE EST NEWVILLE, PA 17241 STATEMENT OF ACCOUNT Debtor's Name: VICTORIA PORTERFIELD Account Number: 5488975025467864 Original Creditor: HSBC CARD SERVICES (III) INC Balance Due: $2,225.87 Our File No.: 249390 EXHIBIT "A" 249390 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiffs: Court Number: ARROW FINANCIAL SERVICES Expiration Date: LLC Type of Action: Civil Action Defendant/s: VICTORIA PORTERFIELD Serve Upon: VICTORIA PORTERFIELD Address for Service: 118 CONODOGUINET MOBILE EST NEWVILLE, PA 17241 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting Special Service Instructions: ** If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~.~uat~ oC ~umbrr~~A 4~FFI~E pF "!-E S~ERIFf ~... ~IL~ ~ (~'~--~t.~t ~.~ THE ~r r°, .;~,, ~~~T~.~Y Jody S Smith Chief Deputy Richard W Stewart Solicitor Arrow Financial Services LLC vs. Victoria Vee Porte~eld za~a~~ i4 ~ x:20 FFi~~vS`~`LVr,~Vl,~ Case Number 2010-3694 SHERIFF'S RETURN OF SERVICE 06/10/2010 08:49 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2010 at 2049 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Victoria Lee Porterfield, by making known unto herself personally, at 118 Conodoguinet Mobile Estate, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.80 June 11, 2010 ~7 DEN FRY, DEPU SO ANSWERS, RON R ANDERSON, SHERIFF (cj CountySuite Sheriff, Teleosoff, Inc.