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Home My WebLink About10-3677' '~ t~ Our File No.: 249437 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. PATRICIA A ZEIDERS 4410 CHESTNUT ST CAMP HILL, PA 17011-4106 Defendant. ~~Il.~~~ ~;~ ~ ;rr, ;,. , P .. 1~l0 ,~U~ -~ P,~~ 1 ~ I 0 CiV'V'r • ~ v is rJ t.~i~ #~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: t ~ - 3!.'77 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. ~ Q~ . ~Q ~~ .~ r CARLISLE PA 17013 h~-hlf 717-249-3166 C ~ ! ~ 3 ~ ~Y~ ~~7 i ,.., Our File No.: 249437 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. PATRICIA A ZEIDERS 4410 CHESTNUT ST CAMP HILL, PA 17011-4106 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 PATRICIA A ZEIDERS, an adult individual residing at 4410 CHESTNUT ST CAMP HILL, PA 17011-4106. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account #5489555108903818; 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 $1,689.19. 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 $1,689.19 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS IATES, P.C. Attorney fo Pl 'tiff A Law Firm En~a~ in ht C;~llecti,e-5 BY: David J. Apothaker, Esquire Dated: 5/27/2010 Our File No.: 249437 VERIFICATION David J. Apothaker, 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 u~sworn falsification to authorities. David J. Ap< Attorney DATE: 5/27/2010 ARROW FINANCIAL SERVICES LLC PATRICIA A ZEIDERS 4410 CHESTNUT ST CAMP HILL, PA 17011-4106 STATEMENT OF ACCOUNT Debtor's Name: PATRICIA A ZEIDERS Account Number: 5489555108903818 Original Creditor: HSBC CARD SERVICES (III) INC Balance Due: $1,689.19 Our File No.: 249437 EXHIBIT "A" ' ~ 24943 7 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 Plaintiff/s: Court Number: ARROW FINANCIAL SERVICES Expiration Date: LLC Type of Action: Civil Action Defendants: PATRICIA A ZEIDERS Serve Upon: PATRICIA A ZEIDERS Address for Service: 4410 CHESTNUT ST CAMP HILL, PA 17011-4106 Alternate Address for Service: Type of Service: OPersonal (X) Adult in Charge ODeputize OCertified Mail OPosting 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 ~.°"'~~~~ ~~ Lu~rabrrif,~~~ ~; ;~. -; rr.;, . ~~~~"I xi-~'~E '7F ?H~ P, , r,~ ~t ~'"A?Y Jody S Smith Chief Deputy Richard W Stewart SOIICItOr r' ~ 4'' F T~ ::i'r' `L~i ~? `~ iE1 Arrow Financial Services LLC vs. Patricia A. Zeiders Case Number 2010-3677 SHERIFF'S RETURN OF SERVICE 06/07/2010 08:19 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2010 at 2017 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Patricia A. Zeiders, by making known unto herself personally, at 4410 Chestnut Street, 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. MICHELLE GUTSHALL, DEPUTY SHERIFF COST: $41.50 June 08, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ;c; Crnn^iySuite Sheriff. Teleosoft. Inr.. • Our file No.: 249437 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 307949 ARROW FINANCIAL SERVICES LLC Plaintiff, vs. PATRICIA A ZEIDERS Defendant. ~.- ~r ~ 2010 JU_ 1 ~ Air f ~ ~ ~ ,~ ~, M1 ,'`;~tdiY ~L I`l ~i~J~ ~ tV .~~ i ~~f'~. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-3677 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 June 09, 2010, STIPULATED by and between Plaintiff, ARROW FINANCIAL SERVICES LLC, and Defendant, PATRICIA A ZEIDERS parties as follows: 1. Defendant agrees to pay the sum of $1,881.19, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $1,881.19 shall be paid by the by Defendant, PATRICIA A ZEIDERS, to the attorneys for Plaintiff in the following manner: a. $471.00 to be paid on or before the 30th day of each month, beginning June 30, 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 Our file No.: 249437 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $1,881.19, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to PATRICIA A ZEIDERS by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attomevs for Plaintiff~'~ A Law FirnYEn~ed in By: J. Cavallaro, Esquire w A~ PATRICIA A ZEIDERS Our File No.: 249437 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. PATRICIA A ZEIDERS Defendant. s ~~M.~~°i~~=~"l~~r~r~~„ 1 t ~ ~ ~ ,~ p tn~ r, +. J ~i~~.. ~.. i ~4+'a~~d EJ"itl1 d nf~~~ !~~' - t A~ 1~~ ~ C ~ ,.. ._ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-3677 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys laintiff A Law Firm Ent d ' Debt Collection By: Dated: 10/22/2010 David J. Apocer, Esquire ~IIIIIIIIIIIIII