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Home My WebLink About10-4529Our File No.: 248643 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. RAYMOND FAHNESTOCK 424 REAR S BALTIMORE AVE MOUNT HOLLY SPRINGS, PA 17065 Defendant. F ?r t t ITtfp,f 2313 J'11?- -0 it COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - '45220 ??v lT?erv1 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 p 4gd.oo Pa Aby ON III 14l? of ayyRy6 Our File No.: 248643 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. RAYMOND FAHNESTOCK 424 REAR S BALTIMORE AVE MOUNT HOLLY SPRINGS, PA 17065 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 RAYMOND FAHNESTOCK, an adult individual residing at 424 REAR S BALTIMORE AVE MOUNT HOLLY SPRINGS, PA 17065. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account # ending in 0369; and said account was issued to Defendant(s) by HSBC BANK NEVADA N.A., 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 $2,986.72. 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 $2,986.72 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for P aint f A Law Firm Enaaaed n De t Collectioi BY: David J. Dated: 7/1/2010 Our File No.: 248643 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 relatingA unworn falsification to authorities. David J. A h ,Esquire Attorne for Plaintiff DATE: 7/1/2010 ARROW FINANCIAL SERVICES LLC RAYMOND FAHNESTOCK 424 REAR S BALTIMORE AVE MOUNT HOLLY SPRINGS, PA 17065 STATEMENT OF ACCOUNT Debtor's Name: RAYMOND FAHNESTOCK Account Number: ending in 0369 Original Creditor: HSBC BANK NEVADA N.A. Balance Due: $2,986.72 Our File No.: 248643 EXHIBIT "A" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOIICItOr SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~z ~_f ~~ f ~. j, ~. ~Jftj l:4 .: 'r ~ I~af 4.M~ ~~ gat ~,`~; ~ - ~p~p PrUG 1 l ~M 2 ~ 37 ~E ,.a~ .: ~ ( . '~!FFfC~E~F Ti~E S!*ERIFF ~ ~ .. _ rl. ~.__ - Arrow Financial Services LLC Case Number vs. 2010-4529 Raymond Fahnestock SHE~tIFF'S RETURN OF SERVICE 08/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 9, 2010 at 1050 hours, he was unable to serve!a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Raymond Fahnestock. After several attempts the Complaint and Notice has expired. SHERIFF COST: $40.60 August 09, 2010 SO ANSWERS, ///~J/fj/J~ RON RAf }N kDER~SON, SHERIFF (c) CountySuite Sheriff, TeleosoR. Inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY -HE 2011 DEC 16 AM IC:' CUMBERLA10 i;UW'<47 ' alt :.?PENNSYLVANIa Arrow Financial Services LLC Case Number vs. 2010-4529 Raymond D. Fahnestock SHERIFF'S RETURN OF SERVICE 12/14/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on December 14, 2011 at 1205 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Raymond D. Fahnestock. After several attempts the Complaint and Notice has expired. SHERIFF COST: $42.00 SO ANSWERS, December 14, 2011 RON R ANDERSON, SHERIFF cj Gouni,SuRP SW ff. T010SOft. Irr. Our File No.: 248643 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 vs. Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY RAYMOND FAHNESTOCK Defendant NO. 10-4529 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER ,Y/AS?OCIATES, P.C. A Law Firm En aged Debt Collection By. `David J. Apothaker, Esquire Dated: 4/9/2012 Fri