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Home My WebLink About10-4647r ? > Our File No.: 263858 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. SONIA L LETTKO 2 MARSHALL DR APT K CAMP HILL, PA 17011 Defendant. F1 2010 JUL 14 '3: 4 GUPv _, ?i RY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10-4641 o'-wererm 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 Q -+9x.00 P0 A7Y1 at 188913 2* aq saa9 r t Our File No.: 263858 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. SONIA L LETTKO 2 MARSHALL DR APT K CAMP HILL, PA 17011 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 SONIA L LETTKO, an adult individual residing at 2 MARSHALL DR APT K CAMP HILL, PA 17011. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account # ending in 8614; 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 $4,014.21. 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". s , 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 $4,014.21 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & S IATES, P.C. Attorney for P aintiff A Law Firm Engaged ' Debt ollection BY: David J. Apot er, Esquire Dated: 7/7/2010 Our File No.: 263858 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 relatin M unworn falsification to authorities. David J. *othaker, Esquire AttorneWor Plaintiff DATE: 7/7/2010 ARROW FINANCIAL SERVICES LLC SONIA L LETTKO 2 MARSHALL DR APT K CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: SONIA L LETTKO Account Number: ending in 8614 Original Creditor: HSBC CARD SERVICES (III) INC Balance Due: $4,014.21 Our File No.: 263858 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~L~ Sheriff ,- , . ~~~,~,tp of ~ ~; mbr~ra ~ - T, . ~,,,, ., Jody S Smith ~ ~, , Chief Deputy 4 ~ L Q i ~ ~, ` ~, - ~:; ~-'` i ~ j : L ', f ~ '~y3 ~ ~?'o Richard W Stewart •`'j~ A'UCr y ~m l'•dI Solicitor Q~wce _ F TNT s~sR~fR ~~'P :; _ '_ ~ ~ s 3' t' i ~~'j°(_1, Arrow Financial Services LLC Case Number vs. 2010-4647 Sonia L. Lettko SHERIFF'S RETURN OF SERVICE 07/30/2010 05:03 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 30, 2010 at 1703 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sonia L. Lettko, by making known unto Farouk Sakr, adult in charge at 2 Marshall Drive, Apartment K-12, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. AM NDA CO AUG ,DEPUTY SHERIFF COST: $41.50 August 03, 2010 SO ANSWERS, ~d~ ~-~,. RON R ANDERSON, SHERIFF lc) CountySuite Sheriff. Teleosoft, Inc. Our File No.: 263858 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 vs. Plaintiff SONIA L LETTKO Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, SONIA L LETTKO, in the default of an Answer, in the amount of $4,014.21 computed as follows: Amount claimed in complaint: $ 4,014.21 Less: Amount Paid: ( 0.00) Plus: Interest from July 7, 2010 to September 7, 2010 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL $ 4,014.21 I certify that Defendant, SONIA L LETTKO, t kn 7?s s i s 2 MARSHALL DR APT K CAMP HILL, PA 17011. David J. Apot `la cer, Esq. Attorney for Plaintiff Dated: September 7, 2010 CIE* /S?S0'r Z-44- .a y8qab A-Witf- '*Vza(LL L410 SAP i ? P? 3? ?6 rCOUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-4647-CIVIL TERM Our File No.: 263858 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff SONIA L LETTKO Defendant VS. NO.: 10-4647-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 Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the 8 Pa.C.S.A. §4904, relating to that false statements herein are made subject to the penalties unsworn falsification to authorities. David J. Apothaker I Attorney for Plaintiff Dated: September 7, 2010 a Our File No.: 263858 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. SONIA L LETTKO Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-4647-CIVIL TERM . 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 2 MARSHALL DR APT K CAMP HILL, PA 17011. We inquired with the web site of the Defense Mz Wilson Boulevard, Suite 400, Arlington, VA 22209-25 branch of the military. Mary M. Snavely-Dixon, Director of the Defei our inquiry indicated that the Defendant(s) is/are not in David J. Apot er, Esq. Attorney for Plaintiff r Data Center, located at 1600 the Defendant(s) is/are in any Center has sent back I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. I3epabma t of D&nst 4farpovarer Data Center Sur-a^-20I0 Ia_3.41 MAt-1 Stab. Report Ptesuart to the Smite _iernbers Civi R64Act Last FirtrdAii & NAM* $ftte Date Aeries Dtttr Mates AMY* Doty E*d Date Semce LETTKO SONIA L Based the ieformattion you her fen stied, for DL D(: dens sax 1x >ses, erns iafor:wibon indicating the indhidual status, Lpon mi rd ing the idotuaatioti data banks of tit Daepart uttt of Ddtew olatpowrf Dua Ctaw based on the xiorms6w dw you provided, the abcr e is the r rmw states of the ire iduai alto all branehes ofthe Ue orwed Services (Ara:y, Naxy, kfariw Carps, Air Force. NO.AA, Public He> ih, sue Coast Guard). Nfwy -i1 Sna efv-Dam, Dwector Dtpa tnent cl Defense - Man" rr Data Center 1646 &i1sm RI%-4, Suite 4413 Atfi4on, VA 32209-2593 The Defeusc Manpower Dam Cater PNVDC) is an organizmaa ofthe Dtparlnvent ofDefense than maintaws the Definse Enrt and EiOW Reporting Spstcm (DEERS) database which is the e&cof source of data an eighty for >a>kary meccal care and oiler ek*Al ty systems The DoD strongly supports the afoxcusnrm of for Sm a Members Cirri RAdAzt (5USC App. 3§ 501 et sett' as amrnded3 (`SCRA) (€urmerly known as the Sok&rs' and Sakrs' CM Rdt Act of 1940). DhlDC has issued hwde& ofdwU3a03ds of 'dxs to pown Say wfwmtmom wdicatiog done die it 4 ideal is cmTe* m actin a dun °' tr€pomes. and khan es menaced a error rate. In the esmat the astfn hW refirenced abwe, o any faenuim inember; fiiend, or rep esmawr asserts in any manner duug ear the nttiridusl s on acwr dui, or n Odenxist entitled t6 the protections of dw SCRs, you air strongly encouraged tD ObLIM firdw vw 6ca0oa of the pdrsot s stains by caaucwg drat persona s Sovkt via the'<Weasekk wf 4: ZL IrEm sanely defrasckinkfaayis PCOaSLR If petsgra is on acsv2 sbrt5 and you rag to obfais tits htu,. s ou have evi k c the adduonalService xTmTwatim prraienxprovisiow oftbe SCRAmar-beivwkedagainst you. See 50 nCApp, §531(c} If Vonn obtain additiotw ilr f"w-atim abotat tae person (e g., an SSN, it ov ed accuracy of DOB1 a Puddle, aawc); y cm ears R ibrm )vw request agan at das Web sit- and we vA gumiAc a new carfficatr fnr that query, phis respome redectsactive defy starts ' tutludiug cats the iadvidtsal was least oa active Butt, ffa was Aithia the preceding 36" dogs. For historical i&nnamM please contact dw Sesice SCRA paints-r- comtacr More infonh tan on Active Derr Slow' Active duty stain as reported is this catfficae is defined it accordance with 10 U SC § 101 01) for is period of more dwn 30 consecutive days. In the case of a m tuber of die Na" Guard, intirmies service under a cal to active ser%ce antbcmed by the Prrsidcnt er the $e"etarv ofDdrue tot a period o(vior'r that 30 eoweWntt &ys mdrr 3Z USC ¢ 5020) for putposes of respond* to a motional amnency declared by the President and supported by Federal funds Al Active Guard ResenT (AGR} umbers esnt be kmgaed atgaiirist an asst wwrd poskim in the emit they support- Ths mxkKks Navy TARS, :'Barone Corps ARs aid Coat Guard RPAs Acting Duty status also applies to a Vato sad Senice nxvk t %to is an active date carsassiss>atsed officer Oder U S Prsblic Hes3h Service or the N Ocra k and AbnogAeris Admix istratiors ('OAA Caunessicecd Carps) for apemdcfmxc don 30 consecutive dams Cove7lw Cider the SCR A is'arwadr r in .Sortaur Cal" Cav-rage undis the SCRA is broader is some cases and wi3des some categories of person an active cht. for purposes ot the S MA unto would riot be reported as on Acts- Due older this certificate. Marrj' tmxs orders am a ae>ded to rSLrnd de pciod oft,-r duty, whwh,%vdd =dead SCRA protectiom. Persons seeking to MY on this websi'tc certification should check t4 make sate the orders on which SCRA protections we based have not been ceded to Mead dte ioduave dates of nice. Furlhetmuse, some protectiuw of the SCRA may intend to persons who have trceiv,ed orders to report far ednx duty cc to be inducted, but who have not acw* btg m actk a duty or act aky reparicd for mdachon. The Iasi Date on Actin a Duty entry is irwortant becans e a number of ptotecbms of SCRA extend be-.nod flit last dates of active dura ThDsr tvhio would rdy ran. firs certdieare we urged to seek qua5bed legal weasel to etsstar that at rights guaranteed to Smict mwbrs undtt dte SCPLA are protected WARNNG 31is certificate was provided based on a nano and SSN prnvidcd by the requester_ Frrtni[ an evromeers name eta SSN wig carts.- an emoeean certificate to be provided. Report 11T2EMAID 7V 263858 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ARROW FINANCIAL SERVICES LLC } COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) SONIA L LETTKO ) NO. 10-4647-CIVIL TERM To: SONIA L LETTKO 2 MARSHALL DR APT K CAMP HILL, PA 17011 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 BAR - - ?7 - DAVID J. APO HA 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 438423 Date: August 23, 2010 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: SONIA L LETTKO 2 MARSHALL DR APT K CAMP HILL, PA 17011 ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. SONIA L LETTKO NO.: 10-4647-CIVIL TERM Civil Action Defendant 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. Apothaker, Esq. at this telephone number: 800-672-0215 9 i7/1o