HomeMy WebLinkAbout10-5975THIS IS AN
ASSESSMENT
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
2085901
ARBITRATION MATTER.
OF DAMAGES HEARING REQUIRED.
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ARROW FINANCIAL SERVICES LLC
5996 W. Touhy Avenue,
Niles, IL 60714
VS.
ROBERT MATTESKY
3 ANTLER CT
SHIPPENSBURG PA 17257-9019
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 16 - S"4 L.>
NOTICE
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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 JUDGEMENT 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, 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 BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
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COMPLAINT IN CIVIL-ACTION
1. Plaintiff, ARROW FINANCIAL SERVICES LLC a debt buyer and
successor in interest to the original creditor, GE Money Bank.
2. At all times relevant hereto, the defendant (s) was the
holder of a credit card, which at the request of the defendant(s)
was issued to the defendant(s) by the original creditor under the
terms of which the original creditor agreed to extend to
defendant(s)tae use of original creditor's credit facilities.
3. Defendant (s) accepted and used the aforesaid credit card
so issued and by so doing agreed to perform the terms and
conditions prescribed by the original creditor for the use of said
credit card.
4. The defendant (s) received and accepted goods and merchand-
ise and/or accepted services or cash advances through the use of
the credit card issued by the original creditor. A true and
correct copy of the Statement of Account or Affidavit of Account,
if available, is attached hereto as Exhibit "A".
5. All the credits to which the defendant(s)is entitled have
been applied and there remains a balance due as of June 7, 2010 in
the amount of $6,238.41.
6. Plaintiff has made demand upon the defendant(s)for
payment of the balance due but the defendant(s)has failed and
refused and still refuses to pay the same or any part thereof.
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7. Defendant's last payment on account was made on
5/11/2008.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$6,238.41 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. NEIN ERG, ESQUIRE
JOEL M. FLIN QUIRE
Attorney for Plaintiff
POIP.DB
2085901
44193321
Arrow Financial Services, LLC
ROBERT MATTESKY
6019183008375784
VERIFICATION
I hereby state that I am the agent for the plaintiff herein, and that
the facts set forth in the attached Affidavit which is incorporated by
reference in the foregoing Complaint in Civil Action are true and correct
to the best of my knowledge, information and belief and is based upon
information which plaintiff has furnished to counsel. The language in the
Complaint is that of counsel and not of plaintiff. To the extent that the
contents of the Complaint are that of counsel, plaintiff has relied upon
counsel in making this verification. This verification is made subject to
18 Pa.C.S. §4904 which provides for certain penalties for making false
statements.
NAME
EXHIBIT "A"
2085901
ARROW FINANCIAL SERVICES, LLC
ROBERT MATTESKY
6019183008375784
State of Illinois §
County of Cook §
AFFIDAVIT
Z/WbeinS duly served sworn according to law, depose and say
that:
1. I am employed as the legal outsourcing clerk for the Plaintiff herein
and I have custody and control of the files relating to this account;
2. I have personal knowledge of the facts and circumstances in connection
with this case and base this affidavit on Plaintiff's records, as well as the
account information provided to Plaintiff by GE Money Bank when GE Money Bank sold
the
account to Arrow Financial Services, LLC.
3. Plaintiff's files are maintained in the usual and ordinary course of
business;
4. This action is based on a claim for breach of contract and that
damages are sought as a direct result of said breach;
5. There is now due and owing from defendant to plaintiff, the amount of
$4,951.32 plus interest of $1,105.79 at the rate of 24.75% less credits in the amount of
$.00 totaling $6,057.11 as of April 14, 2010.
6. If called upon, affiant can testify at trial as to the facts
pertaining to this matter.
The above facts are true and correct to the best of my knowledge,
information and belief.
AFFIANT
Sworn to aY-1, ibed
Z
bef a me this day
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Nr!,--;y Public, State of Illinois
(;;,mrriission Expires 113/2011
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson CI°
Sheriff `;"`1
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Jody S Smith ???,?cr of t?urt?brrr?a h ?-
Chief Deputy 7 r3!? 3:
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Richard W Stewart'
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Solicitor ° ?.^°,!'•...Ij .s?...t!pr,,R1.! t?,
Arrow Financial Services LLC
Case Number
vs.
Robert Mattesky 2010-5975
SHERIFF'S RETURN OF SERVICE
09/23/2010 02:24 PM - Jody Smith, Chief Deputy, who being duly sworn according to law, states that on September
23, 2010 at 1424 hours, she served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Robert Mattesky, by making known unto himself personally, at The Cumberland County
Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its
contents and at the same time handing to him personally the said true and correct copy of the same.
y
JO Y S. S H, DEPUTY
SHERIFF COST: $46.00
September 23, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
±ej CountYSuite Sheriff. Teleosoft. Inc.
2085901
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GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 81894
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS
CUMBERLAND COUNTY -,
VS. DOCKET NO. 10-5975 .' - `Y-
ROBERT MATTESKY
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PRAECIPE FOR ENTRY OF JWGUEN T FOR NUT OF AN AXIMM ASSESS? NT _.;
OF DAMK=S, MUFICATION OF ADDRE88 AND NON-MILITARY SERVICE
TO THE PROTHONOTARY:
Enter judgment for want of an answer for plaintiff and
against defendant(s) above named only and assess damages
certified to be calculable as a sum certain from the complaint,
as follows:
Principal $6,238.41
Less: Payments on Account ( $.00)
Total: $6,238.41
Understanding the false statements made herein are subject to
penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to
Authorities, I verify that:
1. The last known addresses of the parties are: ARROW
FINANCIAL SERVICES LLC and that the last known address of
defendant, ROBERT MATTESKY, 3 ANTLER CT, SHIPPENSBURG PA 17257-9019.
2. The annexed notice(s) of intention to file this
praecipe was (were) mailed to all parties, defendant and to their
record attorneys, if any, after default occurred, and at least
ten days prior to the date of filing of this praecipe.
3. The said defendant(s) is (are) not in the military
service of the United States or otherwise within the coverage of
the Soldiers and Sailors Civil Relief Act and is (are) over 18
years of age.
AND NOW, this day of 2010 Judgment
is entered in favor of the plaintiff(s) and against defendant(s) by
default for want of an answer and damages assessed at the sum of ,
$6,238.41 as per the ab e certi ica 'on.
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P othonotary
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GORDON & WEI ERG P.C.
BY:
FREDERIC I INBERG, ESQUIRE
JOEL M. FL K, ESQUIRE
Attorney for Plaintiff
2085901
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
ARROW FINANCIAL SERVICES LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
ROBERT MATTESKY
3 ANTLER CT
SHIPPENSBURG PA 17257-9019
DOCKET NO. : 10-5975
NOTICE
Pursuant to Pa.R.Civ.P. 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.
LXL Judgment by Default $6,238.41
, lla u Money Judgment $
Judgment on Award of Arbitrators$
Judgment on Verdict$
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL
ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS
TF7,RPTOMP NTTMRFR: 4A4/351-0500
2085901
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
ARROW FINANCIAL SERVICES LLC COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS. DOCKET NO. : 10-5975
ROBERT MATTESKY
NOTICE OF INTENTION TO TAKE DEFAULT
TO/PARA
ROBERT MATTESKY
3 ANTLER CT
SHIPPENSBURG PA 17257-9019
DATE OF NOTICE/FECHA DEL AVISO: October 14, 2010
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY AN 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 BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. INBERG, ESQUIRE
JOEL M. F NK, ESQUIRE
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2085901
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
HE Pf OTHON0- T ,#t
2*2 JUL 13 Amin:
CUMBERLAND COUNTY
PENNSYLVANIA
ARROW FINANCIAL SERVICES LLC
VS.
ROBERT MATTESKY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 10-5975
ORDER TO SATISFY JUDGME&NT
TO THE PROTHONOTARY:
Kindly mark the judgment entered November 15, 2010 in the
above-captioned matter satisfied upon payment of your costs on15
GORDON & WEINBERG, P.C:
BY:
FREDERIC-1. WEINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
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