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Home My WebLink About10-7765Our File No.: 297343 APOTHAKER & ASSOCIAT$S, 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. CLARENCE L BAUM 122 W NORTH ST #B CARLISLE, PA 17013-2317 Defendant. C~~ T#iE ~PTI~c~,~~~t~`~' Zt' ~ ~ DEC ! ~ P3~ ,~~ i~ "~'M~ERLAP~~ C~UT~' ~Et~,~~`(± ~~AP~t~ COURT OF COMMON PLEAS CUMBERLAND COUNTY 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 ~~" 9~_ ~ 717-249-3166 ~,~ lG 573 ~~y ~~~~. Our File No.: 297343 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. CLARENCE L BAUM 122 W NORTH ST #B CARLISLE, PA 17013-2317 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ~6~ `~7~5 ~,~~ ~ CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ARROW FINANCIAL SERVICES LLC, 5996 W TOUHY AVENUE, NILES, IL 60714 2. Defendant(s) is/are CLARENCE L BAUM, an adult individual residing at 122 W NORTH ST #B CARLISLE, PA 17013-2317. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account # ending in 9662; and said account was issued to Defendant(s) by WASHINGTON MUTUAL BANK, 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 $1,764.07. 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 $1,764.07 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & SSO IATES, P.C. Attorney or Pl ntiff A Law Firm Enna din ebt Colle~ BY: Dated: 12/8/2010 David J. Apothal~-Esquire Our File No.: 297343 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. made subject to the penalties of 18 Pa.C.S.A. 4904 undersigned understands that the statements therein are to unsworn falsification to authorities. David J. ~thaker, Esquire Attorney for Plaintiff DATE: 12/8/2010 ARROW FINANCIAL SERVICES LLC CLARENCE L BAUM 122 W NORTH ST #B CARLISLE, PA 17013-2317 STATEMENT OF ACCOUNT Debtor's Name: CLARENCE L BAUM Account Number: ending in 9662 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,764.07 Our File No.: 297343 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor FILED-OFFICE i 70110 DF.C 28 P8 3: 54 '-AMBERLAND COUlKl ;' PENNSYLVANIA Arrow Financial Services Case Number VS. Clarence L. Baum 2010-7765 SHERIFF'S RETURN OF SERVICE 12/21/2010 04:16 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law states that on December 21, 2010 at 1616 hours, he served a true copy of the within Complaint n Notice, upon the within named defendant, to wit: Clarence L. Baum, by making known u o Amb Ha maker, adult in charge at 122 W. North Street #B, Carlisle, Cumberland County, Pen s vania 701 its contents and at the same time handing to her personally the said true and correct coy f ame. r ? / f ,DEPUTY SHERIFF COST: $33.40 December 22, 2010 SO ANSWERS, RON ? R ANDERSON, SHERIFF c?. CamtySuite 5hprifj, 7212ot3 ft h ;; Our file No.: 297343 Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FILED-OFFICE OF THE PROTHONOTARY 2011 J "I l 1 3: 43 r t CUMB-cE 'UNTY P'? A t! f ARROW FINANCIAL SERVICES LLC Plaintiff, VS. CLARENCE L BAUM Defendant. COURT OF COMMONS PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-7765 CIVIL 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 January 06, 2011, STIPULATED by and between ARROW FINANCIAL SERVICES LLC ("Plaintiff') and CLARENCE L BAUM ("Defendant"), as follows: 1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of $1,764.07. 2. Defendant agrees to pay to Plaintiff the sum of $1,764.07, which sum Plaintiff agrees to accept in full settlement of its claim herein. 3. As of this date, payments totaling $0.00 have been applied to the aforementioned sum. 4. Defendant shall remit payment(s) in the following manner: a. $17.00 to be paid on or before January 15, 2011; b. $25.00 to be paid on or before the 15th day of each month, beginning February 15, 2011 until paid in full. 5. All checks shall be made payable to "ARROW FINANCIAL SERVICES LLC", and sent to the office of Plaintiff's attorney, Apothaker & Associates, P.C., located at the following address: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 1 y r- 6. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation and the default is not cured within ten (10) days, then Plaintiff shall be entitled to obtain the entry of Judgment against Defendant in the suit amount specified in paragraph one (1) of this stipulation less any sums paid pursuant to this Stipulation, upon ex parte application, with supporting certification, and with notice to Defendant in the form of a copy of the application addressed to Defendant by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. By: /Of°0 L!? lenjatyffn Cavallaro, Esquire Atto ey ID# 307949 Apothaker & Associates, P.C. Attorneys for Plaintiff By: - - - p. CLARENCE L BAUM Defendant 2 David -D. Buell Prothonotary Office of the Prothonotary Cum6erfancfCounty, Pennsylvania 2�yrkS. Sofionage, ESQ Solicitor �0 -'771s CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, TA •1�P-hone 717 240-6195 • Fax 717 240-6573