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Home My WebLink About10-77660 Our File No.: 297402 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. DARRYL T HOWE 620 BOSLER AVE LEMOYNE, PA 17043-1936 Defendant. f 4L~~-U~~1~~ ~~R~l ~~~ ~ 7 ~~ ~~ ~~ ~:G~lBERI.At~R CO~JPd`~ ~' P~P~l~SY~.VA~lA COURT OF COMMON PLEAS CUMBER/LAND COUNTY NO.: ~U ' 770(1 ~/~/ 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 c~ ~~ ~ ~~~.G~ ~~ ~-o~~~r ~',~~ IOS~S' Our File No.: 297402 ' 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. DARRYL T HOWE 620 BOSLER AVE LEMOYNE, PA 17043-1936 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ARROW FINANCIAL SERVICES LLC, 5996 W TOUHY AVENUE, NILES, IL 60714. 2. Defendant(s) is/are DARRYL T HOWE, an adult individual residing at 620 BOSLER AVE LEMOYNE, PA 17043-1936. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account # ending in 4297; 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 $2,695.91. 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 $2,695.91 and requests this Court award costs to the extent pernutted by applicable law. APOTHAKER & ASS ATES, P.C. Attorney fo lai tiff A Law Firm Enaas in ebt Colle~~ BY: Dated: 12/8/2010 David J. Apotl~~cer, Esquire Our File No.: 297402 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 relating~o ~insworn falsification to authorities. David J. Apoth er, Esquire Attorney for 'ntiff DATE: 12/8/2010 ARROW FINANCIAL SERVICES LLC DARRYL T HOWE 620 BOSLER AVE LEMOYNE, PA 17043-1936 STATEMENT OF ACCOUNT Debtor's Name: DARRYL T HOWE Account Number: ending in 4297 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $2,695.91 Our File No.: 297402 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson iL 0 r F I C Sheriff ?l?! ' Th r ?$ti?rwta afi ??t? ?Jody S Smith,:, i ?S -- i Chief Deputy Richard W Stewart t"JJMBERLA?y c ou + l+ SOiICltOf E . <,. G 3IFF P I* t S { ir, i`c ?; Arrow Financial Services LLC Case Number vs. 2010-7766 Darryl T. Howe SHERIFF'S RETURN OF SERVICE 12/28/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he ade a diligent search and inquiry for the within named defendant to wit: Darryl T. Howe, but was unable t locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as tote defendant Darryl T. Howe. Request for service at 620 Bosler Avenue, Lemoyne, Pennsylvania 17043 the defendant was not found. Current resident of 620 Bosler Avenue, Lemoyne, Pennsylvania 17043 advi ed Deputies, Darryl T. Howe was the previous tenant. However, The Lemoyne Postmaster is delivering D rryl T. Howe's mail to 620 Bosler Avenue, Lemoyne, Pennsylvania 17043. SHERIFF COST: $47.40 SO ANSWERS, - 1?z December 28, 2010 R.ON R ANDERSON, SHERIFF f.ri Ccl y ja t(` S`c K