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Home My WebLink About10-7777Our File No.: 297339 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. PATRICIA JONES 34 PINE HILL AVE MECHANICSBURG, PA 17050 Defendant. FILED-C~~lC~ ~,b T~F PRUT~~~-tt~T~~ ~ ~' 2~ ~ 0 DEC 17 P~f 3: } ~:(s~9~F~LAt~D Cd:~tl~~'T`' ~~.~~N5YL~!A~'~;~. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOTICE ~IVI~ 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 ~~~ 1~~~~ ~~~~~~ Our File No.: 297339 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. PATRICIA JONES 34 PINE HILL AVE MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: l~~ `~ ~~~ ~ ~ ~~~ ~ CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ARROW FINANCIAL SERVICES LLC, 5996 W TOUHY AVENUE, NILES, IL 60714 2. Defendant(s) is/are PATRICIA JONES, an adult individual residing at 34 PINE HILL AVE MECHANICSBURG, PA 17050. 3. Plaintiff, ARROW FINANCIAL SERVICES LLC, is the Assignee and Successor in Interest of Account # ending in 8067; 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 $1,271.42. 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 $1,271.42 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER SSOCIATES, P.C. Atto ey or Plaintiff A Law Firm E ~a ed in Debt,Eollectio~ BY: Dated: 12/8/2010 David J. Xpothaker, Esquire Our File No.: 297339 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 made subject to the penalties of 18 Pa.C.S.A. 4904 understands that the statements therein are unsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 12/8/2010 ARROW FINANCIAL SERVICES LLC PATRICIA JONES 34 PINE HILL AVE MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: PATRICIA JONES Account Number: ending in 8067 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $1,271.42 Our File No.: 297339 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F11.Ep_pFFtCOJ AR`{ sheriff ?F ?N? pRp-?Hpp Jody S Smith Chief Deputy to D(', 29 Richard W Stewart gERLP?p C?uP Solicitor p?jjlg5?0p, Arrow Financial Services LLC vs. Patricia Jones Case Number 2010-7777 SHERIFF'S RETURN OF SERVICE 12/22/2010 08:00 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 22, 2010 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Patricia Jones, by making known unto her if per ally, at 34 Pine Hill Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17050 its c ndn nts a d t the same time handing to her personally the said true and correct copy of the same. .I SHERIFF COST: $37.00 December 27, 2010 SHf MN HARfa9N!CEPUTY SO ANSWERS, / RON R ANDERSON, SHERIFF Our File No.: 297339 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 L '-OF FIC F T' "; i s 1 I FEB 18 PM 12: 27 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. NO. 10-7777 CIVIL PATRICIA JONES Defendant PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A Law Firm By: David J. Apothaker, Esquire SO IATES, P.C. for aintiff ed ' Debt Collectioi Dated: 2/11/2011 ?on?ini?nir?