HomeMy WebLinkAbout10-78402071037
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING REQUIRED.
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
6108 W Touhy Ave,
Niles IL 60714
VS.
SUSAN MUNSHOWER
19 LONGSTREET DR
Carlisle PA 17013
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
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NOTICE c- =r
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)the 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
merchandise 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 November
12, 2010 in the amount of $4,473.05.
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.
7. Defendant's last payment on account was made on
9/19/2007.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$4,473.05 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BERG, ESQUIRE
SQUIRE
Attorney for Plaintiff
BY: _
FREDERIC EIN
JOEL M. F IN E
P01P. DB
EXHIBIT "A"
2071037
41651895
Arrow Financial. Services , LLC
SvSM MUNsISowEn
6019180224066874
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, plain ff has relied upon
counsel in making this verification. This verifica ion s made subject to
18 Pa.C.S. 54904 which provides for certain penalt as or making false
statements.
2071037
ARROW FINANCIAL SERVICES, LLC
SUSAN W"SHOW"
State of Illinois §
County of Cook §
AFFIDAVIT
being duly served sworn according to law, depose and say
that:
1. I am employed as the legal outsourcing cleric for this 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 ca mousy DAUX when sN MONZY 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 plaiatt the amou t of
42,634.70 plus interest of $2,155.69 at the rate of 24.758 Yes. redit. In t e amoaint of
4.00 totaling $3,790.59 as of October 26, 2009.
6. If called upon, affiant can testify at trial a to the
pertaining to this matter.
The above facts are true/nd orrec best of Jinformation and belief. (
I "OFFICE AL"
z 1ne Yotinan
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{ Notary Public, Sla'.e of Nlinois
2 Commission Expires 4P2912012
Sworn to and Subscribed
before me this day
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
FILED -OFF IU-
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?S ID DFC 3D PM I : r, r MBE LA D C0jjN -V
PENMSYL V#" M'i
Arrow Financial Services LLC
VS. Case Number
Susan Munshower 2010-7840
SHERIFF'S RETURN OF SERVICE
12/27/2010 07:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December
27, 2010 at 1925 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Susan Munshower, by making known unto William Clee, Son of defendant at 19
Longstreet Drive, 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.
s
RO RT BITNER, DEPUTY
SHERIFF COST: $33.40
December 28, 2010
SO ANSWERS,
RONWY R ANDERSON, SHERIFF
Davila). Buell -
Prothonotary
Office of the Prothonotary
Cum6errand[County, Pennsylvania
xyrkS. Sohonage, ESQ,
Solicitor
to -1E310 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 I phone 717 240-6195 0 'Fax 717 240-6573