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Home My WebLink About11-4005r 2104790 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 5996 W. Touhy Avenue, Niles, IL 60714 VS. c CD c - U- )r i N Cs f CD o rr, COURT OF COMMON PLEASE --+ D CUMBERLAND COUNTY f% - "- DOCKET NO. CHRISTINA BOWERS 663 MAGARO RD ENOLA PA 17025-1927 and CHRISTOPHER BOWERS 663 MAGARO RD ENOLA PA 17025-1927 NOTICE . ??.yDUS (%i l 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 as qP.M :d a 1? ? asemc, 1 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 2/14/11 in the amount of $2,729.98. 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. I 7. Defendant's last payment on account was made on 12/16/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,729.98 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: BERG, ESQUIRE FREDERIC I. OKESQUIRE JOEL M. FLI Attorney for Plaintiff P01P.DB 2104790 42245416 Arrow Financial Services, LLC CHRISTINA BOWERS andCHRISTOPHER BOWERS 6019180381070164 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. 0 A,? ?4- ? gz /NAME EXHIBIT "A" 2104790 ARROW FINANCIAL SERVICES, LLC CHRISTINA BOWERS and CHRISTOPHER BOWERS 6019180381070164 State of Illinois § § County of Cook § AFFIDAVIT I; G v " being 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 $1,938.62 plus interest of $737.46 at the rate of 24.75% less credits in the amount of $.00 totaling $2,676.08 as of 1/4/11. 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 and Subscribed befor a this day of 2011 Notary Public "OFFICIAL SEAL" Walterine McElroy Notary Public, State of Illinois f Comrnission Expires 1/3/2015 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 VS. CHRISTINA BOWERS and CHRISTOPHER BOWERS 99f?09OF ICE E THE PROTHONOTARY 2011 JUN 20 PM 1: 37 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2011-4005 PRRECIPE FOR ENTRY OF JUDGIMT FOR WANT OF AN ANSWER ASSESSNMT OF DADUMS, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) CHRISTINA BOWERS AND CHRISTOPHER BOWERS above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $1,938.62 Less: Payments on Account ( $.00) Total: $1,938.62 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 defendants, CHRISTINA BOWERS AND CHRISTOPHER BOWERS, 663 MAGARO RD, ENOLA PA 17025-1927. 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) service of the United States or the Soldiers and Sailors Civil years of age. is (are) not in the military otherwise within the coverage of Relief Act and is (are) over 18 %i4oo pd ak? AND NOW, this ? U day of "?U)A el , 2011 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer an dama es assessed at t sum of , $1,938.62 as per the above certifi atio Protho tar GORDON & WEINBERG, P. BY: FREDERIC W NBERG, ESQUIRE JOEL M. F I , ESQUIRE Attorney for Plaintiff 2104790 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. CHRISTINA BOWERS 663 MAGARO RD ENOLA PA 17025-1927 and CHRISTOPHER BOWERS 663 MAGARO RD ENOLA PA 17025-1927 DOCKET NO. : 2011-4005 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. /X/ Judgment by Default $1,938.62 Money Judgment $ f? 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 TELEPHONE NUMBER: 484/351-0500 PROTHONOTARY 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 2104790 ARROW FINANCIAL SERVICES LLC vs. CHRISTINA BOWERS and CHRISTOPHER BOWERS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2011-4005 NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA CHRISTINA BOWERS 663 MAGARO RD ENOLA PA 17025-1927 DATE OF NOTICE/FECHA DEL AVISO: May 27, 2011 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 AGA]NST 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: s' FREDERIC it, WEI ERG, ESQUIRE P10D-2 JOEL M. FLIP., ESQUIRE 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 2104790 ARROW FINANCIAL SERVICES LLC VS. CHRISTINA BOWERS and CHRISTOPHER BOWERS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO, : 2011-4005 NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA CHRISTOPHER BOWERS 663 MAGARO RD ENOLA PA 17025-1927 DATE OF NOTICE/FECHA DEL AVISO: May 27, 2011 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 EINBERG, ESQUIRE. P10D-2 JOEL M. F I K, ESQUIRE