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Home My WebLink About06-0441 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lonnie E. Snyder Plaintiff : No. 0/..,. - 4'-1 f C~ulL'--r~ vs. : Civil Action - Law Twigg Cycles Inc. And Arrow Financial Services Defendants 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 WRmEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRmNG 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 ANY OTHER CLAIM FOR 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA (717) 249-3166 (~~~~J H. ANTHONY ADAMS ATTORNEY AT LAW SUPREME COURT ID NO. 25502 49 WEST ORANGE STREET, SUITE 3 SHIPPENSBURG, PA 17257 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lonnie E. Snyder : No. Ol... - t.;t./ J Clu~l '-r~ Plaintiff vs. : Civil Action - Law Twigg Cycles Inc. And Arrow Financial Services Defendants COMPLAINT AND now, comes the Plaintiff, Lonnie E. Snyder, by and through his attorney, H. Anthony Adams and states the following cause of action and in support thereof avers as follows: 1. The Plaintiff is Lonnie E. Snyder, an adult individual who resides at 54 Walnut Dale Road, Cumberland County, Shippensburg, Pennsylvania, 17257. 2. Defendant is Twigg Cycles, Inc. a corporation with an address of 200 South Edgewood Drive, Hagerstown, Maryland 21740 3. Defendant is Arrow Financial Services through its agent, HSBC Retail Services with an address of P.O. Box 4144. Carol Stream, IL 60197. The payment agent of Twigg Cycle was HRS USA, P.O. Box 703, Wood Dale, IL 60191 4. On or about June 5, 2000, the Plaintiff purchased a used ATV from the Defendant, Twigg Cycles, Inc. for the total amount of $3,927.50. 5. At the time of the purchase, Plaintiff paid to Defendant Twigg Cycles, Inc. the amount of $600.00 as down payment and financed the amount of $3,327.50. 6. The financing arrangements were made through Twigg Cycles, Inc. and payments were to be made to HRS USA, P.O. Box 703, Wood Dale, IL 60191 7. Plaintiff has made payments to Defendants since July 2000 and has paid a total amount believed to be approximately $5,670.00. 8. Defendant HSBC and Arrow Financial Service has declared an amount of $3,753.77 is due and owing to them. 9. The charges and interest applied to the account are usurious, 10. The acts of the Defendants are in violation of the usury laws of the Commonwealth of Pennsylvania and violate the Consumer Protection Laws. 11. Plaintiff requests damages as set forth in the aforementioned statutes together with costs of suit and legal fees. . WHEREFORE, Plaintiff prays your Honorable Court enter judgment in his favor and against Defendants. Respectfully submitted, ~~) H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532- 3270 Dated: Ic;tIDc( !t;,5 I VERIFICATION We verify that the statements made in this Complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: /..$-~" . ~.~....' e -iY~/~<J C n ie E. SnYd~ ~ ~ \:) trt \t- \ ~ Ul \) ~ t: ~ - - ~ ~ -g~ , (-~ ;:.. -, . - !'>,", 00 .'.,\ .' - :, .1""-" ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lonnie E. Snyder Plaintiff vs. Twigg Cycles Inc. And Arrow Financial Services Defendants No. 06 - 441 Civil Term Civil Action -Law STATEMENT OF INTENTION TO PROCEED To the Court: Now, comes the Plaintiff, Lonnie E. Snyder, by and through his attorney, H. Anthony Adams and states that he intends to proceed with the above captioned matter. Respectfully submitted, ~~ H. Anthony Adams, Esquire Attorney for Plaintiff Supreme Court # 25502 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Dated: ~ F{Lr~ -~; ~=iCE t~~ ?F?r ~'~t ~~T'..,.,~~T~RY 1~~~ Sri 2 ~ ~6-~ 2~ f, ,rv ,_ ;, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lonnie E. Snyder Plaintiff vs. Twigg Cycles Inc. And Arrow Financial Services Defendants No. 06-441 Civil Term Civil Action -Law PRAECIPE TO THE PROTHONOTARY: Please dismiss this action. Respectfully, Date: ~ (d H. Ant ony Adams, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 Attorney ID No. 25502 (717)532-3270 ~ ~~ ~n~ p~ ray 3' ~ `~