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Home My WebLink About08-4770Ourf Ne No.: 138037 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. DONALD ZEEK 688 BRITTON RD SHIPPENSBURG, PA 17257-9522 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08 - 41'170 (""i t-Fersk 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 APOITHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. DONALD ZEEK 688 BRITTON RD SHIPPENSBURG, PA 17257-9522 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Of-y77n CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are DONALD ZEEK, an adult individual residing at 688 BRITTON RD SHIPPENSBURG, PA 17257-9522. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #4031150800491951; and said account was issued to Defendant(s) by PROVIDIAN NATIONAL 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 $3,793.23. 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. ` ' f * WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,793.23 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & SS CIATES, P.C. AttornI for Plaintiff A Law Firm En Zed ' Debt Collection BY: Dated: 7/30/2008 Our File No.: 138037 A a VERIFICATION Tiffany Ross hereby states that I am Legal Specialist 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 to unworn falsification to authorities. Plainti DATE: 1 a PORTFOLIO RECOVERY ASSOCIATES, LLC DONALD ZEEK 688 BRITTON RD SHIPPENSBURG, PA 17257-9522 STATEMENT OF ACCOUNT Debtor's Name: DONALD ZEEK Account Number: 4031150800491951 Original Creditor: PROVIDIAN NATIONAL BANK Balance Due: $3,793.23 Our File No.: 138037 EXHIBIT "A" [? N rn 4.J rv -? 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-04770 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS ZEEK DONALD MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE' was served upon ZEEK DONALD the DEFENDANT , at 0018:23 HOURS, on the 12th day of August , 2008 at 688 BRITTON RD SHIPPENSBURG, PA 17257-9522 by handing to DONALD ZEEK DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service Affidavit ? q'?IpS 18.00 22.00 .00 Surcharge 10.00 R. Thomas Kline .00 50.00 08/113/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. APP6 4& Our File No.: 138037 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 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, vs. DONALD ZEEK Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-4770 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Pl?mtiff A Law Firm EngagedA Dkbt Collection By: David J. ApdthWeer, Esquire Dated: November 13, 2009 ALEa-?O Fr ICE ,q}- rr Pr.T' rn l TliFl l 2009 NOV 24 AN 9: 20 ^+y, - ,} It ?J? ?I?Fn