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Home My WebLink About09-2717 Our File No.: 204520 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 . 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FIA CARD SERVICES, N.A. c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. RONALD R ZERANCE 1027 SWARTHMORE RD NEW CUMBERLAND, PA 17070-1730 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. da -,,171'7 l?vi l IG '? 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 Our File No.: 204520 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 . 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FIA CARD SERVICES, N.A. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. RONALD R ZERANCE 1027 SWARTHMORE RD NEW CUMBERLAND, PA 17070-1730 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 4- 2 '1 / 7 CtW 1 ?e w, CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A. c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are RONALD R ZERANCE, an adult individual residing at 1027 SWARTHMORE RD NEW CUMBERLAND, PA 17070-1730. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4264298996067370. 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 $6,913.77. 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. 46 WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $6,913.77 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney,fq Plaintiff A Law Firm Ens a in Debt Collectioi BY: David J. Aaker, Esquire Dated: 4/23/2009 Our File No.: 204520 VERIFICATION David J. Auothaker, Esquire, Esc 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 undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S A4 04 relating to unsworn falsification to authorities. David J. Ap ker, Esquire Attorney for Plaintiff DATE: 4/23/2009 FIA CARD SERVICES, N.A. RONALD R ZERANCE 1027 SWARTHMORE RD NEW CUMBERLAND, PA 17070-1730 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Balance Due: RONALD R ZERANCE 4264298996067370 $6,913.77 Our File No.: 204520 EXHIBIT "A" 0 '.r 01 T! 2009 fi'30 Fli 1: 20 +79-50 Pb A.Tr4 ft* 1Woll R` aa448? Sheriffs Office of Cumberland County R Thomas Kline ct cif+ntrrt, Edward L Schorpp Sheriff L4 Solicitor Ronny R Anderson Jody S Smith Chief Deputy CsFzr? F?'? r?G ="? Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/0112009 04:41 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on May 1, 2009 at 1641 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ronald Zerance by making known unto Ronald Zerance personally, at 1027 Swarthmore Road, New Cumberland, Cumberland County, Pennsylvania, 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $42.40 SO ANSWERS, May 05, 2009 Docket No. 2009-2717 Fia Card Services v Ronald Zerance R THQMAS KLIVI?, SHERIFF Y r.a n v ?-r? ? 2-1 jl? r Suzanne S. Friday, Esquire Supreme Court ID No. 201873 200 North Third Street P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Counsel for Defendant FIA CARD SERVICES, N.A., : IN THE COURT OF COMMON PLEAS c/o Apothaker & Associates, P.C. Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. 09-2717 - Civil Term RONALD R. ZERANCE, Defendant ANSWER AND NOW COMES Defendant, Ronald R. Zerance, by and through his attorney, Suzanne S. Friday, who answers the Plaintiff's Complaint and is support thereof avers the following: 1. Admitted. 2. Admitted. 3. Denied. It is specifically denied that Defendant, Ronald R. Zerance requested FIA Card Services issue him an account. Strict proof thereof is demanded. 4. After reasonable investigation, Defendant, Ronald R. Zerance is without sufficient knowledge or information with which to admit or deny the averments of Paragraph 5, and the averments are therefore denied. By way of further answer, Mr. Zerance requested documentation from FIA Card Services evidencing the charges on this account and received no reply.. 5. After reasonable investigation, Defendant, Ronald R. Zerance is without sufficient knowledge or information with which to admit or deny the averments of Paragraph 5, and the averments are therefore denied. By way of further answer, Mr. Zerance requested documentation from FIA Card Services evidencing the charges on this account and received no reply. Y 6. After reasonable investigation, Defendant, Ronald R. Zerance is without sufficient knowledge or information with which to admit or deny the averments of Paragraph 6, and the averments are therefore denied. 7. After reasonable investigation, Defendant, Ronald R. Zerance is without sufficient knowledge or information with which to admit or deny the averments of Paragraph 7, and the averments are therefore denied. WHEREFORE, Defendant, Ronald R. Zerance respectfully requests judgment be entered in his favor and to dismiss the Plaintiff's Complaint, with costs assessed against the Plaintiff. Respectfully submitted, c ?U Suzanne . Friday, Esquire - 01 Attorney for Plaintiff Nauman, Smith, Shissler & Hall, LLP 200 N. Third Street, 18th Harrisburg, PA 17101 (717) 236-3010 .. I verify that the statements made in this Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904, relating to unsworn falsifications to authorities. Date: cS Def dart Atto y for efendant 61 r CERTIFICATE OF SERVICE AND NOW, on the date stated below, I, Suzanne S. Friday, Esquire, of Nauman, Smith, Shissler & Hall, LLP, hereby certify that I this day served the foregoing Answer by United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed to the following: Apothaker & Associates, P.C. David J. Apothaker, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 Suzanne . Friday, Esquire May 21, 2009 x' nr t.+ R 0041Fti f'I ? : CO ;,? A s 7 Our File No.: 204520 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 FIA CARD SERVICES, N.A. Plaintiff, vs. RONALD R ZERANCE Defendant. 7` . i, 2010M413 AM11: o8 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2717 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOC TES, P.C. Attorneys for P 'ff A Law Firm Engaged ' D t Collection By: David J. Dated: 7/30/2010