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Our File No.: 257580
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D. #38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
ADVANTAGE ASSETS II, INC.
7322 SOUTHWEST FREEWAY, SUITE
1600
HOUSTON, TX 77074
Plaintiff,
VS.
IGNAZIO MELFA
4717 E TRINDLE RD
MECHANICSBURG, PA 17050-3616
Defendant.
20(0 P
NTY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: lO - y5W l-Fe -
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
34 S. BEDFORD ST.
CARLISLE PA 17013
717-249-3166
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Our File No.: 257580
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D. #38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
ADVANTAGE ASSETS II, INC.
7322 SOUTHWEST FREEWAY, SUITE
1600
HOUSTON, TX 77074
Plaintiff,
vs.
IGNAZIO MELFA
4717 E TRINDLE RD
MECHANICSBURG, PA 17050-3616
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.:
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is ADVANTAGE ASSETS II, INC., 7322 SOUTHWEST FREEWAY, SUITE 1600,
HOUSTON, TX 77074.
2. Defendant(s) is/are IGNAZIO MELFA, an adult individual residing at 4717 E TRINDLE RD
MECHANICSBURG, PA 17050-3616.
3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account
# ending in 7119; and said account was issued to Defendant(s) by CITIBANK (SOUTH DAKOTA) N.A./THE
HOME DEPOT, 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 $1,038.09. A true and correct
copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A".
t
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.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
$1,038.09 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & SS CIATES, P
Attorney r laintiff
A Law Firm Enaaa d n Debt llec
BY:
David J. ApothVer, Esquire
Dated: 7/1/2010
Our File No.: 257580
VERIFICATION
David J. Apothaker, Esquire 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.A. 4904 relating togsworn falsification to authorities.
David J.4pothak?Esgi
Atto v for Plaintiff
DATE: 7/1/2010
ADVANTAGE ASSETS II, INC.
IGNAZIO MELFA
4717 E TRINDLE RD
MECHANICSBURG, PA 17050-3616
STATEMENT OF ACCOUNT
Debtor's Name: IGNAZIO MELFA
Account Number: ending in 7119
Original Creditor: CITIBANK (SOUTH DAKOTA) N.A./THE HOME DEPOT
Balance Due: $1,038.09
Our File No.: 257580
EXHIBIT "A"
SHERIF
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Advantage Assets II, Inc.
vs.
Ignazio Melfa
OFFICE OF CUMBERLAND COUNTY
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Case Number
2010-4530
HERIFF'S RETURN OF SERVICE
07/14/2010 08:01 PM -Shawn Harr
2010 at 1955 hours, he
defendant, to wit: Ignazi
Mechanicsburg, Cumbe
him personally the said
SHERIFF COST: $37.00
July 15, 2010
~n, Deputy Sheriff, who being duly sworn according to law, states that on July 14
;rued a true copy of the within Complaint and Notice, upon the within named
Melia, by making known unto himself personally, at 4717 . Trindle Road,
and County, Pennsylvania 17050 its contents a he a time handing to
~e and correct copy of the same.
SW4WN HARRISON, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosoft. Inc.