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HomeMy WebLinkAbout10-4530 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 QS1 49100 PO Art-/ e? ?sg?a? ?# a4yey7 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 ~~,~y~tr p4 ~~r~nbrp~~~~ ~' ~'-, , <' ~~~ QFfitCE O~ `nE BkERIFF 20(0 ~U°~ 1 ~ ~'~ ~~ Cl?~ t-~~ ,. ~ , ~.~C~ ~ Y 9t :... ~ ! ~ t C ti~~l ~ 1 u1, y GF'. 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.