HomeMy WebLinkAbout11-0296Our File No.: 289781
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
PORTFOLIO RECOVERY
ASSOCIATES, LLC
140 CORPORATE BOULEVARD
NORFOLK, VA 23502
Plaintiff,
vs.
MATTHEW B ZERBY
103 E MAIN ST
CAMP HILL, PA 17011
Defendant.
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COURT OF COMMON PLEAS
CUMBERLAND COUNTY
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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. Q
CARLISLE PA 17013
717-249-3166 ?7d 'u .?6 )q*j` 4P 4MY-,(Y
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Our File No.: 289781
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
PORTFOLIO RECOVERY
ASSOCIATES, LLC
140 CORPORATE BOULEVARD
NORFOLK, VA 23502
Plaintiff,
vs.
MATTHEW B ZERBY
103 E MAIN ST
CAMP HILL, PA 17011
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. /I- ;L-96
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC, 140 CORPORATE
BOULEVARD, NORFOLK, VA 23502.
2. Defendant(s) is/are MATTHEW B ZERBY, an adult individual residing at 103 E MAIN ST
CAMP HILL, PA 17011.
3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in
Interest of Account # ending in 8401; and said account was issued to Defendant(s) by CAPITAL ONE BANK,
N.A., 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 $1,104.13. 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.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
$1,104.13 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & S IATES, P.
Attorney r P 'ntiff
A Law Firm En2a2 d i Debt llect
BY:
David J. ApothNker, Esquire
Dated: 12/23/2010
Our File No.: 289781
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 rsigned understands that the statements therein are
made subject to the penalties of 18 Pa.C.S.A. 4904 rela 'ng to sworn falsification to authorities.
David J. A thaker, Esquire
Attorney ntiff'
DATE: 12/23/2010
PORTFOLIO RECOVERY ASSOCIATES, LLC
MATTHEW B ZERBY
103 E MAIN ST
CAMP HILL, PA 17011
STATEMENT OF ACCOUNT
Debtor's Name: MATTHEW B ZERBY
Account Number: ending in 8401
Original Creditor: CAPITAL ONE BANK, N.A.
Balance Due: $1,104.13
Our File No.: 289781
EXHIBIT "A"
289781
Request for Service
R. Thomas Kline Sheriff
Cumberland County Office of the Sheriff
One Courthouse Square
Carlisle, PA 17013
Ph: 717.240.6390
Fx: 717-240-6397
Plaintiff/s: Court Number:
PORTFOLIO RECOVERY Expiration Date:
ASSOCIATES, LLC
Type of Action:
Civil Action
Defendant/s:
MATTHEW B ZERBY
Serve Upon:
MATTHEW B ZERBY
Address for Service:
103 E MAIN ST
CAMP HILL, PA 17011
Alternate Address for Service:
Type of Service:
( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting
Special Service Instructions:
* * If service is to be made by deputized service to another county please specify which
county
Filing Attorney Information:
Name: Apothaker & Associates, P.C.
Address: 520 Fellowship Road C306
Mount Laurel, NJ 08054
Telephone: 215-634-8920