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Home My WebLink About13-7205 Supreme Court of Pennsylvania. X Coullr f Canna Pleas For Prothonotan L ^'se Onto: , JI �� D ��, Docket No:`u� Count. The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the f ling and service of pleadings or other papers as required by law or rules of court. S Commencement of Action: E ® Complaint ❑ Writ of Summons ❑ Petition El from Another Jurisdiction El Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T GE CAPITAL RETAIL BANK GLORIA ZEIGLER Are money damages requested? N Yes ❑ No Dollar Amount Requested: ® within arbitration limits O (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes E No Is this an MDJAppeal? ❑ Yes E No A Name of Plaintiff /Appellant's Attorney: Apothaker and Associates. P.C. ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution E Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not S include mass tort) El Employment Dispute: Discrimination E El Slander/Libel/ Defamation ❑ Other: F1 Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I ❑ Other: O MASS TORT N El Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment $ ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non- Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto PROFESSIONAL ❑ Partition ❑ Replevin LIABLITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: Updated 1/1/2011 Our File No.. 347921'f I� t 1..9C,t40 TA, rt APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire lu' 3 DEC —5 PH 1 : 22 Attorney I.D.# 38423 CUMBERLAND COUNTY 520 Fellowship Road C306 PENMS YLVANIA Mount Laurel, NJ 08054 (800) 672 -0215 Attorneys for Plaintiff GE CAPITAL RETAIL BANK ) COURT OF COMMON PLEAS 170 ELECTION ROAD, SUITE 125 ) CUMBERLAN n-o TY DRAPER, UTAH 84020 ^ NO. Plaintiff, ) VS. ) GLORIA ZEIGLER ) 210 LINCOLN ST # A ) CARLISLE, PA 17013 ) Defendant. ) 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 Our File No.: 347921 ojuj W C )3 u� �1 SQL 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 GE CAPITAL RETAIL BANK ) COURT OF COMMON PLEAS 170 ELECTION ROAD, SUITE 125 ) CUMBERLAND COUNTY DRAPER, UTAH 84020 ) NO.: Plaintiff, ) vs. ) GLORIA ZEIGLER ) 210 LINCOLN ST # A ) CARLISLE, PA 17013 ) Defendant. ) CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is GE Capital Retail Bank ( "Plaintiff'), a federally chartered savings bank with a principal place of business located in Draper, Utah. 2. Defendant(s) is /are GLORIA ZEIGLER ( "Defendant "), an adult individual residing at 210 LINCOLN ST # A CARLISLE, PA 17013. 3. At the special instance and request of Defendant, Plaintiff issued a credit account ( "Account ") to Defendant. 4. The Account number ends in 9473. 5. Defendant received, accepted and used the account by making purchases, balance transfers, and/or cash advances. 6. The account is in default due to Defendant's failure to make timely payments. 7. Although demand has been made, Defendant has failed to make payment of the amount due. 8. The amount due as of this date is $4,930.37. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $4,930.37 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS OCIATES, P.C. Atto ey for Plaintiff A Law Firm E age in Debt Collection BY: David J. Apoltaker, Esquire Our File No.: 347921 Defendants Name: ZEIGLER, GLORIA Account Number: * * * * * * * * * * ** *9473 VERIFICATION 1 hereby state that I am an employee for the plaintiff herein, with authority to sign this verification; and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. Section 4904 which provides for certain penalties for making false statements. Cari Devine Version - 1.0.3 PA 09 19 2012 Ref:CEGZ301330CN v J In Court Judicial (Circuit/District) Creditor Name: GE Capital Retail Bank Debtor Name: ZEIGLER, GLORIA Account Number: .*' * * * * * * * ** * 9473 AFFIDAVIT OF ACCOUNT BALANCE STATE OF MINNESOTA :SS COUNTY OF RAMSEY BEFORE ME, the undersigned authority personally appeared and personally known by me, this day, Cari Devine and who after being duly sworn deposed and says as follows: 1. I am a competent person over eighteen years of age. 1 am an employee of GE Capital Retail Bank ( "GE Capital "), which is the creditor for the account of the Debtor identified above. 1 am authorized to make this Affidavit.. 2. I have personal knowledge of the facts set forth in this affidavit. 3. The business records maintained by GE Capital in the ordinary course of its business show that as of the date of this affidavit, the unpaid balance of Debtor's account is $4,930.37. 4. The business records maintained by GE Capital in the ordinary course of its business show that as of the date of this affidavit the last payment was received from the Debtor on 8/12/2011 in the amount of $20.00. 5. The business records maintained by GE Capital in the ordinary course of its business show that the account of the Debtor was charged off on 9/16/2011 in the amount of $4,930.37. 6. Based on my search of the Department of Defense Service members Civil Relief Act (SCRA) website, it is my belief that the Debtor is not in military service. I declare der the penalty of perjury that the foregoing is true and correct. 8/13/20].3 Cari Devine 1 � RECOVERY LIAISON SPECIALIST- Affiant The for o of r s d u cribed before me this 13 Day of August, 2013. .. =•t. NICOLE A. THOMAS Not Pu li Notary Publio-Minnesota My Commission E 1ms Jan 31, 2018 My cornmission expires: I � Version - 1.0.3 PA 09 19 2012 Ref:CEGZ301330CN Z SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ,. Sheriff Jody S Smith Chief Deputy �`3 3 DEC 17 Atl 9: 59 Richard W Stewart Solicitor ; = l i' i i t o L t '`k PENNSYLVANIA GE Capital Retail Bank Case Number vs. Gloria Zeigler 2013-7205 SHERIFF'S RETURN OF SERVICE 12/06/2013 05:51 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Complaint & Notice by"personally' handing a true copy to a person representing themselves to be the Defendant, to wit: Gloria Zeigler at 210 Lincoln Street#A, Carlisle Borough, Carlisl 17013. / s J Gam— j - /,w BRIAN GRZYBA: I, j `di SHERIFF COST: $34.78 SO ANSWERS, December 11, 2013 RONNY ANDERSON, SHERIFF 4 Our File No.: 347921 ip�$r , APOTHAKER& ASSOCIATES, P.C. Q��JU 'ib rA BY: David J. Apothaker, Esquire 7 Attorney I.D.# 38423 r P-N�sAND �1 3: Mount Laurel,NJ 0 054 06 Ens Y(,VA NM Y (800) 672-0215 Attorney for Plaintiff GE CAPITAL RETAIL BANK ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, ) VS. ) GLORIA ZEIGLER ) NO. 13-7205 CIVIL Defendant. ) PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER ASSO IATES, P.C. Attorn s for P intiff A Law Firm En aged ' Debt Collection By: David J. Apothaker, Esquire * 4 3 4 7 9 2 1 D I S M 1 -