Before Judges Muir, Jr., *fn2 Keefe and Eichen.
The opinion of the court was delivered by: Eichen, J.A.D.
 Argued November 10, 1998
On appeal from the Superior Court of New Jersey, Chancery Division, Family Part, Monmouth County.
Defendant Phillip A. Quarrie appeals from an order denying his motion to vacate a default judgment requiring him to pay child support arrears of $9,675 for a child born out of wedlock who was determined not to be his child. We reverse.
On May 25, 1994, plaintiff Monmouth County Division of Social Services (MCDSS), on behalf of Virginia L. Hall, *fn3 filed a "Complaint for Paternity and Support," pursuant to N.J.S.A. 9:17-45a and 53c, against defendant Phillip Quarrie. The complaint sought a judgment determining that defendant was the father of Lamar I. Hall, the biological son of Virginia L. Hall. Lamar was born January 5, 1991. The complaint also sought support and repayment of all public assistance and medical expenses.
The complaint, which purports to be a verified complaint, states as follows:
Monmouth County Division of Social Services, in the Department of Human Services of the County of Monmouth, Kozloski Road, Freehold Twp., N.J. says:
1. VIRGINIA L. HALL is the MOTHER of: LAMAR I. HALL D.O.B. 01/05/91 - H57435 born out of wedlock.
2. The child is receiving public assistance (AFDC N.J.S.A. 44:10-1 et seq.) from the Monmouth County Division of Social Services and all support rights have been assigned pursuant to N.J.S.A. 44:10-2.
3. The plaintiff seeks to establish paternity pursuant to the New Jersey Parentage Act, N.J.S.A. 9:17-38 et seq.
4. There have been no prior family court actions except: N/A
WHEREFORE, plaintiff prays for judgment against the defendant:
1. Determining the defendant to be the father of the child.
2. Requiring the defendant to support the child.
3. Requiring defendant to provide medical and dental benefits ...