HomeMy WebLinkAbout07-3075IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CITIFINANCIAL I CIVIL DIVISION
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Plaintiff(s), 1 ~'
I No . 2 0 0 7- .,~d7s l.. (V ~ 1~~~1Lyr~
v. I
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ABLDELMONA HLALI, I
an individual I
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I
Defendant(s), 1
I
I COMPLAINT
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I
I Code No.
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I Filed on Behalf of:
I
I PLAINTIFF
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ATTORNEY OF RECORD FOR THIS PARTY
I
I Louis B. Swartz
i
I PA. ID # 00242
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I
ISWARTZ, LOVEJOY & ASSOCIATES
116th FLOOR LAW AND FINANCE BUILDING
(PITTSBURGH, PENNSYLVANIA 15219
I
I
1(412) 288-0300
<77438
NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE
<77438
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CITIFINANCIAL
Plaintiff(s),
v.
ABLDELMONA HLALI,
an individual
Defendant(s),
No. 2007-
NOTICE TO DEFEND AND CLAIM RIGHTS
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 days (20) 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
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
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
NOTDEFCU.FLE
<77438
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CITIFINANCIAL
v.
ABLDELMONA HLALI,
an individual
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I
I
I
Plaintiff(s), I
I No
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I
I
I
I
I
Defendant(s), I
2007- n~ J
30~ l.. t v ~l, `r/L.~
COMPLAINT
1. Plaintiff(s) is CITIFINANCIAL. Plaintiff's address is ATTN:
PAYMENT PROCESSING, FORT MILL, SC 29715.
2. Defendant(s) is ABLDELMONA HLALI, an individual.
Defendant's address is 236 SILVER SPRING RD, MECHANICSBURG PA
170500000.
3. Plaintiff, at Defendant's special instance and request,
opened for the Defendant a credit account which Defendant
thereafter used and there is a balance due and unpaid,
despite demand, in the amount of $12,016.65 plus
interest from September 25, 2006.
WHEREFORE, Plaintiff demands Judgment agains fendant(s) in
the amount of $12,016.65 Plus legal interest
and costs.
Louis B. Sw z
Attorney for;1~ INTIFF
SWARTZ, LOVE OY & ASSOCIATES
16th FLOOR LAW AND FINANCE BUILDING
PITTSBURGH, PENNSYLVANIA 15219
(412) 288-0300
<77438
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CITIFINANCIAL
v.
Plaintiff(s),
Defendant(s),
No. 2007-
VERIFICATION
ABLDELMONA HLALI,
an individual
The undersigned, ~1i,~~ ~~1~~ avers
that he/she is the ~[).}- of Plaintiff,
is authorized to make this verification on behalf of
Plaintiff, the statements of fact contained in the attached
Complaint are true and correct to the best of his/her
information, knowledge and belief, and are made subject
to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904
relating to unsworn falsification to authorities.
Dat l f
VERIFCOM.PLE
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-03075 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIFINANCIAL
VS
HLALI ABLDELMONA
RONALD HOOVER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
HLALI ABLDELMONA the
DEFENDANT at 1612:00 HOURS, on the 25th day of May 2007
at 236 SILVER SPRING ROAD
MECHANICSBURG, PA 17050
TERRY STROHECER
by handing to
ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.60
Affidavit .00
Surcharge 10.00
.00
41bY~~t c~ 3 7 . 6 0
Sworn and Subscibed to
before me this day
So Answers:
~.
R. Thomas Kline
05/29/2007
SWARTZ LOVEJOY & ASSOCIATES
By : C f~-~~~ /~
Deputy She iff
of A.D.
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f ~~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CITIFINANCIAL I CIVIL DIVISION
I
I
Plaintiff(s), I
I No. 2007-03075
v. I
I
ABLDELMONA HLALI, I
an individual I
I
I
Defendant(s), I
I
I PRAECIPE FOR DEFAULT JUDGMENT
I
I
~ Code No.
I
I Filed on Behalf of:
I
I PLAINTIFF
I
I
I
I ATTORNEY OF RECORD FOR THIS PARTY
I
~ Louis B. Swartz
I
I PA. ID # 00242
I
I
ISWARTZ, LOVEJOY & ASSOCIATES
16th FLOOR LAW AND FINANCE BUILDING
(PITTSBURGH, PENNSYLVANIA 15219
I
I
((412) 288-0300
$77438
NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE
r '~
877438
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CITIFINANCIAL
v.
Plaintiff(s),
No. 2007-03075
ABLDELMONA HLALI,
an individual
Defendant(s), ~
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Enter judgment against Defendant(s) and in favor of
Plaintiff in Default of an Answer or a Notice of Intention
to Appear as follows:
AMOUNT CLAIMED IN COMPLAINT $ 12,016.65
PLUS INTEREST FROM 09-25-2006 TO: 07-23-2007 $ 594.58
TOTAL $ 12,611.23
I certify that I mailed a notice of default to the
defendant(s) in the form attached hereto on the date stated
thereon which was more that ten (10) days efore filing this
praecipe. ~ /
Louis B. S~i'artz
Attorney for PLAINTIFF
SWARTZ, LOVEJOY & ASSOCIATES
16th FLOOR LAW AND FINANCE BUILDING
PITTSBURGH, PENNSYLVANIA 15219
(412) 288-0300
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;77438
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CITIFINANCIAL
v.
ABLDELMONA HLALI,
an individual
No. 2007-03075
DEFAULT NOTICE
TO THE DEFENDANT: ABLDELMONA HLALI,
an individual
236 SILVER SPRING RD
MECHANICSBURG, PA 17050
Plaintiff(s),
Defendant(s),
IMPORTANT NOTICE
^MYOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES
OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN
TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.^P
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.
PENNSYLVANIA LAWYER REFERRAL SERVICE
100 SOUTH STREET, P.O. BOX 186
HARRISBURG, PA 17108
1-800-692-7375
Date `o ~ S'-LOwS B. $Wal"tZ
Louis B. Swartz
Attorney for PLAINTIFF
SWARTZ, LOVEJOY & ASSOCIATES
16th FLOOR LAW AND FINANCE BUILDING
PITTSBURGH, PENNSYLVANIA 15219
(412) 288-0300
NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CITIFINANCIAL I CIVIL DIVISION
I
I
I
Plaintiff(s), J
I No. 2007-03075
v. I
I
ABLDELMONA HLALI, I
an individual I
i
I
Defendant(s), I
I
I AFFIDAVIT OF NON-MILITARY
I SERVICE
I
I Code No.
J
J Filed on Behalf of:
I
I PLAINTIFF
I
I
I ATTORNEY OF RECORD FOR THIS PARTY
I
I Louis B. Swartz
I
I PA. ID # 00242
I
I
ISWARTZ, LOVEJOY & ASSOCIATES
116th FLOOR LAW AND FINANCE BUILDING
(PITTSBURGH, PENNSYLVANIA 15219
I
I
((412) 288-0300
$77438
NOTE: THIS I5 AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE
'~ !.
~ ~
&77938
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CITIFINANCIAL
v.
Defendant(s),
No. 2007-03075
AFFIDAVIT OF NON-MILITARY SERVICE
I, David A. Lovejoy, do depose and say that the above-named
Plaintiff(s),
ABLDELMONA HLALI,
an individual
defendant(s) Abldelmona Hlali
are not currently in the naval or military services of the
United States, either directly or indirectly.
These statements are made subject to the penalties of 18 Pa.
Cons. Stat. Ann. Section 4904 relating to unsworn falsification
to authorities.
NONMIL2.PLE
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