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HomeMy WebLinkAbout07-3075IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL I CIVIL DIVISION I I I Plaintiff(s), 1 ~' I No . 2 0 0 7- .,~d7s l.. (V ~ 1~~~1Lyr~ v. I I ABLDELMONA HLALI, I an individual I I I Defendant(s), 1 I I COMPLAINT I I I Code No. I I 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 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 I I I I Plaintiff(s), I I No I 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 ~~ ~~ ~ .y ~ ~ ~ ,.. o w p~ - --- ~ ~ -~,~ ~ _ ~ w ~ .::a ~~ ~, .~ ~" ~,~,_; `, ~._ ,: S'j,j 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. ~a~ , 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 r-~ ~, ~w. ~t~ ~ „~ 4 , , ~ ~ ~ ~ ~ Q ~ v ~ _ c.3 ~ ~ ~~~ ~ `= n ~. " _` ~ ° ` 1 '~ ~ . ~- ;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 defnote/defnotex ,, ' :-~~ :::~ C ` ~ ~ =T3 r ~ . ~ -.., ;~ ~ ~ , f . "^7 i" ~ C.+~ "`.7 r= :, ~~ ~i _;J ~. ~ .-~: 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 _r :: .-i - ^.S r ~` ~=i .y f "_. r,