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Home My WebLink About08-7554Our File No.: 194764 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff AMERICAN EXPRESS CENTURION BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. MOULAY M KANZI BELGHITI 110 W VINE ST APT B CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: C9 -- gb5L{ atv! l -Fer A 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 ` s Our File No.: 194764 ' APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff AMERICAN EXPRESS CENTURION BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. MOULAY M KANZI BELGHITI 110 W VINE ST APT B CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 k- 7 S CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS CENTURION BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are MOULAY M KANZI BELGHITI, an adult individual residing at 110 W VINE ST APT B CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3772-399138-71009. 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 $6,329.00. 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 $6,329.00 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enga9 RTES, P.C.. Debt BY: David I Apkaker, Esquire Dated: 12/22/2008 Our File No.: 194764 VERIFICATION David J. Anothaker Esquire EsQ 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, The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C relating to unworn falsification to authorities. David J. Apo3Tiaker, Esquire Attorney for Plaintiff DATE: 12/22/2008 AMERICAN EXPRESS CENTURION BANK MOULAY M KANZI BELGHITI 110 W VINE ST APT B CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: MOULAY M KANZI BELGHITI Account Number: 3772-399138-71009 Balance Due: $6,329.00 Our File No.: 194764 EXHIBIT "A" TO , jC 00 ? d ?. in tea GA? 'Y1 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07554 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN EXPRESS CENTURTION VS BELGHITI MOULAY M KANZI TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BELGHITI MOULAY M KANZI the DEFENDANT , at 1928:00 HOURS, on the 5th day of January , 2009 at 110 W VINE STREET APT B CAMP HILL, PA 17011 by handing to LISSET KANZI BELGHITI WIFE 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 i??-?.•cC 'P 10.80 .00 10.00 R. Thomas Kline .00 38.80 01/06/2009 APOTHAKER & ASSOCIATES By: day Dep ty Sher' f A.D. r..., .--, ,.. ??? _. - ? ; _. - :, , .?,, - -?1 ?,? ??? ?. , .. J • Our File No.: 194764 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff AMERICAN EXPRESS CENTURION BANK Plaintiff, vs. MOULAY M KANZI BELGHITI Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7554 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER A Law Firm SOCIATES, P.C. ' Plaintiff in Debt Collection By: David J. Apothaker, Esquire Dated: 6/3/2009 ? IlL UE THE PR,01 ?' I!OTARY 2009 JUN 12 PM 3: 3 6