HomeMy WebLinkAbout11-5630IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
Plaintiff NO.
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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 an 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 or any other claim or relief requested by the Plaintiff. You may lose money or
property 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 HELP. 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 S BEDFORD ST.
CARLSILE, PA 17013
(717) 249-3166
FFG File # 274773
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
Plaintiff
V.
MOHAMED A AHRAR
Defendant(s)
NO.
CIVIL ACTION - LAW
NOTICIA
USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda
puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que
esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un
abogado y archivando por escrito con la Corte sus defensas o objeciones a las demandas puestas en
esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un
juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamado
en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder
dinero o propiedad o otros derechos importante para usted.
UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO.
ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN
ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
1NFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A
PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S BEDFORD ST.
CARLSILE, PA 17013
(717) 249-3166
FFG File#: 274773
PA/PA_NTCDE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
125 S. WEST ST
WILMINGTON DE 19801
Plaintiff
V.
MOHAMED A AHRAR
6320 ANTILLES CT
MECHANICSBURG PA 17050-5249
Defendant(s)
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COMPLAINT
AND NOW, comes Plaintiff, by and through its attorneys, Fulton, Friedman & Gullace, LLP, and files
this Complaint and in support avers as follows:
1. On or about 12/22/2004, Plaintiff issued a revolving credit account to Defendant bearing account
number XXXXXXXXXXXX1050 (hereinafter "the account").
2. Upon information and belief, Defendant(s), MOHAMED A AHRAR, has a last known address(es) of:
6320 ANTILLES CT MECHANICSBURG PA 17050-5249 .
3. This action is based upon a written credit agreement entered into between Defendant(s) and Plaintiff; a
copy of the credit card agreement is attached hereto as Exhibit "A."
4. Defendant(s) used or authorized the use of the account to obtain loans from Plaintiff for the purpose of
obtaining goods, and/or services and/or cash advances.
5. Defendant(s) failed to make full payment of the amount owed on the account.
6. Upon information and belief the last payment posted to the account on 8/4/2009.
7. The account shows that Defendant(s) owe(s) a balance of $7290.63.
*0260800W06S*
FFG File # 274773
PA_CCC
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the
Plaintiff and against Defendant(s) in the amount of $7290.63, plus costs of this action, and any other relief
as this Court deems just and reasonable.
Respectfully Submitted,
David R. Galloway # 87326
Fulton Friedman & Gullace, LLP
1308 Gettysburg Pike
Mechanicsburg, PA 17055
Telephone Number: (800) 869-2331
FFG File # 274773
PA_CCC
VERIFICATION
I verify that the facts set forth in this Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §
4904, relating to unsworn falsification to authorities.
Because of my title, I am authorized to make this verification on behalf of Plaintiff.
Date:-G/24Zoi BY P??'NN e)(-f?nA-
Print Name
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Signature
Title
FFG File # 274773
PA_CCC
PA_CCC
Page 1 of 8
Your Cardmember Agreement with Us
This document Is our standard form credit card agreement in effect on the last business day of the
previous calendar quarter that ended on 12/31/2009 and has been supplemented with pricing
information included in the document(s) titled "Pricing Supplement" and other terms and/or
features that may vary between the different types of credit card accounts that we offer as reflected
in the "Addendum to the Cardmember Agreement". These documents are provided to you for
informational purposes only. These account terms may not be available after the above date. If
you apply and are approved for a credit card account with us, your actual account terms will be
based on the terms of the offer available at the time that you applied and your Cardmember
Agreement will be the agreement sent to you when your account is first opened.
Introduction.
This Agreement establishes the terms of your credit card account ("Account") with Barclays Bank
Delaware, Wilmington, Delaware. Please read it carefully and keep it with your records. You do not need to
sign this Agreement, but please sign the back of your credit card (the "Card"), if you have not already done
so. All extensions of credit in connection with your Account are being made by Barclays Bank Delaware.
You do not need to accept the Account and this Agreement and none of the fees on this Account will apply
unless you use the Account.
Definitions.
If we use a capitalized term in this document but we do not define the term in this document, the term has
the meaning as used in your monthly statement.
"Agreement" means this document, the Pricing Supplement (the "Supplement") and the Addendum to the
Cardmember Agreement (the "Addendum") document and any changes we make to these documents from
time to time.
"Authorized User" means any person you allow to use your Account including without limitation through a
Card, Check, the account number, or other credit device.
"Balance Transfer" means the use of your Account for a loan obtained by a transfer of funds initiated by us
at your request and includes the use of a Balance Transfer Check. "Balance Transfer" includes the
Transaction Fees associated with any Balance Transfer.
"Cash Advance" means the use of your Card or account number to obtain cash loans at any financial
institution or automated teller machine that accepts the Card, the use of a Cash Advance Check or the
purchase of Cash Equivalents. "Cash Advance" includes the Transaction Fees associated with any Cash
Advance or any Cash Equivalent.
"Cash Equivalent" means the use of your Card or account number to obtain money orders, traveler's
checks, foreign currency, lottery tickets, gambling chips or wire transfers. Cash Equivalents and the
Transaction Fees associated with any Cash Equivalent are considered Cash Advances for interest
calculation purposes.
"Check" or "Convenience Check" means an access check we provide to you to make a Cash Advance or a
Balance Transfer as applicable on your Account. A Check can be either a Balance Transfer Check or a
Cash Advance Check and will be designated as such by us.
"Daily Periodic Rate" or "DPR" means the applicable APR divided by 365.
"Foreign Transaction" means the use of your Card or Account (other than through a Cash Advance) for a
transaction with a business or entity located outside of the United States or for a transaction in a currency
other than U.S. dollars. Foreign Transactions and the Transaction Fees associated with any Foreign
Transaction are considered Purchases for interest calculation purposes.
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"Monthly Periodic Rate" or "MPR" means the applicable APR divided by 12
"Purchase" means the use of your Card or account number to buy or lease goods or services and to make
a transaction that is not otherwise a Balance Transfer or a Cash Advance. Purchases include Foreign
Transactions, Account Fees and any adjustments associated with any Purchase.
"You" and "your" refer to each person who has applied for, accepted, or used the Account and each person
who has agreed to be responsible for the Account.
"We," "us" and "our" refer to Barclays Bank Delaware
Using Your Account/Acceptance of These Terns.
By signing, keeping or using your Card or Account, you agree to the terms and conditions of this
Agreement. You may obtain credit in the form of Purchases, Balance Transfers and Cash Advances by
using your Card, your account number, Checks, or other credit devices. You agree that we may credit your
Account rather than issue cash refunds when you reverse transactions that were originally charged to your
Account. You agree that you will not use your Card or Account in connection with any transaction that is
prohibited or unenforceable and that if you do engage in such a transaction you waive any claim that the
charge is uncollectible on the grounds the transaction was prohibited or unenforceable. The Card must be
returned to us upon request. We may replace your Card with another Card at anytime.
Obligations on Your Account.
You authorize us to pay and charge your Account for all Purchases, Balance Transfers, Checks, and Cash
Advances made or obtained by you or anyone you authorize to use your Card or Account. You agree to
pay us for all of these Purchases, Balance Transfers, Checks, and Cash Advances, plus any interest
assessed on your Account and any other charges and fees which you may owe under the terms of this
Agreement, whether resulting from 1) physical use of your Card or a Check, 2) mail order or telephone,
computer or other electronic transaction made without presenting the Card, or 3) any other circumstances
where you authorize a charge, or authorize someone else to make a charge, to your Account. Each person
who has agreed to be responsible on the Account is responsible to pay the full amount owed on the
Account. If this is a joint Account, we can send statements and notices to either of you. We may require
that you pay the full amount owed without first asking any other person(s) to pay. Instructions for making
payments are on your monthly billing statement. Payments that comply with the requirements specified on
or with your monthly billing statement, including the time of receipt, will be credited on the business day
they are received. Payments must be mailed to the correct P.O. Box or street address specified for U.S.
Priority Mail and overnight payments. There may be a delay of up to five (5) days in crediting
payments that are not made in accordance with those instructions. Please allow at least seven (7)
days for the U.S. Postal Service to deliver your payment. All payments must be made in U.S. dollars.
Any payment made by check or other negotiable instrument or direct debit must be drawn on a U.S. bank
or a U.S. branch of a foreign bank. We reserve the right to accept payments made in a foreign currency. If
we do, we will select the foreign currency rate at our discretion. Your available credit may not be
immediately increased by the amount of the payment for up to seven (7) days to ensure we collect
the funds from the bank on which your payment is drawn. If you overpay or if there is a credit balance
on your Account, we will not pay interest on such amounts.
Credit Line/Authorized Usage.
Your credit line is shown on the folder containing your Card. We may change your credit line from time
to time either increase or decrease It-in our sole discretion. If at any time (including in the first
month after your Account is opened) you engage in account actions or activity that we perceive could have
a negative impact on your credit standing with us, we may decrease your credit line or close your Account.
Your latest credit line will appear on your monthly billing statement. You agree not to make a Purchase,
authorize a Balance Transfer, use a Check, or obtain a Cash Advance that would cause the unpaid
balance of your Account to exceed your credit line. We may honor Purchases, Balance Transfers,
Checks and/or Cash Advances in excess of your credit line at our sole discretion. If we do, this
Agreement applies to that excess and you agree to pay the excess immediately If we request that
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you do so. You agree that we may change or cancel your credit line at any time without affecting
your obligation to pay amounts that you owe under this Agreement. We may designate that only a
portion of your credit line is available for Cash Advances. If we do and you exceed your line, you
will be considered to have exceeded your credit line for all purposes of this Agreement. We may
limit the auth We will notify you of any change, but the change may take effect before you receive the
notice. orizations to make Purchase, Balance Transfer, Check, or Cash Advance transactions that may be
accomplished with your Card or Account. If you are approved for an account that does not have a
preset spending limit please see the Addendum to the Cardmember Agreement addendum for
additional Information about your credit line and the usage of your Account.
Checks on Your Account.
We may issue Checks on your Account in the form of "Balance Transfer Checks" or "Cash Advance
Checks," which can be used to access your credit line. Each Check will contain your Account number and
may be used only by the person(s) whose name(s) is/are printed on it. Each must be completed and
signed in the same manner as a regular personal check. If we provide Checks to you, you may not use
them to pay any amount you owe under this Agreement or under any other account you may have with us.
Balance Transfer Checks and Cash Advance Checks are subject to the same rate and other terms under
this Agreement as Balance Transfers and Cash Advances, respectively. Unless otherwise indicated, all
references in this Agreement to Balance Transfers include Balance Transfer Checks, all references to
Cash Advances include Cash Advance Checks, and all references to use of the Account include use of
these Checks. Unlike purchase transactions, there are no charge back rights with regard to Balance
Transfer and Check transactions.
Monthly Billing Statements.
At the end of each monthly billing cycle a statement will be mailed or delivered to you if your Account has a
debit or credit balance of more than $1.00 or if interest or a fee has been imposed. We will not send a
monthly billing statement if we deem your Account uncollectible or if delinquency collection proceedings
have been instituted by us sending your Account to an outside collection agency or attorney for collection.
Your Minimum Payment Each Month.
Each billing cycle, you must pay at least the Minimum Payment Due shown on your monthly statement by
its Payment Due Date. If the Statement Balance shown on your monthly statement is less than the amount
reflected in the Addendum to the Cardmember Agreement, your Minimum Payment Due will be that
Statement Balance amount. Otherwise, if your Statement Balance is greater than the applicable disclosed
amount, your Minimum Payment Due will be the total of 1) 1 % of the Principal Balance (defined as the total
Statement Balance minus interest charges, Returned Payment Fee, and any Late Payment Fee, that are
incurred during the current billing cycle), plus 2) interest charges accrued during the current billing cycle,
plus 3) any Returned Payment Fee (and if we so elect, any Late Payment Fee), incurred during the current
billing cycle, plus 4) if we so elect, any amount past due or amount over your credit line at the time of
billing. In certain instances your Minimum Payment Due may be less than your total Fees and Interest
assessed in that billing cycle. At any time you may pay more than the Minimum Payment Due up to the full
amount you owe us.
Transaction Fees.
If you use your Card or Account to obtain a Cash Advance, we will charge a Cash Advance Fee for each
such Cash Advance. If you use your Card or Account to do a Balance Transfer, we will charge a Balance
Transfer Fee for each such Balance Transfer. If you use your Card or Account to purchase Cash
Equivalents, we will charge a Cash Advance Fee (sometimes we may refer to this as a Cash Equivalent
Fee) for each such transaction. If you use your Card or Account for a Foreign Transaction, we will charge a
Foreign Transaction Fee for each such transaction. Balance Transfer Checks and Cash Advance Checks
are subject to the same Transaction Fee as Balance Transfers and Cash Advances, respectively. The
present amounts of those charges are stated in the Supplement.
Account Fees.
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We may also assess the Account Fees listed below. The current amounts of such Account Fees are stated
in the Supplement.
Late Payment Fee - If we do not receive a payment from you in at least the amount of your Minimum
Payment Due by the Payment Due Date shown on your monthly statement, we may charge you a Late
Payment Fee. You may be charged one Late Payment Fee for each Minimum Payment Due which is not
paid by the Payment Due Date.
Returned Payment Fee - If your bank does not honor a check or direct debit you deliver to us, or we must
return a check because it is not signed or is otherwise irregular, we may charge you a Returned Payment
Charge.
Returned Check Fee - If we return a Check unpaid because it exceeds your available credit line at the
time it is processed, your Account is closed or otherwise does not have charge privileges, you did not
comply with our instructions regarding the check or your Account is past due, we may charge you a
Returned Check Fee.
Check Stop Payment Fee - If we stop payment on a Check at your request, we may charge you a Check
Stop Payment Fee.
Foreign Currency Conversion.
For MasterCard Cards, we and MasterCard (or their affiliates) will convert transactions in foreign
currencies into U.S. Dollars. MasterCard will use their currency conversion procedures that are current at
the time of the transaction. Currently, the currency conversion rate they use is either the wholesale market
rate or the government-mandated rate in effect under those procedures increased by one percent. The
currency conversion rate used on the conversion date may differ from the rate in effect on the date you
used your Card or Account.
For Visa Cards, we and Visa (or their affiliates) will convert transactions in foreign currencies into U.S.
Dollars. Visa will use its currency conversion procedures that are current at the time of the transaction.
Currently, Visa selects a rate from the range of rates available in the wholesale currency markets for the
applicable central processing date, which rate may vary from the rate Visa itself receives, or the
government mandated rate in effect for the applicable central processing date. The currency conversion
rate used on the conversion date may differ from the rate in effect on the date you used your Card or
Account.
Authorized Users.
You may allow Authorized Users to use your Account. If you allow an Authorized User to use your Account,
you will be liable for all transactions made by that person including transactions for which you may not
have intended to be liable, even if the amount of those transactions causes your credit limit to be
exceeded. You must notify us to revoke your permission to allow an Authorized User to use your Account
or Card. Until you revoke your permission, you are responsible for all charges made by an Authorized
User, including Balance Transfer Check and Cash Advance Check transactions, regardless of whether you
intended to be responsible for those charges. If you request additional Cards for Authorized Users, checks
accessing this Account may also be included with the Card.
Administrative Charges.
If you request photocopies of monthly billing statements, you will be charged $5 for each duplicate
requested for each statement requested that is less than 23 months old. If the requested statement is older
than 23 months you will be charged $10 for each requested statement. If you request any special services
such as obtaining Cards on an expedited basis, you agree to pay our reasonable charges for such
services, in effect at that time.
Default/Collection Costs.
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Unless otherwise prohibited by law, your Account will be in default and we may demand immediate
payment of the entire amount you owe us if: 1) in any month we do not receive your Minimum Payment
Due by the Payment Due Date; 2) you make Purchases, initiate Balance Transfers, use a Check, or obtain
Cash Advances in excess of your credit line; 3) you fail to comply with this Agreement; 4) there is a filing
for your bankruptcy; 5) you die or become incapacitated; or 6) we believe in good faith that the payment or
performance of your obligations under this Agreement is impaired for any other reason. As permitted by
applicable law, you agree to pay all collection expenses actually incurred by us in the collection of amounts
you owe under this Agreement (including court or arbitration costs and the fees of any collection agency to
which we refer your Account) and, in the event we refer your Account after your default to an attorney who
is not our regularly salaried employee, you agree to pay the reasonable fees of such attorney. We will not
be obligated to honor any attempted use of your Account if a default has occurred or we have determined
to terminate your Account or limit your Account privileges (as discussed below).
Termination.
We may terminate your privileges under this Agreement or limit your right to make Purchases, initiate
Balance Transfers, use Checks, or obtain Cash Advances at any time for any reason without prior notice. If
we ask, you must return your Cards and any unused Checks to us, cut in half. You agree that you will not
try to make a Purchase, use a Check, initiate a Balance Transfer or obtain a Cash Advance after you have
been notified that your privilege to use your Account has been terminated. You may terminate this
Agreement at any time. If you do, you must return to us all Cards and Checks previously issued on the
Account. If you call us, we may require that you confirm your termination in writing. Termination will not
affect existing obligations under this Agreement or your liability for all charges posted to your Account prior
to the time all Cards and unused Checks issued on your Account are returned to us.
Notices to You.
Billing statements and notices will be sent to the address shown in our files. If this is a joint Account, we
may send billing statements and notices to either of you. You promise to inform us promptly in writing of
any change in your e-mail address or your U.S. mail address. You may update this information by visiting
the website on the back of your Card and sending us an e-mail or telephoning us at the telephone number
provided below on your Card. We may in our discretion accept address corrections from the United States
Postal Service.
Consent to Receive Electronic Notices
You may receive periodic billing statements and other notices regarding your Account electronically or by
U.S. mail. By requesting statements and other notices electronically, which may only be done on our
website, and by providing any other legally required consents, you affirmatively consent to receive all
periodic billing statements and other notices electronically when legally permissible. Otherwise, statements
and notices will be sent to the address shown in our files. If at any time you need a paper copy of
statements or notices, or you change your mind and prefer to receive all your statements and notices in
paper rather than electronic form, telephone us at the number provided below or visit us at the website on
the back of your Card and send us an e-mail. In order to access your statements and notices electronically,
you must have a computer equipped with at least a 40-bit JavaScript-enabled Netscape or Microsoft
browser at the Version level 4.0 or higher. In order to retain your statements and notices, you must have a
printer attached to your computer that can print them out or a drive or other storage device onto which you
can download them. By accepting the receipt of electronic statements and other notices, you confirm that
you have the software and equipment that satisfies these requirements to enable you to access and retain
your statements and notices electronically.
Skip Payment Program and Other Special Terms.
From time to time, we may let you skip or reduce one or more monthly payments during a year (interest will
continue to accrue) or offer you other special features. If we do, we will advise you of the scope and
duration of the applicable skip or special feature. When the skip or special feature ends, your regular terms
will resume.
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Changes in This Agreement.
We can change this Agreement, including the annual percentage rate and any fees, and can add or delete
provisions relating to your Account or to the nature, extent and enforcement of the rights and obligations
you or we may have under this Agreement, all as permitted by applicable law. We will notify you of any
such change. Any change, addition or deletion to this Agreement, including any increase or decrease in
your APRs, will become effective at the time stated in our notice and will apply to those balances, including
new transactions, on your Account as described in our notice. The notice we send you may state that you
may notify us in writing within a specified time period that you do not wish to accept the changes, additions
and deletions we are making. You will be deemed to accept all the changes, additions and deletions
accompanying the notice and to ratify and confirm all the provisions of your Agreement and your
acceptance of all the changes, additions and deletions described in other notices previously sent to you if
1) you do not notify us that you do not agree to the change, addition or deletion in the time frame set forth
in the notice, or 2) you use the Card or Account after the conclusion of the specified time period.
Credit Performance.
Your Account was established based upon criteria which reflect your particular credit history. We will from
time to time review your credit performance. In addition to any other rights we have, if you do not maintain
your past level of credit performance, we may change some or all of the Account terms on your Account,
and if we do we will notify you as provided in this Agreement and in accordance with applicable law.
Credit Information.
You agree that we may request consumer credit reports from one or more credit reporting agencies in
connection with your application and the administration of your Account. You also authorize us to
exchange credit information concerning you or your Account with (and answer questions and requests
from) others, such as merchants, other lenders and credit reporting agencies.
Phone Calls/Electronic Communications.
In the regular course of our business, for quality control purposes, we may monitor and record phone
conversations made or received by our employees. Similarly, we may monitor and record e-mail or
conversations on our website between you and our employees. You agree that we will have such right with
respect to all phone conversations, e-mail or conversations between you and our employees, whether
initiated by you or any of our employees.
Refusal to Honor Card.
We are not responsible for refusals to honor your Card or Checks. And, except as otherwise required by
applicable law or regulation, we will not be responsible for merchandise or services purchased or leased
through use of your Account.
Irregular Payments and Delay in Enforcement
We can accept late payments, partial payments, checks and money orders marked "Paid in Full" or
language having the same effect without losing any of our rights under this Agreement. We can also delay
enforcing our rights under this Agreement any number of times without losing them. The fact that we may
at any time honor a Purchase, Check, Balance Transfer or Cash Advance in excess of your maximum
credit line does not obligate us to do so again.
Payments Made on Your Account
If you make a payment on this Account utilizing a check, you authorize us either to use the information
from your check to make a one-time electronic fund transfer from your checking/deposit account or to
process the payment as a check transaction. When we use information from your check to make an
electronic fund transfer, funds may be withdrawn from your bank account as soon as the same day you
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make your payment, and you will not receive your check back from your financial institution. For inquiries,
or to opt out of one-time electronic fund transfers, please call the number listed on the back of your card.
Liability for Unauthorized Use of Your Account.
If your Card or any Check(s) are lost or stolen or if you have reason to think someone may use your
Account without your permission, you must notify us at once. Please either visit the website on the back of
your Card and send us an e-mail or telephone us at the number on the back of your Card concerning the
loss or theft of your Card or Checks or the possible unauthorized use of your Account. Do not use the
Card, Account number or any Checks after they have been reported lost or stolen, even if they are found or
returned. You will not be liable for unauthorized use of the Account; however, you must identify for us the
charges that were not made by you or someone authorized by you and through which you received no
benefit. We may require you to provide us with certain information and to comply with our investigation
procedures. We may terminate or limit access to your Account if you have notified us or we have
determined that your Card or Checks may have been lost or stolen, or that there may be unauthorized
access to your Account.
Assignment.
We may at any time assign or sell your Account, any sums due on your Account, this Agreement or our
rights or obligations under this Agreement. The person(s) to whom we make any such assignment or sale
shall be entitled to all of our rights under this Agreement, to the extent assigned.
Governing Law.
THIS AGREEMENT AND YOUR ACCOUNT WILL BE GOVERNED BY THE LAWS OF THE STATE OF
DELAWARE AND, AS APPLICABLE, FEDERAL LAW.
Inquiries or Ouestions.
You may address any inquiries or questions which you have about your Account to Barclays Bank
Delaware, by visiting the website on the back of your Card and sending us an e-mail, writing us at Barclays
Bank Delaware, P.O. Box 8801, Wilmington, DE 19899-8801, or calling us at the number on the back of
your Card. If you telephone or email us instead of writing, you may lose certain rights the law gives you to
dispute billing errors.
Arbitration.
At the election of either you or us, any claim, dispute or controversy ("Claim") by either you or us against
the other, or against the employees, agents or assigns of the other, arising from or relating in any way to
this Agreement or your Account, or any transaction on your Account including (without limitation) Claims
based on contract, tort (including intentional torts), fraud, agency, negligence, statutory or regulatory
provisions or any other source of law and (except as specifically provided in this Agreement) Claims
regarding the applicability of this arbitration clause or the validity of the entire Agreement, shall be resolved
exclusively and finally by binding arbitration under the rules and procedures of the arbitration Administrator
selected at the time the Claim is filed. The Administrator selection process is set forth below. For purposes
of this provision, "you" includes any authorized user on the Account, and any of your agents, beneficiaries
or assigns; and "we" or "us" includes our employees, parents, subsidiaries, affiliates, beneficiaries, agents
and assigns, and to the extent included in a proceeding in which Barclays is a party, its service providers
and marketing partners. Claims made and remedies sought as part of a class action, private attorney
general or other representative action (hereafter all included in the term "class action") are subject to
arbitration on an individual basis, not on a class or representative basis.
Alternatively, you and we may pursue a Claim within the jurisdiction of the Justice of the Peace Court in
Delaware, or the equivalent court in your home jurisdiction (each a "Small Claims Court"), provided that
the action remains in that court, is made on behalf of or against you only and is not made part of a class
action, private attorney general action or other representative or collective action. Further, you and we
agree not to seek to enforce this arbitration provision, or otherwise commence arbitration based on the
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Page 8 of 8
same claims in any action brought before the Small Claims Court
The party initiating arbitration shall utilize the American Arbitration Association, www.adr.org, 950 Warren
Avenue, East Providence, Rhode Island, 02914, 1-866-293-4053 to administer the arbitration (the
"Administrator'). The Administrator provides information about arbitration, its arbitration rules and
procedures, fee schedule and claims forms at its web site or by mail as set forth above. The Administrator
will apply the rules and procedures in effect at the time the arbitration is filed. The Claim will be heard
before a single arbitrator, whose authority is limited exclusively to the resolution of Claims between you
and us and to providing an award effective only on behalf of you and/or us. The arbitration will not be
consolidated with any other arbitration proceedings. The Administrator shall resolve each dispute in
accordance with applicable law.
If you commence arbitration, you must provide us the notice required by the Administrator's rules and
procedures. The notice may be sent to us at Barclays Bank Delaware, P.O. Box 8801, Wilmington, DE
19899-8801. If we commence arbitration, we will provide you notice at your last known billing address. We
agree to honor your request to remove the action to a Small Claims Court, provided that we receive the
request within thirty days of the notice of commencement of arbitration. Any arbitration hearing at which
you appear will take place at a location within the federal judicial district that includes your billing address
at the time the Claim is filed. This arbitration agreement is made pursuant to a transaction involving
interstate commerce, and shall be governed by the Federal Arbitration Act, 9 U.S.C. §§ 1-16. Judgment
upon any arbitration award may be entered in any court having jurisdiction. No class actions joinder or
consolidation of any Claim with a Claim of any other person or entity shall be allowable in
arbitration, without the written consent of both you and us. In the event that there is a dispute about
whether limiting arbitration of the parties' dispute to non-class proceedings is enforceable under applicable
law, then that question shall be resolved by litigation in a court rather than by the arbitrator; and to the
extent it is determined that resolution of a Claim shall proceed on a class basis, it shall so proceed in a
court of competent jurisdiction rather than in arbitration.
We will pay, or reimburse you for, all fees or costs to the extent required by law or the rules of the
arbitration Administrator. Whether or not required by law or such rules, if you prevail at arbitration on any
Claim against us, we will reimburse you for any fees paid to the Administrator in connection with the
arbitration proceedings. In addition, in any arbitration that you elect to file that could be heard in Small
Claims Court in your jurisdiction, we will pay the filing fees and other arbitration fees above the cost of filing
in that Small Claims Court. If you are required to advance any fees or costs to the arbitration Administrator,
but you ask us to do so in your stead, we will consider and respond to your request.
This arbitration agreement applies to all Claims now in existence or that may arise in the future except for
Claims by or against any unaffiliated third party to whom ownership of your Account may be assigned, in
which case this arbitration agreement will apply only if you or the third party chose arbitration. This
arbitration agreement survives the termination of the Cardmember Agreement or the Account relationship,
including your payment in full, and your filing of bankruptcy. Nothing in this Agreement shall be construed
to prevent any party's use of (or advancement of any claims, defenses, or offsets in) bankruptcy or
repossession, replevin, judicial foreclosure or any other prejudgment or provisional remedy relating to any
collateral, security or property interests for contractual debts now or hereafter owed by either party to the
other under this Agreement.
ARBITRATION WITH RESPECT TO A CLAIM IS BINDING AND NEITHER YOU NOR WE WILL HAVE
THE RIGHT TO LITIGATE THAT CLAIM THROUGH A COURT. IN ARBITRATION YOU AND WE WILL
NOT HAVE THE RIGHTS THAT ARE PROVIDED IN COURT INCLUDING THE RIGHT TO A TRIAL BY
JUDGE OR JURY AND THE RIGHT TO PARTICIPATE OR BE REPRESENTED IN PROCEEDINGS
BROUGHT BY OTHERS SUCH AS CLASS ACTIONS OR SIMILAR PROCEEDINGS. IN ADDITION, THE
RIGHT TO DISCOVERY AND THE RIGHT TO APPEAL ARE ALSO LIMITED OR ELIMINATED BY
ARBITRATION. ALL OF THESE RIGHTS ARE WAIVED AND ALL CLAIMS MUST BE RESOLVED
THROUGH ARBITRATION.
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Pricing Supplement to the
Cardmember Agreement
The information provided below In this Pricing Supplement, along with the Cardmember Agreement(s)
and the Addendum to the Cardmember Agreement (as applicable) reflects certain account pricing and
terms that were available to certain applicants that applied for and were approved for certain credit card
accounts on the last business day of the calendar quarter that ended on 12131/2009. These account terms
may not be available after that date.
These documents are being provided to you for informational purposes only. If you apply and are
approved for a credit card account with us, your actual account terms will be based on the terms of the
offer available at the time that you applied, what you are approved for and your actual Cardmember
Agreement will be the agreement sent to you when your account Is first opened.
Interest Rates and Interest Charges
Annual Percentage Rate 3.74% to 22.99% APR. This is a variable rate that equals the Prime Rate plus a
(APR) for Purchases margin from 0.49% to 19.74%, (this corresponds to a current DPR of 0.0102% -
0.0630%) (this corresponds to a current MPR of 0.3117% - 1.9158% for residents
Iowa at the time of account opening (if applicable)).
APR for Balance 3.74% to 22.99% APR. This is a variable rate that equals the Prime Rate plus a
Transfers margin from 0.49% to 19.74%, (this corresponds to a current DPR of 0.0102% -
0.0630% (this corresponds to a current MPR of 0.3117% - 1.9158% for residents 1
Iowa at the time of account opening (if applicable)).
APR for Cash Advances 14.99% to 23.24% APR. This is a variable rate that equals the Prime Rate plus a
margin from 11.74% to 19.99%, (this corresponds to a current DPR of 0.0411 % -
0.06370/6) (this corresponds to a current MPR of 1.2492% - 1.9367% for residents
Iowa at the time of account opening (if applicable)).
Penalty APR and When it Up to 30.24%, based on your creditworthiness. This is a variable rate that equals the
Applies Prime Rate plus a margin from 0% to up to 26.99% (this corresponds to a current DPR
of 0.0000% - 0.0828%) (this corresponds to a current MPR of 0.0000% - 2.5200% for
residents of Iowa at the time of account opening (if applicable)).
This APR may be applied to your account if you:
1. Make a late payment;
2. Go over your credit limit;
3. Make a payment that is returned; or
4. Do any of the above on another account you have with us.
How Long Will the Penalty APR Apply? If your APRs are increased for any of these
reasons, the Penalty APR will no longer apply to existing balances if you make the nex
6 consecutive payments when due. The Penalty APR will apply to other balances
indefinitely.
Paying Interest Your due date is at least 23 days after the close of each billing cycle. We will not char)
you interest on purchases if you pay your entire balance by the due date each month.
We will begin charging interest on balance transfers, checks and cash advances on thi
transaction date.
Minimum Interest Charge If you are charged interest, the charge will be no less than $2.00 ($0.50 for residents o
Iowa at the time of account opening).
Fees
Annual Fee 1 $0 to $496
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Transaction Fees:
• Balance Transfer
• Cash Advance
The purchase of a
money order,
travelers' check,
foreign currency,
lottery ticket,
gambling chips, or
wire transfer is a
cash advance
• Foreign Transaction
Penalty Fees:
$0 to $195 for each authorized user
Either $0 -10 or 0 - 4% of the amount of each transfer, whichever is greater. We may
from time to time offer you lower Transaction Fees on Balance Transfers and Checks.
Either $0 - $10 or 0 - 4% of the amount of each cash advance, whichever is greater.
Either $0 - $10 or 0 - 4% of the amount of each transaction, whichever is greater.
0 - 3% of each transaction in U.S. dollars.
• Late Payment $0 - 39.95 depending upon the state that you live in at the time of account opening anc
in some cases depending upon the balance on the account on the day the fee is
assessed.
• Over-the-Credit-Line $0 - 39
• Returned Payment $0 - 39.95 depending upon the state that you live in at the time of account opening.
Additional Check Related
Fees
. Check Stop Payment I $0 - 39.95 depending upon the state that you live in at the time of account opening.
Fee
. Returned Check Fee I $0 - 50 depending upon the state that you live in at the time of account opening.
Variable Rate Information.
The following applies to any APR on your Account that varies with the market based on the Prime Rate. The
APRs on your Account correspond to a Daily Periodic Rate ("DPR") or a Monthly Periodic Rate ("MPR") which is
applicable only to residents of Iowa at the time of Account opening. The applicable DPRs/MPRs on your Account
equal 1/365th (or 1/12t' for residents of Iowa at the time of Account opening) of the sum of 1) the applicable Prime
Rate, 2) plus the margin(s) listed above for each Purchase, Balance Transfer, or Cash Advance balance or the
margin listed above if a Penalty APR applies. The "Prime Rate" used in determining the APRs in each billing cycle
will be the highest rate published in the Money Rates column of The Wall Street Journal on the last business day
of each month. An increase or decrease in the Prime Rate will cause a corresponding increase or decrease to
your variable rates on the first day of the billing cycle that begins in the same month in which the applicable Prime
Rate is published. There is no limitation on the amount of any increase. Any such increase or decrease will cause
a corresponding increase or decrease in the amount of interest assessed and possibly in the amount of the
Minimum Payment Due. If The Wall Street Journal does not publish the U.S. Prime Rate, or if it changes the
definition of the U.S. Prime Rate, we may substitute another index. As of 12/31/2009 the Prime Rate was 3.25%.
How the Penalty APR may apply to your Account.
The APRs on your Account may be increased each time, on this Account or any other account you may have with
us, if you fail to make a payment to us when due, you fail to pay at least the minimum payment due, you exceed
your credit line, or you make a payment that is not honored by your bank (each, a "Penalty Event'). If we increase
the APRs on your Account, we will notify you in advance of the increase. The Penalty APR that will be applied to
your Account will be determined based on our review of your credit history at the time of our review (including
your credit performance with other creditors). Our notice to you will include the effective date of the APR increase
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and the balances to which the Penalty APR will be applied. If the Penalty APR is applied to your account, it may
continue to apply to new transactions indefinitely. However, the Penalty APR will cease to apply to transactions
made before the penalty rate notice was sent if, after the Penalty APR goes into effect, you make the next six
consecutive minimum payments in a row when due. If you do not make these six consecutive minimum
payments, the Penalty APR may continue to apply to new and existing transactions indefinitely.
How We Will Calculate Your Balance:
We use a method called "daily balance (including new purchases)". To determine the amount of the interest to be
charged on your Account we first calculate the "Balance Subject to Interest Rate" separately for Purchases, for
Balance Transfers, and for Cash Advances. We apply the applicable DPR to each of the applicable daily balances
for i) Purchases, ii) Balance Transfers and iii) Cash Advances. The daily balances for Purchases, for Balance
Transfers and for Cash Advances are each calculated separately and determined as follows: We take the
beginning balances for each transaction type on your Account each day, including any interest calculated on the
previous day's balance, add to the respective balances any new transaction, subtract any payments or credits and
make any other applicable adjustment(s). This Agreement provides for compounding of interest. A credit balance
is treated as a balance of zero. If you multiply the "Balance Subject to Interest Rate" for each balance category as
shown on your monthly billing statement by the number of days in the billing period and then multiply each sum by
the applicable DPRs, the results will be the interest assessed, except for minor variations caused by rounding. We
may from time to time offer you "introductory," "special" or "promotional" APR offers. If any are in effect on your
Account we will separately identify the balances to which such offers apply on your monthly billing statement.
These separate balances and the related interest will be calculated in the same manner as described above.
How We Will Calculate Your Balance (For Residents of Iowa at the Time of Account Opening):
We use a method called "average daily balance (including new purchases)". To determine the amount of the
interest to be charged on your Account we first calculate the "Balance Subject to Interest Rate" separately for
Purchases, for Balance Transfers, and for Cash Advances. We apply the applicable Monthly Periodic Rate to the
average daily balances of i) Purchases, ii) Balance Transfers, and iii) Cash Advances. The average daily
balances for Purchases, for Balance Transfers, and for Cash Advances are calculated separately and determined
as follows: We take the beginning balances for each balance category on your Account each day, add to the
respective balances any new transaction, subtract any payments or credits and make any other applicable
adjustment(s). A credit balance is treated as a balance of zero. Then we take the sum of all daily balances and
divide by the number of days in the billing period to determine the average daily balance. If you multiply the
"Balance Subject to Interest Rate" for each balance category as disclosed on your monthly billing statement by
the applicable MPRs, the results will be the interest assessed, except for minor variations caused by rounding.
We may from time to time offer you "introductory" "special" or "promotional" APR offers. If any are in effect on
your Account we will separately identify the balances to which such offers apply on your monthly billing statement.
These separate balances and the related interest will be calculated in the same manner as described above.
Accrual of Interest and How to Avoid Paying Interest on Purchases.
On Purchases, interest begins to accrue as of the transaction date. However, you may avoid paying interest on
Purchases in any given billing cycle if you pay your Current Balance in full by the Payment Due Date each month.
For Balance Transfers, interest will accrue from the day we send the Balance Transfer to the payee. For Checks,
interest will accrue on the day the payee accepts the Check. For Cash Advances, interest will accrue from the day
you take the Cash Advance. The amount of the Minimum Interest Charge (or "Minimum Charge") that will be
assessed on your Account in any billing cycle in which you owe interest is disclosed in the Account Summary
Table.
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Addendum to the Cardmember Agreement
This Addendum to the Cardmember Agreement reflects variations to our standard form credit card
agreement in effect on the last business day of the previous calendar quarter that ended on
12131/2009. Our standard Cardmember Agreement(s) is supplemented with pricing information
reflected in the document(s) titled "Pricing Supplement" and other terms and/or features that may
vary between the different types of credit card accounts that we offer as reflected in the below
"Addendum to the Cardmember Agreement". These documents are provided to you for
informational purposes only. These account terms may not be available after the above date. If you
apply and are approved for a credit card account with us, your actual account terns will be based
on the terms of the offer available at the time that you applied and your Cardmember Agreement will
be the agreement sent to you when your account is first opened.
The following provision is to be added at the and of the last sentence of the "Credit LinelAuthorized
Usage" paragraph in our standard Cardmember Agreement and is applicable to a credit card accounts that
do not have a preset spending limit:
"Because your Account has no pre-set spending limit, we may permit you from time to time at our discretion
to make certain charges that cause your outstanding balance to exceed your revolving credit line. These
charges will be evaluated based on account performance, other credit accounts with us, and your
experience with other creditors. If we authorize these charges, you must pay, with your Minimum Payment
Due, the amount by which your balance exceeds your revolving credit line, including amounts due to
Purchases, Cash Advances, Interest charges, Fees, or other charges."
The calculation of the Minimum Payment Due each month is based on the account type that the applicant
applied for and the applicant's creditworthiness. The following paragraphs reflect these two options and will
be reflected in the Cardmember Agreement assigned at account opening.
"Your Minimum Payment Each Month.
Each billing cycle, you must pay at least the Minimum Payment Due shown on your monthly statement by its
Payment Due Date. If the Statement Balance shown on your monthly statement is less than $5, your
Minimum Payment Due will be that Statement Balance amount. Otherwise, if your Statement Balance is
greater than $5, your Minimum Payment Due will be the total of 1) 1 % of the Principal Balance (defined as
the total Statement Balance minus interest charges, Returned Payment Fee, and any Late Payment Fee,
that are incurred during the current billing cycle), plus 2) interest charges accrued during the current billing
cycle, plus 3) any Returned Payment Fee (and if we so elect, any Late Payment Fee), incurred during the
current billing cycle, plus 4) if we so elect, any amount past due or amount over your credit line at the time of
billing. In certain instances your Minimum Payment Due may be less than your total Fees and Interest
assessed in that billing cycle. At any time you may pay more than the Minimum Payment Due up to the full
amount you owe us."
"Your Minimum Payment Each Month.
Each billing cycle, you must pay at least the Minimum Payment Due shown on your monthly statement by its
Payment Due Date. If the Statement Balance shown on your monthly statement is less than $15, your
Minimum Payment Due will be that Statement Balance amount. Otherwise, if your Statement Balance is
greater than $15, your Minimum Payment Due will be the total of 1) 1 % of the Principal Balance (defined as
the total Statement Balance minus interest charges, Returned Payment Fee, and any Late Payment Fee,
that are incurred during the current billing cycle), plus 2) interest charges accrued during the current billing
cycle, plus 3) any Returned Payment Fee (and if we so elect, any Late Payment Fee ), incurred during the
current billing cycle, plus 4) if we so elect, any amount past due or amount over your credit line at the time of
billing. In certain instances your Minimum Payment Due may be less than your total Fees and Interest
assessed in that billing cycle. At any time you may pay more than the Minimum Payment Due up to the full
amount you owe us."
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
FILFO-OFF ICE
}r. THE PROTE ONOTAo t,
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
2911 JUL 2U PPS 1: 5
CUMBERLAND COUNTY
PENNSYLVANIA
Barclays Bank Delaware
vs.
Mohamed A. Ahrar
Case Number
2011-5630
SHERIFF'S RETURN OF SERVICE
07/15/2011 09:20 AM - Timothy Reitz, Corporal, who being duly sworn according to law, states that on July 15, 2011
at 0920 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Mohamed A. Ahrar, by making known unto himself personally, at The Cumberland
County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania
17013 its contents and at the same time handing to him personally the said true and correct copy of the
same.
MOTHY R Z, DEPUTY
SHERIFF COST: $38.00
July 18, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
David. R. Galloway
Attorney I.D. No. 87326 Counsel for Plaintiff
FULTON FRIEDMAN & GULLACE, LLP ! P :0TH 0 i410 TAR 1
130B Gettysburg Pike
Mechanicsburg, PA 17055 I A'J'i' 24 r
Telephone - 717-610-3337 ,
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
Plaintiff
MOHAMED A AHRAR
Defendant(s)
TO THE PROTHONOTARY:
NO. 11-5630civil
CIVIL ACTION - LAW
PRAECIPE FOR JUDGMENT
Please enter Judgment, pursuant to the attached Stipulation, in favor of Plaintiff and
against Defendant MOHAMED A AHRAR in the amount of $7,290.63, plus court costs.
FULTON, FRIEDMAN, & GULLACE LLP
Signature: li
David R. Galloway
Counsel for Plaintiff
326
I, David R. Galloway, an authorized agent of FULTON FRIEDMAN & GULLACE, LLP,
hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in
the Post Office at Camp Hill, PA, first class mail, postage prepaid, addressed as follows:
MOHAMED A AHRAR
6320 ANTILLES CT
MECHANICSBURG PA 17050-5249
FULTON, FRIEDMAN, & GULLACE LLP
Signature:
David R. (
Counsel fa
FFG file#: 274773
PA_JUDGT ON ST[P
a34 %N. oo ?A aN?
Ck4 9 gs i'6
p.Wa?ly77 y 4
w-la ? '-eA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
Plaintiff NO. 11-5630civil
CIVIL ACTION - LAW
MOHAMED A AHRAR
Defendant(s)
NOTICE OF JUDGMENT
Notice is hereby given that a Judgment in the above-captioned matter has been entered against you
in the amount of $7,290.63, plus court costs.
NOW, , 20JUDG EN E D AS A ; E.
ProthcU„Qt Cl ivision
By:
Deputy
I hereby certify that the name and address of the proper person to receive this notice under Pa. R.
Civ. P. 236 is:
MOHAMED A AHRAR
6320 ANTILLES CT
MECHANICSBURG PA 17050-5249
FULTON, FRIEDM ffll,- c GULLACE LLP
Signature: ' L.?
David R. Galloway #873 6
130B Gettysburg Pike
Mechanicsburg, PA 170 5
(866) 563-0809
Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
PA_JUDGT ON STIP
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
Plaintiff NO. 11-5630
V.
CIVIL ACTION - LAW
MOHAMED A AHRAR
Defendant
STIPULATION AND AGREEMENT FOR ENTRY OF JUDGMENT
AND NOW, comes Plaintiff, by and through its attorneys, FULTON FRIEDMAN &
GULLACE, LLP, and Defendant who stipulate and agree as follows:
1. Pa. R.C.P. 1037(c) provides that in all cases, the Court, on motion of a party, may
enter an appropriate judgment against a party upon admission.
2. Defendant agrees and admits that Judgment should be entered in favor of Plaintiff
in the amount of $7,290.63, plus costs of suit.
3. The parties agree that the Prothonotary, upon Praecipe of Plaintiff, may enter
Judgment pursuant to this Stipulation without issuance of a Rule to Show Cause, and without
further proceedings or notice.
By •? By
MO AMED A AHRAR David R Gallow
6320 ANTILLES CT Attorney I.D. No. 87326
MECHANICSBURG PA 17050-5249 130B Gettysburg Pike
Defendant, pro se Mechanicsburg, PA 17055
Attorney for PI intif
I ) Z. it
Date: ?S r ?? ? ??? Date:
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-5630 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BARCLAYS BANK DELAWARE Plaintiff (s)
From MOHAMED A AHRAR - 6320 Antilles Ct., Mechanicsburg, PA 17050-5249
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
METRO BANK - 65 Ashland Avenue, Carlisle, PA 17013
All accounts including but not limited to all savings, checking and other accounts, certificates of
deposit, notes receivables, collateral, pledge, documents of title, securities, and coupons.
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $5,790.63 L.L. $30
Interest
Atty's Comm % Due Prothy $2.25
Atty Paid $175.50 Other Costs
Plaintiff Paid
Date: 2.1/12
David D. Buell, Prot onotary
(Seal) (-BY:
Deputy
REQUESTING PARTY:
Name David R. Galloway, Esquire
Address: Fulton Friedman & Gullace, LLP
130B Gettysburg Pike
Mechanicsburg, PA 17055
Attorney for: Plaintiff
Telephone: 866-563-0809
Supreme Court ID No. 87326
INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
Plaintiff NO. 11-5630civil
vs. CIVIL ACTION - LAW
MOHAMED A AHRAR
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 TO 3149
To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $7290.63.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against, MOHAMED A AHRAR --1
6320 ANTILLES CT
MECHANICSBURG PA 17050-5249 J?
Defendant (s); M rT rq -
(3) and against METRO BANK ---
located at 65 ASHLAND AVENUE
CARLISLE PA 17013 '
Garnishee(s);
(4) and index this writ r:
(A) against MOHAMED A AHRAR
Defendant (s) and
(B) against, METRO BANK
as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows: (Specifical ly
describe property) ***Garnish Only ***
You are directed to attach the property of the Defendant(s) not levied upon in the possession of METRO BA NK,
Garnishee(s)
All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables,
collateral, pledges, documents of title, securities, and coupons.
Judgment Amount due: $7290.63
Less Payments: $(1500.00)
Interest from Judgment Date: $0.00
Total: $5790.63
Prothonotary Fee:
Sheriff Fee:
Costs to be added:
David R. Gallowa #87326
Fulton Friedman Gullace, LLP/ Counsel for Plaintiff
Attorneys in the actice of Debt Collection
130B Gettysburg 'ke
Mechanicsburg, PA 17055 -S
Tel #: (866) 563-0809 Fax: (585) 546-4241 Q' Oo?C ?
FFG file #NN274773uu uB .,? 2 "/ C $?
00
q2. on
14- o a
clue Cv.
PA/PA_BANF::WRI'i , y?
W/'/ j "C ?x /SS v e 50 ?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE ? Confessed Judgment
19 Other
v Docket No. 11 -5630civil
MOHAMED A AHRAR
6320 ANTILLES CT
MECHANICSBURG PA 17050-5249
Judgment Amount $7290.63
Less Payments $(1500.00)
Interest: $0.00
Total: $5790.63
Atty's Comm: $
Costs: $
PRAECIPE FOR ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract or
account based on a confession of judgment, but if it does , it is based on the appropriate original proceeding filed
pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of attachment in the above matter to the Sheriff of Cumberland County, for debt, interest and
costs, directing attachment against METRO BANK , as Garnishee, for the following property of the defendant(s):
All accounts, including but not limited to, all savings, checking and other accounts, certificates of
deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and all other property of
the defen ant(s) in the possession, custody or control of ?-l
Date , ?' ?L Signature:
Print name: David Gallo
Address: 130B Gettvsbur2fPike
Attorney for: BARCLAYS BANK DELAWARE
Telephone: (866) 563-0809
Supreme Court ID No:#87326
FFG File # 274773
PA BANKPW RITC
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff '? ?` ? i ? •= N;.
,, „
?4?,?tiir o? 4uu+Grrl??r r ;: fs 4 Q?? ?}{C',
Jody S Smith +? s
Chief Deputy 2nB
Richard W Stewart
Solicitor ERIFF
PCNNSYLVAN
Barclays Bank Delaware Case Number
VS.
Mohamed A. Ahrar 2011-5630
SHERIFF'S RETURN OF SERVICE
02/08/2012 11:40 AM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on February
8, 2012 at 1140 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Mohamed A. Ahrar, in the hands, possession, or control of
the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle, Cumberland County, Pennsylvania,
17013 by handing to Maria Theodoratos, Assistant Store Manager, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on February 9, 2012 to Mohamed A. Ahrar at
6320 Antilles Court, Mechanicsburg, PA 17050.
SO ANSWERS,
February 09, 2012 RON R ANDERSON, SHERIFF
0% in VIM
utshall, Deputy
!c; CQUl'. "SkAe Sr'e;;,7. I erecsefl. I;i;:.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
VS.
Plaintiff
CIVIL ACTION - LAW
No.11-5630civil
MOHAMED A AHRAR c? r-31 -V.
c--
Defendant(s) ?p
rn _
rn
INTERROGATORIES TO GARNISHEE
-
To: METRO BANK F C: c
65 ASHLAND AVENUE
CARLISLE PA 17013 --
PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING
INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY
REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND
FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S
EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S).
IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE
A. You are required to file answers to the following interrogatories within twenty (20) days after service
upon you. Failure to do so may result in judgment against you.
B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ Execution was issued.
C. "You" means the main office and all branch offices, representatives, employees and agents of your
organization.
D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment
which is in your possession, custody or control is attached, including all property of the Defendant(s) which
comes into your possession thereafter.
E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented
as you receive further or additional information.
F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate
is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate
is made, and the reason the exact information cannot be furnished.
G. Where knowledge or information in possession of a party is requested, such request includes knowledge
of the party's agents, representatives, and attorneys.
FFG file #: 274773
1111111111111111111111111 IN 111111111111111111111111111111111
PA/PA_BANKINTERROGS
INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - MOHAMED A AHRAR
SS# - ***-**-9046
1. At the time you were served or at any subsequent time did you owe the defendant(s) any money
or were you liable to the defendant(s) on any negotiable or other written instrument, or did the
defendant(s) claim that you owed the defendant(s) any money or were liable to the defendant(s) for any
reason? Defendant has account xxxxx4656 held individually with a balance of $38.61
Defendant did not receieve $300 exemption
2. At the time you were served or at any subsequent time was there in your possession, custody or
control or in the joint possession, custody or control of yourself and one or more other persons any
property of any nature owned solely or in part by the defendant(s)?
no
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or in part by the defendant(s) or in which the defendant(s) held or claimed any
interest?
no
4. At the time you were served or at any subsequent time did you hold as fiduciary any property in
which the defendant(s) had an interest?
no
5. At any time before or after you were served did the defendant(s) transfer or deliver any property
to you or to any person or place pursuant to your direction or consent and if so what was the consideration
therefor?
no
6. At any time after you were served did you pay, transfer or deliver any money or property to the
defendant(s) or to any person or place pursuant to the defendant's direction or otherwise discharge any
claim of the defendant(s) against you?
no
7. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant(s) have funds on deposit in an account in which funds are deposited electronically
on a recurring basis and which are identified as being funds that upon deposit are exempt from execution,
levy or attachment under Pennsylvania or federal law? If so, identify each account number and state the
amount of funds in each account, and the entity electronically depositing those funds on a recurring basis.
no
PA/PA_BANKINTERROGS
DEFENDANT(S) - MOHAMED A AHRAR
SS# - ***-**-9046
8. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including
any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42
Pa.C.S. § 8123? If so, identify each account.
no
9. Please identify all accounts not listed in your answer to Interrogatory No. 7, the amount of funds
in each account, whether the funds are deposited electronically on a recurring basis and the entity
electronically depositing those funds. If the defendant(s) maintains any of these accounts jointly with
any other person, or persons, give their name, address and relationship to defendant.
10. Are there any attorney's fees or processing fees charged by you against the defendant(s) or
account(s) of the defendant(s) for the completion of this answer? If yes, outline the exact amount of any
fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer.
11 . Please provide the name, business address and business telephone of the person answering these
interrogatories.
Jennifer Hilbish - Levy Specialist
3801 Paxton St
Harrisburg PA 17111
12. Please provide the address and elephone number where future court documents pertaining to this
case can be served on Garnishee.
see above
FULTON, FRIEDMAN, & GULLACE LLP
David R. Galloway 87326
(866) 563-0809
Counsel for Plaintif
Attorneys in the Practice of Debt Collection
Please return your Answer to Interrogatories to counsel for Plaintiff at: 28 E. Main Street, Suite 500,
Rochester NY 14614.
FFG File #: 274773
PA/PA BANKINTERROGS
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating
to unsworn falsifications to authorities, that he/she is Jennifer Hilbish
(Name)
Levy Specialist of Metro Bank, garnishee herein,
(Title) (Company)
that he/she duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and
belief.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE : ❑ Confessed Judgment
: ❑x Other
: Docket No. l 1-5630civil
Judgment Amount $7290.63
: Less Payments $(1500.00)
MOHAMED A AHRAR : Interest: $0.00
6320 ANTILLES CT : Total: $5790.63: Atty's
MECHANICSBURG PA 17050-5249 Comm: $
: Costs: $
v
PRAECIPE FOR WRIT OF
TO THE PROTHONOTARY:
The undersigned hereby certifies that the below does not arise out of a retail installment sale,
contract or account based on a confession of judgment, but if it does , it is based on the appropriate
original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of
1974 as amended.
Issue writ of attachment in the above matter to the Sheriff of Cumberland County, for debt,
interest and costs, directing attachment against METRO BANK , as Garn is for the following
property of the defendant(s): 4S 11516wd Ave. Ci.rlts(C
All accounts, including but not limited to, all savings, checking d t ; ` e �f�. ccounts, certificates of
deposit, notes receivables, collateral, pledges, documents of title, securitie c `po 's and all other property of
the defendant(s) in the possession, custody or control of Garnishee.
Date
FFG File # 274773
Signature:
Print name: Michael B. Volk, Esq.
Address: 6 Kacey Court, Suite 203
Mechanicsburg, PA 17055
Attorney for: BARCLAYS BANK DELAWARE
Telephone: (866) 563-0809
Supreme Court ID No:#88553
1111111 11111 11111 MO MEMO 111111111 11111111 11111 1111II11111
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THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite 100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
BARCLAYS BANK DELAWARE
Vs.
MOHAMED A. AHRAR
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 11-5630 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against MOHAMED A. AHRAR, 6320 ANTILLES CT.,
MECHANICSBURG, PA 17050 Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
METRO BANKGARNISHEE(S), as garnishee, 65 ASHLAND AVENUE, CARLISLE, PA 17013 (Specifically
describe property) and to notify the garnishee that ALL ACCOUNTS, INCLUDING BUT NOT LIMITED TO,
ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES
RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND
ALL OTHER PROPERTY OF THE DEFENDANT(S) IN THE POSSESSION, CUSTODY OR CONTROL
OF GARNISHEE.
(a) an attachment has been issued;
(b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the
defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof;
(c) the attachment shall not include
(i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any
funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law.
(ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed
$10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being
funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law.
(iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If
1
multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as
determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general
exemption provided in 42 Pa.C.S. § 8123.
(3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added
as a garnishee and is enjoined as above stated.
Amount Due $5,790.63 Plaintiff Paid
Interest Law Library
Attorney's Comm. % Due Prothonotary $2.25
Attorney Paid $285.88 Other Cost
Date: 11/6/14
David D. Buell, Prothonotary
By:
Deputy
REQUESTING PARTY:
Name : MICHAEL B. VOLK, ESQUIRE
Address: FULTON, FRIEDMAN & GULLACE, LLP
6 KACEY COURT, SUITE 203
MECHANICSBURG, PA 17055
Attorney for: PLAINTIFF
Telephone: 866-563-0809
Supreme Court ID No. 88553
MAJOR EXEMPTIONS UNDER PENNSYLVANIA
AND FEDERAL LAW
1. $300 statutory exemption
2. Bibles, school books, sewing machines, uniforms and equipment
3. Most wages and unemployment compensation
4. Social Security benefits
5. Certain retirement funds and accounts
6. Certain veteran and armed forces benefits
7. Certain insurance proceeds
8. Such other exemptions as may be provided by law
2
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
A
`BARCLAYS BANK DELAWARE
Plaintiff CIVIL ACTION - LAW
vs.
MOHAMED A AHRAR
Defendant(s)
No.11-5630civil
al\SA5 f -c)
INTERROGATORIES TO GARNISHEE
To: METRO BANK
65 ASHLAND AVENUE
CARLISLE PA 17013
PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING
INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE 1.S HEREBY
REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND
FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S
EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S).
IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE
A. You are required to file answers to the following interrogatories within twenty (20) days after service
upon you. Failure to do so may result in judgment against you.
B. The tern "Defendant(s)" means the individual(s) or entity against whom the Writ Executpn was issued.
C. "You" means the main office and all branch offices, representatives, employees and agents of your
organization.
D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment
which is in your possession, custody or control is attached, including all property of the Defendant(s) which
comes into your possession thereafter.
E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented
as you receive further or additional information.
F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate
is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate
is made, and the reason the exact information cannot be furnished.
G. Where knowledge or information in possession of a party is requested, such request includes knowledge
of the party's agents, representatives, and attorneys.
FFG file # 274773
111111111111111111111111111111111111111111111111111111 I I 111111111
PA/PA_BANKINTERROGS
INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - MOHAMED A AHRAR
SS# - ***-**-9046
1. At the time you were served or at any subsequent time did you owe the defendant(s) any money
or, were you liable to the defendant(s) on any negotiable or other written instrument, or did the
defendant(s) claim that you owed the defendant(s) any money or were liable to the defendant(s) for any
reason?
No Accounts
2. At the time you were served or at any subsequent time was there in your possession, custody or
control or in the joint possession, custody or control of yourself and one or more other persons any
property of any nature owned solely or in part by the defendant(s)?
no
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or in part by the defendant(s) or in which the defendant(s) held or claimed any
interest?
no
4. At the time you were served or at any subsequent time did you hold as fiduciary any property in
which the defendant(s) had an interest?
no
5. At any time before or after you were served did the defendant(s) transfer or deliver any property
to you or to any person or place pursuant to your direction or consent and if so what was the consideration
therefor?
no
6. At any time after you were served did you pay, transfer or deliver any money or property to the
defendant(s) or to any person or place pursuant to the defendant's direction or otherwise discharge any
claim of the defendant(s) against you?
no
7. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant(s) have funds on deposit in an account in which funds are deposited electronically
on a recurring basis and which are identified as being funds that upon deposit are exempt from execution,
levy or attachment under Pennsylvania or federal law? If so, identify each account number and state the
amount of funds in each account, and the entity electronically depositing those funds on a recurring basis.
no
PA/PA_BANHINTERROGS
DEFENDANT(S) - MOHAMED A AHRAR
'SS# ***-**-9046
8. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including
any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42
Pa.C.S. § 8123? If so, identify each account.
no
9. Please identify all accounts not listed in your answer to Interrogatory No. 7, the amount of funds
in each account, whether the funds are deposited electronically on a recurring basis and the entity
electronically depositing those funds. If the defendant(s) maintains any of these accounts jointly with
any other person, or persons, give their name, address and relationship to defendant.
no
10. Are there any attorney's fees or processing fees charged by you against the defendant(s) or
account(s) of the defendant(s) for the completion of this answer? If yes, outline the exact amount of any
fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer.
no
11 . Please provide the name, business address and business telephone of the person answering these
interrogatories.
Jennifer Hilbish 717-412-6163
3801 Paxton St
Harrisburg PA 17111
12. Please provide the address and telephone number where future documents pertaining to this
case can be served on Garnishee.
Fulton, Friedman
Michael B. Volk, Esq. #88553
(866) 563-0809
Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
Please return your Answer to Interrogatories to counsel for Plaintiff at: 28 E. Main Street, Suite 500
Rochester, New York 14614.
FFG File #: 274773
PA/PA_BANKINTERROGS
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating
to unsworn falsifications to authorities, that he/she is Jennifer Hilbish
(Name)
Levy Specialist
(Title)
of Metro Bank, garnishee herein,
(Company)
that he/she duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and
belief.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson FI-D'OFFICE
Sheriff at cwn»*r/OF THE PROMO -NOTARY
4.00
Jody Smith
S r/�mno�n *=/. °,
Ch�fDoou�m/�mu��� Q�y/�W�
�'
RichnrdVVStewart CUMBERLAND Ty
Solicitor OFFICE QF THE ERIFF PENNSYLVANIA
Barclays Bank Delaware
vs.
Mohamed A. Ahrar
Case Numbe
2011-5630
SHERIFF'S RETURN OF SERVICE
11/102014 10:42 AM - Brian BarrickDeputy, who being duly sworn according to Iaw, attached as herein commanded
all goods, chattels, rights, debts, credits, and monies ofthe Defendant, inmehands.pouseooion.urconro|
of the within named garnishee, Metro Bank, 20 Noble Boulevard., Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to Terry Glass, customer service rep, personally three copies of
interrogatories together with three true and attested copies of the Writ of Execution and made the contents
there of known to her.
The wrof execution and notice to defendant was mailed on November 19, 2014 to Mohamed hrar at
632OAntilles Court, Mechanicsburg, PA17OSO'524S.
BRIAN BARRI K, DEPUTY
SO ANSWERS,
November 19, 2014 R'NN R ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BARCLAYS BANK DELAWARE
Plaintiff NO. 11-5630civil
v.
MOHAMED A AHRAR
Defendant(s)
TO THE PROTHONOTARY:
CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE ATTACHMENT
Please discontinue the Writ of Execution filed against Garnishee METRO BANK in the referenced matter without
prejudice.
Respectfully Su
By:
Michael B. Volk, Esq. • 88553
Fulton, Friedman & Gullace, LLP
Counsel for Plaintiff
6 Kacey Court, Suite 203
Mechanicsburg, PA 17055
(866) 563-0809
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office,
first class mail, postage prepaid, addressed as follows:
MOHAMED A AHRAR
6320 ANTILLES CT
MECHANICSBURG PA 17050-5249
METRO BANK
65 ASHLAND AVENUE
CARLISLE PA 17013
Michael B. Volk, Esq.
Attorney ID #88553
FFG file #: 274773
11111111111111111111111111111111111111111111111111111111111111111
PA/PA_PRAEDISATT
0 jvj 41q'5
apd p�
Ck-# a3-708/