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Home My WebLink About06-4268IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. No. 06 - 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 Plaintiff VS ELIE-JOE M KHOURI 5 NORTHWATCH LN MECHANICSBURG PA 17050-1775 Defendant(s) CIVIL ACTION - LAW Filed on behalf of: Plaintiff, MBNA AMERICA BANK, N.A. Counsel of record for this party: Date: (?Df? L_4? ??, Amy F. Doyle #97062 / Daniel F. Wolfson #20617 Philip C. Warh is #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 136036891 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff VS ELIE-JOE M KHOURI Defendant(s) :No. :CIVIL ACTION - LAW 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 South Bedford Street Carlisle, PA 17013- 717-249-3166 CCP Notice to Defend W&A File No. 136036891 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff VS ELIE-JOE M KHOURI Defendant(s) NOTICIA :No. :CIVIL ACTION - LAW USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dial despu6s 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. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE 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 INFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013- 717-249-3166 CCP Notice to Defend W &A File No. 136036891 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, tif :No. VS. ELIE-JOE M KHOURI Defendant(s) CIVIL ACTION - LAW COMPLAINT AND NOW, this 07 day of July, 2006, comes the Plaintiff, MBNA America Bank, N.A., by and through its attorneys, the law firm of Wolpoff & Abramson, L.L.P., and files the within Complaint and in support avers as follows: Plaintiff, MBNA AMERICA BANK, N.A. , is a National Banking Association organized under the National Banking Act with principal place of business situated at P.O. BOX 15718, WILMINGTON, DELAWARE 19850. 2. Defendant, ELIE-JOE M KHOURI, is an adult individual with a last known address of 5 NORTHWATCH LN, MECHANICSBURG, CUMBERLAND COUNTY, PA 17050-1775. 3. It is averred that Defendant was issued an open-end credit card account by Plaintiff. This account was created through a written contract between Plaintiff and Defendant, accepted by Defendant when he signed and utilized the credit card account. A true and correct copy of the Credit Card Agreement governing this account is attached hereto as Exhibit "A." 4. The Credit Card Agreement contains a binding Arbitration provision providing that any claim or dispute between Defendant and Plaintiff would be subject to binding arbitration before the National Arbitration Forum (NAF). This Credit Card Agreement also recites that since the agreement involved an instrumentality of interstate commerce, that the Federal Arbitration Act, 9 U.S.C. §§1-16 CCP Cmplt - MBNA W & A File No. 136036891 (FAA) governed the Agreement and that following disposition through the NAF, judgment may be entered in any state court having jurisdiction. 5. At all relevant times material hereto, Defendant has been regular user of said charge card for the purchase of products, goods and/or for obtaining services and/or funds. 6. By virtue of Defendant's use and maintenance of this credit card in connection with his purchases of goods, and services, he became bound to all of its contractual terms, which clearly included an arbitration agreement. Therefore, there is a valid agreement to arbitrate and Defendant consented to the NAF having jurisdiction over this claim. Defendant received monthly statements which accurately state all purchases and payments made during the month, interest charges imposed on the unpaid balance, and the amount due. A summary of the account showing the balance due and owing is incorporated herein and marked as Exhibit "B". 8. Defendant did not object to the above-mentioned Statements of Account submitted by Plaintiff to Defendant. 9. Defendant has made sporadic and irregular payments, if any, which have been applied to the outstanding balance of this account. 10. As of the date of the within Complaint, the remaining balance due, owing and unpaid on Defendant's credit account, as a result of charges made by said Defendant and/or any authorized users is the sum of $5,513.53. 11. Pursuant to the Credit Agreement and/or applicable Pennsylvania law, any unpaid and/or delinquent balances on said account shall continue to bear interest at the rate of / $ °0. 12. The amount of interest which has accrued on the aforementioned account is the sum of $1,405.72. CCP Cmplt - MBNA W & A File No. 136036891 13. Plaintiff has retained the services of the law firm of Wolpoff & Abramson, L.L.P. in the collection of the amount due from Defendant. 14. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Wolpoff & Abramson, L.L.P. in the collection of the collection of the amounts due from Defendant incident to the within action, the Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 15. The amount of attorney's fees incurred in this matter is the sum of $827.02. 16. Despite reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 17. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 18. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. CCP Cmplt - M 3NA W & A File No. 136036891 WHEREFORE, Plaintiff, MBNA America Bank, N.A., respectfully requests this Honorable Court enter judgment in favor of Plaintiff and against Defendants, in the amount of $5,513.53, plus interest in the amount of $1,405.72, plus attorney's fees in the amount of $827.02, plus costs of this action and any other relief as this Court deems proper and just. Respectfully submitted, L Date: 7 ?? v4 e/" ? z Amy F. Doyle #87 2 / Daniel F. Wolfson #20617 Philip C. Warholi #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - MBNA 4 W & A File No. 136036891 VERIFICATION The undersigned hereby states that he/she is the attorney for the Plaintiff, MBNA America Bank, N.A., who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. Date: '7 16 P" l Amy F. oyle #8702 / Daniel F. Wolfson #20617 Philip C. Warholi #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - MBNA W & A File No. 136036891 Exhibit "A" 1 F Vow a IIfIf -I i N a:..:''.•• ' . •a Ifill I 11fL111 11.111 1, is aj g $ fig a a g pr fit s ? ?s a a s? { i air a g +? a I Q _ It t= o fill s fill t .131 Iff all fill! I. f: s ? it ell fnlffs ??. !f1-8 ¦ 134 I -rA i I 0111 9 f I f [it; 111,1( to i ; f to ! t n ?M G ,law " its o l at ti's SRI$ lit. I aj J ill J1111 41111 lit all a ? it r Ia,?is t ?r 3 all '' '_ _I N!fl,1111 i if, It Ii I 411 . 11 ill, it I Qr Ulu a fj fill H 111 a x .4 3 fit Zito 3s , f ?s as will I I r ; RA l_x, S 1 ILI ?, fell igIN Lilt . Q I191i VIA a # Q ? ? ZH C . :,. all a .9 sill if 9 1; 12 t R T Z ::F a N v Exhibit "B" ••FICHINFOI •• Date 02/04/05 Account 5490990074586197 Mode L •-Nxt + CLIENT NO 001730 MBNA ACCT#5490990074586197 BALANCE --$5,513.53 ****** PRIMARY DEBTOR ***** C/O DATE 01/01/69 LSTPY DT 08/22/04 *M-ACCT-NO *M-REC-TYPE*M-CUST-TYPE*M-LAST-NAME 5490990074586197 A I KHOURI *M-FIRST-NAME *M-ADDR-1 *M-ADDR-2 ELIE-JOE M 5 NORTHWATCH IN *M-CITY *M-COUNTY *M-STATE*M-ZIP *M-HOME-PH MECHANICSBURG PA 170501775 7176974242 *M-WORK-PH *M-DOB *M-POE-NAME 7175401910 01/30/81 *M-POE-ADDR *M-LOAN-TYPE*M-LENDING-OFFICER LMO1 OM0001 *M-BANK-CODE*M-BRANCH-CODE*M-CALL-CODE*M-RECOVERER-CODE*M-DEALER-CODE LHRK 074 *M-CO-RSN*M-ACCT-STATUS*M-INT-RATE*M-RECEIPT-DATE*M-CONTACT-DATE*M-CO-DATE PCD 0000 01/31/05 02/02/02 01/01/69 *M-LAST-PYMT-DATE*M-CO-AMT *M-ASSOC-COST*M-ACCRUED-INT*M-CUR-BAL 08/22/04 $5,513.53 $.00 $.00 $5,513.53 *M-NET-PRIN *M-NET-COST *M-NET-INT *M-COMMENT-1 $5,513.53 $.00 $.00 DBAAAMMM12345 *M-COMMENT-2 001 20050131 0000045 -MODE L=LFT R=RGT W=WRP Next File -64 ??. !* to u-i Gj w y ` 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. NO. 06-4268 CIVIL TERM PLAINTIFF VS. ELIE-JOE M KHOURI CIVIL ACTION - LAW DEFENDANT 1. Agreed 2. Agreed ANSWER TO COMPLAINT Denied Contract signed was not an open ended credit card. Credit line was limited to $4500.00. (exhibit A) 4. Denied Defendant never at any time signed an arbitration agreement nor does the plaintiff provide any proof of such claim. Defendant has no knowledge of a binding arbitration agreement that was signed on the original agreement date. 5. Denied Defendant disputed charges as of October 25, 2004 and demanded a closure of his account due to misuse and unauthorized charges. (exhibit B) MBNA denied our repeated demand for a 1411 investigation and never provided a full account of signed receipts of the alleged charges by defendant. 6. Denied NAF arbitration is funded by credit card companies, thus they are biased and prejudiced in this case. Furthermore, NAF arbitration refused and did not acknowledge any of our claims and records. 7. Decried Plaintiff did not change address and continued mailing credit card materials and letters to old address. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 8. Denied Defendant did object in a certified registered letter dated October 25, 2004, and asked to close his account because of unauthorized charges. (exhibit B) 9. Agreed Defendant made payments in good faith, and asked MBNA to initiate an investigation in an effort to resolve the unauthorized charges. 10. Denied The balance due at the time defendant demanded closure of his account was closer to $3900.00, interest accrued on this amount after October 25, 2004, is not valid. 11. Agreed But not if defendant demanded closure of his account in a certified registered letter, because of identity card theft, 16. Denied Defendant has been HARRASED with repeated taped phone calls at midnight, early morning, during dinner time and especially Sunday mornings. Also, defendant had asked to be called on his cell phone provided to plaintiff on October 25, 2004. 17. Denied Plaintiff did not at any time show any interest in resolving this matter. WHEREFORE, Defendant, Elie-Joe M Khouri respectfully submitted his case to this honorable court and enter judgment in favor of defendant, where he has made every effort to resolve this case, but plaintiff denied repeated requests to investigate unauthorized purchases. Plaintiff MBNA had failed to change defendants address. Plaintiff MBNA showed no good intent to resolve this matter and failed to protect personal and classified information, and was negligent in handling a valuable credit card, by repeatedly mailing new credit card renewals to old address. Respectfully submitted, Date:[ D6-?-° Elie-Joe M VERIFICATION The undersigned herby states that he/she is the attorney of the defendant, Elie-Joe M Khouri. He/she verifies that the statements made in this foregoing Answer To Complaint are true and correct to the best of his/her Imowledge, information, and belief, based upon information provided by the Defendant. The undersigned understands that false statements herein are made subject to the penalties of 18 P&C.S. Section 4904, relating to unworn falsification to authorities. Hate: Elie- in Khouri 19 Ahirmi ` Alumn Association ? EX HI BIT A PrAwix XBNA ANUICA P.O. BOX 15137 wlLNiNGToN, DE 19886-5137 Fwnommr+aorl, so 1.800-7894005 Mt ' , wwlA+ww?bNpwwerOwbraa - Mawr PLATINUM PLUS- r.. w•• creel ?r• -W CARDHOLOER SIMCE 2002 SW 9900 7458 8197 1 PAM WDLEDAIE MOV84.0$$CE TOTAI. 03/30/05 $5,617.70 WrILAMMBMPAM81 OM AYCIA RXXC6® aErACK Trrvn6rpw ? AEruw w1x yArRMtr 3 new ELIE-JOE M KHOURI 5 NORTHWATCH LN MECHANICSBURG PA 17050-177505 C0' ere. Lp c H 04 0056177000081900000549099007458619T p14N1 wewpiens ar. ago"" owharOwiftAwilbbb w SW 9900 7458 6197 $4.800.00 28 03/02/05 $619.00 03/30/05 N ow' O"M 7Fwa om MA AH 2006 STATEMENT C1wpu Lf9i ? PURCHASES AND AD&AIST E NTS r0 1 i 02/23 02/28 5513 MC C LATE FEE FOR PAYMENT DUE,Q2 TOTAL FOR BILLZNB CYCLE FROM 02/03/2006 TFR01 03/02/2005 19.00 $19.00 $0.00 OUR RECORDS SHOP YOUR ACCOUNT IS PAST DUE AND YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS UPORTANT NEWS SUMS RFOFTBAIENOTIOW IWALME1EMM$POMW R n9twasrww HFyr?t, at Cwda !+)dtM AdanaN (y PwalwraN AgnL6wt? ?y1yy 9111EC$CMM8l8 P19 (y Na?6Y91w Tkbl PatC49AwerE 219.00 CbiwBP%wwt $219.00 $5,531.51 $1.11 $0.00 $19.00 $85.17 $1.01 $5,612.71 Told Lassie P4rwt or $629.00 Calm passed fee Cash Advances A. BALANCE TRANSFERS. CHECKS -0.0547M OLY S. ATM. BANK ................. 0.054767% OLY C. PURCHASES ...................0.084736% DLY '',1' fHW Y + "Olft 66??e?tw ar.rarrrw?N?'awilra.irlt+/.M Fwewefp911w9 PMWCIi E9 • MM?RaiM?ra?l?Ml/aWitirt.ii 19.98% 19.99% 16.98% RRIMMUA18PM9CR AMNIA, PERC11MiAI ERATE 19.98% AaWrMBiasA?wl /YrwMA9AMrr C1wg1a1 PI.FAAF 9FF RPVPARF A31F PM 3APOWANT WAWM AIATM USEOIO Wr016#Mkbwbaarwtegiib al$0.00 *01100HT "It" MGyadWs9, $824.5, Hy9-w3WM ?Mbb WuMAMB"pA.60R1119/.REoff=0E $5.231.96 1• • Ha4ti?y-- ..r..wt?4 .Ar1r$+?• RrLMeo?.?f 1?A ?90yA. WISL!IM_ATON DE 2114 51Z 280 0200 0000 00 5490 9900 7458 6197 PAGE i OF 1 EX H T B I7 g Elie-Joe Khouri 5 Northwatch Lane Mechanicsburg, PA 17050 10252004 MBNA AMERICA P.O. BOX 15137 WILMINGTON, DE 19886-5137 RE: Account # 5490 9900 7458 6197 To Whom It may Concwn This letter is in regard to the closure of my account. As you know, l love recently closed my account dim a very grave mistake made by your company. I recently found out that my credit card has been used by someone other then myself. The statements have been continuously seat to my old address, 6200 Mifflin Ave, Harrisburg PA 17111, even after I notified you of my change of address. I have flied notifying you abort this issue, and I have not been able to get any help fi+an your company on this matter. 1 am willing to discuss an amicable conclusion to this meter. I believe I am responsible for some money owed on this account, but not the total. This I believe is another case of identity theft. Please feel foe to call me at 717-648-9367, or write to the above address. Sincerely, Elie-Joe Khouri r 6?v N C FTI? °n _ 1 SIT, CJ) J Y - - ? r : Q , b m [") A co -< SHERIFF'S RETURN - REGULAR CASE NO: 2006-04268 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MBNA AMERICA BANK N A VS KHOURI ELIE-JOE M DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KHOURI ELIE-JOE M the DEFENDANT , at 1020:00 HOURS, on the 3rd day of August , 2006 at 5 NORTHWATCH LN MECHANICSBURG, PA 17050-1775 by handing to SONIA KHOURI, MOTHER 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: So Answers: Docketing 18.00 ? Service 19.36 Postage .39 Surcharge 10.00 R. Thomas Kline .00 47.75? 08/04/206 WOLPOFF & ABRAMSZON Sworn and Subscibed to By: before me this day of A.D. i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. : NO. 4268 CIVIL TERM 2006 V. ELIE-JOE M. KHOURI RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: I PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Andrew C. Spears, Esquire f , couTel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions),is (are) at issue. 2. The claim of the plaintiff in the action is? $ 7,746.27 + costs The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, la?zl Andrew C. Spears ORDER OF COURT AND NOW, , 19 , in consideration of the foregoing petition, Esq., Esq., and , Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, P.J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A., Plaintiff VS. ELIE-JOE M. KHOURI, Defendant NO. 4268 CIVIL TERM 2006 CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Andrew C. Spears, Esquire, do hereby certify that I served a copy of Plaintiff's Praecipe for Appointment of Arbitrators, upon the Pro-Se Defendant, by First Class Mail, 1? Postage Pre-Paid, a copy thereof on this day of January, 2007, to: ELIE-JOE M. KHOURI 5 NORTHWATCH LANE MECHANICSBURG, PA 170 Andrew C. Spears ID NO.87737 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (717) 303-6700 7 ,Ay j ih, 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. NO. 4268 CIVIL TERM 2006 V. ELIE-JOE M. KHOURI RULE 1312-1. The Petition for Appointment of Arb t rators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Andrew C. Spears, Esquire , cou el for the plaintiff/defendant in the above action (or actions), respectfully represents that: 4 1. The above-captioned action (or actions),is (are) at issue. 2. The claim of the plaintiff in the action is $ 7,746.27 + costs The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, Andrew C. Spears ORDER OF COURT AND NOW, &VnUot"W 7, in consideration of the , foregoing petition, L Esq., ?Y Esq., and , Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By th ourt, ?-- P.J. BLED -0;--HCE OF THE fi'r` ?' ' ? aY 20JQ 7 A 19 N 8' 2 3 culllvl? ??? co MBNA AMERICA BANK, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ELIE-JOE M. KHOURI, DEFENDANT 06-4268 CIVIL TERM ORDER OF COURT AND NOW, this 4O-h, day of April, 2007, the appointment of a Board of Arbitrators in the above-captioned case, IS VACATED and James D. Hughes, Esquire, Chairman, shall be paid the sum of $50.00. ? James D. Hughes, Esquire Court Administrator ded :sal y pai 07 4-11 , 0 .L_ .?., 'r- ?,: ,: `; :1 .? "} - - -- _ ?' 4 ' . t-- i_t _ __ ?? c-? _" C'?-2 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff VS ELIE-JOE M KHOURI Defendant(s) No. 06-4268 Civil Term CIVIL ACTION - LAW PRAECIPE TO SETTLE AND SATISFY Please mark the above-captioned action as settled, satisfied and discontinued. Respectfully Submitted, By: Date: Amy F. Doy e 87062 / Daniel F. Wolfson #20617 Philip C. Warholi 41 / David R. Galloway #87326 i yn M. Chippie #87852 7_3 a ah E. E h a s z #86469 o e 259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff -/Cc: FRANCIS A. Zulli P.O. Box 1121 Harrisburg, PA 171081121 W&A File No. 136036891 Cbrx OD N "^ s MBNA AMERICA BANK, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ELIE-JOE M. KHOURI, DEFENDANT 06-4268 CIVIL TERM ORDER OF COURT AND NOW, this 101-L- day of April, 2007, the appointment of a Board of Arbitrators in the above-captioned case, IS VACATED and James D. Hughes, Esquire, Chairman, shall be paid the sum of $50.00. By the Cquft, Edgar B. Bayley, J. James D. Hughes, Esquire A Court Administrator . lei :sal µ .?? ?? 0-0p'4 r