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Home My WebLink About06-6479 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff VS. SONIA A KHOURI Defendant No: COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05284392 C E Pit VOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff VS. Civil Action No SONIA A KHOURI Defendant COMPLAINT AND NOTICE TO DEFEND 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 in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CACH, LLC is a corporation with offices at 370 17TH ST.,SUITE 5000 DENVER , CO 80202 2. Defendant is adult individual(s) residing at the address listed below: SONIA A KHOURI 5 NORTHWATCH LN MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 4559546262615650 . 4. Defendant made use of said credit card and has a current balance due of $6506.74 , as of September 30, 2006 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000% per annum on the unpaid balance from September 30, 2006 . A copy of Plaintiff's STATEMENT OF ACCO UNT is attached hereto, marked as Exhibit 111" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , SONIA A KHOURI , INDIVIDUALLY , in the amount of $6506.74 with continuing interest thereon at the rate of 6.000% per annum from September 30, 2006 plus costs. James C "Warmbrodt,4Z524 WELT WEINBERG & REIS CO., L.P.A. 436 S e th Avenue, Suite 2718 Pitts ur , PA 15219 (412 43 -7955 FAX: 412 338-7130 052 439 C E Pit VOC This law firm is a debt collector atte4ptiAg to collect this debt for our client and any information obtaine 11 be used for that purpose. BKP084 RECOVERY-1 INCOMING TRANSACTIONS FROM NAM Control # 006139 05118/86 K MEN ACCOUNTS 05119106 PAGE 570 *?a***e**?e*x?e;tx;nexax?x*****a*??n*?otx*aoHf ?****?*x;ot*??x******?******x?**???nt********aaE*n*ins**xx**?***x?*x*?*xae*x?xxxaat* UNA # 5284392 Internal # 5411091 Client # 08618002 Client Acct # 4559546262615650--- ___________________________ -----?tx KHOURI; SONIA A SS # 160-60-5958 CACH, LLC Hone Phone # (717) 697-4242 5 NORTHNATCH Lk MECHANICSBURG , PA 17050- County: - N/A - Not availabl Acct Type: Collection Collection Type: Attorney Office: Cleveland Section: EAttorny Loan Type: Misc: Loan Class: Loss Reason: No reason given Collector Code: Agency Code: COO Sent to Agency:05119106 Agency Fee Code: Charge-off date: 04129105 Charge-off Other: 0.00 Charge-off Principal: 0.00 Loan #: 5411091 Loan Date: 08129101 Loan Ant: 0.00 Int Start Date: 05119106 Int Thru Date: 05119106 Int Rate: 11.99 Last payment date: 09/16104 Last payment ant: 175.00 CHARGES PAID BALANCE PRINCIPAL: 6,366.50 0.00 6,366.50 INTEREST.-. 0.00 0.00 0.00 COSTS_.: 0.00 0.00 0.00 OTHER....: 0.00 0.00 0.00 TOTAL..: 6,366.50 0.00 6,366.50 COMMENTS: CARD PLACE OF EMPLOYMENT: A P CARPET FAMILY COMPANY Mork Phone #: ( ) - NOTES: BRIG CRDTR: PROVIDIAM BANK VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsifications to authorities, that he is Kenneth D. Urban, Authorized Agent of CACH, LLC, plaintiff herein, that he is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. „Wa« SA ? n AZ c V _ c ?..YS _ I IN THE COURT OF COMMON PLEAS OG CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC Plaintiff VS. SONIA A WOURI Defendant ANSWER TO COMPLAINT No: 06-6479 Civil Term CIVIL ACTION LAW 1. Agreed 2. Agreed 3. Agreed 4. Denied Defendant asked in writing with certified mail to close said account, because of unauthorized use, on November 20, 2004. Current balance at that time was $3208.00, exhibit A 5. Denied Plaintiff kept account open against defendant's wishes 6. Denied They are not entitled to the additional interest, since November 20, 2004. 7. Denied Plaintiff was allways willing to settle the account in a reasonable way, but plaintiff never responded. WHEREFORE, Defendant, Sonia A Khouri, was always willing to settle said account, but Providian Processing Services never had good will, intent or faith. They had failed to protect personal and classified information, where alot of charges on the defendants account, were caused by identity theft. Defendant respectfully submits to this honorable court to enter judgement in favor of defendant, and dismiss Plaintiffs inflated case, where defendant is willing to settle this case in a reasonable fashion. Respectfully submitted, Date: // Sonia A Khouri VERIFICATION The undersigned hereby states that he/she is the attorney of the defendant, Sonia A Khouri. He/She verifies that the statements made in the foregoing Answer To Complaint are true and correct to the best of his/her knowlesdge, 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 Pa.C.S Section 4904, relating to unswom falsification to authorities. Date: Sonia A Khouri Ex 41 BIT A Sonia Khouri 5 Northwatch Lane Mechanicsburg, PA 17050 Tel: 717-648-9377 Wednesday, November 17, 2004 To: Providian Processing SVCS. P.O. Box 660487 Dallas, TX 75266-0487 Re: Account number : 4559-5462-6261-5650 To Whom It May Concern: This letter is in regard to the closure of my account. As you know, I have recently closed my account. The main reason for the closure, is due to unauthorized charges on my card. I am willing to discuss an amicable conclusion to this situation, for I believe I am the victim of identity theft. If you are willing to make a settlement on this account, please feel free to contact me at, 717-648-9377, or write to the above address. Sincerley, Sonia Khouri . 0, T i t G z o 4 UN N c:? r,y'l ?,,i?l p r r G, ? t rl r G .. C r a? a S, /- =- G N ? -pG`o-rt CUR F? _ cr m to ."ter X C ? w? O N ?.- 'O t? "-? ??, > ??_.. . ?; , ??i : =ai c -?; rv s.re r ' ,. ? _ • • t ` +.,' f j? {.,,.? w SHERIFF'S RETURN - REGULAR CASE NO: 2006-06479 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS KHOURI SONIA A RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT 6- NOTICE was served upon KHOURI SONIA A the DEFENDANT , at 1552:00 HOURS, on the 8th day of November , 2006 at 5 NORTHWATCH LANE MECHANICSBURG, PA 17050 SONIA A K:HOURI by handing to 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 7.92 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 35.92 11/09/2006 WELTMAN WEINBERG REIS Sworn and Subscibed to By: before me this day Deputy She iff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC., Plaintiff, vs. SONIA A. KHOURI, Defendant. Case No.: 06-6479 Civil Term TYPE OF PLEADING: MOTION FOR JUDGMENT ON THE PLEADINGS FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Patrick Thomas Woodman, Esquire Pa. I.D. #34507 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR # 05284392 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC., Plaintiff, Case No.: 06-6479 Civil Term vs. SONIA A. KHOURI, Defendant. MOTION FOR JUDGMENT ON THE PLEADINGS AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co., L.P.A., and hereby files this Motion for Judgment on the Pleadings and respectfully moves this Court pursuant to Pennsylvania Rule of Civil Procedure 1034 for judgment on the pleadings. In support thereof, Plaintiff avers as follows: 1. This action arises out of the accumulation of credit card debt by defendant. 2. On or about November 11, 2006, Plaintiff filed a Complaint against Defendant, Sonia A. Khouri, seeking $6,506.74 with continuing finance charges thereon at the rate of 6% per annum from September 30, 2006, plus costs. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and made a part hereof. 3. Attached to the Complaint was Verification from an authorized representative of Plaintiff verifying the accuracy of the amount sought. See Exhibit "A". 4. On or about January 17, 2007, Defendant filed an Answer admitting she applied for and used the card while denying the amount due. A true and correct copy of the Answer is attached hereto as Exhibit "B" and made a part hereof. 5. Under Pennsylvania Rule of Civil Procedure 1029(b), the averments of the pleading to which a response is required are deemed admitted when not denied specifically. 6. Defendant's Answer contains no New Matter. 7. Under Pennsylvania Rule of Civil Procedure 1032(a), "a party waives all defenses and objections which are not presented either by preliminary objection, answer or reply..." 8. The pleadings are closed and time exists to dispose of this Motion before trial. 9. No genuine issue of material fact exists as to Plaintiff's claim. 10. Plaintiff is entitled to judgment in its favor as a matter of law on the amount sought in the Complaint. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order directing Judgment on the Pleadings in favor of Plaintiff and against Defendant, Sonia A. Khouri seeking $6,506.74 with continuing finance charges thereon at the rate of 6% per annum from September 19, 2006, plus costs as in the Complaint, or, in alternative, the $3,208.00 as admitted in Defendant's Answer. Respectfully Submitted: WELTMAN, WEINBERG & REIS, CO., L.F.A. By: rc? I,t c,•?G -AAM&A U)MOM.a Patrick Thomas Woodman, Esquire PA I.D.#34507 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 0 \ e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. SONIA A KHOURI Defendant No: COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05284392 C E Pit VOC EXW?BIT ,y IN THE COURT OF CONmON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. Civil Action No SONIA A KHOURI Defendant COMPLAINT AND NOTICE TO DEFEND 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 in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CACH, LLC is a corporation with offices at 370 17TH ST.,SUITE 5000 DENVER , CO 80202 . 2. Defendant is adult individual(s) residing at the address listed below: SONIA A KHOURI 5 NORTHWATCH LN MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 4559546262615650 . 4. Defendant made use of said credit card and has a current balance due of $6506.74 , as of September 30, 2006 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000g per annum on the unpaid balance from September 30, 2006 . A copy of Plaintiff's STATEMENT OF ACCO UNT is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , SONIA A KHOURI , INDIVIDUALLY , in the amount of $6506.74 with continuing interest thereon at the rate of 6.000W per annum from September 30, 2006 plus costs. James C "Warmbrodt,42524 WEL WEINBERG & REIS CO., L.P.A. 436 S e th Avenue, Suite 2718 Pitts ur , PA 15219 (412 43 -7955 FAX: 412 338-7130 052 439 C E Pit VOC This law firm is a debt collector att0ptj,4g to collect this debt for our client and any information obtaine v411 be used for that purpose. W084 RECOVERY-1 INCOMING TRANSACTIONS FROM RAN Control # 006139 05118106 HEN ACCOUNTS 05!19106 PAGE 570 ??????a*? x?**???????*???*??**a??x???***x*???ot?s??t?***?***?*x*??*?xe*??*x* ?x*?*??*??a???xxroE*e?**aoeE? 9UA # 5284392 Internal # 5411091 Client # 08618002 Client Acct # 4559546262615650 RHOURI: SONIA A SS # 160-60-SM CACH, LLC Hone Phone # (717) 697-4242 5 HURTMATCH UK MECHANICS= , PA 17050- County: - N1A - Not availabl Acct Type: Collection Collection Type: Attorney Office: Cleveland Section: EAttorny Loan Type: Rise: Loan Class: Loss Reason: No reason given Collector Code: Agency Code: COs Sent to Agency:05119106 Agency Fee Code: Charge-off date: 04129105 Charge-off Other: 0.00 Charge-off Principal: 0.00 Loan U 5411091 Loan Date: 08129101 Loan Ant: 0.00 lot Start Date: 05119,106 lot Thru Date: 05119106 Int Rate: 11.99 Last paynent date: 09116104 Last paynent ant: 175.00 CHARGES PAID BALANCE PRINCIPAL: 6,366.50 0.00 6,366.50 INTEREST.: 0.00 0.00 0.00 COSTS....: 0.00 0.00 0.00 OTHER....: 0.00 0.04 0.00 TOTAL..: 6,366.50 0.00 6,366.50 CONNENTS CARD PLACE OF EMPLOYMENT: A P CARPET FAMILY COMPANY Rork Phone #: ( ) - NOTES: ORIG CRDTR: PROVIDIAN BANK VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsifications to authorities, that he is Kenneth D. Urban, Authorized Agent of CACH, LLC, plaintiff herein, that he is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. -? This law firm is a debt toilector attempting to collect this;debt for our client I and any inibrma#iori obtained *- -b6 uged for i iat purpose.` 11N3q9`, WWRO 15a SONIA A kF OUR1 De landant IN THE COURT OF COMMON PLEAS OO CUMI3ERL14NO COUNTY, PENNSYLVANIA Page 1 of l No; 06x3479 Civil Term CIVIL ACTION LAW 1. Agreed 2. Agreed 3. Agreed 4 Denied 1)0%ndsrrt a* W in *TWng whh cetrtified mail to class said 00= 4 beOM . unmAhdrt d use, an Noveml er 20, 2004, Current balenoe at tW dme m $3208,00, exh,*A 5. denied P#eijmW kqA account qm N** defendantfs wishes 8. Denied They are not+eniltbd lp thQ addltianai interest since November Z0, x004. 7. Oenied Pialydff W" siiways Wov in Seek 1tm scmnt in a raesamble wsy, but pl near responded. EXTIT CACH, LLC Plairitlff vs. http://records.ccpa.net/weblink_public/ImageDisplay.aspx?cache=yes&sessionkey=WLIm... 1/16/2007 Page 1 of 1 WHEREIrORE, DBandant 9onla A fturl, was skMvp wi' N is sett said sooount, but PrgMISM Prooeseirp BS?V t rwsver had goad wiN, Inl6ent or falh. They hod failed lo pmaW psrsar and ciaseltlml irrb n tlot?, where Slot of ONW9 cm the daknds m socouK wen auesd by identity to t. Defendant mWecMy wbmlts bo this tmmblf mn to ember ju* m d in favor of dsFeM@M,-Snd dismiea Plaindfla Inklmd me, *ftv dsfsndant Is willing to was this cam In a rye wmb* hehion, RaepsWuily submilled, 112 V,102 - -'s 0, -, -,- - ; C? ? http ://records.cepa.netlweblink_publiclImageDisplay. aspx?cache=yes&sessionkey=WLIm... 1/16/2007 Page 1 of 1 The under*q W hereby etatu M WOO Is the sttorney d the deienr wg. Sores A Khour H*Mhe verifies that the d dw ents Enede h the tor%pinq Answer To Complwnt are Ow end comp to the beet of I Whor knoWesdge. khm adw, and WW, bnW upon infbrtnedm pmvlded by the dabndent The unde"nW understands that M" #WMw is henh ors rmde subject W the pan** of iS PLCS Seaton 4904, reldnq to unswom falslficslfon to authoriuee. pew, 12L, 71 LP Santa aun http://records.ccpa.netlweblink_publicllmageDisplay.aspx?cache=yes&sessionkey=WLIm... 1/16/2007 Page 1 of 1 Exyx-BIT A Sonia Khoud 5 Northwatch Lana MwAanksbuM, PA 47050 Teh 717-04a.0377 Wednesday, November 17, 2004 rta pmVidian pmessing Svcs. P.Q. Scot 864457 Dallas, TX 762W-0487 Re; Account number : 4559-W24=14550 To Whom It May Ccm*m: This IWw Is In nosed tc the closure of my account As you know, I have remly ckaeed ray a mu, main Hawn for the obsurs, Is due bo woumort?ecl chargae an my card. I am willing to discuss an amicable oonclusbn to this skustIM fbr I behave I am !ha vWm of WOW If you ere w 1MV to mike it act marl an #vW account, plevee %W Mw to conho t me A 7174464 writs to to above address. Slncerlay, Sonle Khourt http://records. ccpa.netlweblink_publicllmageDisplay. aspx?cache=yes&sessionkey=WLIm... 1/16/2007 ' •1 i • o ?,Im • • • 1116/2007 lay•aSPX??ache=yes&sessionkey- „__..?,,.-ris.ccpa•ne?`jteblink.?ublicilmageDisP i r r r p ? +?{? Jlk ,0 C. . 4 V x?cache--yes&sessionkey-WL,I n etlweblink_publicllmageDlsplay asp ac r.Cl]a.n 1/16/2()07 Page 1 of 1 r=' C; http:/irecords.ccpa.netlweblink_public/ImageDisplay.aspx?cache=yes&sessionkey=WLIm... 1/16/2007 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, he is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to him by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for ding of this pleading, and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge, information and belief. ozl ate/ '? `• dJ44,A . tae ZZ;004rkxV-? Date Patrick Thomas Woodman, Esquire CERTIFICATE OF SERVICE Sonia A. Khouri 5 Northwatch Lane Mechanicsburg, PA 17050 The undersigned certifies that a true and correct copy of Plaintiff s Motion for Judgment on the Pleadings and Brief in Support of Motion for Judgment on the Pleadings was served on the 5-4''4day of M&,, k , 20 0 7 , by first class, U.S. Mail, postage-prepaid, to the Defendant at the address listed above. Patrick Thomas Woodman, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC., Plaintiff, Case No.: 06-6479 Civil Term VS. SONIA A. KHOURI, Defendant. ORDER OF COURT AND NOW, to-wit, this day of , 2007, upon Plaintiff's Motion for Judgment on the Pleadings, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that said Motion is GRANTED and Judgment is entered in favor of Plaintiff for $6,506.74 with continuing finance charges thereon at the rate of 6% per annum from September 30, 2006. BY THE COURT J. _ ? r ?-,.? -- j - ?? -"Y> ?'F ara °t? ?? ` OS-2-9-'4 34 2 PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CAPTION OF CASE (entire caption must be stated in full) CA C q > LL- L, (Plaintiff ) VS. S o Nn on,` nAri (Defendant) No. Civil 07q # 200b 1. State matter to be argued (i.e., plain iff's motion for new trial, defendant Is Pta'n?rl t , dy r?c denurrer to complaint, etc. ?Jr1 f't'? J U !'?G'? D ? Wellman Weinberg & Revs 2. Identify counsel who will argue case 2718 Koppers Bldg. (a) for plaintiff: 436 7th Ave, Address: PlllWgh, PA 15219 A (412) 434.1955 (b) for defendant : ?N -1e A Address: S ?t?/ ?rTh /NtT,h M 3. I will notify all parties in writing within two days that this case has been listed for argument. Vef . 4. Argument Court Date: 4Y 0,7 Attorney for 1-91, fir, CD i w fr IN THE ?OURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff I No. 06-6479-CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE SONIA A. Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: PATRICK THOMAS WOODMAN,ESQUIRE PA I.D. # 34507 WELTMAN,WEINBERG &REIS,CO. L.P.A. 436 SEVENTH AVENUE, SUITE 2718 PITTSBURGH,PA 15219 (412)434-7955 Fax: 412-338-7130 WWR#5284392 1 I y ? IN THE CACH, LLC Plaintiff vs. SONIA A. KHOUIR Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 06-6479-CIVIL TERM TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue the above captioned matter upon the records of the Court with prejudice and mark the cost WELTMAN, WEINBERG & REIS CO., L.P.A. By: a'-04 a"'e PATRICK THOMAS WOODMAN,ESQUIRE PA I.D. # 34507 WELTMAN,WEINBERG &RE1S,CO. L.P.A. 436 SEVENTH AVENUE, SUITE 2718 PITTSBURGH,PA 15219 (412)434-7955 Fax: 412-338-7130 WWR#5284392 Sworn to and subse Before me the ar/? Day of AUGUST, IF 7' NetiNtisl ,' 44m 4 Jena6, NotA, , city of Pte. AQei;, -'Ljo; y my obn aft w E)Oms jut ? 21, 20'i() Member. }-eradylva6la Assoclation of "031 les ? C Q :C7 7 E go: r-n