Appellant's Appendix - Philip D. Stern

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RECEIVED MONDAY 5/14/2012 3:56:13 PM 9194845 IV\A.URICE H PRESSLER (1W0-2C02) SHELDON H PRESSLER GERARD J FELT STEVEN P IVtCABE LAWRENCE J IVtDERMOTT. JR PRESSLER AND PRESSLER,LLP COUNSELLORS AT LAW 7 Entin Rd. Parsippany, NJ 07054-5020 Off: (973) 753-5100 Fax: (973) 753-5353 DANIEL B SULLIVAN DALE L GELBER GINA M LO BUE (NJ & NY] EDWARD STOCK (PA ONLy] NICHOLAS J MADONIA CHRISTOPHER P ODOGBILI DARYL J KIPNIS GLEN H CHULSKY MICHAEL J PETERS RITAE AYOUB THOIV\A.S M BROGAN STEVEN A LANG MITCHELL L WILLIAMSON (NJ & NY] FRANCIS X GRIMES (NJ & PAl DARREN H TANAKA. (NJ & NY] JOANNE L D'AURIZIO (DC,FL, NJ & NY] MITCHELL E ZIPKIN (NJ & NY] CRAIG S STILLER (NY ONLy] RALPH GULKO (NJ ,NY & PI\) NY Office: PA Office 305 Broadway, 9 th Floor 804 West Avenue New York, NY 10007 Jenkintown, PA 19046 Office: (516)222-7929 Office (215)576-1900 Fax: (973)753-5353 Fax: (215) 576-7299 E-MAIL: en!~_~l!:lL@PDE§!~J..-J?J..Et~~J!!L~9..1JJ. Please Reply To: [X] New Jersey Office [ 1 New York Office [ 1 Pennsylvania Office OFFICE HOURS Monday- Thursday 8am-9pm Friday 8am-7pm Saturday 9am-2pm 05/14/12 Motion Please file the Motion on the following case. If you have any questions/problems please call Aneta Koszelnik at 973-753-5100 x 5569. Very truly yours, PRESSLER & PRESSLER,LLP 40a
048924 PRESSLER MD PRESSLER, L.L.P. COUNSELLORS AT LAW 7 Ent"in Rd. Parsippany, NJ 07054-5020 (973) 153-5100 TEAM A P&P File # 048924 FEE: NO FEE ITEM Attorney for Plaintiff NEW CENTURY FINANCIAL SERVICES, INC. Plaintiff vs Al-ILAM OUGHLA Defendant SUPERIOR COURT OF NEW JERSEY LAW DIVISION HUDSON Special Civil Part Docket No DC-004244-12 CIVIL ACTION NOTICE OF MOTION SUMMARY JUDGMENT TO: AHLAM OUGHLA 109 66TH ST APT 2 WEST NEW YORK, NJ 070933106 TAKE NOTICE that the undersigned will apply to the above named court at SPECIAL CIVIL CASE MGMT OFFICE 595 NEWARK AVE, ROOM 711 JERSEY CITY, NJ 07306 for entry of an Order entering Summary Judgment in favor of the Plaintiff and against the Defendant, AHLAM OUGHLA in the sum of $725.40 plus costs upon the following grounds: There are no facts in dispute and as a matter of law, plaintiff is entitled to judgment. See annexed certification. The order sought will be entered in the discretion of the court unless the attorney or pro se party upon whom it has been served notifies the clerk of the court and the attorney for the moving party or the pro se party in writing within ten days after the date of service of the motion that the responding party objects to the entry of the order. NOTICE. IF YOU WANT TO RESPOND TO THIS MOTION YOU MUST DO SO IN WRITING. Your written response must be in the form of a certification or affidavit. That means that the person signing it swears to the truth of the statements in the certification or affidavit and is aware that the court can punish him or her if the statements are knowingly false. You may ask for oral argument, which means you can ask to appear before the court to explain your position. If the court grants oral argument, you will be notified of the time, date, and place. Your response, if any, must be in writing even if you request oral argument. Any papers you send to the court must also be sent to the opposing party's attorney, or the opposing party if they are not represented by an attorney. 41a
Page 1 and 2: Superior Court of New Jersey Appell
Page 3 and 4: Summary Judgment Motion Statement i
Page 5 and 6: RECEIVED THURSDAY 2/16/20121 :04:35
Page 7 and 8: 048924 PRESSLER AND PRESSLER, L. L.
Page 9 and 10: PHILIP D. STERN NJ & DC Bars pstem@
Page 11 and 12: (11) Notice of appeal and attached
Page 13 and 14: (9) TO THE EXTENT POSSIBLE, LIST TH
Page 15 and 16: from Shennan Acquisition to Plainti
Page 17 and 18: evidence addressing each element of
Page 19 and 20: · . New Jersey Jlldlciary Supell,
Page 21 and 22: NOT FOR PUBLICATION WITHOUT THE APP
Page 23 and 24: On December 15, 2009, plaintiff fil
Page 25 and 26: accountholders who have delinquent
Page 27 and 28: 15. . . . Plaintiff has not provide
Page 29 and 30: dismissing plaintiff's complaint fo
Page 31 and 32: that the parties were directed to a
Page 33 and 34: of discretion." Hisenaj v. Kuehner,
Page 35 and 36: of the parties, and even though the
Page 37 and 38: contend[ed] that . . . Summit faile
Page 39 and 40: .. .' ~"'" .... ~, Ahlam Oughla 109
Page 41 and 42: I. Provide a copy of the applicable
Page 43: Plaintiff’s Motion for Summary Ju
Page 47 and 48: STATEMENT OF MATERIAL FACTS P&P Fil
Page 49 and 50: "ChgOffBalance", is ...............
Page 51 and 52: 4447962145828657 INTEREST REPORT Fr
Page 53 and 54: ASSIGNMENT OF ACCQl)NTS AND BILL OF
Page 55 and 56: Receivables File 11.17.08 Transfer
Page 57 and 58: Receivables File 11.30.11 Transfer
Page 59 and 60: Exhibit B 55a
Page 61 and 62: SUBSTITUTION PAGE Defendant’s Ans
Page 63 and 64: AhlamOugWa 1 09 66 th street apt 2
Page 65 and 66: ANS. Objection 1. Plaintiff has no
Page 67 and 68: 048924 PRESSLER MD PRESSLER, L.L.P.
Page 69 and 70: CERTIFICATION OF SERVICE I further
Page 71 and 72: ; Exhibit A 67a
Page 73 and 74: ... '. •• • FORMCC N~w ~h,wCt
Page 75 and 76: PHILIP D. STERN & ASSOCIATES, LLC A
Page 77 and 78: RECEIVED MONDAY 7/2/2012 3:52:05 PM
Page 79 and 80: · . EXHIBIT A 75a
Page 81 and 82: CREDIT ONE BANK 3278143 BC CRC REV
Page 83 and 84: EXHIBITB 79a
Page 85 and 86: *LVNV FUNDING LLC 11-08 1623040 FU
Page 87 and 88: . ' EXHIBITC 83a
Page 89 and 90: Page 2 403 Fed.Appx. ]90,20]0 WL 44
Page 91 and 92: P&P File Number 048924 PRESSLER AND
Page 93 and 94: I certify that the foregoing statem
Page 95 and 96:
EXHIBIT 1 BILL OF SALE AND ASSIGNME
Page 97 and 98:
93a Q) E !'O Z a. E LU \----- Q) c:
Page 99 and 100:
95a QJ .... 10 0 " c 0 a 0 '';::: N
Page 101 and 102:
EXHIBITB 97a
Page 103 and 104:
· " . EXHIBITC 99a
Page 105 and 106:
EXHIBITD 101a
Page 107 and 108:
PHILIP D. STERN & ASSOCIATES, LLC A
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Appellant's Appendix - Philip D. Stern

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