DOCKET NO.: HHD-CV-25-6200631S SUPERIOR COURT
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`MANCHESTER TOBACCO & CANDY COMPANY — : J.D. OF HARTFORD
`V. AT HARTFORD
`AMJED QAWASMEH, ET AL. APRIL 29, 2025
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`PLAINTIFF’S MOTION FOR JUDGMENT
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`Pursuant to Conn. Practice Book Secs. 17-33 and 17-25, the Plaintiff in the
`above-captioned breach of contract collection action, Manchester Tobacco & Candy
`Company (“Manchester”), hereby respectfully requests that this Court enter judgment in
`its favor and against the Defendant Amjed Qawasmeh (“Qawasmeh’) only, in the
`amount of $15,366.89. In support of this motion, the undersigned hereby represents
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`that:
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`1. A Motion for Default for Failure to Appear directed against the Defendants,
`dated March 31, 2025, was granted by this Court against Qawasmeh by order
`dated April 15, 2025;
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`2. This case involves a breach of contract collection action (upon a signed,
`written credit agreement between Manchester, a wholesale vendor of candy
`and tobacco products, and jointly and severally binding Qawasmeh and the
`co-Defendant, Nablusi Market, LLC, as the owners, operators, and/or
`managers of a retail food store who at all relevant times were customers of
`Manchester's, for the sale by Manchester to the Defendants of candy and
`tobacco products for resale of those products by the Defendants at their retail
`food store) where Manchester’s damages are liquidated;
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`3. The accompanying Affidavit of Debt of Michael Schoenfeld, Manchester’s
`duly authorized Vice President, establishes that the amount owed by
`Qawasmeh for goods sold and provided by Manchester is $15,366.89, broken
`down with $14,264.48 representing the unpaid account balance due and
`owing and $1,102.41 representing the 1.5% per month in accrued interest on
`unpaid overdue invoices authorized by the parties’ signed contract:
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`105-0178
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`DAVID G. HILL & ASSOCIATES, LLC Phone (860) 657-1012 @ Fax (860) 657-9264 e Juris No.: 431590
`180 Glastonbury Boulevard, Suite 202, Glastonbury, CT 06033
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`4. The amount of interest claimed is $1,102.41; the terminal dates for the
`computation of interest are December 1, 2024 as the start date through April
`30, 2025 as the end date; the applicable interest rate is the 1.5% per month
`contractual interest charged on overdue unpaid invoices; the manner of
`computation of that 1.5% per month interest is $213.97 for the month of
`December 2024, plus $217.18 for the month of January 2025, plus $220.43
`for the month of February 2025, plus $223.74 for the month of March 2025,
`plus $227.09 for the month of April 2025, for a total of interest claimed
`equaling $1,102.41; and the authority forming the basis of Manchester's
`claimed entitlement to interest is the parties’ signed Credit Contract, a true
`and accurate copy of which is appended to the accompanying Affidavit of
`Michael Schoenfeld; and
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`5. The parties’ contract also authorizes Manchester to recover its costs of
`collection, including attorney’s fees, in the event the Defendants’ account is
`referred for collection, such that Manchester's claim for attorney’s fees is the
`subject of a separate Motion for Award of Attorney’s Fees directed against
`Qawasmeh being filed contemporaneously herewith.
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`WHEREFORE, Manchester respectfully requests that this Court grant its Motion
`and enter judgment in its favor and against the Defendant Amjed Qawasmeh only, for
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`the stated amount of $15,366.89.
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`PLAINTIFF,
`MANCHESTER TOBACCO &
`CANDY COMPANY
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`Ny a,
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`Jahn’'S. Rosania, Esq.
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`David G. Hill & Associates, LLC
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`180 Glastonbury Boulevard, Suite 202
`Glastonbury, CT 06033
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`Ph.: (860) 657-1012
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`Fax: (860) 657-9264
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`Juris No.: 431590
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`Its Attorneys
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`-2-
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`DAVID G. HILL & ASSOCIATES, LLC e Phone (860) 657-1012 e Fax (860) 657-9264 e Juris No.: 431590
`180 Glastonbury Boulevard, Suite 202, Glastonbury, CT 06033
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`CERTIFICATION
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`This is to certify that a copy of the foregoing Motion has been mailed, postage
`prepaid, via certified mail and regular mail, on this 29"" day of April 2025 to the following:
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`Amjed Qawasmeh
`245 Colonial Avenue, Apt. 10A
`Waterbury, CT 06704
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`Nablusi Market, LLC
`1840 Barnum Avenue
`Bridgeport, CT 06610-3020
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`Nablusi Market, LLC
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`c/o its Agent for Service
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`RR Consultancy, LLC
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`1137 Main Street, Suite 202
`East Hartford, CT 06108
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`wind Posne’
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`ohn S. Rosania, Esq.
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`-3-
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`DAVID G. HILL & ASSOCIATES, LLC e Phone (860) 657-1012. « Fax (860) 657-9264 e Juris No.: 431590
`180 Glastonbury Boulevard, Suite 202, Glastonbury, CT 06033
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