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Home My WebLink About07-0708IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC NEVADA BANK, N.A. Plaintiff Vs. DOUGLAS THOMPSON Defendant No. 1. I U ? 1COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molezan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1.5219 (412) 434-7955 WWR#05491135 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC NEVADA BANK, N.A. Plaintiff VS. DOUGLAS THOMPSON Defendant Civil Action No. G 7- ??Dd' COMPLAINT IN CIVIL ACTION 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 ON AGENICES 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 is a corporation with offices at 1111 Towne Center Drive, Las Vegas, NV 891.93- 8724 2. Defendant is an adult individual residing at 140 PARTRIDGE CIR CARLISLE,PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number : 5480420019287430 . 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of JANUARY 31, 2007, in the amount of $ 2,499.62 . A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the statutory rate of 6% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff.. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, DOUGLAS THOMPSON individually, in the amount of $ 2,499.62 with continuing finance charges thereon at the statutory rate of 6% per annum from the date of judgment, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molczan, Es re PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:05491135 UFCW MASTERCARD STATEMENT DOUGLAS THOMPSON Page 1 of 1 FINANCE CHARGE CALCULATION This is a grace account. Grace period information on back. ACCOUNT SUMMARY PAYMENT SUMMARY ACCOUNT 5480-4200-1928-7430 OVERLIMIT AMOUNT 4181.62 NUMBER MINIMUM PAYMENTS #50.00 TOTAL CREDIT LIMIT 42,000 CURRENT PAYMENT DUES #231.62 TOTAL CREDIT LIMIT 40 AVAILABLE PAYMENT REQUESTED BY 06/01/04 PAST DUE AMOUNT 4181.00 BALANCE SUMMARY PREVIOUS BALANCE 42,089.55 PAYMENTS/CREDITS - 40.00 PURCHASES/DEBITS + 458.00 FINANCE CHARGE + #34.07 See reverse side for an ex- STATEMENT DATE 05/07/04 planation of these amounts. NEW BALANCE _ 42,181.62 TRANSACTION SUMMARY TRAM POST TRANSACTION REFERENCE AMOUNT DATE DATE DESCRIPTION NUMBER CHARGES CREDITS 05/0305/03 LATE CHARGE ASSESSMENT 10000030000000999902760 #29.00 04/2204/22 OVERLIMIT CHARGE ASSESSMENT 10000030000000999881750 #29.00 Nominal ANNUAL Average Daily Days FINANCE CHARGE Annual PERCENTAGE Daily PeriodiIn Billing At PeriodicCash Advance Percentage RATE Balance Rate Cycle Rate Fees Rate CASH ADVANCES#1,071.15 .05476%. 30 #17.60 40.00 19.99% 19.990% PURCHASES #750.56 .05202% 30 411.72 40.00 18.99% 18.990% BONUS CHECK 4304.47 .05202% 30 44.75 #0.00 18.99% 18.990% MAIL PAYMENTS TO: QUESTIONS? MAIL INQUIRIES TO: HOUSEHOLD CREDIT SERVICES 24-HOUR CUSTOMER SERVICE HOUSEHOLD CREDIT SERVICES PO BOX 17051 1-800-622-2580 PO BOX 80027 BALTIMORE MD 21297-1051 OUTSIDE USA, COLLECT: 1-702-243-1575 SALINAS CA 93912-0027 TOD HEARING IMPAIRED: 1-800-655-9392 Manage your account online at: www.unionpluscard.com 010266 N 07 G STMTXX 2 9 PLEASE DETACH RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Pf redit Please Write Your Account Number On Your Check count Number 5480-4200-1928-7430 J /? I New Balance 42,181.62 Payment Requested By 06/01/04 Current Payment Due 4231.62 Make checks payable to HOUSEHOLD CREDIT SERVICES . Please write your account number on your check. Do not fold, staple or clip. Do not send cash. Please send your payment 7 days prior to the payment requested by date to ensure timely delivery. Amount Enclosed N N a DOUGLAS THOMPSON 140 PARTRIDGE CIR CARLISLE PA 17013-8701 HOUSEHOLD CREDIT SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 548042001928743000023162002181621 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 Ariel Mendoza Manager of HSBC Nevada, NA, plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct the best of his/her knowledge, information and belief. C (Signature) Wwr#jS-q ? J I -j S. v l ` ? T, 6 Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. DOUGLAS THOMPSON Defendant No. 07-708-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R405491135 Judgment Amount $ 2,499.62 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. Civil Action No. 07-708-CIVIL TERM DOUGLAS THOMPSON Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, DOUGLAS THOMPSON above named, in the default of an Answer, in the amount of $2,499.62 computed as follows: Amount claimed in Complaint $2,499.62 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $0 TOTAL $2,499.62 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: WILLIAM T. MOLCZAN, QUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#05491 135 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 140 PARTRIDGE CIR CARLISLE,PA 17013 • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff VS. Civil Action No. 07-708-CIVIL TERM DOUGLAS THOMPSON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ment was entered against you on_ j4ovk-C 2.0p?' (xx) Assumpsit Judgment in the amount of $2,499.62 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: ?, 1? PROT NOTA 644 44, ) DOUGLAS THOMPSON 140 PARTRIDGE CIR CARLISLE,PA 17013 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. DOUGLAS THOMPSON Defendant Case no: 07-708-CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, DOUGLAS THOMPSON is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, DOUGLAS THOMPSON is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in of . NQiTARY presence this ;?-/_ day COM1,AONWEALI H OF PENNSYLVANIA F Notarial Seal Wend Oauit, hi. =,ry Public ?jneny s July City Oi P;t Burgh, pair Cpmrn?ssior Exp ' Y My , ,n°" t pssncinor of Notaries Membef, . 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. Request for Military Status Department of Defense Manpower Data Center AdIbL IV Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAR-19-2007 07:31:48 -,11( , Last Name First/Middle Begin Date Active Duty Status Service/Agency THOMPSON DOUGLAS Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. y6t Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http-//ww,w.defenselink.mil/fau/i)is/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 3/19/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: CBDWILAZYUN https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 3/19/2007 IN TH' '--OURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff Case # j ? _ / o8 DOUGLAS THOMPSON Defendant(s) IMPORTANT NOTICE TO: DOUGLAS THOMPSON 140 PARTRIDGE CIR CARLISLE,PA 17013 l -7 -7 Date of Notice: ! 6 Id WWR#: 05491135 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY: 4k0 AAA U,)0bb 46, PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 f? r c C ti c c t?M t-J t=3 cD C_7 CD Q'w 1,La -3 iY1 or- SHERIFF'S RETURN - REGULAR CASE NO: 2007-00708 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC NEVADA BANK N A VS THOMPSON DOUGLAS MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon THOMPSON DOUGLAS the DEFENDANT , at 1005:00 HOURS, on the 7th day of February-, 2007 at 140 PARTRIDGE CIRCLE CARLISLE, PA 17013 DOUGLAS THOMPSON by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.40,E Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 32.40 02/08/2007 ,a j WELTMAN WEINBERG REIS Sworn and Subscibed to aI By: ?z ; before me this day Deputy Sheriff of A.D. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. Civil Action No. 07-708-CIVIL TERM DOUGLAS THOMPSON Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and subscribed before me this day of A 7 ?OTARY PUBLI WELTMAN, WEINBERG & REIS CO., L.P.A. By: _ L4 i- /??maa C? PATRICK THOMAS WOODMAN, Esquire PA. I.D.#34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #5491135 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Gault,', City i; - .>uurgh, µ,. eny County Nay Con-,. ssion ExPi )dy 15 ?n10 Member, Per, Sylvania Ass ;Nation of Notariez C) - TO 771 +? ,* OQ rr an