The URL can be used to link to this page

Home My WebLink About07-1956IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff VS. ROBERT DOUGLAS Defendant No: 07 ^ I(?s%o OVAL C-?? 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 05595807 C N Pit CXC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff VS. Civil Action No ROBERT DOUGLAS 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 b 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, HSBC BANK NEVADA, N.A. AS is a corporation with offices at 111 TOWN CENTER DRIVE LAS VEGAS , NV 89193 . 2. Defendant is adult individual(s) residing at the address listed below: ROBERT DOUGLAS 205 1/2 E LOCUST ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 5458001117186902 . 4. Defendant made use of said credit card and has a current balance due of $1824.24 , as of February 19, 2007 . 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 February 19, 2007 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" anr7 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 , ROBERT DOUGLAS , INDIVIDUALLY , in the amount of $1824.24 with continuing interest thereon at the rate of 6.000% per annum from February 19, 2007 plus costs. This law firm is a debt collector at our client and any information obtai Jat243 . Warmbrodt42524 WEEINBERG &,REIS CO., L.P.A. 43en h Avenue, Suite 2718 Pir PA 15219 (4 -7955 FPAC: 41P-338-7130 0 595 7 C N Pit CXC tang to collect this debt for will be used for that purpose. CARDMEMBER SERVICES DIRECT MERCHANTS BANK® PO BOX 21550 TULSA OK 74121-1550 Make Payments Payable To: HSBC Card Services YOUR PAYMENT COUPON STATEMENT NEW MINIMUM ACCOUNT NUMBER 5458 0011 1718 6902 DATE BALANCE PAYMENT DUE AMOUNT PAST PAYMENT MUST DUE BE RECEIVED BY AMOUNT 05/30/06 1,599.54 143.00 ENCLOSED 92.00 06/24106 New address or email? Check box. See reverse side. $: SEND PAYMENTS TO: ROBERT DOUGLAS ozs 205 112 E LOCUST ST 14199 MECHANICSBURG PA 17055-6522 PAYMENT CENTER PO BOX 17313 BALTIMORE, MD 21297-1313 545800111718690200014300001599544 Detach and insert this top Portion in the enclosed envelope Be sure the Payment Center address shows in the env,dope window. DIRECT MERCHANTS BANK® A .VIEW OF YOUR RECENT CHARGES AND CREDITS Pay Online, Anytime: M"A 111.accountcentralonline.com TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION PURCHASES; CASH ADVANCES & FEES CREDITS CHARGES 05130 05/30 ACCOUNT PROTECTION PLUS 'FINANCE CHARGE' PURCHASES $25.51 CASH ADVANCE $9.17 YOUR ACCOUNT SUMMARY - MAY 2006 14.11 34.68 ACCOUNT AND PAYMENT INFORMATION CREDIT LINE INFORMATION ACCOUNT NUMBER 5158 D011 1718 6902 TOTAL CREDIT LINE ACCOUNT SUMMARY NEW BALANCE 1599.54 TOTAL AVAILABLE CREDIT $ 1000 PREVIOUS BALANCE 11550 75 MINIMUM PAYMENT DUE 143.00 CASH ADVANCE CREDIT LIMIT' 0 PURCHASES « 1111 AMOUNT PAST DUE 92.00 CASH ADVANCE AVAILABLE CREDIT 500 CASH ADVANCES « 0 00 PAYMENT MUST BE OVERLIMIT AMOUNT 0 0 CREDITS - 0.00 RECEIVED BY JUN 24, 2006 'CASH ADVANCE CREDIT LIMIT IS A 599.54 PAYMENTS 0.00 PORTION OF YOUR TOTAL CREDIT LINE OTHER « 0.00 FINANCE CHARGE « 34,68 NEW BALANCE 1599.54 CARDMEMBER SERVICE CENTER: 1-800-379-7999 PHONE PAYMENT BY FROM OUTSIDE THE U.S. CALL COLLECT: 904-997-4997 HEARING MPAI ED-TDD CUSTOMERS CALL: 877-902-0967 SEND PAYMENTS TO: PAYMENT CENTER, PO BOX 17313, BALTIMORE, MD 21297-1313 MAIL INQUIRIES TO: CARDMEMBER SERVICES, PO BOX 21550, TULSA, OK 74121-1550 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION. Pay Online, Anytime: www.accountcentralonline.com YOUR ACCOUNT IS TWO PAYMENTS PAST DUE- CALL US IMMEDIATELY AT 1-800-435-1415 TO MAKE PAYMENT ARRANGEMENTS. EFFECTIVE 5117/06, YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS: A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEPHONE, EVEN IF THE PAYMENT IS MADE BY SOMEONE QQ?SY T YOU. THE AMOUNT OF THE FEE WILL BE DISCLOSED WHEN l1:19? ? ? I PHONE IS REQUESTED. CC 5994 0012 %PU 2 / 20 060530 % Page 1 °??15lSf]!T WHEN SENDING US YOUR PAYMENT... ALWAYS INCLUDE YOUR ACCOUNT NUMBER ON THE CHECK` BE SURE TO SIGN YOUR CHECK' REMOVE THE TOP PORTION OF YOUR STATEMENT AND RETURN WITH YOUR PAYMENT IN THE ENVELOPE PROVIDED PAYMENT IS DUE 13Y THE DATE INDICATED IN THIS STATEMENT 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. (Sign Wwr#0 5ScI 5'SS 0-1 lJ V N l Na " l ..d V :r) 4- _z- C-) 1 °J CD "'C7 CaJ CD w --+ T .t I ok) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No.07-1956-CIVIL VS. PRAECIPE FOR ENTRY OF JUDGMENT By CONSENT ROBERT DOUGLAS Defendant 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 WWR#05595807 b0'd 90:ZT L00Z-80-Nnf w .%I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. Civil Action No. 07-1956-CIVIL ROBERT DOUGLAS Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, ROBERT DOUGLAS, above-named, in the amount of $1824.24 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to plaintiff in the amount of $1824.24 with continuing interest thereon at a rate of 6.0% per annum plus costs from MAY 34, 2007. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, ROBERT DOUGLAS, in the amount of $1824.24 plus S L" .s- I continuing interest thereon at the rate of 6.0% per annum from MAY-34, 2007 and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: fi/C'7 (a) $750.00 due by 7; (b) $100.00 due on the 28TH day of eacb consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 90'd 9V:F1 1.AAF-RA-Nnr 4. All payments are to be made payable to the order of " HSBC BANK NEVADA, N.A" 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiffs counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. intending to be legally bound, the parties set their bands and seals this-day of f 20_'a'-? . WELTMAN, WEINBERG & REIS CO., L.P.A. BY: WV,LIXM T. M(1 C AN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & eis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 05595807 By: ?? fendant, ROBEFif DOUGLAS L0'd SV:ZS L00Z-80-Nnf IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. ROBERT DOUGLAS Defendant Civil Action No. 07-1956-CIM PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, ROBERT DOUGLAS, in the amount of $1824.24 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG 8t REIS CO., L.P.A., By: ' Attorney for Plainti ROBERT DOUGLAS, - By: Def ndant WWR#05595807 S0 ' d Sb : n Low-e0-Nnf C 1_ 4 ? 7?, con ?h` 7-J rr F? r1l W1 . 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No. 07-1956-CIVIL ROBERT DOUGLAS Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order r Judgment was entered a nst you on PI . GSU (xx) Assumpsit Judgment in the amount of $1824.24 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 ( ) Default ( ) verdict ( ) Arbitration ( ) Award (XX) By Consent ROBERT DOUGLAS 205 112 E LOCUST ST MECHANICSBURG,PA 17055 80'd Prothonotary Sb:ZI L00Z-80-Nnf SHERIFF'S RETURN - REGULAR CASE NO: 2007-01956 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC BANK NEVADA NA AS VS DOUGLAS ROBERT KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DOUGLAS ROBERT the DEFENDANT , at 1912:00 HOURS, on the 23rd day of April 2007 at 205 1/2 E LOCUST STREET MECHANICSBURG, PA 17055 ROBERT E DOUGLAS 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: Docketing 18.00 Service 10.56 Affidavit .00 Surcharge 10.00 .00 S?a3?n4 ?/ 3 8 . 5 6 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 04/24/2007 WELTMAN WEINBERG REIS By. (?y y Sheriff A.D. day