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Home My WebLink About07-1976ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. LAURETTE A DALTON Defendant NO: 07 -- /9-n C?;?;C`?SSe? 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 05524737 C N Pit CXC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. Civil Action No LAURETTE A DALTON 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, HSBC BANK NEVADA, N.A is a corporation with offices at 1111 TOWN CENTER DR. LAS VEGAS , NV 89193 . 2. Defendant is adult individual(s) residing at the address listed below: LAURETTE A DALTON 1801 LOUISA LN MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 5440455030695269 . 4. Defendant made use of said credit card and has a current balance due of $2556.39 , as of March 09, 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 March 09, 2007 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 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 , LAURETTE A DALTON , INDIVIDUALLY , in the amount of $2556.39 with continuing interest thereon at the rate of 6.000W per annum from March 09, 2007 plus costs. i James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 eth Avenue, Suite 2718 Pit sbh, PA 15219 (4 ) -7955 F 4 338-7130 0 5247)7 C N Pit CXC This law firm is a debt collector at em ing to collect this debt for our client and any information obta'n will be used for that purpose. OR&ialW BANK" LAURETTE A DALTON ACCOUNT SUMMARY ACCOUNT 5440-4550-3069-5269 NUMBER CASH CREDIT LIMIT t $2,000 CASH LIMIT AVAILABLE $0 TOTAL CREDIT LIMIT $2,000 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE 10/24/06 PAYMENT SUMMARY OVERLIMIT AMOUNT $427,40 MINIMUM PAYMENT' $85.00 CURRENT PAYMENT DUE' $512.40 PAYMENT DUE DATE 11/18/06 PAST DUE AMOUNT $270.00 'See reverse side for an explanation of these amounts. Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $2,36735 PAYMENTS/CREDITS - $000 PURCHASESi1DEBITS + $0,00 LATE PAYMENT CHARGE + $0.00 MISC. FINANCE CHARGE + $0.00 FINANCE CHARGE + 60.05 NEW BALANCE _ $2,427.40 T t-asn Crean Limn is a portion of the Total Credit Limit TRANSACTION SUMMARY (For additional transaction detail go to www.orchardbank.com) TRANS POST TRANSACTION REFERENCE AMOUNT DATE DATE DESCRIPTION NUMBER CHARGES CREDITS PERIODIC FINANCE CHARGE SUMMARY This is a grace account Grace period information on back. Balance Subject Daily Days Finance Charges To Finance Charge Periodic in Billing At Periodic Average Daily Balance Rate Cycle Rate PURCHASES $2,396.25 0.08353% 30 $60 05 CASH ADVANCES $0.00 0.00000% 30 . $0-00 ANNUAL PERCENTAGE RATE" 30,490% "May be higher then Nominal Percentage Rate if statement includes misc. finance charges. NOMINAL ANNUAL PERCENTAGE RATE 30.49% 30.49% EXHIBIT I ? MAIL PAYMENTS TO: V QUESTIONS? HSBC CARD SERVICES 24-HOUR AUTOMATED ACCOUNT INFORMATION PO BOX 17051 ENGLISH 1-503.293-4037 BALTIMORE MD 21297-1051 ESPAAOL 1-503-293-4834 Q Manage your account online at: www.orchardbank.com ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 80084 SALINAS CA 93912-0084 110201 N 24 0000000506 G STMTXO 2 6 00053256 EXCPT 'LEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check 4G5fEiii?#`?II?? dew Balance $2,427.40 lyment Due Date 11/18106 Current Payment Due $51241 Make checks payable to HSBC CARD SERVICES. Please write your account number on your check. Do not fold, staple or clip. Do not send cash. Please send your payment 7 to10 days prior to the payment due date to ensure timely delivery. Amount Enclosed #BWNHYTS #328030695261# LAURETTE A DALTON 1801 LOUISA LN MECEANICSBURG PA 17050-7255 1111111111111111111111111IIIIIIIIIIII11111111111IfII11111 11111 ESBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 11111111111111 If I I111111111111 1111111111111111111If I I 544045503069526900051240002427400 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating Eo unsworn falsifications to` authorities, that he; she is Ariel Mendoza Manazer 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. (Signature) W OSS?y73? rV 40, d ' 7,11 f + fn3 0 T'i r -n ?ii?E to) 16 i. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. LAURETTE A DALTON Defendant No.: 07-1976-CIVIL PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C Warmbrodt, Esquire PA I.D.#42524 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05524737 Judgment Amount $ 2590.85 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.: 07-1976-CIVIL LAURETTE A DALTON Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, LAURETTE A DALTON above named, in the default of an Answer, in the amount of $2590.85 computed as follows: Amount claimed in Complaint $2556.39 Interest from 3/9/07 to 5/30/07 at the legal interest rate of 6% per annum $34.46 TOTAL $2590.85 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: PA I4 JameZrgh, t, Ire Welti erg & Reis Co., L.P.A. 2718 ldg. 436 enue PittsA 15219 (412 5 W W,R#05524737 Plai ntiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1801 LOUISA LN MECHANICSBURG,PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No.: 07-1976-CIVIL LAURETTE A DALTON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order r Judgment was entered a ainst you on // ( a00 (xx) Assumpsit Judgment in the amount of $2590.85 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: All &12 PROTHONOTARY LAURETTE A DALTON 1801 LOUISA LN MECHANICSBURG,PA 17050 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`t' Avenue, Pittsburgh, PA 15219 1-888-434-0085 ' . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff case # d-1- 1971? -Ctv i L LAURETTE A DALTON Defendant(s) IMPORTANT NOTICE TO: LAURETTE A DALTON 1801 LOUISA LN MECHANICSBURG,PA 17050 Date of Notice: WWR#: 05524737 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: TCUL4A -- ?- PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. LAURETTE A DALTON Defendant Case no:: 07-1976-CIVIL 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, LAURETTE A DALTON 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, LAURETTE A DALTON is not in the military service. Further Affiant sayeth naught. SWORN TO AND SU?4CRI ED in my presence this ( day of 'n/?Gtn? ? 7. Y 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. COMkiONWPA --t`HP C11" P9NNY'LVANIA N (W &4W WOYMP,iQ.,1l1P7P: , 06"Afy public City C7f Pi f bu1Qht. AI!egr;; n;? CqurPty L My Commission Expo a s , u e 29, 2010 Member, Pennsylvania Association of Notaries Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Pagel of 2 MAY-30-2007 07:08:24 -< Last Name First/Middle Begin Date Active Duty Status Service/Agency DALTON LAURETTE A 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 In 0114.- 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://www.defenselink.mil/faq./pis/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 5/30/2007 a 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 IL>: SESFNJDBIT https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/30/2007 N ?.. 1f ••p +? ••? '?'•• - ?? W .,ti '6A. ^?.. O ?-, c'._ -r1 d <. V _ . _ ni r -- °'? -ett?t `?'? t -?C? _- ti, .w SHERIFF'S RETURN - REGULAR CASE NO: 2007-01976 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC BANK NEVADA NA VS DALTON LAURETTE A JESSICA HERMANSEN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE DALTON LAURETTE A was served upon the DEFENDANT , at 1918:00 HOURS, on the 20th day of April 2007 at 1801 LOUISA LANE MECHANICSBURG, PA 17050 by handing to LAURETTE DALTON 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: Docketing Service Affidavit Surcharge 5/2 3/0 9 (:?, 18.00 11.52 .00 10.00 00 3 9. 5 2 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 04/23/2007 WELTMAN WEIN13ERG REIS By. Ax Noo eput jheriff A.D. VS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. LAURETTE A DALTON Defendant No. 07-1976-CIVIL PRAECIPE FOR SATISFACTION OF 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05524737 I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No. 07-1976-CIVIL LAURETTE A DALTON 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 si before me this day of October, OTARY PUB 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05524737 9C --1 I?i'1/ 1 I N^.» Pannsvlva-niaAssnca1, ,, ies 0 00 8 ? D pa o0 ? C'1 T`•? CZD