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Home My WebLink About07-2505IN TiE COURT OF Ct;:~iD1OP.. PLErS OF C;.TMBE'RLA'`TD COUNTY, PETTNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. ALLAN L JONES Defendant 1 COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 y]ELTr'.ATd, Tr1EINBE??G & REIS CO . , L . P . A . 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05524742 C N Pit KXW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No ALLAN L JONES Defendant COMPLn INT A.ND I~TCTICE 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 3 2 SOLTTH T3EDFORD 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: ALLAN L JONES 12 ~? DARR A~.~E' CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 5491070007957952 . 4. Defendant made use of said credit card and has a current balance due of $2711.69 as of March 12, 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.OOOo per annum on the unpaid balance from March 12, 2007 A copy of Plaintiff's STATMENT is attached hereto, marked as Exhibit "1" 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 ALLAN L JONES INDIVIDUALLY in the amount of $2711.69 with continuing interest thereon at the rate of 6.000% per annum from March 12, 2007 plus costs. Jame Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 Sev nth Avenue, Suite 2718 Pi sb gh, PA 15219 (4 2) 34-7955 F 2-338-7130 0 524 42 C N Pit KXW This law firm is a debt collector at~errKSting to collect this debt for our client and any information obtai ~ will be used for that purpose. HSBC PLATINUM MASTERCARD STATEMENT ALLAN L JONES ACCOUNT SUMMARY ACCOUNT 5491-0700-0795-7952 NUMBER TOTAL CREDIT LIMIT $2,500 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE 10/02/06 PAYMENT SUMMARY PAST DUE AMOUNT $354.00 MINIMUM PAYMENT' $61.00 CURRENT PAYMENT DUE' $415.00 PAYMENT DUE DATE i 10/27/06 OVERLIMrf AMOUNT $0.00 `See reverse side for an explanation of I~~ these amounts. Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $2,452.39 PAYMENTS/CREDiTS - $0.00 PURCHASES/DEBITS + $0.00 FINANCE CHARGE + 35.79 NEW BALANCE _ $2,488.18 TRANSACTION SUMMARY (For additional transaction detail go to www.hsbccreditcard.com) TRANS POST TRANSACTION REFERENCE AMOUNT SATE DATE DESCRIPTION NUMBER CHARGES ~ CREDITS FINANCE CHARGE CALCULATION This is a grace account Grace period information on back. NOMINAL Balance Subject Daily Days Finance Charges ANNUAL To Finance Charge Periodic in Billing At Periodic PERCENTAGE Average Daily Balance Rate Cycle Rate RATE BALANCE TRANSFER $821.08 0.04997% 29 $11.90 18.24% PURCHASES $930.76 0.04997% 29 $13.49 18.24% BALANCE TRANSFER $717.79 0.04997% 29 $10.40 18.24% CASH ADVANCES $0.00 0.00000% 29 $0.00 19.99% ANNUAL PERCENTAGE RATE" 18.240°b "May be higher then Nominal Percentage Rate if statement includes misc. finance charges. ~! r~, ~~yj8 ` Il ~ / MAIL PAYMENTS TO: '~ QUESTIONS? ®MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 17051 24-HOUR CUSTOMER SERVICE HSBC CARD SERVICES y BALTIMORE MO 21297-1051 1-800-462-2016 OUTSIDE USA, COLLECT: 1-757-523-3880 PO BOX 81622 SALINAS CA 93912-1622 TDO HEARING IMPAIRED: 1-800-395-9020 ~ Manage your account online at: 1 www.hsbccreditcard.com EXCPT 080752 N 02 0000000400 G STMTXO 2 L 00104421 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT- To Assure Proper Credit Please Write Your Account Number On Your Check HSBC m ..........................:.:• ::::.:•::::• ::€~ :iii ~€:~i:;~~~~~~~;~'.~~1~; lew Balance $2;488.18 'ayment Due Date 10/27/06 Current Payment Due $415.0 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 days prior to the payment due date to ensure timely delivery. Amount Enclosed ALLAN L JONES 129 DARR AVE CARLISLE PA 17013-1016 11111111111111111/1111t111111111111111111111111111111111111111 HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 IIIIJ 111111 J1111 L 1111) 11111111111111111111111111 549107000795795200041500002488188 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. (Signature) Wwr# `~ ~ ~ ~ r.a C~ ~ ~-.~ ~, ~~ -11 / ~ _ ! -~-~ ' V Qom' ~~' ~ ~T .._ ~^' ~ _~ ° SHERIFF'S RETURN - REGULAR CASE N0: 2007-02505 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC BANK NEVADA N A VS JONES ALLAN L STEPHEN BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JONES ALLAN L the DEFENDANT at 129 DARR AVE at 1440:00 HOURS, on the 11th day of May 2007 CARLISLE, PA 17013 by handing to ALLAN L JONES SR, FATHER 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 4.80 ~~:~ ~~;~ Af f i davi t . 0 0 --~'" `" ~ ~``~ ~~ ~- ~~w Surcharge 10.00 R. Thomas Kline .00 u~',30/p~ / 32.80 05/14/2007 WELTMAN WEINBERG REDS Sworn and Subscibed to By: ~~y~'_"_' before me thi s day Deputy~Sh-er-i f f of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA N.A. Plaintiff vs. ALLAN L JONES Defendant No. 2007-02505 PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#5524742 Judgment Amount $ 2759.39 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA N.A. Plaintiff vs. ALLAN L JONES Defendant TO THE PROTHONOTARY: Civil Action No. 2007-02505 PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, ALLAN L JONES above named, in the default of an Answer, in the amount of $2759.39 computed as follows: Amount claimed in Complaint $2711..69 Interest from MARCH l2, 2007 to JUNE 27, 2007 at the legal interest rate of 6.00% per annum $47.70 TOTAL $2759.39 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: _ WIL I T. M AN, ESQUIRE PA 1.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W W R#5524742 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers :Building, 436 7`~ Avenue, Pittsburgh, PA 1521.9 And that the last known address of the Defendant is: 129 ADRR AVENUE CARISLE PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN[A CIVIL DIVISION HSBC BANK NEVADA N.A. Plaintiff vs. Civil Action No. 2007-02505 ALLAN L JONES Defendant NOTICE OF J1IDGMENT OR ORDER TO; ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $2759.39 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: /~/ ('.,,c~~ ~. ~ aloe PRO ONOTARY (OR DE TY) ALLAN L JONES 129 DARK AVENUE CARISLE 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N . A l r +l ~n~ Plaintiff Case # ~ ~ ~ U I l~ ~~r i ALLAN L JONES Defendant (s) IMPORTANT NOTICE TO: ALLAN L JONES 129 DARR AVE CARLISLE,PA 17013 Date of Notice: ~~ WWR#: 05524742 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 : {-~Z~Gt,u~~-- l `'ri-~t2~ W~~l~i~'_ 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 CUMBI/RLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA N.A. Plaintiff V S. ALLAN L JONES Defendant Case no: 2007-02505 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 Servicemcmbers' 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, ALLAN L JONES 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, ALLAN L JONES is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this ~ day of . ~~. . ; OF PEP~n~~ ~" ~ ,~~~ OTARY PUBLI s' -~ ~ ~~ '_~' i ...__.~__ .a ,_,.~ 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 Military Status Report 'Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUN-27-2007 05:34:10 '~: Last Name First/Middle Begin Date Active Duty Status Service/Agency JONES ALLAN L 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. ,~ .r~.~,-cam. 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/faa/pis/1?C09SLDR.htm1 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 6/27/2007 Request for Military Status w Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: YTUHKPEKDY https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/27/2007 ~ ~~s ,L7 ~ 0 ~ ~ ~ ~ Q "(1 CG:a t ;:~ ~*- ~rt '__ t1~.. ~ r `~~, ::~ - 4 <~~'i~ t (-, t ~ _~ ~^~ ' ~ ,_r ~