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Home My WebLink About03-2864COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC BANK USA FORMERLY MARINE MIDLAND BANK, Plaintiff VS. MARY S. SOKOLOSKI, CIVIL ACTION Defendant NOTICE 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 IS SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 DOUGLAS M. MARINOS & ASSOCIATES, P.C., !i~n::uire 101 Cedar Crest Boulevard Allentown, PA 18104 (610)434-2814 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC BANK USA FORMERLY MARINE MIDLAND BANK, VS. Plaintiff MARY S. SOKOLOSKI, Defendant COMPLAINT NO. 03 CIVIL ACTION 1. Plaintiff, HSBC Bank USA formerly Marine Midland Bank ("HSBC") is a banking institution with an address of P.O. Box 9, Buffalo, NY 14240. 2. The Defendant, MaW S. Sokoloski, is an adult individual who resides at 38 Chestnut Street, Newville, Cumberland County, Pennsylvania 17241. 3. On or about November 01, 2000, the Defendant executed a Promissory Note bearing interest at the rate of 12.99% per annum and providing for monthly installments of $228.64 each. A true and correct copy of the Promissory Note is attached hereto, made a part hereof and marked as Exhibit "A". 4. The Defendant defaulted under the terms of the Application by failing to make the monthly payments when due. 5. The balance due and owing on the aforesaid note is TEN THOUSAND EIGHT HUNDRED TWENTY-FIVE and 25/100 DOLLARS ($10,835.25) as of April 30, 2003. 6. Despite repeated demands, the Defendant has failed and refused to pay the aforesaid balance due and owing. 7. Defendant is in default of the terms of the Note and is indebted to the Plaintiff in the amount of TEN THOUSAND EIGHT HUNDRED TWENTY-FIVE and 25/100 DOLLARS ($10,835.25) plus interest at the rate of 12.99% per annum plus reasonable attorney's fees of FIVE HUNDRED and 00/100 DOLLARS ($500.00) as of April 30, 2003. WHEREFORE, HSBC demands judgment against the Defendant in the amount of ELEVEN THOUSAND THREE HUNDRED THIRTY-FIVE and 25/100 DOLLARS ($11,335.25) (comprised of real debt in the amount of TEN THOUSAND EIGHT HUNDRED TWENTY-FIVE and 25/100 DOLLARS ($10,835.25) and anticipated attorney's fees in the amount of FIVE HUNDRED and 00/100 DOLLARS ($500.00) plus interest of 12.99% per annum from and after April 30, 2003, and costs of suit. DOUGLAS M. MARINOS & ASSOCIATES, P.C., squire A~. I/D. #75242 /]ftt~ey for Plaintiff Allentown, PA 18104 (610)434-2814 2 VERIFICATION of HSBC Bank USA formerly Marine Midland Bank verify that the facts contained in the foregoing Complaint are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. HSBC BANK USA FORMERLY MARINE MIDLAND BANK LeROY W. BATE~, Jr, PROMISSORY NOTE Tc~l $ o. o 0 · LOAN TERM TO ~3 MO9, ' 8ECU RITY AGREEMENT 6 YOUR RIOHTS AFTER TAKING B MY RIGHT TO REDEEM 7 PROPERTY LEFT ;N T~ RESIDENCE A DORE~,,~ AQFIEEMENT YOU~ IIlGHI ~ AFTEII fA)<iNO RIGHT TO REDEEM IX,ACT COPY OF THiB FOFY~! IduST BE QIVEH TO THE I~ORROWEH SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-02864 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HSBC BANK USA VS SOKOLOSKI MARY S R. Thomas Kline duly sworn according to inquiry for the within named DEFENDANT SOKOLOSKI MARY S unable to locate Her in his bailiwick. ,Sheriff or Deputy Sheriff, who being law, says, that he made a diligent search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 38 CHESTNUT STREET NEWVILLE, PA 17241 PER POST OFFICE, , SOKOLOSKI MARY S NOT FOUND , as to DEFENDANT IS NOT KNOWN AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 16.56 5.00 10.00 .00 49.56 So answer_s-;:-~ .~~ R. Thoma~f Kline Sheriff of Curaberland County DOUGLAS MARINOS 07/09/2003 Sworn and subscribed to before me this /g ~ day of (~ ~6m5 A.D. otary