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Home My WebLink About07-3307IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. MICHAEL L MATSON Defendant No : t~~l -, 33D'1 ~T t.. [ (~L \, ~G. 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 05752518 C N Pit SJS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. MICHAEL L MATSON Defendant Civil Action No 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: MICHAEL L MATSON 307 VALLEY ST SUMMERDALE, PA 17093 3. Defendant applied for and received a credit card bearing the account number 5176690016560331 4. Defendant made use of said credit card and has a current balance due of $2036.36 as of May 22, 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 May 22, 2007 A copy of Plaintiff's STATEMENT 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 MICHAEL L MATSON INDIVIDUALLY in the amount of $2036.36 with continuing interest thereon at the rate of 6.000 per annum from May 22, 2007 plus costs. James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 S ve th Avenue, Suite 2718 Pitt bur h, PA 15219 (41 43 -7955 FAX 412 338-7130 057 251 C N Pit SJS This law firm is a debt collector at~mpti,~g to collect this debt for our client and any information obtai d v 11 be used for that purpose. HSBC GOLD MASTERCARD STATEMENT MICHAEL L MATSON Page t of 1 ACCOUNT SUMMARY ACCOUNT 5176-6900-1656- 0331 NUMBER TOTAL CREDTT LIMIT 51,500 TOTAL CREDIT LIMTT 50 AVAII.ABLE CASH CREDIr LIMIT $600 CASH LIMrC AVAII.ABLE 50 STATEMENT DATE 02!18!07 PAYMENT SUMMARY OVERI.IMIT AMOUNT $536.36 MINIMUM PAYMENT" $71.00 CURRENT PAYMENT DUE' $607.36 PAYMENT DUE DATE 03/14/07 PAST DUE AMOUNT 5405.00 "See reverse side for an explanation of these amounts. ~ Asa sag Cash Credit Limit is a portion of the Total Credit Limit TRANSACTION SUMMARY (For additiorail naasaction detail go w www.hsbccreditcard.com) TRANS POST TRANSACTION REFERENCE DATE DATE DESCRIPTION NUMBER FINANCE CHARGE CALCULATION This is a grace account. Grace penod mf°rma<ion on back. Balance Subject To Finance Charge Average Daily Balance PURCHASES $2,010.59 CASH ADVANCES 50.00 ANNUAL PERCENTAGE RATE" 28.240° ""May be higher then Nominal Percentage Rate if staument includes misc. finance chazges. BALANCE SUMMARY PREVIOUS BALANCE 51,986.58 PAYMENTS/CREDITS - $0.00 PURCHASES/DEBTTS + 50.00 FINANCE CHARGE + 4`~ NEW BALANCE = 52,036.36 AMOUNT CHARGES ~ CT RED~ITS NOMINAL Dazly Days Finance Charges ANNUAL Periodic in Billing AtPerlodle PERCENTAGE Rate Cycle Rate RATE 0.07737 32 549.78 28.24% 0.00000 32 $0.00 28.249b ~ QUESTIONS? ®MAIL INQUIRIES TO: / MAIL PAYMENTS TO: HSBC CARD SERVICES HSBC CARD SERVICES 24-HOUR CUSTOMER SERVICE PO BOX 8]622 PO BOX 17051 1-800-477-6000 SALINAS CA 93912-1622 BALTIMORE MD 21297- 1051 OUTSIDE USA, COLLECT: 1-757-523-3680 TDD HEARING BviPAIItED: 1-800-395-9020 ~ Manage your account online at: yyyyyy.hsbccreditcard.com ExcPr 080370 3 N 17 0000000300 G STMTXO 2 7 TION 00001377 WITH YOUR PAYMENT: To Assure Proper Credit Please Wriu Your Account Number Ou Yom Check PLEASE DETACH AND RETURN BOTTOM POR HSBC ID 4ccount Number 5176-0900-1656-033' Zew Balance 52,036.36 'aymen[ Due Date 03/14/07 Current Payment Due 56073[ 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 E~~iI~IT MICHAEL L MATSON 302 VALLEY ST gtJtdD~RDALE PA 17093 ~ut~~~n~~~~n~~t~un~~~~~n~~ HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 ~t~~t~ni~~n~~~~t~n~nt~nt~~~~nn~~~nn~~n~t~~ 517669001656033100060736002036367 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# ~~s a5 ~~ `~ ~ .~, ~ ~ ~ ~ ra y 0 ~ ~~ ~ (~1 "~ ~ `-~ ~ " ~ c -T, n ~ r, ~ .~ ~ frT" TT ~~ ~~ - r ( 9 `~ ~ ' ~ '~. ...~ .C" ~ ~ SHERIFF'S RETURN - NOT FOUND CASE N0: 2007-03307 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HSBC BANK NEVADA N A VS MATSON MICHAEL L R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT MATSON MICHAEL L but was unable to locate Him in his bailiwick. COMPLAINT & NOTICE , He therefore returns the the within named DEFENDANT MATSON MICHAEL L NOT FOUND as to 307 VALLEY STREET SUMMERDALE, PA 17093 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 4 ~ f s(b1 (~,.,,, So answers,...--~ r -- 15 . 3 6 ~.-.~.. _.. 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County 00 4~ WELTMAN WEINBERG REIS 06/11/2007 Sworn and Subscribed to before me this day of A.D. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. Civil Action No. 07-3307-CIVIL TERM MICHAEL L MATSON Defendants PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG &REIS CO., L.P.A. By' V - - James C a brodt PA I.D. 425 WELT AN, EINBE 2718opper Building 436 event Avenue Pitt~urg PA 15219 (41~L) 4 4-7955 i Vii R #057525 ] 8 & REIS CO., L.P.A. C) ~; Q ~ ~ ~ ~p ~ a " _ ~ 0 {- `~ < car --~' ~ ~ ~ 4` `. 'i' ` D ~.. ,y .• a + y LJ ` W SHERIFF'S RETURN - REGULAR CASE N0: 2007-03307 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC BANK NEVADA N A VS MATSON MICHAEL L MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MATSON MICHAEL L DEFENDANT the at 1825:00 HOURS, on the 9th day of August 2007 at 307 VALLEY STREET SUMMERDALE, PA 17093 by handing to MICHAEL MATSON 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 14.40 Affidavit .00 Surcharge 10.00 .00 ~S~tSI~ ~,,, 42.40 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/10/2007 WELTMAN WEINBERG REIS By: Deputy Sheriff of A.D. 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK. NEVADA, N.A Plaintiff vs. Civil Action No.: 07-3307-C[V1L TERM MICHAEL L MATSON Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, MICHAEL L MATSON above named, in the default of an Answer, in the amount of $2078.20 computed as follows: Amount claimed in Complaint $2036.36 Interest from MAY 22, 2007 TO SEPTEMBER 24, 2007 at the legal interest rate of 6.000% per annum $41.84 TOTAL $2078.20 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. ]VIOL AN, F,SQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#05752518 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 302 VALLEY ST POB 67 SUMMERDALE,PA 17093 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff Case #~~"330 -(~ t~-iL -T~1ZYh MICHAEL L MATSON Defendant(s) IMPORTANT NOTICE TO: MICHAEL L MATSON 302 VALLEY ST POB 67 SUMMERDALE,PA 17093 Date of Notice: O~j~~~1O~ WWR## : 05752518 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 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. MICHAEL L MATSON Defendant Case no:: 07-3307-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, MICHAEL L MATSON 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, MICHAEL L MATSON is not in the military service. Further Affiant sayeth naught. ~~ A FIANT SWORN TO AND SUBSCRIBED in my presence this day of ~~~ ~ pF PENNSYLVANIA ___--...__ ~ptllf~a! Se~~ ~ L. (~autt, Nc~Y ~` ' BSI" N TARY PUBLIC dV9r`~ qq~r ~ V;,;,dwi '` ^':J1 Y~~--=' ,'~ iVa11~ AY6:+'.wtli.".; ;f d"~"J=`.1138 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 Page 1 of 2 SEP-24-2007 05:41:54 +~ Last Name First/Middle Begin Date Active Duty Status Service/Agency MATSON 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. ~ ~-~ 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. §§ 501 et seq] (5CRA) (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 9/24/2007 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:PBECDXSLCD https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/24/2007 J E d Q C.s.~ .+. -~t`t ~ ~ ~ .1' .. ~~' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C[VIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No.: 07-3307-C[VIL TERM MICHAF,L L MATSON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on ~ p3JD7 (xx) Assutnpsit Judgment in the amount of $2078.20 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: ~3 PROTHONOTARY (OR DEPU ) MICHAEL L MATSON 302 VALLEY ST POB 67 SUIVIMERDALE,PA 17093 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7~' Avenue, Pittsburgh, PA 15219 1-888-434-0085