The URL can be used to link to this page

Home My WebLink About07-4309 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. CIVIL DIVISION HSBC BANK NEVADA, N.A ~y~`~ Plaintiff No; 67_ ~l30 /~ l..cvc-f' ~~ vs. DAVID G HENCH COMPLAINT IN CIVIL ACTION Defendant 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 05669908 C N Pit KXW ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION H5BC BANK NEVADA, N.A Plaintiff vs. DAVID G HENCH Defendant Civil Action No ~7- ~i3vq ~ ~~-- 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: DAVID G HENCH 413 MEADOWBROOK RD COLEBROOK, PA 17015 3. Defendant applied for and received a credit card bearing the account number 5491100004245851 . 4. Defendant made use of said credit card and has a current balance due of $1558.09 as of May 17, 2007 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 0.000$ per annum on the unpaid balance from May 17, 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 DAVID G HENCH INDIVIDUALLY in the amount of $1558.09 with continuing interest thereon at the rate of 0.000 per annum from May 17, 2007 plus costs. James C. Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 ev th Avenue, Suite 2718 Pit sbu gh, PA 15219 (4 2) 4-7955 F 2-338-7130 0 66 08 C N Pit KXW This law firm is a debt collector ante pting to collect this debt for our client and any information obta(~ d will be used for that purpose. HGUSEHOLD BANK PLATINUM MASTERCARD STATEMENT DAVID G HENCH ACCOUNT SUMMARY ACCOUNT 5491-1000-04245851 NUMBER TOTAL CREDIT LIMIT ;750 TOTAL CREDR LIMIT SO AVAILABLE STATEMENT DATE PAYMENT SUMMARY OVERLIMR AMOUNT ;733.19 MINIMUM PAYMENT' $53.00 CURRENT PAYMENT DUE' $788.19 PAYMENT DUE DATE 03/02!07 PAST DUE AMOUNT $233.00 'See reverse side for an e~lanatwn of ' these amourds. lM~tc Ca, \\\iJ Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE 51,445.29 PAYMENTS/CREDrTS - $0.00 PURCHASESIDEBRS + ;0.00 FINANCE CHARGE + 37.90 NEW BALANCE _ $1,483.19 - _ ---- TRANSACTION SUMMARY (For additional transaction detail go to vvww.householdbankcom) TRANS POST TRANSACTION REFERENCE AMOUNT DATE DATE DESCRIPTION NUMBER CHARGES I CREDRS FINANCE CHARGE CALCULATION This is a grace account Graz period information on back Average Daily Days FINANCE CHARGE Nominal ANNUAL Daily Periodic in At Periodic Cash Advance/ Annual PERCENTAGE Balance Rate Billing Rate Transaction Fees percentage RATE Cycle Rate BALANCE TRANSFER 5905.78 0.08354% 31 $23.46 $0.00 30.48% 30.480% PURCHASES $557.77 0.08354% 31 $14.44 50.00 30.49% 30.490% CASH ADVANCES $0.00 0.00000% 31 $0.00 $0.00 29.99% 29.980% \, ~ MAIL PAYMENTS TO: HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 '~' QUESTIONS? 24HOUR CUSTOMER SERVICE 1-800.482-2018 OUTSIDE USA, COLLECT: 1 757523-3680 TDD HEARING IMPAIRED: 1-800-395-9020 ~ Manage your account online at: www.househokibank.com ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 81822 SALINAS CA 93912-1622 090750 N 05 0000000103 G STMTXO 2 J 00010912 EXCP7 PLEASE DETACH AND RETURN BOTTOM PORTION WffH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check Account Number 5491-1000-0424-0851 Vew Balance ;1,483.19 payment Due Date 03/02/07 Current Payment Due 8788.14 Make dlecks payable to HSBC CARD SERVICES. Please write your account number on your check. l7o not fold, staple or dip. Do not send cash. Please send your payment 7 days prior to the payment due date fo ensure limey delivery. Amount Enclosed DAVID d• HENCH 413 MEADOWBROOK RD CARLISLE PA 17015-8903 I~rtlllrtrllir~tt~~llrltl~ltrlritlr~lltrt~rll~~r~il~tllt~~lrll HSBC CARD 38RVICE3 PO BOX 17051 BALTIMOR& MD 21297-1051 IrrlrLrrlLrLILIr~LrrLtrllllrrttLlr~rrllrrlJl 549110000424585100078619001483199 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# c~ !`a <.. - ~-_~ , _ ~.~ ----~~ ~ ~ r') D~ W r ~ ~ ~ d _ ~- ~1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. DAVID G HENCH Defendant No. 07-4309-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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#05669908 ~ -~. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No. 07-4309-CIVIL TERM DAVID G HENCH Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG &REIS CO., L.P.A. By: ~. William T. Molczan, E uire PA I . D. #47437 WELTMAN, WEINBERG &REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 SWORN TO AND SUBSCRIBED ~CO-M°NIGNW'E"'"ALT_N OF PENNS~YLV-A-N-I-A~ 1It ....... 1.J...• L . ~ :,1 ~.. ~ ~ ~ ~ ~, ~1~~ !~_ before me this ~~`.~ day - . . ~~ A \.:..' ~~ . ,. w ` .-~1 . ~ -~.