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Home My WebLink About09-0547 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: 0Q- 547 aTex*, VS. COMPLAINT IN CIVIL ACTION NANCY M SLASEMAN 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06907420 C N Pit TSW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. Civil Action No NANCY M SLASEMAN 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: NANCY M SLASEMAN 437 KERRSVILLE RD CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4939 . 4. Defendant made use of said credit card and has a current balance due of $3313.72 , as of November 04, 2008 . 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 November 04, 2008 . 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 , NANCY M SLASEMAN , INDIVIDUALLY , in the amount of $3313.72 with continuing interest thereon at the rate of 6.000% per annum from November 04, 2008 plus costs. -- MON uw4.vuI.,'* 6D &'* WELTMANBERG & REIS CO., L.P.A. 436 SeAvenue, Suite 1400 Pitt sbPA 15219 (412) 55 FAX: 4 -7130 069074 Pit TSW This law firm is a debt collector attempt n to collect this debt for our client and any information obtained i 1 be used for that purpose. HOUSEHOLD BANK PLATINUM NANCY M SLASEMAN ACCOUNTSUMMARY ACCOUNT 5491.1000-1581-4939 NUMBER TOTAL CREDIT LIMIT $2,800 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE PAYMENT SUMMARY MINIMUM PAYMENT' $70.00 PAYMENT DUE DATE 08/12008 OVERLIMIT AMOUNT 535490 PAST DUE AMOUNT $184.00 CURRENTPAYMENTDUE' $424 To avoid adddbrurf Asia and br ovarfimd urea, You must pay the Current Payment Due (Which includes the Minimum Payment and any Past Due and/r Overf d Amounts). •See About Your Payment on reverse for an L? Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $3,048.90 PAYMENTS/CREDITS - $0.00 PURCHASES/DEBITS + $70.00 FINANCE CHARGE + 538.00 NEW BALANCE = $3,154.90 TRANSACTION SUMMARY (For additional transaction detail go to www.househoktbank.ccm) TRANS POST TRANSACTION REFERENCE DATE RAM DESCRIPTION NUMBER AMOUNT CHARGE CREDITS 07111 07/11 LATE CHARGE ASSESSMENT 100000010300009p98p4pgp 07111 07/11 OVERLIMIT CHARGE ASSESSMENT $35'00 100000010300009994080 $35.00 BALANCE TRANSFER PURCHASES CASH ADVANCES (4 indicates variable rate ? MAIL PAYMENTS TO: HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 2 QUESTIONS? 24-HOUR CUSTOMER SERVICE 1-800482-2018 OUTSIDE USA, COLLECT: 1-757523.3880 TOO HEARING IMPAIRED: 14800-395-g020 12 Manage your account online at: VVW househoidbanL- com ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO Box 81822 SALINAS CA 83912.1822 090750 5 N 18 0000000103 G STMTXO 2 K 00030811 EXCPT PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check FINANCE CHARGE CALCULATION This is a grace account Grace period inhumation on back. Average Daily Days FINANCE CHARGE Dail P i di Nominal ANNUAL y er o c in At Periodic Cash Advance/ Balance Rate Billing Rate Transaction Fop Annual Percentage, PERCENTAGE RATE $489.92 0.04107%(v) 30 $8.04 0.00 $2 593 89 0 0 RON Rah 14.99%(20 14.990% , . . 4107%(4 30 $31.98 $ 50.00 $0.00 0 08000%(4 30 14.98%(4 14.980% . $0.00 $0.00 21.90%M 21.900% Include account number on check to HSBC CARD SERVICES. Do not send cash, Send Payment 7 to 10 days prior to Payment Due Date to ensure timely delivery. To avoid additional late and/or overllmft fees, pay the Current Payment Due. New Balance 53,154.90 Minimum Payment $70.00 Payment Due Date O8M 2108 CURerrt Payment Due $434 90 Amount Enclosed 3 M BVXLLzAN 4 11111111 8 437 7 PQRRBVILLE RD g CARLISLE PA 17015-9421 SSMC CARD BZRV1CZ8 I"'II'II'I'1iI'I"'IIIIII'IIIIIIIIII'III"dlullr111IIIIIIII'I PO BOX 17051 BALTIMORR ND 21297-1051 I-ass a?a>. co MONSOON X x Liu 549110001561493900042490003154906 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is, VALERIE DEMARAIS, employee, of HSBC BANK NEVADA, N.A., plaintiff herein, that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. ?Y4L,kl AAa44411? VALERIE DEMARAIS 06907420 5491100015614939 $3354.79 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 44- 3 in R, oo O t OD SHERIFF'S RETURN - REGULAR CASE NO: 2009-00547 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC BANK NAVADA N A VS SLASEMAN NANCY M RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon ' CT A C!VM21TT ATAAT("V M the DEFENDANT , at 0017:03 HOURS, on the 5th day of February , 2009 at 437 KERRSVILLE RD CARLISLE, PA 17015 by handing to a true and attested copy of NOTICE COMPLAINT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 1.00 ? 6.30 ii•I . 00 10.00 R. Thomas Kline .00 34.30 02/06/2009 WELTMAN, WEINBERG & RIES By day Deputy Sheriff A.D. C7 -TI FTi 5rrt ?T ~ J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. NANCY M SLASEMAN Defendant No. 09-547 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06907420 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No. 09-547 CIVIL TERM NANCY M SLASEMAN 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: Attorney for la intiff 1400 Kop rs uilding 436 Seve h enue Pittsburg , P 15219 (412) 43 55 WWR#06 07420 SWORN TO AND SU CRIBED before me this day s .rte i177 ' .sue ,.. ? t ,-«y cf F5