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HomeMy WebLinkAbout09-0548 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: Oq- 54$ ol1Vi l T?nK VS. MICHAEL B VANNOY 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06923273 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 MICHAEL B VANNOY 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: MICHAEL B VANNOY 707 PEAR ST APT 4 LEMOYNE, PA 17043 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2622 . 4. Defendant made use of said credit card and has a current balance due of $2271.47 , as of November 10, 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 6.000W per annum on the unpaid balance from November 10, 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 , MICHAEL B VANNOY , INDIVIDUALLY , in the amount of $2271.47 with continuing interest thereon at the rate of 6.000s per annum from November 10, 2008 plus costs. James War ro t,42524 WELTMAP, EINBERG & REIS CO., L.P.A. 436 Y7e3 h Avenue, Suite 1400 Pit, PA 15219 (417955 FAX 38-7130 069 N Pit TSW This lawfirm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. HOUSEHOLD BANK PLATINUM MICHAEL B VANNOY ACCOUNT SUMMARY ACCOUNT 5491.1000-0700.2022 NUMBER TOTAL CREDIT LIMIT $2,000 TOTAL CREDIT UNIT So AVAILABLE STATEMENT DATE 0=20011 PAYMENT SUMMARY MINIMUM PAYMENT' $81.00 PAYMENT DUE DATE 0711 5108 OVERUMIT AMOUNT $271.47 PAST DUE AMOUNT $471.00 CURRENT PAYMENT DUE' $552. To evcid edd/Abnef Ants endbr ovwgn* Arse, YOU must pay the Current PrArwd Due (which larch det be ANnNnum Peymsnt and any Past Duo and& Omfto Amount). •Ses About Your Payment on reverse for an Pape 1 Of 1 BALANCE SUMMARY PREVIOUS BALANCE $2,179.13 PAYMENTSICREDITS $0.00 PURCHASESIDEBRS + $35.00 FINANCE CHARGE + $57.34 NEW BALANCE = $2,271.47 TRANSACTION SUMMARY (For additional transaction detail go to vvww.householdbank.com) TRANS POST TRANSACTION REFERENCE AMOUNT 1?71a 2&M DESCRIPnDN NUMBER CHARGES CREDITS OSM 3 00113 OVERUMI T CHARGE ASSESSMENT 1000000103000099970700 $3500 FINANCE CHARGE CALCULATION This is a grace account Grace period information on back Average Daily Days FINANCE CHARGE Nominal ANNUAL Daily Periodic in At Periodic Cash Advance! Annual PERCENTAGE Balance Rails Billing Rate Transaction Fees Percentage RATE PURCHASES Cycle $2,217.02 0.080w%(v) 32 $57.34 $0.00 Rate 29.49%(v) 29.490x, CASH ADVANCES $0.00 0.mw%(v) 32 $0.00 $0.00 29.49%(v) 29.490% M Ind', - variable rats -/ MAIL PAYMENTS TO: HSSC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 ! QUESTIONS? 2444OUR CUSTOMER SERVICE 14500452-2015 OUTSIDE USA, COLLECT: 1-7574234550 TOO HEARING IMPAIRED: 1.500 X5.5020 Q Meneps your weount oniftm at: www.househok bardwom ® MAIL IINQUIIRIES TO: HSBC CARD SERVICES PO BOX 81522 SAUNAS CA 93912-1622 090750 51 21 0000000103 G STMT37 D D 00028183 HDP1 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Cheek Now Balance $2,271.47 14nimum Payment $81.00 Payment Due Dds 07nS008 Current PafmwA 0w $552.00 Inchtds account number on check to HSBC CARD SERVICES. Do not send cash. Send payment 7 to 10 dabs prior to Payment Due Date to astatine timely del". To avoid additional bits endtor ovedimit fees, pay the Current Pa~ Due. Amount Enekaed 11ICHAZL B VARNO! rlndlllrl'II111111i'I1II111111'all I1111111111111111111eh11Jill 707 PZM ST APT 4 LZWOTN! PA 17043-1944 H=C CARD S=VICzz PO BOX 17051 Illlrlrlrlllllllllrlrrllllllllll'Illlllllrlllllrlrrllllllllirrlll BALTIMM DID 21297-1051 la-- s ¦aa?s X W 549110000700262200055200002271475 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. Section 4904 relating to unworn 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. -( A&? ke)1?MA4JJ VALERIE DEMARAIS 06923273 5491100007002622 $2271.47 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. +? oo r n v co ©© -' =a cn -c SHERIFF'S RETURN - REGULAR CASE NO: 2009-00548 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC BANK NEVADA N A VS VANNOY MICHAEL B NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VANNOY MICHAEL B the DEFENDANT at 0019:45 HOURS, on the 17th day of February-, 2009 at 707 PEAR ST APT 4 LEMOYNE, PA 17043 MICHAEL B VANNOY by handing to DEFENDANT 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 28.80 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 56.80 02/18/2009 WELTMAN WEINBERG & REIS Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. C cu ,+r0-# IN THE &OWS COURT OF Z1,,-t00,&A&'UNTY, STATE OF f9dA1AKP4 XA*-4 Plaintiff, vs. X Y*4'&iy Defendant 'ASE NUMBER: 0 9 _?3W 41J'I-L 7e"O.I ANSWER TO COMPLAINT COMES NOW the Defendant in the above styled cause to answer the Plaintiffs Complaint as follows: ee-ti w' 4.ojex,,,..4 H-r7i.1 Fweew.- Aard? Zdc.arr T.,e.PowY.i- ?'? ?CG/ry?J dk'?rs'mor Pe e,-,,e ,Or -7., 1000.104t- f3,uW ?Iiv,.•7i/rrj M.0W,r Mcf? ?..iQ?'??e? ?..AS ?(!iT dNw??j?f ?m G 10'Ae AV, 1"J' ,4A.0 y.e /'7? i ••? fix- 7'S, -7 .40*1 4440 /'i S/r 7fA.4 7i,Id 1_2i k4 ,o q /,t..?. w *rr 6_1DA r ?404''D Rol-a" 70 G'yGdwTiv4r Ze'e' "G fAdS /4 W-0 l wl.+s7, Dated this /f'1RQL?1 200 `r Respectfully Submitted, Signature CERTIFICATE OF SERVICE W_ I, the undersigned, hereby certify that I have served the Plaintiff or its attorney with a copy of this pleading by US mail, postage pre-paid, on this the S day of.0AWH , 200-47 M_1? I " Defendant r co ,?