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Home My WebLink About09-1233IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff VS. NOREEN K GARNEY AKA NOREEN GARNEY Defendant No : C R- /ate 0,W64 to wt 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06104250 C N Pit TSW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff VS. Civil Action No NOREEN K GARNEY AKA NOREEN GARNEY 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 ages, 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 a9fainst 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 CARDMEMBER SERVICES *AMMQUESr PO BOX 17151 BALTIMORE MD 21297-1151 • - "J ° PaymerMS Payable To: HSBC Card Services ACCOUNT NUMBER UN 00101323 6726 STATEMENT NEW DATE BALANCE MHIIN/M AMOUNT PAST PAYMENT MUST AMOUNT PAYMENT DUE DUE BE RECENED BY ENCLOSED 06!31107 0.00 0.00 0.00 09/22107 $ ?--? O New a0enue or errre ? Check box. See reverse skb. SEND PAYMENTS TO: 324 ss _ D PO BOX 1386 PAYMENT CENTER MECHANICSBURG PA 17055-1386 PO BOX 17313 rrrlllrrr111rrrrlLlrrlrlrrrrllrrIIrl.h.Il. BALTIMORE, MD 21297-1313 h.1.111.111... rrlrlrrIll..ILIlr1.r1.rr1'..1lrrlI.... II..11.11....1.h.Ih. 545800401323972600000000000000007 Detach and Inert this bP portion In Ow enctoea0 envelope. Be ass the Peymera Canter address show- In Sr envelope wkelow. - AkAMER101U.EST"` A VIEW OF YOUR RECENT CHARGES AND CREDITS Pay Online, ADyum e: WWwA=MnteanbukmflnB.C= TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION CREDITS ?VGES PAYMENTS AND CREDITS 08/31 0881 F8000007K00999990 CHARGE OFF ACCOUNT-PRINCIPALS 08/31 08131 F880000700999990 CHARGE OFF ACCOUNT 'FINANCE CHARGES' YOUR ACCOUNT SUMMARY - AUGUST ACCOUNT AND PAYMENT DEFORMATION CREDIT LINE INFORMATION ACCOUNT NUMBER 5456 0040 1323 0726 TOTAL CREDIT LINE $ 5000 NCE $7079.93 NEW BALANCE GAG TOTAL AVAILABLE CREDIT 0 + 0.00 EMtBNNE PAYIOENT DUE OAS CASH ADVANCE CREDIT UNIM 4640 It + 0.00 AMOUNT PAST DUE OAO CASH ADVANCE AVAILABLE CREDIT O - 7079.93 PAYMENT MUST SE OVERLIMIT AMOUNT 0. 04 NT8 - D.00 REcEIV W BY MP 22,2W7 'CASH ADVANCE CREDIT LIMIT M A ? R + Om OAO OAO CARDMEM BER SERVICE :1-M6M4,1428 PAYMENiT BY -PAY-CARD FROM OUTSIDE THE U.S. CALL COLLECT: 904-OB7 IMPAIRED-TDD CUSTOMERS CALL: 877-902-0987 SEND PAYMENTS TO: PAYMENT X 1771; BALTIMORE, MD 21!07-1313 MAIL INQUIRIES TO: CARDMMEMi PO BOX UK CAROL STREAM, L S01S7-1011 NOTICE: SEE IMPORTANT INFORMATION. aYn. Pry o -, : www whoffidnalwillite.eom A SUMMARY OF YOUR FINANCE C CLUDING PROMOTIONAL OFFERS NOMW,AL NUMBER AVERAGE ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING TE RATE CHARGE RATE CYCLE DA PURCHASES 0. .00215 X 29.99% 0.00 20.00 % CASH ADVANCES 0.00 .00218 % 29.99% 0.00 20.0 % 30 08131/07 5994 0000 XPD 2 5 6 070831 2 X Page 1 of 1 8800 4000 769P 01BTS994 0 ?a ca 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. as successor in interest to Direct Merchants Credit Card Bank, 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. VALERIE DEMARAIS 06104250 5458004013239726 $7079.93 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ? N tom- ? -,-? u:? `? ri-; L .-,;? c? ` ? ??_. ? ? ,. -? '+^? ?i?1 ? v ` N -?c? ? ? ? L ? W ?y ? t ??:. ? ,y _, , Sheriffs Office of Cumberland County R Thomas Kline ?u?tv of ClImbr Edward L Schorpp Sheri tSolicitor Ronny R Anderson •? Jody S Smith Chief Deputy CFACE OF T+* SHERI" Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/05/2009 12:34 PM - R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Noreen K. Garvey a/k/a Noreen Garvey at 8 North Market Street, Mechanicsburg, Cumberland County, Pennsylvania but was unable to locate her in his bailiwick he therefore returns the within Complaint as not found as to the defendant, Noreen K. Gamey a/k/a Noreen Garvey. Her mail is delivered at this address but according to current resident defendant does not live there. SHERIFF COST: $42.00 (PAID) March 16, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 2009-1233 HSBC Bank Nevada, N.A. VS Noreen K. Gamey By Deputy Sheriff C-) r.a CZ* r,,J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff vs. No. 09-1233 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT NOREEN K GARNEY Defendant(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA ID #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#6104250 CH2 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff vs. Civil Action. No. 09-1233 CIVIL TERM NOREEN K GARNEY Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG &REIS CO., L.P.A. By: James C. W PA ID #425 WELTMA 1400 Kop e Esquire ERG &REIS CO., L.P.A. uidling 436 Sev nt Avenue Pittsbu , PA 15219 (412) 434-7955 WWR #6104250 ~-tLF~t-, -~ ~„- r r, ~~~ti1 z~~~~~~ ~~ ~'!rl ~~ f CtiPuv j. ` s . ~ i :~'`~ f $lo.oo I~c~J~-~ c~ SQtSVZlP t2~--~3is 8~ C-„ f„r r5 y?M ? ? ?1f t fCty 2 7 IN THE COURT OF COMMON PLEAS OF CUMBI ? 4q 'Y, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA, Plaintiff, vs. NOREEN K GARNEY A/K/A NOREEN GARNEY, Defendant. Case No.: 09-1233-CIVIL TERM MOTION FOR SUMMARY JUDGMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R. Bibler, Esquire PA I.D. #93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6104250 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA, Plaintiff, Case No.: 09-1233-CIVIL TERM vs. MOTION FOR SUMMARY JUDGMENT NOREEN K GARNEY A/K/A NOREEN GARNEY, Defendant. MOTION FOR SUMMARY JUDGMENT AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co., L.P.A., and hereby files this Motion for Summary Judgment against the Defendant. In support thereof, Plaintiff avers as follows: Plaintiff filed a Complaint against Defendant seeking judgment in the amount of $6,728.50 with interest at the interest rate of 6.00% per annum from December 3, 2008, and costs. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and made a part hereof. 2. Defendant filed an Answer to Plaintiff's Complaint. A true and correct copy of the Answer is attached hereto as Exhibit "B" and made a part hereof. 3. On or about September 10, 2010, Plaintiff served upon Defendant a set of requests for admissions and requests for production of documents A true and correct copy of same is attached hereto as Exhibit "C" and made a part hereof. 4. Defendant served upon Plaintiff her Answers to the discovery demands. A true and correct copy of the same is attached hereto as Exhibit "D" and made a part hereof. 5. Defendant admits that she applied for the credit card; that the last payment on the account was made on May 2, 2007, and that she has not submitted a dispute as to any billing inaccuracies. 6. Defendant generally denies the remaining requests, but fails to, as required, provide any explanation or documentation supporting the denial. 7. No documents have been received from Defendant and she has failed to explain or provide support for her denials. WWR No. 6104250 8. Defendant has been given ample opportunity to provide evidence or information substantiating a defense here. 9. Defendant has failed to provide any documentation to refute the existence of this debt. 10. Nowhere in the pleadings does Defendant provide any proof of payment on the credit card debt. 11. Defendant's general denial of the debt is not an issue of material fact. 12. Bald unsupported assertions of conclusory accusations cannot create a genuine issue of material fact to preclude the entry of summary judgment. McCain vs. Pennbank, 379 Pa. Super. 313, 549 A.2d 1311 (1988); Golaschevsky vs. Commonwealth Department of Environmental Resources, 683 A.2d 1299, 1302 (Pa. Cmwlth., 1996). 13. There are no meritorious defenses against this action and Plaintiff is entitled to summary judgment as a matter of Law against defendant. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant summary judgment in favor of Plaintiff and against Defendant for $6,728.50 with interest at the rate of 6.00% per annum from December 3, 2008, and costs. Respectfully Submitted: By: l/ Benjarri' bler, Esquire PA I.D. #9359 WELT AN, INBERG & REIS CO., L.P.A. 1400 Ko Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6104250 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff No: vs NOREEN K GARNEY AKA NOREEN GARNEY 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: 412-338-71.30 06104250 C N Pit TSW EXHi?lT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff vs. Civil Action No NOREEN K GARNEY AKA. NOREEN GARNEY 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. AS is a corporation with offices at 1111 TOWN CENTER DRIVE LAS VEGAS , NV 89193 2. Defendant is adult individual(s) residing at the address listed below: NOREEN K GARNEY 8 N. MARKET ST. MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9726 . a. Defendant made use of said credit card and has a current balance due of $6728.50 , as of December 03, 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 6.0000 per annum on the unpaid balance from December 03, 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 , NOREEN K GARNEY , INDIVIDUALLY , in the amount of $6728.50 with continuing interest thereon at the rate of 6.000% per annum from December 03, 2008 plus costs. This law firm is a debt collector at our client and any information obtai r - James C. rmbro ,42524 WELTMAN W TNBERG & REIS CO., L.P.A. 436 Se ent Avenue, Suite 1400 Pitts rgh PA 15219 (412) 434. 955 FAX: 412- 38-7130 0610 250 C N Pit TSW tem t - g to collect this debt for used for that purpose. ned 11 be CARDMEMBER SERVICES *AMMQUEST PO BOX 17151 BALTIMORE MD 21297-1151 Payments Payable To: HSBCCard Servioes ACCOUNT NUMBER 5468 0040 13Z: STATEMENT NEW MIMMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 06/31/07 O.OD 0.00 0.00 09122/07 $ C D Nor atl4taac er ama04 CAOfA DPx SAP nr.rra sMr. SEND PAYMENTS TO: 324 y? NOREEN K GARNEY O PO BOX 1386 PAYMENT CENTER MECHANICSBURG PA 17055-1386 PO BOX 17313 BALTIMORE, MD 21297-131.3 NIL, Iti „.I,I,.I,L,,,lI„ILf.,6 1f.,1, !„il„IL „II,L„1I..LII.I„L„L IL II,,.,II fl.11n, Lh !i„ 545800401323972600000000000000007 DOmch and Instil Oft top ponbn M Ihs mdmW envelope. Be are 0n P.Yymant Censer aadesc:Mwr M O.e mrrlpp¢..L+imv. *AMMO_UEST A VIEW OF YOUR RECENT CHARGES AND CREDITS Pay Online. Anylims: wwwaecountcenMalonllne.wm TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION CREDITS GES PAYMENTS AND CREDITS 08/31 o5A1 FBlb0007KDDO99990 CHARGE OFF ACCOUNT-PRINCIPALS 5630 DO/3i 08131 F650DOD7KD099999D CHARGE OFF ACCOUNT 'FINANCE CHARGES' YOUR ACCOUNT SUMMARY-AUGUST ACCOUNT AND PAYMENT INFORMATION CREDIT LINE MFORMATION AC Y ACCOUNT NI/MBER 5458 am 1321 ms TOTAL CREW LINE SSW P $7079.93 NEW BALANCE 0.08 TOTAL AVAII.ABIE CREW 0 • 0.00 Mmmum PAYMENT DUE amp CASH ADVANCE CREDIT UMTr 4640 NOES t 0.00 ANOUNT PAST DUE am CASH ADVANCE AVAILABLE CREDIT O - 7079.95 PAYMENT MUST BE OVERLIMRAMOUM oa MS - 0.00 RECEIVED BY SEP 22V 2007 'CASH ADVANCE CRED" LIMIT IS A ? 0.00 PORTION OF YOUR TOTAL CREDMME FINANCE CHARGE . 0.00 NEW BALANCE • 0.00 CARDMEMBER SERVICE '1-866864 1423 PAYMENT IN -PAY-CARD FROM OUTSIDE THE U.S. GALL COLLECT: 804-997 IMPAIRED-TDD CUSTOMERS CALL 677-9D2-0067 S84D PAYMENTS TO: PAYMENT X 11`313, BALTIMORE, MD 21297-1317 MAIL INQUIRIES TO, CARDMEM'BIER S PO BOX 5730, CAROL STREAM, IL 60197-9641 NOTICE: SEE IMPORTANT INFORMATION. Pay 040m ww mowleera atonlh com A SUMMARY OF YOUR FINANCE C CLUDWG PROMOTIONAL OFFERS q9L It NOM94AL NUMBER AVERAGE ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERCENTAGE FINANCE PERCENTAGE IN H WG CLOSING h RATE CHARGE RATE CYCLE DATE PURCHASES D. .08216 % 2939% 0.00 29.99% CASH ADVANCES O.OD .08215% 29-"% 0.00 29.99% 30 oar31/07 5994 0000 XPD 2 5 6 070831 L X Page 1 of 1 8800 4000 769P CIST5994 D y N 6* t } 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. as successor in interest to Direct Merchants Credit Card Bank, 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. LV-g?A- "44 VALERIE DEMARAIS 06104250 5458004013239726 $7079.93 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. In the Court of Common Pleas of Cumberland County, Pennsylvania. Civil Division HSBC Bank Nevada, N.A. as Plaintiff VS. Noreen K. Garney Defendant(s) No. 09-1233 Civil Term Answer -?j t ,HIBa Defendant, Noreen Garney, Answers Plaintiffs Complaint and says, 1. without knowledge, therefore deny 2. deny I deny 4. deny 5. deny 6. deny 7. deny The attorney for the plaintiff has not provided me with a signed copy of a contract and cardholder agreement and/or a promissory. By way of this answer I am disputing the validity of this debt. November 2, 2009 Noreen Garney 501 Cascade rd. Mechanicsburg, Pa. 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION FISBC BANK NEVADA, NA, Plaintiff, V. NOREEN K. GARNEY Defendant. NO.: 09-1233-CIVIL, 'I'i.R?vl PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION OF DOCUMENTS Plaintiff demands that the defendants answer and respond to the following Request for Production of Documents under oath pursuant to the Pennsylvania Rules of Civil Procedure within 30 days from the date of service hereof. Plaintiff also demands that defendants answer and respond to the following Request for Admissions pursuant to Pa. Rules of Civil Procedure 4014. You are requested to admit the truth of each of the statements of fact hereinafter stated. You are instructed that: 1. 'these requests are made under Pennsylvania Rules of Civil Procedure 4001, et seq., and each of these matters of which an admission is requested shall be deemed admitted unless your sworn statement in compliance with such Rules is timely made. 2. If you do not admit each of such statements, you must specifically deny each one not admitted or set forth in detail the reasons why you cannot truthfully either admit or deny each such matter. 3. Your answer, signed and properly verified, must be delivered to the undersigned attorney of record for the Plaintiff within thirty (30) days after delivery hercol'. 4. If you fail or refuse to admit the truth of any such statement of fact and the Plaintiff thereafter proves the truth thereof, you may be required to pay the reasonable expenses incurred in making such proof, including attorneys' fees, witness expenses, etc. 5. If, in response to any of the following statements of fact, it is your position that the statement is true in part or as to some items, but not true in full or as to all items, then answer separately as to each part or item. 6. If you have been sued in more than one capacity or if your answers would be different if answered in any different capacity, such as partner, agent, corporate officer or director or the like, then :" F1 I" B rIT c you are requested to answer separately in each such capacity. Failure to do so constitutes an admission in any such capacity. 7. In these Requests for Admissions: A. The word "person(" means all entities, and, without limiting the generality of the fore11oin'", includes Natural persons, joint owners, associations, companies. partnerships, joint ventures, trusts, and estates; B. The word "dOCL111lep_t Y" means all written, printed, rccordcd. ! raphic, or photographic matter, or, sound rcproductiuns, however produced or reproduced, pcrtai 1110 to any manner to the subject matter indicated; C. The words "identity", "identify", "identification", when used with respect to a person(s) means to state the full name and present or last known address and business address of such persons and, if an actual person, his present or last known job title, and the name and address of' Ills present or last known employers; D. The words "identity", "identify" "identification", when used with respect to a date, subject matter, name(s) or person(s) that wrote, signed initialed, dictated or otherwise participated in the creation of the same, the name(s) of the addressee or addressees iii any and the name(s) and address(es) of each person who have possession, custody, and control of said document S). If any such document was, but is no longer in your possession, custody, or control, or in existence, state the date and manner of its disposition; and L. The word "identify", when used with respect to an act (including an alleged offense), occurrence, statement, or conduct (hereinafter collectively called "act"), means to (i) describe the substance of the event or events constituting such an act, and to state the date when such act occurred-, (2) identify each and every person( participating in such an act; (3) identify_all other person(s) rson(ss) (if any) present when such act occurred; (4) state whether any minutes, notes, memoranda, or other record of such act was made; (5) state whether such record now exists; and (C) identify the person (,s) presently having possession, custody or control of such record. 8. Unless otherwise indicated, all Requests herein relate to those certain events, persons, and period of time more fully described in the pleading in this case. 9. These requests are of a continuous nature. These Requests for Production of Documents shall be deemed continuing so as to require supplemental answers and documents if any information of documents are acquired subsequent to the tiling of responses hereto, which information or documents would have been included in the answers and documents produced had it been known or available at the time the answers and the docllmcnts provided pursuant hereto were produced. Defendants shall supply such information and documents by supplemental answers and production of documents as soon as such information becomes known or available and in all events, prior to trial of this action. If objection is made to any requests for production of documents, it is demanded that the requests for which there is no objection be answered and furnished within the aforesaid period. All documents identified in response hereto shall be organized and labeled to correspond with the request to which it pertains. For all documents produced, list the individual and his or her job title and department from whose files it was produced and the current custodian of said document. If a doCUn7ent called for is believed to exist or is known to exist, but is in the possession. Custody or control of another person or party, the existence of the document, the identity of the possessor, custodian and one in control of such documents shall be provided along with any applicable common description or citation utilized by the publisher, possessor, custodian or disseminator oFsuch document. If any document called For by this request is withheld on the basis of any claim of- privilc, c or anv similar claim, identify that document as lollows: author; addressee; indicated or blind copies, date, subject matter; number of pages; attachments or appendices; all persons to whom distributed, shown or explained; present custodian; and nature of the privilege or similar claim asserted. REQUEST FOR PRODUCTION OF DOCUMENTS l : Produce any and all documents evidencing proof of all payments on the subject credit card referenced in the Complaint, including, but not limited to, cancelled checks, receipts, coupons, statements, accountings, memoranda, invoices, financial statements, accounting entries, diaries, charts, lists, phone records, data compilations etc. REQUEST FOR PRODUCTION OF DOCUMENTS 2: Produce any and all documents you intend to introduce and/or provide testimony on as evidence at the time of trial. REQUEST FOR ADMISSION NO. I : Defendant applied for the credit card referenced in Plaintiff's Complaint. Admitted Denied II'the ,msv\!er to Request For /admissions No. 1 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 2: The attached monthly statements, from November 4, 2006 through September 22, 2007, correctly identify the payments, charges, and balances on the account. Admitted Denied If the answer to Request for Admissions No. 2 is "denied", then supply copies of canceled checks, both fi-ont and back, and/or if not available, specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 3: fhe last payment on the account was made on May 2, 2007. Admitted Denied If the answer to Request for Admissions No. 3 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 4: Defendant has not submitted any written dispute as to billing inaccuracy concerning the credit card in question. Admitted Denied If the answer to the Request for Admissions No. 4 is "denied", then supply copies ofspecilic VNIA MCI] disputes as to any billing inaccuracies. REQUEST I;OR ADMISSION NO 5: $6,728.50 is a correct and accurate current balance of the credit card account in question. Admitted Denied If the answer to Request for Admissions No. 5 is "denied", then supply specific written documentation supporting the denial. THIS IS AN AT'TEMP'T TO COLLECT A DEBT AND AIRY INFORMATION 013` AINFI) SHALL BE USED FOR THAT PU1tPOSE. ^? x i Lyndsay owUd, Esquire -_-___ .- I'A I.D. I 05520 WLI,"fM I, WEJN13f:RG & RG1S CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-79555 W W R: 6104250 DEFENDANT'S VERIFICATION 1, , (please print) under penalty of perjury and subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities verify that the Foregoing Responses are true and correct to the best of my knowledge, information aid belief. Date Signature CERTIFICATE OF SERVICE A true and correct copy of Plaintiff's First Request for Production of Documents and Request for Admissions has been served by U.S. Mail, on the _1Q day of ?yn?( 2010, upon the hoIIOWInb: Noreen K. Garney 501 Cascade Rd Mechanicsburg Pa 17055 /. CARDMEMBER SERVICES A PO BOX 21550 TULSA OK 74121-1550 Make Payments Payable To: HSBC Card Services YOUR PAYMENT COUPON ACCOUNT NUMBER 5458 0040 1323 9726 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 10110106 5,973.64 205.00 0.00 11/04/06 @ New address or email? Check box. See reverse side. AP SEND PAYMENTS TO: }L-1 N R N K ARNEY 1 133 N U PAYMENT CENTER ICS RG PA 117055 1386 M CHA PO BOX 17313 III,.,III„„L1„IJ,,,,11..ILL.1..11„LJ.,IL,II ,, BALTIMORE, MD 21297 1313 ,J,L„III I,ILI„L„L,.II' II,,,,II„II,,,.ILJIJ,,,I 545800 401323972600020500005973641 Detach and MW this top portion in the encbsed envelope. Be -e the Pay-t CCwW add- sh w o ort the emelope window. - 77 -- aa-- , A[vlMQUESr Reward Summarv Ameriquest Ameriquesl Bonus Redeemed C (Pit Rewartis(ID Prior Rewards Earned Amerpuest Ameriquesl Am. Balance This Month Rewards Awarded Rewards Re Ce 100 0 0 0 00 A VIEW OF YOUR RECENT CHARGES AND CREDITS Pa Online, Anytime: www. Iralonline.eom fti TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION EDITS CHARGES PAYMENTS AND CREDITS 10108 10108 8545BOOM901 DZDSM6 PAYMENT-THANK YOU TULSA O - 229.98 - PURCHASES, CASH ADVANCES $ FEES 10107 10/07 LATE FEE 39.00 'FINANCE CHARGE' PURCHASES $144.64 CASH ADV 144.64 YOUR ACCOUNT SUMMARY - OCTO ACCOUNT AND PAYMENT INFORMATION ACCOUNT NUMBER $458 0010 1323 9725 NEW BALANCE 5873.64 MINIMUM PAYMENT DUE 205.00 AMOUNT PAST DUE 0.00 PAYMENT MUST BE RECEIVED BY NOV 4, 2006 TOTAL CREDIT LIRE $5800 TOTAL AVAllABLE D D CASH ADVANCE C Z 4640 CASH ADVANCE DIT 0 CVERL84IT F /73.64 'CASH t AIL LIMB LS A POR CREDIT LINE. ACCOUNT SUMMARY PREVIOUS BALANCE $6019.98 PURCHASES 0.00 CASHADVANCES + 0.00 CREDITS - 0.00 PAYMENTS - 229.98 OTHER • 39.00 FINANCE CHARGE • 144.64 NEW BALANCE 5973.64 YMENT BY PHONE: 877-2-PAY-CARD 90:?CIRDMEIIIIBER WER SERVICE CENTER: 1?B6441423 FROM OUTSIDE THE U.S. T: 904-997-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0967 BEN MENTCENTER PO BOX 17313, BALTMORE, MD 21297-1313 M SERVICES, PO BOX 21550, TULSA, OK 74121-1$50 OTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION. Pay Online, Anytime: www.accourdcentralonline.com ?'!d 11.0 _ "S P?I?r Il "?a.:_ •? _ 6104250 Call 1-889-877-5295 d,: ?.-, t F;b ?Ililyocq alti_,• *AMFRIQ.UES-r ACCOUNT NUMBER 5458 00401323 9726 YOUR BALANCE EXCEEDS YOUR CREDIT LIMIT. PLEASE PAY THE OVERLIMIT AMOUNT TODAY. OR CALL OUR OFFICE AT 1-800-435-1415. EFFECTIVE 5117106. YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS: A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEPHONE. EVEN IF THE PAYMENT IS MADE BY SOMEONE OTHER THAN YOU. THE AMOUNT OF THE FEE WILL BE DISCLOSED WHEN A CHECK BY PHONE IS REQUESTED. Expand your relalionship with Amenquesf® and reap rewards. Redeem your Amenquesl RewardsO and save on an Ameriquest loan.' Call 1-888-877-5345 today. We*?( help you pay o8 debt or twy your first home. 'See insert for more details A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER - AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 6071.30 .08215% 29.99% 144.64 29.99% CASH ADVANCES 0.00 .08215% 29.99% 0.00 29.99% 29 10110106 Great News! As of August 1. 2006, you now have six (6) months from your AmenquestS Mortgage loan funding date to redeem your Amenquest RewardsO certificate. Please refer to the reverse side of your Arnenquest Rewards certificate for mom details. =d rl'U _ F, .51:11:1 l -a;. 6104250 CARDMEMBER SERVICES *AMM%= PO BOX 21550 TULSA OK 74121-1550 Wo Payments Payable To: HSBC Card Services )UR PAYMENT COUPON ACCOUNT NUMBER 5458 0040 1323 97 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 11ro8/06 6,156.73 412.00 205.00 12/03/06 ; New address or email? Check box. See reverse side. SEND PAYMENTS TO: sz4 MgRh6X 61RNEY 111 PAYMENT CENTER CHAN1. URG PA 17055-1386 PO BOX 17313 BALTIMORE, MD 21297 1313 545800401323972600041200006156?35 Detach and insert this lop portion in the enclosed envelope. Be we pR Payment Center address Shows in the -Tope winibw. - *AMMQUEST Rnwarr9 Snmm?rv Ameriquest Ameriquest Bonus Redeemed C nt Rewards@ Prior Rewards Earned Ameriquest Ameriquest Am & L. Balance This Month Rewards Awarded Rewards Re ca 100 0 0 0 D A VIEW OF YOUR RECENT CHARGES AND CREDITS Pay Online, Anytime: www.:O%%?nl-lonline.com TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION IREDITS CHARGES PURCHASES, CASH ADVANCES & FEES 11105 11105 LATE FEE 39.00 'FINANCE CHARGE' PURCHASES $144.09 CASH ADVANCE 144.09 F YOUR ACCOUNT SUMMARY - NOVEMBER ACCOUNT AND PAYMENT INFORMATION CREDIT LINE INFORM AT ACCOUNT SUMMARY Y O ACCOUNT NUMBER 54 59 0410 1323 9726 TOTAL CREDIT LINE " S, O PREVIOUS BALANCE $5973.54 NEW BALANCE 6156.73 , TOTAL AVAILABLE CREDITg D PURCHASES * 0.00 MINIMUM PAYMENT DUE 412.00 CASH ADVANCE CREDIT 4640 CASH ADVANCES 0.00 AMOUNT PAST DUE 295.00 CASH ADVANCE AV lA - T 0 CREDITS - 0.00 PAYMENT MUST BE CVERLMTAMOU 356.73 PAYMENTS - A 0.00 RECEIVED BY DEC 3.2006 'CASH ADVANC ISA OTHER • 39.00 PORTION OF REDIT LINE. FINANCE CHARGE • 144.08 4 NEW BALANCE a 6156.73 y?YU1 11 C SERVICE CENTER: 140"43423 T BY PHONE: ST7-2-PAY-CARD FROM OUTSIDE THE U.S. 997-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0957 SEND PAVME YMENT CENTER PO BOX 17313, BALTIMORE MD 21297-1313 MAIL INQUIRI DMEMBER SERVICES, PO BOX 21550, TULSA, OK 74121-1550 :S REVERSE SIDE FOR IMPORTANT INFORMATION. Pay Online, Anytime: www.eccounteentralonline.wm OUR RECORDS INDICATE YOUR ACCOUNT IS PAST DUE. IF YOU HAVE NOT MAILED YOUR PAYMENT, PLEASE DO SO TODAY. .::;.1 ..., 1h0 _ , 0511:•3 ,- P_a'r. 7... .x.E l15394 111419 6104250 Call 1-888-877-5295 ALAMBUQUES-r ACCOUNT NUMBER 5456 0040 1323 9726 YOUR MASTERCARD® CORE BENEFITS INCLUDE EXTENDED WARRANTY, PURCHASE ASSURANCE COVERAGE, SATISFACTION GUARANTEE COVERAGE, MASTER ROADASSIST® SERVICE, TRAVEL ASSISTANCE SERVICES, AND MASTERCARD GLOBAL SERVICE. FOR DETAILS. CALL 1-8DD-MCASSIST OR VISIT W W W.MASTERCARD.COMICARDHOLDERSERVICESIGUIDETOBENEFIT51 SMARTSHOPPER. EFFECTIVE 5117106, YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS: A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEPHONE, EVEN IF THE PAYMENT IS MADE BY SOMEONE OTHER THAN YOU. THE AMOUNT OF THE FEE WILL BE DISCLOSED WHEN A CHECK BY PHONE IS REQUESTED. A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE INSILLING CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 6048.23 .11112115% 29.99% 144.09 29.99% CASH ADVANCES 0.00 .08215% 29.99% 0.00 29.99% 29 11108/06 Great Newsl As of August 1, 2006, you now have six (6) months from your AmeriquesW Mortgage ban funding date to redeem your Amenquest RewardsO osrlificate. Please refer to the reverse side of your Amenquest Rewards certificate for more details. IF th, it 1"0 _ .5114? A" _ ,r _ g:,. gnri? Ol?lb: v1 1. 11A lG 6104250 *AMMQ= } CARDMEMBER SERVICES PO BOX 21550 TULSA OK 74121-1550 Make Paymentls Payable To: HSBC Card Services YOUR PAYMENT COUPON ACCOUNT NUMBER 5458 0040 1323 9726 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 12/08/06 5,925.59 209.00 0.00 01/02107 New address or email?Ctw& box. See reverse We. SEND PAYMENTS TO: 329 ARNEY a, 3l N R N K l3 M N B O T 7 Y E1? CHA RG PA 17055 1386 ICS X B 1 313 PO 111,,,111,,,,111,11,1,,,,111,1111111,111111,111111„1111, BALTIMORE, MD 21297- 1.11,111,11,11111,11,1111,11.,11,,,, 1313 11„11.,,,11,11111,1,1 545800401323972600020900005925593 DNach and insert this lop port., i1 the enclosed envelope. 8e sure the Payment Center address 5t-. the eme.pe window. *AMMQUESr ROWaf'el CIIAIrnn" Ameriquest Ameriquest Bonus Redeemed C nt Rewards® Prior Rewards Earned Ameriquest Ameriquesl Am L Balance This Month Rewards Awarded Rewards 4 Re e 100 0 0 0 00 TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION REDITS PAYMENTS AND CREDITS r 3. 11/09 11/09 8545800N9D1N8824G PAYMENT- THANK YOU TULSA . 205.64 - O 12I07 12107 8546SODP501DVA367 PAYMENT-THANK YOU TULSA 212.73 - PURCHASES, CASH ADVANCES & FEES 12/04 12104 LATE FEE?VY 'FINANCE CHARGE' PURCHASES $148.23 CASH ADVAf4C E,. TVUK AUUVHN 1 *UMMAMY - VC44CNRMK ACCOUNT AND PAYMENT INFORMATION CREDIT LINE IN ACCOUNT NUMBER 5458004013239726 TOTAL CREDIT LIN NEW BALANCE 5425.59 TOTAL AVAILABLE MINNAlMO PAYMENT DUE 209.00 CASH ADVANCE AMOUNT PAST DUE 0.00 CASH ADVAN PAYMENT MUST BE OJERLIMT RECEIVED BY JAN 2.2007 -CASH ORMAJWN rr ACCOUNT SUMMARY $ S80D PREVIOUS BALANCE $ 6156.73 I 0 PURCHASES • 0.00 4600 =? CASHADVANCES • 0.00 0 OIT ? CREDITS 0.00 125.59 PAYMENTS - 418.37 REDIT LIMIT ISA OTHER + 39.00 TOTAL CREDIT LINE. FINANCE CHARGE • 148.23 NEW BALANCE 5925.59 MBER SERVICE CENTER -966-9643423 4k '4 AYMENT BY PHONE: 877-2-PAY-CARD FROM OUTSIDE T Lrfa: 9D4-997-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0967 : PAYMENT CENTER PO BOX 17313, BALTIMORE, MD 21297-1313 M' CARlX8EMl8ER ERVICES, PO BOX 21550, TULSA OK 74121-1550 SEE REVERSE SIDE FOR IMPORTANT INFORMATION. y Online, Anytime: www.aocountcentralonlma.com 04 ..1 -,,.. ,i _ 1 .. 1: 1!,. y4 , 31 6104250 flare Do Not SwW Oedk Ord Papmasb to Wls Ad&w& CHARGES 39.00 148.23 Go" 141014"- to reelmsta loan. ?s.. ra..lrarll alr r 1.rar. for anmlt *AMEP.1Q,UFSr ' ACCOUNT NUMBER 5458 00401323 9726 YOUR BALANCE EXCEEDS YOUR CREDIT LIMIT. PLEASE PAY THE OVERLIMIT AMOUNT TODAY, OR CALL OUR OFFICE AT 1-800- 435-1415. EFFECTIVE 5/17108, YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS: A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEPHONE, EVEN IF THE PAYMENT IS MADE BY SOMEONE OTHER THAN YOU. THE AMOUNT OF THE FEE WILL BE DISCLOSED WHEN A CHECK BY PHONE IS REQUESTED. A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER AVERAGE DAILY ANNUAL ANNUAL OF UAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 6014.84 .08215% 29.99% 148.23 29.99% CASH ADVANCES 0.00 .08215% 29.99% 0.00 29.99% 30 12/08/06 Great News! As of August 1. 2006, you now have six (6) months from your AmenqueslS Mortgage loan funding date to redeem your Ameriquest Rewards40 cereficate. Please refer b the reverse side of your Amenquest Rewards Certificate for more details. 1rw ., .%d __ rhil _ Q5L'?8 / _ ?? _ :??'?. 1'.. ..., ll Ih. "s?l .. •.I 6104250 CARDMEMBER SERVICES r *AMMQ= '`tk PO BOX 21550 TULSA OK 74121-1550 Make Payments Payable TD: HSBC Card Services YOUR PAYMENT COUPON ACCOUNT NUMBER 5458 00401323 9726 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 01110107 5,917.20 223.00 .' 0.00 02104/07 New address or email? Check box. See reverse side. SEND PAYMENTS TO: s?d NpoREEN Y, ARNEY Dirt PQ BQX 1 6 PAYMENT CENTER MttttCHANlC URG PA 17055 1386 PO BOX 17313 BALTIMORE, MD 21297 1313 545800 401323972600022300005917203 Detxh and insert Its top portm in the emloeed -910pe. Be stye the PaY^>eet (:enter address shows in the elope window. *AMMQ-= Ameriquest Ameriquest Bonus Redeemed C nt Rewards®Prio, Rewards Earned Amerpuest Ameriquest Am - - Lr Balance This Month Rewards Awarded Rewards Re 'ce 100 0 0 0 00 lonline.com A VIEW OF YOUR RECENT CHARGES AND CREDITS Pay Ordine. Anytime: www. tra TRANS POST REFERENCE ms DATE DATE NUMBER DESCRIPTIONREDITS CHARGES PAYMENTS AND CREDITS 01)06 01106 85458000701 L8SLRS PAYMENT-THANK YOU TULSA 209.59 - PURCHASES, CASH ADVANCES & FEES 01102 01102 LATE FEE 39.00 'FINANCE CHARGE' PURCHASES $162.20 CASH ADV 162.20 YOUR ACCOUNT SUMMARY - JANU, ACCOUNT AND PAYMENT INFORMATION ACCOUNT NUMBER 5458 OD40 1323 grA NEW BALANCE S9t7.20 MINIMUM PAYMENT DUE 223.00 AMOUNT PAST DUE 0.00 PAYMENT MUST BE RECEIVED BY FED 4. 2007 TOTAL CREDIT LINE RED - TOTAL = S 5800 0 CASH C 4640 CASH ADVANCE DIT 0 OVERLMT 117.20 'CASH ADV LIMIT IS A POR ALCREOITUNE. ACCOUNTSUMMARY PREVIOUS BALANCE $5925.59 PURCHASES • 0.00 CASHADVANCES 0.00 CREDITS - 0.00 PAYMENTS - 209.59 OTHER 39.00 FINANCE CHARGE 18220 NEW BALANCE 5917.20 SERVICE CENTER: 1.166-86441423 YMENT BY PHONE: 877-2-PAY-CARD FROM OUTSIDE THE U.4ZLEMBER T: 904-997-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0987 SE MENT CENTER. PO BOX 17313, BALTIMORE, MD 21297-1313 CARDMEMSER SERVICES, PO BOX 21550. TULSA, OK 74121-1550 OTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION. * ^' Pay Online, Anytime: www.accountwntmimline.eorn _?•I _ Pp _ . 67011'. 6104250 Haase Do Not Send Credit Ord Paymesb to thk Address. Call 1-INISM3295 to laptrat a ban. SMRW Pa-RAN oe-e0e b rank ALAMERIQ,UEST- ACCOUNT NUMBER 5458 00401323 9726 YOUR BALANCE EXCEEDS YOUR CREDIT LIMIT. PLEASE PAY THE OVERLIMIT AMOUNT TODAY, OR CALL OUR OFFICE AT 1-80o-435-1415. Expand your relationship with AmenquestS and reap rewards. Redeem your Amenquest RewardsV and save on an Amenquest loan' Call 1-888-877-5345 today. We'll help you pay o6 debt or buy your Orsl home. 'See insert for more details. EFFECTIVE 5117/08, YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS' A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEPHONE, EVEN IF THE PAYMENT IS MADE BY SOMEONE OTHER THAN YOU. THE AMOUNT OF THE FEE WILL BE DISCLOSED WHEN A CHECK BY PHONE IS REQUESTED. A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER AVERAGE DAILY BALANCE DAILY PERIODIC RATE ANNUAL PERCENTAGE RATE ANNUAL OF DAYS STATEMENT FINANCE PERCENTAGE IN BILLING CLOSING CHARGE RATE CYCLE DATE PURCHASES 5983.00 .08215% 29.99% 162.20 29.99% CASH ADVANCES 0.00 .06215% 29.99% 0.00 29.99% 33 01/10/07 wI'a ,t Iri: 6104250 ash,, CARDMEMBER SERVICES *AMMQ,=' PO BOX 21550 6104250 EE 324 N?%N K,?AARNEY ``'"" PAYMENT CENTER M CHAN1 URG PA 17055 1386 PO BOX 17313 BALTIMORE, MO 21297 1313 111 111. 1,1,.111„11,1 ,1 11111„11,,, ,,I,1,,,11„1,11,1,,,11„11,,, 11„11 „111.1111-1 .ma- d mail? Chea box See reverse we ressore SEND PAYMENTS TO: TULSA OK 74121-1550 Make Payments Payable TO: HSBC Card Services YOUR PAYMENT COUPON ACCOUNT NUMBER 5458 0040 1323 9726 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 02108107 6,078.86 407.00 203.08 03/05/07 ` 545800401323972600040700006078863 Payment CCentt., atl,t- howIn ttheemebPe winib.. Detach and peen this top potion in the enclosed envelope. Be Sure the*AWRIQUESr ^Ameriquestl1? eriquest Am Bonus Redeemed C nt Rewards® Prior Rewards Earned Ameriquest Ameriquest Am 1, Balance This Month Rewards Awarded Rewards Re ce 100 0 0 0 00 A VIEW OF YOUR RECENT CHAMUG5 AMU L KrUI Ia ra -- TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION EDITS CHARGES ' PAYMENTS AND CREDITS 02/03 02103 854WW130105NYNJ PAYMENT-THANK YOU TULSA 20.00 - OK" , PURCHASES, CASH ADVANCES 3 FEES I 02!04 02104 LATE FEE 39.00 'FINANCE CHARGE' PURCHASES $142.66 CASH ADV 01Y' ` 142.66 ??. w ? Ml? ? YOUR ACCOUNT SUMMARY - FEBR/ ACCOUNT AND PAYMENT INFORMATION ACCOUNT NUMBER 5456 0040 1323 gr-16 NEW BALANCE 6078.68 MINIMUM PAYMENT DUE 407.00 AMOUNT PAST DUE 283.00 PAYMENT MUST BE RECEIVED BY MAR 5, 2007 TOTAL CREDIT LINE °- A S SSBOD TOTAL AVALABLE D... 0 CASH ADVANCEC , 4600 CASH ADVANCE REDIT 0 CVERLaIf 270.86 'CASH ADV LIMIT IS A POR AL CREDIT LINE . ,„ 4 9;1 INME, ACCOUNTSUMMARY PREVIOUS BALANCE $ 5917.20 PURCHASES * ODD CASHADVA14CES • OAO CREDITS - 0.00 PAYMENTS - 2D.00 OTHER • 39.DD FINANCE CHARGE * 142.66 NEW BALANCE 6078.86 EIMER SERVICE CENTER: 1466864a423 YMENT BY PHONE: 877-2-PAY-CARD FROM OUTSIDE THE U.S. CT: 904-997-4997 HEARING IMPAIRED-TDO CUSTOMERS CALL: 877-902-0967 SEN T YMENTCENTER, PO BOX 173131 BALTIMORE, MD 21297-1313 0: CARDMEMBER SERVICES, PO BOX 21550, TULSA. OK 74121-1550 OTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION. •... ,, „' Pay Online, Anytime: www.accourdeemralonline.com Plane De Mel Saul Credit Owd Paylrlel16s to this Address. CIA 14"417796 b 010p101it8Ift Zee 1l?Mna ann ae1. a mar b Male , AMERIQUESI" , ACCOUNT NUMBER 5458 00401323 9726 OUR RECORDS INDICATE YOUR ACCOUNT IS PAST DUE. IF YOU HAVE NOT MAILED YOUR PAYMENT, PLEASE DO SO TODAY. EFFECTIVE 51170. YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS: A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEPHONE, EVEN IF THE PAYMENT IS MADE BY SOMEONE OTHER THAN YOU. THE AMOUNT OF THE FEE WILL BE DISCLOSED WHEN A CHECK BY PHONE IS REQUESTED. YOUR MASTERCARDS CORE BENEFITS INCLUDE EXTENDED WARRANTY, PURCHASE ASSURANCE COVERAGE, SATISFACTION GUARANTEE COVERAGE, MASTER ROADASSIST@ SERVICE, TRAVEL ASSISTANCE SERVICES, AND MASTERCARD GLOBAL SERVICE. FOR DETAILS. CALL 1-800-MCASSIST OR VISIT WWW.MASTERCARD.COMICARDHOLDERSERVICES/GUIDETOBENEFITSI SMARTSHOPPER. A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BALANCE RATE, RATE CHARGE RATE CYCLE DATE PURCHASES 5988.34 .08215% 29.99% 142.66 29.99% CASH ADVANCES 0.00 .08215% 29.99% 0.00 29.99% 29 02108/07 ftT 14 ?.' ?1o r .N 6104250 *AMMQ= Y CARDMEMBER SERVICES ~ : PO BOX 21550 TULSA OK 74121-1550 Payments Payable To: HSBC Card Services ACCOUNT NUMBER 5458 00401323 9726 STATEMENT NEW MINRBUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 03109107 6,2".48 597.00 387.00 04/03107 S I ? Mm address ce em il? Check acs. See reverse sloe. SEND PAYMENTS TO: '50070003743128' NOREEN K GARNEY 0?_14 PO BOX 1386 PAYMENT CENTER MECHANICSBURG PA 17055-1386 PO BOX 17313 BALTIMORE, MD 21297-1313 III,..III, .i,I I I,...11.,111..1.11..1..1..11..11... Ill, 1.11.1.1...I11.11. ,11..11....11..11.1.,.1 545800401323972600059700006244489 Detach and insert this top pWtM N the a l-W envelope. Be swe the Payment Center address shows in the erwel pe window. QUESTe Ameriquesl Ameriquest SOnUS Redeemed C t Rewa= Prior Rewards Earned Ameriquest Ameriquest Am U Balance This Month Rewards Awarded Rewards Re ce 100 0 0 0 TRANS POST REFERENCE a&" DATE DATE NUMBER DESCRIPTION CREDITS CHARGES PAYMENTS AND CREDITS OWN 03106 85458DO2301 KFM7BK PAYMENT-THANK YOU TULSA OIC 20.D0 - PURCHASES, CASH ADVANCES & FEES 03105 03105 ya; LATE FEE 39.00 t" 'FINANCE CHARGE' K. 146.62 PURCHASES $146.62 CASH ADVAJICE J4. YOUR ACCOUNT SUMMARY - MARCH - ACCOUNT AND PAYMENT INFORMATION CREDIT LINE INFORMATION oN ACCOUNT NUMBER 5456 OD4013239726 TOTAL CREDIT LINE $ s1DD NEW BALANCE 6241.40 TOTAL AVAUI, D a 0 MIMMUM PAYMENT DUE 597.00 CASH ADVANCE C 4640 AMOUNT PAST DUE 387.00 CASH ADVANCE DIT 0 PAYMENT MUST BE ONERLIMIT 444.49 RECEIVED BY APR 3, 2007 LIMIT IS A 'CASH ADV A ORTIO L CREDIT LINE. ACCOUNTSUMMARY PREVIOUS BALANCE 58078.86 PURCHASES + 0.00 CASHADVANCES 0.00 CREDITS - 0.00 PAYMENTS - 20.00 OTHER 39.00 FINANCE CHARGE + 148.62 NEW BALANCE 6241.48 EMBER SERVICE CENTER:1.866-86L9423 Y a BY PHONE: 877-2-PAY-CARD FROM OUTSIDE THE U.S. C CT: 9D4-997-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0967 SEN(a T YMENT CENTER PO BOX 17313, BALTIMORE. MD 21297-1313 M O: CARDMEMBER SERVICES, PO BOX 21559. TULSA, OK 74121-1550 - OTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION. ` Pay Online, Anytime: www.accountcentralonline.com ;d ._ zPU _ .. "!3'!? x r.rn or _ ,'9'!'1 1_.. ;?P ? 3f?;.•"'M1 11.-•11 6104250 ,$LAMERICj EST" ACCOUNT NUMBER 5458 00401323 9726 YOUR ACCOUNT IS TWO PAYMENTS PAST DUE. CALL US IMMEDIATELY AT 1-80D-435-1415 TO MAKE PAYMENT ARRANGEMENTS. EFFECTIVE 5117/08, YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS: A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEPHONE, EVEN IF THE PAYMENT IS MADE BY SOMEONE OTHER THAN YOU. THE AMOUNT OF THE FEE WILL BE DISCLOSED WHEN A CHECK BY PHONE IS REQUESTED. A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLNG CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 6154.64 .08215% 29.99% 146.62 29.99% CASH ADVANCES 0.00 .09215% 29.99% 0.00 29.99% 29 03109/07 E a IWO -6104250 • CARDMEMBER SERVICES .. *AMMQ=? PO BOX 21550 TULSA OK 74121-1550 Payments Payade To: HSBC Card Services ACCOUNT NUMBER 5456 0040 1323 9726 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENTDUE DUE BE RECEIVED BY ENCLOSED ?--1 00 05104107 s I 00 577 804 04109/07 6,424.67 . . O Mew address a emsll7 Check box. See reverse side. S TO : SEND PAYMENT '50070031277080' NOREEN K GARNEY PAYMENT CENTER PO BOX 1386 MECHANICSBURG PA 17055-1386 PO BOX 17313 I11,,,III,,,,1,I.,1,1,...11„II,I„I„II„I„ BALTIMORE, MO 21297-1313 I„II„II„ l l,.,II„I,II I..Ill. 1.1.Ill. II „II31.11.11.11111...1 545800401323972600080400006424677 vebPe vnnduw. - n ee nt Center ae ke shows in tth Detach and insert this top Portion n Ite end-tide WWit. Be sure the Payrtre - ? ? 11 Q?VE??-1< rtewara summa Ameriquest Ameriquest Bonus Redeemed C nt Rewards(& Prior Rewards Earned Ameriquest Ameriquest A Balance This Month Rewards Awarded Rewards Rew ance 100 0 0 0 00 A VIEW OF YOUR RECENT CHARGES AND CREDITS Pa Online, Anytime: www. ntralonline.com TRANS POST REFERENCE 1 EDITS CHARGES DATE DATE NUMBER DESCRIPTION_ FA PAYMENTS AND CREDITS 04108 0408 854WW32010HHP8M PAYMENT-THANKYOU TULSA CASH ADVANCES 8 FEES PURCHASES , 04103 04103 ' LATE FEE- 19 CASH ADVR?1'£ ?C? } SES $161 39.00 161.19 'FINANCE CHARGE . PURCHA YOUR ACCOUNT SUMMARY - APRIL ACCOUNT AND PAYMENT INFORMATION CREDIT LINE INFORMATION ACCOUNT SUMMARY ACCOUNT NUMBER S458 0040 1323 9TA TOTAL CREDIT LINE 115500 PREVIOUS BALANCE 6244A8 0 00 NEW BALANCE 6424.67 TOTAL AVALABLE 0 0 PURCHASES . 0A0 MINIMUM PAYMENT DUE 804.00 CASH ADVANCEC 4640 CASHADVANCES - 00 0 AMOUNT PAST DUE ST7.00 CASH ADVANCE DIT 0 CREDITS . 20 00 PAYMENTMUSTBE OVERLMAT 624.67 PAYMENTS . 00 39 RECEIVED BY MAY 4, 2007 'CASH ADV LMR M A OTHER * FINANCE CHARGE AL CREDIT LINE . 161.18 . POR NEW BALANCE 6124.67 E 'ObER SERVICE CENTER:1W68-8643423 YMENT BY PHONE: 877-2-PAY-CARD FROM OUTSIDE THE U.S. C - CT: 904-997-4997 FEARING IMPAIRED-TDD CUSTOMERS CALL.: 877-902-0967 SEN %% :PAYMENT CENTER PO BOX 17313, BALTIMORE, MD 21297-1313 CARDMEMBER SERVICES, PO BOX 21550. TULSA OK 74121-1550 OTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION. Pay Online, Anytime: www.accouMeentralonline.com YOUR CHARGING PRIVILEGES HAVE BEEN RLVOKLU. PLEASE DESTROY YOUR CARD(S). CONTACT US TOLL-FREE AT 800-435-1415 TO DISCUSS YOUR ACCOUNT. _,;,I .:•1 rPU _ .. ?qq_ Lx .? _ '. _ ?.. i 6104250 Mere Do Not Send Croft Ord Peylneats to this AdArt ON 1NY6a7732M5 b reports Irn mss.. o.s.s.es.n es r ee rew. tr 4wnc? *AMERIQUEST x ACCOUNT NUMBER 5456 00401323 9726 EFFECTIVE 5117106, YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS: A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEPHONE, EVEN IF THE PAYMENT IS MADE BY SOMEONE OTHER THAN YOU. THE AMOUNT OF THE FEE WILL BE DISCLOSED WHEN A CHECK BY PHONE IS REQUESTED. YOUR MASTERCARDO CORE BENEFITS INCLUDE EXTENDED WARRANTY, PURCHASE ASSURANCE COVERAGE, SATISFACTION GUARANTEE COVERAGE, MASTER ROADASSIST® SERVICE, TRAVEL ASSISTANCE SERVICES, AND MASTERCARD GLOBAL SERVICE. FOR DETAILS. CALL 1-800-MCASSIST OR VISIT W W W.MASTERCARD.COWCAImHOLDERSERVICESIGUIDETOBENEFITSI SMARTSHOPPER. A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 6329.57 .08215% 29.99% 161.19 29.99% CASH ADVANCES 0.00 .08215% 29.99% 0.00 29.99% 31 04/OW7 %11 1 '- _ , n4: . f r[:• _ ,i gpo 4 _W 1 15.%4 41S 6104250 *AMM%= CARDMEMBER SERVICES PO BOX 21550 TULSA OK 74121-1550 Payments Payable To: HSBC Card Services ACCOUNT NUMBER 5458 00401323 9726 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 00 011 77 1 564 6 00 06103107 $ 1 764 . , . , 05109107 . Q New adAess «eman7 Check bo+. See revwse alder S TO SEND PAYMENT : A 3500700596413553 NOREEN K GARNEY -1 34 PO BOX 1386 PAYMENT CENTER MECHANICSBURG PA 17055-1386 PO BOX 17313 BALTIMORE. MD 21297-1313 „All, ,.III.,, II,.11..I.Ill .Ill, I,II,I„I...I...II.111111.11..1L.IIII..I1111111 545800401323972600101100006564770 Detach and mswt this tap portion n It. -I..d onvebpa. Be wre the Payment Center address shows in the erneloPe window. *AMMQUEST' McWdFU QUFIII1141 Ameriquest Ameriquesl Bonus Redeemed C , t Rewardsm Prior Rewards Earned Amerpuest Ameriquest Am 4 Balance This Month Rewards Awarded Rewards Re ce 100 0 0 0 0 A VIEW OF YOUR RECENT CHARGES AND CREDITS Pay Online Anytime: www.aA%u'Wntraioniine.com TRANS POST REFERENCE EDITS CHARGES DATE DATE NUMBER DESCRIPTION PAYMENTS AND CREDITS 05102 05M 85458003S012Y8M4W Okk"qol 2000 ' PAYMENT- THANK YOU TULSA PURCHASES, CASH ADVANCES & FEES 'FINANCE CHARGE' a PURCHASES $160.10 CASH ADVANCE O ? 16010 YOUR ACCOUNT SUMMARY - MAY ACCOUNT AND PAYMENT INFORMATION CREDIT LINE INFORMATION ACCOUNT SUMMARY ACODUNT NUMBER 5458 OD40 1323 9726 TOTAL CREDIT LINE PREVIOUS BALANCE S6424.67 NEW BALANCE 6364.77 MINIMUM PAYMENT DUE 1011.00 TOTAL AVAILABLE CREDIT 0 PURCHASES CASH ADVANCE C DiT 4640 CASH ADVANCES • 0.00 0100 AMOUNT PAST DUE 764.00 CASH ADVANCE A T 0 CREDITS - 0,00 PAYMENTMUSTSE OVERLMT 76477 PAYMENTS - 20100 RECEIVED BY JUN 3.2007 'CASH ADVA IT 15A OTHER ' 0,00 PORTION - CREDIT UNE. FINANCE CHARGE • 160-10 NEW BALANCE • "O 6564.77 ?y 15? 9, [^x' J' t-AL C SERVICE CENTER:141166-864-3423 T BY PHONE: 877-2-PAY-CARD FROM OUTSIDE THE U.S. CALL : 9114-997-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL 877-9D2-0967 SEND PAY E YMENT CENTER PO BOX 17313. BALTIMORE. MD 2129T-1313 MAIL S . C DMEMSER SERVICES, PO BOX 21550, TULSA, OK 74121-1550 E: SEE REVERSE SIDE FOR IMPORTANT INFORMATION. Pay Online, Anytime. www.accountcontmionline.com YOUR ACCOUNT IS SERIOUSLY PAST DUE. PLEASE PAY THE MINIMUM AMOUNT DUE IMMEDIATELY. SU CUENTA ESTA SERIAMENTE ATRASADA FAVOR DE PAGAR INMEDIATAMENTE EL PAGO MINIMO VENCIDO. PLEASE SEE THE ENCLOSED ANNUAL PRIVACY STATEMENT. DUE TO THE DELINQUENT STATUS OF YOUR ACCOUNT, YOUR CHARGING PRIVILEGES HAVE BEEN REVOKED. PLEASE DESTROY YOUR CARD(S). CONTACT US TOLL-FREE AT 80D-435-1415 TO DISCUSS YOUR ACCOUNT. EFFECTIVE 5117/06, YOUR CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT IS AMENDED AS FOLLOWS: A CHECK BY PHONE FEE MAY BE ASSESSED TO YOUR ACCOUNT EACH TIME A PAYMENT IS MADE BY 6104250 --"t xrp 57p5n. L.a 1 Ber,.. 4r;ru, 764, 0;1515:34 Ir734 CARDMEMBER SERVICES *AMMQ= > 4 PO BOX 21550 TULSA OK 74121-1550 Paymerds Payable To. HSBC Card Services ACCOUNT NUMBER 5456 00401323 9726 STATEMENT NEW DATE BALANCE MINIMUM PAYMENT DUE AMOUNT PAST PAYMENT MUST AMOUNT DUE BE RECEIVED BY ENCLOSED 06106/07 6,726.50 1,243.00 1,011.00 07103107 s ---? ? New atlases ....117 Check bor. See reverse wide. SEND PAYMENTS TO: '50070089678703' NOREEN K GARNEY PO BOX 1386 PAYMENT CENTER MECHANICSBURG PA 17055-1386 PO BOX 17313 BALTIMORE, MD 21297-1313 545800401323972600124300006728507 Detach and Bert this toP Patios b the -bead envelgte. Be sae the Payment Center adders shows in the erwebPe window. *AMMQ-LTffT' K@war0 OU111111a1 quas[ t Ameriquest Bonus Redeemed C nt 1d.S Prior FR= Rewards Earned AmeriquesI Ameriquest Am L Balance This Month Rewards Awarded Rewards Re _ ce 0 0 0 0 0 A VIEW OF YOUR RECENT CHARGES ANU UKtuna ra ?,e„ti. Mr„F.....•... --...--.._ • - _._......_.-_... TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION " ,? fSREDITS CHARGES CASH ADVANCES R FEES PURCHASES , 'FINANCE CHARGE' PURCHASES 5163.73 CASH ADVANCE S0. 163.73 YOUR ACCOUNT SUMMARY- JUNE ACCOUNT AND PAYMENT INFORMATIO CREDIT LINE INFORMATION - ACCOUNT SUMMARY ACCOUNT NUMBER 5455004013239725 TOTALCREDIT UNE PREVIOUS BALANCE $6564.77 NEw BALANCE 6726.50 TOTAL AVAILABLE CREDIT 0 PURCHASES • 0.00 MINIMUM PAYMENT DUE 1243.00 CASH ADVANCE CREDIT LIMIT' 810 CASH ADVANCES • 0.00 AMOUNT PAST DUE 1011.00 PAYMENT MUST BE CASH ADVANCE AVAI DIT OVERUM,ITAMOU 0 CREDITS - 928.50 PAYMENTS - 0.D0 0.00 RECEIVED BY JUL 3.2007 'CASH ADVANCE A OTHER 0.00 163 73 PORTK3N OF IT UNE. Y? FINANCE CHARGE • NEW BALANCE . 6726.50 CAROM VICE CENTER: 1-866464-9423 lwi% BY PHONE: 877-2-PAY-CARD FROM OUTSIDE THE U.S. CALL 987-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0967 SEND PAYMENT NT CENTER PO BOX 17313, BALTIMORE, MD 21297-1313 MAIL INQUIRI EMBER SERVICES, PO BOX 21550, TULSA, OK 74121-1550 N REVERSE SIDE FOR IMPORTANT INFORMATION. y ine, Anytime: www.accountcamralonline.eom YOUR ACCOUNT IS SERIOUSLY PAST DUE. IT IS IMPERATIVE THAT YOU PAY THE AMOUNT DUE IMMEDIATELY. SU CUENTA ESTA SERIAMENTE ATRASADA. ES IMPERATVO CUE PAGUE INMEDIATAMENTE LA CANTIDAD VENCIDA. A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 6643.57 .08215% 29.99% 163.73 29.99% CASH ADVANCES 0.00 .06215 % 29.99% 0.00 29.99% 30 06/08107 6104250 -:1 rr•D _ 6 0,10568. L x _ u . 80,9r- 46C.. .6'sr 01SR,"4 81,1128 Y CARDMEMBER SERVICES *AMMQ= PO BOX 21550 TULSA OK 74121-1550 Payments Payable To: HSBC Card Servioes ACCOUNT NUMBER 5458 00401323 9726 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 07110107 6,907.65 1,493.00 1,243.00 08/04107 s I ? New add-. -mall? Check bar. See reverse YW. SEND PAYMENTS TO: 3?4 y NOREEN K GARNEY 14A8'_ri PO BOX 1386 PAYMENT CENTER MECHANICSBURG PA 17055-1386 PO BOX 17313 BALTIMORE, MD 21297-1313 545800401323972600149300006907656 Uetwh and wmed this fop portion in the enclosed enve". Be sure the Payment Center address shows in the en-ope vArdow. *AMMQUES-r Ameriquest Ameriquest Bonus Redeemed C M Rewards0 Prior Rewards Earned Ameriquest Ameriquest A Balance This Month Rewards Awarded Rewards Re ce 0 0 0 0 0 A VIEW OF YOUR RECENT CHARGES AND CREDITS Pay omtne. Anytime: www TRANS POST REFERENCE <y DATE DATE NUMBER DESCRIPTION PURCHASES, CASH ADVANCES 3 FEES 'FINANCE CHARGE' PURCHASES $179.15 CASH ADVANCE $0 00,' a CHARGES 179.15 TOUR ACCOUNT SUNMNAK7 - JULY ACCOUNT AND PAYMENT INFORMATION CREDIT LINE INFORMATION 1 ACCOUNT SUMMARY ACCOUNT NUMBER 5458 0040 1323 9726 TOTAL CREDIT LINE PREVIOUS BALANCE 4072850 NEW BALANCE 6W.65 TOTAL AVAILABLE CREDIT 1 No PURCHASES + 0.00 MINIMUM PAYMENT DUE 1493.00 CASH ADVANCE CREDIT LIMIT' 400610 CASHADVANCES + 0.00 AMOUNT PART DUE 1213,00 T D CREDRS CASH ADVANC ALA 0.00 PAYMENT MUST BE V OVERUMAITAM1107.05 PAYMENTS 0.00 RECEIVED BY AUG 4.2007 & 'CASH ADVANA OTHER 0.00 PORTION OF YOkK LINE. FINANCE CHARGE • 179.15 NEW BALANCE • 6007.65 C CE CENTEIt14166964-3423 BY PHONE: 877-2-PAY-CARD FROM OUTSIDE THE U.S. CALL 987-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0967 SEND PAYMENT NT CENTER PO BOX 17313, BALTIMORE, MD 21297-1313 MAIL INOUIRI EMBER SERVICES, PO BOX 21550, TULSA, OK 74121-1550 N E REVERSE SIDE FOR IMPORTANT INFORMATION. 4N. _ y !no, Anyllme: www.accourtltantralonfine.twm k SUMMARY OF YOUR FM 6104250 NOMINAL NUMBER AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 6814.88 .08215% 29.99% 179.15 29,99% CASH ADVANCES 0.00 .08215% 29.99% 0.00 29.99% 32 07/10/07 .%s4 __ 1r0 1 no.,71:i LA>acc u' 1 880(! l:. !6?f 11.;!,384 144820 ' *AMMQ= CARDMEMBER SERVICES - PO BOX 17151 BALTIMORE MD 21297-1151 Payments Payable To: HSBC Card Services ACCOUNT NUMBER 5456 00401323 9726 STATEMENT NEW MINIMUM AMOUNT PAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 08109/07 7,079.93 1,737.00 1,493.00 09103107 s 7' O New add- or ema117 Check box. See reverse sde. YMENTS TO : SEND PA NOREEN K GARNEY 320 ss 14P?'3 PAYMENT CENTER PO BOX 1386 MECHANICSBURG PA 17055-1386 PO BOX 17313 ...III...III,„1,1..1,I,•.•II.III.,I•II.,I„ BALTIMORE, MD 21297-1313 i„II,?II„? ,.I?I?..II„I?III„i,.,I.,,II,•II„?.II„II,II.•.II„II,. 545800401323972600173700007079935 emebpe n od- m th e Detach and melt ttm top Dorton in the em"W env ". Be twee the Pay-t Ceenn(w addr- sh- ( ? ? mt ? QV LAJ 1 R6Wilfu QUI1111141 erqu est Ameriquest Bonus Redeemed nt [RZ rds0 Prior Rewards Earned Ameriquest Am Iirl Uest An! Balance This Month Rewards Awarded Rewards Re ce 0 0 0 0 A VIEW OF YOUR REGENT GKAKUGI ANU L KCVI10 - ?•,F, ?• ,,,•.?.......•.,,. .._?.__._ ._. TRANS POST REFERENCE DATE DATE NUMBER ,REDITS DESCRIPTION CHARGES PURCHASES, CASH ADVANCES 8 FEES 'FINANCE CHARGE' PURCHASES $172.28 CASH ADVANCE $04 17228 YOUR ACCOUNT SUMMARY - AUGUST ACCOUNT AND PAYMENT INFORMATION CREDIT LINE INFORMATION r6¢ ACCOUNT SUMMARY ACCOUNT NUMBER 5058 W4013239728 TOTAL CREDIT LINE PREVIOUS BALANCE S 8907.65 NEW BALANCE 1079.93 TOTAL AVAILABLE CREDIT D PURCHASES ' 0.00 MINIMUM PAYMENT DUE 1737.00 CASH ADVANCE CREDIT LIMIT' dpi(' CASHADVANCES 0.00 AMOUNT PAST DUE 1403.01) PAYMENT MUST BE CASH ADVANCE AVAILA DIT D CREDITS - OVERLIMITAMDU 1279.93 PAYMENTS - 0.00 0.00 RECEIVED BY SEP 3.2007 'CASH ADVANCE A OTHER 0.00 PORTION OF REDITUNE. FINANCE CHARGE 172.28 NEW BALANCE 7079.93 C CE CENTER: 14WA4649423 BY PHONE: 877-2-PAY-CARD FROM OUTSIDE THE U.S. CALL 987-4997 HEARING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0967 SEND PAYMENT NT CENTER PO BOX 17313, BALTIMORE, MD 21297-1313 MAIL INOUIRI EMBER SERVICES, PO BOX 21550, TULSA, OK 74121-1550 N REVERSE SIDE FOR IMPORTANT INFORMATION. y Line, Anytime: www.aeeountcontralonlin9.eom OF NOMINAL NUMULK AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DILLY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 6990.56 .08215% 29.99% 172.28 29.99% CASH ADVANCES 0.00 .08215% 29.99% 0.00 29.99% 30 08)09107 6104250 ??r_d ri:?OrzP0 T : rT=B'"!9 L x ^ac? of 1 28p ?-P 01c15,"4 148793 *AMMQ = r r, .?.... ? CARDMEMBER SERVICES PO BOX 17151 BALTIMORE MD 21297-1151 Payments Payable To: HSBC Card Services ACCOUNT NUMBER 5458 00401323 9726 STATEMENT NEW MINIMUM AMOUNTPAST PAYMENT MUST AMOUNT DATE BALANCE PAYMENT DUE DUE BE RECEIVED BY ENCLOSED 00 09/22/07 S I 00 0 0 08131107 0.00 . . ? New atMteec or email? Check bor. See rave+se mitle. SEND PAYMENTS TO: to v NOREEN K GARNEY PAYMENT CENTER BOX 1386 MECHANICSBURG PA 17055-1386 PO BOX 17313 BALTIMORE. MD 21297-1313 54580D401323972600000000000000007 Detach and insan this toP POMDn in the encbsW e"ve". Be axe the Pay-t Center address shows in tM enwbPe vi(Kbw. - *AMMQ-Uff 1 A VIEW OF YOUR RECENT CHARGES AND CREDITS Pay Online Anytime: www.accountoontralonline.com TRANS POST REFERENCE CREDITS RGES DATE DATE NUMBER DESCRIPTION A.M6, N O PAYMENTS AND CREDITS . ` 08131 08131 FasD0007KO0999990 CHARGE OFF ACCOUNT-PRINCIPALS 5610 08131 06131 F880OD07KO0999990 CHARGE OFF ACCOUNT `FINANCE CHARGES' YOUR ACCOUNT SUMMARY - AUGUST ACCOUNT AND PAYMENT INFORMATION CREDIT LINE INFORMATION ACCO ARY ACCOUNT NUMBER S458 0040 1323 9728 TOTAL CREDIT LINE $5800 P RNCE $7079.93 :.as NEW BALANCE 0.00 TOTAL AVAILABLE CREDIT 0 PU + 0.00 0 00 MINIMUM PAYMENT DUE CASH ADVANCE CREDIT LIMIT' 4610 _ CES + - . 93 7070 AMOUNT PAST DUE OAO CASH ADVANCE AVAILABLE CREDIT 0 M . 0 00 PAYMENT MUST BE AS - OVERL9MTAMOUNT 0.0? . P + . 0 00 RECEIVED BY SEP 22, 2007 -CASH ADVANCECREDIT LIMIT 15 A _ HER . 0 00 PORTION OF YOUR TOTAL CREDIT" FINANCE CHARGE n . ... i NEW BALANCE 0.00 CARDMEMBER SERVICE ft:1?66.8643423 PAYMENT BY PAY-CARD FROM OUTSIDE THE U.S. CALL COLLECT: 9D4-997-4 IMPAIRED-TDD CUSTOMERS CALL: 871-902-0967 X 17313, BALTIMORE. MD 211297-13113 SEND PAYMENTS TO: PAYMENT ffi MAIL INQUIRIES TO: CARDMEMBER 8 PO BOX 5250, CAROL STREAK IL 60197-9641 NOTICE: SEE REV OR IMPORTANT INFORMATION. tceMraloniine.eom Pay Done, ylaccoun OF NOMINAL rvvmocrc AVERAGE N ANNUAL ANNUAL OF DAYS STATEMENT DAILY a'n td g. ° PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BA N&I ATE 6 RATE CHARGE RATE CYCLE DATE PURCHASES 0. ^ .09215 % 29.99% 0.00 29.99% CASH ADVANCES 0.00 .08215 % 29.99% 0.00 29.99% 31) 08/31107 6104250 F ! zs°a ? V Z - i I R t y, X g ` r . 1 -??3gY8 ??•? strON-Al S?yy I G • i . ?ss? yy l? l X? I e k, ?. a .? s e' ?s a: ti,9 ? o e yg d ?. ? ? ? ??•.? .. •. 3 ?yr ? _ y L y p g •? e el. i d 12 ? y4 q 5? :•?? ?°=app ? ?s? i•i ]YBS? • ?f1 . I y., y 9 ^ `:s sg a 111- t Y9?? sQK y?E5 $ ' ? Cr 93 £2 "e a35 ?9 £. g o3 C? 8 K 3 E Nadi! 1 411 d all e? 2 sus Y ?J ?d5 T ? e b !_-? Im Oa1AY Olt a MM gE§g 3cgs 5e3jE°'?? ji; $ g bi99 x :H; ipf ;; In u 4 eis e g$ ? a2`Oi - Jam` MA-1 $3 rs cif '? 581 dig oaf -0 ??J ts? W ?p's?34?L(Yaga? L?Y -?- 5 s s± NJ b`' ?8 E? ?' e A je.4c E .05 'S 5 S° 5 a Ell .r a'i.E ?2F< ; ps- P C If-t-g-s up q P A fl. 51. b M sa= u? JEDI 0 s a_y3 y o?r r? °?°??II? BS ?'Q 3 I Trim. ?° E3 d ?g ?j e?S 6 rtes °F ?P S e? ?s s?? 5 .5 R all COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVII. DIVISION HSBC BANK NEVADA, N.A., Plaintiff, V. NOREEN K. GARNEY, Defendant. No. 09-1233 CIVIL TERM DEFENDANT'S RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS OF FACT AND REQUEST FOR PRODUCTION Pro Se Defendant, NOREEN K. GARNEY, hereby responds to Plaintiffs First Request for Admissions of Fact and Request for Production of Documents as follows: Request for Production No. 1: RESPONSE: At this time, Defendant has no documents responsive to this request however, Defendant ;has not completed his trial preparation and will therefore endeavor to supplement this response if any relevant, unprivileged, documents become available. Discovery is ongoing and as such, Defendant will endeavor to obtain any and all documents responsive to this request in advance of trial. Request for Production No. 2: RESPONSE: At this time, Defendant has no documents responsive to this request however, Defendant has not completed his trial preparation and will therefore endeavor to supplement this response if any relevant, unprivileged, documents become available. Discovery is ongoing and as such, Defendant will endeavor to obtain any and all documents responsive to this request in advance of trial. Reauest fo AAdmissions No. 1: RESPONSE: Admit. Page 1 of 4 -"?i-- ?I Reauest for Admissions No. 2: RESPONSE: Denied. At this time, Defendant has no documents responsive to this request however, Defendant has not completed his trial preparation and will therefore endeavor to supplement this response if any relevant, unprivileged, documents become available. Discovery is ongoing and as such, Defendant will endeavor to obtain any and all documents responsive to this request in advance of trial. Request for Admissions No. 3: RESPONSE: Admit. Request for Admissions No. 4: RESPONSE: Admit. Request for Admissions No. 5: RESPONSE: Denied. At this time, Defendant has no documents responsive to this request however, Defendant has not completed his trial preparation and will therefore endeavor to supplement this response if any relevant, unprivileged, documents become available. Discovery is ongoing and as such, Defendant will endeavor to obtain any and all documents responsive to this request in advance of trial. Page 2 of 4 VERIFICATION STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND } ) ss. /v6 y?_""?t K of lawful age, being first duly sworn upon oath, state(s): That she is the Defendant above named; that she has read the above foregoing Request for Admissions and Request for Production of Documents and the answers thereto are true and correct according to her best information and belief. By: Subscribed and sworn to before me this d 7 day of G-ivzl& - '2010. COMMONWEALTH OF PENNSYLVANIA NMI,' SOW Kristen M. Ga WM. Notwy Pubic Cafte Born. Cwnbw? Cou* My Com 1=1vn FAk 11, M3 Member, PennsyW ft AssodOw of Nok*s Commission Expires: T-44u-ul // Zd /.?,7-. Notary Public Page 3 of 4 CERTIFICATE OF SERVICE A true and correct copy of the within Plaintiff's Motion for Summary Judgment and Brief in Support of Motion for Summary Judgment have been served by U.S. Mail, Postage Pre-Paid, on I' &day of CQV?'t 2010 upon the following: Noreen K Garrey 501 Cascade Road Mechanicsburg, Pa 17055 By- Bel ible , Esquire P8 ., L.P.A. WINBERG & REIS CO 14Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6104250 c % IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A., NO. 09-1233 CIVIL TERM Plaintiff, vs. NOREEN K GARNEY, Defendant. TYPE OF PLEADING:... PRAECIPE TO WITHDRAW MOTION FOR SUMMARYJUDGMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Benjamin R. Bibler,Esquire PA I D# 93598 Weltman,Weinberg & Reis CO L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 C-) rv CD Fri - r s c CC:) f?U T? b c) -n ?? GJ ;z F3 Co n fti'1 ? r'o - ° --C R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A., Plaintiff vs. NOREEN K GARNEY, Defendant NO. 09-1233 CIVIL TERM PRAECIPE TO WITHDRAW MOTION FOR SUMMARYJUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to withdraw the Motion for Summary Judgment on the above referenced case number. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Be amin . Bibler,Esquire P ID# 93198 W ltma einberg & Reis CO L.P.A. 140 oppers Building 436 Seventh Avenue Pittsburgh, PA 15219 CERTIFICATE OF SERVICE A true and correct copy of the Praecipe To Withdraw Motion for Summary Judgment has been served by U.S. Mail, Postage Pre-Paid, on r day of _j ??n??*r? , 2010 upon the following: Noreen Garrey 501 Cascade Rd Mechanicsburg Pa 17055 By: Benj i Bibler,Esquire PA # 93 98 Wel ,Weinberg & Reis CO L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 W LTMAN, WEINBERG & REIS CO., L.P.A. ?InGTAi``s BY: Sarah E. Ehasz, Esquire Attorney for Plaintifffs I.D. No. 86469 28 436 Seventh Ave, 1400 Koppers Bldg rUMBERLAND COUNTY Pittsburgh, PA 15219 PENNSYLVANIA Pho e: 412.434.7955 Fax 412.434.7959 File # 6104250 HSl BANK NEVADA, N.A. AS Plaintiff CUMBERLAND County Court of Common Pleas NOl VS. N K GARNEY Defendant(s) No.: 09-1233 CIVIL TERM PRAECIPE TO DISMISS WITH PREJUDICE TO THE PROTHONOTARY: y dismiss the above matter with prejudice. WELTMAN, WEINBERG & REIS CO., L.P.A. By arah E. Ehasz, Esquire Attorney for Plaintiff