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Home My WebLink About09-1380IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: 09-IZ80 &v4Ni,em vs. COMPLAINT IN CIVIL ACTION BRIAN M RANK 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 07114623 C N Pit TSW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. BRIAN M RANK Defendant Civil Action No COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, HSBC BANK NEVADA, N.A is a corporation with offices at 1111 TOWN CENTER DR. LAS VEGAS , NV 89193 . 2. Defendant is adult individual(s) residing at the address listed below: BRIAN M RANK 971 GREENSPRING RD NEWVILLE, PA 17241 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX7638 . 4. Defendant made use of said credit card and has a current balance due of $3691.18 , as of December 31, 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 6.0001 per annum on the unpaid balance from December 31, 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 , BRIAN M RANK , INDIVIDUALLY , in the amount of $3691.18 with continuing interest thereon at the rate of 6.0001 per annum from December 31, 2008 plus costs. ames 436 S Pitts (412) FAX: 0711, This law firm is a debt collector att our client and any information obtain rmbrodt,42524 r EINBERG & REIS CO., L.P.A. h Avenue, Suite 1400 , PA 15219 -7955 338-7130 C N Pit TSW dng to collect this debt for ill be used for that purpose. Q I rewardzone® PROGRAM MASTERCARD BRIAN M RANK Page 1 of 2 ACCOUNT SUMMARY ACCOUNT 5158.2500-0163-7638 NUMBER TOTAL CREDIT LIMIT $3,000 TOTAL CREDIT LIMIT $0 AVAILABLE CASH CREDIT LIMIT t $1,200 CASH LIMIT AVAILABLE $0 STATEMENT DATE 10107108 PAYMENT SUMMARY MINIMUM PAYMENT' $157.00 PAYMENT DUE DATE 10131!08 OVERLIMIT AMOUNT $435.27 PAST DUE AMOUNT $230.00 CURRENT PAYMENT DUE' $553.2 To avoid additional Into andAr ovw*mit fees, you must pay Me Currant Payment Due (Which includes the Minimum Payment and any Past Due andAr ovedimit Amounts). 'See About Your Payment on reverse for an t Cash Credit Limit is a portion of the Total Credit Limit BALANCE SUMMARY PREVIOUS BALANCE $3,313.43 PAYMENTSICREDITS $0.00 PURCHASESIDEBITS + $0.00 LATE PAYMENT CHARGE + $39.00 MISC. FINANCE CHARGE + $0.00 FINANCE CHARGE + $82.64 NEW BALANCE - $3,435.27 TRANSACTION SUMMARY (For additional transaction detail go to www.rowardzonemastercard.com) TRANS POST TRANSACTION PURCHASE REFERENCE DATE DATE DESCRIPTION TYPE NUMBER AMOUNT MASTERCARD 10102 10102 LATE CHARGE ASSESSMENT `10000006060000 M $39.00 YOUR ACCOUNT IS NOW PAST DUE. PLEASE CALL TODAY TO MAKE YOUR PAYMENT OVER THE PHONE. CALL US AT 5884843.3978. ,ol MAIL PAYMENTS TO: 9 QUESTIONS? ® MAIL INQUIRIES TO: REWARD ZONE PROGRAM 24-HOUR AUTOMATED ACCOUNT INFORMATION REWARD ZONE PROGRAM MASTERCARD MASTERCARD ENGUSHIESPANOL 1-804419.4959 PO BOX $0045 PO BOX 17051 TOO HEARING IMPAIRED: 1-800855-9392 SALINAS CA 93912-0045 BALTIMORE MD 21297-1051 2 Manage your account online at: www.rewardzonemastercard.com DBP1 500800 5 E 07 0000000808 G STMT78 D D 00001988 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check Account Number 5756-Z5W-07tf3-itssa I reVVardZ?n@' New Balance $3,435.27 Minimum Payment $157.00 Payment Due Date 10131106 Current Payment Due 9858.27 PROGRAM MASTERCARD Include account number on check to REWARD ZONE PROGRAM MASTERCARD. 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 overlimit fees, pay the Current Payment Due. Amount Enclosed BRIAN M RANK 971 GRZZNSPRING RD NZWVILLE PA 17241-9679 III{Illilrllllllllllllllllll'11111'1111'1'1II'Illll'Illll{I"1111 IIII{I1111'lllllllrrll'llrrrll'111111'll'I'llllllrlrllllllllr?ll I REWARD ZONE PROGRAM MASTERCARD PO BOX 17051 BALTIMORE MD 21297-1051 M X asssal 515625000163763800055327003435277 q i rewardzone® PROGRAM MASTERCARD BRIAN M RANK Page 2 of 2 FINANCE CHARGE CALCULATION This is a grace account. Grace period information on back. Days in Billing Cycle: 30 BEST BUY Purchase Daily Periodic Nominal ANNUAL Date Daily Average Rate Annual PERCENTAGE lnce FINANCE Deferred Percentage Rate RATE Promotion Promotion CHARGES FINANCE T redid Plan Expiration Date At Periodic Rate - CHARGES 00 $0 29 (h 29 969% UR HA S 18%(v) 0 . . 0000002 2 MASTERCARD FINANCE Nominal N AN UAL Average Daily Daily Periodic CHARGES Cash Advance Annual PERCENTAGE Balance Rate At Periodic Rate Fees Percentage Rate RATE HAS 42.9 0.0818% 9.84 0.00 29• PR H S 0. 0. 1 .00 0. 29. (y) indicates variable rate As a reminder, your APRs may immediately increase up to the Default APR if your payment is late or you exceed your credit limes an nor vnur Cardmannher Aareement and Disclosure. IMPORTANT INFORMATION Purchase Summary Amount Best Buy Spend' (4% on eligible purchases) $0.00 Other MasterCard Spend' (up to 2% on eligible purchases) $0.00 For reward and point detail, to update your profile, check out exclusive offers and more, visit MyRewardZone.com. Use the card, earn the points, get the rewards. include ? MAIL PAYMENTS TO: 9 QUESTIONS? REWARD ZONE PROGRAM 24-HOUR AUTOMATED ACCOUNT INFORMATION MASTERCARD ENGLISWESPANOL 14800419-4959 PO BOX 17051 TOO HEARING IMPAIRED: 1-8004155.9392 BALTIMORE MD 21297-1051 2 Manage your account online at: www.rewardzonemastercard.com ® MAIL INQUIRIES TO: REWARD ZONE PROGRAM MASTERCARD PO BOX 80045 SALINAS CA 93912-0045 DBP1 500800 5 E 07 0000000806 G STMT75 D D 00001986 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check 0 y0 e3 X 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. ,VCL" ?t-hAk"?o VALERIE DEMARAIS 07114623 5156250001637638 $3730.18 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. C r C1 tJ CD „ 09 ZRI --j Q Sheriffs Office of Cumberland County R Thomas Kline Qotr et cumbp? Edward L Schorpp Sheri' Solicitor Ronny R Anderson ' Jody S Smith Chief Deputy OFME OF THE S++ERiFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/10/2009 02:40 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 10, 2009 at 1611 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Brian M. Rank, by making known unto April Rank wife of defendant, at 971 Greenspring Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 (PAID) SO ANSWERS, March 14, 2009 R THOMAS KLINE, SHERIFF ` ?' f f D pu y S Sher Docket No. 2009-1380 HSBC Bank Nevada, N.A. v Brian M. Rank y r Z Co Defendants Answer to Plaintiffs Complaint HSBC Bank Nevada, N.A Plaintiff 6 9 - 3 s'o vs. Brian M Rank Defendant I generally deny the amount of debt. Brian M ank March 23, 2009 971 Greenspring Rd Newville PA 17241 tell i •f' f