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Home My WebLink About09-1381 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. JAMES N HARMON Defendant No. 09-1381 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06905306 LXR Judgment Amount $ 3829.55 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. Civil Action No. 09-1381 CIVIL TERM JAMES N HARMON Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, JAMES N HARMON above named, in the default of an Answer, in the amount of $3829.55 computed as follows: Amount claimed in Complaint $3721.88 Interest from NOVEMBER 13, 2008 to MAY 8, 2009 at the legal interest rate of 6% per annum $107.67 TOTAL $3829.55 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: JAMES C W RODT, ESQUIRE PA I.D.#425 4 Weltman, ein erg & Reis Co., L.P.A. 1400 Kp ers dg. o 436 Seve th enue Pittsbur , A 15219 (412) 43 955 WWR#06905306 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 3467 RITNER HWY NEWVILLE,PA 17241 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. JAMES N HARMON Defendant Case no: 09-1381 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, JAMES N HARMON is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, JAMES N HARMON is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBS ED 'n my presence this jQ day of AA?R- V W", NO Y PUBL Z QOM NWEALTH OF PENNSYLVANIA NoWft Seel Wayne A. Jones, Notary Public city Of pwabu*, AMapMny County W commhNon Jule 20, 2010 Member, Penn NOteAa IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. JAMES N HARMON Defendant TO: JAMES N HARMON 3467 RITNER HWY NEWVILLE, PA 17241 Date of Notice: Case No. 09-1381 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTM&N, WEINBERG & REIS CO., L.P.A. By: Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6905306 N PIT KM3 O? ?xa Wa d M ?" Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page I of 1 MAY-04-2009 08:00:36 '< Last Name First/Middle Begin Date Active Duty Status Service/Agency HARMON JAMES Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. A U uk In. 4A4? 4?? Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report !D:BRDUBMUGLEU https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/4/2009 r?z TI C"' FILED C, u7 i,ii iF 20 F'ii 122' J 4. 14.00 P ID AT H C,t,* 4oA8a5q s*iq IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. Civil Action No. 09-1381 CIVIL TERM JAMES N HARMON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ent was entered against you on S (xx) Assumpsit Judgment in the amount of $3829.55 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: L 44?444.'4 7 PR THONOT DE TY) JAMES N HARMON 3467 RITNER HWY NEWVILLE,PA 17241 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. JAMES N HARMON Defendant No : M - M-8 " l 1e-rM 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 06905306 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 JAMES N HARMON 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: JAMES N HARMON 3467 RITNER HWY NEWVILLE, PA 17241 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9762 . 4. Defendant made use of said credit card and has a current balance due of $3721.88 , as of November 13, 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 13, 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 , JAMES N HARMON , INDIVIDUALLY , in the amount of $3721.88 with continuing interest thereon at the rate of 6.000% per annum from November 13, 2008 plus costs. fames u. roaz,gznzq WELTMANWE NBERG & REIS CO., L.P.A. 436 Sev th Avenue, Suite 1400 Pittsbu gh PA 15219 (412) 4- 955 FAX: - 38-7130 069050! C N Pit TSW This law firm is a debt collector attemptdng to collect this debt for our client and any information obtained will be used for that purpose. • HSBC GOLD MASTERCARD JAMES N HARMON ACCOUNT SUMMARY ACCOUNT 5408-0100-0583-9782 NUMBER TOTAL CREDIT LIMIT $0 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE PAYMENT SUMMARY MINIMUM PAYMENT' $125.00 PAYMENT DUE DATE 08119/08 OVERLIMIT AMOUNT $3,721.88 PAST DUE AMOUNT $647.44 CURRENT PAYMENT DUE' $3,721.8 To avoid additions/ late and or overhinit fees, you must pay the Current Payment Due (which includes the Minimum Payment and any Past Due and/or Ovedimit Amounts). 'See About Your Payment on reverse for an Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $3,721.88 PAYMENTS/CREDITS $0.00 PURCHASES/DEBITS + $0.00 FINANCE CHARGE + $0.00 NEW BALANCE _ $3,721.88 PURCHASES CASH ADVANCES (v) indicates variable rate FINANCE CHARGE CALCULATION This is a grace account. Grace period information on back. Average Dairy Days FINANCE CHARGE Nominal ANNUAL Daily Periodic in At Periodic Cash Advance/ Annual PERCENTAGE Balance Rate Billing Rate Transaction Fees Percanfage RATE Cycle Rate $0.00 0.08218%(v) 0 $0.00 $0.00 29.99%(v) 29.989% $0.00 0.08218%(v) 0 $0.00 $0.00 29.99%(v) 29.989% ? MAIL PAYMENTS TO: HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297.1051 It QUESTIONS? 24-HOUR CUSTOMER SERVICE ENGLISHIESPAWOL 1-000.477-8000 OUTSIDE USA, COLLECT: 1-757-523-3880 TDD HEARING IMPAIRED: 1.800-395-9020 12 Manage your account online at: wlnlw hsbccredRcard com ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 81822 SALINAS CA 93912-1822 EXCPT 090255 5 Z 25 0000000108 G STMTXO E G 00024089 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check H00 'BC 4 D Account Number 5408-0100-0563-5762 Lv Now Balance $3,721.88 Minimum Payment $125.00 Payment Due Date OWSM Current Payment Due $3,721.911 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 overlimit fees, pay the Current Payment Due. Amount Enclosed JAMBS N HARMON 8 3467 RITNER HWr NMMLLE PA 17241-9460 Illllrlllllll"Illrllirlllllndlrlly'lll"I'Illll'Illlll"'I'll 1"Iilll'il"11'11"l"111111'Iilll'I'I'1'I'lll'lllll'll'I'Ininll HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 M x s 540801000583976200372188003721885 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, CHARMAIN HOPPER, 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. ?//mot QL/77?!?_ CHARMAIN HOPPER 06905306 5408010005839762 $3721.88 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. t c O 1'. :. Sheriffs Office of Cumberland County Thoas Kline a ?,ta nt ? mbrr Edward L Schorpp Solicitor Ronny RAnderson Jody S Smith Chief Deputy OFFICE OF T4E RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/09/2009 08:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 10, 2009 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: James Harmon by making known unto James Harrison personally, at 3467 Ritner Highway, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $38.80 (PAID) March 14, 2009 Docket No. 2009-1381 HSBC Bank Nevada, N.A. v James Harmon SO ANSWERS, R THOMAS KLINE, SHERIFF "/' 4, 7, , " e -/ -- Deputy Sheriff ? e CO ??