The URL can be used to link to this page

Home My WebLink About09-1384 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff No: OQ- 138{ ?tVi??'Gt'Nt vs. PATRICIA BAHNWEG COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06941280 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 PATRICIA BAHNWEG 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: PATRICIA BAHNWEG 311 APRIL DR APT 1 CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8646 . 4. Defendant made use of said credit card and has a current balance due of $1980.32 , as of November 17, 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 17, 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 , PATRICIA BAHNWEG , INDIVIDUALLY , in the amount of $1980.32 with continuing interest thereon at the rate of 6.000% per annum from November 17, 2008 plus costs. James C. armbrodt,42524 WELTMAN, EINBERG & REIS CO., L.P.A. 436 Sev n h Avenue, Suite 1400 Pittsb g , PA 15219 (412) 3 -7955 FAX: 1 -338-7130 0694 C N Pit TSW This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. A. N-v [[ jj s 33 [ (EE [[ q q[ $$ j 68t1£EIl3IIGl13fi?,.?7£1?1I ??iFi ?'£I?1211'8?11??13IE 6tl3IS'111C &3I I??k£I39 ?fi?<[}3£???3££f33?I E£!€?!€iI£I€1£3€?i£#}£S ?£SIS££3El ?£i E4 ?£? - }} {{((33 33qq ss jj(( {{ ([ ^ (((j (( 33 jj3 77 }£?31£E£i€££$9llt?;'<iE£3€FP£I€EES?E£t{?[FC4 ?tl I£3£3 €£it3 i€3t3 54580015120886460Cit13£55O00019 1322 lYot;zx'httn:F ttneK fluetW ;miran is Eho uni£v£xs£s£tvxloyrv. ,e..... _, _>>.,.__ ,t .... ... ? .are :e"'x .: HSSC Gerd SWrvI£:a'3 S-d Papitro£Et Ta: f .N y t-E£ l ` & . "'VJ L ,:l account a rt-: g n le- ?"Ur Pay ACCOU NTCENTRAL ONLlt iE. CO AM ge .,.r. .9E<> s e--J PJ F{I :' ui£ Alm -m ftn ti ar;", t ..; .?Eaf£., 7 y ? 5 _.. C E'S itt'{ A. t f a[3 c Co # at n_ X - '7f T>i or k d di* ,. € „ 36E,ray - Pay your bill anytir£se at AccountContraiOmline,com YOUR HSBC ACCOUNT SUMMARY vrA ,fit r .... . .. ........... ....... a3.7 All Z-111 .AP .. EE S,t k ,.... i. YOUR BALANCE UEI'AILS P aAl .x ,. . ., t ' e0 .y Y et t F: ..................... .. _..., 51. - ........................................... ..... Notice: Bas £vaarsa side fat imp-tact it£Sorntatiori, YOUR TRANSACTIONS PAYlM & F3 T?ar:a. ;ate n;, ..,,.ence €? [3c,xFigi=,n iits .:;£arg:;s ri :l 05;.:'3 85?iCii33(i E J':12No5 . AYFNT T? t o YC;, PURCHASES, G "S ADVANCES, to FEES Af::,3UNT s£P7£F:T FLAP 'tn:9 '.ii „ATE FEE 336,,F5Cl ? A „h;;•£ $775 .40 m I 7 Ch-go-your ftdc1mrsontinn inrtsntiy of AcaaunxCnntrsK7niiars.ranx -771 00, YOUR CONTACT INFORMATION Please note-Address changes may take up to two (2) weeks to process. Please prtit clearly Address It Street Name Apt f and Other Address Into City State Zip Code Your Home Phone Number Your Business Phone Number code) (Ann cede) Print Email Add res' _ •Emsd add•®s is 00"t We puW mnsnmhsar silo you via erMl/? naug lost eaouu eroaww.v.siq es,..?...+w•+- __-.._.-_.._ -dams! mwtethp part- gyou PmW Y?bon froaa raumivbY aptri,proupldbDY?core sA'bare w11 esruod tfrfelsalon. •AbWYom PaymenL• • Yon agree to pry at less[ the Mintmmm Payment in time to be credited to yar Account in of the Payment Due Date. If your Account is delinquent, you can avoid an additional Late Payment Fee by paying at lead the Mm®um Payment Doe, which imbdes my par due amount, in time to be posted a of the Payment Due Date. Yon may pry mac thmthe Monsoon Payment Durand you may pry the tome New Balance at any time. Payments should be mailed with a Single coupon to Wa palmed address shown on the hod of due Wait statement. Payments must be made by a single check amoney order payable in AS. dollars and draw on a 11.5. latt0nim payments received at the payment address by 5:00 pm Eamrn time, on my dry, will be credited to your Account a of the date of receipt; omerwise payment will be eredhod in of the sat day. Crediting payments to your Amount may be delayed up to five days if on payment is not made as daubed above: is not received at the add.- provided for remittance; is not Accompanied by the payment coupon; is received in m emlope oil= tin the soveloW provided fr rmintsnce; is AAW" folded r papr clipped; r includes mubiple payment -up- r died.. • Y your New Balance is a credit balance, it will be applied to future purchases or cast[ advances, or refmded to you at your written toques[, Requests should be mailed to the inquiry addre s shown on the flout of your billbg statement. By sending an a check for payment on yen Aeso®4 yoaratho an to make a roe time electreak fonds tram(r (EFF": m your bank trm®t o[ m ptoces the payments a check traiandlem. Whin we ua iformation from yar dtedkto make an EFr, fads may be withdrawn lima your Accotmd w soon s the core dry we yourpayment, end You will not teceive your check back ft en fmmcia taw onion If yen do not want your checks to m EFT, Please all artomr service at dw phone of your card Payment By Phone: What you m our optro1W service, you au hoti , us to initiate an electronic from your designated tack account r10 process a dick tranacticn. You amen aahrbe the of each peymem, Please rem. [hie Athoriirstica for cut Renewal- AaAmusl m Account. f yon Annual Fee a bilked ammlly, the fce f you call and curse y. AaaA o billed Yon may continue to urn your Gad during the without paying the fee. If yon fee is billed close your Account due to the Amid Pee dirge, be credited brie to your Account. Haw VA : We cantlas the periodic Fmma Charge on by multiplying the Applicable Daily Periodic Rate by theA Balance fat cant- category dranocdm shown on your statement (erg., prehaa, balance bansfan, cash advances); We are slim multiplied by the comber of drys is the biting cycle. Daunja Bing the Daily Balance: We Wm the begim®g balance fr cub category of rmacfiooc each day, add my new taaondims. my peviom drys periodic Ftnasee Charges, any aeased fees and d aga, and subbad any paymmu w&o, credin. If a traaadim poem after the beginning of the billing cycle, tie applicable Daily Balance And my related Finance Ousge calculations will be adjusted retroativahe to nchde the tnmaction -ovum in of the day 9 was pasted Caledating tbeAverage Dally Balmer: Fr eah baractim category, we add all the Daly B.1-- fr the billing cyck together and divide the total by the nwI of days in the billing cycle. f dr bOlmoe for any dry is has mm into, we treat it in zoo. this is the Average Daily Balance (mchding new purchases) method Grace Periods: For ctedn arc puaduaes. periodic F- Charges begin to sector on the date of the bausactiam sad con n _ to aem¢ udu prymeu in full is redted to yar Account However. you bwe a Cora Period of as lead 20 days horn Poe as- date if no periodic Forma Chrge was billed to the Account in tie emrew billing Phi omrwaa the Payment Due Date will be 25 drys from the stmme t dete.Thatmeans,fynu paidth NewB -your hat billing auteatm by the Ps5 Dun Doe billing su term, you have until the Payment Due Date for billing cycle to Pay your New Balance in fall to avoid ofpriodic Fuanes charges on new credit cad Chargen tint accrue after the sWmesa date the nena billing swam-. These is no Cram Period (ins Whaac vewfm, mchdiog credit card checks periodic Finance Charges begin to seem m the Ad continue to neeruue until pryaam in fall' Account Dail Perio?e urge Rate: M. Annual Percentage Rates on yon - reflect fls Annualized equivalent of the Daily applied rhaiotg ¦ parbuamhr billing cycle. The Rats wry diflr hen tlr Namiusl AmuW of the inebwion of any Fiona Charge od- d= Barge. Your Annual Percentage Rates and any vary Chump: A Minimum FINANCE CHARGE of drged in each billing cycle in which peiodw Firma arc pM". R3gMs Summary: In case of emote or questions about your • summons: If you think your billing smtmeat ; wrong, r If you need more mfrmation about a transaction on your billing Moment, write ea a soma a pelanble, on a seI , shat of paper, a Csrdmemba Service Coate, PQ Ban 5251, caA Swam, IL 60197-%G. We sast her from you no Ed. it. 60 days albr we sent you the form bA* macarstonwtim 6e ricerprobim appeared. Yon ®telepbose m, he doing awill ad pasture your rights. lnyour )ter, please include the following ofcrmstA= . • Your arms and Account comber • 1he doer amountof the suspected rror. • A dariptionof the eras. EVIM f Yon mn why you behave thus is an rror and any step you Inure Wren or resolve the err. You do act have te pay any amount in gnatioa while we n mw , tin you m obligated to pay me Per of your bill dm are not in question. While we iavesligsu your q , wa cannot report you s riche at or telm any action to cdket the Atom you questies. Special Rule ter Cradle Card Pmcbaas: If you have a problem with the quality of goob r swine that youpmclu ad with a rent[ cad and you bm tried in good faith mooned the problem with the merchant, you may not bin to pay the renaming amount dw on tln goods r srvices. This protection applies only when tie Pie Price war morethanS50 sod tie prdrae was made in your home auu or within 100 mike of yourmailin g adduss. If ere own r opiate the merchant r f me mailed you A. sdvrtia nm fr the popety or arvks, an prcham are courted A gardkw of amount or location of Purchase. Debt collection: % an required by bm when applkahk, to notify you the we are attempWg to called a debt, and any Information obtained will be used for that purpose. Negethre Ctsdit Burma Repenting: We may report iub-tian arat yas Aees®t m redid bureaus. Lee payments, mired payme m; or ad. defABs an your Account may be reflected In your credit report. OI BN5991-11-02/112008 M ?m ' IMPORTANT ACCOUNT INFORMATION YOUR FINANCE CHANGES FINANCE ANNUAL NOMINAL ANNUAL Fe ,l di" I E. CHARGES PERCENTAGE RATE PERCENTAGE RATE ? i . 4It HOW TO REACH US C.r..a £. if, .: ^uz :, xzce :. ............ __............. ............ ___............................................. ...................... 877-2 PAY-CARD ::> .. .,... .. ...............3£54.337.433? P:i ........ ...... ..... ...Paprsssrrt Can4a#', Po Sar 17313, Baltl£narn, MD 712.97-1313 `,,i...: .. ...............Carahna£rabar So£vicaa, PO Box 5250, Carol Stream, IL 60197 5250 .F#.}-'#!vf#f_t ... ...., .. AaWUrztG#£FiealC3n II£4a.Wa1 ESPECIALLY FOR YOU TRAVELING OUTSIDE THE UNITED STATES? AL lqw t`r„ r£ z ? .? #- _F y :.i=a 1,5. "sutra p "i? -Itt "_t? '.1 KEt ) !.• (3 3 f-.? [ ? 1 d Afl >iC2 Sy", '"(£ c1 t' :il I loe i < i.: f r• a;^u{ u >...+: ?"'Y1 E1{; US :ll a ?Vc.t:; l vv:ii '.£;i; . V.le? ,.....: ;tL•rri` :(.a A"p I X co VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. Section 4904 relating to unworn falsification to authorities, that hetshe is, CHARMAIN HOPPER, 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. CHARMAIN HOPPER 06941280 5458001512088646 $2242.70 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. r?? -t 0 0 p - g QU ? ? o Sheriffs Office of Cumberland County R Thomas Kline oO%r EC Cumbtr Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy QFFiQE of T"E SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/10/2009 04:06 PM - Kenneth Gossert, Deputy Sheriff, who being duly swom according to law, states that on March 10, 2009 at 1606 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Patricia Bahnweg, by making known unto Patricia Bahnweg personally, at 311 April Drive #1, Camp Hill, 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: $41.50 (PAID) March 16, 2009 2009-1384 HSBC Bank Nevada, NA SO ANSWERS, THOMAS KLINE, S40 ?IFZF VS Patricia Bahnweg r P ,