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Home My WebLink About09-2479IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: OQ- 0~~79 LitVilT~f'N, vs. SERGEY A REZNICHENKO Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: V Kelly Mulholland,69978 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 07051316 C N Jer SPE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No SERGEY A REZNICHENKO 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: SERGEY A REZNICHENKO 917 HERMAN DR MECHANICSBURG,.PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1305 . 4. Defendant made use of said credit card and has a current balance due of $3031.74 as of January 22, 2009 . 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 0.000 per annum on the unpaid balance from January 22, 2009 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 SERGEY A REZNICHENKO INDIVIDUALLY in the amount of $3031.74 with continuing interest thereon at the rate of 0.000 per annum from January 22, 2009 plus cos. V Ke y Mu o an 978 WELTMAN, WEINBERG REIS CO., L.P.A. 325 CHESTNUT STRE SUITE 501 PHILADELPHIA, PA 9106-2614 215-599-1500 FAX: 215-599-1505 07051316 C N Jer SPE 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. SERGEY A REZNICHENKO -Valued Cardmember Since 2006 ACCOUNT SUMMARY ACCOUNT 5440-4550-3888.1305 NUMBER CASH CREDR LIMB f 52,800 CASH LIMrr AVAILABLE 5722 TOTAL CREDIT LIMfi $2,800 TOTAL CREDIT LIMIT 5722 AVAILABLE STATEMENT DATE 0 2!08/08 PAYMENT SUMMARY MINIMUM PAYMENT` 527.00 PAYMENT DUE DATE 03/04108 CURRENT PAYMENT DUE• 527.00 "See About Your Payment on reverse for an explanation of these amounts. t Cash Credit Limn is a portion of the Total CrodR Lmit Page 1 of 2 BALANCE SUMMARY PREVIOUS BALANCE E370.12 PAYMENTSICREDRS - 5370.12 PURCHASESJDEBRS + 51,875.54 LATE PAYMENT CHARGE + 50.00 MISC. FINANCE CHARGE + 50.00 FINANCE CHARGE + ~$,~ NEW BALANCE = 51,877.81 TRANSACTION SUMMARY (For additronal tnnsactfon detail go to www.orchardbank.comj !TRANS POST TRANSACTION REFERENCE AM DATE DATE DESCRIPTION NUMBER CHARGES 01124 0184 PAYMENT -THANK YOU 2012408A017081901222201 01/28 01/29 BB OF ATLANTA #14 CONLEY GA MT080280102000010199548 550.50 01128 01129 PILOT Valdosta GA MT080290107000010183053 5393.83 01/28 01!30 SPEEDCO#327 CONLEY GA MTp60300100000010230948 585.33 01129 02/01 GEORGIANNA MOTEL GAINESVILLE GA MT080320102000010238243 548.00 01!31 02!01 PILOT Vienna GA MT080320108000010141354 5490.75 02/01 02/02 PILOT Wildwood FL MT080330102000010149574 512.00 02/02 02104 OT 707 07007073DORAVILLE GA MT080350088000010727226 558.92 02/03 02104 KROGER CO 365 SL9 MARIETTA GA MT08035010100D010237400 518.83 02!03 02105 PILOT Bnselton GA MT080380101000010213796 5432.78 02105 02!07 SUNOCO SVC STATION GREENCASTLE PA MT0803801p5000010228278 5247.82 02108 02!08 ANNUAL FEE ASSESSED 10000005080000889494280 559.00 SEE REVERSE FOR CARD RENEWAL INFORMATION -5370.12 ~c r"t .-- / MAIL PAYMENTS TO: '~ QUESTIONS? ®MAIL INQUIRIES TO: HSBC CARD SERVICES 24-HOUR AUTOMATED ACCOUNT INFORMATION HSBC CARD SERVICES PO BOX 68000 ENGLISH 1.503-283.4037 PO BOX 80084 BALTIMORE MD 21288-0001 ESPANOL 1-503-293-4834 SALINAS CA 839120084 ~ Manage your account online at: www.orchardbank.com oDS1 1102015 OB 0000000508 G STMi07 D 7 00032595 PLEASE DETACH AND RETURN BOTTOM POR110N WfTH YOUR PAYMENT: To Assuro Proper Credit Pksae Write Your Account Number ~ Your Check Payment Due Date o31a4 New Balance 51,677.91 Currant Payment Due i27 fnc a eccount num on to H-~C not send cas , end paym 7 to 10 daya prior to the Payment Due Date to ensure timely delivery. Amount Enclosed #BWNHYTS #328036681307# SRRCiEY A RSZIZICK8NK0 917 HERMAN DR MECHANICSBURr3 PA 17055-5736 III~~IIIII"1111'IIIIIIIIIII~I~IIIIIIIIIII~11111"'rll~ll"1 HSBC CARD 38RVICE3 PO SOX 88000 BALTIMORE DID 21288-0001 ~ir~r~rn~~ii~~~~u~r~rr~r~~rn~~rn~~urnr~~~rr~r~ 54404550366813050000270000]877918 SERGEY A REZNICHENKO -Valued Cardmember Since 2006 Page 2 of 2 PERIODIC FINANCE CHARGE SUMMARY This is a grace account Grace period information on back Balance Subject Daily Daya Fi~anes Charges NOMINAL To Finance Charge Periodic in Billing At Perlodie ANNUAL Average Daily Balance Rate Cycle Rab PERCENTAGE RATE BALANCE TRANSFER $180.84 0.04220% 31 52.37 15.40% PURCHASES 50.00 0.04220% 31 50.00 15.40% CASH ADVANCES 50.00 0.00000% 31 50.00 24.15% ANNUAL PERCENTAGE RATE" 13.400% "May ba higher tfron Nominal Percentage Rate if statement includes miae. finance charges. As a reminder, your APRs may immediately increase up to the Default APR if your payment is late or you exceed your credit Nmit, ~ per your Cardmember Agreement and Disclosure Statement. IMPORTANT INFORMATION Your variable Customary APR will be based on 1/365th of the sum of the highest Prime Rate(s) published in The Wall Street Journal in the month prior to the month in which the billing cycle ends ("Index") plus 8.15% ('Spread") and will never be leas than 14.90% APR. If at anytime your Minimum Payment is received and posted aRer the Payment Due Date, you exceed the credit limd on this Account or any other axount you have with us or our affiliates, or you are otherwise in defauR urxkr the terms of your Cardmember Agreement, a variable Default APR of "Index" plus 20.99% ("Spread") will appy and will never be less than 24.99% APR. """""CARDMEMBER NEWS""""" To learn about services we offer to protect your account at times of need, call800-690-1532. ~ MAIL PAYMENTS TO: '~ QUESTIONS? ®MAIL INQUIRIES TO• HSBC CARD SERVICES 24HOUR AUTOMATED ACCOUNT INFORMATION • ~ BOX 88000 ENGLISH 1-503-283~IXi7 HSBC CARD SERVICES BALTIMORE MD 21288.0001 ESPANOL 1-503.293.4834 3gLBNASBCA 93812-0084 ~ Manage your account online at: www.orchardbank.com 110201 5 O8 0000000~.i08 G STMT07 D 7 00032585 ODS1 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assuro Proper Credit Please Writs Your Aeeount Number On Your Check 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., 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. ~Gl.~ A~'~~ ~" lWl~ VALERIE DEMARAIS 07051316 5440455036681305 $3031.74 R,ez n.i ch PnKD ~ M ,~,e~ l~~ ~ ~, S~~g~y A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ~a~/ ~ i ~'r-~.Jt-~ ,~.~~ ~. Z~G9 ~~'~~ ~~~ ~ ~~ ~ ~ Z ~~;"`~' dik~~G , ~ ,,- ,, Pa A~ 5D ~~-r~ $9 pg3 ~j ,~. aa3gh5