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Home My WebLink About09-3465 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. ANN A MCHALE MARY Defendant No: p.311 U5 T fi-q 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 07217709 C N Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. Civil Action No ANN A MCHALE MARY 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: ANN A MCHALE MARY 1128 COLUMBUS AVE APT 4 LEMOYNE, PA 17043 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8660 . 4. Defendant made use of said credit card and has a current balance due of $6320.69 , as of May 05, 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 6.OOOg per annum on the unpaid balance from May 05, 2009 . A copy of Plaintiff's STATEMENT OF ACCO UNT is attached hereto, marked as Exhibit 111" 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 , ANN A MCHALE MARY , INDIVIDUALLY , in the amount of $6320.69 with continuing interest thereon at the rate of 6.000% per annum from May 05, 2009 plus costs. JWa ro t,42524 WWEINBERG & REIS CO., L.P.A. 4nth Avenue, Suite 1400 Pgh, PA 15219 (V4134-7955 F 2-338-7130 09 C N Pit KMJ 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 MIGM Card Quick Look Account Summary Statement Date 3/12/08 Account number 5437 0005 0688 8680 New Balance $6,885.46 Total Credit Limit $0 Minimum Payment' $198.00 Total Cash Advance Limit $0 Payment Due Date 04106108 Available Credit $0 Past Due Amount $162.00 Available Cash Advance $0 # Days This Billing Cycle 29 Current Pa ant Due • $360600 Page 1 of 1 Customer Center Payment Address: 1-800-947-1000 HSBC CARD SERVICES P.O. BOX 80082 PO BOX 37281 Salinas, CA BALTIMORE MD 93912-0082 21297-3281 Visit us at www.gmcard.com To avoid an additional late fee, you must pay the Current Payment Due (which includes the Minimum Payment plus any Past Due Amount). * Sae About Your Payment on reverse for an explanation of these amounts. Transaction Date Post Dade Description Amount I Reference Number 02116 02118 RED ROBIN #333 HARRISBURG PA $77.72 MT080490073000010205047 03!08 03108 LATE CHARGE ASSESSMENT $39.00 19999999980000999970100 PROTECT YOUR CREDIT RATING. YOUR ACCOUNT IS PAST DUE. CALL 800-285-5100 TODAY TO MAKE YOUR PAYMENT. THANK YOU. r. ; Previous Balance T Payments and Other Credits + Purchases, Cash Advances, + Finance Charges = New Balance Fees and Other Debits $6,678.00 $0.00 5118.72 $90.14 $6,885.48 is .:. . '..; Average Daily Daily Periodic Nominal Annual Finance Cash Advance/ Annual Balance Rate Percenteas Rate C a e Transaction Fees Percentage Rate Purchases $1,588.54 0.04107% 14.99% $18.92 $0.00 14.990% Access Checks $3,001.12 0.04107% 14.99% $35.74 $0.00 14.990% Cash Advances $1,801.34 0.05863% 21.40% $30.63 $0.00 21.400% Access Checks $407.34 0.04107% 14.99% $4.85 $0.00 14.990% Previous Earnings $190.34 Now Earnings Total $194.23 Remember, every time you make a purchase with Earnings Received $3.89 Anniversary Date 511194 your GM Card, you'll earn 8% In OM Card Earnings. Additional Earnings $0.00 Anniversary Y-T-D Earnings $31,83 No other credit card offers such rich rewards!t Earnings Adjustments $0.00 Ldetime Earnings Redeemed $0.00 Current Period Earnings $3.89 r I s * * * * * * * * * * * * * * * Important Information " * " " " " * * * * * * w As a reminder, your APRs may immediately increase up to the Default APR if your payment is late or you exceed your credit jimlt as per your Cardmember Agreement and Disclosure Statement. 1002005 A 12 STMT95 E 01-01 0026031BM BGA1 (Please detach and return bottom portion with payment and retain top portion for your records. Do not staple or clip your check to the form below.) HSBC m Account Number 5437 0005 06M 86M New Balance $6,885.46 Minimum Payment $198.00 Payment Due Date 04/06= Current Payment Due $360.00 ,,.,,???,??,..., Include account number on check to HSBC CARD SERVICES. Do not send cash. Send payment 7 to 10 visit r to and Auaunt online days prior to Payment Due Date to ensure timely delivery. To avoid an additional late fee, pay the Current Payment Due. tSee reverse for more information Amount Enclosed MARY ANN A MCHALE III 11 1 11 1 1 III IIII III I tt t tit tt t t ?? tit tt tit t tt tutu t t 1128 COLUMBUS AVE APT 4 N LEMOYNE PA 170434729 HSBC CARD SERVICES R I III III IIII 111 1 1 1 1 1 1 1 I I I I I Box 37281 n t n t t i n n n tau u t n t t o n u t t n t BALTIMORE MD 21297-3281 M X X ea?a>• aaa-I 0036000 0668546 5437000506888660 2 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. VALERIE DEMARAIS 07217709 5437000506888660 $6546.95 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 17 17 TFE .1 u ii ??? a?s7ak Sheriff s Office of Cumberland County R Thomas Kline ~.°~~tr at ~ia~pbrrf~rr Edward L Schorpp Sheriff ~ Solicitor Ronny R Anderson °=~~~~~~~'*" Jody S Smith Chief Deputy c~~rcE o~ rte s++~rticF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/10/2009 07:16 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that hle made a diligent search and inquiry for the within named defendant to wit: Ann A. Mchale Mary, bit was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not fond as to the defendant Ann A. Mchale Mary. Mary Lou Herr caregiver, has advised the deputy that Anln A. Mchale Mary is deceased. SHERIFF COST: $61.80 June 11, 2009 2009-3465 HSBC Bank v Ann Mchale Mary cn-_ y ,,.. ; ~- ,. C,' i ti ~-, ti_, _ - - F:_ ':v r= -f p c7 o -n ~ m~ r _ ~ Q Z} ' -i i ~ !~ C~ s"n .._ N