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Home My WebLink About09-3467h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N . A ,M?/? Plaintiff No: ?l? 3C/?? ?/fir/ ?rm VS. BARBARA A MARTIN 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 06874318 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 BARBARA A MARTIN 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: BARBARA A MARTIN 302 W LISBURN RD MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4860 4. Defendant made use of said credit card and has a current balance due of $3781.83 , as of May 05, 2009 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000$ 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 , BARBARA A MARTIN , INDIVIDUALLY , in the amount of $3781.83 with continuing interest thereon at the rate of 6.0001 per annum from May 05, 2009 plus costs. WWEINBERG & REIS CO., L.P.A. gP4318 waxmwroat, 42524 4nth Avenue, Suite 1400 Pgh, PA 15219 (4-7955 F -338-7130 0 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. HOUSF-HOLD BANK GOLD MASTERCARD STATEMENT BARBARA A MARTIN - Valued Cardmember Since 2002 ACCOUNT SUMMARY ACCOUNT 5408-010009084880 NUMBER TOTAL CREDIT LIMIT $3,000 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE 101=7 TRANSACTION SUMMARY (For additional transaction detail go to www.householdbank.com) TRANS POST TRANSACTION REFERENCE AM OUNT. DATE DATE DESCRIPTION NUMBER CHARGES CREDITS. 101`17 10f17 PAYMENT - THANK YOU 8540801729001 WZPXSWRXL -$220.00 09125 09127 WAWA, INC. OW25 004 GAP PA WM72700100000010053489 $25.00 10118 10119 GAP DINER RESTAURANT GAP PA MT072920100000010032029 $8.24 10118 10119 WINE & SPIRITS 2215 HARRISBURG PA MT072920105000010037718 $48.74 10118 10120 WAWA, INC. 06025 004 GAP PA MT072930098000010048M $40.50 10108 10/08 OVERLIMIT CHARGE ASSESSMENT 10000001030000999771090 $35.00 FINANCE CHARGE CALCULATION This is a grace account. Grace period information on back. Average Daily Days FINANCE CHARGE Nominal ANNUAL Daily Periodic in At Periodic Cash Advance/ Annuat PERCENTAGE Balance Rate Billing Rate Transaction Fees percentage RATE Cycle Rate PURCHASES $1,709.58 0.07889% 29 $38.02 $0.00 27.99% 27.990% BALANCE TRANSFER $1,381.24 0.07889% 29 $30.72 $0.00 27.99% 27.990% CASH ADVANCES $0.00 0.00000% 29 $0.00 $0.00 29.24% 29.240% PAYMENT SUMMARY OVERLIMIT AMOUNT $48.83 MINIMUM PAYMENT' $100.00 CURRENT PAYMENT DUE' $148.83 PAYMENT DUE DATE 11118/07 PAST DUE AMOUNT $0.00 'See reverse side for an explanation of Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $3,044.41 PAYMENTSICREDITS $220.00 PURCHASESIDEBITS + $155.48 FINANCE CHARGE + $88.74 NEW BALANCE = $3,048.83 V MAIL PAYMENTS TO: HSBC CARD SERVICES PO BOX 88000 BALTIMORE MD 21288-0001 Q QUESTIONS? 24-HOUR CUSTOMER SERVICE 1-000.477.8000 OUTSIDE USA, COLLECT: 1-757-523-38W MD HEARING IMPAIRED: 1.800.395.9020 2 Manage your account online at: www householdbank corn ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 81822 SALINAS CA 93912-1822 HDP1 090550 5 22 0000000103 G STMT37 D J 00019802 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check Account Number 5408-0100-0908-4880 dew Balance $3,048.83 aayment Due Date 111187 Current Payment Due $148.8: Make checks payable to HSBC CARD SERVICES. Please write your account number on your check. Do not fold, staple or clip. Do not send cash. Please send your payment 7 days prior to the payment due date to ensure timely delivery. Amount Enclosed BARBARA A MARTIN 302 R LISBURN RD MECHANICSBURG PA 17055-5825 E BSBC CARD SERVICES IIIIIIIso III III Its If It III I1III IIIIIIIIIIIIIIIIIIIIII1.r11IIis III PO BOX 88000 BALTIMORE MD 21288-0001 1111 liege 1111111 11111 111111 11111111111111111111 111111 11 1 M 540801000908486000014863003048634 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. VALERIE DEMARAIS 06874318 5408010009084860 $3781.83 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 10, _, f w c, 20HM€Y21 t? ,J i'u Tti,' 114 #lf,-o M/ ??? aas?a9 ?r. Sheriffs Office of Cumberland County R Thomas Kline s'00 st cumbri? ? Edward L Schorpp Sheriff" ? Solicitor ', > fr Ronny R Anderson Jody S Smith Chief Deputy OMM OF THE PgRIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/28/2009 07:48 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on May 28, 2009 at 1950 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Barbara A. Martin, by making known unto Thomas Martin, defendant at 302 W. Lisburn Road Mechanicsburg Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 May 29, 2009 SO ANSWERS, R TH KLI ,SHERIFF 2009-3467 HSBC Bank Nevada V Barbara A. Martin riff .a r - v IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION HSBC BANK NEVADA, N.A. v. Case Number: CNIL 09 3467 BARBARA MARTIN ANSWER OF DEFENDANT pro se Deferant, Barbara Martin, answers the Complaint of Plaintiff as follows: 1. The Defendant lacks sufficient information to either admit or deny the allegations of Paragraph 1 of the Complaint. 2. The Defendant admits the allegations of Paragraph 2 of the Complaint. 3. The Defendant admits the allegations of Paragraph 3 of the Complaint. 4. The Defendant denies the allegations of Paragraph 4 of the Complaint. 5. The Defendant admits the allegations of Paragraph 5 of the Complaint. 6. The Defendant denies the allegations of Paragraph 6 of the Complaint. 7. The Defendant admits the allegations of Paiagn~ph 7 of the Complaint. VERIFICATION The Defendant verifies that the statements made herein are true and correct based upon her knowledge, information and belief. The statements are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. .~C~v~ ~ Barbara Martin 302 West Lisburn Road Mechanicsburg, PA 17055 (717) 802-6208 CERTIFICATE OF SERVICE .dam The Defendant(s) HEREBY CERTIFY that on this I ~ day of ,'~"' `~' copy of the foregoing pleading was mailed, first-class, postage pre-paid to: James Wannbmdt 436 N. Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Attorney for Plaintiff 20~a OF TN~~~^ -; ,rt~C T~QY 2009 JUP~ t 6 Pik ~: I CU"~a t ;, ,,w~~~;~' ~ r ., v