The URL can be used to link to this page

Home My WebLink About09-3470r., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff vs NED B SNYDER Defendant No : 0- ? ??7U ?l V1 ? T-ern2 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 07225875 C N Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff VS. Civil Action No NED B SNYDER 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 b 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 4b 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: NED B SNYDER 1603 MATTHEW RD CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX7839 . 4. Defendant made use of said credit card and has a current balance due of $7578.20 , 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 "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 , NED B SNYDER , INDIVIDUALLY , in the amount of $7578.20 with continuing interest thereon at the rate of 6.000% per annum from May 05, 2009 plus costs. James Wa ro t,42524 WELT WEINBERG & REIS CO., L.P.A. 436 e enth Avenue, Suite 1400 Pit s rgh, PA 15219 (4 ) 434-7955 F 412-338-7130 07 5875 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. CARDMEMBER SERVICES PO BOX 21400 TULSA OK 74121-1460 Payments Payable To: HSBC Card Services STATEMENT NEW MNIMUM DATE BALANCE PAYMENT DUE 12!12107 9,064.98 "0.00 O New add- ce.md1 Check box. See - sid.. DIRECT MERCHANTS BANK! VISA AMOUNT PAST PAYMENT MUST AMOUNT DUE BE RECEIVED BY ENCLOSED 270.00 01106108 $ ?- SEND PAYMENTS TO: NED B SNYDER 021 '50070284179971' 1603 MATTHEW RD 935 CAMP HILL PA 17011-1165 PAYMENT CENTER PO BOX 17313 III,,,III„,,,,II,,,II,,,II,,,Il,lirrrirl,llr,rr,Ilrrl, I BALTIMORE, MD 21297-1313 r11.11.11h.1.11.1rr1...Irl rIh.11,r„ 111. 11... 1 11.. II, 1...1 473068012203783900054000009054982 Detach and insert this top Portion in the anebsed envelope. Be sun the Payment Center address stows in the -lope vdndow. DIRECT MERCHANTS BANK® A VIEW OF YOUR RECENT CHARGES AND CREDITS Pay Online Anytime: wwwj ccotmftsn&WordkiB com TRANS POST REFERENCE DATE DATE NUMBER DESCRIPTION CREDITS S PAYMENTS AND CREDITS 11/14 11/14 7473088OZOIROXl ZL PAYMENT - THANK YOU 270, PURCHASES, CASH ADVANCES & FEES 'FINANCE CHARGE' PURCHASES $0.03 CASH ADVANCE $43.77 43.80 YOUR ACCOUNT SUMMARY - DECEMBER ACCOUNT AND PAYMENT N KM MATION CREDIT LINE INFORMATION ACCOUNT NUMBER 4730 5801 2203 7839 TOTAL CREDIT LINE $ 12500 CE $9201.18 NEW BALANCE 90"As TOTAL AVAILABLE CREDIT 0 S 0.00 MOWN PAYMENT DUE 540.00 CASH ADVANCE CREDIT LIMIT 11250 VANCES * 0.00 AMOUNT PAST DUE 270.00 CASH ADVANCE AVAILABLE CREDIT ITS - O .DO PAYMENT MWT SE OVERUMIT AMOUNT YMENTS - 270.00 RECEIVED BY JAN IL2009 'CASH ADVANCE CREDIT LAST MAMW OTHER . 0.00 PORTION OF YOUR TOTAL CftqUyo& FINANCE CHARGE . 43.80 'REP, In NEW BALANCE . 9064.N CARDMEMBER SE :1800.379-7998 PAYMENT BY 2-PAY-CARD FROM OUTSIDE THE U.S. CALL COLLECT:904-99 ING IMPAIRED-TDD CUSTOMERS CALL: 877-902-0967 SEND PAYMENTS TO: PAYMENT BOX 17313, BALTIMORE, MD 21207-1313 MAIL INQUIRIES TO: CARDME , PO BOX 0250, CAROL STREAM, IL 80197-9841 NOTICE: SF?„R RS FOR IMPORTANT INFORMATION. P : www.scoounmr*alonlm.com A SUMMARY OF YOUR FINANCE CLUDING PROMOTIONAL OFFERS 41L 111111111110F NOMINAL NUMBER AVERA Y ANNUAL ANNUAL OF DAYS STATEMENT i D PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BA _E RATE RATE CHARGE RATE CYCLE DATE PURCHASES 7.38 .01615% 5.90% 0.03 0.90 % CASH ADVANCES 9033.96 .01615% 5.90 % 43.77 0.90 % 30 12112107 5994 0005 XPD 2 7 8 071212 ED Page 1 of 1 5420 0100 CCDD OIBY5994 935 -7a-)5I? -7 ? ,? yo a tllllllli W NSSNNI 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 07225875 4730680122037839 $7800.21 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Q T] I` '77ARY 2C9 ?7 111 , '. l?L'? yo3 0 7r Sheriffs Office of Cumberland County R Thomas Kline 4661'o cr of ''rruubrry???0 Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFf ',,'E {. ` E "ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/03/2009 02:11 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 3, 2009 at 1411 hours, she served a true copy of the within Confession and Notice, upon the within namec defendant, to wit: Ned B. Snyder, by making known unto himself personally, defendant at 1603 Matthew Road Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, June 04, 2009 R THOMAS KLINE, SHERIFF Deputy S eriff 2009-3470 HSBC Bank Nevada v Ned B. Snyder C-j C: C