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HomeMy WebLinkAbout09-3472 IN, THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. ROSALIND G GRAEFF Defendant No : 0- 31/1), 61411-1 Von 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 07031319 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 ROSALIND G GRAEFF Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the cl'iaims set forth in the following pages, you must take action within twlenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing wilth the court your defenses or objections to the claims set forth ag inst you. You are warned that if you fail to do so the case may pr=ed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or fojr 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 TOPROVIDE 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: ROISALIND G GRAEFF 1770 PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0577 . 4. Defendant made use of said credit card and has a current balance due of $2618.52 , 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 , ROSALIND G GRAEFF , INDIVIDUALLY , in the amount of $2618.52 with continuing interest thereon at the rate of 6.00016 per annum from May 05, 2009 plus costs. James C. Wa ro t,42524 WELT WEINBERG & REIS CO., L.P.A. 436 S nth Avenue, Suite 1400 Pitt gh, PA 15219 (41 34-7955 FAX 12-338-7130 070 1319 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. •MIG'MCard customer center Payment Address: 1-800-947-1W?7 HSBC CARD SERVICES P.O. BOX 2 PO BOX 37281 Salinas, CA BALTIMORE MD 93912-0082 21297-3281 Visit us at %*w.gmcard.com Quick Look Account Summary Statement Date 3111/08 Account number 5437 00031133 0577 New Balance $2,048.30 Total Credit Limit $11,000 Minimum Payment • $104.00 Total Cash Advance Limit $11,000 Payment Due Date 04105/08 Available Credit $8,951 Past Due Amount $3600 Available Cash Advance $8,951 Current Payment Dw' 1140.00 Page 1 of l # Days This Billing Cycle 29 .j?/1 ?\ To avoid an additional late fee, you must pay the Current Payment Due (which includes the Minimum Payment plus any Pest Due Amount). 'Irv"? Sea About Your Payment on reverse for an explanation of these amounts. \\ J Transaction] Date I Post Date I Description I Amount I Reference Number 02/16 02/18 PAYMENT - THANK YOU $51.00 CR 2021808A024382341124701 02!23; 02!25 OFFICE MAX MECHANICSBURG PA $635.99 MT0805OW73000010066818 03005! 03105 PAYMENT - THANK YOU $55.00 CR 203050BA024492331093601 031071 03107 LATE CHARGE ASSESSMENT $39.00 199999999a0000999997480 PROTECT `OUR CREDIT RATING. YOUR ACCOUNT IS PAST DUE. CALL 800-285-5100 TODAY TO MAKE YOUR PAYMENT. THANK YOU Balance Payments and Other Credits + Purchases, Cash Advances, ? Finance Charges = New Balance Fees and Other Debits 5.02 $106.00 $674.99 $44.29 $2,048.30 Purchases Balance Tra; Cash Advanl Average Daily Daily Periodic Nominal Annual Finance Cash Advance/ Annual Balance Rate percentage Rate a s Transaction Fees percentage Rate $1,727.20 0.08491% 30.99% $42.53 $0.00 30.990% $71.63 0.08491% 30.99% $1.76 $0.00 30.990% $0.00 0.00000% 30.99% $0.00 $0.00 0.000% 100200 11 STMT95 C 01-01 002163/BM BGA1 (Please detach a?hddrreturn bottom portion with payment and retain top portion for your records. Do not staple or clip your check to the form below.) H?r ' Account Number 5437 00031133 0577 New Balance $2,048.30 Minimum Payment $104.00 Payment Due Date 04/05/08 Currant Payment Due $140.00 visit Include account number on check to HSBC CARD SERVICES. Do not send cash. Send payment 7 to 10 ! to ma yowAOmunt onuns 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 R ALIND G GRAEFF 1770 PEYTON RANDOLPH CT N CUMBERLAND PA 17070.2226 RN 8 ?rss????sr???sss?sss???t?irr?r?er?a?re?s?i??ss?ssr???sssr??er? HSBC CARD SERVICES PO BOX 37281 BALTIMORE MD 21297-3281 M T? ram ssssa= as?ea 00141000 0204830 5437000311330577 8 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 07031319 5437000311330577 $2618.52 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 6,11 ;, r-T 1 f.. r 7HE i Sheriffs Office of Cumberland County R Thomas Kline Q tr of `11T1brr Edward L Schorpp Sheri' 40 Solicitor Ronny R Anderson Jody S Smith Chief Deputy 0MCE F '"ERIFF Civil Process Sergeant HSBC Bank Nevada, N.A. Case Number vs. 2009-3472 Rosalind G. Graeff SHERIFF'S RETURN OF SERVICE 06/22/2009 07:33 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Rosalind G. Graeff, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not served as to the defendant Rosalind G. Graeff. After several attempts the defendant will not answer the door and is being returned not served. SHERIFF COST: $67.60 June 23, 2009 0 a M O -6 .? .,. t-5 M . -? 3 -4 -r .) 1 S ` W N ~. > __ {- ` F' t L I ~ ' ~uL ~ PN~ ~ ~5'~i ,r-~ ,,. ,f,,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. ROSALIND G GRAEFF Defendant(s) No. 09-3472 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA ID #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7031319 JAM ~d ~'la - ~6 ~ ~Zor~la~r~ ~~~y~~~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No. 09-3472 CIVIL TERM ROSALIND G GRAEFF Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMA~Q, W$INBERG & REIS CO.,~I,.P.~A. By: Lyndsay 1 , Esq ire PA ID #2052 WELTMAN EINBERG & REIS CO., L.P.A. 1400 Koppers uidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #7031319 t,? BUG 24 AH 10? 21 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. ROSALIND G GRAEFF Defendant No. 09-3472-CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. 442524 WELTMAN, WEINBERG & REIS CO.. L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#7031319 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff No. 09-3472-CIVIL TERM vs. ROSALIND G GRAEFF Defendant AFFIDAVIT OF SERVICE OF COMPLAINT BEFORE ME, the undersigned authority, personally appeared James C. Warmbrodt, Esquire, who according to law deposes and says that a copy of the Complaint in Civil Action has been served on the Defendant, ROSALIND G GRAEFF. I . On or about APRIL 14T", 2010, Plaintiff received a signed Order of Court permitting service, on the Defendant, to be complete and valid upon mailing to the complaint by first class mail, certificate of mailing and by certified mail, return receipt requested. Said Order of Court is attached as Exhibit "I". 2. On or about AUGUST 6T", 2010, Plaintiff mailed the complaint to ROSALIND G GRAEFF. Said certificate of mailing and certified mail receipts are attached as Exhibit "2". WELTMAN, WEINBERG & REIS, CO., L.P.A. James C. WAr brodt, Esquire PA I.D. #41524 WELT N, EINBF,RG ers uilding, 1400 K T 436 Se h v enue Pittsbdrgh, A 15219 (412434 955 WW # 31319 Sworn to and subscribed L before met is - day of 2Q NOTdRY PUW( r' COMMONWEALTH OF PENNSYLVANIA NOMMal leaf Wayne A. Janes, Notary Pub k City Of PMburgn, wkigheny County www June 29 2014 Mamba. Penn enla Association Not do & REIS CO., L.P.A. APR 1 4 2010 IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA o Plaintiff No. 09-3472-CIVIL TERM ? vs. ?. ROSALIND G GRAEFF r t? ORDER OF COURT AND NOW, to-wit, this day of r L 2010, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendant, Rosalind G. Graeff, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant the last known address being 1770 Peyton Randolph Court, New Cumberland, Pa. 17070 by f,fTIA2S" w7ACertified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. DISTRIBUTION: Rosalind G Graeff 1770 Peyton Randolph Ct New Cumberland, PA 17070 y 'lliam "1'. Molczan, Esq. EXHIBIT /V? eltman, Weinberg & Reis, Co. LPA 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 152)9 \ a' a W W R 97031319 Wk BY THE COURT: r•1 lJ I L- (Domestic Only; No Insurance Coverage Provided) M For delivery information visit our website at wwwuspsxomj? p^ 'ostage ? $ EXHIBIT ir;e ,ti'ied Fee t O O Fietum Receipt Feet n Postmark p (endorsement Required) V Here mo"d" Restricted Delivery Fee (,Endorsement Required) O ro To nt Postanr & Fees I $ ?. ? Q Sent To ?`?O\%n6 G o ------_ - --------fa- --------.-... Cl Street, Apt. N) -1-10 ar P(i Box Nc+. \l., r` ?V._._!`(it__ ,\-__- CA ------- .i ----------------------- I ---- i',it?, State, ZIP+4 U,YY1 c'?1A ? PS Form 3800. Auglist 2006 SeL Reverse for Instructions -1C3, 3) C\ t11VITE©STATFS -SWY) Certificate Of ' 1 OST/SLSERVICE- Mailing This Certificate of Ma! ing provides evidence that mail has been presented to USPS® for mailing. This to= may be used for domestic and lntemational mail - From: V1/eltmanr Welnbera s- 1400 KOPPers Bld g 436 7th Ave . i sburgh PA 15219 ' , ,r To: ?? In ?? ??1..? •?1 1 Y?-C''? l ao Pe-sl 10 Vn tZarir??? C? New Ciivv?\oerIank PA i?ir)id PS Form 3817, April 2007 PSN 7530-02-000-9065 ~~~.~~"Q~~~~~ ~'~ TAE F'~t0`~~~Oalt~T;~.F?`3' CU~U 4*/T ~~ t t[ J: 1jLA C~7M$ERLA~{~ CG~~~T `~°. P~F~t~S i~~_'+~~5~(A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: 09-3472 CIVIL TERM vs. ROSALIND G GRAEFF PRAECIPE FOR DEFAULT JUDGMENT 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 07031319 C N Pit JAM Judgment Amount $2835.89 -~ a~ ~C~~ ~~ ors ~ ~,K~ Q;~`e-~~ ~ ~~,~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. ROSALIND G GRAEFF TO THE PROTHONTARY: Civil Action No. 09-3472 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant ROSALIND G GRAEFF above named, in the default of an Answer, in the amount of $2835.89 computed as follows: Amount claimed in Complaint $2618.52 Less payments / adjustments made $o.oo Interest on the remaining principal balance of $2618.52 from May 05, 2009 to September 22, 2010 @ the interest rate of 6.000 per annum $217.37 Attorney's fees $0.00 TOTAL $2835.89 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W ro t,42524 07031319 C Pit JAM Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, 15219 And that the last known address of the Def dant is ROSALIND G GRAEFF 1770 PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs ROSALIND G GRAEFF Defendant Case No. 09-3472 CIVIL TERM IMPORTANT NOTICE TO: ROSALIND G GRAEFF 1770~PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070 Date of Notice: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 248.3168 WELTMAN, WEIN~ERG & REIS CO,, L.P.A. Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: {412) 434-7955 7031319 N PIT T4L IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION H5BC BANK NEVADA, N.A Plaintiff vs. ROSALIND G GRAEFF Civil Action No. 09-3472 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant ROSALIND G GRAEFF is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), which states that the DMDC does not possess any information indicating the individual status. ROSALIND G GRAEFF 1770 PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070 is not in the military service. Further Affiant sayeth naught. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Sep-23-2010 09:23:50 ~ Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service A enc GRAEFF ROSALIND Based on the information you have furnished, the DMDC does not possess G any information indicatin the individual status. Upon seazching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). ~ ~-~ Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical Gaze and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you aze strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.htm1. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 9/23/2010 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d}(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:8PP8GQ9B4O https://www.dmdc.osd.mil/appj/scra/popreport.do 9/23/2010 ~ i ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. ROSALIND G GRAEFF Civil Action No. 09-3472 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order of Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $2835.89 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROTHONOTARY OR DEPUTY ROSALIND G GRAEFF 1770 PEYTON RANDOLPH CT NEW CUMBERLAND, PA 17070 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 ~~'~ ~lO WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-3472 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC BANK, NEVADA., NA Plaintiff (s) From ROSALIND G. GRAEFF AT 1770 PEYTON RANDOLPH CT., NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of SUSQUEHANNA VALLEY FCU AT 3850 HARTZDALE DRIVE, CAMP HILL, PA 17011 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2,835.89 L.L.$.50 Interest 61.07 Atty's Comm % Due Prothy $2.00 Atty Paid $197.10 Other Costs Plaintiff Paid Date: 2/18/11 David D Buell, Pr t tary (Seal) By: ' MCI" Deputy REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN WEINBERG & REIS CO., L.P.A 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: Plaintiff Telephone : 412-434-7955 Supreme Court ID No. 90963 ! FEB 1 8 AH In-: 5- U M B E R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. ROSALIND G GRAEFF Defendant SUSQUEHANNA VALLEY FCU, Garnishee, No. 09-3472 CIVIL TERM PRAECII'E FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: 41 ?/?1 C c' /I ?11?11a? lelpt i 5O Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15,219 (412) 434-7955 WWR#7031319 G???? tel. '-ze? l,,:' -71 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. ROSALIND G GRAEFF Defendant SUSQUEHANNA VALLEY FCU, Garnishee Civil Action No. 09-3472 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against ROSALIND G GRAEFF, Defendant 3. against SUSQUEHANNA VALLEY FCU, Garnishee 4. Judgment Amount Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 2835.89 $ 61.07 $ 2896.96 WELTMAN, WEINBERG & REIS CO., L.P.A. B Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15,219 (412) 434-7955 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor HSBC Bank USA, N.A. vs. Rosalind G. Graeff g •- : r c{. z Case Number 2009-3472 SHERIFF'S RETURN OF SERVICE 02/28/2011 01:59 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 28, 2011 at 1359 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Rosalind G. Graeff, in the hands, possession, or control of the within named garnishee, Susquehanna Valley Federal Credit Union, 3850 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Patricia Shaffer, Secretary/Receptionist personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 1, 2011 to Rosalind G. Graeff at 1770 Peyton Randolph Court, New Cumberland, PA 17070. SO ANSWERS, March 01, 2011 RON RANDERSON, SHERIFF Noah Cline, Deputy (c GeunrySude S^er'f Te! ;rofl Ir:;:. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7031319 HSBC BANK NEVADA, N.A vs. ROSALIND G GRAEFF and SUSQUEHANNA VALLEY FCU Garnishee(s) Attorney for Plaintiff(s) C.-, y rn '*Jfrt fir` -<> r + o , Cumberland County Court of Common Pleas ?c7 ° CD r CZ) rte > ' Q i NO. 09-3472 CIVIL TERM t- PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), SUSQUEHANNA VALLEY FCU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and subscribed Before me the ?0, day of February, 2011 NOTARY PUBLIC COMMONWEALTH pl PENNSYLVANIA Notarial seal Public Sheila G. Bevan, Notary o my Ross Trvp., All y MY Commission Ex Nov. 15, 2014 MEMBER PEMNSYLVA.NFA A TAiION OF NOTARIES James CyWarmbrodt, Esquire Attorn for Plaintiff a(v 'k a*1 as(A 47Y