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Home My WebLink About09-3621.J • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: cR_ %ai Ci wit -re-m vs. COMPLAINT IN CIVIL ACTION MICHAEL D FAUST 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 07265363 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 MICHAEL D FAUST 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: MICHAEL D FAUST 4 ROCKLEDGE CT CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2138 . 4. Defendant made use of said credit card and has a current balance due of $2246.37 , as of May 08, 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 08, 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 , MICHAEL D FAUST INDIVIDUALLY , in the amount of $2246.37 with continuing interest thereon at the rate of 6.000% per annum from May 08, 2009 plus costs. James a ro t,42524 WEL EINBERG & REIS CO., L.P.A. 436 S e th Avenue, Suite 1400 Pitt u gh, PA 15219 (412 4-7955 FAX 2-338-7130 07 363 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. - 7a(aS-3 6, 3 ®1GMCard 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 Oulck Look Account Summary Statement Date 3107108 Account number 5499 4410 0883 2138 New Balance $1,648.64 Total Credit Limit $0 Minimum Payment • $58.00 Total Cash Advance Limit $0 Payment Due Date 04/01108 Available Credit $0 Available Cash Advance $0 Current P ent Due • 580.00 S Days This Billing Cycle 29 Page 1 of 2 • See About Your Payment on reverse for an explanation of these amounts. $13.7 3 1 $40.53 1 51 1 1 RENUffin Average Daily Daily Periodic Nominal Annual Finance Cash Advance/ Annual Balance Rate Percarrtsae Raft Charne Transaction Fees Pervenbas Rate Purchases $1,478.05 0.08491% 30.99% $36.40 $0.00 30.990% Balance Transfer $173.77 0.08491% 30.99% $4.28 $0.00 30.990% Cash Advances $0.00 0.00000% 30.99% $0.00 $0.00 0.000% Previous Earnings $0.00 New Earnings Total $0.00 Remember, every time you make a purchase with Earnings Received $0.00 Anniversary Date 411105 your GM Card, you'll earn 5% In OM Card Earnings. Additional Earnings $0.00 Anniversary Y-T-D Earnings $0.00 You can save hundreds, even thousands on the Earnings Adjustments $0.00 Lifetime Earnings Redeemed $0.00 purchase or lease of your new GM car or truck Current Period Earnings $0.00 (excluding Saturn, Saab and HUMMER H1). Choose I from over 50 brandst I 1002105 D 07 STMT94 3 01-02 0025971CM GMC1 (Please detach and retum 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 5499 4410 0863 2138 Payment Due Date OW/08 New Balance $1,848.64 Current Payment Due $88.00 visit gmrdLwm Include account number on check to HSBC CARD SERVICES. Do not send cash. Send payment 7 to 10 e manageyotuACCOrad online days prior to Payment Due Date to ensure timely delivery. tSee reverse for more information Amount Enclosed MICHAEL D FAUST 4 ROCKLEDGE CT CARLISLE PA 17015-9190 IIII IIIII IIII1III if 'II'I11111111111111111'I111"1111'IIIIIIII' 0005800 0164864 5499441008632138 6 111111111111I1I11I111111I1II1If III IIIIIIIIII IIIIIIII HSBC CARD SERVICES PO BOX 37281 BALTIMORE MD 21297-3281 03107 03007 ACCOUNTSECURE PLUS 8004MO-1532 $13.73 10000002010000999978200 02128 02/28 PAYMENT - THANK YOU $61.00 CR 50228080900808OW123487 M?GMCard Customer Center Payment Address: 14800.947-1000 HSBC CARD SERVICE; P.O. BOX 80082 PO BOX 37281 Salinas, CA BALTIMORE MD 93912-0082 21297.3281 Visit us at www.gmcard.com MM IM • • f • w • f ? • • f • • • « Important Information f • • f • f f f f f f f • f f As a reminder, your APRs may immediately increase up to the Default APR if your payment is late or you exceed your credit limit as per your Cardmember Agreement and Disclosure Statement. Quick Look Account Summary Statement Date 310701 Account number 5498 4410 0883 2138 New Balance $1,848.64 Total Credit Limit $0 Minimum Payment* $58.00 Total Cash Advance Limit f0 Payment Due Date 04101/08 Available Credit $0 Available Cash Advance $0 Current Payment Due* :38.00 0 Days This Billing Cycle 29 Page 2of2 ' See About Your Payment on reverse for an explanation of these amounts. • f*•• f - • f f•• f•• Important Information * f f f• f f f f f f•. f• AS YOU REQUESTED, YOUR ACCOUNT IS CURRENTLY CLOSED. ANY OUTSTANDING BALANCE REMAINS PAYABLE IN ACCORDANCE WITH THE TERMS OF YOUR AGREEMENT. TO FIND OUT HOW TO REOPEN YOUR ACCOUNT, PLEASE CALL OUR CUSTOMER SERVICE NUMBER ABOVE. WE VALUE YOUR BUSINESS AND LOOK FORWARD TO SERVING YOU IN THE FUTURE. IF THIS ACCOUNT WAS USED FOR AUTOMATIC PAYMENTS, SUCH AS SUBSCRIPTIONS, MEMBERSHIP DUES OR INSURANCE POLICIES, PLEASE CONTACT THE APPROPRIATE COMPANY FOR CANCELLATION. """""CAROMEMBER NEWS***'****** If you want a vehicle that moves you - check out the all-new Pontiac G8. It seamlessly combines power, performance, and a" that compel the true driver to hit the road. A 6.01- V8 engine unleashes an impressive 361 hp and 385 lb-ft of torque, while a seductive body and low profile give it a performance attitude. Simply said, the G8 will truly set you apart. 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, CHARLES SHUMAN, 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. CHARLES SHUMAN 07265363 5499441008632138 $2285.37 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. *,M.50 Pp Ann CIE qoq aal9 R;rw cu?6108 Sheriffs Office of Cumberland County R Thomas Kline „tt, at umb.., Edward L Schorpp Sheri t4o Solicitor 4 Ronny R Anderson ' Jody S Smith Chief Deputy OFF CE OF 7k< ';?*ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/08/2009 12:25 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 8, 2009 at 1225 hours, he served a true copy of the within Complaint and Notice, upon the w?thin named defendant, to wit: Michael D. Faust, by making known unto himself personally, defendant at 4 Rockledge Court Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $32.50 SO ANSWERS, June 09, 2009 2009-3621 Q?*?lr ?f R THOMAS KLINE, SHERIFF Deputy Sheriff HSBC Bank Nevada v Michael Faust OF THE PROD-!?i, 2009 JUN 10 Pr`s 0 CUmsL i 4 1 r Fi ?I f PE