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Home My WebLink About09-3622T % IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: (4- 3c"aa Q'-?,Te M vs. MICHAEL S COLEMAN 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 07281422 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 S COLEMAN 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 T 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 S COLEMAN 20 HEMLOCK DR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2889 . 4. Defendant made use of said credit card and has a current balance due of $3924.54 , 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 S COLEMAN , INDIVIDUALLY , in the amount of $3924.54 with continuing interest thereon at the rate of 6.000% per annum from May 08, 2009 plus costs. JameIsbrgh, Wa ro t,42524 WELT WEINBERG & REIS CO., L.P.A. 436 nth Avenue, Suite 1400 Pit PA 15219 (4 4-7955 F 412-338-7130 0 1422 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. HSBC m PLATINUM MASTERCARD STATEMENT ACCOUNT SUMMARY ACCOUNT 5491.0988-1898-2889 NUMBER TOTAL CREDIT LIMIT $3,250 TOTAL CREDIT LIMIT $281 AVAILABLE CASH CREDIT LIMIT t $7,825 CASH LIMIT AVAILABLE $281 STATEMENT DATE 05101108 PAYMENT SUMMARY MINIMUM PAYMENT' $30.00 PAYMENT DUE DATE 05121108 CURRENT PAYMENT DUE' $30.00 See About Your Payment on reverse for an explanation of these amounts. t Cash Credit Limit is a portion of the Total Credit Limit Previous Points 0 Points 0 Total Points 0 Page 1 of 2 BALANCE SUMMARY PREVIOUS BALANCE $0.00 PAYMENTS/CREDITS $0.00 PURCHASESIDEBITS + $2,901.00 FINANCE CHARGE + $87.03 NEW BALANCE = $2,988.03 TRANSACTION SUMMARY (For additional transaction detail go to www.habecreditcard.com) TRANS POST TRANSACTION REFERENCE AMOUNT DATE DATE DESCRIPTION NUMBER CHARGES CREDITS 04117 04117 031710 BALANCE TRANSFER CHECK 09999998980417014570288 $1,901.00 04117 04117 031709 BALANCE TRANSFER CHECK 0891iD889980417014570276 $1,000.00 04117 04117 CASH FEE FINANCE CHARGE 10000004070000999358480 $57.03 04117 04/17 CASH FEE FINANCE CHARGE 10000004070000999358470 $30.00 ? MAIL PAYMENTS TO: HSOC CARD SERVICES PO BOX 17332 BALTIMORE MD 21297-1332 IN QUESTIONS? 24-HOUR CUSTOMER SERVICE 14888-385-8910 OUTSIDE USA, COLLECT: 1.710.841.7141 TOO HEARING IMPAIRED: 14M00855-9392 ® Manage your a=unt online at: www hsbccreditcard com ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 80028 SAUNAS CA 93912.0028 2Q 140801 5 01 0000000407 G STMT89 D J 00014072 IDF01 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check HSBC m Account Number 5491-0986-1896-2884 Payment Due Date 05121101 Now Balance $2,988.03 Current Payment Due $30.01 wkide account number on check not send cos . pa comet 7 to 10 days prior to the Payment Due Date to ensure timely delivery. Amount Enclosed MICHAEL S COLEMAN 20 HEMIACM: DR MECHAMICSWMG PA 17055-4744 HSBC CARD SERVICES loll lllnrlilgo 1111111111lrrllnrlr111111rrin1111l,nur111 PO BOX 17332 BALTIMORE MD 21297-1332 549109861896288900003000002988035 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, 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 07281422 5491098618962889 $3924.54 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 0 ". so flb ATW cr,''m 4o4a3ao Sheriffs Office of Cumberland County R Thomas Kline ?,i?? ofua?bp Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE' F'"r s"-P'FF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/10/2009 08:10 AM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2009 at 0810 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael S. Coleman, by making known unto himself personally, defendant at 1 Courthouse Square, Room 303 Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 June 11, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy S eri 2009-3622 HSBC Bank Nevada V Michael S. Coleman C? r_- C= C= -r