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Home My WebLink About09-4134 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: 09 - `ll3y 0'iV LTAir1n vs. COMPLAINT IN CIVIL ACTION BLAINE C GROVE 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 06676637 C N Pit BNT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No BLAINE C GROVE Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend agrainst 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: BLAINE C GROVE 38 APPALACHIAN TRAIL RD GARDNERS, PA 17324 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4093 . 4. Defendant made use of said credit card and has a current balance due of $12407.65 , as of June 02, 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 June 02, 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 , BLAINE C GROVE , INDIVIDUALLY , in the amount of $12407.65 with continuing interest thereon at the rate of 6.00001 per annum from June 02, 2009 plus costs. James C. Warmbrodt,42524 WELTMAN WEINBERG & REIS CO., L.P.A. 436 Se e th Avenue, Suite 1400 Pitts r h, PA 15219 (412) 4 4-7955 FAX: 4 -338-7130 0667 6 7 C N Pit BNT 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. TEAMSTERS PRIVILEGE BLAINE C GROVE - Valued Cardmember Since 2007 ACCOUNT SUMMARY ACCOUNT 5480-4200-3077-4093 NUMBER TOTAL CREDIT LIMIT $10,500 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE 01115/08 PAYMENT SUMMARY MINIMUM PAYMENT' $359.00 PAYMENT DUE DATE 02109108 OVERLIMIT AMOUNT $518.48 PAST DUE AMOUNT $358.00 CURRENT PAYMENT DUE' $807. To avoid additional Into endb ovarBmN lees, you must pay the Current Payment Due (Which includes the Minimum Payment and any Post Duo andobr Overlimlf Amounts). 'See About Your Payment on reverse for an Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $10,789.87 PAYMENTS/CREDITS - $0.00 PURCHASESIDEBMS + $70.00 FINANCE CHARGE + 78.81 NEW BALANCE = $11,018.48 TRANSACTION SUMMARY (For additional transaction detail go to www.unionpluseard.com) TRANS POST TRANSACTION REFERENCE AMOUNT DATE DATE. DESCRIPTION NUMBER CHARGES CREDITS 01/10 01110 LATE CHARGE ASSESSMENT 100000300000009 M 49830 $35.00 01110 01/10 OVERUMIT CHARGE ASSESSMENT 10000030000000999949020 $35.00 PROTECT YOUR CREDIT RATING. YOUR ACCOUNT IS PAST DUE. CALL 800-201-0071 TODAY TO MAKE YOUR PAYMENT. THANK YOU 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/ Annual PERCENTAGE Balance Rate Billing Rate Transaction Fees Percentage RATE Cycle Raft PURCHASES $9,725.32 0.05477% 30 $159.80 $0.00 19.99% 19.980% CASH ADVANCES $1,144.53 0.05477% 30 $18.81 $0.00 19.99% 19.990% IMPORTANT INFORMATION Your AooountSecure® protection has been canceled per your request. Please call us at 1-800-690-1532 with any questions. V MAIL PAYMENTS TO: UNION PLUS CREDIT CARD PO BOX 17051 BALTIMORE MD 21297-1051 2 QUESTIONS? 24-HOUR CUSTOMER SERVICE 148004Y22-2580 OUTSIDE USA, COLLECT: 1-702.243.1575 TOO HEARING IMPAIRED: 1-800855-9392 2 Manage your account online at: www unionpiuscard com ® MAIL INQUIRIES TO: UNION PLUS CREDIT CARD PO BOX 80027 SALINAS CA 93912-0027 UPI 010232 5 15 0000003000 0 STMT57 D 2 00007582 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Writs Your Account Number On Your Check Account Number 5480-4200-3077-4093 New Below@ $11,018.48 Minimum Payment $359.0E Payment Due Date 02KWW Current Payment Due SM7.41 nclude account number on check to UNION PLUS CREDIT CARD. Do not send cash. Senn payment 7 days prior to Payment Due Date to ensure timely delivery. To avoid additional late and/or overlimit fees, pay the Current Payment Due. Amount Enclosed BLAINE C GROVE 36 APPALACHIAN TRAIL RD 0 GARDNERS PA 17324-9052 UNION PLUS CREDIT CARD lurlllnrlnllurlrlrlullrlnllnnlrlnrlrlnllrlnlullnl PO BOX 17051 BALTIMORE DID 21297-1051 Inlrl1111111111111111111111III1IIIIlruII1II1rrllrrlrll exHIBIT 548042003077409300080748011018482 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. U ytut kk-A- 01)0 VALERIE DEMARAIS 06676637 5480420030774093 $12407.65 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Q OF 7 R EC - T-f; ;E _ !H f{{ Y 209 JUN 17 PrI: 50 Col r r (f * IS. SG Po A'M4 Cw-v 4d sal o RT*" 2,2(0 84 1 Sheriffs Office of Cumberland County R Thomas Kline of c li lub" Edward L Schorpp SheriSolicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF T,,E SHERIFF Civil Process Sergeant HSBC Bank Nevada, N.A. Case Number vs. 2009-4134 Elaine C. Grove SHERIFF'S RETURN OF SERVICE 06/18/2009 07:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 18, 2009 at 1950 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Elaine C. Grove, by making known unto himself personally Blaine C. Grave, defendant at 38 Appalachian Trail Road Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.90 June 19, 2009 SO ANSWERS, 0001104aeo-00* -0-0 C, 40 - - - %. 14? R THOMAS KLINE, SHERIFF Dep y Sheriff r- 7 y, JASON M. RETTIG, PABN 200948 418 WILLARD RD HATBORO, PA 19040 (267) 879-9054 Attorney for Defendant BLAINE GROVE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC BANK NEVADA N.A. vs. BLAINE GROVE To the Prothonotary: Plaintiff, Defendant. y/3`/ Case No.: 09-13 Civil Term CIVIL ACTION - LAW PRAECIPE TO ENTER APPEARANCE Please enter my appearance for BLAINE GROVE, defendant, in the above titled case. DATED: June 22, 2009 JASO . RETTIG., PABN 200948 418 WILLARD RD HATBORO, PA 19040 (267) 879-9054 Attorney for Defendant BLAINE GROVE F'i kd 4fbd 0/ A pro4h no f-a13 aaoi aul-u oum d?,w p rn a : O 1'ouny P,4 * wr/ JASON M. RETTIG, PABN 200948 418 WILLARD RD HATBORO, PA 19040 (267) 879-9054 Attorney for Defendant BLAINE GROVE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC BANK NEVADA N.A., Case No.: 09-4134 - Civil Term Plaintiff, VS. BLAINE GROVE CIVIL ACTION - LAW Defendant. ANSWER AND NOW, this 22°d day of June, 2009, comes the defendant BLAINE GROVE, by and through his attorney Jason Rettig, who admits, denies, and alleges as follows: 1. Defendant, BLAINE GROVE, admits to the facts contained in paragraph one, that the Plaintiff, HSBC BANK NEVADA. is a corporation with offices at 1111 TOWN CENTER DR. LAS VEGAS, NV 89193. 2. Defendant, BLAINE GROVE, admits to the facts contained in paragraph two, that he is an adult individual residing at 38 Appalachian Trail Rd, Gardners, PA, 17324. 3. Defendant, BLAINE GROVE, admits facts alleged in paragraph three, that he applied for and received a credit card bearing the account number ending in 4093. 4. Defendant, BLAINE GROVE, admits facts alleged in paragraph four, that he made use of said credit card but does not have sufficient information to admit or deny a current balance due of $12407.65, as of June 02, 2009 5. Defendant, BLAINE GROVE, admits facts alleged in paragraph five that he is in default by failing to make monthly payments when due. 6. Defendant, BLAINE GROVE, admits facts alleged in paragraph six that the Plaintiff is entitled to the addition of interest at the rate of 6% per annum on the unpaid balance due. 7. Defendant, BLAINE GROVE, admits facts alleged in paragraph seven, that he has failed to pay the balance due to the Plaintiff. WHEREFORE, the defendant respectfully requests this honorable court enter judgment in favor of the defendant and that Complainant take nothing by said Complaint; that Defendant recover its cost of action herein; and such other relief as the Court may deem proper. Respectfully submitted, DATED: June 22, 2009 (?' r- " - JAS M. RETTIG, PABN 200948 418 WILLARD RD HATBORO, PA 19040 (267) 879-9054 Attorney for Defendant BLAINE GROVE VERIFICATION I, Defendant, BLAINE GROVE, verify that the facts set forth in this answer are true and correct to the best of my knowledge, information, and belief DATED: Defendant BLAINE GROVE FILED--t i;" CF TI-E F 1. 2009 JUL -6 PH 2: 5-4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA NA Plaintiff vs. BLAINE C GROVE Defendant. Case No.: 09-4134 CIVIL TERM TYPE OF PLEADING ~_ ~_ PRAECIPE FOR JUDGMENT ~."' ~~~ PER ORDER OF COURT : ~~' `~' ~ -; °~-' FILED ON BEHALF OF: c.~ ? ~~,^~ Plaintiff - - _ '.~ ;~ - ~.. ',_ , r w, ~ ~~ ~~ COUNSEL OF RECORD OF THIS PARTY: Benjamin R Bibler, Esquire PA I.D. #93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No. 6676637 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA NA Plaintiff vs. BLAINE C GROVE Defendant. TO THE PROTHONOTARY: Case No.: 09-4134 CIVIL TERM PRAECIPE FOR JUDGMENT Pursuant to Pa.R.C.P. 237, I certify that a copy of this Praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. In light of the Court Order granting Judgment in favor of Plaintiff on November 30 2009, kindly enter Judgment against the Defendants, Blaine Grove, in the amount of Q'_ _'_? computed as follows: Iol,No'l.(c5 Amount Awarded per Order: $12,407.65 / i'~°`' Interest from 6/2/09 through 4/1/10 at the legal rate of 6.00% per annum: b -A9-- ~. Per ~ ~~j3~ TOTAL: $43;82`.rfr5~ Attached is a copy of the Court Order in favor of Plaintiff for Judgment. WELTMAN, W~IBERG & REIS, CO., L.P.A. By: Benjafn n `l'er, Esquire PA LD #9 5 8 WEL , WEINBERG & REIS CO., L.P.A. 1400 Ko ers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 Plaintiff s address is: Weltman, Weinberg & Reis, 1400 Koppers Building, 436 7`~ Avenue, Pittsburgh, PA 15219 And Defendant's address is: 38 Appalachian Trail Rd Gardners Pa 17324 ~ IMF. oo P ~1 A7~( Gc,~r $ga'1tal ~"~ a ~d 3s3 fJakee. ~.~k~O1 WWR No. 6676637 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA NA Plaintiff Case No.: 09-4134 CIVIL TERM vs. BLAINE C GROVE Defendant. NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendants ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $1a,4~7. V5 plus interest at 6% per annum, 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 (xx) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award ( ) By Consent Prothonotary Jason Rettig,Esquire 418 Willard Rd Hatboro Pa 19040 PROTHONOTARY (OR D PUTY) WWR No. 6676637 b' [~~u:~ ~ ~~_ ~ ~~~ L' _ ~ ~ ~ ~ v~ ~ ~~ ~~ " ~ i 4 ' '. 'U- y, ~ -- 1 ~ V N ~ n. ~ ~ ~ ~m ~ ~ ~. m ~ ~ ~ m m w m .~ ~, o~ o ~ ~ W = ~ ~ ~ ~ 3 ~ ~ ~ rri _ ~ ~ Uc - ~ ~ ~ m Q ~ ~ .r. ~ ~ ~ x~ I5 ~ r.~ _ ~ ~ ~ Q ~ N o N ~ ~ ~ m T rr c= tit ~ .-~ ~. ~ ~ ^-' _ T ~~ m ~ ~ 3 ~ ~ !~ ~ v C~ ~ ~ ~ m ~ O ~ ~ ~ rn ~ a w ~ ~ ~ ~ .. .. . ......... ~ rr c o ~ rn ~ ~' ~ mrn -~ rn r?o c °-s ~ ~ C~11 ~ ~ 7.11 C~ ~ ~ , ~ ~' C ~ o ~ L ~ rn c3 O ~ i rr• , m ~: ~ ~ ~ O --, x ~ w w m ~ ~ ~ ~ ~ ~ -i ~ s ~: ~ ~ w ' ~ ~ ? ~~ ~ 3 CD ~ ~ ~ ~ ~ ~ . ~, o c a ~ ~ .~r~ ~ ~ ~ r ~ C ~ rn ]~ p J ~~ ~ ~ ~~~~6~~~ ~rr-~ WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) I.D. No.86469 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Far: 41'_11.4334.7959 File =' 66766,' HSBC Br1? K NEVADA, N.A CUMBERLAND County Court of Common Pleas vs. BLAINE C GROVE rn100 c.., rn r- W -<a cn = c3 t-: -? --qcD ? -r3 z? co -r; Qr, c -= --?'r" .. --i NO. 09-4134 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the Court and mark the cost paid. WELTMAN, EIN E CO., L.P.A. By Sarah E. Ehasz, Esquire Attorney for Plaintiff Sworn to and subsc ibed Before me the ITMday of May, 2011 OTARY PU ,IC F;*V"ViC*MM*CM. AUAIWW COIW" iM #apirM JM M, 013 3 Gtt4+!tB(ZPd aKI 9,*_at,o537