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Home My WebLink About09-6778IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. KAREN L TAYLOR Defendant No : b 078 (2! u ? L -7i/z-rvl 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 07309405 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 KAREN L TAYLOR 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: KAREN L TAYLOR 2312 NEW YORK AVE CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8656 . 4. Defendant made use of said credit card and has a current balance due of $2237.51 , as of May 22, 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 22, 2009 . A copy of Plaintiff's statement is attached hereto, marked as Exhibit 11111 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 , KAREN L TAYLOR , individually , in the amount of $2237.51 with continuing interest thereon at the rate of 6.000% per annum from May 22, 2009 plus costs. fames u. WELTMAN, 436 SevE Pittsbuz (412) 4 FAX: 4 073094 E This law firm is a debt collector attempt our client and any information obtained w rmbrodt,42524 INBERG & REIS CO., L.P.A. Avenue, Suite 1400 PA 15219 955 8-7130 N Pit KMJ to collect this debt for be used for that purpose. ..HSBC GOLD MASTERCARD KAREN L TAYLOR ACCOUNT SUMMARY ACCOUNT 5408.0100-3406-8656 NUMBER TOTAL CREDIT LIMIT $2,000 TOTAL CREDIT LIMIT $0 AVAILABLE CASH CREDIT LIMIT t $500 CASH LIMIT AVAILABLE $0 STATEMENT DATE 02/12109 PAYMENT SUMMARY MINIMUM PAYMENT' $66.00 PAYMENT DUE DATE 03/09/09 OVERLIMIT AMOUNT $126.27 PAST DUE AMOUNT $220.00 CURRENT PAYMENT DUE' $266. To avoid additional late andlor overlimit fees, you must pay the Current Payment Due (which includes the Minimum Payment and any Past Due and/or Overlimit Amounts). 'See About Your Payment on reverse for an -1...0- of 16unn -...fa t Cash Credit Limit is a portion of the Total Credit Limit Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $2,047.20 PAYMENTS/CREDITS $0.00 PURCHASES/DEBITS + $35.00 FINANCE CHARGE + 44.07 NEW BALANCE _ $2,126.27 TRANSACTION SUMMARY (For additional transaction detail go to www.hsbecreditcard.com) TRANS POST TRANSACTION REFERENCE AMOUNT DATE DATE DESCRIPTION NUMBER CHARGES CREDITS 02/06 02106 OVERLIMIT CHARGE ASSESSMENT 10000001060000999776940 $35.00 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 Rate PURCHASES $2,076.29 0.06847%(v) 31 $44.07 $0.00 24.99%(v) 24.990% CASH ADVANCES $0.00 0.06847%(v) 31 $0.00 $0.00 24.99%(v) 24.990% (v) indicates variable rate ? MAIL PAYMENTS TO: HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 2 QUESTIONS? 24-HOUR CUSTOMER SERVICE ENGLISH/ESPANOL 1-800-477-6000 OUTSIDE USA, COLLECT: 1-757-523-3880 TOD HEARING IMPAIRED: 1.800-395-9020 Q Manage your account online at: www hsbccreditcard corn ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 81622 SALINAS CA 93912.1622 EXCPT 090255 5 N 12 0000000106 G STMTXO 2 E 00004530 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check HSBC ID Account Number 5408-0100-3406-865( 4ew Balance $2,126.27 Minimum Payment $66.0( Dayment Due Date 03/09109 Current Payment Due $2860 Include account number on check to HSBC CARD SERVICES. Do not send cash. Send payment 7 to 10 days prior to Payment Due Date to ensure timely delivery. To ?wd?¢d11014 p? ?`•.(/ late and/or overlimit fees, pay the Current Payment Due. ?,Y` miIT Amount Enclosed KAREN L TAYLOR 2312 NEW YORK AVE CAMP HILL PA 17011-7315 111-II I-1-.1111111111111"1-111'11 '1'11111-111-I1-1-I-IIIIIIIIIIII tltlitil??ttll?ll?i?illl??l?llriirr?r?r??t?lilitltil?li?rttirii HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 540801003406865600028600002126274 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 07309405 5408010034068656 $2284.91 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. nLED-rrjFRCE OF TI-'r, n; - }T 7a 0TAf?Y 20D OCT 12 Ark !D: 56 X75. so -?0" Sheriffs Office of Cumberland County R Thomas Kline FILED-t''`Z Sheriff CF THl ?,???;?tiu of 4Ai1ubrrf??A Ronny R Anderson 2009 OCT IS Ali S- 10 Chief Deputy T - ; Jody S Smith N T Y Civil Process Sergeant Edward L Schorpp Solicitor HSBC Bank Nevada, NA vs. Case Number Karen L. Taylor 2009-6778 SHERIFF'S RETURN OF SERVICE 10/13/2009 08:10 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on October 13, 2009 at 2010 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Karen L. Taylor, by making known unto herself personally, at 2312 New York Avenue Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, October 14, 2009 R THOMAS KLINE, SHERIFF putt' Sheriff In IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. KAREN L TAYLOR Defendant(s) No. 09-6778 CIVILTERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7309405 SMP IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A vs. Civil Action No. 09-6778 CIVILTERM KAREN L TAYLOR PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO REFILE TO THE PROTHONOTARY OF COUNTY: ti Plaintiff Defendant(s) Settle, Discontinue and End With Prejudice to Refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. Wa PA I.D. #425 WELTMAN 1400 Kopp 436 Seven Esquire Iding Pittsburg V, A 15219 (412)43 - 955 WWR# 09405 Sworn to and subscribed Before me the 0'2 Day of NOV apOq OTAR UBLIC i'ar?al Seai z ne a ur;, otary Public City Ot c`itt V, 4,.,^v C^ mty My Commission Expires Nov. 15, 2010 nber, Pennsylvania Association of Notnm-s & REIS CO., L.P.A ,r of TH FP-0 7?(7' OTARY 2009 NOV 20 P 3: 38