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Home My WebLink About09-7874IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: ?Q - 7874 0-,wV L -lion- VS. COMPLAINT IN CIVIL ACTION SHAHJEHAN S MAJEED 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 07083037 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 SHAHJEHAN S MAJEED 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: SHAHJEHAN S MAJEED 307 MERCURY DR MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8469 . A copy of the Plaintiff's Statement is attached hereto, marked as Exhibit "1" and made a part hereof. 4. Defendant made use of said credit card and has a current balance due of $4804.75 , as of October 28, 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. 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 , SHAHJEHAN S MAJEED , individually , in the amount of $4804.75 with continuing interest thereon at the rate of 6.0001 per annum from date of judgment plus costs. James C. Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 S e th Avenue, Suite 1400 Pitts ur h, PA 15219 (412 4X4--7955 FAX: 4 2-338-7130 070 3 37 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. r MASTERCARD CREDIT CARD STATEMENT ACCOUNT SUMMARY ACCOUNT 5215-3188-3 NUMBER TOTAL CREDIT LIMIT TOTAL CREDIT LIMIT AVAILABLE STATEMENT DATE $9,000 01/20/08 PAYMENT SUMMARY MINIMUM PAYMENT' $202.00 PAYMENT DUE DATE 02/14108 PAST DUE AMOUNT $261.00 CURRENT PAYMENT DUE* $463.00 To avoid an additional late fee, you must pay the Current Payment Due (which includes the Minimum Payment plus any Past Due Amount). * See About Your Payment on reverse for an explanation of these amounts. Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $3,670.71 PAYMENTS/CREDrrS $0.00 PURCHASES/DEBITS + $212.42 FINANCE CHARGE + $104.54 NEW BALANCE _ $3,987.67 TRANSACTION SUMMARY (For additional transaction detail go to www.hsbccreditcard.com) TRANS POST TRANSACTION REFERENCE AMOUNT DATE DATE DESCRIPTION NUMBER CHARGES CREDITS 12/21 12/24 SHOPPERS FOOD & #7564 BALTIMORE MD MT073580098000010461957 $29.07 12/21 12124 VALUE VILLAGE #116 BROOKLYN PARK MD MT073580096000010525901 $21.37 01/04 01/05 Fraud Balance Transfer 4847.0880058 (01-01)000 $104.85 01/04 01105 INTEREST DEBIT ADJUSTMENT 09999999980104000920455 $18.33 01/14 01/14 LATE CHARGE ASSESSMENT 10000004070000899381310 $39.00 IF YOU ARE UNABLE TO SEND YOUR PAYMENT TODAY, PLEASE CALL 800-724-4967 TO DISCUSS A REPAYMENT 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 $3,847.24 0.08785% 31 $104.54 $0.00 31.99% 31.990% CASH ADVANCES $0.00 0.00000% 31 $0.00 $0.00 31.99% 31.990% v-' MAIL PAYMENTS TO: HSBC CARD SERVICES PO BOX 17332 BALTIMORE MD 21297-1332 9 QUESTIONS? 24-HOUR CUSTOMER SERVICE 148t18-385-8918 OUTSIDE USA, COLLECT: 1-716-841-7141 TDD HEARING IMPAIRED: 1-800.655.9392 2 Manage your account online at: www hsbccreditcard corn ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 80026 SALINAS CA 93912-0028 1402015 A 20 0000000407 G STMTe9 D A 00004996 IDF01 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check Account Number 5215-3188-3934-8469 4ew Balance $3,987.67 Minimum Payment $202.0( payment Due Date 02/14/08 Current Payment Due $463.a iclude account number on check to HSBC CARD SERVICES. Do not send cash. Send Davmer 7 days prior to Payment Due Date to ensure timely delivery. To avoid an additional late fee, pay the Current Payment Due. Amount Enclosed SHAHJEHAN S MAJEED 1855 NILLIAMSBRIDt3E RD APT 2 BRONX NY 10461-6205 11111111111111111111111 1IIIIIIIIIIIIIIIIIIIIIIIIII III II III II II HSBC CARD SERVICES PO BOX 17332 BALTIMORE I4D 21297-1332 521531883934846900046300003987679 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 corroct to the best of his/her knowledge, information and belief. Ink" "Y&M-0-.4 VALERIE DEMARAIS 5215318839348469 $4804.75 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 0 FILED " f ic nc. T? ? oc ,- T,?LgV 2x03 N 0 y 12 4 y r. 4q$. 50 po A-my C,k-* ?4 5b' 8 ? a.33?1q t ~ ~ '"~ ~ ~1 li U ; 1 i~J• d'v ~rh:la:sy i~ ,,,.,: ~ di _ i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. SHAHJEHAN S MAJEED Defendant(s) No. 09-7874 CIVIC.TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFII.,E FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA 1.D. #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#7083037 JAM ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No. 09-7874 CNILTERM SHAHJEHAN S MAJEED Defendant(s) PRAECII'E TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF Cumberland COUNTY: SIR Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. CO., L.P Lyndsay wlai sq ire PA LD. #20S 20 WELTMAN~ INBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 SWORN TO AND SUBSCRIBED before me this ~_ day of , 2010 ~~ ,~~ TARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila G. Bevan, Notary Publk Roar Twp., Afiepl»ny County My Commblgon Explros Nov. 18, ZO30 Member. Pennsvlvanla Assodatlon ~ Notaries