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Home My WebLink About09-7875I/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: Terw vs. COMPLAINT IN CIVIL ACTION AMY L POKLAR 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 07230065 C N Pit KMJ r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. Civil Action No AMY L POKLAR 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: AMY L POKLAR 171 SHIPPENSBURG MOBILE SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4573 . A copy of the Plaintiff's Statement is attached hereto, marked as Exhibit 111" and made a part hereof. 4. Defendant made use of said credit card and has a current balance due of $3151.36 , 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. I/ Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , AMY L POKLAR , individually , in the amount of $3151.36 with continuing interest thereon at the rate of 6.0001 per annum from date of judgment plus costs. James C. a ro t,42524 WELTMAN EINBERG & REIS CO., L.P.A. 436 Se /5C; h Avenue, Suite 1400 Pitts , PA 15219 (412) 7955 FAX: 4 38-7130 0723 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 PLATINUM MASTERCARD AMY L POKLAR ACCOUNT SUMMARY ACCOUNT 5491-0700.18904573 NUMBER TOTAL CREDIT LIMIT $2,500 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE 10/13/08 PAYMENT SUMMARY MINIMUM PAYMENT' $108.00 PAYMENT DUE DATE 11!07!08 OVERLIMIT AMOUNT $851.38 PAST DUE AMOUNT $892.00 CURRENT PAYMENT DUE' $798. To avoid additional late and or overlimit fees, you must pay the Current Payment Due (which includes the Minimum Payment and any Pest Due and or Ovedimit Amounts). 'See About Your Payment on reverse for an awnlanatinn of thmQ AmM inic M.*-?i•; t vr1 Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $3,077.18 PAYMENTSICREDITS $0.00 PURCHASES/DEBITS + $0.00 FINANCE CHARGE + 74.18 NEW BALANCE = $3,151.38 FINANCE CHARGE CALCULATION This Is a grace account. Grace period information on back. Balance Subject Daily Days Finance Charges NOMINAL To Finance Charge Periodic in Billing At Periodic ANNUAL Average Daily Rate Cycle Rate Rate PERCENTAGE Balance RATE PURCHASES $3,112.84 0.08217% 29 $74.18 29.99% CASH ADVANCES $0.00 0.08217% 29 $0.00 29.99% ANNUAL PERCENTAGE RATE" 29.990%. "May be higher then Nominal Percentage Rate if statement includes misc. finance charges. -1 MAIL PAYMENTS TO: 2 QUESTIONS? ® MAIL INQUIRIES TO: HSBC CARD SERVICES 24-HOUR CUSTOMER SERVICE HSBC CARD SERVICES PO BOX 17051 1-800-462-2016 PO BOX 81822 BALTIMORE MD 21297-1051 OUTSIDE USA, COLLECT: 1-757-523-38W SALINAS CA 93912-1822 MD HEARING IMPAIRED: 1400.395.9020 2 Manage your account online at: www.hsbccreditcard.com 080752 51 13 0000000400 G STMT38 D C 00001385 HMP1 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check HSBC m %ccount Number 5491-0700-1690-457: Jew Balance $3,151.38 Minimum Payment $108.0 'ayment Due Date 11/07/m Current Payment Due $79e.0 iclude account number on check to HSBC CARD SERVICES. Do not send cash. Son payment 7 to 10 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 ANY L POKLAR 125 E BROOKHAVEN RD BROOKHAVEN PA 19015-2309 rllih?rnrrin?lillilHirelrril?ili?iri??rirhrlimirilutiu nll??llilihll?r?irihnnrr?tlrllrl??uili?l"yln?lltnnil HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 549107001690457300079800003151361 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 5491070016904573 $3151.36 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. *zv ^..C THE ,,T. A 25A NOV 12 PI'S 2: 5 ! Ci)v _ l *79.5D PD AMY ? a??ao ';rl -U 'I ILL i T 0N0TArt WELTMAN, WEINBERG & REIS CO., L.P.A. () ; p, BY: Sarah I ,. Ehasz, Esquire Attorney for fl., ,miff s r I.D. No.86469 `?`Ut "IBERLAND COUNT'S 436 Seventh Avenue, Suite 1400 !"E MN S Y LVA N I A Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7230065 HSBC BANK NEVADA, N.A Plaintiff CUMBER-AND County Court of Common Pleas vs. NO. 09-7875 CIVILTERM AN,'e L POKLAR Dr.fendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROT; IONOTARY: Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the Cour(. and czjark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By_ -- S .rah E. F?hasz, Esquire / Attorney (or I ` liW iff Sworn to anL, ?u wribed Before me the _?_ day of LA19--v, 2011 f NOTARY 1'UE11C COMMONMkTM Of PFlUVSMANIA Noto seal Sheila G. Bevan, Notwy "k RON Twp., M@Ot W County MY COnlntli M B0 0 NOV. 15, 2014 MEMBER, PENNSY VMM ASSOCIATION OF NOTARIES at*k ILg. 00 pa 0I 0 10USinII Q4 6-7 S%