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Home My WebLink About09-7876 t- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HOUSEHOLD BANK (SB), N.A. Plaintiff No: CA _ 781(o 011V4 Ier'ht VS. COMPLAINT IN CIVIL ACTION KATHY L WATERS 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 07262007 C N Pit KMJ P. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HOUSEHOLD BANK (SB), N.A. Plaintiff VS. Civil Action No KATHY L WATERS 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 ages, 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 w COMPLAINT 1. Plaintiff, HOUSEHOLD BANK (SB), 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: KATHY L WATERS 1923 WALNUT ST CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0826 . 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 $3007.97 , 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 , KATHY L WATERS , individually , in the amount of $3007.97 with continuing interest thereon at the rate of 6.000% per annum from date of judgment plus costs. fames c WELTMAN 436 Se Pittsb (412)/4 FAX: 41 072 02d •.wi.• iVK{.., ZG.JGZ WEINBERG & REIS CO., L.P.A. th Avenue, Suite 1400 h, PA 15219 -7955 -338-7130 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. HOUSEHOLD BANK MASTERCARD Sm KATHY L WATERS ACCOUNT SUMMARY ACCOUNT 5488-9750-0872-0826 NUMBER CASH CREDIT LIMIT t $2,500 CASH LIMIT AVAILABLE $0 TOTAL CREDIT LIMIT $2,500 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE 12/28!08 PAYMENT SUMMARY MINIMUM PAYMENT' $105.00 PAYMENT DUE DATE 01122/09 OVERLIMIT AMOUNT $507.97 PAST DUE AMOUNT $614.00 CURRENT PAYMENT DUE' $719. To avoid additional late and br overlimit tees, you must pay the Current Payment Due (which includes the Minimum Payment and any Past Due and or Overlimit Amounts). *See About Your Pavment on reverse for an t Cash Credit Limit is a portion of the Total Credit Limit r , Mr?«; Gud Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $2,933.59 PAYMENTS/CREDITS - $0.00 PURCHASES/DEBITS + $0.00 LATE PAYMENT CHARGE + $0.00 MISC. FINANCE CHARGE + $OAo FINANCE CHARGE + $74,38 NEW BALANCE _ $3,007.97 IMPORTANT INFORMATION Your account has been laced with a collection agency. Please contact them directly, or call us at 1-800-388-5333. S I. i? ? MAIL PAYMENTS TO: QUESTIONS? 2 MAIL INQUIRIES TO: HSBC CARD SERVICES 24-HOUR AUTOMATED ACCOUNT INFORMATION HSBC CARD SERVICES PO BOX 17051 ENGLISH 1-503-293-4037 PO BOX 80084 BALTIMORE MD 21297-1051 ESPANOL 1-503-293.4834 SALINAS CA 93912.0084 9 Manage your account online at: www.householdbank.com Account Number 5488-9750-0872-082E Jew Balance $3,007.97 Minimum Payment $105.0( payment Due Date 01n2ro9 Current Payment Due $719.91 iclude account number on check to HSBC CARD SERVICES. Do not send cash. Sen 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 #BWNHYTS #333008720828# KATHY L WATERS V 1923 WALNUT ST CAMP HILL PA 17011-3854 rllrllll?l?lllln?rllrl???llull?l?l?ln??lr?i?lln?lllrllylllll 110246 51 27 0000000508 G STMM8 D H 00018272 HDS1 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check Il?rlllillllln?i?r?h?n??u?rll?lulr??lr?llll'?I111'llil'?111' HSBC CARD SERVICES PO BOX 17051 BALTIMORE !ID 21297-1051 548897500872082600071900003007976 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. ' ?e,?'Ytc?uiR,4 VALERIE DEMARAIS 5488975008720826 $3007.97 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 0 2G09 NOV 12 PH 2: 51 *178. so p t. " CV-* 4335551 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ??,?rttr of ?u,n6r?•Cr?G OF Fir E ,F FFE -?-ER1FF 2009 NOV 19 PM 12: 58 CLNBL..?•1u (DuNi PENNSYiyWX 411 Household Bank (SB), NA Case Number vs. 2009-7876 Kathy L. Waters SHERIFF'S RETURN OF SERVICE 11/18/2009 08:55 AM - Jody Smith, Sergeant, who being duly sworn according to law, states that on November 18, 2009 at 0855 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kathy L. Waters, by making known unto herself personally, at The Cumberland County Sheriffs Office 1 Courthouse Square Room 303 Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 November 18, 2009 SO ANSWERS, 44* eooooa? R THOMAS KLINE, SHERIFF W ? ? YX ?' I - DDeputAy Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY RLEp Q r OF THE PROTHONCTARY Icy CountySu'te ShPni(. ieleosott Inc. WELTMAN, WEINBERG & REIS CO., L.P.A. ~~ BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) LD. No.86469 ~ 436 Seventh Avenue, Suite 1400 ~~ Pittsburgh, PA 15219 7~ib- 3 Phone: 412.434.7955 ~'~ ~` w Fax: 412.434.7959 ~ ,~ File # 7262007 -~ t''v HOUSEHOLD BANK (SB), N.A. Plaintiff CUMBERLAND County Court of Common Pleas vs. KATHY L WATERS Defendant(s) NO. 09-7876 CNILTERM 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, WEINBERG & IS C .P.A. By Sarah E. Ehasz, Esquire Attorney for Plaintiff ~ C~~a~~ KATHY ~, WATERS 193 WALNUT ST CAMP H1Y,L, PA 17011