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Home My WebLink About09-787941 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: CR -'7819 \AMI-C,rM vs JEFFREY L HOOVER COMPLAINT IN CIVIL ACTION 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 06866190 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 JEFFREY L HOOVER 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: JEFFREY L HOOVER 961 GREENSPRING RD NEWVILLE, PA 17241 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2833 . 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 $2399.32 , as of October 12, 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 , JEFFREY L HOOVER , individually , in the amount of $2399.32 with continuing interest thereon at the rate of 6.000. per annum from date of judgment plus costs. James C. Warmbroclt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Se e th Avenue, Suite 1400 Pitts r h, PA 15219 (412) 43 -7955 FAX: 41 -338-7130 0686 1 0 C N Pit KMJ This law firm is a debt collector attemlWing to collect this debt for our client and any information obtained will be used for that purpose. MASTERCARD CREDIT CARD STATEMENT ACCOUNT SUMMARY ACCOUNT 5215-3188.0379.: NUMBER TOTAL CREDIT LIMIT $1 TOTAL CREDIT LIMIT AVAILABLE STATEMENT DATE Previous Earnings $7.46 Earnings $0.00 Total Earnings $7.46 PAYMENT SUMMARY MINIMUM PAYMENT' $112.00 PAYMENT DUE DATE 03J08108 OVERLIMIT AMOUNT $540.81 PAST DUE AMOUNT $444.00 CURRENT PAYMENT DUE• $813.81 To avoid additional late and l r over imit fees, you must pay the Current Payment Due (which includes the Minimum Payment and any Past Due andhx Overhmif Amounts). *See About Your Payment on reverse for an -J-fl- 'd th- -.f. Page 1 of 2 BALANCE SUMMARY PREVIOUS BALANCE $1,933.12 PAYMENTS/CREDITS $0.00 PURCHASES/DEBITS + $56.00 FINANCE CHARGE + $51.89 NEW BALANCE = $2,040.81 This tax season, use your HSBC cast card to pay your taus and any preparation fees. You'l eam one Pont for every dolor you spend Wth the card and W that much doter to aro rewaMs you want. Plus, you l be obit to pay your lax lea over ams vMh conversant monllrly paymsnts to yourHSBC a card. TRANSACTION SUMMARY (For additional transaction detail go to www.hWxcreditcard.com) TRANS POST TRANSACTION REFERENCE AMOUNT DATE DATE DESCRIPTION NUMBER CHARGES CREDITS 02/07 02107 LATE CHARGE ASSESSMENT 10000004000000999330050 $39.00 02112 02112 ACCOUNTSECURE PLUS 800490.1532 $17.00 I FINANCE CHARGE CALCULATION I 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 $1,094.18 0.08785% 30 $2877 $0.00 31.99% 31.980% CASH ADVANCES $871.53 0.08765% 30 $22.92 $0.00 31.99% 31.990% v" MAIL PAYMENTS TO: HSBC CARD SERVICES PO BOX 17332 BALTIMORE MD 21297-1332 2 QUESTIONS? 24-HOUR CUSTOMER SERVICE 1.888-3858916 OUTSIDE USA, COLLECT: 1-718-641-7141 MD HEARING IMPAIRED: 1800-855-9392 Q Manage your account online at: www hsbccreditcard corn ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 80028 SALINAS CA 93912-0028 140201 51 12 0000000400 G STMT69 D H 00013652 IOF01 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check Account Number 5215-3188-0379-283; 4ew Balance $2,040.81 Minimum Payment $112.0( payment Due Date 0308108 Current Payment Due $613.8+ WAude account number on check to HSBC CARD SERVICES. Do not send cash. Sen payment 7 days prior to Payment Due Date to ensure timely delivery. To avoid additional late and/or overiimil fees, pay the Current Payment Due. Amount Enclosed JEFFREY L HOOVER 961 MRZNSPRINt3 RD 'o NENVILLS PA 17241-9679 ° HSBC CARD SERVICES I111"I111'II'III'111111I"111111'11h11I11?111I1111111'Inll' PO BOX 17332 BALTIMORE MD 21297-1332 loll 11111111111 111 i c v 521531880379283300061381002040813 MASTERCARD CREDIT CARD STATEMENT Page 2 of 2 IMPORTANT INFORMATION As a reminder, your APRs may immediately Increase up to the Default APR if your payment is late or you exceed your credit limit, as per your Cardmember Agreement and Disclosure Statement. IMPORTANT INFORMATION Your AccountSecure® protection has been suspended due to the past due status of your account. Your benefits may be eligible for reinstatement once the status of your account meets the eligibility requirements outlined in the enrollment information. ? MAIL PAYMENTS TO: 2 QUESTIONS HSBC CARD SERVICES • CA MAIL INQUIRIES TO• PO BOX 17332 24-HOUR CUSTOMER SERVICE HSBC CARD SERVICES BALTIMORE MD 21297-1332 1-888-3&5-W18 OUTSIDE USA COLLECT: 1.716-841-7141 PO BOX 80028 , TOO HEARING IMPAIRED: 14800.855-9392 SALINAS CA 93912-0028 2 Manage your account online at: www.hsbecreditcard.com IDF01 140201 51 12 0000000400 G STMT89 D H 00013852 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check 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, CHARLES SHUMAN, 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. CHARLES SHUMAN 06866190 5215318803792833 $2399.32 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. O t t t ??' ?70 ?iYFI'y r4l C11',1 +1J 1 ? G P l' ILJ $?B.So PA ATI`/ et* M311 SW ataawwq R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor arx r1444 OFFICE ?= r JIFF 2009 NOV 2S A„' e: 08 QumAa l HSBC Bank Nevada, NA vs. Jeffrey L. Hoover Case Number 2009-7879 SHERIFF'S RETURN OF SERVICE 11/19/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jeffrey L. Hoover, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Jeffrey L. Hoover. Per Defendant's Grandmother Jeffrey L. Hoover is currently residing at 215 Briggs Street #A Harrisburg, PA 17102. SHERIFF COST: $43.80 SO ANSWERS, Sly- q Ltl S?- November 19, 2009j( R THOMA KLINE, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED-D_ CE 1Ctaiq Gp ARd (e) CbunfySIAP, Shenff. Teleosoft. Inc.