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Home My WebLink About09-8092IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A rr Plaintiff No: - VN ClC>t,l.vs. COMPLAINT IN CIVIL ACTION REBECCA L RAMOS AKA REBECCA RAMOS 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 06637145 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 REBECCA L RAMOS AKA REBECCA RAMOS 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: REBECCA L RAMOS 2071 RITNER HWY CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8525 . 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 $14052.45 , 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 , REBECCA L RAMOS , individually , in the amount of $14052.45 with continuing interest thereon at the rate of 6.000% per annum from date of judgment plus costs. James C' warmnroar,4L524 WELTMAN, EINBERG & REIS CO., L.P.A. 436 Se en h Avenue, Suite 1400 Pittsb rg PA 15219 (412) 43 -7955 FAX: 41 -338-7130 0663 1 C N Pit KMJ This law firm is a debt collector atteml:?Eing to collect this debt for our client and any information obtained will be used for that purpose. Customer Center Payment Address: 1-800-947-1000 HSBC CARD SERVICES P.O. BOX 80082 PO BOX 37281 Salinas, CA BALTIMORE MD 93912-0082 21297-3281 Visit us at www.gmcard.com Quick Look Account Summary Statement Date 1125/08 Account number 5466 4103 0508 8525 New Balance $13,646.44 Total Credit Limit $0 Minimum Payment • $535.00 Total Cash Advance Limit $0 Payment Due Date 02119108 Available Credit $0 Past Due Amount $2,895.00 Available Cash Advance $0 # Days This Billing Cycle 31 Current -Payment Due' $3,430.00 Page 1 of 1 ..r:.:.:.:.n:::: ... ........ ............:........ ... ... ... ...... ... .......... ..u..: xr.... r..:.:;.::..:mro!?-si,,t!r!r.i _.!......N,,.. _ n:::.:n:nnnn:nfi,k!u!nna:::x,:r:!:.rr::: ............. ..i!- :.:.:::::.:.. .......... ........... ... ...:.::..::...............;... rn..n....c, _a...:.,xa..lnl.,ar.l... !:....., r.._r_...._.a.a......r...l...rr .. .. .............. .......... ... ...., .. ...... .................... ... .. :r4::;,;c:;c:;r!:an n.r.._r!......r._,F..!!.r...r._,I r.._r_r...!.!_.... .. .......u.!.u?, ...r.r...._:!::.. AdttD ??I ... . ...................... a ,: ........... n::!!:::::r::,ua::.:,:,,n,.n,ru.,rl.,...r....l.._r:u.......,..:...a!..,n.rr.n,?r..nn.-n...._............_? ..............:.......r......,...,.xr.u:_,,,, ........ . :?.r.:::? ::.r.::.r.:.::::::? :?:!:i!:4ir " ........._._. _..............a.... ............. n,c:!!: .r 1.rl.. r. !,.. _i. ....... .. .-.. .. ... .:. ,,............ „! i,..nx..1.L:r::Y::!?:::!::::::,:-,. .. i!ri, r ri:iii-iiiiii:i:ii: 4......._.... ............_.... -- ,: nisi:!:. r.xr:n:::::..::: r!!!II!:!!:c__F!:...... ...G ............... I I ,,..i::u,;,al:,:n::n:::..r..................,,. :raar!i ixr::r:::::::!::: Previous Balance Payments and Other Credits + Purchases, Cash Advances, + Finance Charges = New Balance Fees and Other Debits $13,248.24 $0.00 $39.00 $359.20 $13,646.44 :.r,,.rrrrr„rr ;!:....::::::::- ..!.. r..r ....................... .,::. :........ .... ......_.._...... ..............:!!!!!!iGi!!!i :!'!!iliri!!!x!!•i!!i!!!::!r!!i i!!i!'-!i::;'x_............ ......r... n.r .. .. ..:..... x......,..t..... ...: ... .L:. rr....::....nr..r ... .. .. .. .:.:............ ....r...._n_i.x._...,r_x!!!r;x!!!!! .a.r...ir .................,....,:. ,:rrr ... .....,..... ........I.........:..,: ,.mr...rxi.....n..,._.........,....!.......r....x.I.._..........I......................._.rx.,..,r._.n.,.........x . .r,,:, .....nr..r. r.9r. !h .. .. rl..i ... ....r...r.rr.ri..r..i.r_.......c......r...:...r....... r... .... ... rrr.....r..rl.4......!........!F:n. ..:......r.r.....rd...!...n_........ _ ...................................................._.....:.......,.._......................., ............... ..!:.. 9 ............... _......:. ..... .!.... .. ... r..r.._.,.,,....r,.!r:.li..l.:l..rr,l.:r:..?...,...:...r....:........!...,...,..r.r.r........__....r........r..r.rr. r.r..:......................... ....::..•:.i.:,c:.:i?:!.:,,::'!$;I,.:r:rrr ur.......,,..n..._,...,.6....!.r..rrrr ..............r..s.rr.....r,:,:.:..,t;,....lFjtf?B!t3!Cg..?i't11S1 ...:.. klkifllL3ln,!:r::r:!.. r.......r.........a... Average Daily Daily Periodic Nominal Annual Finance Cash Advance/ Annual Balance Rate Percentage Rate Charge Transaction Fees Percentage Rate Purchases $11,203.37 0.08628% 31.49% $299.65 $0.00 31.490% Convenience Check $737.84 0.08628% 31.49% $19.73 $0.00 31.490% Convenience Check $1,488.76 0.08628% 31.49% $39.82 $0.00 31.490% Cash Advances $0.00 0.00000% 31.49% $0.00 $0.00 0.000% ............. ......._......................_._............................................._......_....._.............._.._..,.. ..6d .! r .rr:n.......rr....r.......__rl....cin.u.r.u...r.r....r ..........?..........r:. ...... ...... ..... .r r .................... .. ... _ .. .. r ... v.. ca:::;-__ .... .1 ... !.I.... . ::.:. i ......... :..r:xi ':a:!I Ih: .5111m. ::: _ :!::::::: ax:: :xasli,;r :ii;Irei ....................: r:n:linMim ...., .:,!!iiixii[iGi! =!!.:..: :!!r::::::!i: Previous Earnings $0.00 New Earnings Total $0.00 Remember, every time you make a purchase with Earnings Received $0.00 Anniversary Date 2/1/06 your GM Card, you'll earn 51% in GM Card Earnings. Additional Earnings $0.00 Anniversary Y-T-D Earnings $0,00 You can save hundreds, even thousands on the Earnings Adjustments $0.00 Lifetime Earnings Redeemed $0.00 purchase or lease of your new GM car or truck (excluding Saturn, Saab and HUMMER H1). Choose Current Period Earnings $0.00 from over 50 brandst :.:::i:,,!i'.;!!::!r'ce!i!a':m::!!;m:::!xrr!:i!.!Ix:::::iru:r:::!x::;;nx:.;.r.rn,,,..,r.':Kyir :.:.rn dlteaEk I ftllatferClt"af carol trade ? 'I? : ?t?'n ............. :.. r::!rr::::rn!r:- ?I?h ar7 c 49f i7f7TT' e . ::.. .::I * * * * * * * * * * * * * * Important Information * ' * * " ' Your account has been laced with a collection agency. Please contact them directly, or call us at 1-800-388-5333. 1007505125 STMT94 B01-01 005940/PM GMC1 (Please detach and return bottom portion with payment and retain top portion for your records. Do not staple or clip your check to the form below.) account Number 5466 4103 0508 8525 New Balance $13,646.44 Minimum Payment $535.00 Payment Due Date 02/19/08 Current Payment Due $3,430.00 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. 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 avoid an additional late fee, pay the Current Payment Due. tSee reverse for more information Amount Enclosed REBECCA L RAMOS III 11 1 11 1 1 III IIII IIII I rr r rrr rr r rrr rrr rr rrr r rr rrrr r r r 2071 RITNER HWY CARLISLE PA 17015-9303 HSBC CARD SERVICES I III I l i 1 1 1 1 1 1 I I I I III I I I III PO BOX 37281 'o n r rrr r u n r r r r r n n r u n r r u r u r n r BALTIMORE MD 21297-3281 i 0343000 1364644 5466410305088525 9 01/19 01/19 LATE CHARGE ASSESSMENT $39.00 10000002010000999957700 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, KAMI TRAASDAHL, 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. i?AMI'TRAASDABL 06637145 5466410305088525 $14052.45 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 91, FILLIP -' r 7 r e 2009 NOV 20 Fri Li: O i CK-4J 1/3I lS"G`r ? j?,4-- a 3 3 93S .. ZOiQ,~ii~ -9 ~' IZ~ ~4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. REBECCA L RAMOS Defendant(s) No. 09-8092 CIVILTERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA ID #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 1521.9 (412) 434-7955 WWR#6637145 JAM ~/a, a6 p~"~Y ~~- y~6 y9/ ~ ,e~t+` ~.y3 y1~ IN THE COURT OF COMMON PLEAS Ct1MBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No. 09-8092 CIVILTERM :REBECCA L RAMOS Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN,~INBERG & REIS CO., L.P.A. ~' C~ By: / / ~~ Lyndsay E wland, Esquire PA ID #2 520 WELT AN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6637145 7' ~ ', '`. T~ - ao~o ~ AUG r 3 PIU 3: 5/ ~~ { [ _ HSBC BANK NEVADA, N.A IN THE COURT OF COMMON PLEAS .CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff No: 09-8092 CIVILTERM vs. REBECCA L RAMOS AKA REBECCA RAMOS PRAECIPE FOR DEFAULT JUDGMENT 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 06637145 C N Pit JAM Judgment Amount $14052.45 ~ I~: oo Pp r~rN c# ~oaa.(oa ~~ ~~~I HSBC BANK NEVADA, N.A Plaintiff vs. REBECCA L RAMOS AKA REBECCA RAMOS TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 09-8092 CIVILTERM PRAECIPE FOR DEFAULT JUDGMENT Kindly. enter Judgment against the Defendant REBECCA L RAMOS AKA REBECCA RAMOS above named, in the default of an Answer, in the amount of $14052.45 computed as follows: Amount claimed in Complaint $14052.45 Less payments / adjustments made $0.00 Attorney's fees $0.00 TOTAL $14052.45 I hereby certify that appropriate Notices of Default; as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By : ~ -_~~ James C. W~ rodt,42524 06637145 (7 N I Pit JAM Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, P 15219 And that the last known address of the De/f~ndant is REBECCA L RAMOS v ACA REBECCA RAMOS 428 1ST ST CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff. vs. REBECCA L RAMOS AKA REBECCA RAMOS Civil Action No. 09-8092 CIVILTERM NOTICE OF JUDGMENT OR ORDER TO: ( ) .Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that th €ollowing Order of Judgment was entered against you on S~i 10 (xx) Assumpsit Judgment in the amount of $14052.45 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prc By REBECCA L RAMOS AKA REBECCA RAMOS 428 1ST ST CARLISLE,. PA 17013 Plaintiff's address is: c/O WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Aug-03-2010 12:41:41 ~G Last N First/Middle Begin Date Active Duty Status Active Duty End Date Service A ame en RAMOS REBECCA Based on the information you have furnished, the DMDC does not possess any information indicatin the individual status. Upon seazching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Mazine Corps, Air Force, NOAA, Public Health, and Coast Guard). ,ern. ,4~..~-v~.- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you aze strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/facLp/ is/PC09SLDR.htm1. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 8/3/2010 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guazd Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guazd RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections aze based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:6OBSRBJJQD https://www.dmdc.osd.miUappj/scra/popreport.do 8/3/2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. REBECCA L RAMOS Civil Action No. 09-8092 CIVILTERM NON-MILITARY AFFIDAVIT The undersigned, who first duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. APP- 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant REBECCA L RAMOS AKA REBECCA RAMOS is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), which states that the DMDC does not possess any information indicating the individual status. REBECCA L RAMOS AKA REBECCA RAMOS 428 1ST ST CARLISLE, PA 17013 is not in the military service. Further Affiant sayeth naught. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. REBECCA L RAMOS AKA REBECCA RAMOS Defendant Case No. 09-8092 CIVILTERM IMPORTANT NOTICE TO:. REBECCA L RAMOS 428 1ST ST CARLISLE, PA 17013 tt ~^, Date of Notice: 1 G YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 1701 S (717}248-3166 WELTMAN, WEINBERG &REIS CO., L.P.A. By: Ma ew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG &REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone; (412) 434-7955 6637145 N PIT G46