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Home My WebLink About09-8153I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff No: ?- 81 ?tVtL -ePw, vs CHARLES W FICKES 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 07592036 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 9- p'1S3 CHARLES W FICKES 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: CHARLES W FICKES 105 CUMBERLAND DR CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9304 . 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 $3264.90 , as of November 09, 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 , CHARLES W FICKES , individually , in the amount of $3264.90 with continuing interest thereon at the rate of 6.000. per annum from date of judgment plus costs. James C. ar ro t,42524 WELTMAN EINBERG & REIS CO., L.P.A. 436 Sev n h Avenue, Suite 1400 Pittsb rg PA 15219 (412) 43 -7955 FAX: 1 -338-7130 0759 0 6 C N Pit KMJ This law firm is a debt collector attem ing to collect this debt for our client and any information obtained will be used for that purpose. HOUSEHOLD BANK PLATINUM CHARLES L^, F*ICKES ACCOUNT SUMMARY ACCOUNT 5408.0100.3145.9304 NUMBER TOTAL CREDIT 00IT $2,600 TOTAL CREDIT LIM17 $0 AVAILABLE CASH CREDIT LIMIT t $650 CASH LIMIT AVAILABLE $0 STATEMENT DATE 05/20/09 PAYMENT SUMMARY MINIMUM PAYMENT' $111.00 PAYMENT DUE DATE 06/12109 OVERLIMIT AMOUNT $664.90 PAST DUE AMOUNT $681.00 CURRENT PAYMENT DUE* $792,Ot To avoid additional late andlor ovedimit fees, you must pay the Currant Payment Due (which Includes the Minimum Payment and any Past Due and or Ovedimil Amounts). 'See About Your Payment on reverse for an t Cash Credit Limit is a portion of the Total Credit Limit M.a1erC?rd Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $3,186.74 PAYMENTS/CREDITS $0.00 PURCHASES/DEBITS + $0.00 FINANCE CHARGE + 78.16 NEW BALANCE _ $3.264.90 FINANCE CHARGE CALCULATION This is a g race account. Grace period i nformation on back. Average Daily Days FINANCE CHARGE Nominal ANNUAL Daily Balance Periodic Rate in Billing At Periodic Cash Advance/ R t T Annual PERCENTAGE a e ransaction Fees Percentage RATE CASH ADVANCES P $1,674.14 0.08080%(v) Cycle 30 $40.58 $0.00 Rate 29 49%(v) 29 490% URCHASES PURCHASES $1,441.64 0.08080%(v) 30 $34.95 $0.00 . 29.49%(v) . 29.490% $108.58 0.08080%(v) 30 $2.63 $0.00 29.49%(v) 29.490% (v) indicates variable rate ? MAIL PAYMENTS TO: HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 ® MAIL INQUIRIES TO: HSBC CARD SERVICES PO BOX 81622 SALINAS CA 93912.1622 090750 51 20 0000000103 G STMT37 D 7 00007668 HDP1 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check Account Number 5408-0100-3145-9304 Vew Balance $3,264.90 Minimum Payment $111,0( 'ayment Due Date 06/12/09 Current Payment Due $792.0( Iclude account number on check to HSBC CARD SERVICES. Do not send cash. Sen. 9 QUESTIONS? 24-HOUR CUSTOMER SERVICE 1-800-462.2016 OUTSIDE USA, COLLECT: 1-757-523-3880 TDD HEARING IMPAIRED: 1-800-395-9020 13 Manage your account online at: W WW.householdbank.com 'ar. F--- - raymeor vue ume io ensure timely delivery. To avoid additional late and/or overlimit fees, pay the Current Payment Due. Amount Enclosed CHARLES N FiAtCES Illlnlil?rrrlrllul'?I??lilll?l?l??lllil?n??lllnlrlllllnlllll 105 CUMffiERLA:.*i` DR S CAMP HILL PA '.7011-6620 HSBC CARD SERVICES ° PO BOX 17051 Illtll??llllt?lrllllllll?tl?rrillll??llilllllll?lllll"1111"1111 BALTIMORE MD 21297-1051 540801003145930400079200003264907 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. Section 4904 relating to unsworn 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 07592036 5408010031459304 $3264.90 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Q rr F '!'LE t`1 riCE 2009 NIJ 24 AH 9: 23 u M_ . o ". 50 PO Ar%4 c& 4,3501co10 01-34040,