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Home My WebLink About10-5294 2DW I W-LZ RK0:3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: /p _. VS. COMPLAINT IN CIVIL ACTION CINDY A KRAMER 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 07209128 C N Pit EMR 5 ?4a.oo r7??? ayl?ool? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. Civil Action No CINDY A KRAMER 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 (2.0) 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 b 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: CINDY A KRAMER 319 FARMINGTON DR SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4677 . 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 $2377.60 , as of July 23, 2010 . 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 , CINDY A KRAMER , individually , in the amount of $2377.60 with continuing interest thereon at the rate of 6.000% per annum from date of judgment plus costs. fames c. WELTMAN 436 Sev Pittsb (412) 3 FAX: 4 2 0-72091 A2 INBERG & REIS CO., L.P.A. Avenue, Suite 1400 PA 15219 -795'5 338-7130 C N Pit 'EMR This law firm is a debt collector attemp111 g to collect this debt for our client and any information obtained be used for that purpose. ORCHdRD BdNKe CINDY A KRAMER PAYMENT SUMMARY MINIMUM PAYMENT' $88.00 PAYMENT DUE DATE 1011801 OVERLIMIT AMOUNT $422,56 PAST DUE AMOUNT $411.00 CURRENT PAYMENT DUE' $510. To avoid adddional late and or ovac0mit fees, you must pay the Current Payment Due (lvhich includes the Minimum Payment and any Past Due andlar Ovedimit Amounts). 'See About Your Payment on reverse for an BALANCE SUMMARY PREVIOUS BALANCE $2,263,30 PAYMENTS/CREDITS $0.00 PURCHASES/DEBITS + $0.00 LATE PAYMENT CHARGE + $0.00 MISC. FINANCE CHARGE + $0,00 FINANCE CHARGE + $59.26 NEW BALANCE _ $2,322.56 Page 1 of 1 ACCOUNT SUMMARY ACCOUNT 400MOUNIM M4677 NUMBER CASH CREDIT LIMIT t $1,900 CASH LIMIT AVAILABLE $0 TOTAL CREDIT LIMIT $1,900 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE 09/21/08 t Cash Credit Limit is a Portion of the Total Credit Limit PERIODIC FINANCE CHARGE SUMMARY This is a grace account Grace period information on back. Balance Subject To Finance Charge Daily Days Finance Charges Average Daily Periodic in Billing At Periodic ANNUAL Balance Rate Cycle Rate PERCENTAGE PURCHASES CASH ADVANCES $2,159.30 0.08080%(v) 32 $.83 RATE 29.49%(v) $132.57 0.08080%(v) 32 $3 E3.43 29.49%(v) ANNUAL PERCENTAGE RATE" 29.490;L **May be higher then Nominal Percentage Rate it statement includes misc. finance charges. (V) indicates variable rate EMIBff ? MAIL PAYMENTS TO: V QUESTIONS? ® MAIL INQUIRIES TO: HSBC CARD SERVICES 24-HOUR AUTOMATED ACCOUNT INFORMATION HSBC CARD SERVICES BOX 17051 BA ENGLISH 1-503-293.4037 PO BOX 80064 BALTIMORE MD 21297-1051 ESPAF40L 1-5032934834 SALINAS CA 93912-0084 Q Manage your account- online at: www.orchardbank.com 1102015 W 20 0000000508 G STMT07 D E 00049118 ODSt PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check Account Number INS4671 New Balance $2,322.56 Minimum Payment $883 Payment Due Date 10/16M Current Payment Due $81051 Iclude account number on check to HSBC CARD SERVICES. irreM 7 ?- AA J Do not send cash. Sen . v- - rap-ronr Lnm Lore to ensure timely delivery. To avoid additional late and/or overlimit fees, pay the Current Payment Due. Amount Enclosed #BWNHYTS #328041324679# CITY A KRAMM 8 117 QVENTIN TIN CIR ilriltilnnllllnrrrhllri?l?irlrirly?trinlll?ilti?rlil?l?r?l 8 SBIPPENSBURG PA 17257-8794 BSBC CARP SERVICES PO BOX 17051 ???rl?ll??l???l??rl??trr?l?r?rl???ll?r?rr?lrlr?l???llr??rlt?rr?l? BALTIMORE MD 21297-1051 467700051056002322569 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating to unsworn falsifications to authorities, that she is Valerie DeMarais, Business Consulting Analyst of HSBC Bank Nevada, N.A., plaintiff herein, that she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. if (Signature) C r ILED-OFFICE Dr TIDE PR OTHO N O'Tt?P,'r 2010 NOV 22 PM 12: 28 PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. CINDY A KRAMER Defendant(s) No. 10-5294 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R Bibler, Esquire PA I.D. #93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7209128 JAM IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff VS. Civil Action No. 10-5294 CIVIL TERM CINDY A KRAMER Defendant(s) PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF Cumberland COUNTY: SIR: Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ler, squire PA L Benja P3D WEL EINBERG & REIS CO., L.P.A. 1400 uilding 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 SWORN TO AND SUBSCRIBED COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wayne A. )ones, Notary Public City of Pittsburgh, Allegheny County Commission Ires June 29, 2014 Marron I nn no a 8EIon of Notaries before me this lb day David 11 Buell Prothonotary Office of the Prothonotary Cum6erfand County, Tennsyfvania 70kS. Sofionage, BSQ Solicitor /�-S:291{ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28Th DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 ® CarfrsCe, TA 0 (Phone 717 240-6195 0 Fax 717 240-6573