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Home My WebLink About10-5657 -CFFIM T o THE c. ~ 1 AM IQ: 47 CUMgEriUr#`1D ",' ()UNTY pENt, SYLVAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff No: lb - 5(v5'7 a;y;tTem vs. JENNIFER MURRAY 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 06785043 C N Pit CXC *4a.oo Pry Ar71/ e,'f 4744511 ?', 61q 7 5-88 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. Civil Action No JENNIFER MURRAY 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: JENNIFER MURRAY 512 N WALNUT ST MOUNT HOLLY SPR, PA 17065 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0279 . 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 $1701.86 , as of August 16, 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 , JENNIFER MURRAY , individually , in the amount of $1701.86 with continuing interest thereon at the rate of 6.000% per annum from date of judgment plus costs. James C Wa ro t,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Sev n h Avenue, Suite 1400 Pittsbu g , PA 15219 (412) 4 4 7955 FAX: 4 2- 38-7130 067850 3 C N Pit CXC This law firm is a debt collector attemp4/91 to collect this debt for our client and any information obtained be used for that purpose. HSBC MASTERCARD STATEMENT JENNIFER MURRAY ACCOUNT SUMMARY ACCOUNT 5407-9150-2429-0279 NUMBER CASH CREDIT LIMIT t $1,300 CASH LIMIT AVAILABLE $0 TOTAL CREDIT LIMIT $1,300 TOTAL CREDIT LIMIT $0 AVAILABLE STATEMENT DATE om5f08 PAYMENT SUMMARY MINIMUM PAYMENT' $56.00 PAYMENT DUE DATE 09/19/08 OVERLIMIT AMOUNT $401,86 PAST DUE AMOUNT $345.00 CURRENT PAYMENT DUE- $457.8 To avoid additional late and/or overlimit fees, you must pay the Current Payment Due (which includes the Minimum Payment and any Past Due and/or Overlimir Amounts). `See About Your Payment on reverse for an t Cash Credit Limit is a portion of the Total Credit Limit ! r Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $1,664.72 PAYMENTSICREDITS - $0.00 PURCHASES/DEBITS + $0.00 LATE PAYMENT CHARGE + $0.00 MISC. FINANCE CHARGE + $0.00 FINANCE CHARGE + 37.14 NEW BALANCE _ $1,701.86 PERIODIC FINANCE CHARGE SUMMARY This is a grace account Grace period information on back. Balance Subject To Finance Charge Daily Days Finance Charges NOMINAL Average Daily Periodic in Billing At Periodic ANNUAL Balance Rate Cycle Rate PERCENTAGE PURCHASES CASH ADVANCES $1,682.62 0.07121%(v) 31 $37.14 RATE 25.99%(v) $0.00 0.07121%(v) 31 $000 25 99%(v) ANNUAL PERCENTAGE RATE- 25.99056 ""May be higher then Nominal Percentage Rate if statement includes misc. finance charges. (V) indicates variable rate rviL CA11 R 1 ? MAIL PAYMENTS TO: QUESTIONS? HSBC CARD SERVICES N1 MAIL INQUIRIES TO: PO BOX 17051 24-HOUR AUTOMATED ACCOUNT INFORMATION HSBC CARD SERVICES BALTIMORE MD 21297-1051 ENGLISH 1.800-216-1013 PO BOX 80084 ESPANOL 1-800-950-3390 SALINAS CA 93912-0084 OUTSIDE USA, COLLECT. 1-503.245-9280 H Manage your account online at: www.hst)ccreditcard com 110242 5 N 25 0000000500 G STMTXT 2 g EXCPT 00031027 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check HSBC m Account Number 5407-9150-2429-0279 4ew Balance $1,701.86 Minimum Payment $56.0( 'ayment Due Date 09/19/08 Current Payment Due $457.8( iclude account number on check to HSBC CARD SERVICES. Do not send cash. Seni r-r••• ••• •? •? .ay. P.., to .aymem uue uate to ensure timely delivery. To avoid additional late and/or overlimit fees, pay the Current Payment Due. #BWNHYTS #317024290270# JENNIFER MURRAY 512 N WALNUT ST MOUNT HOLLY SPRINGS PA 17065-1509 IIInIrIrIIn?11?II?r1?Ily?In?JnL?rlll?llll?llll?nlll Amount Enclosed rll?ll???l?rl?lll?lirl?l??lrl?rllrrrll'IIIIIIII?IIIrllr?rllrr?rrl HSBC CARD SERVICES PO BOX 17051 BALTIMORE MD 21297-1051 540791502429027900045786001701867 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. V02 A4 - &VQ 4" VALERIE DFMARAIS 06785043 5407915024290279 $1701.86 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. s SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy PLED-Offl- CE OF THE [11 . ,, _. +rtTA,IRYY A SEA' -9 AM 8: 45 Richard W Stewart Solicitor OFFICE 14 -? E PENNSYLVANIA HSBC Bank Nevada, NA vs. Case Number Jennifer L. Murray 2010-5657 SHERIFF'S RETURN OF SERVICE 09/03/2010 05:29 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 3, 2010 at 1729 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer L. Murray, by making known unto Daniel Murray, Husband of defendant at 512 N. Walnut Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.30 September 07, 2010 GE LD WORTHINGT DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ipj GounrySuite Sheriff. Te;easoft. {r,c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff No. 10-5657 CIVIL TERM VS. STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT JENNIFER MURRAY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6785043 $1701.86 r cn o >- ?-- Uj 0 ce) U- C? U- = °' o Q O? N Jcn a it - co 1?- 2 ? sl q/ LL C) N (.? LI L w tc? m a l s - 14- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff VS. Civil Action No. 10-5657 CIVIL TERM JENNIFER MURRAY Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, JENNIFER MURRAY, in the amount of $1701.86 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By Attorney for Plaintiff JENNIFER MURRAY, By: a I-/ Defend a WWR#6785043 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff VS. Civil Action No. 10-5657 CIVIL TERM JENNIFER MURRAY Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, JENNIFER MURRAY, above-named, in the amount of $1701.86 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1701.86 with continuing interest thereon at a rate of 6.00% per annum plus costs from Date of Judgment. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, JENNIFER MURRAY, in the amount of $1701.86 plus continuing interest thereon at the rate of 6.00% per annum from Date of Judgment and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $200.00 due by OCTOBER 15'H. 2010; (b) $100.00 due on the 30TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "HSBC BANK NEVADA, N.A." 5. The first payment due under this agreement is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 436 Seventh Avenue, Suite 1400, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals thi/!day of WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6785043 By: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff VS. Civil Action No. 10-5657 CIVIL TERM JENNIFER MURRAY Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $1701.86 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 ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary Jennifer Murray 512 N Walnut St Mount Holly Spr, Pa 17065 By PF WELTMAN, WEINBERG & REIS CO., L.P.A. 0 N?? Ids `t BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) I.D. No.86469 r l y -9 pt'1 1: L 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 "'_11"IBERLAND COUNTY' Phone: 412.434.7955 PEtI SYLVANI¢ Fax: 412.434.7959 File # 6785043 HSBC BANK NEVADA, N.A Plaintiff CUMBERLAND County Court of Common Pleas vs. JENNIFER MURRAY Defendant(s) NO. 10-5657 CIVIL TERM 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 &_I?FXS CO., L.P.A. By Sarah E. Ehasz, Escl: Attorney for Plaintiff -a? ?l R 10