HomeMy WebLinkAbout07-4047GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
PA ID#69006
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff,
NO. D'7- ~~~f 7 Ci v ~ l Te1-m
v.
DARLENE R POINT ,
Defendant(s)
COMPLAINT IN CIVIL ACTION
Filed on behalf of:
TARGET NATIONAL BANK,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412)429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK,
Plaintiff,
NO.
v.
DARLENE R POINT ,
Defendant.
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 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, 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.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK,
Plaintiff
NO. ~ ~- yon/ 7 ~ ~,c.,~.
v.
DARLENE R POINT ,
Defendant.
COMPLAINT IN CIVIL ACTION
AND NOW, comes Plaintiff, TARGET NATIONAL BANK, by and through its
attorney,GREGG L. MORRIS, ESQUIRE and the law offices of PATENAUDE & FELIX,
A.P.C. and files the following Complaint in Civil Action, and in support thereof aver as
follows:
1. Plaintiff, TARGET NATIONAL BANK, is a corporation and for the purpose of
this litigation, maintaining a place of business c/o Patenaude and Felix, A.P.C., 213 East
Main Street, Carnegie, Pennsylvania 15106.
2. Defendant is DARLENE R POINT , an adult individual, believed to currently
reside at 515 KEVIN CT ,CAMP HILL, PA 170111263.
3. Heretofore, the Defendant opened a TARGET NATIONAL BANK account with
Plaintiff being Account No. 4352378365956263 ,for the purchase of goods and services.
4. The Defendant has made or authorized a number of purchases and as of
05/15/07, Defendant owes $4,213.24 on said account plus interest.
5. Plaintiff maintains accurate books of account recording all credits and debits for
this account.
6. The Defendant has received monthly billing statements from Plaintiff setting
forth the nature and amount of all charges made by Defendant, and the transactions between
Plaintiff and Defendant give rise to an account stated, upon which Plaintiff has relied.
7. The Defendant made payments, but has refused to pay, and now refuses to pay
the balance due and owing on the aforesaid account in the sum of $4,213.24, plus interest
and costs.
8. By failing to object or dispute to the statements including the statement attached
hereto as Plaintiffs Exhibit "A", Defendant has assented to and agreed to the correctness of
the balance due on the credit card account so as to constitute and account stated.
9. Despite repeated demands, Defendant has failed to make the required installment
payments when due and therefore the full amount of the account is now due and payable.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant, in
the amount of $4,213.24, plus legal interest from the date of breach, with continuing interest
at the legal rate thereon from the date of Judgment plus costs. The damages requested are
less than the maximum amount for compulsory arbitration as set by the Court.
Submitted:
& Felix, A.P.C.
~~'9'E. G L. MORRIS, ESQUIRE
Main Street
Carnegie, PA 15106
(412) 429-7675
o ii iiA~~~n ii
Account Number: 4352-3783-6595-6263 Statement Closing Date: May 11, 2007
DARLENE R POINT Page 1 of 2
Target Visa Account Summary
Total Credit Limit $0
Cash Limit $0
Available Credit $0
Portion Available for Cash $0
The Cash Limit is a portion of the Total Credit Limit
Questions? Call Us:
Target Credft Services 1-888-755-5856
TDD/TDY 1-800-347-5842
Outside the U.S. 11-612-307-8622 (Call Collect)
Calling will not pfeserve yourbilling-errorrights
Previous Balance $4,178.24
Payments & Credits 0.00
Purchases & Advances 0.00
Other Charges 35.00
FINANCE CHARGES 0.00
New Balance $4,213.24
Amount Past Due 51,101.78
Minimum Payment Due 54,213.24
(includes any Amount Past Due)
Payment Due Date June 5, 2007
Payments ~ Credits
No payments or credits were received last month.
Other Charges
May 6 LATE PAYMENT FEE $35.00
Total Other Charges $35.00
Target National Bank, en afiliete of Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
INCLUDE THIS PORTION WRH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK
Account Number 4352-3783-6595-6263
TARGE'~
I~~~~~~IINIIIIIINIIIIIN~IIIN~IIIIII~~
Mm mum Payment Due
$4,213.24
Payment Due Date June 5, 2007
NEW PHONE, HOME OR I I I I I t 1 I l I11I11 I l I I I I I I I I I I I I I I I I I I I I I I I I (I I I I I I I I I I ~ Amount
E-MAIL ADDRESS? Enclosed $
PLEASE UPDATE ON TARGET NATIONAL BANK
REVERSE SIDE. P.O. BOX 59317
OFFICE COPY MINNEAPOLIS, MN 55459-0317
STATEMENT PAGE NOT PRINTED
DARLENE R POINT
515 KEVIN CT
CAMP HILL, PA 17011-1263 // ~'
IIIIIIItItIII11111tIL111LItIL111111L1111L111111Lllltl111 ~~xh ~ k~ i ~ ~t~
0008080421324042132490435237836595626371
O IIB~IIIIIIIIIIIIIIIIIII~IIIIII
Account Number: 4352-3783-6595-6263 Statement Closing Date: May 11, 2007
DARLENE R POINT Page 2 of 2
Finance Charges _ _ __ __ __ _ _
Days in Billing Period: 30
Corresponding Average Periodic Transaction
Daily Annual Daily FINANCE FINANCE
Balance Type Periodic Rate Percentage Rate Balance CHARGE CHARGE
Purchases 0.0773696 28.24% $0.00 $0.00 $0.00
Cash 0.07736% 28.24% $0.00 $0.00 S0.00
Total FINANCE CHARGES: $0.00
Actual AN NUAL PERCENTAGE RATE: 0.00°h
There is a minimum FINANCE CHARGE of $1.00 for any billing period in which a Finance Charge is imposed
I 8510363
In
Original Creditor Name: TARGET NATIONAL BANK
Debtor Name: POINT, DARLENE R
Co-Debtor Name:
Account Number: 4352378365956263
AFFIDAVIT OF ACCOUNT
STATE OF MINNESOTA
COUNTY OF HENNEPIN ss:
The undersigned, TIFFANY LEWIS states that:
I am a representative of TARGET NATIONAL BANK and am authorized to Verify
current balances due and owing to TARGET NATIONAL BANK on credit card
accounts.
As of the date of this affidavit I have reviewed the records of the above listed person and
account, and that the amount due and owing to TARGET NATIONAL BANK on this
account, over and above all known legal set offs is $4213.24.
That reasonable inquiry has been made to determine if the defendant is in the military
service of the United States of America, and to the best of my knowledge that defendant
is not in such military service and is therefore not entitled to the rights and privileges
provided under the Soldiers and Sailors Civil Relief Act of 1940, as amended.
That the above information is true to the best of my knowledge,
information and belief, and based upon the books and business
records of TARGET NATIONAL BANK.
c-
~_ .
Aut 'orized GET NATIONAL BANK
Subscribed and sworn to before
Me on 22nd day of May, 2007
otary public
My commission expires: ~~ ~v
4352378365956263
A144 PATENAUDE & FELIX, A.P.C "~€'''''~' JANICE 1. LOKEN
~= '~ ~,
3r~~~:~ Notary Public
~•.. ~~, Minnesota
1'~..+' My Cummission Exntres January 3i 2008
Court
Judicial (Circuit/District)
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities, that she is, Tiffany Lewis, Assistant Secretary, of Target National Bank, Plaintiff
Herein, that she is duly authorized to make this Declaration, and hat the facts set forth in the foregoing
Complaint in Civil Action are true and correct to the best of her knowledge, information and belief.
Tiffany Lewis
Authorized Agent of Target National Bank/Target Visa
4352378365956263
A144
PATENAUDE & FELIX, A.P.C
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SHERIFF'S RETURN - REGULAR
CASE N0: 2007-04047 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TARGET NATIONAL BANK
VS
POINT DARLENE R
MEGAN HARLOW
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
POINT DARLENE R
DEFENDANT
at 515 KEVIN CT
the
at 1810:00 HOURS, on the 11th day of July 2007
CAMP HILL, PA 17011-1263
was served upon
by handing to
JAMES SNEED, BOYFRIEND ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 14.40
Affidavit .00
Surcharge 10.00
.00
FI)~~py ~ 42.40
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
07/12/2007
PATENAUDE & FELIX
By:`~j,
-~2 ~-
Deputy Sheriff
A.D.
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
07- 4047
NO. 3
v.
DARLENE R POINT
Defendant(s)
PRAECIPE FOR DEFAULT
JUDGMENT
Filed on behalf of:
TARGET NATIONAL BANK
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_119 Prcp DefJg Both
P&F File No. 2050.16211
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARC7ET NATIONAL BANK
Plaintiff
NO. 04-4047
v.
DARLENE R POINT
Defendant(s)
PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
Please enter a judgment against the defendant, above named, for failure to file an Answer
to Plaintiff s complaint.
Amount claimed in Complaint
Interest from May 15, 2007
Less payments received
Attorney's fees
TOTAL
$4,213.24
$0.00
$0.00
$4,213.24
With continuing interest on the principal amount of $4,213.24, with interest at the legal
rate, plus costs of suit.
I hereby certify that a written notice of intention to file this praecipe was mailed to the
defendants and defendants' counsel (if known), after the default had occurred and at least ten
(10) days prior to the date of the filing of this praecipe. A copy of the Notice is attached.
F~Pix,/A.P.C.
Date:
PA_119 Prcp Def Jg Both
Esquire
213`E. Main ~treet
Carnegie, PA 5106
(412) 429-7675
P&F File No. 2050.16211
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
v.
DARLENE R POINT
Defendant(s)
NO. 04-4047
PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF
NOTICE PURSUANT TO PA.R.C.P. 1037(bl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
Before me, the undersigned authority, a Notary Public in and for said County and State,
personally appeared GREGG MORRIS, attorney for and authorized representative of Plaintiff,
who being duly sworn according to law, deposes and states that the defendant(s), DARLENE R
POINT, is not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that Notice of Intent to take Default Judgment
was mailed in accordance with Pa.R.C.P.237.1, as evidenced by the attached copy.
Feki+~c, A.P.C.
Date:
Sworn to and subscribed before me this
~!'~ day of ~JS J S-~ , 20~.
r`-ti l `.
Notary Public
Gre~ L. orris, Esquire
213 E. in Street
Carnegi , PA 15106
(412) 42 - 675
NOTARIAL SEAL
ERIN N gALTZELI
Notary publ~
C MyECommsOon Exp~esGHENY 2010 N
PA 120 Aff of Non Mil P&F File No. 2050.16211
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
v.
DARLENE R POINT
Defendant(s)
NO. 04-4047
IMPORTANT NOTICE
Filed on behalf of:
TARGET NATIONAL BANK
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Fa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_111 10 Day D1
P&F File No. 2050.16211
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 04-4047
v.
DARLENE R POINT
Defendant(s)
To: Darlene R Point
515 Kevin Ct
Camp Hill Pennsylvania 17011-1263
Date of Notice: August 03, 2007
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 NOTICE TO A 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 MAYBE 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 17013
717-249-3166 .i1
A.P.C.
Date:
~regg L. Mo s, Esquire
213 E. Main reet
Carnegie, PA 15106
(412) 429-7675
PA_111 10 Day Dl P&F File No. 2050.16211
I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK/TARGET VISA ,
hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail
upon the following:
Darlene R Point
Defendant
515 Kevin Ct
Camp Hill PA 17011-1263
Date:
PA_111 l0 Day D1 P&F File No. 2050.16211
Carnegie, PA 15106
(412) 429-7675
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 04-4047
v.
DARLENE R POINT
Defendant(s)
NOTICE OF ORDER, DECREE
OR JUDGMENT
Filed on behalf of:
TARGET NATIONAL BANK
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_123 Ntc Jgmt Both P&F File No. 2050.16211
w
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
v.
DARLENE R POINT
Defendant(s)
NO. 04-4047
NOTICE OF ORDER, DECREE OR JUDGMENT
AGAINST DARLENE R POINT ONLY
TO: ( )Plaintiff (x )Defendant ( )Garnishee ( )Additional Defendant
You are hereby notified that the following Order, Decree, or Judgment has been entered
against you on _ g~~~p-7
( )Decree Nisi in Equity
( )Final Decree in Equity
(X) Judgment of ( )Confession ( )Verdict ( )Court Order
(X) Default ( )Non-suit
( )Non-Pros ( )Arbitration Award
(X) Judgment in the amount of 4 213.24, plus costs.
( )District Justice Transcript of Judgment in the amount of $ ,
plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be
suspended by the Department of Transportation.
Prothonotary
By a
Deputy
If you have questions concerning the above, please Contact:
Name of Attorney: GREGG MORRIS, Esquire
213 East Main St
Carnegie PA 15106
(412)-429-7675
P&F File No. 2050.16211
PA_123 Ntc Jgmt Both
i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
v.
DARLENE R POINT
Defendant(s)
BELCO COMMUNITY CREDIT UNION
Garnishee
07- 404 7
NO.
PRAECIPE FOR WRIT OF
EXECUTION
Filed on behalf of:
TARGET NATIONAL BANK
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_134 Prcp Writ of Exe
P&F File No. 2050.16211
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
v.
DARLENE R POINT
Defendant(s)
BELCO COMMUNITY CREDIT UNION
Garnishee
To The Prothonotary:
NO. 04-4047
PRAECIPE FOR WRIT OF EXECUTION
Issue writ of execution in the above matter,
(1) directed to the Sheriff of Cumberland County;
(2) against, DARLENE R POINT Defendant(s); , 5t 5 Kevin (~, ~.arn.p f{; tl , p A i~o tt
(3) against, BELCO COMMUNITY CREDIT UNION, Garnishee; ~ 3soo Tr-rd le IZd
tamp N; ll , P A t'tOt 1
(4) and index this writ
(a) against, Defendant(s) DARLENE R POINT, Defendant(s); and
(b) against BELCO COMMUNITY CREDIT UNION, Garnishee;
as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows:
(5) Amount due
Interest from August 17, 2007
At 5.00 % per annum
(Costs to be added)
PA_134 Prcp Writ of Exe
$4,213.24
$254.55
P&F File No. 2050.16211
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4047 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s)
From DARLENE R. POINT, 515 Kevin Ct., Camp Hill, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
BELCO COMMUNITY CREDIT UNION, 3500 Trindle Road, Camp Hill, PA 17011
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $4,213.24
L.L. $.50
Interest from 8/17/07 at 5.00 % per annum -- $254.55
Atty's Comm % Due Prothy $2.00
Atty Paid $161.90
Plaintiff Paid
Other Costs to be added
Date: 11/17/08
(Seal)
REQUESTING PARTY:
Name GREGG L. MORRIS, ESQUIRE
Address: PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
Attorney for: PLAINTIFF
Telephone: 412-429-7675
Supreme Court ID No. 69006
s
urti R. Long, Prothonota
By:
Deputy
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-04047 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
TARGET NATIONAL BANK
VS
POINT DARLENE R
And now MARK CONKLIN
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0016:50 Hours, on the 18th day of November 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
POINT DARLENE R
hands, possession, or control of the within named Garnishee
BELCO COMMUNITY CREDIT UNION 3500 TRINDLE ROAD
CAMP HILL, PA 17011
Cumberland County, Pennsylvania, by handing to
REBEKAH NICHOLSON (ASST. MANAGER
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscribed to
before me this
in the
true
and made
So answers:
.00
.00
.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.0000 /~a-~or/o P
11/18/2008
~
~ r
day of By
Depu y eriff
A.D
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
~7
NO. l~-4047
v.
DARLENE R POINT
Defendant(s)
BELCO COMMUNITY CU
Garnishee
PRAECIPE TO
DISCONTINUE WITHOUT
PREJUDICE AS TO
GARNISHEE ONLY
Filed on behalf of:
TARGET NATIONAL BANK
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_170 Prcp Disc w/o Prjdc
P&F File No. 2050.16211
•
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
D~-
NO. 94-4047
v.
DARLENE R POINT
Defendant(s)
BELCO COMMUNITY CU
Garnishee
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY
TO: Prothonotary
Please discontinue the matter captioned above without prejudice as to Garnishee only.
Thank you.
Date: December 15, 2008
Sworn to and subscribed before me this
1,'~day of ~~Q. , 20c~
Notary Pu lic
COMMONWEALTH OF PENNSYLVANIA
N Seal
Cardyn J. Sle~rart, Notary Public
~ne~e Moro, AJleghenY CouMY
My Commifssbn E>~kes Aug.14, 2011
Member, Pennsylvenla Association of Notaries
Respectfully ub d:
Patenaud~ elix, .P.C.
Greg . Mo ,Esquire
21 E Main ~ reet
C ie, PA 15106
( 12) -7675
PA_170 Prcp Disc w/o Prjdc P&F File No. 2050.16211
I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK ,hereby
certify that a true and correct copy of foregoing document was served. this date by ordinary mail
upon the following:
BELCO COMMUNITY CU
3500 TRINDLE RD
CAMP HILL, PA 17011
Date: December 15, 2008
Gregg L o ' ,Esquire
Patena de elix, A.P.C.
213E Ma' Street
Carn gie, A 15106
(41 429-7675
PA_170 Prcp Disc w/o Prjdc P&F File No. 2050.16211
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4.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff s Costs:
Docketing
Poundage
Law Library
Prothonotary
Mileage
Surcharge
Levy
Postage
Garnishee
18.00
1.89
.50
2.00
14.00
30.00
20.00
.88
9.00
96.27
Advance Costs: 150.00
Sheriff s Costs: 96.27
53.73
Refunded on 05/27/09
So Answers,
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baron R. Lantz
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WRIT OF EXECUTION and/or ATTACHMENT
e'
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4047 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s)
From DARLENE R. POINT, 515 Kevin Ct., Camp Hill, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
BELCO COMMUNITY CREDIT UNION, 3500 Trindle Road, Camp Hill, PA 17011
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $4,213.24
L.L. $.50
Interest from 8/17/07 at 5.00 % per annum -- $254.55
Atty's Comm % Due Prothy $2.00
Atty Paid $161.90
Plaintiff Paid
Other Costs to be added
Date: 11/17/08
(Seal)
REQUESTING PARTY:
Name GREGG L. MORRIS, ESQUIRE
Address: PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
Attorney for: PLAINTIFF
Telephone: 412-429-7675
By:
Deputy
Supreme Court ID No. 69006