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Home My WebLink About07-4049GREGG 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff, v. ELLEN J SKILL , 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. 07- 'i'D y9 ~~ ~~`""` v. ELLEN J SKILL , 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, TffiS 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. O ~ - yb `~ 4 ~-cerc.Y ~,2.~.--- v. ELLEN J SKILL , 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 ELLEN J SKILL , an adult individual, believed to currently reside at 6 HAZELWOOD CT , MECHANICSBURG, PA 170507963. 3. Heretofore, the Defendant opened a TARGET NATIONAL BANK account with Plaintiff being Account No. 4352376700474703 ,for the purchase of goods and services. 4. The Defendant has made or authorized a number of purchases and as of 11/21/06, Defendant owes $6,175.43 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 $6,175.43, plus interest and costs. 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 $6,175.43, 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. Respectfully Submitted: & Felix A.P.C. ~'~3 E. Main Street arnegie, PA 15106 (412) 429-7675 O IINIII~1~1~~~ Account Number: 4352-3767-0047703 Statement Closing Date: May 18, 2007 ELLEN J SKILL Page 1 of 1 Target Visa Account Summary Total Credit Limit $0 Previous Balance $6,175.43 Cash Limit $0 Payments & Credits 0.00 Available Credit $0 Purchases & Advances 0.00 Portion Available for Cash $0 Other Charges 0.00 FINANCE CHARGES 0.00 The Cash Limit is a portion of the Total Credit Limit New Balance 56,175.43 QU@St1on5? Cell Us: Target Credit Services 1-888-755-5856 TDDITDY 1-800-347-5842 Outside the U.S. 11-612-307-8622 (Call Collect) Calling will not preserve your billing-errorrights Amount Past Due Minimum Payment Due includes an Amount Past Due) ( y Payment Due Date 56,175.43 56,175.43 June 12, 2007 Payments 8~ Credits No payments or credits were received last month. 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 0.00000% 0.00% $0.00 S0.00 00 00 50 00% $0 30.00 30.00 Cash 0.00000% . . 0. Total FINANCE CHARGES: 30.00 Actual ANNUAL PERCENTAGE RATE: 0.00°k There is a minimum FINANCE CHARGE of 51.00 for any billing period in which a Finance Charge is imposed Target Netionel Benk, en efiliete of Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK Account Number 4352-3767-0047-4703 I~~M~~I~r~~~~~~~I~~~~~~N~~~~~~~~~~1 Mi vmum Payment Due $6,175.43 TARGET Payment Due Date June 12, 2007 NEW PHONE, HOME OR E-MAIL ADDRESS? PLEASE UPDATE ON REVERSE SIDE. OFFICE COPY STATEMENT PAGE NOT PRINTED ~~~rf~~~~~~~~~n~~~~~~~~~n~~u~n~~~n~~~~~~~~~n~~~ TARGET NATIONAL BANK P.O. BOX 59317 MINNEAPOLIS, MN 55459-0317 ELLEN J SKILL 6 HAZELWOOD CT MECHANICSBURG, PA 17050-7963 i,,, i n...iii,,,, i, i, i i,,, i,,, i i, i,,, i i,,,, i i, n.... i i,,, n„i 7001000617543061754390435237670047470371 Amount Enclosed $ rt ,~ aoso, ~ 3 7oz~ In Court Judicial (Circuit/District) Original Creditor Name: TARGET NATIONAL BANK Debtor Name: SKILL, ELLEN J Co-Debtor Name: Account Number: 4352376700474703 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. 2. 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 $6175.43. 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. \- Auth 'z gent GET NATIONAL BANK Subscribed and sworn to before Me on 28th day of November, 2006 Notary public / J My commission expires: I/~ ~ ` ~~ O o 4352376700474703 A144 PATENAUDE & FELIX, A.P.C MARGARET L OLSEN :~ Notary Public Minnesota ~' My Commission Expires January 37 21108 .~3~~~ ~~ The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom 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 ew Authorized Agent of Target National Bank/Target Visa 4352376700474703 A144 PATENAUDE & FELIX, A.P.C C"~ r-- ^' ~ Q < ' --~ 7^i ~, ~ ~ 1 -~ ~ ~ ~ OO w'~ . u -r-~ r~ -~~c _~ ~ : , r ~ ~ -;~ CJ ~ ' ~ =' -O -a d 'G G , a - - ~' Y E s :i rn 0o -~, - ~~ . ~ :~ ~.c~ --c -C C SHERIFF'S RETURN - REGULAR CASE NO: 2007-04049 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TARGET NATIONAL BANK VS SKILL ELLEN J MEGAN HARLOW Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SKILL ELLEN J the DEFENDANT at 1913:00 HOURS, on the 13th day of July 2007 at 6 HAZELWOOD CT MECHANICSBURG, PA 17050-7963 by handing to ELLEN SKILL a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service 18.00 8.64 Affidavit .00 ~ ~~ ,~=~-~ Surcharge 10.00 R. Thomas Kline `e~l3~bl ~ „-~ .00 36.64 07/16/2007 PATENAUDE & FELIX Sworn and Subscibed to By: ~ before me this day e uty S heriff of A.D. .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4049 v. ELLEN J SKILL Defendant(s) PRAECIPE TO DISCONTINUE WITH PREJUDICE Filed on behalf o£ TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morns, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_169 Prcp Disc with Prjdc P&F File No. 2050.13700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ,~ PENNSYLVANIA Plaintiff v. TARGET NATIONAL BANK ELLEN J SKILL Defendant(s) NO. 07-4049 PRAECIPE TO DISCONTINUE WITH PREJUDICE TO: Prothonotary Please discontinue the matter captioned above with prejudice. Thank you. Feli1C, A.P.C. Date: rris, Esquire 3 E. Ma' Street Carnegie, A 15106 (412) 429- 75 Sworn to and subscribed before me this ~.~ day of ~~5~, , 20~. _ ~~ Notary Public PA_169 Prcp Disc with Prjdc NOTARIAL SEAL ERIN N BALTZELL Notary Pubilc ~AkNEGIE BOROUGH, ALLEGHENY COUNTY ~, ~nmmiss(on Expires Jul 21, 2010 P&F File No. 2050.13700 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: Ellen J Skill Defendant 6 Hazelwood Ct Mechanicsburg PA 17050-7963 Date: PA_169 Prcp Disc with Prjdc Pat ude & Felix, A.P.C. 3 E. Main Street Carnegie, PA 15106 (412) 429-7675 P&F File No. 2050.13700 ~'~ ~ ~`~ :cx• ^I r 3 ~ . _ _^ i fw) _ , :1.! _ ....~ ~ : t... -~ t~r't .. _--i [~.) a ~