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Home My WebLink About07-4162 GREGG L. MORRIS, ESQ. PATENAUDE & FELIX, A.P.C. 213 E. MAIN STREET CARNEGIE, PA 15106 (412) 429-7675 FACSIMILE (412) 429-7679 PAID #69006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) ) No. 07 - ~il~a Plaintiff ) v. ) ANGELA R TROUT, ) Defendant ) ~~~< < ~~ 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 ) NO. Plaintiff ) v. ) ANGELA R TROUT, ) 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 maybe 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) v. ) ANGELA R TROUT, ) Defendant ) NO. D 7 - HlG a Cun.~ ~.c~.., 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 Angela R Trout , an adult individual, believed to currently reside at 487 Nursery Dr, Mechanicsburg, PA 17055. 3. Heretofore, the Defendant opened a Target National Bank account with Plaintiff being Account No.4352376689210870, for the purchase of goods and services. 4. The Defendant has made or authorized a number of purchases and as of 04/24/07, Defendant owes $9,514.50 on said account plus interest. 5. Plaintiff maintains accurate books of account recording all credits and debts 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. 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 $9,514.50, plus interest and costs. By failing to object or dispute to the statements including the statement attached hereto as Plaintiff s 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 $9,514.50 ,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: o ~u~a~~~1~~ Account Number: 43523766-8921-0870 Statement Closing Date: April 21, 2007 ANGELA R TROUT Page 1 of 2 Target Visa Account Summary Total Credit Limit $0 Previous Balance $9,479.50 Cash Limit $0 Payments & Credits 0.00 Available Credit $0 Purchases & Advances 0.00 Portion Available for Cash $0 Other Charges 35.00 The Cash Limit is a portion of the Total Credit Limit FfNANCE CHARGES 0.00 Questions? Call Us: Target Credit Services 1-888-755-5856 TDDlTDY 1-800-347-5842 Outside the U.S. 11-612-307-8622 (Call Collect) Calling will not preserve your billing-errorrights New Balance $9,514.50 Amount Past Due $1,757.13 Minimum Payment Due $9,514.50 (includes angAmount Past Due) Payment Due Date May 16, 2007 Payments ~ Credits No payments or credits were received last month. Other Charges Apr. 15 LATE PAYMENT FEE $35.00 Total Other Charges $35.00 I Tsrget Natlonsl Bsnk, en efiiisle of Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION • TARGET. I NEW PHONE, HOME OR E-MAIL ADDRESS? PLEASE UPDATE ON REVERSE SIDE. OFFICE COPY ~ STATEMENT PAGE NOT PRINTED INCLUDE THI5 PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK Account Number 4352-3766-8921-0870 New Balance $9,514.50 Minimum Payment Due $9,514.50 Payment Due Date May 16, 2007 II'II11'lilt'llltll'1'1I11I~1IIIIIIIIIIII~IIIIIIIIII TARGET NATIONAL BANK P.O. BOX 59317 MINNEAPOLIS, MN 55459-0317 Amount Enclosed $ ANGELA R TROUT 487 NURSERY DR N MECHANICSBURG, PA 17055-7017 / 'llt'1I111I'11111I1111'Illltll l'~111111'I'111II11~1IIIIIIIII'~ ~X/~~~/~~ r. ~ ~ 000140D951450095145090435237668921087071 o i~~u~u~~uw~ Account Number: 4352-3766-8921-0870 Statement Closing Date: April 21, 2007 ANGELA R TROUT Page 2 of 2 Finance Charges Days in Billing Period: 31 Corresponding Average Periodic Transaction Daily Annual Daily FINANCE FINANCE - Balance Type Periodic Rate Percentage Rate Balance CHARGE CHARGE Purchases 0.06821% 24.90% $0.00 50.00 50.00 Cash 0.06821% 24.90°,6 $0.00 $0.00 50.00 Total FINANCE CHARGES: $0.00 Actual ANNUAL PERCENTAGE RATE: 0.00% There is a minimum FINANCE CHARGE of 51.00 for any billing period in which a Finance Charge is imposed. 14554693 In Court Judicial (Circuit/District) Original Creditor Name: TARGET NATIONAL BANK Debtor Name: TROUT, ANGELA R Co-Debtor Name: Account Number: 4352376689210870 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 $9514.50. 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 l / records of TARGET NATIONAL BANK. Authorized A~~t ~ARGET NATIONAL BANK Subscribed and sworn to before Me on 1st day of May, 2007 ' ary public My commission expires: / ~~~~ 4352376689210870 JANICE L LOKEN A144 PATENAUDE & FELIX, A.P.C ~ i~ Notary Public Minnesota A?Y Cnmmtssion Expires January 31.2009 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. ~- r Ti y Le 's Authorized nt get National Bank/Target Visa 4352376689210870 A144 PATENAUDE & FELIX, A.P.C .~, t"? J ~~ ~~ ~ W ~ Q `r' ~ ; iw J< 7 ~_ ~~, .. ~::~ _~` :~ cap z c ~ "~ SHERIFF'S RETURN - REGULAR CASE N0: 2007-04162 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TARGET NATIONAL BANK VS TROUT ANGELA R ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE TROUT ANGELA R DEFENDANT was served upon the at 1240:00 HOURS, on the 19th day of July 2007 at 487 NURSERY DRIVE MECHANICSBURG, PA 17055 by handing to ZODA LAUER MOTHER 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: Docketing 18.00 Service 11.52 Affidavit .00 Surcharge 10.00 .00 fjt4~b`! ~ 39.52 Sworn and Subscibed to before me this day of , So Answers : .~~ !• R. Thomas Kline 07/20/2007 PATENAUDE & FELIX By: Deputy Sheri A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4162 v. ANGELA R TROUT 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 Def Jg Both P&F File No. 2050.15999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/ Plaintiff v. ANGELA R TROUT Defendant(s) TO: PROTHONOTARY PI AiNTIFF'5 PRAECIPE FOR DEFAULT JUDGMENT 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 Apri124, 2007 Less payments received Attorney's fees TOTAL NO. 07-4162 $9,514.50 $0.00 $0.00 $9,514.50 With continuing interest on the principal amount of $9,514.50, 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. A.P.C. Date: PA_ 119 Prcp Def Jg Both e g L. rris, Esquire 2 E. Ma' Street Carnegie, 15106 (412) 429-76 5 PBcF File No. 2050.15999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff v. ANGELA R TROUT Defendant(s) NO. 07-4162 PLAINTIFF'S AFFIDAVIT OF NON-MILIT RY 4FRVif F AN ALINE OF NOTICE PURSUANT TO PA R C P 1037(bl COMMONWEALTH OF PENNSYLVANIA COUNTY OF BUCKS 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), ANGELA R TROUT, 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, asevidenced by the attached copy. Pat~rl~u~e~Xc F»~Iix,iA.P.C. Date: Sworn to and subscribed before me this day of ~a~, 2f~~ . v ~ ~~ Notary Public ~~ egg >5~r1VIo s, Esquire 13 E. Main treet Carnegie, P 1 S 106 (412) 429-76 NOTAR'~ ERIN N BJU.1ZEu Notary Public CAftNEG1E gOROUfiH. p,~~EGHENY COUNTY MY Commission ExpUes Jul 21, 2010 PA_120 Aff of Non Mil P&F File No. 2050.15999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4162 v. ANGELA R TROUT Defendant(s) IMPORTANT NOTICE 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_l 11 10 Day Dl PBcF File No. 2050.15999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4162 v. ANGELA R TROUT Defendant(s) To: Angela R Trout 487 Nursery Dr N Mechanicsburg Pennsylvania 17055-7017 Date of Notice: August 09, 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 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. Cumberland County Bar Association 32 South Bedford Street Carlisle PA 17013 717-249-3166 Respectfully submitted: Date: PA_] 11 10 Day Dl PBcF File No. 2050.15999 Carnegie, PA 15106 (412) 429-7675 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: Jeff Yoffee, ESQ. Attorney for Angela R Trout Date: Gregg L. Mb ids, Esquire Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_l l l 10 Day Dl PBcF File No. 2050.15999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4162 v. ANGELA R TROUT Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: 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_123 Ntc Jgmt Both P&F File No. 2050.15999 ~r ~p O a -+ ~ r -.c3, Y "~' ~' '~ ~ 'L. ~. I~ { ~ ` ~ ~` '\4y :2„lr' ~, ~ rr~ ^4 `:a ~ [~ ~~ ~~ I~ R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff v. ANGELA R TROUT Defendant(s) NO. 07-4162 NOTICE O~ ORDER, DECREE OR JUDGMENT AGAINST ANGELA R TROUT 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 _~A7 ~ ~-~ ( )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 ~Q,,S 14.50, 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 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 PA_123 Ntc Jgmt Both P&F File No. 2050.15999 v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. TARGET NATIONAL BANK ANGELA R TROUT Defendant(s) NO. 07-4162 PRAECIPE TO STRIKE JUDGEMENT Filed on behalf of: 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_147 Prcp Sat Jg PBcF File No. 2050.15999 ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff v. ANGELA R TROUT Defendant(s) NO. 07-4162 PRAFCIPE TO STIZI~ .1im~FlvrFNT TO: Prothonotary Please strike the judgement that was entered on or about August 27, 2007 in the matter captioned above. Thank you. submitted: ~elix, A.P.C. Date: ~13 E ~Glain Stree arnegie, PA 151 (412) 429-7675 Sworn to and subscribed before me this 1 day of , 20~. ~ ~ r~~ Notary Public PA_170 Prcp Disc w/o Prjdc t~'.;;~.RLA; SEAL Ewr+ N 4~.AtTZELI Nr,r::rd Public ,~,,~,.;-nor P,^'; ;+.>' ~, ALLEGHENYC~UNN p , .ns Jul 2l, 2G10 ~,~ .~ PBcF File No. 2050.15999 1 r S I, Gregg L. Morns, 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: Date: Jeff Yoffee, Esq. 214 Senate Ave. Suite 404 Camphill, PA 1 egg L. orris, Esquire atenaud & Felix, APC Attorney or Plaintiff 213 E. M in Street Carnegie, PiA 15106 (412)429-7675 p ~ a ~ ~ 0 ~ ~*w, C,' sa W 'O ~, ~~~., vo .,, ~ ~ r ~ b ca N w