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Home My WebLink About07-4163GREGG 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. ANDREA S ORNER A/K/A ANDREA S STUMPO, Defendant(s). ~ NO. ~7 - '`H~3 Civi I ~CI'M 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. ANDREA S ORNER A/K/A ANDREA S STUMPO, 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. 07- y JG 3 ~ / Cw- v. ANDREA S ORNER A/K/A ANDREA S STUMPO, 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 ANDREA S ORNER A/K/A ANDREA S STUMPO, an adult individual, believed to currently reside at 16B W GLENWOOD DR ,CAMP HILL, PA 17011. 3. Heretofore, the Defendant opened a TARGET NATIONAL BANK account with Plaintiff being Account No. 4352375045833425 ,for the purchase of goods and services. 4. The Defendant has made or authorized a number of purchases and as of 05/22/07, Defendant owes $3,734.95 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 $3,734.95, plus interest and costs. 8. 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 $3,734.95, 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: Fe)~x, A.P.C. 213 E. Nfain Street Carnegie, PA 15106 (412) 429-7675 • TARGET ~~~III(~~IA~~ =ooooo= Account Number: 4352-3750583-3425 Statement Closing Date: May 18, 2007 ANDREA S ORNER Page 1 of 2 Target Visa Account Summary Total Credit Limit $0 Previous Balance $3,699.95 Cash Limit $0 Payments & Credits 0.00 Available Credit $0 Purchases 8 Advances 0.00 Portion Available for Cash $0 Other Charges 35.00 The Cash Limit is a portion of the Total Credit Limit FINANCE CHARGES 0.00 Questions? Call Us: New Balance $3,734.95 Amount Past Due $861.49 Target Credit Services 1-888-755-5856 TDD/TDY 1-800-347-5842 Outside the U.S. 11-612-307-8622 (Call Collect) Calling will not preserve yourbilling-errorrights Minimum Payment Due $3,734.95 includes any Amount Past Due) Payment Due Date June 12, 2007 Payments & Credits No payments or credits were received last month. Other Charges May 13 LATE PAYMENT FEE sss o0 Total Other Charges $35.00 Target National Benk, en efAliek ofTerget Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION _. INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK • TARGET. I~~~~I~I~~~~~~~I~I~~~~~~~~~R~~~~~I NEW PHONE,HOME OR IIII'IIIIIII'IIIIIIII'IIIIIIIIIIIIIIIIIIII111'lll E-MAIL ADDRESS? PLEASE ul=oATE ON TARGET NATIONAL BANK REVERSE SIDE. P.O. BOX 59317 OFFICE COPY MINNEAPOLIS, MN 55459-0317 STATEMENT PAGE NOT PRINTED ANDREA S ORNER 16B W GLENWOOD DR CAMP HILL, PA 17011 ~~ it / ~ .L "~ ''' u Account Number 4352-3750583-3425 New Balance $3,734.95 Minimum Payment Due $3,734.95 Payment Due Date June 12, 2007 Amount Enclosed $ 3000800373495037349590435237504583342571 TARGET ~~V~VN~~~Y~I Account Number: 4352-3750583-3425 Statement Closing Date: May 1s, 2007 ANDREA S ORNER 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 0.06821% 24.90% % $0.00 $0.00 00 00 $0 $0 $0.00 $0.00 Cash 0.06821% 24.90 . . Total FINANCE CHARGES: $0.00 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 »s~o2az In Court Judicial (Circuit/District) Original Creditor Name: TARGET NATIONAL BANK Debtor Name: ORNER, ANDREA S Co-Debtor Name: Account Number: 4352375045833425 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 $3734.95. 3. 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. Authori d of GET NATIONAL BANK Subscribed and sworn to before Me on 29th day of May, 2007 i~ otary public My commission expires: ~ 3/ ~ a - .r JANICE L LQKEN 4352375045833425 ,~ Notary Public A144 PATENAUDE & FELIX, A.P.C '~innesota ~~~ 4Pm~'iSSion Expires January 31.2005 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. C 1 Ti any Authorized Agent of Target National Bank/Target Visa 4352375045833425 A144 PATENAUDE & FELIX, A.P.C '~°; - - .> _ L Vl O , ~ C,_. ~' ~ ---1 ~~~ ' ~ ~ _ -, , ro b --r ~ _''~, ', ' D - _- iv ` ~ ~ 5 ~"~ ; rZ - - ::{ ts-i 0 SHERIFF'S RETURN - REGULAR CASE NO: 2007-04163 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TARGET NATIONAL BANK VS ORNER ANDREA S ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ORNER ANDREA S A/K/A STUMPO ANDREA S the DEFENDANT at 1308:00 HOURS, on the 18th day of July 2007 at 1tiS W GLENWOOD DRIVE CAMP HILL, PA 17011 by handing to ANDREA ORNER 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 Service Affidavit Surcharge F~~~/~? Sworn and Subscibed to before me this of So Answers: 18.00 ~/' 14.4 0 ~i'~r~ii'~~~ /~a~ . 0 0 ~I 10.00 R. Thomas Kline .00 42.40 07/19/2007 PATENAUDE & F IX By: day Deputy Sheriff ~~ A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4163 v. ANDREA S ORNER Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa LD. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_ 119 Prcp Def Jg Both PBcF File No. 2050.16347 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, • PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4163 v. ANDREA S ORNER 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 Plaintiffs complaint. Amount claimed in Complaint Interest from May 22, 2007 Less payments received Attorney's fees TOTAL $3,734.95 $0.00 $0.00 $3,734.95 With continuing interest on the principal amount of $3,734.95, 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 Notip~e is attached. ix, A.P.C. Date: Gre orris, Esquire 21 E. Ma n Street arnegie, A 15106 (412) 429 7675 PA_ 119 Prop Def Jg Both P&F File No. 2050.16347 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, • PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4163 v. ANDREA S ORNER Defendant(s) PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA.R.C.P. 10371b1 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 defendants}, ANDREA S ORNER, 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. y submitted: Felix, A.P.C. Date: K'rre L. Morris, Esquire 213 .Main Street egie. PA 15106 (412) 429-7675 Sworn to and subscribed before me this -~ day of A-~J~~ , 20f~ . / Y{ Notary Public NOTARIAL SEAL ERIN N BALTZELL Notary Public CAkNEG1E BOROUGH, ALLEGHENY COUNTY MY Commisslon Expires Jul 21, 2010 PA 120 Aff of Non Mil P&F File No. 2050.16347 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4163 v. ANDREA S ORNER 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 1 l ]0 Day Dl PBcF File No. 2050.16347 '{ ;i 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff v. ANDREA S ORNER Defendant(s) To: Andrea S Orner 16B W Glenwood Dr Camp Hill Pennsylvania 17011 Date of Notice: August 08, 2007 NO. 07-4163 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 HIlZING 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 J1., A.P.C. Date: ~g L. ms, Esquire E. Main tree arnegie, PA 15106 (412) 429-7675 PA_] 11 10 Day DI P&F File No. 2050.16347 I, GREGG MO~tRIS, 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: Andrea S Orner Defendant 16B W Glenwood Dr Camp Hill PA 17011 Date: Gre . Mo 's, Esquire Pat aude Felix, A.P.C. E. Mai Street Carnegie, P 15106 (412)429-76 5 PA_l l l 10 Day Dl P&F File No. 2050.16347 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 07-4163 v. ANDREA S ORNER .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. 2050.16347 -fir ~'? ;~,< a ~ ~: $ s '~ o g ~ o a - ~. t ; ~~%' na a c_ c~ rv N C> -n n ~'' r- ~_~ .`;~ `y.~ l~ .-,.r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff v. ANDREA S ORNER Defendant(s) NO. 07-4163 NOTICE OF ORDER DECREE OR JUDGMENT AGAINST ANDREA S ORDER 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 9/~~~m7 ( )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 3 4. ,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 n 5 - Deputy 'AKd 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. 2050.16347