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Home My WebLink About08-4507IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. d f - VV 7 ? /l , V. SERENA CABAN Defendant(s) COMPLAINT IN CIVIL ACTION Filed on behalf of: TARGET NATIONAL BANK/TARGET VISA 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 PF_PA_I I Cmplt Cvr Sht P&F File No. 08-37544 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. SERENA CABAN Defendant(s) 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 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. NO. Usted ha sido demandado en corte. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted fall de tomar accion como se describe anteriormente, el caso pude proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad au otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSO A PERSONAS QUE CALIFICAN. 1amle/ /GWMI Ser?r1 Cw' eurn4e4and (7m?l 3a Shed S AdWe. P-1 I PA-2 I Notice to Defend P&F File No. 08-37544 L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. SERENA CABAN Defendant(s) COMPLAINT CIVIL ACTION NO. 09- YS 0'7 Cux.( 7" AND NOW, comes Plaintiff, TARGET NATIONAL BANK/TARGET VISA, by and through its attorney, GREGG 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/TARGET VISA, 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 St Carnegie, Pennsylvania 15106. 2. Defendant is SERENA CABALA, an adult individual, believed to currently reside at 54 MONARCH DR CARLISLE, PA 17015-7311. 3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No. 4352375047136660, for the purchase of good and services. 4. The Defendant(s) has/have made or authorized a number of purchases and as of , Defendant(s) owes $11,228.15 on said account plus interest at 0.00 %. 5. Plaintiff maintains accurate books of account recording all credits and debits for PA-05 Civil Cmplt Crdt Crd P&F File No. 08-37544 this account. 6. The Defendant(s) have/has received monthly billing statements from Plaintiff setting forth the nature and amount of all charges made by Defendant(s), and the transactions between Plaintiff and Defendant(s) give rise to an account stated, upon which Plaintiff has relied. 7. The Defendant(s) made payments, but have/has refused to pay, and now refuses to pay the balance due and owing on the aforesaid account in the sum of $11,228.15, plus interest and costs. 8. By failing to object or dispute the statements, Defendant(s) have/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(s) have/has failed to make the required installment payments when due and therefore the full amount of the account is now due and payable. PA-05 Civil Cmplt Crdt Crd P&F File No. 08-37544 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $11,228.15, plus interest as set forth herein 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. Date: June 19, 2008 -! Morris, Esquire 3 E. Main Street arnegie, PA 15106 (412) 429-7675 PA-05 Civil Cmplt Crdt Crd P&F File No. 08-37544 *00000* Account Number: 4352-3750-4713-6660 Statement Closing Date: May 22, 2008 SERENA M CABAN Page 1 of 1 Target Visa Credit Card 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 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 your billing-error rights Previous Balance $11,228.15 Payments & Credits 0.00 Purchases & Advances 0.00 Other Charges 0.00 FINANCE CHARGES 0.00 New Balance $11,228.15 Amount Past Due $1,008.52 Minimum Payment Due $1,121.52 (includes any Amount Past Due) Payment Due Date June 16, 2008 Payments 81 Credits No payments or credits were received last month. Finance Charges Days in Billing Period: 30 Balance Type Purchases Cash Corresponding Daily Annual Periodic Rate Percentage Rate 0.00000% 0.00% 0.00000% 0.00% Average Periodic Daily FINANCE Balance CHARGE $0.00 $0.00 $0.00 $0.00 Total FINANCE CHARGES Actual ANNUAL PERCENTAGE RATE Transaction FINANCE CHARGE $0.00 $0.00 $0.00 0.00% There is a minimum FINANCE CHARGE of $1.00 for any billing period in which a Finance Charge is imposed. Target National Bank, an affiliate of Terget Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK Account Number 4352-3750-4713-6660 New Balance $ TARGEI? Minimum Payment Due $1,1211.52 Payment Due Date June 16, 2008 NEW PHONE, HOME OR 'Ifl'111'IIIIIIIIIIIIIIIII'lllll"I111'?'llllllll'I Amount E-MAIL ADDRESS? Enclosed $ 71 PLEASE UPDATE ON TARGET NATIONAL BANK . REVERSE SIDE. P.O. BOX 59317 OFFICE COPY MINNEAPOLIS, MN 55459-0317 SERENA M CABAN 54 MONARCH DR CARLISLE, PA 17015-7311 ?III?II111'II111111??1'IIIIIIIIIIIIIIIII'lll??l?llll?lllllllll 2001410112152112281590435237504 A366 071 In Original Creditor Name: TARGET NATIONAL BANK Debtor Name: CABALA, SERENA M Co-Debtor Name: Account Number: 4352375047136660 AFFIDAVIT OF ACCOUNT STATE OF MINNESOTA COUNTY OF HENNEPIN ss: The undersigned, ADAM GRIM 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 $11228.15. 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 GET I AL BANK. Authorized Agent of TARGET NATIONAL BANK Subscribed and sworn to before Me on 3rd day of June, 2008 ary Public 7 My commission expires: 4352375047136660 ' ANICE L. LOKEN A144 PATENAUDE & FELIX, A.P.C - 40TARY PUBLIC-MINNESOTA W, (;0MM wn Exp es Jan. 31, 2013 r 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 he is, ADAM GRIM, Assistant Secretary, of Target National Bank, Plaintiff Herein, that he is dilly authorized to make this Declaration, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his knowledge, information and belief. ADAM GRIM Authorized Agent of Target National Bank/Target Visa 4352375047136660 A144 PATENAUDE & FELIX, A.P.C v ? co r : `- s Q SHERIFF'S RETURN - REGULAR CASE NO: 2008-04507 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TARGET NATIONAL BANK VS CABAN SERENA WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE CABAN SERENA DEFENDANT was served upon the at 1311:00 HOURS, on the 26th day of August , 2008 at 54 MONARCH DRIVE CARLISLE, PA 17015 SERENA (CABAN) OWENS by handing to 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 5.00 Affidavit .00 Surcharge 10.00 .00 R )o a/0 ' 3 3. 0 0 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/27/2008 PATENAUDE'& FELIX By: Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 08-4507 V. SERENA CABAN 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. 08-37544 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. SERENA CABAN Defendant(s) NO. 08-4507 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 $11,228.15 Interest from $0.00 Less payments received $0.00 Attorney's fees $0.00 TOTAL $11,228.15 With continuing interest on the principal amount of $11,228.15, 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. Respectfully Date: September 29, 2008 Patenaude gFelik A.P.C. regg L. orris, Esquire 1 E. ain Street ClmCgie, PA 15106 (412) 429-7675 PA_119 Prep Def Jg Both P&F File No. 08-37544 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. SERENA CABAN Defendant(s) NO. 08-4507 PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA R.C P 1037(bl COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) 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), SERENA CABAN, 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. Respectfully Date: September 29, 2008 Sworn to and subscribed e ore me this day of 2Oc.O. Notary Public Notuial 9"l Carolyn I Stec art, Notary PUAc COM099 Sm, AU%ftny County My CommMion E)Orw Aug. 14, 2011 Patenaude h Felix. A.P.C. fre L. orris, Esquire Vg41 ain Stre et , PA 15106 -7675 5 9 - --- ----l v1 i.eianes P&F File No. 08-37544 PA-1 20 Aff of Non Mil IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 08-4507 V. SERENA CABAN 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_111 10 Day Dl P&F File No. 08-37544 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 08-4507 V. SERENA CABAN Defendant(s) To: Serena Caban 54 Monarch Dr Carlisle Pennsylvania 17015-7311 Date of Notice: October 3, 2008 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 LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET, CARLISLE PA 17013 717) 249-3166 or(800)990-9108 Respectfu ubmitted: Patena a Felix, A.P.C. Gre L. Morris, Esquire 21 . Main Street Carnegie, PA 15106 (412) 429-7675 PA_I I 1 10 Day DI P&F File No. 08-37544 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: Serena Caban 54 Monarch Dr Carlisle PA 17015-7311 Date: October 3, 2008 GrL. Morris, Esquire P enaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-1 11 10 Day D1 P&F File No. 08-37544 n_ 0 y 0 (? V Ul L ?- ^' .. Cr, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 08-4507 V. SERENA CABAN 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. 08-37544 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. SERENA CABAN Defendant(s) NO. 08-4507 NOTICE OF ORDER, DECREE OR JUDGMENT AGAINST SERENA CABAN ONLY TO: ( )Plaintiff ( x )Defendant ( )Garnishee ( )Additional Defendant You are hereby notifd that the following Order, Decree, or Judgment has been entered against you on 10/307403 ) 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 $11,228.15, 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 tion suspended by the Department of Trarro4tono 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. 08-37544 e" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TARGET NATIONAL BANK SERENA CABAN MEMBERS 1 ST FCU Plaintiff Defendant(s) Garnishee NO. 08-4507 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. 08-37544 ..J* IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. SERENA CABAN Defendant(s) MEMBERS 1 ST FCU To The Prothonotary: Garnishee NO. 08-4507 PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against, SERENA CABAN Defendant(s); 5+ Monaxth Dr, Carlisle, PA 170(5 (3) against, MEMBERS 1ST FCU, Garnishee; IIU(P "nuf &44om 0"It. PA 1706' (4) and index this writ (a) against, Defendant(s) SERENA CABAN, Defendant(s); and (b) against MEMBERS 1 ST FCU, 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 October 30, 2008 At 6.00 % per annum (Costs to be added) $11,228.15 $191.64 PA_134 Prcp Writ of Exe P&F File No. 08-37544 ,asp AA- 4u O? Cat o°o°a ? p 'D w -o b g? r 1 ?1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 084507 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s) From SERENA CABALA, 54 Monarch Drive, Carlisle, PA 17015 (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: MEMBERS 1" FCU, 1166 Walnut Bottom Road, Carlisle, PA 17015 Real property of Defendant in the name of garnishee 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 $11,228.15 L.L.$.50 Interest from 10/30/08 at 6.00% per annum -- $191.64 Atty's Comm % Due Prothy $2.00 Atty Paid $152.50 Plaintiff Paid. Date: 2/23/09 (Seal) Other Costs IV A ._4 - %1444-- Curt' R. Lon otary By: REQUESTING PARTY: Name GREGG L. MORRIS, ESQUIRE Address: PATENAUDE & FELIX, A.P.C. 213 E. MAIN STREET CARNEGIE, PA 15106 Attorney for: PLAINTIFF Telephone: 412429-7675 Deputy Supreme Court ID No. 69006 l ! i . RECEIVED MAR 0 5 2009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. SERENA CABAN Defendant(s) MEMBERS 1 ST FCU Garnishee NO. 08-4507 } } INTERROGATORIES IN ATTACHMENT 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 P&_139 Interogs Attch Exe P&F File No. 08-37544 c ; & %. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. SERENA CABAN Defendant(s) MEMBERS 1 ST FCU Garnishee } NO. 08-4507 } OFFICES OF PATENAUDE & FELIX BY: GREGG MORRIS, ESQUIRE 213 East Main St Carnegie PA 15106 858-244-7675 You are hereby notified to plead to the ene ed Interrogator' 'thin 20 days from e d to of hereof or def ul entered Drris, Esquire for Plaintiff You are required to answer the following interrogatories abo Defendant(s) whose address is 5A MONAR H DR A RLl LE PA l 7015 7311 You must file with the Court answers to the following interrogatories within twenty (20) days after service upon you. Failuo do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of the subject property. PA_139 Interogs Attch Exe P&F File No. 08-37544 a I ? %, 1. At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed them any money or were you liable to them for any reason? If yes, please specify as set forth herein. No kcajyur 2. At the time you were served, or at any subsequent time, was there in your possession, custody or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and describe the property. 3. At the time you were served, or at any subsequent time, did you hold legal title to any property or any nature owned solely or in part by the Defendant(s)? If yes please list and describe the property. (? ?( 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which the Defendant(s) had an interest? If yes, please list and describe the property. ?I01+CC(kl?l T- PA-139 Interop Attch Exe P&F File No. 08-37544 t 5. At any time before or after you were served, did the Defendant(s) transfer or deliver any property to you, or to any person, or place pursuant to your directions or consent? If yes, what was the consideration therefore? ?W Wooor 6. At any time after you were served, did you pay, transfer, or deliver any money or property to the Defendant(s) or to any person or place pursuant to their direction, or otherwise discharge any claim of the Defendant(s) against you. W kMOV)T 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electroncially on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. PA 139 Interogs Atteh Exe No kcomr P&F Fife No. 08-37544 8. If you are a bank or other financial insitution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, indentify each account.. NO k6d0l- & FAx, A.P.C. Date: January 22, 2009 /ee, orris, Esquire rl Street C A 15106 (4 675 PA 139 Interogs Attch Ere P&F File No. 08-37544 V ? i ?.. i u; .yti..a..?+ ?X'?. .. ., c.?r ;? -^?' ?? VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is (Name) l? of Members Ist (Title) Fedft Cl'9dj U:TIOfl (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNA RE) C? c' = C Sheriffs Office of Cumberland County R Thomas Kline +1AV,OW of CulabE? Edward L Schorpp Sheriff Solicitor Ronny R Anderson 44-i. Jody S Smith Chief Deputy o"CE of THE a<aiFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/05/2009 12:45 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on 03-05-09 at 1245 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Serena Caban, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1155 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, by handing to Lannie Moore, Customer Service Representative personally three copies of interrogatories together with 3 true and attested copies of the writ of execution and made the contents there of known to her. 2008-4507 So Answers, R. Thomas Kline, Sheriff By: Deputy Sheriff ? ?? ?'?' ._ ;? ?. ? } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TARGET NATIONAL BANK SERENA CABAN MEMBERS 1 ST FCU Plaintiff Defendant(s) Garnishee NO. 08-4507 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 Ptjdc P&F File No. 08-37544 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff V. SERENA CABAN Defendant(s) ; MEMBERS 1 ST FCU ) Garnishee ) NO. 08-4507 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. ed: RespectfulVFel b2X/P.C. Pater aude i Date: March 13, 2009 Gregg s, Esquire 213 E. treet Carne P 15106 (412P675 Swo to and subscribed before me this /gttay of , 20 Off' Notary Public PA_170 Prcp Disc w/o Pijdc P&F File No. 08-37544 NOTARIAL SEAL HEATHER L GOGAL Notory Public CARNEGIE BOROUGH, ALLEGHENY COUNTY My Commission Expires Oct 19, 2011 Al. 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: MEMBERS 1 ST FCU 5000 LOUISE DR PO BOX 40 MECHANICSBURG, PA 17055 Date: March 13, 2009 PA_170 Prcp Disc w/o Prjdc Gregg /,PA s, Esquire Pate lix, A.P.C. 213 eet C e5106 (4 ) P&F File No. 08-37544 r,• 4> op ?b y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith 41Chief Deputy Edward L Schorpp ; ,Y Solicitor; G ;:f, tis . Target National Bank vs. Case Number Serena Caban 2008-4507 SHERIFF'S RETURN OF SERVICE 03/05/2009 12:45 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on 03-05-09 at 1245 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Serena Caban, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1155 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, by handing to Lannie Moore, Customer Service Representative personally three copies of interrogatories together with 3 true and attested copies of the writ of execution and made the contents there of known to her. 04/08/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $76.38 April 09, 2010 Sharon R. Lantz j; ?..50 CC, SO ANSWERS, RON R ANDERSON, SHERIFF B y ''?-- Rte'- stvazgJ WRIT OF EXECUTION and/or ATTACHMENT CO, 1MONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4507 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s) From SERENA CABAN, 54 Monarch Drive, Carlisle, PA 17015 (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: MEMBERS IsT FCU, 1166 Walnut Bottom Road, Carlisle, PA 17015 Real property of Defendant in the name of garnishee 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 $11,228.15 L.L.$.50 Interest from 10/30/08 at 6.00% per annum -- $191.64 Atty's Comm % Due Prothy $2.00 Atty Paid $152.50 Plaintiff Paid Other Costs Date: 2/23/09 .Se-1) Cur 's R. 4hon ary By: Deputy REQUL'STING PART-Z: Name GR'ZGG 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 ?,_ . ?? `:"; ?, . ?: .. ;J Ji ?Jt? ????tt `a/ jj/f