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Home My WebLink About08-4523r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 0$ - 4,SoI3 l'iv i W r w v. VIRGINIA COLE Defendant(s) COMPLAINT IN CIVIL ACTION Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Parry: 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_1 I Cmplt Cvr Sht P&F File No. 08-35030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. VIRGINIA COLE 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. 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. 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PA-2 lNotice to Defend P&F File No. 08-35030 r' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, • PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. VIRGINIA COLE Defendant(s) COMPLAINT IN CIVIL ACTION NO. A F- YS,13 a;'il 7'L- AND NOW, comes Plaintiff, TARGET NATIONAL BANK, 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, 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 VIRGINIA COLE, an adult individual, believed to currently reside at 711 ROBERT ST MECHANICSBURG, PA 17055-3448. 3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No. 4352375044542944, 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 $14,391.04 on said account plus interest at 0.00 %. 5. Plaintiff maintains accurate books of account recording all credits and debits for this account. PA 05 Civil Cmplt Crdt Crd P&F File No. 08-35030 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 $14,391.04, 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. 08-35030 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $14,391.04, 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. Respectfully submitted: Pat an?ude & Felix,A-P.C. Date: June 10, 2008 rris, Esquire Street Carnegie, PA 15106 (412) 429-7675 PA-05 Civil Cmplt Crdt Crd P&F File No. 08-35030 TARGET =00000= Account Number: 4352-3750-4454-2944 Statement Closing Date: May 8, 2008 VIRGINIA R COLE 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 $14,391.04 Payments & Credits 0.00 Purchases & Advances 0.00 Other Charges 0.00 FINANCE CHARGES 0.00 New Balance $14,391.04 Amount Past Due $1,653.65 Minimum Payment Due $1,797.65 (includes any Amount Past Due) Payment Due Date June 2, 2008 Payments & 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 Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION TARGEI? NEW PHONE, HOME OR E-MAIL ADDRESS? PLEASE UPDATE ON REVERSE SIDE. OFFICE COPY INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK IIIIIIIIIIIIIIIIIIIINIIIIIIIIIIINII TARGET NATIONAL BANK P.O. BOX 59317 MINNEAPOLIS, MN 55459-0317 VIRGINIA R COLE 711 ROBERT ST MECHANICSBURG, PA 17055-3448 Account Number 4352-3750-4454-2944 New Balance $14,391.04 Minimum Payment Due $1,797.65 Payment Due Date June 2, 2008 Amount Enclosed $ f• 8002600179765143910490435237504454294471 o ?S- 3S o`?O In Original Creditor Name: TARGET NATIONAL BANK Debtor Name: COLE, VIRGINIA R Co-Debtor Name: Account Number: 4352375044542944 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. 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 $14391.04. 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 ' rue to the best of my knowledge, information d be ' ased upon the books and business records E TIONAL BANK. Authorized Agent of TARGET NATIONAL BANK Subscribed and sworn to before Me on 27th day of May, 2008 otary Public > My commission expires: 4352375044542944 A144 PATENAUDE & FELIX, A.P.C Court Judicial (Circuit/District) K JANICE L. LOKEN NOTAHy PUBLIC-MINNESOTA My C n E*4,,Nm. 31.2013 •N1M? 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 duly 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. 4352375044542944 A144 PATENAUDE & FELIX, A.P.C ADAM GRIM Authorized Agent of Target National Bank/Target Visa I P W W 00 ? y r.a tU OD 71 C? C'I C3 TI r? t -c SHERIFF'S RETURN - REGULAR CASE NO: 2008-04523 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TARGET NATIONAL BANK VS COLE VIRGINIA STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE COLE VIRGINIA was served upon the DEFENDANT , at 0010:15 HOURS, on the 9th day of August 2008 at 711 ROBERT STREET MECHANICSBURG. PA 17055 VIRGINIA COLE DEFENDANT 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 11.00 Affidavit .00 Surcharge 10.00 00 9 jb? /v Y ?^- 39.00 Sworn and Subscibed to before me this day So Answers: r?td R. "Thomas Kline 08/11/2008 PATENAUDE & FELIX By: Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 08-4523 V. VIRGINIA COLE 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 1g Both P&F File No. 08-35030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff ) NO. 08-4523 V. ) VIRGINIA COLE ) 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 $14,391.04 Interest from $0.00 Less payments received $0.00 Attorney's fees $0.00 TOTAL $14,391.04 With continuing interest on the principal amount of $14,391.04, 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. submitted: , A.P.C. Date: September 11, 2008 egg L orris, Esquire Main Street amegie, PA 15106 (412) 429-7675 PA_119 Prcp Def Jg Both P&F File No. 08-35030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. VIRGINIA COLE Defendant(s) NO. 08-4523 PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA R C P 1037(b) 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), VIRGINIA COLE, 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.23 7. 1, as evidenced by the attached copy. submitted: Date: September 11, 2008 Sworn to and subscribed before me this 1 day of ; Notary Pub is COMMONWEALTH OF PENNSYLVANIA Notarial Seal Carolyn J. Stewart Notary Public Carnage Boro, Aftheny County My Commbalon E)#m Aug. 14, 2011 PA 120 Aff of Non Mil Mernber, Pennsylvania Association of Notaries P&F File No. 08-35030 Felix, A.P.C. Grigg L. Morrij, Esquire 21/3 E. Main S eet W5106 7675 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 08-4523 V. VIRGINIA COLE 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-113 10 Day D1 D2 P&F File No. 08-35030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. VIRGINIA COLE Defendant(s) To: VIRGINIA COLE 711 ROBERT ST MECHANICSBURG PA 17055- 3448 Date of Notice: September 05, 2008 NO. 08-4523 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 Date: September 05, 2008 submitted Felix, A.P.C. /S/ Gregg Morris, Esquire 3 /Main Street Carnegie, PA 15106 (412) 429-7675 PA_113 10 Day D1 D2 P&F File No. 08-35030 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: Virginia Cole 711 Robert St Mechanicsburg PA 17055-3448 Date: September 05, 2008 G gg L. Moir s, Esquire P,Atenaude & Felix, A.P.C. 1213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-1 l 1 10 Day D1 P&F File No. 08-35030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 08-4523 V. VIRGINIA COLE 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. 08-35030 4116 'mow r ? ° a r 1 1*0 ..rS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARG$T NATIONAL BANK Plaintiff NO. 08-4523 V. VIRGINIA COLE Defendant(s) NOTICE OF ORDER DECREE OR JUDGMENT AGAINST VIRGINIA COLE ONLY TO:( )Plaintiff ( x )Defendant ( )Garnishee ( )Additional Defendant You are he eby notified that the following Order, Decree, or Judgment has been entered against you on 9 . Is, ( ) 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 $14,391.04, 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. Prothonot By / -1 Pepatr_ 4_zu?V7 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 Nte 3gmt Both P&F File No. 08-35030