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HomeMy WebLinkAbout08-6202IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 08 - &a0a C iv aTrash v. ANITA N WARFEL 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_l I Cmplt Cvr Sht P&F File No. 08-56008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ANITA N WARFEL Defendant(s) NOTICE TO DEFEND NO. You have been sued in Court. If you wish to defend against Usted ha sido demandado on corte. Si usted desea defenderse the claims set forth in the following pages, you must take de las demandas que se presentan mas adelante en las action within TWENTY (20) DAYS after this Complaint and siguientes paginas, debe tomar accion dentro de los proximos notice are served, by entering a written appearance personally veinte (20) dias despues de la notificacion de esta Demanda y or by an attorney, and filing in writing with the Court your'; yAviso radicando personalmente o por medio de un abogado defenses or objections to the claims set forth against you. You Duna comparecencia escrita y radicando en la Corte por escrito are warned that if you fail to do so the case may proceed sus defensas de, y objecciones a, las demandas presentadas without you and a judgment may be entered against you by the aqui en contra suya. Se le advierte de que si usted fall de court without further notice for any money claimed in the tomar accion como se describe anteriormente, el caso pude Complaint or for any other claim or relief requested by the proceder sin usted y un fallo por cualquier suma de dinero Plaintiff. You may lose money or property or other rights reclamada en la demanda o cualquier reclamacion o remedio important to you. 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 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 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 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 INotice to Defend P&F File No. 08-56008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ANITA N WARFEL Defendant(s) COMPLAINT IN CIVIL ACTION NO. 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 ANITA N WARFEL, an adult individual, believed to currently reside at 706 MEADOW DR CAMP HILL, PA 17011-1719. 3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No. 4352371708338232, for the purchase of good and services. 4. The Defendant(s) has/have made or authorized a number of purchases and as of August 04, 2008, Defendant(s) owes $5,950.45 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. 08-56008 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 $5,950.45, 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. 08-56008 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $5,950.45, 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 Date: September 12, 2008 Patenaude &AULA.P.C. 7an gg rris, Esquire E. M n Street ' , PA 15106 5 (412) 29-7675 PA-05 Civil Cmplt Crdt Crd P&F File No. 08-56008 (i) ? TARGET *00000* Account Number: 4352-3717-0833-8232 Statement Closing Date: August 4, 2008 ANITA N WARFEL Page 1 of 2 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? Go online or call us: Manage My REDcard Target.com/redcard 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 $5,911.45 Payments & Credits 0.00 Purchases & Advances 0.00 Other Charges 39.00 FINANCE CHARGES 0.00 New Balance $5,950.45 Amount Past Due $1,402.87 Minimum Payment Due $5,950.45 (includes any Amount Past Due) Payment Due Date August 29, 2008 Payments 8t Credits No payments or credits were received last month. Other Charges Jul. 29 LATE PAYMENT FEE $39.00 Total Other Charges $39.00 Target National sank, an alwkate of"Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION (D' NEW PHONE, HOME OR E-MAIL ADDRESS? PLEASE UPDATE ON REVERSE SIDE. OFFICE COPY STATEMENT PAGE NOT PRINTED INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK TARGET NATIONAL BANK P.O. BOX 59317 MINNEAPOLIS, MN 55459-0317 ANITA N WARFEL 706 MEADOW DR CAMP HILL, PA 17011-1719 7001080595045059504590435237170833823271 Imo'-Sl.??g` Account Number 4352-3717-0833-8232 New Balance $5,950.45 Minimum Payment Due $5,950.45 Payment Due Date August 29, 2008 Amount Enclosed $ TARGET =ooooo> Account Number: 4352,3717-0833$232 Statement Closing Date: August 4, 2008 ANITA N WARFEL 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 0.00000% 0.00% $0.00 $0.00 $0.00 00 $0.00 00 $0 $0 Cash 0.00000% . . 0.00% Total FINANCE CHARGES: $0.00 Actual ANNUAL PERCENTAGE RATE: 0.00% period in which a Finance Charge is imposed. billin 00 for an f $1 E CHARGE There is a minimum F . o INANC g y 29433527 In Court Judicial (Circuit/District) Original Creditor Name: TARGET NATIONAL BANK Debtor Name: WARFEL, ANITA N Co-Debtor Name: NAN Number: N00000024962244 Account Number: ************8232 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 $5950.45. 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 ap? belief, and based upon the books and business tQcords of TARGET NATIONAL BANK. r T NATIONAL Subscribed anlKworn to before Me on 26th day of August, 2008 ary Public My commission expires: ************8232 A144 PATENAUDE & FELIX, A.P.9 C . ~ JNNICE L. LOKEN NOTARY PUBLIC-MINNESOTA *v comm om Expim Jan. 31, 2013 e AAAn 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, TIFFANY LEWIS, 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. TIFF of Target National Bank/Target Visa ************8232 A144 PATENAUDE & FELIX, ARC p il), 03 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06202 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TARGET NATIONAL BANK/TARGET VI VS WARFEL ANITA N NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WARFEL ANITA N the DEFENDANT , at 0010:30 HOURS, on the 23rd day of October , 2008 at 706 MEADOW DRIVE CAMP HILL, PA 17011-1719 JOSH WEIKEL by handing to HUSBAND OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge cold rI4 (1,, So Answers: 18.00 15.00 .00 10.00 R. Thomas Kline .00 43.00 10/24/2008 PATENAUDE & FELIX Sworn and Subscibed to before me this By day Deputy Sheriff of A. D. I It) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA ) Plaintiff ) NO. 08-6202 V. 1 ANITA N WARFEL Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT 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 PA_l 19 Prcp Def Jg Both P&F File No. 08-56008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA ) Plaintiff V. ANITA N WARFEL Defenct4nt(s) NO. 08-6202 PLAINTIFF'S PMECIPE 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 $5,950.45 Interest from August 04, 2008 $0.00 Less payments received $0.00 Attorney's fees $0.00 TOTAL $5,950.45 With continuing interest on thle principal amount of $5,950.45, 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 Nome is attached. & Felix, A.P.C. Date: November 25, 2008 regg L. M ris, Esquire 13 E. M e ' ' Street , PA 15106 (412) 429-7675 PA_119 Prep Def Jg Both P&F File No. 08-56008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA i TARGET NATIONAL BANK/TARGET VISA 1 V. ANITA N WARFEL Plaintiff Defendant(s) NO. 08-6202 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 MOWS, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and states that the defendant(s), ANITA N WARFEL, is not in the military servic'e 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 FeliV-A.P.C. Date: November 25, 2008 Sworn to and subscribed before me this C2:!?77day of , 2(XX. Notary NOWW Sad Carolyn J. Slswart, Notwy CWVe B=, AAepl"eny W Oanr?iss m Eves Aug. 14, 11 G gg orris, Esquire 2 3 Main Street Carnegie, PA 15106 (412) 429-7675 PA-1 20 Aff of Non Mil .." P&F File No. 08-56008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 08-6202 V. ANITA N WARFEL Defendant(s) IMPORTANT NOTICE 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 PA_113 10 Day Dl D2 P&F File No. 08-56008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 08-6202 V. ANITA N WARFEL Defendant(s) To: ANITA N WARFEL 706 MEADOW DR CAMP HILL PA 17011-1719 Date of Notice: November 14, 2008 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND LE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FOR 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 ?2 South Bedford Street Carlisle PA 17013 717-249-3166 Respec *Fe, Pate .C. Date: November 14, 2008 egg Moms, Esquire 13 E ain Street Carn ie, PA 15106 (412) 429-7675 PA-1 13 10 Day D1 D2 P&F File No. 08-56008 I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK/TARGET VISA, hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Anita N Warfel 706 Meadow Dr Camp Hill PA 17011-1719 Date: November 14, 2008 egg L orris, Esquire 13 E. Pain Street Carngie, PA 15106 (412) 429-7675 PA_113 10 Day Dl D2 P&F File No. 08-56008 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TAROET VISA ) Plaintiff ) NO. 08-6202 V. ANITA N WARFEL Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT 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 PA_l23 Ntc Jgmt Both P&F File No. 08-56008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ANITA N WARFEL Defendant(s) NO. 08-6202 NOTICE F ORDER, DECREE O NT AGAINS ANITA N WARFEL 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 _Dec, e o, 6 V v ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( X ) Judgment of ( ) Confession ( ) Verdict ( ) Court Order ( X) Defa It ( ) Non-suit ( ) Non- ros ( ) Arbitration Award ( X ) Judgment in the amount f $5,950.45, plus costs. ( ) District Justice Transcrit of Judgment in the amount of $ , plus costs. ( ) If not satisfied within si ty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotary By If you have questions concerning the above, please Contact: Name of Attorney: GRE MORRIS, Esquire 213 Ea Main St Carneg PA 15106 (412)-4 -7675 PA_123 Ntc Jgmt Both P&F File No. 08-56008 nn \v ib v d .? AA b "S 4 R X IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 08-6202 V. ANITA N WARFEL Defendant(s) WASHINGTON MUTUAL Garnishee PRAECIPE FOR WRIT OF EXECUTION 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 PA_134 Prcp Writ of Exe P&F File No. 08-56008 --.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ANITA N WARFEL WASHINGTON MUTUAL Defendant(s) Garnishee NO. 08-6202 PRAFCPE FOR WRIT OF EXECUTION To The Prothonotary: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against, ANITA N WARFEL Defendant(s); +lp(, Meada.0 Dr, , aftp Rig, PA 1-70 11 (3) against, WASHINGTON MUTUAL, Garnishee; )aoo bill 6y", WU. A (4) and index this writ (a) against, Defendant(s) ANITA N WARFEL, Defendant(s); and (b) against WASHINGTON MUTUAL, Garnishee; as a lzs pendens against real property of the Defendant(s) in the name of the garnishee as follows: (5) Amount due Interest from December 01, 2008 At 6.00 % per annum (Costs to be added) PA_134 Prcp Writ of Exe $5,950.45 Yf 'COQ {31 m h? m'? rib -71 d_ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6202 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s) From ANITA N. WARFEL, 706 Meadow Drive, Camp Hill, PA 17011 (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: WASHINGTON MUTUAL, 1200 Camp Hill ByPass, Camp Hill, PA 17011 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 $5,950.45 L.L.$.50 Interest from 12/01/08 at 6.00% per annum -- $59.50 Atty's Comm % Due Prothy $2.00 Atty Paid $162.50 Plaintiff Paid Date: 2/23/09 (Seal) REQUESTING PARTY: Name GREGG 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 Other Costs 11010 140L C is R. Long otary By: Deputy R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, Sheriffs Costs: Advance Costs: 200.00 Sheriffs Costs: 94.86 Docketing 18.00 105.14 Poundage 1.86 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 03/04/09 Mileage 13.50 Surcharge 30.00 Levy 20.00 Certified Mail Post Pone Sale Garnishee 9.00 Postage 4 /?4 TOTAL $ 94.86 l?e So Answers; R. Thomas Kline, Sheriff (1 0 By Claudia A. Brewbaker 0 r15 :Z Cj SZ 973 HU old ??yy1 1 3? 1*83NS Z ? C!- 4 ?3-71 4, z?;©yl WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6202 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s) From ANITA N. WARFEL, 706 Meadow Drive, Camp Hill, PA 17011 (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: WASHINGTON MUTUAL, 1200 Camp Hill ByPass, Camp Hill, PA 17011 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 $5,950.45 L.L,$.50 - Interest from 12/01/08 at 6.00% per annum -- $59.50 Atty's Comm % Due Prothy $2.00 Atty Paid $162.50 Plaintiff Paid Date: 2/23/09 (Seal) REQUESTING PARTY: Name GREGG L. MORRIS, ESQUIRE Address: PATENAUDE & FELIX, A.P.C. 213 E. MAIN STREET CARNEGIE, PA 15106 Attorney for: PLAINTIFF Telephone: 412429-7675 Supreme Court ID No. 69006 Other Costs (In. s R. Lon thong By: Deputy r- zx` i 'c•: x s F w q -0 7i { : >C) tv ? r. ?, 2'10 N AY 28 Fi', .. UJ GUt,?i r., ' INIY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 08-6202 V. ANITA N WARFEL Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT Filed on behalf of. TARGET NATIONAL BANK/TARGET VISA Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 8. oo PO All--1 e 4$cp 54 e a m8l PA_ 147 Prep Sat Jg P&F File No. 08-56008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ANITA N WARFEL TO:PROTHONOTARY Defendant(s) NO. 08-6202 PRAECIPE TO SATISFY JUDGMENT Please satisfy the Judgment at the above captioned action of record upon payment of your costs, only. Thank you. Date: May 19, 2010 Respectfully lefix mi ed: Patenaude & , P .C. Gregg L Esq uire 213 E. S et Carne e, P 15106 (4121/429/-1675 PA_147 Prcp Sat Jg P&F File No. 08-56008 I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK/TARGET VISA , hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Anita N Warfel 706 Meadow Dr Camp Hill PA 17011-1719 Date: May 19, 2010 PA_ 147 Prcp Sat Jg P&F File No. 08-56008