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HomeMy WebLinkAbout08-6569IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. D8 - &6o 0,1ya Term V. ROBIN L BOECKEL 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 1 Cmplt Cvr Sht P&F File No. 08-75778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. V. ROBIN L BOECKEL 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. 08-75778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ROBIN L BOECKEL 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 Demands 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 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 SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE OFFICE MAY BE ABLE TO PROVIDE YOU WITI 4? ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE INFORMATION ABOUT AGENCIES THAT MAY OFFER 'PUEhA PROVEER INFORMACION SOBRE AGENCIAS LEGAL SERVICES TO ELIGIBLE PERSONS AT A QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O REDUCED FEE OR NO FEE. BAJO COSO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY BAR CUMBERLAND COUNTY BAR ASSOCIATION ASSOCIATION 32 SOUTH BEDFORD STREET 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 CARLISLE, PA 17013 717-249-3166 PA-2 I Notice to Defend P&F File No. 08-75778 IN THE COURT OF COMMON PICAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ROBIN L BOECKEL Defendant(s) COMPLAINT IN CIVIL ACTION NO. AP- G 5.4 9 C r 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 ROBIN L BOECKEL, an adult individual, believed to currently reside at 221 W DAUPHIN ST # X ENOLA, PA 17025-2210. 3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No. 4352375021604550, for the purchase of good and services. 4. The Defendant(s) has/have made; pr authorized a number of purchases and as of , Defendant(s) owes $9,258.03 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. 08-75778 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 toM 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 $9,258.03, 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. 08-75778 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $9,258.03, 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 bmitted: Patenaude lix, A.P.C. Date: October 29, 2008 G gg L. orris, Esquire E. ain Street gie, PA 15106 (412) 429-7675 PA-05 Civil Cmplt Crdt Crd P&F File No. 08-75778 0. TARGET *00000* Account Number: 43523750-2160-4550 Statement Closing Date: October 4, 2008 ROBIN L BOECKEL 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 TDD1TDY 1-800-347-5842 Outside the U.S. 11-612-307-8622 (Call Collect) Calling will not preserve your billing-error rights Previous Balance $9,243.03 Payments & Credits -20.00 Purchases & Advances 0.00 Other Charges 35.00 FINANCE CHARGES 0.00 New Balance $9,258.03 Amount Past Due $1,735.58 Minimum Payment Due $1,863.58 (includes any Amount Past Due) Payment Due Date October 29, 2008 Important Messages Important Statement Message Security is important to us as it is to you - thats why we will be removing your account number from your credit card statement, beginning on your next statement. If you need to call us for any reason, please have your credit card handy. Payments & Credits Sep. 26 PAYMENT. THANKS! -$20.00 Total Payments & Credits -$20.00 Other Charges Sep. 29 LATE PAYMENT FEE $35.00 Total Other Charges $35.00 Target National Bank, an atlliate of Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK Account Number 4352-3750-2160-4550 New Balance $9,258.03 Minimum Payment Due $1,863.58 Payment Due Date October 29, 2008 NEW PHONE, HOME OR IIIIIIIIIIIIIIIIIII'1IIII III IIII II I III Amount E-MAIL ADDRESS? I IIII III III III Enclosed $ PLEASE UPDATE ON TARGET NATIONAL BANK REVERSE SIDE. P.O. BOX 59317 OFFICE COPY MINNEAPOLIS, MN 55459-0317 II I L IILLIIIII II 1 Ill I II ILJLLIII LII I 1111 I I I II I1 1 . I I I 1111 ROBIN L BOECKEL 221 W DAUPHIN ST ENOLA, PA 17025-2210 IIIJIIIIIIIIIIIIIIILIJIIILIIIIILIIIIILIIIJILIIIIL1111 2000200186358092580390435237502160455071 0. 1111111111111111111 TARGET. - Account Number: 4352-3750-2160-4550 Statement Closing Date: October 4, 2008 ROBIN L BOECKEL 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 0.00000% 0.00% $0.00 $0.00 $0.00 Cash 0.00000% 0.00% $0.00 $0.00 $0.00 Total FINANCE CHARGES: $0.00 Actual AN NUAL PERCENTAGE RATE: 0.00% There is a minimum FINANCE CHARGE of $1.00 for any billing period in which a Finance Charge is imposed 9140588 In Court Judicial (Circuit/District) Original Creditor Name: TARGET NATIONAL BANK Debtor Name: BOECKEL, ROBIN L Co-Debtor Name: NAN Number: N00000025826214 Account Number: ************4550 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 $9258.03. 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 record T ATIONAL BANK. Authorized Agent of TARGET NATIONAL BANK Subscribed and sworn to before Me on 14th day of October, 2008 Notary Public AIIZ ? My c ommission expires: M JANICE L. LOKEN ************4550 X= NOTARY PUBLIC-MINNESOTA A144 PATENAUDE & FELIX, A.P.C My Commission Explrea Jan, 31,2013 Y 4 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. ADAM GRIM Authorized Agent of TARGET NATIONAL BANK ************4550 A144 PATENAUDE & FELIX, A.P.C a N ssa -r7 QI lp Cj antb rn cr SHERIFF'S RETURN - REGULAR CASE NO: 2008-06569 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TARGET NATIONAL BANK/TARGET VI VS BOECKEL ROBIN L MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOECKEL ROBIN L the DEFENDANT , at 0018:30 HOURS, on the 20th day of November-, 2008 at 221 W DAUPHIN STREET # X ENOLA, PA 17025 by handing to ROBIN BOECKEL DEFENDANT 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 j1))s)or 18.00 15.00 .00 10.00 .00 43.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 11/24/2008 PATENAUDE & FELIX By: Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 2008-06569 V. ROBIN L BOECKEL 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_119 Prcp Def Jg Both P&F File No. 08-75778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ROBIN L BOECKEL Defendant(s) NO. 2008-06569 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 $9,258.03 Interest from $0.00 Less payments received $0.00 Attorney's fees $0.00 TOTAL $9,258.03 With continuing interest on the principal amount of $9,258.03, with interest at the legal rate, plus costs of suit. I hereby certify that a written notice of intention to file this praecipe was mailed to the defendants and defendants' counsel (if known), after the default had occurred and at least ten (10) days prior to the date of the filing of this praecipe. A copy of the Notice is attached. A.P.C. Date: December 22, 2008 PreAg . Morris, Esquire 21 ain Street C egie, PA 15106 (412) 429-7675 PA_1 19 Prcp Def Jg Both P&F File No. 09-75778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ROBIN L BOECKEL Defendant(s) NO. 2008-06569 PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA R.C P 1037(b) COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared GREGG MORRIS, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and states that the defendant(s), ROBIN L BOECKEL, is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that Notice of Intent to take Default Judgment was mailed in accordance with Pa.R.C.P.237.1, as evidenced by the attached copy. Respectfully suAitted: Date: December 22, 2008 Patenaude & FeRK, A.P.C. Greg f- Mo s, Esquire 213 Mai Street C ie A 15106 (41) 9-7675 Sworn to and subscribed before me this ` day of 200$.' Notary Pu is COMMONWEALTH OF PENNSYLVANIA Notarial Seal Carolyn J. Slawt, Notary Public C MV9 Boro , M%heny County My Commisslon Ekes Aug. 14, 2011 PA-1 20 Aff of Non MilMember, Pennsylvania Association of Notaries P&F File No. 08-75778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 2008-06569 V. ROBIN L BOECKEL 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-1 13 10 Day Dl D2 P&F File No. 08-75778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 2008-06569 V. ROBIN L BOECKEL Defendant(s) To: ROBIN L BOECKEL 221 W DAUPHIN ST # X ENOLA PA 17025-2210 Date of Notice: December 12, 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 32 South Bedford Street Carlisle PA 17013 717-249-3166 Respectfully, Date: December 12, 2008 PA_113 10 Day Dl D2 Patenaude , A.P.C. F 's, Esquire 15106 75 P&F File No. 08-75778 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: Robin L Boeckel 221 W Dauphin St # X Enola PA 17025-2210 Date: December 12, 2008 PA 113 10 Day Dl D2 P&F File No. 08-75778 . © Tv rr- IYS t, L'3 C ??.? cl" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 2008-06569 V. ROBIN L BOECKEL 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_123 Nte Jgmt Both P&F File No. 08-75778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA ) Plaintiff V. ROBIN L BOECKEL Defendant(s) NO. 2008-06569 NOTICE OF ORDER, DECREE OR JUDGMENT AGAINST ROBIN L BOECKEL 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 ( ) 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 $9,258.03, 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 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. 08-75778 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline ?4LE0'r1 Sheriff R70 Ronny R Anderson 36 Chief Deputy DEC -9 Jody S Smith Civil Process Sergeant cljmc'?jj-"A"VM"11A Edward L Schorpp Solicitor Target National Bank/Target VISA Case Number vs. Robin L. Boeckel 2008-6569 SHERIFF'S RETURN OF SERVICE 12/03/2009 03:04 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on Decembei 3, 2009 at 1455 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Robin L. Boeckel, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers, Customer Service Representative personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on December 7, 2009 to Robin L. Boeckel, 221 W Dauphin St., # X, Enola, PA 17025-2210. So Answers, R. 10?a s Kline, Ay , ill?, 7: eputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ROBIN L BOECKEL SOVEREIGN BANK Defendant(s) Garnishee NO. 2008-06569 PRAECIPE FOR WRIT OF EXECUTION Filed on behalf o£ 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, 08-75778 S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ROBIN L BOECKEL X ,2,21 w . baA-kPC%4% ale. ????0` c P 1 -1 Defendant(s) 12210 SOVEREIGN BANK 17 Ltd. Ntgh S+ Garnishee Cctr"La P 14 r7 013 NO. 2008-06569 PRAECIPE 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, ROBIN L BOECKEL Defendant(s); (3) against, SOVEREIGN BANK, Garnishee; (4) and index this writ (a) against, Defendant(s) ROBIN L BOECKEL, Defendant(s); and (b) against SOVEREIGN BANK, 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 January 06, 2009 At 6.00 % per annum (Costs to be added) PA_l34 Prep Writ of Exe t 4a4-5o PC) ATTy oo - Cost l2. ?. S-C - rt r f 1K•DU - rr rr .Z S- rr ?? 2.oo q. sv 4.1. W 45foO(o RT* A335q 8 Wr't+4 & 1"tud WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6569 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK/TARGET VISA, Plaintiff (s) From ROBIN L. BOECKEL, 221 W. DAUPHIN STREET #X, ENOLA, PA 17025- 2210 (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 SOVEREIGN BANK, 17 W. HIGH STREET, CARLISLE, PA 17013 GARNISHEE(S) as follows: 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 $9,258.03 L.L. $.50 Interest FROM 1/6/09 AT 6.00 % PER ANNUM - $413.25 Atty's Comm % Due Prothy $2.00 Atty Paid $162.50 Other Costs Plaintiff Paid Date: NOVEMBER 16, 2009 (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 C R. Long, Prothonotar By: ?C Deputy Supreme Court ID No. 69006 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson; f Sheriff rat au,b 'r_ TI '._ -._ "c Y Jody S Smith 2010 JUL -8 ki 8- 4 Chief Deputy } Richard W Stewart Solicitor OFF '<E OF -k= 4ERIFF Target National Bank/Target VISA Case Number vs. 2008-6569 Robin L. Boeckel SHERIFF'S RETURN OF SERVICE 12/03/2009 03:04 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 3, 2009 at 1455 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Robin L. Boeckel, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers, Customer Service Representative personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on December 7, 2009 to Robin L. Boeckel, 221 W Dauphin St., # X, Enola, PA 17025-2210. 07/07/2010 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: $85.78 July 07, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF Ai Stlar or. Tt. nt. - -2 Z,/ Pd. a ys?? 3 (c) CounfySuite Sheriff, ieleosoft. Inc, r. •;• "." • ".7."•-. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff NO. 2008-06569 V. ROBIN L BOECKEL 221 W Dauphin St Enola Pa 17025-2210 Defendant(s) SANTANDER BANK 401 N Enola Road Enola Pa 17025 Garnishee PRAECIPE FOR WRIT OF EXECUTION To The Prothonotary: Issue writ of execution in the above matter, (1) directed (2) against, (3) against, to the Sheriff of Cumberland County; ROBIN L BOECKEL Defendant(s); SANTANDER BANK, Garnishee; (4) and index this writ (a) against, Defendant(s) ROBIN L BOECKEL, Defendant(s); and (b) against SANTANDER BANK, Garnishee; as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows: $9,258.03 (5) Amount due Interest from January 06, 2009 At 6.00 % per annum Court Cost Less: Payment Total PA_134 Prcp Writ of Exe $2,144.70 $0.00 $8,748.00,7 Aar, $2,6 rne `or Pl.ntiff cliAiL 1 iLv 7? -29 gi4 967 3gre No. " "778 Sissrkvel ' ' • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff v. ROBIN L BOECKEL 221 W Dauphin St Enola Pa 17025-2210 Defendant(s) SANTANDER BANK 401 N Enola Road Enola Pa 17025 Garnishee NO. 2008-06569 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 Prep Writ of Exe P&F File No. 08-75778 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net TARGET NATIONAL BANK/TARGET VISA Vs. ROBIN L. BOECKEL WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08-6569 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against ROBIN L. BOECKEL, 221 W. DAUPHIN STREET, ENOLA, PA 17025-2210 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2). you are also directed to attach the property of the defendant (s) not levied upon in the possession of SANTANDER BANKGARNISHEE(S), as garnishee, 401 N. ENOLA ROAD, ENOLA, PA 17025 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $510.03 Plaintiff Paid Interest FROM JANUARY 6, 2009 AT 6.00% PER ANNUM - $2,144.70 Law Library Attorney's Comm. % Attorney Paid Date: 6/16/14 (SLa�i Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary Deputy 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 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy i �'-1 27 flm„l Richard W Stewart Solicitor 'D114SY1_V1tP3 A Target National Bank/Target VISA vs. Case Number Robin L. Boeckel 2008-6569 SHERIFF'S RETURN OF SERVICE 06/25/2014 11:00 AM -William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Santander Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Denise Beecher, Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 26, 2014 t Robin L. Boeckel at 221 W Dauphin Street, Enola, PA 17025-2210. LLIAM CLINE, DEPUTY SO ANSWERS, June 26, 2014 RONNY R ANDERSON, SHERIFF h Aleousl rAk- roaa 68— 16-Cloci 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. C) c -0 a m CX) .72 X r'i z 7-) G", r— CD 7:› r:%.) 2. At the time you were served, or at any subsequent time, was there in y—clur 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. 4 '41 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. PA_I39 Interogs Attch Exe P&F File No. 08-75778 4 • • 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? K..) 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. 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. 4V -77-V PA 139 Interogs Attch Exe P&F File No. 08-75778 • 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. Date: June 12, 2014 0 Respectfully submi Patenau gg L. 13 E. ain St Cam- ie, PA 151 ) 429-7675 PA_139 Interogs Attch Exe P&F File No. 08-75778 A.P.C. Esquire t ANSWERS TO INTERROGATORIES Account # 0921712634 CHECKING Balance: $1,560.67 IT HAS BEEN DETERMINED THAT THIS ACCT. IS EXEMPT FROM ATTACHMENT UNDER PA RULE. 5/21 $1,194.00 SSA TREASURY 6/18 $1,194.00 SSA TREASURY 7/16 $1,194.00 SSA TREASURY Account Holder: TIMOTHY C BOECKEL ROBIN L BOECKEL 221 W DAUPHIN ST ENOLA, PA 17025-2210 VERIFICATION I, Debbie Lewis, C.O.P. Process Specialist of Santander, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Santander By: Debbie Lewis C.O.P. Process Specialist OS -65&09. THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: TARGET NAT'L BK. vs. ROBIN L BOECKEL CERTIFICATE OF. SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Gregg L Morris, Esquire Patenaude & Felix, A.P.C. 213 E. Main St Carnegie, PA 15106 Service by certified mail addressed as follows: ROBIN L BOECKEL 221 W DAUPHIN ST ENOLA, PA 17025-2210 Deb. ie Lewis C.O.P. Process Specialist Santander MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 August 8, 2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA Plaintiff V. ROBIN L BOECKEL SANTANDER BANK Defendants(s) Garnishee NO. 2008-0656, CD "-Z PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY 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 Tb sq.°P cuAL o‘kjk --7146) PA_193 Prep Disc with Prjdc Garnishee only P&F File No. 08-75778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK/TARGET VISA ) ) Plaintiff ) NO. 2008-06569 ) ) ) ) ) ) ) ) v. ROBIN L BOECKEL Defendant(s) PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY TO: Prothonotary Please settle and discontinue the matter captioned above without prejudice as to Garnishee only. Thank you. Date: August 20, 2014 Respectfully susmitted: fril .Morris,ire / i . ' reet i. gie, PA 15106 429-7675 elix, A.P.C. Sworn to and subscribed before me this 20th day of August, 2014. j-)0122 11 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Brandi Tucci, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Dec. 28, 2014 MEMBER, PENNS'y6VANIA ASSOCIATION OF NOTARIES r PA_193 Prep Disc with Prjdc Garnishee only P&F File No. 08-75778 I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK/TARGET VISA , hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail, postage prepaid upon the following: SANTANDER BANK 401 N ENOLA ROAD ENOLA PA 17025 Date: August 20, 2014 Morris, Esquire aude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_193 Prcp Disc with Prjdc Garnishee only P&F File No. 08-75778