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Home My WebLink About10-0078Tt tit ?fl;fl i;°. -`? Fir 48 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA "TARGET NATIONAL BANK Plaintiff Civi lTerr NO. 10-018 V. KATHRYN W KRUSE Defendant(s) COMPLAINT IN CIVIL ACTION 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 #qa • oo A° P"-N 0,0 41oa.03)4516 8 P-T* a357&8 PF_PA_l 1 Cmplt Cvr Sht P&F File No. 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE 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 IN otice to Defend P&F File No. 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE Defendant(s) COMPLAINT IN CIVIL ACTION NO. 8 c 1Irl l ?z-"t 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 KATHRYN W KRUSE, an adult individual, believed to currently reside at 802 N ARCH ST MECHANICSBURG, PA 17055-2783. 3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No. 4352375050371105, for the purchase of good and services. 4. The Defendant(s) has/have made or authorized a number of purchases and as of November 10, 2009, Defendant(s) owes $2,090.66 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. 09-67147 6. Defendant assented to the correctness of the balance by making payments on the account. 7. 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 by continuing to extend credit to Defendant(s). 8. 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 $2,090.66, plus interest and costs. 9. By making payments andy 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. 10. 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. 09-67147 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $2,090.66, 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 subm' ed: Patenaude & Fe x, P.C. Date: November 25, 2009 Grj orris squire 21ain S eet Ca , P 15106 (41 9- 675 PA-05 Civil Cmplt Crdt Crd P&F File No. 09-67147 TARGETa Account Number: XXXX-XXXX-XXXX-1105 Account Identification Number: 00005039394 KATHRYN W KRUSE 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 Payments & Credits No payments or credits were received last month. Other Charges $39.00 Nov. 4 LATE PAYMENT FEE Total Other Charg ,s $39.00 Target National Bank, an affiliate of Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT It FORMA TI IN 0 TARGETa NEW PHONE. HOME OR E-MAIL ADDRESS? PLEASE UPDATE ON REVERSE SIDE. OFFICE COPY STATEMENT PAGE NOT PRINTED Statement Closin. Date ! !ove nl. er 10, 2009 Page 1 of 2 Previous Balance $2,051.66 Payments & Credits 0.00 Purchases & Advances 0.00 Other Charges 39.00 00 0 FINANCE CHARGES . New Balance $2,090.66 Amount Past Due $700.66 Minimum Payment Due $2,090.66 includes any Amount Past Due) Payment Due Date December 5, 2009 INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK TARGET NATIONAL BANK P.O. BOX 59317 MINNEAPOLIS, MN 55459-0317 KATHRYN W KRUSE 802 N ARCH ST MECHANICSBURG, PA 17055-2783 Account Numter XX KX-;KX.XX-XXXX-1105 New Balance $2,090.66 Minimum 3ayrnent CIL $2,090.66 Payment Due Date December 5, 2009 Amount Enc osed $ 10015002090660209066907777000[1!:;039';394771 TARGET =ooooo= Account Number: XXXX-XXXX-XXXX-1105 Account Identification Number: 00005039394 Statement Closing Date: November 10, 2009 KATHRYN W KRUSE 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 $0.00 $0 Cash 0.00000% . 0.00% Total FINANCE CHARGES: $0.00 Actual ANNUAL PERCENTAGE RATE: 0.00% 00 ANCE CHARGE of $1 for any billing period in which a Finance Charge is imposed. . There is a minimum FIN 5039394 In Court Judicial(Circuit/District) Original Creditor Name: Target National Bank Debtor Name: KATHRYN W KRUSE Co-Debtor Name: Account Number: XXXXXXXXXX371105 AFFIDAVIT OF ACCOUNT STATE OF MINNESOTA SS: COUNTY OF HENNEPIN The undersigned, RYAN FLYI4N states that: 1. 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 $2,090.66 . 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. i That the above information is true to the best of my knowledge, information and belief, and based upon the books and business records of Target National Bank. Authorized Age) of Target National Bank Subscribed and sworn to before me on this 19th day of November, 2009. Notary Public My Commission expires:__,/ s. xr JANICE L. LOKEN XXXXXXXXXX3 7110 5 NOTARY PUBLIC-WNNESOTA LNOC my C0=dWW Expka Jm. 31, 2019 wennrnl? e.AAA A r Theundersigned does hereby verify subject to penalties of 18 Pa. C.S Section 4904 relating to unsworn falsification to authorities, that he is, RYAN FLYNN, a Custodian of records for Target National Bank, Plaintiff herein, that he is duly authorized to make this Decleration 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. RYAN FLYNN Authorized Agent of TARGET NATIONAL BANK XXXXXXXXXX371105 LNOC SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff " Jody S Smith 0 Chief Deputy (U ?4 , l <_, ? ! l 7 Edward L Schorpp C , Solicitor Target National Bank vs. Kathryn W. Kruse Case Number 2010-78 SHERIFF'S RETURN OF SERVICE 01/21/2010 10:36 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 21, 2010 at 1036 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kathryn W. Kruse, by making known unto herself personally, at 802 N. Arch Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 22, 2010 SO ANSWERS, Y R ANDERSON, SHERIFF By ? Deput eriff {e. Coi.is=.<.ySufte 5henit. Teleosott. Inc;. (7 W-: P;' ,ur v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE Defendant(s) NO. 2010-078 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 pq.DU ,Vc?FrcE erIZI&CL PA_l 19 Prcp Def Jg Both P&F File No. 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE Defendant(s) NO. 2010-078 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 $2,090.66 Interest from November 10, 2009 $0.00 Less payments received $0.00 Attorney's fees $0.00 TOTAL $2,090.66 With continuing interest on the principal amount of $2,090.66, 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: Date: February 22, 2010 elix, A.P.C. regg . Mo 's, Esquire 213 E Main treet Cam gie, P 15106 (412 429-7175 PA_l 19 Prcp Def Jg Both P&F File No. 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE Defendant(s) NO. 2010-078 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), KATHRYN W KRUSE, 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. submitted: Date: February 22, 2010 Sworn to and subscribed before me this day of , 2010 Notary Public (/ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Carolyn J. Swart, Notary PuM CanMle Boro, Akoheny County ,MY,Co ton EVIres Aug. 14, 2011 PA 120 Aff of Non Mil- PennsylvaPoa Amdatlon of Notaries Felix, A.P.C. tEg. L. rris, Esquire Mai Street negie, P 15106 2) 429- 75 P&P File No, 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-078 V. KATHRYN W KRUSE 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_I 13 10 Day DI D2 P&F File No. 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . TARGET NATIONAL BANK Plaintiff NO. 2010-078 V. KATHRYN W KRUSE Defendant(s) To: Kathryn W Kruse 802 N Arch St Mechanicsburg PA 17055-2783 Date of Notice: February 11, 2010 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: February 11, 2010 PA 113 10 Day DI D2 P&F File 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: Kathryn W Kruse 802 N Arch St Mechanicsburg PA 17055-2783 Date: February 11, 2010 Gregg L. 213 E. M (a ?, ?A 15106 412 129-V675 PA_l 13 10 Day D1 D2 P&F File No. 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-078 V. KATHRYN W KRUSE 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_l23 Ntc Jgmt Both P&F File No. 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE Defendant(s) NO. 2010-078 NOTICE OF ORDER DECREE OR JUDGMENT AGAINST KATHRYN W KRUSE 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 ( ) 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 $2,090.66, 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 Me Jgmt Both P&F File No. 09-67147 i ICE e tjfg 'a? THO OF TN 701040v 16 AM 1 r : Z8 cur+eER sY?°va?a?,1Y PENN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE Defendant(s) MEMBERS 1ST CREDIT UNION Garnishee NO. 2010-078 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&I? Rile No. 09-67147 W1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE fteXJ1S01k rL44j,U Defendant(s) l?OS5- x,783 NO. 2010-078 MEMBERS 1ST CREDIT UNION ) .5600 k0o.-or - k . Garnishee ) It2?-??csbw?q? ?!4 t?ar s-?t84`? 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, KATHRYN W KRUSE Defendant(s); (3) against, MEMBERS 1ST CREDIT UNION, Garnishee; (4) and index this writ (a) against, Defendant(s) KATHRYN W KRUSE, Defendant(s); and (b) against MEMBERS 1ST CREDIT UNION, 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 March 01, 2010 At 6.00 % per annum (Costs to be added) X 4.56 ?C- 3 7.&O - e Ost ? . rr .1.00 T n - rr of 4"?.00 l.0 X70. aD - t r ` c PA_134 Prcp Writ of Exe C**f xao? P 20, .-Is/ ;Zqr $2,090.66 $86.95 P&I, Pile No. 09-67147 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-078 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s) From KATHRYN W. KRUSE, 802 N. ARCH ST., MECHANICSBURG, PA 17055-2783 (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 MEMBERS 1sT CREDIT UNION, 5000 LOUISE DRIVE, MECHANICSBURG, PA 17054899 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 det?ndant (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 $2090.66 L.L. $.50 Interest FROM MARCH 01, 2010 AT 6.00 % PER ANNUM - $86.95 Atty's Comm % Atty Paid $170.00 Plaintiff Paid Due Prothy $2.00 Other Costs Date: NOVEMBER 16, 2010 (Seal) David . Buell, othonotary By: Deputy REQU'ESTfi1G.PARTY: NMO-GlikOL-MORRIS, ESQ. Address: PA'PENAUDE & FELIX, A.P.C. 213 E. MAIN STREET CARNEGIE, PA 15106 Attorney for: Plaintiff Telephone: 412-429-7675 Supreme Court ID No. 87326 c FILED-OFFICE OF THE PROTHONOTARY 2010 DEC -2 Pty 3: 38 CUMBERLAND COUNTY PENNSYLVANIA powffm DEC 012010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE Defendant(s) MEMBERS 1ST CREDIT UNION Garnishee NO. 2010-078 ,41,2?UMKS fo... 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 PA_1391nterogs Attch Exe P& I File No. 09-67147 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff } NO. 2010-078 V. ) KATHRYN W KRUSE ) Defendant(s) } MEMBERS 1ST CREDIT UNION ) Garnishee ) OFFICES OF PATENAUDE & FELIX You are hereby notified to BY: GREGG MORRIS, ESQUIRE plead to the enclosed 213 East Main St Interrogatories within 20 Carnegie PA 15106 days from the date of 858-244-7675 hereof or a default judgment may be entered against you. Gregg Morris, Esquire Attorney for Plaintiff INTERROGATORIES IN ATTACHMENT EXECUTION You are required to answer the following interrogatories about Defendant(s) whose address is 802 N ARCH ST. MECHANICSBURG PA 17055-2783 You must file with the Court answers to the following interrogatories within twenty (20) days after service upon you. Failure to 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 affix mative, specify the amount, value and/or nature of the subject property. PA-139 Interogs Attch Exe P& I; File No. 09-67147 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 tht'm any money or were you liable to them for any reason? If yes, please specify as set forth hereili. n0 CECC6Ur1-?- 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. n 0 QCCO (n 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. no Dffwo 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. aCCCU PA-139 Interogs Anch Exe P& I File No. 09-67147 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? Yl d aCCcu v? ? 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. too accaf nt 7. If you are a bank or other financial insti ution, 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. 00 0 CCCUK& PA-139 Interogs Attch Exe M File No. 09-67147 t v 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, illdentify each account. Date: November 09, 2010 PA-139 Interogs Attch Exe ?0 QC(OUn? Respectfully submitted: Patenaude & Felix, A.P.C. Gregg L. Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 P& 1 File No. 09-67147 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (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. V jw?"A - (SIGNATU E) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFi E . F "-E i FILED-OFFICE of THE PROTHONOT,AP ?0!fl DEC -1 AM 8' 20 CUMBBLAND COUN.F PENNS 1 LMANIA- Target National Bank vs. Kathryn W. Kruse Case Number 2010-078 SHERIFFS RETURN OF SERVICE 12/01/2010 12:40 PM - Sheldon Marshall, De December 1, 2010 at 1233 hours and monies of the within named c the within named garnishee, Men Cumberland County, Pennsylvan copies of interrogatories together contents there of known to her. uty Sheriff, who being duly sworn according to law, states that on attached as herein commanded all goods, chattels, rights, debts, credits, 9fendant, to wit: Kathryn W. Kruse, in the hands, possession, or control of Hers 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, 3 17055, by handing to Jody Burkholder, Deposit Analyst personally three Nith three true and attested copies of the writ of execution and made the The writ of execution and notice t defendant was mailed on December 3, 2010 to Kathryn W. Kruse, 802 K Arch Street, Mechanicsburg, PA 7055. SO ANSWERS, December 02, 2010 ,r;, CountySuac Sherff. TEhO oft. !n;:. RON R ON, SHERIF Sheldon Marsha Deputy r a T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL BANK Plaintiff V. KATH? YN W KRUSE Defendants(s) ERS I ST CREDIT UNION Garnishee PA_193 Prep Disc with Prjdc Garnishee only NO. 2010-078 c - -?' - ?• f ..TIImo' U'3 %% C7 PRAECIPE TO SETTLE AND 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 P&F File No. 09-67147 G?ruk ??8•0° ?aJl ??? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. KATHRYN W KRUSE Defendant(s) TO: Date: Sworn Notary NO. 2010-078 ease settle and discontinue the matter captioned above without prejudice as to only. Thank you. 29, 2010 and subscribed before me this of , 201L- COMMONWEALTH OF PENNSYLVANIA Nohdel Seal Carolyn J. Stewart, Notary Public CWnWM OM ANe&" County My corrim elon ft-W Aug. 14, 2011 Member, a atieon NoWdes PA_193 Prcp Disc with Prjdc Garnishee only P&F File No. 09-67147 GAKNISHEE UNLY Prothonotary 1, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK, 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: MEMB RS I ST CREDIT UNION 5000 L UISE DRIVE MECH NICSBURG PA 17055-4899 Date: December 29, 2010 ???erfis,%squire e & Felix, A.P.C. E. Main Street egie, PA 15106 412) 429-7675 PA-193 PrcplDisc with Prjdc Garnishee only P&F File No. 09-67147 SHERIFF'S OFFI?.:E OF CUMBERLAND COUNTY Ronny R Anderson Sheriff LOOM of Or- TiHELPOTHONOTARY -OFFICE Jody S Smith Chief Deputy Richard W Stewart Solicitor C?F¢ ." <, 2011 AUG 23 PM 3: 53 CUMBERLAND COUNTY PENNSYLVANIA Target National Bank Case Number vs. Kathryn W. Kruse 2010-078 SHERIFF'S RETURN OF SERVICE 12/01/2010 12:40 PM - Sheldon Marshall, Deputy Sheriff, who being duly sworn according to law, states that on December 1, 2010 at 1233 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kathryn W. Kruse, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, by handing to Jody Burkholder, Deposit Analyst 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 3, 2010 to Kathryn W. Kruse, 802 N Arch Street, Mechanicsburg, PA 17055. 08/22/2011 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: $91.62 SO ANSWERS, August 22, 2011 RON R ANDERSON, SHERIFF ,i- -? 4,3 73S" c Gouttysuite S `f fae:; o`t Inc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK v. KATHRYN W KRUSE Plaintiff Defendant(s) ) NO. 2010-078 ) ) , 6,bdi-1) Ptoc pik..4-7 ) ) PRAECIPE FOR ASSIGN 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_158K Prcp for Assign Judg P&F File No. 09-67147 f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK v. KATHRYN W KRUSE Plaintiff Defendant(s) NO. 2010-078 PRAECIPE TO ASSIGN JUDGMENT FROM PLAINTIFF TO TD BANK USA, N.A. AS USE as PLAINTIFF TO: Prothonotary Kindly mark the Judgment plus costs to use of TD BANK USA, N.A. and assign from Plaintiff to TD BANK USA, N.A., upon payment of cost only. Date: December 03, 2014 Respectfully submitted: Patenaud Felix, A.P.C. 15106 2)4'-675 PA_158K Prcp for Assign Judg P&F File No. 09-67147 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: Kathryn W Kruse 802 N Arch St Mechanicsburg PA 17055-2783 Date: December 04, 2014 arnegie, 'A 15106 (412) 429-7675 PA 65 Certificate of Service P&F File No 09-67147