HomeMy WebLinkAbout10-0079Tl ,- P)v
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 10-0119 OA-vt"17-3rpt
V.
VICTORIA J HOHNEY
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
*ga .oo p Q A7'-/
ce `f(oa o5/459 oal
0-7* 0235'7&o
PF_PA_11 Cmplt Cvr Sht P&F File No. 09-67462
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
V.
VICTORIA J HOHNEY
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 soya. 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 21Notice to Defend P&F File No. 09-67462
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
V.
VICTORIA J HOHNEY
Defendant(s)
COMPLAINT IN CIVIL ACTION
NO. /0- 7f Ganl
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:
I . Plaintiff, TARGET NATIONAL BANK, is a National Bank 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 VICTORIA J HOHNEY, an adult individual, believed to currently
reside at 184 VIRGINIA AVE CARLISLE, PA 17013-1067.
3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No.
4352376694752924, for the purchase of good and services.
4. The Defendant(s) has/have made or authorized a number of purchases and as of
November 16, 2009, Defendant(s) owes $3,755.47 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. 09-67462
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 $3,755.47, 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. 09-67462
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in
the amount of $3,755.47, 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
Respectfully sub i ed:
Patenaude & elix, A.P.C.
Date: December 09, 2009
Gr g L. M is, Esquire
2 E. Ma' Street
negi , PA 15106
121 9-7675
5
PA 05 Civil Cmplt Crdt Crd P&F File No. 09-67462
0TARGET@
Account Number: XXXX-XXXX-XXXX-2924
Account Identification Number: 00014892445
VICTORIA J HOHNEY
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 biiiing-error rights
% TO
iri
Statement Closing Di t, No?en I I : 11, 2009
Page 1 of 2
Previous Balance
Payments & Credits
Purchases & Advances
Other Charges
FINANCE CHARGES
New Balance
Amount Past Due
Minimum Payment Due
(includes any Amount Past Due)
Payment Due Date
Important Messages
$3,622.83
0.00
0.00
39.00
93.64
$3,755.47
$587.06
$757.70
DF , : ?i nber 6, 2009
Please Contact us About Your Past Due Account
We've been trying to help bring your account current for the last few months. We have a number of s )ecial F ; I t rent
arrangements, but we clicto hear from you in order to try to help. ease get in touch king on "Manage My REDard" or calling (888) 608-7627with us today by goir I to
Targetcomlredcad and
Payments & Credits
No payments or credits were received last month.
Other Charges
$39.00
Nov. 5 LATE PAYMENT FEE -"
Total Other (t irges $39.00
Target National Bank, an affiliate of Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORN. 4TION
TARGETe
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 BANIC
Account Number , J(X}: X;;XX-XXXX-2924
New Balance $3,755.47
Minimum Payment )ue $757.70
Payment Due Date :ieoember 6, 2009
Amount
Encloser $
TARGET NATIONAL BANK
P.O. BOX 59317
MINNEAPOLIS, MN 55459-0317
?I?1??111??11111?1?1?11?11??1??1111?11?1?11?1??111??111??
VICTORIA J HOHNEY
184 VIRGINIA AVE
CARLISLE, PA 17013-1067
7002620075770037554790777700014891i141+5571
0-
TARGET9
*00000*
Account Number: XXXX-XXXX-XXXX-2924
Account Identification Number: 00014892445 Statement Closing Date: November 11, 2009
VICTORIA J HOHNEY 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 0.08216% 29.99% $3,676.66 $93.64 $0.00
00 $0.00 $0.00
$0
Cash 0.08216% .
29.99%
Total FINANCE CHARGES: $93.64
Actual ANNUAL PERCENTAGE RATE: 29.99%
Your periodic rate(s) and corresponding Annual Percentage Rate(s) for purchases and cash advances may vary.
There is a minimum FINANCE CHARGE of $1.00 for any billing period in which a Finance Charge is imposed.
14892445
In
Court
Judicial(Circuit/District)
Original Creditor Name: Target National Bank
Debtor Name: VICTORIA J HOHNEY
Co-Debtor Name:
Account Number: XXXXXXXXXX752924
AFFIDAVIT OF ACCOUNT
STATE OF MINNESOTA SS:
COUNTY OF HENNEPIN
The undersigned, KEVIN MARKLING 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 $3,755.47 .
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 informat' n is true to the best of my knowledge,
information and belief and based upon the books and business
i/ecords of Targe fi/onal Bank.
AutAc rizeh Ageft of Ta4jet National Bank
Subscribed and sworn tV before
me on this 24th day of November, 2009.
/ary Public
My Commission expires:-
CNOTARY ICE L. LOKEN
XXXXXXXXXX7 5 2 9 2 4 PUBLIC-MINNESOTA
CNOC o bn Expire) ArL 31, 2019
r
Y
Theundersigned does hereby verify subject to penalties of 18 Pa. C.S Section 4904 relating
to unsworn falsification to authorities, that he is, KEVIN MARKLING, 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.
KEVIN MARKLING
Authorized Agent of TAR ET NATIONAL BANK
XXXXXXXXXX752924
CNOC
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
4'0119 of
r t c . ,c T, E "-ERIFF
.87*,
201D JAN 7 Ph 2: 4 2
euma , ?.
Edward L Schorpp
Solicitor
Target National Bank
vs.
Victoria J. Hohney
Case Number
2010-79
SHERIFF'S RETURN OF SERVICE
01/05/2010 03:25 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January
5, 2010 at 1525 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Victoria J. Hohney, by making known unto Clyde Miller, Adult in charge at 184 Virginia
Avenue, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $33.40
January 06, 2010
SO ANSWERS,
O Y R ANDERSON, SHERIFF
By. '
Depu ey ? eriff
{cj CcuntySutte Sheriff. Teleosoft: Inc.
ED-C L: FUE
-i • 07 ?j
1
2010 FEB 16 PH 2: 52
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
V.
VICTORIA J HOHNEY
Defendant(s)
NO. 2010-079
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
$I4-.BO Pb Am
??? ?(6I SLn
?' a37(o?(v
PA-1 19 Prep Def Jg Both P&F File No. 09-67462
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
V.
VICTORIA J HOHNEY
Defendant(s)
NO. 2010-079
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 $3,755.47
Interest from $0.00
Less payments received $0.00
Attorney's fees $0.00
TOTAL $3,755.47
With continuing interest on the principal amount of $3,755.47, with interest at the legal
rate, plus costs of suit.
I hereby certify that a written notice of intention to file this praecipe was mailed to the
defendants and defendants' counsel (if known), after the default had occurred and at least ten
(10) days prior to the date of the filing of this praecipe. A copy of the Notice is attached.
Respectfully somitted:
Date: February 08, 2010
Felix; A.P.C.
g L. Morr s, Esquire
E. Main S reet
Legie, PA 15106
12) 429-7075
PA_I 19 Prcp Def.lg Both P&F File No. 09-67462
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
V.
VICTORIA J HOHNEY
Defendant(s)
NO. 2010-079
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), VICTORIA J
HOHNEY, 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 submitted:
Date: February 08, 2010
Sworn to and subscribed before me this
day of , 20,.
Notary Publi •
Felix, A.P.C.
712) g L. M rris, Esquire
E. MaStreet
C egie, 15106
( 429-7675
COMMONWEALTH OF PENNSYWAN A
NOOMW Saw
Carolyn J. Slew L Notary Public
My Conin"on County
Aug. 14,2011
Expiros
PA- 120 Aff of Non MilMember, Penns*arda Assoclafth NWAdW P&F File No. 09-67462
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 2010-079
V.
VICTORIA J HOHNEY
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 Dl D2 P&F File No, 09-67462
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 2010-079
V.
VICTORIA J HOHNEY
Defendant(s)
To: VICTORIA J HOHNEY
184 VIRGINIA AVE
CARLISLE PA 17013-1067
Date of Notice: January 26, 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
RespectfullAubmitted:
Felix, A.P.C.
Date: January 26, 2010
it g L. M rris, Esquire
3 Mai Street
ar egie, P 15106
41 429- 675
PA_I 1110 Day DI & ATTY P&[he No.
I, GREGG MORRIS attorney for Plaintiff, TARGET NATIONAL BANK , hereby certify that
a true and correct copy of foregoing document was serve this date by ordinary mail upon the following:
VICTORIA J HOHNEY
184 VIRGINIA AVE
CARLISLE PA 17013-1067
Date: January 26, 2010
Gregg is, Esquire
Paten JStr
elix, A.P.C.
213 . eet
C
a egi P /A
(4 ) 42 675
PA_l I 1 10 Day DI & ATTY P&F File No. 09-67462
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 2010-079
V.
VICTORIA J HOHNEY
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_I23 Ntc Jgmt Both P&F File No. 09-67462
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
V.
VICTORIA J HOHNEY
Defendant(s)
NO. 2010-079
NOTICE OF ORDER DECREE OR JUDGMENT
AGAINST VICTORIA J HOHNEY 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 02 /
( ) 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 $3,755.47, 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. 09-67462
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIF'F'S OFFICE OF CUMBERLAND COUNTY
_ F 4 c
Target National Bank Case Number
vs.
Victoria J. Hohney 2010-79
SHERIFF'S RETURN OF SERVICE
10!1612012 10.31 AM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
October 16, 2012 at 1031 hours, attached as herein commanded all goods, chattels, rights, debts, credits,
and monies of the within named defendant, to wit: Victoria J. Hohney, in the hands, possession, or control
of the within named. garnishee, New Cumberland Federal Credit Union, 6692 Carlisle Pike,
Mechanicsburg, Cumberland County, Pennsylvania, by handing to Briana Howsare, Branch Manager,
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 October 17, 2012 to Victoria Hohney at 184
Virginia Avenue, Carlisle, PA 17013.
SO ANSWERS,
October 17, 2012 RON~IY R ANDERSON, SHERIFF
A da Cobaugh, Depu~,t
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
V.
VICTORIA J HOHNEY
Defendants(s)
NEW CUMBERLAND FEDERAL CREDIT UNION
Garnishee
~ 7
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_~ ~
ru ,~
T
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w
-_ '
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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- i 675
~ ~:; ~ P ~ ~ rr/
~ ~~8a5 ~~ 9
NO. 2010-079
PA_ 193 Prcp Disc with Prjdc Garnishee only P&F File No. 09-67463
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT'Y'..
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 2010-07y
v.
VICTORIA J HOHNEY
Defendant(s)
PRAF,CIPE TO SETTLE AND DISCONTIN E WITHOUT PRE.TUDICE .AS TO_
GARNISHEE ONLY
TO: Prothonotary
Please settle and discontinue the matter captioned above without prejudice as to
Garnishee only. Thank you. ,
Respectf lly su tted:
Patena & Fe x, A.P,C.
,Ot ;
Date: October 23, 2012.
Sworn to and subscribed before me this
o~,,~, day of ~ ~-'C~3~2 ~' , 20~~-,
4tCMr1l~"~ ,~~~- 1
Notary Public
Gre . Morris, Esquire
2I3 . M~n Street
Ca e , PA 15106
( 429-7675
._„ ,~~
h1>>'V,~100 ~tA(3H93'ily,~ ~iti,~ ~N!
Od09 j~E)3Nfis~~
~i~gnd ,Selo;!
~~Jfi3d S dONl~pjy~
?b'3S lbl~lylON
Pn_I93 PrrGi Uisc ~+uh Prjdc Garnishee only R&F Rile No. 09-6746
I, GREGG MC)RRIS, attorney for Plaintiff, TARGET NATIONAL. BANK ,hereby
certify that a true and correct of the foregoing document was served this date by lJS pirst Class
Mail, postage prepaid upon the following:
NEW CUI~rIBERLAND FEDERAL CREDIT UNION
345 LEWISBERRY ROAD
NEW CUMBERLAND PA 17070
Date: October 23. 201:?
tyre orris, r,squire
Pa de & Felix, A.P.C.
2 .Main Street
C egie, PA 15106
( 2 ) 429-7675
PA_793 Prep Disc with Prjdc Garnishee only P&F File No. 09-67d~;2
i
SHERIFF'S OFFICE ORCUMBERLAND COUNTY
R Anderson
f �),
!E PR"
,dy S Smith
chief Deputy to'3 JUH —4 AM 11:
Richard W Stewart
Solicitor OPF ICE OF THE Sr<RlFr I''U 0 ,U ,f
r�4t4 S Yl,/A-IgI1A,
Target National Bank
Case Number
vs.
Victoria J. Hohney 2010-79
SHERIFF'S RETURN OF SERVICE
10/16/2012 10:31 AM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
October 16, 2012 at 1031 hours, attached as herein commanded all goods, chattels, rights, debts,
credits, and monies of the within named defendant,to wit: Victoria J. Hohney, in the hands, possession,
or control of the within named garnishee, New Cumberland Federal Credit Union, 6692 Carlisle Pike,
Mechanicsburg, Cumberland County, Pennsylvania, by handing to Briana Howsare, Branch Manager,
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 October 17, 2012 to Victoria Hohney at 184
Virginia Avenue, Carlisle, PA 17013.
06/03/2013 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: $92.94 SO ANSWERS,
June 03, 2013 RbNW R ANDERSON, SHERIFF
tc!C;ou^!y6u:e Sheriff.Teleosoft.
a