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Home My WebLink About10-5966IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. LAURA C RUPP Defendant(s) NOTICE TO 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 ajudgment 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. 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 NO. !o -S (- (2, u tlc Tl r- Q DEFEND ? rU Usted ha sido demandado en cone. Si usted deseatfendme de las demandas que se presentan mas adelante en1?S Q_t 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. 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 q --1 c I 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 S 7 1 ?• ME (2k-:h'' 12 -g "7116 PA-2 I Notice to Defend P&F File No. 10-57302 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. LAURA C RUPP Defendant(s) COMPLAINT IN CIVIL ACTION NO. 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: 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 LAURA C RUPP, an adult individual, believed to currently reside at 103 WESTVIEW DR MECHANICSBURG, PA 17055-5755. 3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No. 4352376718701055, for the purchase of good and services. 4. The Defendant(s) has/have made or authorized a number of purchases and as of May 20, 2010, Defendant(s) owes $13,461.90 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. 10-57302 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). 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 $13,461.90, 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. 10-57302 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $13,461.90, 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. Date: September 09, 2010 PA-05 Civil Cmplt Crdt Crd P&F File No. 10-57302 0 1111111111 TARt3ET4 Target Visa Credit Card Account Number: XXXX-XXXX-XXXX-1055 Account Identification Number: 00009811040 Statement Closing Date: July 20, 2010 LAURA C RUPP Page 1 of 2 Previous Balance $13,461.90 Payments and Other Credits -$0.00 Purchases and Other Debits +$0.00 Cash Advances +$0.00 Past Due Amount $13,461.90 Fees Charged +$0.00 Interest Charged +$0.00 New Balance $13,461.90 Total Credit Limit $0.00 Cash Limit $0.00 Available Credit $0.00 Portion Available for Cash $0.00 The Cash Limit is a portion of the Total Credit Limit Statement Closing Date 7!2012010 Days in Billing Cycle 30 New Balance Minimum Payment Due Payment Due Date $13,461.90 $13,461.90 8/17/2010 If you would litre information about credit counseling services, call 1-800-991-8433. For questions, an address change or to report a lost or stolen card, go online or call us: Manage My REDcard Target.comlredeard Target Credit Services 1-888-755-5856 TDD/TDY 1-800-347-5842 Outside the U.S. 1-612-307-8622 (Gail Collect) Calling will not preserve your billing-error rights Trans Date Description of Transaction or Credit Location _gPyriteil?tCQ11dt t7.. a No payments or credits were received last month. Total fees charged in 2010 $195.00 Total interest charged in 2010 $1,261.02 Amount Target National Bank, an attiNate elTarget Stores NOTICE' SEE REVERSE SIDE FOR IMPORTANT INFORMATION INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL SANK Account Number XXXX-XXXX-XXXX-1055 Balance l $13,461.90 TARGET, ?'IIEI?IItfi???lll?) mum Payment Due Mini $13,461.90 Payment Due Date August 17, 2010 NEW PHONE. HOME OR (( ]j / {{ [ [( 111111!?1?11'lI?II1rl?1'li?'ir111I11111''i11?ItII? Amount E-MAIL ADDRESS? Enclosed $ PLEASE UPDATE ON TARGET NATIONAL BANK REVERSE SIDE. P.Q. BOX 59317 OFFICE COPY MINNEAPOLIS, MN 55459-0317 STATEMENT PAGE NOT PRINTED LAURA C RUPP 103 WESTVIEW DR MECHANIeeCSBURG, PA 170(55-57`55 'III??I111 ?'11111?1'11?1?(1'i?1?11 /1t?i?111l?II?!!/H'I!'lII?I 7005121346190I134619090777700009811040271 0 1111111111 TARGET '00000' Target Visa Credit Card Account Number: XXXX-XXXX-XXXX-1455 Account Identification Number: 00009811040 statement Closing Date: July 20, 2010 LAURA C RUPP Page 2 of 2 Your Annual Percentage Rate (APR) is the annual interest rate on your account. T*pebf$atance Annual P*roWtaW'ftt*,fAM) Purchases 0.00% $13,461.90 $0.00 Cash Advances 0.00% $0.00 $0.00 There is a Minimum Charge of $1.00 for any billing period in which an interest charge is imposed 8811040 10-S-730-1 F4 In Court Judicial(Circuit/District) Original Creditor Name: Target National Bank Debtor Name: LAURA C RUPP Co-Debtor Name: Account Number: XXXXXXXXXX701055 AFFIDAVIT OF ACCOUNT STATE OF MINNESOTA SS: COUNTY OF HENNEPIN The undersigned, TYLER ROESSEL 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 $13,461.90 . 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 and belief, and based upon the books and business records of Target National Bank. Aut rized Agent of ar e ational Bank Subscribed and sworn to before me on this 23rd day of August, 2010. Do ry Public, My Commission expires: = _(S XXXXXXXXXX'7 010 5 - ' Ss fo ?? IV If 1l i?? LNOC ) V.. .....:. i' .,. ?i. i, c. via Theundersigned does hereby verify subject to penalties of 18 Pa. C.S Section 4904 relating to unsworn falsification to authorities, that he is, TYLER ROESSEL, 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. hoYLER ROESSEL rized Agent of TARGET NATIONAL BANK XXXXXXXXXX701055 LNOC SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOi1CltOr ~a~ti~~tn a1 ~runGcc/r~~4 :. ~~ ~, ,~ ,,,ix,' `~~'',. F~sC~:~s s,.~;r.G~iF~ Target National Bank vs. Laura C. Rupp Case Number 2010-5966 SHERIFF'S RETURN OF SERVICE 09/28/2010 08:45 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 28, 2010 at 2045 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Laura C. Rupp, by making known unto herself personally, at 103 Westview Drive, 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. --,/ _ NOAH CLINE, DEPUTY SHERIFF COST: $37.00 September 29, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF -~z N ~a ~° cn~ ~ .gyp ~~ c-.~ ~~ - c~ ~'~ ~~ ~~ --~ ~} ici Cour:.ySuile Sheriff, Teleosoft. Irc. y r- E E 1^ 17 n T11E E'lOT ?Iii "0 Ir . . ?r.l i ?1 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-5966 V. LAURA C RUPP Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT Filed on behalf of. TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. 469006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_119 Prcp DefJg Both ?'op C?o 0'v' P&F File No. 10-57302 `?"? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. LAURA C RUPP Defendant(s) NO. 2010-5966 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 $13,461.90 Interest from May 20, 2010 $0.00 Less payments received $0.00 Attorney's fees $0.00 TOTAL $13,46190 With continuing interest on the principal amount of $13,461.90, 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 submitted: Date: November 01, 2010 PA_ 119 Prcp DefJg Both & Felix, A.P.C. V L Morris, Esquire an Street e, PA 15106 9-7675 7302 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. LAURA C RUPP Defendant(s) NO. 2010-5966 PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA.R.C.P. 1037 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), LAURA C RUPP, 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: November 01, 2010 21 Felix, A.P.C. , Esquire 16gie, PA 5106 ) 429-76 5 Sworn to and subscribed before me this ' / day of A10V . , 20/40. Notary Pub is COMMONWEALTH OF PENNSYLV I'M ' SMi Cc - k@4 n 14, 2DI I PA-120 Aff of Non Mil P&F File No. 10-57302 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-5966 V. LAURA C RUPP 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 DI D2 P&F File No. 10-57302 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . TARGET NATIONAL BANK Plaintiff NO. 2010-5966 V. LAURA C RUPP Defendant(s) To: Laura C Rupp 103 Westview Dr Mechanicsburg PA 17055-5755 Date of Notice: October 19, 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 Respectfully Patenaude F A.P.C. ?S Date: October 19, 2010 Gr L. Morri , Esquire 21 Main S eet /2429_7 ie, PA 5106 ( 5 PA-113 10 Day D1 D2 P&F File No. 1, 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: Laura C Rupp 103 Westview Dr Mechanicsburg PA 17055-5755 Date: October 19, 2010 PA_113 10 Day DI D2 P&F File No. 10-57302 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-5966 V. LAURA C RUPP Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_123 Ntc Jgmt Both P&F File No. 10-57302