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HomeMy WebLinkAbout10-7021Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney LD #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. SEAN M REGAL Attorney for Plaintiff, TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. lD - 70,21 l?A7 1el'1'Vtt c, ?. , 2407 NEW YORK AVE _> }.... CAMP HILL PA 17011-7318 Defendant. : NOTICE TO DEFENDr You have been sued in court. If you wish to defend against the claims set forth in the follow ng pages,-< you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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. 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. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 2531087 PPTCPADI OS $Q8.00 P10 A-17Y P-'r 39'0Ua P-Aas-o 7d4 AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL C/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. SEAN M REGAL 2407 NEW YORK AVE CAMP HILL PA 17011-7318 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. x0-70 ?-.( cap I COMPLAINT Plaintiff TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK, claims as follows: 1. The Defendant(s), SEAN M REGAL, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) opened an account agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $4547.49. 4. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2531087 PPTCOCCI WHEREFORE, the Plaintiff, TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK, prays for judgment in its favor and against Defendant(s), SEAN M REGAL in the amount of $4547.49, plus costs. Respectfully submitted, TARGET NATIONAL BAN15,F?A RETAILERS NATIONAL BANK O ft-el its Attorneys Daniel Santucci, Attorney No. 92800 Gregory R. Dye Attorney #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 (800) 850-1079 Dated: July 26, 2010 VERIFICATION the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to aui PPTXVERI Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK Gregory R. Dye, Attorney I.D. #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANI c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. SEAN M REGAL 2407 NEW YORK AVE CAMP HILL PA 17011-7318 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASEN & MOORE, LLe Dated: July 26, 2010 2531087 PPTJCAMI 1111111 I I I I I III 111111111111111111111111111111111111111111111 IN By: Gregory R. Dye LEIBS Exhibit "A" PPTXEXAI 253i?? In Court Judicial(Circuit/District) Original Creditor Name: Target National Bank Debtor Name: SEAN M REGAL Co-Debtor Name: Account Number: XXXXXXXXXX053024 AFFIDAVIT OF ACCOUNT STATE OF MINNESOTA COUNTY OF HENNEPIN SS: The undersigned, DENISE RANDALL 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 $4,547.49 . 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. Authorized Agent of Target National Bank Subscribed and sworn to before me on this 7th day of July, 2010. otary Public My Commission expires:[,- ?D4 -15 XXXXXXXXXX053024, LNFC m SHANNON MARIE SOLBERG NOTARY PUBLIC. MINNESOTA My Commission Expires Jan. 31, 2015 v tt Theundersigned does hereby verify subject to penalties of 16 Pa. C.S Section 4904 relating to unsworn falsification to authorities, that he is, DENISE RANDALL, 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. DENISE RANDALL Authorized Agent of TARGET NATIONAL BANK XXXXXXXXXX053024 LNFC Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney LD #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 610-902-0644 Attorney for Plaintiff, TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANE c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. SEAN M REGAL 2407 NEW YORK AVE CAMP HILL PA 17011-7318 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. ID - 7001/ 0'_1 v I I exm PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFft ' TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK. ` i Papers may be served at the address set forth below: - "? 1 m' Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 y Malvern, PA 19355 ` Telephone Number: 1-610-902-0644 ext. 4151 BLATT, HASENM & MOORE, LLC/ Dated: July 26, 2010 2531087 PPTXPEAI 111111111 IN 111111111111111111111111111111111111111111111111 IN By: Gregory R. Dye BSK SHERIFF'S OFFICE OF CUMBERLAND Ronny R Anderson Sheriff ???W,tp of ?u?n6crt??? Jody S Smith Chief Deputy Richard W Stewart Solicitor f,CE Or THE S-ER(FF Target National Bank vs. Sean M. Regal Case Number 2010-7021 SHERIFF'S RETURN OF SERVICE 11/12/2010 08:10 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on November 12, 2010 at 2010 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sean M. Regal, by making known unto Renee Regal, Wife of defendant at 2407 New York Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 November 16, 2010 TIM LACK, DEPUTY SO ANSWEERRS,,? RON R ANDERSON, SHERIFF (c) CountySuite Shentt. Teleosoft. Inc. 0 7 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANE c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, Vs. SEAN M REGAL 2407 NEW YORK AVE CAMP HILL PA 17011-7318 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA o CIVIL ACTION rnrrCo n :Do rn r-._. 2:?o No.10-7021-CIVILTERM -<? cD rn a° o r' =o ?C W Grp ? N -•c: PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT SEAN M REGAL in this matter in the amount of $4547.49 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 12/21/10 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: January 13, 2011 2531087 PPTJPFJI in No'm I 1111111 IN 1111111 IN IN By: BLATT, HA & MOORE, ? S1y.?u t"'? a? aQ v.4?$co9 Respectfully submitted, Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. SEAN M REGAL 2407 NEW YORK AVE CAMP HILL PA 17011-7318 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10-7021-CIVILTERM AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASE & MOORE, Lly Dated: January 13, 2011 By: R. Dye 2531087 PPTJCAMI I I Mull ? N 11111 Hill 1111111 IIII 1111 LEIROKER TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL Plaintiff, Vs. SEAN M REGAL 2407 NEW YORK AVE CAMP HILL PA 17011-7318 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10-7021-CIVILTERM TO: SEAN M REGAL Date of Notice: December 21, 2010 IMPORTANT NOTICE By: 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 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASE LER, BSKER & MOOPE, 183"arket Str?et, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This Is an attempt to collect a debt and any information obtained will be used for that purpose. 2531087 PPTNLRSI 11111111111111111111111111111111111111 IN WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-7021 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK Plaintiff (s) From SEAN M REGAL, 2407 New York Avenue, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013 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$4,547.49 Interest $50.07 Atty's Comm % Atty Paid $174.50 Plaintiff Paid Date: AUGUST 10, 2011 (Seal) L.L.$.50 Due Prothy $2.00 Other Costs la4mo-t-1. - David D. Buell, Prothonotary a Je- Deputy REQUESTING PARTY: Name DANIEL SANTUCCI, ESQUIRE Address: 1835 MARKET STREET, SUITE 501 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 610-902-0644 Supreme Court ID No. 92800 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION TARGET NATIONAL BANK F/K/A RETAILERS NATIONAL BANK Plaintiff VS. SEAN M REGAL Defendant Address: 44 4n INe CV k i 00A? t-? lk 14 TO THE PROTHONOTARY OF THE SAID COURT: ? Confessed Judgment - E Other Other _ rnC3 File No. 10-7021-CIVILTERM Amount Due _q,,_ e Interest © ? Atty's Comm -iC Costs [7 C:) ?? The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description: supply four copies of lengthy personalty list) Wt QaA L -105 N61ole GJ vc1., Ca r(f-s1-e I PO 176 r and all other property of the defendant(s) in the possession, custody or control of the said ? (Indicate) Index this writ against the garnishee(s) as a lis pendens against defendant(s) described in the attached exhibit. / Date 0.u?- ?a4. sow ( t? y 1.5? Ct? 1 Ct 00 14. UO tt k u ?r a. sn +4C14.SD Signature: of the Print Name: -e j :24y -/a ,f-', c C Address: v //i f ?'}Y r 't_ S r? i f Attorney for: gjr y e ) Telephone: V ?-` 5 Y (? 6 Supreme Court ID No: 2531087 ?.ob ? ?. PPTXCMPI 4% ?? L L wt 59&13 ,zo A S*ct W/),+ CS 6, Ttscwj SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff to ai CuMbetti b OFFICE OF >?FRIFF rr 1- € HE PR.JI +Fc-irlEut { l,.J i 4 Jody S Smith Chief Deputy Richard W Stewart Solicitor 2511 A UG 16 fi`' 8, C, 4 CUMBEPLArd PENNSYLV, NiA Target National Bank vs. Sean M. Regal Case Number 2010-7021 SHERIFF'S RETURN OF SERVICE 08/12/2011 10:29 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, PNC Bank at 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Kristand King, 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 August 15, 2011 to Sean M. Regal at 2407 New York Avenue, Camp Hill, PA 17011. SO ANSWERS, r• August 15, 2011 RON R A DERSON, SHERIFF 1C, i i iam Cline, Corporal (c) GountySuite Sheriff. Te!eosoft. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,y R Anderson ,riff Jody S Smith Chief Deputy Richard W Stewart Solicitor r 2012 KAR 23 PM 2: 38 CUMBERLAND Coutip, PENNSYLVANIA' Target National Bank vs. Sean M. Regal Case Number 2010-7021 SHERIFF'S RETURN OF SERVICE 08/12/2011 10:29 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, PNC Bank at 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013 Cumberland County, by handing to Kristand King, 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 August 15, 2011 to Sean M. Regal at 2407 New York Avenue, Camp Hill, PA 17011. 03/22/2012 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: $97.31 SO ANSWERS, March 22, 2012 RbNWY- R ANDERSON, SHERIFF d, CAD `,11 , &, 51) L L%( ill Coy. w?tyS??IL: Shenff_ Teeosoft. inN;