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HomeMy WebLinkAbout13-3735 Supreme Count - 6 ennsylvania COUC,,,,' Oi,:CQjpY(�0 leas For Prothonotary Use Only. C14iI V @Y'S]i' t Docket No: Q UM County The.: infryrtnatintt c•nllc�ctcd ou this f�r•nt is tt.red solely fir cutu•t adntinistrettiort purposes. This f < n - nt clues Trot mp ee or replace the ftlin 9 and set•1•ic•e� of'pleudi'tgs car other papers as regttlt•e d hl� law or rules of court. Comme nt of Action: I Complaint ❑ Writ of Summons ❑ Transfer from Another Jurisdiction [3 Petition E, ❑ Declaration of Taking C. Lead Plaintiffs Name: US J �. •� �1S Lead Defendant's Name: Are money damages requested? 'Y 03 es No Dollar Amount Requested: l� within arbitration limits 0: (check one) ❑outside arbitration limits lv Is this a Class Action Suit? „,,, ❑ Yes !9' O Is this an WjAppeal? ❑ Yes ®-�Ko Name of Plaintiff /Appellant's Attorney: . S ❑ Check here if you have no attorney (area Self- Represented [Pro Se) Litigant) Nature of the Case Place an "X” to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT No not include Judgments) CIVIL APPEALS El Intentional ❑ yer Plaintiff E3 Malicious Prosecution Administrative Agencies Debt Collection: Credit Card ❑ Board of Assessment [3 Motor Vehicle ❑ Debt Collection: Other © Nuisance ©Board of Elections ❑ Premises Liability Dept. of Transportation ►... ❑ Product Liability (does not include Statutory Appeal: Other ' mass to ❑ Employment Dispute: ❑ Slander /LibeU Defamation Discrimination IQ" ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board ❑ Other: MASS TORT ❑Other: ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES © Toxic Tort - Implant REAL PROPERTY ❑ ❑ Toxic Waste rCDeclaratory ELLANEOUS Other: ❑Ejectment Common Law /Statutory Arbitration Eminent Domain /Condemnation Judgment ❑ Ground Rent Mandamus [3 Landlord/Tenant Dispute Non - Domestic Relations PROFESSIONAL LIABILITY [3 Mortgage Foreclosure: Residential Restraining Order E0 Dental ❑Mortgage Foreclosure: Commercial ❑ Quo Warranto E] Partition ❑ Legal ❑ Replevin ❑ Medical [3 Quiet Title ❑Other: ❑ ❑ Other Professi Other: Professional: Updated 1 /1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TD BANK USA, N.A., AS SUCCESSOR IN INTEREST TO ) TARGET NATIONAL BANK 3-) 3S NO. J �- Plaintiff ) C t ✓ll� V. JYOTI B PATEL ) ` CD r- Defendant(s) NOTICE TO DEFEND You have been sued in Court. If you wish to defend against Usted ha sido demandado en corte. Si usted desea defenderse the claims set forth in the following pages, you must take de las demandas que se presentan mas adelante en las action within TWENTY (20) DAYS after this Complaint and siguientes paginas, debe tomar accion dentro de los proximos notice are served, by entering a written appearance personally veinte (20) dias despues de la notificacion de esta Demanda y or by an attorney, and filing in writing with the Court your Aviso radicando personalmente o por medio de un abogado defenses or objections to the claims set forth against you. You una comparecencia escrita y radicando en la Corte por escrito are warned that if you fail to do so the case may proceed sus defensas de, y objecciones a, las demandas presentadas without you and a judgment may be entered against you by the aqui en contra suya. Se le advierte de que si usted fall de court without further notice for any money claimed in the tomar accion como se describe anteriormente, el caso pude Complaint or for any other claim or relief requested by the proceder sin usted y un fallo por cualquier suma de dinero Plaintiff. You may lose money or property or other rights reclamada en la demanda o cualquier reclamacion o remedio important to you. solicitado per el demandante puede ser dictado en contra suya per 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 USTED DEBE LLEVAR ESTE DOCUMENTO A SU AT ONCE.IF YOU DO NOT HAVE A LAWYER GO TO OR ABOGADO INMEDIATAMENTE. SI USTED NO TIENE TELEPHONE THE OFFICE SET FORTH BELOW. THIS UN ABOGADO, LLAME O VAYA A LA SIGUENTE OFFICE CAN PROVIDE YOU WITH INFORMATION OFICINA. ESTA OFICINA PUEDE PROVEERLE ABOUT HIRING A LAWYER INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS Sl USTED NO PUEDE PAGAR POR LOS SERVICIOS DE OFFICE MAY BE ABLE TO PROVIDE YOU WITH UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE INFORMATION ABOUT AGENCIES THAT MAY OFFER PUEDA 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 CARLISLE, PA 17013 717- 249 -3166 717- 249 -3166 O Q-�� a ll, PA 21Notice to Defend P &F File No. 13 -4365 �� y 3:R rt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TD BANK USA, N.A., AS SUCCESSOR IN INTEREST TO ) TARGET NATIONAL BANK ) NO. Plaintiff ) V. ) JYOTI B PATEL ) Defendant(s) ) COMPLAINT IN CIVIL ACTION AND NOW, comes Plaintiff, TD BANK USA, N.A., AS SUCCESSOR IN INTEREST TO 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, TD BANK USA, N.A., AS SUCCESSOR IN INTEREST TO TARGET NATIONAL BANK, is a national banking association registered with the Office of the Comptroller of the Currency 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 JYOTI B PATEL, an adult individual, believed to currently reside at 14 HAMLET CIR MECHANICSBURG, PA 1 -5263. 3. Defendants) obtained extensions of credit, purchases or cash advances on the following opened ended credit card account number XXXXXXXXXXXX6991 issued by Target National Bank. PA 05D Civil Cmplt Crdt Crd P &F File No. 13 -4365 4. The Defendant(s) made payments on the account with the last payment posting on May 22, 2012, but have /has refused to pay, and now refuses to pay the balance due and owing on the aforesaid account in the sum of $1,769.36 plus interest and costs. 5. Plaintiff, TD BANK USA, N.A., purchased the debt and now owns the aforesaid account. A copy of the bill of sale and assignment is attached here as Exhibit "A" and incorporated herein by reference. 6. The Defendant(s) has/have made or authorized a number of purchases and as of 1/18/2013 12:00:00 AM, Defendant(s) owes $1,769.36 on said account plus interest. 7. Plaintiff maintains accurate books of account recording all credits and debits for this account. 8. 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. 9. A copy of the Account Statement is attached hereto as Plaintiffs Exhibit "B" and incorporated herein by reference. PA Civil Cmplt Crdt Crd P &F File No. 13 -4365 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $1,769.36, 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 Respectfu s mit d: Paten a e Felix A.P.C. Date: May 31, 2013 r 12 L. squire E. in Street le, PA 15106 )429 -7675 PA_05D Civil Cmplt Crdt Crd P &F File No. 13 -4365 EXECUTION COPY ASSIGNMENT AND ASSUMPTION AGREEMENT This Assignment and Assumption Agreement, dated as of March 13, 2013 (the " Assignment and Assu mption") is entered into by (i) Target National Bank, a national banking association; Target Receivables LLC, a Minnesota limited liability company ( " TR.LLC " and together with Target National Bank, the " Sellers. " and each a " Seller "), as the Sellers, and TD Bank USA, N.A., a national banking association (the " Purchaser "), as the Purchaser, pursuant to subsection 3.1(b) of the Purchase and Sale Agreement, dated as of October 22, 2012, as amended by the First Amendment thereto, dated as of March 13, 2013 (as amended, the " Purchase and Sa Agreement "), by and among the Sellers, Target Corporation, a Minnesota corporation (the 'T=") and the Purchaser, and (ii) Target National Bank, as the depositee (in such capacity, the " Depositee ") and the Parent, as the depositor (in such capacity, the " Depositor ") as parties to the Deposit Account Agreement #1 and Deposit Account Agreement #2, each dated as of April 28, 2009 (collectively, the " Dgpg.sit Account Agreement "), pursuant to subsection 3.1(d) of the Purchase and Sale Agreement. Section L Definition Capitalized terms used but not defined in this Assignment and Assumption have the same meaning as set forth in the Purchase and Sale Agreement, or if such term is not defined therein, the Credit Card Program Agreement (the " Credit Card Program Agreement "), dated as of October 22, 2012, by and among the Parent, Target Enterprise, Inc., a Minnesota corporation and the Purchaser. Section 2. Assi ment (a) Purchase Agreement (i) The Sellers hereby sell, convey and assign to the Purchaser, free and clear of all Liens, the Acquired Assets, including, without limitation, each Private Label Account and Co- Branded Account owned by Target National Bank as of the Cut -Off Time and existing as of the Closing Date, including Closed Accounts and Written -Off Accounts as of the Closing Date (the "Accounts '). (ii) All purchases and cash advances in connection with the Accounts and the Cardholder Indebtedness related to such Accounts outstanding as of the Closing Date or thereafter effected shall create the relationship of debtor and creditor between the Cardholder and the Purchaser, respectively. (iii) The Sellers acknowledge and agree that, following the Closing Date, (x) they shall have no right, title or interest in or to, any of the Accounts or the Account Documentation related to such Accounts or any EXHIBIT o E m k proceeds of the foregoing, and (y) the Purchaser shall extend credit directly to Cardholders. (b) Deposit Account Agreement (i) The Depositee hereby transfers and assigns to the Purchaser all of its rights and obligations under the Deposit Account Agreement, including all deposit Liabilities currently outstanding. (ii) On the Closing Date, the Depositee hereby pays to the Purchaser an amount equal to the Deposit Liabilities held by the Depositee for the Depositor, as estimated per subsection 3. I (d)(i) of the Purchase and Sale Agreement (which payment shall be made by a deduction from the Purchase Price and is subject to final adjustment as provided in subsection 3.1(d) of the Purchase and Sale Agreement). (iii) The Depositor and Depositee agree to terminate those two certain Pledge and Security Agreements, each dated as of April 28, 2009, and the pledges therein. (iv) The Depositor and Depositee agree that notwithstanding any other provision of the Deposit Account Agreement, no interest shall accrue thereunder on or after the Closing Date. Section 3. Assumption (a) Purchase Agr em nt (i) The Purchaser hereby assumes and shall pay, defend, discharge and perform as and when due the Assumed Liabilities upon the terms and conditions set forth in the Purchase and Sale Agreement. For greater certainty, the Purchaser will not be assuming or agreeing to pay, defend, discharge and perform the Excluded Liabilities. (ii) The Purchaser hereby agrees to purchase all the Acquired Assets and on and after the Closing Date, the Purchaser shall be the sole and exclusive owner of the Accounts and other Acquired Assets, and shall have all rights, powers, and privileges with respect thereto as such owner. (iii) Except as expressly provided in the Credit Card Program Agreement, the Purchaser shall be entitled to (x) receive all payments made by Cardholders on Accounts, and (y) retain for its account all Cardholder Indebtedness related to Accounts and such other fees and income authorized by the Credit Card Agreements and collected by the Purchaser with respect to the Accounts and the Cardholder Indebtedness related to such Accounts. (b) Deposit Account Agreement 2 (i) The Purchaser hereby assumes all rights and obligations of the Depositee under the Deposit Account Agreement, including all deposit Liabilities thereunder to the extent outstanding as of the Closing Date, as set forth in the Purchase and Sale Agreement. (ii) On the Business Day following the Closing Date, the Purchaser hereby agrees to pay the amount of such deposit Liabilities assumed, as estimated per subsection 3.1(d) of the Purchase and Sale Agreement, to the Depositor. Section 4. Credit Card Program Agreement The terms of the operation of the Program with respect to the Acquired Assets and Assumed Liabilities will be subject to the terms and conditions of the Credit Card Program Agreement. The Parent and/or its Affiliate(s) and the Purchaser shall have the rights set forth in the Credit Card Program Agreement in accordance with the terms thereof. Section 5. C ounterparts . This Assignment and Assumption may be executed in two or more counterparts (and by different parties on separate counterparts), each of which shall be an original, but all of which together shall constitute one and the same instrument. Section 6. Effect of Headings The Section headings herein are for convenience only and shall not affect the construction hereof. Section 7. Severability In case any provision in this Assignment and Assumption shall be invalid, illegal or unenforceable, the validity, legality, and enforceability of the remaining provisions shall not be affected or impaired thereby. Section 8. Governing Law THIS ASSIGNMENT AND ASSUMPTION SHALL BE GOVERNED BY, AND CONSTRUED IN ACCORDANCE WITH, THE LAWS OF THE STATE OF NEW YORK, WITHOUT REFERENCE TO ITS CONFLICT OF LAWS PROVISIONS (OTHER THAN SECTION 5 -1401 OF THE GENERAL OBLIGATIONS LAW), AND THE OBLIGATIONS, RIGHTS AND REMEDIES OF THE PARTIES HEREUNDER SHALL BE DETERMINED IN ACCORDANCE WITH SUCH LAWS. 3 i Section 9. Effective Date This Assignment and Assumption shall become effective as of the day and year test above written. [REMAINDER OF THE PAGE BLANK] 4 IN WITNESS WHEREOF, the parties hereto have caused this Assignment and Assumption to be duly executed by their respective officers as of the day and year first above written. TARGET CORPORATION, as the Parent and as the Depositor By: Jc_ Y Name: Sara J. Ross Title: Assistant Treasurer TARGE'r RECEIVABLES LLC, as a Seller By: , /& Name: Sara J. Ross Title: Vice President and Assistant Treasurer TARGET NATIONAL BANK, as a Seller and the Depositee By: Name: Spencer Johnson 'Title: Vice President TD BANK USA, N.A., as the Purchaser By: Name: "Title: 1788005- NYCSR07A MSW ASSIGNMENT AND ASSUMPTION • i IN WITNESS WHEREOF, the parties hereto have caused this Assignment and Assumption to be duly executed by their respective officers as of the day and year first above written. TARGET CORPORATION, as the Parent and as the Depositor By: Name: Sara J. Ross Title: Assistant Treasurer TARGET RECEIVABLES LLC, as a Seller By: Name: Sara J. Ross Title: Vice President and Assistant Treasurer TARGET NATIONAL BANK, as a Seller and the Depositee By: ----� Name: Spencer n Title: Vice President 'I'D BANK USA, N.A., as the Purchaser By: Name: Title: ASSIGNMENT AND ASSUMPTION 17M5- NYCSR07A • MSW f IN W11 WHEREOF, the parties hereto have caused this Assigrnnent and Assumption to be duly executed by their respective officers as of the day and year first above written. TARGET CORPORATION, as the Parent and as the Depositor BY: Name: Sara J. Ross ~ Title: Assistant Treasurer TARGET RECEIVABLES LLC, as a Seller By: Name: Sara J. Ross "Title: Vice President and Assistant Treasurer TARGET NATIONAL BANK, as a Seller and the Depositoe Name: Spencer Johnson Title: Vice President TD BANK USA, N.A., as the Purchaser By: Name: Michael Collins Title: President and CEO AssIGNM &'NT AND ASSUMPTION TARGET. *00000' Target Visa Credit Card Account Number: XXXX - XXXX -XXXX -6991 Account Identification Number: 00032084814 Statement Closing Date: December 16, 2012 JYOTI B PATEL Page 1 of 2 Summary of Account Activity Payment Information Previous Balance $1,671.26 New Balance $1,734.36 Payments and Other Credits -$0.00 Minimum Payment Due $499.00 Purchases and Other Debits +$0.00 Cash Advances +$0.00 Payment Due Date 1/13/2013 Past Due Amount $419.00 Late Payment Warning: If we do not receive your minimum Fees Charged +$35.00 payment by the date listed above, you may have to pay up to a Interes Ch arge d +$28,10 $35.00 late fee. New Balance $1,734.36 Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take Total Credit Limit $0.00 you longer to pay off your balance. For example: Cash Limit $0.00 Available Credit $0.00 If you make no You will pay off the And you will Portion Available for Cash $0.00 additional charges balance shown on end up paying The Cash Limit is a portion of the Total Credit Limit using this card and this statement in an estimated Statement Closing Date 12/16/2012 each month you pay... about... total of.... Days in Billing Cycle 30 Only the minimum Payment 7 years $2,825 For questions, an address change or to report a lost or stolen card, go Online or call us: If you would like information about credit counseling services, Manage My REDcard Target.com /redcard call 1- 800 - 991 -8433. Target Credit Services 1- 888 - 755 -5856 TDDrrDY 1- 800 - 347 -5842 Outside the U.S. 1- 612 - 307 -8622 (Call Collect) Calling will not preserve your billing -error rights Im Account Seriously Past Due If we don't set up payment arrangements for your REDcard soon, we'll charge off your account and report it to the credit bureaus as bad debt. There's still time to work with us to try to find a solution for your account and prevent this negative impact to your credit report, but we need to hear from you right away. Call us at (888) 608 -7627 or go to Target.com /redcard and click on "Manage My REDcard" to learn more. Target National Bank, an affiliate of Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK Account Number XXXX- XXXX -XXXX -6991 Account TARGETa 11111 IN 111111 1111111111 �11111 111 New BalancetificatiDn Number o$1,734.36 Minimum Payment Due $499.00 Payment Due Date January 13, 2013 NEW PHONE. HOME OR Amount E -MAIL ADDRESS? PLEASE UPDATE ON TARGET NATIONAL BANK Enclosed $ REVERSE SIDE. P.O. BOX 660170 OFFICE COPY DALLAS TX 75266 -0170 I'll Illllllr'nllll "'I "II "I II111 "II JYOTI B PATEL 14 HAMLET CIR MECHANICSBURG PA 17050 -5263 11 11111' 1 "IIIII'II'I' 11 'lllll'llll "II 1• EXHIBIT 0 0000 90777700032084814271 E m TARGEfi *00000* Target Visa Credit Card Account Number: XXXX - XXXX -XXXX -6991 Account Identification Number: 00032084814 Statement Closing Date: December 16, 2012 JYOTI B PATEL Page 2 of 2 Important Product Safety Guest safety continues to be a top priority for Target. Visit Target.com or any Target in -store kiosk for product safety alerts and recall information. Transacti Trans Date Description of Transaction or Credit Location Amount Payments And Other Credits No payments or credits were received last month. Fees Dec. 13 - LATE PAYMENT FEE _ — - - _ __ -- - - - -•- - -- _— $35.00 TOTAL FEES FOR THIS PERIOD $35.00 Interest Charg INTEREST CHARGE - PURCHASES T�$28.10 TOTAL INTEREST CHARGED FOR THIS PERIOD $28.10 2012 Totals Year-to-Date Total fees charged in 2012 $260.00 Total interest charged in 2012 $215.40 mmmmq Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. �Balance Subject to Type of Bala Annual Pe rcenta ge Rate (APR) Inte Rate Int Char Purchases 20.24% (v) $1,689.43 $28.10 Cash Advances 23.24% (v) $0.00 $0.00 (v) = Variable Rate There is a Minimum Charge of $1.00 for any billing period in which an interest charge is imposed. 32084814 TARGET. *00000* Target Visa Credit Card Account Number: XXXX - XXXX -XXXX -6991 Account Identification Number: 00032084814 Statement Closing Date: January 16, 2013 JYOTI B PATEL Page 1 of 2 Summary of . Previous Balance $1,734.36 New Balance $1,769.36 Payments and Other Credits -$0.00 Minimum Payment Due $1,769.36 Purchases and Other Debits +$0.00 Cash Advances +$0.00 Payment Due Date 2/13/2013 Past Due Amount $499.00 If you would like information about credit counseling services, Fees Charged +$35.00 call 1- 800 - 991 -8433. Interest Charged +$0.00 New Balance $1,769.36 For questions, an address change or to report a Total Credit Limit $0.00 lost or stolen card, go online or call us: Cash Limit $0.00 Manage My REDcard Target.com /redcard Available Credit $0.00 Target Credit Services 1- 888- 755 -5856 Portion Available for Cash $0.00 TDD/TDY 1- 800 - 347 -5842 The Cash Limit is a portion of the Total Credit Limit Outside the U.S. 1- 612 - 307 -8622 (Call Collect) Statement Closing Date 1/16/2013 Calling will not preserve your billing -error rights Days in Billing Cycle 31 Im portant •- Your account has been charged off. This is your final statement. Transacti Trans Date Description of Transaction or Credit Location Amount _ . _ _..._.... ................... ... ....... ..... ... ._.._ _... Payments And Other Credits No payments or credits were received last month. Fees Jan, 13 LATE PAYMENT FEE $35.00 TOTAL FEES FOR THIS PERIOD $35.00 (transactions continued on next page) Target National Bank, an affiliate of Target Stores NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION INCLUDE THIS PORTION WITH YOUR PAYMENT MADE PAYABLE TO TARGET NATIONAL BANK Account Number XXXX- XXXX -XXXX -6991 Account Iden tification Number o TARGET• III�I IIII IIIIII IIII'lII'I IIIIII III New Balance $ 1 , 769.36 Minimum Payment Due $1,769.36 Payment Due Date February 13, 2013 NEW PHONE, HOME OR Amount E -MAIL ADDRESS? PLEASE UPDATE ON TARGET NATIONAL BANK Enclosed $ REVERSE SIDE. P.O. BOX 660170 OFFICE COPY DALLAS TX 75266 -0170 I'llllllllll" 111 "'I "II" 1 "I1 JYOTI B PATEL 14 HAMLET CIR MECHANICSBURG PA 17050 -5263 11 11111' 1 " 11111' II' 1' 1' II 'llll "II 5000860176936017693690777700032084814271 J q1tr '00000* Target Visa Credit Card Account Number: XXXX - XXXX -XXXX -6991 Account Identification Number: 00032084814 Statement Closing Date: January 16, 2013 JYOTI B PATEL Page 2 of 2 Transactions (cont.) 2013 Totals Year -to -Date Total fees charged in 2013 $35.00 Total interest charged in 2013 $0.00 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Balance subject to Type of Balance Annual Percentage Rate (APR) Interest Rate Interest Char_ ge Purchases 0.00% $1,738.87 $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. 32084814 w VERHMAnOM The undersigned, Adam Grim, does hereby verify subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswMrn falsification to authorities, that he is a Custodian of Records and the Authorized Representative, of TD BAND USA, N.A., AS SUCCESSOR IN INTEREST TO TARGET NATIONAL BANK, Plaintiff herein, and that he is duly authorized to make this Declaration, and that the facts set forth in the foregoing document are true and correct to the best of his ,knowledge, information and belief. Adam Grim, Authorized Representative TD HAND USA, N.A., AS SUCCESSOR IN INTEREST TO TARGET NATIONAL BANK 4352391722306941 4332311722306441 PA_OIT Tt+ pt verifi ion P&F He No. 134365 SHERIFF'S OFFICE OF CUM13ERLANDT "„ R Ronny R Anderson 7j]13 JUL I .I 31 Sheriff ��� �3 � UMBERLAF40 COUNTY Jody S Smith .� � Chief Deputy �" �� PF-NNSYLVANIA " r�Pw Richard W Stewart ` Solicitor OF`iCE F THE SHERIFF TD Bank USA, N.A. as Successor in Interest to Target National Bank Case Number vs. Jyoti B Patel 2013-3735 SHERIFF'S RETURN OF SERVICE 07/08/2013 08:37 PM- Deputy Amanda Cobaugh,being duly sworn according to law, served the requested Complaint&Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Jyoti B Patel at 14 Hamlet Circle, Silver Spring TO ship, Mechanicsburg, PA 050. r � f +' AM-AN COBAU , DEP by SHERIFF COST: $39.30 SO ANSWERS, July 09, 2013 RON Y R ANDERSON, SHERIFF (c)CountySuite Sheriff,Toleosoft,Inc.