HomeMy WebLinkAbout06-1937
GREGG L MORRIS, ESQ.
PATENAUDE & FELIX, A.P.c.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant(s).
)
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) NO. ()~ - I9.J7
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C'-u ; L ~82_J01
TARGET NATIONAL BANK
Plaintiff,
v.
LEEANN C CARLSON,
COMPLAINT IN CIVIL ACTION
Filed on behalf of:
TARGET NATIONAL BANK,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa LD. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, P A 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK ,
Plaintiff,
)
)
) NO. Dlo - I Cf.J7
)
)
)
)
)
)
)
(2u;l~~
v.
LEEANN C CARLSON,
Defendant.
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 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TillS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT illRING A LAWYER.
IF YOU CANNOT AFFORD TO illRE A LAWYER, TillS 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 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant.
)
~ NO. 6~ - /q27
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)
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)
CLo:L ~~
TARGET NATIONAL BANK,
Plaintiff
v.
LEEANN C CARLSON,
COMPLAINT IN CIVIL ACTION
AND NOW, comes Plaintiff, TARGET NATIONAL BANK, by and through its
attomey,GREGG L. 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 corporation and for the purpose of
this litigation, maintaining a place of business c/o Patenaude and Felix, A.P.c., 213 East
Main Street, Carnegie, Pennsylvania 15106.
2. Defendant is LEEANN C CARLSON, an adult individual, believed to currently
reside at III SALEM CHURCH RD ,MECHANICSBURG, PA 170502835.
3. Heretofore, the Defendant opened a TARGET NATIONAL BANK account
with Plaintiff being Account No. 4352378340554738 ,for the purchase of goods and
services.
4. The Defendant has made or authorized a number of purchases and as of
12/30/05, Defendant owes $3,537.39 on said account plus interest.
5. Plaintiff maintains accurate books of account recording all credits and debits for
this account.
6. The Defendant has received monthly billing statements from Plaintiff setting
forth the nature and amount of all charges made by Defendant, and the transactions between
Plaintiff and Defendant give rise to an account stated, upon which Plaintiff has relied.
7. The Defendant made payments, but has refused to pay, and now refuses to pay
the balance due and owing on the aforesaid account in the sum of$3,537.39, plus interest
and costs.
8. By failing to object or dispute to the statements including the statement attached
hereto as Plaintiffs Exhibit "A", Defendant has assented to and agreed to the correctness of
the balance due on the credit card account so as to constitute and account stated.
9. Despite repeated demands, Defendant has failed to make the required installment
payments when due and therefore the full amount of the account is now due and payable.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant, in
the amount of$3,537.39, plus legal interest 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 Submitted:
G
21 Street
Carnegie, P A 15106
(412) 429-7675
o TARGET
Statement Closing Date: December 27, 2005
Page 1 of 2
'j,C::JU Iv')} c""'"
11111111111111
Target National Bank
an affiliate of Target
Account Number: 4352-3783-4055-4738
LEEANN C CARLSON
Target Visa 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
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
$3,577.39
0.00
0.00
35.00
0.00
$3,612.39
$574.00
$3,612.39
Questions? Call Us:
Target Credit Services 1-888-755-5856
TDDITDY 1,800-347,5842
Outside the U.S. 11~612-307.8622 (Call Collect)
Calling will not preserve your billing-error rights
January 21, 2006
Payments & Credits
No payments or credits were received last month.
Other Charges
Dec. 22 LATE PAYMENT FEE
Total Other Charges
$35.00
$35.00
Fi nance Charges
Days in Billing Period: 30
Balance Type
Purchases
Cash
Daily
Periodic Rate
0.06821 %
0.06821 %
Corresponding
Annual
Percentage Rate
24.90%
24.90%
Average
Daily
Balance
$0.00
$0.00
Periodic
FI NANCE
CHARGE
$0.00
$0.00
Transaction
FINANCE
CHARGE
$0.00
$0.00
Total FINANCE CHARGES:
Actual ANNUAL PERCENTAGE RATE:
$0.00
0.00%
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION.
INCLUOE THIS PORTION WITH YOUR PAVMENT MADE PAVABLE TO TARGET NATIONAL BANK.
Target National Bank an affiliate of
o TARGET
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII~IIIIIIIIIIIIIIIIII11II1111111111111111111111
Account Number 4352-3783-4055-4738
New Balance $3,612.39
Minimum Payment Due $3,612.39
Payment Due Date January 21, 2006
Amount I
Enclosed $
NEW PHONE. HOME OR
E-MAIL ADDRESS?
PLEASE UPDATE ON
REVERSE SIDE.
OFFICE COPY
1,1,1"1,1"1"1,1,1,1,1"11,,,,,11,,,,111,,,1,.,111
TARGET NATIONAL BANK
P.O. BOX 59317
MINNEAPOLIS, MN 55459-0317
STATEMENT PAGE NOT PRINTED
-
111 SALEM CHURCH RD
MECHANICS BURG, PA 17050-2835
1",111",111""1,1,11"",1,11"1",11,,1,1,,,,11,,,111",11
- "1 ",1"\
t.x"'-\L-1I~ rl
0000750361239036123990435237834055473871
-
Target National Bank
an affiliate of Target
o TARGET
Statement Closing Date: December 27, 2005
Page 2 of 2
1111111111 " II
Account Number: 4352-3783-4055-4738
LEEANN C CARLSON
Target Rewards Status
You're on your way to earning the 1000 points needed to get your Target Rewards certificate. It'll get you
10% oW on a full day of shopping (with your Target Visa) at Target stores. Use your Target Visa often,
and enjoy the savings sooner!
Points Earned Previously
Points Earned This Month
708
+0
New Balance
708
'Subject to Target Rewards program rules.
Special Announcements and Exclusive Offers
Thanks to you, we've already raised more than $154 million for education.
Every time you use your Target Visa, you add to our donation
to Cumberland Valley High School. Thanks again for
participating in the Take Charge of Education program. For
both teachers and students, you've truly made a difference.
As a valued Target Visa cardholder, you'll always be the first to know.
Like to get the scoop on exclusive promotions, savings and
updates? Simply write your e-mail address on the back of
this bill and mail it in with your payment. Whenever we've got
something new to share, you'll be the first to hear about it.
In
Court
Judicial (Circuit/District)
Original Creditor Name: T ARGET NATIONAL BANK
Debtor Name: CARLSON, LEEANN C
Co' Debtor Name:
Account Number: 4352378340554738
AFFIDAVIT OF ACCOUNT
ST ATE OF MINNESOTA
COUNTY OF HENNEPIN
S8;
The undersigned, CHRISTIE COMES states that:
I. 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 $ 3612.39.
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.
UwA~
Authorized Agent ofT ARGET NATIONAL BANK
Subscribed and sworn to before
Me on 3rd day of January, 2006
~;i,~
:::n:i:~ii:n expires _ I /3 t! ~~ ~ ~
MARGARET L OLSEN
Nolary Public
MInnesota
M'II:0('1fT!I%in~FxpiresJ81111ary31 2008
4352378340554738
Al44 PATENAUDE & FELIX, AP.C
.
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities, that she is, Christie Comes, Assistant Secretary, of Target National Bank,
Plaintiff Herein, that she is duly authorized to make this Declaration, and hat the facts set forth in the
foregoing Complaint in Civil Action are true and correct to the best of her knowledge, information and
belief.
l r C\
'lvVV\~ ~..
Christie Comes
Authorized Agent of Target National Bank/Target Visa
4352378340554738
AI44
PATENAUDE & FELIX, A.P.C
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GREGG L. MORRIS, ESQ,
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A 1D#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant( s),
)
)
) NO, 06-1937 CIVIL TERM
)
)
)
)
)
)
)
TARGET NATIONAL BANK
Plaintiff,
v,
LEEANN C CARLSON,
PRAECIPE FOR
DEFAULT JUDGMENT
Filed on behalf of:
TARGET NATIONAL BANK,
Plaintiff
Counsel of Record for This Party:
Gregg 1. Morris, Esquire
Pa LD. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant(s)
)
)
) NO. 06-1937 CIVIL TERM
)
)
)
)
)
)
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TARGET NATIONAL BANK,
Plaintiff
v,
LEEANN C CARLSON,
PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
Please enter ajudgrnent against the Defendant(s), above named, for failure to file an Answer
to Plaintiff's complaint.
Amount claimed in Complaint
Interest from December 30, 2005
Attorney's fees
TOTAL
$3,537.39
$66,28
$0,00
$3,603,67
With continuing interest on the principal amount of$3,603.67, 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
Defendant(s) and Defendant(s) counsel (if known), after the default had occured and at least ten (10)
days prior to the date of the filing of this praecipe. A copy of the Notice is attached.
R 1. MO RIS, ESQUIRE
Patenaude & Felix, AP.C.
213 E. Main Street
Carnegie, P A 15106
(412) 429-7675
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant(s)
)
)
) NO, 06-1937 CIVIL TERM
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TARGET NA TlONAL BANK,
Plaintiff
v,
LEEANN C CARLSON,
PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF
NOTICE PURSUANT TO PA.R.C.P. I037(b)
COMMONWEALTH OF PENNSYLVANIA )
)
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and State,
Personally appeared Gregg L, Morris, Attorney for and authorized representative of Plaintiff, who being
duly sworn according to law, deposes and states that the Defendant(s), LEEANN C CARLSON, 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,
Public
IAL
TERESA L LESKO
Notary Public
CARNEGIE BOROUGH
ALLEGHENY COUNTY
My Commission Expires Feb II, 2006
GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX. A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant(s).
)
)
) NO, 06-1937 CIVIL TERM
)
)
)
)
)
)
)
TARGET NATIONAL BANK,
Plaintiff,
v,
LEEANN C CARLSON,
IMPORTANT NOTICE
Filed on behalf of:
TARGET NATIONAL BANK,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa LD. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, P A 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant(s)
)
)
) NO. 06-1937 CIVIL TERM
)
)
)
)
)
)
)
TARGET NATIONAL BANK,
Plaintiff
v,
LEEANN C CARLSON,
To: LEEANN C CARLSON
III SALEM CHURCH RD
MECHANICSBURG, P A 170502835
Date of Notice: May 02, 2006
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN
APPEARANCE PEROSONALL Y 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 MAYBE 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 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
By:
. MORRIS, ESQUIRE
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
I, GREGG L. MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK,
herby certifY that a true and correct copy of the foregoing document was served this day
by US First Class Mail, postage prepaid upon the following:
LEEANN C CARLSON
III SALEM CHURCH RD
MECHANICSBURG, PA 17050
. s, EsqUire
Pa aude & elix, A.P.C.
Attorneys for Plaintiff
213 E. Main Street
Carnegie, P A 15106
(412) 429-7675
Date: May 02, 2006
.
GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX. A.P.C,
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant(s ),
)
)
) NO, 06-1937 CIVIL TERM
)
)
)
)
)
)
)
TARGET NATIONAL BANK
Plaintiff,
v.
LEEANN C CARLSON,
NOTICE OF ORDER,
DECREE OR JUDGMENT
Filed on behalf of:
TARGET NATIONAL BANK ,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa 1.0, #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant( s)
)
)
) NO. 06-1937 CIVIL TERM
)
)
)
)
)
)
)
TARGET NATIONAL BANK,
Plaintiff
v,
LEEANN C CARLSON,
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: ( ) Plaintiff ( X) Defendant ( ) Garnishee ( ) Additional Defendant
. You are her~J notified that the following Order, Decree, or Judgment has been entered
agamst you on C!l.::J" fR J.Dolo
, I
( ) Decree Nisi in Equity
( ) Final Decree in Equity
( X ) Judgment of ( ) Confession
( X) Default
( ) Non-Pros
( ) Verdict () Court Order
( ) Non-suit
( ) Arbitration Award
(X) Judgment in the amount of$3,603.67, plus cost.
( ) District Justice Transcript of Judgment in the amount of $
plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle operator's license wi! be
~'P~d",bYtb'D""_~IOfT-l~~
By
Deputy
If you have questions concerning the above, please contact:
Name of Attorney: GREGG 1. MORRIS, ESQUIRE
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01937 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TARGET NATIONAL BANK
VS
CARLSON LEEANN C
MARK CONKLIN
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CARLSON LEEANN C
the
DEFENDANT
, at 0910:00 HOURS, on the 10th day of April
, 2006
at 111 SALEM CHURCH ROAD
MECHANICSBURG, PA 17050-2835
by handing to
LEEANN CARLSON
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
8.80
.00
10.00
.00
36.80
3)/'f/b/"Q.-,
Sworn and Subscribed to before
r%-;.~/~~-,
R. Thomas Kline
me this
day of
04/11/2006
PATE~~E & FEL~
~,y Eheriff
A.D.
Prothonotary
I
GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, P A 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff,
) NO. 06-1937 CIVIL TERM
)
)
)
)
)
)
)
)
)
v.
LEEANN C CARLSON,
Defendant(s).
PRAECIPE FOR
SATISFACTION OF
JUDGMENT
Filed on behalf of:
TARGET NATIONAL BANK ,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa J.D. #69006
Patenaude & Felix, A.P.c.
213 East Main Street
Carnegie, P A 15106
(412) 429-7675
!
/.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK,
Plaintiff
v.
LEEANN C CARLSON,
Defendant( s)
) NO. 06-1937 CIVIL TERM
)
)
)
)
)
)
)
)
)
PRAECIPE TO SATISFY JUDGMENT
TO: Prothonotary
Please satisfy the Judgment at the above-captioned action of record. Thank you.
Date: December 19, 2006
Sworn to and subscribed before me
this~dayof Otu~r 20'0("
-
~"^-.~
Notary Public
S, ESQUIRE
Patenaude & Felix, A.P.c.
213 E. Main Street
Carnegie, P A 15106
(412) 429-7675
NOTARIAl. SEAL
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I, GREGG L. MORRIS, attorney for Plaintiff, T ARGET NATIONAL BANK ,
hereby certify that a true and correct copy of the foregoing document was served this day
by US First Class Mail, postage prepaid upon the following:
LEEANN C CARLSON
l11 SALEM CHURCH RD
MECHANICSBURG, P A 170502835
Date: December 19,2006
s, sqmre
naude Felix, A.P.c.
Attorneys for Plaintiff
213 E. Main Street
Carnegie, P A 15106
(4l2) 429-7675
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