HomeMy WebLinkAbout00-01420
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ROBERT E. ANGST, ESQUIRE
Attorney I.D. #80042
PARK LAW ASSOCIATES, P.C.
25 E. STATE STREET
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE
ADDRESSES OF THE PARTIES ARE:
PTF: 2 NORTH I0-SALLE STREET
CHICAGO, IL 60602-3702
DEF: 1725 WALNUT BOTTOM ROAD
NEWVILLE, PA 17241
FARM PLAN CORPORATION
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff
vs.
SHAY P. FARWELL
Defendant
NO. 2000-1420
PRAECIPE FOR JUDGMENT
TO THE PROTHONOTARY:
Please enter Judgment in favor of the Plaintiff and against
the said Defendant for failure to plead or otherwise respond to
the Complaint and assess the damages as follows:
AMOUNT OF CLAIM
ATTORNEY FEES
PLUS ACCRUED INTEREST
LESS PRINCIPAL PAID
LESS OTHER PAYMENTS
$ 5,731. 74
$ 1,145.00
$ 1,720.08
$ 0.00
$ 0.00
TOTAL
$ 8,596.82
PLUS ADDITIONAL COSTS
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR
SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS
CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
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I certify that written notice of the intention to file this
Praecipe was mailed or delivered to the party against whom
judgment is to be entered and to the attorney of record,. if any,
after the default occurred and at least ten (10) days prior to the
date of the filing of this Praecipe. A true and correct copy of
the notice pursuant to Pennsylvania Rule of Civil Procedure No.
237.1 is attached hereto and marked E 'bit "A".
ESQUIRE
e Plaintiff
AND NOW, (Yl.:;;; I l b .)(Vl ( Judgment
is entered in favor of t~e Plaintiff and against the Defendant by
Default for want of an Answer and damages assessed at the sum set
forth in the above certification. 4
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PROTHONOTARY
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED
THAT WE STATE THE FOL~OWING TO YOU. THIS IS AN ATTEMPT TO COLLECT
A DEBT. ANY INFORMATIN OBTAINED WILL BE USED FOR THAT PURPOSE.
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ROBERT E. ANGST
ATTORNEY I.D. # 80042
PARK LAW ASSOCIATES, P.C.
25 EAST STATE STREET, P.O. BOX 1779
DOYLESTOWN, PA 18901
(215) 348-5200
ATTORNEY FORPLAINTWF
I HEREBY CERTWY THAT THE
TRUE AND CORRECT ADDRESS IS:
PLAINTWF: 2 NORTH LASALLE
SUITE 900, CHICAGO,IL 60602
DEF: 1725 WALNUT BOTTOM RD
NEWVILLE, P A 17241
CUMBERLAND COUNTY COURT OF COMMON PLEAS
FARM PLAN CORPORATION
Plaintiff
VS
SHAYP. FARWELL
Defendant
NO. 2000-1420
NOTICE OF PRAECIPE FOR
ENTRY OF DEFAULT JUDGMENT
TO: SHAYP. FARWELL
1725 WALNUT BOTTOM ROAD
NEWVILLE,PA 17241
DATE OF NOTICE: 4/10/00
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WlTHlN TEN (10) DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAlNST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. W
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, 4" FLOOR
CARLISLE, PA 17013
(717) 240-6200
PARK LAW ASSOCIATES,P.C.
BY~G~
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT A
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ROBERT E. ANGST, ESQUIRE
Attorney I.D. #80042
PARK LAW ASSOCIATES, P.C.
25 E. STATE STREET
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE
ADDRESSES OF THE PARTIES ARE:
PTF: 2 NORTH LASALLE STREET
CHICAGO, IL 60602-3702
DEF: 1725 WALNUT BOTTOM ROAD
NEWVILLE, PA 17241
FARM PLAN CORPORATION
CUMBERLAND COUNTY
COURT OF COlVJlVlON PLEAS
Plaintiff
vs.
SHAY P. FARWELL
Defendant
NO. 2000-1420
VERIFICATION OF NON-MILITARY SERVICE
COlVJlVlONWEALTH OF PENNSYLVANIA:
COUNTY OF BUCKS
Robert E. Angst, Esquire, being duly sworn according to law,
deposes and says that he will make this Affidavit on behalf of the
within Plaintiff, being authorized to do so, and that he knows of
his own personal knowledge and therefore avers, that SHAY P.
FARWELL, Defendant is over 21 years of age; that his/her place of
residence/business is located at 845 AMOSLAND ROAD, MORTON, PA
19070 and that he/she is employed and that he/she is not in the
Military or Naval Service of the United States or its Allies or
otherwise within the provisions of the Soldiers and Sailor Civil
Relief Act of Congress of 1940 and its amendments.
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ROBERT E. ANGST, ESQUIRE
Attorney I.D. #80042
PARK LAW ASSOCIATES, P.C.
25 E. STATE STREET
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE
ADDRESSES OF THE PARTIES ARE:
PTF: 2 NORTH LASALLE STREET
CHICAGO, IL 60602-3702
DEF: 1725 WALNUT BOTTOM ROAD
NEWVILLE, PA 17241
FARM PLAN CORPORATION
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff
vs.
SHAY P. FARWELL
Defendant
NO. 2000-1420
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are
hereby notified that a Judgment has been entered against you in
the above proceeding as indicated below:
{x} Judgment by Default
{ } Money Judgment
{ } Judgment in Replevin
{ } Judgment in Possession
{ } Judgment on Award of Arbitration
{ } Judgment on verdict
{ } Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE
CALL: PARK LAW ASSOCIATES, P.C. at this telephone number: (215)
348-5200.
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PROTHONOTARY:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS QUI RED
THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT TO COLLECT
A DEBT. ANY INFORMATIN OBTAINED WILL BE USED FOR THAT PURPOSE.
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ROBERT E. ANGST, ESQUIRE
Attorney I.D. #80042
PARK LAW ASSOCIATES, P.C.
25 East State Street
P.O. Box 1779
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FARM PLAN CORPORATION
Plaintiff
cJ.fTt1) - FIX;
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VS.
SHAY P. FARWELL
Defendant
NO.
NOTICE
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 other claims
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 OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CO~_.l- l""UJl~lIJll..il'l~QR
4th -, ~r, Cumberland County G6~ . ,
Carlisle, PA 17013
(717) <He (,,99
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THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
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ROBERT E. ANGST, ESQUIRE
Attorney I.D. #80042
PARK LAW ASSOCIATES, P.C.
25 E. State Street
P. O. Box 1779
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
FARM PLAN CORPORATION
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff
VS.
SHAY P. FARWELL
Defendant
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NO. :Zovv" 7. ~
CIVIL ACTION - COMPLAINT
COUNT I
1.
Plaintiff, Farm Plan
institution with an
Wisconsin 53705-0328.
Corporation,
address of
is a national
P.O. Box 5328,
financial
Madison,
2. Defendant is an adult individual with an address at 1725
Walnut Bottom Road, Newville, Pennsylvania 17241.
3. At the request of the defendant, plaintiff issued the
defendant a credit card subj ect to the terms of the card
member agreement. A true and correct copy of the credit
application is attached hereto, made a part hereof and marked
Exhibit "A".
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4. Defendant has incurred charges for purchases, cash advances
and/or finance charges in the amount of $5,731.74 as of
November 25, 1998.
5. Defendant's obligation is based on a subsisting debt was in
writing and arises from a pre-existing account.
6. Defendant has not obj ected to account statements issued to
the defendant on a monthly basis.
7. Defendant is liable to plaintiff on this account as an
Account Stated.
8. Defendant has failed to make payments as they became due
under the terms of the card member agreement. A true and
correct copy of the account agreement is attached hereto,
made a part hereof and marked as Exhibit liB".
9.
Defendant
agreement
$5,731.74
is in default of the terms of the card member
and is indebted to plaintiff in the amount of
plus interest at the rate of 12.25% per annum.
10. Pursuant to the terms of the card member agreement, plaintiff
is entitled to a reasonable attorney's fee and plaintiff will
incur an attorney's fee in the sum of $1,145.00.
WHEREFORE, plaintiff demands judgment against the defendant
in the sum of $5,731.74 plus interest at the rate of 12.25% per
annum from November 26, 1998, plus a reasonable attorney's fee of
$1,145.00 and Court costs.
COUNT II
11. Plaintiff realleges each and every allegation contained in
paragraphs 1 through 10 of this complaint and incorporates
them herein by reference as if the same were set forth at
length.
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12. The defendant received a monetary benefit of $5,731.74 that
was in fact appreciated by the defendant.
13. By virtue of the circumstances surrounding the request for
plaintiff's credit card, the completion of the application
and use of plaintiff's credit facilities, the defendant
knowingly and voluntarily accepted the benefits bestowed.
14.
It would be inequitable for this Court to allow the
to retain the benefits of the funds or to be
enriched at the expense of the plaintiff.
defendant
unjustly
15. In accordance with the law there is interest due at the rate
of 6% per annum from November 26, 1998.
WHEREFORE, plaintiff demands judgment against the defendant
in the sum of $5,731.74 plus interest from November 26, 1998 and
costs of this action.
Respectfully submitted,
PARK LAW ASSOCIATES, P.C.
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BY: ROBERT E. ANGST
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STAl E OIJ:J'l
COUNfY 'OF F()\~
AFFIDAVIT OF INDEBTEDNESS
ThEa under"signed, beIng duly s....orn, dep,)ses i1nd st;~tes that he/she Is
an er"ploYE'e/agent of, I-ARM PI AN (:OHPOI(A'r I(lt4;
and h,~s knowledge of the ,1CCI)lHlt bt''ll,''tncB, \"lnd ;,5 duly authOt~i.'t8d to nlill,€?
this affidavit.
Affi.ant states that the anlOunts ShOt..HI be 1 CH....I are ta~uHl/cC'~]cLJ.lat8d frofll
the original books and records o,f the above n~'ned plaintiff, ~nd b~sed
on information and belief, affiant stnt~s thnt the nmount due to
FARM PLAN CORPORArION;
by SHAY P lARW~LL
on account(s): 69100 13169
fo," purchases by or' set'vices t'endet'ed to the above nm"ed defendt;nt(s) or
member(s) of his/her f~mlly is i1S follo....s:
Balance:
Plus [ntCt~est:
Less Payments:
Bali1nce Oue:
S:
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b731.74
tL00
0.00
b/:31.74
$
S:
,
$
Affiant states that the amount shown nbove is true and correct and that
there Mre no setoffs or cO!Jnterclailns dv~il~ble to defendant(s)~
Further affiant sayeth not.
Mw~
Affi.~nt
R.€coul&~ t~ "..J .'S~i&Iv It
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orn tn BB'fot~e Ine
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Reference I: 1156054
Account #: b9100 131b9
ICRI8TEN N. JAGERSON
MY COMMISSION EXPIRES
May 17,2000
1\ICF(09/95)M r3
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BILL caCE: C2 PRoF OT: ai/11
;:.J'ndlviduafWJthAulhorizedUser F"!pr. CArE: 57/10 171....~1S62-5
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Stale Zip YD""~ lhtllO
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T\fP(t of .&CCCVflt ~:.a:>led
rr. Individual
No one ql~ rr1ay use l~,j; =UO"lt
About Yourself Pt~:1~ complete entire appliC2lllfon, leave no bl,nk spaces.
Lit31Name F'rst 8ortrJ.!wfI So::w~v
F.I1iZ.WELL
SHAY
Home Ad(:ttlU nv...lt>. C'ly
~wu'.ll(!, R..D.dj Bor7.F
PfllWJ"''lAdC1<MS.'labovO''''d....tt\ant'''''J;Y'la~
00 you Farm? 'It Yes :J No
Years in farming L/.._<;'
Do you: Own Farm
Type of operation
(Cho.:kaaltlal&pp(1'l
o Renl Farm :J Other:
:J aaer :J Poullryieggs
~ Dairy ~ Horses
b Hogs Cl Other
LlCorn
~ Soybeans
OWhaat
8 Tobacco
:JCilruS
o Colton
:.JFruil
:.J Va'getables
:::JOthor(s)
VOUr3IM,o
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Pre:>e'11 Emllloylll
Position
yrs.
mo,
Addl11$$
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Annual Farm ~ aO() Annllallncomo A.M1,l~ trlcome
tn~omllo(Oro5sJ$ ~ OH.rllrmJob$ ClhorSoUlCO$'S
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Jl.3S<mS StO(j~ aU f> l'~1l1ItllO$3q. 9dD :eIWO"3'7c:',OO {l
Caon.l""".CulIO' ",EClU-pmefl1....' (m,;;;"') DoOlo.Mortgogeo,.", (~ """"'".I.W>iI....
'lncomel.om ahmony. cllJd suppOrt Of 5.Opa.al6 ma,nlo,lr.4nCll paym'ln15 n&&Cl nOl be d'E.CloSOd II you do 1'10I ",.sh 10 halM' II conSldO,"d all. t11lS1..1Q.r fllpa~ IhtS obl'll'allOn.
OllSC.lbll$OlJrces:
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Full Nllme I R,alal.0MhIPIOYOU I a"lh(lalll I Sc>cIaISoctlrlly/l I HomllPr>one
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tlomeMdrllloll RoullJt Clly Counly Slale Zop
l'Iamo&Ad'd.essofEmployer I ;onlhlYlncome
1'Itt<:I<ing
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Do you have: 0 American Express 0 MasterCard ~ VISA [] Diners Club 0 Carte Blanche . one
Calalog Cel(l RalalfmCQS
Do you have:
00 you ha.ve.
,Sears 0 J.e. Penney
A peA Loan
OYesDNo
_ Montgomery Ward ::J None
.,. FLB Loa"... I.' ? ~ FHA Loa"
nYeswNo(..,Q.... _s ~ ~OYesC1No
C't.\I:S'lAfE
o Other
CI".HAI(;.
Have you ever liIed Bankruptcy [i ''H.'~ )M':o
Has a judgement ever been filed against you [J Yas ~o
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Bosiness(es) that sent YOll thiS apPlication: ___
p, ~.:;en! Farm Plan Account Number: --'1Lo/!!. ~
Anticipated monthly purchases: ~Q-L!g ~ N 't' I<IVO W J -:r n - .:roo:)
Anticipated rnontl1ly purcnases ~xcelJding ,500.00 will reqUIre additIonal finanCIal mformatlon.
1, I hereby apply for a Fau,j Plan account o.nd agree 10 Iho lerms and conditions of the Farm Plan Credit AgfE'amenl. a copy of which I havo
recoived, This applicallon shall romaln the property of Farm Plan whether or not D Farm Plan line of credit is eSlabllsMd. I cortiry lha: thG
above inlormation is correct as of this date
2. I understand that Farm Plan reservos the rIght al any time to wilhdraw my credit approval. or to terminate, or otherwise limil myaccount.
3. I authorize Farm Plan to obtain or exchange a.ny informalion It may require relative to Ihis application from any source, including my financial
institutions and Irade suppliers, and I authorize each SOlJrce to provide Fl!rm Plan wilh such information. (_ 30 . 61
4. If married, I understand I have the right 10 apply ror a separate credit account in my own nama. (J I
For Wisconsin Residents Only: Id
For Separate Account of mamed applicant: The credit extended through my Farm Plan Account, if approved. will b^ incurrod In the int&rest of
my marrIage or family.
For Jolnl Account with non.spouse: my co-applicant is and hislher separate
application is attached.
NOTICE to BUYERS
00 not sign tfds before you read It or if It contoln. any b18nk sp.!Ices, You are entitled to an exact copy of Illny paper you sign, You IuIve
the right to p!!y In advance the ful mount due, By signing this applfcatfon, applicant acknowledge!! recelpf of a credit agreement,
p
r.pe(ica~:.~ ~i.:-~~
J1bv 13/';-1
Dale Co-Appllcant's Sign3ture
Sill a:':>"30f.)C~
Date
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r.\R~[ PL.\:\~ CREDIT .\GREE\lE~T
THr5 IS rD[R .-\GREDIE:\I,
PLESE RHO IT A.\D KEEP IT FOR 'iOrR RECORDS,
TER,\IL'iOLOGY. In t.hi~ Agreement the words you, your, and yours mean
each person who applies for and is granted a Farm Plan Account, as well as
any person permitted to use the Account. The words we, us, and our mean
Farm Plan Corporation. lfthis Agreement is governed by TN law, the words
we and OUI mean the seller or its assignee.
FARM PLA.'J ACCOGNT. You request a Farm Plan Account from us, and
further authorize us to issue a Farm Plan .\ccount card to each merchant from
whom you may make a purchase. By applying for a Preferred Account. or by
using a Merchant Authorized Account to make a purchase from a merchant
who requests us to open one for you, you agree ilial this Credit Agreement will
apply to all purchases made through your Farm Plan Account by you or any
person )'ou authorize. You authorize us to bonor any purchases you make by
telephone or mail on your Account. You agree that a signature is not necessary
as identification in such cases. You agree that any authorized use of your
Account constitutes your acceptance of all the terms and conditions of this
Agreement. as it may be amended from time to time. If you submit your
application to us by facsimile transmission (fax), you agree that the fa'(ed copy
of that document will bave the same effect as a signed original. You will
promptly notify us of any suspected loss, theft. or unauthorized use of the
Account. If that notice is given orally, you witt confirm it in writing. You may
be liable for the unauthorized use of your Farm Plan Account before you notify
us orally or in writing at Farm Plan Corporation. P.O. Box 5328, Madison.
Wisconsin 53705-0328 of the unauthorized use. In anv case, vour liabiIitv will
not exceed S50. You consent and agree that your telephone conversations with
us mav be recorded to further impro\'e our customer service. You acknowledge
that no one acted as a broker for the account. You agree to give us prompt
notice of any chan&e in your name, mailing address, or place of employment.
For the purposes 01 this Agreement, you will be deemed to "reside" in the
state of your billing address as shown on our records. If more than one person
or entity signed the application, each is jointly and severally responsibre for
all obligations, and amounts due, under this agreement.
ACCOL~'TTYPE. If your Farm Plan Account arose through our purchase of
your existing account balance with a merchant, or at the request of one or more
merchants. without your submission and our approval of a Credit Application,
vour Account will be classified as a .\ferchant A.uthorized .-Iccount. If vour
Account resulted from our approval of your completed Credit Application for
either: 1] a new Account, or for 2) the conversion of vour ~[erchant Authorized
Account. your Account will be classified as a Prejeried Account. Certain
special features or promotions we may offer from time to time may be made
available only to Preferred .-\ccounts. When we open your Account. and on
each montJ.lv statement. we lNiIl indicate whethllr vour Account is either a
Preferred or 11erchant Authorized Account. .
CREDIT IDlITS, We will establish and advise rou of vour credit limit.
We may change your credit limit at any time. You may request a change to
your credit limit by writing us at the above address. If you have a ~Ierchant
Authorized .-\ccounl. it is useable only at the merchant(sl who requested us to
finance your purchases from them.
ACCOLNl' eSE. By applying for or accepting a Farm Plan Consumer Account,
you agree to use your Account primarily to make purchases for personal.
familv or household use. rather than for agricultural. commercial or
gover'nmental use. (We also offer Farm Plan .-\gricultural, Commercial or
Governmental Accour.ts with higher credit limits, different rates and
repayment terms for agricultural, commercial or governmental purchases.
Please '....rite to us at the above address if you would like to apply for one.)
You can make purchases up to the full amount of your credit limit. and
you agree to pay us all amounts charged by the use of the Account, plus
Finance Charges, and the other charges described bdow, as provided in
this.-\greement.
W~ are not responsible for the refusal of anyone to allow a purchase to be
made through your Farm Plan Account.
~[ONTIILY STATEME~'T. We will send vau a monthlv statement whenever
there is activity on your Account, ualess the onh' att(vity is a payment in fulL
We will bill \'ou on the montblv statement for al1 amounts vou owe.
Your monthfy statement will snow your :\ew Batance. any'Finance Charge.
I
EXHIBIT
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the Minimum Required Pa~'ITlent and the Payment Due Date. In addition, it
will sbow vour Credit Limit, an itemized list of current Purchases, PaYments.
and CreditS. as well as other information concerning your Account. ~
PAYMENt'. The Payment Due Date is the date the paymenl is due at the
address shown on the front of your monthly statement. You may at any time
pay your entire New Balance or pay more than the Minimum Required
Payment, and you will avoid or reduce Finance Cbarges by doing so. However,
pa.ment of more than the ~linimum Required Payment, while reducing vour
balance, will not prepay or be applied against future Minimum Requireu
Payments. All payments must be in U.S. dollars and drawn on funds on
deposit in the United States. If your Payment Due Date falls on a SatUIday,
Sunday or holiday, the Payment Due Date will not be extended. For information
about your rights regarding billing errors, refunds or adjustments. please refer
to the section . What ToDo lfThere's An Error In Your Bill. on the reverse
side. You are responsible for notifying us of any change in your billing address.
F1NA..~CE CHARGE RATES. Finance CharO'es on your Farm Plan Account win
be calculated using variable rates that wilfbe determined by reference to a
"Base Rate" to wbich is added a "Spread" to arrive al the current rate.
For residents of all states except AR and TX, the Base Rate from which
your variable rates will be determined is the annual percentage rate of
interest announced publicly from time to time by Citibank, N,A. in
New York, New York as the base rate it uses for interesl rate
determinations, which was in effect at the dose of business on the
fifteenth (15th) calendar day of each month, or the next succeeding
business day if the fifteenth is nol a business day ("Reference Day").
Subject 10 any applicable rate restriction under Governing Law, the
Advantage Spreads added to the Base Rate to determine the .A.l'mUAL
PERCENTAGE RATES that will apply to your Purchase balances will be:
Preferred Merchant Authorized
Advantage Spread 8.9% 10.9%
For residents of TX the variable ANNUAL PERCENTAGE R." TES will be
calculated in the same manner and will be the same as the rates in the states
above, unless the quarterly interest rate ceiling announced by the Texas
Consumer Credit Commissioner ("Index Rate") to become effective on the first
day of each calendar quarter ("Reference Day") is lower. in which event the
lodex Rale will be vour ANNUAL PERCENTAGE RATE. The lodex Rale is based
on the average aucllon rale for 26.week U.S. Treasury Bills for the preceding
three months, multiplied by two, subject to a minimum Ju~N1JAL PERCThTAGE
RATEofH% and a maximum of22%.
For residents of AR the Base Rate is tbe Federal Reserve discount rate for
gO-day commercial paper for the Federal Reserve District including that slate,
effective when announced ("Reference Day") by the applicable Federal
Reserve District Bank.
Subject in AR to a maximum ANNUAL PERCENTAGE RATE of 17%, the
Standard Spread added to the Base Rate to determine the ANNUAL
PERCENTAGE RATES that will apply to your purchases will be:
Preferred Merchant Authorized
Standard Spread ~ 5%
In AR. rate increases, and in all other states, rate increases and decreases, that
result from chan$es in tbe Base Rate or Index Rate will take effect on the first
day of your first oHUng cycle commencing after the Reference Day on which
Base or lodex Rale changes. [n AR, rate decreases will take effect on the first
day of the statement period during which the Reference Day on which the
Bo.se Rate decline occurs, and each such cbange will constitute a new contract
between us.
In all states, changes in your variable rates will apply to your existing Account
Balances as well as to future purchases. An increase in your rate will increase
the total Finance Charge accruing on your Account and the balance on which
your ~nnimum Required Payment is calculated. For example, if the Base Rate
or [ndex Rate (and thus the applicable variable rate) were to increase by 5%.
and the average daily balance to which the new rate applied was 51,000, vour
FI:-JANCE CHARGE for that month would increase b\. S4.17 as a result of the
increase in the variable rate. -
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Currently etfecti\"e rates are shown below~
Statfof Daily ANNUAL
Y cur Retlidence Periodic Rates(s) PERCENTAGE RATES(S):
Merchant Merchant
Preferred Authorized Preferred Au1horized
Purchases Purchases Purchases P-
AK. t>Z, CO, DE,
DC, 10, IL IN, lA,
MD, MI, MS, MO,
MT, NV, NH, NJ,
NM, OH, OK, OR,
RI. SC, SO, TN. UT
VA, WA, WY
Advantage Rate: .047671% .053151% 11,4% 1t.:4%
CA Advantage Rate: .047671% .052603% 17.4% 19.2%
AL, CT, FI.., GA,
HI, KS. KY, LA. ME.
MA, MN, NE, NY.
NC, NO, PA, VT,
WI,WV, .047671%
Advantagl;1 Rate: .049315% 17.4% 18%
TX Advanf8ge Rate: .038356% .038356% 14% 14%
AR Standllord Rate: .027397% .027391% 10% 10%
The abOVel rates are correct as of the date of printing, 02/01/98, but are subject
to change after that date. To find out what may have changed, write to us at
Farm Plan, P.O. Box 5328, Madison, Wisconsin 53705-0328; or call Customer
Service at 1-800-356-9033.
FINANCE CHARGE CALCULATION. FINANCE CHARGES will accrue on your
Account Balance as follows: -
On purchases we will add a FINANCE CHARGE, calculated as shown
below, if your New Balance is not paid in full on or before the Payment
Due Date. To avoid additional Finance Charges on your purchases, you
must pay the New Balance in full on or before the Payment Due Date.
The amount of your FINANCE CHARGES will be determined as follows:
We use the daily periodic rates and corresponding ANNUAL
PEItCENTAGE RATES shown in this Agreement for the state of your
residence. The applicable periodic rate is applied to the "Average Daily
Balance" of your purchases, including current transactions (1), during
the current billing cycle.
To get the "Average Daily Balance," we take the beginning balance of
your purchases, starting with any Previous Balance outstanding on the
first day of the monthly billing cycle, add any new purchases (1J and
debits [other than late payment fees) and subtract any payments or
credits (2}. This detennines the daily balance. Unless.we elect to use a
later date, purchases are added to the daily balance as of the date of
purchase.
We total the daily balances for the billing cycle and divide the total by
the number of days in the billing cycle. This gives us the "Average Dailv
Balance" which is shown on your monthly statement. .
(1} In ME. ~1A, MT and NM, new purchases are not added in.
(2) I" AR. CA, FL, IL, MD. MS. NH, ND. PA. RJ and TN, u"paid finance
charges are also subtracted.
A MINIMUM FlNA..'lCE CHARGE of 50 cents will be made when the result of
the application of the periodic rate(s) to the "Average Daily Balance" is less
than 50 cents, unless you reside in AL, AR, CA, DC. FL, ME, MD, MI. :VL\l, NE,
NM, ND. OH, RJ, TX. VT or WY.
MINIMlJMREQl'IRED PAYMENT. You agree to pay each month a Minimum
Required Payment equal to:
1. Any late payment fee due; plus
2. Any amount past due; plus
3. Any amount by which your New Balance exceeds your credit Limit;
flus
4. for Purchases:
(al Either the greater of: 525. or 10% of your New Balance if it
exceeds 525:
(bl Or your entire New Balance, if it is less.
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SPECIAL PROMOTIONS. From time to time special financing tenns, such as
extended free periods, incentive interest rates on certain purchases or for
limited time periods, or other promotions may be available for the purchase
of certain items from participating merchants. These special terms will be
disclosed by the merchant at the time of purchase. Purchases you make during
these special promotions will be separately identified on your monthly
statement and will become part of the balance on which your FINANCE CHARGE
and Minimum Required Payment are calculated at the time provided in the
special terms disclosure.
OTIIER FEES AND CHARGFS. LATE PAYMENT FEES: IT within 10 davs after
the Payment Due Date we have not received payment of at least the mnt
portion of your Minimum Required Payment (Minimum Required Payment
less unpaid late payment fees and past due amounts), we will add to your
Account a late payment fee calculated as a percent of the unpaid balanca of
the current portion of your Minimum Required Payment ("Late Balance~) or a
predetermined dollar amount. Late payment fees are: $10 in AK, AR, CO. cr,
DE, FL. GA. Hl.IL.IN. lA, KY, LA, MD, MI, MS, Mf,NV, NJ.NY, OK. SD, \VA
and WI; the lesser of $10 or 5% of your Late Balance in AL, KS, SC, UT and
VA; the lesserof$5 or5% of your Late BaIance in AZ, MO, NE, OR. W\' and
WY. There is no late payment fee if you reside in a state not listed above.
RETURNED PAYMENT FEE. IT you send us a check that is dishonored, we
will add to your Account a fee of $20, or such lesser amount specified by
. awexpress" ~
COLLECTION COSTS. Unless you reside in NH. if we have to refer collection
of your Account balance to an attorney, you will pay the attorney's fees plus
court costs and related fees including any bankruptcy fees and costs, to the
extent not limited or prohibited by Governing Law. --
ACCEPTING PAYMENT. We can accept late or partial payments, as well as
payments marked "paid in full" or with other restrictive endorsements.
without losing any of our rights under this Agreement.
CREDIT REPORTS. We may report your perfonnance under this Agreement to
credit reporting agencies and others who request a credit reference from us.
As required by law, you are hereby notified that a negative credit report
reflecting on your credit record may be submitted to a credit reporting agency
if you fail to fulfill the terms of your credit obligations. We may ask credit
reporting agencies or others you list as a credit reference for consumer reports
or information regarding your credit history at any time for all legitimate
purposes, including credit decisions and the review and collection of your
account. You authorize us to use information about you far other busine<...s
purposes, including sharing information with our corporate affiliates.
CLOSING YOUR ACCOUNl, You may close your Account at any time by
notifying us in writing, We may dose or suspend your Account to future
purchases at any time without prior notice. We may dose or suspend your
Account to future purchases if your Account has no activitv for 12 or more
months. Regardless of the closing or suspension of your Account, you remain
responsible for paying the amount you owe us according to the terms of dlls
Agreement.
SECURITY INTEREST. Unless vou reside in NY or W A, or in NC and the
ANNUAL PERCENTAGE RATE"on a purchase or transaction exceeds 15'.)."J.
you grant us a purchase money security inlerest in all merchandise purchased
through your Account, and its proceeds, including insurance proceeds.
Our security interest continues until such merchandise is paid for in full ~y
application of your payments in the manner described in this AgreemenL
PAYMENT APPUCATION. Payments are applied both to your minimum
required payment and to late fees and finance charges for which payment:.s
due, in that order. and then to the remaining balance. Pavments are applied,
within that remaining balance, first to balances described on prior montbiy
statements and then to new balances as follows:
To transaction balances for which payment is due: to the regular
balances first, in order of posting; and then on other account bala.r:ces.
also in the order they ',vere posted 10 the account.
Then to transaction balances for which pa\ment is deferred, accor~i:1g
to when payment is due, re~ardless of die 'type of balance. (When.
finance charges are deferreo, payments are applied first to defeme
finance charges and then to the remaining balances by transaction..
Payment will be credited as of the date of receipt at the address an the
payment stub of your Statement if received by 9:00 a.m. Eastern Time \1'J:-:day
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through Fridav (otherwise next business day); but if payment is not
accompanied by the payment stub or not received at that location, credit may
be delayed up to five days.
MERCHAI~T CHARGEBACKS, We may charge back to a merchant who sold
goods or services to vou on your Account, any part of your Account balance
related to those purcbases. In that event. this Agreement will be deemed
assigned to the merchant to the extent of the chargeback, You agree to such
an assignment and further agree to pay the merchant the amount of such
chargeback in accordance with the terms of this Agreement.
DEFAULT, You will be in default if: (a) you fail to pay the ~finimum Required
Payment within 10 days after the Payment Due Date on two occasions within
any 12-month period; (b) the value of our security interest in anv collateral is
materially impaired; (c) your ability to repay is materially reduc'ed by your
exceeding your credit limit, by a change in your employment, by an increase
in your obligations, by bankruptcy or insolvency proceedings involving you,
by your death, or (for community property state residents only) by a change in
your marital status or domicile: or (d) you fail to perform any other of vour
obligations under the terms of this Agreement as it may be amended. .
Upon your default, we may close your Account to future purchases and, to the
extent not prohibited by Governing Law, demand immediate payment of your
entire Account balance, after givin! you any notice and opportunity to cure
the default required by applicable aw, In addition, we shall have 811 the rights
of a secured creditor under the Uniform Commercial Code and other
applicable law.
Flor~da Residents.: You agree th~t, should we obtain a judgment against you, a
porhon of your dIsposable earnmgs may be attached or garnished (paid to us
by your employer], as provided by Florida and Federal law.
DELAY IN ENFORCEMENT, We can delay enforcing our rights under this
Agreement without losing them.
GOVERNING LAW. This Agreement must be approved, and all charges and
payments to your Account processed by us at our office in Madison, Wisconsin,
Therefore, this Agreement will be governed by Wisconsin law if the application
of that law is necessary to validate any of its provisions. Otherwise, the law
of your state of residence will govern this Agreement, and in any event will
apply to our recovery of any collateral located there. This is the entire
Agreement between you and us and no oral changes can be made.
Invaliditv of any provision of this Agreement shall not affect the validitv and
enforceability of the remainder of its terms. For TN residents this Agreement
will be governed by the Tennessee Retail Installment Sales Act. We hold
California Finance Lender's License Number 603-2234, FOR INFOR.\1ATIDN
CONTAcr TIlE DEPARTMENT OF CORPORATIONS, snTE OF
CALIFOR,"-l1A. We are licensed and examined bv the State of Texas - Office of
Consumer Credit Commissioner. Call the ConsUmer Credit Hotline or write for
credit information or assistance with credit problems. Office of Consumer
Credit Commissioner. 2601 North Lamar Boulevard, Austin, TX 78705-4207.
Texas residents may call (512)479-1285 or 1-800-538-1579 (in TX).
CHANGDlG TInS AGREEMENT. We may chan"e this Agreement. including
the Finance Charge Calculation and the Annuaf Percenta"e Rate. at anv time.
If we do, we wil! mail you theIrior written notice requir~d by law. TO' the
extent that the law permits an we indicate in our notice, the chan"es will
apply to your existing Account balance as well as to future transactions.
ASSIGNMENT: TN Residents Only: It is expected that this Agreement and
purchases made under it will be submitted for approval to Farm Plan
Corporation ~FPC) of Madison, Wisconsin without further notice to you and. if
approved. will be assigned to FPC. All of Seller's rights under this ,\greement
also apply to any assignee or holder of this Agreement.
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WHAT TO DO IF THERE'S AN ERROR IN YOUR BILL,
YOUR BILLING RIGHTS,
KEEP TIllS NOTICE FOR FUTURE (SE,
This notice contains important information about your rights
and our responsibilities uncler the Fair Credit Billing Act.
NOTIFY US IN CASE OF ERRORS OR Q(ESTIONS
ABOUT YOUR BILL,
If you think your bill is wrong, or if you need more information
about a transaction on your bill. write to us (on a separate
sheet] at the address shown on the reverse side of your billing
statement. Write to us as soon as possible. We must hear from
you not later than 60 days after we sent you the first bill on
which the error or problem appeared. You can telephone us,
but dOll! so will not preserve your rights. In your letter, give
us the fa lowing information:
. Your name and account number
. The dollar amount of the suspected error
. Describe the error and explain, if you can, whv you believe
there is an error -
. If you need more information. describe the item you are
unsure about.
YOUR RIGHTS AND OUR RESPONSIBILITIES ArnR WE
RECEIVE YOUR WRfITEN NOTICE, We must acknowledge
your letter within 30 days, unless we have corrected the error
by then. Within 90 days, we must either correct the error or
explain why we believe the bill was correct.
After we receive your letter, we cannot try to collect any
amount you question, or report that amount delinquent.
We can continue to bill you for the amount you question,
including finance charges, and we can apply an unpaid
amount against your credit limit. You do not have to pay any
que.stioned amount while we are investigating. but you are still
obligated to pay the parts of your bill that are not in question.
If we find that we made a mistake on your bilL you will not
have to pay any finance charges related to anv questioned
amount. If we didn't make a mistake, you ma~' have to pay
finance charges, and y?U will have to make up any missed
payments on the questIOned amount. In either case, we will
send you a statement of the amount you owe and the date that
it is due.
If you fail to pay the amount that we think you owe, we may
report you as delinquent. However, if our explanation does not
satisfy vou, and you write to us within 25 days telling us that
you sliB refuse to pay, we must tell anyone \ve report you to
that you have a question about your bill. And. we must tell
you the name of anyone we report you to. We must tell anyone
we report you to that the matter has been settled between us
when it is finally settled.
If we don't follow these rules, we can't collect the first $50 of
the questioned amo,:!-nt, even if your bill was correct.
SPECIAL RULES FOR ClIARGE ACCOUNT PURCHASES
If you have a problem with the quality of property or services
that yo~ p~rchased -yith your Farm Plan Account, and you
have trIed In good faith to correct the problem with the
merchant, you may have the right not to pay the remaining
amount due on the propertv or services. Th'ere are two
limitations on this right: .
. you mu~t ~ave made the purchase in your home state or.
If not wlthm your home state, within 100 miles of your
current mailing address; and
. The purchase price must have been more than S50,
These limilat~ons do ~ot apply if we own or operate the
merchant, or If we maIled you the advertisement for the
property or services.
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Credit Disclosure for Consumer Account
State of Your Residence
ANNUAL PERCENTAGE RATE(S)
""",>I
Percentage
Kale{s) for
P=h....
AK, .\2, CO, DE, DC, [0,
n.,IN,lA,>lD,MI,MS,
MO. Mr, NV. NH, NT. NM,
OH, OK. OR, RI, SC, SO,
TN, UT. VA. W.\. WY
Advantage Rate:
CA Advantage Rate:
AI., cr, FL. GA, HI, KS,
KY, L\. ME, MA, MN,
~. NY,NC,ND, PA. VT,
WV, WI Advantage Rate:
TX Advantage Rate:
AR SlandardRate:
All states
not listed
below.
Variable
Rale
Information
AR
Preferred
Purchases
Merchant
Authorized
P=b""
17.4%
17.4%
19.01%
19.2%
IH%
14%
10%
18%
14%
10%
Your annual percentage rate may vary.
The rate is determined by adding 8.9
(for Preferred Accounts 1 and 10.9
(ror~erchantAuthoritedAccou.nts)
percenlage points to the annual
percentage rate of interest announced
publicly'from time to time by Citibank.
N.A. in New York.:-iew York as the
base rale it uses for interest rate
determinations, which was in effect at
the close of business on the lSth dav
ofeachmonth,subjectinTXtoaceiJing
of the quarterly interest rate ceiling
announced by the Texas Consumer
Credit Commi~ionl1r [two tim;:s tho:
3-month average auction rale for
26-wee~Tt1!asuryBills.subjecttoa
floor of 14% and a ceiling ofZZ"bI.
Your annual percentage rate may vary.
The rate is determmed by the Federal
Resel"'/ediscountratefor90-day
commercial p'aper for the Federal
Reserve Oislrict induwng your state,
plus 5percentagtl points subject in
.\R 10 a ceiUng of tiClb.
Grace Period for 25 days, on average, from the billing date to repay the
RepaymeDt of Balances newbalanca of purchases before a finance charge will
for Purchases be imposed.
~ethod of Computing Average daily balance [excluding new purchasesl if you
the Balanceior reside in ME, ~H. Mr. or moL Otherwise. average daily
I'wclwe balance {including new purchases1.
MinimWD SO.50unlessvouresideinAL,AR,C.\,DC,FL,;'.fE.
Finance Charge ~D, MI.MN:~,NM. :-'U.OH.RL TX, VT or WY.
ut. Late Payment fees vary from state-lo-state. from zero
PaymentFtl! toS10.00.
The aho\"e infonnation was accurale as of the date of its printing. o2folf98. bul is
subject to change after that date. To find what may have cbanged. wrile to us at
Farm Plan CJrporation, PO Box 5326, Nladison. m 53iD5-0326.
II Farm Plan'
A Service of FPC Financial
The Charge Account For Rural America'
OCCB3B7 ulho in U.S.A. (9B-02)
Farm Plan@
For Consumer/Personal Use
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-01420 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FARM PLAN CORP
VS
FARWELL SHAY P
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
FARWELL SHAY P
the
DEFENDANT
, at 0013:20 HOURS, on the 17th day of March
, 2000
at 1725 WALNUT BOTTOM ROAD
NEWVILLE, PA 17241
by handing to
SHAY P. FARWELL
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
6.82
.00
10.00
.00
34.82
~~-..t: 4t:A
R. 'Thomas Kline 1 <
03/21/2000
PARK LAW ASSOCIATES
Sworn and Subscribed to before
By:
dW~~
c1'9'dA
Deputy Sherifr
me this 7 ~
day of
a,~'f A.D.
C)tt. .a ~ ~-
Prothonotary'
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AS OF II - O~ - J.tJD~
CASE# ;lOD 0 - )4 .)..0
HAS BEEN SCANNED.
ALL EARLIER
FILINGS TO THIS
CASE HAVE BEEN
MICROFILMED.
.
VALERIE ROSENBLUTH ANGST, ESQ.
ATTORNEY 10#72094
ANGST & ANGST, P.C.
37 SOUTH CLINTON STREET
P. O. BOX 1779
DOYLESTOWN, PA 18901
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY COURT OF COMMON PLEAS
FARM PLAN CORPORATION
Plaintiff
VS
SHAY P. FARWELL
Defendant
NO. 2000-1420
PRAECIPE TO MARK THE JUDGMENT SATISFIED
TO THE PROTHONOTARY:
Kindly mark the above captioned matter satisfied upon payment
of your costs.
ANGST & ANGST, P.C.
BY: V ~
VALERIE ROSENBLUTH ANGST,
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