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HomeMy WebLinkAbout00-02556 ,.- '. n.. ___,',_"'^ ,~__ ",_^, -" /. ~-",~-,,,,,",,' -",--^-,'"--~,, d' > ._, '-' ,~ . , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK SUCCESSOR IN CASE NO: 00 - ,;!SS'- INTEREST TO UNION NATIONAL BANK Cl('>~(~ Plaintiff, v. COMPLAINT IN CIVIL ACTION JEANNE S. PARSONS Defendant. FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: LORI A. GIBSON, Esquire PA J.D. #68013 WELTMAN, WEINBERG & REIS CO., L.P.A. 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #01847238 , ~_ r ~. " - .', ",,,,,,,.-,f.,,,' .'--', -o',,~~,__h~, -'--'~''''.-'"''~';'' ";;;'~-""',A.-';'",. ,-~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK SUCCESSOR IN CASE NO: M- .:lsGt., ~ ...,~ INTEREST TO UNION NATIONAL BANK Plaintiff, v. JEANNE S. PARSONS Defendant. COMPLAINT IN CIVIL ACTION 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 " . .. . r'-> ;'C . ,-~, -,-. --', -,--,1,":";'_ ,-- l~',''-'---;i .i~" .j , .~:[ COMPLAINT 1. Plaintiff is a corporation with offices at 6750 Miller Road, Brecksville, OH 44141. 2. Defendant is an adult individual residing at 237 North 26th Street, Camp Hill, CUMBERLAND County, Pennsylvania 17011-3621. 3. On or about February 4, 1987, pursuant to the terms of a Signature Credit Agreement, Plaintiff loaned Defendant the sum of $12,000.00, a true and correct copy of Signature Credit Agreement and, the terms and conditions of which were agreed upon by the parties, is attached hereto, marked as Exhibit "1", and made a part hereof. 4. Defendant made use of such credit granted by Plaintiff and has currently a principal balance due and owing to Plaintiff, as of December 10, 1999, in the amount of $9,275.27. 5. Defendant defaulted under the terms of the parties' agreement by failing to make the required payments to Plaintiff since December 10, 1999. 6. By the terms of the parties' agreement, more specifically the" acceleration clause" therein, Defendant's default made the entire balance of the loan immediately due and payable to Plaintiff. .-, " _ __',:_,',_i___., , ,,-,. ,--;,1 co"~ __, '-. -,~ .""";,;,~",,;;,, ,;;,-.,_,,_ <"'-, ,; , ,,,:.- 7. Plaintiff avers that the written agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at a variable rate. 8. Plaintiff avers that it is entitled to finance charges at the rate of 9.62 percent per annum on the unpaid balance. 9. Plaintiff avers that finance charges calculated at the aforesaid rate from December 10,1999 to March 6,2000 amount to $206.19. 10. Plaintiff avers that the agreement between the parties provides that Defendant will pay Plaintiff's reasonable attorneys' fees incurred in enforcing said agreement. 11. Plaintiff avers that such attorneys' fees amount to $150.00 to date and that those fees continue to accrue. 12. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/ or refused to pay the principal balance, finance charges, late fees, attorneys' fees or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant, Jeanne S. Parsons, individually, in the amount of $9,631.46 with appropriate additional attorneys' fees and continuing interest thereon at the rate of 9.62 percent per annum plus costs. -1-<- , ",,,~--',-" --'" ',;"'-- -',-,,,1... ,,,"'~,,_c,.;>;'''~-; ~"- C"-__'_'';;~; i,,-, c ~: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEI BERG & REIS CO., L.P.A. -_.--- --" LORI A. GIBSON, Esqu' PA LD. #68013 Attomey for Plaintiff 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR # 01847238 -~,-- ""- f I- . National ~.Bank ' s Agreem'ent the words you and your mean each who sign as a "Borrower" below. We, our and us me_an The Union National Bank of rittsburgh. ,SIGNATURE CREDIT AGREEMENT 2-4-1Y/ s your" Signature Credit Agreement. I ADVANCES, Once we have notified you In writing that your :~tlon has been approved,you can request loans from your Signature t Account irom time to time by using only the special checks we will je. You can fill out the special check for any amount more than $25 rocess it like any other check. If we honor the check, you agree that "noun! of the check will be a loan from us to you under. your line of Credit Limit $ 1~,nnn nn G YOUR ACCOUNT. There are three important restrictions on your \Yer privilege. First, the total "unpaid principal balance" (dollars Ned but not yet repaid, exclusive of Finance Charges and insurance es) of your Account cannot exceed your Credit Limit. Second,)'9u It request a loan of less than $25. Finally, the special check must be feted prope.rly" unaltered and presented for payment within three 1S of its date. As long as this Agreement has not been terminated. we :)Oor all checks you draw not violating these restrictions and treat as a loan to you. IT LIMIT. Your Credit limit appears at the topofthls Agreement. You not to let your "unpilid principal balance" exceed Ihis amount s we tell you In writing that we have increased your Credit Limil.lfyou tuest a loan which would cause your Credit Limit to be exceeded. we duse to honor your check and return U. in IISE TO PAY. You promise to pay us or anyone we designate all nls you borrow under this Agreement, plus the applicable Anance :es, Insurance charges, and any-collection costs or other amounts Ne us under this Agreement '-lCE CHARGE. Finance Charge on your Signature CredilAccount will e for any day credit 1$ outslandlng. There Is no free.ride period. The ce Charge is computed In the following way: Ve slart with the Previous Balance, excluding any Anance Charge ' 'nd insurance premium charges unpaid at the beginning of the new. lilling. cycle. . : 'or each day in the billing cycle we obtain a daily balance by adding ny new loans and subtracting any payments (and other credits) rom the prior day's balance. We add the dally balances for each day 1 the billing cycle and divide by the number of days in that cycle to Iroduce the "Balance for Anance Charge.~ ole multiply the "Balance for Finance Charge" by the initial "rate of 1?77":197 % per day and by the number of days In the billing cycle J find your finance charge for that cycle: These periodic rates orresp~nd to an A~nual Percentage Rate of approxlm~tely I.O.1.2S.. %. These rates will change from time to time based on an ldex, as described on the reverse side of this Agreeme!lt. The ,nnual Percentage Rate will be 4 50 percentage points above 1e index, but In no event will It exceed the maximum rate permitted y state or federal statutes, rules or regulations. ,. . . ;MENTS. We will mail a staternenteach month to the billing address rovide. It- will show all loans, payments and other credits to your nt during that billing cycle.l\will also showthe minimum payment ust make and the date your payment Isdue.Uyou have authorized make. deductions .from your checking account..-lhe minimum" " !nt will be charged fa your account on that due date. You'have 60 "rom the date we mall the slatement to notify us In writing If you e It contains any inaccuracies. If you don't, it will be considered ted and correct' . ENTS. You can pay the entire balance of your account, or any part of ny time, without penalty. Since your Finance Charge is calculated :h the date payment Is received, you should contact us for an exact figure fo~ the, date you expect to pay. Account Number ?~_'::U1_{119';LR If you don't pay your entire balance, you promise '0 make a payment at I~ast equal to the Minimum Payment shown on your, statement on or before the due date shown. .The amount of each mlhimum paymerit depends on the "unpaid principal balance" after we honored the last c!1e~k processed in your account, accordlng'to the followlpg table: Unpaid Principal Balance Minimum Principal Payment $ 0.00 through $ 503.99 $21.00 or New Balance, whichever is less $ 504.00 through $ 3,500.00 1/24 of Unpaid Principal Balance $ 3,500.01 through $ 5,000.00 1/36 of Unpaid Principal Balance $ 5,OOO.Ollhrough $ 7,500.00 1/48 of Unpaid PrIncipal Balance $ 7,500.01 through $10,000.00 1/60 of Unpaid Principal Balance $10,000.01 through $25,000.00 1/72 of Unpaid Principal Balance $25.000.01 through $40,000.00 1/84 of Unpaid Principal Balance $40~OOO.01 and above 1/120 of Unpaid Principal Balance The Minimum Paymentthen"isdetermined by addlrigthe Finance Charge and any credit .life Insurance premiums for the billing cycle to the minimum principal'payment. . Payments firsi' will be applied to any Finance Charge due. then 10 any unpaid cred" lite Insurance charges, Ihen 10 the "unpaid principal balance." If you pay Iliore than Uie mhllmum payment, you'll still have to pay at least the minimum paYfRentln each later billing cycle. AD~IT.ONAl CHARGES. If you fequest a copy of a special check, monthly blllmlJstatemenl, orotherdocument In connection with your IineOfcredlt, you will pay the charge In effect at that lime. Currently. the Charge lor this . service is $5.00. In addition. you will pay the following Charges; NI.A Ul> ,.. ,N/A ~fi Notary ..,....................................... $ Appraisal................:.......:..............-. $ Title Examination ................................ $ Title Insurance ...... ........................ ,... $ Charge for recording mortgage .................... $ Charge for satisfying mortgage (estimate based on current rates) ............... $ other $ Other $ N/A N/A N/A SECURITY. We have the "right of setoff" 10 protect us If you don't repay your Signature Credit Account. This means we have the right to apply any " money you may have in any deposit account with us against the tolal "amount you owe. In addlllon, we will have a security interest In: Deposits, accounts. and other money or property belonging to you which are In 'our possession or control. Real pfoperty located at . . . Collateral securing other loans with us may also secure your line of credit. PROPERTY IN$URANCE.lfflood insurance or other insurance on the real property securing your _line of credit Is required, you may obtain such insurance from any person or company of your choice that is acceptable to us." _ liT LIFE INSURANCE. If one of you is under 65, or both of you are under 65. we can pl'Ol!ide that person(s) with group credit life Insurance protection to r Ihe amounts elected below. The Insurance ends automatically when oneor the designated person(s) reaches 65, and 15 also subject to cancellation by 1surer. The Insurance Is defined in the Insurance Certificate, not in this ContraCt. See the NOTICE OF PROPOSED CREDIT INSURANCE on the reverse o not require that you .purchase this insurance and it will not be provided unless you Sign below and agree to pay the premium. If you decide you want it .ign immediately below, a monthly premium will be added 10 the amount you owe us and to your monthly minimum payment. The present charge for e life coverage is $.000023 per dollar per day and the present charge for Joint life coverage is $.000041 per dollar per day. We multiply the applicable ~nt charge by the insured average daily balance and by the number of days in the billing cycle to find your monthly premium for that cycle. This charge bject to change by the insurer. The name of the Insurer is; JRITY OF AMERICA LIFE INSURANCE COMPANY, Reading. Pa. elecl: no insurance coverage. Signature of Borrower credit life insurance coverage equal to the amount of your Principal Outstanding Balance not to exceed $25,000.00. 10 apply for credit life insurance coverage equal to the amount of your Principal Outstanding Balance not to exceed $60,000.00. You understand If the Credit life Insurance application Is denied by the insurer, you will still receive life Insurance coverage equal toyour Principal Outstanding Balance not to exceed $25,000.00. . THEREVERSESIDEDFTHtSAGREEMENT CONTAlNSADDtTtDNAL TERMS AND OISCLOSURES WHtCH APPLYTOYDURSIGNATURECREDtT ACCDUNT. \ \/] , r Either borrower who signs below will be legally responsible for the payment ,...L- of the lotal amount owed. ~- gning, you want Single Credit Ufe Insurance. Ilure of Borrower to be insured for Smgle Credit life Insurance. " is your age? years !? EXHIBit lk~~ By signing. you bolh want Joint Credit life Insurance. What are your ages? }, _years . . . 2 " years Signature of both Borrowers to_be Insured lor Jomt Crecht Life Insurance. (SFAl) ~~I . " .-- a ,I. , .!\,' .... . .. ,. 'cHANGES. We can change the terms of this Agreement atanytime for any reason we choose. This inc: Jde~ a rigji, to change the daily perlodicrate,.and. 0 course, the corresponding Annual Percentage Rate. Changes can apply to both new loans and to the outstanding unpaid balance on your account We will givE you at least as much notice of a change as is required by law. TERMINATION. Wec'!!' ca~cel this Agreement at any time by notifying you (or either of you, If this is a joint account) and confirming that noticg i'1-.W1'iting sen' to the billing address you have provided within three business days. You (or either of you, if this is a joint account) have the same right. If you cancel, we" continue to honor checks meeting our rules for 14 days after receipt of your notice. If we cancel, we can stop honoring your checks immediately but may hono' checks for up to 14 days if we wish. Your obligation to repay amounts you owe underthisAgreement will not be Changed by either our termination or yours THE INDEX AND RATE CHANGES. The periOdic rates and corresponding annual percentage rate which apply to your line of credit will Change from time te time, based on.an index. The value of the index will be recalculated on the first business day of January, April, July, and October. The value ofthe Index will equal the auction average interest rate for thirteen week United States Treasury Bills which is most recently available althe time the index is being recalculated, rounded to the nearest .125%. AdjustmentS in the annual percentage rate will take effect on the first day of the next billing cycle beginning after the day the index is recalculated. An) increase in the annual percentage rate will take the form 01 higher payment amounts. Ifthe index ceases to be made available, we will determine the annua percentage rate by using a comparable national index. ENTIRE BALANCE DUE. II you don't pay any payment when it is due, or don't do everything else you've promised in this Agreement, or if you should die or it any kind of bankruptcy, receivership or Insolvency proceedings are begun by or against you, or if you've made or make any misrepresentation to us, or if you de anything indicating you may be unwilling or unable to pay your loan, you'll be in default If you default, we can require you to pay all you then Owe immediately, rather than continuing to pay in installments. Once we have, we will make no more loans to you. We can also postpone taking any such .action without losing any 01 our rights. COllECTION COSfS.lfwe are forced to start collection proceedings to recover amounts you owe, you agree to pay all 01 our costs and expenses in doing so including the reasonable fees our attorneys charge us. OTHER PROMISES. You also promise us you will: 1. _ Furnish us with re"ised finandal information whenever we request within 30 days of when we ask; 2. Not issue any postdated Signature Credit check; 3. Not assign'your rights or Obligations under this Agreement; 4. Use only the special checks we provide under this Agreement and then in amounts which will not cause your Credit Limit to be exceeded; 5. Notify us immediately of any change of address or employment, 6. Not use the cr<idlt available under this Agreement to violate any law or regulation; 7. Not use any Signature Credit checks to pay amounts due under this Agreement; B. Not request certification 01 any Signature Credit check. NOTICE OF PROPOSED CREDIT INSURANCE The Signer(s) of this Agreement hereby take(s) notice that group credit life insurance coverage(s) will be applicable to this Agreement if so marked on the frontolthis Agreement. and such coverage will be written by the insurance company named. This insurance, subjeclto acceptance by the insurer. covers only the person(s) Signing the request lor such Insurance. The amount 01 charge is indicated for the credit insurance(s) to be purchased. The term of the insurance(s) will commence on the date you approve this Agreement. Subject to acceptance by the insurer and within 30 days, there will be delivered to the insured borrower(s) a certificate of insurance more fully describing the insurance. YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE USE This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. NOTIFY US IN CASE OF ERRORS OR INQUIRIES ABOUT YOUR SIGNATURE CREDIT STATEMENT If you think your bill is wrong:or if you need more information about a transaction on your bill, write, us on a separate sheet atrhe Union National Bank 01 Pittsburgh, Time Deposit/Loan Accounting Section, Pittsburgh, Pennsylvania 15278.1900. Write to us as soon as possible. We must hear from YDU no late, than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve yourrigltts. In your letter, give us the following information: . Your name and account number. . The dollar amount of the suspected error. " ' , . Describe the error and explain, if you can, why you believe there is an error. If you need more information. describe the nem you are not sure about. If you have authorized us to pay your bill automatically from your savings or Checking account, you can stop the payment on any amount you think is wrong, To stop the payment your letter must reach us three business days before the automatic payment is scheduled to occur. : YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRmENNOTICE We must aCknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correclthe error orexplain Whl we believe the bill was correct. ' , After we receive your letter, we cannot try to collect any amount you Question, or report you as delinquent. We can continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit limit You do not have to pay any questioned amount while we are investigating, but you are still obligated to pal' 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 any questioned amount. If we ~idn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments'on the questioned amount. In either case, we w,lI send you a statement of the amount you owe and the date that it is due. ., " If you lail to pay the amount that we think you owe, we may report you as delinquent. However, If our exp!anation does no~satisfyyou aodyou write to us within ten days telling us thaI you slill refuse 10 pay, we must leli anyone we report you to thaI you have a question about your bill. And, we must tell you the name 01 anyone we reported you 10, We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the firsi $50 of the Questioned amount, even if your bill was correct. 8ANCONSUMER FORM PAS70.a9 (Rev. 11/86} CC 963AZ. (Rev. 11/86) ,. Ll-o ;, .ell" , \ t '. 01 ~41)3l VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. i 4904 relating to unsworn falsificatio.n to authorities, thathe/sh~~.r:t?.ci/,Y\u1)irJc ~(' ,r' .. . .~ .. '\ I ~I C~Name) U(\5U-lIYWI c../l,I:6J1;j cm=-iccr of f'-/.t5.;t",/onaf .. i (Title) (Company) , Plaintiff herein, that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and beliet. ~-~l,rItLi7~ (Signature) '"' ~..; -~-~ - '~.uj~ _""IU,""""':t',"""_"t-I,~~"",m-.l._'_iEc.4~ ~i-IlW!!I<lIl'" ld~,"""""k,C_,,\-"H,,' lii!li~liiLIilJUIllil!.li ~. -"""....", .>. . ~~ . . . , , fJ P t 'I<:l (") C::; CI 8 \:t. ~ ~ ~ t..:) '. r~ ~ "" -.-l -rJn'" '-, (y fi1:T- _~:,J ~ ~ ;s;~.] 1'-.) n,' I ..0 ~ (0 ~-. c.! -<.. .,- ..r::- I c:.:c ~: ~ I ;z;c-, --.) -,'" 6' ~ U ~ ~~ c:' a ~. "I p.':: 'Cl - .,. " '1- =<! (:J -< S- ,-,. --~-~" -, ~- .. --". ~ ~- -. - ~,,~,' ' I -. __,,~,^ -.',_,_0<, '"",">>'.._-C"c' ie,,? , ,,,-. ~'- .~"'--"~~ . -- ",,"- ~- ,', , - ~,.-~ ~ -'~ "," , SHERIFF'S RETURN - REGULAR CASE NO: 2000-02556 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY BANK VS PARSONS JEANNE S RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PARSONS JEANNE S the DEFENDANT at 0019:34 HOURS, on the 28th day of April , 2000 at 237 NORTH 26TH STREET CAMP HILL, PA 17011-3621 by handing to JEANNE PARSONS a true and attested copy of COMPLAINT & NOTICE together with CIVIL ACTION and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.30 .00 10.00 .00 37.30 r~~~~~e R. Thomas Kline 05/01/2000 WELTMAN, WEINBE Sworn and Subscribed to before By: me this 'i'~ day of ~.)g1JV A.D. 'C}~u ()_ rl/u~":., /tpJ thonotary / , . .' , '" ,i..~,~, (' 1> , . ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK SUCCESSOR IN INTEREST TO UNION NATIONAL BANK Plaintiff No. 00-2556 CIVIL vs, PRAECIPE FOR DEF AUL T JUDGMENT JEANNE S. PARSONS Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lori A. Gibson, Esquire PA I.D, #68013 WELTMAN, WEINBERG & REIS CO., LP.A. 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01847238 " ,', THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. {' , "1<);, " , ~ '" . " , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK SUCCESSOR IN INTEREST TO UNION NATIONAL BANK Plaintiff vs, Civil Action No. 00-2556 CIVIL JEANNE S. PARSONS Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Jeanne S, Parsons, above named, in the default of an Answer, in the amount of $9,863.10 computed as follows: Amount claimed in Complaint $9,631.46 " Interest from 3/6/00 to 6/6/00 at the contract interest rate of 9.62% per annum $231.64 $9,863,10 TOTAL I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA RC.P, 237.1 on the dates indicated on the Notices. ~: By: Lori ,Gi , Esquire PA I.D. #68013 WELTMAN, WEINBERG & REIS CO" LPA 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01847238 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co" LPA, 2601 Koppers Building, 436 71h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant Is: 237 North 26th Street, Camp Hill, PA 17011 ~ . - I -I' "" I" " r ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .. CIVIL DIVISION NATIONAL CITY BANK SUCCESSOR IN INTEREST TO UNION NATIONAL BANK Plaintiff vs. Civil Action No. 00-2556 CIVIL ..... JEANNE S. PARSONS ,..- Defendant .--IMPORTANTNOTICE- TO: Jeanne S.-Parsons- ,,----------- 237 North 26th Street Camp Hill, PA 17011 Date of Notice: Mav 19. 2000 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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 O~ OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF 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: -- ______n___n___ Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 By: LOR~ . IBSON PA I.D.#68013 Weltman, Weinberg & Reis Co., L.PA 2718 Koppers Building 436 7'h Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #01847238 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED F.CJRTHAT PURPOSE. , . - ~, .. , , " , VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C,S, Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according ti to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. '~ " , By: Lori A. son, Es ir PA I.D, #68013 WELTMAN, WEINBERG & REIS CO., LPA 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01847238 " , ~!WfIiltil!illl~WJ.lB~..-~li~~~ll!lIiiIilf.l!ii!ll!mli;i,Wlt"",&&:,;",;""."~OiN""'~"'"'""-~WJJ\t~~~,"J!:"'~~--""'. ",,, ,<,.,,--,.> ~ c< ___.1 __ " c ,<,~_, <_,' _ 1 C8~~iD :~ !~ -J \-- ~ ~ ~ ~ ~ ~ t, ~ ~ ~ , < ~-'" , ~.. , .. 0 c') , c: t::':~ '..-' $' ~ -! -c Cj := ~~.i,',-; ~ ; -,"7("- :-n cj)_~-: ~..() ~ J " -< ,"",:- , T r~~ ~ CJ -<-.-,-", " ~CJ ~ ~~ =~,i "=C> (~i PC: ~~) " iT; \_~ Z ..., .:;.:! =< S .-.J -< - .~,' " E ", " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK SUCCESSOR IN INTEREST TO UNION NATIONAL BANK Plaintiff vs. No. 00-2556 CIVIL PRAECIPE FOR SATISFACTION OF JUDGMENT JEANNE S. PARSONS Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES VALECKO, Esquire PA I.D.#79596 WELTMAN, WEINBERG & REIS, CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA15219 (412) 434-7955 WWR#01847238 - " i;j ,. , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK SUCCESSOR IN INTEREST TO UNION NATIONAL BANK Plaintiff vs. Civil Action No. 00-2556 CIVIL JEANNE S. PARSONS Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.PA BY:~ JAMES AL CKO, Esquire PA I.D.#79596 WELTMAN, WEINBERG & REIS, CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA15219 (412) 434-7955 . Nota1fal Seal . .... Beth A.~, ~8/)' Public .~~ ~reaJ~2004 Mi!moer'~~OINollr1e1 WWR#01847238 Sworn to and subscribed before me this ~ day of September, 00 Gb:+ Ie )Wo lfJi'1w NOTARY P L1C ii/w_~IMIIlI!WiIlllWllllillllo1li!_.~JiI<'>'i"i!&i!i~~_,.lli/tr~~j,",=;;",-~~'lit;I'i"l.w""~~"',"-~~ili:&l1!!IlIrlllI''"'-"'''''-' . -"",,_...-"'-"'" :" I;"~ ;,\\-,\' """,,, ,,' .."."ill' ... ""'1, t;~'~:V:': :.:,c!.Jlo''! ~. j,lt/;( ;:\~,?A;.;i'i:' ";"1'- ~""-' ~ -, ,r ... 0 c::> 0 C a ;,>- -"1 '1J~' CI) mW: Pi Z::tJ -u ~n " Zr-~ 1'0 ..;i,b.7 C/) ?;:~ _i ; '-' ;:$- ~~ :s::C " Zr-. :J:.: )>0 \::1 c Om Z .,~--! =< ~ J> fv :n- -< ;-.",,1- ,";' , ,:d:"~"