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HomeMy WebLinkAbout03-0900IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. KATHIE R. GRUCZ, Defendant NO. 03 - qa cD CIVIL ACTION -LAW 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 is 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 document, 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. NOTICIA Le han demandado a used en la cone. Si used quiere defenderse de estas demandas expuestas en las paginas siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notification. Used debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y puede entrar una orden contra used sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Used puede perder dinero o sus propiedades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS CCUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. KATHIE R. GRUCZ, Defendant : CIVIL ACTION -LAW 4. vehicle. 5. COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Steven C. Courtney, Esquire, and Godfrey & Courtney, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at One Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Kathie R. Grucz, is an adult individual with a last known address of 2605 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. Defendant is, and at all relevant times material hereto was, the primary loan applicant. Defendant applied to Plaintiff for a loan for the purpose of purchasing a motor The loan application submitted by Defendant was approved by Plaintiff and Defendant signed a Loanliner Advance Proceeds Check for the purchase of the vehicle. A true and correct copy of said Loanliner Advance Proceeds Check is attached hereto, incorporated herein and marked as Exhibit "A". 6. Pursuant to the Loanliner Advance Proceeds Check marked as Exhibit "A", Defendant agreed to the terms and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (hereinafter referred to as "Contract"). A tree and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 7. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms and conditions of the Contract marked as Exhibit "B". 8. On or about July 25,2001, Plaintiff provided a letter to Defendant stating that the vehicle purchased by Defendant, a 2001 Lexus IS300, serial number JTHBD 182X10015372, is being considered as a repossession and unless payment in full was made on the outstanding loan balance, the said vehicle would be sold at a public sale on account of the Defendant and Defendant would be still responsible for any resulting deficiency. A tree and correct copy of this letter is attached hereto, incorporated herein and marked as Exhibit "C". 9. As a result of Defendant's failure to cure the default in payment, Plaintiff sold for and on account of Defendant said 2001 Lexus IS300. 10. On or about March 27, 2002, Plaintiff provided a letter to Defendant indicating that there was a resulting deficiency after the sale of the 2001 Lexus IS300. 11. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 12. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 13. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. 14. As of January 15, 2002, the balance due, owing and unpaid on Defendant's loan account with Plaintiff is the sum of $14,147.64 Dollars. 15. Pursuant to the terms and conditions of the extension of credit contained in the Contract, Plaintiffis entitled to receive and Defendant agreed to pay an annual interest charge at a rate of 8.490% on the principal loan balance. 16. Pursuant to the terms and conditions of the extension of credit as set forth in Exhibit "B", Defendant agreed to pay reasonable attorney's fees and all court and collection costs. 17. Plaintiffhas retained the services of the law firm of Godfrey & Courtney, P.C. in the collection of the amounts due and owing by Defendant. 18. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Godfrey & Courtney, P.C. in the collection of the amounts due from Defendant incident to the within action, and Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 19. The amount of attomey's fees incurred in this matter is the sum of Two Thousand Eight Hundred Fifty Four and 53/100 Dollars ($2,854.53). 20. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 21. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Kathie R. Gmcz, in the amount of Fourteen Thousand One Hundred Forty Seven and 64/100 Dollars ($14,147.64), plus interest at an annual rate of 8.490%, reasonable attorney's fees in the amount of Two Thousand Eight Hundred Fifty Four and 53/100 Dollars ($2,854.53), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, /~' By: N // / X Steven C. ~<m:!~ey~quire x~ P.O. Bo~~ Harrisb~'~7, PA 17112 (717) 540-3900 I.D. # 74669 Attorney for Plaintiff VER1TICATION I, Bormie L. Berkoski. hereby certify that the following is correct: The facts set forth in the foregoing Co/nplaint ~e based upon information which ! have fLu-nished to counsel. ~ ,.,.'ell as upon information wNch h~ been gar. gered by counsel and/or others acting on my behalfin th_is mauer. Thc language of the Co/npl~dnt is that of cotmsel ~d not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true a_nd correct to the best of/ny knowledge, information, ~d belief. To the extent that t~e content of the Complaint is that of cou_~el, I have relied upon such counsel in making this Verification. I b. ereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penn/ties of 18 Pa. C.S.A. {4904 relating to urtsw'om £a.lsification to authorities. Bonnie L. Berkoski Date: ' -/ t . - PenAsyl~;an[a ~tate Employees Credit Union ~ '{r,o~o=n · "- · J AUTOORA~ VOID OVER s 35.5~.00 · REFERENCE 0-875~5274 VOiD ~20 DAYS A~ER. PAYTOTHE ' .- '~.· . "" '*.~= .' : :' ' '.'~ '' '*, '' ~ ..? *:<* ¥ .' ~ :,F ~C ,~. - ...... ~E C,?..C' '.~; ~<~:../?..;,~ k~;~f~ _: Z~,_ ,,.~,.'...,~' :..'.' ~:~...: '~ '.,'."~:~..:.~'" / I ~sted on ~l rivelse s de, No por~n of ~e ~oceeds ol l~s I ' . ~TH[E JLGRC~ ' ' ~.. . ~ . ) .._. -., .-. ,:~- . .. .'o~-,~n~z.~ '~;.:-c-' ":~:;. ;:'::' ~::..:'. ~ the PIe~ Credit Unl<~n, we, our ar, d us n-~zn PSEC~ ~terest ~te ~¢ e~ su~unt ~re~ as a daily ~ri~,c ~te and ~~[n9 an~ ~r~nta~ rate a~ o~r ~arg~. It r~7 al~ ~ other terms ~ a ~ule ~r determini~ the ~en~ a~nW. ~, If ~ a~ ~ to use ~r A~b~ ~ to a~ss ~r ~ ~~ use o~ ~ur AT--bit ~rd. You u~~ u~ ~t ~m a~er ~u noisy us o~Ry num~¢ ~ a~ ~t ap~a~ e~ere 7. PRQPE~NSU~NC~T~ES AND FE~ f you ~-~ce4 yoJr t"¢surance and get a refund, we hs~e a r~ to ~e refund. If ~ I,x'°P?r~Y .o~s~/l~towa-rds",,',4~atyo~,e. Yo~Jau.bhodzeu~toex~u.~_ repair ~ r:~y ~y ~ o~igad~% ~ we are ~t r~uir~ Io do ~ ~ n~ ~ ~ )~ vdll [~ay interes~ ~ ¢~ a~nL~ at ~ ~ ~te ~ agr~ lo ~, ~ ~ 10. PERIODIC STA~ME~ ~ On a r~u~r ~sis ~u w~l r~ a ~te~nt S~[e~n~ and ~t~ ~lt ~ sent to ~u at ~e ~t r~ a~r~s )gu ~ve 15. ACTIONS AFTER DEFAULT ~ The following paragcaph zpp#~ to bo~c~wer~ In ~do, DIs~lct of ~lumbla, Iowa, ~n~s, ~Ine, ~sln and Louise--: ~n ~ are ~ ~u~. p~ ~11 ~ ~ f~ ~ ~ r~ 16. A~ONS ~R DEFAULT- ~NSIN- ~.413 ~ ~ ~ ~ 77~ fo#cw~fng para;rap6 zpp~ to ~ bon'owe~ other ~ ~T~E SECUR~ I~ C~RS ~ ~ ~er~ ~re~ ~ o~ ~n~ ~ ~. 26. HO~ DAK~A H~ ~ BORR~ PUR~NG A ~R ~D A~ AMOU~ DUEndE SE~R~ P~ ~E H~ RE~D ~ ~T S~YOU ~Y ~ PAYEE 27. VERMONT NOTICE TO CO-SIGNER ~'YOUR SIGNATURE ON ~IS NOTE M~NS ~AT YOU ARE EQUA~Y ~AB~ FOR REPAYME~ OF~IS LO~, IF~E BORROWER ~ES N~ PAY,.~E LENDER HAS A LEGAL RIG~TO ~LLE~ FROM YOU. ~<:rr'~u~r' Us L~ CASE OF ERRORS OR C~JESTIONs ABOUTYOUR STATEMENT_ "The do~r anxx.~ c4 the ~t,~:~:l erroc If you r, eed mo~e infocrr~A~ de::,cdbe the i~em You ~re not sum about If you have authodzed us to ~ a cre<:~ card · account acrtomalk::al~¥ from your share YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE - We rnu~ ec:kn<~ your letter wfthin 30 days, tna/es.s we have corrected b~e errc~ by ther~ W-rd~n SO days, we rnu~ either correc~ the erroc or exp~[n why we berm~,e Zt~e statement w3.s c,0~recL les ~ ~ ~ ~. ~,~ -..__. ~ ~m ~ ~ ~ ret~ ~ ~Y~r ~ ~ ~s ~n ~h ~ a~m. ~ ~ or ~r ~un ~ to ~ we are ~t a pa~ ~ Cr~ ~u or one of ~ o~er ~mons r~e ~ ~ ~ a~nL 2. LO~ C~D NO~CA~ON ~ If~ ~e ~ ~rd~ ~n ~ or ~en. ~ ~1 ~te~ ~( ~ ~ U~ ~ ~1~ ~ ~ (~) ~7-~8. ~er ~m ~ (~) ~8. 3. ~l~ FOR U~OR~O USE ~ y~ u~ ' ~ ~n ~ t~ ~en~ f~ ~~. ~~.By "~~~~ a~ ~ ~y · A~n~ and U~ of MON~A~ CARD Y~ ~ ~t a M~ ~ C~R ~ a PLUS SY~ A~ ~ vaF~tate l~e c~rec~kx'ts g~,'~n ~ as ~r a~ d~tum ~91 a~n~le ~ ~te ~ur ~r~ 9~n to ~. You a~~ ~t ~r PIN E ~ : ~re~ore, ~U AGREE TO T~E ~ R~~ P~~S ~T NO ONE ~E ~ ~R PiN. 7. ~nd~nt of ~is Agr~t ~EGU~ON ~ DIS~OSURE ~ ~ ~. a~ we ~ p~ we ~ ~ s~ ~e ~ ~ng ~r ~ ~ ~ ~a ~ ~in ~ ~ a~ ~ ~te~n~ ~ ~1~ to ~u, ~ ~ ~ Te~p~ Num~ ~ Add~s to No~ of U~~ Tm~fem Or~to~ RO. ~ ~13 ~, ~ 17~7013 ~o (~) ~.~ ~ ~~*~; ~ a~.f~ ~S~ ~ to ~~; -) ~ ~,e m:cou~ bataz~oe(s) oi' your Cl~ddng your Regu~r S~.res. c) ~ a~~ f~~~~. ~ ~ ~. Not ~ ~ ~ C~ ~ a~pt PLUS SYS~ ~C On~ - Y~ (~US SYS~M a) ~te~ ~ ~ ~s) ~ ~ ~. ~r ~ S~. b) ~w~ c) ~ a ~ g~ f~ ~r ~I ~ ~ (~L). ~C ~-Y~ ~ m ~r ~E~ ~ ~ ~r ~ A~ ~t~ ~ ~ ~ o~r a~ ~m ~.~ ~ H~R ~ M~A~ CARD. ~ ~r ~1 ~ L~n (~L). b) ~mw ~ ~ ~r ~ ~ ~ R~ar ~r~. c) ~ a ~ a~ ~ ~ur ~1 ~ ~ (PSL). N~: ~ ~ ~t ~ ~ HONOR SYS~ ~. · ~ ~e ~ MON~ ~E~ ~R ~ ~e~y ~e ~h ~ H~ SY~ ~ ~r ~ ~.~ o~ ~ ~ ~e. ~ A~ Ne~ A~s .. 14.~Tm~ ~~~Me~ ~e Y~ ~ ~ ~ C~ .PLUS SY~ID. For those members who purchase a vehl.cle un. der the DRIV Program, pleaSe review the following FTC Notice: NOTICE ANY HOLDER OFTHIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST.THE'SELLER OF GOODS .OR SERVICES OBTAINED WITH THE PROCEEDS HEREOF. 'RECOVERY HEREUNDER BYTHE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BYTHE DEBTOR HEREUNDER. o '~oo oo .q~8ooo8 0800088888008°0 ooo ~~o o~o.O~OOoo° Exhibit C the financial fink,. July 25, 2001 #0287565274 Kathie Grucz 2605 Market Street Camp Hill, PA 17011 NOTICE OF REPOSSESSION AND SALE Thc 200I Lexus IS300, VIN# JTHBDi 82X I00i 5372, which we are financing for you has been repossessed. The vehicle is being stored by: Central Penn Recovery, 5203 E Trindle Road, Mechanicsburg, PA 17105 (717) 697-6600. Auction: Harrisburg Auto Auction t 100 S York Street Date: July I6, 2001 Mechanicsburg, PA 17105 Time: 10:30am (717) 697-2222 The vehicle will remain in storage until August 9, 2001. You have the legal right to redeem this motor vehicle within fifteen (I 5) days after the mailing of this NOTICE OF REPOSSESSION AND SALE by payment of the AMOUNT NECESSARY TO REDEEM VEHICLE. Amount of Unpaid Balance (L 10) $34,551.47 Amount of interest 420.96 Pitts Expenses: Repossession Expense 275.00 Storage Expense ('~$20/day (7/25 - 8/9) 300.00 Cost of Suit Late Fee 28.04 Other Less Credit for Unearned Charges: Finance Charge Other AMOUNT NECESSARY TO R. EDEEM VEHICLE (Cash or Certified Check): $35,375.47 You are hereby notified that the holder, intends to offer the vehicle at public sale at the expiration of fifteen (15) days after the date of mailing this notice, and shall continue to be offered for saie thereaher until ~old. If the vehicle is sold and the proceeds of the sale are less than the AMOUNT NECESSARY TO REDEEM VEHICLE, we will notify you of the deficiency which you are obligated to pay by the contract and by the law. Any personal belongings left in the vehicle must be redeemed by you within 15 days from the date of this letter or they will be disposed of accordingly. {~/~ecel'ely' Account Advisor PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 · (717) 234-8484 · (800) 237-7328 Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 · (717) 777-2100 (TDD) - (800) 472-1967 (TDD) Web Address: www.psecu.corn Savings federally insured up to $100,000 by the National Credit Union Administration. SHERIFF'S RETURN - REGULAR CASE NO: 2003-00900 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS GRUCZ KATHIE R RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GRUCZ KATHIE R the DEFENDANT at 2605 MARKET STREET , at 1853:00 HOURS, on the 7th day of March CAMP HILL, PA 17011 by handing to , 2003 MICHAEL GRUCZ, ADULT SON 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 18 00 10 35 00 10 00 00 38 35 Sworn and Subscribed to before me this /~'~ day of So Answers: R. Thomas Kline 03/10/2003 GODFREY & COURTNEY By: ~~- ~,~//~ Deputy Sheriff PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION KATHIE R. GRUCZ, : NO. 03-900 CIVIL TERM Defendant : DEFENDANT' S ANSWER TO PLAINTIFF' S COMPLAINT AND NOW, THIS ~~ DAY OF March, 2003, comes Defendant Kathie R. Grucz, by and through her attorney, Michael D. Rentschler, who files the within Answer to Plaintiff's Complaint, by respectfully averring as follows: I. Admitted upon informati'on and belief. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Denied. The allegation in Paragraph 6 of Plaintiff's Complaint constitutes a conclusion of law to which no response is necessary. To the extent that there are factual averments, Defendant upon reasonable investigation, Defendant is unaware as to the truth or falsity of the allegation contained in Paragraph 6 of Plaintiff's Complaint so the same is denied and proof thereof is demanded. 7. Denied. Upon reasonable investigation, Defendant is unaware as to the truth or falsity of the allegations contained in Paragraph 7 of Plaintiff's Complaint, so the same is hereby denied and proof thereof is hereby demanded. 8. Denied. Upon reasonable investigation, Defendant is unaware as to the truth or falsity of the allegations contained in Paragraph 8 of Plaintiff's Complaint, so the same is denied and proof thereof is hereby demanded. 9. Denied. Upon reasonable investigation, Defendant is unaware as to the truth or falsity of the allegation contained in Paragraph 9 of Plaintiff's Complaint, so the same is hereby denied and truth thereof is hereby demanded. 10.Denied. Upon reasonable investigation, Defendant is unaware as to the truth or falsity of the allegations contained in Paragraph 10 of Plaintiff's Complaint, so the same is denied and proof thereof is hereby demanded. Il.Denied. Upon reasonable ~nvestigation, Defendant is unaware of the truth or falsity of the allegation contained in Paragraph 11 of Plaintiff's Complaint, so the same is hereby denied and proof thereof is hereby demanded. 12.Denied. Upon reasonable investigation, Defendant is unaware of the allegations contained in Paragraph 12 of Plaintiff's Complaint, so the same is hereby denied and proof thereof is hereby demanded. 13.Denied. After reasonable mnvestigation, Defendant is unaware of the truth or falsity of the allegations contained in Paragraph 13 or Plaintiff's Complaint, so the same is hereby denied and proof thereof is hereby demand4ed. 14.Denied. After reasonable ~nvestigation, Defendant is unaware of the truth or falsity of the allegations contained in Paragraph 14 of Plaintiff's Complaint, so the same is hereby denied and proof thereof is hereby demanded. 15.The allegation in Paragraph 15 of Plaintiff's Complaint constitutes a conclusion of law to which no response is necessary. To the extent that said averment that said averment is deemed to be factual in whole, or in part, upon reasonable investigation, the Defendant is without knowledge as to the truth or falsity of the allegation, so the same is hereby denied and proof thereof is hereby demanded. 16.The allegation contained in Paragraph 16 of Plaintiff's Complaint constitutes a conclusion of law to which no response is necessary. To the extent that the allegation is deemed, in whole or part to be factual averments, the same is denied and proof thereof is hereby demanded. 17.Admitted upon information and belief. 18.Denied. Upon reasonable investigation, Defendant is unaware of the truth or falsity of the allegation contained in Paragraph 18 of Plaintiff's Complaint, so the same is hereby denied and proof thereof is demanded. 19.Denied. After reasonable investigation, Defendant is without knowledge as to the truth or falsity of the allegation contained in Paragraph 19 of Plaintiff's Complaint, so the same is hereby denied and proof thereof is demanded. 20.Denied. Upon reasonable investigation, Defendant is without knowledge as to the truth of falsity of the allegation contained in Paragraph 20, so the same is hereby denied and proof thereof is demanded. 21.Admitted in part. Denfed in part. It is admitted that the amount that Plaintiff's allege to be due to them by the Defendant is an amount that falls within the jurisdictional limit for compulsory arbitration. It is denied that the amount as alleged by Plaintiff is due and owing by Defendant. WHEREFORE, it is respectfully requested that this Honorable 'Court find in favor of Defendant and against Plaintiff. Respectfully submitted, Law Office of Michael D. Rentschler, P.C. Dated: MICHAEL D. RENTSCHLER, ESQUIRE Attorney for Defendant 1300 Market Street, Suite 200 Lemoyne, PA 17043 (717) 975-9129 Supreme Court ID No. 45836 CERTIFICATE OF SERVICF I, MICHAEL D. RENTSCHLER, ESQUIRE, do hereby certify that on this date I served a copy of the foregoing document via first-class mail, postage pre-paid to: Steven C. Courtney, Esquire Courtney & Godfrey, P.C. P.O. Box 6280 Harrisburg, PA 17112 Date:, MICHAEL D. RENTSCHLER, ESQUIRE Attorney for Defendant ,VERIFICATION I, Kathie R. Grucz, Defendant herein, do hereby acknowledge that the statements contained in the w/thin the forgoing document are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. K~at 'e~R. Grucz Pennsylvania Credit Union, Ve Kathie R. State Employees Plaintiff Grucz, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL 19 NO. 03-900 RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Steven C. Court-n~y; w. qq,,ire _, counsel for the plaintiff/dl~olgbllg in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ 17,002.17 pln~ costs The counterclaim of the defendant in the action isNone The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: ~ Steven C. Court. n~v_ ~.~_quire ~-~ Michael n p~n~=~hl=~ m .... 4-- WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, ORDER OF COURT AND NOW, ~~4~ ~ ,~, in consideration of the foregoing petition, 5~"_/~,~ ~/-/-/~'~'"'~ Esq., Esq.,and _/It/fi-t_ ~'I-~ .~.- -~~'~/ff~'~- , Esq., are appointed arbitrators in the above captioned action (°r actions) as prayed for. By the P.J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. KATHIE R. GRUCZ, Defendant : NO. 2003-00900 : CIVIL ACTION -LAW TO: Kathie R. Grucz, Defendant You are hereby notified that on _ , the following (Order) (Degree) (Judgment) has been entered against you in the above captioned case pursuant to the attached Arbritration Award in the total amount of $17,002.17 plus costs and interest. DATE: Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: Kathie R. Grucz C/o Michael Rentschler, Esquire 1300 Market Street, Suite 200 Lemoyne, PA 17043 To: Kathie R. Gmcz, Defendido/a (Dcfendidos/as) Por este medio se le esta notificando que El de Del , El/la siguiente (Ordcn) (Decretc) (Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Prothonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Kathie R. Grucz C/o Michael Rentschler, Esquire 1300 Market Street, Suite 200 Lemoyne, PA 17043 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. KATHIE R. GRUCZ, Defendant : NO. 2003-00900 _. : -_ .- _. : CIVIL ACTION -LAW PRAECIPE FOR JUDGMENT To the Prothonotary: Please enter judgment in the amount of $17,002.17 pursuant to the Arbitrators' Award dated October 23, 2003, which is attached hereto as Exhibit "A", in favor of Plaintiff and against Defendant, Kathie R. Grucz. DATE: Signature: Steven . o , uire Attorney for Plaintiff P.O. Box 6280 Harrisburg, PA 17110 (717) 540-3900 ID#: 74669 , 2003, JUDGMENT IS ENTERED AS ABOVE. Prothonp~ry/Clerk, C By: ~X"I~._l~ /% ~puty Curt Long Prothonotary OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Telephone: (717) 240-6100 Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff: PENNSYLVANIA STATE EMPLOYEES CREDIT UNION versus Defendant: Kathie R. Gmcz Judgment No. 2003~900 CERTIFICATE OF RESIDENCE PA. R. C. P. 236 I, hereby certify that the precise residence of Plaintiff is: Pennsylvania State Employees Credit Union 1 Credit Union Place Harrisburg, PA 17110 and certify that the last known add~s: Kathie R. Grucz 2605 Market Street Camp Hill, PA 17011 , ' Steven C. Courtney, Esquire GODFREY & COURTNEY P.O. BOX 6280 Harrisburg, PA 17112 717.540.3900 Attorney for the Plaintiff Attorney ID# 74669 : NO. 03- ~o : OATIt IN THE COURT OF COMMON PLEAS OF CUlVlBERLAND COUNTY, PENNSYLVANIA We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of AWARD :C5~ ~e, t~.I~: ~dersigned arbitrators, having been duly appointed and sworn (or affirmed), make L th¢ tow_r award: © c:~ cO (Note: If damages for delay are awarded, they shall be separately stated.) · Arbitrator, dissents. (insert name if applicj~b...~_.)~, Date °f Award: /~' 2~3-°-'~ NOTICE OF ENTRY OF AWARD Now, the ~ day of ~rJ. , 20~_"~ , at ~ :~¢ ,/~ .M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Artibitrators'compensation to be 7~ Paid upon appeal: Prothonotary $290.00 By: