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HomeMy WebLinkAbout03-1177Godfrey & Courtney, P.C. BY: Steven C. Courtney, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717~ 540-3900 Attorney for Plaintiff PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. JOHN A. SHEA, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA 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 fights 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 corte. 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 notificacion. Used debe presentar una apanencia 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 Bar Association 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 or 1-800- 990-9108 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. JOHN A. SHEA, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Steven C. Courtney, Esquire, 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 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, John A. Shea, is an adult individual with a last known address of 59 West King Street, Shippensburg, Cumberland County, Pennsylvania 17257. Defendant is, and at all relevant times material hereto was, a applicant for a loan with Plaintiff. 4. Defendant applied to Plaintiff for a Visa and Personal Service Loan. A true and correct copy of the loan applications is attached hereto, incorporated herein and marked as Exhibit 5. Pursuant to the Visa and Personal Service Loan Application 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 true and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 6. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms and conditions of the Contract marked as Exhibit "B". 7. Various charges and/or purchases were made by Defendant on the Visa and Personal Service Loans with Plaintiff. 8. Defendant has not made a payment on account of the Personal Service and Visa Loans with Plaintiff since August 13,2002. 9. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 10. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 11. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 12. 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. 13. As of March 4, 2003, the total balance due, owing and unpaid on Defendant's Visa and Personal Service Loan accounts with Plaintiff is the sum of $ 9,223.98 Dollars. 14. Pursuant to the terms and conditions of the extension of credit contained on the loan application, Plaintiff is entitled to receive and Defendant agreed to pay an annual interest charge on the principal loan balance. 15. Pursuant to the terms and conditions of the extension of credit, Defendant agreed to pay reasonable attorney's fees and all court and collection costs. 16. Plaintiff has retained the services of the law firm of Godfrey & Courtney, P.C. in the collection of the amounts due and owing by Defendant. 17. 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. 18. Dollars. 19. by Plaintiff. 20. arbitration. The amount of attorney's fees 21. incurred in this matter is the sum of $1,869.80 Any and all conditions precedent to the bringing of this action have been performed The amount in controversy is within the jurisdictional amount requiring compulsory COUNT I WRITTEN CONTRACT Paragraphs One (1) through Twenty (20) are incorporated herein by reference as if set forth in their entirety. 22. Defendant has accepted the monies provided by Plaintiff pursuant to the terms and conditions of the Contract marked as Exhibit "A". 23. 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 account balance, all to the damage of Plaintiff. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, John A. Shea, in the amount of $ 9,223.98 Dollars, plus interest, reasonable attorney's fees in the amount of $1,869.80 Dollars, the costs of this action, and such other relief as the Court deems just and proper. COUNT II QUANTUM MERUIT 24. Paragraphs One (1) through Twenty-three (23) are incorporated herein by reference as if set forth in their entirety. 25. The aforesaid amount of $11,093.78 Dollars is the fair and reasonable value of the services/monies provided to Defendant by Plaintiff. 26. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay the fair and reasonable value of the services/monies rendered to Defendant plus any accrued interest, all to the damage of Plaintiff. WItEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgrnent in favor of Plaintiff and against Defendant, John A. Shea, in the amount of $ 9,223,98 Dollars, plus interest, reasonable attorney's fees in the amount of $1,869.80 Dollars, the costs of this action, and such other relief as the Court deems just and proper. COUNT IH UNJUST ENRICHMENT 27. Paragraphs One (1) through Twenty-six (26) are incorporated herein by reference as if set forth in their entirety. 28. Defendant would be unjustly enriched if it were permitted to benefit from the services/monies provided by Plaintiff without paying the monies owed to Plaintiff. 29. The aforesaid services/monies provided by Plaintiff and accepted by Defendant have enriched Defendant in the amount of$11,093.78 Dollars. 30. Said enrichment would be unjust if Defendant was not required to pay the monies owed to Plaintiff, and said Defendant accordingly is obligated to Plaintiff for said amount. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, John A. Shea, in the amount of $ 9,223.98 Dollars, plus interest, reasonable attorney's fees in the amount of $1,869.80 Dollars, the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, O~REy~Ey, P.C. By: -x~ rf Steve~~ Esquire P.Of,--B6x 6280 Hardsburg, PA 17112 (717) 540-3900 I.D. # 74669 Attorney for Plaintiff VER1TICATIO.N_' I, Bormie L. Berkoski. hereby certify that the following is correct: The facts set forth in the foregoing Complaint we ba_scd upon information which ] have ft.wnished to counsel, ~ ,.,.'eli as.upon information wb_ich h~ been ga~ered by counsel and/or others acting on my behalf in th.is matter. Thc language of the Complaint is that. of counsel and not my o,.wa. I have read the Compl~nt, and to tlxe extent that it is based upon information which I have given to counsel, it is true ~d correct to the best of my knowledge, information, md belief. To the extent that the content of the Complaint is Sat of cou_,-,.sel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 15 Pa. C.S.A. {4904 relating to mu'om falsification to authorities. Bonnie L. Berkoski Request Voucher COMPLETE AL, L INF, ORMATION 7 5.77 WRITE BELOW -- FOR CREDIT IJNlOt, LOAN APPROVED: ' AUTO $ '- - IRA $ ~. :..: . -:"- LOC$ ~LOAN DENIAL: ILl AUTO C'~ PSL [3 SHARE :":~ :... FO( $ : ' ' ~_O&te ~ ::"!-~'~::'L.::.:' :'- Reaz, on~' EC II CH DO AH F)O Commont~ _ t EUOA NOTICE AND REASON FOR REJ£CTION SENT ON (DATE) . ...:- _ '; -.. · . ......~.~.~_.,_~.~.~_._~ -.~.~.~ ONLY CHECK APPL~Amr: ~x~S) :' - .... "~ PSL - SHARE S .. ~3 : - : : ;' ::.' ~ : .. -~,.... -:; '-;.: ~_ ~ ~ ~ '-;~-: . Loan Disclosures ~ LO~NLJ~m Cmcr~ ~nd .~ &;eament. va~h Indudes ~T~ ~ ~U~~~~r~ ~~a~te~~ 1. H~IS P~ WORKS --~ ~ an ~n~. ~-~tu~ ~ ~.We anti.re ~ f~ ~ to ~. ~ ~ ~n~ ~ (~ '~s~ u~r ~r~t ~ ~ ~ (~ ~~ a~ u~r ~ ~, ~ ~t ~tere~ ~te ~ ea~ su~nt ~re~ as a da~ ~ ~e a~ ~ing ~al ~n~ rote ~ ~r ~arg~. ~ ~ al~ ~ ~r ter~ a~ a ~ule ~ ~termini~ ~ ~nt a~n~. ~ CRED~ MM~ ~We ~y. ~ ~ ~t ~ ~. ~ a ~ ~ ~ 3. REPAYME~ ~Y~ ~ ~ m~ M ~ ~ ~ ~r'~ ~ ~ ~ ~ ~~ use o; ~ur ATilt ~rd. You ~1 ~[ ~ F~e ~t u~ u~ ~t ~m a~er ~u ~t~ ~. o~lly ~ in w~. of ~ ~. ~ or ~ u~ u~. If ~ ~ ~r AT~e~ ~ ~ ~n ~ or ~ ~ a~ ~t ~m e~m ~ ~e P~n. If ~ ~d ~ u~ ~ me ~ ~ ~ ~ ~ ~er~ ~ ~ g~n ~ ~ ~ ~ ~ ~e. ~ ~ ~ gi~n ~ ~elF~ ~ ~ ~ n ~n ~ ~. ~t 7. P~OPE~NSU~C~T~GS AND FE~ ~Y~ ~1 ~ ~ ~ ~ due under your insurance Ix(cy. Yo~ promise to pay all taxes and fees (like regiseation fees) due o~ the property and to keep the property insured against loss If Y°~ d° not PaY the taxes o~ fees on the ~erty vd~en due cr keep it insured, we may pay these obligalJo~s, ~ we are not required to do s~ Any moray we ~nd Io~ taxes, fees o~ insurance will be added 1o Ire unpaid balance of the you wiU pay interest on those amounts at em same ~ate you agreed to ~ en the advance. We. may recek~ payme~ in cnonectio~ ~ the insurance from a cha~ed added to ~x~r advance may include (1) ~e insa~nce ~s ~ Insurance will not be Ilablaty Insurance. g. CREDIT INSURANCE -- C~ecr~ life and/o~ ¢recr~ ¢rtsabilily insuram3e is optional us ~o add Ihe insurance Premiums monlt~ to ~r loan balance and cha~e you Interest on the entire balance. If you elect crecr~ Insurance, your payments may beyond the approximate term stated on the Addendum. The credit insurance rates may change during the Plan. If the rotes change, we will l~ovide any notices required by appr~cable law. 10. PERIODIC STATEMENT ~ On a regular b~sis yo~ will receive a slatement showing all transactions under the Plan during the period covered by ltm statement. Statements and notices will be sent to you at the most recent address you have g'~n us in writing. Un~,s appr,:at~e law cequkes notice to each joint borrow, er. notice to any one of you w~31 be notice to all. · 11. JOINT ACCOUNTS -- If this Is a joint account, each of you is ind'widually and rights under the Plan against any one of you ind'~,:lually or against all el you togaltmr. If yoo gi~e us inconsistent instmc~ons; we = refuse to follow your instn, a:tions. Unless oor,~rittefl po&~,y m<Nims all of you to sign for an advance, each of you am2xx, tzes Ihe other(s) to c~tain advances lnceadually and agrees to repay advances made to Itm c~e~s). 12. FEES AND CHARGES -- ff ).~J give us & secudty intem~t in certain types el us updated financial 14.'DEFAULT ~ T/~ fo#owing paragrap~ applles 'to bor~m~ I~ ~daho, Kansas, Maine and South Olmlln~: You v~ be in defatf4 ff you do not ~ a payment of the amcx~ required when It is due. You will ,,bo be in default # we The foliowfng paragraph apf~es only to boffowers in Wls~slm You v~ be default if you fail to make a payment when due two times cluing any 12-month. impaim your ability to repay what you owe. You will sbo be in default il b~eaking any :)romise made under a Secmffy Agreement made in com3ec~ ~ an advance. materially impaim the coflcfiliofl, value. ~' I~'o(ectiofl o! o~ our ~ght in the property you It you are more than 10 daTs late in maidng a paymef~L you wal also. l:m in delault ~ 15. ~ONS ~l~ D~LT ~ ~ ~l~g ~gmph ~ to ~e~ In ~do, DIs~ct of ~lumb[a, lows, ~n~s, ~ine, Ma~u~, M~u~ Neb~s~, ~e~ ~inla and ~ ~ll~: ~ ~ ~ ~m ~ ~ ~ ~ ~ ~te ~ of ~ ~m ~ ~ln and ~u~: ~n ~ am ~ ~uE. ~ ~n ~ulre ~te ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ to a~mte ~ ~-~ a~m~~~~ffa~~~e~ ~ ~ ~ ~ ~.We ~ ~ ~ a~ o~r ~ ~ ~ ~ ~ ~ ~ °f ~ ~ ~. p~ a ~ ~ auks ~ ~'~ ~ ~ ~e ~ ~ ~r~) of~ ~~. 1~ ~O~ ~R DEF~LT ~ ~NSIH ~ ~ f~/~ng '"~"~ rem "a"aaeea an me ~ ff I demmxl lot knmecrmle pe)~enl m me.Fape~y. . 18. CANCELLING OR CHANGING' THE PLAN ~ The following mpplles ordy to borrowem In Illinois: We ha~ ~he dght to ctumge me tern= The following paragraphs apply o~ly to borrowe~ In Wlsconslm We can of the Wisconsin Statutes. You wOI be noUfied of any change in terms. An Increase in Ire daily perkx~ rate u~der a variable rote Interest rote is not oonsklemd a We can cancel the emlm Plan or any part of Ihe Ptan at any lime. You may canoet ~e Pta~ at any lime by giving us pdo~ wdtten not~=e. Your ot34igatkm lo pay Ihe ~ ~EOFP~--~~ ~ ~~~~. m me I~rty Is la~X. (3) In~ us In writing I:~ ~ your ad~ (4) 26. NORTH DAKO'I:A NOTICE TO B~R~ PURCHASING A M~R VEHICLE. THE M~R ~ ~~~N MAY BE,SUBJECTTO REPOSSESSION. IF IT ~S REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUETO THE SECURED PARTY ARE NOT RECEWED IN THAT SALE, YOU MAY HAVE TO PAYTHE Du-I'I~ENCF_ 27. VERMONT NOTICE TO CO-SIGNER ~'YouR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY UABLE FOR REPAYMENT OFTHIS LOAN. IFTHE BORROWER DOES NOT PAY,*THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. ~ ff Y°° rm requesl and tatum ail cards. Your obflgad~ to pay ~he account batance co~inu,~ eve~ Itxx,~h an agreement, d'wome dec:me or ob~er court Judgment to which we are not a party may direct yx3u or one of the other persons fe'~:Xl~l~e to pay the accounL 2. LOST CARD NOTIFICATION ;- If you believe the card has been lost or ~tolen, you will Immediately call ttM Cred'~ Union at (717J 234-84~4 or (800} 237-7328. After aue~_.purc*~__ ~ ee date they ~- ~ ~ are a~ re ~ to ~r a~nt. ........ : ~ pu~ ~ ~ ~ ~ ~ a~ -- call (800) 5565678. Cash Advance~: We calculate - ur ' USE- ....... ~~~,~ ......... ,~~~.~ J_ ~'~~~~ ....... m ~ ~ ~ ~ ~ ---~---~, ........ 6. MONTHLY PAYMENT -- We will mail you a statement every month showing ,- .... ~ ~,,u cash advance, the TotaJ New BaJance. the ~'tance The mlrkr,~ paym~ ~ he'(a} 2'/. ~ y,~.Tota~ New BaJance. ro~'x:~d t~ to ~ ..... ,,,,,uums m ~ cm<r~.s m' payments which post to your u"I~aK~ nc~ C~arges o~ L~te Cha~es. Then we a~so ~:~a¢~ i~e amo~.~ of fro-- ~-- ~.:'.'Z ....-,, ,~ovanc~ are alwa~ subject to flnam~ ¢h~rg~ .nd ,- -,- ~ mey am IX~ted. to yoor account. ~ment. s are appr, ed in U~e toaowing manner:, fir~ to previous fate fees, me~ to law To the ex*er* g- USING THE CARD -- To make a purdtase or cash adv.azx:e, thore am two cx)~ur~ ~ ~m card in an A~tomated Teller Machine or other type of electronic 10. RETURNS A~D ADJUSI~IENTS -- Men;:hanls ~ o~ers who hon~ lhe ca,'d oy o~e peece~[. . . ~'-'"'""~'~ a~.e. 12. I~A,N MERCHANT 0~PUI'E~ ~ We &m not re~ble io~ ~he ~ . specific pledge of ~3<Jr (:m<~t unio~ shares (Deposits) by signing the Ptedge of Shares or othenvise, or any other security k-,terests for aa your deb~, your lS. LATE PAYMENT CHARGE -- {f ycx~' Minimum Paym~n~ ~ nc~ ~ vHthin 15 days a~er the ~ Due Date, you will be subject Io a single cha~ge d $% o~ the /,our MAC card(s) cortsdtutes acceptance of the terr~s and condRions of this ~entent. Yo~f undemland that MAC' is a c~edit-~elated service and you authorize 3SECU to obtain a oredit report o~ any users of t~s account. I. Acco~nt~ and Uses of MONEY ACCESS CARD Yo~ have the acx:o~t(s) (indud'~g Ct~ng and Re~ula~ Shares), wf~h we set ~ on your appGcation form ~ this Agreement. You hereby reque~ that we You unde~a~ ~ may ~se me MONEY ACCESS CARD at · ,4CCE~ CENTER' to (1) withdraw cash from. (2) make or arrange for depo~ bt. (3) effect tra-.~fers to o~ from yo~r'aoco~m. (4) receive lr~orma~<~ rega,-o~g 4J~e of Pere, o~al Identification Number ("PIN') tvfth MONEY ACCESS CARl:) Yo~ understand that a MONEY ACCESS CENTER or a PLUS SYSTEM ATM is a~ automated tel~c I1 ca~ and v~ll Porform many of the same tasks as a ~ teger. You acknowledge lttat the PersonaJ IdentJficatJo~ Number or PIN whic~ you use wish ~%e MONEy ACCESS CARD is ycx~r signature, identJfie~ the bearer of ~e C4u~ lo the MONEY'.4CCESS CENTER, PLUS SYSTEM ArM, or other validate the directions given just as your actual signature v~ll authenlfcate and validate your directions gk,~n to us. You acknowledge ~at y~x~r PIN is an identificatio~ code that is persor~ a,-x:l co~Klenl~ a.'xl that the use of the PiN with the MONEY ACCESS CARD is a secudty devise for your ;Therefore. YOU AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO ONE F_L~E LEARNS YOUR PIN. 3. Uabil{ty for Urmu~o~zedTrm~ac-dons Yo~ agree to conta~ us at once/t' yo~ ~ the MONEY ~ CA~s) Issued to yo~J orPIN has bee~ lost 0f ~tolen ~' money is ~issing from yo~Jr account(s). You aL~o agree ~ if your mon~/~tamer4 ~ YOU AGREE THAT IFYOU GIVE YOUR MONEY A4:X~ESS CARD(s) and PINTO choose a PIN If-~t is early ~. , retaloed by the MONEY ACCESS CENTER. PLUS SYSTEM, o~ HONOR ATM. 4. Charge~ Yo~ agree to pay a 50 ce~t charge fo~ each deposit or wttt~lrawal excae<rmg 15 wf~ch ma7 later be offered as such fees or chaJ;es may be ~ or c~mnged Y~J agree that when yo~ mane a deposit at a MONEY ACCESS CENTER that If yo4J de~,vor ~ checks or c~Ser i{ems toa MONEY .N~ CENTER, account(s) w~h Items <Xher ~ cast~ (check, dra~s o~ o~er #ems) ~ ~ ~ ~ ~ ~. ~ ~ ~r~s) am ~ at ~ ~, 7. ~~t of ~ll Ag~ REOU~ON ~ ~~~ ~a~er~ ~ E~ ~we~ ~ T~p~ Num~ ~ A~s to ~ of U~~ Tm~fe~ ~at ~) ~-~ ~ ~~ ~. ' A~ and ~. ~ P~E~'at (~) ~-~8 (~~) or ~0. ~ ~13 ~, ~ 171~7013 ~O (~) ~-1~ ~ 4. ~ ~ ~ T~n~e~ a ~su~r ~ Make PSE~ ~ ~ ~ ~ ~ 7. ~ ~t Rlgh~ - P~o~ ' ~C a~ ~- Not ~e. * A~* Right to Stop ~nt end P~u~ ~ d~g ~. ~a~~~r~ ~~14~~ ' ~~u~op~tofP~~Tm~e~ff~r 8. Summa~ of ~e Rnanclal Insflt~on's Failure to Make ~ Stop ~i~ Tin.em ~um ~(1) ~m ~e ~ ~ ~~ ~ ~ to believe ~hat the trar~=____~.-~ requested is unau~'mdzed; (6) ~he tdlure ~ ~allure to make the tm~.=___c~Jo~ resulted from a b<ma i~de e~ro¢ despite PSECU's DlscJo~um to Third Parties MAC, ACH m~d ~T- PSECU vdll dL~k)se irdommb~<m abo~t your eccoor~ to soc~ a.~ a cmdt Ixa~m; (3) to comply w~ government agency o~ court orders; (~) ~ .cco~da~ ~ your ~'~e~ perm~k~* (5) to oom~ wftu 0ovemm~.. or. a<~nir-~,e a;ency r, ommmses. ~. o~ court o~lers; (6) o~ rece~ o~ c) i a c&~ edvuflce from yqoqx Pemomd Service Loan (p~L). ~ ~ m~ M~ ~E~ C~. PLUS SYS~ ~C O~ - Y~ ~~ N~r ~1~ (~S SYS~ c) ~ = ~ ~ f~ ~r ~ ~ ~ (~. ~ M~ ~ CARD. ~ ~r ~1 ~ L~n (~L). c) ~ ~ ~ a~ ~ ~r ~ ~ ~ (PSL). H~ ~ ' ~H~SY~~~r~~.~o~~e. ~ A~ N~ A~ l~~Tm~ at 12 ~~ ~.~~~, ~m ~ ~ ~ ~ CARD.~..,~ tn& MAC and; (c) The dollar amount of HO.On sYs'r~, Se-F-SERViCE Ta.EPHO. E. T c o.s. o, ~~ ff~ ~ ~ U~ ~ ~ ~U$ SY~, SE~CE ~E, or Ol~ D~~ q~ ~ ~ ~ 10 .~~. N~ To ~m Using ' ff ~ A~ ~ ~ ~, ~ ~ ~r pdor to ~6~r~' ' Dir~ ~ ~ A~ ~ to an ~te ~nt of ~ ~r of ~ A~ N~ For those members who purchase a vehicle under the DRIV Program, please revlew the following' FTC Notice: ANY HOLDER OFTHIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES VI~-IICH 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. Godfrey & Courtney, P.C. BY: Stcven C. Courtney, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717} 540-3900 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. JOHN A. SHEA,' Defendant Attorney for Plaintiff IN THE COURT 01~ COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1177 CIVIL ACTION -LAW PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Please withdraw the Complaint filed in the above referenced matter. The Defendant has filed Bankruptcy. GODFREY & COURTNEY, P.C. Dated: By StevenS'. Courtney, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717) 540-3900 Attorneys for Plaimiff Document #: 181832.1 SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-01177 p COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES SHEA JOHN A VS R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SHEA JOHN A unable to locate Him COMPLAINT & NOTICE in his bailiwick. but was He therefore returns the the within named DEFENDANT SHEA JOHN A , NOT FOUND , as to 59 WEST KING STREET SHIPPENSBURG, PA 17257 59 W KING STREET SHIPPENSBURG IS VACANT. NO FORWARDING ADDRESS AT POST OFFICE. Sheriff's Costs: Docketing 18.00 Service 13.80 Not Found 5.00 Surcharge 10.00 .00 46.80 SO answer .s~/ ~--*-' ~-"~ ~'"/ Sheriff of Cumberland County GODFREY & COURTNEY 04/07/2003 Sworn and subscribed to before me this /6~ day of ~ ~0%k3 A.D. P~o~hon6t ary - '