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Home My WebLink About00-06326 ~, J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, NO, 00 - (,.JJC... Ci(.)~L l~ Plaintiff vs. SANTOS A. TORRES, Defendant 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 corte. Si used qui ere 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 apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas 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 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Used puede perder dinero 0 sus propiedades 0 otros derechos importantes para used, LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717/249-3166 Document #: 184644.1 II . . c IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYL V ANJIA STATE EMPLOYEES CREDIT UNION, /'>-.1 "'f~ NO, (}(P _ (,),2.& L..<>><-' Plaintiff vs, SANTOS A. TORRES, Defendant CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Steven C, Courtney, Esquire and Metzger, Wickersham, Knauss & Erb, P.C" and states the following cause of action and in support thereof, avers as follows: I, 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 I Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Santos A. Torres, is an adult individual with a last known address of 203 W. Main Street, Walnut Bottom, Cumberland County, Pennsylvania, 17266, 3. Defendant is, and at all relevant times material hereto was, the primary applicant for a Personal Service Loan. 4. On or about October 13, 1988, Defendant applied to Plaintiff for a Personal Service Loan. A true and correct copy of the loan application is attached hereto, incorporated herein and marked as Exhibit "A". Document #: 184644.1 ~, ~ Ii 5, PursUll11t to the 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. The contract marked as Exhibit "B" contains the terms and conditions of the extension of credit agreed to by Defendant. 7, Various charges and/or purchases were made by Defendant on the Personal Service Loan with Plaintiff. 8. Defendant has not made a payment on account of the Personal Service Loan with Plaintiff since August 17, 1999. A true and correct copy of a partial statement of account for the Personal Service Loan, consisting of one (1) page, is attached hereto, incorporated herein and marked as Exhibit "C", 9, Plaintiff has maintained a statement of account, marked as Exhibit "C", 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. II, 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 swns due and owing on Defendant's loan account balance, all to the danlage of Plaintiff. Document #: 184644.1 II . j "'"'~' '".,,~ 13, As of August 8, 2000, the balance due, owing and unpaid on Defendant's Personal Service Loan account with Plaintiff is the sum of Eight Thousand Eight Hundred Ninety-four and 91/100 Dollars ($8,894.91), 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 Metzger, Wickersham, Knauss & Erb, 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 Metzger, Wickersham, Knauss & Erb, 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 ofthe proceedings, 18. The amount of attorney's fees incurred in this matter is the sum of One Thousand Seven Hundred Seventy-eight and 98/100 Dollars ($1,778.98). 19, Any and all conditions precedent to the bringing of this action have been performed by Plaintiff, 20, The amount in controversy is within the jurisdictional amount requiring compulsory arbitration.. Docume~t#:18464~1 II , I WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Santos A. Torres, in the amount of Eight Thousand Eight Hundred Ninety-four and 91/100 Dollars ($8,894.91), plus interest, reasonable attorney's fees in the amount ofGne Thousand Seven Hundred Seventy-eight and 98/100 Dollars ($1,778,98), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, B: St v 321 Front Street Box 5300 Harrisburg, P A 1711 0 (717) 238-8187 !.D. # 74669 Attorney for Plaintiff Dated: Document #: 184644.1 - , I '-""',,: 07/21/2000 14:14 FAX 7172349478 l4KtcE BBG Pi\. I<<IUUZ VERIFlCATION I, Bomrle L, Berkoski. hereby certify that the following is com:ct: . The facts set forth iu the fmegoing Complaint are based upon information which I have furniShed to counsel, as well as upon infunnation which has been gatheml by co\lllSel and/or others acting 0lI my bc:haIf in this matter. The language of the Cumplaint is that of counsel and not my own. I have read the ComplaWt, and to the extent that it is based upon. infonrnrtion which I have given to counsel, it is txue and correa to the best of my knowledge, inflmnatiOll, and belief. To the extent that the content of the Coinplaint is tbat of counsel, I have Nlied upon such counsel in making this Verification. I heleby acknowledge that the facts set forth in the aforesaid Complaint are made subj~ to the penalties of ,18 Pa. C.sA f4904 relating to lmSWOm falsification to a\Ithorities. -;:?- ~.~}OIL Bonnie t.. Berkoski Date: ~ _It 1/!fJ/11.l i QFFJCE uS[ ONLY 'j' , , . I ]1 CIWOfT L.IMlT --;----____ _ 'Pfl ._. .:.;~~.:J.!.l L..!---:.:..L\_ _ ~_~___,__:___ ~~__~_ I _.hi____,_ ,:,. '-~---- ;.......L-- L-_.__ L I I l I I l I I , I I 'u '0 , "-M- l ,; o .'. ..... ~.rl-m..Vl'..ANI.. STATE EMPlOYEES CREDIT UNION "'"PIICATIUN FOR'" PERSONAl.. SlRVICE LOAt1 '"H. " N.... ",~.("d'( .4 /t'~_ CUAAEHT TOTAl PRO I HEW TOTM. II'RDAMOUNT I Tobo__'" 'O__.lIi__ 0__ o 1ulDrnahC1'....l'(cfIooMClneI_ ftlClhlhty.111t _ "'"*"r. t8tt1: _ -.6._..... PSECU ...-rv.... 1'"' ..9'11 10 rfqU"" '1'1""10<"1 ""Ior~m)fl If ~ A!'PlleANT INFORMATION ........... () t'''' t..J T r-_~ I".~/^ jr - ~OI'~"'" '> ~ ::r " ~ '< c ~ o' r. o " ;; ~ Ii " 3 " ! -=- r ~,-: - - ~ 0- "" -;... ~,....... -- ~T. ""'011_'--''''- - - -... , . n.eMCllllnl...,.. wltlMrdl-..ff...... _ltat,.,... "lftCIIIlIIetor ......._....... "IN........ Nfr on......... tor,.,.,..... .. ~ II.... ~ IlIII C1Df\IIIIlNd 1Ind.......... __... CO.APPltCANT INFORMATION (Co.....1eant mulll...... with .ppI&cllnt and be eUgible lot meMberUUp.) ..... .... ..... .. ..... ... ...- itA, 'V - --- , , .............--'.--......................................... . . ___ ,_ i:...... ~......... -:-.r. _......................... -....CIII"!f~... -..--~ .. ~ 4-..'" ~ ~ -- ~-==:- ....... r.,..,......, .....- --- J ""'.......,,.cu ----.... . .--- "'';'t" ., ...... ~._......... .,...........'-...............~ ...................~ ................... ~c...~....... CMI..............__.... ~-......- ---...... ... .... ..., ADDMsa (W CRlDlfOM - - ......... - - -....co DAn _0 ". ~~. ......_"'........."'!o.'. Jl..' "s 00 you nave any pPI or Pf8aenIIUita. JUCSgmenta. repoo-.,-SiO"t.. b8nkr'uJ*y or oa~ ~ you? .... there any Dell or ptlIMN ..,... JudQmefdS. benkruPICY or prnilhmenll againll co-app6icam? 00 ""'.....,.,... '-""'9'" _ '" your PSL1 PLEASE READ AND SIGN THE BACK OF THE APPLICATION I ~ , ~' I ~ : , 1- ',-'. ...,. Ot !, l ;~,~., _,/ _ ......-......- ,/ POOO ':9 r~ S ~. M '0 ~ cc PC . . I' . I " I ,. t, e ~ I ' . ----,~ - -~. ,..:-~ OND Ta_~ ~"y $-----C'~~:!.. _weekly --1<C: biwee..} --- _ ___ ..."..monthr, "0thIr _. S Tok. _ P., S --~. -.. -""""", sen'lf.ntolMty "Othor _ $ -, ..- ,/ /" v y'? "v Yd." ... )P,O >' NO ~C NO """''"'''''''''''''',~'''_.~'''''h''''.'' -,' - - ,..--" ]1(1 "{ . .;;;;;;1,:.... ....... /........ .. ~ - i. -' \. 0$":' __=~~, IW:lli:;ilHl,'; I . .....1II_fII~~.......~~......~llt3,..~f.~" " "'~. i$iif'? ....-ur1~11.. : rQ'M~l ~ , ,i;:"'ti!if~-"1J-i".-. - ~ ~ --~,~ ~~ ~~ "- -. .....~ ,I~~! PS~(t Pennsylvania State EmP-fgyees Credit Union p.o. Box 67013 . Harrisburg, PA 17106-7013 . (717) 234-8484 Harrisburg, (800) 237-7328 Nationwide Loan Disclosures LOAiNL/NER" CREDIT AND SECURITY AGREEMENT This LOANUNER* Credit and Security Agreement, which includes the Truth in Lending Disclosures, will be referred to as the Plan. The Plan documents include thi~ Agreement and an Addendum. You, your and bOfrower mean any person who signs the Plan. Credit Union, we, our and us mean PSECU or anyone to whom the Credit Union transfers its rights under the Plan. This is a multi-state document which may be used to lend to borrowers in all states. 1. HOW THIS PLAN WORKS - This is an open-end, multj~featured credit plan. We anticipate that, from time to time, you will borrow money (called Madvances") under the Plan. We are not required to make advances to you under the Plan and can refuse a request for an advance at any time. The Addendum describes the different types of credit (called ~subaccounts") available under the Plan, the current interest rate for each subaccount expressed as a daily periodic rate and corresponding annual percentage rate and other charges. It may also have other terms and a schedule tor determining the payment amounts. 2. CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain subaccounts. If a credit limit is set for a subaccount, you promise not to exceed the established credit limit. If you exceed the credit limit, you promise to repay ;mrnediate\y the amount which exceeds the credit limit. 3. REPAYMENT - You promise to repay all amounts you owe under the Plan plus interest. Payments are due on the last day of the month unless we set a different date at the time of an advance. If the Addendum has no payment schedule for a sulJaccount, your payment will be determined at the time of each advance. Payments must include any amount past due and any amount by which you have exceeded any credit limit you have been given for a slilbaccount. You may repay all or part of what you owe at any time without any prepayment penalty. Even if you prepay, you will still be required to make the regularly scheduled payments unless we agree in writing to a change in the payment schedule. If you have a joint share draft account, you will be responsible for paying all overdraft advances obtained by a joint holder of the share draft account. Payments will be applied in the order the Credit Union chooses. 4. PLAN ACCESS - You can obtain credit advances in any manner authorized by us. If we allow you to use your ATM/Debit card to accea:s the Plan, you may be liable for the unauthorized use of your ATM/Debit card. You will not be liable for una.uthorized use that occurs after you notify us, orally 'Or in writing, of the loss, theft, or possible unauthorized use. If you believe your ATM,IDeblt card has been lost or stolen, immediately inform the Credit Union by calling wr writing us at the telephone number or address that appears elsewhere in the Plan. If the card is used to obtain advances directly from the Plan, your liability will not exceed $50. If the unauthorized wit/ldrawal is from a share draft account, your liability i$ governed by the Regulation E disclosures you received at the time you received your ATMlDebit card, even if the wit/1drawal results in an advance being made from your overdraft subaccount. 5. FINANCE CHARGE - The dollar amount you pay for money borrowed is called a "finance charge" and begins on the date of each advance. A finance charge will be computed separately for each separate balance und~r the Plan. To compute the finClnce charge, the unpaid balance for each day since your last payment (or since an advance if you have not yet made a payment) is multiplied by the applicable daily periodic rate. The sum of these amounts is the finance charge owed. The balance us6d to compute the finance charge is the unpaid balance each day after payments and credits to that balance have been subtracted and !any additions to the balance have been made. In addition to interest, we may charge other finance charges which are disclosed on the Addendum. If the interest rate is a variable Interest rate, the .Addendum explains how the variable interest rate works. 6. SECURrTV INTEREST - The Plan is secured by the shares and deposits in all joint and individual accounts you have with the Credit Union now and in the future. ShClres and deposits in an Individual Retirement Account and any other account which would lose special tax treatment under state or federal law if given as security are not subject to the security interest you have given in your shares and deposits. Additional security may be required depending on the subaccount under which an advance is requested. For example, a subaccount called "New Car Advances" meMS the security will be a new car. A subaccount called ~Other Secured Advances" means you must offer security acceptable to the Credit Union for the advance. Property given as security for any advance under the Plan will secure all other amounts you owe under the Plan or under any dther Agreement with us now or in the future. Property securing other loans with us may also secure the Plan. However, if you have given your dwelling as security for a loan with us. that dwelling will not secure an advance made under the Plan. 7. PROPERTY INSURANCE. TAXES AND FEES - You will be required to purchase property insurance on certain types of security that you give for a~nces. You may purchase the property insurance from anyone, you choose who is acceptable to the Credit Union. The amount and coverage of the property Insurance must be acceptable to LIS. You may provide the property insurance through a policy you already have, or .OCI)NA MUTUAL GROUP. 1980, 62, 84, 66, 89, 97, ALL RIGHTS RESERVED through a policy you get and pay for. You promise to make the insurance policy payable to us and to deliver the policy or proof of coverage to us if asked to do so. If you cancel your insurance and get a refund, we have a right to the refund. If the property is lost or damaged, we can use the insurance settlement to repair the property or apply it towards what you owe. You authorize us to endorse any draft or check which may be payable to you in order for us to collect any refund or benefits due under your insurance policy. You promise to pay aU taxes and fees (like registration fees) due on the property and to keep the property insured against loss and damage. If you do not pay the taxes or fees on the property when due or keep it insured. we may pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the advance and you wUl pay interest on those amounts at the same rate you agreed to pay on the advance. We may receive payments in connection with the insurance from a company which provides the insurance. We may monitor our loans for the purpose of determining whether you and other borrowers have complied with the insurance requirements of its loan agreements or may engage others to do so. The insurance charged added to your advance may include (1) the insurance company's payments to us and (2) the cost of determining compliance with the insurance requirements. If we add amounts for taxes, fees or insurance to the unpaid balance of your advance, we may increase your payments to pay the amount added within the term of the insurance or approximate term of the advance. 8. NOTICE - If you do not purchase the required property insurance, the insurance we may purchase and charge you for will cover only our interest in the property. The Insurance will not be liabilitY Insurance. 9. CREDIT INSURANCE - Credit life and/or credit disability insurance is optional under the Plan. If you qualify for and purchase the insurance from us. you authorize us to add the insurance premIums monthly to your loan balance and charge you interest on the entire balance. If you elect credit insurance, your payments may increase or the period of time necessary to repay your advance may be extended beyond the approximate term stated on the Addendum. The credit insurance rates may change during the Plan. If the rates change, we will provide any notices required by applicable law. 10. PERIODIC STATEMENT - On a regular basis you wlll receive a statement showing all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each joint borrower, notice to anyone of you will be notice to all. 11. JOINT ACCOUNTS - If this is a joint account. each of you is individually and jointly responsible for paying all amounts owed. That means we can enforce our rights under the Plan against anyone of you individually or against all of you together. >> you give us inconsistent instructions, we can refuse to follow your instructions. Unless our written policy requires all of you to sign for an advance. each of you authorizes the other(s) to obtain advances individually and agrees to repay advances made to the other(s). 12. FEES AND CHARGES - n you give us a security interest in certain types of property, we may charge you a filing fee to perfect our interest in the property. If so, the amount of the fee will be disclosed to you at the time you obtain an advance. We may also charge you other fees in connection with the Plan. Those fees are disclosed on the Addendum and wUI be added to your loan balance unless you pay them in cash. 13. UPDATING CREDIT INFORMATION - You promise that you will promptly give us written notice if you move, change your name or employment, or if any other in1ormat\on you provided- to U5 changes. Upon our request you also agree to provide us updated financial information. 14. DEFAULT - The following paragraph applies to borrowers In Jdaho, Kansas, Maine and South Carolina: You will be in default if you do not make a payment of the amount required when " is due. You will also be in default if we believe the prospect of payment, pertormance, or realization on any property given as security is significantly impaired. The following paragraph applies only to borrowers In Wisconsin: You will be in default if you fall to make a payment when due two times during any 12-month period. You will be in default if breaking any promise made under the Plan materially impairs your ability to repay what you owe. You will also be in ~efaul~ if breaking any promise made under a Security Agreement made in connectIon With an advance. materially impairs the condition, value, or protection of or our right in the property you gave as security. The following paragraph applies only (0 borrowers In Iowa: You will b~ in defau~t if you are more than 10 days late in" makIng a payment. You Will also be 10 default If PSECU FORM #3146 JBXX060H 037.2092.1 (3100) ". ~,~,,~~--_.= ~- _._~ , "._~~ -'~ LOANUNEF/" Credit and Secur/tv Credit A_menl (I:ontlnued) you do not comply with the terms of the Plan and your failure to comply materially impairs any property you gave as security of your ability to repay what you owe under the Plan. The followIng paragraph applies to borrowers In all other states: You will be in default if you do not make a payment of the amount required when it is due. You will be in default if you break any promise you made under the Plan or if anyone is in default under any security agreement made in connect/on wlth an advance under the Plan. You will be In default if you die, file for bankruptcy, become insolvent, Jf you make any false or misleading statements in any credit application or update of credit information, or if something happens we beli~ may substantially reduce your ability to repay what you owe. You will also be in default under the Plan If you are in default under any other loan agreement with us. lS, ACTIONS AFTER DEFAULT - The following paragraph appllas to borrowers In Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, West Virginia and South Carolina: When you are in default and after expiration of any right you have under applicable state law to cure your default, we can demand immediate payment of the entire unpaid balance under the Plan without giving you advance notice. The following paragraph applies to borrowers In all other states except Wisconsin and LouisIana: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any fight you have to demand for payment, notice of Intent to accelerate and notice of a.cceleration. The following paragraphs apply to borrowers In all states except, Wisconsin Ilnd Louisiana: If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid, at the applicable interest rates in effect unless Cl default rate is disclosed on the Addendum. If a Ciiemand for immediate payment tlas been made, the shares and deposits given as security for the Plan can be ClPplied towards what you owe. We can also exercise any other rights given by law when you are in de'fault. You agree the Credit Union has the right to take possession of any property given as security for an advance under the Plan without Judicial process if this can be done without breach of the peace. If we ask, you promise to deliver the property at a time and place we choose. We will not be responsible for any other property, not covered by this Agreement, that you leave inside the property or that is attached to the property. We will try to return that property to you or m'ake It available to you to claim. After we have possession of the property, we can sell it and apply/the money to any amounts you owe us. We will give you notice of any public sale. or the date after which a private sale will be held. Our expenses for taking possession of and selling the property will be deducted from the money received from the sale. Those costs may ioclude the cost of storing the property, preparing it for sale and attorney's fees to the extent penmitted under state law or awarded under ~S06(b) of the Bankruptcy Code. The rest of the sale money will be applied to what you owe under the Plan. 16. ACTIONS AFTER DEFAULT - WISCONSIN - The following paragraph applies only to Wisconsin borrowers: When you are in default and after expiration of any right you have under applicable state law to cure your default, we may require immediate payment of your outstanding loan balance under the Plan and seek possession of the property. You may voluntarily give the property to us If you choose, or we may seek to take posseSSion of the property by judicial process. If we repossess the property, you agree to pay reasonable expenses incurred in disposing of the property. If the property is a motor vehicle, mobile home, trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted by Section 422.413 of the Wisconsin Statutes. 17. ACTIONS AFTER DEFAULT - LOUISIANA - The following paragraph applies only to Louisiana borrowers: When' you are in default, we can require immediate payment (acceleration) at the entire unpaid balance under the Plan. Vou waive any right you have to demand for payment, noli.. of Intent to accelerate and notice of acceleration. If immediate payment is demanded, you will continue to pay interes\ until whet you owe has been repaid a\ the applicable interes\ rates in effect unless a defauft rate Is cfrsclosed on the Addandum.lf a demand for immerfrale payment has been made, the shares and deposits given as security for the Plan can be applied towards whet you owe. We can also exercise any other rights given by Iew when you are in defauli and our rights under any security agreements you have with us. 1a. CANCELLING OR CHANGING THE PLAN - The following paragraph applies only to borrowers In Ifflnols: We have the right to change the terms of Itle Plan from time to time after giving you any advance notice required by law. Any change to the interest rate or other charges wUl apply ro future advances. The following paragraphs apply only to borrowera In WIsconsin: We can change the terms of the Plan from time to time in accordance with Section 422.415 of the Wisconsin Statutes. You will be notified of any change in terms. An increase in the dally periodic rate under a variable rate Interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel ttle Plan at any time by giving us prior written nmice. Your ob\igation to pay the unpaid balances under the terms of the Plan' continues whether: you or the credit union cancel the Plan, except to the extent that your liability is limited by Section 422.4155 of the Wisconsin Statutes. II ~~"~ i- -~ The following paragraph applleiJ only to borrowers In Iowa: We can change the terms of the Plan from time to time after giving you any advance notice required by law. A change that Increases the rate of finance charge or other charge, that increases the amount of your payments, or that otherwise adversely a.ffects existing balances will apply to existing balances only if you agree to the change or you use the Plan after receiving notice that your use of the Plan means you agree the change applies to existing balances. The following paragraph applies to borrowers In all other states: We have the right to change the terms of the Plan irom time to time after givJng you any advance notice required by law. Any change In the interest rate will apply to future advances. and at our discretion, and subject to any requirements of applicable law, will also apply to unpaid balances. The following paragraph applies to all borrowers other than Wisconsin borrowers: An increase in the dally periodic rate under a variable interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You can cancel the Plan at any time. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the Credit Union cancel the Plan. Sections 21-25 apply If you give security In connection with an advance under the Plan. They apply to borrowers In all states except louisiana. Loulslana borrowers will execute a separate security agreement. Borrowers In other states may also be asked to execute a separate security agreement. 19. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay enforcing any of our rights under this Plan any number of times without losing the ability to exercise our rights later. We can enforce this Plan against your heirs or legal representatives. If we change the terms of the Plan, you agree that this Plan wUI continue to protect us. 20, CONTINUED EFFECTIVENESS - If any part of this Plan is detenmined by a court to be unenforceable, the rest will remain in effect. 21. THE SECURITY FOR THE LOAN - You give us what is known as a security interest in all property described in any receipt voucher or other document you receive for an Advance \the Advancej. The security interest you give includes all accessions. Accessions are things which are attached to or installed in the property now or in the future. The security interest also includes any replacements for the property which you buy within 10 days of the Advance or any extensions, renewals or refinancing of the Advance. It also includes any money you receive from selling the property or from insurance you have on the property. If the value of the property declines, you promise to give us more property as security if asked to do so. 22. WHAT THE SECURITY INTEREST COVERS - The security interest secures the Advance described in the receipt. voucher or any other document you receive at the time of the Advance and any extensions, renewals or refinancings of the Advance. It also secures any other advances you have now or receive in the future under the Plan and any other amounts or loans, Including any credit card loan, you owe us for any reason now or in the future, except any loan secured by your principal residence. If the property is household goods as defined by the Federal Trade Commission Credit Practices Rule, the property will secure only the Advance and not other amounts you owe. 23. OWNERSHIP OFTHE PROPERTY - You promise thaI you own the property or M Ihe Advance Is 10 buy \he property. you promise you w"I use the Advance for thaI purpose. You promise that no one else has any interest In or claim against the property that you have not already told us about. You promise not to sell or lease the property or to use It as security for a loan with another creditor until the Advance is repaid. You promise you wilt allow no other security Interest Of lien to attach to the property either by your actions or by operation of law. 24. PROTECTING THE SECURITY INTEREST -If your stale Issues a IIUe for the property, you promise to have our security interest shown on the title. We may have to file what is called a financing statement to protect our security interest from the claims of others. If asked to do so, you promise to sign a financing statement. You also promise to do whatever else we think is necessary to protect our security interest in the property. 25, USE OF PROPERTY - Until the Advance has been paid off, you promise you will: (1) Use the property carefully end keep ~ In good repair. (2) Obtain our wrilten permission before maktng major changes to the property or changing the address where the property Is kept. (3) Infonm us In wrlllng before changing your address. (4) Allow us to Inspect the property. (S) Promptly notify us ff the property Is damaged. stolen or abused. (6) Not use the property for eny unlawful purpose. 26, NORTH DAKOTA NOTICE TO BORROWERS PURCHASING A MOTOR VEHICLE. THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECTTO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. 27, VERMONT NOTICE TO CO-SIGNER YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OFTHIS LOAN,IFTHE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU, ~. _I~ ~~ - ~__ ~'~_ilII,IllIt~<:..jl;Ol> C"'" ~~ 4_.~~"O'~~_ " BILLING RIGHTS . This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUTYOUR STATEMENT- If you think your statement is wrong, or if you need more in10rmatlon about a transaction on your statement, write us on a separate sheet at the address listed on your statement. Write to us as soon as pOSSible; We must hear from you no later than 60 days after we sent you the first statement on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your leUer, 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. It you need. more Information, describe the item you are not sure about. If you have authorized us to pay a credit card account automatically 1rom your share account or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your leUer must reach us three business days before the automatic payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRfTTEN 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 statement 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 send statements to 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 pay the parts of your statement that are not In question. It we find that we made a mistake on your statement, you wm not have to pay any finance charges related to any questioned amount. If we didn'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 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 you and you write to us within ten days telling us that you still refuse to pay, we must t9l1 anyone we report you to that you have a question about your statement. And. we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. Ii we don't 1ollow these rules, we can't collect the iirst $50 of the questioned amount. even if your statement was correct. SPECIAL RULE FOR CREDIT CARD PURCHASES - If you have a problem with the quality of property or services that you purchased with a credit card, 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 property or services. There are two limitations on this right: (a) You must have made the purchase hi your home state or, if not within your home state, within 100 miles of your current mailing address; and (b) The purchase price must have been more than $50. These limitations do not apply If we own or operate the merchant, or if we mailed you the advertisement for the property or services. l/ISA@ CREDIT CARD AGREEMENT AND TRUTH IN LENDING DISCLOSURE. In this Agreement, the words you and your means each and all of those who apply for the card or who signs this Agreement. Card means the VISA Credit Card and any duplicates and renewals we issue. Account means your VISA Credit Card Line of Credit account with us. We, us, and ours means this Credit Union. 1. RESPONSIBILITY - Ii we issue you a card, you agree to repay all debts and the Finance Charge arising from the use of the card and the card account. For example, you are responsible for charges made by yaurself, your spouse and minor children. You are also responsible for charges made by anyone else to whom you give the card, and this responsibility continues until the card is recovered. You cannot disclclim responsibility by notifying us, but we will close the ,account for new transactions i1 you so request and return all cards. Vour ob!lgation (0 pay the account balance continues even though an agreement, divorce decree or other court judgment to which we are not a party may direct you or one of the other persons responsible to pay the account. 2. LOST CARD NOTIFICATION - If you believe the card has been lost or stolen, ycu will immediately call the Credit Union at (717) 234.8484 or (800) 237.7328. After hours call (800) 556-5678. 3. liABILITY FOR UNAUTHORIZED USE - You understand thaI ycur lotal liability to the Credit Union shall not exceed $50. for any card transactions resulting from the loss, theft or unauthorized use of the card that occurs prior to the time you give notice to the Credit Union. Such liability does not apply when the card is used to make electronIc fund transmrs. The Credit Union uses neural networks, which by artificial intelligence can recognize and alert us to potential fraudulent transactions. These alerts may generate inquiries about your use of the card and we apologize for any inconvenience this might cause. 4. CREDIT LINE - If we approve ycur application, we will establish a self. replenishing Une of Credit for you and notify you of its amount when we issue the card. You agree not to letthe account balance exceed this approved Credit Line. Each payment you make on the account will restore your Credit Une by the amount of the payment which is applied to the principatYou may request an increase in your Credit Line only by written appllcallon 10 us, which must be approved by our cred~ commIIIee or loan officer. By giving you written notice we may reduce your Credit Une from time to time, or with good cause, revoke your card and terminate this Agreement Good cause includes your failure to comply with this Agreement or any other agreement with us. or our adverse reevaluation of your creditWorthiness. You may also terminate this Agreement at any time, but termination by either of us does not affect your obligation to pay the account balance. The cards remain our property and you must recover and surrender to us all cards upon our request and upon termination 01 this Agreement. 5. CREDIT INFORMATION - You authortze us to investigate ycur cred~ standing when opening, renewing or reviewilig your account, and you authorize us to disclose in1ormation regarding your account to credit bureaus and other creditors who inquire of us about your credit standing. 6. MONTHLY PAYMENT - We will mail you a statement every month showing your Previous Balances of purchases and cash advances, the current transactions on your account, the remaining credit available under your Credit Une, the New Balances of purchases and cash advances, the Total New Balance, the Finance Charge due to date, and any other billed fees, and the Minimum Payment required. Every month you must pay at least the Minimum Payment within 25 days of your statement closing date. By separate agreement you may authorize us to charge the minimum payment automatically to your share or checking account with us. You may, of course, pay more frequently, pay more than the Minimum Payment, or pay the Total New Balance in full, and you will reduce the finance charge by doing so. The, minimum payment will be '(a) 2% of your Total New Balance, rounded up to the next even donar, or (b) $20.00, whichever,is greater. In addition, at any time your Total ,I New Balance exceeds your Credit Une, you must immediately pay the excess upon our demand. We will apply payments in the following marmer: 1m to previous late lees. then to previous cash advances finance charges, then to previous purchase finance charges, then to current late tees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. 7. FINANCE CHARGES -You can avoid Finance Charge on purchases by paying the full amount of the New Balance at Purchases each month within 25 days oi your statement closing date. Otherwise, the New Balance of Purchases, and the subsequent purchases from the date they are posted to your account, will be subject to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average adjusted daily balance (see explanation below), including new purchases, for the billing cycle by the monthly periodic purchase rate as disclosed on the addendum. Cash Advances: We calculate your finance charge on cash advances by multiplying the average adjusted daily balance (see explanation below) for cash advances during the billing cycle by the monthly periodic advance rate. Balance Computation Method Avslllge Daily Balance for Purchases - The Average Dally Balance for Pu.rchase Transactions Is calculated by adding the Daily Balances (Purchase Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance tor purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. 1 Then, in the sequence in which amounts are posted to your accoun1. we add the amounts of an debits and subtract the emounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the I amount of any unpaid Finance Charges ot late Charges. Then we aSso subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day in the billing cycle. This gives us the Dally Balance for purchases. Average Dalfy Balance for Cash Advances - Cash Advance Transactions whi~ are posted to your accounl are not Included in the Average Datty Balance calculation for purchases, and are therefore not subject to the monthly periodic rate for purchas~. The Average Daily Balance is calculated separately for Cash Advances and IS subject to the Cash Advance Monthly Pertodic Rate. The Average Daily BatB.!'ce for Cash Transactions is calculated by adding the Daily Balances (Cash Tra~sactlo~) .for each day in the billing cycle, and then dividing by the number of days ,n the bnl'ng cycle. To calculete the Dally Balance for cash each day, we take the following steps: We take the outstanding balance (an amounts ycu owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts 01 all debits and subtract the amounts of all credits or payments whICh post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the am?unt of arrj Purchase Transactions that posted to your account on that day or In any previous day in the billing cycfe. This gives us the Daily Balance for Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account. Payments are applied In the following manner: first 10 previous late tees, then to previous cash advances finance charges, then to previOUS purchase finance charges, then to current late fees, then to previous cash advance b~lances, then ~o previous purchase balances in the order lhel they wefe'pos\edlo your eccounl, th~n to current cash advance balances, and then to current purchase balances. Credits are applied first to the particular type of debt which is being credited, if any, and then to the balance 01' your account. - ~. - ELECTRONIC FUNDS TRANSFER, MAC AGREEMENT AND REGULA '/"ION "E" DISCLOSURE VISA- Credit Card Aareement and Truth In Landlna ,Disclosure (continued) Nots also that if the total of the payments and credits which Bre posted to your account by the Payment Due Date shown on a statement is equal to or exceeds the New Balance shown on that statement, we will not apply the Monthly Periodic Rate to your Account on your next statement. 8,. ~EFAULT - You will be in default if you fall to make any Minimum Payment within 25 dS;Ys after your monthly statement closing date,You authorize us to transfer funds sufficient to make the minimum payment due if your VISA loan is In default. You agree that we may temporarily suspend your ATM card access if your VISA payment Is due for a period exceeding 30 days. You will also be in default ft your ~billty to . repay us !S f!1Bterially reduced by a chang~ in your employment, an Increase In your obligations, bankruptcy or insolvency proceedings Involving you your death or .your fail~re to abide by this Agreement, or if the value of our securitY Interest materially d~lnes. We have the right to demandllmmediate payment of your full account balance If you default, subject to our giving 'you any notice required by law. To the. exten.t permitted by law, you will also be required to pay our collection expenses, including court costs and reasonable attorney fees. 9. USING THE CARD - To make a purchase or cash advance. there are two alternative procedures to be followed. One is for you to present the card to a partlcipating VISA plan merchant, to us or another financial Institution, and sign the sales or cash advance draft which will be imprinted wit/1 your card. The other is to complete the transaction by using your Personal Identification Number (PIN) in conj~nction with f!1e card in an Automated Teller Machine or other type of electronic terminal that provIdes access to the VISA system. You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. The monthly statement wlH identify the merchant, electronic terminal or financial institution at which tran~ctions were made, but sale, cash advance, credit or other slips cannot be returned with the statement. You will retain a copy of such slips furnished at the time of the transaction in order to verify the monthly statement. the Credit Union may make a reasonable charge for photocopies of slips you may request. 10. RETURNS AND ADJUSTMENTS - Merchants and others who honor the card may give credit for returns arid adjustments, and they Will do so by sending us a credit slip which we will post to your account. If your credit and payments exceed what you owe us, we will hold and "?ply this credit balanca agains! future purchases and cash advances, or If it is one dollar or more, refund it on your written request or automatically ~fter six months. MONEY ACCESS CARD CARDHOLDER AGREEMENt - The Undersigned (you or yDur), in consideretion of THE PENNSYLVANIA STAtE EMPLOYEES CREDIT UNION (we, our and us) issuing to you a MONEY ACOESS CARD.'tlereby agree to be legally bsund by the following terms and conditions. You agree that the use of your MAC card(s) constitutes aCGeptance of the terms and conditions of this Agreement. You understand that MAC' is a credit-related service and you authorize PSECU to obtain a credit report on any users of this account. 1. Accounts and Uses of MONEY ACCESS CARD You have the account(s) (including Checking and Regular Shares), which we set fOrth on your application form with this Agreement. You hereby request that we i6sue to you one or more MONEY ACCESS CARD(s) to be used In connection with such accounts as described In this Agreement. You understand you may use the MONEY ACCESS CARD at a MONEY ACCESS CENTER" 10 (1) whhdraw cash from, (2) make or arrange for deposits in, (3) effect transfers to or from your account, (4) reQ9ive information regarding tI1e balance in your account(s) or (5) make cash advances from your credit account(s) in the amounts you request. You may ~Iso use automated teller machines throughout the United States and in certain foreign countries which bear the PUJS SYSTEM" name and togo (1) to make withdrawals from. (2) elfact transfers to or from, (3) receive information regarding the balances In your Checldng Dr Regular shares. If you have a Personal Service Loan approved and in place, you may also make ,a cash advance ~m your PSL. You further understand you may use the MONEY ACCESS CARD to purchase goods and services ("Purchase") at any retail establishment ("Merchanr) where MONEY ACCESS CARDs are accepted by such Merchant. If you use the MONEY ACCESS CARD to make a Purchase to oblatn cash. if permitted by the Merchant, you shall be requesting us to withdraw fUli1ds in the amount of such Purchase (including any cash received from the Merchant) from your Checking Shares and directing Dr ordering us to pay such funds to the Merchant. You request that we will provide to you ,such other servipes or access to other ATM systems or networks using \he MONEY ACCESS CARD which wa may later make available and which we advise you are offered in connection with your account(s) set forth on your application form. You also understand that from time to time you may request in writing that we provide access to additional accounts of yours mrough \he MONEY ACCESS CARD we have issued to you. You agree\het the uses of the MONEY ACCESS CARD descrtbed in this Agreement shall be subject to the rules and regulations of each account which is accessed by such Card. 2. Use of Personalldentl1lcallon Number ("PIN") wtth MONEY ACCESS CARD You understand thai a MONEY ACCESS CENTER or a PLUS SYSTEM ATM is an automated teller. It can and will perform many of the same tasks as a human teller. You acknowledge that the Personal Identification Number or PIN, which you use with the MONEY ACCE~S CARD Is your, si,gnatur~, identifies the be,arer of me Card 10 1119 MONEY ACCESS CENTER, PLl!S SYSTEM ATM. or other netwo~ ATM and authenticates and validates the c;ilrectlons given just as your actual signature and other proof identify you and authenticate and validate your ~- ~""~~IIml!j,~, ,~ ~-'^ ~"'~~J ~ .., . 11. FOREIGN TRANSACTIONS "'"t"" Purchases and cash advances made in foreign countries and foreign currencies wIll be billed to you in U.S. dollars. The conversion rate to dollars will be (i) the wholesale market rate or (ii) the government.mandated ~te, whichever is applicable, in effect one day prior to the processing date, Increased by one percent. 12. PLAN MERCHANT DISPUTES - We are not responsible for the refusal of any plan merchant or financial institution to honor your card. We are subject to claims and defenses (other than tort claims) arising out of goods and services you purchase with the. card only if you have made a good faith attempt, but have been unable to obtain satisfaction from the plan merchant, and ta) your purchase was made in response to an advertisement we sent or participated In sending you, or (b) your purchase cost more than $50 and was made from a plan merchant in your state or within 100 miles of your home. Any other disputes you must resolve directly with the plan merchant. 13. SECURrry INTEREST - To sec~re your account, you grant us a purchase money secunty Interest under the Uniform Commercial Code In any goods you purchase throug~ the account. If you defauh, we will have the right to recover any of these goo~s which we have .not ~een paid for through our application of your payments m the manner descnbed m the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have If you are in defauh to prevent withdrawal of your unpledged credit union shares (Deposits) below the unpaid balance of your account. However, If you give or have given us a specilic pledge of your orad" union shares (Deposits) by signing \he Pledge ol Shares or otherwise, or any other security interests for aU your debts, your account will be secured by your pledged shares (Deposits) and by the property described in those other security agreements, except for your home. 14. EFFECT OF AGREEMENT - This Agreemenl Is the contract which applies 10 all transactions on your account even though the sales, cash advance, credit or other slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance written notice required by law. Your use of the card thereafter will Indicate your agreement to the amendments. To the extent the law permits, and we 'indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. 15. LATE PAYMENT CHARGE -If your Minimum Payment is not paid within 15 days after the PaYment Due Date, you will be subject to a single charge of 5% of the minimum scheduled payment. 16. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement. directions to a human teller. You also understar:\d that a Merchant which accepts the MONEY ACCESS CARD for a Purchase transaction may have an electronic terminal (Merchant operated or Self-Service) which requires the use of your PIN and when your PIN is used at a Merchant's terminal, it will authenticate and validate the directions given just as your actual signature will authenticate and validate your directions given to us. You acknowledge that your PIN is an identification code that is personal and confidential and that the use of the PIN with the MONEY ACCESS CARD is a security devise for your account(s). Therefore, YOU AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO ONE ELSE LEARNS YOUR PIN. 3. Liability for Unauthorized Transactions You agree to contact us at once it you beneve the MONEY ACCESS CARD(s) issued to you or PIN has been lost or stolen or money is missing from your account(s). You also agree that if your monthly statement shows transactions which you did nol mal<.a, and you do not contact us within 60 days after the statement was mailed to you, you may not get any money lost after that time. YOU AGREE THAT IFYOU GIVE YOUR MONEY ACCESS CARD(s) and PINTO SOMEONE ELSE TO USE YOU ARE AUTHORIZING THEM TO ACT ON YOUR BEHALF AND YOU WILL BE RESPONSIBLE FOR ANY USE OF THE CARD(s) BY THEM. You could lose all your money In the account(s) If you take no action to notify PSECU of the loss of your MONEY ACCESS CARD or PIN. Safeguard your Personalldentfflcatlon Number (PIN). Do not tell or disclose your PIN to any other person. Do nof write your PIN on your MONEY ACCESS CARD. Do not keep a written record of your PIN near your MONEY ACCESS CARD. Do not choose a PIN that is easily identifiable. A new card may be ordered for you at that time and a "hold" will be placed on your old card. Atter such time, if you tind your old card, destroy the old card by cutting it in half. If you attempt to use your old card, it will be captured and retained by the MONEY ACCESS CENTER, PLUS SYSTEM. or HONOR ATM. 4, Charges You agree to pay a 50 cent charge for each deposit or withdrawal exceeding 15 a month. You agree tq pay the 50 cent penalty charge on any cash disbursement transaction (loan advance or share withdrawal) that is less than $20. You agree to pay a 25 cent charge on each balance inquiry. You agree to pay the charges or transaction fees which are charged by us for these services or tor services which may later be offered as such fees or charges may be Imposed or changed from time to time. 5. Deposits You agree that when you make a depos" al a MONEY ACCESS CENTER that we have the right to verify the deposit before we make the money available to you. If you denver cash, checks .or other items to a MONEY ACCESS CENTER, you understand and acknOWledge that the funds from your deposit may 'not be available for Immediate withdrawal and that the avatlabilily of your depostt shall depend on our rules and regulations regarding the particular account in which you _~_''''''_.''illoJ_",," ~ ...~'... ~ - Electronic Funds li'ansfer. MAC Aa~ment snd Beau/stlon ,ME" Dlsc/osulYJ (cottllnut1d) are mo,king a deposit, the Items that you are depaslting and whether the deposit is made at a MONEY ACCESS CENTER that Is owned by us or another financlal insI~u\ion. You also understand and acknowledge that not all MONEY ACCESS CENTERs may accept deposits and some MONEY ACCESS CENTERs may IIm~ the amount of funds which may be deposited and we may not control these limits. 6. Uablllty If the MONEY ACCESS CARD is issued for a joint account, you agree to be joinUyand severally liable under the terms of this Agreement and the agreement for such account. You agree that if you make deposits or payments to your 8CCOWlt(s) with items other than cash {checks, drafts Qr other items) and we make funds available to you from such deposits prior to their collection, you agree that we may deduct the amounts of such funds from your account(s) which are not collected or, If the funds in your account(s) are insufficient at such time, you will promptly pay to us any amount of such funds which are not collectecl. 7. Amendment of this Agreement You agree that from time to time we may amend or change the terms of .this agreement including amendments or Changes to add further MONEY ACCESS CARD services or to amend or change Ule charges for these services. We may do so by notifying you in writing of such amendments or changes and your use of the MONEY ACCESS CARD after the effective date of any such amendment or change shall constitute your acceptance of and agreement to such amendment or change. 8, Ownership You agree that the MONEY ACCESS CARD Is our property and you wtll surrender it \0 us upon our request. You agree that the MONEY ACCESS CARD Is non-transferrable. 9. Discfosures You hereby acknowledge receipt of the disclosure statement Informing you of your rights under the Electronic Funds Transfer Act and a copy of this Agreement. REGULATION "E" DISCLOSURE 1. Summary 01 Consumer Llabtllty MAC. ACH and SST - Tell us at once jf you believe your card has been lost or stolen. Telephoning is the best way to keep your possible losses down. You could lose all the money in your account plus your maximum overdraft line of credit. If you believe your card has been lost or stolen, and you tell us within two business days atter you learn of the loss or theft, you can loss no fObre than $50 If someorle used your card without your permission, If you do not tell us within two business days after you learn of the loss or theft of your card, and we can prove we could have stopped someone from using your card without your permission if you had told us, you could lose as much as $500. Also, if your statement shows transfers that you did not make, tell us at once. If you do not tell us within 60 days after the statement was mailed to you, you may not get back any money you'lost after the 60 days If we can prove that we could have stopped someone from taking the money if you had told us in time. If a good reason such as a long trip or a hospital stay kept you from telling us, we will extend the time periods. 2. Telephone Number and Address to Notify 01 Unauthorized Transfers MAC - Contact PSECU at (800) 237.7328 or Money Access Service (MAC) at (800) 523-4175 during PSECU non-business hours, then follow up by contacting PSECU at (800) 237-7328 the next business day. ACH and SST - Contact PSECU at (800) 237-7328 (nationwide) or (717) 234-8484 (in Harrisburg). Or write to us at: Pennsylvania State Employees Credit Union P.O. Box 67013 Harrisburg, PA 17106-7013 PSECU Business Hours 7:00 a.m. - 5:00 p.m. M . F 8:00 a.m. - Noon Saturday TOD (800) 472-1967 Nationwide (717) n7-2100 in Harrisburg 3. Financial Institution's Business Days MAC ACH and SST - PSECU's Business Days are Monday through Friday, Holid~ no1. included. . 4. Types of Electronic Transfers a Consumer May Make MAC - Balance inquiries on checking, savings and PSL; withdrawals from checking/savings; cash advance from PSL; deposits to checking/savings; purch86e goods and services at any accepting retail establishment. ACH.. Preauthorized deblts and credits to checking and savings. SST .. Balance inquiries. and transaction.- histories on all sharEl, certificate and loan accounts; transfers from any share to another share or loan account from your PSl to any share or loan account; withdrawals from any, share except IRA shares or certificates. ~~--. ................--"-' J~ ~ ~ ~" ~~ .'u~""'""""""'~'~_.' ...~ 5. Any Charges for- Electronic 'Funds Transfers or for the Right to Make Transfers MAC.. Fifty cents for each disbursement (cash advance or withdrawal) less than $20; fifty cents for each transaction over 15 per month, and a 25 cent charge on each balance inquiry. ACH .. $20 seNice charge for insufficient funds for each electronic transfer. . SST.. none 6. Summary of Consumer's Right to Receive Documentation of EFT's MAC .. You are entitled to receive a printed receipt at the time of each transaction. You will receive a monthly statement showing the status of your account, any transactions made during the month, and any penalties or charges PSECU may Impose during the month. ACH and SST.. You will receive a monthly statement showing the status of your account, any transactions made during the month, and any penalties or charges PSECU may Impose during the month. If you have arranged to have a direct deposit made to your account at least once every 60 days from the same person or company, you can call us at (800) 237.. 7328 to find out whether or not the deposit has been made. 7. Stop Payment Rights.. Pre-authorlzed transfers . MAC and SST.. Not applicable. . ACH.. Right to Stop Payment and Procedures for doing so. If you have told us In advance to make regular payments out of your account, you can stop any of these peyments. Hera's how: Call us al (800) 237-7328 (Nationwtde) or (717) 234-8484 (Harrisburg) or wrtle us at Pennsylvania State Employees Cred~ Union, P.O. Box 67013, Harrisburg, PA 17106-7013,10 time for us to receive your request three business days or more before the payment Is scheduled to be made. If you call, we may also require you to put your request in wrfting and get n to us wnhln14 days alter you calt. Notice of Varying Amounts. If these regular payments may vary in amount, the person you are going to pay will tell you, 10 days before each payment, when it will be made and how much It will be. You may choose Instead to get this notice only when the payment would differ by more than a certain amount from the previous payment, or when the amount would fall outside certain limits that you set. Liability for Failure to stop Payment of PreauthorlzedTransfers. If you order : us to stop one of these payments three business days or more before the ' transfer is scheduled, and we do not do so, we will be liable for your losses or damages, unless we request and do not receive written confirmation of an oral stop payment within 14 days and the transfer takes place after 14 days, or you fail to give us proper instructions that would enable us to place the stop on the transfer. 8. Summary of the FInancial Institution's Failure to Make or Stop Certain Transfers MAC ..If PSECU fails to complete a transaction on time or in the correct amount, " when properly Instructed by you, PSECU will be liable for damages caused by our failure unless: (1) there are insufficient funds in your account to complete the transfer; (2) the funds ,In your account are uncollected; (3) the funds are ~ubject to legal process; (4) the transaction you request would exceed the funds In your accounl plus any available overdraft protection; (5) the Money Access Center, PLUS system or HONOR ATM has insufficient cash to complete the transaction; (6) your card has been reported lost or stolen and you are u~ing the report~ card; (7) PSECU has ,reason to believe that the transaction requested IS unauthorized; (8) the failure Is due to an equipment breakdown that you know about when you started the transaction at the Money Access Center, PLUS System or HONOR ATM; (9) the failure was caused by an act of God, fire. or other catastrophe, or by any other cause beyond control; (10) if you attempt to complete a transaction that, at a Money Access Center, PLUS System or HONOR ATM, or merchant terminal that is not a permissible transaction listed above: or, (11) the transaction would exceed the security limitations on the use of your Money Access Card. ACH and SST ..If PSECU falls to complete a transaction on time or in the correct amount. when properly InstNcted by you, PSECU wtll be liable for damages caused by our failure unless: (1) there are insufficient funds in your account to comple\e Ihe transfer; (2l the funds in your accounl are uncollected; (3l the funds are subject to legal process; (4) the transaction you request would exceed the funds in your account plus any available overdraft credit; (5) PSECU has reason to believe that the transaction requested Is unauthorized: (6) the failure was caused by an act of God, fire, or other catastrophe, or by another cause beyond control In any case PSECU shall be liable for actual proven damages fi the failure io make ttie ttansactton resulted from a bona fide error desp~e PSECU's procedures to avoid such errors. 9. Disclosure 10 Thfrd Parties . MAC ACH and SST .. PSECU will disclose Information about your account to third parties: (1) when ~ is necessary to complete transactions; (2) to verify the existence and standing of your account with PSECU upon request of third party: such as a credit bureau; (3) to comply with government agency or court orders, (4) In accordance with your written permission; (5) to comply with governm~nt or administrative agency summonses, subpoena~, or cc;>urt orders; (6) .on recelp~ of certification frOm a Federal ~ or department that a requeS\ lor Infonmatio~ is In compliance with the Right to Finanei'" Privacy Act of 1978; and (7) when It Is necessary to take legal action to recover shares. II .... ~ Electronic Funds Transfer.. MAC ADMBms1ff and ReDulatlon '''E" Disclosure ("""tlnued) 10. MONEY ACCESS CENTER Services MAC Only - You may use your MONEY ACCESS CARD w~h your Personal Identification Number (PIN) at MONEY ACCESS CENTERS located in Detaware Maryland, New Jersey and PennsylvanIa to conduct any of the following transactions for the accounts accessed by your MONEY ACCESS CARD. a) Determine the account balance(s) of your Checking your Regular Shares and your Personal Service Loan (PSL). 1 b) Withdraw cash from your Checking and your Regular Shares. c) Make a cash advance from your Personal Service Loan (PSL). d} Deposit currency, checks, or drafts (coins are not acceptable) for transmission to PSECU for deposit in your Checking and your Regular Shares. NOTE: There are limited locations in Maryland where deposits may be made. We wish to inform you that some MONEY ACCESS CENTERs located in these areas may only'provide access 10 your Checking, your Regular Shares, and your Personal Service Loan. Not ~II. MONEY ACCESS CENTERs may accept deposits. There may also be limits on the amount of funds which you may deposit in certain MONEY ACCESS CENTERS. 11. PLUS SYSTEM" Servloes MAC Only - You may use your MONEY ACCESS CARD with your Personal Identification Number (PIN) at any PLUS SYSTEM automated teller machine (PLUS SYSTEM ATM) located throughout the United States, Puerto Rico Canada, Great Britain and Japan to conduct any of the following transactions o~ the accounts accessed by your MONEY ACCESS CARD. a) Determine the account balance(s) of your Checking, your Regular Shares, and your Personal Service Loan (PSL). b) Withdraw cash from your Checking and your Regular Shares. c) Make a cash advance from your Personal Service Loan (PSL). NOTE: Deposits are not available through PLUS SYSTEM ATMs. These are the MONEY ACCESS CENTER services currenlly available throu9h the PLUS SYSTEM network. Other services may be offered In the future. 12. HONOR< System Services MAC Only - You may use your MONEY ACCESS CARD w~h your Personal Identification Number (PIN) al any HONOR automated teller machine (HONOR ATM) located throughout Florida and other areas where ther.e are HONOR ATMs. The following transactions may be done on the accouhts accessed by your MONEY ACCESS CARD. a) Determine the account balance(s) of your Checking, your Regular Shares, and your Personal Service Loan (PSL). b) Withdraw cash from Your Checking and your Regular Shares. c) Make a cash advance from your Personal Service Loan (PSL). NOTE: Deposits are not available through HONOR SYSTEM ATMs. These are the MONEY ACCESS CENTER services currently available through the HONOR SYSTEM network. Other services may be offered in the future. 13, Other ATM Ne\work Access MAC Only. From time to time, PSECU may make arrangements with other ATM networks to grant access to MONEY ACCESS CARDs. PSECU shall Inform you when such arrangements are made and describe the services that are available to you. Arry charges will also be described. 14. Purchase Transactions MAC Only - You may use the MONEY ACCESS CARD to purchase gOOds and services rPurchase") at any retail establishment ("Merchanf) where MONEY ACCESS CARDs are accepted by such Merchant. The amount ot all such Purchases will be deducted from your Checking. When you make a Purchase using the MONEY ACCESS CARD. you wiil be requesting PSECU to withdraw funds from your Checking in the amount af the Purchase and directing PSECU to pay these funds to such Merchant. 15, Llmltallons on the Use 01 your MONEY ACCESS CARD MAC Only. You may withdraw up to $500 per day from one or a combination of your accounts by using a MONEY ACCESS CARD provided the lunds are available at a MONEY ACCESS CENTER, PLUS SYSTEM or HONOR System ATM. In addition, you may withdraw/purchase up to $500 at point of sale locations. PSECU reserves the right to reduce this dally limit at any time. In the evenl that your daily Iim~ is less than $500, PSECU wiil advise you ot the new limitation. The day for withdrawal limIts starts at 12 midnight each day and ends at 12 midnight the next day. For security purposes, there are also certain dally limitations on the frequency of use of the MONEY ACCESS CARD. However, these limitations are not revealed for security reasons. The Pennsylvania State Employees Credit Union Is not ob\lged to maintain such limitations. You will be denied use of your MONEY ACCESS CARD if you exceed the dally withdrawaVpurchase limit, If you do not have adequate funds available in your account, do not enter the correct Personal Identification Number (PIN), or exceed the frequency of usage limitallon. The receipt provided ~y lhe MONEY ACCESS CENTER. PLUS SYSTEM, or HONOR System ATM, or Merchant terminal will notify you of the denial. There is a limit on the number of such denials permitted. Attempts to exceed the limit will resuh in machine retention of - ~ I,~ ~~II!.,,,,,~.J.w..,,,,....""'~ ',J~~' ~ ~."........."" our MONEY ACCeSS CARD. the number of attempts that result in machine retention Is not revealed for security purposes. 16. Error Resolution Procedures MAC, ACH ~nd SST .. In case of errors or questions about your transactlons: Direct I"'!ulries to PSECU at (600) 237-7326 Nationwide, TOO (600) 472-1967 Nationwide, (717) ~-210~ in Harrisburg, or write PSECU at: Pennsylvania Stale Employees Cred~ Unron, P.O. Box 67013. Harrisburg, PA 17106-7013, as soon ~ you can If you think your statement or receipt is wrong, or If you need more Information about a transaction listed on the statement or receipt. PSECU must hear from you no later than 60 days after it sent you the first statement on which the problem or error appeared. You must provide the following information: <al Your name, account number, and MONEY ACCESS CARD number (IT a MAC transa~on), or reference number (if Self-Service Telephcme Transaction); (b) DeSCribe the error or the transaction you are unsure about, and explain as clearly as you can why you believe It is an error or why you need the Information and; (c) The dollar amount of the suspected error. ' If you tell PSECU orally, you must send your complaint or question In writing within 10 business days. PSECU will tell you the results of the investigation within 10 business days for MONEY ACCESS CENTER. PLUS SYSTEM, HONOR SYSTEM, SELF-SERVICE TELEPHONE. or DIRECT DEBITICREDtT TRANSACTIONS, or 20 days lor MONEY ACCESS CENTER purchase transactions. If we need more time, however, we may take up to 45 days for MONEY ACCESS CENTER, PLUS SYSTEM, HONOR SYSTEM. SELF- SERVICE TELEPHONE, or DIRECT DEBIT/CREDIT TRANSACTtONS or 90 days for MONEY ACCESS CENTER purchase transactions. If PSECU decides to do this, it wi1l recredit your account within 10 business days for the amount you think is in error if n is a MONEY ACCESS CENTER, PLUS SYSTEM. HONOR SYSTEM, SELF-SERVICE TELEPHONE. or DIRECT DEBIT/CREDIT transact~on, or 20 business days if it is a MONEY ACCESS CENTER purchase transaction. You will have the use of the money during the time it takes to complete the Investigation. If PSECU does not receive your complaint or question in writing within 10 business days, PSECU may not recredit your account. If PSECU decides there is no error, you will be advised within three business days after the investigation is completed. You may ask for copies of the documents PSECU used in the investigation. If PSECU credits your account while Investigating, you must repay those funds if PSECU concludes no error has occurred. Notice To Consumers Using ATM's Be alert to your surroundings. If you doubt the safety of a particular location, choose another ATM. 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(.J'l -< "-J ~~ '-...J ~'t- " SHERIFF'S RETURN - REGULAR CASE NO: 2000-06326 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PA STATE EMPLOYEES CREDIT UNIO VS TORRES SANTOS A BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TORRES SANTOS A the DEFENDANT , at 0018:56 HOURS, on the 29th day of September, 2000 at 203 W MAIN STREET WALNUT BOTTOM, PA 17266 by handing to RHONDA WELLER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18,00 8,68 ,00 10,00 ,00 36.68 ~~~~c:~~~ R, Thomas Kline Sworn and Subscribed to before 10/02/2000 MET'G::: W'CKE.&F~, ' ~ I!!!tfJ IA ~ Deputy Sheriff me this 5>!=- day of (Ppr::A.. ~ ;l1T/JO A.D, q"t,~f2 ~ A~ rothonotary ,'-,-" 1 ~.. ,-," ..', , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, NO. 2000- 6326 Plaintiff v. SANTOS A, TORRES, Defendant CIVIL ACTION . LAW PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff and against Defendant, SANTOS A. TORRES, for want of ANSWER TO COMPLAINT. (X) Assess damages as follows: De bt ............-.-.-...---..-..-..-..-..-.--.--.-..-...----...---... Interest from August 17, 1999 .....-------.----.-.--.---.------. Attorney's Commission--.------..--------.-------.---.-.--.----. Filing costs.-.-.-...-.-.-.--.--....-..-..-.-...-.-..-.--.-.-.-.-..-. TOTf\JL--..--.-----.--..-.-..-.---....-.--.--.----....-.-.----.-.... $8,894.91 $ to be determined $ 1,778.98 $ 81.68 $10.755.57 plus interest (X) 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. (X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to hislher Attorney of Record. (X) Pursuant to Pa.R.C.P. 237.1, I certifYJ at written notice of the intention to file this praecipe was mailed or delivered to the party agains w 0 judgment is to be entered and to hislher Attorney of Record, if any, after the default occurre d Ie t te a prior to the date of the filing of this praecipe nd a copy of the notice is attached. DATE: Signature: 17110 NOW, YltM) . 02 , 2000, WDGMENT IS ENTERED AS ABOVE. /.5' ~ ~.~ Prothonotary/Clerk, Civil VISIOn /AL. By: Deputy Document #: 188650. J II 1iII~~I!'ll~~~'i!1liI~~;~..>Wi!M"~"','.;""t,b'li~i)Ml"";.o:;"~,^"'>1.j.'i-"'~'I,,,-,>;k:1<i'\M~Wl>li~~~~' o~"'~lIif ~-"'~/il.-1.1llo!l!lr" 0, , (") 0 0 '-O~ 0 ..,., a: ~"-l I~m 0 " < {ii:!! ,_.:0 r- 75; I ;fJt? 05" N -<Z ~a :0. ~=;o ~~o ::l!: 7==H 2:0 \....)-- 5> - ~O '~ - om .. ~ t::" <:0 -< I .. "J "~ OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Curt Long Prothonotary Telephone: (717) 240-6195 Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff: PENNSYLVANIA STATE EMPLOYEES CREDIT UNION versus Defendant: SANTOS A. TORRES Judgment No. 2000-6326 Civil CERTIFICATE OF RESIDENCE PA. R. C. P. 236 I, hereby certify that the precise residence of Plaintiff is: Pennsylvania State Employees Credit Union One Credit Union Place Harrisburg, P A 17110 AND CERTIFY TIIA T THE LAST KNOWN ADDRESS OF THE WITHIN DEFENDANT IS: Santos A. Torres 203 West Main Street Walnut Bottom, P A 17266 ve C. ourtney, Fsquire Attorney for the Plaintiff Attorney ID# 74669 Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street Harrisburg, PA 17110 l)ocument#: 18864~1 II jm'I 'J._~~"'~/Iil);~_->:I;!,,"-"",'i"'-'Uf,!.-l,.~,l~,J;Jill;illit>Jlii~Il!Mj~::""_'~'~"~ ',""c", -",,~_.", 1iW~llliIliiU. (') <::) 0 C <::) '"l1 $: :z .-; U'CO C) -,.- mfTl 0<:: (t'j-n Z:IJ , z~'" I .~,:TJ CO ':+ N "9 .'~ --<2 ,:~C) r.::C ~O ;c. -,-'t ::ll: ("5::!1 :i>g ZO Om ~ <='" ~ 0:> -< 1iIl" I. --", IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, NO, 2000-6326 Plaintiff v, SANTOS A, TORRES, Defendant CIVIL ACTION - LAW ENTRY OF APPEARANCE Please enter the Appearance of Steven C. Courtney, Esquire, as counsel for Plaintiff in the above captioned action. Respectfully Submitted, SS & ERB, P.C, By St en C, Courtney, Esquire Attorney LD. No, 74669 P.O. Box 5300 Harrisburg, P A 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dm. ;# Document #: 188419.1 ii!~~&i~~,wm:\!II..d"~"I"",.k,."d.,;~~~~~M~Iillio-' _.M , ~<,', b...~~~ ~~m~ - "II I 'i (') 0 0 C 0 .,.., s: :;e .... "Om 0 ;~s;.::: ntm Z:n >", 7S;- I -Gm OJ -~~ N :-,~'")o -......:::.. ()f~ !::;:CJ "'" :;j:.r; ;e ::J:: 6::0 ",-0 )>0 ._C") c 8m ~ t:" ~ <Xl -< . , ~ , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYL V ANIASTATE EMPLOYEES CREDIT UNION, NO. 2000-6326 Plaintiff v. SANTOS A. TORRES, Defendant CIVIL ACTION - LAW TO: Santos A. Torres 203 West Main Street Walnut Bottom, P A 17266 Date of Notice: 20 October 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN APPEARANCE PERSONALLY OR BY ATIORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITlllN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENTMA Y BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFH)RDONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717/249-3166 / By , s o . No. 74669 P,O, Box 5300 Harrisburg, P A 17110-0300 (717) 238-8187 Attorneys for Plaintiff MET. GER, WICKERS Document #: /87516.1 II :MIj~" ~'J~"'-II!lIiIiiEilI~~~~~~~Iiili'"fu','lfuC.1,,,:,,,,,j,",,,~~;iCl;_"'-""h'~,,"~<1'iiliilO:W>llliO<tiIlI~IiiI<li& .......1 - ~ ~ ~ ~ ~ ~ (") 0 0 ~ 0 -n \ Z --1 ""- ~ -oU"1 C) -,- mrn ..::: i"n~ \:) Z::lj ~ zr- I -c-tlT1 \jJ . W...'.. N :f,y r ~ ~Z S(~ ~ r-:'.~J ~'- J:> -,--1'"1 ZO ::il: B::h! ~ 0 .,0 5>c: Ofll ~ ;::- :n! <X> ~ ~. .~W ".- ~ ~~ ru '~,L IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA PENNSYL VANIA STATE EMPLOYEES CREDIT UNION, NO. 2000-6326 Plaintiff v. SANTOS A. TORRES, Defendant CIVIL ACTION - LAW TO: SANTOS A, TORRES, Defendant You are hereby notified that on '71#0, .,:;J o7&'# , the following (Graef) (Degree) (Judgment) has been entered against you in the above captioned case for vour failure to file an answer to the complaint. A Judgment in the total amount of $10.755.57. plus costs and interest herebv entered. DATE: / / /d2 /tJCl , 1:5/ ~A.zfA K_'y~ Prothonotary $ t: I hereby certify that the name and address of the proper person(s) to receive this notice is: Santos A. Torres 203 West Main Street Walnut Bottom, P A 17266 A: Santos A. Torres, Defendido/a (Defendidos/as) Por este medio se Ie esta notificando que el de del , el/la siguiente (Gft\eft) (Deerete) (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: Santos A, Torres 203 West Main Street Walnut Bottom, P A 17266 Document #: 188651.1 II "'""--li~", Godfrey & Courtney, P.C. BY: Steven C. Courtney, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 Attorney for Plaintiff (717) 540-3900 PENNSYL VANIA STATE EMPLOYEES : IN THE COURT OF COMMON PLEAS CREDIT UNION, CUMBERLAND COUNTY, PA Plaintiff vs. NO. 2000-6326 SANTOS A. TOREES, Defendant CIVIL ACTION -LAW PRAECIPE TO WITHDRA W/ENTER APPEARANCE TO THE PROTHONOTARY: Please withdraw Steven C. Courtney, Esquire of Metzger, Wickersham as counsel of record for Plaintiff in the above-referenced matter. Please enter the appearance of Steven C. Courtney, Esquire of Godfrey & Courtney, P.C. as counsel of record for the Plaintiff in the above-referenced matter. Respectfully submitted, GODFREY & COURTNEY, P.C. By: s~ Attorney ID# 74669 P.O. Box 6280 Harrisburg, PA 17112 717-540-3900 Attorney for Plaintiff o Dated: \0\ ?d.ID~ Document #: 218597.1 II ~~.'~'';''~_lii~.~,'.''''-aJ~,,,,,,,,,__.&"~~,,,_,,"-''''','1;' ,k-'~",h..:L,,,---,,,,,,,<;';*"""'I'Ullii,iM,,,,,,,",,_iaj_ilIM"""="'-''''''''___'''''~' . ~ ~= _.,"," '0' ,-- ,. , ^ ~, "~ " """"" " ,'~"~ ,,- ~.. () ~i? -0:';'; rd:' I'" ~[" ~~' ~~ i~~ ::::j -< c_ ',.~J t."':' c:> C) --I f''' 1"-.,) 'I !i i:i 'I 'I II I !I I 'I 'I I, Ij ~ .." " ->~tj -,~ I '0,0 ~~~H ":'~C) ~l\Tl ~ :0 -<.. A__;"~ r. -:::> f-v ,,-