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Home My WebLink About04-0534 PENNSYL VANIA STATE EMPLOYEES CREDIT UNION, Plaintiff l i, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLvKNiA (Jc~LL~~ NO. 0'-1- ~3'1 VS. KENNETH J. MILLER, Defendant CIVIL ACTION - LAW NOTICE TO DEFEND Pursuant 10 PA RCP No. 1018,1 You have been sued in court. ]f you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are 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. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH lNFORMA nON ABOUT HIRING A LA WYER. IF YOU CAN NOT AFFORD TO HIRE A LA WYER, THIS OFFICE MA Y BE ABLE TO PROVIDE YOU WITH lNFORMA nON ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 (717) 249.3 1 66 (800) 990-9108 Effective Septemner J, 2003 Complaint EN LA CORTE DE ALEGATOS COM UN DEL CONDADO DE CUMBERLAND, PENNSYLVANIA DIVISION CIVIL AV ISO PARA DEFENDER Conforme a PA Nlim. 1018.1 USTED HA SIDO DEMANDOIA EN LA CORTE. Sj usted desea defender conta Ja demanda puestas en las siguientes pilginas, usted tienen que tomar acci6n dentro veinte (20) dias despues que esta Demanda y A visa es servido, con entrando por escrito UIUl aparencia personalmente 0 por un abogado y archivando por escrito con la Corte sus defenses 0 objeciones a Jas demandas puestas en contra usted. Usted es advertido que si fall a de hacerlo el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda 0 por cuaJquier otro reclamo 0 alivio solicitado por Demandante. Ustedpuede perder dinero 0 propiedad 0 otros derechos importante para uSled. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SJ USTED NO TlENE UN ABOGADO, V A Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQui ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENClAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 (717) 249-3] 66 (800) 990-9108 Efectivo 1 de scpticmbre. 2003 Queja IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYL VANIA STATE EMPLOYEES CREDIT UNION Plaintiff NO. Olf - $'.3 'I (},~~L~~ VS. KENNETH J. MILLER, Defendant CIVIL ACTION - LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union., by and through its attorneys, Steven C. Courtney, Esquire and Godfrey & Courtney, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Peunsylvania State Employees Credit Union, is a financial institution authorized to conduct business in the Commonwealth of Pennsylvania with a principal place of business located at I Credit Union Place, Harrisburg, Dauphin County, Pennsylvania, . 2. Defendant, Kenneth J. Miller, is an adult individual with a last known address of218 2nd Street, Enola, Cumberland County, Pennsylvania 17025. 3. Defendant Kenneth J. Miller, and at all relevant times material hereto was, the loan co-applicant. 4. On or about March 28, 2001, Defendant signed a Motor Vehicle Installment Sale Contract (hereinafter retelTed to as "Contract"). A true and correct copy of said Contract is attached hereto, incorporated herein and marked as Exhibit "A". 5. Pursuant to the loan application marked as Exhibit "A", Defendants 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 Defendants. 7. Defendant has made various payments to the Plaintiff as repayment of the monies borrowed from Plaintiff. 8. On or about January IS, 2003 Plaintiff provided a letter to Defendant Kenneth J. Miller stating that the vehicle purchased by Defendant, a 2000 Ford F-150 Truck, serial number lFTRX18L6YNA42999, was repossessed and unless payment in full was made on the outstanding loan balance, the said vehicle would be sold at a public sale on account of the Defendant and Defendant would be still responsible for any resulting deficiency. 9. As a result of Defendant' s failure to cure the default in payment, Plaintiff sold for and on account of Defendants said 2000 F-150 Truck on or about March 20, 2003. 10. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 11. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 12. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 13. Despite Plaintiffs reasonable and repeated demands for payment, Defendant has failed, refused and continue to refuse to pay all sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. 14. As of January 5, 2004, the balance due, owing and unpaid on Defendant's loan account with Plaintiff is the sum of Thirteen Thousand One Hundred Twenty Eight and 69/100 Dollars ($13,128.69). 15. Pursuant to the terms and conditions of the extension of credit contained in the Contract, Plaintiff is entitled to receive and Defendant agreed to pay an annual interest charge at a rate of 9.990% on the principal loan balance. 16. Pursuant to the terms and conditions of the extension of credit as set forth in Exhibit "B", Defendant agreed to pay reasonable attorney's fees and all court and collection costs. 17. 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. 18. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Godfrey & Courtney, P.c. in the collection of the amounts due from Defendants incident to the within action, and Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 19. The amount of attorney's fees incurred in both matters is the sum of Two Thousand Six Hundred Twenty Five and 73/100 Dollars ($2,625.73). 20. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 21. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Kenneth J. Miller, in the amount of Thirteen Thousand One Hundred Twenty Eight and 69/100 Dollars ($13,128.69), plus interest at an annual rate of 9.990%, reasonable attorney's fees in the amount of Two Thousand Six Hundred Twenty Five and 731100 Dollars ($2,625.73), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, GODF~. & COURTNEY, P.C.. By: ~ ven C~ourmey,J2'squire 15 Forest Hills Dr. x 6280 Harrisburg, P A 17112 (717) 540-3900 I.D. # 74669 Attorney for Plaintiff Date: \\\i1- VERIFICATION I, Steven C. Courtney, Esquire, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have been furnished by my client as well as upon information which has been gathered by me and/or others acting on my behalf in this matter. I have read the Complaint and to the extent that it is based upon information which I was given by my client, it is true and correct to the,best of my knowledge, information, and belief. I hereby acknowledge that the facts set fo . the aforesaid Complaint re made subject to the penalties of 18 Pa. C.S.A. ~4904 relating to sworn falsification to authorities. Date: J)ucumen( #: 180/11/ Exhibit A 0I;(olll;I......1=="':I"" IF THiS IS A HOME EaUITY ADVANCE, niE ONLY SECURITY FOR THIS ADVANCE IS THE REAL PROPERTY (IN MOST CASES YOUR HOME) WHICH YOU GAVE AS SECURITY WHEN YOUR ACCOUNT WAS ESTASUSHED. _ IF THIS IS NOr A HOME EQUITY ADVANCE, IN ADDITION TO THE PLEDGE OF SHARES IN YOUR lOANL.1NER'" CREDIT AGREEMENT, THE FOUOWING PROPERTY SECURES THIS ADVANCE. ITEM PROPERTY MODEL 'fEAR 1.0. NUMBER TYPE VALUE ,. FORD F150 2000 lFTRX18L6YNA42999 TK 28,040.00 lOANUNII. ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT MEMBER NAME JAIME L MUNDIS KENNETH MILLER 1041 HEMLOCK LN ENOLA, PA 17025-2043 TRANSACTION tyPE 1, 0 NEW LOAN YOU HAVE PREVIOUSLY ELECTED TO HAVE THIS ADVANCE INSURED WITH THE FOLLOWING COVERAGe DAIl.Y PERIODIC RATE ANNUAL PER.. (CHANGE IN TEAMS ONLY) CENTAGE RATE .02737 9.990 % I PAYMENT 518.65 2. 3. 4. OTHER "'. ........." B\( Pennsylvania State Employees CredIt Union P.O. Box 67013 Harrisburg, PA 17106-7013 (717) 787-7328 (800) 237-7328 ~I DATE MEMBER ACCOUNT NUMBeR NOTE NUMBER 3/28/2001 0201608825 / L10 180700 PURPOSE: Dealer Purchase O OPEN.eND 2. LOAN ADVANCE O HOME 4. EQUITY ADVANCE O OTHER 3. {DESCR!BE) IJ~'IIJ:~::lI'II::l~I.'I:f"":.'l'1'm','~III:l::l:l"'41',I::l~I",,{1i1I::lII"~ CREDIT DISAB1UTY SINGLE CR~OIT UFE YES 0 NO~ VESO NOG INTEREST RATE IS I A~~AR~=~D ~;UN~ ~~ANCED Ij PREVIOUS BAlANCE ~o IVAA[jLEr 27,999.9 ,"~:""94'r 0.00 = Due DATE I PAYMENT FAEQUENCY 4127/2001 MONTHLY JOINT CREDIT LIFE VES 0 NO i:J I NEW BALANCe 27,999.94 I PROJECTeD LOAN TeRM YOU PLEOGE SHARES AND/OR DEPOSITS OF $ IN ACCOUNT NUMBER OLD ACCQUNTlLOAN NUMBeR (A) PAYOFF (PAINC. + INT.) OLD ACCQUNTJt.OAN NUMBER (8) PAYOFF (PAING. '" INT.) OLD ACCOUNTIl..OAN NUMBER I (0) PAYOFF (PRING. + INT.) I OLD ACCOUNT /LOAN NUMBER! (F) PAYOFF (PRING. + INT.) I OLD I\CCOUNTtt..OAN NUMBeR (OJ PAYOFF (PRINe. '" INT.) OLD ACCOUNTILOAN NUMBER (E) PAYOFF (PRING. + INT.) By accepting the proceeds or by using the funds advanced and deposited into your share/share draft account, you agree (1) that the property referenced above wilt secure the advance and any other advances you have now or receIve in the future under the LOANLINER~ Credit and SecurIty Agreement (the Plan) and any other amounts you owe us for any reason now or in the future in accordance with the terms of the Plan and (2) to make payments as disclosed above In accordance with the terms of the Plan. CCUNA MUTUAl-INSURANCE SOCIETY. 1980, 82, 84, 86, 89. ALL AIGHTS RESER"/ED PSECU FORM '3175 (1100) JVXXOfOO.1 037.2092.1 (1100) i/i/E#5J!ti5tt7d/ SCANNED Exhibit B PSECItP Pennsylvania State Employees Credit Union Po. Box 67013 . Ha.rrisburg, PA 17106-7013 <<Y (717) 234-8484 Harrisburg, (800) 237-7328 Nationwide the financiallinkTM Loan Disclosures ~,,, ""./.'1 ::(;?,,,:/::(,j i ,"'"'1 '\"I~" I);/ i.~ rel:/::(::(,,,::(,'i This LOANUNERCl Credit and Security Agreement, which includes the Truth in Lending Disclosures, will be referred to as the Plan. The Plan documents include this Agreement and an Addendum. You, your and borrower 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. 1. HOW THIS PLAN WORKS - This is an open-end, multi-featured credit plan. We anticipate that, from time to time, you w'ill borrow money (called "advances") 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") avaiiable under the Plan, the currElnt 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 for 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 ])mit. If you eXCeed the credit limit, you promise to repay immediately the amount which exceeds the credit limit. 3. REPAYMENT - You promise to repay aU 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 subaccount, 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 subaccount. You may repay all or part of what you owe at any time without any prepayment penalty. Even if you prepay, you wilt still be required to make the regularly scheduled payments unless we agree in writing to a change in the payment schedule. If you have ajoint share draft account, you will be responsible for paying aJl 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 access the Plan, you may be liable for the unauthorized use of your ATM/Debit card. You will not be liable for unauthorized use that occurs after you notify us, oraJJy or in writing, of the loss, theft, or possible unauthorized use. If you bel1eve your ATMlDebit card has been lost or stolen, immediately inform the Credit Union by caHing or writing U$ 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 withdrawal is from a share draft account, your liability is governed by the Regulation E disclosures you received at the time you received your ATM/Deblt card, even if the withdrawal results in an advance being made tram your overdraft subaccount. 5. FINANCE CHARGE - The doJlar amount you pay tor money borrowed is caJled a '1inance charge~ and begins on the date of each advance. A finance charge will be computed separately for each separate balance under the Plan. To compute the finance 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 bElianCe used 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. SECURITY - You pledge as security for the Plan all shares and d"ividends and, ii any, a\l deposits and interest in all joint and individual accounts you have with us now and in the future. If a specific dollar amount is pledged for an advance, we will freeze shares in that account to the extent of the outstanding baiance for the advance. Otherwise, your pledged shares may be withdrawn unless you are in default. The following paragraph applies in all states except in Ohio, Rhode Island and Massachusetts: We have a statutory lien on the shares and dividends and, if any, the deposits and interest in all individual and joint accounts you have with us and may exercise our rights under the lien to the extent permitted by state law. (We are state chartered if our name does not include the term ;'Federal Credit Union.") For all borrowers: The statutory Hen and/or your pledge will allow us to apply the funds In your account(s) to what you owe when you are in default. The statutory lien and your pledge do not apply to any Individual Retirement Account or any other account that would lose special tax treatment under Slate or federal law jf given as security. Additional security for the Plan may be required at the time of an advance. If a subaccount identifies a type of property (such as "New Cars") you must giv9 that type 01 property as security when you get an advance under that subacco:mt. A subaccount name such as "Other Secured" means you must prcvida security acceptable to us when you obtain an advance under that subaccount. Properl)' you give as securlty will secure all amounts owed under the Plan and all ot;ler loars yOIJ have with us now or in the future, except any loan secured by your prlncip21 diJ1Jedling. Property securing other loans you have with us may also secure the Plan. 7. PROPERTY INSURANCE, TAXES AND FEES - You must maint:od,l pr:)perty insurance on all property that you give as security under the Plan. You may pur~hc;:se ~ CU'JA MUTUAL GROUP, 1980, 82, 84, 86, 89, 98, 99. 2000, 01. 02, 03. ALL RIGHTS RtSEiWED IS. .. ___J.'3t. the property insurance from anyone you I!lhoose who is acceptable to the Credit Union. The amount and coverage of the property insurance must be acceptable to us. You may provide the property insurance through a policy you already have, or through a pollcy 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 whal 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 pollcy. You also promise to pay all taxes and fees (like registration fees) due on the property. 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 10 the unpaid balance of the advance and you will pay interest on those amounts at Ihe same rale 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 at 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 oi the insurance or approxima1e 1erm of the advance. B. NOTICE - jf 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 and will not satisfy any state financial responsibility or no fault laws. 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 for 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 iaw. 10. PERIODIC STATEMENT - On a regular basis you will 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 aJl. 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. (1 you give us inconsistent instructions, we can refuse to follow your instructions_ Unless our written poJicy requires an of you to sign for an advance, each of you au:horizes the other(s) to obtain advances individually and agrees to repay advances made to Ihe other(s). Any joint accountholder may terminate the Plan by giving us prior written notice. If any of you terminate the Plan, the Plan is terminated for all of you. You remain liable individua1Jy and jointly for alf advances incurred before termination. 12. FEES AND CHARGES - If you give us a security interest in certain types of property, we may charge you a filing fee to pertect 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 tees in connection with the Plan. Those fees are disclosed on the Addendum and will be added to your Joan balance unless you pay them in cash. 13. UPDATiNG CREDIT INFORMATION - You promise that you will promptly give us written notice i1 you mO\le, change your name or employment, or if any ether information you provided to us changes. Upon our request you also agree to prcvide us updated financial information. 14, DEFAULT - The following paragraph applies to barrowsrs in Idaho, Kansas, Maine and South Carolina: You will be in default if you do not ma;';e a payment of the amount required when it is due. You wili also be in default ii we believe the prospect of payment, performance, or realization on any property gl'/en as security is significantly impaired. The following paragraph applies only to borrowers in Wisconsin: You will be in default if you fail 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 mat-3,ially impairs your ability to repay what you owe or malerialiy impairs the condition, 'faJue, or protection of or our right in any property you gave as security. The following paragraph applies only to borrowers in Jawa:You will be in c5rault if you are more than 10 days late in making a payment. You will aiso be in de-i3'.Jlt i! you do not comply with the terms of Ihe Plan 2nd your failure to comply mcrl3-lally impairs any property you gave as security of your a.bility to repay whe.t you ewe under the Plan. p- i"SECG FORrvl-:t3146 mVY"';'!1,_, ('~7_~i'."').< .1:n"', 1: LOA:~ER<\ Credit and Security Credit Aqreement (continued) The foJlcwing 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 jf anyone is in default under any security agreement made in connection with an advance under the Plan. You will be in default if you die, file for bankruptcy, become insoivent, if you make any false or misleading statements in any credit application or update 01 credit information, or jf something happens we believe may substantially reduce your ability to repay what you owe. You will also be in default under the Plan if you ars in default under any other loan agreement wi1h us. 15. ACTIONS AFTER DEFAULT - The foJ/owing paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, West Virginia emd South Carolina: When you are in default and after expiration of any right you have under applicable state Jaw to cure your default, we can demand immediate payment of the entire unpaid balance under the Plan without givlng you advance notice. The following paragraph app1Jes 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 right you have to demand for payment, notice of intent to accelerate and notice of acceleration. The fol/owing paragraphs apply to bOrrowers in aI/ states except. Wisconsin and 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 a default rate is disclosed on the Addendum. If a demand for immediate payment has been made, the shares and deposits given as security for the Plan can be applied toward what you owe. We can also exercise any other rights given by law when you are in default. You agree the Credif 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 at 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 make it available to you to claim. After we have possession of the property, we can sen 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 setling 1he property will be deducted from the money received from the sale. Those costs may include the cost of storing the property, preparing)t for sale and attorney's fees 10 the extent permitted under state law or awarded under the Bankruptcy Code. The res1 of 1he sale money will be applied to what you owe under the Plan. You will also have to pay any amount that remains unpaid after the saie money has I been applied to any unpaid balance under the Plan. You agree'to pay interest on that amount at 1he same rate as the advance, or, if appHcable, at the default rate disclosed on the Addendum, until that amount has been paid. The fol/owing paragraph applies only to Wisconsin borrowers: Wher. 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 given as security. 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 prcperty, you agree to pay reasonable expenses incurred in disposing of the property. If the property is a motor vehicle, mObHe home, trailer, snowmobiie, boat or aircraft, you will also be required to pay any costs permitted by Section 422.413 of the Wisconsin Statutes. The following paragraph applies only to Louisiana borrowers: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the app!Jcable interest rates in effect unless a default rate is disclosed on the AddendUm. If a demand for immediate payment has been made, the shares and deposits given as security for 1he Plan can be applied toward what you owe. We can also exercise any other rights given by law when you are in default and our rights under any security agreements you have with us. '16. CANCELLING OR CHANGING THE PLAN - The following paragraph applies only to borrowers in Jllinois: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by laV!. Any change to the interest rate or other charges will apply to future advances. The fol/owing paragraphs apply only to borrowers in Wfscor,sfn: We can change the terms of the Plan from time to time in accordance with Section 422.4 15 of the Wisconsin Statutes. You will be notified of any change in terms. Ail increase in the daily periodic rate under a variable rate interest rate is not cO.'lsidered a I change in terms under lhe Plan. We can cancel the entire Plan or any part of the Plan at a,..,y time. You nlay (;anceJ the Plan at any time by giving us prior written notice. Your obligation ':0 pi?y the unpaid balances under the terms of the Plan continues whether you or the credit I union cancel the Plan, except to the extent that your liabiiity is limited by Section I 422.4155 of the Wisconsin Stat~tes. The following paragraph applies only to borrowers in Jowa: We CUI cnanJe the I terms of the Plan from time to time after giving you any advance notics r9quired by I law. A change that increases the rate of finance charge or other chargE, that inc,eases the amount of your payments, or that otherwise adversely ,,'fel'ts e,.:sting I 11~~ balances will apply to existing balances only if you agree to the change or you Ut the Plan after receiving notice iha~ your use 01 the Plan means you agree tr change applies to existing balances, The following paragraph applies to borrowers in all other states: We have th right to change the terms of the Plan from time to time after giving you any advanc notice required by law, Any change in the interest rate will apply to future advancet and at our discretion, and subject to any requirements of applicable law, will aJsi apply to unpaid baiances. The fo/Jowing paragraph applies to"aJl. borrowers other than Wisc:msiJ borrowers: An increase in the daily periodic rate under a variabie interest rate is no considered a change in terms under the Plan. We can cancel the entire Plan or an) part of the Plan at any time. You can cancel the Plan at any time. Your obligation tc pay the unpaid balances under the terms of the Plan continues whether you or the Credit Union cancel the Plan. 17. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay enforcing any of our rights under this Plan any number of times wHhout losing the ability to exercise our rights later. We can enforce this Plan against your heirs or legal representatives. Jf we change the terms of the Plan, you agree that this Plan will continue to protect us. 18. CONTINUED EFFECTIVENESS - If any part of this Plan is determined by a court to be unenforceable, the rest will remain in effect 19. NOTICE TO UTAH BORROWERS - This written agreement is a final expression of the agreement between you and the Credit Union, This written agreement may not be contradicted by evidence of any oral agreement. 20. 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 Advance"). 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 01 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 1he proper1y. If the value of the property declines, you promise to give us more proper1y as security If asked to do so. 21. 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. 22. OWNERSHIP OFTHE PROPERTY - You promise that you own the property or if the Advance is to buy the property, you promise you will use the Advance for that 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 wiH allow no other security interest or lien to attach to the property either by your actions or by operation of law. 23. PROTECTING THE SECURITY INTEREST -If your state issues a title lor 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 aiso promise to do whatever else we think is necessary to protect our security interest in the property. You promise to pay aU costs, including but not limited to any attorney fees, we incur in protecting our security interests and rights in the property, to the extent permitted by applicabie law. 24. USE OF PROPERTY - Until the Advance has been paid off, you promise you will; (1) Use the property carefully and keep it in good repair. (2) Obtain our written permission betore making major changes to the property or changing the address where the property is kept. (3) Inform us In writing before changing your address. (4) Anow us to inspect the property. (5) Promptly notify us if the property IS damaged, stolen or abused. (6) Not use the property for any unlawful purpose. 25. NORTH DAKOTA NOTICE TO BORROWERS PURCHASING A MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF iT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THA7 SALE. YOU MAY HAVE TO PAY THE DIFFERENCE. 26. VERMONT NOTICE 7D CO-SIGNER - YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHTTO COLL;:CT FROM YOU. 27. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to fail to return a molor vehicle that is subject to a security interest, within thirty days after you have received notice of delauIt. The notice Will be malled to the address you gave us. It is your responsibility to notify us if ~'our address changes. The maxImum penalty for unlawful faiiure to return a rilotor vehicle is one year In orison and/or a fine of $150,000. : I~~ m"l:1 {ef :u..-g~~UJ{tJ~f {I1::f;[I):J!;l'I/'I:/ ""}"1 i This l10tke contains important information about your rights and our resporlt:ibihi8S under the Fair Credit Billing Act. You are advised to read your monthly s,s'Jemenr and review it lor any error discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT, If you think your slatement is wrong, or if you need more information about a transaction on your statement. write us on a separate sheet at the address listed on your statement. You are required to notify us in writing within 60 days following the date on which we sent your statement wherein the error or probiem first appeared regarding any discrepancy or unauthorized transactions en your accaunt. Failure to notify us may result in your acceptance of any res;lOnsibiiity for payment or reimbursement to us for any such error or discrepancy on your a,:;count. Write to us as soon as possible. You can telephone us, but doing so '.'lIm not preserve your rights. In your letter, give us the following information: Your name and account number. << The doHar amount of the suspected error. * Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are not SLlre about. If you have authorized us to pay a credit card account automalicaHy from your. ~he~e account or checkIng account, you can stop the pa.yment on any amount you tnInk IS wrong. To stop the payment your lelter must reach us three business days be';'ore the automatic payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE. We must acknowledge your letter within 30 days, unless \/':e have corrected the error by then. Within 90 days, we must either correct the error or explain why we beHeve the statement was correct. ,\fter we receive your [etter, we cannet try to collect any amount you question, or repe you as delinquent. We can continue to send statements to you for the amount ye question, including finance charges, and we Ca.1 apply any unpaid amount against YOI credit limit. You do not have to pay any questioned amount while we are invesligatin! but you are stili obligated to pay the parts of your statement that are not in question. If we find that we made a mistake on your statement, you will not have to pay an finance charges related to any questioned amount. If we didn't make a mistake, yo may have to pay finance charges, and you will have to make up any misse payments on the questioned amount. In €ithE'r case, we will send you a statemer 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 delinquenl However, if our explanation does not satisfy you and you write to us within ten day~ telling us that you still refuse to pay, we must tell anyone we report you to that yOL have a question about your statement. And, we must tell you the name of anyone we reported you to. We must tel! anyone we report you to that the matter has beer settled between us when it finally is. If we don't follow these rules, we can't collect the first $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) Yaw must have made the purchase In your home state or, jf 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 Elr services. .' 1i:1 ~ I] i 1601" Y;/ "" T~:/ ~ ~M ::ij"" ,."'.I:/'i i;. Ii" .~j'/IJ/N"I I)!:fl1/(IJ..ill:1 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 Une 01 Credit account with us. We, us, and ours means this Credit Union. 1. RESPONSIBILITY -If 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 yourself, 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 disclaim responsibility by notifying us, but we will close the account for new transactions if you so request and return all cards. Your obligation to 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, you 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 agree to notify us immediately, orally or in writing of the loss, theft or unauthorized use of your Credit Card. You may be liable for the unauthorized use of your Credit Card. You will not be liable for unauthorized use that occurs after you notify us of the 10$5, theft, or possible unauthorized use. Vou will have no liability for unauthorized purchases made with your Credit Card, unless you are grossly negligent In the handling of your Card. In any case, your liability will not exceed $50. 4. CREDIT LINE - If we approve your application, we will establish a self- replenishing Line of Credit for you and notify you of its amount when we issue the card. You agree not to let the account balance exceed this approved Credit Line. Each payment you make on the account will restore your Credit Line by the amount of the payment which Is applied to the principal. You may request an increase in your Credit Line only by written appfication to us, which must be approved by our credit committee or loan officer. By giving you written not}ce we may reduce your Credit Line 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 alsG 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 reccver and . surrender to us all cards upon our request and upon termination of this Agreement. 5. CREDIT INFORMATION - You authorize us to investigate your credit standing when opening, renewing or reviewing your account, and you authorize us to disclose information regarding your account to credit bureaus and other creditors whc inquire of us about your credit standing. 6. MONTHLY PAYMENT - We will mail you a statement every month s,'lowing your Previous Balances of purchases and cash advances, the current transactions on your account, the remaining credit available under your Credit Line, the New Baler;ces of purchases and cash advances, the Total New Balance, the Finance Cha,"ge 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 dale. By Sep2ra!e 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, psy rnore than the Minimum Payment, or pay the Total New Balance in full, and you will rec~uce the finance charge by doing $0. If your monthly payment exceeds the IOtal credit iine ,Jalance owed, we will automatically post the credit to your 81 shares. The minimum payment will be (a) 2% of your Total New Balance, rot-nded up to the next even dollar, or (b) $20.00, whichever is greater. In addition, at any time yeur Totai New Balance exceeds your Credit Line, you must immediately pay the Excess u:)on our demand. We will apply payments in the foJlowing manner: first to previous !c:te fees. then to previous cash advances finance charges, then to previous purchase finance charges, then to current late fees, 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 the Finance Charge on purchases by paying the full amount of the New Balance of Purchases each month within 25 days of your st~tement 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), induding new purchases, for the billing cycle by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE 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 and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Daily Balance for Purchases. The Average Daily Balance for Purchase 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 biHing cycle. To calculate the Daily Balance for purchases each day, we take the foHowing steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, In the sequence in which amounts are posted to your account, we add the amounts of alf 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 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 Daily Balance for purchases. Average DaHy Balance for Cash Advances. Cash Advance Transactions which are posted to your account are not Included in the Average Daily Balance calculation for purchases, and are therefore no! subject to the monthly periodic rate for purchases. The Average Daily Balance is calculated separately for Cash Advances and is subject to the Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions is calculated by adding the Daily Balances (Cash 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 for cash each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of 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 amount of any Purchase Transactions that posted to your account on that day or in any previous day in the biliing cycle. This gives us the Daily Balance for Cash Advance Transactions. Note: Cash Advances are always s:.s!:>ject to finance charges and from the day they are posted to your account. Payments are applied in the following manner: first to previous late lees, then to previous cash advances finance charges, then to previous purchase finance charges, then to current late fees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted tc your account, then to current cash advance balances, and then to current purchase balances. C~edits are applied first to the particular type of debt which is being credited, if an)', and then to the balance of your account. Note also that if the total of the payments and credits which are posted to your account by the Payment Due Date shown on 8 statement is equal to or exceeds the Jlm~ VJSA~ Credit Card Agreement and Truth In Lending Disclosure (continLfec..') defenses (other than lort claims) arising out of goods and services you purchase with I the card only if you have made a good faith attempt, but have been unable :0 obtain New Balanc'e shown on that statement, we will not apply the Monthly Periodic Pale satisfaction from the plan merchant, and (a) your purchase was made in response to to your Account on your next statement. an advertisement we sent or participated in sending you, or (b) your purchase cost 8. DEFAULT - You will be in default if you fail to make any Minimum Payment I more than $50 and was made from a plan merchant in your stale or within 100 miles within 25 days after your monthly statement closing date. You authorize us to transTer of your home. Any other disputes you must resolve directly with the plan merchant. funds sufficient to make the minimum payment due if your VISA loan IS in default. 13. SECURITY INTEREST _ To secure your account, you grant us a purchase You agree that we may temporarily suspend your ATM card access if your VISA money security interest under the Uniform Commercial Code in any goods you payment is due for a period exceeding 30 days. You will also be in default if your purchase through the account. If you default, we will have the right to recover any of ability to repay us is materially reduced by a change in your employment, an these goods which we have not been p~id Jor through our application of your increase in your obligations, bankruptcy or insolvency proceedings involving you, payments in the manner described in the Monthly Payment section. With respect to your death or your failure to abide by this Agreement, or if the value of our security this account only, we will not assert any statutory right we may have if you are in interest materially declines. We have the right to demand immediate payment of your default to prevent withdrawal of your unpledged credit union shares (Deposits) full account balance if you default, subject to our giving you any notice required by below the unpaid balance of your account. However, if you give or have given us a law. To the extent permitted by law, you will also be required to pay our collection specific pledge of your credit union shares (Deposits) by signing the Pledge of expenses, including court costs and reasonable attorney fees. Shares or othernise, or any other security interests for all your debts, your account 9. USING THE CARD - To make a purchase or cash advance, there are two will be secured by your pledged shares (Deposits) and by the property described in alternative procedures to be followed. One is for you to present the card to a those other security agreements, except for your home. participating VISA plan merchant, or another financial institution, and sign the sales or 14. EFFECT OF AGREEMENT _ This Agreement is the contract which applies to cash advance draft which will be imprinted with your card. The other is to compleie the all transactions on your account even though the sales, cash advance, credit or transaction by using your Personal Identification Number (PIN) in conjunction with the other slips you sign or receive may contain different terms. We may amend the card in an Automated Teller Machine or other type of electronic terminal that provides Agreement from time to time by sending you the advance written notice required by access to the VISA system. You agree that you will not use your card for any law. Your use of the card thereafter will indicate your agreement to the amendments. transaction that is illegal under applicable federal, stale, or local law. The monthly To the extent the law permits, and we Indicate in our notice, amendments will apply statement will identify the merchant, eiectronic terminal or financial institution at which to your existing account balance as well as to future transactions. transactions were made, but saie, cash advance, credit or other slips cannot be 15. LATE PAYMENT CHARGE _ If your Minimum Payment is not paid wiihin 15 returned with the statement. You wil! retain a copy of such slips furnished at the time days after the Payment Due Date, you will be subject to a single charge of 5% of the of the transaction in order to verify the monthly statement. The Credit Union may ma!{e minimum scheduled payment. a reasonable charge for photocopies of slips you may request. 10. RETURNS AND ADJUSTMENTS _ Merchants and others who honor the card 16. RUSH FEES - You may incur additional charges for rush processing and rush delivery of cards and/or PIN mailer. may give credit for returns and adjustments, and they wiil do so by sending us a credit slip which we will post to your VISA line of credit. If your credit and payments exceed 17. DRAFT COPIES - You may incur an additional charge for transaction what you owe us, we will automatically post the excess credit balance to your Sl summary/sale draft documentation. Shares within 75 days. If the balance is one dollar or more, upon your written request, 18. COPY RECEIVED - You ackflowledge receipt of a copy of this Agreement. we will refund the credit balance to you. 19. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use your 11. FOREIGN TRANSACTIONS - Purchases and cash advances made in foreign card for any transaction that is illegal under applicable federal, state, or loca/law. . currencies will be billed to you in U.S. dollars. The conversion rate to dollars will be 20. NO USE - Inactive Visa accounts that have no purchase or cash activity may made in accordance with the operating regulations for International transactions be closed without notice to you after 1 a months of no activity. established by VISA U.S.A., Inc. 21. NEURAL NETWORK - PSECU uses neural network systems to predict and 12. PLAN MERCHANT DISPUTES - We are not responsible for the refusal of any 1 prevent unauthorized transactions. There may be occasions when a transaction is plan merchant or financial institution to honor your card. We are subject to claims and declined because it is indicative of possible fraudulent activity. ::/1f;foj,;{'J.'/{,.;i'l1'/.]:f[,;" W:!;i::/;W'!r'il':ftj;/ ::/ir,::/"i" ,.'1'6;/::tt!., ~U{'}"IIiII']I-"f1i 1('].;'/;/ ATM CARD CARDHOLDER AGREEMENT - The Undersigned (you or your), in you and authenticate and validate your directions to a human teller. You also consideration of THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION (we, understand that a Merchant which accepts the ATM CARD for a Purchase our and us) issuing to you an ATM CARD, hereby agree to be legally bound by the transaction may have an electronic terminal (Merchant operated or Self-Service) following terms and conditions. You agree that the use of your ATM card(s) which requires the use of your PIN and when your PIN is used at a Merchant's constitutes acceptance of the terms and conditions of this Agreement. You terminal, it wllJ authenticate and validate the directions given just as your actual understand that ATM is a credit-related service and you authorize PSECU to obtain signature will authenticate and validate your directions given to us. You acknowledge a credit report on any users of this account. that your PIN is an identification code that is personal and confidential and that the 1. ACCOUNTS AND USES OF ATM CARD _ You have the account(s) (including use of the PIN with the ATM CARD is a security devise for your account(s). Checking and Regular Shares), which we set forth on your application form with this The~efore, YOU AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO Agreement. You hereby request that we issue to you one or more ATM CARD(s) to ONe ELSE LEARNS YOUR PIN. be used in connection with such accounts as described in this Agreement. 3. LIABILITY FOR UNAUTHORIZED TRANSACTIONS - You agree to contact us You understand you may use the ATM CARD at a STAR SYSTEMS@ P.TM io (1) at once if you believe the ATM CARD(s) Issued to you or PIN has been lost or stolen withdraw cash from, (2) make or arrange for deposits in, (3) effect transfers to or from or money is missing from your account(s). You aiso agree that if your monthly your account, (4) receive information regarding the balance in your account(s) or (5) statement shows transactions which you did not make, and you do not contact us make cash advances from your credit account(s) in the amounts you request. You may within 60 days after the statement was mailed to you, you may not get any money also use automated teller machines throughout the United States and in certain lost after that time. YOU AGREE THAT IF YOU GIVE YOUR ATM CARD(s) and PIN foreign countries which bear the PLUS SYSTEM@name and logo (1) to make TO SOMEONE ELSE TO USE YOU ARE AUTHORIZING THEM TO ACT ON YOUR withdrawals from, (2) effect transfers to or from, (3) receive information regarding the BEHALF AND YOU WILL BE RESPO~SIBLE FOR AN':' USE OF THE ~ARD(S) ~Y balances in your Checking or Regular shares. If you have a Personal Service Loan THEM. You could lose all your money In the account(s) If you take no action to notify approved and in place, you may also make a cash advance from your PSL You brther PSE?U?f the loss of your ATM CA~D or PIN. Safeguard your Personal understand you may use the ATM CARD to purchase goods and services Identification Number (PIN). Do no! tell or dlscfose your PIN to any other person. Do ("Purchase") at any retail establishment ("Merchant") where ATM CARDs ~.re not write your PIN on your ATM CARD. Do not keep a written record of your PIN near accepted by such Merchant. If you use the ATM CARD to make a Purchase to obtain your ATM CARD. Do not choose a PIN that is easily identifiable. cash, if permitted by the Merchant, you shail be requesting us to withdraw funds in the A new card may be ordered for you at that time and a "hold" will be placed on your amount of such Purchase (inciudlng any cash received from the Merchant) from your old card. After such time, if you find your old card, destroy the old card by cutting it Checking Shares and directing or ordering us to pay such funds to the Mei.cha:~t. in half. If you attempt to use your oid card, it wil! not work. You request that we will provide to you such other services or access to other ATM 4. CHARGES _ You agree to pay a 50 cent charge for each deposit or withdrawal systems or networks using the ATM CARD which we may tater make aV2iiabie and exceeding 15 a month. You agree to pay the 50 cent penalty charge on any cash which we advise you are offered in connection with your account(s) set forth 0.1 your disbursement transaction (loan advance or share withdrawal) that is less than $20. application form. You als,? understand that from time to time you may requ2st in You agree to pay a 25 cent charge on each balance Inquiry. You may incur a charge writing that we provide access to additional accounts of yours through t'1e ATM for any adjustment that needs to be made to your account resulting from an error CARD we have issued to you. You agree that the uses of the ATM CARD des~ribed you made whiie making a deposit at an Automated Teller machine (ATM). You agree in this Agreement shall be subject to the rules and regulations of each account to pay the charges or transaction fees which are cherged by us for these services whJch is accessed by such Card. or for services which may later be offered as such fees or charges may be imposed 2. USE OF PERSONAL IDENTIFICATION NUMBER ("PIN") WITH AnA C/,RD or changed from time to time. You understand that a STAR SYSTEMS or a PLUS SYSTEM ATM is an 2uto:nated 5. DEPOSITS - You agree that when you make a deposit at a STAR SYSTEf"lS teller. It can and will perform many of the same tasks as a human te:18,'. You I ATM that we have the right to verify the deposit befo;e we make the money aV2iiable acknowledge that the Personal Identification Number or PIN which YOLi use W!~:l the to you. It you deliver cash, checks or other items to a STAR SYSTEMS ATM, you ATM CARD is your signature, identifies the bearer of the Card [0 !h3 STp.R understand and acknowledge that the funds from your deposit may noi be aV2i1ab!e SYSTEMS ATM, PLUS SYSTEM ATM, or other network ATM and autj-:;::nticatf.S and I for Immediate withdrawal and that the availability of )'our deposit shall depend on our validates the directions given just as your actual signature and other prcof iC:.o;ntify rulea and regulations regarding the particular .,:,:CCOU,1t in which you are making a ____ fJl~D Electronic Funds Transfer, ATM AClreement and Reaulation "E" Di~c!cs'.1re Ccontinuefi) deposit, the items that you are depositing and whether the deposit is made at a STAR SYSTEMS ATM that is owned by us or another financial institution. Ycu a!so understand and acknowledge that not all STAR SYSTEMS ATMS may 3.ccspt deposits and some STAR SYSTEMS ATMS may limit the amount of funds which may be deposited and that we may not control these limits. 6. LIABILITY - If the ATM CARD is issued for a joint account, you agree to be jointly and 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 account(s) with items other than cash (checks, drafts or 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 collected. 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 ATM CARD services or to amend or change the char,~es for these services. We may do so by notifying you in writing of such amendments or changes and your use of the ATM CARD after the effective date of an'! such amendment or change shall constitute your acceptance of and agre'?ment t'') such amendment or change. 8. OWNERSHIP - You agree that the ATM CARD is our property and you will surrender it to us upon our request. You agree that the ATM CARD is non- transferable. 9. DISCLOSURES - You hereby acknowledge receipt of the disclosure sta:ement informing you of your rights under the Electronic Funds Transfer Act and a copy of this Agreement. REGULATION "E" DISCLOSURE 1. ELECTRONIC CHECK CONVERSION/ELECTRONIC RETURNED CHECK FEES - If you pay for something with a check or share draft, you may authorize it to be converted to an electronic fund transfer. You may also authorize merchants to electronically debit your account for returned check fees. You are considered to have authorized these electronic funds transfers if you complete the transaction after being told (orally or by a notice posted or sent to you) that the transfer may be processed electronically or jf you sign a written authorization. 2. SUMMARY OF CONSUMER LIABILITY - . ATM, ACH and SST - Tell us at once if 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 credi:. If you believe your card has been lost or stolen, and you tel! us within two business days after you learn of the loss or theft, you can lose no more than $50 if someone 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, jf 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, yeu may not get back any money you los! 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 <..IS, we will extend the time periods. 3. TELEPHONE NUMBER AND ADDRESS TO NOTIFY OF UNAUTHORIZED TRANSFERS - ATM - Contact PSECU at (800) 237-7328 EXT 3808 (nationwide) or (717) 234*8484 (in Harrisburg). After hours, follow the menu options on PSEGU's voice mail system to report a lost or stolen card. For VISA Credit or Debit Cards, follow the directions for Lost Card Notification under the VISA Credit Card Agreement and Truth-in-Lending Disclosures section of this docJment. ACH and SST - Contact PSECU at (800) 237-7328 (nationwide) cr (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: 8:00 a.m. * 5:00 p.m. M - F TDD (800) 472-1967 Nationwide (717) 777-2100 in Harrisburg 4. FINANCIAL INSTITUTION'S BUSINESS DAYS - . ATM, ACH and SST - PSECU's Business Days are Monda.y :hiCugh Friday. Holidays not included. 5. TYPES OF ELECTRONIC TRANSFERS A CONSUMER MAY WAKE-, ATM - Balance inquiries on checking. savings and PSL; wi:hdrawals from checking/savings; cash advance from PSL; deposits to ch,xk:ng/f-2vings; purchase goods and services at any accepting retail establishment. ACH - Preauthorized debits and credits to checking and savings. SST - Balance inquiries and transaction histories on all share, cedificO".te and loan accounts; transfers from any share to another sha;e or loer: c.CCOl'iTt fran', your PSL to any share or loan account; v!ithdrawals from any share sxcept IRA shares or certificates. 6. ANY CHARGES FOR ELECTRONIC FUNDS TRANSFERS OR FOR THE RIGHTTO MAKE TRANSFERS - ATM - Fifty cents for each disbursement (cash advance or withdrawal) less than $20; fifty cents for each transaction over 15 per month; 25 cent for each balance inquiry; and there may be an additional charge for any adjustment that needs to be made to the account of any member who makes an error while depositing at an Automated T~_ller.machine (ATM). ACH - $20 service charge for insufficient 'funds for each electronic transfer. SST - none 7. SUMMARY OF CONSUMER'S RIGHT TO RECEIVE DOCUMENTATION OF EFT'S- ATM - You are entitled to receive a printed receipt at the time Of each transaction. You will receive a monthiy 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 wiil 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)'our account ai [east 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. 8. STOP PAYMENT RIGHTS - PRE-AUTHORIZED TRANSFERS - ATM 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 payments. Here's how: Call us at (800) 237-7328 (Nationwide) or (717) 234-8484 (Harrisburg) or write us at: Pennsylvania State Emp[oyees Credit Union, PO. Box 67013, Harrisburg, PA 17106-7013, in 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 writing and get it to us within 14 days after you call. 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 FaUure to Stop Payment of Preauthorized Transfers. 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. 9. SUMMARY OF THE FINANCIAL INSTITUTION'S FAILURE TO MAKE OR STOP CERTAIN TRANSFERS - ATM - 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 uncoliected; (3) the funds are subject to legal process; (4) the transaction you request would exceed the funds in your accouni plus any avallabie overdraft protection; (5) the STAR Systems, PLUS system has insufficient cash to complete the transaction; (6) your card has been reported lost or stolen and you are using the reported 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 STAR Systems, PLUS System; (9) the failure was caused by an act of God, fire, or other catastrophe, or by any other cause beyond conirol; (10) if you attempt to complete a transaction that, at a STAR Systems, PLUS System, 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 ATM CARD. ACH and SST - If PSECU fails to complete a transaciion 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 aCCOl!nt are uncollected; (3) 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 aot of God, fire, or other catastrophe, or by another cause beyond control. In any case, PSECU shall be liable only for actuai proven and not c'Jns?quential damages if the failure to mal~e the transaction resulted from a bona fide error despite PSECU's procedures to avoid such errors. 10. DISCLOSURETOTHIRD PARTIES- Electronic Funds Transfer. ArM Aareement and Reaulatio!1 "E" Disc'cs':J.L"E ({:ontinuee) orders; (4) in accordance with your written permission; (5) to comply with government or administrative agency summonses, subpoenas, or cou~t orders; (6) on receipt of certification from a Federal Agency or departm~nt that a request for information is in compliance with the Right to Financial Privacy Act of 1978; Regulation P, Privacy of Consumer Financiallnforme.tion; and (7) when it is necessary to take legal action to recover shares. 11. STAR SYSTEMS SERVICES - ATM Only - You may use your ATM CARD with your Personal Identification Number (PIN) at STAR SYSTEMs located in Delaware, Maryland, New Jersey and Pennsylvania to conduct any of the following transactions for th~ accounts accessed by your ATM 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). d) Deposit currency, checks, or drafts (coins are not acceptabie) 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 ATMs located in these areas may oniy provide access to your Checking, your Regular Shares, and your Personal Service Loan, Not all ATMs may accept deposits. There may also be limits on- the amount of funds which you may deposit in certain ATMs. 12. PLUS SYSTEM' SERVICES- . ATM Only - You may use your ATM 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 on the accounts accessed by your ATM 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 STAR SYSTEMs services currently available through the PLUS SYSTEM network, Other services may be offered in the future. 13. OTHER ATM NETWORK ACCESS- ATM Only - From time to time, PSECU may make arrangements with other ATM networks to grant access to ATM CARDs. PSECU shall inform you when such arrangements are made and describe the services that are available to you. Any charges will also be described, 14. PURCHASE TRANSACTIONS - ATM Only - You may use the ATM CARD to purchase goods and services ("Purchase") at any retail establishment ("Merchant") where ATM CARDs are accepted by such Merchant. The amount of all such Purchases wiiJ be deducted from your Checking. When you make a Purchase using the ATM CARD, you will be requesting PSECU to withdraw funds from your Checking in the amount of the Purchase and directing PSECU to pay these funds to such Merchant. 15. LIMITATIONS ONTHE USE OFYOUR ATM CARD- ATM Only - You may withdraw up to $500 per day from one or a combination of your accounts by using a ATM CARD provided the funds are available at a STAR SYSTEMs or PLUS SYSTEM ATM. In addition, you may withdraw/purchase up to $500 at point of sale locations. PSECU reserves the right to reduce this daily limit at any time. In the event that yout' daily limit is less than $500, PSECU will advise you of 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 daily limitations on the frequency of use of the ATM CARD. However, these limitations ar3 not revealed for security reasons. The Pennsylvania State Empl'Jyees Credit Union is not obliged to maintain such limitations. You will be denied use of your ATM CARD if you exceed the daily withdrawal/purchase limit, if you do not have adequate funds available ir your _~~IJm account, do not enter tile correct Personai Identification Number (PI:\", or exceed the frequency of usage limitation. The receipt provided by the STAR SYSTEMs or PLUS SYSTEM ATM or Merchant terminal will notify you 0: the deniai. There is a limit on the number of such denials permitted. Attempts to exceed the limit will result in machine retention of our ATM CARD. The number of attempts that result in machine retention is not revealed for security purpc'ses. 16. ERROR RESOLUTION PROCEDURES- ATM, ACH and SST - In case of errors or questions about your transactions: Direct inquiries to PSECU at (800) ~37-7328 Nationwide, TOO (800) 472- 1967 Nationwide, (717) n7-2100' in . Harrisburg, or write PSECU at: Pennsylvania State Employees Credit Union, P.O. Box 67013, Harrisburg, PA 17106-7013, as soon as 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 rIlust provide the foilowing information: (a) Your name, account number, and ATM CARD number (if a ATM transaction), or reference number (if Self- Service Telephone 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 compiaint or question in writing within 10 business days. PSECU will tell you the results of the investigation within 10 business days for STAR SYSTEMS, PLUS SYSTEM, , SELF- SERVICE TELEPHONE, or DIRECT DEBIT/CREDIT TRANSACTIONS. or 20 days for STAR SYSTEMS purchase transactions. If we need more time, however, we may take up to 45 days for STAR SYSTEMS, PLUS SYSTEM, SELF.SERVICE TELEPHONE, or DIRECT DEBIT/CREDIT TRANSACTIONS or 90 days for STAR SYSTEMS purchase transactions. If PSECU decides to do this, it will recredit your account within 10 business days for the amount you think is in error if it is a STAR SYSTEMS, PLUS SYSTEM, SELF-SERVICE TELEPHONE, or DIRECT DEBIT/CREDIT transaction, or 20 business days if it is a STAR SYSTEMS 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 jf PSECU concludes no error has occurred. 17. ATM SURCHARGE -If you use an ATM that is not operated by us, you may be charged a fee by the ATM operator and by any national, regional or local network used in processing the transaction (and you may be charged a fee for a balance inquiry even jf you do not complete a fund transfer). The ATM surcharge will be debited from your account if you elect to complete the transaction, Notice To Consumers Using ATM's Be alert to your surroundings. If you doubt the safety of a particular loc3tion, choose another ATM. If the ATM has an entry door, close the door prior to initiating your transaction. Put your cash away immediately. Direct complaints concerning ATM security to an appropriate department of the owner of the ATM. New Jersey residents: you may call the New Jersey Department of Banking at (609) 292-7272. 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(J ~ 'ir/} -l:: 0 ~?! ~~ ~"--!.. g ~ r- ~ ~ 0.:..- C-....=J .J...- _~ ~1 C1.:n G rl. !T'r- c;:;; -ors , :r~ ~l m (- ~ ~~) CI') ~--i --'", - '\- J :""1: 111 .~ O..~ ';~ .;.- ( ~n w =< ~ UI SHERIFF'S RETURN - REGULAR CASE NO: 2004-00534 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS MILLER KENNETH J VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MILLER KENNETH J was served upon the , at 1517:00 HOURS, on the 6th day of February, 2004 DEFENDANT at 218 2ND STREET ENOLA, PA 17025 CHERYL MILLER, WIFE by handing to 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 Aff idavi t Surcharge 18.00 11.04 .00 10.00 .00 39.04 Sworn and Subscribed to before me this 1.3~ day of ;J~ ;2(1[)'( A.D. g~flt~'~' So Answers: '~~""'''':t ",.~ ; "/".~ R. Thomas Kline 02/09/2004 GODFREY & COURTNEY By: jf4p!t:~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Plaintiff NO. 2004 - 00534 vs. KENNETH J, MILLER, Defendant CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff and against Defendant, Kenneth Miller, for want of ANSWER TO COMPLAINT. (X) Assess damages as follows: Debt m________m_mnm__n____m_________mnm__m___mm$ 13,128.69 Attorney's Commission-----m---m-nnmmm-m----m--- $ 2,625.73 Interest _________mm_______nmm_n_____mm________mm____ $ to be determined Filing costs____mm___n__m______n___m__m______mmnm_ $ to be determined TOT ALn__n___mmm______m___m_nn___mm_______m____ $ 15,754.42 plus costs (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 certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at ast ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE ~~ ~ Signature: Ste C. Courtney. squire Attorney for Plaintiff P.O. Box 6280, Harrisburg, PA (717) 540-3900 lD#: 74669 17112 NOW, ~J_c2:.l , 2004, JUDG~NT IS ENTE~D ;}& ABOVE. l.(.A./Vl<<) ~ ,-x.. u~ Prothonotar) /0' I:, Civil DiviIJon } .,: , ,,-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYL VANIA STATE EMPLOYEES CREDIT UNION Plaintiff NO. 2004 - 00534 vs. KENNETH J. MILLER, Defendant CIVIL ACTION - LAW TO: Kenneth Miller 218 2nd Street Enola, P A 17025 DATE OF NOTICE: February 28,2004 IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (1 0) DA YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MA Y BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LA WYER AT ONCE. IF YOU DO NOT HA VE A LA WYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Assoc. 2 Liberty A venue Carlisle"P A 17013 717.24Q.3166 By: Steven :, ourtney, Esquire GODF EY & COURTNEY P.O. Bo~ 6280 Harrisburg. Pennsylvania 17110 Telephone: 717.540.3900 J.D. # 74669 Attorncv for Plaintitl OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Curt Long Prothonotary Telephone: (717) 240-6100 Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff: PENNSYLVANIA STATE EMPLOYEES CREDIT UNION versus Defendant: Kenneth Miller Judgment No. 2004-00534 CERTIFICATE OF RESIDENCE PA. R. C. P. 236 1, hereby certify that the precise residence of Plaintiff is: Pennsylvania State Employees Credit Union I Credit Union Place Harrisburg, P A 17110 and certify that the last known address of the within defendant is: Kenneth Miller 218 2nd Street Enola, P A 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (/ PENNSYL VANIA STATE EMPLOYEES CREDIT UNION Plaintiff NO. 2004 - 00534 vs. KENNETH J. MILLER, Defendant CIVIL ACTION - LAW TO: Kenneth Miller, Defendant You are hereby notified that on 3 .- J), -61, the following (Gffier) (Degree) (Judgment) has been entered against you in the above captioned case for your failure to file an answer to the ::;~:i~tot~~::~+$15,754.42 P1c=tere12 j~ Prothonotary U ;~ I hereby certify that the name and address of the proper person(s) to receive this notice is: Kenneth Miller 218 2nd Street Enola, P A 17025 To: Kenneth Miller, Defendido/a (Defendidos/as) Par este medio se Ie esta notificando que EI de Del , El/la siguiente (Green) (Deereto) (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: Kenneth Miller 218 2nd Street Enola, P A 17025 \">0.~ ~:;:0 9"" ~ ~ Fe,?' 1 it 1 c-S\ r 6 0J \ \'- I:-' \ c> ~. '-, 1"-'__) ~~ -;-) ....1.--- ~~'"J . -.,- r<: . . . ...., PENNSYL VANIA ST ATE EMPLOYEES : IN THE COURT OF COMMON PLEAS CREDIT UNION, : QL':(nbe~iQ()d COUNTY, PA Plaintiff VS. : NO. QCDLi- C:f:)~3J ~{llMh cJ. lildkRj Defendant CIVIL ACTION -LAW PRAECIPE TO WITHDRA W/ENTER APPEARANCE TO THE PROTHONOTARY: Please withdraw Steven C. Courtney, Esquire of the Law Offices of Steven C. Courtney, P.c. as counsel of record for Plaintiff in the above-referenced matter. Please enter the appearance of Melissa L. Van Eck, Esquire of Van Eck & Van Eck, P.c. as counsel of record for the Plaintiff in the above-referenced matter. Respectfully submitted, '"-- By: Steven C. Courtn Attorney ID #74669 P.O. Box 6280 Harrisburg, PA 17112 717-540-3900 By: (j)(' y l ftl JhiJ!l / . UIL f ~ Melissa L. VanEck, Esquire Attorney ID #85869 P.O. Box 6662 Harrisburg, P A 17112 717-540-5406 Attorney for Plaintiff Date: Document #: 218597.1 ~-"':! ;",1 I r" -'