HomeMy WebLinkAbout08-4695IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
VS.
JANINE M GROVE
Defendant
. NO. 0$-405 -vi.l terms
: CIVIL ACTION -LAW
NOTICE TO DEFEND
Pursuant to PA RCP No. 1018.1
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 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 INFORMATION ABOUT HIRING A LAWYER.
IF YOU CAN NOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
Document #: 180057.1
EN LA CORTE DE ALEGATOS COM UN DEL CONDADO DE CUMBERLAND,
PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES NO.
CREDIT UNION,
Plaintiff
VS.
JANINE M GROVE
Defendant CIVIL ACTION -LAW
AV I S O PARA DEFENDER
Conforme a PA Num. 1018.1
USTED HA SIDO DEMANDO/A EN LA CORTE. Si usted desea defender conta la
demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias
despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia
personalmente o por un abogado y archivando por escrito con la Corte sus defenses o objeciones
a las demandas puestas en contra usted. Usted es advertido que si falla de hacerlo el caso puede
proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mds aviso
por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado
por Demandante. Ustedpuede perder dinero o propiedad o otros derechos importante para usted.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED
NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA
AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACI6N DE COMO
CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE
PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER
SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O
GRATIS.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
Document #: 180057.1
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
VS.
JANINE M GROVE
Defendant
NO. Of- yG 9S C?? 7;-
CIVIL ACTION -LAW
COMPLAINT
AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and
through its attorneys, Van Eck & Van Eck, P.C. and states the following cause of action and in
support thereof, avers as follows:
1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution
qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place
of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania.
2. Defendant, Janine M Grove, is an adult individual with a last known address of 29
Maple Ave., Camp Hill, PA 17011-4119.
3. Defendant is, and at all relevant time material hereto has been, the primary loan
applicant.
4. Defendant applied to Plaintiff for a Visa loan.
5. The application submitted by Defendant was approved by Plaintiff.
6. Pursuant to the Loan Activation Notice, 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 Loan Activation is attached
hereto, incorporated herein and marked as Exhibit "A". A true and correct copy of the Loanliner
Document #: 180057.1
Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit
"B"
8. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms
and conditions of the Contract marked as Exhibit "B".
9. Various charges and payments were made by Defendant on the account.
10. Defendant has defaulted on the loan by failing to make timely and regular
payments.
11. The last payment made by Defendant was on June 25, 2007.
12. Defendant is required under the contract to make regular and timely payments.
13. Plaintiff has maintained a statement of account keeping an accurate and running
amount of debits and credits made on Defendant's account.
14. Plaintiff has submitted to Defendant a copy of the statement of account accurately
showing all debits and credits for transactions with Defendant.
15. Defendant has not objected to any of the monthly statements of account submitted
by Plaintiff to Defendant.
16. Despite Plaintiff's 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.
17. As of July 31, 2008, the balance due, owing and unpaid on Defendant's loan
account with Plaintiff is the sum of Thirteen Thousand Seven Hundred Fifty Dollars and 47/100
($13,750.47).
Document #: 180057.1
18. 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 on
the principal loan balance.
19. Due to the default of the Defendant and pursuant to the terms and conditions of
the Contract attached as Exhibit "B", Plaintiff is entitled to be reimbursed for all costs and
expenses, including reasonable attorney's fees incurred in bringing any action.
20. For purposes of this action, Plaintiff believes, and therefore avers, that One
Thousand Four Hundred Twenty-Five Dollars and 00/100 ($1,425.00) constitutes reasonable
attorney's fees. However, Plaintiff recognizes that it is restricted by law to those attorneys' fee
that are actually incurred. If those fees are less than the aforegoing amount, Plaintiff agrees to
adjust its demand for attorneys' fees, if applicable, at the time of payment on any judgment is
made.
21. Any and all conditions precedent to the bringing of this action has been performed
by Plaintiff.
22. The amount in controversy is within the jurisdictional amount requiring
compulsory arbitration.
Document #: 180057.1
WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully
requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant,
Janine M Grove, in the amount of Fifteen Thousand One Hundred Seventy-Five Dollars and
47/100 ($15,175.47), plus interest, the costs of this action, and such other relief as the Court
deems just and proper.
Respectfully submitted,
VAN ECK & VAN ECK, P.C.
By.
Melissa L. Van Eck, Esquire
Attorney I.D. No. 85869
P.O. Box 6662
Harrisburg, PA 17112
717.540.5406
Document #: 180057.1
VERIFICATION
I, Gregory R. Diffenderfer, Manager of the Pennsylvania State Employees Credit Union
verify that the statements made in the aforegoing document are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to
unsworn falsification to authorities.
Pennsylvania State Employees Credit Union
By: < <
Title: 0's fl/1A A L6 ?
Date: 7 1 t i OR
i
y(yv
l.AA?n1-1
PERSONAL SERVICE LOAN AND Visa® ACTIVATION NOTICE W"11 rw i 4U1
Loan Information January 17, 2006 Ref #: 510221598
Approval Amount: $14,000.00 Account # : 0893
Applicant: JANINE M GROVE Home Telephone # • Work Telephone #
I acknowledge receipt of the PSECU LOANLINER® Disclosure and Credit Agreement and agree to be
bound by the terms set forth in said agreement.
T
24A&ad:;e 't J ?'I
&- tune of JANINE M GROV ?v v We
Personal Service Loan Options
• I would like an immediate Personal Service Loan advance of $ . Purpose:
Send a ? Check or ? Deposit to my Share 4
9 Select your Personal Service Loan repayment option.
l :t Automatic Transfer from PSECU account ? Homebanking ? Payroll deduction
? Direct Payment from another financial institution ? Self Service Telephone
• For overdraft options, complete the enclosed Overdraft Transfer Service sheet and return it with your Activation Notice.
Visa® Options
• I would like an immediate Visa® advance of $ . Purpose:
Send a ? Check, or ? Deposit to my Share 4
• Select your Visa® loan repayment option.
? Transfer on Pay Day (select one): ? Minimum amount ? Alternate payment amount of $
? Transfer automatically from PSECU account on the 25th of each month (select one):
? Minimum amount ? Alternate payment amount of $ ? Previous month's balance
? Mail a payment monthly by the 25th.
For overdraft options, complete the enclosed Overdraft Transfer Service sheet and return it with your Activation Notice.
• You may have one additional card issued on your Visa® account. Indicate your choice below:
1.0
? %,= issGAn additional card in the name below. I authorize him/her to use It and I accept full responsibility for all charges and(o; cash advances just as
j1hough I nimde them Authorized card holders may not order replacement cards or obtain Visa® account information (i.e. detailed transactions, balance
intmatt m payment activity). JAMIE M GROVE must sign below.
0-
10 ') LU `1 -?o
C_ are of rizcd Card Holder Signature of JANINE M GROVE
• Sel
ELyour,?grsonal Identification Number for your Visa® card
Selgtl PIN Q is not easily identified with you, and write your PIN in the spaces provided. PSECU does not keep your PIN on file. We cannot produce a card
without a PIN. You will need this PIN to make cash advances on your Visa line of credit. Please do not use the letters Q or Z as part of your PIN, and do not use
the following combinations of numbers: 0000 through 0009 or 9999.
Exhibit "B"
PSE Pennsylvania State Employees Credit Union
P.O. Box 67x 13 0 Harrisburg, P4 17109-7013 ? (717) 234-9484 Harrisburg, (800) 237.7323 Nationwide
the financial !inks
Loan Disclosures
This LOANLINER0 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
onion transfers its rights under the Plan.
NOW THIS PLAN WORKS - This is an open-end, mull-featured credit plan. We
anticipate that, from time to line, you will borrow money (called *advances*) under
the Plan. We are not required to snake advances to you under the Plan and can
refuse a request for an advance at arty time. The Addendum describes the
different types of credit (called'subaccounts") available under the Plan, the current
interest rata 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.
CREW LIMIT - We may, but do not have to, establish a credit fini t on certain
subaccounts. if a credit Omit is set for a subaccount, you promise not to exceed the
established creel n PrmIL It you exceed the credit limit, you promise to repay
immediately the amount which exceeds the credit "t.
REPAYMENT - You promise to repay an amounts you owe under the Plan plus
ate dux artsfssty of-the month unless we set a dltterwnt day
at the time of an advance, if the Addendum has no payment schedule for a
subaccount, your payment "I be deterilned at the lime 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 One without any prepayment penatty. Even if you
prepay, you will $91 be required to make the regularly scheduled payments unless
we agree in writing to a change in the payment schedule. it you have a joint
sharedrall account, you will be responsible for paying all overdraft advances
obtained by a joint holder of the sharedraft account. Unless otherwise required by
law, payments win be applied to amounts owed under the Plan, in the manner the
Credit Urdw chooses.
PLAN ACCESS --Ybu cart obtain credit advances in any manner authorized by us. If
we allow you to use your ATMiOebit card to access the Plan, you may be liable or the
unauthorized use of your ATMlOebit card. You will not be cable for unauthorized use
that ocacure after you notly us, orally or in writing, of the loss, theft, or possible
unauthorlized use. If you believe you ATMIDetA card has been lest or stolen,
Immediately irdorm the Cm* Union by calling or writing a at the telephone number or
address than appears elsewhere in the Plan. It the card to used to obtain unauthorized
advances di redly from the Plan, your liability win not exceed $50. If the unauthorized
withdrawal is hom a shamdraft account, your liability is governed by the Regulation E
disdosures you received at to tnrte you recelred your ATMtDeW card, avert if the
withdrawal results in an advance being made from your overdraft subaccount.
FINANCE CHARGE - The dollar amount you pay for money borrowed is called a
'Yknance charW and begins on ft date of each advance. A finance charge win be
computed separatey, tar each separate balerce under the Plan. To compute the
finance charge. the unpaid balance for each day shm yarn 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 anKxmts is the finance charge owed. The balance
used to compute the finance charge is the unpaid balance each day after payments
and cmc to to that balance have been subtracted and any additions to the balance
have been roads. In addition to interest. we may charge other finance charges which
are dosed on the Addendum. If the interest We is, a variable interest rate, the
-Addendum theverlebte interest rate works.
SECURITY - You pledge as security for the Plan all shares and dividends and, it
any, all deposits and interest in an 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 balance for the
advance. Otherwise, your pledged shares may be withdrawn unless you are in
delaulf. The fnllmling paragraph applies In an states except in Ohio, Rhode
Island and Mum achueetts: We have a statutory non on the shares and dividends
and. If any, the deposits and Interest in all i chvidual and joint accounts you have with
us and may woe" our rights under the ten to the extent permitted by state law.
(We are state chartered if our name does not include the term "Federal Credit
Union!) Far all borrowers: The statutory Ilan and/or your pledge wits allow us
to apply the funds In your account(s) to what you owe when you are In default.
The statutory Pen and your pledge do not apply to any Individual Retirement
mount or any other account that would lose special tax treatment under state or
federal law if 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 give that
We of property as security when you get an advance under that subac count. A
subacoount name such as 'Otfter Secured' means you must provide security
acceptable to us wtoen you obtain an advance under that subaecounnt. Property you
give as security will secure all amounts owed under the Plan and all other loans you
have with us now or b the future, except any ban secured by your principal dwelling. .
Property securing other loans you have with us may also secure the Plan.
CREDIT INSURANCE - Credit life andior 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
O cUVU MUTUA GRWP 19atr, at, K N, e9, ta: cll. zoaa. 01, V. o3. w, 05, uE aisHrs RESEPWO
Interest on the entire balance, If you elect credit insurance, your payments may
increase or the period of lime necessary to repay your advance may be extended,
The credit insurance rates may orange during the Plan. It the rates change, we will
provide any notices required by applicable taw.
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 rent address you have
given us in writing. Unless applicable taw requires notice to each joint borrower,
notice to any one of you will be notice to all.
JOINT ACCOUNTS - it 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 Plant against any one of you individually or against all of you together. ff you
give Ue 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). Any )oittt aarounthoider may terminate the Plan by giving us prior written
notice. It any of you terminate the Plan, the Plan is terminated for all of you. You
remain liable Individually and jointly for all advances incurred beore termination.
FEW AND CHARGES - it you give is a security interest in certain typos of
property, we may charge you a filing fee to perfect our interest in the property. If we
do, the amount of the fee win be disclosed to you at the time you obtain an advance.
We may also charge you other fees in connection with the Plan. Our current fees are
disGOsed on the Addendum and will be added to your loan balance unless you pay
thorn in cash.
UPDATING CREDIT INFORMATION - You promise that you will promptly give us
written notice if you move, change your name or employment, or it any other
Information you provided to us changes. Upon our request, you also agree to
provide us updated financial Information.
DEFAULT - The following paragraph applies to borrowers in Idaho, Kansas,
Alarms and South Carolina, You will be in default it you do not make a payment of
the amount required when it is due. You win also be in default it we believe the
prospect of payment, performance, or realization on any property given as security
is significantly impaired.
The t~ng Paragraph applies only to borrowers in Wisconsin: You will be in
default ti you fail to make a payment when due two times curing any 17 month
period. You will be In default if breaking any promise made under the Plan materially
impairs your ability to repay what you owe or materially impairs the condition, value,
or protection of or our right in any property you gave as security.
The Wowft paragraph applies only to borrowers In lows: You win be in
default if you are more than 10 days late in making a payment. You win also be in
default if you do not comply with the terms of the Plan and your failure to comply
materially Impairs any property you gave as security or your ability to repay what you
owe under the Plan.
"a AaNowing paragrap applies to borromrs In all other states, You will be in
default d you do not make a payment of the artwunt required when it is due. You win
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 connection v ft an advance railer
the Plan. You win be in default if you die, file for bankruptcy, become insolvent, it you
make any false or misleading statements in any credit application or update of credit
Information. or If something happens we believe may substantially reduce your
ability to repay what you owe. You will be in default if any property you have given
us as security is repossessed by someone else. seized under a forfelaxe or similar
Iaw. or if anything else happens that significantly affects the value of the property or
our security interest in ILYou will also be in default under the Plan If you are in default
under any other ban agreement with us.
ACTIONS AFTER DEFAULT- The loiiowirig paragraph applies to borrow" in
CoJOiado, Disbk of Cofumbla, Iowa, Kansas, Afalne, Afesswburefts, Aftsaour4
Nisbraskk South Caroilns and West frkgkd& When you are in default and after
expiration of any right you have under applicable state taw to cure you default, we can
demand immediate payment of the entire unpaid balance under the Plan without
giving you advance notice,
The kiloa ft pwWAph appllrs to borrowsm in all oftrsr stsfes except Mscorisin
and LouisJans. When you are in default, we can require Immediate paymwit
(acceleration) of the entire unpaid balance under the Plan. You waste any right you have
to demand for payment, notice of intent to accelerate and notice of abcelwatiom
The WOWkV paragnsphs apply fo borrowers in all states except tNMwonsln and
Loulslana: If Immediate payment is demanded, you will continua to pay interest until
what you owe has been repaid at the applicable interest rates in sited or, if applicable,
at the default rate disclosed on the Addendum. It a demand for immediate payment
has been made, your shares andror deposits can be applied towards what you owe
as provided in the section above called `Security." We can also exercise any other
rights gwn by law when you are in default.
You agree the Credit Union has the right to take possession of any property given
as security under the Plan, without iudicial process, if this can be done without I
breach of the peace. If we ask, you promise to deliver the property at a time and
!
place we choose, if the property is a motor vehicle or boat, you agree that we may
CPS1491 PSECU FORM 103146
LOANLiNEW Credit and Security Credit Agreement (continued)
obtain a key or other device necessary to unlock and operate it, when you are in
j default. We will not be respon", to for any other property, not covered by this
j 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 for 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 9.we you notice of any public disposition or the date after
which a private disposition well be held. Our expenses for taking possession of and
sonirig the property will be deducted from the money received from the sale. Those
costs may include the cost of storing the property. preparing it for sale and attorney's
fees to the extent permitted under state law or awarded under the Bankruptcy Code.
You must pay any amount that remains unpaid after the sale money has been applied
to any unpaid balance under the Plan. You agree to pay interest on that amount at the
same rate as the advance. or, it applicable. at the default rate disclosed on the
Adde:rdum, until that amount has been paid.
The following paragraph applies only to Wisconsin borrowers: When you are in
default and after expiation of any right you have under applicable state law to cure your
default, we may require immetfiste payment of your outstanding ban balance under the
Plan and seek possession of prop" given as security. You may voruntar ly give the
property to us N you choose, or we may seek to take possession of the property by
A ddldal process, if we repossess the property, you agree to pay reasonable expenses
incurred in disposing of the property. It the property Is a motor vehicle, mobile home,
trailer. snowmobfb, boat or amcxaft, you will also be required to pay any costs permitted
by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains
unpaid after the sale money has been applied to what you owe under the Plan. You
agree to pay Interest on at the debuk any disclosed unpold amount at the sarne rate as the on th Addendum, until that Isamounf poi, if
applicable.
11 the property is located outside Wisconsin at the time of default, we may take
possession of the property without }tt kiaf process, if permitted by the state where
the property Is Iodated.
Trig following par iigirA le applies ortNy to Louisfens borrowers: When you are in
detaut. we can require irimediate payment (acceleration) of the entire unpaid
i 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 wil 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 this
Addendum. If a demand for Immediate payment has been made, the shares and
deposits given as security for the Plan can be applied towards what you owe. We
can aft* examse any other rights Oven by law when you are in default and our
rights under any security agreements you have with us.
CANCELLING OR CHANOL40 THE PLAN - The following par WVh applies
only to bornwmv in A%wil is We have the right to change the terms of the Plan from
time to time after giving you any advance notice required by law. Arry change to the
interest rate or other charges will apply to future advances.
The tbAowUng paragraph appliar only to borrouvars In Wisconsin. We can
change the terms of the Plan from lima to time in accordance with Section 422,415
of the Wisconsin Statutes. Ybu wdl be notified of any change in terms, An Increase
In the dd% periodic rate under a variable rate interest rate is not considered a
change in terns trader the Plan. We can cancel the entire Plan or any part of the
Plan at any time. Nbu may cancel the Plan at any time by giving us prior written
notice. Your obligation to pay the unpaid balances under the terms of the Plan
contknuss wfietf ter you or the cruill: union cancel the Plan, except to the extent that
your kabithy is limited by Section 422.4155 of rte Wisconsin Statutes.
TTte *Wo"V paagnrph appHss only to bonowers in lows: We can change the
tames of the Plan from lime 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 affects existing
balances will apply to axisting balanoes only If you Was, to the change or you use
true Plan after receiving notice that your use of the Plan means you agree the
change applies to existing balances.
Tyra perayrnph a WM* to borrowers In ail oVw states: We have the
right to change the terms of the Plan from time to time after giving 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 belances.
The fallowing perograph appdtea to all but N9aconsin borrowers; An increase in
the daily portodtc rate under a variable interest rate is not considered a change in
tam under the Plan. We can cancel the entire Plan or any part of the Plan at any I
time. You may cancel the Plan at any tine by giving us prior written not". Your I
obligation to pay the unpaid balances under the tarns of the Plan continues whether
you or the Credit Union cancel the Plan.
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay
erhiorcing any of our rights under this Plan any number of times without toning the
ability to exercise our rights later. We can enforce this Plan against your heirs or
legal representatives. H we change the terms of the Plan, you agree that this Plan
Will dxxhtii ill to protect us.
CONTINUED EFFECTTVENESS - H any part of this Plan is determined by a court
to be unenforceable. the rest will remain in effect.
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,
The toliewinp is rsq#W by Vedmaal law - NOTICE TO 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 LENOER HAS A LEGAL RIGHT TO COLLECT FROM YOU.
j The following paragraphs apply If you give security In connection with an
advance under the Plan. They apply to borrowers in all states except Louisiana.
Louisiana borrowers will execute a separate security agreement. Borrowers in
other states may also be asked to execute a separate security agreement.
THE SECURITY FOR THE PLAN - You give us what is known as a seourity
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 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. It the value of the property
declines, you promise to give us more property as security if asked to do so.
WHATTHE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS
-The security interest secures the Advance described in the receipt, voucher or any
other document you recalve at the time of the Advance and any extensions, renewals
or refinancings of the Advance. it also secures any otter 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.
OWNERSHIP OF THE PROPERTY - You promise that you awn all property you
give as security or I the Advance Is to buy the property, you promise you win use
the Advance for that purpose. You promise that no one else has any ingest in or
claim against the property that you have tot already told us about You promise not
to SON or tease the property or to use it as security for a ban with another creditor
until the Advance Is repaid. You promise you will allow no other security interest or
ften to aitadt to the. property either by your actions or by operation of law.
PROPERTY INSURANCE, TAXES AND FEES - You must maintain property
Instance on all property that you give as security under the Plan. 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 nest be acceptable to
us. Yqu may provide the property insurance through a policy you already have, or
through a policy you deliver ? ver and pay for. the icy or proof coverage to us it asked to do s
payable to us and o.
If you cancel your insurance and yet a refund, we he" a right to the refund. If the
property Is last or damaged, we can use hie insurance settlement to repair the
property or apply ft towards what you dime. You authorize us to endorse any draft or
check which may be payable to you in order for us to coiled any refund or benefits
due under your insurance policy. You also promise to pay at taxes and fees (like
registration fees) due on the property.
If you do not pay the taros 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 baler" of the advance and you wil pay
interest on dose amounts at the same rate you agreed to pay on the advance. We may
receive payments in connection with the instance from a company which provides the
Insurance. We may monitor our loans for the purpose of datannkring whether you and
otter borrowers have compiled with the insurance requirements of our ban agreements
or may engage otters to do so. The insurance charge added to an advance may Include
(1) the insurance compartys payments to us and (2) the cost of determining compliance
with the Insurance requirements. It we add amounts for taxes, fees or insurance to this
unpaid balance of an we may increase your paytr eM to pay the amount
added within the terra oI rernce or approximate tern of the advance.
INSURANCE 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 premium for this Insurance may be higher because the insurance
oompany may have given us the right to purchase assurance after uninsured
collateral Is last or damaged. The Insurance will not be liability insurance and
will not satisfy any state financial responsibility or no fault laws.
PROTECTING THE SECURITY INTEREST - H your state Issues a tftle for the
property, you promise to have our security interest shown on tiro 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 also we think is necessary to protect our security
interest in the property. You promise to pay all costs, including but not limited to any
atomay fees, we incur in protecting our security interest and rights In the property,
to the extent permitted by applicable taw.
USE OF PROPERTY -- Until the Advance has been paid off, you promise you will:
{t)'is" th e property carefugy and keep it in good repair, (2) Obtain our written
perntission before making major changes to the property or changing the address
where the property l9 kept. {3) Inform us in writing before changing your address. (4)
Allow us fo inspect the property (5) Promptly notify us if the property is damaged,
stolen or abused. (B) Not use the property for any unlawful purpose. (7) Not to retitle
property in another state without telling us.
NOTICE TO NORTH DAKOTA 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
THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE.
NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to fail
to rehlm a motor vehicle that is subject to a security Interest, within thirty days after
you have received notice of default. The notice will be mailed to the address you
gave us. It is your responsibility to notify us it your address changes. The maximum
penalty for unlawful failure to return a motor vehicle is one year in prison and/or a
fine of $150,000. i
This notice contains important information about your rights and our responsibilities
under the Fair Credit Billing Act. You are advised to read your monthly statement
and review it for any error discrepancies or unauthorized transactions.
NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR
STATEMENT. It you think your statement 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 problem
first appeared regarding any discrepancy or unauthorized transactions on your
account. Failure to notify us may result in your acceptance of any responsibility for
payment or reimbursement to us for any such error or discrepancy on your account.
Write to us as soon as possible. You can telephone us, but doing so will not
preserve your rights.
In your letter, give us the following information:
Your name and account number.
The dollar amount of the suspected error.
Describe the error and explain, if you can, why you beknne there is an error.
It you need more information, describe the item you are not sure about.
it you have authorized us to pay a credit card amount automatically from your share
account or checking account, you can stop the payment on any amount you think is
wrong. To stop the payment your letter most reach us three business days before 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 we
have corrected the erns by then. Within 90 mays we roust either correct the error or
explain why, we bafttvs the;stallemard was correct,
In hint Agreement, rite words you and yaw means each and all of arose who apply
for the card or who signs flits Agreement. Card means the Visa Croft Card and any
duplicates and renewals we issue. Account means your Visa Credit Card Une of
Credit account with us. Vft. cis, and ours means this Credit Union,
1. RESPONSIBILITY -- if we issue you a card, you agree to repay all debts and the
Poiance Charge arising from the hue 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 Wm the
card, and this responsitility conlinues until the card is roots vered. Ybu cannot disclaim
responsr'Wkt' y by notifying us. but we will tie ft account for new transactions it you
so request and return all cards. Your obfigatim to pay the account baler" continues
even though an agreement, divorce decree or other court judgment to which we are
not a parry may dired you or one of the other persons responsible to pay the account.
The cards remain our property and you must recover and surrender to us all cards
upon our request and upon termination of this Agnismant,
2. LOST HARD NOTWICAT1ON -- N you bell" the card has been lost or stolen,
you wig frriimadiatelly call the Credit Union at (7t7) 234-8484 or (800) 237.7328. After
hours call (800) 556 5678.
3. LIABILITY FOR UNAUTHORIZED USE -`nbu agree to notify us immedaWy, orally
or in writing d the iosa, theft or unauthataed use of your Credit Card. You may be gable
for the urtautiortaad use of your Crock Card. You wig not be gable for dx orized use
dw ooom saw you notify us of ft loss, then, or possible un u l hor zed use.ybu will suave
no fati ft for wvK*o t*d purchases made wbtt you Credit Card, unless you are grossly
negligent in the handing of yaw Card. M arry case, your liali ft will not alwood $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 awe not to tat the amotrht balance exceed this approved Crock Line. Each
payment you make on, this smourd will restore your Cred?t_L4rie by,the amount.gi~Ute.
ai
payment which ? aippli d-t fe prfnCipBt You request an irxz+9ass In your Cr n
Lvhe only by wrAlen eppscaton to us, which must be approved by our credit committee
or khan officer. By t" you written rtotce we may reduce your 0adit Line from time
to time, or with good cause, revoke yore card and terminate this Agreement. Good
cause Dudes your failure to comply with this Agreement or any other agreement with
us, or our adverse rea valuation of your 0x9ditW0rth1rese. You may also terminate this
Agreement at any time, but termination by either of us does not affect your obligation
to pay the amount balance.
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 who inquire
of us about your osdN standing.
6. MONTHLY PAYMENT - We will mail you a statement every month stowing your
Previous Balances of purchases and dash advances, the current transactions on your
aocount, to remaining ered'd available under your Credit tine, the New Balances of
purchases and casts advances, the Total New Balance, the Finance Charge due to date,
and any other billed tares, and the Muumum Payment retired. Every month you must pay
at least the Miwrhrm Payment within 25 days of your statedners dosing data By saps rate
agreement you may authorize us to charge the minimum payment automadcasy to your
share or ched ft aoootnt with us. You may, of course, pay more frequently. pay more
than the Mirtrnum Payment, or pay the Total New Balance in fug. and you will reduce the
finances charge by doing so If your mon#* payment exceeds the total crock ina balance
owed, we will ataorriatcally post the credo to your St shares.
The minimum payment will be (a) 2% of your Total New Balance, rounded up to the
next even dollar, or (b) $20.00, whichever is greater. In addition, at any time your Total
New Balance exceeds your Credit Lane, you must immediately pay the excess upon our
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.
If we find that we made a mistake on your statement, you will 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 fine 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, it our explanation does not satisfy you and you write to us within ten days
telling us that you still refuse to pay, we must tell 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.
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 CARL) 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 ft problem with the merchant, you may have the
6" 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 in 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 Imitations do not apply it we own or operate the merchant, or if we mailed
YOU ths_rhf for the property or sue..
demand. M will apply payments In the fallowing rnmhtr first to previous late tees,
than to previous cash advances finance dnarges, toot to previous purchase finance
charges, then to current tats fees, then to pwiou s rash advance b W11:es, thderh to
previous purchase balances in the order that they were pasted to your account, then
to current casts advance balances, and than to current purchase balances.
7. FINANCE CHARGES -- You can avoid use Finance Charge on purchases by
paying the full amount of the New Balance of Purchases each month wiMin 25 days
of your statement closing date. Otherwise, the New Balance of Purchases, and the
subsequent purchases from the data 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.
Purcf ooW, We calculate your finance charge by multiplying the average adjusted
oily balance (a" explanation below), including new purchases, for the billing cycle
by Me 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 (sea explanation below) for cash
advances during the billing cycle by the monthly oarlock advance rate and
corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum.
Balance Computation Method
Av nW* Daily Ballanoe br•furchases • The Average Daily Bator" for Purchase
Transardoxs Its calculated by adding the Daily Balances (Purchase Transaction) for
each day In the billing cycle, and then dvrding by the number of days in the billing
cycle. To calculate the Dally Balance to purchases 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 dobfts and subtract the amounts of all credits or payments which post
. to .y o r account that day.. Aftw applying payments.. and credits,.. we subtract the
amount of any unpakf Finance Charges or Late Charges. Then we also subtract the
amount of any Cash Advance transactions that posted to your account out that day or
in arty previous day in the billing cycle. This gives us the Dairy Balance for purchases.
Aw+sragie DWify Bak" lion (ash Advances - Cash Advance Transactions which are
posted to your amount are not included in the Average Dally Balance calculation for
purchases, and are therefore not 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 Ttensactions
is calculated by adding the Daily Balances (Cash Transaction) for each day in the bling
cycle, and #w dividing by the number of days in the billing cycle. 7b 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 exacts 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
accent on that day or in any previous day in the billing cycle. This gives us the Daily
Balance for Cash Advance Transactions. Nots: Cash Advances are always subject to
finance 0mugea and from the day they are posted to your account.
Payments are applied in the following manner: first to previous late 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. Credits
are applied first to the particular type of debt which is being credited, it any, and then
to the balance of your account.
Visa' Credit Card Agreement and truth In Lending Disclosure (continued)
Note also that if 'he total of the payments and credits which are 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. DEFAULT - You will be in default it you fail to make any Minimum Payment
within 25 days 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 d your Visa payment
is due for a period exceeding 30 days. You will also be In default if your ability to
repay us is materially reduced by a change in your employment, an increase in your
obligations, bankruptcy or insolvency proceedings involving you, your math or your
failure to abide by this Agreement. or if the value of our security interest materially
declines. We have the right to demand Immediate payment of your full account
balance if you default, subject to our giving you any notice required by law. To the
extent permitted by taw, you wilt also be required to pay our collection expenses,
including court costs and reasonable anorney fees,
9. USING THE CARD - To mate a purchase or cash advance, there are two
alternative procedures to be followed. One is for you to present the card to a
partfcpating Visa plan merchant, or another financial institution, and sign the sales
or cash advance draft which will be imprinted with your card. The other is to complete
the transaction by using your Personal Identification Number (PIN) in conjunction
with the 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 will Identify the mend, electrotNc terminal or financial Institution at
which transactions were matte, but sate, cash advance, credit or other aids cannot
be returned with tie statement.. You will retain a copy of such slips furnished at the
tirrw of the transaction in otter to inanity'the' month stativi lent The Credit Union may
make a reasonable charge for photocopies of sloe you may request.
10. OVERDRAFT OPTION - If you elect to overdraft to your PSECU Visa Credit
Card, that election is subject to the existing credit limit and the agreement it represents
and the current bah policy, at the time of the overdraft. You also understand that an
overdraft will be cormidered the sans as a cash advance on your PSECU Visa Credit
Card and that the cumin[ Annual Perteritage Rate for cash advarnces will amply.
11. RETURNS AND ADJUSTMENTS- Merchants and others who honor the card
may give credit for mtwrrs and adjustments, and they will do so by sending us a
credit slip which we will post to your Visa fire of credit It your credit and payments
exceed what you we us, we will automatically post the excess credit balance to
your $1 Shares within 75 days. it the balance is one dollar or more, upon your
written request, we will refund the credit balance to you.
12. FOREIGN TRANSACTIONS - The exchange rate between the transaction
currency and tie billing currency used for processing international fransecbcns Is a rate
selected by Visa from the range of rates available in wholesale currency markets for the
applicable central processing data, which rate may vary from the rate Visa itself
receives, or a rate in effect for the applicable central processing
date. In eat,Ine#artoe, an a*xtment may be assessed based on the ISA fee imposed
by Visa. This fee„ which totals 1% of the transaction amount, will be assessed on all
tfardections where the merdwd country differs from the country of the card issuer.
13. SPECIAL RULES FOR VISA PURCHASES - If you disagree or fund an error
with a Visabansaction, and have tried in good faith to oonact the problem with the
AN CARD CAROMOLM AGREEMENT - The Undersigned (you or your), it
ooraideration of THE PENNSYLVANIA STXrE EMPLOYEES CREDIT UNION (we, our
and us) Issuing to you an ATM CARR hereby agree to be leg* bound by the following
temro and condiaoni0bu Visit to tie use of your ATM card(s) amfilifts sooeptance
of the terms and ocridtione of this Agreement. You understand that ATM is a oreuit-retated
"servicaend you wAhoft PSECU to obtain a o!atftreport on any users of this account.
1. ACCOUNTS AND USES OF ATM CARD -4bu have the account(s) onciuxling
Chaddng and Regular Shares), which we set forth on your application form with this
Agreement. You hereby request that we issue to you one or more ATM CARD(S) to
be used in connection with such accounts as described in this Agreement.
You understand you may use the ATM CARD at a STAR SYSTEMS* ATM to (i)
withdraw cash from, (2) make or arrange for deposits in, (3) effect transfers to or from
your aodount. (4) receive milomtatfot regarctetg the balance in your account(s) or (5)
make cash advances from your crust aocoungs) in tine amounts you request. You may
also use automated teller maddnes throughout the United States and in certain
breig n countries which bear the PLUS SYSTEMA name and logo (1) to make
withdrawals from. (2) effed transfers to or from. (3) receive Information regarding the
balances in your Cheddng or Regutar shares. If you have a Personal Service Loan
approved and in place. you may also make a cash advance from your PSL You further
understand you may use the ATM CARD to purchase goods and services
("Purchase') at any retail astablishment (`Merchant') where ATM CARDS are
accepted by such Merchant if you use the ATM CARD to make a Purchase to obtain
cash, d permitted by the Merchant, you shall be requesting us to withdraw funds in the
amount of such Purchase (Including any cash received from the Merchant) from your
Checking Shares and directing or ordering us to pay such funds to the Merchant.
You request that we will provide to you such other services or access to other ATM
systems or networks using the ATM CARD which we 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 through the ATM
CARD we have issued to you. You agree that the uses of the ATM CARD described
merchant or the charges are the result of unauthorized or fraudulent use, or your
purchase cost more than S50 and was made from a plan merchant in your state
within 100 miles of your tome, contact PSECU.
14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing
within 60 days following the date on which we sent your statement wherein the error
or problem first appeared regarding any discrepancy or unauthorized transaction on
your account. Telephoning PSECU does not preserve your dispute rights. You may
be required to provide us with documentation to support your dispute claims. In
addition, you may be required to complete a standard dispute form outlining the
details of your dispute. In cases of fraudulent card use, PSECU will also require a
notarized afftdavil. In some cases we may ask you to notify the local authorities.
If we cb not receive the proper requested documentation in the time specified you
may be held responsible for the transaction(s) in question. PSECU must adhere to
strict dispute tirreframes set forth by Visa.
15. SECURITY INTEREST - To secure your account, you grant us a purchase
money security interest under the Uniform Commercial Code in any goods you
purchase through the account. If you default, we will have the right to recover any of
these goods which we have not been paid for through our application of your
payments in the manner described in the Monthly Payment section. With respect to
this account only, we will not assert any statutory right we may have it you are in
default 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
specific pledge of your credit union shares (Deposits) by signing the Pledge of
Shares or otherwise, or any other security interests for all 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.
16. EFFECT OF AGREEMENT - This Agreement is the contract which applies to
all transactions on,, your account even tough the sales, cash advance, credit of
other alips you sigh 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.
17. LATE PAYMENT CHARGE - It your Minimum Payment is not received by the
first day of the month following your due date, you will be subject to a $20 charge,
1& RUSH PEES -You may incur additional charges for rush processing and rush
delivery of cards andtor PIN matter.
19 OVER t.Wr FEE- A$20 be will be applied breach monthly std closing dame
on which the otutstartdatp balance exceeds the assigrsed crock limit by more than $100.
20. DRAFT COPIES - You may incur an additional charge for transaction
summiarylsale draft documentation.
21. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement.
22. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use
your card for any transaction that Is illegal under applicable federal. state, or local law.
23. NO USE - inactive Visa accounts that have no purchase or cash activity may
be closed without notice to you after 18 months of no activity.
24. NEURAL NETWORK - PSECU uses neural network systems to predict and
prevent unauthorized transactions. There may be occasions when a transaction is
deokied Wow" it is Indicative of possible fmUctulert ad:W#.%
In this Agreement shall be subject to the rules and regulations of each account
which is accessed by such Card. .
2. USE OF PERSONAL IDENTIFICATION NUMBER (-PIN-) WITH ATM CARD
You understand that a STAR SYSTEMS or a PLUS SYSTEM ATM is an automated
teller. It can and will perform many of the same tasks as a human teller. You
acluttiliul Age VW the Personal Identification Number or PIN which you use with ft
ATM CARD is your signature, identifies the bearer of the Card to the STAR SYSTEMS
ATM. PLUS SYSTEM ATM, or other network ATM and authenficates and validates the
directions given just as your actual signature and other proof Identify you and
authenticate and validate your directions to a human teller. You also understand that
a Merchant which accepts the ATM CARD for a Purchase transaction may have an
electronic terminal (Merchant operated or Sell-Servios) which requires the use of your
PIN and when your PIN is used at a Merchants terminal, It will authenticate and
validate the direction given just as your actual signature will authenticate and validate
your directions given to u5. You acmowledge that your PIN is an identification code
that is personal and confidential and that the use of the PIN with the ATM 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 believe the ATM 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 not make, 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 IF YOU GIVE YOUR ATM CARD(s) and PIN
TO 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 motley in the account(s) it you take no action to notify
PSECU of the loss of your ATM CARD or PIN. Safeguard your Personal
Identification Number (PIN). Do not tell or disclose your PIN to any other person. Do
not write your PIN on your ATM CARD. Do not keep a written record of your PIN near
your ATM CARD. Do not choose a PIN that is easily identifiable.
?l nls_E?n .mnffe&.ATM A9c em nt. ant ...R 9u t?srn .._ 11 z ce
(continued)
A new card may be ordered for you at that time and a "hold' will be placed on your
old card. After such time, If you find your old card, destroy the old card by cutting it
in half. It you attempt to use your old card. it will not work.
4. CHARGES - You agree to pay a 50 cent charge for each deposit or withdrawal
exceeding 15 a month. You agree to pay the 50 cent penalty charge on any cash
disbursement transaction (ban advance or share withdrawal) that is less than $20.
You agree to pay a 25 cent charge on each balance inquiry. You may incur a charge
for any adµistment that needs to be made to your account resuffing from an error
you made white making a deposit at an Automated Teller machine (ATM). You agree
to pay the charges or transaction fees which are charged by us for these services
or for 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 deposit at a STAR SYSTEMS
ATM that we have the right to verify the deposit before we make the money available
to you. It you deliver casts, checks or other items to a STAR SYSTEMS ATM, you
understand and acknowledge that the funds from your deposit may not be available
for immediate withdrawal and that the availability of your deposit shall depend on our
niles and regulations regarding the particular account in which you are making a
deposit, the items fiat you are deposltirlg and whether the deposit is made at a
STAR SYSTEMS ATM that is owned by us or another financial Institution. You also
understand and acknowledge that not all STAR SYSTEMS ATMS may accept
deposits and some STAR SYSTEMS AiMS may limit the amount of funds which
may be deposited and that we may not control these limits.
ktl. LIA131 Y 0.. If the ATM CARD is issued for a joint account, you agree to be
puny amt sevecp N" under the terfn's of this Agreement and tfie agreement for
such account You agree that 4 you make deposits or payments to your account(s)
with Items other than cash (checks, drafts or other item) 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,
it the funds In your aomu t(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 charges for
these services. We may do so by niotiy ng you in writing of such amendments or
changes and your use of the ATM CARD after the effective date of any such
amendment or change shall constitute your acceptance of and agreement to such
amendment or cheroge,
a. OWNERSHIP -- You agree that the ATM CARD is our property and you will
surrender ft to us upon our request. You agree that the ATM CARD is non-
transferable.
9. LOSURES-You hereby acknove receipt of the disclosure statement
inforrmm i you of yoke ro ts. under the Electronic Funds Transfer Act and a COPY of
this Agreement.
REGULATION "E" DISCLOSURE
1. ELECTRONIC CHECK CONVERSIONIELECTRONIC RETURNED CHECK
FEES - if you pay for something with a check or share draft, you may authorize t
to be converted to an electronic find transfer. You may also authorize merchants to
electronically Wblt your account for returned check fees. You are considered to have
authorized these electronic kinds transfers H 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 it you sign a written authorization.
2. SUMMARY OF CONSUMER LIABILITY -
• ATM, ACH acid SST - Tell us at once it you believe your card has been lost
or slolen. 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 11 you
believe your card has been lost or stolen, and you tea us within two business days
after you team of the loss or theft, you can lose no more than $50 if someone used
your card untiou{ your permission.
N you do not tea us within two business days after you foam of the loss or theft of
your card, and we can prove we could have stopped someone from using your card
without your permission it you had told us, you could lose as much as $500.
Also, it your statement shows transfers that you did not make, tell us at once. If
you do not tea 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 it you had told us In time.
C a good reason such as a tong trio or a hospital stay kept you from telling us. 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). Aker hours, follow the menu options on PSECVs
voice mail system to report a lost or stolen card. For Visa Credit or Debts
Cards, Vlow the directions for Lost Card Atori7ication under the Visa Credit
Card Agreement and TruIP-in-Lending Disclosures section of Mris document.
• ACH and SST - Contact PSECU at (800) 237.7328 (nationwide) or (717)
234-6484 (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
TDO (600) 472.1967 Nationwide
(717) 777.2100 in Harrisburg
4. FINANCIAL INSTITUTION'S BUSINESS DAYS -
• ATM, ACH and SST - PSECU's Business Days are Monday through Friday,
Holidays not included.
5. TYPES OF ELECTRONIC TRANSFERS A CONSUMER MAY MAKE -
• ATM - Balance inquiries on checking, savings and PSL; withdrawals from
checking/savings; cash advance from PSL; deposits to checkinglsavings;
purchase goods and services at any accepting retail establishment,
• ACH - Pmauthorized debits and credits to checking and savings.
• SST - Balance inquiries and transaction histories on all share. 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 dedtificates.
8. ANY CHARGES FOR ELECTRONIC FUNDS TRANSFERS OR FOR THE
RIGHT TO MAKE TRANSFERS -
• ATM - Fifty cents for each disbursement (cash advance or withdrawal) less
than $20; fifty cents for each transaction over 15 par month; 25 cent for each
balance inquiry;. and there may be an additional charge for any ac4ustment
tfriat needs to be made to the account of any member vitro makes an error
while depositing at an Automated taller machine (ATM).
• ACH - $30 service charge for fnsuffident funds for each electronic transfer,
• SST - none
7. SUMMARY OF CONSUMER'S RIGHT TO RECEIVE DOCUMENTATION OF
EFT'S -
• ATM - Wu 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 t1he month.
• ACH and SST - You wN 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 trans a direct deposit made to your amount at least
once every 80 days from the same person or company, you can call us at
(600) 237-7328 to find out whattet or not the deposit has been made.
a. STOP PAYMENT RIGHTS - PRE-AUTHORIZED TRANSFERS -
• ATM and SST - Not matte.
• ACH - Right to Stop Payment and Procedures for doing sm If you have told
us in advance to matte regular payments out of your account, you can stop
any of these payments. Here's haw: Cap us at (800) 237-7328 (Nationwide)
or (717) 234.8484 (Harrisburg) or write us at Pennsylvania State Employees
Credit Union. P.( aox 67013, Hardsbury, PA 17106-7013, In time for us to
reathre your request three business days or more before the paymen 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 cal.
• Nodes of VaryhV Amounts. If these regular payments may vary in amount.
the person you are going to pay will tea you, 10 days before each payment,
when tit wit be made and hour nuioh. ..be,.Yqu matt'- 1tlt0ee; O&A"
this notice only when the payment would differ by more than a certain amount
from the previous payment, or when the amount would tali outside certain
limits that you set.
• Liability for Fallunne to Stop Payment of Preauthodked Transfers it 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 Gable for your losses
or damages, unless we request and do not receive written confirmation of an
oral stop payment within 14 days and the trans* takes {lace after 14 days,
or you W to give us proper instructions that would enable its to place the stop
on the transfer.
9. SUMMARY OF THE FINANCIAL INSTITUTION'S FAILURE TO MAKE OR
STOP CERTAIN TRANSFERS -
ATM - C PSECU ails to complete a transaction on time or In the colmad
am ouutt, when property instructed by you, PSECU will be liable for damages
caused by our failure tress: (1) there are insufficient funds in your account to
complete the transfer: (2) the funds in your account are uncoiiected; (3) the
funds are subject to legal process; (4) the transaction you request would exceed
the funs In your account plus any available 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 ties reason to believe that the transaction requested is
unauthorizW; (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 falurs was caused by an act of God, fire, or other catestrophe, or by any
other cause beyond control; (10) if you attempt to complete a transaction that,
at a STAR Systems, PLUS System, or merchant terminal that is not a
Els?ttenl?.._F.i><rzs?t1'cs??L??i.Thi_A1e?tnsni.end..8asvlaa?ion..._,E..._p1?tQ.svT?
(continued)
permissible transaction listed above; or, (11) the transaction would oxceed the
security limitations on the use of your ATM CARD.
• ACH and SST - 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 subject to legal process; (4) the transaction you
request would exceed the fluids 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 only for actual proven and not consequential damages if the failure
to make the transaction resulted from a bona fide error despite PSECU's
procedures to avoid such errors.
10. DISCLOSURE TO THIRD PARTIES -
• ATM, ACH and SST - PSECU will disclose information about your account to
third parties: (1) when it is necessary to complete transactions; (2) to verily
the existence and standing of your amount with PSECU upon request of third
party, such as a credit bureau; (3) to comply with government agency of court
orders; (4) in accordance with your written permission; (5) to comply with
government or administrative agency summonses, subpoenas, or court
orders; (6) on receipt of certification from a Federal Agency or department
that a request for information is in compliance with the Right to Financial
Privacy Act of 1978; Regulation P, Privacy of Consumer Financial information;
and (7) when it is necessary to take legal action to recover shares.
11. STAR SYSTEMS SERVICES -
• ATM Only - Ytxt 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 the
accounts accessed by you ATM CARD.
a) Determine the account balance(s) of your Checking your Regular
Shares, and your Personal Service Loan (PSL).
b) Withdrew casts from your Checking and your Regular mares.
c) Make a cash advance from your Personal Service Loan (PSL).
d) Deposit currency. check& or drafts (coins are not acceptable) or
transmission to PSECU or deposit in your Checking and your Regular
Shares.
NOTE: There are Bolted locations in Maryland where deposits may be made.
We wish to inform you that some ATMs located in time areas may only provide
mesa to your Checking, your Regular Shares, and your Personal Service Loan.
ATMs may accept deposits. There may also be limits on the amount of
furka which you may deposit in certain ATMs.
12. PLUS SYSTEfitf• SERVICES -
+ ATM Only -You may use your ATM CARD with your Personal Identification
Number (PIN) at any PLUS SYSTEM automated teser machine
(PLUS SYSTEM ATIA) located throughout the United States, Puerto Rio,
Canada, Great Brilairt and Japan to conduct any of the following transactions on
the accounts accessed by your ATM CARL,
a) Determine the account balance(s) of your Check(ing, your Regular
Shares, and your Persor W Service Loan (PSL).
b) Withdraw casts 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 itre STAR SYSTEMS services currently available through the PLUS
SYSTEM network Otter 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 stall inform you when
such arrangements are made and describe the services that are available to
you. Any charge 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 will be
deducted from your Checking. When you make a Purchase using the ATM
CARD, you wig be requesting PSECU to withdraw funds from your Checking
in the amount of this Purchase and directing PSECU to pay these funds to
such Merchant
15. LIMITATIONS ON THE USE OF YOUR 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
withdrawlptrrchese up to $500 at point of sale locations. PSECU reserves the
right to reduce this daily limit at any time. In the event that your daily limit is
less than S500, PSECU will advise you of the now 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 are not
revealed for security reasons. The Pennsylvania State Employees Credit
Union is not obliged to maintain such limitations.
You will be denied use of your ATM CARD it you exceed the daily
withdrawaitpurchase limit, 0 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 limitation. The receipt provided by the STAR
SYSTEMS or PLUS 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 result in machine retention of our ATM CARD. The number
of attempts that result in machine retention is not revealed lot security purposes.
18. ERROR RESOLUTION PROCEDURES --
• ATM, ACH and SST - in case of errors or questions about your transactions:
Dkect inquiries to PSECU at (800) 237-7328 Nationwide, TDD (800) 472-
1867 Nationwide, (717) 777-2100 in Harrisburg, or write PSECU at:
Pennsylvania State Employees Credit Union, P.O. Box 67013, Harrisburg. PA
17106-7013, as soon as you can bf you think your statement or receipt is
wrong, or 0 you need more Information about a transaction listed on the
statement or receipt PSECU must hear from you no later than 60 days after
4 sent you the first statement on which the problem or error appeared. You
must provide the following information: (a) Your name, account number, and
ATM CARD number (If a ATM transaction), or reference nurn ber (if Seth
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 complaint or question in wining
within 10 txrsiness days. PSECU will tell you The results of the investigation
within 10 business days for STAR SYSTEMS, PLOS SYSTEM, SELF-SERVICE
TELEPHONE. or DIRECT DEBITICREDIT 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 DEBITICREDIT TRANSACTIONS or 90 days for
STAR SYSTEMS purchase transiactions, it PSECU decides to do this, it will
rec redl your account within 10 business days or the amount you think is in error
if it Is a STAR SYSTEMS, PLUS SYSTEM, SELF-SERVICE TELEPHONE, or
DIRECT DEBITICREDIT 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 imrostigation. If PSECU does not receive your
complaint or question in writing within 10 business days, PSECU may not
recruit your account. If PSECU decides More is no error, you will be advised
within three business rays after the investigation is completed. You may ask for
copies of the documents PSECU used in the investigation, If PSECU credits
your atocium while innnastigltcting, you must repay those funds if 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 arty national, regional or local network
rifted in processing the ac Lion (and you may be charged a tee for a balance
Inquiry avert If you do not complete a fund transfer). The ATM surcharge will be
debited from your account 0 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 location,
choose another ATM.
• It the ATM has an entry door, close the door prior to initiating your transaction.
• Put your cash away immediately.
• Direct complaints concerning ATM sowriy to an appropriate department of
the owner of the ATM. New Jersey residents: you may call the New Jersey
Department of Banking at (609) 292-7271
For those members who purchase a vehicle under the
DRiV Program, please review the following FTC Notice:
NOTICE
ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT
IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH
THE DEBTOR COULD ASSERT AGAINST THE SELLER OF
GOODS OR SERVICES OBTAINED WITH THE PROCEEDS
HEREOF. RECOVERY HEREUNDER BY THE DEBTOR
SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR
HEREUNDER.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04695 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE EMPLOYEES
VS
GROVE JANINE M
RONALD E HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
GROVE JANINE M the
DEFENDANT , at 0016:13 HOURS, on the 20th day of August 2008
at 29 MAPLE AVENUE
CAMP HILL, PA 17011 by handing to
JANINE M GROVE DEFENDANT
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 18.00
Service 15.00
Affidavit .00
Surcharge 10.00
.00
q 1b41VT C?„ 43.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
08/21/2008
VAN ECK & VAN ECK
Deputy Sheriff
A. D.
*'
PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS
CREDIT UNION, : CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
NO. 2008-04695
VS. .
JANINE M GROVE
Defendant CIVIL ACTION -LAW
PRAECIPE FOR JUDGMENT
Enter Judgment in favor of Plaintiff and against Defendant, Janine M Grove for want of
ANSWER TO COMPLAINT.
(X ) Assess damages as follows:
Debt -----------------------------------------------------------------$13,750.47
Attorney's Commission ------------------------------------------- $1,425.00
Filing costs ---------------------------------------------------------- $to be determined
TOTAL--------------------------------------------------------------$15,175.47 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 his/her 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 least ten days prior to the
date of the filing of this praecipe and a copy of the notice is attached.
DATE: qW?_ Signature: ?A" a -
Melissa L. Van Eck, Esquire
Attorney for Plaintiff
7810 Allentown Blvd., Suite B, Hbg., PA 17112
(717) 540-5406
ID#: 85869
NOW, , 2008, JUDGMENT IS ENTERED AS ABOVE.
P_
thou tart'/Clerk, Civi sion
By: a_ VL
Deputy
Document #: 180057.1
PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS
CREDIT UNION, : CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
NO. 2008-04695
VS.
JANINE M GROVE
Defendant CIVIL ACTION -LAW
TO: JANINE M GROVE
29 Maple Ave.
Camp Hill, PA 17011-4119
DATE OF NOTICE: September 10, 2008
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGHBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
By: 19-ok
Melissa L. Van Eck, Esquire
Attorney I.D. No. 85869
P.O. Box 6662
Harrisburg, PA 17112
717.540.5406
Attorney for Plaintiff
I 1 ''C
PENNSYLVANIA STATE EMPLOYEES:
CREDIT UNION,
Plaintiff
VS.
JANINE M GROVE
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2008-04695
CIVIL ACTION -LAW
ENTRY OF APPEARANCE
Please enter the Appearance of Van Eck & Van Eck, P.C., as counsel for Plaintiff in the
above captioned action.
Respectfully Submitted,
Date: September 22, 2008
VAN ECK & VAN ECK, P.C.
By: (Y'
Melissa L. Van Eck, Esquire
Attorney I.D. No. 85869
Henry W. Van Eck, Esquire
Attorney I.D. No. 83087
P.O. Box 6662
Harrisburg, PA 17112
(717) 540-5406
Attorneys for Plaintiff
Document #: 180057.1
PENNSYLVANIA STATE EMPLOYEES:
CREDIT UNION,
Plaintiff
VS.
JANINE M GROVE
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2008-04695
Defendant CIVIL ACTION -LAW
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I, Henry W. Van Eck, Esquire, being duly sworn according to law, depose and say that I am
the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my
knowledge, information and belief Defendant, Janine M Grove, above named, is not a
corporation and is an adult individual under the age of 21 years of age; is not in the military
service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and
Sailors' Civil Relief Act of Congress of 1940 and its Amendments.
V ECK & VAN ECK, P.C.
By
Henry W. V Eck, Esquire
Attorney I.D. No. 83087
P.O. Box 6662
Harrisburg, PA 17112
717.540.5406
Attorney for Plaintiff
Sworn and subscribed to
before me this 00- day
of September 08
`?Ic
Notary ?bli,
Document #: 184057.1
FNR OTARIAL SEAL
ISSA L VANECK
otary Public
TWP, DAUPHIN COUNTY
on Expirss Mar 22, 2011
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, to
PENNSYLVANIA STATE EMPLOYEES:
CREDIT UNION,
Plaintiff
VS.
JANINE M GROVE
Defendant
TO: Janine M Grove, Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2008-04695
CIVIL ACTION -LAW
You are hereby notified that on q jSjo8 , the following
(OFdef) (Degr-ee) (Judgment) has been entered against you in the above captioned case for ,your
failure to file an answer to the complaint. A Judgment in the total amount of $15,175.47 plus
costs is hereby entered.
DATE: Li'? 8. "
W thonotary Q
I hereby certify that the name and address of the proper person(s) to receive this notice is:
Janine M Grove
29 Maple Ave.
Camp Hill, PA 17011-4119
A: Janine M Grove, Defendant, Defendido/a (Defendidos/as)
Por este medio se le esta notificando que el
de
del , el/la siguiente (Qfden) (Deerete)
(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Prothonotano
Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado
de residencia:
Janine M Grove
29 Maple Ave.
Camp Hill, PA 17011-4119
Document #: 180037.1