HomeMy WebLinkAbout08-7300IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA (n?
PENNSYLVANIA STATE EMPLOYEES NO. b$ - 17300 l.iWi J -r&PA
CREDIT UNION,
Plaintiff
VS.
MATTHEW A SHANABROUGH
Defendant : 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
CREDIT UNION,
Plaintiff
NO.
VS.
MATTHEW A SHANABROUGH
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
despu6s 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 mas 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 INFORMACION 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 #: 1800571
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
VS.
MATTHEW A SHANABROUGH
Defendant
NO. Of 'I,3 to C,vz -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, Matthew A Shanabrough, is an adult individual with a last known
address of 206 9th Street, New Cumberland, PA 17070-1609.
3. Defendant is, and at all relevant time material hereto has been, the primary loan
applicant.
4. Defendant applied to Plaintiff for a personal service 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»
7. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms
and conditions of the Contract marked as Exhibit "B".
8. Various charges and payments were made by Defendant on the account.
9. Defendant has defaulted on the loan by failing to make timely and regular
payments.
10. The last payment made by Defendant was on August 22, 2007.
11. Defendant is required under the contract to make regular and timely payments.
12. Plaintiff has maintained a statement of account keeping an accurate and running
amount of debits and credits made on Defendant's account.
13. Plaintiff has submitted to Defendant a copy of the statement of account accurately
showing all debits and credits for transactions with Defendant.
14. Defendant has not objected to any of the monthly statements of account submitted
by Plaintiff to Defendant.
15. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has
failed, refused and continues to refuse to pay all sums due and owing on Defendant's loan
account balance, all to the damage of Plaintiff.
16. As of December 11, 2008, the balance due, owing and unpaid on Defendant's
loan account with Plaintiff is the sum of Seven Thousand One Hundred Seventy-one Dollars and
72/100 ($7,171.72).
Document #: 180057.1
17. 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.
18. Due to the default of the Defendant and pursuant to the terms and conditions of
the Contract attached as Exhibit "B", attorney's fees in the total amount of One Thousand Four
Hundred Fifty-nine Dollars and 34/100 ($1,459.34) have been added to the account.
19. Any and all conditions precedent to the bringing of this action has been performed
by Plaintiff.
20. 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,
Matthew A Shanabrough, in the amount of Eight Thousand Six Hundred Thirty-one Dollars and
06/100 ($8,631.06), 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: e 4&4 6-C
?p!-
Date: n
F-YF ccA)i
i
i
SIGNATURE LOAN ACTIVATION NOTICE
September 20, 2006
SEP 25 MR -
t1ppueaut
Information:
Ref M 567165 598
Approval Amount: $8,500.00
Account Number:
Applicant: MATTHEW A SHANABROUGH
Work Telephone M
Home Telephone #: '- -
Signature: I acknowledge receipt of the PSECU LOANLINER Disclosure and Credit Agreement and
agree to be bound by th rm set fo in said agreement.
Signature of MATTHEW ABI?OUGH Date
SIGNATURE LOAN OPTIONS
Purpose: / G g/
Please select one of the following Signature Loan disbursement options:
Send a )j(check, or ? deposit to my Share 4 (MoneyHandler/Checking Shares)
Please select one of the following Signature Loan repayment options:
? Payroll Deduction ? Home banking
? Self Service Telephone Coupon
? Automatic Transfer from PSECU account
? Direct Payment from another financial institutioi
SCANNER
Exhibit "B"
PSECO Penns ylvania State Emplovees Credit Union
PO S,r, C,:013 I 1arr,cbur1 Pit 1 ji!%1 ?.7•J nL9»Han: <?.n .ti7?,. ,
n. ! r -. '.77 '32.ti 'van inv. ^e
Loan Disclosures
This LOANLINER, Credit and Security Agreement, which ncludos the 7r.:h1 in CREDIT INSURANCE - Credit life and/or credit disability insurance is optional
Lending Disclosures, will be referred to as the Plan The Plan documents include lhis under the Plan if you quality for and purchase the insurance from us, you authorize
agreement and an Addendum You, your and borrower mean any person who signs ! us to lido file insurance premiums monthly to Your loan balance and charge you !
the Plan. Credit union, we, our and us mean PSEGU or anyone to ,vhom the Credit interest on file enfirr_ balance. If you elect credit insurance, your payments may
Union transfers its rights under the Plan increase or the period of time necessary to repay your advance may be extended. ;
HOW THIS PLAN WORKS - This is an open-end, multi-featured credit plan We The credit insurance rates may change dunny the Plan. If the rates change, we will
anticipate that, from time to time, you will borrow money (called "advances') under provide any notices required by appl,cable law
the Plan. We are not required to make advances to you under the Plan and can j PERIODIC STATEMENT - On a regular basis you tv.d receive a statement show,nq
refuse a request for an advance at any time, The Addendum ciescribc!s the , all transactions under the Plan during the perod covered by the statement
different types of credit (called "subaccounts") available under the Plan, :he current Statements and notices will be sent to you at the most recent address you have
interest rate for each subaccount expressed as a daily periodic rate and given us in visiting. Unless applicable law requires notice to each Joint borrower
Corresponding annual percentage rate and other charges. It may also have other notice to any one of you wit! be notice to all.
terms and a schedule for determining the payment amounts. JOINT ACCOUNTS - if this is a joint account. each of you is individually and jouttly
CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain I responsible for paying all amounts owed. That means we can enforce our rights
subaccounts if a credit limit is set for a subaccount, you promise not to exceed the under the Plan against any one of YOU indtvidualty or against all of you together. If you j
established credit limit. ff you exceed the credit limit, you promise to repay j give us inronsistent instructions. we can refuse to follow your instructions. Unless our '
immediately the amount which exceeds the credit limit. i ritten policy requires all of you to sign for an advance, each of you authorizes the
REPAYMENT - You promise to repay all amounts you owe under the Plan plus w other(s) to obtain advances individually and agrees to repay advances made to the
interest. Payments are due on the last day of the month unless we set a different day I other(s). Any joint accountholder may terminate the Plan by giving us prior writton
tit the time of an advance. If the Addendum has no payment schedule for a notice. It any of you terminate the Plan, the Plan is terminated for all of you. You
subaccount, your payment will be determined at the time of each advance I remain liable individually and jointly for all advances incurred before termination.
Payments must include any amount past due and any amount by which you have I FEES AND CHARGES - If you give us a security inlarest in certain types of
exceeded any credit limit you have been given for a subaccount. You may repay all property, we may charge you a filing fee to perfect our interest in the property, if we l
or part of what you owe at any time without any prepayment penalty. Even if you do, the amount of the fed will be disclosed to you at the time you obtain an advance. I
prepay, you will still be required to make the regularly scheduled payments unless We may also charge you other fees in connection with the Plan. Our current fees are j
we agree in writing to a change in the payment schedule. If you have a joint disclosed on the Addendum and wit! be added to your loan balance unless you pay
sharedraft account, you will be responsible for paying all overdraft advances them in cash, j
obtained by a joint holder of the sharedraft account. Unless otherv;ise required by UPDATING CREDIT INFORMATION -You promise that you will promptly give us
law, payments will be applied to amounts owed under the Plan, in the manner the
Credit Union Chooses. written notice if you move, change your name or employment, or if any other
information you PLAN ACCESS -You can obtain credit advances in any manner authorized by us. 11 Y Provided to us changes Upon our request, you also agree to
we allow you to use your ATM/Debit card to access the Plan, you may be liable for the provide us updated financial information.
unauthorized use of your ATIAlDebtt card. You Will not be liable for unaurhorizad use DEFAULT - The following paragraph applies to borrowers In Idaho. Kansas,
that occurs after you notify us, orally or in vaiting, of the loss, theft. or possible ; Maine and South Carolina: You will be in default if you do not make a payment of
unauthorized use. If you believe your ATM/Debit card has been lost or stolen, the amount required when it is due. You will also be in default If we believe the
immedialey inform the Credit Union by calling or writing us at the telephone number or prospect of payment, performance, or realization on any property given as security
address that appears elsewhere in the Plan. If the card is used to obtain unauthorized 1 is significantly ;repaired,
advances directly from the Plan, your liability will riot exceed S50. If the unauthorized i The following paragraph applies only to borrowers In Wisconsin., You will be in
withdrawal is from a sharedratt account, your l!atrlay is governed by the Regulation E default if you fail to rnake a payment when due two times during any 12 month
disclosures you received at the time you received your ATM/Debit card. even it the f period. You will be in default If breaking any promise made under the Plan matenally
withdrawal results in an advance being made from your overdraft subaccount. j impairs your ability to repay what you owe or materially impairs the condition, value. !
FINANCE CHARGE - The dollar amount you pay for money borrowed is called a I or protection of or our right in any property you gave as security.
"'finance charge" and begins on. the date of each advance. A finance charge will be The following paragraph applies only to borrowers in Iowa: You will be m i
computed separatety for each separate balance under the Plan. To compute the default if you are more than 10 days late in making a payment. You will also be in'
finance charge, the unpaid balance for each day since your last payment for since j default if you do not comply with the terms of the Plan and your failure to comply
an advance if you have not yet made a payment) Is multiplied by the appticable daily ( materially impairs any property you gave as socurity or your ability to repay what you f
periodic rate. The sum of these amounts is the finance charge owed, The balance I owe under the Plan,
used to compute the finance charge is the unpaid balance each day after payments The following paragraph applies to borrowers in all other states: You will be in j
and credits to that balance have been subtracted arid any additions to the balance defeuil it you do not make a payment of the amount required when it is due, You will i
have been made. In addition to interest, we may charge other finance charges which be in default it you broak an
are disclosed on the Addendum. It the interest rate is a variable interest tale, the y any promise you made under the Plan if anyone is in
Addendum explains how the variable interest rate works, ; default under any security agreement made in connection with an advance under
j the Plan, You wilt be in default if you die, file for bankruptcy, become insolvent, if you
SECURITY -You pledge as security for the Plan all shares and dividends and, it any. i make any false or misleading statements in any credit application or update of credit
all deposits and Interest in all joint and individual accounts you have with us now and information, or if something happens we believe may substantially reduce your I
in fire future. 11 a specific doflat amount is pledged for an advance, we will freeze ability to repay what you owe. You wall be it,, default if any property you have given I
shares in that account to the extent of the outstanding balance for the advance. us as security is repossessed by someone else, seized under a forfeiture or similar
Otherwise, your pledged shares may be withdrawn unless you are in default. The law, or if anything else happens trial significantly affects trio value of the property or
following paragraph applies in all states except in Ohio, Rhode Island and I our security interesl in it You will also be in detault under the Plan if you are in default
Massachusetts: We have a statutory tier, on the shares and dividends and, it any, the I under airy other loan agreement with us.
deposits and interest in all individual and join! accounts you have with us ano may I ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers In i
exercise our rights under the lien tG the extent permitted by state lam. (We are state I Colorado, District of Columbia, Iowa. Kansas, Maine, Massachusetts, Missouri,
-havered if our name duos not include ti,e term "Federal Credit Union') For all ! Nebraska, South Carolina and West Virginia: When you are in default and alter
orrowers: The statutory lien and/or your pledge will allow us to apply the funds
oil unt(s) your es: The st to what you owe when you are in default. The slalutury her, and expiration of any right you have under apphCable- sate lave to cure your default, via can
your pledge (in not apply to any Ireividuai Retirement Axoun! or any wt.ur aC.:tit, r! demand urimfd!aIP, payment of the entire Unpaid G.i4:nce under ire Plan without
giving pw advarcu notice
that would lose special tax treatment under state or federal law i! gven as serunty.
Ac,Irior,at s_C:airy for vie Plan mrv be req-wd at the llmc, Of irri advance If :i The following paragraphappliesto borrowers in all otherstatesexcept Wisconsin ;
subaccount denlf es a tyPe of Pr _ipert isu t. as -New Cars. .red Louisiana: 1?'h•_•• you ti,e it faul•, v,t an (-(tune immediate payrnerv
Y w u mul g tl: t tai^cdieralion) of the en! re unbard balari e tinder ire Plan Ybu wa-.e any right you have
type of property as secirily mien you gi.•I an ro`:ance under that subEiccou'it.
sutiaccount -,amo such as 'Other Ic demand r^.r payrn, ^! neut.; DI nlerr : , a elrrate and nonce of 1 CBlerabon.
Securc7 means you siust provicd: .n•t;
aocefitaDle ID us when you obtain an acvance UW1r.f tha! stipaccount. Propof:y yo.: The following paragraphs apply to borrowers in all states except Wisconsin and
arse is security iwill secnire al' arncurim atieo under the Plan and all o:lter /oars yo„ Louisiana: If imired,ate pa',mert is icnia^ied ;o,: sell ccnlint,& to pay interes! unit(
I'ave m t'. US '•t4' iii Ir) the hi!'ul e, t-'Cep! any !011'I S3CUrc l by your F?fi^CI?.R din fllir u ..e hFa 7 -", rc Cd i'C 3 .h _l; ,..3 Ule ?"'erc ?! rates in eff&V or, ill appllcabie.
PropeRy ._ _r,ng :her Vans y0i.; e th ;s m.ay ills Sec-re Par
A,,xS50i-2'iJF_i... m
LOANLINER' Credit and Se curity_Credit Agreement (continued) ability to i;rercua our iq+ l;atr. Vii rat, pr r r: trls Fla your n-e,r< ")r
at the doe-jif rate u sclnsi•d c . he A.d:,tr••.dam :f i 1c.. _nd .r m••'e_:,-_ : p._., I legal repr:,senra!. ves If _h;r:: , 1r.', t?r•Tr r., trio Plat— -, lwri 'hat !r.a Plan
•ia5 been ma0e your sraies and or d6pos IS z :r c_ ;ip:ilLrd !C:v;'rOS 7.::dt yo,, '7v.. ''+•"11 contunue In t r')tc.:'t us
a5 provided in rte sectiin Ca+!vd .,.._: t ,.: r, . a'SO e.i:rrae an:: of-.., ? CONTINUED EFFECTIVENESS - 1! luny part c. :1) sic: ., oy cfir • ad by a .. ,:r,
rights giveri by law • ,hen yr,I a-e n Vofatx. to be unenforceaate. the fEst w is rem:, it r ,tlcct.
You agree the Crei I G-',ion has the ng'a to t-,ke possessor .if sire property giver, i NOTICE TO UTAH BORROWERS - 'i r.s a.'Ire,?m•r•t s j hoot erprrss-n of
as sec:uhty under the Piaui, x IThdut Jo 6k-1,11 you s, if tills rill". be LXTe mthoui !tie agreement between you and the Gre.t Uhl n, its a fi n agreement may not
breach of the peace. If we :,SK, you promise to delver tie prop elty of a lime and be contrad;cfed oy eviidcn:e of any oral agreeneni
place we choose If the property is a motor vehicle or boat, you agree that we may The following is required by yertnant law -NOTICE TO CO-SIGNER -YOUR
obtain a key or other device necessary to unlock and operate it, whon you are it,
SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE
this
defauil A
thawill riot be t
erty or that sr ap ached not covered by to the
reements
ou leave inside he
r
ro
ert FOR REPAYMENT OF THIS LOAN
IF THE BORROWER DOES NOT PAY
g
,
y
p
op
p
p
y.
will try to return that property to you or make it ava table for you to claim. .
,
THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU.
After we have possession of the property, we can sell it and apply the money to any I The following paragraphs apply if you give security in connection with an
amounts you owe us. We will give you nonce of any public disposition or the date after advance under the Plan. They apply to borrowers in all states except Louisiana.
which a private disposition will be held, Our expenses for taking possession of and Louisiana borrowers will execute a separate security agreement. Borrowers in '
selling the property will be deducted from the money received Iron the sale. Those other states may also be asked to execute a separate security agreement.
costs may include the cost of storing he property, preparing it for sale and attorney's
t
i
? THE SECURITY FOR THE PLAN - You give us what is known as a security ;
ees to the extent perm
tted under state law or awarded under the Bankruptcy Code interest in all property described in any receipt, voucher or other document you
You must pay any amount that remains unpaid after the sale money has been applied receive for an advance ('the Advance"). The security interest ycu give includes all
to any unpaid balance under the Plan. You agree to pay Interest on that amount at the accessions. Accessions are filings which are attached to or installed in the property
same rate as the advance, or. It applicable, at the default rate disclosed or, the now or in the future. The security interest also Includes any replacements for the f
Aodendum, until that amount has been paid. property which you buy within 10 days of the Advance or any extensions, renewals
The following paragraph applies only to Wisconsin borrowers: When ycu are in I or refinancing of the Advance it also includes any money you receive from selling
default and after expiration of any right you have under applicable state law to cure your I the property or from insurance you have on the property. It the value of the property
default, we may require immediate payment of your outstanding loan balance under the 1 declines, you promise to give us more property as security if asked to do so,
Plan and seek possession of property given as security. You may voluntarily give the i WHAT THE SECURITY INTEREST COVERSICROSS COLLATERAL PROVISIONS
property to is if you choose, or we may seek to take possession of the property by - The security interest secures he Advance described in the receipt. voucher or any
Judicial process. It we repossess the property, you agree to pay reasonable expenses
incurred in disposing of Ina property. If the property is a motor vehicle, mobtle home, + other document you receive at the time of the Advance and any extensions, renewals
I or refinancin
Advance
s of th
It al
n
cu
es
th
d
h
trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted g
.
y o
e
so se
r
a
er a
vances you
ave now
or receive in the future under the Plan and any other amounts or loans,
by .section 422.413 of the Wisconsin Statutes. You must pay any amount that remains Including any credit card loan, you owe us for any reason now or in the future,
unpaid after the sale money has been applied to what you owe under the Plan. You except any loan secured by your principal residence. It the property is household
agree to pay interest on any unpaid amount at the same rate as he advance, or, if
applicable, at the default rate disclosed on the Addendum
until that amount is paid. goods as defined by the Federal Trade Commission Credit Practices Pule, the
I
,
If the property is located outside Wisconsin at the time of default, we may take property will secure only the Advance and not other amounts you owe
E
OWNERSHIP OF THE PROPERTY - You promise that you own all property you ;
possession of the property without judicial process, it permitted by the slate where give as security or it the Advance is to buy the property, you promise you will use
the property is located. the Advance for that purpose. You promise that no one else has any interest in or
The following paragraph applies only to Louisiana borrowers: When you are in claim against the property that you have not already told us about. You promise not
default, we can require immediate payment (acceleration) of the entire unpaid
balance under the Plan
You waive any right
ou have to demand for pa
ment
notice to sell or lease the property or to use it as security for a loan with another creditor
il th
A
i
id
Y
l
i
,
y
y
. unt
e
dvance
s repa
.
ou promise you wil
allow no other security interest or
of intent to accelerate and notice of acceleration. If immediate payment is lion to attach to the property ofther by your actions or by operation of law,
demanded, you will continue to pay interest until what you ow•a has been repaid at PROPERTY INSURANCE, TAXES AND FEES - You must maintain properly
the applicable Interest rates in effect unless a default rate is disclosed on the insurance on all property that you give as security under the Plan. You may purchase
.Addendum. It a demand for immediate payment has been made, the shares and the property insurance from anyone you choose who Is acceptable to the Credo
deposits given as security for the Plan can be applied towards what you owe. We Union The amount and coverage of the property insurance must be acceptable to
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 us. You may provide the property Insurance through a policy you already have, or
through a policy you gat and pay for. You promise to make the insurance policy
CANCELLING OR CHANGING THE PLAN - The following paragraph applies payable to us and to deliver the policy or proof of coverage to us if asked to do so.
only to borrowers In Illinois: 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 to the If cancer insurance and et a refund, we have a n the refund. If the
you your g gnt to
interest rate or other charges will apply to future advances, property is lost or damaged, we can use the insurance settlement to repair the
The following paragraph applies only to borrowers in Wisconsin: We can property or apply it towards what you owe. You authorize us to endorse any draft or
check which may be payable to you in order for us to collect any refund or benefits
change the terms of the Plan from time to time in accordance with Section 422.415 due under your insurance policy. You also promise to pay all taxes and fees (like
of the Wisconsin Statutes. You will be notified of any change in terms. An increase registration tees) due on the property. I
in the daily periodic rate under a variable rate interest rate is not considered a E
change in terms under the Plan. We can cancel file entire Plan or any part of rho 11 you do not pay the taxes or fees on the property when due of keep it insured, we may
Plan at any time. You may cancel the Plan at any time by giving us prior written Day these obligations, but we are not required to do so Any money we spend for taxes,
notice. Your obligation to pay the unpaid balances under the terms of the Plan
lees or insurance will be added to the unpaid balance of the advance and you wilt pay
i
continues whether you or the credit union cancel the Plan, except to the extent that
li
li
i
b interest on those amounts a1 the same rate you agreed to pay on the advance. We may
receive payments in connection with the insurance from a company which provides the
your
a
ty +s l
i
mited by Section 422.4155 of the Wisconsin Statutes. Insurance. We may monitor our loans for the purpose of determining whether you and
The following paragraph applies only to borrowers in Iowa: We can chance the other borrowers have complied with the insurance requirements of our loan agreements
terms of the Plan from time to time after giving you any advance notice required by or may engage others to do so. The insurance charge added to an advance may include
law A change that increases the rate of finance charge or otner charge, that (1) the insurance company's payments to us and (2) the cost of determining compliance
increases the amount of your payments or that otherwise adversely allects existing with the insurance requirements If we add amounts for taxes
fees or insurance to the i
balances will apply to existing balances only if you agree to the change or you use
the Plan after receiving notice that your use of Ire Plan means you agree the ,
unpaid balance of an advance, we may Increase your payments to pay the amount
change applies to existing balances
The followi
h
li
b
ll
i
h
W added within the term of the insurance or approximate term of the advance
INSURANCE NOTICE - If you do riot purchase the required property insurance.
ng paragrap
app
es to
orrowers
n a
ot
er states:
e have the the insurance we may purchase and charge you for will cover only our interest ,r the
right to change the terms of the Plan from lime to time after giving you any advance property. The premium for this insurance may be higher because the insurance
notice required by taw Any chrnye in the interest rate will apply to lufura advances, company may have given us the right to purchase Insurance after uninsured
and at our discretion and sublecf To any iequirolnents of applicable law, cv!ll also collateral is lost or damaged. The insurance will not be liability insurance and i
<lppiy to unpaid balances. will not satisfy any state financial responsibility or no fault laws.
The following paragraph applies to all but Wisconsin borrowers: At,, increase :n
PROTECTING THE SECURITY INTEREST - if your state issues a Iva for the
tr r ca !y pcnooic rate under a variable n.cr st role is t c: ncir:Cr.0 a Change :n
t rrns urber the Pian We can rancel foci orn,c Pnn or any Dart of tine Pan of any Property. you piomiso to ha e c _,r se-mty inter?at shown on The title We may have
time. You may cancel the Plan at any tune by going us prior written notice vc-t to 1;;e whal is called a hnancina St lemenl to protect our security interest from the
claims of others If m:ked to do so. you promise to sign a financing statement
You
Zicllr.;aUJn to pay the unpaid balances under tile. terms Ot the Pear continues ashetrer
'
ou or -he Credit Unr
n canc
l the Plnn .
-
ais0 LrJ.T.15e Id 10 whatever e!SE vin tank is ner'essar to protect our se CUra?
y y?
y
,
.
e
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - Vie can du'"ly 1'1101CSf :n !n0 ,r0;l%'ri1J You ?h;tl'.ISt? 10 p Y ill ': G S nCll l!t1ng nut nD' ilrhi{ed L^ any -
attorne
fees v
e in;
r in
rote.un
;
L
c
t
i
i
enforc,rq any ')f our rkt'ats ur der tn.s P.Lin any nur*dr•; r Cif rimes vrgh"lat los,rg try i
-
y
p
r
q
t cur
n
.r
erest and r
gors .n the prc;ocrty.
to the extent I1ei nlaied Ly apph^ablE 167..
LOANLINER' Credit and Serurity Credrtgrccment (continued)
USE OF PROPERTY - Onhl the Advanc ; has beer paid or. you prumse you v,,
(I) Use the property carefully and keep it in good repair. 12) Obtain, our .vnttcn
permission before making major changes to the property or chang rig tr,e address
where the property is kept. (:3) Inform us in v,rting before changing your address. 14! i
Allcv, us to inspect the property. (5) Promptly notify its it the property is damal ij1
stolen or abused (6) Net use the property for any Wi%WtUl purpose (7) Not to retitle
property In another stale without telling us.
NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE
- THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO i
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 unlaw4ll for you to fad
to return a motor vehicle that is subject to a sea.uity interest, within thirty days after
you have received notice of default. The notice wi!I be mailed to :he address you
gave us It is your responsibility to notify us if your address changes. The maximum
This notice contains Important Information about your rights and our responsibilities
under the Fair Credit Billing Act. You are advised to read your montmy 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 it 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. Ynti 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 believe there !s an error
if you need more information, describe the item you are not sure about.
If you have authorized us to pay a credit card account automatically from your share
account or checking account, you can Stop the payment on any amount you think is
;I wrong. To stop the payment your letter must reach us three business days before the
i 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 error by then- Within 90 days, we must other correct the error or
explain why we believe the statement was, Correct.
pe•na,N, (or unla tul ';: lure U rL:rr - motor 's oru y?at in prison
lire of 5150,000.
For those members who purchase a vehicle under the
DRIVe Program, please review the following FTC Notice:
NOTICE
ANY HOLDER OFTHIS CONSUMER CREDIT CONTRACT,
IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH
THE DEBTOR COULD ASSERT AGAINST THE SELLER
OF GOODS OR SERVICES OBTAINED WITH THE
PROCEEDS HEREOF, RECOVERY HEREUNDER BY THE
DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE
DEBTOR HEREUNDER.
I 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. It we didn't make a mistake, you
may have to pay finance charges, and you will have to make up any missed I
payments on the questioned amount. In either case, we will send you a statement
of the amount you owe and the date that it is clue.
If you fail to pay the amount that we think you owe, we may report you as delinquent.
However, if our explanation does not satisfy you and you write to US within ten days
telling us that you still refuse to pay, we must tell anyone we report you to that you i
have a question about your statement. And. we must tell you the name of anyone i
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 S50 of the questioned amo%inf,
even if your statement was correct.
SPECIAL RULE FOR CREDIT CARD PURCHASES - If you have a problam 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 I
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 limitations do riot apply it we own or operate true merchant, or if we mailed
you the advertisement for the property or services.
In this Agreement, the words you and your means each and all of those who apply lane only by written application to us, which must be approved by our credit committee
for the card or who signs this Agreement. Card means the Visa Credit Card and any or loan officar. By giving you written notice we may reduce your Credit Line from time
duplicates and renewals we issue. Account means your Visa Credit Card Line of to time, or with good cause, revoke your card and terminate this Agreement. Good
Credit account with us. We, us, and ours means this Credit Union, cause includes your failure to comply with this Agreement or any other agreement with
1. RESPONSIBILITY- If we issue you a card, you agree to repay all debts and the
a
us, or our dverse reevaluation of your creditworthiness. You may also terminate this
Finance Charge arising from the use of me card and the card account. For example, Agreemen
t at any time, but termination by either of us does no! affect your obligation
you are responsible for charges made by yourself, your spouse and minor children to pay the account balance.
You are also responsible for charges made by anyone else to whom you give the 5. CREDIT INFORMATION - You authorize us to investigate your credit standing
card. and this responsibility continues until the card is recovered. You cannot disclaim when opening, renewing or reviewing your account, and you authorize us to disclose
responsibility by notifying us, but we will close the account for new transactions It you information regarding your account to credit bureaus and other creditors who inquue
so request and return all cards Your obligation to pay the account balance continues Of us about your credit standing
even though an agreement, divorce decree or other court judgment to which we are 6. MONTHLY PAYMENT - We will nail you a statement every month showing your
riot a parry may direct you or one of the other persons responsible to pay the account. Previous Balances of purchases and cash advances, the current transactions on your
The cards remain our property and you must recov.,i and surrender to us all cards account, the remaining credit available under your Credit Line, the New Balances of
upon our request and upon termination of taus Agreement. I purchases and cash advances, the Total New Balance Ine Finance Charge due to date.,
2. LOST CARD NOTIFICATION - If you believe the card has been Iosl or stolen, i and any other billed fees, and the Minimum Payment required. Every month you must pay
you will Immediately call the Credit Union At (;171234-54,44 or f13001 2377328 Alter at least the MInimum Payment within 25 clays of your statement closing date. By separate
hours call (800) 5565673 agreement you may authorize us to charge trio minimum payment automatically to your
3. LIABILITY FOR UNAUTHORIZED USE - You agrc e to nut t}• us Ahmed a:e'y ouOy snare or checking account w th us You may of course, pay more frequently, pay more
or in writing of the bss, ihett or anal.^,hon7ed use or your (rPd r Card. You may be. fiat r• than the f0w.imum Payment, or pay the Total New Balance in full. and you will reduce the
finance charge by doing so. If your monthly payment exceeds the total credit line balance
for the unauthorized use of your Credit Card You will not be liatue for unauthorized u5a l
th
nt
us of me loss rneh, or posse ie unauth,;v¢ed use. You will have
occur-, after you not owed we wi
l automatically post the cr.?dit to your Si Shares
i
i•
?
r for p' r .ases mac!e'AIt your Credl' _.ar"1 l nlP_S you Are grni siy The, n ini mom payment will oe ia) e-,, of your 1;Aal New Balance,. rounoed up lo the
negiigent in the handling o vo.r Car! In any case, your hebftty wit not exceed 550 nazi even dollar or (b Tv a
C
it
it
. ur is yrea addit Ln. , any
I
y
ou
4. CREDIT LINE - It wo approve your acolicm,or., we will establish a self s
Line.
your
r
Now Balance exceeds Great Line. you rr;usr rn rr.e d?ate!y pay t he exces
upgr our
excess
demand
We wil. apply payrrows In the fOr..:nn
mnnhcr
'i
st t
l
!
reolenish,rg Line of Credit for yoL and notry you of its rip -t w en the i s u !.e ,
;
-
r
o previous
acs.
ate
than to previous case a7 ances finance ch :•;
!hen to previous pure*iase f ian,,t
card You agree not to let ine acwnurt onfarce ax oea t i, :!C,,rrr; all Creaa Line Earn ,
criarges. than to curron! !a,o fees then to ev,7.1, cash d:arlcc tia arces then to
payrnenr you make on tr;e acco.int v itl restore your Creo t Line by ire cunount of the previous purchase balances in r•.e ord,r tha• If,-?y were posted t: your accour•t
tnen
payrnent which is applie^ to the pnm!oa;. ybu riay request an increase n your Credit ,
to current cash ao?;tnce balarlp-js, and then '.: c.irrent purccase oilarces.
Visa` Credit Card Agreement and Truth !n Le ii my sure
Disclo (continued)
7. FINANCE CHARGES - `eou can avol0 the F anre Ch :rge on p r& .es
paying ire full articunl o' the Nov, Balanco of Purchases each month within 17 days
s
of your statement closing date. Otherwise, the Ne Bra ono-: Cl PLJ?hases. and role
subsequent purchases from the dale they are posted to vour acco_ tit. vast. be sabtect
to Finance Charge. Cash advances are always scblect V) Fir Since Chargo irpnt th^
date they are posted to your scco!,nt.
Purchases: We calculate your finance charge by r*1u11 ,^.iy:r:g the average adiusled
gaily balance (see explanation below), rrclud:ng new purchases, for The billing cycle
by l-e 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 (seo explana6cin below) !of cash
advances during the baling cycle by the rimcntnly periodic advance rate any
corresponding ANNUAL PERCENTAGE RATE as d sc,osed on Ilia Ad?:!encluni
Balance Computation Method
Average Dairy Balance for Purchases • The Average Daily Balance for Purchase
Transactions is calculated by adding the Daily Balances tPurchase 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 purchases each day. we take the following
steps: We take the outstanding balance (all amounts you owe) at the $fail of the day.
Then, in the sequence in which amounts are posted to your account, we acid 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 Laie 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 Daily 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 thoreifore not subject to the monthly periodic rate for purchases. The
Average Daily Balance is calculated separately tot Cash Advances and is subject to the
Cash Advance Monthly Periodc Rate. The Average Daily Balance for Cash Transactions
is calculated by adding the Daily Balances (Cash Transaction) for each day in the brlfing
cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily
Balance for cash each day, we take me following steps. We take the outstanding balance
(an 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 baling cycle, This gives us the Daily
Balance for Cash Advance Transactions. Note: Cash Advances are always subject to
finance charges and from the day they are posted to your account.
Payments are applied in the following manner: first to previous late tees, then to
previous cash advances finance charges, then to previous purchase finance
charges, then to current late fees, then to previous cash advance 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 lype of debt which is being credhod, if any. and then
to the balance of your account.
Noto also that it the 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 oxceeds 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 if you tail to snake any Minimum Payment within
25 days after your monthly statement closing date. You authorize us to transfer funds
iI
sufficient to make the minirnurn payment due it your Visa loan is in default. You Will
also be in default if your ability to repay uS is materially reduced by a change in your
employment, an increase iii your obligations, bankruptcy or insolvency proceedings
involving you, your death or your failure to abide by this Agreement or if trio value of
our security irderest materially declares. We have the riclllt to demand immediate
payment of your full account balance if you oefaut!, subject to our giving you any
notice required by law. To the extent permitted by la.V, you will also oe required to pay
our collection expenses, including court costs and reasonable attorney fees
9. USING THE CARD - To make a purchase of cash advance, tnom are two
a:ternative procedures to ee followed. One is for you to riresen! the card to a
participatng Visa plan mcich'ant, or arioiFler foaricial instltUCon, and Sign the Sailes
or cash advance draft whim will be imps ntecl with your card. The other is to complete
the transaction by usirg ycur Personal Identification N,mber (PItJ) in conroncton
an the card in an Automates Teller Machine or other type e! electronic tarnanaI that
provides access to the visa system. You agree that you will no: use your card tot any
transaction Thal is illegal under applicable federal. stale. or local iaw. Ire monthly
statement will identify ire merchant. electronic rerminal or financial ^Stl?Ution et
which transac lions were made. but Sale, cash advance, Credo or other 56ps cann0!
^:e retur rod .: iIr, the ,aiteni enl You :ar i cci: ;f it _ch ps !uirl!s •d ....!K•
i :true el the !ran6 _tiorl n c:u7er h;` !Cnty„r,(. ..-.,i t, y s',ateri ,il 1''? j,&cw un,r.n ma;'
-nali:- a reasonable 11virge 'or I,rrato . ir:e<. I sips iou ° -y ie ;',r••.!
? I 10. OVERDRAFT OPTION - If you t•,ect» rcro!a!• to you P°c 7 V s-1 Credit
Card. mat election is subject io the ex3ung cre0 , limit and !ne agreemc_ ?.1 it represents
and the current loan policy at t,e. brit,? of !ne overorafl. Yoi also understand that an
overdraft will be cons:dereo the same as a cash advance on your PSECU Visa Credo
Carl and trial the current Annua. Percentage Rate for cash advances will apply.
11. RETURNS AND ADJUSTMENTS - Merchants and afherS who nonor tho cart'
may give credit for returns and adjustments, and they wit do so by serdrig vs if
credit Slip wruch we will post to your Visa line cl credit It your credit and payments
exceed wrist you 0•h'e us, we will automatically post the e•xcr-s Credit balance to
your S1 Shares within 75 says. If the balance is one ciollar or more, upon your
written request. we will refund the credi! b,rance to you
12. FOREIGN TRANSACTIONS - The exchange rate uetween the transaction
currency and the billing currency used for processing international transactions is it 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 government-mandalod rate in effect for the applicable central processing
date. In each instance, an adjustment may be assessed based on the ISA fee imposed
by Visa. This foe, which totals 1% of the transaction amount, will be. assessed on all
transactions where the merchant country di`ters from file country of fire card issuer.
13. SPECIAL RULES FOR VISA PURCHASES - If you disagree or find an error
with a Visa transaction, and have tried in good faith to correct the problem with the
merchant or the charges are the result of unauthonzed 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 home. contact PSECU.
14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing
within 60 days following the date on wilier, we sent your statement wherein the error
or problem first appeared regarding any discrepancy or unauthorized transaction on
i your account. Telephoning PSECU does not preserve your dispute rights. You may
be required to provide us with dor_-imentetion 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 haudutont card use, PSECU will also require a
notarized affidavit. In some cases we may ask you to notify the local authorities
If we do 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 fimeframes 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 i
payments in the manner described in the Monthly Payment section. With respect to i
this account only, we will not assert any statutory right we may nave if you are in I
default to proven? withdrawal of your unpledged credit union shares (Deposits)
below the unpaid balance of your account. However, if you give or have given us a i
specific pledge of your credit union shares (Deposits) by signing the Pledge of
Shares or otherwise. or any other security interests Tor all your debts, your account
will be secured by your pledged shares (Deposits) and by the property descritTied in =
those other security agreements, except lot your home.
18. EFFECT OF AGREEMENT - This Agreement is the contract which applies to ?
all transactions on your account even though the sales. cash advance, credit or 1
other slips you sign or receive may contain different terms We may amend the I
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 Iransaclions.
17. LATE PAYMENT CHARGE - If your Minimum Payment is riot received by the
first day of the month following your due date, you viii be subject to a S20 charge.
18. RUSH FEES - YOU may incur additional charges lot rush processing and rush
delivery of cards andior PIN mailer.
19. OVER LIMIT FEE -A S20 tee will be atrpi:ad for each monthly statement dosing crate
on which the outstanding balance excoeds trio ass,gneo crooiT limit lily more than S IW
20. DRAFT COPIES - You may incur an a idrfioral charge for transaction
summary/sale draft dOCUmentation.
21. COPY RECEIVED - You acknoo;Ircige ieceip! cif a cosy of Bus Agreement
22. ILLEGAL TRANSACTIONS PROHIBITED - You agrt,e that pu w.!I riot use
your card for any transacuon that is illegal under aFp!icabte federal. state. or +oral raw
23. NO USE - InacEve visa accounts trial have no purclaue or c;;;!i activir_; may
be closed .without notce to you after 18 rcriths of to act•,Ity.
24. NEURAL NETWORK - PSECJ uses Cenral network systems to predict and
prevent unauthorised Transactions 1'nure may t•o occas)-nll, vni,n =: iransaci,on i&
declined because it is i.ndicalive of possih'e !rawdulerl ac!i:•ny
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CASE NO: 2008-07300 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE EMPLOYEES
VS
SHANABROUGH MATTHEW A
TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SHANABROUGH MATTHEW A the
DEFENDANT
at 1810:00 HOURS, on the 5th day of January , 2009
at 206 9TH STREET
NEW CUMBERLAND, PA 17070-1609
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 15.30
Affidavit .00 ,•
Surcharge 10.00 R. Thomas Kline
.00
43.30 01/06/2009
VAN ECK & VAN ECK
Sworn and Subscibed to By: y-- ??
before me this day Dep y Sher' f
of A.D.
r-.a
c
L
+JJ
?J f
.• ?1J' rA'i
PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS
CREDIT UNION, : CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
NO. 08-7300 Civil Term
VS.
MATTHEW A SHANABROUGH
Defendant CIVIL ACTION -LAW
PRAECIPE FOR JUDGMENT
Enter Judgment in favor of Plaintiff and against Defendant, Matthew A Shanabrough for
want of ANSWER TO COMPLAINT.
(X) Assess damages as follows:
Debt -----------------------------------------------------------------$7,171.72
Attorney's Commission ------------------------------------------- $1,459.34
Filing costs ---------------------------------------------------------- $to be determined
TOTAL --------------------------------------------------------------58,631.06 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.
V /gyp
DATE: ? Signature: 4 '
lit
Melissa Van Eck, Esquire
Attorney for Plaintiff
7810 Allentown Blvd., Suite B, Hbg., PA 17112
(717) 540-5406
ID#: 85869
NOW, 2009, JUDGMENT IS ENTE D AS ABOVE.
17,
P othonot r Civil Division
By:
Deputy
Document #: 180057.1
PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS
CREDIT UNION, : CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
NO. 08-7300 Civil Term
VS. .
MATTHEW A SHANABROUGH
Defendant CIVIL ACTION -LAW
TO: MATTHEW A SHANABROUGH
206 9th Street
New Cumberland, PA 17070-1609
DATE OF NOTICE: January 27, 2009
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
I
By:
Melissa L. Van Eck, Esquire
Attorney I.D. No. 85869
P.O. Box 6662
Harrisburg, PA 17112
717.540.5406
Attorney for Plaintiff
? a
PENNSYLVANIA STATE EMPLOYEES:
CREDIT UNION,
Plaintiff
VS.
MATTHEW A SHANABROUGH
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-7300 Civil Term
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,
VAN ECK & VAN ECK, P.C.
Date: February 10, 2009
By: I IS19A tAW VA
Melissa L. Van Eck, Esquire
Attorney I.D. No. 85869
Henry W. Van Eck, Esquire
Attorney I.D. 83087
P.O. Box 6662
Harrisburg, PA 17112
(717) 540-5406
Attorneys for Plaintiff
Document #: 180057.1
W
PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS
CREDIT UNION, CUMBERLAND COUNTY,
: PENNSYLVANA4,
Plaintiff
NO. 08-7300 Civil Term
VS.
MATTHEW A SHANABROUGH
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, Matthew A Shanabrough, above named, is not a
corporation and is not 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: L:1W v
Henry W. 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 Tday
of February 09
Not Public
AL
ECK
iic
UMaN2 OUNTM
Document 4: 180057.1
Em;j
Co
f
PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS
CREDIT UNION, CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
NO. 08-7300 Civil Term
VS.
MATTHEW A SHANABROUGH
Defendant CIVIL ACTION -LAW
TO: Matthew A Shanabrough, Defendant
You are hereby notified that on a /? I09 , the following
(Or-de (Degree) (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 $8,631.06 plus
costs is hereby entered.
DATE:
?'?r?JqL
P thonot
I hereby certify that the name and address of the proper person(s) to receive this notice is:
Matthew A Shanabrough
206 9th Street
New Cumberland, PA 17070-1609
A: Matthew A Shanabrough, Defendant, Defendido/a (Defendidos/as)
Por este medio se le esta notificando que el
del
de
el/la siguiente (Ord) (Deerete)
(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Prothonotario
Certifico que la siguiente direccion es la del defendido/a Begun indicada en el certificado
de residencia:
Matthew A Shanabrough
206 9th Street
New Cumberland, PA 17070-1609
Document #: 180057.1