HomeMy WebLinkAbout08-7513IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION
Plaintiff
No. 4!?G _ "js a
(2"A'-?
vs.
COURTNEY BRADLEY
AKA COURTNEY C BRADLEY
Defendant
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,
P.A.I.D.# 42524
Weltman,Weinberg & Reis Co.,L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412)434-7955
Fax: 412-338-7130
WWR#7057515
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION
Plaintiff
vs. Civil Action No.
COURTNEY BRADLEY
AKA COURTNEY C BRADLEY
Defendant
COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the court without further notice for
any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may
lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff is a corporation having offices in P.O.BOX 67013 HARRISBURG, PA 17106-
0000.
2. Defendant is an adult individual residing at 405 N BALTIMORE AVE#3
MT HOLLY SPGS,PA 17065.
3. On or about SEPTEMBER 15 2004, Defendant duly executed a ADVANCE PROCEEDS
VOUCHER SECURITY AGREEMENT (hereinafter the "Contract") in favor of BOBBY RAHAL
HONDA, a true and correct copy of said Contract is attached hereto, marked as Exhibit "1" and made a
part hereof.
4. Pursuant to said Contract, Defendant took possession of the vehicle more particularly
identified in the Contract as a 2002 HONDA ACCORD.
5. Pursuant to the terms and conditions provided by the Contract, the Contract was assigned
from BOBBY RAHAL HONDA to Plaintiff.
6. Plaintiff avers that Defendant is in default of the Contract by having not made payment to
Plaintiff as promised, thereby rendering the entire balance immediately due and payable.
7. Plaintiff avers that a balance of $6,346.93 is due from Defendant as of NOVEMBER 7
2008.
8. Plaintiff avers that the Contract between the parties provides that Plaintiff is entitled to
interest at the rate of 5.49% per annum.
9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay the principal balance, interest or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant, COURTNEY BRADLEY AKA
COURTNEY C BRADLEY , individually, in the amount of $ 6,346.93 with continuing interest thereon
at the Contract rate of 5.49% per annum from NOVEMBER 7 2008 and costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL BE USED FOR THAT PURPOSE.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
James C. brodt,
P.A.I.D.# 2 24
berg & Reis Co.,L.P.A.
436 Sevenue, Suite 1400
Pittsb 15219
Weltm)-338-7130
(412) Fax: WWR#:7057515
ADVANCE PROCEEDS VOUCHER
AND SECURITY AGREEMtNT
Pennsylvania State
Employees Credit Union
V P. O. Box 67013
PSE(O
Harrisburg, PA 17106-7013
(717) 234-8484
the financial iinkTM (800) 237-7328
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p.{V•. ?n1!t.4 r1.4,1?2/Y?I Irv.']. v...H?.•t k 'ems\ a:.n?01'?,C. ?
sa}.2i :.1..
COURTNEY BRADLEY 9/15/200 8102036434 / L10 409632
7
1864 WALNUT BOTTON RD
P1"bealer Purchase
NEWVILLE, PA 17241
TRANSWTM -END
TYPE 1. ? NEW LOAN 2. OAN ADVANCE 3. ? (0E3DRtSE) 4.0 HEOURY ADVANCE
YOU HAVE PREVIOUSLY ELECTED To HAVE THIS ADVANCE CREDIT DISABILITY?^? SINGLE CREDIT LIFE X JONT CREDIT LIFE X
' YES El NO ? YES El NO ?
? No
L_i
INSURED WITH THE FOLLOWMIO COVERAGE YES
DAILY PERIODxi RATE ANNUAL PER- INTEREST RATE IS AMOUNT REQUESTED AMOIINTAUAQ C? ; PREVIOUS BALANCE NEW BALANCE
(CHANGE IN TERMS ONLY) t'iENTAGE RATE CEO VARIABLE +OMER CHARGES
+
18,678. 0.00 18,678.40
90
.015041 5.4
% CT El
PAYMENT DUE DATE PAYMENT FREQUENCY PROJECTED LOAN TERM
L 305.08 10/15/2004 MONTHLY
ADVANCE, THE OAKYSEMI TY FOR THIS ADVANCE IS THE REAL PROPERTY ON MOSrCASES YOUR HOME) WNIOHYOU GAvE AS SECURITY WHEN YOUR ACCOUNT
NUM"
WAS
N mOT A HOME EOURY ADVANCE, N ADOMON TD THE PLEDGE OF SHARES IN YOUR LOANUNER• CREDIT AGREEMENT. THE FOLLDWING PROPERTY SECURES TNIS ADW+NCE
IFTHIs EBA
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ITEM PROPERTY.::. :v ? ? :e •-z.. ' ?<:? =.w; . _ ` , . • •• ?:_ '? :LBi ??.X
.2002 «1HGCG16512A05649 SDN 18,900.00
1. HONDA ACCORD
2.
a
4. OTHER
YOU PLEDGE SHARES MIDIOR DEPOSITS OF $ N ACCOUNT NUMBER
0L0 A000UNTA.D N NUMSEA (A PAYOFF RN M+ INL Ol O ACCOUNTAAAN NUMBER R4YOFF (PRINC.+ NT. OLD ACCOl1NTA.0AN NUMBER C) PAYOFF (PRNC. + NT
OLD ACCOUNTADAN NUMBER PAYOFF PRIND.+INT OLD ACCOUNTA-OIIN NUMBER PAYOFF PRMIC.+I OLD A(xOUNTAAV?N NUMBER PAYOFF PAINC +INT)
By accepting the proceeds or by using the funds advanced and deposited into your shar"hare draft account, you agree (1) that the property referenced above
n) and
ceive In the future under the LOANUNER' Credit and security Agreement (
th
will secure the advance and any other advances you have now or re
in
l
ed ab
ou owe us for any reason now or In the future to accordance with the terms of the Plan and (2) to make payments
t
s y
any other amoun
---- ---.....al.-+e-...e M 1hn Plan
O CUM MUTUAL GRW 1900.02.84.08.08.90.99.2088.04, 04. ALt BMM RE$UM
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM 03175 JV)=100.1 037-208¢-1 (404)
# 6(jkDP0
Pennsylvania State Employees Credit Union
PSECO
Yin financial lf7l 4 Loan Disclosures
This LQANI_INERF Credit and Security Agreement :vhich irc.,des the T u!-, jr. I ir,teresw on v e enure ,a! a:,ce. if you elect credit :nsurance, your payments may
tending Disclosures, will be referred to n the Plan. The Plan doc.,morts incl,ide :his I increase or :rue ccriod of !irr,c nccess-ary to rr:-ay your advance may be ez'erned
agreement and an Adderdurn You, your and borrower mean any person :v!,c signs Tr e credii r:su- nce cafes r:ay change crurirn: inc P'an. If the wales e:' a;.ge, ae ,v
tr'e P+a n. Credit union, we, our and us r^.ean PSFCU or anyone to w`nr- the Credit provide any r:otices requires by applicable law:.
Union trars`ers its riglds under the Plan. PERIODIC STATEMENT - On a rer,,.!ar basis epu :vtil receive a statemerif sh:iw no
HOW THIS PLAN WORKS - This is an open-end, rn:itweatured credit plan We all trarsactfons i.nder the Piar) Ourt,g the Ceriod 00:ered Ly the statement.
antc+pate that, !ram time to time, you • ii:l borrow money (called "advances'') under Statements and notices w,ii be sent in you Lt ine coos; recent adcres.s you hate
-e Pian. We are not required to make advances to you under the Plan and can f given us in •rrrihrg. Uniess ap !icab!e taw re:;,,ires notice to eact•. jo+nl hcroater,
refuse a request for an advance at any time. The Addendum descnbeS the i notice to any one of you wiG be notice to all.
different types of credit (caned "subaccounts") available under the P!ar., the current JOINT ACCOUNTS - if this is a joint account. each of you is individually and lo:nt'y
interest rate for each subaccount expressed as a daily periodic rate and responsible for paying all amounts owea. That means eve can enforce our rights
correspordino annual percentage rate and other charges. It may also have ether { under the Plan against any one of you individually or against all of you together, if you
terms and a schedule for determining the payment amounts, give us inconsistent instructions, we can refuse to follow your instructions. Unless cur
CREDIT LIMIT - We may, but CIO not have to, establish a credit !imit on certain j written policy requires all of you to sign fcr an advance, each of you authorizes the
subaccourts. It a credit limit is set for a subaccount, you promise not to exceed the 1 other(s) to obtain advances individually and agrees to repay advances made to the
established credit limit. If you exceed the credit limit, you promise to repay I other(s), Any joint accourtholder may terminate the Plan by giving us prior written
immediately the amount which exceeds the credit limit, notice. If any of you terminate the Plan, the Plan is terminated for all of you. You
REPAYMENT - You promise to repay all amounts you owe under the P°an plus remain fiabie individually and jointly for all advances incurred before termination,
interest. Payments are due on the last day of the month unless we set a different day FEES AND CHARGES - if you give us a securty interest in certain types of
at the time of an advance. If the Addendum has no payment schedule for a property, we may charge you a filing fee tc pe-fect our interest in the property. If we
subaccouet, your payment will be determined at the time of each advance. do, the amount of the fee will be disclosed to you at the time you obtain an advance.
Payments must include any amount past due and any amount by which you have We may also charge you other fees in connection with the Plan. Our current fees are
exceeded any credit limit you have been given for a subaccount You may repay ail disclosed on the Addendum and will be added to your loan balance unless you pay
or part of -what you owe at any time without any prepayment penalty. Even if you them in cash.
prepay, you will still be required to make the regularly scheduled payments unless UPDATING CREDIT INFORMATION - You promise that you will promptly give us
we agree in vrriting to a 'change in the payment schedule. It you have a joint I written notice if you move, change your name or employment, or if any other
sharedraft account, you will be responsible for paying all overdraft advances information you provided to us changes. Upon our request, you also agree to
obtained by a joint holder of the sharedraft account, Unless otherwise required by provide us updated financial information.
law, payments will be applied to amounts owed under the Plan, in the manner the
Credit Union chooses. DEFAULT - The following paragraph applies to borrowers in Idaho, Kansas,
PLAN ACCESS - You can obtain credit advances in any manner authorized by us. if Maine and South Carolina: You will be in default if you do not make a payment of
we allow you to use your ATM; Debit card to access the Plan, you may be fiable for the the amount required when it is due. You will also be in default lt we believe the
unauthorized use of your ATM/Debit card. You will not be liable for unauthorized use prospect of payment, performance, or realization on any property given as security
that occurs after you notify us, orally or in writing, of the loss, theft, or possible is significantly impaired.
unauthorized use. If you believe your ATMJDebit card has been test or stolen, The following paragraph applies only to borrowers in Wisconsin: You will be in
immediately inform the Credit Union by calling or writing us at the telephone number or default if you fail to make a payment when due two times during any 12 month
address that appears elsewhere in the Plan. If the card is used to obtain unauthorized period. You will be in default it breaking any promise made under the Plan materially
advances directly from the Plan, your liability will not exceed $50. If the unauthorized impairs your ability to repay what you owe or materially impairs the condition, value,
withdrawal is from a sharedraft account, your liability is governed by the Regulation E or'protection of or our right in any property you gave as security
disclosures you received at the time you received your ATM/Debit card, even it the The following paragraph applies only to borrowers in Iowa: You will be in
wdhdrawaf results in an advance being made from your overdraft subaccouet default if you are more than 10 days late in making a payment. You will also be in
FINANCE CHARGE - The dollar amount you pay for money borrowed is called a default ff you do not comply with the terms c:` the Plan and your failure to comply
"finance charge" and begins on the date of each advance. A finance charge will be materially impairs any property you gave as security or your ability to repay what you
computed separately for each separate balance under the Plan. To compute the owe under the Plan.
finance charge, the unpaid balance for each day since your last payment for since The following paragraph applies to borrowers In all other states: You will be in
an advance if you have not yet made a payment) is multiplied by the applicable daily default it you do not make a payment of the amount required when it is due. You will
periodic rate. The sum of these amounts is the finance charge owed. The balance be in default if you break any promise you made under the Plan or if anyone is In
used to compute the finance charge is the unpaid balance each day after payments f default under any security agreement made in connection with an advance under
and credits to that ba!ance have been subtracted and any additions to the balance ; the Plan,. You will be in default if you die, file for bankruptcy, become insolvent, if you
have been made. In addition to interest, we may charge other finance charges which make any false or misleading statements in any credit application or update of credit
are disclosed on the Addendum. It the interest rate is a variable interest rate, the information, or it something happens we believe may substantially reduce your
Addendum explains how the variable interest rate works. ability to repay what you owe. You will be in default if any property you have given
SECURITY - You pledge as security for the Plan all shares and dividends and, if us as security is repossessed by someone else. seized under a forfeiture or similar
any, all deposits and interest in all joint and individual accounts you have with us law. or tt anything else happens that significantly affects the value of the property or
now and in the future. If a specific dollar amount is pledged for an advance, we will I our security interest in it. You will also be in default under the Plan if you are in default
freeze shares in that account to the extent of the outstanding balance for the under any other loan agreement with us.
advance. Otherwise, your pledged shares may be withdrawn unless you are in i ACTIONS AFTER DEFAULT- The following paragraph applies to borrowers In
default. The following paragraph applies in all states except in Ohio, Rhode Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri,
Island and Massachusetts: We have a statutory lien on the shares and dividends f Nebraska, South Carolina and West Virginia. When you are in default and after
and, ii any, the deposits and interest in al! individual and joint accounts you have with t expiration of any right you have under applicable state lay: to cure your default, we can
us and may exercise our rights under the lien to the extent permitted by state law. demand immediate payment of the entire unoaid balance under the Plan without I
('.Ne are state chartered if our name does not include the term "Federal Credit ;giving you advance notice
Union") For all borrowers: The statutory lien and/or your pledge will allow us
to apply the funds in your account(s) to what you owe when you are in default. The following paragraph applies to borrowers in all other states except Wisconsin
The statutory lien and your pledge do not apply to any Individual Retirement and Louisiana. When you are ir, default, we can require immediate payment
Account or any other account that would lose special tax treatment under stale or (acceleration) of the entire unpaid balance under the Plan. You waive any right you have
federal law if given as security. to demand for payment, notice of intent to accelerate and notice of acceleration.
Additional security for the Plan may be required at the time of an advance. if a The following paragraphs apply to borrowers in all states except Wisconsin and
subaccount identifies a type of property (such as "New Cars") you must give that Louisiana: It immediate payment is demanded, you will continue to pay interest until
type of property as security when you get an advance under that subaccount. A what you owe has peen repaid at the applicable interest rases in effect or, i' applicable,
subaccount name such as 'Other Secured" means you must provide security at the default rate disclosed or the Addendum if a demand for immediate payment
acceptable to us when you obtain an advance under that subaccount. Property you has been made, your shares ardor deposits can be -applied towards what you owe
give as security will secure all amounts owed under the Plan and at) other loans you as provided in the section above called "Security" We can a!so exercise any other
have :with ,;s nos or in the future. except any soar secured by your principal dwelling. rights given by law when you are in default.
Property securing other loans you have with us may also secure the Plan. You agree the Credit Union: has the right to mke possession p' any prooerty given
CREDIT INSURANCE - Credit life anaor credit disability insurance is optional as security under the Plan, without judicial p ocess, if this can be done without
.,rder the Plan if you quality fcr arc- purchase the insurance from us, you autherize , breach of the peace If we ask, you promise to delver the p•operty at a tame and
,s tc and Y7e :nsu,ance prem;ums rior.'h!y to your !oan balance and charge you place we chc:ose. If the pr.:,per-y is a motor vehicie or boat, you agree that vie may
FSEc-
LOANLINER Credit and Secure i, (re cif Agreement (continued)
! G ct"c' n r'r 1 ., .. i
a..,.. ::i . n be res ;n, deg !- a.r•
13r_ _mc:., •ha! vc": leave lns:r._ the rr_. r C-.C r2 cr
r .7 ^ that :rr,-rady (nr y. .
_-iE F. . _ sse si r oft he F ' err - 1 ;_i' ?t zr d app -: s d %e `Ne !'i g ,e y u r :r? t1 f s, r orlon r`
err r p.ivn!e csposi?;., wil ae r ..Id Ou t. lion ses .er t34i r , c r c l!
l:i'tq the ,rocerty .vill be cjeau_tec fr;rr tic' r,c-y r cc f m r = s
_rs+ y< y incl J ll' ccS ifs ;ring :he rr rt: ).e tr,ria t ter k r. ey
Y Extent parmir J wl"jr S- ate 'a'.L f - ,t a'dF.d and ..r tnt. B'* `k { 1 ry Cod
lou r ,...t gay any amount the. remains unba a a,r:r the sale wooev has e a,?!
arty unpaid balance under the Plan. Ycu agree tc pay merest On that amount at th
.
same rate as the advance, or, if applicable at :he :lefault rats: disclosed on th
Addendum, until that atr'.ount has teen paid.
The following paragraph applies only to Wisconsin borrowers: Whet'r Y'_ Li are :
Oefauit and after expiration of any right you have under applicable slate taw to cure vcc
efault, we may require immediate payment of your outstanding loan balance under to
I Ran and seek possession of property given as security. You may voluntarily give t
1 property to us if you choose, or we may seek to take possession of the property
judicial process. If we repossess the property, you agree to pay reasonable experts
incurred in disposing of the property. If the property is a motor vehicle, mobile hom
trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitta
by Section 422.413 of the Wisconsin Statutes You must pay any amount that remain
unpaid after the sale money has been applied to :what you owe under the Plan. Y_
agree to pay interest on any unpaid amount at the same rate as the advance, or,
applicable, at the default rate disclosed on the Addendum, until that amount is paid.
It the property a located outside Wisconsin at the time of default, wo may to
possession of the property without judicial prc :ess. it permitted by the stale who
^e property is located.
The following paragraph applies only to Louisiana borrowers: When, you are
defau3, we can require immediate payment (acceleration) of the entire unpa
balance under the Plan. You waive any right you have to demand for paymert, optic
of intent to accelerate and notice of acceleration. It immediate payment
demanded, you will continue to pay interest until what you owe has been repaid
I the applicable interest rates in effect unless a default rate is disclosed on t
.Addendum. If a demand for immediate payment has been made, the shares a
deposits given as security for the Plan can be applied towards what you owe.
can also exercise any other rights given by law when you are in default and o
rights under any security agreements you have with us.
CANCELLING OR CHANGING THE PLAN - The following paragraph appli
only to borrowers In Illinois: We have the right to change the terms of the Plan fro
time to time after giving you any advance notice required by law. Any change to tt
interest rate or other charges will apply to future advances.
The following paragraph applies only to borrowers In Wisconsin: We can
change the terms of the Plan from time to time in accordance with Section 422.41
of the Wisconsin Statutes. You will be notified of any change in terms. An Increa
' in the daily periodic rate under a variable rata interest rate is not considered
chance in terms under the Plan. We can cancel the entire Plan or any part of t
Plan at any tiome. You may cancel the Plan at any time by giving us prior writt
notice. Your obligation to pay the unpaid balances under the terms of the PI
continues whether you or the credit union cancel the Plan, except to the extent th
your Ijabtijty is limited by Section 422.4155 of the Wisconsin Statutes.
1 The following paragraph applies only to borrowers in Iowa: We can change t
terms of the Plan from time to time after giving you any advance notice required
law. A change that increases the rate of finance charge or other charge, th
increases the amount of your payments, or that otherwise adversely affects existi
balances will apply to existing balances only if you agree to the change or you Us
the Plan after receiving notice that your use of the Plan means you agree t
change applies to existing balances.
The following paragraph applies to borrowers In all other states: We nave t
right to change the terms of the Plan from time to time after giving you any advan
rottce required by law. Any change in the interest rate will apply to future advance
and at our discretion and subject to any requirements of applicable law, will al
apply to unpaid balances.
The following paragraph applies to all but Wisconsin borrowers: An increase
:he daily periodic rate under a variable interest rate is not considered a change
terms under the Plan. We can cancel the entire Plan or any part of the Plan at a
time. You may cancel the Plan. at any time by giving us prior written notice. Yo
obligation to pay the unpaid balances under the terms of the Plan continues wheth
you or the Credit Union cancel the Plan.
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can del
enforcing any of our rights under this Plan any number of times without losing t
ability to exercise our rights later. We can anforce this Plan against your heirs
legal representatives. If we change the terms of the Plan, you agree that this PI
will continue to protect us.
CONTINUED EFFECTIVENESS - It any part of this Plan is determined .y a court
to be unenforceable. the rest will remain in effect.
NOTICE TO UTAH BORROWERS - This :•: river agreemert is a fina; exrression
tr?e agreemenl between you and t`te Cred:*. Unio^. This written agreement may
be contradicted by evidence of any Oral agraement.
The following is required by Vermont law - NOTICE TO CO-SIGNER - YOU
SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIAB
FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PA
THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU.
The following paragraphs apply if you gi:e security in connection vr,fh an
advance under the Plan. They apply to borrcv:ers in all states except Louisiana
Louisiana borro:ers will execute a separate security agreement. Borrowers in
other states (nay also be asked to execute a separate security agreement.
THE SECURITY FOR THE FLAN - a
, n s •G
of rE?? PoE .C :! i l i E / ,.: , ..(' C 1 c _
a.:ccss n? .A rls h r: ? e • 1 -7 r y r , .y
:o..v or, in t. IJ,U'e ' ie .ecw;i it :,r i,2
r I _
prupe ty t,ch +r u : i v.t"Nil crvs cr 1hr +v :r e r, x . ,ion a _ s
s cr ref n :nc9ng c?f u n r. I' so ire u o an,, nJ y vc. re.,cive + o . li n:
(rue p r?,erjy 1( r m `Gal R.e ycU 'i3•:E J .iC^cr :he Vai,:B C• ?`e .. .:F•
o I declines, you pru,nise to g ,e us. m:;re prc,er-y as sec_,ny :1 asked to Co so
e WHATTHE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS
-The security interest secures the Advarr,-e descrieed in the receipt. voucher cr a^y 1
other document you receive at the time of :h ue Advance anc any ex:ensicrs. rene.:a!s
or refinancings of the Advance. It also secures any other advances you have now i
or receive in the future under the Plan and any other amounts or loans,
e I including any credit card loan, you owe us for any reason now or in the future,
he except any loan secured by your principal residence. If the property is househo'd
bq f goods as defined by the Federal Trade Commission Credit Practices Rule. the
e 3 property will secure only the Advance and not other arnounts you ave.
OWNERSHIP OF THE PROPERTY - You prom e trat you own ail cropary yo=!
s give as security cr if the Advarce is to buy the property, you promise you will tasty
u 1 the Advance for that purpose. You promise that rr, one else has any interest in ;,r
It claim against the property that you have rot e+iready told Us anOW. You promise not
to sell or lease the property or to use it as security for a loan Min another -rodjtor
ke until the Advance is repaid You promise you will aiow no other security interest or
re 1 lien to attach to the property either by your actions or by operation of law:.
PROPERTY INSURANCE, TAXES AND FEES - You must maintain property
in ! insurance on all property thatyeu give as security under the Plan.You may purchase
id the property insurance from anyone you choose who is acceptable to the Credit
1 Union. The amount and coverage of the property insurance must be acceptable to
s us. You may provide the property insurance through a policy you already have. cr
is through a policy' you get and pay for. You promise to make the insurance policy j
at ! payable to us and to deliver the policy or proof of coverage to us it asked to du so.
rid If you cancel your Insurance and get a refund, we have a right to the refund. If the !
Wa property is lost or damaged, we can use the insurance settlement to repair the 1
ur property or apply it towards what you owe. Y u authorize us to endorse any draft or '
check which may be payable to you in order or us to collect any refund or benefits
is due under your insurance policy. You also promise to pay all taxes and fees ;tike i
ni registration fees) due on the property.
may
ie If you do not pay the taxes or fees on the ptope!ny when due or keep t insured, we
pay these obligations, but we are not required to do so. Any money we spend tux taxes,
I fees or insurance will be added to the unpaid balance of the advance and you will pay
5 interest on those amounts at the same rate you agreed to pay an the advance. We may
se j receive payments in connection with the insurance from a company which provides the
insurance. We may monitor our bans for the purpose of determining whether you and
he ' other borrowers have compiled with the insurance requirements of our loan agrearrents
en or may engage others to do so. The insurance charge added to an advance may include
art (1) the insurance company's payments to us and (2) the cost of determining compfrar ce I
at with the insurance requirements. If we add amounts far taxes, fees or insurance to the i
unpaid balance of an advance, we may increase your payments to pay the amount s
he added within the term of the insurance or approximate term of the advance.
b INSURANCE NOTICE - If you do not purchase the required property insurance,
at y the insurance we may purchase and charge you for will cover only our interest in the
rig property. The premium for this insurance may be higher because the insurance
e company may have given us the right to purchase insurance after uninsured
rte collateral is lost or damaged. The insurance will not be liability insurance and
will not satisfy any state financial responsibility or no fault taws.
he PROTECTING THE SECURITY INTEREST - If your state issues a title for the
ce property, you promise to have our security interest shown on the title. We may have
s, to file what is called a financing statement to Protect our security' interest from the i
so claims of others. If asked to do so, you promise to sign a financing statement. "?Du
also promise to do whatever else we think is necessary to protect Our secu'ly
interest in the property. You promise to pay all costs, including but not limited to any
in I attorney lees, we incur in protecting our security interest and rights in the property.
in 1 to the extent permitted by applicable law.
Ur USE OF PROPERTY - Until the Advance his been paid off, you promise you will.
er (1) Use the property carefully and keep it n good repair, i_) Obtain our written
permission before making major changes to trio properly or changing the address
where the property is 'kept. (3) inform us in writing before changing your address. (4)
Allow us to inspect the property. (5) Promptly notify us if the property is clarnaCed.
he av stolen or abused. f6) Not use the pr. perty for any unla,.+ul puroosa. (', Not to rel;lle
n property in another state without telling us.
an
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 NCT RECE!V-D IN !
of THAT SALE, YOU tvlAY HAVE TO PAY THE 7:FFERENCE
not i y...,U
NOTICE FOR ARIZONA OWNERS OF PROPERTY - u' is nla:.;! +cr In tail
R to return a motor vehicle that is subject to a security interest, witnin thirr days after
i you have received notice of delau*t. The ice vriG be rnalled to the address you
LE gave us, it is your raspons:bifity to n.ot:ty us if your address changes. Tne maxirrurt
Y ` penalty for unlawful !allure to :e-urn a motor vehicle is one yr.•ar n prison an,7!;or a
fine of S150,000.
i
?BILUNG RIGWS KEEP T HIS, • FORFUTY0E Wt.
r
: r1i:ICe r: •a,rs :Tit Jrta In :.n ... :il.' ..e I Af' er'::C rflr .tU' ...a, ,.. .:... .. 'r•j 1,......-, J c. ?L' VUI. --
if, r..' FI .1? A.1. f)l w I at 1. r(! :r ly .. ,c1IF:'1 r y.U 1 .i : 1 (. f 1 J iU .- :r 'i __
?... ?,
nd _ . _.. d .. er ..• d v_ra„ C, ., ..•.... ..o:f •. ?..-.,_. t- .. u, _ . r r u-
NOTIFY US iN CASE OF ERRORS OR QUESTIONS ABOUT YOUR L c t nt. ( ,
STATEMtE1JT.:' yr..: ti . K . •r; :.r r r_:1 ..,. , i.,i n atinr,
t,, y l t
in - t a ansac",U" on j,ou _'at ?r v- i ut? r a scpara e 5 eet -t t ie arj ss
c o,
e `rd .ria i Li
rl> . O. 'ct.' statement YOU a t c•ily ..s rI writing L. ,tart OU a ays ,'.ance cr;.g__ .ela.!:d 1?, ",J!v Q.it-. etc c-i v.rrt .•f .l:•7 , rut...
1
'pl! ' :vie mate on JI h ':•u >r it iii'..r S -TrF \ :i cn tl e E rJr •r prr:t ri Pity havr__ t dJ -.^ In ?'. 'CJ 4 vn , l IPi'.'D ti t^ uG in y -n._-Sr-7
..rsi ppr_areC1 regarding 1n, cli cr? c'1 / t. T'aulh.,.t_ed tra no--,C ors on your ;3aym5",11S On tilE, ' qGC V d a , r. f- -,.?_,.. '.ti§ .ti•2 -. V6.: _. t
r
doC^u'hl. Failure to notify us may eau:: :r ')Jr acceptance of a^y report _:v !itr fur of the amid: ,. yDii cv e, hr., rr. _a ...I .:, I_ jJe.
CayrrEnt o-. reimbursement to us for an.., such error or discrepancy or your accoJ'? r..
•^ =;J Or you a 1E ngL.F :'
It .
you °aa i0 pay the r:C C + vrl •;e rip
,
'
`v`lrite to us as soon as DCsslbie. '-(cu can te!ephore Lis, but do:ng so wh nct to -is 'A iln ten :: v s ,
ou aril y^.., wr,T
However, if our expia •aton does rct sa I; s
preserve your rghts. telling us ;rat you stilt refuse to pay, we aius: ;ell anyone we report cu to that you
In your letter, give us the following information: I have a question about your statement. And, %e must tell you the name of anyone
eve reported you to We must teal anyone :ve r : rt ync to that the rna`-er has beer,
Your name and account nUrr,ber settled between us when it finally is. I
The dollar amount of the suspected error. Ne can't COI'ect t^e fist 550 of ire questored amoL rt
If we don't follow these rules
Describe the error and exolan, if you can, .why you believe there is an error. .
even it your statement was correct
If you need rt re intcrnaticn, describe tie i m you are not sure about. i SPECIAL RULE FOR CREDIT CARD PURCHASES - if ycu have a prot;em wth
If you have authorzed us to pay a credit card account automatically from your share the quality Of property or services that yr u ourch,ased with a credit card, and yeu
account or checking account, you can stop the payment on any amount you think is have tried in good faith to correct the problem with the merchant, you may have the
',wrong. To stop the payment your letter must reacn us three business days before the right not to pay the remaining amount due on the property or services. There are two
automatic payment is scheduled to occur, limitations on this right: (a) You trust have made the purchase in your home state or,
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR it not within your home state, within Wo miles of your current retailing address; and
WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we (b) The purchase price must have been more than S50. l
have corrected the error by then. Within 90 days, we must either correct the error or These limitations do not apply if we own or operate the merchant, or if we mailed i
explain why We believe the statement was correct. you the advertisement for the property or services.
In this Agreement, the words you and your means each and all of those who apply
for the card or who signs this Agreement. Card means the VISA Credit Card and any
duplicates and renewals we issue. Account means your VISA Credit Card Line of
Credit account with us. We, us, and ours means this Credit Union.
1. RESPONSIBILITY - if we issue you a card, you agree to repay all debts and the
Finance Charge arising from the use of the card and the card account. For example,
you are responsible for charges made by yourself, your spouse and minor children.
You are also responsible for charges made by anyone else to whom you give the
card, and this responsibility continues until the card is recovered. You cannot disclaim
responsibility by notifying us, but we will close the account for new transactions it you
so request and return all cards. Your obligation to pay the account balance continues
even though an agreement, divorce decree or other court judgment to which we are
not a party may direct you or one of the other persons responsible to pay the account,
2. LOST CARD NOTIFICATION - If you believe the card has been lost or stolen,
you will immediately call the Credit Union at (717) 234-8484 or (800) 237.7328. After
hours call (800) 556-5678.
3. LIABILITY FOR UNAUTHORIZED USE - You agree to notify us immediately,
orally or in writing of the loss, theft or unauthorized use of your Credit Card. You may
be liable for the unauthorized use of your Credit Card. You will not be liable for
unauthorized use that occurs after you notify us of the loss, theft, or possible
unauthorized use. You will have no liability for unauthorized purchases made with
your Credit Card, unless you are grossly negligent in the handling of your Card. In
any case, your liability will not exceed S50
4, CREDIT LINE - If we approve your application, we will establish a self-
replenishing Line of Credit for you and notify you of its amount when we issue the
card. You agree not to let the account balance exceed this approved Credit Line. Each
payment you make on the account will restore your Credit Line by the amount of the
payment which is applied to the principal. You may request an increase in your'Cred•R
Line only by written application to us, which must be approved by our credit committee
or loan officor. By giving you written notice we may reduce your Credit Line from time
to time, or with good cause, revoke your card and terminate this Agreement. Good
cause includes your failure to comply with this Agreement or any other agreement with
us, or our adverse reevaluation of your creditworthiness. You may also terminate this
Agreement at any time, but termination by either of us does not affect your obligation
to pay the account balance. The cards remain our properly and you must recover and
surrender to us all cards upon our request and upon termination of this Agreement.
5. CREDIT INFORMATION -You authorize us to investigate your credit standing
when opening, renewing or reviewing your account, and you authorize us to disclose
information regarding your account to credit bureaus and other creditors who inquire I
of us about your credit standing.
6. MONTHLY PAYMENT - We will mail you a statement every month showing your
Previous Balances of purchases and cash advances, the current transactions on your
account, tree remaining credit available under your Credit Lire, the New Balances of
purchases and cash advances- the Total New Balance, the Finance Charge due to date,
and any other billed fees, and the Minimum Payment required. Every month you must pay i
at feast the Minimum Payment within 25 days of your statement closing date. By separate
agreemert you may autnorize us to charge the minimum payment automatically to your
share or -necking account with us. You may, of course, pay more frequently, pay more
than the Minimum Payment, or pay the Total N•wv Balance in full. and you will reduce the
f.nance charge by doing so. If your monthly payment exceeds the total credit line balance ,
owed. we will autcnatical!y post the credit to your S1 shares.
The minirnum payment will be (al 2'6 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 Line, you must immediately pay the excess upon our
demand. We will apply payments in the following manner: first to previous late fees,
inen to previous cash advances finance charges, then to previous purchase finance
charges, then to current late fees, then to previous cash advance balances, then to
previous purchase balances In the order that they were posted to your account, then
to current cash advance balances, and then to current purchase balances.
7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by
paying the full amount of the New Balance of Purchases each month within 25 days
of your statement closing date Otherwise, the New Balance of Purchases, and the
subsequent purchases from the date they are posted to your account, will be subject
to Finance Charge. Cash advances are always subject to Finance Charge from the
date they are posted to your account,
Purchases: We calculate your finance char';e by multiplying the average adjusted
daily balance (see explanation below), includ!ng new purchases, for the billing cycle
by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE
RATE as disclosed on the Addendum.
I Cash Advances: We calculate your finance charge on cash advances by
multiplying the average adjusted daily balance (see explanation below) for cash
advances during the billing cycle by the monthly periodic advance rate and
corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum.
Balance Computation Method
Average Daily Balance for Purchases • The Average Daily Balance for Purchase
Transactions is calculated by adding the Daily Balances (Purchase Transaction) for
each day in the billing cycle, and then dividing by the number of days in the 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 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 arty Cash Advance transactions that posted to your account on that day or
l in any previous day in the billing cycle. This gives us the Daily Balance for purchases. '
Average Daly Balance for Cas'i Advances - Cash Advance Transactions which are
posted to your account are not included in the Average Daily Balance calculation for
purchases, and are therefore not subject to the monthly periodic rate for purchases The
Average Dairy Balance is calculated separately for Cash Advances and is subject to the ,
Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions
is calculated by adding the Daily Balances (Cash Transaction) for each day in the billing i
cycle, and then dRriding by the number of days in the billing cycle. To calculate the Daily
Balance for cast, each day we take the following, steps: We take the outstanding balance
(all amounts you owe) at the start of the day. Then, in the sequence in which amounts
are posted to your account, we add the amounts of all debits and subtract the amounts '
of all credits or payments which post to your account that day. Attar 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 o: in any previous day in the bang cycle. This gees us the Daily
Balance for Cash Advance Transactions. Note: Cash Advances are always subject to i
finance charges and from the day they are posted to your account
Payments are applied in the lo,lowing manner, first to previous late fees. then to
previous cash advances finance charges, tnen to previous purchase finance
charges, then to current late fees, teen tp previous cash advance valances then to
previous purchase balances in the ewer :hat tney'.:•ere posted to your account, tren
to current cash advance oalances. and tnen to current purchase baia.-ces. Crecf ,S
are applied firs: 1,3 The particular type o' oe.ht ::nicn :s being c,ediied. if any, and ir,-r•
to the balance of your ac.:ou^t.
Note also that if the total of ine payments -and creu!!s w^::Cn a•e posted TO you:
account by the Payment Due Date shown on a "aterner::s equal. to or exceeds the
New Balance shown on that statement, vve. viol riot appy the Monthly Periodic Rate
to your Account or yUur r•,r.xt statement
Q3 0
VISA' Credit Card Agreernenf and Trum i t Le.ndLr g Drs<tosure r ?nfn'u[;1!
f.i
8. DEFAULT r„u v.11 . < it," _h:- .: t
.; \,r ', l" .t c.... i .. =.
?_usLz?rio your ATM, G.i.. ,l,ce"_; I VISA ay'fr.l, ... .. •• - . .?
:.:r•e_ . ng :, . ck:ys You u4i also c . it i,:f2.. ! d ,.r at,? q t:, epay ,. .._ _. ;:c;e^
' fcrange:n your employment. ,?!1 "rrB;as' J yU'Jr CLS Jalp':-5.:, + ,•[C': bf;.»I'?•ncy
rcreedrngs rrvcwo-ry you. your oewn or'/O.. r atl ire Y. a_nice b•v is ]r:•r.•.r•.er or r ,hP
., !ue :,` cur security interest mWenally dcci:nes.'rie nave 1-ie rc_h to 5crn; d : m^ tia:8
Davrne"rit if your full account balance if you de47.urr. S.:bi: t to cur gr/.nc, r,u ,:"rr rauc:?
r.?gcted by :av:. To :he event e`er r tted b/ I v. ^: loll also he required n-aw (,w
C?;Iecncn e':-er5es, irciu ng court costs and r?asG,abl a"omey fe=es.
9. USING THE CARD - To ma,,- a D,rr_! ase or cash advance. t re 3r;
:':ernetive procedures to be fulloe:ed On? is for you :o Diesent trig Card in a
p.,rtic`.oating VISA plan merchant, or ancmer fsnarcia! institution, and sign the sans
or cash advance draft which vJil be Impnnted with your card. True other is tp ccmplete
the transaction by using your Personal Identification Number (PIN) ut. conjunction
kith the card in an Automated Teller Machine or other type of electronic terminal trial
provides access to the VISA system You agree that you will not use your card for any
transaction trial is i9egat under applicable lederai, state, or local lava. The monthly
statement will identify the merchant, electronic tarmral or finr_ncial insJT.iticn at
•,0ich transactions were made, but sale, cash advance, credit or other slips cannot
be returned with the statement. You will rstain a copy of such slips furnished at the
time of the transaction in order to verify the monthly statement. The Credit Union may
make a reasonable charge for photocopies of slips you may request.
10. 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 loan policy at the time of the overdraft. You also understand that at,,
overdraft will be considered the same as a cash advance on your PSECJ Visa Credit
Card and tll,d the current Annual Percentage Rate for cash advances will apply,
11. RETURNS AND ADJUSTMENTS -Merchants and others who honor the card
may give credit for returns and adjustments, and they will do so by sending us a credit
sip which we will post to your VISA line o` credit. If your credit and payments exceed
what you owe us, we wilt automatically post the excess credit balance to your S1
Shares within 75 days. If the balance is one dollar or more, upon your written request,
we will refund the credit balance to you,
12. FOREIGN TRANSACTIONS - Purchases and rash advances made in foreign
currencies will be billed to you in U.S. dollar. The conversion rate to dollars will be
made in accordance with the operating regulations for inter national transactions
established by VISA U.S.A.. Inc.
13. PLAN MERCHANT DISPUTES - We are not responsible for the refusal of any
plan merchant or financial institution to honor your card. We are subject to claims and
.... ,. _ .. ..-.._ ..-?_ . - .
.,c r.'_`,7,
r, _v-,n var.
Jt° h :ft,, A:- ,l 1c.. h;.._. ref t, .. 1,... to : ;
14. SECURITY INTEREST - ' r yc,r occur: you t us t
m;ccy ecu•:ty ^ ,.st _rncf_ e J for-i G:rnT Cede r .?
P .chase t ro_ic•,t`te acr_c_rl 4 you _ .. t. - :.I. : e noY; to •i % -:r.y '
these ^yoods 'lint t .:c ... vB rCl ..Id 'Gr J. our apoicat,in C v1.2-or
Payments in tine r;a ;her oaccr' eJ tine '.1.ortt!y ../ rent s_ ,,cr. 1'J -- es. ^ct tc
rh:s accourir only, :^%e v,tll not asserl any -.n•.:ivy vg*it Pn3 ?iy r :".e t` you are I'",
default to 'prevent w-ticirawal of 'rjCW urofcdced CrCr:t iX-7n S WES (DepoS;t p
below :he unpaid uaance cf y.-,:,r icccurr H_ sera if ,r:u g!ve or hay given us
specific pledge of your credit unw--.. shares (Deposttsi cy signing the Pl,:dca of
j Shares or cinerv!se, or ary other snuri,, interests for all your debts. your acco' r
will be secured by your'pledged shares (Dapo>ts) and cy the property cesc rib_1 u n
those other security agreements, except for Y,;,?.r
15. EFFECT OF AGREEMENT - This Acreerrent ;s the conimc: which applies t:)
all transactions on YOU accour,t eV-2n tricug!• the sales, cash advance, credit jr
other slips you sign or receive may contain a:ffervnt terms. `Ne may amend the
Agreement frorn time to time by sendirg you the advance written notice required 6y
law,. Your use of the card thereafter Witt indicate your agreement to the antendmen!s.
To the extent the law permits, and we indicate in our notice, amendments wil! apply
to your existing account balance as well as to future transactions.
16. LATE PAYMENT CHARGE - If 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.
17. RUSH FEES - You may incur additional charges for rush. processing and rush
deiiverv of cards anti PIN mailer.
18. OVER LIMIT FEE - A = fee waif be applied for each monthly statement cios;rvi date
on which the outstanding balance exceeds the assigne-d credit limit by more than 5100.
19. DRAFT COPIES - You may incur an additional charge for transaction
summaryrsale draft documentation,
20. COPY RECEIVED -You acknowledge receipt of a copy of this Agreement.
21. ILLEGAL TRANSACTIONS PROHIBITED-You agree that you wilt not use your
card for any transaction that is illegal under applicable federal. state, or ?oval taw.
22. 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.
23. NEURAL NETWORK - PSECU uses nr>ural netvork svsiems to predict and
prevent unauthorized transactions. There m4y be occasions when a transaction is
declined because it is indicative of possible fraudulent activity.
ATM CARD CARDHOLDER AGREEMENT - The Undersigned (you or your), in validates the directions given just as your actual signature and other proof Identify
consideration of THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION (ne, you and authenticate and validate your directions to a human teller. You also
our and us) issuing to you an ATM CARD, hereby agree to be legally bound by the understand that a Merchant which accepts the ATM CARD for a Purchase
following terms and conditions. You agree that the use of your ATM card(s) '. transaction may have an electronic terminal (Merchant operated or Seff-Seance)
'
constitutes acceptance of the terms and conditions of this Agreement. You s
which requires the use of your PIN and when your PIN is used at a Merchant
understand that ATM is a credit-related service and you authorize PSECU to obtain terminal, it will authenticate and validate the directions given just as your actual
a credit report on any users of this account. { signature will authenticate and validate your directions given to us. You acknowledge
1. ACCOUNTS AND USES OF ATM CARD - You have the account(s) (including 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).
Checking 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 I Therefore, YOU AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO
be used in connection with such accounts as described in this Agreement. ONE ELSE LEARNS YOUR PIN.
You understand you may use the ATM CARD at a STAR SYSTEMS@ ATM to (1) 3. LIABILITY FOR UNAUTHORIZED TRANSACTIONS -You agree to contact us
(2) make or arrange for deposits in, (3) effect transfers to or from
withdraw cash from at once if you believe the ATM CARD(S) issued to you or PIN has been lost or stolen
,
(4) receive information regarding the balance in your account(s) or (5)
your account or money is missing from your account(s). You also agree that it your monthly
,
make cash advances from your credit account(s) in the amounts you request. You may statement shows transactions which you did not make, and you do not contact us
also use automated teller machines throughout the United States and in certain within 60 days after the statement was mailed to you, you may not get any money
foreign countries which boar the PLUS SYSTEMO name and logo (1) to make lost after that time. YOU AGREE THAT IF YOU GIVE YOUR ATM CARD(s) and PIN
(2) effect transfers to or from, (3) receive information regarding the
withdrawals from TO SOMEONE ELSE TO USE YOU ARE AUTHORIZING THEM TO ACT ON YOUR
,
balances in your Checking or Regular shares. If you have a Personal Service Loan I BEHALF AND YOU WILL BE RESPONSIBLE FOR ANY USE OF THE CARD(s) BY
ou take no action to notify
ccount(s) if
the
i
l
l
ll
approved and in place, you may also rake a cash advance from your PSL.You further ;
understand you may use the ATfvl CARD to purchase goods and services
i y
n
your money
a
ose a
d
THEM. You cou
PSECU of the loss of y' our ATM CARD or FIN. Safeguard your Personal i
r
("Purohase`j at any retail establishment ("Merchant') where ATM CARDS are i ?
person. Do
identification Number (PIN). Do not tell or disclose your PIN to any othe
Do not loop a varitten record of your PIN near !
our ATM CARD
r PIN on
rt
accepted by such Merchant. It you use the ATM CARD to make a Purchase to obtain I
th
f .
y
e you
not w
your ATM CARD. Do not choose a PIN that is easily identifiab:e.
e ?
unds in
cash, i1 permitted by the Merchant, you shall be requesting us to withdraw
amount of such Purchase (including any cash received from the Merchant) from your A new card may be ordered for you at that tittle and a "nold' wi!i :;e paced on your
Checking Shares and directing or ordering us to pay such funds to the Merchant ( old card. After such time, if you find your rld rd d st.ov the old card tv u ::ng it
You request that we will proviae to you such other services or access to other ATM in "!alt. If you attempt Io use yc.,r old c2 rd vi no v k.
systems or networks using the ATM CARD which we may later make available and 4. CHARGES - You agree tc pay a 50, cent cnnrge or each depose o. wkndra,val
w'hicn we advise you are offered in connection with your account(s) set forth on your exceeding 15 a riontn. Yoe agree tc. pay ,he ' 0 cerr penalty charge on ary cash
application form. You also understand that from time to time you may request in i disbursement transaction (loan advance :;- share wltndr aw'alf tt`iai is less that, $20.
rriting that we provide access to adlitloral accounts of yours through :he ATM i You agree to pay a 25 cent charge on each G:'ance inq_, ray. You may incur a charge
CARD we have issued to you. You agree that the uses of the ATM CORD described ? for ary adjustment that needs to be .made to your account resulting f•om an error
it, this Agreement shall be subject to the rotes and regulations of each account you made while making a deposit a: an Automated Teller machire 1A7A1i. You agree
whic!': !s accessed by such Card. to pay the charges or :ransact:on tees wr.ich are cnarg ed ny is for these sarwcts ,
2. USE OF PERSONAL IDENTIFICATION NUMBER ("PIN") WITH ATM CARD or for services v,Nch may later ne o'erel as t;.:ch'ees ?- cnarges may oe ^Peseci
•'rn under-stand that a STAR S'r STEMS cr i PLUS SYSTEM A tut is an automated ' or changed from time to time
1 to le r It can and viii; perform many of the same tasks as a tturran teller. You 5. DEPOSITS - You agree t';-t omen you rnoln a dews:! it a STAR SYSTEMS
krovaedge that the Persona! Identifica:ion Number or PIN which you use w&. the
0 ATM that w'e have the r+3h b vet, ty r e efo e v e r ape the pored alac!e.
'
TM CARD is your signature. identifes the bearer of the Card to the STAR
i 1, v;u
to you. it you deliver tits , checks :npr t e is , S ,AR SYSTEMS A
ATM. PVJS SYSTEM .ATM, jr otner network ATM and autnentcates and
eSTENIS
I understand and acknowledge that , e .midi, f orr y u deposit may ncr e 3 ilab:a ,
Electronic Funds Transfer, ATP.1 Agrecment and ,Segu:Vion 'E' Disclosure SST- r -.- : ,- Ei .°
(continued)
.
n s r J J r'
t
' r
NIC FLNDS TRANSFERS OR FOR THE
ANY CHARGES FOR ELECTRONIC
6
, i :..
:•.. . I s .. s y..., ,i .. . ,. a. :... ; ., • ,. tie .. .
L',.1S A.rM that .. , u try' '.-f c. ,. ,.r t , ._;al !rStiL .?n. Y.nt t ; RIGHT TO MAKE TRANSFERS --
u-,d-. ?',,,_ and ac'<rox'cuyr: the not ail 5 "AF, S 'TE'AS ATI,.11; r'a't accepl ATM - Fifty cCt.: for r'.:cr, Jir -, :,.. „J.E:nc ass
•- ,.,,. t t.._. vat -n
s or'e AR SY3TE'•.1S AT,.iS ;Tar ':-'i• :re of f .,
f:.an S_.. , re-tts fJr e.c , Fc' 25 c:,r.t f:_'-r ea
.
L.. ds,. `.f•i-e..?.^. If","* :ve -'ay -7': t ..- t.,. .5-•Ilrr r--> t.%enc• ifl.!t.rry ,r1 fP be c :.harge :_r arty
.. ,
,.- ?r t 1 CAIi Ssu0 for rt ...•.
6 LIABILITY 1' t n:: f5 t t ' r. .t, a,cct:"! ..y e' ..akec ,:r err:,
.)„Er thi rV,S J J, A;jr 'net . and e ,._ er,. : tr;r
.
r. I_ r •. cN 1 "+11
_ch a_co.,r, You agree . ,at f you rr,_ e iFp s.ts ur payrnen s I-) you .can .isl ACH - 530 _erv:c argc ... ..sr:icier.: fun_,, for each electronic .rd. ,;. .
_^ s ether than cash 'checks, riraf;s or other items) and we make SST -nor,.:
rict e tr, yo.t `rom Such deposits 0!ior to th' -: r Cc! i icn. yocr oc,`rea ;hat v+e r-.-.y
7 SUMMARY OF CONSUMER`S RIGHT TD RECEIVE DOCUMENTATION OF '
.•?[foci the amounts nt funds tfGm your cCGO:: rd(51 tvhicr. are not collected or,
EFT'S -
if the funds in your account(s) are insufficient at such f.rne. yc.u will promptly pay M i
• ATM - You are entity:d ;o receive a prirte receipt at the ti e cif aeon
u, ,try amount of such funds which are not collected. transactor. You will receive a monthly s aten-Fnt showing the Sta;us of yeti
7. AMENDMENT OF THIS AGREEMENT - Ycu agree that from time to time :vr account, any transactions made during the month, and any pena;ties cr
may amend or charge the terms of this agreement including arnencirr•ents or charges PSECU tray lmpesa during the month.
;';antes to add further ATM CARD services cr to amend or change the charges for
these services. We may do so by notifying yc•u in writing of sucn arnendments or ACH and SST - You grill receive a rtton`niy statement showinq the status cf
changes and your use of the ATM CARD a her the eftecf've date of any such ! your account any transactions made du ng the month. and any penalties or
amendment or change shall constitute your acceptance of and agreement to such charges PSECU may impose dcring the month.
amendment or change • If you have arranged to have a direct deposit made to your account ai least
8. OWNERSHIP - You agree that the ATM CARD :s our properly and you grill once every 60 days from the same person cr company, you can call us at
surrender t to us upon our request. You agree Inat the ATM CARD is ron- (800) 237-7328 to find out whelher or nct the deposit has been made.
trar's.`erable 8. STOP PAYMENT RIGHTS - PRE-AUTHORIZED TRANSFERS -
9. DISCLOSURES -You hereby acknowledge receipt of the disclosure statement i • ATM and SST - Not applicable.
informing you of your rights under the Eiectrnic Funds Transfer Act and a copy of • ACH - Right to Stop Payment and Procedures for doing so. If you have told
this Agreement. us in advance to make regular payments out of your account, you can stop I
REGULATION "E" DISCLOSURE any of these payments. Here's how: Call us at (800) 237-7328 (Nationwide) '
i
ELECTRONIC CHECK CONVERSION/ELECTRONIC RETURNED CHECK II
1 or (717) 234.8484 (Harrisburg) or write us at: Pennsylvania State Employees
.
FEES - If you pay for something with a check or share draft, you may authorize it 1 Credit Union, P.O. Box 67413, Harrisburg, PA 1 71 06-701 3, in time for us to
to be converted to an electronic fund transfer, You may also authorize merchants to receive your request three business days or more before the payment is
electronically debit your account for returned check fees. You are considered to have scheduled to be made. li you call, we may also require you to put your request i
authorized these electronic funds transfers if you complete the transaction after j In writing and get it to us within 14 days after you call.
being told (orally or by a notice posted or sent to you) that the transfer may be I Notice of Varying Amounts. If these regular payments tray vary in amount,
processed elecironicafly or ii you sign a wrt en authgrization the person you are going to pay will tell you, 10 days before each payment,
SUMMARY OF CONSUMER LIABILITY -
2 when it 's'ill be made and how much d will be. You may choose instead to get i
. this notice only when the payment would differ by more than a certain amount
• and SST - Tell us at ortcea you believe your card has teen lost
ATM, ACH
us payment, gr whin the amount would tat[ outside certain
from
t
e
j
or stolen. Telephoning is the best way to keeo your possible losses down. You could
h
at , you s you set.
limits t.
lose all the money in your account plus your maximum overdraft line of credit. If you
Liability for Failure to Stop Payment of Preauthorized Transfers. if you
believe your card has been lost or stolen, and you tell us within two business days order us to stop one of these payments three business days or more before
after you learn of the foss or theft, you can lose no more than $50 if someone used the transfer is scheduled, and we do not do so, we will be liable for your losses
your card without your permission. or damages, unless we request and do not receive written confirmation of an
If you do riot tell us within two business days after you learn of the loss or theft of oral stop payment within 14 days and the transfer takes place after 14 days,
your card, and we can prove we could have stopped someone from using your card i or you fail to give us proper instructions that would enable us to place the stop
without your permission if you had told us, you could lose as much as $500. on the transfer,
Also, if your statement shows transfers that you did not make, tell us at once. If 9. SUMMARY OF THE FINANCIAL INSTITUTION'S FAILURE TO MAKE OR
vn;, do riot tell us within 60 days after the statement was mailed to you, you may STOP CERTAIN TRANSFERS -
not get back any money you lost after the 60 days if we can prove that we could
i
have stopped someone from taking the money if you had told us in time. ( n the correct
ATM - If PSECU fails to complete a transaction on time or
amount, when properly instructed by you, PSECU will be Ilab:e for damages
pod reason such as a Ion tai hospital sia kept u from teiiin us, we
If
g p or a y g
a gg caused by our failure unless: (1) there are insufficient funds in your account to
end the time periods.
will
t
ncollected;
the
(3)
are
u
in
your
account
the
funds
transfer;
(2)
a
e
the
. TELEPHONE NUMBER AND ADDRESS TO NOTIFY OF UNAUTHORIZED
3 ed
funds
r r
you u
exce
ed
would
funds er
equest
transaction
process;
legal
ess; (4
)
the
ra
subject to
TRANSFERS - the funds in your account plus any available overdraft protection; (5) the STAR
• ATM - Contact PSECU at (800) 237-7328 EXT 3808 (nationwide) or (717)
234.6464 (in Harrisburg). After hours, follow the menu options on PSECU's i ?
Systems, PLUS system has insufficient cash to complete the transaction; (6)
your card has been reported lost or stoier and you are using the reported card;
voice nail system to report a lost or stolen card. For VISA Credit or De-bir l (7) PSECU has reason to believe :hat the transaction requested is
Cards, follow the directions `:}r Lost Card Notification under the VISA Credit unauthorized; (8) the failure is due to an equipment breakdown that you know {
Card Agreement and Truth-in.-Lending Disclosures section of this document, about when you started the transaction at the STAR Systems, PLUS System; i
• ACH and SST - Contact PSECU at (800) 237.7328 (nationwide) or (717) ! (9) the failure was caused by an act of God, fire, or other catastrophe, or by any
j 234.6484 (in Harrisburg), other cause beyond control, (10) if you attempt to complete a transaction that,
at a STAR Systens, PLUS System, or merchant terminal that is not a
Or write tg us aft
permissible transaction listed above: or, (i 1) the transactorwould exceed the
Credit Union
Pennsvlvan:a State EmP1„yees securlty limitations on the use of your ATIA CARD.
RO Box 67013
• ACH and SST - if PSECU fails tc complete a transaction on time or in the
Harrisbur PA 17106-7013
g'
correct amount. when properly instructed by you, PSECU ,.Jil be liable for
PSECU Business Hours: damages caused by our failure unless. (1 ? there are ins2ficient funds ih your j
5:00 a.m. - 5:00 p.m. M - account tc complete the transfer. (2t ; .e furls m your account are
TDD 1800) 472-1967 Nat orwide uncolfectea: (3, the funds are s_ioject to egal process; (.:j the transaction you
7171 777-2140 in Harrisburg request would exceed the funds in yur acco_,nt plus any available overdraft
FINANCIAL INSTITUTION'S BUSINESS DAYS -
4 credit, (5) PSECU has reascr to belie,-e that ;Ce transaction recuested is
. (6i the fa lure was caused by an act o` Scd, fire r o t err
uaauthorr Fd
• ATM. ACH and SST - PSEC'J's B::sJr...ss Daye are Monday throu ; Frcay. ,
Jatast-nphe or by a rcher ause, lw ,r n :r I rv case PS r ch .
Hol'd_ays riot mcwced.
! e liable cr,!y ter ag ual proven ar _ r t outages if the f ilure
5. TYPES OF ELECTRONIC TRANSFERS A CONSUMER MAY MAKE - t, make the transaction resuae.: frz,.m a bar',,. f, e eiro despre PS=CU's
• ATM - Ba!ance ingd:ries nr cnect,inc, savings and PSL; withdrawals !tom procedures to avoid svch errc•s.
cneck ng.'savincis: cash aavancc from PSL deposit=_ to che"rtg'savings: 10. DISCLOSURE TO THIRD PARTIES -
pururase spoils arnd set?ces at arty acesPt r:g retail esiacfishment
-
ATIM, ACH and SST - PSECU v:ill ds is ae irrorr.aron acout your account t„
• ACH - P•eauthorized debits and cro:,d,rs io check ng and savincis.
. > t rd parties: (1 f when it is recess try t', c.,-cNe!e :rarsact ors i2) to ven,h; '
.. __. ---_.__
Electronic, Funds Transfer AT&I Agreement. and Regulation. °E" Disclosure
(continued)
F..1 _ r .. . J..,r ., 1 a_.' .... .^! :. .,. J l.?L,n ;7f
?]r 1'i. ?.. _,.. ecf: rA I.I .. ?Pl' _.Jv,-, c'..: r`
ra,.' i In aCCrraa".;:r yc:;r nc•tmissrln .,. r,r '.y IT
.,.? rr. nt cr adriints:r?iti•:e ay; suir norse_. oer cr ccuri
rders: I or. r ce pt 5' c ica'_T ir:m a PeJera, Ageocy G P- a r,;rreerI
'hat a rap'.:est for infor-nat'cn is in :vim`' :`'e :o Flna1ciNl
Privacy Act of 1 @; c: Reg laticti R Prn / o{ Ln FI ancia I i t r,r,
a?,c 17) when a is necessary in tar.a Ir =1 ar-trr recover s,..ras.
11. STAR SYSTEMS SERVICES -
• ATM Only -You may use your A. Tr1 CARD wrh your Personal Ident!ticeror
^Jur:her (PIN) at STAR SYSTE! Is '.stated in Delaware. t0aryiiiia7 Nev.,
Jersey and Pennsy!var.ia to conduct a^i of 1ht fei!o:wng transactions trr the
accounts accessed by vour ATM CARD.
a1 Determine the account balance--is) of your Checking ;Our 'r.egular
Shares, and your Perso a! Service Loan (PSL).
b) Wuhdraw cash from, your Checkirg and your Reg::%3r Shares.
0 Make a cash advance from your Personal Service Loan (PSL).
d) Deposit currency, checi:s, or drafts (coins are net acceptable) for
transmission to PSECU for deposit in your Checking and your Regular
Shares.
NOTE: There are limited locations it-, Maryland where deposits may be made.
We wish to inform you that scrre ATMs located in these areas may only provide
access to your Checking, your Regular Shares, and your Personal Service Loan.
Not all ATMs may accept deposits, There may also be limits on the amount of
funds which you may deposit in certain ATMs. i
12. PLUS SYSTEM' SERVICES -
• ATM Only -You may use your ATM CARD with your Personal Identification
Number (PIN) at any PLUS SYSTEM automated teller machine
(PLUS SYSTEM ATM) located throughout the United States, Puerto Rico, ft
Canada, Great Britain and Japan to conduct any of the following transactions on {
the accounts accessed by your ATM CARD, {
a) Determine the account balance(s) of your Checking, your Regular
Shares, and your Personal Service Loan (PSQ. i
b) Withdraw cash from your Checking and your Regular Shares.
I
c) Make a cash advance from your Personal Service Loan (PSL),
NOTE: Deposits are not available through PLUS SYSTEM ATMs.
These are the STAR SYSTEMS services currently available through the PLUS
SYSTEM network. Other services may be offered in the future.
13, OTHER ATM NETWORK ACCESS -
• ATM Only - From time to time, PSECU may slake arrangements with other
ATM networks to grant access to ATM CARDS. PSECU shall inform you when
such arrangements are made and describe the services that are available to
you. Any charges will also be described.
14. PURCHASE TRANSACTIONS -
• ATM Only -You may use the ATM CARD to purchase goods and services
("Purchase") at any retail establishment ("Merchant") where ATM CARDS are
accepted by such Merchant. The amount of all such Purchases will be j
deducted from your Checking. When you make a Purchase using the ATM ,
CARD, you will be requesting PSECU to withdraw funds from your Checking
in the amount of the Purchase and directing PSECU to pay these funds to
such Merchant.
15. LIMITATIONS ONTHE USE OFYOUR ATM CARD - I
• 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
withdrawrpurchase up to $500 at point of sale locations. PSECU reserves the i
right to reduce this daily limit at any time. In the even; that your daily lima is `•
Tess than $500, PSECU will advise you of the new, limitation.. The day for F
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
freouency of use of the ATIA CARD. However, these limitations are not
revealed for security reasons. The Pennsylvania State Empfoyees Credit
Union is not obliged to maintain such limitatons.
i
YDU .::I' os. :ter..:d ..:':e , :r :,Tf.' .=zD .. :...E.... _
..r:,..?; ,.? ... .tr the ... res.'..: ..r ::1. ..•": .
, 'ceps: '
a YSTE'.'s PLUS r 5T= , ....,.. ,. I c.. .
Jen. -!. ,•e ,list ,n tr,, r,.n-.r e It ^.a s ?. rn , _• i
k Kk.?2d ; Irrit r.J.. res,dt . ..':ins _L .. ?n " ...r AT`? CA=tD .;mLe.
,i often,; s that res,tlt'r matt. r .te^tor• _ rw , _r: ea'or scc,?r: ;cry
16. ERROR RESOLUTION PROCEDURES -
• ATM, ACH and SST - In 'i s ?r qt. e (-? tit yci.r
- rec.t ngjic es t.. PSECU a: 3001 23 7-7325 Na on., de TD:` ;30 : -
°n' Nat: n•,vi e., 1717} ?7; 213_1 it Har sburg, „rife PSECJ ..
Pennsylvania Sta,.e Emtilcy'ees Credit Union. RC Sox 67013 Har.sburg. PA
171106-7013, as soon as you .an i' you th;r. ,_cu- sla:ernert receip' •_
...Ong, or if you need mare .-;formailcn at,:)ula :ransacton Its:cd pn :^e
statement or receipt. PSECL! must tear from vote re. laver than, 60 deeds aver
it sent you the first statement ^.n r ^,Irh, the problem or error appeared. Ynu
must provide the foilowing inforrl_ ticn: a) Your name. aocourt number, ano
ATM CARD number (f a ATM transaction), or reference rumber I,l Sel`-
Service Telephone Transaction): (b) Describe the aror or the transaction ycLl
are unsure about, and explain as cleariv as you can why you•besieve is an
error or why you need tme information, and. (c) The dollar amount of t`e
suspected error
If you tell PSECU oraJly, you must send your complaint or question in writing
within 10 business days. PSECU will tell you the results of the investigation
within 10 business days for STAR SYSTEMS, PLUS SYSTEM, SELF-
SERVICE TELEPHONE, or DIRECT DEBITJCREDIT TRANSACTIONS. or 20
days for STAR SYSTEMS purchase transactions. It we need more time,
however, we may take up to 45 days for STAR SYSTEMS, PLUS SYSTEJ.1,
SELF-SERVICE TELEPHONE, or DIRECT DEBIT`CREOIT TRANSACTIONS or
90 days for STAR SYSTEMS purchase tr ansactiors 11 PSECU decides to no
this, it will recredit your account within 10 business days for the amount you think
is in error if it is a STAR SYSTEMS, PLUS SYSTEM, SELF-SERVICE
TELEPHONE, or DIRECT DEBITrCREDIT transaction, or 20 business days if it
is a STAR SYSTEMS purchase transaction. You will have the. use of the money
during the time it takes to complete the investigation. It PSECU does not receive
your complaint or question In'wr`:ting within 10 business days, PSECU may not
recredit your account. If PSECU decides there is no error, you will be advised
within three business days after the investigation Is completed. You may ask for
copies of the documents PSECU used in the investigation. It PSECU credits
your account while investigating, 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 to
charged a fee by the ATM operator and by any national; regional or local network
used in processing the transaction (and you may be charged a fee for a balance
inquiry even it you do not complete a fund t-ansfer). The ATM surcharge will be
debited from your account if you elect to complete the transaction.
Notice To Consumers Using ATM's
• Be alert to your surroundings. If you doubt the safety of a particular location,
choose another ATM.
• If the ATM has an entry door, close the door prior tc initSaling your transaction
• Put your cash away Immediately.
• Direct complaints concerning ATM security to an appropriate department of
the owner of the ATM. New Jersey residents: you may call the New Jersey
Department of Banking at ;609) 292-722
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 AGAINSTTHE SELLER OF
GOODS OR SERVICES OBTAINED WITH THE PROCEEDS
HEREOF. RECOVERY HEREUNDER BY THE DEBTOR
SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR
HEREUNDER.
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to
unworn falsifications to authorities, that he/she is 4j? w R.
(Name)
L'o /?q,i,-. of PS &c a, , plaintiff herein, that
(Title) (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint
in Civil Action are true and correct to the best of his/her knowledge, information and belief.
(Signatur
WWR#7057515
sm -
T1
p ? ? C'?"?' C7
-43
c.:a
0
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-07513 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE EMPLOYEES
VS
BRADLEY COURTNEY AKA COURTNEY
MICHAEL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
BRADLEY COURTNEY A/K/A COURTNEY C BRADLEY the
DEFENDANT , at 0018:23 HOURS, on the 13th day of January , 2009
at 405 N BALTIMORE AVE #3
MT HOLLY SPRINGS, PA 17065
COURTNEY BRADLEY
DEFENDANT
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Additional Comments
ADDRESS PROVIDED OF 405 N BALTIMORE AVE, APT 3, MT HOLLY SPRINGS
IS NO LONGER A GOOD ADDRESS. DEFENDANT MOVED TO 34 TRINE AVE,
MT HOLLY SPRINGS.
Sheriff's Costs:
Docketing 18.00
Service 1 Z. 6d
Affidavit .00
Surcharge 10.00
.00
`?U•(oo
Sworn and Subscibed to
before me this day
So Answers:
R. homas Kline
01/14/2009
WELTMAN WEINBERG & EIS
By:
Deputy'Sheei
of A. D.
ra
r?!
,,e
PENNSYLVANIA STATE EMPLOYEES : IN THE COURT OF COMMON
CREDIT UNION, : PLEAS, CUMBERLAND COUNTY
Plaintiff
vs.
No: 08-7513 Civil Term
CIVIL ACTION - LAW
COURTNEY C.BRADLEY,
Defendant
Praecipe for Entry of Appearance
Please enter my appearance on behalf of the Defendant above.
`j'E;(J(9 g Geoffrey M. Biringer
MidPenn Legal Services
401 E.Louther Street
Carlisle, PA 17013
(717) 243-9400
Supreme Court ID#18040
.--t
-TI
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION
Plaintiff
VS.
COURTNEY C. BRADLEY
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
: No. 08 - 7513 - Civil Term
CIVIL ACTION - LAW
PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT
AND NOW, comes the defendant, Courtney C. Bradley, by and through her legal
counsel, MidPenn Legal Services, and files these PRELIMINARY OBJECTIONS TO
PLAINTIFF'S CIVIL ACTION COMPLAINT, and in support thereof avers the
following:
1. Plaintiff is Pennsylvania State Employees Credit Union, P.O. Box 67013,
Harrisburg, PA 17106.
2. Defendant is Courtney C. Bradley (hereinafter "Defendant").
3. Plaintiff filed its complaint on December 29, 2008.
4. Plaintiff claims that it is owed a balance on account of $6,346.93 for an
outstanding loan.
1. PRELIMINARY OBJECTION PURSUANT TO PA. R. C. P. No. 1028(a)(4)
(DEMURRER)
5. Paragraphs 1 through 4 of Defendant's Preliminary Objections are hereby
incorporated by reference hereto.
6. Plaintiff does not allege that there was any agreement between the Plaintiff and
the Defendant, merely that an assignment took place.
7. Absent such an allegation, Plaintiff fails to adequately state a cause of action.
WHEREFORE, Defendant prays that Plaintiff s Complaint be dismissed
with prejudice for failure to state a cause of action.
II. PRELIMINARY OBJECTION PURSUANT TO PA. R. C. P. No. 1028(a)(5)
LACK OF CAPACITY TO SUE
8. Paragraphs 1 through 7 of Defendant's Preliminary Objections are hereby
incorporated by reference hereto.
9. Plaintiff relies on Exhibit 1 to show that an assignment took place, but fails to
attach Exhibit 1.
10. Without Exhibit 1, Defendant does not know whether Plaintiff has the capacity to
sue.
WHEREFORE, Defendant prays that Plaintiff s Complaint be dismissed
with prejudice for lack of capacity to sue.
III. PRELIMINARY OBJECTION PURSUANT TO PA. R. C. P. No. 1028(a)(2)
and No. 1019 (i) (FAILURE OF PLEADING TO CONFORM TO LAW OR RULE
OF COURT) FOR FAILURE TO ATTACH A WRITING
11. Paragraphs 1 through 10 of Defendant's Preliminary Objections are hereby
incorporated by reference hereto.
12. Plaintiff bases its claims against Defendant on an Advance Proceeds Voucher
Security Agreement (hereinafter called the "Voucher") in favor of Bobby Rahal
Honda and marked as exhibit 1.
2
13. The Voucher attached to Plaintiff's complaint purports to be the agreement
between Bobby Rahal Honda and Defendant, but is marked with the number "2".
Exhibit 1 is not attached.
14. The name "Bobby Rahal Honda" does not appear on the agreement and is
therefore not the agreement that is referred to in paragraph 3 of the Complaint.
15. Neither the Voucher nor the The Loan Disclosure are signed or initialed by the
Defendant and are therefore of unknown origin and authenticity.
16. Plaintiff has failed to attach the Addendum as referred to in the Loan Disclosure
on page 1.
17. Plaintiff has failed to attach the Payment Schedule as referred to in the Loan
Disclosure on page 1.
18. Plaintiff has failed to attach the terms and conditions of the assignment form
Bobby Rahal Honda to Plaintiff.
19. Plaintiff has failed to attach any credit or loan agreements initialed or signed by
Defendant.
20. Plaintiff has failed to attach any loan disclosures initialed or signed by Defendant.
21. When a claim is based upon a writing, the pleader must attach a copy of that
writing or provide explanation for its absence (Pa. R. C. P. No. 1019(i)).
22. To the extent that any credit or loan agreements between Defendant and Plaintiff
are written, Plaintiff's Complaint fails to comply with Pa. R. C. P. No. 1019(i) in
that Plaintiff has failed to attach to its Complaint a copy of any such written
agreements or any explanation for the absence thereof.
3
WHEREFORE, Defendant respectfully requests that this Honorable Court
dismiss Plaintiff's Complaint for failure to conform to a law or rule of court.
IV. PRELIMINARY OBJECTION PURSUANT TO PA. R. C. P. No. 1028(a)(3)
(INSUFFICIENT SPECIFICITY IN A PLEADING) FOR FAILURE TO
PROPERLY PLEAD ITEMS OR TIME, PLACE AND SPECIAL DAMAGES
23. Paragraphs 1 through 22 of Defendant's Preliminary Objections are hereby
incorporated by reference hereto.
24. Plaintiff claims that it is owed a balance in the amount of $6,346.93 and attaches
as sole support thereof a Voucher.
25. The Voucher fails to specify any agreements of the parties, terms and conditions
of the agreements and amendments to the agreements.
26. Plaintiff fails to sufficiently specify the type and/or amount of the alleged debt
owed, including the amounts and dates of the alleged charges, the amounts and
dates of any payments made, the amounts and dates of any interest charges, the
amounts and dates of any other charges, the date of repossession, if any, the
amounts realized at sale, if applicable, the method of advertising the sale, whether
notice of repossession was sent to the Defendant,
27. Pa. R. C. P. No. 1019(f) requires that averments of time, place and special
damages shall be specifically stated.
28. Plaintiff s general assertion of damages therefore is in violation of Pa. R. C. P.
No. 1019(f) and renders Defendant unable to properly defend this action.
4
WHEREFORE, Defendant respectfully requests that this Honorable Court
dismiss Plaintiff's Complaint for insufficient specificity in a pleading.
Respectfully submitted,
Date U
MidPenn Legal Services
By: , L ". f
Geoffrey Biringef
401 E. Louther Street r
Carlisle, PA 17013
(717) 243-9400
5
CERTIFICATE OF SERVICE
I, Geoffrey M. Biringer, being a member in good standing of the Bar of
Pennsylvania, hereby certify that I served a true and correct copy of the foregoing
Preliminary Objections on this 26th day of January, 2009, by placing same in the
United States mail, first class, postage prepaid, addressed as follows:
James C.Wambrodt., Esquire
4367 1h Avenue, Suite 1400
Pittsburgh,PA 15219
MIDPENN LEGAL SERVICES
By:
Geoffrey M. Biringer
Attorney for the Defendant
401 E. Louther Street
Carlisle, PA 17013
(717)243-9400
Supreme Court ID#18040
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES CIVIL DIVISION
CREDIT UNION,
Plaintiff, NO: 08-7513- CIVIL
V.
PLAINTIFF'S AMENDED COMPLAINT
COURTNEY C. BRADLEY,
Defendant.
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD FOR THIS PARTY:
Lyndsay E. Rowland, Esquire
Pa. I.D. # 205520
WELTMAN, WEINBERG, & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: (412) 434 - 7955
Fax: (412) 338 - 7130
WWR# 7057515
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES CIVIL DIVISION
CREDIT UNION,
Plaintiff, NO: 08-7513-CIVIL
V.
COURTNEY C. BRADLEY,
Defendant.
AMENDED COMPAINT
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take action within TWENTY (20) days after this complaint and
notice 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 by the court without further notice for any money claimed in the complaint or for any
other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, Pa 17013
(717) 249-3166
PLAINTIFF'S AMENDED COMPLAINT
AND NOW, comes the Plaintiff, Pennsylvania State Employees Credit Union, by and
through its counsel, Weltman, Weinberg, & Reis Co., L.P.A., and files the following Amended
Complaint, averring as follows:
1. Plaintiff is a corporation with a business address of P.O. Box 67013, Harrisburg,
Pa 17106.
2. Defendant is an adult individual residing at the 24 Thrine Avenue, Mount Holly
Springs, Pa 17065.
On or about September 15, 2004, Defendant entered into a loan agreement with
Plaintiff for a loan to purchase a 2002 Honda Accord VIN #
1HGCG16512A056495, a true and correct copy of said Contract is attached
hereto marked as Exhibit "1 ".
4. Pursuant to the Loanliner Security Agreement (hereinafter the "Agreement"),
Plaintiff supplied Defendant with a loan in the amount of eighteen thousand six
hundred and seventy eight and 40/100 dollars ($18,678.40), which was the
purchase price of the vehicle and paid directly to Bobby Rahal Honda. A true and
correct copy of the check payable to Bobby Rahal is attached hereto and made a
part hereof as Exhibit "2."
5. The Defendant signed that check which acknowledges that Defendant agreed to
the terms of the Loanliner Security Agreement, and also agreed to repay the loan
by monthly coupons over 72 months.
6. Pursuant to the Agreement the Defendant agreed to make 72 monthly payments of
$305.08, starting on or before October 15, 2004.
7. Pursuant to the Loan Disclosures portion of the Agreement, Defendant granted
Plaintiff security interest in said vehicle.
8. This is further evidenced by a copy of the Certificate of Title for the Defendant's
vehicle that listed Plaintiff as the First Lien Holder. A true and correct copy of
the Certificate of title for the subject vehicle is attached hereto and made a part
hereof as Exhibit "3."
9. Defendant breached the terms of the Agreement by having not made the required
payment to Plaintiff as promised, pursuant to the terms of said agreement.
10. Defendant made random payments on the loan for some time with the last
payment she made being $188.51 on September 10, 2007. A true and correct
copy of a ledger of payments is attached hereto and made a part hereof as Exhibit
644.19
11. Plaintiff had notified the Defendant by correspondence dated August 15, 2007
that she needed to make a payment of $915.24 to bring her loan current, which the
Defendant failed to do. A true and correct copy of the correspondence dated
August 15, 2007 is attached hereto and made a part hereof as Exhibit "5."
12. Upon Defendant's default under the terms of the agreement, Plaintiff exercised its
rights under the agreement and repossessed the vehicle.
13. On or about December 18, 2007, the Plaintiff notified the Defendant that it had
repossessed the vehicle and of it's intent to sell the vehicle sometime on or after
January 2, 2008 as per it's right under the Agreement. A true and correct copy of
the December 18, 2007 letter is attached as Exhibit "6."
14. The December 18, 2007 letter also provided the Defendant with information
detailing how the Defendant could cure her default of the agreement.
15. On or about February 25, 2008, Plaintiff notified the Defendant that vehicle had
been sold and provided an accounting of the amounts remaining due pursuant to
the Agreement. A true and correct copy of the February 25, 2008 letter is
attached as Exhibit "7."
16. The amount remaining due, which totaled $5,616.27, included the balance left on
the loan plus fees and deducted the credit due to the Defendant from the sale of
the vehicle. Please see Exhibit "7. "
17. Defendant has failed to pay the outstanding balance due as set forth in the
February 25, 2008 letter despite being requested to do so.
WHEREFORE, Plaintiff prays for Judgment in its favor and against Defendant, Courtney
C. Bradley, individually, in the amount of $5616.27 with continuing interest thereon at the rate
of 6.00% per annum from February 25, 2008 and costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE
USED FOR THAT PURPOSE.
WELTMAN, WEINBERG, & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: (412) 434 - 7955
Fax: (412) 338 - 7130
WWR# 7057515
- LK - - M', I - W?.
ADVANCE PROCEEDS VOUCHER
AND SECURITY AGREE tNT
P
Pennsylvania State
l Employees Credit Union
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P S CO P. O. Box 67013
E
Harrisburg, PA 17106-7013
(717) 234-8484
fhe financial IinkTM (800) 237-7328
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COURTNEY BRADLEY 9/15/200 8102036434 / L10 409632
1864 WALNUT BOTTON RD
NEWVILLE, PA 17241 PURPOSbealer Purchase
T YPE ION ? ? END
O F-1 OTHER
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NOM
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1. NEW LOAN 2. L
OAN ADVANCE 3. L_j (DESC
RIBE) 4.
EQUT
CYADVANCE
YOU HAVE PREVIOUSLY ELECTED TO HAVE THIS ADVANCE CREDIT DISABILITYy?
INSURED WITH THE FOLLOWING COVERAGE YES O NO U SINGLE CREDIT LIFE
YES ? NO ? X JOINT CREDIT UFE
YES ? NO ? X
DAILY PERIODIC RATE
(CHANGE IN TERMS ONLY) ANNUAL PER- INTEREST RATE IS AMOUNT REQUESTED
+OTHEA CHARGES AMOUNT. ADVANCED PREVIOUS BALANCE NEW BALANCE
CENTAGE RATE FIXED VARIABLE +
?
-
.015041 5.490 % U El 18, 678, ?•'ti
4;$`i.??&:;?; 0.00 18, G78.40
PAYMENT DUE DATE PAYMENT FREQUENCY PROJECTED LOAN TERM
305.08 10/15/2004 MONTHLY
I F SECURITY OFFERED
IFTHISISAHOMEEQUITYADVANCE,THEONLYSECURITYFORTHISADVANCEISTHEREALPROPERTY(INMO TCASESYOURHOME)WHICHYOUQAVEASSECURITYWHENYOURACCOUNT
WAS ESTABUSHED.
IFTHI$ IS MOT A HOME EOUTTY ADVANCE. IN ADDITION TO THE PLEDGE OF SHARES IN YOUR LOANUNER-CREDIT AGREEMENT, THE FOLLOWING PROPERTY SECURES THIS ADVANCE
ITEM PROPERTY. ;N,1`^ _I:MNUMBER
I. HONDA ACCORD 2002 1HGCG16512A05649 SDN 18,900.00
2.
3.
4.OTHER
YOU PLEDGE SHARES AND/OR DEPOSITS OF $ IN ACCOUNT NUMBER
OLD ACCOUNTA.OAN NUMBER (A PAYOFF (PRINO.+ INT.) OLD ACCOUNTA.OAN NUMBER e) PAYOFF (PRINC.+ INT.) OLD ACCOUNTA.OAN NUMBER C) PAYOFF (PRINC. + INT.)
OLD ACCOUNTA.OAN NUMBER (D PAYOFF (PRINC.+ INTJ OLD ACCOUNTILOAN NUMBER E PAYOFF (PRINC, + INT.) OLD ACCOUNTA_OAN NUMBER PAYOFF (PAINC.+INT.)
By accepting the proceeds or by using the funds advanced and deposited into your share/share draft account, you agree (1) that the property referenced above
will secure the advance and any other advances you have now or receive in the future under the LOANUNER• Credit and Security Agreement (the Plan) and
any other amounts you owe us for any reason now or in the future in accordance with the terms of the Plan and (2) to make payments as disclosed above in
accordance with the terms of the Plan.
1W WJM MUIUAL UNMR,, )YOU. 07, #9, 66, B9, 99, 99, 7UM 01, 114. ALL RIGHTS RESERVED
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM #3175 JVXX0100.1 037-2092-1 (4/04)
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Pennsvivariia State Emoloyees" Credit Union
Loan Disclosures
This LQANI_INERI Credit and Security Agraerre.nt. :,which rc'ides the TVr ir.
Leming Disc osures. will be referred to ; the Plan Tl.e Plan Joc.,r-i r s this
a.grc; - -.cn and' an AJderaurn You. your and borrower -riles-1 a ; l e,, ,r .. c signs
e I an Credit union, we, our anc us ,near P SECU or a v. e C _. flu
Unicr, trar:s erg its rirthts undo, the P!arl.
HOW THIS PLAN WORKS -- Tr.s is an cc n a"d "ru'F-'_an ad c-ec,t clan VJe
of c•oale :ha!, lmm tame to tin e. you nPl bUrov. rrorcy (•-t_iieo ad. 'noes') unCor
".e P:an. We are not required to make advances to you under the Plan and can
refuse a request for an advance at any time. The .Addendum . :,bes the
;i fferent types of credit (called'subacr_:!unls') available under the P!ar, !ne Curren:
,r4efesl rate for each F.'•llb?.CCgunt e'gpres,fed as _. daily pert d;c ate and
corresponding annual percentage rate and other charge.=. it may also have other
terms, and a schedule for determiring t: e pz:ymenl amounts.
CREDIT LIMIT - Wa tray, but do not have to, establi sn a cro it !irmt on certain
subaccourts. if a credit limit is set for a sut)acco:;ni, ycu promise not to exceed :tie
established credit limit. It you exceed the cretin !unit, you prom se 'n repay
immedately the amount which exceeds the credit limit.
REPAYMENT - You promise to repay all a!rour:is you owe ur:der'.ire P'an pies
Interest. Pny'rner,ts are due on the last day of the month unless we Set a different Clay
at the time of an advance. It the Addendum has no payment schedule for a
subaccount, your payment will be determined at the time of each advance.
Payments must include any amount past due and any amount by which you have
exceeded any credit limit you have been given for a subaccount. You may repay all
or part of xhai you owe nt any time w':'hoUt any prepayment penalty. Even if you
prepay, you will still be required to make the regularly schrdu;ed payrlenis unless
ve argres in :writing to a- change in the payment schedule. It you haves a ipint
sharedraft account. you will be responsible for paving all overdraft acrrarcgs
obtained by a joint holder of the sharedraft account. Unlcss otherwise required by
law, payments will be applied to amounts orred under the Plan. in the manner the
Credit Union chooses.
PLAN ACCESS -You can obtain credit advances in any manner authorized by us. If
We allow you to use your ATM;`Debit car; to access the Plan, you may be liable for the
u. authorized use of your ATM "Debit carry. You will not be liable for unauthorized use
that occurs after you notify us, orally or in writing, of the loss, theft, or possible
unauthorized use. If you believe your ATMi DebB card has been lest or stolen,
immediately inform the Credit Union by calling or writing us at the telephone number or
address that appears elsewhere in the Plan. If the card is used to obtain unauthorized
advances directly from the Plan, your liability Will not exceed 550. If the unauthorized
withdrawal is fro .m a sharedraft account, your !,ability is governed by the Regulation E
disclosures you received at the time you received your ATM/Debit card, e en if the
withdrawal results in an advance being made from your overdraft subaccount.
FINANCE CHARGE - The dollar amount you pay for monev borrowed is called a
-finance charge" and begins on the date of each advance. A finance charge Will be
computed separateiy for each separate balance under the P!an. To compute the
finance charge, the unpaid balance for each day since your last payment for since
an advance if you have not yet made a payment) is multiplied by the applicable daily
periodic rate. The sum of these amounts is the finance charge owed. The balance
used to compute the finance charge is the unpaid balance each day after payments
and credits to that balance have been Subtracted and any additions to the balance
have been made. In addition to interest, we may charge other finance charges which
are disclosed on the Addendum. If the interest rate is a variable interest rate, the
A.JdendUm explains how the variable interest rate works.
SECURITY - You pledge as security for the Plan all shares and dividends and, if
any, all deposits and interest in all joint and individual accounts you have with us
now and in the future. If a specific dollar amount is pledged for an advance, we will
freeze shares in that account to the extent of ttie outstanding balance for the
advance. Ott!ermise, your pledged shares flay be withdrawr unless you are in
de'ault. The following paragraph applies in all states except in Ohio, Rhode
Island and Massachusetts: We have a statrtdry lien on the shares and dividends
and, i' any, the deposits and interest in al. individual and joint accounts you have with
:a and may exercise our rights under the lien to the extent permitted by state law.
i:"?e are state chartered if our name noes not include the term "Federal Credit
Union") For all borrowers: The statutory lien and/or your pledge will allow us
to apply the funds in your account(s) to what you owe when you are in default.
T:-:e statutory lien and your cledee do not apply tC any Individual Retirement
Account or any -ether aecVUri; that wou d lose special tax t,eatrlent under state or
fecerai lav; if given as security.
Additional security for the Plan may be required at the tine of an advance. if a
subaccount identifies a type of'property (such a "New Cars") you must give that
type of property as security :vier you get an advance under that subaccount. A
subaccount name such f. "Other Sec.irec', means you must pre-.ide security
Ccec.atde to us whr;n you obtain an ad.ar.c_ -der that caccpunt. Prc•c r y yciu
tl!ve as seCuri'v will Secure al! amounts owed under the Plan. a„o all other icans you
!nave vfith ,:s n Or in the fuh.r_==. except any bar secured by your principal dwelling
Proc=rly recur trier Cans VOL, have tJth us may also secure the Plan.
CREDIT INSURANCE - Credit life ara.ur crrdl' .,ability insurance is op:;•:;nal
.;rder the Flan !' you quality to aria pur,-base the insurance from us, you aulitc,i=e
,.S ii 2011 :r:e :nsi once prerr..,m., yc:., loan p3lance and charge ;ou
i jn,=rr.<t or, _ntlfe b1-:,ce it y.., o!ec, credit n5 rarce you, payments ma•?
i' C .T.._,r, or .. e Ecrii_d t. ?. „cc=--ir n r;.:--av ,our ?Jva"'CEs r'ay be ex'9r,cie:J
T .,r ii F!ar. I'. OhC .,
g9. ;se .v 'u
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pr-vice env rcob:-,.5 by
PERIODIC STATEMENT - 0 receive a state,rc-it sr,rnv na
al irsrsac -i.ins tie ,_r-r.; !', _arered Lv'he stwe,Ter
S m".e ,e nls rind robe . •. h Se-r1 'c tnF..mos: recrnd aacress y.--.u tai.
g' _n u= in ss at 't.ui?e a,v rr-,::%.ir s t.ce !c eacr zit pry, p:. r.
notce to any one ^f v-. u v:I!i be nol,ce to all.
JOINT ACCOUNTS - if this is a account ::acre of •cL is indiv'd.ra! and ;o:n:!•;
rsporsible bur a'. gall :meuras owed. That means v.e, can enforce cur rights
Linder't)e P'an acainsi any one of y,-,u indiv,Ju<J;y or against all of you tog_.the;. if you
q:._ u_, inconzistent insiruc4on. we can refuse to tol,cw yz%ur instructions. Unless cur
written policy reouires all rf you to sign fcr an advarce, each of you at:thori>_es the
otherlsj to obtain advances individua ly and agrees to repay advances made to the
otherkil. Any joiril accouriJ,.oider may terminate the Plan by giving LIS prior written
no!ice. it any of you terminate the Plan, the Plan is terminated for all of you. You
emza;n !iabie individuai!y and jointly for all advances incurred before termination.
FEES A14D CHARGES - II you give us a sect.:rly interest ir'. certain types o'
property, we may charge ycu a filing fee is pe^ect our interest in the property. 11 wn,
do, the amount of the fee will be disclosed to y-,u at the fume you obtain an advance.
We rray also charge you other fees in connect on v+ith the Plan. Our current fees are
disclosed on the Addendum and will be, added to your ioa.n balance unless you pay
there in cash.
UPDATING CREDIT INFORMATION -You pro ridse that you will promptly give us
written notice if you -rove, chance your name or employment, or if any other
information you provided to Lts changes. Upon our request, you also agree to
provide us updated financial information.
DEFAULT - The following paragraph applies to borrowers in Idaho, Kansas,
Maine and South Carolina., You will be in default if you do not make a payment of.
the amount required when it is due- You wilt also be in default if we believe the
prospect of payment, performance, or reaiizatcn on any property given as security
is significantly impaired.
i
The following paragraph applies only to borrowers in Wisconsin You will be in
default if you fail to snake a payment when duo two times during any 12 month
period. You will be in default if breaking any pr„mise made under the Plan materially
impairs your ability to repay what you owe or materially impairs the condition, value,
or protection of or cur right in any property yo., gave as security.
The following paragraph applies only to borrowers in Iowa: You will be in
default if you are more than 10 clays late in rnaking a payment. You will also be in
default if you do not comply with the terms c' the Plan and your failure to comply
materially impairs any property you gave as security pr your ability to repay what you
owe under the Plan.
The following paragraph applies to borrowers in all other states: You will be in
default if you do not (rake a payment of The amount required when it is due. You will
be in default if yc,u break any promise you made under the Plan or ff anyone is in
default under any security agreement made in cor•r ec5on with an advance under
the Plan. You Mil be in default if you die, file for bankruptcy, become insolvent, if 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 o',ve. YOU will be in default if any propery you have given
us as seCUrlty is repossessed by someone else, seized under a forfeiture or similar
law: or if anything else happens that significantly affects the value of the property or
our security interest in il. You will also be in default under the Plan if you are in default
under any other loan agreement Wit-, LIS,
ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers in
Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri,
Nebraska, South Carolina and West Virginia: When you are in defau:' and after
expiration of any right you have Linder applicable state lay: to cure your default, we can
demand immediate payment of 'he entire ur_,aid balance under the Pan :without
giving you advance notice
The following paragraph applies to borrowers in all other states except Wisconsin
and Louisiana. When ycu are in default »e can require immediate payment
(acceleration) of the entire unpaid balance Linde : the P;an, You waive any rich( you have
to demand or payment, notice e! intent to accelarate and notice of acceleration.
The following paragraphs apply to borrowers in all states except Wisconsin and
Louisiana: If Immediate payment is demanded:, you Ail! continue to pay Interest until
what you owe has bee ep :d at ie app ale interest rases in effect or i app/ cable,
at the default rate dis_icsed or . at Aadenoum if, a demand fo, im-reciito payment
has bean made, your shares ardlor deposits ,:an t e pl etl Lowaros wrtat you o::e
as provides in the section ab.rve called "Secs nly-" ,% can also Exercise any o'ner
rights g-.er, by law- when you are in cefau!t.
You -9Q,- 2a Credit Unit,- has the right i., t:.6:e possess-on of any property' given
as sec r!ty under the jug r :I f tnis can be bone ...".hoot
breach of t''^.e peace ` we ask, you prorrse to delve, the property at a t;ra and
it:aue we cn.')se If t.' pr ., err is a. mc'2.r vE. e or ..__ , YCU ?-gree ,nat :,C M"IN
LOs1lJLlIJER' Credit and Secure C7e rr1 A rre:.ment (continued.; The followuyg paragraphs apply if you y ye security in corn ction v. till an
--
advanee under the Plan. They apply to 6orrev:e':rs in rill states except Louisian
lir-1 bc. .eVr.rr _k - - r _ Louisiana borrowers will exec.,tp a separu:e aCCurit'y' agreane^t. °e,•r^.v:Gr; i
r. ether states may also be asked to execute a seoarate security agreement
r,, leavi? trist,?e :he ; ;V o of lire r-..._..,. c.r,'.,,l Jt. r'r t r r THE
vs ; - „ `rJG -.i ? ,..i n ':C CCi SECURITY C F T PLAN
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r un 'a I balance under The FI . Yc g b^ F v ntere t amt:uni a. t
same ate ris , 'advance, or, if {opIjCalb.; Zit Jcfaul. rate S. -lo:,2d on the I WHATTHE SECURITY INTEREST COVERS ROSS COLLATERAL PROVISIONS
ddendum, until that error-till ffs been paiv. -The secuf,ty mten re._.re e dvir-c Gen I G : he cE pI. vc. chc y
other documenl'wGU r _ at tr,.e cf :`7a Ali ce a -,c. any ex,ensi,,;rs. rc• J '.s
The following paragraph applies only to Wisconsin borrowers: Lb r n cr cU ; nc.ns of th Adv=nc.It also secure, any other advances you have now
eiatii! and after expiration of any r.gnt ynu have umJer t:rlicable state it ,;re v
1 r tho` or receive in the future under the Plan and any other amounts or loans,
i vela:, t, L•:e may req'uirn immediate payrr.en; of your autstandirg inar-: gala;.rue urdz Including any credit card loan, you owe us for any reason now or in the future,
Plan and seek possession of property given as securityr You may voluntarily give the except any loan secured by your principal residence. If the prnpsrty i; no',isano'd
I proper-,y tC. us if you choose or w may see4. to take possession of e property by ? goods as d•cfired by the re^'.. nr Trade t Ummi ,ruin C edit Practices RUe "e
udiaal pmc s if v.e repossess the pro pE ty. you agree to !:,ay r . enabl e ra rses , property will ;scup y ,re J i., ea . n d nci ,:I e -r r.: i , o. .
ncum d in disposing of the property 1 the p pert,, a tnotor nowe home, i
trailer, snowmobile, beat or aircraft, you will als•- be uired to pal any costs permitted OWNERSHIP OF THE PROPERTY - Y , ,., ,, tr t VC "A : ?r .. }
by SEr:io:n• 422.413 of the Wisconsin Statures You Ust pay any . x t: tt that ren .ens dive as secuhry .,r i Ady, re 5 to bur i, F e o' fro E yni r•
;npain after the sale money has been a.,plied t ha: you JA,e under the P'an You the Advance for Ma! Purpose YOU promise th , r ere eie ha, any i +e •s r
a_rez to peg :ntsrest on any urtpaaio ar;ount at the same .r e a the ,fa ce ter, if daim against the prop•-rty that )u ;ready told r c .t 'r-)L cri e /
- if c as recur + c;- a loa t dun r c e i
:puircable, at the default rate disclosed pr: the Addero_;m, uric that amount is pa,rJ. to self or le ase the pr pc r y 111 t c
until the Advance is repaid YOU Ur0 i;c ie will I :v no ctrer secur , it res _r
It tla property is located ouis de Wscons;n at the t,rna of default. we may t ke i lien to attach to the property eitf -i by your a; uors or by ,P -rit;on of tr ..
o.r,ssessi ;n. of the property 6rthout judicial process,r permittac by the state v.,hera attach
properly is located. PROPERTY INSURANCE, TAXES AND FEES l u rust maintain ,r p ,y
( insurance c„ all property that v U give as cc ray Under tie P an. You may bur e i
The following paragraph applies only to Loulsiona borrowers: When, you are in the property insurance from anyohe you ..hose r, ho is accepte:bJe to the Cr it
default vve can require imineauYe payment (a.cele•atio-l, of the entire unpaid
t Union. The amount and coverage of the roperty, Insurance niust be ccep'Ct ie to
balance under the Plan Yeu'raive any r.rlht you have to demand for p?.yincrt, notice ( Us. Ybu may provide the property nsurln e '`;rough a obey you already `law or
of intent to accelerate and notice of acceleration. If immediate payment is I through a polio YOU get'
r et and pe v for Yin Iy .^mi to make the insurance pc a:y
demanded, you will continue to pay interest until what you owe has been repaid at ( y ye
the applicable interest rates in effer_t unless a default rate is disclosed on the I payable to Lis and to deliver ter policy o rent ct ruverago to Us t asked to co ,,).
Addendum. If a demand for immediate payment has been made, the shares and It you cancel vcur insurance and get a efund, we have a right to the refun; If •tio
deposits given as security for the Plan can be applied towards what you owe. We property is lost or damaged, we Can use $ e insurance settlement to repair true
can also exercise any other rights given by law when you we in default and our property or appl'v it towards w`-:at yc•u ore 'Yoa auto ri e us k' endorse any d of or
rights under any security agreements you have with us. I check which may be payable t you in order oar us o cu'i<cl any refurd Jr hen i s
;r ni%l
CANCELLING OR CHANGING THE PLAN - The following paragraph applies f due under your i su nc> poi icy. *You also .o . _+y all to as and f e e
only to borrowers in Illinois: We have the right to chance the terms of the Plan from `registration fees) du on the p ,,r?e t,.
time to time after giving you any advance notice required by lava. Any chemao to the If you do net pay the taxes or ties on the property when due or keep it insured. :'+a may
interest rate or other charges will apply to future advances, pay these obligations; but wa are not spurred to do so. Any money v,,e spend to taxes,
f fees or insurance will be added to the unpaid balance of the advance and you will pay
The following paragraph applies only to borrowers in Wisconsin: can interest. on 6:ose amounts at the same rate you agreed to pay on the advance. We may
change the terms of the Plan from time to time in accordance tviti? Section 422,415 receive 't„eels in connection with the insurance from a x•mpany which provides the
, the Wisconsin Statutes. You will bo notified of any change in terms. An increase j p`?y
in the daily periodic rate under a variable rate interest rate is not considered a insurance. We may monitor our loans for the purpose of determining whether you and I
Change in terms under the Plan. We can cancel the entire Plan or icy part of the i other borrowers have complied with the insurance requirements of our loan agreements
j Plan at any time. You may cancel the Plan at any tame by giving us prior written I or may engage others to do so. The insurance charge added to an advance may include
1 the insurance compary ` payments to us and (2) tea cost of determining compliance I
relics Your obligation to pay the unpaid balances under the terms of the Plan
continues whether you or the credit tin on cancel the Plan, exce t to the Extent that with the insurance requirements. If vie add amounts for taxes, fees or Insurance to the
your liability is limited by Section 422.4155 of the Wisconsin, Sta utes. unpaid balance of an advance, v - may increase your payments to pay the amount
added within; the term of the insurance or approximate term of the advance.
The following paragraph applies only to borrowers in Iowa: We can change the I INSURANCE NOTICE - If y. U do not purchase the rsquirsd prGperly insurance,
terms of the Plan from time to time after giving you any advance notice raquZd by
ivy. A change that increases the rats of finance charge or other charge. that the insurance vie may purchase and charge you for will cover only our interest in the .
increases the amount of your payments. or that otherwise adversely affects existing ; Property. The premium for this insurance may be higner because the insurance
balances will apply to existing balances only if you acree to the change or you use I company may have given Us the right to pu chase insurance after un nswed
the Plan after receiving notice fiat yOUr use of the Plan means you agrees the I coI, tcra! is ,oat or damaged. The Insurance will not be liability insurance and
change applies to existing balances will not satisfy any state financial responsibility or no fault taws
The following paragraph applies to borrowers in all other states; We nova the PROTECTING THE SECURITY INTEREST - If yoL•r state is, ties , ' e for he
right to change the terms of the Pin from time it, lime after giving you any advance Property, you promise to have our security irteres ht n on he ti'la t e tray
rotce required by law. Any change in the interest rate will apply to tut:,re acvances. to file what s called a ffrancing statement t, protect cut security interest rJ't t-e
and at our discretion and subJect to ary requirements of applicable law, will also I claims of others. it asked to do so, you prorrise to sign a financing s:. !arri,.^ Y ,:
:apply to unpaid balances: also promise to do whatever eiss we t I is necessary tG p'c'cct r?,/' s?cu•,!y
interest in the property. You prom se to pay all cons in hiding but not -i i eJ tc n^ry
The following paragraph applies to all but Wisconsin borrowers: An increase in attorney fees, we incur a pre e tirIC Our SoCL.6ty trite...,' and mgr.'s in , ie .^_ro rty.
:he daily periodic rate under a variable interest rate is not considered a Char e in tic Itte extent pentiulcd by appit able law.
terms under the Plar. We can cancel the entire Plan or any par! of the Plan at any
time. You may cancel the Plan at any time by giving us prior writ tern nonce Your I USE OF PROPERTY - Until ne AJ.,arce h s been pa G c` you Premise rou r
ot,6g3tien to pay the unpaid ba,arces Linder the :arms of the Plan coc.Inues Whether (1) Use the Property carefUll and keep it n good air r2I Cbla O .r vvr
yDu cr the Crzd,t Union cancel the F'tar?. pa mission e era m rig •naiar changes +,, the property or changing he -ddress
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN -'04"c can deiay ',Allow here us the to rubc[ ; ta rcpt i3) . (5,1 Pr r,- una1.t nng y before ,s 1 c tithe ,,r?ro: your tlc, ?? f 1 i
Inspect proper',,,,. t_, u, zrty i d .n cd
enforcing any of our rights under t`:rs Plar any number of times :wilt vut ICsirg th "
e stolen o
abil-f1 to exercise qur rights ate•. Wci :.an enforce this Pear against your heirs or en or .'r s' d iG1 Not - ,r pr ,er f?.r-ant L.r,h:.,,t ., u. pO_a.! rJ rr_.',aa
p t r:y in another state v'±nn.i. : ali.nc us.
eg pr-sentatives. It woe chance the terms of the Plan, you acres !let this Plar
":.It , :nt: ,,:e to protect us I NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE
PAOTUn VEHICLE IN ;S TRAP.SAGTION MAY 5E SJBJ=C r -O
CONTINUED EFFECTIVENESS It any . t Oi itw:, Plan is do;::rm c ::v a e urt THE i REPOSSESSION. !F IT IS REPOSSESSED Atr SOLD TO S7+I JNF = _E
c he ,nentor sable the rest will _n a, in .-a_.e.' AND ALL AMOUNTS DUE TO THE S CUP;ED PARTY ARE NCT RECE'V_D IN
NOTICE TO UTAH BORROWERS - Tr izn nr =meal is n fir,:: xl iss'on of TH ' A.i S,ALc. YOU i? A F Ao/..=TO PAY HE :]'. FEt?ENCE
'r e agree'r_ t _ ,v.eer, you ar•d t lc, Crr.J. U„ion .s vc!'en agr?:r, or' may net
NOTICE
ce poet adietac by evidence c anr era' =gleemenL FOR ARIZONA OWNERS OF PROPERTY „ is
rid r vehicle z C eCUf r ''e ( LJt ni C v
t to ti n ' a c c
The following is required by Vermont law - NOTICE TO CO-SIGNER - YOUR ' yo, h c rte iv d it:= f ?ietau- - T e re r-a ed to i,2 3r r ,S
SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE gaive - I: s you r ors bit tit aty ?_s 14 o nc s h .n s r. x r,
FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, i i natty for unlw.rul ..1u.e to c emir a ' rcr vehicle n C:re year i-i pr ..•., ..:,d
THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. fine of s15o,o00.
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NOTIFY US IN CASE OF ERRORS OR OUESTIONS ABOUT YOUR
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Ldy i%-n, .,' fe m,t'iU'sen'=nt tO ,is I:), an,, sL _.: . ' or d.SC: eDBnCV ur: vOu• %C JJI-'c. li vpu 'ad f'_, pay ;hr c . _Ci.' l 11 _r, ..... ?UU 0 .... e .- - .Or: V
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m J 'rC Ur f gals. ,S ,el ny lc V tort `,CU tc ii at y . 1
lilting Us you 5I r u.zc to pay,
in y.ur le,?Lr give ..S the folk sir r mini 1,a,1: :: have a que.e Ir about your t c. t rd s n the rip-me of r rlyc, -
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P rE on you to t `e r'. 5 tea lny0 CC
• name and tieCOCfA f1l r?lJU
Y^L c find bt1 u, ,s Lnen f1 ' } i .
I rte dollar amount of the suspected error. 11 we en 10:f ihPSr r!, ..s t cal c, i ._a ,r.: .,,._ of c qua.,ucr.. 1 + ?_,., a,
Des,Jr be the error and exp!ain, if ;c„ car .'hy you relieve ti.ere is an error. I &.ren it your sta.ternr,,n, wac• corect
If ycu neeri mom in crrnancn des.cbr, , i'em yt.,u are not sure :boot.
SPECIAL RULE FOR CREDIT CARD PURCHASES - 11 -t ve ocsn t h
If YOU flaw :Utt-Or ".'Led US :o pay a c'edi Car',! account aut:rratically ho^', yoL,f a the quality of f.'.rperty or ;erv.E:es tn<tt ; u ,:urc'^,_, eJ : itn credi card, .rd
1 account cr checking acceun+ you can r m the payment on any arr:ount you thinks `have hied i' gaud fa :h to O r f the prvo,eot ;vith eta Merchant, yea iy nz\F c
wrong. To stop the payment your leper must reseal us three business nays before the I rg t not to pay the rernairing amount due on !le pnpe y ciservices. The re : ,o
autcr?atic pay'nent is sc edu'ed to occ'r. limitations on IN, right (a) You rL ..t `.aft made the p:,-cri s in ysur home s r l or,
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR I if riot'.vithin your home stele, wlihirt 1';0 miles of your current. mai!ing address: and i
1 WRITTEN NOTICE - We must acknowl:edge your letter within 30 days, unless we ' (bl The purchase prop must haL'e been n5ore `hap $50.
have corrected the error by then. :^Jithin 50 days, we must either correct live error or I These limitations do not apply if we own or c,parate Ile merchant, or if we mailed
explain why vie believe the statement v,as correct you the advertisement for the property or services.
In this Agreement, the words you and your means each and all of those who apply I charges, then to current late tees, tr!an t:? previous cash advance balances, then to
for the, card or who signs this Agreement. Card means the VISA Credit Card and any . previous purchase balances In the order that Ineyr were posted to your accotrra, then
duplicates and renewals we issue. Account means your VISA Credit Card Line of to current cash advance balances, and then tc current purchase balances.
Credit account with us. We, us, and ours means this Credit Union. ! 7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by
1. RESPONSIBILITY - if vie issue you a card, you agree to repay ail debts and the 1 paying the full amount of the New Balance of Purchases each month within 25 days
Finance Charge arising frurl the use of the card and the card account. For example, of your statement closing date Otherwise, the New Balance of Purchases, and the
you are responsible for charges made by yourself, your spouse and minor children. ' subsequent purchases from the date they are posted to your account, will be subject
You are also responsible for charges made by anyone else to whom you give the ' to Finance Charge. Cash advances are always subject to Finance Charge frci"f; ;tie
j card, and this responsibility continues until the card is recovered. You cannot disclaim date they are posted to your account.
responsibility by notifying us, but we will close the account for new transactions if you Purchases: We calculate your finance charge by multiplying the average adjusted
so request and return all cards. Your obligation to pay the account balance continues , daily balance (see explanation below), including new purchases, for the bitting cycle j
even though an agreement, divorce decree or other court judgment to which we are ' by the mon4mly -periodic purchase rate and corresponding ANNUAL PERCENTAGE
riot a party may direct you or one of the other persons responsible to pay the aco0urtL I RATE as disclosed on the Addendum.
2_ LOST CARD NOTIFICATION - If you believe the card has been lost or stolen, I Cash Advances: We calculate your finance charge On cash advances by
you will immediately call the Credit Union at (717) 234-8484 or (800) 237.7328. After i multiplying the average adjusted daily balance (see explanation below) for cash
flours call (800) 556-5678. a advances during the billing cycle by the monthly periodic advance rate and j
3. LIABILITY FOR UNAUTHORIZED USE - You agree to notify us immediately, I corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum.
orally or in writing of the loss, theft or unauthorized use of your Credit Card. You may Balance Computation Method
be liable for the unauthorized use of your Credit Card. You will not be liable for Average Daily Balance for Purchases - The Average Daily Balance for Purchase
unauthorized use that occurs after you notify us of the loss, theft, or possible Transactions is calculated by adding the Daisy Balances (Purchase Transaction) for I
unauthorized use. You will have no liability for unauthorized purchases made with 1 each day in the billing cycle, and then dividlog by Me number of days in the billing
your Credit Card, unless you are grossly negligent in the handling of your Card. In I cycle. To calculate the Daily Balance for purchases each day, we take the following ,
any case, your liability 'will not exceed $50. 1 steps: We take the outstanding balance (all amounts you owe) at the start of the day ?
4. CREDIT LINE - if we approve your application, we will establish a self- i Then, in the sequence in `.which amounts are posted to your account, we add fhe j
replenishing Line of Credit for you and notify you of its amount when we issue the amounts of all debits and subtract the amount=-- of all credits or payments which post
card. You agree not to let the account balance exceed this approved Credit Line. Earth to your account that day. After applying payments and credits, we subtract the
payment you make on the account will restore your Credit Line by the amount of the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the i
payment which is applied to the principal. You may request an increase in your'Cradit amount of any Cash Advance transactions that posted to your account on that dry or !
Line only by written application to us, which must be approved by our credit committee in any previous day in the billing cycle. This gives us the Daily Balance for purchases.
or loan officer By diving you wr'Itten notice we may reduce your Credit Lire from time Average DerYy Bafanca for Cash Advances - Cash Advance Transactions which are
to time, or with good cause, revoke your yard and terminate this Agreement. Good I posted to your a--court are riot included in the Average Daily Balance ca!culafien for
curse includes our failure to comply with this A reement or any other agreement with b :^ r , eriy g y purchases, and are therefore na su.,lc.,t to ',tie monthly periodic rate for purchases The
us, or our adverse reevaluation of your creditworthiness, You may also terminate this Average Daily Balance is calculated Separately for Cash Advances and is suhject to the
Agreement at any time, but termination by either of us does not affect your obligation ( Cash Advance iLtontNy Periodic Rale.The Average Daly Balance .or Casn Transactions
to pay the account balance. The cards remain our property and you must rerover and 1 is calculated by adding the Daiiy Balances Kash ?7ansac8on) for each day in the bi!iing
surrender to us all cards upon our request and upon termination of this Agreement. I cycle, and then dividing by the nu:-nber of days in the bitting cycle. To caic,late the Daily
5. CREDIT INFORMATION - You authori_ e us to investigate your credit standing Balance for cash each day w'e take the id!L_win:; steps: We take the outstanding balance
whe:r opening, renewing or reviewing your account, and you authorize us to disclose j (all amounts you Owe) at:t,e start of the day. Then, in the sequence in which amounts '
intom,cation regarding your account to credit bureaus and other creditors who inquire are posted to your account, we add the amours of all de sts and subtract the arro rr s ;
01 us acout your credit standiro ? of all credits or payments whirr ost to your account Lha. day. After applying payrn s
6. MONTHLY PAYMENT - We will rral you a statement every month showing your and credits. we subtract the a nomt of L u pia Finan ce Charges or' ate Charges.
Previous Balances of purchases and cash advances, the current transactions on your Then we also subtract the amount of are P chase Trars ct1 ns tsar ,steel ' v .ur i
account, t. e remaining credit available Linder your Credit Lire, the New Balances Of account or that day in an, previous ry in the o,Crrg cycle, Th;s ::ves cu :he D .i!y
purchases and cash advances the T_ta! New Balance, Me Finance Charge due to date. Balance for Cas^ Advance transactions. Note: Cash Advances are always subject to
nn any ruler billed fees, and the Minimum Payment required. Every morth you must pay I finance charges and from the day they are posted to your account
at e__t the 10ir-i num Payment .vithin 25 days of your statement c!OSlng date. By separate Payments are applied in the faiov.-no r Irr,r r' first ;;, mrev ous We fees n tC
agree^?er: you may utr,crize us to charge P e minimum nays-lent automatically to 'your , ew0ts cash advances finance oh f r, to a prev;c purcrase e
;ha-e or crecking account wGh us- You May c,' course, pay more freq' ently pay more I Cf,a yes: Ihen I^ Ct rent late fees,tint ca-sr advance balances. •` r 1c
t f t.t!rlmJ'n Payment, cr pay Tne'I(,ial Flew' Balance in full, and yu will reduce tine ? p •evlous pu%,hase b?lances 1 a r. P y - ., C V O rOS n to LOW 9 u-rt
f n rqe by doing so. If your monl:nly paw neat exceeds :he total credit line balance to current c s advance n.,es J n r c rt pure gar Ce
owed. we will ELUtemetcal!y post the credit to your St shares are aopliod firs... e part:cuiar ly::e n r,_ht Laic 's e_Ina c _d, any. .nr, .,
7n in;••- m -aypent will be. to `ir cf yo r Total New Balance rounded up to t^e , to the balance Of yb ,
next c dr, du'lar. or (b) $20,00. wh r teve.:s greater. In addition, at any time your Total Note a se :he! t' tic a_: of ;stir r•avru. s nJ rd v I are e r : y
New Balance exceeds your Credit Line you m,:st immediately pay the excess upon our , accoun' by n Pay en! Due Date h o r ii- st c ' ib 0 ex :e f-
de.mand. We will apply payments in the ioilcw r,c manner: first to precious late fees, New Salance _rcw on tint _;ate. y_n, r apps y if-.,c PE o:i1 Fare
me,! to prev'cus case advances 1:nance cna•ces then to previous t•:?Ilase finance to your Acrur: c. dr ..,t s'ateme,-,(
VISA' Credi! Card Agreerent and Tr rn r•'• !.c a+ino Dry assure /; nntin,.eri
8. DEFAULT ,'cu v. !I i_ _
i;:• e , :,rr',-;....t:'nrr Ire:,_.-:,. _.-... .:.. .. .... :....
r-. rr.c. ;f.•. ,. , n:1 ,'?.. ..nt ,_ l -,;I r. -,. 1 ..
u5.--.rtc; tr 4-f. r. :!-SA trot. '7 F-W
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4. , ,, P. coy
a c range Yt your Gr', I( n e. ,, ,., r e.., _ .r , _ ., . a- is
.-, rf'.:71nC.: /;,.I,n'3 Y-1U. your charn or •Iz'.;f ... 't.l .:::..r_..._ tI . F,:, 'Jr
.-JuE ;,' cur cecurty inter[ at m? ,r!v der-,ni. !h? :; rc t lg r r. . ':Cg, ,.rill rr,rl - ;
PavrTierd your full account tit. r cr. If you dt:t..lt. .t...,t .o c:r g,r.nc L ._?•ri _.
r id -.r! b, '...'n :Ye '.^ent ,.iso :!o t rp l cur
_ •fect:cn er:. r. scs. Ir{iLiC:,1?1U ct:ur c oits _r: .:'torn,'?`+ fr:r E
ar ...
9. USING THE CARD - TL, na, :' n , rc! a.. :ash aav .ra ere
ve proccdures t, be. follov ed Or-= :s For y,-. ,L, Mo f__:-nt ,e •.ard ;r' :1
fa ti_.;•alin.g VISA plan merchant, 'jr C,nd s1q
Or cash advance dra which v, !'4i c .n-npr -d '' ith your -:?rd 1 I: ; rite, is I m. Ctc
,he transaction by ;Is nit your Pe•Eonai Ider I,ficaton Num,-:er (PIN) cu" !::'clot!
yr th the card ir, an Automated Tel!er Mac' Ine cr other tyre cf lac: or i rrn;nat teat
provides access to the VISA system You agtoe that val.: will r.o' use your cart for ar•:v
;ansaction that Segal :moiler appl;ca?!e federal, state: or !eca! taw. Thf; rren., y
a.:atemant will •denGiy the rnerohant, ale':Lrnic ' -rminal .,r fin; nc al Ins: t,ricn at
,Shich tranaacUOr'.S `,4efe n?1de, but sale, C8=^ adb\a poet Credit or other s[:ps Ca;'TQt
be returned aiith the statement. You will r61<:!n a copy of such slips !Urnlsf'red al ;he
time of the transaction in order to verify the monthly statement. The Credit Union :nay
reque<_I.
make a reasonable charge for photocopies of slip; you may
10. OVERDRAFT OPTION - if you elect io ovomra" to your PSECU Visa Credit
Card, that election is subject to the existir, crdit iimii and the agreement it re :resents
and th•e current loan policy at the time of the overdm t You a'so i,:nderstand that an
overdr;ih will be considered the sam1- as a rash advaance on your PSECU Visa Credit
Card and that the current Annual Percentage Rate `or cash advances .vill apply.
11. RETURNS AND ADJUSTMENTS - Merchants acd ome s :a;o honor The. card
may give credit for returns and adjustments, grid they v:rl do so by san•Jrng us a credit
S.i;p which we will post to Ycur VISA tine of rrdit. It your credit and payments exceed
,vhat. You CA-le Li we w'ill` autrrrna!ically cost,no excess credit balanc•? to your S1
Shares within 73 days. If the balance is one do"ar or more, upon your wrihen request,
we will refund the credit baiance to you.
12. FOREIGN TRANSACTIONS - Purcl-:_=.ses and cash advances made in ioreidn
currencies will be billed to you in U.S. dollars. The conversion rate tr_- dollars will to
made in accordance with the operating regulations for irtemational transactions
estabilshed by VISA U.S.A., inc.
13. PLAN MERCHANT DISPUTES We are not responsible for the refusa! of any
clan merchant or financial institution to honor your card. We are subject to claims and
..
14 SECURITY INTEREST
those cc.c? r.n:c:h rt aid fcr u. „u„ at,cie. 7r
I-' By c t. ! e r:a r.a oc J ! ;r 1v e ..,a
h. s ..cc::u!r: unl'v, ?•.i! ,..: a,.. ..A. , _ ......d,. I,Q,i' _ .: y r.: '.e . Ire I`
d.- .:.Jl: :o .r ,t. -1-?i .. ?':;t: ?.e .: ?L.7 fro":'. .r.'.n 5.^.?-E'.. !i.• ,.,,5•':;.
t'elUw ' ,aid D_i I,. r• ;.t y. ,. .:root'. a. FI _';,. if 1•":-? r;:.: c. I:A e .
slpecif'?.C pi rage. G' \n it crr_=c7lt. U'?i?iC 5n i-?5 Deposits) oy F:gnlrng the PIeC ?\ of
Shares rr !pen. se, Of acy o! *h-er s:., I.; inn -.Sts for yr r detis v--,,-:r -
anJ be sec-7-;j by your pledged s';:,.e _ pt,>:>o) -anJ _, n_ Prceerty •:! _•s; •I: _d in
those ot^F:r sec.ir,ty ag c. ^IC;nts, •'x:-ept !or yo:., I ^Te.
15. EFFECT OF AGREEMENT - T^.is Ar;ree 7-nt a ti.e ^on=. 2c: ,?h h :a l•as t_
all transactions on y,-ii acc7 T . ec_•n 1101LJJ11-2 Sates C<. ad ti . -.edit -jr
otnc-r slips you sign or rc_ceiv- may co,-tain of e•, i te.rms. We may ;mend
Agreement frurn l'nrle I- time by se.n.:Ping you t!'.e advancc- writteri notice egclrad oy
aw. Ycur use of the card tht;ren ,er'sui r l-wE your grre,neni to the r rend' cg, a.
To the extent the law perrn!ts, arid are ind+cate in our notice, amendments wil' acp!v
to your existing account balance as wel! as lin i-,turd transactions.
16. LATE PAYMENT CHARGE - If v.-ur A4irn:rrlum Payment is n Tt recelveo by !ha
first day of the month ` Ac,.ving your due date, you •,vyl be subject to a S20 chase
17. RUSH FEES - Y>u may incur additional rr ar_e. for rug;t prccessinr r-i rl;sh
deliver' of cards end:or PIN ma;ic.r.
18. OVER LIMIT FEE - :A S2 fee will be applied for e c11 nr.;nthiy state manf cicsng d.te
on which tic Outstanding h•a!ance, axcec•ds the a:-signed creed lit,i by mcr• ,hat, 5100.
19. DRAFT COPIES - You rt7ay incur an addltiona! charge for transaction
SUnlmar -'S3Ie draft dOCUilinenta'.icn.
20. COPY RECEIVED -You aoknoWtedr;e recBipt of .a copy of this Agreement.
21. ILLEGAL TRANSACTIONS PROHIBITED -Ye..: ag =-e that you will -oil use your
card for any transaction that, is illegal under ap:^•hcable federal. state, or ;coal ;aw.
22. NO USE - Inact'va Visa acca;rrs that ha'. rc purchase or cash actin ty r . .
be closed wi?hout notice to you after 16 months of no activity.
23. NEURAL NETWORK - PSECU uses rural nefwcrk systems to predict anti
prevent unauthorized transactions, There n ne occasions when a tr.ansactior: Is
declined because it is indicative of possible fra;:dulcnt activity.
.ATM CARD CARDHOLDER AGREEMENT - The Undersigned (you or your), in ? validates the directions given just as your actual signature and other proof identify
consiceration of THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNOIN ('Ne, ' you and authenticate and validate your directions is a human teller. You also
our and us) issuing to you an ATM CARD, hereby agree to be legally bound by the understand that a Merchant which accepts the ATM CARD for a Purchase
following terms and conditions. You agree that the use of your ATlvt card(s) transaction may have an electronic terminal (Merchant operated or Self-Service)
constitutes acceptance of the terms and conditions of this .Agreement You which requires the use of your PIN ono who n your FIN Is used at a Merchant's
understand that ATM is a credit-related service and you authorize PSECU to obtain I terminal, it w!If authenticar and validate the directors given lust as your actual
a credit report on any users of this account. signature will authenticate and validate your directions given to us. You acknowledge
1. ACCOUNTS AND USES OF ATM CARD - You have the. account(s) (inctt;oing 1 that your PIN is an identificzlion cede that is personal and confidential and tnat the
Checking and Regular Shares), which we set forth on your application form with this ( use of the PIN with the ATM CARD is a security devise for your accotintts)
Agreement. You hereby request that we issue to you one or more ATM CARD(s) to Therefore, YOU AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO
be used in connection with such accounts as described in this Aareenient. ONE ELSE LEARNS YOUR PiNt.
You understand you may use the ATM CARD at a STAR SYSTEMS9 ATM to (1) I 3. LIABILITY FOR UNAUTHORIZED TRANSACTIONS - You agree to Contact us
withdraw cash f'a'rt, (2) make or arrange for deposits in, (3) effect transfers to ur, from at once if you believe the ATM CARD(s) issued to you or PIN has been lost or stolen
your account, (4) receive into;-nation regarding the balance in your account(s) or (5) or money is missing !ram your accountls•). You also agree that f` your monthly
rake cash advances from your credit account(s) in the amounts you reauesi, You may statement shows transac".ions vrhich you did 'rot make, and you do not contact us
I a!so use automated teller machines throughout the United States and in certain. within 60 days after the statement was mailed to you, you may not oet any monev
toreian countries which bear the PLUS SYSTEM) name and logo (1) to nnake I lost of?er that tirne. YOU AGREE THAT IF YOU GIVE YOUR ATM CARD(s) and PIN
withdrawals from, (2) effect transfers to or from, (3) receive information regarding the TO SOMEONE ELSE 1-0 USE YOU ARE ?.JTHORIZING THEM TO ACT ON )'OJR
balances in your Checking or Regular shares. If you have a Persona! Service Lean i BEHALF AND YOU bVJILL DE RESPONS!BL E FOR Ar`JY' USE OF THE CARD(s) BY
losa : c cg,, 's) you take no action to no'iry
approves' and in place, you may dls D rn:ake a cash advance from your FSi_'Yc•.; f.a-ther THEM, You could all Y=,::r rr,rney i +, e, ac if i
urde and you may use the ATM CARD to purchase goods and services ` PSECU or the loss of your AFM C D or PIN. Safeguard yuu Perso•ial
i"Pu.crtase`) at any retail estahlishms^t ti tvlercha.nt') wnere ATM CARD- are j Icent!flcat!on Number IPINi Do riot tea r i!Sc oso tour PIN to any othe Jerson. Dc
accepted by sL.ch Merchant. It you use t"e ATM CARD to make a Pure as o obtain not write yc:ir PIN on your ATM CA ,D. G no . et w . en i coro of ,•.,ur ^
cash:. if permitted by the fiercnant you shall be recd esting us to w:tndra.v funds in Ihr• your ,ATIA CARD. Do not choose a PIN rat IF, _ .,,.+,
rto:, it of such Purchase !including, any c•as!ri received from the Merchan! from Ycur Anew card may ee erne' d for you at that tire- any ;i!: !;e p _ ... y:_,'r
Checking Shares ano directing or c-denng u= to pay such funds to the: tviarrha.-t old card. After such tiT•o yo.; f nd void' cld ::-rd, sestTov I _ o; + car, _y -,;-ing it
'fou request that we will l;rovia: V; you Such other services or access to other ATM in raft. If YOU attempt to use v ol,. Cr.d, :1't n r.r`-
syste rs r,r ne^rrorks usmc, Ire ATt.". CARD vrhich'.vC may ate' make avaiiab e and 4. CHARGES -You agree to pry e Ct v._r: c.,a .1(2 aaoh Jeposd v,;rcira,.+!
which; we advise you are offered in connection with ro..r accoount(s) SO. f0 ,.:.,. ,cr exceeding 15 a mrntn. Y,:,, a, ee is a, the S . :1z carat'} cna ?e or arv cas'n
leizs ! i.
-oc'Iicahc;n form, You also understand "'at front ti'r'e to !imc you May request I.' c. S?.
y disbursement tronsarnart (lori,. :adt.,rco . s are ':I:hd.ar.s ; a
;rte that we rovide access to addi:!or_' accounts of yours !hrocgn :tie ATM You n _:, ba otter. ng_„ r. :. uT ;harac'
p ag ree to pay a 25 cent barge
CARD we have issued to you. You agree that the uses of the ATM C=.nD o_scr wed (or any adj.:stmenl Ina: needs to be m.. : rou ?cc:,-rvl _ .: t:ng F-;•n an error
this Agreement shall to subject to t..e rules and regu!a.tioxts of ea--! Ii you made w nice making a e. posit a; an .,it; r ..,:v T_ ;_r mac^rre ;ATt.I;. Y•::u ao-e
wlh c`: 's accessed by such Card. to pay the charges or tra^sacu: n rtes 'a'r.IC.h a. Dy us for !:,cse s::•;I:::??
2. USE OF PERSONAL IDENTIFICATION NUMBER ("PIN") WITH ATM CARD cr hot srrvlces vr!•rCh mav later ne c rite....,, .._h .-., c _ ma , ^oeEeo
ot. ur:der_tanrl diet a STARS %S7E.'11S cg, ;_ PL-S SYSTEM ATM is; an t. .... axed or changed tom time to time.
coat It ca,i and :.ir pe.rforn' many of th.e sam;• :asks as a !,urra t •e' er You ' 5. DEPOSITS - You acrce . .r ,. a rnase. 1 dr cs . ,.. a S--AR SYSTE`."s
l
e that the Persona! !dentl'.ca:ion '"umber or P !N .hc ;h yo !v the r; , etv' v.e r-a,e !h, r v ? i : n : h_ ' :TM that we ? r g ^ mnrrev nsa e
ackr:c::l^V
t Th,1 CARD vc;r Signature IDentfles the bearer of the Caret :c, c S TAR to you it vo-- deliver cc as cf:_ck, t.r . . n._ . STAR 3YS7E v S A-',11,
(STEMS ATI;' PLUS SYSTE'A ATM,.,.,_r neraor's ATM,M and aw -en:sates and understand ana ack^ i,vlr _ _., . .. !u J., f om r_c .o:ir rn r,c: ?t
- - - - ?- - -- --- ---
Electronic Funds Transfer, .',Tit; Agreement and Requ';ti,,; 'L ' Disclosure SST ..
tc n:uiuedl ..., _. _ _.. ,. _ .
_ J,.. _
t. , 5 :` - . Y,.., ., c .. ....:. ... :. ... '.: _ ; 6. ANY CHARGES FOR ELECTRONIC FL NDS TRANSFERS OR FOP, THE
`-1 ?-t ;.' '; `c-'•.15 Al.'.? ih-o •. " U?. .,. i :. ._..., ".5':;.'cl ?r5'11u, '-`.'tju RIGHT TO I"JAKE TRANSFERS
'TE',IS ATI':1S ... r.l ATM - - .. a:c'nCo . .. h _n.,.. S?
t ._. _ .. -. S-iAP S'. ,. T r .+ .,- A . . a i .. _ a-.---t (:•' ,.o . in._n ?. n . , n':. ,.. --n c ..t f_r ...
..,..;., :. .I _., __ ': ,.5 t•re .t.. '•' c !=;_ I -^, _:an u, ::.cr - , 1 'st n:a L< r.. -,,.. ... ..-,.]r ,e .r i iJ -
6. LIABILITY - I! tr_ A lA ;riu ue' (^r
a'- - - h. a t.. .,Lc .:r.,. a.
-, ,-,d Sr:,t <:yII-i. ... .:.. t'. .:'('_i!. >. .. dr, .. 1:.. e.l .. ,, .\h ii_,._,.C., .. I.. :r._
__ aI ou r';t-? J -G. ?s.ts r rayr*?e^:5 t . -.r ,,. r.-.... .1,i ACH J z '- F1 :C .,
.., rq;. >-r :,Jer.,.t tor `s ?cr ::_ir.- ,ra'_ -
,han cast, ec-5. c: -r om<r ,.ale's anrl we man, f.. !s; SST- r,rr
;ou from such dco, iL, ,: r!or t,-., ; r r. c;icn n nine n,tt v:e r ::y 7 SUMMARY OF CONSUNiER'S RIGHT TO RECEIVE DOCUMENTATION OF '
_ i. ?nr: ,p^ n,.ns n+ ..:h fur.rs m-• y ur ,..:.: :(. din, •• ara n- 3t .c.?ed r) r. EFTS -
L he t rr ! 1 y J acCOUrt(s) a - r If is er at •, c`1 tame. ,cu Mill promptly pay la
,s :
d elf suer funds 'which are oe_[ c_,ter.'_
s try a • ATM - You !•= u,:a d ccc•we- a at the li; of r9Cn
transactor. You >vdl receive a mcn h ? s;atrr rt shovr, a the stat:a cf aeon
7. AMENDMENT OF THIS AGREEMENT ,cu rr e ,ria,!rotm h t,, na r':
i 1 or cha he terms of t!.5 rednent inc!-:Ling aim nd. ent. cr
accou any trans,c*!c r n r r 6 it g Ire ^icc:h, and any v5na:',es Cr
i
-
? Ct'a rites PSL".U niriv rrir)_.j jU'rtg the CiGG;"I.
i
<inge t ci arge for
.ancas _ .aJH furlhe AT1i Ce,.nU is r r to ariena or c
z
e _ercb es. Y'le may co : y r+adyi J in :,r`.'ng rf suer ar :endme:'nt_ cr : ACH and SST -Yon; will rC::Elee t on hiy ._.,or ?n: sr^,owinq th s:a s z?f
2r;;1 yO'Jr USS of the Aht1 CA^D <'. `lcf he EfrE•C`ve date of any such yohr <c n ;:t. ary trans.tr ictn ^7;e du-nq the riu'r;al. Ina any penalties
erne^d-r•ert or change sha If cps stlt'Jte y,,..( ::cceo!a lc.e or a,)d aar;eTent to s_ch charges PSLCU 'na' " nlr. Se j.-ring ine mort•)
,.. :enoment yr dram ;e If you have arranged to h vE a diract dE,:oslt rr.rd:: to your account :• react
8. OWNERSHIP - YOU agree tha, the ATM CARD S Our proeerty and vote Once every 60 nay's from the same person u r ,r,,pary yzr,: can cai us at
urc ,' c•r to us upon our recuest `,'nu agree tn;:: the A.T>,1 CARD 's ran- (800) 237_7328 iv find out wrelher Or nr3 the , -posit has been made.
e.; s e'at Ir: A. STOP PAYMENT RIGHTS - PRE-AUTHORIZED TRANSFERS -
9. DISCLOSURES -You hereby acknoMaedge receipt cif the disclosure statement • ATM and SST - Not applicable.
-nnrng you of your rights under the Flectrcinic Funds Transfer Act and a copy ?-f ACH - Right to Stop Payment and PfOCcdures for doinC sc. If you have told i
REGULATION "E" DISCLOSURE
1. ELECTRONIC CHECK CONVERSION/ELECTRONIC RETURNED CHECK
FEES - If you pay for something Minh a check or share drali you may auihonze it
to be converted to an electronic fund transfer. You may also authorize merchants to
electronically debit your account for returned check fees. You are considered to have
authorized these electronic funds transfers if you complete file transaction after
j being told (orally or by a notice posted or sent to youl that the transfer may be
processed electronically or it you sign a whiten, authorization,
2. SUMMARY OF CONSUMER LIABILITY -
• ATM, ACH and SST - Tell us at once :f you believe your card has been lost
or stoien. Telephoning is the best way to keep your possible losses down, You could j
iosa all the money in your account plus your maximum overdraft line of credit. It you
believe your card has been lost or stolen, and you tell us within two business days
after you learn cif the loss or theft, you can lose no more than $50 it satneone used j
your card without your pertnission.
If you do riot tell us within two business days after you learn of the loss or theft of
yo_tr card, and we can prove we could have stopped someone fern using your card
without your permission if you had lot,] us, you could lose as much as 5500.
i
Also, if your statement shows I ar,sfers ,hat you did not make, fell us at once. H
,rciu do not tall us within 60 days after the statement was mailed to VOL" You may
riot get back, any money you lost after the 60 days if we can prove that we could
gave stopped someone frorn taking the money if you had told us in time. l
If a good reason, such as a long trip or a hospital slay kept you from telling us, we
r101 exlend the time periods.
3. TELEPHONE NUMBER AND ADDRESS TO NOTIFY OF UNAUTHORIZED
TRANSFERS -
• ATM - Contact PSECU at (8001, _237-7328 EXT 3806 (nationwide) or (717)
234-8484 (in Harrisburg). After hoe.rs, follow the menu options on PSECt;'s
noire rna?! system to report a lost or stoien card. For VISA Credit or Denir !
Canes, lol;ow the directions for Lost Carl Normri ation tinder the VISA Credit +
Card Agreement and Tr,•;h-in.-!_r-nd,,-] DisC+csures sechOn of tins document.
I -
• ACH and SST - Contact PSECU al ib0j) 737-7328 (nationwide) or (7f7)
234-6-484 iin Harrisburg).
O Ife to u
en.,syl.an?a State EriployC•es Credit Union
P.O. Box 6" 0 13
Harr!sburg. PA 17106-7013
PS.,-CU Business Hours:
5:5Ga.re -50,}p.m.NI -:
TDD ;800; 472-1967 Na;.on'v.ido
717; 777-21-D0 in HarrisDurg
4. FINANCIAL INSTITUTION'S BUSINESS DAYS -
ATNL ACH and SST - PSFCJs 9, _ [, ay L•r,r Fr' ay
Hof.,:ays not irclucec.
5. TYPES OF ELECTRONIC TRANSFERS A CONSUMER MAY MAKE -
ATM - F ..arse irq •ics Dr n?s .rd PS_ .Mir^d Minis ?i
..)g savings .._.,r ad,ar. e f-D r SL ae.,,, tt- IC _c r,, swir:CS.
urcr.--se :odds anc soiree.. at , cpl:nq retail est L'i!sren,ent
ACH - P•eaut^,zmzel deDits ..nd cry r_; in rr(.C . rg a-d
any of these payments. Here's hoar: Call us ai (800) 237-7328 (Nationwide)
or (717) 234-841:1=; (Fiarrisl?urgj or write us at: Pennsylvania State Empk,fees I
Credit Union, PO. E^x 870131 Harrisburg. PA 17106-7013, in time fcr :a to I
receive your request three business da'y`s cr rnGre before the cayment is
scheduled to be made. If you call, the may also require you to put your request j
in writing and get it to us within 14 dayS after Ycu call.
• Notice of Varying Amounts. If t}iee,e regular payments may vary n amount,
the person you are going to pay will tell you, 10 days before each payment.
when it wits be made and how much It will be. You may choose instead m get
this notice only when the payment would 1,i `er by more than a certain amount
from the previous payment, or v:hen the amount 'wcjid fall outside certain
limits that you $Of,
• Liability for Failure to Stop Payment of Preauthorized Transfers. If you
order us to step one of thew payments :hree business davs or more before
tha transfer is scheduled, and are do not do so, we vitl be. liable for your losses
or damages, unless we request and Jo not receive written confirmation of an
orat stop payrnent. within 14 days and the transfer takes place after 1 days,
or you fail to give us proper instructions that would enable us to place the step
on the transfer. I
9. SUMMARY OF THE FINANCIAL INSTITUTION'S FAILURE TO MAKE OR
STOP CERTAIN TRANSFERS -
• ATM - If PSECU fails to complete a dansaction on time or in the correct
amount, when properly instructed by you, PSECU will be liable for damages
causer,' by our failure unless: (1) there ar) insufficient funds in your account to
complete the transfer; (2) the funds in your account are uncollected; (3) 0',e
ands are su'.]ject to I=_cal process, (4) the t(rn actier you request would exceed
vne funds in your account plus any available overdraft protection; (5) the STAIR
Systems, PLUS system has insufficient ,-n.sh to complete the transaction; ('6)
your card has been reported last or r:sfer end you tare using the repori car
(7) PSECU has reason, to believe .hat the transaction requested is
unauthorized; (8) ?he -failure is d,:e to an equipment breakdo'.vn that YOU kno."r
about when you start ad the 1.arzaclicn at t'ie STAR Systems, PLUS System;
(9) the failure wlls caused by an, act of Got fire, or :,:nor catastrophe, or by win
ct!-er cause beyDnd Corr i, (10), d yc'; a'tem to ccmple'a a'rarsact,on. that.
a STAR Syutelns, PLUS System, r;- tr< ch rt terminal :hat Is "ot a
permissibia transaction, iist d above. ,r (11) tr ,.,.acto,i VC;old exceed the
secunty limitations on the use of yo.ATl l CA;.D
• ACH and SST - if PSECL! fai!s tc comC.irte a t._nsaaicn or, lime or in tree
correct, amourt..vha prc;t-erly inst-uct: by yo:, PSECU :Mill be liable for
dam ages c3cbed by ,:r fal!,u ,lles_ I I.: the < re :s_!ffoen..,.r,:ds n yo:,r
a,..;CUrt lit COT JIFie I.`e. 1 jnSfer, ?(2? ., `ur::S rr. vo_., acc7'J'I', a'e
_-; ( the tm. Sarno- ,: .
ro!I<Je tie +. n_!s s_iDieCt to
rcp..eSI would exceed the i.nds it ..,u __,.._. t F s .any avmil a,.';.. eve:rdra? .
credit; (5) PSEi . reasu? tc, _: action a es.c:d
n&. ., n ed, I•r he fc. r 5:93 :'us, an .:( 3c: J,
_at-ist-phi. Or < _c.._,. 'n I- ca?.e PAZ C_ sl-
+e liable r y fc c- :a! C _ J,.n ti car•,eOE:S ii?w! [aik.nE,
1:, m.a 6'12 irL!-ldr.Ct,in S ._. _ c, a I _._ ac gcsc _ PStCU's
Procedure= to avoid _.r-i erc•5
0, DISCLOSURE TO THIRD PARTIES -
• ATM, ACH and SST - PS CL 'til + r Dn o y^ cc :rat to
in r-I n-.tins: f, i it n .., _.,r ,Y_,L 7a. ;, Ct;a ms I_ i to
Eectranic Ft;nds Transfer ATM Ac
reet
-,,,enl and Regulation `E Disci_rsur e
i cori tin Lied.)
,'C)• -) I'I 2!'u,:!]a": .. ?. .. . :'ic :'S,. , L G.:1;'y' ;1''I'
,- •r ?•a ., .u"tidy. _.r: _ _'..r :i:.,.'_.._ _.. .• n .. cr c::..a!
'rdar5 1-i r ec: cl :..r. .r m ?.__•a -,g ,. _ ;.r!
= rr.:,y Act or 1?. E'. lac r,P, n _.:•/ 5,.. F _ ...al 1,1 .. _...
nr ir) v.nen it is r- * ces r/ 4? a _ cr tc. ^r 5:.'.; ?.S
11. STAR SYSTEMS SERVICES --
• ATM Only - 'f may cze your i M CARD r h vcu r ors::n , I 1 - lir r
Nx,. _ (PIN) u, STAR SYS fE .t., alt ? r De , ,_. e t 1.3 y..r vv
Jersey aril Pennsyivar` a to coni.,--ict a7- e ..'Jar Chic
acccun s accessed by your ATM CARD.
,) Ceti^nice the account ba'lce-is) )f ycur Cr ckcg ,.ur =er„!ar
bit es- a-id your Pcrs3?:a! So.-Ac(? Lo n (PSL).
yv. a,r Cash f-on; your Che,- Irg rrrd your R.e,_I ar dr ar,,s
c) Make a cash advance from y;r.r Person-tl Service Lear: LPSL}.
c) Deposit currency, checks, or dr,.fts (coins are nct a cep!able) 'cr
:ransmisslcn to PSECU for deposi' in your Checking and your Regular
Shares.
NOTE: There are limited location8 it Mrary!and :.hare 3&-,os•!s may be made.
VJe wis -. to inform you that scrnp AT,`;ts located in ihese areas may only provide
.cess !o your Checking, your Regular Shares. and your Personal Service Lcan.
NM, all ATMs may accept deposits. There may also be iiniits on the amour:* o!
funds vehich you may deposit in certair ATVs.
12. PLUS SYSTEM' SERVICES --
ATM Only - You May use your AI "M CARD with your Persona? kfenilificatipn
Number (PIN) at any PLUS SYSTEM automated teller machine
(PLUS SYSTEM ATM) located throughout the United States, Puerto Rico,
Canada. Great Britain and Japan to conduct any of the loifowing transactions on
the accounts accessed by your ATM CARD,
a) Determine the account balance(s) of your Checking, your Regular
Shares, and your Personal Service Loan (PSL).
b) Withdraw cash from your Checking and your Regular Snares.
c) Make a cash advance from your Personal Service Loan (PSL).
NOTE: Deposits are not available through PLUS SYSTEM ATMs.
These are the STAR SYSTEMS services currently available !hr%gh the PLUS
SYSTEM network. Other services may be offered in the future.
13. OTHER ATM NETWORK ACCESS -
• ATM Only - From time to time, PSECU may make anangerner s with other
ATM networks to grant access to ATM CARDS. PSECU shall inform you when
Such arrangements are made and describe the services that are available to
you. Any charges will also be described.
14. PURCHASE TRANSACTIONS - {
• ATM Only -You may use the AIM CARD to purchase goods and services j
("Purchase") at any retail establishmen! (" Merchant") where ATM CARDS are j
accepted by such Merchant. The amount of all such Purchases will be j
deducted from vour Checking. When you make a Purchase using the ATM
CARD, you will be requesting PSECU to withdraw funds from your Checking
in the amount of the Purchase and directing PSECU to pay these funds to
such Merchant.
15. LIMITATIONS ON THE USE OFYOUR ATM CARD - f
• ATM Only - You may withdraw/ up to 5500 per day from one or a combination j
cf your accounts by using a ATM CARD provided the funds are available a! a
STAR SYSTEMS or PLUS SYSTEM ATM. In addition, you may
vAmdraw'purchase up to ,5500 at point Of Sale locations. PSECU reserves the i
right to reduce this daily limir at any time. in the even: iha! your daily limi is
ess t*an $500, PSECU will advise you of the new limitation. The day for '
•,vithdra:val limits starts at 12 midnight each day and ends at 12 midnight the
next day. For securiy purposes, there are also certain daily limitations en :he
irequency of use at the ATM CARD. However, these imitations are ,,at
:avea!ed for security reasons. The Pennsylvania State Employees Credit
Union is not obliged to maintain such I4mitations.
o. STr_ . PL' S A7 -
(ee(i . .. I r,i Es r r AR.+ ?D nt
16. ERROR RESOLUTION PROCEDURES -
• ATM ACH and SST - I r L c
D ri?.•I (u F?-ECU _. rrr 1 237732-5 Tn._ i
96 7 a::r .S.GCrg. _ , lie 'SECv .•
.
."t;?l I._ /IVa'l S i:e E ,? c. es Crc -_... P.O Cox 6..u..j r _ rrJ, 0A
:
7101-'0I,3, ai s_Cr,. as vn•j Ca .. y th:, Sa:er'•?-t -i')'
:'rdnu or f you :'lied '1c?'e •..Il?n aCC;.1V". .r_i >a_r,^,n LS ..d _.
T.'atc. ...en! Gr recE-pt. PSECU mist Cea' i'Jr; rP 1 aTer tr F;Q dal,s after
it yen: ycu Ine first slat ,r! ;;n rift e , ohic error a, aa,,......
must orov,"_e the ioilov rrr, in:c•rint:cn: n) name . •...cu t nt,
ATni CARD m.amber (:f ATM tram ..r ::ni. or ra`erecce Irene Se^
Servi,-c. Te: e'ohone Tra,^,s8_Lenl, (bi Des-rite rite _. r the transinci n y_„
rro unsure. albout, and explair as gleam :s you can ,. you : eliave'.. _r
error rrr .ny yo;, need Inq ^f ;r ra; on. , r c T ne racilar
suspected : rror
if you tell PSECU oraf!y, you must send your ^7plaint or au-es ion in :•:r:r.
within 10 business day. PSECU will tell au the i-esutts of trio eve;
within 10 business d_ s for STAR SYSTEMS, PLUS SYSTEM, SELF,
SERVICE TELEPHONE, cr DinECT DEBIT"CQ.EDfT TRANSACTIONS. or 20
days for STAR SYSTEMS purchase tr rsact!ons It vie need rnore ti
hoe ever. ,ve may take :)p to 45 days tar SITAR SYSTEMS, PLUS SYSTE11s1,
SELF-SERVICE TELEPHCJtiE, or DIRECT DEBIT CREDIT TRANSACTIONS c r
90 days for STAR SYSTEfAS purcn85:e transactions if FSECU decides to <
this, it will recredit your account v: i:hin 10 business days for :he amocnt you Ihini:
is in error if it a STAR SYSTEMS PLUS SYSTEM, SELF-SERVICE
ELEPHONE, or DIRECT DEBIT-'CREDIT transaction, or 20 business days if ii
Is a STAR SYSTEMS purchase trans action. You will have the use of the money
during the time it takes to complete the investigation. II PSECU d:'es not receive
your complaint or question in writing within 10 business days, PSECU may no
recredit your account. 11 PSECU decides ti:ere is no error, you be ac•rsed
within three business days after the in,,estigafion is completed. You may ask f(.r
copies of the documents PSECU used ir the investigation, If PSECU credits
your account white investigating, you must repay those funds if PSECU
concludes no error has occurred.
17. ATM SURCHARGE - If you use an ATIA that Is nol operated by us, you may be
charged a fee by the ATM operator arid by any national. regional or local nr_•twcrk
used in processing the transaction (and you may be charged a 'tee for a balance
inquiry even it you (to not complete a fLJnd t-ansfar). The AT^A surcharge will bir
debited from your account if you elect to complete the transaction.
Notice To Consumers Using ATM's
• Be alert to your surround!ngs. If you doubt the salaty of a particular location,
choose another ATM
• if the ATM has an entry door, close the door prior to ini!ta'.ing your transaction
• Put your cash away Immediately.
• Direct complaints concerning ATM sea,n,:y to an appropriate department of
the owner of the ATM. New Jersey resident you may call the Flew .:ersey
Department of Banking a*, '60-0) 29)2-72'2
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 AGAINSTTHE 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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Pennsylvania' State Ernployeesr Credlf:_Union> No: 4096320
PO Scs 67013 • Mvri+6u ,PA17106.701J (71n7J1-616d or (ecO) 7nn76 _
AUTODRAFT VOIO OVER $ 11,9,,67(8.40 REFEREN%' 9102036434 voiD i zo M1320 ER
.5.. PAY TOTHE .. ? SoQIILL
I?'\1\In }4.
ORDErI t>F IDEALERI ?T
'1"7o1?,I Jt xa?l? YI()1•ICA C?\??_ -. ` S_j?f'D-I P7: Q-?
' 7y? -?• \ \:.???
-"`J ` _ V:n 'L, 1?? '?IILLIDOCLARS?
IMPORTANT:VOIRPNLESSD'EALERENobRSEMENT'6DMPLETED
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, cepting the proceeds of this draft; you agree to the terms
By I
listeon the nvuae side. No portion of the proceeds of this.
d
AutoDraft may be paid to the Borvowerfel or to any agent of the'
Borrowers .
' MEMBER END RSEMENT '?-
By endorsing this draft, VW, •sgrea to the leans listed on the reverse side '
el the d1e11. _ .
•'•9EPAVMF11T1AE7N0D [? M°nlhly Co?Pon -_?Aulomebe Trsnsler .Q Pnyrdl Deduc Iion• '
•.TER/A:1 2 ,. Monlhs-. ? t ?Ie
Member Endorsement .
`. „COURT Y D DLBY :.. . -
"-applicanl Erdorsei7ieni ` •S : -
rl - ' ' NO CO-APPLICANT.
1!'4096,3 2011' 1: 23,1381 i 161:' 31059S098011':, 44 d'000 196781.0.1'
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CERTIFICATE OF TITLE FOR A VEHICLE
1'? - - .- -I..--.--., ...........
345
073519999004886-001
1HGCG16512AO56495 120021 HONDA 1 57404530302 BR
VEHICLE IDENTIFICATION NUMBER YEAR MAKE OF VEHICLE TITLE NUMBER
?,'
S D 1 ? I
i I I
6 D ?4 I a
1
6IL !
BODY TYPE DUP SEAT CAP PRIOR TITLE STATE
ODOM ROC DDO
MILES ODOM STATUS
5/01/02 I 9/16/04
DATE PA TITLED DATE OF ISSUE UNLADEN WEIGHT GVWR GCWR TITLE BRANDS
REGISTERED OWNER(S) ?' )
,?„O pry
e
COURTNEY C BRADLE4 °'T ` ,rl,.ll
1864 WALNUT BOTTOM AD.
NEWVILLE PA 17241
FIRST LIEN FAVOR OF: SECOND LIEN FAVOR OF:
PSECU
FIRST LIEN RELEASED
DATE
MAILING ADDRESS
AUTHORIZED REPRESENTATIVE
ODOMETER STATUS
0 = ACTUAL MILEAGE -
I = MILEAGE EXCEEDS THE MECHANICAL
LIMITS
2 = NOT THE ACTUAL MILEAGE
3 = NOT THE ACTUAL MILEAGE-ODOMETER
TAMPERING VERIFIED
4 = EXEMPT FROM ODOMETER DISCLOSURE
TITLE BRANDS .
A = ANTIQUE VEHICLE
C e CLASSIC VEHICLE
O = COLLECTIBLE VEHICLE
F = OUT OF COUNTRY ' '
G OFIGIN ILLY MFGD FOR NON U .S.
DISTRIBUTION
H =AGRICULTURAL VEHICLE
L = LOGGING VEHICLE -
P = ISWAS A POLICE VEHICLE
R = RECONSTRUCTED.:
S - STREET ROD
T RECOVERED THEFT VEHICLE
V < VEHICLE CONTAINS REISSUED VIN
W = FLOOD VEHICLE
X P ISMAS A TAXI
It a second Ifenholder is listed upon soU.aiaction 61 the hmt Ilon the Aral
fienholder must forward this Title to the Bureau 6f,; Motor V&00 wdh `lhe
appropriate form and I I 4A
SECOND LIEN RELEASED
DATE
BY
AUTHORIZED REPRESENTATIVE
PSECU
P 0 BOX 67013
HARRISBURG PA 17106
CD
N
W
N
C]
I certify as of the date of issue, the official records of the Pennsylvania Department ALLEN D B I E H L E R
of Transportalton reflect that the person(s) or company named herein is the lawful owner
• of ft said vehicle. Secretary of Transportation
SUBSCRIBED AND SWORN
TO BEFORE ME:
J
EXHIBIT
20 3
The -d-ped hereoy makes eppr ,Iwo for Genii- d Tine I, Me ?.NFW M, eeed ?
move. subleu ro me en-b.... es nd o:he, Ieyal Elains sel lonh hen.
SIGNATURE OF APPLICANT OR AUTHORIZED SIGNER
SIGNATURE OF CO-APPLICANT,71TLE OF AUTHORIZED SIGNER
If a co-purchaser other than your spouse is listed and you want the title to
be listed as "Joint Tenants With Right of SurviYorship" ((?n death of one
owner, title goes to surviving owner.) CHECK. HERE O. Qjiherwlsk th0ttle
will be issued as "Tenants In Common' (On death of one 8wner, loterest,of,
deceased owner goes to his/her heirs or estate).
1ST LIEN DATE: --, IF NO LIEN, CHECK
1ST LIENHOLDER
STREET - -
CITY STATE ZIP
IF THIS IS AN ELT, CHECK HERE ? FINANCIAL
NOTE: FIN REQUIRED INSTITUTION NO.
2ND LIEN DATE: ---? IF NO LIEN, CHECK
2ND LIENHOLDER
STREET
CITY STATE ZIP
IF THIS IS AN ELT, CHECK HERE ? FINANCIAL
NOTE: FIN REQUIRED INSTITUTION NO.
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PSECO
COURTNEY C BRADLEY
1864 WALNUT BOTTOM RD
NEWVILLE, PA 17241-9510
Dear COURTNEY C BRADLEY:
`/
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08/15/2007 do L/ (P
Your L10 Auto Loan was due on 06/15/2007; the amount needed to bring your account current is $915.24.
This is a serious situation that needs your immediate attention.
PSECU is willing to negotiate a reasonable repayment arrangement. Call immediately to advise us of the
action you are taking to resolve the delinquency on your account.
This is your final notice. Failure to comply by 08/25/2007 may result in legal action against you and
your credit history will be reported to all the national credit bureaus. All court costs and fees will be
your responsibility.
If you have any questions, call 234-8484 in Harrisburg or call our toll-free number, (800) 237-7328. At the
menu prompt, enter 6 then extension 3116. We are open from 8 a.m. to 5 p.m. Monday through Friday and
8 a.m. to noon on Saturday.
Sincerely,
cc??o
Cortny Hartman
Account Advisor
CERTIREE
(Domestic Mail Oi
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Postage
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(Endorsement Required)
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EXHIBIT
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° Sent To
° COURTNEY C BRADLEY
? Street, Apt. Ni
or PO Box No 1864 WALNUT BOTTOM RD ,____ Pennsylvania State Employees Credit Union
City",Sttits, i, NEWVILLE, PA 17241-9510 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD)
trotion. Equal O
pporfunify Lender www.psecu.com
PSECO
12/18/2007
Via Certified and First Class Mail
COURTNEY C BRADLEY
1864 WALNUT BOTTOM RD
NEWVILLE, PA 17241-9510
NOTICE OF REPOSSESSION AND RIGHT TO REDEEM
You are hereby notified that your 2002 Honda Accord, VIN# 1HGCG16512A056495, has been
repossessed by the Pennsylvania State Employees Credit Union ("PSECU"). You have failed to pay the
08/15/2007 installment due under the above Loan and Secuirty Agreement (the "Contract").
The motor vehicle is currently being stored by: Richard & Associates, 3999 Spring Rd, Shermans Dale, PA
17090; 717-241-5884. You may redeem the motor vehicle and terminate the Contract by paying the
following amounts on or before 5:00 p.m. on 01/02/2008.
Unpaid principal balance $10,827.28
Accrued Interest $161.23
ADDITIONAL COST IF REPOSSESSED MORE THAN 15 DAYS AFTER DEFAULT
Repossession Expense $325.00
Storage expense @ $20 per day (12/18/07-1/2/08) $300.00
Late Fees $45.76
Other Charges
Total Cost to Redeem $11,659.27
Payment to redeem must be in cash, certified funds or a cashier's check.
We will sell the 2002 Honda Accord at private sale sometime after 01/02/2008. The money that we get
from the sale (after paying our costs) will reduce the amount you owe. If we get less money than you owe,
you will still owe us the difference. If we get more money than you owe, you will get the extra money
unless we must pay it to someone else, or use it to pay other loans you owe to PSECU. You can get the
property back at any time before we sell it by paying us the full amount you owe (not just the past due
payments), including our expenses. If you want us to explain to you in writing how we have figured the
amount that you owe us or you need more information about the sale, you may call us at
(717) 234-8484, ext. 3116 or (800) 237-7328 or write us at PSECU, P.O. Box 67013, Harrisburg, Pa.
17110-2990, and request a written explanation. You should also contact us if you are unable to pay the
foregoing amount in full prior to the above deadline. PSECU n:ay allow you to reinstate your loan, if
you qualify, upon payment of the arrears and additional costs only.
We are sending this notice to the following other people who have an interest in the collateral listed or who
owe money under your agreement: (Names of all other debtors and obligors, if any)
You have 30 days to make arrangements to take possession of the personal effects found in the vehicle.
Failure to recover them in this time period will result in disposal of such personal effects.
cer
EXHIBIT 0 [??
Shawna Tingle
Account Advisor
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 171 10-2990 717 234.8484 800.237.7328
Mailing Address: PO. Box 67013, Harrisburg PA 17106-7013 • 717.777 2100 (TDD) • 800'..472 1967 (TDD) ,
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.com
PSECO
02/25/2008
COURTNEY C BRADLEY
1864 WALNUT BOTTOM RD
NEWVILLE, PA 17241-9510
Dear COURTNEY C BRADLEY:
Your repossessed vehicle has been sold. The total amount owed the Credit
Union after the disposal of your vehicle is $5,616.27. Listed below is the
breakdown of charges and proceeds realized on the sale:
Balance as of last payment date $10,827.28
Interest $161.23
Charges:
Repossession Fee $325.00 .
Auction Fee $257.00
Other Fee
Late Fee $45.76
Total Charges $627.76
Less Credits:
Insurance (collision)
Sale of car $6,000.00
Payment
Total Credits $6,000.00
Total Amount Due $5,616.27
This balance is payable immediately. Unless we receive payment in full by
March 6, 2008, we may proceed with legal action. If you have any questions
regarding this matter, you may contact me at (800) 237-7328. At the menu
prompt, enter Option 6, then extension 3116.
Sincerely,
EXHIBIT ? ° U
?;hTingle
Account Advisor
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
Mailing Address: PO_ Box 67013 Harrisburg, PA 17106-7013 717.777 21000?TDD) - 800.472 1967 (TDD)
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.com '
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C3 COURTNEY C $RrApLE.Y
1864 WALNUT BOTTOM RD------------
NEWVILLE, PA 17241-9510 --_--______-
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VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities, that she is an attorney for the Plaintiff herein and makes this
Verification based upon the facts as supplied to her by the Plaintiff because the Plaintiff is
outside the jurisdiction of the court and the Plaintiff s Verification cannot be obtained within the
time allowed for the filing of this pleading; and that the facts and circumstances set forth in this
pleading, are true and correct to the best of her knowledge, information and belief.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Amended
Complaint has been sent to the following parties by first class, U.S. Mail, postage prepaid, this
lh- day o \ 1 t 2009, as follows:
Geoffrey M. Biringer, Esquire
MidPenn Legal Services
401 E. Louther Street
Suite 103
Carlisle, Pa 17013
l?
Lyn ay E. Ro d, P-sgfzire
Pa. IUD. 4 2055
WELTMAN, WEINBERG, & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: (412) 434 - 7955
Fax: (412) 338 - 7130
WWR4 7057515
rl
C-1t: THE-
:r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION
Plaintiff
VS.
COURTNEY BRADLEY
Defendant
No. 08-7513-CIVIL
PRAECIPE FOR SUBSTITUTION OF
VERIFICATION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Lyndsay E. Rowland, Esquire
PA I.D. 205520
Weltman, Weinberg & Reis Co., L.P.A
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#7057515
I.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION
Plaintiff
VS.
COURTNEY BRADLEY
Defendant
Civil Action No. 08-7513-CIVIL
PRAECIPE FOR SUBSTITUTION OF VERIFICATION
TO THE PROTHONOTARY:
At the request off the undersigned attorneys for the plaintiff, you are directed to substitute the
verification in the civil complaint in the above caption matter.
WELTMAN, WEINBERG & REIS CO., L.P.A.
E. Rowland, Esquire
05520
Pittsburgh, PA 15219
(412) 434-7955
WWR #7057515
Weltman, Weinberg & Reis Co., L.P.A
1400 Koppers Building
436 Seventh Avenue
16
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904
relating
to unsworn falsifications to authorities, that he/she is (I? o6m Q116 J L'+ LC
(NA.ME)
CM0 U
Cp of ??Zge plaintiff herein,
that (TITLE) (CO?)
he/she is duly authorized to snake this verification, and that the facts set forth in the foregoing
Amended Complaint are true and correct to the best of his/her knowledge, information and
belief.
(SIGNATURE)
CERTIFICATE OF SERVICE
A true and correct copy of the within Plaintiff's PraecipJJe For Substitution Of Verification has been
served by U.S. Mail, Postage Pre-Paid, onday of`--'Ln 2009 upon the following:
Geoffrey Biringer, Esquire
MIDPENN LEGAL SERVICES
401 E. Louther Street
Carlisle, PA 17013
By
20C, 9 V!;1. 30 Pit 2: 52
7?, , P
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION
Plaintiff
vs.
No.08-7513 CIVIL TERM
STIPULATION OF THE PARTIES FOR
PAYMENT AND FOR THE ENTRY OF
JUDGMENT BY CONSENT
COURTNEY BRADLEY
AKA COURTNEY C BRADLEY
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Lyndsay E. Rowland, Esquire
PA I.D. #205520
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#7057515
Judgment Amount: $6,690.76
/'
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION
Plaintiff
VS.
Civil Action No. 08-7513 CIVIL TERM
COURTNEY BRADLEY
AKA COURTNEY C BRADLEY
Defendant
PRAECIPE FOR JUDGMENT BY CONSENT
TO THE PROTHONOTARY:
Kindly enter Judgment against Defendant, COURTNEY BRADLEY, in the amount of $6,690.76
plus costs, based upon the consent of the parties.
CONSENTED TO:
WELTMAN, WEINBERG & REIS CO., L.P.A., COURTNEY BRADLEY
AKA COURTNEY C BRADLEY,
By:
Attorn for Plai i
WWR#7057515
!,
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION
Plaintiff
VS.
COURTNEY BRADLEY
AKA COURTNEY C BRADLEY
Defendant
Civil Action No. 08-7513 CIVIL TERM
STIPULATION OF THE PARTIES FOR THE ENTRY OF JUDGMENT BY CONSENT
TO THE PROTHONOTARY:
Kindly enter Judgment in favor of Plaintiff and against the Defendant, COURTNEY BRADLEY,
above-named, in the amount of $6,690.76 pursuant to the Stipulation of the Parties for the Entry of
Judgment by Consent, as follows:
Defendant admits indebtedness to Plaintiff in the amount of $6,690.76 with continuing
interest thereon at a rate of 6.00% per annum plus costs from August 18, 2009.
2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by
Consent will be entered in favor of the Plaintiff and against the Defendant, COURTNEY BRADLEY, in
the amount of $6,690.76 plus continuing interest thereon at the rate of 6.00% per annum from August 18,
2009 and costs.
No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall
constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the
Defendant in this Stipulation which the parties agree is final and complete.
i' ..
r
4. Intending to be legally bound, the parties set their hands and seals this ? day of
By:
WEL
PA I.D. #20590
WELTMAN, WEINBERG & REIS CO.,
L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 7057515
By:
COURTINE'A BRADLEY
mil}-OrFICE
OF THE 1-' ONO"j"ARY
2009 SEP -8 PM 1: 24
cum - :: ) ` fui iNi`r
PIENNSYLVRNIA
414.oo Pry AT"
au.* m 110(9A
e a3o.-19(,0
a ? .
a?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION
Plaintiff
VS.
COURTNEY BRADLEY
AKA COURTNEY C BRADLEY
Defendant
Civil Action No. 08-7513 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that
the following Order or
Judgment was entered against
you on `i
01
(xx) Assumpsit Judgment in the amount
of $6,690.76 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or
registration will be suspended by the Department of
Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
Court Order
( ) Non-Pros
( ) Confession
( ) Default
( ) Verdict
( ) Arbitration
( ) Award
(XX) By Consent
Prothonotary
Courtney Bradley
24 Thrine Ave
Mt Holly Spgs, Pa 17065
By:
PRO ONOT O E UTY)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION
Plaintiff
VS.
COURTNEY BRADLEY
AKA COURTNEY C BRADLEY
Defendant
Civil Action No. 08-7513 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER.
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that
the following Order or
Judgment was entered against
you on q o _
(xx) Assumpsit Judgment in the amount
of $6,690.76 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or
registration will be suspended by the Department of
Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
( ) Default
( ) Verdict
( ) Arbitration
( ) Award
(XX) By Consent
Prothonotary
Geoffrey Biringer, Esq.
M`dpenn Legal Services
401 E. Louther Street, Ste 103
Carlisle, Pa 17013
By:
PR ONOTARY UTY