HomeMy WebLinkAbout09-0525
NOTICE TO DEFEND
Pursuant to PA RCP No. 1018.1
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
JOSEPH E. BRAS,
Defendant
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 09. 5a5 0'iyil-Fam
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 to you for any money claimed in the Complaint
or for any other claim or relief requested by Plaintiff(s). You may lose money or property or
other rights important to you.
24944801
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
JOSEPH E. JIRAS,
Plaintiff
V.
Defendant
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. D 9 . ?6--2l
COMPLAINT
Plaintiff, Pennsylvania State Employees Credit Union ("PSECU") is a
Pennsylvania financial institution having an office at One Credit Union Place, Harrisburg,
Pennsylvania 17110.
2. Defendant, Joseph E. Jiras, is an adult individual with a last known address of
2014 Lincoln Street, Camp Hill, Pennsylvania 17011-3841.
3. On or about April 12, 2005, Defendant applied for a Signature Loan and on April
19, 2005 executed an Activation Notice ("Activation Notice") with PSECU. A true and correct
copy of the Activation Notice is attached hereto as Exhibit "A" and incorporated by reference.
24944801
4. PSECU approved Defendant's application and opened an account (the
"Account") in Defendant's name.
5. Defendant received a disbursement on the Account for home improvements
subject to the terms and conditions of PSECU's Loanliner Credit and Security Agreement and
Loanliner Addendum ("Agreement"). A true and correct copy of the Agreement is attached
hereto as Exhibit "B" and incorporated by reference.
6. Defendant is in default under the Account for failure to make payments when
due.
7. Several notices of default were sent to Defendant: on April 11, 2008, June 2,
2008, July 3, 2008, July 31, 2008, and August 11, 2008. A true and correct copy of the notices
are attached hereto as Exhibit "C" and incorporated by reference.
8. The balance due and owing to PSECU from the Defendant on the Account is
$6,811.83, plus collection costs of twenty percent (20%) or $1,362.36, which totals $8,174.19
plus costs.
9. PSECU has demanded payment from Defendant, but despite these demands, the
Defendant has refused and continues to refuse to make payments.
10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.,
Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in
writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and
provide Defendant with written verification thereof; otherwise, the debt will be assumed to be
valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for
24944801
2
Plaintiff will send Defendant the name and address of the original creditor if different from the
above.
WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment
in its favor and against Defendant, Joseph E. Jiras, in the amount of $8,174.19, and costs of suit.
BARLEY
Date: By:
Shawn M. Long, Esquire
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
24944801
3
VERIFICATION
Pennsylvania State Employees Credit Union v. Joseph E. Jiras
I, Gregory R. Diffenderfer, being duly affirmed according to law, depose and say that I
am the Collection Manager for Pennsylvania State Employees Credit Union; that I am authorized
to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are
true and correct to the best of my knowledge, information, and belief.
To the extent that any of the averments in the foregoing document are based upon the
understanding or application of law, I have relied upon counsel in making this Verification.
This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to
unsworn falsification to authorities.
Dated: ? O
Gregory R. Diffenderfer
Complaint (Signature Loan) - PSECU Jiras
SIGNATURE LOAN.ACTIVATION NOTICE
April 13, 2005
Applicant
Information: SS #: 190-50-4329
Ref #: 448713 598
Approval Amount: $10,000.00
Account Number: 0190504329
Applicant: JOSEPH E JTRAS
Work Telephone #: (717) 780-6700
Home Telephone #: (717) 731-0939
Signature: I acknowledge receipt of the PSECU LOANLINER Disclosure and Credit Agreement and
agree to be bound by the terms set forth in said agreement.
0 1Q 6
Signa of JOSEPH E J S Bat
SIGNATURE LOAN OPTIONS
Purpose: /---Z0 hi <. 1 AV /7 LG {,?f
Please select one of the following Signature Loan disbursement options:
Send a Ff check, or ? deposit to my Share 4 (MoneyHandler/Checking Shares)
Please select one of the following Signature Loan repayment options:
? Payroll Deduction ? Automatic Transfer ? Direct Payment
? Self Service Telephone )Z Coupon
? Homebanking
LBIT A
PSE(O
the financial link.
Pennsvfv?ania State Ernyees Credit Union
P.0. Box 87013 • Ham'sbcrrg, P4 17106-7013 • (717) 234.8484 Harrfsburg, (800) 237-7328 Natlonwlde
Loan Disclosures
This LCyWIJNER' Credit ==r% Agreement, which includes the Truth in
Lending Qisdoeures, will be the Plan. The Plan documents include this
agreement and an Addendum. You, your and bortnwer mean any parson who signs
the Plan. Credit union, we, our and us mean PSECU or anyone to whom the Credit
Union transfers Its rights under the Plan.
HOW THIS PLAN WORKS - This is an open-end, mutt)-featured credit plan. We
anticipate that, from time to time, you will borrow money (called "advances') under
the Plan. We am not required to make advances to you under the Plan and can
refuse a request for an advance at any dnm The Addendum describes the
different types of credit (called'subaccountsl available under the Plan, the current
interest rate for each subaccount expressed as a daily periodic rate and
corresponding annual percentage rate and other charges. It may also have other
terms and a schedule for determining the payment amounts.
CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain
subaccounts. if a credit limit is set for a subaccount, you promise not to exceed the
established credit Hmtt. If you exceed the credit limit, you promise to repay
immediately the amount which exceeds the credit limit.
REPAYMENT - You promise to repay all amounts you owe under the Plan plus
interest. Payments are due on the last day of the month unless we set a different day
at the time of an advance, if the Addendum has no payment schedule for a
subac count, your payment will be determined at the time of each advance.
Payments must include any amount past due and arty amount by which you have
exceeded any erect limit you have been given for a subaceount You may repay all
or part of what you we at arty time without any prepayment penalty. Even If you
prepay, you will still be required to make the regularly scheduled payments unless
we agree in writing to a change In the payment schedule. If you have a joint
sharedraft account, you will be responsible for paying all overdraft advances
obtained by a joint holder of the sharedraft account Unless otherwise required by
law, payments will be applied to amounts owed 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 card to access the Plan, you may be amble brew
unauthorized use of your ATM/Debit card, You will not be liable for unauthorized use
that occurs after you notify us, orally or in writing, of the kiss, theft, or possible
unautltortmd use. It you believe your ATMIDWA card has been lost or stolen,
Irrttedls- inform the Credit Union by caring 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 $W H the uneuthorized
withdrawal is from a sharedraft account, your liability is governed by the Regulation E
disclosures you received at the time you received your ATM/Dealt card, even If the
withdrawal results in an advance being made from your overdraft subaccount.
FINANCE CHARGE - The dollar amount you pay for money borrowed is called a
'finance charge' and begins on the date of each advance. A finance charge will be
computed separately for each separate balance under the Plan. To compute the
flnarcearge, the unpaid balance for each day since your last payment (or since
an advance N 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 wKhich
are disclosed on the Addendum. Of the interest rate is a variable interest rate, the
Addendum explains how the variable interest rats works.
SECUIRMY - You pledge as security W the Plan an shares and dividends and, if
any, all deposits and Interest in all joint and individual accounts you haw with us
now and in the future. If a specific dollar amount is pledged for an advance, we will
freeze shares In that account to the extent of the outstanding balance for the
advance. Otherwise. your pledged shares may be withdrawn unless you are in
default The following paragraph epplles in all states except in Ohio, Rhode
Island and Massachusetts: We have a statutory Han on the shares and dividends
and, If any, the deposits and interest In all individual and joint accounts you have with
us and may exercise our rights urWer the lien to the extent permitted by state law.
(We are state chartered if our name does not Include the term "Federal Credit
Unbn.1 For all borrowers: The statutory Ilan and/or your pledge will allow rue
taexortm(s} to what you owe when you are In defau L
ur pledge do rot apply to any Individual Retirement
nt that would lose special tax treatment under state or
federal law if given as security.
Additional security for the Plan may be required at the time of an advance. If a
subaccount identifies a type of property (such as New Cars") you must give that
type of property as security when you get an advance under that subaccount A
subaooount name such as 'Other Secured' means you must provide security
acceptable to us when you obtain an advance under that subacco um. Property you
give as security will secure all amounts owed under the Plan and all other loans you
have with us now or in the future, except any loan secured by your principal dwelling.
Property securing other loans you have with us may also secure the Plan.
CREDIT INSURANCE - Credit life and/or credit disability insurance is optional
under the Plan If you qualify for and purchase the insurance from us, you authorize
us to add the insurance premiums monthly to your loan balance and charge you
O WkA MUTUAL GROUP. 1980. S2. 84. 86, 89.96.99.2000. 01.02.03.06.06. ALL RQfTS RESERVED
Interest on the entire balance. If you elect credit insurance, your payments may
Increase or the period of time necessary to repay your advance may be extended.
The credit insurance rates may change during the Plan. if the rates change, we will
provide any notices required by applicable law.
PERIODIC STATEMENT- On a regular basis you will receive a statement showing
all transactions under the Plan during the period covered by. the statement.
Statements and notices will be sent to you at the most recent address you have
given us in writing. Unless applicable law requires notice to each joint borrower,
notice to any one of you will be notice to all.
JOINT ACCOUNTS - If this is a joint account, each of you Is individually and jointly
responsible for paying all anwurtts owed. That means we can srtforoe our rights
under the Plan against arty one of you individually or against all of you together. If you
give us inconsistent instructions, we can refuse to follow your Instructions. Unless our
I written policy requires all of you to sign for an advance, each of you authorUes the
other(s) to obtain advances Individually and agrees to repay advances made to the
other(s). Any joint accountholder nay terminate the Plat by giving us prior written
notice. If any of you terminate the Plan, the Plan is temdnated for all of you. You
remain liable individually and jointly for all advances Incurred before termination.
FEES AND CHARGES - if you glue us a security interest In certain types of
property, we may charge you a Ming fee to perfect our Interest In the property. If we
do, the amount of the fee will be disclosed to you at the time you obtain an advance.
We may also charge you other We In connection with the Plan. Our current fees are
disclosed on the Addendum and will be added to your ban balance unless you pay
therm In cash.
UPDATING CREDIT INFORMATION - You promise that you will promptly give us
written notice if you move, change your name or employment, or if any other
information you provided to us changes. Upon our request, you also agree to
provide us updated financial information.
DEFAULT - The tollowtng paragraph appose to borrowers In klsho, Kwisse,
Maine and South Carof lrw: You will be in default if you do not make a payment of
the amount required when it is due. You will also be in default if we believe the
prospect of payment, performance, or realization on any property given as security
is significantly Irgxaired.
The O li milng paragraph applJee only to borrowers In Wboonafn: Ybu will be In
default If you fail to make a payment when due two times during any 12 month
period. You will be In default if breaking any promise made under the Plan materially
impairs your ability to repay what you owe or materially Impairs the condition, value,
or protection of or our right in any property you gave as security.
The ttvlfowing paragraph appxlfaa only to boniowws In kim: You will be in
default if you are more than 10 days late In making a payment. You will afro be in
default if you do not comply with the terms of the Plan and your failure to comply
materially impairs any property you gave as security or your ability to repay what you
owe under the Plan.
The fofkmfng Paragraph appltea to borrowers In aft oprar afatas: You will be In
default If you do not make a payment of the amount required when It is due. You will
be In default if you break any promise you made under ft Plan or 0 anyone Is In
default under arty security agreement made in connection with an advance under
the Plan. You will be in default 0 you die, file for bankruptcy, booome Insolvent, If you
make any false or misleading statements in any cnxk application or update of credit
information, or if something happens we bellow may substantially reduce your
ability to repay what you owe. You will be In default N any property you have givert
Darr, or security Is else by someone ?• setzed under a lorkiture or simllar
arty#gng happens that significantly uNflcts the value of the property or
our security interest in it. You will also be in default under the Plan 0 you are in default
under any other ban agreement with us.
ACTIONS AFTER DEFAULT - The Aofiow V applNs to 40vrotsus in
Colorado, I7tabfot of Cawnbfs, kuwal, Kanars"iAiatisad>rMSfb, +Mpiraoart,
i obrtssks, South Carotins aid What VWVNM When you are In deleult and after
expiration of any right you haw under applicable state law to acre yore dsfactt, we can
demand immediate payment of the entire unpaid balance under the Plan without
giving you advance notice.
TheA*ow/ngparagraphapplies krbona" toallatlMra/elaa?aer?twb onabr
and LoulAlleru: When you are in default, we can roquhe irarwdets payment
(acceleration) of the entire unpaid balance under the Plan. You waive any ripftt you have
to demand for paymett notice of I lent to accelerate and nodoe of soceferallon.
The lbilowing paragraph* apply to borrowers In aU ahbe WA74W NRioorakr and
Louralano: If Irnmedate payment is demanded, you wig continue to pay Interest until
what you owe has been repaid at the applicable Interest rates It effect or, If applicable,
at the default rate disclosed on the Addendum. h a demand for immediate payment
has been made, your shame and/or deposits can be applied towards what you owe
as provided in the section above called 'SeaxrW We can also exercise any other
rights given by law when you are in default.
You agree the Credit Union has the right to taka possession of any prop" given
as security under the Plan, without judicial process, It this can be done without
breach of the peace. If we ask, you promise to deliver the property at a time and
place we choose. It the property is a motor vehicle or boat, you agree that we may
CPSM01
PSECU FORM 03146
.a3XX0061-2087.20BQ-1 (3106)
EXHIBIT B
L04 M)P 0000 not wrffi Could Axriyyie of (Conflitued)
obtain a key or other device necessary to unlock and operate k, when you are in
default We will not be responsible for any other property, not covered by this
Agreement. that you leave inside the property or that is attached to the properly. We
will try to return that property to you or make it available for you to claim.
After we have possession of the property, we can sell it and apply fits money to any
amounts you owe us. We will give you notice of any public disposition or the data after
which a private disposition will be held. Our expenses for taking possession of and
selling fie property will be deducted from the money received from the sale. Those
costs may include the cost of storing the property, preparing it for sate and attorney's
fees tdthe extent permitted under state law or awarded under the Bankruptcy Code.
You must pay any amount that remains unpaid after the sale money has been applied
to any unpaid balance under the Plan. You agree to pay interest on that amount at the
I same rate as the advance, or, d applicable, at the default rate disclosed on tine
Addendum, until that amount has been paid.
The foAowkg paragraph appess only to Wisconsin borrowers: When you are in
default and after expiration of any right you have under applicable state law to axe your
default, we may require immediate payment of your outstanding loan balance under the
i Plan and seek possession of property given as security. You may voluntarily give the
property to ire if you choose, or we may seek to take possession of fie property by
judicial process. if we repossess the property, you agree to pay reasonable exams
Incurred in disposing of the property. It the property is a motor vehicle, mobile home.
trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted
by Section 422.413 of be Wisconsin Statutes. You must pay any amount that remains
unpaid after the sale honey has been applied to what you owe under fie Plan. You
agree to pay interest on arty u ripakd amount at the same rate as fie advance, or, if
applicable, at the default rate disclosed on the Addendum, until that amount is paid.
If the property is located outside Wisconsin at the time of default, we may take
possession of the property without judicial process, if permitted by the state where
the property is located.
The followkVper aph appdoe only to Loulslarra borrowers: When you are in
default, we can require immediate payment (acceleration) of the en*e unpaid
balance under the Plan. You waive arty right you have to demand fax paymetrt, notice
of intent to accelerate and notice of acceleration. If immediate payment Is
demanded, you will continue to pay interest unfit what you owe has bean repaid at
the applicable interest rates in effect unless a default rate is died oaed out the
Addendum. If a demand for immediate payment has been made, the shares and
deposits given as security for the Plan can be applied towards what you owe. We
can also exercise any other rights given by law when you are in default and our
rights under any security agreements you have with us.
CANCELLING OR CHANGNNG THE PLAN - The foilowitrg paragraph appNes
only to borrowers In IAbx*: We have the right to change the terms of fife Plan from
time to time after giving you any advance notice required by law. Any change to the
interest rate or other charges will apply to future advances.
TTre bNoW ng paragraph .s Wee only to borrowers in Wisconsin: We can
change the terms of the Plan from one to time in accordance with Section 422.415
of the Wisconsin Statutes. You will be notified of any change in terms. An increase
in the daily periodic rate under a variable rate interest rate is not considered a
change in terms under the Plan. We can cancel the entire Plan or any part of the
Plan at any time. You may cancel the Plan at any time by giving us prior written
notice. Your obligation to pay the unpaid balances under the terms of fie plan
continues whether you or the credit union cancel the Plan, except to fie extent that
your liability is limited by Section 422.4155 of the Wisconsin Statutes.
The IoNawfrrQ paragraph rgrpllas only to borrorroa In Own: We can change the
terms of the Plan from time to tiros attar giving you any advance notice required
by
law. A change that increases the rate of finance charge or other ctrarge, that
increases the amount of your payments. or that otherwise adversely afleCls exietlrrg
balances will apply to existing balances only if you agree to the change or you use
the Plan after receiving notice that your use of the Plan means you agree fie
change applies to existing balances.
The bNowiltrig pWW4mph appbm to borrowers In all ottw states. We have ft
rim to change fie terms of the Plan from time to time after giving you any advance
notice required by law. Any change in the interest rate will apply to future advances,
and at our discretion and subject to any requirements of applicable law, will also
apply to unpaid balances.
TTre foilonfng ParWaph apples to sell but Wlseonsin borrowers: An increase in
the daily periodic rate under a variable interest rate Is not considered a change in
terms under fie Plan. We can cancel fie ernf re Prat or any part of fits Plat at any
time. Ybu may cancel the Plan at any time by giving us prior written notice. Your
obligation to pay the unpaid balances under fie terms of fie Plan continues whether
you or the Credit Union cancel the Plan.
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay
enforcing any of our rights under this Plan any number of times without losing fie
ability to exercise our rights later. We can enforce this Plan against your heirs or
legal representaUves. If we change the terms of the Plan, you agree that this Plan
will continue to protect us.
CONTINUED EFFECTIVENESS - If any part of this Plan is determined by a court
to be unenforceable, the rest will remain in effect.
NOTICE TO UTAH BORROWERS - This written agreement is a final expression of
the agreement between you and the Credit Union. This written agreement may not
be contradicted by evidence of any oral agreement.
TAO fabling is regetred by varment to it - NOTICE TO CO-SIGNER - YOUR
SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE
FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY,
THE LENDER WAS A LEGAL RIGHT TO COLLECT FROM YOU.
== oxring paraSlraphs eppNy H you give somwity In eonnectloin with an
tailor the Pier. Tahey apply to bonowa M allatata www L wwaru.
6a+isiana bo9"vwers wilt otecute a sspaaee aeC rIty apresmWIL borrowers In
other states may also be asked to execute a separate security agreernneft
THE SECURITY FOR THE PLAN - You give us what is known as a security
interest in all property described in any receipt, voucher or other document you
receive for an advance ("the Advance's The security interest you give Btdludes all
accessions. Accessions are things which are attached to or installed in the property
now or In fie future. The security interest also includes any replacements lbr the
property which you buy within 10 days of the Advance or any extension, renewals
or refinancing of the Advance. It also Includes any money you receive from selling
the property or from insurance you have on the property, if the value of the property
declines, you promise to give us more property as security if asked to do so.
WHAT THE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS
-The security interest secures the Advance described in the receipt, voucher or any
other document you receive at the time of the Advance and any extensions, renewals
or refinancings of the Advance. ft also secures any other advances you hew now
or receive in the future under the Plan and any o#w amounts or bars,
Including any credit card ban, you owe rn for any reason now or in the future,
except any loan secured by your prkrclpal residence. If the property is household
goods as defined by the Fedeial Trade Commission Credit Practices Rule, the
property will secure only the Advance and not other amounts you owe.
OWNERSHIP OF THE PROPERTY - You promise that you own all property you
give as security or If the Advance is to buy the property, you promise you will use
the Advance for that purpose. You promise that no one else has any interest In or
claim against the property that you have not already told us about. You promise not
to sell or lease the property or to use it as security for a ban with another creditor
until the Advance is repaid. You promise you will allow no other security interest or
lien to attach to the property either by your actions or by operation of law
PROPERTY INSURANCE, TAXES AND FEES - You must maintain property
insurance on all property that you give as security under fie Plan. You may purchase
the property insurance from anyone you choose who is acceptable to the Credit
Union. The amount and coverage of the property Insurance rrwst be acceptable to
us. You may provide the property insurance through a policy you already have, or
through a policy you get and pay for. You promise to make the insurance poll
payable to us and to deliver the
policy or proof of coverage to us if asked to do so.
If you cancel your insurance and get a refund, we have a right to the refund. If the
property is lost or damaged, we can use the insurance settlement to repair the
property or apply i towards what you owe. You authorize us to endorse any draft or
check which may be payable to you in order for us to collect any refund or benefits
due under your Insurance policy. You also promise to pay all taxes and fees (like
registration fees) due on the property.
If you do riot pay fie taxes or fees on the property when due or keep it insured, we may
pay these obligations, but we are not required to do so. Any money we spend for texas,
fees or insurance will be added to fie unpaid balance of fie advance and you will pay
interest on those amounts at fie same rode you agreed to pay on the advance. We may
receive payments in connection with the insurance from a company which provides the
insurance. We may monitor our bans for the purpose of
other borrowers have compiled with fie insurance requrermowhether you and
ban agreements
or may engage others to do so. The Insurance charge added to an advance may kxAxde t
(1) fie insurance company s payments to us and (2) the cost of determkwng compliance
with fie insurance requirements. If we add amounts for taxes, toss or Insurance to fie
unpaid balance of an advance, we may Increase your payments to pay the amount
added within fie term of the insurance or approximate term of fits advance.
INSURANCE NOTICE - If you do not purchase the required roperty insurance,
the insurance we may purchase and charge you for will cover on?y our interest in the
property. The premium for this insurance may be higher because the insurarnce
company may have given us the right to purchase Insurance after uninsured
collateral Is lost or damaged. The insurance will not be PAbltty Insurance and
will not satisfy any state f nencfof resparsWilty or no fault laws.
PROTECTING THE SECURITY INTEREST - If your state issues a title for the
property, you promise to have our security interest shown on the tide. We may have
to fie what Is called a financing statement to protect our security Interest from the
claims of others. If asked to do so, you promise to sign a financing statement You
also promise to do whatever else we think Is necessary to protect our security
interest in the property. You promise to pay all costs, including but not limited to any
attorney fees, we incur in protecting our security interest and rights in the property,
to the extent permitted by applicable law.
USE OF PROPERTY - Until the Advance has been paid off, you promise you will:
(1) Use the property carefully and keep it in good repair. (2) Obtain our written
permission before making major changes to the property or changing the address
where fie property is kept. (3) Inform us in writing before changing your address. (4)
Allow us to inspect the property. (5) Promptly notify us if fie property is damaged,
stolen or abused. (6) Not use the property for any unlawful purpose. (7) Not to retitle
property in another state without telling us.
NOTICE TO NORTH DAKOTA BORROWERS PURCHASING{ A MOTOR VEHICLE
- THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO
REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE,
AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN
THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE.
NOTICE FOR ARIZONA OWNERS OF PROPERTY - h is unlawful for you to fail
to return a motor vehicle that is subject to a security interest, within thirty days after
you have received notice of defatuft. The notice will be mailed to tfte address you
gave us. it is your responsibility to notify us if your address charges. The maximum
penalty for unlawful failure to return a motor vehicle is one year in prison and/or a
fine of $150,000.
This notice contains important information about your rights and our rem
under the Fair Credit Billing Act You are advised to read your monthly statement
and review it for any error discrepancies or unauthorized transactions.
NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR
STATEMENT. If you think your statement is wrong, or If you need more information
about a transaction on your statement, write us on a separate sheet at the address
bated on your statement You are required to notify us in writing within 80 days
lodowing the date on which we sent your statement wherein the error or problem
first appeared regarding any discrepancy or unauthorized transactions on your
account. Failure to notify us may result in your acceptance of any responsibility for
payment or reimbursement to us for any such error or discrepancy on your account
Write to us as soon as possible. You can telephone us, but doing so will not
preserve your rights.
In your letter, give us the following information:
Your name and account number.
The dollar amount of the suspected error.
Describe the error and explain, if you can, why you believe there is an error
If you need more information, describe the item you are not sure about
It you have authorized us to pay a credit card account automatically from your share
account or checking account, you can stop the payment on any amount you think is
wrong. To stop the payment your letter must reach us three business days before the
automatic payment is scheduled to occur.
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR
WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we
have corrected the error by then- Within 90 days we must either correct the error or
explain why we believe the statement was correct.
In this Agreement, the worsts you and yaw means each and of of those who apply
for the card or who signs this Agreement. Card means the Via Credit Card and arty
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 - Uwe issue you a card, you agree to repay all debts and the
Finance Charge arlsing 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 One card is recovered. You cannot disclaim
resporoibli ty 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 bean 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 rot 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 Credtt Cani, unless you are grossly negligent In the handling of your Card. In
any case, your liability will not exceed $50.
4. CREDIT LINE - If we approve your application, we will establish a "it-
replenishing tine of Credit for you and notify you of its amount when we issue the
card. You agree riot to let the account balance exceed this approved Credit Line. Each
payment you make on the account will restore your Cm* Line by the amount-of the
principal. payment which is applied to the ush Nbu rthu may request an increase In your Credit
Line only by written application 1
or ban officer: By diving you written notics we educe yiom' r cur credit e
from time
to We. or with may ?? your Credit Line f from time
good cause, revoke your card and terminate this Agreement. Good
cause includes your failure to comply with this Agreement or ary other agreement with
us, or our adverse reevaluation of your creditwortltiness. You may also terminate thin
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
surrarxfer to is all cards upon our request and upon termination of #us Agreemail .
5. CREDIT INFORMATION - You authorize us to investigate your credit standing
when opening, renewing or reviewing your account, and you authorize us to disclose
Information regarding your account to credit bureaus and other creditors who inquire
of us about your credit standing.
6. MONTHLY PAYMENT - We will mad you a statement every month showing you
Previous Balances of purchases and cash advances, the Current transactions on your
account, the remaining credit available under your Credit Line, the New Balances of
purchases and cash advances, the Total New Balance, the Finance Charge due to data,
and any other tilled fees, and the Mfntmun Payment required Every month you must pay
at least the Minirturn Payment within 25 days of you statement Closing data By separate
agreement you may authorize us to charge the minmum payment automatically to your
sham o a omi t with us. You may, of course, felt more frequeft pay more
than the Minimum Payrnent, or pay ft Total New Balance In full, and
will reduce the
finance charge by doing so. If your monthly payment exosecis the total tract fine balance
owed, vm will dutomaticady post the Credit to your 31 Maim
The minimum payment will be (a) 2°k 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
After we receive your letter, we carrot try m eollact any amount you question. or report
you as delinquent We can continue to send statements so you for the amount you
4uen, inckding finance charges, and we can apply any unpaid amount against your
credit limit, You do not have to pay any questioned amount while we are investigatng,
but you are ab'il obligated to pay the parts of your statement that are not in question.
It we find that we made a mistake on your statement, you will not have to pay any
finance charges related to any questioned amount. O we didn't matte a mistake, you
may have to pay finance charges, and you will have to make up any missed
payments on the questioned amount. In either case, we will send you a statement
of the amount you owe and the date that it is due.
If you fait to pay the amount that we think you owe, we may report you as delinquent.
However, if our explanation does not satisfy you and you write to us within ten days
telling us that you still refuse to pay, we must tell anyone we report you to that you
have a question about your statement. And, we must tell you the name of anyone
we reported you to. We must tell anyone we report you to that the matter has been
settled between us when it finally is.
If we don't follow these rules, we can't collect the first $50 of the questioned amount,
even if your statement was correct.
SPECIAL RULE FOR CREDIT CARD PURCHASES - It you have a problem with
the quality of property or service that you purchased with a credit card, and you
have tried in good faith to correct the problem with the merchant, you may have the
right not to pay the remaining amount due on the property or services. There are two
limitations on this right: (a) You must have made the purchase in your home state or,
if not within your home state, within 100 miles of your current malliing address; and
(b) The purchase price must have been more than $50.
These limitations do not apply if we own or operate the merchant, or if we mailed
you the advertsernent for the property or services.
demand. We will apply peymterts in the following manner, first to previous We lies,
them to previous cash advances finance charges, then to previous purchase finance
Charges, then to Current late fees, then to previous cash advance balances, than 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 state they are posted to your account, will be subject
to Finance Charge. Cash advances are always subject to Finance Charge from the
date they are posted to your account.
Purchases: We calculate your finance charge by multiplying the average adjusted
daily balance (see explanation below), including new purchases, for the billing cycle
by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE
RATE as disclosed on the Addendum.
Cash Advances. We calculate your finance charge on cash advances by
multiplying the average adjusted daily balance (see explanation below) for cash
advances during the billing cycle by the monthly periodic advance rate and
corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum.
Balance Computation Method
TransactionDaly filaktrice for Purdmisee - The Average s is calculated by adding the Daily Balances (PurchBalance ase Transaction) for
each day in the billing cycle, and than 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 psyments and credits, we subtnict Ina
amount of any unpaid Finance Charges or Late Charges Then we also subtract the
amount of any Cash Advance transactions that posted to your account on that day or
In any previous day in the billing cycle. This gives us the Dally Balaince for purchases.
Average D&ay Balance for Cash Advances - Cash Advance Transactions which are
posted to your account are not Included in the Average Defy Balance calculation for
purchases, and are therefore rot subject to the monthly periodic rats for push ises The
Average Daily Balance Is calculated separately for Cash Advances and is subject to the
Cash Advance Monthly Periodic Rate. The Average Dally Balance for Cash Transactions
is calculated by adding this Daily Balariors (Cash llranwcoon) for each day in the billing
cycle, and then dividing by the number of days to the billing cycle. To calculate the Daily
Balance for cash each day, we take the following stops: We take the oufalandng balance
(all amounts you owe) at the start of tine day. Then, in the sequence in which amounts
are posted to your acom", we add the amounts of of debits and subtract the arrhourits
of all credits or payments which post to your account that day. After applying payments
and credits, we subtract the amount of any unpaid Finance Charges or Late Charges.
Then we also subtract the amount of any Purchase Transactions that posted to your
account on that day or in any previous day in the billing cycle. This gives us the Daft'
Balance for Cash Advance Transactions. Nods: Cash Advenose are always atutifect to
finance charges and from the day they are ported to your ecoouaut
Payments are applied in the following manner: first to previous late fees, than to
previous cash advances finance charges, than to previous purchase finance
charges, then to current late fees, then to previous cash advance balances, Own to
previous purchase balances in the order that flay were posted to your account, Ihen
to current cash advance balances, and then to current purchase balances. Credits
are applied first to the particular type of debt which is being credited, if any, and then
to the balance of your account.
Vita' Credit Card Agrheernent and Truth In Lending Disclosure (condnued)
Note also that if the total of the payments and credits which are posted to your
account by the Payment Due Date shown on a statement is equal to or exceeds the
New Balance shown on that statement, we will not apply the Monthly Periodic Rate
to your Account on your next statement.
& DEFAULT - You will be in default if you fail to make any Minimum Payment
within 25 days after your monthly statement closing date. You authorize us to transfer
funds sufficient to make the minimum payment due if your Visa loan Is in default You
agree that we may temporarily suspend your ATM card access if your Visa payment
is due for a period exceeding 30 days. You will also be in default If your ability to
repay us is materially reduced by a change in your employment, an increase in your
obligations, bankruptcy or insolvency proceedings involving you, your death or your
failure to abide by this Agreement, or if the value of our security interest materially
declines. We have the right to demand immediate payment of your full account
balance if you default, subject to our giving you any notice required by law. To the
extern permitted by law, you will also be required to pay our collection expenses,
including court costs and reasonable attorney fees.
9. USING THE CARD - To make a purchase or cash advance, there are two
alternative prooedures to be followed. One is for you to present the card to a
participating Visa plan merchant, or another financial institution, and sign the sales
or cash advance draft which will be imprinted with your card. The other is to complete
the transaction by using your Personal Identification Number (PIN) in conjunction
with the card in an Automated Teller Machine or other type of electronic terminal that
provides access to the Visa system. You agree that you will not use your card for any
transaction that is illegal under applicable federal, stale, or local law. The monthly
statement will identify the merchant, electronic terminal or financial Institution at
which transactions were made, but sale, cash advance, credit or other slips cannot
be resumed with the statement You will retain a copy of such slips furnished at the
time of the transaction in order to verify the monthly statement. The Credit Union may
make a reasonable charge for photocopies of slips you may request.
10. OVERDRAFT OPTION - t you elect to overdraft to your PSECU Visa Credit
Card, that election is subject to the eodsting credit limit and the agreement it represents
and the current ban policy at the time of the overdraft. You also understand that an
overdraft will be considered the same as a cash advance on your PSECU Visa Credit
Card and that the current Annual Percentage Rate for cash advances will apply.
11. RETURNS ANO 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
Slip which we will post to your Visa line of credit. If your credit and payments exceed
what you owe us, we will 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 - The eucchange rate between the transaction
currency acid the billing currency used for processing intemational transactions Is a rate
selected by Visa from the range of rates available in wholesale currency markets for the
applicable central processing date, which rate may very from the rate Visa Itself
receives, or a govemmert-mandated rate in effect for the applicable central processing
data in each InstAroe, an ad*tnent may be assessed based on the ISA fee Imposed
by Visa. This tae, which totals 1 % of the transaction amount, will be assessed on all
transactions where the merchant county differs from the country of the card issuer.
13. DISL%ITIM V you disonroc or find an error with a Visa
ATM CARD CARDHOLDER AGREEMENT - The Undersigned (you or your), in
consideration of THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION (we,
our and us) issuing to you an ATM CARD, hereby agree to be legally bound by the
following terms and conditions. You agree that the use of your ATM card(s)
constltutes acceptance of the terms and conditions of this Agreement. You
understand that ATM Is a credit-related service and you authorize PSECU to obtain
a credit report on any users of this account.
1. ACCOUNTS AND USES OF ATM CARD -You have the account(s) (including
Checking and Regular Shares), which we set forth on your application form with this
Agreement. You hereby request that we issue to you one or more ATM CARD(s) to
be used in connection with such accounts as described in this Agreement.
You understand you may use the ATM CARD at a STAR SYSTEMSM ATM to (1)
withdraw cash from. (2) make or arrange for deposits in, (3) effect transfers to or from
your account, (4) receive information regarding the balance in your account(s) or (5)
make cash advances from your credit account(s) in the amounts you request. You may
also use automated teller machines throughart the United States and in certain
foreign countries which hear the PLUS SYSTEM® name and logo (1) to make
withdrawals from, (2) ailed transfers to or from. (3) receive information regarding the
balances in your Checking or Regular shares. It you have a Personal Service Loan
approved and in place. you may also matte a cash advance from your PSL. You further
understand 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. It you use the ATM CARD to make a Purchase to obtain
cash, if permitted by the Merchant, you shall be requesting us to withdraw funds in the
amount of such Purchase (including any cosh received from the Merchant) from your
Checking Shares and directing or ordering us to pay such funds to the Merchant
You request that we will provide to you such other services or access to other ATM
systems or networks using the ATM CARD which we may later make available and
which we advise you are offered in connection with your account(s) set forth on your
application form. You also understand that from time to time you may request in
writing that we provide access to additional accounts of yours through the ATM
CARD we have issued to you. You agree that the uses of the ATM CARD described
transaction, and have tried in good faith to correct the problem with the merchant or
the charges are the result of unauthorized or fraudulent use. or your purchase cost
more than $50 and was made from a plan merchant in your state within 100 miles
of your home, contact PSECU. You are required to notify PSECU in writing within 60
days folio" the date on which we sent your statement wherein the error or
problem first appeared regarding any discrepancy or unauthorized transaction on
your account. Telephoning PSECU does not preserve your dispute rights. You may
be required to provide us with documentation to support your dispute claims. In
addition. you may be required to complete a standard dispute form outlining the
details of your dispute. In cases of fraudulent card use, PSECU will also require a
notarized affidavit In some cases we may ask you to notify the local authorities.
if we do not receive the proper requested documentation in the time specified you
may be held responsible for the transaction(s) in question. PSECU must adhere to
strict dispute timetrames set forth by Visa.
14. SECURITY INTEREST-To secure your account, you grant us a purchase money
security interest under the Uniform Commercial Code in any goods you purchase
through the acoount. t you default. we will have the right to recover any of these goods
which we have no been paid for through our application of your payments in the manner
described in the Monthly Payment section. With rasped to this account only, we will not
assert any statutory right we may have 4 you are in default to prevent withdrawal of your
umpledged credit union shares (Deposits) below the unpaid balance of your account.
However, if you give or have given us a specific pledge of your credit union shares
(Deposits) by signing the Pledge of Shares or otherwise, or any other security Interests
for all your debts, your account will be secured by your pledged shares (Deposits) and
by the property described in Lose other security agreements, except for your tome.
15. EFFECT OF AGREEMENT - This Agreement is the contract which applies to
all transactions on your account even though the sales, cash advance, credit or
other slips you sign or receive may contain different terms. We may amend the
Agreement from time to time by sending you the advance written notice required by
law. Your use of the card thereafter will Indicate your agreement to the amendments.
To the extent the law permits, and we indicate In our notice, amendments will apply
to your existing account balance as well as to future transactions.
16. LATE PAYMENT CHARGE - it your Minimum Payment is not received by the
first day of the month following your due date, you will be subject to a $20 charge.
17. RUSH FEES - You may incur additional charges for rush processing and rush
delivery of cards and/or PIN mailer.
16. OVER LIMIT FEE -A $20 tee will be applied for each nhonthy statementg date
on which the outstanding balance exceeds the assigned credit limit by more then $100.
19. DRAFT COPIES - You may incur an additional charge for transaction
summary/sale draft documentation.
20. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement.
21. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use
your card for any transaction that is Illegal under applicable federal, stale, or local law.
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 neural network systems to predict and
prevent unauthorized transactions. There may be occasions when a transaction is
declined because it is indicative of possible fraudulent activity.
in this Agreement shat be subject to the rules and regulations of each account
which is accessed by such Card.
2. USE OF PERSONAL IDENTIFICATION NUMBER ("PIN-) WITH ATM CARD
You understand that a STAR SYSTEMS or a PLUS SYSTEM ATM is an automated
toiler. It can and will perform many of the same tasks as a human letter. You
acknowledge that the Personal Identification Number or PIN which you use with the
ATM CARD is your signature, klentilies the bearer of the Card to the STAR
SYSTEMS ATM, PLUS SYSTEM ATM. or other network ATM and authentlcales and
validates the directions given just as your actual signature and other proof identify
you and authenticate and validate your directions to a human teter. You also
understand that a Merchant which accepts the ATM CARD for a Purchase
transaction may have an electronic terminal (Merchant operated or Set-Service)
which requires the use of your PIN and when your PIN is used at a Momhanfe
terminal, it will authenticate and validate this directions given just as your actual
signature will authenticate and validate your directions given to us. You acknowledge
that your PIN is an identification code Mat Is personal and confidential and that the
use of the PIN with the ATM CARD is a security devise for your account(s).
Therefore, YOU AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO
ONE ELSE LEARNS YOUR PIN.
3. LIABILITY FOR UNAUTHORIZED TRANSACTIONS -You agree to contact us
at once if you believe the ATM CARD(s) issued to you or PIN has been lost or stolen
or money is missing from your account(s). You also agree that if your monthly
statement shows transactions which you did not make, and you do not contact us
within 60 days after the statement was mailed to you, you may rat get arty money
lost after that time. YOU AGREE THAT IF YOU GIVE YOUR ATM CARD(s) and PIN
TO SOMEONE ELSE TO USE YOU ARE AUTHORIZING THEM TO ACT ON YOUR
BEHALF AND YOU Will. BE RESPONSIBLE FOR ANY USE OF THE CARD(s) BY
THEM. You could lose all your money in the account(s) If you take no action to notify
PSECU of the loss of your ATM CARD or PIN. Safeguard your Personal
Identification Number (PIN). Do not tell or disclose your PIN to any other person, bo
not write your PIN on your ATM CARD. Do not keep a written record of your PIN near
your ATM CARD. Do not choose a PIN that is easily identifiable.
ATM Aomu=t and fl#gLdWW "E" 04008M
(contftwao
A new card may be ordered for you at that tore and a `hold' will be placed on your
old card. After such time, If you find your old card, destroy the old card by cutting it
in half. If you attempt to use your old card, it will not work
4. CHARGES - You agree to pay a 50 cent charge for each deposit or withdrawal
exceeding 15 a month. You agree to pay the 50 cent penalty charge on any rash
disbursement transaction (loan advance or share withdrawal) that is less than $20.
You agree to pay a 25 cent charge on each balance inquiry. You may Incur a charge
for any adjustment that needs to be made to your account resulting from an error
you made while making a deposit at an Automated Teller machine (ATM). You agree
to pay the charges or transaction fees which are charged by us for these services
or for services which may later be offered as such fees or charges may be imposed
or changed from time to time.
5. DEPOSITS - You agree that when you make a deposit at a STAR SYSTEMS
ATM that we have the right to verify the deposit before we make the money available
to you. If you deliver cash. checks or other items to a STAR SYSTEMS ATM, you
understand and adviawledge that the funds from your deposit may not be available
for Immediate withdrawal and that the availability of your deposit shag depend on our
rules and regulations regarding the particular account in which you are making a
deposit, the items that you are depositing and whether the deposit is made at a
STAR SYSTEMS ATM that is owned by us or another financial institution. You also
understand and acknowledge that not all STAR SYSTEMS AiMS may accept
deposits and some STAR SYSTEMS ATMS may limit the amount of funds which
may be deposited and that we may not control these limits.
6. LIABILITY - if the ATM CARD is issued for a joint account, you agree to be
jointly and severally liable under the terms of this Agreement and the agreement for
such account. You agree that if you make deposits or payments to your account(s)
with items other than cash (checks, drafts or other items) and we make funds
available to you from such deposits prior to their collection, you agree that we may
deduct the amounts of such fords from your account(s) which are not collected cc
if the funds in your socount(s) are insufficient at such time, you wilt promptly pay to
us any amount of such funds which are not collected.
7. AMENDMENT OF THIS AGREEMENT - You agree that from time to time we
may amend or change the terms of this agreement including amendments or
changes to add further ATM CARD services or to amend or change the charges for
these services. We may do so by notifying you in writing of such amendments or
changes and your use of the ATM CARD after the effective date of any such
amendment or charge shall constitute your acceptance of and agreement to such
amendment or charge.
8. O W14ERSHiP - You agree that the ATM CARD is our property and you will
surrender it to us upon our request. You agree that the ATM CARD is non-
transferable.
9. DISCLOSURES -You hereby acknowledge receipt of the disclosure statement
informing you of your rights under the Electronic Funds Transfer Act and a copy of
this Agreement.
REGULATION "E" DISCLOSURE
1. ELECTRONIC CHECK CONVERSK"ELECTRON11C RETURNED CHECK
FEES - If you pay for something with a check or share draft, you may autttorixe it
to be converted to an electrorile fund transfer. You may also authorize merchants to
electronically debit your account for returned check fees. You are considered to have
authorized these electronic funds transfers If you complete the transaction after
being tout (orally or by a notice posted or sent to you) that the transfer may be
processed electronically or If you sign a written authorization.
2. SUMMARY OF CONSUMER LIABILITY -
• ATM, ACH and SST - Tail us at once 9 you believe your card has been lost
or stolen. Telephoning is the beat way to keep your poeslbie bases down. You could
lose all the money k% your account plus your maximum overdraft fine of credit. If you
believe your card has been lost or stolen, and you tell us within two business
after you loam of the loss or theft, you can lose no more than, $60 if someone used
your card without your permission.
If you do not tell its within two business days after you learn of the loss or theft of
your card, and we can prove we could have stopped someone from using your card
without your permission it you had told us, you could lose as much as $500.
Also, if your statement shows transfers that you did not make, tell us at once. If
you do not tell us within 60 days after the statement was mailed to you, you may
not get back any money you lost after the 80 days if we can prove that we could
have stopped someone from taking the money If you had told us in time.
If a good reason such as a long trip or a hospital stay kept you from telling us, we
will extend the time periods.
3. TELEPHONE NUMBER AND ADDRESS TO NOTIFY OF UNAUTHORIZED
TRANSFERS -
• ATM - Contact PSECU at (800) 237-7328 EXT 3808 (nationwide) or (717)
2348484 ('m Harrisburg). After hours, follow the menu options on PSECU`s
voice mail system to report a lost or stolen card- For On Credit or Debit
Cards, bllow the diredlons for Lost Cord Notification undar ft Voss Credit
Card Agreement and Truth-in-Landing Disclosures section of this document.
• ACH and SST - Contact PSECU at (800) 237-7328 (nationwide) or (717)
234-8484 (in Harrisburg).
Or write to us at
Pennsylvania State Employees Credit Union
P.O. Boa 67013
Harrisburg. PA 17106-7013
PSECU Business Hours:
8:00 a.m. - 5:00 p.m. M -F
TDO (800) 472-1967 Nationwide
(717) 777-2100 in Harrisburg
4. FINANCIAL INSTITUTION'S BUSINESS DAYS -
• ATM, ACH and SST - PSECU's Busk*ss Days are Monday through Friday,
Holidays not included.
5. TYPES OF ELECTRONIC TRANSFERS A CONSUMER MAY MAKE =
• ATM - Balance inquiries on checking, savings and PSL; withdrawals from
chocking1savirigs; cash advance from PSL; deposits to checkbWsavuhgs;
purchase goods and services at any accepting retail establishment.
• ACH - Preauthortzed debits and credits to checking and savings.
• SST - Balance inquiries and transaction hletoriea an all share, certificate and
ban accounts; transfers from arty share to another share or ban account from
your PSL to any share or ban account; withdrawals from any share except
IRA shares or certificates.
6. ANY CHARGES FOR ELECTRONIC FUNDS TRANSFERS OR FOR THE
RIGHT TO MAKE TRANSFERS -
• ATM - Fifty cents for each disbursement (casts advance or withdrawal) less
than 520; fifty cents for each transaction over 15 per month; 25 cent for each
balance inquiry: and there may be an addkional charge for any adr,stmgnt
that needs to be made to the account of any member who makes an error
while depositing at an Automated War machine (ATM).
• ACH - $30 service charge for Insufficient funds for each aiectronlc transfer.
• SW - none
7. SUMMARY OF CONSUMER'S RIGHT TO RECEIVE DOCUMENTATION OF
EFTS -
• ATM - You are entitled to receive a printed receipt at the time of each
transaction. You will receive a monthly statement showing the status of your
account. any transactions made during the month, and any penalties or
charges PSECU may impose during the month.
• ACH avid SST - You will receive a monthly statement showing the status of
your account, any transactions made during the month, and any penalties or
charges PSECU may impose during the month.
• if you have arranged to have a direct deposit made to your account at least
once every 60 days from the aeme person or company, you can call us at
(800) 237-7328 to And out whether or not to deposit has been made.
8. STOP PAYMENT RIGHTS - PRE-AUTHORIZED TRANSFERS -
• ATM and SST - Not applbcabie.
• ACH - Right to Stop Payment and Procedures for doing so. If you have bid
us in advance to make regular payments out of your account, you can stop
any of these payments. Here's how: Call us at (800) 237-7328 (Nationwide)
or (717) 2348484 (Harrisburg) or write us at: Pennsylvania State Employees
Credit Union, P.O. Box 67013, Harrisburg, PA 17106-7013, in time for us to
receive your request three business days or more before the payment is
scheduled to be made. If you call, we may also require you to put your request
in writing and get it to us within 14 days after you cant.
• Notice of VwOng Amounts. If these regular pw#rw to may vary in amount,
the person you are going to pay wig tell you, 10 days before each payment,
when it will be made and how much it wi8 be. You may choose unsteed to get
this notice only when the payrrient woWd dil'far by more then a c ortsin amount
from the previous payment, or when the amount would fag outside certain
limits that you set-
• Uxbpftr for Fellure to Stop Psynow of PhwuV rfard 7hwurh rs. it you
order us to stop one of these payments three bueirheae days or more before
the transfer is scheduled, and we do not do so, we will be D" for your losses
or damages, unless we request and do not receive writer, confirmation of an
oral stop payment within 14 days and the transfer takes piece after 14 days,
or you fag to give us proper Istniodons that world enable us to piece the stop
on the transfer.
8. SUMMARY OF THE FINANCIAL INSTITUTION'S FAILURE TO MAKE OR
STOP CERTAIN TRANSFERS -
• ATM - if PSECU fails to complete a transaction on *no or in the correct
amount, when property inMrtictad by you, PSECU will be liable for damages
caused by our failure unless: (1) two are insufficient funds in your account to
complete the transfer, (2) the hinds in your account are unhoodected; (3) the
hinds are subject to legal prooess; (4) the transaction you requestwould eoosed
the kinds In Systems, PLUS account plus any available overdraft pralecbn; (5) the STAR
system has insufficient cash to complete the bvnescori; (8)
your card has been reported lost or stolen and you are using the reported card;
(7) PSECU has reason to believe that the transaction requested is
urutu otized; (8) the fWr8 iS due 10 8i1 flQUipf Wt Hi88kdM" MW you know
about when you started the transaction at the STAR Systems, PLUS System;
(9) the failure was caused by an ad of God, fire, or other catastrophe, or by any
other cause beyond control; (10) If you attempt to complete a transaction that,
m? at a STAR Systems, PLUS System, or merchant terminal that is not a
EIlsioranla Funds MMSter. ATM Agf tt and &g&II0 ^ E° !i[8ofo3t!r+
(C-0husdl
permissible transaction listed above; or, (11) the transaction would exceed the
security limitations on the use of your ATM CARD.
• ACH and SST - If PSECU fails to complete a transaction on time or in the
correct amount, when property instructed by you, PSECU will be liable for
damages caused by our failure unless: (1) there are insufficient funds in your
account to complete the transfer; (2) the funds in your account are
ur$x t tied; (3) the funds are subject to legal process; (4) the transaction you
netluest would exceed the funds in your account plus any available overdraft
crack (5) PSECU has reason to believe that the transaction requested is
unauthorized; (6) the failure was caused by an act of God, fire, or outer
catastrophe. or by another cause beyond control. In any case, PSECU shall
be liable only for actual proven and not consequential damages 9 the failure
to make the transaction resulted from a bona ride error despite PS£CU's
procedures to avoid such errors.
10. DISCLOSURE TO THIRD PARTIES -
• ATM, ACH and SST - PSECU will disclose information about your account to
third parties: (1) when it is necessary to complete transactions; (2) to verify
the existence and standing of your account with PSECU upon request of third
party, such as a credit bureau; (3) to comply with government agency or court
orders; (4) in accordance with your written permission; (5) to comply with
government or administrative agency summonses, subpoenas, or court
orders; (6) on receipt of certification from a Federal Agency or department
that a request for information is in compliance with the Right to Financial
Privacy Act of 1978; Regulation P, Privacy of Consumer Financial Information;
and (7) when it is necessary to take legal action to recover shares.
11. STAR SYSTEMS SERVICES -
• ATM Only -You may use your ATM CARD with your Personal Idanttfication
Number (PIN) at STAR SYSTEMS located in Delaware, Maryland, New
Jersey and Pennsylvania to conduct any of the following transactions for the
accounts accessed by your ATM CARD.
a) Determine the account balance(s) of your Checking your Regular
Shares, and your Personal Service Loan (PSL).
b) Withdraw rash from your Checking and your Regular Shares.
c) Make a cash advance from your Personal Service Loan (PSL).
d) Deposit currency, checks, or drafts (coins are not acceptable) for
transmission to PSECU for deposit in your Checking and your Regular
Shares.
NOTE: There are limited locations In Maryland where deposits may be made.
We wish to Inform you that some ATMs located in these areas may only provide
scow to your Checking, your Regular Shares, and your Personal Service Loan.
Not all ATMs may accept deposits. There may also be limits on the amount of
funds which you may deposit in certain ATMs.
12. PLUS SYSTEM' SERVICES -
• ATM Only - You may use your ATM CARD with your Personal Identification
Number (PIN) at any PLUS SYSTEM automated te0er machine
(PLUS SYSTEM ATM) located throughout the United States, Puerto Rico,
Canade, Great Britain and Japan to conduct any of the following transactions on
the accounts accessed by your ATM CARD.
a) Determine the account balance(s) of your Checking, your Regular
Shares, and your Personal Service Loan (PSL).
b) Withdraw cash from your Checking and your Regular Shares,
c) Make a cash advance from your Personal Servos Loan (PSL).
NOTE: Deposits are not avail" through PLUS SYSTEM ATMs.
These are the STAR SYSTEMS services currently available through the PLUS
SYSTEM network. Other services may be offered in the future.
13. OTHER ATM NETWORK ACCESS -
• ATM Only - From time to time, PSECU may make arrangements with other
ATM networks to grant access to ATM CARDS. PSECU "I 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 GARDs are
accepted by such Merchant. The amount of all such Purchases will be
dectucted 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 ON THE USE OF YOUR ATM CARD -
• ATM Only -You may withdraw up to $500 per day from one or a combination
of your accounts by using a ATM CARD provided the funds are available at a
STAR SYSTEMS or PLUS SYSTEM ATM. In addition, you may
withdraw/purchase up to $SW at point of sale iecations. PSECU reserves the
right to reduce this daily limit at any time. In the event that your daffy limit Is
less than $500, PSECU will advise you of the raw HmNabon. The day for
withdrawal limits starts at 12 midnight each day and ends at 12 midnight the
next day. For security purposes, there are also certain daily (irnltaitons on the
frequency of use of the ATM CARD. However, these limitations are not
revealed for security reasons. The Pennsylvania State Employees Credit
Union is not obliged to maintain such limitations.
You will be denied use of your ATM CARD if you exceed the daily
withdrawal/purchase limit, if you do not have adequate funds available in your
account, do not enter the correct Personal Identification Number (PIN), or
exceed the frequency of usage limitation. The receipt provided by the STAR
SYSTEMS or PLUS SYSTEM ATM or Merchant terminal will notify you of the
denial. There Is a limit on the number of such denials permitted. Attempts to
exceed the limit will result in machine retention of our ATM CARD. The number
of attempts that result in machine retention is not revealed for security purposes.
16. ERROR RESOLUTION PROCEDURES -
• ATM, ACH and SST - in case of errors or questions about your transactions:
Direct inquiries to PSECU at (800) 237-7328 Nationwide, TOD (800) 472-
1967 Nationwide, (717) 777-2100 in Harrisburg, or write PSECU at:
Pennsylvania State Employees Credit Union, P.O. Sox 67013, Harrisburg, PA
17106-7013, as soon as you can 4 you think your statement or receipt is
wrong, or it you need more information about a transaction Gated on the
statement or receipt PSECU must hear from you no later than 80 days after
it sent you the first statement on which the problem or error appeared. You
must provide the following information: (a) Your name, account number, and
ATM CARD number (if a ATM transaction), or reference number (if Self-
Service Telephone Transaction); (b) Describe the error or the transaction you
are unsure about, and explain as clearly as you can why you believe it is an
error or why you need the information, and; (c) The dollar amount of the
suspected error.
If you tell PSECU orally, you must send your complaint or question in writing
within 10 business days. PSECU will tell you the rester of the invesstigatlon
within 10 business days for STAR SYSTEMS, PLUS SYSTEM, SELF-SERVICE
TELEPHONE, or DIRECT DEBIT/CREDIT TRANSACTIONS, or 20 days for
STAR SYSTEMS purchase transactions. If we need more time, however, we may
take up to 45 days for STAR SYSTEMS, PLUS SYSTEM, SELF-SERVICE
TELEPHONE, or DIRECT DESIT/CREDiT TRANSACTIONS or 90 days for
STAR SYSTEMS purchase transactions. If PSECU decides to do this, it will
recredh your account within 10 business days for the amount you think is in error
it it is a STAR SYSTEMS, PLUS SYSTEM, SELF-SERVICE TELEPHONE, or
DIRECT DESIT/CREDIT transaction, or 20 business days if it is a STAR
SYSTEMS purchase transaction. You will have the use of the moray during the
time it takes to complete the investigation. If PSECU does not recahre your
complaint or question in writing within 10 business days, PSECU may not
recredit your account. It PSECU decides there Is no error, you wig be advised
within three business days after the Investigation is completed, You may ask for
copies of the documents PSECU used in the investigation. If PSECU credits
your account while Investigating, you must repay those funds if PSECU
concludes no error has occurred.
17. ATM SURCHARGE -- It you use an ATM that is not operated by us, you may be
charged a fee by the ATM operator and by any national, regional or local network
used in processing the transaction (and you may be charged a fee for a balance
inquiry even if you do rat complete a fund transfer). The ATM surcharge will be
debited from your account if you elect to complete the transaction.
Notice To Consumers Using ATM's
• Be start to your surroundings. If you doubt the safety of a partkwwr kcatiorh,
choose another ATM.
• If the ATM has an entry door, dose the door prior to Initiating your transaction.
• Put your cash away immediately.
• Direct complaints concerning ATM security to an appropriate department of
the owner of the ATM. New Jersey residents: you may call the New Jersey
Department of Banking at (809) 292.7272.
For those members who purchase a vehicle under the
DRIV Program, please review the following FTC Notice:
'ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT
IS SUBJECT TO ALL CLAWS 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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IPSECO
04/11/2008
, 10, 5-0 - ?/ '3 cz??
JOSEPH E JIRAS
2014 LINCOLN ST,
CAMP HILL, PA 17011-3841
Dear JOSEPH E JIRAS:
PSECU has made several attempts to contact you and to negotiate suitable payment arrangements. We
received no response. Your Signature Loan is 6 months past duel
This is your final notice. Unless we receive the payment amount of $1,200.00 by April 26, 2008, we may
refer your account to our Legal Review Committee.
If this occurs, a judgment maybe entered and executed against you. All court costs and fees will be added
to your loan balance. If we do not take legal action and payments are not received, we will charge off your
account. You will still be responsible for the balance. In either case, your status will be reported to all
national credit bureaus.
This is a serious situation that requires your immediate attention.
If you cannot make the full payment, we are willing to negotiate a reasonable payment schedule that fits
your needs. Call me today to see ifwe can resolve this situation.
I can be reached at 234-8484 in Harrisburg or call our toll-free number, (800) 237-7328. At the menu
prompt, enter 6 then extension 3118. We are open from 8 am. to 5 p.m. Monday through Friday and 8 a.m.
to noon on Saturday.
Sincerely,
Cheryl Kelly
Account Advisor
411/
Pennsylvania State Employees Credit Union'
Main Address; 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328 ,
- - _ MailL Address: P.O. Brno 67013, Harrisbur?PA 17106-7013 • 717.777.2100 Qgl - " - 800.472.1967 DD
This crod't un.'on is {edam @y insured br the National Cred:r Union Aaminis?roFon. Equal Opportunity Lender • ?''-
www.psecu.com
NEE)
SE(*
JOSEPH E JIRAS
2014 LINCOLN ST,
CAMP HILL, PA 17011-3841
Dear JOSEPH E JIRAS:
06/0212008
COPY
61%gsU1?)-q
On OS/28/2008 your Signature Loan was charged off for $6,371.98. You are still responsible for
repayment of this entire debt
Because Interest slopped accruing, this allows as to accept payment arrangements suitable to your
presentJlnanclal situation,
As your Account Advisor I will assist you with questions and concerns. I will work with you to help you
get back on track with us. This will give you the opportunity to become eligible for our member services.
Please call me at 234-8484 in Harrisburg or call our toll free number (800) 237-7328. At the menu
prompt Dress 6 then e:rt 3119.
Sincerely,
Michelle Hess
Account Advisor
enc.
Pennsylvania State Employees Credit Union 11
Main Address: 1 Credit Union Place, Horrisbu% PA 17110-2990 • 717.234.8484 • 800.237.7328
_ Adailing Address?P.O. Box 67013LHorrisburg?RA 17106_70_13 • 717J77.2100 ?' DD''• 800.472.1967 DQ?_-
ihis rndU union is ledaraliy insured by he National Credit Union Adminislmlion. Equal Opportunity lender - - ' .19 -•
www.psecu.com
X
PSECO
JOSEPH E JIRAS O
2014 LINCOLN ST,
CAMP HILL, PA 17011-3841
Dear JOSEPH E JIRAS:
07/03/2008
COPY
aft 1504 ?)aq
On June 2, 2008, I sent you a letter concerning your Charged-Off Signature Loan. This account still has a
balance of 86,371.98. It is ve Important .that you contact me immediately
We are willintr to work with you to improve r credit value with us Please call meat 1-800-237 7328 or
234-8484 tenter 6) ert 3119 to discuss a suitable pm?ment arrant?emenr
When your balance is paid in full, we will report it to the credit reporting agencies as a paid charge off.
And, you will be eligible to apply for our member services.
Upon your request, we can refer you to an agency that can help you with your budget and other debt
problems. This is a non-profit agency and the service is free.
Let us help you get back on track.
Sincerely,
Michelle Hess
Account Advisor
Pennsykania State Emplayees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDDti • 800.472.1967 (TW)
com
This credit union is federally Insured by the National Credit Union Administration. Equal p pBeCU.
PPo?nih' tender
ANNED
PSECO
07/31/2008
JOSEPH E JIRAS
2014 LINCOLN ST,
CAMP HILL, PA 17011-3841
Dear JOSEPH E JIRAS:
COPY
We have tried several times to contact you concerning your Charged-Off Signature Loan. This account still
has an outstanding balance of $6,811.83.
We have continually expressed our willingness to work with you. When your balance is paid in full, we
will report it to the credit reporting agencies as a paid charge off. And, you will be eligible to apply for our
member services.
Should you continue to ignore your obligation to pay this debt, I will have no alternative but to
submit your account for Manager Review. This may result In your account being sent to a collection
agency or legal action taken. Should any of these options be necessary, you will be responsible for all
cost and fees incurred.
Please call me at 234-8484 in Harrisburg or call our toll-free number (800)-237-7328. At the menu prompt,
press 6, then ext. 3119.
Sincerely,
Michelle Hess
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: P.O. Box 67013, Harrisburg, PA 17106-7013 - 717.777.2100 (TDD) - 800.472.1967 (TDD)
Lander
This credit union is federo&y insured by the National Credit Union Administration. Equal OasPSrtunit h '
.
NNED
IPSEC?
JOSEPH E BRAS
2014 LINCOLN ST,
CAMP HILL, PA 17011-3841
Dear JOSEPH E BRAS,
coFrIlrr
08,11/2008 o?goz,- 4-.? aq
Sent via certified & regular mail
SETTLE YOUR CREDIT UNION DEBT AND GET A 1061, DISCOUPTI'I I
As a Credit Union, we recognize that unexpected occurrences can sometimes result in difficulty meeting financial
obligations. PSECU would like to help you with fulfilling your outstanding obligation with a one-time opportunity to satisfy
your severely delinquent PSECU Charged-Off Signature Loan by establishing a monthly payment agreement.
We can help if you are willing to work with us; however, a decision must be made now as we are on the verge of pursuing
legal remedies to collect your debt.
To assist with your decision, I would like to describe two scenarios:
Allowing us to work with you:
-**We will reduce your current Charged-Off Signature Loan balance from $6,811.83 to $6,130.65.
+We will stop all interest and late fees from further increasing your obligation.
4• We will work with you to establish a reasonable monthly payment.
A. credit report, which now reflects a charged-off account, will show you have resumed making payments,
4-This is a one-time offer which is good for 14 days from the date of this letter.
-If you fail to consistently make the established monthly payment, this agreement will be immediately voided and the
loan will be turned over to our attorney for legal action.
Ignoring this letter and doing nothing could result in the following:
4-We will forward your file to our attorney or third-party collection agency following 14 days of this letter.
?Collection costs of 205'6 plus additional court costs will be added to your outstanding Charged-Off Signature Loan
balance resulting in an increased outstanding obligation.
-Our attorney will file a judgment against you in Civil Court for the increased amount.
4-Your appearance in court wil I be requested.
?A Lien will be placed on your personal property and be reflected on your credit report for up to 20 years making it
more difficult to obtain credit in the future including buying a vehicle and buying or selling a house.
-Mny co-applicant on this loan will be negatively impacted In the same way.
4-Your account could be referred to a third-party collection agency for additional collection efforts.
This choice is clearly up to you. Please call one of our member service representatives, toll free, at
1-800-237-7328, or locally at 717-234-8484, extension 3119, to take advantage of this one-time offer.
Sincerely,
Julie Serino
Director
Member Services
Pennsylvania State Employees Credit Union
Main Address. 1 Credit Union Place, Horrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
-` Mai(fn$Add.'essP.O. Box 67_013, Horrisburg, PA 17106-7013 • 717.777.2100 DD • 800.472.1967 TDDI 1
Thu credlt un'on Is federally!nsured by thn Nollonal CQll Union Adnanistrolion. Eaual Opportunity t.ecder _ 1- - - `
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SHERIFF'S RETURN - REGULAR
CASE NO: 2009-00525 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE EMPLOYEES
VS
JIRAS JOSEPH E
MARK CONKLIN , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
JIRAS JOSEPH E the
DEFENDANT , at 0011:00 HOURS, on the 4th day of February-, 2009
at 2014 LINCOLN STREET
CAMP HILL, PA 17011
by handing to
JOSEPH JIRAS DEFENDANT
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
of
So Answers:
18.00
12.60
.00
10.00 R. Thomas Kline
.00
40.60 02/05/2009
BARLEY SNYDER
By.
day Deputy Sheriff
A. D.
cV
co
??p n+?t Ll .}
?
..3.. y ...r.{ ED
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff,
V.
JOSEPH E. JIRAS,
Defendant.
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No.09-525 Civil Term
PRAECIPE FOR JUDGMENT
Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and
against Defendant, Joseph E. Aras for want of an answer in the amount of $8,174.19 plus costs
of suit.
(X) I certify that the foregoing assessment of damages is for specified amounts alleged to
be due in the complaint and is calculable as a sum certain from the complaint.
( ) Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify
that a copy of this praecipe has been mailed to each other party who has appeared in the action or
to his/her Attorney of Record.
2549897-1
W- (X) Pursuant to Pa. R.C.P. 237. 1, I certify that written notice of the intention to file this
praecipe was mailed or delivered to the party against whom judgment is to be entered and to
his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the
date of the filing of this praecipe and a copy of the notice is attached.
BARLEY SNYDER LLC
Date: 3'(409 By:
$'hawn M. Long, Fi(quire
Attorneys for PI 'tiff
Pennsylvania to Employees Credit Union
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
NOW, (lL-J&gk .Z,6 , 2009, JUDGMENT IS ENTERED AS ABOVE.
Prothonotary/Clerk, Civil Division
By:
2549897-1
A
?
F+ %
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
v.
JOSEPH E. BRAS,
Defendant
T OF COMMON PLEAS OF
ERLAND COUNTY, PENNSYLVANIA
ACTION - LAW
o. 09-525 Civil Term
To: Joseph E. Jiras
Date of Notice: February 25, 2009
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH
2535110-1
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford St.
Carlisle, PA 17013
(717) 232-7536
eo . Shoop, Esquire
I.D. No. 25367
Shawn M. Long, Esquire
I.D. No. 83774
126 East King Street
Lancaster, PA 17602-2893
(717) 299-5201
2535110-1
C=D C)
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
JOSEPH E. JIRAS,
Defendant
t OF COMMON PLEAS OF
ERLAND COUNTY, PENNSYLVANIA
ACTION - LAW
o. 09-525 Civil Term
PROOF OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF BERKS
. ss.
Colleen Brelje, Paralegal, being sworn according to law, deposes and says that she served
a true and correct copy of the 10-day Default Notice upon Joseph E. Jiras, 2014 Lincoln Street,
Camp Hill, Pennsylvania 17011, by regular mail on February 25, 2009 at 5:00 p.m.
BARLEY SNYDER LLC
By: -- o Lae
Co een Brelje, Paralegal
Sworn to and subscribed before me 501 Washington Street
this day of jAlach , 2009 P.O. Box 942
tary Public
Reading, PA 19603-0942
(610) 376-6651
COMMONWEALTH OF PENNSYLVANIA
Notarial Seel
Margaret C. Edwards, Notary Public
C ky Of Rearing; Soft Cour><y
My Cam* dm Ekes Merck 22, 2WO
Member, Pennsylvania Association of Notaries
2535110-1
r
VA
C i.?J
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff,
V.
JOSEPH E. JIRAS,
Defendant.
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No.09-525 Civil Term
AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE
MILITARY SERVICE, PURSUANT TO "SOLDIERS
AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940
LANCASTER COUNTY, SS: Before me, the undersigned authority, personally
appeared Shawn M. Long, Esquire, who being duly sworn according to law, doth depose and say
that Joseph E. Jiras, the Defendant is not in the Military or Naval Service, based on the following
facts: Age of Defendant is unknown; Present place of employment is unknown; Present place of
Residence is 2014 Lincoln Street, Camp Hill, PA 17011 as of the date of this affidavit.
2549897-1
ADDITIONAL FACTS, if any.
Date: :1 /11.101 By:
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Attorneys for PlaintUl
Pennsylvania State Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602-2893
(717) 299-5201
Credit Union
A
Sworn and subscribed to before me this ) I day of Ma '2009.
Public
COMMONWEALTH OF PENNSYLVANIA
Nomrld Suet
ctp?ate BMW. NoWy ?
ioe ,
My OW06*n SOU MW. 14,2M
Mew, Pvnft%yKwft Aamclslion d Notadas
2549897-I
,
fS? M
C)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
OFFICE OF THE PROTHONOTARY
CARLISLE, PA
TO: Joseph E. Jiras
Defendant
YOU ARE HEREBY NOTIFIED that Pennsylvania State Employees Credit Union has
caused a judgment by default to be entered against you with the Prothonotary of Cumberland
County. The judgment was entered on 11:34-r-L to No. 09-525 Civil Term
-T
with the Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the
amount of $8,174.19 plus costs of suit.
ROTH O ARY
By:
Deputy Clerk
2549897-1
n ? C?