HomeMy WebLinkAbout09-3624SUSQUEHANNA VALLEY FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY
Plaintiff PENNSYLVANIA
vs.
JOHN A. POTTEIGER AND
KIMBERLY L. POTTEIGER
Defendants
NO. OR -3(cd4 (2tvZ( (erw
CIVIL ACTION - LAW
NOTICE
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 RELIEF REQUESTED BY
THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT
RIGHTS.
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. 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.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166 /J
By:
JR6well Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION
Plaintiff
VS.
JOHN A. POTTEIGER AND
KIMBERLY L. POTTEIGER
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 0 9- 34 "Y ?.( T
CIVIL ACTION - LAW
COMPLAINT
1. The Plaintiff is the Susquehanna Valley Federal Credit Union with a principal place of
business located at 3850 Hartzdale Drive, Camp Hill, Cumberland County, PA 17011. Plaintiff is
a federally chartered nonprofit credit union.
2. The Defendant John A. Potteiger is an adult individual residing at 5 West Main Street,
McAlisterville, Juniata County, PA 17049.
3. The Defendant Kimberly L. Potteiger is an adult individual residing at 30 Ken-Lin Drive,
Dillsburg, York County, PA 17019.
4. The Defendants are not current members of the Armed Forces.
COUNT 1: SVFCU CREDIT CARD
5. On July 18, 1997 the Defendants executed a Classic/Platinum Visa Credit Card
Agreement attached as Exhibit "A" with an interest rate of 9.90%. Defendants were the
borrowers under this Credit Card Agreement.
6. The terms of Exhibit "A" required timely payments due each month.
7. Defendants failed to make timely payments on the Credit Card Balance with $1,950.00
past due and a total balance due of $10,978.57 as of 5-6-09. (Exhibits "B")
Defendants have made no regular payments despite repeated requests.
9. Pursuant to the Credit Card Agreement at Paragraph 5 (e) the Defendants agreed to pay all
"court costs and reasonable attorney fees" incurred in any collection action.
WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount of
$10,978.57 (principal plus past interest) at 9.90% interest and from May 6, 2009 a per
diem of $2.92 together with all court costs and an award of reasonable attorneys' fees.
Respectfully submitted,
By:
(717) 770-1277
Supreme Court ID 62063
,"619 Bridge Street
New Cumberland, PA 17070
05/26/2009 13:17 7177701278 HOWELL LAW FIRM PAGE 02/09
Verification
1 verify that the statements made in the forgoing document are true and correct. I understand that
false statements hereon are made subject to the penalties of IS Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities. I. verify that I am the President of the Susquehaana Valley
Federal Credit Union and that I am authorized to execute this document.
By: -ZO& I.
Stephen J. Brindamour, President
SVFCU
Date: /-fi)gy 16, 0?007
SUSOUEHAHHA VALLEY
FEDERAL CREDIT UNION AM E R I CA' s
3850 Hartzdale Drive ` CREDIT UNIONS'
® Camp Hill, , PA PA 17011-7809
(717) 737-4152
Classic/Platinum
VISA CREDIT CARD AGREEMENT
In this Agreement the words 'ou" and "your' mean each and all of those who
agree to be bound by this Agreement; "Card' means the VISA credit card and any
duplicates, renewals, or substitutions the Credit Union issues to you; "Account"
means your VISA credit card line of credit account with the Credit Union, and
"Credit Union" means the Credit Union whose name appears on this Agreement
or anyone to whom the Credit Union transfers this Agreement.
Using Your Account. if you are approved for an Account, the Credit Union
will establish a line of credit for you and notify you of your credit limit. You
agree that your credit limit is the maximum amount (purchases, cash
advances, finance charges, plus "other charges') that you will have
outstanding on your Account at any time. If you are over your credit limit, you
must pay the amount you are over before payments will begin to restore your
credit limit. You may request an increase in your credit limit only by a method
acceptable to the Credit Union. The Credit Union has the right to reduce your
credit limit, refuse to make an advance and/or terminate your Account at any
time for any reason not prohibited by law.
Using Your Card. You may use your Card to make purchases from merchants
and others who accept VISA Cards. However, you may not use your Card to
initiate any type of gambling transaction. If you wish to pay for goods or
services over the Internet, you may be required to provide card number
security information before you will be permitted to complete the transaction.
In addition, you may obtain cash advances from the Credit Union and from
other financial institutions that accept VISA Cards, and from some automated
teller machines (ATMs). (Not all ATMs accept VISA Cards.) To obtain cash
advances from an ATM, you must use the Personal Identification Number
(PIN) that is issued to you for use with your Card. You agree that you will not
use your Card for any transaction that is illegal under applicable federal, state
or local law.
3. ResRQnsibility. You agree to pay all charges (purchases and cash advances)
to your Account that are made by you or anyone whom you authorize to use
your Account. You also agree to pay all finance charges and other charges
added to your Account under the terms of this Agreement or another
agreement you made with the Credit Union. If this is a joint Account, Section
17 below also applies to your Account.
4. Finance Charges. New purchases posted to your account during a billing
cycle will not incur a finance charge for that billing cycle if you had a zero or
credit balance at the beginning of that billing cycle or you paid the entire New
Balance on the previous cycle's billing statement by the Payment Due Date
of that statement; otherwise a finance charge will accrue from the date a
purchase is posted to your account. To avoid an additional finance charge on
the balance of purchases, you must pay the entire New Balance on the billing
statement by the Payment Due Date of that statement. A finance charge
begins to accrue on cash advances from the date you get the cash advance
or from the first day of the billing cycle in which the cash advance is posted
to your account, whichever is later.
The finance charge is calculated separately for purchases and cash
advances. For purchases, the finance charge is computed by applying the
monthly periodic rate to the average daily balance of purchases. To get the
average daily balance of purchases, we take the beginning outstanding
balance of purchases each day, add any new purchases, and subtract any
payments and/or credits. This gives us the daily balance of purchases. Then,
we add all the daily balances of purchases for the billing cycle together and
divide the total by the number of days in the billing cycle. This gives us the
average daily balance of purchases.
For cash advances, the finance charge is computed by applying the monthly
periodic rate to the average daily balance of cash advances. To get the
average daily balance of cash advances, we take the beginning outstanding
balance of cash advances each day, add in any new cash advances, and
subtract any payments and/or credits that we apply to the cash advance
balance. This gives us the daily balance of cash advances. Then, we add all
the daily balances of cash advances for the billing cycle together and divide
the total by the number of days in the billing cycle. This gives us the average
daily balance of cash advances.
For our VISA Classic Card, the monthly periodic rate for purchases, cash
advances and balance transfers is 1.0750%, which is an ANNUAL
PERCENTAGE RATE of 12.901/6.
For our VISA Platinum Card, the monthly periodic rate for purchases, cash
advances and balance transfers is 0.8250%, which is an ANNUAL
PERCENTAGE RATE of 9.90°/6.
0 CUNA Mutual Group, 1991, 2005 116/05 25349
5. Other Charges. The following other charges (fees) will be added to your
Account, as applicable:
a. Late Payment Fee: If you are ten (10) or more days late in making a
payment, a late charge of $20.00 will be added to your account.
b. Return Check Fee: If a check or share draft used to make a payment on
your account is returned unpaid, you will be charged a fee of $25.00 for
each item returned.
c. Card Replacement Fee: We reserve the right to charge $5.00 for each
additional replacement card if more than three (3) cards are requested
within one year. Additional fees may be incurred if other than standard
delivery is requested.
d. Document Copy Fee: We reserve the right to charge $5.00 for requested
sales draft copies if not associated with a billing error or fraudulent
charges.
e. Collection Costs: You agree to pay all costs of collecting the amount you
owe under this Agreement, including court costs and reasonable
attorney's fees.
f. Card Capture Fee: We reserve the right to charge $65.00 for requesting
a return of all card(s) in your possession if you or your authorized user
has willfully misused the card(s) after such time as the card was reported
lost/stolen.
g. Emergency Limit: You may be charged $5.00 for each emergency limit
increase requested if more than three (3) are requested per year.
6. Payer. Each month you must pay at least the minimum payment shown
on your statement by the date specified on the statement or no later than
twenty-five (25) days from the statement closing date, whichever is later. If
your statement says the payment is "Now Due" your payment is due no later
than twenty-five (25) days from the statement closing date. You may pay more
frequently, pay more than the minimum payment or pay the Total New
Balance in full. If you make extra or larger payments, you are still required to
make at least the minimum payment each month your Account has a balance
(other than a credit balance). The minimum payment is 3% of your Total New
Balance, or $a0.00, whichever is greater, Rlo the amount of any prior
minimum payments that you have not made, and any amount you are over
your credit limit. The Credit Union also has the right to demand immediate
payment of any amount by which you are over your credit limit.
7. Payment Allocation. Subject to applicable law, your payments may be
applied to what you owe the Credit Union in any manner the Credit Union
chooses. We may accept checks marked "payment in full" or with words of
similar effect without losing any of our rights to collect the full balance of your
account with us.
Securily Interest. If you give the Credit Union a specific pledge of shares by
signing a separate pledge of shares, your pledged shares will secure your
Account. You may not withdraw amounts that have been specifically pledged
to secure your Account until the Credit Union agrees to release all or part of
the pledged amount. In addition, your Account is secured by all other shares
you have in any individual or joint account with the Credit Union, except for
shares in an Individual Retirement Account or in any other account that would
lose special tax treatment under state or federal law if given as security.
These other shares may not be withdrawn unless you are in default under this
agreement. You authorize the Credit Union to apply the balance in your
individual or joint share accounts to pay any amounts due on your Account if
you should default. Collateral securing other loans you have with the Credit
Union may also secure this loan, except that a dwelling will never be
considered as security for this Account, notwithstanding anything to the
contrary in any other agreement.
9. Default You will be in default if you fail to make any minimum payment or
other required payment by the date that it is due. You will be in default if you
break any promise you make under this Agreement. You will be in default if
you die, file for bankruptcy or become insolvent, that is, unable to pay your
obligations when they become due. You will be in default if you make any false
or misleading statements in any credit application or credit update. You will
also be in default if something happens that the Credit Union believes may
substantially reduce your ability to repay what you owe.
When you are in default, the Credit Union has the right to demand immediate
payment of your full Account balance without giving you notice. If immediate
payment is demanded, you agree to continue paying finance charges, at the
periodic rate charged before default, until what you owe has been paid, and
any shares that were given as security for your Account may be applied
towards what you owe.
CONTINUED ON REVERSE SIDE
10. Liability for Unauthorized Use-Losi/Stolen Card Notification. You agree
to notify us immediately, orally or in writing at 3850 Hartzdale Drive, Camp
Hill, PA 17011-7809 or telephone (717) 737-4152 Monday through Friday
9:00 A.M. to 5:30 P.M., (800) 433-0505 Monday through Friday 8:00 A.M. to
6:00 P.M. or (800) 991-4961 twenty-four (24) hours a day, seven (7) days a
week, 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 $50.
11. Changing Ttrminating Your Account. The Credit Union may change the
terms of this Agreement from time to time. Notice of any change will be given
in accordance with applicable law. If permitted by law and specified in the
notice to you, the change will apply to your existing Account balance as well
as to future transactions.
Either you or the Credit Union may terminate this Agreement at any time, but
termination by you or the Credit Union will not affect your obligation to pay the
Account balance plus any finance and other charges you owe under this
Agreement. You are also responsible for all transactions made to your
Account after termination, unless the transactions were unauthorized.
The Card or Cards you receive remain the property of the Credit Union and
you must recover and surrender to the Credit Union all Cards upon request
or upon termination of this Agreement whether by you or the Credit Union.
The Credit Union has the right to require you to pay your full Account balance
at any time after your Account is terminated, whether it is terminated by you
or the Credit Union. If this is a joint Account, Section 17 of this Agreement
also applies to termination of the Account.
12. Credit Review and Release of Information. You authorize the Credit Union
to investigate your credit standing when opening or reviewing your Account.
You authorize the Credit Union to disclose information regarding your
Account to credit bureaus and creditors who inquire about your credit
standing. If your account is eligible for emergency cash and/or emergency
card replacement services, and you request such services, you agree that we
may provide personal information about you and your account that is
necessary to provide you with the requested service(s).
13. Returns and Adjustments. Merchants and others who honor your Card may
give credit for returns or adjustments, and they will do so by sending the
Credit Union a credit slip which will be posted to your Account. If your credits
and payments exceed what you owe the Credit Union, the amount will be
applied against future purchases and cash advances. If the credit balance
amount is $1 or more, it will be refunded upon your written request or
automatically after six (6) months.
14. Additional Benefits/Card Enhancements. The Credit Union may from time
to time offer additional services to your Account, such as travel accident
insurance, at no additional cost to you. You understand that the Credit Union
is not obligated to offer such services and may withdraw or change them at
any time.
15. Foreign Transactions. Purchases and cash advances made in foreign
currencies will be debited from your account in U.S. dollars. The exchange
rate between the transaction currency and the billing currency used for
processing international transactions is a rate selected by Visa from a range
of rates available in wholesale currency markets for the applicable central
processing date, which rate may vary from the rate Visa itself receives or the
government-mandated rate in effect for the applicable central processing
date. The exchange rate used on the processing date may differ from the rate
that would have been used on the purchase date or cardholder statement
posting date.
16. Merchant Disputes. The Credit Union is not responsible for the refusal of any
merchant or financial institution to honor your Card. The Credit Union is
subject to claims and defenses (other than tort claims) arising out of goods
or services you purchase with the Card if you have made a good faith attempt
but have been unable to obtain satisfaction from the merchant or service
provider, and (a) your purchase was made in response to an advertisement
the Credit Union sent or participated in sending to you; or (b) your purchase
cost more than $50 and was made in your state or within one hundred (100)
miles of your home.
17. Joint Accounts. If this is a joint Account, each person on the Account must
sign the Agreement (by signing on the application). Each of you will be
individually and jointly responsible for paying all amounts owed under this
Agreement. This means that the Credit Union can require any one of you
individually to repay the entire amount owed under this Agreement. Each of
you authorizes the other(s) to make purchases or cash advances individually.
Any one of you may terminate the Account and the termination will be
effective as to all of you.
18. Effect of Agreement. This Agreement is the contract which applies to all
transactions on your Account even though the sales, cash advances, credit
or other slips you sign or receive may contain different terms.
19. No Waiver. The Credit Union can delay enforcing any of its rights any number
of times without losing them.
20. Statements and Notices. Statements and notices will be mailed to you at
the most recent address you have given the Credit Union. Notice sent to any
one of you will be considered notice to all.
21. Final Expression. This Agreement is the final expression of the terms and
conditions of this VISA line of credit between you and the Credit Union. This
written Agreement may not be contradicted by evidence of any alleged oral
agreement.
22. Copy Received. You acknowledge that you have received a copy of this
Agreement.
23. Signatures. By signing in the Signature area of the application form that was
attached to this Agreement when you received it, you agree to the terms of
this Agreement. You should detach this Agreement from the application and
retain it for your records.
YOUR BILLING RIGHTS
KEEP THIS NOTICE FOR FUTURE USE
This notice contains important information about your rights and our
responsibilities under the Fair Credit Billing Act.
Notify Us In Case of Errors or Questions About Your Bill
If you think your bill is wrong, or if you need more information about a transaction
on your bill, write us on a separate sheet at the address listed on your bill. Write
to us as soon as possible. We must hear from you no later than sixty (60) days
after we sent you the first bill on which the error or problem appeared. 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.
If you have authorized us to pay your credit card bill automatically from your
savings or share draft account, you can stop the payment on any amount you
think is wrong. To stop the payment your letter must reach us three (3) 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 thirty (30) days, unless we have
corrected the error by then. Within ninety (90) days, we must either correct the
error or explain why we believe the bill was correct.
After we receive your letter, we cannot try to collect any amount you question, or
report you as delinquent. We can continue to bill you for the amount you question,
including finance charges, and we can apply an unpaid amount against your
credit limit. You do not have to pay any questioned amount while we are
investigating, but you are still obligated to pay the parts of your bill that are not in
question.
If we find that we made a mistake on your bill, you will not have to pay any finance
charges related to any questioned amount. If we didn't make a mistake, you may
have to pay finance charges, and you will have to make up any missed payments
on 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 fail to pay the amount that we think you owe, we may report you as
delinquent. However, if our explanation does not satisfy you and you write to us
within ten (10) days telling us that you still refuse to pay, we must tell anyone we
report you to that you have a question about your bill. 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 bill was correct.
Special Rule for Credit Card Purchases
If you have a problem with the quality of property or services that you purchased
with a credit card, and you have tried in good faith to correct the problem with the
merchant, you may have the right not to pay the remaining amount due on the
property or services. There are two (2) limitations on this right:
(a) You must have made the purchase in your home state or, if not within your
home state, within one hundred (100) miles of your current mailing address;
and
(b) The purchase price must have been more than $50.
These limitations do not apply if we own or operate the merchant, or if we mailed
you the advertisement for the property or services.
Mini Credit Card Application Im"ORTANT R1s1"uc110Ns: Complete and sigr?'Applicant portion to apply for
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Both applicant and co-applicant must belong to the Credit Union, and both
portion A
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Credit Limit Requested $ .
assume responsilAity for any charges made to the account. Availability of an L m
individual account with an authorized user depends on the board policy.
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Applicant Name (Last First -Middle) 2
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Home Address (Street & No.) c
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City State Zip
Phone (Day) (Evening)
Birth Date
SS# 1
Current Employer r
Address
Phone # How Long Employed There?
Gross Annual Income $ Net Monthly Pay $
*Other Income $ Source of Other Income
Own OR Rent: Monthly Payment $
n
Total of all Monthly Installment Payments $ o
CO-APPLICANT
None OR Name
Relationship SS#
Employer
Phone # How Long Employed There?
Gross Annual Income $ Net Monthly Pay $
Alimony or child support or maintenance payments are optional information and need not be revealed if the
applicant does not choose to rely on such income in applying for credit.
This statement is submitted to obtain credit and I (we) certify that all information herein is true and complete. I (We) also authorize
the Credit Union to verity or obtain further information the Credit Union may deem necessary concerning my (our) credit standing.
If this application is approved and a Credit Card(s) Issued, the undersigned applicant(s) by signing, using or permitting another to
the Credit Card(s) agree(s) that the applicant(s) will be bound by the terms and conditions accompanying the Credit Card(s) and
all amendments. I (We) hereby acknowled receipt of the Credit Union Credit Card Agreement and Disclosure and Billing
Rights that Inform me (us) of the to sponsibilides nd rights as a Credit Union Credit Card account user.
Applicant's Signature X. Date -
Co-Applicant's Signature ( kirpe- ? Date -7 1
Name of authorized user
Signature
Date
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SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION
Plaintiff
VS.
JOHN A. POTTEIGER AND
KIMBERLY L. POTTEIGER
Defendants
TO: John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
DATE OF NOTICE: June 30, 2009
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 09 - 3624 CIVIL TERM
CIVIL ACTION - LAW
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 YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU 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 PERSONA AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
AVISO IMPORTANTE
A: John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
ECHA DEL AVISO: June 30, 2009
LISTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVE S DE UN ABOGADO
Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS
QUE SE HAN PRESETADO CONTRA LISTED. A MEMOS QUE USTED ACTUE
DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA
VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS
IMPORTANTES.
USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A
LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE.
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO
A PERSONAS QUE CALIFICAN.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Respectfully submitted,
By:
(717) 770-1277
Supreme Court ID 62063
Date: June 30, 2009
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
Date: June 30, 2009
619 Bridge Street
New Cumberland, PA 17070
I--c ? f-i' r1T CRY
2099 Pilo)
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SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION
Plaintiff
VS.
JOHN A. POTTEIGER AND
KIMBERLY L. POTTEIGER
Defendants
TO: John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
DATE OF NOTICE: July 2, 2009
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 09 - 3624 CIVIL TERM
CIVIL ACTION - LAW
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 YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU 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 PERSONA AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
AVISO IMPORTANTE
A: John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
ECHA DEL AVISO: July 2, 2009
USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO
Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS
QUE SE HAN PRESETADO CONTRA LISTED. A MEMOS QUE USTED ACTUE
DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA
VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS
IMPORTANTES.
USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO
1NMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A
LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE.
1NFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO
A PERSONAS QUE CALIFICAN.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Respectfully submitted,
By:
Ste in Howell, Esquire
well Law Finn
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: July 2, 2009
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
B
Date: June 30, 2009
OF Tr',-
?,n', r,,nT4pY
1004 JUL -6 FM 2: 32
r'EN YL? 1ri. V ? h viA
.
SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
VS.
JOHN A. POTTEIGER AND
KIMBERLY L. POTTEIGER
Defendants
NO. 09 - 3624 CIVIL TERM
CIVIL ACTION - LAW
TO: John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
DATE OF NOTICE: July 7, 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 YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU 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 PERSONA AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
AVISO IMPORTANTE
A: John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
ECHA DEL AVISO: July 7, 2009
USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO
Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS
QUE SE HAN PRESETADO CONTRA USTED. A MEMOS QUE USTED ACTUE
DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA
VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS
IMPORTANTES.
USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A
LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE.
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO
A PERSONAS QUE CALIFICAN.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Respectfully submitted,
By:
S
ell Law Firm "
19 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: July 7, 2009
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
Date: July 7, 2009
fl;l `L'1
TH'
20G9 JUL -3 Fi°i 1: 58
C'C''. ?.'uJ
RICHARD S. FRIEDMAN, P.C.
Richard S. Friedman, Esquire
ID #07176
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
Tel.: (717) 234-3441/Fax: (717) 232-9946
e-mail: rsfl3glive.com
Attorney for Defendant, John A. Potteiger
SUSQUEHANNA VALLEY FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. : NO. 09-3624 Civil Term
JOHN A. POTTEIGER and : CIVIL ACTION - LAW
KIMBERLY L. POTTEIGER,
Defendants
ENTRY OF APPEARANCE
Kindly enter my appearance on behalf of the Defendant, John A. Potteiger, in the above-
captioned matter.
Respectfully submitted,
RICHARD S. FRIEDMAN, P.C.
Dat
Rich S. man, Esquire
300 .2nd Street, Suite 402
H isburg, PA 17101
(717) 234-3441
FiLEJ-1' IF"-ICE
2004 JUL -9 P 12. 49
?,u ti y
RICHARD S. FRIEDMAN, P.C.
Richard S. Friedman, Esquire
ID #07176
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
Tel.: (717) 234-3441/Fax: (717) 232-9946
e-mail: rsfl3&live.com
SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION,
Plaintiff
V.
JOHN A. POTTEIGER and
KIMBERLY L. POTTEIGER,
Defendants
Attorney for Defendant, John A. Potteiger
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 09-3624 Civil Term
CIVIL ACTION - LAW
DEFENDANT. JOHNA. POTTEIGER'S. ANSWER TO COMPLAINT
AND NOW, comes the Defendant, John A. Potteiger, by and through his attorney,
Richard S. Friedman, Esquire, and replies as follows:
1. Admitted.
2. Admitted.
3. Denied. Defendant, Kimberly L. Potteiger, recently moved to an unknown location in
Camp Hill, Pennsylvania.
4. Admitted.
COUNT 1: SVFCU CREDIT CARD
5. Admitted.
6. Admitted.
7. It is admitted that Defendant, John A. Potteiger, failed to make timely payments. It is
averred that he has made payments. By way of further answer, Defendant, John A. Potteiger, is
without sufficient information as to the truth or falsity of the past due amount and total balance
due, and proof thereof is therefore demanded at trial.
8. Admitted.
9. Admitted.
WHEREFORE, the Defendant, John A. Potteiger, requests judgment be entered in his
favor.
Date: Q?A,
Respectfully submitted,
RICHARD S. FRIEDMAN, P.C.
Richard X. Friedman, Esquire
300 W 2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
JUG-07-2009 03:16 PM NEWPORT ELEMENTARY 5679485 P.01/01
' 07/07/2009 16:08 7172329946 CHARLES FRIEDMAN PAGE 04/I7b
11 : l a . _M_ 4 .
L Jobn A,. Potteiger, hereby a&wwkdge that I am a Defendant in die foregoing action;
that i have read the foregoing Anwar to Compleint; and the facts stated therein are true and
correct to the bast of my knowledge, information and bolief.
I undemumd that any fell statements harein are made subject to penalties of 18 Pa.
C.S. Seadon 4904, relating to unworn falsification to authotities.
C.( /ga?
A. Potteiger
)k I
SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 09-3624 Civil Term
JOHN A. POTTEIGER and : CIVIL ACTION - LAW
KIMBERLY L. POTTEIGER,
Defendants
CERTIFICATE OF SERVICE
I, Richard S. Friedman, Esquire, hereby certify that on July 8, 2009, I served a copy of
the within Defendant, John A. Potteiger's, Answer to Complaint, by depositing same in the
United States Mail, first class, postage prepaid, addressed as follows:
Steven Howell, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
Kimberly L. Potteiger
c/o Timothy J. O'Connell, Esquire
Turner and O'Connell
4701 North Front Street
Harrisburg, PA 17110
RICHARD S. FRIEDMAN, P.C.
Rich S. Friedman, Esquire
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
BLED--?? ?t '0"=
OF, THE M -TYI-??IIOTNPIY
2 SUL -9 Ph 12: ?, 9
}
l ~
SUSQUEHANNA VALLEY FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY
Plaintiff PENNSYLVANIA
VS.
NO. 09 - 3624 CIVIL TERM
JOHN A. POTTEIGER AND
KIMBERLY L. POTTEIGER CIVIL ACTION -LAW
Defendants
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter a DEFAULT JUDGMENT against KIMBERLY L. POTTEIGER for her
failure to file and Answer to the Complaint served June 11, 2009 by the Office of the Sheriff of
York County as shown on Exhibit "A-1" in accordance with PA R.C.P. 404 and 403. A Notice of
Intention to Take a Default Judgment was filed on July 8, 2009 and served using a U.S. Postal
Certificate of Mailing by first class prepaid postage on July 7, 2009 as shown on Exhibit "A-2"
(Certificate of Service and USPS Form 3817 are attached showing service). No answer or
response having been filed with the Prothonotary as of July 20, 2009 please enter a Default
Judgment in the following amount as of $11,650.49 plus all costs:
Count I $10,978.57
Interest Count I $ 221.92 ($2.92 Per Diem from May 6,2009)
Fees $ 450.00 (Attorney Fees per Contract)
$11,650.49 plus all costs
Respectfully submitted,
By:
ell Law Firm
19 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Attorney for Plaintiff
Date: July 20, 2009
~ i
' ; COUNTY OF YORK
OFFICE OF THE SHERIFF
45 N. GEORGE ST.,YORK, PA 17401`
SHERIFF SERVICE
PROCESS RECEIPT and AFFIDAVIT OF RETURN
SERVICE CALL
(717) 771-9601
1. PLAINTIFF/S! 2 COURT NUMBER 2009-3624
SUSQUE~IANNA VALLEY FEDERAL CREDIT UNION _
3. DEFENDANT/S! 4. TYPE OF WRIT OR COMPLAIN~Orj,ICE, CICA
JOHN A. POTTEIGER & KIMBERLY L. POTTEIGER PLAINT AND NOTICE
SERVE 5. NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD
KIMBERLY L. POTTEIGER
6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO ,CITY, BORO. TWP .STATE ANO ZIP CODE)
AT 30 KIN-LIN DRIVE DILLSBURG, PA 17019
7. INDICATE SERVICE' O PERSONAL l] PERSON IN CHARGE X! DEPUTIZE U CERT. MAIL U 1ST CLASS MAIL U POSTED U OTHER
NOW JUNE 4 , 2009 I, SHERI COUN hereby deputize the sheriff of
YORK COUNTY to execute t ~ ri ~ t cording
to law. This deputization being made at the request and risk of the plaintiff.,
SHERIFF ®f.
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE
OU'1' C F' C O. CL1i~ERL,F,I~iI)
ADV F.EE PAID E9Y Ate!"~:.
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N:B. VYAIVER OF WATCHMAN -Any deputy sherAt levying upon or attaching any property under within cant may leave same
without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff
herein for any loss, destruction, or removal of any property before sherifrs sale thereof.
9. TYPE NAME and ADDRESS of ATTORNEY /ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 1 t. DATE FILED
STEVEN HOWELL, ESQUIRE 17-770-1277 6/03/2009
619 BRIDGE STREET NEW CUMBERLAND, PA 17070
12. SEND NOTICEOF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed d notice is to be marled).
CUMBERLAND ODL)NTY SHERIFFS OFFICE ~ CLm~F_IU.~r;I` C.CI SHERIFF
1
- -a ...
... ., .
~~ ,, .~_
~~ 11~4~ Ryt~$E;i~F-~'>T~f:S1~ER~F~~~=°'DO'NO7~lH .° ''~
13. I scknowfedge receipt of the card 14. DATE RECEIVED 15 Expiralion/Heanng Date
or oomptaii-t as indicted above. MJ MCCILL YC'SO 6-•5-C S- 7 -~-C9
16. HOW SERVED: PERSONAL ( ) RESIDENCE. POSTED ( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW
17. O I hereby certiry and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.).
t .NAME ANO TITLE OF IN I AL SERVED !LIST ADDRES~ RE IF~GO~SH~~A80~E~Relationship to Deten~~ U 19. Date~f Se~ 2 ~~~ of Service
21. EMPTS M I Date Time Miles Int.. Dale Time Miles Int. Date Time Miles .Int... -Gate Time- Miles IM. Date Time .Miles Int.
zz.
23. Advance Costs 24. S ni
ts
ce
C
o
s 25. N!F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary 37 Surchg. 32. Tot. Costs 33 Costs Due Relund Check No
$100.00 p\
~
~f
(
j
~ V,/ ~ /O ~~ ~
i
/
34. For~iyn County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. 38. MileagrJPostage/Not Found 39. Total Costs 40. Costs Due or Refund
47: AFFIRMED and subscribed to bet a me this SO ANSWERS
42. day of ~~1"2QI~T~a. '~ 44, Signature of
Dep. SheriR .. ~ .
".:_ ~ L 45. ATE / I/ ~/.-~
- °~ ! ! l/
` ,yr~Tnidi'r.L 5E!,L 46. SignatureotYOrk
County Sheriff 47. DATE
f ~ ~~;TARY PUBLIC
LI^,`~~. N l `` s
~ ~%IaKCOUNT'(
CITY it ruiti:~ RICHARD P. EU . HERIF 26-09
,
MYC:~i'~6.~1 s ,OIV ::.R!ftESAUG. 12, 2009
48. Signatureofforegn
County Shenrt ,.,,_
~ #
ATE
50. I AC WLEDGE RECEIPT OF THE SHERIFF'S RETURN SIG ~`
NATURE - ~ ~ J
1 ~
OF AUTHORIZED ISSUING AUTHORITY AND TITLE
v.~. rVJIHL JtKVICE CERTIFICATE OF MAILING
wry r of UJtO FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
----- 11 -- --- d
Received Fro Steven Howell
Attorney At Law ~ ~a c
ooo=n r- ~o
619 Bride Street ;- n.¢ n°o^~ N
New Cum}~er)and, PA 170z0't~ ya"~¢ '~~~
ti~
One piece of c ~`
z
- ---- --•
~_ ~~
~D ~1ElL -~'AJ ~jll~~~. C°,~ o
PS Form 3817, January
y C O
-..
- _ __
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED r -_
PROVIDE FOR Steven Howell _ ;+~ ~
Received F Attorney At Law ~ ¢ c ~'o
619 Bridge Street cc"an •z ~.~~
New Cumberland, PA 17070 - a¢ ,^~~°
v
via ~ ~~~
J o
~` W
Z
One iece of ordinary mail addressed to: - ~ `
i
GU ~ ~~ o
~c% i sT~~~, ~~~ ~.4 I ~oY ~ o ~ o
~a
~P
PS Form 3817, January 2001
z
~~ ~ Cfl PY
r ~ --
SUSQUEHANNA VALLEY FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY
Plaintiff PENNSYLVANIA
VS.
: N0.09 - 3624 CIVIL TERM
JOHN A. POTTEIGER AND
KIMBERLY L. POTTEIGER
Defendants
TO: John A. Potteiger
5 West Main Street
McAlisterville, PA 17049-
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
DATE OF NOTICE: July 7, 2009
IMPORTANT NOTICE
v
:_
~
co :
'~,-
- -~-,
3
. ~
cxa
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 YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU 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 PERSONA AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
CIVIL ACTION -LAW
/"~
AVISO IMPORTANTE
A: John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
30 Ken-Lin Drive
Dillsburg, PA 17019
ECHA DEL AVISO: July 7, 2009
~.
LISTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO
Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS
QUE SE HAN PRESETADO CONTRA LISTED. A MEMOS QUE LISTED ACTUE
DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA
VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS
IMPORTANTES.
LISTED DEBE LLEVAR .EST DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A
LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE.
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO
A PERSONAS QUE CALIFICAN.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
!~ ~
Respectfully submitted,
By:
ell Law Firm "
19 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
_ _ __ __
___ _ _
Supreme Court ID 62063
Date: July 7, 2009
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
John A. Potteiger
5 West Main Street
McAlisterville, PA 17049
Kimberly L. Potteiger
3 0 Ken-Lin Drive
Dillsburg, PA 17019
Date: July 7, 2009
FILED-C't="rICF
QF THE PI•;~?~.~:~-~~j~RY
2009 .lUL 2 f A~11 i~ 5 9
CUP,' ~ ~ ;~ ~~~m~~~±Y
;0~
CIL~ $'1'1(0
~ aa$ aces
1JakeR. ~.la.~.ta~
SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION .
Plaintiff
VS.
JOHN A. POTTEIGER AND
KIMBERLY L. POTTEIGER
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 09 - 3624 CIVIL. TERM
CIVIL ACTION -LAW
RULE 236 NOTICE OF FILING JUDGMENT
(X) Notice is hereby given that a money judgment in the above captioned action has been
entered against Kimberly L. Potteiger in the amount of $11,650.49 plus all costs on July
~"~ , 2009.
(X) A copy of all documents filed with the Prothonotary in support of the within judgment
is/are enclosed.
BY:
If you have any questions regarding this Notice, please contact the filing party:
Steven Howell, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
This Notice is given in accordance with Pa R.C.P. 236. Notice should be sent to:
Kimberly L. Potteiger John A. Potteiger
30 Ken-Lin Drive c/o Richard S. Friedman, Esquire
Dillsburg, PA 17019 300 North 2"d Street, Suite 402
Harrisburg, PA 17101