Loading...
HomeMy WebLinkAbout04-3005 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, NO. 04 - JODS c.lUte J~ Plaintiff vs. LAURENCE H. GALLAGHER, Defendant CIVIL ACTION -LAW NOTICE TO DEFEND Pursuant to PA RCP No. J018.J You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CAN NOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 EN LA CORTE DE ALEGATOS COM UN DEL CONDADO DE CUMBERLAND, PENNSYLVANIA DIVISION CIVIL A V ISO PARA DEFENDER Conforme a PA Nfun. 1018.1 USTED HA SIDO DEMAND alA EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias despues que esta Dernanda y A viso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defenses 0 objeciones alas demandas puestas en contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda 0 por cualquier otro reclamo 0 alivio solicitado por Demandante. Ustedpuede perder dinero 0 propiedad 0 otros derechos importante para usted. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. 81 USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME paR TELEFONO LA OFICINA FIJADA AQui ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIa REDUCIDO 0 GRATIS. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PENNSYL VANIA STATE EMPLOYEES CREDIT UNION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 04- .3005 C;(J~tT~ Plaintiff vs. LAURENCE H. GALLAGHER, Defendant CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Steven C. Courtney, Esquire and Godfrey & Courtney, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Laurence H. Gallagher, is an adult individual with a last known address of 457 Rupley Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Defendant is, and at all relevant times material hereto was, the applicant for the loans with Plaintiff. 4. Defendant applied to Plaintiff for a personal service loan and visa loan. A true and correct copy of the loan application is attached hereto, incorporated herein and marked as Exhibit "A". 5. Pursuant to the loan application marked as Exhibit "A", Defendant agreed to the terms and conditions of the extension of credit as set forth in the LoanIiner Credit and Security Agreement (hereinafter referred to as "Contract"). A true and correct copy of the LoanJiner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 6. The contract marked as Exhibit "B" contains the terms and conditions of the extension of credit agreed to by Defendant. 7. Defendant has defaulted on the loan payments by failing to make timely payments. 8. Defendant has not made a payment on account of the Loans with Plaintiff since December of2001. 9. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 10. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 11. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 12. Despite Plaintiffs reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on Defendant's loans account balance, all to the damage of Plaintiff. 13. As of May 14, 2004, the total balance due, owing and unpaid on Defendant's Loan accounts with Plaintiff is the sum of $20,943.35. 14. Pursuant to the terms and conditions of the extension of credit contained on the loan application, Plaintiff is entitled to receive and Defendant agreed to pay an annual interest charge on the principal loan balance. 15. Pursuant to the terms and conditions of the extension of credit, Defendant agreed to pay reasonable attorney's fees and all court and collection costs. 16. Plaintiff has retained the services ofthe law firm of Godfrey & Courtney, P.C. in the collection of the amounts due and owing by Defendant. 17. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Godfrey & Courtney, P.c. in the collection of the amounts due from Defendant incident to the within action, and Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 18. The amount of attorney's fees incurred in this matter is $4,188.66. 19. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 20. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Lawrence H. Gallagher, in the amount of $20,943.35, plus interest, reasonable attorney's fees in the amount of $4,188.66, the costs of this action, and such other relief as the Court deems just and proper. Respectful1y submitted, GODFREY & COURTNEY, P.C. ~. By: Steven C. Courtney, Esquire 2215 Forest Hills Drive Box 6280 Harrisburg, PA 17112 (717) 540-3900 J.D. # 74669 Attorney for Plaintiff VERIFICATION I, Bonnie 1. Berkoski, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of COlillse] and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and COlTect to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. [hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. S4904 relating to unsworn falsification to authorities. ~~ fl-i). Bonnie 1. Berkoski Date: DOC/lfll<.!rIf #__ /80JJ1./ Exhibit A l ~il" a 4 ~ PERSONAL SERVICE LOAN AND VISA ACTIVATION NOTICE I - November 9, 1999 tJOY 24 1999 Loan Information: SS #: 163-42-6772 Applicant: LAURENCE H GALLAGHER Ref#: 101956 296 Approval Amollnt: $20,000 Home Telephone #: 717 731-9277 Work Tele~hone #: 410962-6618 Signature: I acknowledge receipt ofthe PSECU LOANLlNER Disclosure and Credit Agreement and agree to be bound by the terms set forth in said agreement. ~A'_ 11 b~/Z- 11-22-<:(7 ~~URENCE H GAL~ER Date . I would like an immediate PSL advance of $ PURPOSE: Send a 0 check, or 0 deposit to my S4 (MoneyHandier/Checking Shares) . Select your Personal Service Loan repayment option. o Payroll deduction 0 Automatic Transfer 0 Direct Payment o Self Service Telephone o Homebanking . I 0 want 0 do not want overdraft protection from my Personal Service loan. . I would like an immediate VISA advance of $ . PURPOSE: Send a 0 check, or deposit to my S4 (MoneyHandler/Checklng Shares) . You may have one additional card issued on your VISA account. Indicale your choice beiow: ~e issue an additional card in the name below. I authorize him/her to use it and I accept full responslbmty for all charges and/or cash advances just as though I made them. Authorized card holders may not order replacement cards or obtain VISA account information (I.e. detailed transactions, balance Information, payment activity). LAURENCE H GALLAGHER must sign below> ~ _ ___ t;:.:':=C~:'d(A~ ::atureOILAURENC~~ -- -----_...______________._. ~ ~-.-_ t ,.. SCANNED >- Exhibit B r)tl. ,i.':J ~~','. '__,,''" ('"t;" ,,~~<~ ,':'~ :!r' "',,t,... ..-r-'''' "':) ": ~,-,.",. "r' ,~, .-:""l '_ "" ,~"', " 1", : ~ k' ~/ii;/....;J}'... t,'lirJA";i;it;.l t'<ofY'"".;..J\~";; J>-..;jfJ'~'U-)t...'''''..j vi;,:;;iJ'/a. U',ll;Oi; PO Box 67013 . Harrisburg, PA 17106-7013 . (71'1) 234~8484 (BOO) 237~7328 Nationwide Loan Disclosures ':.T;.r"I.N1::(:lI.ll:I::('Ji"-r~:/::(::(III::("i"-r""'t:I'it:.",..::(."'JIN~'l/..'fI/I(.}'''f.'I:1 This lOANLlNER Credit Agreement and Truth in lending DiSClosure will be referred to as "this Plan." "you" and ''your'' mean e~ch person who signs this Plan. The "credit union" means PSECU or anyone to whom the credit union transfers its rights under this Plan. HOW THIS PLAN WORKS. The credit union anticip2tes thaI )leu will borrow money (called advances) under this Plan from tlme to time. The credit union, however, Is not required to make advances for you under this Plan and can refuse a request for an advance at any time. The Addendum describes t/1e different types of credit (called subaccounts) available under this Plan. If yOIJ have been approved for credit under a subaccount marked with a star (*), you will be given a specific credit limit for that subaccount Fer other subaccounts yOu may not be given a specific dollar limit. . PROMISE TO PAY. You promise to repay to the credit union all advances made to you under this Plan and any applicable charges described in the Addendum together with interest on what you owe unW the total amount has been repaid. The interest rate depends on the subaccount under which the advance is made. The Addendum shows the current interest rates as daily periodic rates and their corresponding annual percentage rates. If the interest rate for any or aU advances is a variable Interest rate, the Addendum explains how the variable- intere:st rate works. PAYMENTS. The amount of payments for an advance is determined according to the payment schedule in the Addendum. If the Addendum Ilaa no payment schedule tor a subaccount, the amount and due date of payments wlJl be determined at the time of each advance. You may pay any or all at the principal balance on any busjness day. You promise to make payments in the amount requited under the payment schedule provided on YOLlr disclosure statement. Payments are not reduced as the principal balance declines. Payments must Include any amount past due and any amount by which you have exceeded any credit limit you have been given fOr a subaccount. You may prepay an or part of what you owe at any lime without any prepaymenl. penalty. LATE CHARGE. If your (minimum) payment is not received by us within 15 days of its due date we may charge and you have to pay a late Charge of 5% of overdue payment. COST OF CREDIT. The dollar amount you pay for money borrowed is called a finance charge and begins on the date of each advance. To compute the finance charge, the unpaid balance for eaCh day since your last payment (or since an advance if you have not yet made a payment) is multiplied by the applicable dally periodic rate. The sum of these amounts is the finance charge owed. The balance used to compute the finance charge is the unpaid barance each day after payments and credits to that balance have been subtracted and any new advances have been added. -A finance charge will be computed separately for each separate balance under this Plan. SECURITY INTEREST ~ You agree ,that all balances und_er this Plan except those obtained by using your A TM card to access your line of credit subaccount will be secured by the shares elnd deposils in all joint and indIvidual accounts you have with the credit union now and in the future. You will give us a security interest in aU indMdual and joint accounts you have with the credit union now and in the future to secure all advances obtained by use of your A TM card. Additional security will be reqUired depending on the subaccount under which an advance is requested. For example, a subaccounl called "New Car Advances" means the security will be a new car. Share$ and deposits in an Individual Retirement Account and any other account that would lose special tax treatment under state or federal law if given as security are nol subject to the security interest you have given in your shares and deposits. Property given as security under this Plan or for any other loan may secure all amounts you owe the credit union now and in the future. However, for purposes of loans made under this LOANlINER Agreement, the credit union specifically waives any security Interest it may have in your dwellings given through any other mortgages or security agreements. DEFAULT - 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 this Plan or if anyone is In default under any security agreement made in connection with an. advance under this Plan. You will be in default if you die, file fer r."~~Tl.1:"1:::.1, r,:-:-,_,C;1~ hS'::!'Jen!, l,8':e your PSECU Bccmmt rarni~'"led, if you make any false or misleading statements in any credit application or update of credit information, or if something happens which the credit union believes Illay substaotlaUy reduce your ability to repay what you awe. In the case of toans not conforming to policy, the credit union reserves the right to charge the highest signature subaccount interest rate currently in effect at PSECU or may reqUire payment in fulL \iVhen you are in default the credit union can demand immediate payment of the entire unpaid balance under tl1is Plan without giving you advance notice. If immediate payment is demanded, you will continue to pay interest, at the applicable interest rates in effect under this Plan, until what you owe has been repaid. "a demand for immediate payment has been made, the shares and deposits given as security for this Plan can be applied towatds what you owe. In the case of Certificate Secured loans, you agree to pay any penalties in connection with redemptIon of the certificate. The Credit union can ~lso exercise any other fights given by lawwhen you are in default PROPERTY INSURANCE. You will be required to purchase property insurance on certain types of security that you give for advances. You may purchase the property insurance from anyone you choose that is acceptable to the credit union. CANCELLING OR CHANGING THIS PLAN. The credit union has the right fo change the terms of this Plan from time 10 time after giving you any advance notice required by law. Any change will apply to future advance.s, and at the discretion of Ihe credit union and subject to any requirements of the applicable law, will also apply to unpaJd balances, An increase in the daily periodic rate under a variable interest rate Is not considered a change in terms under thit Plan. The tredit union can cancel the entire Plan or any part of this Plan at any time. You can cancel this Plan at any time. Your obligation to pay the unpaid balances under the terms of this Plan continues whether you or the credit union cancel this Plan or any part of this Plan. STAiEMENTS AND NOTICES - On a regular basis you will receive a statement showing an transactions under this Plan during the period covered by the statement. Statements and notices will be mailed to you at the most recent address you have given the credit union in writing. NotIce to anyone of you will be notice to all. JOINT ACCOUNTS ~ If this is a joint account, each of you authoriZes the other{s) to get advances individually under this Plan. That means an advance can be made upon the request of only one of you and that the check can be issued to only one of you. If yOU give Inconsistent instructions, the credit union can refuse to follow your instructions. Each of those who sign this Plan wlll be individually and jointly responsible for paying the entire amount owed under this Plan. That means the credit union can enforce its rights under this Plan against anyone of you individually or against all of yeu together. UPDATING INFORMATION. You promise that you will promptly gIve the credit union written notice if you move, change your name or employment. or if any other information you provided to the credit union changes. You also agree fo provide the credit union updated financial information about yourself upon request. The credit union can delay enforcing any of its rights any number of times without losing its rights. If the law makes any term(s) of this Plan unenforceable, the other terms wHl remain in effect SECURITY AGREEMENT -In this agreement all references to "ctedit union" mean the Credit union whose name appears on this agreement and anyone to whtim the credit un.ion aSSigns the lOANUNER Credit Agreement. All references to "the advance" mean the amount in the box labeled "New Balance.~ All refer. ences to nyou~ mean each person who signs this agreement. THE SECURITY FOR THE LOAN. By sign1ng this security agreement in the signature area or under the statement re'erring to this agreement which is on the back of the check or draft you receive for the advance, you give the credit union what is known as a security interest In the property described in the "Security Offered" section of the voucher. The security interest you give includes all aCCessions. Accessions are things which are Clttached to or installed in the property now or in the future. The security interest also inCludes any replace- ments for the property which you buy within 10 days of the advance or any extensions, renewals or refinancing of the advance. It also includes any money you receive from selHno the proper:y or from insurance you na.te on the prope;rty. If the value 01 t;'~ property declines, you promise to give the credit union merE property as security if asked to do so. The credit union wm cease to have a security Interesl in the property described in the "Security Ortered" section of the voucher when the advance is repaid in fun. .;;r.f.C~. P$ECU FORM #- 3146 (02J96) Loanliner Credit Aqreement and )j-ufh in Lending Discfo;Jl,)fe rC;Jntinr:d) WHAT THE SECURITY INtEREST COVERS ~ The security interest secures the advance and any extensk)ns, renewals or refinancings 01' tile advance. It also secures any other advances you have now or receive in the future under lhe LOANLlNER Credit Agreement and any other amounts Y(lU ewe the credit union for any reason now or in the future. If the property description is marked with two stars (~j, tl1e property wlll secure only the advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY ~ You promise that you \)wn the property, or if this 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 ()r claim against the property that you nave not already told the credit union about. You promise not to sell or lease the property or to use it as security for a loan with another creditor until the advance Is repaid, You promise you will allow no security Interest or lien to attach to the property either by your actions or by operatic>n of law. PROTECTING THE SECURITY INTEREST ~ It your state issves a title for the property, you promise to have the credit union's security Interest shown on the title. The credit union may have to file what is called a financing slatement to protect its $E!curlty 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 the credit union thinks is necessary to protect its security interest In the property. USE OF THE 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 written permission from the credit union before making major changes to the property. (3) Inform the credit union In writing berore changing your address or the address where the property is kept. (4) Allow the credit union to Inspect the property. (5) Promptly notify the credit union if the property Is damaged, stolen or abused. (6) Not use the property for any unlawful purpose. PROPERTY INSURANCe, TAXES AND FEES - You promise to pay 81/1 taxes and fees (like registration fees) due on the property and to keep the property insured against loss and damage. The amount and coverage of the property insurance must be acceptable to the credit union. You may prOVide the property Insurance through a policy you already have, or through Cl policy you get and pay for; You promise to make the insurance policy payable to the credit union and to deliver the policy or proof of coverage to the credit union. If you cancel your insurance and get a refund, the creefit union has a right to the refund. If the property is lost or damaged, the credit union can use the insurance settlement to repair the property or apply it towards what you owe. You authorize the credit union to endorse any draft or check which may be payable to you in order for the credit union to collect any refund or benefits due under your insurance policy. If you do not pay the taxes or fees on the property when due or keep it insured, the credit union may pay these obligations, but is not required to do so. Any money the credit union spends ror taxes, fees or insurance will be added to the unpaid balClnce of the advance or a new advance will be made and.'you will pay the Interest on those amounts at the same rate you agreed to pay on tile advance. If the credit union adds amounts for taxes, fees or insurance or makes. a new advance to Include these funds, your payments will be increased by the amount necessary for the total amount due to be paid off In the samenum.ber of months originally scheduled. OEFAUl T ~ You will be in dersult ir you break any promise you make under this agreement. You will also be In default under the LOANUNER Credit Agreement If you are pledging property, but have not signed the lOANI.JNER Credit Agreement, you wlU be in default if anyone is in default who has signed the lOANL.INER Credit Agreement. WHAT HAPPENS IF YOU ARE IN DEFAULT - When you are in default, the credit union can, without advance notice to you, require immediate payment of what you owe under the lOANlINER Credit Agreement and take possession of the property. You agree the credit union bas the right to take possession of the property without gOing to court and without giving you advance notice. If you are asked to do so by the credit union, you promise to denver the property at a time and place the credit union chooses. The credit union wiU not be responsible for any of your other property, not covered by this agreement, that you leave Inside the property. The credit union will try to return that property to you or make it available for you to claim, After the credit union has possession of the property, It can self/t,and apply the money received to any amounts you owe the credit union. The credit union will give you notice of any publiC sale or the date arter which a private sale will be held. The expenses of the credit union for taking possession of and Selling the property will be deducted from the money received from Ihe sale. Those costs may include the cost of staring the property, preparing it for sale and attomey's fees to'the extent permitted under state law or awarded under subsection 506(b) of the BankruplCY Code. The rest of the sale money will be applied to what you owe under the LOANUNER Credit Agreement If you have agreed to pay the advance, you will also have to pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the advance and to what you owe under this agreement. You agree to pay Interest on that amount at the same rate as the advance until that amount has been paid. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT -The credit union can delay enforcing any of its rights under this agreement any number or times without losing the abifity to exercise Its rights later. The credit union can enforce this agreement against your heirs or legal representatives. If the credit union changes the terms of the LOANUNER Credit Agreement, you agree that this agreement will continue to protect the credit union. CONTINUED EFFECTIVENESS - If any part of this agreement is determined by a court to be unenforceable, the rest will remain in effect. This notice contains important information about your rights and our (esponsi. bilities under the Fair Credit Billing Act. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR ST A TEMENT- 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 listed on:"IJour statement. Write to us as soon as possIble. We must hear from you no iater than 60 days after we sent you the first statement 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 fol/owing information: Your name and account number. The dollar amount of the suspected error. Describe the error and expla!n, if you can, why you believe there Is an error. It you need more informat"ron, describe the item you are not sure about. 't you have authorized us to pay a credit card account automatically from your share account or checking account, you can slap the payment on any amount you think is Wrong. TO stop the payment your letter must reach us three business days before the autornatic payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBIUTlES 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 slatement was correc!. After we receive your letter, we Ci:1nnol try to collect any amount you question, or report you as delinquent. We can ccntJnue to send statements to YOu for the amount you 'question,including finance charges, and we can apply any unpaid amount against your credit limit. You do no! have to pay any questioned amount while we are investigating, but you are still Obligated to pay the parts of your statement that are not in question. If we find that we made a mistake on your statement, you will not have to pay any finance charges related to any. questioned amount. If we didn't make a mistak.e, you may have to pay finance charges, and you will have to make up any misse<! payments on the questioned amount. In either case, we will send you a statement oflhe amount you ow.e and the date that it is due. If you fail to pay the amount that we think you owe, we may report you as delinquent However, it our explanation does not satisfy you and you write to us within ten days telling us thai you still refuse to pay, we must teU anyone we report you to that you have a questJon about your statement. And, we must lell you the name of 8nyone 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 questJoned amount, even if your statement 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 servJces. There are two limitations on this right: (a) You must have made the purchase in your home state, with!n 100 miles of your current mailing address; and (b) The purcnase 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 advertisemenl for the property or services. .~l!'~" -'-_..__._,-,,-,-,_..C rJ{'''f.:.rI.~:~::t'Ji.."r:~'.':~III:''''.Vii'fOl/''~'l{'~~..]'.t.II:~ In this Agreement, the words "you" and ''you,'' mean.s each and all of those who apply for the card or who signs this Agreement "Card" means the VISA Credit Card and sny duplicates snd renewers we issue. "Accounr' means your VISA Credit Card Une of Credit account with us. 'We", "u,s", and "ours" means this credit lJnion. RESPONSIBILITY - If we issue you a card, you agree to repay all debts and the Finance Charge ariSing from the use of the card and ithe card account. For example, you are responsible for charges made by YIJurself, your spouse and minor children. You are also responsible for Charges made by anyone else to whom you give the card, and this responsibility contjmJes until the card is recovered. You cannot disclaim responsibility by noti~'ing us, but we will close trle account for new lransactions if you so request and return all cafcls. Your obligatJon to pay the account balance continues even though an agreement. divorce decree or of her court judgment to which we are not a party may direct you or one of the other persons. responsible to pay Ute acoount. lOST CARD NOTIFICATION - If you believe the card ha:s been lost or stolen, you will immediately call the credit union at (717) 234-8484 or (800) 237-7328. After hours call (800) 556-5678. LIABILITY FOR UNAUTHORlzeo USE - You understand that your tota' liability to the credit union sl1all not exceed $50 for any card transactions resulting from the loss, theft or unauthorized use of the card that occurs prior to the time you give notice to the credit union. Such liability does not apply when the card Is used to make electronic fund transfers. CREDIT LINE - If we approve your application, we will establish a self.replenish- ing Line of Credit for you and notify you of its amount when we issue the card. You agree not to let the account balance exceed this approved Credit Line. Each payment you make on the account will restore your Credit Une by the amount of the payment which Is applied to the principal. You may request an Increase in your Credit Une only by written application to us, which must be approved by our credit committee or loan officer. By giving you written notice we may reduce your Credit line from time to time, or with good cause, revoke ~'our card and terminate this agreement. Good cause includes your failure to comply with this Agreement or any other agreement with us, or our adverse reevaluation of your creditworthi. ness. You may also terminate this Agreement at any time, but termination by either of us does not affect your obligation to pay the acc:ount balance. The cards remain our property and you must recover and surrender to us aU cards upon our request and upon termination of this agreement. 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 bUreal.lS and other creditors who inquire of us about your credit standing. MONTHLY PAYMENT - We will mail you a statement every month showing your Previous Balance's of purchases and cash advances, the current transactions on your account, the remaining credit available under your Credit Line, the New Balances of purchases aM cash advances, the Total New Balance, the Finance Charge due to date, and any other billed fees, and the Minimum Payment required. . Every month you must pay at least the Minimum Payment within 25 days of your statement Closing date. By separate agreement you may authorize us to charge the minimum payment 8utomaticaHy to your share or checking account with us. You may, of COurse, pay more frequenUy, pay more than the Minimum Payment, or pay the Total New Balance In full, and you will reduce the finance charge by dO!Llg so. The minimum payment will be {a) 2% of your Tota) New Balance, rounded IIp to the next even dollar, or (b) $20.00, whichever is greater. In addition, at any time your Tolal New Balance exceeds your Credit Une, you must Immediately pay the excess upon our demand. We will apply your payments first to the Finance Charge on bolh purchases and cash advances, then to any billed fees, then to the principal balance of purchases in the order they were posted to your account and then to the principal balance of cash advances. FINANCE CHARGES - You can avoid Finance Charge on purchases by paying the full amount of the New Balance of Purchases each month within 25 days of your statement closing date. Otherwise, the New Balance of Purchases, and the subsequent purchases from the date they are posted to your account, will be SUbject to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Monthly Periodic Finance Charge, Monthly Periodic Rate and Annual Percentage Rate. The Finance Charge is the Monthly Periodic Finance Charge. The Monthly Periodic Finance Charge for each billing cycle will be calculated by multiplying the Average Adjusted 'Balance (see explanation below) for your Account for the bJHing cycle by the Monthly Periodic Rate as disclosed on the Addendum. Ca{cl)laliOn of the Average Adjusted Dal7y Balance, We calculate your Average Adjusted Daily Balance (the balance which is subjeCt to the Monthly Periodic .Rate) as follows; The Average Adjusted Daily Balance for your account for the billing cycle is the average of the adjusted dally balances for each day of the billing cycle. To calculate the Adjusted Oaily Balance 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 the amounts post to your account, we add the amounts of all debits and subtract the amounts or all payments and credits which post to your account that day. . Payments_ are applied first to any late Charges, then to any Over/imit Charge, then to any unpaid Finance Charge for previous billing cycles, Annual Fee, then to the Cash Advance balance, and then to the balance of your Account. Credit! are appRed tirst to the particular type of debt which is being credited, if any, and . then to the balance of your account. After applying payments and credits, we subtract any amount of Finance Charge, Late Charge, Overlimlt Charge and Annual Fee that remains unpaid. Then we also subtract the amount of any Cash Advance transaction that posts to your account on that day or on any previous day on the same billing cycle. The result is the Adjusted Daily l;3a.lance for that day. We add together all the Adjusted Daily Balances for each day in trle billing cycle and divide the total by the number or days in the biJIi/'lg cycle. The result is the Average Adjusted Daily Balance for that biWng cycle. Nqte- that cash advance transactions which are posted to your Account during a billing cycle are not included in the Average Adjus;ted Daily Balance for that cycle, and are therefore not subject to the Monthly Periodic Rate during that cycle. However, they are included In the New Balance shown on the statement for that cycle, and are therefore al~o included In the outstanding balance at the start of the first day of the next billing cycle. 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 .Salance shown on that statement, we will not apply tI1e 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 will also be in derault 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 aoy notice required by law. To the extent permitted by law, you will also be required to pay our collection expenses, including court costs and reasonable attorney fees. USING THE CARD - To make 8 purchase or cash advance, there are two alternative procedures to be followed. One is for you to present the card to a participating VISA plan merchant, to us 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., The monthly statement wili identify the merchant, electronic terminal or financial institution at which transactions were made, but sale, cash advance, credit or other slips cannot be returned with the statement. You will retain a copy of such slips furnished at the time of the transaction in order to verify the monlhly statement. The credit union may make a reasonable Charge for photocopies of slips you may request RETURNS AND ADJUSTMENTS ~ Merchants and others who honor the card may give credit for returns and adjustments, and they wf!J do so by sending us a credit slip which we will post to your account If your credit and payments exceed what you owe us, we will hold and apply this credit balance against future purchases and cash advances, or if it is one dollar or more, refund it on your written request or automatically after six months. FOREIGN TRANSACTIONS ~ Purchases and cash advances made In foreign countries and foreign currencies will be bifled to you in U.S. doHars. The conversion rate to dollars wUl be 0) the wholesale market rate or (ii) Ihe government-mandated rate, whichever is appllcable, In effect one day prior to the proce~sing date, increased by one percent. PLAN MERCHANT DISPUTES - We are not responsible for Ihe refusal of any pian merchant or financial institution to honor your card. We are subject to claims . and defenses {other than tort claims) arising out of goods and services you purchase with the card only if you have made a good faith attempt, but have been unable to obtain satisfaction from the plan merchant. and (a) your purchase was made in response to an advertlsement we serlt or participated in sending you, or j7:i:r.wlii VISA Credit Card Trutlz In Lending Disclosure (continued) (b) your purchase cost more than $50 and was made from a plan merchant in your state or wJthin 100 miles of your tlome. Any other disputes you must resolve directly with the plan merchant. SECURITY INTEREST - To secure your acccunt, you grant us a purchase mcney security interest under the Uniform Commercial Code in any goods you purchase through the accoun!. If you default, we will have the right to recover any of these goods which we tlave not been paid for through our application of your payments in the manner described in the Monthly Payment section. \NIth respect to this account only, we will not assert any statutory right we may have if you are In default to prevent withdrawal of your unpledged credit union shares (Deposits) be/ow 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 othetwise, or any other security interests for all your debts, your account will be secured by your pledged shares (Deposits} and by the property described in those other security agreements, except for your home. 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 thefeafter 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 MU~ transactions. LATE PAYMENT CHARGE -If your Minimum Payment!s not paid within 15 days after the Payment Due Date, you will be subject to a single charge of 5% of the minimum scheduled payment. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement. :t1f::tltl:l'N1rr;tINI'J...nT.i.J.w,;t:t:_lli.r...!ret:I:t, ~/:t"''''-'''''.:I::tetIJIli.'l['J''_'JI."!IlIC'}''f.IJ:/ MONEY ACCESS CARD CARDHOLDER AGREEMENT -In thJs Agreement C'I" or "we"), in consideration of The Pennsylvania Stale Employees Credit Union ('you" Of "your? issuing to me a Money Access Card, hereby agrees to be legally bound by the following terms and conditions. ACCOUNTS AND USES OF MONEY ACCESS CARD -I have the account(s) (including Checking, Regular Shares, and Personal Service Loan (PSL)) with you set forth on my application form with this Agreement. 'hereby request that you Issue to me one or more Money Access Cards to be used in connection with such accounts as described in this Agreement J understand I may use the Money Access Card at a Money Access Center to (1} withdraw cash from, (2) make or arrange for deposits In, (3) effect transfers to or tram my accounts, (4) receive information regarding the balance In my account(s) or (5) make cash advances from my credit account(s} In the amounts I request. I may also use tlUtomated tetler machines throughout the United States and in certaIn foreign countries which bear the PLUS System n.ame and logo to (1) make withdrawals from, (2) effect transfers to or from, or (3) receive information regarding the balances in my Checking or Regular Shares. I may also make a cash advance from my Personal Service Loan if I have a PSL. approved and in place. I further understand I may use the Money Access Card to purchase goods and services C'Purchase") at any retail establishment C'Merchanf') where Money Access Cards are accepted by such Merchant. If ( use the Money Access Card to make a Purchase or obtain cash, if permitted by the Merchant, I shaH be requesting you to wllhdraw funds in the amount of such Purchase (including any cash received from the Merchant) from my Checking Shares and directing or ordering you to pay such funds to the Merchant. I request that you provide to me such other services or access ta other A TM systems or nefIHorks using the Money Access Card which you may later make available and which you advise me are offered in connection with my account(s) set forth on my application form_ I also understand that from time to time 1 may request in writing thaI you provide access to additional accciunts of mine through the Money Access Card you have issued to me. I agree that the uses of the Money Access Card described in this Agreement shall be subject 10 the rules and regulations Of each l1Iccount which accessed by such cafd. USE OF PERSONAL IDENTIFICATION NUMBER rPIN") WITH MONEY ACCESS CARO...-runderstand that a Money Access Center or a PLUS System ATM Is an automated teUer. It can and will perform many of the same tasks as a human teller. J acknowledge th~l! the Personal Identification Number or PIN which I use with the Money Access Card is my signature, identifies the bearer to the Money .' Access Center, PLUS System ATM, or other network ATM and authentJcates and validates the directions given just as my actual signature and other proof identify me and authenticate and validate the directions to a human teUer. I also understand that a merchant which accepts the Money Access Card for a Purchase transaction may have an electronic terminal (Merchant-operated or self.service) which requires the use of my PIN and when my PIN is used at a Merchant's terminal, it wiU authenticate and validate the directions just as my actual signature wfl/ authenticate and validate my directions gIven to you. I acknowledge that my PIN is an identification code that is personal and confidential and that the use of the PIN with the Money Access Card Is a security method by which you are helping me to maintain the security of my account(s}. Therefore, J AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO ONE ELSE LEARNS MY PIN. HOW TO CONTACT MONEY ACCESS SERVICE - I agree to contact the Money Access SelVice immediately if I believe the Money Access Card or PIN has been lost or stolen or that an unaulhorized transfer from my account has occurred or might occur, by phoning, and by confirming such information in writing: PSECU P.O. Box 67013 Harrisburg, PA. 17106~7013 (717) 234-8484 in Harrisburg (800) 237-7328 mD) Nationwide (717) 777-2100 (rOO) in HSffisburg (800) 472-1967 (TOO) Nationwide Money Access ServIce (800) 222-2781 In Pennsylvania (800) 523-4175 in other states CHARGES.. I agree to pay the 50 cent penalty charge on any cash disbursement transaction (loan advance or share withdrawal) l11at is less than $20. I agree to pay a 25 cent charge on each balance Inquiry. I agree to pay the charges or transactJon fees which are charged by you for these services or for services which may later be offered as such fees or charges may be Imposed or changed rrom time to time. DEPOSITS ~ I agree that when I make a deposit at a Money Access Center that you have the right to verify the deposit before you make the money available to me. 111 dellver cash, checks or other items to a Money Access Center, I understand and acknowledge thai the funds from my deposit may not be available for immediate withdrawal and that the availability of my deposit shall depend on your rules and regulations regarding the particular sccount In which I am making a deposit. the items that I am deposIting and whethef the deposit Is made at a Money Access Center that is owned by you or another financial institution. I also understand and acknowledge that not all Money Access Centers may accept deposits and some Money Access Centers may Jimit the amount of funds which may be deposited and you may not control these limits. LIABILITY ~ It the Money Access Card is Issued for a joint account, we agree to be jointly and severally liable under the terms of this Agreement and the agreement for such account. I agree that if 1 make deposits ot payments to my account(s) with Items. other than cash (checks, drafts .or other Items} and you make funds l!Ivailable to me from such deposits prior to their collection, I agree that you may deduct the amounts. of such funds from my account(s) which are not collected or, if the funds In my account(s) are Insufficient at such time, I will promptly p8y to "you any amount of such funds which are not collected. AMENDMENT OF THIS AGREEMENT - J agree Ihat from tJme to time you may amend or change the terms of this Agreement including amendments or changes to add further Money Access Card services or to amend or change the charges for these services. You may do so by notifying me in writing of such amendments or changes and my use of the Money Access Card after the effective dale of any such amendment or Change shall constitute my acceptance of and agfeement to such amendment or change. OWNERSHIP. I agree that the Money Access Card Is your property and I will surrender it to you upon your request. I agree that the Money Access Card Is non-transferable. MONEY ACCESS CARD DISCLOSURE STATEMENT. PSECU believes you will find using the Money Access Centers helpful and convenient. The purpose of this Disclosure Statement Is to inform you of certain rights that you have under the Electronic Funds Transfer Act. MONEY ACCESS CENTER SERVICES ~ You may use your Money Access Card with your Personal Identification Number (PIN) at Money Access Centers located in Delaware, Maryland, New Jersey, New York and Eastern Pennsylvania to conduct any of the following transactions for the accounts accessed by your Money Access Card. ~iIf;l'I~. -_.-.':.~.~---'". Electronlc.Funds Transfer. MAC Agreement and Requlatlon toe Disclosure (continued) (a) Determine the account balance(s} of your Checking, your Regular Shares and your Personal Service Loan. (b) 'A'ithdraw cash from your Checking and your Regular Shares. (c) Make a cash advance from your Personal Service Loan. (d) Deposit currency, checks, or drafts (coins are not acceptable) in amounts less than $10,000 fortransmlssfon to PSECU for deposit in your Checking and your Regular Shares. NOTE: Deposits may not be made In Money Access Centers located in Maryland or New York. (e) Make loan payments at PSECU's Strawbeny Square Revenue or Service Center, the Capitol Complex, or 1 Credit Union Place Money Access Centers by endosing cash, checks, or drafts and the payment coupon on those Items that are normally accepted at the office of the Pennsylvania State Employees Credit Union. (f) *from your Checking to your Regular Shares or Personal Service Loan (PSL); *from your Regular Shares to your Checking or Personal Service Loan (PSL); .from your Personal Service Loan (PSl) to your Checking or Regular Shares. We wish to inform you that some Money Access Centers located In these areas may only provide access to your Checking, your Regular Shares, snd your Personal Service Loan. Not aJl Money Access Centers may accept deposits. There may also be limits on the amount of funds which you may deposit in certain Money Access Centers. In addition. you may use your Money Access Card with your Personal Identifica- tion Number at Money Access Centers located in New York. to withdraw cash or make a cash advance or obtain the available balance from your Checking, your Regular Shares, and your Personal Service Loan. TRINET (MAC WEST) SERVICES ~ You may use your Money Access Card with your Personal Identification Number at Money Access Centers located In Western Pennsylvania, Ohio and West Virginia for the services described below. These Money Access Center services are provided through. Tri-State Network Association, Inc. ("MAC VVESr' or "TRINET') and lis participating financial institutions. You may request any of tne following Iransactions for the accounts accessed by your Money Access Card. (a) Determine the available balance{s) from your Checking, your Regular Shares, and your Personal Service Loan (PSL). NOTE: MAC West only gives daily available balances {maximum daily availa.ble balance - $300}. (b) Withdraw cash from your Checking and your Regular Shares. (c) Make a cash advance from your Personal Service Loan. (d) Deposit currency, checks or drafts (coins are not acceptable) In amounts up to a total of $5,000 for transmission to PSECU for deposit in your Checking and your Regular Shclres. (e) Payments are not accepted at MAC WestATMs. (1) Transfer funds: . from your Checking to your Regular Shares or Personal Service Loan (PSL); . from your Regular Shares to your CheckIng or Personal Service Loan (PSL); . from your Personal Service Loan (PSl) to your Checking or Regulslf Shares. These are the Money Access Center services currently available through MAC We~t.. Other services may be offered in the future. PLUS SYSTEM SERVICES ~ You may use your Money Access Card and your Personal Identification Number (PIN) at any PLUS System automated telJer machine (PLUS SYSTEM A TM) located throughout the United States, Puerto Rico, Canada, Great Britain, and Japan to conduct any of the following transac.- tions on the accounts accessed by your Money Access 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 Service Loan (PSL). (d) Deposits are not available through PLUS System A 1Ms. (e) Payments are not accepted at PLUS System A TMs. (1) Transfer funds: * from your Checking to your Regular Shares or Personal Service Loan (PSL); . from your Regular Shares to your Checking or Personal Service Loan (PSL); * from your Personal Service Loan (PSl) to your Checking or Regurar Shares. These are the Money Access Center services currently available through the PlUS System network. Other services may be offered in the future. HONOR SYSTEM SERVICES ~ You mey use your Money Access Card with your Personal Identification Number {PIN} at any HONOR automated teUer machine (HONOR A TM) located throughout Florida and other areas where there are HONOR ATMs. The fOllowing transactions may be done on the accounts accessed by your Money Access Card. (a) Determine the account balance(s) of your Checking, your Regular Shares and your Personal Service Loan {PSt) (b) INithdraw cash from your Checl;lng and your Regular Shares. (c) Make 8 cash advance from your Personal Service loan (PSl). Cd) Deposits are not available through HONOR System A TMs, (e) Payments are not accepted at HONOR System A 1Ms. (f) Transfer funds: . from your Checking to your Regular Shares or Personal Service loan lPSL); . from your Regular Shares to your Checking or Personal Service loan (PSL); .. from your Personal Service Loan (PSL) to your Checl<ing or Regular Shares. These are the Money Access Center services ClJrrently availabre through the HONOR System network. Other services may be offered in the future. OTHER ArM NETWORK ACCESS - From time to time, PSECU may make arrangements with other A TM networks to grant access to Money Access Cards. PSECU shall Inform you when such arrangements are made and describe the services that are available to you. Any Charges will also be described. PURCHASE TRANSACTIONS - You may use the Money Access Card to purchase goods and services C'Purchase") at any retail establishment ("Merchant") where Money Access Cards are accepted by such Merchant. The amount of all such PUfchases will be deducted from your CheCking Shares. \'VIlen you make a Purchase using the Money Access Card. you will be requesting PSECU to withdraw funds from your Checking Shares in the amount of the Purchase and dIrecting PSECU to pay these funds to such Merchant. NOTE: lIVhen USing a VISAlMAC card to purchase gOOdS and s(JIVlces at any retail establishment. your purchases will be chatged to your VISA account. LIMITATIONS ON THE USE OFYOOR MONEY ACCESS CARD - You may withdraw up to $300 per day from one or a combination of your accounts by using a Money Access Card provided the funds available at a Money Access Center, PLUS System or HONOR ATM. In addition, you may withdraw up to $300 at point or sale locations. The day for withdrawal limits starts at 12 midnight each day end ends at 12 midnight the next day. For security purposes, there are also certain daily limitations on the frequency of use of the Money Access Card. However. these Ilmitations are not revealed for security reasons. The Pennsylvania State Employees Credit Union Is not obliged to maintain such limitations. You wnJ be denied use of your Money Access Card if you exceed the daily withdrawal/purchase limit, 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 Money Access Center, PLUS System or HONOR 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 your Money Access Carel... The number of attempts that result in machine retention is not revealed for security purposes. CHARGES FOR TRANSACTIONS - There are no charges for PSECU Money Access Card transactions of $20 or over, A penalty charge of 50 cents will be imposed for each cash disbursement transaction (loan advance or share withdrawal) that Is less than $20. PSECU does reserve the right to Impose and change a fee schedule from time to time and to charge your account In accordance with the fee schedule that will be provided to you at least twenty-one (21) days prior to the Imposition or Change in assessment. ADDITIONAL DEPOSIT INFORMATION - Deposits made at Money Access Centers are posted to your account(s) accord'lng to the rules and regulations 0' those account(s) and PSECU's funds availability policies, which are contained in our disclosure statement required under the Expedited Funds Availability Act ("EFAA'l A copy of this statement has been provided to you or is avallable upon request. You may not deposit any foreign currency. All deposited Items are removed from the Money Access Center before 3 p.m. each business day. The Pennsylvania State Employees Credit Union reserves the rlght to verify the items so deposited before such funds are made available to you. However, you may withdraw against the amount deposited up to a maximum of 1 00 percent of the deposit or $300, whichever is less. When all of the deposited funds become available, you may withdraw against the entire amount deposited up to $300. You may deliver cash, checks, and other items at most Money Access Centers located in Pennsylvania, New Jersey and Delaware for Iransmission to us for deposit in your accoun!(s). However, some Money Access Centers may not accept such Items for deposit and certain other Money Access Centers may limit the amount of funds you deliver for transmission to PSECU for deposit in your accounls. You may not deliver such items at Money Access Centers located In Maryland, New York or ~ir.1.1;.a." I electronic FW1ds Tran.sfer, MAC Ar;reemen( and RerJulatlon -e- Disclosure (continued) West VIrginia. If Ihe amount of the funds contained in your deposit envelope differs by more than $1 from the amount you have indicated to the Money Access Center, PSECU will adjust your account(s) to reflect the amount received and advise you Of any difference. RECORP OF TRANSACTION. You will receive a printed receipt at tile time of the transaction for each Money Access Center, PLUS System. or HONOR A TM, or Purchase transaction that you make. You will receive a monthly statement Showing the status of your account(s), transactions made during the past month, and any penalties or charges PSECU may Impose for such services or transactions. LIABILITY FOR UNAUTHORIZED TRANSFERS. Contact PSECU or tha Money Access Service Immediately I' you believe your Money Access Card or Personal Identification Number (PIN) has been lost or stolen. Telephoning PSECU at (717) 234.8484 in Harrisburg, (BOO) 237.7328 Nationwide, (717) 777-2100 (fOO) In Harrisburg, (SOO) 472~19S7 (rOD' Nationwide during business hours or Money Access Service at (SOD) 222~27B1 in Pennsylvania, or (800) 523.4175 in other slates is the best way to keep your losses to a minimum. You could lose all your money in the account(s) if you take no action to notify PSECU of the loss of your Money Access Card or PIN. If you notify PSECU of the loss, your liability is as follows. (a) If you contact PSECU within two business days of the loss or your discovery of tne losS, you can lose no more than $50, if someone used YOllr Money Access Card and Personal Identification Number (PIN) without your permissiort (b) If you do nol contact PSECU within two business days after you" learn of the loss, and PSECU can prove that it could have prevented the loss If you /'lad contacted PSECU, you could lose liS much as $500 if someone used your Money Access Card and Personal Identification Number (PIN) without your permission. (c) If your monthly statement shows transactions or purchases that you did not make and you do not contact PSECU within 60 days af!erthe statement was mailed to you, may not get back any money lost if PSECU can prove that your contacting us would have prevented those losses. Safeguard your Personal Identification Number (PIN). Do not tell or disclose your PIN to any other person. Do not write your PIN on your Money Access Card. Do nOr keep a written record of your PIN near your Money Access Card. BUSINESS DAYS - PSECU's business days are Monday through Friday. HOlidays are not Included. IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR TRANSACTIONS. Telephone PSECU at (717) 234.8484, (800) 237.7328, (717) 777,2100 (TOO), (800) 472~1967 or write PSECU at: Pennsylvania. State Employees Credit Union pO Box 67013 Harrisburg, Pennsylvania 17106.7013 as soon as you. can if you tnink your statement or receipt is wrong. or if yOu need more inforrTlation about a transaction listed on the statement or receipt. PSe.CU must hear from you no later than 60 days after it sent you the first statement on which the problem or error appeared. You must provide the following: (a) Your ntlme, account number, arid Money Ac:c:e6s Card number; (b) Describe the error or tile transaction you are unsure about, and explain as dearly 85 you can why you believe It is an error or why .. you need more information; and (e) The dollar amount or Ine suspected error. If you tell PSECU ora/ly, you must send yourcomplalntorquestiol1 in Writing within 10 business days. PSECU will tell you the results of the investigation within 10 business days for Money Access Center, PLUS System or HONOR. transactions, or 20 business days for Purchase transactions after PSECU hears from you. Any error will be corrected promptly. If PSECU needs more time, it may take up to 45 days for Money Access Center, PLUS System or HONOR transactions or gO days for Purchase transactions to investigate your complaint or question. If PSECU decides to do this, It will recredit your account within 10 business days if it is a Money Access Center, PLUS System or HONOR transaction, or 20 business days if it is a Purchase transaction for the amount you think Is in error. YOLl wiH have the use of the money during the time it ta/<es to complete the investigation. If PSECU does not receive your complaint or question In writing within 10 business days, PSECU may not recredit your account. If PSECU decides there is no error, you will be advised within three buslnel days after the InvestigatiOn Is completed. You may ask for copies or the documents PSECU used In the Investigation. If PSECU credIts your acc:ou!1 with funds while Investigating sn error, you must repay thosa funds if PSECl concludes no error has occurred. DISCLOSURE OF ACCOUNT INFORMATION. PSECU will diSClose Inforrnatiol about your account or the transactions you mak.e to third par1les: (a) where It Is necessary to complete transactions; (b) to verity the existence and standing of your account with PSECU upon the request of a third party, suCh as a credit bureau; (c) to comply with government agency or court orders; (d) In accordance with your wrlttel1 pernU.sslon; (e) to comply with government or administratiVe agency summonses, subpoenas or orders, or court orders; and (Q on receipt of certification from a Federal agency or department that e. request for information is in.compl~nce with the Right to Financial Privacy Act of 1978. PSECU's WABILITY FOR FAlLU~E TO COMPLETE AN ELECTRONIC FUND TRANSFER TRANSACTION - If PSECU tails to complete a transaction on time or in the correct amount, when properly instructed by You,. ~SECU will be nable for damages caused by ourfajlure unless; (S) there are insufficient funds in your account to complete the transaction through no fault of PSECU; (b) the funds In your account are uncollected; (e) the funds in your account are subject to legal process; (d) the transaction you request would exceed the funds In your account plus any available over<fratt credit; (e) the Money Access Center, PLUS System or HONOR A 1M has insufficient cash to complete the transaction; (f) your card has been reported lost or stolen and you are u,jng the reported carei; (g) PSECU has reason to believe that the transaction requested is unauthorized; (h) the failure is due to an eqoipment breakdown that you knew about when you started the transaction at the Monev Access Center, PLUS System or HONOR ATM, or Merchant terminal; (i) t~ fallure was caused by an act of God, fire, or oUter catastrophe, or by an electrical or computer failure or by another cause beyono control; V) it you attempt to complete a transaction at a Money Access center, PLUS System or HONOR ATM, or Merchant terminal ttlat is not a permissible transaction listed above; or (k) the transaction would exceed security limitations 0(1 the use of your Money Access Card. ~ In at1y case, PSECU shall only be liable for actu~l proven damages if t~ failure to make the transaction resulted from a bona fide error despite PSECU's procedures to avoid such errors. [!!.<o.l'ga:.lI ~~. , !<i:/. u;;,.; ~ t: .0", ...- t:~ :::l~ -- ....'" 't:j- !II 0: c3e3 lI)il Q.)'~ !II;!'! .e-- Q,,,, e~ l!,j1O .s~ -Sf? CI) .!.!! t: ~ "S. II) t: t: ~ - o e " o o U o 5 " M () ~ () M o 5 - -'" E ~.. Of!~ E,,_ cv~..8 .c -"" -.c " "'-.c 'tJ C'C 2o~ ..!!!epQ) "-,, u '" -~0 !j QJ (IJ 0>0 ~~ B Ci) <0 C ~ ~ ~ ~ c.~ ~C6.c " " 0 ~Elj ~ (IJ'O 00> C c'" B:O(/l c c " ~ Rm ll:~"5 W~5 C!JUo. "'''0 i!iffi~ U2g wf::ra Uo'iti ~';;.o :z.g ~ -,,'" U. 0." >. " ~ cti:5 rn~.9 :E,gai o " > "E e ~:e= .c E . U E" ~u.~ o cJ.it? . ~ ..: g'~s.s E ~2c~.E Q) go.- ~ '0 ~ ~ ~~~.;~ 01 ~ Q) en QJ .'_ ~ <: '0 iii Q):B II) C C l"Cl "C.::J::;J C rtI .::J :0 C ... CD g- VI lil..2 1; @ OS.::Jcr:eE~1E U';"E~B:~:-.Q) f5 :S ~ c g.Sl (ij o..c Z >. Cll > ~ E'O Q) ::iO~E"O o@-E Z II) Q.:J<(=S CV 1]) <ra-OlD<rll~~ o '0 ~g:Sc;}>':2 -.J CD 5" c t?.o:: () 5:5o~oo:gco o E E..... '0 U I! Q).... >. e ra af ~ S t!: [E '0..... -g:g-8u~~.~ "t: ~ ro CD Ill.!? ro Gl Q) ~ i'? CIl'5'6'O.....::-5 CIl--''&Ul-001!!OC/l ~g~c~t:'8~ 8.E~~B~g:525 <l.l :5 05.1:: Cl 0 ~ e .0 '~"s &~:E; C1l r:: 'g.!?C.O~~E:S.Q lU .0 >. C 1I).c::..... c o ~~.~"fie,~:';": .~ ~ 'C @ ~ (tI c: Q) '6 "0 'C ~ (!)....."fi 0 (! @ 11l 1:::0:50 iiiEU ~ III c..... C1l,S! QJ en OJ o ~ g--:.~.!22'6:S e- 'C Ul ~;; Qf.S (/) =:." 8 en ~(5..c....: '0 ~ ~ c"E8.c:;w C) .~ Q) C fIl 0"" c: 'C E ~ t~~mfl~.E >'-.cc.c'O Ul .g a:IIl'~I=~~';;; ~ E? Gl e &i ~ ~ IV co 'tJ to:: Ct co 1i3.t: e E.2 ~ ..... SC'O cn c.:;:::; '" :::I ~ ~ Cll ~ ro Cll ~:j :i: 5!. ~ tl:: to 1ii:5.... 0 I- a. ro'i;:~:e ro-w ED..o ~ ro 0 .. en o W_:::I", >d!:!~Q. CEftI"'E-oro~lll_ .2 >. g c Cll 5: E ct: (U 1; :. r; s [ R::l ~ := U :J <( to E()-o:J& b 1? Q)'fi o..-w c:: J! Q) .~ IT F. ~ ~ ~ 5!' ~ ~ .~ E ::s "P .r::: Q) '"0 "'C <( @ 0::= LU 2: - -I 2: ~ -J ti " t; ;g '" 0. " ~ ~ " ~ '" .., Q. W I:! :i;: ::J"~/!! "w ~lE w Q. .!! " o 'J:: . . A._ ~;;, :; o o >; 'iii' tl " .c (J gf U _c :Ill "" ~ M .c.c I:! 0 " '" e:.~ M ~ o 0 55 -'" c f! " U " i;; " 'C o ~l! A. . ~IX .. o ~ ~:: -" ;.5 e . Q. e- .~ .... ri~ 0. 0.0 " .- o " o 0 " 0 "= .0. .g';: '" ~ o. .0 o ~ 1010 N'" 0>0 o~ ~~ ~ro q$E N~" -" E ~~'c ii3.:o'e , E::-ID~ CIJ 0:5 a. 1$":05 -" =-CtIl :c: ~ .9.5 ........t::ro cooE G? tIl a. Q) S.,.->..... riii3ffi"fj >'[)u:2 ::c.c -.5:' E'~ tIl_ o.J:: ::J en E .5:' 0.:::- . . c EOoCIJ .::I~~E EOoCIJ 'c~~E .- " Eo C .... " "'0 .J:: B='c t-cwQ. .. Ctl en C ~m~o w.Q.~ ~ .::E~~(; ~c~iij a..(ijB_ .:Eoc.,e ::>-.!!:!E .:E:sjg(l) 2' ~;o [ ~"""CllCQ .cOca. ~~ 0>. oj~ .'J ~~. .~~ A.si' E_~ "~~ .s" .5 '8 ::E~; ~~ "w ~" ~~ Ww "'0 w", "'w "-0. """""" 0.0.0.0.0.0. ~'<l'o.o.o.o. .nui"';"';"<i~ ~""'~""'''''''lN ~'<l'l"ol"ol"ofO) 00-0-0-00. ll)ll)fO)fO)fO)O 000000 000000 C?C?CJCJC!C! '<l'NOCO-o'<:l" COI"o-o""f"'C\J o ~ 0 '" 0 rn,- 1;")- W(I)....,-Vlo 5g~g;c:: ... '- 0 0 CT:l ~~C5C5:c:: ~~~JJ~~ E~~~~~~1ii .t::'~oooo ~ C! or 0 0 0 0 al , o~~f~~~~ ~ ~~~t.'loVloVlo>1- ....-:;:;: c, =, c' E '" "", .c .0 -'" o>c co :=V,I u '" ~~ 8" ~ c o ~ 00 - .- 00 8 8 ~ 15 ~8 0." o != ;;;;; tIl .:~ E ~~ 0'-' 5.'E' " " :e~ " u;en ... '" 100 0:2 0- z G:i ui Q~Cll I- .::I,~ 0,,>- ~g~ ~, 0.::1.9 () g, CO '<:l"<")o..Oo,<r ""f-oCO""OV) ...:..:...:~...;~ 'If>.'lf>.___~. ~ " g, o. ~~ '" " ~- 00 ~ '" El~ ~.- '5~ ,,- mE -" ~[ '" ~ 0.0. Bi:' " 'Ii .~ QJ E c 00 0.1: " " ,e[ " '" Wo. C!Jc ~~ IE 0" WE 1- '2 :s 'E ".."""" 0.0.0.0.0.0. '<:l"'<:l"o.o.o.o. uilri"';";";~ ~""'o-""''-N '<:l"'O;;l'''l''ol''ofO) 00-0-0-00. lOlO"'''''''O ~.........o-........... 000000 000000 C!C!C!C!C!C! '<:l"NOCC-o'<:l" cc"'O'<:l""'N >- f; c o E ." ~'c ~a~M woo..... ~ R 1lJ-:e ~Q~~ 5..~5;:: ="0;:;..... roCro..... C5lllc;;" u.-Jcou.. U:i.E~ ~ (1)="::::1 W2",-.Q cr: I- M,~ o"O~... Cl coo.\! <"~a:l""': ~~C5~ - E 0)0 ::!CIJsG ~ ~~ ~ o<tt:m Z"E~O' <'" . ZU.sa.. Q~~:; ~e~o .::EU...t~ a:::roMa.. o .~t\l.. u.>"":m ~~~g l.JJ C (0'2 B:O::l~ IIlO,;; a.cl.JJCIJ l.JJIllUJ... -J"'a..O W.&=CIJ I- ~ ~Ls 'O;;l'f")o.OO'<t ""f-oc:ofO)o.., "":"':"':N"';'<i -----~ O"C:OCO -qC!~~ -NC\J"ro) --...,.- """" 0000 0.0.0.0. eO eO eO eO ""'0;;1''0;;1''0;;1' COc:oc:oco "'''''''<? ""f'<:l"'O;;I'''''f ggSs 0000 C!C!C!C! ""Occ-o CO-o'<:l"fO) o & g Cll... ri t:!~~~&') 0l0:>:> I: ~5a~~~ 8!11~~~~~ VI'B(ij.2.21ii..Q 1lJ > :> rn rn ll' ... ~Oo:>:>5rn iiggggal~ >o"N'C!.C!..2o i~;;~~~~ - :-. .tiC-en '1:I~OlOlen ~-g :-~~ ~rn""''''''V :r: 0 ' , , alOooo zoooo .si~f~~~ u~"'&')t.1- ~EEEE >~:J~~ _0000 ~EEEE OrtlrtlrtlCll :O::cC:c:c: e&&&& u-J-J-J-J ~ " c o E o : c. .. o " o :; ~ c .e :I 0> C ~ '" 1: ~ [ ~ E " E '2 i ..J III 0. --- g~g~g~~g~~g~g~g~~g~~ N................................................ ooooooooo~oooooogooo ~~~~Rg~re~N~~~:~~ .~""N <::- o e " :; '" ~ . . . - _ 0 lD . E ~ ~ . EA. C i '" .c . 0_ >; 0 . E ~ ~ . .sA. o j E ~ ~ ~ c " o ~ 'i .!! .0 !I. . 0. " . . . ~ " .!! . . ~ . 0.. -eg '=l :;. > C ii .. f\l C ~ oS! 0 w. e ::E:5 0 >- - A. " 0 A. . ..." ",,, '" . L&::5 c :: .. - . . ~ I!. E ~ .s o j . . o ~ e .. . o !P '" . " ! . '" . B . 0 ~ ~ . " ri~ lD 0 o . ~.E ~... ooooooooooooooooooog 0000000000~C!C!C!C!C!C!C!C! . ~ggggggggggggggggggg q~~~~~~~~~~~~~~~~~~~ ~.......................................~~ 0 ~~~S~EEEEEEEESSSSSS~ ...........................................................................................~ 0000000000000000000 ggggggggggggggggggg 0000000000000000000 ~~~~~t~~~~~~~~~~riN~ ~ '" c ~ CO "NU) lriN~ ~~~ " U) ~ oi """ U)U)U) ~~~ N~c-.i v " U) ~ g o " vvv """ U)U)U) ~~~ 8gg 000 C!qC? o N 000 N~N N Ooc -v ~ C- o . o ~ " !l; ~ ~- 1::: I!!" ~~ . co oO~ :;; g-Ci -g...;'o E !:?Qt0078E c..... , ~.~ ~t007.....~ ..Jsg~ o a. - > lQ ~:J;;'O.Q ~ "' c ~ o ~ .!! . " '" '2 . o 10 ..; ti t B ~ . i ~ o N . .Q 2i ~ ~ ~ ~ e o . o ~ . " .~ . '" .. o o e . c ~ f:! ~~. · ~ f" i~ iil E~~ 1:18, ;~ j I:! l~l~j:~ H ~d~ ~i ~~l" ~~ "il...~. 1l} 11" ~ E~ ~g~.~ ~.~'! 3 ~~ i]~ll ~~lj.il 1:j i ~ :1i" ~ll~Hl1~ ~i !i~~i s!,'jsi !; ~~i~i ff:~ij~f !;;~~lj~ "hffl!. 6_ !..~ '.~ll~-' ~ HnH:I l f!iiH: 00 ~~I,~~.~~ I~I=~~.~ '" ~li. ~.u gE!l~Brl u,~~~.ir'l ~.H.&~'!~ ~~ ~ .EI~ ~~I'a~. " l~8 ~~;l~lig ~:~la!~~~~J~a!~6~ 2 ~HjHH~!~Hj~3h N ~"h~fijooB~11r~~li! ~ ~~2.q~..~H8d;H. 5 g.'~.~g0 .B"~'~ i:l~~~~sl~~i~~!~ir J ~~~~ ~i!fj ~;~!~ ~ {s ~~e~~2.6~'~~1l'~i.~ .1.~0-.S.r-.ll'i.>l hH~H~IHlj~~U2 f~~I~ii!f~8:~~~~:jl ~~5 elllg>lQ""t;:>~~_3~u ~I. Clll!ll:!jg~.! !f~I~~:~j ~~~f!c:"..g ~ ~ ~1:~ I" ~1~N~jH H~ f~I!~~I~~~~.lf~i~J ~E~~g~~'.lluBli .'~8 !i.lli~~f!~~ji:~Mg~j =g~~:~~~~~~l5~~~2~ o~~-~Qce ~~ ~ ~E-a 2~j~IC~lllgE~85IJQ~. il~l~i~~~'Mji~~SIB ~ ~18~ Ef~ ijH2i!~~ tl ~~ 8!ii~cr..J-_<:J< Illo::,!! 2~8ij11.~~~!l~:~.!... =~ '~,~di!'~."jjmjj-11!Q dr.; ~.ll..J~E~Hg~ a. ~rl" ~6-1I ~a. .u"~~O wiiilldi1G <l>-S;ili.22w.!!;Z.g g,fi; ~~~~~~~2 0~~~ ~~.; 2~s&!ff5~l~~a~!~~B~ ~. B:~ N V :;l @ "' . ~" DC - 0 g.E . .!: c ~3 .~ !!1e ~.s o ~ eo .!P "", 70 (:) "q u-.iCrt l' ~ .... ~ 6 t~~ ~ , , G .,1 ",'" _..._,,--~---~--_.."' SHERIFF'S RETURN - REGULAR CASE NO: 2004-03005 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS GALLAGHER LAURENCE H KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GALLAGHER LAURENCE H the DEFENDANT , at 1955:00 HOURS, on the 14th day of July , 2004 at 457 RUPLEY ROAD CAMP HILL, PA 17011 by handing to LAURENCE GALLAGHER 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 So Answers: 18.00 11.84 .00 10.00 .00 39.84 ~~d'<:~ R. Thomas Kline 07/15/2004 GODFREY & COURTNEY Sworn and Subscribed to before By: )ft "'- me this I~ ~ day of () . / ,;}Do'! A . D . '--fU7(l. a . ~hO~/::;!;~) ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYL VANIA STATE EMPLOYEES CREDIT UNION, NO. 2004 -03005 Plaintiff vs. LAURENCE H. GALLAGHER, Defendant CIVIL ACTION -LAW PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff and against Defendant, Laurence H. Gallagher, for want of ANSWER TO COMPLAINT. (X) Assess damages as follows: Debt -----------------------------------------------------------------$ 20,943.3 5 Attorney's Commission------------------------------------------ $ 4,188.66 Interest-------------------------------------------------------------- $ to be determined Filing costs-----------------------------------h-------------------- $ to be determined TOT AL--------------------------------------------h--------------- $ _25.132.01 plus costs It is also entered that Possession ofthe 1995 Nissan Maxima bearing Vehic1e Identification Number lNICA21D7ST056352 is awarded to Plaintiff. (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to hislher Attorney of Record. (X) Pursuant to Pa.R.C.P. 237.1, I certifY that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered 31!d to hislher Attorney of Record, if any, after the default occurred and at least ten days p' to the date of the filing of this praecipe and a copy of the notice is attached. DATE: Signature. Steven C. Co ey, EsqUire Attorney D Plaintiff P.O. Box , Harrisburg, PA (717) 540-3900 ID#: 74669 , 2004, JUDGf~TERPj))~~OVE. Prothonotary~, t-~il DiVl~ NOW, ~J 7 (} C) ~ Jc- -, , 8 .-1 T n; I _.J -'::7 '." :;} eTl -.D IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA PENNSYL VANIA STATE EMPLOYEES CREDIT UNION, NO. 2004 -03005 Plaintiff vs. LAURENCE H. GALLAGHER, Defendant CIVIL ACTION -LAW TO: Laurence H. Gallagher 457 Rupley Road Camp Hill, PA 17011 DATE OF NOTICE: August 10,2004 IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Assoc. 2 Liberty Avenue Carlisle, PA 17013 717.249.3166 By: Steven . Courtn~e GODF Y &. COURmL~ P.O. Box 6280 Harrisburg, Pennsylvania 171 10 Telephone: 717.540.3900 LD. # 74669 Attorney for Plaintiff OFTICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Curt Long Prothonotary Telephone: (717) 240-6100 Cumberland County Courthouse 1 Courthouse Square Carlisle, P A 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff: PENNSYLVANIA STATE EMPLOYEES CREDIT UNION versus Defendant: Laurence H. Gallagher Judgment No. 2004-03005 CERTIFICATE OF RESIDENCE PA. R. C. P. 236 I, hereby certify that the precise residence of Plaintiff is: Pennsylvania State Employees Credit Union I Credit Union Place Harrisburg, PA 17110 and certify that the last known address of the within defendant is: Laurence H. Gallagher 457 Rupley Road Camp Hill, PA 17011 Steven C. Courtne , GODFREY & U P.O. BOX 62 Harrisburg, PA 17112 717.540.3900 Attorney for the Plaintiff Attorney ID# 74669 6 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA PENNSYL VANIA STATE EMPLOYEES CREDIT UNION, NO. 2004 -03005 Plaintiff vs. LAURENCE H. GALLAGHER, Defendant CIVIL ACTION -LAW TO: Laurence H. Gallagher, Defendant You are hereby notified that on1 -7 -oc( , the following (Gffief) (Degree) (Judgment) has been entered against you in the above captioned case for your failure to file an answer to the ::;~~:~n ~to~.;;?f$25,132.0l Ptt~~~tere[ t N1\ kr I Prothonotary J u'~ I hereby certifY that the name and address of the proper person(s) to receive this notice is: Laurence H. Gallagher 457 Rupley Road Camp Hill, PA 17011 To Laurence H. Gallagher, Defendidola (Defendidos/as) Por este medio se Ie esta notificando que El de Del , ElIla siguiente (GFdefl) (Deerete) (Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Prothonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Laurence H. Gallagher 457 Rupley Road CampHill,PA 17011 w~ -J ~j ~~lfJ -f::-~ ~ ~ r --- ~ C/ .....S) , -..J \ \:> ~ ---,..S'\ , c~ "" (-;::> 0 , ':"'_'l .'11 .e- (n '''; -r I....' fh .. '-' ,....., "j -. (-, i,::"'" , -, u -, - . -- C) . .. - (.]1 -( "" <:-. rJ- , vs. hltuRerce. /.J, CPJlQqheR.j Defendant' CIVIL ACTION -LAW PRAECIPE TO WITHDRA W/ENTER APPEARANCE TO THE PROTHONOTARY: Please withdraw Steven C. Courtney, Esquire of the Law Offices of Steven C. Courtney, P. C. as counsel ofrecord for Plaintiff in the above-referenced matter. Please enter the appearance of Melissa 1. Van Eck, Esquire of Van Eck & Van Eck, P.C. as counsel of record for the Plaintiff in the above-referenced matter. By: Respectfully submitted, s<~'"c.c~ Attorney ID #74669 P.O. Box 6280 Harrisburg,PA 17112 717-540-3900 By: l{){11~tJxJ) .~ 1I1~ .eel Melissa 1. VanEck, Esquire Attorney ID #85869 P.O. Box 6662 Harrisburg, PA 17112 717-540-5406 Attorney for Plaintiff Date: Document #.. 218597.1 to,.", ... ; r:::.> C 09-5663 Civil Term or, r 1 � tit 3 it r Melissa Van Eck, Esquire Court I.D. No. 85869 4431 N Front St. Third Floor Harrisburg, PA 17110 Attorneys for Plaintiff 717-234-2401 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES IN THE COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. bH - 360S No. 09-5663 Civil Term LAURENCE H. GALLAGHER, Defendant I PRAECIPE TO WITHDRAW APPEARANCE Kindly withdraw the appearance of Melissa L. Van Eck, Esquire as counsel for Pennsylvania State Employees Credit Union in the above-captioned matter. By: 9-," Date: lo-3 7N Melissa Van Eck, Esquire Court I.D. No. 85869 4431 N Front St. Third Floor Harrisburg, PA 17110 717-234-2401 4455024.1 09-5663 Civil Term N,OTA i LUM OCT I , 1 L; )L14-ITY' BARLEY SNYDER `i`' � t� �A Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299-5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES IN THE COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW C(UIJIV. C)q _'10()S No. 09-5663 Civil Term LAURENCE H. GALLAGHER, Defendant PRAECIPE TO ENTER APPEARANCE Kindly enter the appearance of Shawn M. Long, Esquire as counsel for Pennsylvania State Employees Credit Union, regarding the above-captioned matter. Papers may be served at the address set forth below. BARLEY SNYDER Date: I By: Wawn M. Long, Esqui Court I.D. 83774 '/ 126 East King Stree Lancaster, PA 176 2-2893 717.299.5201 4372498.1 4455027.1 f- 09-5663 Civil Term 2014 OCT 16 l PENh'- 't"� t��,� 11 BARLEYSNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299-5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES IN THE COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. O L4- 300 S No. 09-5663 Civil Term LAURENCE H. GALLAGHER, Defendant PRAECIPE Kindly mark the above-captioned matter settled, discontinued and ended, with costs paid, without prejudice and judgment as satisfied. BARLEY SNYDER By: , Sha n . Long, E uire Court I.D. No. 83, 74 Attorneys for Plaintiff Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602 (717) 299-5201 4469285.1