HomeMy WebLinkAbout10-7911' COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
Judicial District, County Of Cumberland
If appellant was
MAGISTERIAL DISTRICT JUDGE JUDGMENT
.4
COMMON PLEAS No. 16 - I q11 L'ul I.
NOTICE OF APPEAL T?
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
Judge on the date and in the case referenced below.
NOTICE OF APPEAL
NAMt UV AYYtLLAN I MAG. DIST. NO. NAME OF MDJ
Pennsylvania State Employees Credit Union 09-3-05 Honorable Mark Martin
ADDRESS OF APPELLANT CITY STATE ZIP CODE
One Credit Union Place Harrisburg PA 17110
DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant)'
12/02/2010 Pa State Employees Credit Union V5 Debra Blosnich
UUUKt I NO.
CV-0000329-2010
This block will be signed ONLY when this notation is required under Pa.
R.C.P.D.J. No. 1008B.
This Notice of Appeal, when received by the Magisterial District Judge, will
operate as a SUPERSEDEAS to the judgment for possession in this case.
FROM
(see Pa. R. C. P. D. J. No. 1001(6) in
before a Magisterial District Judge, A COMPLAINT MUST BE FILED
within twenty
(20) days after filing the NOTICE of APPEAL.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District
Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon
Name of appellee(s)
appellee(s), to file a complaint in this appeal
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
RULE: To , appellee(s)
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: 20
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-05
FILEU-OFFICE
OF THE PR0TH0.N0Ti`,R"(
2010 DEC 29 PM 2: 23
CUMBERLAND COUNTY
PENNSYLVANIA
94i ys ??AI{y
v?ss?8l
e*4
" COMMONWEALTH OF PENNSYLVm14lA
COUNTY OF CUMBERLAND
Notice of Judgment/Transcript Civil
Case
Mag. Dist. No: MDJ-09-3-05
MDJ Name: Honorable Mark Martin
Address: 507 North York Street
Mechanicsburg, PA 17055
Telephone: 717-766-4575
Pa State Employees Credit Union
One Credit Union Place
Harrisburg, PA 17110-2990
Pa State Employees Credit Union
V.
Debra Blosnich
10,1'1 LanMsJ_-r Blvd
)Aa h&n i odour 3 , PA 1?DW
Docket No: MJ-09305-CV-0000329-2010
Case Filed: 8/27/2010
Disposition Summary
Docket No Plaintiff Defendant Disposition Disposition Date
MJ-09305-CV-0000329-2010 Pa State Employees Credit Union Debra Blosnich Judgment for Defendant 12/02/2010
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE
PROTHONOTARYICLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF
JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A
REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR
OTHERWISE COMPLIES WITH THE JUDGMENT.
f` wr,l. wf pDate Magisterial District Judge Mark Martin
I certify that this is a true and correct copy of the record of the proceedings containing the judgment.
Date Magisterial District Judge Mark Martin
MDJS 315 Page 1 of 1 Printed: 12/02/2010 3:48:11 PM
FILED-OFFICE
OF THE PROTHONOTARY
2011 ,lI 10 F 2: !
CUMBc ;L. , O C-MINTY
P_
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Gum*erfand Ld nCcl54v ; ss
AFFIDAVIT: I hereby (swear) (affirm) that I served
® a copy of the Notice of Appeal, Common Pleas No.10-7911 Civil Term, upon the Magisterial District Judge
designated therein on
(date of service) Decemer 31, 2010, ? by personal service ® by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) Debra Blosnich on
December 31, 2010 ?by personal service ® by (certified) (registered) mail,
sender's receipt attached hereto.
(SWORN) (AFFIRMED AND SUBSCRIBED BEFORE ME
THIS _?L DA /Y O dn, 20 I
Signature of official before whomraffi avit was made
/V,4Y ,b!,
Title of official
My commission expires on , 20
C01110AON100ALTH OF PlllNNSYLVANIA
NOWIGI Bed
Caftwo M. Domes, Nofery Public
Cdr of LanaMer, Lom" County
My Cn m d In - Eg"Apill 17.2013
Member, Pwm"wwm Aesodstlon of Nowdes
Signature of afant
Matthew M. Hennesy, quire
Court I.D. No. 307020
AOPC 312A - 05
I-3-II
TO:
Debra Blosnich
1077 Lancaster Boulevard
Apartment 8 }
Mechanicsburg, PA 17055
SENDER:
Hennesy
REFERENCE:
i
?7?9 0 '1008 9040 0034 2156
i RETURN Posta
RECEIPT Certflied Fee
SERVICE
Retum Receipt Fee
Restricted Delvery
Total Postage & Fees
US Postal Service POSTMARK OR DATE
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for Intemationai Man
0 T V! PE P
V E Y L 1"7 i.t 4? tl e lm ?.
17 ??Iy r ,.. ,
s _
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
126 East King Street
Lancaster, PA 17602 Attorneys for Plaintiff
(717) 299-5201 Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
V.
DEBRA L. BLOSNICH,
Defendant
CIVIL ACTION - LAW
No. 10-7911
NOTICE TO DEFEND
Pursuant to PA RCP No. 1018.1
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be entered
against you by the Court without further notice to you for any money claimed in the Complaint
or for any other claim or relief requested by Plaintiff(s). You may lose money or property or
other rights important to you.
30958361
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO N
OT 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 PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
800.999.9108
30958361
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
126 East King Street
Lancaster, PA 17602
(717) 299-5201
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
DEBRA L. BLOSNICH,
Defendant
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 10-7911
AVISO PARA DEFENDER
Conforme a RCP No. 1018,1 del PA
LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas
dispuestas en las paginas siguientes, usted debe tomar la acci6n en el plazo de veinte (20) dias
despues de esta queja y el aviso es servido, incorporando un aspecto escrito personalmente o por
el abogado y archivando en escribir con la corte sus defensas a objeciones a las demandas
dispuestas contra usted. Le advierten que si usted no puede hacer asi que el caso puede proceder
sin usted y un juicio se puede incorporar contra usted por la corte sin aviso adicional a usted para
cualquier dinero demandado en la queja o para cualquier otra demanda o relevaci6n pedida por
Plaintiff(s). Usted puede perder el dinero o la caracteristica u otra endereza importante a usted.
30958361
USTED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE Un ABOGADO, VAYA A O LLAME POR TELEFONO La OFICINA
DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De USTED La INFORMACION
SOBRE EMPLEAR A un ABOGADO.
SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA
PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE
LOS SERVICIOS JURIDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES
EN Un HONORARIO REDUCIDO O NINGON HONORARIO.
Cumberland County Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
800.999.9108
30958361
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
DEBRA L. BLOSNICH,
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 10-7911
Defendant
COMPLAINT
1. Plaintiff, Pennsylvania State Employees Credit Union ("PSECU") is a
Pennsylvania financial institution having an office at One Credit Union Place, Harrisburg,
Pennsylvania 17110.
2. Defendant, Debra L. Blosnich, is an adult individual with a last known address of
1077 Lancaster Blvd. Apt. 8, Mechanicsburg, Pennsylvania 17055.
3. On or about March 12, 1994, Defendant was pre-approved and applied for a Visa
Loan with PSECU. A true and correct copy of the pre-approved Visa Application is attached
hereto as Exhibit "A" and incorporated by reference.
30958361
4. PSECU approved Defendant's application and opened an account ("Account") in
Defendant's name.
5. Defendant received a disbursement on the Account subject to the terms and
conditions of PSECU's Loanliner Credit and Security Agreement and Loanliner Addendum
("Agreement"). A true and correct copy of Agreement is attached hereto as Exhibit "B" and
incorporated by reference.
6. Defendant is in default under the Account for failure to make payments when
due.
7. Notices of default were sent to the Defendant on April 22, 2009 and May 26,
2009. True and correct copies of the notices are attached hereto as Exhibit "C" and incorporated
herein.
8. Pursuant to the Agreement, in the event of default, PSECU is entitled to be
reimbursed for all costs and expenses, including reasonable attorneys' fees incurred in bringing
any action to enforce the Agreement.
9. The balance due and owing to PSECU from the Defendant on the Account is
$7,220.79, plus attorneys' fees/collection costs of $348.56, which totals $7,569.35 plus costs.
10. PSECU has demanded payment from Defendant, but despite these demands, the
Defendant has refused and continues to refuse to make payments.
11. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.,
Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in
writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and
provide Defendant with written verification thereof, otherwise, the debt will be assumed to be
30958361
2
valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for
Plaintiff will send Defendant the name and address of the original creditor if different from the
above.
WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment
in its favor and against Defendant, Debra L. Blosnich, in the amount of $7,569.35, and costs of
suit.
: VQ•Date , U G 13 3011
BARLEY SNYDER LLC
I. ?-?;
By:
Shawn M. Long, Esquire
Court I.D. No. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
126 East King Street
Lancaster, PA 17602
(717) 299-5201
30958361
3
VERIFICATION
Pennsylvania State Employees Credit Union
V.
Debra L. Blosnich
I, Gregory R. Diffenderfer, being duly affirmed according to law, depose and say that I
am the Collection Manager for Pennsylvania State Employees Credit Union; that I am authorized
to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are
true and correct to the best of my knowledge, information, and belief.
To the extent that any of the averments in the foregoing document are based upon the
understanding or application of law, I have relied upon counsel in making this Verification.
This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to
unsworn falsification to authorities.
Dated: i llbkotl
t A5?-
Gregory . Diffenderfer
Complaint_PSECU_BLOSNICH(visa) (2)
EXHIBIT "A"
You're pre-approved for up to $10,000
L::,. (.. .
on our 9.,9% 1f.R dCawitol CacrAd'I VISAO t .
3 3
Debra Blosnidi
820 Fairfield St
Med"csbur Pa. 17055
•z
There's never bye", a better timb to. twm odWAnta?
of PSECU's Capitol Card; "SAI, With `otu
now,
9.9% APR rate for purchases and gtui' 12'M
for cash advances and VISA Checks.thM??'?
Metter card on the marked i F•s
11;:.3 f?,.?/CIF rrgnµtf ., `fr
And to make it even bettex s wr ;"
Just take a minute to fill out and Ib 106t'tt s? tr
application below and we'll settdyou aCapitol
Card VISA.' Your f`:
food credit'histdrj!'io?tlo??ra,ttatl? ?,?,??, ?,?•.,
make you this {"win- Vin" offer - you l) reftive
9.9 /O . • ISA with no annual lee• ? • ' ? M& 5 1A+?w,f '? ?, tTvP'k'?'y?.kn
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t He apptood ereerr that . prekrskurry nnlen dyer audit fdWfry.w etadR'<fOMt as rem" yo
You Pnwkk us for 1*'fP s of updatkf j your uW it states and aMben, We Iessfw ON ti?hl rot b satlptd acadlt p
changes to "t credit status such a bankn*ky. Wn wWwA a, atewhsrtt, let" wtt, nPa.w.iori, Mrt ar?A?tN
an in"irl mWit bne of •soo m i 10.000 band an your ctWkesrthkress rd kmonr.- we dsteerrdns Ua genune d
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EXHIBIT "B"
oy/lr
PennSylvania State Erylployee Credit Union
PW OP., PO Box 67013 ® Harrisburg, PA 17106-7013 ® (717) 234-8484 (800) 237-7328 Natiomvirre
Loan Disclosures
M,
This LOANI_I?.ER Credit Agreement and Truth in Lending Disclosure will be
referred 'a as "Ifiis Plan." "you" and "your" mean each person who signs this
Plan. The "cr dit union" means PSECU or anyone to whom the credit union
transfers its rights under this Plan
substantially reduce your ability to repay vrhat you owe. In the case of loans not
conforming to policy, the credit union reser.,es the right to charge the highest
signature subaccount inlerest rate currently in effect at PSECU or may require
payment in full
HOW THIS PLAN WORKS - The cr:dil union anticipates that you will borrow
Ii (Called ddVanGeS) under This Plan from time 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 the
different types of credit (called subaccounts) available under this Plan. If you
have been approved for credit under a subaccount marked with a star ('), you will
be given a specific credit limit for that subaccount. For 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 until the total amount has been repaid.
The interest rate depends on the subaccount under which the advance is made.
The Addendurn shows the current interest rates as daily periodic rates and their
corresponding annual percentage rates. If the interest rate for any or all
advances is a variable interest rate, the Addendum explains how the variable
interest rate works.
PAYMENTS - The amount of payments for an advance is determined according to
the payment schedule in the Addendum. If the Addendum has no payment
schedule for a subaccount the amount and due date of payments will be
determined at the time of each advance. You may pay any or all of the principal
balance on any business day. You promise to make payments in the amount
required under the payment schedule provided on your disclosure statement.
Payments are not reduced as the principal balance declines, even if the new
advances are made.
Payments must include any amount past due and any amount by which you have
exceeded any ctedii limit you have been given for d subaucounE. You ii-lay prepay
all or part of what you owe at any time without any prepayment 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 the
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 daily
periodic rate. The sum of these amounts is the finance charge owed. The
balance used to compute the finance charge is the unpaid balance each day
after payments and credits to that balance have been subtracted and any 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 under this Plan except those
obtained by using your ATM card to access your line of credit subaccount will be
secured by the shares and deposits 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
all individual and joint accounts you have with the credit union now and in the
future to secure all advances obtained by use of your ATM card. Additional
security will be required depending on the subaccount under which an advance
is requested. For example, a subaccount called "New Car Advances" means the
security will be a new car. Shares 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 not 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
for bankruptcy, become insolvent, have your PSECU account garnished, 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 may
V,0hen you are fir default the credit union can dernand immediate payment of the
entire unpaid balance u rider this Plan withoul giving you advance notica. If
Immediate payment is di;manded, you will continue to pay interest, at the
applicable interest rates in effect under this Plan, until what you owe has been
repaid. If a demand for immediate payment has been made, the shares and
deposits given as security for this Plan can be applied towards what you owe.
The credit union can also exercise any other rights given by law when 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 to
change the terms of this Plan from time to time after giving you any advance
notice required by law. Any change will apply to future advances, and at the
discretion of the credit union and subject to any requirements of the applicable
law, will also apply to unpaid balances. An increase in the daily periodic rate .
under a variable interest rate is not considered a change in terms under this
Plan.
The credit union can cannel 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.
STATEMENTS AND NOTICES On a regular basis you will receive a statement
showing all transactions unriar this Plan during the nerind rnvered by the
statement. Statements and notices will be, mailed to you ai the must recent
address you have given the credit union in writing. Notice to any one 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 will 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 any one of
you individually or against all of you 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 to
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 lave makes any term(s) of this Plan unenforceable, the
other terms will remain in effect.
SECURITY AGREEMENT -In this agreement all references to "credit union" mean
the credit union whose name appears on this agreement and anyone to whom
the credit union assigns the LOANLINER Credit Agreement. All references to
"the advance" mean the amount in the box labeled "New Balance." All refer-
ences to "you" mean each person who signs this agreement.
THE SECURITY FOR THE LOAN - By signing this security agreement in the
signature area or under the statement referring 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 attached 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 selling the property or from insurance you have on the property.
If the value of the property declines, you promise to give the credit union more
property as security if asked to do so. The credit union will cease to have a
security interest in the property described in the "Security Offered". section of the
voucher when the advance is repaid in full.
Loanliner Credit Agreement and Truth in Lending Disclosure (contined)
WHAT THE SECURITY INTEREST COVERS - The security interest secures the
advance and any extensions, renev.als or refinancings of the advance. It also
secures any other advances you have ncaa or receive in the future under the
LOANLINER Credit Agreement and any other arrounls you owe the credit union
for any reason now or in the future. If the properly description is marked v:ith tv:n
stars ("), the prcperfy sec,jle only the ar.vana and not other airoun,ts you
ovie.
OWNERSHIP OF THE PROPERTY - You plernise that you own the property, cr if
this advance is to buy the property, you promise you will use the advance for that
purpose. You prornise that no one else has any interest or claim against the
property that you have riot 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 properly eilher by your actions or by operation of law.
PROTECTING THE SECURITY INTEREST - If your state issues a lille 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 statement to
protect its security interest from the claims of others. If asked to do so, you
promise to sign a financing statement. You also promise to do whatever else
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 before 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 all taxes and
fees (like registration fees) due on the properly 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 a 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 credit 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 for taxes, fees or insurance will be added to the
This notice contains important information about your rights and our responsi-
bilities under the Fair Credit Billing Act.
NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT- If
you think your statement is wrong, or if you need more information about a
transaction on your statement, write us on a separate sheet at the address
listed on your statement. Write to us as soon as possible. We must hear from
you no later 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 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 a credit card account automatically from your
share account or MoneyHandler/Checking account, you can stop the payment
on any amount you think is wrong. To stop the payment your letter must reach
us three business days before the automatic payment is scheduled to occur.
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR
WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless
we have corrected the error by then. Within 90 days, we must either correct the
error or explain why we believe the statement was correct.
unpaid balance of the advance or a new advance v:ill be made and you will pay
the interest on those amounts at the same rate you agreed to pay on the
j advance. If the credit urion adds arnounts for taxes, fees or insurance or makes
i 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 same number of
months originally scheduled.
DEFAULT - You vAl be in default if you break any promise you make under this
agreement. You v:ill also be in default under the LOANLINER Credit Agreement.
if you are pledging property, but have not signed (he LOANLINER Credit
I Agreement, you will be it default if anyone is in default who has signed the
LOANLINER 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 LOANUNER Credit Agreement and take possession of the
property. You agree the credit union has 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 deliver the property at a time
and place the credit union chooses. The credit union will 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 sell it 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 after which a private sale will be
held. Tile 'expenses of the credit union for taking possession of and selling the
properly will be deducted from the money received from the sale. Those costs
may include the cost of storing the property, preparing it for sale and attorney's
fees to the extent permitted under state law or awarded under subsection 506(b)
of the Bankruptcy Code. The rest of the sale money will be applied to what you
owe under the LOANLINER 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 of
tittles w"hout losing tho ability to cx-seise its rights later. The credit union nan
enforce this agreement against your heirs or legal representatives. If the credit
union changes the, terms of the LOANLINER 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.
amount you question, including finance charges, and we can apply any unpaid
amount against your credit limit. You do not have to pay any questioned amount
while we are investigating., but you are still obligated to pay the parts of your
statement that are not in question.
If we find that we made a mistake on your statement, you will not have to pay any
finance charges related to any questioned amount. 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 days telling us that you still refuse to pay, we must tell anyone we
report you to that you have a question about your statement. And, we must tell
you the name of anyone we reported you to. We must tell anyone we report you
to that the matter has been settled between us when it finally is.
If we don't follow these rules, we can't collect the first $50 of the questioned
amount, even if your statement was correct.
SPECIAL RULE FOR CREDIT CARD PURCHASES - 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 limitations on this right: (a) You must have made the purchase in your home
state, within 100 miles of your current mailing address; and (b)
The purchase price must have been more than $50.
After we receive your letter, we cannot try to collect any amount you question, or These limitations do not apply if we own or operate the merchant, or if we mailed
report you as delinquent. We can continue to send statements to you for the you the advertisement for the property or services.
In this Agreement, the v.ords "you" and "your" n, eans each and all of (hose r,ho
apply for the card or who signs this Agreement. "Card" means the VISA Credit
Card and any duplicates and rene'•::als 'are issue. "Account" means your VISA
Credit Card Line of Credit account v:ith us. "We", "us", and "burs" means this
credit union.
RESPONSIBILITY - If we issue you a card, you agree to repay all debts and the
Finance Charge arising from the use of the card and the card account. For
example, you are responsible for charges made by yourself, your spouse and
minor children. You are also responsible for charges made by anyone else to
whonn you give the card, and Ibis responsibiiity continues until the card is
recovered. You cannot disclaim responsibility by notifying us, but we will close
the account for new transactions if you so request and return all cards. Your
obligation to pay the account balance continues even though an agreement,
divorce decree or other court judgment to which we are not a party may direct you
or one of the other persons responsible to pay the account.
LOST CARD NOTIFICATION - If you believe the card has been lost or stolen, you
will immediately call the credit union at (717) 234-8484 or (800) 237-7328. After
hours call (800) 556-5678.
LIABILITY FOR UNAUTHORIZED USE - You understand that your total liability to
the credit union shall 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 Line by the amount of
the payment which is applied to the principal. You may request an increase in
your Credit Line 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 your card and terminate
this agreement. Good cause includes your failure to comply with this Agreement
or any other agreement with us, or our adverse reevaluation of your 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 account balance. The cards
remain our property and you must recover and surrender to us all 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 bureaus and other
creditors who inquire of us about your credit standing.
MONTHLY PAYMENT - We will mail you a statement every month showing your
Previous Balances of purchases and cash advances, the current transactions
on your account, the remaining credit available under your Credit Line, the New
Balances of purchases and cash advances, the Total New Balance, the Finance
Charge due to 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 automatically to your share or
MoneyHandler/Checking account with us. You may, of course, pay more
frequently, pay more than the Minimum Payment, or pay the Total New Balance in
full, and you will reduce the finance charge by doing so.
The minimum payment will be (a) 2% of your Total New Balance, rounded up to
the next even dollar, or (b) $20.00, whichever is greater. In addition, at any time
your Total New Balance exceeds your Credit Line, you must immediately pay the
excess upon our demand. We will apply your payments first to the Finance
Charge on both 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
billing cycle by the Monthly Periodic Rate as disclosed on the Addendum.
Calculation of the Average Adjusted Daily Balance. We calculate your Average
Adjusted Daily Balance (tho balance ::hich is subject !o the Monthly Periodic
Rate) as follows:
The Average Adjusted Daily Balanco for year account fur the billing cycle is the
average of the adjusted daily balances for each day of the hilling cycle.
To calculate the Adjusted Daily Balance each day, v:e take the follovring steps
We take the outstanding balance (all amounts you ov:e) at the start of the day.
Then, in the sequence in vrhich the amounts pest to your account, vie add the
amounts of all debits anc' subtract the amounts of all payments and Credits
which post to your account that day.
Payments are applied first to any Late Charges, then to any Overlimit 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. Credits
are applied first 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, Overlimil 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 Balance for that day.
We add together all the Adjusted Daily Balances for each day in the billing cycle
and divide the total by the number of days in the billing cycle. The result is the
Average Adjusted Daily Balance for that billing cycle.
Note that cash advance transactions which are posted to your Account during a
billing cycle are not included, in the Average Adjusted 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 also 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 Balance shown on that statement, we will not apply the Monthly Periodic
Rate to your Account on your next statement.
DEFAULT - Yuu will be iu default if you fail to rliake any I'Ainimum Paymiient vvithin
25 days after your monthly statement closing date. You will also be in default if
your ability to repay us is materially reduced by a change in your employment, an
increase in your obligations, bankruptcy or insolvency proceedings involving you,
your death or your failure to abide by this Agreement, or if the value of our security
interest materially declines. We have the right to demand immediate payment of
your full account balance if you default, subject to our giving you any notice
required by law. To the 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 a 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 will 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 monthly 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 will 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 billed to you in U.S. dollars. The
conversion rate to dollars will be (i) the wholesale market rate or (ii) the
government-mandated rate, whichever is applicable, in effect one day prior to the
processing date, increased by one percent.
PLAN MERCHANT DISPUTES - We are not responsible for the refusal of any plan
merchant or financial institution to honor your card. We are subject to claims
and 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
rnable to obtain satisfaction from the plan merchant, and (a) your purchase was
Wade in response to an advertisement we sent or participated in sending you, or
VISA Credit Card Truth in Lending Disclosure (continued)
1?h) your purchase cost more than S50 and was made frorn a plan merchant in
your state or within 100 miles of your home. Any ether disputes you must
resolve directly with trip. plan merchant.
SECURITY INTEREST - To sea:re your 3rc3LX.t, you gran) us a purchase mcr',ey
security interest under the Unifrrrn Commercial Coue in any goods you
purchase through the account. If you default, '::e :.ill have the right to recover any
of these goods wihir.h re have not been paid for through our application of your
payments in the manner described in the Monthly Payment section. With respect
to this account only, woe -Al not assert any statutory right ;:e may have If you are
in default to prevent withdrawal of your iinpledged credit union shares (Deposits)
below the unpaid balance of your account. Fic:re:er, if you give or have given us
a spccI pledge of','QU credit union sh:ire ;nom sits) by signing the Pledge_ of
Shares or otherwise, or any other security interests for all your debts, your
account will be serured by your pledged shares (Deposits) and by the property
described in those other security agreements, except for your home.
MONEY ACCESS CARD CARDHOLDER AGREEMENT -In this Agreement ("I" or
"we"), in consideration of The Pennsylvania State Employees Credit Union ("you"
or "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 MoneyHandler/Checking, Regular Shares, and Personal Service Loan
(PSL)) with you set forth on my application form with this Agreement. I 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.
I 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
from 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 automated teller machines throughout the United
States and in certain foreign countries which bear the PLUS System name and.
logo to (1) make withdrawals from, (2) effect transfers to or from, or (3) receive
information regarding the balances in my MoneyHandler/Checking or Regular
Shares. I may also make a cash advance from my Personai Service Loan if t
have a PSL approved and in place. I further understand I may use the Money
Access Card to purchase goods and services ("Purchase") at any retail
establishment ("Merchant") where Money Access Cards are accepted by such
Merchant. If I use the Money Access Card to make a Purchase or obtain cash, if
permitted by the Merchant, I shall be requesting you to withdraw funds in the
amount of such Purchase (including any cash received from the Merchant) from
my MoneyHandler/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 to other ATM
systems or networks 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 I
mayrequest in writing that you provide access to additional accounts 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 to the rules
and regulations of each account which accessed by such card.
USE OF PERSONAL IDENTIFICATION NUMBER ("PIN") WITH MONEY ACCESS
CARD - I understand that a Money Access Center or a PLUS System ATM is an
automated teller. It can and will perform many of the same tasks as a human
teller. I acknowledge that 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 authenticates and
validates the directions given just as my actual signature and other proof identify
me and authenticate and validate the directions to a human teller. 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 will authenticate and validate the directions just as my
actual signature will 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, I 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 Service immediately if I believe the Money Access Card or PIN has been
lost or stolen or that an unauthorized transfer from my account has occurred or
might occur, by phoning, and by confirming such information in writing:
EFFECT OF AGREEMEN-1 - This agreement is the coniraci 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 frorn time to lime by sending you the advance vrrltten notice required
by lave Your use of the cord thereafter ,.`ill indicate your agreerent to the
arnendmenls. To the erlei t the law permits, grid vie indicate in our notice,
amendments writ apply to your existing account halance as yell as to future
transactions.
LATE PAYMENT CHARGE - If your tvlinimurn Payment is not paid within 15 days
after the Payment Due Dare, you will be subject to a single charge of 59,, of the
minimum scheduled payment.
COPY RECEIVED - You acknowledge receipt of a copy of this Agreement.
PSECU P.O. Box 67013 (717) 234-8484 in Harrisburg
Harrisburg, PA. 17106-7013 (800) 237-7328 (TTD) Nationwide
(717) 777-2100 (TDD) in Harrisburg
(800) 472-1967 (TDD) 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) that is less than $20. 1 agree to
pay a 25 cent charge on each balance inquiry.
I agree to pay the charges or transaction 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 from 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. If I deliver cash, checks or other items to a Money Access Center, I
understand and ackn.. ledge that the fiends 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 account in which I
am making a deposit, the items that I am depositing and whether 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 limit the
amount of funds which may be deposited and you may not control these limits.
LIABILITY - If 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 I make deposits or payments to my account(s) with items other
than cash (checks, drafts or other items) and you make funds available 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 aocounl(a) arc in-lificicut at such time, I will promptly pay to you any
amount of such funds which are not collected.
AMENDMENT OF THIS AGREEMENT - I agree that from time 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 date of any such amendment or change shall constitute my acceptance
of and agreement to such amendment or change.
OWNERSHIP - I agree that 'he 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.
Electronic Funds Transfer MAC Aoreement and Regulation Disclosure
(continued)
(a) Determine the account balance(s) of your r0oneyHandled
Checking, your Regular Shares and your Personal Seriice Lean.
(h) Withdravw cash from your r. tonayHandledChecking 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 for transmission to PSECU for
deposit in your MoneyHandler.Checking and your Regular
Shares.
NOTE: Deposits may not he mado in Money Aoress Centers
located in Maryland or New York
(e) Make loan payrncn;s at PSECU's Stravih.c ry Squa Revenue
or Service Center, the Capitol Complex, or 1 Credit Union Place
Money Access Centers by enclosing 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 MoneyHandler/Checking to your Regular Shares or
Personal Service Loan (PSL);
'from your Regular Shares to your MoneyHandler/Checking
or Personal Service Loan (PSL);
'from your Personal Service Loan (PSI to your MoneyHandler/
Checking or Regular Shares.
We wish to inform you that some Money Access Centers located in these areas
may only provide access to your MoneyHandler/Checking, your Regular Shares,
and your Personal Service Loan. Not all 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 Idenlifica-
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 MoneyHandler/
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 WEST" or "TRINET") and its participating financial
.n sfltuflons. ,uu may request any of the following. transactions for the arcoui5ts
accessed by your Money Access Card.
(a) Determine the available balance(s) from your MoneyHandler/
Checking, your Regular Shares, and your Personal Service
Loan (PSL)_
NOTE: MAC West only gives daily available balances (maximum
daily available balance - $300).
(b) Withdraw cash from your MoneyHandler/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 MoneyHandler/Checking and your Regular
Shares.
(e) Payments are not accepted at MAC West ATMs.
(() transfer funds:
` from your MoneyHandler/Checking to your Regular Shares or
Personal Service Loan (PSL);
` from your Regular Shares to your MoneyHandler/Checking or
Personal Service Loan (PSL);
from your Personal Service Loan (PSL) to your MoneyHandler/
Checking or Regular Shares.
These are the Money Access Center services currently available through MAC
West. 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 teller
machine (PLUS SYSTEM ATM) 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 MoneyHandler/
Checking, your Regular Shares, and your Personal Service
Loan (PSL).
(b) Withdraw cash from your MoneyHandler/Checking and your
Regular Shares.
(c) Make a cash advance from your Personal Service Loan (PSL).
(d) Deposits are not available through PLUS System ATMs.
(e) Payments are not accepted at PLUS System ATMs.
(i) transfer funds:
from your tvloneyHandler/Checking to your Regular Shares or
Personal Service Loan (PSI
from your Regular Shares to your MoneyHandler/Checking or
Personal Service Loan (PSL);
from your Personal Service Loan (PSL) to your MoneyHandler/
Checking or Regular Shares.
These are. the Money Access Carter services curranHy available throur,'h the
PLUS System network. Other services inay be offered in Iha future.
HONOR SYSTEM SERVICES - Y.;u may use your Money Access Card mth your
Personal Identification Number (PIN) at any HONOR automated teller machine
(HONOR ATrvT located throughout Florida and cthc;r areas /,here there are
HONOR ATMs. The following transactions may be done on the accounts
accessed by your Money Access Card.
(a) Determine the account halance(s) of your MoneyHandler/
Checkinn; your Regular Shares and ynur Personal Service
Loan (PSL)
(b) Withdraw cash from your MoneyHandieUChecking and your
Regular Shares.
(c) Make a cash advance from your Personal Service Loan (PSL).
(d) Deposits are not available through HONOR System ATMs.
(e) Payments are not accepted at HONOR System ATIVis.
(1) transfer funds:
from your MoneyHandler/Checking to your Regular Shares or
Personal Service Loan (PSL);
from your Regular Shares to your MoneyHandler/Checking or
Persona,' Service Loan (PSL);
from your Personal Service Loan (PSL) to your MoneyHandler/
Checking or Regular Shares.
These are the Money Access Center services currently available through the
HONOR System network. Other services may be offered in the future.
OTHER ATM NETWORK ACCESS - From time to time. PSECU may make
arrangements with other ATM 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 ("Purchase") at any retail establishment ("Merchant') where
Money Access Cards are accepted by such Merchant. The amount of all such
Purchases will be deducted from your MoneyHandler/Checking Shares. When
you make a Purchase using the Money Access Card, you will be requesting
PSFCU to withdraw hands from vmrr MonevHandler/Chnckinn Shares in the
a, ,run , of the f urchase and dire hng PSECU to pay these funds to such
Merchant.
NOTE. When using a VISA/MAC caul to purchase goods and services at any
retail establishment, your purchases will be charged to your VISA account.
LIMITATIONS ON THE USE OF YOUR 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 of
sale locations. The day for withdrawal limits starts at 12 midnight each day and
ends at 12 midnight the next day. For security purposes, there are also certain
daily limitations on the frequency of use of the Money Access Card. However,
these limitations are not revealed for security reasons. The Pennsylvania State
Employees Credit Union is not obliged to maintain such limitations.
You will be denied use of your 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 Card. 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) according to the rules and regulations of those
account(s) and PSECU's funds availability policies, which are contained in our
disclosure statement required under the Expedited Funds Availability Act
"EFAA'). A copy of this statement has been provided to you or is available upon
equest. You may not deposit any foreign currency. All deposited items are
emoved from the Money Access Center before 3 p.m. each business day.
Electronic Funds Transfer. MAC Agreement and Regulation "E" Disclosure
(continued)
The Pennsylvania State Employees Credit Union reserves the right to verify the
items so deposited before such funds are made. available to you. Hcv;ever, you
may vmhdra:r against the arTIOUn'I deposited up to a ma:.imum of 1,00 percent of
the deposit or S300, s,h:chever is less. When all of the JL;Posited funds become
available, you may vAhcriwi against the entire amount r;eposited up to $300.
You may deliver cash, checks, and other items at most Money Access Centers
located in Pennsylvania, New Jersey and Delaware for transmission to us for
deposit in your account(s). Hot;ever, some Money Access Centers may not
accept such items for deposit and certain other Money Access Centers (nay limit
the amount of funds you deliver for transrnission to PSECU for deposit in your
accounts. You may not deliver sur;h items at Money Access Centers located in
Maryland, New York or West Virginia. if the 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 feflerel Ilse
amount received and advise you of any difference.
RECORD OF TRANSACTION - You will receive a printed receipt al the time of the
transaction for each Money Access Center, PLUS System. or HONOR ATM, 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 the Money
Access Service immediately if you believe your Money Access Card or Personal
Identification Number (PIN) has been lost or stolen. Telephoning PSECU at
(717) 234-8484 in Harrisburg, (800) 237-7328 Nationwide, (717) 777-2100
(TDD) in Harrisburg, (800) 472-1967 (TDD) Nationwide during business hours
or Money Access Service at (800) 222-2781 in Pennsylvania, or (800) 523-4175
in other states 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 the loss, you can lose no more than $50, if
someone used your Money Access Card and Personal
Identification Number (PIN) without your permission.
(h) If you do not contact PSEC I within two business d..^y& afte you
`o'
learn of the loss, and PSECU can prove that it could have
prevented the loss if you had contacted PSECU, you could lose
as 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 after the 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 riot tell or disclose
your PIN to any other person. Do not write your PIN on your Money Access Card.
Do not 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 (TDD),
(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 think your statement or receipt is wrong, or if you need
more information about a transaction listed on the statement or receipt. PSECU
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 name, account number, and Money Access Card number;
(b) Describe the error or the transaction you are unsure about, and
explain as clearly as you can why you believe it is an error or why
you need more information; and
(c) The dollar amount of the suspected error.
If you tell PSECU orally, you must send your complaint or question in wiling
v;ithin 10 business days. PSECU will tell you the results cf the investigation
within 10 business days for Money Access Center, PLUS System or HONOR
?ransactions, 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 90 days for Purchase transactions to investigate your complaint
or question. If PSECU decides to do this, it vAl rocredit 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. You will have the use of the money during the time it takes to
complete the investigaticn. If PSECU does not receive your complaint or
question in writing within 10 business days, PSECU may riot rocredit your
account.
If PSECU decides there is no error, you will be advised within three business
days after the investigation is completed. You may ask for copies of the
documents PSECU used in the investigation. If PSECU credits your account
with funds while investigating an error, you must repay those funds if PSECU
concludes no error has occurred.
DISCLOSURE OF ACCOUNT INFORMATION - PSECU will disclose information
about your account or the transactions you make to third parties:
(a) where it is necessary to complete transactions;
(b) to verify (fie existence and standing of your account with PSECU
upori 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 written permission;
(e) to comply with government or administrative agency summonses,
subpoenas or orders, or court orders; and
(f) on receipt of certification from a Federal agency or department
that a request for information is in compliance with the Right to
Financial Privacy Act of 1978.
PSECU's LIABILITY FOR FAILURE TO COMPLETE AN ELECTRONIC FUND
TRANSFER TRANSACTION - If PSECU fails to complete a transaction on lime or
in the correct amount, when properly instructed by you, PSECU will be liable for
damages caused by our !failure unless:
(a) there are insufficient funds in your account to complete the
transaction through no fault of PSECU;
(b) the funds in your account are uncollected;
(c) 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 overdraft credit;
(e) the Money Access Center, PLUS System or HONOR ATM has
insufficient cash to complete the transaction;
(f) your card has been reported lost or stolen and you are using the
reported card;
(g) PSECU has reason to believe that the transaction requested
is unauthorized;
(h) the failure is due to an equipment breakdown that you knew
about when you started the transaction at the Money Access
Center, PLUS System or HONOR ATM, or Merchant terminal;
(i) the failure was caused by an act of God, fire, or other catastrophe,
or by an electrical or computer failure or by another cause
beyond control;
Q) if you attempt to complete a transaction at a Money Access Center,
PLUS System or HONOR ATM, or Merchant terminal that is not a
permissible transaction listed above; or
(k) the transaction would exceed security limitations on the use of
your Money Access Card.
In any case, PSECU shall only be liable for actual proven damages if the failure
to make the transaction resulted from a bona fide error despite PSECU's
procedures to avoid such errors.
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EXHIBIT " U
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PSE(O 04/22/2009 COPY
D I qqqLIN13
DEBRA L BLOSNICH
1077 LANCASTER BLVD APT 8,
MECHANICSBURG, PA 170554492
Dear DEBRA L BLOSNICH:
Your Charged Off Visa Loan still has a balance of $7,569.35. It is very important that you contact me
immediately.
We are willin to work with you to improve our credit value with its, Please call me at 1-800-237-7328 or
234-8484 (enter 6) ext. 3119 to discuss asuitable payment arrangement.
When your balance is paid in full, we will report it to the credit reporting agencies as a paid charge off.
And, you will be eligible to apply for our member services.
Upon your request, we can refer you to an agency that can help you with your budget and other debt
problems. This is a non-profit agency and the service is free.
Let us help you get back on track.
Sincerely.
Linda Carter
Account Advisor
Pennsylvania State Employees Credit !Onion
Main Address: I Credit Union Place, Harrisburg, PA 17110-2990 - 717.234.8484 •800.237.7328
Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD)
psecu.coan
This credit union is federally insured by the (National Credit Union Administration. Equal Opportunity Lander
NNED
PSEC40
05/2ij2009
Serat via certr rer! & re t rr r ? rl
Certified Rcpt # 8376
?1??d4?l?u'l3
DEBRA L BLOSN[Ct1
1077 LANCASTER BLVD APT 8,
MECHANICSBURG, PA 17055-4492
Dear DEBRA 1, BLOSNICH,
SETTLE, YOUR CREDIT UNION DEIST AND GET A 10% DISCOUNTH
As a Credit Union, we recognize that unexpected occurrences can sometimes result in difficulty meeting financial
obligations. PSECU would like to help you with fulfilling your outstanding obligation with a one-time opportunity to satisfy
your severely delinquent PSUCU Charged Off Visa Loan by establishing a monthly payment agreement.
We can help if you are willing to work with us; however, a decision must be made now as we are on the verge of pursuing
legal remedies to collect your debt.
To assist with your decision, I would like to describe two scenarios:
Allowing us to work with you:
-'.-We will reduce your current Charged Off Visa Loan balance 'tom 7,569.35 to 6,812,42.
-.'-We will stop all interest and late fees from further increasing your obligation.
•3 We will work with you to establish a reasonable monthly payment.
•:•Yonr credit report, which now reflects a charged-off aer_.nunt, will show vnti l,qA, ,r_c;;;newl making n t,nrn;;t°
:This is a one-time offer which is good for 14 days from the date of this letter, a 2
•3If you fail to consistently make the established monthly payment, this agreement will be immediately voided and the
loan will be turned over to our attorney for legal action.
Ignoring this letter and doing nothing could result in the following:
•3 We will forward your file to our attorney or third-party collection agency following 14 days of this letter.
Collection costs of 20% plus additional court costs will be added to your outstanding Charged Off Visa Loan
balance resulting in an increased outstanding obligation.
•3Our attorney will file a judgment against you in Civil Court for the increased amount.
s•Your appearance in court will be requested.
•:•A Lien will be placed on your personal property and be reflected on your credit report for tip to 20 years making it
more difficult to obtain credit in the future including buying a vehicle and buying or selling a house.
•SAny co-applicant on this loan will be negatively impacted in the same way.
:-Your account could be referred to a third-party collection agency for additional collection efforts.
This choice is clearly up to you. Please call me, toll free, at 1-800-237-7328, or locally at 717-234-8484, extension 3119, to
take advantage of this one-time offer.
Sincerely,
Linda Carter
Collector
Member Services
cc:
pennsyrvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD)
psecu.ccm
This credit unbn is federally insured by the National Credit Union Administration. Equal Opportunity Lender
PSc? PENNSYLR STATE
C EMPLOYEES.C;CREDI EDIT UNION
P.O. Box 67013
Harrisburg, PA 17106-7013
ADDRESS SERVICE REQUESTED
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DEBRA L BLOSTIICH
1077 LANCASTER BLVD APT 8,
MECHANICSBURG, PA 17055-4492
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Faid
SCANNED
CERTIFICATE OF SERVICE
I HEREBY gERTIFYthat a true and correct copy of the foregoing Complaint has been
served this 3 day of 2011, by certified mail, return receipt requested,
postage prepaid, upon:
Debra L. Blosnich
Apartment 8
1077 Lancaster Boulevard
Mechanicsburg, PA 17055
BARLEY SNYDER LLC
B
Y•
Shawn M. Long, Esquire
Court I.D. No. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
126 East King Street
Lancaster, PA 17602
(717) 299-5201
3095836_1 .DOCX
Fit FO-OFFICL
gT4
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All 14 Atilt:
x?a???r:t?t~a?al7 cou?iY
f?'?;a?SYLVAtdt A
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
126 East King Street
Lancaster, PA 17602
(717) 299-5201
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
V.
DEBRA L. BLOSNICH,
No. 10-7911
Defendant
PRAECIPE FOR JUDGMENT
Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and
against Defendant, Debra L. Blosnich, for want of an answer.
Assess Damages as Follows:
Debt $7,220.79
Attorneys' fees/collection costs 348.56
Total $7,569.35
Plus statutory post judgment interest at the rate of six percent (6%) per annum continuing after
the date of this judgment, together with costs until paid in full.
3191942.1
Q'A %tiy co (F d 4
ct #, 4x'7610.1
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(X) I certify that the foregoing assessment of damages is for specified amounts alleged to
be due in the complaint and is calculable as a sum certain from the complaint.
( ) Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify
that a copy of this praecipe has been mailed to each other party who has appeared in the action or
to his/her Attorney of Record.
(X) Pursuant to Pa. R.C.P. 237. 1, I certify that written notice of the intention to file this
praecipe was mailed or delivered to the party against whom judgment is to be entered and to
his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the
date of the filing of this praecipe and a copy of the notice is attached.
Date: q 3 - If
BARLEY SNYDER LLC
By:
Shawn Long, Esq. (Id. No. 83774
Matthew Hennesy, Esq. (Id. No. 307020)
Attorneys for Plaintiff
126 East King Street
Lancaster, PA 17602-2893
(717) 299-5201
NOW, H096. , 2011 JUDGMENT IS ENTERED AS ABOVE.
Prothonotary/Clerk, Civil Division
By:
Deputy
3191942.1
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
126 East King Street
Lancaster, PA 17602
(717) 299-5201
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
V.
DEBRA L. BLOSNICH,
No. 10-7911
Defendant
DEFAULT NOTICE
DATE OF NOTICE: March 22, 2011
TO: Debra L. Blosnich
1077 Lancaster Blvd., Apt. 8
Mechanicsburg, PA 17055
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
Respectfully submitted,
Date: ! no c c_A 1? d Qo (1
BARLEY SNYDER LLC
By:
Shawn M. Long, Esquire
Court I.D. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
126 East King Street
Lancaster, PA 17602-2893
717.299.5201
Attorneys for Plaintiff
3168927-1
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Matthew M. Hennesy, Esqui X7608
Barley Snyder LLC ?j
'
126 East King Street
Lancaster, PA 17602 ?. r
One Piece of ordinary mail addressed to: S
Debra L. Blosnich
1077 Lancaster Blvd., Apt. 8
Mechanicsburg, PA 17055
.. %:
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Hasler
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PS Form 3817, January 2001
i?iLL D-0 F I C
RCi ONOTAR
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
Matthew M. Hennesy, Esquire
Court I.D. No. 307020
126 East King Street
Lancaster, PA 17602
(717) 299-5201
2011 APR 14 Aid 11= 53
1;UMBERLAND COUNTY
PENNSYLVANIA
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
V.
DEBRA L. BLOSNICH,
No. 10-7911
Defendant
AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE
MILITARY SERVICE PURSUANT TO "SOLDIERS
AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940
The undersigned, Matthew Hennesy, Esquire, doth depose and say that Debra L.
Blosnich, Defendant, is not in the military service of the United States of America, based on the
following facts: Age of Defendant is unknown; present place of employment is unknown;
present place of residence is unknown.
ADDITIONAL FACTS, if any.
The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S.
§4904, relating to unsworn falsification to authorities.
BARLEY SNYDER LLC
By:
Shawn Long, Esq. (Id. No. 837 4)
Matthew Hennesy, Esq. (Id. No. 307020)
Attorneys for Plaintiff
126 East King Street
Lancaster, PA 17602-2893
(717) 299-5201
3191942.1