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Home My WebLink About13-1145F.\FI[,ESlClients\11470 MemberslstU 1470 Curren[\11470.249 Sine\I1470.249.complaint.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 R. Christopher VanLandingham, Esquire Attorney I.D. No. 307424 MARTSON DEARDORFF WILLIAMS OTTO GILROY MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff L' .. I1~L }}i4t"~~5111 is`J ~~f1 ~f ^' i ~ M ~: ~? -1 Pry 3 ~ 12 ~d a3.iv`sF i~l..r~Fl+:l lrULl!\ { l ~'~:FINSYLV~F~1~'~ & FALLER MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. TODD M. STINE, IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 2013- f I't/~ NOTICE CIVIL TERM 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 aze served, by entering a written appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD A LAWYER Contact: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Defendant S $/03.75` cL~~~~ CK~ .2G'Y'Y l ~as7~of NOTICE REQUIRED UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601 (AS AMENDED) AND THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT AND CONSUMER PROTECTION LAW, 73 PA. CON. STAT. ANN. §201, ET SEQ. ("THE ACTS") To the extent the Acts may apply, please be advised of the following: The amount of the original debt is stated in the Complaint attached hereto. 2. The Plaintiff who is named in the attached Complaint is a Creditor to whom the debt is owed. The Creditor's law firm, Martson Deardorff Williams Otto Gilroy & Faller, is filing this Complaint on behalf of the Creditor. 3. The debt described in the Complaint attached hereto and evidenced by the copies of the note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within thirty (30) days after receipt of this notice, disputes the validity of the debt or some portion thereof. 4. If the Debtor(s) notifies the Creditor's law firm within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the Creditor's law firm will obtain verification of the debt and a copy of the verification will be mailed to the Debtor(s) by the Creditor's law firm. 5. If the Creditor who is named as Plaintiff in the attached Complaint is not the original Creditor, and if the Debtor(s) makes a request to the Creditor's law firm within thirty days from the receipt of this notice, the name and address of the original Creditor will be mailed to the Debtor(s) by the Creditor's law firm. 6. Requests can be made to: MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER Attn: Christopher E. Rice, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 THIS DOCUMENT MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT FOR THE PLAINTIFF AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. F:~FILES\ClientsU 1470 Memberslst\11470 CurrentV 1470.249 StineU 1470.249.complaint.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 R. Christopher VanLandingham, Esquire Attorney I.D. No. 307424 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. TODD M. STINE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2013- CIVIL TERM COMPLAINT AND NOW, comes the Plaintiff, MEMBERS 1St FEDERAL CREDIT UNION, by and through its attorneys, MARTSON LAW OFFICES, and files this Complaint upon the following: 1. Plaintiff, Members 1St Federal Credit Union ("Plaintiff'), is a federally chartered credit union located at 5000 Louise Drive, Mechanicsburg, Pennsylvania 17055. 2. Defendant, Todd M. Stine ("Defendant"), is an adult individual residing at 15 Courtyard Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. On or about January 14, 2012, Defendant executed a loan and security agreement ("Agreement") with Plaintiff in the amount of $22,327.88. A true and correct copy of the Agreement is attached hereto as Exhibit "A" and is incorporated herein by reference. 4. Defendant has failed to make the minimum required payments when due and is therefore in default under the Agreement. 5. Per the terms of the Agreement, when a default occurs Plaintiff may require Defendant to pay all amounts then due and owing. 6. Plaintiff has made demand for payment of all sums due and owing thereunder, but payment has been refused. Defendant 7. The total sum due and owing from Defendant under the Agreement, as of February 7. The total sum due and owing from Defendant under the Agreement, as of February 22, 2013, is itemized as follows: Principal: $20,572.47 Interest as of February 22, 2013: $1,412.74 Court Costs: $500.00* Attorney fees: $2,000.00 Total as of February 22, 2013: $24,485.21 Plus interest accruing at a rate of $6.27 per day from February 22, 2013, until paid in full. *To be determined by the Cumberland County Sheriff. 8. Plaintiff specifically reserves the right to increase the Court Costs and Fees, and Attorney Fees listed above should additional services be requested and/or costs/charges/fees be incurred as a result of the collection of the money owed. WHEREFORE, Plaintiff demands j udgment against Defendant under the Agreement in the amount of $24,485.21, plus interest at a rate of $6.27 per day from February 22, 2013 and any additional late fees and court costs incurred. MARTSON LAW OFFICES ~_ By: ~ --_ Christopher E. Rice, Esquire I.D. No. 90916 R. Christopher VanLandingham, Esquire I.D. No. 307424 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: ;3 / , 2013 Attorneys for Plaintiff This is a debt collecting firm for Members ls` Federal Credit Union. Any information obtained will be used for that purpose. EXHIBIT "A" s N fi~ ~ ~ ~ g ~~ ~ s ~. R ~8 S •~ ! yw~ ~ ~ 3 ~g ~~~ ~ s ~ ~- ~ ~ ~ Q o ~ ~ ~ ~ O ~ ~ v i j ' .. a s ~~ eeoooooooo~e ~MM MMI~~~f~MM Z C ~oooo~ooo°a w w Y 1 ~ s i~ ~ ~ w ~ ; ~ ~~~~~~~~~ ~~ ~~~~ $ n1 ~ Q ~ ~ ; ~ ~ 1 € ~~~ ~~ ~~ t~! ~ ~ ~ ~~~~ ~~ ~ ~ ~ i m ~ ~ g ~ ~ ~~t ~~ ~ ~c a ~ 3 ~ _ s ~ ~ ~ s _ ~~ ~ ~ 3 ~ fpil ~„ M ~~ ~ ~ ~ ~ ~ t~ r ~ ° ¢ ~~ ~ ~ i aR` ~ ~; ; ~~ ~ i w ~ ~ a ~ ~ ~ ~ a ~_ ~ #~ -~ M ~} _; ~ ~~ ~"' 0 v sp ~~ O ~I w 1 II f i g j ~ d ~j S s g r d VERIFICATION I, Q,~~t ~ a.~e ~I.~n-S, as an employee of Members 1 S` Federal Credit Union, acknowledge I have the authority to execute this Verification on behalf of Members 1~` Federal Credit Union and certify that the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of this document is that of counsel and not my own. I have read the document and to the extent the Complaint is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent the content of the Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. MEMBERS 1ST FEDERAL CREDIT UNION Y F:~FR.ES1CIimISU 1470 Membenist~l 1410 Curtem\11470.119 SlineU 1470.249.tomplaint.wpd SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r IL D-OFFi Sheriff Ulu THE PROTHO}X fAt`,,'i Jody S Smith Chief Deputy , . >} 2013 MAR 26 AM 9: 35 Richard W Stewart CUMBERLAND CGUNTY Solicitor OfFiCE OP THE SHERIFF RNWJ 1 LVA91 A Members 1st Federal Credit Union Case Number vs. Todd Matthew Stine 2013-1145 SHERIFF'S RETURN OF SERVICE 03/20/2013 01:50 PM-Sergeant Jason Vioral served the requested Complaint&Notice by"personally" handing a true copy to a person representing themselves to be the Defendant,to wit: Todd Matthew Stine at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013. JAS VIO L, DEPUTY SHERIFF COST: $40.46 0 SWERS, March 20, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff.Teleosof, Inc. t