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HomeMy WebLinkAbout14-7201 1 U f Supreme Ca " nnsylvania Couleas For Prothonotary Use Only �Nt A � Docket No:. CUMBERLA - County 176 1 t%rUsl lean` The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefi?ing and service ofpleadings or other pqpers as required by law or rules o court. Commencement of Action: Complaint 13 Writ of Summons © Petition M Transfer from Another Jurisdiction [3 Declaration of flaking Lead Plaintiff's Name:SUSQUEHANNA VALLEY lead Defendant's Name: ANGIE COLLINS FEDERAL CRDIT UNION Dollar Amount Requested: within arbitration limits ?1�1 Are money damages requested? Yes 0 No (check one) ®outside arbitration limits Is this a Class Action Suit? ®Yes eNo Is this an MDJAppeal? [ Yes *No Name of Plaintiff/Appellant's Attorney: STEVEN HOWELL, ESQUIRE ® Check here if you have no attorney(are a Self-Represented [Pro Sel Litigant) 7, Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. Ix TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ® Intentional 0,Buyer Plaintiff Administrative Agencies 13 Malicious ProsecutionDebt Collection:Credit Card ® Board of Assessment Motor Vehicle Debt Collection:Other © Board of Elections ;.' ®Nuisance Dept.of Transportation ® Premises Liability Statutory Appeal:Other sµf b ® Product Liability(does not include :. mass tort) 13 Employment Dispute: ® Slander/Libel/Defamation Discrimination ® Other: 13 Employment Dispute:Other ® Zoning Board z.T' [3 Other: ® Other: ;$ MASS TORT Asbestos u 1`' Tobacco N`$ © Toxic Tort-DES >; ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS s ® Toxic Waste 13 Ejectment ® Common Law/Statutory Arbitration [3 Other: 0 Eminent Domain/Condemnation ®Declaratory Judgment ® Ground Rent C"j Mandamus ® Landlord/Tenant Dispute Non-Domestic Relations ® Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY © Mortg e Foreclosure:Commercial Quo Warranto Dental ® Partition ®Replevin Legal [f Quiet Title ©Other: r. ® Medical ® Other: Y ® Other Professional: Updated 1/1/2011 r c- MCC SUSQUEHANNA VALLEY FEDERAL IN THE COURT OF COMMON ffTA : CREDIT UNION, CUMBERLAND COUNTY �'C n cn a PLAINTIFF PENNSYLVANIA cam, :I-- c-) =r =t': >c V CIVIL ACTION—LAW "' ANGIE COLLINS DEFENDANT NO. I - 'lt��� 1v� NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES,YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PENNSYLVANIA 17013 (717)249-3166 BY: Steven owell,E quire Ho 1 Law Firm 6 Bridge Street �s ew Cumberland PA 17070 Pp (717) 770-1277 6 115.75 Supreme Court ID 62063 C �Iq�l� &314593 SUSQUEHANNA VALLEY FEDERAL THE COURT OF COMMON PLEAS CREDIT UNION, CUMBERLAND COUNTY PLAINTIFF PENNSYLVANIA V CIVIL ACTION—LAW ANGIE COLLINS DEFENDANT NO. COMPLAINT 1. The Plaintiff is the Susquehanna Valley Federal Credit Union with a principal place of business located at 3850 Hartzdale Drive, Camp Hill PA 17011-7809. Plaintiff is a federally chartered nonprofit credit union. 2. The Defendant Angie Collins is an adult individual residing at 42 Patterson Lane, Liverpool, Juniata County,PA 17045-8365. 3. The Defendant is not a current member of the Armed Forces. COUNT I: SVFCU CREDIT CARD 4. On August 6,2009 Defendant executed a Credit Card Application attached as Exhibit"A"with a credit limit of Seven Thousand and 00/100 ($7,000.00) Dollars. 5. Defendant failed to make timely payments. 6. The principal balance due is $7,002.37 plus past due interest at 12.90% with a$2.48 per diem interest charge from December 1, 2014. 7. Defendant has made no regular payments despite repeated requests. 8. Pursuant to the Loan Agreement's Credit Card Account Opening Disclosure the Defendant agrees to pay all"court costs and reasonable attorney's fees"incurred in any collection action., WHEREFORE,Plaintiff respectfully requests entry of judgment in the amount of $7,002.37 (principal plus past interest) at 12.90%interest from December 1,2014 with a per diem of$2.48 together with all court costs and an award of reasonable attorneys' fees. Respectfully submitted, By: Steven ell quir How;TLaw Firm 6 Bridge Street ew Cumberland,PA 17070 (717) 770-1277 Supreme Court ID 62063 12/69/2614 15:55 7177701278 HOWELL LAW FIRM PAGE 02/09 Verification I verify that the statements made in the forgoing document are true and.correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn .falsification to authorities. I verify that I am the President and CTA of the Susquehanna Valley Federal Credit Union and that I am.authorized to execute this document. By: Eric E. Lundvall,President 6d CEO SVFCU Date: 1 ZA Lo ,20 l"( SUSQUEHANNA VALLEY FEDERAL CREDIT UNION 3850 Hartzdale Drive ISA Camp Hill, PA 17011-7809 (717) 737-4152 VISA CLASSIC CREDIT CARD ACCOUNT OPENING DISCLOSURE This Addendum is incorporated into and becomes part of your LOANLINER®Consumer Credit Card Agreement. Please keep this attached to your LOAN LINER®Consumer Credlt,Card,A9.Teement. Ma es a 1 4 es. Annual Percentage Rate(APR)for 12.90% Purchases APR for Balance Transfers 12.90% APR for Cash Advances 12.90% Paying Interest Your due date is at least 25 days after the close of each billing cycle. We will not charge you any interest on purchases and balance transfers if you pay your entire balance by the due date each month.We will begin charging interest on cash advances on the transaction date. For Credit Card Tips from the Consumer To learn more about factors to consider when applying for or Financial Protection Bureau using a credit card, visit the website of the Consumer Financial Protection Bureau at hft :l/www.consumerfiinance. ovllearnmore. i c' INS F. .i Transaction Fees - Foreign Transaction Fee 1.00% -of each multiple currency transaction in U.S. dollars 0.80% of each single currency transaction in U.S. dollars Penalty Fees - Late Payment Fee Up to $25.00 - Returned Payment Fee Up to $30.00 How We Will Calculate Your Balance.We use'a method called "average daily balance (including new purchases)." See your account Agreement for more details. Billing Rights. Information on your rights to dispute transactions and how to exercise those rights is provided in your account Agreement. OTHER DISCLOSURES Late Payment Fee $25.00 or the amount of the required minimum payment, whichever is less, if you are ten (10) or more days late in making a payment. Returned Payment Fee $30.00 or the amount of the required minimum payment,whichever is less. Rush Fee $30.00 Card Capture Fee $65.00 Document Copy Fee $5.00 for sales draft copies Card Replacement Fee $5.00 per card if more than.three (3) are requested in a calendar year Collection Costs. You agree to pay all costs of collecting the amount you owe under this Agreement, including court costs and reasonable attorney's.fees. Periodic Rates. The Purchase APR is 12..90% which is a monthly periodic rate of 1.0750%. The Balance Transfer APR is 12.90% which is a monthly periodic rate of 1.0750%. .The Cash Advance APR is 12.90% which is a monthly periodic rate of. 1.0750%. EXHIBIT 6 ff DRAGW2(MXC452 CCM002}e 8 ®CUNA Mutual Group 2009,10,12 All Rights Reserved m 5--l.i3 . TABULAR DISCLOSURE An ua VISA tClassic ag o ' G w fir, .+ � 2`.90 /° t y at iR VISA Platinum asp. 9.90% Cash Advance VISA Classic. . :. . . . . 12.90% VISA Platinum :. . . . . . . 9.90% �a APRs Balance Transfer VISA Classic. .. . . . . :12.90% VISA Platinum . . . . . . . 9.90% race Pe iod j f 25 Das Y.o"f��Pu�chases,M t ,$ IVlethod�Qf M � Comtrth Average.Daily Balance •, ,, Baance fa (Including New Purchases) ; > t x ` t� Fee.. None zLLJ o I Ell' None Z'j ^ Credit Cards . an C ► Y e J .- Transaction Fee for Purchases. : . . . . . . . None > w of r ` .Are C'e," Lafe Payment:Fee. . . . . . . . . . . $20.00' Z w p Q t CL x 1 y}v If ten (10) or more days late. Q U _ JCC The information about the" costs of the card lJ1 Q Q DCr described in this application is accurate as of Q o =o 't 9/2005: This information may have changed D w CO Q. after that date. To find out what may have U) L." U j changed, contact the credit union. Currently, a 1.0% fee is assessed only on international transactions when a currency conversion occursGet the This fee is unchanged. Credit Union Effective April 4, 2008-, Visa will also impose:a 0.8% fee 06foreign Difference transactions where a`currency conversion is not performed. PUNA Mutual Group,2003. To reorder call t-80435012 2534--+K1 4103 _ - S_ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY O. PEKE 4F "HE ; EXP: 01/14/2015 0 ti Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND }!} . of cituthe,,,fi e OFFICE OF 'THE SHERIFF UT soy. DEC11 8 2014 IATAOIN SHERIFF'S DEPARn Susquehanna Valley Federal Credit Union vs. Collins, Angie Case Number 2014-7201 (Service Details: Category: Manner: Notes: - ' Serve To: J 0 Name: 0a c w J ui Phone: z - Alternate Address: w Phone: a • Name: SERVICE COVER SHEET Civil Action - Complaint & Notice Deputize Expires: 01/14/2015 Zone: Warrant: Primary Address: Angie Collins 42 Patterson Lane Liverpool, PA 17045 DOB: rAHomey/ Originator: 0 N r` 0 N COLLINS, ANGIE [Final Service: Served: Adult In Charge: Relation: Date: Deputy: Personally • ' dult In Charge • Posted • Other 033 Time: Mileage: U4M 5o Steven Howell [ervice Attempts: Date: Time: Mileage: Deputy: Phone: 717-770-1277 Iwo ," : , Pi WAN / i :Notes / Special lnstru • ns: weAA 5 6 trvi' o. (ato 0=° /-0;S lam? o 3 , 4/07.11 ighte # a Now, December 16; 2014 I, Sheriff of Cumberland County, Pefinsylvania do hereby deputize the Sheriff of Juniata County to execute service of the documents herewith and make return thereof according to law. Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 methi Sworn to and subscribed before s-F9day of (c) CountySare Sharif: Teleosoft. h,c nnxRAnderson, Sheriff, '�L L•