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Home My WebLink About01-5353IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff LISA B. WALLOWER, Defendant NO. : : : : _- : .. CIVIL ACTION -LAW NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice is 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 document, or for any other claim or relief requested by the Plaintiff. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~NOTICIA Le han demandado a used en la corte. Si used quiere defenderse de estas demandas expuestas en las paginas siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notificacion. Used debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y puede entrar una orden contra used sin previo aviso o notificacion y pot cualquier queja o alivio que es pedido en la peticion de demanda. Used puede perder dinero o sus propiedades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Document #' 215402.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. LISA B. WALLOWER, Defendant NO. C.3I~ ~,3,.~ CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Steven C. Courtney, Esquire and Metzger, Wickersham, Knauss & Erb, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Lisa B. Wallower, is an adult individual with a last known address of 602-B Ross Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendant is, and at all relevant times material hereto was, the applicant for a Visa Loan with Plaintiff. 4. On or about March 10, 1994, Defendant applied to Plaintiff for a Visa Loan. A true and correct copy of the loan application is attached hereto, incorporated herein and marked as Exhibit "A". Document # 215402.1 5. Pursuant to the loan application marked as Exhibit "A", Defendant agreed to the terms and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (hereinafter referred to as "Contract"). A tree and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 6. The contract marked as Exhibit "B" contains the terms and conditions of the extension of credit agreed to by Defendant. Various charges and/or purchases were made by Defendant on the Visa Loan with Plaintiff. 8. Defendant has not made a payment on account of the Visa Loan with Plaintiff since September 19, 2000. 9. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 10. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 11. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 12. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. Document #: 215402.1 13. As of March 28, 2001, the balance due, owing and unpaid on Defendant's Visa Loan account with Plaintiff is the sum of Eight Thousand One Hundred Twenty-Two and 27/100 Dollars ($8,122.27). 14. Pursuant to the terms and conditions of the extension of credit contained on the loan application, Plaintiff is entitled to receive and Defendant agreed to pay an annual interest charge on the principal loan balance. 15. Pursuant to the terms and conditions of the extension of credit, Defendant agreed to pay reasonable attorney's fees and all court and collection costs. 16. Plaintiff has retained the services of the law firm of Metzger, Wickersham, Knauss & Erb, P.C. in the collection of the amounts due and owing by Defendant. 17. As of the filing of this Complaint, Plaintiff has incurred ~easonable attorney's fees from the law office of Metzger, Wickersham, Knauss & Erb, P.C. in the collection of the amounts due from Defendant incident to the within action, and Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 18. The amount of attorney's fees incurred in this matter is the sum of One Thousand Six Hundred Twenty-Four and 45/100 Dollars ($1,624.45). 19. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 20. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration.. Document ii: 215402 1 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Lisa B. Wallower, in the amount of Eight Thousand One Hundred Twenty-Two and 27/100 Dollars ($8,122.27), plus interest, reasonable attorney's fees in the amount of One Thousand Six Hundred Twenty-Four and 45/100 Dollars ($1,624.45), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, Dated: ~/(~ 2001 /I METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Steven C. Courtne~ 3211 N. Front Street Box 5300 Harrisburg, PA 17110 (717) 238-8187 I.D. # 74669 Attorney for Plaintiff Document#:215402. I VERIFICATION I, Bonnie L. Berkoski, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behaifin th.is matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. 34904 relating to unswom falsification to authorities. Bormie L. Berko~ki " Document #, 180122 1 A "WIN-W/Ar' OFFER FROM PSECb7 You're pre-approved for up to $'10,000 on our 9.9% APR Capitol Card~ VI~A* ! ofP~ECU'. Caplfo! Card ~ISA! W/th our new 0,9% APR rate for purcha~-a nnd our 12.9% APR for ca,ch ~dv:lnce~ and VISA Cbeckg. /herc'g at: Lis~ Wallower 602 Ross Axe # B New Cumberland. Pa 17070 How do j~ou udnP And to make it even heeler, you're l~l~-mppr,t~.ed: · lust toke n minute to fill out and g~ tho she. application {~low and ~'11 ~nd yea a Capitol Card VISA. Your good credi~ hi~to~ ~lews u~ make you t~s ~n-x~n' offer - you;Il ~ceix e o~ 9.9'g, ViSA g~th no annual fee. n ttslness Phone