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Home My WebLink About02-2415WAYPOI NT BANK, successor to Harris Savings Bank IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW VICKiE L. PATTERSON Defendant 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 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 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 LEGA~c. HE~. Date: May 16, 2002 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 / (800) 990-9108 KEEFER WOOD ALLEN & RAHAL, By: ~n~ky, Jr. Attorney I.D7/'/'~23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 C) Attorneys for Plaintiff WAYPOINT BANK, successor to Harris Savings Bank Plaintiff VICKIE L. PATTERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Defendant NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted 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 usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. 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 ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASlSTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 / (800) 990-9108 Date: May 16, 2002 KEEFER WOOD ALLEN & RAHAL, LLP By: ~nsky, Jr. Attorney~. #23702 210 Walnut Street, P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff WAYPOINT BANK, successor to Harris Savings Bank Plaintiff V, VICKIE L. PATTERSON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMPLAINT 1. Plaintiff is Waypoint Bank, successor to Hards Savings Bank, a federal bank, with its principal office at 235 North Second Street, P.O. Box 1711, Harrisburg, Pennsylvania 17105. 2. Defendant Vickie L. Patterson, is an adult individual living and residing at 210 Frytown Road, Carlisle, Pennsylvania 17013. 3. Defendant, as buyer, entered into a Pennsylvania Motor Vehicle Installment Sale Contract with Forbes Chevrolet, Inc. A true and correct copy of the said Pennsylvania Motor Vehicle Installment Sale Contract is attached hereto, made a part hereof and marked Exhibit A. 4. The Contract was subsequently assigned to Plaintiff. 5. Defendant defaulted in her obligations under the Contract, and the Vehicle was repossessed. 6. Subsequently, Plaintiff sold the Vehicle, leaving a deficiency balance owing in the amount of $4,050.32. 7. Despite Plaintiff's repeated demands, Defendant has failed and refused and continue to fail and refuse to pay the current balance owed to Plaintiff under the Contract. WHEREFORE, Plaintiff demands judgment against Defendant in the sum of $4,050.32, together with interest, attorneys' fees and costs of suit. KEEFER WOOD ALLEN & RAHAL. LLP. Date: May 16, 2002 By: 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff -2- The un~e~lgned. L/.2~o, ~./~¢t../.-~ ~ , hereby veriflel and ~t~ ~ (S)He ~ ~ ~P ef Ha~s ~ng= Bank. maina~in; (~)He Is autha~ ~ ~ke ~ls Ve~t~ on i~ be~l~ ~e ~ s~ ~ In ~ ~o~ ~mplaint am ~e and ~ ~ ~ best o1' (her)his knowledge, Information end beilef; 4. (S)~e Is aware ~at False statements herein am rrmde sul~ect to the pen~Ities of 18 Pa. C.S. § 4904, relating to unswom falsification t~ autho~tles. Dated: MAY 14,2002 PERCENTAGE RATE The cost of your credit as a yearty rate. 8.90 % The dollar amount the credit will cost yon. $ 3542.26 The amount of credit provided to you or on your behalf. $ 12987.44 The amount you will have paid after you have made all scheduled payments. 16529.70 The total cost of your purchase on credit, including your downpayment nfs 3000.00 . $ 19529.7O Your Payment Schedule wig be: No. of Payments Amount ot Payments ! When Payments Are Due I Security:purchased. You are giving a security interest in the motor vehicle being 66 $ 250.4~ Monthly, beginning 03/1 1/1 999 I $ N/~ Prepayment: If you pay off early, you will not have to pay a penalty. Filing Fees: $ 5.OO Late Charge: If a payment is late, you will be charged 2% of the porkion of the payment which is late for each month, or part of a month greater than 10 days, that it remains unpaid. See below and amy other Contract documents for any additional information about nonpayment, default, any required repayment in lug before the scheduled date and prepayment refunds and penalties, e means estimate In this Contract we are the SELLER. IF YOU DO NOT MEET YOUR CONTRACT OBLIGATIONS, YOU MAY LOSE THE MOTOR POREES CHEVROLET~ INC, 3400 HARqT. IALR [RIVE CAMP HT.LL PA 17~)lJ/EHICLE AND PROPERTY THAT YOU Name Address Zip Code BOUGHT WITH THiS CONTRACT, AND/OR You are MONEY ON DEPOSIT WITH THE ASSIGNEE. theBUYER(S). VICKIE L PATTERSON 210 FRYTOWN ROAD CARLISLE PA 17013 This Contmct is between sefler and Buyer. AII d~chJsures have been made by Seller. Seller Name(s) Address(es) Zip Code(s)' intends te assign this Contract to the Assignee. If there is more than one Buyer, each promises, separately and together, to pay all sums due us and to perform all agreements in this Contract Itemization of Amount Financed Cash Price $ 14999.00 Cash Downpayment $ 3000.00 Tradedn Value of Trade-in $ N/A Lien Payoff to: $ N/A Unpaid Cash Price Balance $ 11999.00 TO Credit Insurance Company $ .5 To Public Officials for: ~ License, Tags a nd Registration E , $ 43.50 ~ Lien Fee $ 5.00 ~ $ N/A ~ To [XDC FEE ~ $ 40. O0 ~ To _o $ N/A TRADE-IN: You have traded in the following vehicle: Year and Make Description If a balance is still owing on the vehicle you have traded in, the Seller will pay off this amount on your behalL You warrant and represent to us that any trade-th is free from lien, claim, encumbrance or security interest, except as shown in the Itemization of Amount Financed as the "Lien Payoff," PROPERTY INSURANCE: You may choose the person through whom insurance is obtained against loss or damage to the Vehicle and against liability arising out of use or ownership of the Vehicle. in this Contract, you are promising tO insure the Vehicle and keep it insured. CREOIT INSURANCE IS NOT REQUIRED: Cred t L fe Insurance and Credit Disability Insurance are not required to obtain credit, and will not be provided unless you sign below and agree to pay the additional cost(si. Please read the NOTICE OF PROPOSED CREDIT INSURANCE on the reverse side. Your insurance certificate or policy will tell you the MAXIMUM amount of insurance available. All insurance purchased will be for the term of the credit. 8y signing, you select Single Credit Lite Insurance, What is your which costs $ N/A age? Years Signature of Buyer to be insured for Single Credit Lite Insurance By signing, you both select Joint Credit Life Insurance, which costs N/A What are your ages? Signatures of both Buyers th be insured for Joint Credit Life insurance By signing, you select Single Credit Accident & What is your Health Insurance, which costs $ N/A age? Years Signature of Buyer to be insured for Single Credit Accident & Health Insurance By signing, you both select Joint Credit N/~hat are Percentage Accident & Health Insurance, which costs $ '~nur ages? th be insured 1. % 2. % Signatures of both Buyers to be insured for Joint Credit Accident & Health Insurance WAY'POINT BANK, successor to Harris Savings Bank Plaintiff V. VICK~ L. PATTERSON Defendant TO THE PROTHONOTARY: PRAECIPE IN THE COURT OF COMMON PLEAS OF CUMBEKLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No.02-2415 Please mark this action "discontinued". Date: July 1, 2002 KEEFER WOOD ALLEN & RAHAL, LLP Eugene"5. Pepinsky, Jr. Attorney I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff