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Home My WebLink About94-04727 " " " ~ ~ \ I i I I I i I I i I , '; J. 1,' " " " " , , \ \ \. " , " " " ~ J , ", ,,~ .. ." I' ,,< ".~_~' '.,f} 1_1 , , r ~ ' ' '~', I' ;I' .,' "1 q .j 'II /Ii I, , I " , '-I '~~~~ ~'~"1- ~ -~ ....c:.lS- :3~ ,,"\y ',1 " ' i " "r' , I, MV'I I': ,UNUOUV :JISIl>l 'V HIlH1.U\f - " IN THB COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV IA CIVIL ACTION - LAW NO. PNC BANK, N .A., the successor in interest to UNITBD FEDERAL BANK, PLAINTIFF V JUDITH K. FARNER, DEFENDANT , c P A N T ~, C'~" '~I;"", '" ~,~, .' "~~'. r _. Cj.,..':~ ;;:.~.h "'-.J"\ . \.,!-':. . MIl " ,~i - ,....,1., 'I I' .' o M L I " "i,'" l ARTHUR A. KUSIC ATTORNEY AT LAW 4201 CRUMS MILL ROAD P,O, BoX67015 HARRISBURG. PlNNSYLVANIA 17106.7015 (717) 540-5610 '"' '., " , , I " I ,- liij ~ w ~ -0 lCIlI ~ , , , " PNC BANK, N.A., the successor in interest to UNITED FEDE~~kiR~~~, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA V. CIVIL ACTION - LAW .J NO, 11/- L(1)'l (' ql... e.,l i. ~, JUDITH K. FARNER, Defendant NOTICE You ~lave been sued 1 n court, If you W 1 sh to defend agalnst the clalms set forth in the followlng pages, you must take action wlthin twenty 120) days after thlS Compla1nt and Notlce are served. by entering ,3 wrltten appearance personally or by attorney and flllng 1n wrltlng wlth the court your defenses or objections to the clalms set forth against you. You are warned that 1f you fall to do so, the case may proceed wlthout you and Judgment may be entered aga1nst ',IOU by the court without further notlce for any money cla1med HI the Complalnt for any other clalm or rel1ef requested by the PlaHltlff, You may lose money or propertv or other r 1 ghts 1 mportant t.o you, YOU SHOULIi TM,E THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAwvER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOlv TO FIND OUT WHERE YOU CMI GET LEGAL HELP, Dated: S),r./ Res~)ectftll'IY Stlbm1".ted: -.-- '---- ~;-~)~--'~ (---A~1;t 'R , ~ 3lC, ESQUIRE 4201 Crums Mll 1 Road Post Offlce Bo. 67015 Har r 1 sb J rg, PA , 7112 (717) 54(1-5610 SUPREME COURT MO. 07207 ATTORNEy FOR Pl,AlllTIFf Lawyer Referral Cumberland Co. Court Administrator Fourth Floor 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 '.C BAMK, B.A., the I auaae..or in intere.t to I UMITID rlDlRAL BAMK, I I Plaintiff I I V. I I JUDI1'H K. rUlIlSR I Defendant I IN THIS COURT or COMMOII .LIAS CUIIBIRLAlfD COUNTY, .....IYLVAIlIA CIVIL ACTION - LAW BO. COMPLAINT AND NOW comes Plaintiff by and through its attorney I ARTHUR A. KUSIC, ESQUIRE, and respectfully represents the following: 1. Plaintiff, PNC BANK, N.A., is a national banking association organized and existing under the laws of the United states of America, and maintaining its principal office at 103 Bellevue Parkway, Wilmington, Delaware 19809. 2. Defendant, JUDITH K. FARNER is an adult individual residing at 28 South Washington street, Shippensburg, Cumberland County, Pennsylvania. 3. PNC BANK, N. A. is the successor in interest to United Federal Bank. 4. On or about January 13, 1989, Defendant entered into an Installment Note (hereinafter "Note") with the Plaintiff for a net financing amount and finance charges in the amount of Six Thousand Five Hundred and Forty-Two and 64/100 ($6,542.64) Dollars. A copy of the Note is marked as Exhibit "A", is attached hereto and its contents are incorporated herein by reference. 5. Pursuant to the express terms of the Note, Defendant agreed to pay the monthly amount due under the Note, to wit: One Hundred and Eighty-one and 74/100 ($181.74) Dollars in thirty-six (36) monthly installments, commencing February 13, 19B9 and payable on the same day of each successive month thereafter until the total f inanc1ng amount of $6,542.64 became paid in full in 1992. 6. Defendant has defaulted in her legal obligation to Plaintiff pursuant to the Note, by failing to make the agreed upon payments. As evidence whereof, copies of the Plaintiff's correspondence to Defendant are attached hereto, made a part hereof and marked Exhibit "B". 7. On or about October 17, 1991, Plaintiff at Defendant's request granted an extension of time to make past due payments current by October 2B, 1991. As evidence whereof, a copy of said Extension Agreement is attached hereto, made a part hereof and marked as Exhibit "C". B. Defendant did not abide by the terms of the Extension Agreement. As evidence whereof, copies of the Plaintiff's correspondence to the Defendant are attached hereto, made a part hereof and marked Exhitib "D". 9. Plaintiff has made demands upon Defendant for the balance due, which demands remain unheeded. 10. Under and pursuant to the Installment Note, Defendant agreed that in the event of default she would be responsible reasonable attorney fees which fees are 20% of the deficiency amount. Accordingly, Defendant is repsonsible for attorney's fees in the amount of $420.79. .110 BAMK, II.A., tbe I III THI oouaT or 0011II011 .L1lA8 .uooe..or 1n intere.t to I OUKBIRLAlfD OOUIITY, .11lIf8YLVAIIIA UJrITID rlDIRAL BAlli, I I 'laintiff I I V. I CIVIL ACTIOII - LAW I JUDITH I. rUlla I 110. I Defendant I VIlRII'IOATIOH I, J1/a.r~<(e-rffe. F (;/bs~ ~ ( ( 041 '5 I statements made in Complaint are true and correct and that I am , the 'Re~()te,yy " of PNC BANK. N.A. ver ify that the authorized to make this Verification on behalf of PNC BANK, N.A. I understand that false statements herein are subject to the penalties of 18 Pa, C. S. section 4904, relating to unsworn falsification to authorities. PNC BANK, N.A. By: PeCo</~ .sit g/~'1 '. \ " " " RXBIBI'I' .0' . '.0. loa 111 Swe CoU'I..'A 1610&.41179 November 19, 1991 Judith K. Farner 28 S. Washington Strset Shippensburg, PA 17257 RE: IL02000041729 Dear Ms. Farner: The installment loan account is past due the August through Novemb~r pay- ments. The amount owed to pay the loan current is $726.96. The bank is requesting that you either pay the loan current or pay the balance in full. The bank will no longer tolerate the serious delinquenc> problem in regard to this loan. Upon receipt of this letter visit our Shippensburg office in order to pay the loan current. If you have any questions please call me at (814) 231-1617. Sincerely yours, UNITED FEDERAL 8ANK ~ ' .!JI tt./': '- C;'rJ,':i'~' BRUCE CHILCOTE COLLECTIONS MANAGER "N FDIC INSURED S"VINGS ."NK . P_O. 8011 179 SlAW Call'I', p" 1681)40(1119 January 10. 1992 Judith K. Farner 28 S. Washington Street Shippensburg, PA 17257 RE: IL #2000041729 Dear Ms. Farner: Tho installment loan is past due the August 1991 through December 1991 payments, The total amount owed including late charges is $913.70. The bank expects that the account be paid current at once. If not, the bank will proceed with legal action against you in order to collect the monies owed us. If you have any questions please call me st 1-800-258-7283. Sincerely yours, UNITED FEDERAL BANK .B~u.:.: c.Mtt., BRUCE CHILCOTE COLLECTIONS MANAGER A:-; FDIC I:-;SUREO S,\VI:-;c;S BA~I( a-- Umted Federal JWI."K P,o. 8". 179 Stall C~II'I" PA 1611)404)179 , October 4, 1991 Judith K. Farner 28 S. Waehington Street Shippensburg, PA 17257 RE: IL#2000041729 Dear Ms. Farner: The installment loan account is past due $941.64. The payments for May through September are past due. Late charges of $32.94 are also owed. T~e loan ~usc be ?aid c~.rant at once. The bank will consider legal ac- tion if deemed necessary in the collection of this account. Upon receipt of this letter visit our Shippensburg office and pay the loan current. If you have any problems please call me at 1-800-258-7283. Sincerely yours, UNITED FEDERAL BANK - 6uttli cU..,i BRUCE CHILCOTE COLLECTIONS MANAGER All FDIC IIlSURED SAVIIlGS BA:'lK " , '" ~~ . ~~c , E ~I'..') ~l.. , 1~'a~;Jt ~ ..'ou.... ,~ :r:'l"" \-.. ~, '-) ~~ l- M :- ,.,J....." ;~) ,,! ... .z l"~ ,;:;: Z en "('~~~;l~ 141.1u" '"", ~ b~') , ,