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HomeMy WebLinkAbout02-3804COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS L DISTR[Cy NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. N~,~OF APPELLANT~ yy / ~'"3 J __ / .~ I MAG. DIST. NO. OR NAME OF D.j' ,~E~ OF ~E~NT ~ ~ ~ ~) Y STATE . ZIP CODE --~,,,~,z, I ~THE CASE ~ ~P~INTIFF) CV YEAR/jy. This block Will be signed ONLY when this notation is require~ under PA. If appellant was Claimant (see :A~ C P ~ P R.C.P.J.P. No. 1008B. . .... This notice of Appeal, when received by the District Justice, will operate as No. I0~1(6)) in action bafora districl ,Justice, he A SUPERSEDEAS to the Judgment for possession in this case. MUST FILE A COMPLAINT within lwenty (2~) days after filing his NOTICE of APPEAL. S~nalufe of Prolhonolary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see PA R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appeUee. PRAEClPE: To Prothonotary Enter rule upon (Common Pleas No. Name of appellee(s) __, appellee(s), to tile a complaint in this appeal ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. RULE: To Name of appellee(s) , appellee(s) Signature of appel/ant or his attorney or agent Date: (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAEClPE. (3) The date of service of this rule if service was by mail is the date of the mailing. White - Prothonotary Copy Green - Court File Copy Yellow - Appelant's Copy Pink Appellee Copy Gold D, J. Copy , Year_ Signature of Prothonotary or Deputy Proth. - 76 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FII. E (~OMi~L~INT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONV~EALTH OF PENNSYLVANIA COUNTY OF AFFIDAVIT: I hereby swear or affirm that I served [] a copy of the Notice of Appeal, Common Pleas No. (date of service) , year ; ss , upon the District Justice designated therein on , [] by personal service []by (certified) (registered) mail, sender's , on receipt attached hereto, and upon the appellee, (name _ _, year ___ , [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. [] and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on , year _, [] by personal s~rvice [] by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS __ DAY OF , YEAR ..... Signature of Affiant Signature of official before whom affidavit was made Title of official My commission expires on _ , year __ COMMONWEALTH OF PENNSYLVANIA · "COUNTY OF: COll~~ 09 - 3 - 05 DJ Name: Hon. ~AY~E &. ~LDRR ~o~: (717) 766-4575 A~y FOR P~ZFF STEV~N C. COURTNEy EsOUIR~ 321! N FRONT STRENT ~OBOX 5300 HARRISBURG, PA 17110 17055 NOTICE OF JUDGMENT/TRANSCRIPT P.O. ~X 5300 L~IBB~G, PA 17XA0-0300 OEFENDANT: VS. NAME an0 ADDRESS 600 ~.~ ~~C~S~G, ~A 17055 7/1 /n2 (Date & Time). Amount of Judgment $_. · 0~ Judgment Costs $-- .0 Interest on Judgment $_ · 0, Attorney Fees $ ,0 Total $ .oq Post Judgment Credits $_ Post Judgment Costs $. ~ Objection to levy has been filed and hearing will be held: Certified Judgment Total $_._________ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ~'NTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRiPT FORM WITH YOUR NOTICE OF APPEAL. c Date ~ertify that th Il i~i _"-T'. _, District Justice [.... ~,~ [I lm [,,, S a true and correct copy of the record of the prOceedings containing the judgment. My commission expires first Monday of January, 2006 AOPC 315-99 SEAL []* This case dismissed without prejudice. ~ Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Levy is stayed for~ _ days or ~ generally stayed. ~ocketNo.: 6/13/02 IDateFiled: CV-0000172-02 THIS IS TO NOTIFY YOU THAT: Judgment: ~-~ Judgment was entered for: (Name) ~ [] Judgment was entered against: (Name) ~ -----'--'--- in the amount of $ - no_ on: (Date of Judgment) [~] Defendants are jointly and severally IJable. - [~ Damages will be assessed on: PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMI~LAINT (This proof of service MUST BE FILED WITHIN~TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA . AFFIDAVIT: I hereby swear or affirm that i served acopy otthe Notice of,~ope~al, Common Pleas No. ~' ~Y , uponthe District Justice designatod therein on ~ (date of se~ice) ~' , y~r _ , ~ b~ p~sonal sewic~y (caVilled),(registered) mail, sender's / / ~ ~,~TJ~- ~ ,on ,~eipt .~h~ereto, and upon the appellee, (name~.[ ~/~" ~ , year_ , ~ by personal se~ice ~ by (c.~ified) (registered) mail, sender's receipt a~ached hereto. / ~ and fu~her that I se~ the Rule to File a Complaint accompanying the above Notice ol Appeal upon the appellee(s) to whom the Rule was address~ on , year ~ by personal s~ice ~ by (ce~ifi~) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SLE~SCRIBED BEFORE ME Title of off, iai ~ My commission expires on , year ~ KIMBERLY A. NALL, Nota~ Pub~ ~ Ci~ of Hamsbu~, Da~hin Cou~ I My C~mission Expires ~anua~ 19, 2~1 · e-~~ ~-~ X,, Signatb(e of Affiant ~:0 Post2ge r--I r~ r-1 Return Receipt Fee (Endorsement Required/ Total postage & Fee - ~ C~Mfrey & Courmey, P.C. BY: Stewm C. C~urmey, E~pdre A~oruey LD. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 Aflom~y for Plain~ PENNSYLVANIA STATE EMPLOYEE CREDIT UNION, Plaintiff MITCWELL G. STEIN, Defendant : IN THE COURT OF COMMOM : PLEAS, CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 02-3804 : : 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 jud~omem 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. 1F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TEI.~PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICIA Le hah demandado a used en la corte. Si used quiere defenderse de estas demandas ~d~uestas en las paginas siguientes, used tiene viente (20) dias de plazo al partir de la fecha de manda y la notification. Used debe presentar una apariencia escrita o cn persona o pot 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 mcdidas y puede entrar una orden conWa used sm 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 ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA ! 7013 717.249.3166 Document #: 180094.1 G~lfrey & Com~ey, P.C. BY: S~evm C. C~ney, Esquire Attorney LD. Nb 746~9 P.O. Box 6280 Harrbburg, PA 17112 (717) A~omey for Plaintiff PENNSYLVANIA STATE EMPLOYEE CREDIT UNION, Plaintiff MITCHELL G. STEIN, Defendant : IN THE COURT OF COMMOM : PLEAS, CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 02-3804 : : CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through/ts attorneys, Steven C. Courtney, Esqu/re and Godfrey & Courtney, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaint/ff; Pennsylvama State Employees Cred/t Un/on, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 1 Cred/t Union Place, Harr/sburg, Dauph/n County, Pennsylvania. 2. Defendant, Mitchell G. Stein, is an adult individual with a last known address of 600 S. Market Street, Mechan/csburg, Cumberland County, Pennsylvania, 17055. Defendant is, and at all relevant times material hereto was, the primary loan applicant. 4. On or about July 2, 1991, Defendant applied to Plaintiff for a personal service loan and a Visa Loan. A true and correct copy of the loan application is attached hereto, incorporated herein and marked as Exhibit "A". Document #: 180094.1 5 Pursuant to the Personal Service 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 (here/nafter referred to as "Contract"). A true and correct copy of the Loanl/ner Credit and Security Agreemem is attached hereto, incorporated herein and marked as Exhibit "B". 6. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms and conditions of the Contract marked as Exhibit ~'B". 7. Various charges and/or purchases were made by Defendant on his personal service loan with Plaintiff. 8. Defendant has not made a payment on account of his personal service loan w/th Plaintiff' since May 10, 2001. A tree and correct copy of a partial statement of account for the personal sent/ce loan is attached hereto, incorporated herein and collectively marked as Exhibit 9. Plaintiffhas maintained a statement of account, marked as Exh/bit "C", keeping an accurate and running mount of debits and credits made on Defendant's account. 10. Plaintiffhas 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 bas 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. 13. As of August 8, 2002, the balance due, owing and unpaid on Defendant's personal Document #: 180094.1 service loan with Plaintiff is the sum of Three Thousand Seven Hundred Ninety-eight and 13/100 Dollars ($3,798.13). 14. Pursuant to the terms and conditions of the extension of credit contained on the loan application, Plaimiff is entitled to receive and Defendant agreed to pay an annual interest charge on the pr/ncipal 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 Godfrey & Courtney, P.C. in the collection of the mounts due and owing by Defendant. 17. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Godfrey & Courmey, P.C. in the collection of the amounts due from Defendant incident to the within action, and Plaintiff shall continue to ineu~ such attorney's fees throughout the conclusion of the procccd/ngs. 18. The amount of attorney's fees incurred in this matter is the sum of Seven Hundred Fifty-n/ne and 63/100 Dollars ($759.63). 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 arbitral/on. WIHr. REFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enterjndgment in favor of Plaintiffand against Defendant, Mitchell Stein, in the amount of Three Thousand Seven Hundred Ninety-eight and 13/100 Document #: 180094.1 Dollars ($3,798.13), plus interest, reasonable attorney's fees in the amount of Seven Hundred Fifty-nine and 63/100 Dollars ($759.63), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, Dated: 8 August 2002 GODFREY & COURTNEY, P.C. By: ~ Steven C."'Co~ourmey~ P.O. BOX 6280 Harrisburg, PA 17112 (717) 540-3900 I.D. # 74669 Attorney for Plaintiff Document It: 180094.1  ,.~,,.;~,,,~, .,,~ PERSONAL SERWCE LOAN APPLICATION 1%11'1~ ~ ~ . ( I~1 IH I I \1~ ~% P~ease comple!e the enclosed Member Census ff you do not have one on hie A Member Censu~ must be on file ~L 0 3 ~ 'or us 1o process your ~pphcallon A ~;~ y~A ' , , , , , , , , , , , , Are ~ ~ the ~ a~ a~e to ~m a ~mal t~r ~ Ou~3/V~ . ~ wish tO reDay this loan by automat,c ly on the 16th "~ S~Tt,-rnOnthly On the ls~ and 1~l :'= ~ly ~ a,ernah~ Fr,Oa~. ~uld prefer a~r pa~nl ~ '/Checking Shares >>> 231381116 <<< ~TATE EMPL~.qYEES CREDIT UNION MBE~ ONE ~,REI')IT tJNiON PLACE ~[ILO 2'gi Loan Disclosures frmY oe useo m te~:l to bonowers in all starer "m~n~e~t to repair Ibe 1. HOWTHIS PLAN WORKS -- This is an open-end, muRi-fsetured c~edit plan. We anlicipate ~at. from time to time. you will Ixxrow nxxtey (called 'advances') under interest rate for each sul~:count expressed as a daily perto~c rote and con'esponding annual percentage rate and ~ charges. It may also have other tm'ms and a schedule fo~ determining ~he payment amours. 2. CREDIT UMIT ~ We maY, Ix~ do nol have to, estab~lsfl a credit limit o~ serlain 4. PLAN ACCESS -- You can obtain credit advances in any n'~nner authorized by uslor- If we allow YO~ to use YOUr ATM/Det~ card to access the plan, you may be ilab~ the unauthorized use of your ATM/Oebit card. You will not be liable for unauthorized use that ocoum alter you notify us, orally or in writing, Of the loss, theft, or ~ unauthorized use. If you believe )'our ATM/Oebit card has been lost or stoke. Immediately inform the Credit Unio~ by calling or wilting us at tbe telelYnOf~ numbor or address that appears elsewhere in '~e Plan. If the card is used to oblain advanca$ dimcitY from the Plsn, your IlabiTrty will not exceed $50. If the ummthorized withdrawal ls from a share draft account, your liablr~y is governed by ~ Regulatlo~ E..d'. -.--'~?fosur~. YOu recelved a( the dme you recalved t~. ATM/De~ ca.~l_ even If ~ ....... the -A~clsf#Jum. If file kllem~t ra~e m a vana~e k.ea,.,~a, ,.h, h "~x~oum ~ how em vadat~ intem~ mte wo~s. or in the future· Property ~,~oudng other loans wi~ us may also secure the Plan. 7. PROPERTY INSURANCE, TAXES AND FF~:~_ __you wiU be required to lx~rchese may PaY these °bliga~s, Ix~ we are not required to do so. Any monay we spend You will PaY interest o~ Itx~e amounts at the seine rate ~ou agre~l to pay o~ the advance. We may recaive payments in coflflec~k~ vath em inmJranca from a · ..,d~, um ,.Rn.~ty IR~rlfl~. ' g. CREDIT INSURANCE -- Credit life and/o~ ~xedit dical~y insurance is optiona{ us t° add the Insurance Pre.alums nxw~hly to ~Ax~r loan beJanca and chapge you may change during the Plan. If the rates change, we NIl p~ovide any notices required by ap¢ical~e law. 10. PERIODIC STATEMENT -- On & regular basis you will receive a statement ~latements and nofioes will be sen! to you at the most recan~ address you have ~*m, en us in writing. Unless applicable law requires no,ice to each joim bonower. 1~o dOINT ACCOUNTS ~ If 6'ds ls - joint ~.mt~ each Of you ls incF~idually and 12. FEES )J~lO CHARGES -- ff y~u give u- a eeoudty imem.t in ~.,~Nn M~es Of ......... you you en 4~We 14.' DEFAULT -- The f~ ~ ..,.m,,. 'to tmm3,we~ /n /daho. default if you fm'l 1o make a payment when due two limes during any 12-month. prondse made under a Secudly Agreement mada in con~ with an advance, ga~a~..~. .. . . . .... mmm ~ ~ ~314~ .~~~~~,~ ~ ~ ~ ............ ~~ ~___._~. . ~)~ ~~ ~. or =~~~.~..m.~m~._. --.v~..o~ .o~c~ *o C~m"~. --'YOU" ~ ~ 7ZY_~-~ "~ ~ ~ ~ ~ ~ __ ~_ ~F~RE ON ~IS N~ M~NS ~AT YOU ARE ~,~ ~ ~ ~ ~ --' ~ ~ k ~ ~ ~ u..uW~ ~ N~ PA~-~E ~DER HAS A ~O~ ff Y°° have auth°rized us to PaY a cm~t card account automatica#y fr(xn yOUr sham YOUR R~HTS ~ OU~ RESPO~Sm..mES ~_WRrl-fEN NOTICE. We must aci~. le..AFTER WE RECEIVE YOUR nave corrected the error hv th=,, t,u-.,4~_~ y~ur ue~'wflhin3Odays, unle~ l~mr MAC cafxf(s) cons~tutes acceptance of ~ terms a~ ~ ~ ~ ~ Y~ ~ ~t ~ ~ a ~<elat~ sew~ and ~u a~e ~E~ ~ ~in a ~ ~ ~ ~ u~m ~ ~ a~uN. 1. A~ and U~ of MO~ ~ CA~ ~-~ ~ ~ ~ ~ ~ M~ ~ ~s) lo . . m ~'<XJ ~' PIN has been k~ ~- ~ ~, ,~__~_,-_'-_--' -'-'-'-' of - --~ s-- "'-- "~ u. ~scrl amertdrlnents or · the MONEY ACCESS CARD aftor ~e effecllve ~; ,.. &-~y soctt amendme~ Stop ~ayment nlghta - Pm-authorked tran~ors MAC a~d SST' - Not apprcable. or change shall cor~lt~e your ace~ntn~-.~ -~ ~ ' ACH - Rlght to Stop P~~~t _ - ~ ~ Summary of the Financial InsUtuflon'e Failure to Make or Stop Certalr& 'r~n~for~ EY ACCESS CARD. be done o, ~he acoou~s a~ by a) Determine ~e account balance(s) of your Chectdng, your Regular Shams. a~d your Personal Servfce Loan (PSL). b) W'~hdraw cash from your Cheddng and your Regular Shares. c) Make a cash advance ~ your Personal Sen4ce Loan (PSL). NOi~-: Deposits am not available through HONOR SYSTEM ATMs. the ~ SYSTEM netwo~ Other- '-'2_'--' '"'~' ~'renay avam~e ~ MAC On/y. From llrne to time, PSECU ma~ make arrangements wRh o~her ATM Notice To Consumem Using AT~ ° If tha ATM hes an e~trY door, dose tha door prior to In~aUng your transactio~ · Put your cash away imrned'mtely. ' ' Direct complaints concerning ATM security to an appropriate department of the owr~r of ~ ATM. New Jm'esY residents: you may call the New jemey For those membem who purchase a vehicle under the , please review the following' FTC Notice: O~IFE _DFpTOR CO[ILl} ASSERT A~Ns'r THE ~OOD$-OR SERVICES OBT.AJNED WrTH THE _PROCEEDS HEREOF. 'RECOVERY HEREUNDER BYTHE ~)EE:.,~RR i~E~REL~i~D(~E~ED(CEED AMOUNTS PAJD BY THE Account 0000017413 STEIN,MITCHELL G 12/31/56 202-46-6103 Accoun'5 Name Birthday Social Sec Home Phone 0~00017413 STEIN,MITCHELL G 12/31/56 202-46-6103 717-671-0819 600 S MARKET ST MECHANICSBURG PA 17055-6416 Date: 08/07/02 Account Type: CHARGE OFF ACCOUNT Account Branch 0000 S 01 OTHER S 02 20% COLLECTION COSTS -1ST L 01 CHARGED-OFF PSL LOAN Relationship Code 00 Due Date Payment Avail/DQ* Balance 0.00 0.00 759.63- 759.63- 03/20/99 100.00 C 3,798.13- 3,798.13 CERTIFICATE OF SERVICE AND NOW, this_~ ~y of /~~ , 2002,1, Steven C. Courtney, Esq., of Godfrey & Courmey, P.C., attomey~ for Plaint/fi, fi~reby certify that I served the foregoing Complaint this day by depositing the same in the United States mail, postage prepaid, in Harrisburg Pennsylvania, addressed to: Mitchell Stein 600 S. Market Street Mechanicsburg, PA 17055 Steven C. Courtney, Esquire Document #.. 180094. PENNSYLVANIA STATE EMPLOYEE CREDIT UNION, Plaintiff MITC1]ELL G. STEIN, Defendant : IN T/IE COURT OF COMMOM : PLEAS, CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 02-3804 : : CIVIL ACTION -LAW PROOF OF SERVICE BY M~II, I, Steven C. Courtney, Esquire, do hereby certify that on August 14, 2002, a copy of the Court of Common Pleas Complaint filed in the above referenced matter was served upon the following person by certified mail, as is evidenced by the signed Certified Mail Return Receipt attached hereto. District Justice Gayle Elder 507 North York St~et Mechanicsburg, PA 17055 Steven C. Co~~squire~--,~ A~tomey I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717) 540-3900 Attorneys for Plaintiff · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Signature [] Agent B...I;leceived by (Printed Name) Cz3~ate.clf Delivery I, V'g i/IS. fll'.llOZ. D. Is deliver~ address ,~ifferent from item 1?I [] ~Yes If YES, enter delivery address below: [] No Ii ' Service Type v~'eertified Mail Express Mail [] [] Registered ~"-Return Receipt for Merchandise [] Insured Mail [] C.O.D. · Restricted Delivery? (Extra Fee) [] Yes Domestic Return Receipt 102595-02-M-1035 (Transfer from service label) PS Form 3811, August 2001 PENNSYLVANIA STATE EMPLOYEE CREDIT UNION, Plaintiff MITCHELL G. STEIN, Defendant : IN THE COURT OF COMMOM : PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3804 : : CIVIL ACTION -LAW PROOF OF SERVICE BY MAIL I, Steven C. Courtney, Esquire, do hereby certify that on August 27, 2002, a copy of the Court of Common Pleas Complaint filed in the above referenced matter was served upon the following person by certified and regular mail. Dated: Mitchell Stein 600 South Main Street Mechanicsburg, PA 17055 GODFREY & COUTRNEY, P.C. Steven C Courtney, squire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717) 540-3900 Attorneys for Plaintiff Document Il: 181832.1