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Home My WebLink About95-06196 . ,... . '~ -:.:Q u~. A I ,.. . PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, IN 'l'IlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA plaintiff v. CIVIL AC'I'ION - LAW ROBERT SPANGLER, JR., Defendant NO.95-6196 CERTIFICATE OF SATISFACTION TO: Robert Spangler, Jr, You are hereby notified that on , 19_, a praecipe was filed with this Court to mark the above-captioned action satisfied, discontinued and ended. prothonotary Cumberland County, Pennsylvania . , PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA plaintiff , v. NO. 95-6196 ROBERT SPANGLER, JR., Defendant CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: pursuant to Pa. R. civ. P. No. 1037(bl, enter judgment in favor of Pennsylvania State Employees Credit Union, plaintiff, in the above-captioned action, and against Robert Spangler, Jr., Defendant, in the above-captioned action, for failure to file an . Answer to plaintiff's complaint within twenty (20) days from the date of service of said Complaint and assess Plaintiff's damages in the total sum of $11,062.40, plus interest and attorney's fees until Defendant'S obligation is paid in full. I hereby certify that a written Notice of Intention to File this Praecipe for Entry of Default Judgment was given in accordance with Pa. R. civ. P. No. 237.1; a true and correct copy of the aforesaid Notice is attached hereto. . PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 95-6196 ROBERT SPANGLER, JR., Defendant CIVIL ACTION - LAW NOTICE OF ENTRY OF JUDGMENT TOI ROBERT SPANGLER, JR., Defendant You are hereby notified that on Air t, I~ following Judgment has been entered against you n above-captioned case. 1- , 199..2, the the DATE: 11- (1 fj j- , A fendido/a Defendidos/as Por este medio se Ie est a notificando que el de del 199 ,el/la siguiente (Orden), (Decreto), (Fallo) ha Bide anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Protonotario Certifico que la siguiente direccion es la del defendido/a Begun indicada en el certificado de residencial ROBERT SPANGER, JR. 26 EAST SIMPSON STREET MECHANICSBURG, PA 17055-1166 . I hereby certify that the name and address of the proper person(s) to receive this notice under Pa. R. Civ. P. 236 iSI ROBERT SPANGER, JR. 26 EAST SIMPSON STREET MECHANICSBURG, PA 17055-1166 ~ Attorneys for plaintiff r-, f\ . . MAY IE UStD fOR DOUlIlIe ~ND INTlRNAtlONAl MAll. OOE& "01 ....OVIOE fOR INSURANCE. poStMASTIR ",c.',wld From 1 37 IU ., tpUJIl'F. IlUUat PO - 1166, IWltT_mG, ~'-1i4 -rn o ~: ~'~ ll' ~;~ v>} \ : ~t l)~"" , ;""'..' ,_, .- "/l,t, v -':', \ " " ,;. <,~ r,' .', . ~:,~ ..,1\'. I, l:iJJ , ; 'it, C:l 'I In HI (JI i '\ ,,' _ ,.[: .. ,.,...f. One plec. 01 ardin.', m.lI ,dd,..std to _4' SpMI(UII., JR. 26 BMT sDMDt fJI1QZl' -~-_.__.- IIDIN<<CSIIRJ, PA 17055-1166 ------------. -_._---~-'-- 15933-0064 "form 3117. Ma.. 1918 'IJ,IOP,O" ,..-- f\l.f.o-offiCE OF i\if: P\101HON01Nrl 95 rr.c \ 9 rK \II,G Cli~;;r,r.qvffi CQUN1't h NNS'tlWJ.!11\ ,l~~q~_ 1U-~ ~L I). -Itffl- (!,L 5" 7( l- ft.pl- (I!J " I' i;;- \: I " t 1 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW , ROBERT SPANGLER, JR., Defendant NO. q:J-- ~jtl~ (7l:-t4.[" J'-_I-(V'--.. NOTICB TO DBPBND 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 attor- ney and filing in writing with the Court your defenses or objec- tions 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 LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 ::~~u &,7K Brett D. Dav~ Attorney 1.0. No. 62668 100 Pine Street P. O. BOlC 1166 Harrisburg, PA 17108-1166 (717) 232-8000 . ..."'... ~ '"2 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA plaintiff v. CIVIL ACTION - LAW q~'. (,19(, cw.p ;;.,.. ROBERT SPANGLER, JR., Defendant NO. COMPLAINT 1. Plaintiff, Pennsylvania State Employees Credit Union (hereinafter "PSECU"), is a Pennsylvania financial institution with its principal offices located at One Credit Union Place, Harrisburg, Pennsylvania 17110. 2. Defendant, Robert spangler, Jr., is an adult individual whose last known address is P. O. Box 1160, Mechanicsburg, Pennsylvania 17055-1166. 3. On or about August 1B, 19B7, Defendant executed an Application and Note Personal Service Loan Application (the "Loan Agreement"), pursuant to which Defendant could borrow monies in the nature of a revolving loan from PSECU. A true and correct copy of the Loan Agreement is attached hereto and made a part hereof as Exhibit "A". 4. On or about November 23, 19B7, Defendant executed a Visa &: Mac Application (the "Visa/Mac Agreement") for a VISA/MAC account with Plaintiff, pursuant to which Defendant could make purchases and cash advances in the form of an open ended credit line from PSECU. A true and correct copy of the Visa/Mac Agreement is attached hereto and made a part hereof as Exhibit "B". 5. Under the terms of the Visa/Mac Agreement and Loan Agreement (hereinafter collectively referred to as the "Agreements"), the Defendant agreed to pay PSECU "li]n equal installments not less frequently than monthly, with interest on unpaid balances II at a 12.9\ annual rate. 6. Defendant has defaulted on his obligations under the Agreements by failing to make the required monthly payments since April 26, 1994. 7. The total amount remaining due and owing to PSECU by Defendant as pursuant to the Agreements as of October 17, 1995, is Eleven Thousand sixty-Two Dollars and Forty Cents ($11,062.40), which includes principal in the amount of $9,427.01, interest in the amount of $1,525.88 and late fees of $109.51- 8. The Agreements provide that in the event of default, Defendant shall be responsible for the payment of attorney fees and collection costs in an amount equal to twenty (20\) percent of the outstanding loan balance. 9. By correspondence dated June 1, 1995 (the "Demand Letter"), PSECU notified Defendant of his default under the - 2 - Agreements and demanded payment thereunder, but Def~ndant has failed and refused to make payment. A true and correct copy of the Demand Letter is attached hereto, made a part hereof and marked as Exhibit "C". WHEREFORE, PSECU demands judgment against the Defendant in the sum of Eleven Thousand Sixty-Two Dollars and Forty Cents (11,062.40) plus interest, late fees, costs of suit, and attorneys' fees, which amount requires reference to compulsory arbitration. ::N~\) 'J:K Brett D. Davis Attorney I.D. No. 62668 100 Pine Street P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for pennsylvania State Employees Credit Union .3. EXHIBIT "A" , . . .. EXHIBIT "e" ~""""""""""'...~_..,,,,..-,.-..,,...,....,>..,- .; .-vcr 0 1IAOlt, Al.NiIR lIO'rH'ON.JA 1"'C L Mouto&AH M)lKlitl foI CHt'"'" \MUIAM A CHII~" DtoVIDI~t:' MCHAll. A bOC'ROW [LIZAK'H A. DOIJOHIR" HMY(Y'NIDlNIllACI ..IAfoIUL-'''1fI 'lIWotCIII HMI.,j/It .. .II'"" .IAMOUNtAU MICKAlL-O ~ ~\IIDM ..u"'NOP IlRtWtDA v.IUIMQ. JA DC.&.ANO M lAW'l "...., ,-. McNEES, WALLACE & NURICK ATTORNEYS AT LAW ftlCHAAO" lHl'o'lR DAVIOI UHMAN cuot:w MeI~hRt '''''kIllINA follLtI."lR ftOIKR' A "'ILLS Itl""t:NA WClOR( HIRIlR'1t NUAICII JOHkIOT\t:R 'IMO'H'I"l "'11'1" GAIt'I""'''IR 10000000w ItO'H........ 04NA"MNIICADU'o ~1t'D ITltI _HARDW'I'tvtNIOH O&.UIIN'~, DAVlON W"'''I oJR 100 PINt SlR[[T PODOll 1168 HARRISbURG. PA 17108'1168 lruPHo,..t 17111i'JZ6000 r..I7I7123753oo 6<01' ", Gouul ~ "'lCHOlAIOUAA"lUCHIUJ ROBlRf 4 H...... ........,~1\IOJOj ~DI ""'Ut""'N "'1CI~AtUI "'lllt:' f>rIUH .....Ut JAM[11IIl' "Ul1 C-'MILltC MAIIION IHAAOH" ...... 'ON CHUOf<<JH fi'ttAIo4 JONA'HAN H RUllO ..-uc-t,,~u, CAROl A Ifl'HQUJI U....[~Nt t VrAlflRl Dl"""II"lWIUlA~ ,flV(Joi J ,"'NGARII N NLAl' WElt "'~"""NIWl111[ LA'IrR(",cr.. WltDU' GAlli., 'I1NIoIQIrIIrrp., IlirII.UAloI M YOUNG JA or COVIiMI. 'lOUt",.. GItISlM1l0 fI,IoMUH A fK:1'RlCHIiQ.AuSf .JA 1""IiA'Hh DAVtOM BAAIA JQN"'fltAHC IKRftf _HP DAVlI ,JAMU" DV.NGllO .JAMU.. POl.IOt1r"'" ....,HI1.I."... ()uN" Ff06I"'J OOOIJIQ June 1, 1995 via C"~I.I.D aDd .IRB~-CLABB NAIL Robert Spangler, Jr. P.O. Box 1160 Mechanicsburg, PA 17055-1160 ReI PaKl8YLVAKIA 8~ATB IMPLOYB!B CRBDIT UNION v. Robert Spangler, Jr. Our File No. 15933-0064 Dear Mr. Spangler I This office represents pennsrlvania state Employees Credit Union ("PSECU") to which you are ndebted the sum of $10,766.33. PSECU has notified you of your obligation to pay and your payment i. now long past due. Therefore, PSECU insists upon payment in full within the next thirty (30) days. If payment is not made within that time, PSECU shall have no alternative but to institute legal proceedings against you without further notice. All court costs which are incurred in connection with legal proceedings will have to be paid by you and will, accordingly, increase your obligation. Unless you dispute the validity of this debt, or any portion thereof, within thirty (30) days of your receipt of this notice, your debt will be assumed to be valid. If you notify us within that thirty-day period that you dispute the debt, we will obtain and send you a verification of the debt. This letter is for the purpose of collecting a debt. Any information obtained will be used only for collecting the debt. To make arrangements to pay this account, you should contact me directly at the address or phone number noted above. You shall not receive any further notice with respect to this matter. Very truly yours, MCNEES;WALLA;4& ~RI~K By ~ttti. .~j/. / j"Brett D. avis 1~ BDDlbd :.. ..f::,'-. l_o"".' .n"'. *.fIi'1~ _........._"~_"'.;...,.~."""".h.W'''',.F..:'-.':.:';~-<,.''~.- . " VERIFICATION subjeot to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsification to authorities, I hereby certify that I am John Bucher, the Account Advisor of pennsylvania State Employees credit Union, and am authorized to verify this complaint on its behalf, and further, that the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. 41~h.r