Answer:
Whether or not you can hold her liable for the $50 has nothing to do with invalid PIN attempts or consumer cooperation, and everything to do with timing.
The $50 limit on cardholder liability for unauthorized EFTs applies to transactions occurring before the consumer notified you of the theft of her card, if she made the notification within two business days of learning the card had been stolen. The key timing question is: When did the consumer realize her card had been stolen? That date is "Day 0." The next business day (as defined in Regulation E) is "Day 1," and the following business day is "Day 2." If she notified the bank at any time before midnight on "Day 2," she's responsible for up to $50 of any unauthorized transactions made before she notified you.
Your question is unclear as to whether she notified you just a few hours after the two ATM withdrawals, or the ATM withdrawals occurred a few hours after she notified you. If they occurred after her notice to the bank, she's not liable for anything.
First published on BankersOnline.com 5/23/11
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