HomeMy WebLinkAbout07-1113NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V
ANDREW FUNK,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. is `7 - 1lt 3
l U l 1, ?y1/'1
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
IMPORTANT RIGHTS.
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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
By:
well Law Firm
19 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
NEW CUMBERLAND FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION, CUMBERLAND COUNTY,
PLAINTIFF PENNSYLVANIA
V. CIVIL ACTION - LAW
ANDREW FUNK, _
DEFENDANT NO.
COMPLAINT
1. The Plaintiff is the New Cumberland Federal Credit Union with a principal place of
business located at 345 Lewisberry Road, New Cumberland, York County,
Pennsylvania 17070. Plaintiff is a federally chartered non profit credit union.
2. The Defendant Andrew Funk is an adult individual residing at 4 West Dulles Drive,
Camp Hill, Cumberland County, Pennsylvania 17011. The Defendant is not a current
member of the Armed Forces
COUNT I: 2003 PROMISSORY NOTE
3. On April 28, 2003 Defendant executed a Promissory Note attached as Exhibit "A" in
the amount of Eighteen Thousand Sixty Eight and 90/100 ($18,068.90) Dollars at
4.990% interest. Defendant was the borrower under this Promissory Note.
4. The terms of Exhibit "A" required timely payments of $157.42 bi-weekly for 129
payments and a final payment of $149.73.
5. Defendant failed to make timely payments and the vehicle securing the Promissory
Note was repossessed and sold.
6. The Promissory Note was secured by a 2000 Toyota Celica (VIN JTDD
Y32T3Y0004977) which was repossessed and sold at auction in February 2007 with
net proceeds of $2,077.00 received by Plaintiff.
7. The outstanding principal balance owed following receipt of $2,077.00 from the auto
auction as of February 26, 2007 is $5,058.94 with a per diem of $0.69.
8. Pursuant to each Promissory Note the Defendants agreed to pay all "court costs and
reasonable attorney fees" incurred in any collection action.
WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount
of $5,058.94 at 4.99% interest from February 26, 2007 and a per diem of $0.69 together
with all court costs and an award of reasonable attorneys' fees.
COUNT II: 2005 PROMISSORY NOTE
9. On September 8, 2005 Defendant executed a Promissory Note attached as Exhibit
"B" in the amount of Seven Thousand Seventy Eight and 37/100 ($7,078.37) Dollars
at 14.90% interest. Defendant was the borrower under this Promissory Note.
10. The terms of Exhibit "B" required timely payments of $112.84 bi-weekly for 77
payments and a final payment of $106.29.
11. Defendant failed to make timely payments.
12. Pursuant to each Promissory Note the Defendants agreed to pay all "court costs and
reasonable attorney fees" incurred in any collection action.
13. The outstanding principal balance owed as of February 26, 2007 is $4,042.61 with a
per diem of $1.62.
WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount
of $4,042.61 at 14.90% interest from February 26, 2007 and a per diem of $1.62 together
with all court costs and an award of reasonable attorneys' fees.
COUNT III: VISA CREDIT CARD
14. On September 2, 2004 Defendant executed a credit card application which is
attached as Exhibit "C".
15. Defendant's account is subject to the terms and conditions set forth in Exhibit "C"
which is a true and correct copy of the Visa Credit Card Agreement.
16. Defendant has been late numerous times in paying his minimum payment due on
the credit card with $541.41 past due as of February 5, 2007.
17. Defendant's outstanding balance is $541.41 accruing interest at 12.90% annual
percentage rate (APR) as of February 5, 2007.
18. Pursuant to the Visa Credit Card Agreement the Defendants agreed to pay "20%
collection expenses including court costs and attorney's fees" as set forth in Paragraph 6
of Exhibit "C". This amount totals an additional claim for $108.28.
WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount
of $649.69 (principal plus past interest and collection costs) at 12.90% interest from
February 5, 2007 and a per diem of $0.23 together with all court costs.
Respectfully submi
By:
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
55 717770127e HOWELL LAW FIRM PAGE 02?' ?
Verification
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.. C.S.A.
Section 4904 relating to unswom falsification to authorities. I verily that I am the
President of the New Cumberland Federal Credit Union and that I am authorized to
execute this document.
.BY: _
tD?onald?Vamer, Pr ent
NCFCU
Date: a Ja 4 /a?
NEW CUMBERLAND FEDERAL CREDIT UNION
P.O. Box 658 - New Cumberland, PA 17070-0658
(717) 774-4633 - 1-800.716-2328
LOAN AND SECURITY AGREEMENTS
AND DISCLOSURE STATEMENT
LOAN/f)AT?2 003 N NUMBER AC66UNT NUMBER GROUP POLICY NUMBER MATURITY DATE
04 Gt3 2 tf1514 037-0619-4
BORROWER 1 BORROWER 2
NAME AND ADDRESS NAME AND ADDRESS IF DIFFERENT FROM BORROWER 11
ANDREW FUNK
606 STATE ST.
LEMOYNE PA 17043
TRUTH IN LENDING _D1SCLOSURf 'e' means a- estimate
ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price
The cost of your credit as a yearly rate. The dollar amount the The amount of credit The amount you will have The total cost of your purchase on credit is
credit will cost you
provided to you or on
i
f
.
pa
d a
ter you have made $
your behalf. all payments as scheduled.
4 . 990 % $ 2,388.01 e S 18,068.90 $ 20, 456.91 a which includes your
downpayment of $
Your Payment Schedule Will Be:
Prepayment: If you pay off early you will not have to
Number of Payments Amount of Payments When Payments Are Due pay a penalty.
129 $ 157.42 EI-WEEKLY 05/23/2003 Required Deposit: The Annual Percentage Rate does
AND 1 $ 149.73 a not take into account your required deposit, if any.
Pro ertInsurance: You may obtain
p y y property insurance from anyone you El Assumption: Someone buying your mobile home
want that is acceptable to the credit union. If you get the insurance from us, cannot assume the remainder of the loan on the
original terms
you will pays N/A .
Demand: E] This obligation has a de
d f
Late Charge: man
eature.
? All disclosures are based on an assumed
maturity of one year.
THIS CREDIT UNI
ON DOES NOT ASSESS LATE CHARGES Filin
Fees
g
Non-Filing Insurance
$
0.00 $
/A
?
S
ecurity: Collateral securing other loans with the credit union may also secure this loan. You are giving a security interest in your
shares and dividends and, if any, your deposits and interest in the credit union; and the property described below:
Collateral Property/Model Year I.D. Number Type Value Key Number
Celica Toyota 2000 JTDDY32T3Y0004977 $ _
17j? •LC'
.00
$ 0.00
A
Other (Describe) 0.00
` 0.00
Pledge of Shares $ 0.00 in Account No. $ 0.00 in Account No.
See your contract documents for any additional information about nonpayment, default, and any required repayment in full before the
scheduled date.
SIGNATURES
CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT. By signing as
Borrower, you agree to the terms of the Loan Agreement. If property is described in the "Security" section of the Truth in
Lending Disclosure, you also agree to the terms of the Security Agreement. If you sign as "Owner of Property" you agree
only to the terms of the Security Agreement.
BORROWER I (OWNER OF PROPERTY F1 WITNESS
(SEAL) !3 ? M-11 X
(SEAL)
DATE BORRO ER2 DATE
(SEAL)
11 X 21w_ d (SEAL)
DATE [-I OTHER BORRO ? WN OF PROPERTY WITNESS DATE
G EXHIBIT
G
z
m
0 CUNA MUTUAL GROUP, 1999, 2000, 2001, ALL RIGHTS RESERVED NXX022 (LASER)
Credit Union New Cuunberland Federal Credit Union
BGrrdWer(s) ANDREW FUNK
ITEMIZATION OF THE A
Itemization of Amount Financed of Amount Given to You Directly
_ $ 18,068.90 $ n nn
unts Paid to Others on Your Behalf: Of an amount is -m
$ 17,968.90 To ANDREW FUNK AND
$ 0.00 To
$ 0.00 To
$ To
$ To
$ To
$ To
Loan No. Acct. No.
L# 2 081514
Amount Paid on Your Account
$ 0.00
an asterisk (') we will be retaining a portion
$ 100.00 To NCFCU
$ 0.00 To
$ 0.00 To
$ To
$ To
$ To
$ To
amount.)
LOAN AGREEMlEW
In this Loan Agreement ("Agreement") all references to "Credit Union," "we," "our," or "us," mean the Credit Union whose name
appears above and anyone to whom the Credit Union assigns or transfers this Agreement. All references to "you," or "your" mean each
person who signs this Agreement as a borrower.
1. PROMISE TO PAY -
You promise to pay $18,068.9fb the Credit Union plus interest on the unpaid balance until what you owe has been repaid. For fixed
rate Loans the interest rate is 4.990 % per year.
Collection Costs:
You promise to pay all costs of collecting the amount you owe under this agreement including court costs and reasonable attorney
fees.
2. PAYMENTS - You promise to make Layments of the
amount and at the time shown in the Truth in Lendingg
yDisclosure. You may prepay any amount without penalty. rf
to make theareguularly s what you payments unlesslwe have
agreed to a change in the payment schedule. Because this
is a simple interest loan, if you do not make payments
exactly as scheduled, our final payment may be more or
less than the amount of the final payment that is disclosed.
If you elect credit insurance, we will either include the
premium in your payments or extend the term of your loan.
If the term is extended you will be required to make
additional payments of the scheduled amount, until what
yyou owe has been paid. You promise to make all payments
to the place we choose. If this loan refinances another loan
we have with you, the other loan will be canceled and
refinanced as of the date of this loan.
3. LOAN PROCEEDS BY MAIL - If the proceeds of this loan
are mailed to you, interest on this loan begins on the date
the loan proceeds are mailed to you.
4. SECURITY FOR LOAN - This Agreement is secured by all
property described in the "Security," section of the Truth in
Lending Disclosure. Property securing other loans you have
with us also secures this loan, unless the property is a
dwellingq A dwelling secures this loan only if it is described
in the '?5ecurity' section of the Truth in Lending Disclosure
for this loan. /f Credit Union has a federal charter: Statutory
Lien - If you.are in default on a financial obligation to us,
federal law give us the right to apply the balance of shares
and dividends in all individual and 1joint accounts you have
with us to satisfy that obligation. After you are in default,
we may exercise this ri ht without further notice to you.
jWe have a federal char er if our name includes the term
Federal Credit Union.") if Credit Union has a state charter,
except in Ohio and Rhode Island: We have a statutory lien
on tie shares and dividends and, if any, the deposits and
interest in all individual and [joint accounts you have with us
and may exercise our rights under the lien to the extent
permitted by state law. (We have a state charter if our
name does not include the term Federal Credit Union.")
For all borrowers: You pledge as security for this loan al
shares and dividends and, if any, all deposits and interest in
all joint and individual accounts you have with the credit
union now and in the future. The statutory lien and/or your
pledge will allow us to apply the funds in, your account(s)
to wat you owe when you are in defaut. The statutory
lien and your pledge do not apply to any Individual
Retirement Account or any other account that would lose
special tax treatment under state or federal law if given as
securit
5. DEFAULT - You will be in default under this Agreement if
you do not make a payment of the amount required on or
® CUNA MUTUAL GROUP, 1999, 2000, 2001, ALL RIGHTS RESERVED
before the date it is due. You will be in default if you break
any promise you made in connection with this loan or if
anyone is in default under any security agreement made in
connection with this Agreement. You will be in default if you
die, file for bankruptcy, become insolvent (that is unable to
pay our bills and loans as they become due), or if you made
any
YoTalse or misleading statements in your loan application.
u will also be in default if something happens that we
believe may seriously affect your ability, to repay what you
owe under this Agreement or if you are in defaul under any
other loan a reement ?rou have with us.
6. ACTIONFAFTER DEFAULT - When you are in default, we
may demand immediate payment OT the entire unpaid
balance under this Agreement. You waive any n ht you have
to receive demand for payment, notice of inten? to demand
immediate payment and notice of demand for immediate
payment. If we demand immediate payment you will
continue to pay interest at the rate provided for in this
Agreement, until what you owe has been repaid. We will
also apply against what you owe any shares and/or deposits
given, as security under this Agreement. We may also
exercise any other rights given 6y law when you are in
default.
7. EACH PERSON RESPONSIBLE - Each person who signs
this Agreement will be individually and jointly responsible for
paying the entire amount owed under this Agreement. This
means we can enforce our rights against any one of you
individually or against all of you together.
8. LATE CHARGE - If you are late in making a payment, you
romise to pay the late charge shown in the Truth in Lending
Disclosure. If no late charge is shown, you will not be
charged one.
9. DELAY IN ENFORCING RIGHTS - We can delay enforcing
any of our rights under this Agreement any number of times
without losing the ability to exercise our rights later. We can
enforce this Agreement against your heirs or legal
representatives.
10. CONTINUED EFFECTIVENESS - If any part of this
Agreement is determined by a court to be unenforceable, the
rest will remain in effect.
11. NOTICES - Notices will be sent to you at the most
recent address you have given us in writing. Notice to any
one of you will be notice to all.
12. OTHER PROVISIONS -
NXX022 (LASER)
Prepaid Finance Charge
- $ n nn
NBW CU BW AND FEDERAL CBBDIT UNION
P. O. Banc 658 • New Cumberland, PA 17070-0658
(717) 774-4633 9 1-800-716-2328
MNUM.
CG)
LOAN AND SECURITY AGREEMENTS
- AND DISCLOSURE STATEMENT
LW/WA2005 LLiF? 8 #N NUMBER AC?OU?T N1 14UMBER GROUP POLICY NUMBER MATURITY DATE
U y (J ?3 037-0619-4
BORROWER') BORROWER 2
NAME AND ADDRESS NAME (AND ADDRESS IF DIFFERENT FROM BORROWER 11
ANDREW FUNK
417 HERMAN AVE
LEMOYNE PA 17043
TRUTH'1N LENDING D SCLOSUFtE 'e' means an estimate
ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price
The cost of your credit as a yearly rate. The dollar amount the The amount of credit The amount you will have The total cost of your purchase on credit is
credit will cost you. provided to you or on paid after you have made $
your behalf. all payments as scheduled.
794.97 a which includes your
14 . 900 % $ 1,716.60 e $ 7,078.37 $ 8
,
downpayment of $
Your Payment Schedule Will Be: Prepayment: If you pay off early you will not have to
Number of Payments Amount of Payments When Payments Are Due pay a penalty.
77 $ 112.84 BI-WEEKLY 09/23/2005 Required Deposit: The Annual Percentage Rate does
AND 1 $ 106.29 e not take into account your required deposit, if any.
?
Pro ertInsurance: You may obtain
p y y property insurance from anyone you Assumption: Someone buying your mobile home
want that is acceptable to the credit union. If you get the insurance from us, cannot assume the remainder of the loan on the
original terms.
you will pay$ N/A
Demand: E] This obligation has a demand feature
Late Charge: .
? All disclosures are based on an assumed
maturity of one year.
THIS CREDIT UNION DOES NOT ASSESS LATE CHARGES Filing Fees Non-Filing Insurance
$ $ 0.00
N/A
Security: Collateral securing other loans with the credit union may also secure this loan. You are givin
g a security interest in your
shares and dividends and, if any, your deposits and interest in the credit union; and the property described below:
Collateral Property/Model Year I.D. Number Type Value Key Number
$ 0.00
$ 0.00
$ 0.00
Other (Describe) 0.00 0.00
Pledge of Shares $ 0.00 in Account No. $ 0.00 in Account No.
See your contract documents for any additional information about nonpayment, default, and any required repayment in full before the
scheduled date.
I SIGNATURES -I
CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT. By signing as
Borrower, you agree to the terms of the Loan Agreement. If property is described in the "Security" section of the Truth in
Lending Disclosure, you also agree to the terms of the Security Agreement. If you sign as "Owner of Property" you agree
only to the terms of the Security Agreement.
Fv (SEAL) X (SEAL)
VBO OWER 1 DATE BORRO ER 2 DATE
X (SEAL) X ?_ c (SEAL) ," F
OTHER BORROWER OWNER OF PROPERTY E] WITNESS DATE ? OTHER BORROWER - I] 0 ER OF PROPERTY ITNESS DATE
EXHIBIT
? t3
m
0 CUNA MUTUAL GROUP, 1999, 2000, 2001, ALL RIGHTS RESERVED NXX022 (LASER)
CreditUri& New Cumberland Federal Credit Union
BorroVerlq) ANDREW FUNK
Itemization of Amount Financed of
$ 7.078.37
mounts
$
$
Loan No.
Acct. No.
L# 5 081514
AUNT FINANCED
Amount Paid on Your Account Prepaid Finance Charge
$ 0.00 $ n nn
1.. marKea w:tn an asterisk ('*) we will 1
2,458.52 To 600
2,540.99 To UNION PLUS $ 2,078.86 To
0.00 To CREDIT CARD 0. 0 0 To
To $ 0.00 To
To $ To
To $ To
To $ To
$ To
retaining a portion of the amount.)
CAPITAL ONE BANK
In this Loan Agreement ("Agreement") all references to "Credit Union," "we," "our," or "us," mean the Credit Union whose name
appears above and anyone to whom the Credit Union assigns or transfers this Agreement. All references to "you," or "your" mean each
person who signs this Agreement as a borrower.
1. PROMISE TO PAY -
You promise to pay $ 7,078.3t7o the Credit Union plus interest on the unpaid balance until what you owe has been repaid. For fixed
rate loans the interest rate is 14.900/ per year.
Collection Costs:
You promise to pay all costs of collecting the amount you owe under this agreement including court costs and reasonable attorney
fees.
2. PAYMENTS - You promise to make payments of the
amount and at the time shown in the Truth in Lendingg
Disclosure. You may prepay any amount without penalty. ft
ou prepay any part of what you owe, you are s&I required
o make the regularly scheduled payments, unless we have
agreed to a change in the payment schedule. Because this
is a simple interest loan, if you do not make payments
exactly as scheduled, your final payment may be more or
less than the amount of the final payment that is disclosed.
If you elect credit insurance, we will either include the
premium in your payments or extend the term of your loan.
If the term is extended you will be required to make
additional payments of the scheduled amount, until what
you owe has been paid. You promise to make all payments
to the place we choose. If this loan refinances another loan
we have with you, the other loan will be canceled and
refinanced as of the date of this loan.
3. LOAN PROCEEDS BY MAIL - If the proceeds of this loan
are mailed to you, interest on this loan begins on the date
the loan proceeds are mailed to you.
4. SECURITY FOR LOAN - This Agreement is secured by all
property described in the "Security," section of the Truth in
Lending Disclosure. Property securing other loans you have
with us also secures this loan, unless the property is a
dwellin A dwelling secures this loan only if it is described
in the 'ecurity section of the Truth in Lending Disclosure
for this loan. /f Credit Union has a federal charter: Statutory
Lien - If you are in default on a financial obligation to us,
federal law ive us the right to apply the balance of shares
and dividends in all individual and joint accounts you have
with us to satisfy that obligation. After you are in default,
we may exercise this rigght without further notice to you.
SWe have a federal charier if our name includes the term
'Federal Credit Union.") /f Credit Union has a state charter,
except in Ohio and Rhode /s/and: We have a statutory lien
on the shares and dividends and, if any, the deposits and
interest in all individual and )joint accounts you have with us
and may exercise our rights under the lien to the extent
permitted by state law. (We have a state charter if our
name does not include the term Federal Credit Union."I
For all borrowers: You pledge as security for this loan al
shares and dividends and, if any, all deposits and interest in
all joint and individual accounts you have with the credit
union now and in the future. The statutory lien and/or your
Fledge
pledge will allow us to apply the funds in your account(s)
what you owe when you are in default. The statutory
lien and your pledge do not apply to any Individual
Retirement Account or any other account that would lose
special tax treatment under state or federal law if given as
securit
5. DEAULT - You will be in default under this Agreement if
you do not make a payment of the amount required on or
0 CUNA MUTUAL GROUP, 1999, 2000, 2001, ALL RIGHTS RESERVED
to
on
Amount Given to You Directly
$ 9 AqA q1
an amount is
before the date it is due. You will be in default if you break
any promise you made in connection with this loan or if
anyone is in default under any security, agreement made in
connection with this Agreement. You will be in default if you
die, file for bankruptcy, become insolvent (that is unable to
pay our bills and loans as they become due), or if you made
any your or misleadin statements in your loan application.
You will also be in dgefault if something happens that we
believe may seriously affect your ability. to repay what you
owe under this Agreement or if you are in default under any
other loan a reement ?rou have with us.
6. ACTIONS?AFTER DEFAULT -When you are in default, we
may demand immediate payment of the entire unpaid
balance under this Agreement. You waive any ri ht you have
to receive demand for payment, notice of inten? to demand
immediate payment and notice of demand for immediate
payment. If we demand immediate payment, you will
continue to pay interest at the rate provided for in this
Agreement, until what you owe has been repaid. We will
also apply against what you owe any shares and/or deposits
given, as security under this Agreement. We may also
exercise any other rights given 6y law when you are in
default.
7. EACH PERSON RESPONSIBLE -Each person who signs
this Agreement will be individually and jointly responsible for
paying the entire amount owed under this Agreement. This
means we can enforce our rights against any one of you
individually or against all of you together.
8. LATE CHARGE - If you are late in making a payment, you
om:se to pay the late charge shown in the Truth in Lending
drisclosure. If no late charge is shown, you will not be
charged one.
9. DELAY IN ENFORCING RIGHTS - We can delay enforcing
any of our rights under this Agreement any number of times
without losing the ability to exercise our rights later. We can
enforce this Agreement against your heirs or legal
representatives.
10. CONTINUED EFFECTIVENESS - If any part of this
Agreement is determined by a court to be unenforceable, the
rest will remain in effect.
11. NOTICES -Notices will be sent to you at the most
recent address you have given us in writing. Notice to any
one of you will be notice to all.
12. OTHER PROVISIONS -
E
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NtFCL VISA Credit-Gard PPli6tion'
tt _
'? ?vn?C ???trar ? _
hd
Applicant ecT u
?L-`h L •? ?y Date of nppttgM First Name
SSN f, .L?C] of Sl 7 ?S{?
1 )6 1 r Birth
Driver's Lice
nse Number & State n
-7 CL
Street Address
L tanov?,,o Q 17??3
4
Gty State
Years T? her- pvvn/{tent Pmt Amt.
Home P;I.,,e4
Previous Address ftf less than two years at present address) 8 7
Years There Own/ Rent Rent Number of Dependents
nLa In -'-n-s
PresentEmploye_rEmployees Street Addr
s
Employer's Ci.
?y.??p State Zip
Position ` -? Date Hi ed I--I ? ?7?
Work Phone
Joint AppllcilLm LAST Name TplicaM First Name
SSN Date of Birth
Drivers License Number & State
Present Employer Employers Soeet Address
Employer s City State Zip
Position Date Hired ?- I
Work one
Notice: Alimony, child support, or separate maintenance need not be revealed if you do
not wish to have it considered.
Month) Sala
?r ss Net Other Income ? Gross ? Net
1 /P
NCECU Account NO. I C
Cr it Limit Requested
This statement is submitted to obtain credit and Vwe certify that all informa-
tion herein is true and complete. UWe also authorize NCFCU to verify or
obtain further information NCFCU may deem necessary concerning my/our
credit standing if this application is approved and a VISA Credit Card(s) is is-
sued. The undersigned applicanos) by siggning, using, or permitting another to
use the VISA Credit Card(s) agree(s) that tFte appl
terms and condit icants will be bound by the
ions of the cardholder agreement accompan)m the VISA
Credit Card(s) and all amendments. I/we understand the typpep ofctedit'card
and credit limit wil be established after my financial inforrh4,0 iii; been
review d.
Appl' ant's Signa
Da
e' .
Joint Applicant's Signature Date
Verification Of Income May Be Re uired
ForOfftdal.U Yc
F,Pate: ?I Loan O i
of Card C
om:
_.. .: _...:,.3+w eisysc.,_i _.?•; r x.Sf:G-Yx^ 4F:,uu.a?aae.
EXHIBR
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cu L) ma :t- 0 Co co -0 :s I cu
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NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V
ANDREW FUNK,
DEFENDANT
TO: Andrew Funk
4 West Dulles Drive
Camp Hill, PA 17011
DATE OF NOTICE: April 10, 2007
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 07 -A 113 CIVI TERM
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH
THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE
OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONA AT A REDUCED FEE OR NO
FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
w
Respectfully submitted,
By:
Staten Howell, Efgwfre
owell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: April 10, 2007
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
Andrew Funk
4 West Dulles Drive
Camp Hill, PA 17011
By:
Date: April 10, 2007
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NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V.
ANDREW FUNK,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
: NO. 07 -1113 CIVI TERM
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter a DEFAULT JUDGMENT against ANDREW FUNK for his failure to file
an Answer to the Complaint served MARCH 20, 2007 by the Sheriff of Cumberland County as
shown on Exhibit "A-1 ". A Notice of Intention to Take a Default Judgment was filed on April 11,
2007 and served using a U.S. Postal Certificate of Mailing by first class prepaid postage on April
10, 2007 as shown on Exhibit "A-2" (Certificate of Service and USPS Form 3817 are attached
showing service). No answer or response having been filed with the Prothonotary as of May 15,
2007 please enter a Default Judgment in the following amount as of May 15, 2007 against
ANDREW FUNK:
Count I $ 5,058.94
Interest Count I $ 53.82 (4.99% per annum from February 26, 2007 at $.69 per diem)
Count II $ 4,042.61
Interest on Count II $ 126.36 (14.90% per annum from February 26, 2007 at $1.62 per diem)
Count III $ 649.69
Interest on Count III $ 17.94 (12.90% per annum from February 5, 2007 at $.23 per diem)
Fees $ 192.00 (Legal Fees Expressly Recoverable Under Contract)
$10,141.36 plus all costs
Respectfully submitted,
By:
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: May 15, 2007
SHERIFF'S RETURN - REGULAJ
,,---CASE-NO: 2007-01113 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NEW CUMBERLAND FEDERAL CREDIT
VS
FUNK ANDREW
KENNETH GOSSERT
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
FUNK ANDREW the
DEFENDANT , at 1833:00 HOURS, on the 20th day of March 2007
at 4 WEST DULLES DRIVE
CAMP HILL, PA 17011 by handing to
PHILIP REESE, ROOMMATE/COUSIN, ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00 r="...
Service 28.80.?'? a
Postage .39
Surcharge 10.00 R. Thomas Kline
.00
57.19 03/21/2007
STEVEN HOWELL
Sworn and Subscibed to By:
before me this day De ty S if
of A.D. ( %
EXHIBIT
A-1
(is I
4
NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V. :
ANDREW FUNK,
DEFENDANT
TO: Andrew Funk
4 West Dulles Drive
Camp Hill, PA 17011
DATE OF NOTICE: April 10, 2007
0 COPY
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 07 - 113 CIVI TERM
t' 1'71 m
-in
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH
THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE
OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONA AT A REDUCED FEE OR NO
FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
& EXHIBIT
l? -2
A- mow'.
r°
Date: April 10, 2007
Respectfully submitted,
By:
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage--
prepaid, first class United States Mail addressed as follows:
Andrew Funk
4 West Dulles Drive
Camp Hill, PA 17011
By:
Date: April 10, 2007
U.S. POSTAL SERVICE
St en Howell, Eegw re
owell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
MAILING
PROVIDE FOR
Steven Howell
Received F Attorney At Law
619 Bride Street
New Cumberland, PA 0
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NEW CUMBERLAND FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION, CUMBERLAND COUNTY,
PLAINTIFF PENNSYLVANIA
V. CIVIL ACTION - LAW
ANDREW FUNK,
DEFENDANT NO. 07 -1113 CIVI TERM
RULE 236 NOTICE OF FILING JUDGMENT
(X) Notice is hereby given that a money judgment in the above captioned action has
been entered against you in the amount of $10,141.36 plus all costs on A4A4W-H
2007.
(X) A copy of all documents filed with the Prothonotary in support of the within
judgment is/are enclosed.
Prothonotary Civil Divisio '
BY:
If you have any questions regarding this Notice, please contact the filing party:
Steven Howell, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
This Notice is given in accordance with Pa. R.C.P 236. Notice should be sent to:
Andrew Funk
4 West Dulles Drive
Camp Hill, PA 17011
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-01113 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NEW CUMBERLAND FEDERAL CREDIT
VS
FUNK ANDREW
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
FUNK ANDREW the
DEFENDANT , at 1833:00 HOURS, on the 20th day of March
at 4 WEST DULLES DRIVE
CAMP HILL, PA 17011 by handing to
PHILIP REESE, ROOMMATE/COUSIN, ADULT IN CHARGE
2007
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 28.80
Postage .39
Surcharge 10.00
.00
3)A(4) 57.19
Sworn and Subscibed to
before me this
of
So Answers: R. Thomas Kline
03/21/2007
STEVEN HOWELL
By: :0
1?q I
day De ty S if 1-12(U V,
A. D.
3
M
NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V.
ANDREW FUNK,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
DEFENDANT NO. 07 - 1113 CIVI TERM
PRAECIPE FOR WRIT OF EXECUTION
PURSUANT TO PA. R.C.P. 3101 TO 3149
TO THE PROTHONOTARY: Please issue writ of execution in the above matter,
(5) Directed to the Sheriff of Cumberland County, Pennsylvania;
(6) Against DEFENDANT ANDREW FUNK, 4 WEST DULLES DRIVE, CAMP HILL,
CUMBERLAND COUNTY, PENNSYLVANIA 17011
(7) and index this writ
(8) against DEFENDANT ANDREW FUNK, 4 WEST DULLES DRIVE, CAMP HILL,
CUMBERLAND COUNTY, PENNSYLVANIA 17011
as a lis pendens against the property of the Defendant located at 4 West Dulles Drive, Camp
Hill, Cumberland County, Pennsylvania:
ALL PERSONAL PROPERTY INCLUDING BUT NOT LIMITED TO APPLIANCES,
ELECTRONIC EQUIPMENT, COMPUTERS, DVD PLAYERS, TELEVISIONS,
TOOL, FIREARMS, AND COLLECTIBLES LOCATED AT 4 WEST DULLES
DRIVE, CAMP HILL, PENNSYLVANIA 17011.
(5) Amount Due $10,141.36
Interest Count 1 $ 86.25 (4.99% per annum from May 15, 2007 at $.69 per diem)
Interest on Count II $ 202.50 (14.90% per annum from May 15, 2007 at $1.62 per diem)
Interest on Count III $ 28.75 (12.90% per annum from May 15, 2007 at $.23 per diem)
Fees $ 100.00 (Legal Fees Expressly Recoverable Under Contract)
$10,558.86 plus all costs
Respectfully submitted,
By:
dwell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: September 18, 2007
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-1113 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NEW CUMBERLAND FEDERAL CREDIT UNION,
Plaintiff (s)
From ANDREW FUNK, 4 West Dulles Drive, Cumberland County, Camp Hill, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell all personal property
including but not limited to appliances, electronic equipment, computers, DVD players,
televisions, tool, firearms and collectibles located at 4 West Dulles Drive, Camp Hill, PA 17011 .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $10,141.36
Interest Count I -
Count H -
Count III -
Atty's Comm %
Atty Paid $96.00
Plaintiff Paid
Date: 9/19/07
(Seal)
REQUESTING PARTY:
Name STEVEN HOWELL, ESQUIRE
Address: HOWELL LAW FIRM
619 BRIDGE STREET
NEW CUMBERLAND, PA 17070
Attorney for: PLAINTIFF
Telephone: 71'7-770-1277
L.L. $.50
$ 86.25 - (4.99% per annum from 5/15/07 at $.69 per diem)
$202.50 - (14.90% per annum from 5/15/07 at $1.62 per diem)
$ 28.75 - (12.90% per annum from 5/15/07 at $.23 per diem)
Due Prothy $2.00
Other Costs $100.00 (legal fees expressly recovered
under contract)
C is R. Long, Prothonota
By:
Deputy
Supreme Court ID No. 62063
A
x,
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff s Costs: Advance Costs: 150.00
Sheriffs Costs: 73.48
Docketing 18.00 76.52
Poundage 1.44
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 02/27/08
Mileage 30.72
Surcharge 20.00
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage 82
TOTAL 8 io-Answers;
R. Thomas Kline, Sh riff
YB
By
laudia A. Brewbaker
0
Cj-- L -L
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-1113 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NEW CUMBERLAND FEDERAL CREDIT UNION,
Plaintiff (s)
From ANDREW FUNK, 4 West Dulles Drive, Cumberland County, Camp Hill, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell all personal property
including but not limited to appliances, electronic equipment, computers, DVD players,
televisions, tool, firearms and collectibles located at 4 West Dulles Drive, Camp Hill, PA 17011 .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $10,141.36 L.L. $.50
Interest Count I - $ 86.25 - (4.99% per annum from 5/15/07 at $.69 per diem)
Count II - $202.50 - (14.90% per annum from 5/15/07 at $1.62 per diem)
Count III - $ 28.75 - (12.90% per annum from 5/15/07 at $.23 per diem)
Atty's Comm % Due Prothy $2.00
Atty Paid $96.00 Other Costs $100.00 (legal fees expressly recovered
under contract)
Plaintiff Paid
Date: 9/19/07
1-4tl 2. cn.?
is R. Long, Prothonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name STEVEN HOWELL, ESQUIRE
Address: HOWELL LAW FIRM
619 BRIDGE STREET
NEW CUMBERLAND, PA 17070
Attorney for: PLAINTIFF
Telephone: 717-770-1277