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HomeMy WebLinkAbout03-1812MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF, VS. JOHN V. SHOEMAKER TAMARA A. SHOEMAKER DEFENDANTS. IN THE COURT OF COMMON PLEAS ~ CUMBERLAND COUNTY, PENNSYLVANIA · NO.: CIVIL ACTION-LAW NOTICE TO DEFEND AND CLAIM R/GHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 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 claims 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. CUMBERLAND COUNTy BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR (800) 990-9108 THOUSAND ONE HUNDRED THIRTY-EIGHT AND 03/100 DOLLARS ($7,138.03) plus interest at the rate of $1o71468 per day, through the date of payment, including on and after the date of entry of the judgment on this complaint, additional attorney's fees and costs of suit. Respectfully submitted, Esq '59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff M ernbers AL CREDIT UNION 5000 Louise Drive · P.O. Box 40 Mechanicsburg, PA 17055 OClAL SECURITY NUMBER -- ~71898 11-89-808 RATE OF INTEREST 10. 7888 LOAN NUMBER 71898 MATURITY DATE 11-16-85 SHOENAKER V, JOHN V. 8HOENRKER, TAMARR A. 127 N BECOND ST -WORNLEYSBU~ PA 17843 'CCOUNTNUMBER 163323-83 ~-'EFIXED ~ VARIABLE CLOSED-END NOTE, DISCLOSI. LOAN AND SECURITY AGREEMEI TAMiiRii ANNUAL PERCENTAGE FINANCE CHARGE: RATE: The cost of your The dollar amount the credit I ~omyOoUy to rO fo nC reodiut ?l~g ~iadl~. d Total of Payments: The "e" means estimate. · amount you will have paid Prepayment: If you pay off earl~y, you credit as a yeady rate. will cost ydu. Y · after you have made al/ will not have to pay a penalty. · ~r~ri :~ payments as scheduled. See your contract documents for any j ~a_d.d~.o. nal information about nonpayment uerau,t, any required repayment in full ' before the scheduled date and $183~4. ~8 Prepayment refunds and penalties. n · g' of ii ...... ' nsaction --------.-----._ tu [ne Inaex value· The rate will change monthly maximum rate all ........ the N/ii-- I~ ........ ~,wuu oy law, and it will never be less th=~ N/ii on the first da of '------'-- _ . (Index ~was for $5,000 at 15% ~ ....... ~" ~. Any interest rate increa ......... ~..Y. the month. The ra[e will never be hi h ) I ~nd the Annual Percentaae R~o ~ ............ ~ wi, resun ,n more payments of the s ....... g er_than the ear fh,~ *~ _~ . " .... (~,,,Ount. For I=xample, I Amount Paidto $ 475. 99 T~r'edi~; Insu~'ance Others on $ n/a ~n/a Your Behalf T~[TI~ Fee To To --"'-'-"-'-' NOTE AND ....... $ To The following paragraph applies only if this is a V~I~U,E.D_ON REVERse SIDE; Interest: Interest will be charged from the date of this loan until you have paid what you owe under this Agreement. The interest rate is subject to change as follows: N/ii '--- If the N/ii ~%. The rate will change monthl on th ' In . Any interest r · Y. e first day of the m ---------- (dex) changes· We w ~ rathe incr_~eases wdl result in more na,,m~n-.°~nt-h.'.The rate w,ll never be hi- er ..... ,Il add a margin of _ N/ii . . Promise t-, p ...... _----/__._ ~_ --- ,--z ...... ,o u~ me same amount, uh ,, ,,=,, [ne max,mum rate allowed b ..~ [o t~h.e.m_dex value. ..... ""Y. Lou p.romlse to pay $ 7975.9~ ..... _____ y law, and it wdl never be less tha%l/R ...... to the credit union -I ...... ~-- -~----~-' ~, u~ ,~[eres~ on the unpaid balance at ~ o -- -- EXHIBIT A - ~ .- Yo Der vear urJ&lJ WIi).IL yUU UW~ II;'l~ L)~er] rep~la. MAKE SECURITY INFORMATION OTHER (Describe): 1 ~7 MODEL N SECOND STREET YEAR I.D. NUMBER TYPE WORMLEYSBURS PA VALUE n/a You Pledge S~ 1 171~+ 8ND. MORTSAS~e and/or Deposits of l $ n/a ACCOU.T.U~SER ~ ~ . I agree that the terms l$ ~/a to this loan. If there is and conditions in the disclosure statement above and the loan and secud~ agreements located on the reverse side of this document shall appl] more than one borrower, we agree that all the conditions of the loan and security agreements governing ~is loan shall apply to both jointly an( severally. I acknowledge that I have received a copy of ~e loan and securi~ agreements and disclosure statement. ................. -v X DATE X DATE (S~L) ~ DATE 'OTHER OWNER- An ~mon wh ~ collate fal as explamed in the Se~ Ag~ment. "GUARANTOR; U~n ~fauE, ~e c~ uni~ ~y ~ ~me~ate ~ ~m ~ g~ranlor of any ~ ~1 ~ d~ on ~ I~, ~ gua~n~r w~ all ~s APPLI~n~ ~ ~ ~ ........ vn =~UUP CREDIT INSURANCE I (we) are applying for the credit insurance coverage s selected . .-----.-.-.-- I...(..w_e.)Lu_n.d_~r?,tand !h. at ~h~.pu.rchase of this insuranc~ Is volunfa be[°n~ ~ agree, to p. ay th?_requ,red.premi.u.m. (we) understand that fees ...... .... ~L ue lutm,y and reDly, Due y liable under the loan and that ~ '. o- o~!.~_~.n_o._rd_e.r to o. bt.a.m.c, re.d t,.and that l (we) may terminatem~ty be pa[~mbeY' ~he nsurer ,n__.c_o. nnect;~.n..w!th t.hjs.coverage to th editor , co slun~,o o.u vu,=.m~ur~ are not el g n e/or msurance, it at any . (we) unde~tand that if Joint hfe Insurance is s~?e~e~d, we The following questions, I and 2, must be answered to determine my (our) eligibility for insurance: /t~LICANT ~D-APPLICANT 1. (Applicable to life insurance coverage only) Will you be under age 70 on the effective date of your loan? YES NO YES NO 2. (Applicable to disability insuranc~ coverage only Will you be und r - °urs°rm°reperweekan ave een w !ng r: °itays a gr ' ° n`. h ` e c e eA" rey u resent yW i go side ur ,, [] [] [] [] In addition if your I - ..... .~. ~. ........ ~ ............ Y home for wages or profit for 30 , . oa..~,.,~.u~, q~ ~ 19e lOllOWJng question must also be ' · 3. ~l~l~l~El~o ~al~ej~u~e~amlmql,,,mm~. ...... --answered m order to determine ellgibilit~ [~ [] [] [] ou )answers to the abov ............ r e, c,rrhosls, Acquired Immune ., ..... u.~re[rue[o,neDestT .S W llfED. [] [] [] [] ~nd wifi not be nsured, o my (ourl know edge and behef. If my co-applicant or I answer 'No" to question 1 or 2, we understand that this person is not eligible for insurance T~e eftectwe date et my (our)insurance wili be the date of this application. Any person who knowingly and with intent ta del statement of c aim containing any materially raise information er conceals for the purpose of misleading information ruud any insurance company or other person files an a crime and subjects such person to criminal and c vii penalties Do not si n this a ' concerning an fact ma pplication for insuranc have not been cam lefad g hca Y terlel theret e or P the debtor h P hen if any appl,cahle a aces o commils a fraudulent msuranca act wh as not sfgned and dated h P are blank TMs application wJ ich is a t e apphcatlon and ~f the a fl not be used in a contest ' ' ' ' pplication has not been witnessed ' ' ' ' ' if all applicable biank ~'ou are covered only for the types of coverage for which a charge Js indicated on this application. Single Credit Life '~ ~ ~ NOTE: ONLY ONE APPLICANT MAY APPL Joint Credit Life .,_r~ ~ Y FOR DISABILITY COVERAGE Indicate which pp' s A ' ' ~ ~ Credit Disabilt¥ YES NO INITIAL AMOUNT OF LOAN ~TOTAL ~NSURAUC~E~REMiUM I MONT- .......... -- · ~ pplicant [] Co-a~nli~t CREDITDISABtLITY J~" ............... I ........... TERM OF INSURANCE IN MONTH~ EFFECTIVF na,'rc ~ .... '_~_ $ 7 ..... I"" ..... UI,5'A ..... ¥ I CREDIT DISABILITY ~ ........ IL)ATE OF BIRTH -_ © 1999 Minnesota Mutual Companies, Inc. All rights reserved. IN THESE .AGREEMENTS, THE WORDS "1." "ME," "MY" AND "MINE" MEAN ALL THOSE NAMED AS DEBTORS. THE WORDS "YOU." "YOUR" AND "YOURS" ME.&N THE CREDIT UNION. LOAN AGREEMENT Payments/Finance Charges: For value received. I promise to pay. at your office, ail ~mounts due. All payments shall be made pursuant to the disclosure statement on the face of this document. I understand that the finance charge and total of payments shown on the reverse side of this page are basea on the assumption that all installment payments will be mace on me scneauled due dates f I fail to pay any installment by the time iT is due. ! ',v pay additional interest on the overdue amount. Late Charges: If ! make a late payment. ~ agree to pay a late charge jf one '.s Jisc~osea on the face of this document. ProDerty Insurance: ;f I obtain a loan secured by a motor vehicle or other tangible propem/, i must obtain insurance which protects the credit union from financial ;oss. The amount and coverage of the property insurance /~r,U,S!h~eeftac_ce_p?~b~e. to.t.h.e' cre.dit union. Such a poi cy must roy de *. uom,ln~d aod,honal coverages and collision insurance. Itamt lues~St conjoin a Loss PayAele clause endorsement naming the credit union as lien holder. ~ may obtain this insurance from any aoent of my choice and direct the agent to send you a copy of the policy. ~ Debtor Responsibility: I promise to notify you of any change n my name, address or employment. ! oromise not to apply for a loan if know there is a reasonable probability th'at I will be unab e to repay my obligation according to the terms of the credit extension. I promise to inform you of any new information which relates to my ability to repay my obligation. promise not to submit fa se or inaccurate information or willfully conceal information regarding my creditworthiness, credit standing, or credit capacity. Default: I shall be considered in default if any of the following occur: (1) If I break any promise made under this Loan Agreement or under the Security Agreement; or (2) if i do not use the money you caned me for the purpose stated in my application; or (3) if you should, in good faith, bel eve that prospect of payment, performance or realization of the col atera if an !_rn_p_a..!r_ed;, ?r (4) if I die; or (5) ill file a petition in bankru ....... '_',. y, s ,~'uu,versnlp or am put involuntarily into such proceeding~"~r'('~)ui~/tehneCY' or collateral, if any. given as secur ty for this loan is lost, damaged or destroyed, or if t is levied against, attached or garnished; or (7) if I do not pay on time any of my other or future debts to you. If I default you may at your option and without prior notice, declare this loan mmediate y due and payable, and I must immediately pay the total unpaid balance, as well as the Finance Charge to date, any late charges and costs of collection permitted under law, includ ng reasonable attome's f . incur up to 20% of the unn 'd nrinr ....... Y. Lees: that you may · '. . fa_,. .... p,~ aha meres[ L;os[ inClUde b ~. · . . s of collection · , ut are not ,~mlted to, repossession fees, appraisals, environmental site assessments, casualty damage insurance covera e. and attorney's fees for any action taken by an attorney in order to c~lglect ~his loan or preserve or protect the credit union's dghts and remedies, including, without limitat on, pre-suit demands for payment, pre-suit mediation or settlement negotiations, investigation and assessment of the credit unions' dghts, participation in bankruptcy cases, matters, and proceedings (includ rig, w thout limitation, filing proofs of claim,pursuing reaffirmation agreements, attending meetings of creditors, and pursu ng complaints, motions and objections that relate in union's collateral or riaht t ~vrnc,-*~ ~^,, ....... .any w..ay to the cred t ~ 0 ~_¢...~,,~1, ~ullct[ural alsposition non- bankruptcy suits and/or administrative actions, and appeals. The principal balance in default shall bear interest at the contract rate. Statutory Lien: If I am in default, federal law gives you the right to apply the balance of shares and/or dividends in my account(s) at the time of default to satisfy this loan. Once I am in default, you may exercise this right without further notice to me. Delay In Enforcement: You may delay enforcing any of your rights under this agreement without losing them. Irregular Payments: You may accept late pa ments or ' .e._ve_,n__t.h~ugh marked "payment in full "with ,,[Y~ ....... p_a?al payments, · , o~, ,~,~,,,~ ~,y or your rights ,,,,uur ~nls agreement. Co-makers: If I am s gning this agreement as a co-maker, I agree to be equa y responsible with the borrower, but you may sue either or both of us. You do not have to notify me that this agreement has not been paid. You may extend the terms of payment and release any security without notifying or releasing me from responsibility on this agreement. Contractual Pledge of Shares: I pledge all my shares and deposits in the credit union, including future additions, as security for this loan. In case I default, you may apply these shares and deposits to the payment of all sums due at the time of default inc of collection , luding costs impress a lienanodn r-e~a~s-°-n-a-b-le~a~tt°rne..y's f. ees. No lien or right to .... · == ~,~ aepos~[s snail apply to any of my ,, shares which may be held in an "individual Retirement Account or "Keogh Plan." SECURITY AGREEMENT 1. To secure payment of this loan and all expenditures incurred by the credit union in connection with this loan, or in realizing on a security interest, I grant to 7ou a~ecurity interest in the property described on the reverse side of ,his dccument. The security interest includes all increases, substitutions and additions to the secured property, proceeds from any insurance on the secured property and all earnings received from the secured property. Cross-collateralization. Property given as security for this loan or for any other loan will secure all amounts ! owe the credit union now and in the ~ture. However, oroperty securina anothor d ' loan :f such property'is mv ,~rinci-~, ~ ....... ' ebt.w~ll no.t secure this ~ ~, ~,o, ~,mg or are nousenold goods. 2. I will not change the iocation of. sell or transfer the collateral unless have your prior written consent. .3. I warrant that i have good title to the collatera, free · 2tnenrne.S~tS,, e~x~c~pt that give. n to the credit union and exoe'o~/I~snevc~nr',~, ~Z-~L'.,..--_,,-,.,,~,,,e.r owner of the collateral who has sinne,4¼~,~ -7.:.Z-""-'T.~?' '~' L,,~ iflulcaTeo place = ~ "'~ c~l/~fllen[ in 4. I will pay ail taxes, assessments, and liens against or attached to the property described and further ag-ee to kee,, th- - - ~- ~ proper~y in good condition, housed in a suitable shelter. I agree to execute financing statements and security agreement amendments at your request and will defend the property against adverse third party claims. 5. I will maintain insurance to cover any vehicle or other property in which you have a security interest. This insurance will be in a form and an amount satisfactory to you. I will supply you with proof of such insurance until all sums Owed to you and secured by this property are repaid. If I fail to maintain such insurance, you may, but are not required to, obtain insurance of your own and add the cost of such to the sums owed. This cost will bear interest at the contract rate until paid. I further assign to you the right to receive the proceeds of any insurance on such property, and direct any insurer to pay those proceeds directly to ou Iaut . _end, orse. an..y check or draft provided as the "rocee~ -; .... h. orize you to ~, u~ ~ucn Insurance, ano apply [nose proceeds to the sums owed to you. I further authorize you to provide your Insurance Service Center with the necessary information for verification of adequate coverage. I acknowledge that insurance or .any extension thereof, p aced by you is without benefit to me individually but is pr mari~ for the protection of you. 6. Should you feel at any time that the security presented has diminished in value, or for any reason feel that additional security is required, I agree !o assign to you within ten (10) days whatever additional security you feel ~s necessary to protect yourself against possible loss. 7. If a default as defined in the Loan Agreement should occur, you have the authority, upon such default, to repossess and sell the collateral in a lawful manner. In such case, you or your authorized re res ' at your option, enter the premises where the ,-~,~ ...... ..P_~ ,_ en. tabv. e.s.may, ~,,,,o,~,,=~ ~ Kepi ano take possession, subject to applicable laws You have the ri. h t property pledged as collat al .n, .... L ..... g t .o render the on the premises where t~,[,-er,-~,%'.'~-~u..~,-~n? .re. ay o~s. pos.e ct the collateral ,,o ,-,,,,<~a ~ Kepi. Ii' you aeciae to sell the collateral at a pub c sale, private sale or otherwise dispose of the collateral, you will not fy me of the time and place of the intended disposition ten (10) days prior to the sale or disposition. If you sell or otherwise dispose of the collateral you may collect from me reasonable expenses incurred in the retaking, holding and preparing the collateral for and arranging the sale of the collateral. You may also collect reasonable attorney's fees and legal expenses perm tted by applicable law. incurred in connection with disposition of the property. Unless I default, I may keep possession of the property (collateral) described and use it in any lawful manner consistent with this agreement or with the insurance policy on the collateral. I understand that you have certain ri hts and lega remedies available to you under the Uniform Commercia?Code and other applicable laws. and that you may use these dghts to enforce payment if I default. In the event, I will at your request assemble the property (collateral) and make it available to you at a place oi' your choosing. If you decide to waive this default, it will not constitute waiver of any other subsequent defaults. 8. You are hereby appointed as my Attornev-in-Fact to perform any acts which you fee are necessary to protect the collateral and the security interest which this agreement creates. 9. If there is more than one borrower, our obligations under this agreement are joint and several each being equally responsible to fulfill the terms of this agreement. ' 10. This security agreement not only binds me, but my executors, administrators, heirs, and assigns. 6100 2/99 F.$5400 10/00 Members FEDERAL CREDIT UNION 5000 Louise Ddve - P.O. Box 40 Mechanicsburg, PA 17055 SOCIAL SECURITY NUMBER CERTIFICATE NUMBER · AA71090 DATE OF LOAN 11-14-00 L.O~ANRATE OF INTEREST 10. 7000 NUMBER l ~,II~ITY DATE 11-16-0~5 CLOSED-END NOTE, DISCLOSURE LOAN AND SECURITY AGREEMENT~ SHOEMAKER V, JOHN V. & SHOEMAKER, TAMARA A. 127 N SECOND ST WORMLEYSBURO.t PA 1704,3 ACCOUNT NUMBER 163;323-03 CO-DEBTOR'S NAME SHOEMAKER, TAMARA A. FIXED ~ VARIABLE RATE: The cost of your credit as a yeady rate. 10.7000 % FINANCE CHARGE: The dollar amount the credit will cost you. Amount Financed: The Total of Payments: The amount of credit provided amount you will have paid to you or on your behalf, after you have made all payments as scheduled. $7975.49 $ 10338.60 "e" means estimate. Prepayment: If you pay off early, you will not'have to pay a penalty. See your contract documents for any additional information about nonpayment. default, any required repayment in full before the scheduled date and prepayment refunds and penalties. $ 2363. 11 Variable Rate: The Annual Percentage Rate may increase durin I the term of this transaction if the N/A - (~ndax) changes. We add a margin of N/A to the Index value. The rate will change monthly on the first day of the month. The rate will never be higher than the maximum rate allowed by law, and it will never be less than N/A . Any interest rate increases will result in more payments of the same amount. For Example, if your loan was for $5,000 at 15% for 48 months and the Annual Percentage Rate increased by 2% after one year, the term of your loan would increase by two months. Your Number of Payments Amount of Payments When Payments Are Due ~: You may obtain property insuran~-e Payment9 172.31 monthly Begin 12-16-00 Schedule1 I fro.rn a.n?one you w~nt that is acceptab e to the credit wi, be: 172.31 Final due 11-16-05 I .u. ..n,!°n' lf you ~et the insurance from the credit union you I will pay ' _- J $ N/A I Security: Collatera secudng other loans with the credit union the goods or will also secure this loan. You are giving a security interest in property being Other ~~: ,,,~,u~ ,n ~ purchased.- ~ (Describe): 2ND MORT(.~A{.,=E l~ · ~_ ~ ,.o ,~t=. uy ~u Days or I Requ~ Deposit Balance: T--he Annual iling Fees: Non-Filing Insurance. ~~~/~'~)~')7(~ur I ~ercentage Rate does not take into account your n/a N/A ' ' ITEMIZATIO'-----"--'~ OF AMOUN'""--"--~ FINANCED 0'---'"-'---~ ITEMIZATION OF THE AMOUNT FINANCED TO YOU DIRECTLY UNT ~NCE CHARGE $ 79____7~. 49 7~00.00 n/a Amount 45 n/a Paidto $ 475. 49 T~:r'edit Insur, ance ~t/a To Others on $ rl/~* T(F-n~ F~, $ To Your Behalf $ ~0 *To $ To --'---------- NOTE AND SECURITY AGREEMENT (CONTINUED ON REVERSE SIDE) The following paragraph applies only if this is a vadable rate loan. The initial rate of interest is ~ Interest: Interest will be charged from the date of this loan until you have paid what you owe under this Agreement. The interest rate is subject to change as follows: If the N/A (Index) changes. We will add a margin of N/A to the index value. The rate will change mo~U~iy on the first day of the month. The rate will never be higher than the maximum rate allowed by law, and it will never be less tha~/A Any interest rate increases will result in more payments of the same amount. Prnmi~ fa P~v_' Yoi~ Oromi.~e to Oar ~ 7975. 49 to the credit union plus interest on the unpaid balance at ~ % oar year until what you (~we ha~ been repaid.' MAKE MODEL SECURITY INFORMATION YEAR LO. NUMBER TYPE VALUE OTHER(Describe):~.L~7 N SECOND STREET 14ORMLEYSBURG Pt:l :1.70/~ 2ND MORTGRSE You Pledge Shares AMOUN--'--'-'-~ ~'~ and/°r Dap°sits °f $ I1 ~at ~ ~ · _~$n/a I agree that the terms and conditions in the disclosure statement above and the loan and security agreements located on the reverse side of this document shall to this loan. If there is more than one borrower, we agree that all the conditions of the loan and security agreements governing this loan shall apply to both jointly aec severally. I acknowledge that I have received a copy of the loan and security agreements and disclosure statement. DEBTOR'S SIGNATURE DATE CO-MAKER [] *OTHER OWNER [] "GUARANTOR (SEAL) DATE [] 'OTHER OWNER "GUARANTOR DATE ('SEAL) CO-MAKER [] 'OTHER OWNER [] "GUARANTOR CO-MAKER (SEAL) X DATE X DATE (SEAL) 'O'I3.1ER OWNER: Any person who has a pref3e~- interes[~ · (SE=a~AL~ X DATE L u.mfl may seek ~mmediate payment from the guarantor of an:~ ~-~ a~o a co-maker, is eel oOligatod to pay the debt. but un~ ....... ~PLI~JATION FOR GROUP CREDIT INSURANCE I (we) are app ying for the credit insurance coverage(s) selected be ow and agree to pay the required premium I we und I (we) understand that the purchase of this insurance is volun er . . . must be jointly and individuaflv liable..nd~ .......... ta~/and not required in order tn nhtnin ~. ..... '- (~ .L)... s. tand that fees may be naid bv th~ in ......... -'--"'-'-'---- .......... ~ ,Dan, ano mar co-signers and guarantors are ~o~'eli-~'ib'~'e=f~';'i~r~e~. (we) may terminate it at an'y ti~~. ~l-(-~n~(~;~s~a°nndn~a~t°i~ j~Itnht li~SiCnsO~ar~gc~ Iso tshe?eCc~eeddltwOr The following questions, 1 and 2, must be answered to determine my (our) eligibility for insurance: /~LJCANT ~D-APPLICANT 1. (Applicable to life insurance coverage only) Will you be under age 70 on the effective date of your loan? 2. (Applicable to disability insurance coverage only) Will you be under age 66 on the effective date AND are you presently workin ou YES NO YES NO hours or more per week and have been so working for 30 days or more before this date~ g tSide your home for wages or profit for 30 In addition, if your loan exceeds $ _ 1.eL the following quest on must ' · 3. . o . . als~o._be_answered in order to determine e i ibili "y a, g ty' [] y <our)an,wars to the ahoy ............... ' . S?IOI o,rrho ,s. Ac,u red,mm,,n and will not be insured· ~ qu~,u,~ are true to tee oest of my (our) knowledge and belief f m~vc~ a~'n~ir~"~'~-=, ~.-_~,....~ · ___ [] [] [] [] · . ----,,..~,~m u~ ~ answer NO" to question 1 or 2, we understand that this person is not eligible for insurance The effective date of my (our)insurance will be the date of this app cation Any person who knowingly and with intan Statement el claim coefainieg any materially false Jet, rrna .... t · ~advmeena_.Ad~ subjects s.u.ch person In criminal and civil oen,l~°~n o,r,.co_n,ce_,a_/s ~r. the purpo..se of misleadlu informa .to defraud .any ,nsurance compa.n.y or other arson f . . T~ un[ ueen completed, the debtor has tint o~---,, --~., :-:_-.:...~u flm..u~g.n. [DiS application if any annr O, tloe_c_oflcemln.g, any fact material thereto P. lies aA _application for insurance or -,e,,,~u o.u ua[on [ne application an 'f the ~aflflli~,-,!- ~r lcab!e, spaces are blank. This a . corn.re, lis a fraudulent Insurance · - · d, ..r acne nas not oeen w,tnessed, ppllcation w,l, not be used m a contest ,, all applic~, lea~la~kh~pha~e: You are covered only for the types et coverage for which a charge is indicated on this application. ~ DATE SIGNATURE WITN[ DATE X OATE NONECOVERAGE Single Credit Life YES NO Joint Credit Life indicate which applicant(s): [] Applicant [] Co-applicant ~ITIAL AMOUNT OF LOAN TOTAL INSURANCE PREMIUM MC)NTI-Ii ...................................................... "I ............................. ........ MHC-98-4388.37 MHC-97-6200.37 CP F.43769 Rev. 9/99 REQUESTED NOTE: ONLY ONE APPLICANT MAY APPLy FOR DISABILITY COVERAGE Credit Disability YES NO Indicate which applicant: [] Applicant [] Co-applic~nt ~;;;;;; OATE~'u-appuCannt ........... CREDIT D/SABIL/TY ~ -A~ 'p;/;~A~V~ ' " ........................... ~ ! Z-07-7= 1 e1-~3-76 CREDIT UNION COPY © 1999 Minnesota Mutual Companies. Inc. All rights reserveo KARL M. LEDEBOHM ATTORNEY_AT LAW P.O BOX 173 New Cumberland, PA 17070-0173 Phone: 717-938-6929 Fax: 717-932-0317 February 28, 2003 (Via Certified and regular mail) John V. Shoemaker 127 North Second Street Wormleysburg, PA 17043 Tamar A Shoemaker 127 North Second Street Wormleysburg, PA 1 7043 RE: Members 1 st Account No.' 163323-03 Dear Mr. and .Mrs. Shoemaker: THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE FROM THIS OFFICE IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. AN IMPORTANT STATEMENT OF RIGHTS IS INCLUDED ON THE REVERSE OF THE SECOND PAGE OF THIS LETTER. Members 1~'' Federal Credit Union ("Members l~''') has requested my office to collect the amounts due to Member's 1~' under the above account . . As you know, you are in default of your obligations under the above account (the "Account") evidenced by a Closed -End Note dated November 14 2000 in the original principal amount of $7 975 49 (the 'N ' ' · ore") due to your failure to make the payments required under the Note in a timely manner As a result of your defaults, Members 1"' hereby accelerates al/amounts due to Members 1x' under the Account and the Note and hereby demands the payment of all amounts due to Members 1st under the Account and the Note in the amount of $6,278 73 itemized as follows: 1. Principal 2 Interest to 2/18/03 $5,849.08 3 Late fees 34293 4 Legal Fees 51 72 35o~o 5 Total due to Member Is' as of 2/18/03 $6,278.73 EXHIBIT B Interest continues to accrue on the above obligation at the rate of $1.71468 per day If you fail to deliver payment of the $6,278 73 together with additional interest to the date that payment is delivered to Members 1~' within thirty (30) days of the date of this letter, Members 1 ~t will have no choice but to file a legal action against you to collect all of the amounts due under the Account and the corresponding Note without further notice. In such event, in addition to the above amounts, you may also be responsible for the payment of additional reasonable legal fees and costs of suit incurred by Members 1~ Ifa suit is filed against you and a judgment entered, Members 1st may authorize my office to issue execution against an and al property. In such event, your ,, .......... Y . . i of your real or pers~ff~acle and sold at sheriff sale. " vr'-'v,:-,y may ne ~ev~ea upon by the Sheriff's O This may take place one or more times until the debt together with interest, legal less and costs are paid in full. Each time that execution is issued, the fees and costs in connection with the execution will be added to the indebtedn.ess thereby increasing the amount you owe to Members l~t. For the above reasons it is in your best interest to payoffthe debt in full prior to the expiration of thirty (30) days from this letter. If you do not want Members 1~t to sue you, you must deliver payment in the amount of $6,278.73 to my office at the address at the top of this letter on or before thirty (30) days from the date of this letter. Nothing herein shall constitute or be construed as an agreement on behalf of Members 1-~ to accept any terms and conditions in exchange for payment of the amounts due under the Account except for the immediate payment of all amounts due to Members l~t Nothing herein shall constitute a waiver of any rights or remedies which Members Ist may have under any written agreement or at law or in equity to collect the balance of the indebtedness due under the Account without further notice, including, without limitation, the right to accept and apply any partial payments made on the Account without waiver of any demand for payment in full of all amounts due under the Account Members 1~ looks forward to the payment of the $6,278.73 together with additional interest to the date that payment is delivered to Members 1~. KML/I CC Ned Picciotti, Collections Officer (pe~lnbel:l tueme~opu~) Og~ ~JOAJlg0 pe,~J~se~ (pe.qnbe~l luetues.~opu~) ee..i ),deiOeH tumel:l ee4 peuIUeO e§ataOcl 00'05 .~'15 Z£'05 .1=* (po. qnbo~ ~u~u~opu~]) ~ oe_d/ue^!le0 poloplseH r--~ (pe~nbea 3ueu~es~opu~) eed tdeloeH mntekl I-3 I--3 ee::l Pe§l~ue0 ~ e§msod r~ '.~olloI s[ql o~o dol oql 1~ lu!~d m ~uuuodd~ ~ollo| s!ttl jo puo Otll lu pou~!s omuu otll suuom pou~!s~opun 'oo!lou s!ttl jo ldt. o~o~ jo sX~p (0~;) il J!rtl u!tll!A~ noX mo~ lsonbo~ U0111.JA~ uodn ~ol!po~* l'~u!~!Jo oql jo sso~ppu pu~ otuuu oql ql!A~ no~ op!Ao~d II!~ poui~!s.~opun oql '~011oI s!ql jo o~d luoaJ oql uo poluls aol!poao oql moaJ luo~ojj!p s~. lqop s!qljo aol~.po~o leU!~!a° oqlJI · p!lUA S! lqop oql omnsse II!~ pou~!saopun oql 'oAoqU polglS Se jooJoql uo!laod Xuu ~o lqop oql olnds!p lou op noX JI 'lqop oql jo uo!I'~o~J!~OA UOlII.13A olnl!lsuoo II!A~ l!nsAYel p!us u! pol§ lu!uldm°~ ottl 'sKip (0[) Xl~!ql oq13° uotl~dxo oql oJojoq lq~P s!ql l*Ollo* ol noX lsum~u poi9 uooq suq l!ns~x~l ~ J! luql 'pop!A6~d !lqop oql jo UOI.11~OI. JI.-10A UOlll. JA'~ ql!m poqs!mr~J oq II~.A~ noX 'oo!lON sl. ql Jo ld!o,o~ ~o13~ skip (0£) Xu!ql u!ql!A~ paug~.s~opun oql lo~luoo no.g puu 3oa-~aql uo~.laod Xu~ jo 'lqop s!qljo KI!P!I'eA oql olnds~.p noX 11 'lqop u lOOliOO ol ldtuoll~ uu s~. Jollol s!q£ 3DIJ~Olq VERllqCA TION I, Leonard PicciottL Collations Officer for Members 1N Federal Credit Union, bzing authorizgxi to do so on behalf of Members lA Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my Mfomtation knowledge and belief~ I understand that false statements are made subject to the penalti~ of 18 Pa. C.S.A, Section 4904, relating to un,~worn falsification to a~thoril~es. Members In Federal Credit Union Officer SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-01812 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MEMEBERS 1ST FEDERAL CREDIT UN VS SHOEMAKER JOHN V ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SHOEMAKER JOHN V unable to locate Him in his bailiwick. but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , NOT FOUND , as to , SHOEMAKER JOHN V 127 NORTH SECOND STREET WORMLEYSBURG, PA 17043 PER POST OFFICE, DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18 00 11 04 5 00 10 00 00 44 04 [ ' R~Thomas Kl~ne Sheriff of Cumberland County KARL LEDEBOHM 05/08/2003 Sworn and subscribed to before me this /~ ~' day of , ~2~3 A.D. Pr~t~onot ary SHERIFF'S RETURN - REGULAR CASE NO: 2003-01812 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MEMEBERS 1ST FEDERAL CREDIT UN VS SHOEMAKER JOHN V ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHOEMAKER TAMAPJt A the DEFENDANT at 127 NORTH SECOND STREET , at 1050:00 HOURS, on the 30th day of April WORMLEYSBURG, PA 17043 by handing to , 2003 JESSE PIACINE, BOYFRIEND a true and attest'ed copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6 00 00 00 10 00 00 16 00 Sworn and Subscribed to before me this /~ ~--~ day of  2~6~ A.D. ! ~rothonotary' ' So Answers: R. Thomas Kline 05/08/2003 ~ KARL LEDEBOHM ~ / /2 By: ~~~ ~.-'"~ Deputy Sheriff MEMBERS 1ST FEDERAL CREDIT UNION Plaintiff VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : 03-1812 Civil Term JOHN V. SHOEMAKER and TAMARA A SHOEMAKER Defendants · CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please enter judgment in the above captioned proceeding in favor of Members 1~t Federal Credit Union, Plaintiff, and against the Defendant, Tamara A. Shoemaker, in the amount of Seven Thousand One Hundred Thirty-eight and 03/100 Dollars ($7,138.03), plus interest at the rate of $1.71468 per day through the date of payment, including on and after the date of entry of judgment on the Complaint, and attorney's fees and costs. Judgment is entered pursuant to Pa. R.C.P. 3031 for failure to file an Answer on behalf of Defendant, Tamara A. Shoemaker, to Plaintiff' s Complaint within twenty (20) days of service thereof and after a 1 O-day Notice was sent. Date: June ~q~_,2003 Respe 't y mitted, ~arl M. Lec[el~o~m, l~squire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff I hereby certify that notices of intent to take a default judgment were forwarded to Tamara A Shoemaker by United States Mail, First Class, postage prepaid on May 23, 2003. The aforesaid notice was each contained within an envelope bearing the return address of the undersigned. The notice has not been returned to the undersigned as undeliverable or otherwise. A copy of the notice and Postal Form 3817 is attached hereto and marked Exhibit "A". a~/~.~e~de~tm~ ~' ~°~,'Esquire MEMBERS i sT FEDERAL CREDIT UNION, Plaintiff VS JOHN V SHOEMAKER and TAMARA A SHOEMAKER Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 03-1812 Civil Ferm CIVIL ACTION - LAW TO¸ 151PORTANT NOTICE Tamara A Shoemaker 127 North Second Street Wormleysburg, PA 17043 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. YOU ARE iN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE 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 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17015 (717) 249-3166 or (800)990-9108 #590'12 /Supreme Court ID PO Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff EXHIBIT A U.S, POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: 3f PS Form 3817, Mar. 1989 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. SECTION 101 TO SECTION 149 ETC. MEMBERS 1s~r FEDERAL CREDIT UNION PLAINTIFF : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : No. 03-1812 Civil Term JOHN V. SHOEMAKER and TAMARA A. SHOEMAKER DEFENDANTS : Amount Due: $7,138.03 Interest From: 4/1,1/03 at $1.71468 per day to be added Atty's Com. N/A : COSTS TO BE ADDED TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriffof Cumberland County, Pennsylvania; (2) against Tamara A. Shoemaker, '127 North Second Street; Wormleysburg, PA 17043, Defendant; (3) and against N/A Garnishee (s); (4) and index this writ (a) against Tamar~ A. Shoemaker, PA 17043; Defendant; 127 North Second Street, Wormleysburg, (b) against N/A Garnishee (s), and levy upon any and all personal property of the defendant (s) as follows: Any and all personal property including, without limitation, automobiles located at the address of the Defendant at 127 North Second Street, Wormleysburg, Cumberland County, Pennsylvania. (c) Exemption has (not) been waived. Dated: ff~q"~ '~ P.O. Box 173 New Cumberland, PA 17070-0173 (717)9:t 8-6929 Attorney for Plaintiff 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-1812 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION, Plaintiff (s) From JOHN V. SHOEMAKER AND TAMARA A. SHOEMAKER (1) You are directed to levy upon the property of the defendant (s)and to sell AGAINST TAMARA A. SHOEMAKER, 127 NORTH SECOND STREET, WORMLEYSBURG, PA 17043 - ANY AND ALL PERSONAL PROPERTY INCLUDING, WITHOUT LIMITATION, AUTOMOBILES LOCATED AT THE ADDRESS OF THE DEFENDANT. (2) You are also directed to attach the properVy of the defendant(s) not i[evied 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 p°ssessi°n 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 $7,138.03 Imerest FROM 4/14/03 AT $1.71468 PER DAY Atty's Comm % Arty Paid $142.04 Plaintiff Paid Date: JUNE 10, 2003 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Deputy REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: P.O.BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-01812 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MEMEBERS 1ST FEDERAL CREDIT UN VS SHOEMAKER JOHN V ET AL Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT SHOEMAKER JOHN V unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 127 NORTH SECOND STREET WORMLEYSBURG, PA 17043 , SHOEMAKER JOHN V NOT FOUND , as to PER POST OFFICE, DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing 18.00 Service 11.04 Not Found 5.00 Surcharge t0.00 .00 44.04 So answer~m~ /~'~ ~.~.._---c~ ~ RT Thomas KIine Sheriff of Cumberland County KARL LEDEBOHM 05/08/2003 Sworn and subscribed to before me this m~ day of ~ ~3 A.D. ~r~,thonot ary ~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-01812 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MEMEBERS 1ST FEDERAL CREDIT UN VS SHOEMAKER JOHN V ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE 1050:00 HOURS, STREET SHOEMAKER TAM_ARA A DEFENDANT , at at 127 NORTH SECOND WORMLEYSBURG, PA 17043 JESSE PIACINE, BOYFRIEND a was served upon the on the 30th day of April , 2003 by handing to 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 ~00 16.00 Sworn and Subscribed to before me this 2~ ~ day of ~,~_ ~/2~ A.D. · Prothonotar¢ t - So Answers: R. Thomas Kline 05/08/2003 '//~ KARL LE~EBOHM /j// / ~ ~--~ Deputy Sheriff PRAECI~E FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. SECTION 101 TO SECTION 149 ETC. MEMBERS 1sT FEDERAL CREDIT UNION Plaintiff VS. JOI'-l~ V. SHOEMAKER and TAMARA A. SHOEMAKER Defendants : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-1812 Civil Term ' Amount Due: $7,183.03 : Interest from: 4/14/03 at $1.71468 per day : CIVIL ACTION - LAW TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Tamara A. Shoemaker, 127 North Second Street, Wormleysburg, PA 17043, Defendant; (3) and against N/A Garnishee (s); (4) and index this writ (a) against Tamara A. Shoemaker, 127 North Second Street, Wormleysburg, PA 17043, Defendant; (b) against N/A Garnishee (s), and levy upon any and all personal property of the defendant (s) as follows: Any and all personal property including, without limitation, automobiles located at the address of the Defendant at 127 North Second Street, Wormleysburg, Cumberland County, Pennsylvania. (c) Exemption has (not) been waived. Dated: P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO03-1812 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1s~r FEDERAL CREDIT UNION Plaintiff (s) TAMARA A SHOEMAKER 127 NORTH SECOND STREET WORMLEYSBURG PA From 17043 (I) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY INCLUDING WITHOUT LIMITATION AUTOMOBILES LOCATED AT THE ADDRESS OF THE DEFENDANT AT 127 NORTH SECOND STREET WORMLEYSBURG PA . (2) You are also directed to attach the property of the defendant(s) not levied upun 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 DueS7,183.03 Interest 4/14/03 AT $1.71468 PER DAY Atty's Comm % Atty Paid $157.04 PlaintiffPaid Date: AUGUST 27, 2003 (Seal) REQUESTING PARTY: Name KARL M LEDEBOHM ESQUIRE L.L.$ 0.5O Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary By: Deputy Address: P O BOX 173 NEW CUMBERLAND PA 17070-1-0173 C00gl' ID NO. 59012 Attorney for: PLAINTIFF Telephone: (717)938-6929 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 18.00 Poundage 1.41 Advertising Law Library .50 Prothonotary 1.00 Mileage 11.04 Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee TOTAL $ 71.95 Advance Costs: 150.00 Sheriff's Costs: 71.95 $ 78.05 Refunded to Atty on 03/17/04 Sworn and Subscribed to before me This$/2~4day of ~ 2oo ^.D. R. Thomas Kline, Sheriff By Claudia A. Brewbaker MEMBERS 1sT FEDERAL CREDIT UNION Plaintiff VS. JOHN V. SHOEMAKER and TAMARA A. SHOEMAKER Defendants IN THE COURT OF COMMON PLEAS cUMBERLAND cOUNTY, PENNSYLVANIA 03 - 1812 Civil Term · CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment entered in the above captioned matter satisfied. Date: March 9, 2004 Resp~ctfu. F/y submitted, ,~ ~ TM. Eedebbhm, k, squm /Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff