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Home My WebLink About01-06009 " ~'~., SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, : IN THE COURT OF COMMON PLEAS Fonnerly Known As WEST SHORE TEACHERS FEDERAL: CUMBERLAND COUNTY, PENNSYL VANIA CREDIT UNION Plaintiff v. : NO. 01 - t-a5f CIVIL DIVISION - LAW C'~l'l ~~ BEVERLY J. THOMAS Defendant COMPLAINT The Plaintiff, SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Fonnerly Known As WEST SHORE TEACHERS FEDERAL CREDIT UNION, by its attorneys, KNUPP, KODAK & IMBLUM, P.c., brings this action of Assumpsit against the Defendantto recover the sum of SIX THOUSAND, TWO HUNDRED SEVENTY-FIVE DOLLARS AND FIFTEEN CENTS ($6,275.15), along with interest thereon at the rate of 8.25% per annum from October 11,2001, upon a cause of action of which the following is a statement: I. The Plaintiff, SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, is organized and existing under Federal laws, having its principal office and place of business at 1213 Slate Hill Road, Camp Hill, Cumberland County, Pennsylvania 170 II, and was fonnerly known as WEST SHORE TEACHERS FEDERAL CREDIT UNION. 2. The Defendant, BEVERLY J. THOMAS, is an adult individual residing at 353 Marsh Oaks Drive, Pawleys Island, South Carolina 29585. 3. On or about February 26, 1996, Defendant did complete and execute Plaintiff's Loanliner Application to induce Plaintiff to extend credit to Defendant at various times and for various amounts. A true and correct copy of said Loanliner Application is attached hereto, marked as Exhibit" A" and made a part hereof. 4. To further induce Plaintiff to extend credit to her, Defendant did also execute Plaintiff's Loanliner Credit Agreement. A true and correct copy of said Credit Agreement is attached hereto, marked as Exhibit "B" and made a part hereof. F:\USERIBONNlEJO\COMP\ WORK\27508COM. WPD: 160clO 1 '"" - ,,~ ~, "-""-"Y""I~ti 5. At all times pertinent to the creating of this indebtedness to Plaintiff, Defendant was a resident ofCnmberland County, Pennsylvania, all applications and advance requests were made to Plaintiffs offices in Cnmberland Connty, Pennsylvania, and all monies were issued from Plaintiffs offices in Cnmberland County, Pennsylvania, thereby creating situs for this action. 6. On or about January 5, 1998, Defendant did execute Plaintiffs Loanliner Advance Request Voucher and Security Agreement requesting monies and offering as security for said monies the title to a 1993 Cabriolet. A true and correct copy of said Loanliner Advance Request Voucher and Security Agreement is attached hereto, marked as Exhibit "e" and made a part hereof. 7. Defendant has defaulted in the payment terms and conditions of the aforesaid docnments attached hereto and made a part hereof, and there remains due and owing a principal balance in the amount of Four Thousand, Nine Hundred Ninety-Seven Dollars and Seventy-Six Cents ($4,997.76), as set forth on Plaintiffs Statement of Account attached hereto, marked as Exhibit "D" and made a part hereof. 8. Due to Defendant's default in payment of said amount due and owing as aforesaid, interest has been added to said account in the tuta! amount of Two Hundred Twenty-Nine Dollars and Forty Cents ($229.40), as shown on Exhibit "D" attached hereto and made a part hereof. 9. Due to Defendant's default in payment of said amount due and owing as aforesaid, and pursuant to the terms and conditions found on Plaintiffs Exhibits "A", "B" and "C", attorney's fees have been added to said account in the total amount of One Thousand, Thirty-Seven Dollars and Ninety-Nine Cents ($1,037.99), as set forth on Plaintiffs Exhibit "D" attached heretu and made a part hereof. 10. The balance due and owing by Defendantto Plaintiff is the sum of Six Thousand, Two Hundred Seventy-Five Dollars and Fifteen Cents ($6,275.15)), as appears by the Statement of Account hereto attached, made a part hereof and marked as Exhibit "D". 11. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof. A:\27508COM. WPD: 160ctO 1 2 '~ ,"A~~ , ,.'~ -, ! ->~'.""""";;lI>,,,,'"!ii<r~, WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of SIX THOUSAND, TWO HUNDRED SEVENTY- FIVE DOLLARS AND FIFlEEN CENTS ($6,275.15), along with interest thereon at the rate of 8.25% per annum from October II, 200 I. Respectfully submitted, Robert D. Kodak 407 North Front Street Post Office Box # 11848 Harrisburg, P A 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff A:\27508COM. WPD: 160clO 1 3 .. ~",~ j , '~ ~ ^'r ~:' SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, : IN THE COURT OF COMMON PLEAS Formerly Known As WEST SHORE TEACHERS FEDERAL: CUMBERLAND COUNTY, PENNSYLVANIA CREDIT UNION Plaintiff v. : NO. D/ - I..D09 G;.,Jc,-~ BEVERLY 1. THOMAS Defendant : CIVIL DIVISION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WIlHIN TWENTY (20) DAYS AFTER lHIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERlNG A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WIlH 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 WIlHOUT 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. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249-3166 ........-." ""- H . ~ . \ Application ,_........ . ft.@ ~ .....~ i "".. ~..J,'-Il~ WEST SHORE TEACHERS FEDERAL CREDIT- UNION 1213 Slate Hill Road Camp Hill, PA 17011 (717) 737-4152 HOW TO APPLY .,Ple;se'domplete red sections, 1 through 8. Be sure to check all applicable boxes, . S,ign seqtiolJ 9 :c' " . Return this application to the Credit Uhion 1 NOTE AND COMPLETE ,;",",'<, ";~' Check the appropriate boxes 10 indicate the type of account(s) and type of credit for which you are applying. Married Applicants may apply for a separate account. o LOANLlNER@ Account/Loan o Credlt,Card Account o Individual Cledll: Complete Applicant section. Complete Co-Appllcanl, Spouse, Guarantor (referred to as "Other") section: (1) about your spouse if you live in a community property state (AZ, CA, 10, LA, NM, NV, TX, WA; WI), or (2) if your spouse will use the Account, or (3) if there is a guarantor on this account. Please check box to indicate whom the information is about. o Joint Credit: Provide information about both of you by completing Applicant and Other section. You REOUEST AN ADVANCE OF $ Purpose: Collate rei: Repayment: 0 Payroll Deduction 0 Cash 0 Automatic Payment 0 Military Allotment 0 o Credit Disability Insurance STATEMENT OF INTENT L1CANT INFORMATION Check coverage(s) desired. The credit union will disclose the cost of this voluntary insurance to you, A separaie insurance election which discloses the terms and conditions must be signed for coverage to become eHective APPLICANT Please print In ink or type. NAME (Last - Arst Inltiaij "1" 1itM11~ 13 rvGeL y J DRIVER'S UCE~SE NUMBER/STATE [~401 40G:- ACCOUNT NUMBER I SOCIAL SECURITY NUM, BER 3'0:>1 ( ro"2 - UI - T~ot.j BIRTH DATE HOME PHONE BUSINI:SS PHONE/EXT. o'!hS/~"1n) ]J~'J!.tlbl.o (lm7?L?b~wl:ll:O. PRESENT ADORE,SS" (Street ~ Clly - Slate/' Zip) [] Q\,\rN' ~ ,Fil:NT SLIO ~ /W'G MT Q)"'xf~~~LS"' 0liw C0~\~Ai..i),P{-\ ,'1i-70 ADORESS PREVIOUS ADDA,l:SS ,(Street -,City - 81a.!s - Zip) 0 OWN r.RRENl 4L'i.Jdl€lK. Sf' '", '""" Xffll~ C+V\I\' Ii-Ill FA (1070 ADDRESS COMPlETE FOR JOINT CREDIT, SECURED CREDITOR IF YOU LIVE IN A COMMUNITY PROPERTY STATE: o MARRIED D SEPARATED f2l UNMARRIED (Single - Divorced - Widowed) LIST AGES OF DEPENDENTS NOT LISTED BY OTHER APPLICANT (Exclude Sell) o o CO-APPLICANT 0 SPoUSE 0 GUARANTOR Use "SAA" if information is "Same As Applicant': NAME (last Firsl- lnillal) DRIVER'S LICENSE NUMBER/STATE ACCOUNT NUMBER I SOCIAL SECURITY NUMBER eUSlNESS PHONE/EXr. BIRTH DATE HOME PHONE :,"c.'!)..,. , ( ') PRESENT ADDRESS (Streel'- city - Stale - Zip) o OWN 0 RENT YEARS AT THIS ADDRESS PREVIOUS ADDRESS (Streel- City - Stale - Zip) 0 OWN 0 RENT YEARS AT THIS ADDRESS COMPLETE FOR JOINT CREDIT, SECURED CREDIT OR IF YOU LIVE IN A COMMUNITY PROPERTY STATE: o MARRIED 0 SEPARATED 0 UNMARRIED (Single - Divorced - Widowed) LIST AGES OF DEPENDENTS NOT LISTED BY APPLICANT (Exclude Self) 3 EMPLOYMENT INFORMATION MILITARY NAME AND ADDRESS OF EMPLoYER &JILL 1e::1i1J1Ci~ Q,U'b()L1YW1 'Ht'iClC[,\ tfu:ct?'y TITL~/GRADE SUPERVISOR IF SELF EMPLOYED, TYPE OF BUSINESS NAME AND ADDRESS OF EMPLOYER TITLE/GRADE SUPERVISOR STARTING DATE IF SELF EMPLOYED, TYPE OF BUSINESS IF EMPLOYED IN CURRENT POSITION LESS THAN FIVE YEARS, COMPLETE PREVIOUS EMPLOYER NAME AND ADDRESS STARTING DATE ENDING DATE IS DUTY STATION TRANSFER EXPECTED DURING NEXT YEAR 0 YES 0 NO WHERE ENDING/SEPARATION DATE IF EMPLOYED IN CURRENT POSITION lESS THAN FIVE YEARS, COMPLETE PREVIOUS EMPLOYER NAME AND ADDRESS STARTING DATE ENDING DATE IS DUTY STATION TRANSFER EXPECTED DURING NEXT YEAR 0 YES 0 NO WHERE ENDING/SEPAF\ATIONQATE TELEPHONE 4 REFERENCES Please include Streer, City. State and Zip, NAME AND ADDRESS OF CREDllOR(S) OF DEBTS PAID OFF TELEPHONE t>l'riJltL H'.-WOIV1(-)') NAME AND ADDRESS OF NEAREST RELATIVE NOT LIVING WITH YOU r'ilil-lCe RELATIONSHIP 7')2 - 'I7'1S HOME PHONE --,"'1 'I 1 EXHIBIT A NAME AND ADDRESS OF CREDiTOR(S) OF DEBTS PAID OFF NAME AND ADDRESS OF NEAREST RELATIVE NOT LIVING WITH YOU AELATlONSHfP HOME PHONE ll", v'u~ll'"\ol ".....~ ~ NET 0 GR~~S SOURCE j"'\l,.d-cl ~'( It\\1l''.,)H'':J..,. U NET 0 GROSS SOURCE NAME AND ADDRESS OF OEPOSITORY 6 ASSETS Check box for Appllcant/O/he, List all assets and aCcOllnt number(s)- Attach other s!Jea(s if nccessal}'. SHARE DRAFT OR NAME AND ADDRESS OF DEPOSITORY CHECKING AMOUNT $(<:0' V,.t"LL' CWI-\U'l'.f: ",'''\1Nl:. SAVINGS AMOUNT NAME AND ADDRESS OF DEPOSITORY $ LIC' ,l L tl.!' "lOy..,L.J. u-::/t \ C L, I SHARE DRAFT OR CHECKING AMOUNT $ $ NAME AND ADDRESS OF DEPOSlTOAY SAVINGS AMOUNT tXflPLlCANT UST HOME AND ALL OTHER ITEMS VOU OWN AND lOCATION. Of PROPERTY PLfOGED AS COLlATf:RAl OTHER for Example: Aulo, BClat, S1OC::ks, Boncl~, Cash, Housuholcl Goods, Real Estate, ele. MARKET VAUJE FOR ANOTHER LOAN ("":'''W - HOME ""tz:C'CC:' 5V"Ttf\ ~, H\JO\L $ l.(:'cl(\'r YES X NO it-ifilC')' -- 'At'ti\ '\'I\..:i1 1\.ft'Jt.-'-(i.;.:~r $ ,L hJ t.j(j + X J.,-ILIu lfL.U' , 1,\!'_l-\1--11l\ii. YES NO - M-il( IlUllv--H ,,-,,(,('D a '~\Oll( C~~ '. t,1 "';i.;:-II..vl\r~ $ j C5rJe' T YES Y NO ;(j11,1.111-lf\ $ YES NO 7 DEBTS In addition to Rent/Mortgage list all other debts ((or example, auto roans, credit cards, second mortgage, home assoc. dues, alimony, child support, child care, medical, utilities, auto insurance, etc.) Please use a separate Nne!Dr each credit card and auto roan. Attactlother sflt1t)tsif flil,Jessary APPLICANT CREDITOR -ACCOUNT OFllGINAl PRESENT MONTHLY IF PAST OTHER NAME ANO ADDRESS NUMBER BALANCE BALANCE PAYMENT Duev ~ RENT - S " MORTGAGe "2 \ut. --t?,)\?lI'vT(.l N $ $ $2J'>l.. 50 (11'1cl. Tax&lna:l , 1,,1 t. :',~--\ 1,0 I)(~ tS-r 0'5/1 $ $ $ "/0,1.'0 '-, ,JulI'N V(>i'1 'U(\(AlIIM Dl('6",T " filL, $ $ $ feD/v, '- Lnl\'>111.J'flC. rrnhf\AA~ $ $ $ "iV,dJ ", 'rIll'JIM /, [, l' IT, (jt1t~'L $ $ $ ItO,L'7J , vl")l1 Ill\1lt r ")/'IZn-\r:~q:flil/,IL.':,fxn,- -"'" $ $ $ '(G.t'!) " PI\l~/;ll'..Hllr ; "f)l,t<(~W"r () ':(If ) Cds 110; Co gl"tv 1l;\'iLl"' U $ $ $ 7c.iD " tv', f..r I t-fGlv'C(~ldYI"-1\(b " /,1 c,/J I b- wArD . $ $ $ 31.Gb , , ::,r{'{'') ',11\,>c) $ $ $ ",i./.;/"; LIST ANY NAMES UNDER WHICH 'tOUR CAEDIT REFERENCES AND CREDIT HISTORY CAN BE CHECKED $ $ $7r;,Ir.DD TOTALS c_ 8 FltlANCIAL ItlFORMATIOtl rhes~ questions apply to both Applicant and Other. IF A "YES" ANSWER IS GIVEN TO A QUESTION, EXPLAIN ON AN ATTACHED SHEET HAVE YOU ANY ourST ANDING JUDGMENTS? HAVI::: YOU EVER FllED FOR BANKAU-PTCY OR-AJID A DEBT ADJUSTMENT PLAN CONFIRMED UNDER CHAPTER 131' HAVE YOU HAD PROPERTY FORECLOSED UPON OR REF>QSSES$ED IN THE LAST 7 YEARS? AAE YOU A PARTY IN A LAWSUIT? ARE YOU OTHER THAN A U.S. CITIZEN OR PERMANENT RESIDENT AllEN? IS YOUR INCOME LIKElY TO DECLINE IN THE NEXTTWOYEARS? ARE YOU A CO-MAKER, CO.SIGNER OR GUARANTOR oN' AN't' LOAN NOT LIsTED ABOVE? FOR WHOM (Name of Others Obllgated on loan): TO WHOM (Name of CredItor): APPLICANT OTHER YES NO ---,,, YES NO X X \( '- X X ><. - 9 You understand that when applicable, a Personal Identification 1 N T E Number (PIN) maybe issued, ThisPIN,whenvalidaled wUl allow you. ~ t~er:ar~~w S the co-applicant and any authorized users, to access your credit union's CJ::lED1T CARDJATM accounts through participating Aulo- Jmport~nt c~an9as, mated Teller Machine (ATM) networks, subject to the terms and r()~, ~I~~~ n'?tJly udS'. disclosures of the Credit Card Agreemen~ andJhe El~~~!onic Funds In ..n dig 1,17me / Transfe(n,sclosure for Cf{EDTf CARD/ArM Access Card. You :~~~ :~u;S; s understand that use of your credit 9l!rd-Will constitute acknowl. of ~ny c~n~e- Yn edgment of re?eipt and a~reeme (r? the terms of the CREDIT your nam~ address CAR~/ ~TM A'Cce~~. Card d~ _ reS'. . or employment /._ -' ...-.: -.-:;, -- ~j("in a reasonatJ{a~)(' - "?'?- / J:/~ "- Orne thereafter. APPLICANT'S SIGNATURE' /./ 0 TE You also promise that everything you have stated in this application Is correct to the best of your knowledge and that the above information is a complete listing of all your debts and obligations. You authorize the credit union to obtain credjt reports in connection with this application for credit and for any update I renewal or extension of the credit received. If you raquoat, tIle ':'[ild!t unlonwlil tail you tho name and address ot any crodit bureau from which it received a credit report on you. You understand that it is a federal crime to willfully and deliberately provide incomplete or incorrect information on loan applications made to Federal Credit Unions or State Chartered Credit Unions insured by NeUA. X O'rliER SIGNATURE DATE 10 CREDIT UNION INFORMATION Do not write in this section- lor credit union use only. Check app/fcabfe box(es). . v APPROVED $ $ DATE - LIMITS SIGNATURE LlNEOFCREDIT OLOANOF1"ICER ADVANCEAPPAOVED: DYES oNO OCREDIT COMMITTEE OR OTHER OOUT61DE INFORMATION CONSIDERED; REFERRED TOIREASQN(S) FOR REFERRAl: $ $ OrnER OTHER DEBT RAnD o COUNTER OFFEA WILL BE MADE, IF ACCEPTED, ADVANCE APPROVED DYES 0 NO IF YES, ATTACH ADDJT1QNAL SHEET AND DESCRIBE DESCRtBE COUNTER OFFER: SPECIFIC REASON(S) fOR REJECTION; SIGNATURES: o LOAN OFFICER X o CREDIT COMMITTEE X o ECOA NOTICE AND AEASON FOR AEjE'cTroN SENT OR DEllVERt;O ON DATE x X DATt DATE DATE COATl:) BY (INITIAlS) __0" _.~ ._~~ .~ , WEST SHORE TEACHERS .,. FEDERAL CREDIT UNION "'~ 1213 Slate Hill Road Camp Hill, PA 17011 @ (717) 737-4152 HOW TO APPLY: Read section 1 sign and complete sections 2 & 3 Complete Credit Insurance Application & Schedule Return this Credit Agreement to the Credit Union - An incomplete or unsigned form may delay processing - You will receive your copy of the Credit Agreement and " "L,~,;,"",..:, IOININR CREDIT AGREEMENT insurance information IMPORTANT 1 CREDIT AGREEMENT AND TRUTH IN LENDING DISCLOSURE When you are in default the credit union can demand immediate payment of the entire unpaid balance under this Plan without giving you advance notice. If immediate peyment is demanded, you will continue ':~~rRIBIT B CREDIT UNION COPY The following is part of your LOANLlNER Open-End Plan. Read this information before signing on page 2. Please see the accompanying Addendum for a This LOANLlNER Credit Agreement and Truth in Lending Disclosure will be referred to as "this Plan". "You" and "your" mean each person who signs this Plan. The "credit union" means the credit union whose name appears above or anyone to whom the credit union transfers its rights under this Plan. HOW THIS PLAN WORKS -- The credit union anticipates that you will borrow money (called advances) under this Plan from time to time. The credit union, however, is not required to make advances to you under this Plan and oan refuse a request for an advanoe at any time. The Addendum describes the different types of credit (called sub. accounts) available under this Plan. If you have been approved for credit under a subaccount marked with a star (*), you will be given a specific credit limit for that subaccount. For other subaccounts you may not be given a specific dollar limit. PROMISE TO PAY -- You promise to repay to the credit union all advances made to you under this Plan and any applicable charges described in the Addendum together with interest on what you owe until the total amount has been repaid. The interest rate depends on the subaccount under which the advance is made. The Addendum shows the current interest rates as daily periodic rates and their corre- sponding annual percentage rates. If, the interest rate for any or all advances is a variable interest rate, the Addendum explains how ~he v8iiab!e :nterest rate works. PAYMENTS -- The amount of payments for an advance is determined according to the payment schedule in the Addendum, Payments are due on the last day of each month unless a different date is set by the credit union at the time of an advance. If the Addendum has no payment schedule for a sub. account, the amount and due date of payments will be determined at the time of each advance. Payments must include any amount past due and any amount by which you have exceeded any credit limit you have been given for a subaccount. You may prepay all or part of what you owe at any time without any prepayment penalty. COST OF CREDIT -- The dollar amount you pay for money borrowed is called a finance charge and begins on the date of each advance. To compute the @CUNAMUTUALINSURANCESOCIETY, 1980, 82. 84, 86, 89 ALL RIGHTS RESERVED disclosure of your various Subaccounts, Present Annual Percentage Rates, Daily Periodic Rates and any additional information. finance charge, the unpaid balance' for each day since your last payment (or since an advance if you have not yet made a payment) is multiplied by the applicable dally periodic rate. The sum of these amounts is the finance charge owed. The balance used to compute the finance charge is the unpaid balance each day after payments and credits to that balance have been subtracted and any new advances have been added. A finance charge will be computed separately for each separate balance under this Plan. SECURITY INTEREST -- You agree that all advances under this Plan will be secured by the shares and deposits in all joint and individual accounts you have with the credit union now and in the future. Additional security will be required depending on the subaccount under which an advance is requested. For example, a subaccount called "New Car Advances" means the security will be a new car. Shares and deposits in an Individual Retirement Account and any other account that would lose special tax treatment under state or federai law if given as security are not subject to the security interest you have given in your shares and deposits. Property given as security under this Plan or for any other loan will secure all amounts you owe the credit union now and in the future. However, for advances made under this Plan, the credit union specifically waives any security interest it may have in your dwellings given through any other mortgages or security agreements. DEFAULT -- You will be in default if you do not make a payment of the amount required when it is due. You will be in default if you break any promise you made under this Plan or if anyone is in defauit under any security agreement made in connection with an advance under this Plan. You will be in default if you die, file for bankruptcy, become insolvent, if you make any false or misleading statements in any credit application or update of credit information, or if something happens which the credit union believes may substantially reduce your ability to repay what you owe. (Continued) BPA67 A (LASER) 6849l.L "' ~ ---- .!<,j-iIill__IIikilIIllll"~ .....1 ", 'West Shore Teachers rederal Credit Union Beverly J. Thomes 1 CREDIT AGREEMENT AND TRUTH IN LEIIIDING DISCLOSURE to pay interest, at the applicable interest rates in effect under this Plan, until what you owe has been repaid. If a demand for immediate payment has been made, the shares and deposits given as security for this Plan can be applied towards what you owe. The credit union can also exercise any other rights given by law when you are in default. Continued PROPERTY INSURANCE -- You will be required to purchase property insurance on certain types of security that you give for advances. You may purchase the property insurance from anyone you choose that is acceptable to the credit union. CANCELLING OR CHANGING THIS PLAN -- The credit union has the right to change the terms of this Plan from time to time after giving you any advance notice required by law. Any change will apply to future advances, and at the discretion of the credit union, and subject to any requirements of the applicable law, will also apply to unpaid balances. An increase in the daily periodic rate under a variabie interest rate is not considered a change in terms under this Plan. The credit union can cancel the entire Plan or any part of this Plan at any time. You can cancel this Plan at any time. Your obligation to pay the unpaid balances under the terms of this Plan continues whether you or the credit union cancel this Plan or any part of this Plan. STATEMENTS AND NOTICES -- On a regular basis 2 SIGNATURE 3 01/05/1998 DATE o LOAN OFFICER [i] CREDIT COMMITTEE OR OTHER REFERRED TO/REASON IS} FOR REFERRAL: CREDIT UNION INfORMATION APPROVED $ LIMITS SIGNATURE LINE OF CREDIT ADVANCE APPROVED: 0 YES 1:&:1 NO OUTSIDE INF,?RMATION CONSIDERED: DESCRIBE COUNTER OFFER: SPECIFIC REASON(S) FOR REJECTION: SIGNATURES: o LOAN OFFICER o CREDIT COMMITTEE X o ECOA NOTICE AND REASON FOR REJECTION SENT OR DELIVERED ON x . ,~" ~ ".L-...~'-''"''''~~i,~",,,,,~,~f,;.,, - ~" Date 01l05/'i998., you will receive a statement showing all transactions under this Plan during the period covered by the statement. Statements and notices will be mailed to you at the most recent address you have given the credit union in writing. Notice to anyone of you will be notice to all. JOINT ACCOUNTS -- If this is a joint account, each of you authorizes the other(s) to get advances individually under this Plan. That means an advance can be made upon the request of only one of you and that the check can be issued to only one of you. If you give inconsistent instructions, the credit union can refuse to follow your instructions. Each of those who sign this Plan will be individually and jointly responsible for paying the entire amount owed under this Plan. That means the credit union can enforce its rights under this Plan against anyone of you individually or against a/l of you together. UPDATING INFORMATION -- You promise that you will promptly give the credit union written notice if you move, change your name or employment, or if any other information you provided to the credit union changes. You also agree to provide the credit union updated financial information about yourself upon request. The credit union can delay enforcing any of its rights any number of times without losing its rights. If the law makes any term(s) of this Plan unenforceable, the other terms will remain in effect. you sign below. You have read the LOANLlNER Credit Agreement and by signing below, you agree to be bound by the terms of the agreement. X OTHER SIGNA TURE DATE 39.76200 % OTHER OTHER DEBT AATIO o COUNTER OFFER WILL BE MADE, IF ACCEPTED, ADVANCE APPROVED [K] YES 0 NO IF YES, ATTACH ADDITIONAL SHEET AND DESCRIBE DATE DATE x x DATE DATE {DATE} BY (INITIALS) CREDIT UNiON COPY BPA67A (LASER) 68491.L - . ~ WEST SHORE TEACHERS 'ft, , ",',',.. FEDERAL CREDIT UNION 1213 Slate Hill Road Camp Hill, PA 17011 @ (717) 737-4152 CREOIT INSURANCE You can protect your financial future by signing up for voluntary credit insurance below. Enroll by simply indi- cating your preference in the "Credit Insurance Application" " ,,' "'JilI--",.,_,; "'~--'"'.=" laMtUNR section below. Your credit union will be happy to explain the various insurance options and coverage. The cost is reasonable. CREDIT INSURANCE APPLICATION & SCHEDULE "You" or "Your" means the member and the joint insured (if applicable). Credit insurance is voluntary and not required in order to obtain your loan. You may select any insurer of your choice. You have established an open-end Loan Plan with the Credit Union. Your Loan Plan may consist of one or more Loans. You are applying to the Society for credit insurance. You authorize the charges for insurance to be added to your Loan Balance each month and understand that interest will ft.. CUNA MUTUAL GROUP P.O. Box 391 . 5910 Mineral Point Road Madison, WI 53701-0391 Phone: 600/937-2644 CL1Nf:l. Mutual Insurance Society accrue on these charges the same as it accrues on amounts of advances which are added to your Loan Balance. DO NOT SIGN THIS APPLICATION IF IT CONTAINS ANY BLANK SPACES. This application is void and will not be used in a contest if all blank spaces have not been completed, if the member has not signed and dated the Application. and if the Application has not been witnessed. INSUREr> MEMBER DATE OF BIRTH DATE OF ISSUE OF CERTIFICATE Beverly J. Thomas JOINT INSURED MEMBER 09/25/1958 DATE OF BIRTH ACCOUNT NUMBER 3551 01105/1998 ACCOUNT NUMBER SECONDARY BENEFICIARY (If you desire to name anel , UNDER CREDIT LIFE AND DISABILITY, THE MAXIMUM ELIGIBILITY AGE FOR COVERAGE IS 65 WITH NO TERMINATION AGE REQUIREMENT. THE FOLLOWING STATEMENTS MADE BY YOU ARE REPRESENTATIONS AND' ARE TRUE TO THE BEST OF YOUR KNOWLEDGE AND BELIEF: CREDIT DISABILITY INSURANCE YES NO COVERAGE SELECTED X SINGLE CREDIT DISABILITY PREMIUM SCHEDULE SEE SEPARATE RATE SCHEDULE ON THIS DATE. ARE YOU PHYSICALLY WORKING FOR A X SALARY OR WAGES A MINIMUM OF 25 HOURS A WEEK? ARE YOU MAXIMUM AGE X UNDER AGE....22...? FOR INSURANCE NONE' MAXIMUM MONTHLY TOTAL DISABILITY BENEFIT $ 600.00 If you are totally disabled for more than benefit will begin with the 15 14 days, then the disability day of disability. DATE DATE X APP.801-Q786PA CREDIT LIFE INSURANCE YES NO COVERAGE SELECTED COST PER $100 OF YOUR X SINGLE CREDIT LIFE MONTHLY LOAN BALANCE $ .057 COST PER $100 OF YOUR X JOINT CREDIT LIFE MONTHLY LOAN BALANCE $ .099 ARE YOU MAXIMUM AGE X UNDER AGE 65 ? FOR INSURANCE NONE" MAXIMUM INSURABLE BALANCE PER LOAN ACCOUNT DATE DATE x WITNESS DATE x APP.811-Q786PA CREDIT UNION COPY BPA67A (lASeR) 6849LL 1ilIUlt1~_-' ",.".,...... ~ ~ .. ,'6 ~ i ',.~-",~;;;""""~ ...".... West Shore Teachers FederaL Credit Union Date 01/05/1998 BeverLy J. Thomas SECURITY AGREEMENT In .this agreement all references to "credit union" mean the credit union whose name appears on this agreement and anyone to whom the credit union assigns the LOAN LINER Credit Agreement. All references to "the advance" mean the amount in the box labeled "New Balance". All references to "you" mean each person who signs this agreement. THE SECURITY FOR THE LOAN -- By signing this security ag:reernent m the s.lgn~ture area or under the statement referring to this agreement which 's on the back of the check you receive for the advance, you give the credit union what is known as a security interest in the property described in the "Security Offered" section. The security interest you give includes all accessions. Accessions are things which are attached to or installed in the property now or in the future. The security interest al~o , includes any replacements for the property which you buy wlthm 10 days of the advance or any extensions, renewals or refinancing of the advance. It also includes any money you receive from selling the property or from insurance you have on the property: It the value at the property declines, you promise to give the credit union more property as security if asked to do so. WHAT THE SECURITY INTEREST COVERS --The security interest secureS the advance and any extensions, renewals or refinancings of the advance. It also secures any other advances you have now or receive in the future under the LOANLlNER Credit Agreement and any other amounts you owe the credit union for any reason now or in the future. If the property descriptIon is marked wIth two stars (*0), or the property is household goods as defined by the Credit Practice Rule, the property will secure only the advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY -- You promise that you awn the property, or if this advance is to buy the property, you promise you will use the advance for that purpose. You promise that no one else has any interest in or claim against the property that you have Tlot already told the credit union about. You promise not to sell or lease the property or to use it as security for a loan with another creditor until the advance is repaid. You promise you will allow no security interest or lien to attach to the property either by your actions or by operation of law. PROTECTING THE SECURITY INTEREST -- If your state issues a title for the property, you promise to have the credit union's securitY interest shown on the title. The credit union may have to file what is called a financing statement to protect its security interest from the claims of others. If asked to do so, you promise to sigrl a financing statement. You also promise to do whatever else the credit union thinks is necessary to protect Its security interest in the property, USE OF PROPERTY -- Until the advance has been paid off, you promise you will: {1} Use the property carefully and keep it in good repair. (2) Obtain written permission from the credit union before making major changes to the property. (3) Inform the credit union in writing before changing your address or the address where the property is kept. \4} Allow the credit union to inspect the property. (51 Promptly notify the credit union if the property is damaged, stolen or abused. (6) Not use the property for any unlawful purpose. PROPERTY INSURANCE, TAXES ANO FEES -- You promise to pay all taxes and fees (like registration feesl due on the property and to keep the property insured against loss and damage. The amount and coverage of the property insurance must be acceptable to the credit union. You may provide the property insurance through a policy you already have, or through a policy you get and pay for. You promise to make the insurance policy payable to the credit union and to deliver the policy or proof of coverage to the credit union if asked to do so. FOR TENNESSEE CREDIT UNIONS ONLY -- USE WHEN AUTOMOBILE IS PURCHASED NOTICE! If you do not purchase the insurance required on the automobile and the credit union purchases the insurance, the insurance purchased by the credit union will cover only the credit union's interest in the property. The insurance will not be liability insurance. You have read the above statement and acknowledge that the credit union has explained it to you. SIGNATURE DATE X SIGNATURE X DATE If you cancel your insurance and get a refund, the credit union has a r.,ght to the refund. If the property is lost or damaged, the credit unIOn .can use the Insurance settlement to repair the property or ~pply It towards what you owe. You authorize the credit union to mdorse any draft or check which may be payable to you in order for the credit union to collect any refund or benefits due under your insurance policy, If you do not pay the taxes or fees an the property when due or keep It i\lsured, the credit union may pay these obligations, but is not reqUired to do so. Any money the credit union spends for taxes, fees or insurance will be added to the unpaid balance of the advance and you will pay interest on those amounts at the same rate you agreed to pay on the advance. If the credit union adds amounts for taxes. fees, or insurance to the unpaid balance of your advance, your payments may be increased by the amount necessary for the advance to be paid off in the same number of months originally scheduled. DEFAULT .- You will be in default if you break any promise you make under thiS agreement. You will also be in default if you are in default under the LOANLlNER Credit Agreement. If you are pledging property, but have not signed the LOAN LINER Credit Agreement, you will be in default if anyone is in default who has signed the LOANLlNER Credit Agreement. WHAT HAPPENS IF YOU ARE IN DEFAULT -- When you are in default, the credit union can, without advance notice to you, require immediate payment of what you owe under the LOAN LINER Credit Agreement and take possession of the property. You agree the credit union has the right to take possession of the property without going to court and without giving you advance notice. If you are asked to do so by the credit union, you promise to deliver the property at a time and place the credit union chooses. The credit union will not be responsible for any of your other property, not covered by this agreement, that you leave inside the property. The credit union will try to return that property to you or make it available for you to claim. After the credit union has possession of the property, it can sell it and apply the money received to any amounts you owe the credit union. The credit union will give you notice of any public sale or the date after which a private sale will be held, The expenses of the credit union tor taking possession ot and selling the property will be deducted from the money received from the sale. Those costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded under Section 5061b) of the Bankruptcy Code. The rest of the sale money will be applied to what you awe under the LOANLlNER Credit Agreement. If you have agreed to pay the advance, you will also have to pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the advance and to what you owe under this agreement, You agree to pay interest on that amount at the same rate as the advance until that amount has been paid. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT -- The credit union can delay enforcing any of its rights under this agreement any number ot times without losing the ability to exercise its rights later. The credit union can enforce this agreement against your heirs or legal representatives. If the credit union changes the terms of the LOANLlNER Credit Agreement, you agree that this agreement will continue to protect the credit union. CONTINUED EFFECTIVENESS -- If any part of this agreement is determined by a court to be unenforceable, the rest will remain in effect. FOR NORTH DAKOTA CREDIT UNIONS ONLY u APPLIES ONLY WHEN A MOTOR VEHICLE IS PURCHASED NOTICE: THE MOTOR VEHICLE IN THIS TRANSACTION MAYBE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PA Y THE DIFFERENCE. THE PROPERTY DESCRIPTION ON PAGE 1 IS PART OF THIS AGREEMENT. NOTICE: SIGN THIS AGREEMENT ON PAGE 1. MEMBER coPY VS,025 (LASER) 6826LL '..... ~ ~, , ~~~.~-""i nl~'" ~ ~ . ~""I\~.hl'''',; , .@ WEST SHORE TEACHERS FEDERAL CREDIT UNION 1213 Slate Hill Road Camp Hill, PA 17011 (717) 737-4152 ntMua Advance Request Voucher and Security Agreement 1 MEMBER INFORMATION DATE 01/05(1998 MEMBER NAME (LAST) Thomas, Beverly J. MEMBER ACCOUNT NUMBER 3551-1 {FIRSTl (INITIAL) SOCIAL SECURITY NUMBER 162-54-7304 HOME TELEPHONE NUMBER (717)-763-1448 PURPOSE/LOAN SUBACCOUNT DESCRIPTION Business Equipment ADORES::; DATE WANTED 700 Nailor Drive Apt.302 CITY 01/05/1998 YOU REQUEST THE FOLLOWING ADVANCE SUBJECT TO THE TERMS AND CONDITIONS OF YOUR LOANLINE'R CREDlT AGREEMENT , 2,255.52 STATE ZIP CHECK BOX IF NEW ADDRESS OR PHONE NO. SECURITY OFFERED (IF ANY) FulLy TitLe Secured Camp Hill, PA 17011-7428 2 CHANGES SINCE LAST ADVANCE LIST Al-L DEBTS: {i.e. Rem, Mortgage, Auto, CredIt Cards, Credit Union, Alimony, etc.) ATTACH ADDITIONAL SHEET IF NECeSSARY PRESENT BALANCE , , , , MONTHLY PAYMENT MARITAl.. STATUS. 00 NOT CQMPI-ETE IF APPLYING FOR INO VIDUAL UNSECUREO CREDIT UNLESS YOU,RESIDE 0 ARE RELYING UPON PROPERTY IN A COMMUNITY PROPERTY STATE (AZ, CA, 10, LA, NV, NM, TX, WA, WIl. lF YOU ARE WORKING, NAME AND ADDRESS OF NEW EMPlOYER NEW POSlTlON SEPARATED CAIU Technical Consultant DATE HIRED 01111/1984 PHONE NO. (717)-732-8400 MONiHLY SALARY $ 3,611.33 NOTICE: YOU DON'T HAVE TO INCLUDE INCOME FROM CHILD SUPPORT, SEPARATE SOURCE OF OTHER INCOME MAINTENANCE, OR ALIMONY UNLESS YOU WANT THE CREDIT UNION TO CONSIDER IT. ~ GROSS OTHER MONTHLY INCOME , 3 SECURITY OFFERED PROPERTY Fully Title See IN ADDITION TO THE PLEDGE OF SHARES IN YOUR LOANlINER CREDIT AGREEMENT, THE FOLLOWING PROPERTY SECURES THE ADVANCE: MODEL YEAR 10 NUMBER TYPE Cabriolet 93 WVWBB5150PKOOl772 VW VALUE , 11,675.00 , , OTHER (OESCRIBE) PRIMARY USE OF PROPERTY: PURCHASE MONEY: YES 4 PAYMENT TERMS t-ARM\NG PLEDGE OF SHARES $ , KEY NO: LOCATION OF PROPERTY: ACCOUNT N01S). Your Credit Union Shares .022603% % AMOUN APPROVED ANNUAL PERCENTAGE RATE 8.25000 % OTHER CHARGES INTEREST RATE IS: OTHER CHARGES tDESCRIBE) , .00 VARIABLE $ .00 PREVo LOANL1NER BALANCE (THIS SU8AccaUN\\ +' 8,251.98 LOAN LlM1T DAILY PERIODIC RATE OTHER lOANS minus NEW BALANCE 2,255.52 CURRENl PAYMENT + DATE DUE N/A =, PMT. AFTER ADVANCE 2,255.52 DATE DUE PMT. FREQUENCY + , TOTAL PMT. ALL AeCTS. N//\ 10,507.50 equals REMAiNING L1MIT N/A N/A $ 257.73 02/05/1998 M Your term will be approximately 48 payments, which may be more or less, depending on whether you prepay, have late payments, or insurance is added, etc. 5 SIGNATURES5'GN BECOW BY SIGNING BELOW OR UNDER THE ENDORSEMENT ON THE ADVANCE PROCEEDS CHECK YOU AGREE: . TO MAKE AND BE BOUND BY TIiE TERMS OF THE SECURITY AGREEMENT. . THAf EVERYTHING IN SECTlON 21S A COMPLETE USTING OF ALL YOUR DEBTS AND OBLIGATIONS. . THAi THE CREDIT UNION WILL RELY ON RMATION IN SECTION 2 TO MAKE A DECISION ON THIS ADVANCE. . TO MAKE PAYMENTS AS DISCLOSED IN CTlON . TO THE TERM{SI DISCLOSED BELOW IF AN ONE R MORE ITEM{SI ARE CHECKED. YOU ARE PLEDGING SHARES FOR THE AMOUNT IF YOU ARE NOT A BORROWER BUT AN OWNER OF THE COL1.ATERAL, SIGN BELOW AND CHECK THE APPLICABLE BOX. a8orro DATE SIGNATURE DATE (SEAL) X SIGNATURE X (SEAL) 5' X DATE (SEAL) (SEALl @CUNA MUTUAL INSURANCE SOCIETY, 1980,82, 84, 86, 89, ALL RIGHTS RESERVED MEMBER COpy VST025 {lASER) 6826LL <~ ".~ , ~~- ~ '0.' , 1 'L4mni,. , WEST StlORE TEACHERS .' FEDERAL CREDIT UNION 1213 Slate Hill Road Camp Hill, PA 17011 " (717) 737-4152 1 MEMBER INFORMATION DATE 01/05f1998 MEMBER NAME Thomas, Beverly J. IOMIINIIt Advance Request Voucher and Security Agreement ILASTI MEMBER ACCOUNT NUMBER 3551-1 (FIRSTI SOCIAL SECURITY NUMBER 162-54-7304 HOME TELEPHONE NUMBER (717)-763-1448 PUf!POSelI..OAN SUBACCOUNT DESCRIPTION Business Equipment (lNITIALI ADDRESS DATE WANTED 700 Nailo, O,ive Apt.302 CITY 01/05f1998 you REQUEST THE FOL.L.OWING ADVANCE SUBJECT TO THE TERMS AND CONDITIONS OF YOUR I.OANl.lNeR CREDIT AGREEMENT , 2,255.52 STATE ZIP CHECK BOX IF NEW ADDRESS OR PHONE NO. SECURITY OFFERED (IF ANY) Fully Title Secured Camp Hill, PA 17011-7428 2 CHANGES SINCE LAST ADVANCE L.IST AL.L. DEBTS; {Le. Rent, Mortgage, Auto, Credit Cards, Credit Union, Alimony, etc.) ATTACH ADDITIONAL. SHEET IF NECESSARY CAJU NEW POSITION Technical Consultant MONTHLY PAYMENT , , , , MAR TAL. STATUS. 00 NO COM L.ET I A PL.YING FOR INDIVIDUAL UNSECURED C EDIT UNL.ESS YOU RE 10E OR ARE R LYING UPON PROPERTY IN A COMMUNITY PROPERTY STATE (AZ, CA, 10, LA, NV, NM, TX, WA, WIJ. IF YOU ARe WORKING, NAME AND ADORE S OF NEW EMPL YER S P ,A,RA TED DATE HIRED 01/11/1984 PHONE NO. (717)-732.8400 MONiHLY5ALARY $31611.33 NOTICE: YOU DON'T HAVE TO INCL.UDE INCOME FROM CHILD SUPPORT, SEPARATE SOURCE OF OTHER INCOME MAINTENANCE, OR AUMONY UNLESS YOU WANT THE CREDIT UNION TO CONSIDER Ii. ~ GROSS OTHER MONTHLY INCOME , 3 SECURITY OFFERED PROPERTY Fully Title See IN AODITION TO THE fLEOGE OF $Hp.,RES IN YOUR LOANUNER CREDIT AGREEMENT, THE FOLLOWING ?ROPERT'r' SECURES THE ADVANCE: MODEL YEAR 10 NUMBER TYPE Cabriolet 93 WVWBB5150PK001772 VW VAL.UE , 11,675.00 , , OTHER (DESCRIBE) Your Credit Union Shares PLEDGE OF SHARES :'I , ACCOUNT NOlSI. PRIMARY use OF PROPERTY: PURcHASE MONEY: KEY NO: LOCATION OF PROPERTY: DAILY PeRIODIC RAre .022603% % AMOUNT APPROVED ANNUAL PERCENTAGE RATE 8.25000 % OTHER CHARGES INTEREST RATE IS: OTHER CHARGES (DESCRIBE) , .00 VA.RtAau. $ .00 P EV. LOANLINER BALANCE (THIS SUBACCOUNT) ...' 8,251.98 PMT. FREQueNCY lOAN llMlT o HER L ANS minus NEW BALANCe 2,255.52 CURRl::NT PAYMENT + , DATE Due N/A =, PMT. AFTER ADVANCE 2,255.52 OA TE DUE + , TOTAL. PMT. ALL ACGTS. N/A , 10,507.50 equals REMAINING LIMIT N/A N/A 257.73 02/05/1998 M Your term will be approximately 48 payments 1 which may be more or less, depending on whether you prepay, ha\Je late payments, or insurance is added, etc. 5 SIGNATURESsIGNaElow BY SIGNING BELOW OR UNDER THE ENDORSEMENT ON THE AO\JANCE PROCEEDS CHECK YOU AGREE; IF YOU ARE NOT A . TO MAKE AND BE BOUND BY THE TERMS OF THE SECURlTY AGREEMENT < BORROW-Efl BUT AN . TIlAT EVERYTHING IN SECTION 215 A COMPlETE USTlNG OF ALL YOUR OEBTS AND OBUGATIONS. OWNER OF THE . THAT THE CREDIT UNION WILL RELY ON THE INFORMATION IN SECnON 2 TO MAKE A DECISION ON THIS ADVANCE. COLlATERAL. SIGN . TO MAKE PAYMENTS AS DISC ECTt01ll4. BELOW AND CHECK THE . TO THE TERM(S) DISCl. ED Bao AN OR MORE ITEM(Sl ARE CHeCKED. APPUCABLE BOX. YO A yOU ARE PLEDGING SHARES FOR THE AMOUNT HE CHANGE IN THE TERM(SI OF YOUR LOANUNER X SHICHECK ADVA SHOWN IN THE SeCURITY OFFERED SECTION AGREeMENT MARKED WITH A STARI.). N URE O'YY-NER OF DATE SIGNATURE OWNER OF COLLATERAL lather than a. Borrowerf DATE 'S'ALl \ <::i~ X ISEALl o TE 51 NATURE DATE (SEALl (SEALI --------'-- - THAU OFFICE. INTERNALLY BY CU TRANSACTION: FIRST ,AD\JAN X SUBSEQUENT EXHIBIT c. (INT CREDtT liFE. REPAYMENT THROUGH: PAYROLL AUTOMATIC DEDUCTION PAYMENT X CASH ~LHJf~~NT LOAN NUMBER CHEC!( NUMBER DEPOSIT ACcT. NU~ ;1 ~7NA MUiuAL iNSURANCE SOCiETY, 1980, 82. 84, 8<3, 39, ALL "iG;-,TS FlESErlVELi r.RFDiT WJTCJ/J r.OPY PROCESSED BY \olSC VST025 ILASEFlJ 6826i-L CONTF\ACT NUMBER 037-1661 ~8 REFERENCE NUMBE.r.. ven-,:)'.JJ IVI - .--"~ '",~" "' ~ ~.~ ~ ~est Shore Teachers Federat Credit Union 11~'i' lli:.iIiiIiJ~_~Si_,,cl,,,,,,:,_ Beverly'J. Thomas Date 01/05/1998 SECURITY AGREEMENT In .this agreement all references to "credit union" mean the credit union whose !'1am~ appe~rs on this agreement and anyone to whom the cred't un, on assigns the LOAN LINER Credit Agreement. All references to "the advance" mean the amount in the box labeled "New Balance"..A1I references to "you" mean each person who signs this agreement. THE SECURITY FOR THE LOAN -- By signing this security ag.reement In the s.lgn~ture area or under the statement referring to th,s agreement which 's on the back of the check you receive for the ~dvar:'ce, you. give the credit union what is known as a security Interest '" the property described in the "Security Offered" section. The security interest you give includes all' accessions. Accessions are things which are attached to or instal.led in the property now or in the future. The security interest al~o ,includes any replacements for the property which you buy WI~hlO 1.0 days of the advance or any extensions, renewals or reftnancln~ of the advance. It also includes any money you receive from selling the property or from insurance you have on the property: if the value of the property declines, you promise to give the credit union more property as security if asked to do so. WHAT THE SECURITY INTEREST COVERS --The security interest secures the advance and any extensions, renewals or refinancings of the ~dva.nce. It also secures any other advances you have now or receive In the future under the LOANLlNER Credit Agreement and any.other amounts you owe the credit union for any reason now or In the future. If the property description Is marked with two stars (H), or the property is household goods as defined by the Credit Practice Rule, the property w111 secure only the advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY -. You promise that you own the prope~y, or if this advance is to buy the property, you promise you wIll use the advance for that purpose. You promise that no one else has any interest in or claim against the property that you have not already told the credit union about. You promise not to sell or tease the property or to use it as secuiity for a ioen with another creditor until the advance is repaid. You promise you will allow nO security interest or lien to attach to the property either by your .actions or by operation of law. PROTECTING THE SECURITY INTEREST - If your state issues a title for the property, you promise to have the credit union's security interest shown on the title. The credit union may have to file what is called a financing statement to protect its security interest from the claims of others. If asked to do so, you promise to sign a financing statement. You also promise to do whatever else the credit union thinks is necessary to protect its security interest in the property. USE OF PROPERTY -- Untii the advance has been paid off, you promise you w111: (1) Use the property carefully and keep it in good repair. (2) Obtain written permission from the credit union before making major changes to the property. (3llnform the credit union in writing before changing your address or the address where the property is kept. (4) Allow the credit union to inspect the property. (5) Promptly notify the credit union if the property is damaged, stolen or abused. (6) Not use the property for any unlawful purpose. PROPERTY INSURANCE, TAXES AND FEES -- You promise to pay al\ taxes and fees (like registration fees) due on the property and to keep the property insured against loss and damage. The amount and coverage of the property insurance must be acceptable to the credit union. You may provide the property insurance through a policy you already have, or through a policy you get and pay for. You promise to make the insurance policy payable to the credit union and to deliver the policy or proof of coverage to the credit union if asked to do so. FOR TENNESSEE CREDIT UNIONS ONLY -- USE WHEN AUTOMOBILE IS PURCHASED NOTICE: If you do l10t purchase the insurance required on the automobile and the credit union purchases the insurance. the insurance purchased by the credit union will cover only the credit union's interest in the property. The insurance will not be liabilitY jr'1surance. You have read the above statement and aCknowledge that the credit union has explained it to you. SIGNATURE DATE X SIGNA TUME X DATE r If you cancel your insurance and get a refund, the credit union has a r.'ght to the refund. If the property is lost or damaged, the credit union ,can use the Insurance settlement to repair the property or ~pply It towards what you owe. You authorize the credit union to Indorse any ?raft. or check which may be payable to you in order for the credit un'?n to coliect any refund or benefits due under your Insurance policy. If yo~ do not pay the taxes or fees on the property when due or keep ,t Insured, the credit un, on may pay these obligations, but is not reqUlred to do so. A~y money the credit union spends for taxes, fees or ""surance Will be added to the unpaid balance of the advance and you will pay interest on those amounts at the same rate you agreed to pay on the advance. If the credit union adds amounts for taxes, fees, or insurance to the unpaid balance of your advance, your payments may be increased by the amount necessary for the advance to be paid off in the same num ber of months originally scheduled. DEFAULT -. Y~u will be in defauit if you break any promise you :nake under thIS agreement. You will also be in default if you are In defauit under the LOANLlNER Credit Agreement. If you are pledging property, but have not signed the LOANLlNER Credit Agreement, you will be in default if anyone is in default who has signed the LOAN LINER Credit Agreement. WHAT HAPPENS IF YOU ARE IN DEFAULT -- When you are in default, the credit union can, without advance notice to you require immediate payment of what you owe under, th~ LOANLlNER Credit Agreement and take possession of the property. You agree the credit union has the right to take possession of the property without going to court and without giving you advance notice. If you are asked to do so by the credit union, you promise to deliver the property at a time and place the credit union chooses. The credit union will not be responsible for any of your other property, not covered by this agreement, that you leave inside the property, The credit union will try to return that property to you or make it available for you to claim. After the credit union has possession of the property, it can sell it and apply the money received to any amounts you owe the credit union. The credit union will give you notice of any public sale or the date after which a private sale will be held. The expenses of the credit union for taking possession of and selling the property will be deducted from the money received from the sale. Those costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent perm itted under state law or awarded under Section 506(b) of the Bankruptcy Code. The rest of the sale money will be applied to what you owe und~r the LOANLlNER Credit Agreement. If you have agreed to pay the advance, you will also have to pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the advance and to what you owe - under this agreement. You agree to pay interest on that amount at the same rate as the advance until that amount has been paid. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT -- The credit union can delay enforcing any of its rights under this agreement any number of times without losing the ability to exercise its rights later. The credit union can enforce this agreement against your hei,s or legal ,epresentatives. \f the credit union changes the terms of the LOANLlNER Credit Agreement, you agree that this agreement will continue to protect the credit union. CONTINUED EFFECTIVENESS -- If any part of this agreement is determined by a court to be unenforceabie, the rest will remain in effect. FOR NORTH DAKOTA CREDIT UNIONS ONLY.- APPLIES ONLY WHEN A MOTOR VEHICLE IS PURCHASED NOTICE: THE MOTOR VEHICLE IN TH'S TRANSACTION MAYBE SUBJECT TO REPOSSESSION. IF IT'S REPOSSESSED AND SOLO TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECE1VED IN THAi SALE, you MAY HA VE TO PA Y THE DIFFERENCE. THE PROPERTY DESCRIPTION ON PAGE 1 IS PART OF THIS AGREEMENT. NOTICE: SIGN THIS AGREEMENT ON PAGE 1. VSi025 (LASER) 6826LL CREDIT UNION COPY '" ~ --,,'"~.' , -, '_.'^~'= ~ >c",o,;,;"~.';,c:~,--/",,,,,, .__'0'1'__ ".,:,,,,",,,~,,;;*",',,,,*_"_:o.'~"':'-- '-~'--,:~\",~'~,,:,s;i_v I ,., 'I I .,..., .. I . ____ _. . .. _ C' "'^ ',0" "; ~,:,;::',~ "':~~ SUSQUEHANNA ~""'- VALLEY FEDERAL CREDIT UNION Statement of Account Date: October 11, 2001 Maker: Beverly J. Thomas Comaker: NONE Home Address: 353 Marsh Oaks Drive Pawleys Island, SC 29585 Our Account Number: 3551-1 Maker Social Security # 162-54-7304 Comaker Social Security # Principal Amount Owed: $4997.76 Interest Owed: $229.40 Penalty (20 % of Principal & Interest): $1037.99 Total Amount Claimed: $6275.15 $10.00 late fee included. t=XII- tJ ~ 1213 SLATE HILL ROAD . CAMP HILL, PA 17011-8035 LOCAL: (717) 737-4152 TOLL FREE: (800) 948-1454 FAX: (717) 737-0589 ~ ~~ OCT-.16 01 TUE 04: 12 PM SUSQUEHANNA VALLEY FCU OCT 16 '131 03:Z4PM KNUPP 8. KODAK PC ,;ill', '--, .~ " '- - " ,'.' [" ",'; , '~"'"t..."'iIi;;: FAX NO. 7177370588 P. 02 V l:.R I F I ~ A:D9J~ I, SUSAN 1. BRUBAKBR, Loan ServlgeslCoIl~IlOlU Manager of SUSQUBHANNA VALLEY l'EDIlP.AL CREDIT UNION, verify that the 9t4teUlem.s made In the aforegolng document are true llIld (lOlTCol I undcrsWId tbas fa)se alalcmel\ll bereIIl arc mo.d.e subject 10 Ihe penalties of 1 S 'l'a. C, S. 14904, rela1lng to UIl5WOrll falSlfl.catlOll to authoritieS, SUSQUEHANNA VALLEY FEDERAL CREDIT UNION '~!;lII1{J /J{lLhql ~ ~J.BrubS . l.oan Sorvice!liCoUectlong Mnnazcr Dated; 101 Jlp I () l A:\2150SCOM.l\lfD: 160..01 -"'-" il'w''''''tr~dlllll - =<<<.ilhll\lll',,-~i,,@.';!;l~~M~~~' < " ''''"1~.1I>~""M~ll'm,'Wt,,,,,, ~llililh.... ';.t_6i:14ti'odi -,-. "liJ~ ~'. or- -_~ -- r: I: ~ -'9. ~ 0 C::"l ~, ~ ~-' -l::' c -ij G ~ ~ ,'C:) b-t ,"t'~ C"'J ~' n~i(;i '-'; ~JJ ~ ~ . ~~---' "---;1-,,11 ~ ~ 8 ~~ to ;T ~~ ~ I~:: :-:-::1(.; :'::-;:... :b.. ''':_:;=~ ~ I <::~C). - ::~::C) ~ ~:~ (:J 5 CFT1 Pc: q it! r "':->' ~ ~-, :,., 51 -j ~, co -< ~ ~~ . ,~ ,,~'" .._,,_~ ~ ~H' ~"'~ 7"_~ "~~'"~ . --~ ">~,,,,,,,,,,,,,,",-,,,,,.,~..........t I , , ""~..t"""",_.~,,,y, * .... SHERIFF'S RETURN - U.S. CERTIFIED MAIL . CA~E NO: 2001-06009 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL VS. THOMAS BEVERLY J R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,THOMAS BEVERLY J by United States Certified Mail postage prepaid, on the 22nd day of October ,2001 at 0000:00 HOURS, at 353 MARSH OAKS DR PAWLEYS ISLAND, SC 29585 , a true and attested copy of the attached COMPLAINT & NOTICE Together with The returned receipt card was signed by MOVED, LEFT NO ADDRESS 00/00/0000 on Additional Comments: Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.40 .00 10.00 .00 32.40 ~~ ' . Thomas Kl ine Sheriff of Cumberland County Paid by KNUPP KODAK IMBLUM on 11/05/2001 . Sworn and subscribed to before me this '1ft:' day of n..w...L .J .Joo1 A.D. ~t2~ ,~ Prothonotary , , . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery IS desired. . Print your name and address on the reverse sa.1hat we can return the card to you. . Attach- !hl,s..card to the back of the maiJpiece.. or on the: front if spac~ permits. ,~ 1. Article Addressed to: Beverly J. Thanas 353 Marsh Oaks Drive Pawleys Island, SC 29585 2. Article Number (Copy from S8fYice label) 7000 1670 0001 8790 1052 c. SIgnature x D. Is delivery address different from item 1? If YES. enter delivery address below: 3. Service Type XJXCertified Mail o Registered o Insured Mail o Agent - [] Addressee DYes oNo o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Deli....ery1 (Extra Fee) 01-6009 civil DYes 102595-9Sl.M.1789 ,PS Form 3811 , July 1999 ~,,-->. Domes1}c Return Receipt ;~-~--:--=-=-~~- -,- ~ -! ~ f o 0 '" 00 ::1. =tc OO....n:...Z .1D~$~ "5.00 g5"--'T\ iil"'-fo '<"':rc <' '" $ ;: "'SL'cntll 3."'e :r m Q)Q.)CDF2 ~(il..> ...., -z ::: =" '" =--= =- ,-- '-= - !! ~w ~~ ~~ i~ f7ffi fe' < '" .... 0- -,J CJ .... CJ Ln ru ='- ~ - - - - - -- - -- ,.:;; -~.,$;.\ ..-""" .;--~ ' ~ - .'t-:,_-~, iiic;. .'-, ~ "-l~t1,,- ~A ~ '" iP 6 :..... ~ Q :; ,Ill rft *** *"..."'**...."'''. '- ". ' , "'~.~ ,~ I'~~,;i /). SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : In the Conrt of COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 2001-06009 P BEVERLY J. THOMAS I Defendant PRAECWE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint filed to the above term and nnmber and forward same to the Sheriff for certified mail service upon Defendant at 756 Sycamore Avenue, Myrtle Beach, South Carolina 29577. TO Cumberland Connty Prothonotary Dated: November 19. 2001 Robert D. Kodak Attorney I.D. No. 18041 Attorney for Plaintiii- !W J~ ~ ''';IiiIliiiiWl!~IIi>l~tIIt~~iI>r~~'~i~,'''''''-J\i-i~~~~",<~"~1J-!~-*''''",Hill'-~,~",,~j-!:,A. :$:'limt~~~""""" I "~,,,'~-' "'-, -,~ .~-,,< "~---, -. =,,-,, ''"'!iil~ ~ ,~" -"',~. , . ,,~ _IT -- r;',- ,~ 0 0 0 C- ~::"" -n -o-(D :z rnp-, 0 Z-~' """ "")", ?-E'- N ::':] ~':; ~~~~: V -~C) eC" -,~-"'- Zc' :::r;; ~~ :i> c: Y! '-' 2: '-1 -j ':::> )> -, ()'i ::0 -< ~ - ~-~~.~ -. " ..,,~.' . ~i,,;.. ^. ,J". "'~k~l',-,'i'i SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2001-06009 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL VS. THOMAS BEVERLY J R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,THOMAS BEVERLY J by United States Certified Mail postage prepaid, on the 27th day of November ,2001 at 0000:00 HOURS, at 756 SYCAMORE AVENUE MYRTLE BEACH, SC 29577 , a true and attested copy of the attached COMPLAINT & NOTICE Together with The returned receipt card was signed by UNCLAIMED 00/00/0000 on Additional Comments: Docketing Cert Mail Affidavit Surcharge 18.00 4.40 .00 10.00 .00 32.40 ----. Sheriff's Costs: ..."",,,- County Paid by KNUPP KADAK IMBLUM on 12/27/2001 . Sworn and sUbscr~ed to before this ;I-'WI. day of or 7 ,;)UV,)/ A.D. me o ., a. ".,.#~...v' ~othonotary ~ . "' ~ Complete items 1, '2, and 3. AI~o -b~mplert~ item 4 jf Restricted Delivery is desired. . Print your name and address on the reverse 50 that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front jf space permits. 1. Article Addressed to: Beverly J. Thanas 756 Sycamore Avenue Myrtle Beach, SC 29577 2. Article Numbel"(Copy-from service label) 7000 1670 0001 8790 0956 c. Signature x o Agent o Addressee DYes DNa D. Is delivery address different from item 11 If YES, enter delivery address below: 3. Service Type }QQ{certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 01-600~ civil 102595-99-M-1189 PS Form.3811" JuN 1999 Dom_e~~ic Return Receipt ~. '" ~ .'~ "'h,.~'~;~ ~ <, - '" , ~--""~-,,,,,<- - ~ .' SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, : IN THE COURT OF COMMON PLEAS Formerly Known As WEST SHORE TEACHERS FEDERAL : CUMBERLAND COUNTY, PENNSYL V ANlA CREDIT UNION Plaintiff v. : NO. 2001 -06009 CIVIL TERM BEVERLY J. THOMAS : CIVIL DIVISION - LAW D~fendant TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in fuvor of plaintiff and against Defendant(s), BEVERLY J. THOMAS, named for fiillure to file within the required time an Answer to the Complaint in the above-captioned case and assess the plaintifl's damages as follows: Amount claimed in Plaintifl's Complaint $6,275.15 Interest from October 11,2001 at the rate of8.25% per annum $ 172.56 Total $6,447.71 It is hereby certified that a written notice of intention to file this P~ipe was mailed to the Defundant(s) and his attorney of record, after the defuult occurred and at least ten (10) days prior to the date of the filing of this Praceipe. See Exhibits A & B attached. By' Robert D. Kodak, Attorney for Plaintiff DATED: Judgment entered and damages assessed as above. ;;NOd.. (L~ K~ ProthOnotary - -~~~ - > 1 ~~Il>?k",;, - .. ., . LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 1184B HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 717/238-7158 email: kki.law@Verizon.net fiLE GAllJLg Knupp Vfi1919-1976) Robert H. Maurer (1923-1998) Robert L Knupp Robert D. Kodak Gory J. Imblum January 21, 2002 BEVERLY J THOMAS 756 SYCAMORE AVE MYRTlE BEACH SC 29577 RE: Susquehanna Valley Federal Credit Union f/k/a West Shore Teachers Federal Credit Union VS: Beverly J. Thomas No. 2001-06009 Civil Term, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 2750B Dear Ms. Thomas: In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County, Pennsylvania, to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & (MBLUM, P.C. Robert D. Kodak, Esq. roberf.kodak@verizon.nef THIS LETTER IS AN ATTEMPT TO COlLECTA DEBT AND ANY INFORMATION OBTAINED WilL BE USED IiOR THAT PURPOSE RDKlkqb enclosure cc: SUSAN J BRUBAKER LOANS/COlL MGR SUSQUEHANNA VALLEY FEDERAL 3850 HARTZDAlE DRIVE CAMP HILL PA 17011-7809 #3551-1 j EXHIBIT A ~ ~ ,~ , " ~ I~i<"'"lt.-J .. - , , " ." fiLE COpy SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS Formerly Known As WEST SHORE TEACHERS FEDERAL : CUMBERLAND COUNTY, PENNSYLVANIA CREDIT UNION Plaintiff v, : NO. 01-6009 CIVIL TERM BEVERLY J. THOMAS : CIVIL DIVISION - LAW Defendant IMPORTANT NOTICE TO:BEVERL Y 1. THOMAS, Defendant(s) DATE OF NOTICE: JANUARY 21. 2002 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUlRED OF YOU IN TIDS CASE. UNLESS YOU ACT WITIllN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIDS 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 NOTICIA IMPORTANTE A:BEVERL Y 1. THOMAS, Demandado(s) FECHADE NOTICIA: JANUARY 21. 2002 USTED NO HA COMPLlDO CON EL AVISO ENTERIOR PORQUE HA FALTADO EN TOMAR MEDlDAS REQUERIDS RESPECTO AESTE CASE. SI USTED NO ACTUA DENTRO DE DIEZ (10) DlAS DESDE LA FECHA DE ESTA NOTIClA, ES POSIBLE QUE UN FALLO SEIA REGlSTRADO CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD 0 OSTROS DERECHOS IMPORTANlES. USTED DEBE LLEV AR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TIENE ABOGADO 0 NO TIENE CON QUE P AGAR LOS SERVICIOS DE UN ABOGADO, VA Y A 0 LLAME ALAOFICINAESCRlTA ABAJO PARAAVERIGUAR A DONDE USTED PUEDE OBTENERLA AYUDA LEGAC: CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249-3166 . ' h " 1,,~_,-,.~ 1,""','_ ~' . , .e SUSQUEHANNA VALLEY FEDI::RAL CREDIT UNION, : IN THE COURT OF COMMON PLEAS Formerly Known As WIlST SHORE TEACHERS FEDERAL : CUMBERLAND COUNTY, PENNSYLVANIA CREDIT UNION Plaintiff v. : NO. 2001-06009 CIVIL TERM BEVERLY J. THOMAS : CIVIL DIVISION - LAW Defendant To BEVERLY J. THOMAS, Defendant(s) You are hereby notified that on )- p...'" L (Judgment) has been entered against you in the above-captioned case. . 20~e following DATE: ~ JnrtlV"""t entered in the ..mount of$6.447.7l. OM.!.;" K.~ Prothonotary (.,. ::l r':P~ , I hereby certifY that the name and address of the proper person( s) to receive this notice is: BEVERLY J. THOMAS 756 SYCAMORE A VB MYRTLE BEAClf SC 2"9577 ~BEVERLY J. THOMAS. Defendido/a Defendidoslas Por este media se Ie esta notificando que el de del 20-, el/la siguiente(FaJIo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. PECHA: Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: BEVERLY J. THOMAS 756 SYCAMORE AVE MYRTLE BEACH SC 29577 Abogado del Demandante n: t,~t~ti~~iii___<Wllhllmi~~~&~,""\l.';" !1!J.~JJ.J,lj.,ll ill!! """",,,,,-,~;~,,,,,,-,,,~,,~.~__ ;,""",,,,i<>,',. dN'iJi-*aliMtJ_i'r:M ltUlllI :--"'""U>l1&.,,!i~ .. 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