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Home My WebLink About03-2736 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS formerly known as WEST SHORE TEACHERS FEDERAL : CUMBERLAND COUNTY, PENNSYL VANIA CREDIT UNION Plaintiff v. : NO. 03 - .=l?'3lc. C'Ut"l <--r-~ NA THAN E. CUZA 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 MUSTT AKEACTION WITHIN TWENTY (20) DA YSAFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY ORBY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MA Y 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 A VENUE CARLISLE P A 17013 (717) 249-3166 NOTICA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUI ERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VEINTE (20) DlAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGADO Y ARCHIV AR EN LA CORTE EN FORMA ESCRIT A SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA A VISADO QUE SI USTED NO SE DEFlENDE, LA CORTE TOMARA MEDIDAS Y PUEDA ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO A VI SO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DlNERO 0 SUS PROPIEDADES 0 OTROS DERECHOS lMPORTANTES PARA USTED. LLEVE EST A DEMANDA A UN ABOGADO IMMEDIA T AMENTE. SI NO TlENE ABOGADO 0 SI NO TlENE EL DINERO SUFIClENTE DE PAGAR TAL SERVICIQ, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY A VENUE CARLISLE PA 17013 (717) 249-3166 -.--.----.." SUSQUEHANNA VALLEY FEDERAL CREDIT UNION formerly known as WEST SHORE TEACHERS FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff Defendants : NO. 03 - .2.731.. e,;..~CT~ : CIVIL DIVISION - LA W v. NATHAN E. CUZA COMPLAINT The Plaintiff, SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, formerly known as WEST SHORE TEACHERS FEDERAL CREDIT UNION, by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of NINETEEN THOUSAND, SIX HUNDRED NINETY-THREE DOLLARS AND EIGHTY-ONE CENTS ($ I 9,693.8 I), along with interest thereon from June 5, 2003 , at the rates as agreed upon between the parties, upon a cause of action of which the following is a statement: I. The Plaintiff, SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, is a corporation organized and existing under Federal laws, having its principal office and place of business at3850 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania, and was formerly known as WEST SHORE TEACHERS FEDERAL CREDIT UNION. 2. The Defendant, NATHAN E. CUZA, is an adult individual residing at 5427 Pine Street, Omaha, Nebraska 68106-2348. COUNT I SUSOUEHANNA VALLEY FEDERAL CREDIT UNION vs. NATHAN E. CUZA LOANLINER LOAN ACCOUNT 3. Plaintiff incorporates Paragraphs I through 2 inclusive as if fully and at length set forth herein. F:\USER\ST ACY\CCP Complaints\WORK\29534.svcu.wpd: IOJun03 4. On or about March 19,200 I, Defendant did apply for credit with Plaintiff through its Loanliner program. A true and correct copy of the Loanliner Credit Agreement as executed by the Defendant is attached hereto, marked as Exhibit "A" and made a part hereof. 5. Subsequent thereto, Defendant did draw on said Loanliner account, thereby creating a balance due and owing, as of June 4, 2003, in the principal amount of Eight Thousand, Seven Hundred Forty-Seven Dollars and Eighty-Six Cents ($8,747.86), as set forth on Plaintiff's Statement of Account attached hereto, marked as Exhibit "B" and made a part hereof. 6. Due to Defendant's default in payment of said amount due and owing as aforesaid, interest has been added to said account in the total amount of Eight Hundred Twenty-Seven Dollars and Fifty-Three Cents ($827.53), as shown on Exhibit "B" attached hereto and made a part hereof. 7. Due to Defendant's default in payment of said amount due and owing as aforesaid, and pursuant to the terms of the Loanliner Credit Agreement attached hereto as Exhibit "A" and made a part hereof, attorney's fees in the amount of One Thousand, Nine Hundred Twenty-Nine Dollars and Seventy Cents ($1 ,929.70)) have been added to said account, as set forth on Plaintiff's Exhibit "B" attached hereto and made a part hereof. 8. The balance due and owing by Defendant to Plaintiff is the sum of Eleven Thousand, Five Hundred and Five Dollars and Nine Cents ($11,505.09), as appears by the Statement of Account hereto attached, marked as Exhibit "B" and made a part hereof. 9. 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. .:\USER\ST ACY\CCP Complainls\WORK\29534.\\]Jd: IO.lun03 2 --......~--.. .- WHEREFORE, Plaintiff brings this suit to recover from Defendants, the sum of ELEVEN THOUSAND, FIVE HUNDRED AND FIVE DOLLARS AND NINE CENTS ($11,505.09), together with interest thereon from June 5, 2003, at the rate as agreed upon between the parties. COUNT II SUSOUEHANNA VALLEY FEDERAL CREDIT UNION vs. NATHAN E. CUZA LOANLlNER LOAN ACCOUNT 10. Plaintiff incorporates Paragraphs 1 through 9 inclusive as if fully and at length set forth herein. 11. On or about December 5, 2001, Defendant did apply for credit with Plaintiff through its Loanliner program. A true and correct copy ofthe Loanliner Credit Agreement as executed by the Defendant is attached hereto, marked as Exhibit "C" and made a part hereof. 12. Subsequent thereto, Defendant did draw on said Loanliner account, thereby creating a balance due and owing, as of June 4, 2003, in the principal amount of Five Thousand, Eight Hundred and Nine Dollars ($5,809.00), as set forth on Plaintiff's Statement of Account attached hereto, marked as Exhibit "D" and made a part hereof. 13. Due to Defendant's default in the payment of said account, interest has been added in the amount of One Thousand Fifty-Six Dollars and Sixty-Nine Cents ($1 ,056.69), as set forth on Plaintiff's Exhibit "D" attached hereto and made . a part hereof. 14. Due to Defendant's default in payment of said amount due and owing as aforesaid, and pursuant to the terms of the Loanliner Credit Agreement attached hereto as Exhibit "C" and made a part hereof, attorney's fees in the amount of One Thousand, Three Hundred Twenty-Three Dollars and Three Cents ($1,323.03) to said account, as set forth on Plaintiff's Exhibit "D" attached hereto and made a part hereof. F:\USER\ST ACY\CCP Complaints\WORK\29534.svcu.wpd: IOJun03 3 15. The balance due and owing by Defendant to Plaintiff is the sum of Eight Thousand, One Hundred Eighty- Eight Dollars and Seventy-Two Cents ($8, 188.72), as appears by the Statement of Account hereto attached, marked as Exhibit "D" and made a part hereof. 16. 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. WHEREFORE, Plaintiff brings this suit to recover from Defendant: (A) Count I ' The sum of ELEVEN THOUSAND, FIVE HUNDRED AND FIVE DOLLARS AND NINE CENTS ($1 ] ,505.09), together with interest thereon from June 5, 2003, at the rate as agreed upon between the parties; and (B) Count II - The sum of EIGHT THOUSAND, ONE HUNDRED EIGHTY- EIGHT DOLLARS AND SEVENTY-TWO CENTS ($8,188.72), together with interest thereon from June 5, 2003 at the rate as agreed upon between the parties; for a Judgment in favor of Plaintiff and against Defendant in the amount of NINETEEN THOUSAND, SIX HUNDRED NINETY-THREE DOLLARS AND EIGHTY -ONE CENTS ($19,693.81), along with interest thereon from June 5, 2003 at the rates as agreed upon between the parties. Respectfully submitted, KN~ Robert D. Kodak 407 North Front Street Post Office Box # 11848 Harrisburg, P A ] 7108-1848 (717)238-7151 Attorney ID No. 1804] ----------- .. F:IUSERIST ACYICCP ComplaintBIWORKI29534.svcn. wpd: IOJun03 4 ICANUNa Sl;ISQUEHANNA VALLEY F. C. U. 1213 Slate Hill Rd Camp Hill, PA 17011-8012 (717)-737-4152 Application 1 NOTE AND COMPLETE STATEMENT OF INTENT 2 APPLICA INFORMATION 3 E PLOYMENT IN ORMATION MlUTARY 4 REF RENCES Please Include Street City, State and ZIp. Married Applicants may apply for a separate account. Check the appropriate box to indicate Individual Credit or Joint Credit. o Individual Credit: Complete Applicant section. Complete Co-Applicant, Spouse, Guarantor (referred to as 'Other") section: (1) about your spouse if you live in a community property state (AZ,CA,ID.LA,NM,NV,TX,WA,WI), or (2) ~ your spouse will use the O Account, or (3) if there is a guarantor on this account. Please check box to indicate whom the information is about. Joint Credit: Provide information about both of you by completing Applicant and Other section. Amount Requested $ Purpose: Collateral: Repayment: 0 Payroll Deduction 0 Cash 0 Automatic Payment 0 Military Allotment 0 NOTICE OHIO APPUCANTS: The Ohio laws against discrimination require that all creditors make credit equally available to all credit worthy customers. and that credit reporting agencies maintain separate credit histories on each individual upon request. The Ohio Civil Rights Commission administers compliance with this law. The credit union will disclose the cost of this voluntary insurance to you. A separate insurance election which discloses the terms and conditions must be signed for coverage to become effective. NO -:tAl ~ NAM rrst-lnitial) C u:Z().. fho.n DRIVER'S UCENse NUMBERlSTATE gr:, 060 ACCOUNT NUMBER SOCIAL SECURIlY NUMBER 1?fsc> 6 (0 - 0..5- 7L//. BIRTH DATE HOME PHONE BU IN~SS PHQNElEXT. f,Z7 '4',2 (7 77t"'I'Ii!fp 'eJ H/- -ZO'-/I PRESENT ADDRESS (Street - City. State - Zip) ~ OWN 0 RENT E 707 Si-..tw=d reI.., New Cvm/" o PREVIOUS ADDRESS (Street - City - State - Zip) JJiAVid. !b".; l'rJ SUPERVISOR'S NAME .5 o CO-APPLICANT 0 SPOUSE 0 GUARANTOR Referrsd to as -Other" Us8 "SAA" if inJonnation is -Same as AppliCant" NAME (Last - First - Initial) DRIVER'S UCENSE NUMBERlSTATE ACCOUNT NUMBER SOCIAL SECURITY NUMBER BIRTH DATE HOME PHONE BUSINESS PHONElEXT. PRESENT ADDRESS (Street - City - Stale. Zip) DOWN 0 RENT PREVIOUS ADDRESS (Street - City - State - Zip) u RI Y NAME AND ADDRESS OF EMPLOYER YOUR T1nEIGRADE SUPERVISOR'S NAME IF EMPLOYED IN CURRENT POSITION LESS THAN FIVE YEARS, COMPLETE PREVIOUS EMPLOYER NAME AND ADDRESS HOURS AT WORK IF SELF EMPLOYED, TYPE OF BUSINESS START DATE HOURS AT WORK IF SELF EMPLOYED. TYPE OF BUSINESS STAATING DATE s-;~ '"tIr:' ENDING DATE IS DUTY STATION TRAN R EXPECTED DURING NEXT WHERE ENDINGlSEPARATION DATE NAME AND ADDRESS OF CREDITOR(S) OF DEBTS PAID TELEPHONE NAME Af'iD Ag2:JE~ OF NEAREST t\ELATlVE NOT LIVING WITH YOU (/%~Vrtl/W'~ E....ns Itbl (''''/Y1ir~~ /# /767c1 RElATIONSHIP e;:.".",1 ~HOMEPHONE("70) /7'1"-<JW? NAME AND ADDRESS OF PER FRIEND _ NOT A RELATIVE "'-.....,N Lyle /':; ~" ,e,.{ 1M R'( lJavphif"J, PA I 0 If CUNA MUTUAL INSURANCE SOCIETY. 1980, sa. 84. 86. 89, AU RIGHTS RESERVED --~--~~._.. /" HOME PHONE ("717)'12(- 33f4> 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 WHERE ENDlNGfSEPARATION DATE NAME AND ADDRESS OF CREDITOR(Sl OF DEBTS PAID OFF NO TREPHONE NAME AND ADDRESS OF NEAREST RELATIVE NOT LIVING WITH YOU Page 1 OF2 AST023 (LASER) 6826Ll RELATIONSHIP NAME AND A ELATIVE HOME PHONE 5 INCOME INFORMATION APPLICANT OTHER(CO-APPLlCANT, SPOUSE, GUARANTOR) I NOTICE. AlImony. child support. or separaII malrWanInC8 mcorae neec:I not be revealed If you do not choose 10 haW it COf'IIidiecL , I:MPLUYMI:.N I INCOMe U I HtH IN(;UMt: $ $ PER PER o NET 0 GAOSS SOUACE NOTICE: Alimony. child support, or separate maintenance income need not be . " revealed if you do not choose to have it considered. . l::MI-'LUYMI:.N I INlj(JMt:: U I HE:H IM;UMt: $ PEA o NET $ PEA SOURCE o GROSS number{s)~ APPUCANT UST HOME AND ALL OlliER ITEMS YOU OWN AND LOCATION OF PROPERTY PLEDGED AS Attach other For example: Auto, Boat. StoCkS. Bonds, Cash. Household Goods, Real Estate, etc. MARKET VALUE COUATERAL FOR sheets if OTHEA ANantER LOAN necessary. HOME $ YES NO $ YES NO I $ YES NO I , 7 APPUCANT CREDITOR ACCOUNT , ORtGlNAL I PRESENT I MOIfTHl. y ~ OTHEA NAME AND ADDRESS NUMBER BALANCE BALANCE PAYMENT DEBTS Mt In addition to RTGAGE Is Rent/Mortgage . Tax & 109-:-\ $ list all other $ $ debts (for example, auto loans. credit $ cards, second mortgage, home $ assoc. dues. alimony, child $ support, child care, medical, $ utilities, auto insurance, IRS Is liabilities, etc.) $ Please use a separate line for 1$ $ Is each credit card and auto loan. ls $ 0- Attach other - sheets if UST AHY NAMES UNDER wHICH YOUR CREDIT AEFERENCES AND CREDIT HISTORY CAN BE CHECKED Is / '\. necessary. TOTALS $ 6 ASSETS Check box for Applicant/Other. List all assets and account 8 FINANCIAL INFORMATION These questions apply to both Applicant and Other. SHARE DRAFT OR CHECKING AMOUNT NAME AND ADDRESS OF DEPOSITORY I SHAAE ORAFT OA ~HECKING AMOUNT SAVI~AMUUNI $ NAME AND ADDRESS OF DEPOSITORY $ NAMt:: AND AUUHt::~S O~ DI:,.OSII UHY NAMt:: ANt) AOuHt:::s:s Ot' LJt:t'USII UHY SAVlOOS AMUUN I $ IF A ""YES" ANSWER IS GIVEN TO A QUESl1ON, EXPlAIN ON AN ATTACHED SHEET DO YOU HAVE ANY OUTSTANDING JUDGEMENTS? HAVE YOU EVER ALEC FOR BANKRUPTCY OR HAD A DEBT ADJUSTMENT PlAN CONFIRMED UNDER CHAPTER 13? HAVE YOU HAD PROPERTY FORECLOSED UPON OR REPOSSESSED IN THE LAST 7 YEARS? ARE YOU A PARTY IN A LAWSUIT? ARE YOU OTHER THAN A U.S. CITIZEN OR PERMANENT RESIDENT AUEN? IS YOUR INCOME UKEL Y TO OECUNE IN THE NEXT TWO YEARS? ARE YOU A COMAKER, CO-SIGNER OR GUARANTOR ON ANY LOAN NOT USTED ABOVE? FOR WHOM (Name of Others OblIgated on Loan): TO WHOM (Name of Creditor): APPUCANT YES NO ....c OTHER \; YES \NO .. . 9 SIGNATURES ~.. 10 CREDIT UNION INFORMATION If there are any important chan~s, you will notify us in writing immediately. You also agree to notify us of any change in your name, address or employment Within a reasonable time thereafter. You also promise that everything you have stated in this application is correct to the best of your kilowledge and that the above infoh'nation is a com lete listing of all your debts and obligations. You authorize the union to obtain credit reports in connection with this application for credit and for any update, renewal or extension of the credit received. If you request. the credit union will tell you the name and address of any credit 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 Stale Chartered Credit Unions insured by NCUA. 5/01 X s . OTHER OTHER DEBT RATIO o COUNTER OFFER WILL BE MADE, IF ACCEPTED, ADVANCE APPROVED DYES 0 NO IF YES, ATIACH ADDITIONAL SHEET AND DESCRIBE ~....... APPROVED S $ DATE LIMITS SIGNATURE UNE OF CREDIT o LQANOFACER ADVANCE APPROVED: 0 YEsD NO o CREDIT COMMITTEE OR OlliER OUTSIDE INFORMATION CONSIDEREO: REFERRED TOIREASON(S) FOR REFEARAL: DESCRIBE COUNTER OFFER: SPECIFIC REASON(5) FOR REJECTION: SIGNATUHt::::i; o LOAN OFFICEA X o CREDIT COMMITTEE X o ECOA NOTICE AND REASON FOR REJECTION SENT OR DEUVERED ON UAII: UAII: x X DATE DATE (DATE) BY (INITIALS) AST023 (LASER)6826LL age20F2 ~ ~" ."'-'>1'..~.""'" ,- ...,. SUSQUEHANNA VAllEY FEDERAL CREDIT UNION 1213SJa1" Ro.d ClmpHII.M 17011~12 (717)737-4152 IOANUNB. CREDIT AGREEMENT 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 fonm may delay processing - You will receive your copy of the Credit Agreement and insurance information IMPORTANT 1 CREDIT AGREEMENT AND TRUTH IN LENDING DISCLOSURE 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 (calied advances) under this Plan from time to time. The credit union, however, is not required to make advances to you under this Plan and can refuse a request for an advance at any time. The Addendum describes the different types of credit (called sub- accounts) avaiiable 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 the variable interest 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 CCUNA MUTUAL INSURANCE SOCIETY, 1 sao. 82, 84, 8S, 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 daily 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 federal 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 dweliings 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 default 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 insoivent, 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. 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 payment is demanded, you will continue (Continued) CREDIT UNION COPY BPA67A (LASERI8S49LL I Susquehanna Valley Federal .credi t Union 1 CREDIT AGREEMENT AND TRUTH IN LENDING DISCLOSURE Continued 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. 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 Pian 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 variable 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 It is important that you read all the provisions of the SIGNATURES Credit Agreement and Addendum thoroughly before cg)NT'S~~ <- \s h /D'\ Joate " 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 si9n 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 all 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 A9reement and by signing below, you agree to be bound by the terms of the agreement. X OTHER SIGNATURE DATE ..--0:> )~...--.: DATE 3 CREDIT UNION INFORMATION APPROVED LIMITS , , SIGNATURE UNE OF CREDIT ADVANCE APPROVED: 0 YES 0 NO OUTSIDE INFORMATION CONSIDERED: , OTHER OTHER DEBT RATIO o COUNTER OFFER WILL BE MADE, IF ACCEPTED. ADVANCE APPROVED DYES 0 NO IF YES, ATTACH ADDITIONAL SHEET AND DESCRIBE DATE o LOAN OFFICER o CREDIT COMMITTEE OR OTHER REFERRED TOIREASON(S} FOR REFERRAL: DESCRIBE COUNTER OFFER: SPECIFIC AEASON(S) FOR REJECTION: x DATE DATE SIGNATURES: o LOAN OFFICER o CREDIT COMMITTEE X o ECOA NOTICE AND REASON FOR REJECTION SENT OR DEUVEREO ON DATE DATE x x (OATEI BY (INITIALS) CREDIT UNION COPY BPA67A (LASERI6849Ll ~ SUSQUEHANNA vALLEY FEIlERAL CIlBlIT UIION 121Ssaa.....~ Camp" A\ 17011-8012 (117) 737~152 CREDIT 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" IOANUNIR. 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 Soci.ety 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 MUIUAL GROUP CUNA Mutuallnsun:mce Society P,O. Box 391 .5910 Mineral Point Road. Madison, WI 53701-0391 Phone: 8001937-2644 . 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. INSURED MEMBER DATE OF BIRTH ACCOUNT NUMBER DATE OF ISSUE OF CERTifICATE DATE OF BIRTH g -,)770 8155" ACCOUNT NUMBER SECONDARY BENEFICIARY (1f you desire to name onel .za JOINT INSURED ME BEA -4-0 ( " UNDER CREDIT LIFE AND DISABILITY, THE MAXIMUM ELIGIBILITY AGE FOR COVERAGE IS 65 YITH 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 PREMIUM SCHEDULE SEE SEPARATE RATE SCHEDULE ON THIS DATE. ARE YOU PHYSICALLY WORKING FOR A SALARY OR WAGES A MINIMUM OF 25 HOURS A WEEK? ARE YOU MAXIMUM AGE UNDER AGE....,QL? FOR INSURANCE NONE" MAXIMUM MONTHLY TOTAL DISABILITY BENEFIT $ 600.00 If you are totally disabled for more than benefit will begin with the 15th 14 days, then the disability day of disability. DATE ,.&..of DATE &-f.o- Of CREDIT LIFE INSURANCE YES NO CDVERAGE SELECTED COST PER $100 OF YOUR SINGLE CREDIT LIFE MONTHLY LOAN BALANCE $ .057 COST PER $100 OF YOUR JOINT CREDIT LIFE MONTHLY LOAN BALANCE $.099 ARE YOU MAXIMUM AGE UNDER AGE -2L? FOR INSURANCE NONE" MAXIMUM INSURABLE BALANCE PER LOAN ACCOUNT $ 30,000.00 DATE &-v-G) DATE x x DATE &r'u-cJ CREDIT UNION COPY BPA67AlLASER)6B49Ll @. , . SUSQUEHANNA "ALLEY FEDERAL CREDrr UNlDN 1213S1ateI-llA* ~~ CompH"'" 17011-80" ~ (7tn737-4152 IOANUNBt Advance Request Voucher and Security Agreement 1 MEMBER INFORMATION DATE 06/06/2001 MEMBER NAME ILASTI CUZA, NATHAN E MEMBER ACCOUNT NUMBER 8955-1 (FIRSTl (INITIAl) SOCIAL SECURITY NUMBER 610-05-7412 HOME TELEPHONE NUMBER (717)-744-4426 PURPQSEIlOAN SUBACCOUNT DESCRIPTION Used Auto ADDRESS DATE WANTED 707 SHERWOOD ROAD 06/0612001 YOU REOUEST THE FOLL.OWING ADVANCE SUBJECT TO THE TERMS AND CONDITIONS OF YOUR LO.A.NUNER CREDIT AGREEMENT , 15,300.00 CITY STATE ZIP CHECK BOX IF NEW ADDRESS OR PHONE NO. SECURITY OFFERED \IF ANYI Fully Title Secured NEW CUMBERLAND, PA 17070-1449 2 CHANGES SINCE LAST ADVANCE UST ALL DEBTS: {i.e. Rent, Mortgage. Auto, Credit Cards, Credit Union, Alimony, etc.} ATTACH ADDITIONAL SHEET IF NECESSARY PRESENT BALANCE MONTHLY PAYMENT MARITAL. AU, N OMPL.E I APPL YIN F A lNDM UAL UN E UREO CREOI UNLES YOU RE 10 RARE R LING UPON PROPERTY IN A COMMUNITY PROPERTY STATE tAZ, CA. 10, LA, NV, NM, TX, WA, WII. I Y U ARE WRING. NAM AND A N EMPL Y N W I I N EPARA TED DAT HI OFAS AVIATOR E.2 05/0312000 PHONE NO, NOTICE: YOU DON'T HAVE TO INCLUDE INCOME FROM CHILD SUPPORT, SEPARATE MAINTENANCE, OR AliMONY UNLESS YOU WANT THE CREDIT UNION TO CONSIDER IT, MONTHLY SALARY $ 1 ,302.28 SOURCE OF OTHER INCOME 3 SECURITY OFFERED IN ADDITION TO THE PlEDGE OF SHARES IN YOUR LOANLINER CREDIT AGREEMENT, THE FOllOWING PROPERTY SECURES THE ADVANCE: MODEL YEAR 10 NUMBER TYPf'- ............,... ,c;:ouu 1FAFPi'040YF~l8b~( I"Ut(O-- .._- ,,--- Sb<..C Pt-r ~~." ON q "0 lo~ PROPERTY VALUE ''-'" ~.lS,.1)!"D' _Be.. TIT tE SEetJRfIl PRIMARY USE OF PROPERTY: PURCHASE MONEY: YES 4 PAYMENT TERMS ARMING PLEDGE OF SHARES $ , KEY NO: LOCATION OF PROPERTY: ACCOUNT NO(S). OTHER tDESCRIBE} YOUR CREDIT UNION SHARES DAILY PERIODIC RATE ANNUAL PERCENTAGE RATE 6.95000 " OTHER CHARGES INTEREST RATE IS: OTHER CHARGES (DESCRIBE} , .00 VARIABLE $ .00 PREV. LOANLiNER BALANCe OTHER LOANS (THIS SUBACCOUNT) + $ N/A + $ N/A PMT. FREQUENCY TOTAL PMT. ALL ACCTS. LOAN liMIT .019041% " AMOUNT APPROVED , minus NEW BALANCE , 15,300.00 CURRENT PAYMENT + , OA TE DUE NIA 15,300.00 PMT. AFTER ADVANCE DATE DUE =, 15,300_00 equals REMAINING liMIT , NIA NIA 302.58 07/05/2001 M Your term will be approximately 60 payments, which may be more or less, depending on whether you prepay, have late payments, or insurance is added, etc. 5 SIGNATURES SIGN BELOW BY SIGNING BELOW OR UNDER THE ENDORSEMENT ON THE ADVANCE PROCEEDS CHECK YOU AGREE: . TO MAKE AND BE BOUND BY THE TERMS OF THE SECURITY AGREEMENT. . THAT EVERYTHING IN SECTION 21S A COMPLETE USTING OF All. YOUR DEBTS AND OBUGATIONS. . THAT THE CREDIT UNION WILL Ray ON THE INFORMATION IN SECTION 2 TO MAKE A DECISION ON THIS ADVANCE. . TO MAKE PAYMENTS AS DISCLOSED IN SECTION 4. . TO THE TEAMlS) DISCLOSED BELOW IF ANY ONE OR MORE ITEMISI ARE CHECKED. IF YOU ARE NOT A BORROWER BUT AN OWNER OF THE COLlATERAL, SIGN BELOW AND CHECK THE APPUCABLE BOX. YOU ARE PLEDGING SHARES FOR THE AMOUNT HE CHANGE IN THE TERM(SJ OF YOUR LOANLiNER SHOWN IN THE SECURITY OFFERED SECTION GREEMENT MARKED WITH A STAR{4J. SIGNATURE OWNER OF COLLATERAL tOther than a Borrower) DATE (SEALI (SEALI E QATE X 6 FOR CREDIT UNION USE ONLY (SEAL) x (SEAU REQUESTED: BY MAIL BY PHONE TRANSACTION: THRU OFFICE X FIRST ADVANCE DINSURANCE INTERNAllY BY CU SUBSEQuENT ADVANCE CHANGE MEMBER PAYS PREMIUM FOR: CREDIT DISABILITY DJOINT CREDIT LIFE SINGLE CREDIT LIFE CHECK NUMBER DEPOSIT ACCT. NUMBER PlAN/SUBACCOUNT NO. 8955 LOAN NUMBER ~ CUNA MUTUAL INSURANCE SOCIETY, 1980, B2. 84. 86. 89, ALL RIGHTS RESERVED C':RFOTT tlNTON r.OP'r' PROCESSED BY LNS VST025 [LASERl 6826l'.. CONTRACT NUMBER 037-1661-8 REFERENCE NUMBER veh.895501 BRANCH NUMBER Susquehanna Valley Federal Credit Union Date 06/00;C:J~, NATHAN E CUZA 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 agreement in the signature area or under the statement referring to this agreement which is 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 also includes any replacements for the property which you buy within 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. 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 advance. It also secures any other advances you have now or receive in the future under the LOAN LINER 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 (..), 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 own 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 not 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 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 -- Until the advance has been paid off, you prom ise 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. (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 all 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 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 X SIGNATURE X DATE DATE If you cancel your insurance and get a refund, the credit union has a right to the refund. If the property is lost or damaged. the credit union can use the insurance settlement to repair the property or apply it towards what you owe. You authorize the credit union to indorse 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 on the property when due or keep it insured, 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 LOANlINER Credit Agreement. if you are pledging property, but have not signed the LOANlINER 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 the 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. A fter 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 permitted under state law or awarded under Section S06Ib) of the Bankruptcy Code. The rest of the sale money will be applied to what you owe under the LOAN LINER 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. DElA Y 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 heirs or legal representatives. If the credit union changes the terms of the LOANUNER 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 -- APPLIES ONLY WHEN A MOTOR VEHICLE IS PURCHASED NOTICE: THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE 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 PAY THE DIFFERENCE. THE PROPERTY DESCRIPTION ON PAGE 1 IS PART OF THIS AGREEMENT. NOTICE: SIGN THIS AGREEMENT ON PAGE 1. CREDIT UNION COPY VST025 (LASERI 6828Ll ["", "',i'~,.\l:l' :.":IQ' SUSQUEHANNA ~"""-- VALLEY FED.ERAL CREDIT Statement of Account UN ION Date: June 4, 2003 Maker: Nathan Cuza Comaker: NONE Home Address: -707 Sherwood Road New Cumberland, P A 17070 Home Phone: 717-774-4426 Our Account Number: 8955-1 and 8955-2 Maker Social Security # 6 J 0-05-7412 Comaker Social Security: None Principal Amount Owed: Interest Owed: Penalty (20 % ofPrincipal& Interest): Total Amount Claimed: ~ $8,747.86 $827.53 $1,929.70 $11,505.09 i l' ,I.." ' 3850 HARTZDALE DRIVE. CAMP HILL, PA 17011-7809 LOCAL: (717) 737-4152 TOLL FREE: (800) 948-1454 PAX: (717) 737-0589 ~ ~ SUSQUEHANNA VALLEY FEDERAL CREDIT UNION 38SO Har1zdaIe Drive Camp HU. PA 17011.7809 (717) 737-4152 K>>.NUNR ~..,.",."",.,.,.,.,..""""",.",.""" ... .... t .................-.-...........,....._'..............;.;.;'.:':';.;:,:::::,:;:::.;.:.,. BORROWER 1 NAME NATHAN E CUZA ;;'('{:':;' BORROWER:iNiiORMATioi\i ACCOUNT NUMBER 8955-2 BORROWER 1 ADDRESS 707 SHERI<<lOO ROAO NEW CUMBERLAND, PA 17070-1449 BORROWER 2 NAME HOME TELEPHONE NUMBeR (717)-744-4426 SOCiAl SECURITY NUMBER 610-05'7412 AMOUNT REQUESTED $ 9,990.00 PURPOSE: USed Auto DATE 12/05(2001 ACCOUNT NUMBER DEPOSIT CHECK IN ACCOUNT NUMBER/OTHER: BORROWER 2 ADDRESS SOCIAL SECUAITY NUMBER CHECK PAYABLE TO: REPAYMENT METHOD: Cash BORROWER 1 EMPLOYER NAME OFAS BORROWER 2 EMPLOYER NAME WORK TELEPHONE NUMBER DATE HIRED 05/0312000 DATE HIRED GROSS MONTHLY SALARY '1,302.28 GROSS MONTHLY SALARY . OTHER MONTHLY INCOME .231.57 """"":,:,:::("",,,:,,,:,:,(":',:'(::;::';':"::i'".1 WORK TELEPHONE NUMBER NOTICE: YOU DON'T HAVE TO INCLUDE INCOME FROM CHILD SUPPORT, SEPARATE MAINTENANCE, OR AUMONY UNLESS YOU WANT THE CREDIT UNION TO CONSIDER IT. !,t'"".:,,,::,,,,,,,,,, ..................................-.......'.'...:.:,:;,.'. ..-....-.-...-...'.:.,::::'~:::<:.,. .-.-.-.....:.:<-,.:::::..... :.:.:.,::,::::,::.::,::::,:::::,:::.:::,:::::;::::::::"::':'::":'::":"':':::"';::.,::.,,:::::::::,,:::,,,:::::,~ .,.:-:.:.:<. ""." SOURCE OF OTHER INCOME ZOO ZONE ;;';;;l':;::::mWAA'tYOQ;(lW'E){ ......".",.,.",.""",;;;;;;::;;;;,.,........ PRESENT BALANCE MONTHLY PAYMENT CURRENT INTEREST RATE LIST ALL DEBTS OTHER THAN TO THIS CREDIT UNION (Attach additional sheet{s.llf necessary.l AAFES SUSQUEHANNA VALLEY F. C. U. CAPITAL ONE SEARS 906.00 . 39.00 14,229.53 . 302.58 310.00 30.00 . 570.00 . 13.00 })"';:';';:)SUIlSEQOaliT'ettdtioi\iI;OI:l\ioliul\ict:AilYPA5lMEN't'PRO'ti!1CTIO1\1: . '" '" '" kt:)':",: You can now voluntarily elect to become insured with the coverage(s) shown below. In order tor coverage to become effective you must meet all eligibility requirements stated in the Credit Insurance Application/Schedule. A statement of insurability must be completed if you are adding coverage more than 30 days after the date of your advance. Details of this insurance coverage are included in the Insurance Certificate which you received with your Credit Agreement. Ask us if you need a copy of the Insurance Certificate. You agree to the terms of the insurance election checked below and you authorize us to add the charges for the insurance to your outstanding balance each month. Your payment amount will increase or you will be required to make additional payments. Coverage election applies to the entire balance on this subaccount. Insurance rates are subject to change. ~I YOU ELECT THE FOllOWING: NO Single Credit Disabil i ty NO NO HO Single Credit Life Joint Credit Life COST PER $1000F YOUR MONTHLY lOAN BALANCE SEE SEPARATE RATE SCHEDULE .057 .099 NAME OF INSURED(SI > DAILY PERIODIC RATE ~ .021233% % o MOUNT ADVANCED ~ .. 9,990.00 :> Your term will be approximately 36 payments, which may be more or less, depending on whether you prepay, have Z late payments, or insurance is added, etc.. o Z ::> ..... THE ADVANCE IS SECURED BY YOUR SHARES, AU PROPERTY SECURING OTHER PLAN ADVANCES AND lOANS RECEIVED IN THE PAST OR IN THE FUTURE, AND THE FOLLOWING o PROPERTY/MOOEl YEAR 1.0. NUMBER VALUE KEY NUMBER ~ ....Lor un. ...n..n._I!! r1"TI C ~5:r.IIRFn () a: o u. ANNUAL PERCENTAGE RATE 7.75000 '" INTEREST RATE IS: OTHER FEES IAmouot aod Description) Fixed . N/A NEW BALANCE THIS SUBACCOUNT . 9,990.00 PAYMENT AMOUNT '314.56 DATE DUE 0211512002 PAYMENT FREQUENCY Month l y LINE OF CREDIT LIMIT . REMAINING LIMIT . OF Xctf ......M ....i:::': ..~eliE ":"",,,,::' ........:s ...~RPfllio c 19Q1i ...:l)t.:b 1'rr Au.c.n 6"-f 1 IL~77Rv~~~~lJ1OP ~ Iti/OL. "1 1nn 00 I . . . PLEDGE OF SHARES AND/OR DEPOSITS . ACCOUNT NUMBER PLEDGE OF SHARES AND/OR DEPOSITS $; ACCOUNT NUMBER By signfng below, by endomng the proceeds check or by using the amount advanced and depoalted into your share/share draft account you agree: ,. To make and be bound by the terms of this Security Agreement inctuding the CI'08S coftateral clltUse: ~...J!I. above information '- true and correct and the Credit Union wil rety on that information and your credit report to make a credit decision: 3. Tctmake payments.. disclosed ebove in eccordllnce with the t8fml; of your Aen. 11x.;,/~ C_ BORROWER 1 SIGNATURE (SEAW .tIAi'/11 :' DATE (SEAW II DATE (SEAU Ilx SIGNATURE DOWNER OF COLLATERAL IOttler than a Borrower) DATE ISEAU DATE OCUNA MUTUAL GROUP, 1980, 82,84,86,89,98,99,2000, ALL RIGHTS RESERVED VXX064 {LASER) 27860 Susquehanna Valley Federal Credit Union NATHAN E CUZA SECURITY AGREEMENT In this agreement all references to "credit union," "we," "our" or "us" mean the credit union whose name appears on this agreement and anyone to whom the credit union assigns or transfers this agreement. All references to "you," "your" or "borrower" mean each person who signs this agreement. You have previously executed an open-end agreement ("Plan") with the credit union (loan number specified above) under which you may receive credit from time to time. If you are required to provide security in connection with a particular extension of credit ("Advance") the property that is security will be described on a receipt, voucher or other document that you receive at the time of the Advance. That property description and the terms below together constitute the Security Agreement. Some of the provisions of this agreement apply only if the credit union is state chartered. A credit union is state chartered if its name does not include the words "Federal Credit Union" or "Feu." 1. THE SECURITY FOR THE PLAN -- You give us what is known as a security interest in all property described in any receipt, voucher or other document you receive for the Advance. 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 also includes any replacements for the property which you buy within 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 vou have on the property. If the value of the property declines, you promise to give us more property as security if asked to do so. 2. 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 Plan and any other amounts or loans, including any credit card loan, you owe us for any reason now or in the future. except any loan secured by your principal residence. If the property is household goods as defined by the Federal Trade Commission Credit Practices Rule, the property will secure only the Advance and not other amounts you owe. 3. OWNERSHIP OF THE PROPERTY -, You promise that vou own the property you give as security or if the 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 us 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 other security interest or lien to attach to the property either by your actions or by operation of law. 4. PROTECTING THE SECURITY INTEREST - If your state issues a title for the property, you promise to have our security interest shown on the title. We may have to file what is called a financing statement to protect our 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 we think is necessary to protect our security interest in the property. You promise to pay all costs, including but not limited to any attorney fees, we incur in protecting our security interest and rights in the property, to the extent permitted by applicable law. 5. USE OF PROPERTY -- Until the Advance has been paid oft, you promise you will: (t) Use the property carefully and keep it in good repair. (2) Obtain our written permission before making major changes to the property or changing the address where the property is kept. (3) Inform us in writing before changing your address. (4) Allow us to inspect the property. (5) Promptlv notifv us if the property is damaged, stolen or abused. (6) Not use the property for any unlawful purpose. 6. CONSUMERS' CLAIMS AND DEFENSES NOTICE -- The following paragraph applies only when the box on page one is checked. C CUNA MUTUAL GROUP, 1980.82,84, Be, 89. 98, 99. 2000, All RIGHTS RESERVED Date 12/05/2001 ICMIJNIR. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. 7. PROPERTY INSURANCE. TAXES AND FEES -- You must maintain property insurance on all property that you give as security under the Plan. You may purchase the property insurance from anyone you choose who is acceptable to the Credit Union. The amount and coverage of the property insurance must be acceptable to us. 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 us and to deliver the policy or proof of coverage to us if asked to do so. If you cancel your insurance and get a refund, we have a right to the refund. If the property is lost or damaged, we can use the insurance ,settlement to repair the property or apply it towards what you owe. You authorize us to endorse any draft or check which may be payable to you in order for us to collect any refund or benefits due under your insurance policy. You also prom ise to pay all taxes and fees (like registration fees) due on the property. If you do not pay the taxes or fees on the property when due or keep it insured, we may pay these obligations, but we are not required to do so. Any money we spend 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. We may receive payments in connection with the insurance from a company which provides the insurance. We may monitor our loans for the purpose of determining whether you and other borrowers have complied with the insurance requirements of our loan agreements or may engage others to do so. The insurance charge added to the Advance may include (t) the insurance company's payments to us and (2) the cost of determining compliance with the insurance requirements. If we add amounts for taxes, fees or insurance to the unpaid balance of the Advance, we may increase your payments to pay the amount added within the term of the insurance or approximate term of the Advance. 8. NOTICE - If you do not purchase the required property insurance, the insurance we may purchase and charge you for will cover only our interest in the property. The insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. 9. DEFAULT -- Ths fo/fowing pilragraph appliss only to Wisconsin borrowsrs. You will be in default if breaking any promise you make under this agreement materially impairs the condition, value, or protection of or our rights in any property you give as security. You will also be in default under this agreement if you are in default under the Plan. Ths foffowing pilragraph appliss to aD othsr borrowsrs: 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 Plan. 10. WHAT HAPPENS IF YOU ARE IN DEFAULT -- Ths foffowing paragraph appliss to borrowers in Colorado, Diamct of Cofumbia, Iowa, Kansas, Mains, Massachusetts, Missouti, Nebraska, West Virginia and stats charts"'" cradit unions Isnding to South Carolina borrowers. When you are in default and after expiration of any right you have under applicable state law to cure your default, we can demand immediate payment of the entire unpaid balance under the Plan without giving you advance notice. Ths following pIIragrsph applies to borrowers in allothsr stlltes and fsdsrafly chsrtBred credit unions fsnding 10 South Carolina borrowers. When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of CREDIT UNION COPY VXX064 IlASERJ 27860 susqlJehanna; VaL Ley, Federa,L Credit Union intent to accelerate and notice ot acceleration. The foHowing fN1ragraphs apply to alf bolrOwars. You agree the Credit Union has the right to take possession of the property given as security under the Plan. without judicial process, if this can be done without breach of the peace. If we ask, you promise to deliver the property at a time and place we choose. We will not be responsible for any other property not covered by the agreement that you leave inside property or that is attached to the property. We will try to return that property to you or make it available to you to claim. After we have possession of the property. we can sell it and applv the money to any amounts you owe us. We will give you notice ot anv public sale or the date after which a private sale will be held. Our expenses for taking possession of and selling the property will be deducted from the money received from the sale. Those costs may inciude the cost of storing the propertv, preparing it for sale and attorney's tees to the extent permitted under state law or awarded under the Bankruptcy Code. The rest of the sale money will be applied to what vou owe under the Plan. 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. or, if applicable, at the default rate Date 12/05/2001 disclo!.ed on the Addendum, until that amount has been paid. 11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN __ We can delay enforcing any of our rights under this agreement anv number of times without losing the ability to exercise our rights later. We can enforce this agreement against your heirs or legal representatives. If we change the terms of the Plan, you agree that this agreement will continue to protect us. 12. CONTINUED EFFECTIVENESS -- If any part of this agreement is determined by a court to be unenforceable, the rest will remain in effect. 13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSEO AND SOLD TO SOMEONE ELSE. AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE. YOU MAY HAVE TO PAY THE DIFFERENCE. 14. NOTICE FOR ARIZONA OWNERS OF PROPERTY -. It is unlawful for you to fail to return a motor vehicle that is subject to a security interest, within thirty days after you have received notice of default. The notice will be mailed to the address you gave us. It is your responsibility to notifv us if your address changes. The maximum penalty for unlawful failure to return a motor vehicle is one year in prison and/or a fine of $150,000. THE PROPERTY DESCRIPTION ON PAGE ONE IS PART OF THIS AGREEMENT. NOTICE: SIGN THIS AGREEMENT ON PAGE ONE. I.,i}::':"'....... ... .. . ....,., .......1 REQUESTED: MEMBER PAYS PREMIUM FOR: . .. . ........................,',.",".",.""",'.'",,':"':""':':}}:::"'::iFtiftCREDIT.ui\iioi\i.usit,,'oilltM'i'}::'" DATE APPROVED LIMITS: SIGNATURE $ X APPROVED DENIED IAdverse Action Notice Senti 12/0512001 LOAN OFFICER COMMENTS: SIGNATURES: X iO CUNA MUTUAL GROUP, 19BO, 82, 84, 86, 89, 98, 99. 2000. ALL RIGHTS RESERVED CHECK NUMBER: PLAN/SUBACCOUNT NO.: LINE OF CREDIT OTHER BRANCH NUMBER: PROCESSED BY: OTHER LNS DEBT RATIOISCQRE 8EFORE AFTER 45.58100 X $ $ $ x DATE DATE CREDIT UNION COPY VXX084 !lASER} 27860 Susquehanna Valley Federal Credit Union 1213 Slate Hill Road Camp Hill, PA 17011-8035 LOANLINER INTEREST RATES EFFla<tJ1VE NOV'F/tmm~ AWl~ Description Term Share Secured Vehicles: Model Years 1998-Present 1996-1997 1994-1995 Signature/ Unsecured Lines of Credit: Shared Secured Unsecured , 1 - 24 Months 25 - 60 Months 61 - 96 Months 0.0135616 0.0143836 0.0171233 4.95% 5.25% 6.25% The amount and due date of your payment will be established at the time of each advance and will be disclosed on the voucher accompanying the advance. Your minimum monthly loan payment will never be less than $20.00. 1 - 24 Months 0.0157534 5.75% 25 - 60 Months 0.0169863 6.20% 61 -72 Months 0.0190411 6.95% 1 - 48 Months 0.0212329 7.75% 1 - 36 Months 0.0212329 7.75% 1 - 36 Months 0.0300000 10.95% 37- 60 Months 0.0327397 11.95% 0.0143836 0.0327397 5.25% 11.95% Other Charges: CoUection Costs: The borrower(s) agree to pay all collection costs, including court costs and attorney's fees as permitted by law. Late Fees: All payments received more than 14 days past their due date will be charged a $10 late fee. NSF Charge: You will be charged a $15 fee if your payment is made with a check drawn on an account with insufficient funds. Filing Fees: !fa security interest is taken you will be charged the fee the particular government agency levies to perfect that security interest. CUNA HUTUAl GROOP PENNSYLVANIA HONTHLY RENEWABLE CREDIT DlSASILITf DISClOSURE RATES PER $100 OF COVERAGE PER IIlNTIl 25 26 2J 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 lERH 1 2 3 ~ 23 24 RATE .,""""" .1332 .1304 .1273 .1245 .1219 .1199 .1180 .1155 .1131 .1113 .1096 .1080 .1064 .1046 .1026 .1016 .0999 .09B7 .0974 .0963 .0951 .0939 .0927 .0917 .0909 .0896 .0889 .0877 .0869 .0860 .0854 .0844 .0834 .083(J .0821 .0B12 .0808 .0799 lERH 61 62 63 llZ B3 84 85 86 B7 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 lOB 109 110 111 112 113 114 115 116 117 118 119 120 MONTHLY RENEW ABLE CREDIT RATE .0791 .0788 .0780 .0b87 .0683 .068D DISABILITY DISCLOSURE FORM me ll1~' month of your loan is $2,400 x .1304 x .01, or $3.13. After you have made your first $100 periodic loan payment, the gross balance of your loan would then be $2,300 (23 x $100) and our charge to you for your insurance for the second month would be $2,300 x .1304 x .01, or $3.00, etc. The charges we actually make to you for your insurance are shown in your periodic statement which you receive from the Credit Union. .0676 .0672 .0669 .0666 .0662 .0659 .0656 .0654 .0649 .0645 .0642 .0640 .0637 .0636 .0631 .0628 .0626 .0624 .0621 .0617 .0614 .0613 .0609 .0608 .0605 .0603 .0602 .0599 .0597 .0595 .0593 .0591 .0589 .0587 .0583 .0581 Please remember: Whenever you add a new advance to your loan, you recast the loan and a new projected loan term is determined according to your Loan Pian. Please note also that if the amount of your periodic loan payment is greater than the maximum benefit per month shown in the Insurance Schedule of your Certificate of Insurance, our charge to you is based on the sum of the maximum benefits per month times the number of periodic loan payments remaining to be paid on your loan. For example, if your periodic loan payment is $400 and the maximum benefit per month is $300 and you have 24 payments remaining to be paid, the gross balance of your loan for purposes of this insurance would be $7,200 (not $9,600) and our charge to you for insurance the first month would be $9.39. ($7,200 x .1304 x .01). SUSQUEHANNA ~"""--- VALLEY F E rsrn~ntem or rfc&l?n~ TUN ION Date: June 4, 2003 Maker: Nathan Cuza Comaker: NONE Home Address: -707 Sherwood Road New Cumberland, PA 17070 Home Phone: 717-774-4426 Our Account Number: 8955-1 and 8955-2 Maker Social Security # 610-05-7412 Comaker Social Security: None Principal Amount Owed: Interest Owed: Penalty (20 % of Principal& Interest): Total Amount Claimed: @; $5,809.00 $1,056.69 $1,323.03 $8,188.72 3850 HARTZDALE DRIVE. CAMP HILL, PA 17011-7809 LOCAL: (717) 737-4152 TOLL FREE: (800) 948-1454 FAX: (717) 737-0589 ..1/ : ;!~ @; JUN-10-2003 11:43 SUSQ. VALLEY Feu .......... .- .....-.......... .",-,. - ..-.-,... ,- VER I'FIC,,"',TI ON 7174412022 P.02/02 1, SUSAN J. BRUBAKER, LOANS/COLLECTION MANAGER of SUSQUEHANNA VAlLEY FEDERAL CREDIT UNION (formerly known Ai West Shore Teachers Feperal Credit Union), verify that the statcmenti made in the , aforcsolng doo;wnent are true and correct. [undmtand that raise statements herein are made subject to the penalties of 18 PL C. S. g4!104, relating to unsworn falsification to authoritiCli Dated: ~)O /tJ3 F:IUSBRIST ACYlCCP COlllPIIlIlllIW0RKl29$34.wp4: IOJu1I03 SUSQUEHANNA VALLEY FEDERAL CREDIT tlNION '< r, LoanlllCollectlon Manager 28900 TOTAL P.02 ~p~ \'l~ ~ ~ CIrt -.., ~ ~i'~ lrr ~ p:.. J- ~>~ 4'" .~-) \ c; .. ,-8 ..-~~~~ SHERIFF'S RETURN - U. S. CERTIFIED MAIL CASE NO: 2003-02736 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL CRE VS. CUZA NATHAN E R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,CUZA NATHAN E by United States Certified Mail postage prepaid, on the 11th day of June ,2003 at 0000:00 HOURS, at 5427 PINE STREET OMAHA, NE 68106-2348 , a true and attested copy of the attached COMPLAINT & NOTICE Together with The returned receipt card was signed by 00/00/0000 on Additional Comments: RETURNED TO SHERIFF AS "UNCLAIMED" Docketing Cert Mail Affidavit Surcharge 18.00 5.11 .00 10.00 .00 33.11 ~o answ. : ~~~/~/~;....--? .~ / R. Thom~;~Kl~ Sheriff of Cumberland County Sheriff's Costs: Paid by KNUPP KODAK IMBLUM on 07/09/2003 . Sworn and sUbscrtJ;d to before this /D ~ day of dlln3 A.D. me ~ )'-'1.UL- Q. )v..JP,o.J, AOd&:" "-1?:r'othonotary r -, ,I " -';;''';,1''1"""=.,,,,_ ~~- ~ b: ~y " /' ~ 00 ~ 0 tif.....=c 10 0- n' Z - 0 "'" -oc:CD.-<1. ~::>OO :;:J~"""" ~~...(') ZCl>::rC ll>Cf)CIlS: 2..0 enOl ll>c::rm ..... ~ C'D :0 -Jm...r ~' .~ w.." 0 c: --' ~ 0 0 I1.J t; I1.J -"" - .... 3 0 rn 0 0 0 0 --' '" In 0 .,.. I1.J --' I1.J W . l .0) :....., n~ d 1__"V"."'. tr < . -:r- .--...- d ~d3 '" M · -!~~ =.:~ !Ath:i' I : "'" rl J ;. i~ "'............. .~t""".: ",. ,.., " l;....- . '- SUSQUEHANNA VALLEY FEDERAL CREDIT UNION formerly known as WEST SHORE TEACHERS FEDERAL CREDIT UNION In the Court of COMMON PLEAS of CUMBERLAND County, Pennsylvania v. NO. 2003-02736 NATHAN E. CUZA CIVIL DIVISION - LAW Defendant(s) PRAECIPE TO THE PROTHONOTARY: Please file the attached Affidavit For Service to the above term and number. TO CUMBERLAND County Prothonotary Dated: September 2. 2003 ~ , Robert D. Kodak Attorney 1.0. No. 18041 -. Attorney for Plaintiff ~------ AFFIDAVIT FOR SERVICE STATE OF NEBRASKA) ) SS COUNTY OF DOUGLAS) INDEX: 963716 I, THE UNDERSIGNED, BEING FIRST DULY SWORN, ON OATH DEPOSE AND STATE THAT I AM OVER THE AGE OF 18 YEARS, AND A RESIDENT AND A DESIGNATED AGENT OF THE SHERIFF OF DOUGLAS COUNTY, NEBRASKA RECEIVED THIS WRIT ON AUGUST 8, 2003 AND THE SAME IS liEREBY RETURNED WITHOUT SERVICE AS AFTER DILIGENT SEARCH AND INQUIRY THE WITHIN NAMED NATHAN E. CUZA WAS NOT FOUND IN DOUGLAS COUNTY, NEBRASKA. SUBJECT DOES NOT LIVE AT ADDRESS GIVEN FOR SERVICE PER STEPMOTHER WHO STATES SUBJECT LIVES AT 717 SHERWOOD LANE, CUMBERLAND, PENNSYLVANIA c~fV' OF THE SHERIFF SUBSCRIBED TO AND SWORN BEFORE ME ON AUGUST 11, 2003 "'1II1MY .SIIIIaI NeInslla CNII E. CHIllSTlANsEN DImL ~ Ald2ll, 2llO7 FEES $ $ 50.00 PAID TOTAL 50.00 PAID """'~ G.'"", ,nil91,,2.YAATOlIJNaIIIl \ V.3."'A::aIRH:).!l~ .~re: .~\ lrQA .q13 ,mm03'" , -.. (") c: ?:: '""Or"'" 52 fJ5 t5~':_" ;:s' :<c. ~,. Lr-.~ j3: ,-,J C. 2: ~ r;,> r::- eo .~, J""... a "-') U) r.." -0 I W c -" -, '.-;-n .. "t'r" :i() ,.....,.. 'I~ ,,--~ ( ... .:.5r'rt ::;.-.; .> '::0 ~~ v :-.i: SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION formerly known as WEST SHORE TEACHERS FEDERAL CREDIT UNION Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003-02736 NATHAN E. CUZA Defendant( s) : CIVIL DIVISION LAW PRAECIPE TO REINSTATE COMI)LAINT TO THE PROTHONOTARY: Please reinstate the Complaint filed to the above term and number and forward same to the Sheriff for service upon Defendant at: 111 Bridge Street, Apt. 2, New Cumberland, P A 17070 OR 707 Sherwood Road, New Cumberland, P A 17070 TO CUMBERLAND County Prothonotary g~Z~ Robert D. Kodak Attorney for Plaintiff Attorney I.D. No. 18041 Dated: Seotember 4. 2003 0 0 C) C (--.: I -:;;~ (/) -0 ,-" P, I QJ ~. "U ~:; ~:'- I r-il 65 t~ : " u:> --:;; ~',; r:) ~C' -0 ~" -r, ~~ (-~ :.:t'i: -',") .' (os ;p:L' (...) ,jiTl 'c 2...: .:,n :,-:~ -, ~ -< en SHERIFF'S RETURN - REGULAR CASE NO: 2003-02736 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL CRE VS CUZA NATHAN E RONALD HOOVER , Sheriff or Deputy Sheriff of cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE CUZA NATHAN E was served upon the DEFENDANT , at 0920:00 HOURS, on the 11th day of September, 2003 at 207 LYNNDALE MECHANICSBURG, PA 17055-2348 NATHAN E. CUZA by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.90 .00 10.00 .00 34.90 Sworn and Subscribed to before me this JI, ~ day of J,17_1""".;2~ A. D. ~ . --- co O.~ <PI othonotary , So Answers: r;;V~~ R. Thomas Kline 09/12/2003 KNUPP KODAK IMBLUM By: ~~ Deputy Sheriff SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN 1HE COURT OF COMMON PLEAS formerly known as WEST SHORE 1EACHERS FEDERAL : CUMBERLAND COUNTY, PENNSYL VANIA CREDIT UNION Plaintiff v. : NO. 2003..()2736 NATHANE. CUZA : CIVIL DIVISION . LAW Defendant TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) NATHAN E. CUZA, named for failure to file within the required time an Answer to the Complaint in the above-<Jllptioned case and assess the Plaintiff's dan1ages as follows: Amount claimed in plaintiff's Complaint $19,693.81 Interest from June 5, 2003 at the legal rate of 6% per annum $467.73 Total $20,161.54 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant( s) and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached. By Robert D. Kodak, Attorney for Plaintiff DATED: Judgment entered and damages assessed as above. f3-A/7~J~_~ _ Prothonotary U Of Counsel Mark A. Mateya LAW OFFICES OF KNUPP, KODAK & IMBlUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET F It E POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 717/238-7158 email: kki.law@verizon.net October 6, 2003 C 0 D;9~;;'~~PP IttMit H. Maurer (1923-1998) Robert L. Knupp Robert D. Kodak Gary J. Imblum NATHAN E CUZA 707 SHERWOOD ROAD NEW CUMBERLAND PA 17070-1449 RE: Susquehanna Valley Federal Credit Union fka West Shore Teachers Federal Credit Union VS: Nathan E. Cuza No. 2003-02736, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 29534 Dear Mr. Cuza: In accordance with Pennsylvania Rules of Civil Procedure 237.1 (a)(2), 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 to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak, Esq. THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDKlkqb enclosure cc: SUSAN J BRUBAKER LOANS/COLL MGR SUSQUEHANNA VALLEY FEDERAL CREDIT UNION 3850 HARTZDALE DRIVE CAMP HILL PA 17011 #8955-1 #8955-2 filE COpy 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. 2003-02736 NATHANE. CUZA . CIVIL DIVISION - LAW Defendant IMPORTANT NOTICE TO: NATHAN E. CUZA . Defendant(s) DATE OF NOTICE: OCTOBER 6. 2003 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITIDN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIllS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HlRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTHAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LffiERTY AVENUE CARLISLEPA 17013 (717) 249-3166 W .tQ. ~i ~ -c () () ~ co 0 ~. c..... "~n ~ -u .. ~ 0 :-t ~ (Bl"P C-) J" ,1 p:: m --I "'i= W ~~ N . ~fn ~ -.0 tv 0'';; ,;'~iZ ~ .. -- "< . ~ () J KC~ -0 '.-.'n ~ ~Q ::J: ".-.: l"5 EJ:' :;;:.C; t:? ~'5f"n c: -I 'f--.. -7 ""'",.. ~ ::> ~ C::> SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS fonnerly known as WEST SHORE TEACHERS FEDERAL : CUMBERLAND COUN1Y, PENNSYL VANIA CREDIT UNION Plaintiff v. : NO. 2003..Q2736 NATHAN E. CUZA : CIVIL DIVISION - LAW Defendant To NATHAN E. CUZA , Defendant(s) You are hereby notified that on 0ri .JP (Judgment) has been entered against you in the above-captioned case. , 20aj the following Judgment entered in the amount of $20.161.54. .~ (/J DATE: (')('+ ;)f I .:u-Ja..:~ r?t..{fl :i; ) 12.. ~_J Prothonotary U I hereby certifY that the name and address of the proper person(s) to receive this notice is: NATHAN E. CUZA 707 SHERWOOD ROAD NEW CUMBERLAND PA 17070-1449 AI NATHAN E. CUZA.. Defendido/a Defendidoslas Por este medio se Ie esta notificando que el de del 20 ~ el/la siguiente(Fallo) ha sido anotado en contra suya en el case mencionado en el epigrafe. FECHA: Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: NATHAN E. CUZA 707 SHERWOOD ROAD NEW CUMBERLAND PA 17070-1449 Abogado del Demandante .' PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 SUSOUEHANNA VALLEY FEDERAL CREDIT UNION FIKIA WEST SHORE TEACHERS F. C. U. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 Plaintiff No. 2003-02736 Term 20~ vs Amount due .20.161.54 NATHAN E. CUZA InterestFROM DATE OF JUDG. 110/28/03) 707 SHERWOOD ROAD NEW CUMBERLAND PA 17070-1449 Atty's (.'omm. . 1.008.08 and CostsTO BE DETERMINED. Defendant Is) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of ~~ county, Pennsylvania: (2) against NATHAN E. CU~A (3) and against Defendant (s) Garnishee (s), (4) and index this writ (a) against NATHAN E. CUZA Defendant(s) and (b) against Garnishee (s) , as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as fallows: . (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) (5) Exemption has (not) been waived. -LXSTBD AIlDJlBSS. LBVY UPON ALL Pl:RSODL PRO~ or UOVl!:-LXSTBD DBJ'BHDAll'J! (S) Dated 11/4/03 Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Attorney Far Plaintiff(s) '(~)~Ol( aTn~ aas 'pa~1sap 51 suapuad slT e se 5ur:capU1 pue patpe~~e s1 aaqs1u.Ie5 aq=l 10 aumu aq:t U1 h=lJado::rd TeaJ 11 AlUO pa~aTdwoo aq PTnoqs (q) (~) 4de.:rce.:red . (q)vOIE aTn~ aas 'A.1e~ouoq~o::rd aq~ Aq A~unoo :teq~ UT aSJnOO JO se paJ1nbsJ Sl 5uTxapuT A~unoo Jaq~oue 0=1 sanss1 ~1JM a4~ uaqM "(e)vOI( atn~ Aq paz1::roq~ne SI2 pa.rTsap ST 'aoue.:rnssT 10 A=l-uno:J a4=l uT sUOT=l-n::mxa aq=l 10 cUTxapuT JT Atuo pa::;.atdUlo:J aq PtnOl.~s (12) (v) qdl2Jce.:red . (:n:.:rM a4=l- ur papntOur aq o:t s1 aaqsTUJ125 pauwu Eo' Ul hTuO pa:taTdwoo aq ptnoqs aAoqe) {EJ qdl2.:rceJed .panssT q:J1qM uT h~unoo aq:t 10 11T::raqs aq~ o~ ATUO pa~oaJTP aq hew ~uaw5pn~ pa.rJa15uI2J~ e UD panSSl :tlJM e (o)EOIE aTn~ Japun 'pa=l-e:JTPuT aq PTnoqs A::;.unoo aq::;. '(q)EOIE aTn~ AG paZTJoq~nl2 512 A::;.unoo Jaq::;.oue 10 I1TJaqs sq~ 0=1 pa~oaJTP S~ ::;'lJM aq:t uaqM (1) qdeJcl2Jl2d JapUn 3J.ON I 81 '-'l~ 0 0 ~~ N N a e a ... H " " ~e-. H .. .. ::> <1)1::> ...: u >.~f.j ~ r.:I " i:>1 ~ f.j ><: '-'l r.:I .... ~E~ .... .., rn i:>1 ~ ..-1 H ::,; ~ :> 0 ~ ..., > " ~ ~ '" ..-1 H ~:<:f.j '0 u " I :<:~...: r.:I 0 ..... '" ~~~ 0.. ~ 0. '" e-. r- ~ H ... N ~ U 0 0 f:3e-. ~ 14 .... I ,., '" 0.... +-' 0 0 <l)l:! " " 0 0.. ... " N ~~ Q) ... ..., .0 0 .... 0"" J ... 0 ~:;: i3: " 0" r.: u-: :~ ~ ('"oJ ;:~3~ "',"- ~ 1 >...-. -'I ~.:J .,... f.l9 ~ -.. :-0 a - 12 t '-2 ~CJ . J], tJ -...II c::: t:r)a.. -.J~ ~ -:{ ~c. :~ ~ ~ "() S!- !..I- e....) :::> ~, ~ () ,"::'"",,;1 (.) I ~9Q I e; ~ ~ ~ ~. a \J '0 l.., ~ ~ -.:. 1 "::# -+ f\ ~ 't7J- ~ - ....... 'C:J. ~ CY ~ 3 J WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-2736 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION FIKIA WEST SHORE TEACHERS F.C.U., Plaintiff (s) From NATHAN E. CUZA, 707 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449 (t) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT((S) AT ABOVE-LISTED ADDRESS (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not tevied 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 helshe has been added as a garnishee and is enjoined as above stated. Amount Due $20,161.54 Interest FROM DATE OF JUDG. (10/28/03) Atty's Corum % $1,008.08 Ally Paid $36.75 ptaintiffPaid Date: NOVEMBER 7, 2003 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) ProthonotarY n '-By: -f/J,~D ~ ~'.. Deputy . ~/U"'~ REQUESTING PARTY: Name ROBERT D. KODAK, ESQIDRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 R. Thomas Kline, Sheriff, who being duly sworn according to law, states [l,'lIfis writ is returned STAYED. cr'. , ~;, ,,~ p'~eriffs Costs: ~cketing ~undage Advertising Law Library Prothonotary Mileage Surcharge Levy Post Pone Sale Garnishee TOTAL 18.00 1.29 .50 1.00 24.84 20.00 $ 65.63 Sworn and Subscribed to before me Thisd~ day of ~ 200:yA.D.~1 ~r-' (1 .~ ~ ..tr6thonotary Advance Costs: Sheriffs Costs: . :\.-. .~. <C-.J; ~ 150.00 65.63 $ 84.37 Refunded to Atty on 03/24/04 P~-:';::~~l R. Thomas Kline, Sheriff CJ ~ c__q. ~bcJa/ By Claudia A. Brewbaker \:} "" . "-:. '-l \k ... \,'5t c.k. '-I'1'\?:.'\ ~ J'f'?/fO ," ... PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 SUSOUEHANNA VALLEY FEDERAL CREDIT UNION FIK/A WEST SHORE TEACHERS F. C. U. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 Plaintiff NO. 2003-02736 CIVIL TERM Term 2022- vs Amount due $ 20,161.54 NATHAN E. CUZA 141 EAST COLUMBIA ENOLA PA 17025 Interest FROM DATE OF JUDG. 10/28/03 ROAD - ;:un FLR Atty's Comm. $ -1,388308 /iI, ot>'ij. 07 f2il{ c<.'1't~~<"";i,, f.t't.n t",~ and CostsTO BE DETERMINED$ Defendant (s) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of ~~ County, Pennsylvania; (2) against NATHAN E. CUZA (3) and against Defendant Is) Garnishee ( s) I (4) and index this writ (a) against NATHAN E. CUZA Defendant(s) and (b) against Garnishee (5), as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UPON ALL PZRSONlIL PRO~y OJ' ABOVE-LJ:S!rED DZJ'I:NllA!lT (S) AT ABOVE-LIS!rED ADDlU:SS INCLUDING BUT NOT LIMI!rED TO I'llRNITOU, ZQUIPMI!:N'l!, ZLl!:CTROJll:CS, ZTC . ? /~42-- (5) Exemption has (not) been waived. Dated 01/10/05 Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Attorney For Plaintiff(s) ~. '(~)vOIE eTn~ aas 'paxTsap s1 suapuad S11 E 5e oUTxapul pUE paqoe~~e S1 aaqsluxeo aq:). JO aweu aq4 uT ^~JadoJd IBeJ 11 ATUO pa4oTdwoo aq PTnoqs (q) (v) qdexoexea Aq ^4UnOO ~eq~ u1 aSJnoo JO 5e paJTnbax s1 5uTxapuT ^4UnOO xaq40ue 04 S8 pa.:rlsap s1 'aou8xnssT 10 1\4UnOO aq4 UT suoT4noaxa aq:). JO 5uTxapuT 11 "(q)vOlE aTn~ aas SanGST 41JM aq4 uaqM "(e)vOTE ^p.:o pa:J.oTdmoo aq PTnoqs (e) (v) "AJ840UOl.!40.:rd aq4 aTn~ Aq paZTJoq4ne Ljde.:roe.H'd . (:).pM alp U1 papnT:lUT aq 0:). 51" aallSTUJeO paweu e U1 AIUO pa:p~Tdwo:) aq PTnoqs 8Aoqe) (El 4deJoe.:rEd 'panss! Q01l!M uT ;::4UOOO aq4 JO JJTJaqs aq4 0:). AluO pa408JTP aq hew 4ua1U6pn~ pax.:raJsuex4 e uo panssT 41.:1M e (olEOTE aTn~ JapUn 'pa480TPUT aq PTnoqs 1\+uooo aq:). '(q)EOTE aTn~ Aq paZT.IOl.l+ne 5e ^+uooo Jaq~ou~ JO JJ1~a4s a4~ o~ pa~~a~1P S1 ~1J~ a4~ ua4~ (t) 4deJoeJed JapUn 3.LON I 81 '""I~ 0 0 ~g N N Z S S 0 ... ... QU) H " " ~h H ... ... ::> u):::, <>: ><~u l><l U :::, "" <II ti! r" U X '""I~ "" .... U) .... "' ~r,,~ (J) ti! r:x: ." H >- 0 ..><: .., > [ij ~ III ~ H :z; ." U ~~u ~ '"0 '" I >--<<>: "" 0 H '" ~:z;~ 0., :<: "" '" h r- ::r:t:l ~ H ... N U 0 0 [:;h ~ Q .... I '" 0>--< +J '" 0 0 U)Q " z 0 0., ~ ~ N :::,~ Q) ... .., ..Q 0 ." U)u 0 .., ... 0 .., i3: z r:x: '" ~ .,- ~ I;;-- "-- ':\' \;:1 ,~ lv ~ '- '" <J\ ~. I~ .J '- ~ ~ ~ ~ ~ \> ~ ~ ::::::. ~ '" l:, ~ \)~ ~ ~ , " '\ '- b ~ ~ ~~ ~ ~~ < ~ ~ ~, ~ Ii> L ' , "1 ,I'.~. ,-' * " !~ '" ~ ", ,-') .~~ ,(, \J\ :::! , ~_..> .:;1 (- ."J ,. l'"'...',' r.<.. WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N02003-2736 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION FIKlA WEST SHORE TEACHERS F.C.U. Plaintiff(s) From NATHAN E. CUZA 141 EAST COLUMBIA RD, 2ND FLOOR ENOLA, PA 17025 (I) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING BUT NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, ETC. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not tevied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due$20,161.54 L.L. Interest FROM DATE OF JUDGMENT 10/28/03 Atty's Comm %$1,008.07 Ally Paid $228.14 Plaintiff Paid Due Prothy $1.00 Other Costs Date: January 11,2005 CURTIS R. LONG (Seal) Prothonotary By: ~J,Md ,/ )/ /d" f):f Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQ. Address: POBOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Advance Costs: Sheriffs Costs: R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee TOTAL $ 18.00 1.02 1.00 11.84 20.00 51.86 Sworn and Subscribed to before me This ~ day ofJYkr-4 2005 A.D. t .0.... ~g~. Prothonotary LE :b 'V G I NVr ~ODl (~ .~ '''"iliJ --'ill <:.~ ~~ If-if Vd 'A1i;,'"'' ij" i c,dl.lit;) .:l.:lIU3HS 3iH JO 3:JI.:l.:lO 150.00 51.86 $ 98.14 Refunded to Atty on 03/03/05 So Answers; ~~ 1-<-t?'t!.e R. Thomas Kline, Sheriff ft. J OulJ I Q. ~-UJ bctl ~Iaudia A. Brewbaker ~!J WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N02003-2736 Civil CIVIL ACTION - LAW TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION F/K/A WEST SHORE TEACHERS F.C.U. Plaintlff(s) From NATHAN E. CUZA 141 EAST COLUMBIA RD, 2ND FLOOR ENOLA, PA 17025 (I) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING BUT NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, ETC. (2) You are atso directed to attach the property of the dcfendant(s) not tevied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$20,161.54 L.L. Interest FROM DATE OF JUDGMENT 10/28/03 Atty's Conun %$1,008.07 Arty Paid $228.14 Plaintiff Paid Due Prothy $1.00 Other Costs Date: January 11, 2005 CURTIS R. LONG (Seal) Prothonotary By: ~---'<C~p:;9~Vl, W REQUESTING PARTY: Name ROBERT D. KODAK, ESQ. Address: POBOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159