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Home My WebLink About01-6009SUSQUEHANNA 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. OI- &~3~ BEVERLY J. THOMAS : CIVIL DIVISION - LAW Defendant : COMPLAINT The Plaintiff, SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Formerly Known As WEST SHORE TEACHERS FEDERAL CREDIT LrNION, by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to 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 11,200 l, upon a cause of action of which the following is a statement: 1. The Plaintiff, SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, is organized and existing trader Federal laws, having its principal office and place of businass at 1213 Slate Hill Road, Camp Hill, Cumberland County, Pennsylvania 17011, and was formerly 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 Plaintiffs Loanliner Application to induce Plaintiff to extend credit to Defendant at various times and for various amounts. A aue and correct copy of said Loanliner Application is attached hereto, marked as Exhibit "A" and made a part hereof. 4. To further induce Plaintiffto extend credit to her, Defendant did also execute Plaintiffs Loanliner Credit Agreement. A tree and correct copy of said Credit Agreement is attached hereto, marked as Exhibit "B" and made a part hereof. F:\USER\BONNIEJO\COMP\WORK~27508COM.WPD: 16Oct01 5. At all times pertinent to the creating of this indebtedness to Plaintiff, Defendant was a resident of Cumberland County, Pennsylvania, all applications and advance requests were made to Plainti~s offices in Cumberland County, Pennsylvania, and all monies were issued from Plaintiffs offices in Cumberland County, Pennsylvania, thereby creating sitos 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 "C" and made a part hereof. 7. Defendant has defaulted in the payment terms and conditions of the aforesaid documents 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 total 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 hereto and made a part hereof. 10. The balance due and owing by Defendant to Plaintiff is the sum of Six Thousand, Two Hundred Seventy-Five Dollars and Fil%an 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: 16Oct01 2 WHEREFORE, Pla'mtiffbrings this suit to recover from Defendant 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. Respectfully submitted, Robert D. Kodak 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff A:\27508COM.WPD: 16Oct01 3 · ' WEST SHORE TEACHERS FEDERAL CREel'i; UNION ~ R 1213 Slate Hill Road ~' Camp HHI. PA 17011 Appli cation HOW TO · Please complete re(; secEons t through 8. Be sure tc check all applicable t~oxes. APPLY · Sign section 9 · Return th~s application to the Credit union I Check the appropriate boxes ts indicate the type of account(s) and type of credit for which you ere applying Married Applicants may apply for a separate account. NOTE AND [] LOANLiNER® Account/Loan ...... "Other" section . S use, Guarantor (remrreu tu ~ ) . : Credit Cald Account action. Comp eta Co Applicant, po W or (2) if your spouse w~ll use COMPLETE [] ,.d)v,dua, Cra"'t: [] (1) about your spo_u.s.e, fi. you ,,~,~ ..... r on this account. Please cheCK cox to the Account, or (3) I! there ,.', a [3 Joint Credit: provide information about both of you by completing Applicant and Other section. You REQUEST AN ADVANCE OF $ _ Purpose: Colateral: - h [] Automat c Payment E] MIlitary Allotment [] Repayment: [] Payra Deduction [] {Jas iumon w~ll disc ese the cost of th s voluntary msursnce to ul he term a STATEMENT ~ Credit Disability Insurance Check coverage(s) desired The cred t ~ ~ ~r. ln~,~ t s nd conditions must be s~gned you A separate iRsLIrence elecbon wh~c~ for coverage to become eflechve ,~OF INTENT ~ANT ~,,, SPOIJSE ~ .,G, UARANTOR LICANT Please print in ink or ~ype. - N~-'~-~'~ - ~ INFORMATION NAME tLa~-Fir~-mma) 3 EMPLOYMENT INFORMATION NAME AND ADDRESS OF EMPLOYER TITLE I gRADE G DATE tF EMPLOYED IN CURRENT pOSITION LESS THAN FtVE YEARS. COMPLETE PREVIOUS EMPLOYER NAME AND ADDRESS NAME AND ADDRESS OF EMPLOYER SUPERVISOR TITLE I GRAOE ~~ ,F~PEO~ SU~"ESS IF EMPLOYED IN CURRENT POSITION LESS THAN FIVE YEARS, COMPLETE :'REVIOUS EMPLOYER NAME AND ADDRESS FER EXPECTED DURING NEXT YEA~ [] YES [] NO - EDDURINGNEXTYEAR []YES [~NO iSOUTYSTATIONTRANS ENDiNGISEFARATIONOAT; MIUTAR WHERE NAME AND ADDRESS OF CREDilOR(S) OF DEBTS PAID OFF TELEPHONE 4 NAMEAND^OOSSSsoPeRED'OSIS'O eE PAleOFF E EPNONE I REFERENCES .... ~ ~ -- nEL~T~C:"e: "'; Please include ~[~II.~L- L~- t~' ;P I ~ REL~rlONS"I". ~O_RESSO~BT RELATIVE NAME ND ADDRES~ OF NEAREBT RELAT ~ . ' ~OME PHONE- Street, Ci~4, S;ate NOT LIOlNG W~TH YOU l:~? i~ '~[ ;3 NOT LIVING WITH YOU .n~ Zip.., ~PH~E , ' ...... ~ EXHIBIT .R 6 ASSETS Check box for Applicant/ Othe~ List all assets and account number(s)-- Attach other sheets ff necesssr~ SAVINGS AMOUNT NAME AND ADDRESS OF DEPOSITORY SAVINGS AMOUNT AP/R./CANT DEBTS In addition to Rent/Mo~gage list ali other debts (for example, auto ' loans, credit cards, second mortgage, home assoc, dues, alimony,, child suppo~l, child care, medical, utilities, auto insurance, etc.) Please use a separate line for each credit card and auto loan. Attach other sheets il FINANCIAL IF A "YES" ANSWER IS GIVEN TO A QUESTION, EXPLAIN ON AN ATTACHED SHEET INFORMATION HAVE YOU ANY OUTSTANDING JUDGMENTS? HAVE YOU EVER FILED FOR EANKRUPTCY OR HAD A DEBT ADJUSTMENT PLAN CONFIRMED UNDER CHAPTER 13? HAVE YOU HAD PROPERTY FORECLOSED UPON OR REPOSSESSED tN THE LAST 7 YEARS? ARE YOU A PARTY IN A LAWSUIT? ARE YOU OTHER THAN A U.S. CITIZEN OR PERMANENT RESIDENT ALIEN? iS YOUR INCOME LIKELY TO OECMNE IN THE NEXT TWO YEARS? ARE YOU A CO-MAKER, CO-SiGNER OR GUARANTOR ON ANY LOAN NOT LISTED AEOVE? FOR WHOM IName et Others Obligated on Loan): TO WHOM (Name el CCedlto~): These questions APPLICANT OTHER apply to both YES NO × Applicant and Other You understand that when applicable, a Personal Identification SIGNATURES Number (PIN) may be issued. This PIN, when validated will allow you, tf there are any the co-applicant and any authorized users, to access your credit ~tportant changes, union's CREDIT CARD/ATM accounts through participating Au o- /ou will notify us mated Teller Machine (ATM) networks, subject to the terms and disclosures of the Credit Card Agreement and the Electronic Funds rt writi/~g immedi- Transfer Disclosure for CREDIT CARD/ATM Access Card. You t/ely. ~ou also tgree to notify us understand that .use of your credit.~At~vtll constitute acknowl- if anu chan~,e in edgmant of receipt arid agreeme~-ro the terms of the CREDIT ,... '.~ ~.~.~. CA R D/ATM-A~i~bSS, Card discio~Q~res.TM ithinareasone a X L - ime thereafter. · --~ ~.7,~.~--,.~ z / z~ '[' T ¢' APPLICANT'S E~GNATURE ~// D.~TE :REDIT INION ~IFORMATION o not write in ~is section-- credit union I YEE NO You also promise that everything you have stated in this application !s correct to the best of your knowledge and that the above information ~s a complete listing of all your debts and obligations. You authorize the credit union to obtain credit reports in connection with this application for credit and for any update, renewGI or extension of the credit received. If you request, the credit union will toll you tho name and address of any credit bureau from which it received a credit report on you. You understand that it is a federal crime lo willfully and deliberately provide incomplete or incorrect information on loan applications made to Federal Credit Unions er State Chartered Credit Unions insured by NCUA. X OTHER SIGNATURE DATE ~' APPROVED $ $ $ DATE LIMITS SIGNATURE LINE OF CREDIT OTHER OTHER DEBT RATIO E] LOAN OFFICER ADVANCE APPROVED: [] YES [] NO ~]COUNTER OFFER WILL BE MADE, IF ACCEPTED, ADVANCE APPROVED [] CREDrF COMMITTEE OR OTHER E] OUTBICE INFORMATION CONSICERED: []YES []NO IFYES, ATTACRADDITIONALSHEETANDCESCRiBE REFERRED TO/REASON(S) FOR REFERRAL: DESCRIBE COUNTER OFFER: [] LOAN OFFICER X DATE X E~ CREDIT COMMITTEE X DATE X DATE DATE [] ECOA NOTICE AND REASON FOR REJECT/ON SENT OR DELIVERED ON (DATE) BY SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Formerly Known As WEST SHORE TEACHERS FEDERAL CREDIT UN/ON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTy, PENNSYLVANIA : NO. d)l -- /.OOq BEVERLY $. THOMAs : Defendant : CIVIL DIVISION. LAW ~OT~C~ YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEy AND F/LING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SE IF YOU FAIL TO DO SO THE CASE T FORTH AGAINST YO MAy PROCEED WITHOUT y,-, ...... U. YOU ARE WARNED THAT BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MON~ a~t~ A JUDGMENT MAy BE ENTERED AGAINST YO~ CLAIMED IN THE CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS COMPLAINT OR FOR ANY OTHER IMPORTANT TO YOU. Y O L HIS PAP R O U A YERAT N . FYO N THAV LA R O NE T T EPHONE E OFF FO T L TO CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 Application WEST SHORE TEACHERS FEDERAL CREDIT. UNION 1213 Slate Hill Road Camp Hill, PA ~7011 (717) 737-4152 HOW TO APPLY · Please complete red sections 1 through 8. Be sure (o check al apphcable boxes. · Sign section 9 · Return th~s application to the Crecflt Un~o- 1 NOTE AND COMPLETE STATEMENT OF INTENT ~J~LICANT INFORMATION 3 EMPLOYMENT INFORMATION MILITARY 4 REFERENCES Please include Street, Ci~ State and Zip. Check the appropriate boxes to indicate the type of account(s) and type of credit for which you are applying, Married Applicants may apply for a separate account, [] LOANMNER® Account/Loan [] Credit Card Account [3 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) 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. [] Joint Credit: Provide information about both of you by completing Applicant and Other section. You REQUEST AN ADVANCE OF $ Purpose: Collateral: Repayment: [] Payroll Deduction [] Cash [] Automatic Payment [] Military Allotment [] [] Credit D~sability Insurance Check coverage(s) desired The credit union w~ll disclose the cost of this voluntarwnsurance to you A separate insurance elecbon which discloses the terms and conditions must be signed for coverage to become effeohve APPLICANT Please print in Ink or type. ACCOUNTNUMEER [SOC,ALSEOD., NUMaE, BIRTH DATE HOME PHONE BUSINESS PHONE/EX[ NAME AND ADDRESS OF EMPLOYER IF EMPLOYED IN CURRENT POSITION LESS THAN FIVE YEARS, COMPLETE PREVIOUS EMPLOYER NAME AND ADDRE~ STARTING DATE [] CO-APPMCANT [] SPOUSE [] GUARANTOR Use "SAA" if information is "Same As Applicant". BIRTH DATE HOME PHONE BUSINESS PHONE I EX~ ( ) , ; { PRESENT ADDRESS (StreM - City - State - Zip) [] OWN [] RENT YEARS AT THIS ADDRESS AT THIS ADDRESS COMPLETE FOR JOINT CR EDIT, SEC U RED CREDIT OR IF YOU LiVE IN A COMMUNITY PROPERTY STATE; [] MARRIED [] SEPARATED [] UNMARRIED (S~ngle - Dborced - Widowed) LIST ~J~ES OF DEPENDENTS NOT LISTED ~f APPLICANT (Exclude Self) 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 ENDING DATE NAME AND ADDRESS OF CREDITOR(S) OF DEBTS PAID OFF TELEPHONE RELATIONSHIP H~E PHONE NAME AND ADDRESS OF CREDITOR(S) OF DESTS PAID OFF TELEPHONE NAME AND ADDREeE OF NEAREST RELATIVE RELATIONSHIP NOT LIVING WtTH YOU HOME PHONE I CHECKING AMOUNT SHARE DRAFT OR NAME AND ADDRESS OF DEPOSITORY SHARE DRAFT OR CHECKING AMOUNT ASSETS $_('~.~ L~,~;~:~~ C~'t'(l't~cE~'~ ~')¥~/'~ $ ~VINGS ~OUNT NAME AND ADDRESS OF DEPOS~RY ~WNGS AMOUNT NAME AND ADDRESS OF DEPOSI~RY $ L{L' .~[ ~ - ~V ,av~ ~ I HOME AND ALL ~ER ITEMS ~U ~N AND ~TiON ~ PROPE~Y M~ PLE~~ Check box ~ Ap~i~NT ~ppl~ant/ O~he~ List all assets and acc~nt Attach other In addition to · list all other debts (forexample, auto loans, credit mo~ag~ home blimo~ child care, medical, insurance, etc.) each credit card and au,o loan. Attach other FINANCIAL INFORMATION HAVE YOU ANY OUTSTANDING JUDGMENTS? These questions HAVE YOU EVER FILED FOR BANKRUPTCY OR HAD A DEBT ADJUSTMENT pLAN CONFIRMED UNDER CHAPTER 137 apply to both HAVE YOU HAD pROPERTY FORECLOSEC UPON OR REPOSSESSED iN THE LAST 7 YEARS? Applicant and ARE YOU A PARTY iN A LAWSUIT? Othe~ ARE YOU OTHER THAN A U.S. CITIZEN OR PERMANENT RESIDENT ALIEN? iS YOUR INCOME LIKELY TO DECLINE IN THE NEXT TWO yEARS? ARE YOU A CO-MAKER, CO-SiGNER OR GUARANTOR ON ANY LOAN NOT LISTED ABOVTE?O WHOM (Name ol Credit~): FOR WHOM (Name ol Others Obliga{ed on Loan): understand hat when applicab e s Personal identification You also prom se that everything you have stated in this applioattoR You ...... ,..^~=.~ isPIN whecvalidatedwitlallowyou, iscorrec ~othebestofyourknowledgeandthatthe~3veinf~msti°n Number ~' r~) may u= ...... Th , is a complete listing of all your debts and obligations. You authorize SIGNATURES the co-applicant and any authorized users, to access your credit YES NO ..~, UNION INFORMATION Do not write in this section-- Check appl~abla bOX(eS). SIGNATURES: ~] LOAN OFFICER X ~] LOAN OFFICER ADVANCE APPROVED: [~ CREDIT COMMITTEE OR OTHER [~ OUTSIDE ~NFORMATION CONSIDERED: REFERRED TO/REASON(S) FOR REFERRAL: DATE DATE X DATE DATE X (DATE)BY If there are any .ninn's CREDIT CARDIATM accounts through participating Auto- important changes, ~,~ Taller Much ne (ATM) networks, subject to the terms and ~e(~ addreSs of any credit bureau from which it received a credit report you wi# notih/ us ~[~.'~ureso theCreditCardAgreemectandtheElectroRicFunds r ditreceived ifyoursqaest, t~ecredltunioRwillmilyouthename . " nmed- ' ..... ~,.~.re or CREDIT CARDIATM Access Card. You m wr~t,!~ Transfer D~sci ...... ~' constitute acknowl- on you. You understand that it is a federal crime to willfully and ately. You also understand that use of your credit.~_.~Wll/ .... t the CREDIT deliberately provide incomplete or incorrect information on loan agree to notify us adamant of receipt and agreeme~J~--t? in ............. applicationsmadetoFederalCreditUnionserStateCharteredCredit of any change in CA~R Di ~i-M -A-c~e S~ C ar d disc. c~ res. '~ . your nam~ address // ~ ~_..~.~ ~ _ ~ ..~ / Unions insured by NCUA. within a reasonable X ~~ ~ DATE ~me thereafter ~- DATE OTHER SIGNATURE t' · ~p~;CANT'S SIGNATURE ~ 10 , ^pP.OVED $ LIMITS ~GNAT~ LiNE OF CRED CREDIT OATE [~] YES ~NO E~ COUNTER OFFER WILL BE MARE, IF ACCEPTED' ADVANCE APPROVED ~]YES [~]NO iF yES, ATTACH ADDITIONAL SHEET AND DESCRIBE the credit union to obtain credit reports in connection with this application for credit and for any update, renewal or extension of the ®WEST SHORE TEACHERS FEDERAL CREDIT UNION 1213 Slate Hill Road Camp Hi,,, PA 17011 (717) 737-4152 ncuI GREEMENT ~,- n~re~nc to ~ ...... IMPORTANT The follow ng is part of your LOANLINER Open-End P~an. Read this information b . . disclosure of your various Subaccounts, Present 2. Please see the acc~- ~fore S~gnmg on I ~,-,anwng Addendum f~r=~ Annual .Percentage Rates, Daily Periodi This LOANLINER Credit Agreement a~ Truth in any add~tional information c Rates and CREDIT ~end~g Disclosure will be ref AGREEMENT ~ou and 'YOUr" ~ erred to as this I~,, finance charge, the Unpaid balance for each day ANDTRUTH tn~s Pan Th="'~. -. -,=an each perso- -.~ P'~' ' since your last Payment (or since an advance jf you · -~ ~,e=~t union" m==-= --" w.o S~gns have not yet made a Payment) is multiplied by the IN LENDING whose name appears above o .... [ne credit union DISCLOSURE creditunJon transfers its rioh~,~°n~° whom the applicable daily Periodic ~ate. The Sum of these amounts is the finance charge Owed The balance -~ ~ ...... ~er this Plan. Used to COmpute the finance Charge 'is the unpaid nuW THIS PLAN WORKS -. The credit union balance each day aher Payments and credits to that advances, Under this Plan from time to time The balance have been subtracted and any new advances anticipates that you will borrow money ,called have been added. A finance charge will be COmputed credit union, however, is not required to make for each Separate balance under this Plan. advances to you Under this Plan and Can re'use a separately ~Y~me. ~he Addendum Under this r,=~ UT crealt (called sub- Plan will be se ...... t aJJ advances accounts avai(abie Under this ~rov~d for credit unde ~ *..~lan' Jf you have been deposits in all joint an~ :_,~,=u oy the shares an ~ =Jar (~}, vo ,..;. ~_ . r _ ~uuaccount marked with ' · .~ ~Hu~viduaJ accounts you hav~ . u _,,, u= gwen a specific credit I~mit for Additional Security wdl be required depending on the that Subaccount. For other subaccounts subaccount Under which an advance is requested. be given a specific dollar limit, you may not wrt~ the Cred~ un,on now and in the future .. s the Security will be Shares and deposits in an Individual a new car. PROMISE TO PAY You promise to repay to the Account and any other account that would lOse Retirement credit union all advances made to you under this special tax treatment Under state or federal law Plan and any applicable charges described in the ' Addendum together with interest on what you Owe g~ven as Security .are .not subiect to the security until the total amount has been repaid. The interest interest you have given m your shares and deposits. rate depends on the subaccount Under which the Property given as security under this Plan or for any advance s made. The Addendum shows the Current other Joan wiJ( secure ail amounts interest rates as dai y perJodJ Sponding annual n ..... c rates and their c ~er~o,,uge rates If th~ :-- orre- union now and in the future. Howy°u Owe the credit for any or a~l advances s a ~ariab~e interest rate, the ' ' ~ ,-~erest rate made under this Pan, the cra .te~: for advances Adder~dum explains how ~,,e variable ~nterest rate Works. Waives any security interest d~...~un specifically PAYMENTs ._ The amount of Payments for an dwellings ~Jven throuoh an it may have in your advance is determined according to the Payment Security agreements. ~ .Y Other mortgages or last day of each month unless a different date is set DEFAULT .. You will be in default if you do not make SChedule in the Addendum. Payments are due on the a payment of the amount r ' You. will be in defaul ;~ .~ e~u~red when it is by the Credit union at the time of an advance. If the any security agreement made Jn Connection with an maoe Under this Planto~ ~uu orea~ a~y promise d~ Addendum has no Payment schedule for a sub- advance Under this Plan. You will be in default if you ,. anyone ~s In default u/d~ account, the amount and due date of Payments will die. file for bankruptcy, become insolvent, if you be determined at the time of each advance. Payments must inClUde any amoun ~ any false or miSlea~:- ~ny amount by wA.~ t Past due ~,~ . .~u~t appJicat on or u~+- ~'~g statements in a limit you h~-~ -,~- you have exce~ .... if SOmethj~n h~__ ~u~ Or credit inform--' ny prepay all ":~ ueen given for a subac~ta~.Y Credit ..... ~ -.pens whic~ .... ,,,-uon or .flay SUDsta~tja~b~ re,..__ ,, ~lu creolt union belie w,~nout any Prepayment Pe~al~.u OWe at any tim~ you Owe . uuuu your ability to .... ~es When You are in default the credit union can demand COST OF CREDIT ._ The dollar amount you pay for immediate Payment of th money borrowed . is called a finance char e ~nder this Plan w.- ..... e entire un ad begins on the date of each advance Tn ~ g and ad,ate Payment is d-~-~°~ advance not, ce. f · - ~umpute the CREDIT · repa?d. If a demand ~- .nt, what you Owe h~ ~ In You will receive a Stateme . maoe, the ~- ,u, Immediate ..... ~o ueen this Plan c~*~'~res and depos ts ~iv~a-Yfnent has been Under this Plan durino t~net sho.wmg all transact'on° ~., ue applied to,~,~,~_~ .~" as Security for - period COVered by Ith~ --o,u~ what you Owe. The AGREEMENT AND TRUTH IN LENDING DISCLOSURE credit Union can also exer ' by law When you a o ~ ~ ?se any other rights Continued r~ ,, uerauJt, given PROPERTY INSURANCE .. You will be required purchase property insurance on certain types ot~ security that you give for advances You m f purchase the propert in ' choose that is a ..... Y~. SUrance from ..... ay c~,~le to the credit un?(~'n~u"e you CANCELLING OR CHANGING THIs PLANT credit union has the ri h Plan from ' . g ttochan e -- he n t~ t~.me to t~me a ~, ' g the termsofth · ~t._~ required by Jaw ~' giving you any advan~ · U~ure advances, and a; ~Y..CnanCe will - ,,, alScretlon of .... ua,y periodic rat= ~ u~ances. An interest rate is not COnsidered ~ u-uer a Variable Under this Plan. a change in terms 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 ~rtant ~at you CREDIT D~ ~ UMFY~- UNION INFORMATION Statement. Statements and notices will be mailed to you at the most recent address you have given the Credit Union in writing. Notice to any one 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 nstructions, the Credit can refuse to fo ow yOUr instructions. Each of union who sign this Plan will be individually those · ' · and jointly responsible for paying the entire, amo. unt Owed Under this Plan That means the Credit union can enforce its rights Under this Plan against any One individually or against all of you together, of You UPDATING INFORMATION .. You promise that you will promptly give the Credit union written notice if you an.y omt~er', tiYo~Ur,.~)uame or employment, or if un~on changes. You also agree to provide the credit ~ provided to the credit union Updated financial information about yourself Upon request. The credit union Can delay enforcin ~a~.y. num. bet of times w ~ ..... g .any of/ts ri ht .o~v ma,es any ter Io~ t~'"-~.~°slng Its rights ~h~ the other terms will remain in effect. m,,, u, [n,s Plan unenforc~fa~e, tho oughl ~ ~ X ',,s ot the agreement. ~ -- / ~ ~ OTHER StGNATUR~ CREDIT UNION COPy WEST SHORE TEACHERS FEDERAL CREDIT UNION 1213 Slate Hill Road Camp Hill, PA, 17011 (717) 737-4152 Credit insurance is voluntary and not required in orde obtain your loan· You ma eel . r You have established an ~n ect any maurer of yOur ~L . to _ v,-en-end L .- --wnolce. Union. Your Loan Plan Dan Plan w~th the Credit You are applying to themay Consist of one or more Loans. SOciety for credit inSUrance. You authorize the charges for inSUrance to be added to your CREDIT INSURANCE You can protect yOur financal future by si m cVa°~nnota,,r~Y Credit insurance be,,,., - 'g 'ng un f~, . ...... ~ your preference in the "~;~}. ,c, nroll by Simply "i.~'?- .s2_ctlon below. Your cro.~;+ · . ...... =u,[ ~nsurance ApPlication,, .~ Various insurance (~,.~..u.~n~on ?Il be happy to ..... -~e. ~he cost is CREDIT INSURANCE APPLICATION & SCHEDULE ~,~ C[J~ ~ G~O[j~ ~ . P.O. Box 391 ~ A4rut~l [~r~mc~-~ly · 5910 Mineral Point Road -- Madison, WI 53701-0391 "You" or "Your" means the member and the joint insured accrue on these charges the Same as it accrues on (if applicable). Phone: 800/937-2644 Loan Balance each month and Understand Appication a · has not si COmpleted, if the member ~SU~E~ES that interest w/Il , nd ~f the ApPlicatio h~o g_n,e? and dated the n __o no[ Dean Witnessed. Beverly j. ThOmas 09/2~/1~58 RATE SCHEDULE DATE, ARE YO ES A MINIMUM OF 25 HOURs A WEEK? UNDER AGE __~___ ? FOR iNSURANCE DISABILITy BENEFIT .~ 600. O0 you ere totally disabled for more than begin with the days, then the disability X }P. 801-0786PA DATE 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 X X SINGLE CREDIT LiFE LOAN BALANCE $ .057 JOINT CREDIT LIFE LOAN BALANCE UNDER AGE ~._~__~ ? FOR INSURANCE NONE* PER LOAN ACCOUNT ~ 30,000.00 DATE CREDIT UNION COPy SECURITy AGREEMENT In .this agreement all references to "Credit Union" un,on whose .nam.e appears on this a re mean the Credit ~hom the credit un,on as ' g ement If you . , !1 references to "~ _s~;gns the LOANLINE a.n.d anyone to a r' Cancel your Insuran ~Oeled "New Bala~,?uv~a,,rice'' mean the R.~Cr_~d,t .Agreement. u.;i..g~ht to the refund. If t~.C~e.-a-nd get a refund, the person who si~n~ -~"-' ' *~11 reference° + .~,,,uunt mn the bov _"'~' .can use the in~--'-'"' property s lost or .~_~-,~u[t umon has .-_ ~ o ~.ls agreement. ~ ~o you" mean ea~ ~pply it towards wh~*.u.~nce settlement to r ~..ageo, the Credit m~E SECURITY F~ -.-_ ~" mOorse any dr~ - ~yuu Owe. You a-+~- .e'~" the property or agreement i~*~ .--" ~= LOAN .. =_ . . for the cr' ' -,~.ur C~eck which m ~-unze the Credit un - -- t?s agreem~;'~ture area or Under~= ~;ng this Security your insur~t Um~n to collect an ~ be payable t~ you in ~ to the advance .,~ ;s on the back "~ ~=~ement referdn - e policy. Y efund or benefits d = __~er s · , , you gve , of the check , gtc u~ u,~er ~un~ interest in th.th~ Credit union wha. ,~ race,ye for ? yo~ do not pay th..- ~.~ere? section. T~ ~ pro~e~y described [n'~n°,~n as a ~eep it insured .... a~es ?r fees on th ~cce~slons. ACCess ;~-~ecunty. interest you '~'~_"~ Securty ~ot required t~ ~e~ed~t union ~ay pa ~ prope~ W. hen due or ~stal]ed in the pro.~.~['~ are things whlc~ ~.?,v~ includes all [axes, fees or n .... "~' ~Y money th~y ~:~ ob{~gatlons, but s also includes a.. '~'~Y now or in the f.*... ~',~ attached to or advance an~ ---~'~ce wdl be addea *~ .~.~ul[ un,on spend w[~hln 10 day;"[fr~'ace~ents for th~"~'r~e se~rity interest rate you a~;e~U.~i~ pay ,nterest o~ ;~o;~paid balance o~ ~ -.. aavance, It also inclu;e;~[~s~°ns, renewals ~ advance, o~reS~s, or reS.tahoe to ~ If the ~redlt union add ~rrt;ert;~Jll~n~h;~,~;°~1~ or from insurance ou ~-~,ve ~-.y rot the advance t~ ~ u~_ 'ncreased by *h:" ~' yOur the credit Union more ~r~--~pr°pe~y declines .~(. _ haye on the months originally scheduled. ~ uu pa~o off in the s~m;'~_~°unt W~ ..... . ~.u~y as Security f a;'k~ pr~mlse to give -u.,~er of s~'~.~a /HE SECURITY iN~ .... ' ..... ~o eo so. DEFAULT .. You will be in default ' of the ad,.~uv~nce and any exte.~;~n~ --/he Securlt i ~a~e?n~er th~s agreement ~- f you break an - .... ~-~.ce. ~t a so .... --,u.s, renewa .... [~ nterest ,~ ~e[ault under the -~;';;. ~.~u w~tl also be i- ~-[Y ~r~m~se You the future Under ~Y.~h~.advances ou ~.~gs P~eogmg pro ..... ~u~LINER Cre~* * - uurault If you are th~ ~V~LiNER Cr~* _h~.~-ow Agreement :~,~v,.put have not .in~' ~reement. If vou ~'~ ~greement s~gned the LOA~*~ default f an ..... ' · ANLINER Credit ..... cn Credit Agreemen~'c ~s m default who ha~ and any other amount- ~ropertv .. ~HE PROPERTY .. v~ "r~ LINER Credit A~ree~ of whet you ow to you, you ,..=4' ~- - m~s advance i- - ,,uu promise that ..._ . ~perty. You a~ree ~ -~ent and take .... e, Under the ~_ ~,. Use the advent. ¢ o~o buy the pro-e.*- ~u own the P~ssesslon of t~ - ..e credit union .~_~essmn of the nave not already, *.~'~[ m or claim a~ai--* .?u promise that no union. ~.. ~uva~ce notice, jf YOu --~ u~?g to cou~ and sell or lease *-~ .~,u the Credit union ~h~'~ ~e ~rope~y that v.. credi~ ,~ ~r~m~se to deliver t~ -~'~ asked to do so by *~ all-.., ~' ~eo~t~r until the a~-~ ~? ~ as security f~r ~"~" .o~.to ~.y o~ your other Drn~'~ ~re~t Unmn wi~J nn~ ~"~"" ~no Pmce the ,._~ '~ Secunty interes* ~.ce ~s repaid, You'..~_~ ~oan w~th ?u leave inside ..~---~'W, not COvered h,.~2~,~ responsible for ~ur actions or bv on~.~..' v' ~en to attach to t~- .~-nse you will that ~ro~e~v .~ ,~'.= property The cr ~* ~- ~.~s ~greement. the PROTECTING THE SECU After th , , · t tie for the RITy INTEREST e credit unmn . Security ..~. ~O~erty, you promi .... ~- If your state iss- an~ a~ply the m has possession of th file ~,~..-~o.es[ shown on th. ~*~ ~u nave the cr~;* . ~s,a un,on The ...~,.oney received to any .~-e ~rope~y, ~t can sell t [o sign a fina-~=- -""~ or Others jf a~U-~ *~ ~o[ect ~ts securJ*,. E, y~eott union for t=~- o.~ ~a~e. will be heJH ~[ .~u.~ sale or else the cr-~=['~'"~ statement. You ~ .o co so, you nro~ ~ w,I be deducted fr~'~ POssessmn of and ~,~.-e ~x~enses of interest in *~'~ Umon thinks Js ne~-~u promise to do ~a;~',~ costs may inctud~ ~ ~-e money receive +.~',~ the prope~ USE OF PROPER-- " ~' '.~ security awarded ;~;~%~?ees~o the ext;~1 .ne PrOpe~y' prepar .git f~ promise .......... ,~.f -- Until the ad ...... of the -~,- -~don uOC(b) ~¢ +~_~rm?ted under stat aw repair f2~k~{il' (1) Use the pro.er;.~'~e ~s been paid off .--. LOAN/~ ~Oney wit be a--~"~ ~an~ruptcy Code ~%-- .wntmg before c~~ ~-e property, (3 n' ~-~u~( Umon before ~r you have a r ~;?pe.y is kept. (;;7~2g r2ur address o,)/~°:~,the Credit union any amount ~d~ay the advance, o ' ,?.Promptly not/f; ~;~ t~ credit union to i.:~:r~sf, where the apphed to the unn.[~'~:ns unpaid after ~u.~,~l also have to pay s~olen or abused ' ¢~'~ ~reo~t union if the .~%%ct ~ne prope~y. Under this aoree~.%~ance of the advan¢-%~'~ money has been purpose. ' ~¢ ~ot use the or n.~'.~P~Y is damaged, the Same ra¢~ a ,,.~.t. rou agree to pa i ~ ~nu to what you owe · .. ..... - O..... rOt any .nlawf. I .~. .... s the advance until thane ~If~2~[°n ~hat amount at ,il.taxes and f~fi~SE' T~XE, AND FEES- ,, AGREEMEN¢~rt~?NG RIGHTS AND .... ,eh o ~eep the nr~ u~e registration fe..~ ~ - rou promise to n~,, rights undo- -~' .ne cred t Union ..... ~mANGES IN TN~ ~e?t Umon. You ~,~ inSUrance taus' [%"-"u~' ~ne amount ~nts agreement an=i~.L'~ rights later. The ~;-'.'-~ w~t~out Ios/n ou or~m~'~~oy ~ave, or throu~k %---%.W insurance thr~.~khe Aoree~.~°n changes the tar--- I~gM representative if · ~on.and to deliver *~;-~ ~surance po cy ~aCa~2' anu pay for. me Credit union. " .... ~ [n~s agreement wil %~Z~LII~bR Credit ~ ~o, ~uverage to the credit ~?u~D EFFECTiVENEee .. u,u, ~ne rest will remain Jn [R TENNE effect. TICE: If you do not purchase the insuranc has explained t to e above stetemen nsurance wilt not b ~~N Mg ~ ~. ~ you, t and acknowledge that th~ YOU MAy H~c ~u THE SECURED ¢~ ~ SOLD TO SOMEONe- ~U~ECT TO 'ATURE DATE ~ AVE TO PAY THE D'FFERE~;~ ARE NOT RECEIVED ,~L~N~L, THE PROPERT~ DESCRIPTION ON PAGE 1 ~ IS PART OF THIS AGREEMENT. ~ NOTICE: SIGN THIS AGREEMENT ON PAGE 1. ,~® WEST SHORE TEACHERS FEDERAL CREDIT UNION 1213 Slate Hill Road Camp Hill, PA 17011 (717) 737-4152 Advance Request Voucher and Security Agreement Thomas, Beverly j. ~6~R~ SS~--~------ BUS fness Equipment Technf cai Consu[ ~ant MAINTENANCE, OR ALIMONY UNLESS YOU WANT THE CREDIT UNION TO CONSIDER IT. ~Y s3,611 PROPeRTy N ADDITION TO THE PLEDGE OF PuL[y Tft[e Sec Cabrfo[et 11,6~.00 4 PAYMENT TERMs 8.25000 % ~xE~ VA~LE ~ .00 N/A N/A + ~ N/A = s ~s, 507 S0 ~L SHOWN IN ~E~ D GING SHAPES FOR THE AMD El'OW ~ND CHECK THE HE SECUR TV OFFER UNT APPUCABLE BOX. ED SECTION HE CHANGE IN THE TERM {Si OF y AGREEMENT MAPKED WITH A STA~R LOANLINER -~UNA MUTUAL INSURANCE SOCIETY, 1980, 82, 84, 86, 89, ALL RIGHTS RESERVEO MEMBER COpy VST025 (LASER) ®' WEST SHORE TEACHERS FEDERAL CREDIT UNION 1213 Slate Hill ROad Camp Hill, PA 17011 (717) 737-4152 ~^~_~MMEMBER INFORMATION . Adv,ance Request Voucher ~ '"~ _M M ER A UNT ~,,~. aha SecuriW Agreemen~ MEMeER ~M ~~~L SECURI~ Ni~M~=~ - aever[y j. ~ 6us fness Equf~ Us~~ ~ONE NO; FU[Cy Tf~[e Se CAJU ' V, NM, TX, WA, W~L N FU[ty Title Sec Cabrfo[e~ o~H~ ~O~sc~e~ ~ 1 Your Cr~ft Unfon ~ - t 1,6~.00 · 02260~ % . N/A ~/A N/A = ~ 10,S07 S0 5 SIGNATURESs~GNe~ow ~ OEPOSIT ACC~. NU~ EDUCTION ~AYMENT C SECURiTy AGREEMENT Jn .this agreement all references to 'credit union" . L ,e, nces to the =-~- ,, ~-UANLtNER Cre,~* ^ To a ~Jght to the refund ,..L get a refund, t · ~=,ance . All references"~ ~mo~,~t in ~he bo~ Unmn Can use th= :~" ~ne prope~y is lost ~- ~e credit Umon has person who signs this agreement. ~u you mean each apply it tOwar~. ~.~.~SUrance se~Jement +~ ~. u=~aged, the credit .... on to collect any ~fun~a~~e t~ you in order THE SECURITY FOR THE LOAN ._ By signing th~s our a~reement in the ~ign~ture area or Under the statem ' secur ty Y insurance policy th~s agreement which ts on ent ref the ~dvance, you .; .... ~he back of the c ~ -- er?ng to Offered" ~ ~ ~ne prope~v ~..~,.~.~a~ is known as a keep it insure p y the ta~es or fees on t accessJon.---['on. ,.he security ~nt2;~''~'u ,n. the "Security not require~ ~2 ?e credit union may ~.~?rope~ W. hen due or installeg'[~'+~ccesslons are t~inn~'-',:,[~ ~ou give /nc/udes ~[t taxes, fees~.~__~O so. Any mone~' ~:~ oOhgat~ons, but also incl~r°pe~y now or in ~e ~,l~n ~? a~ach~ to ~ advance an~',,'~,~u~ce will be added to~t~'.~'~ ~q,on Spends for Crag of the advance. It also~_~xtens'ons, renewals ~ advance, f v~e~ tees, or inSUran~t~h~,~ ~d,t union ~-~ originally scheduled. --- ~me number of Wu_. _ "'~'~ property as security if ~'k~ P?m~se to give DEFAULT .. You will be in d ' ~/ /HE SECURity , ..... ~u ~o OD secures the adv---'' "~/eHEST COVERS ..~ . ~a~e under the agreeme-. ~fault ~f you break any .... of the advance ~'~)~ and any extensions, r~,[~.~,secur~t~ J~terest ~n Oefauit under t~- .~".'~' ~ou wm aiso be j~ ~-~' ~'X'"'~ you -=. ,ne LOANLINE~ ~- ~- ..... u now signed the [J~l,~J~e Jn default jf~';:~_J"~ ~OANLINER Credm~ - ~reomt Agreement ........ .:n Credit Agreemen~'~ Is m default who ha~ and any.other amounts you owe the ' the Credit Pra~t~'~ ~e, prope~y is h~seh~ ,s marked with WHAT HAPPENS IF YOU ARE IN DEFAULT _ When _._. ~ .... amounts you Owe. Y wdl secure only the advanc~ F~q~[? ~mmediate Davm._~n' ~mthout advance n~.;~o~ are UWNERSHip OF THE PROPERTy .. You promise the ~LINER Credit ~-~;~__.or what you o~"~.~ y~u, h ...... S any interest in ~ ~,~: P pose. You promls~ .~-- un o~ ..... ~ce nOt,ce, if you ~r~ ~ ?g. to cou~ and w sell or ..... - --,~ u~e credit un ~ ~ 2 ... ~.upe~y that you Credit un on c~ ehver the prope~y at - -' o by the credit a~iow no ....... ? ......=aovance is ..... ~?tty for a roan with you ~aave insid, ~h~,~pe~y, not COvered bv ~" responsible for your acH~un[~ interest or lien to ~e~~' ~ou promise you w'll that ...... - -.,- prope~y. The Credi- ' '""~ ~greement, that ..... ~ or Dy operation of law.-''"~ [o the prope~y either bm~ ~'~,tY to you or mak~ Xt avai ~m~ ~?on_wdJ try to return PROTECT NG THE SECURI A~er the credi . tit~e for the pro e TY INTEREST .. If . and a I t Unmn has possess~o . ~ecurity nter-s+ -~ ~y' you ~romise to ~,,-Y~ur stat~ tSSues a un nn p~ the ~oney recelwa +- - n of the prope~y, It cen ,~,, '+ file wha~ is ~a~lZ~'~w~ on the title The ~;;~..~n~ credit union's th~-~';.!n~red,~ union will'~i~ ~.~Y am?unts you OWe t~e' interest from th~~ ~ nnancing stateme.. ~" unmn may have to th~ ~.~e~ which a priva~ -~ ]uu .~Otme of any pubic ~o Sign a fin-;2;-~~a~ms of others If as~ ~ ~rotec~ its security ::;~ ~'.~? union for takinn ~;~". w~l be held. The ex*~2:'- else the cr-;~'~'"~ statement You a s;~:-~ 9o so, you ~romise ~;.~e ~e~uc~ed from t~; ~;~on ~f and selling th;~es~ interest i- +~" union thinks is nec~..~..~Yraise ~o do whatever ::~.~ ~ay ~nclude the cos· ~Y. rece~v~ from the sal~ - u,. prope~y. -o~a~y ~o protect its secu-~+- ~e an~ a~orney's fee- *~' ~ ~onng the prope~v ~.~22:;' USE OF P~OP~v "'~ awarded under Sece ~_-.~.~ne e~ent Peri.ed ;:2.~-~-~mg it ~or promise -~- ;:.' .... Until the adv .... of the sale m .... "~,], ~o{b) of the Ban~.,-~"~r~tale ~aw or repair ~2~.~*:~{: (1~ Use ~he prope~;~,~ bee~ paid off you LOANLINE~ Cr;~;~"' be applied to wh;;"~ ~o~e. The res~ prope~y s kep~ i~[a~'rig ~ur address o7~;~.~e credit union ~Y,.a~ount that re~: ~g~_a~agce, you will also .:;::,. or aoused. {6) Not --~'"~Z' ,r the prope~y is ~A;;':~' the sam;"r;~;~nt. You agree to pa;'~e to what you owe ,11 taxes an;~A~FE' TAXEs AND FEES - AgREEMENT -- T~;'~-.RIGHTS AND CHANG=.... ,red~t union v~.~'~ prope~ insurance m...~"age' the amount mm .agreement ada n.*~.~e'? ~?er. The credit uni~- ~uu~ ~Smg ,olicy you al.~ ~ay provide the pro~e~~ ?e acceptable to the ?~t union ch~n~' [~ur nears or legal renres~['_.~an e~[orce 'ou prom s-'::"y n?e, or through a ~:~ ~nsurance through a ~greement, you aar:;'..~e ~erms of the '~O~;~[~' It the n~on if asked *~"~' the policy or proof of' ~7.'"''~ ~o tne cr~it CO~. ..... -- ~u project .~ uo so. ~uverage to the credi* ~_.-e~?u~u ~FECTIVENES$ ._ ,. - u~[ermmed by a cou~ to be u ~;~_~ of this agreement i effect. ~ __ AY ~E DIFFERENCE. RECEIVED IN THAT SALE, ~run~ ~ THE PROPER~ DESCRI~ION ON PAGE 1 ~ ~ ~ IS PART OF THIS AGREEMENT. NOTICE: SIGN THIs AGREEMENT ON PAGE 1. USQUEHANNA LLEY 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. 1213 SLATE HILL ROAD · CAM]? HILL, PA 17011-8035 LOCAL: (717) 737-4152 TOLL FREE: (800) 948-1454 FAX: (717) 737-0589 .,o-u~ zue u4:12 PH SUSQUEHflNNfl VflLLEY FOU FflX NO. 7177370589 OCT 18 '01 O3:Z4P~ KH~PP & KODRK PC ?. 02 LAW OBFIC~S OF KNuPp, KODAK & IMBLUM, P.C. SHERIFF'S RETURN - U.S. CASE NO: 2001-06009 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSQUEHAA!NA VALLEY FEDERAL VS. THOMAS BEVERLY J CERTIFIED MAIL R. Thomas Kline , Sheriff of Curaberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDkNT ,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 and attested copy of the attached COMPLAINT & NOTICE with , a true Together receipt card was signed by MOVED, LEFT NO ADDRESS 00/00/0000 Additional Comments: The returned on Sheriff's Costs: Docketing 18.00 Service 4.40 Affidavit .00 Surcharge 10.00 .00 32.40 Paid by KNUPP KODAK IMBLTM Sworn and subscribed to before me this ~ day of ~,~ mi A.D. onotary ~R. Thomas Klin~~ Sheriff of Cumberland County on ii/05/200i pr~ and with recei Sheriff, Docket Service Affidav Surchar! Paid by ~, Sworn and this ~ ~ of Cumberland iCc°rding to law served the les Certified Mail postage 0000:00 HOURS, at ~ , a true OTICE To~ether ~_ - The returned ~unty SUSQUEHANNA VALLEY FEDERAL CREDIT UNION Plaintiff Vt BEVERLY J. THOMAS Defendant : In the Court of COMMON PLEAS of : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-06009 P PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint filed to the above term and number and forward same to the Sheriff for certified mail service upon Defendant at 756 Sycamore Avenue, Myrtle Beach, South Carolina 29577. TO Cumberland County Prothonotary Dated: November 19. 2001 Attorney I.D. No. 18041 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. 2001-06009 CIVIL TERM BEVERLY $. THOMAS : Dcfen&mt : CIVIL DIVISION - LAW TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter.judgmem in favor of Plaintiff and against Defendant(s), BEVERLY J. THOMAS, named for faika~ to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaint Interest fi.om October 11, 2001 at the rate of 8.25% per annum Total $6,275.15 $6,447.71 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defend~t(s) aml his attorney of record, after the default occurred and at least ten ( 1 O) days prior to the date of the filing of this Praceipe. See Ex[u~oits A & B attached. KNUPP, IMBLUM, P.C. By//____~__~~f ~ Robert D. Kodak, Attorney for Plaintiff DATED: Judgment entered and damages assessed as above. Robert L Knupp Robeet O. Kodak Gary J. Imblum BEVERLY J THOMAS 756 SYCAMORE AVE MYRTLE BEACH SC 29577 LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 717/238-7158 email: kki.law~,erizon.net January 21, 2002 Robeet H. Maurer (1923-1998) RE: VS: Susquehanna Valley Federal Credit Union f/k/a West Shore Teachers Federal Credit Union Beverly J. Thomas No. 2001-06009 Civil Term, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 27508 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 Jn 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 & IMBLUM, P.C. Robert D. Kodak, Esq. roi~e#./co~lak~verizon, ne! RDK/kqb enclosure THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE CC: SUSAN J BRUBAKER LOANS/COLL MGR SUSQUEHANNA VALLEY FEDI 3850 HARTZDALE DRIVE CAMP HILL PA 17011-7809 #3551 - 1 FILE COPY SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, : 1N THE COURT OF COMMON PLEAS Formerly Known As WEST SHORE TEACHERS FEDERAL : CUMBERLAND COUNTY, PENNSYLVANIA CREDIT UNION Plaintiff : : NO. 01-6009 CIVIL TERM BEVERLY J. THOMAS : Defendant : CIVIL DIVISION - LAW IMPORTANT NOTICE TO:BEVERLY I. THOMAS, Defendant(s) DATE OF NOTICE: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL I-[ELP: CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 NOTICIA IMPORTANTE A:BEVERLY J. THOMAS, Demandado(s) FECHA DE NOTICIA:~ USTED NO HA COMPLIDO CON EL AVISO ENTERIOR PORQUE HA FALTADO EN TOMAR MEDIDAS REQUERIDS RESPECTO AESTE CASE. SI USTED NO ACTUA DENTRO DE DIEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SEIA REGISTRADO CONTRA USTED SIN UNA AUDIENCIA y USTED PODRIA PERDER SU PROPIEDAD O OSTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TTANE ABOGADO O NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VAYA O LLAME CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Formerly Known As WEST SHORE TEACHERS FEDERAL CREDIT UNION Plaimiff BEVERLY $. THOMAS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-06009 CIVIL TERM : CIVIL DIVISION - LAW To BEVERLY $. THOMAS. Defendent(s) You are hereby notified that on ~ (Judgment) has been entered against you in the above-captioned case. ,20ea. khe tonowing DATE:~;~.. J ~u&?nent ente~d in the amount of $6,447.71. Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: BEVERLy J. THOMAS 756 SYCAMORE AVE MYRTLE BEACH SC 29577 A/BEVERLY J. THOMAS, Def~ndido/a Defendidos/as Por este medio se le esta notificando que el de del 20__, el/la siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el ePigrafe. FECHA: Protonoterio Cerfi~ao que la siguiente direction es la del defendido/a segun indicada en el cetificado de residencia: BEVERLY J. THOMAS 756 SYCAMORE AVE MYR~E BF_~kCH SC 29577 Abogado del Demandante