HomeMy WebLinkAbout99-05606
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WEST SHORE TEACHERS FEDERAL
CREDIT UNION
Plaintiff
V.
WILLIAM P. LONGSTREET and MARGARET
LONGSTREET
Defendants
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9C/ - SG06
CIVIL DIVISION - LAW
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET
FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER
THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE
PERSONALLY OR BY 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 MAY BE ENTERED
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE
COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY
LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
WEST SHORE TEACHERS FEDERAL
CREDIT UNION
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. (J g. 1-606 6t?PTi,
WILLIAM P. LONGSTREET and MARGARET CIVIL DIVISION -LAW
LONGSTREET
Defendants
The Plaintiff, WEST SHORE TEACHERS FEDERAL CREDIT UNION, by its attorneys, KNUPP,
KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of
SEVENTEEN THOUSAND, FIVE HUNDRED THIRTY-TWO DOLLARS AND SEVENTY-TWO CENTS
($17,532.72), along with costs of this suit and interest thereon at the rate of 11.91/6 per annum from September 1,
1999 upon a cause of action of which the following is a statement:
The Plaintiff, WEST SHORE TEACHERS FEDERAL CREDIT UNION, is a federal credit union
organized and existing under Federal laws, having its principal office and place of business at 1213 Slate Hill Road,
Camp Hill, Cumberland County, Pennsylvania 17011.8012.
2. The Defendant, WILLIAM P. LONGST'REET, is an adult individual residing at 6153 Newgate Circle,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. The Defendant, MARGARET LONGSTREI%I', is an adult individual residing at 6153 Newgate Circle,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
F:\USER\KATHY\CMPLAINT\2537B.WST
4. On or about June 26, 1992, Defendants did apply, complete, execute, and agree to the terms and
conditions for credit in the form of Plain ffs Loanliner Credit Agreement. A true and correct copy of said agreement
is attached hereto at Exhibit "A"
5. As further evidence of the terms of the ban is the Advance Request Voucher executed by Defendants
and hereto attached, made a part hereof, and marked as Exhibit "B".
6. Defendants are indebted to Plaintiff in the principal amount and interest of FOURTEEN
THOUSAND, SIX HUNDRED AND THIRTEEN DOLLARS AND EIGHTEEN CENTS ($14,613.18).
Defendants have defaulted in the payment terms as agreed upon with Plaintiff.
8. Due to Defendants' default in payment of said account, attorney's fees have been added to said
account in the total amount of TWO THOUSAND, NINE HUNDRED NINETEEN DOLLARS AND FORTY-
FIVE CENTS ($2,919.45).
9. The balance due and owing by Defendants to Plaintiff is the sum of SEVENTEEN THOUSAND,
FIVE HUNDRED THIRTY-TWO DOLLARS AND SEVENTY-TWO CENTS ($17,532.72), as appears by the
Statement of Account hereto attached, made a part hereof and marked as Exhibit "C".
10. Plaintiff has frequently demanded payment from Defendants of said amount due and owing as
aforesaid, but Defendants have refused and neglected and still refuse and neglect to pay said amount thereof.
F:\USER\KATHY\CMPLAINT\25378.WST2
WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of SEVENTEEN THOUSAND,
FIVE HUNDRED THIRTY-TWO DOLLARS AND SEVENTY-TWO CENTS ($17,532.72), along with costs of
this suit and interest thereon at the rate of 11.9% per annum from September 1, 1999.
Respectfully submitted,
KNUPP ODAK & IMBLUM, P.C.
Robert D. Kodak
407 North Front Street
Post Office Box 411848
Harrisburg, PA 17108.1848
(717) 238-7151
Attorney ID No. 18041
Attorney for Plaintiff
F:\USER\KATHY\CMPLAINT\25378.WST3
Application
19 1213 Slate Hill Road
Camp Hill, PA 17011
APF 'W q (717) 737.4152
HOW TO
APPLY
• Please complete red sections 1 through B. Be sure to check all applicable boxes.
• Sign section 9
• Return this application to the Credit Union
1 Check the appropriate boxes to Indicate the type of account(s) and type of Credit forwhIch you are applying. Married Applicants may
apply for a separate account.
NOTEAND ? LOANLINER® Account/Loan
COMPLETE D Credit Card Account
? 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 stale (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: CdAd2i'? //oW o Al 7b *OVW
Collateral: 41'17e D147 dt-14 f
Repayment: ? Payroll Deduction ? Cash ? Automatic Payment ? Military Allotment ?
STATEMENT ? Credit Disability Insurance Check coverages) desired. The credit union will disclose the cost of this voluntary insurance to
OF INTENT you. A separate insurance election which discloses the terms and conditions must be signed
for coverage to become effective.
Z APPLICANT
APPLICANT please print in ink or type.
INFORMATION NAME (taM-Flral-Inlael)
Longstreet William Price
DRIVER'S LICENSE NUMBEFUSTATE
18-601-085 PA.
ACCOUNTNUMBER SOCIAL SECURITY NUMBER
6062-00 1196-48-3578
BIRTH DATE HOMEPHONE BUSINESS PHONE/EXT.
8/29/59 1717)763-1196 (717)783-5006
PRESENT ADDRESS (Slyest-Ciry-SMts-Zip) ®OWN ?RENT
1494 Letchworth Road ! YEARS
Camp Hill, PA. 17011-7521 ADoRFSs 3
PREVIOUS ADDRESS (Street-eery-Slab-Zip) ?OWN [RENT
611A Geneva Drive YEARS
Mechanicsburg, PA. 17055 AO?R SS 2
COMPLETE FORJOINT CREDIT, SecuREOCREDIT OR IFYOU LIVE IN COMMUNITY
GjjOPERfY STATE:
LAY MARRIED ?SEPARATED ?UNMARRIED ISingle-Divorced-wldv«aEl
LIST AGES OF DEPENDENTS NOT LISTED BY OTHER APPLIGN I
1 C1Year old
(E¢iuda S•Iq
0 CO-APPLICANT ? SPOUSE [] GUARANTOR
Use "SAA" if information is "Same As Applicant':
NAME ILaa - First - InigaB
Longstreet Margaret
ORIVER'S LICENSE NUMBERISTATE
19-031-060 PA.
ACCOUNT NUMBER SOCIAL SECURITY NUMBER
7838-40 I 170-52-8179
BIRTH DATE HOMEPHONE BUSINESSPHONEIEXT.
3/18/60 (717)763-1196 (717)238-8666
PRUWADDRESS Mtrwt-Cly-Stele-Zip) [.gOWN?SENT
1494 Letchworth Road Y
EAR's
AT TH
CaM Hill PA. 17011-7521_ ADDRESS 3
PREVIOUSADDRESS (Street-City-Sum-00 ?OWN®RENT
611A Geneva Drive YEARS
Mechanicburg, PA. 17055 ADDRESS 2
COMPLETE FOR JOINTCFIEDIT, SECUREDCREDIT OR IFYOU LIVEIN ACOMMUNfiY
PROPERTY STATE:
MMARRIED ?SEPARATED ?UNMARRIED (Single-Dlarcetl-Wdond
LIST AGES OF DEPENDENTS Nor LISTED BY APPLICANT
(EUiude Seln None
3 NAME AND ADDRESS OF EMPLOYER
EMPLOYMENT PA. D.O.T. Engineering District 8-0
INFORMATION 2140 Herr Street Harrisburg, PA. 17103
TITLEIGRADE SUPERVISOR
Civil Engineer
STARNNG DATE IF SELF EMPLOYED. TYPE OF BUSINESS
April, 1984
IF EMPLOYED IN CURRENT POSITION LESS THAN FIVE YEARS. COMPLETE
' PREVIOUS EM PLOYER NAME AND ADDRESS STARTING DATE
ENDING DATE
MILITARY IS OUTY STATION TF NSFER EXPECTED DURING NEXT YEAR? YES ?NO
WHERE N/A ENDINGISEPARATION DATE
NAME AND ADDRESS OF EMPLOYER
Edgewater Psychiatric Hospital I 17103
1829 North Front Street, Harrisburg, PA.
TITLEIGRADE SUPERVISOR
Registered Nurse
STARTING DATE IF SELF EMPLOYED, TYPE OF BUSINESS
Septem`'er, 1989
IF EMPLOYED IN CURRENT POSITION LESS THAN FIVE YEARS. COMPLETE
PREVIOUS EMPLOYER NAME AND ADDRESS STARTING DATE
Polyclinic Medical Center January,1989
E
Harrisbur;, PA. 17103 ENDING
Sectembember,1989
IS DUTY STATION TRANSFER EXPECTED DURING NEXT YEAR ? SEYES PARATION NO
WHERE N/A ENDING I 4 NAME AND ADDRESS OF CREDITOR(S) OF DEBTS PAID OFF PA.TEdEPW@ NAME AND ADDRESS OFCREDIMR(S) OF DEBTS PAID OFF TELEPHONE
Caldwell Jewelers, Philadelphia 864-1292
REFERENCES Hill 763-1440
Cam
ial
Fi
Please Include p
,
nanc
Avco
ATIVE
RE RELATIONSHIP
Street, City, State NAME AND ADDRESS OF NEAREST REUTIVE RELATIONSHIP
F L1e[
WI YO L
NA ME AND ADDRESS OF NEAREST
NOr UVINGWITHYOU Brother
and Zip. N UvIN
.C..
?eu3I -,ongstreet S.C. HD ONE A2150n Medynec HOME PHONE
CSalt Marsh Cove, Pawleys Islanc 2371612
2 430 Wit'..t-.;- Drive Lanhorne PA.2157578386
HOMEPHONE
.
FRIEND .__ LIVHIBI
NAME AND ADDRESS OF PERSONAL It
All OF PERSONAL FRIEND
T
5 NOTICE: Alimony chile aoppon. or separate Ineinlenance income need nol be NOTICE: Allmon child eu
rwaalaa II You de naI chooaa t have?
INCOME 1 0 c need revealed it vau Eo na eh?u m n:e,:v.°,hnence income need not be
EMPyQr?tENT NCCpME CTHER INCOME eWeM,
INFORMATION $ .7id1N. (?&'p Month $ PER . aE.?r-?J-?JJ.tEfjJ,INCOME
D NET M GROSS E QV 'P"'W • "U PEP ' ?" NEW'doeFtMonth
-- *ac mF R/AI"P__s?94ra76 ?NET SGaoss)jlwA +Rb€?1Tgaberger
6 SHAREORAFTOR M NO DO E9 FDEPOSITORY SHARE DRAFT OR NAME ANDA 0
ASSETS E8 OF DEPOSITORY
CHECKINOAMOUNT Ip , ,?',?,?, CHECKINGAMOUNT W•S.T.EQ.?1
$ Harrisburg, PA. 17103($ Camp Hill PA 17011
SAVINGS AMOUNT NAMa AnrR I. SOF DEPOSITORY SAVINGSAMOUNT NAME AND ADORES OF DEPOSITORY
t'. J. ..
$ Harrisbur Ug, PA. 17103 W•S.T__F:i if. Check bear for
Applicant/Olher.
List am assets
and account
number;;}-
Attach odw
sheets if
necessary.
7 AP PMCA
DEBTS 1TnI
In addition to
RentlMongage
list all DOW debts
(for examplm auto
loans, Credit
Calm second
motgagm home
assoc. due;
alimorry, child
support, child
cam medlcaL J
utilities, auto
insurance, eta)
Please
s
a
u
e
separate line for
each credit card
and auto loan.
Attach other
sheets it
necessary.
L
IST
ACCOUNT
INI
box 1332, Madison, WI 53701 Acct758323
GA.
Alexandria
PA
ORIGINAL
MLANCE PRESENT
SALAHCE MONTHLY
PAYMENT
$ $ $747.00
$ $3261.1" $110.00
$ $2826.8 $ 58.32
$ $1460.3C $ 41.OC
$ $ 696.0 .
$ 24.OC
$ $2132.3 $ 78.OC
$ $ 737.2 $ 115.0C
$ $-.100-0c $ 90.0C
See Part Tdo TOTALS Is 1$24164.01$1443.31
8 IFA"YES" ANSWER IS GIVEN TO A QUESTION, EXPLAIN ON AN ATTACHED SHEET APPLICANT OTHER
FINANCIAL YES No YEs No
INFORMATION HAVE YOU ANY OUTSTANDING JUDGMENTS?
These questions HAVE YOU EVER FILED FOR BANKRUPTCY OR HAD A DEBT ADJUSTMENT PLAN CONFIRMED UNDER CHAPTER 137
X X
Appyropplicant both
and HAVE YOU HAD PROPERTY FORECLOSED UPON OR REPOSSESSED IN THE LAST T YEARS? X X
A
Other. ARE YOU A PARTY IN A LAWSUIT?
AP
PLICANT
OTHER _
LIST NOME ANO ALL OTHER ITEMS YOU OWN AND LOCATION OF PR
OPERTY
AA EaamPla:alp,Dam, SWAA CW. HowahoM 0ooda. RAW EAAA•e, I A 17011
O AE COLLATE141L
OMCOLLOAN MOTH
NOME 1994 Letchcyorth Rd. Como Hill, PA.17011 Yes JC No
rninshin s M YES no
n a ES
x
No
tomobile ES x NO
NT
X X
ARE YOU OTHER THAN A U.S. CITIZEN OR PERMANENT RESIDENT ALIEN? X X
IS YOUR INCOME LIKELY TO DECLINE IN THE NEXT TWO YEARSo X X
ARE YOU A CO-MAKER. COSIGNER OR GUARANTOR ON ANY LOAN NOT LISTED ABOVE? X
FOR WHOM (NAM* of Othna OblNated on Loan): TO WHOM INema el Creditor):
9 You understand that when applicable, a Personal Identification You also promise that everything you have stated in this application
SIGNATURES Number(PIN)may be issued. This PIN, when validated will allow you, is correct to the best of your knowledge and that the above information
it there are an the co•appllcanl and any authorized users, to access your credit is a complete listing of all your debts and obligations. You authorize
important changes, union's CREDIT CARD/ATM accounts through participating Auto• the credit union to obtain credit reports in connection with this
you will AD* us mated Teller Machine(ATM) networks, subject to the terms and application for credit and for any update, renewal or extension of the
in writing lmmedl- disclosures of the Credirt CardA m Land the Electronic Funds credit received. If you request, the credit union will tell you the name
ately. You also Transfer Disclosure I0CR T CARDIATM Access Card. You
and address of any credit bureau from which it received a credit report
agree to no* us understand th us of yo credit . -rd will constitute acknowl• on you. You understand that it is a federal crime to willfully and
of any change in CARP nTMfep Ca disc oxen oth terms of the CREDIT deliberately made provide Federal Credit Unions or SleteCh en Chartered Credit
your name address f 1 applications
employment Unio sinsured by NCUA.
within a reasonable ?r I
time thereafter. XI .AUTLe clrw ^ tom°f CI?/ F
10
CREDIT
UNION
INFORMATION
Do not write in
this section-
for credit union
use only.
Check applicable
box(es).
APPROVED $ $ $ $
DATE LIMITS SIGNATURE LINE OF CREDIT OTHER OTHER DEBTRATIO
D LOAN OFFICER ADVANCE APPROVED: DYES ONO DCOUNTER OFFER WILL BE MADE. IF ACCEPTED. ADVANCE APPROVED
OCREDIT COMMITTEE OR OTHER COUTSIOE INFORMATION CONSIDERED: DYES DNO IF YES. ATTACH ADDITIONAL SHEET AND DESCRIBE
REFERRED TO/REASON(S) FOR REFERRAL.
SPECIFIC REASON(S) FOR nEJECTION.
SIGNATURES: DATE DATE
?LOAN OFFICER
V
WEST SHORE TEACHERS
hOMUNERS FEDERAL CREDIT UNION
1213 ampIHill PA 17011
Credit Agreement Rit C
(717) 737.4152
HOW TO • Please complete red section 1
APPLY a Read section 2
• Sign red section 3
• Return this Credit Agreement to the Credit Union
to An Incomplete or unsigned form may delay processing
• You will receive your copy of the Credit Agreement and insurance information
IMPORTANT The following Is part of your LOANLINER'a Open-End Plan. Read Please see the accompanying Addendum for a disclosure of your
this information before signing on the opposite side of this page. various Loan Subaccounts, Present Annual Percentage Rates,
Dally Periodic Rates and any additional information.
CREDIT You can protect your financial future by signing up for voluntary Your credit union will be happy to explain the various Insurance
INSURANCE credit insurance below. Enroll by simply indicating your preference options and coverage. The cost Is reasonable.
in the "Credit Insurance Application" section below.
"You" or "Your" means the member and the Joint Insured (if applicable). same as it accrues on amounts of advances which are added to your Loan
CREDIT Credit Insurance Is voluntary and not required In order to obtain your Balance.
INSURANCE loan. You may select any insurer of your choice. You have established DO NOT SIGN THIS APPLICATION IF IT CONTAINS ANY BLANK
APPLICATION an open?end Loan Plan with the Credit Union, Your Loan Plan may consist SPACES. This application Is void and will not be used In s contest
of one or more Loans. You are applying to the Society for credit Insurance. If all blank spaces have not been completed, If the member has not
You must s!
9n You authorize the charges for insurance to be added to your Loan Balance signed and dated the Application, and It the Application has not been
whether Or not each month and understand that interest will accrue on these charges the witnessed.
Insurance Is INSURED MEMBER DATE OF BIRTH ACCOUNT NUMBER DATE OF ISSUE OF CERTIFICATE
slowed.
JOINT INSURED MEMBER DATE OF BIRTH ACCOUNT NUMBER SECONDARY BENEFICIARY pI fine doom to Mme coal
UNDER CREDIT LIFE AND DISABILITY, THE MAXIMUM ELIGIBILITY AGE FOR COVERAGE IS 65 WITH NO TERMINATION
AGE REQUIREMENT.
STATEMENTS MADE BY YOU ARE REPRES
YES NO COVERAGE SELECTED
SINGLE CREDIT LIFE COST PER a100 OUR
MONTHLY LO BALANCE
NIA
JOINT DIT LIFE COST P 100 OF YOUR NIA
MONT Y LOAN BALANCE
ARE YOU
A IMUM AGE
N/A
UNOER AGE? OR INSURANCE
MAXIMUM INSURABLE DALAN
PER LOAN ACCOUNT
$ N/A
SIGNATURE OF BORRO R ELIGIBLE TO OE UREO DATE
lae wm le aMit lM et0orel
X NIA
SIGNATURE OF INT INSURED MEMBER GATE
X N/A
WITH DATE
AND ARE TRUE TO THE BEST OF YOUR KNOWLEDGE AND BELIEF:
nnenl'f rem A.11 ITV wen. A Mne
YES NO COVERAGE SELECTED PREMIUM SCHEDULE
X CREDIT DISABILITY SEE SEPARATE
RATE SCHEDULE
X ON THIS DATE. ARE YOU PHYSICALLY WORKING FOR A SALARY OR
WAGES A MINIMUM OF 25 HOURS A WEEK?
ARE YOU
65 MA%I
MUM AGE
NON
X UNDER AGE? INSU
FOR RANCE
MA%IMUM MONTHLY TOTAL
DISABILITY BENEFIT
$ 600
It you are totally dlsabledT•more than 14 days, then the
+4441b, ty bietsef ill begin Ilh the 15th day of disability.
,
A E F O POWER d.. ELI E I
I t? Mi I Ce.ee,
w UREO d GATE
??
ryrr
X
X
11 A• --
l?
S v DATE
X rt G ??-ya,
2 This LOANLINERN Credit Agreement and Truth in Lending
CREDIT Disclosure will be referred to as "this Plan". "You" and "your"
"
"
AGREEMENT means
credit union
mean each person who signs this Plan. The
the credit union whose name appears above or anyone to whom
AND TRUTH the credit union transfers its rights under this Plan.
IN LENDING
DISCLOSURE HOW THIS PLAN WORKS - The credit union anticipates that
you will borrow money (called advances) under this Plan from time
to time. The credit union, however, Is not required to make
advances to you under this Plan and can refuse a request for
an advance at any time. The Addendum describes the different
types of credit (called subaccounts) available under this Plan. If
you have been approved for credit under a subaccount marked
with a star (•), you will be/9-iven 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 corresponding 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.
(Continued)
. CUNA MUTUAL INSURANCE SOCIETY. 19AD. 82 . aA 86 69 ALL NO,IS RESERVED PAGE I
2
CREDIT PAYMENTS - The amount of payments for an advance is
determined according to the payment schedule in the Addendum. giving you advance notice. If Immediate payment Is demanded,
you will continue to pay Interest, at the applicable Inter
t
AGREEMENT
Payments are due on the fast day of each month unless a different
data is set by the credit union at the time of an advance
If th es
rates
in effect under this Plan, until what you owe has been repaid. If
d
f
AND TRUTH
IN LENDING .
e
Addendum has no payment schedule for a subaccount, the a
emand
or immediate payment has been made, the shares and
deposits given as security for this Plan can be applied toward
DISCLOSURE
DISC
amount and due date of payments will be determined at the time
of each advance s
what you owe. The credit union can also exercise any other rights
. given by law when you are in default.
Payments must include any amount past due and any amount by
which you have excaeded 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 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 sub•
account 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 treat.
ment 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
may secure all amounts you owe the credit union now and in the
future. However, the credit union specifically waives any security
interest it may have in your dwellings given through any other
mortgages or security agreements.
DEFAULT - You will be in default if you do not make a payment
of the amount required when it is due. You will be in default if you
break any promise you made under this Plan or if anyone is in
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 insolvent, if you make any false or mis.
leading statements In any credit application or update of credit
information, or if something happens which the credit union be.
lieves 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 balgace under this Plan without
PROPERTY INSURANCE - You will be required to purchase
property insurance on certain types of security that you give for
advances. You may purchase the property insurance from anyone
you choose that is acceptable to the credit union.
CANCELLING OR CHANGING THIS PLAN - The credit union
has the right to change the terms of this Plan from time to time
after giving you any advance notice required by law. Any change
will apply to future advances, and at the discretion of the credit
union, and subject to any requirements of the applicable law, will
also apply to unpaid balances. An increase in the daily periodic
rate under a 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 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 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 o7 dnly
one of you and that the check can be issued to only one of you.
If you give inconsistent instructions, the credit union can refuse
to follow your instructions. Each of those who sign this Plan will
be individually and jointly responsible for paying the entire amount
owed under this Plan. That means the credit union can enforce
its rights under this Plan against any one 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.
It is imports t a u read all the provisions (9
the Credit A
na?t(and( ' e du hgroughly befog you sn below. You
CREDIT
UNION
INFORMATION
Do not write in
this section-
for credit union
use only.
Check applicable
box(es).
read the LOANLINERO Credit Agreement and by signing below,
you,agree to be bound by the terms of the agreement.
APPROVED I
LIMITS $ $ $ $
DATE SIGNATURE LINE OF CREDIT ?. ?Im _ imam BEST RATIO
OLOAN OFFICER ADVANCE APPROVED: OYES ONO C1 COUNTER OFFER WILL BE MADE, IF ACCEPTED, ADVANCE APPROVED
OCREDIT COMMITTEE OR OTHER OUTSIDE INFORMATION CONSIDERED: DYES ONO IF YES, ATTACH ADDITIONAL SHEET AND DESCRIBE.
REFERRED TO/REASON(S)FOR REFERRAL:
OFFER:
SPECIFIC REASON(S) FOR REJECTION:
SIGNATURES: DATE DATE
OLOAN OFFICER X X
?CREDIT COMMITTEE DATE DATE
O ECOA NOTICE AND REASON FOR REJECTION SENT OR DELIVERED ON (DATE) BY (INITIALS)
PAGE 2
LCMUML Advance Request Voucher
1 MEMBER INFORMATION WEST SHORE TEACHERS
F _ 92 M COUNT NUMBER
8 FEDERAL CREDIT UNION
1213 Slate Hill Road
R
BOCMI.,SECVB.RY',(I?AIBEq "
16 Y?UM
``
E
" 15 Camp Hill, PA 17011
11
JJ CC 4400??33 ?/ tltl ..77 11
196
l
T
1 e (717) 737.4152
M (PYRSi)
aREET, W?`EIAM P
ON/TMq YOV REQUEST THE FOLLOWING
ADVANCE SUB ECT TO THE TERMS
10,450.00
LO
N
NERDIC
EO
T
QH
ENT
A
LI
$
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'RESB1494 LETCHWORTH ROAD 08-06-1992 DATE wANTEDESTABELP?i4fEJOINT OPEN END
CHECK BO% IF
'TAMP HILL, SPA 17011-7521
NEW ADDRESS
OR PNONE NO.
2 PAYMENT TERMS
DMLY PENGDID BATE AMMIIAI OCOPCMTARC OATG INTFRFPT PLTF IC niu[e nu.erace meenee.. ...........
• • , FIXED F71 VARIABLE N/A
AM VE OiN FIUROES AMOUNT ADVANCED PREV. LOANUNERc 9AIdNCE (THIS SUBACCOUNT) NEW BAUNSE
S t Y 15,450.00 + N/A =15,450.00
.•.. um=wc rm .ncuu[nbT IUTALI`M1ALLAGOT5 REMININGLINEOF
N/ 463. 0 09-15-1992 Monthly . s N/A SCIVDq LIMIT
PROJECTED LOAN TERM:
43 MONTHS
TS OF THE AMOUNT AND AT THE TIME SHOWN IN THE PAYMENT TERMS SECTION ABOVE. IF ONE
ALSO AGREE TO ITS TERM(S).
ADE IN THE TERM(S) OF YOUR LOANLINER-
BY MAIL TNgU OFFICE FIRST ?
ADVANCE INSURANCE CREDIT
?
CHANGE
DISABILITY
JOINT
CREDIT LIFE
?I
PAYROLL
DEDUCTION
AUTOMTIC
BY PHONE INT
ERNALLY SUVA
S
SINGLE H ? MIUMA Y
BY CV
ADVANCCIE
E
CREDIT LIFE
CASH ALLOTMENT
NUMBER DEPOSIT ACCT. NUMBER RLANIBUBACCOUNT NO. LOAN NUMBER
4322 030
MBER REFERENCE NUMBER BRANCH NUMBER PROCESSED BY
YSURANCE SOOETY, IMO, N, N. W. 0, 90, ALL RIOTS RESERVED VSTOD4 670LL _
CREDIT UNION -
EXHIBIT 11Bn
emote V Scjieis Federal OP
5? d
STATEMENT OF ACCOUNT
DATE: September 2, 1999
MAKER: William P. Longstreet
ca4AKER: Margaret Longstreet
HOME ADDRESS: 6153 Newgate Circle
Mechanicsburg, PA. 17055
HOME PHONE: 717-697-6178
OUR ACCT # 6062-3
MAKER SOCIAL SECURITY # 196-48-3578
CCMAKER SOCIAL SECURITY # 170-52-8179
Principal Amount Owed: $ 14,069.40
Interest Owed: $ 543.78
Penalty (208 of Principal & Interest): $ 2919.45
Total Amount Claimed: $ 17,532.72
EXHIBIT "C"
1213 SLATE HILL ROAD • CAMP HILL, PA 17011-8012 • TEL: (717) 737.4152 • FAX: (717) 737-0589
SEP 07 '99 02:21PM KNUPP & KODAK PC
VERIFICATION
P.6
I, Linda M. Sto=, Operations Manager of West Storm Teachers Fedaal Credit Union, verify that the
statemada nude in the afortgoin4 docwnent m true and correct. I understand that false statements herein ere made
subled to the penalties of 18 Pa. C. S. §4904, ralatuog to uesworn falsification to authorities.
WEST SHORE TEACHERS FEDERAL CREDIT UNION
1JWx M. Stoner, Operations Manager
Dated:
Fr\USER\KATHY\CMPLAIMT\25378.t9ST
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CASE NO: 1999-05606 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WEST SHORE TEACHERS FEDERAL CR
VS.
LONGSTREET WILLIAM P ET AL
JODY SMITH , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT was served
upon LONGSTREET WILLIAM P the
defendant, at 14:10 HOURS, on the 20th day of September
1999 at CUMBERLAND CO. SHERIFF'S DEPT. 1 COURTHOUSE SQUARE
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to WILLIAM P. LONGSTREET
a true and attested copy of the COMPLAINT
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service .00
Affidavit 00 R-7
Surcharge 8.00
X09 20%199DAK & IMBLUM
by
19_ A. D.
42
Sworn and subscribed o before me
this .2v 1' day of _
CASE NO: 1999-05606 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WEST SHORE TEACHERS FEDERAL CR
VS.
LONGSTREET WILLIAM P ET AL
JODY SMITH , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT was served
upon LONGSTREET MARGARET the
defendant, at 14:10 HOURS, on the 20th day of September
1999 at CUMBERLAND CO. SHERIFF'S DEPT 1 COURTHOUSE SQUARE
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to MARGARET LONGSTREET
a true and attested copy of the COMPLAINT
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 6.00
Service 10.54
Affidavit .00
Surcharge 8.00 rtdt9Fa i S miff
$24.b4 KN PP, KODAK & IMBLUM
09 20/1999
by _
y eri -
Sworn and subscribed o before me
this ,7° tt day of
19l _ A.D.
o nonoca y 14y&?-o gap