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HomeMy WebLinkAbout99-05606 ..;wA (En:e rj 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 $ P I A EEM '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 d N U a ? 3 ok ° ? Z 4 Q f ? k 6 a 0? 0 4 m 0 _ ? 3 °a W H O M 3 f i m y 4 C _ _ z s -- L L m It- . . 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