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HomeMy WebLinkAbout07-4483 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION PLAINTIFF THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA V. ZACHARY DEITCH DEFENDANT NOTICE CIVIL ACTION -LAW YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WI"THIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINSE YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 By: even we , Es uire Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION PLAINTIFF V. ZACHARY DEITCH DEFENDANT COMPLAINT 1. The Plaintiff is the Susquehanna Valley Federal Credit Union with a principal place of business located at 3850 Hartzdale Drive, Camp Hill, PA 17011-7809. Plaintiff is a federally chartered non-profit credit union 2. The Defendant Zachary Deitch is an adult individual residing at 329 South Front Street Apartment #1, Wormleysburg, PA 17043. 3. The Defendant is not a current member of the Armed Forces of the United States. IN THE COURT OF COMMON PLEASE CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION -LAW NO. 4'l- y 51 k3 Ccu~-f I .,~-~ COUNT 1: SVFCU LOAN 4. On April 6, 2006 Defendant executed a Loan Agreement attached as Exhibit "A" in the amount of Ten Thousand and 00/100 ($10,000.00) Dollars at 11.74% per annum. 5. The terms of Exhibit "A" required timely payments of $221.20 monthly for approximately sixty (60) months. 6. Defendant has been late numerous times in paying his minimum payment due on the Loan with $9,471.34 past due as of July 16, 2007. 7. Defendant has made no regular payments despite repeated requests. 8. Pursuant to the Loan Agreement the Defendant agreed to pay all "attorney fees" incurred in any collection action. (Page 3 of Exhibit "A"). WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount of $9,471.34 (principal plus past due interest) at 11.74% interest from July 16, 2007 with a per diem of $2.93 together with all court costs and an award of attorneys' fees. COUNT II: VISA CREDIT CARD 9. On September 22, 2005 Defendant executed a credit card application attached as Exhibit "B" which is a true and correct copy of the Visa Credit Card Application. 10. Defendant has been late numerous times in paying his minimum payment due on the credit card with $ 6,761.14 past due as of July 16, 2007. 11. Defendant has made no regular payments despite repeated requests. 12. Pursuant to the Loan Agreement the Defendant agreed to pay all "attorney fees" incurred in any collection action. (Paragraph 5 E of Exhibit "B"). WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount of $6,761.14 (principal plus past due interest) at 11.90 % interest from July 16, 2007 with a per diem of $1.80 together with all court costs and an award of reasonable attorneys' fees. Respectfully submitted, By 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Verification I verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. I verify that I am the President of the Susquehanna Valley Federal Credit Union and that I am authorized to execute this document. By: Step en J. rindamour, President SVFCU Date: 7/Zy/m~ SUSQUEHANNA VALLEY FEDERAL CREDIT UNION ' 3850 Harizdale Drive "`~ Camp Hill, PA 17011-7809 /7171 747_A ~ cn BORROWER 2 NAME BORROWER 2 ADDRESS ACCOUNT NUMBER DEPOSIT CHECK IN ACCOUNT NUMBER/OTHER: SOCIAL SECURITY NUMBER CHECK PAYABLE T0: REPAYMENT METHOD: CeSh BORROWER 1 EMPLOYER NAME WORK TELEPHONE NUMBER DATE HIRED GROSS MONTHLY SALARY SUSQUEHANNA VALLEY H-D 01/10/2005 x3,764.59 BORROWER 2 EMPLOYER NAME WORK TELEPHONE NUMBER DATE HIRED GROSS MONTHLY SALARY -_ 9 ~. , ~ rvv uUiv ~ nAVt i U INCLUDE INCOME FROM CHILD SUPPORT, SEPARATE SOURCE OF OTHER INCOME OTHER MONTHLY INCOME MAINTENANCE, OR ALIMONY UNLESS YOU WANT THE CREDIT UNION TO CONSIDER IT, x ~ ~~ LISI' ALL DEBTS OTHER THAN TO THIS CREDIT UNION (Attach additional sheetlsl if necessary.) PRESENT BALANCE ~ MONTHLY PAYMENT CURRENT INTEREST RATE GEMB/BRYN MN s 335.00 s 10.00 % AMS-SG/CLEMS a 5,971.00 s 80.00 % MEMBERS FIRST-JOINT 5 5,266.00 S 83.00 % s RENT s 200.00 You can now voluntarily elect to become insured with the coverages) shown below. In order for coverage to :becomeeffective. ou must meet all insurance eligibility requirements stated in the Credit Insurance Application/Schedule. NOTE: The insurance you're applying for contains certain terms and exclusions; Refer to your Certifioate for Coverage details. If you need a copy of the Insurance Certificate, just ask. By signing below, you authorize us to add the charges for the insurance to your outstanding balance each month. Coverage election applies to the entire balance on this subaccount. Insurance rates are subject to change. YOU ELECT THE FOLLOWING: COST PER 5100 OF YOUR MONTHLY LOAN BALANCE NAME OF INSUREDISI NO Single Credit Disability SEE SEPARATE NO RATE SCHEDULE NO Single Credit Life .070 NO Joint Credit Life .123 } DAILY PERIODIC RATE ANNUAL PERCENTAGE RATE INTEREST RATE IS: OTHER FEES (Amount and Description) NEW BALANCE THIS SUBACCOUNT "t .032164Y ~ 11.74000 % s O Fixed N/A s 10,000.00 MOUNT ADVANCED PAYMENT AMOUNT DATE DUE PAYMENT FREQUENCY LINE OF CREDIT LIMIT REMAINING LIMIT N s4,855.34 x221.20 05/06/2006 Monthly s s ~ Your term will be approximately 60 payments, which may be more or less, depending on whether' you prepay, have O late payments, or insurance is added, etc. Z :.;...:..; ... ::.:..::...: ;:.:.:..:..:........: ,.:..:..::::.::.. ~ :.:..,...:...:.....;, ..;. ;,..,:. ;,; .:; ...; .;....::; ~:.: ,:.:.:.::....... ,: f" THE ADVANCE IS SECURED BY YOUR SHARES, ALL PROPERTY SECURING OTHER PLAN ADVANCES AND LOANS RECEIVED IN THE PAST OR IN THE FUTURE, AND THE FOLLOWING W PROPERTY/MODEL YEAR I.D. NUMBER VALUE KEY NUMBER ~ SIGNATURE 0000 s U s O s ~ -- s PLEDGE OF SHARES AND/OR DEPOSITS 9 ACCOUNT NUMBER PLEDGE OF SHARES AND/OR DEPOSITS 8 ACCOUNT NUMBER By signing below, by endoroing the proceeds check or by using the amount advanced and deposited into your shore/share draft account you agree: 1. To make and be bound by the terms of this Security Agreement including the cross collateral clause; 2. The above information (a true and conect and the Credit Union will rely on that information and your credit report to make a credit decision; 3. To make payments acloaed above in accordance with the terms of your Plan. - ~ ° EXHIBIT OWER DATE BORROWER 2 SIGNATURE X (SEALI SIGNAT E OWNER OF COLLATERAL (Other than a Borrower) DATE SIGNATURE OWNER OF COLLATERAL (Other than a Borrower) E ® CUNA MUTUAL GROUP, 1980, 82, 84, 86, 89, 98, 99, 2000, 02 ALL RIGHTS RESERVED CREDIT UNION COPY vxxD65 (LASER) Susquehanna Valley Federal Credit Union Izachary Deitch 1Date 04/06/2006 I SECURITY AGREEMENT In this agreement all references to "credit union,' we," "our," or "us" mean the credit union whose name appears on this agreement and anyone to whom the credit union assigns or transfers this agreement. All references to "you," "your," and "borrower" mean each person who signs this agreement. All references to "the advance" mean the amount in the box labeled "Amount Advanced" on page one. All references to "the Plan" mean the Credit Agreement under which the advance was obtained. Some of the provisions of this agreement apply only if the Credit Union is state chartered. A credit union has a state charter if its name does not include the words "Federal Credit Union" or "FCU". This is a multi-state document which may be used to lend to borrowers in all states except Louisiana and Wisconsin. 1. THE SECURITY FOR THE PLAN -- By signing this security agreement in the signature area or under the statement referring to this agreement which is on the back of the check you receive for the advance, you give us what is known as a security interest in the property described in the "Security Offered" section on page one. The security interest you give includes all accessions. Accessions are things which are attached to or installed in the property now or in the future. The security interest also includes any replacements for the property which you buy within 10 days of the advance or any extensions, renewals or refinancings of the advance. It also includes any money you receive from selling the property or from insurance you have on the property. If the value of the property declines, you promise to give us more property, as security if asked to do so. 2. WHAT THE SECURITY INTEREST COVERS -- The security interest secures the advance and any extensions, renewals or refinancings of the advance. It also secures any other advances you have now or receive in the future under the Plan and any other amounts or loans, including any credit card loan, you owe us for any reason now or in the future, except any loan secured by your principal residence. If the property is household goods as defined by the Federal Trade Commission Credit Practices Rule, the property will secure only the advance and not other amounts you owe. 3. OWNERSHIP OF THE PROPERTY -- You promise that you own the property you give as security or if the Advance is to buy the property, you promise you will use the Advance for that purpose. You promise that no one else has any interest in or claim against the property that you have not already told us about. You promise not to sell or lease the property or to use it as security for a loan with another creditor until the advance is repaid. You promise you will allow no other security interest or lien to attach to the property either by your actions or by operation of law. 4. PROTECTING THE SECURITY INTEREST -- If your state issues a title for the property, you promise to have our security interest shown on the title. We may have to file what is called a financing statement to protect our security interest from the claims of others. If asked to do so, you promise to sign a financing statement. You also promise to do whatever else we think is necessary to protect our security interest in the property. You promise to pay all costs, including but not limited to any attorney fees, we incur in protecting our security interest and rights in the property, to the extent permitted by applicable law. 5. USE OF PROPERTY -- Until the advance has been paid off, you promise you will: (1) Use the property carefully and keep it in good repair. (2) Obtain our written permission before making major changes to the property or changing the address where the property is kept. (3) Inform us in writing before changing your address. (4) Allow us to inspect the property. (5) Promptly notify us if the property is damaged, stolen or abused. (6) Not use the property for any unlawful purpose. 6. CONSUMERS' CLAIMS AND DEFENSES NOTICE -- The fol%wing paragraph applies only when the box on page one is checked. l ~ ll(( J~`~L~) NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. 7. PROPERTY INSURANCE, TAXES AND FEES -- You must maintain property insurance on all property that you give as security under the Plan. You may purchase the property insurance from anyone you choose who is acceptable to the Credit Union. The amount and coverage of the property insurance must be acceptable to us. You may provide the property insurance through a policy you already have, or through a policy you get and pay for. You promise to make the insurance policy payable to us and to deliver the policy or proof of coverage to us if asked to do so. If you cancel your insurance and. get a refund, we have a right to the refund. If the property is lost or damaged, we can use the insurance settlement to repair the property or apply it towards what you owe. You authorize us to endorse any draft or check which may be payable to you in order for us to collect any refund or benefits due under your insurance policy. You also promise to pay all taxes and fees (like registration fees) due on the property. If you do not pay the taxes or fees on the property when due or keep it insured, we may pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the advance and you will pay interest on those amounts at the same rate you agreed to pay on the advance. We may receive payments in connection with the insurance from a company which provides the insurance. We may monitor our loans for the purpose of determining whether you and other borrowers have complied with the insurance requirements of our loan agreements or may engage others to do so. The insurance charge added to the advance may include (1) the insurance company's payments to us and (2) the cost of determining compliance with the insurance requirements. If we add amounts for taxes, fees or insurance to the unpaid balance of the advance, we may increase your payments to pay the amount added within the term of the insurance or approximate term of the advance. 8. NOTICE -- If you do not purchase the required property insurance, the insurance we may purchase and charge you for will cover only our interest in the property. The insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. 9. DEFAULT -- You will be in default if you break any promise you make under this agreement. You will also be in default if you are in default under the Plan. If you are pledging property, but have not signed the Plan, you will be in default if anyone is in default who has signed the Plan. 10. WHAT HAPPENS IF YOU ARE IN DEFAULT -- The fo/%wing paragraph applies to borrowers in Colorado, District of Columbia, lows, Kansas, Maine, Massachusetts, Missouri, Nebraska, West Virginia and state chartered credit unions lending to South Carolina borrowers. When you are in default and after expiration of any right you have under applicable state law to cure your default, we can demand immediate payment of the entire unpaid balance under the Plan without giving you advance notice. The fo/%wing paragraph applies to borrowers in a// other states and federal/y chartered credit unions /ending to South Caro/ins borrowers. When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. (Continued on next page) a r..nie u.nriini rnnno .onn a~ ae as A4 oA 842000.02. ALL RIGHTSRESERVEO CREDIT UNION COPY VXX065(LASER) (Susquehanna Valley Federal Credit Union (Zachary Deitch (Date 04/06/2006 I The fo/%wing paragraphs app/y to a//borrowers. You agree the Credit Union has the right to take possession of the property given as security under the Plan, without judicial process, if this can be done without breach of the peace. If we ask, you promise to deliver the property at a time and place we choose. We will not be responsible for any other property not covered by this agreement that you leave inside the property or that is attached to the property. We will try to return that property to you or make it available to you to claim. After we have possession of the property, we can sell it and apply the money to any amounts you owe us. We will give you notice of any public sale or the date after which a private sale will be held. Our expenses for taking possession of and selling the property will be deducted from the money received from the sale. Those costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded under the Bankruptcy Code. The rest of the sale money will be applied to what you owe under the Plan. If you have agreed to pay the Advance, you will also have to pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the Advance and to what you owe under this agreement. You agree to pay interest on that amount at the same rate as the Advance, or, if applicable, at the default rate disclosed on the Addendum, until that amount has been paid. 11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN -- We can delay enforcing any of our rights under this agreement any number of times without losing the ability to exercise our rights later. We can enforce this agreement against your heirs or legal representatives. If we change the terms of the Plan, you agree that this agreement will continue to protect us. 12. CONTINUED EFFECTIVENESS -- If any part of this agreement is determined by a court to be unenforceable, the rest will remain in effect. 13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE ---THE MOT_ OR VEHICLE IN THIS TRANS- ACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. 14. NOTICE FOR AR120NA OWNERS OF PROPERTY -- It is unlawful for you to fail to return a motor vehicle that is subject to a security interest, within thirty days after you have received notice of default. The notice will be mailed to the address you gave us. It is your responsibility to notify us if your address changes. The maximum penalty for unlawful failure to return a motor vehicle is one year in prison and/or a fine of $150,000. THE PROPERTY DESCRIPTION ON PAGE ONE IS PART OF THIS AGREEMENT. NOTICE: SIGN THIS AGREEMENT ON PAGE ONE. .. ....::.: ~::a:::::•:::~::::•:::~: BRANCH NUMBER:,:.>::. ~ ::::>:::. ~::::>:>: ~ ~::::~.:::: REQUESTED: MEMBER PAYS CHECK NUMBER: PREMIUM FOR: PLAN/SUBACCOUNT NO.: BY: TEL 04/06/2006 "'" $ BEFORE AFTER (Adverse Action Notice Sent) $ $ $ 23 85900 X LOAN OFFICER COMMENTS. X DATE X DATE © CUNA MUTUAL GROUP, 1980, 82, 84, 86, 89, 98, 99, 2000, 02, ALL RIGHTS RESERVED CREDIT UNION COPY VXX065 ILASERI .. SUSQUEHANNA VALLEY A table that includes the APRs and Requested Credit Limit F6tDERAL CREDIT UNION other required cost disclosures for $ ~(~~) 3850 Hartzdale Drive credit card applications is on the ®Camp HIII, PA 17011-7809 reverse side of this application. CREDIT CARD APPLICATION 17 7 7-41 Individual Credit: You must complete the Applicant section about yourself and the Other section about your spouse if: (1 you live in or the property pledged as collateral is located in a community property state (AK, AZ, CA, ID, LA, NM, NV, TX, WA, WI); (2) your spouse wilt use the account, or (3) you are relying on your spouse's income as a bads for repayment. If you are relying on income from alimony, child support, or separate maintenance, complete the Other section to the extent possible about the person on whose payments you are relying. OJoint Credit: If you are applying with another person, complete the Applicant and Other sections. NAM t - I flial) MOTHER'S MA N E NAME (Last • First -Initial) MOTHER'S MAIDEN NAME ACCOUNT NUMQ R SOCIA RIT`f N BER~ C• ACCOUNT NUMBER SOCIAL SECURITY NUMBER DRIVE N ERh DRIVER'S LICENSE NUMBER/STATE BIRTH AT HOME PH N WORK PHO E 5' tl~-1, BIRTHRATE HOME PHONE WORK PHONE/ EXT. c c EMAIL AD RESS ,~ ~ - ~~ - -' - E-MAIL ADDRESS - P T ADDR S (S eet - C • State • p) WN RENT. YEARS AT THI ADDRESS ~ PRESENT ADDRESS (Street • City -State -Zip) ^ OWN ^ RENT YEARS AT THIS ADDRESS PREV~If~~A ESS tie t - Cily 1 to - ) ~ WN RENT ,,,,// ~ YEARS AT THIS ADDRESS PREVIOUS ADDRESS (Street -City -State -Zip) ^ OWN ^ RENT YEARS AT THIS ADDRESS MORTGAGElRENT OWED TO: MORTGAGE/RENT OWED TO: MORTGAGE BALANCE ~~ MONTHLY PAYMENT NO. OF DEPENDENTS 8 AGE MORTGAGE BALANCE MONTHLY PAYMENT N0. OF pEPENDENTS & AGE COMPLETE FOR JOINT CREDIT, SECURED CREDITOR IF YOU LIVE IN A COMMUNITY PROPERTY STATE: MARRIED SEPARATED UNMARRIED Sfn to • Divorced -Widowed COMPLETE FOR JOINT CREDIT, SECURED CREDITOR IF YOU LIVE IN A COMMUNITY PROPERTY STATE: MARRIED SEPARATED UNMARRIED Sin le -Divorced -Widowed NAME~A(JQ ~IDDRE~ OF_EMPLOYER p eta l~/1 lNtR / ., _ NAME AND ADDRESS OF EMPLOYER START~~/O -,.,Y I POSITION ~~ 1p~ nB ^~'n_ ~ ~. I (START DATE I POSITION NOTICE: ALIMONY CHILD SUPPORT, OR SEPARATE~Ilu AINTENANCE INCOME NEED NOT BE REVEALED NOTICE: ALIMONY, CHILD SUPPORT, OR SEPARATE MAINTENANCE INCOME NEED NOT BE REVEALED IF YOU DON T HOOSE T HAVE IT CONSIDER IF Y D N T H SE TO HAVE IT N 1 R D. EMPL ENT( COME OTHER INCOME EMPLOVMENTINCOME `OTHER INCOME $ ~~,_ PER $ PER $ PER $ PER ^NET GROSS SOURCE ^NET ^GROSS SOURCE NA E AN ADDRESS OF P VI US EMP YER START D E/E D DATE NAME AND ADDRESS OF PREVIOUS EMPLOYER START DATE/END DATE l ~ C V UE BALANCE MONTHLY PAYMENT SAVINGS $ CREDITO R Y $ $ CHECKING $ CREDITOR $ $ CREDITOR $ $ OTHER PROPERTY $ CREDITOR $ $ OTHER $ AUTO $ $ AUTO MAKE,11,~,,, ~„ YEAR 1t?Ir~~ OTHER $ $ IF YOU ANSWER "YES" TO ANY QUESTION OTHER THAN #1, EXPLAIN ON AN ATTACHED SHEET. YES ICNOT YEOSH NO 1. ARE YOU A U.S. CITIZEN OR PERMANENT RESIDENT ALIEN? 2. DO YOU CURRENTLY HAVE ANY OUTSTANDING JUDGMENTS OR HAVE YOU EVER FILED FOR BANKRUPTCY, HAD A DEBT ADJUSTMENT PLAN CONFIRMED UNDER CHAPTER 13, HAD PROPERTY FORECLOSED UPON OR REPOSSESSED IN THE LAST 7 YEARS, OR BEEN A PARTY IN A LAWSUIT? 3. ARE YOU A CO•MAKER, CO-SIGNER OR GUARANTOR ON ANY LOAN NOT LISTED ABOVE? FOR WHOM (Name of Others Obligated on Loan): TO WHOM (Name of Creditor): RELATIONSHIP: jiflJL- (~ NAME AND ADDRESS OF NEAREST RELATIVE NOT LIVING WITH YOU: OHIO RESIDENTS ONLY: The Ohio laws against discrimina on require that all creditors make credit equally available to all creditworthy customers, and that credit reporting agencies maintain separate credit histories on each individual upon request. The Ohio Civil Rights Commission administers compliance with this law. WISCONSIN RESIDENTS ONLY: (1) No provision of any marital property agreement, unilateral statement under Section 766.59, or court decree under Section 766.70 will adversely affect the rights of the Credit Union unless the Credit Union is furnished a copy ~ HOtv1E PHONE: of the agreement, statement or decree, or has actual knowledge of its terms, before the credit is granted or the account is opened. (2) Please sign if you are not applying for this account or loan with-your spouse. The credit being applied for, if granted, will be incurred in the interest of the marriage or family of the undersigned. ~„ _~ SIGNATURE FOR WISCONSIN RESIDENTS ONLY DATE You promise that everything you have stated in this application is correct to the best of your knowledge. If there are any important changes you will notify us in writing immediately. You authorize the Credit Union to obtain credit reports in connection with this application for credit and for any update, increase, renewal, extension, or collection of the credit received. You understand that the Credit Union will rely on the information in this application and your credit report to make its decision. If you request, the Credit Union will tell you the name and address of any credit bureau from which it received a credit report on you. It is a federal crime to wilif and deliberately provide incomplete or incorrect information on loan applications ma e t federal credit unions or state chartered credit unions insured by NCUA. You understand that the use of your card will constitute acknowledgment o1 receipt and agreement to the terms of the credit card agreement. A condition of your account is your granting us a security Interest in your share accounts. By signing below you grant us a security interest in all individual and joint share and/or deposit accounts you have with us now and in the future to secure your credit card account. Shares and deposits in an Individual Retirement Account and any other account that would lose special tax treatment under state or federal taw if given as security are not subject to this security interest. When you are in default we may apply the balance in these accounts to any amounts due under the credit card agreement. -- -- _ ..._.. _._.-... _.._ g is ®CUNArMUTUAL GROUP, 1995, 2001, ALL RIGHTS RESERVED DETACH AND RETURN THIS APPLICATION TO YOUR CRE !J JL-19-2007 15:23 SUSQUEHANNA VALLEY FEDERAL CREDiT UNION '3850 Hartzdale Drive ® Camp Hill, PA 17011.7809 (717)737-4152 =-SUSQ. VAL. FCU f1f4YlGVGG ~.~~ ~~ AMERICA'S ~~~ CREDIT UNIONS' Classic/Platinum VISA CREDIT CARD AGREEMENT In this Agreement the words "you" and "yowl" mean each and all of those who agree to De bound by this Agreement;'Cerd" mxcns the VISA credit card and any duplicates, renewals, or substitutions the Credlt Unian issues to you; "Account" means your VISA credit card line of credit account with the Credit Union, and "Credit Union" means the Credit Union whose name appears on this Agreement or anyone to whom the Credlt Union lnsrtaters this Agreement. 1. Using Your Accourrt. If you are approved for an Account, the Credtt Union will establish a line of credit for you and notify you of your credit limit. You agree that your credk limit is the maximum amount {purchases, cash advances, finance charges, plus "other charges") that you will have outstanding on your Account at any time. If you are over your credit limit, you must pay the amount you are over before payments will begin to restore your credit limit. You may request an increase in your credtt Iimtt only by a method acceptable to the Credit Union. The Credit Union has the right to reduce your credit limit, refuse to make an advance and/or terminate your Account at any time for any reason not prohibited by law. 2• !lOingYour Card. You may use your Card to make purchases from merchenis and others who accept VISA Cards. However, you may not use your Card to initiate any type of gambling trensactlon. H you wish to pay for goods or services over the Internet, you may be required to provide card nrmtber security infonnaflon before you will be permitted to complete the transaction. In addition, you may obtain cash advances Tram the Credo Union end from other financial institutions that accept VISA Cards, and from some automated teller machines (ATMs). (Not all ATMs accept VISA Cards.) To obtain cash advances from an ATM, you must use the Personal Identification Number (PIN) that is issued to you for use with your Card. You agree that you will not use your Card for any transaction that is illegal under applicable federal, state or local law. 3. Bespgnslbilltv.You agree to pay all charges (purchases and cash advances) to your Account that are made by you or anyone whom you authorize to use your Account. You also agree to pay ail flnance charges and other charges added to your Account under the terms of this Agreement or another agreemern you made with the Credit Union. If this is a joint Account, Section 17 below also applies to your Account. 4. Finance Chases, New purchases posted to your account during a billing cycle will not incur a finance charge for that billing cycle if you had a zero or credit balance at the beginning of that billing cycle or you paid the entire New Balance on the previous cycle's billing statement by the Payment Due Date of that statement; otherwise a flnance charge will accrue from the date a purchase is posted to your account. To avoid an additional finance charge on the balance of purchases, you must pay the entire New Balance on the billing statement by the Payment Due Dale of that statement. A finance charge begins to accrue on cash advances from the date you qet the cash advance or from the first day of the' billing cycle In which the cash advance is posted to your account, whichever is later. The finance charge is calculated separately for purohases and cash advances. For. purchases, the finance charge Is computed by applying the monthly periodic mte to the average dNly balance of purohases. To get the average daily balance of purchases, tore take the beginning outstanding balance of purchases each day, add any new purchases, and subtract any payments and/or credits. This gives us the dally balance of purchases. Then, we add all the dally balances of purchases for the biding cycle together and divide the total by the number of days In the billing cycle. This gives us the average daily balance of purchases. For cash advances, the flnance charge is computed try applying the monthly perfodk rate to the average dally balance of Cash advances. To get the average daily balance of cash advances, we take the beginning outstanding balance o1 cash advances each day, add in any new cash advances, and subtrad any payments and/or credits tf-at we apply to the cash advance balance. This gives us the daily balance of cash advances. Than, we add sit the dally balances of cash advances for the billing cycle together and divide the total by the number of days In the billing cycle. This gives us the average daly balance of cash advances. For our VISA Classic Card, the monthly periodic rate for purchases, cash advances and balance transfers is 1.0750%, which Is an ANNUAL PERCENTAGE RATE of 12.90%. For our VISA Platinum Card, the monthly periodic rate for purchases, cash advances and balance transfers fs 0.8250%, which is an ANNUAL PERCENTAGE RATE of 9.lt0%. 5. Other Chases. The following other charges (fees) will be added to your Accoum, as applicable: ' a. Late Payment Fee: If you are ten (10) or more days late in making a payment, a late charge of $20.00 will be added to your account. b. Return Check Fse: If a check or 'share draft used to make a payment on your account Is returned unpaid,.you will be charged a fee of $25.00 for eadt item returned. c. Card Replacement Fes: We reserve the right !o charge x5.00 for each addRional replacement card If more than three (3) cards are requested wtthin one year. Addiional fees may be incurred if other than standard delivery is requested. d. Document Copy Fas: We reserve the right to charge 55.00 for requested sales draft copies 'rf not assoc:fated with a b(Iling error or fraudulent charges. e. Coflsctlon COSts: You agree to pay all costs of collecting the amount you owe under this Agreement, Including court costa and reasonable attorney's lees. F. Csrd Capturo Fss: We reserve the right to charge $65.00 for requesting a return of sit card(s) In your possessiond you or your authorized user has willfully misused the card(s) after such time a8 the card was reported IosUstolen. g. Etttergenry Llmft: You may be charged 55.00 for each emergency limit increase requested it more than three (3) are requested per year. 8. msnts. Each month you must pay at least the minimum payment shown on your statement by the date specttied on the statement or no later than twernyfnre (25) days tram ttte statement dosing date, whEhever is later. If your statement says the payment is "Now Due; your payment is due no later than twenty-five (25) days from the statement closing date. You may pay moro frequently, pay more than the minimum payment or pay the Total New Balance in fup. If you make extra or larger payments, you are still required to make et least the minimum payment each month your Account has a balance (other lftnn a credit balance). The minimum payment b 3% of your Total New Balance, or 510.00, whidtever is greater, pjuS the amount of any prbr minimum payments that you have not made, and any amount you are over your credit limit The Credit Union also has the right to demand immediate payment of any amount by which you are over your tredlt limit. 7. Ppymant Alloeatlon. Subject to applicable law, your payments may be applied to what you owe the Credit Union in any manner the Credit Unian chooses. We may accept checks marked `payment in full' or with words of similar effect without Losing any of our rights to collect the full balance of your account with us. 8. ;~u~r y interest If you glue the Credit Union a spedflc pledge of shares by signing a separate pledge of shares, your pledged shares will secure your Acoautt.You may not withdraw amounts that have been spedflcelly pledged id securo your Account until the Credit Union agrees to release all or part of the pledged amount In addition, your Account is secured by all outer shares you have in any individual or Joint account with the Credtt Union, except for shares in an Individual Retirement Account or in any other account that would lose special tax treatment under state or lederel law N given es security. These other shares may not be withdrawn unless you are in default under this agreement. You authorize the Credit Union to appy the balance in your individual or joint share accounts to pay arty amounts due on your Acxount H you should default. Collateral securing other loans you have with the CredR Union may' also secure this loan, except that a dwelling will never be considered as security for this Account, notwtthstanding anything to the contrary in any other agreement. e. Default You will be In default If you fail to make arty minimum payment or other required payment by the date that It is due. You win be in default If you break any promise you make under this Agreement You will tie in default if you die, file for bankruptcy or become insolvent, that is, unable to pay your obligations when tney become due.You will be in default i you make any false or misleading statements in any credit application or crodlt update. You will also be in default 'rf something happens that the Credit Union believes may substantially reduce your ability to repay what you owe. When you are in default, the Credit Union has the right to demand immediate payment of your full Account balance wtthout giving you notice. If Immediate payment is demanded, you agree to continue paying finance charges, at the periodic rate charged before defauR, urnll what you owe has been paid, and any sharos that were given as security for your Account may be applied towards what you owe. ®CUNA Mutual Group, 1991, 2005 (2rl310cvcpCustom) 09/18/05 25349 CONTINUED ON REVERSE SIDE JUL-19-2007 lb:'L4 ~u~t,t. vAL. r~u ~. 4iaoi~!tY_ror unau**+onzeQ_t~ge-~osVSl S:ard Notmcatlon. You agree Io notify us immediately, orally or in writing at 3850 Hanzdale Drive, Camp Hill, PA 1 701 1-7809 or telephone (717) 737-4152 Monday through f-ridey 9:00 A lvl. to 5:30 P.M., (800) 433-0505 Monday through Friday 8:00 A.M. to 6:Ob P.M. or (800) 991-4981 twenty-four (24) hours a day, seven (7) days a week, of the loss, theft, or unauthorized use of your Credit Card. You may be liable for the unauthorized use of your Credit Card. You wilt not be liable for unauthorized use that occurs after you notify us d the loss, then, or possible unauthorized use. You will have no liability for unauthorized purchases made with your credit card, unless you are grassy negligent in the handling of your card. In any case, your liability will not exceed 550. t 1. hanr~tg or Termtnatipq Your Account. The Credtt Union may change the terms of this Agreement from time to time. Notice of any change wilt be given in accordance with applicable law. If permhted by law and speclHed in the notice to you, the change will apply to your existing Account balance as well as to future transactions. Either you or the Credit Unbn may terminate this Agreement at any time, but termination by you or the Credit Union will not affect your obligation ro pay the Account balance plus any finance and other charges you owe under th~ Agreement. You are also responsible for ail transactions made to your Account after termination, unless the transactions were unauthorized. The Card or Cards you receive remain the property of the Credk Union and you must recover and surrender to the Credit Unbn all Cards upon request or upon termination of this Agreement whether by you or the' Credit Union. The Credit Union has iha right to require you to pay your fun Account balance at any time after your Account is terminated, whether it is terminated by you or the Credit Unbn. If this is a joint Account, Section 17 of this Agreement also applies to termination of the Account. 12. r'redit Review and Release of informatlon. You authorize the Credit Union to investigate your credit standing when opening or reviewing your Accaxtt You authorize the Credit Unbn to disclose irtformafion regarding your Account to credit bureaus and creditors who inquire about your credit standing. If your account is eligible for emergency cash and/or emergency card replacement services, and you request such services, you agree that we may provide personal information about you and your account that is necessary to provide you with the requested service(s). t3. Returns and Adjustments. Merchants and others who honor your Card may give credit for returns or adjustments, and they will do so by sending the Credit Union a credit snp which win be posted to your Aoeount. ff your credits and payments exceed what you owe the Credtt Union, the amount will be applied against future purchases and cash advances. If the credit balance amount is S1 or mare, M will be refunded upon your written request or automatically after six (8) months. 14. gddltional 8snefitslCard F..pbancements.Tha Credit Union may from time to time offer addkional services to your Account, such as travel accident insurance, at no additional cost to you. You underetartd that the Credit Union is not obligated to offer such services and may withdraw or change them at any time. 15. Foreign Transactions. Purchases and cash advances made in foreign currencies wilt be debited from your account 1n U.S. donors. The exchange rate between the transaction currency and the baling currency used for processing international transactions is a rate selected by Visa from a range of rates available in whobsale Currency markets for ttte applicable central processing date, which rate may vary from the rate Visa itself receives or the government-mandated rate in effect for the applicable central processing date. The exchange rate used on the processing date may dfffer from the rate that would have been used on the purchase date. or cardholder statement posting date. 16. Merchant Disputes. The Crtadk Union is not responsible for the refusal of any merchant or financial institution to honor your Card. The Credit Union is subject to Gaims and defenses (other than tort claims) arising out of goods or services you purchase with the Card i}you Move made a good faith attempt but have been unable to obtain satisfaction from the merchant or service provider, and (a) your purchase was made in response to an advertisement the Credit Union sent or participated In sending to you; or (b) your purchase cost more than i650 and was made in your state or within one hundred (100) miles of your home. 17. Joint Accounts. if this is a Joint Account, each person on the Account must sign the Agreement (by signing on the application). F_adt of you will be individually and Jointly responsible for paying all amounts owed under this Agreement. This means that the Credh Union can require any one of you individually to repay the entire amount owed under this Agreement. Each of you authorizes the other(s) to make purchases tx trash advances individually. Any one of you may terminate the Account and the termination will be effective as to all of you. 18. Elf .This Agreement is the contract which applies t0 an iransadions on your Account even though the sales, cash advances, credit or other slips you sign or receive may contain ddferent terms. 19. No Waiver. The Credit Union can delay enforcing any of its rights arty number of times without losing them. 20. Statements end Notlces. Statemems and notices witl be malted W you at the most recent address you have given the Credff Union. Native sent to any one of you will be considered notice to att. zt. Final Exoressic ais Agreement is the final expression of the terms and conditions of this ,A line of credit between you and the Cre'iit Union. This written Agreement may not l>e contradicted by evidence of ar~y alleged oral agreement. 22. Cotes Recelyg~. You acknowledge that you have received a copy of this Agreement. 23. $lgnatures. By signing in the Signature area of the application form that was attached to this Agreement when you receitred it, you agree ai the terms of this Agreement. You should detach this Agreement from the application and retain it for your records. YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE USE This notice contains important information about your rights and our responsibnttiea under the Fair Crodit B81ing Ad. Notify Us In Case of Errors or Ouestlons About Your Bill K you think your bill is wrong, or ff you need more information about a transaction on your b7, wrNe us on a separete sheet at the address fisted on your bill. Write to us as soon as possible. We must hear hom you tto later than sixty (60) days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so wiB not preserve your rlgMS. In your letter, give us the following information: • Your name and account number. • The dollar amount of the suspected error • Describe the error and explain, ff you can, why you believe there Is an error.lt you need more informatbn, describe the item you are not sure about. If you have authorized us to pay your credit card bill automatically from your savings or share draft account, you can stop the payment on any amount you think is wrong. To stop the prrymer-t your letter must reach us three (3) txrsiness days before the automatic payment is scheduled to oxur. Your Rights and Our Responsibilities Attsr We Rtrceive Your WrNten Notlee We must actnowledge your letter within thirty (30) days, unless we have corrected the error uy then. Within ninety (90) days, we must either correct the error or explain why we believe the bill was corcect. After we receive your letter, we cannot try to collect arty amount you question, or report you as delinquent. We can continue to bill you for the amount you question, inducting finance charges, and we can apply an unpaid amount against your credo limit You do not have to pay any questioned amount while wa are Investlgating, but you are still obligated to pay the parts of your bill that are not In question. I(we find that we made a mistake on your bill, you will not have to pay any finance charges related to arty questioned amount. If >wre didn't make a mistake, you may have fo pay finance charges, and you will hatre to make up any missed payments on the questioned amount. to either case, we win send you a statement of the amount you owe aril the dais that it to due. If you tail b pay the amotutt that we think you owe, we may report you as delinquent. However, ff our explanation does not satisfy you and you write to us within ten (10) days falling us that you still refuse to Pay, we moat ten anyone we report you b that you have a question about your bill. And, we must tell you the name of anyone we reported you to. We must ten anyone we report irou to that the matter has been settled between us when it finally is. It we don't follow these rules, we cant cotltact the first 550 of the questioned amount, even if your bill was t:orrect. Special Rula for Credit Card Purchases if you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem wfth the merchant, you may have the right not to pay file remaining amount due on the property or services. There are two (2) limitations on this right: (a) You must have made the purchase in your home state or, ff not within your home state, within one hundred (100) miles of your current mailing address; and (b) The purchase price moat have been more than 550, These limitations do not apply ff we own or operate the merchant, or ff we mailed you the advertitaemertt Tor the property or services. TOTAL P.03 -O O ~ J ? ~_ ~ ~ O 0 V ~~r` ~ i b0 ~ r: __ ~;:~ W D -G ~:' ~ c~' O -,-. ~~ ~ ca ~ 0 SHERIFF'S RETURN - REGULAR CASE NO: 2007-04483 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FCU VS DEITCH ZACHARY KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DEITCH ZACHARY the DEFENDANT at 1710:00 HOURS, on the 1st day of August 2007 at 329 SOUTH FRONT STREET APARTMENT 1 WORMLEYSBURG, PA 17043 ZACHARY DEITCH by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 15.36 Postage .41 Surcharge 10.00 .00 s~~~)0.,! ~~ 43.77 Sworn and Subscibed to before me this day of , So Answers: • ~--'~ R. Thomas Kline ` 08/02/2007 STEVEN HOWELL By: A.D. y.. ., SUSQUEHANNA VALLEY FEDERAL CREDIT UNION PLAINTIFF V. ZACHARY DEITCH DEFENDANT TO: ZACHARY DEITCH 329 SOUTH FRONT STREET APARTMENT 1 WORMLEYSBURG, PA 17043 DATE OF NOTICE: SEPTEMBER 4, 2007 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION -LAW N0.07-4483 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONA AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AVISO IMPORTANTE A: ZACHARY DEITCH 329 SOUTH FRONT STREET APARTMENT 1 WORMLEYSBURG, PA 17043 FECHA DEL AVISO: SEPTEMBER 4, 2007 LISTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESETADO CONTRA LISTED. A MEMOS QUE LISTED ACTUE DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS IMPORTANTES. LISTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE. INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 .' w Respectfully submitted, By: Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Date: SEPTEMBER 4, 2007 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: ZACHARY DEITCH 329 SOUTH FRONT STREET APARTMENT 1 WORMLEYSBURG, PA 17043 By: S en Date: ~ `l ? ~ ~".~ ~.~ ~ -•- ~` .~ s •• ~' SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, PLAINTIFF VS. ZACHARY DEITCH, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4483 CIVIL TERM PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a DEFAULT JUDGMENT against ZACHARY DEITCH for his failure to file an Answer to the Complaint served AUGUST 1, 2007 by the Sheriff of Cumberland County as shown on Exhibit "A-1". A Notice of Intention to Take a Default Judgment was filed on SEPTEMBER 19, 2007 and served using a U.S. Postal Certificate of Mailing by first class mail prepaid postage on SEPTEMBER 4, 2007 as shown on Exhibit "A-2" (Certificate of Service and LISPS Form 3817 are attached showing service). No answer or response having been filed with the Prothonotary as of September 27, 2007 please enter a Default Judgment in the following amount as of September 27, 2007: Count I $ 9,471.34 Interest Count I $ 213.89 (11.74% per annum from July 16, 2007 at $2.93 per diem) Count II $ 6,761.14 Interest Count II $ 131.40 (11.90% per annum from July 16, 2007 at $1.80 per diem) Fees $ 300.00 (Legal Fees Expressly Recoverable Under Contract) $16,877.77 plus all costs Respectfully submitted, By: St,~Cen Howell, F~u~"re owell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Plaintiff Date: September 27, 2007 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: Zachary Deitch Apartment 1 329 South Front Street Wormleysburg, PA 17043 By: H ell Law Firm 19 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Plaintiff Date: September 27, 2007 . CASE NO: 2007-04483 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FCU VS DEITCH ZACHARY KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DEITCH ZACHARY the DEFENDANT at 1710:00 HOURS, on the 1st day of August 2007 at 329 SOUTH FRONT STREET APARTMENT 1 WORMLEYSBURG, PA 17043 by handing to ZACHARY DEITCH a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge Sworn and Subscibed to before me this of So Answersc 18.00 15 .3 6 ~ ~~~ .41 10.00 R. Thomas Kline .00 43.77 08/02/2007 STEVEN HOWELL By: day A.D. e EXHIBIT d ~ A-, m COPY SUSQUEHANNA VALLEY FEDERAL CREDIT UNION PLAINTIFF V. ZACHARY DEITCH DEFENDANT T0: ZACHARY DEITCH 329 SOUTH FRONT STREET APARTMENT 1 W©RMi,EYSBURG, PA-17043 DATE OF NOTICE: SEPTEMBER 4, 2007 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4483 CIVIL TERM IMPORTANT NOTICE :~ ~ ~ o cs (z r ~ ~7 - ~.., r- , rT'1 "' ~,: p /~'7~ r=- -~' r _. ~7 ~' ~f ~1't ..,~ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONA AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 s EXHIBIT ~-a AVISO IMPORTANTE A: ZACHARY DEITCH 329 SOUTH FRONT STREET APARTMENT 1 WORMLEYSBURG, PA 17043 FEGIiA DEL AVISO: SEPTEMBER 4, 2007 USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESETADO CONTRA USTED. A MEMOS QUE USTED ACTUE DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS IMPORTANTES. USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO INMEDIATAIVIENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE. INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE AGENCIAS -QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Respectfully submitted, By: ~owell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Date: SEPTEMBER 4, 2007 ~ - Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: ZACHARY DEITCH 329 SOUTH FRONT STREET APARTMENT 1 WORIWILEYSBURG, PA 17043 B Date: ~ `~ ~ U.S. POSTAL SERVICE CERTIFICATE OF MAl~ln~ ~ ... ---- ~M~q ., ROVIDE FOB. rno„~,~,~_..,~,,.,_. Steven Howell ~v , Received Froi Attorney At Law 4, SEP "~ ,~ 619 Bride street z 4 ,i- New Cumberland, PA 17070 ~~~ ~T ~ 9°~ m -._.. '070 '_ c 0 ,:,~ a-mo c ~ One piece of ordinary mail addressed to: v~..~ 3 ~,~~, ~` o. Oo`J00~ "7 w ~~ . • w ~O Z~ K~Jr00rO eP ~~ ~o~ 1 ~~ ~ 9 .~Ca ~~ 7G 7~ ~ m i i PS Form 3817, January 2001 r`s C` ~'~~, ~ $ ~' ~ O0 ~ ~ ~ `~. 00 a ~`.. ~- t a ,`~ ~_~:~ -art Ut =~ -,-, 6_ M ; it ~^ ~~ ~ ~.t ~ ;.., ~• -4= SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, PLAINTIFF VS. ZACHARY DEITCH, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4483 CIVIL TERM RULE 236 NOTICE OF FILING JUDGMENT (X) Notice is hereby given that a money judgment in the above captioned action has been entered against you in the amount of $16,877.77 plus all costs on September ~, 2007. (X) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. ~honotary Civil Divi ion BY: ~Qp~ If you have any questions regarding this Notice, please contact the filing party: Steven Howell, Esquire Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 This Notice is given in accordance with Pa. R.C.P 236. Notice should be sent to: Zachary Deitch Apartment 1 329 South Front Street Wormleysburg, PA 17043