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HomeMy WebLinkAbout07-6913MEMBERS 1 ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. NO.. &943 eEUL_7_ER_J1V1 MAUREEN M. CUFF DEFENDANT : CIVIL ACTION -LAW NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTUNG TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims 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 attorney and filing in writing 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 claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 MEMBERS 1 ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF . Vs. : NO.: MAUREEN M. CUFF DEFENDANT : CIVIL ACTION - LAW NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) digs de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus de€ensas o sus objectiones a las demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS DERECHOS RvIPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS 1" FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA PLAINTIFF Vs. NO.: 07- G 5 13 ' ?L MAUREEN M. CUFF DEFENDANT. CIVIL ACTION-LAW COMPLAINT AND NOW, comes Members I" Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney, Karl M. Ledebohm and makes the following complaint: 1. Plaintiff, Members I 't Federal Credit Union ("Members is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 1 2. Maureen M. Cuff ("Defendant") is an adult individual having a last known address of 1201 Gunstock Lane, Mechanicsburg, PA 17050-2098. 3. On or about April 22, 1994, Defendant submitted to Members 1St a credit card application (the "Application") for a Visa credit card issued by Plaintiff. 4. Plaintiff accepted the Application and sent to Defendant a Visa Credit Card, account 44287-5900-0083-0147 (the "Visa Account") and a Visa Credit Card Agreement and Disclosure Statement. 5. The Visa Account is governed by the Visa Credit Card Agreement and Disclosure Statement (the "Credit Card Agreement and Disclosure"), a copy of which is attached hereto as Exhibit "A" and made part hereof. 6. Pursuant to the terms and conditions of the Credit Card Agreement and Disclosure, Defendant agreed to pay to Plaintiff monthly installments in an amount of not less than two percent (2.0%) of the outstanding balance on the account or $20.00, whichever is greater. 7. Defendant has made charges against the Visa Account and is in default of Defendant's obligations under the Credit Card Agreement and Disclosure and the corresponding Visa Account as a result of Defendant's failure to make the payments due to Plaintiff as set forth in the Credit Card Agreement and Disclosure, the last payment having been received by Members 1St on or about June 16, 2006. 8. By letter dated October 2, 2007, addressed to Defendant, Plaintiff demanded the payment of all amounts due under the Credit Card Agreement and 2 Disclosure and the corresponding Visa Account. A copy of Plaintiffs 9 10. 11. Demand is attached hereto as Exhibit "B" and made part hereof. As of the date hereof, Defendant is indebted to Plaintiff in the amount of TWENTY-EIGHT THOUSAND NINETY-SEVEN AND 31/100 ($29,097.31) itemized as follows: a. Principal $24,447.80 b. Unpaid finance charge 1,609.51 c. Unpaid other fees 240.00 d. Legal Fees* 1,800.00 e. Total due to Member 1St as of November 13, 2007 $28,097.31 *Legal fees are estimated in accordance with the terms and conditions set forth in the Credit Card Agreement and Disclosure. Defendant will be responsible for payment of actual, reasonable legal fees incurred by Members 1 st in this matter. Defendant also agreed under the terms and conditions of the Credit Card Agreement and Disclosure that in the event of default there under Defendant would pay, in addition to the amounts set forth in paragraph 9 above, additional reasonable legal fees, if any, and costs incurred by Plaintiff as a result of the institution and prosecution of these legal proceedings. Legal fees and costs continue to accrue on the above obligation as set forth in the Credit Card Agreement and Disclosure through the date of payment and including on and after entry of judgment on this complaint. 3 12. As set forth above, Plaintiff has made demand upon Defendant to make payment of all amounts due to Plaintiff under the Visa Account and corresponding Credit Card Agreement and Disclosure and, as of the date hereof, Defendant has failed and refused to make payment of all such amounts due to Plaintiff. WHEREFORE, Plaintiff, Members 1s Federal Credit Union demands judgment against Defendant, Maureen M. Cuff, in the amount of TWENTY-EIGHT THOUSAND NINETY-SEVEN AND 31/100 ($28,097.31) together with additional attorney's fees and costs of suit and interest at the legal rate on and after the entry of judgment on this complaint which does not exceed the jurisdictional amount requiring arbitration referral by local rule. Date: o?- Respectfully submitted, Supreme Court ID # : 59012 P.O. Box 173 (717)938-6929 Attorney for Plaintiff 4 New Cumberland, PA 17070-0173 VISA Credit Card Agreement and Disclosure Notice See reverse side lot important Inlormalion regarding your rights 10 dispute billing errors 1. Meaning of Words. The lollowing words have the following meanings in this Agreement and in the monthly billing statement sent hereunder. (a) "Agreement" means the Visa Credit Card Agreement and Disclosure furnished by us. (b) "We", "us" and "our- means Members 1st Federal Credit Union, Mechanicsburg, PA (c) "you" and "your" means each person who signs the application for the Account (d) "Card" means any Visa Credit Card and any duplicates and renewals we issue to you or to an authorized user of your Account (e) "Account" means your Visa Credit Card Account with us. (p "Line of Credit" means the sell-replenishing line of credit we make available to your Account (g) "Advance" means any credit extended on your Account for any purchases or Cash Advances. (h) -Cash Advance" means (i) any cash or credit extended on your Account by us or by any other institution that accepts a Card. (ii) any withdrawal of cash made by using a Card and personal idenlilication number ("PIN") at an automaled letter machine ("ATM") or other type of electronic terminal that provides access to the Visa system, (iii) the amount of any Visa Convenience Check paid by us, or (iv) the amount of any balances transferred to your Account from another credit card or account (i) "Visa Convenience Check" means any check that directly accesses your Account The amount of any Visa Convenience Check paid by us is posted as a Cash Advance under your Account 2. How To Use This Account. Your Account may be used to purchase or lease goods and services ("purchases") from a merchant by presenting a Card and signing a sales Iransaciton receipt for the amount or the purchase or by giving a Card Account number Your Account may also be used to obtain Cash Advances: (a) By receiving cash or credit Irom financial institutions that accept a VISA Credit Card; (b) By use of Visa Convenience Checks; (c) By making rash withdrawals with a Card at an ATM or other type of electronic terminal that provides access to the Visa system, or (d) By transferring to your Account a balance from another credit card or account. 3. Responsibility. You agree to pay all Advances, finance charges and other lees or charges charged to your Account arising from the use of a Card, a Visa Convenience Check or the Account by you or anyone you authorize or permit to use your Account, a Visa Convenience Check or a Card, even if you do not notify us that others are using your Account, a Visa Convenience Check or a Card Your responsibility lot charges made by anyone you authorize or permit to use your Account, a Visa Convenience Check or a Card continues until you notify us in writing al 5000 Louise Drive, P 0 Box 40, Mechanicsburg, PA 17055, and recover and destroy any Visa Convenience Check or Card in such person's possession Your obligation to pay the Account balance continues regardless of the terms of any agreement, divorce decree, or other court judgment to which we are not a party II more than one person signs the application for the Accounl, you are each jointly and severally responsible lot all charges on the Account 4. Liability for Unauthorized Use. You understand that your total liability to us shall not exceed Fifty Dollars ($50) resulting from the loss, theft or other unauthorized use of a Card that occurs prior lo the time you give notice to us. Such limitation does not apply when a Visa Convenience Check is used 5. Lost Card Notification. II you believe a Card or any Visa Convenience Check has been lost or stolen, you must immediately call us at (717) 795-6032 or 1(800)-283-2328 during normal business hours After business hours (nights and weekends) or on hol- idays, lost or stolen Cards or VISA Convenience Checks must be reported by calling 1(800)-325-3678. 6. Credit Line. II we approve your application, we will establish a Line of Credit lot you and notify you of its amount when we issue a Card. This amount is your credit limit for the Account You agree not to let the Account balance exceed this approved credit limit Each payment you make on the Account will restore your credit limit by the amount of the payment that is applied to the principal balance owed on the Account. You may request an increase in your credit limit, which must be approved by us We may reduce your credit limit or terminate this Agreement for any reasons not prohibited by applicable lavZ with only such notice as is required by applicable law. You may also terminate this Agreement at any time, but lermination by either of us does not affect your obligalion to pay the Account balance. To terminate this Agreement, you must notify us in writing at 5000 Louise Drive, P 0 Box 40. Mechanicsburg, PA 17055, and recover and surrender to us all Cards, and any issued but unused Visa Convenience Checks. They remain our property. 7, Credit Information. You authorize us to investigate your credit standing when opening, renewing or reviewing your Account, and you authorize us to disclose information regarding your Account to credit bureaus and other creditors who inquire of us about your credit standing 8. Payments. We will mail you a billing statement every month showing your Previous Balance comprised of purchases and Cash Advances, the current transactions on your Account, your credit limit, the available credo, the New Balance, the Finance Charges Ior the billing cycle, and the Minimum Payment required. Each month you must pay al least the Minimum Payment shown on your statement by the Payment Due Date shown on the statement or no later than 25 days Irom the statement Closing Dale, whichever is later II your statement says your payment is -Now Due," your payment is due no later than 25 days from the statement Closing Date. You may pay more Irequenlly, pay more than the Minimum Payment or pay the New Balance in full If you make extra or larger payments, you are still required to make at least the Minimum Payment each month your Account has a balance (other than a credit balance), The Minimum Payment will be either a) Two percent (2%) of your New Balance or $20, whichever is greater, plus any portion of the Minimum Payment shown on prior statement(s) which remains unpaid, or b) your New Balance, it it is less than Twenty Dollars ($20) We also have the right to demand immediate payment of any amount by which your New Balance is over your credit limit. We will apply your payments first to any lees, [hen to Finance Charges on both Cash Advances and purchases, then to previously billed Cash Advances, then to previously billed purchases, then to new Cash Advances and then to new purchases We may accept checks marked "payment in full" or with words of similar edecl without losing any of our rights to collect the lull balance of your Account 9. Finance Charge. A. The current monthly Periodic Rate and corresponding Annual Percentage Rate are set forth on the "Additional Disclosure" which is sent to you together with this Agreement B. Variable Rate: The Annual Percentage Rate will be determined by adding the margin to the index value. The Annual Percentage Rate can change on the first calendar day of the lirst billing cycle in each calendar quarter The margin [or Visa Platinum is 5.00% for both purchases and Cash Advances. The margin lot Visa Gold is 5.00% lot both purchases and Cash Advances. The margin lot Visa Classic is 5.50% for both purchases and Cash Advances. The margin for Visa Classic Rate Shaver is 2.00% lot both purchases and Cash Advances, subject to a minimum Annual Percentage Rate of 9.9% for the Visa Classic Rate Shaver program. The index is the highest Prime Rate published in the money rates section of the Wall Street Journal The index will be measured as of the last business day of the immediately preceding calendar quarter. Any increase.in the Annual Percentage Rate may cause the amount of the minimum monthly payment to increase Also, you may have to pay more payments. The Annual Percentage Rate will never exceed 21% or the maximum allowed bylaw, whichever is less. The monthly Periodic Rate is equal to one-Twelfth (1/12) of the Annual Percentage Rate C. Method A - Average Daily Balance (Including New Cash Advances): A Finance Charge will be imposed on Cash Advances from the dale made or from the first day of the billing cycle in which the Cash Advance is posted :o your Account, whichever is later, and will continue to accrue until the dale of payment The Finance Charge on Cash Advances for a billing cycle is computed by applying the monthly Periodic Rate to the average daily balance of Cash Advances, which is determined by dividing the sum of the daily balances during the billing cycle by the number of days in [he cycle. Each daily balance is determined by taking the beginning balance of Cash Advances on your Account each day, adding any new Cash Advances, and subtracting any payments or credits that are applied to Cash Advances but excluding any unpaid Finance Charges 0. Method G - Average Daily Balance (Including New Credit Purchases): A Finance Charge will be imposed on purchases only it you elect not to pay the entire New Balance shown on your monthly billing statement lot the previous billing cycle on or before the Payment Due Date of that statement If you elect not to pay the entire New Balance shown on your previous monthly billing statement by the Payment Due Date, a Finance Charge will be imposed on the unpaid average daily balance of purchases from the previous statement Closing Date and on new purchases from the date of posting to your Account during the current billing cycle, and will continue to accrue until the Closing Date of the billing cycle preceding the dale on which the entire New Balance is paid in full or until the date of payment if later than the Payment Due Date. The Finance Charge on purchases for a billing cycle is computed by applying the monthly Periodic Rate to the average daily balance of purchases, which is determined by dividing the sum of the daily balances during the billing cycle by the number of days in the cycle. Each daily balance is determined by taking the beginning balance of purchases on your Account each day adding any new purchases, and subtracting any payments or credits that are applied to purchases, but excluding any unpaid Finance Charges 10. Default. You will be in default if you tail to make any minimum payment or other required payment by the date that if is due You will be in delaull it you break any promise you make under this Agreement You will be in default it you die, file for bankruptcy, or become insolvent, that is, unable to pay your obligations when they become due You will be in default it you make any false or misleading statements in any credit application or update of credit information. You will also be in default if something happens which we believe may substantially reduce your ability to repay what you owe When you are in default we can demand immediate payment of the entire amount you awe under this Agreement without giving you advance notice If immediate payment is demanded, you will continue to pay interest at the applicable interest rates in effect under this Agreement, until what you owe has been repaid. It demand for immediate payment has been made, the shares and deposits given as security for payment under this Agreement can be applied towards what you owe We can also take appropriate action as authorized under the Uniform Commercial Code to repossess any and all collateral pledged to secure repayment under this Agreement To the extent permitted by applicable law, you will also be required to pay our collection expenses, including court costs and reasonable attorneys' lees. We can also exercise any other rights given 10 us by law when you are in default 11. Using the Card. You may use a Card, Card Account number and/or PIN to make transactions on your Account. You will retain the copies of the transaction receipts furnished to you in order to verily your monthly billing statemeni. You agree that you will nor use or permit anyone to use a Card or your Account for any transaction that is illegal under applicable federal, slate or local law. You agree that illegal use of any financial service will be deemed an action of default and/or breach of contract and such a service and/or other related services may be terminated at our discretion. You runner agree, should illegal use occur, to waive any right to sue us for such illegal use or any activity directly or indirectly related to il. Additionally, you agree to indemnify and hold us harm- less from any suits or other legal action or liability, directly or indirectly, resulling from such illegal use We reserve the right to decline any transactions that we consider fraudulent, suspicious, or illegal and you further understand that we will not knowingly autho- rize charges related to online gambling B.Fiii(1.1dte By06 :' -36-00 CONTINUED ON REVERSE EXHIBIT "A" 12. Returns and Adjustments. Merchants and others who honor a Card may give credit or returns or adjustments, and they will do so by sending us a credit transaction receipt , which we will post to your Account. II your credits and payments exceed what you owe us, wewill hold and apply this credit balance toward future purchases and Cash Advances, or it it is one dollar or more, refund it on your written request or automatically after six months. 13. Using Visa Convenience Checks. You may use your Visa Convenience Checks, if available, as you would use a Card to make a purchase or payment or to receive rash. Your Visa Convenience Checks directly access your Account. All Visa Convenience Checks paid by us are treated as Cash Advances hereunder and, except as otherwise indicated, are subject to all terms of this Agreement pertaining to Cash Advances and to the following additional terms: A. No Visa Convenience Check may be used to make a payment on your Account. 8. Only the person whose name appears on a Visa Convenience Check may use them. C Visa Convenience Checks must be written in U.S. Dollars. Visa Convenience Checks may not be certified. D We may return a Visa Convenience Check unpaid it there is not enough available credit on your Account to pay it, it your Account is in default, or if a Card or any Visa Convenience Checks have been reported lost or stolen. A $10 fee will be charged for each returned Visa Convenience Check. 14. Foreign Transactions. Purchases and Cash Advances made in foreign countries and foreign currencies will be billed in U.S. Dollars. Effective April 2, 2005, the exchange rate for transactions in a foreign currency will be a rate selected by Visa from the range of rates available in wholesale currency markets for the 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, increased by one-percent. On foreign transactions you agree to pay all currency exchange charges. 15. Merchant Disputes. We are not responsible for the refusal of any merchant or financial institution to honor a Card or Visa Convenience Check. 16. Security Interest. To secure your Account, you grant us a purchase money security interest under the Uniform Commercial Code in any goods you purchase using the Account. If you default, we will have the right to recover any of these goods which have not been paid for through our application of your payments in the manner described in paragraph B. Pledge of Share Accouarys) - NOTE: To secure your Account, you pledge to us and grant a security Interest In all joint and individual accounts you have with Members 1st Federal Credit Union now and In the future, except shares in Individual Retirement Accounts and accounts where the pledge or transfer of which would cause the loss of a tax-exempt or tax-deterred status. You authorize us to apply the balance in these account(s) to pay any amounts due under this Agreement if you should default. 17. Fees and Other Charges. The following lees and other charges will be added to your Account, as applicable: A. Annual Fee Visa Platinum .. ..... None Visa Gold .. ..... .... . None Visa Classic ..... ........ None Visa Classic Bale Shaver...... None B. Late Payment Charges. If you fail to pay the minimum payment on your Account within five (5) days of the Payment Due Date, a late payment charge of $30 will be added io your Account. C. Over-Limit Charge. It your Account balance exceeds your credit limit at any time during the statement period, an over-limit charge of $15 will be added to your Account. 0. Returned Check Fee. If a check or share draft used to make a payment on your Account is returned unpaid because of insufficient funds or for any other reason, you will be charged a fee of $10 for each item returned. E. Returned Statement Fee. You will be charged $1 for each monthly billing statement that is returned. F. Copies of Visa Transaction Receipts and Statements. You will be charged $3 for each copy you request of a receipt for any purchase, credit or Cash Advance or of a monthly billing statement (except in connection with the resolution of a billing error.) 18. Skip Payment Option. We may allow you, from time to time, to omit a monthly payment. We will nolity you as to any month in which the option is available. If you omit a payment, Finance Charges will accrue on your balance in accordance with this Agreement. A skip payment does not extend the period within which you most pay the New Balance in order to completely avoid Finance Charges on purchases. A minimum payment will be due in the month following the month in which you skip your payment. 19. Effective Agreement. This Agreement is a contract which applies to all transactions on your Account, even though the receipts you sign or receive for purchases, credits, Cash Advances or other transactions may contain different terms. We may amend this Agreement from time to lime by sending you written notice. If required by applicable law, we will give you written notice before the effective dale of the amendment. To the extent applicable law permits, and as we indicate in our notice to you, amendments will apply to your existing Account balance as well as to future transactions. This Agreement shall be construed in accordance with the applicable laws of the Commonwealth of Pennsylvania and applicable federal laws, YOUR BILLING RIGHTS KEEP THIS FOR YOUR RECORDS This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR MONTHLY BILLING STATEMENT. II you think your monthly billing statement is wrong, or if you need more information about a transaction on your statement, write us on a separate sheet of paper at the address listed on your statement. Write to us as soon as possible. We most hear from you no later than 60 days after we send you the first statement on which the error at problem appeared. You can telephone us, but doing so will not preserve your rights. 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, if you can, why you believe there is an error If you need more information, describe the item you are not sure about. It you have authorized us to pay your monthly billing statement automatically from your Savings or Checking Account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us three (3) business days before the auto- matic payment is scheduled to occur YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the statement was correct. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to send statements to you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit limit. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your statement that are not in question. If we find that we made a mistake on your statement. you will not have to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the ques- tioned amount. In either case, we will send you a statement of the amount you owe and the date that it is due. It you fail to pay the amount that we think you owe, we may report you as delinquent. However, it our explanation does not satisfy you and you write to us within ten days telling us that you still refuse to pay, we must (ell anyone we report you (o that you have a ques- tion about your statemenl. And, we must tell you the name of anyone we reported you to. We must tell anyone we repon you to that the matter has been settled between us when it finally is. II we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your statement was correct. SPECIAL RULE 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 with the merchant, you may have the right not to pay the remaining amount due on the property or services. There are two limitations on this right: (a) you must have made the purchase in your home state or, if not within your home stale, within 100 miles of your current mailing address, and (b) the purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the properly or services. KARL M. LEDEBOHM ATTORNEY-AT LAW P.O. BOX 173 New Cumberland, PA 17070-0173 Phone: 717-938-6929 Fax: 717-932-0317 October 2, 2007 (Via Certified and regular mail) Maureen M. Cuff 1201 Gunstock Lane Mechanicsburg, PA 17050-2098 RE: Members 1St Visa Account No.: 4287590000830147 Dear Ms. Cuff: THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE FROM THIS OFFICE IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. AN IMPORTANT STATEMENT OF RIGHTS IS INCLUDED ON THE REVERSE OF THE SECOND PAGE OF THIS LETTER. Members 1St Federal Credit Union ("Members 1St") has requested my office to collect the amounts due to Member's 1St under the above account. As you know, you are in default of your obligations under the above Members 1St Visa Account (the "Account") due to your failure to make the payments required under the Account in a timely manner. The last payment on the Account was received by Members 1 st on or about June 16, 2006. As a result of your defaults, Members 1St hereby accelerates all amounts due to Members 1St under the Account and hereby demands the payment of all amounts due to Members 1St under the Account in the amount of $26,428.31 itemized as follows: 1. Principal $24,447.80 2. Unpaid Finance Charge 1,609.51 3. Unpaid other fees 240.00 4. Legal Fees 131.00 5. Total due to Member 1St as of 10/2/07 $26,428.31 If you fail to deliver to my office at the address set forth above payment of the $26,428.31 within thirty (30) days of the date of this letter, Members 1St will have no choice but to file a legal action against you to collect all of the amounts due under the Account without further notice. In such event, in addition to the above amounts, you may EXHIBIT "B" also be responsible for the payment of additional reasonable legal fees and costs of suit incurred by Members I". Nothing herein shall constitute or be construed as an agreement on behalf of Members 1 st to accept any terms and conditions in exchange for payment of the amounts due under the Account except for the immediate payment of all amounts due to Members 1St . Nothing herein shall constitute a waiver of any rights or remedies which Members 1St may have under any written agreement or at law or in equity to collect the balance of the indebtedness due under the Account without further notice, including, without limitation, the right to accept and apply any partial payments made on the Account without waiver of any demand for payment in full of all amounts due under the Account. Nothing herein shall constitute an agreement on behalf of Members 1St to postpone or extend the maturity date of the obligation. Members 1St looks forward to the payment of the $26,428.31 on or before November 1, 2007. Very 1 M. Ledebohm CC: David Thomas, Collections Officer NOTICE This letter is an attempt to collect a debt. It you dispute the validity of this debt, or any portion thereof, and you contact the undersigned within thirty (30) days after receipt of this Notice, you will be furnished with written verification of the debt; provided, that if a lawsuit has been filed against you to collect this debt before the expiration of the thirty (30) days, the complaint filed in said lawsuit will constitute written verification of the debt. If you do not dispute the debt or any portion thereof as stated above, the undersigned will assume the debt is valid. If the original creditor of this debt is different from the creditor stated on the front page of this letter, the undersigned will provide you with the name and address of the original creditor upon written request from you within thirty (30) days of receipt of this notice. The undersigned means the name signed at the end of this letter appearing in print at the top of this letter. Us, .O co Er !? CERTIFIED M _LDomestic Mail Only; AIL , RECEIPT No In M surance Coverage Provided ti M Postage $ 11° t? iiflt'ii Certified Fee O O Return Receipt Fee (Endorsement Required) { r ? • Postmark H C3 Restricted Delivery Fee (Endorsement Required) e $11,1 CIV.C M1 O Total Postage & Fees 015. ,? 1 jtt,:`ii?f '1lII% r%- Sent To?/? - .- - t O Street, Apt. Kb ------ ----- 7 .; - - L ----• ? _... or PO Box No. ' City fate ZlP 4 , - • -- tai r- ?'/?- 1 ???, , ?.,a ?, MEMBERS 1 sT FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY PENNSYLVANIA PLAUM Vs. NO.: MAUREEN M. CUFF DEFENDANT- CPAL ACTION-LAW VERMCATION 1, David Thomas, Collections Officer for Members I" Federal Credit Union, being authori=d to do so on bebalf of Members 1S` Federal Credit UnicA hereby verify that the statements made in the foregoing pleading axe true and correct to the best of my Wormadon knowledge and belief. I understand tW false statements axe made subject to the Mies of IS Pa. C.S.A. Section 4904, relating to unswom falsification to autbo rides. Members 13` Federal Credit Union B• David Thomas, Colleatioxs Officer 5 0 1 1 IvLolll N (r.1 Q ?.rr-?? SHERIFF'S RETURN - REGULAR CASE NO: 2007-06913 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT VS CUFF MAUREEN M 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 CUFF MAUREEN M the DEFENDANT at 1620:00 HOURS, on the 6th day of December , 2007 at 1201 GUNSTOCK LANE MECHANICSBURG, PA 17050 by handing to MAUREEN CUFF a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage , Surcharge 1A11 -7 /0 -7 So Answers: 18.00 11.52 ?? -° ?:' ,, /, /f .58 r' 10.00 R. Thomas Kline .00 40.10 12/07/2007 KARL LEDEBOHM Sworn and Subscibed to before me this of day By. A. D. Karl A Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-69251, MEMBERS 1 FEDERAL CREDIT UNION PLAINTIFF Vs. MAUREEN M. CUFF DEFENDANT TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 07-6913 Civil Term : CIVIL ACTION-LAW PRAECIPE Please enter judgment in the above captioned proceeding in favor of Members I' Federal Credit Union, Plaintiff, and against the Defendant, Maureen M. Cuff, in the amount of Twenty-eight Thousand Ninety-seven and 31/100 Dollars ($28,097.31) together with additional attorney's fees and costs of suit and interest at the legal rate on and after the entry of judgment on the complaint. Judgment is entered pursuant to Pa. R.C.P. 3031 for failure to file an Answer on behalf of Maureen M. Cuff to Plaintiff's Complaint within twenty (20) days of service thereof and after a 10-day Notice was sent. A"V 4. Date: January 8, 2008 arl M. edebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff I hereby certify that notice of intent to take a default judgment was forwarded to Maureen M. Cuff by United States Mail, first class, postage prepaid on December 27, 2007. The aforesaid notice was contained within an envelope bearing the return address of the undersigned. The notice has not been returned to the undersigned as undeliverable or otherwise. A copy of the notice and Postal Form 3817 are attached hereto and marked Exhibit "A". M. Ledebohm, Esquire •e MEMBERS 1 ST FEDERAL CREDIT UNION PLAINTIFF Vs. MAUREEN M. CUFF DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 07-6913 Civil Term CIVIL ACTION-LAW IMPORTANT NOTICE TO: Maureen M. Cuff 1201 Gunstock Lane Mechanicsburg, PA 17050 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800)990-9108 Date: December 27, 2007 U,S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE' ------- - Recel, Karl M. Ledebohm, Esq. P.O. Box 173 - New Cumberland, PA 17070-0173 One piece of ordinary mail addressed to PS Form 3817, January 2001 Respectfuul? submitted, zarl. Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff o? O D O ?I ? m '1 r ? N P? NC= -.1?9053 J '3D -i m EXHIBIT "A" CH) C) 00 ? a c Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-929 MEMBERS l i FEDERAL CREDIT UNION PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. MAUREEN M. CUFF DEFENDANT : NO.: 07-6913 Civil Term : CIVIL ACTION-LAW NOTICE OF JUDGMENT PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE TO: Maureen M. Cuff 1201 Gunstock Lane Mechanicsburg, PA 17050 You are hereby notified that on ?0_n !_ , 2008 the following judgment has been entered against you in the above captioned case: Judgment in the above captioned proceeding in favor of Members 1St Federal Credit Union, Plaintiff, and against the Defendant, Maureen M. Cuff, in the amount of Twenty-eight Thousand Ninety-seven and 31/100 Dollars ($28,097.31) together with additional attorney's fees and costs of suit and interest at the legal rate on and after the entry of judgment on the complaint. Judgment is entered pursuant to Pa. R.C.P. 3031 for failure to file an Answer on behalf of Maureen M. Cuff to Plaintiffs Complaint within twenty (20) days of service thereof and after a 10-day Notice was sent. Dated: 2?, L ?_' P onotary I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 is: Maureen M. Cuff 1201 Gunstock Lane Mechanicsburg, PA 17050 A: Maureen M. Cuff Por este medio se le esta notificando que el de 2008 el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso mencionado en el epigrafe.. Fecha: Protonotario Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado de residencia: Maureen M. Cuff 1201 Gunstock Lane Mechanicsburg, PA 17050 Respectfully Date: January 8, 2008 K# M. Ledebohm, Esquire v Fupreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. SECTION 101 TO SECTION 149 ETC. MEMBERS 1sT FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff 07-6913 Civil Term VS. Amount Due: $28,097.31 Interest from: 1/11/08 per day at the legal rate Atty. Fees: to be added MAUREEN M. CUFF Atty's Com. N/A Defendant COSTS TO BE ADDED TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Maureen M. Cuff, 1201 Gunstock Lane, Mechanicsburg, PA 17050, Defendant; and (3) and against N/A Garnishee (s); (4) and index this writ (a) against Maureen M. Cuff, 1201 Gunstock Lane, Mechanicsburg, PA 17050, Defendant; and (b) against N/A Garnishee (s), and levy upon any and all personal property of the defendant (s) as follows: Any and all personal property located at the address of the Defendant, 1201 Gunstock Lane, Mechanicsburg, PA 17050 including, without limitation, any and all vehicles of Defendant. (c) Exemption has (not) been waived. Dated: 3 " ?0 - zodeol Karl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 2u ma o r? ? c v 4A. c . o st, o o - ?g o poID op s- 0 o , SL1 17 (- r l" i C ` WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6913 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION, Plaintiff (s) From MAUREEN, M. CUFF, 1201 Gunstock Lane, Mechanicsburg, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all personal property located at the address of the Defendant, 1201 Gunstock Lane, Mechanicsburg, PA 17050 including, without limitations any and all vehicles of Defendant. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $28,097.31 Interest from 1/11/08 per day at the legal rate Atty's Comm % Atty Paid $159.10 Plaintiff Paid Date: 3/17/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs to be added Curtis . Long, oPho4ta- By: Deputy REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: PO BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 ' ou?ti? of ?unr?Prt? ? ? era _y f R. THOMAS KLINE Sheriff et » W EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 05/19/08 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Sergeant Members 1St Federal Credit Union vs Maureen M. Cuff Writ No. 2007-6913 Civil Term ?Property Claim Determination Dear Sir, 4 Reference is made to Property dated May 9 2008, entered" ? T by Rex Cuff, pertaining to Writ of Execution No. 2007-6913 Civil Term, r T' Members 1St Federal Credit Union -vs- Maureen Cuff. 77 _ r R. Thomas Kline, Sheriff, has determined that the claimant, Rex Cuff, r < =%` `' in the above mentioned property claim, is the owner of the property set forth them. 9 ? Thomas R. Kline, Sheriff B ? cc Karl Ledebohm, Atty for Pltff Maureen M. Cuff, Deft Rex Cuff, Claimant PROPERTY CLADI 7 Members 1st Federal Credit Union VS Maureen M. Cuff TO THE SHERIFF OF CLTAI BERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 07-691.x The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE All personal property that was $5,000.00 (estimated) identified in the Sheriff's Execution-Levy Form served on 4/17/08 and attached hereto as Exhibit "A" THE CLAITIANT OBTA.INZED TITLE TO THE PROPERTY AS FOLLOWS: Claimant is the Htrahanri of the nefenrlant And nlaims nwnPrahii intareat ac tenants by the ontlret I cam AZi rtua of c"lr'qui r-Lq the sllb jprtPrn= Ar_ty r7oanri bed a- b-oye during the?^.(Lursip of the (l ai m?nf ? ? marriage to llo'FamaAnt. Date Claimant _ R P x A_ Cuff State of Pennsylvania: County of C»betlend Z* LLPH i N . eFA ' ` - a u Ff being duly sworn according to law, deposes and says that the above list in the property claim are correct and true. Swo d subscribed to before me ( ?{+ G Cr- This'dav of Claimant 144 Pub 'c COMMONWEALTH OF PENNSYLVANIA Notarial Seal Linda L. Fetteftff, Notary Public Derry Twp.. Dauphin County My Commission Mores Nov. 8, 2011 Member, lb nnaylvanla Arrroalation of Notaries "EXHIBIT A" , _ Wy ons Make Model Serial Cal/Gauge Make Model Serial CallGauge Make Model Serial Cal/Gauge Make Model Serial Cal/Gauge Misc. Vehicles (Boats, Snowmobiles, Trailers, Etc) Make z?V- Tag ?f?? Condition Z, Model S?r7 - ow-%n? vin sC3??5??5S?i/63GZ? Make Tag. Condition Model Vin Make -Tag Condition Model Vin Make Tag Condition Model Vin. No. 3241 P. Execution-Levy Form Defendant 1?.l,ZzegU Address Instruction Checklist- C 1. Explain Execution 2. Explain Levy 3. Explain Time Limitations 4. Explain Sheriff's Posting 5.. Explain Property Claims 6. Defendant can't move, giveaway, sell, barter or take out of the County of Cumberland 7. Penalties for non compliance to laws L/R Sofa. ?L FIR Love Seat Chairs Coffee/End Table Piano/Organ _ Lamps ? ? Misc. Furniture _ Rugs Pictures ./ Mirrors Television ?L VCR ? DVD Desk Computer Computer Printer Fax Machine Stereo Grandfather Clock Gun Cabinet Video Games Answering Machine Play StadomMox_ Date Served 17 ,r Served ByT C/ten. Dinin Room ' Table Chairs Buffet 2- Lamps Silverware Rugs Pictures ?Chinaware . /Hutch Kitchen Dinette Table Chairs V Microwave ? Utensils ? Pot&Tans iron Ironing Board Refrigerator ?Stove-Gas/Electric S -?Wasber =Dryer Freezer Mixer Blender Food Proc. Television Radio ? Coffee Pot Toaster Telephones Bedrooms Bed Dresser Chairs Lamps Rugs Bureau Night Stand Television Radio Stereo Clock Telephone Cedar Chest Computer Computer Printer Playstation/Xbox VCR/DVD Video Games 1 s 2nd L/ -Lz f Bedrooms Bed Dresser Chairs Lamps Rugs Bureau Night Stand Television Radio Stereo Clock Telephone Cedar Chest Computer Computer Printer PlaystationMox VCR 'DVD Video Games Garage/Shad Lawnmower Hand Tools Power Saw Power Drill Garden Tools Sporting Equipment Camping Equipment Tools Bicycles Snowmobiles Snowblowers N,D. 3245 3rd 4m r-Z L D ? 3 ? ?K Basement Miscellaneous dy?y( tk) Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS 1 FEDERAL CREDIT UNION PLAINTIFF Vs. MAUREEN M. CUFF DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO.: 2007-6913 CIVIL ACTION-LAW OBJECTION TO SHERIFF'S DETERMINATION BY MEMBERS 1sT FEDERAL CREDIT UNION TO THE PROTHONOTARY: Enter objection to the sheriff's determination of ownership of the property. submitted, Date: 23 -0 9S 'vsa11 1V1. irvaavWallll, -t- Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff OD ?? _s V MEMBERS 1St FEDERAL CREDIT UNION, PLAINTIFF V. MAUREEN M. CUFF, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 07-6913 CIVIL TERM ORDER OF COURT AND NOW, this S© day of May, 2008, a hearing shall be conducted on the within property claim in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 11:30 a.m., Wednesday, June 11, 2008. Edgar B. Bayley, J. ? Karl M. Ledebohm, Esquire /For Plaintiff ?/ Maureen M. Cuff 1201 Gunstock Lane Mechanicsburg, PA 17050 Sheriff sal COF I £ s rnw (L ,511 f?U? ?. `;.,', ,.?'P?.,i ;? ?,. r.,- _ f?? { ? ` ?1, j ?J ??????„/ }? F MEMBERS 1 ST FEDERAL CREDIT UNION, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MAUREEN M. CUFF, DEFENDANT 07-6913 CIVIL TERM ORDER OF COURT AND NOW, this day of June 2008, upon consideration of the property claim filed by Rex Cuff and the Objection to Sheriff's Determination filed by Members 1St Federal Credit Union it is hereby ORDERED that the Sheriffs levy is hereby released as to all the personal property subject to Rex Cuffs property claim except for the motor vehicle titled in the name of Maureen M. Cuff alone being a 2005 Chrysler VIN #1 C3AL56R55N663612 and the property claim of Rex Cuff is hereby withdrawn as to the said vehicle, with prejudice. -/Karl M. Ledebohm, Esquire PO Box 173 New Cumberland, PA 17070 For Plaintiff ./"'John M. Hyams PO Box 650 Hershey, PA 17033 For Rex Cuff Maureen M. Cuff 1201 Gunstock Lane Mechanicsburg, PA 17050 heriff (2LI-Eg ?n?oB C7 FA ?w ? ?° { ? ?Fig W • ??? 1 E? G7 N R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Advance Costs: 252.32 Sheriff's Costs: 252.32 Docketing 18.00 000.00 Poundage 140.00 Advertising 10.00 Law Library .50 Prothonotary 2.00 Refunded to Atty on 09/22/08 Mileage 26.00 Surcharge 20.00 Levy 20.00 Certified Mail Post Pone Sale 15.00 Garnishee Postage .82 o TOTAL 252.32 V 'I a q So Ans ers; 00,001, R. Tho as Kline, Sheriff w By Claudia A. Brewbaker CC- AJLI h l .? d 81 8VW 8001 L L? C dJId3HS 3H1 --'G 3.ijAj,(jj crp 4 L, o?z. Ck WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6913 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION, Plaintiff (s) From MAUREEN, M. CUFF, 1201 Gunstock Lane, Mechanicsburg, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all personal property located at the address of the Defendant, 1201 Gunstock Lane, Mechanicsburg, PA 17050 including, without limitations any and all vehicles of Defendant. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $28,097.31 Interest from 1/11/08 per day at the legal rate Atty's Comm % Atty Paid $159.10 Plaintiff Paid L.L. $.50 Due Prothy $2.00 Other Costs to be added Date: 3/17/08 (Seal) REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: PO BOX 173 NEW CUMBERLAND, PA 17070-0173 Curtis R. Long, Pro ry By: Deputy Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 ?" FEDERAL CREDIT UNION PLAINTIFF Vs. MAUREEN M. CUFF DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO.: 07-6913 Civil Term CIVIL ACTION-LAW PRAECIPE TO RELEASE FROM JUDGMENT TO THE PROTHONOTARY: Please release from the lien of the judgment entered in the above captioned matter all that certain real estate and improvements erected thereon known and numbered as 1201 Gunstock Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050-2098, owned by defendant, Maureen M. Cuff. Date: November 4, 2010 `Karl M. Ledebohm, Esquire Supreme Court ID #59012 P.O'. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff _ik y . . .. Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 170700173 (717)938-6929 MEMBERS l" FEDERAL CREDIT UNION PLAINTIFF Vs. MAUREEN M. CUFF DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO.: 07-6913 Civil Term CIVIL ACTION-LAW CERTIFICATE OF SERVICE I, Karl M. Ledebolim, Esquire, hereby certify that on the 8th day of November, 2010, I served a true and correct copy of the foregoing Praecipe to Release from Judgment upon the following individuals by first class mail, postage prepaid, addressed as follows. Maureen M. Cuff 1202 Egret Court Mechanicsburg, PA 17050 Date: November 8, 2010 Supreme Court ID 9: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 t ! l r i?s :? i 4'JTyi?'14rT t? Poll "jh7?:fV 6 d r 4s tFj 'q Kati M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)93"929 MEMBERS 1 a ` FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. NO.: 07-6913 Civil Term MAUREEN M. CUFF DEFENDANT : CIVIL ACTION-LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment entered in the above captioned matter satisfied. Date: November 10, 2010 &l M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff %L I 06 4` ?CP