HomeMy WebLinkAbout03-5792MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF,
VS.
DONNA M. BERDNICK n/k/a
DONNA M. GOODHALL
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION-LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATrEMPTING 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 fights
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 1s~r FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
DONNA M. BERDNICK N/K/A
DONNA M. GOODHALL
NO.:
DEFENDANT.
CIVIL ACTION-LAW
COMPLAINT
AND NOW, comes Members 1st Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
Plaintiff, Members 1~t Federal Credit Union ("Members la"), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
Donna M. Berdnick N/K/A Donna M. Goodhall ("Defendant") is an adult
individual having a last known address of 30 Mashapang Road, Union, CT
06076.
On or about April 10, 2001, Defendant borrowed from and agreed to repay to
Members 1st TWENTY THOUSAND THREE HUNDRED TWENTY-
TI-IKEE AND 02/100 ($20,32302) dollars (the "Loan"). The Loan is
evidenced by a Closed-End Note, Disclosure, Loan and Security Agreements
dated April 10, 2001 (the "Note") executed and delivered to Members 1~t by
Defendant. A copy of the Note is attached hereto as Exhibit "A" and made
part hereof
The Note has never been assigned by Members 1a and is still held by it as a
valid and subsisting obligation of Defendant.
Pursuant to the terms and conditions of the Note, Defendant agreed to pay to
Members 1st monthly installments of principal and interest in the amount of at
least $458.16 each beginning on May 16, 2001 and continuing on the first day
of each month thereafter.
Defendant is in default of Defendant's obligations under the Note as a result
of Defendant's failure to make the payments due to Plaintiff as set forth in the
Note.
By letter dated August 27, 2003, addressed to Defendant, Members lst
exercised its rights under the Note and accelerated all amounts due under the
Note and demanded the payment of all amounts due under the Note. A copy
of Plaintiff's Demand is attached hereto as Exhibit "B" and made part hereof
As of the date hereof, Defendant is indebted to Members 1st in the amount of
SIXTEEN THOUSAND EIGHT HUNDRED TWENTY-SEVEN AND
00/100 ($16,827.00) dollars itemized as follows:
a. Outstanding principal $14,665.02
b. Interest to October 27, 2003 547.43
c. Late fees 114.55
c. Attorney's fees 1,500.00
e. Total due to Members 1 st as of October 27, 2003 $16,827.00
9. Defendant also agreed under the terms and conditions of the Note that in the
event of default there under Defendant would pay, in addition to the amounts set
forth in paragraph 8 above, costs incurred by Members 1st as a result of the
institution of these legal proceedings.
10. Interest continues to accrue on the above obligation at the rate of $5.02233 per
day including on and after the entry of judgment on this complaint and legal fees
and costs continue to accrue.
11. As set forth above, Members 1st has made demand upon Defendant to make
payment of all amounts due to Members 1 st under the Note and, as of the date
hereof, Defendant has failed and refused to make payment of all such amounts
due to Members 1st.
WHEREFORE, Plaintiff, Members 1 ~ Federal Credit Union, demands judgment
against Donna M Berdnick N/FdA Donna M. Goodhall in the amount SIXTEEN
THOUSAND EIGHT HUNDRED TWENTY-SEVEN AND 00/100 ($16,827.00) plus
interest at the rate of $5.02233 per day, through the date of payment, including on and
after the date of entry of the judgment on this complaint, additional attorney's fees and
costs of suit.
Date: October 30, 2003
Respectfully submitted,
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
5000LoulseOnveoPO, Box40 457 W MAIN ST
M~n~=bur=,ParZOSS WALNUT BO_TTOM, PA
1~, 5000 ..... 1~3118-01
AA7~58 , 75058
BERDNICK~ DONNA
CLOSED-END NOTE, DISCLOSURE,
LOAN AND SECURITY AGREEMENTS;
17~66
X PREFERRED
~N#URL PERCENTAGE FINANCE CHARGE: Amount Financed: The Tota~ of Payments: The
P~TE: The cost o~ your The dollar amount the credi amount of credit provided amounl you will have paid
to you or on your behalf, a~ter you have made all
cred'rt as a yearly ate w~ll cost you. I payments as scheduled.
1~, 5000 % $ 7166.58 $ 20323. ..... 02 ~___.! $ 27489, 60e
Variable Rate: The Annuat Percentage Rate may increase dudng the term of th~s transaction if the N/A
Prepayment: Ir you pay off ea~, you
will not have to pay a penal~y.
.See your contracl documents fo~ any
(Index)
changes. We add a margin of N/A to Ihs Index value. The rate will change monthly on the first day of the month. The rate will never be h~gher than the
maximum rate allowed by law, and it will never be less than _ N / A Any interest rate increases will result In more payments of the same amount. For Example,
il your loan was for $5,000 at ! 5% for 48 months a_nd_ the Annual Percentage R~.!e__ir~(~!eas~d by 2% after one year, the term of your Io~m would increase by hvo months.
Your NemlNr of Peyme~e Amouot of Payments When Payments Are Due I Propa~'y Inlurance: You may obtain properly insurance
Payment 59 45~', 16e monthly Begin 05-16--~1 lfr°manyoneyouwantthatlsacceptabe othemddit
union. If you get the insurance rom the cred t un on you
Schedule I 45El. 16e Final due 04-16-06 wiltpay
will be:
................... $ N/A
~ecurlty: Collateral secudng other loans with the credit union ~ the goods or
~ll aisc secure this loan, You are g/ring a security Interest in I I property being I~ i Other
your shares and/or deposit in the credit union, and: [ [ purchased b
Late Charge: If a payment is Isle by 10 days or .... Required De_posit ~l-a~ce: T~nnnual IFtl ng Feel Non-Filing Insurance:
more, you will be charged a lare tee of 5% of your I ~erCerntage Rate does not take into account your 13 / a
scheduled payment. I equl ed oepcei~ balance, i$ $ N/A
ITEMIZATION OF TNE AMOUNT FINANCED
$~T~ON O~ ~MOU~ ~0323. ~NmCe00~ O,mm°u"~ ~*vs. ............. TO YOU ~'0081 .O'"EC~Y 18 !lS ^MOU"r' ~^~O
Paidto S 241· 84
Othe~son $ n/~
Your Behalf
$ n/a
ToCredit Ins,-~rance $ n/a To
ToEnc Fee $ To
TO $ To
NOTE AND SECURITY AGREEMENT IC(~NTINUEO ON REVERSE SLOE)
The following paragraph applies only if this is a variabie rate loan. The initial rate of interesl is N/~ %.
[ntsresf~ interest will be charged from the date of this loan until you have paid what you owe under this Agreement. The interest rate is subject to change as follows
If the ~1/~ (Index) changes. We will add e margin of N/il to the ~ndex value.
The rets will change monthly on the first day of the month The rate will never be higher than the maximum rate allowed by law, and it will never be tess th~nN/~l
AnY intere"'tt rate irK;('ea'~e~ witl result th more payments °f the same am°unt' ~HZBI? "A" ~
MODEL
SECURITY INFORMATION
TYPE VALUE
n/a
iOTHER (Describe): ~ n /
an(t''°r Dap°sits °fiYc~ P _l~:Jge Shares IS~ A~OUN~/~ ACC~BER sA~UNTn/a ACCOU~ NUMBER
agree that the terms a~ ~it ohs in the disclosure stalement above and the loan and s~-d~ a~r=~m=n ~ ~ ed on ~e rever~ aide of ~his document
~this~ ii herels~ore h~no~borrower w "' ~ ....... · PPY
I~veral~ ~ a~k~,.,~- .~ ..... e agree that ~l the conditions of the loan and ~cu~ agreements ~vem ng Ih s {o~ sh~ll Apply to both i~y and
.~. ~ -~-,=~ ~.a~ nave rece~v~ a COpy of the [o~ ~ecu~ agreements and digit,re ~talement. --
j~to~il~co~erag~onl~)W you~unoe ~~O~e~ore~lngOu~eyourhome~.~waceso ~ro~o~b
~ or more ~er week a~ ~ve bee, so wor~*~ or 30 days or mo~e ~f~ ~? '-- ~ ' ~
~y (~r~swet~ to the ~ questio~ are ~u .... ~ ~ ~ ''~'~ ~ ~ ' , ,~-
~ingle Credil Life
Joint Credi[ Lite
Indicate which applicant(s): E] Applicant '~
¢NITIAL AMOUNT OF LOAN j TOTAL INSURANCE ~REMIUM
s ~e3~. e~ /s ~41. 84
$ . n?a
NOTE: ONLY PPUCANT MAY APPLY FOR DISASILITf COYERAGE
Gre~! Dteebltlty ~ ~-~
Indicate which a~OPlicant: [] Apphcant ~] Co.applicant
CREDIT D~*EABIUTY ~ I APA JC.~NT
CREDIT LIFE
~Rd=13iT I IKU~N {~,t~13V
I 04-tO-Or
}~'~ T~ESE A~SPEEMENTS. THE WORDS "1' "ME/' "MY" AND "MINE" MEAN ALL THOSF NAMED AS DE,=-TO~S. THE WORDS "YOU/' "YOUR" AND
"YOURS" MEaN THE CREDIT UNION.
LOAN AGREEMENT
Psymants/Finsnca Charges: For vatue ~ece~ve~, I promise to pay at your
office, all ~mounts due All payments shall be made pursuant to the
discrosure $1alement on the face of li~s document. I understand that the
tinance charge and ~,o~al of payments show~ on the reverse side cl this
Debtor Responslbitib/: I promise to nolify you of any change ;n my name,
Defz~uit; I stall be considered in detaul~ if any of the following occur: (1) If I
break ar~y promise made under this Loan Agreement or under the Security
stated in my application; or 3) if you should, in good faith, believe that
impaired; or (4) if I die: or (5) if I file a petition in bankruptcy, insolvency, or
receivership Or am put involuntarily info such proceedings; or 6 if the
collateral, irony. ~iven as security for this loan ia lost, damaged or
destroyed, or if it iS levied against, attached or garnished; or 7) if I do not
Pay on time any of my other or future debts to you. If I default, you may, at
payable, and J must immediately pay the total unpaid balance, as well as
the Finance Charge lo dare. any ~ate charges and costs of collection
incur up to 20% of the unpaid principal and i~terest. Costs of collection
~his loan or ip. ressr'~e or prolect the credit union a rights and remedies,
mediation or ~ettle~ent negotiations, investigation and assessment of the
credit un~Ons' rights, pa~ictpsltOn in bankruptcy cases, matters, and
proceedings (including without limitation filing proofs of claim pursuing
reaffirmation agreements, attending meetings of creditors, and pursuing
complaints, motionS, end ob actions that relate in any way to the credit
ur~;cn'~ .~oltateral or r!ght to pa,/menS), collateral disposition, non.
bankruptcy suits and~or administrative actions, and appeals, The principal
Slatutory Lien: If I am in default, federal law gives you the dght to apply
the balance of shares and/or dividends in my account(a) al the time of
right without further notice to me,
Delay In Enforcement: You may dalay enforcing any of your rights unde~
irregular Paymanta:.Y_ou may accepts late payments or partiaf payments,
even Ihough marked payment in full, without losing any of your rights
us. You do oct have to notify m~ that this agreement has not been paid.
You may extend Sa'la terms of payment and release any security without
Contractual Pledge of Sheree: I pledge all my shares and depeelts
Icon. In case I default, you may apply the~e IftaM and deposits to
the payment of ~Jll auras due at the time of default, Including coats
of cottaoflon and reeaonable attorney's tees. No 1lan or right to
impress a lien on shares ~d, d~e~eita shall apply to any of my
shares which may be held In an "Individual Retirement Account" or
'~Keogh Plan,"
SECURITY AGREEMENT
I To secure payment o h a can and all expenditures incurred by
the credit union in connection with th S can, or n rea z r~g on S
security interest I grant to you e security interest in the property
deacr!bed on the rever~e side of this document. The security Interest
Includes all increases, substitutions and additions to the secured
property, proceeds from any insurance on the secured property and
all sarongs received /rom the secured property.
Cross-co stero aatlon Property/given as security for thi~ loan or for..
any of her loan will secure all amounts ! owe the cred t union now eno in
he fu ute However ~ro~erty sacur ng another debt will not secure this
loan if such property'ta my princ pa dwe ng or ara household goods.
2. i will nor change the Iocalion ct. sell or transfer the collateral unless
3. warrant tho. have good e o ha co ateral frae of all security
the indicated place.
4. I will pay all taxes, assessments, and tiens against or attached to the
property described and urther agree to keep the property in good
defend the propedy sg:~mst adve'se third party claims.
5 I will maintain insurance to cover any vehicle or other propeAy in which
you have a security interest, This insurance will be in a torn and an
amounl satisfactor/to you. I wi I supp y you with proof of such insurance
u~ti a sums owed to you arid secured 6y this property are repaid, if I fail
nsurance o your own and add ha coat of such to the sums owed. This
coat w ( bear interest at ~e contrect rate until paid. I further assign to you
the right to ecs ye he p~oceeda o a y insurance on such property, and
direct any insurer to pay those proceeds directly to you. I authorize you to
endorse a~y check or draft prov,M~d a~ the proceeds of such insurance,
and apply those proceeds to the cues owed to you.
urther aulhodze you ~0 provide your Insurance Service Center with the
necessary information Ici verification o adequa e coverage.
acknowledge the nsu ance or any extension thereof, placed by you is
without benefit to me inclividually but s pdmart y or the pro ec ion of you,
6. Should you feel at any tlr'ne fhet the security presented has diminished
in value, or for any casco ee tho add tional security is required, I agree
o ass gn o you within tan (10) days whatever additional security yO~ feel
is necessary to protect yourself ago nat pose bls loss.
? a defauJt as defined in the Loan Agreement should occur, you have
the author ty upe~ such da au t to repossess and sel~ the cofiateral in a
~awfut manner. In such case, you or your au horizod representatives may,
at your option, enter the premises where the collateral is kept and take
possession sub eof to appticab[a awe You have the hght to render the
property p edged as co a e a unusable and may dispose of the collateral
on the premises where the collateral ia kept. Ii you decide to sell the
collateral at a publ c sa e, pdvate sale or othenvise dispoas of the
collatera you w no fy me of the time and piece of the intended
disposition ten 10) days prior to the sale or dispositidn. It you sell or
otherwise dispose o the co a ara you may collect from ma reasonable
expenses incurred in the retaking, holding and preparing the COllatereJ tot
and arra.,ng ng he sa e of he collateral. You may also collect raasonabio
aflorneys ess and ego expenSes perm[fled by applicable law, Incurred
n connection with dispos tion of the property. Uniass I delault, I may keep
possession of the property (collaterol dasCtfbed and use it i~ any lawful
manner cons stent w h h s agreement or with the insurance policy ?n the
coils erst. i understand that you have certs n righ s and legal remed~as
available to you un0er the Un form Commercial Code and otha~ a~plicabia
laws. and ha you may use hess rights to enforce ~ayment if I default, in
the even w la your aquest assemble the property (co~lataral) and
make ~t avNlab · to you at a pla~e of your choosing, If you decide ld waiva
th~s default, if will not constitute waiver of any other subsequan defaufis.
8. You are hereby appointed as my Attorney-in-Fact to peflorm any acts
g f there s more than one borrower our obligations under this
agreement are pint and several, each being equally responsible to
the terms of th s agreement,
10 This security agreement not only binds me, but my executors,
edministrators,he[re, and assign:~.
6100 2/99
F.55400 10/00
KARL M. LEDEBOEIM
ATTORNEY-AT LAW
PO Box 173
New Cumberland, PA 17070-0173
Phone 7I 7-938-6929
Fax 717-932-0317
August 27, 2003
(Via Certified and regular mail)
Donna M Berdnick
n/k/a Donna M Goodhall
30 Mashapang Road
Union, CT 06076
Re: Members Ist Account No.: 193118-01
Dear Ms Berdnick:
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 1~ Federal Credit Union ("Members 1st'') has requested my office to
collect the amounts due to Member's 1** under the above account
As you know, you are in default of your obligations under the above account (the
"Account") evidenced by a Closed -End Note dated April 10, 2001 in the original
principal amount of $20,32303 (the "Note") due to your failure to make the payments
required under the Note in a timely manner As a result of your defaults, Members 1~
hereby accelerates all amounts due to Members 1st under the Account and the Note and
hereby demands the payment of all amounts due to Members 1~t under the Account and
the Note in the amount of $15,085.98 itemized as follows:
1 Principal $14,66520
2 Interest to 8/26/03 236.05
3 Late fees 6873
4 Legal Fees I15 0Q
5 Total due to Member Ist as of 1/26/03 $15,085 98
Interest continues to accrue on the above obligation at the rate of $5 02233 per
day
EXHIBIT "B"
August 27, 2003
Page 2
If you fail to deliver payment of the $15,085 98 together with additional interest
to the date that payment is delivered to Members 1s~ 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 and the corresponding Note without further
notice In such event, in addition to the above amounts, you may also be responsible for
the payment of additional reasonable legal fees and costs of suit incurred by Members 1s~
Nothing herein shall constitute or be construed as an agreement on behalf of
Members Ist to accept any terms and conditions in exchange for payment of the amounts
due under the Account except for the immediate payment of ali amounts due to Members
1~t Nothing herein shall constitute a waiver of any rights or remedies which Members
lN 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 1~ to postpone or
extend the maturity date under the Note
Members 1't looks forward to the payment of the $15,085 98 together with
additional interest to the date that payment is delivered to Members 1~
V~.U( t ,r~y yoursx
:Il~Il
~ede'~o'h~n!~e~ Y'~'--'''~
KML:I1
CC: Ned Picciotti. Collections Officer
~olloI s!qlJO dol oql lu
lu[~d u! ~'u!~oddu ~olloI s[ql J.o puo oql 17 pou~!s o[uuu oql su?otu p,u§!saopun oqz
oo!lou
s!ql jo ld!o:>oa jo sXep (0 £) X!~!ql u!ql!~ no~( mo.lj lsonbo.I uoll!a~ uodn lol!poao [eu!$~ao
oqljo ssoappu puu omeu oql ql[~ noX op!Aoad I1!~ pou~!saopun oql 'JolloI s!ql jo
luolj oql uo polels .~ol!poav oql mo~ luolojj[p si lqop s[qljo aol!poav luu!~!ao oqlJI
· p!iu^ s! lqop oql omnsse li[~x pou~!s~opun
oql '0Aoq~ p01'elS S~e JOOZOql uo!laod Xue ~o lqop oql olnds!p lou op no.~ 3I
lqop oqlJO UOll*99!.~o^ uoll!~a olnl!lSUOO II!a l!nsa~l
p[~s u! poi9 lu!~Idmoo oql 'sXep (0£) XUgtl otllJo uo!lmldxo otll o~ojoq lqop slql
Ol no~ lsu[~ pol~J uooq s~q l!ns~1 ~ J! l~ql 'pop!Ao.~d '.lqop oqljo uo!ll~ol.J!lo^
t~l!~ potls[mnJ *q I[!~ noX 'o~!1oN s!tI1jo ld[o~oJ .I,[[~ sX~p (0£) XH!ttl u!t[l?x pou~!saopun
o141 l:)l~luoo noX pul~ ~olOO1,1~1 IlO!Hod .4ul~ io 'lqop s!l~loto Xl!p[Iu^ otiS. olnds[p noX 1I
lqop u lOOllOO Ol ldtuolle ue s! ~olloI s[qj~
3[DI&OhI
ReStricted Delivery Fee
(Endorsement Required)
Total Postage & Fees
· Complete items 1, 2, and 3, Aisc complete
item 4 if Restricted Delivery is desired.
· Pdnt your name and address OR the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if space permits.
1. ,z~ticle Addressed to:
A, Signature
t-'-. /0. #~/~, I / i-I Agent
B. Received by (Prinre~'a~n~ame) ~ ) C. Date of Delivery
D. is ~lelivery address different from/tern 1 ? i~ Yes
If YES, enter delivery address below: I'1 NO
3, Se~,[~=e Type
Certified Marl i'-I Express Mall
Registered J~ Return Receipt for Merchandise
I-1 Insured Mail n C.O.D.
4. Restdcted Delivery? (Extra Fee) ~] Yes
2, ,~flcle Number
cr~er~f~m~'Wce/Ce), 7002 2410 0006 7109 1516
PS Form :~8~q ASgdS[t ~(~1 i ~'
102595-O2-M- 1540
V~RIFICATION
1, Leonard Picciotti, Collections Officer ~r Members 1~t Federal Crcdil Union.
being authorized to do so on behalf of Members 1~ Federal Credit Union. hereby verify
that the stalements made in the foregoing pleading are tree and correct to the b~st of my
information knowledge and belief I understand that false statements are made subject to
the penalties of 18 Pa. CS.A Section 4904, relating to unsworn falsification to
authorities
Members 1'~ Federal Credil Union
e~rd Picciot~i, Coll~ciions -
O~cer
MEMBERS 1 ST FEDERAL
CREDIT UNION
: IN THE COURT OF COMMON PLEAS
CLTMBERL)~qD COLTNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NO.: 03-5792 Civil Term
DONNA M. BERDNICK n/k/a
DONNA M. GOODHALL
DEFENDANT
CIVIL ACTION-LAW
AFFIDAVIT OF SERVICE
I, Karl M. Ledebohm, Esquire, being duly sworn according to law, swear and
affh:m as follows:
That on the 6th day of November, 2003, I sent by United States certified mail the
NOTICE TO DEFEND AND CLAIM RIGHTS along with PlaintiW s Complaint in
the above captioned matter to the defendant, Donna M. Berdnick n/k/a Donna M.
Goodhall ("Defendant"), at the following address outside of the Commonwealth of
Pennsylvania:
30 Mashapang Road
Union, CT 06076
Service of process of said complaint was completed upon Defendant's acceptance of
the mail pursuant to Pa. R.CP 404 (2) and 403 on November 8, 2003 as evidenced
by U.S. Postal Form 3811 bearing the signature of Defendant, a copy of which is
attached hereto as Exhibit "A" and made part hereof
/Karl Mi Ledebohm,' ESq.
/Supre, p.o. 59012
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Members 1"t Federal Credit
Union
Sworn before me, a notary public this
My commission expires:
0 NOTklIIAL SEAL
D£B~ L SWIGERT, NOTART I~UBLII~
UTH MIOOLETON'IWR, CUMBERLANO CO.
MY COMMISSION EXPIRES.JUNE 26~ 2006
day of November 2003.
EXHIBIT "A"
7002 2410 0006
7108 7878
MEMBERS IsT FEDERAL
CREDIT UNION
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Vs.
NO.: 03-5792 Civil Term
DONNA M. BERDNICK n/Fda
DONNA M. GOODHALL
DEFENDANT
: CIVIL ACTION-LAW
PRAECII'E
TO THE PROTHONOTARY:
Please enter judgment in the above captioned proceeding in favor of Members 1
Federal Credit Union, Plaintiff, and against the Defendant, Donna M. Berdnick
n/k/a Donna M. Goodhall, in the amount of Sixteen Thousand Eight Hundred
Twenty-seven Dollars ($16,827.00), plus interest at the rate of $5.02233 per day
through the date of payment, including on and al[er the date of entry of judgment
on the Complaint, and attorney's fees and costs. Judgment is entered pursuant to
Pa. R.CP. 3031 for failure to file an Answer on behalf of Defendant, Donna M.
Berdnick rffka Donna M. Goodhall, to Plaintiffs Complaint within twenty (20)
days of service thereof and al[er a 10~day Notice was sent.
Respect~y submitted,
~;upreme Court 1D #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
Donna M. Berdnick n/k/a Donna M. Goodhall by United States Mail, First Class, postage
prepaid on December l, 2003. 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 is
attached hereto and marked Exhibit "A".
. ede o m, squire
MEMBERS lST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAI~NTIF,F ~ ~ 4 : I,t I
Vs NO: 03-5792 Civil Term
DONNA M BERDNICK n/k/a
DONNA M GOODHALL
DEFENDANT
CIVIL ACTION-LAW
IMPORTANT NOTICE
TO¸
Donna M Goodhall
30 Mashapang Road
Union, CT 06076
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM
REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT
CORRESPONDENCE OR COMTvlUNICATION 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 1N TI-tIS ICASE UNLESS YOU )klUT WITHIN TEN (I0) 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
Date
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166 or (800)990-9108
PO Box 173
,~ , I I New Gu~mbe~land, PA 17070-0173
(717) 938-692w
Attorney for P!aigtiff
U.S. pOSTAk SERVICE CERTIFICATE OF MAILING
~Y B~ US~O FOR DOME$~C AND t NTE~NATIONAL ~1~, DOES NOT
Kar M Ledebohm Esquire
-- P O Box 173 It[ ,
-- New Cumber and PA 17070-0 73X-~ U~:.} /~
EXHIBIT
PSForm 3817, Mar. 1989 ~po : 1993 O - 151-o~