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HomeMy WebLinkAbout08-3615 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES : NO. M" 3(0(5 l - r M CREDIT UNION, VS. IVELISSE VELEZ Plaintiff Defendant : CIVIL ACTION -LAW NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 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 the 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 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. 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CAN NOT 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Document 4: 180057.1 EN LA CORTE DE ALEGATOS COM UN DEL CONDADO DE CUMBERLAND, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES NO. CREDIT UNION, . Plaintiff VS. IVELISSE VELEZ Defendant CIVIL ACTION -LAW AV I S O PARA DEFENDER Conforme a PA Num. 1018.1 USTED HA SIDO DEMANDO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defenses o objeciones a las demandas puestas en contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Ustedpuede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACI6N ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Document #: 180057.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff . VS. IVELISSE VELEZ Defendant CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Van Eck & Van Eck, P.C. and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Ivelisse Velez, is an adult individual with a last known address of 144 Meadow Brook Court, New Cumberland, PA 17070. 3. Defendant is, and at all relevant times material hereto has been, the primary loan applicant. 5. Defendant applied to Plaintiff for a loan for the purpose of purchasing a motor vehicle. 6. The loan application submitted by Defendant was approved by Plaintiff and Defendant signed a Loanliner Advance Proceeds Check for the purchase of the vehicle. A true and correct copy of said Loanliner Advance Proceeds Check is attached hereto, incorporated herein and marked as Exhibit "A". Document #: 180057.1 7. Pursuant to the Loanliner Advance Proceeds Check marked as Exhibit "A", Defendant agreed to the terms and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (hereinafter referred to as "Contract"). A true and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 8. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms and conditions of the Contract marked as Exhibit "B". 9. Various charges and payments were made by Defendant on the account. 10. Plaintiff provided a letter to Defendant stating that the vehicle purchased by Defendant was deemed repossessed. The letter further advises Defendant that unless payment in full was made on the outstanding loan balance, the said vehicle would be sold at a public sale and Defendant will be responsible for any resulting deficiency. 11. As a result of Defendant's failure to cure the default in payment, and pursuant to state law remedies, Plaintiff sold the vehicle at public sale. 12. Plaintiff provided a letter to Defendant indicating that there was a resulting deficiency after the sale of the vehicle. 13. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 14. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 15. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. Document #: 180057.1 16. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. 17. As of June 13, 2008, the balance due, owing and unpaid on Defendant's loan account with Plaintiff is the sum of Eleven Thousand Six Hundred Thirty-Nine Dollars and 58/100 ($11,639.58). 18. Pursuant to the terms and conditions of the extension of credit contained in the Contract, Plaintiff is entitled to receive and Defendant agreed to pay an annual interest charge on the principal loan balance. 19. Due to the default of the Defendant and pursuant to the terms and conditions of the Contract attached as Exhibit "B", attorney's fees in the total amount of Two Thousand Three Hundred Fifty-Two Dollars and 92/100 ($2,352.92) have been added to the account. 20. Any and all conditions precedent to the bringing of this action has been performed by Plaintiff. 21. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. Document #: 180057.1 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit -Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Ivelisse Velez, in the amount of Thirteen Thousand Nine Hundred Ninety-Two Dollars and 501100 ($13,992.50), plus interest, the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, VAN ECK & VAN ECK, P.C. By: ? 4. ?k kl" Melissa L. ?cir' an Esquire Attorney I.D. No. 85869 P.O. Box 6662 Harrisburg, PA 17112 717.540.5406 Document #: 180057.1 VERIFICATION I, Gregory R. Diffenderfer, Manager of the Pennsylvania State Employees Credit Union verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Pennsylvania State Employees Credit Union By: , Title: ?? ?'C Ickll? (T?? Date: 6-14-0% EIMIT CWs i a ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT R. 41('4 6-q -? v5-640 Pennsylvania State Employees Credit Union P. 0. Box 67013 Harrisburg, PA 17108-7013 717.234.8484 800.237.7328 MEMBERNAME: .p.y w( M ::; •:i.. T[tY =+' ;c '.<4.' :Rf4TAeE? Acc4L..•?+l. v ?% IVEL IVE ISSE VELEZ D 8/30/200 8846850801/L10 00056154'60 2205 CEDAR RUN DRIVE APT H EXT PURPOSE CAMP HILL, PA 17011 Dealer Purchase TRANSACTION TION 1 1 ? NEW LOAN 2 ? OPEN-END LOAN ADVANCE 3 OpCR ? HOME . . . { MaE) 4. EQUITY ADVANCE SECURITY OFFERED E XralEffi,?M AWANCE, THE MysuWRITY FORTHIB ADVANCE IS THE REAL PROPERTY pN M09T CASES ymn HOME) WHICH VOU GAVE AS SECURITY WHEN YOUR ACCOUNT IF THIS IS KOTA HOME EQITY AWANCSi. IN ADDITION TO THE PLEDGE OF SHARES IN YOUR LOANLINER' CREDIT AGREEME bM THE FOLLOSMNG PROPERTY SECURES THIS ADVANCE. ITEM PROPERTY w• EI;i,-• i`rYCG ` :a< ?LtZ C;x,• • ?Cn •^ :>: ?- ... r .1 "-1 • ti(UM- t• HONDA z 3. CCORD 2003 1 1HGCM511623A120196 SDN 19,505.00 4.OTHER YOU PLEDGE SHARES ANWOR DEPOSITS OF $ IN A00OUNT NUMBER OLD ACOOUWTA.OAN NUMBER PAYOFF AINM+ INT.) OLD ACCOUNT&OAN NUMBER PAYOFF (PRIN0.+INT. OLD ACOOUNTILOVW NUMBER PAVOFF (PRWA + INT.) OLD ACCOUNTA.OAN NUMBER 9 PAYOFF (PAM + INT.) OLD ACCOUNTA CAN NUMBER PAYOFF (PRINC.+ INt OLD ACCOUNTA.OAN NUMBER PAYOFF PRINC.+ INT.) accepting the proceeds or by using the funds advanced and deposited into your share/share draft account, you agree (1) that the properly referenced above will secure the advance and any other advances you have now or receive In the future under the LOANLINER• Credit and Security Agreement (the Plan) and any other amounts you owe us for any reason now or In the future In accordance with the terns of the Plan and (2) to make payments as disclosed above In accordance with the terms of the Plan. 0004A MIRUAL SRM. ISK r4 IH, r4, M, L!, K tJ00. 01.04. U0. ALL WORTS RESERVED PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM 43173 JV)01610o t 087.2002-1 (SIDE) ED SECURITY AGREEMENT In this agreement all references to Credit Union, we, our, or us means Pennsylvania State Employees Credit Union and anyone to whom the Credit Union assigns the Credit Agreement which will be referred to as the Plan. 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. This is a mufti-state document which may be used to lend to borrowers in all states except Louisiana and Wisconsin. 1. THE SECURITY FOR THE LOAN - 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 the reverse side. 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 or if this 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 if 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 following paragraph applies only when the box on reverse side is checked. 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 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 xoperty is lost or damaged, we can use the insurance settlement to repair the )roperty or apply it towards what you owe. You authorize us to endorse any draft or ;heck which may be payable to you in order for us to collect any refund or benefits fue under your insurance policy. You also promise to pay all taxes and fees (like vtjc oommnTv nteF%D YlTinm nu TRc ocirrDet QFnc IC tmwr nr ran 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 Plari. 10. WHAT HAPPENS IF YOU ARE IN DEFAULT - The following paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia. When you are in default and after expiration of any right you have under applicable state law to cure your default, we can require immediate payment of your outstanding balance under the Plan without giving you advance notice. The following paragraph applies to borrowers in all other states: When you are in default, we can require immediate payment (acceleration) of what you owe under the Plan and take possession of the property. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. The following paragraphs apply to all borrowers: You agree the Credit Union has the right to take possession of the property 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 until that amount has been paid. 11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT - 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 MOTOR VEHICLE IN THIS TRANSACTION 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 ARIZONA 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. .` F/?CCEPA['A[T E[n4'[evn_ n.ne. .....? .-------- Pennsylvania State Employees Credit Union No. 3615160 -- •• :n . n]r[c.:,.?au1:f.:a1 p:!i7adt;f:ra:h2.-1..i . AUTODRsFT ; vaq•OVER s; l9,GS1iyl00?,;f•'.?:.REF_RENCE" SS-tCS5080I c!D tl^ia : ,vis.:.i?E,a `OS124121" PAYiO TIIE. '.?f'/1,, 1j+?V,, ,•• lr"1?? ?D'[ ?.J ?. - ORDER CF (DEALER) r?"N T[-tlt t- f' -5•-il1__ . C 'ni Ore[f /dll el ?' iEe re: rnO bill of la n7 ,7. 1 rt. -marvud, eomin Ytl:J euIJJ, P•, UrJI ? Ic arrnaleaef en •f d 7M16 5 1?7+ sr s3ya 4M-?II %m ti€?x m gp;'?C 3 U0 i z t' 3 'E •?ZL DOLLARS 1 UNLESS DEALER EFIDOR>EWIEMBNi CO!Ai•ILTED '• M1:F.LtBER E. RSE/ Sd.Inaw D u 1 Ya1 MO ael NT COM P+:w Va.. lea 3y en3¢isfn? I(Iief u:eDl]It; li1'.'a n n Io Il.n :e v[ L[IC3 e1 [0.n m of a- IiCi?•. Gl[li:a:[a..aJ e?FS:CVulrw :..n[Jrall n..l [:;' of the tlrall:?Camryl:ti lh.lD:kwinp 11 P[7n»nt inlem.• lt[n. , II Ina P•cuala el [re :.c::014[ Y.,::r Pi] a nx Carro..r?f.l ? : •?"• • ? •/?, "? ? ? ? • C-nen:44. Tlii axloOr,ll.nYl nclM Urwt le?r•rnl•a•a ?T4m 1:=on':i.il:?.l x' •P:!a?lo M:.4ru?n? n in :fi l.•al:r t'al.:l: l:+nE :?.. • r[iJ,OUJ,.Ih•O,a,l.,)•J. cr tleed vJ..i; .hl[ln or •Jc[:o 1aGVl. ? •'fe 7..',[lar ? IUT<[a•]?n] 0 F#-II 'Al :ACn:Hf.as Of Oran( Pyn and ?A SI,[a,. af.:[aq"+`f cw yl[[eea[el lr;[er,:l. sov .4-is F::irn[7 X`I.lamRr I] Se-eiaa.lv'I..i t•:eat11 ?emih: I. lft?U F?f 717-h 74" 04 ?, v : g;i v1w ry rnLar En lore m nl?- lrrz n ?2014?0 lv«ISSe VELD - da Y? "• ??? •Co.Applicant Endwwn-t_ PA = i?r`t''•??? ' [ NO CO-A{'I LICANT VS6LS1:60111 1: 23LAIIL61: l 3to 7S26457111 4t, r[ 11000196807 se 75191 a2?006 593 92 M?S9Sg?• 1? m • 'Y 1'a -9pO m ? , Ito, V.-B, id m s .1 Z ' ;gY i 3 1 $ $ '3g?i3A $ • Cy X7'•7.' 7-i 7[?]4xu • C r.??.? S?: rp2E p a r.. -7a!? -?gg n.mn 1m^5 ?3?6372'm0 ? J T .sp :i ROL CCoM ?c? i?y°?$?Om• In S' 94 61 F 3tg i Ft? T l i J? s 1"'f u B? ? g ? mg g/ 1 0 3 ;JGaS1?Qf n 3 issE'E.njjiq??r? 1. JS to 5-. sLa'-sM?^D ?zN ri, Or ''Ji?'B Mr z w< C) EXHIBIT "B" 9 PSE,(* Pennsylvania State Employees Credit Union P.O. Box 67013 • Harrisburg, PA 1`7106.7013 • (717) 234-8484 Harrisburg, (800) 237-7328 Nationwide the financial links Loan Disclosures This LOANLINER• Credit and Security Agreement, which includes the Truth in Lending Disclosures, will be referred to as the Plan. The Plan documents include this agreement and an Addendum. You, your and borrower mean any person who signs the Plan. Credit union, we, our and us mean PSECU or anyone to whom the Credit Union transfers its rights under the Pian. HOW THIS PLAN WORKS - This is an open-end, multi-featured credit plan. We anticipate that, from time to time, you will borrow money (called "advances"] under the Plan. We are not required to make advances to you under the Plan and can refuse a request for an advance at any time. The Addendum describes the different types of credit (called "subaccounts") available under the Plan, the current interest rate for each subaccount expressed as a daily periodic rate and corresponding annual percentage rate and other charges. It may also have other terms and a schedule for determining the payment amounts. CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain subaocounis. If a credit limit is set for a subaccount, you promise not to exceed the established credit limit. If you exceed the credit limit, you promise to repay immediately the amount which exceeds the credit limit. REPAYMENT You promise-.to-repay all amounts you owe under the Plan plus interest Payments are due on the last day of the month unless we set a different day at the time of an advance. If the Addendum has no payment schedule for a subaccount, your payment will be determined at the time of each advance Payments must include any amount past due and any amount by which you have exceeded any credit limit you have been given for a subaccount. You may repay all or part of what you owe at any time without any prepayment penalty. Even if you prepay, you will still be required to make the regularly scheduled payments unless we agree in writing to a change in the payment schedule. If you have a joint sharedraft account. you will be responsible for paying all overdraft advances obtained by a ]ctrl holder of the sharedraft account. Unless otherwise required by law, payments will be applied to amounts awed under the Plan, in the manner the Credit Union chooses. PLAN ACCESS -You can obtain credit advances in any manner authorized by us. If we slow you to use your ATM/Debit card to access the Plan, you may be liable for the unauthorized use d your ATM/Debit card. You will not be liable for unauthorized use that occurs after you notify us, orally or in writing, of the loss, theft or possible unauthorized use. It you believe your ATM/Debit card has been lost or stolen, immediately inform the Crodd Union by calling or writing us at the telephone number or address tfftitt appeals elsewhere in the Plan- If the card is used to obtain unauthorized advances directly from the Plan, your liability will rot exceed $50. If the unauthorized withdrawal is from a sharedraft account, your liability is governed by the Regulation E disclosures you received at the time you received your ATM/Debit card, even if the withdrawal results in an advance being made from your overdraft subaccount. FINANCE CHARGE - The dollar amount you pay for money borrowed is called a "finance charge' and begins on the date of each advance. A finance charge will be computed separately for each separate balance under the Plan. To compute the finance charge, the unpaid balance for each day since your last payment (or since an advance If you have not yet made a payment) is muffipiied by the applicable daily periodic rate. The sum of these amounts is the finance charge owed. The balance used to compute the finance charge is the unpaid balance each day after payments -and-CredttS that balm ,,e 1 inve been sobtracted'and arty'additforts to the balancer have been made. In addition to interest, we may charge other finance charges which are disclosed on the Addendum. If the interest rate is a variable interest rate, the Addendum explains how the variable interest rate works. SECURITY -You pledge as security for the Plan all shares and dividends and, if any, all deposits and interest in all joint and individual accounts you have with us now and in the future. If a specific dollar amount is pledged for an advance, we will freeze shares in that account to the extent of the outstancling balance for the advance. Otherwise, your pledged shares may be withdrawn unless you are in default. The following paragraph applies in all states except in Ohio, Rhode Island and Massachusetts: We have a statutory lien on the shares and dividends and, if any, the deposits and interest in all individual and joint accounts you have with us and may exercise our rights under the lien to the extent permitted by state law. (We are state chartered if our name does not. include the term 'Federal Credit Union.) For all borrowers: The statutory lien and/or your pledge will allow us to apply the funds in your accounts) to what you owe when you are In defauiL The statutory lien and your pledge do rot apply to any Individual Retirement Account or any other account that would lose special tax treatment under state or federal law if given as security. Additional security for the Plan may be required at the time of an advance. If a subaccount identifies a type of property (such as `New Cars) you must give that type of property as security when you get an advance under that subaccount. A subaccount name such as "Other Secured' means you must provide security acceptable to us when you obtain an advance under that subaccount. Property you give as security will secure all amounts owed under the Plan and all other loans you have with us now or in the future, except any ban secured by your principal dwelling. Property securing other loans you have with us may also secure the Plan. O CUNA MUTUAL GROLP 1980. 2008. ALL RIGHTS RESERVED Em CREDIT INSURANCE - Credit life andlor credit disability insurance is optional under the Plan. If you qualify for and purchase the insurance from us, you authorize us to add the insurance premiums monthly to your ban balance and charge you interest on the entire balance. If you elect credit insurance, your payments may increase or the period of time necessary to repay your advance may be extended. The credit insurance rates may change during the Plan. If the rates change, we will provide any notices required by applicable taw. PERIODIC STATEMENT - On a regular basis you will receive a statement showing all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each joint borrower, notice to any one of you will be notice to all. JOINT ACCOUNTS - If this is a joint account, each of you is individually and jointly responsible for paying all amounts owed. That means we can enforce our rights under the Plan against any one of you individually or against all of you together. If you give us inconsistent instructions, we can refuse to follow your instructions. Unless our written policy requires all of you to sign for an advance, each of you authorizes the other(s) to obtain advances individually and agrees to repay advances made to the. other(s). Any joint accountholder may terminate the Plan by giving us prior written notice. If any of you terminate the Plan, the Plan is terminated for all of you. You remain liable individually and jointly for all advances incurred before termination. FEES AND CHARGES - It you give us a securt y interest in certain types of property, we may charge you a filing fee to perfect ourinterest in the property. If we do, the amount of the fee will be disclosed to you at the time you obtain an advance. We may also charge you other fees in connection with the Plan. Our current fees are disclosed on the Addendum and will be added to your loan balance unless you pay them in cash. UPDATING CREDIT INFORMATION -You promise that you will promptly give us written notice if you move, change your name or employment, or it any other information you provided to us changes. Upon our request, you also agree to provide us updated financial information. DEFAULT - The following paragraph applies to borrowers In Idaho, Kansas, Maine and South Carolina: You will be in default if you do not make a payment of the amount required when it is due. You will also be in default K we believe the prospect of payment, performance, or realization on any property given as security is significantly impaired. The following paragraph applies only to borrowers In Wlaconsln: You will be in default if you tail to make a payment when due two times during any 12 month period, You will be in default if breaking any promise made under the Plan materially impairs your ability to repay what you owe or materially impairs the condition, value, or protection of or our rig"Ain any property you gave as security. The following paragraph applies only to borrowers In lows: You will be in default if you are more than 10 days late to making a payment. You will also be in default if you do not comply with the terms of the Plan and your failure to comply materially impairs any property you gave as security or your ability to repay what you owe under the Plan. The following paragraph.oppl?s to borrowers In ail other states:.You will be in default if you do not make a payment of the amount required when It is due. You will be in default if you break any promise you made under the Plan or If anyone is in default under any security agreement made in connection with an advance under the Plan. You will be in default if you die, file for bankruptcy, become insolvent, if you make any false or misleading statements in any credit application or update of credit information, or it something happens we believe may substantially reduce your ability to repay what you owe. You will be in default if any property you have givers us as security is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value of the property or our security interest in it. You will also be in default under the Plan if you are in default under any other loan agreement with us. ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: 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 following paragraph applies to borrowers In all other states except Wisconsin and Louisiana: 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. rho following paragraphs apply to borrowers in all states except Wisconsin and Louisiana: If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the applicable interest rates in effect or, if applicable, CPS14101 PSECU FORM 93146 LOANLINER• Credit and Security Credit Agreement (continued) at the default rate disclosed on the Addendum. It a demana for immediate payment has been made, your shares and or deposits can be applied towards what you ov.e as provided in the section above called "Security: We can also exercise any other rights given by law when you are in delault. You agree the Credit Union has the right to take possession of any property given as security under the Plan, without judicial process, if this can be done without breach of the peace. It we ask, you promise to deliver the property at a time and place we choose. If the property is a motor vehicle or boat, you agree that we may obtain a key or other device necessary to unlock and operate it, when you are in default. We will not be responsible for any other property, not covered try 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 for 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 disposition or the date alter which a private disposition writ 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 extend permitted under state law or awarded under the Bankruptcy Code. You must pay any amount that remains unpaid after the sate money has been applied to any unpaid balance under the Plan. 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. The following paragraph applies only to Wisconsin borrowers: When you are in default and after expiration of any right you have under applicable state law to cure your default, we may require immediate payment of your outstanding loan balance under the Plan and seek possession of property given as security. You may voluntarily give the property to us if you choose, or we may seek to take possession of the property by judicial process. lt we repossess the property, you agree to pay reasonable expenses incurred in disposing of the property. If the property is a motor vehicle, mobile home, trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains unpaid after the sale money has been applied to what you owe under the Plan. You agree to pay interest on any unpaid amount at the same rate as the advance, or, if applicable, at the default rate disclosed on the Addendum, until that amount is paid. If the property is located outside Wisconsin at the lime of default, we may take possession of the property without judicial process, if permitted by the state where the property is located. The following paragraph applies only to Louisiana 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. If immediate payment is demanded, you wig continue to pay interest until what you owe has been repaid at the applicable interest rates in effect unless a default rate is disclosed on the Addendumr if a demand for immediate payment has been made, the shares and deposits given as security for the Plan can be applied towards what you owe. We can also exercise any other rights given by law when you are in default and our rights under any security agreements you have with us. CANCELLING OR CHANGING THE PLAN - The following paragraph applies only to borrowwv in tfUrtoia: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change to the interest rate or other charges will apply to future advances. The fiollowing paragraph applies only to borrowers In Wisconsin: We can change the terms of the Plan from time to time in accordance with Section 422.415 of the Wisconsin Statutes. You will be notified of any change in terms. An increase in the daily periodic rate under a variable rate interest rate is not considered a change in terms under the Man. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the credit union cancel the Plan, except to the extent that your liability is limited by Section 422.4155 of the Wisconsin Statutes. The following parsgraph applies only to borrowers In Iowa: We can change the terms of the Plan from lime to time after giving you any advance notice required by law. A change that increases the rate of finance charge or other charge, that increases the amount of your payments, or that otherwise adversely affects existing balances will apply to existing balances only if you agree to the change or you use the Plan after receiving notice that your use of the Plan means you agree the change applies to existing balances. The following paragraph applies to borrowers in aA other states: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change in the interest rate will apply to future advances, and at our discretion and subject to any requirements of applicable law, will also apply to unpaid balances. The following paragraph applies to all but Wisconsin borrowers: An increase in the daily periodic rate under a variable interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. Ybu may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the Credit Union cancel the Plan. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay enforcing any of our rights under this Plan any number of times without losing the ability to exercise our rights later. We can enforce this Plan against your heirs or legal representatives. If we change the terms of the Ran, you agree that this Plan w111 continue to protect us. f CONTINUED EFFECTIVENESS - 11 any part of this Plan is determined by a court to be unenforceable. the rest will remain in effect. NOTICE TO UTAH BORROWERS - This written agreement is a final expression of the agreement between you and the Credit Union. This written agreement may not be contradicted by evidence of any oral agreement. The following is required by Vermont law - NOTICE TO CO-SIGNER - YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. The following paragraphs apply If you give security In connection with an advance under the Plan.They apply to borrowers In all states except Louisiana. Louisiana borrowers will execute a separate security agreement. Borrowers In other states may also be asked to execute a separate security agreement. THE SECURITY FOR THE PLAN - You give us what is known as a security interest in all property described in any receipt, voucher or other document you receive for an advance ("the Advance'). 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 refinancing of the Advance. It also includes any money you receive from selling the property or from insurance you have on the property. It the value of the property declines, you promise to give us more property as security if asked to do so. WHATTHE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS -The security interest secures the Advance described in the receipt, voucher or any other document you receive at the time of the Advance and any extensions, renewals or refinancings of the Advance. h 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. OWNERSHIP OF THE PROPERTY - You promise that you own all 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 sat! 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. 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 insuranc:ii! 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 bans for the purpose of determining whether you and other borrowers have complied with dna insurance requirements of our loan agreements or may engage others to do so. The insurance charge added to an 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, lees or insurance to the unpaid balance of an advance, we may increase your payments to pay the amount added within the term of the insurance or approximate term of the advance. INSURANCE NOTICE - It 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 premium for this insurance may be higher because the insurance company may have given us the right to purchase insurance after uninsured collateral is lost or damaged. The insurance will not be liability Insurance and will not satisfy any state financial responsiblfily or no fault laws. PROTECTING THE SECURITY INTEREST - it 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 i 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 tees, we incur in protecting our security interest and rights in the property. to the extent permitted by applicable law. LOANLiNER• Credit and Securify Credit Agreement (continued) USE OF PROPERTY - Until Ire Advance has been paid off, you promise you wJl: ;1) Use the property carefully and keep a in good repair. (2) Obtain our written permission before making ma;or changes to the property or changing the address where the property is kept (3) Inform us in writing before changing your address i41 Allow us to inspect the property (5) Promptly notfy us if the property is damaged. stolen orabusea. (6) Not use the property for any unlawful purpose (7i Not to ref tie property in another state without telling us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE -- THE MOTOR VEHICLE IN THIS TRANSACTION 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. NOTICE FOR ARIZONA 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 This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. You are advised to read your monthly statement and review it for any error discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT. It you think your statement is wrong, or if you need more information about a transaction on your statement; write us on a separate sheet at the address listed on your statement. You are required to notify us in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transactions on your account. Failure to notify us may result in your acceptance of any responsibility for payment or reimbursement to us for any such error or discrepancy on your account. Write to us as soon as possible. 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. If you have authorized us to pay a credit card account automatically from your share account 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 business days before the automatic payment Is scheduled to occur. YOUR RIt3F' M AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE . We must acknowledge your latter within 30 days, unless we have corrected the error by than. Within 90 days, we must either correct the error or explain why we believe the statement was correct. In this Agreement, the words you and your means each and all of those who apply for the card or who signs this Agreement. Card means the Visa Credit Card and any duplicates and renewals we issue. Account means your Visa Credit Card Line of Credit account with us. We, us, and ours means this Credit Union. I. RESPClA SMUTTY-p agree to repay 90 debts and-the- Finance Charge arising from the use of the card and the card account. For example, you are responsible for charges made by yourself, your spouse and minor children. You are also responsible for charges made by anyone else to whom you give the card, and this responsibility continues until the card is recovered. You cannot disclaim responsibility by notifying us, but we will dose the account for new transactions if you so request and return all cards. Your obligation to pay the account balance continues even though an agreement, divorce decree or other court judgment to which we are not a party may direct you or one of the other persons responsible to pay the account. The cards remain our property and you must recover and surrender to us all cards upon our request and upon termination of this Agreement. 2. LOST CARD NOTIFICATION - If you believe the card has been lost or stolen, you will immediately call the Credit Union at (717) 234-6484 or (800) 237.7328. After hours call (800) 558-5678. 3. LIABILITY FOR UNAUTHORIZED USE - You agree to notify us immediately, orally or in writing of the loss, theft or unauthorized use of your Credit Card. You may be liable for lire unauthorized use of your Credit Card. You will not be liable for unauthorized use that occurs alter you nobly us of the loss, theft or possible unauthorized use. You will have no liability for unauthorized purchases made with your Crack Card, unless you are grossly negligent in the handling of your Card. In any case. your liability will not exceed $50. 4. CREDIT LINE - If we approve your application, we will establish a self- replenishing tine of Credit for you and notify you of its amount when we issue the card. You agree not to bet the ac ;aunt balance exceed this approved Credit Line. Each payment you make on the account will restore your Credit Line by the amount of the payment which is applied to the principal. You may request an increase in your Credit penalty for unlawful fa,lure to return a motor vehicle is one year in prison and: or a fine of $150,000. For those members who purchase a vehicle under the DRIVe Program, please review the following FTC Notice- 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 WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. 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 questioned amount. In either case, we will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within ten days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your statement. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. It 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, it not within your home state, 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 it we mailed you the advertisement for the property or services. Una only by written applicabon to us, which must be approved by our credit committee or ban officer. By giving you written notice we may reduce your Credit line from time to time, or with good cause, revoke your card and terminate this Agreemant. Good cause includes your failure to comply with this Agreement or any other agreement with uA_%QttL.adyw, 6 meeyWofilm-41.your.rrediturorthiness.Youmatf.slso tarntinate.this Agreement at any time, but termination by either of us does not affect your obligation to pay the account balance. 5. 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. 6. MONTHLY PAYMENT - We will marl you a statement every month showing your Previous Balances of purchases and cash advances, the current transactions on your account the remaining credit available under your Credit Una, the New Balances of purchases and cash advances, the Total New Balance, the Finance Charge due to date, and any other billed tees, and the Minimum Payment required. Every month you must pay at least the Minimum Payment within 25 days of your statement dosing data. By separate agreement you may authorize us to charge the minimum payment auiamatically to your share or dhacking account wish us. You may, of course, pay more frequar , pay more than the Minimum Payment, or pay the Total New Balance in full, and you wig reduce the finance charge by doing so. If your monthly payment exceeds the total credit fine balance owed, we will automatically post the credit to your St shares. The mitumum payment will be (a) 2% of your Total New Balance, founded up to the next even dollar, or (b) $20.00, whichever is greater. In addition, at any time your Total New Balance exceeds your Credit Line, you must immediately pay the excess upon our demand. We will apply payments in the following manner: first to previous fate fees, than to previous cash advances finance charges, then to previous purchase finance charges. then to current late lees, then to previous cash advance balances. then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, ano then to current purchase balances. Visa' Credit Card Agreement and Truth In Lending Disclosure (continued) 7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by paying the full amount of the New Balance of Purchases each month within 25 days of your statement closing date. Otherwise, the New Balance of Purchases, and the subsequent purchases from the date :hey are posted to your account, will be subject to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average adjusted daily balance (see explanation below), including new purchases, for the billing cycle by the monthty periodic purchase rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum Cash Advances: We calculate your finance charge on cash advances by multiplying the average adjusted daily balance (see explanation below) for cash advances during the billing cycle by the monthly periodic advance rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method I Average Daily Balance for Purchases - The Average Daily Balance for Purchase i Transactions is calculated by adding the Dairy Balances (Purchase Transaction) tar each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account. we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day in the billing cycle. This gives us the Daily Balance for purchases. Average Dally SalanCe for Cash Ad+ences - Cash Advance Transactions which are posted to your account are not witcluded in the Average Daily Balance calculation for purchases, and are therefore not subject to the monthly periodic rate for purchases. The Average Daily Balance is calculated separately for Cash Advances and is subject to the j Cash Advance Monthly Periodic Rate.The Average Dally Balance for Cash Transactions is calculated by adding the Deily Balances (Cash Transaction) Ibr each day in the t» Vq cycle, and than dIvK ing by the BYnber of days in the billing cycle. To calculate the Daily Balance for cash each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the days Than, In the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your aoocwnt that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Purchase Transactions that posted to your account on that day or in any previous day in the billing cycle. This gives us the Daily Balance tot Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account Paymer n are applied In the following manner: first to previous late fees, then to previous cash advances finance charges, then to previous purchase finance charges, then to current late tees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. Credits are applied first to the particular type of debt which is being credited, if any, and than to the balance of your account Note also that If the toted of the payments and credits which are posted to your account by the Payment Due Date shown on a statement is equal to or exceeds the New Balance shown on that statement, we will not apply, the Monthly Periodic Rate to your Account on your next statement. S. DEFAULT --You will be in default it you fail to make any Minimum Payment within 25 days attar your monthly, statement closing dale. You authorize us to transfer funds sufficient to make the minimum payment due it your Visa loan is in default. You will also be in default 9 your ability to repay us is materially reduced by a change in your employment, an increase in your obligations, bankruptcy or insolvency proceedings involving you, your death or your failure to abide by this Agreement, or if the value of our security interest materially dedines. We have the right to demand immediate payment of your full account balance N you default, subject to our giving you any notice required by law. To the extent permitted by law, you will also be required to pay our collection expenses, including court costs and reasonable attorney fees. 9. USING THE CARD -- To snake a purchase or cash advance, there are two alternative procedures to be followed. One is for you to present the card to a participating Visa plan merchant, or another financial institution, and sign the sales or cash advance draft which win be imprinted with your card. The other is to complete the transaction by using your Personal Identification Number (PIN) in conjunction t with the card in an Automated Teller Machine or other type of electronic terminal that provides access to the Visa system. You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. The monthly statement will identity the merchant, electronic terminal or financial institution at which transactions were made, but sale, cash advance, credit or other slips cannot be returned with the statement. You will retain a copy of such slips furnished at the time of the transaction in order to verity the monthly statement. The Credit Union may make a reasonable charge for photocopies of slips you may request. 10. OVERDRAFT OPTION - If you elect to overdraft to your PSECU Visa Credit Card, that election is subject to the existing credit limit and the agreement it represents and the current loan policy at the time of the overdraft. You also understand that an overdraft will be considered the same as a cash advance on your PSECU Visa Credit Card and that the current Annual Percentage Rate for cash advances will apply. i 11. RETURNS AND ADJUSTMENTS - Merchants and others who honor the card may give credit for returns and adjustments, and they will do so by sending us a credit slip which we will post to your Visa line of credit. Il your credit and payments exceed what you owe us, we will automatically post the excess credit balance to your S1 Shares within 75 days. If the balance is one dollar or more, upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS - The exchange rate between the transaction currency and the billing currency used for processing international transactions is 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 a government-mandated rate in effect for the applicable central processing date. in each instance, an adjustment may be assessed based on the ISA fee imposed by Visa. This fee, which totals 11% of the transaction amount, will be assessed on all transactions where the merchant country differs from the country of the card issuer. 13. SPECIAL RULES FOR VISA PURCHASES - If you disagree or find an error with a Visa transaction, and have tried in good faith to correct the problem with the merchant or the charges are the result of unauthorized or fraudulent use, or your purchase cost more than $50 and was made from a plan merchant in your stale within 100 miles of your home, contact PSECU. 14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing within 60 days hollowing the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transaction on your account Telephoning PSECU does not preseAh{e your dispute rights. You may be required to provide us with documentation to support your dispute claims. In addition, you may be required to complete a standard dispute form outlining the details of your dispute. in cases of fraudulent card use. PSECU will also require a notarized affidavit. In some cases we may ask you to notify the local authorities. If we do not receive the proper requested documentation in the time specified you may be held responsible for the transaction(s) In question, PSECU must adhere to strict dispute timetrames set forth by Visa. 15. SECURITY INTEREST - To secure your account, you grant us a purchase money security interest under the Uniform Commercial Code in any goods you purchase through the account. 11 you defauft, we will have the right to recover any of these goods which we have not been paid for through our application of your payments in the manner described in the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have if you are in default to prevent withdrawal of your unpledged credit union shares (Deposits) below the unpaid balance of your account. However, if you give or have given us a specific pledge of your credit union shares (Deposits) by signing the Pledge of Shares or otherwise, or any other security interests for all yow debts, your account will be secured by your pledged shares (Deposits) and by the property described in those other security agret ments, except for your home. 16. EFFECT OF AGREETAENT - This Agreement is the contract which applies to all transactions on your account even though the sales, cash advance, credit or other slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance written notice required law. Your use of the card thereafter will indicate your agreement to the amendments. To the extent the law permits, and we indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. 17. LATE PAYMENT CHARGE - If your Minimum Payment is not received by the first day of the month following your due date, you will be subject to a SM charge. I& RUSH FEES -You may incur additional charges for rush processing and rush delivery of cards and/or PIN mailer. 19. OVER LIMIT FEE -A $20 fee will be applied for each mantiry statement dosing date on which the outstanding balance exceeds the assigned credit limit by more than $100. 20. DRAFT COPIES - You may incur an additional charge for transaction summary/sale draft documentation. 21. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement. 22. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. 23. NO USE - Inactive Visa accounts that have no purchase or cash activity may be closed without notice to you attar IS months of no activity. 24. 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O NhN 1n V)V"r'7V YM(?Mf7M C')MMMMN (VNN fVNN O OOOOcO 000000 000000 000000 000000 N C ,L --NMQN?O -co p.O^N MV V)`O (?W PO^N(`)i C4tl^WPO (y ^^--^--? ?N(VNNN NNNNNN F O d ate„ © ? -c?s • SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-03615 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS VELEZ IVELISSE R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: VELEZ IVELISSE but was unable to locate Her deputized the sheriff of YORK serve the within COMPLAINT & NOTICE County, Pennsylvania, to On July 29th , 2008 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep York County 65.80 Postage .83 103.63 ? 07/29/2008 VAN ECK & VAN ECK Sworn and subscribe to before me this day of in his bailiwick. He therefore So answer R. Thoma I-ne Sheriff of Cumberland County A. D. 11'-??V/ COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE "STRUCTIOtr1S PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE OI&Y LM 1 THM 12 DO NOT DETACH ANY COMS 1 INTIFF/S/ 2 COURT NUMBER 08_3615 civil P 1'4 4 TYPE OF WRIT OR COMPLAINT' 3. DEFEN NTIS/ CI C ' N? C SERVE 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED. AT-(ACHED, OR SOLD -r-l) t\% .55 U62 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO, CITY, BORO, TWP • STATE AND ZIP CO E) AT l yCl MlaA" /U t" PA 17076 7. INDICATE SERVICE $FDRSONAL RSON IN CHARGE U DE UTIZE ' CE T IL U 1ST CLAS MAIL U POSTED U OTHER NOW June 24 20 08 I, SHERIFF OF COUNTY, PA, do hereby deputize the sheriff of York COUNTY to execute this Writ a return th cording to law. This deputization being made at the request and risk of the plaintiff., '°°-k SHERIFF OF OUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE U T 0 F C O C(Anber. Please mail return of service to Ctanberland County Sheriff. Thank you. ADV FEE PAID BY ATTY. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment. without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. PE NAME ADDRESS of TTORNEY /ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11 DATE FILED 2 elael ?/ to/r??ia,ry-; r b t2? 6-17-2008 12. SEND NOTICE OF SERVICE COPY TO NAME AN(VbDRESS BELOW: (This area must be completed if notice is to be maded) I ? ,,4UMBERLAND CO HERIFF SPACE BELOW FOR USE OF THE SHE10 h' = 00 NOT WRRE E01LOW TM LW 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date or compiaint as indicated above. M J M C G I L L Y C S O 16-25-2008 17-17-2008 16. HOW SERVED PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. 1 hereby certity and return a NOT FOUND because I am unable to locate the individual, oompany, etc named above. (See remarks below.) 18. NAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 1 19 Date of Service 120 Time of Service 21. ATTEMPTS' Dn W ,? I Miles I Ini ' D 71* to Time MQ I Int I Date I Time I Miles I Int. Date I Time I Miles Int. I Date I Time I Miles I Inl I Dale I Time Miles InL 22 REMARKS: PER MRS. MEDINA WHO STATED DEF MOVED ABOUT 1 MO. AGO. DID A PO CHECK. PER POST OFFICE CHECK , NEW ADDRESS IS 1523 BERRY HILL ST., HARRISBURG, PA17101 23 Advance Costs 24 'service Costs 125.00 25 N/F 26 Mileage 27 Postage 28 Sub Total 29. Pound 30 Notary Sol 3t. Surchg. 32 Tot. Costs 33-6. 99tie Refund Check No 5?:) 2-9 34. Foreign County Costs " 35 Advance Costs 36 Service Costs 37 Notary Cen 38. Mdeage/Postage/Not Found 39 Total Costs 40 Costs Due or Refund 41. AFFIRMED andAubschbied tto, bef a me 42 day of ?lN'` eT 1 sr L 1 ? ? _iC SO ANSWERS 44. Signature of 45 DATE p. Sheriff 46. Signature of York _ 47 TE RTCHARD County Sheriff 48 Signature of Foreign ac narc IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. IVELISSE VELEZ Defendant NO. 2008-03615 CIVIL ACTION -LAW PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint with regard to the above defendant in the above captioned matter. Respectfully submitted, VAN ECK & VAN ECK, P.C. Date: %`` D `u D Melissa L. Van Eck, squire Attorney ID No.: 85869 7810 Allentown Blvd., Suite B. P.O. Box 6662 Harrisburg, PA 17112 (717)540-5406 0 0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES NO. (fig 3(015 CREDIT UNION, Plaintiff VS. IVELISSE VELEZ Defendant 0--iu, t Te-rm : CIVIL ACTION -LAW NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 cn N - i9i M exs w 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 the 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 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. 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CAN NOT 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Document #: 180057.1 0 • EN LA CORTE DE ALEGATOS COM UN DEL CONDADO DE CUMBERLAND, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES NO. CREDIT UNION, Plaintiff VS. IVELISSE VELEZ Defendant : CIVIL ACTION -LAW AV I S O PARA DEFENDER Conforme a PA Niue. 1018.1 USTED HA SIDO DEMANDO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defenses o objeciones a las demandas puestas en contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Ustedpuede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Document #. 180057.1 • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. IVELISSE VELEZ Defendant NO. CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Van Eck & Van Eck, P.C. and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Ivelisse Velez, is an adult individual with a last known address of 144 Meadow Brook Court, New Cumberland, PA 17070. 3. Defendant is, and at all relevant times material hereto has been, the primary loan applicant. 5. Defendant applied to Plaintiff for a loan for the purpose of purchasing a motor vehicle. 6. The loan application submitted by Defendant was approved by Plaintiff and Defendant signed a Loanliner Advance Proceeds Check for the purchase of the vehicle. A true and correct copy of said Loanliner Advance Proceeds Check is attached hereto, incorporated herein and marked as Exhibit "A". Document #.• 180057.1 1 0 0 7. Pursuant to the Loanliner Advance Proceeds Check marked as Exhibit "A", Defendant agreed to the terms and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (hereinafter referred to as "Contract"). A true and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 8. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms and conditions of the Contract marked as Exhibit "B". 9. Various charges and payments were made by Defendant on the account. 10. Plaintiff provided a letter to Defendant stating that the vehicle purchased by Defendant was deemed repossessed. The letter further advises Defendant that unless payment in full was made on the outstanding loan balance, the said vehicle would be sold at a public sale and Defendant will be responsible for any resulting deficiency. 11. As a result of Defendant's failure to cure the default in payment, and pursuant to state law remedies, Plaintiff sold the vehicle at public sale. 12. Plaintiff provided a letter to Defendant indicating that there was a resulting deficiency after the sale of the vehicle. 13. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 14. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 15. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. Document #: 180057.1 0 0 16. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. 17. As of June 13, 2008, the balance due, owing and unpaid on Defendant's loan account with Plaintiff is the sum of Eleven Thousand Six Hundred Thirty-Nine Dollars and 58/100 ($11,639.58). 18. Pursuant to the terms and conditions of the extension of credit contained in the Contract, Plaintiff is entitled to receive and Defendant agreed to pay an annual interest charge on the principal loan balance. 19. Due to the default of the Defendant and pursuant to the terms and conditions of the Contract attached as Exhibit "B", attorney's fees in the total amount of Two Thousand Three Hundred Fifty-Two Dollars and 92/100 ($2,352.92) have been added to the account. 20. Any and all conditions precedent to the bringing of this action has been performed by Plaintiff. 21. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. Document #: 180057.1 • • WHEREFORE, Plaintiff, Pennsylvania State Employees Credit -Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Ivelisse Velez, in the amount of Thirteen Thousand Nine Hundred Ninety-Two Dollars and 50/100 ($13,992.50), plus interest, the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, VAN ECK & VAN ECK, P.C. By: Melissa L. Van Eck, Esquire Attorney I.D. No. 85869 P.O. Box 6662 Harrisburg, PA 17112 717.540.5406 Document #: 180057.1 • • VERIFICATION I, Gregory R. Diffenderfer, Manager of the Pennsylvania State Employees Credit Union verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Pennsylvania State Employees Credit Union By: ??n! D Title: Date: 6-1V0% EXHIBIT "A„ I t t i ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT j0* ?+I e.,41 ?b 5q v5? Pennsylvania State Employees Credit Union R O. Box 67013 Harrisburg. PA 17106-7013 717.234.8484 800.237.7328 MWSERNAME •.l>!A??:.:• ' . --..?NFi1 B ?I .??Ft.:" ;".= •' =?QTEryyrw : : ?.ri.Y J •»: ?S? ?'; IVELISSE VELEZ? . 8/30/200 , . , 8846850801/L10 r „ . - ` ,l; 0005615460 2205 CEDAR RUN DRIVE APT H EX T PURPOSE: CAMP HILL, PA 17011 Dealer Purchase TRA SA TION 1. [:] NEW LOAN Y ? -END LOOPEN AN ADVANCE 3 ? OESCAIBE HOME . ( ) 4. EQUITY ADVANCE SECURITY OFFERED I?NAB? 18 0.EQUITY AdiMNCE, THE OAM YSECURniY FORTHIB ADVANCE IS THE REAL PROPERLY pN MOST CASESYOUA WWM WHICHYOU GAVE AS SECURITY WHEN YOUR ACCOUNT IFTHIS IS IOTA HOME EQUITY ADVANCE. W ADDITION TO THE PLEDGE OF BFIAFES W YOUR LOANLWEFP CREDIT AGREEMENT, THE FOLLOWING PROPERTY SECURES THIS ADVANCE. REM PROPERTY EAy+?., i'tyE1(TC% :.•; :ai ° =LFL` +. n : .•r r } .: t: .;YPE'•": w_: .?:.. -c:. /ILiIE•.?°; 1• HONDA Z CCORD 2003 1HGCM56623A120196 SDN 19,505.00 a 4.OTHER YOU PLEDGE SHARES ANDIOR DEPOSITS OF $ IN ACCOUNT NUMBER OLDACCOUNTNAANNUMBER PAYOFF (PRIM +INC OLDACCOUNTADANNUMBER, PAYOFF RWC+INI OLOACOOLINTILOANNUMBER PAYOFF (PRINO. + wn OLD ACCOUNTILOAN NUMBER RIYOFF AING+ INT OLD ACCOUNTA.QAN NUMBER PAYOFF (PRINC.+ INT. OLD ACCOUNTA.OAN NUMBER PAYOFF PRINC. + INT.) By accepting the proceeds or by using the funds advanced and deposited Into your shere/share draft account, you agree (1) that the properly referenced above Will secure the advance and any other advances you have now or receive In the future under the LOANLINER' Credit and security Agreement (the Plan) and any other amounts you owe us for any reason now or In the future In accordance With the terms of the Plan and (2) to make payments as disclosed above In acoordance with the terms of the Plan. ecumAMumaw.ismit.0E.atm. tB.Bq=%o1,04,skALLPuawrasmet o PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM 03175 A-AX0/00.1 097.2002.1 (aMe) SECURITY AGREEMENT In this agreement all references to Credit Union, we, our, or us means Pennsylvania State Employees Credit Union and anyone to whom the Credit Union assigns the Credit Agreement which will be referred to as the Plan. 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. 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 LOAN - 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 the reverse side. The securely 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 or if this 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 following paragraph applies only when the bax on reverse side is checked. 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 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 3roperty is lost or damaged, we can use the insurance settlement to repair the xoperty or apply it towards what you owe. You authorize us to endorse any draft or :heck which may be payable to you in order for us to collect any refund or benefits fue 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. B. 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 4 anyone is in default who has signed the Plan. 111. WHAT HAPPENS IF YOU ARE IN DEFAULT - The following paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: When you are in default and after expiration of any right you have under applicable state law to cure your default, we can require immediate payment of your outstanding balance under the Plan without giving you advance notice. The following paragraph applies to borrowers in all other states: When you are in default, we can require immediate payment (acceleration) of what you owe under the Plan and take possession of the property. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. The following paragraphs apply to all borrowers: You agree the Credit Union has the right to take possession of the property 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 until that amount has been paid. 11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT - 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 MOTOR VEHICLE IN THIS TRANSACTION 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 ARIZONA 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 $150,000. • 0 Pennsylvania State Em'p'loyees Credit Union No. 5615-160 . --_- -.u .,cew_?.?x nl;:::7 (::'i 7it3+51 a(a!']a.lYB AUTOJRl<FT VOID OV:R S' 19,6 Siy00;? - R_: EREUCE` SS-16350S01 C-3 120 DAYS A'E.a OS!24/1006 . PAY i0 Till- _Ir- (X'' ' •'.G'..,; ORDER CF IDEA[ ? 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ZI 19 g » q y 9?sR ?S?O: JJ^..'1..?'..?'•.G. ?G? r?l ?. ?S2a?. ig°Zg3e i?p ag Y77?my =j dF f m SiA r? g?,l?r°m =q'+p ?$AtD 3 IL w ;.c c? D xo.ml a C Sa,??<O !?iI yp a9D'mp TESJ2; 1 m P!?$ f No of 'T u ;?° 1 03 rn 1 .1illif 11 - IL g { 3 e m n F1191 W9 (0313011 cn a: t el 1 ° (0.29.06 !51•°JS7179. i J[y?.} p-g5? YX °o z cm W. M m i n •a' • • EXHIBIT "B" • • Pennsylvania State Employees Credit Union P.O. Box 67013 I Harrisburg, PA 17106-7013 • (717) 234-8484 Harrisburg, (800) 237.7338 Nationwide PSECO the rinancial link, Loan Disclosures This LOANLINER' Credit and Security Agreement, which includes the Truth in Lending Disclosures, will be referred to as the Plan. The Plan documents include this agreement and an Addendum. You, your and borrower mean any person who signs the Plan. Credit union, we, our and us mean PSECU or anyone to whom the Credit Union transfers its rights under the Plan. HOW THIS PLAN WORKS - This is an open-end, multi-featured credit plan. We anticipate that, from time to time, you will borrow money (called 'advances' under the Plan We are not required to make advances to you under the Plan and can refuse s request for an advance at any time. The Addendum describes the different types of credit (called'subaccounts') available under the Plan, the current Interest rate for each subaccount expressed as a daily periodic rate and corresponding annual percentage rate and other charges. It may also have other terms and a schedule for determining the payment amounts. CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain subaocounis. If a credit limit is set for a subaccount, you promise not to exceed the established credit IimiL If you exceed the credit limit. you promise to repay immediately the amount which exceeds the credit limit. REPAYMENT You promise-to repay all amounts you owe under the Plan plus interest. Payments are due on the last day of the month unless we set a different day at the time of an advance. If the Addendum has no payment schedule for a subaccount, your payment will be determined at the time of each advance Payments must include any amount past due and any amount by which you have exceeded any credit limit you have been given for a subaccount. You may repay all or part of what you owe at any time without any prepayment penalty. Even if you prepay, you win still be required to make the regularly scheduled payments unless we agree in writing to a change in the payment schedule. If you have a joint sharedraft account, you will be responsible for paying all overdraft advances obtained by a joint holder of the sharedraft account Unless otherwise required by law, payments will be applied to amounts owed under the Plan, in the manner the Credit Union chooses. PLAN ACCESS -Ybu can obtain credit advances In any manner authorized by us. If we allow you to use yous ATM/Debit card to access the Plan, you may be liable for the unauthorized use of your ATM/Debit card. You will not be liable for unauthorized use that occurs after you notify us. orally or in writing, of the loss, theft, or possible unauthorized use. H you believe your ATM/Debit card has been lost or stolen, immediately inform the Credit Union by calling or writing us at the telephone number or address tft$t appears elsewhere In the Plan. If the card is used to obtain unauthorized advances directly, from the Plan, your liability will not exceed $50. If the unauthorized withdrawal is from a shtaredraft account, your liability is governed by the Regulation E disclosures you received at the time you received your ATM/Debit card, even if the wiNudrawal results In an advance being made from your overdraft subaccount. FINANCE CHARGE -- The dollar amount you pay for money borrowed is called a 'finance charge and begins on the date of each advance. A finance charge will be computed separately lot each separate balance under the Plan. To compute the finance charge, the unpaid balance lor each day since your last payment (or since an advance If you have not yet made a payment) Is multiplied by the applicable daily periodic rate. The suit of these amounts is the finance charge owed. The balance used to compute the finance charge is the unpaid balance each day after payments -and-credits beers subtracted and any additions to the balance, have been made. In addition to interest, we may charge other finance charges which are disclosed on the Addendum. It the interest rate is a variable interest rate, the Addendum explains how the variable interest rate works. SECURITY -You pledge as security for the Plan all shares and dividends and, if any, an deposits and interest in all joint and individual accounts you have with us now and in the future. If a specific dollar amount is pledged for an advance, we will freeze shares in that account to the extent of the outstanding balance for the advance. Otherwise, your pledged shares may be withdrawn unless you are in default. The following paragraph applies in all states except in Ohio, Rhode Island and Massachusetts: We have a statutory lien on the shares and dividends and, d any. the deposits and interest in all individual and joint accounts you have with us and may exercise our rights under the lien to the extent permitted by state law. (We are state chartered if our name does not include the term 'Federal Credit Union.) For all borrowers: The statutory lien and/or your pledge will allow us to apply the funds In your account(s) to what you owe when you are in default. The statutory lien and your pledge do not apply to any Individual Retirement Account or any other account that would lose special tax treatment under state or federal law if given as security. Additional security for the Plan may be required at the time of an advance. If a subaccount identifies a type of property (such as 'New Cars) you must give that type of property as security when you get an advance under that subaccount. A subaccount name such as "Other Secured' means you must provide security acceptable to us when you obtain an advance under that subaccount. Property you give as security will secure all amounts owed under the Plan and all other loans you have with us now or in the future, except any ban secured by your principal dwelling. Property securing other loans you have with us may also secure the Plan- 0'VkA MUTUAL GRel P 190 2006. ALL M514TS RESERVED EM CREDIT INSURANCE - Credit life and/or credit disability insurance is optional under the Plan. If you quality for and purchase the insurance from us, you authorize us to add the insurance premiums monthly to your ban balance and charge you interest on the entire balance. If you elect credit insurance, your payments may increase or the period of time necessary to repay your advance may be extended. The credit insurance rates may change during the Plan. If the rates change, we will provide any notices required by applicable law. PERIODIC STATEMENT - On a regular basis you will receive a statement showing all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each joint borrower, notice to any one of you will be notice to all. JOINT ACCOUNTS - if this is a joint account, each of you is individually, and jointly responsible for paying all amounts owed. That means we cari enforce our rights under the Plan against any one of you individually or against an of you together. If you give us inconsistent instructions, we can refuse to follow your instructions. Unless our written policy requires all of you to sign for an advance, each of you authorizes the other(s) to obtain advances individually and agmAB to repay advances made to the- other(s). Any joint accountholder may terminate the Plan by giving us prior written notice. II any of you terminate the Plan, the Plan is terminated for all of you. You remain liable individually and jointly for all advances incurred before termination. FEES AND CHARGES - If you give us a security interest in certain types of property, we may charge you a filing fee to perfect out *interest in the property. If we do, the amount of the fee will be disclosed to you at the time you obtain an advance. We may also charge you other fees in connection with the Plan. Our current fees are disclosed on the Addendum and will be added to your loan balance unless you pay them in cash. UPDATING CREDIT INFORMATION -You promise that you will promptly give us written notice If you move, change your name or employment, or if any other information you provided to us changes. Upon our request, you also agree to provide us updated financial information. DEFAULT - The following paragraph applies to borrowers In Idaho, Kansas, Maine and South Carolina: You will be in default U you do not make a payment of the amount required when it is due. You will also be in default lt we believe the prospect of payment, performance, or realization on any property given as security is significantly impaired. The following paragraph applies only to borrowers in Wisconsin: You will be in default it you fail to make a payment when due two times during any 12 month period. You will be in default it breaking any promise made under the Plan materially impairs your ability to repay what you owe or materially impairs the condition, value, or protection of or our righ..in any property you gave as security. The following paragraph applies only to borrowers In Iowa: You will be in default if you are more than 10 days late in malting a payment. You will also be in default if you do not comply with the terms of the Plan end your failure to comply materially Impairs any property you gave as security or your ability to repay what you we under the Plan. The_Iollowin9 paragraph.eppilyts to borrowers In all other states: You.win be in default if you do not make a payment of the amount required when it is due. You win be in default if you break any promise you made under the Plan or If anyone is in default under arty security agreement made In connection with an advance under the Plan. You will be in default if you die, file for bankruptcy, become Insolvent, it you make any false or misleading statements in any credit application or update of credit information, or if something happens we believe may substantially reduce your ability to repay what you owe. You will be in default it any property you have given us as security is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value of the property or our security interest in it. You will also be in default under the Plan it you are in default under any other ban agreement with us. ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers In Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: 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 following paragraph applies to borrowers In all other states except Wisconsin and Louisiana: 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. The following paragraphs apply to borrowers in all states except Wisconsin and Louisiana: If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the applicable interest rates in effect or, if applicable, CPS4101 PSECU FORM 03146 C] LOANLINER' Credit and Security Credit Agreement (continued) at the default rate disclosed on the Addendum. If a demand for .mmediate payment i has been made, your shares and or deposits can be applied towards what you cae as provided in the section above called "Security' Wa can also exercise any other rights given by law when you are in default. You agree the Credit Union has the right to take possession of any property given as security under the Plan, without judicial process. if this can be done without breach of the peace. It we ask, you promise to deliver the property at a time and place we choose. It the property is a motor vehicle or boat, you agree that we may obtain a key or other device necessary to unlock and operate it, when you are in default. We will not be responsible for any olher property. not covered by this Agreement, that you leave inside the propeny or that is attached to the property. We will try to return that property to you or make it available for 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 disposition or the date after which a private disposition will be held. Our expenses for taking possession of and selling the property will be deducted from the money reserved 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. You must pay any amount that remains unpaid after the sale money has been applied to any unpaid balance under the Plan. You agree to pay interest on that amount at the same rate as the advance, or, it applicable, at the default rate disclosed on the Addendum, until that amount has been paid. The following paragraph applies only to Wisconsin borrowers: When you are in default and after expiration of any right you have under applicable state law to cure your default, we may rekrire immediate payment of your outstanding loan balance under the Plan and seek possession of property given as security. You may voluntarily give the property to us it you choose, or we may seek to take possession of the prop" by judicial process. N we repossess the property, you agree to pay reasonable expenses incurred in disposing of the property. If the property is a motor vehicle, mobile frame, trailer. snowmobile, boat or aircraft, you will also be required to pay any costs permitted by Section 422.413 of the Wisconsin Staines. You must pay any amount that remains unpaid after the sale money has been applied to what you owe under the Plan. You agree to pay interest on any unpaid amount at the same rate as the advance, or, if applicable, at the default rate disclosed on the Addendum, until that amount is paid. If the property is located outside Wisconsin at the time of default, we may take possession of the property without judicial process, it permitted by the state where the property is located. The following paragraph applies only to Louisiana borrowers: When you are in default, we can require immediate payment (acceleration) of the entire unpaid valance under the Plan.Ybu waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. It Immediate payment is demanded, you will continue to pay Interest until what you owe has been repaid at the applicable interest rates In effect unless a default rate is disclosed on the Addendunw If a demand for immadiate payment has been made, the shares and deposits given as security W the Plan can be applied towards what you owe. We can also exercise any other rights given by law when you are in default and our rights under any security agreements you have with us. CANCELLING OR CHANGING THE PLAN - The loNowing paragraph applies only to borrowers In NlbaW We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change to the interest rate or other charges will apply to future advances. The Hollowing paragraph applies only to borrowers In Wisconsin: We can change the terms of the Plan from time to time in accordance with Section 422.415 of the Wsconsin Statutes. You will be notified of any change in terms. An increase in the daily periodic rate under a variable rate interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the credit union cancel the Plan, except to the extent that your liability is limited by Section 422.4155 of the Wisconsin Statutes. The following paragraph applies only to borrowers in Iowa: We can change the terms of the Plan from time to time after giving you any advance notice required by law. A change that increases the rate of finance charge or other charge, that increases the amount of your payments, or that otherwise adversely affects existing balances will apply to existing balances only if you agree to the change or you use the Plan after receiving notice that your use of the Plan means you agree the change applies to existing balances. The following paragraph applies to borrowers in all other states: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change in the interest rate will apply to future advances, and at our discretion and subject to any requirements of applicable law, will also apply to unpaid balances. The following paragraph applies to aft but Wisconsin borrowers: An increase in the daily periodic rate under a variable interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the Credit Union cancel the Plan. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN -We can delay enforcing any of our rights under this Plan any number of times without losing the is aoility !o exercise our rights later. We can enforce this Plan against your heirs or legal representatives. If we change the t«rms of the Ran, you agree that this Plan will continue to protect us. CONTINUED EFFECTIVENESS - It any part of this Plan is determined by a court to be unenforceable, the rest will remain in effect. NOTICE TO UTAH BORROWERS - This written agreement is a final expression of the agreement between you and the Credit Union. This written agreement may not be contradicted by evidence of any oral agreement. The following is required by Vermont law - NOTICE TO. CO-SIGNER - YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. The following paragraphs apply It you give security In connection with an advance under the PIan.They apply to borrowers In all states except Louisiana. Louisiana borrowers will execute a separate security agreement. Borrowers In other states may also be asked to execute a separate security agreement. THE SECURITY FOR THE PLAN - You give us what is known as a security interest in all property described in any receipt, voucher or other document you receive for an advance ("the Advance'). 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 refinancing 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. WHATTHE SECURITY INTEREST COVERSICROSS COLLATERAL PROVISIONS -The security interest secures the Advance described in the receipt, voucher or any other document you receive at the lime of 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. It 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. OWNERSHIP OF THE PROPERTY - You promise that you awn all property you give as security or if the Advance is to toy 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 Gen to attach to the property either by your actions or by operation of law. 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 prop" 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 it asked to do so. II you cancel your insuranA 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 pike registration lees) due on the property. If you do not pay the taxes or lees on the property when due or keep it iiinsured, we may pay these obligations, but we are not required to do so. Any money we spend br 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 bans for the purpose of determining whether you and other borrowers have complied with the insurance requirements of our ban agreements or may engage others to do so. The Insurance charge added to an 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 an advance, we may increase your payments to pay the amount added within the term of the Insurance or approximate term of the advance. INSURANCE NOTICE - It 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 premium for this insurance may be higher because the insurance company may have given us the right to purchase insurance after uninsured collateral is lost or damaged. The Insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. PROTECTING THE SECURITY INTEREST - It 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 tees. we incur in protecting our security interest and rights in the property, to the extent permitted by applicable law. • LOANLiNER• Credit and Security Credit Agreement (continued) USE OF PROPERTY - Until trio Advance has been pa•d oH, you promise you will: (t) Use the property carefully and keep it in good repair. f2) Obtain our written permission before making ma!or changes to the property or changing the address a.here the property is kept (3) Inform us in writing before charging your address t1) A!Ivs us to inspect the property (5) Promptly noffy us d the property is darna3ed. stofun or abusso. (6) Not use the prcpei!y tot any unlawful purpose (7) Not to retitle property in another state without telling us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION 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. NOTICE FOR ARIZONA 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 This notice contains important information about your rights and our responsibilities under the Fair Credit Bitting Act. You are advised to read your monthly statement and review it for any error discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR OUESTIONS ABOUT YOUR STATEMENT. If you think your statement is wrong. or if you need more information about a transaction on your statement, write us on a separate sheet at the address listed on your statement. You are required to notify us in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transactions on your account. Failure to notify us may result in your acceptance of any responsibility for payment or reimbursement to us for any such error or discrepancy on your account. Write to us as soon as possible. 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. If you have authorized us to pay a credit card account automatically from your share account 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 business days before the automatic payment is scheduled to occur. YOUR RIGWS 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 In this Agreement, the words you and your means each and all of those who apply for the card or who signs this Agreement Card means the Visa Credit Card and any duplicates and renewals we Issue. Account means your Visa Credit Card Line of Credit account with us. We, us, and ours means this Credit Union. f. Rt'aSPONSIBIl?if--tt?ve+sseeyr,kracero-yokregree-lo-repey$ltdebts andtFre Finance Charge arising from the use of the card and the card account. For example, you are responsible for charges made by yourself, your spouse and minor children. You are also responsible for charges made by anyone also to whom you give the card, and this responsibility continues unlit the card is recovered. You cannot disclaim responsibility by notifying us, but we will dose the account for new transactions if you so request and return all cards. Your obligation to pay the account balance continues even though an agreement, divorce decree or other court judgment to which we are not a party may direct you or one of the other persons responsible to pay the account. The cards remain our property and you must recover and surrender to us all cards upon our request and upon termination of this Agreement. 2. LOST CARD NOTIFICATION - If you believe the card has been lost or stolen, you will immediately call the Credit Union at (717) 234-8484 or (800) 237-7328. After hours call (800) 566-5678. 3. LIABILITY FOR UNAUTHORIZED USE -You agree to notify us immediately, orally or in writing of Cte loss, theft or unauthorized use of your Credit Card. You may be liable for the unauthorized use of your Credit Card. Ybu will not be liable for unauthorized use that occurs after you notify us of the loss. theft or possible unauthorized use. You will have no liability for unauthorized purchases made with your Credit Card. unless you are grossly negligent in the handling of your Card. In any case, your liability will not exceed W. 4. CREDIT LINE - It we approve your application, we will establish a self- replenishing Line of Credit for you and notify you of its amount when we issue the card. You agree not to let the account balance exceed this approved Credit Li, e. Each payment you make on the account will restore your Credit Line by the amount of the payment which is applied to the principal. You may request an increase in your Credit .• penalty for unlawful failure to return a motor vehicle is one year in prison and: or a fine of $150,000 For those members who purchase a vehicle under the DRIVe Program, please review the following FTC Notice: NOTE 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 WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. 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 fired 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 questioned amount. In either case, we will send you a statement of the amount you owe and the date that it is due. If 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 tell anyone we report you to that you have a question about your statement. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even it 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 slate, 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 property or services. Line only by written application to us, which must be approved by our credit committee or ban officer. By giving you written notice we may reduce your Credit Line from time to time, or with good cause, revoke your card and terminate this Agreement. Good cause includes your failure to comply with this Agreement or any other agreement with us, a t ;Se reeyzbmfim-ot.YOur.creditworthiness. Younw.also.termkwe.this Agreement at any time, but termination by either of us does not affect your obligation to pay the account balance. 5. 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. 6. MONTHLY PAYMENT - We will mail you a statement every month showing your Previous Balances of purchases and cash advances, the current transactions on your account, the remaining credit available under your Credit Line, the New Balances of purchases and cash advances, the Total New Balance, the Finance Charge due to date, and arty other billed fees, and the ?Animum Payment required. Every month you must pay at least the Minimum Payment within 25 days of your statement closing date. By separate agreement you may authorize us to charge the rninirnum payment aulanaticaly to your share or checking account with us. You may, of course, pay more frequently, pay more than the Minimum Payment, or pay the Total New Balance in full, and you will reduce the finance charge by doing so. If your monthly payment exceeds the total credit One balance owed, we will automatically post the credit to your S1 shares. The minimum payment will be (a) 211. of your Total New Balance, rounded up to the next even dollar, or (b) $20.00, whichever is greater. In addition, at any time your Total New Balance exceeds your Credit Line, you must immediately pay the excess upon our demand. We will apply payments in the following manner: first to previous late fees, than to previous cash advances finance charges, then to previous purchase finance charges. then to current late fees. then to previous cash advance balances, then to previous purchase balances in the order [hat they were posted to your account, then to current cash advance balances, ano then to current purchase balances. • Visa' Credit Card Agreement and Truth In Lending Disclosure (continued) 7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by paying the full amount of the New Balance of Purchases each month within 25 days of your statement closing date. Otherwise, the New Balance of Purchases, and the subsequent purchases from the date they are posted to your account, will be subject to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average adjusted daily balance (see explanation below), including new purchases, for the bitting cycle by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum Cash Advances: We calculate your finance charge on cash advances by multiplying the average adjusted daily balance (see explanation below) for cash advances during the billing cycle by the monthly periodic advance rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Daily Balance for Purchases • The Average Daily Balance for Purchase Transactions is calculated by adding the Daily Balances (Purchase Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day in the billing cycle. This gives us the Daily Balance for purchases. Av&W Daly Balance br Cash Advances • Cash Advance Transactions which are posted to your account are not Included In the Average Daily Balance calculation for purchases. and are therefore not subject to the mouthy periodic rate for purchases. The Average Daily Balance is calculated separately for Cash Advances and is subject to the Cash Advance Monthly Periodic Rate. The Average Daly Balance for Cash Transactions is calculated by adding the Daly Mono" (Cash Transaction) for each day in the billing aide, and than dividing by the number of days in the billing cycle. To caictutale the Daily Balance for cash each day, we felts the blowing steps: We take the outstanding balance (al amounts you owe) at the start of the day. Then, In the sequence in which amauas are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Lath Charges. Then we also subtract the amount of any Purchase Transactions that posted to your account on that day or in any previous day In the billing cycle. This gives us the Daily Balance for Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account. Paymen3 are applied In the following manner: first to previous late fees, then to previous cash advances finance charges, then to previous purchase finance charges, then to current late tees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. Credits are applied first to the particular type of debt which is being credited, if any, and then to the balance of your account. Note also that l the total of the payments and credits which are posted to your account by the Payment Due Date shown on a statement is equal to or exceeds the New Balance shown on that statement, we wig not apply the Monthly Periodic Rate to your Account on your next statement. S. DEFAULT-You will the in default l you fail to make any Minimum Payment within 25 days after your monthty statement closing date. Ybu authorize us to transfer funds sufficient to make the minimum payment due l your Visa loan is in default. You will also be in default it your abBty to repay us is materially reduced by a change in your employment, an increase in your obligations, bankruptcy or insolvency proceedings involving you, your death or your failure to abide by this Agreement, or if the value of our security interest materially dedines. We have the right to demand immediate payment of your full account balance if you default, subject to our giving you any notice required by law. To the extent permitted by law, you will also be required to pay our collection expenses, including court costs and reasonable attorney fees. 9. USING THE CARD - To make a purchase or cash advance, there are two afternative procedures to be followed. One is for you to present the card to a participating Visa plan merchant, or another financial Institution, and sign the sales or cash advance draft which will be imprinted with your card. The other is to complete the transaction by using your Personal Identification Number (PIN) in conjunction with the card in an AulomatedTailor Machine or other type of electronic terminal that provides access to the Visa system. You agree that you will not use your card for any transaction that is illegal under applicable federal, state. or twat law. The monthly statement will identity the merchant, electronic terminal or financial institution at which transactions were made, but sale, cash advance, credit or other slips cannot r1 be returned with the statement. You will retain a copy of such slips furnished at the time of the transaction in order to verity the monthly statement. The Credit Union may make a reasonable charge for photocopies of slips you may request. 10. OVERDRAFT OPTION - If you elect to overdraft to your PSECU Visa Credit Card, that election is subject to the existing credit limit and the agreement it represents and the current loan policy at the time of the overdraft. You also understand that an overdraft will be considered the same as a cash advance on your PSECU Visa Credit Card and that the current Annual Percentage Rate for cash advances will apply. 11. RETURNS AND ADJUSTMENTS -Merchants and others who honor the card may give credit for returns and adjustments, and they will do so by sending us a credit slip which we will post to your Visa line of credit. If your credit and payments exceed what you owe us, we will automatically post the excess credit balance to your S1 Shares within 75 days. If the balance is one dollar or more, upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS - The exchange rate between the transaction currency and the billing currency used for processing international transactions Is 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 a government-mandated rate in effect for the applicable central processing date. In each instance, an adjustment may be assessed based on the ISA tee imposed by Visa. This fee, which totals 11% of the transaction amount, will be assessed on all transactions where the merchant country differs from the country of the card issuer. 13. SPECIAL RULES FOR VISA PURCHASES - It you disagree or find an error with a Visa transaction, and have tried in good faith to correct the problem with the merchant or the charges are the result of unauthorized or fraudulent use, or your purchase cost more then $50 and was made from a plan merchant in your state within 100 miles of your home, contact PSECU. 14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transaction on your account. Telephoning PSECU does not presefye your dispute rights. You may be required to provide us with documentation to support your dispute claims. In addition, you may be required to complete a standard dispute form outlining the details of your dispute. In cases of fraudulent card use. PSECU wig also require a notarized affidavit. In some cases we may ask you to notify the local authorities. If we do not receive the proper requested documentation in the time specified you may be held responsible for the transaction(s) in question. PSECU must adhere to strict dispute timeframes set forth by Visa. 15. SECURITY INTEREST - To secure your account, you grant us a purchase money security interest under the Uniform Commercial Code In any goods you purchase through the account. If you default, we will have the right to recover any of these goods which we have not been paid for through our application of your payments in the manner described in the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have it you are in default to prevent withdrawal of your unpledged credit union shares (Deposits) below the unpaid balance of your account. However, if you give or have given us a specific pledge of your credit union shares (Deposits) by signing the Pledge of Shares or otherwise, or any other security interests for all your debts, your account wig be secured by your pledged shares (Deposits) and by the property described in those other security agret ments, except for your home. 16. EFFECT OF AGREMENT - This Agreement is the contract which applies to all transactions on your account even though the sales, cash advance, credit or offter slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance vhitten notice required by law. Your use of the card thereafter will indicate your agreement to the amendments. To the extent the law permits, and we indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. 17. LATE PAYMENT CHARGE - If your Minimum Payment is not received by the first day of the month following your due date, you wig be subject to a $20 charge. 18. RUSH FEES -You may incur additional charges for rush processing and rush delivery of cards and/or PIN mailer. 19. OVER OMIT FEE -A$20 fee will be applied for each mouthy statement dosing date on which the outstanding balance exceeds the assigned credit limit by more than $100. 20. DRAFT COPIES - You may incur an additional charge for transaction summary/sale draft documentation. 21. COPY RECEIVED -You acknowledge receipt of a copy of this Agreement. 22. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. 23. 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NYIPhV`Om Ch V)N0 Y4NO?,AN m•YM^• 0000 00,0,0,0.01 wwoococom NNNNNN N•-^^^^ 000000 666006 000006 Mvul,Ohfp 0,0^NMv of •OKWO.o Vvvvvv vto -nano LAh&AV1N0 L c OOONhO 'N hOVh Ohv Pv vMmm ?ON-f7M0 NI?O.MOv pQAO•NO. O m?A ?ONm Vv <vl?co.-M c0.-?A^h^ O vOMOh MOmv1vN OO.h?NV MN-000 ow 1010 Ovf?A?A u")?AVVVV vM MMI'7M l")MMf7MN NNNNNN 0 006060 000000 060000 006060 000000 ^NMVVf ?O ncpPO^N MV?A Ohcp O'O•-NMV NCO I?p°°, 0 ^NNNNN NNNNNm F r O s 3 3 u F 3 14 8 C rn -n ? r ??z SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-03615 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS VELEZ IVELISSE R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: VELEZ IVELISSE but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On August 29th , 2008 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So ans r Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Th s Kline Dep Dauphin Co 41.25 Sh i of Cumberland County Postage 1.34 79.59 ? 91D) 8' 08/29/2008 VAN ECK & VAN ECK Sworn and subscribe to before me this day of A. D. In The Court of Common Pleas of`Cumberland County, Pennsylvania* permsylvania State Dnplcyees Credit Union VS. Ivelisse Velez 08-3615 civil No. Now, August 20, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ?? ??. Sheriff of Cumberland County, PA Affidavit of Service Now, . within 20 , at o'clock M. served the upon at by handing to a and made known to So answers, the contents thereof. Sworn and subscribed before me this day of , 20 copy of the original Sheriff of COSTS SERVICE _ MILEAGE AFFIDAVIT County, PA C-01xt.1t, of the 'Seref May Jane Snder Real Estate Depu William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS IVELISSE VELEZ Sheriff s Return No. 2008-T-1825 OTHER COUNTY NO. 08-3615 CIVIL And now: AUGUST 26, 2008 at 1:40:00 PM served the within COMPLAINT upon IVELISSE VELEZ by personally handing to JALBERT VELEZ 1 true attested copy of the original COMPLAINT and making known to him/her the contents thereof at 1523 BERRY HILL STREET HARRISBURG PA 17104 BROTHER Sworn and subscribed to before me this 26TH day of August, 2008 117/ NOTARIAL SEAL ARY JANE SNYDER, Notary Publi Highslxre, Dauphin County M Commission Expires S !Pt 1, 2010 So Answers, n c- Sheriff of Dauphin County, Pa. By Depu en Deputy: R HOPKINS Sheriffs Costs: $41.25 8/25/2008 PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS CREDIT UNION, : CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA NO. 2008-03615 VS. IVELISSE VELEZ PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff and against Defendant, Ivelisse Velez for want of ANSWER TO COMPLAINT. (X ) Assess damages as follows: Debt -----------------------------------------------------------------$11,639.58 Attorney's Commission ------------------------------------------- $2,352.92 Filing costs ---------------------------------------------------------- $to be determined TOTAL -------------------------------------------------------------- 513.992.50 plus costs ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( X ) Pursuant to Pa.R.C.P. 237. 1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE: 101 /N Signature: I " d, d il? 4 1A A A V4 " ALW ? 4 1 61 Melissa L. Van Eck, Esquire Attorney for Plaintiff 7810 Allentown Blvd., Suite B, Hbg., PA 17112 (717) 540-5406 ID#: 85869 NOW, (} 3 , 2008, JUDGMENT S ENTERE S ABOVE. Pr onota r ,C' it Division By: Deputy Defendant CIVIL ACTION -LAW PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS CREDIT UNION, : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff NO. VS. IVELISSE VELEZ Defendant CIVIL ACTION -LAW TO: IVELISSE VELEZ 144 Meadow Brook Court New Cumberland, PA 17070 DATE OF NOTICE: September 19, 2008 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 NOTICE TO A 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 ELIGHBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 By: Meli sa L. Van Eck, Esquire Attorney I.D. No. 85869 P.O. Box 6662 Harrisburg, PA 17112 717.540.5406 Attorney for Plaintiff PENNSYLVANIA STATE EMPLOYEES: CREDIT UNION, Plaintiff VS. IVELISSE VELEZ Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-03615 CIVIL ACTION -LAW ENTRY OF APPEARANCE Please enter the Appearance of Van Eck & Van Eck, P.C., as counsel for Plaintiff in the above captioned action. Respectfully Submitted, VAN ECK & VAN ECK, P.C. Date: October 1, 2008 By: Melissa L. Van Eck, Esquire Attorney I.D. No. 85869 Henry W. Van Eck, Esquire Attorney I.D. No. 83087 P.O. Box 6662 Harrisburg, PA 17112 (717) 540-5406 Attorneys for Plaintiff PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2008-03615 VS. IYELISSE VELEZ Defendant CIVIL ACTION -LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, Henry W Van Eck, Esquire, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, Ivelisse Velez, above named, is not a corporation and is an adult individual under the age of 21 years of age; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. VA ? ECK & VAN ECK, P.C. By. ov",( Henry Van Eck, Esquire Attorney I.D. No. 83087 P.O. Box 6662 Harrisburg, PA 17112 717.540.5406 Attorney for Plaintiff Sworn and subscribed to before me this r 1 day of October 08 d Notary ublic NOTARIA?. SEAL MELISSA i VANECK Notary Public WEST HANOVER TWP, DAUPHIN COUNTY My COMMIssion Expires Mot 22, 2011 NOTARIAL. SEAL MEi0E.;4 LNECK WEf " -IN COUNTY 22, 2011 k +ik +Y Q ?T1 0? 'D Fz } _"yam },-a L l 7 ?_1 l PENNSYLVANIA STATE EMPLOYEES: CREDIT UNION, Plaintiff VS. IVELISSE VELEZ Defendant TO: Ivelisse Velez, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-03615 CIVIL ACTION -LAW You are hereby notified that on 10r oaho8 , the following (9r-de F) (Degree) (Judgment) has been entered against you in the above captioned case for your failure to file an answer to the complaint. A Judgment in the total amount of $13,992.50 plus costs is hereby entered. DATE: 4y"414akd Pr onotary I hereby certify that the name and address of the proper person(s) to receive this notice is: Ivelisse Velez 144 Meadow Brook Court New Cumberland, PA 17070 A: Ivelisse Velez, Defendant, Defendido/a (Defendidos/as) Por este medio se le esta notificando que el de del , el/la siguiente (Ofdm) (Deerete) (Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Prothonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Ivelisse Velez 144 Meadow Brook Court New Cumberland, PA 17070