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HomeMy WebLinkAbout08-3772MEMBERS 11T FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. ©Y- _a 7 7,2- TIFFANY M. HOLLAND Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses and objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without fiuther notice for any money claimed in the Complaint or for any other claim or relief requested .by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166. MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. TIFFANY M. HOLLAND Defendant AVISO USTED HA SIDO DEMANDO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos viente (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogando una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos impotantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A. UNO, LLAME 0 VAYA LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MEMBERS 11T FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW Lure-t ?' NO. Of-2772 V. TIFFANY M. HOLLAND Defendant COMPLAINT AND NOW come the Plaintiff, Member's lst Federal Credit Union, who files the instant action against Defendant, Tiffany M. Holland, of which the following is a statement: IDENTITY OF THE PARTIES 1. Plaintiff, Member's 1St Federal Credit Union ("Members 1st") is a federal credit union organized, licensed, and existing under the laws of the Commonwealth of Pennsylvania with an address of 5000 Louise Drive, Mechanicsburg, Pennsylvania 17050. 2. Defendant, Tiffany M. Holland ("Holland"), is an adult individual, who resides at 3 South Season Drive, Dillsburg, Pennsylvania 17019. 3. At the time of the Agreement, Tiffany M. Holland used the name Tiffany M. Benitez. FACTS 4. The averments of Paragraphs 1 though 3 are incorporated herein by reference as if set forth in full. 5. On or about the 13th day of November 1995, Members 1st issued a Visa credit card ("Credit Card") to Holland-based on the information contained in a Visa Credit Card Application ("Credit Agreement") signed by Holland; a true and accurate copy of said Agreement is attached and made a part hereof, and marked Exhibit A 6. The Credit Agreement extended a revolving line of credit to Holland, with a credit limit of $9,700.00 and subject to the terms of the Credit Agreement; a true and accurate copy of said terms is attached and made a part hereof, and marked Exhibit A. 7. Holland used the Credit Card to make various purchases from November 13, 1995 until approximately July 15, 2007. 8. Holland made payments toward the Credit Card balance through July 24, 2007, with a final payment of $200.00 made on said date. 9. As of July 24, 2007 no further payments have been made toward the outstanding balance on the Credit Card. 10. Members 1 st is owed an outstanding amount of $11,022.92 from Holland. COUNTI BREACH OF CONTRACT 11. The averments of Paragraphs 1 though 10 are incorporated herein by reference as if set forth in full. 12. By virtue of the aforementioned Credit Agreement, a valid and binding contract was created between Members 1 st and Holland. 13. Holland has refused and neglected to pay the amount due under the Agreement and has therefore breached Holland's obligations to Members 1 st in accordance with the Credit Agreement. 14. On or about March 20, 2008 a demand was made on Holland by certified mail to pay the outstanding balance, and Holland has refused and neglected to pay the same on demand. A true and accurate copy of said letter is attached hereto as Exhibit B. 15. As a result of the aforesaid default, Holland is indebted to Members 1 st in the sum of Eleven Thousand Twenty-Two and Ninety-Two One-Hundredths ($11,022.92) Dollars, comprised as follows: Principal Balance: $9,842.40 Unpaid Finance Charges: $880.52 Other Unpaid Fees: $300.00 Total: $11,022.92 The terms of the Credit Agreement further provide for payment of Attorney's fees and costs, and a demand is made therefor. 16. All conditions precedent to Plaintiffs right to recover have been performed or have occurred. WHEREFORE Plaintiff, Members 1St Federal Credit Union, respectfully requests entry of judgment in its favor and against Defendant, Tiffany M. Holland, in the amount of $11,022.92 with attorney's fees and costs in accordance with the agreement. COUNTII BREACH OF ACCOUNT STATED 17. The averments in Paragraphs 1 though 16 are incorporated herein by reference as if set forth in full. 18. Beginning on or about November 13, 1995, Members 1St had an ongoing business relationship with Holland pursuant to which Members 1St made a loan to Holland, and Holland was to pay the loan in accordance with the terms of the Credit Agreement. 19. Members 1St sent statements of account to Holland regarding the outstanding balance on the Credit Card, which was issued at Holland's request. 20. Holland had the opportunity to review the relevant statements of account and raise any objections regarding the accuracy of the information contained therein, including, among other things the amount stated as due. 21. Holland never objected to the amounts set forth in the statements or the letter of demand. 22. Despite repeated demands, Holland has failed to make payment on the amount due. The balance remains due. 23. As a direct and proximate result of Holland's failure to pay the account as stated, Members 1St has been damaged in the amount of $11,022.92. WHEREFORE Plaintiff, Members Pt Federal Credit Union, respectfully requests entry of judgment in its favor and against Defendant, Tiffany M. Holland, in the amount of $11,022.92 with attorney's fees and costs in accordance with the agreement. COUNT III UNJUST ENRICHMENT Plead in the alternative 24. The averments in Paragraphs 1 though 23 are incorporated herein by reference as if set forth in full. 25. By providing Holland with the Credit Card, Members 1St conferred a benefit upon Holland to which Holland was not entitled. 26. Despite demand, Holland has refused to pay the monies owed to Members 1St for purchases made with the Credit Card. 27. By accepting the Credit Card, using it, and refusing to pay the amount due to Members 1 st, Holland has been unjustly enriched at the expense of Members 1St in an amount of $11,022.92, thereby damaging Members 1st WHEREFORE Plaintiff, Members 1 st Federal Credit Union, respectfully requests entry of judgment in its favor and against Defendant, Tiffany M. Holland, in the amount of $11,022.92 with attorney's fees and costs in accordance with the agreement. Respectfully submitted, LAW OFFICE OF DUANE P. STONE, P.C. Dated: S UA' By: 4/E / Duane P. Stone, Esq. Attorney for Plaintiff Attorney I.D. No. 85715 8 North Baltimore Street Dillsburg, PA 17019 Ph: (717) 432-2089 Fx: (717) 432-0158 VERIFICATION The above Complaint is based upon information which I have furnished to my counsel and information which has been gathered by my counsel in preparation of this matter. The lan- guage of the Complaint is that of counsel and not of me. I have read the Complaint and to the extent that the Complaint is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon counsel in making this verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: 0611,312-60r By: Members 1St Federal Credit Union MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. TIFFANY M. HOLLAND Defendant CERTIFICATE OF SERVICE AND NOW, this i day of_, 2008, I hereby certify that I have served a copy of the Complaint upon the following by depositing a true and correct copy of the same in the United States Mail, postage prepaid, at Dillsburg Pennsylvania addressed to: Tiffany M. 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Now 1, Cash Adwtra FBB NorM aldt 01" fell L TWINIoa FM (lot podrw) • NM t Trasrda114s ltor prdMwy - Nono t LOFir-Now t UMro•Nan L OAdkAFa-fife 4. t de"Fa -510 YOti DILLING 1`1110"TS KEEP THIS NOTICE FOR FUTURE USE - This notice awdai s Nnportant InIlamtatlon about your rights and our rosponalblNtlaa under the Fair Crm* falNinq Aot. NOTTRY US IN CASE OF ERROR OR OUNGTIONB ABOUT YOUR IUL.L it* brat ? o. wUMch pw?w oo show at problem ewso You Can OWWWU Lik but am address ilated an your bill. Wft to esy souwrn " Wnk y?r beb We nwrorV. or It Vow need re ouett how from you no Intaffnatlon ister than No dda a aIW i e 0001You your Pn dakV us is will not possible, atarve your rllflbl. In your Iona *a we the followlrq Information: (t) Your nerne and acovint number. (R) The dollar amount of dw suspected corer. 13) aueckoe 6'w wror and otphm. It you can, why you beiWirs dwe Is an error. 11 you rnwd more Wlarmation, deewbe the Item you we not aura about, W it the amount on No det mmi don PO oemlapo?W to An arnoon of your Babe alp or you have not mealved the proper w*A an your etuferownt for nwrehandbe raturnad, a copy of ow salve clip MUST aemrnpany your low. YOUR RK#HTS ANO OUR RlVirON904UTIES AFTER WE RECEIVE YOUR WWtTEN NOTICE W moo wAnowradpe your loner. O hln 30 dws. unfess we have oorreebd the sm by than. WNhln 00 days. wa must aNhar care Ow error or *Wbin why we brlwo the bill Well correct. AhN We honift your letter. We canmt try to colkat any t you Quesda t of raoort you in dalk t. We can continua to ill for to amount you we qunl? In ut c mum ?r end cos rnn e .ry TVyll that we not ln?awiti at?r andll Ilnh Moir do not love to WY any b amount wile cos era Irwaa but you w arilsilill b pay?rNre parts o our bi mlimake anrount. In ahh ease. we mount send tw e?alrawmd of On mnvq haw a pay Nrriiea ?? a Ya not and yams vA hove b minks uupp ary niwtoed P" aq psymenla on #* queadw da nY quesdorwi 1 o" and Ifie am 111111111 N li flue If fail to the amount Aaf we think you wa nay MW you as delh*Jark Fiowsrrer, N our apMlallon does not se", uM and your maws bn d w t?Yw eliA trrhtw to par. we muff till =Z10=1 you taw a aprratron low. your . M4 veer lrou sqAne To M w?ino 111. tt tawseew?ihwsrulm• e - -M-W-M ubrr? ?dIl" qiss vms iwnir M Nosh sofrfbt eet drMm wNh the SPECIAL M" FOR CREW CARD?PrgU, MASES If you have 9 pooblem oft Owe --am A nN1M hw n I oilier biyoorr?r?q?r?o set -in 111111011 you r. 11101 tit yar?orne I of aA "in". 6are 100 miles ofvw eEtone yft Naaad Co. ft Or fwm be rr srara Alen ito es. _ rrreunN e. T hr purdstw rmtN Thee Mldtatlora der nw spphiown err opera1 tisnand" or N we sled you the adwrYaarrrrrl for fhe papertr or Benton ti0/ti0 'd LUSSELIL SNOI1031100 ISI SHOWN Wd SS:SO 800Z-E1-Hr A Credit Card Agreement and Discla. ; Notice: See reverse side for important information regarding your rights to dispute billing errors. 1. Meaning of Words. The following wards have the following meanings in this Agreement and in the monthly billing statement sent hereunder: (a) 'Agreement" means the Visa Credit Card Agreement and Disclosure furnished by us. (b) 'we', *us' and 'our' means Members 1st Federal Credit Union, Mechanicsburg, PA. (c) 'you" and 'your means each person who signs the application fa the Account. (d) "Card" means any Visa Credit Card and arty duplicates and renewals we issue to you or to an authorized user of your Account. (e) 'Account" means your Visa Credit Card Account with us. (f) "Line of Credit means the self-replerrishing line of credit we make available to your Account. (g) "Advance" means any credit extended on your Account for any purchases or Cash Advances. (h) "Cash Advance" means (i) any cash or credit extended on your Account by us or by any other institution that accepts a Card, (ii) any withdrawal of cash made by using a Card and personal identification number ('PIN') at an automated teller machine ('ATM') or tither type of electronic terminal that provides access to the Visa system, (Iii) the amount of any Visa Convenience Chak paid by us, or (iv) the amount of any balances transferred to your Account from another credit card or account. (f) 'Visa Convenience Check' means any check that directly accesses your Account. The amount of any Visa Convenience Check paid by us is posted as a Cash Advance under your Account. 2. How To Use This Account. Your Account may be used to purchase or lease goods and services ("purchases') from a merchant by presenting a Card and signing a sales transaction receipt for the amount of the purchase or by giving a Card Account number. Your Account may also be used to obtain CashAdvances: (a) By receiving ash or credit from financial institutions that accept a VISA Credit Card; (b) By use of Visa Convenience Checks; (c) By making cash withdrawals with a Card at an ATM or other type of electronic terminal that provides access to the Visa system; or (d) By transferring to your Account a balance from another credit card or account. 3. Responsibility. You agree to pay all Advances, finance charges and other fees or charges charged to your Account arising from the use of a Card, a Visa Convenience Check or the Account by you or anyone you authorize or permit to use your Accotm, a Visa Convenience Check or a Card, even if you do not notify us that others are using your Account, a Visa Convenience Check or a Card. Your responsibility for charges made by anyone you authorize or permit to use your Account, a Visa Comonierce Check or a Card continues until you notify us in writing at 5000 Louise Drive, P. 0. Box 40, Mechanicsburg, PA 17055, and recover and destroy any Visa Convenience Check or Card in such person's possession. Your obligation to pay the AccoM balance continues regardless of the terms of any agreement. divorce decree, or other court judgment to which we are not a party. If more than one person signs the application for the Account, you are each jointly and severally responsible for all charges on the Account. 4. Liability for Unauthorized Use. You understand that your total liability to us shall not exceed Fifty Dollars ($50) resulting from the loss, theft or other unauthorized use of a Card that occurs prior to the tlme you give notice to us. Such limitation des not apply when a Visa Convenience Check is used. 5. Lost Card Notification. if you believe a Card or any Visa Convenience Check has been lost or stolen, you must immediately call us at (717) 795-6032 of 1(800}283-2328 during normal business tours. After business hours (nights and wed") a on hol- idays, lost or stolen Cards or VISA Convenience Checks most be reported by calling 1(800)-325-3678. 6. Credit Line. If we approve your application, we will establish a Lire of Credit for you and notify you of its amount when we issue a Card. This amount is your credit limit for the Account. You agree not to let the Account balance exceed this approved credit limit. Each payment you make on the Account will restore your credit limit by to amount of the payment that is applied to the principal balance erred on the Account. You may request an Increase in your credit limit, which must be approved by us. We may reduce your credit limit or terminate this Agreement for any reasons not prohibited by applicable law, with only such notice as is required by applicable law. You may also terminate this Agreement at any time, but termination by either of us des not affect your obligation to pay the Account balance. To terminate this Agreement, you must notify, us in writing at 5000 Louise Drive, P. 0. Box 40, Mechanicsburg, PA 17055, and recover and surrender to us all Cards, and any Issued but unused Visa Convenience Checks. They remain our properly. 7. Credit Information. You authorize us to investigate your credit standing when opening, renewing or reviewing your Account, and you authorize us to disclose information regarding your Account to credit bureaus and other creditors who inquire of us about your credit standing. 8. Payments. We will mail you a billing statement every month showing your Previous Balance comprised of purchases and Cash Advances, the current transactions on your Account, your credit limit, the available credit, the New Balance, to Finance Charges for the billing cycle, and the Minimum Payment required. Each month you must pay at least the Mininaan Payment shown on your statement by Me Payment Due Data shown on the statarrent or no later than 25 clays from the statement Closing Date, whichever is later. It your statement says your payment is 'Now Due; your payment is due no later gran 25 days from One statement Closing Date. You may pay more frequently, pay more than the Minimum Payment or pay the New Balance In full. If you make extra of larger payments, you are still required to make at least the Minimum Payment each month your Account has a balance (offer than a credit balance). The Minimum Payment will be either a) Two percent (2%) of your New Balance or $20, whichever is greater, plus any portion of the Minimum Payment shown on prior statement(s) which remains unpaid, or b) your New Balance, if it is less than Twenty Dollars ($20) We also thaws the right to demand immediate payment of any amount by which your New Balance is over your credit limit. We will apply your payments first to any fees, then to Finance Charges on both Cash Advances and purchases, then to previously billed Cash Advances, On to previously billed purchases, then to new Cash Advances and then to new purchases. We may accept checks marked 'payment in full' or with words of similar effect without losing arty of our rights to collect the full balance of your Account. 9. Finance Charge. A. The current monthly Periodic Rate and corresponding Annual Percentage Rafe are set forth on the 'Additional Disclosure' which is sent to you together with this Agreement. B. Variable Rate: The Annual Percentage Rate will be determined by adding the margin to is index value. The Annual Percentage Rate an charge on the first calendar day of the first billing cycle in each calendar quarter. The margin for Visa PlMkrum is 5.00% for both purchases and Cash Advances. The margin for Visa Gold is 5.00% for both purchases and Cash Advances. The margin for Visa Classic is 5.50% for both purchases and Cash A varoes. The margin for Visa Classic Rate Shave is 2.00% for both purchases and Cash Advances, subject to a minimum Annual Percentage Rate of 9.9% for the Visa Classic Rate Shaver program. The index is the highest Prime Rate published in the money rates section of the Wall Street Journal. The index will be measured as of the last business day of the immediately preceding calendar quarter. Any increase in the Annual Percentage Rate may cause the amount of the minimum monthly payment to increase. Also, you may have to pay more payments. The Annual Percentage Rate will never exceed 21% or the maximum allowed by law, whichever is less. The monthly Periodic Rate is equal to one-twelfth (1/12) of the Annual Percentage Pie. C. Method A - Average Dairy Balance (Inabding New Cub Advances): A Finance Charge will be imposed on Cash Advances from to date made or from the first day of the billing cycle in which the Cash Advance is posted to your Account, whichever is later, and will continue to accrue until the data of payment. The Finance Charge on Cash Advances for a billing cycle is computed by applying the monthly Periodic Rate to the average dally balance of Cash Advances, which is determined by d* ding the sum of the daily balances during the billing cycle by the number of days in the cycle. Each daily balance is determined by taking the beginning balance of Cash Advances on your Account each day, adding any new Cash Advances, and subtracting any payments or credits that are applied to Cash Advances but excluding any unpaid Finance Charges. 0. Method 0 - Average Daily Balance (Includlrp Now CredN Purdrues): A Finance (gouge will be imposed on purchases only it you elect not to pay the entire New Balance shom on your monthly billing statement for this previous billing cycle on or baton the Payment Due Date of drat statement. t you elect not to pay the entire New Balance sham on your previous madly billing statement by the Payment Due Data. a Finance Charge will be imposed on the unpaid average daily balance of purchases from the previous slalennent Closing Data and on new purchases from the date of posting to your Amount during the current billing cycle, and will continue to aanre untl the Closing Date of the billing cycle preceding the date on which to entire New Balance is paid in hull or until the date of payment if later than the Payment Due Data. The Finance Charge on purchases for a billing cycle is computed by applying the monthly Periodic Rate to the average daily balance of purchases, which is determined by dividing the sum of the dally balances dying the billing cycle by the number of days in tie cycle. Each daily balance is determined by taking the beginning balance of purchases on your Account each day, adding any new purchases, and subtracting any payments or credits that are applied to purchases, but excluding any unpaid Finance Charges. 10. Default. You will be in default it you fail to make any minimum payment or other required payment by the date that it is due. You will be in default if you break any promise you make under this Agreement. You will be in default if you die, file for bankruptcy, our become Insolvent, that is, unable to pay your obligations when they become due. You will be in default it you make any false or misleading statements in any credit application or updals of credit information. You will also be in default if something happens which we believe may substantially reduce your ability to repay what you owe. When you are in default we can demand Immediate payment of the entire amount you owe under this Agreement without giving you advance notice. If immediate payment is demanded, you will continue to pay interest, at the applicable interest rates in effect under this Agreement, until what you on has been repaid. If demand for immediate payment has been made, the shares and deposits given as security for payment undo this Agreement can be applied towards what you owe. We can also take appropriate action as authorized under the Uniform Commercial Code to repossess any and all collateral pledged to secure repayment under Oft Agreement. To the extent permitted by applicable law, you will also be required to pay our collection expenses, including court costs and reasonable aftomeys' fees. We can also exercise any other rights given to us by taw when you are in default. 11. Using the Card. You may use a Card, Card Account number and/or PIN to make transactions on your Account. You will retain to copies of the transaction receipts furnished to you in order to verify your monthly billing statement. You agree that you will not use or permit anyone to use a Card or your Account for am transaction that is illegal under applicable federal, state or local law. You agree that illegal use of any financial service will be deemed an action of data* and/or breech of contract and such a service and/or other related services may be terminated at our discretion. You further agree, should illegal use occur, to waive any if It to sue us for such illegal use or any activity directly of indirectly related to it. Additionally you agree to indemnify and hold us harm- less from any suits or other legal action or liability, directly or indirectly, resulting from such illegal use. We reserve the right to decline any transactions that we consider fraudulent, suspicious, or illegal and you further understand that we will not knowingly autho- rize charges related to online gambling. -00 CONTINUED ON REVERSE 12. Relates and Ad)es6nsat&. Merchants and odm who honor a Card may give credit or returns or adjustments, and they will do so by sending Lisa credit Transaction receipt, which we will post to your Amount. If your credits and payments exceed what you owe us, we will hold and apply this credit balance toward future purchases and Cash Advances, or if it is one dollar or more, refund It on your wrf8eh request or automatically after six months. 13. Using Visa Conronieaae Cheeks. You may use your Visa Convenience Checks, it available, as you would use a Card to male a purchase or payment or to receive ash. Your Visa Convenience Checks directly access your Account. All Visa Convenience Checks paid by us are WW as Cash Advaces herearder and, woo as o8erwise indicated, are subject to all terms of this Agreement pertaining to Cash Advances and toga following additional tams: A No Visa Convenience Check may be used to make a payment on your Account. B. Only the parson whose tame appears on a Visa Convenience Check may use them. C. Visa Convenience Charts must be wrten in U.S. Dollars. Visa Convenience Checks may nol be certified. 0. Ne may return a Visa Convenience Check unpaid 9 there is not sough available credit on your Account to pay it, if your Acco mt is in default, or if a Card or any Visa Corrvenience Clads have been reported lost or stolen. A $10 fee will be charged for each returned visa Convenience Check. 14. Foreign Transactions. Purchases and Cash Advances made in foreign countries and foreign currencies will be billed in U.S. Dollars. Effective April 2, 2005, the exchange rate for transactions in a foreign currency will be a rate selected by Visa from the range of rates available In wholesale currency markets for the applicable central processing date, which rate may vary from the rate Visa bell receives, or the government mandated rate in elect for the applicable central processing date, increased by ore-percent. On foreign transactions you agree to pay all currency exchange charges. 15. Merdwd ObMdes. We are rout responsible for the refusal at any merchant or financial institution to honor a Card or Visa Convenience Check. 16. Security lose a . To sense your Aceant, you grad us a purclm money seaaity interest under the Uniform Commercial Code in arty goods you purchase using the Account. If you default we will have the right to recover any of these goods which have not been paid for through our application of your payments in the manner described in paragraph 8. Pledge of Shas Aconsl(N • MOTE: To snare year Actual, year ~ to ae and greet a oseadty lateead Is all plat ad hailledded scosasts yru hero with Nation 1st Federal Crank Ueda am sad is tha tetw% aruap sync ka hrraMaal Ilaifanlld Asnoala sad a ere I wtnwe the plaits or transfer of which world ca sso the lose d a tax-tempt or tax4dorred sides. Tao =U wee os to apply the salute la there ueauya) b pol coq mossila doe ands iWa Agraasood M year dhald ddult. 17. Fees acrd Oder Charges. The Moving fees and other charges will be added to your Account, as applicable: A. ArA" Fos Viss Platinum .............. Nora Visa Gold............ None Visa Classic ................ None Visa Classic Rate Shave...... None 8. Lela payment Charges. If you left to pay the minimum payment on your Account within five (5) days of the Payment Due Date, a late payment large o1$30 will be added to your Account. C. Over•Limft Charge. If your Account balance exceeds your credit limit at any time during the statement period, an over-limit charge of $15 will be added to your AceounL D. Relaraod Check fee. If a deck or On draft used to make a payment on your Account is returned unpaid because of insufficient kinds or for any other reason, you will be charged a fee of $10 for each item returned. E. Beta reed Stalamed Fee. You will be charged $t for each monthly billing statement that is returned. F. Copies of Vbe Transaction Rose41s and Statements. You will be charged $3 for each copy you request of a receipt for any purchase, credit or Cash Advance or of a monthly billing statement (except in connection with the resolution of a billing error.) 18. Skip Payment Option. We may allow you, from time to time, to omit a monthly payment. We will rotily you as to any month in which the option is available. l you omit a payment, Finance Charges will accrue on your balance in accordance with this Agreement. A skip payment does not extend the period within which you must pay the New Balance in order to completely avoid Finance Charges on purchases. A mk*w payment will be due in the month following the month In which you skip your payment. 19. Effective Agreement. This Agreement is a contract which applies to all transactions on your Account, even though the receipts you sign or receive for purchases, credits, Cash Advances or the transactions may curtain different terms. We may amend this Agreement from doe to lime by sending you written notice. If required by applicable law, we will give you written notice before the effective date of the amendment. To the extent applicable law permits, and as we indicate in our notice to you, amendments wilt apply to your existing Account balance as well as to future transactions. This Agreement shall be ohstrued In accordance with the applicable laws of the Commonwealth of Pennsylvania and applicable federal laws. YOUR BILLING RIGHTS - KEEP THIS FOR YOUR RECORDS This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Ad. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR MONTHLY BILLING STATEMENT. If you think your monthly billing statement is wrong, or if you need more information about a transaction on your statement, write us on a separate sleet of papa at de address listed on your statement gun 60 days after we send you the first statement on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your Won,, give us the following information: • Your name and Arrant rnumber • The dollar amount of the suspected error. bet here f an rrorl need more information describe the Rem u are not sure about Write to us as soon as possible. We must hear from you no laW Describe gar error aid explain, d you cah, why you eve Is e You yo If you have authorized us to pay your monthly billing statement automatically from your Savings or Checking Account, you can stop the payment on any amount you think is wrong. To slap the payment your letter must reach us three (3) business days before the auto- matic payment Is scheduled to occur. . YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the statement was correct. Age we receive your feller, we cannot by to cow any amount you question, or report you as delinquent. We can continue to sob statements to you for the ameurt you question, including finance charges, and we can apply any unpaid amount against your credit limit. You do not have to pall any questioned amount while we are Investigating, but you are still obligated to pay the parts of you statement that are not in question. If we fiend that we made a mistake on you statement, you will not have to pay any finance charges related to any questioned amount. It we didn't male a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the ques- fieoed amourd. In either case, we will send you a statement of the avant you owe and the data that it is due. If you left to pay the amount lal we think you owe, we may report you as delinquent However, if our explanation doss not satisfy you and you write to us within en days telling us tlai you still refuse to pay, we must ell mWm we report you to that you have a ques- fio about your statement. And, we met tell you the name of anyaa we reported you to. We nxsl tell anyone we report you to that the maker has been settled behieen us when it finally is. If we don't follow these rues, we can't collect the first SW of the questioned amount, even it you statement was cared. SPECIAL RULE FOR CREDIT CARD PURCHASES. If you have a problem with the quality of property of services that you purchased with a credit card, and you have tried in good elk to mrred the problem.with the merchant, you may have the right not to pay the remaining wool due on the property or services. There are who gmitadors on ills rigid: (a) you must have made the purchase in your home slate 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 nailed you der advertisement for the properly or services. . EXHIBIT B Law Offices of "Duane P. Stone, P.c. ATTORNEYS AND COUNSELORS AT LAW Duane P. Stone Jason B. Duncan J. Grant Moubry * Also licensed in New Jersey P.O. Box 696 8 N. Baltimore Street Dillsburg, PA 17019 OFFICE 717-432-2089 1-866-314-7777 FAX 717-432-0158 Duane@StoneatLaw.com March 20, 2008 Ms. Tiffany Holland 3 S. Season Drive Dillsburg, PA 17019 RE: Past due amount for Member's l.t Visa - Account No. 4121-4499-9352-4979 .Dear Mr. Bullock: IM firm has been retained to `serve as a debt collector on behalf of Member's 1st Federal Credit Union ("Member's l ?t") regarding -the. "matter of your past due credit card balance for the above referenced. "account. As of March 10, 2008. the.. overdue balance on this account totals Eleven Thousand Twenty Two . and Ninety Two One Hundredths ($11,022.92). It 'is my understanding that Member's lot has repeatedly informed you of the outstanding balance due but. received. no response from you. There 'is nothing to be 'gained. by delaying "or avoiding communication; in fact., your silence may have a negative impact on. the' future handling of this matter. This is an attempt to collect the, outstanding debt of Eleven Thousand Twenty Two and., Ninety- Two One Hundredths ($11,022.92) due and owed to. Member's 1st. Unless.you notify us within thirty (30) days of receipt of this letter that you dispute the validity. of this debt or any portion thereof, we. will: assume that this debt is valid: Member's. 1st has the right to pursue late fees, collection costs, and attorney's fees. If you notify us in writing within thirty (30) days after receipt of this notice that you dispute the debt or any portion thereof, we will obtain verification of the debt and mail the same to you. Any information that you provide will be used in the collection of the debt. Quality,, Integrity and Personal Attention. ¦ Complete sterns 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the. card to you. ¦ Attech this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: 1 ?5.? i F?an? Nv?la?-? 3 S . Seaso?? '?' 13 Agent X ? Addra ( ## m) . I Qi-jDate of Dellvery lsdeMMy a"M different from Item 1? ? Yes If YES, enter delivery address below: ? No O k Service Type Ptlfled Mail E3 Express Mail E3 Registered ? Return Receipt for mwd m hw ? Insured Mail 13 C.O.D. 4. Restricted Delivery ? Pft Feel ? Yes 2. AnUe Number 7006 0100 0004 7137 4190 '(rraosrerrrom servke rabep PS Form 3811, February 2004 Domestic Return Receipt 1025e5-oz-*1540 0 Ir r,- m r:l r\- C3 C3 CertMed Fee O (EndotaemeM"Rega4 O Restricted Delivery Fee M (Endorsement Requlredy r-9 C3 TOW postage & Fees C3 o C3 I a?er? ..... ip; : ate; l t1 r. f --j 0 I'ai o C?v C? -r Cf Y ?? SHERIFF'S RETURN - OUT OF COUNTY f a? CASE NO: 2008-03772 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UNI VS HOLLAND TIFFANY M 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: -- T -- T T Tl- wT?7 TR but was unable to locate Her deputized the sheriff of YORK serve the within COMPLAINT & NOTICE On July 24th , 2008 , t attached return from YORK s office was in receipt of the Sheriff's Costs: So answers: Docketing 18.00 J 4(" Out of County 9.00 t (1 Surcharge 10.00 ?(-R) Thomas line Postage 1.52 Sheriff o Cumberland County .00 38.52 ? 71.2vl0f 07/24/2008 DUANE STONE Sworn and subscribe to before me this day of in his bailiwick. He therefore County, Pennsylvania, to A. D. !? .? iP(1' r 1 n? 00f t& r PENNY PRESS OF YORK, INr,. Ph (717) 843-4(078 Fax (717) 648-1360 COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 I boop", SERVICE CALL (717) 771-9601 SHERIFF SERVICE OSTIOM PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LN 1 THRU 12 DO NOT DETACH ANY COPIES 1 PLAINTIFF/S/ 3 DEFENDANTS/ SE RVE - OIL 2 COURT NUMBER 4. TYPE OF WRIT OR COMPLAINT N O T I C E, Notice' Wd Complaint NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO., CITY, BORO. TWP. STATE AND ZIP CODE) AT 50LA-h Sf-gS rill (' ( 13 b ur 1-70 7. INDICATE SERVICE U PERSONAL 0 PERSON IN CHARGE EPUTIZE RfiW2n 'q O CLASS MAIL 0 POSTED 0 OTHER NOW June 27 20 08 I, SHERIFF OF 'SIC COUNTY, PA, do hereby deputize the sheriff of Ynrk COUNTY to execute this return thereof rding to law. This deputization being made at the request and risk of the plaintiff., ..?.?.? -? SHERIFF OF 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVIN T OF COUNTY Cumberl Please mail return of service to Cumberland 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 wi8wut 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 sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE (>A 10. TELEPHONE NUMBER I1 DATE FILED DU h Imo. 5n a I-i or-p- S+ pl? Os bu 6-26-08 12. SEND NOTICE OF SERVICE COP TO NA AND ADDRESS BELOW: (This area must be completed it notice is mailed) n ?aI'1.L P Sty <- C- x • , 8 lJ . ?e 1 i;MeY-? S CUMBVR °°?uR Iii- f? 6T 13. 1 admowWW receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date or complaint as i n d i c a t e d above. M J M C G I L L Y C S Q 16-30-08 17-26-08 16. HOW SERVED: PERSONAL RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17 O 1 har.lw r• ti and rorurn a T Fni INr1 harause I am unahle to Inrate the individual oomnanv etc named above. (See remarks below.) 18.XIrAME"0 TITL OF INDIVIDUAL 4:J UAnAA ERVE T ADDRES HERE IF NOT SHOWN ABO (Relationship to De ant) 19. ygc?gggi?e 20 Tim?ff S ' 21. EMPTS lme t. Dale ime Miles Int. Date Time Milesr Int. 03e Time Miles I -TRr Dale Time Miles Int. Date [Tim Miles Int. ZZ. KLMAMW 23. Advance Costs 24 S ice Co is 3 25 N/F 26. Mileage 27. Postage X28. SlAb 29. Pound 30 Notary 7 31. Surchg. 3 . Tot. Costs 33 nit Check No. 7 100.00 0 d'/'. (O?` 5 0 $3 9 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. 38. Mileage/Postage/Not Found 39. Total Costs -40. Costs Due or Refund SO ANSWERS 41. AFFIRMED and subscribed toT rme?ltu 0 44, Signature of / ll (y 7 45.T 42, day of Dep. Sheriff ^'':??L-... NC7;":?,L-... / NOTARY / NOTARY 46. Signature of York 47. DATE LISA L 00 ^t + ' I UBLIC County Sheriff 01 /18/08 7 CITY OF t: yN RICHARD KEU L IF B R WY COWWIS.. -= .- 12, 2009 48 Signature of Foreign 49 DATE County Sheriff MEMBERS 1 ST FEDERAL CREDIT UNION Plaintiff V. TIFFANY M. HOLLAND Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3772 PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter judgment in favor of Plaintiff and against Defendant Tiffany M. Holland in the amount of $11,022.92 together with interest, any legal fees, plus costs to be determined. A Ten Day Notice of Default is attached hereto and made a part hereof, marked as Exhibit "A". I hereby certify that the name and last known address of the proper person against whom judgment should be entered under Pa.R.Civ.P. 236 is: Tiffany M. Holland 3 South Season Drive Dillsburg, Pennsylvania 17019 It is certified that a written notice of intention to file this praecipe was mailed to the defendant against whom judgment is to be entered after the default occurred and at least 10 days prior to the date of the filing of this praecipe. Respectfully, Date: 9- 3 O-O$ Duane P. Stone, Esq. Atty ID No. 85715 8 North Baltimore Street Dillsburg, PA 17109 Ph (717) 432-2089 Fx (717) 432-0158 MEMBERS 1 IT FEDERAL CREDIT UNION Plaintiff V. TIFFANY M. HOLLAND Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3772 NOTICE OF ENTRY OF JUDGMENT TO: Tiffany M. Holland You are hereby notified that on - 30..2009 , the following judgment has been entered against you in Cumberland Co ty for the above-captioned matter: 1. Judgment in the amount of $11,022.92 together with interest, any legal fees, plus costs to be determined. 1 111444 Date: 9.30 -De P othonotat I hereby certify that the names and last known address of the proper person to receive this notice under Pa.R.Civ.P. 236 is: Tiffany M. Holland 3 South Season Drive Dillsburg, PA 17019 LAW OFFICE OF DUANE STONE, P.C. Duane P. Stone, Esq. Attorney ID # 85715 8 North Baltimore Street Dillsburg, PA 17019 Ph (717) 432-2089 MEMBERS 1 IT FEDERAL CREDIT UNION Plaintiff V. TIFFANY M. HOLLAND Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3772 CERTIFICATE OF RESIDENCE PA.R.CIV.P.236 I, Duane P. Stone, Esquire, hereby certify that the precise residence of Plaintiff is: Member's 1St Federal Credit Union 5000 Louise Drive Mechanicsburg, Pennsylvania 17050 And certify that the last known address of the within Defendant is: Tiffany M. Holland 3 South Season Drive Dillsburg, PA 17019 Date: Respectfully, Duane P. Stone, Esq. Atty Id No. 85715 8 North Baltimore Street Dillsburg, PA 17019 Ph (717) 432-2089 Fx (717) 432-0158 I,& MEMBERS 1 IT FEDERAL CREDIT UNION Plaintiff V. TIFFANY M. HOLLAND Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3772 CERTIFICATE OF SERVICE AND NOW, this 5b"" day of S bee-, 2008, I hereby certify that I have served a copy of the Notice upon the following by depositing a true and correct copy of the same in the United States Mail, postage prepaid, at Dillsburg Pennsylvania addressed to: Tiffany M. Holland 3 South Season Drive Dillsburg, PA 17019 LAW OFFICES OF DUANE P. O E, P.C. 40 J2.1 By: EXHIBIT "A" MEMBERS 1ST FEDERAL CREDIT UNION Plaintiff V. TIFFANY M. HOLLAND Defendant TO: Tiffany M. Holland IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3772 IMPORTANT NOTICE DATE OF NOTICE: September 16, 2008 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO RESPOND TO A COMPLAINT WHERE YOU ARE NAMED AS A DEFENDANT. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU 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 ELGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 a AVISO IMPORTANTE A: Tiffany M. Holland FECHA DEL AVISO: September 16, 2008 USTED ESTA. EN DEFECTO PORQUE USTED NO HA PODIDO RESPONDER. A LAS PETICIONES DEL DESCUBRIMIENTO RELACIONADAS CON LA DEMANDA ANTEDICHA.. A MENOS QUE USTED ACTUE DENTRO DE DIEZ (10) LOS DIAS A PARTIR DE LA FECHA DE ESTE AVISO, UN JUICIO SE PUEDE INCORPORAR CONTRA USTED SIN UNA AUDIENCIA Y USTED PUEDE PERDER SU CARACTERISTICA U OTRAS DERECHAS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Duane P. Stone, Esq. Atty Id No. 85715 8 North Baltimore Street Dillsburg, PA 17019 Ph (717) 432-2089 Fx (717) 432-0158 THIS NOTICE SENT FIRST CLASS AND CERTIFIED MAIL MEMBERS 11T FEDERAL CREDIT UNION Plaintiff V. TIFFANY M. HOLLAND Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 08-3772 CERTIFICATE OF SERVICE AND NOW, this 1 B4"*' day of , 2008, I hereby certify that I have served a copy of the Notice upon the following by depositing a true and correct copy of the same in the United States Mail, postage prepaid, at Dillsburg Pennsylvania addressed to: Tiffany M. Holland 3 South Season Drive Dillsburg, PA 17019 LAW OFFICES OF DUANE P. STONE, RC. By: Dyx?A F S-tt,? ?ts SU vim} r `.. b ?D c? c.a v r- a