HomeMy WebLinkAbout08-44769'
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES NO. C)% - qq% Civ'L ief-rti
CREDIT UNION,
Plaintiff
VS.
KRISTY M PALMER
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 #: 180057.1
EN LA CORTE DE ALEGATOS COM UN DEL CONDADO DE CUMBERLAND,
PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES NO.
CREDIT UNION, ,
Plaintiff _
VS.
KRISTY M PALMER
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 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.
KRISTY M PALMER
Defendant
NO. Of- 4«f 7G Cc,-4 ru,....
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, Kritsty M Palmer, is an adult individual with a last known address of
204 S. 16th Street, Camp Hill, PA 17011-5507.
3. Defendant is, and at all relevant times material hereto has been, the primary loan
applicant.
4. Defendant applied to Plaintiff for a loan for the purpose of purchasing a motor
vehicle.
5. 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
6. 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".
7. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms
and conditions of the Contract marked as Exhibit "B".
8. Various charges and payments were made by Defendant on the account.
9. 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.
10. 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.
11. Plaintiff provided a letter to Defendant indicating that there was a resulting
deficiency after the sale of the vehicle.
12. Plaintiff has maintained a statement of account keeping an accurate and running
amount of debits and credits made on Defendant's account.
13. Plaintiff has submitted to Defendant a copy of the statement of account accurately
showing all debits and credits for transactions with Defendant.
14. Defendant has not objected to any of the monthly statements of account submitted
by Plaintiff to Defendant.
Document #: 180057.1
15. 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.
16. As of July 22, 2008, the balance due, owing and unpaid on Defendant's loan
account with Plaintiff is the sum of Ten Thousand Seven Hundred Fifty-One Dollars and 32/100
($10,751.32).
17. 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.
18. 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 One
Hundred Seventy-Five Dollars and 26/100 ($2,175.26) have been added to the account.
19. Any and all conditions precedent to the bringing of this action has been performed
by Plaintiff.
20. 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,
Kritsty M Palmer, in the amount of Twelve Thousand Nine Hundred Twenty-Six Dollars and
58/100 ($12,926.58), 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:-AM?
Title: CD ll ec o a 11 a nAf6,2 ('
Date: g -N-o D
EDIT «A»
I
t
• 1
1
.1
K)AMM
ADVANCE PROCEEDS VOUCHER
AND SECURITY AGREEMENT
'MEMBER NAME; '::,-•.,,J;.
KRISTY M PALMER
204 S 16TH STREET
HARRISBURG, PA 17011
PSEC#
Pennsylvania State
Employees Credit Union
P. O. Box 87013
Harrisburg, PA 17108-7013
717.234.8484
800.237.7328
0005735800
10/30/20168674132538/L10
LIRPOSE 1
Dealer Purchase
?N ,. NEW LOAN 2 ? LOP?ANN ADVANCE 3. a p
MIIIIIIII
DISBURSENIENT D
YOU HAVE PREVID1l81.Y ELECTED TO HAVE MG ADVANCE OREDIT DISABIJTY
INSURED WITH THE FOLLOWM COVEWE YES ? No
DADdr PeRIO[NO MTi ANNUAL. PER- INTEREST RATE 13 AMOUNT REQUESTS
(CHANQUIVTERMSONCI CENTAGE RATE +OTHERCHARSE8
.015726
1 11 5.740 9?o FIXED YAQ?' , 14 602.0
PAYMENT DUE DATE .
280.52 11129/2006
DHOME
4 EQUITY ADVANCE
ENT SCHEDULE-
SINGLE CF3EDIr L*b JOINT CREDIT OF?p
YES Q MO YES F-1 NO t_ J
IDVANCEO PREVIOUS BALANCE NEW aALANCE
0.00 14, 602.00
Monthly
SCANNED
oy ac WwW the proceeds or by using the funds advanced and deposited Into your share/share draft account, you agree (1) that the property referenced above
will secure the advance and any other advances you have now or recelve in the future under the LOANUNER° Credit and Securtlyr Agreement (the Plan) and
arty 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
accordance with the terms of the Plan.
a cmMurIA p)P. UK Sp, WK ak It It 200. ply 040%ALL NOW RMERVED PENNSYLVANIA SUn EMPLOYEES CREOrr UNION FORM 13178 ,W)0(0100.1 037-209&1 (SW
SECURITY AGREEMENT
In this agreement all references to Credit Union, we, our, or us means Pennsylvania registration fees) due on the property.
State Employees Credit Union and anyone to whom the Credit Union assigns the Credit If you do not pay the taxes or fees on the property when due or keep it insured, we may
Agreement which will be referred to as the Plan. Ail references to you, your, and pay these obligations, but we are not required to do so. Any money we spend for taxes,
borrower mean each person who signs this agreement. All references to the advance fees or insurance will be added to the unpaid balance of the advance and you will pay
mean the amount in the box labeled Amount Advanced. This is a multi-state document interest on those amounts at the same rate you agreed to pay on the advance. We may
which may be used to lend to borrowers in all states except Louisiana and Wisconsin. receive payments in connection with the insurance from a company which provides the
1. THE SECURITY FOR THE LOAN - By signing this security agreement in the insurance. We may monitor our loans for the purpose of determining whether you and
signature area or under the statement referring to this agreement which is on the back other borrowers have complied with the insurance requirements of our loan agreements
of the check you receive for the advance,. you give us what is known as a security or may engage others to do so. The insurance charge added to the advance may include
interest in the property described in the Security Offered section on the reverse side. (1) the insurance company's payments to us and (2) the cost of determining compliance
The security interest you give includes all accessions. Accessions are things which are with the insurance requirements. If we add amounts for taxes, fees or insurance to the
attached to or installed in the property now or in the future. The security interest also unpaid balance of the advance, we may increase your payments to pay the amount
includes any replacements for the property which you buy within 10 days of the added within the term of the insurance or approximate term of the advance.
advance or any extensions, renewals or refinancings of the advance. It also includes B, NOTICE - If you do not purchase the required insurance
any money you receive from selling the property or from insurance you have on the we may urchase and property nt , the insurance
property. If the value of the property declines, you promise to give us more property insurance will not be charge liability nsur nce and wi I not interest
as security if asked to do so.
any statepfi anc al
2. WHAT THE SECURITY INTEREST COVERS The security interest secures the responsibility or no fault laws.
advance and any extensions, renewals or refinancings of the advance. It also secures g' DEFAULT -You will be in default if you break any promise you make under this
any other advances you have now or receive in the future under the Plan and an other agreement. You will also be in default if you are in default under the Plan. If you are
amounts or loans, including any credit card loan, you owe us for any reason now or default ing property, but have lnot.
ari. signed the Plan, you will be in default if anyone is in
in the future, except any loan secured b defau who hassigned the Par your
principal re household goods as defined s the Federal Trade Commission Credit the ptt es Rule, 10. WHAT HAPPENS IF YOU ARE IN DEFAULT - The following paragraph applies
the property will secure only the advance and not other amounts you owe. to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska 3. OWNERSHIP OF THE PROPERTY - You promise that you own the property or are in default and after expiration of a?ny? ght you (have under appli able state law to
if this advance is to buy the property, you promise you will use the advance for that cure your default, we can require immediate payment of your outstanding balance
purpose. You promise that no one else has any interest in or claim against the under the Plan without giving you advance notice.
property that you have not already told us about. You promise not to sell or lease the The following paragraph applies to borrowers in all other states. When you are in
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 default, we can require immediate payment (acceleration) of what you owe under the
property either by your actions or by operation of law. Plan and take possession of the property. You waive any right you have to demand for
4. PROTECTING THE SECURITY INTEREST - It your state issues a title for the payment, notice of intent to accelerate and notice of acceleration.
property, you promise to have our security interest shown on the title. We may have The following paragraphs apply to all borrowers:
to file what is called a financing statement to protect our security interest from the You agree the Credit Union has the right to take possession of the property without
claims of others. If asked to do so, you promise to sign a financing statement. You ludicial process if this can be done without breach of the peace. If we ask, you promise
also promise to do whatever else we think is necessary to protect our security interest to deliver the property at a time and place we choose. We will not be responsible for
in the property. You promise to pay all costs, including but not limited to any attorney any other property not covered by this agreement that you leave inside the property
fees, we incur in protecting our security interest and rights in the property, to the it that is attached to the property. We will try to return that property to you or make
extent permitted by applicable law. it available to you to claim.
extent USE PROPERTY- Until the advance has been paid off, you promise you will: After we have possession of the property, we can sell it and apply the money to any
5. OF (1) Use the property carefully and keep it in good repair. (2) Obtain our written amounts you owe us. We will give you notice of any public sale or the date after which
permission before making major changes to the property or changing the address a private sale will be held. Our expenses for taking possession of and selling the
where the property is kept. (3) Inform us in writing before changing your address. (4) Property will be deducted from the money received from the sale. Those costs may
Allow us to inspect the property. (5) Promptly notify us if the property is damaged, include the cost of storing the property, preparing it for sale and attorney's fees to the
stolen or abused. (6) Not use the property for any unlawful purpose. extent permitted under state law or awarded under the Bankruptcy Code. The rest of
6. CONSUMERS' CLAIMS AND DEFENSES NOTICE -The following the sale money will be applied to what you owe under the Plan.
applies only when the C
box LAIMS an reverse side is checked. g paragraph 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
NOTICE; ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS advance and to what you owe under this agreement. You agree to pay interest on that
SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD amount at the same rate as the advance until that amount has been paid.
ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED 11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT - We can
WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE delay enforcing any of our rights under this agreement any number of times without
DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR losing the ability to exercise our rights later. We can enforce this agreement against
HEREUNDER. your heirs or legal representatives. If we change the terms of the Plan, you agree that
this agreement will continue to protect us.
7. PROPERTY INSURANCE, TAXES AND FEES - You must maintain property 12• CONTINUED EFFECTIVENESS - If any part of this agreement is determined by
insurance on all property that you give as security under the Plan. You may purchase a court to be unenforceable, the rest will remain in effect.
the property insurance from anyone you choose who is acceptable to the Credit Union. 13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE -
The amount and coverage of the property insurance must be acceptable to us. You THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO
may provide the property insurance through a policy you already have, or through a REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL
policy you get and pay for. You promise to make the insurance policy payable to us AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU
and to deliver, the policy or proof of coverage to us if asked to do so.
MAY HAVE TO PAY THE DIFFERENCE.
If you cancel your insurance and get a refund, we have a right to the refund. If the 14. NOTICE FOR ARIZONA OWNERS OF PROPERTY- It is unlawful for you to fail to
property is lost or damaged, we can use the insurance settlement to repair the return a motor vehicle that is subject to a security interest, within thirty days after you
property or apply it towards what you owe. You authorize us to endorse any draft or have received notice of default. The notice will be mailed to the address you gave us. It
'heck which may be payable to you in order for us to collect any refund or benefits is your responsibility to notify us if your address changes. The maximum penalty for
Jue under your insurance policy. You also promise to pay all taxes and fees (like unlawful failure to return a motor vehicle is one year in prison and/or a fine of $150,000.
_-THE PROPERTY DESCRIPTION ON THE REVERSE SIDE IS PART OF THIS <tRi`s, PWrFUT NnTtc°r. . eram -ruic hl?Q?exti?ar- ncr -rrcr• 114rr' - .r
Pennsylvania State ?Employees'Credit Union ' N"o: 5735600.
• ' • ,•, y,. ' P09.67013 •- N•nrrp,PA 171047Ff7 pr7J 27••Irlf orfaaq 277.7770
AUTOD(iAF7,•,: - VOI VER,4'.14"602tOD.%??7 REFERENCE`.' 8674132538 VOIO1 .200AYS:AFTER>- 10120/2006
r "PAY.TO THE', ? .,r;, ,ir ? ?i: ?? ''I'r /: !r .? •??, .''/,l'i<,: YJ ..
'o110ER Of ID EA RII /J •?; (?: ,''1.; i6 .???;' l :• ?:.
i' - .. .. i • • % /?/ COLLARS t
/' U PORTANri.VOID UNLESS DEALER:ENDORSEMElJT COMPLETED •? MEIASER'FNDORSEMENr: % ? r, : ; , , ,; ..•,%:
B,qu?}Oakes I W S.4'Rnr w Ur0 Wnrinl w lacw*,(meer (w., Vehek,? [l? anda{iinp ?hi? 4uto0iift ;11W apni to th• ierm• IialaA on Ihi r•ren• ,id•~ •
1:0..., p1p _
tnfuiliY AUMI•liBnerJeigKECU Omni AwoDrilt,rMI gj;, ofI *.dI•ft.;Ro1., lit•'th• folbwlna,op•yinent 6lfonne w ',% •?• Y - +
' -nlvri,?.W•rl„ndlheSne,d•rtni A.saWehllrn S:-d 1M Srrn rl!1•??. :.Ji•?/? I. ?•.+'., •. .
u N eny •2,M a tlr Berlw.rld. 7m; AN•Weh :Ila em 4 or Is
Pwdue. : Tmn IMOr,uirt ?Jfl?lelu to 4 Wr - T.ra. r. lh:•M te.r W'oks torn Braelrn. '' .
I,cwtrY[l,d, remrw,l{ d•,d•, tMh,,edrp. e, Red ••,d reNd.. r whlW. M•th k' ? Aae Trr,hr ? mo- .Arp ? Parrs. '?.IA..INr C- 1A 0+.a1 P. -
?','. SYi••wdM Sr UiOW •Idx.: B?': pyo0"Awk;' e11tu lidVY!u qrr ta,,. RKU,rY: -mg.Nv'? MWUMY 0 WWY ?.S<m,. aMMY .
'f?'i W1uin: ir:l en uie ierm r•o.•:. /,'- '•iiBCU FAJU 717.787J7W . ;..,. ,, ;/.r , •, , ,
. iySrS . ?/?. , , r! '!, ' M•mb.r End. -non
ti " ?tit• '
.:•?yl - V .ruw •' •_••?`%• .,?'.ilr.' AL.MF.R .. .
(( Trelya .01 CwApplicant Endor••rtrnt
b V4
.•„? LOKD NO CO-APPLICANT.::
u.'S7.3580011'.,!:23138Li162: 3&024.98009"' 44, r!'00004-0200,0
? ?a JO?Of7 i CJ,:ifYfY7 O.!`3 (it
i?
till
rplill Rift,
tar
E
I c fl=
°ea
a of
"??lBi7r 6-€E9s0
a 0
ODRfa'ig 3x31998 aI a
m='j?s qlg 3
• nCT? x o?E. s ? :
RUM MIT 13301A2?(. . '? V G r. s 33 ~t i
f0? 161557179 m RI
R 1118L M
]'A a Egg fig
mi.
vil f ¢1 I A30
ai
pill 3
s
s? G
Eiat'1 11*1 t•o
?p? F" 0o
t t MONO
300
i??r?•??14o'rn
s•?gsf$?i? ?
Exhibit "B"
PSECO
Pennsylvania State Employees Credit Union
PO. Boy 67013 • Narrisharry. PrA 17106.7013 1 (717) 234.5454 Hatristwi-9. ;15061 247-: i?.ti Natronwr;le
This LOANLINER` Credit and Security Agreement, which includes the Truth in
Lending Disclosures, willbe relenea •o as the Plan. The Plan 'documerits include this
agreement and an Addendum You, your and borrower mean any person who signs
the Plan. Credit union, we, our and us mean PSEGU or anyone to whom the Crean(
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 'advarces') 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 Io,. establish a credit limit on certain
subaccounts. If a credit limit is set for a subaccount, you promise not to exceed the
established credit iimit. If you exceed the credit lima, 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. It the Addendum has no payment schedule for a
subaccount, your payment will be detormined at the lime of each advance.
Payments rnust includo any amount past due and any amount by which you have
exceeded any credit limn 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. It you have a joint
1 sharedraft account. you will be responsible for paying all overdraft advances
obtained by a joint holder of the sharedraft account. Unless otherwise required by
1 law, payments will be applied to amounts owed under the Plan, in the manner the
credit union chooses.
PLAN ACCESS - You can obtain credit advances in any manner authorized by us. If
j we allow you to use your ATM/Debit card to access the Plan, you may be liable for the
I unauthorized use of your ATM/Debit card. You will not be liable for unauthorized use
I that occurs after you notify us, orally or in writing, of the loss, thett, or possible
unauthorized use. it you believe your ATMiDebit card has been lost or stolen,
immediately inform the Credit Union by calling or writing us at the telephone number or
address that appears elsewhere in the Plan. It 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 sharedraft account, your liability is governed by the Regulation E
disclosures you received at the time you received your ATMtDebit 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 i
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 it you have not yet made a payment) is multiplied by the applicable daily II
periodic rate. The surn of these amounts is the finance charge owed. The balance
used to compute the finance charge is the unpaid balance each day after payments
j and credits to that balance have been 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. If the interest rate is a variable interest rate, the i
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 will) 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 statuiory lion on the shares and dividends and, if any, the
deposits and interest in all individual antl joint accounts you have mtn us and may
exercise our rights under the lien to the extent permitted by state law. (We are state
chartered it 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 j
that would lose special tax treatment under slate or federal law if given as securityy.
Additionai security for the Plan may be required at Ine time of an advance. If a
subaccount identifies a type of property (such as "New Cars") you roust g,ve 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 secai ity
acceptable (0 uS when you ob'ain an advance under that Subaccount. Property you
give as security will secure all ;,mounts owed under the Plan and al! other loans yogi
have with us row or in IhF, future, except any .can secures, by your principal d Nchng
Property securing other loans you have wish us may also secre the Plan
f _;A Ari?'Lai l N:" 9:.0 F AIL = z ',b" ;
?. • • ••? - --l .,.o nnv:vi w, un usauimy insurance is optional
under the Plan It you quality for and purchase the insurance from us, you authorize f
us to add the insurance premiums monthly to your loan 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. i
The credtt'nsurance rates may change during the Pian, 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
ail 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 - h this is a joint account, each of you is individually and jointly i
responsible for paying all amounts owed. That means we can enforce our rights
1 under the Plan against any one of you individually or against all of you together. if you I
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 die Plan by giving us prior written
notice. It any of you terminate the Plan, the Plan is terminated for all of you. YOU
remain liable individually and jointly for all advances ncurred 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 our interest in the property , It we
da, the amount of the tee will be discloses 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
I 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 if you do not make a payment of
the amount required when it is due. You will also be in default if we believe the
prospect of payment, performance, or realization on any properly 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 if breaking any promise made under the Plan materially
impairs your ability to repay what you owe or materially impairs the condition, value. 1
or protection of or our right in any property you gave as security. I
The following paragraph applies only to borrowers in Iowa: You will be in
default if you are more than 10 days late in 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. l
The following paragraph applies to borrowers in all other states: You will be in
default if you do, not make a payment of the amount required when it is due. You will I
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 i
the Plan, You will be in default if you die, tie for bankruptcy, become insolvent, if you
make any false or misleading statements m 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 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 i(. You will also be in defaual 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 immediato payment of the entire unpaid balance under the Plan without
giving you advance nonce.
The following paragraph applies to borrowers in all other states except Wisconsin
and Louisiana: When you are in default, we can lequtre immediate payment
tacceterabon) of the entire unpaid baiance under the Plan. You waive any right you have
to demand for payment, notice of inlani 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 mteres- rates in effect or, if applicable,
"?'•'r+' nSECU FORM .3146
?axxrree+-2 037-,0421 19 ?6i
Loan Disclosures
LOANLINER` Credit and Sccurvty_Credif Agreement (continued)
at the dafauit race 7 sciosel on the. Addenaurn. It t s..>nrand for ,mmediate payment
nay been mane, yot.r snares andor Joposrts can Ue applied tor:aros what you ov.e
as provici' d In !'le sectuat above caled "?,LCUnry We can also exercise any other
ngn:s yi -n by ;]w -Amen y.,,j are in d,rfauit
You agree the Credit Ur.on has tl,e right fo take p:;?session of any property given
as security under the P!_rn, without Judicial process, it this can ee done without
breach of the peace If we ask, you promise to deliver the property at a time and
place we i.hoose. 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 ara in
default. 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 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 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.
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, if applicable. at the default rate disclosed on the
Addendum. until that amount has been paid.
The tollowing paragraph applies only to Wisconsin borrowers: Wnen you are in
default and after expiration of any right you have under applicable slate taw to cure your
delauft. 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. If we repossess the property, you agree to pay reasonable expenses
incurred in disposing of the properly If the property is a motor vehicle, mobile home,
trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted
i 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 time of default, we may take
possession of the property without Judicial process, it permitted by the stale 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 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
Addendum. It 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 borrowers in Illinois: 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 following 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 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 I
change applies to existing baiances. i
The following paragraph applies to borrowers in atf 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, wall also
apply to unpaid balances.
The following paragraph applies to aft but Wisconsin borrowers: An increase in
the daily periadic 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 j
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 Pion,
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - Vife can relay ;
u:ilOrc ng any of our rggnts ;-der if, s Plan any number of hires vethOvit losing the i
ability to exercise our rights later. Vic can enfcrca this Pian against your heirs or
legal representatves. It we change the terms of the Plan. you agree that this Plan
vv- C conunae to protect us.
CONTINUED EFFECTIVENESS - If a,,y part of fn's Plan is aeteirn;ned by a court
to be Unerl'oiceable, the rest wail iunia.ri in eilect
NOTICE TO UTAH BORROWERS - Tnrs +, tten agreement is a final expression of
the agreement between you and the Crcdd Ur-on "ri.s wrilten agreement may ,,or
be conlrad;Cled by evidence of any oral agreement.
The following is required by Vermont taw - 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 tD 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
I declines, you promise to give us more property as security it 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. 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.
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 sell or lease the property or 10 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 properly 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 insurance and get a refund, we have a right to the refund. If the
property is lost or damaged, we can use the insurance settlement to repair the
property or apply it towards what you owe. You authonze 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 0 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 comphed 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 I
unpakJ balance of an advance, we may increase your payments to pay the amount j
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 i
company may have given us the right to purchase insurance after uninsured !
collateral is lost or aamaged. The insurance will not be liability Insurance and
will not satisfy any state financial responsibility or no fault laws.
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 i
interest in the property You promise ro 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 exterit permitted by applicable law.
LOANLINER" Credit Arid Sccurity_ CredR Agreement (continued)
USE OF PROPERTY - Until the Advance has been paid off, you pro,n,se you w.11
(1) Use The propeny carefuily ana i;eep it :n good repair. (:) Obtain our wnnen
permission before making major changes to the property or changing file address
where the property is kept. (3) Inform us in wrong before changing your address. (4)
Alloy us to inspect the property. (5) Promptly notify us it the property is damaged.
stolen or abused. (6) Not use the property for 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 trial 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 it 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
i 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
liisted 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
I first appeared regarding any discrepancy or unauthorized transactions on your
account, Failure to notify us may tesuft 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.
It you need more inlormation, 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.
I
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR
WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we
have Contacted the error by then. Within 90 days, we must either correct the error or
explain why we believe the statement was correct,
penalty for unlawful failure to return a motor vu-),01 ;s one year in prison, and or a
tine of 5150,000.
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 pans of your statement that are not in question.
It we find that we made a mistake on your statement, you will not have to pay any
finance charges related to any questioned amount. It 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 550 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, rind you
have tried in good faith to correct the probiern 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 state, within 100 miles of your current mailing address: and
(b) The purchase price must have been more than $50.
These limitations do riot apply if we own or operate the merchant, or if we mailed
you the advertisement for the property or services.
! In this Agreement, the words you and your means each and all of those who apply Line only by written application to us, which must be approved by our credit committee
for the card or who signs this Agreement. Card means the Visa Credit Card and any or loan officer. By giving you written notice we may reduce your Credit Line from time
duplicates and renewals we issue. Account means your Visa Credit Card Line of to time, or with good cause, revoke your card and terminate this Agreement. Good
Credit account with us. We, us, and ours means this Credit Union. cause includes your failure to comply with this Agreement or any other agreement with
1. RESPONSIBILITY -It we issue you a card, you agree to repay all debts and the us, or our adverse reevaluation of your creditworthiness. You may also terminate this
Finance Charge arising from the use of the card and the card account. For example, Agreement at any fine, but termination by either of us does not affect your obligation
you are responsible for charges made by yourself, your spouse and minor children, to pay the account balance.
You are also responsittle for charges made by anyone else to whom you give the S. CREDIT INFORMATION - You authorize us to investigate your credit standing I
card, and this responsibility continues until the card is recovered You cannot disclaim when opening, renewing or reviewing your account, and you authorize us to disclose
responsibility by notifying us, but we will close the account for new transactions it you I information regarding your account to credit bureaus and other creditors who inquire
so request and return all cards. Your obligation to pay the account balance continues of us about your credit standing.
even though an agreement, divorce decree or other court judgment to which we are 6. MONTHLY PAYMENT - We will mail you a statement every month showing your
not a party may direct you or one of the other persons responsible to pay the account. Previous Balances of purchases and cash advances, me current transactions on your
The cards remain our property and you must recover and surrender to us all cards i account, the remaining credit available under your Credit Una, the New Balances of i
upon our request and upon termination of this Agreement , purchases and cash advances, the Total New Balance the Finance Charge due to date,
2. LOST CARD NOTIFICATION - It you believe the card has been lost or stolen, and any other billed fees, and the Minimum Payment required. Every month you must.pay
you will immediately cats the Credit Union at (717) 234-8484 or (800) 237-7328. After at least the minimum Payment within 25 days of your statement closing date. By separate j
hours call (800) 556.5678, j agreement you may authorize us to charge the minimum payment automatically to your i
3. LIABILITY FOR UNAUTHORIZED USE - bu agree to notify us immediate, i share or checking account with us. You may, of course, pay more frequently, pay more
y immediately, era1y, than the Minimum Payment, or pay the Total New Balance In full, and you will reduce the
or in writin unaug of the Loss, thorized theft or unauthorized use of your Credit Card. You may be liable finance charge by doing so. If your monthly payment exceeds the total credit line balance
the use your Credit Card. You will not be liable for unauthonzed use owed we will automatically post the credit to your St shares.
that occurs after you notify us of the loss, theft, or possible unauthorized use. You will have The minimum a ment will be a 21% of I
no lability for unautrorzed purchases made with your Credit Card unless you are grossly ! p y O your Total New Balance, rounded up to the
negligent in the nantl tog of yrour Care. In any case, your liability will not exceed $50. I next even dollar, or (b) S20.00, whichever is greater, In addition, at any time your Total
; New em Balance exceeds your ment f Line, you must im manner fi pay the excess upon our
4. CREDIT LINE - If wo approve yo.rr aeplication, we will establish a sell-
: demand. We will apply payments in the following manner: first to previous late foes. ,
replenishing Lane of Cretin for you and notity, you of its amount when we issue the then to prcwious cash advances finance charges, then to previous purchase finance 1
card. You agree ^ot to let hi) wCoun+ balance exceed th s ipproved Cred Line Each " Charges, then to current late fees. then to previous cash advance balances, then to
payment you make on t e rcc-aur f I re;ion yo.rr r re 1 t Line by re amount of the previous p r chase balances in the orcer that they were posted to your account, them
payment v,hn.r s apple., :_ ,r,3 unn.,ipa: r+JU ?? ay rcyrr , an r6 ns<: it your Credit to current cash a;r:arice ba ances and then to current purchase baiarces.
Visa" Credit Card Agreement and Truth !n Lending Dlsclosure (continued)
7. FINANCE CHARGES - You can avoid the Finance Charge on purchases D
paying the full amount of the New Balance of Purchases each mormh within 25 day
of your statement closing date. Otherwise, the New Balance of Purchases, and IN
subsequent purchases from the dale they are posted to your account, will be subiec
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 monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE
RATE as disclosed on the Addendum.
Cash Advances: We calculate your finance charge on cash advances b)
multiplying the average adjusted daily balance (see explanation below) for cast
advances during the billing cycle by the monthly periodic advance rate anc
corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum.
Balance Computation Method
Ave .age Daily Balance for Purchases - The Average Daily Balance for Purchase
Transactions is calculated by adding the Daily Balances (Purchase Transaction) let
eacri 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 Ina 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 clay. 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 cycte.This gives us the Daily Balance for purchases.
Average Daily 8alarice ku 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 monthly periodic rate for purchases. The
Average Dally Balance is calculated separately for Cash Advances and is subject to the
Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions
Is tabulated by adding the Daily Balances (Cash 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 cash each day. we take the following steps: We take the outstarxiing balance
(all amounts you owe) at the start of the day. Then, in the sequence in which amounts
are posted to you account, we add the amounts of all debits and subtract the amounts
of all Crecifts or payments which post to your account [fiat 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 bilfing cycle. This gives us the Daily
Balance for Cash Advance Transactions. Note: Cash Advances are always subject to
i finance charges and from the day they are posted to your account.
Payments 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 fees, 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 if 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 wilt not apply the Monthly Periodic Rate
to your Account on your next statement
8. DEFAULT-You will be in default if you fail to make any Minimum Payment within
25 days after your monthly statement closing date. You authorize us to transfer funds
Suffxtient to make the minimum payment due if your Visa loan is in default. You will
also be in default it 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 irderest materially declines. We have the right to demand immediate
payment of your full account balance if you default, subject to our giving you arty
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
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 Stales
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 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 i
transaction that is illegal under applicable federal. state. or local law. The monthly i
statement will identify the merchant, electronic terminal of financial institution at
which transactions were made. but Saie, cash advance, credit or other slips cannot I
be returned with [no materent. You will retain a cony of such slips furnished at the
tune of the transaction in order to verify the 'rionoity staternent. the Credit Union may
make a reasonable charge for photocopic, of slip, y<tu 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
j 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 i
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. Tats fee, which totals 1% of the transaction amount, will be assessed on all
transactions where the merchant country di klrs 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 unauthofrzed or Iraudulent use, or your
purchase cost more than S50 and was made from a plan merchant in your state
within 100 mlles of your home, contact PSECU f
14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing j
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 preserve your dispute rights. You may f
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 timefrannes 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. It 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 if you are in
default to prevent withdrawal of your unpledged credit union shares (Deposits) i
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 1
Shares or otherwise, or any other security interests for all your debts, your account {
will be secured by your pledged shares (Deposits) and by the property described in If
those other security agreements, except for your home.
16. EFFECT OF AGREEMENT - 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 by
taw. 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 $20 charge,
18. RUSH FEES - You may incur addmonal charges for rush processing and rush
lelivery of cards ancifor PIN mailer
19. OVER LIMIT FEE -A S20 fee will be applied for each monmly statement closing date
in which the outstanding balance exceeds the assigned credit limit by more than 5100.
>0. DRAFT COPIES - You may incur an additional charge for transaction
¢ummaryisale draft documentation.
H. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement.
!2. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use ;
,our card for any transaction that is illegal under applicable federal, state, or local law.
!3. NO USE - Inactive Visa accounts that have no purchase or cash activity may
ie closed without notice to you after 18 months of no activity. 1
A. NEURAL NETWORK - PSECU uses neural network systems to predict and
irevent unauthorized transactions. There may be occasions when a transaction is
ectined because it is indicative of possible fraudulent activity
6
0
p
n
0
i
?y
F
0
0
v
E
J:
Y
o ;
ro m
M EcoooGOOOGOOG
vOPmn. -O •n -r t_,rv--O Cl QO' OO C' O o
C E Ery. _. .. .. ? POp r. KI U) d rlN..
L C OY
O
? a
L
p C
O. g
O tlOOGQ OOO OOOOGUO GC>jO0U ti
EOO
RhRNOCO AO tV Gap C) tN J,C) J
E Q <t th M;!) M hINNN- co d
N
m
E °
pE
G
Y
V
7 A Z 0
a lL >
Sa O
a c
? m
V
C
u
a O G O Q O p O G 0 0
EC?r..7 ooyt?oaoo?coi ?lo? 0
oc4i,
?38C??agS 0 ?
rr C]QOGO
° C) O: W U Wi -4Ch N •- O ?"Z Cq ck n C,
V ty .._ ._ ._ .._ Q P CO r. •O Wl d' f: C-1 ?i
I a o Q g g g o 0 0
O _ -- O 0° O J s Q O ??
p O U O O Q U O C7 0
Owi cs
d
mpcOP't0 t'- jvri tti .-0
n. .p end MN- "7
0, 00
o o v E
o
a a r. d L) .c
P LLI a s
c O N O r _?
V au x V 5° p
up u d
° V C
y C V Q L G
U V
, c] .7
4; c o y4, 41 j
Oy O ` jl E N 'O
'? ? u o A 3? _!' P o
ro V N u iV C
o c O y c d E:?
y Y ,
U cq€ g o Q 1k $ o
z o ???b ??.e F
`a 0 0 _- v
v _
c3 O L" j ?`.w
",.? o xa e' ? o "" "1
y
o E a ? ° c ? ??! ,o
?-p ?! ° fi V .?Q OC V
Gay1J ,L a'.
EM u.?ro mL ° We
£ p -0 0 c T V
El .0 y
V - u p h
6 'A } a u N O C '?
p. O
C q d C '? ° V N T a °
I-o = urn
-06 7 p'v o
s m _O a c
@7 E E C E v o .c ° o
p y. C C U ._ V
E ?. ae o 3 e a
We v E 41 7
L E.- E
w T a LL O
ZV ... ? a ? O ? 4 'll •? f?
o v a
O V J
[I
y_ H -0 ._ n
r c a U c a.. w v u
Zc _ p
C d p, [Y p
QL ° •4
O2n. u ° ?) E3 or °'
V ? O
.
n" C? u O r 'a C O i)
O 4 r, O
r
w r r
p ro
CO .- 'ti n m u E a,
... .n'. iJ V .° O fJ n.
`
O
O O c
a. N u 4
1. 1i O Z^ --
.- m ? n
A .u U o
•- .f
J O ?' ?' ?Oi C J 18f N •W r` h
F^N ? O uL J m
d, 4L)i
W E
O L] a y .° o
O
C o d V? CL
V
G V
o Q O-
' . y
c
..V 4
M
v -. 3V
N m
E u =q _v c ?
If C C c i
._ c n O`
a"t v= k
.
d .
.u CC C. J 2 ?. O U c w „.0w
c
E O c c z mQ
?'rn E S ?aZ cy
E °pc u u Qu?S c °UDuti E
.Q
E ro t
o ° _
C
E -_ Ij -
?.n ? v
] ..
L w c 00,
p ?-?: o
?
N
N p a` o t
L
r a c u a 4
2 o y , .
Cp m
?
? O 0 0 2 0 'O
0
OF a c
. c u Y E
0 Q, ED U
s
`.. ov s °
??+ u
E u l]. p vE
O E
v -p ? L
O
O U m U. c 3 o E u o w o .? m
~ V V
? E ° °! -E =woU°
.v c Q c ly 0E c a o > a o O
°
O ; uz
W v
b 'Q o
E
ro C. t5
? JD
° 'a V O
GO a.
H
C1 U) .t L ?
y O
so c
C A. N
=0 o o
v_o
a U?
CI p n a.
u ?, co
E
c
o
p 0
g
c a G
- c .£ r)
„ c O
4 T •.n
c a 4
1
7 7
4
a+.?ro
Esoo
4
'C y p l y m P D. '! ? V) P m ?. P ?1 :f. 0, O rw m Y., T^?
.'. a; .t'
a V
? ar
a P M??
r o o vt r, •
s C c
a c a n w? +? + ._ 1. ' Z _. ._ !_ .- 2
u
<
c c
u?
in u
zQEL 'c??oa?o?
'????????
7Ri?
.X •. !'.+t r A ? o
r . R P D,-
r
d? z
?
y -.aa a-od-a
O
? .c EE'S on_°coa_
00
0 Dm.nn.a-o
n
°
u K77 n j _
?
?
0 ..ON
7J00 p
?<` S
S p
p
pp
?OCi C`I $? 00 ,,
5: ????i.
`' ? ?.!
??
?
?
0000 G 00000 0 ?
•. ,1+
c v
o a u
_
LE c eta'-i..,
...
o F
T ? o
o
c
O ?
Y 1 ' z
a
? C ?e,
oa
4 l U _ _
V Y
u
c r)
F a o
O
L
u
b
A
n
o v v 0 ., - j
C1 u y_ N' C C '"ppQ y c -o .D
O 'D c fJ W O L --0 E W N a 10 c
0 C L fj .a d ,^V' C
o a p '> O .a '? c O O- O 00 c ° 0 O o d E 0 W v y
0, -0 c
0
a O ° o u E 0 0 u 0. 3 ^? 3 T p °a o y E? w °? o f c
c CJ
E N V? O y c m o 3 a p;u c c o a>
° 0 o o a o c s ?.u m ?? a> o o E c u T
a a v p a c « p 0 0 -° ya
y ,? p 0 0 0 E c j i 0 t
Z: -o co o 'E -C Z E
o N u° a'sV E 3 m? °..? ? u EU V E- v c a°° c d
H c ° ' y E Q o 3
° y° °T a c c -0 9-0 a o
N n 0 c d a L E o x V a y° 3 Q c O 0 o 6- t: o
T ro L a° tl 0= E? .` O L l! d O S O E 0. 0 u T D
v O y O v 0 O E -0 - O Q _ TJ
E N U j C O N Y N L N a a `q `7 c ° v= y N a O` a[ C y N t y = a
} O O 0 0 w 0 d> c I L O V L; y s c a 0 3 v S c .3 o v o
E o o y 3 `o , r c E_ a 0 , o a o o U u
° o= o 0) = C) cc
o D o cc .o ° E> m E o j o G y o m y° o o i `c ov c °- E -5
a C1. y a 5 -7`?7 a c d o re) M a 'O C O` a c W v a 0 O a °v 0 j O E
O y a `_° O p!^ VY a.0- jM O C ry d v 3 Q-« C QU a.?.u d 0 T'
O r C 1 y °` y= y d O N 0 O M C F- a. C O p C^ t O a T y C -cc -0 n 'O -C c 0 0 y c 0 a] --o m- T a T 2j Q y a a .G V u u 0 U` .C O c >
n v o° `c O °' E v 2 E N Q v
f O^ cos d ow v
v d a `O d- a > v v
0 v 0 o.'s= v .o.a ;
0 0 0 0' m ° 0-0 o a >m ? , <a-60 .0 6'c .t
c N t opa -« E
E o dar L.v a o rn rn o v E 3 c o
d U O a ?! 'D S 0 ?`- "O 0' Y .L '0 6 a` X C 0
! E O. v 0 0 0° L a C 0 O.' o a a cc o. c° c O a 3 s y d w
iliac °:c n .4H° c 0 s°fl>`ov °0~-0 5 an«30 Q ;
'10- E
» o 0 r o '3 m 3 a`r a c v o d c u c o;; 0 v° u° 3 N£ o 0 o L c c
O y r- 0 y E v E °' c c d a = - o °i y. c a$ N v o .y O v
_ o :N cU a? EU o c_-b a 2 °-0a o c c v a a$ g c ucr 0?
3 `c Q w d- 0
° m a v nx ' u 9_ p m 0 O y C 4) J 0 uU- `»: a E c a a- E a
u Q+ a E; y v m a s s 3 L S c v f' c
c o o S o t ° tl a ro y 0 o 0
0 s j p y v U p
s o. v •c M¢ v n y d .E E= : =j :C w 4 s C° v tv o c.
W a ° E
p v CD to Q ? mar ..6 a m o '?.c w E rL- -0 u -0 0 ? a_ c v"ci vti a V a V a $ d o 0 £ °. ?
o °- T - a a 5 ' d > d v v 0 E$ a v E a 0•s a.-'-- ;
J J a U o ?. r.. o« r .n E >. o
t ca!) °cOO 8
a ?
c`ca5og EE4f%
E ? X,
E E c,w
v E a
co4+-c9E >> o?
Eg?2oEC? $c?EE
0 7 u o O vY E 11-2p2 O knocoovP r4 co a°Na_o:: u'1 oVIDI A OLANknNn NdMNOd
> >'$4? d R?<V<'V' _V VNC?Y•f OMMC`7 M__M f?7MCd'1(`7f?7 _M M_(7Mf`7(N')M_
00 °? g u q E E U 666666 666C;6 i 066600 000000 000006
v
220 _?nn O? _ •o` B m 0 `o
o OL O 0 g-? c y. u? O (VM VMd n000,000 000000 OO?NMV ^d^cOP04
U81 ?" 3-. PO1POPPP PPP
is m v t' c2 i$ o a
$ $ pO?.°.cc°xDE gE 8-°5 m
a c >V Cc O
j c°?.g c? • O u c4 >$ p.« a MdMNO dOpV Znco NMRMiAM MMVfdNP O^7nWM
v ?? •..° >> dS«- E PcodhVM O0 '0 kn v(nN^OP a0ndw)lrm MN?-OPP
EE$ C O,c 0 -vp Q+? > hnhhhn nhddd_d _dd dddN N?nh_h 4nN ?nNVyNV_V
-2 E E cc w O• j .? c d m HO 000000 06.00000 00 0000 000000 000060
v m K tl
_ ° 0 0
C °Ir c? ;-°'' o ?-y R J2 a- d?dd?? ?wOO:? r,?r, ,r, °nccoo O ccoocooo ccoo go coo coo ccooP
r !u ac0 F0. oocgNa'
~ tl pt .-gN 2 u;; J O a' O
J Oy '^ amp n p°c Wc°p
o'p?c E > E E ,o w _
e T ococoNcoo,
E u n pw O_ q u u E '^.Op OPn0, cl co C'4OOlrm0 vOd NOdMOco NNPnh(V N cino r, -T odvM? ZoNnMNO
a U M1 E? 00 ° yis u?P H hVlvv vM MMNNN ^70000 OPPPPP cowcococow
V p$ j ,0 A tt. u Op U NNNNNN tVNNC4C4 NNNNNN N^?-^^--
O C K U _ G
c #g•w „pwo ?Yc y?g a 000000 000000 000000 000000 000000
D ?t M >?o >
0 o c c icp0 c0r,d Tv g_O
C a •-NM 7hd no0P0•-N Mv?n OnaO POD--NMV ?ndna°PO
c G? °a0 o O• c ? Clt c MIMMMMM Mmmvvv cvvvvv vvi Vl Nan nu)N?AVId
•?°n MhNNMOU 8 E0
n -a! 2 c r 4'b oE???v c it
`c
0-5 C .? at D F v CnN N v ti O
OooLnr-p
C a u O
d O d t"'^ a D- ,? J V N 0 OOOPNP n?Onn?nv PQ vMODW dN -MMO Nn PMOR
ooO
y? ^ ?+.' c dN vv n e0 .-?n o0.-?n^n.-
n `._ M_{ c g' E ¢c O 0 O 0 OOOMdn M0(O?KN OP mhl d vV)v v MN--OOP cpa°nn 0
S.p v C o -a c 'c OOO?nn n nin Rq-q vM MMMM MMMMMN NNNN(V(V
j c j J 03 0 a y C ?-? 000060 000000 000000 000000 000000
ZO $ yam-iii°E Rc^Uy? p?ac`o
U w V? -NMQ'nd hGOPO^N My NdnaD 0.0--NMQ Vnd n(p PO
--CN NNN 04 NN NNM
n ?
C
T
)
DO t
Y
pp i'll)
.
0
I
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-04476 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE EMPLOYEES
VS
PALMER KRISTY M
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT , PALMER KRISTY M
204 S 16TH STREET
CAMP HILL, PA 17011
NOT FOUND , as to
PER FATHER, DEFENDANT HAS MOVED TO LEWISBERRY (YORK COUNTY). PER
POST OFFICE, MAIL IS STILL DELIVERED TO THIS ADDRESS.,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Not Found ?
So answers
18.00
15.00
.00 R. Thomas Kline
10.00 Sheriff of Cumberland County
5.00
48.00 VAN ECK & VAN ECK
08/19/2008
Sworn and Subscribed to before
me this day of
A. D.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
VS.
KRISTY M PALMER
Defendant
NO. 08-4476 CIVIL TERM
CIVIL ACTION -LAW
PRAECIPE TO REINSTATE
TO THE PROTHONOTARY:
Please reinstate the Complaint with regard to the above defendant in the
above captioned matter.
Date: 101-1 _(A
Respectfully submitted,
VAN ECK & VAN ECK, P.C.
Melissa L. Van Eck, Esquire
Attorney ID No.: 85869
7810 Allentown Blvd., Suite B.
P.O. Box 6662
Harrisburg, PA 17112
(717)540-5406
ILI'
.
C T-I
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2008-04476 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE EMPLOYEES
VS
PALMER KRISTY 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:
PALMER KRISTY M
but was unable to locate Her in his bailiwick. He therefore
deputized the sheriff of YORK
serve the within COMPLAINT & NOTICE
On December 24th , 2008 this office was in receipt of the
attached return from YORK
Sheriff's Costs: So answers:
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kline _
Dep York County 62.20 Sheriff of Cumberland County
Postage 2.07
12/24/2008
VAN ECK & VAN ECK
Sworn and subscribe to before me
this day of
County, Pennsylvania, to
A. D.
?'i rV
^,
?
??? ?
.?
-?,"
:
f r
.,
^.
_ ? '
g` .:,
??? :.7
David D. Bueff
(Prothonotary
Kirks. Sohonage, ESQ
Solicitor
1,enee X Simpson
Ft Deputy 1tothonotary
Irene E. Morrow
2nd Deputy ftothonotary
office of the Prothonotary
Cum6erfand County, (Pennsy(vania
( 9 " J7 "T 91& CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P 230.2
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite 100 0 Carlisle, PA 17013 • (717 240-6195 0 Ta,? (717 240-6573