HomeMy WebLinkAbout08-5374IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES NO. D$ - 53'74 (2ivi l Term
CREDIT UNION,
Plaintiff
VS.
WILLIAM H NELSON JR.
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.
WILLIAM H NELSON JR.
Defendant CIVIL ACTION -LAW
AV I S O PARA DEFENDER
Conforme a PA Niue. 1018.1
USTED HA SIDO DEMANDO/A EN LA CORTE. Si usted desea defender conta la
demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias
despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia
personalmente o por un abogado y archivando por escrito con la Corte sus defenses o objeciones
a las demandas puestas en contra usted. Usted es advertido que si falla de hacerlo el caso puede
proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso
por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado
por Demandante. Ustedpuede perder dinero o propiedad o otros derechos importante para usted.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED
NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA
AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACI6N DE C6M0
CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE
PROVEERE INFORMACI6N ACERCA AGENCIAS QUE PUEDAN OFRECER
SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O
GRATIS.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
Document #: 180057.1
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
VS.
WILLIAM H NELSON JR.
Defendant
NO.
CIVIL ACTION -LAW
COMPLAINT
AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and
through its attorneys, Van Eck & Van Eck, P.C. and states the following cause of action and in
support thereof, avers as follows:
1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution
qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place
of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania.
2. Defendant, William H Nelson Jr., is an adult individual with a last known address
of 117 E Pomfret Street, Carlisle, PA 17013-3315.
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 September 8, 2008, the balance due, owing and unpaid on Defendant's loan
account with Plaintiff is the sum of Eight Thousand Nine Hundred Sixty-Nine Dollars and
50/100 ($8,969.50).
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 One Thousand Two
Hundred Thirty-Six Dollars and 90/100 ($1,236.90) 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,
William H Nelson Jr., in the amount of Ten Thousand Two Hundred Six Dollars and 40/100
($10,206.40), 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: d-?AaA
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
unswom falsification to authorities.
Pennsylvania State Employees Credit Union
By:
Title: ?Jleehl
Date: 11 fl ok
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ADVANCE PROCEEDS VOUCHER
AND SECURITY AGREEMENT
or.n.
Pennsylvania State
Employees Credit Union
P. 0. Box 67013
PSECO 'Harrisburg, PA 17108-7013
717.234.8484
800.237.7328
•
18E ADVANCE, THE OMYSECURIFY FOR THIS ADVANCE IS TM PIEAL PROPMM (N MOST CAMBYOUR HOME;) WENCH VW GAVH AS SEMM WHEN YOUR ACCOUNT
IF THIS IS N orA HOME EQUITY ADVANCE, IN ADDITION TO THE PLEDGE OF SHARES NVY(XUR LOAM NR* cREOITAGREE .. niE FOLLOWNG PROPERTY SECURES THIS ADVANCE.
ITEM PROPERTY r r • yam: . +c`
Wic
Y
1. CHRYSLER OWN & COUNT 2003 2C4GP44L03R222635 SW 16,590.00
2 1
C OTHER
YOU PLEDGE SHARES ANDM DEPOSITS OF S NJ ACCOUNT NUMBER
OLD ACCOUINVLOAN NUMBER A PAYOFF PRNO t W..) OLD ACCOUNTA.CIAN NUMBER B PAYOFF (PRINO.+ INT OLD ACCOUNTA.OAN NWBER FAYOFF (PRNC. + NT4
OLD ACCOUNTMAN NUMBER D) PLAYOFF +INT.) OLD ACCOtWA.OAN NUMBER PAYOFF (PRNC.+ OLD ACCOUNTAAAWNUMBER PAYOFF WRING. + NT.
By accepting the proceeds or by using the hinds 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 receive In the future under the LOANI-INEW Credit and Security Agreement (the Plan) and
any other amounts you owe us for any reason now or in the future in accordance with the terms of the Plan and (2) to make payments as disclosed above In
accordance with the terms of the Plan. ,
O L1N0A BRDIN; w(k at, IK a4 8% a4 9% taco, 01.04. W. AL RRNnB REMIND
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PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM 05173 JYXX0100-1 037-20824 (Bb0)
C
SECURITY AGREEMENT
In this agreement all references to Credit Union, we, our, or us means Pennsylvania
State Employees Credit Union and anyone to whom the Credit Union assigns the Credit
Agreement which will be referred to as the Plan. All references to you, your, and
borrower mean each person who signs this agreement. All references to the advance
mean the amount in the box labeled Amount Advanced. This is a multi-state document
which may be used to lend to borrowers in all states except Louisiana and Wisconsin.
1. THE SECURITY FOR THE LOAN - By signing this security agreement in the
signature area or under the statement referring to this agreement which is on the back
of the check you receive for the advance,. you give us what is known as a security
interest in the property described in the Security Offered section on the reverse side.
The security interest you give includes all accessions. Accessions are things which are
attached to or installed in the property now or in the future. The security interest also
includes any replacements for the property which you buy within 10 days of the
advance or any extensions, renewals or refinancings of the advance. It also includes
any money you receive from selling the property or from insurance you have on the
property. If the value of the property declines, you promise to give us more property
as security if asked to do so.
2. WHAT THE SECURITY INTEREST COVERS - The security Interest secures the
advance and any extensions, renewals or refinancings of the advance. It also secures
any other advances you have how or receive in the future under the Plan and any other
amounts or loans, including any credit card loan, you owe us for any reason now or
in the future, except any loan secured by your principal residence. If the property is
household goods as defined by the Federal Trade Commission Credit Practices Rule,
the property will secure only the advance and not other amounts you owe.
3. OWNERSHIP OF THE PROPERTY - You promise that you own the property or
if this advance is to buy the property, you promise you will use the advance for that
purpose. You promise that no one else has any interest in or claim against the
property that you have not already told us about. You promise not to sell or lease the
property or to use it'as security for a loan with another creditor until the advance is
repaid. You promise you will allow no other security interest or lien to attach to the
property either by your actions or by operation of law.
4. PROTECTING THE SECURITY INTEREST - If your state issues a title for the
property, you promise to have our security interest shown on the title. We may have
to file what is called a financing statement to protect our security interest from the
claims of others: If asked to do so, you promise to sign a financing statement You
also promise to do whatever else we think is necessary to protect our security interest
in the property. You promise to pay all, costs, including but not limited to any attorney
fees, we incur in protecting our security interest and rights in the property, to the
extent permitted by applicable law.
5. USE OF PROPERTY- Until the advance has been paid off, you promise you will:
(1) Use the property carefully and keep it in good repair. (2) Obtain our written
permission before making major changes to the property or changing the address
where the property is kept. (3) Inform us in writing before changing your address. (4)
Allow us to inspect the property. (5) Promptly notify us if the property is damaged,
stolen or abused. (6) Not use the property for any unlawful purpose.
6. CONSUMERS' CLAIMS AND DEFENSES NOTICE - The following paragraph
applies only when the box on reverse side is checked.
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS
SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD
ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED
WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE
DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR
HEREUNDER.
7. PROPERTY INSURANCE, TAXES AND FEES - You must maintain property
insurance on all property that you give as security under the Plan. You may purchase
the property insurance from anyone you choose who is acceptable to the Credit Union.
The amount and coverage of the property insurance must be acceptable to us. You
-nay provide the property insurance through a policy you already have, or through a
)olicy you get and pay for. You promise to make the insurance policy payable to us
ind to deliver the policy or proof of coverage to us if asked to do so.
registration fees) due on the property.
If you do not pay the taxes or fees on the property when due or keep it insured, we may
pay these obligations, but we are not required to do so. Any money we spend for taxes,
fees or insurance will be added to the unpaid balance of the advance and you will pay
interest on those amounts at the same rate you agreed to pay on the advance. We may
receive payments in connection with the insurance from a company which provides the
insurance. We may monitor our loans for the purpose of determining whether you and
other borrowers have complied with the insurance requirements of our loan agreements
or may engage others to do so. The insurance charge added to the advance may include
(1) the insurance company's payments to us and (2) the cost of determining compliance
with the insurance requirements. If we add amounts for taxes, fees or insurance to the
unpaid balance of the advance, we may increase your payments to pay the amount
added within the term of the insurance or approximate term of the advance.
8. NOTICE- If you do not purchase the required property insurance, the insurance
we may purchase and charge you for will cover only our interest in the property. The
insurance will not be liability insurance and will not satisfy any state financial
responsibility or no fault laws.
9. DEFAULT -You will be in default if you break any promise you make under this
agreement. You will also be in default if you are in default under the Plan: If you are
pledging property, but have not. signed the Plan, you will be in default if anyone is in
default who has signed the Plan.
10. WHAT HAPPENS IF YOU ARE IN DEFAULT - The following paragraph applies
to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine,
Massachusetts, Missouri, Nebraska, South Carolina and West Virginia. When you
are in default and after expiration of any right you have under applicable state law to
cure your default, we can require immediate payment of your outstanding balance
under the Plan without giving you advance notice.
The following paragraph applies to borrowers in all other states. When you are in
default, we can require immediate payment (acceleration) of what you owe under the
Plan and take possession of the property. You waive any right you have to demand for
payment, notice of intent to accelerate and notice of acceleration.
The fallowing paragraphs apply to all borrowers.
You agree the Credit Union has the right to take possession of the properly without
judicial process if this can be done without breach of the peace. If we ask, you promise
to deliver the property at a time and place we choose. We will not be responsible for
any other property not covered by this agreement that you leave inside the property
or that is attached to the property. We will try to return that property to you or make
it available to you to claim. ,
After we have possession of the property, we can sell it and apply the money to any
amounts you owe us. We will give you notice of any public sale or the date after which
a private sale will be held. Our expenses for taking possession of and selling the
property will be deducted from the money received from the sale. Those costs may
include the cost of storing the property, preparing it for sale and attorney's fees to the
extent permitted under state law or awarded under the Bankruptcy Code. The rest of
the sale money will be applied to what you owe under the Plan.
If you have agreed to pay the advance, you will also have to pay any amount that
remains unpaid after the sale money has been applied to the unpaid balance of the
advance and to what you owe under this agreement. You agree to pay interest on that
amount at the same rate as the advance until that amount has been paid.
11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT - We can
delay enforcing any of our rights under this agreement any number of times without
losing the ability to exercise our rights later. We can enforce this agreement against
your heirs or legal representatives. If we change the terms of the Plan, you agree that
this agreement will continue to protect us.
12. CONTINUED EFFECTIVENESS - If any part of this agreement is determined by
a court to be unenforceable, the rest will remain in effect.
13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE -
THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO
REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL
AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU
MAY HAVE TO PAY THE DIFFERENCE.
f 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
xoperty 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
xoperty 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
lue 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.
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION CASHIER'S CHECK
Mailing Address:'
P:O: Box 87013
32
HARRISBURG, PA 171087019
DATE
08/11/2006
fsf .: f ..`,`•.% t'!:'?'i: vi' J,' %'` ra , j' , " Y.. $; '116.59D.00' v
"SIXTEEN THOUSAND FIVE 14UNDRA6lkrN TY DOLLARS AND 00 CENTS
TO.TrE
:.ORDER" WILl1AM NELSON PENNSYLVANIA STATE
•' ? I'• ?i /, - _ BAPLOYEESCREDIT UNION . ±''1, r' '`i.;•' .
i'•OF .',, . f'i 1:-`? is `.:
AND NARRISBURQ HYUNDAI'S VOID;AFTER'k DAYS,' ^.nr.. +?•'°'t
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AMENDED LOAN SECURITY AGREEMENT
The background of this security agreement Is as follows:
On 8/1112006, WILLIAM NELSON (debtor), Account # _ borrowed a sum of $16590
from the Pennsylvania State Employees Credit Union (PSECU), as evidenced by a loan
agreement executed by debtor dated 8/11/2006. Said loan was to finance the purchase of the
following motor vehicle which debtor pledged as security for said loan.
Year. 2003 Make: CHRYSLER Model: TOWN & COUNTR
Manufacturer Serial #: 2C4GP44L03R222635
Said vehicle was not only titled in the name of debtor, but in fact, was titled in the name (s):
TARA WENGREZN =.,
All parties must sign this security agreement.
This agreement Is given to perfect the Interest of PSECU In salt vehicle, as previously agreed to
under the LOANLINER® security agreement and the parties hereto agree to be bound by the
terms of the Security Agreement executed by the above named debtor, which security agreement
Is Incorporated herein by reference.
IN WITNESS WHEREOF and Intended to be legally bound I/We have set my/our hand and seal.
All prior named must sign this security agreement
Date
WILLIAM NELSON (Debtor)
Date
TARA WfWGRE99
Wenrzyp
Date
Exhibit "B"
PSECO# Penns ylvania State Em ployees Credit Union
. 7 P _, c;°J*:r w ri: r _•, -. PA w ,7 1;) 234.5494 hvrsc nucl ,8;00:
Loan Disclosures
SECURITY AGREEMENT.-
LOANUNER' CREDIT AND
I LOANLINER' Cr.-(,;t and Secunry Ay eeme•u. ,vn,ch cluces 'he 'r,th ;n CREDIT INSURANCE - +ed ++ :., ,:, c r . _ Ji. saU''iTy ?_• ritncu rs at;t, T.ii
Le;ndi-ig Disclosures. wiii be referred to as the Plan the Plat: u,rca.rrenT_S ncl:rde this under !tie Plan If you qua y rat a:= z ,,urcr:rsf, t us:.ranee i(orn ut you authorize
agfeernert and art Add3•tdurr You, your .,ld borrower mean an, :; tfSt,a r.ha $,QriS :;S to ado '.1.6 "rif"wance pre li-r.lb 'r,nt^N to yo +r liar bala,v, a and chargr yr'u
the Plan Credit union, we. Our am us - ear ;";EC .; Or 'inyor, ,.t ^ t. the "rieirt rater si Or the entue ba :nce If you _ i,,.: CtCJ.f n? riince. your payments may
',Trion irar,sters its r1]MS un!1er the Plar "I';rease or tn8 ;,eri•yl it Itme ne-_essary to r?p,fy yn:; r advance may be extended.
HOW THIS PLAN WORKS - Tft s is jr, open er,,, n:a ,i-featured cm jit piar t::; yt'e :tech nsurarice rates atay :nange dt.ong t"a P::in. If the rates change, we will
anticipate that, from ire to tirre, vc•u r. barrow money fcai eo 'a-fvar ,r s"1 unmet provide any nruees rf:C,uired by applicaUle, law
the Plan, We are not required to make advances to you under the Plan and can PERIODIC STATEMENT - On a regular oasis you v:i3 receive a statement snowing
refuse a request for an advance at any time. The Addendum describes the all transactions under the Plan during the period covered by the statomr;nl
different types of credit Icafled'subaCcounts'j available under the Plan, the current Statements and notices will be rent to you at the most recent address you nave
interest rate for each subaccournt expressed as a daily periodic rate and given us in writing Unless applicable law requires uauce to each joint b)rroAer,
correspording annual percentage rate and oOor charges. $1 may also have other j notice to any one of you will be notice to all.
terms and a schedule for determining the payment amounts. j JOINT ACCOUNTS - If this is a joint account. each of you is individually and jointly
CREDIT LIMIT - We may, but do not have to, establish a credit fimit on certain i responsible for paying all amounts owed. That means we can enforce our rights
subaccounts. If a credit limit is set lot a subaccount. you promise not to exceed the ; under the Plan against any one at you individually or against all of you together. if you
established credit limit. It you exceed the credit limit, you promise to repay ' give us inconsistent instructions, we can refuse to follow your instructions. Unless our
immediately the amount which exceeds the credit limit. i written policy requires all of you to sign for an advance, each of you authorizes the j
REPAYMENT - You promise to repay all amounts you owe under the Plan plus r other(s) to obtain advances incirvidually and agrees to repay advances made to the
interest. Payments are due on the last day of the month unless we set a different day other(s). Any pint accountholder may terminate the Plan by giving us prior written
at the time of an advance. If the Aadencl;m has no payment schedule for it notice if arty of you terminate the Plan, file Plan is Terminated fur all of you Yoa
subaccount, your payment will be determined at the lime of each advance. ? remain liable individually and jointly for alt advances iccuried before termination
Payments must include any amount past due and any amount by whir;n you have i. FEES AND CHARGES - It you give us a serurity interest in certain types of
exceeded arty credit time y'ou `cave !?aen giver, far a Subaccaunt YOU may repay, au properly, wf may charge you a fnir.q foe to perfect our interest in the property if we
or part of what you awe at any time wrtnout any prepayment penalty. Even If YOU do. the amount of the tee will be disclosed to you at the time you obtain an advance.
prepay, you will still 'lie required is make the regularly scheduled payments unless We may also charge you ofnei fees in connection with the Plan. Our current leas ate f
we agree in writing to a cnanigo in Tne payment schedule, if you have a jorill disclosed on the Addendum and wilt be added to your foan patance unless you pay
sharedraft account, you will be responsible for paying all overdraft advances them in cash
obtained by a lout holder of Gte snaredra t account. Unless otherwise required by ' UPDATING CREDIT INFORMATION - You promise that you will promptly give us
law payments will be applied to amoums )wild under the Plan, in the manner the i w7inen notice if you move, change our name or em
Credit Union Chooses. Y your employment, or it any other '
information you provided to us changes. Upon our request, you also agree to
PLAN ACCESS - You can obtain credit advances in any manner authorized by us. It provide us updated financial information,
we allow you to use your ATMiDebit card to access the Plan, you may be liable for the DEFAULT - The following paragraph applies to borrowers in Idaho, Kansas, t
i unauthorized use of your ATMiDabit card. You will not be liable for unauthorized use I
that occurs after you notify us• crafty or in writing, of to loss, theft, or possible ! Maine and South Carolina: You will be in default if you do not make a payment of t
the amount required when it is due. You will also be in default if we believe the
!
unauthorized use. It you believe your ATMs Debit card has been lost or stolen,
immediately inform the Credit Union by calling or writing us at the telephone number or prospect of payment, performance, or realization an any property given as security ;
address that appears elsewhere in the Plan, If the card is used to obtain unauthorized 1 is sfgnificanttyrmpaired.
advances directly from the Plan, your liability will not exceed $50. It the unauthorized The following paragraph applies only to borrowers In Wisconsln: You will be in
withdrawal is Iron a sharearaft account, your liability is governed by the Regulation E , default it you fail to make a payment when due Two times during any 12 month
disclosures you received at the time you received your ATM/Debit card. even if the period You will be in default It breaking any promise made under the Plan materially
wftliarawaf resutts in an advance being made from your overdraft subactlaurti impairs your aridity K: repay what you owe or rrraianauit, impairs the csnd,non, >ruue
FINANCE CHARGE - Tne collar amoi,m you pay for .^toney bornwee ca .ea a nr protection of at our right in any prapony Yo' gave <'=s sfcurity if, "finance charge- and begins on ;ne clads of sacn advance A finance chargo vill be The following paragraph applies only to borrowers in Iowa: You will ti<i in
cemputea separately for each saparwe balance under the Ran, To comp i!e trie default if you are more than 10 days late in mak:nq a payment You will also be, in
finance cr:argc, Ote unpael tfaiance for each clay :;tnctt your last pa`frTlent (or since default if you ao flat comply wilt, the terms of ?he Pi;tn and your failure to comply
an advanco if you have riot yet made a payfner"I is multiplied by the app Fcabie. daily ! materially impairs any property you gave as so curdy of your ability !o repay what you
periodic rate. The sum of these amounts is the tirance charge owad. Tile balance owe under the Pout. '
used to compute the finance charge is the unpaid balance each day alter payments i The following paragraph applies to borrowers In all other states: You will be in i
and credits to that balance have been subtracted and any additions to the balance default if you do not make a payment of ire amount requited when it is due. You w01
have been made. In addition to interest, we may Charge other finance charges which 1 be in default if you break any promise you made under the Plan or if anyone is in
are disclosed on the Addendum. N the vilemst rate is a variable interest rate. the ! default under any security agreement made in connection with an advance under i
Addendum explains how the variable inierest rate works f the Plan. You will be in default if you die, file for bankruptcy, become; insolvent, it you
SECURITY - You pledge as security for the Plan all shares and dividends and, i'' any, I make any false or misleading statements in any credit application or update of credit
all deposits and Interest in all joint and individual accounts }roll have wan us now and information, or it something happens we believe n:ay substantially reduce your
in the future. if a specific dollar amount is pledged for an advance, we will freeze f ability to repay what you owe. You will be in default it any property you have given
shares in that account to the extent of the outstanding balance for the advance. 1 us as security is repossessed by someone else. seized under a forfeiture or similar
Otherwise, your pledged shares may be withdrawn unless you are in default The i law, or if anything else happens that significantly affects the value of the property or
following paragraph applies in all states except in Ohio, Rhode island and our security interest in it. You will also be in defaa:lf under the Plan it you are in default
Massachusetts: We have a statutory lien on the shares and dividends and, if any. the under arty other loan agreement with us.
deposits and interest in all individual and joint accounts you have with us and may ACTIONS AFTER DEFAULT -The following paragraph applies to borrowers in
cercise our rights under the leer TO he eaten ,)ermined try st a e paw Nve " e stafaf
Colorado. if o u name do es not 1 r.`ua hertn "F.aeral C.rc at ,/nion. ) For all . District of Columbia, Iowa. Kansas. Marne, Massachusetts, Missouri.
borrowers: The statutory lien and/or your pledge will allow, us to apply the funds Nebraska. South Carolina and West Vrrgrnia 1JI f yce u n oatauif and -rttvr
in your account(s) to what you owe when you are in default. 7"he 5tahrt.,ry V 'pirat nt. of any r gt.t you rave ,iijcr i,pi r ap.v tt aw cure }our otaUlt we hn
lema i n l EMi tE pa-/mC L c"i ti,i% , rOr under !nil Plan vtn)id
your t if ?;f c3 not a? Np :nil lm Yva i RE f- t we. t A onn of a Y i r
rptaig t ] 1 GJVdr.'.f not ra.
bl a ,t :rd OS Spec el -ax :r a of : u has r - it , c r 1;-.w if c, c. e ..i.t,
IMra 1 arl The following paragraph applies to borrowers in all other states except Wisconsin
A al L et i tic +iny iH it P. ',n rr- 1 i e ,? ?'- C7 a:J ff it n
i a +ii, nr
and Louisiana: tJY: r re n '•4
re i a.re cdiafe p<+y Went
(.. "clot Il a. -Cc '0 .: till t ft 1.. Of iP t rc ,, 4 c1 "::. u )r e yt t y r qht y,,. ,.,.:e
tyi. .: ! o'a a' e7T . as SecUnfy vita Ju ra
? 7v i t . ? ih.rt .n•:'<x r.,tt n. r,. act e . + .,. , ..i .. , ..a i tr...... ,:, ca o a,-:,e;t:rat,nn
so haccount came such :1S 0'ne!
aceept.:, a1., ro us v: ho" yeti ihh Tair an „r1 v: nw.:- ",inner p,a i.it;.7: co,i^f F rc i...t ;, the following paragraphs apply to borrowers in all states except Wisconsin and
give as sect wy y 1e sL!Cure all anlOUntS ew,d irt: the P an and ail ether o..,,,, is : Louisiana: If imrred :fie pat. :r..., ,ou r ,alit to pay in!eras: emir
nave w'itn us row fir :n rte lu'ute, (-/ )f ,i ',iln se "arc' o Ir 7+ 11,^.i,^. 91 w.::• ir,it rut you : ,e .':its bei:n rep-,:t1 a* fit! o:ect nr..f
Property securing diner'oar.s you rave !tt, us may also set-ire The Pian
. 1.', ... ,.; 'x ,i, ;. .._ ...: (':,::.err :,; . ?ri,r:u •.,•.i <;
LOANLINER'_Credit and_SocuM Credit Agreemunl (continued) abdity !n eyorciso our rights tine+. We can enforce this Plan aca,no yr,;;r r ,r> er
at the default rate dscloseo o .tie addendum If a demand !or :mm.ediwe payment legal reprdser4lal ves. 11 vie change ibe leans of the Ptein you ;l1le8 Ilial t -. I' an
has been maoe, your s!tlres and'or deposits ran tie dip 'led :c-wares What you ova oil! continue. to protect US
as provided :n the ser,tion at>;ve caned `Sec.,rty W-3 can a;sc, ex:=n any Wr er CONTINUED EFFECTIVENESS - If ary part r y .:c
nghts given by law v.hen you are n Jafawt to be Uner•,iorceao;r the rest war iorn,-wt in effect
You agree the Great i tiat has the nq r rc, :axe ;, cc lion •:} anY pill:. r,y griesr NOTICE TO UTAH BORROWERS - `pus an:'Fn a,,f ; . to a f. nat eypre,S ^r rd
as .e(.'C":I ti„der !^e P'an, pros :.s. 'f Cis Car, Ur do".a v; oho-: tie agreement berwean y0U and Inc lire,-: Uri in. -!uS 'written :Iwei l'lgii! rl . V •N)!
ma i ol the pvaze. It 'va as,. you pr!:r_ise to deliver lie property at a Urn:! and ? be contrnd-Cted by ewdenue of any oral agrec-rrEnt
pl;a:;e ,4c• choose, if the properly is a motor vehicle or mat. yot. agree that we may The following is required by Vermont taw -NOTICE TO CO-SIGNER -YOUR
:era in
ocher daes r.eces
opera:e
you
stain a Bey
o
p
!'? ! SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE
e lot
it not
r no
any y
for e
r
other
not covered
by
his
..
t, ,,
, IF THE BORROWER DOES NOT PAY
FOR REPAYMENT OF THIS LOAN
at you leave insfie side ino
is attached to the e p(uperty W we
properly c
a Int+ s :
Agreement,
,
,at
.
,
will try to return that property to you or make it available for you to claim. THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU.
After we have possession of the property we, can sell it and apply the money to any The following paragraphs apply it you give security in connection with an
amounts you owe us. We will give you notice of any public disposition or the date after advance under the Plan. They appty to borrowers In all states except Louisiana.
which a private dfsposition will be held. Our e+rpenses for taking possession of and Louisiana borrowers will execute a separate security agreement. Borrowers in
selling the property will be deducted from the money received Irom the sale. Those i other states may also be asked to execute a separate security agreement.
costs may include the cost of storing the property, preparing it for safe and attorney's THE SECURITY FOR THE PLAN -You give us what is known as a security '
tees to the extent permitted under stale law or awarded under the Bankruptcy Gods.
interest in all property described in any receipt, voucher or other document you
You must pay any amount that remains unpaid after the sale money has been applied receive for an advance ('the Advance'). The security interest you give includes all
to any unpaid balance under the Plan. You agree to pay interest on that amount at the accessions. Accessions are things which are attached to or installed in the property
same rate as the advance. or, if applicable, at the default rate disclosed on the I now or in the future. The security interest also includes any replacements for the,
Addendum, until that amount has been paid. 1 property which you buy within tU days of the Advance pr any extensions, renewals
The following paragraph applies only to Wisconsin borrowers.: Wren you are tr or refinancing of the Advance It also includes any money you receive from y?:ii:nq
default and after expiration of any right you have under applicable state law to cure your j the properly or 'rpm. insurance you hate on cite property. It the value of the property ,
default. we may require ormodiate pay'-le-1 01 your outstanding loar balance Under the declines, YOU promise to give us tnO1F, pfi.pe Yly as S(sGUt Its :( asked to do so,
Ptah and seek possession of property given as s>ri,nryYou stay vniuntaNy give ute WHAT THE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS
property to us if you choose, :r we may see', to take possession o! the property cy - The security mtcre st secures the Advance: described in the recotpt, voucher or any ,
judicial pn?ress. It we repossess file ptorkirty, you agree to pay reasonable expenses other OOCurnent you receive at the time of the Advance and any extensions, renewals
incurred in disposing of the properly If the property is a motor vehicle moolle home, or refinancings of the Advance. It also secures any other advances you have now
trailer, snowmobile, boat or aircraft, you '.vifl air z off required to pay any costs perm tied or receive in the future under the Plan and any other amounts or loans,
by Section 422.413 of the Wsconsin Statutes You must pay any amount that remains including any credit card loan, you owe us for any reason now or in the future,
I
unpaid after the sale money has been applied to what you owe under the Plan. You
or
if
agree to pay interest on any unpaid amount at the same rate as the advance 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 ,
applicable, at the default rata disclosed on the Addendum, until that amount is paid. property will secure only the Advance and not other amounts you owe
If the property Is located outside Wisconsin at the time of default, we may take ( OWNERSHIP OF THE PROPERTY - You promise that you own all property you
possession of the properly without judicial process, it permitted by the state where give as security or it the Advance is to buy the property, you promise you will use j
the prop" is located.
the Advance for that purpose. You promise that no one else has any interest in or i
The toliowfng paragraph applies only to Louisiana borrowers: When you are in claim against the property that you have not already told us about. You promise not
default. we can require immediate payment (acceleration) of the entire unpaid to sell of lease the property or to use it as security for a loan with another creditor ;
balance under the Plan. You waive any right you have to demand for payment, notice until the Advance is repaid. You promise you will allow no other security interest or
of intent to accelerate and notice of acceleration. if immediate payment is lien to attach to the properly either by your actions or by operation of law.
demanded, you will continue to pay interest until what you owe has been repaid at
property
PROPERTY INSURANCE, TAXES AND FEES -You must memtain
the applicable interest rates in effect unless a default into is disclosed on the i insurance on all property that you give as security under me Plan, You may purchase
Addendum. It a demand lot immediate payment has been made. the shares and :he property insuraru a from anyone you choose who is acceptao'e to the Grat7;t `
deposits given as security for the Plan can be applied towards what you owe. We .? anion The amount and coverage of the property insurance mc,st tro acceptable to
can also exercise any Other rights given by taw when You are in deleuit anti our us. You ma iovide the insurance inrou h a ou airead have it
y p property 5 policy 1' Y
tights under any security agreement=_ you haviA wdh us
CANCELLING OR CHANGING THE PLAN -The fallowing paragraph applies through a policy you get and pay for. You promise to make the insurance polity
payable to us and to deliver the policy or proof of coverage to us if asked to do so.
only to borrowers in Illinois: Wtd navy me tight to charge the terms of the Plan from
h
i
A
d
l f If you cancel your insurance and get a refund, we nave a tight to the refund. It the
e
time to time after giving you any advance not
ce require
ny change to t
by
aw. property is lost or damaged, we can use the insurance settlement to ripe r the
interest rate or other charges will apply to future advances,
property or apply it towards what you owe. You authorize us to endorse any draft or
The following paragraph applies only to borrowers in Wisconsin: We can check which may be payable to you in order lot us to cofioct any refund or benefits +
'
change the terms of the Plan from time to time in accordance with Section 422.415 .
due under your insurance policy. You also promise to pay all taxes and fees (tike
of the Wisconsin Statutes. You will be notified of any change in terms An increase f registration fees) due on tt-:e property.
! in the daily periodic rate under a variable rate interest rate is not considered a
If you do not pay the taxes or fees on the property when due or keep it insured. we may
change in terms under the Plan. We can cancel the entire Plan or any part of the pay these obligations, but we are not required to do so. Any money we spend for taxes.
Plan at any time. You may cancot the Plan at any time by giving us prior written 1 Or tnsutartce will be added to the unpaid balance of the advance and you will pay
notice. Your obligation to pay the unpaid balances under the forms of the Plan I
I
continues whether you or the credit union cancel the Plan, except to the extent that interest on those amounts at the same rate you agreed to pay on the advance. We may i
your liability is limited by Section 422.41 SS of the Wisconsin Statutes. rocerve payments in connection with the insurance from a company which provides the I
insurance. We fray monitor our loans for the purpose of determining whether you and
The following paragraph applies only fo borrowers in Iowa: We can change the ocher borrowers have compiled witn the insurance requirements Of our k,an agreements
terms of the Plan from time to time after giving you any advance notice required Oy or may engage others to oo so The rrtsuraace charge adoed IQ an arJuance May :nu,,de
law. A Change that increases the rate of finance cnafge or other charge.. that ; t 1 the insurance companys payments to us ano 4} the cost of determining cornpi.ance
increases the amount of your payments. or that otherwi se. adversely alfnr.S evsiirtg with the insurance requirements. It we add amounts tail wim-,.. fees or insurance to he
batanceS will apply to e.xlsnng balanLtiS only 1 you sgiee to in. rn<tnge or you use . •pa a ba'ar;Ce of an advance, we may increase your payn,on!s to say the ar..ount
the Plart :after receiving noti(12 that y+. or u5G of y Plan means you agree v added w0im the term of the insurance Or 1pp1Oxin1a!P lean of the advance
change applies to ex.stng bounces
The following paragraph applies to borrowers in 311 other stares: rile nave tf`e INSURANCE NOTICE - If yru do riot purchase ,tie re,li-red property insurance.
the insuranco we may pufcha.e and charge Vol, for wd+ c. ?;t;•r only o..r jnte.rsl r the
nghl to change the terms of the Plan 0r0:'t time io tirre ;tier giving y0U : y w,,aw-t? property. The premium :or [h:'::nSUranCt may or. !:.finer tic :auSe ire insurance '
notice required by law. Any change in tn•? interest rate will apply to future ad mnces. _ company may have given us the right to purchase insurance after uninsured
and at our discretion and subject to. ary requirements of aDphcil ie taw, w1l also collateral is lost or damaged. The insurance will not be liability insurance and ,
apply to unpaid balances. wiff not satisfy any state financial responsibility or no fault laws.
The following paragraph applies to all but Wisconsin borrowers: An increase in PROTECTING THE SECURITY INTEREST - If your slate issues a title for the
file dais periodic rate under a variable interest rate is not considered a change in property, you promise to have our security interest shown on the title We may have
farms under the Platt, We can cancel the entire Plan Or any part of the Plan at any to file what is called a financing statement to Urolec: our security intares: lmri the
time. You may cancel the Plan at any time by graving us prior written notice Your claims of others it asked to do so, you promise to s:gri a financing statement you
obligation to pay me unpaid balances under the terms of the Plan continues whether also promise to do whatever else we think is necessary to protect Our Socurlty
you or file Credit Union cancel the Pian,
interest in trie praper;y You promise to pry al! sts, :ncludlnC Cul not ltmileo tc, af,y
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN -Vile can delay attorney fees, we incur in protecl,ng our security interest and rights :r the procerty.
entorring arty of out tights order lh,S P'an arty nU.mbrr of tmi;s vnlhoiA losing the to the extent porniltled by ap pbcab e Ia&
LOANL/NER' Credit and Sect r{t?_ Credit AAgrecment fcnntinucd)
USE OF PROPERTY -' i' ne 1av,an e f ." t, r p..t:.? o°• :cu pto n se y,;:, V..'11,
Ill USe ,. e prop rri carefa.'-. an:7 +«. '10-31 rc;..;r ,L,) OL:a.n our r;nnes .
par^res.on before e•akr,.g n agar c.^.<in.,ie.s to :he t rr,>..rty or t.han9:nr? ;rte .rddre?s
nhrre- :property korit :.vi its... r,. •-gig. clone zraryv,y y: ,r d,]J!_,.
A,lo•:i u' A inspect tae pr ,p erty i,5. PI3Inp:`1,' 'i0l.iy l,> J the pruua'rtV Is C!ara(lep
Stolen or abused. !Si Ncr use the property `cv any uniawr„' I.urpJ •: t71 Not to reIrie
property in another <.tate wilt0ut i19nrg us. '
i
NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE
- THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO i
REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, 1
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 i
to return a motor vehicle that is subject to a security interest, within thirty days after ,
you have received notice of default. The notice will be mailed to the address you
gave us It is your responsibility to notify us it your address changes. The maximum
This novice contains important Information about your rights and our responsibilities
under the Fair Credit Billing Act You are advised to read your monthly statement
and rev ew 4 far any error discrepancies or unauthorized trarsacticns.
NOTIFY US IN CASE OF ERRORS OR OUESTIONS ABOUT YOUR
STATEMENT. It you rhink your statement is wrong. or it you toed mare Information
j about a transaction on your statement, write us on a separate sheet at the eodress
listed on your statement You are required to notify us in writing within 60 days
following the date on which we saril your statement wherein the error or problem
first appeared regarding any discrepancy or unauthorized transactions on your
account. Failure to notify us may result in your acceptance of any responsibility for
payment or reimbursement to us for any such error or discrepancy on your account.
Write to us as soon as possible. You can telephone us, but doing so will not
preserve your rights.
In your letter, give us the following information:
Your name and account number.
The dollar amount of the suspected error.
Describe the error and explain, if you can, why you believe there is an error.
it you need more information, describe the item you are not sure about,
It you have authorized us repay 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 loner most reach LS three business days before the
automatic payment is scheduled to occur
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR
WRITTEN NOTICE • We must acknowledge your tenet within 30 days, unless we
have corrected the error by then. Within 30 days. we mu;it either correct the error or
explain why we believe the statement was correct.
pennity for unlamul : Aurv r u mot"r u r ul .• .5 w',. .rt Pr a," i 7,r a
I.ne 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 ary 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 limil. You do not have to pay any questioned arncunt while we are investigating,
but you are still obligated to pay the parts of your statement that are riot in question.
It we find that we made a mistake on your statement, you will not have to pay any j
finance charges related to any questioned amount. If we didn't make a mistake, you
may have to pay finance charges, and you will have to make up any missed
payments on the questioned amount. In ribber case. we will send you a statement
of the amount you owe and the date that it is due.
If you fail to pay the amount that we think you owe, we may report you as delinquent.
However, it our explanation does not satisfy you and you write to us within ten days
tatting us that you stilt 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 I
we reported you to. We must tell anyone we report you to that the matter has been
;
settled between us when it finally is.
If we don't follow these rules, we can't collect the first $50 of the questionec amount,
even if your statement was correct
SPECIAL RULE FOR CREDIT CARD PURCHASES - It you have a problem with
the quality of property or services that you purchased with a credit card, and you
have tried in good faith io correct the proti4em with the merchant, you may have the
right not to pay the remaining amount due on the property or services. There are two
limitations an this right: (a) You must have made the purchase in your home state or,
if riot within your home state, within 100 miles of your current mailing address, and
(b) The purchase price must have been more than S50.
These limitations do not apply if we own or operate :he 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 I Line only by written application to us, which must be approved by our credit committee
i 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 I
j 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 time, but termination by either of us does not affect your obligation
you are responsible for charges made by yourself, your spouse and minor childron. to pay the account balance.
'
You are also responsible for charges made by anyone else to whom you give the S. CREDIT INFORMATION -You authorize us to investigate your credit slano?ng
j card: and this responsibility continues until the card is recovered. You cannot disclaim when opening, renewing or reviewing your account, aria you authorize us to disclose
responsibility by notifying us, but we will close the account for now transactions if you 111 information regarding your account to credit bureaus and otner creonors who inquire .
so request and return all cards Your obligation fo pay the account balance continues ? of us about your credit starding.
even though an agreement. divorce decree or other court judgment to who" we are 6. MONTHLY PAYMENT - We will mail you a statement every mach 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, the current transactions on your
The cards remain our property and you must tk?caver and surrender to us all cards account, the remaining credit available urtder your CreJ1 Lne, the New balances of
uocn our request and upon temtinahon of Vus AgurSn,enf purchases and cash advances, the Total New Balance. the F6nanc:e Charge due to date.
2, LOST CARD NOTIFICATION - If you believe the yard has been lost or stolen, and any other billed fees, and the Minimum Payment required. Every month you must pay
you will immediately call the Credit Union a! 171 7) 23»-8484 or f8001 237-732F After i at loast the Minimum Payment within 25 days of voir statement closing date. By separate
hours call (800) 556-5678 I agreement you may authorize us to charge the minimum payment automatically to your
share or checking account with us. You may, of course, pay more iequently, pay "tore '
3. LIABILITY FOR UNAUTHORIZED USE -You agree to notify us united airily. orally i than the Minimum Payment, or pay the Total New Balance in full, and you will reduce the
or in writing of the loss, then or inaunirorrr.•d use of your Credit Card. You may be Katie finance charge by doing so. It your monthly payment exceeds the total credit line balance
for the unauthorized use of your Credit Card You wil: not be Bale for unat.thonzed use owed. we will automatically post the credit to your S1 snares
that occurs after you notify us of the loss, theft, or possible unauthorized use. You will haw, The minimum payment will he (a) 2°-0 of your Total New Balance, rounded up to the
n ligent in for the e ban handy+nc + orrzed of p yror made with your Cour liability redliability Card, will not unless you exrcrid are S5grossly i next even dollar, or (b) S20.00, whichever is greater. In addition, a: any time your Total
negligent
your Card ard In any cos ?. y 0 Now Balance exceeds your Credit Line. you must unmed arely pay tr,e excess up„n our
4. CREDIT LINE - If we approve your appircalion, we will 2stablisn a se!! domand. We will apply pavmen:s in the foliomn,g manner fusr 1;; previous Into teas.
replenishing L.ne of Credit for you and notify you of its amount when we issue the men !O fevious cash advances f nett; e Crap"u? then in r ve n
P u t i :. r i:ise
Card. You agree not to le! !ne a coJ1' raL=n_e &z^eoc !'tis ipprnv ea CreOit Line Facn charoes, then to -urrdrt la:r feet then, to prey ,us :;all n b,r,, lrp;, 1h ;,t fc
piaymenl you make on ir:a account wi!i restore /our . led t Lane by ° ar n f pit, p,evio,.s purchase La'ances in tie vroer tha! tnev were po„ted tc yo.;r auceuni en
payrnen! v;hicn. is eppi a... J no; pr l-wn' .. .fir it- 0 :r: yixn crud! to current ash ra..ar e ',r ca5 and then •o c.;.re. l,w.a.,:. C.a:,:rres
Visa' Credrr C-rrd A reernerrt and Truth Lt Lendin Disclosure onfinued o' reti,rned wi h lie. statement 'r v r .II r :tai e COW 01 „' t rnisr, d fit 1v.
-- - -- -' -- - --- 9 ----- :trig of the 'ran.>auw : i r or ier to vef t, It e rr n i y 5 r trig r
7. FINANCE CHARGES - l.,u .a? av :d the f t h c Change on purchase,, y -title a reasonable change f; r phnt , ,#: s , f cats r, a m,y rr-q,e:,t
paying the iua amount the New Balance of Pu , h f cS eacn rnown wil fin 25 days : 10. OVERDRAFT OPTION - If you elect to overdraft to your PSECU V sa Credit
of your statement closing date. Otherwise, the New Balance of Purchases, and the A Card, that election is subject to the existing credit lirm, and the agreement it represents I
subsequent purchases from the da,p they are posted To your account, will be subject and the current loan policy at the time of the overdraft. You al,e understar'.d trial nth
to Finance Charge Cash advances area ways subject to Finance Charge, from The ; overdraft will be considered the same as a cash adva•hce on your PSECJ visa Cradu
date they are posted to your account Card and that the current Annual Percentage Rate for cash advances will apply
Purchases: We calculate your finance Charge by mult,ptyng the average adjusted 11. RETURNS AND ADJUSTMENTS- Merchants and,):hers who honor the card
daily balance (see explanation below), including new purchases, for the billing cycle j (flay give credit 'or returns and adjustments, and they wd'I do so t y Sendinrt us a
by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE credit slip which we will post to your Visa fine Cf crntlu If your ;3er.,t and Tiaym(-ntc
RATE as disclosed on the Addendum. exceed what you Owl) us, we will automatic rill peat h ,odi
r _ t ., i
Cash Advances: We calculate your finance charge on cash advances y your St Snares within 75 days If the hatancr s lio dollar vt r tO ;:Pon your
multiplying the average adjusted dally balance :See explanation beivw) for cast, evritten request we will refund The credit balance to you
advances during Tne billing cycle by the rtio h y periodic advance rare and 12. FOREIGN TRANSACTIONS -The er.dtan t rate uehaoen the ?ra 1Sa;: rip t
corresponding ANNUAL PERCENTAGE RATE a u su'cse] on the Addendum currency and the billing currency used ter lxO essing nlernaf:onal +ran a lens tatP
Balance Computation Method selected by Visa from the range of rates available in w1irlcsa;o currency markets for the
Average Daily Balance for Purchases - The Average Daily Balance for Purchas(. applicable central processing date. which rate may vary from the rate Visa itself
Transactions is calculated by acidi*r; the Daly Balances )Purchase Transaction) for i receives, or a government •mandaled rate m affect for the applicable central processing
each day in the billing cycle, and then dividing by the number of days in the baling i date. In each instance, an adjustment may be assessed based on the 1SA tee imposed
cycle 'to calculate the Daily Balance for purchases each day, we take the following by Visa. This fee, wh:Ch totals I% of the transaction amount, will be assessed or. all
steps: We take the outstanding balance (at! amounts you owe) at the start of the day. ; ?ransactions where the merchant country differs from the country of the card issuer.
Then, in the sequence in which amounts are posted to your account, we add the 13. SPECIAL RULES FOR VISA PURCHASES - if you disagree or find an orror i
amounts of all debits and subtract the amounts of all credits or payments which post with a Visa transaction, and have tried in good taith to correct the problem with the
to your account that day. After applying payments and credits, we subtract the merchant or the charges are the result of unauthorized or fraudutiEnt use. or your
amount of any unpaid Finance Charges or Late Charges. Then we also subtract the purchase cost more than $50 and was made from a plan merchant in your state
amount of any Cash Advance transactions that posted to your account on that day or within 100 miles of your home, contact PSECU.
in any previous day in the billing cycle, This gives us the Dally Balance for purchases. 14. DISPUTED TRANSACTIONS -You are required to nobly PSECU in wrung
Average Daily Balance for Cash Advances • Cash Advance Transactions which are within 60 days "lowing the date on which we sent your 52ateme:nt wherein the error i
posted to your account are not included in the Average Daily Balance calculation for or problem first appeared regarding any discrepancy or unauthorized transaction on
purchases, and are therefore not subject to the monthly periodic rate for purchases. The your account. Telephoning PSECU does not preserve yo,-,r dispute rights You may
Average Daily Balance is calculated separately for Cash Advances and is subject to the be required to provide us with docurnenlafion to support your dispute claims In
Cash Advance Monthly Periodic Rate. The Average Dally Balance for Cash Transactions addition, you may be required to complete a standard dispute form outlining the
is calculated by adding the Daily Balances (Cash Transaction) for each day in the billing details of your d spule. In cases of fraudulent card use. PSECU will also require a
cycle, and then dividing by the number of days in the of ling cycle. To calculate the Daily I notwized affidavit. In some cases we may ask you To notify the local authorities
Balance for cash each day. we take the folk)wirtq steps: We take the outstanding amounts If we do not receive the proper requested documentation, in the time. Specified you
(alt amounts you owe) at the start of the Jay. Then. in the sequence in may be held responsible for the transaction(s) in question. PSECU must adhere to
are posted to your account, we add the amounts of all debits and subtract the amounts j strict dispute timeframss set forth by Visa.
at ail credits or payments which post to your account that day. After applying payments I
and credits, " subtract the amount of any unpaid Finance Charges or Late Charges. 15. SECURITY INTEREST - To secure your account. you grant us a purchase
Then we also subtract the amount of any Purchase Transactions that posted to your money security interest under me Uniform Commercial Code in any goods you
account on that day or in any previous day in the billing cycle. This gives us the Daily purchase through the account. If you default, we will rave the right to recover any of
Balance for Cash Advance Transactions. Note: Cash Advances are always subject to ? these goods which we have not been paid for Through our application of your
finance charges and from the day they are posted to your account. i 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
Payments are applied in the following manner: first to previous late fees, then to I default to prevent withdrawal of your unpledged credit union shares (Deposits)
previous cash advances finance charges, then to previous purchase tnance below the unpaid balance of your account. However. if you give or have given us a I
charges, then to current fate fees, then to previous cash advance balances, then to + specific pledge of your credit union shares (Deposits) by signing the Pledge of ,
previous purchase balances in the order that they were posted to your account, then j Shares or otherwise, or any other security interests for all your debts, your account
to current cash advance balances, and then to current purchase balances Credits will be secured by your pledged shares (Deposits) and by the property described in
are applied first to the particular type of debt which is being credited, if any, and then those other security agreements, except for your home.
to the balance of your account. 16. EFFECT OF AGREEMENT - This Agreeme.r• is th ccntrao 9h rn 3P1 to
Note also that if the total of The payments and credits which are posted to your 11 all transactions on your account even Though the sains cash ac vance, chi Oil of !
account by the Payment Due Date shown on a statement is equal To or exceeds the other slips you sign or receive may contain different terms 'trite may amend the
New Balance shown on that statement, we will not apply, the Monthly Periodic Rate Agreement from time to time by sending you the advance wimen notice required by
to your Account on your next statement aw. Your use of trie card thereafter will indicate your agrrl6rnent to the nmendrrents
6. DEFAULT-You w&t be in aetautt it you fan to make any Minimum Payment wrthm To the extent the law pormas, and we fndfcate In Our notice imenomc-nis w,li apply
25 days after your monthly statement Uc-xsing date You authorize us to transfer tunas I !o your existing account balance as well as to inure uansactions
sufficient to make the minimum payment dual d Your Visa loan is in default 'Ou will 17, LATE PAYMENT CHARGE - if your Mn mum Pavment i5 not recetved by the,
also be in default if your ability to repay us is malenally reduced by a change n yOUi `first day of the month following your due data, you v.ili oa sLJUJI cf to a 520 cnaryr•.
employment, an increase in your obirgations, bankruptcy or insolvency proceedings j 18, RUSH FEES - You may incur addition,.! C'taroes for rush processing an e, rush
involving you, your death or your failure to abide by this Agreement, or if the value of delivery of cards anct'or PIN mane.)
our security interest materially declines. We have The right to demand immediate I
payment of your full account balance if you default, subject to our giving you any ! 19, OVER LIMIT FEE -A 520 fee will be applied for eacn monthly statement, closing sate
notice required by taw. To the extert permitted by law, you will also be required to pay on which the outstanding balance exceeds the assgrutd Credit limit by more than S 100
our collection expenses, includng court costs and reasonable attorney tees. 20. DRAFT COPIES - You may incur art aciJitdnal charge for transaction
9. USING THE CARD - To make a purchase or cash advance, there are two summary/sale draft documentation.
alternative procedures to be followed. One is fa you to present the card to a 21. COPY RECEIVED - You acknowledge receipt of a coy of this Agreement
participating Visa plan merchant, or another financial Institution, and, sign trig sales 22. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use
or cash advance draft which will be imprinted with your card. The other is to complete ! your card for any transaction that is iliac
;at under applicable federal, state. or 1, a-'law
the transaction by using your Personal Identification Number (PIN) in conjunction i
with the card in an Automatea Teller Machine or other type of electronic terminal that 23. NO USE - Inactive Visa accounts that n,evo np C.ur +tase or Cal St' 8( twill, "hay
provides access to the visa system. You agrot, that you wdi not use ,our Card Ir,r any be dosed without notice !(J you after 111 months, Of n?, act A!y
transaction that is illegal under applicable tedentl, state. Or local law-Tie monthly 24. NEURAL NETWORK - PSECU uses neural rte work sysier„i fn predict and
statement will identify the merchant electronic terminal Or financial iristilut, n at prevent unauthorized transactions. 'There may be :,2ccas1on5 wheri i trarS acfion i9
whion transactions were mace-. n.,t sine ca5n advance, credit or :)trier slips carrot , d0chned oecause it is Indicative u' pOSSrble tai. Pule ,,.^?day
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-05374 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE EMPLOYEES
VS
NELSON WILLIAM H JR
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
NELSON WILLIAM H JR but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE ,
the within named DEFENDANT
NOT FOUND , as to
NELSON WILLIAM H JR
117 E POMFRET STREET
CARLISLE, PA 17013-3315
PER MOTHER, DEFENDANT LIVES AT SAFE HARBOR HOMELESS SHELTER IN
CARLISLE.
Sheriff's Costs: So answers:
Docketing 18.00
Service 5.00
Affidavit .00 R. Thomaszne
Surcharge 10.00 Sheriff of Cumberland County
Not Found 5.00
jo1bq/pg 38.00 VAN ECK & VAN ECK
09/16/2008
Sworn and Subscribed to before
me this day of ,
A. D.
08-5374
- T, rn r?
2010 APR -5 h 3: 44
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602 ttorneys for Plaintiff
(717) 299-5201 ennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES IN HE COURT OF COMMON PLEAS OF
CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIV L ACTION - LAW
v.
WILLIAM H. NELSON, JR.,
Defendant
No. $8-5374
Kindly withdraw the appearance of Melissa L
Pennsylvania State Employees Credit Union and
Esquire as counsel for Pennsylvania State Employees
captioned matter.
Papers may be served at the address set forth
BARLEY SNYDER LLC
By:
Sh M. Long, Esqu'
Court I.D. 83774
126 East King Stre t
Lancaster, PA 17602-2893
717.299.5201
Date: 3 31 U
V
B,
an Eck, Esquire as counsel for
appearance of Shawn M. Long,
Union, regarding the above-
?N ECK & VAN ECK, P.C.
Melissa L. Van Eck, Esquire
Court I.D. 85869
7810 Allentown Blvd., Suite B
P.O. Box 6662
Harrisburg, PA 17112
717.540.5406
2862161-1
08-5374
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
WILLIAM H. NELSON, JR.
-OFFICE
OF THELROTHONOTA
RY
2010 DEC -3 PM 3: 55
CU??+? Yt°varv°?v1?rY
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 08-5374
MOTION OF PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FOR
SERVICE PURSUANT TO SPECIAL ORDER OF COURT PA.R.C.P. 430(a)
AND NOW, comes the Plaintiff, Pennsylvania State Employees Credit Union, by and
through its attorneys, Barley Snyder LLC, Esquires and moves your Honorable Court, pursuant
to Pa. R.C.P. 430(a), for a special order directing service of process, default notice, and writ of
execution notices, if necessary, upon Defendant by publication in accordance with Pa. R.C.P.
430, as follows:
1. On September 9, 2008, the Plaintiff filed its Complaint against the Defendant. A
true and correct copy of the Complaint is attached hereto as Exhibit "A" and incorporated herein
by reference.
2. The Sheriff of Cumberland County attempted service at 117 E. Pomfret Street,
Carlisle, Pennsylvania 17013 and returned the Return of Service to Plaintiff indicating "per
3062300-1
08-5374
Mother, Defendant lives at Safe Harbor Homeless Shelter in Carlisle." A true and correct copy
of the Return of Service is attached hereto, made a part hereof and marked Exhibit "B".
3. On July 8, 2010, Plaintiff performed an Accurint search on www.Accurint.com.
The address listed on the Accurint search is 117 E. Pomfret Street, Carlisle, Pennsylvania 17013.
A true and correct copy of the Accurint Search is attached hereto, made a part hereof and marked
Exhibit "C".
4. On September 8, 2010, Plaintiff performed an Accurint search on
www.Accurint.com. The address listed on the Accurint search is 117 E. Pomfret Street, Carlisle,
Pennsylvania 17013. A true and correct copy of the Accurint Search is attached hereto, made a
part hereof and marked Exhibit "D".
The Plaintiff's counsel prepared and mailed a Request for Change of Address to
the Carlisle Postmaster. The response to the Request for Change of Address indicates "not
known at address given". A true and correct copy of the response to the Request for Change of
Address is attached hereto, made a part hereof and marked Exhibit "E".
6. On November 11, 2010, Plaintiff performed an Accurint search on
www.Accurint.com. The address listed on the Accurint search is 117 E. Pomfret Street, Carlisle,
Pennsylvania 17013. A true and correct copy of the Accurint Search is attached hereto, made a
part hereof and marked Exhibit "F"
7. Plaintiff believes and therefore avers that the reasonable method, under the
circumstances, is to serve all pleadings, including service of process, default notice, writ of
execution and notices of sale upon the Defendant, if necessary, by publication.
3062300-1
08-5374
8. The Plaintiff will suffer irreparable harm and injury if the Plaintiff is not allowed
to effect alternate service of the process, default notice, writ of execution and notices of sale, if
necessary, upon the Defendants, under Pa.R.C.P. 430, by publication, under Pa.R.C.P.430.
WHEREFORE, the Plaintiff, Pennsylvania State Employees Credit Union, prays your
Honorable Court to enter an Order authorizing service of process, default notice, writ of
execution and notices of sale, if necessary, in the within matter upon the Defendant, William H.
Nelson Jr., by publication in accordance with Pa. R.C.P. 430(b)(1).
BARLEY SNYDER LLC
Date: /)-A-/ U By:
Shawn M. Long, uirgo'
Attorneys for Plaintiff
Pennsylvania State ployees Credit Union
Court I.D. No. 837 4
126 East King S eet
Lancaster, PA 17602-2893
717-299-5201
3062300-1
EXHIBIT "A"
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES : NO. CS- 5bhq
CREDIT UNION,
Plaintiff
VS.
WILLIAM H NELSON JR. s
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.
WILLIAM H NELSON JR.
Defendant CIVIL ACTION -LAW
AV I S O PARR 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) dial
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 rods aviso
por cualquier dinero reclamado en la Demands o por cualquier otro reclamo o alivio solicitado
por Demandante. Ustedpuede perder dinero o propiedad o otros derechos importante para usted.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED
NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA
AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO
CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE
PROVEERE INFORMACI6N ACERCA AGENCIAS QUE PUEDAN OFRECER
SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O
GRATIS.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
Document #: 180057.1
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES NO.
CREDIT UNION, .
Plaintiff
VS.
WILLIAM H NELSON JR.
Defendant CIVIL ACTION -LAW
COMPLAINT
AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and
through its attorneys, Van Eck & Van Eck, P.C. and states the following cause of action and in
support thereof, avers as follows:
1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution
qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place
of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania.
2. Defendant, William H Nelson Jr., is an adult individual with a last known address
of 117 E Pomfret Street, Carlisle, PA 17013-3315.
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 September 8, 2008, the balance due, owing and unpaid on Defendant's loan
account with Plaintiff is the sum of Eight Thousand Nine Hundred Sixty-Nine Dollars and
50/100 ($8,969.50).
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 One Thousand Two
Hundred Thirty-Six Dollars and 90/100 ($1,236.90) 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,
William H Nelson Jr., in the amount of Ten Thousand Two Hundred Six Dollars and 40/100
($10,206.40), 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: Al d-?AKA
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
unsworn falsification to authorities.
Pennsylvania State Employees Credit Union
By:
T' PL m e_-
Date: IIg 1 0e
BIT ccA?s
i
KANWW .
ADVANCE PROCEEDS VOUCHER
AND SECURITY AGREEMENT
Pennsylvania State
Employees Credit Union
P. O. Box 67013
PSECO 'Harrisburg, PA 17108-7013
717.234.8484
800.237.7328
• MEMBF? R . ?.:.:-.••-.. ?- ` 'r :•.•?i:... •:•:?+ .i ACS tiERr :r:•q, .:4 ,?,•V +?
ILLIAM L NE S 8/11/200
f 0005559660
117 E POMFERET DRIVE
CARLISLE, PA 17013
AutoCheck Dealer
TRAPLYM 1 ? NEW L OAN 2 a ope" 0 Q BE 4 E9Wm ADVANCE
. . l
( .
SECURiTY OFFERED
19 )m9YdICE, THE ONLY SEtxl M POR71119 AV ANCE N THE REAL PROPERTY (W MOSTCASESYOUR HOME) NRICH YOU GAVE AS SECIJRI W E9r YOUR ACCOUNT
IFTHIS 19 NOM HOME EDURY ADVANCE N ADDITION TOME PLEDGE OF SHARES NYOUR LOAN L*or CREOITAGREEMFr11; 7HE FOLLOWING PROPERTY SECURES THIS ADVANCE.
n7EM PROPEAT'Y
?;: .. •..M , !c3„ x _ j }..v *?; r.' .?J{?+Y
WDE
1. CHRYSLER OWN & COUNT 2003 MGP441,03R222635 SW 16,590.00
2
4 OTHER
YOU PLEDGE SHARES ANWOR DEPOSnB OF $ N ACOOUNT NUMBER
OLD AUMBER
(A) QDFFOfta + 9M OLD ACcOUNDLmAN NUMBER FMYOFF (PAIN-. INC OLD ACCOUNTAAAN NMBER PAYOFF (PRWC.+ NTa
:
OLD UMBER AYOFF PRNC. + Wn OLD ACOMWULOAN MMM F*0FF (PRINC,+ Wt OLD ACCOUNTAOAN'NUMBER PAYOFF P n%r-+
By accepting the proceeds or by using the huTds advanced and deposited into your share/share draft account, you agree (1) that the property referenced above
witi secure the advance and any other advances you have rlDw or receive in the future under the LOANUNER' Credit and Security Agreement (the Wan) and
arty other amounts you owe us for any reason now or in the future to accordance with the terms of the Plan and (2) to make payments as disclosed above in
accordance with the terms of the Plan.
v61YNA!D ebow.MRaz,Kak49,!1,99,N00,01.N,06,ALLgN91TbRESEmo
PENNSYLVANIA STATE EMPLOYEES CREDIT LMN FORM 43175 JVXX0100.1 W7-2092-1 (Blob)
3&!% AcNNED
SECURITY AGREEMENT
In this agreement all references to Credit Union, we, our, or us means Pennsylvania
State Employees Credit Union and anyone to whom the Credit Union assigns the Credit
Agreement which will be referred to as the Plan. All feferences to you, your, and
borrower mean each person who signs this agreement. All references to the advance
mean the amount in the box labeled Amount Advanced. This is a multi-state document
which may be used to lend to borrowers in all states except Louisiana and Wisconsin.
1. THE SECURITY FOR THE LOAN - By signing this security agreement in the
signature area or under the statement referring to this agreement which is on the back
of the check you receive for the advance, you give us what is known as a security
interest in the property described in the Security Offered section on the reverse side.
The security interest you give includes all accessions. Accessions are things which are
attached to or installed in the property now or in the future. The security interest also
includes any replacements for the property which you buy within 10 days of the
advance or any extensions, renewals or refinancings of the advance. It also Includes
any money you receive from selling the property or from insurance you have on the
property. If the value of the property declines, you promise to give us more property
as security if asked to do so.
2. WHAT THE SECURITY INTEREST COVERS -The security interest secures the
advance and any extensions, renewals or refinancings of the advance. It also secures
any other advances you have now or receive in the future under the Plan and any other
amounts or loans, including any credit card loan, you owe us for any reason now or
in the future, except any loan secured by your principal residence.. It the property is
household goods as defined by the Federal Trade Commission Credit Practices Rule,
the property will secure only the advance and not other amounts you owe.
3. OWNERSHIP OF THE PROPERTY - You promise that you own the property or
if this advance is to buy the property, you promise you will use the advance for that
purpose. You promise that no one else has any interest in or claim against the
property that you have not already told us about You promise not to sell or lease the
property or to use It'as security for a loan with another creditor until the advance is
repaid. You promise you will allow no other security interest or lien to attach to the
property either by your actions or by operation of law.
4. PROTECTING THE SECURITY INTEREST - It your state issues a title for the
property, you promise to have our security interest shown on the title. We may have
:o file what is called a financing statement to protect our security interest from the
:laims of others: If asked to do so, you promise to sign a financing statement You
ilso promise to do whatever else we think is necessary to protect our security interest
n the property. You promise to pay all. costs, including but not limited to any attorney
`ees, we incur in protecting our security interest and rights in the property, to the
,xtent permitted by applicable law.
i. USE OF PROPERTY- Until the advance has been paid off, you promise you will:
1) Use the property carefully and keep it in good repair. (2) Obtain our written
)ermission before making major changes to the property or changing the address
vhere the property is kept (3) Inform us in writing before changing your address. (4)
know us to inspect the property. (5) Promptly notify us if the property is damaged,
;toles or abused. (6) Not use the property for any unlawful purpose.
i. CONSUMERS' CLAIMS AND DEFENSES NOTICE - The following paragraph
applies only when the box on reverse side is checked.
IOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT 1S
rUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD
iSSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED
VITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE
)EBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR
IEREUNDER.
. PROPERTY INSURANCE, TAXES AND FEES - You must maintain property
isurance on all property that you give as security under the Plan. You may purchase
ie property insurance from anyone you choose who is acceptable to the Credit Union.
he amount and coverage of the property insurance must be acceptable to us. You
iay provide the property insurance through a policy you already have, or through a
olicy you get and pay for. You promise to make the insurance policy payable to us
Id to deliver, the policy or proof of coverage to us if asked to do so.
you cancel your insurance and get a refund, we have a right to the refund. If the
loperty is lost or damaged, we can use the insurance settlement to repair the
'operty or apply it towards what you owe. You authorize us to endorse any draft or
)eck which may be payable to you in order for us to collect any refund or benefits
je under your insurance policy. You also promise to pay all taxes and fees (like
registration fees) due on the property.
If you do not pay the taxes or fees on the property when due or keep it insured, we may
pay these obligations, but we are not required to do so. Any money we spend for taxes,
fees or insurance will be added to the unpaid balance of the advance and you will pay
interest on those amounts at the same rate you agreed to pay on the advance. We may
receive payments in connection with the insurance from a company which provides the
insurance. We may monitor our loans for the purpose of determining whether you and
other borrowers have complied with the insurance requirements of our loan agreements
or may engage others to do so. The insurance charge added to the advance may include
(1) the insurance company's payments to us and (2) the cost of determining compliance
with the insurance requirements. If we add amounts for taxes, fees or insurance to the
unpaid balance of the advance, we may increase your payments to pay the amount
added within the term of the Insurance or approximate term of the advance.
8. 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
insurance will not be liability Insurance and will not satisfy any state financial
responsibility or no fault laws.
9. DEFAULT- You will be in default It you break any promise you make under this
agreement. You will also be in default if you are in default under the Plan. If you are
pledging property, but have not.signed the Plan, you will be in default If anyone is in
default who has signed the Plan.
10. WHAT HAPPENS IF YOU ARE IN DEFAULT - The following paragraph applies
to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine,
Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: When you
are in default and after expiration of any right you have under applicable state law to
cure your default, we can require immediate payment of your outstanding balance
under the Plan without giving you advance notice.
The following paragraph applies to borrowers in all other states: When you are in
default, we can require immediate payment (acceleration) of what you owe under the
Plan and take possession of the property. You waive any right you have to demand for
payment, notice of Intent to accelerate and notice of acceleration.
The following paragraphs apply to all borrowers:
You agree the Credit Union has the right to take possession of the property without
judicial process if this can be done without breach of the peace. If we ask, you promise
to deliver the property at a time and place we choose. We will not be responsible for
any other property not covered by this agreement that you leave inside the property
or that is attached to the property. We will try to return that property to you or make
it available to you to claim. ,
After we have possession of the property, we can sell it and apply the money to any
amounts you owe us. We will give you notice of any public sale or the date after which
a private sale will be held. Our expenses for taking possession of and selling the
property will be deducted from the money received from the sale. Those costs may
include the cost of storing the property, preparing it for sale and attorney's fees to the
extent permitted under state law or awarded under the Bankruptcy Code. The rest of
the sale money will be applied to what you owe under the Plan.
If you have agreed to pay the advance, you will also have to pay any amount that
remains unpaid after the sale money has been applied to the unpaid balance of the
advance and to what you owe under this agreement. You agree to pay interest on that
amount at the same rate as the advance until that amount has been paid.
11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT - We can
delay enforcing any of our rights under this agreement any number of times without
losing the ability to exercise our rights later. We can enforce this agreement against
your heirs or legal representatives. If we change the terms of the Plan, you agree that
this agreement will continue to protect us.
12. CONTINUED EFFECTIVENESS - If any part of this agreement is determined by
a court to be unenforceable, the rest will remain in effect.
13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE -
THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO
REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL
AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU
MAY HAVE TO PAY THE DIFFERENCE.
14. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to fail to
return a motor vehicle that is subject to a security interest, within thirty days after you
have received notice of default. The notice will be mailed to the address you gave us. It
is your responsibility to notify us if your address changes. The maximum penalty for
unlawful failure to return a motor vehicle is nne vear in nricnn nnrUn, n fi- M e, =r, nnn
. %r .:
' PENNSYLVANIA STATE EMPLOYEES CREDIT UNION CASHIER'S CHECK
Ma11ng Address:
Pro: BOX .67013
NO..?19043?
HARRISBURG, PA 17106-7013 • . r _ -:: ':? :.,= .- .-..:.'.DATE:
;?? •. ; ,? el. 09/1.1!2006
'l? .: r .: .%'% ;: %a:, :': '•1 $..'16590.00°'
SIXTEEN THOUSAND FIVE HUNDRED NINETY•D0
TO.TrtE 13L,1RS AND 00 CENTS'
IV-
:.ORDER WILLIAM NELSON '.'-• ' PENNSYLVANIA STATE '
.'r• ii 7 'i, :I. ?. _ _ E?pmEEs rRWIT uMON.
r•, OF
AND HARRISBURG HYUNDAP. '2' ?? •'
YOID.AFTER'90 GAYS.
A W SIGNATURE
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AMENDED LOAN SECURITY AGREEMENT
The background of this security agreement is as follows:
On 8/1142006, WILLIAM NELSON (debtor), Account # _ borrowed a sum of $16590
from the Pennsylvania State Employees Credit Union (PSECU), as evidenced by a loan
agreement executed by debtor dated 8/11/2006. Said loan was to finance the purchase of the
following motor vehicle which debtor pledged as security for said loan.
Year. 2003 Make: CHRYSLER Model: TOWN & COUNTR
Manufacturer Serial* 2C4GP44L03R222635
Said vehicle was not only titled In the name of debtor, but In fact, was titled In the name (s):
TARA WENGREZN
All parties must sign this security agreement.
This agreement Is given to perfect the Interest of PSECU In said vehicle, as previously agreed to
under the LOANLINER® security agreement and the parties hereto agree to be bound by the
terms of the Security Agreement executed by the above named debtor, which security agreement
is Incorporated herein by reference.
IN WITNESS WHEREOF and Intended to be legally bound WVe have set my/our hand and seal.
All prior named must sign this security agreement.
tN 'W Date/2„//U /
WILLIAM NELSON (Debtor)
Date
TARA WENG14094
VzV)
Date
Exhibit"
"
PSECO Pennsylvania State Employees Credit Union
O • , ; ll) 2.iw;-,id5,*4.,I."- :;,irq ,ri;t7; "':i? :3?`i r?',Y.r:;n::;.:-?
Loan Disclosures
.• NUNEJP'CRWff AND SECURffY AGREEMENT
This LOANLINER- CrP00 and Sec:,nrv Agreemr:ra. .:n 1h .tlcludes 'ice To,t/i :r CREDIT INSURANCE - ties r." anc-.f v>>c api+ity :n3uiantu rs r r;t.undi
Lend ng DtscK;suies. writ De referred %a as the Plan 7110 Plar::s;xl'V-Nl!? *nCl..rdt' ;his X^aef !lie Plan If you quea'v 1'.r r^=:i ;•mcLa>v ; c ,r:sl:ranCe horn us. you duthor•Ze
agfeemer: ani art Addav,dum You, your and borrower ,mean arty c_rior. who ;,ors is to mic !`.e nsu:anec ptorn.?r is a+ ,ntm.y to =o.u ;c:ar balance and enargr you
_a Plan Credit union. we. our ar.- us 'nca,i anyorc n n-r I'm : red'! .n!ere5! 0• the entire ba:cnco I' you eie%n =credit -nl;: rw ice, your payments may
Union frdnsters Is fhJnis untie r Iha Piar ,?uease cr Ina ri,n•y7 t lime ne•-essJry K, rrpay yCt:r advance mat be exic-nded.
HOW THIS PLAN WORKS - This is a+: nu rteafure: cre-!i! par 'W'et -rio -reds risurara:e rates ..^ay Cnanua dt:rnq 1'•a P:;n I! no rates crianga. we will
anticipate that. !torn !role to t:rre..Ric ocr.e-,v money icarlt i' clv tr:rs i u]cr provide any nncces re vireo by apptcab!c• aw
the Plan. We are not required to make advances to you under the Plan and can PERIODIC STATEMENT - On a tegutai cast; you via receive a statement showing
refuse a request for an advance at any time. The Addendum describes trio an transactions under the Plan during !ne peitno covered by the stalomenf
different types of eredl (called'subaCCOUMS-) avai!abie under the Plan, the currant Statements and notices will be sent to you at :he moist recent address you nave
interest rate for each subaccourt expressod as a daily periodic rate and ! given us in writing. Unless applicable taw requires na!ice to each joint borrower,
COlrespordmq annual percentage rate and other charges. It may also have otnef ; notice to any one of you will be notice 10 Vi.
terms and a schedule for determimng me payment amounts. i JOINT ACCOUNTS - If this is a pint account, each of you is individually and !Cintly
CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain i responsible for paying all amounts owed. That means we can enforce our rights
subaccounts. If a credit limit is sat for a subaccount. you promise not to exceed the under the Plan against any one of you individually or against all of you together. If you
eslabli had credit Nmit. It you exceed the credit limit, you promise to repay give us inconsistent instructions, we can refuse to follow your instructions. Unless our
immediately the amount which exceeds the credit IimiL written policy requires sit of you to sign for an advance, each of you authorizes the j
REPAYMENT - You promise to repay all amounts you owe under the Plan plus j other(s) to obtain advances individually and agrees to repay advances made to the
interest Payments are due on the last day of (tie mon1i unless wo set a ditlefeni day t other(s). Any joint accountholder may terminate the Plan by giving us prior written ,
at the time of an advance. If the Addendum has no. payment schedufa for it ! notice 11 arty of you terminate the Plan, the P'.an is terminated for all of you 'roe
subaCCOUnt, your payment will be deternrmed at the time lit eacrl adyaric'e. remain liable indili dualy, and jointly for all lovar-ces :ncurred before termination
Payments musi include any amount past due and any amount by which you have FEES AND CHARGES - If you give us a security interest in cenain types of ,
exceeded any credit firm y0il cave peen giver, for a set:acccJnt YOU may raj?2y aft property, wtt may charge you a filing fee to perfect our interest in the property If we
or part of what you owe at any time wrinoul any prepayment penalty. Ever. if yrj;i j do. the amount of the lee will bel disclosed to yru al ilia time you obtain an advance.
prepay, you wui sett Le regwred to make !na regularly scredu{ed payments unless We may also charge you other fees in conneciiati with the Plan. Our curiont lees ate ?
we agree in. writing to a cnange in :ne payment schedule. If ynu have a otnt disclosed on the Addendum and will be added to your loan balance unless you pay
sharetln;ft account, you will oe responsible for paying all overdraft advances them in cash.
obtained oy a girt holder of Kra shaiedra!1 account. Unless otherwise required by
law payments will be applied to amounts owed under fro Plan, in the manner the I UPDATING CREDIT INFORMATION You promise that you will promptly give us
Credit Union chooses. t written notice if you move, change your name or employment, or if any altxrr !
information you provided to us changes. Upon our request, you also agree to i
PLAN ACCESS -You can obain credit advances in any manner authorized by us if I provide us updated financial +nlertnatton.
ii we allow use
your
ATMIDebill } unauthorized ruse of your ATM petit card. to access You will noel be Plan, you liable braunauthor'tzedr use ( DEFAULT - The following paragraph applies to borrowers in Idaho, Kansas, j
y that occurs after you notify us. orally or in willing, of the loss, theft, or possible I Maine and South Carolina: You will be in default It you do not make a payment of )
unauthorized use. If you believe your ATM: Debit Caro has been lost or stolen, i the amount required when it is due. You will also be in default it we believe the i
i immediately inform this Credit Union by calling of writing us at the telephone number or prospect of payment, performance, or realtzalron on any property given as security (
address that appears elsewhere in the plan, it the card is used to obtain unauthorized is significantly rmpa)red.
advances directly from the Plan, your liability will not exceed $50. If the unauthorized i The iollowlrrg paragraph applies only to borrowers In Wisconsin: You will be in i
withdrawal is from a sharerxah account, your liability is governed by the Regulation £ default if you fail to make a payment when due two times during any 12 month
dicciosures you received at Me time you received your ATMiDeb.1 card. even if the period You will be in default it breaking any promise made under the Plan materially
withdrawal results in an advance being made fforr, your overdratt Subaccounl impairs your aWrty Ic repo) wnh! you owe at rnararialry impairs me cJndbdn, s:uae
FINANCE CHARGE - The dollar amount you pay for money borrowe. s calved a or protection of or our right in any property yo:, gave as security.
-finance charge' and begins on tr.e dnte 0 each advarce A finance charge vIII lie The following paragraph applies only to borrowers in Iowa: You will be in
compute-3 separately for each separwe balau,ee unoel Otte Pinn. To compute tie default if you are more than 10 days We in mak .q a payment You will also be m
finance charge. the unpaK7 balance !a eac ri day Since your fast payment (of since default if you eo not comp!y with the terms of the P!.:in and your failure to comply .
an advance .t you have no, yet made a payme t!) Is munipltud by the. applrcabta daily ? materially impairs any property you gave d8 so,:unty t ic your ability to repay what you
periodic rate.', he sum of these amounts is !Ole firlance Charge Owed. The balance i owe under R.e Plan. '
used to compute the finance charge is the unpaid ba,ance each day alter pay-rents i The following paragraph applies to borrowers In all other states: You will be in i
i and credits to that balance have been subtracted and any additions to Vie balance d,lautt if you do not make a payment of the amount ret)uapd when it is due. You will j
have been made. In addition to interest, we may charge other finance charges which be in default it you break any promise you made under the Plan or if anyone is ul
are disclosed on the Addendum. U the interest rate is a variable interest rate. Ine t default under any security agreement made in connection with an advance under
Addendum explains how trio vatiabfe interest raze works the Plan. You will be in default if you cite, file for bankruptcy, become insolvent, of you
i SECURITY - You pktdge as secur y let the Plan all shares and dividends and, d any, ( make any false of misleading statements in any credit application or update of credit
all deposits and Interest in all joint and,ndividual accounts you have with us now and information, or It something happens we believe may substantially reduce your
in the future. It a specific dollar amount is pledged for an advance, we will ;reeza ability to repay what you owe. You will be jr, default it any properly you have given
f shares in that account to the extent of the outstanding balance for the advance , us as security is repossessed by someone else, seized under a forfeiture or similar
Otherwise, your pledged shares may be witridrawn unless you are in default. The i law, or if anything e!Se happens that significantly affects the value of the property or
following paragraph applies in all states except in Ohio, Rhoda Island and our security interest in it. You will also be it. defac!f under the Plan if you are in default
Massachusetts: We have a statutory lien tin the shares any dividends and, it any, the ! under arty other loan agreement with us.
deposits and interest in all indvidual and pmt accounts your have will es artd niay i ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers in
e eetc-se our rights under the I,en to the e4enr perritmea W sfa!d Iiw (We are slate Colorado. District of Columbia, Iowa. Kansas. Maine, Massachusens, Missouri.
c-ianered it our name does not todude Ine term 'Feoajaf Green Orion') For all Nebraska. South Carolina and West Virginia: Wl;e- ycu ire n oetault and .tier
twrrowers:Tne statutory lien andlor your pledge will allow us to apply the funds e.ouat:nn n; any riglit you have rider apln+Cap;O state =iw !r cure yniir aotault, vie can
in your account(s) to what you owe when you art: in default. Itie sLitut, icy - oemated itemf`Cltair• pavimc•it ct viv :,;rp 1 ir. r.;lit
Pr'tir? '.-W!;e under 'rlo Plan w't,
o f situ ,e clt not : p la , n r-e .t A, oun! or ay •? r -.
piing rloUce
In t .c:1:1 'OS spec-ai.lx irca. ni 100 t -.t •t i:r . 1'w if y a; •.C i i .
i.
f,Icr r.a secuiiry for rte Pia n mat, J ?,! a :lime „t ,i. n ntr- The following paragraph applies to borrowers in allotherstates except Wisconsin
end Louhmana Wr- n p:,; c n ?a 't •1 r i r •dJ re u, :mod etc >a n,enn
%Pk? p t .•, ' ' r". / r .-.. / F tr. -: _,_i:,e'r' .ii ri: iii :ilr , t Y
ty-:t 1 ',p<,ti as x'CUnI) .•. ,t i J t ;?t It er 0 t ( ) u N P: t t r )ht ?•.r tl:,.e
'le^t in. tx
s,.naccount r.3nle •.rJCh as Q !hl! Scli.lE_ ..: s VNI 01u5. Li .V !7r, 'u
accet'tGbir, rl os v.riti-i yrl, itt:rutr a,i :,rv:;n,^.:• :mini-, !r_,.• ;.t,;.-,ccc•ur:r P,o,rw-v v - The following paragraphs apply to borrowers in all states except Wisconsin and
give as secuf i!y si,'i..uTe ai: :rrncuna ew 7d ? -tie: r._ Par an u ii: o,i,er o .?_ Louisiana: If i•rmec7..er pa,-.r:.:, .. mJ •dec_ sett to pay 1. 'afa5! .rn4
r'i)w' r.!( :n !LE In`l:r P, F t..: pt a y 'an SeC.l f.. • ,Yr' ?ulif pf f^t?3i - r:: .n:? ••rnf you .. e nas b8eir n'-ap piKcb!v. .1101..., •:!'0 .•i W ter? of. it nave arL', us .
Prcpeny securing other :oars YOU r:avE it iral, al•,o Sul: e ;na Pia,,
r6FW -1 1 ,e, .K,:1' ... 1 ..,.. i
Credit Agreement (continued}
LOANLINER' Credit. and Sccuriry too! :n eyercisa our ffgn!- Cn+•!. Vie c..rn en.!cuce this Ftan ,. air t y;_:r
-
at tie default :ale rrcC! :?7 G Ili; .oil :d!:m It a t)_ a^d f m!redfa a p•:Inn -r t ierar repfosar!lat :es. It via ra n{e file terrns _t me Plan y.c -!grr•. tY:a!
has peen mane. yccr S!1 Ve5 and•Cr •7000=1!S 'an r:0 epee';ed ^Villas wna! yCU •ir.9 : ii con!mue to pral(m! US
a5 DrdvijEI Ile s'ti:IGh :rt>ae _ai-O ' Sec,rty' W-! can ) so r?r-r.: , . ;viy or:cr CONTINUED EFFECTIVENESS - I` :ry prlrt f't .. ._ •.!. r r:. .....:!'
rights gwk n by law v:hen v, --u are n lafautt to to :;rentcrCez;o1, the nest w,ft lord.,, in effect
You agree the CreJ;t ;'r•cn ":s the !iif^ ter :axe! {:cr;c:•sslgn :;` acs prue-'I:, tii•,•i NOTICE TO UTAH BORROWERS - ! his ..[teen A:;ir;.... ' 4 d f:ttit crate>5:'.r t.t
'is :BCc.r.'V ur.dGr a ,fp.e r:ah?. t
tr, ...e agreement befwean y.,-,j a:13 m3 ire.h•: Ur r)rr, •,!q •r.'r iC:e%h ,rUrtrr•tcrr! 'rt,:y 1)3!
bec.::h or the pva:e& It N. as'. ic.f Dra 7t56 to de!rvet ! .d p,oper!v RI a hrr,;t are, De contrrtdtted Dy ev,denCe of any oral agreerht,nt
place wc•:h•i0so. If the properry, is a rc,tcr ver;ickt ,-,r t:.at. yci. a:.yee fha! wa may The following is required by Vermont law - NOTICE TO CO-SIGNER - YOUR
onfain a icey or other device nec^:sc ify ill Jnlcrk and oxrata it wh,>n you [re to !SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE
default. pie will rot be fespor.srp•e for any crhef property. not :oveled by this
. IF THE BORROWER DOES NOT PAY
FOR REPAYMENT OF THIS LOAN
y r:e
Agreement, trial you teave msi;le tno property cr ch is anacr.eo to :he D,vpel ,
.
?
will try to return that property to ycu or make it available for you to ctrurn. THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU.
After we have possession of ,".1e per we ran %of! it and apply ine me,niS '"u an
Protf Y I
I The following paragraphs apply if you give security in connection with an
amounts you ewe us. We watt give you notice of any public disposition or the daft. after advance under the Plan. They apply to borrowers in all states except Louisiana.
which a private disposition will be held. Our erpenses for taking possession of and I Louisiana borrowers will execute a separate security agreement. Borrowers in
selling the property will be deducted from the money received from the sale. Those other states may also be asked to execute a separate security agreement.
costs may include the cost of storing the property, preparing it to sate and attorneys THE SECURITY FOR THE PLAN - You give us what is known as a security
fees to the extent permitted under stale taw or awarded under the Bankruptcy Code.
property described in any receipt, voucher or other document you
interest in all
You mull pay any an)ount that remains unpaid after the sale money has been applied receive for an advance (-the Advance'). The security interest you give includes all
to any unpaid balance underline Plan. You agree to pay interest on that amount at the accessions. Accessions are things which are attachec to or installed in the properly ?
same rate as the advance, or, it applicable. at the defauil rate disclosed on the 4 now or in the iuluie. The security interest also includes any replacements for the
Addendum, until that amount has been paid I property which you buy within 10 days of the Advance or any extensions, renewals
The following paragraph applies only to Wisconsin borrowers. When you ate In or refinancing of the Advan.e it also includes any money you receive from s0hrag
default and after expiration of any right you have inner applrcabe state taw to cure your the oroparty or front insurance you have on the property. It the value of the propcrry ,
default, we may require Immediate payment of your outstanding roar balance under the ? declines. you promise to give us more property as secui r; :f asked w do so.
Plate and seek possession of property given as sacurrfy 'rbu may voluntarily gr,e the WHAT THE SECURITY INTEREST COVERSICROSS COLLATERAL PROVISIONS
properly to us it you choose. ar 'ee may see; in ta'•te possession a! the property ry ' - The security,merest secures the Advance described in the receipt, voucher or any ,
ludigal process. It we repossess me pntd+lrty: you agree to pay reasortaD!e expanses other document you receive at the time of the Advance and any extensions, renewals
incurred in disposing of the properly n the properly is a motor vehicle m Tolle nome.. or refinancings of the Advance. It also secures any other advances you have now
trail e,(, sncwrngblle, boat or aircraft, you wis also oe regdued to pay any costs permitted ; or receive in the future under the Plan and any other amounts or loans,
by Section 422.413 of the Wisconsin Statutes You must pay any arrioum that remains including any credit card loan, you owe us for any reason now or in the future,
unpaid after the sale money has been applied to what you owe urufer the Plan. You except any loan secured by your principal residence. if the property is household
agree to pay interest on any unpaid amount at the same rare as the advance, or, it
i goods as defined by the Federal Trade Commission Credit Practices Rule, me
applicable, at the default rate disclosed on the Addendum, until that amount is paid, l property will secure only the Advance and not other amounts you owe
If the property Is located outside Wisconsin at the time of default, we may take OWNERSHIP OF THE PROPERTY -You promise that you own all property you
possession t1I the property without judicial process, it permitted by the state where
you will use
give as security or it the Advance is to buy the property, you promise
the property is located.
{
the Advance for that purpose. You promise that no one else has any Interest in of
! rho following paragraph applies only to Louisiana borrowers: When you are in claim against the property that you have not already told us about. You promise not t
dehavtL we can require immediate payment (acceleration) of the entire unoau3 to sell or lease the property or to use it as security for a loan with another creditor ;
balance under the Plan. You waive any right you have to demand for payment, notice until the Advance is repaid. You promise you will allow no other security interest or
of intent to accelerate and notice of acceleration. If Immediate payment is lien to attach to the properly either by your actions or by operation of law,
demanded, you will continue to pay interest until what you owe has been repaid at PROPERTY INSURANCE. TAXES AND FEES - You must maintain property
the applicable interest rates in effect unless a default rate is disclosed on the i
! Insurance on all property that you give as security under roe Plan. You may purchase i
Addendum, It a demand for immediate payment has been mace. the shares and i the property insurance from anyone you choose who is acceplaoie to rlte Credit
deposits given as securrry for the Plan can be applied towards whal you owe. We Jnion The amount and coverage of the property insurance must be acceptable to
can also exercise any other rights g:en by !aw v;helr you are in default and our
I us. You may provide the property insurance through a policy you already have of
lights under any security agreements you nave w-th us ! Insurance
through a policy you get and pay for YOU promise to make me policy
CANCELLING OR CHANGING THE PLAN - rho following paragraph applies payable to us and to deliver the policy or proof of coverage to us if asked to dg so. '.
only to borrowers in 111irYOis:We have file right to charge the terms of the Plan from If you cancel your insurance and get a refund, we have a light to the refund. It the
time to time after giving you any advance notice requirad by law Any change to the ? property is ldst or damaged, we can use the insurance settlement to repent the i
interest rate or other charges will apply to future advances. f
property Or apply it towards what you owe. You authorize us to endorse any draft or
I
9 paragraph applies only to borrowers in Wisconsin: We can
fol/owln
The f
check which may be payable to you in order for us to collect any refund or benefits ii
change the terms of the Plan from time to time in accordance with Section 422.415 f due under your insurance policy. You also promise to pay all taxes and toes (like
?
of the Wisconsin Statutes. You will be notified of any change in terms An increase registration fees) due on the property.
I
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 If you do not pay the taxes or foal on the property when due of keep it insured. we may
f
pay these obligations. but we are not rehired to do so. Any money we spend for taxes. I
Plan at any time. You may cancel the Plan at any time by giving us prior written
l
th
f th
Pl
d i!
unpaid
will p
nce at the advance
y
ig be
and you
an
ances un
er
e terms o
e
notice. Your obligation to pay the unpaid ba
t
th
nt Ir
I
l
Pl
t
i
h ay
ou a
s
We
at the same rate
interest on those amounts
an, except
e ex
e
e
on cance
t
o
continues whether you of the credit un
e
your liabiiity is limited by Section 422.4155 of the Wisconsin Statutes. receive payments in connection with the insurance from a company which provides the f
Insurance. We may monitor our fears for the purpose of determining whether you and
The following paragraph applies only to borrowers In laws: We can change the other borrowers have complied with the insurance requirements of our loan agreements
terms of the Plan from time to lima after giving you any ad lance notice required oy ', or may engage others to oo so Tl e insuance cnaicre added to an :ay ,lice fray :nci:xie
law. A change, that increases the rate of !inane cnarge or other cttarge. lrai ' 11 the insurance company9 pay!nerts to us ana 121 the cost of deternu ing compf:anim
increases the amount of your payments. or that otherwise aoverseiy affects ecsticg ,,.jtn the ins)ranica requirements. It we add arncurits far „..es fees or Insurance to the
batances will apply to existing Da!anc:s o!rly %I you sgree to the,, crtatnge or you use :.rpatc balance of an advance, we may increase your paymoh-s u, pay the a:•,^uro '
the Plan after receiving notice tnat yo it uce of 11-,? Pian means you agree rr!e added withm the Hsrrr of inn insurance or approximate term of !hr.- advance
change applies to existing hawncee
INSURANCE NOTICE - it yf:u do not purcnace tie required properly Insurance.
The following paragraph applies to borrowers in all other stares: via nave tr:? Ind ,rt5utanCC 'wC may pufch.r!e and charge yet lay will corer only esr interest ,r file
right to change the terms of the F!an rues n-re to urre after c vin; you a u ;ur
Dfoperty. Tine pi°rraum :or this insurance r: ay be !ignr•r De•-.aus<_ one insurance
notice required by law. Any change in ;lie ir.!arost tale will apply to ru:ure advances, company may have given us !rte right to purchase !nsuranca after uti rtsured
and at our discretion and sub eci to airy requirements of aopbcatle taw, w.1! atsc collateial is lost or damaged. The insurance will not be liability insurance and
apply to unpaid balances. will not satisfy any state financial responsibility or no fault laws.
The following paragraph applies to all but Wisconsin borrowers: An increase if'. PROTECTING THE SECURITY INTEREST - If your state issues a title for the
the Italy periodic rate under a variable interest rate is rot considered a change in
property, you promise to have our security,niorest shown on the title We may nave
tarn undue the Plan. Vie can cancer tine entire Plan •or any part of the Plan It any to Ilia what is called a financinrg statement to protec: cur secunt; i,:terms: iri,m the
fence. You may cancel lrte Plan at any time ty giving vs prior woven notice You(
claims of others if asked to du so, you promise to sign a financing state•rent You
obligation to pay the unpaid balances under lne terms of ma Plan continues whether also promise to do whatever else we think is necessary to prote.cl our socially
yw or ine fired I Unroll cancel the Plan. interest :n tole prdperr You prdr^u;e to pay all .csts. ;nc!udr w Cut no; ttmited 1:' ;try ;
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - Vile car, delay attorney fees. we incur in protecting our seCuri'y inlera,,f and rigris it the provenly.
enteccinq arty of out nytas ,.rder ms P'an arty fwTtx•c of tini,s with;l;A losing tree to the extent penn!ttecl by a,:plicanie, lath,.
LOANLINErt_Credit and Security Credit Agreement (Carl linued)
USE OF PROPERTY - n• '^•e tJvan. (, i:1S b r t rJ " 'C/U:10•'11 SP Y 'j :•r
r!i ise ` rIr0¢Gi'i ar_ .ev:; Ican.r .Y) \J:aty,n ;);j, :.rift E•.r. ,
perm si.cnbrfoie r air angel in :he Frnp rt, .;r i,ha- ng !ne coddres5
.?r•.er ! . I,ra- arty ., 6c:?, ,.Si i:-.!CC.. its ,........:) t.eiare ,,r ald(es-
AaCa a°, td inS?:v'Cl .ne or:p,9r`y :,5 r qmp!", , '•f'y , !In pri,(r r!Y rS da;7,19e0
slog r: or at,"eo. ib) Not "t, '.Ne pruper!y 1,ir any :ills,!,! rt_-rp3- 171 Not to
property in another stato adntna leli.rg us
1
NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE
- THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT iO
REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, t
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 tail
to return a motor vehicle that is subject to a security interest, within. thirty days aver
you have received notice of default. The notice wiil be mailed to the address you
gave us It is your responsibility to notify us it your address changes. The maximum
pC ., tGr Uri! -A UI -- r,2 ... r•. ., It u "ioibr .a:'?:C`.i.._ ,ir.' .., .. • ,cn in.. ?i a
?e of S15C.000O
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.
j OF GOODS OR SERVICES OBTAINED WITH THE
PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE
DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE
DEBTOR HEREUNDER.
This novice contains important information about your rights and our responsibilities ! After we receive your letter. we cannot try to collect arty amount you question, or report
under the Fair Crecht Billing Act You are advised to read your monthly statement ? you as delinquent. We can continue to send statements to you for the amount you
and review 4 for arty error discrepanrles or unauthorized trarsactions. ! question. including finance charges. arts we can apply anyainpaid amount against your
NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR credit limit. You do not have to pay any questioned amount while we are mvesfrgaling,
STATEMENT. It you chink your statement !s wrong. or it you need more Information l but you are still obligated to pay the parts of your statement that are not in question.
about a transaction on your statement, write us or. a separate sheer at the aaaress It we find that we made a mistake or your statement, you will not have to pay any '.
listed on your statement You are required to notify us in writing within 60 days finance charges related to any questioned amount. If we didn't make a mistake, you
following the dale an which we sent yo'ut statement wherein the error or problem ! may have to pay finance charges, and you will have to make up any missed !
first appeared regarding any discrepancy or unauthorized transactions an your f payments on the questioned amount. In either caso. we will send you a statement '
account. Failure to notify us may result in your acceptance of any responsibility for of the amount you owe and the date that it is due.
payment or reimbursement to us for any such error or discrepancy on your account. If you fail to pay the amount that we ttiink you owe, we may report you as delinquent.
Write to us as soon as possible. You can telephone us. but doing so wilt not However, it our explanation does not satisfy you and you write to us within ten days
preserve your rights. telling us that you still refuse to pay, we must tell anyone we report you to that you
in your letter, give us the following inbrmation: have a question about your statement. Ana. we must tell you the name of anyone
Your name and account number. we reported you to. We must tell anyone we report you to that the matter has been ;
settled between us when it finally is.
The dollar amount of the suspected error. ! If we don't follow these rules, we can't collect the first 5 ,0 of the questioned amount. !
Describe the error and explain, it you can, why you believe there is an error. I even if your statement was correct.
it you need more information, describe the den you are not sure about.
f SPECIAL RULE FOR CREDIT CARD PURCHASES - it you have a problem with
it you have authorized us to pay a credit card account automat"0y from your share the quality of property or services that you purchased with a credit card. and you +
account or checking account, you can stop the payment on any amount you think is I have tried in good laith to correct the problem with the merchan!, you may have the
wrong- To stop the payment your letter must reach us three busiress days before the right not to pay the remaining amount due on the property or services. There are two
automatic payment a scheduled to occur limitations on this right: (a) You must have made the purchase in your home state or,
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR if not within your home state, within 100 mites of your current mailing address, and
WRITTEN NOTICE • We must acxnowledge your letter within 30 days. unless we I (b) The purchase price must have been more than 550.
have corrected the after by then. Within 90 days. we mu„ either correct the error or ! These limitations do not apply i) we own or operate the merchant, or if we mailed j
explain why we believe me statement was correct. I you the advertisement for the property or services.
In this Agreement, the words you and your means each and all of those who apply i line only by written appfication to us, which must be approved by our credit commillee
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
j 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 i
1, RE5PONStBIUTY - Uwe issue you a taro, you agree to repay ag 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 exempts, Agreement at any time. but termination by either of us does not atlecl your obligation
you are responsible for charges made by yourself, your spouse and minor children. to pay the account balance.
i You are also responsible $or charges trade by anyone else to whom you give the S. CREDIT INFORMATION - You auinonze us to investigate your credit standing j
'
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, trot we wig close the account for new transactions it you mformatior regarding your account to credit bureaus and other creanors who inquire
so request and return all cards. Your obligation to pay the account baience conhnues of us about your credit standing
oven though an agreement, tl,vorce tk.cree or other court judgment to which we are 6. MONTHLY PAYMENT - We will mad you a statement every mbrith showing your '
not a parry may direct you or one of rte other persons responsible to pay the account. i Previous Balances of purchases and cash advances, the current transactions on your
The cards remain our property and yuu niust recover and surrender !o us all cards account, [tie remaining cretht available snider your Credo Lane, me, New Wilances of ,
uDOn our request and upon lerntinaUOn of this Aire°.rv!^.t purchases and cash advances, the Total New Balance. the Flnarv:e Charge due to date.
2. LOST CARO NOTIFICATION - It you believe Ine card has been lost or stolen. and any other ogled fees, and the Minimum Payment required. Every month you must pay
you will immediately call the Credit Union at 1717) 234-8494 or i.9001 23: - 7328. After at least !ire Minimum Payment within 25 days of your statement closing date. By separate
hours call 1800) 556-5678 t agreement you may authorize us to charge the minimum payment automatitaay to your
share or checking account with us. You may, of course, pay more 'roquently, pay more
3. LIABILITY FOR UNAUTHORIZED USE -A j agree to nabty i imrned atery. waAy than the klirimum Payment, or pay tow Total New Satance In lug, and you will reduce 'he
or in wrung of the loss, lrett or urtat;trXxii..•d Use of you! Cre(iit Card 1';;u may be Marie finaw* charge by doing so. It your monthly payment exceeds the iota! credit lire balance
for the unauthorized use of your Credit Cara. You wiG not br; liable for unaLMOnzed use meal, we will automatically post the credit to your St shares
that pi'CUrS alter ya•U notify try of !tie 10.,5, Inch, or possible unaultlari:EY7 use. YOU will have The minimum payment will be (a) 2"0 of your Total New Balance
rounded up to the
no laoiury lair unautnorizoo purchases made with your C10',11 Card. unless you are aressty ,
I next even dollar, or (b) S20.0O, whichever is eater. In addition. a: any time rY i your Total
ne,,49eni in the handi:n of yo..ir Card In any c3sr. yixir !vaulty vng not exceed S60 New Balance exceeds your Crew Line. you n Est anmed,ately pa•r the excess up•.rr, wui
4. CREDIT LINE - it Ne approve your appit, [ui0n, we will eslablisn a s0- i demand. We will apply payrriews in the foit.,Ymna manner first in rnevious late 'rros.
repienishmg Lane of Credit for you and notify 4Ju of ;i, amount when we issue the teen !o previous cash aevinces f:nan;:a rrarge5 then tq
`card. You agree not to le: the a,^,oaY. ^a! Ilce ey^.2fC !'LS ; ,,',r0VC•d CrC-w Line Fac^
i ,,!%ar ton 13 Curr.>n .. ico
c
065. F f 'a:,? e5 Ih6r lU tir'n:r. :;<iSR :: i1S:1'tcF-
Hyman! you make on !r, _ ecccun! r;i!i te5torn -p=Jr rc:v:; L i. ,e by e of tL? p,ev:C sour: base tra!a ,C2s ir, t^z iirCnr that Sr, e t t ?sty:J ey w t lc ;,titr aiscc ii* an
payman! v,t:Cr. is apa:,e....? ,r. yo;_,; C¢sl.: r; curte"ll :..1.1- d....,u _E ba. „roes and vir.n 0.c, c_:te" , ui .,as.- Ci:arce=.
Visa_Credir Card Agreemenr dnd rrufh !tl Lending Disclosure (confinued) - •-1'• rett.rme-1 : i' tc:!omen! 'r,;: -n o. ?c. -,fns ; 1 :i•. -
- --- -------- ---------- ---- °- -- ;ine ut the irl OI:lG'1 to vCrtr it:c ^..? .y S_? L..,,. n•,,;y
7. FINANCE CHARGES - 1•tiu .3 0:d rho F;rvan^.,: Charge .. pi;r,:hscr, .. -i.ke a reasonable change lcr phnh- }r•?s ::I 5?rp$ p?.;..-:.;y :.- :ei,t
pay,ng the t,i!t amourr of the Ne%v Eiatance of Pu:ctit+sai earn coon',n within 25 days 10. OVERDRAFT OPTION - It you oleo: 10 overdra!t t3 your PSECU V sa Cred:
of your statement closw.g date. Otherwise, lh _ New Balance of Purchases. and the I Card; !hat election is subject 101119 exrsllr-:g aedn 1311i, and *ce agreement it rep:%sents i
subsequent purchases from the de!9 they are pOStpd t0 year aGrOuni• will be subject 1 and the current loan policy at the hme of the Ovetdratt. *to., al,c Jnderslar.d trial a't
to Finance Charge. Casn advances are always subject to Finance Charge from !hr,
overdraft will be considered me same as a cash advance c: your PSECU V: sa ('wrht
date they are posted to your account Card and that the current Annual Percentage Rate for co;h ado, r:;;e, will apWy
Purchases: We calculate your finance chatae by muWp,ying the average adjusted 11. RETURNS AND ADJUSTMENTS - Merchants and -:hers who nonor the carv
da,ty balance (see explanat>•on below), mclud.ng new purchases, lot the billing cycle , may give creda 'or returns and adjustments, and they iAl oc so by send'n us a
by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE j credit slip which we wilt pdS! to your visa nne cf cred:r If your ',edit and nayrr."eats
RATE as disclosed on the Addendum, exceea what you owe us, we wai autorr.aw;atiy peat ;he a.n <r, :,:curt t t: nr•.c: t.
Cash Advances: We cakculate your finance charge or, cas`: advances try ! your S1 Shares within 75 days 11 file balance Is one do,:tar cr mirn:. ::ptnl yot,r
multiplying the average adjusted dally Dafance see expiana:ion oeizw; !ur cast, ' vintter request. we w:11 refund the credit Cara-lco to you
advances during to billing cycle by the rho^:nty periouic a0vanec ra:2 aria 12. FOREIGN TRANSACTIONS -The exrhartgt iJt uet• +c:+ tole tfuni ,or,
corresponding ANNUAL PERCENTAGE RATE as o souse+] on lne Aoeendunl urren+_y and the billing currerxy us k7 ter processing nterrac: ,nat'ra:? ar tors i5 a rate
Balance Computation Method j selected by Visa from the rage of rates avaitaote in wtisieswe currency markets for the
Average Daily Balance for Purrhase?. - The Average Daily Balance for Purchase applicable central processing date. which rate may vary from the rate Visa itW-1
Transactions is calculated by aadi'tg the Oany Balances (Purchase Ttar:sect cn} tar j receives, or a government•nandated rate in effect for the tippfica 4e cen!rx proceSSrng
each day in the bitting cycle, and then cirlding by the number of days in the billing ` date. In each instance, an adjustment may be assessed based on the iSA fee imposed
cycle. To calculate the Daily Balance tot purchases each day. we take the kwuwing i by Visa" This lee, which totals 1% of the transaction amourt, will be assessed on aN
steps- We take the outstanding balance (all amounts you owe) at the start of the day. transactions where the merchant country dtlfers from the caunlry of the card issuer.
Then, in the sequence in which amounts are posted to your account, we add the i 13. SPECIAL RULES FOR VISA PURCHASES - if you disagree or find an error
amounts of all debits and subtract the amounts of all credits or payments which post ; with a Visa transaction, and have tried in good faith to correct the problem with the
to your account that day After applying payments and credits, we subtract the merchant or the charges are the result of unauthomzeo or fraudulent use. or your
amount of any unpaid Finance Charges or Late Charges. Then we also subtract the purchase cost more than S50 and was made from a plan merchant in your stale
amount of any Cash Advance Transactions that posted to your account on that day or within 100 miles of your home, contact PSECU. i
in any previous day in the tlaitng cycle.This gives us the Daily Balance for purchases. 14. DISPUTED TRANSACTIONS - You are required to nohfy PSECU in writing
Average Daly Balance for Cash Adtrarrces - Cash Advance Transactions which are within 60 days following the we on which we sent your statement wherein that error
posted to your account .are not included in the Average Daily Balance calculation for or problem first appeared regarding any discrepancy or unauthorized transaction on ,
purchases, and are therefore not subject to the monthly periodic rate for purchases. The r your account. Telephoning PSECU does not preserve yos dispu!r, rights You may,
Average Daily Balance is calculated separately for Cash Advances and is subject to the j be required to provide us with documentation to support your dispute claims in
Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transacijorts i addition, you may be required to complete a standard o;sputo form outlining the
is calcu:alod by adding the Daily Balances (Cash Transaction) for each day in the billing ' details of your dispute. In cases of fraudulent card use. PSECU will also require a
cycle, and than dividing by the :climber of days in the billing cycle. To calculate the Daily j notarized affidavit. In some cases we may ask you it, notify the local authorities.
Balance lot cash each day. we take the following steps: We take the outstanding balance j If we do not receive the proper requested documentation in me time specked you
(all amounts you owe) at the start of the day. Then. in the sequence in Which amounts i may be held responsible for the transaction(s) in queslirn. PSECU must adhere to
are posted to your account, we add the amounts of all debits and subtract the amounts strict dispute limeframes set forth by Visa.
of ail credits or payments which past to your account that day. After applying payments t
and credits, we subtract the amount of any unpaid Finance Charges or late Charges. 15. SECURITY INTEREST - To secure your acccurl, you gram us a purchase f
Then we also subtract the amount of art/ Purchase Transactions trial posted to your money security interest under the Uniform Commercial Code in any gooris you j
account on that day or in any previous day in the baling cycle. This gives us the Daily purchase through the account. If you default, we will rave the right to recover any of
Balance for Casa Advance Transactions. Note: Cash Advances are always subject to ; these goods which we have not been paid for through our application of your
+ finance charges and from the day they are posted to your account. payments in the manner described in the Monthly Payment section. With respect to i
this account only. we will not assert any statutory right we may have if you are in
Payments are applied in the following manner: first to previous late fees, then Id default to prevent withdrawal of your unpledged ciodrt union shares (Deposits)
previous cash advances finance charges, then to previous purchase finance j below the unpaid balance of your account. However. it you give or have given us a i
charges, then to current (ale Wes, then to previous cash advance balances, then to I specific pledge of your credit union shares (Deposits) by signing the Pledge of j
previous purchase balances in the order that they were posted to your account, then I Shares or otherwise, or any other security interests for all your debts, your account
to current cash advance balances, and ther. to current purchase balances Credits I will be secured by your pledged shares (Deposits) and by rho Property described in
ate applied first to the particular type of debt which is being credited, it any, and then those other Security agreements, except for your home.
to the balance of your account, i 16. EFFECT OF AGREEMENT - This Agreenwr• is Ire Contract vntrn applars to
Note also that if the total of me payments and credits which are posted to your j all transactions on your account even though tree sales casim amance, cc:-dil or
account by the Payment Due Date shown on a statement is equal to or exceeds the j other slips you sign or receive may contain c iflerenl terms ''We may amend the
New Balance shown on that statement, we will not apply the Monthly Periodic Rate Agreement from time to hme by setidnng you trie advance wnnen notice requireo by
to your Account on your nex; statement yaw. Your use of me card thereafter will indicate your agreemenf to tr.e nmordrnems
8. DEFAULT -You wilt be in oetault it you fad !0 make any Mtn<murr.. Payment witL',ri 1 TO the extent the law pdrmas, and we indicate in our notice, amendments will apply
25 days afler your monthly statement closing cite You authorize us to transfer tuncm i :o your existing account balance as well as to f.;ture transactions
sufficient !c make the minimum payment due it your Visa loan Is ,n default You will 17. LATE PAYMENT CHARGE - If your M n:murn Payment m not recerved by the
also be in default if your ability to repay us is materially reduced by a change it, your 'rrst day of the month following your cue da!e, you will bit suojrct to a S20 chat<ije.
employment, an increase in your obligations, bankruptcy or nsutvency procn+idrngs I 18. RUSH FEES - You may incur additional r. merges for rush t rucessing am rush
involving you, your death or your failure to abide by this Agreement, or if the value of I delivery, of taros ana'or PIN manes
ous security interest materially declines. We have the right to demand immediate I
payment of your full account balance it you defaua, subject to our grving you any 19. OVER LIMIT FEE-AS20tee will beappledlot earn nicnthly slatement closing late
notice required by law. To the exiert permitted by law, you will also be requ red to pay on which the olrtsanding balance exceeds, fie assgrnc d peort limit by ni0re than S I GC
our collection expenses, including tour costs and reasonable attorney fees 20. DRAFT COPIES - You may incur an aJJitional charge for transaction
9. USING THE CARD - To make a purchase or cash advanca, there arc two summary/sale draft documentation.
alternative procedures to be followed- One is for you to present the card to a 21. COPY RECEIVED - You acknowledge receip! of a co.y of this Agreement
Participating Visa plan merchant, or another financial institution, and, sign the sales 22. ILLEGAL TRANSACTIONS PROHIBITED - You ?grin that you will not use j
or cash advance draft which wily be unprirted with your card. The Other is tP complete i your card for any transaction that rs !!logat under appncathle federal. sriue. or loci;' taw
the transaction by using your Personal Identification Number (PIN) in conjunction
with the carom an Automated Teller Machine or ott:or type of electronic terminal that 23. NO USE - Inactive Visa accounts inat i i e nc -_.zarhase or c i-t a+: nit t•, -•sly
provides access to the visa system. you agree that you svdl not use lour card k,r any be closed without nonce in you after 18 r-onth, c,1 n,z w, i!y
Ir3^ saction that is .1egai undt•I a;p'icabie led;?ml• state, or iocat law :Tie monthly 24. NEURAL NETWORK - PSEC 1 use's neural nur :Ork system; m pro:lrct and
statement w.-';l identify the mocrarl, -i ecir:^:iir terrri"nal w lirtanc,al mn$htt,t-on al prevent urauthorzed lransachOrs Ttlete may be t>CCas"ons ;hen 3 ir'ir ?Ea;;!:cr. is
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EXHIBIT "B"
U
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-05374 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE EMPLOYEES
VS
NELSON WILLIAM H JR
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
NELSON WILLIAM H JR but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE ,
NOT FOUND , as to
the within named DEFENDANT NELSON WILLIAM H JR
117 E POMFRET STREET
CARLISLE, PA 17013-3315
PER MOTHER, DEFENDANT LIVES AT SAFE HARBOR HOMELESS SHELTER IN
CARLISLE.
Sheriff's Costs: So answers:
Docketing 18.00
Service 5.00
Affidavit .00 R. Thomas ine
Surcharge 10.00 Sheriff of Cumberland County
Not Found 5.00
38.00 VAN ECK & VAN ECK
09/16/2008
Sworn and Subscribed to before
me this day of
A. D.
EXHIBIT "C"
Summary Report
Page 1 of I
Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes entered poorly, processed
incorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this system
supplies, it should be independently verified. For Secretary of State documents, the following data is for information purposes only and is not an official
record. Certified copies may be obtained from that individual state's Department of State.
Accurint does not constitute a "consumer report" as that term is defined in the federal Fair Credit Reporting Act, 15 USC 1681 et seq. (FCRA).
Accordingly, Accurint may not be used in whole or in part as a factor in determining eligibility for credit, insurance, employment or another permissible
purpose under the FCRA.
Your DPPA Permissible Use: Civil, Criminal, Adminictrotive, or Arbifral Proceedings
Your GLBA Permissible Use: Use by Persons Holding a Legal or Beneficial Interest Relating to the Consumer
Summary Report
Date: 07108110
Reference Code: 46931-316
Subject Info AKAs Indicators
o
(Best Informa r Subject) Names Associated with Subject)
Na LLIAM H NELSON JR WILLIAM H NELSON Bankruptcy: No
D e of Birth: 1969 DOB: 411969 Age: 41 SSN: 188-54-)o= Property: No
Age. WILLIAM NELSON Corporate Affiliations: No
SSN: 188-54-:o= issued in Pennsylvania DOB: 1969 Age: 41 SSN: 188-54-xxxx
between 11111975 and 12131111976
Address Summary (4 - Probable Current Address) t ?/1
117 E POMFRET ST, CARLISLE PA 17013-3315, CUMBERLAND COUNTY (Sep 2006 - Ju 2
Neighborhood Profile (2000 Census)
Average Age: 32 Median Household Income: $21,512 Median Home Value: $61,700 Average ears of Education: 13
117 W POMFRET ST, CARLISLE PA 17013-3219, CUMBERLAND COUNTY (Oct 2002 - May 2010)
Neighborhood Profile (2000 Census)
Average Age: 33 Median Household Income: $18,365 Median Home Value: $93,000 Average Years of Education: 12
700 RUPP AVE APT 12, MECHANICSBURG PA 17055-8416, CUMBERLAND COUNTY (Oct 1995 - Mar 2006)
Neighborhood Profile (2000 Census)
Average Age:47 Median Household Income: $45,950 Median Home Value: $144,300 Average Years of Education: 13
670 3 RIVER RD # 1, HALIFAX PA 17032, DAUPHIN COUNTY (Oct 2002)
Neighborhood Profile (2000 Census)
Average Age:37 Median Household Income: $48,158 Median Home Value: $112,000 Average Years of Education: 13
207 CONODOGUINET AVE APT 1, CAMP HILL PA 17011-4155, CUMBERLAND COUNTY (Sep 1996 - Apr 2002)
Neighborhood Profile (2000 Census)
Average Age:39 Median Household income: $58,542 Median Home Value: $108,100 Average Years of Education: 14
700 RUPP AVE APT 12, CAMP HILL PA 17011, CUMBERLAND COUNTY (Oct 1995)
Neighborhood Profile (2000 Census)
Average Age:44 Median Household Income: $47,361 Median Home Value: $114,700 Average Years of Education: 14
700 RUPP AVE APT, CAMP HILL PA 17011, CUMBERLAND COUNTY (Oct 1995)
Neighborhood Profile (2000 Census)
Average Age:44 Median Household Income: $47,361 Median Home Value: $114,700 Average Years of Education: 14
700 RUPP AVE APT 12, SHIREMANSTOWN PA 17011, CUMBERLAND COUNTY (Sep 1995)
Neighborhood Profile (2000 Census)
Average Age:39 Median Household Income: $52,500 Median Home Value: $123,500 Average Years of Education: 14
700 RUPP 12, SHIREMANSTOWN PA 17011, CUMBERLAND COUNTY
Neighborhood Profile (2000 Census)
Average Age:44 Median Household Income: $47,361 Median Home Value: $114,700 Average Years of Education: 14
ttps:J/secure.accurint.com/app/bps/report 09-5:37,4 7/8/2010
h
EXHIBIT "D"
Person Search
Page 1 of 2
24f7 Search and Technical Assistance 1-866-277-8407
Main Menu W Account I Print I Contact Us Log Out
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Last Name First Name Middle Name SSN
1? 188-54-2961
Street Address City State Zip County Radius
(-
Phone DOB Age Range
(- Search for other possible name spellings F Include Bankruptcies
Output Type: t: Formatted HTML, r Cut and Paste 1 Printer Friendly Text (No Reports)
Important: The Public Records and commercially available data sources used in this System have errors. Data is sometimes
entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upor. as definitively
accurate Before relying on any data this system supplies. it should be independently verified. For Secretary of State documents. the
following data is for information purposes only and is not an official record. Certified copies may be obtained from that individual
state's Department of State. The criminal record data in this product or service may include records that have been expunged,
sealed, or otherwise have become inaccessible to the public since the date on which the data was last updated or collected.
Accurint does not constitute a "consumer report" as that term is defined in the federal Fair Credit Reporting Act. 15 USC 1681 et seq
(FCRAi Accordingly, Accurint may not be used in whole, or in pail as a factor in determining eligibility for credit insurance.
employment or another permissible purpose under the FCRA.
Search completed
SEARCH: SSN: 188542961
'i All Full Name
ON WILLIAM
@LSON
a
@#
]
c`=
Gender. M
l
DOB:
1969 (41)
%xMa 0it
*?'T copy
WS01bocuopy
Reference Code:
46931-316
Records: 1 to 10 of 10
SSN Address
188-64-xxxx 117 E POMFRET ST
CARLISLE PA 17013-3315
WILLIAM H NELSON JR186-64-xxxx
Gender: Male
DOB:
1969 (41)
WILLIAM H NELSON JR188-64-xxxx
Gender. Male
DOB:
1969 (41)
WILLIAM H NELSON JR188-64-xxxx
Gender. Male
DOB:
1969 (41)
Sep 06 - Aug 10
117 W POMFRET ST
CARLISLE PA 17013-3219
Oct 02 - Jul 10
700 RUPP AVE APT 12
MECHANICSBURG PA 17055-8416
Oct 95 - Mar 06
670 3 RIVER RD # 1
HALIFAX PA 17032
Oct 02
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WILLIAM H NELSON JR188-64-xxxx 207 CONODOGUINET AVE APT 1 • Relatives
Ft ® Gender: Male CAMP HILL PA 17011-4155 • Neighbors
DOB: • Associates
1969 (41) Jun 99 - Apr 02 • Relatives,
Neighbors
Associates
• People at
Work
WILLIAM H NELSON JR188-64-xxxx 700 RUPP AVE APT • Relatives
® Gender. Male CAMP HILL PA 17011 • Neighbors
DOB: • Associates
1969 (41) Oct 95 • Relatives.
Neighbors
6
Associates
• People at
Work
WILLIAM H NELSON JR188-64-xxxx 700 RUPP AVE APT 12 • Relatives
4C COPY Gender: Male SHIREMANSTOWN PA 17011 • Neighbors
DOB: • Associates
0411969 (41) Sep 95 - Oct 95 • Relatives,
Neighbors
8
Associates
• People at
Work
rta
0 WILLIAM H NELSON JR188-54-xxxx 700 RUPP 12 731-9761 • Relatives
If 6D a lo
- @00 Gender. Male SHIREMANSTOWN PA 17011 • Neighbors
DOB: • Associates
04/1969 (41) • Relatives,
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8
Associates
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WILLIAM NELSON 188-64-xxxx 207 CONODOGUINET AVE APT • Relatives
1011.0 c w Gender: Male CAMP HILL PA 17011-4117 • Neighbors
DOB: • Associates
1969 (41) Sep 96 • Relatives.
Neighbors
8
Associates
• People at
Work
WILLIAM NELSON 188-54-xxxx 700 RUPP AVE APT 12 • Relatives
RON Gender. Male MECHANICSBURG PA 17055-8416 • Neighbors
DOB: • Associates
1969 (41) May 96 • Relatives,
Neighbors
Associates
• People at
Work
Records: 1 to 10 of 10
SEARCH: SSN: 188542961 Edit Search New Search
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EXHIBIT "E"
50 North Fifth Street
P.O. Box 942
Reading, PA 19603-0942
Tel 610.376.6651 Fax 610.376.5243
www.barley.com
July 12, 2010
To. Postmaster
U. S. Postal Service
Carlisle, PA 17013
REQUEST FOR CHANGE OF ADDRESS
OR BOXHOLDER INFORMATION
Kelly Cunneen, Paralegal
Direct Dial Number: 717.399.1528
E-mail: kcunneen@barley.com
Please furnish the new address for the following individual or verify whether or not the
address given below is one at which mail for this individual is currently being delivered. If the
following address is a post office box, please furnish the street address as recorded on the
boxholder's application form. Also include any address listed on a permanent change of address
order application (Form 3575):
Name (if known).- William I1. Nelson Jr.
Last Known Address 117 E. Pomfret St
City, State, ZIP Code Carlisle PA 17013
The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii):
I, Cal --city of requester (e.g., process server, attornev, party representing himself):
Attorney.
2. The names of all known parties to the litigation: Pennsylvania State Employees
Credit Union vs. William 11. Nelson Jr.
3. The court in which the case has been or will be heard: Cumberland County Court
of Common Pleas.
4. The docket or other identifying number if one has been issued: 08-5374
5. The capacity in which the customer is to be served (e.g., defendant or witness):
Defendant, William 11. Nelson Jr.
Reading • York • Lancaster • Berwyn • Hanover
Postmaster
July 12, 2010
Page 2
6. A brief description of the nature of the litigation (e.g., domestic relations, personal
injury, property damage, indebtedness): indebtedness.
I certify that the above information is true and that the name and/or street address of the
customer is needed and will be used solely for service of legal process in connection with actual
or prospective litigation.
Barley Snyder LLC
Address
50 N. Fifth Street P.O. Box 942
Address
Reading, PA 19603-0942
City, State, ZIP Code
FOR POST OFFICE USE ONLY
FORWARDING:
Name
Street Address
City, State, ZIP Code
No change of address on file.
Not known at address given
Moved, left no forwarding address.
No such address.
Postmark
170" 0
? 15
uses
S78181
Kelly Cunneen, Paralegal
Printed Name
EXHIBIT "F"
Person Search
My Accurint People Business Assets Licenses Phones Courts
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Last Name First Name Middle Name SSN
?- F_ F_ 188-54-2961
r Inclunr: name Yaiiah.?n5 ;(?
Street Andress At (City-- state 11 Zip
i I F_ F
County Radius
Phone A DOB A Age Range
(
1.. InUudc L'ankruptdi. AS
Reference code: 46931-316
Person Search Results
Search Terms Used - SSN: 188542961;
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..._....... .............
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c Gender: Male CARLISLE PA 17013-3315
DOB: 0411989 (41) Sep 00 - Oct t 0 Neighbors
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188-54•xxxx __ _.__._._._.....____._...._....__.._......_.._..._......._..._......_..._....
117 W POMFRET ST ............_....................................._...._.......__.... ............................._..__..._........._......__......__..._.........._._..................__....
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Gender: Male CARLISLE PA 17013-3219
DOB: 1969 (41) Oct 02 - Sep ' 0 Neighbors
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c Gender: Mete MECHANICSBURG PA 17055841e
DOB: 0411969 (41) Oct f,5 Mar Oft Neighbors
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4. WILLIAM H NELSON JR 18844-xxxx 670 RIVER RD a 1 Relatives
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S. a WILLIAM H NELSON JR 188.54-xxxx 207 CONODOGUINET AVE APT 1 Relatives
Gender: Male CAMP HILL PA 17011 -4155
DOB: 1969 (41)
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SHIREMANSTOWN PA 17011
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LexisNex's. About 1"'Nexis I T""$ 8 CcnUltions
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;,9Edit Search '} New Search his Print Result. dj Export to Excel
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08-5374
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
2010 DEC -3 Ply 3: 56
OF '"'PROTHONOF
VARY
V
U)y rLV COUNT
PENNSYLVANIA
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
WILLIAM H. NELSON, JR.
Defendant
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 08-5374
AFFIDAVIT IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE
PURSUANT TO SPECIAL ORDER OF COURT
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF LANCASTER
SS.
SHAWN M. LONG, ESQUIRE, being duly sworn according to law, deposes and says
that he is the attorney of record for the Plaintiff, Pennsylvania State Employees Credit Union,
and that the following is an itemization of the efforts taken by the Plaintiff to locate the
Defendant, William H. Nelson Jr. to effect service under the provisions of the Pennsylvania
Rules of Civil Procedure, without success.
1. The Sheriff of Cumberland County attempted service of the Complaint upon the
Defendant at 117 E. Pomfret Street, Carlisle, Pennsylvania 17013. The Sheriff's return indicates
"per Mother, Defendant lives at Safe Harbor Homeless Shelter in Carlisle."
3062300-1
08-5374
2. On July 8, 2010, Plaintiff's Counsel performed a search on
www.accurintsearch.com. The information received from the Accurint search indicates an
address of 117 E. Pomfret Street, Carlisle, Pennsylvania 17013.
3. On September 8, 2010, Plaintiff's Counsel performed a search on
www.accurintsearch.com. The information received from the Accurint search indicates an
address of 117 E. Pomfret Street, Carlisle, Pennsylvania 17013.
4. Plaintiff s counsel prepared and mailed a Change of Address Request form to the
Carlisle, Pennsylvania Post Office for the address of 117 E. Pomfret Street, Carlisle,
Pennsylvania 17013.
5. The response to the Change of Address Request from the Carlisle Post Office
indicates "not known at address given."
6. On November 11, 2010, Plaintiff's Counsel performed a search on
www.accurintsearch.com. The information received from the Accurint search indicates an
address of 117 E. Pomfret Street, Carlisle, Pennsylvania 17013
7. The Plaintiff has exhausted all reasonable efforts to serve the Defendant, William
H. Nelson Jr.
Sworn to and subscribed before me
this
1?7 I-ei da of A I V , 2010.
Notary Public
My Commission Expires:
CQMMOt4WEAL OF PENNSYLVANIA
Notefial Saw Public
Colleens M. [)a'nej j M* county
C" of L.encM - April 17120`13
My CommIssw
Member, Pannsytvants AssoGetion of Notaries
3062300-1
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
PLAINTIFF
V.
WILLIAM H. NELSON, JR.,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
08-5374 CIVIL
ORDER OF COURT
AND NOW, this 8th day of December, 2010, upon consideration of the Plaintiff's Motion
for Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts
to ascertain the present whereabouts of Defendant has been unsuccessful, Plaintiff's Motion is
GRANTED.
IT IS HEREBY ORDERED AND DIRECTED:
1. That the Plaintiff is directed to serve the Complaint upon Defendant by posting a copy
of the Complaint upon the premises at 117 East Pomfret Street, Carlisle, PA 17013;
2. That the Plaintiff serve the Complaint by certified and regular mail to the Defendant's
last known addresses at 117 East Pomfret Street, Carlisle, PA 17013;
3. That the Plaintiff effect service by publication to include the notice prescribed in
Pa.R.C.P. 430, in a legal journal and newspaper of general circulation in Cumberland County,
Pennsylvania;
4. All future service of legal papers, including but not limited to motions, petitions and
rules be made by certified and regular mail to Defendant's last known addresses.
By the Court,
S-? hawn M. Long, Esquire
Attorney for Plaintiff
?Iliam H. Nelson, Jr.
Defendant
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08-5374
BARLEY SNYDER LLC
Keith Mooney, Esquire
Court I.D. No. 74001
50 :north Fifth Street
P.O. Box 942
Reading, PA 19603-0942
(610) 898-7155
FILED-OF "CE N,
C Thy PROTHONOTAR
CUMBERLAND ANi A "
EN
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Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
WILLIAM H. NELSON, JR.
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 08-5374
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in the above-captioned action.
BARLEY SNYDER LLC
31368091
Keith Mooney, Esquire
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
Court I.D. No. 74001
50 North Fifth Street
P.O. Box 942
Reading, PA 19603-0942
610.898.7155
D
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SHERIFF'S OFFICE OF CUMBERLAND COUNTS = !
n s
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy c- :rm
Richard W Stewart
Solicitor
Pennsylvania State Employees Credit Union
Case Number
vs.
William H. Nelson, Jr. 2008-5374
SHERIFF'S RETURN OF SERVICE
02/22/2011 07:40 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February
22, 2011 at 1940 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: William H. Nelson Jr., pursuant to order of court by posting the premises located at 117
E. Pomfret Street, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy
according to law.
ROBE T BITNER, DEPUTY
SHERIFF COST: $39.40
February 23, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
to., ; .. ^o-, I't i
BARLEY SNYDER LLC
Keith Mooney, Esquire
Court I.D. No. 74001
50 North Fifth Street
P.O. Box 942
Reading, PA 19603-0942
(610) 898-7155
OF TNt PRC fd NOT?
1011 APR - R14 1: C
CUMBERLAND comTY
PENNSYLVANIA
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
WILLIAM H. NELSON, JR.
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 08-5374
VERIFICATION
Kelly Cunneen, hereby verifies that on February 18, 2011 the reinstated Complaint was
mailed by first class and certified mail to 117 East Pomfret St., Carlisle, PA 17013, on February 22,
2011 the reinstated Complaint was posted by the Cumberland County Sheriff at 117 East Pomfret St.,
Carlisle, PA 17013, and on March 4, 2011 Legal Notice was published in The Cumberland Law
Journal and The Sentinel, in accordance with Order of Court dated December 8, 2010. Proofs of
mailing, the Sheriffs Return, and Legal Notice are attached hereto and marked Exhibit "A".
BARLEY SNYDER LLC
1
Dated: April 5, 2011 By:
Kelly Cun en, Paralegal
126 East K1 g Street
Lancaster, PA 17602
717.299.5201
31825541
EXHIBIT "A"
TO.WILLIAM H. NELSON JR.
I 117 EAST POMFRET STREET
CARLISLE, PA 17013
SENDER:
t KC
REFERENCE:
1 PSECU/ NELSON
e
7196 9006 9040
PS For, 3800 0099 0111
2005
RETURN Postage
i RECEIPT
Fee
SERVICE '
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Retum Receipt Fee
Restricted Delius 1 . b
Total Plpstage & Fees
US Postal Service P
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OSTAAA 60
Receipt for
Certified Mail ,
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Coverage Provided
Do Not Use for International Mail
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US POSTAGEE-1
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith MOM of cumbtN4
Chief Deputy
Richard W Stewart
Solicitor COKE CF rsE SNERjFF
Pennsylvania State Employees Credit Union
vs.
William H. Nelson, Jr.
Case Number
2008-5374
SIAM 'S RETURN OF SERVICE
02/22/2011 07:40 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February
22, 2011 at 1940 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: William H. Nelson Jr., pursuant to order of court by posting the premises located at 117
E. Pomfret Street, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy
according to law.
SHERIFF COST: $39.40
February 23, 2011
r
ROBE T BITNER, DEPUTY
SO ANSWERS,
6?:
RON R ANDERSON, SHERIFF
tc Cot ^toante Te:eos; t lr
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
March 4, 2011
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
L sa Marie Co4neitoi SWOR
N TO AND SUBSCRIBED before me this
4 day of March 2011
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
CUMBERLAND LAW JOURNAL
NOTICE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Civil Action-Law
08-5374 CIVIL
PENNSYLVANIA STATE
EMPLOYEES CREDIT UNION,
Plaintiff
VS.
WILLIAM H. NELSON, JR.
Defendant
NOTICE
To WILLIAM H. NELSON, JR.
You are hereby notified that on
September 9, 2008, Plaintiff, Penn-
sylvania State Employees Credit
Union, filed a Complaint endorsed
with a Notice to Defend against you
in the Court of Common Pleas of
Cumberland County, Pennsylvania,
docketed to No. 08-5374 CIVIL,
which has been reinstated, wherein
Plaintiff seeks to enforce its rights
under its loan documents.
Since your current whereabouts
are unknown, the Court by Order
dated December 8, 2010, ordered
notice of said facts and the filing of
the Complaint to be served upon you
as provided by R.C.P. 430(b).
You are hereby notified to plead
to the above referenced Complaint
on or before 20 DAYS from the date
of this publication or Judgment will
be entered against you.
NOTICE
You have been sued in Court. If
you wish to defend, you must enter
a written appearance personally or
by attorney, and file your defenses or
objections in writing with the Court.
You are warned that if you fail to do
so, the case may proceed without
you and a Judgment may be entered
against you without further notice for
the relief requested by the Plaintiff.
You may lose money or property or
other rights important to you
YOU SHOULD TAKE THIS NO-
TICE 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 INFORMA-
TION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO
HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES
THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A RE-
DUCED FEE OR NO FEE.
Cumberland County
Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
(800) 999-9108
SHAWN M. LONG, ESQUIRE
BARLEY SNYDER LLC
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Mar. 4
PROOF OF PUBLICATION
Suite of Pennsylvania, County of Cumberland
acklc I_:c lte X111 Sales Manager, of The Sentinel, of the County- and State aforesaltI
Jeii"t, flu s?v irn, deposes and says that THE SENTINEL, a newspaper of genenii
irrufaticll a tie [orou;;h of Carlisle, County and State aforesaid, was established
;in 7e which date THE SENTINEL has been regularly lssuecf !! i
'iJUrt; , t d 11 II the (printed notice or publication attached hereto is rxactly the -1, 1.
?,i- ; rir r i .)I i Il,.lhlisl ell in the regular editions and issues of
I'll! -J I t%'? hc wtowing day(s):
COI' ( I \( 'I( F OF PUBLICATION
NOTICE
a
IN.THQ-OLIFfV, COjiA ON PLEAS OF CUMBERLAND Cr?l1NT ?PENNSYLVANIA
PNVILACTION';[AW
.,,PENNS Z1?11A STATL 9,111 OYfE (IIEDIT IINIOLJ -
+:µ Plaintflt
v?
3 e u
.' VILUAM H NEf SON JH
Dependant
CIVIL ACTION, IAY%
..,. •.?«.q.-qr,.?. .,-.:.,.?n? ?r.w ? •.:08-5374CIVIL? ;; .., *;;,., .. .:.;E'.. ,..:;.?.;.
k N611
r { 1 ti="
To WILL AM -w' 4ELSON JH ?r a r
You or h2rcJhyn6?ftetl,0iatuTi Sehtwnber 5 X00$ H mu fr Pe'o'n ylvan? dta Empk yew SedtL?lnipn;,h ad a
umplsivil ?f ?`e t, Deie'ggaW00 tyouan 6lt 'c iu pL 0& nonrpjeas of CUinbe?Jand ?o my
•?nf(P YIVt? (? RK'?7d,(11 V11,.w6A, h??r ,,,,...,..,.._., ,, ...4 _.-.. ..
I dt x? F# ?1.3? Aut?i. if }^S ? :'? 1t'.tx;.'1 r .:.., .: •:- .; . .y
Si(ace yurfir cr7 en w rbTs are atrea ourtby c)nie Dated Decernber $'2010,ordered nopce;jfsaidtacts
ndthoMing-otthe'Gomgiarnftct'e tiponyouasprov&dbyR.C.' -430(b).
You it hereby nolihotj to pl adtothe above referenced Complaint on or be fore 20 DAYS from the date of this
publu:at;oncarJudqu utwil[pe?Qntered,ag'ainstyou_
NOTICE
a
You W VC, heeai su d III 0ourt. It ypir ikish to defend, you must enter a written appearance personally or by attorney, and
file yourcefensesar 761igat?bris r i wntidg'with the Court. You-are warned that if you fail to do so, the case may
proceed with,,ntyouand a Judgment maybe entered against you without further notice for the relief requested by the
PlaintiffYou m iy lose money or property or other rights important to you.
YQ115HQUj Al ]t lS NQT `U TO YOUR LAWYER AT ONCE. If YOU DO NOT HAVE A LAWYER; GO TO OR
TELI PHOIIE TIit OFFICE ?ETFO1iTH BELOW. THIS OFFICE CAN'PROVIDE YOU WITH INFORMATION
ABOUA HIRING AiAWYER.
IF'YOLU,,ANNr )T AFFORD40flIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATiONABOUT:AGEOCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCFD FEt;OR NO'FEE
Affiant further deposes that hc,/shr'
interested in thc, subject matter of thr
aforesaid notice or advertise nwnt, I' it
all allegations il_t the forc'going 4'itc 'r,t
to time, piece and t-harat-toi of publl, .i
TO true r , yy j
Sworn tC) ?lnd Flih??l Ibe!; hl'!(?it' IJ1?
'bit ? , ;
- j.
?, ?1,,1? ?rlllJ'I
V C r) I l l ill 1 P 10 l 1 ?' \ r` l ic"
Cumberland CoU. Lawyer Referral Service M v
32 South'Bedford Street
Carlisle, PA 170 t 3
500-999-9108
Shawn M. Long, Esquire N'OTARIAI SE -
BARLEY SNYDER LLC
126 East King Street BAMBI ANN HirKIrNDU4:
Lancaster, PA 17602 Npiary
(7171299-5201 'r'0olrc
CARL-ISLE BORvL'GH. AN[' r
ivA?y C,i mi?;?n F
08-5374
OTNDNOTARY
?EI' 13 13 A 11:"5
ERLAND COUNT
r`';PaNSYL1/ANIA
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
WILLIAM H. NELSON, JR.
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 08-5374
PRAECIPE FOR JUDGMENT
Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and
against Defendant, William H. Nelson Jr. for want of an answer in the amount of $10,206.40
plus interest and costs of suit.
(X) I certify that the foregoing assessment of damages is for specified amounts alleged to
be due in the complaint and is calculable as a sum certain from the complaint:.
( ) Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify
that a copy of this praecipe has been mailed to each other party who has appeared in the action or
to his/her Attorney of Record.
31909391
Q? tly.W Pa p lS
#asasX,yi
08-5374
(X) Pursuant to Pa. R.C.P. 237. 1, I certify that written notice of the intention to file this
praecipe was mailed or delivered to the party against whom judgment is to be entered and to
his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the
date of the filing of this praecipe and a copy of the notice is attached.
Date: By:
BARLEY SNYDER LLC
Shawn M. Long, Esquir
Court I.D. No. 83774
Attorneys for Plain ' f
Pennsylvania Sta Employees Credit Union
126 East King Street
Lancaster, PA 17602
(717) 299-5201
NOW, jri L3 , 2011, JUDGMENT IS ENTERED AS ABOVE.
Prothonotary/Clerk, Civil Division
By:
Deputy
31909391
08-5374
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
OFFICE OF THE PROTHONOTARY
CARLISLE, PA
TO: William H. Nelson Jr.
Defendant
YOU ARE HEREBY NOTIFIED that Pennsylvania State Employees Credit Union has
caused a judgment by default to be entered against you with the Prothonotary of Cumberland
County. The judgment was entered on ft?fi ( 13, 00 , to No. 08-5374 with the
Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the amount
of $10,206.40 plus costs of suit.
PROTHONOTARY
By:
De erk
31909391
08-5374
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
WILLIAM H. NELSON, JR.
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 08-5374
AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE
MILITARY SERVICE. PURSUANT TO "SOLDIERS
AND SAILORS" CIVIL RELIEF ACT OF 1918. RE-ENACTED 1940
The undersigned, Shawn M. Long, Esquire, doth depose and say that William H. Nelson
Jr., the Defendant is not in the Military or Naval Service, based on the following facts: Age of
Defendant is unknown; Present place of employment is unknown; Last known place of
Residence is 117 East Pomfret St.. Carlisle. PA 17013 as of the date of this affidavit.
ADDITIONAL FACTS, if any.
The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S.
§4904, relating to unsworn falsification to authorities.
BARLEY SNYDER LLC
By:
ShAA M. Long, Esquire
Attorneys for Plaintiff
Court I.D. No. 83774
126 E. King Street
Lancaster, PA 17602
717.299.5201
31909391
08-5374
BARLEY SNYDER LLC
Keith Mooney, Esquire
Court I.D. No. 74001
50 North Fifth Street
P.O. Box 942
Reading, PA 19603-0942
(610) 898-7155
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
WILLIAM H. NELSON, JR.
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 08-5374
AFFIDAVIT OF SERVICE
Kelly Cunneen, Paralegal, doth depose and say that she served a true and correct copy of
the 10-Day Default Notice upon William H. Nelson Jr. at 117 East Pomfret St., Carlisle, PA 17013
by first class and certified mail on April 1, 2011 at 5:00 p.m.
The statements set forth in this Affidavit are made subject to the penalties of 18 Pa. C.S.
§4904, relating to unsworn falsification to authorities.
BARLEY SNYDER LLC
Date: April 1, 2011 By: LJ(J ', ,
Kelly Cunne , Paralegal
126 East Ki g Street
Lancaster, PA 17602-2893
717.299.5201
31826161
4
BARLEY SNYDER LLC
Keith Mooney, Esquire
Court I.D. No. 74001
50 North Fifth Street
P.O. Box 942
Reading, PA 19603-0942
(610) 898-7155
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
WILLIAM H. NELSON, JR.
Defendant
08-5374
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 08-5374
To: William H. Nelson Jr.
Date of Notice: April 1, 2011
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
31826161
08-5374
YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
BARLEY SNYDER LLC
By:
Keith Mooney, Esquire
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
Court I.D. No. 74001
50 North Fifth Street
P.O. Box 942
Reading, PA 19603-0942
610.898.7155
31826161