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HomeMy WebLinkAbout08-5725BARLEY 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. TALITHA V. MAY, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. (K - 5ga6 0-iyi t (ern 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 this 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 by the Court without further notice to you for any money claimed in the Complaint or for any other claim or relief requested by Plaintiff(s). You may lose money or property or other rights important to you. Complaint- PSECU May 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 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 St. Carlisle, PA 17013 Telephone: (717) 249-3166 or (800) 990-9108 Effective September 1, 2003 Complaint- PSECU_May 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 TALITHA V. MAY, V. Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. o 8- 5 7,2 5 L 9 I A? AVISO PARA DEFENDER Conforme a RCP No. 1018,1 del PA LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas dispuestas en las paginas siguientes, usted debe tomar la accion en el plazo de veinte (20) dias despues de esta queja y el aviso es servido, incorporando un aspecto escrito personalmente o por el abogado y archivando en escribir con la corte sus defensas u objeciones a las demandas dispuestas contra usted. Le advierten que si usted no puede hacer asi que el caso puede proceder sin usted y un juicio se puede incorporar contra usted por la corte sin aviso adicional a usted para cualquier dinero demandado en la queja o para cualquier otra demanda o relevacion pedida por Plaintiff(s). Usted puede perder el dinero o la caracteristica u otra endereza Complaint- PSECU_May importante a usted. USTED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE Un ABOGADO, VAYA A O LLAME POR TELEFONO La OFICINA DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De USTED La INFORMACION SOBRE EMPLEAR A un ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE LOS SERVICIOS JURIDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES EN Un HONORARIO REDUCIDO O NINGON HONORARIO. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249-3166 or (800) 990-9108 Efectivo 1 de Septiembre, 2003 Queja Complaint- PSECU_May 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, TALITHA V. MAY, Plaintiff V. Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. COMPLAINT Plaintiff, Pennsylvania State Employees Credit Union ("PSECU") is a Pennsylvania financial institution having an office at One Credit Union Place, Harrisburg, Pennsylvania 17110. 2. Defendant, Talitha V. May is an adult individual with a last known address of 616 Erford Road, Camp Hill, Pennsylvania 17011. 3. On or about July 3, 2006, Defendant applied for a Signature Loan Account ("Account") with PSECU. A true and correct copy of the Activation Notice is attached hereto as Exhibit "A" and incorporated by reference. Complaint- PSECU May 4. PSECU approved Defendant's application and opened an Account in Defendant's name. Defendant made home improvements using the Account subject to the terms and conditions of PSECU's Loanliner Credit and Security Agreement and Loanliner Addendum ("Agreement"). A true and correct copy of the Agreement and Transaction Summary are attached hereto as Exhibit "B" and incorporated by reference. 6. Defendant is in default under the Account for failure to make payments when due. 7. Several notices of default were sent to Defendant: on November 14, 2006, January 26, 2007, June 18, 2007, August 23, 2007, September 18, 2007, October 5, 2007, November 6, 2007, November 14, 2007, July 7, 2008 and July 30, 2008. A true and correct copy of the notices are attached hereto as Exhibit "C" and incorporated by reference. 8. The balance due and owing to PSECU from the Defendant on the Account is $6,956.20, plus collection costs of twenty percent (20%) which totals $1,391.24, plus costs. 9. PSECU has demanded payment from Defendant, but despite these demands, the Defendant has refused and continues to refuse to make payments. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant the name and address of the original creditor if different from the above. 23954371 2 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment in its favor and against Defendant, Talitha V. May, in the amount of $8,347.44, plus costs. BARLEY Date: By: Shawn M. Long, Esqui Attorneys for Plainti Pennsylvania State mployees Credit Union Court I.D. No. 83 74 126 East King Street Lancaster, PA 17602 (717) 299-5201 Complaint- PSECU_May VERIFICATION [Pennsylvania State Employees Credit Union vs . Talitha V. May] I, Gregory R. Diffenderfer, being duly affirmed according to law, depose and say that I am the Collection Manager for Pennsylvania State Employees Credit Union; that I am authorized to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. To the extent that any of the averments in the foregoing document are based upon the understanding or application of law, I have relied upon counsel in making this Verification. This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Dated: 011( 8''OY Gregory R. Diffenderfer Complaint- PSECU May -C. SIGNATURE LOAN ACTIVATION NOTICE July 5, 2006 Applicant Information: SS M 171-66-0732 Applicant: TELITHA V MAY Ref #: 548289 598 Work Telephone #: (717) 558-9500 Approval Amount: $7,000.00 Home Telephone #: (717) 986-0126 Account Number. 8104867034 Refinance: L20 Signature: I acknowledge receipt of the PSBCU LOANLINER Disclosure and Credit Agreement and agree to be o d by the ent. Si -.Cm T KI-ft MAY Date ?? SIGNATURE LOAN OPTIONS Purpose: 1 Please select one of the following Signature Loan disbursement options: Send a ? check, or ® deposit to my Share 4 (MoneyHandl Che king Shares Please select one of the following Signature Loan repayment options: q? . ? Payroll Deduction ? Home banding ? Self Service Telephone p Coupon ? Ag ect c Transfer from PSECU account Payment from another financial institution " 14 Rd Z- 7W gUZ 831Nnx cino tl??Sd. EXHM A PSECO Pennsylvania State Em?nloyees Credit Union P.O. Brix 67013 • Harrisburg, PA 17108-7013 • (717) 2344184 Harrisburg, (8W) 237-7328 Nationwide the rrnanciallinke Loan Disclosures This LOANLINER11 Credit and Security Agreement, which includes the Truth o Lending Disclosures, will be referred to as the Plan. The Plan documents include fhb agreement and an Addendum. You, your and borrower mean any person who sign, the Plan. Credit union, we, our and us mean PSECU or anyone to whom the Credo i Union transfers its rights under the Plan. I HOW THIS PLAN WORKS - This is an open-end, multi-featured Credit plan. We anticipate that, from time to time, you will borrow money (called "advances") under ! the Plan. We arc not required to make advances to you under the Plan and can 1 refuse a request for an advance at any time. The Addendum describes the different types of credit (called 'subaccounts') available under the Plan, the current interest rate for each subaccount expressed as a daily periodic rate and corresponding annual percentage rate and other charges. 11 may also have other i terms and a schedule for determining the payment amounts. CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain subaocounts. If a credit limit is set for a subaccount, you promise not to exceed the established credit limit, If you exceed the credit limit. you promise to repay immediately the amount which exceeds the credit limit. REPAYMENT -+. You procu to-repay all amounts you owe under the Plan plus interest. Payments are due on the last day of the month unless we set a different day at the time of an advance. It the Addendum has no payment schedule for a subaocount, your payment will be determined at the time of each advance. Payments must include arty amount past due and any amount by which you have exceeded any credit limit you have been given for a subaccount. You may repay ad or pan of what you owe at any time without any prepayment penalty. Even If you prepay, you will still be required to make the regularly scheduled payments unless we agree in writing to a change in the payment schedule. If you have a joint sharedraft account, you will be responsible for paying all overdraft advances obtained by a joint holder of the sharedraft account. Unless otherwise required by law, payments will be applied to amounts owed under the Plan, in fits manner the I Credit Union chooses. PLAN ACCESS - You can obtain credit advances in any manner authorized by us. It we allow you to use your ATM/Debit card to access the Plan, you may be liable lot the unauthorized use of your ATM/Debit card. You will not be liable for unauthorized use that occurs after you notify us, orally or in writing, of the loss, theft, or possible unauthorized use. 11 you believe your ATM/Debk card has been lost or stolen, immediately inform the Credit Union by calling or writing us 3I the telephone number or I address t1Gt appears elsewhere in the Plan. If the card is used to obtain unauthorized I advances directly from the Plan, your liability will riot exceed $50. If the unauthorized withdrawal is from a sharedraft account, your liability is governed by the Regulation E disclosures you received at the time you received your ATM/Debit card, even it the ?vit>drawal results in an advance being made from your overdraft subaccount. j FINANCE CHARGE - The dollar amount you pay for money borrowed is called a 'finance charge' and begins on the date of each advance. A finance Charge will be computed separately for each separate balance under the Plan. To compute the finance charge, the unpaid balance for each day since your last payment (or since an advance If you have not yet made a payment) is multiplied by the applicable daily periodic rate. The sum of these amounts is the finance charge owed. The balance used to compute the finance charge is the unpaid balance each day after payments andcredffs to tftatbapmcattev?paen subtracted-and any additions to-the -balance- have been made. In addition to interest, we may charge other finance charges which are disclosed on the Addendum. it the interest rate is a variable interest rate, the Addendum explains how the variable interest rate works. SECURITY-You pledge as security for the Plan all shares and dividends and, if any, all deposits and interest in all joint and individual accounts you have with us now and in the future. It a specific dollar amount is pledged for an advance, we will freeze shares in that account to the extent of the outstanding balance for the advance. Otherwise, your pledged shares may be withdrawn unless you are in default The following paragraph applies In all states except in Ohio, Rhode Island and Massachusetts: We nave a statutory lien on the shares and dividends and, if any, the deposits and interest in all individual and joint accounts you have with us and may exercise our rights under the lien to the extent permitted by state taw. (We are state chartered if our name does not include the term rederal Credit Union') For all borrowers: The statutory Uen and/or your pledge will allow us to apply the funds in your account(s) to what you owe when you are in default. The statutory lien and your pledge do not apply to any Individual Retirement Account or any other account that would lose special tax treatment under state or federal law it given as security. Additional security for the Plan may be required at the time of an advance. If a subaccount identifies a type of property (such as "New Cars-) you must give that type of property as security when you get an advance under that subaccount. A subaccount name such as 'Other Secured" means you must provide security acceptable to us when you obtain an advance under that subaccount. Properly You give as security will secure all amounts owed under the Plan and all other loans you have with us now or in the future, except any ban secured by your principal dwelling. ! Property securing other loans you have with us may also secure the Plan. ' O CUNA uUTUAL GROUP TM. M. AU RIGHTS DESERVE: CREDIT INSURANCE - Credit fife and/or credit disability insurance is optional under the Plan. If you quality for and purchase the insurance from us, you authorize us to add the insurance premiums monthly to your ban balance and charge you interest on the entire balance. It you elect credit insurance, your payments may increase or the period of time necessary to repay your advance may be extended. The credit insurance rates may change during the Plan. If the rates change, are will provide any notices required by applicable law. PERIODIC STATEMENT - On a regular basis you will receive a statement showing all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each joint borrower. notice to any one of you will be notice to all. JOINT ACCOUNTS - It this is a joint account, each of you is individually and jointly responsible for paying all amounts owed. That means we can enforce our rights under the Plan against any one of you individually or against all of you together. If you give us inconsistent instructions, we can refuse to follow your instructions. Unless our written policy requires all of you to sign for an advance, each of you authorizes the other(s) to obtain advances individually and agrees to repay advances made to the. other(s). Any joint accountholder may terminate the Plan by giving us prior written notice. It any of you terminate the Plan, the Plan is terminated for all of you. You remain liable individually and jointly for all advances incurred before termination. FEES AND CHARGES - If you give us a security interest in certain types of property, we may charge you a filing fee to perfect our interest in the property. If we do, the amount of the fee will be disclosed to you at the lime you obtain an advance. We may also charge you other fees in connection with the Plan. Our current fees are disclosed on the Addendum and will be added to your loan balance unless you pay them in cash. UPDATING CREDIT INFORMATION - You promise that you will promptly give us written notice if you move, change your name or employment, or if any other information you provided to us changes. Upon our request, you also agree to provide us updated financial information. DEFAULT - The fallowing paragraph applies to borrowers In Idaho, Kansas, Maine and South Carolina: You will be in default If you do not make a payment of the amount required when it is due. You will also be in default If we believe the prospect of payment, performance, or realization on any property given as security is significantly impaired. The following paragraph applies only to borrowers In Wisconsin: You will be in default if you fail to make a payment when due two times during any 12 month period. You will be in default if breaking any promise made under the Plan materially impairs your ability to repay what you owe or materially impairs the condition, value, or protection of or our righl.in any property you gave as security. The following paragraph applies only to borrowers in Iowa: You will be in default if you are more than 10 days We in making a payment. You will also be tin default if you do not comply with the terms of the Plan and your failure to comply materially impairs any property you gave as security or your ability to repay what you owe under the Plan. The following paragraph appllas to borrowers in all other states: You will be in default it you do rot make a payment of the amount required when it is due. You will be In default if you break any promise you made under the Plan or lt anyone is in default under any security agreement made in connection with an advance under the Plan. You will be in default if you die, file for bankruptcy. become insolvent, if you make any false or misleading statements in any credit application or update of credit information, or if something happens we believe may substantially reduce your ability to repay what you owe. You will be in default if any property you have given us as security is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value of the property or our security interest in ft. You will also be in default under the Plan if you a re in default under any other ban agreement with us. ACTIONS AFTER DEFAULT -- The following paragraph applies to borrowers in I` Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Vlrginle, When you are in default and after expiration of any right you have under applicable state law to cure your default, we can I demand immediate payment of the entire unpaid balance under the Plan without 1 giving you advance notice. The following paragraph applies to borrowers In all other states except Wisconsin i and Louisiana: When you are in default, we can require immediate payment acceleration) of the entire unpaid balance under the Plan. You waive any right you have j o demand for payment. notice of intent to accelereie and notice of acceleration. Erie following paragraphs apply to borrowers In all states except Wisconsin and .ou/sham: If immediate payment is demanded, you will continue to Day interest unlit vhat you owe has been repaid at the applicable interest rates in effect or, if applicable. CPS1401 PSECU r-ORrr 113145 EXMIT 8 LOANLINEir Credit and Security Credit Agreement (continued) at the default rate dsclosed on the Addendum. If a demand for immediate payment has been made, your shares andfor deposits can be applied towards what you owe as provided in the section above called -Securgy' We can also exercise any other rights given by law when you are in default. You agree the Credit Union has the right to take possession of any property given as security under the Plan, without judicial process, if this can be done without breach of the peace. It we ask, you promise to deliver the property at a time and place we choose. It the property is a motor vehicle or boat. you agree that we may obtain a key or other device necessary to unlock and operate it. when you are in defaultt. We will not be responsible for any other property, not covered by this Agreement. that you leave inside the property or that is attached to the property. We will try to return that property to you or make it available for you to claim. After we have possession of the propeny, we can sell it and apply the money to any amounts you owe us. We will give you notice of any public disposition or the date after which a private disposition will be held. Our expenses for taking possession of and selling the property wig be deducted from the money received from the safe. Those costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded under the Bankruptcy Code. You must pay any amount that remains unpaid after.the sale money has been applied to any unpaid balance under the Plan. You agree to pay interest on that amount at the same rate as the advance, or, if applicable. at the default rate disclosed on the Addendum, until mat amount has been paid. The following paragraph applies only to Wisconsin borrowers: When you are in default and after expiration of any right you have under applicable state law to cure your default. we may require-immediate payment of your outstanding loan balance under the Plait and seek possession of property given as security. You may voluntarily give the property to us it you choose, or we may seek to take possession of the property by judicial process. If we repossess the property, you agree to pay reasonable expenses incurred in disposing of the property. It the property is a motor vehicle, mobile home, trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains unpaid after the sale money has been applied to what you owe under the Plan. You agree to pay interest on any unpaid amount at the same rate as the advance, or, H applicable, at the default rate disclosed on the Addendum, until that amount is paid. It the property is located outside Wisconsin at the lime of default. we may take possession of the property without judicial process, if permitted by the state where the property is located. The following paragraph applies only to Louisiana borrowers: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the applicable interest rates in effect unless a default rate is disclosed on the Addendumr If a demand for immediate payment has been made, the shares and deposits given as security for the Plan can be applied towards what you owe. We can also exercise any other rights given by law when you are in default and our rights under any security agreements you have with us. CANCELLING OR CHANGING THE PLAN - The following paragraph applies only to borrowers in Illinois! We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change to the interest rate or other charges will apply to future advances. The following paragraph applies only to borrowers In Wisconsin: We can change the terms of the Plan from time to time in accordance with Section 422.415 of the Wisconsin Statutes. You will be notified of any change in terms. An increase in the daily periodic rate under a variable rate interest rate is riot considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the credit union cancel the Plan, except to the extent that your liability is limited by Section 422.4155 of the Wisconsin Statutes. The following paragraph applies only to borrowers in Iowa: We can change the terms of the Plan from lime to time after giving you any advance notice required by law. A change that increases the rate of finance charge or other charge. that increases the amount of your payments. or that otherwise adversely affects existing balances will apply to existing balances only if you agree to the change or you use the Plan after receiving notice that your use of the Plan means you agree the change applies to existing balances. The following paragraph applies to borrowers In all other states: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change in the interest rate will apply to future advances, and at our discretion and subject to any requirements of applicable law, will also apply to unpaid balances. The following paragraph applies to all but Wisconsin borrowers: An increase in the daily periodic rate under a variable interest rate is riot considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the Credit Union cancel the Plan. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay enforcing any of our rights under this Plan any number of times without losing the ability to exercise our rights later. We can enforce this Plan against your heirs or legal representatives. It we change the terms of the Plan, you agree that this Plan will continue to protect us. CONTINUED EFFECTIVENESS - If any part of this Plan is determined by a court to be unenforceable, the rest will remain in eflect. ! NOTICE TO UTAH BORROWERS -This written agreement is a final expression of the agreement between you and the Credit Union. This written agreement may not be contradicted by evidence of any oral agreement. The fopoadag Is required by Vermont law - NOTICE TO CO-SIGNER - YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. 1 The following paragraphs apply If you give security In connection with an advance under the Plan.They apply to borrowers In all states except Louisiana, i Louisiana borrowers will execute a separate security agreement. Borrowers In tl other states may also be asked to execute a separate security agreement. THE SECURITY FOR THE PLAN - You give us what is known as a security interest in all property described in any receipt, voucher or other document you receive for an advance (the Advance'). The security interest you give includes all accessions. Accessions are things which are attached to or installed in the property now or in the future. The security interest also includes any replacements for the property which you buy within 10 days of the Advance or any extensions, renewals or refinancing of the Advance. It also includes any money you receive from selling the property or from insurance you have on the property. If the value of the property declines. you promise to give us more property as security it asked to do so. WHATTHE SECURITY INTEREST COVERSICROSS COLLATERAL PROVISIONS -The security interest secures the Advance described in the receipt, voucher or any other document you race" at the time of the Advance and any extensions. renewals or refinancings of the Advance. It also secures any other advances you have now or receive In the future under the Plan and any other amounts or bans, Including any credit card loan, you owe us for any reason now or in the future, except any loan secured by your principal residence. If the property is household goods as defined by the Federal Trade Commission Credit Practices Rule. the property will secure only the Advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY -You promise that you own all property you give as security or if the Advance is to buy the property, you promise you will use the Advance for that purpose. You promise that no one else has any interest in or claim against the property that you have not already told us about. You promise not to sell or lease the property or to use it as security for a loan with another creditor until the Advance is repaid. You promise you will allow no other security interest or lien to attach to the property either by your actions or by operation of law. PROPERTY INSURANCE, TAXES AND FEES - You must maintain properly 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 Io us. You may provide the property insurance through a policy you already have. Or through a policy you get and pay for. You promise to make the insurance policy payable to us and to deliver the policy or proof of coverage to us if asked to do so. If you cancel your insuranA and get a refund, we have a right to the refund. II the property is lost or damaged, we can use the insurance settlement to repair the j property or apply it towards what you owe. You authorize us to endorse any draft or ! check which may be payable to you in order for us to collect any refund or benefits due under your insurance policy. You also promise to pay all taxes and fees (like registration fees) due on the property. H you do not pay the taxes or fees on the property when due or keep it insured, we may pay these obligations, bun we are riot 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 I other borrowers have compiled with the insurance requirements of our ban agreements I or may engage others to do so. The insurance charge added to an advance may include (1) Cie insurance company's payments to us and (2i the cost of determining compliance with the insurance requirements. If we add amounts for taxes, fees or fnsurar" to the unpaid balance of an advance, we may increase your payments to pay the amount added within the term of the insurance or approximate term of the advance. INSURANCE NOTICE - If you do not purchase the required property insurance, the insurance we may purchase and charge you tot will cover only our interest in the ; property. The premium for this insurance may be higher because the insurance company may have given us the right to purchase insurance after uninsured ! collateral is lost or damaged. The Insurance will not be liability Insurance and i will not satisfy any state financial responsibility or no fault laws. PROTECTING THE SECURITY INTEREST - If your state issues a trtte 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 i 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 blot not limited to any attorney tees, we incur in protecting our security interest and rights in the property. to the extent permitted by applicable law. , LOANUNER* Crsdit and Seeurlty Credit Aar ee-1 (continued) 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 mused. (6) Not use the property for any unlawful purpose. (7) Not to reGlle property in another state without telling us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT 1S REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to tail to return a motor vehicle that is subject to a security interest, within thirty days after you have received notice of default. The notice will be mailed to the address you gave us. It is your responsibility to notify us if your address changes. The maximum This notice contains important information about your rights and our responsibilities under the Fair Credit Bitting Act. You are advised to read your monthly statement and review it for any error discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT. If you think your statement is wrong, or it you need more information about a transaction on your statement, write us on a separate sheet arthe address Fisted on your statement. You are required to notify us in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transactions on your account. Failure to notify us may result in your acceptance of any responsibility for payment or reimbursement to us for any such error or discrepancy on your account, Write to us as soon as possible. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: Your name and account number. The dollar amount of the suspected error. Describe the error and explain, if you can, why you believe there is an error, If you need more information, describe the item you are not sure about. If you have authorized us 10 pay a credit card account automatically from your share account or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us three business days before the automatic payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the statement was correct. In this Agreement, the words you and your means each and all of those who apply for the card or who signs this Agreement. Card means the Visa Credit Card and any duplicates and renewals we issue. Account means your Visa Credit Card Line of Credit account with us. We, us, and ours means this Credit Union. 1. RESP4DNSIBIL4PF--I "iawe you-e card; you.agreetoi"ay.eN.debleard-the Finance Charge arising from the use of the card and the card account. For example, you are responsible for charges made by yourself, your spouse and minor children. You are also responsible for charges made by anyone else to whom you give the card, arid this responsibility continues until the card is recovered. You cannot disclaim responsibilfry, by notifying us. but we will close the account for new transactions it you so request and return all cards. Your obligation to pay the account balance continues even though an agreement, divorce decree or other court judgment to which we are not a party may direct you or one of the other persons responsible to pay the account. The cards remain our property and you must recover and surrender to us all cards upon our request and upon termination of this Agreement. 2. LOST CARD NOTIFICATION - It you believe the card has been lost or stolen, you will immediately call the Credit Union at (717) 234-8484 or (800) 237-7328. After hours call (800) 556-5878. 3. LIABILITY FOR UNAUTHORIZED USE - You agree to notify us immediately, orally or in writing of it* loss. theft or unauthorized use of your Credit Cant. You may be Sable br the unauthorized use of your Credit Card. Yau will not be Sable for unauthorized use that occurs after you nobly us of ffre loss, theft, or possible unauthorized use. You wig have no liability for unauthorized purchases made with your Credit Card, unless negligent in the handling of your Card. Ina case, ce are grossly any your liability will not exceed $50, C CREDIT LINE - If we approve your application, we will establish a self- •eplenishing Line of Credit for you and notify you of its amount when we issue the :aid. You agree not to let the account balance exceed this approved Credit Line. Each Sayment you make on the account will restore your Credit Line by the amount at the Dayment which is applied to the principal. You may request an increase in your Credit i penalty for unlawful failure to return a motor vehicle is one year in prison and: or a fine of $150,000. For those members who purchase a vehicle under the DRIVe Program, please review the following FTC Notice: big ME ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to send statements to you for the amount you question, including finance charges. and we can apply any unpaid amount against your credit limit. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your statement that are not in question. It we find that we made a mistake on your statement, you will not nave to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date that it is due. It you fail to pay the amount that are think you owe, a,a may report you as delinquent. However, if our explanation does not satisfy you and you write to us within ten days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your statement. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount. even if your statement was correct. SPECIAL RULE FOR CREDIT CARD PURCHASES - If you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the property or services. There are two limitations on this right: (a) You must have made the purchase in your home state or, It not within your home slate, within 100 miles of your current mailing address; and (b) The purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or it we mailed you the advertisement for the property or services. Line only by written application to us, which must be approved by our credit committee or ban officer. By giving you written notice we may reduce your Credit Line from time to time, or with good cause, revoke your card and terminate this Agreement. Good cause includes your failure to comply with this Agreement or any other agreement with u2 Q[S?yfAft!sP-reevatuatjorLof your creditworthiness. You may also terminate this Agreement at any time, but termination by either of us does not affect your obligation to pay the account balance. 5. CREDIT INFORMATION - You authorize us to investigate your credit standing when opening, renewing or reviewing your account. and you authorize us to disclose information regarding your account to credit bureaus and other creditors who inquire of us about your credit standing. 6. MONTHLY PAYMENT - We will mail you a statement every month showing your Previous Balances of purchases and cash advances. the current transactions on your account, the remaining credit available under your Credit Line. the New Balances of purchases and cash advances, the Total New Balance, the Finance Charge due to date, and any other billed fees, and the Minimum Payment required. Every month you must pay at least the Minimum Payment within 25 days of your statement closing date. By separate agreement you may authorize us to charge the minimum payment automatically to your share or checking account with us. You may, of course, pay more frequently. pay more than the Minimum Payment, or pay the Total New Balance in full, and you wig reduce the finance charge by doing so. If your monthly payment exceeds the !otal credit fine balance owed, we will automatically post the credit to your St snares- The minimum payment will be (a) 2% of your Total New Balance, rounded up to the next even dollar, or (b) ;20.00, whichever is greater. In addition, at any time your Total New Balance exceeds your Credit Line. you must immediately pay the excess upon our demand. We will apply payments in the following manner: firsi to previous late fees, then to previous cash advances finance charges. then !o previous purchase finance charges, then, to current late fees, then to previous cash advance balances. Men to previous purchase balances in the order that they were posted to your account. Men to current cash advance balances. ano then to current purchase balances I Visa' Credit Card Agreement and Truth In Lending Disclosure (continued) 7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by paying the full amount of the Nev Balance of Purchases each month within 25 days I of your statement dosing date. Otherwise, the New Balance of Purchases, and the i subsequent purchases from the date they are posted to your account, will be subject to Finance Charge. Cash advances are always subject to Finance Charge from the i date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average adjusted j daily balance (see explanation below). including new purchases, for the billing cycle I by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Cash Advances: We calculate your finance charge on cash advances by multiplying the average adjusted daily balance (see explanation below) for cash ! advances during the billing cycle by the monthly periodic advance rate and j corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Daily "ante for Purchases - The Average Daily Balance for Purchase Transactions is calculated by adding the Daily Balances (Purchase Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the r amounts of all debits and subtract the amounts of alf credits or payments which post j to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day in the billing cycle. This gives us the Daily Balance for purchases. Average Daily as lance ;br rash Advances - Cash Advance Transactions which are posted to your account are not included in the Average Daily Balance calculation for purchases, and are therefore not subject to the monthly periodic rate for purchases. The Average Daily Balance is calculated separately for Cash Advances and is subject to the Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions is calculated by adding the Daily Balances (Cash Transaction) for each day in the billing cycle, and then d'evidng by the number of days in the billing cycle. To calculate the Daily Balance for cash each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account [hat day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Purchase Transactions that posted to your account on that day or in any previous day in the billing cycle, This gives us the Daily Balance for Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account. Paymenjs are applied In the following manner: first to previous late fees, then to previous cash advances finance charges, then to previous purchase' finance charges, then to current late tees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account. then to current cash advance balances, and then to current purchase balances. Credits are applied first to the particular type of debt which is being credited. if any, and then to the balance of your account. Note also that it the total of the payments and credits which are posted to your account by the Payment Due Date shown on a statement is equal to or exceeds the New Balance shown on that statement, we will not apply the Monthly Periodic Rate to your Account on your next statement. S. DEFAULT -You will be in default if you fail to make any Minimum Payment within 25 days after your monthly statement closing date. You authorize us to transfer funds sufficient to make the minimum payment due it your Visa loan is in default. You will also be in default if your ability to repay us is materially reduced by a change in your employment, an increase in your obligations, bankruptcy or insolvency prangs Involving you, your death or your failure to abide by this Agreement, or if the value of our security interest materially declines. We have the right to demand Immediate payment of your fug account balance if you default, subject to our giving you any notice required by law. To the extent permitted by law, you will also be required to pay our collection expenses, including court costs and reasonable attorney fees. 9. USING THE CARD - To make a purchase or cash advance, there are two alternative procedures to be followed. One is for you to present the card to a participating Visa plan merchant, or another financial institution, and sign the sales or cash advance draft which will be imprinted with your card. The other is [o complete the transaction by using your Personal Identifrca[ion Number (PIN) in conjunction with the card in an Au[omated Teller Machine or other type of electronic terminal that provides access to the Visa system. You agree that you will not use your card for any transaction that is Illegal under applicable federal, state, or local taw. The monthly statement will identity the merchant, electronic terminal or financial institution at which transactions were made, but sale, cash advance, credit or other slips cannot be returned with the statement. You will retain a copy of such slips furdinishedio at the time of the transaction in order to verify the monthly statement. The Cret Unn may make a reasonable charge for photocopies of slips you may request. 10. OVERDRAFT OPTION - If you elect to overdraft to your PSECU Visa Credit Card, that election is subject to the existing credit limit and the agreement it represents and the current ban policy at the time of the overdraft. You also understand that an overdraft will be considered the same as a cash advance on your PSECU Visa Credit Card and that the current Annual Percentage Rate for cash advances will apply. 11. RETURNS AND ADJUSTMENTS - Merchants and others who honor the card r may give credit for returns and adjustments, and they will do so by sending us a 1 credit slip which we will post to your Visa line of credit. If your credit and payments exceed what you owe us, we will automatically post the excess credit balance to your St Shares within 75 days. If the balance is one dollar or more, upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS - The exchange rate between the transaction currency and the billing currency used for processing international transactions is a rate selected by Visa from the range of rates available in wholesale currency markets for the applicable central processing dale, which rate may vary from the rate Visa itself receives, or a government-mandated rate in effect for ;he applicable central processing date. In each instance, an adjustment may be assessed based on the ISA fee imposed by Visa. This fee, which totals 1% of the transaction amount, will be assessed on all transactions where the merchant country differs from the country of the card issuer. 13. SPECIAL RULES FOR VISA PURCHASES - If you disagree or find an error with a Visa transaction, and have tried in good faith to correct the problem with the merchant or the charges are the result of unauthorized or fraudulent use, or your purchase cost more than $50 and was made from a plan merchant in your state within 100 miles of your home, contact PSECU. 14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transaction on your account. Telephoning PSECU does not presefte your dispute rights. You may be required to provide us with documentation to support your dispute claims. In addition, you may be required to complete a standard dispute form outlining the details of your dispute. In cases of fraudulent card use. PSECU w,II also require a notarized affidavit. In some cases we may ask you to notify the local authorities. It we do not receive the proper requested documentation in the time specified you may be held responsible for the transaction(s) in question. PSECU must adhere to strict dispute timeframes set forth by Visa. 15. SECURITY INTEREST - To secure your account, you grant us a purchase money security interest under the Uniform Commercial Code in any goods you purchase through the account. It you default, we will have the right to recover any of these goods which we have not been paid for through our application of your payments in the manner described in the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have if you are in default to prevent withdrawal of your unpledged credit union shares (Deposits) below the unpaid balance of your account However, if you give or have given us a specific pledge of your credit union shares (Deposits) by signing the Pledge of Shares or otherwise, or any other security interests for all your debts, your account wig be secured by your pledged shares (Deposits) and by the properly described in those other security agregments, except for your home. 16. EFFECT OF AGRE&ENT - This Agreement is the contract which applies to all transactions on your account even though the sales, cash advance, credit or other slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance written notice required by law. Your use of the card thereafter will indicate your agreement to the amendments. To the extent the law permits, and we indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. e I 17. LATE PAYMENT CHARGE - If your Minimum first day of the month following your due date, you will be subject tota received by 320 charge. 11L RUSH FEES - You may incur additional charges for rush processing and rush delivery of cards andlor PIN mailer. 19. OVER LIMIT FEE -A S20 fee win be applied for each monthly statement dosing date on which the outstanding balance exceeds the assigned credit limit by more than $100. 20. DRAFT COPIES - You may incur an additional charge for transaction summaysale draft documentation. 21. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement. 22. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. 23. NO USE - Inactive Visa accounts that have no purenase or cash activity may be closed without notice to you aler 18 months of no activity. 24. NEURAL NETWORK - PSECU uses neural network systems to predict and prevent unauthorized transactions. There may be occasions when a transaction is j d eclined because it is indicative of possible fraudulent activity. 0 p O ., h C ? Y E N ?D C e Z" o V c .? o J J. 4 f -0 EO O u ° u ° _ a cc e X O P ~O o o `, ? c« L` M E o 0 0 o a o 0 0 0 0 0 M E a s 7 E z _ j p N . aNaa° wv nvncr^°_o°m°o 0000 <e_ C CC a `? p V CCC Os ???Vri 7 E 3-G « ?: - =`-- vo E' p ? v ? ? t+7 j j >? i - s Eo 000oooooaoooo x'`o v °° u ` ep•? ESa .? r c? omvr ?oco o o .? N o n v E c anal nr:?cr cn t,t•, c•. ...----c°?? r E p `? y ? ? g Q.-•._`c ?c c J 'O cy E•^ ? ? Y " -O L - ? J? 3? ?? 0 0 E ?'? e a 1c O p? 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OOOPNP NNOCOOh gN aDOff ffhop^?n O-yJ,-N.,,, SOOM?on MOaDNfN P N•otnv mN;-OOP a0opnn.D•O OOu'lhvf v1N V.f.rf ""qq qq "C4 NNNNNN 4. 660606 000000 000000 006000 000000 ^NMfNv hCOPO^N Mf N?OhCO 0,0.-NMA W.O noDPO '- ^^^^ --NNNN NNNNNN I 3 f P u 3 E f i W Z3 N O O OO rrrrrr N N N N N N 00000 Vc-?w vNOn?icOnwO°w 13 f?i F3 N I? 13 0 Cl 0 0 0 0 800V 00 OD OD Z --1 @ ? = ? CD (D CD 3 N N N N N N w?`GY. 3 3 3 3 3( 0 0 CD CD •'-? rt V O O O O O O CA) 0 0 0 0 0 0 -? N O? Co 00 O N O? O O OOCph??pOO O O O A O O V V V V V 0) 00 000 CD 0 0 0 0 0 0 O O O O O N 0 0 0 0 0 0 TI 91 3 ? Cn Cn O ca ID 0A C3 H r C ro CD 0 C a r d a ti Dear MS. MAy: November 14, 2006 Your services with PSECU have been terminated. This action is a result of PSECU policies that allow us to terminate services due to a delinquent loan obligation. Your Check card is invalid and will be retained if used after November 13, 2006. if you have any concerns or questions, Call 800.237.7328 nationwide or 717.234.8484 in Harrisburg. At the menu prompt, enter 6 then ext. 3118. Michelle Hess Service Advisor Member Services EXHMff C PSE TELITHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELMIA V MAY: O V 2007 COPY Nq (4-103(1 PSECU bas made several attempts to contact you and to negotiate suitable payment arrangements. We received no response. Your Signature Loan is 6 months past duel This b your final notice. Unless we receive the payment amount of $1,15458 by February 12, 2007, we may refer your account to our Legal Review Committee. Ifthis oomrs, a judgment may be entered and executed against you. All court cysts and fees will be added to your loan balance. If we do not take legal action and payments are not received, we will charge off your account You will still be responsible for the balance. In either case, your status will be reported to all national credit bureaus. This is a serious situation that requires your immediate attention, If you cannot make the fall payment, we are willing to negotiate a reasonable payment schedule that fits your needs. Call me today to we if we can resolve this situation. I can be reached at 234-8484 in Harrisburg or call our toll-free number, (800) 23.7-7328. At the menu prompt, enter 6 then extension 3118. We are open from 8 a.m. to 5 p.m. Monday through Friday and 8 a.m. to noon on Saturday. Sincerely, Michelle Hess Account Advisor www.ps*cu.com ANNEID PSECO 06,18!2007 coo Py $164 () aq TEIdTHHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELITHA V MAY: On 02/22/2007 your Signature Loan was charged off for $7,456.20, -YOU are :tin tee.,,. Mavment of thisentire debt. naible for Because haerest stopped accruing, this allows us to accept payment arrangements suitable to your present ftnauckrl situation. As Your Account Advisor I will assist you with questions and concerns. I will work with you to help you get back on track with us. This will give you the opportunity to become eligible for our member services. Please call me at 2 eAa 111! Harrisbura or call our toll free number (8001237 7328. At the mcuu prompt press 6 then ezt, 312. Sincerely, Linda Carter . Account Advisor enc. ,1 Croda Unbn ?? Hortis Pann !2;? State E loyass Credit Union 717 . 0O Bw 67013, H--6Jwr PA 1710670 31. p717.777100ffDD) - HMO) o,?i'MI, %V~.;MGW.Co," I NNED PSECO 08/2V2007 copy e"I TELITHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELITHA V MAY. Congratulations on taldng the first !rig step to improve your eligibility for services with us. During the phone conversation on August We expressed our willingness to work with you, At that time, you to set up a payment arrangement and a due date that would be suitable to your circumstances. As a result; you said that you would send $s0,00 by the 30° of each month. We accepted this arrangement and your first payment is due on August 30, 2007. If you have any questions, please call us at 1-800-237-7328 or 234-8484 (enter 6) ext. 3119. Sincerely, PSECU Collections Department Charge Off Unit enc. Penns; ylvanla State E es Credit Union Address: 1 Crodff Union Ploce, Hardy PA 1 7 1 1 0-2990 • 717.234.8481 •800.2 7328 PO. Box 67013, Horrlsbu , PA 17106-013 • 717_T/7,2100 800.472,1967 D an nfsirafor. Equal OpportuaUy er ?A --» - r..?Q L www.psscu.com NNED PSE- ;=Mr. - MMDL#0WN, PA 17057-5542 Dear TBLITHA, V MAY: 09,182007 COPY We did not receive your first payment of 550.00 as agreed. And, we hope that you simply overlooked the date. Set a Angus at 23, 2t 07, we ox eWIRthLWM pressed our willingness to work with you, During that conversationvou arra 3F monthly starting on August 31, 2007, ' Please send your payment to us today- Remember, once your account is paid you will be eligible for our member services. If you need more help, please can me at 1-800-23777328 or 234.8484 (eater 6) ext, 3119. Sincerely,., f Michelle Hess Account Advisor Main Addrou: 1 Credit Union Place }{a . Pennsylvania Sfate Employees Crodit Union 1li'N.I ddMw P.O. Box 67013 Hor h , P r`"b"?? PA 17 ] ]0.2990 • 717.234.8484 • g00-?37.7328 ' °° '" fO1 i. kd?yoily Mu+red by she 1'"ImW GedR Urgos Adnd -,.Lr A17106-7013 • 717.777.2100 p ntsimgon. Equal oppoAomy lender Z. ' - .O _800.4721967 (fDD! www psseu.eom PSECO TELITHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELITHA V MAY: 10/05/2007 COPY %k 049S-Io-64 On June 18, 2007, I sent you a letter concerning your Charged-Off Signature Loan. This account still has balance of $7,456.20. It is very important ^- . me immediately a When your balance is paid In fill, we will report it to the credit reporting agencies as a paid charge off. And, you will be eligible to apply for our member services. Upon your request, we can refer you to an agency that can help you with your budget and other debt problems. This is it non-profit agency and the service is free. Let us help you get back on track. Sincerely, Michelle Hess Account Advisor i Moln Address: 1 Credit Union 126m, Harrisbcrg??A 0-2990-717.234.8484 Credit Union ! 1W--de anion 8 - ___#, A4ailing Adds U,,- - p,_8wc 67013, Horrisbu? PA 17106-7013 • 717_777.2100 pZ . 1100.472 967'732p8 ? by insmd by 1i, Nal onol Creefit niar Admfni 6701, k Opp?„ey j; 10 --pp _ - - - M..)-. _ Equal wwavpsecu.eom E4 PSECO C 0F7 2. $10u1a(,ro14 I1/06/2007 Sent via ceHried & regular mail TELITHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELITHA V MAY, MWLE YOUR CRTDTi' UMON DEBT AND CET A 10°/. DISCOUNTii As a Credit Union, we recognize that unexpected occurrences can sometimes result is difficulty meeting financial obligations. PSECU would hike to help you with fulfilling your outstanding obligation with a one-time opportunity to satisfy your severely delinquent PSECU Charged-Off Signature Loan by establishing a monthly payment agreement. We can help if you are willing to work with us; however, a decision must be trade now as we are on the verge of pursuing legal remedies to collect your debt. To assist with your decision, I would like to describe two scenarios: Allowing us to work with you: + We will reduce your current Charged-Off Signature Loan balance from $7,456.20 to $6,710.5 S. +We will stop all interest and late foes from ftuther increasing your obligation. +We will work with you to establish a reasonable monthly payment. •ll?Your credit report, which now reflects a charged-offaccount, will show you have resumed making payments. This is it one-time offer which is good for 14 days from the date of this letter. +If you fail to consistently make the established monthly payment, this agreement will be immediately voided and the loan will be turned over to our attorney for legal action. Ignoring this letter and doing nothing could result in the following: %wWe will forward your file to our attorney or third-party collection agency following 14 days of this letter. *Collection costs of 20% plus additional court costs will be added to your outstanding Charged-Off Signature Loan balance resulting in an increased outstanding obligation. +Our attorney will file a judgment against you in Civil Court for the increased amount. •SYour appearance in court will be requested +A Lien will be placed on your personal property and be reflected on your crodit report for up to 20 years making it more difficult to obtain credit in the future including buying a vehicle and buying or selling a house. •: Any co-applicant on this loan will be negatively impacted in the same way. *Your account could be referred to a third-party collection agency for additional collection efforts. This choice 13 you, 800-237-7328, orllocaally at 717Please-234-call one of our adrepresentatives, toll free, at extension 3119, too take sery(ce vantage of this one-tithe offer. Sincerely, Dave Warwavesyn Vice President Member Services Main Address; 1 Credit Union place i{efi?{, Pennsylvania Sfaie Employees Credit Union Moiling Address; P_O67013, H . PA (7110.2990 • 717234.8484 • 800237.7328 Th& credit union k (ed°rapy ?d (y, ? Nil C? UnTan (iDD - ariabu?g?PA 17106Oi3 • 717.777,2100 (• 800.472.1967 (TDD) , Adminlsfmlion Equal Opporturny der rvarw Peeeu.com' - ANNEID C 0 p17 at . bq&r?U3V ¦ Pitayournmwana.d*m=anduievc= d Ate b ¦ , n cmd to ft at* of the madugece '?-A ^A1 , or on the toot r apace Permft ,. AnkteAd6rasW,x ?• tannre? aYEB,w„r aednnt,dowr. Tel'ithe V. May - 88 Manny Dr. Middletown, PA 17057-5542.. a. TOP* ..wa Stu n tiw - t' ?rM e n ooA $ ?'?y&D 70, .n e. naataadMt..y,PeeA* 11 vim Z mma.rt.r 7003 3110 OQOQ 4558 sfaracrn+erkearep (Am9679 Ps Frnm 3811. Pebnmery mOD4 toonnewo PAWM n.e44t SCANNED PSEC? TELITHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TBLITHA V MAY: 11/142007 cur V g MSWM4 Congratulations on taking the first big step to improve your eligibility far services with us. During the phone conversation on 11/142007 we expressed our willingness to work with yon. At that time, you to set up a payment anangement and a due date that would be suitable to your circumstances. As a result, you said that you would send $100.00 by the last day of each month. We accepted this arrangement and your firat payment is due on i 1/30/2007, If you have any questions, please call us at 1.800-237-7328 or 234-8484 (enter 6) ext. 3119. Sincerely, PSECU Collections Department Charge Off Unit enc. Maln Addnsss I CrodA Union Place, Hor?sbcrPQe q j jj,on?°te Employees Credit Union ,?,---- k!11 001mv BO. Box 67013, HoOsh u PA 1 71 06-701 3 . 717.777.2100 LT DL 800.47267 The aedil union is kdemfir Insumd by the Notional Cwt Union Admirl*arlon, &PxA der " - LTDp) Opportunity lender wwuaPseeu.com } --SCANNEL) PSE(O 07/07/2008 TELITHA V MAY 176 CEMETERY ST, HUGHESVILLE, PA 17737 Dear TELITHA V MAY: PSECU did not receive your $100.00 loan payment on April 30'h, 2008 as you promised. If payments are not received as agreed we cannot honor any payment arrangements. Your Signature Loan is now overdue. We hope this is a simple oversight and your payment is in the mail today. Remember, your personal credit rating is one of your most important asset. If you have any questions, call 234-8484 in Harrisburg or call our toll-free number, (800) 237-7328. At the menu prompt, enter 6 then extension 3118. We are open from 8 a.m. to 5 p.m. Monday through Friday and 8 a.m. to noon on Saturday. Sincerely, Calply Lisa Carl Account Advisor Pennsylvania State Employees Credit Union Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328 Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD) psecu.com This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender rn n i ?I o SOH a , i m w i µ µ = Wa1C+C Z1 O-ib0 -1r µCm CU olrr b? c wmm z n z = 00 om = z N qo yr *rno M. oz4b zm =- wmbv m0 Ioxxx bn I am - O 0 O W N O - n = 0 0 N r N ?.. W W I ? tS W PRESORTED FIRST CLASS H aster fr7 ?: ? ? o C c col) C) 3 v: J p V: G) ci O7 I .(? a m N PSEc? 07/30/2008 Sent certified and regular delivery TELITHA V MAY 616 ERFORD RD, CAMP HILL, PA 1701) Dear TELITHA V MAY: PSECU has made several attempts to contact you and to negotiate suitable payment arrangements. We received no response. Your Signature Loan is 663 days past due! This Is your final notice. Unless we receive the payment amount of $4,304.46 by August to, 2008 we may refer your account to our Legal Review Committee. If this occurs, a judgment may be entered and executed against you. All court costs and fees will be added to your loan balance. If we do not take legal action and payments are not received, we will charge offyour account. You will still be responsible for the balance. In either case, your status will be reported to all national credit bureaus. This is a serious situation that requires your immediate attention. If you cannot make the full payment, we are willing to negotiate a reasonable payment schedule that fits your needs. Call me today to see if we can resolve this situation. I can be reached at 234-8484 in Harrisburg or call our toll-free number, (800) 237-7328. At the menu prompt, enter 6 then extension 3118. We are open from 8 a.m. to 5 p.m. Monday through Friday and 8 a.m. to noon on Saturday. Sincerely, ID If Lisa Carl Account Advisor Pennsylvania State Employees Credit Union Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328 Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD) psecu.com This credit union is federally insured by the Notional Credit Union Administration. Equal Opportunity Lender 7004 2510 0001 fill I n CD -1. L r m v X won rv< ? C ,v o U i? E .a 0 0 N In t-i 0 0 in 0 L-j 0 ti Q' Ul w Ln 7026 5354 -E? c-> ', o o A? v ? ? v a ?? ? ?~ ^?,? ?? .?°' cw+ ; r.J -?? r?r-"?_- ? =-i ? 1 f ?} .q ?J :? 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-05725 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS MAY TALITHA V 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 MAY TALITHA V but was unable to locate Her in his bailiwick. He ;therefore returns the COMPLAINT & NOTICE , , NOT FOUND , as to the within named DEFENDANT MAY TALITt?I V 616 ERFORD ROAD CAMP HILL, PA 17011 PER CURRENT RESIDENT, DEFENDANT MOVED TO PEOY COUNTY. Sheriff's Costs: Docketing 18.00 Service 15.00 Not Found 5.00 Surcharge 10.00 .00 l 0 /o06 P ?L-%/ 48.00 So answers R. Thom s Kline Sheriff of Cumberland County BARLEY SNYDER 10/07/2008 Sworn and Subscribed to before me this day of , A.D. 1 ? BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 No. 08-5725 Civil Term Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. TALITHA V. MAY, Defendant OURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA IVIL ACTION - LAW o. 08-5725 Civil Term PLAINTIFF'S MOTION TO AMEND CAPTION 1. On September 26, 2008, the above-captioned matter was initiated by Pennsylvania State Employees Credit tJnion's ("PSECU") filing a Complaint (the "Complaint"), a true and correct copy of which is attached hereto as F,xhibit "A" and incorporated herein by reference. 2. The Defendant has not yet been served with the Complaint. 3. Plaintiff's Complaint contains a certain typographical error identifying Defendant Telitha V. May as Talitha V. May. 2442493-1 4. Accordingly, the instant action was erroneously and inadvertently brought in the name of. "Pennsylvania State Employees Credit Union, Plaintiff v. Talitha V. May, Defendant." 5. The instant action should have been brought as: "Pennsylvania State Employees Credit Union, Plaintiff v. Telitha V. May, Defendant." 6. The typographical error has recently been discovered by Plaintiff. 7. Amending the caption will not prejudice the Defendant. WHEREFORE, Plaintiff respectfully requests that this Court enter an Order amending the caption in this case to read: Pennsylvania State Employees Credit Union, Plaintiff v. Telitha V. May, Defendant. Date: fr 6 Or BARLEY By: Shawn M. Long, Esquire Attorneys for Plaintiff, Pennsylvania State Empl Court I.D. No. 83774 , 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 Credit Union 2442493-1 2 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 N C= c? O - r tit ` ic"?Ti r 1J J Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff TALITHA V. MAY, V. Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. (2 - 57x5 , tm I-&," 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 this 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 by the Court without further notice to you for any money claimed in the Complaint or for any other claim or relief requested by Plaintiff(s). You may lose money or property or other rights important to you. Complaint- PSECU May E)&= A 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 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 St. Carlisle, PA 17013 Telephone: (717) 249-3166 or (800) 990-9108 Effective September 1, 2003 Complaint- PSECU_May 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 TALITHA V. MAY, V. Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. AVISO PARA DEFENDER Conforme a RCP No. 1018,1 del PA LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas dispuestas en las paginas siguientes, usted debe tomar la accion en el plazo de veinte (20) dias despues de esta queja y el aviso es servido, incorporando un aspecto escrito personalmente o por el abogado y archivando en escribir con la corte sus defensas u objeciones a las demandas dispuestas contra usted. Le advierten que si usted no puede hacer asi que el caso puede proceder sin usted y un juicio se puede incorporar contra usted por la corte sin aviso adicional a usted para cualquier dinero demandado en la queja o para cualquier otra demanda o relevacion pedida por Plaintiff(s). Usted puede perder el dinero o la caracteristica u otra endereza Complaint- PSECU_May importante a usted. USTED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE Un ABOGADO, VAYA A O LLAME POR TELEFONO La OFICINA DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De USTED La INFORMACION SOBRE EMPLEAR A un ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE LOS SERVICIOS JURIDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES EN Un HONORARIO REDUCIDO O NINGON HONORARIO. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249-3166 or (800) 990-9108 Efectivo 1 de Septiembre, 2003 Queja Complaint- PSECU_May 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 TALITHA V. MAY, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. No. Defendant COMPLAINT 1. Plaintiff, Pennsylvania State Employees Credit Union ("PSECU") is a Pennsylvania financial institution having an office at One Credit Union Place, Harrisburg, Pennsylvania 17110. 2. Defendant, Talitra V. May is an adult individual with a last known address of 616 Erford Road, Camp Hill, Pennsylvania 17011. 3. On or about July 3, 2006, Defendant applied for a Signature Loan Account ("Account") with PSECU. A true and correct copy of the Activation Notice is attached hereto as Exhibit "A" and incorporated by reference. Complaint- PSECU May 4. PSECU approved Defendant's application and opened an Account in Defendant's name. 5. Defendant made home improvements using the Account subject to the terms and conditions of PSECU's Loanliner Credit and Security Agreement and Loanliner Addendum ("Agreement"). A true and correct copy of the Agreement and Transaction Summary are attached hereto as Exhibit "B" and incorporated by reference. 6. Defendant is in default under the Account for failure to make payments when due. 7. Several notices of default were sent to Defendant: on November 14, 2006, January 26, 2007, June 18, 2007, August 23, 2007, September 18, 2007, October 5, 2007, November 6, 2007, November 14, 2007, July 7, 2008 and July 30, 2008. A true and correct copy of the notices are attached hereto as Exhibit "C" and incorporated by reference. The balance due and owing to PSECU from the Defendant on the Account is $6,956.20, plus collection costs of twenty percent (20%) which totals $1,391.24, plus costs. 9. PSECU has demanded payment from Defendant, but despite these demands, the Defendant has refused and continues to refuse to make payments. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant the name and address of the original creditor if different from the above. 23954371 2 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment in its favor and against Defendant, Talitha V. May, in the amount of $8,347.44, plus costs. BARLEY S Date: R /r d By: ,Shawn M. Long, Esqui Attorneys for Plainti Pennsylvania State mployees Credit Union Court I.D. No. 83 74 126 East King Street Lancaster, PA 17602 (717) 299-5201 Complaint- PSECU_May VERIFICATION [Pennsylvania State Employees Credit Union vs . Talitha V. May] I, Gregory R. Diffenderfer, being duly affirmed according to law, depose and say that I am the Collection Manager for Pennsylvania State Employees Credit Union; that I am authorized to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. To the extent that any of the averments in the foregoing document are based upon the understanding or application of law, I have relied upon counsel in making this Verification. This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Dated: 0' 11 F/OW Gregory R. Diffenderfer Complaint- PSECU_May I -a - SIGNATURE LOAN ACTIVATION NOTICE July 5, 2006 Applicant Information: SS #: 171-66-0732 Applicant: TELITHA V MAY Ref #: 548289 598 Work Telephone #: (717) 558-9500 Approval Amount: $7,000.00 Home Telephone #: (717) 986-0126 Account Number: 8104867034 Refinance: L20 Signature: I acknowledge receipt of the PSECU LOANLINER Disclosure and Credit Agreement and agree to be ound by the t ent. s Si V MAY Date q ?. SIGNATURE LOAN OPTIONS Purpose:U + 1 n"fib Please select one of the following Signature Loan disbursement options: S Send a ? check, or ® deposit to my Share 4 (MoneyHandle Che king Shares Please select one of the following Signature Loan repayment options: ? Payroll Deduction ? Home banking 12 Automatic Transfer from PSECU account ? Self Service Telephone ? Coupou ? Direct Payment from another financial institution FZ V lid L- Inp pWZ 83INnoo dr)o tlo3sd. F)(H= A PSE Pennsylvania State Employees Credit Union P.O. Box 67013 • Harrisburg, PA 1710&7013 & (717) 2348484 Harrisburg, (800) 237-7328 Nationwide the financial linke Loan Disclosures ! This LOANUNER• Credit and Security Agreement. which includes the Truth in Lending Disclosures, will be referred to as the Plan. The Plan documents include this agreement and an Addendum. You, your and borrower mean any person who signs the Plan. Credit union, we, our and us mean PSECU or anyone to whom the Credit ! Union translers its rights under the Plan. i HOW THIS PLAN WORKS - This is an open-end, multi-featured credit plan. Vie j anticipate that, from lime to time, you will borrow money (called "advances') under j the Plan. We are not required to make advances to you under the Plan and can refuse a request for an advance at any time. The Addendum describes the different types of credit (called "subaccounts) available under the Plan, the current interest rate for each subaccount expressed as a daily periodic rate and corresponding annual percentage rate and other charges. It may also have other i terms and a schedule !or determining the payment amounts. CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain subaccounts. It a credit limit is set for a subaccount, you promise not to exceed the i established credit limit. If you exceed the credit limit, you promise to repay immediately the amount which exceeds the credit limit. REPAYMENT -,You procuse._to-repay all amounts you owo under the Plan plus interest. Payments are due on the last day of the month unless we set a different day at the time of an advance. If the Addendum has no payment schedule for a subaccount, your payment will be determined at the time of each advance. Payments must include arty amount past due and any amount by which you have exceeded any credit limit you have been given for a subaccount. You may repay all or part of what you owe at any time without any prepayment penalty. Even if you prepay, you will still be required to make the regularly scheduled payments unless we agree in writing to a change in the payment schedule. If you have a joint sharedrah account, you will be responsible for paying all overdraft advances obtained by a joint holder of the sharedrah account. Unless otherwise required by law, payments will be applied to amounts owed under the Plan, in the manner the Credit Union chooses. PLAN ACCESS -You can obtain credit advances in any manner authorized by us, if we allow you to use your Ani/Debit card to access the Plan, you may be liable for the unauthorized use of your ATId/Debit card. You will not be liable for unauthorized use that occurs after you notity us, orally or in writing, of the loss, theft, or possible unauthorized use. If you believe your ATM/Debit card has been lost or stolen, immediately inform the Credit Union by calling or writing us at the telephone number or ! address that appears elsewhere in the Plan. It the card is used to obtain unauthorized advances directly from the Plan, your liability will not exceed S50. If the unauthorized withdrawal is from a sharedrat account, your liability is governed by the Regulation E disclosures you received at the lime you received your ATIA/Debit card, even it the withdrawal results in an advance being made from your overdraft subaccount. j FINANCE CHARGE - The dollar amount you pay for money borrowed is called a 'finance charge' and begins on the date of each advance. A finance charge will be computed separately for each separate balance under the Plan, To compute the finance charge, the unpaid balance for each day since your last payment (or since an advance if you have not yet made a payment) is multiplied by the applicable daily periodic rate. The sum of these amounts is the finance charge owed. The balance used to compute the finance charge is the unpaid balance each day after payments and credits to tl2Yba?rtce trays been subtracted-and any additions td the balance ? have been made. In addition to interest, we may charge other finance charges which I are disclosed on the Addendum. It the interest rate is a variable interest rate, the Addendum explains how the variable interest rate works. SECURITY -You pledge as security for the Plan all shares and dividends and, if any, all deposits and interest in all joint and individual accounts you have with us now and in the future. If a specific dollar amount is pledged for an advance, we will freeze shares in that account to the extent of the outstanding balance for the advance. Otherwise, your pledged shares may be withdrawn unless you are in default. The following paragraph applies In all states except in Ohio, Rhode Island and Massachusetts: We have a statutory lien on the shares and dividends and, if any, the deposits and interest in all individual and joint accounts you have with us and may exercise our rights under the lien to the extent permitted by state taw. (We are state char•,ered if our name does not include the term r-ederal Credit Union') For all borrowers: The statutory lien and/or your pledge will allow us to apply the funds In your account(s) to what you owe when you are in default. The statutory lien and your pledge do not apply to any Individual Retirement Account or any other account that would lose special tax treatment under state or federal law if given as security. Additional security for the Plan may be required at the time of an advance. if a subaccount identifies a type of property (such as "New Cars) you must give that type of property as security when you get an advance under that subaccount. A j subaccount name such aS 'Other Secured" means you must provide security ! acceptable to us when you obtain an advance under that subaccount. Property you give as security will secure all amounts owed under the Plan and all other loans you have with us now or in the future, except any loan secured by your principal dwelling. ! Property securing other loans you have with us may also secure the Plan. oeuru.tun,a G;10u? :ssa 2ua.A4.t aw rrs zEStave^ r? CREDIT INSURANCE - Credit life and/or credit disability insurance is optional under the Plan. If you quality for and purchase the insurance from us, you authorize us to add the insurance premiums monthly to your loan balance and charge you interest on the entire balance. If you elect credit insurance, your payments may increase or the period of time necessary to repay your advance may be extended. The credit insurance rates may change during the Plan. If the rates change, we will provide any notices required by applicable law. PERIODIC STATEMENT- On a regular basis you will receive a statement showing all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each pint borrower, notice to any one of you will be notice to all. JOINT ACCOUNTS - It this is a joint account, each of you is individually and jointly responsible for paying all amounts owed. That means we can enforce our rights under the Plan against any one of you individually or againt all of you together. If you give us inconsistent instructions, we can refuse to follow your instructions. Unless our written policy requires all of you to sign for an advance, each of you authorizes the other(s) to obtain advances individually and agrees to repay advances made to the other(s). Any joint accountholder may terminate the Plan by giving us prior written notice- It any of you terminate the Plan, the Plan is terminated for all of you. You remain liable individually and jointly for all advances incurred before termination. FEES AND CHARGES - If you give us a security interest in certain types of property, we may charge you a filing fee to perfect our interest in the property. If we do, the amount of the fee will be disclosed to you at the lime you obtain an advance. We may also charge you other fees in connection with the Plan. Our current fees are disclosed on the Addendum and will be added to your loan balance unless you pay them in cash. UPDATING CREDIT INFORMATION -You promise that you will promptly give us written notice if you move, change your name or employment, or if any other information you provided to us changes. Upon our request, you also agree to provide us updated financial information. DEFAULT - The following paragraph applies to borrowers fn Idaho, Kansas, Maine and South Carolina: You will be in default if you do not make a payment of the amount required when it is due. You will also be in default if we believe the prospect of payment, performance, or realization on any property given as security is significantly impaired. The following paragraph applies only to borrowers in Wisconsin: You will be in default if you fail to make a payment when due two times during any 12 month period. You will be in default if breaking any promise made under the Plan materially Impairs your ability to repay what you owe or materially impairs the condition, value, or protection of or our righlin any property you gave as security. The following paragraph applies only to borrowers In Iowa: You will be in default if you are more than 10 days !ate to making a payment. You will also be to delault it you do not comply with the terms of the Plan and your failure to comply i materially impairs any property you gave as security or your ability to repay what you owe under the Plan. The. following paragraph appl/gs to borrowers In all other states: You will be to default if you do not make a payment of the amount required when it is due. You will j be In default if you break any promise you made under the Plan or 4 anyone is in default under any security agreement made in connection with an advance under the Plan. You will be in default if you die, file for bankruptcy, become insolvent, if you make any false or misleading statements in any credit application or update of credit information, or if something happens we believe may substantially reduce your ability to repay what you owe. You will be in default if any property you have given us as security is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value of the property or our security interest in it. You will also be in delault under the Plan if you are to default under any other ban agreement with us. ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: When you are in default and after expiration of any right you have under applicable state law to cure your default, we can demand immediate payment of the entire unpaid balance under the Plan without giving you advance notice. The following paragraph applies to borrowers In all otherstates except Wisconsin i and Louisiana: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive t ! to demand for any right you have payment. notice of intent io accelerate and notice of acceleration. The following paragraphs apply to borrowers In all states except Wisconsin and Louisiana: It immediate payment is demanded, you will continue to Day interest unlit ! what you owe has been repaid at the applicable interest rates in effect or. if applicaNe. CPSLtct PS'_CU FORM #3145 EXHIBIT 11 LOANLiNER "Credit and Security Credit Agreement (continued) at the defauh rate disclosed on the Addendum. 11 a demand for immediate payment has been made, your shares andror deposits can be applied towards what you owe as provided in the section above called 'Security' We can also exercise any other rights given by law when, you a. a in default. You agree the Credit Union has the right to take possession of any property given as security under he Plan,, withoL4 judicial process. if this can be dons without breach of the peace. It we ask, you promise to deliver the property at a time and place we choose. It the property is a motor vehicle or boat, you agree that we may obtain a key or other device necessary to unlock and operate it, when you are in default. We will not be responsible for any 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 lot you to claim. After we have possession of the properly, we can sell it and apply the money to any amounts you owe us. We will give you notice of any public disposition or the date after which a private disposition will be held. Our expenses for taking possession of and selling the property will be deducted from the money received from the sale. Those costs may include the cost of storing the property. preparing it for sale and attorney's fees to the extent permitted under slate law or awarded under the Bankruptcy Code. You must pay any amount that remains unpaid after.the sale money has been applied to any unpaid balance under the Plan. You agree to pay interest on that amount at the same rate as the advance. or, if applicable, al the default rate disclosed on the Addendum, until that amount has been paid. The following paragraph applies only to Wisconsin borrowers: When you are in detauh and alter expiration of any right you have under applicable state law to cure your default. we may require immediate payment of your outstanding loan balance under the Plan and seek possession of property given as security. You may voluntarily give the property to us it you choose, or we may seek to take possession of the property by judicial process. It we repossess the property, you agree to pay reasonable expenses incurred in disposing of the property. If the property is a motor vehicle, mobile home, trailer. snowmobile, boat or aircraft, you will also be required to pay any costs permitted by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains unpaid after the sale money has been applied to what you owe under the Plan. You agree to pay interest on any unpaid amount at the same rate as the advance, or, 4 applicable, at the default rate disclosed on the Addendum, until that amount is paid. It the property is located outside Wisconsin at the time of default we may take possession of the property without judicial process, it permitted by the state where the property is located. The following paragraph applies only to Louisiana borrowers: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. If immediate payment is demanded, you will oontinue to pay interest until what you owe has been repaid at the applicable interest rates in effect unless a default rate is disclosed on the Addendum, It a demand for immediate payment has been made, the shares and deposits given as security for the Plan can be applied towards what you owe. We can also exercise any other rights given by law when you are in default and our rights under any security agreements you have with us. CANCELLING OR CHANGING THE PLAN - The tollowing paragraph applies only to borrowers In Illinois: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change to the interest rate or other charges will app!y to future advances. The following paragraph applies only to borrowers In Wisconsin: We can change the terms of the Plan from time to time in accordance with Section 422.415 of the N9sconsin Statutes. You will be notified of any change in terms. An increase in the daily periodic rate under a variable rate interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the credit union cancel the Plan, except to the extent that your liability is limited by Section 422.4155 of the Wisconsin Statutes. The following paragraph applies only to borrowers in Iowa. We can change the terms of the Plan from time to time after giving you any advance notice required by law. A change that increases the rate of finance charge or other charge. that increases the amount of your payments. or that otherwise adversely affects existing t balances will apply to existing balances only if you agree to the change or you use i the Plan after receiving notice that your use of the Plan means you agree the i change applies to existing balances. I The /allowing paragraph applies to borrowers In all other states: We have the r right io change the terms of the Plan from time to time after giving you any advance notice required bylaw. Any change in the interest rate will apply to future advances, and at our discretion and subject to any requirements of applicable law, will also apply to unpaid balances. i The following paragraph applies to all but Wisconsin borrowers: An increase in the daily periodic rate under a variable interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written notice. Your t obligation to pay the unpaid balances under the terms of the Plan continues whether you or the Credit Union cancel the Plan. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay enforcing any of our rights under this Plan any number of times without losing the ability to exercise our rights later. We can enforce this Plan against your :heirs or legal representatives. If we change the terms of the Plan, you agree that :his Plan will continue to protect us- CONTINUED EFFECTIVENESS - It any part of this Plan is determined by a tour j to be unenforceable, the rest will remain in etlect. NOTICE TO UTAH BORROWERS - This written agreement is a final expression of the ag:eement between you and the Credit Union. This written agreement may not i be contradicted by evidence of any oral agreement. The following is required by Vermont law - NOTICE TO CO-SIGNER - YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. The following paragraphs apply if you give security in connection with an i advance under the Plan. They apply to borrowers In all states except Louisiana. Louisiana borrowers will execute a separate security agreement. Borrowers in other states may also be asked to execute a separate security agreement. THE SECURITY FOR THE PLAN - You give us what is known as a security interest in all properly described in any receipt, voucher or other document you receive for an advance (the Advance'). The security interest you give includes all accessions. Accessions are things which are attached to or installed in the property now or in the future. The security interest also includes any replacements lot the property which you buy within 10 days of the Advance or any extensions, renewals or refinancing of the Advance. It also includes any money you receive from selling '' the property or from insurance you have on the property. If the value of the property I declines. you promise to give us more properly as security if asked to do so. WHATTHE SECURITY INTEREST COVERSICROSS COLLATERAL PROVISIONS I -The security interest secures the Advance described in the receipt, voucher or any other document you receive at the time of the Advance and any extensions. renewals or refinancings of the Advance. It also secures any other advances you have now or receive In the future under the Plan and any other amounts or loans, Including any credit card loan, you owe us for any reason now or in the future, except any loan secured by your principal residence. If the property is household goods as defined by the Federal Trade Commission Credit Practices Rule, ine property will secure only the Advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY -You promise that you own all property you give as security or it the Advance is to buy the property, you promise you will use ! the Advance for that purpose. You promise that no one else has any interest in or claim against the properly that you have not already told us about. You promise not to sell or lease the properly or to use it as security for a loan wilh another creditor until the Advance is repaid. You promise you will allow no oche: security interest or lien to attach to the property either by your actions or by operation of law. PROPERTY INSURANCE, TAXES AND FEES - You must maintain properly insurance on all property that you give as security under the Plan. You may purchase I the property insurance from anyone you choose who is acceptable to the Credit Union. The amount and coverage of the property insurance must be acceptable to us. You may provide the property insurance through a policy you already have, or through a policy you get and pay for. You promise to make the insurance policy payable to us and to deliver the policy or proof of coverage to us if asked to do so. It you cancel your insuranA and gel a refund, we have a right to the refund. II the property is lost or damaged, we can use the insurance settlement to repair the j property or apply it towards what you owe. You authorize us to endorse any draft or I check which may be payable to you in order for us to collect any refund or benefits due under your insurance policy. You also promise to pay all taxes and 'ees (like registration fees) due on the property. I 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 lot the purpose of determining whether you and j other borrowers have complied with the insurance requirements of our ban agreements I or may engage others to do so. The insurance charge added to an advance may include (1) the insurance company's payments to us and 12i the cost of determining compliance with the insurance requirements. If we add amounts lot taxes, lees or insurance to the ; unpaid balance of an advance, we may increase your payments to pay the amours added within the term of the insurance or approximate term o' the advance. INSURANCE NOTICE - If you do not purchase the required properly insurance, the insurance we may purchase and charge you lot wit; cover only our interest in the t property. The premium for this insurance may be higher because the insurance company may have given us the right to purchase insurance after uninsured ! collateral is lost or damaged. The insurance will not be liability Insurance and i will not satisfy any state financial responsibility or no fault laws. PROTECTING THE SECURITY INTEREST - If your state issues a true for the property. you promise to have our security interest shown on the title. We may have to file what is called a linancing statement to protect our security inieresf lrom 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 arty attorney fees, we incur in protecting our security interest and rights in the property, i to the extent permitted by applicable law. LOANL1NfR' Credit and Security Credit Agreement (continued) 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) tnfarm us in writing before changing your address. (4) Allow us to inspectt`te p:operty. (5) Promptly notify us it the property is damaged, stolen or axsed. (6) Not use the property for any unlawful purpose. (7) Not to reline property in another state without telling us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE. YOU MAY HAVE TO PAY THE DIFFERENCE. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to fail to return a motor vehicle that is subject to a security interest, within thirty days after you have received notice of default. The notice wifl be mailed to the address you gave us. It is your responsibility to notify us it your address changes. The maximum This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. You are advised to read your monthly statement and review it for any error discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT. If you think your statement is wrong, or it you need more information about a transaction on your statement, write us on a separate sheet afthe address fisted on your statement. You are required to notify us in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transactions on your account. Failure to notify us may result in your acceptance of any responsibility for payment or reimbursement to us for any such error or discrepancy on your account. Write to us as soon as possible. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: Your name and account number. The dollar amount of the suspected error. Describe the error and explain, it you can, why you believe there is an error. It you need more information, describe the item you are not sure about. 0 you have authorized us to pay a credit card account automatically from your share account or checking account, you can stop the payment on any amount you think is wrong. To slop the payment your letter must reach us 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 letter within 30 days. unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the statement was correct. In this Agreement, the words you and your means each and all of those who apply for the card or who signs this Agreement. Card means the Visa Credit Card and any duplicates and renewals we issue. Account means your Visa Credit Card Line of Credit account with us. We, us, and ours means this Credit Union. 1. RESPONSIBIL4T*---N we+seue you-e card yow-ayreeto rep"debtaard U,e_ Finance Charge arising from the use of the card and the card account. For example, you are responsible for charges made by yourself, your spouse and minor children. You are also responsible for charges made by anyone else to whom you give the card, and this responsibility continues unfit the card is recovered. You cannot disclaim responsibility by notifying us, but we will close the account for new transactions it you so request and return all cards. Your obligation to pay the account balance continues even though an agreement. divorce decree or other court judgment to which we are not a party may direct you or one of the other persons responsible to pay the account. The cards remain our property and you must recover and surrender to us all cards upon our request and upon termination of this Agreement. 2. LOST CARD NOTIFICATION - It you believe the card has been lost or stolen, you will immediately call the Credit Union at (717) 234-8484 or (800) 237.7328. After hours call (800) 556-5678. 3. LIABILITY FOR UNAUTHORIZED USE -You agree to notify us immediately, orally x in writing of the loss, theft or unauthorized use of your Credit Card. You may be liable br the unatAhorLzed use a your Credit Card. Yaj will not be liable for unauthorized use tftat occurs after you notify us of the loss, theft, or possible unauthorized use. You will have no liability for unauthorized purchases made with your Credit Card, unless you are grossly negligent in the handling of your Card. In any case, your liability will not exceed W. 4. CREDfT LINE - If we approve your application, we will establish a self- •eplenishing Line o! Cred for you and notify you of its amount when we issue the :ord. You agree not to let the account balance exceed this approved Credit Line. Each ;ayment you make on the account will restore your Credit Line by the amount of the iayment which is applied to the principal. You may request an increase in your Credit penalty for uniaw!ul failure to return a motor vehicle is one year in prison ano or a fine of 5150,000. For those members who purchase a vehicle under the DRIVe Program, please review the following FTC Notice: NOTICE ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED WITH THE PROCEEDS HEREOF RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to send statements to you for the amount you question, including finance charges. and we can apply any unpaid amount against your credo limit. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your statement that are not in question. If we find that we made a mistake on your statement, you will not nave to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the dale that it is aue. It you tail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within ten days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your statement. And, we must te!I you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first S50 of the questioned amount. even it 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 to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the property or services. There are two limitations on this right: (a) You must have made the purchase in your home state or, it not within your home state, within 100 miles of your current mailing address; and (b) The purchase price must have been more than S50. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or services. Line only by written application to us, which must be approved by our credit comminee or ban officer. By giving you written notice we may reduce your Credit Line from lime to time, or with good cause, revoke your card and terminate this Agreement. Good cause includes your failure to comply with this Agreement or any other agreement with 45._2C9...XAdye!se reevaluation-of your creditworthiness. You may also terminate this Agreement at any time, but termination by either of us does not affect your obligation to pay the account balance. 5. CREDIT INFORMATION - You authorize us to investigate your credit standing when opening, renewing or reviewing your account, and you authorize us to disclose information regarding your account to credit bureaus and other creditors who inquire of us about your credit standing. 6. MONTHLY PAYMENT - We will mail you a statement every month showing your Previous Balances of purchases and cash advances, the current transactions on your account, the remaining credit available under your Credit Line, the Now Balances of purchases and cash advances, the Total New Balance, the Finance Charge due to date, and any other billed fees, and the Minimum Payment required. Every month you must pay at least the Minimum Payment within 25 days of your statement closing date. By separate agreement you may authorize us to charge the minimum payment automatically to your snare or checking account with us. You may, of course, pay more frequently. pay more than ft Minimum Payment, or pay the Total New Balance in full, and you will reduce the finance charge by doing so. It your monthly payment exowds the total credit line balance owed, we will automatically post the credit to your St snares. The minimum payment wttl be (a) 2% of your Total New Balance, rounded up to the next even dollar, or (b) 520.00, whichever is greater. In addition, of arty time your Total New Balance exceeds your Credit Line, you must immediately pay the excess upon our demand. We will apply payments in the hohowmg manner: firs; to previous late lees, then to previous cash advances finance charges. then to previous purchase finance charges, then to current late fees. then to previous cash advance balances. Men to previous purchase balances in the order that tney were posted ;o your account. men to current cash advance balances. ano then to current purchase balances Visa' Credit Card Agreement and Truth in Lending Disclosure (continued) 7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by paying the full amount of the New Balance of Purchases each month within 25 days of your statement dosing date. Otherwise, the New Balance of Purchases, and the subsequent purchases from the date they are posted to your account, will be subject to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average adjusted daily balance (see explanation below), including new purchases, for the billing cycle by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Cash Advances. We calculate your finance charge on cash advances by multiplying the average ad usted daily balance (see explanation below) for cash advances during the billing cycle by the monthly periodic advance rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Daisy Balance for Puchases - The Average Daily Balance for Purchase Transactions is calculated by adding the Daily Balances (Purchase Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day in the billing cycle. This gives us the Daily Balance for purchases. Average Daly Balance for Cash Adrdnces - Cash Advance Transactions which are posted to your account are not included in the Average Daily Balance calculation for purchases, and are therefore not subject to the monthly periodic rate for purchases. The Average Daily Balance is calculated separately for Cash Advances and is subject to the Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions is calculated by adding the Daily Balances (Cash Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for cash each day, we take the following steps: We take the outstanding balance (alt amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of alI credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Purchase Transactions thal posted to your account on that day or in any previous day in the billing cycle. This gives us the Daily Balance for Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account. Payments are applied In the following manner: first to previous late tees. then to previous cash advances finance charges. then to previous purchase finance charges, then to current late fees, than to previous cash advance balances, then !o previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. Credits are applied first to the particular type of debt which is being credited, if any, and then to the balance of your account. Note also that if the total of the payments and credits which are posted to your account by the Payment Due Date shown on a statement is equal to of exceeds the New Balance shown on that statement, we will not apply the Monthly Periodic Rate to your Account on your next statement. 8. DEFAULT-You will be in default if you fail to make any Minimum Payment within 25 days after your monthly statement closing date. You authorize us to transfer funds sufficient to make the minimum payment due if your Visa loan is in default. You will also be in default if your ability to repay us is materially reduced by a change in your employment, an increase in your obligations, bankruptcy or insolvency proceedings Involving you, your death or your failure to abide by [his Agreement, or if the value of our security interest materially declines. We have the right to demand immediate payment of your tug accouunt balance if you default, subject to our giving you any notice required by law. To the extent permitted by law, you will also be required to pay our collection expenses, including court costs and reasonable attorney fees. 9. USING THE CARD - To make a purchase or cash advance, there are two alternative procedures to be followed. One is for you to present the card to a participating Visa plan merchant, or another financial institution, and sign the saves or cash advance draft which will be imprinted with your card. The other is to complete the transaction by using your Personal Identification Number (PIN) in conjunction with the Card in an Automated Teller Machine or other type of electronic terminal that provides access to the Visa system. You agree that you will not use your card for any i transaction that is illegal ;under applicable federal, state, or local law. The monthly statement will identity the merchant, electronic terminal or financial institution at which transactions were made, but sate, cash advance, credit or other slips cannot be returned with the statement. You w:li retain a copy of such slips furnished at the time of the trarsiction in order to verity the monthly statement. The Credit Union may make a reasonable charge for photocopies of slips you may request. 10. OVERDRAFT OPTION - It you elect to overdraft to yout PSECU Visa Credit Card, that election is subject to the existing credit limit and the agreement it represents and the current ban policy at the time of the overdraft. You also understand that an overdraft will be considered the same as a cash advance on your PSECU Visa Credit Card and that the current Annual Percentage Sale for cash advances will apply. 11. RETURNS AND ADJUSTMENTS - Merchants and others rrho honor the card may give credit for returns and adjustments, and they will do so by sending us a credit slip which we will post to your Visa line of credit. It your credit and payments exceed what you owe us, we will automatically post the excess credit balance to your S1 Shares within 75 days. If the balance is one dollar or more. upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS - The exchange rate between the tansaction currency and the billing currency used for processing international transactions is a rate selected by Visa from the range of rates available in wholesale currency markets for the applicable central processing date, which rate may vary from the rate Visa itself receives, or a government-mandated rate in effect for the applicable central processing date. In each instance, an adjustment may be assessed cased on the ISA fee imposed by Visa. This fee, which totals 1% of the transaction amount, will be assessed on all transactions where the merchant country differs from the country of the card issuer. 13. SPECIAL RULES FOR VISA PURCHASES - If you disagree or find an error with a Visa transaction, and have tried in good faith to correct the problem with the merchant or the charges are the result of unauthorized or fraudulent use, or your purchase cost more than S50 and was made from a plan merchant in your slate within 100 miles of your home, contact PSECU. 14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transaction on your account Telephoning PSECU does not presek* your dispute rights. You may be required to provide us with documentation 10 support your dispute claims. In addition, you may be required to complete a standard dispute form oullining the details of your dispute. In cases of fraudulent card use. PSECU wr.11 also require a notarized affidavit, In some cases we may ask you to noliy, the local authorities. If we do not receive the proper requested documentation, in the time specified you may be held responsible for the transaction(s) in question. PSECU must adhere to strict dispute timeframes set forth by Visa. 15. SECURITY INTEREST - To secure your account, you grant us a purchase money security interest under the Uniform Commercial Code in any goods you purchase through the account. If you default, we will have the right to recover any of these goods which we have not been paid lot through our application of your payments in the manner described in the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have if you are in default to prevent withdrawal of your unpledged credit union shares (Deposits) below the unpaid balance of your account. However, if you give or have given us a specific pledge of your credit union shares (Deposits) by signing the Pledge of Shares or otherwise, or any other security interests for all your debts, your account will be secured by your pledged shares (Deposits) and by the properly described in those other security agreements, except for your home. 16. EFFECT OF AGREEMENT - This Agreement is the contract which applies to all transactions on your account even though the sales, cash advance, credit or other slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance %4ritten notice required by law. Your use of the card thereafter will indicate your agreement to the amendments. To the extent the law permits, and we indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. 1 17. LATE PAYMENT CHARGE - 11 your Minimum Payment is not received by the f first day of the month following your due date, you will be subject to a $20 charge. 18. RUSH FEES - You may incur additional charges for rush processing alto rush delivery of cards andror PIN mailer. 19. OVER LIMIT FEE -A S20 fee will be applied for each monthly statement dosing date on which the adstanding balance exceeds the assigned credit limit by more than S 1 Q0. 20. DRAFT COPIES - You may incur an additional charge for transaction summarylsale draft documentation. 21, COPY RECEIVED - You acknowledge receipt of a copy of this Agreement. 22. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use your card for any transaction that is illegal under applicable lederaf, stale. or local law. 23. NO USE - Inactive Visa accounts that have no purchase or cash activity may be closed without notice to you after 16 months of no activity. 24. 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O a r d a ?tI 1. November 14, 2006 TELITHA V. MAY g?bt{??a103y 88 MANNY DRIVE MIDDLETOWN, PA 17057-5542 Dear MS. MAY: Your services with PSECU have been terminated. This action is a result of PSECU policies that allow us to terminate services due to a delinquent loan obligation. Your Check card is invalid and will be retained if used after November 13, 2006. If you have any concerns or questions, call 800.237,7328 nationwide or 717.234.8484 in Harrisburg. At the menu prompt, enter 6 then ext. 3118. Sincerely, Michelle Hess Service Advisor Member Services Pennsylvania State p Main Address: 1 Credit Union Piece, Harrisburg, PA 17110-2990 - 717.22 4.84484 8 0 3!7 7326 ' _Mai ina Address: P.O. Box 67013, Hook-bus PA 17106-7013 • 717.777.21 W? D) .800.472.196% (TDD?? is &4, y insured by the Narwnd G-1111 UW1 ?ldrroniskafon. f:quol Opporlurrry (ender www.pseeu.eom EXHIBIT C PSECO MLr'M V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELITTIA V MAY: 01/26/2007 COPY Nq 8(e--103L( PSBCU has made several attempts to contact you and to negotiate suitable payment arrangements. We received no response. Your Signature Loan is 6 months past duel This is your Huai notice. Unless we receive the payment amount of $1,154.58 by February 12, 2007, we may refer your account to our Legal Review Committee. If this occurs, a judgment maybe entered and executed against you. All court costs and fees will be added to your loan balance. Ifwe do not take legal action and payments are not received, we will charge offyour account. You will still be responsible for the balance. In either case, your status will be reported to all national credit bureaus. This is a serious situation that requires your immediate attention. If you cannot make the full payment, we are willing to negotiate a reasonable payment schedule that fits your needs. Call me today to see if we can resolve this situation. I can be reached at 234-8484 in Harrisburg or call our toll-free number, (800) 237-7328. At the menu prompt, enter 6 then extension 3118, We are open from 8 a.m. to 5 p.m. Monday through Friday and 8 a.m. to noon on Saturday. Sincerely, Michelle Hess Account Advisor t r i Pennsylvania Slate Employees Credit Union i Main Address: I Credit Union Place, Harrisburg, PA 17110-2990 • 717234.8484 • 800237.7328 Address: P.O. Box 67013, Harrisburg, PA 17106.7013 • 717.777.2100 (TDD_) • 800.472.1967 (TDD) :ffl aUninAdm"nrstrallon.Equal Opportunity lender www.psecu.com ANNED PSECO coo Py 06/18/2007 $1 by-%kj--1 o3A TELITHA V MAY 88 MANNY DR, MODLETOWN, PA 17057-5542 Dear TELITHA V MAY: - On 02122!2007 your Signature Loan was charged off for $7,456.20. You are still responsible for repayment of this entire debt. Because asterest stopped accruing, this allows us to accept payment arrangements suitable to your presentflnancialsihtation. As your Account Advisor I will assist you with questions and concerns. I will work with you to help you get back on track with us. This will give you the opportunity to become eligible for our member services. Muse call me at 234-8484 in Harrisburg or call our toll free number (800) 237-7328. At the menu prompt press 6 then ext. 3119. - Sincerely, Linda Carter Account Advisor enc. f Penn vania Slate Empployeas Credit Union Main Address: 1 Crodil Union Place, Harrisburg, PA 17110-2990 • 717.2 4 .8484 • 800.237.7328 ldnen: P.O Box 67013, Harrlsbu%PA 17106.7013 • 717.777.2100 TDD 800.472.1967 (TD_ Dl? A Union Ad,nrnis?ro6on. Equal Opportunity lender ?- www.psecu.com NED 0 PSECO 08/23/2007 z TELYTHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELITHA V MAY: Congratulations on taking the first big step to improve your eligibility for services with us. During the phone conversation on August we expressed our willingness to work with you. At that time, you to set up a payment arrangement and a due date that would be suitable to your circumstances. As a result, you said that you would send $50.00 by the 300 of each month. We accepted this arrangement and your first payment is due on August 30, 2007. Please mail the enclosed card and your payment in the envelope provided. The card and another envelope will be returned for use with your next payment. If you have any questions, please call us at 1-800-237-7328 or 234-8484 (enter 6) ext. 3119. Sincerely, PSECU Collections Department Charge Off Unit enc. 1 Pennsylvania State Employees Credit Union Main Address: 1 Crodit Uneon Place, Harrisb PA 17110-2990 • 717.234.8484 • 800 237.7326 Address: P.O. Box 67013, Homsburg, PA 17106-7013 • 717.777.2100 D 800.472.1967 (TDD) ve?rtJrMOnlldminipmror.EqualOpportunNylender ?? wwwpsecu.com ---L NED PSE(O... TEUM V MAY, 88 MANNY DR, - MIDDL#OWN, PA 17057-5542 09/18/2007 COO p17 T1014 rN39 Dear TELITHA V MAY: We did not receive your first payment of $50.00 as agreed. And, we hope that you simply overlooked the date. On August 23, 2007, we expressed our willingness to work with you, During that conversation, ou set up a payment arrangement for $50 00 monthly starting on August 31, 2007. Please send your payment to us today. Remember, once your account is paid you will be eligible for our member services. If you need more help, please call me at 1-800-237-7328 or 234-8484 (enter 6) ext. 3119. Sincerely,'. t Michelle Hess Account Advisor r• f Pennsylvania State Employees Credit Union Win Address: 1 Credit Union Pk-, Harrisburg, PA ) 7110-2990 • 717.234.8484 • 600.237.7328 M2Ain9.Address P.O. B. 67013, Fbrrisburg PA 17106-7013 • 717.777_2100 D • 800.472 i 967 x DD T}ds o edR orlon :s kd{7ally mired by •6e Not" cr.N uru'or. Adndnlnnkion. Equal OpoAunily Lander - j `-- - -?- www.pseeu.com N 1,11ki N E PSEC# TELITHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELITHA V MAY: 10/05/2007 COPY %k a4&°` c-3-! On June 18, 2007, I sent you a letter concerning your Charged-Off Signature Loan. This account still has a balance of $7,456.20. It is very important that you contact me immed€ately. 'e are willing to work with you to imnroye vavr credit value with us Please call me at 1 -800-237-7328 or 234-8484 (enter 6) eat 3119 to discuss a surtable payment arrangement. When your balance is paid in full, we will report it to the credit reporting agencies as a paid charge off. And, you will be eligible to apply for our member services. Upon your request, we can refer you to an agency that can help you with your budget and other debt problems. This is a non-profit agency and the service is free. Let us help you get back on track. Sincerely, Michelle Hess Account Advisor Pennsylvania State Employees Credit Union,' Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328 Mailing Address: P.O. Box 67013, Horrisburg:PA 17106-7013 • 717_777.2100DOj_ 800.472_1967 Tf_Dp)-. _ TNs wd t union it ;4-k ;.-d by tw NaFonol Zr.; Unioa AdmGiistrolton Egwl Oppo Wnpy lender www.psecu.com ED PSECO 1l/o6noo7 Sent via certifrel & regular snail TELPTHA V MAY 88 MAMMY DR, MIDDLBTOWN, PA 17057-5542 Dear TELITHA V MAY, SETTLE YOUR CREDIT UNION DEBT AND CET A 10% DISCOUNn As a Credit Union, we recognize that unexpected occurrences can sometimes result in difficulty meeting financial obligations. PSECU would like to help you with fulfilling your outstanding obligation with -time a agreementopportunity . to satisfy your severely delinquent PSECU Charged-Off Signature Loan by establishing a monthly paymentone We can help if you are willing to work with us; however, a decision must be made now as we are on the verge of pursuing legal remedies to collect your debt. To assist with your decision, I would like to describe two scenarios. Allowing us to work with you: •. We will reduce your current Charged-Off Signature Loan balance from $7,456.20 to $6,710.58. -We will stop all interest and late fees from further increasing your obligation. We will work with you to establish a reasonable monthly payment. :-Your credit report, which now reflects a charged-off account, will show you have resumed making payments. +This is a one-time offer which is good for 14 days from the date of this letter. If you fail to consistently make the established monthly payment, this agreement will be immediately voided and the loan will be turned over to our attorney for legal action. Ignoring this letter and doing nothing could result in the following: -We will forward your file to our attorney or third-party collection agency following 14 days of this letter. Collection costs of 20% plus additional court costs will be added to your outstanding Cbarged-Off Signature Loan balance resulting in an increased outstanding obligation. ?Our attorney will file a judgment against you in Civil Court for the increased amount. Your appearance in court will be requested. •2•A Lien will be placed on your personal property and be reflected on your credit report for up to 20 years making it more difficult to obtain credit in the future including buying a vehicle and buying or selling a house. -Any co-applicant on this loan will be negatively impacted in the same way. 4-Your account could be referred to a third-party collection agency for additional collection efforts. This choice is clearly up to you. Please call one of our member service representatives, toll free, at 1-800-237-7328, or locally at 717-234-8484, extension 3119, to take advantage of this one-tithe offer. Sincerely, Dave Warwavesyn Vice President Member Services Main Address; I Credit Upton Place, Harrisburg,PPA 171 0-299001717.234 8484 CB00 237,7326 ?'cred.dos ,, - A Equal A der 7 , Tha union is federally Ensured br the National C?d? Unwn n3sburgu PA ] 7106-70i 3 • 717_777,2100 (TDDI .800_472.1967 (iDD) , www.psecu.com TANNED ?B ?f (? s NO& ?0 F e : Pb3l Q ? Faa - 1f 1 ;C?,Oj r-7 4 blabd rye °2. /s o4sV Y°? J m ire: Asa ft. @ `? o 4 ?' Soll `'s` U Telrtha arao s8 Mann y -. Middlaf?, ?P ..--?.?.. .. •A 17057-s?e?___. _ C(D p 8l6yXle-tL3V. A A -, mem a a Heehi?ad o.wwy Is -MI t ¦ Pttd your naoa and ukhu on to Rvase - ? SOthatM B myLL W r . Wnj r h the wmnpkoe„ Atach thb or on the hart K apace pawns o. Dam bm t t. awx ?eeRa.a 6Y MYES W rd tddeabduW.. Tel'itha V_ May 88 Manny Dr. PA 17057-5542 n t ddl . , ow e Mi i - - Oedffiw UM 0t3- MH - 0 paodww 0 Raaan ReowforM $?o?}8cn703? °OnawMA °r-Ma f. pes67dw peavayt p3ba Foo 016$ Z Ai&=Wftmamiad6eU 7003 3110 DD00 4558 9679 (Gao?areom . Ps Fomt 3811, Fehnary zoos Doom psWm Recdpt , ,sa SCANNED PSE TELITHA V MAY 88 MANNY DR, MIDDLETOWN, PA 17057-5542 Dear TELITHA V MAY; 11/14/2007 cur u ?wqs/?M? Congratulations on taking the first big step to improve your eligibility for services with us, During the phone conversation on 11/14/2007 we expressed our willingness to work with you. At that time, you to set up a payment arrangement and a due date that would be suitable to your circumstances. As a result, you said that you would send $100.00 by the last day of each month. We accepted this arrangement and your first payment is due on 11/30/2007. Please mail the enclosed card and your payment in the envelope provided The card and another envelope will be returned for use with your next payment If you have any questions, please call us at 1-800-237-7328 or 234-8484 (enter 6) ext. 3119. Sincerely, PSECU Collections Department Charge Off Unit enc. Pennsylvania Siate Employees Credit Union Main Address: 1 Credh Union Pfoca, Horrisbu , PA 17110-2990 . 717234.8484 • 800.237.7328 Maih'o_Address: P.O. Box 67013, Hcrrisbu , Pry A 171p§-- _717.777.2100 9CtDL 800.472.1967 Op This aide union is federally insured by the National Gedif Union Admkisirotion. -" - - -? Equal Opportunity finder www.pseeu.c om } SCANNED PSE(40i 07/07/2008 TELITHA V MAY 176 CEMETERY ST, HUGHESVILLE, PA 17737 Dear TELITHA V MAY: PSECU did not receive your $100.00 loan payment on April 30`h, 2008 as you promised. If payments are not received as agreed we cannot honor any payment arrangements. Your Signature Loan is now overdue. We hope this is a simple oversight and your payment is in the mail today. Remember, your personal credit rating is one of your most important asset. If you have any questions, call 234-8484 in Harrisburg or call our toll-free number, (800) 237-7328. At the menu prompt, enter 6 then extension 3118. We are open from 8 a.m. to 5 p.m. Monday through Friday and 8 a.m. to noon on Saturday. Sincerely, COO p?7 Lisa Carl Account Advisor Pennsylvania State Employees Credit Union Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328 Mailing Address: PO. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD) pseCU This credit union is federally insured by the National Credit Union Administration, Equal Opportunity Lender Lon IT7 m " x 5m z m CD I?'1 F?1 tQh W! b' w' W? c, F+ ? O O -Imzm M. OADU --1? µGD C-i omrr vp ?zmm x w 'R z - A-1-1 -I?I 00 om _ W•n0 014 x'mo m. 0TUD zw OUDO a 0 0 - 10AA4 fin I am O 0 o 0, 0 O 0 0 O I ? H ?.a tJ IJ p w ? PRESORTED FIRST cL_ASS h06 4 Hasler Ci 49 3 "? J A r V 0 PSECO 07/30/2008 Sent certified and regular delivery TELITHA V MAY 616 ERFORD RD, CAMP HILL, PA 17011 Dear TELITHA V MAY: PSECU has made several attempts to contact you and to negotiate suitable payment arrangements. We received no response. Your Signature Loan is 663 days past due! This is your final notice. Unless we receive the payment amount of $4,304.46 by August 1.0, 2008 we may refer your account to our Legal Review Committee. If this occurs, a judgment may be entered and executed against you. All court costs and fees will be added to your loan balance. If we do not take legal action and payments are not received, we will charge off your account. You will still be responsible for the balance. In either case, your status will be reported to all national credit bureaus. This is a serious situation that requires your immediate attention. If you cannot make the full payment, we are willing to negotiate a reasonable payment schedule that fits your needs. Call me today to see if we can resolve this situation. I can be reached at 234-8484 in Harrisburg or call our toll-free number, (800) 237-7328. At the menu prompt, enter 6 then extension 3118. We are open from 8 a.m. to 5 p.m. Monday through Friday and 8 a.m, to noon on Saturday. Sincerely, r-17 OF-ly Lisa Carl Account Advisor Pennsylvania State Employees Credit Union Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328 Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (!DD) psecu.com This credit union is federally insured by the National Credit Union Administration. Equal Opportunity lender fill T N 3% z N pO A i 0 0 ti w L-i 0 0 C3 0 0 ti G' w w Ln m 7004 2510 0001 7026 5354 h' r? 4 CO r>rs? No. 08-5725 Civil Term 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 COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. TALITHA V. MAY, Defendant 08-5725 Civil Term PLAINTIFF'S AMENDED MOTION TO AMEND CAPTION 1. On September 26, 2008, the above-captioned matter was initiated by Pennsylvania State Employees Credit Union's ("PSECU") filing a Complaint (the "Complaint"), a true and correct copy of which is attached hereto as Exhibit "A" and incorporated herein by reference. 2. The Defendant has not yet been served with the Complaint. 3. Plaintiff's Complaint contains a certain typographical error identifying Defendant Telitha V. May as Talitha V. May. 2460245-1 4. Accordingly, the instant action was erroneously and inadvertently brought in the name of. "Pennsylvania State Employees Credit Union, Plaintiff v. Talitha V. May, Defendant." 5. The instant action should have been brought as: "Pennsylvania State Employees Credit Union, Plaintiff v. Telitha V. May, Defendant." 6. The typographical error has recently been discovered by Plaintiff. 7. Amending the caption will not prejudice the Defendant. 8. No judge has ruled upon any issue involving this case. 9. No opposing counsel has entered his or her appearance in this case, and, therefore, the Plaintiff has not sought concurrence. WHEREFORE, Plaintiff respectfully requests that this Court enter an Order amending the caption in this case to read: Pennsylvania State Employees Credit Union, Plaintiff v. Telitha V. May, Defendant. Date: Z Z ?0 BARLEY By: E13vLLC Shawn M. Long, 1/ quire Attorneys for Plat tiff, Pennsylvania St to Employees Credit Union Court I.D. No. 83774 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 2460245-1 2 07 1 :fi'r` No. 08-5725 Civil Term BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 By: Colleen K. Brelje, Paralega 501 Washington Street P.O. Box 942 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. TALITHA V. MAY, Defendant Attorneys for Plaintiff Pennsylvania State Employees Credit Union OURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA IVIL ACTION - LAW o. 08-5725 Civil Term PROOF OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF BERKS . ss. Colleen K. Brelje, Paralegal, being sworn according to law, deposes and says that she served a true and correct copy of the Amended Motion to Amend Caption upon Telitha V. May, at her last known address of 616 Erford Road, Camp Hill, PA 17011, via First Class Mail, postage prepaid on December 4, 2008 at 5:00 p.m. BARLEY SNYDER LLC Sworn to and subscribed before me this 4th day of December, 2008. otary Public 2442486-1 Reading, PA 19603-0942 (610) 376-6651 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Margaret C. Edwards, Notary Public City Of Reading, Berks County My Commission Expires March 22, 2009 Member, Pennsylvania Association of Notafts c? . cl N C5 r y ? C. 4- N o[Q 0 8 03 No. 08-5725 Civil Term CO CU CIV ORDER AND NOW, this _ 9 day of _ 2008, upon consideration of Plaintiff's BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299-5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES URT OF COMMON PLEAS OF CRF,DITUNION, MBERLAND COUNTY, PENNSYLVANIA Plaintiff IL ACTION - LAW V. No. 08-5725 Civil Term i TALITHA V. MAY, Defendant Motion to Amend Caption, IT IS HEREBY ORDERED that the caption is amended as follows: Pennsylvania State Employees Credit Union, Plaintiff v. Telitha V. May, Defendant. BY THE OURT: .1. 4 200245-1 0 ? w GTE -!y LU V d I) ' a 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. TELITHA V. MAY, Defendant OURT OF COMMON PLEAS OF ERLAND COUNTY, PENNSYLVANIA ACTION - LAW 08-5725 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned action. BARLEY YI R LLC BY: awn M. Long, Esquire Attorneys for Plaintiff Pennsylvania State Employees Credit Union Court I.D. No. 83774 126 East King Street Lancaster, PA 17602-2893 717-299-5201 2478174-1 4 -.. r V + ' r r FA SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-05725 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS MAY TALITHA V R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: MAY TALITHA V but was unable to locate Her deputized the sheriff of DAUPHIN in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 30th , 2008 , t attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin County 47.25 Postage 1.85 86.10 12/30/2008 BARLEY SNYDER s office was in receipt of t So answers; J Thomas i. e Sheriff of,Cumberland County Sworn and subscribe to before me this day of A.D. I& The Court of Common Pleas of Cumberland. County, Pennsylvania Pennsylvania State Employees Credit Union vs. Talitha V. May No. 08-5725 civil Now, December ?2, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ,r Sheriff of Cumberland County, PA Affidavit of Service Now, , 20 , at within upon at by handing to a and made known to copy of the original So answers, Sheriff of Sworn and subscribed before me this day of , 20 o'clock M. served the COSTS SERVICE _ MILEAGE _ AFFIDAVIT the contents thereof. County, PA (ffilfitit of the c0lterr'ff Mary Jane Snyder Real Estate Depu William T. Tully Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS TALITHA V MAY Sheriff's Return No. 2008-T-2638 OTHER COUNTY NO. 08-5725 CIVIL I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for TALITHA V MAY the DEFENDANT named in the within NOTICE & COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, DECEMBER 26, 2008. AS PER HERRY REIGEL, RESIDENT FOR 1 YEAR, DOES NOT KNOW DEFENDANT Sworn and subscribed to before me this 29TH day of December, 2008 e?o NOTARIAL SEAL JANE SNYDER, Notary Publi [ARY Highspire, Dauphin County Commission E Sept 1, 2010 So Answers, Sheriff of Dauphin County, Pa. By !5??"X__ =I ?L? Deputy Sheriff Deputy: S SCHAEFFER Sheriffs Costs: $47.25 12/24/2008 t ' t BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff v TELITHA V. MAY, Defendant Attorneys for Plaintiff Pennsylvania State Employees Credit Union OURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA ACTION - LAW 08-5725 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned action. BARLEY SNYDER LLC BY: awn M. Long, Esquir/byees Attorneys for Plaintiff Pennsylvania State Emp r edit Union Court I.D. No. 83774 126 East King Street Lancaster, PA 17602-2893 717-299-5201 2478174-1 4-V t `! t Y W 00 z SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-05725 P COMMONWEALTH-OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS MAY TALITHA V R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: MAY TALITHA V but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of WASHINGTON serve the within COMPLAINT & NOTICE County, Pennsylvania, to On March 9th , 2009 , this office was in receipt of the attached return from WASHINGTON Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Washington Co. 89.00 Postage .42 1GV .'IG 03/10/2009 BARLEY SNYDER Sworn and subscribe to before me this day of So answer _,__a R. Thomas Kline Sheriff of Cumberland County A. D. f7i, C%j Q- ? LL- O N WASHINGTON COUN*Y, PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 08-5725 CIVIL TERM COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAx 724-223-4719 Sheriff File Number - 09000404 County of WASHINGTON, Commonwealth of PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION vs TELITHA V. MAY Affidavit of Service COMPLAINT I hereby CERTIFY and RETURN that on 2/9/2009 at 3:OOPM service was attempted with the due diligence and inquiry for TELITHA V. MAY. Service was unable to be made for the following reasons: DEFENDANT DOES NOT LIVE AT THIS ADDRESS AS PER CURRENT RESIDENT. SERVICE ATTEMPTS Date: 2/9/2009 Time: 3:00 pm 1145 ROBINSON HIGHWAY McDONALD, PA 15057 Date: 2/9/2009 Time: 3:35 pm 233 BARR STREET MCDONALD, PA 15057 Date: 2/17/2009 Time: 2:20 pm 233 BARR STREET MCDONALD, PA 15057 Date: 2/19/2009 Time: 11:25 am 233 BARR STREET MCDONALD, PA 15057 Attorney Name: BARLEY SNYDER LLC, 126 EAST KING STREET, LANCASTER, PA 17602 Affirmed & Subscribed to before Me March 2, 2009 Notary Public NOTARIAL SEAL PAULETTE DANIELS, Notary Public My commission expires. Washington, Washington County, PA Re., nnmmicsinn Expires February 24, 2010 ROBERT LONICK, Deputy Sheriff of Washington County • .s WASHINGTON COUNIfY, PENNSYLVANIA OFFICE OF ThE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 08-5725 CIVIL TERM COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAx 724-223-4719 Sheriff File Number - 09000404 County of WASHINGTON, Commonwealth of PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION vs TELITHA V. MAY Affidavit of Service COMPLAINT I hereby CERTIFY and RETURN that on 2/19/2009 at 11:25AM service was attempted with the due diligence and inquiry for TELITHA V. MAY. Service was unable to be made for the following reasons: NO ANSWER. LEFT NOTICES. SERVICE ATTEMPTS Date: 2/9/2009 Time: 3:00 pm 1145 ROBINSON HIGHWAY McDONALD, PA 15057 Date: 2/9/2009 Time: 3:35 pm 233 BARR STREET MCDONALD, PA 15057 Date: 2/17/2009 Time: 2:20 pm 233 BARR STREET MCDONALD, PA 15057 Date: 2/19/2009 Time: 11:25 am 233 BARR STREET MCDONALD, PA 15057 Fees Received from Attorney: N. E. I. ($5.00), MILEAGE ($59.40), POSTAGE ($1.00), FIRST DEFENDANT BASE COST ($24.50) Total Charges $89.90 Attorney Name: BARLEY SNYDER LLC, 126 EAST KING STREET, LANCASTER, PA 17602 Affirmed & Subscribed to before Me March 3, 2009 Notary Public NOTARIAL SE PAULETTE DANIELS, Notary Public Washington, Washington County, PA My commission expires: My Commission Expires February 24,201 ROBERT LONICK, Deputy Sheriff Clirrua,? ? ?GYrta.r? o of Washington County s 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. TELITHA V. MAY, Defendant T OF COMMON PLEAS OF tERLAND COUNTY, PENNSYLVANIA ACTION - LAW o. 08-05725 Civil Term MOTION OF PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT PA&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: On September 26, 2008, the Plaintiff filed its Complaint against the Defendant. 2. The Sheriff of Cumberland County, Pennsylvania has returned the Return of Service to Plaintiff indicating "Not Found" at 616 Erford Road, Camp Hill, Pennsylvania as to 2546642-1 the Defendant. A true and correct copy of the Return of Service for the Defendant is attached hereto, made a part hereof and marked Exhibit "A". 3. Plaintiff's counsel prepared and mailed a Change of Address Request form to the Camp Hill Post Office for the Defendant. 4. The response to the Change of Address Request from the Camp Hill Post Office indicates "Forward" for the Defendant at 616 Erford Road, Camp Hill, Pennsylvania 17011, but no forwarding address is provided. A true and correct copy of the response to the Change of Address Request is attached hereto, made a part hereof and marked Exhibit "B". Plaintiff's counsel prepared a Zaba search on Zabasearch.com. 6. The Zaba search indicates an address at 1145 Robinson Highway, McDonald, Pennsylvania 15057. A true and correct copy of the Zaba search is attached hereto, made a part hereof and marked Exhibit "C". 7. Plaintiff's counsel also prepared a US Search on USSearch.com. 8. The US Search indicates addresses of 57 Manny Drive, Middletown, Pennsylvania 17057, 1153 Robinson Highway, McDonald, Pennsylvania 15057, and 233 Barr Street, McDonald, Pennsylvania 15057. A true and correct copy of the US Search is attached hereto, made a part hereof and marked Exhibit "D". 9. Plaintiff's counsel filed a Praecipe to Reinstate Complaint on December 19, 2008. 10. Plaintiff's counsel provided the Sheriff's office with the address of 57 Manny Drive, Middletown, Dauphin County, Pennsylvania ("Dauphin County Address") for service. 11. The Sheriff of Cumberland County has returned the Return of Service to Plaintiff indicating "Not Found" at the Dauphin County Address. A true and correct copy of the Return of Service for the Defendant is attached hereto, made a part hereof and marked Exhibit "E". 12. Plaintiff's counsel prepared and mailed a Change of Address Request form to the Middletown Post Office for the Defendant. 2546642-1 WHEREFORE, the Plaintiff, Pennsylvania State Employees Credit Union, prays your Honorable Court to enter an Order authorizing service of process, default notice, and writ of execution notices, if necessary, in the within matter upon the Defendant, Telitha V. May, by publication in accordance with Pa. R.C.P. 430(b)(1). BARLEY BY: ShOn M. Long, Esqu Attorneys for Plaintif Pennsylvania State Employees Credit Union Court I.D. No. 83774 126 East King Street Lancaster, PA 17602-2893 717-299-5201 2546642-1 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-05725 P 'COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS MAY TALITHA V 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 MAY TALITHA V but was unable to locate Her in his bailiwick COMPLAINT & NOTICE , He therefore returns the the within named DEFENDANT MAY TALITHA V NOT FOUND , as to 616 ERFORD ROAD CAMP HILL, PA 17011 PER CURRENT RESIDENT, DEFENDANT MOVED TO PERRY COUNTY. Sheriff's Costs: Docketing Service Not Found Surcharge So answers: 18.00 15.00 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 48.00 BARLEY SNYDER 10/07/2008 Sworn and Subscribed to before me this day of A. D. E)GW A 501 Washington Street P.O. Box 942 Reading, PA 19603-0942 Tel 610.376.6651 Fax 610.376.5243 www.barleycom October 13, 2008 To: Postmaster U. S. Postal Service Camp Hill, PA 17011 .rsJx :lam Colleen Brelje, Paralegal Direct Dial Number: 610.898.7166 E-mail: cbrelje@barley.com REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION 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) Telitha V. May Last Known Address 616 Erford Road City, State, ZIP Code Camp Hill, PA 17011 The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii): 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney. 2. The names of all known parties to the litigation: Pennsylvania State Employees Credit Union vs. Talitha V. May. 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: 2008-05725 P. 5. The capacity in which the customer is to be served (e.g., defendant or witness): Defendant, Talitha V. Mav Reading • York • Lancaster • Harrisburg • Berwyn • Hanover .!4"t 1,11 " Postmaster October 13, 2008 Pages 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. Colleen Brelje, Paralegal Printed Name Barley Snyder LLC Address 501 Washintton Street Address Readine, PA 19603 City, State, ZIP Code FOR POST OFFICE USE ONLY 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. rq 1z u1141?) - .= Al ?J 2423252-1 ZabaSearch Maps rage i or i ZABASEARCH Maps Poweredr,to by ?j? © 2008 ZABA Inc. http://www.zabasearch.com/maps/?snamel=TELIT?HAA/* 0V%20MAY&sname=TELITH... 11/7/2008 ++?jN e TELITHA V MAY More info Record Created: 0712001 1145 ROBINSON HWY Google Images News Video MC DONALD, PA 15057 Complete Report on TELITHA V MAY US Search - Search Results rage I or i Member Services Member Center Order History Account Information Customer Service S SLARCH 8E tfiF0RMED US SEARCH - the information you need to make sound life decisions - for you, your family, your home, Below are the results of your completed search. If you have any questions regarding your search, click here or email us. # Name Age Address Phone # More Info 1 TELITHA V MAY 57 MANNY DR MIDDLETOWN I PA 17057 5520 2 TEL.ITHA_V MAY 1153 ROBINSON HWY MC DONALD PA 15057 2023 3 TELITHA MAY 233 BARR ST MC DONALD PA 15057 1415 Thank you for choosing US Search as your trusted information provider! Please click here to view our Terms of Use. Home People Search Directory All Products Affili a Contact Us FAO's Privacy Terms of Use Links Blaa Care, VUS SEARCH.com 2001-2008 All Rights Reserved https://www.ussearch.com/consumer/ecustomer/viewresult.doxjsessionid=Z 15B2zZrg6nG... 12/15/2008 Ea W&T, 1) SHERIFF'S RETURN - OUT Or' C.:UUNTY CASE NO: 2008-05725 P • COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS MAY TALITHA V R. Thomas Kline .Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: MAY TALITHA V but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 30th , 2008 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin County 47.25 Postage 1.85 86.10 12/30/2008 BARLEY SNYDER Sworn and subscribe to before me this day of A. D. So answer Thom-a--s- Itl j e Sheriff of,-Cumberland County NW, E In The Court of'Common Pleas of. Cumberland County, Pennsylvania Pennsylvania State Fhlployees Credit union vs. Talitha V. May No. 08-5725 civil Now, December 22, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, , 20 at o'clock M. served the within upon at by handing to a and made known to copy of the original the contents thereof. So answers, Sheriff of Sworn and subscribed before me this day of , 20 COSTS SERVICE $ MILEAGE AFFIDAVIT County, PA MarR x,J Ean state e Depnuly William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick sheriff Commonwealth of Pennsylvania County of Dauphin PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS TALITHA V MAY Sheriffs Return No. 2008-T-2638 OTHER COUNTY NO. 08-5725 CIVIL I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for TALI THA V MAY the DEFENDANT named in the within NOTICE & COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, DECEMBER 26, 2008. AS PER HERRY REIGEL, RESIDENT FOR 1 YEAR, DOES NOT KNOW DEFENDANT So Answers, Sworn and subscribed to before me this 29TH day of December, 2008 A2?? NOTARIAL SEAL Y JANE SNYDER, NotaryPubli Highspire, Dauphin County M Commission Fimires Sept 1, 2010 Sheriff of Dauphin County, Pa. By Ina-A Deputy Sheriff Deputy: S SCHAEFFER Sheriffs Costs: $47.25 12/24/2008 501 Washington Street P.O. Box 942 Reading, PA 19603-0942 Tel 610.376.6651 Fax 610.376.5243 www.barley.com January 6, 2009 To: Postmaster U. S. Postal Service Middletown, PA 17057 REQUEST FOR CHANGE OF ADDRESS OR B.OXHOLDER INFORMATION Colleen Brelje, Paralegal Direct Dial Number: 610.898.7166 E-mail: cbrelje@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) Telitha V. May Last Known Address 57 Manny Drive City, State, ZIP Code Middletown PA 17057 The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii): 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney. 2. The names of all known parties to the litigation: Pennsylvania State Employees Credit Union vs. Telitha V. May. 3. The court in which th'e 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: 2008-5725 Civil. 5. The capacity in which the customer is to be served (e.g., defendant or witness): Defendant, Telitha V. May Reading • York • Lancaster • Harrisburg • Berwyn • Hanover 0 Postmaster January 6, 2009 Pages 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. Signature U Colleen Brelje, Paralegal Printed Name Barley Snyder LLC Address 501 Washington Street Address Reading, PA 19603 City, State, ZIP Code FORWARD: Name Street Address City, State, ZIP Code No change of address on file. Postmark _ Not known at address given Moved, left no forwarding address. No such address. iETQWN 9 JAN 00 ?.oo 2423252-1? I7??r?1 FOR POST OFFICE USE ONLY 13. The response to the Change of Address Request from the Middletown Post Office indicates "Moved, left no forwarding address" for the Defendant at the Dauphin County Address. A true and correct copy of the response to the Change of Address Request is attached hereto, made a part hereof and marked Exhibit "F". 14. Plaintiff's counsel filed another Praecipe to Reinstate Complaint on January 22, 2009. 15. Plaintiff's counsel provided the Sheriff's office with the addresses of 1145 Robinson Highway, McDonald, Washington County, Pennsylvania, 1153 Robinson Highway, McDonald, Washington County, Pennsylvania, and 233 Barr Street, McDonald, Washington County, Pennsylvania ("Washington County Addresses") for service. 16. The Sheriff's office of Washington County has informed Plaintiff's counsel that no service has been made on Defendant. A true and correct copy of the Return of Service for the Defendant is attached hereto, made a part hereof and marked Exhibit "G". 17. Plaintiff believes and therefore avers that the reasonable method, under the circumstances, is to serve all pleadings, including service of process, default' notice, and writ of execution notices upon the Defendant, Telitha V. May, if necessary, by publication. 18. The Plaintiff will suffer irreparable harm and injury if the Plaintiff is not allowed to effect alternate service of the process, default notice, and writ of execution notices, if necessary, upon the Defendant, Telitha V. May, by publication, under Pa.R.C.P.430. 19. Judge Kevin A. Hess entered an Order dated December 9, 2008 correcting the spelling of Defendant's name and amending the caption. 20. No opposing counsel has entered his or her appearance in this case, and, therefore, the Plaintiff has not sought concurrence. 2546642-1 CASE NO: 2008-05725 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIA STATE EMPLOYEES VS MAY TALITHA V R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENnANT MAY TALITHA V to wit: but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of WASHINGTON serve the within COMPT,ATNT L NIPTOV County, Pennsylvania, to On March 9th , 2009 , this office was in receipt of the attached return from WASHINGTON Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Washington Co. 89.00 Postage 42 126.42 03/10/2009 BARLEY SNYDER Sworn and subscribe to before me this day of So answer R. Thomas Kline Sheriff of Cumberland County A.D. AM, (; WASHINGTON COUN1 Yr PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 08-5725 CM L TERM COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAx 724-223-4719 Sheriff File Number - 09000404 County of WASHINGTON, Commonwealth of PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS. TELITHA V. MAY Affidavit of Service COMPLAINT I hereby CERTIFY and RETURN that on 2/9/2009 at 3:OOPM service was attempted with the due diligence and inquiry for TELITHA V. MAY. Service was unable to be made for the following reasons: DEFENDANT DOES NOT LIVE AT THIS ADDRESS AS PER CURRENT RESIDENT. SERVICE ATTEMPTS Date: 2/92009 Tune: 3:00 pm 1145 ROBINSON HIGHWAY McDONALD, PA 15057 Date: 2/92009 Time: 3:35 pm 233 BARR STREET MCDONALD, PA 15057 Date: 2/172009 Time: 2:20 pm 233 BARR STREET MCDONALD, PA 15057 Date: V192009 Time: 11:25 am 233 BARR STREET MCDONALD, PA 15057 Attorney Name: BARLEY SNYDER LLC, 126 EAST KING STREET, LANCASTER, PA 17602 Affirmed & Subscribed to before Me March 2, 2009 Notary Public NOTARIAL SEAL. PAU' EE'+ TE DANIELS, Notary Pubiic My commission expires WasP?irrgton, Washington County, PA IJiv f'r,mmEcCinn Exeire.zFebruary 24. 2010 ROBERT LONICK, Deputy Sheriff of Washington County :, P(S WASHINGTON COUNTY, PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. R OMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 08-5725 CIVIL TERM COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 Fax 724-223-4719 Sheriff File Number - 09000404 County of WASHINGTON, Commonwealth of PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS. TELITHA V. MAY Affidavit of Service. COMPLAINT I hereby CERTIFY and RETURN that on 2/19/2009 at 11:25AM service was attempted with the due diligence and inquiry for TELTTHA V. MAY. Service was unable to be made for the following reasons: NO ANSWER LEFT NOTICES. SERVICE ATTEMPTS Date: 2/942009 Time: 3:00 pm 1145 ROBINSON HIGHWAY McDONALD, PA 15057 Date: 2/92009 Time: 3:35 pm 233 BARR STREET MCDONALD, PA 15057 Date: 2/172009 Time: 2:20 pm 233 BARR STREET MCDONALD, PA 15057 Date: 2/192009 Time: 11:25 am 233 BARR STREET MCDONALD, PA 15057 Fees Received from Attorney: N. E. I. ($5.00), MILEAGE ($59.40), POSTAGE ($1.00), FIRST DEFENDANT BASE COST ($24.50) Total Charges $89.90 Attorney Name: BARLEY SNYDER LLC, 126 EAST KING STREET, LANCASTER, PA 17602 Vffrmed & Subscribed to before 4e March 3, 2009 , / . 77e-' i Z' U . ROBERT LONICK, Deputy Sheriff Notary Public PAULETTE DANIELS, Notary Public Washington. Washington County, PA commission expires: ply Commission Expires February 24, 2( GZm-cc?.? Q? ?Orre?.r+ o of Washington County At' Irj,:. F z... ?? r- ?? ': San, s?7 _Tr _? - `-? 1 „? ,' _.. ,: ti:,: °t ? MAM C 0 200A y 1 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. TELITHA V. MAY, T OF COMMON PLEAS OF IERLAND COUNTY, PENNSYLVANIA ACTION - LAW o. 08-05725 Civil Term Defendant ORDER AND NOW, to wit, this 23'Jday of alc-k , 2009, upon consideration of the Motion of Pennsylvania State Employees Credit Union for a Special Order of Court authorizing service of process, default notice, and writ of execution notices, if necessary, upon the Defendant, Telitha V. May, by publication in accordance with Pa.R.C.P. 430 and the Court having made a determination that sufficient evidence of concealment has been presented, and that the Plaintiff has made a good faith effort to locate the Defendant to the degree necessary to justify service by publication in accordance with said Rule, it is ORDERED that service of process, default notice, and writ of execution notices, if necessary, by publication in accordance with Pa. R.C.P. 430(b)(1) is hereby authorized, and Plaintiff, upon effecting service in accordance with said Rule, shall file a Certificate of Service with the Office of the Prothonotary of Cumberland County, Pennsylvania. / 2546642-1 :.? J4C1Y.?r, , ,r t ' ?t 3H! 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. TELITHA V. MAY, Defendant URT OF COMMON PLEAS OF MBERLAND COUNTY, PENNSYLVANIA IIL ACTION - LAW o. 08-5725 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned action. BY: BARLEY SNYDER LLC ?Kawn M. Lon/aa't uire Attorneys for Pff Pennsyl vania S mployees Credit Union Court I.D. No. 83774 126 East King Street Lancaster, PA 17602-2893 717-299-520'1 2565767-1 ALED-OffrCE OF THE PROTHONOTARY 2089 APP -8 P 1: 00 PFNI,ISYLVANIA $10• oo PO A'MY Cx.' ('S rte` aa?y c?4 Sheriffs Office of Cumberland County R Thomas Kline IV st Cutnbrr/ D Edward L Schorpp Sheriff Solicitor "A Ronny R Anderson Jody S Smith Chief Deputy OFFCE C T4E S"ERiFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/13/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Talitha V. May, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Perry County, PA to serve the within Complaint and Notice according to law. 04/17/2009 Perry County Return: And now April 17, 20091, Carl E. Nace, Sheriff of Perry County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint, upon the within named defendant, to wit: Talitha V. May by making known unto herself personally, defendant at 29 Oak Lane Shermans Dale, Perry County, Pennsylvania 17090 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.42 April 21, 2009 2008-5725 Pennsylvania State Employees Credit Union VS Telitha V. May SO ANSWERS, R THOMAS KLINE, SHERIFF FILE04,"I-F iCE OF 114' PPC'-0,N!0'FAPY 2009 APR 27 AM It : 35 CUM, rIr BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Defendant PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. TELITHA V. MAY, Attorneys for Plaintiff Pennsylvania State Employees Credit Union T OF COMMON PLEAS OF ffiRLAND COUNTY, PENNSYLVANIA ACTION - LAW 08-05725 Civil Term PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Telitha V. May for want of an answer in the amount of $8,347.44 plus 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. 2624227-1 " (X) Pursuant to Pa. R.C.F. 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. BARLEY SNYDER LLC Date: 4?rloj Shawn M. Long, Es re Attorneys for Plai ff Pennsylvania Sta a Employees Credit Union Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 NOW, i U.t1E /o'l 4 , 2009, JUDGMENT IS ENTERED AS ABOVE. Prothonotary/Clerk, Civil Division By: /l/if A. 2624227-1 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. TELITHA V. MAY, Defendant OURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA IVIL ACTION - LAW 08-05725 Civil Term To: Telitha V. May Date of Notice: May 19, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. 2607439-! 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 St. Carlisle, PA 17013 Telephone: (717) 249-3166 or (800) 990-9108 BARLEY SNYDER LLC By: &0" V Shawn M. Long, Esquire George J. Shoop, Esquire Attorneys for Plaintiff Pennsylvania State Employees Credit Union Court I.D. No. 83774; Court I.D. No. 25367 126 E. King Street Lancaster, PA 17603 717.299.5201 2607439-1 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. TELITHA V. MAY, Defendant OURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA IVIL ACTION - LAW o. 08-05725 Civil Term PROOF OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF BERKS ss. Colleen Brelje, Paralegal, being sworn according to law, deposes and says that she served a true and correct copy of the 10-day Default Notice upon Telitha V. May, 29 Oak Lane, Shermans Dale, PA 17090, by regular mail on May 19, 2009 at 5:00 p.m. BARLEY SNYDER LLC By: t . Ut'j V,-Q ? Colleen Brelje, Paralegal Sworn to and subscribed before me 50 North Fifth Street this 9A day of , 2009 P.O. Box 942 Reading, PA 19603-0942 C d-zle ? (610) 376-6651 o y Public CONMAONV'TH OF PENNSYLWANW Not&rw seal public Margaret C. EdwardsSoft Coufdy . NoLurch tary City o1 Reading. 2013 My Commission AMA of Nsfb?bs Member. 2607439-i 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. TELITHA V. MAY, Defendant URT OF COMMON PLEAS OF ERLAND COUNTY, PENNSYLVANIA ACTION - LAW o. 08-05725 Civil Term AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE, PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 LANCASTER COUNTY, SS: Before me, the undersigned authority, personally appeared Shawn M. Long, Esquire, who being duly sworn according to law, doth depose and say that Telitha V. May, 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 29 Oak Lane, Shermans Dale, PA 17090 as of the date of this affidavit. 2624227-1 > .f ?y ADDITIONAL FACTS, if any. Date: ?0 By: BARLEY SNYDER LLC , awn M. Long, Esquire Attorneys for Plaintiff Pennsylvania State Empl Court ED. No. 83774 / Credit Union 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 Sworn and subscribed to before me this / day of V Uh , 2009. !?" I /' Notary Public COMMOWWALTH OF PEWVAM MoMrw sw CO MM M. DaeM, MW Public s Cily of L0=0W. Urm" And " OOM* w comm.Mw MemW PenMylWM AUO? Or MOM* 2624227-1 F11 El ?UFRCE OF TNc PRO,' =- 'NITAR'Y 2009 JUN 12 PH 12: 38 .* tq,oo Po KTvq ? ? ass IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OFFICE OF THE PROTHONOTARY CARLISLE, PA TO: Telitha V. May 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 to No. 08-05725 Civil Term with the Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the amount of $8,347.44 plus costs of suit. 4?ROTHO *TAY By: Deputy Clerk 2624227-1 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 2009-CV-219-CV r 201'1 APR 23 PM • 2 I CUPOERL ND COUNTY PENNS YL VA NIA ) Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, V. TELITHA V. MAY, Plaintiff Defendant OURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA NIL ACTION — LAW Revival No. 2014-364 Judgment entered on June 12, 2009 No. 08-05725 Civil PRAECIPE Kindly mark the above-captioned matter settled, discontinued and ended, with costs paid, without prejudice and judgment as satisfied. By: 4282222_1 BARLEY SNYDER %hawn M. Long, Es ire Court ID. No. 8377 Attorneys for Plaintiff Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602 (717) 299-5201