HomeMy WebLinkAbout09-0440
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
BRADLEY M. BRYAN
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
NO.. ()q q 40 01V-11 Iefk
: CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
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 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 for any money
claimed in the Complaint or for any other claims or relief requested by the Plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o
sus objectiones a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070
MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.: O q- 4 L4 o CXL;J R.t,
BRADLEY M. BRYAN
DEFENDANT : CIVIL ACTION-LAW
COMPLAINT
AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1
Plaintiff, Members 1St Federal Credit Union (sometimes referred to hereinafter
as "Members 1st"), is a National Federal Credit Union having a principal
address of 5000 Louise Drive, Mechanicsburg, PA 17055.
2. Bradley M. Bryan ("Defendant"), is an adult individual having a last known
address of 62 South High Street, Newville, PA 17241.
COUNT I - HOME EQUITY LOAN
3. Paragraphs 1 and 2 are incorporated herein by reference as if set forth in full.
4. On or about June 4, 2007, Defendant borrowed from and agreed to repay to
Members 1 s' FIVE THOUSAND TWO HUNDRED FOUR AND 70/100
($5,204.70) dollars (the "Loan"). The Loan is evidenced by a Closed-End
Note, Disclosure, Loan and Security Agreement dated June 4, 2007 (the
"Note") executed and delivered to Members 1St by Defendant. A copy of the
Note is attached hereto as Exhibit "A" and made part hereof.
5. As security for the Loan, Defendant executed and delivered to Members 1St a
mortgage ("Mortgage") also dated June 4, 2007, on all that certain real estate
and improvements erected thereon situate in the Borough of Newville,
Cumberland County, Pennsylvania, known and numbered as 62 South High
Street, Newville, PA 17241 (the "Property").
6. The Note and the Mortgage have never been assigned by Members 1 st and
remain held by it as a valid and subsisting obligation of Defendant.
7. Pursuant to the terms and conditions of the Note, Defendant agreed to pay to
Members 1St bi-weekly installments of principal and interest in the amount of
2
at least $62.09 each, which amount was subsequently adjusted to $62.01 each,
beginning on July 13, 2007 and continuing every two (2) weeks thereafter.
8. Defendant is in default of Defendant's obligations under the Note as a result
of Defendant's failure to make the payments due to Plaintiff as set forth in the
Note and as more particularly set forth and described in the Act 91 Notice
attached hereto as Exhibit "B" and made part hereof.
9. Members 1St gave written notice of its intent to foreclose Pursuant to the Act
of January 30, 1974, P.L. 13, No. 6,41 P.S. section 101, et. seMC ., and in
particular section 403 thereof, and of Defendant's rights in accordance with
the Homeowners' Emergency Mortgage Assistance Act, Act of December 23,
1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. seg by letter dated
September 5, 2008, addressed to Defendant via certified mail, return receipt
requested. A copy of the said notice is attached hereto as Exhibit "B" and
made part hereof.
10. A copy of the electronic tracking confirmation evidencing the mailing of said
Notices is attached hereto as Exhibit "C" and made part hereof.
11. Simultaneously, Members 1St forwarded to Defendant the same Notices as set
forth in paragraph 9 above addressed to Defendant by United States mail, first
class, postage prepaid, bearing the return address of Members I. The Notices
forwarded to Defendant in said manner have not been returned to the offices
of Members 0 as undeliverable or otherwise.
12.
13.
14.
15.
As of January 27, 2009, Defendant is indebted to Members 0 in the amount
of FIVE THOUSAND FIVE HUNDRED THIRTY-FOUR and 00/100
($5,534.00) DOLLARS itemized as follows:
a. Outstanding principal $4,314.89
b. Interest to January 27, 2009 272.61
c. Late fees 46.50
d. Attorney fees 900.00
f. Total due to Members 1st as of 1/27/2009 $5,534.00
The above attorney's fees are estimated and are in accordance with
Defendant's agreements as set forth in the underlying Mortgage and Note.
Defendant will be responsible for actual reasonable legal fees incurred by
Members 1St in this matter subject to any limitation set forth in the Note.
Defendant also agreed under the terms and conditions of the Mortgage that in
the event of default there under Defendant would pay, in addition to the
amounts set forth in paragraph 12 above, costs incurred by Members 1St as a
result of the institution of these legal proceedings.
The obligation owed to Members 1St continues to accrue interest at the rate of
$1.2696 per day, through the date of payment and continues to accrue late
charges and attorney's fees as set forth in the Note.
As set forth above, Members 1 st has made demand upon Defendant to cure the
default under the Mortgage and the Note. However, as of the date hereof,
Defendant continues to fail and refuse to cure the default.
4
WHEREFORE, Plaintiff, Members 11, Federal Credit Union, demands
judgment against Bradley M. Bryan in the amount of FIVE THOUSAND
FIVE HUNDRED THIRTY-FOUR and 00/100 ($5,534.00) DOLLARS plus
interest at the rate of $1.2696 per day, through the date of judgment entered on
this complaint and at the legal rate thereafter until the date of payment,
additional legal fees and costs of suit.
COUNT II - UNSECURED LOAN
16. Paragraphs 1 through 15 are incorporated herein by reference as if set forth in
full.
17. On or about April 6, 2006, Defendant borrowed from and agreed to repay to
Members I" SIX THOUSAND TWO HUNDRED EIGHTY-FOUR AND
64/100 ($6,284.64) dollars (the "Loan"). The Loan is evidenced by a Closed-
End Note, Disclosure, Loan and Security Agreements dated April 6, 2006 (the
"Unsecured Note") executed and delivered to Members 1 S' by Defendant. A
copy of the Unsecured Note is attached hereto as Exhibit "D" and made part
hereof.
18. The Unsecured Note has never been assigned by Members 1 S' and is still held
by it as a valid and subsisting obligation of Defendant.
19. Pursuant to the terms and conditions of the Unsecured Note, Defendant agreed
to pay to Members 1" bi-weekly installments of principal and interest in the
amount of at least $63.65 each beginning on April 21, 2006 and continuing bi-
weekly thereafter.
5
20.
21.
22.
23
Defendant is in default of Defendant's obligations under the Unsecured Note
as a result of Defendant's failure to make the payments due to Plaintiff as set
forth in the Unsecured Note.
By letter dated December 26, 2008, addressed to Defendant, Members 1St
exercised its rights under the Unsecured Note and accelerated all amounts due
under the Unsecured Note and demanded the payment of all amounts due
under the Unsecured Note. A copy of Plaintiffs Demand is attached hereto as
Exhibit "B" and made part hereof.
As of January 27, 2009, Defendant is indebted to Members 1St in the amount
of FIVE THOUSAND THREE HUNDRED FIFTY AND 00/100 ($5,350.00)
DOLLARS itemized as follows:
a. Outstanding principal $4,102.05
b. Interest to January 27, 2009 350.25
c. Late fees 47.70
d. Attorney's fees 850.00*
e. Total due to Members 1 st as of January 27, 2009 $5,350.00
*Legal fees are estimated in accordance with the terms of the Unsecured Note.
Defendant will be responsible for the payment of the actual reasonable legal
fees incurred by Plaintiff subject to any limitation set forth in the Unsecured
Note.
Defendant also agreed under the terms and conditions of the Unsecured Note
that in the event of default there under Defendant would pay, in addition to the
6
amounts set forth in paragraph 22 above, costs incurred by Members 1St as a
result of the institution of these legal proceedings.
24. Interest continues to accrue on the above obligation at the rate of $1.2924 per
day.
25. As set forth above, Members 1 St has made demand upon Defendant to make
payment of all amounts due to Members 1St under the Unsecured Note and, as
of the date hereof, Defendant has failed and refused to make payment of all
such amounts due to Members 1St
WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands
judgment against Bradley M. Bryan in the amount of FIVE THOUSAND
THREE HUNDRED FIFTY AND 00/100 ($5,350.00) DOLLARS plus
interest at the rate of $1.2924 per day, through the date of judgment entered on
this complaint and at the legal rate thereafter until the date of payment,
additional legal fees and costs of suit.
COUNT III - VISA
26. Paragraphs 1 through 25 are incorporated herein by reference as of set forth in
full.
27. On or about November 15, 1997, Defendant submitted to Members 0 a credit
card application (the "Application") for a Visa credit card issued by Plaintiff.
28. Plaintiff accepted the Application and sent to Defendant a Visa Credit Card,
account #4121-4400-1170-1749 (the "Visa Account") and a Visa Credit Card
Agreement and Disclosure Statement.
7
29. The Visa Account is governed by the Visa Credit Card Agreement and
Disclosure Statement (the "Credit Card Agreement and Disclosure"), a copy
of which is attached hereto as Exhibit "F" and made part hereof.
30. Pursuant to the terms and conditions of the Credit Card Agreement and
Disclosure, Defendant agreed to pay to Plaintiff monthly installments in an
amount of not less than two percent (2.0%) of the outstanding balance on the
account or $20.00, whichever is greater.
31. Defendant has made charges against the Visa Account and is in default of
Defendant's obligations under the Credit Card Agreement and Disclosure and
the corresponding Visa Account as a result of Defendant's failure to make the
payments due to Plaintiff as set forth in the Credit Card Agreement and
Disclosure, the last payment having been received by Members 1 sc on or about
July 8, 2008.
32. By letter dated December 26, 2008, addressed to Defendant, Plaintiff
demanded the payment of all amounts due under the Credit Card Agreement
and Disclosure and the corresponding Visa Account. A copy of Plaintiff's
Demand is attached hereto as Exhibit "E" and made part hereof.
33. As of January 27, 2009, Defendant is indebted to Plaintiff in the amount of
SEVEN THOUSAND NINE HUNDRED TWENTY-EIGHT AND 98/100
($7,928.98) DOLLARS itemized as follows:
a. Principal
b. Legal Fees*
$6,128.98
1,800.00
e. Total due to Member 1" as of January 27, 2009 $7,928.98
8
*Legal fees are estimated in accordance with the terms and conditions set
forth in the Credit Card Agreement and Disclosure. Defendant will be
responsible for payment of actual, reasonable legal fees incurred by Members
1 st in this matter.
34. Defendant also agreed under the terms and conditions of the Credit Card
Agreement and Disclosure that in the event of default there under Defendant
would pay, in addition to the amounts set forth in paragraph 33 above,
additional reasonable legal fees, if any, and costs incurred by Plaintiff as a
result of the institution and prosecution of these legal proceedings.
35. Legal fees and costs continue to accrue on the above obligation as set forth in
the Credit Card Agreement and Disclosure through the date of payment and
including on and after entry of judgment on this complaint.
36. As set forth above, Plaintiff has made demand upon Defendant to make
payment of all amounts due to Plaintiff under the Visa Account and
corresponding Credit Card Agreement and Disclosure and, as of the date
hereof, Defendant has failed and refused to make payment of all such amounts
due to Plaintiff.
WHEREFORE, Plaintiff, Members I" Federal Credit Union, demands
judgment against Bradley M. Bryan in the amount of SEVEN THOUSAND
NINE HUNDRED TWENTY-EIGHT AND 98/100 ($7,928.98) DOLLARS
plus interest at the legal rate on and after entry of judgment hereon until the
9
date of payment, additional legal fees and costs of suit.
Date:
Supreme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
10
Respectfully submitted,
CLOSED-END NOTE, DISCLOS QAI Sf LD ADDRFFBORROV
NAM! AND ADDRESa
5000 LOUI6e Drive, P.O. Box 40 BRADrERLEY7 MBRYAN
Mechanicsburg, PA 17055 BRAD
e2 S HIGH ST
NJ uJrt. ''PA?2_t
ruraalnertlJar
FIXED
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed: The amount of Total of Payments: The amount
RATE: The cost or your credit as a The dollaf amount the Credit Will credit provided to you or on your you will have paid alter you have
yearly rate. ' coal you. behalf, made all payments as scheduled.
10.74 % • $ 1,251.50 • $ 5,2D4.7D e $ 6,456.29
Varfebit Rate: II your toss has a "debt, rate as indicated above ties Annual Percentage Rata may increase durixg
ties lam al Ihls trensactlen if the (Index) Changes. The
a.du mlon will edd a margin of to the Index value. The rate will change mouldy on the rust day of the month. The u will never bat higher tan the maximum role auovnd by
n
few, and a cold rwvu oe Cep roan Any interest rata Maria will resuk in mac payments of the same amount. For Example, It your loco was for $3,1100 et i5% for 40
months and the A-) Percentage Role Increased by 2% Mar one yea, Ih. Jim of yourloon would increase by two monns
PP Ierred R¦to: If dNQed, IM following applies to your loan:
USl Automatic rayment tNscounted Ralr. Be-- you nave speed to nneke your nquhd monpdy VaymenN through an automatic deduction from your CMCkInySaNnpa
AcwunI. your ANNUAL PERCENTAGE RATE has been discounted WOW The ANNUAL PERCENTAGE RATE disclosed above in the ANNUAL PERCENTAGE RATE box is
the ALAC"k Peymem 0lscounted Rate. This me will nasase by ,2 it you Cane t e oulanati , payment arrangement a fail to nrinlpn suHcient funds in your account to
cover the automatic payments. In such a coat, the affect of the increase will be to extend the Ism of your ban. Far example if your Automate Payment Discounted Rate is 10%
on o SS.000.00 ban fa 60 months and you coats ties oulomalc paymam errenlg."ni. yourrate will roue.- to 10.20%, resulting In I additional payment.
Variable Rate Preferred Loans. If yew loan is a variable rate loan and you quo&y for a Preferred role, your preferred discount Is taken at the lines you take out your ban. This
Initial Preferred ANNUAL PERCENTAGE RATE will then very accerdinp b changes in the Index (.s disclosed abow). Fa exernple, It a variable Into ban's Inlet ANNUAL
PERCENTAGE RATE Is 12% a the Ibn. you Me. IM ban, you Initial pretense ANNUAL PERCENTAGE RATE will be WAW Your initial preferred ANNUAL PERCENTAGE
RATE will than very according to the Index, u distdosed In the lredsbla Raw' previslon bow,
Fixed Rate Preferred Loans. If your ban Is a Reed rate Berl and you quality for a preferred rate, yaw ANNUAL PERCENTAGE RATE wM be the prolenad ANNUAL
PERCENTAGE RATE disclosed above fa ¦a land ate w Preferred s1aWs mains in offset.
Number of Payments Amount of Payments Payment Frequency When Payments Are Due Property Insurance: You may obtain
property
Yeur ,
Insurance from anyone you want that is acceptable to
peyrrenn 103 562.09 81-Weekly - Beginning 07113/2007 the credit union. If you pet the insurance from the
sd.w. Credit union you will pay
col a: 1 $61.02 Final Due - On 0612412011 i NIA
Security: CoRaMral securing other loans with the credit union ties goods or property GO
.if else pour. into loan. You ere giving • security interest in [7 band purchased. ? (Desaloe):
your aere$ and/or deposit in the vedit Mon
end: X
.
Late Ch¦rW: If a payment is left by to days or men you will Required Deposit Balance, The Annual Percentage Rate doer Filing Foos: Non-FRing Insurance:
be charged a Ab la of 3% of yaw scheduled payment. not take Into account your required deposit baWlu, if ary. S WA S WA
Mve'se yW pay a t ,you w s Prey • par
Y-mega eaNpN. t geld m 1 JMsay a Mapymeu. W 1y neur tipsy- n
er Iall .a ll 4l0 prgePN Ie5. end p"Siu.
AMOUNT FINANCED $ 5,204.70 Amount Paid to others on your behalf (Describe)
AMOUNT GIVEN TO YOU DIRECTLY S 5,000.00 $ooo To Mi.- Lka S To
$2on.To To Mrnewl. LW S To
AMOUNT PAID ON YOUR ACCOUNTS S To $ To
S TO
0.00
To
PREPAID FINANCE CHARGE
$ 0.00 $4.00 To Aura sokNan. $000 To "id saNhbm
OTHER (Describe): e2 S HIGH ST
and/or Deposits of I S I I S
Yw apse that the leans and Conditions In Inc d12CJ0sun statement end the ban err security agmernerus located on page 2 of Ws dowmanl shot apply b this loan. II there is more
IMn oM borrower, wo sgne that al the coadtions of the ban and security psements goveming We ban slat apply to both laurel, end ...'ally. You acknowledge th.l you have
recetwd a copy of the ban and security agreements and disclosure slakyme tl. Cosigner: N you ate slonind as eo-signer, you acknowledge receipt of the nonce to co-signer
Contain on page 2.
BORRp/V/¢R'S AT DATE CO-MAKER -OTHER OWNER -CO-SIGNER DATE
x ?1.SI ? (SEAL} X (SEAL)
Q CO-MAK C] -OTHER OWNER 0 -COSIGNER DATE ? CO-MAKER [] -OTHER OWNER O -CO-SIGNER DATE
X (SEAL) X (SEAL)
CO-MAKER O .OTHER OWNER ? -COSIGNER DATE C] CO-MAKER 0 'OTHER OWNER 0 -CO-SIGNER DATE
X (SEAL) X (SEAL)
a OMNNA Aq wooswM?•seese ?1NMss/.,wanrIcedrer new wrM rer,rr ebn ratTM aprr orrr, ewlr M••aewwaw,b Ina oYyrr rnWwa.r,rmxrnlxr her
e.a.rw aw a •aargr I,rl,r•M r IM wsrwwsa.lar.elorr. a•..W Mr..ro. -COaaarn uran Cars, r...dn w..,.n ewes kwsr ew.w tat, w. s..r.,lar w err w.s.ww w,. a. u. r.,. rh.
aw..,rr..H.. all wow rrrrrM r N. w•Wrrwr. e.•nrlr Mew.
CREDIT
.Si cow , r 1-1 m•y wnnme . m wry Nrre. ? (cost unpnran. elan R per ee 0.- n telwled, we
mug p
leMn N+ha/ Yid Indvlduefy laola
WanNaa Yes Ina spell Mx NlsenMw
Th• ra .101 rat ban, and lost caapnrs T CO-Ap ICAM
t?g
g glwetena, t end !. must be anawered se darnMne any (*.I Stalbillry/erbeur.na.: 1+ _? s D Y O
1. IApaiaae IS ill Inunnce cawnago only) will you be sneer ago 7a on err jol"Nd rp.xar err of your
ben? +
3. IApplifaa. r d..b&w canna. _111 tall you b ..tire" 70..
Ina egNea.e rNlum/ YN sl year tow ANp en pnssnsy wertkp L ? ? El
Isirr Your hYre 11 cogs 1 "N 11101-1 or men pr w..k W Mn M.n so wAYq Ir ]t day, 1 mar. giro n,. d.rT N
In call nMnnppl your Icon •rtaar i?lyswpp0,ao IM apeewna w..u.n -11 cos w ..-.d n .,do,
IS anrlwlM 1gr0uy.
]. cmweY AeprwW Nm4n, Wrwn YtAI gAndapr Ise fprrrpN IARC17Ma<k sr clanary Mary dbpaa. lbpke. ? ? ? ?
"Voull ula..n le n. abwq aeoM an ou. to lMMlslrNlOt R.hrOC r?'Ianw .,
br inaWal nu up b .n •emeuN Ml eael.•dng S l: annd lMl Nb Canon /not .XpaY la wnnp red
dI Ml be nrxod. II w/ W ppYN W I - Y.s' b wppp 7?? k d.nl?sa N wN?.n W.
TM .a•tlna br a fry level naunw coal M IM d1• el nr appNwlgn. AnY Mnen wM MawrelY .Ina .Nr Inh•m he Minced any naunM. eenpany er uMr p.non I4ae an applNaeon tar b.unrKa
l arurpnlacrkn canWnln Y.ny=mtolyfat nsi endtivenercenephlorr. pllryp I-wading, IMomWlbn aonamnp an ncl mNrMllMnlo eommllaa Cocoa I.nl w„nnc. act,
wnNn Is • cram. ant eub)eela • all p.n.s to anmIM and e1vN pasaba, Ds net slen IMe ypepdm t arty appllaaer apaaa.n 64nk Thlp ypllu0on will net W uwd In com.al H .S appllcaor
a•^" •Me•a h•w MI ern o.mprl.d. cow d.brer ha. raw lpmd ant dated IM applkulon and N IM app! celbn hw not b..n wireped.
CREDIT INSURANCE APPLIED FOR; NOTE: ONLY ONE APPLICANT MAY APPLY FOR DISABILITY COVERAGE.
? Yes Q No Single Credit Life Total Premium Q Yes ? N. Credit Oisabilty Total Premium
Yes - Q No Joint Credit Life
Indicate which epptCansay ? Apoh- ? C.Apptunl ; $ 0.00 Indicols 1A4cfh spptcaml.): X? Applicant ? C.ApPNUnt $ 204.70
Yau M Nuarade y11 ter NWs Ncewnta for xAxCs• dhYta r klreaW an err appisallm
APT ATURE DAT OF IRTH DATE CO-APPLICANT'S SIGNATURE DATE OF BIRTH DATE
X
DATE SEC ND Y BENEFICIARY (APPLICANT) SECONDARY BENEFICIARY (CO-APPLICANT)
MH p]Y.] A
MHG111`420077LASER-vWROF. 43762R.v Intl -'--- - ---------
_ __. _ _ ?panra, wc. Al /gnu n4Nrv.a.
Exhibit "A"
6011110 's NAM9 LOAN NUMBER ACCOUNT NUMBER SMTE Or LOAN
BRADLEY M BRYAN 207355 17017403 Oe104R007
IWWEDSASABORROVYERS$ITHE WORDS "CREDIT UNION- MEANS MEMBERS 1ST FEDERAL CREDIT UNION. THE WORDS *YOU.' -YOUR" AND -YOURS- MEAN THOSE
LOAN AGREEMENT
Payments/Finance Charges: For value received. you promise to pay, at
the Credit Union's office, aU amounts due. AV Payments &hall be made
pursuant to the disclosure statement on Page 1 PoafYlhig document. You
of this docuumeetit us based on throe assumptionf rhat allinstallmment payments
will be made on the scheduled due dates, and , If you have %?ualified for
preferred rote that you continue to satisfthe yy the conditions of Thal referred
ate. If you fail to any inslatlmeM by time It is due, you vrPtl pay
additio nal interal on the overdue amount.
Allocation of Payments and Additional Payments: Payments and
credits shall be applied in the following order. any amounts past due; any
fees or charges owing, including any insurance premiums; accrued interest
or finance charges; outstanding principal. Payments made In addkton to
regularly scheduled payments shall be applied in the same order.
Preferred Role: If you quo NT for a preferred rate as disclosed on ppalgqe t of
this document or in a separate preferred rate addendum, you underiteno
that you must meet the conditions disclosed to you in order to quarf? for the
preferred rate and must continue to meet those conditions in onlar o keep
your preferred rate. If you fail to meet those conditions, your rate will
Incre6se. Uureby extending the terms of your loan, You promise to continue
making payments and to meet all obliCatiOns under this Agreement even if
you no conger receive the preferred rate.
Late Charges: If ou make a late payment you agree to pay a late charge
It one Is disciosedyon page 1 of this documers.
Property Insurance: If you obtain a loan secured by a motor vehicle or
other tangible property, you must obtain insurance which protects the credit
union from financial toss. The amount and covers?a of the property
insurance must be acceptable to the credit union. Such a polity must
provide at least fire, then, combined additional coverages and collision
insurance. It must contain a Loss Payable clause endorsement naming the
credit union as ken holder. You may obtain this insurance from ant agent of
your choice and direct the agent to send the credit union a copy othe
policy
Debtor Responsibility; You promise to notify credit Union of any change in
your name, address of employment. You promise not to apply for a loan If
you know there is a reasonable probabtlity that you VAN be unable to repay
your obligation according to the !arms o11ha credit extension. You promise
o inform credit union of any new information which relates to your abdlry to
=your obligation. You promise not to submit false or inaccurate
IMarmallon or wilfully conceal Information regarding your creditworthiness,
credit standing, or credit capacity.
SECURITY AGREEMENT
I. To secure payment of this ban and nI expenditures Incumd by the credit
union In connection with this loan, 9r M realizing on a aacudqq InNrest, you
great to the credit union a seeurky Itntyyterest in the propaaN described on
all atitutions and adilUoes to till setunlli sppiinec udes • Increues,
Insunaco on U. secured property sad ore earn .9i'ricr.i-d frfrom
e y
secured properly,
Crws•cDyaNrallatlon: ProDarty vNor
es socunly for this loan or for any
tlsa loan eonowerChas with the five nl If secure ell amounts
?rurresrlne99rmacrieWr deer! wllltunof iecu?satlrkl Iola IfiucA prvrray 1i ropeny
Borrow•r1s principal nskonce (unless the pro r resclssn notices are
plvm and an oMer N ¦1 nqW rmnts •n sslPinetll. or an non•purchau
money household poo8a,
2. You wW rat change the location of. all or Innsf r the collateral uniess you have
tll• ur . union's mar wdaan Caesar
3. You warrant that you Mve Mood Due to as colialeral, free d 60 teatxily 1hI!raal
u DI n 1. Nq ensdil union and erupt la any imaest t; a non-ca
mater owIna! .0111. r f the lNlerN xM Ms s
plan igned Inc epreemoni m the irdioled
.
4. You will r1 all taxes, aswssm•nts, and Dens against or attached to Our property
destxbed , nd luraha agree le keep Ute property in pow condition, housed in a
suhabla shenu. V?oce •qrell b axeaN tans sbmcnls and secunry
dill
apr4emenl amemm?erasa da? union's request and wltl defend the properly
ap•val entrees DYwntl pea rry ma
pith
s, ciEllwil"ho IIMi s lewd4nWes1. Thrn?inaurano v?All MPn lorryimmsnu ? the
emotes Nlls o"Ory N w credit union, You w0 s p y Wa aadN union with proof
ed ktaursnp umd ¦ sums it lq vW1i cetic SnaA mtwa and aSWfed ey tills
prso j re r} ad 11 you Nk to mantnn anu, wdll union may out
a reel ri Wkeo ?o, ODlaln Insunnu of our own and Wd me u{I of Writ to the
sums owe0. TMs cost vNl Los r erest el Nor contract rata unsl paid. You lunnar
assign beta -dk lnlorl livCed to revive Nf procaedit of my inwronu on
auto p(yopary, srW died airy eta- to pery ease proceeaa arsWV b credit
upon. You wAhpdalIfr the aedil union to entlona •rw dterk a dint/ provbetl a3
Iha pop udnU, sudh Insurenu. and a19ppM as procesds ID Iha fYmi Owed 10
Y% =,
t en uiuap, union le, provide girur Sitar.. I-c.,
va _.=ry IMOnnieontroi waflcivoo nuof aC r Insunncs service Cenlsr
iquaN -.,age.
You • led s inauann or my, extension thereof placed b
union Is w lad e, the' el to you irdividwy bus is OdmaNy for the onleclion of the
credit union Y the oedit
.
s. Should the 00ndil union lea at any time chat as seventy pesemtd has
dimidshed In valve, Or for any naspn tea that addD'ghet searkY, is nequind, you
apse 10 asalp to cretin union wiNm Ian (10) days whatever adOkbnei tewn(y
Iha lyede union feel i$ neeeuary ice protect the credit union against possible
loss.
7.
Statutory Lien: If you ore In default, federal law gives the credit union the
ripht.lo apple the balance of shares and/or dividends in our account
(s1 at
the time bl default to saUalyy this ban. Once you are In dyefaull, the ered'If
union may exercise Ws fiDltt without lurlher notice to you.
Datay In Enforcement: Credit Union may delay enforcing any of the credit
umor Ilahta trader this
anrwomwnt r.,:rAn„f i...c.... •r?...
Irregular Payments: The credit union may accepl late payments or partial
payments, oven thouoh marked "payment In fun, without losing any of the
credit union rights uncle this agreement.
Co-makers: If you are signing this agreement as a co-maker, you agree to
be equally responsible wt h the borrower, but me credit union may sue
either or both of you. The credit union does not have to notify you that IMs
agreement has not been paid. The credit union may extend the terms of
payment and release any security without notifying or releasing you from
responsibility on this agreement.
contractual pledge of Shares: You pledge all your shams and it its In the
credit union. Including future addltions, as security for this loan In use yov
defaulL the credit union mey apply these shares sad deposits to the payment
of all sums duo at the time of default, Including costs of collection end
reasonable attorney's Ises, that the credit union may incur, up to 20% of the
paid principal and Interest No lion or right to Impress a thin an shams and
deposits shall apply to any of your ahaes which may be held In an -Individual
Rotlnment Account" of "Keogh Plan..'
S 100 2199
NOTICE TO CO-SIGNER You are being asked touaranles this debt Think carefully before you do. If the borrower doesn't pay the debt you will have to. Be sure you can afford to
pay It you have to, and tRat you want to accept this responsibility.
You may have to pay up to the lull amount of lee debt it the borrower does not pay. You may also have to pay late fees or collection costs, vvhirh increase this
amount.
The creditor can tolled this debt from you without first trying to collect from the borrower. The creditor an use the same collection methods against you that
can be used epainsl the borrower, such as suing you, garnish 'mg your wages, etc. If this debt l ever In default, that fad may become a part or your credit
record. This notice is not the eontred that makes you liable for the debt.
F. 43759 1/02
APPRO sy,tene, aa.. 224•10Te
Page 2 of 2
unpx anon ts Oy eepppolnlenecYd as aur Altomsyyes-Fad to ptriorm anY
ads vdtidt N• credl unon Nds as aC F Wt al
Da
Beady In terest Which this apnamaM cru ucesay to li the nl and
q saes is more loan one Dot r, your Ipailory utsnrddeer this agr•smeni are
I as!vra. cad Dien • ai nsDD n We to hAeq Da lama of W s
This scanty pnamenl not only binds you, but your executors. adminisustom.
noire, sad esssgns.
Date: September 5, 2008
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE*
This is an official notice that the mortgage on your home is in default, and the
lender intends to foreclose. Specific information about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE.
Take this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have any
questions, you may call the Pennsylvania Housing Finance Agency toll free at
1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869).
Exhibit "B"
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help
explain it. You may also want to contact an attorney in your area. The local bar
association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA, SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.
PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
BRADLEY M BRYAN
62 S HIGH ST
NEWVILLE, PA 17241
170174 - 03
Members 1st Federal Credit Union
Members 18t Federal Credit Union
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU
MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN
CAUSED BY
CIRCUMSTANCES BEYOND
YOUR CONTROL,
IF YOU HAVE A REASONABLE
PROSPECT OF BEING ABLE
TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER
ELIGIBILITY REQUIREMENTS
ESTABLISHED BY THE
PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a
temporary stay of foreclosure on your mortgage for thirty (30) days from the date
of this Notice. During that time you must arrange and attend a "face-to-face"
meeting with one of the consumer credit counseling agencies listed at the end of
this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF
YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU
MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TNic n1nT1r`9:
CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW
TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the
consumer credit counseling agency listed at the end of this notice, the lender
may NOT take action against you for thirty (30) days after the date of this
meeting. The names, addresses and telephone numbers of designated
consumer credit counseling agencies for the county in which the property is
located are set forth at the end of this Notice. It is only necessary to schedule
one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for specific
information about the nature of your default.) If you have tried and are unable to
resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To
do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your
face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN
THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE
WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibility criteria
established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A
PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS
FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage
Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to
date).
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender
on your property located at: 62 S HIGH ST, NEWVILLE, PA 17241
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following bi-weekly installments and the
following amounts are now past due: $18.59 for 06-13-08, $62.01 for 06-27-08, $62.01 for 07-11-08,
$62.01 for 07-25-08, $62.01 for 08-08-08, $62.01 for 08-22-08 and $62.01 for 09-05-08.
Other charges (explain/itemize):
TOTAL AMOUNT PAST DUE: $390.65
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable):
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER, WHICH IS $390.65, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified
check or money order made payable and sent to:
Members 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA
17055, Attention: Dave Thomas
You can cure any other default by taking the following action within THIRTY (30)
DAYS of the date of this letter: (Do not use if not applicable.)
IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its
rights to accelerate the mortgage debt. This means that the entire outstanding
balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in Bi-Weekly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends
to instruct its attorneys to start legal action to foreclose upon your mortgaged
property, 62 S HIGH ST, NEWVILLE, PA 17241
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be
sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to
its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, if legal
proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount you owe the lender, which may also
include other reasonable costs. If you cure the default within the THIRTY (30)
DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have
not cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default and prevent
the sale at any time up to one hour before the Sheriffs Sale. You may do so by
paying the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and
any other costs connected with the Sheriffs Sale as specified in writing by the
lender and by performing any other requirements under the mortgage. Curing
your default in the manner set forth in this notice will restore your mortgage to the
same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest
date that such a Sheriffs Sale of the mortgaged property could be held would be
approximately Three(3) months from the date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may
find out at any time exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Members Is' Federal Credit Union
Address: 5000 Louise Drive, Mechanicsburg, PA 17055
Phone Number: (717) 795-5133 or (800) 283-2328 Ext 5133
Fax Number: (717) 795-5207
Contact Person: Dave Thomas
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end
your ownership of the mortgaged property and your right to occupy it. If you
continue to live in the property after the Sheriffs Sale, a lawsuit to remove you
and your furnishings and other belongings could be started by the lender at any
time.
ASSUMPTION OF MORTGAGE -- You may not sell or transfer your home to a
buyer or transferee who will assume the mortgage debt, provided that all the
outstanding payments, charges and attorney's fees and costs are paid prior to or
at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF
THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME
POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU
CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE
TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY
FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY
HAVE TO SUCH ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL
BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
Certified Mail # 9171082133393582999194
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated: 10/15/2007 10:03:08 AM
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Captlal Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565
Relief Act and Urban Development (exp 4/30/2007)
Notice Disclosure Office of Housing
Legal Rights and Protections Under the SCRA
Servicemembers on "active duty" or "active service," or a dependent of such a
servicemember may be entitled to certain legal protections and debt relief pursuant to the
Servicemembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA).
Who May Be Entitled to Legal Protections Under the SCRA?
Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard,
and active service National Guard;
Active service members of the commissioned corps of the National Oceanic and
Atmospheric Administration;
Active service members of the commissioned corps of the Public Health Service;
• United States citizens serving with the armed forces of a nation with which the United
States is allied in the prosecution of a war or military action; and
Their spouses.
What Le al Protections Are Servicemembers Entitled To Under the SCRA?
The SCRA states that a debt incurred by a servicemember, or servicemember and spouse
jointly, prior to entering military service shall not bear interest at a rate above 6 percent
during the period of military service.
The SCRA states that in a legal action to enforce a debt against real estate that is filed
during, or within 90 days after the servicemember's military service, a court may stop the
proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or
seizure of real estate shall not be valid if it occurs during, or within 90 days after the
servicemember's military service unless the creditor has obtained a court order approving
the sale, foreclosure, or seizure of the real estate.
The SCRA contains many other protections besides those applicable to home loans.
How Does A Servicemember or Dependent Request Relief Under the SCRA?
• In order to request relief under the SCRA, a servicemember or spouse, or both, must
provide a written request to the lender, together with a copy of servicemember's military
orders. The Lender providing this Notice is Members I` Federal Credit Union, ATTN:
Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The
phone number is toll free (800) 283-2328.
How Does a Servicemember or Dependent Obtain Information About the_SCRA?
The U. S. Department of Defense's information resource is "Military OneSource".
Website: http://www.militaryonesource.com
The toll free telephone number for Military OneSource are:
o From the United States: 1-800-342-9647
o From outside the United States (with applicable access code): 800-3429-6477
o International Collect (through long distance operator): 1-484-530-5908
Servicemembers and dependents with questions about the SCRA should contact their
unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal
assistance office locator for all branches of the Armed Forces is available at
http•//]egaIassistance law of mil/content/locator.php
form HUD-92070
(2/2007)
USPS - Track & Confirm
Search Results
Label/Receipt Number: 9171 0821 3339 3582 9991 94
Detailed Results:
• Delivered, September 30, 2008, 7:53 am, MECHANICSBURG, PA
17055
• Unclaimed, September 20, 2008,11:37 pm, NEWVILLE, PA
• Electronic Shipping Info Received, September 06, 2008
• Notice Left, September 06, 2008, 12:45 pm, NEWVILLE, PA 17241
• Acceptance, September 05, 2008, 6:23 pm, MECHANICSBURG, PA
17055
c !Tack ; Retain to USPIcom Horne
(tih cation Option
Return Receipt (Electronic)
Verify who signed for your item by email.
Page 1 of 1
Track & Confirm
Enter Label/Receipt Number.
Site Ma Contact Us Forms Gov't Services Jobs Privacy Policy I mns of Use National & Premier Accounts
Copyrighttc 1999.2007 USPS. Alt Rights Reserved. No FEAR Art EEO Data FOIA
Exhibit "C"
http://trkenfrml.smi.usps.com/PTSi,., 10/31/2008
14 l St
MEMBERSr
r.ea.elren.ar
BORROVWR S NANE AND,
5000 Louise Drive, P O Box 40 BRADLEY M BRYAN
Mechanicsburg, PA 17055 62 S HIGH ST
FIXED I I VARIABLE
UVO
ANNUAL PERCENTAGE FINANCE CHARGE' Amount Financed The amount of Total of Payments The amount
RATE' The coal of your credit as a The dollar amount the credit will credit provided to you or on your you cell have paid after you have
behalf made all payments as scheduled
yearly rate ' cost you
% $ 1,98395 $ 6.26464 $ 8,27359
11 60
Variable Rats If your loan has a Venable rate as Indicated above the Annual Percentage Rain may macaw during On term of this transaction If the (Index) chanties The
credit anon will add a margin of to the ndsx value The rate will change monthly on the first Wy of the month The rate will never be higher than the maximum rate allowed by
ses will result in more payments of the same amount For Example, d your loan was for 15,000 at 15% for 46
t
t
erest ra
e hntuaa
law, and d wit never be less than Any in
months and the Annual Percentage Role meraased by 2% after one year, the term of your loan would increase by two months
•Prafemd R W M chedtad, the fosowmg applrao to your loan
TE your box S
I(C?I AutanaUe PaynleG Oiaeounbd Rats Becww Yo0 have agreed to make your ragulrad monthly ments through an automatic L from Chocking(Saving
ANNUAL PERCENTAGE AGE RATE RATE Don N
been dtsceuntW by 20% The ANNUAL PERCENTAI,.E RATE dadossd above in h
GE RATE t
P
CENT
int
w
ER
A
l?tx;ouril your ANNUAL
tha Automatic Payment Disceinited Rab Tha rate we nrxsaw by 2 % d you cease tbe aulomahc psyrtNnt arrangement or fad maninn stdhae tends in your account to
l d the ncreew will bs W sxwd ttN term ttf your loco For example if your Automatic Payment Discounted Role Rets is a 10%
1M
lte
h
• cew
e
c
cover the wloma0c payments In suc
on a i5 000 00 loan for 60 months and you caasa ate aubmatc paymem orrangemsm yvw rain will rncrsaee k` 10 20%. d discount 1 additional
t the the ti ms payment
rain Ian and yea gwldy ter a pMamd rate your preferred duocunounl is ra token at e you take out your ken This
n
bl
a
a
Variable Rats Pratsrted Leans II y0uf ban a • ve
R
mNal prafarred ANNUAL PERCENTAGE RATE will then vary awaiting ts dtsnpee n 1M Index (n dadosd above) For example d • vaoahle rain l ANNUAL
PERCENTAGE RATE will be N/A% Your anal preferred ANNUAL L PERCENTAGE
ralerrad ANNUM
our IaDal
fha b
k
.
p
en y
e
PERCENTAGE RATE le tZ% al ea tires you ta
RATE will then wry eaaNng te the Index ee dad n Iha'Vanahle Rats' pnovrsor above
fixed rate ban and you gwky for a prMarrad rate, your ANNUAL PERCENTAGE RATE will be One preferred ANNUAL
Fixed Rob Preinrted Laws R your bee lot I's
PERCENTAGE RATE disclosed above for as as your preferred status rarm ns in aflacl
Number of Payments Amount of Payments Payment Frequency When Payments Are Due Proporty Insurance You may obtain property,
insurance from armryone you want that is acceptable to
the
f
y- 129 $6365 BNWeekly • Beginning (14/21!2006
a
P rom
the credit union IT you get the insurance
Credit union you well pay
eymo
-ea e 1 $6274 Final Due • On 0001/2011 S NIA
Security Collateral ring other loans with ft credit union the goods or property Otter
will also secure this ken You are giving a security Interest in being purchased X (0--be)
your shams and/or deposit in the credit union and SIGNATURE
Late Charge If a payment a lab by 10 days or more you sad Requires! Deposit Balance The Annual Percentage Rate does Filing Fees Non•Flling Insurance
be charged a lain tee of 5% of your scheduled payment not take Ido account your required deposit balance d any $ MA t NIA
vry roiq COMM snyrspix rapsym n ric.
N a penalty I M yidlgMO tleN ate pnpgn?i rdunds and psrWMs
e from essnM
ITEMIZATION OF
AMOUNT FINANCED $
8,264 64
Amount Pad to others on your behalf (Describe)
AMOUNT GIVEN TO YOU DIRECTLY S 6,00000 s000
$28404 To ?NSaaws Life
To ManeeraLife S
$ To
To
AMOUNT PAID ON YOUR ACCOUNTS S To $
$000 To
To Fees
PREPAID FINANCE CHARGE S S
$ To
To Ailed SOAM $ To AN" 8D48110ns
OTHER (Describe)
and/or Deposits of I S I I s
You agree that sia terms and condieons in the disclosure statement and the ban and security agreements located on pass 2 of this docurnent shall apply b this (sun If then I more
than one bormwer we agree than as the conditions of the ban and security agreements governing this loan $half apply to be jointly a e y You WKe to gthae have
racewed a copy of the loon and security agreements and disclosure statement Casgnsr If you are sign ng as co-sgner, you acknowledge receipt of gn
contained ore page 2
RR 'S SI TU DATE CO-MAKER 'OTHER OWNER ''CO-SIGNER DATE
(SEAL) X (SEAL)
? CO-MAKE ? 'OTHER OWNER [] -CO-SIGNER DATE ? C44AAKER []'OTHER OWNER 0 -CO-SIGNER DATE
X (SEAL) X (SEAL)
? CO-MAKER [] 'OTHER OWNER ? --COSIGNER DATE ? CO-MAKER ? -OTHER OWNER ? "COSIGNER DATE
(SEAL)
X (SEAL) X
otasao CR amr never wwnw..sra.rrr L..rwt U+•rw.,rerw?wrr.«rlww. r...e..eiew «er.r periw. n..w...,es,w.r..e.rr.r rmw.esa+srr.r e. e++, r. w..r.w cur
w.arawn Naeseaesy YerrrlnearYrNrreisew4y ear uaeeylY?eeranl Co4seese lraw,4MwiMaret rerlrrnrre rte kwraW w7nre aaneasesrrerW cry re elaere 4wrea Mr ltw
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3 r.0 M tut see we hen, frou nN?r?Or d 1retlW &= Man Dormb7 rierydswas snots ? Q ?
damn Aepred klniYrr oi00.iier° 'ndnx S) of Alo$rrtMew ARC 1)
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wi net saase n my Oo-ePPlrra «1 wwaf 1'ee N premn i we indersiond rat we era 0raa for nruarrn w N an crews not nn0 $l00
The WNiaes dale of my toll) xalaane,vrk be the die of the aOPa?rt Any poison MM baiMralY one Win Imam as Ae4we say InaMallia eanipogi ear MMr praon MM any C a ter inwnnce
srstreeira or tuba eeniteinkig any raeteiidY Wsa brain tiiNe or wncwN for IM see N rNefeedkG kdamwAlan eeneawd^ on feat ataunat Hereto conndN a kw t keunnee act
ion he:o hoe noiubw?wu?na dTMN application will not be us.d m contest x an applicable
blank . w rrd".?ardi ? °g,afOdebyer has „w ;Ipned a,M erw the wpue+aoria M t
CREDIT INSURANCE APPLIED FOR NOTE ONLY ONE APPLICANT MAY APPLY FOR DISABILITY COVERAGE
? Yes T No Single Credit Life Total Premium
? Yes x? No Joint Credit Life
Indicate which epPlrant(e) ? Applicant ? Co-Applicant $0 (10
appleeson
you re covered any ter M types d oDweO/ far-.h • dirge N bvk -" en Was
ICANT IGNATURE DATE OF BIRTH DATE
5 DATE SECONDARY BENEFICI
w 37
MNC 97 37 USER-WORD F 43760 Rev IM
Q Yes ? No Credit Dlsabllty Total Premium
Inmate which appkcant(s) ? Appkant ? Co-ApPbram 264 64
CbAPPLICANT'S SIGNATURE DATE OF BIRTH DATE
X
(APPLICANT) - - FMA111 °-"-4CV.RY (CO-APPLICANT)
I Rawl Compwwa Imo At not" raeervw
Exhibit "D"
BORRON£R S NAM LOAN NUMBER ACCOUNT NUMBER DATE OF LOAN
BRADLEY M BRYAN 147530 17017402 04/06!2000
NAMED AS G&E.E WER(S)THE WORDS "CREDIT UNION MEANS MEMBERS 1ST FEDERAL CREDIT UNION THE WORDS "YOU" "YOUR" AND `YOURS" MEAN THOSE
LOAN AGREEMENT
PeymentsfFinonce Charges For value received, you promise to pay, of
the Crodlt Urlon'a office, all smounls due All payments shall be made
pursuant to the dhscbsurs statement on page 1 of nitro document You
understand that the finance charge and total of prey rients shown on page 1
of this document are based on the assumption ttwt pM uulaament payments
LAN be made on the scheduled due dates, and , if you have quebled Ur
preferred rate that you conte abe to satisfy the conditions of that preferred
role If you fah( to fay any Installment by the time it is due, you will pay
additional Internet on the overdue amount
Allocation of Payments and Additional Payments Payments and
credits shat be applied in the following order any amounts past due, any
fees or charges owing, Including any Insurance premuns, accrued interest
or finance charges, outstaird principal Payments matte in addition to
regularly schedulef psymenb shall be applied n the same order
Preferred Rate H you qushN for a preferred rate as disclosed on page 1 of
this document or in a separate preferred rate addendum, you understand
that you must meet the eordlbom disclosed to you in order to queahff for the
preferred rate and must continue to meal those conditions in order o keep
your preferred rate If you fall to meet those conditions, your rate will
increase, trorebbyy extending the bans of your loan You Tomlea to continue
making paymenfa and to meet all oVtions under this Areement even of
you no longer receive the preferred rile
Late Charges If you make a Into payment, you agree to pay a late charge
if one is disclosed on page 1 of this =nt.
Property Insurance If you obtain a loan secured by a motor vefrde or
other tangible properly, you must obtain insurance which protects the credit
union from financial Ides The amotxit and coverage of the property
insurance must be acceptable to the credit union Such a policy must
provide at least fire, then, cambmed additional coverages and colbsion
insurance it must contains Loss Payable clause endorsement naming the
credit union as lien holder You may obtain this Insurance from any agent of
your choice and direct the agent to send the credit union a copy of the
policy
Debtor Responsibility You promise to notify credit union of "_ change in
your name address or empb rtent You promise not to apply r a loan it
you know there is a reasons probablbty that you will be urhable to repay
Yyour obhgabon Beoordlp to the tames of tie cradd extension You promse
to inform credit union of any new Information wfach relates to your ability to
re ay your obligation You propose not to submit false or Inaccurate
information or *difuly conceal Information regarding your creditworthiness.
credit standing, or credit capacity
Default You shall be considered in default H any of the following occur 1)
or realization 'of Me collateral, If any, is Impaired, or (4)-d you die, or (5) If
Yyou file a petition in bank Nptcy insolvency or recelverehh or are put
involunlanly into such proceeds tx (6 if the collateral. it any, given as
security for the account is Iost, dameg? or destroyed, or if d is levied
against, atached or garnished. Or ( d you do not pay on lime arty of your
other or futons debts M to cradd uniort If you defoult, the Credit unon may,
at the credit union's option and without prior notice, declare this loan
Irrxnedrately duo and payable, and you must unmedntely pay to the credit
union at that time the total unpaid balance as well as the Finance Charge
to data, antM late charges and costs of collection permitted under law,
Including reasonsble atorney s fees, that the credd canon may incur, up to
20% of the unpaid ...aag and Irdereat Costs of collecllon include, but are
not hmiled to, r sgessbn tees, appraisals, emmonmental ado
acueerr.wnta ?uuNv damene, nauranre coveraaa. and attorMv's fees for
responsibility SECURITY AGREEMENT
Statutory Lien H you are in default, federal low gives the credit union the
nghl to apply the balance of shams "for divdendo In our account( s at
the same of default to satisfy this ban Once you are in default, the credit
union may exercise this right without further notice to you
Delay M EMorcemsnt Credit Union may delay enforcing any of the credit
union rights under this agreement without losing them
Irregular Payments The credit union may accept late pa nts or partial
payrthents, event h marked 'payment in full, without toting any of the
credit union rights under this agreement
Co-makers If you are agning this agreement as a co-maker, you agree to
be equalhy responsible with the borrower, but the credit union may sue
either or both of you The credit union does not have to nobly you that this
agreement has not been pad The creckl union may edend 111e terms of
payment and on t release any agreement without ratifying or reieassg you from
1 To saeun WYmaM otpl Iban and sit sapaMRune incurred W tln credit
uMon In conM Donee wltlt tRis bees, or In nallsrno on A {acwkylnb ml, you
gnot te credit union !s.ecurty Interest In rhi property described on
papa / this mn j=Rt Tha e?eurily hdereat pb0¢.{luydescacR Iona ions,
IruOeuuinu oMii Inn.0d tasaOedOOUWngduprtoopertty asabu nd 11=111' tpi'nmlwd tramdny
eseured property
Croas<ollaWdlatbn rly %s u sacV for this ban or for any
other loan Borrower hqq the entpt ion weir saeun all amounts
Borrower otvN tN ciao sin n now sin n the fuWn However property
secu another debt 1 not" n m loan H cuts properp? )a
Bofa pdn¢Ipsl n nee (u ii ew the psropsl Rio ?1aWOn Ibtlcea an
w apnd ay other M uirarwnb mm aua ) mum to
mo ney newehotd pooch
2 YYoe Gwbep dnt h np = ol. 1,11 or, transfer the mNateral unless you have
3 You warrant OW you have flood sae b the collabnl free of all sacunry mbrssb
to
pt that gn to maker owner of the wNi aterall wun0 his s d d s? the aa any mprsem in eM at in the a ind noIndicated for terest of
h
piece
4 You will ail taxes sesaaarthante, and pens against or attached to the property
described nd further apse to keep the propergr in cool condition, housed in a
suitable shelter You wrw tp execute lnananp ate *Me end sectany
apeamait atnendnrnla d the credit unon'e request and will defend the property
agural edvene th rd perry deans
S You will maintain insurance to cover any vehicle or other property in which the
credit union has a seafrry interest This insurance well be in a form and an
amount satisfactory to fh• credit union You we supply the credit union with proof
of such insurance until of sums awed to credit union and secured by Ihn
, edrt union may but
property are rewd if you fail b rrowaaah such insurance a
is not requnrd ro obWn nsuonos of our own and add me cost of such to IM
sums owed Tka cost via burr interest at the contract rate until pad You further
assign to ft credit won to right to rem" the proceeds of any uaunnce on
suds property and daect any insurer to pay those proceeds dwecv to dledit
wo;=I Ulhont die credt union b endorse airy cheek or din provided air
the of such insurance and apply those pmcesoa to the sums owed to
the credit union
You further authorw the credit union to provide your Insurance Sen non Center
with the necessary information for verification, of adequate coverage
You adnowledpa Plat nsurance cr on sbderhsion tared placed pry rte credit
primarily br the profecoon d the
endrt asp Nhoul DsneM to you indivdu"uy but is
N Should the credit union feel at any am* that the security presented has
duNmshed in value, or ter any rNSOn fast IhaI addrborhrf seanry u nqu¢ed you
eprw b n ?p dmxM union wahm pro ionte (10) days aAhabver addnonal aseunrY
X Wd n reels a nece{sary b d the credit union against possible
ions
contractual Pledge of Shen. You pledge as your aharse and depwlle In the
credit union, lmludhv rupture addltbns, as security for this ban In caw you
defaua, the credit union may apply thew there" and deposits to the payment
of at sums due at the time, of default, leohuding costs of coosclbn and
reasonable attorney's fees, that the credit union may Incur. up to 20% of the
unpaid principal and Interest No Nan or right to Impress a Ilan on shares and
deposits shelf apply to any of your share which may be how In an "Ir dMdual
flatinment Account" or "Keogh Plan "
9100 2199
You are being asked to guarantee tthhs debt Thank carefully before you do If the borrower doesn't pay the debt you wel have to Be sure you can amore to
pay if you have to, and that you ward to accept this responsibility
You may have to pay up to the ill amount of the debt if the borrower does not pay You may also have to pay late fees or ooNechon costs which increase this
amount yo p cred
wages a borrower If this ot is event ,n delaWt,that fad maay beection come a part ofyouilc edition
method cTahn be uei aganslt the borrwvarf resuch saes suing you tgtrying shxw yllect from the
record This notice is not the wMrad that makes you liable for a debt
F 437591!02
APPRO Sy.hens Inc 2241079
Page 2 of 2
=Credit
s Th. whit 1M aeabtheimioih tKls are ne4aas b P. F. tole M, and ins the CO
whreb this agreement erealas
9 if there is more Man one borrower, vow Obligations rm?er this agroampnt are
9Z several each being *fluid areporwble to hdlN the terms d tlvs
Ill
10 This eecunty agreement not only bonds you, but your executors, admmsUaba,
heirs, and assigns
KARL M. LEDEBOHM
ATTORNEY-AT LAW
P.O. BOX 173
New Cumberland, PA 17070-0173
Phone: 717-938-6929
Fax: 717-932-0317
December 26, 2008
(Via Certified and regular mail)
Bradley M. Bryan
62 South High Street
Newville, PA 17241
RE: Members 1St Visa Account No.: 4121440011701749 (the "Visa Account")
Members 1St Account No: 0000170174
Dear Mr. Bryan:
THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE FROM
THIS OFFICE IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. AN
IMPORTANT STATEMENT OF RIGHTS IS INCLUDED ON THE REVERSE
OF THE SECOND PAGE OF THIS LETTER.
Members 1St Federal Credit Union ("Members 1St") has requested my office to
collect the amounts due to Member's 1St under the above accounts (collectively, the
"Accounts").
As you know, you are in default of your obligations under the Accounts due to
your failure to make the payments required under the Accounts in a timely manner.
Account No.: 0000170174 is evidenced by that certain Closed-End Note, Disclosure,
Loan and Security Agreement dated April 6, 2006 in the original principal amount of
$6,284.64 (the "Note"). The last payment on the Visa Account was received by Members
1St on or about July 8, 2008. As a result of your defaults, Members l St hereby accelerates
all amounts due to Members 1St under the Accounts and hereby demands the payment of
all amounts due to Members 1St under the Accounts in the amount of $10,895.62 itemized
as follows:
A. The Visa Account - Principal and late charges $6,128.98
B. The Note
a. Principal $4,102.05
b. Interest to 12/22/08 302.43
c. Late charges 47.70
Exhibit "E"
d. Total due under the Note as of 12/22/08 $4,452.18
C. Legal fees and costs
$314.46
D. Total due to Members 1St under the Accounts as of 12/22/08 $10,895.62
If you fail to deliver to my office at the address set forth above payment of the
$10,895.62 within thirty (30) days of the date of this letter, Members 1St will have no
choice but to file a legal action against you to collect all of the amounts due under the
Accounts without further notice. In such event, in addition to the above amounts, you
may also be responsible for the payment of additional reasonable legal fees and costs of
suit incurred by Members 1St
Nothing herein shall constitute or be construed as an agreement on behalf of
Members 1St to accept any terms and conditions in exchange for payment of the amounts
due under the Accounts except for the immediate payment of all amounts due to
Members I". Nothing herein shall constitute a waiver of any rights or remedies which
Members 1St may have under any written agreement or at law or in equity to collect the
balance of the indebtedness due under the Accounts without further notice, including,
without limitation, the right to accept and apply any partial payments made on the
Accounts without waiver of any demand for payment in full of all amounts due under the
Accounts. Nothing herein shall constitute an agreement on behalf of Members 1St to
postpone or extend the maturity date of the obligation.
Members 1" looks forward to the payment of the $10,895.62 on or before January
25, 2009.
Very tru yours,
W1
Karl M. Ledebohm
CC: Arlanda Dintaman, Collateral Liquidation Specialist
KML:II
NOTICE
This letter is an attempt to collect a debt.
It you dispute the validity of this debt, or any portion thereof, and you contact the
undersigned within thirty (30) days after receipt of this Notice, you will be furnished with
written verification of the debt; provided, that if a lawsuit has been filed against you to
collect this debt before the expiration of the thirty (30) days, the complaint filed in said
lawsuit will constitute written verification of the debt.
If you do not dispute the debt or any portion thereof as stated above, the
undersigned will assume the debt is valid.
If the original creditor of this debt is different from the creditor stated on the front
page of this letter, the undersigned will provide you with the name and address of the
original creditor upon written request from you within thirty (30) days of receipt of this
notice.
The undersigned means the name signed at the end of this letter appearing in print
at the top of this letter.
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VERMCATION
L Arlanda Dintaman, Collateral Liquidation Specialist for Members 1" Federal
Credit Union, being authorized to do so on behalf of Members 1" Federal Credit Union,
hereby verify that the statements made in the foregoing pleading an ftc and comma to
the best of my information lmowledge and belief T undw%aW that false statements an
made subjed to the penalties of 18 Pa. C.S.A. Suction 4904, relating to unswaM
falsification to mwxvi6=.
Members I" Federal Credit Union
Arlandaa Dintaman, Collateral
Liquidation Specialist
11
C 1 f^..J
r8
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17
D
SHERIFF'S RETURN - REGULAR
CASE NO: 2009-00440 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT U
VS
BRYAN BRADLEY M
SHAWN HARRISON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BRYAN BRADLEY M the
DEFENDANT , at 0836:00 HOURS, on the 31st day of January , 2009
at 62 SOUTH HIGH STREET
NEWVILLE, PA 17241 by handing to
BRADLEY BRYAN
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 9.90
Postage .56 '
Surcharge 10.00 R. Thomas Kline
.00
38.46 02/02/2009
KARL LEDEBO
Sworn and Subscibed to By:
before me this day Deputy Sheriff y
of A.D.
C
rrr
r JJ
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-929
MEMBERS 1`51 FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
PLAINTIFF : PENNSYLVANIA
Vs. : NO.: 09-440 Civil Term
BRADLEY M. BRYAN :
DEFENDANT : CIVIL ACTION-LAW
PRAECIPE
TO THE PROTHONOTARY:
Please enter judgment in the above captioned proceeding in favor of Members 1St
Federal Credit Union, Plaintiff, and against the Defendant, Bradley M. Bryan, on
Counts I, II and III as set forth in the Complaint in the aggregate amount of
Eighteen Thousand Nine Hundred Twenty-five and 70/100 Dollars ($18,925.70)
together with interest at the legal rate on and after the entry of judgment on the
complaint through the date of payment, additional attorney's fees, if any, and
costs of suit. Judgment is entered pursuant to Pa. R.C.P. 3031 for failure to file an
Answer on behalf of Bradley M. Bryan to Plaintiff's Complaint within twenty
(20) days of service thereof and after a 10-day Notice was sent.
Respectfully submitted,
Date: March 11, 2009
Carl A'Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
I hereby certify that notice of intent to take default judgment was forwarded to
Bradley M. Bryan by United States Mail, first class, postage prepaid on February 24,
2009. The aforesaid notice was contained within an envelope bearing the return address
of the undersigned. The notice has not been returned to the undersigned as undeliverable
or otherwise. A copy of the notice and Postal Form 3817 are attached hereto and marked
Exhibit "A".
Ledebohm, Esquire
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
BRADLEY M. BRYAN
DEFENDANT
TO: Bradley M. Bryan
62 South High Street
Newville, PA 17241
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-440 Civil Term
CIVIL ACTION-LAW
IMPORTANT NOTICE
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM
REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. 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 PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Date: February 24, 2009
U.S. POSTAL SERVICE
USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NO7
E FOR INSURANCE-POSTMASTER
Re Karl M. Ledebohm, Esq.
-P.O. Box 173
-New Cumberland, PA 17070-0173
Respectf ly submitted,
L_-
K6r1 M. Ledebohm, Esci
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
o T ? C
One Ilk" of omkwy mail apeteaeee lo: p rn n y
o _ ?pp
J69- N?1 D
ftv d? GO
? N
PS Fonn 3817, January 2001
Exhibit "A"
?-Lz- :::s
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)93&929
MEMBERS 1 ?" FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
BRADLEY M. BRYAN
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO.: 09-440 Civil Term
: CIVIL ACTION-LAW
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM
REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE
TO: Bradley M. Bryan
62 South High Street
Newville, PA 17241
You are hereby notified that on 31 Id 10q , 2009 the following
judgment has been entered against you in the above captioned case:
Judgment in favor of Members 1" Federal Credit Union, Plaintiff, and against the
Defendant, Bradley M. Bryan, on Counts I, II and III as set forth in the Complaint
in the aggregate amount of Eighteen Thousand Nine Hundred Twenty-five and
70/100 Dollars ($18,925.70) together with interest at the legal rate on and after
the entry of judgment on the complaint through the date of payment, additional
attorney's fees, if any, and costs of suit. Judgment is entered pursuant to Pa.
R.C.P. 3031 for failure to file an Answer on behalf of Bradley M. Bryan to
Plaintiff's Complaint within twenty (20) days of service thereof and after a 10-day
Notice was sent.
Dated: 31 G thono
is:
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236
Bradley M. Bryan
62 South High Street
Newville, PA 17241
A: Bradley M. Bryan
Por este medio se le esta notificando que el de
2009 eUla siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso
mencionado en el epigrafe.
Fecha:
Protonotario
Certifico que la siguiente direccion as la del defendido/a segue indicada en el certificado
de residencia:
Bradley M. Bryan
62 South High Street
Newville, PA 17241
submitted,
Date: March 11, 2009
M. Ledebohm, Esquu
erne Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-929
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. SECTION 101 TO SECTION 149 ETC.
MEMBERS 1sT FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
09-440 Civil Term
vs. : Amount Due: $18,925.70
Interest from: 3/12/09 at the legal rate
: Attorney's fees: To be added
BRADLEY M. BRYAN
Defendant COSTS TO BE ADDED
TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE
MATTER
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2) against Bradley M. Bryan, 62 South High Street, Newville, PA 17241, Defendant;
(3) and against N/A Garnishee (s);
(4) and index this writ against Bradley M. Bryan, 62 South High Street, Newville, PA
17241, Defendant;
(a) against N/A Garnishee (s),
?-? and levy upon and seize the following real property of Defendant and index this
writ against the following real property of Defendant as a lis pendens:
All that certain tract of land and improvements thereon erected situate in Borough
of Newville, Cumberland County, Pennsylvania, known and numbered as 62 South High
Street, Newville, PA 17241 and as more particularly set forth and described on Exhibit
"A" attached hereto and made part hereof by reference.
-%
(b) Exemption has (not) been waived.
Dated: April 17, 2009
?Irl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
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Karl M. Ledebohm, Esquire j r',
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(717)938-6929
MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
V. : NO.: 09440 Civil Term
BRADLEY M. BRYAN
DEFENDANT CIVIL ACTION-LAW
AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1" Federal Credit Union, plaintiff in the above action, set forth as of the date
the praecipe for the writ of execution was filed the following information concerning the real
property located in Newville Borough, Cumberland County, Pennsylvania, known and numbered
as 62 South High Street, Newville, PA 17241.
1. Name and address of owner(s) or reputed owner(s):
Bradley M. Bryan
62 South High Street
Newville, PA 17241
2. Name and address of defendant(s) in the judgment:
Bradley M. Bryan
62 South High Street
Newville, PA 17241
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Members 1St Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
4. Name and address of the last recorded holder of every mortgage of record:
Members 1St Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
M & T Trust Company
1 M&T Plaza
Buffalo, NY 14240
Beneficial Consumer Discount Co.
d/b/a Beneficial Mortgage Co. of PA
419 Village Drive, Suite 2
Carlisle, PA 17013
5. Name and address of every other person who has any record lien on the property:
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
M
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: April 17, 2009 Respectfully
1 M. Udebohm, Esq.
S?ipreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
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Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 FEDERAL
CREDIT UNION
PLAINTIFF
V.
BRADLEY M. BRYAN
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO.: 09-440 Civil Term
: CIVIL ACTION-LAW
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
To: Bradley M. Bryan
62 South High Street
Newville, PA 17241
THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR PURSUANT
TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO
INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
Your house (real estate) at 62 South High Street, Newville, PA 17241, as more
particularly set forth and described on Exhibit "A" attached hereto and made part
hereof, is scheduled to be sold at Sheriff s Sale on September 2, 2009 at 10:00 aVm. in
the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street,
Carlisle, PA 17013 to enforce the court judgment in the principal amount of
$18,925.70 plus interest at the legal rate, additional attorney's fees and costs of suit
obtained by the above named Plaintiff against you. In the event the sale is continued,
an announcement will be made at said sale in compliance with Pa.R.C.P. Rule
3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff s Sale, you must take immediate action:
1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the
amount of the judgment plus costs and reasonable attorney's fees. To find out
how much you must pay, you may call Karl M. Ledebohm, Esquire, at
(717)938-6929.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also
ask the Court to postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings. You may
need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice below to find out how
to obtain an attorney.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling the Sheriff at the County
Courthouse.
2. You may be able to petition the Court to set aside the sale if the bid price was
grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due
in the sale. To find out if this has happened, you may call the Sheriff at the
County Courthouse, which number is listed below.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have a right to remain in the property until the fu11 amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the
Sheriff on October 2, 2009 (within thirty (30) days after the Sheriff Sale).
This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the
proposed distribution is wrong) are filed with the Sheriff within ten (10) days
after the schedule of distribution is filed by the Sheriff.
7. You may also have other rights and defenses, or ways of getting your house
back, if you act immediately after the sale.
h
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717)249-3166 or (800)990-9108
The Sheriffs phone number is: (717)240-6390.
ar 3 PLt S,
M. d:11) hm, Esquire
upreme Co#59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
S
ALL THAT CERTAIN tract of land situate on South High Street in the Borough of
Newville, Cumberland County, Pennsylvania, bounded and described as follows, to wit:
ON the East by South High Street; on the West by lot now or formerly of Melvin Kelly;
on the North by other property of John L. Rickabaugh et ux; on the South by lot now or
formerly of William Gilbert. CONTAINING thirty-six (36) feet, more or less, in width
and eighty-two (82) feet, more or less, in depth.
HAVING thereon erected a dwelling known as 62 South High Street, Newville, PA
17241.
BEING the same premises which Robert A. Suloman, Sharon L. Rockwood and Stanley
L. Spencer, co-partners, by their deed dated August 24, 1989 and recorded in the
Cumberland County Recorder of Deeds Office at Deed Book D-34, page 124 granted and
conveyed unto Bradley M. Bryan.
EXHIBIT "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-440 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1sT FERERAL CREDIT UNION,
Plaintiff (s)
From BRADLEY M. BRYAN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $18,925.70 L.L. $.50
Interest from 3/12/09 at the legal rate
Atty's Comm % Due Prothy $2.00
Atty Paid $157.46 Other Costs to be added
Plaintiff Paid
Date: 4/21/09
?r Curtis R. Long, Pr thonot ry
(Seal) By:
Deputy
REQUESTING PARTY:
Name: KARL. M. LEDEBOHM, ESQUIRE
Address: PO BOX 173
NEW CUMBERLAND, PA 17070-0173
Attorney for: PLAINTIFF
Telephone: 717-938-929
Supreme Court ID No. 59012
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-929
MEMBERS 1 J' FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Vs.
BRADLEY M. BRYAN
DEFENDANT
NO.: 09-440 Civil Term
: CIVIL ACTION-LAW
AFFIDAVIT OF SERVICE OF NOTICE TO MEN HOLDERS PURSUANT TO
Pa. R.C.P. 3129.2 (e)
I, Karl M. Ledebohm, Esquire, being duly sworn according to law hereby swear
and affum that on the 13th day of May, 2009, I served the attached NOTICE TO
LIENHOLDERS AND OTHER PARTIES IN INTEREST pursuant to Pa. R.C.P.
3129.2 in the above captioned matter upon the following individuals by first class
mail, postage prepaid, addressed as follows:
Members I" Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
M & T Trust Company
1 M & T Plaza
Buffalo, NY 14240
Karl M. L.edebobm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
V.
BRADLEY M. BRYAN
DEFENDANT
: NO.: 09-440 Civil Term
CIVIL ACTION-LAW
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa. R.C.P. 3129.2
To: Members 1" Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
M & T Trust Company
1 M & T Plaza.
Buffalo, NY 14240
Beneficial Consumer Discount Co.
d/b/a Beneficial Mortgage Co. of PA
419 Village Drive, Suite 2
Carlisle, PA 17013
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland
County, directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, PA 17013
on September 2, 2009 at 10:00 a.m., the following described real estate which Bradley M.
Bryan is the owner and reputed owner and on which you may hold a lien or have an interest
which could be affected by the sale of:
62 South High Street
Newville, PA 17241
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of :
MEMBERS 1ST FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
V. NO.: 09-440 Civil Term
BRADLEY M. BRYAN
DEFENDANT CIVIL ACTION-LAW
at Ex. No. 09-440 Civil in the amount of $18,925.70, plus interest, additional attorney's fees
and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed in the Office of the Sheriff no later than thirty (30)
days from the sale date.
Exceptions to distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution
is filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriff's Sale or this Notice,
you should contact your attorney as soon as possible.
Date: May 13, 2009
1?GId1 111. LVYV W1J111, iJV?.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN tract of land situate on South High Street in the Borough of
Newville, Cumberland County, Pennsylvania, bounded and described as follows, to wit:
ON the East by South High Street; on the West by lot now or formerly of Melvin Kelly;
on the North by other property of John L. Rickabaugh et ux; on the South by lot now or
formerly of William Gilbert. CONTAINING thirty-six (36) feet, more or less, in width
and eighty-two (82) feet, more or less, in depth.
HAVING thereon erected a dwelling known as 62 South High Street, Newville, PA
17241.
BEING the same premises which Robert A. Suloman, Sharon L. Rockwood and Stanley
L. Spencer, co-partners, by their deed dated August 24, 1989 and recorded in the
Cumberland County Recorder of Deeds Office at Deed Book D-34, page 124 granted and
conveyed unto Bradley M. Bryan.
EXHIBIT "A"
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Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-01-73
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