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Home My WebLink About09-0950 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff V. JEFFREY A CRIDER Defendant(s) NO. 09 - '150 Cwi l .Tem COMPLAINT IN CIVIL ACTION Filed on behalf of. HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 PF_PA_l I Cmplt Cvr Sht Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 P&F File No. 08-95575 si. IN THE COURT OF COMMON PLEAS bF CUMBERLAND COUNTY, PENNSYtVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff V. JEFFREY A CRIDER Defendant(s) NOTICE TO DEFEND NO. You have been sued in Court. If you wish to defend against Usted ha sido demandado en corte. Si usted desea defenderse the claims set forth in the following pages, you must take de las demandas que se presentan mas adelante en las action within TWENTY (20) DAYS after this Complaint and siguientes paginas, debe tomar accion dentro de los proximos notice are served, by entering a written appearanceerspnel#y? rv t? 30) dias despues de la notifcacion de esta Demanda y or by an attorney, and filing in writing with the 4p X ?', ? tV? R,radicando personalmente o por medio de un abogado or escrito n la Corte d di i i m ' u defenses or objections to the claims set forth against yo . p o e ta y ra can a escr parecenc yn a'cti are warned that if you fail to do so the case may proc'ee'd' -sus defensas de, y objecciones a, las demandas presentadas without you and a judgment may be entered against you by the aqui en contra suya. Se le advierte de que si usted fall de court without further notice for any money claimed in the tomar accion como se describe anteriormente, el caso pude Complaint or for any other claim or relief requested by the proceder sin usted y un fallo por cualquier suma de dinero Plaintiff. You may lose money or property or other rights reclamada en la demanda o cualquier reclamacion o remedio important to you. solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad au otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER ,UST,ED DEBE LLEVAR ESTE DOCUMENTO A SU AT ONCE.IF YOU DO NOT HAVE A LAWYER GO TO OR ABOGADO INMEDIATAMENTE. SI USTED NO TIENE TELEPHONE THE OFFICE SET FORTH BELOW: THIS UN ABOGADO, LLAME O VAYA A LA SIGUENTE OFFICE CAN PROVIDE YOU WITH INFORMATION OFICINA. ESTA OFICINA PUEDE PROVEERLE ABOUT HIRING A LAWYER ,- - INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE OFFICE MAY BE ABLE TO PROVIDE YOU WITH UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE INFORMATION ABOUT AGENCIES THAT MAY OFFER PUEDA PROVEER INFORMACION SOBRE AGENCIAS LEGAL SERVICES TO ELIGIBLE PERSONS AT A QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O REDUCED FEE OR NO FEE. BAJO COSO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY BAR CUMBERLAND COUNTY BAR ASSOCIATION ASSOCIATION 32 SOUTH BEDFORD STREE 1 ra ?? .? 1,?? +` 't.32 SOUTH BEDFORD STREET CARLISLE, PA 17013 CARLISLE, PA 17013 717-249-3166 717-249-3166 -A ,l.": r PA-2 INotice to Defend ` t li`' P&F File No. 08-95575 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff s Y, V. JEFFREY A CRIDER NO. 02-0s" C-N" l +0(nt Defendant(s) ) COMPLAINT 1IN CIVIL ACTION AND NOW, comes Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. , by and through its attorney, GREGG MORRIS, ESQUIRE and the law offices of PATENAUDE & FELIX, A.P.C. and files the following Complaint in Civil Action, and in support thereof aver as follows: s 41 t Account Stated 1. Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT CO., is a corporation with offices with an address for the purposes of this litigation C/O the law offices of Patenaude and Felix, APC, 213 E. Main St eety Carnegie, PA. 2. Defendant(s) is JEFFRE tCIDF?R, ?n adult individual, believed to currently ..? a_ reside at 825 S HUMER ST ENOLA, PENNSYLVANIA 17025--294. 3. Heretofore, the Defendant(s) opened an account with Plaintiff being Account No. 71330300136502. A copy of the Account Agreement is attached hereto as Plaintiffs Exhibit "A" and is incorporated herein by reference: 4. The Defendant(s) made paym?hi t has refused to pay, and now refuses to pay PA 05A Civil Cmplt Crdt Line P&F File No. 08-95575 the balance due and owing on the aforesaid account and now the full amount of the account is due and payable in the sum of $14,358.85 as of 07/07/2008, plus interest at 20.24 % and cost. 5. Plaintiff maintains accurate books of account recording all credits and debits for this account. 6. Defendant(s) have/has received monthly billing statements from Plaintiff setting forth the nature and amount of all debits and'credits_ and the transactions between Plaintiff and Defendant(s) give rise to an account stated, upon which Plaintiff has relied. 7. By failing to object or dispute the statements, Defendant(s) have/has assented to and agreed to the correctness of the balance due,on the credit card account so as to constitute and account stated. WHEREFORE, Plaintiff demandsucgment m its favor, and against Defendant(s), in the amountof $14,358.85 plus interest as attached hereto, with continuing interest thereon at the legal rate from the date of Judgment plus costs. Counts H Breach of Contract 8. The averments of paragraphs, l through 7 are incorporated herein by reference as ,? "(1 uz4:?, ?s a.?+' if the same were set forth herein at length. 9. Defendant completed an Application for Credit and the Agreement is attached hereto as Plaintiffs Exhibit "A" and is incorporated herein by reference. 10. Defendant is in default for failing to make payments as due. 11. The terms of the Contract pgv ed (that Defendant will pay Plaintiff s reasonable attorney's fees. 12. Plaintiff avers that counsel for Plaintiff is not a salaried employee of Plaintiff and that such attorney's fees will amount to $1,400.00. ;S 1!III- U1,11 PA-05A Civil Cmplt Crdt Line P&F File No. 08-95575 N WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amountof $14,358.85 plus interest as attkNdkhereto, with continuing interest thereon at the legal rate from the date of Judgment, reasc?t?l313`ttorney's fees in the amount of $1,400.00 plus costs. Respectfully Submitted: Patenaude el , A.P.C. Date: February 11, 2009 fvv Gregg 2135 Esquire C gl P 15106 (411) 42V675 PA 05A Civil Cmplt Crdt Line P&F File No. 08-95575 Personal Credit Line Account Agreement (Page I of 3) LENDER (called "We", "Us". "Our") HOUSEHOLD FINANCE CONSUMER DISC01;4T 25 GATEWAY DRIVE GATEWAY SQUAREISUITE 101 I MECHANICSBURG PA 11055 LOAN NO. 113303-00-135941 BORROWERS (called "You". "Your") I CRIDER, JEFFREY A 825 S HOMER ST ENOLA PA 11026*' iv 1 Etfi?1y F?4l`t ?yi{I1 , INITIAL AURAL OYI YAROMt wIML YON77AY FE29E11TA911 op PoRTM OF AVEFAaE oAAr a/LLanc6 Pf ooK RAti RATE: GEt)rt UsuT 12000 OA1A 10 OF OF I k 11105 15.2500091 .01 AND OVER 1.834 % 22.000 X wmu A VJMWM AMU FEN P 50.00 s 50.00 I , In this Agreement. "ym". "your" and "Borrower" r r(s} Who sigas'Ulis Agreement "We'. "us" and "our' refer to aonsl Credit Line Account. We Want you to understand how your Lender. This Agreement covers the terms and coni?llon hay questions, and if you agree to be bound by this Agzsement, sign Personal Credit Line Acoouat worts. Read this carefully, askb all sums advanced under this Agreement. below. If more than one parson signs, each will be responsible for repaying You can obtain funds from Your Personal Credit Line is a revolving line of credit extended to you and secured as ddb lbellow. checks we supply to you. You may your Personal Credit Line Account (up to your credit timit} directly from us or by wing the pay your total unpaid balance at any time or in installments. . .. ?'I,?.. 41 +I? 4'SaRA REQUIRED INSURANCE. You may obtain any1? r A from anyme you choose. You must obtain insurance for term Of loan covering security for, t'all bari°as indicated by the word "YES' below, naming us as oss Payee. Physical damage insurance on vehicle listed under *Security- above, if "Y" appears under "Insured.' NOTICE. SEE THE FOLL0INING PAGES FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGMDING VOLIN RIGHTS TO DISPUTE BILUNG ERRORS. PA056611 01 -00 00 ORIGINAL KC04CIeF0o090RLA7000PA0556710K11CRIDEIt " Personal C"t Line AceeDni Agreement (Page Z of 3) AVAILABLE CREDIT. You may obtain twills directly from us or through your special cocks up to Vow available starlit, Each dhaek 'must W written for o most $I" Your available credit limit is vow, oral 1 ishotm on page and INS the total Unpaid balance, II- -Charges, of your Account. if you make loan payments by Q adjust yew OYailabls credit wren days after we restive glider pp allow for Cheoh clearing. If yow request funds in an rrnount this V+aWB cause view to exceed your available credit, we are not obligated to 00 of your varietal. If we do land you on wwwal over your a alablafdit. you Perot to pay us that excess amoent. N PROMISE TO PAY. You promise to pay Lander. W amount borrowed under this Agreement: 0 Pirate Chrtpa. Adminlstratlve Chrgee Ohs late abree and bed cock ohargd, and ocher charges provided in this Agreement: W credit Insurance charges, H arty: fall collection toe». permitted by applicable law, including reasonable attorneys' fees-fif,tle attorney Is met our salaried amployed: and it) amounts in exeestr,,uf, yaw credit limit that we may load you. Plus Finance Charges. PAYMENT. You may repay Vow wake outstanding balance at saw' aims without penalty. You may not vase yaw spsale$ checks to pay: k4 amounts due wow this Agreement. Became to Fl ti n Charge is dempoad *"b day, you will eoraM cis regarding the axset psyclfU seraunt for tie day yen Intend to make full psyment. i It you do not pay the entire wipaid belame on Vow AyeoSnti b!t ' you Pill" to pay at asst tlu tninienwn Payment shown our yOUF^ fy atnemeat. Payments will be applied as follows: First to nalle l ieeriud but unpaid Finance Chaps: Second, to nut unpaid Adminlstrative Credit insurance Chaged; and Fourth, toktheeunp id OutstanI* any ding balance of your Aoceum. Any part of your monthly payment to be applied to amounts borrowed an yaw Account will be applied to the emourns borrowed under your Potential Credit Line Account In ties order in of yew monthly payment ANNUAL M. You agree to pay an Annual Foe es stated on yap one for parUtipation in this revolving credit Nan:, The Initial Annual Fee Is stated yp??gee ens and I. due sad payable on 1M dale that your Account is ?j>blTehed, and the subsetfrsnt Annual Fee stated on pate one is due and H on the sane day of Oak mdlvsgisnt year. You wee that this fee i4y be Charged to yaw Ateount balance. BAD CHECK CHARGE. If you pay by a Cheek which is returned for any reaelm, you will pay a bed check sharp of $20. LATE CHARGE. 11 low do not pay any reOred Minimum Monthly Psyaent within 10 days abler it is dw, you pprre 1p WY a lea Charge of 10% of the Mlnimwn Monthly Payment due Of sIO, srhiehevar is greater lexelumng any unpaid late Charges and am- due treat plot billing cyolesi. 0THS11 CHANGES, You also agree to eery tom' sessions actually incurred by Lander for services rendered In ewoool" with The Pwsonml Credit Line Account for f•" paid to faMIC offiaiale In conreallso with recording, ro"Ing in satisfying a security interest in the security. You ogres that drso fees may be detailed to your Aesoui balance. 6%CHANOE OF INFORMATION. You mdw*lmd that halm tone to time we may receive wain Information eomeen)ng you from others, such as states, other lend I. and Credit i"401ni agencies. You sUthoriaa on to shoo any 1011 tiro an a r•gWW bgis. we obtain related to your ; Aoodum, Including Mort cot limited W. credit reports and Wwomm lnfermotion, with any of our affiliated oojyeratfena, rdbehowles at allow third pwtlo& The uses of this Inlormatiea my Include on inquiry to determine if you qualify for sdditiottlll offers of credit you also Pathorl" us to there arty UlrNtati n r Ins yaw Account with say of our offillsted corporations, Subsidiaries or olhw third parties. Tao may premblt the skewing of seek Idermallia (*most for tea skwlas of la/atbotlae at*$ tralseweas at otyarfescap betwaes a cod yao) by "edieg a trill" repeat wild catalas veto foil ism, 36061 searlty ember ace .%"Mae to as N P.O. not 11147, cNsepeski, VA tests. which the arnomts wee berrowe0 i11 applied in the same manner. iw repot to be applied to Finwielb Charges If you fall to fulfill Use ttoms of your credit obligation. a regal MINIMUM MONTHLY PAYMENT. The Minimum Monthly Palwuon far any rieflectleg wt your credit resod my be submitted to a Credit Reporting billing cycle will be Ike greater of III the treater of $25 or the Agency. You area that the DePerthhhant of Muter Vehicles for your Variable Payment Amount In described betov4 phi any Admrmsustivs state's equivalent of ales doWt*MIO nay release Yaw reaidtoce addrees Charges and ocedlt usratta charges, rewedad to the morost $I; or Ili to us, shoed it became nooNary to leeste yon. Yew agr" that w Nary personnel may listen to tols1*000 "Its between yon and our the Ckhr"q a sa morose due for the billing is cycle The ales anu Adidhiskir"t ! w vlntivN in wow to evafwa the quality of ow service to Vow sill credit Insurance ohargee; of i71 wr' of tlialAiw?a4 ubtji F" **""ad to yew Adew". In Oath instance to Minim ATIbN No tNANOEi NI IN AGulkiliIT. we Celt Chocp tic terms of this Payment will be edjested to include any unpaid amefblts t; PPS, Iotlolles lemasles Vow k wmoi Ilerly Raywost and ucresalae d o"` f i preview billing Cycles. iYrsiwl two or Ffaasce charge. 04414 on oea l lea "tier has If r u?sk ,j?gg The Variable Payment Amount depends on the monthly pMlpdrR 7ASah r. rs11u1 by aspllceme low, at caesge as 'Variable gals lases, at say Iles. Rrlar *flow sod%$ will be provided to yon wbe• rgalrwd by appicabls low than applicable to your Account, and Is ealeulPted eo foltewa pless yes consent to the ckoap ball that this. Cb"get may apply Is beta Mostbly Periodic Rata variable Faywat Assent caw as astounding belea v aloes "lolled by swIcobl• low. However, lermination of VOW eredit limit will ecw Hwy as provided in the "Default lhrougb 1.77% 1.43% of Account balance and Cancellation of AgrOwmsnlI parefrapk. Balances outstanding under this over 1.33% through 1.45% 1.06% of Account balance AgrPPPnet wren the credit Held in reduced or terminated will Cool) me to over 1.45% through 1.57% 1.07% of Account Balance soorwe Interest at the variable Contract rani well) paid in lull. ever 1.57% through 1.70% 1.00% of Account Balance avow 1.70% through 1.117% 1.t3% of ACSwm Balance" evr, 1.51% through 1,95% 2.00% of Account Boluncj?.' ..,? over 1.fO% 2A11% of ACCOynj' ? i MiC FINANCE CHARM. The FiftSWO Chop Is the IFAWNSt Charged 0en41 balance of your Account during each billing Cycle. The Pinanaa,fcnaaay Calculated from the data that each advance, chock or charge 10 ,9081 Cycles. reclulfe Vow Account. The Finance Cher" Is compiled by multiplying 1M aYrdf daily balance in year Account in each billing eytle times tM melPlh periodic rate. The average daily balance is dOtwmined'Qpyy t??a l daily unpaid balances In each billing cycle and d1vi9I ' Y11 tq[yl t number of days in that Cycle lout not Ins than 70t. i! i is the amount owed each day, excluding any fP Administrative Charges, and credit Insurance clwgsa er 1* ?"6111i you to pay yew abMT OF Pwa ?? othher wiouv 0 tit@ right but Unpaid Corps Ansn•diately and fie cweal your credit oivilops under this Aorcement .bseouse of W failure to make My payment in full when it is dw under this lliiprownwrt: IM frNaamt oveldr-Isle of your line of credit; Iel f•Ilws " `supply es with any information requested; a sapoying us with misleading, Noise. Incomplete or incorrect htfwmmiem id brooking any of the promises, r rune or conditions Met are contained in thls Agreemord; 1f) the filing of • "Uptay petition by of 4pt+et yep Igl ,the death of any borrower who %Igns this Agreement. After deiook you will pay our cowl coals. reasonable 1.11ded ey Wes lit attorney is not cur "idea rnployad, and other Collection nlsted to tM default, if not prehibflW by syplieable law. You may be reasonable attorm-et son if you p, avail in an aetice against to. In lee event yaw credit privilege is eancollid, we hew the right to convert your Account to a fixed rate •f interest which shall be no higher then the variable contract rime In .float at On time if conversion. VARIABLE RATEYou agree that ttm monthly pariodla rate used In VOldl MILLING RIGNTS. SEEP TRN NOTICE FOR Fe711111 051. Tbia notice determining your Fi"MA Charge will be a variable role which may rights end Lander's change from month to month The menthly periodic rate will be contains important infotmatlon shout Your one•twalfth of the /um of the Prins Rats pigs the number of raspomibilhiss wrier the fair Credit Billing Act. percentage points as stated in the 'Margin' box on pep ore. The Notlfy Leader Is Cass of griefs or BoasMeas i}faet year OIII: if you think yew prints ROI apple Wall to astreetm Journal billing a cycle will business be ue the prime rate bill is wrong, or if you need aware info?mallon about a tronvaction an your published i n"Tea Wal wh period b, an the bill, write Lender on a separate sliest at the address listed on Vow bill after Horst range of rate any of published. month I n which the billing period begin. If tM words: 'Seed yew billing error notice to (Lander's mime and addroesl." publication the a rang of rates is change In wen use to hiuMat ol the rates In Write to Lander as soon as possible. Lambert must or from you no later the range. Whoa change the Paine Rate is first'de, a change st 00 days after Leader see you the fjrst bill on which the error or the monthly periodic rote will eke edoff" on the ublishay',ol tIR?'ffr ISnh ed. You can telephone Lender. bet doing to will not preserve complete billing cycle following the date o) IM published k?k son appeals your Inter, give Lender tea following Info?matien w Vow now rate will apply to new ioeru @00 ehrgea.' and to and account ruamw 41 The dotter amount -of the suspected after been" of vow eeeeunt. ' • • yu ^1} biribe the error and explain, If you Can, wpw you bellow there is an error. The initial monthly w1odle rota on your Account is whowh anj? 1. yeii need mare Inferms110% describe the Item you are not sore about. Cie. The monthly periodic rate will not exceed Abet parmllt year aislb sod LessaYa MPS•entfblHMaa Ahw lacier faceless ysat Vilifies ruling or law. If Circumstances song ate Itnanp in the law, any cwt Notice. Leader moat acknowledge your 16114 within 30 days, unless Lander continue or se at this variable eti rate of index, we ea wet permit us to has corrected the error by thee. Within; 00 days, Leader must either continue we he this * set rate index, " will change the index correct tits error of explain why Landow believes the bill was correct. according to the pr"odwe set ow below In Termination and Changes in 1M AgreameM." An increase in the Prime Rata may increase the Amcet Percentage Rate Icriesponding to the monthly periodic rata) and the minimom payment on you account NOTICE: SEE THE FOLLOWING PAGE FOR ADDITIONAL. PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. PA056672 VII N "C01C70F00090RLA7000PA056M0"h ORIGIN% Fe ,rt,aEiylY y? 0 ?M i h ux lift alt} ?JT Personal Credit Line Account Agreement (Page 3 of 3) After Lender receives your letter. Lander cannot try to collect My s"no"t YOU quomia"' or r,,. you es delinquent. Lender ash confines to bill you to the amount you question, including finance sharges, and Lender can apply any tmeald amount "Watt year credit limit. You do not be" to pay any questioned while Lender is Inwest(gatkhg, but you we still obligated to pay the owls, of your bill thin we net in gnestloe. Of under finds thin Lender nhsde s misteko on Your bill, you Will r1q3_¢gV0 10,pay any finance ahrga¦ related to any qusstlened amount. If Lend" did not make a mistake, you may hove to pay finance ehwse¦, and, stf hwe41t0. wake up any missed Payments on fen questioned wnount. In either d case, Lender will send you a statement of the smounf You p If is due. ?` a p delinquent. Hower", if Lender's etnplanstiaa does not amisfy you If you nail to pay the amohant that Lender thinks you owe, Li!i lrlnRya.. _ Conner neaten loll anyeee Lander I"*"$ you to the You love a and You write to Lender within ton days felling Lender thin you .NUI O OeY quo¦tion about yew bill. And Lewder must tell ym the home Ot rewl;l you to Lender must tell anyone Lender reports you to that the ,letter has been settled between us when It finally is. 11 1~ doesn't follow those rules, Lender can't collect the first $50 of the questioned @mount, wee if your bill was tweet. ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDER The t¦rms of the Arbitration Agreement end any other Riders signed as part Of this lean tromeoian we kworpwMed into this Agreement by reference. APKICA6ILE LAW. The terns and conditions of this Agreement will be governed by the prwisiota of the PwwnsylvsMs Con~ Discount CoMPOW Act, Cheer 7, Sections 6101 three" 6131, Purdah's Pannsylvenie Statutes Annotated particularly Small*" 6117.1. Before ss ning this Agreement, you have reed afid eeft ' iml this Agreement and the Federal Truth-in-Landing disclawries contsia en 21. ?f You, the customer(s) signing below", ogres to obselrve 11?e tronditions of this Agreement. This {can is governed by the Pennsylvania Consame>; itlo 11M disipanr Loan Act and applicable Federal law. t . (SEAL) ustoster Signature Customer Signature (SEAL) Data. 49-11-to J Data a ?lk :1' .?p'?,iflF° r (SEAL) ` Yjl...l I. 'htta?islttl Cit. 03-01-00 RL VR RE t? ?1 p?!!r K000C70F00060RLA7000PAOSS9730YeCRIOER It ORIGINAL PA056673 (Page 1 of 1) LOAN "CLt 9*0'STATEM ENT REVO01NG LQAN VOUCHER F. CREDITOR HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY 25 GATEWAY DRIVE GATEWAY SQUAREISUITE 107 MECHANICSBURG PA 17055 BORROWERS LOAN NO. 713303-06-136841 CRIDER, JEFFREY A r 825 S HOMER ST ENOLA PA 17025nx. t Borrowers agree to and direct the disbursements and Advance indicated below. If anY estimated amount shown below varies from the actual amount paid. Borrowers agree to the disbursement of the actual amount and a corresponding change to the Advance shown below. Borrowers agree that this Advance is made under Borrowers' Revolving Loan Agreement (account number shown above.) 5D.00 Inltlal Annual Fee ............. ..• .•.••.•••.•••••.....' . . . . . . . . . . . CASH OR CHECK TO BORROWER...... ••••..••.•...$ 11950.00 TOTAL ADVANCE(S) ...................... .......................................5 12000.00 Y_ r .s" l?1?®??11?t??1?N111??M1N11M????l?l ft Vmdwr "COdG1QF00a9DRLV7000PA1?79210k"fRJQER ' GRiGi1tl1L PA 137921 A ARBITRATION RIDER 1.16ited States This Arbitration Rider is signed as part of *?6ur ?Wslen ant with Lender and is made a part of that Agreement. By signing this Arbitration Rider; ypu agree that either Lender or you may request that any claim, dispute, or controversy (whathdr`baW upon contract; tort, intentional or ollhaiwise; constitution; statute; common law,, or equity and whethb -pre isSm Present, or future), including initial claims, counter-dell s, cross-claims, and third-party claims, arising from or relating to ft Agreerent or the relationships which result from this Agreernent. Including the validlty or enforceability of this arbitration clause, any part thereof or the entire Agreement ("Claim"), shall be resolved, upon the election bt you or us by binding arbitration pursuant to this arbitration provision and the applicable rules or procedures of the arbitration administrator selected at the time the Claim is fled. The perry initiating the arbitration proceeding shall have the right to select one of the following three arbitration administrators: the American Arbitration Association ("AAA"). National Arbitration Forum ("NAF") or JAMSJErdlspute ("JAMS'). The arbitrator shall be a lawyer with more than ten years experience or a retired or former judge. The arbitrator shall be independent of and unrelated to you or Lender. Notwithstanding any language in this Arbitration Rider to the , tion may be administered. without the consent of all parties to the arbitration, by any In piece a formal or informal policy that is inconsistent with and purports to override .tile tim.of this `Arbltration Rider, Inducting the Class Action Waiver Provision defined below. The rules and fbrrno of the AAA, NAF and JAMS may be obtained by writing to these organizations at the addresses anchor welbsdes listed below. Our address for the service of process under this provision is: P.O. Box 279, ML Prospect, ' 60056. Any participatory arbitration hearing that you attend will take place in the city nearest to your residence where a federal district court is located or at such other location as agreed by the parties. If Lender fibs a Claim, Lender shall pay all She 016g costs. If you go a Claim, ding costs and administrative fees, (other than hearing fees) 6WIllebe"peld as follows: (a) you agree to pay for the initial cost of filing the Claim up to the maximum amclOk. f $100.00; and (b) if required by the ad*ation administrator's rules, we will pay for filing costspaac r $400.00 and for any administrative fees charged by the arbitration administrator on any Claim Miy you up to a maximum of the amount of the firing costs and administrative fees that "Ir the arbitration administrator for a Claim equal to your loan amount. Any filing costs., assessed for a Claim in excess of your ban amount shall be paid by yov. Th8 d one fim they of arbitration hearings. Fees for hearings that exceed one day nesting party. We shall each bear the expense of our respective attorney's fees, except as otherwise provided by law. If a statute gives you the right to recover any of these fees, or the fees paid to the arbitration administrator, these statutory rights shall apply in the arbitration notwithstanding anything to the contrary herein. If the arbitrator issues an award In our favor, you will not be required to reimburse us for any fees we have previously pad to the arbitration administrator or for which we are responsible. This Arbitration Rider is made pursuant to a transaction invoMng interstate commerce, and shall be governed by the Federal Arbitration Act, 9 U.S. C. Sections i •16 (the "FAA"). The arbitrator shall apply applicable substantive taw consistent with g taws concerning reception, rejection, and consideration of evidence and shall pmai flndirtgs of fact and conclusions of law. The arbitrator's award shag not be sybject t ;`permitiujd by the FAA. For Cisirns where there is an appebt fight under the FAA, any party award to a three-arbitrator panel appointed by the Administrator, which will reconsider tls-novo h.e. in its enfrety) any aspect or all aspects of the initial award that is appealed. The panel's decision will be final and binding, except for any appeal right under the FAA. Judgment upon the award may be entered in any court having jurisdiction. All statutes of limitations that would otherwise be applicable shall apply to any arbitration proceeding. 10111/2005 09:33 ao t of 3 0111LEOS • coac7oraooa - go - XAR 7- 000 - 0111LE . z - 1- 0 •• GROER 11 ORWGINAL ?r RIDER A i w *- A r, We agree not to invoke our right to arbitrate an individual Calm you may bring in Small Claims Court or an equivalent court. V any, so long as the Claim is pending only in that court. No class actions or private attorney general actions in court or in arbitration or joinder or consideration of claims in court or with other persons are permitted in arbitration wftut the written consent of the parties. The validity and effect of the preceding sentence (herein referred to as the "Gass Action Waiver Provision') shag be determined exdtisively by a court and ,not 4y administrator or any arbitrator. N r the administrator nor any arbipralor shall have 'tl p Ivor .authority to wage, modify or fail to enforoe the Gass Action Waiver Provision, and any attempt 1o?do ?o, whether by rule, policy, arbitration decision or otherwise, shall be invalid and unenforceable. The arbitrator shag be empowered to I a l0 s rind to take such other aCtiorls as the arbitrator deems necessary to the same extern by a judge pursuant to the Federal Rules of Civil Procedure. This Arbitra8on Rider shall survive repayment of your loan andlor termination of the Agreement If any portion of this Arbitration Rider is deemed invalid or unenforceable under any law or statute consistent with the FAA. it shag not invalidate the remaining portions of this Arbitration Rider of the Agreement. However, If a determination is made that the Gass Action Waiver Provision is unenforceable, this Arbitration Rider (other than this sentence) and an prior Arbitration Rider ??aad void. I he event of a conflict or Inconsistency between the rules and pracedun and this ArbitraWn,Rider, this Arbitration Rider shall govern. tration Rider shall limit the right of any exercise of No provision of, nor the a" :wry or preliminary remedies, judicial or party during the pendency of any: Clad,; or foreclosing upon any property of realng otherwise, for the ia involved in any Claim or subject to the loan . The use of the courts shah not constitute a waiver of the right of any party, Including the plaintiff, to submit any Claim to arbitration nor render inapplicable the compulsory arbitration provisions contained in this Arbitration Rider. THE PARTIES ACKNOWLEDGE THAT THEY HAD A RIGHT TO LITIGATE CLAIMS THROUGH A COURT BEFORE A JUDGE OR JURY, BUT WILL NOT HAVE THAT RIGHT IF EITHER PARTY ELECTS ARBITRATION. THE PAR1ilES HEREBY KNOWINGLY AND VOLUNTARILY WAIVE THEIR RIGHTS TO LITIGATE SUCH CLWN3' I Ali1R'f? BEFORE A JUDGE OR JURY UPON ELECTION OF ARBITRATION BY ON , You may contact, obtain the arbitration noes of+ `file a Claim with AAA, NAF or JAMS as follows: «brum (NAF) JA American Arbitration Association„ JA A MSIEndispute 13E Street NW 335 Madison Avenue Pk. 81 New York, NY 10017 Minneapolis, MN 55405 Suite 400 West 22 -adr.ora www.arb-forum.om Washington, DC 20004 Arbitration ra Rules for Consumer Code of Procedure ww-"Mill Related Disputes (claims under $10,000). Arbitration Rules (all other claims). 10111/2005 09:33 Page 2 of 3 ?r?rrsrrr®r?r??rirrt®,®rrrrrr?? C04C70F000 - W - XAR = T!4ooD o111 LE - Z - 2.0 " CROER " ORIGINAL Financial Services Arbitration Rules and Procedures 0111 LE06 Y x, *+ i w ARBITRATION RIDER United Status ®"'rl-,DS Date: FFREY A. CRIDER Prim Name HOUSEHOLD FINANCE U R DISCOUNT COMPANY Data: i By: ?"rv 10/11!2005 09:33 Page 3 of 3 • CD4C700= Q - 96- XAk Z - 3 - 0 •' CRIOER A ORIGINAL Y 0111LEDO VERIFICATION The undersigned, Gregg L. Morris,' ereby, states that he is the attorney for Plaintiff in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. Counsel has signed the verification at the request of Plaintiff as a matter of time and convenience. Plaintiff has represented to counsel that there is a debt due and owing from Defendant to :Plaintiff in the amount as set forth within the foregoing pleading. Plaintiff has provided'-cotn sel with all relevant information in order to allow counsel to sign this verification. Plaintiff agrees to provide a verification signed by Plaintiff upon request by Defendant. The statements are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: February 11, 2009 )?M //r Esquire Patix, A.P.C. 213 et GrePgiA15106 Car(41 PA 0 1 Atty Verification P&F File No. 08-95575 ?° ? a # ? o0 €-? ?.? S -a b ''' O D -?:? - •.? s r C; i "`_ lL.? ?.C7 °e` SHERIFF'S RETURN - REGULAR CASE NO: 2009-00950 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER DIS VS CRIDER JEFFREY A NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CRIDER JEFFREY A the DEFENDANT , at 0019:24 HOURS, on the 19th day of February-, 2009 at 825 S HUMER ST ENOLA, PA 17025-0294 by handing to JEFF A CRIDER DEFENDANT 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: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 14.40 .00 10.00 R. 'Thomas Kline .00 42.40 02/20/2009 PATENAUDE & FELIX By: day Deputy Sheriff A. D. N ._.. -.rte IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff NO. 2009-00950 V. JEFFREY A CRIDER Defendant(s) PRAECIPE FOR, DEFAULT JUDGMENT Filed on behalf of: HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_119 Prcp Def 3g Both P&F File No. 08-95575 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Plaintiff NO. 2009-00950 V. JEFFREY A CRIDER Defendant(s) PLAINTIFF'S PRAEECIPE FOR DEFAULT JUDGMENT TO:PROTHONOTARY Please enter a judgment against the defendant, above named, for failure to file an Answer to Plaintiffs complaint. Amount claimed in Complaint Interest from July 07, 2008 Less payments received Attorney's fees TOTAL $14,358.85 $2,058.37 $0.00 $1,400.00 $17,817.22 With continuing interest on the principal amount of $17,817.22, with interest at the legal rate, plus costs of suit. I hereby certify that a written notice of intention to file this praecipe was mailed to the defendants and defendants' counsel (if known), after the default had occurred and at least ten (10) days prior to the date of the filing of this praecipe. A copy of the Notice is attached. & Fix, A.P.C. Date: March 23, 2009 Gre g L. Morris, Esquire 21 E. Main Street C egie, PA 15106 ( 2) 429-7675 PA_119 Prcp Def Jg Both P&F File No. 08-95575 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Plaintiff V. JEFFREY A CRIDER Defendant(s) COMMONWEALTH OF PENNSYLVANIA PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA RC P 1037(b) COUNTY OF CUMBERLAND SS. NO. 2009-00950 Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared GREGG MORRIS, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and states that the defendant(s), JEFFREY A CRIDER, is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that Notice of Intent to take Default Judgment was mailed in accordance with Pa.R.C.P.237.1, as evidenced by the attached copy. Respectfully submitted: Patenaude & eli , A.P.C. Date: March 23, 2009 Sworn to and subscribed before me this -,:Q?day of , 201 Notary Pub is Greg . Morris, Esquire 213 . Main Street Car#egie, PA 15106 (41#) 4294675 COMMONWEALTH F PENMYLVANiA Seel C&M" J. SIPAWt, Nobly PuNNc 0"19 Bm, AA OwW County PA- 120 Aff of Non * 1 E*k Bs At9.14, 2011 P&F File No. 08-95575 AAember, Pennsylvania Asaodation of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff NO. 2009-00950 V. JEFFREY A CRIDER Defendant(s) IMPORTANT NOTICE Filed on behalf of: HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_113 10 Day Dl D2 P&F File No. 08-95575 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff NO. 2009-00950 V. JEFFREY A CRIDER Defendant(s) To: JEFFREY A CRIDER 825 S HUMER ST ENOLA PA 17025--294 Date of Notice: March 12, 2009 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 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 NOTICE TO A 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 South Bedford Street Carlisle PA 17013 717-249-3166 Date: March 12, 2009 PA_113 10 Day D1 D2 P&F File No. 08-95575 I, GREGG MORRIS, attorney for Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. , hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Jeffrey A Crider 825 S Humer St Enola PA 17025--294 Date: March 12, 2009 PA_113 10 Day D1 D2 P&F File No. 08-95575 FUD-OffU OF THE WDTH. T 2009 APR -2 PM 1: 4 1 CUM S{"_ uNI10 c uffrY POMYLVAMA *4 - oo .0 Prr1 cc 3898 ? wr # No4jve oo?j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Plaintiff NO. 2009-00950 V. JEFFREY A CRIDER Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix;, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_123 Ntc Jgmt Both P&F File No. 08-95575 J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff V. JEFFREY A CRIDER Defendant(s) NO. 2009-00950 NOTICE OF ORDER. DECREE OR JUDGMENT AGAINST JEFFREY A CRIDER ONLY TO: ( )Plaintiff ( x )Defendant ( )Garnishee ( )Additional Defendant You are hereby n tified that the following Order, Decree, or Judgment has been entered against you on a o ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( X ) Judgment of ( ) Confession ( ) Verdict ( ) Court Order ( X) Default ( ) Non-suit ( ) Non-Pros ( ) Arbitration Award ( X ) Judgment in the amount of $17,817.22, plus costs. ( ) District Justice Transcript of Judgment in the amount of $ , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotary By , 2--,- a" 'e-6 ? ? ? - 107 t44?? ?_ / If you have questions concerning the above, please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 PA_123 Ntc Jgmt Both P&F File No. 08-95575 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Respondent/Plaintiff NO. 09-950 vs. JEFFREY A CRIDER Movant/Defendant SUGGESTION OF BANKRUPTCY COMES NOW the Movant/Defendant, Jeffrey A. Crider, (the "Debtor"), through the undersigned Counsel, and would show the Court: 1. Debtor filed a petition for relief under Title 11, United States Code, in the United States Bankruptcy Court for the Middle District of Pennsylvania, Harrisburg Division, which bears the case number 1:09-bk-02446-RNO 2. Relief was ordered on March 31, 2009 3. This action is founded on a claim from which a discharge would be a release or that seeks to impose a charge on the property of the estate. 4. This is for informational purposes only and does not constitute a notice of appearance by the undersigned Counsel. WHEREFORE, Defendant/Debtor respectfully suggests that the action pending before this court is barred by operation of the automatic stay provided by 11 U. S.C. § 362(a) and requests that Plaintiff s complaint be dismissed. Respectfully submitted, Law O ce f Brian J. Tyler Brian . yler, Esquire ( PA77958) 3621 'North Front Street Harrisburg PA 17110 (717) 230-9900 Bankruptcy Counsel for Debtors Date: April 3, 2009 CERTIFICATE OF SERVICE I, John Jacob Laughman, Assistant to Counsel, with the Law Offices of Brian J. Tyler, hereby certify that a copy of the foregoing Suggestion of Bankruptcy was served by first-class U. S. Mail, postage prepaid, on the following, on this day as noted below: Patenaude & Felix, A.P.C. Gregg L. Morris, Esquire 213 East Main Street Carnegie, PA 15106 LAW OFFICES OF BRIAN J. TYLER By: (?? J0'4ohn nl? n Date: April 3, 2009 IN THE COURT OF COMMON'PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff v. JEFFREY A CRIDER Defendant(s) NO. Oq - 9 50 0',vilTerw ) ) - ? ?Y",?, 1 iS .4 G` eGr4 PF_PA._1 I CmPlt Cvr Sht COMPLAINT IN CIVIL ACTION Filed on behalf of., HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 t7 F11- ? : OWL COPY FROM RECORD *4 COUNI Q"*. ft. P&F File No. 08-95575 United States Bankruptcy Court Middle District of Pennsylvania Notice of Bankruptcy Case Filing A bankruptcy case concerning the debtor(s) listed below was filed under Chapter 13 of the United States Bankruptcy Code, entered on 03/31/2009 at 10:57 PM and filed on 03/31/2009. Jeffrey Alan Crider 825 South Humer Street Enola, PA 17025 SSN / ITIN: xxx-xx-6510 Penny Lea Crider 825 South Humer Street Enola, PA 17025 SSN / ITIN: xxx-xx-2990 The case was filed by the debtor's attorney: The bankruptcy trustee is: Brian J. Tyler Charles J. DeHart, III (Trustee) Law Offices of Brian J. Tyler 3621 North Front Street 8125 Adams Drive, Suite A Harrisburg, PA 17110 Hummelstown, PA 17036 717-230-9900 717 566-6097 The case was assigned case number 1:09-bk-02446-RNO to Judge Robert N Opel. In most instances, the filing of the bankruptcy case automatically stays certain collection and other actions against the debtor and the debtor's property. Under certain circumstances, the stay may be limited to 30 days or not exist at all, although the debtor can request the court to extend or impose a stay. If you attempt to collect a debt or take other action in violation of the Bankruptcy Code, you may be penalized. Consult a lawyer to determine your rights in this case. If you would like to view the bankruptcy petition and other documents filed by the debtor, they are available at our Internet home page http://www.pamb.uscourts.gov/ or at the Clerk's Office, U.S. Bankruptcy Court, Ronald Reagan Federal Building, PO Box 908, Harrisburg, PA 17108. You may be a creditor of the debtor. If so, you will receive an additional notice from the court setting forth important deadlines. Terrence S. Miller Clerk, U.S. Bankruptcy Court Mg Ail -6 Pi"I 13 - G 1 T r v+V..; ? kJrtr v????. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Plaintiff NO. 2009-00950 V. JEFFREY A CRIDER Defendant(s) PRAECIPE TO STRIKE JUDGMENT Filed on behalf of. HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA- 158 Praecipe for Appearance P&F File No. 08-95575 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT CO Plaintiff V. JEFFREY A CRIDER Defendant(s) NO. 2009-00950 PLAINTIFF'S PRAE M TO TRI F JUDGMENT TO: Prothonotary Please strike the Judgment that was entered on or about APRIL 2, 2009 in the matter captioned above due to Defendant's Petition for Bankruptcy filed at Docket No.1:09-BK-02446 , filed in the MIDDLE District of Pennsylvania . Thank you. Sea: A.P.C. Date: April 08, 2009 1/g . Morris, Esquire 3 Main Street egie, PA 15106 2) 429-7675 PA- 158 Praecipe for Appearance P&F File No. 08-95575 I, GREGG MORRIS, attorney for Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. , hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Jeffrey A Crider 825 S Humer St Enola PA 17025--294 Date: April 08, 2009 , Gregg orri , Esquire Paten rZdle elix, A.P.C. 213 Mai Street C egie, A 15106 (41 ) 4 -7675 PA-65 Certificate of Service P&F File No 08-95575 FIL -t? =tuE OF THE PR`°-MIONMARY 2009 APR 14 AM 10: 2 4 Ml1/GW4.. 1 f J j ++'( ' i , LINTY 48.m pa ATr4 M* 3AS99