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09-1487
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. AMBER CONNORS Defendant NO. 09 - 1487 aly ; l-Fc-m : CIVIL ACTION -LAW NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE--T4fIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CAN NOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 Document #: 180057.1 EN LA CORTE DE ALEGATOS COM UN DEL-CONDADO DE CUMBERLAND, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES NO. CREDIT UNION, Plaintiff VS. AMBER CONNORS Defendant CIVIL: =10N -LAW AV I S O PARA DEFENDER Conforme a PA Niue. 1018.1 USTED HA SIDO DEMANDO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defenses o objeciones a las demandas puestas en contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Ustedpuede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACI6N ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland County Bar Association 32 S Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 Document #: 180057.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLQYEES CREDIT UNION, Plaintiff VS. AMBER CONNORS Defendant NO. 0,?_ 1y,07 ?'rv=( Te - CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Van Eck & Van Eck, P.C. and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the-Gommonwealth of Pennsylvania with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Amber Connors, is an adult individual with a last known address of 1 A Umberto Avenue, New Cumberland, PA 17070. 3. Defendant is, and at all relevant times material hereto has been, the primary loan applicant. 4. Defendant applied to Plaintiff for a loan for the purpose of purchasing a motor vehicle. 5. The loan application submitted by Defendant was approved by Plaintiff and Defendant signed a Loanliner Advance Proceeds Check for the purchase of the vehicle. A true and correct copy of said Loanliner Advance Proceeds Check is attached hereto, incorporated herein and marked as Exhibit "A" Document #: 180057.1 6. Pursuant to the Loanliner Advance Proceeds Check marked as Exhibit "A", Defendant agreed to the terms-and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (hereinafter referred to as "Contract"). A true and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 7. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms and conditions of the Contract marked as Exhibit "B". 8. Various charges and payments were made by Defendant on the account. 9. Plaintiff provided a letter to Defendant stating that the vehicle purchased by Defendant was deemed repossessed. The letter further advises Defendant that unless payment in full was made on the outstanding loan balance, the said vehicle would be sold at a public sale and Defendant will be responsible for any resulting deficiency. 10. As a result of Defendant's failure to cure the default in payment, and pursuant to state law remedies, Plaintiff sold the vehicle at public sale. 11. Plaintiff provided a letter to Defendant indicating that there was a resulting deficiency after the sale of the vehicle. 12. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 13. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 14. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. Document #: 180057.1 15. Despite Plaintiff s reasonable and repeated demands for payment, Defendant has failed, refuse&6and continues to refuse to pay all sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. 16. As of March 9, 2009, the balance due, owing and unpaid on Defendant's loan account with Plaintiff is the sum of Fourteen Thousand Five Hundred Fifty-two Dollars and 81/100 ($14,552.81). 17. Pursuant to the terms and conditions of the extension of credit contained in the Contract, Plaintiff is entitled to receive and. Defendant agreed to pay an annual interest charge on the principal loan balance. 18. Due to the default of the Defendant and pursuant to the terms and conditions of the Contract attached as Exhibit "B", attorney's fees in the total amount of Two Thousand Three Hundred Fifty Dollars and 56/100 ($2,350.56) have been added to the account. 19. Any and all conditions precedent to the bringing of this action has been performed by Plaintiff. 20. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. Document #: 180057.1 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Amber Connors, in the amount of Sixt®en Thousand Nine Hundred.1tree Dollars and 37/100 ($16,903.37), plus interest, the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, VAN ECK & VAN ECK, P.C. By: _ a q '?? i Melissa L. Van Eck, Esquire Attorney I.D. No. 85869 P.O. Box 6662 Harrisburg, PA 17112 717.540.5406 Document #: 180057.1 VERIFICATION I, Gregory R. Diffenderfer, Manager of the Pennsylvania State Employees Credit Union verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Pennsylvania State Employees Credit Union By: v Title:] tltr t4? d:a Date: 6 r q '09 B IT CONS t ,i Ah? ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT MEMSEti NAME' = y-' AMBER CONNORS 811 VALLEY STREET ENOLA PA 17025 TRANSACTION OPEN-END TYPE t ? NEW LOAN 2 [I LOAN ADVANCE 01/18/2007 0 IPOS • DEALER PURCHASE OTHER g 3. ? (OESCRIBE7 4. EQ?UITY ADVANCE I i Pennsylvania Sta e Employees Credit Union R 0. Box 67013 Harrisbeq, p}E" 17106-7018 - 717.234.8484 80(T.2v.7328 0005890881 YOU HAVE PREVIOUSLY ELECTED TO HAVE THIS ADVANCE CREDIT DISAMLITY SINGLE CFMT LIFE DIMMED WnHTHE FOLLOWING COVERAGE YES ? NO ? I JOINT CREDIT LIFE YES NOJ YES ? NO DAILY PERIODIC RATE ANNUAL. PER- INTEREST RATE IS AMOUNT AEWESTED PREVIOUS BALANCE (CHANGE IN TERMS ONLY) CENTAGE RATE AMOUNTADVANCE + OTFIEA CHAR(iEs NEW BALANCE FIXED VNVNR.E + --^ • ; : r:: -, .021205 07.740 /0? 22 000 00 : dto t 1 _ , . M:. :• 0.00 za 000.00 PAYMENT DUE DATE PAYMENT FREQUENCY PR OJECTED LOAN TERM 382.98 102117107 MONTHLY MEW SECURITY OFFERED P SIMECKM ADVANCE, THE OWSECUPATY FORTHE ADVANCE E7M REAL PROPERTY W MOST CASES YOUR HOME) V*WH YOU GAVE AS B Fury WHENYOUR ACCOUNr IF THIS IS rYOTA HOME EQUITY ADVANCE. IN ADDITION To THE PLEDGE OF SHARES IN YOUR LOANLINEW CREDIT AGREEMENT THE FOLLOWING PROPERTY SECURES THIS ADVANCE FTEM PROPERTY ,.-^r" EAft:- r .•' :K !!fiJ?i r ..?. . . 1. FORD F150 2001 1FTRW08L31KC43375 TK a 17,455.00 4.OTHER YOU PLEDGE SHARES ANDIOR DEPOSITS OF $ IN ACCOUNT NUMBER OLD ACCOUNTAJ]AN NUMBER A) PAYOFF (PRING+ M47a OLD ACCOUNTAJ?AN NUMBER (S) PAYOFF PRINC. + INT.) OLD ACOOLINTA.OAN NUMBER PAYOFF (PRINC.+ IR:) OLD AGCOt114TA OAN NUMBER PAYOFF (PRM4G + SIC OLD ACCOUNrAJJAN NUMBER (E) PAYOFF PRINC + ANT) OLD ACCOUNTILOAN NUMBER ( PAYOFF (PRM4C, + IIY) try accepting the proceeds or by using the funds advanced and deposited into your share/share draft account, you agree (1) that the property referenced above will secure the advance and any other advances you have now or moelve In the future under the LOANLINER° Credit and Security Agreement (the Plan) and any other amounts you owe us for any reason now or In the future In accordance with the terms of the Plan and (2) to make payments as disclosed above in accordance with the terms of the Plan. QCWMA WMIAL C0101P 18x0, 82, 84.4 08.90.88.2000, 01, 04, 06. ML RIGHTS 1rESSM PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM 03175 JVXX0100.1 037-2M-1 (11108) 0 C? tyR 2LO R) C, (e P N) ? ?-e rit . A . D SECURITY AGREEMENT In this agreement all references to Credit Union, we, our, or us means Pennsylvania registration fees) due on the property. State Employees Credit Union and anyone to whom the Credit Union assigns the Credit Agreement which will be referred to as the Plan. All references to you your and If you do not pay the taxes or fees on the property when due or keep it insured, we may , , borrower mean each person who signs this agreement. All references to the advance mean th t i pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the advance and ou will a e amoun n the box labeled Amount Advanced. This is a multi-state document which may be used to lend to borrowers in all states except Louisiana and Wisconsin y p y interest on those amounts at the same rate you agreed to pay on the advance. We may . 1. THE SECURITY FOR THE LOAN - By signing this security agreement in the receive payments in connection with the insurance from a company which provides the insurance. We may monitor our loans for the purpose of determining whether ou and signature area or under the statement referring to this agreement which is on the back y other borrowers have complied with the insurance requirements of our loan agreements of the check you receive for the advance,. you give us what is known as a security or may engage others to do so. The insurance charge added to the advance may include interest in the property described in the Security Offered section on the reverse side. (1) the insurance company's payments to us and (2) the cost of determining compliance The security interest you give includes all accessions. Accessions are things which are with the insurance requirements. If we add amounts for taxes fees or insurance to the attached to or installed in the property now or in the future. The security. interest also , unpaid balance of the advance, we may increase your payments to pay the amount includes any replacements for the property which you buy within 10 days of the added within the term of the insurance or approximate term of the advance advance or any extensions, renewals or refinancings of the advance. It also includes any money you receive from selling the property or from insurance you have on the . B. NOTICE - If you do not purchase the required property insurance, the insurance property. If the value of the property declines, you promise to give us more property as s it if k we may purchase and charge you for will cover only our interest in the property. The insurance will not be liability insurance and will not satisfy any state financial ecur y as ed to do so. responsibility or no fault laws. 2. WHAT THE SECURITY INTEREST COVERS - The security interest secures the advance and any extensions, renewals or refinancings of the advance It also secures 9. DEFAULT - You will be in default if you break any promise you make under this . any otheradvances you have now or receive in the future underthe Plan and any other amo t l agreement. You will also be in default If you are in default under the Plan, If you are pledging property, but have not signed the Plan you will be in default if an one is in un s or oans, including any credit card loan, you owe us for any reason now or in the future, except any loan secured by your principal residence.. If the property is . , y default who has signed the Plan. household goods as defined by the Federal Trade Commission Credit Practices Rule 10. WHAT HAPPENS IF YOU ARE IN DEFAULT - The following paragraph applies , the property will secure only the advance and not other amounts you owe. to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, 3. OWNERSHIP OF THE PROPERTY - You promise that you own the property or if h Massachusetts, Missouri, A'ebraska, South Carolina and West Virginia. When you are in default and after expiration of any right you have under ap licable state la t t is advance is to buy the property, you promise you will use the advance for that purpose. You promise that no one else has any interest in or claim a ainst th p w o cure your default, we can require immediate payment of your outstanding balance g e property that you have not already told us about. You promise not to sell or lease the under the Plan without giving you advance notice. 3roperty or to use if as security for a loan with another creditor until the advance is The following paragraph applies to borrowers in all other states: When you are in -epaid. You promise you will allow no other security interest or lien to attach to the default, we can require immediate payment (acceleration) of what you owe under the )roperty either by your actions or by operation of law. Plan and take possession of the property. You waive any right you have to demand for t. PROTECTING THE SECURITY INTEREST - If your state issues a title for the payment, notice of intent to accelerate and notice of acceleration. )roperty, you promise to have our security interest shown on the title. We may have The fallowing paragraphs apply to all borrowers. o file what is called a financing statement to protect our security interest from the You agree the Credit Union has the right to take possession of the property without ;laims of others: If asked to do so, you promise to sign a financing statement You judicial process if this can be done without breach of the peace. If we ask, you promise .Iso promise to do whatever else we think is necessary to protect our security interest to deliver the property at a time and place we choose. We will not be responsible for i the property. You promise to pay all costs, including but not limited to any attorney any othe proerty not by this a' tht you the r c n I l d o ses, we incur in protecting our security interest and rights in the property, to the or that s atta hed to the property. We will try to return that p operty t o you or make xtent permitted by applicable law, it available to you to claim. USE OF PROPERTY- Until the advance has been paid off, you promise you will: After we have possession of the property, we can sell it and apply the money to any t) Use the property carefully and keep it in good repair. (2) Obtain our written amounts you owe us. We will give you notice of any public sale or the date after which ermission before making major changes to the property or changing the address a private sale will be held. Our ex enses for takin p g possession of and selling the There the property is kept. (3) Inform us in writing before changing your address. (4) Property will be deducted from the money received from the sale. Those costs may [low us to inspect the property. (5) Promptly notify us if the property is damaged s include the cost of storing the property, preparing it for sale and attorney's fens to the , [oleo abused. (6) Not use the property for any unlawful purpose. extent permitted under state law or awarded under the Bankruptcy Code. The rest of . CONSUMERS' CLAIMS AND DEFENSES NOTICE - The following paragraph u li the sale money will be applied to what you owe under the Plan. If you have agreed to pay the advance you will also have to a an amount th t p es only when the box on reverse side is checked. , p y y a remains unpaid after the sale money has been applied to the unpaid balance of the OTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS advance and to what you owe under this agreement. You agree to pay interest on that UBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD amount at the same rate as the advance until that amount has been paid. SSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED 11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT - We can ?iTH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE delay enforcing any of our rights under this agreement any number of times without EBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR losing the ability to exercise our rights later: We can enforce this agreement against your heirs or legal representatives If we change the terms of th Pl EREUNDE . e an, you agree that this agreement will continue to protect us. PROPERTY INSURANCE, TAXES AND FEES - You must maintain property 12. CONTINUED EFFECTIVENESS - If any part of this agreement is determined by surance on all property that you give as security under the Plan. You may purchase a court to be unenforceable, the rest will remain in effect. I property insurance from anyone you choose who is acceptable to the Credit Union. 13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE - e amount and coverage of the property insurance must be acceptable to us. You jy provide the property insurance through a policy you already have, or through a THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE AND ALL , licy you get and pay for. You promise to make the insurance policy payable to us AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU J to deliver the policy or proof of coverage to us if asked to do so . MAY HAVE TO PAY THE DIFFERENCE. iou cancel your insurance and get a refund, we have a right to the refund. If the 14. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to fail to )perty is lost or damaged, we can use the insurance settlement to repair the return a motor vehicle that is subject to a s it i ecur y nterest, within thirty days after you )perty or apply it towards what you owe. You authorize us to endorse any draft or have received notice of default. The notice will be mailed to the address you gave us. It :ck which may be payable to you in order for us to collect any refund or benefits i i s your respons bility to notify us if your address changes. The maximum penalty for under your insurance policy. You also promise to pay all taxes and fees (like unlawful failure to return a motor vehicle is one year in prison and/or a fine of $150,000. -__THE PsR€ PARTY DESCRIPTION ON THE REVERSE SIDE IS PFITT nF TRIC t?:??Fr?.ftiEt r"rs?t?G• crr_rv ruse nr•rcc?rrc?- ncr ? .? ...... _ .-- Pennsylvania State 'E n n1t8yeersrCrlt'L' : `:' : No. 5890881;1 PoAua»f7 • 7Wa?q, PA 111ai7a17 • p?In77r1111 •VOID?r 1P20 O?! DAYS A ;(l• AUTODRAFT, VdID Ot/ER;f; '22 000'00' REFERENCE• 8094896050 FTEFF.,. 01/1112007. '?!,.• ',MT•TO 1HE. ?. , ?.: 4 ?', ,. ? ?•? ?•i •,. ?/? 1?i ^. •.. ;; r;l?^r atDEti of tIiEALERi ' ?('. ?'i' • j? ;a . a •: ,({?? 91, ??• .. ; i:. fir. ? . /?:.. ,?;r .?: LtJO OC/ ,r `acv -"i'• .% .i.'.. f. . .. .. J - DOLLARS , :. ,. ' ONVOTAR7[: VOID UNLESS DEALER ENDOIIiEAEN7,COAMLETED t ,-O I EAMFII ENDORiElA6NT`.•.. .. ' Bufd-i Or•v 7 a{ef Li: Ul.w d Ur/ Vdi:l..f ti fsrry i?r.ie. p/:w V.IWd i? epdoii0iy Lii i1Yta0rittt IIWe pre. r flr'femu Y.IeA an the nwne slde: ' M nerve 6i PLECU einYiw.C.it ri N :; of Ihi Aref1.!G?u ihi ti/orMy.wNym.neinfenirUen.' :' , . ' ' ''. •• j ` •. r:r.www. Ni'erirn•i1u.r.rr.aa.wuorfi'iwLi:?.?+:.nrirw?:n'? y ''??.v.• r l'?i?F .• • .. ;..y',. ,,',• '.. . r r •M .are d •r Wwr.ntl. TY. AwOrdr ii/.w ei iW r pe.M.r - ?Trr fL/?.7r r Miin.n T.? inai LMieN lire Mechue.: ,.'?.. ' ....e.reww•...e.w, drre. rx..!.:K. r L.M whw.. ei wWdw . nr.•w. ? sy. n.d¦. O Irenrrr•Yy ? rwwi .:7M• e.we O Di:a r;rw..r wr..rrra.Udadsw.:'Sje,:oaya:?ig!.+..fieto+n.r.u?r»;r: 1.1?'r•ewr'13.I•W 0 w.rq 13 ulp ?+r .. nriw..r.i'w.niw..rr.ee•,. r/.•' ?•, n•euiAivi'fY•m?aas. .. ,?, f.. : , ii raw 'f ' hi•robn bdoiw .- - TL• W o 81.3 /'1CCN: 3;7.5-: ,. m:?i li ._iY1Qi?2'=•:.I../' ! ?:.. AMBER CONNORS . 1 o Y? 7 ?i 1? co-Apptipant Endm.m•nt ' NO.CO-APPLICANT'.' i Ea 569088LD'. 1: 23L'38LLL61: 3105756262N, 44. x'0002200000.' II mI 18849 611887 571 fs a m :1z° 110 r a g y¢ {? ALI e ro @ ll a ;s :....T: ~ < 7V 17 : t??? s =3€ er 8g o ~° a i>g tat!: $°.? .it't s-? ? c = (di?71TNf 073f?- 44? = ? t gg ? ?1 ? ° . PHllA. Pp l17? • o . e? ?ec 4' t_ g. f t? ? ?? '!emu:.-_ ?L S!$?i0; a'z=t=11?0?+ F. g3?tt:dE?tt'd e2?sgtsP:?? 4 • y Exhibit "B" Pennsylvania State Employees Credit Union PO. Fca 670113 40 i?ar.•atil:r?, PA 17106.7013 • (1 171 234•8-t84 Harrs;rmrg. 180Q)237-7325 N,ationwme PSECO Loan Disclosures This LOANLINER' Credit and Security Agreement, which ncluccS, the Truth in L(: ndirc iLlsc Sures, wilt be referred to as the Plan The Plan documents include this agreemerl and an Addendum You, your and borrower mean any person who signs illw Plan. Credit union, we. our and us mean PSECJ or an yore to whom the Credit Urnun transfers its rights under the Plan. HOW THIS PLAN WORKS - This is an open-end, multrfeatured credit plan. We ar.tlc,pate that, from tittle to time, you will, borrow money (called 'advances') under It,e Plan. We are not required to make advances to you under the Plan and can refuse a request for an advance at any time. The Addendum describes the dlfferenc typos of credit (called "subacccunts") available under the Plan, the current interest rate tot each subaccuunt expressed as a daily periodic rate and r_orrosponding annual percentage rate and other charges. It may also have other terms and a schedu!e tar determining the pay*nent amounts. CREDIT LIMIT - We nlav. but do not have to, establish a credit limit on certain 5ur.?accounts, it a Credit limit is set for a -,ubacccrum, you promise not to exceed the established credit limit If ycu exceed the credit limit, you promise to repay im:nedtwely the amount which exceeds the credit Gm:t. REPAYMENT - You promise to repay all amounts you owe under the Plan plus Inicmo. Payments are ot.e on the la5r day of the month unless we set a ditlerent day at the time of :an advance. V the Addendum has no payment schedule for a s:rt,accounl, your payment will be determined at the time of each advance. Pnyrnents must include any amount past due and any amount by which you have oxceeded any credit limit you have been given for it subaccount. You may repay all or part of what you owe at any timu without any prepayment penally. Evan if you oiepay, you will still be required to make the regularly scheduled payments unless we agroo In writing to a change in the payment schedule. If you have a joint sh'in:draft account, you will be responsible for paying all overdraft advances ootar;ed by a foist holder of the sharedraft account. Unless otherwise required by law, payments will be applied to amounts owed under the Plan, in the manner the Credit Union choosbs. PLAN ACCESS -You can obtain credit advances in any manner authorized by us. It we a1ow you In use your ATNIIDebit card to access hie Plan, you may be liable for the unauthorized use of y'eut ATM! Doerr card. Yoo will not be liable for unauthorized use that occurs after you nottly us, orally or in writing. of the loss, theft, or possible unauthorauo use- If you believe your ATNVOILbit card has been lost or stolen, rlmedinitey, tr:iorrn the Credit Union by calling or writing us at We telephone number or aridress trial appears elsewhere in the Plan. It the card is used to obtain unauthorized a-wances oire-_!ly from the Plan, your liability wolf nor ex,>eed S50_ It the unauthorized w Thdi nwi, is from a sharedraft account, your liability is governed by the Regulation E di ;IOS,:res you received at the time you ioce ved your ATM/Debit card, even if the witridravnl rasufts In an. advance being made fiort your overdraft subacmunt. ' FINANCE CHARGE -The dollar amount you pay for money borrowed is cal'ed a "hnanCe charge- and begins on the dale of cacti advance. A finance charge will be cornpuhJC separately for each separate balance under the Plan. To compute the fill^.,inte charge, the unpaid balarce for cacti day since your last payment (or since all advance If you have not yet made a payment) is multiplied by the apphcabte daily pareoic rate. The sum of Ihcso amounts is the finance charge owed. The balance used to compete the finance charge is the unpaid balance each day after payments ano crectiis to that balance have been subtracted and any additions to the balance hn•:e been mane. In addition to interest, we may charge other finance Charges which art? dl5clo5ed on the AddeGdurn If the interest rate is a Variable interest rate, the Ao lonrtjm ex•,ilains how The variable rmarest rate works. SECURITY -feu piedge as securay, for the Plan all shares and dvidonds arid, if any, all a :pcs,ts and interest it all fora! And lndividutil accounts you lutve with us now and in 1''11!: "':L'ta. i' a spucd,c: d%,Iar an;uunt IS pleaged for an advance, we will frNizle ilia , !Nil e,ccouII to It..; !xw.rlt o !tie aa!standing balance for the advance. ,o:;r p.vrigi-c shares may .. i.i: , raven unktss you are in default The following paragraph applies In all states except in Ohio, Rhode Island and Massachusehs: We have a siatulor r her, on v,.e shares and dividends and, if any the F sit ;,n d .,wrosi n all n v tia;! arid form accounts you have with us and may cx.rns( :r f ghts under 01C I,e. t.> the e0ent permuted by state lay. {),Ve are state c;r-,v i,,J i name docys ^cI Iricluoe the farm. 'Federal Credo Union') For all I borrowers; The statutory lien and/or your pledge will allow us to apply the funds in your account(s) to what you owe when you are in default. The statutory lien arid a ",? not apply to ar.i le;,,.ICW1 Hetaemenl Accows, or ary olner accorr! use :a e.:,al tai. trcatn;car un.;er stale or lredera' Ian, if y.,fen its security . ..;.:,'_ ... ., _.:n•y'cr the F m.a:v L Q lewa,::red at Ino I'm, of a, ad:ancc. 11 a a rn_ ." Gr:lro i, 's:.xi' as car""') yq'; •u,,'t g v'i It•al ill;: :Cr*J e_ soc_WIy .t Cn 'r ra.t + :Yi: intro ur4"r Ina: ti..DnCrn,.71t. A 1 ani;• 'U,a•. as Y!-, •r ,,_ '..r,,, y.;li nLls' T, ,._ ::11.•...... :: _^i .: t.-.,t ?.. r,,..l '1 J", i. ,:-: ,': I17 ., t ,:i :.. .. 'rn r _ ,.. .., ._ :t. .,i'i a-.;', ,. r•rr_.F::i.,.., ?i4ry i CREDIT INSURANCE - Credit life and'or credit disability insurance is optional under the Plan. 11 you qualify fcr and purchase the insurance from us, you authorize j us to add the insurance pretwunis monthly to your loan balance and charge you i interest on the entire balance. if you elect credit insurance, your payments may increase or the period of time necessary to repay your advance may be extended ? The credit insurance rates may change curing the Plan. If the rates change, we will j provide any notices required by applicable law, PERIODIC STATEMENT - On a regular basis you will receive a statement showing I all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing Unless applicable law requires notice to each joint borrower, notice to any one of you will be nonce to all. JOINT ACCOUNTS - it this Is a joint account, each of you is individually arid jointly responsible for paying Ali amounts owed. That means we can enforce our rights under the Plan against any one of you indmictualty or against all of you together. It you give us inconsistent instructions. we can refuse to follow your instructions. Unless our wvntien polrcy requires all of you to sign for an advance, each of you authorizes the other(sl to obtain advances individually and agrees to repay advances made to the other(s). Any joint accountholder clay terminate the Plan by giving us prior written notice. It any of you terminate the Plan, the Plan is terminated for all of you. You remain liable individually and jointly for all advances incurred before termination. FEES AND CHARGES - It you grve us a security interest in certain types of property, we may charge you a filing fee to perfect our interest in the property. If we do, the amount of the fee will be disclosed to you at the time you obtain an advance. We may also charge you other fees in connection with the Plan. Our current tees are ? disclosed on the Addendum and will be added to your loan balance unless you pay 1 them in cash. UPDATING CREDIT INFORMATION - You promise that you will promptly give us ` written notice it you move, change your name or employment, or if any other information you provided to us changes. Upon our request, you also agree to provide us updated financial information. DEFAULT - The following paragraph applies to borrowers In Idaho, Kansas, Malne and South Carolina: You will be in default if you do not make a payment of the amount required when it is due You will also be in default 0 we believe the prospect of payment, performance, or realization on any property given as security is significantly impaired ! The following paragraph applies only to borrowers In Wisconsin: You will be in ! default it you fail to make a payment when due two times during any 12 month j period. You will be In default if breaking any promise made under the Plan materially impairs your ability to repay what you owe or materially impairs the condition, value, or protection of or our right in any property you gave as security. The following paragraph applies only to borrowers in Iowa: You will be in default it you are more than 10 days late in making a payment. You will also be in default if you do not comply with the terms of the Plan and your lailura to comply materially impairs any property you gave as security or your ability to repay what you owe under Iho Plan. The following paragraph applies to borrowers in all other states: You will be in default if you do not make a payment of the amount required when it is due. You will be in default if you break any promise you made under the Plan or if Anyone is In default under any security agreement made in connection with an advance under j the Plan. You w, i be in default if you die. ftie for bankruptcy, become insolvont, if you make any false or misleading statements ir, any credit application or update of credit ; inloimanor, or +f something happens we believe may substantially reduce your ability to IePay what you owe. You will be in default it any property you 'lave given us as sectrity s repossessed by someone else, seized under a forfeiture or Slmlat taw, or it anylntrap o!se haopi%ns That significantly affects the value of the property or oUl s Culily i. ,0 r - sl ill ittit w•Il! nlse oil in default under the Plan if you are in default under ariy !her loan aqr eiiienl ,vl:11 us ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers In Colorado, District of Columbia, Iowa. Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: When you are in default and after e.paaeon of any right you have i;rider applcable stale law to cure your delaurl. vie can demand Immediate payment of the enter, unpaid balance under the Phan witncut giving you advam"'. tool ce The following paragraph applies to borrowers in all other states except Wisconsin and Louisiana. svr,r. yo; a,e m da'c:,it, •r:e ran require rtnntedlate payment rp!; fir. Cra'i,_rtl if l.r. pnTlro ip,3 d rya arlcC Plan Y^u waive ary right yea 'nave. I' ncnir +nr f).'4) nest, e ct nfi•nt tr> a-.rc r r :. and nols:e of acco!era'ir>n The following paragraphs apply to borrowers in all states except Wisconsin and Louisiana: It t _. ••,a"di'n. 'I ^.,, :.;:I Ccnf:ht:' to Gay in'tjr4..' Uri 'l .,. ,._ •. - - I , ? ,'1 rt.es•n•,:c-ct :7r. it 3^:r .... .. X... Socurity Credit Agreement (continued) LOANLiNER" Credit and ability to erercis^ our right, later. We can entorce this Plan against your heirs or _ A 1, 4- Maul: rate d,sclos?d ,he Addendum if a d rand 'or :rnr:eolace paym nt ' legal represonra wee if we eh.inge the terms et the Plan. you agree that this Pian las he ma,e. )Cur Sh .rE ar rtrr uep ds car, Ce apGII d ti rc s b•Oal you owe , N'IP CC+n:IrUE In ? fOlect US Cis ?r ,...ell " tr. , lee.t .?. .. qty' Vie can .i:si*) canL:15a any other + CONTINUED EFFECTIVENESS - If any pint of thls Plan is determined by a Court ryl::: ' by law •wher, you Urp in •derauit t^ hu uner1,3rceable, the rest w!!i terown in effect. 1r, agee Le Cr, ; l Ur„on has t'rr rvi'r to take possess on o1 ny pr ppr;y y:vGn , NOTICE TO UTAH BORROWERS - This written agreement is a final expression of s ;ecur v under !no Ran, wfhGut judicial process t rhki .an ce done without j me agreement oetween YOU and the Credit Union. This written agreement may not OIe3Ch cf the peace. II we ask. vo i promise tU deliver trio properly at a time and j be ccnlrad?cted by evidence of any oral agreement. place vie choose If the propety is a motor vehicle or boat, you agree that we may i The following is requited by Vermont law - NOTICE TO CO-SIGNER - YOUR obtain a key or Omer device necessary to urfock and operate it. vrhen you are in ; SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE dcfawl We flat rout responsible fur any other property, not covered by late w i FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, e Aye.ement. !hat you leave :rsida the prdpert;r or that is attached to me property Agreement. i , THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU viii try to return that property to you or make it available for you to claim. . After we have possession of the property, we can sell it and apply the money to any The following paragraphs apply !f you give security in connection with an j amount; you ow o us. We will give. you nonce of any public disposition or the date alter advance under the Plan. They apply to borrowers In all states except Louisiana. a which a private disposition will be held. Our expenses for taking possession of arid spring the property will be deducted from the money received from the sale. Those Louisiana borrowers will execute a separate security agreement. Borrowers in other states may also be asked to execute a separate security agreement. crsrs may include the test of sronng the radperty, plcflaring it for sate and attor'ney's THE SECURITY FOR THE PLAN - You give us What is known as a security 1 fr;+s to mil extent permitted under state taw or awarded under Inc Bankruptcy Code interest in all property described in any receipt, voucher or ocher document you 'r'o,i must pay any amount that remains unpaid after the sale money has been applied receive for an advance (':fie Advance°). The security interest you give includes all to any unpaid! balance under the Plan. You agree to pay interest on that ariounf at the accessions. Accessions are things which are attached to or installed in the property saute rate as the advance, or. it applicable, at ine default rate disclosed on tree now or in the future. The security interest also includes any replacements for the Addendum, until that amount has been pafrl property winch you buy within 10 days of the Advance or any extensions, renewals The following paragraph applies only to Wisconsin borrowers: When you are in or refinancing of the Advance. It also includes any money you receive from selling de!ault and attar expratron of any right you have under applicable state law to cute your ( the property or front insurance you have on the property. It the value of the property j m+ent of your outstanding loan balance under the ! uire immediate pa re faull we ma d declines, you promise to give us more property as security if asked to do so. ) y q ! , Pan and seek possession of property given as security. You may voluntarily give the WHAT THE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS property to us if you choose, or we may seek to take possession of the property by - The security interest secures the Advance described in the receipt, voucher or any i µrdtcial process. 11 we repossess the property you agree to pay reasonable expenses , other document you receive at the time of the Advance and any extensions, renewals incurred in disposing of the property. If the property is a motor vehicle, mobile home, or refinancings of the Advance. H also secures any other advances you have now trailer, snowmobile, boat or aircraft, you will else, be required to pay any costs permitted or receive in the future under the Plan and any other amounts or loans, by Seclkln 422.413 of the Wisconsin Statutes You must pay any amount that romaine including any credit card loan, you owe us for any reason now or In the future, unpaid at er the sale matey has been applied to what you awe under the Plan. You except any loan secured by your principal residence. It the property is household agree to pay interest on any unpaid amount at the same rate as the advance, or, if goods as defined by the Federal Trade Commission Credit Practices Rule, the applicable, at the default rate disclosed on the Addendum, until that amount is paid. property will secure only the Advance and not other amounts you owe. 4 1 If the property is located outside Wisconsin at the time of default, vie may take it permitted by the stale where without judicial process f th ro ert i n OWNERSHIP OF THE PROPERTY - You promise that you oven all property you ou will use omise l i t i , o p y possess o e p y, you pr y le proper s to ray f give as security or it the Advance the property is located. the Advance for that purpose. You promise that no one else has any interest in of The following paragraph applies only to Louisiana borrowers; When you are in claim against the property that you have not already told us about. You promise not defau!t, we can require immediate payment (acceleration) of the entire unpaid to sell or lease the property or to use It as security for a Wan with another creditor balance under the Pian.You waive any fight you have to demand for payment, notice until the Advance is ropalo You promise you wilt allow no other security interest of of ir;I nt fo accelerate and notice of acceleration. If immediate payment is lion to attach to the property either by your actions or by operation of law. den,andr d, you will continue to pay interest until what you owe has been repaid at PROPERTY INSURANCE, TAXES AND FEES -You must maintain property the applicable interest rates in effect unless a default rate is disclosed on the nsurance on all property that you give as security under the Plan. You may purchase A.drendum. If a demand for immediate payment has been made, the shares and the property insurance from anyone you choose who is acceptable to the Credit deposits. given as security for the Plan can be applied towards what you owe. We Union The amount and coverage of Ire properly insurance must be acceptable to can also uxerctse any other rights giver by law when you are in default and our us. You may provide the property Insurance through a policy you already have, or j ghts under Any security agreements you have with us through a policy you get and pay for. You promise to make the Insurance policy CANCELLING OR CHANGING THE PLAN - The following paragraph applies payable to its and to deliver the policy or proof of coverage to us if asked to do so. only to borrowers in Illinois: We have fhe right to change the terms of the Plan from It you cancel your insurance and gee a refund. we have a right to the refund. If the by law. Any Change to the required notice Ce g giving any advance me a a to ti after I property is lost or danlzil we can use the insurance settlement to repair the int otter c advance future s. to m charges will apply rave eres or properly or apply it towards what you owe. You authorize us to endorse any draft or The following paragraph applies only to borrowers in Wisconsin: We can check which may be payable 10 you in Order for us to collect any refund or benefits change Me terms of the Plan from time to time in accordance with Section 422.415 Cue under your insurance policy. You also promise to pay all taxes and fees (like ` of the Wisconsin Statutes. You will be notified of any change in terms, An increase registration fees) due on the property ` ir the aaity periodic rate under a variable rate interest rate is riot considered a it you do rcA pay the taxes or fees on the property when due or keep it insured, vie may the Plan, We can cancel the entire Plan or any part of the change in terms o pay these obligatlons, but we are not required to do so. Any money we spend for taxes. Y u P!r-n at any it me. You may canoe? the Plan at any time by giving us prior writer added to the unpaid balance of the advance and you will pay ; insurance will tees err nonce Your ooligation to pay the unpaid balances under the terms of the Plan r may ' o. ide n<. it the carne rate you agreed t0 pay on the ,r d on those nt ere5l enntirues whether you or the credzt union cancel the Plan. except to the extent that which provides pa ?nonts in with tt insurance e from a company y which connection The recut;e your IiaCdity :s limited by Section 4224155 of the Wisconsin Statutes 2 insurance We may monitor Our 'loans for the purpose of determining whether you and { The following paragraph applies only to borrowers in Iowa: We can change the other borrowers have campned with the insurance requirements of our loan agreements I r rc; ?. me Pinn from tune In nine after glvirg you any ;_dvanco notice required by I or may engage others to dc, so. The insurance charge added to an advance may include 1:,,v. . A. c i a ..,,; thd! increasers the rate of `finance charge or caner charge, that ? (1) the insurance compan;%s payments to us and (2) the cost of determining compliance u,crea5.9i OIC amount of your paymenii, or ;hat oth•3rwlse.acvarsely affe-cts existing L;i•li the insurance requirements. If we add amounts fen taxes, lees or insurance to the t a:anres r.dl airily to exlsnng ba ances Onl, f you aline to Ine change cr you use I unpa,a balance of an advance, we may increase your payments to pay the amount j the Plan after receiving nevice that year use of the Plan means Vol; agree the I added within the fern of the insurance or approximate term of the advance cnanye apples to existing halances. i INSURANCE NOTICE - It you do not purchase the required property InSUreince. I q paragraph applies to borrowers in all other stares: We nave Pte The to/loavln ate ;nsurance wc, may purchase and charge you lot will cover only our interest fir, the ! , r G'•i1 to „r er.ge Ine Terms of the P!ar hu n lime to urn; after giving you any advance , property. the premium fur this insura nrr-. may be higher because the insurance I.i e royclr.: J by 'taw Am: CI lr'i 0 in the ill!f-fCSI rate ;t" ape')' it, flitUfv' advances, i Company rray 1)ove yi7an us the right to purchase insurance after uninsured also :. .r .; , ,our alECnsor and sehje,:I ;., a %e rE:;ui'c^ eats c f a::uticaale la,", w a1 col atera' is lost or damaged. The insurance will not be liability insurance and :;1y t" urpa,'j ba ar,',es. will not satisfy any state financial responsibility or no fault laws. The following paragraph applies to all but Wisconsin borrowers: Ai, mereasee in PROTECTING THE SECURITY INTEREST - If your state issues a 1,:,e for th., f (' .ir r- t u k' r tl I- r at r i t r idareC a crian fi in g rtroi : r f you l.w t -e tc have our s.-ur ty Inl?•rest strnon on the Inir- We n-:av hr,vp ' "of ,.• f ;'ir..._ :., r. -_o' -n. or,: re I n or art, <tft Of tl" Plan al any • } f. ,, IS tt!G a } r i rlf j ' I nor.: J ro1CC1 Our security irtr res Iron, the ` "no, US pn:;t v; alien no11Sn Y ,]If1L ,' 21>ke-1 ,o d i pr- mi , to sign a lna^ci to tatu're'1 You :.f C it :.V t of "ha F"111 ,i!9(+ _Clrl$e ]C. '.: hiL: -f Pi:Q :.C !n .rik if, necessary to prot['e. Our ,,_:•.r.t ftl ?:. r L1C fir i,;ert'i f ,-.: t (',rr.1 ;? !'' fJ i•. Ail cr.st5 mclipling Gut riot ilfr', r! rl i `:eiiti DELAY IN ENFORCING RIGHTS AND C144NGES IN THE PLAN a:t,:r r,,' fccs +;o !rr,;r .r _-_ i , irtcres7 and r.infs w ire prr. grly. .. ;?. _I , ':1 c•f 7 t':.,r _ r .. ., 'n 1...1(:. ..L ex!„fin , I ,t: %: I ,t,. ?' .. ",t, . la:•; LOAN_ LINER' Credit and Seeuri}: Credit Agreement. (continued) USE OF PROPERTY -',in!,! the Ad+ance Pas been paid ctf. ycu promiee ycu wilt; I1: m:" properly cat2fu lv tr ? ,q yep n , oOj ru ir. i2i Obtain our written Td< .r before making mi!_.r cl?anges tc the property Or chang:ng the address Camera the. properly is Lcpf. 13) Inf;;rnt us m wr icing before ::hanging your address. (4; Ailv•.a uS to insced the pro!-,ery i Promptly iotfy us it the properly is damaged. str..;l;.r-, ryr abused. t61 Not use the proverty for any ur lawfui purpose (7) Not to rattle picperly in another state wni lelkng U's. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE - rHE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to fait to return a motor vehicle that is subject to a security interest. within thirty days after you have received notice of default The notice will be mailed to the address you gave IS If is your responsibility to nctify us it your address changes. The maximum Ttus notice contains Important information about your rights and our responsibilities urdei the Fair Credit Bfi!ing Act. You are advised to read your monthly statement ai-d review it for any error discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR OUESTIONS ABOUT YOUR STATEMENT. If you think your statement is wrong, or it you need more infomnation about a transaction on your statement, write us on a separate sheet at the address listed on yov statement, You are required to notify us in writing within 60 days following the dale on which we sent your statemont wherein the error or problem first appeared regarding any discrepancy or unauthorized transactions on your account. Failure to notify us may result in your acceptance of any responsibility for payment or reimbursement to us for any such error or discrepancy on your account. Write to us as soon as possible You can fetephone us, but doing so will not preserve your rights. In your letter, give us the following information: Your name and account number. The dollar amount of the suspected error. De_cnbe the error and explain, if you can, why you believe theta is an error. If you read more information. describe the iier you tire not sure abort. If you have authorized us to pay a credit card account automatically from your share account or checking account, you can stop the payment on any amount you think is wrong To stop the payment your letter must reach us three business days before the automatic payment is scheduted to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless Nye have corrected the error by then- Within 90 days. wo must either correct the error or explain why we believe the statement was correct. per.a!ty for Gniaw!ul 'a here to return a motor ven cle is aria year in prison and:ror a trite of S150,000, For those members who purchase a vehicle under the DRiVe Program, please review the following FTC Notice: NQTI ? E ANY HOLDER OFTHIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE 'SELLER OF GOODS OR SERVICES OBTAINED WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. After we receive your letter, we cannot try to collect any amount you question, or report i you as delinquent. We can continue to sand statements to you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit limit. You do not have to pay any questioned amount while we are investigating, i but you are still obligated to pay the parts of your statement that are not in question. I If we find that we made a mistake on your statement, you will not have to pay any k finance charges related to any questioned amount, It we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. in either case, we will Send you a statement of the amount you owe and the dale that it is due. If you fail to pay the amount that we think you owe, we may report you as delinquent. However, it our explanation does not satisfy you and you write tows within ten days f telling us that you still refuse to pay, we must tall anyone we report you to that you have a question about your statement. And. we must tell you the name of anyone f we ieported you to We must tell anyone we report you to that the matter has been settled between us when it finally is. It we don't follow these rules, we can't collect the first S50 of the questioned amount, even it your statement was correct. ` SPECIAL RULE FOR CREDIT CARD PURCHASES - If you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the property or services. There are two limitations on this right: (a) You must have made the purchase in your home state or, if not within your home state, within 100 miles of your current mailing address; and (b) The purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisameni for the properly or services. In -,his Agreement. the words you and your means each and all of those who apply Line only by written application to us, which must be approved by our credit committee ' for the card or who signs this Agreemom. Card means the Visa Credit Card and any or ban officer. By giving you written notice we. may reduce your Credit Line from time duplicates and renewals we issue Account means yaur Visa Credit Card Line of to time, or with good cause, revoke your card and terminate this Agreement. Good Credit account with us We, us, and ours means this Credit Union. cause includes your failure to comply with this Agreement or any other agreement with 1. RESPONSIBILITY - 11 we issue you a card, you agree to repay all debts and the us. Or our adverse reevaluation of yr}ur creditworthiness. You may also terminate this I Fir ance Charge arising from the use of the card and the card account. For exampref, Agreement at any time. but termination by either of us does not affect your obligation it, pay the account balance. yuc are respensibie for charges made by yourself, your spouse and minor children. you are also responsible for charges made by anyone else to whore you give the 5. CREDIT INFORMATION -You authorize us to investigate your credit standing ca: e, and this responsibility continues unti! the ::ard is recovered. You cannot disclaim when opening. renewing or reviewing your account, and you authorize us to disciose_ C xmsibi illy by naifyhx; us, but we vhf GIOSe the: account for new transactions if you I information regarding your account la credit bureaus and other creddors who inquire ,•, rt ques: and return at cards Your obligation to pay the account balance continues of us about your credit standing ever: Ihough an agrecrrent, divorce decree or other tour judgnlerq IO which v.'e are 6. MONTHLY PAYMENT - We will mail you a statement every month showing your not a party may direct you or one of the other persons responsible to pay the account. Previous Balances of purchases and Cash advances, the current lransactbms on your '?-!e car_os rernaic our property and you must recover and surrender to us all cards ! tiCCaunl, file rerr-ali i avallab+e under your Credit Line, the New Balances of roan our r-equest and upon lerrmnw:on of this Agreement purchases and cash advances, the Total New Balance the Finance Charge due to dale", 2. LOST CARD NOTIFICATION - If our believe the card has been :OSt or stolen, aria any ether billed fees, and the MinimLim Payment required. Every month you must pry ' vnu .Call; ttm.?Uialaly call ire Ci ed:f imio i at 17) 7) 23u-8464 or 1600) 2:7.7326. Afton at least we Minimum Payment witrin 25 days of your statement closing data. By sc•parato I,,; it'; C„il 160,,,t 556-5676 agrcem:ant you may a.::hon;.f Us to charge the minimum payment automatically to your s':•rie or ct,erling account wth us You mrri. of course, pay more frequently, pay more 3. lJAt31LITY FOR UNAUTHORIZED USE - i'vu a';reci tC: us imn:C-crate°y. Cl t , fri,tn 1_, f.! rirn,. Ptayrr.ClJ, nr p, ,y the total New Balance in full, and you wiil reduce the X v.n . e e b • + n,. tt ru ,.,ncLc".c u. <.;; of your It(, Card You may be tar tI fir r r ch [r.Ne ^, blur (j, so. 14 your mon,:lily l ayrnenl exceeds lne total credit iine baiOnco 'Or :rte rr .L:'rl•;rltCd Js'i 0' Yu:r Grad,: Cif,: I'll. 0,11 .ipl be iaUe fci ui,ilu `oi,Zi+ llie _,v._u „J wit ifu _ ndi ;.;illy jJSI the credit to your Si snares ..` .,t . titer yp,; rill'^. U5 ?. t! I_a rti r po ss-.0 iwau l J h y Lisr• •:'uJ tr II have ? ',i ? . ?I n ro a ..nn i r•nnr.. - t+ f of your Total New Sal, rrn.;nr,•,d up ic, the 1, e. 1 r c; yi: ar? ;r, 5.r r r dill+r or ft)r '0 1%, U,e,,r-r i5 gicater. In adda or. a: any [4712 your Total t ,,, :,nc..n ti C ^.r .n, G' ,n..r tar' In C,a:. , qv.:r 6,ic r, will r of exceed 5:;0. F ,.1,a. _e x -9•iU> y-mr C +t Una. y,-)u ii mrredialety pa'y the excess aii our 4. CREDIT LITHE - I` .. ;p: ,(.ur xt: .701 .Stab; r SL:+ 0,11.7.--1 0 . , al p'y ^ ,-rctvs in the tJiow:rg manner first to pieviOLIS late fees. v:: i+i af. •'q L^e r.. Crv 4, Car yUU i3nL ;?:d C .f .: nn?rl v.ron th9 : ,t pr._:•: 7_.,i ...,, d.,vc. -.,ut f ,iin- Cha :5, ll erl to previous purchase f:na'i'-r` ?rr i rl C' S =la.r:.,a ..ir „I :J .v E.iCil ..`l lr i .. t-l !,) Li tc6? t` c-n to ^rt,,ous Cash nGi'JBnCQ ba:An1 cs t li•'l to I ?.f , ,t d i r.•,f:r•.' :n ., Cr:. I i V!, i. of U:_ t...,... L.o. in I:", Ir a'tr,e,? ' Lwere posrell tG your acr„^wr, ,'er, _ .. 1t _ ir, Lh a - , 'o ., pr••?.'r . ,.: ';:t r- 1"23: a e ,::^ in -,our, Crod.: V" C::r,w,I ..?. ! ....ir. ?.:,; 1. irid'hen :U cJrrow purcr,;ise balar•tes Visa' Credit Card Agreement and Truth In Lending DIsclosuro (continued) 7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by raying the fu!I amount of the Nev, Balance of Purchases eacn month within 25 days of your statement closing date. Otherwise. the New Balance of Purchases, and the subsequent purchases from the da'a they are posted to your account, will be subject to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average acjusted daiiy balance (see explanation below), includlnq new purchases, for the billing cycle by re monthly periodic purchase rate and Corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Cash Advances: We calculate your finance charge on Cash advances by muhiplying the average adjusted daily balance (see explanation below) for cash advances during the biliing cycle U/ the monthly periodic advance rate and Corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Dadly Balance for Purchases - The Average Daily Balance for Purchase Transactors is calculated by adding the Daily Balances (Purchase Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day Then, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of alt credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day in the biliing cycle. This gives us the Daily Balance for purchases. Average Dairy Balance for Cash Advances _ Cash Advance Itansacaons which are posted to your account are not included in the Average Daily Balance calculation 'or purchases, and are therefore riot subject to the monthly periodic rate for purchases, The Average Dally Halaixe is calculated separately for Cash Advances and is subject to the Cash Advance Monthly Periods Rate. The Average Daffy Balance for Cash Transactions is calculated by adding the Dally Balances (Cash Transaction) for each day in the billing cycle, and then dividing by the number of days in the b sling cycle. To calculate the Daily Balance for cash each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, In the sequence in which amounts i are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Purchase Transactions that posted to your account on that day or in any previous day in the billing cycle. TI11s gives us the Daity Balance for Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account. Payments are applied in the following manner: first to previous late fees, then to previous cash advances finance charges, then to previous purchase finance charges, then to current late fees, Then to previous cash advance balances, then Iq previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. Credits are applied first to the particular type of debt which is being credited, if any and then to the balance of your account. Note a:so that if the total of the payments and credits which are posted to your account by the Payment Due Date shown on a statement is equal to or exceeds the New Balance shov;n on that statement, we will riot apply the Monthly Periodic Rate to your Account on your next statement. 8, DEFAULT- You will be in default if you fall to make any Minimum Payment within 25 days after your monthly statement closing date. You authorize us to transfer funds sutficieni to make ilia minimum payment due it your Visa loan is in default. You will also be in dufault if your ability to repay us is materially reduced by a change in your employment, an increase in your obligations, bankruptcy or insolvency proceedings involving you, your death or your failure to abide by this Agreemont, or if the value of our security interest materially declines. We have the right to demand immediate payment of your fall account balance if you default, SubjeCt 10 our giving you any nonce required oy law. To the extent permitted by law, you will at su be required to pay our co lud,on expenses, ?hclud rig court cosh,a and reasonab:e attorney fees 9. USING THE CARD - To make a purcihaso or cash ad,,arlee. Mere are Iwo alternative procedures to lie foijored. One is for you to presont the! card to a pariiciparr,g Visa plan mood ant, or another linanctal inatduiion, arc sign the salos or cash advance draft which will be imprinted v:llh your card. The other is to complete il(-. transaction by using your Peri,final IdentuGration Number (PIP:) in Conjunction a,ih the crara ir, an Aulomated Teller Macnine or o0lcr type of elictron,c terminal that prcv dos trace .s to the •Jsa '_y5+em. YCL agrer_ 'hat you will no'ruse your card for any i on !!.af is legal .corder app),,!!!. federal. sta:c. or lo,gal ia1v Tile n:c.wh!y st,i:r:lncrt Will identity the rn@rc!la^.t Jeciionic termt^9i or finacciil !nstilul on at v:'.:Cn tr,trsaztiens were made. uA sale. cash advance, ciedh or at!ier s:,ps cannot l be returned with the statement. You will retain a copy of such slips lurnisned at the time of the transaction in order to verity the morthiy statement. The Credit Union may make a reasonable charge for photocopies of slips you may request. 10. OVERDRAFT OPTION - if you elect to overdraft to your PSECU V!sa Credit Card. that election is subject to the existing credo limil and the agreement it represents and the current loan policy at the time of the overdraft. You also understand that an overdraft will be considered the same as a cash advance on your PSECU Visa Credit Card and that the Current Annual Percentage Rate for casn advances will apply. 11. RETURNS AND ADJUSTMENTS- Merchants and others who honor the card may give credit for returns and adjustments, and they will do so by sending us a credit slip which we will post to your Visa line of credit. It your credit and payments exceed what you owe us, we will automatically post ilia excess credit balance 10 .I your St Shares within 75 days. If the balance is one dollar or more, upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS - The exchange rate between the transaction currency and the billing currency used for processing international transactions is a rate selected by Visa from the range of rates ava+lable in wholesale currency markets for the applicable central processing date, which rate may vary from the rate Visa itself receives, or a government-mandated rate in effect for Ilia applicable central processing ' date, In each instance, an adjustment may be assessed based on the ISA foe imposed by Visa. This foe, which totals 11i6 of the transaction amount, will be assessed on all transactions where the merchant country differs from the country of the card issuer. i 13. SPECIAL RULES FOR VISA PURCHASES - If you disagree or find an error with a Visa transaction, and have tried in good taith to correct the problem with the merchant or the charges are the result of unauthorized or fraudulent use. or your purchase cost more than 550 and was made from a plan merchant in your state within 100 miles of your home. contact PSECU. 14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transaction on your account, Telephoning PSECU does not preserve your dispute rights. You may be required to provide us with documentation to support your dispute claims. In addition, you may be required to complete a standard dispute form outlining the j details of your dispute. In cases of fraudulent card use, PSECU will also require a j notarized affidavit. In some cases we may ask you to notify the local authorities l it we do not receive the proper requested documentation in the time specified you may be held responsible for the transaction(s) in question. PSECU nwst adhere to strict dispute timeframes set hxih by Visa. 15. SECURITY INTEREST - To secure your account, you gram us a purchase money security interest under the Uniform Commercial Code in any goods you l purchase through the account. it you default, we will have the right to recover any of these goods which we have not been paid for through our application of your payments in the manner described In the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have if you are in default to prevent withdrawal of your unpledged credit union shares (Deposits) below the unpaid balance of your account. However, If you give or have given us a specific pledge of your credit union shares (Deposits) by signing tike Pledge of ? Shares or otherwise. or any other security interests for all your debts, your account i will be secured by your pledged shares (Deposits) and by the property described in those other security agreements, except for your home. 18. EFFECT OF AGREEMENT - This Agreement is the contract which applies to all transactions on your account even though the sates. cash advance, credit or : other slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance written notice required by law. Your use of the card thereafter will Indicate your agreement to the amendments To the extent the law permits, and we Indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. 17. LATE PAYMENT CHARGE - If your Minimum Payment is not received by file first day of the month following your due dale, you will be subject to a $20 charge. 18. RUSH FEES - You may incur additional charges for rush processing and rush delivery of cards andior PIN mailer. 19. OVER LIMIT FEE -A S20 fee will be applied for each monthly statement W!w-ig data on which the outstanding balance exceeds the as&gnod cicilit limit by rrim than S 14J 20. DRAFT COPIES - You may incur an additional charge for transaction sunimarylsale draft documentation. 21. COPY RECEIVED - You acknowledge receipt of a copy of this Agrees cot. 22. ILLEGAL TRANSACTIONS PROHIBITED - You agioe, that you well not use your card for any transaction that is illegal under app!rrabie federal, state, of !ocal law 23, NO USE - Inactive Visa accounts that have ne purchase or cash activity may be dosed without notice to you after 18 months of no activity. 24. NEURAL NETWORK - PSECU uses neural network syst•ams fo par--dxt anti prevent unauthorized transaction, There may be occasions wren a lido 5ar.br'h r; declined hecau e it is indw itwe o' possihlt fraudulent acnury. Y O o O M •L.. 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Q V Q Q V Q V p v ,n ono NOVhhQ PQQMmm `ON^MMO Nh0"(")OQ hh OmOV1 +ONmVVV Qtvr w6tn m^Ln^h^ MOmv)VN Oc hr lok)Q MN^OP mmhh 10 `O ,n,n V Q V V QM MMMM MMMMMN NNNNNN 000000 000000 ' 000000 000000 ?.mPO^N MQ Nmhm PO^NMV ?f .Ohm00 d -? a n rs Q ? 47l K Sheriffs Office of Cumberland County R Thomas Kline oa?,tr of icrrmbrr Edward L Schorpp Sheri Solicitor 4 Ronny R Anderson Jody S Smith Chief Deputy OFFICE'? F T"_ 6'' RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/19/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Amber Connors, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint and Notice according to law. 03/26/2009 York County Return: And now, March 26, 2009 I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Amber Connors the defendant named in the within Complaint and that I am unable to find her in the County of York and therefore return same NOT FOUND. Per Post Office check, defendants new address is Box 3 Rheems, Lancaster County, Pennsylvania 17570. SHERIFF COST: $42.00 SO ANSWERS, April 24, 2009 R THOMAS KLINE, SHERIFF 2009-1487 Pennsylvania State Employees Credit Union VS Amber Connors FILED-0-1Frive. 2009 APR 28 Ail 9. 17 cultk ;; . COUNTY OF YORK OFFICE OF THE SHERIFF S(7117)1771-9A601 L 45 N. GEORGE ST., YORK, PA 17401 SHERIFF SERVICE 06-1 ' PROCESS RECEIPT and AFFIDAVIT OF RETURN PL, E TYft OWY LIVE 1 TMtj 12 DO NOT DETACH ANY COWS r /+ 2 T N 'e V , `VVJ I NTIFFISI Naj? (J(^J (?•LU 4. TYPE OF WR OR COMPLAINT NMICE, CICA C' 3. DEFENDANT ?T I ; It Ili IW/JL Y IV S RVE 5 E OF IN IVIDUAL, CO ANY, CORPORATION.N. ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIE , A LED ORS D y 6. IDDR S (STREET OR RF WITH BO NUM?R PT NO ,CITY, BORO. TWP STATE AN IP CODE) AT fnM e 7. INDICATE RVICE' PERSONAL PERSON IN CHARGE V DEPUTIZE 1 CLASS MAIL U POSTED J OTHER _1?5 4a a 99 NOW 20 I, SHERIFF OF O NTY, PA, do hereby deputize the sheriff of COUNTY to exec t?i? make retu f-according to law. T is deputization being made at the request and risk of the plaintiff. , T 11119 SHERIFF OF O 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE OUT OF CO CUMERI M ADV FEE PAID BY ATTY. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watCMrhan, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss. destruction. or removal of any property before shenfrs sale thereof. TY ttl ji ?'P ?1AE and R of ATTJ?RN / ORIGfNATOR and SIGNATURE 10 NE NUMBER 11. FILED IXE ('Lffil IF 12. SEN TICE RVIGE??A ADDRESS BELOW: (TMs area must E?MM7_7 et ?, ? M Lv VQy ?? eCk MI6sa L U ?-b x 2, I, 11a?1 n'UU'7'T WAM OW FOR USE OF THE SMW ? DO NOT 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date or complaint as indicated stove. MJ MCGILL XCSO 3-23-2009 47-9-09 16. HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. hereby certify and return a NOT FOUND because 1 am unable to locate the individual, company, etc. named above. (See remarks below.) 18. NAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 119. Date of Service 120 Time of Service 21 22. Time Miles Int. Dale 1 Time in I Int. I Date I Time I Miles I Int. I Date I Time I Miles I Int. I Date I Time I Miles I Int. r PER POST OFFICE CHECK, N91 ADDRESS IS POST OFFICE BOX 3, RHEEMS, PA 17570-0003 23. Advance Costs Service Costs 25 N/F ^ 26.?JMileage 27 Postage 28. SuD T?oJfa?1? 29. Pound 30 Notary -? 4 31. Surf g. 3?2/. Td. Cyw 33CostsDueor 1.00.00 •00 ,W a °z-?`-? 6 a't1 Y r 1 3716, 34. Foreign County Coats 35. Advance Costs 36 Service Costs 37 Notary Cert. 8. Mileage/Pos tage/Not Found 39. Total Cost Costs Due or Refund S SO ANSWERS 41. AFFIRMED and subscribed to 14 a me thi 44 Signature of 45. DATE 42, day of Dep. Sheriff NC`F?,IIAL SEA1 46. Signature of Yak County Shddf 47 DATE LI '. I r -.C1-- N' ;` ' Y PUBLIC RICHARD P SHERIFF 4-21-2009 .r C C", NTY . , ' 12, 2009 ` 48. Signature of Foreign 49 DATE County Sheriff 50. 1ACKNUVVItUUt Ktctirr Ur Int antrurr a ntIUnn aaurmmIuRt OF AUTHORIZED ISSUING AUTHORITY AND TITLE ITE - Isswq Authority 2. PINK - Attorney 3. CANARY - Shenfrs Office 4. BLUE - Sheriff's office 4 y 3' r? COUNTY Of YORK OFFICE OF THE SHERIFF S(R )1771 9 CAL OItJ 45 N. GEORGE ST., YORK, PA 17401 I SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN . 5 CORPOPAT4014, S (STREET OR RF WITH B UMBER, PT NO, CITY, BORO. TWP TATE AND IP CODE) 6 AbCkU AT t A (A W1 rx rv-? m 7. INDICATE SERVICE- 'kPERSONAL ERaSON IN CHAR U DEPUTIZE E , 0. U t Cl/tS 'MAIL U'PaTED; ' U OTHER NOW 11,11 ' , 20? I, SHERIFF OF N PA, do hereby deputize the sheriff of COUNTY to execute this Writ and make return thereof -according to law. A i's dilputization being made at the request and risk of the plaintiff., SHERIFF OF YORK COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE OUT OF CO CUt BER-LAND ALM FEE PAID BY ATTY. I NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attactung any property under within writ may leave same wi8tout a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein forairmy be$. deahrucion, or removal of any property before shenfrs sale thereof. 9. TYPE and E S of ATT,0R?N+ /ORIGINATOR and SIGNATURE r ( s ( 10. TELEPHONE NUMBER 11. DATE FI EO _NAMJE ?Fit,..- ?>n , _ . , ? ? ti a fi ?i t 1 ?? ;W ?f?t?r' ? ??tT 1,?1?? C?7 i f?l"'1 ) /'?_ - ?? ,??? ?12. SFID - TIC?S?tTFRMIC f't:?OPY T/ At ADDRESS BELOW: (This are must led notice is to be ma SIF1 _- T,? LV/r•) ?/1 LC ,r1„ Tj 7 ltL (h((i law, a 'lam 6 SPACE BELOW FOR USE CW TM - 00 Wn 'OW TM 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date or complisAas indicated above. 3-23-2009 4-9-09 18. HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc famed above. (See remarks below.) 18. AND TITLE OF INDIVIDUAL SERVED /,LISTADDRESS HERE IF NOT SHQWtIABOVE;Retabonship to DefeniOnQ 19. Date of Service 20 Time of Service 1 21.A 22. Time Miles Int. Date Time Miles IM. Date I Time 1 Miles I Int. Date I Time I Miles I Int I Date l Time I Miles Int. f PER. POST OFFICE CHECK, "7EW ADDRESS IS POST OFFICE BOX 3, RHEIE4S, PA 17570-0003 l t, '23. Advance Costs 24 Serv ice Costs 25.E NIF Miteage? 27 Postage 28. Sub Total` 29. Pound 0 Notu,,y?.j 31. Surchg. 32. Tot. Comb t 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary Cert 38. MileagWftstage/Not Found 39. Total Costs 41. AFFIRMED and subscribed to be a me thi 1St 42. dayof-AkWj C?Q!0&/-O? , NOT IA_ SF `.L Lis,", ( .. Vt' NC; RY PUBLIC M`(CC ,iftif.;Sl!iiu LiiP''r['SRl;:3, `t?, 2009 k.IACKNOWLt:UU AECEfP I HE"SHERiFF'S RETURA OF AUTHORIZED ISSUING AUTHORITY AND TITLE t -;IssumgAulhonty 2. PINK` Attorney 3. CANARY momwml 44. Signature of Dep. Sheriff 46. SignMuro of York County Sheriff RICHAM P. KEUF SHE:RIF 48 Signature of Foreign County Sheriff - sheriff's Office 4: SLUE - Sh.W. Office PLEASE T"ME ONLY L9W 1 TMU 12 00 Mt MUCH ANY COPIES 2 TN E -je V vyl 4. TYPE OF 11VR1 O- CO PLAINT 130TI,C E,CLC A 33 Costs Due Costs Due or Refund 51 DATE 45. DATE 47. DATE 4--21-2009 49 DATE EIVED SHERIFF'S OFFICE OF CUMBERLAND COU;_NTY Ronny R Anderson ,~ ~. ~~" ~~ . E,1;~~~~ Sheriff t_,- ,1-,~- : _ ~` ~,,wr at ~a~urb~~l Jody S Smith i9 ~"~ ss ' ~ ` ~,: ~~ ~" '~!~ Chief Deputy ~~ ~ ~ "~' ~~ ,/ s t`-. > Richard W Stewart ~~ ~ ~~` ~ ~' ` E^,i.1~ i~ ~'~ Solicitor cF~ ~~ ~~.~ ~~F~ ~~~R~~~ ~. ~ _ ,~,. r _, ~ ~„~ . Pennsylvania State Employees Credit Union Case Number vs. Amber Conners 2009-1487 SHERIFF'S RETURN OF SERVICE 07/01/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Amber Conners, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Amber Conners. The Enola Postmaster has confirmed, Amber Conners is not known at 413 Pitt Street, Enola, PA 17025. SHERIFF COST: $46.50 SO ANSWERS, July 01, 2010 RON R ANDERSON, SHERIFF {c CouniySuite ShOn`f. Te~easoR, Inc. 09-1487 FILE--D-1O F ICI. "l- THE PROTHONOTAR )° 2011 FEB 17 AM I1: 20 CUMBERLAND COUNTY PENNSYLVANIA BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 MOTION OF PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT PA.R.C.P. 430(a) AND NOW, comes the Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Barley Snyder LLC, Esquires and moves your Honorable Court, pursuant to Pa. R.C.P. 430(a), for a special order directing service of process, default notice, and writ of execution notices, if necessary, upon Defendant by publication in accordance with Pa. R.C.P. 430, as follows: On March 10, 2009, the Plaintiff filed its Complaint against the Defendant. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and incorporated herein by reference. 2. On or about March 26, 2009, the Sheriff of Cumberland County attempted service at 1 A Umberto Avenue, New Cumberland Pennsylvania and returned the Return of Service to 3062705-1 09-1487 Plaintiff indicating "moved." The Sheriff of Cumberland County deputized service to the Sheriff of York County and returned the Return of Service to Plaintiff indicated "per Post Office check, new address is Post Office Box 3, Rheems Pennsylvania 17570."A true and correct copy of the Return of Service is attached hereto, made a part hereof and marked Exhibit "B". 3. On or about May 4, 2009, the Plaintiffs counsel prepared and mailed a Request for Change of Address to the Rheems Postmaster. The response to the Request for Change of Address indicates "Street Address 107 Greider Avenue". A true and correct copy of the response to the Request for Change of Address is attached hereto, made apart hereof and marked Exhibit «C„ 4. On May 19, 2009, Plaintiff performed an Accurint search on www.Accurint.com. The address that was searched is 107 Greider Avenue, Rheems Pennsylvania 17570. A true and correct copy of the Accurint Search is attached hereto, made a part hereof and marked Exhibit «D„ 5. On June 15, 2010, Plaintiff performed an Accurint search on www.Accurint.com. The address listed on the Accurint search is 413 Pitt Street, Enola, Pennsylvania 17025. A true and correct copy of the Accurint Search is attached hereto, made a part hereof and marked Exhibit "E". 6. On June 23, 2010, the Plaintiff filed its Reinstated Complaint against the Defendant. A true and correct copy of the Complaint is attached hereto as Exhibit "F" and incorporated herein by reference. 7. On or about July 1, 2010, the Sheriff of Cumberland County attempted service at 413 3rd Street, New Cumberland, Pennsylvania 17070 and returned the Return of Service to Plaintiff indicating "unable to locate Amber Connors, Enola Post: Office confirmed, Amber 3062705-1 09-1487 Connors is not known at 413 3rd Street, New Cumberland, Pennsylvania 17070." A true and correct copy of the Return of Service is attached hereto, made a part hereof and marked Exhibit "G95. 8. On November 11, 2010, Plaintiff performed an Accurint search on www.Accurint.com. The address listed on the Accurint search is 413 3rd Street, New Cumberland, Pennsylvania 17070. A true and correct copy of the Accurint Search is attached hereto, made a part hereof and marked Exhibit "H". 9. Plaintiff believes and therefore avers that the reasonable method, under the circumstances, is to serve all pleadings, including service of process, default notice, writ of execution and notices of sale upon the Defendant, if necessary, by publication. 10. The Plaintiff will suffer irreparable harm and injury if the Plaintiff is not allowed to effect alternate service of the process, default notice, writ of execution and notices of sale, if necessary, upon the Defendants, under Pa.R.C.P. 430, by publication, under Pa.R.C.P.430. WHEREFORE, the Plaintiff, Pennsylvania State Employees Credit Union, prays your Honorable Court to enter an Order authorizing service of process, default notice, writ of execution and notices of sale, if necessary, in the within matter upon the Defendant, Amber Connors, by publication in accordance with Pa. R.C.P. 430(b)(1)., Date: By: BARLEY SNYDER LLC Shawn M. Long, Esquir Attorneys for Plaintif Pennsylvania State mployees Credit Union Court I.D. No. 8 74 126 East King treet Lancaster, PA 17602-2893 717-299-5201 3062705-1 EXHIBIT "A" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff S. AMBER CONNORS Defendant NO. 09 -1487 c . _7 a t. m? o ?=C i ? Ca 6rn CIVIL ACTION -LAW z •• .z- a, NOTICE TO'DEFEND Pursuant to PA RCP No. 1018.1 You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE--HIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CAN NOT AFFORD TO HIRE A LAWYER, 711118 OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 Document #: 180057.1 EN LA CORTE DE ALEGATOS COM UN. DELICONDADO DE CUMBERLAND, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES NO. CREDIT UNION, Plaintiff V3. AMER CONNORS Defendant CIMAL.17ON -LAW AV I S 0 PARA DEFENDER Conforme a PA Niun. 1018.1 USTED HA SIDO DEMANDO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defenses o objeciones a las demandas puestas en contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio sohcitado por Demandante. Ustedpuede.perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. Cumberland County Bar Association 32 S Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 Document #: 180057.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. AMBER CONNORS Defendant NO. CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Van Eck & Van Eck, P.C. and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the-C-ommonwealth of Pennsylvania with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Amber Connors, is an adult individual with a last known address of 1 A Umberto Avenue, New Cumberland, PA 17070. 3. Defendant is, and at all relevant times material hereto has been, the primary loan applicant. 4. Defendant applied to Plaintiff for a loan for the purpose of purchasing a motor vehicle. 5. The loan application submitted by Defendant was approved by Plaintiff and Defendant signed a Loanliner Advance Proceeds Check for the purchase of the vehicle. A true and correct copy of said Loanliner Advance Proceeds Check is attached hereto, incorporated herein and marked as Exhibit "A". Document #: 180057.1 6. Pursuant to the Loanliner Advance Proceeds Check marked as Exhibit "A", Defendant agreed to the terms-and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (hereinafter referred to as "Contract"). A true and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 7. Defendant has accepted the monies borrowed from Plaintiff pursuant to the terms and conditions of the Contract marked as Exhibit "B". 8. Various charges and payments were made by Defendant on the account. 9. Plaintiff provided a letter to Defendant stating that the vehicle purchased by Defendant was deemed repossessed. The letter further advises Defendant that unless payment in full was made on the outstanding loan balance, the said vehicle would be sold at a public sale and Defendant will be responsible for any resulting deficiency. 10. As a result of Defendant's failure to cure the default in payment, and pursuant to state law remedies, Plaintiff sold the vehicle at public sale. 11. Plaintiff provided a letter to Defendant indicating that there was a resulting deficiency after the sale of the vehicle. 12. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 13. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 14. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. Document #: 180057.1 15. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused?and continues to refuse to pay all sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. 16. As of March 9, 2009, the balance due, owing and unpaid on Defendant's loan account with Plaintiff is the sum of Fourteen Thousand Five Hundred Fifty-two Dollars and 81/100 ($14,552.81). 17. Pursuant to the terms and conditions of the extension of credit contained in the Contract, Plaintiff is entitled to receive and. Defendant agreed to pay an annual interest charge on the principal loan balance. 18. Due to the default of the Defendant and pursuant to the terms and conditions of the Contract attached as Exhibit "B", attorney's fees in the total amount of Two Thousand Three Hundred Fifty Dollars and 56/100 ($2,350.56) have been added to the account. 19. Any and all conditions precedent to the bringing of this action has been performed by Plaintiff. 20. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. Document #: 180057.1 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit- Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Amber Connors, in the amount of Sixteen Thousand Nine. Hundred-Three Dollars and 37/100 , ($16,903.37), plus interest, the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, VAN ECK & VAN ECK, P.C. By: Melissa L. Van Eck, Esquire Attorney I.D. No. 85869 P.O. Box 6662 Harrisburg, PA 17112 717.540.5406 Document #: 180057.1 VERIFICATION I, Gregory R. Diffenderfer, Manager of the Pennsylvania State Employees Credit Union verify that the statements made in the aforegoing document are true and correct. I .understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Pennsylvania State Employees Credit Union By: Title:! Date: 6 A '09 ..-wo.,.. ccss RIT r ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT AMM R COMORS 811 VALLEY STREET ENOLA PA 17025 .? 7YM 1. ? NEW LOAN 2 El opel LOAN w ---i ® Pennsylvania sta e EmPloyees t Union P. O. Bout 67013 I-Ianisl)M7, »710s-7(Hs 717.234.8484 8W .2V.7328 OU18/2007 -0 DEALER PURCHASE ? OTHER YES u NO ANNUAL PER- WTENESTaxrt:Is ALIOUNTFr4uESTFD CEM'AGE RATE +an?acw?AC+es Fi7tED VArHIABLE .( 07.740 % JD ? 22 000.00 art' .. DUE nuvE PY?Yl?i 3 8 02/ mot RY Au>tiawc>r THE 0lYtxsEExlfi61Y u R7tHts AI7VIUOEE t$71IE REAL PROPEM (IN AmXT, EOUITY ADVANCE IN ADOMON 10 W PLEDGE OF SKAWRES 94 YOM LOAN LWER° CRgDrr 1. 2. FORD F150 a _ 4L OTHER YOU PLEDGE SHAMES ANW R DEPOSITS OF $ WiAE 1 a MUrrYAUNANCE 7FIE FOLLOWNID 2001 1FTRW08L31K(743375 TK N ACCOUM NUMB M OLD ACCOUXUDAN NUMBER 10) PAYOFF f PRNiC + NHL) OLD A( COtNITA 0AN ! OLD ACCOUNMOAN NUMBER tq PAYOFF (PRWC + Wn OLD ACCOlarrn rmu i, OW5890881 YES U Nob 'Ll _ rlEiv uHAt.ANCE ? 22 000.0( ROJt3S I aw eau .. 17,455.00 BY acoepft the proceeds advanced and deposited Into your shareftare draft account, you agree (1) that the property referenced above wM secure the advance and my other advatmas you have now or receive In the future under the LOANLWF.R- CmM and S any other amounts you owe us for any reason now or In the future In accordance with the terms of the Plan and (2) to snake p dLed above In and accas*mm wflh the terrrre of the Plan. :GYfR1lmmL WOtr, X12, Bt, Sk wx 9i It lall t 01, %0kAlL Wm me V a PENNSYWANM STAM QPLOYEES CMFDfi UWION FORM 1-175 JII=100.1 037-2092-1 f WM 75 m G i sraMED ;EGURITY AGREEMENT i this agreement all references to Credit Union, we, our, or us means Pennsylvan Late Employees Credit Union and anyone to whom the Credit Union assigns the C Ireement which will be referred to as the Plan. All references to you, your, irrower mean each person who signs this agreement. All references to the adva ean the amount in the box labeled Amount Advanced. This is a multi-state docum itch may be used to lend to borrowers in all states except Louisiana and Wiscon THE SECURITY FOR THE LOAN - By signing this security agreement in !nature area or under the statement referring to this agreement which is on the b the check you receive for the advance,-you give us what is known as a secu Brest in the property described in the Security Offered section on the reverse si e security Interest you give includes all accessions. Accessions are things which ached to or Installed in the property now or in the future. The security. interest al ludes any replacements for the property which you buy within 10 days of ranee or any extensions, renewals or refinancings of the advance. It also inciud i money you receive from selling the property or from insurance you have on iperty. If the value of the property declines, you promise to give us more prope security 9 asked to do so. WHAT THE SECURITY INTEREST COVERS - The security interest secures ance and any extensions, renewals or refinancings of the advance. It also secure other advances you have now or receive in the future under the Plan and any oth )unts or loans, including any credit card loan, you o:ke us for any reason now or default who has signed the Plan. ie future, except any loan secured by your principal residence.. If the property sehold goods as defined by the Federal Trade Commission Credit Practices Rul properly will secure only the advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY - You promise that you own the property is advance is to buy the property, you promise you will use the advance for th lose. You promise that no one else has any interest in or claim against th party that you have not already told us about You promise not to sell or lease th ?erty or to use if as security for a loan with another creditor until the advance L id. You promise you will allow no other security interest or lien to attach to the arty either by your actions or by operation of law. the PROTECTING THE SECURITY INTEREST - If your state issues a title. for tharty, you promise to have our security interest shown on the He. We may hav e what is called a financing statement to protect our security interest from the is of others. If asked to do so, you promise to sign a financing statement You )romise to do whatever else we think is necessary to protect our security interest property. You promise to pay all costs, including but not limited to any attorney we incur in protecting our security interest and rights in the property, to the t permitted by applicable law. ISE OF PROPERTY - Until the advance has been paid off, you promise you will: 'se the property carefully and keep it in good repair. (2) Obtain our wriHen !ssion before making major changes to the property or changing the address the property is kept (3) Inform us in writing before changing your address. (4) us to inspect the property. (5) Promptly notify us if the property is damaged, or abused. (6) Not use the property for any unlawful purpose. ONSUMERS' CLAIMS AND DEFENSES NOTICE - The following paragraph ?s only when the box on reverse side is checked. CE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS ECTTO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD RT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE OR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR UNDER. iOPERTY INSURANCE, TAXES AND FEES - You must maintain property ice on all property that you give as security under the Plan. You may purchase perty insurance from anyone you choose who is acceptable to the Credit Union. count and coverage of the property insurance must be acceptable to us. You ovide the property insurance through a policy you already have, or through a lou get and pay for. You promise to make the insurance policy payable to us deliver the policy or proof of coverage to us if asked to do so. :ancel your insurance and get a refund, we have a right to the refund. If the y is lost or damaged, we can use the insurance settlement to repair the y or apply it towards what you owe. You authorize us to endorse any draft or rhich may be payable to you in order for us to collect any refund or benefits ter your insurance policy. You also promise to pay all taxes and fees (like is registration fees) due on the property. redrt If you do not pay the taxes or fees on the property when due or keep it insured, we may and pay these obligations, bul: we are not required to do so. Any money we spend-for taxes, nce fees or insurance will be added to the unpaid balance of the advance and you will pay ent interest on those amounts at the same rate you agreed to pay on the advance. We may sin. receive payments in connection with the insurance from a company which provides the the insurance. We may monitor our loans for the purpose of determining whether you and ack other borrowers have complied with the insurance requirements of our loan agreements ft* or may engage others to do so. The insurance charge added to the advance may include de. . (1) the insurance comparr/s payments to us and (2) the cost of determining compliance are with the insurance requirements. If we add amounts for taxes, fees or insurance to the so unpaid balance of the advance, we may increase your payments to pay the amount the added within the term of the insurance or approximate term of the advance. es B, NOTIGE - if you do not purchase the required property insurance, the insurance the we may purchase and charge you for will cover only our interest In the property. The 1Y Insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. the 9. DEFAULT -You will be in default If you break any promise you make under this s agreement You will also be in default if you are in default under the Plan, If you are er pledging property, but have not,signed the Plan, you will be in default it anyone is in rs 10. WHAT HAPPENS IF YOU ARE IN DEFAULT - The following e, to borrowers in Colorado, District of Columbia, Iowa, Kansas paragraph Maine, Massachusett, Missouri, A'ebraska, South Carolina and West Virginia: When you or are in default and after expiration of any right you have under applicable state law'to at cure your default, we can require immediate payment of your outstanding balance e under the Plan without giving you advance notice. e The following paragraph applies to borrowers in all other states. When you are in s default, we can require immediate payment (acceleration) of what you owe under the Plan and take possession of the property. waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. The following paragraphs apply to all borrowers.e You agree the Credit Union has the right to take possession of the property without judicial process if this can be done without breach of the peace. If we ask, you promise to deliver the property at a time and place we choose. We will not be responsible for any other property not covered by this agreement that you leave inside the property or that is attached to the property. We will try to return that property to you or make it available to you to claim. After we have possession of the property, we can sell it and apply the money to any amounts you owe us. We will! give you notice of any public sale or the date after which a private sale will be held. Our expenses for taking possession of and selling the property will be deducted from the money received from the sale. Those costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded under the Bankruptcy Code. The rest of the sale money will be applied to what you owe under the Plan. If you have agreed to pay the advance, you will also have to pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the advance and to what you owe under this agreement You agree to pay interest on that amount at the same rate as the advance until that amount has been paid. 11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE AGREEMENT - We can delay enforcing any of our rights under this agreement any number of times without losing the ability to exercise our rights later. We can enforce this agreement against your heirs or legal representatives. If we change the terms of the Plan, you agree that this agreement will continue to protect us. 12. CONTINUED EFFECTIVENESS - If any part of this agreement is determined by a court to be unenforceable, the rest will remain in effect. 13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. 14. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to fail to return a motor vehicle that is subject to a security interest, within thirty days after you have received notice of default. The notice will be mailed to the address you gave us. It is your responsibility to notify us if your address changes. The maximum penalty for unlawful failure to return a mntnr -hi,h ; :_ _ . _ Perw)sylvanis State `Erei?loyeesr.G? i :No.589088!•r`%, ?•:; - roi..aoi? N..ri.i??inas»u • p.7)ba...i.P AurooaAFT Jow ? aYM+ 4 ?1000-00 , ne?cE 809.4896030 vao 120 oars AFTM 01/11(1007 %- .. <. -I'e r . ?.M?•TO•iNE" •'rf :1,. i.'! !ir ; ?.•'.; •„i.; i I,?i /Il ii%;:r{ . . '. . rGI1DE11Of IDEALFl11r %? . ' ' / r "' • ;J'.:? •i• , ?' : r r ';? ? % _': , ? rJf ? I% " Yi1'OIITARI[: VOID Wft7 OiEIIIHI BAOIpEfB/i.•COhYlF710 i F EIOOIIffJ?EN({. 'v`::ur: )?l?ii: M...?ww.?7.r :rt:?•'r'' iC: vi.ae?t • - ... ?? '' rray..a V . ?p tl dw W: ?Yt ? uw. i,. to M.??... 4I.4 an d. ? r?rl 4wiwvwbit- n." w'n.r.r?it", Mnl.l.wr.y..wN:iiwl.a - • `.Y',-. .r:!r ?4i+rii.i. wrr:r•. wrp.ga rl: r..rv. u....1.G? /IiJ?%( %-?017_r . .. _ -i .ti. '). ?rq.w:rwu.w.Ian..In.OWl irrbrwrr.i.• Ts MYri?L A11?rMiiw.w7?Ywirr??w.r?.Iid.Xwr/shu•?!;. - .r.rr.a....+ar,r wl gMr? .irr++{rWr.i•.Ydn ..wr L3 13 w..b"bw0 P,..•i _e•?.r+rc.r., u:.?.r"...` . •.:P r.a..rrrwra+w:ijsvi+q+1?...+.rinG'aa?,y.++pr. _r•?,r?r..ltYrp.uii'0. . rr'r..rr:.a:Qw.f{.??.r.)ry:?rlt•/; i?•:s?irifnaii?xt'• _ ?. ,Q w•+r 0. . - -'. >. I? .ry?,WOSL.JIK? ?? Y F ?F', .r ? I r) l ? ! ;.f '7?;: ? !? Mao6.r 6?dafwelwK„.. •.r. L161{?C.__^ ?„•j . r AMOMCONNOM' !•?Y 17,!?''''!d .e.,4ppYe.m sew [l?• 7.O?J90? NO.CO-APPLICANT';'• . - - , ?•' ;.?' ' - , - -- Vii; - _ ' 115890881n. !231313.1& : 3105756.2621' 44. ('0002200000.( fit ' # tail ?s 18649 611887 571 27 D sg :s ( g 9 ??? ?? o Duo a ;? y•' Oa m w ni+ii gf'' l?jl•# 2 'O G1 ? O = -I i f?t.i• ! s O ???ii•S?}•[? ICC .?? i ?cHO<m C3, > G < i ° °;y•r 3A ?Fi7s?3s??° Ila, -,w - 'p, 1 [? - ?!???:i: Si s?^ yrr..y?l y1 [?1{Y. =? ¦:?. 7??.????$???01 - - -= -? fiiiss F}i 1222 j}i ?= ii'• -:i IL E3 iil??3)ri 3.l ?ti t:??f ?ri 3:?3 lyI'' Exhibit «$» Pennsylvania State Employees Credit Union PO. Eo 670113, tarn::..:r2. PA f71C6-70l,i • 071234-5•18-f harnsaur(7. bi'n'/i1137•:329 N.atiornsx!e PSECO Loan Disclosures This LOANLINEW Crean and Security Agreement, v,hrch :nciudes. the Truth in CREDIT INSURANCE - Credit life and•'or credit disability insurance is optional ' Le-uW.g iOmck:sutos, v t,M be referred td as the Plan The Pan documents include this = under the Plan. N. you quafiN for and purchase the insurance frdrn us. you authorize a5rcamerl and an Addendum You, your and borrower mean any person who signs f us Ib add the insurance preen his monthly to your ban balance and charge you 'lie Plan. Credit union, we. our and us mean PSECU or anyore to whom the Cred+I i interest on the entire balance.- If you elect credit insurance, yoto payments may ` Uo*P transfers its rights under the Plan. ) increase or the period of time necessary to repay your advance may be extended j i HOW THIS PLAN WORKS - This is an open-end, multi-featured credit plan. We The credit insurance rates may change during the Plan. It the rates change, we will i anticipate that, from time to time, you wilt Willow money (called 'advanr es) under provide any notices required by applicable law. i it to Plan. We are not required to make advances.to you under the Plan and can PERIODIC STATEMENT - On a regOar basis you win receive a statement showing I refuse a request for an advance at any time. The Addendum describes the all transactions under the Plan during the period covered by the statement. ! different ryoas at ueift fca tied 'suwcceums') available under ttie Plan, trio current Statements and riWlces will be sent to you at the most recent addrem you have I interest rate for each subaccount expressed as a daily periodic rate. and given us in writing Unless applicable lair requires notice to each pint borrower, i corresponding annual percentage rate and other charges. It may also have other # notice to any one of you will be notice to all. terms and a schedule for de!ermining the paymertt amounts. 1 JOINT ACCOUNTS It this Is a joint account, each of you is individually and jointly ! CREDIT LIMIT -vie may but d° not have to, esiateGsh a credit limit on certain I responsible for paying an amounts owed. That means We can erface our rights i :ubaccornls. If a credit I.-mit a set for a subaccount, you promise not to exceed the l tinder the Plan against any one bf you nid:riciuany or against all of you together. If you established credit limit, if you exceed the credit lirctt, you promise to repay give us inconsistent instructions. we can refuse to follow your instructions. Unless our immediately the amount which exceeds the credit Sma. written policy requires all of you to sign Ior an advance, each of you authorizes the REPAY161ENT - You premise to repay all amounts you owe under the Plan plus other(s) to obtain advances individually and agrees to repay advances made to the interest. Payments are oLe on the last day of ire month unless we set a dillelert day other(s). Any joint accountholder may terminate the Plan by giving us prior written at the time of an advance. 1! the Adderoum has no payment schedule for a notice. It any of you terminate the Plan, the Plan is terminated for all of yoL You subac curd, your payment will be determmed at the tine of each advance. remain liable Individually and j xntfy ku as advances incurred before termination. I Payments must include any amount past due and any amount by which you have FEES AND CHARGES - If you give us a security interest in certain types of exceeded any a add limit you have. been given for a subaccount. You may repay all property. we may charge you a fiing fee to perfect our interest in the property: tf we or part of what you owe at any tune without any prepayment penalty. Even if you do, the amount of the fee will he disclosed to you at the Time you obtain an advance. orepay. you will still be required to make the ragutarty scheduled paymerds unless We may also charge you other fees in connection with the Plan. Our current fees are I we agree in wrong to a change in the payment schedule. N you have a joint disclosed on tie Addendum and wilt be added to your ban balance unless you pay char dralt account. you will be responsible for paying all overdralt advances them in cash, i obtained by a joint holder of the sharedratt account. Unless otherwise required by UPDATING CREDIT INFORMATION -You WORfISe that taw. payments win be apptied to amounts owed under the Plan. In the manner the you win promptly glue us i CrLt Union chooses. mitten notice it you move, change your name or employment, or it airy other j inlormation you provided to us changes. Upon our request, you also agree to PLAN ACCESS -You can obtain credit advances in any manner authorized by us. It provide us updated financial Information. j we slow you to use your ATMfDebncard to access the Plan, you maybe liable by the DEFAULT - The following paragraph applies to borrowers In Idaho Kansas, unauthorized use of your ATM/Debit card. You will not be table br unauthorized use r + I fiat omits after you notity us. orally or in writing. of Vie loss, theft, or possible Maine and South Carolina: You will be in deWut'rf you do not make a payment ol ! unauthoraed use. N you believe your ATM(Debit card has been lost at stolen, the amount required when it is due You will also be in default it we believe the 1 tmm-OL)tely inform the Credit Union by calling or writing us at ft lelepttone number or prospect a payment, performance, or realization on any properly given as security address trial appears elsewhere it, the Plan. If the card is used to obtain unauthorized ( is significantly impaired I aa:ances dirrsr_tly from et, Plan, your liability will nor exceed S50. 11 the unauthorized I The following paragraph applies only to borrowers In Wisconsin: You will be in i w•rthdrawai is from a sharedraf: account. your 1!abiity, s governed by the Regulation E default d you lad to make a payment when due two times during any 12 month I dic.tosures yqu raceived at the time you ioceived your ATM/Debit card, even d tie period. You will be In datault if breaking any promise made under the Plan materially w,lhdrarial results in an advance being made horn your overdraft subac:c6Uni. ' impairs your ability to repay what you owe of materially impairs the condition, value. i FINANCE CHARGE - Tte dollar amount you pay for money borrowed is cared a or protection of or our right in any property you gave as security i ltn3nce charge and begas on the dale of each advance. A finance charge will be The following paragraph applies only to borrowers in foiva: You will be in i computed separateiy for each separate balance under the Plan. To compute the default d you ate more than 10 days late in making a payment. You will also be in finance charge, the unpaid balance for each day since your lost payment (or since default it you do not comply with ilia terms of the Plan and your tailtire to comply all advance if you have not yet made a payment) s multiplied by the applicabe daily materially impairs any properly you gave as security or your ability to repay what you peticatc rate. The sum of these amounts is the finance charge owed. The balance owe under the Plan. used to compute the finance charge is the unpaid balance each day after payments The following paragraph applies to borrowers In all other states: You will be in i ano cre&ts to that balance have been subtracted and any additions to the balance defrtult it you do not make a payment of the amount required when it is due. You wilt hnve been merle. In addition to interest, vie may charge otier finance charges which be in default 4 you break any promise, you made under the Plan or if anyone is to i are Chlcltxed on the Addardunt, 11 the interest rase is a variable interest rife, the default under any security agieemem madu in connection with an advance under I AcIR a:,m explains how the variable in•aresl rate. war'. the Plan. You w:r be in default it you bia. Ilia for bankruptcy, become insolvent. if you SECURITY - lk. u pledge as securq Ica ins Mar. all shares and Jvicends arid, if any, m ;ke any false or mis!nad:rig statements in any credit appicafion or updam of credit all uepcs,:s and intowst in ak join( and ndiriduai accoums you (rave pith us no•.v and 1 Inloicna:io". or it someirnn.. happehc we believe may substantially reduce Yom ...lutura. r a ,vord•;; dolar amounl o; pk ou-',d lcr an advance. we rail frr,.ze ability Its repay venal y:±u owe. You wr9 he in default it any property you have gi:mn "^stICS A' !hat iacroun: lo the emeat b! :rrr+ ;:U!SGInOkit,? t4i;ance far the advance- i 7s as S.:CI:fay ;s (epossessod by scmeti :e else. seized under a forfeiture or rimilai Q.'ter..?se, sour p:vCgee snares may be w.i:vdraa•n tenk*s you are in debuil The tg,e, br i! arythine arse naplr.;ns :!•:,I Sic ii!icarlily effects we value of the prapern>/ or following paragraph applies In all states except in Ohio, Rhode Island and ` our s°CW iiy t verest ,n +t. y;u w:•1 aIr'u be ir, default under the Plan if you are in detaul; - Massachusetts: We have a sLuoto i lier. on e:e stones and iv%idends and, if any me I. cndt;r any J[her l;,an agree;n?nl-:701 e•S. n,„sa.- and (nt r<^s; r:r all rnC:v d lief and !Dina accoun:s vLni have v'btlh us and may ? ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers In ex+Lc•so o.;( rrgrus und!@r the Len to the e'aent perninle., by stare wee. (We are state ., peen.` :: deer name dues net inc!uae the lem1 'Federal Gre;m Urusin') For all I Colorado, District or Columbia, !Diva, Kansas, Maine, Massachusetts. ilfissCurt, borrowers:The statute lien andfor our Nebraska, Sawn Carolina and West Virginia: When you are at default and after statutory y pledge will allow us to apply the funds r r rarer o` ar.• w f i you tiave jnder stab law to Cure III your account(s) to what you owe when you are in default. The ststulor,• lien and G• / ?'• ' pSCaUie your CawuN:. v:e can .:. ; ,o •:? r..-,* .vin".a•td arrj 1r. c:,- U,;i: 1t;ua kHu.,menl rut^qu•C Of :cry O! :C( aicacrl im nc6.:i!C- oa/mvn? :?! I?,,, Cnt:r- unpaid ba!snca under Ine PL-11 vot'1Gut a i, os_ Std pal :a;. uca•.n:.:•1: un.:?r sate w ! Jcra: p.: if y.:en „? se_?iity Cr,n:y '-)u edv:,rcr. rice ct i.?... The following paragraph applies to borrowers in all other states except Wisconsin r.• i rei.v bi' r -_-,•ad at tr,t I:mc of an ai:err;? if a ' i and Louisiana: `Nryr. y .; c, ce..::;lt, ::g Can rx u:re unr+rl:atBrcent z pro::•r; x rs -tic:, calf: ii7, mint g!:d 11•il1 i G 1 'ct _ r%rid 35 Rh: •P till uryrr tea' 5:•D`a "r n..+l: A M!7 _.:rcr: nil td°.itC't. ••Jcr:CQ Fran Y'ir w. a::•e Grit lit)" jttave t•..-, :. - :p .rri..? _ a.. ?r,:'+.?r. and r: .toe... S_....r.: 1.; ^t.3n•:+ir i n:,:: ?I:-rr 'V'11;4 n! CJ!: so? _..'t ' ,. ..:,.. _ fit. _ Ji ur._ .:8;, !, Mi:, .. •... ••• ;•,r`-rt :.. ,,.,. n a^ ::_... ., .,r: rip !^ '? z:,[-ld r•: ;^t. Fr•y,,er: ::, The 10UOLr,ng paragraphs app:n to borrowers is all slates except lvisconsin and a!: , Lci isiatia I:.r .: e _ .. _. t d: a I ,.. ;f •ie:. fo . a; rr_r cr!,, .. ... . .. .. :. . r.. t . , `. .. . .... .: .-. .. :. .., ::'-.,• :". :-,.-, . ;:9. •. rug .. _. r ..... - .. r- r., .-, i Credit Agreement (comrnucd) ability ca exercise Our rignta laser. We Can e0oice this Plan agganns! your heirs or LDANLINER' Credit and SecurAy _u t::_ detaur rate 4-,Closcd on 'ho Addenda-, 11 a dtm,.and for :lotto la o vayment fegi: reolesorra!ves II wit's change the terms of the Plan" you agree that mis Pian nas beor may-,e. your shares at-41cs ;trip=cots oils Ce apzirrd :^.:tarCS N^a! You ohte wilt con::rue to ; rot[.-( us 01! Sec'?n ay?-,e ca,led S?ru••ry "re car. r.:su e:er ase ary other i CONTINUED EFFECTIVENESS - f[ any part of Ihrs Plan is deternmed by a court rr4ii:s ,pve!, by law when you ar•: in de!aufI - ;O be uner' ceabi- the rL .: W.a rt±rna:n in effect. .34 You agree :lie Cre•i•t U- on h:3s :he- rigai to take powwssion of a: y prcpeny given j NOTICE TO UTAH BORROWERS - This written agreement is a final expression of as secur•. f under fie Pran. vrtheut judiciW process. :f this can be done without ' the agreement oetween you and rite Credit Union. This wrinen agreement may not i breach of the peace. It we ask, you prortise :r, dolnrer the property at a time and be contradicted by evidence of any oral agreement" trace we choose If the property is a moter vehicle or boat. yOu agree Ihat vie may rho follewiap is required by Vermont law - NOTICE TO CO-SIGNER - YOUR obtain a key or olra;r de-Ace necessary to ur;ock and operate it. when you are in t SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE defaun We hv:+7 rol be responsible for any other property, not covered by n:is Agree rent. Mai you leave inside the property or that is attached to the property. Vie , FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, -.-dill :ry to return that prOWly :o you or make it available for you to claim. I THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. After we have possession of the property, we care sell a and apply the money !o any The following paragraphs apply It you give security in connection with an amounts you eve us. Vie will give you notice of any public disposition or the date after advance (order the Plan. They apply to borrowers In all states except Louisiana. t which a private disposition will be hell. our expenses for taking possession of and Louisiana borrowers will execute a separate security agreement. Borrowers in selling ft property w8 to deducted from the money received from the sale. Those other states may also be asked to execute a separate security agreement. costs may include the cost of storing the propeny, prc-parir ig it !or sale and ahemey's fees to the extent permitted under state law a awarded under the Bankruptcy Code THE SECURITY FOR THE PLAN - any You . receipt us what is known a security ! interest in an property desaibeU in n-arty receipt, voucher or otter document you': You must pay any amount that remains unpaid after the sale money has been applied receive for an advance f'Jte Advance'). The security interest you give includes as f to any urnptaipf balance uhr er the Pian. You agree to pay merest on that amount at the accessions. Accessions are things which are attached to or installed in the property t sane rate as the advonce, or, it applicable. at tow default rate disclosed on the now or in the future" The security interest also includes any replacements for the E AWerwum. until the! amount has been paid. property wt ch you buy within 10 days of the Advance or any extensions. renewals j The Wowing paragraph applies only to Wisconsin borrowers: When you are in I or refinancing of the Advance. 11 also includes any money you receive from setting i detavit and after expirat on of any right you have under applicable slate law toque your ! the proporty or from insurance you have on the property. It the value of the properly i default, vie may require immediate payment of your outstanding ban balance under the ! declines, you promise to give us more property as security if asked to do so. Plan and seek possession: of property given as seclrriy. You may voluntarily gins the f WHAT THE SECURITY INTEREST COVERSICROSS COLLATERAL PROVISIONS property to as it you choose. or we may seek to is' a possession of the property by The security interest secures the Advance described in the receipt, voucher or anr uAdal process; H we repossess the property: you agree to pay reasonable expenses other document you receive at the time of the Advance and any extensions, renewals irxxrned in olsptxring of grit property. {it the property is a mote vehicle, mobile home, or refinancings of the Advance. It also secures any otter advances you have now t,ailer, srtcwmobde, boat or aircraft, you well also be required to pay arty costs permitted or receive In the future under the Plan and any other amounts or loans, by Section 422.413 Of lea Wisconsin Statures You roust pay any amorun that remains Including any credit card loan, you owe us for any reason now or In the future, I unpaid other the sale mm?'eY has been applied to what you eve under the Plan. Ycu except any loan secured by your principal residence. if ft property is household 1 1 agree to pay axerest on any unpaid amount at rite same rate as the advance, or, it goods as defined by the Federal Trade Commission Credit Practices Rule, the ' applicable, at the delaull role d4rrlr>setl M the Addendum, until that amount paid. properly wilt secure only the Advance and not other amounts you owe" If me property is located outside Wisconsin at tfie time of default we may take I it where OWNERSHIP OF THE PROPERTY - You promise that you own property you { possession of the property without judicial process. permitted by the state give as security or it the Advance is to telly the property, you promise is i$e you win use use ' the Prop"- is located. the Advance Wr that purpose. You promise that no one else has any interest in of t The tollowing paragraph applies only to Louisiana borrowers. When you are in claim against the property brat you have nol already told us about. You promise not j default, we can require immediate payment (acceleration) of the entire unpaid to set or tease The property or to use k as sectrtty for a loan with another creditor . balance under the Plan. You waive any right you have to demand for payment, notice until the Advance is repaid. You promise you will allow no other security interest or i i of imonl to accelerate and notice Of acceleBtion. If immediate payment is lien to attach to the properly Omer by your actions or by operation of law. , : demanded, you will continue to pay interest until what you owe has been repaid at f PROPERTY INSURANCE, TAXES AND FEES - You must maintain property lire applicable interest rates in effect unless a default rato is disclased on the assurance al! property you give as security the Plan. You ma Addendum. If a demand for immediate payment has been made, the shares and on Y 1 g may purchase j .esposits given as security for rise Plan can be applied towards what you owe. We the property insurance from anyone you choose who is acceptable to the Credit can also exercise any. other rights giver. by taw when you are in default and our Union. The amount and coverage of the property insurance must be keeptatie to rghts under any security agreements you have with. us us. You may provide the property Insurance through a policy you already have. or j through a policy you get and pay foe. You promise to make the insurance policy i CANCELLING OR CHANGING THE PLAN - The following paragraph applies payable to its and to deliver the policy or proof of coverage to us if asked to do so. only to borrowers In Illinois: We have the right to change the terms of the Plan from It you cancel your insurance and tat a refund. we have a right to the refund. If the j time fo time after giving you any advance notice required by law. Any change to tea property is lost or damaged, we can use the insurance settlement to repair the i interest rate at olne( charges wife apply to future att-lances. property or apply it tc y eve, You authorize to any draft or The following paragraph applies only to borrowers in Wisconsin: Vie can check which may be payable ayab to what you u in order for us to collect any y rotun refun an check of benefits change the teems o'the Plan, from time:o time in accordance with Section 422.415 due urrtler your insurance policy. You also promise to pay all taxes and fees (tike of the Wisconsin Statutes" You will be notified of any change in term.. An Increase registralron fees) due on the property in the daily periodic rare under a variable rate interest rate is riot considered a change in terms taller the Plan. We can cancel the entire Plan or any part of the N you do nW pay the taxes Of fees on the property when due or keep it insured, we may Plan at arty lime. You may cancel IN Plan at arty time by giving us prior written ? Pay these obligations, but we are reel required to do so. Any money we spend for lazes, notice- Your obligation to pay the unpaid balances under the terms of the Plan + letz vi insurance will be added to the unpaid balance of the advance and you will pay Contflx,es. whotlvw you or the Credit union cancel the Pian, except to the ament that ; ,nleresT on those amounts at the same rate you agreed to pay oil rte advance. we may yo it taOi y :s Herded by Section 422.4155 of the Wisconsin Statutes. ? receive pay mants it ccrnectuon with tie insurance hem a company which provides the insurance. We may monitor our :owns for the purpose of determining whetter you and The following paragraph applies only to 6orrotivers in lrnva: We can cnanga :he j Og1Pr borrat'ers leave o?;npfted with the insurance requirements of our ban agreements I ton -is o: the Plan Isom tune th time after givhrg yo--- any advance notice r quired by I or may engage others to do so. The insurance charge added to an advance mev include A charge the: increases we race of `finance charge or etnor cnama, that 111 the inswahct. comparess s payments :o us anC 12) the cost of delerminag compliance f +!v_'reaSeS itte amount of your paynhents• or that ov"erwKa a.varsa:y affects existing - . rrn the ussurartce ter, yirement,. N we add amounts ter taxes, fees or insurance to the i Ca:anCEs wilt anply to ex:sung ba-antes Only •r• you agree to the change cr you use ' i try r,4 balance of an ed •an^e, r.?, rivet increase lour payments to pay the amrn,r:; : me Pun at:er receiving nit?,^e it-a; yJur use of :he Plan means yot: agree file i added warn the tern of the insurance or approximate term of the advance cnangs applies to existing batanc.es INSURANCE NOTICE - It you do rot purchase the required properly Insurance. The Wowing paragraph applies to borrowers in all other states: We n w Ise f Inc :rsurince we- may ' f'ui cnase and charge you for vtill cover only cur interest 11, rho r.-'-:! to rge me terra of the Pa: r: rime to I'me after ;r: inn you nrrcc ' The premi:,;m f._r ims in5urani.E may be higher because the insurance i rC?Cr requd;,•ulr.•q by i3PI A^.: Ina c x:!erCS: is /a:a -.v!;:; ativf to i4tur, ' advovar_es. poper fy. y ; ., '1':i W J!:r ,? ci„j a••., rr • tsr: _ On'p?r!I:y f.^. 11 !liihC J•1'i?n us Isle (ignt to purcha$e insurance aster n:fltnst:rr!d -szcf 1:•r. and tle.t :o any irquee^:C"nt5 0 ?trc:r:?:e la'i'r. :v:. ,,.. cof;a:Ara?,s lost or cama3_l. The insurance will not be liability insurance and a;-ley is unf.-a.d ba:anccs. The loAcwfn will not satisfy any state financial responsibility or no fault laws. - g paragraph applies to all but Wisconsin borrowers: Ar- rncre-z&e :r. : for !I,.:_ PROTECTING THE --iv SECURITY INTEREST - If p•jr stet.: is$w3s a t?t' . t::y ,;r:r ?,rc tale u?aciar :. r:ft„,asp ra:C- i ::r.:iC!crr=- r rr:;age m y • ,:Or Fr . , - ?• '};_ pglCa^?y. you proms.; :O K Y "c. Carr secs::y in1C"rest Shot:n on ;he faic `Nit may ::.,•;B - r'•;.^...^ _ ,:;•' f:: : re P'.il C'r :h'1.1 :<;/1 l'1 Yw; at :1 T: r .. n; -r t P . r t - ^q s not. r Y I is c?lrn, 1.r' ,Cull d.-;•mcn: ;r p•olect ours Ct oily u.rr s !r,.:>,:! it*.(! i-.rr s f -.t rte ,' ,+. t,.:„ d, ;;r? milli- IC •a G` ••'c' Fan 17 sign a tnancew s. a,t r.em YOU C L...- ...: t- 1 -.: r! S I .. . - :•; ,,...-?.. _:.: r._r ^: l t _ !r...:.?-:.. ., .;rr :C '. ] :.:uc•_ ter •. -_ :•?r,• t:,.r:k ,., ne_::ssary to pm!cc: O::r t-r - 1 ?? , .r. r ;? p r r : ' p ,all" Cr:c ; mCht':rnq t•vl r. D! .r;:.:. all E_ ::r DELAY CI ENFOSCiri RIGHTS AND CHANGES IN THE PLA ;. ,•,.?i,';:- _ r .-r r' hr:.2r, t and r7^L q pry: Cr l:. (continued) L_OANLINER` Credit and Security Credit AgregL_ rlgqt USE 4J PROPERTY - tin!:1 ha Ad+a:ce has been p:.iC cif. cu y(om+ee you .l:.Jya if-.e preG4rty catefu!ly arm, i•eep it •n grid recaii. i2) Ott:lin our written f;otmrcc.or: before makm: maid'r oranges tr• the property or changng tr:e address mere the property is kept. t3) 1nt-arm us in wtunq before changing your address. (41 AllZn us to rnSC'ect the property (3) Ptornpdy nol:fy its it the property is damaged. stolen or abused-(f•1 Not use the prwerty for any unlawful purpose (7) Not to rehtle property in another state wither. Leta :g us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE - T)iE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. . NOTICE FOR ARIZONA OWNERS OF PROPERTY - It Is unlawful for you to fail to return a motor vo hive ttat is subtect to a security interest. within thirty days after you have received notice of default. Tice notice will be mailed to the address you., 1 gave us it is your responsibility to notify us d your address changes. The maximum This nottee contains Important Information about your rights and our responsibilities urder tote Fair Credit Billing Act. You are advised to read your monthly statement ar•d review it for any erax discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT. if you think your statement Is wrong. or it you need more inlotmation about a transaction on your statement, write us on a separate sheet at the address listed on your statement. You are required to ndtity us in writing within 60 days following the dale on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transactions on your account Failure 10 notify us may result in your acceptance of any responsibility for payment or reimbursement to us for any such error or discrepancy on your account. Write to us as soon as possible You can telephone us, but doing so will not preserve your rights. In your letter, give us the following `.rbrmation: f Your name and account number. The doper amount of the suspected error. th.cribe the error and explain, if you can, why you believe there is an error. It you rived more informal-on. dnscr:be the item you are not sure about. If you have authorized us to pay a credit card account automatically from your share account or checking account, you can stop the payment on arty amount you think is .'Fong To stop the payment your fetter must reaLh us three business days before the i aulomatic payment is schedu:ed to occur. i YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE - We must acknowledge your lotter within 30 days, unless w'e have corrected the error by then. Within 90 days. we must either correct the error or explain why we believe the statement was correct. For those members who purchase a vehicle under the DRIVe Program, please review the following FTC Notice: NOTICE ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED WITH THE PROCEEDS HEREOF RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. After we receive your letter. we cannot try to collect arty amount you question, or report ' you as delinquent. t Ie can continue to send statements to you for Ole amount you question, including finance charges, and we can apply any unpaid amount against your credit limn. You do not have to pay arty questioned amount while we are investigating, i but you are still obligated to pay the parts of your statement that are not in question. If we find that we made a mistake on your statement, you wig not have to pay any finance charges related to any questioned amount. It we didn't make a mistake, you may have to pay finance charges, and you will have to make up arty missed I payments on the questioned amount. In either case, we will send you a statement ! of the amount you owe and the date that it is due. i 0 you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within on days telling us that you stilt refuse to pay. we (Host tell anyone we report you to that you have a question about your statement. And. we must tell you the name of anyone 1 we reported you to. We must left anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, vie can't collect the first S50 of the questioned amount, a even if your statement was correct. F SPECIAL RULE FOR CREDIT CARD PURCHASES - It you have a problem with the quality of property or services that you purchased with a credit card. and you have tried in good faith to correct the problem with the merchant, you may have the right not 10 pay the remaining amount due on the property or services. There aro two i limitations on this right: (a) You must have made the purchase in your home slate or, 1 if not within your home state, within 100 miles of your current mailing address: and i (b) The purchase price must have been more than S50. 1 Theso limitations do not apply it we own or operate the merchant, or it we mailed you the advertisement for the property or services. - { In ma Agreement, the words you and your means each and all of those who apply I tine only by written application to us, which must tie approved by our credit commrltee for the card or whops this Agreement. Card means the Visa Credit Card and any or ban officer. By giving you written notice we may reduce your Credit Line from time duplicates and renewals we issue. Account means your Visa Credit Card Line of to time, or with good cause, revoke your card and terminate this Agreement. Good Credit account wit'i us Vie, us, aril ours means this Credo Union. cause inchtdes your failure to comply with this Agreemenl or any other agreement with 1. RESPONSIBILITY -It we issue you a card, yon: agree to repay all debls and the us, or our adverse reevaluation of your creditworthiness. You may also terminate this ! Fir•ance Charge arwng from the use of rim card and the card account. For example Agreement at any time. but termination by either of us does not affect your obligation to pay the account balance. ywti are responsibie for charges made by yourself, your spouse and minor children. You are also respmsibfe for charges made by anyone else to whom you give the 5. CREDIT INFORMATION --You authorize us to investigate your credit standing Cato. and this responsibility continues unii! tits =3rd is recover& J. You cannot disclaim when opening. ren&,v!ng or reyieviing your account, and you authorize us to disclose ' :es:.Jns:Dlity by r-Wying us, b:: we ran close the accourl for nee: transactions If you i mforination regatow-9 pow account Io Credil bureaus and other creditors who in-,ti-re ;•_ fi-quest and retum as cards Your c+igaiion W pay ale account balance continues i of us about your credit slarding dre)r. Ihp r,)It an agreement, divorce decree or other tour. judgmeni to wf;fdt we are 8 MONTHLY PAYMENT - We will mail you a statamr_-m every month sharing your . not a patty may drrev. you or one of the other persons resM. isibfc to pay Ine account. Previous Balances of purchase:' and cash advances, the current Iransact`o,'1s out your l l+_ _afds remain, our pv4"ty and you must recover and surtence'r to us an cards i aiorrunl, try: temaIning creeda available under your Credit Lune. the Now &-lances cf u, ,n our request and upon terrnerta::on o: this Agreement purchases and cash adlrances, the Total New Balance the Fin ance Charge dun it date ' 2. LOST CARD NOTIFICATION - 11 you beli•;ve rim card has uet:n test or clolen, I and any °sher billed fees, and the Minimum Payment re ;hired. Every morn you must pay ' YrJU .+::7 :^ rrediateq can info Ger. l Uricr• a1 1717) 23--t?c pr ai0i 1 2=3%• 7328. At[,,( i at least tie k6rh nr.;m Payrran: w;trhr, 25 drys of your slatrarierht closing date. By sepa:ale ' h^urC ..ill Sjb-51175 • ayre-er:zr: you nnay aus t•) Cmatgr: the miniint:m payment autornaticll y to Your ct 0!e;?:mg aCC'*wnt 'A-:h us. ibu May. of course. pay more 4eq::enlti. piny :node - 3. LIABILITY FOR UNAUTHORIZED USE -)(,:,j a;trir 1C cq•..`, u: y. c+:t!':' 4?an L':•_ t,':rrn;:m r ay-erl. cr pay Ili2 ltnii/1 N@W Bdil.;E.' in lull. and you vrrJ rerjUS tile . •.)r r. r.rrry ;, ;inC >;i::5. c-'tI p;nau!tzit q:, :..v' n: yx:r C+a'i! :act You m3.; t•.: elite Sra:`e4 d'C2rlc- t: dui^; eve 1' ynw rri6rtP.!y payni»t c<meds L'ie Woo! Crg(fil nrq: ba:nrtcC 'Or J'C cry 1n,:nicd use :' vu:d C:s;-- ,!t not ., iiaL:, Ier wmt,'!`c: v_i-.cf u;d - r nat.<;a'ry it :o v-v u he ere ?• q:. -.? -.". your St snares t Lti dt'ef yr}' tar J : n, F n -E. , r Fora .IPJn: t•z.4 us,- J N' ! r. 9;r -.a A ^ !anti i <,rn y: ur Crec+Gar:: r c, ar 7r c ; !Ile m'aur,lnl f ai.nnr. roe; CC lei 23, of join Tr,!di New Balance. tOtfnc?:1 up to ti`e , . _ •ii: _. ,CnE n It:e %:d't,^^1 t, ?t(x)t l t ire a•-. r 1 c .r 1 rC ! r 7• aC 'J J .v < .. r r h ?r rb ele', .t k iea:Cr In r c•+g aft! cit. c; a:y :.mc ; wr T .al i \ G I _ _ s Lrr , V ,>j a u 1 mn-edt3le:V pay the a cLSs apor. -_F a. CREDIT LINE ..,. SL' s 1 '4 -; .'rG• `7 en 'J \.rC mpnnCt' l,I,1 ii pIC\?GJS late Ices . r ' L:`_ ten,. eft ;:C a.-W. a .:J a .- •.'1b, _:'1 1. ^•i , _ R 1:,. ' .%an._e, shill J?:`, 11'en 10 f.re.!Cus putCjwa t Lnwi'.. r) e , .. t.-. .r-.A+ , 1 r. . ..._. ..i ..i r- ., rr; .•l: _'i :-._. .:.f l:_ . a.. _., ...' .._ .. ... r? i••r,? .3 ?y a\Gr2 posted . '1'O Jr 1CC=Lr? ,'e'• r r , Vr .• r.;. , ,_ ..;j r,y r, . i z :.n.a s .r :._ ; ir.ercd-; : C:.r:u t r,' .i _., .i ,r3 c?rn•n; pircr.ase c;dar.ias p?ra!°y k,•r L'I!aW?fUl !alurc to return. a motor Vehicle is one year in prison and: or a w:a: i .t,e of S150,000 ?-.rot,:-`'.%•',: M Viss' Credit Card Agreement and Truth ht Lending Disclosura (continued) 7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by paring :tie lUa amount of t:ta Key, Balance of Purchases each month within 25 dayi of ,tour s:alemertt clos ng date. Otherwise. trio Nev: Balance of Purchases, and the su_tsequ:ent purchases from the da!a Choy are posted to your account, will be subjecl to Finance Charge. Cash advances are ahva s subject to Finance Charge from the date they Pro posted to your account. Purchases: We calculate your finance charge by multrpiy?i1g the average adjusted dairy balance (see explanation be:fovv), including new purchases, for the titling cycle bytre monthly periodic purchase rate and certespondling ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Cash Advances: We calculate your finance charge on cash advances !:y multiplying the average adjusted daily balance (see explanation below) for cash advances during die billing cycle by. the monthly periodic advance rate and corresporuliog ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Daly iWarice her Prrchases - The Average Daily Balance for Purchase Transactions is Calculated by adding the Daily Balances (Purchase Transaction) for each day in the billing cycle, and then dividing by the number of days in the boiling cycle. To calculate the Daily Balance for purchases each day. we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day Than, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post f to your account that day. Attar applying payments and credits, we subtract the amount of any unpaid Finance Charges or late Charges Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day in the billing cycle. This gives us the Daily Balance for purchases. Average Daily Balance Ilor Cash Advances - Cash Advance Transactions which are posted to your account are not intkwed in the Average Daily. Balance calcutatlon for purchases, and are therabre rout subject to the monthly periodic rate for purchases. The Average Daily Balance is cak-milated separately for Cash Advances and is subject b the Cash Advance Monthly Periodic Rate. The riverage Dart/ Balance for Casts Transactions is calctdaled by adding the Daily Balances (Cash Transaction) for each day in the billing cycle. and then dividig by the number of days in the billing cycle. To calculate the Daly Balance lot rash each day, we take the Waiving steps: We lake ft outstanding bata. ice fall amounts you owe) at the start of the day. Then. in the sequence in which amounts i are posted to your account, we add the amounts of all debits and sttetract the amounts of all credits or payments which post to your account lftat day. Attar applying payments and creme. we subtract the amount of any unpaid Finance Charges or late Charges. Then we also subtract the amount of arty Purchase Transact:ons that posted to your account on thal day or in arty previous day it the billing cycle. This gives us the Davy Balance for Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account. Payments are applied in the Wowing manner: first to previous late fees. then to previous cash advances finance charges, then to previous purchase finance charges. then to current late fees, then to previous cash advance balances, men to previous purchase balances in the order that they were posted to your account, then j to anent cash advance balances. and than to current purchase balances. Credits are applied first to the particular type of debt which is being credited. 8 any. and then 1e the balance of your account. Note aso that if the total of the payments and credits which are posted to your account by the Payment Due Date shown on a statement is equal to or exceeds the New Baiance shown on that statement, we will not apply the Monthly Periodic Palo to your Accou>rnt on your next statement. 8. DEFAULT -You will be in defautt i1 you fad to make any Minimum Payment witf :n 1 25 days attar your monthly statement closing date. You authorize, us to transfer (silos sufficient to make the minimum payment due if your Visa loan is in default. You vAll also be in default if your ability to repay us is materially reduced by a change in your employment. an increase in your obligations, bankruptcy or insolvency proceedings involving you. your death or your failure to abide by Mrs Agreement, or it she value of our sec=drily interest materiaty declines- We have the right to demand immediate payment of your fill account balance d you default, sub;ecr to our grnng you any nonce required by raw. To the extent permitted by lav.t you will also be required to pay Our cane.:lion expenses. atcludfig court arias and reasonable attoirey fees 9. USING THE CARD - To make a purchase or cash advance. mare are rso ailernalive procedures to be loflo::cd One :s kr you to present the car^ to a R3rticnpal4sy'visa plan merchanl, or another financial inrulu on, arc Sign me sates of cash ad•:antce Cralt wn ch tall be impr need :•: nh y,ur Card. The Ottie4 it/ :o cotrplefe the :rant-action by using your Persgn2l Ider.:d;cauan Numt» r (Pita in cone:nr_liGr. dart: ate -Pic it at.. Aulomaled Teller Macnine for oti-er etr,, of et:;CLon.c htrrninal th.11 prow dos a•Mess to the •,/_sa sxs•err.. Y cu a rut the: ou :nil no 9 y [ use ;d •r card r, ;r any i U^rs o-lon S,at is Aeg-I urde-r api:4Y... fed-;ra:. slat_, or f-:;at I?.,v Tn rCa l C ::her i sla:emEr.f %vi:I iderti!y rnf mere^.a.^.:. ele• u,onLc ler.mt tai or !Rlarcial :nstrful:on al l'ied' made- CA ?i:n. cash acT.'ance. ciLdst Cf ot!h;r s:.ps carnet i be returned with the statement. You will retain a copy of such saps tutnisred al the time of the transaction in order to verily the monthly statement. The Credd Union may ' make a reasonable charge for pholoccpies of slips you may request. 1 10. OVERDRAFT OPTION - 11 you elect to overdraft to your PSECU Wsa Coed: Card, that election is subject to lha existing creel t emit and the agreement it represents and the current ban policy at the time of the overdraft. You also understand that an ovorcirah will be cons.dered the same as a cash advance on your PSECU Visa Credo, Card and that the current Annual Percentage Rate for cash advances will apply. 11. RETURNS AND ADJUSTMENTS - Merchants and others who honor the card may give credit for returns and adjustments, and they will do so by sending us a credit slip wtnich we will post to your Visa One of credit If your credit and payments r exceed what you owe us, we will autontaticaty post the excess credit balance w your St Shares within 75 days. If the balance_is one dolor or more. upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS - The exchange rate between the transaction currency and the bring currency used for processing international transactions is a rate selected by Visa from the range of rates available in wkilesale currency markets for the i applicable central processing date. which rate may vary from the rate Visa itself receives, or a govornment-mandated rate in effect for tlne applicable central processing ' date. In each instance. an adjustment may be assessed based on the ISA fee Ynposed by Ytsa. This be. which totals 1% of the transaction amount. will be assessed on as transactions where the merchant country differs from the country of the card issuer. 1 13. SPECIAL RULES FOR VISA PURCHASES - K you disagree Or find an error wilb a Visa transaction, and have tried in good faith to correct the problem with the merchant or the charges are the result of unauthorized or fraudulent use. or your I purchase cost more than S50 and was made from a plan merchant in your state f within 100 miles of your home. contact PSECU. f 14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing within 60 days Viewing the date on which we sent your statement wherein the error or problem fast appeared regarding any discrepancy or unauthorized transaction on f your account. Telephoning PSECU does not preserve your dispute tights. You may I# be required to provide us with documentation to support your dispute claims. In j addition, you may be required to complete a standard dispute form outlining the j details of your dispute. In eases of fraudulent card use, PSECU wilt also require a notarized affidavit. in some cases we may ask you to notify the toeaf authorities. 9 we do not receive the proper requested documentation in the time spa stied you may be held responsible for the transaction(s) in question. PSECU must adhere to i strict dispute teneframes set north by Visa. 15. SECURITY INTEREST •- To secure your account, you grant us a purchase money security interest under the UnHo?m Commercial Code in any goods you purchase through the account. If you defauh, we will have the right to recover any of i these goods which we have not been paid for through our application of your ) payments in the manner described in the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have it you are in j default to prevent withdrawal of your unpiedged credit union shares (Deppsilsf below the unpaid balance of your account. However. if you give or have given us a specific pledge of your credit union shares (Deposits) by signing the Pledge of Shares of otherwise. of any other security interests lot all your debts, your account i well be secured by your pledgod shares (Deposits) and by the property described in those other security agreements, except for your tome. 16. EFFECT OF AGREEMENT - This Agreement is the contract which applies to 8:1 transactions an your account even though the sales. cash advance, credo or other slips you sign or receive may contain d:ffetenl terms. We may amend the t Agreement from time to lime by sending you the advance written notice required by i Iaw.Your use of the card thereafter will indicate your agreement to the amendments f To Ilna extent the law permits, and we Indicate In our notice, amendments will aopty to your existing account balance as web as. to future transactions. 17. LATE PAYMENT CHARGE -- If Your Minimum Payment is not received by the ? first day of the month following your due date, you vAll be subject to a S20 charge. 16. RUSH FEES - You may incur additional Charges for rush processing and rush delivery of cards and/or PIN mailer. 19. OVER UMIT FEE -A S20 fee 'Mil be applied t each monthly statement cicSinq biota an vt!ticti ate btrswfding balance exceeds the a,s!gned crMil limit by more titan S 1 iYJ 20. DRAFT COPIES - You may incur an additional charge sor transa;Uon summarylsale drain documentation. 21. COPY RECEIVED - You acknowiodge recotpi of a copy of th,s Agreement. 22. ILLEGAL TRANSACTIONS PROHIBITED - You agree. than you wr:l not use r• ur card for any transaction that is illegal under applicable federal. s!a!e. or foeat law 23. NO USE - Iraet. v Visa accounts ilia! have no purchase or cash activity may be closed Lvntti.Ul not.::e to you alter 16 morims of no acuvity. 24- NEURAL NETWORK - PSECCU uses n!-oral nelvica syitenl5 :U pv,o'l ar::i Dfinenf Ur-aulriGn:ed transaclions. Tnere may be Occaston5 :':non a ICe:aa,:,0.1 K. lod!ned be:car>e- it is rndwatn•.? u' po;sitdn fraadulin: acnrry. r?'?? 0 z c 9 -r 1 • S c O c O N ° a? c6 o t ° Op0' S O r O O H m p ?Cp0.OOOOOO00ppO0OOOOOOO "• ?) E P LO C E /?. -•O N -ahN O P 00 h ?riCN - ..? e C- M V # ?? S • 9L p g ? ?QS r _p a-?ty G C L O CQ^ 0 C C E 10, f 0 g E c •oooo080000000000S .e E >T im n 'I lafNMC4N(4V (NY(O`?.m•O ? NOO?DOO • 'f T aOV ; `o ° u O o M ?.% q.S L. _ v o ? e g 4 e y ? 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V` 40 O O O C C O a r0 c j.Cr?? ? 00'C>0 - X0 1-h0- (n 00 v01 P r,'q0" NOOVMO NtnP Mr lpW Ntnl0r?v0 00 00 r? 00 M . O.. 010 C_ v c .O m 0,0 N010M000 tnNPr?.tA!V 0 --t°104M? WIlV)NPIC4 NO s? C. - °aO i _ p v _ y- - - - - - MMNNN? -- 0000 0.0.0.0.0. T Omw WCO Cl w0 > ? c -: y ^-y cc+1°^ lJ OSrOJ NNNtvN NN(VNNN NNNNNN N----'--? } 0 uN -0 O ri " oo O v 000000 000000 000000 000600 000600 r. o O OX>?O°0.O c. "o'cLN cu MMMMMM r)r)M,qvv vvvv-zv vwuntntntn tntnLntnoo z -0 C- CIZ Z,-- C,_ ?S ? t..:=oN` i-°" Y tom .21 c O p 7," ?tN o :. c `' 0 3 000,0^10 NOvr?r?v Py vr)WW 10N?MM0 Nt?PI")OV IL o A J' 0000."01 OWOtn 10N Wyvy avr?op-tn ?- w o _, ;o OOOM10 r` MOWVivN OP I, lolnv MC4_00P WWt?1?•010 Y? O i1 ZT'r 10 t• is = -L %' 0001n,nV) u).nRyyy yr7 Mr7MM MMMMMN NNNNNN [ c G ?. u y 2 c c 01" OOOOCO 000000 000000 -666666 000000 z y y c-iJ Bs c Ec Cc m9, - t :• 4 Ci-' .n `O P; O-N MY tAK>l?Cp POD-NMR to 10?aOP0 r. z Un2 V.`- 3 _.C i_Y CGi' LT :.C C K NM V.oJP NNNNNN a -. 5 u c c a w O S O S W EXHIBIT "B" COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST JORK, PA 17401 ., 5. I. S. 7. INDICA NOW to law-' SHERIFF SERVICE , PROCESS RECEIPT and AFFIDAVIT OF RETURN , SIP rr? anon t- {V SERVICE CALI. (717) 771-9601 1 TF#tU 12 . ' COPIES 4. TYPE OF WR OR COMPLAINT NOTICE,CICA &4?LNn no Y-5 - iiy`L? 5. E OF IN VIDUAL, CO ANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIE , ATTA HED, OR S D 6. DDR S (STREET OR RF VNTH BO NUMBER PT NO.R , C TY. B . TWP TATE ANDIP CODE) t , m ienn .j it-rue RVICE: PERSONAL 451 PERSON IN CHARGE U DEPUTIZE , 1 CLASS MAIL U POSTED U OTHER 1/1 A Ick M-A W1 tot 20 I, SHERIFF OF O NTY, PA, do hereby deputize the sheriff of COUNTY to exec ig'make retur heyQof-according deputization beinq made at the reauest and risk of the nlainfiff .7 -PF?liiilii? rrr/ ADV FEE PAID BY ATTY. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy shell( levying upon or attaching any property under within writ may leave same without a-watchrnan, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for"loss. destruction. or removal of any property before shenfrs sale thereof. 70NO11u, A ORIGINATOR and SIGNATURE j ? d ' TELEPHONE NUMBER t t FI Ep ?nA M9 ' VIA (-1 VI YI D ?/ I 1 /? !tl 1'?c-7 11 A. r_7 1f,? PA 12. mil SuMT F M LVV V&n CY, !11 &,X 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date or oorrrplant as mdrated above. MJ MCCiILL YCSO 3-23°2009 14-9-09 16. HOW SERVED: PERSONAL( ) RESIDENCE ( ) POSTED(.) POE ( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 18. NAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20 Time of Service --l 21. ATTEMPT T n to Time Miles Int. Dale Time Mika Int. Date Time Miles Int. Date Time Miles Mt. Date Time Miles Int. 22. REMARKS: PER POST OFFICE CHECK, Nl-'6d ADDRESS IS POST OFFICE BOY. 3, RHE-EMS, PA 17570-0003 23- Advance Costs Service Costs 25. N/F 26. Mileage 27. Postage 28. Sub T? 29. Pound Notary , 100.00 ©U 6,06 14 1 12d 5 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. 38. MileagerPOStagdNot Found 41. AFFIRMED and subscribed to a me 81i S so A of 42. day or ?I r? ?110 Ts be We Dep. Signature -? _-. Sheriff P I AL 46. Signature of York L? I- t UELIC County Sheriff _.^:;C , .NTY RICHARD P. F , SIiERIF ViiC 12, 2009 48. Signature of Foreign County Sheriff 50. I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE 31. 739L 32. Tot. Costs 33 Costs Due a eland 43 Z Total Costs 40. Costs Due or 45. DATE 4. 47. DATE 4-21-2009 49 DATE 51 DATE RECEIVED No. I I 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - ShenffS Office OUT OF CO CUMBERLAND Shel.if s Office of Cumberland Cou?_.y R Thomas Kline 01F ct cannbrr Edward L Schorpp Sheriff Solicitor X Ronny R Anderson Jody S Smith Chief Deputy OFFICE of ThE SRERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03119/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Amber Connors, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint and Notice according to law. 03/26/2009 York County Return: And now, March 26, 2009 I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Amber Connors the defendant named in the within Complaint and that I am unable to find her in the County of York and therefore return same NOT FOUND. Per Post Office check, defendants new address is Box 3 Rheems, Lancaster County, Pennsylvania 17570. SHERIFF COST: $42.00 SO ANSWERS, April 24, 2009 R THOMAS KLINE, SHERIFF 2009-1487 Pennsylvania State Employees Credit Union VS Amber Connors EXHIBIT " U C 0?? HEN,if W. VAN ECK VAN ECK & VAN ECK, P.C. hwv@vanecklaw.net ATTORNEYS AT LAW " P.O. BOX 6662 TELEPHONE: (717) 540-5406 MELISSA L. VAN ECx FAx: (717) 540-5407 mlv@vanecklaw.net 7810 ALLENTOWN BLVD., SUITE B HARRISBURG, PA 17112 May 4, 2009 POSTMASTER Rheems Branch Rheems, PA 17570 REQUEST FOR INFORMATION 1S NEEDED FOR PHYSICAL ADDRESS OF BOXHOLDER FOR SERVICE OF LEGAL PROCESS Please furnish the physical street or new address (if a boxholder) for the following: (All former addresses are given). Amber Conners PO Box 3 Rheems, PA 17570 Note: The name and address are required for service of legal process. The name, if known, and post office box addresses are required for boxholder information. The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6 (d)(1) and (2) and corresponding Administrative Support Manual 253.44 a and b. Capacity of requester (e.g. process server, attorney, party representing himself): ATTORNEY 2. Statute or regulation that empower me to serve process (not required when requester is an attorney for a party acting -pro-se - except a corporation action pro se must cite statute: 65 P.S. 66.1 et seq.. Freedom of Information Act 3. The names of all known parties to the litigation: Pennsylvania State Employees Credit Union v. Amber Conners 4. The Court in which the case has been or will be heard: Court of Common Pleas for Cumberland County 5. The docket or other identifying number, if one'has been issued: 09-1487 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant VAN ECK & VAN ECK, P.C. ATTORNEYS AT LAW WARNING The submission of false information to obtain and use change of address information or boxholder information for any purpose other than the service of legal process in connection with actual or prospective litigation could result in criminal penalties including a fine of us to $10,000 or imprisonment or (2) to avoid payment of the fee for change of address information of not more than 5 (five) years, or both (TITLE 19 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with the actual or prospective litigation. t w Melissa L. Van Ec ,Esquire P.O. Box 6662 Harrisburg, PA 17112 FOR POST OFFICE USE ONLY STREET ADDRESS OF BOXHOLDER NAME: Amber Conners _ STREET ADDRESS: 10'7 G R Lcl DER A V E No Street address available ? ?? No change of address order on file. Not known at address given. Moved, left no forwarding address. No such address. MLV/jks EXHIBIT "D" Property Assessment Search Page 1 of 2 t,exisNexrs' 2417 Search and Technical Assistance 1-800-543-6862 for r G r Main M ni I MkAcrmu_t I Print I __4n ar.LUs I Log Out A?C C Coflectllssnaoons i. Last Name First Name Middle Name Company Name Street Address City State Zip Parcel Nu er Q 11 107 GREIDER AVE RHEEMS PA Output Type: (*- Formatted HTML ( Cut and Paste / Printer Friendly Text (No Reports) Important: The Public Records and commercially available data sources used in this system have errors. Data is sometimes entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this system supplies, it should be independently verified. For Secretary of State documents, the following data is for information purposes only and is not an official record. Certified copies may be obtained from that individual state's Department of State. Accurint does not constitute a "consumer report" as that term is defined in the federal Fair Credit Reporting Act, 15 USC 1681 et seq. (FCRA). Accordingly, Accurint may not be used in whole or in part as a factor in determining eligibility for credit, insurance, employment or another permissible purpose under the FCRA. Search completed SEARCH: Street: 107 GREIDER AVE City: RHEEMS State: PA All Property AsseE 9 Owner Name - WALTZ JEAN C cow Property Address - 107 GREIDER AVE, RHEEMS PA 17570 Owner Address - PO BOX 137, RHEEMS PA 17570-0137 Land Usage - DUPLEX (2 UNITS, ANY COMBINATION) Data Source - B Records: 1 to 8 of 8 ,sment Sale Date - Recording Date - Tax Year - Sale Amount - Assessed Value - $117,800 Parcel Number - 160-36082-0-0000 Owner Name - WALTZ JEAN C cow Property Address - 107 GREIDER AVE, RHEEMS PA 17570 Owner Address - PO BOX 137, RHEEMS PA 17570-0137 Land Usage - DUPLEX (2 UNITS, ANY COMBINATION) Data Source - B 0 Owner Name - WALTZ JEAN C cow Property Address - Owner Address - 107 GREIDER AVE, RHEEMS PA 17570 Land Usage - DUPLEX Data Source - A Sale Date - Recording Date - Tax Year - Sale Amount - Assessed Value - $117,800 Parcel Number - 160-36082-0-0000 Sale Date - Recording Date - Tax Year - 2006 Sale Amount - Assessed Value - $117,800 Parcel Number - 160-36082-0-0000 n92 Owner Name - WALTZ JEAN C Sale Date - cow Property Address - 107 GREIDER AVE, RHEEMS PA 17570 Recording Date - Owner Address - PO BOX 137, RHEEMS PA 17670-0137 Tax Year - Land Usage - DUPLEX (2 UNITS, ANY COMBINATION) Sale Amount - Et : V0 5® 21 tl https:Hsecure.accurint.com/app/bps/misc 5/19/2009 Property Assessment Search Page 2 of 2 Data Source - B Assessed Value -• $117,800 Parcel Number - 160-36082-0-0000 9 Owner Name - WALTZ JEAN C Sale Date - lift c? Property Address - 107 GREIDER AVE, RHEEMS PA 17570 Recording Date - *am Owner Address - 107 GREIDER AVE, RHEEMS PA 17570 Tax Year - 2005 Land Usage - DUPLEX Sale Amount - Data Source - A Assessed Value -- $117,800 Parcel Number - 160-36082-0-0000 92 Owner Name - WALTZ JEAN C Sale Date - cow Property Address - 107 GREIDER AVE, RHEEMS PA 17570 Recording Date - Owner Address - Tax Year - 2002 Land Usage - DUPLEX Sale Amount - Data Source - A Assessed Value •- $90,600 Parcel Number - 160-36082-0-0000 9 Owner Name - WALTZ JEAN C Sale Date - Aim cow Property Address -107 GREIDER AVE, RHEEMS PA 17570 Recording Date - 1010 Owner Address - Tax Year - 2001 Land Usage - SFR Sale Amount - Data Source - A Assessed Value - $90,600 Parcel Number - 160-36082-0-0000 9 Owner Name -WALTZ JEAN C Sale Date - cow Property Address -107 GREIDER AVE, RHEEMS PA 17570 Recording Date - Owner Address - Tax Year - 2000 Land Usage - SFR Sale Amount - Data Source - A Assessed Value - $90,600 Parcel Number - 9D 7 - 8 -11 Records: 1 to 8 of 8 SEARCH: Street: 107 GREIDER AVE City: RHEEMS State: PA Ec Your DPPA Permissible Use: Use in the Normal Course of Business Your GLBA Permissible Use: Persons Holding a Legal or Beneficial Interest Relating to the Consumer https:Hsecure.accurint.com/app/bps/misc 5/19/2009 EXHIBIT "E" Summary Report Page 1 of 3 Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this system supplies, it should be independently verified. For Secretary of State documents, the following data is for information purposes only and is not an official record. Certified copies may be obtained from that individual state's Department of State. Accurint does not constitute a "consumer report" as that term is defined in the federal Fair Credit Reporting Act, 15 USC 1681 et seq. (FCRA). Accordingly, Accurint may not be used in whole or in part as a factor in determining eligibility for credit, insurance, employment or another permissible purpose under the FCRA. Your DPPA Permissible Use: Civil, Criminal, Administrative, or Arbitral Proceedings Your GLBA Permissible Use: Use by Persons Holding a Legal or Beneficial Interest Relating to the Consumer Summary Report Date: 06/15/10 Reference Code: 46931-0000368 Subject Information AKAs Indicators (Best Information for Subject) (Names Associated with Subject) Name: AMBER A CONNORS AMBER A SHUMAKER Bankruptcy: No Date of Birth: 12/xx/1984 DOB: 12/xx/1984 Age: 25 SSN: 200-64-xxxx Property: No Age: 25 AMBER CONNERS Corporate Affiliations: No SSN: 200-64-xxxx issued DOB: 12/xx/1984 Age: 25 SSN: 200-64-xxxx in Pennsylvania between 1/1/1985 and AMBER SHUMAKER 12/3111987 DOB:12/xx/1984 Age: 25 SSN: 200-64-xxxx AMBER CONNORS DOB: 12/xx/1984 Age: 25 SSN: 200-64-xxxx AMBER P CONNORS DOB:12/xxM984 Age: 25 SSN: 200-64-xxxx Address Summary (4 - Probable Current Address) https://secure.accurint.com/app/bps/report 6/15/2010 Summary Report Page 2 of 3 W413 PITT ST, ENOLA PA 17025-2234, CUMBERLAND COUNTY (Aug 2004 - Jun 2010) Phone at address: 717-732-9692 CONNORS AMBER Neighborhood Profile (2000 Census) avPrao Ac .34 Median Household Income $36,618 Median Home Value:-W,8W Ave rage Ye am- ion: 13 4413 PITT ST, EAST PENNSBORO PA 17025-2234, CUMBERLAND COUNTY (Mar 2005 - Jun 2008) Phone at address: 717-732-9692 CONNORS AMBER [No Data Available] 103035 VALLEY RD, MARYSVILLE PA 17053-9516, PERRY COUNTY (Dec 2007 - Feb 2008) Phone at address: 717-957-3693 SHUMAKER LEE L Neighborhood Profile (2000 Census) Average Age:37 Median Household Income: $56,375 Median Home Value: $126,200 Average Years of Education: 13 9 DICKINSON AVE APT C, CAMP HILL PA 17011-5416, CUMBERLAND COUNTY (May 2010) Neighborhood Profile (2000 Census) Average Age:38 Median Household Income: $38,980 Median Home Value: $710,100 Average Years of Education: 13 PO BOX 3, RHEEMS PA 17570-0003, LANC&STER COUNTY (Jan 2009 - May 2 Qv Neighborhood Profile (2000 Census) D J,e _1..L 1 Average Age:35 Median Household Income: $60,870- Median H ?y lu 513 ,90 erage Years of Education: 13 1A UMBERTO ST, NEW CUMBERLND PA 17070-2YORK(6pUJ1IjY ov 2009) Neighborhood Profile (2000 Census) Average Age:37 Median Household Income: 526,08 edian Home Value: 559,300 Average Years of Education: 12 1 UMBERTO ST, NEW CUMBERLAND PA 17070-2625, YORK COUNTY (Oct 2008(- Jan 2009) Phone at address: 717-695-4467 SCHNEIDER DAVID J{2 717-774-3172 STUMP PENNY rev/ [No Data Available] 1 UMBERTO ST A, NEW CUMBERLND PA 17 70 YO K UN (Oct 2008 - Dec 2008) Neighborhood Profile (2000 Census) Average Age:37 Median Household Income: $26,0 3 lue. 55,300 Average Years of Education: 12 166 LOCUST ST APT 4, COLUMBIA PA 17512-1178, LANCASTER COUNTY (Mar 2008 - Sep 2008) Neighborhood Profile (2000 Census) Average Age:32 Median Household Income: $30,789 Median Home Value: $61,700 Average Years of Education: 12 PO BOX 25, ENOLA PA 17025-0025, CUMBERLAND COUNTY (Sep 2007 - Sep 2008) Neighborhood Profile (2000 Census) Average Age:38 Median Household Income: $55,352 Median Home Value: $134,400 Average Years of Education: 13 204 MARIETTA, COLUMBIA PA 17512, LANCASTER COUNTY (Mar 2008) Neighborhood Profile (2000 Census) Average Age:47 Median Household Income: $47,143 Median Home Value: $110,100 Average Years of Education: 13 811 VALLEY ST, ENOLA PA 17025-1539, CUMBERLAND COUNTY (Sep 2006 - Nov 2007) Phone at address: 717-732-2169 CHEST LAURA Neighborhood Profile (2000 Census) Average Age:38 Median Household Income: $55,352 Median Home Value: $134,400 Average Years of Education: 13 60 OLIVER RD, ENOLA PA 17025-2124, CUMBERLAND COUNTY (Aug 2004 - Sep 2005) Phone at address: 717-635-8498 JOHNS JUSTIN Neighborhood Profile (2000 Census) Average Age:34 Median Household Income: $36,618 Median Home Value: $87,800 Average Years of Education: 13 PO BOX 15, MARYSVILLE PA 17053-0015, PERRY COUNTY (Oct 1999 - Aug 2004) Neighborhood Profile (2000 Census) Average Age:37 Median Household Income: $56,375 Median Home Value: $126,200 Average Years of Education: 13 19 CASSATT ST, ENOLA PA 17025-2001, CUMBERLAND COUNTY (Oct 2003) Neighborhood Profile (2000 Census) Average Age:34 Median Household Income: $35,518 Median Home Value: $79,000 Average Years of Education: 12 1A UMBERTO ST, NEW CUMBERLAND PA 17070-2625, YORK COUNTY (Feb 2009) https:Hsecure.accurint.com/applbps/report 6/15/2010 Summary Report Page 3 of 3 Neighborhood Profile (2000 Census) Average Age:37 Median Household Income: $26,083 Median Home Value: $59,300 Average Years of Education: 12 https:Hsecure.accurint.com/app/bps/report 6/15/2010 EXHIBIT " F" 09-1487 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, Defendant Attorneys for Plaintiff Pennsylvania State Employees Credit Union COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned action. BARLEY SNYDER LLC Dated: lie 1/9 Shawn M. Long, Esquire Attorneys for Plaintiff Pennsylvania State Empk Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 c> Credit Union N Q C_ ;at 7W W I;i 29394191 EXHIBIT "G" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?,ptr of Cr???nb rr4 Jody S Smith 419 4# Chief Deputy Richard W Stewart "" Solicitor of of THE s?ER)FF Pennsylvania State Employees Credit Union I Case Number vs. Amber Conners 2009-1487 SHERIFF'S RETURN OF SERVICE 07/01/2010 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Amber Conners, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Amer Conners. The Enola Postmaster has confirmed, Amber Conners is not known at 413 Pitt Street, Enola, PA 17025. SHERIFF COST: $46.50 July 01, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CartySute ShwM. Teleown, Inc. EXHIBIT "H" Person Search My Accurint People Business Assets Licenses Phones Courts People Advanced Person People At Work Death Records Email Search Last Name First Name Middle Name SSN F_ 200 64-2869 ?' Inch;de rem!-varlets: ns i Street Address >Y City State ; ZIP r - r- F_ County Radius Phone DOS Age Range F I Inclorc 8ankruptci•., Page 1 of 4 24/7 Search and Technical Assistance 1-866-277-8407 NOME CLASSIC VIEW PRINT CONTACT US : LLVE CHAT HELP SIGN OUT Coverage I Help? Important: The n?.i::if Re<nras ar'n: Clrnn?pr<:af:y aeeila1,A o.ta sG Ies ..o in this wst- Gave <'rpfs. D.W S -en;nes entered ?:JOrlr, ,M.M.PS .ed Yn AnY.U11• dF'?^. IS ycr:El'af} MI t ee !rnn? Berea. Read t4Jrc Recent Searches MyAccount Person Sea... 188-66-xxxx Ali Recert Searches » Use of Recent Searches is subject to your Permissible Use selections. Search Tips Did you know that the Phones Plus database contains over 98M cell phone numbers? Reterence. Code: 46931-368 Person Search Results Search Terms Used - SSN: 200642869; All Full Name SSN Address R.N.: ' , to s & s nes'R nave: 1 2 3 :fl Edit Search r New Search 4:' Print Results ;Id Export to Excel Phone. Next SteoS _._...... ............... __..... ._.......... ........... ..... ............ 1. EP AMBER A CONNOR8 .... _._.__.__._... _.._..._ 200.64-xxxx ._.____.____.__._._.....__...__.... _....._._........__..._....-.._. 413 PITT ST ................ ....._._....... ....... .................................. 717-732-9092 - EST ... .___.._...._._._._.........._..._.._--....._._._._..._.__..._._........ Relatives cory DOB: 12/xx71984 (25) ENOLA PA 170252234 Aug 04 - Nov 10 CONNORS AMBER Neighbors, H Seu:p Ake ?robeble rxinent addf-s Associates Relatives, Neighbors & Associates People at Work We Also Found: r Professional Licenses (-•••: Email Address orts: Ju eomprehenslre i other s Itelavim tE9 Finder 0 Address IVO) tit Leant tow Accurint Report p ?i rtr.Part Repo!ss Report 1 imT Report Report Card Report :an assist vau:5ee Example 2. 6a AMBERA CONNORS DOB: 12!x.11984 (25) 200-4 xxxx 413 PITT ST ENOLA PA 17025-2234 Aug C4 Nov 10 717-732-9892-EST CONNCRS DAVID P JR Relatives Neighbors *k Setup Ater, 4/ P,ot a rurrsrt address Associates Relatives, Neighbors & Associates j People at Work Reports: Comprenens:ve other Nepor, Reports RNavint le", (p Finder -.[3 Address Report Y? Report ,•?1S Contsct "ir Card Report '..earn now Aaur;nt Report.. an assist you:See Example 3. AMBER A SHUMAKER Gender: Female DOS: 121x.11984 (25) 200.64-xxxx 413 PITT ST ENOLA PA 170252234 AIKI 04 - Jun 10 717-732-9692 CONNORS AMBER` _._._ ............... __...._ ._...... _.._..___.____._..__..__.. Relatives Neighbors i Setup Alert Associate, Relatives, Neighbors & Associates People at Work Reports: Cxrrnprehansivc Other Report Reports If y= RMavim Rlport Ip nnder Addy s ?aT Report Report C. tact Card Report Learn how Arcunnt Report i 3n assist vou:See Examp)e 4. ? AMBER A SHUMAKER Gender: Female DOB: 121x.!1984(25) 20084-64 413 PITT ST ENOLA PA 17025 2234 A.9 04 ,tun 10 717-732-9692 CONNGRS DAVID P JP, tives Rela Neigllhor5 *•t Setup Alert Associates Relatives, Neighbors & Associates People at Work sports: Comprehensive I Other Report "0 Reports if 0.eWvint 3; Reyort rty Finder ?t Address t `.T Report 9p' RePart ?AComau °-Y Card Report i.eii, how Amurint Repor can assist you: See Exampl<. _ __..._..._cw...._...._.__ -...__.....__.._.__._.._..___.._.._..._._ ....... 5, AMBER A CONNORS Gender: Female ........_.__. ..._._........__ 20044-xxxx _._.-... _._...... -.__............ .... .....__.._.._..__ 9 DICKINSON AVE APT C CAMP HILL PA 17011 5418 .___...._.____.... _......_.......... __....... _.._.___...._ _....__..._._........... ....._....._.._.___..._...... ..... _..._.._._.____.._.... Relatives DyOOB:121x.11984(25) 1?.7 Setup Alert .run io - Oct 10 Neighbors Associates Relatives, Neighbors & Associates People at Work sports! JU Comprehenswe Omer Report Reports Relavim Report fC? tinder 0Address Report Report ConUtrt ?CarU Report Learn hcw Ac., it Report :an as<ist vnu:see Example 6. AMBER A WOOD Gabler. Female 20084-64 9 DICKINSON AVE AP' C CAMP HELL _LP" -A-1- 717-327-5766 - EST Relatives https://secure.accurint.com/app/bps/main 11/11/2010 Person Search Page 2 of 4 DOB: 121.x/1984 (25) t_1ay 10 ? Sep 10 Neighbors Setup Alert Associate., Relatives, Neighbors & Associates People at Work i x fbmprehens:ve )rher eports: U :leltort Reports RNawnt Report t;nder Address V Report Report Contart ?Grd Report ,5rn hpw Accor:nt Feport cal. vl<ist you:See Example. 7, AMBER CONNERS 200-64-xxxx 9 DICKINSON AVE APT C Relatives car Gender. Female DOB: 121.x/1984 (25) CAMP HILL PA 17011-5416 Jun 10 Neighbors ? S A Associates . NUV lert Relatives, Neighbors & Associates People at Work U. ComprehensNe V Other R t iRelavint (Q Finder Address Contact :earn how A:CUrint Report A epor s: Report ?l Relxnis a Report vl Report Report Card Report can assist you:5ee Example A 9HUMAKER B, aw AMBER l 200.64-xxxx 9 DICKINSON AVE APT C Relatives c oi y Gander: Female DOB: 12(xz/1984 (25) CAMP HILL PA 17011-5416 Jun 10 Neighbors Setup Alert Associates Relatives, Neighbors & Associates People at Work Reports: Comprehensve a Other Report Reports w Relavint Report ((? Finder ® Address Report Report to AC. tact ?W Card Report rn_arn how Accurint Report can .assist you:See Example 9, AMBER WOOD 200-64-xxxx PO BOX 113 Relatives Gender: Female DOB: 12/x./1984 (25) ENOLA PA 17025-0113 May 10 . Ju: 10 Associates t 0 Setup Alert People at Work Reports: U Corn rchen"" I Omer Report cO Revorts Reavint Report (Q Finder' Address {?:f Report Report Contact Card Report :...earn how Accurst Reports r wt assist you:See Exam le ... .......... _....._..._-...___.___.__._...._.._._.... 10. AMBER A CONNORS .... __.___._._.___.__.__._.. 200-64-xxxx ...__...___-._.____._.........____._...__........ _.... PO BOX 3 _...... _........ _..... _._..._.._......._......_................. .... ..................... _......__............ ...__...... ._....... '_....... _...... ""__...__.. Relatives Gender: Female DOB: 12/x./1984 (25) RHEEMS PA 17570-0003 an 09 - Jun 1:0 Associates 0 Setup Alert People at Work Reports: Comprehort ensive 1A Other Rep Reports =y Relavint 3Z Report (Q Antler jo Acklms hej Report J? Report go C. tae Card Report earn how AtCUrrn[ Report ran assist you:See Example 11. AMBER A SHUMAKER 200.64-xxxx Gander: Female DOB: 121.x11984 (25) PO BOX 3 RHEEMS PA 17570-0003 Jan09 -Jun10 Relatives Associates 0 Setup Alr'rt P-opie at Work Reports: CnmpreI""t a ` Other Report Q Reports Relav!nt Report lQ F,nder all Address Rep- Report Contact _ Card Report Learn prow Acrrint Report. can assist you:See Example 12. AMBER A CONNORS Gender: Fehwle 200-64-xxxx 1A UMBERTO ST NEW CUMBERLND PA 17070-2625 Relatives DOB: 12,7x11984 (25) May O[ - Nov 09 Neighbor, Sea1p Alert Associates Relatives, Neighbors & Associates People at Work eports: Corri"Ileri-e (ra Other Report Reports Reavint Report ?Q under k`7l` Report adorcss R rt Contut ?Gid Report !_earn how Arxvrint Repnrt_ ::sirs assist you:Se.e Example 13. I AMBER CONNERS Gender: Female 20044-xxxx PO BOX 3 P,HEEMS PA 17570 0003 Relatives DOB: 12/x.11984 (25) Jan 09 - Mar 09 Associates N Swup Alen People at Work Reports; IQ Comprehensive Omer Report Re rts y>E Relavint .L'L Report (F? finder W Report Aridness Report Contact Card Report Learn 1r.n Accur:n[ Reports :all assist va!:See Example 14. Goer AMBER CONNERS Gender: Female 20044-xxxx 3 RHEEMS?A 77570 Relative, DOB: 12/xx/1984 (25) an 09 - Feb. 09 Associates I ? Setup Alert People at Work Reports; Comprehensive I':1 (khan Report cQ Repcrtt y? Relavint .T=RCport [ Rntler tip Report Address Report t(:ontad "? Card Repyrt ;earn how Acr:urint Repo an 35Sist '•ou: SP.e Fxampte 15. at, AMBER A CONNORS 20044-643 Gender: Female RHEEMS PA 17570 DOB: 12,7x/1984 (25) Jan OP - Feh 09 Setup Alen Relatives Associates °enpe at Work https://secure.accurint.com/app/bps/main 11/11/2010 Person Search Page ?eports: 'L' .. Cn!nprehensl:e I Other Rem-11.t Finder Address •CA, lact t.earn how Acrnt Report U R port "ts! aepo!is Report Report Reoort q Card Report an assist you: See Example 16. c? AMBER A SHUMAKER Gender: Ferrel. DOB: 12,xx/1984 (25) q-e 20064-xxxx 3 RHEEMS PA 17570 tan 09 - Feh 09 Relatives PeopiE d at x?Opl Work Setup Al.r• Reports: Comprehensive Other Report Reports Relavlnt Repot rQ Finder Address W Report Yr Report ?eodact Cad Report Learn hew Aaurint Report can assist you:See Example AMBER P CONNORS 17 200.64-xxxx 1 UMBERTO ST Relatives , Gender: Female DOB: 121x-/1984 (25) Soup Alen NEW CUMBERLND PA 17070-2625 Doc 08 Neighbors Associate, Relatives, Neighbors & ASSOCiateS ! People at Work sports: Comprehensive (A Other Report `rte Reports Rel.vim Repot Finder Address Report Report Contact Card Report i-earn h ' Accur:nt Report• can assist vou:5ee Example ` 18. AMBER A SHUMAKER Gender: Female DOB: 121-x71984 (25) 20064-xxxx 1 UMBERTO ST NEW CUMBERLND PA 17070-2825 Dec 08 Relatives Neighbors Setup Alert '•4 Associates Relatives, Neighbors & Associates People at Work Reports: comprehensive other Report "es Reports Relavlnt Report Fader Address 10 Report Report Contact Card Report Learn how Aaurint Report. can assist you: See Example lg, AMBER CONNERS 200-84-xxxx 1 UMBERTO STA Relatives Gender: Female NEW CUMBERLND PA 17070-2625 Neighbors DOB: 12/xx/1984 (25) 0, OB Der, 08 Solup Akin tom' Associates Relatives, Neighbors & Associates People at Work Comprehensive other sports: R Report ? Reports g1x Relavll 3 Report R{?]] Finder Address Ir;1' Report Report C. UCt Card Report earn how A.:c a it Repo can assist vou:5ee Example 20, AMBER CONNERS 200-64-xxxx 166 LOCUST ST APT4 Relatives a Gender: Female DOB: 12/xx/1984 (25) COLUMBIA PA 17512-1178 Mar 08 - Sep 08 Neighbors Associates Setup Alert Relatives, Neighbors & Associates People at Work l:omprohenslve. other - Relavlnt ?Q F;der Address & I Conl act ieam how Aaurnt RepVrt. {Reports: Report Reports Report Report Report -"? card Report c.=.n assist you:See Example 21. ERP AMBER A CONNORS 200-64-xxxx 168 LOCUST a APT 4 Relatives corn Gender: Female DOB: 12xx/1984 (25) COLUMB!A PA 17512-11 Mar oe' -Sep n8 78 Neighbors DO Associates Setup Alert Relatives, Neighbors & Associates People at Work JU Conhprehens!ve Other y5 Reis." (d Finder VAddress contact i.a rrn hew Aa.urint Report teports: Report Reports 3= Report {ttP' Report 4 ? Report Card Report ran assist you:Sre Example 22. EP AMBER A SHUMAKER 200.64-xxxx 166 LOCUST ST APT 4 Relatives o Gender, Ferrel. DOB: 12/xx/1984 (25) COLUMBIA PA 17512-1178 Met 08 - Sep D8 Neighbors Associates Setup Alert Relatives, Neighbors & Associates People at Work teports: Comprehens3w Other ® Report Reports Relovint Report [Q Fader ip? Report Address Report g+l1 Conl act °? Card Report tear!1 'new A:curllt Reporl ran assist you, See Example 23, ? AMBERA CONNORS 20084-64 PO BOX 25 Relatives Gender: Female DDOB: 12zx/1984 (25) ENOLA PA 170250025 Sep 07 - Sep 08 Associates Setup Alert People at Work Reports: U Comprehensive fA Otlher Report t$ Reports Relavint Report Finder Report ,.qp Address Ye Report ?Conlact Carcl Report ixarn hew A.:.curinl Re.pori can Assist you:See Example 24. AMBER CONNERS 200-fie-xxxx to UMBERTO ST Relatives Gender: Femele DOB: 12/xx/1964 (25) +0 s Al t rt NEW CUMBERLND PA May 06 Au17 08 17670-2625 Neighbors Associates e up e Relatives, Neighbors & Associates People at Work https:Hsecure.accurint.com/app/bps/main 11/11/2010 Person Search Page 4 of 4 11 i . Comprehensive ( Other y? Relavint (a Finder 0) Add- loeomiitt :earn hCx' Acc print Retwrt ?eports: Report I M! Reports ?S Report Mir Report Report" Grd Report c:an as,, `Juu: See Exam'. 25. AMBER A SHUMAKER 20044-xxxx IA UMBERTO ST Relatives Gender: Femele NEW CUMBERLNO PA 1 70 7 0-262 5 Neighbors DOB: 121xx71914 (25) Setup Alen AssociateF Reatives, Neighbors & Associates People at Work reports: IU Comprehensive other af Relavkn lQ Finder Address g.:.A Conti ct R R t °? C d R t Learn h w Accunnt Report S Report Reports Repot epor epor ar eport :;an s55LSt you: eC Exam rtcrdti t to 25 of 5's ^R-M Page: 1 2 i P .; Edit Search =p Hew Search y prlnt Results ;jg Export to Excel Your DPPA Permissible Use: I-Nii, Criminal, Admenistra;ive or k-111hal prxeedings Your GLBA permissible Use: Pier oms HAding a Legal W Beneficial Int-t Relating to the Cgnswnty 1 eX'SNCX's. About Lexhhexis I Terms & Conditions 4C Copyright 0 2010 LexisNexis Risk Solutions. All rights reserved. https:Hsecure.accurint.com/app/bps/main 11/11/2010 09-1487 FILED-OFFICF O THE PR TH0NoTAj'(,3 2011 FEB 17 APB I1: 19 CUMBERLAND COUNTY PENNSYLVANIA BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 Defendant AFFIDAVIT IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT COMMONWEALTH OF PENNSYLVANIA : COUNTY OF LANCASTER SS. SHAWN M. LONG, ESQUIRE, being duly sworn according to law, deposes and says that he is the attorney of record for the Plaintiff, Pennsylvania State Employees Credit Union, and that the following is an itemization of the efforts taken by the Plaintiff to locate the Defendant, Amber Connors to effect service under the provisions of the Pennsylvania Rules of Civil Procedure, without success. 1. On or about March 26, 2009, the Sheriff of Cumberland County attempted service of the Complaint upon the Defendant at 1 A Umberto Avenue, New Cumberland Pennsylvania and returned the Return of Service to Plaintiff indicating "moved." The Sheriff of Cumberland 3062705-1 09-1487 County deputized service to the Sheriff of York County and returned the Return of Service to Plaintiff indicated "per Post Office check, new address is Post Office Box 3, Rheems Pennsylvania 17570." 2. On or about May 4, 2009, Plaintiff s counsel prepared and mailed a Change of Address Request form to the Rheems, Pennsylvania Post Office for the address of Post Office Box 3, Rheems Pennsylvania 17570. 3. The response to the Change of Address Request from the Rheems Post Office indicates "Street Address 107 Greider Avenue." 4. On May 19, 2009, Plaintiff performed an Accurint search on www.Accurint.com. The address that was searched is 107 Greider Avenue, Rheems Pennsylvania 17570. 5. On June 15, 2010, Plaintiff performed an Accurint search on www.Accurint.com. The address listed on the Accurint search is 413 Pitt Street, Enola, Pennsylvania 17025. 6. On or about July 1, 2010, the Sheriff of Cumberland County attempted service of the Complaint upon the Defendant at 413 Pitt Street, Enola, Pennsylvania 17025. The Sheriff's return indicates "unable to locate Amber Connors, Enola Post Office confirmed, Amber Connors is not known at 413 3rd Street, New Cumberland, Pennsylvania 17070." 7. On November 11, 2010, Plaintiff performed an Accurint search on www.Accurint.com. The address listed on the Accurint search is 413 3rd Street, New Cumberland, Pennsylvania 17070. 3062705-1 09-1487 8. The Plaintiff has exhausted all reasonable efforts to serve the Defendant, Amber Connors. Sworn to and subscribed before me this /6*d of u-a. , 2011. Notary Public M. Long, My Commission Expires: CoMMONwEM.TM OR MNNWVLVANIA Notarial Seal CoUeeee M. Domes, Notary Public City of Lancaster, Lancaster 17 2013 My ComrNMbn E)Mes Member, Pennsylvania Association of Notaries 3062705-1 09-1487 ? BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 FLED-OFFICE i`H E PRCTH0P='?'fife 11 FEB 22 P14 j: 0 s PUMBERLA 1a r- *j tIiq' `r Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 ORDER AND NOW, to wit, this a day of 2011, upon consideration of the Motion of Pennsylvania State Employees Credit Union for a Special Order of Court authorizing service of process, default notice, and writ of execution notices, if necessary, upon the Defendant, Amber Connors, by publication in accordance with Pa.R.C.P. 430 and the Court having made a determination that sufficient evidence of concealment has been presented, and that the Plaintiff has made a good faith effort to locate the Defendant to the degree necessary to justify service by publication in accordance with said Rule, it is ORDERED that service of process, default notice, and writ of execution notices, if necessary, by publication in accordance with Pa. R.C.P. 430(b)(1) is hereby authorized, and Plaintiff, upon effecting service in accordance with said Rule, al l file a Certificate of Service with the Office of the Prothonotary of Cumberland Coun sylvania. J. 7y rh,ai L£c? adz ?,?ir 30627051 09-1487 2 t 1 _ mill. 21 j?UjjBER S?LVA? pTY PENN BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299-5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned action. BARLEY SNYDER LLC S4awn M. Long, Esquire Attorneys for Plaintiff Pennsylvania State Empl Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 29394191 Credit Union ® lb oaf a 0? to to 6Y t2+?-as???y BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 F THE PR d TV, 01y O 0 T4, ? u 1011 APR -6 Pti is S CUMBERLAND A our; y f ?IA Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 VERIFICATION Kelly Cunneen, hereby verifies that on March 18, 2011 service of the Complaint was served by publication upon the Defendant, Amber Connors, in accordance with Order of Court dated February 12, 2011 in The Cumberland Law Journal and The Sentinel. Proofs of publication in The Cumberland Law Journal and The Sentinel are attached hereto and marked Exhibit "A". BARLEY SNYDER LLC Dated: April 5, 2011 By: 1 Kelly Cunn n, Paralegal 126 East King Street Lancaster, PA 17602 717.299.5201 31846141 EXHIBIT "A" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz luilarcn I zS, 2u 11 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. a Marie Coyne, E 'or SWORN TO AND SUBSCRIBED before me this _ 18 day of March 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law 09-1487 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. AMBER CONNORS Defendant NOTICE To: AMBER CONNORS You are hereby notified that on March 10, 2009, Plaintiff, Penn- sylvania State Employees Credit Union, filed a Complaint endorsed with a Notice to Defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 09-1487, which has been reinstated, wherein Plaintiff seeks to enforce its rights under its loan documents. Since your current whereabouts are unknown, the Court by Order dated February 22, 2011, ordered notice of said facts and the filing of the Complaint to be served upon you as provided by R.C.P. 430(b). You are hereby notified to plead to the above referenced Complaint on or before 20 DAYS from the date of this publication or Judgment will be entered against you. NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, the case may proceed without you and a Judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA- TION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 SHAWN M. LONG, ESQUIRE BARLEY SNYDER LLC 126 East King Street Lancaster, PA 17602 (717) 299-5201 Mar. 18 PRC CIF ()I' PIIBL1(_.' A 11C N <tIIII,' ,) > I' n, - , ( '-,LIP, t I kl-Kie COX, Retail Salts klai, gltei, t•t ht -tnt3ric tl-, 1'?Tg dL1lN ,worn, depose: ?, xid ,:1., ? h, 1 1 f ! A IIN,'I : -, -t uLation in the t3on,ugh i-t t?,Ili- >tlnt ,Intl `g at . M P%H I ., ?nnty,anci the t Ihe 'prirlrt?;I n,t i", ?'. I, }printed inc IIIt.SEN7IM-1 ontb(? frlllwv;I?I vhrch 18_'-_'().H_ St<<ie afclre???i, per of genc'r?i1 I-, ("St lbli: he,i Marty issued 11 Sn t xact!v tilt ?_nII1c ?? t)1)Y0 1, N0"I'f('11 F'I?'iU13L3<: AIIt NOTICE a ?I 1 T'OF`COMMON PLEAS`OF CUMBERLAND COUNTY PENNSYLVANIA ?fir , .,h r1* -CIVILACTION-LAW ?"PENNSYLVANIA. STATE EMPLOYEES GREDITi1NION r q Plaintiff v t k ...F. (} vs a ?AMBEWGONNORS, e -fleTennt CIVIL AcT10N LAW r ` ' ? ?9 1487 C]VIL - - - II13-it ILI! I!, i'It+ "t'ti`Cc' i I < IIC,-,,I f It r 1 l 1l1att( r I,.I 1, 1( . rtl?'enleI It, cIr I th:l r ?om st -I tc In( It I t'I' o pUhilc(ltIk) yr t rvUO t}'f" w ,x , q 4 i dN0TiCE TovfIf?E?C`ONtIORS? Y` r on March l0 0o9;'Plaintiff;PennsylvaniaStateErfipljy CroditUniun.filedaComplaint and'agamstyouin?he courtof Common Ptdds"'bf Cumberland Cowity Pe nsylvania, hr83itias ebnY iis°taiAdroG63ienPIaintffseek-? cohforcWiIsoghtsyndeut,k?, ''4t'mr r.., , ratioutsareunltroy`njlteL'euni?y{?derd3tpdFebru9 '2'Q_073 orderod_noticegtsatdfacts aq YheflinylifiheTotip?ainfYObe ser?eduponyou as provided by R.C.P.d30K. Vouare ti rebyhbfiffato "plead to the above referenced Complaint on or befdre 20 DAYS from the date of this 4)u61ica6on,or)u4gment will be entered against you. r NOTICE You have been sued in Court. Ityou wish to defend, you must enter a written appearance personally. or by attorney, and "ffe yourdefer6' "i?661igahonsan writing with the Court. You are warue446tif-you fail to do so, the case may ioCegdvwit d a Judgment maybe entered ag8instyou with out`fgrthernotice for the relief requested by the 'Plaintiff You'ivaiylose money or property or other rights important to you. r y 11VOTICE TO `FOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR 33 ! "E 'SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ?tRf?(3yA?L•j4tNYE R. ?e D TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH A 7 AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A Cumberland- County Lawyer Referral Service 32 Shut i Bedford%Street Carlisle, PA 17013 800-999-9108 Shawn M. Long, Esquire BARLEY SNYDER LLC 128 -East King Street Lancaster, PA 17602 (717) 299-5201 Zl_ ? ?',t t I I' ltd .3 3?t'I(r''c' ltlt? th; >? r I p ? ! ?? i PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Retail Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): March 18, 2011 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to ter' ne, place and character of publication y, fn`s, Sworn and subscribed before me this (111 W uYl X2611 My commission expires: I NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 Notary Public ;a _ x i,°J I H'JF3DTAR 4 S4l?L `,i D COUNT`` )ENNSYL"HIA 09-1487 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299-5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Amber Connors for want of an answer in the amount of $16,903.37 plus interest and costs of suit. (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( ) Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. 32034831 Cut 09,1 ?.?as$ t?y°? 09-1487 (X) Pursuant to Pa. R.C.P. 237. 1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date:,A/2(,) I k r By: BARLEY SNYDER LLC Shawn-M. Long, Esq, Court I.D. No. 83774 Attorneys for Plaintif Pennsylvania State F) 126 East King Street Lancaster, PA 17602 (717) 299-5201 Credit Union NOW, 2011, JUDGMENT IS ENTERED AS ABOVE. Prothonotary/Clerk, Civil Division By: l .?. PePW ?' /'yl 32034831 09-1487 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OFFICE OF THE PROTHONOTARY CARLISLE, PA TO: Amber Connors Defendant YOU ARE HEREBY NOTIFIED that Pennsylvania State Employees Credit Union has caused a judgment by default to be entered against you with the Prothonotary of Cumberland County. The judgment was entered on to No. 09-1487 with the Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the amount of $16,903.37 plus costs of suit. PROTHONOTARY By: 32034831 09-1487 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE, PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 The undersigned, Shawn M. Long, Esquire, doth depose and say that Amber Connors, the Defendant is not in the Military or Naval Service, based on the following facts: Age of Defendant is unknown; Present place of employment is unknown; Last known place of Residence is 413 3rd Street, New Cumberland, Pennsylvania 17070 as of the date of this affidavit. ADDITIONAL FACTS, if any. The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S., §4904, relating to unsworn falsification to authorities. BARLEY SNYDER LLC By: awn M. Long, Es ire Attorneys for Plain. ff Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 32034831 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. AMBER CONNORS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-1487 VERIFICATION Kelly Cunneen, hereby verifies that on April 15, 2011 service of the 10-Day Notice was served by publication upon the Defendant, Amber Connors, in accordance with Order of Court dated February 12, 2011 in The Cumberland Law Journal and The Sentinel. Proofs of publication in The Cumberland Law Journal and The Sentinel are attached hereto and marked Exhibit "A". BARLEY SNYDER LLC By: Kelly C neen, Paralegal 126 East/King Street Lancaster, PA 17602 717.299.5201 Date: April 25, 2011 3203074_1 EXHIBIT "A" PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Retail Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): April 15, 2011 COPY OF NOTICE OF PUBLICATION • ` 4C,.,r+k-r deposes that he/she is not d ir o LOo mAO mM._3ject matter of the } QMJ `dcyN -wF- (r z CC, O o < 0 m in NLn advertisement, and that ZF-p? Off" ~ c < o o w ¢ x < ?z = ? 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Z .? - er Rm< <' < 0 ¢ F- (7 OZ? ?WZ Agw Q OZ¢ W zQ r .J7Q2 Z a QO o pmc?a --)Wm O?WW SEA_ F } O?-< >-z¢ 'KENDORN iblic ?nnuo?? uunvuun, uUMBERLAND CNTY My Commission Expires Jan 2; , 2014 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tackie Cox, Retail Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): April 15, 2011 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are e. Sworn t and sub ibed be re me this 2-b 2- Notary ? I . Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY ivly Commission Expires Jan 27, 2014 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 15, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. La Marie Coyne Editor SWORN TO AND SUBSCRIBED before me this 15 day of Mri1.2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law 09-1487 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. AMBER CONNORS, Defendant IMPORTANT NOTICE To: AMBER CONNORS You are in default because you have failed to enter a written appear- ance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be en- tered against you without a hearing and you may lose your property or other important rights. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 SHAWN M. LONG, ESQUIRE I.D. No. 83774 BARLEY SNYDER LLC 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 Apr. 15