HomeMy WebLinkAbout09-2953NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V.
ROBERT A. OLLISON, JR., AND
KATRINA L. KIRKMAN,
a/k/a KATRINA L. OLLISON
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN
TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED BY
ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND
FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO
SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY
CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM RELIEF REQUESTED BY
THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 170
(717) 249-3166
By:
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
NEW CUMBERLAND FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION, CUMBERLAND COUNTY
PLAINTIFF PENNSYLVANIA
V. CIVIL ACTION - LAW
ROBERT A. OLLISON, JR., AND
KATRINA L. KIRKMAN,
a/k/a KATRINA L. OLLISON
DEFENDANT NO. 0 9 - 9 53 Ca, 4- 7u.,.,,.
COMPLAINT
1. The Plaintiff is the New Cumberland Federal Credit Union with a principal place of
business located at 345 Lewisberry Road, New Cumberland, York County, Pennsylvania 17070.
Plaintiff is a federally chartered nonprofit credit union
2. The Defendants Robert A. Ollison, Jr., and Katrina L. Kirkman, a/k/a Katrina L. Ollison
are adult individuals residing at 505 Barry Court, Mechanicsburg, Cumberland County, PA
17050.
COUNT 1: NCFCU CAR LOAN
3. On July 2, 2007 Defendants executed a Loan Agreement attached as Exhibit "A" in
the amount of Twenty One Thousand Nine Hundred Six Dollars and 26/100 ($21,906.26)
Dollars at 7.50% interest and pledged as collateral a 2005 Nissan Maxima (VIN
1N4BA41EX4C884062). Defendants were the borrowers under this Loan Agreement.
4. The terms of Exhibit "A" required timely payments of $408.64 monthly for 71 months
and a final payment of $408.39 in the 72nd month.
5. Defendants failed to make timely payments and the car was repossessed and sold in
accordance with a letter by the New Cumberland Federal Credit Union, dated of April 28, 2009
(Exhibit "B") with Plaintiff receiving a net check for $7,215.00 from the sale after deductions for
fees and auction expenses.
6. After applying $7,215.00 received from the auction towards the vehicle loan there
remains a principal balance due of $12,351.52 plus past due interest at 7.50% with a $2.54 per
diem from April 28, 2009.
7. Defendant has made no regular payments despite repeated requests.
8. Pursuant to the Loan Agreement the Defendants agreed to pay all "court costs and
reasonable attorney fee" incurred in any collection action.
WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount of
$12,351.52 (principal plus past interest) at 7.50% interest from April 28, 2009 and a per diem
of $2.54 together with all court costs and an award of reasonable attorneys' fees.
COUNT II: NCFCU LOAN
9. On November 14, 2007 Defendants executed a Loan Agreement attached as Exhibit "C"
in the amount of Eight Thousand Nine Hundred Twenty Nine Dollars and 63/100 ($8,929.63)
Dollars at 11.90% interest. Defendants were the borrowers under this Loan Agreement.
10. The term of Exhibit "C" required 103 timely bi weekly payments of $114.86 and a
final bi weekly payment of $114.51.
11. Defendants failed to make timely payments.
12. There remains a principal balance due of $6,279.79.
13. Defendants have made no regular payments despite repeated requests.
14. Pursuant to the Loan Agreement the Defendants agreed to pay all "court costs and
reasonable attorney fee" incurred in any collection action.
WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount of
$6,279.79 (principal plus past interest) at 11.90% interest from April 28, 2009 with a per
diem of $2.05 together with all court costs and an award of reasonable attorneys' fees.
Respectfully submitted,
By:
Howell Law/' inn
60 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
71 77701279 HOWELL L A'4 FIRX PAGE 92114
Verification
1 verify that the statements made in the forgoing document are true and correct. I understand that
false statements herein are tnade subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
Iuasworn falsification to authorities. I verify that Z altt the President of the New Cumberland
Federal credit Union and that I am authorized to execute this document.
By: Z'Gyl?l?
Donald Varner, sid.enit
NCFCU
Date: J-/s-/O
4V CUMBERLAND FEDERAL CREDIT UNION
?. Box 658 New Cumberland, PA 17070-0658
17) 774-4633 • 1-800-716-2328
_. ,
A^AAM
OIL
LOAN AND SECURITY AGREEMENTS
AND DISCLOSURE STATEMENT
LQF?V/DAT?L 0 0 7 LJO N NMBER AMBER GROUP POLICY NUMBER MATURITY DATE
/ BC1RR03i!4E€R 1
NAME (AND ADDRESS IF DIFFERENT FROM BORROWER 1)
ROBERT A OLLISON JR. KATRINA L KIRKMAN
505 BARRY COURT
MECHANICSBURG PA 17050-4601
TRUTH<IN ?;ENOCNi?,`QISOLOSf .....:?e, mas alii estirriiate
ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price
The cost of your credit as a yearly rate. The dollar amount the The amount of credit The amount you will have The total cost of your purchase on credit is
credit will cost you. provided to you or on paid after you have made $
your behalf, all payments as scheduled.
7.500 °i6 $ 5,503.80 e $ 21,906.26 $ 29, 421.83 a which includes your
downpayment of S
Your Payment Schedule Will Be: Prepayment: If you pay off early you will not have to
Number of Payments Amount of Payments When Payments Are Due pay a penalty.
71 $ 408.64 MONTHLY 07/30/2007 Required Deposit: The Annual Percentage Rate does
AND 1 $ 408.39 a not take into account your required deposit, if any.
Property Insurance: You may obtain property insurance from anyone you ? Assumption: Someone buying your mobile home
y cannot assume the remainder of the loan on the
want that is acceptable to the credit union. If you get the insurance from us, original terms.
you will pay$ N/A
Demand: ? This obligation has a demand feature.
Late Charge: ? All disclosures are based on an assumed
maturity of one year.
THIS CREDIT UNION DOES NOT ASSESS LATE CHARGES
Filing Fees Non-Filing Insurance
Security: Collateral securing other loans with the credit union may also secure this loan. You are giving a security interest in your
shares and dividends and, if any, your deposits and interest in the credit union; and the property described below:
Collateral Property/Model Year I.D. Number Type Value Key Number
NISSAN MAXIMA 2004 1N4B 4062 AU $ 19,925.00
$ 0.00
$ 0.00
Other (Describe) 0.00 0.00
Pledge of Shares $ 0.00 in Account No. $ 0.00 in Account No.
See your contract documents for any additional information about nonpayment, default, and any required repayment in full before the
scheduled date.
$tG:NATU099
CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT. By signing as
Borrower, you agree to the terms of the Loan Agreement. If property is described in the "Security" section of the Truth in isclosu
ou also onl yto the temsrof the Secu ty Ag Agreement. of the Security Agreement: If you sign as "Owner of Property" you agree
X X
80 OWER 1 ISEALI
ISEALI
TE BORRO ER 2
X DATE
(SEAL) X 7 (SEAL)
OTHER BORROWER OWNER OF PROPERTY 7]WITNESS DATE ? OTHER BORRO R NER PROPERTY 'IF WITNESS DATE
0 CUNA MUTUAL GROUP, 1999, 2000, 2001, ALL RIGHTS RESERVED
Credit Union New Cumberland Federal Credit Union
Borrower(s) ROBERT A OLLISON JR.
KATRINA L KIRKMAN
Loan No. Acct. No.
L# 10 4"
Itemization of Amount Financed of Amount Given to You Directly Amount Paid on Your Account Prepaid Finance Charge
$ 21 906.26 $ 0.00 $ 21 731.26 $ 0.00
Amounts Paid to Others on Your Behalf: (If an amount is marked with an asterisk (") we will be retaining a portion of the amount.)
$ 21,731.26 To REF $ 175.00 To NCFCU
$ 0.00 To $ 0.00 To
$ 0.00 To $ 0.00 To
$ To $ To
$ To $ To
$ To $ To
$ To $ To
In this Loan Agreement 1"Agreement") all references to "Credit Union," "we," "our," or "us," mean the Credit Union whose name
appears above and anyone to whom the Credit Union assigns or transfers this Agreement. All references to "you," or "your" mean each
person who signs this Agreement as a borrower.
1. PROMISE TO PAY -
You promise to pay $21,906.2fo the Credit Union plus interest on the unpaid balance until what you owe has been repaid. For fixed
rate loans the interest rate is 7.500 % per year.
Collection Costs:
You promise to pay all costs of collecting the amount you owe under this agreement including court costs and reasonable attorney
fees.
2. PAYMENTS - You promise to make payments of the
amount and at the time shown in the Truth in Lending
Disclosure. You may prepay any amount without penalty.
Yu prepay any part of what Iyou owe, you are still required
0, make the regularly scheduled payments, unless we have
agreed, to a change in the payment schedule. Because this
is a simple interest loan, if you do not make payments
exactly as scheduled, our final payment may be more or
less than the amount of the final payment that is disclosed.
If you elect credit insurance, we will either include the
remium in your payments or extend the term of your loan.
Pf the term is extended you will be required to make
additional payments of tie scheduled amount, until what
yyou owe has been paid. You promise to make all payments
to the place we choose. If this loan refinances another loan
we have with you, the other loan will be canceled and
refin nced f he d t of his loan.
3. MAN PAME DS ?l? MAIL - It the proceeds of this loan
are mailed to you, interest on this loan begins on the date
the I an pr ceedOs are mailed to you.
4. S9CU?I1eY F R LOAN - This Agreement is secured by all
property described in the "Security," section of the Truth in
Lending Disclosure. Property securing other loans you have
with us also secures this loan, unless the property is a
dwellin A dwelling secures thi loan only if it is described
in the 'Security" section of the ruth in Lending Disclosure
for this loan. /f Credit Union has a federal charter Statutory
Lien - If you are in default on a financial obligation to us,
federal law give us the right to apply the balance of shares
and dividends in all individual and joint accounts you have
with us to satisfy that obligation. After you are in default,
we may exercise this nght without further notice to you.
?We have a federal charter if our name includes the term
Federal Credit Union.") If Credit Union has a state charter,
except in Ohio and Rhoda Island: We have a statutory lien
on the shares and dividends and, if any, the deposits and
interest in all individual and )joint accounts you have with us
and may exercise our right under the lien to the a tent
permuted by state law. (V1?e have a state charter it our
name does not include the term "Federal Credit Union.")
For all borrowers: You pledge as security for this loan al
shares and dividends and, if any, all deposits and interest in
all joint and individual accounts you have with the credit
union now and in the future. 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 defaut. The statutory
lien and your pledge do not apply to any Individual
Retirement Account or any other ac ount that would lose
special tax treatment under state or Tederal law if given as
securit
5. DEAULT - You will be in default under this Agreement if
you do not make a payment of the amount required on or
before the date it is due. You will be in default if you break
any promise You made in connection with this loan or if
anyone is in default under any security agreement made in
connection with this Agreement. You will be in default if you
die, file for bankruptcy, become insolvent (that is unable to
pay our bills and loans as they become due), or if you made
any false or misleading statements in your loan application.
You will also be in def ult if something happens that we
believe may seriously afafect your ability to repay what you
owe under this Agreement or if you are in default under any
other loan a reement you have with us.
6. ACTIONS-AFTER DEFAULT - When you are in default, we
may demand immediate payment of the entire unpaid
balance under this Agreement. You waive any n ht you have
to receive demand for payment, notice of intengt to demand
immediate payment and notice of demand for immediate
payment. If we demand immediate payment, you will
continue to pay interest at the rate provided for in this
Agreement, until what you owe has been repaid. We will
also apply against what you owe any shares and/or deposits
given. as security under this Agreement. We may also
exercise any other rights given 5y law when you are in
default.
7. EAH PERSON RESPONSIBLE - Each person who signs
this Agreement will be individually and jointly responsible for
paying the entire amount owed under this Agreement. This
means we can enforce our rights against any one of you
individually or against all of you together.
8. LATE CHARGE - If you are late in making a payment, you
dromise to pay the late charge shown in the Truth in Lending
isclosure. If no late charge is shown, you will not be
char ed one.
9. DELAY IN ENFORCING RIGHTS - 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.
10. CONTINUED EFFECTIVENESS - If any part of this
Agreement is determined by a court to be unenforce;,ble, the
rest will remain in effect.
11. NOTICES - Notices will be sent to you at ti to most
recent address you have given us in writing. Notice; to any
one of you will be notice to all.
12. OTHER PROVISIONS -
Credit Union 14ew Cumberland Federal Credit Union
Borrower(S) ROBERT A OLLISON JR.
KATRINA L KIRKMAN
In this Agreement all references to "credit union," "we," "our" o
"us" mean the credit union whose name appears on this document
and anyone to whom the credit union assigns or transfers this
Agreement. All references to the "Loan" mean the loan described
in the Loan Agreement that is part of this document. All references
to "you," or "your" mean any person who signs this Agreement.
1. THE SECURITY FOR THE LOAN - You give us what is known as
a security interest in the property described in the "Security"
section of the Truth in Lending Disclosure that is part of this
document ("the Property"). The security interest you give includes
all accessions. Accessions are things which are attached to or
installed in the Property now or in the future. The security interest
also includes any replacements for the Property which you buy
within 10 days of the Loan and any extensions, renewals or
refinancings of the Loan. It also includes any money you receive
from selling the Property or from insurance you have on the
Property. If the value of the Property declines, you promise to give
us more property as security if asked to do so.
2. WHAT THE SECURITY INTEREST COVERS - The Property
secures the Loan and any extensions, renewals or refinancings of
the Loan. If the Property is not a dwelling, it also secures any other
loans, including any credit card loan, you have now or receive in
the future from us and any other amounts you owe us for any
reason now or in the future, except any loan secured by your
principal residence. If the Property is household goods as defined
by the Federal Trade Commission Credit Practices Rule or your
principal residence, the Property will secure only this Loan and not
other loans or amounts you owe us.
3. OWNERSHIP OF THE PROPERTY - You promise that you own
the Property or, if this Loan is to buy the Property, you promise
you will use the Loan proceeds for that purpose. You promise that
no one else has any interest in or claim against the Property that
you have not already told us about. You promise not to sell or
lease the Property or to use it as security for a loan with another
creditor until the Loan is repaid. You promise you will allow no
other security interest or lien to attach to the Property either by
your actions or by operation of law.
4. PROTECTING THE SECURITY INTEREST - If your state issues a
title for the Property, you promise to have our security interest
shown on the title. We may have to file what is called a financing
statement to protect our security interest from the claims of
others. If asked to do so, you promise to sign a financing
statement. You promise to do whatever else we think is necessary
to protect our security interest in the Property. You also promise to
pay all costs, including but not limited to any attorney fees, we
incur in protecting our security interest and rights in the Property,
to the extent permitted by applicable law.
5. USE OF PROPERTY - Until the Loan has been paid off, you
promise you will: (1) Use the Property carefully and keep it in good
repair. (2) Obtain our written permission before making major
changes to the Property or changing the address where the
Property is kept. (3) Inform us in writing before changing your
address. (4) Allow us to inspect the Property. (5) Promptly notify
us if the Property is damaged, stolen or abused. (6) Not use the
Property for any unlawful purpose.
6. PROPERTY INSURANCE, TAXES AND FEES - You
promise to
pay all taxes and fees (like registration fees) due on the Property
and to keep the Property insured against loss and damage. The
amount and coverage of the property insurance must be
acceptable to us. You may provide the property insurance through
a policy you already have, or through a policy you get and pay for.
You promise to make the insurance policy payable to us and to
deliver the policy or proof of coverage to us if asked to do so.
If you cancel your insurance and get a refund, we have a right to
the refund. If the Property is lost or damaged, we can use the
insurance settlement to repair the Property or apply it towards
what you owe. You authorize us to endorse any draft or check
which may be payable to you in order for us to collect any refund
or benefits due under your insurance policy.
If you do not pay the taxes or fees on the Property when due or
keep it insured, we may pay these obligations, but we are not
required to do so. Any money we spend for taxes, fees or
insurance will be added to the unpaid balance of the Loan and you
will pay interest on those amounts' at the same rate you agreed to
pay on the Loan. We may receive payments in connection with the
insurance from a company which provides the insurance. We may
monitor our loans for the purpose of determining whether you and
other borrowers have complied with the insurance requirements of
our loan agreements or may engage others to do so. The insurance
charge added to the Loan may include (1) the insurance company's
payments to us and (2) the cost of determining compliance with
Loan No. Acct. No.
L# 10 00
AGREEMENT
r the insurance requirements. If we add amounts for taxes, fees or
insurance to the unpaid balance of the Loan, we may increase your
payments to pay the amount added within the term of the insurance
or term of the Loan.
7. INSURANCE NOTICE - If you do not purchase the required
property insurance, the insurance we may purchase and charge you
for will cover only our interest in the Property. The insurance will
not be liability insurance and will not satisfy any state financial
responsibility or no fault laws.
8. DEFAULT - You will be in default if you break any promise you
make or fail to perform any obligation you have under this
Agreement. You will also be in default under this Agreement if the
Loan is in default.
9. WHAT HAPPENS IF YOU ARE IN DEFAULT - When you are in
default, we may demand immediate payment of the outstanding
balance of the Loan without giving you advance notice and take
possession of the Property. 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 Loan.
If you have agreed to pay the Loan, you will also have to pay any
amount that remains unpaid after the sale money has been applied
to the unpaid balance of the Loan and to what you owe under this
Agreement. You agree to pay interest on that amount at the same
rate as the Loan until that amount has been paid.
10. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE LOAN -
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 Loan, you agree that
this Agreement will remain in effect.
11. CONTINUED EFFECTIVENESS - If any part of this Agreement is
determined by a court to be unenforceable, the rest will remain in
effect.
12. NORTH DAKOTA NOTICE TO BORROWERS PURCHASING A
MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION
MAY BE SUBJECT TO REPOSSESSION. IF IT IS NOT
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.
13. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful
for you to fail to return a motor vehicle that is subject to a security
interest, within thirty days after you have received notice of default.
The notice will be mailed to the address you gave us. It is your
responsibility to notify us if your address changes. The maximum
penalty for unlawful failure to return a motor vehicle is one year in
prison and/or a fine of $150,000.00.
? The following notice applies ONLY when the box at left is marked.
14. 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 PURSUANT
HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT EXCEED
AMOUNTS PAID BY THE DEBTOR HEREUNDER.
15. OTHER PROVISIONS -
0 ri rota Mi Mjai rpni ip i aao 7nnn )nni At i o,cure OGQCC\/Cn
Member #First Name Last Name ISoc Sec #1 Gen Misc JAHIFI#ComICU#l
084535 ROBERT IOLLISON JR. 1 2222 IDI 51
--------------------LOAN 10 INQUIRY - USED CAR ------- ------------
CURRENT BAL 12351.52 INTEREST DATE 042809 INT PAST DUE 0.00
ORIGINAL AMT 21906.26 ORIGINAL DATE 070207 INT ACCRUED 0.00
LAST ADV BAL 21906.26 LAST ADV DATE 070207 TOTAL INT DUE 0.00
PLEDGE AMOUNT 0.00 BASE DATE 073007 ANNUAL RATE 7.500
UNAPP ATM ADV 0.00 REVIEW DATE DAILY ACCRUAL 2.54
CREDIT LIMIT 0.00 DUE DAYS 112 30/ 0 LATE FEE RATE 0.00
AVAILABLE AMT 0.00 DUE DATE 043010 LOAN OFFICER 68
TOTAL CREDIT 0.00 TERMIMATURITY 72/063013 SUMMER SKIP
CHRDG-OFF AMT 0.00 CHRG OFF DATE RPT-PROC CDS =5 •G =
DELINQ AMOUNT 0.00 DELINQ PMTS 0 DLNQ 30160190 0 1 0
PARTIAL PMT 112.83 COLLECT DATE 022809 COLLECT AGENT CA3
SCHEDULED PMT 408.64 PAYMENT METH TRANSFER NOTE NUMBER LH
ALT CNTIPMT 0/ 0.00 PAYMENT FREQ MONTHLY MISCELLAN90US 640
LAST PAY DATE 042809 UNSECURED CD N PURPOSE CODE B
LATEICOL FEES 0.00 OPEN-END LOAN NO COLLATERAL CD 25
PAYOFF AMOUNT 12351.52 MORTG OWNER INT CALC METH SIMPLE
COUNTERS 0 0 0 0 0 LATE FEE 0.00/043010
TYPE:
'1?4XZ6-
New Cumberland Federal Credit Union
P. O. Box 658
New Cumberland, PA 17070-0658
Robert A. Ollison, Jr.
505 Barry Court
Mechanicsburg, PA 17050
April 28, 2009
Title: 60218740102 OL
Vehicle: 1N4BA41 EX4C884062
Dear Robert,
This is to notify you of the disposition of the proceeds from the sale of your repossessed
vehicle.
Principal loan balance $ + 25,227.19 (L10, L11, L12)
Past due interest + 619.64
Sales expenses and fees + 0.00
Proceeds of sale - 7,215.00
Due Credit Union $ 18,631.83
Unless regular payments are received by the Credit Union or arrangements are made with
the Credit Union to meet this outstanding balance, we may have to take whatever legal
action is deemed necessary to liquidate the loan.
Please call us within 7 days to make arrangements for a satisfactory repayment schedule,
717-774-4633, ext. 215.
;;; es
Sr. Collector
New Cumberland Federal Credit Union
P. O. Box 658
New Cumberland, PA 17070-0658
Katrina Ollison
505 Barry Court
Mechanicsburg, PA 17050
Dear Katrina,
April 28, 2009
Title: 60218740102 OL
Vehicle: 1 N4BA41 EX4C884062
This is to notify you of the disposition of the proceeds from the sale of your repossessed
vehicle.
Principal loan balance $
Past due interest
Sales expenses and fees
Proceeds of sale
+ 25,227.19 (L 10, L 11, L 12)
+ 619.64
+ 0.00
- 7,215.00
1)ue Credit Union $ 18,431.83
Unless regular payments are received by the Credit Union or arrangements are made with
the Credit Union to meet this outstanding balance, we may have to take whatever legal
action is deemed necessary to liquidate the loan.
Please call us within 7 days to make arrangements for a satisfactory repayment schedule,
717-774-4633, ext. 215.
Si cerel
ee Jo s
Sr. Collector
?K.
NEW CUMBBA;LAND FEDERAL CA;BDI'f . '4ION
P.O. Box 658 New Cumberland, € - 17070-0858
(717) 774-4833 • 1-800-716.2328
LOAN AND SECURITY AGREEMENTS
- AND DISCLOSURE STATEMENT
LQ?N/QAT?2 0 0 7 L f N? YMBER AMBER G P ICY NUMBER
1 14 L f 11 MATURITY DATE
BORROW €R..1 AVER 2
NAME AND ADDRESS NAME (AND ADDRESS IF DIFFERENT FROM BORROWER 1)
ROBERT A OLLISON JR. KATRINA L KIRKMAN
505 BARRY COURT
MECHANICSBURG PA 17050-4601
.:I: ilvs .. Re. S .
ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price
The cost of your credit as a yearly rate. The dollar amount the The amount of credit The amount you will have The total cost of your purchase on credit is
credit will cost you. provided to you or on paid after you have made $
your behalf. all payments as scheduled.
11 . 900 % $ 2,363.71 e $ 8,929.63 $ 11, 945.09 a which includes your
downpayment of 9
Your Payment Schedule Will Be: Prepayment: If you pay off earl
Number of Payments Amount of Payments When Payments Are Due pay a penalty. Y You will not have to
103 $ 114.86 BI-WEEKLY 11/30/2007 Required Deposit: The Annual Percentage Rte does
AND 1 $ 114.51 a not take into account your required deposit, if ny.
Property Insurance: You may obtain property insurance from anyone you 0 Assumption: Someone buying your mobile ome
want that is acceptable to the credit union. If you get the insurance from us, ocant riginal terms a the remainder of the loan on the
you will pays N/A
Demand: This obligation has a demand feature.
Late Charge: All disclosures are based on an assumed
maturity of one year.
THIS CREDIT UNION DOES NOT ASSESS LATE CHARGES
Filing Fees Non-Filing Insurance
$ $ 0.00 Security: Collateral securing other loans with the credit union may also secure this loan. You are givinNit
g a security interest in your
shares and dividends and, if any, your deposits and interest in the credit union; and the property described below:
Collateral Property/Model Year I.D. Number Type Value
Key Number
$ 0.00
$ 0.00
Other (Describe) $ 0.00
0.00 0.00
Pledge of Shares $ 0.00 in Account No. $ 0.00 in Account No.
See your contract documents for any additional information about nonpayment, default, and any required repayment in full before the
scheduled date.
CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT. By si ningg as
Borrower, you agree to the terms of the Loan Agreement. If property is described in the "Security" section of the I ruth in Disclosu
ou also onlLendi to the to msrof the Securii9y Ag eementrms of the Security Agreement. If you sign as "Owner of Property" you agree
(SEAL)
(SEAU
r?r/l ? / f./U_ l V (BEAU I ? I !1 ? I ill r `j (SEAL)
OFPROPERTV
D CUNA MUTUAL GROUP, 1999, 2000, 2001, ALL RIGHTS RESERVED
nrvvnoo n eceo.
Loan No.
L# 11
Acct. No.
Itemization of Amount Financed of Amount Given to You Directly Amount Paid on Your Account Prepaid Finance Charge
$ 8,929.63 $ 1,100.00 $ 7,829.63 $ 0.00
Amounts Paid to Others on Your Behalf: (If an amount is marked with an asterisk (") we will be retaining a portion of the amount.)
$ 7,829.63 To REF $ 1,100.00 To 010
$ 0.00 To $ 0.00 To
$ 0.00 To $
0.00 To
$ To $ To
$ To $ To
$ To $ To
$ To $ To
La?? AGRI:?iVIE1?T
In this Loan Agreement ("Agreement") all references to Credit Union "we," "our," or "us," mean the Credit Union whose name
appears above and anyone to whom the Credit Union assigns or transfers this Agreement. All references to "you," or "your" mean each
person who signs this Agreement as a borrower.
1. PROMISE TO PAY -
You promise to pay $ 8,929.6 the Credit Union plus interest on the unpaid balance until what you owe has been repaid. For fixed
rate loans the interest rate is 11.900; per year.
Collection Costs:
You promise to pay all costs of collecting the amount you owe under this agreement including court costs and reasonable attorney
f ees.
rya T 1V1CIV 1, - You promise to make payments of the
mount and at the time shown in the Truth in Lending
Disclosure, You may prepay any amount without p?enalty. IT
ou prepay any part of what you owe, you are Still required
Yo make the regularly scheduled payments, unless we have
agreed to a change in the payment schedule. Because this
is a simple interest loan, if you do not make payments
exactly as scheduled, Your final payment may be more or
I ss than the amoVnt of the final payrrlent that is disclosed.
I you elect credit insurance, we will either include the
premium in your payments or extend the term of your loan.
if he term is extended you will be required to make
additional payments of tie scheduled amount, until what
Y ou owe has been paid. You promise to make all payments
o the place we choos If this I an refinances another loan
we have with you, tie other loan will be canceled and
refin n d a Qf the d _tg of this IQan.
3.1 PR?CEEDS ?Y MAIL - It the proceeds of this loan
are mailed to you, interest on this loan begins on the date
the I n r ce dds ar m iled to you.
4.S EO?UgI P R L?AI?- This Agreement is secured b. all
e roPprty des ribed i the "Security, section of the Truth in
ending Disclosure. Fropertsecurty other loans you have
with also secures this loan, unless the property is a
dwellin A dwelling secur s thi loan only if it is described
in the ' ecurity" section o? the sCruth in Lending Disclosure
for this loan. /f Credit Union has a federal ch rter. Statutory
Lien - If you are in default on a financial obligation to us,
federal law give us the right to apply the balance of shares
and dividends in all individual and joint accounts you ave
with us to satisfy that obligation. After you are in de cult,
we may exerci&a this right without further notice to you.
?We have a federal chart r if our name includes the term
Federal Credit Union.") h Credit Union has a state charter,
except h? Ohio and Rhode Island: We have a statutory lien
on the Shares and dividends and, if ant, the deposits and
interest in all individual and joint accoun s you have with us
and may xercise our righ? under the lien to the Qxtent
permitted Ty state law. (V1?a have a state charter if our
name dyes not incl de he term "Federal Credit Union."1
For ail borrowers: ou p?edge as security for this loan all
shares and dividends and, Wan , all deposits and interest in
all joint and individual accouyou nave with th credit
union now and in the future. statutory lien andtor our
ledge will allow us to apply the Junfls in yo ?r account(s)
to what you owe when you are in efault. he statutory
lien and your pledge do not apply to any Individual
Retirement Account or any other ac o nt that would lose
special tax treatment under state or Tederal law if given as
secdiik
S. ULT - You will be in default under this Agreement if
you do not make a payment of the amount required on or
0 CUNA MUTUAL GROUP, 1999, 2000, 2001. ALL RIGHTS RFCFRVFn
before the date it is due. You will be in default if ou break
any promise ou made in connection with this lloan or if
anyone is in default finder any security agreement made in
connection with this Agreement. You will be in default you
die, file fqr bankruptcy, become insolven# (that is unable to
pay your bills and loans as they become due , or if you made
any TalSe or misleading f in your loan application.
You will also be in def quit if something happens that we
believe may seriously aft ct your ability, to repay what you
owe under this Agreement or if you are in default under any
other loan a reem nt Lou have with us.
6. ACTIONS?AFTE¢R DEFAULT - When you are in default, we
may demand immediate payment of the entire unpaid
balance under this Agreement. You waive any ri ht you have
to receive demand for payment, notice of inten? to demand
immediate payment and notice of demand for immediate
payment. If we demand immediate payment, you will
continue to pay interest at the rate provided for in this
Agreement, until what you owe has been repaid. We will
also apply against what you owe any shares and/or deposits
given, as security under this A reement. We may also
ex rcise any other rights given 6y law when you are in
de ault.
7. EACH PERSON RESPONSIBLE - Each person who signs
this Agreement will be individually and jointly responsible for
paying the entire a ount owed under this Agreement. This
means we can enforce oyr rights against any one of you
individu 11 Y 9r ag inst all of you toget?ier.
8. LATI ART - If you are late in making a payment, you
romise to pay the late charge shown in the Truth in Lending
?IscloS re. If no late charge is shown, you will not be
charggeT one.
9. NE AY IN ENFORCINGG RIGHTS - We can delay enforcin
any o 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
representativQs_.
10. CONTINUED EFFECTIVENESS - If any part of this
Agreement is determined by a court to be unenforceable, the
rest will remain in effect.
11. NOTICES - Notices will be sent tc you at the most
recent address you have given us in writing. Notice to any
one of you will be notice to all.
12. OTHER PROVISIONS -
Credit Union New Cumberland Federal Credit Union
Borrower(s) ROBERT _A OLLISON JR.
Member # First Name
1 416" ROBERT
--------------------LOAN 11
CURRENT BAL
ORIGINAL AMT
LAST ADV BAL
PLEDGE AMOUNT
UNAPP ATM ADV
CREDIT LIMIT
AVAILABLE AMT
TOTAL CREDIT
CHRDG-OFF AMT
DELINQ AMOUNT
PARTIAL PMT
SCHEDULED PMT
ALT CNTIPMT
LAST PAY DATE
LATEICOL FEES
PAYOFF AMOUNT
6279.79
8929.63
8929.63
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
114.86
0/ 0.00
042809
0.00
6279.79
Last Name (Soc Sec #1 Gen Misc IAHIFI#ComICU#l
IOLLISON JR. 2222 IDI 51
INQUIRY - ADJ SCORE/UNSECURED ------- ------------
INTEREST DATE 042809 INT PAST DUE 0.00
ORIGINAL DATE 111407 INT ACCRUED 0.00
LAST ADV DATE 111407 TOTAL INT DUE 0.00
BASE DATE 113007 ANNUAL RATE 11.900
REVIEW DATE DAILY ACCRUAL 2.05
DUE DAYS 112 31/ 0 LATE FEE RATE 0.00
DUE DATE 051509 LOAN OFFICER 65
TERMIMATURITY 104,/111111 SUMMER SKIP
CHRG OFF DATE RPT-PROC CDS =5 =G =
DELINQ ••PMTS 0 DLNQ 30160190 1 0 0
COLLECT DATE 022809 COLLECT AGENT CA3
PAYMENT METH PAYROLL NOTE NUMBER
PAYMENT FREQ BI-WEEKLY MISCELLANEOUS 602
UNSECURED CD N PURPOSE CODE K
OPEN-END LOAN NO COLLATERAL CD 44
MORTG OWNER INT CALC METH SIMPLE
COUNTERS 0 0 0 0 0 LATE FEE 0.00/051509
TYPE:
(Zss
F PiE P; "C)T,` PbTARY
'?M?PC09 !??'? t 1 PPS 3: l
*79. 50 PO A7N
(v„-° Sto 59
eic d;Lv `
Sheriffs Office of Cumberland County
R Thomas Kline d?atr ?t 4nrntrrr???D Edward L Schorpp
Sheri Solicitor
s
Ronny R Anderson Jody S Smith
Chief Deputy OFF:.'r OF ,eEWF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/12/2009 08:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 12,
2009 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Robert Ollison, by making known unto himself personally, defendant at 505 Barry Court
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
him personally the said true and correct copy of the same.
05/12/2009 08:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 12,
2009 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Katrina L. Kirkman, by making known unto Robert Ollison, husband of defendant at 505
Barry Court Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $56.14
May 13, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
2009-2953
New Cumberland Federal Credit Union
VS
Robert A. Ollison, Jr.
By.
Deputy Sheriff
-
Q
NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
ROBERT A. OLLISON, JR., AND
KATRINA L. KIRKMAN,
a/k/a KATRINA L. OLLISON
DEFENDANTS
NO. 09-2953
TO: Robert A. Ollison, Jr., and Katrina L. Kirkman, a/k/a Katrina L. Ollison
505 Barry Court
Mechanicsburg, PA 17050
DATE OF NOTICE: June 3, 2009
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONA AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
AVISO IMPORTANTE
A: Robert A. Ollison, Jr., and Katrina L. Kirkman, a/k/a Katrina L. Ollison
505 Barry Court
Mechanicsburg, PA 17050
ECHA DEL AVISO: June 3, 2009
USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO
Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS
QUE SE HAN PRESETADO CONTRA USTED. A MEMOS QUE USTED ACTUE
DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA
VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS
IMPORTANTES.
USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A
LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE.
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO
A PERSONAS QUE CALIFICAN.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Respectfully submitted,
By:
#6well Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: June 3, 2009
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
Robert A. Ollison, Jr., and Katrina L. Kirkman, a/k/a Katrina L. Ollison
505 Barry Court
Mechanicsburg, PA 17050
B,
Date: June 3, 2009
FUD-O ICE
OF THE PF??1 # OTAPY
2009 JUN -4 PM 1: 16
CWPf.
PENNS'62VA NA,
r
NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V.
ROBERT A. OLLISON, JR., AND
KATRINA L. KIRKMAN,
a/k/a KATRINA L. OLLISON
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 09-2953
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter a DEFAULT JUDGMENT against ROBERT A. OLLISON, JR., AND
KATRINA L. KIRKMAN, a/k/a KATRINA L. OLLISON for their failure to file and Answer to
the Complaint served May 12, 2009 by the Office of the Sheriff of Cumberland County as shown
on Exhibit "A-1" in accordance with PA R.C.P. 404 and 403. A Notice of Intention to Take a
Default Judgment was filed on June 4, 2009 and served using a U.S. Postal Certificate of Mailing
by first class prepaid postage on June 3, 2009 as shown on Exhibit "A-2" (Certificate of Service
and USPS Form 3817 are attached showing service). No answer or response having been filed
with the Prothonotary as of June 16, 2009 please enter a Default Judgment in the following
amount of $19,306.22 plus all costs:
Count I $12,351.52
Interest Count I $ 124.46 ($2.54 Per Diem from 4/28/2009)
Count II $ 6,279.79
Interest Count II $ 100.45 ($2.05 Per Diem from 4/28/2009)
Fees 450.00 (Attorney Fees per Contract)
$19,306.22 plus all costs
Respectfully submitted,
By:
Date: June 16, 2009
<?6 ell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Attorney for Plaintiff
M''-`. Sheriffs Office of Cumberland County
''tr 04 cu mbrr,? d Edward L Schorpp
R Thomas Kline b.4" Solicitor
.
Sher
Ronny R Anderson Jody S Smith
Chief Deputy 4FnOE of THE SKRIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/12/2009 08:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 12,
2009 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Robert Ollison, by making known unto himself personally, defendant at 505 Barry Court
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
him personally the said true and correct copy of the same.
05/12/2009 08:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 12,
2009 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Katrina L. Kirkman, by making known unto Robert Ollison, husband of defendant at 505
Barry Court. Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $56.14
May 13, 2009
2009-2953
New Cumberland Federal Credit Union
VS
Robert A..Ollison, Jr.
SO ANSWERS,
ems? ,
R THOMAS KLINE, SHERIFF
By
Deputy Sheriff
NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V.
ROBERT A. OLLISON, JR., AND
KATRINA L. KIRKMAN,
a/k/a KATRINA L. OLLISON
DEFENDANTS
[0 COPY
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 09-2953
TO: Robert A. Ollison, Jr., and Katrina L. Kirkman, a/k/a Katrina L. Ollison
505 Barry Court
Mechanicsburg, PA 17050
DATE OF NOTICE: June 3, 2009
IMPORTANT NOTICE
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C-
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ti
Him
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YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONA AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
AVISO IMPORTANTE
A: Robert A. Ollison, Jr., and Katrina L. Kirkman, a/k/a Katrina L. Ollison
505 Barry Court
Mechanicsburg, PA 17050
ECHA DEL AVISO: June 3, 2009
USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO 0 A TRAVES DE UN ABOGADO
Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS
QUE SE HAN PRESETADO CONTRA USTED. A MEMOS QUE USTED ACTUE
DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA
VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS
IMPORTANTES.
USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A
LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE.
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO
A PERSONAS QUE CALIFICAN.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Respectfully submitted,
By:
J Ewell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: June 3, 2009
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
Robert A. Ollison, Jr., and Katrina L. Kirkman, a/k/a Katrina L. 011ison
505 Barry Court
Mechanicsburg, PA 17050
U.S. POSTAL SERVICE CERTIFICATE OF MAILING }
MAY BE USED FOR ^^?r?enr n?rn IM--ATrnMer u n - nj .- 0
p
PROVIDE FOR IN' Steven Howell _ Z; I
?a I
Received From Attorney At Law o° e
619 Bridge Street 110 _
New Cumberland, PA 17070
One Piece of ordinary mail addressed to: c2
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U.S. POSTAGE
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NEW CUMBERLAND FEDERAL
CREDIT UNION,
PLAINTIFF
V.
ROBERT A. OLLISON, JR., AND
KATRINA L. KIRKMAN,
a/k/a KATRINA L. OLLISON
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 09-2953
RULE 236 NOTICE OF FILING JUDGMENT
(X) Notice is hereby given that a money judgment in the above captioned action has been
entered against you in the amount of $19,306.22 plus all costs on June Jry'µ, 2009.
(X) A copy of all documents filed with the Prothonotary in support of the within judgment
is/are enclosed.
othonot *'i
BY:
If you have any questions regarding this Notice, please contact the filing party:
Steven Howell, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
This Notice is given in accordance with Pa R.C.P. 236. Notice should be sent to:
Robert A. Ollison, Jr., and Katrina L. Kirkman, a/k/a Katrina L. Ollison
505 Barry Court
Mechanicsburg, PA 17050