HomeMy WebLinkAbout10-2744c t Tr;? ,T'ARY
2010 %FR 23 Pill 2: 23
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
JAMES E. NAUGLE and
KIMBERLY K. NAUGLE
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 10 oZ?4? C?vi l?r?m
: CIVIL ACTION -LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20) days after this
Complaint and Notice are served by entering a written appearance personally or by
attorney and filing in writing 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 claims or relief requested by the
Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
01.0co PD 1\7V
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& ?41o17,2
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o
sus objectiones a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
MEMBERS 1 FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
JAMES E. NAUGLE and
KIMBERLY K. NAUGLE
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO..
CIVIL ACTION-LAW
COMPLAINT
AND NOW, comes Members 0 Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney, Karl M. Ledebohm and makes the
following complaint:
1. Plaintiff, Members 1St Federal Credit Union ("Members 1St"), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
1
2. Defendants, James E. Naugle and Kimberly K. Naugle (collectively herein
"Defendants"), are adult individuals having a last known address of 15581
Paxton Run Road, Newburg, PA 17240.
3. Defendants submitted to Members 1St a credit card application (the
"Application") for a Visa credit card issued by Plaintiff.
4. Plaintiff accepted the Application and sent to Defendants a Visa Credit Card,
account #4287-5900-1119-8252 (the "Visa Account") and the corresponding
Visa Credit Card Agreement and Disclosure Statement.
The Visa Account is governed by the Credit Card Agreement and Disclosure
Statement (the "Credit Card Agreement and Disclosure"), a copy of which is
attached hereto as Exhibit "A" and made part hereof.
6. Pursuant to the terms and conditions of the Credit Card Agreement and
Disclosure, Defendants agreed to pay to Plaintiff monthly installments in an
amount of not less than two percent (2.0%) of the outstanding balance on the
account or $20.00, whichever is greater.
7. Defendants have made charges against the Visa Account and are in default of
Defendants' obligations under the Credit Card Agreement and Disclosure and
the corresponding Visa Account as a result of Defendants' failure to make the
payments due to Plaintiff as set forth in the Credit Card Agreement and
Disclosure, the last payment having been received by Members 0 on or about
December 5, 2008.
By letter dated March 12, 2010, addressed to Defendants, Plaintiff demanded
the payment of all amounts due under the Credit Card Agreement and
2
Disclosure and the corresponding Visa Account. A copy of Plaintiff's
9.
10.
11.
12
Demand is attached hereto as Exhibit "B" and made part hereof.
Defendants are indebted to Plaintiff in the amount of TWELVE THOUSAND
FOUR HUNDRED FORTY-FOUR AND 59/100 ($12,444.59) itemized as
follows:
a. Principal $10,296.18
b. Unpaid Finance Charge 738.41
c. Unpaid other fees 210.00
d. Legal Fees 1,200.00*
e. Total due to Member 1St $12,444.59
*Legal fees for collection are estimated in accordance with the terms and
conditions set forth in the Credit Card Agreement and Disclosure. Defendants
will be responsible for payment of actual, reasonable legal fees incurred by
Members 1St in this matter which may be more or less than the amount stated
depending upon the date of payment and legal fees actually incurred by
Members 1 st
Defendants also agreed under the terms and conditions of the Credit Card
Agreement and Disclosure that in the event of default there under Defendants
would pay, in addition to the amounts set forth in paragraph 9 above,
additional reasonable legal fees, if any, and costs incurred by Plaintiff as a
result of the institution and prosecution of these legal proceedings.
Legal fees and costs continue to accrue on the above obligation as set forth in
the Credit Card Agreement and Disclosure through the date of payment.
As set forth above, Plaintiff has made demand upon Defendants to make
payment of all amounts due to Plaintiff under the Visa Account and
3
corresponding Credit Card Agreement and Disclosure and, as of the date
hereof, Defendants have failed and refused to make payment of all such
amounts due to Plaintiff.
WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment
against Defendants, JAMES E. NAUGLE and KIMBERLY K. NAUGLE, in the amount
of TWELVE THOUSAND FOUR HUNDRED FORTY-FOUR AND 59/100
($12,444.59) together with additional attorney's fees and costs of suit and interest at the
legal rate on and after the entry of judgment on this complaint which does not exceed the
jurisdictional amount requiring arbitration referral by local rule.
Date: April 19, 2010
Respectfully submitted,
arl M. Ledebohm, Esq.
Supreme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
4
VISA Credit Card Agreement and Disclosure
Notlixi: See reverse side nor important intimation regarding your rights to dispute billing errors.
1. Moaning of Wander. The following wads have Ifs following meanings in this Agreement and in the monthly billing statement sent hereunder:
(a) 'Agreeme ar means the Visa Credit Card Agreement and Disclosure turmsted by us.
(b) 'we, 'us' and "our" means Merrd>ers 1st Federal Credit Union, Mechanicsburg, PA.
(c) you' and 'your means each person who signs die application for 8le Account.
(d) 'Card' means any Visa Credit Card and any duplicates and renewals we issue to you or to an authitzed use of your Account.
(e) :Card'
means your Visa Credit Card Account with us.
(f) 'Lire of Credir means to self-replenishing line of credit we make available to your Account.
Ili 'Advance' means any credit extended on your Account for any purchases or Cash Advances.
(h 'Cash Advance' means (1) any cash or credit extended on your Account by us or by any olher Institution that "its a Card, (it) any withdrawal of cash made by using a Card and personal identification number ('PIN') at an automated teller machine (-ATM")
or other We of electronic terminal that provides aims to the Visa system, (ill) the amount of any Visa Convenience Checi paid by us, or (iv) the amount of any balances transferred to your Account from another credit Card or account.
(i) -Visa Convenience Check' mere any deck that directly accesses your Account. The amount of any Visa Convenience Check paid by us is posted as a Cash Advance under your Account.
2. Now To Use This Accoanl. Your Account may be used to purchase or lease goods and services ('purchases") from a merchant by presenting a Card and signing a sales transaction rannipb for the amount of tle purchase or by giving a Card Account number
Your Account may also be used to obtain Cash Advances;
(a) By receiving cash or credit from flarcml Institutions that accept a VISA Credit Card;
(b) By use of Visa Convenience Clacks;
(c) By making cash withdrawals with a Card at an ATM or other type of electronic terminal tat provides access to ft Visa system; or
(d) By transferring to your Account a balance from another credit card or account.
3. NesWsWWy. You agree to pay all Adam, finance charges and other tenor charges c argot to your Account arising from to use of a Card, a Visa Convenience Chock or One Account by you or anyone you authorize of permit to use your Ac unt, a Ursa
Convenience Check or a Card, am t you do rat notify uslhat odors are using your Account, a Visa Convenience Check or a Gad. Your responsibility for charges made by anyone you authorize or permit to use your Account. a Visa Convenience Check of a Card
continues unit you not ty us In writing at 5000 Louise Drive, P. 0. Box 40, Mechanicsburg, PA 17055, and recover and destroy any Visa Convenience Check or Card in surf personk possession. Your obligation to pay the Account balance conlim m regardless of
the terms of any agreement, divorce decree, or other cam judgment to which we are not a party. t more than one person signs life application for IM Account. you are each Jointly and sweaty responsible for all charges on the Accord.
4. L mbillI yr for UmwuNhorlpd Uoo. You understand that your total liability to us stall not exceed Filly Dollars 450) rmubg from to loss, dot or rther unauthorized use of a Card that scars prior to the time you give ration to us. Such limitation does not apply
when a Visa Convenience Crock is used.
b. LM Card NoUNatlon. If you bellev r a Card or any Yea Convenience Check has been IN or stolen, you must immediately call us at (717) 795-8032 or 1(800)-283-2328 during normal business hours. After business hours (nights and weekends) or on hol-
idays, lest or stolen Cards or VISA Convenience Checks must be reported by calling 1(800)-325-3678.
6. Credit Una. If we approve your application, we will establish a Lire of Credit for you and notify you of its amount when we Issue a Card. This mount is your credit limit for the Account. You agree not to let the Acaunf balance exceed this approved credit limit.
Each payment you make on IN Account will restore your credit limit by the amount of One payment 00 is applied to the princlo bolo= owed on the Account. You may request an Increase In your credit limit which most be approved by us. We may reduce your
credit limit or terminal# this Agreement! for arty reasons not prohibited by applicable law, with only such notice as Is required by appgcable law. You may also hi ninale this Agreement at arty time, but lamination by either of us does not affect your obligation to
pay the Account balance. To terminate this Agreement, you must notify os In writing at 50DO Louise Drive, P. 0. Box 40, Mechanicsburg, PA 17055, and meow and surrender to us all Cards, and any issued but unused Visa Conve fence Checks. They remain our
propartY.
7. CradN Information. You authorize us to imesd0110 your credit standing when opening, renewing or reviewing your Account, and you authorize us to disclose Information regarding your Account to credit bureaus and offer creditors who inquire of us about your
=!%
6. will mail you a billing statement every mordh showing your Previous Balance comprised of purchases and Cash Advances, the current transactions an your Account, your credit lialk die available credit, The New Balance, the Fiance Charges for
to billing cycle, and the Minimum Payment requited. Each month you must pay at leas) the Minimum Payment shown an your statement by to Payment Due Dab shown on the sblemant or rho later den 25 days from to statement Closing Date, whichever is
later-, ifyour statanern Says your papnteRis'NoarDire; yiwrpeymo t Is duo•rhmRlzrIne ZSrdapsffom tlasbtamenmCbshgDah: YWrayaay mortrlrogaettyleYmarEtan the Minim twPay in.! urge ft New,99 it, full. If You nuke extra or lxdn
payments, you are silt required to make at least dta Minimum Payment each month your Account has a balance (other than a credit balance).
The Minimum Payment will be either a) Two percent (2%) of your New Balance or $20, whichever is greater, plus any portion of tat Minimum Payment shawl on prior statement(s) which remains unpaid, or b) your New Balm, If t is less than Twenty Dollars
($20).
We also have the right to demand immediate payment of any emou ll by which your New Balance is over your credit limit.
We will apply your payments first to any fees, ten to Finance Charges on both Cash Advances and purchases, then to previously billed Cash Advances, I* to previously billed purchases, then to new Cash Advances and then to new purchases,
We may accept checks marked 'payment in full' or with words of similar effect without losing any of our rights to oollect the full balance of your Account.
9, Ron
ce Clamp.
A. The currant mdnthly Periodic Rate and corresponding Annual Percentage Rate are set forth on the 'Additional Disclosure which is surd to you together with this Agreement
I. Variable Nate: The Annual Percentage ltete will be determined by adding the margin to the index value. The Annual Percentage Rate can dirge on the first calendar day of the first billing cycle in each calendar quarter. Tte margin for Visa Platinum is
5.gD% for bodn puritans and Cash Advances The margin for Visa Gold Is 5.00% her both purchases and Cash Advances. The margin lot Visa Classic is 5.50% for both purchases and Cash Advances. The margin for Visa Classic gate Shaver Is 2.00% for
both purchases and Cash Advances, subject to a minimum Annul ParoaMap Now of 9.9% for the Visa Classic Rob Sharer program. The index is the highest Prime Rale published in the money rates section of one Wall Sueel Journal. The index will
be measured as of the last business day of tle immediately preoading calendar quut f. Any increase In the Annual Percentage Pale may cause the amount of the minimum mcedhy, paymed to increase. Also. you may have to pay mote payments. The Annuol
Potentials Mw will rover exceed 21% or the nammaxn allowed by law, whichever is less. The monthly Periodic Rene is equal to oneawelth (1112) of the Annual Percentage Rate.
C. Margined A - Average Daily Balsa (Including Now Cub Advances): A Finance Charge wig be imposed on Cash Advances from the date made or from tle first day of the billing cycle In which the Cash Advance Is posted to your Account, whichever
is later, and will continue to accnhe unit the data of perm ent.
Tile Finance Charge on Cash Advances for a billing cycle is computed by applying the monthly Periodic Rate to the average dairy balance of Cash Advances, which is determined by dividing the sum of the daily balances duing the billing cycle by the
number of days in the cycle. Fach daily balance Is determined by taking the beginning balance of Cash Advances on your knot each day, adding any now Cash Advances, and subtracting any payments or credits that are applied Id Cash Advances but
excluding any unpaid Finance Charges.
D. MoMW D • Averap Daily Balance (hncladiag Naar Credit Purchases): A Finance Charge will be imposed on purchases only t you eied not to pay to on ire New Balance shown on your monthly billing statement for the previous billing cycle on
or before the Payment Due Date of that statement t you elect nit to pay to entire New Balm show on your previous montty billing statement by to Paymod Due Dale, a Fiance Charge wig be Imposed on the unpaid average daily balance DI purchases
from the previous statmanl Closing Data and on now purchases from the data of posting to your Accent during tie cumin billing cycle, and wig continue to accrus untl rite Closing Date of de billing cycle preceding to data on which the entire New
Balance is paid in fug or urail the date of paymatt t later that the Payment Due Deb.
The Finance Charge on purchases for a billing cycle is computed by applying the manthy Periodic )tale lo the average Vally balance of purchases, which is determined by dMdIM the sum d l ha dally balances during the billing cycle by the number of days
intM? le. Each dairy balance is determined by taking the beginning balance of purchases on your Account each day, adding ary new purchases, and subtracting any payments or credits That are applied to purchases, but excluding any unpaid Finance
ad. Derfautl. You will be in dehuht if you fall to make any minimum payment or other required payment by to dab that It Is doe. You will be In default ff you break any promise you make under this Agredthent. You will be In default it you die, file ti bankruptcy, on
became lnsoMK that is, unable to pay your obligations when they become due. You will be In default 9 you make any false of misleading statements in arty crergl application or update of crafgl information. You will also be in deaut t something happens which
we bafieve may Substantially reduce your ability to repay what you core. When you are in detest we can demand ImmedWe payment of to afire amount you awe radar this Agreement without giving you advance notice. t immediate paymentis demarded, you
will continue to pay interest, at the applicable interest vales In offed undo this Agreement, until wait you owe has been repaid. II demand for Immediate payment his been made, the shares and deposits given as security for paynd under this Agreement can be
applied towards what you owe. We can also take epproprbb action as a dhiind under to Uniform Commercial Cade to repossess any and all collateral pbdged to secure repayment under this Agreement. To to adem permited by applicable law, you will also
be required to pay ourcollection expenses, Including court costs and reasonable atemeys' fees. We can also exercise any other dots given to us by law when you ore In default
11, Using Me Card. You may use a Card, Card Account number andMr PIN to make transactions on your Amount. You will retain the copies of the transaction receipts furnished to you in order to verity your monthly billing swernen. You agree Ural you will not
use of perrnit anyone to use a Cato of your Account for any transaction that is Illegal under applicable leieraf, able of focal law. You agree tat illegal use of any financial seMm will be deemed an action of data It and/or breach ot contract and such a service
and/ix other related services may be terminated A our discretion. You further agree, should itegal use occur, to waM any right to sue Us for Mich illegal use or any activity dinacty or Indirectly related to it. Additionally, you agree to indemnify and hold us hamm-
less from any suits or other lead action or liability, directly or Indirectly, resulting from such Illegal use. We reserve to right In, decline any tmrhsedloro that we consider hauduleit, suspicious, or illegal and you kosher understand that we wi It not knowingly mdho-
rize charges related to online gambling.
Print Date 4108
36-00 COKINUED ON REVERSE
Exhibit "A99
12. Nabnw aced Agodaswla. irtercharps and others who honor a Card may give credit or returns or ad)rshtmts, and they will do so by sending us a cWft transaction receipt. which we will post to your Account. 11 your credits and payments exceed what you
owe us, we wall fold and apply this credit balance toward fuvae purdaaes and Cash Advances, or If nt Is one dollar or more, rehmd it an your written request or a domillially after six months.
13, Will; Via Crewad ass Chub. You may use your Yea Co avolence Cheeks, If awailable, as you would use a Cad to make a purchase or paymad or to receive cash. Your Visa Convenience Checks directly access your Account. All Visa Convenience
Checks paid by us are treated as Cash Advances hereunder and, except as otherwise indicated, are subject to all terms of this Agreement pertaining to Cash AMarces and to the following additaet terms:
A. No Visa Ccrwe lerxe Check may be used to male a payment on your Account.
D. Only The person whose name appears on a Visa Comcnienoe Check may use them.
C- Visit Corwarkerce Checks must be written in U.S. Dollars. Visa Convenience Checks may not be certified
D. Wit magi return a Visa Crxrvenkince Chock unpad t there is not enough aafths credit on your Account to pay it, if your Account is in default or P a lard at any Visa Corwenience Chocks have been reported lost our stolen. A $10 fee will be charged for each
rdurnod Visa Cawanlena Chock.
14. Fordpm ti mm$mw. Purchases and Cash AcAnmcw made In foreign countries and loreign currencies will be billed in U.S. Dollars. Etfullve W12, 2996, the ecKha ale tale for lransaciona; in a foreign cumliq will be a rate selected W Visa from the
range of rates avellable in wholesale currency markets for the applicable central processing dale, which race may vary from the rate Visa #sell receives, or the government mandated rate in effect for the applicable central processing dale, increased by orm-porcent.
on fa ign connections you am to pay all currency loop chips.
16. Mw twat f3lapltal. We are not responsible ter the refusal of any merchant or fi ariM insWion to honor a Cad or Visa Gamenlence Check.
15. 9ewMr hAaeaaI. To secure your Account, you grant us a purchase money security Interest under the Uniform Commercial Code in any goods you purchase using the Amount. It you default we will have the right to recover any of sale goods which hens not
been paid for through our application ol your paymerb m the mama described in paragraph S.
FI? 41 Shm Ace 0 OM To some lour Mawat, file ~ b as uM Wool w Oawllll labsast In 90 W ad IadlwliW acaaoN ilea lam walk Membo tat FaM I OmM Vmbo am mod he the bhn,
M a lu-alahsaa0 adua Yes ardmis a to qFb 1M YNOaw in am ddadL
pay my mmoft be smile No NaMwri Asouft Mdaass cub ? the pthellp or f oulve of which coastal am In tall d a ba•mnaallA
*am Ile kfd"
17. Fait and f»aa C%wW. The following fees and other dirges will be added to your Amount, as applicable:
A. Allied In
Visa Platinum .. ........... Nonc
Visa Gold .............. ... None
Visa Classic ................ Nate
Vise Classic tqk Stover...... None
9. tale Fap sM Gran-, . If you fall to pay the minimun payment on your Account within fin (5) days of the Payment Due Data, a late payment charge of $30 will be added to your Account.
C. Ow4b ed Clasp. If your Amount balm giant your credit limit at any time during tai steha and period, an over-limit charge of $15 will be added to your Account.
0. Pill ' Claali Fes. Me check our share dram used to make a payment on your Amount is returned unpaid because at irsufficie t funds or far any other reason, you will be dinged a fee of $10 for W item returned.
E. lftdomed OtaMwwd Fas. You will be mtmged $1 for each monthly bilihq statement that Is returned.
F Coke M Ulaa That odu Resaipa acrd 9gtataseh. You will be dinged 33lot each mpy you request of a recelpl fa any purchase, and" or Cash Advance or d a maltlfy billing statekkleni (mco in mamredion with the resolution d a bilang error.)
Agreement.
t9- Aft kq payr not stand Its per'hod within Oft you miud to (NMI a pay the Ne oww Balanpayanio. ce in order Wl?plel you mas to mcrdh in which the option Is id Fii a nce Clages. on p irdcrses: aA ml iriimum payment ? be tae in the mo th tollowing the on your balance In accordance wilh this
month in which you skip your payment
19. of @Mm Apmo$ 4 This Agreenamt Is a contract which applies to all transactions on your Account even though the receipts you sign or receive for purchases, credits. Cash Adam or otter himudio s may contain differed terms. We may amend this .
Ageenma from time to biller by seeing you written Polka. It repriced % applicable last we will gin you written notice before The selective deb of the anadanad To the aderkt applicable law permits, and as we irrdiab in our notice to you, amenkirmktt will
apply to your existing Amount heiress wall as to White transactions. ThisAgreernent shall be construed to accordance wfth the applicable taws of the Commhonwleabh of Pennsylvania and applicable Water laws.
YOUR BILLING RIGHTS KEEP THIS FOR YOUR RECORDS
This notice contains important information about your rights and our responslbilkles under to Fair Credit Billing Ad.
NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR MONTHLY BILLING STATEMENT.
it you think your monthly billing shrlamenl Is wrong, or If you rind more intomdloe about a transaction an your statement write us on a separate sheet of paper at the address listed on your statement. Write to us as soon as possible. Vk must has from you no later
than 60 days after we send you the first slalemenl on which the error or problem appeared. You an isYphone us, but doing so will net preserve YDW rights.
In your letter, give us to following intemation:
• Your now and Account number
• The dolls amount of the suspected error.
• Describe Is error and ekplain, ff you an, why you balleve pine is an error. If you need more irdormalon, describe the item you are not sure about
It you have athakrad us to pay your mathly baling sfabmnd automatically ban your Swings or Checking Account you can stop the payment on pry armed You tank is wrong. To stop the payment you teas must reach us three (3) business days betas the ato-
malt payenm Is scheduled to ocarr.
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE.
M must allatowledge your letter within 3D days, unless we have connoted to error by ten. Whin 90 days, we must either correct the edam at volam why we belles tie sTafcrrml was cared.
After we receive your killer, we cannot try to caged any want you giasilon, or repot you as ddinque t We can continue to send stabrrwrYs to you for the amount you question. Inducting finance Barges, and we can apply army unpaid amount against your credit limit
You do not hive to pry any questioned amount while we am kwego* g, but you are still obligated to pay Itue parts o (your statement that are not In question.
If we find that we ask a rrd*k on your statement, you will net have to pay any finance charges related to curry questioned amount. ff we didn't stake a mistake, you may twwe to pay trance charges, and you will here to make up any missed payrtlents on the ques-
tioned amount. In efts use, we will send you a statement of she anmad you an and the dais list it is due.
If you fail to pay lithe amount tat we tltMc you awe, warily repart you as delinquent. Howwer. N our alpq min does not satisfy you and you write bus within ten days telling us that you still refuse t0 pay, we must tell anyone we reporl you to ft you have a ques-
tion aboul your di e w . And, we must tell you the name of anyonewe reported you to_ We must tell anyone we reporl youto pal the m tux has bank sett between us when a finally is.
It we don'I follow then rules, we can't called the first $50 of the qumtioned amkxtmt even it your statement was coned.
SPECIAL RULE FOR CREDIT CARD PURCHASES.
It you have a problem with the qualay of properly at services that you purchased with a aedft card, and you have tried in good lath to correct the prole emwllh the merchant, you may have the right not to pay the remaining amount due on the property or se curs. Thee
are two limitations on ibis right (e) you must have made the purchase in your home stale a, t net within your home slate, within 100 miles at your current mailing address; and (b) gs purchase price mug here been more thou $50.
These limitations do not apply a we own or operate the mecant, or 11 we mailed you the advertisement for the property or services.
KARL M. LEDEBOHM
ATTORNEY-AT LAW
P.O. BOX 173
New Cumberland, PA 17070-0173
Phone: 717-938-6929
Fax: 717-932-0317
Of Counsel: Richard P. Mislitsky, Esq.*
March 12, 2010
(Via Certified and regular mail)
James E. Naugle
Kimberly K. Naugle
15581 Paxton Run Road
Newburg, PA 17240
RE: Members 1" Visa Account No.: 4287-5900-1119-8252
Dear Mr. Naugle:
Dear Mrs. Naugle:
THIS CORRESPONDENCE IS FROM A DEBT COLLECTOR. THIS
LETTER AND ANY SUBSEQUENT CORRESPONDENCE FROM THIS OFFICE
IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED MAY BE USED FOR THAT PURPOSE. AN IMPORTANT
STATEMENT OF RIGHTS IS INCLUDED ON THE REVERSE OF THE
SECOND PAGE OF THIS LETTER.
Members 1" Federal Credit Union ("Members 1 S`") has requested my office to
collect the amounts due to Member's 1 S` under the above account.
As you know, you are in default of your obligations under the above Members 1 S`
Visa Account (the "Account") due to your failure to make the payments required under
the Account in a timely manner. The last payment on the Account was received by
Members ls` on or about December 5, 2008 in the amount of $200.00. As a result of your
defaults, Members 1 S` hereby accelerates all amounts due to Members 1" under the
Account and hereby demands the payment of all amounts due to Members 1 S` under the
Account in the amount of $11,412.59 itemized as follows:
1. Principal $10,296.18
2. Unpaid Finance Charge 738.41
3. Unpaid other fees 210.00
4. Legal Fees 168.00
5. Total due to Member ls` as of 3/12/10 $11,412.59
*Also practices independently as Richa Exhibit "B"
If you fail to deliver to my office at the address set forth above payment of the
$11,412.59 within thirty (30) days of the date of this letter, Members 1 S` will have
choice but to file a legal action against you to collect all of the amounts due under th
Account without further notice. In such event, in addition to the above amounts, the
also be responsible for the payment of additional reasonable legal fees and costs of suit
incurred by Members 1 St. you may
Nothing herein shall constitute or be construed as an agreement on behalf of
Members 1 St to accept any terms and conditions in exchange for payment of th
due under the Account except for the immediate payment of all amounts due t the amounts
1St • Nothing herein shall constitute a waiver of any rights dies w o Members
1 S` may have under any written agreement or at law or or reme
he b in equity to collectltch Members
the indebtedness due under the Account without further notice, ito colle w'th alance of
mlimitation, the right to accept and a 1 g, out
without waiver of any demand for payment in full of allnamounts due un e Account
Nothing herein shall constitute an agreement on behalf of Members 1 st to postpone Account.
der the extend the maturity date of the obligation. or
Members 1St looks forward to the payment of the $11,412.59 on or before April
11, 2010. Very truly urs
/Karl . Ledebohm
CC: David Thomas, Collections Officer
KML:11
NOTICE
This letter is an attempt to collect a debt.
It you dispute the validity of this debt, or any portion thereof, and you notify the
undersigned debt collector in writing within thirty (30) days of the receipt of this notice
that you dispute the debt or any portion thereof, the undersigned debt collector will obtain
verification of the debt or a copy of a judgment against you, if any, and mail to you a
copy of such judgment or verification.
If you do not dispute the validity of the debt or any portion thereof within thirty
(30) days of the receipt of this notice, the undersigned debt collector will assume the debt
to be valid.
If the original creditor of this debt is different from the creditor stated on the front
page of this letter, the undersigned debt collector will provide you with the name and
address of the original creditor upon written request from you within thirty (30) days of
your receipt of this notice.
The "undersigned debt collector" means the name signed at the end of this letter
appearing in print at the top of this letter.
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RS lSx FEDERAL IN THE COURT OF COMMON PLEAS
C UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO..
E. NAUGLE and
RLY K. NAUGLE
DEFENDANTS CIVIL ACTION-LAW
VE1MC.ATION
I, David Thomas, Collections Officer for Members I" Federal Credit Union,
eixrg authorized to do so on behalf of Members I" Federal Credit Union, hereby verify
iat the statements made in the foregoing pleading are true and correct to the best of my
iformation knowledge and belief. I understand that false statements are made subject to
ie penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to
Members 1' Federal Credit Union
By: Q -1--i s
David Thomas, Collections Officer
5
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ,, -•,t; ~ ~-~~-
Sheriff ~(! '{'~F!L~#~
,ti;, pt ~ti+rft,~,1 .11~ ~ ~iG f S t'.., h ` ! ,! CI~TP~'l l
Jody S Smith ~4, ~ 'd~'a
Chief Deputy - ~~~~ ~~~ -$ ~~~ ~; !}~
,t.
Richard W Stewart
Solicitor ~F - _ =~~Fr CUMF . ~~:'~~ i ~ ,~-~,UMY
_~.,
F'ENi w~Y~Vi'~~ii,
Members 1st FCU Case Number
vs.
James E. Naugle (et al.) 2010-2744
SHERIFF'S RETURN OF SERVICE
04/28/2010 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: James E. Naugle, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Franklin County, PA to serve the within Complaint and
Notice according to law.
04/28/2010 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: Kimberly K. Naugle, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Franklin County, PA to serve the within Complaint and
Notice according to law.
05/12/2010 Franklin County Return: And now May 12, 2010 at 1539 hours I, Dane Anthony, Sheriff of Franklin
County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and
Notice, upon the within named defendant, to wit: James E. Naugle by making known unto himself
personally, at 15581 Paxton Run Road, Newburg, PA 17240 its contents and at the same time handing to
him personally the said true and correct copy of the same.
06/04/2010 Franklin County Return: And now May 12, 2010 at 1539 hours I, Dane Anthony, Sheriff of Franklin
County, Pennsylvania, do herby certify and return that 1 served a true copy of the within Complaint and
Notice, upon the within named defendant, to wit: Kimberly K. Naugle by making known unto herself
personally, at 15581 Paxton Run Road, Newburg, PA 17240 its contents and at the same time handing to
her personally the said true and correct copy of the same.
SHERIFF COST: $53.44
June 04, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
!c} CouniySuite Sheriff, T2~ec.=,o`t. Ir,:.
SHERIFF'S RETURN - REGULAR,
CASE NO: 2010-00110 T
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF FRANKLIN
MEMBERS FIRST FEDERAL
VS
JAMES E AND KIMBERLY K NAUGLE
ANGEL L LAVIENA
Deputy Sheriff of FRANKLIN
County, Pennsylvania, who being duly sworn according to law,
says, the within COMP CIVIL ACTION
NAUGLE JAMES E
DEFENDANT
was served upon
the
at 1539:00 Hour, on the 12th day of May 2010
at 15581 PAXTON RUN ROAn
NEWBURG, PA 17240
JAMES E NAUGLE
by handing to
a true and attested copy of COMP CIVIL ACTION
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing .00
Service .00 ANGEL L A
Affidavit .00
Surcharge .00 By
.00 uty Sheriff
.00 05/25/2010
KARL M LEDEBOHM ESQ
Sworn and Subscribed to before
me this ~j~ day of
~! / n
Notary l-
Richard D. McCarty, Notary Public
Chambersburg Boro, Franklin County
SHERIFF'S RETURN - REGULAR
CASE NO: 2010-00110 T
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF FRANKLIN
MEMBERS FIRST FEDERAL
VS
JAMES E AND KIMBERLY K NAUGLE
ANGEL L LAVIENA
Deputy Sheriff of FRANKLIN
County, Pennsylvania, who being duly sworn according to law,
says, the within COMP CIVIL ACTION was served upon
NAUGLE KIMBERLY K
the
DEFENDANT at 1539:00 Hour, on the 12th day of May 2010
at 15581 PAXTON RUN ROAD
NEWBURG, PA 17240
by handing to
KIMBERLY K NAUGLE
a true and attested copy of COMP CIVIL ACTION
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing .00
Service .00 ANGEL L A
Affidavit .00
Surcharge .00 By
.00 Deputy Sheriff
.00 05/25/2010
KARL M LEDEBOHM ESQ
Sworn and Subscribed to before
me this ~~ day of
~l~ A.D.
l_ /2
Richard D. McCarty, Notary Public
Chambersburg Boro, Franklin County
In The Court of Common Pleas of Cumberland County, Pennsylvania
Members 1St Federal Credit Union
vs.
James E. Naugle & Kimberly K. Naugle
15581 Paxton Run Road
Newburg, PA 17240
Civil No. 2010-2744
Now, Apri128, 2010, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of
Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.
~nenn oz t;umberland County; PA
Affidavit of Service
Now, y~ ~, , 20 l y , at~_o'clock ~M, served the
within
upon/~~
.~
at~,~~~
by handing to
l
a % e~ ~' 3"~ r>/ copy of the original~~ , ~ y. ~~y~^
and made known to /~';~,~~y ~! /~/~,r4~c the contents thereof.
S o answers,
~ ''~ ~/~.~c/mar .
Sheriff of
Sw rn a r~xbscribed
t d' da f ,20 ~~ ~ ~
r
r
Notarial Seal
Richard D. McCarty, Notary Public
Chambersburg Boro, Franklin County
M Commission Ex fires Jan. 29 2011
COSTS
SERVICE-
MILEAGE_
AFFIDAVIT
County, PA
In The Court of Common Pleas of Cumberland County, Pennsylvania
Members 1St Federal Credit Union
vs.
James E. Naugle & Kimberly K. Naugle
15581 Paxton Run Road
Newburg, PA 17240
Civil No. 2010-2744
Now, Apri128, 2010, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of
Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.
Affidavit of Service
Cumberland County; PA
Now, ~` ~ ~ , 20~, at 3~o' clock ~M, served the
within [~1ia a ~ ~h~~. ~ ~/- ~~'-
upon~.,l~~~~ ,G
at
by handing to
a ~u~ ~~~~/ _ copy of the original ~~~ • (;y ~~ /~"
l
and made known to~~~'S ,~ . /r/sClC~tl~/ °a~ the contents thereof.
COSTS
scribed re SERVICE
da 2~~ MILEAGE
~- 9 ~ AFFIDAVIT
~ ,
Richard D. McCarty, Notary Public
Chambersburg Boro, Franklin County
~__~ ;;-
,;
'_ AP~9302010
,.`
~~ ~
iL`,1 .
2~ (0 J ~~ f ~ ~;`'i ~: 3 f
,'_
i~~... RR ,~' ~{
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(71738-6929
MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION :CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
v. : NO.: 10-2744 Civil Term
JAMES E. NAUGLE and
KIlVIBERLY K. NAUGLE
DEFENDANTS :CIVIL ACTION-LAW
PRAECIPE
TO THE PROTHONOTARY:
Please enter judgment in the above captioned proceeding in favor of Members 1~
Federal Credit Union, Plaintiff, and against the Defendants, James E. Naugle and
Kimberly K. Naugle, in the amount of TWELVE THOUSAND FOUR HUNDRED
FORTY-FOUR AND 59/100 DOLLARS ($12,444.59) plus interest at the legal rate on
and after entry of judgment until the date of payment, additional attorney's fees and costs
of suit. Judgment is entered pursuant to Pa. R.C.P. 3031 for failure to file an Answer on
behalf of Defendants, James E. Naugle and Kimberly K. Naugle, to Plaintiff's Complaint
within twenty (20) days of service thereof and after a 10-day Notice was sent.
~14.Do PP >,~
~* ~aa
~,'~~l3R(ol
Date: June 16, 2010
~A ~
1 . Ledebohm, Esq
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
I hereby certify that notices of intent to take default judgment were forwazded to
James E. Naugle and Kimberly K. Naugle by United States Mail, first class, postage
prepaid on June 2, 2010. The aforesaid notices were contained within envelopes bearing
the return address of the undersigned. The notices have not been returned to the
undersigned as undeliverable or otherwise. A copy of the notice and Postal Forms 3817
are attached hereto and mazked Exhibit "A".
t
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 °' FEDERAL
CREDIT UNION
PLAINTIFF
Date: June 2, 2010
TO: James E. Naugle
Kimberly K. Naugle
15581 Paxton Run Road
Newburg, PA 17240
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 10-2744 Civil Term
.~
CIVIL ACTION-LAW
IMPORTANT NOTICE
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY
SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN
ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
v.
JAMES E. NAUGLE and
KIMBERLY K. NAUGLE
DEFENDANTS
Exhibit '~A~~
>f
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 PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Date: June 2, 2010
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Respectfully bmitted,
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earl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR pOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
d~
P ~
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,~
Received From' "' a
Karl M. Ledebohm, Esq.
P.O. Box 173 ~ ~ "~ °'
~Q~`: t
-New Cumberland, PA 17070-01 ~ o ~ ``
~ m
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One piece of ordinary mail addressed to: J
~
_
:
i;Cb~}~ °
'
ct-;~`
y O
OOJ07D
CNOR1~-+'0
z• o~oN
Kimberly K. Naugle r
mC.T'1
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15581 Paxton Run Road .
L ::~. '
~-~`'° m
D
{Newburg, PA 17240
PS Fc.,,,, ..... ..,,..~.~ ~,..,,
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(71738-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
v.
JAMES E. NAUGLE and
KIMBERLY K. NAUGLE
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 10-2744 Civil Term
CIVIL ACTION-LAW
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned hereby swears and affirms on behalf of Members 1 S` Federal
Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiff's
knowledge, James E. Naugle and Kimberly K. Naugle are not currently on active military
service.
Date: June 16, 2010
Karl I1~I. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
f
Karl M. I.edebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(71738-6929
MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION :CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
v. : NO.: 10-2744 Civil Term
JAMES E. NAUGLE and
KIlVIBERLY K. NAUGLE
DEFENDANTS :CIVIL ACTION-LAW
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM
REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMiTNICATION IS AN ATTEMPT' TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WII~L BE USED FOR THAT
PURPOSE
TO: James E. Naugle
15581 Paxton Run Road
Newburg, PA 17240
Kimberly K. Naugle
15581 Paxton Run Road
Newburg, PA 17240
You are hereby notified that on ~~p,, - g'~ , 2010 the following
judgment has been entered against you in the above captioned case:
Judgment in favor of Members 1St Federal Credit Union, Plaintiff, and against the
Defendants, James E. Naugle and Kimberly K. Naugle, in the amount of TWELVE
THOUSAND FOUR HUNDRED FORTY-FOUR AND 59/100 DOLLARS ($12,444.59)
plus interest at the legal rate on and after entry of judgment until the date of payment,
additional attorney's fees and costs of suit. Judgment is entered pursuant to Pa. R.C.P.
3031 for failure to file an Answer on behalf of Defendants, James E. Naugle and
Kimberly K. Naugle, to Plaintii~s Complaint within twenty (20) days of service thereof
and after a 10-day Notice was sent.
Dated: Prothonotary
is:
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236
James E. Naugle
15581 Paxton Run Road
Newville, PA 17240
Kimberly K. Naugle
15581 Paxton Run Road
Newville, PA 17240
A: James E. Naugle and Kimberly K. Naugle
Por este medio se le esta notificando que el de
2010 eUla siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso
mencionado en el epigrafe.
Fecha:
Protonotario
Certifico que la siguiente direction as la del defendido/a Begun indicada en el certificado
de residencia:
James E. Naugle
15581 Paxton Run Road
Newville, PA 17240
Date: June 16, 2010
Kimberly K. Naugle
15581 Paxton Run Road
Newville, PA 17240
1 M. L~debohm, Esquire
upreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
KARL M. LEDEBOHM
ATTORNEY-AT LAW
P.O. BOX 173
New Cumberland, PA 17070-0173
Phone: 717-93 8-6929
Fax: 717-932-0317
March 23, 2010
Office of the Prothonotary
Cumberland County Courthouse
One Courthouse Square
Cazlisle, PA 17013
Re: Members l8L v. James E. & Kimberly K. Naugle
No. 10-2744 Civil
Dear Prothonotary:
Enclosed aze an original and two (2) copies of a Praecipe for Judgment, an
original and one (1) copy of an affidavit ofnon-military service, an original and three (3)
copies of a Notice of Judgment, envelopes addressed to the defendants and a check in the
amount of $14.00 to cover the filing fee. Please file the original praecipe, forward the
Notices of Judgment to the defendants set forth in the notice via the addressed stamped
envelopes provided. Additionally, I have enclosed a check in f $16.00 for
an exemplified record so that I may transfer the j ent to Franklin County. Pleas
return the exemplified record and clock stem opies to my office via the enclosed
envelope.
Thank you for your assistance. Please contact me with any questions.
y o ,
i~
1 M. Ledebohm
KML:11
Enclosures
RECEIPT FOR PAYMENT
Cumberland Countyy Prothonotary's Office Receipt Date 6/18/2010
Carlisle, Pa 17013 Receipt Time 14:48:02
Receipt No. 243961
MEMBERS 1ST FEDERAL CREDIT U (VS) NAUGLE JAMES E ET AL
Case Number 2010-02744
Received of PD ATTY LEDEBOHM
D KB
Total Non-Cash..... +
Total Cash......... +
Change ............. -
Receipt total...... _
30.00 Check# 3722/3733
.00
.00
$30.00
------------------------ Distribution Of Payment ----------------------------
Transaction Description Payment Amount
JDMT/DEFAULT 14.00 CUMBERLAND CO GENERAL FUND
EX RECORD 16.00 CUMBERLAND CO GENERAL FUND
$30.00
r
OF THE R? NO SCE
NOTARY
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
LUIUDEC 28 4H10:24
CUMBERLAND
COUNT Y
PENNSYLVq A
MEMBERS 1 ST FEDERAL
CREDIT UNION
PLAINTIFF
V.
JAMES E. NAUGLE and
KIMBERLY K. NAUGLE
DEFENDANTS
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
NO.: 10-2744 Civil Term
CIVIL ACTION-LAW
PRAECEPE TO SATISFY JUDGMENT
To the Prothonotary:
Please mark the judgment entered in favor of Members 1st Federal Credit Union
in the above captioned matter satisfied for less than full payment.
Date: December 21, 2010
'Karl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
P a?
mow- s$. oat 4
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 1 ST FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
: PENNSYLVANIA
PLAINTIFF :
V. NO.: 10-2744 Civil Term
JAMES E. NAUGLE and
KIMBERLY K. NAUGLE :
DEFENDANTS CIVIL ACTION-LAW
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm, Esquire, hereby certify that on the 22nd day of December,
2010, I served a true and correct copy of the foregoing Praecipe to Satisfy Judgment
upon the following individuals by first class mail, postage prepaid, addressed as follows:
James Naugle
15581 Paxton Run Rd.
Newburg, PA 17240
Date: December 22, 2010
Kimberly Naugle
15581 Paxton Run Rd.
Newburg, PA 17240
Attorney for Plaintiff
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070.0173
(717)938-6929
Respectfully submitted,