HomeMy WebLinkAbout10-5952?LED-091CE
°^.^ ,.. TORY
.?0 16 A 8.32
PENI,+SYWANIA
Karl M. Udebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
ANNTOINETTE V. SAUNDERS a/k/a
ANNTOINETTE SAUNDERS
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
. NO. 10 -.SQ.S'd , Civ i lTerm
: 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
.oo fla A'I
ABOUT HIRING A LAWYER. #Qa
:11 .2 L-S 3 ffl
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 objections 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 a' FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
ANNTOINETTE V. SAUNDERS
a/k/a ANNTOINETTE SAUNDERS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
NO..
DEFENDANT
CIVIL ACTION-LAW
COMPLAINT
AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney, Karl M. Ledebohm 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. Defendant, Anntoinette V. Saunders a/k/a Anntoinette Saunders
("Defendant'), is an adult individual having a last known address of 14
Cardamon Drive, Mechanicsburg, PA 17050.
3. On or about March 16, 2005, Defendant submitted to Members 1St a credit
card application (the "Application") for a Visa credit card issued by Plaintiff.
A copy of the Application which has been redacted to remove personal
information of Defendant such as social security number, monthly income,
Defendant's mother's maiden name and phone numbers is attached hereto as
Exhibit "A" and made part hereof.
4. Plaintiff accepted the Application and sent to Defendant a Visa Credit Card,
account #****-****-****-0350 (the "Original Visa Account") and the
corresponding Visa Credit Card Agreement and Disclosure Statement.
5. On or about January 8, 2007, pursuant to Defendant's request, the Original
Visa Account was transferred to a Visa Gold/Visa Rate Shaver account
#****-****-****-0359 (the "Visa Gold Account"). A copy of the Request to
Transfer Visa Account dated January 8, 2007, signed by Defendant and
redacted to remove account number and mother's maiden name is attached
hereto as Exhibit "B" and made part hereof.
6. On or about November 19, 2007, pursuant to Defendant's request, the Visa
Gold Account was transferred to a Visa Gold/Visa Rate Shaver account
#****-****-****-7890 (the "2nd Visa Gold Account"). A copy of the Request
to Transfer Visa Account dated November 19, 2007, signed by Defendant and
redacted to remove account number and mother's maiden name is attached
2
hereto as Exhibit "C" and made part hereof. The Original Visa Account, the
Visa Gold Account and the 2nd Visa Gold Account are collectively referred to
herein as the "Visa Account."
7. 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 "D" and made part hereof.
Pursuant to the terms and conditions of the Credit Card Agreement and
Disclosure, Defendant agreed to pay to Plaintiff monthly installments in an
amount of not less than two percent (2.0%) of the outstanding balance on the
account or $20.00, whichever is greater.
9. Commencing on or about March 17, 2005, and continuing through December
8, 2009, Defendant made charges against the Visa Account.
10. Monthly statements regarding the Visa Account span approximately five (5)
years, are voluminous and contain potentially private information concerning
Defendant. For the above reasons, said statements are not attached to this
complaint and filed as a public record but will be made available to Defendant
upon request.
11. Defendant is in default of Defendant's obligations under the Credit Card
Agreement and Disclosure and the corresponding Visa Account as a result of
Defendant's failure to make the payments due to Plaintiff as set forth in the
Credit Card Agreement and Disclosure, the last payment having been received
by Members 1 S` on or about November 10, 2009.
3
12.
13
14.
By letter dated August 5, 2010, addressed to Defendant, Plaintiff demanded
the payment of all amounts due under the Credit Card Agreement and
Disclosure and the corresponding Visa Account. A copy of Plaintiff's
Demand is attached hereto as Exhibit "C" and made part hereof.
Defendant is currently indebted to Plaintiff in connection with the Visa
Account in the amount of TWENTY-SEVEN THOUSAND EIGHT
HUNDRED TWENTY-SIX AND 511100 ($27,826.51) DOLLARS itemized
as follows:
a. Principal $25,029.77
b. Unpaid Finance Charge 1,341.74
c. Unpaid other fees 255.00
d. Legal Fees 1,200.00*
Total due to Member 1St $27,826.51
*Legal fees for collection are estimated in accordance with the terms and
conditions set forth in the Credit Card Agreement and Disclosure. Defendant
will be responsible for payment of actual, reasonable legal fees incurred by
Members 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 1St.
Defendant also agreed under the terms and conditions of the Credit Card
Agreement and Disclosure that in the event of default there under Defendant
would pay, in addition to the amounts set forth in paragraph 13 above,
additional reasonable legal fees, if any, and costs incurred by Plaintiff as a
result of the institution and prosecution of these legal proceedings.
4
15. 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.
16. As set forth above, Plaintiff has made demand upon Defendant to make
payment of all amounts due to Plaintiff under the Visa Account and
corresponding Credit Card Agreement and Disclosure and, as of the date
hereof, Defendant has failed and refused to make payment of all such amounts
due to Plaintiff.
WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment
against Defendant, Anntoinette V. Saunders a/k/a Antoinette Saunders, in the
amount of TWENTY-SEVEN THOUSAND EIGHT HUNDRED TWENTY-SIX
AND 51/100 ($27,826.51) together with additional attorney's fees and costs of suit and
interest at the legal rate on and after the entry of judgment on this complaint which does
not exceed the jurisdictional amount requiring arbitration referral by local rule.
Respectfully
Date: lD /10
az M. Ledebohm, Esq.
Supreme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
VISA CRFniT CARD AP LI ATiON - --
O F FIGEVSE ONLY wsA ACCIa _._•Nwplo__
IMPORTANT. Read Iheao olrocliona belore completing lhls appilcallon.
it you are applying for do ind-LiUal account in your own name and a,U Ianymg on your Own rnCOme OI assets and not Ina iIICLme Jr . sseli
CI enonhel pUrs m as me Basis' lot repayment of the credit requested. Complele only the lop and I>0110m seC,on of ap 0l'Cal'u,
J yOV are app I Yln910r a 1-( 4--,I Dr an _.uni In., you and anDlne, person will U_ complete all SBClmns. plOalding InlO,rfla G Jn
Coca it aooul the joint applicant or user.
Awoo,ni, We Intend 10 apply lot joint credit. Applicant X _ Joint Applicant X
80, CJ II you are applying lot an individual account, but relying On income from alimony, child or separate maintenance or on the income or asse?5
of another person as the oasis lot repayment of the credit requested, complete all Sections to the extent possible, providing inlorrnal'on On II
abqul the person on which Ine alimony, support, or maintenance payments or income By assets you are relying.
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CREOIT LIMIT REQUESTED ?? INCREASE CRED.T LIMIT r0
U:;nrd Mra a Ywr wva tae caY.en•rrrca owdM.
DCnep, Iwrp rl you vnm .Lamar Vl W4nu Wmn pyoy.
PLEASE SIGN DAPPLICATION BEFORE RETURNING AND PROVIDE VERIFICATION OF INCOME.
APPLIC ANT55aDNAN?Y ??`?-' DATE
JOINT APPLaCANTS SIONATURE (IF AHY) X
DATE
Av TnORIZEO u9ER'9 SIGNATURE eF ANr(x
DATE
aFE +Yl+crEp DISCED$URE uIFORU AnOR-
QFFICE GSE . p TE Exhibit "A" -LE
2_\?l
M
RAL CREDIT UNION
REQUEST TO TRANSFER VISA ACCOUNT
Date: _-1--&___2-001
Primary Member Name: /17)n tOItg-61?7 V' 5?t 6045
Members tst VISA Account Number:
Please transfer my existing Members Isi VISA account.
FROM:
VISA Classic
Rebate eliminated on the date of uccO>unt
transfer,
`VISA Rate Shaver
VISA Gold
Rebate eliminated on the date of account
transfer.
VISA Platinum
Air miles eliminated on the date of acaiuni
tran?fer.
W n
To..
-0350 ?1,P4z- S?
VISA Rate Shaver
See VISA Cardholder Agreement fm terni? ,t J
conditions.
VISA Gold
See VISA Curdholder Agreement for terms , r _!
conditions.
VISA Platinum
See'VISA Cardholder Agreement Cor Icrmx ; iid
conditions.
I understand that my line of credit, uccount owners, number of cards, and terms will retrain th
,?ume its my existing VISA account.
fut1her agree that when I receive my/our new card(s), I will be instructed to call a to!]-free
number to activate the card. At the time of the activation call, any balance outstanding will be
transferred to my new account. Ifyou do not want this balance transferred, simply pay your
balance in full before you call the activation number. NOTE: By transferring your account, you
will immediately begin receiving the enhancements associated with the new product; howevc.,
on the date the account is transferred, your previous enhancements will be eliminated,
Ptease send my new VISA card(s) so that l muy begin to take advantage of the benefits of this
new card.
Mother's Maiden Name (VISA requirement)
Primary Member's Signature
MBRS7 36'9
',A;' 9; ,/ 15;99
Exhibit "B"
!1/18/2007 21:48 7177909525 DEVON3ANNTOINE7TE -u? ?-
nvi a9-CwI INn IV'cc tut rLtr=lW J5I v??R otrl• FRX NO, 7177955208 P, ():/'A
UqLAIDj?Tq WO ST
QUEST TO TRANSM V7$A ACCOUNT
ice: I F I q o?
Ptimary 1Ketnbcr NUw:
Memt)ecs 1 It VISA A== Number:_
Please trsadw my miyftZ Mtrmbert 161 VISA account.
MM
-VM Cute
Rebate elin3i rad on the date of aoaowut
trtSad=
..____VISA Rau Slamrur
V VISA GoW
Rcb= cumin= on ttu bate of aaoouat
w nder.
TO:
2VMRM6hffw
Sec YISA Crodit Cad mat sad
Disalaerue for terms and oandiwas.
____„VMA Cold
50o Y1SA Crtdtt Card Agroem=1=4
DiacLoscre for trans and condldc=
.._,_..VI" Pbd=M
Air asks obrniastad va? dw dM of 4==t
41mudar.
_VISA Plans=
See VISA Credit C*d Agree=ens and
Di.9405ure for rearm ewd ooudidoW,
I t r4wt ul thu ray Hue of reeft account owuem and bomber of taMda, wiD remain the same as rrry
mfg VISA woo=J &rthcr agm that id tho time the am=4 tr md r is p¢vicessod, aay baltttwo
CUt9 d3ag will be h MzfiTrad W ttty 11M account
Whm you Maive your now otrd(p), You will bo inorgc ad to c411 a toll-free muaber to atctiv4w dg card
140M. By trtttul=Wg y= awomU, you will W=odW* begin =caivin the araoad?
vAlb the mw product; hownvm cn the date the acwwr 1e tamed, your previous ernbmwammts wo
be ekraod,
F'locao scud my now VISA card(s) so that I may begin to talot advemrage Ul the bane m of tb is now card.
By your aide Wow you agm tv be bound by the MotzA=1 st VISA C odit Card Amt end
Dis 4oanra tar ft VISA prods to wtricb you an nnndMring y= account
c he's MAW= Nano (VISA requirement)
Primary Mcmbcr'e Siguanuo
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?t3wtLl1 41$. y
aW "I
Exhibit "C"
VISA Credit Card Agreement and Disclosure .
Notice. See reverse side for important information regarding your rights to dispute billing errors.
1. Meaning of Words. The following words have the following meanings in this Agreement and in the monthly billing statement sent hereunder.
(a) "Agreement' means the Visa Credit Card Agreement and Disclosure furnished by us.
(b) "we". 'us' and "our" means Members 1st Federal Credit Union, Mechanicsburg, PA.
(c) 'you' and "your" means each person who signs the application for the Account.
(d) "Card" means any Visa Credit Card and any duplicates and renewals we issue to you or to an authorized user of your Account.
(e) "Amount" means your Visa Credit Card Account with us.
(f) "Line of Credit" means the self-replenishing line of credit we make available to your Account.
(g) "Advance" means any credit extended on your Account for any purchases or Cash Advances.
(h) 'Cash Advance' means (i) any cash or credit extended on your Account by us or by any other institution that accepts a Card, (ii) any withdrawal of cash made by using a Card and personal identification number ("PIN") at an autcmabd to lee machine ("ATM )
or other type of electronic terminal that provides access to the Visa system, (iii) the amount of any Visa Convenience Check paid by us, or (iv) the amount of any balances transferred to your Account from another credit call! or account.
(i) "Visa Convenience Check" means any check 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. How To Use This Account. 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 receipt for the amount of the purchase or i;y g vine a Card Account nonber.
Your Account may also be used to obtain Cash Advances
(a) By receiving cash or credit from financial institutions that accept a VISA Credit Card:
(b) By use of Visa Convenience Checks,
(c) By making cash withdrawals wim a Card at an ATM or other type of electronic terminal that provides access to the Visa system, or
(d) By transferring to your Account a balance from another credit card or account
3. Responsibility. you agree to pav all Advances, finance charges and other fees a charges charged to your Account arising from the use of a Card, a Visa Convenience Check or the Account by you or anyone you authorize cc ; ern t to ise yeu Account. a Visa
Convenience Check or a Card. even It you do not notify us that other, are using your Account, a Visa Convenience Check Of a Card. Your responsibility for cnarges made by anyone you authorize or permit to use you Account. a'. isa ConremE nee Check or a Carl
continues until you notify us in writing at 5000 Louise Drive, P 0. Box 40, Mechancstfor g, PA 17055. and recover and destroy any Visa Convenience Check or Card in such person's possession Your obligation to pay the Amoort balan(e coatinjes regardless of
the terms of any agreement, divorce decree, or other could judgment to whicn we are not a party. If more than one person signs the application for the Accounl, you are each jointly and severally responsible for all cnarges or the Acc )unl
4. Liability for Unauthorized Use. You understand that your total liability to us shall not exceed Fifty Dollars ($50) resulting from the loss, theft or other unauthorized use of a Card that occurs prior to the time you give notice 10 cs. ,ucr limiall( n does not apply
when a Visa Convenience Check is used.
5. Lost Card Notification. 11 you believe a Card or any Visa Convenience Check has been lost or stolen you must immediately call us at (717) 795-6032 or 1(800)-283-2328 during normal business hours Alter business Yours hml.hfs ind weekends) or or no -
days, lost or stolen Cards or VISA Convenience Checks must be reported by calling 1(800)-325-3678.
6. Credit Line. If we approve your applicalton, we will establish a Line of Credit for you and notify you of its amount when we issue a Card. This amount is your credit limit lot the Account- You agree not to let the Account balance exceed his approved credit hmi?
Each payment you make on the Account will restore your credit limit cry the amount of the payment that is applied to the principal balance owed on the Account You may request an increase in your credit limil. which must or, app' owed by us We may reduce your
credit limit or lerminate this Agreement lot any reasons not prohibited by applicable law, with only such notice as is required by applicable law. You may also terminate this Agreement at any time but termina,ion by either A m does nc1 0Cl four obligation
pay the Account balance To terminate this Agreement. you must nolify us in writing at 5000 Louise Drive, P 0 Box 40, Mechanicsburg, PA 17055, and recover and surrender to us all Cards, and any issued but unused Visa Con em tnce Che.:ks They remain oE.i
property
7. Credit Information. You authorize us to investigate your credit standing when opening renewing or reviewing your Account and you authorise us to disclose information regarding your Account to credil bureaus and other crec for wh indairr of us aooul your
credit standing.
B. Payments. We will mail you a trilling statement every month showing your Previous Balance comprised of purchases and Cash Advances, the current transactions on your Account, your credit limit the avatlable credit the Nev, Ba ancr the Finance Charges for
the billing cycle, and the Minimum Payment required. Each month you must pay at least the Minimum Payment shown on your statement by the Payment Due Date shown on the statement or no later than 2F days from Ihn stalemrm C osir g late, wnichever is
later If your statement says your payment is "Now Doe," your payment is due no later than 25 days from the statement Closing Date- You may pay more frequently, pay more than the Minimum Payment or p2, the New Aal:mre n h u 1 yo, make extra or argf
payments, you are still required to make at least the Minimum Payment each monni 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 the Minimum Payment shown on prior statement(s) which remains unpaid, or b) ymr New B3Iar e, i it c less Iran Twenty Dollars
($20).
We also have the right to demand immediate payment of any amount by which your New Balance is over your credit limit.
We will apply your payments first to any fees, then to Finance Charges on both Cash Advances and purchases, then to previously billed Cash Advances, then to previously billed purchases, then to new Cash Advances and then a new purchases
We may accept checks marked "payment in full" or with words of similar effect without losing any of our rights to collect the full balance of your Account.
9. Finance Charge.
A. The current monthly Periodic Rate and corresponding Annual Percentage Rate are set forth on the "Additional Disclosure" which is sent to you together with this Agreement.
0. Variable Rate: The Annual Percentage Rate will be determined by adding the margin to the index value. The Annual Percentage Rate can change on the list calendar day of the first billing cycle in each calendar qualde Tie margin lot Visa Platinum s
5.00% for both purchases and Cash Advances. The margin for Visa Gold is 5.00% for both purchases and Cash Advances. The margin for Visa Classic is 5.50% for both purchases and Cash Advances. The margin for Visa Classic Rate Shaver is 2.00% for
both purchases and Cash Advances, subject to a minimum Annual Percentage Rate of 9.9% for the Visa Classic Rate Shaver program. The index is the highest Prime Rate published in the money rates section of the V/all Seen I Journal. The index wit
be measured as of the last business day of the immediately preceding calendar quarter. Any increase in the Annual Percentage Rate may cause the amount of the minimum monthly payment to increase. Alsc, you may have to pay mor paSme ts. The Annual
Percentage Rate will never exceed 21% or the maximum allowed by law, whichever is less. The monthly Periodic Rate is equal to one-twel0h (1/12) of the Annual Percentage Rate.
C. Method A • Average Daily Balance (Including New Cash Advances): A Finance Charge will be imposed odCash Advances from the date made or from the first day of the billing cycle in which the Cash Advance is I oshd to you Account, whichever
is later, and will continue to accrue until the date of payment.
The Finance Charge on Cash Advances for a billing cycle is computed by applying the monthly Periodic Rate to the average daily balance of Cash Advances, which is determined by dividing the sum of the daily balances curing the billing cycle by the
number of days in the cycle. Each daily balance is determined by taking the beginning balance of Cash Advances on your Account each day, adding any new Cash Advances, and subtracting any payments or credits that ire appl ad to Cash Advances but
excluding any unpaid Finance Charges.
D. Method G - Average Daily Balance (including New Credit Purchases): A Finance Charge will be imposed on purchases only if you elect not to pay the entire New Balance shown on your motility billing slatemer I for the precious billing cycle on
or before the Payment Due Date of that statement. If you elect not to pay the entire New Balance shown on your previous monthly billing statement by the Payment Due Date, a Finance Charge will be imposed on the unpaid avenge daily balance of purchases
from the previous statement Closing Date and on new purchases from the date of posting to your Account during the current billing cycle, and will continue to accrue until the Closing Date of the billing cycle preceding the date on which the entire Nev
Balance is paid in full or until the date of payment if later than the Payment Due Date.
The Finance Charge on purchases for a billing cycle is computed by applying the monthly Periodic Rate to the average daily balance of purchases, which is determined by dividing the sum of the daily ba ances during me b lung cycle ov the lumber of days
in the cycle. Each daily balance is determined by taking the beginning balance of purchases on your Account each day, adding any new purchases, and subtracting any payments or credits that are app red to purchases, mt pxGrdinc an/ unpaid Finance
Charges
10. Default. You will be in default it you fail to make any minimum payment or other required payment by the dale that it is due. You wil be in default if you break any promise you make under this Agreement. You will be in defau t if rout tie, the tar bankruptcy, or
become insolvent, that is, unable to pay your obligations when they become due. You will be in default if you make any false or misleading statements in any credit application or update of credit information. You will also be in defaut it [ omelffmg happens which
we believe may substantially reduce your ability to repay what you owe When you are in default we can demand immediate payment of the entire amount you owe under this Agreement without giving you advance notice. If Im ediater p tyrni is demanded, you
will continue to Day interest, at the applicable interest rates in effect under this Agreement, until what you owe has been repaid. If demand for immediate payment has been made, the shares and deposits given as security for pay nii under if is Agreement can be
applied towards what you owe We can also take appropriate action as authorized under the Uniform Commercial Code to repossess any and all collateral pledged to secure repayment under this Agreement. To the extent permiftid by ap llica)Ie aw, you will also
be required to pay our collection expenses, including could costs and reasonable afforneys' fees We can also exercise any other rights given to us by law when you are in default
11. Using the Card. You may use a Caro Card Account number and/or PIN to make transactions on your Account You will retain the copies of the transaction receipts furnished to you in order to verify your nonthly billing statemef i You agree that you will not
use or permit anyone to use a Card or your Account for any transaction that is illegal under applicable federal, stale or local law You agree that illegal use of any financial service will be deemed an action of default and/e' breach tf ccntrart aid such a service
and/or other related services may be terminated at our discretion You further agree, should illegal use occur, to waive any right to sue us for such illegal use or any activity directly or indirectly related to it. AoJiFonafly, yoe agree to ini Fr iy and hold us harm-
less from any suits or other legal action or liability, directly or i d rectly, resulting Isom such illegal use We reserve the right to decline any iransachons that we consider fraudulent, suspicious, or illegal and yoc tuldh=r understand Iha we .viu rol <nowingly a tlhc-
nze charges related to o ilme gambling
Print Date 3/05 CONTINUED ON REIERSE
Exhibit "D"
12. Returns and Adjustments. Merchants and others who honor a Card may give stedil 0r returns or adjustments, and they will do so by sending us a credit transaction receipt , which we will past to your Ac ount if your credts no ayrnene exceed what y :u
owe us, we will hold and apply this credit balance toward future purchases and Cash Advances, or it it is one dollar or more, refund it on your written request or automatically after six months.
13. Using Visa Convenience Checks. You may use your Visa Convenience Checks, if available, as you would use a Card to make a purchase or payment or to receive cash. Your Visa Convenience Checks directly access yc it hcco nt 411 Lisa Conver fence
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 Advance; and to the following additional terms
A No Visa Convenience Check may be used to make a payment on your Account.
B Only the person whose name appears on a Visa Convenience Check may use them
C. Visa Convenience Checks must be written in U.S Dollars. Visa Convenience Checks may not be certified.
D We may return a Visa Convenience Check unpaid if there is not enough available credit on your Account to pay it, it your Account is in default, or it a Card or ant Visa Convenience Checks have been repo ted lost or stnlen A 9101-e wrl be charged for each
returned Visa Convenience Check
14. Foreign Transactions. Purchases and Cash Advances made in foreign countries and foreign currencies will be billed in U S Dollars Effective April 2, 2005, the exchange rate for transaclions in a loreign currency will re 2 fair selected by Visa from cre
range of rates available in wholesale currency markets for the applicable central processing date. which rate may vary from the rare Visa itself receives. or fine government mandated rate in effect for the appiicat le central pro:ess, g Cale. ncrrasel by o9e-percept
On foreign transactions you agree to pay all currency exchange charges.
15. Merchant Disputes. We are not responsible for the refusal of any merchant or I nanclal institution to honor a Card or Visa Convemence Check
16. Security Interest. To secure your Account, you grant us a purchase money security interest under the Uniform Commercial Code in any goods you purchase using the Account- II you default, we will nave Pre ngnt to rec fiver my )I it=se roots which have not
heen nand tnr thrnunh nor anphration of vnur navmenls :n the manner detrrilwd in paragraph R
PtsdN4 oliharoAoeoenf(a) •.Np To sseuro your:Aaeoanty ._pgo with Members 1stFederol Crsdit.Anios now and in thefuture,
olrcepttNlrpJ4iodhilduatAsUreuuratAccouAtCandaaaouafs 11 t Is oferredatadra Yrouauthbriveyrstdappiythefialaneeln-those
pr:cosat(s)its pay any temoursts doe tinder this 'Agreeneid it yuL sboufd dsfault:
Fees and Other Charges. The lollowino fees and other charges will be added to Your Accounl, as applicable
A. Annual Fee
Visa Platinum .............. None
Visa Gold. .. None
Visa Classic ................ None
Visa Classic Rate Shaver...... None
B. Late Payment Charges. If you fail to pay the minimum payment on your Account within five (5) days of the Payment Due Date, a late payment charge of $30 will be added to your Account.
C. Over-Limit Charge. If your Account balance exceeds your credit limit at any time during the statement period, an over-limit charge of $15 will be added to your Account,
0. Returned Check Fee. II a check or share draft used to make a payment on your Account is returned unpaid because of insufficient funds or for any other reason, you will be charged a fee of $10 for each item felon led.
E. Returned Statement Fee. You will be charged $1 for each monthly billing statement that is returned.
j
F. Copies of Visa Transaction Receipts and Statements. You will be charged $3 lot each copy you request of a receipt lot any purchase, credit or Cash Advance or of a monthly billing statement (except in connection w th lire resolu'ion of a filling giro,
18, Skip Payment Option. We may allow you, from time to time, to omit a monthly payment. We will notify you as to any month in which the option is available- It you omil a payment, Finance Charges will accrue on your balance it ai cor( ancf wt'h this Agreement
A skip payment does not extend the period within which you must pay the New Balance in order to completely avoid Finance Charges on purchases. A minimum payment will be due in the month following the month in which you kip row paymenl
1g. Effective Agreement. This Agreement is a contract which applies to all transactions on your Account, even though the receipts you sign or receive for purchases credits, Cash Advances or other transacticns may contain d Neu r l arms Wa may amero th s
Agreement Irom time to time oy sending you written notice It required by applicable law, we will give you written notice before the effective dale of the amendment To the extent applicable law permits, and as we indicate in car f olio to foe amendmems will
apply to your existing Account balance as well as to future transactions This Agreement shall be construed in accordance with the applicable laws of the Commonwealth of Pennsylvania and applicable federal laws
YOUR BILLING RIGHTS - KEEP THIS FOR YOUR RECORDS
This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act.
NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR MONTHLY BILLING STATEMENT.
If you think your monthly billing statement is wrong, or if you need more information about a transaction on your statement, write us on a separate sheet of paper at the address listed on your statement, Write to us as soon as possible. 4)e mast fear from you no laic
than 60 days after we send you the first statement on which the error or problem appeared. You an telephone us, but doing so will not preserve your rights.
In your letter give us the following information
• Your name and Account number
• The dollar amount of the suspected error.
Describe the error and explain, it you an, why you believe there is an error It you need more information, describe the item yOC are not sure about
If you have authorized us to pay your monthly billing statement automatically from your Savings or Checking Account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us three (3) oust ess days before the auto-
matic payment is scheduled to occur
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE.
We must acknowledge your lever wnma 30 days, unless we have corrected the eeor by then Within 90 days, we must either correct the error or explain why we behove the statement was correct.
After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to send statements to you lot me amount you question. Including finance charges, and we can apply any anpa d ar r0, t agems your credit imit
You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your statement that are nor in question.
II we find that we made a mistake on your statement, you will not have to pay any finance charges related to any questioned amount- II we didn't make a mistake, you may have to pay finance charges, and you will have to make up r ny nlss:d payments ou the quo s-
hoped amount. In either case, we will send you a statement of the amount you owe and the date that it is due.
II you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within ten days telling us that you still refuse 10 pay we must tell anyone we 2pcrl yon to 'hat you have a ques-
tion about your statement. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is.
If we don't follow these rules, we cant collect the first $50 of the questioned amount, even if your statement was correct.
SPECIAL RULE FOR CREDIT CARD PURCHASES.
II you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amour due on he g of ry or services There
are two limitations on this right. (a) you must have made the purchase in your home stale or, it not within your home state, within 100 miles of your curreni'mailing address, and (b) the purchase price must have been more than $50
These limitations do not apply it we own or operate the merchant, or if 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
Of Counsel Richard P. Mislitsky, Esq.*
Fax: 717-932-0317
August 5, 2010
(Via Certified and regular mail)
Anntoinette V. Saunders
14 Cardamon Drive
Mechanicsburg, PA 17050
RE: Members 0 Visa Account No.: 4672-0900-0016-7890
Dear Ms, Saunders:
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 LAST
PAGE OF THIS LETTER.
Members I" Federal Credit Union ("Members 1St") has requested my office to
collect the amounts due to Member's Pt under the above account.
As you know, you are in default of your obligations under the above Members l 5t
Visa Account (the "Account") due to your failure to make the payments required tinder
the Account in a timely manner. The last payment on the Account was received by
Members 1" on or about November 10, 2009. As a result of your defaults, Members 1"
hereby accelerates all amounts due to Members 1St under the Account and hereby
demands the payment of all amounts due to Members 1St under the Account in the
amount of $26,794.51 itemized as follows:
1. Principal $25,029.77
2. Unpaid Finance Charge 1,341.74
3. Unpaid other fees 255.00
4. Legal Fees 168.00
5. Total due to Member 1St as of 8/3/10 $26,794.51
If you fail to deliver to my office at the address set forth above payment of the
$26,794.51 within thirty (30) days of the date of this letter, Members V' will have no
*Also practices independently as RichaExhibit «E"
choice but to file a legal action against you to collect all of the amounts due under the
Account without further notice. In such event, in addition to the above amounts, } ou coati
also be responsible for the payment of additional reasonable legal fees and costs or suit
incurred by Members I".
Nothing herein shall constitute or be construed as an agreement on behalf of
Members 1S` to accept any terms and conditions in exchange for payment of the amounts
due under the Account except for the immediate payment of all amounts due to Members
1 ` . Nothing herein shall constitute a waiver of any rights or remedies which Members
1'` may have under any written agreement or at law or in equity to collect the balance of
the indebtedness due under the Account without further notice, including, without
limitation, the right to accept and apply any partial payments made on the Account
without waiver of any demand for payment in full of all amounts due under the Account.
Nothing herein shall constitute an agreement on behalf of Members 1 S` to postpone or
extend the maturity date of the obligation.
Members 1" looks forward to the payment of the $26,794.51 on or before
September 4, 2010.
Very truly/yours
/ i
M. Ledebohm
.i ,
CC: David Thomas, Collections Officer
KM L:11
NOTICE
This letter is an attempt to collect a debt
It you dispute the validity of this debt, or any portion , and you ify
undersigned debt collector in writing within thirty (0) days of theoreceipt of thistnoticle
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 bent
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
our receipt of this notice.
The "undersigned debt collector" means the nam
i
appearing in print at the ' c this letter e s
gned at the end of thi s letter
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`L996 9929 2000 OSTO 9002
MEMBERS 1 IT FEDERAL
CREDIT UNION'
PLAINTIFF
Vs.
ANNTOINETTE V. SAUNDERS
Wa ANNTOINETTE SAUNDERS
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
NO..
CIVIL ACTION-LAW
VERMCATYON
1, David Thomas, Lead Collector for Members 1" Federal Credit Union, being
authorised to do so on behalf of Members 1 st Federal Credit Union, hereby verify that the
statements made m the foregoing pleading are true and correct to the best of my
information knowledge and belief. I understand that false statements are made subject to
the penalties of 18 Pa. C.S.A. Section 4944, relating to unworn falsification to
authorities.
Members I" Federal Credit Union
ByD
David Thomas, Lead Collector
6
L0/L0 39bd WHO93Q31INVA LTE0ZE6LTL LZ:LT 0TOZ/L0/60
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
~~~~,tr ct ~a~brr~,ryA
Jody S Smith
Chief Deputy ~ ~ ~~
.~, , ~, w
Richard W Stewart °'`-' '°
Solicitor ~s~l~,e cF '-~~ s~~~a(~~
Members 1st FCU
vs.
Anntoinette V. Saunders
Case Number
2010-5952
SHERIFF'S RETURN OF SERVICE
09/23/2010 09:15 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on
September 23, 2010 at 2115 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Anntoinette V. Saunders, by making known unto herself personally, at 14
Cardamon Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.44
September 27, 2010
TIM C ,DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
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(cl GountvSuite Shenff. Teieosoft. Inc.
r
Tracy L. Up ike, Esquire
PA Supreme Court ID # 88680
CUNNING AM & CHERNICOFF, P.C.
2320 North'. econd Street
P.O. Box 6 457
Harrisburg,', A 17106-0457
(7171238-6 70
IN THE
vs.
t~iQ CCU 2~ P~'! 3~ ~~
~E~t~SY~ V,~~I~~A
URT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
1ST FEDERAL CREDIT UNION,
Plaintiff,
CIVIL ACTION -LAW
No. 10=-
~l~~
?TTE V. SAUNDERS a/k/a
~TTE SAUNDERS,
Defendant
NOTICE OF STAY
NC
has filed a
10-08412
United Sta
notice onl:
case.
I'ICE IS HEREBY GIVEN that Anntoinette V. Saunders, above-named Defendant,
'etition under Chapter 7 of the United States Bankruptcy Code to Case No. 1-
nd as a result thereof, the above-captioned action is stayed until further Order of the
es Bankruptcy Court. The undersigned executes this Notice for purposes of giving
and the providing of this Notice is not intended to enter an appearance in the within
Respectfully submitted,
Date:
CUNNINGHAM & CHERNICOFF, P.C.
B
18, 2010 y
T a L. dike, squire
I.D. #8868
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
i
Tracy L. Up ike, Esquire
PA Supreme Court ID # 88680
CUNNING AM & CHERNICOFF, P.C.
2320 North econd Street
P.O. Box 6 457
Harrisburg,' A 17106-0457
(717) 238-f 70
IN THE OURT OF COMMON PLEAS OF CUMBERLAN COUNTY, PENNSYLVANIA
EMBER 1ST FEDERAL CREDIT UNION, CIVIL ACTION -LAW
Plaintiff, No. 10-5952
V. SAUNDERS a/k/a
SAUNDERS,
Defendant
CERTIFICATE OF SERVICE
I, Jahn Jones, do hereby certify that a true and correct copy of the NOTICE OF STAY
was sent byj first class mail, postage prepaid on this day to the following:
Karl M. Le
P.O. Box 1
New Cum
~, Esquire
PA 17070
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: October 18, 2010
wpd
B:
J Jones, P legal
2
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
._L. L.
THE PROTHONOTAi
2014 SEP 1 2 PM 12: 07
CUMBERLAND COUNTY
PENNSYLVANIA
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
v. : NO.: 10-5952 Civil Term
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
ANNTOINETTE V. SAUNDERS a/k/a
ANNTOINETTE SAUNDERS •
DEFENDANT : CIVIL ACTION -LAW
PRAECIPE TO SETTLE, DISCONTINUE AND END
To the Prothonotary:
Please mark the docket in the above captioned case settled, discontinued
and ended.
Date: September 8, 2014
Ily s
arl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff