HomeMy WebLinkAbout10-7656F~t~l^!1-Qr~~f.r
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ROBERT D. KODAK, ESQUIRE
KODAK & IMBLUM, P.C.
407 N FRONT STREET, PO BOX 11848
HARRISBURG, PA 17108-1848
(717) 238-7159 Attorney for Plaintiff
CORNERSTONE FEDERAL CREDIT IN THE COURT OF COMMON PLEAS OF
UNION, :CUMBERLAND COUNTY,
Plaintiff :PENNSYLVANIA
v
GEORGE P. MCNAUGHTON,
Defendant(s)
No. ~D-~1~S~O
CIVIL ACTION -LAW
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 an
attorney and filing in writing with the court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the case may proceed without
you and a judgment may be entered against you by the court without further notice for any
money claimed in the complaint or for any other claim 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.
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
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
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LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion
dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y
Aviso radicando personalmente o por medio de un abogado una comparencencia escrita
y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion
como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier
suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio
solicitado por el demandante puede ser dictado en contra suya por la Carte sin mas aviso
adicional. Usted puede perder dinero o propiedad u otros derechos importantes Para
usted.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A
PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
CORNERSTONE FEDERAL CREDIT
UNION,
Plaintiff
v
GEORGE P. MCNAUGHTON,
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
COMPLAINT
The Plaintiff, CORNERSTONE FEDERAL CREDIT UNION, by its attorneys,
KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant(s) to
recover the sum of TWELVE THOUSAND FIVE HUNDRED TWENTY NINE DOLLARS
AND THIRTY-THREE CENTS ($12,529.33), along with interestthereon atthe rate of 8.5%
from July 29, 2007, upon a cause of action of which the following is a statement:
1. The Plaintiff, CORNERSTONE FEDERAL CREDIT UNION, is a corporation
organized and existing under the laws of the State of Pennsylvania, having its
principal office and place of business at P.O. Box 1181, Carlisle, Pennsylvania
17013-1811.
2. The Defendant, GEORGE P. MCNAUGHTON, is an adult individual residing at
925 CENTER ROAD, NEVWILLE, CUMBERLAND COUNTY, PENNSYLVANIA
17241.
F:\USER\TONYA\COMMON PLEAS CMPS\COMPLAINTS\CORNERSTONE FCU\CORNERSTONE.36666. three count.wpd 2
3. On or about September 5, 2003 Defendant submitted a Loanliner Application to
Plaintiff, which credit was granted to Defendant, a true and correct copy of which is
attached hereto, marked Exhibit "A" and made a part hereof.
Count I -Cornerstone Federal Credit Union vs.
George P. McNaughton
4. Paragraphs 1 and 3 are incorporated herein above the same as if fully set forth at
length herein.
5. On or about May 27, 2004 Defendant submitted a Visa Application to the Plaintiff
and a Visa account was issued to Defendant.
6. Defendant has defaulted under the terms of the Agreement by failing to make
monthly payments when due and owing.
7. The balance due and owing by Defendant to Plaintiff in the sum of FOUR
THOUSAND FIVE HUNDRED SIX DOLLARS AND NINETY CENTS ($4,506.90)as
appears by Plaintiff's Statement ofAccount hereto attached hereto, marked Exhibit
"B" and made a part hereof.
F:\USER\TONYA\COMMON PLEAS CMPS\COMPLAINTS\CORNERSTONE FCU\CORNERSTONE.36666. three count.wpd 3
8. Plaintiff has frequently demanded payment from Defendant of said amount due and
owing as aforesaid, but Defendant has refused and neglected and still refuses and
neglects to pay said amount of any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of FOUR
THOUSAND FIVE HUNDRED SIX DOLLARS AND NINETY CENTS ($4,506.90), along
with interest thereon from January 19, 2007.
Count II -Cornerstone Federal Credit Union vs.
George P. McNaughton
9. Plaintiff incorporates Paragraphs 1 through 8 above the same as if fully set forth at
length herein.
10. On or about July 15, 2004 Defendant under his previously approved Loanliner with
Plaintiff, was approved for a Car Loan. A true and correct copy of the Open-End
Disbursement Receipts Plus of which is attached hereto, collectively marked
Exhibit "C" and made a part hereof.
11. Defendant has defaulted under the terms of the Agreement by failing to make
monthly payments when due and owing.
F:\USER\TONYA\COMMON PLEAS CMPS\COMPLAINTS\CORNERSTONE FCU\CORNERSTONE.36666. three count.wpd q
12. The Defendant(s) outstanding balance due and owing of FIVE THOUSAND SIX
HUNDRED FOUR DOLLARS AND SIX CENTS ($5,604.06) as shown on Plaintiff's
Statement of Account, a true and correct copy of which is attached hereto, marked
Exhibit "D" and made a part hereof.
13. Plaintiff frequently demanded payment from Defendant of said amount due and
owing as aforesaid, but Defendant refused and neglected and still refuse(s) and
neglect(s) to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of FIVE
THOUSAND SIX HUNDRED FOUR DOLLARS AND SIX CENTS ($5,604.06) along with
interest thereon from July 29, 2007.
Count III -Cornerstone Federal Credit Union vs.
George P. McNaughton
14. Plaintiff incorporates Paragraphs 1 through 13 above the same as if fully set forth
at length herein.
15. On or about May 19, 2005, Defendant under his previously approved Loanliner with
Plaintiff, was approved for a Loan. A true and correct copy of the Open-End
Disbursement Receipts Plus of which is attached hereto, collectively marked
Exhibit "E" and made a part hereof.
F:\USER\TONYA\COMMON PLEAS CMPS\COMPLAINTS\CORNERSTONE FCU\CORNERSTONE.36666. three count.wpd g
16. Defendant has defaulted under the terms of the Agreement by failing to make
monthly payments when due and owing.
17. The Defendant(s) outstanding balance due and owing of TWO THOUSAND FOUR
HUNDRED EIGHTEEN DOLLARS AND THIRTY-SEVEN CENTS (2,418.37) as
shown on Plaintiff's Statement of Account, a true and correct copy of which is
attached hereto, marked Exhibit "F" and made a part hereof.
18. Plaintiff frequently demanded payment from Defendant of said amount due and
owing as aforesaid, but Defendant refused and neglected and still refuse(s) and
neglect(s) to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum:
A. Count I: the sum of FOUR THOUSAND FIVE HUNDRED SIX DOLLARS AND
NINETY CENTS ($4,506.90),
B. Count II: the sum of FIVE THOUSAND SIX HUNDRED FOUR DOLLARS AND SIX
CENTS ($5,604.06),
C. Count III: the sum of TWO THOUSAND FOUR HUNDRED EIGHTEEN DOLLARS
AND THIRTY-SEVEN CENTS (2,418.37)
F:\USER\TONYA\COMMON PLEAS CMPS\COMPLAINTS\CORNERSTONE FCU\CORNERSTONE.36666. three count.wpd 6
For a total amount due and owing by Defendant to Plaintiff of TWELVE THOUSAND FIVE
HUNDRED TWENTY NINE DOLLARS AND THIRTY-THREE CENTS ($12,529.33), plus
interest as set forth herein.
Respectfully submitted,
KODAK 8~ IMB~.UM, P.C.
Robert D/Kddak, Esquire ID# 18041
407 N h Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7159
Attorney for Plaintiff
F:\USER\TONYA\COMMON PLEAS CMPS\COMPLAINTS\CORNERSTONE FCU\CORNERSTONE.36666. three count.w~d
9- 5-03;`9:04AM;Advert lsl ne
t NAME (Pkeee Prlnq ACCOUNT NUI~Eti
.or_r_ Q t~Ct~~tiG L1TAt~t ~rtt".~i
INscbsures, wgl be referred to as "Ihe Plan.' The Ph+n documents include this agroement and
an Addendum. "Yau', '~rou1' and "borrower" mearl any per~n who signs the Plan. "Credtt
union", "we", "our" and us" mean the Credit Union whose reams appears on the Plan or anyone
to whom the Credn Udon transfers its rlgMs under the Plan. This is a molt[-state document
wddl may be used to lend to borrowers in all states except Louisiana.
1. HOW THIS PLAH WORKS -This fs anopen-eM,multi-featured credit plan. We arrtiapate
that, from time h thee, you will borrow money (aNad "advances") under the Plan. Wa are eat
rsquYed a na(u advsnns h you order me Pisa sad aces radices a request for as adrasoa
at thw. The Addendum describes the dtfterent types of credtt (quad "sut-axourus")
available under the Plan, the current Interest rate for each subaccetmt expressed as a defy
periodic rate and correaporlntng annual percentage rate and other charges. It may also have
other terms snd a sdledule for dehmdning the payment amounts.
•L CREDIT LIMIT - Wo may, but do not have to, establish a credd Ifmit on certain
subaccourus. If a eredtt limtt is set for a subaeeount, you promise not to exceed the establisMd
credit limit ff you exceed the credit (unit, you promise to rePsY Immediately the amount wh~h
etaaeds ftls crodtt limit.
3. REPAYMENT -You promise to repay all amoulh you owe under the Plan phis int~st.
Payments are due on the last day of the month unless ova set a diderent day at the dnle of an
advance. d the Addendum has no payment schedule for a sObaxOUnt, your payment wdl be
dNerrrlllrod at the limo of each advance. Paymanh must include arty amount past due and arty
amount by whkh you have exceeded any crsdn dmit yyo~u have boon givSl for a subaxount You
may repay aN a part of what you owe at any dme wahad ary Prepayment Dsnalh~ even d you
prepay, you wIN afMl.be required to make the rogulary ~hedufed payments antes we agree In
writing b s change m the payment schedule. If you have a Joint sharedraft account,you wit be
responslllk for paying .all overdraft advances obtahled by a joint holder of the struedreft
1. You have reawived and read the LOANLINEfi' Credit roof Security Aqg~roetnettt
indudinp the AddefKlum ("Agreement') and a Credit Insurance Certificate. By
signing below you agree to be bound by the terms of the Agreement.
2. Yon Jiraot tIe a security inten5t is ati Individual and joitd share and/or
deposit aatamata yyaouu~~have with ue sow end to flee futon to sown what yet owe
Hader the LOMM.lN~ Credit and 8fultrily AlyrssmeM. Whoa Yoe aro in de(arR,
DATE
•:.~, a
CUNA Mutual Insurance Society • Madison, WI 53701-0391 • Phone: 800/937-2644
"You" or "Your" means the member and the joint insured (if applicable).
Credit insurance la valeatary and not required in order to obbia your loan. You m
select any insurer of your cho(ce. You have established an open-end Loan Plan wi~
the Credit Union. Your Loan Plan may consist of one or more Loans. You are applying
to the Society for credit insurance. You authorize the charges for insurance to be
added to your Loan Balance each month and understand that interest will accrue on
DATE
5=03
NOTE: The insurance you're applying for contains certain terms and saclusions; Refer to your certificate for coverage details.
wsuRED MEMBER MEMBER`s DATE OF BIR7H ACCOUNT NUMBER RATE OF ISSUE OF THIS CERTIIacATE
JOINT INSURI~ MEMBER JOINT INSURC-05 LY~TE OF BIRTH GROUP POLICY NUMBER SECOtg11R1r BENEFICIARY le yw dKYs b ~ ar)
037-2095-0
THE FOLLOWING STATEM131TS MADE BYYOU ARE REPRESENTATIONS AND ARETAUHTO THE BE.&T OFYOUR KNtJINLEDriE AND BELIEF:
t3Ytt ~rT~ L'tFE NrSIlRANCE
YES NO CONERA~GE 8EI.t:CTED
COST PER 5100
SINGLE CREDIT LIFE D URONEHLY 7rc
O
L
COST PER S1g0
JOINT CREDIT LIFE OF YOUR MONTHLY 12.35
LOAN BALANCE
ARE YOU
~` MAXIMUM AtiE G5't
7
UNDER AGE FOR INSURANCE
MA)OiaUM INSURABLE BALANCE +uNOER chear LIFe ArM aSABLITY. THE
PER IJDAN ACCOUNT MAXIMUM ElJGIBaJTY At•E FOR CO/ERAGE
5 5O 000 M ~. wort NO MAwMUM TaaASwo'x~a AGE
SIGNATURE ~ JOINT INSURED MEMBER
APesltaTeePA
nw Boss aeovl
q_~..~~
;7179607920 # A- 7
2 NAME (Pkw Prinq I ACCWNi NUMBER
axolelt. Unless otherwLge required bylaw, paynrenh wSl be appded to amounts owed under
the Plan, in the mamler the Crodtt Union chooses.
4. PLAM ACCESS -You can obtain credit advances in any mariner authorized by us. ff we
albw you to Use r ATM/Debit card to axes thePlan, you may be dable for the unauthorized
use of your ATM/lkbR card. You wiA not be Iteble for unauUadaed use tlat oxurs after you
nobly us, only or in wrgf ng, of the loss, theft, or possible unaudwriaed use. if you believe your
ATM/Debit card has been lost or stden, imnle~abllii Inform file CtedR Union ceding or
wrldrg us at the telephone number or address that appears elsevdlero In the Plan. die and is
roved to obtain urroutiadzed advances directy front the Plan, your satiety wit not exceed i5D.
H the unauthorbed wttlldrawal is from a sharodtaft account, your ira6ttlly to governed Dy the
Regu~tlon E disclosuros you received at the time you teoelved your ATM! artl, even f the
withdrawal resuRs h an advarxx being mart from your overdcalt aubaxount.
6. RNANf:E CHARGE -The dollar amount you pay for money borrowed is r.Ilhd a "finance
charge' and bogies on the date of each advance. A flnarlee charge wiN be computed separately
for each separate hslarrce under the Plan. To compute nle ellsnoe charge, the unpaid balance
for each dry shrce your last payment (or since an rldvallce ft you have not yet made a paynlsrrt)
is multiplied by the applicable dally periodic rates Ttre wm of rises amounts k the flntnce
charge owed. the baWtce used to compuM the fUwnce adage is the unpaW bahna used day
after psirtrlents and credits to drat balance hauls bcen subtncbd and arty additions to the
balance have been made. In addKion to interest, rre may adlarge adler fklanrx charges whid-
aro dbdosod on the Addendum. ff die interest rah is a vsriahle interest rate, the Addendum
explains how the variable interest rate works.
e. ti~Uf111Y -You pledge as security for the Plan all siwas and dlviderads and, if atl
doPostts Mld interest in all joint and individual eax-Ielts you have tvNh us now and N the fubae.
( on reverse side)
rou atdflortze a5 to aPptY tits helaace ia'titwe ala~e io airy aultwlds due.
Shwas told d~tts In an fintNridual ~ Actro~tt, and airy Mbar
account itttt would lots tpetdal tart under staN a kdetal law H divan
as severity, fw [let sebject ~ the Secarhy~~ you have pllnn in yotrc ahare5
sad deposits.
eoRROwER z:3IONaIrRE
DArE
these charges the same as it accrues on amounts of advances which are added to
your Loan Balance.
DO NOT SIGN TH1S APPLICATION IF R QONTAINS ANY BLANK SPACES. This
appiicaUoh is void and will not be used is ^ realest ti ail blank spaces have not
been eomplated, It the member has no! slytNUl and dated the Application, and if
the Application has sot been witansed.
CRE DIT 01SA-131UTY~MISURANCE""'
YES NO COVER/WE SELECTED PREMIUae SCHEDULE
SINGLE CREDIT DISABILITY ~ S ~~
ON THIS DATE, ARE YOU PHYSICrAI.i.Y NIOFW NG FOR A SALARY OR
WAGES A MINIMUM OF 25 HOUF#S A WEEK?
URND RAGE 65 Z FOB R INSURANCE (i5*
MAXIMUM MONTHLYTOTAL CREDR LIFE AND DlsAeaJi7 ins
i>18ABILrrY BENEFIT MAXaiNAe taromruTr ARiE FOR COdERKaE
S 050 00 Is ee. wma NO MAwMUMTewa+ATmN KaE
ff you are totally d[sablsd for more than t 4 days, then the
beraefrt veld begin wins the 15 day of
EXHIBIT
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CORNERSTONE
r.ar .i cr•al, uolr,
PS1 Bn" 1181 • 5 Fml Ciile Drire • CarGsk, PA 17013
PFrorc: p171249-1611 • Tdl-firs 1.881!-71 &G7B6
PA%: p17I2<')-820tl • www.[nrnrrSM"Cku.coop
Mu"6e~foundrd SrrvicebaseA
Open-End Disbursement
Receipt Plus
. E7ttlSiER~~~11RMA"~FIO~`:>::::::::«:::>:<t<::>::.<.:::>:::><:>:::>::;>:<:::::::><:::>~<::;>>~~:>>:»'><:«>:><~;:>:>:>:;:«:>::<<;>::«~:}<::>:i<>«::::
BORROWER 1 NAME BORROWER 2 NAME ACCOUNT NUMBER DATE
GEORGE MCNAUGHTON JR 8706-02 07/15/2004
#''i?iii?'?G?'`Ei?!%i::iii's:i::: 'tiEiE~`?~ 11111"f
THE ADVANCE IS SECURED BY YOUR SHARES, ALL PROPERTY SECURING OTHER PLAN ADVANCES AND LOANS RECEIVED IN THE PAST OR IN THE FUTURE, AND THE FOLLOWING PROPERTY:
PROPERTY/MODEL YEAR I.D. NUMBER VALUE KEY NUMBER
HONDA CIVIC SI 1999 1HGEM1152XL072953 Sq~~'~~
$
PLEDGE OF SHARES ACCOUNT PLEDGE OF SHARES ACCOUNT
AND/OR DEPOSITS $ NUMBER AND/OR DEPOSITS $ NUMBER
CONSUMER'S CLAIMS AND DEFENSES NOTICE - - The following paragraph applies to the Advance only if the box is checker
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICf
THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OF
WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID Bl
THE DEBTOR HEREUNDER.
::><:::;:<::::::::::::<:;<:>>>::<:::>::::`::<::>::<::::::;:::>:::«.....3~~~ P~11'd.'aE't`:117N:<1~31~~::~iI:LRfiTAI~I~`:1~!~1-~!`!!T;'~'P ~ : < .:.; ; .. ;:<:::>:;;;»<>;>>~:;:<;.;::.;:;~:.;::<.;;:;;::;:;;:.;::.:;:>;>;:;.;::::.
>:~:<: t~ t . .::
You can now voluntarily elect to become insured with the coveragels) shown below. In order for coverage to become effective you must meet a
insurance eligibility requirements stated in the Credit Insurance Application/Schedule. NOTE: The insurance you're applying for contains certail
terms and exclusions; Refer to your certificate for coverage details. If you need a copy of the Insurance Certificate, just ask. By signing below
you authorize us to add the charges for the insurance to your outstanding balance each month. Coverage election applies to the entire balance on thi
subaccount. Insurance rates are subject to change.
COST PER $100 OF YOUR NAME OF INSURED(SI
YOU ELECT THE FOLLOWING: MONTHLY LOAN BALANCE
NO Single Credit Disability SEE SEPARATE Not Elected
RATE SCHEDULE
NO Single Credit Life S .070 Not Elected
NO Joint Credit Life S .123 Not Elected
.~
DAILY PERIODIC RATE ANNUAL PERCENTAGE RATE INTEREST RATE IS:
% OTHER FEES (Amount and Deacriptlon)
$ 0
00`0 `
~~ L/ ~' NEW BALANCE THIS SUBACCOUNT
900
00
$ 9
1'
"
.013698 5.000
Fixed .
j, 00 ( a
~ ~ ,
.
~ e
/ ?
/>7 Q /
AMOUNT ADVANCED PAYMENT AMOUNT DATE DUE PAYMENT FREQUENCY L NE 0 CREDIT LIMIT REMAINING LIMIT
$ 9,900.00 $228.02 08/75/2004 Monthly l.~g $ .00 50.00
Loan Officer: 21
............................................................................................................. .. .. ~W7 Eli"wvtasyii"EEEEEi?Eii?i'>E~i>%i`'?iii'r'asr~_E;-'-`i`'-`iEii?ii'ziEiE;>Ei>i'>iiiiifi`lzC'ii>iii2?i~~;
By signing below, or by endorsing the proceeds check for the advance described above, or by having the loan proceeds deposited into your share/sha
draft account or paid to a third party, you agree:
(1) that the property described in the Security Offered section above ("Property") is security under the terms of the LOANLINER Credit and Securi
Agreement (the "Plan") for all amounts you owe under the Plan and that the property description is incorporated into and a part~of the Plan;
(21 that the Property is also security for any other loans, including but not limited to, any credit card loan that you have with the credit union now or
the future;
l3) that you will make the payments disclosed above in accordance with the terms of the Plan; and
14) that if you are now electing credit insurance, you are voluntarily electing the coverage checked in the Subsequent Election for Voluntary Payme
Protection section above.
X (seau X (sEAu
BORROWER 1 SIGNA URE DATE BORROWER 2 SIGNATURE DATE
REQUESTED: MEMBER PAYS
PREMIUM FOR:
DATE LOAN OFFICER COMMENTS
.7 ~5 ~~
CHECK NUMBER: ~ r oZ~a BRANCH NUMBER:
702. PROCESSED aY:
LOAN OFFICER INITIALS
EXHIBIT ~~
vxxoss ILASE
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CORNERSTONE ~ `~u~ ~,~CL.
P.(3. Ba> IIAI • 5 Eau (:ale Drive • (arliJe. PA 17013 /// t2
I'honr (71?I?i9-1611 • Tall-free: 1.AAA•71 R-67 A(. ~~ ~ ~ ~~`~ ~~ ~) 1 /~ /• r-,, \"'7~ ~~ ~~~`f /1 n -f ~~ 112
(AX'17171?JV-tl2Utl•~nvw.<W,M,51UnCICU.000P ~tl/`-- `\(/..lr-tC~Nl..4,vI ~t 7.I'r v1 tf
Mtmberfomrdtd-Stn~irr bared
~~~ ~ 1PrT~ Application
Married Applicants :May apply for a separate account.
Individual Credit: You must complete the Applicant section about yourself and the Other section about yow- spouse if
1. you live in or the property pledged as collateral is located in a community property state (AK, AZ, CA, [D, LA, NM, NV, TX, WA, WI),
2. your spouse will use the account, or
3. you are relying on your spouse's income as a basis for repayment. If you are relying on income from alimony, child support, or separate maintenance,
complete the Other section to the extent possible about the person on whose payments you are relying.
Joint Credit: F~ch Applicant must individually complete the appropriate section below. If Co-Borrower is spouse of the Applicant, mark the Co-Applicant
box.
Guarantor: Complete the Other section if you are a guarantor on an account/loan.
LOANLINER Account/Loan: 8706- Credit Card Account:
%hu'luding ATM/Debit Card Access to the Account ijAvailable) (See Disclosure Table or Agreement jor Tw•n3s)
Amount Requested $ 10, 500.00 ~ Credit Limit Requested $
Pu3pose/Collateral: 1999 HONDA CIVIC SI ~~L-~~k~JpL~ If Authorized User, Name:
Repayment:
PAYMENT PROTECTION Are you interested i n having your loan protected?
If you answer 11yes11, then the credit union will disclose the cost of this voluntary payment
protection to you. A separate election which discloses the terms and conditions must be signed
for protection to be effective.
APPLICANT' _J-.~1~1 ( 1~ I ~ ~(~ UT<~iER
GEORGE MCNAUGHTON JR
3lRTHDATE HOMEPHONE~~ M`{~~ BUSMESSPHONE~EXT.
10/22/1982 (717)776a~1(l5•~ (717) 691-2616
PRESENT ADDRESS
925 CENTER RD, PO BOX 294 LENGTH AT RESIDENCE
NEWVILLE PA 17241
PROPERTY STATE:
MARITAL STATUS: $1 ng l e
EMPLOYJ1iliNTiINGFQML~ $ 35000 PER Annua l
VAME AND OVERNITE TRANSPORTATION
ADDRESS OF MECHANICSBURG PA 17055
EMPLOYER r
FORKLIFT OPER.
PROPERTY STATE:
MARITAL STATUS:
NAME AND
ADDRESS OF
EMPLOYER
PHONE~EXT.
$ PER
REVEALEDIF YOU DO NOT CHOOSE TO HAVE Tr CONSIDERED. REVEALEDIF YOU DO NOT CHOOSE TO HAVE IT CONSIDERED.
JTHER INCOME OTHER INCOME
$ PER SOURCE $ PER SOURCE
~ PER SOURCE $ PER SOURCE
~ PER SOURCE $ PER SOURCE
$ PER SOURCE $ PER SOURCE
U'HERE
FI\'E YEARS
ENDING%SEPARATION DATE I I W HERE
REFERENCE
SAME AND ADDRESS OF NEAREST RELATIVE NOT LNING WITH YOU
ENDINGSEPARATION DATE
REFERENCE
NAME AND ADDRESS OF NEAREST RELATIV E NOT LIVING \VITH YOU
< .. ... ........~......,,,..,., .,.~~ ~, ... ~, ..,. ,,.,.,. ,., .,. ... ,....,.,•.•,..-ter-...,.-.. PA(:F 1
W1iA1 YOU OWE CREDITOR NAME THERTHA THIS CRED[ UNION
(Atachadditionalsheet(s)lfnecessary) INTEREST
RATE
PRESENT BALANCE M NTHLI
PAYMENT OWED BY
APPLICAN OTHEI
AUTO LOAN ~ WAYPOINT S 0 S 130 X
CREDIT CARD VISA CFCU S 0 S 100 X
s s 3
s s
s s
s s
s s
s s
s s
s s
s s
s s
LIST ANY NAMES UNDER WHICH YOUR CREDIT REFERENCES AND CREDIT HISTORY CAN BE CHECKED: TOTALS ~ O S 23O
WHAT YAU QWN ~:
LIST LOCATION OF PROPERTY OR FINANCIAL INSTITUTION
MARKET VALUE PLEDCEDASCOLLATERAL
FOR ANOTHER LOAN . OWNED
APPLICA BY
OTHER
1997 MIT. ESCLIPE $ 8000 X
S
S
S
S
S
S
1L1t IIYt ()1TIVI~TIIQN A~OIIT'.~C11~ '~ IF YOU ANSWER "YES" TO ANY QUESTION OTHER THAN sl, EXPLAIN ON AN ATTACHED SHEET App~LICANT GOTH-ER
ARE YOU A U.S. CITIZEN OR PERMANENT RESIDENT ALIEN? YI BS~ 1
'_. DO YOU CURRENTLY HAVE ANY OUTSTANDMG NDGMENTS OR HAVE YOU EVER FILED FOR BANKRUPTCY, HAD A DEBT ADIUSTMENT PLAN
CONFIRMED UNDER CHAPTER 13, HAD PROPERTY FORECLOSED UPON OR REPOSSESSED IN THE LAST 7 YEARS, OR BEEN A PARTY M A LAWSUIT! NO
3. IS YOUR INCOME LIKELYTO DECLINETN THE NEXT TWO YEARS? NO
4. ARE YOU A C0.MAKER, CO-S)GNER OR GUARANTOR ON ANY LOAN NOT LISTED ABOVE'! YBS
FOR W HOM (Name of Others Obligated on Loan): TO WHOM (Name of Creditor):
BLS S)ST~2; ~~U.. ('(1~-f~A~UC-~1T~- Wq~ icy ~dt D
STA'i'E LAW N17tTItr~S ' OHIO RESIDENTS ONLY: The Ohio laws unless the Credit Union is famished a copy of the agreement, statement or
- 'against discrimination require that all creditors decree, or has actual knowledge of its teens, before the credit is granted
make credit equally available to all creditworthy customers, and that credit or the account is opened. (2) Please sign if you are not applying for this
reporting agencies maintain separate credit histories on each individual account or loan with your spouse. The credit being applied for, if granted,
upon request. The Ohio Civil Rights Commission administers compliance will be incurred in the interest of the mamage or fatnily of the
with this law. undersigned.
WISCONSIN RESIDENTS ONLY: (1) No provision of any marital property
agreement, unilateral statement under Section 766.59, or court decree
under Section 766.70 will adversely affect the rights of the Credit Union
~X
SIGNATURE FOR WISCONSM RESIDENTS ONLY
DATE
~)E~-1
I. You promise that everything you have stated in this application is
'con'ed to the best of your knowledge and that the above information is a
complete listing of what you owe. If there are any important changes you
will notify us in writing immediately. You authorize the Credit Union to
obtain credit reports in connection with this application for credit and for
any update, increase, renewal, extension or collection of the credit
received. You understand that the Credit Union will rely on the information
in this application and your credit report to make its decision. If you
request, the Credit Union will tell you the name and address of any credit
bureau from which it received a credit report on you. It is a federal crime
to willfully and deliberately provide incomplete or incorrect information on
loan applications Inade to federal credit unions or state chartered credit
unjoHS.igsured by NCUA.
APPLICANT'S SIGNATUR~ O
~ APPROVED APPROVED SIGNATURE
LIMITS:
DENIED S
(Adverse Action Notice SmU
LOAN OFFICER COMMENTS:
~~~~` ,:
2. If you are applying for a credit card, you understand that the use of
your card wiU constitute acknowledgment of receipt and agreement to the
terms of the credit card agreement and disclosures. You grant us a
security interest in all individual and joint share and/or deposit accounts
you have with us now and In the future to secure your credit card
account. When you are in default, you authorize us to apply the balance in
these accounts to any amounts due. Shares and deposits in an Individual
Retirement Account, and any other account that would lose special tax
treatment under state or federal law if given as security, are not subject to
the security interest you have given in your shares and deposits.
1 A (SEAL)
OTHER SIGNATURE DATE
['TJ1±11(QPl 1SE #aNLY>
_.
LINE OF CREDIT OTHER OTHER DEBT RA710~SCORE
BEFORE AFTER
$ $ $
X
X
DATE
DATE
n ~ nr ~
CO'RNER6TONE FEDERAL C.II.
P.0 HOX 1181
CARLISLE PA. 17015
(717) 249-1661
Iz-Member Inquiry
Member: 8706 - GEORGE MCNAUGHTON JR
TSD: XXX-XX-0252
Loan Information
Record
Amount
Balance
Payment/Alt
Frequency
Method
Status
Late Fee
Int Due/Payoff
RateJDlyInt
Next Due
Last Pymt
.Loan Date
First Pymt
Co-Borrower(s)
1)
2)
3)
4)
Credit Bureau
Comment Code
Status Code
Option Code
ACCOUnt Type
Compliance Cond
Date First Delq
02 - LOAN ACCOUNT/
9,900.00
.00
228.02
12-Monthly
Cash
Charged-Off
.00
.oo/.oo
5.000/ .000
06/15/2008
06/29/2007
07/15/2004
08/15/2004
Date Printed: 10/25/2010
Eff Date: 10/25/2010
Type Closed-End
Lock/Warn 99/
Pledged
Note No. 02
Prp/Co]./Off 5/ 3 /21
User1234 / / /
Closed 06/29/2007
Charged-Off
Last F/M 02/03/2009
Matures 07/15/2008
LOC Date
LOC/Avai]. 0/.00
ECOA Code
Amcx~nt "~~- ~5,~CX4~1o
Repoxt Loan
(Individual)
06/15/2006
Delinc,~uent Status
Amount
Months/Pyrtits
Notice No.
Notice Date
.00
0/ 0
3
07/17/2006
-- ----Times Delinquent-----~-
30days 60days 90days 120days
5 2 1 1
--Payment History (24 mos)--
LLLLLLLLLLLLLLLLLLLLLLLL
EXHIBIT
CORNERSTONE
P.Q ana I la1 • S East Cale Drive • Carlisle, PA 1701.;
PLEDGE OF SHARES ACCOUNT PLEDGE OF SHARES ACCOUNT
ANDJOR DEPOSITS 6 NUMBER AND/OR DEPOSITS s NUMBER
^ CONSUMER'S CLAIMS AND DEFENSES NOTICE - - The following paragraph applies to the Advance only if the box is checker
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICI
THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OI
WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID B'
THE DEBTOR HEREUNDER.
You can now voluntarily elect to become insured with the coverageis) shown below. In order for coverage to become effective you must meet a
insurance eligibility•requirements stated in the Credit Insurance Application/Schedule. NOTE: The insurance you're applying for contains certail
terms and exclusions; Refer to your certificate for coverage details. If you need a copy of the Insurance Certificate, just ask. By signing below
you authorize us to add the charges for the insurance to your outstanding balance each month. Coverage election applies to the entire balance on thi
subaccount. Insurance rates are subject to change.
YOU ELECT THE FOLLOWING:
NO Single Credit Disability
NO Single Credit Life
NO Joint Credit Life
COST PER x100 OF YOUR
MONTHLY LOAN BALANCE
SEE SEPARATE Not Elected
RATE SCHEDULE
S .070 Not Elected
S .123 Not Elected
NAME OF INSUREDS)
DAILY PERIODIC RATE ANNUAL PERCENTAGE RATE INTEREST RATE IS: OTHER FEES (Amount and/pescriptionl 1 ~ NEW BALANCE THIS SUBACCOUNT
.029452 10.750 % Fixed s~~00 /`j, -=~?~<,F 7 f''`, /~~1 ~/G f'~Fl>?/ -~ -(-; ~' s 4, 584.54
AMOUNT ADVANCED PAYMENT AMOUNT DATE DUE PAYMENT FREQ ENCY LI~EDIT LIMIT REMAINING LIMIT
s 4,584.54 s213.20 06/19/2005 Monthly.,Z1~ s .00 x0.00
Loan Officer: 21
:> ..:....:.. >:S-t~I~IA~I~~~ES> .:...
By signing below, or by endorsing the proceeds check for the advance described above, or by having the loan proceeds deposited into your share/shat
draft account or paid to a third party, you agree:
11) that the property described in the Security Offered section above 1"Property") is security under the terms of the LOANLINER Credit and Securii
Agreement (the "Plan") for all amounts you owe under the Plan and that the property description is incorporated into and a part of the Plan;
121 that the Property is also security for any other loans, including but not limited to, any credit card loan that you have with the credit union now or i
the future;
13) that you will make the payments disclosed above in accordance with the terms of the Plan; and
(4) that if you are now electing credit insurance, you are voluntarily electing the coverage checked in the Subsequent Election for Voluntary Paymer
Protection section above.
X
DATE BORROWER 2 SIGNATURE DATE
':><::>~~R`~ffE : I'C I~iIE~N~`~~~`~111E:1f.,
REQUESTED: MEMBER PAYS CHECK NUMBER: ---" BRANCH NUMBER:
PREMIUM FOR: '
PLAN/SUBACCOUNT NO.:_ !~=
~ PROCESSED BY:
DATE LOAN OFFICER COMMENTS I ~N OFFICER INITIALS
r 1
,- - ,.
r'i ~
,;
EXHIBIT
~_CORNERSTONE
~ ere. .,. ~,.~, 1,~
P.Q Box 11fl1 • 5 Eui Caie Drive • Carlisle, PA 1701.1
Fhone:1717) 249-1611 • Toll-free: 7-flag-71 B-fi7fl6
fAX: V17J 249-a2Ua • w..m'.corncrS(OnefCU.cUOF
Mrmberjouuded-Service based
~. ~ ~~ `~ t~1~
Applicatior
Individual Credit: You must complete the Applicant section about yourself and the Other section about your spouse if:
1. you live in or the property pledged as collateral is located in a community property state (AK, AZ, CA, ID, LA, NM, NV, TX, WA, Wq,
2. your spouse will use the account, or
3. you are relying on your spouse's income as a basis for repayment. If you are relying on income from alimony, child support, or separate maintenancE
complete the Other section to the extent possible about the person on whose payments you are relying.
Joint Credit: Each Applicant must individually complete the appropriate section below. If Co-Borrower is spouse of the Applicant, mark the Co-Applicar
box.
Guarantor: Complete the Other section if you are a guarantor on an account/loan.
Check below to indicate the type of accountls) and type of credit for which you are applying. Married Applicants may apply for a separate account.
® LOANLINER Account/Loan: ® Individual ^ Joint ^ Credit Card Account: ^ Individual ^ Joint
(including ATM/Debit Card Access To The Account if Avai/ab/e1 (See Disc%sure Table or Agreement for Terms)
Amount Requested $ 4,584.54 Credit Limit Requested $
Purpose/Collateral: REFI LDAN AND FIX AUTOS If Authorized User, Name:
Repayment: ^ Payroll Deduction ®Cash ^ Military Allotment ^ Automatic Payment
PAYMENT PRO~EGTIClIY; Are you interested in having your loan protected? ^ Yes ^ No
If you answer "yes", then the credit union will disclose the cost of this voluntary payment
protection to you. A separate election which discloses the terms and conditions must be
signed for protection to be effective.
AMT
JR
A
^ CO-APPLICANT ^ SPOUSE ^ OTHER
10/22/1982 (717)776-5239 (717) 691-2616
PRESENT ADDRESS (Street -City -State -Zip) OWN RENT
925 CENTER RD, PO BOX 294 LENGTH AT RESIDENCE
NEWVILLE PA 17241
PREVIOUS ADDRESS (Street -City -State -Zip) ^ OWN ^ RENT
LENGTH AT RESIDENCE
COMPLETE FOR JOINT CREDIT, SECURED CREDIT OR IF YOU LIVE IN A COMMUNITY
PROPERTY STATE:
^MARRIED ^ SEPARATED ®UNMARRIED (Single -Divorced - Widowed)
-City -State - Zipl II I OWN I I RENT
PREVIOUS ADDRESS (Street -City • State -Zip) ll-I OWN rl RENT
PROPERTY STATE: ,,., ..,.~..~ ~, „~.,.,~,......,,~.., ~ ..., „ ,.,., ~~.~ ,~. „.,..,.~~.,.,,.,, .
^MARRIED ^ SEPARATED ^ UNMARRIED (Single -Divorced -Widowed)
SS of OVERN 17E TRANSPORTATION
IYER MECHANICSBURG, PA 17055
FORKLIFT OP
- • •- rvs.x„wc ivccu rvu i oc
REVEALED IF YOU DO NOT CHOOSE TO HAVE IT CONSIDERED.
EMPLOYMENT INCOME OTHER INCOME
g 28161 pefAnnual $ Per
® NET ^ GROSS SOURCE
ENDING/SEPARATION DATE
FIVE
NAME AND
ADDRESS OF
EMPLOYER
REVEALED IF YOU DO NOT CHOOSE TO HAVE IT CONSIDERED.
EMPLOYMENT INCOME OTHER INCOME
$ Per $ Per
^ NET ^ GROSS SOURCE
ENDING/SEPARATION DATE
NO
FIVE YEARS
ENDING DATE
R£;FERENGE:
NAME AND ADDRESS OF NEAREST RELATIVE NOT LIVING WITH YOU
NAME AND ADDRESS OF NEAREST RELATIVE NOT LIVING WITH YOU
HOME PHONE
CREDITOR NAME OTHER THAN THIS CREDIT UNION INTEREST MONTHLY OWED BY
WHAT ~lOU OWE ' (Attach additional sheeNsl if necessary) RATE PRESENT BALANCE PAYMENT AppUCANT OTHE
RENT a FIRST
MORTGAGE
(incl. Tax & Ins.)
AUTO LOAN-SOVEREIGN
$ 0
$ 180
X
2nd MORTGAGE CREDIT CARD-VISA CFCU $ 0 $ 250 X
1st AUTO LOAN CHARGE ACCT-HSCB $ 0 $ 29 X
2nd AUTO LOAN $ $
CHILD-CARE $ $
CHILD SUPPORT $ $
CREDIT CARD $ $
CREDIT CARD $ $
OTHER $ $
OTHER $ $
LIST ANY NAMES UNDER WHICH YOUR CREDIT REFERENCES AND CREDIT HISTORY CAN BE CHECKED: TOTALS $ O $ 459
~
~ PLEDGED AS COLLATERAL OWNED BY
';<::<;:';;'
' ''t;:: ;' ~ :.' .. •
~:::~~~:;~;.:::::::::
..............................................
............................................... UST LOCATION OF PROPERTY OR FINANCIAL INSTRUTION MARKET VALUE FOR ANOTHER LOAN
APPLICANT OTHE
HOME 1997 MIT. ESCLIPE $ 8000 vES NO X
AUTO $ YES NO
SAVINGS $ YES NO
CHECKING $ YES NO
OTHER (Describe) S YES NO
c:
U #iER dNFORMAT113N A~~I.#>F YOD ::'
IF YOU ANSWER "YES" TO ANY QUESTION OTHER THAN M1, EXPLAIN ON AN ATTACHED SHEET pppUCANT
OTHER
1. ARE YOU A U.S. CITIZEN OR PERMANENT RESIDENT ALIEN? YES
2. DO YOU CURRENTLY HAVE ANY OUTSTANDING JUDGMENTS OR HAVE YOU EVER FILED FOR BANKRUPTCY, HAD A DEBT ADJUSTMENT PLAN
CONFIRMED UNDER CHAPTER 13, HAD PROPERTY FORECLOSED UPON OR REPOSSESSED IN THE LAST 7 YEARS, OR BEEN A PARTY IN A LAWSUIT? NO
3. IS YOUR INCOME LIKELY TO DECLINE IN THE NEXT TWO YEARS? NO
4. ARE YOU A CO-MAKER, CO-SIGNER OR GUARANTOR ON ANY LOAN NOT LISTED ABOVE? Y2S
FOR WHOM (Name of Others Obligated on Loen): TO WHOM (Name of Creditor/:
OHIO RESIDENTS ONLY: The Ohio laws
ST'A'~Ft?GA~1t>f1:t3T~~~S?<>:;: unless the Credit Union is furnished a co of the a reement statement c
PY 9
................................................
against discrimination require that all creditors
decree, or has actual knowledge of its terms, before the credit is grante
make credit equally available to all creditworthy customers, and that credit or the account is opened. (2) Please sign if you are not applying for th
reporting agencies maintain separate credit histories on each individual account or loan with your spouse. The credit being applied for, if granter
upon request. The Ohio Civil Rights Commission administers compliance will be incurred in the interest of the marriage or family of tF
with this law. undersigned.
WISCONSIN RESIDENTS ONLY: (1) No provision of any marital property X
agreement, unilateral statement under Section 766.59, or court decree
under Section 766.70 will adversely affect the rights of the Credit U
n
i
on SIG
NATURE FOR WISCONSIN RESIDENTS ONLY DATE
~y
~
y
~r
~~c~
iiiii%:';:v?ISiN/.+1,ifi~,''ii`at;i; ';i:i;t2:':::f:' < i:ai:a:;'.'? <t:%`' i;i;:i: ~i::~ i;i:::i 1' [i:i ~;:;[iii~:i:iii:i{.%i:;<i i ~ :i:i ~ ai'.~;i:i[ 5:iii iti::c
1 . You promise that everything you have stated in this application is 2. If you are applying for a credit card, you understand that the use c
correct to the best of your knowledge and that the above information is a your card will constitute acknowledgment of receipt and agreement to th
complete listing of what you owe. If there are any important changes you terms of the credit card agreement and disclosures. You grant us
will notify us in writing immediately. You authorize the Credit Union to security interest in all individual and joint share and/or deposit account
obtain credit reports in connection with this application for credit and for you have with us now and in the future to secure your credit cat
any update, increase, renewal, extension or collection of the credit account. When you are in default, you authorize us to apply the balance i
received. You understand that the Credit Union will rely on the information these accounts to any amounts due. Shares and deposits in an Individu,
in this application and your credit report to make its decision. If you Retirement Account, and any other account that would lose special to
request, the Credit Union will tell you the name and address of any credit treatment under state or federal law if given as security, are not subject t
bureau from which it received a credit report on you. It is a federal crime the security interest you have given in your shares end deposits.
to willfully and deliberately provide incomplete or incorrect information on
loan applications made to federal credit unions or state chartered credit
unions insured by NCUA.
.~.
X t'~ ) ~;I: ' ~ •~y- ~.. t ~ C. (' ~ ~~ - % ~ ` (sEPf ~ -I' (~~ L-''~
x (SEAL)
APPLICANT'S SI~iNATURE DATE OTHER SIGNATURE DATE
':'. :::::::i::Ei`: ': i'; :;:asi:::: ::i si::i's'i::p;i i;:;ii:::^;as~~1.~:3Y.~`~~~:F:f;W17~:::xIS~~ri ~;#4i..... _ ..
DATE AppROVED APPROVED SIGNATURE LINE OF CREDIT OTHER OTHER DEBT RATIO/SCORE
LIMITS: BEFORE AFTER
DENIED $ $ $ $
(Adverse Action Notice Sentl
OFFICER COMMENTS:
DATE
DATE
CORNERSTONE FEDERAT, C.U.
P.0 BOX 1181
CARLISLE PA 17015
(717) 249-1661
IZ-Member Inquiry
Member: 8706 - GBORGE MCNAUGHTON JR
TID: XXX-XX-0252
Loan information .
Record
Amount
Balance
k~ayment /A1 t
Frequency
Method
Status
Late Fee
Int Due/Payoff
Rate/Dlylnt
Next Due
Last Pymt
-Loan Date
First Pymt
Co-Borrower(s)
1)
2)
~~
O1 LOAN ACCOUNT/
Date Printed: 10/25/2010
Fsff Aate: 10/25/2010
4,584.54 Type Closed-End
.00 Lock/Warn 99/ S
213.20 Pledged
12-Monthly Note No.
Cash
~ Prp/Col/Off 1/ 7/21
Chaxged-Off User1234 / / /
.00 Closed 01/29/2007
.00/.00 ~~;Charged-Off 2418.37-
10.750/ .000 Last F/M 01/29/2007
05/19/2007 Matures 05/19/2007
01/29/2047
5 LOC Date
05/19/200 LOC/Avail 0/.00
06/19/2005
Credit Bureau
Comment Cvde
status Code
Option Code
Account Type
Compliance Cond
Date First Delq
Do Not Report
(Individual)
06/19/2006
Delinquent Status
Amount .00
Months/Pymts 0/ 0
Notice No. 3
Notice Date 07/19/2006
---~---Times Delinquent-----~-
30days 60days 90days 120days
5 3 1 1
--Payment History (24 mos)--
LLLLLLLLLLLLLLLLLLLLLLLL
ECOA Code
~-
EXHIBIT
VERIFICATION
I, David G. Keller (~ , ~ . O ~ ,
c~~ ~~~~
ot~aans~rZ~2rU1~, ~ . C • ~ . ,verify that the statements made in the aforegoing
document are true and correct_ I understand that false statements herein are made subject
to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities.
CORNERSTONE FEDERAL CREDIT UNION
ey: ,~.
Title: L! , g , b ,
Dated: / ~ ~
3668618706-01,02
McNaughton
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
FILED-CAF F1C
'HE PR0Th'M!07fAF-1Y
2916 DEC 2 ! PH 3; 01
1340 9BERLAH01 COUNTY
PENNSYLVA,WA
Cornerstone Federal Credit Union Case Number
vs. 2010-7656
George P. McNaughton
SHERIFF'S RETURN OF SERVICE
12/14/2010 08:15 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on
December 14, 2010 at 2015 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: George P. McNaughton, by making known unto Carolyn McNaughton,
Mother of defendant at 925 Center Road, Newville, Cumberland County, Pennsylvania 17241 its contents
and at the same time handing to her personally the said true and correct copy of the same. STEPHE BENDER, DEPUTY
SHERIFF COST: $39.24
December 15, 2010
SO ANSWERS,
,?Z
RON R ANDERSON, SHERIFF
CORNERSTONE FEDERAL CREDIT
UNION,
Plaintiff
v
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-7656
r_0
GEORGE P. MCNAUGHTON
Defendant(s) CIVIL ACTION - LAW
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR DEFAULT JUDGMENT
0
CTA
Y C7
CD -T,
Enter judgment in favor of Plaintiff and against Defendant(s), GEORGE P. MCNAUGHTON,
named for failure to file within the required time an Answer to the Complaint in the above-captioned
case and assess the Plaintiff's damages as follows:
Amount claimed in Plaintiff's Complaint ................................ $ 12,529.33
Less payments, if any .................................................. $ 0.00
Interest at the rate of 8.50% per annum from 7/29/07-1/31/11 (2.92 per diem) $ 3,740.61
Total ............................................................... $ 16,269.94
I hereby certify that a written Important Notice of the intent to file this Praecipe was mailed or
delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after the default occurred and
at least ten (10) days prior to the date of the filing of this Praecipe and a copy of the notice(s) is/are
attached.
KODA L ,
By
Robert D. Kodak, .Attorney for Plaintiff
aph t,-t .o N 45
ev*1?s31
',lkasq
Noon 1J
DATED: -pZ ( Judgment entered and damages assessed as above.
rothonota y
LAW OFFICES OF
Robert D. Kodak
Gary J. Imblum
GEORGE P MCNAUGHTON
925 CENTER ROAD
NEWVILLE PA 17241
KODAK & IMBLUM, P.C.
CAMERON MANSION Telephone
407 NORTH FRONT STREET 717.238.7159 x101
POST OFFICE BOX 11848 Facsimile
HARRISBURG, PA 17108-1848 717.238.7158
www.kodak-imblum.com
January 11, 2011
FILE COPY
RE: Cornerstone Federal Credit Union
VS: George P. McNaughton
No.10-7656, Court of Common Pleas, Cumberland County, PA
Our File No. 36666
Greetings:
In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing herewith
a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the
Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the
Complaint filed against you to the above term and number, nor has any attorney entered an appearance
on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take
action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office
of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in
said Complaint.
Very truly yours,
KODAK & IMBLUM, P.C.
J1,o er 1g. X o Aa t
ROBERT D. KODAK, ESQUIRE
robert. kodak@kodak-imblum. corn
RDK/ akr
Enclosures
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED
FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
ROXANE KAIN
CORNERSTONE FEDERAL CREDIT UNION
P O BOX 1181
CARLISLE PA 17013-1811
8706-01,02
CORNERSTONE FEDERAL CREDIT
UNION,
Plaintiff
GEORGE P. MCNAUGHTON,
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-7656
CIVIL ACTION - LAW
IMPORTANT NOTICE / AVISO IMPORTANTE
TO/ A: GEORGE P. MCNAUGHTON Defendant(s) / Defendido(s)
DATE OF NOTICE / FECHA DEL AVISO: January 11, ?011
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS 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.
.............................................................................................................................................................................................................................................
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER
CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN
PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE
HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA
SUVA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U
OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTA DOCUMENTO A SU ABOGADO INMEDIATEMENTE.
SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA
OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN
ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE
QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE
OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE
CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
JRiT R
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-7656 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CORNERSTONE FEDERAL CREDIT UNION
Plaintiff (s)
From GEORGE P. MCNAUGHTON, 925 CENTER ROAD, NEWVILLE, PA 17241
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT AT THE ABOVE
ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO
FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC..
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $16,269.94 L.L. $.50
Interest FROM JUDGMENT 6-5-12 -S2.L7 PER DIEM - $1,305.63
Atty's Comm5 %$813.50 Due Prothy $2.25
Atty Paid $176.24 Other Costs
Plaintiff Paid
Date: 6/6/2012
David D. Buell, Protonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name : JEFFREY L. TROUTMAN, ESQUIRE
Address: KODAK LAW OFFICES, P.C.
P.O. BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 53984
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
CORNERSTONE FEDERAL CREDIT IN THE COURT OF COMMON PLEAS OF
UNION, Cumberland COUNTY, PENNSYLVANIA
Plaintiff Writ No. Term 20
Vs No. 2010-7656 Term 20 10
GEORGE P. MCNAUGHTON Amount Due
925 CENTER ROAD 2/2/11 jdmt .............. $ 16,269.94
NEWVILLE, PA 17241 Interest from jdmt -6/5/12
DEFENDANT(S) $2.67 per diem .............. $ 1,305.63
Atty's Commission
5% statutory rate .......... $ 813.50
Costs (to be determined) $
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania
(2) against GEORGE P. MCNAUGHTON - a
i C
a nts;
(3) and against
ees;
(4) and index this writ
(a) against GEORGE P. MCNAUGHTON
Defendant(s) and
(b) against
armsneels),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy):
LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN
CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC.,
(5) Exem lion has (not) been waived.
S ag'so-d a
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14. 0 0
Dated 6/1/12 01. S
W n te. a
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17
,(p r . Kodak, Esquire
U PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Attorney For Plaintiff(s)
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Under paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b), the county should be indicated.
Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued.
Paragraph (3) (above should be completed only in a named garnishee is to be included in the writ).
Paragraph (4)(a) should be completed only if indexing ofthc executions in the county of insurance, is desired as authorized by Role 3104(a) When the writ issues to
another county indexing is required as of course in that county by the prothonotan ' See Rule 3104(b).
Paragraph (4)(b) should be completed only if real property in the name of the garnishee is attached and indexing as a Its pendens is desired. See Rule 3104(c).
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
ay R Anderson
,eriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
I _!`E
'r'k[cjrfpt`h:
Cornerstone Federal Credit Union
Case Number
vs.
George P. McNaughton 2010-7656
SHERIFF'S RETURN OF SERVICE
06/20/2012 04:05 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Writ of
Execution and Claim for Exemption Form to a person representing themselves to be Carolyn
McNaughton, mother of defendant, who accepted as "Adult Person in Charge" for the within named
Defendant, to wit: George P. McNaughton at 925 Center Road, Lower Mifflin Township, Newville, PA
17241, informed person of contents of same and levied upon personal property as directed. Copy of levy
mailed to attorney and letter mailed to defendant on 06-21-12.
07/30/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED. Defendant entered into bankruptcy.
SHERIFF COST: $73.65
July 30, 2012
SO ANSWERS,
RON Y R ANDERSON, SHERIFF
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