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Home My WebLink About11-0778I:-ED-OFFICE F TI '" ' ?0l-ll0!10TARY 2J 1 Y,%N 24 1'i a 2: -1 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299-5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NATHAN LIDDICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. o ? ? `77 g (2'v 'f -h Wt NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 to you for any money claimed in the Complaint or for any other claim or relief requested by Plaintiff(s). You may lose money or property or other rights important to you. 3082262 43?- -,)A a k?j y7031 c? asq IL(9 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 3082262 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NATHAN LIDDICK, No. Defendant AVISO PARA DEFENDER Conforme a RCP No. 1018,1 del PA LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas dispuestas en las paginas siguientes, usted debe tomar la accion en el plazo de veinte (20) dias despues de esta queja y el aviso es servido, incorporando un aspecto escrito personalmente o por el abogado y archivando en escribir con la corte sus defensas u objeciones a las demandas dispuestas contra usted. Le advierten que si usted no puede hacer asi que el caso puede proceder sin usted y un juicio se puede incorporar contra usted por la corte sin aviso adicional a usted para ckialquier dinero demandado en la queja o para cualquier otra demanda o relevacion pedida por 3082262 Plaintiff(s). Usted puede perder el dinero o la caracteristica u otra endereza importante a usted. USTED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE Un ABOGADO, VAYA A O LLAME POR. TELEFONO La OFICINA DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De USTED La INFORMACION SOBRE EMPLEAR A un ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE LOS SERVICIOS JURIDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES EN Un HONORARIO REDUCIDO O NINGON HONORARIO. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 3082262 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NATHAN LIDDICK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. COMPLAINT 1. Plaintiff, Pennsylvania State Employees Credit Union ("PSECU"), is a Pennsylvania financial institution having an office at One Credit Union Place, Harrisburg, Pennsylvania 17110. 2. Defendant, Nathan Liddick, is an adult individual with a last known address of 321 Herman Avenue, Lemoyne, Pennsylvania 17043-1940. 3. On or about May 22, 2007 Defendant entered into a PSECU Loanliner Advance Proceeds Voucher and Security Agreement and Loanliner Credit and Security Agreement and I oanliner Addendum ("Agreement") with Plaintiff for the purchase of a 2006 BMW Mini 3082262 Cooper, VIN # WMWRE33586TL23413 ("Vehicle"). A true and correct copy of the Agreement is attached hereto as Exhibit "A" and incorporated herein by reference. 4. Plaintiff's perfected security interest in the Vehicle is evidenced by a Commonwealth of Pennsylvania Certificate of Title ("Title"), a true and correct copy of which is attached hereto as Exhibit "B" and incorporated herein by reference. 5. Defendant defaulted under the Agreement by failing to pay the monthly payments when due and is currently due for the months of September 21, 2007 and thereafter. 6. Due to Defendants defaults Plaintiff repossessed the Vehicle on or about February 24, 2009. 7. By letter dated February 26, 2009, Plaintiff provided Defendant with a Notice of Repossession and Right to Redeem ("Notice"), a true and correct copy of which is attached hereto as Exhibit "C" and incorporated herein by reference. 8. For purposes of this action, PSECU is entitled to be reimbursed for all costs and expenses, including reasonable attorneys' fees of twenty percent (20%) of the amount due for enforcing the Agreement. 9. Defendant remains liable to Plaintiff under the Agreement as follows: Principal Balance $18,654.74 20% Collection/Attorney's Fees 3,730.95 Total $ 22,385.69 plus costs of suit. 10. PSECU has demanded payment from Defendant, but despite these demands, the Defendant has refused and continues to refuse to make payments. 11. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in 3082262 2 writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant the name and address of the original creditor if different from the above. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment in its favor and against Defendant, Nathan Liddick in the amount of $22,385.69, and costs of suit. BARLEY D LC By: Shawn M. Long, F Court I.D. 83774 126 East King Stree Lancaster, PA 1760P-2893 717.299.5201 Attorneys for Plain iff 3082262 VERIFICATION Pennsylvania State Employees Credit Union v. Nathan Liddick I, Gregory R. Diffenderfer, being duly affirmed according to law, depose and say that I am the Collection Manager for Pennsylvania State Employees Credit Union; that I am authorized to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. To the extent that any of the averments in the foregoing document are based upon the understanding or application of law, I have relied upon counsel in making this Verification. This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Dated: i I Z n (c Gregory R. Diffenderfer 3082262 L`^JI?? I'I'a ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT rr Pennsyivania State Employe es Credit Union PSECU P. 0, Box 67013 ;r Harrisburg, PA 17106 7013 717.234.8484 800.237.7328 MEMBER NAME DAl"E" l1?FA43Eri ACCOUCtT 11Uh16ER FIOTE NUFABER NATHAN LIDDICK 5/22/2007 0209701844/T,11 0006161100 406 DAVIS STREET - HARRISBURG, PA 17109-4019 PURPOSE: - Dealer Purchase TRANSACTION TYPE ? 1 NE AN 2 L ? OPEN-END L OTHER ? . . W O OAN ADVANCE 3. D ESCRIBE) 4. EQUITY ADVANCE CREDIT DISABILITY YOU HAVE PREVIOUSLY ELECTED TO HAVETHIS ADVANCE L E n IN E CREDIT LI ? JOINTCHEDITLIFE INSUR D WITH THE FOL O WING COVERAGE YES ND I ? YES YES IN DAILY PERIODIC RATE (CHANGE INTERNS ONLY) ANNUAL. PER- INTEREST RATE ISI AMOUNT REQUESTED O AMOUNTADVANC50 PREVIOUS BALANCE NEW BALANCE CENTAGE RATE + THER CHARGES 0212055 7 740 FIXED VARIABLE 29 934 32 _ ?- 3` - . . % g] , . :2 32 0.00 [l 29,934.32 PAYMENT DUE DATE ^ ..... PAYMENT FREQUENCY PROJECTED LOAN TERM 462.80 6121/2007 Monthly SECURITY OFFERED IFTHIS IS A HOME EQUITY ADVANCE, THE ONLYSECURITY FOR THIS ADVANCE IS THE REAL PROPERTY (IN MOST CASES YOUR HOME) WHICH YOU GAVE AS SECURRY WHEN YOUR ACCOUNT WAS ESTABLISHED. IF THIS IS NOTA HOME EQUITY ADVANCE, IN ADDITION TO THE PLEDGE OF SHARES IN YOUR LOANLINER' CREDIT AGREEMENT, THE FOLLOWING PROPERTY SECURES THIS ADVANCE. ITEM PROPS M EC:" :^ RTY O!3 FTlH4 rQ.NUMBER: ;TYP BMW - MINI 11.'L'LV1 CVUPi' R 2006 W 1WRE335u6'.1L23413 SIN 2U, ?l15. Uli 2 3. 4.OTHER YOU PLEDGE SHARES ANDIOR DEPOSITS OF $ IN ACCOUNT NUMBER OLD ACCOUNTlLOAN NUMBER A) PAYOFF (PRINC.+INT.) OLD ACCOUNTA GAN NUMBER (D) PAYOFF PRINC.+ INT OLD ACCOUNT/LOAN NUMBER (C) PAYOFF (PRINC.+ INT.) OLD ACCOUNTA.OAN NUMBER D PAYOFF (PRINC. + INT) OLD ACCOUNTICAN NUMBER E) PAYOFF (PRINC. + INT. OLD ACCOUNTILOAN NUMBER F) PAYOFF (PRINC. + INT.) By accepting the proceeds or by using the funds advanced and deposited into your share/share draft account, you agree (1) that the property role renced above will secure the advance and any other advances you have now or receive in the future under the LOANLINERa Credit and Security Agreement (the Plan) and any other amounts you owe us for any reason now or in the future in accordance with the terms of the Plan and (2) to make payments as disclosed above in accordance with the terms of the Plan. ., . . .n. . . a.cw... . -111 n-vcu ?IgIT A PUNNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM #3175 JVXX0100-1 037'-2092-1 (0/05) i AUTODRAFT PAY TO THE ORDER OF (DEALER) . .-, , j. EMBER ENDORSEMENT,-',. - By endorsing this AotoDraft, Me agree to the terms listed on the reverse side of the draft Cleu the following mpayerent Inlommtlon. Term IMo th )' 11117 to M.A-T- in the M??ot°°jj Vah daloans &«Nae. McLhad. (`?' ?A,Ao Tranda ? Homab" ing ? Par on LJ]< mNv cc oon ? Wrect Prymsnt Frequency, }1? ManNy ? B.Wedly ? W1el.ly ?. S-i M-01v Membsr''Endorsement NATHAN LIDDICK Co-Applicant Endarserrmnt NO CO-APPLICANT 1106161100116 .11:23131811161: 31113259SS11a 44 1110002993432011 3A, ?+p 3 to °3m 71 .dYn1SlIFm Cm 95arm z -,? sa ?-"ore 3°+1 3(z tigql 3 Do -40 „ir 1- Sg Doss ? n?° m blo -? r^t o ST' w c< cr..Za M m71 zasm 57315 05220-t 014 95 -n T. a 13 7?92A °m ??=4 s o gn ny ? .?,N ZO aley •rtt a >ga?Tfx''y ggg:003 y (77? $c°rb$S.R$m 5..`3Q7".3$6•D?m ? G --.. .. .. .. .. .. _.._. ... =.a?J-- ?v33 oS-$ K-72- = il_ °ro•roz. "o ^?=fCTI ng?3? qzy ?3ge?nM m Xi° M I ., mri DD -D e.°e??cr'•eg$ ^8F?t?oa?t?'Z"o°nmD ?yy13 Q 1 n rl?vi 0 5-tIl1? Aga D o6p z j??---?.-1i.•N£?-s.?•R8m fi:saOm- t+m- - ---- _.? - ?? 3a3x ° y?1•oy - •?n8 r•1SSmlD ?`= JLTJ ym o3s;,?gr?a Sq-'R?`Eff 01ozmr Q o ti IT 3 r m Y C T>Ro g 2 Rp n? if gg, ?s p mym Is. 0 V. -am 2_ - FLLTL'f(En4i( /331?d19?{,-?oA3Sr`iKS?E C?a8'351?mD0i0 ;on 05$547 351a71'1T1-.. mi_oe ¢ _ 1.3 0 ?z?573?14? u31341?2n33za<.a>'oe-$0 1iom 2,1 it ennsy Varna Late mploym Credit Union No. 6I6t100 PO Sox 67013 • HamsbuM. PA 17106.7013 • (7f 7) 234-04&4 or(800) 237.7328 VOID OVER S' 29,999A0 : - , .. REFERENCE 0209701844 VOID 120 DAYS AFTER 05/1012007 C, ix A + +.311 oR LS (.L r QD DOLLARS IMPORTANT: VOID UNLESS DEALER ENDORSEMENT COMPLETED - Buys .order / B-R of Sala (New and Used Vehicles) and lact°ry invacs INaw VeNcleal rriusl be racelved bofors the AutoDfaft is racaivad 1:y PSECU or tha Aut°Draft -u b.... iallrrled. No ponion of the precaeda of.lhs AutoDran shall be paid to IhG Borrowed B), or to any agent of the Ow-Irrls) TMs AuteDrult "1 -1 ba wad to wrchew rsconatmood, cof mrro f• Work, (hell, aelvagod, or flood edwl v.Ndee at vw4dea bd.d oulaida ma Wdl.d Sulea: By scc.owig Ih. proceeds of INs draft, you agree to Ih• terms Astad on the never: sitle f. -, PSFCU FA%I 717.787.8364 MN(E ? IMI _, MOC6 V" W? MRSAW MAIERI)DWI . - DELLFR PNpE NUA1FR r S E ' Penns lvania State - Employ ees Credit Union PO. Sov CA)13 O ih), 1}1 1 l •, . ;71,7 • 41717) 23d-A •,91 , l.... .;u ? Loan Disclosures Thi LOANLINER` Cre,M and Security Agroern of vhich iar,'Lirf •S foe ?; fh i" Lending Disclosures, v ilI ho referred to as the Plan. The Plan dot ;Invents mrl iris th i :agreement and an A i 1 ndL.m. YOU. your arnd borrower mean any per on .Lo st ,r . the Plan: Credit union, we, our and us rnean PSECU iir anyono to wl,Om ti,,, rr:ct, it Union transfers its rights under Iho Plpn. i HOW THIS PLAN WORKS - This is art-open-end, multi-featured credit plan. Wr. anticipate that, from tune to tinge, you will borrow money (called 'advances') under the Plan. We are not required to make advances to you under the. Plan and can refuse a request for an.advance at any time. The Addendum describes the different types of credit (caller! "subaccounts") available under the Plan, the current interest- rate for :each srbaccounl expressed as it daily periodic fate and corresponding annual percentage rate and other charges. It may also have other terms and a schedule, for determining Ihe payment amounts. CREDIT LIMIT We IlMy, but do not have lo, establish a'credit limit on certain subaccounts, If a credillilnit is set for a subaccount, you promiso riot to exceed the established credit limit. If you exceed the credit litnit, you promise to repay Immediately the amount which exceeds the credit limit. REPAYMENT - You promise to repay all amounts you owe under the. Plan plus interest. Payments are duo on the last day of the month unless we set a different day at the ttmo of an advance. If the.Acidendum has no payment schedule fora subaccount, your payment will be determined at the time of each advance. Payments mustinclude any amount past due and any amount by, which you have exceeded any credit limit you have been given for a subaccount. You'may repay all or part of what you owe at any tine without any prepayment penalty. Even if you prepay, you will still be required to make the regularly scheduled payments unless we agree in writing to a- chango in the payment schedule, if-you have a joint sharedraft account, you will be responsible for paying all overdraft advances obtained by a joint holder of the sharodraft account. Unless otherwise required by law, payments will be applied to amounts owed under the Plan, in the manner the Credit Union chooses. PLAN ACCESS -You can obtain crodit advances in any manner authorized by us. If we allow you to use your ATM/Debit card to access the Plan, you may he Iialiln for alto I tun@tuthnd7ed use of your ATM/Debit Card. You will act l o !;ablC .'Or unauthorized use that occurs after you notify us, orally or in writing, of the loss, theft, or possible unauthorized use. If you believe your AIM/Debit card has been lost or stolen, immediately inform the Credit Union by calling or writing us at the telephone number or address that appears elsewhere in the Plan. If the card is used to Obtain unauthorized advances directly from the Plan, your liability wilt not exceed M. If the unauthorized withdrawal is from a sharodraft account, your liability is governed by the Regulation E disclosures you received at the Limo you received your ATM/Debit card, even if the withdrawal results in an advance being made from your overdraft subaccount. FINANCE CHARGE - The dollar amount you pay for money borrowed is called a "finance charge" and begins on the date of each advance. A finance charge will be computed separately for each separate balance under the Plan. To compute the finance charge, the unpaid balance for each day since your last payment (or since an advance if you have not yet made a payment) is multiplied by the applicable daily periodic rate. The sum of those amounts is the finance charge owed. The balance used to compute the finance charge is the unpaid balance each day after payments and credits to that balance have been subtracted and any additions to the balance have been made. In addition to interest, we may charge other finance charges which are disclosed on the Addendum. lithe lnterest rate is a variable interest rate, the Addendum explains how the variable interest rate works. SECURITY ? You pledge as security iorthe Plan all shares and dividends and, if any, all deposits and interest in. all joint and individual accounts you have with us now and in the future. If a specific dollar amount is pledged for an advance, we will freeze shares in that account to the "extent of the- outstanding balance for tho advance. Otherwise, your.. pledged, shares may be withdrawn unless you-are in default. The following paragraph applies in all states except in Ohio, Rhode Island and Massachusetts: We have a statutory lien on the shares and,dividonds and, it any, the deposits and interest in all individual and joint accounts you have. with us and may exorcise. our rights under the lien to the extent permitted by state law. (We are state chartered if our name does not include the term "Federal Credit Union") For all borrowers;The statutory lien and/or your pledge will allow us to apply the funds in your account(s) to what you owe when you are in default. The statutory lien and your pledge do not apply to any Individual Retirement Account or any other account that would lose special tax treatment under state or federal law if given as security. Additional security for the Plan may be required at the time of an advance- If a subaccount identities a type of property {such as "New Cars") you must give that type of property as security when you get an advance under that subaccount- A t subaccount name such as "Other Secured" means you must provide security acceptable to us when you obtain an advance under that subaccount. Property-you give as security will secure all amounts owed under the PIan and all other loans.you have with us now or in the future, except any loan secured by your principal dwelling. Property securing other loans you have With us may also secure the Plan. t -;7 CUHA MUTUAL 431101P 1900. 20)C AtL IIIGh IS t L?yEU:_ CREDIT INSURANCE Credit ',f and or credit di ihi ity insurance is option: and r he PI n. If You , r lire !or u1 l -i_t' .... r , i a !r ni us, You aufhunzi !-s to rthc in a .1r,c pre ou n., ticinfli y to your loan baiance and charge you t interest on the, cwire balance. if,you eie(,I creriit insurutcu, your payments III,) increase or the period of time necessary to repay your advance may bn extended The credit insurance rates may change during Ihe Plan If the rates charge, we wil provide any notices requited by applicable law. PERIODIC STATEMENT-On it regular basis you will ioceive a staten)enl showing all transactions under the Plan eluting the period covered by the statement. Statements and polices will be sent to you at fit(. most recent address you have given us in writing. Unless applicable law requires notice to each joint borrower, notice to any one of you will be notice to all. JOINT ACCOUNTS - If this is a joint account, each ofyou is individually and jointly responsible for paying all amounts owed. Tfiat means we care onfbrce our rights under the Plan against any one of you individuahy or against all of you together. It you give us inconsistent instructions, we can refuse to follow your instructions. unless our written policy requires all of you to sign for an advance ; each of you'authorizes the other(s) to obtain advances individually and agrees to repay advances made to tthe, other(s). Any joint accountholder may torniinati; the Plan by giving us prior Written .notice. It any of you terminate the Plan, the Plan is terminated for all of you, You remain liable individually and jointly for all advances incurred before termination. FEES AND CHARGES -- If you give us a security interest in certain types ' of property, we may charge you a filing fee to perfect our, iinterest in the property.. If we do, the amount of the fee will be disclosed to you nt the ttime you obtain an advance. We may also charge you other foes in connection with thePlan, Our current fees are disclosed on the Addendum and will be added to your loan balance unless you pity them in cash. UPDATING CREDIT INFORMATION -- You promise that you will promptly give us written notice it you (nova, change your name or employment, or if any other information you provided to us changes. Upon our request, you also agree to provide us Updated financial information. I DEFAULT The following paragraph applies to borrowers in :da,",o, Kansas, Maine and South Carolina: You will be in default if you do not make a payment of the amount required when it is due. You will also be in default if we believe the prospect of payment, performance, or realization on any property given as security is significantly Impaired. The following paragraph applies only to borrowers in Wisconsin: You will be in default if you fail to make a payment when due two times,during any 12 month period. You will be in default if breaking any promise made under the Plan materially impairs your ability to repay what you Owe or materially impairs the condition, value, or protection of or our right in any'property you gave as security. The following paragraph applies only to borrowers in Iowa; You will be in default if you are more than 10 days late in making a payment. You will also be in ,default if you do riot comply, wtlhthe forms of the Plan and your, failure to comply materially impairs any property you gave as Security or your ability to repay what you owe under the Plan. The following paragraph applies to borrowers in all other states: You will be in default if you do not make a payment of the amount required when it is due, You will . be in default if you break any promise you made under; the Plan or if anyone is in default under any-security agreement made in connection with an advance under the Plan. You will be in default if you die, file for bankruptcy, become insolvent,; if you make any false or misleading statements In any credit application or update of credit information, or it something happens we believe may substantially. reduce your ability to repay what you owe. You will be in default it any property you have given us as security is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value of the property or our security interest in it. You will also be in'detault.under the.Plan if you are in default , under any other loan agreement with us. ACTIONS AFTER DEFAULT -- The following paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: When you are in default and after expiration of any right you have under applicable state law-to cure Your default, we can demand immediate payment of the entire unpaid balance under the 'Plan without giving you advance notice. Tile following paragraph applies to borrowers in all otlterstafes except Wisconsin and Louisiana: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have o demand for payment, notice of intent to accelerate and notice of acceleration. The following paragraphs apply to borrowers in all states except Wisconsin and Louisiana: If immediate payment is demanded, you will continue to pay interest until whatyou owe has been repaid at the applicable interest rates in effect or, if applicable, CPSr,101 PSECU FORM #3146 JUY,X0601-20374092-1 i6'06) LOAl LINER" Credit- Tnd_Security Credit AgLogLi cli (continuecl) rd the default rate J sdrzed on the AdJenrJuni. If t c ?rnarld f;r i ?n In, r.::;r e .t 11as been r r 1e, y'o!,r s arr.s and.'or dej,„r .. n e appl'. 1 I, .: mils ..'tat xr rs prov;ded A th3 socl;i n r.r r eJ ' cr:.,G y „e Carl ,.'oo cv ..cr u ,;s 'j L/ ,-lw r•n yo., '+G :I ;LA'I'J You n r.e t11e Credt U 1 ;"15 tt:e right to ta'r r cs e;swn ra any t r?:p,r'y , .eu is Security under the Plan. t •!Iiout judicial process, it tr s care h Ju c t r1c,lch rJ 0.c pea,o If r.., r..K. ,ou prur ise to ichver th property at a lnj place ::e chooso. I t?ie f ioprrty is a meter vehic'o cr bout. you agree that r.c will obtain a key or other do:ico necessary to unlock and operato it, -, hon you are in dcbtu!t We •ill not t resp i isi!,!e for any u'!.or proper y, 'irt w :d ;,,v i is Agrrorn t, '1 at you !oa e i aide the property or that is attached to the property 1/n e:ill try to return that property to you or make it available for you to claim. i After we have possession of the properly, wo can sell it and apply the money to any amounts you owe us. We will give you notice of any public disposition or the date after which a private disposition will be held. Our expenses "for taking possession of and Selling the property will be deducted from the money received from the sale. Those f costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded undor the Bankruptcy Code. You must pay any amount that remains unpaid after the sale money has been applied to any unpaid balance under the Plan. You agree to pay interest on that amount at the same rate as the advance, or, if applicable, at the default rate disclosed on the Addendum, until that amount has been paid. The following paragraph applies only to Wisconsin borrowers: When you are in default and after expiration of any right you have under applicable state law to cure your default, we may require immediatepayment of your outstanding loan balance under the Plan and seek possession of property given is security.You may voluntarily give the property to us if you choose, -or we hiay seek to take possession of the property by judicial process. If we repossess the property, you agreo to pay reasonable expenses incurred in disposing of the property. If the property is 'a motor vehicle, mobile home, buffer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted . by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains unpaid after the sale money has been applied to what you owe under the Plan. You agree to pay interest on any unpaid amount sit the same rate as the advance, or, if applicabio, at the default rato disclosed on the Addendum, until that amount is paid. If the property is located outside Wisconsin at the time of default, we may take possession of the property without judicial process, if permitted by the state where the property is located. The following paragraph applies only to Louisiana borrowers: When you are in default, we can require immediate ;payment (acceleration) of the entire unpaid balance under the, Plan. You waive anv riaht you have to dernand fnr payment, notice; of intent to accelerate and notice of acceleration. If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the applicable interest rates in effect unless a default rate is disclosed on the Addendum. If a demand for immediate payment has been made, the shares and deposits given as security for the Plan can be applied towards what you owe. We can also exercise any other rights given by law when you are in default and our rights under any security agreements you have with us. CANCELLING OR CHANGING THE PLAN,- The following paragraph applies; only to borrowers in Illinois: We have the right to change the terms of the Plan from, time to time after giving you any advance notice required by law. Any change to the, interest rate or other charges will apply to future advances. The following paragraph applies only to borrowers in Wisconsin:.Wo can ehango the terms of the Plan from time to time in accordance with Section 422.415` of the Wisconsin Statutes. You will be notified of any change in terms. An increase in the daily periodic rate under a variable rate interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the forms of the Plan continues whether you or the credit union cancel the Plan, except to the extent that your liability is limited by Section 422.4155 of the Wisconsin Statutes. The following paragraph applies only to borrowers in Iowa: We can change the terms of the Plan from time to time after giving you any advance notice required by law. A change, that increases the rate of finance charge or other charge, that increases the amount of your payments, or that otherwise adversely affects existing balances will apply to existing balances only it you agree to the change or you use the Plan after receiving notice that your use. of the Plan means you agree the change applies to existing balances. The following paragraph applies to borrowers in all other stales: We have file right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change in the interest rate will apply to future advances, and at our discretion and subject to any requirements of applicable law, will also apply to unpaid balances. The following paragraph applies to all but Wisconsin borrowers.-.An increase in the daily periodic rate under a variable interest rate is not considered a change in ,arms under the Plan. We can cancel the entire Plan or any part of the Plan at any ime. You may cancel the Plan at any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether lou or the Credit Union cancel the Plan. BELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay enforcing any of our rights under this Plan any number of times without losing the ty to cfcr. cur iq' , s Flo .;1 l yc„r i,,cirs Cr e191 fepfoscwat'.es If ',.e r'`•? 1 , 0-0 t 5 -"t i'r;r ,,'J ,rf,Ce that :11's Pla'i CONTINUED EFFECTIVENESS - .! ';0:J it 140TICE TO UTAH BORROWERS - !no agrecn•er, b_I::e.n ycm wit It:.. (.,e 1.1 0nirm s , ilttt i <.,Jr _;::ne t m;-'y niil be r aNtad:!_ c I i)l a Wt 1 ,i. ; f ary „r Ilse following is required by Vermont law - NOTICE TO CO-SIGNER.- YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. The following paragraphs apply if you give security in connection with an advance under the Plan.They apply to borrowers irnall slates except Louisiana, Louisiana borrowers will execute a separate security agreement. Borrowers in other states may also be asked to execute a separate security agreement. THE SECURITY FOR THE PLAN - You give us. what is known as a security interest in all property described in any receipt, voucher or other document you receive for an advance ("the Advance"). The security interest you give includes all accessions. Accessions are things which are attached to or installed in the property now or in the future. The security interest also. includes any replacements for file property which you buy within 10 days of the Advance or any extensions, renewals or refinancing of the Advance. It also includes ai,y money you receive from selling the property or from insurance you have on the property. If the value of the property declines, you promise to give us more pioperty'as security if asked to do so. WHATTHE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS - The security interest secures the Advance described in the receipt, voucher or any other document you receive at the time of the Advance and any extensions, renewals or refinancings of the Advance. It also secures any other advances you have now or receive in the future under the. Plan and any other amounts or loans, including any credit card loan, you owe us for any reason now or in the future, except,any loan secured by your principal residence. If tho property is household goods as defined by the Federal Trade Commission Credit Practices Rule, the property will secure only the Advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY - You promise that you own all property you give as socurity or if the Advance is to buy the property, you prornise you will use the Advance for that purpose. You promise that no one else has any interest in or claim against the property that you have riot already told us about. You promise not to sell or lease the Drooertv or to usn it aS ;nm irity fnr a In: n with ,nether creditor until 'he Advance is repaid. Yv promise you will ideuVY ile uthei suuurlly interest or lien to attach to the property either by your actions or by operation of law. PROPERTY INSURANCE, TAXES AND FEES - You must maintain property insurance on all property that you give as security under the Plan. You may purchase the property insurance from anyone you choose who is acceptable, to the Credit Union. The amount and coverage of the property insurance must be acceptable to us. You may provide the property insurance through a policy you already have, or through a policy you get and pay for You promise to make the insurance policy _ payable to us and to deliver the policy or proof of coverage to us if asked to do so. If you cancel your insurance and get a refund, we have a right to the refund. If the property is lost or damaged, we can use the,insuranco settlement to repair the property or apply it towards what you owe. You authorize us to endorse any draft or check which may be payable to you in order for us to collect any refund or benefits due under your insurance policy. You also promise to pay all trues and fees (like registration fees) due on the property. If you do not pay the taxes or fees on the property wlien due or keep it insured, wo may pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the advance and you will pay interest on those amounts at the same rate you agreed to pay on the advance. We may receive payments in connection with the Insurance from a company which provides the insurance. We may monitor our loans for the purpose of determining whether you and other borrowers have complied with the insurance requirements of our loan agreements or may engage others to do so. The insurance charge added to an advance may include (1) the insurance company's payments to us and (2) the cost of determining compliance with the insurance requirements. If we add amounts for taxes, fees or insurance to the unpaid balance of an advance, we may increase your payments to pay the amount added within the term of the insurance or approximate terra of the advance. INSURANCE NOTICE - If you do riot purchase the required property insurance, the insurance we may purchase and charge you for will cover only our interest in the property. The premium for this insurance may be higher because the insurance company may have given us the right to purchase insurance after uninsured collateral is lost or damaged. The insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. PROTECTING THE SECURITY INTEREST - if your state issues a title for the property, you promise to have our security interest shown on the title. We may have to file what is called a financing statement to protect our security interest from the claims of others. If asked to do so, you promise to sign a financing statement. You also promise to do whatever else we think is necessary to protect our security interest in the property. You promise to pay all costs, including but not limited to any attorney fees, we incur in protecting our security interest and rights in the property, to the extent permitted by applicable law. LOANLINER" Credit and Security_Crerlit ?l?recrrtcnt (continued) USE OF PROPERTY - Um;l the Advance has been paid o!f, you promise yc)u :,I:i: (1) Use the property Carefwly and 'trop t n gc,od repa!r. (2) Obtain r;ir permission b,=Lre marking n:aior ehange3 10 :I:e prrpcriy or changing ti ..:cJcir:._s .%here :!',e plop;:Ny is kefd. i:±) ini:,rm us In antis, before cl:..nging year ad'lrc_, t) 11!0:: us to Inspect 1ho pro(',eity. iE.) Frompt'y nr-):dy us if the prop?rry is dar:vt ;:..1, stolen or abusod.-056) Not use Vio picp> -ity fcr any un!av.ful purpose. (7) Not to rcltin property in anr.lh!:r state c.-ithout liil'ing us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A h10TOR VEHICLE - F HE MOTOR VEHICLE IN Tins TRANSA.GIION t.IAY CE :SUBJECT -0 REPOSSESS10H IF IT !5 REPOSSESSED AND SOLD 10 SOUIEGNE ELc:;E, AND ALL AMIGUNTS DUE TO THE SFCUHE.u PAkTY Afif- NOT HECEIVFD IN THAT SALE, YOU M." HAVE FO PAY THE DIFFERENCE. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to foil to return a motor vehicle that is subject to a security interest, within thirty days after you have received notice of default. The notice will be mailed to the address you gave us. It is your responsibility to notify us it your address changes. The maxintunt This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. You are advised to read your monthly statement and review it for any error discrepancies or unauthorizod transactions. .NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT. If you think your statement is wrong, or if you need more information about a transaction on your statement, write us on a separate Sheol at the address listed .on your statement. You are required to notify us in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized' transactions on your account. Failure to notify us rnay result in your acceptance of any responsibility for payment or. reimbursement to us for any such error or discrepancy on your account. Write to us as soon as possible. You can telephone us, but doing so .will -not preserve your rights. In your letter, give us the following information: Your name and account number. The dollar amount of the suspected, error. Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are not sure about. If ynrt have author17P11 rig to n.ty a credit card account automatically from your stare account or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us three business days before the automatic payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the statement was correct. In this Agreement, the words you and your means each and all of those who apply for the card or who signs this Agreement. Card means the Visa Credit Card and any duplicates and renewals we issue. Account means your Visa Credit' Card Line of Credit account with us. We, us, and ours means this Credit Union. 1. RESPONSIBILITY -If we issue you a card, you agree to repay all debts and the Finance Charge arising from the use of the card and the card account. For example, you are responsible for charges made by yourself, your spouse and minor children. You are also responsible for charges made by anyone else to whom you give the card, and this responsibility continues until the card is recovered. You cannot disclaim responsibility by notifying us, but we will close the account for new transactions if you so request and return all cards. Your obligation to pay the account balance continues even though an agreement, divorce decree or other court judgment to which we are not a party may direct you or one of the other persons responsible to pay the account. The cards remain our property and you must recover and surrender to us all cards upon our request and upon termination of this Agreement. 2. LOST CARD NOTIFICATION - If you believe the card has been lost or stolen, you will immediately call the Credit Union at (717) 234-8484 or (800) 237-7328. After hours call (800) 556-5678. 3. LIABILITY FOR UNAUTHORIZED USE -You agree to notify us immediately, orally or in writing of the loss, theft or unauthorized use of your Credit Card. You may be liable for the unauthorized use of your Credit Card. You will not be liable for unauthorized use that occurs after you notify us of the loss, theft, or possible unauthorized use. You will have no liability for unauthorized purchases made with your Credit Card, unless you are grossly negligent in the handling of your Card. In any case, your liability will not exceed $50. 4. CREDIT LINE - If we approve your application, we will establish a self. replenishing Line of Credit for you and nobly you of its amount when we issue the card. You agree not to let the account balance exceed this approved Credit Line. Each payment you make on the account will restore your Credit Line by the amount of the payment which is applied to the principal. You may request an increase in your Credit i i pCM Iy fJr L. 1 a'., fcl fa; I ore to iC;..111 a file i %e 11, C, i .'i j .('.n i7n$an Iin,i. U( 1 j fine of 5150,000. For those members who purchase a vehicle under the DRIVe Program, please review the following FTC Notice: NOTICE ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to send statements to you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit limit. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your statement that are not in question. If we find that we made a mistake on your statement, you will not have to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make Up any missed payments on the questioned amount: In either case, we will send you a statement of the amount you owe and the date that it is due. If 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 to pay, we must toll anyone we report you to that you have a question 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 can't collect the first $50 of the questioned amount, even if your statement was correct. SPFCIAL RUI.,F FOR CREDIT CARD PL)RdHACFS - It }mU have a problem with the quality of pluperty of surviuus that yuu puicllasud with a urudit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the property or services. There are two limitations on this right. (a) You must have made the purchase in your home state or, if not within your home stale, within 100 miles of your current mailing address; and (b) The purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or services. Line only by written application to us, which must be approved by our credit committee or loan officer. By giving you written notice we may reduce your Credit Line from time to time, or with good cause, revoke your card and terminate this Agreement. Good cause includes your failure to comply with this Agreement or any othor agreement with us, or our adverse reevaluation of your creditworthiness. You may also terminate this Agreement at any time, but termination by either of us does not affect your obligation to pay the account balance. 5. CREDIT INFORMATION -You authorize us to investigate your credit standing when opening, renewing or reviewing your account, and you authorize us to disclose information regarding your account to credit bureaus and other creditors who inquire of us about your credit standing. 6. MONTHLY PAYMENT - We will mail you a statement every month showing your Previous Balances of purchases and cash advances, the current transactions on your account, the remaining credit available under your Credit Line, the New Balances of purchases and cash advances, the Total New Balance, the Finance Charge due to date, and any other billed fees, and the Minimum Payment required. Every month you must pay at least the Minimum Payment within 25 days of your statement closing date. By separate agreement you may authorize us to charge the minimum payment automatically to your share or checking account with us. You may, of course, pay more frequently, pay more than the Minimum Payment, or pay the Total New Balance in full, and you will reduce the finance charge by doing so. If your monthly payment exceeds the total credit line balance owed, we will automatically post the credit to your Si shares. The minimum payment will be (a) 2% of your Total New Balance, rounded up to the next even dollar, or (b) S20.00, whichever is greater. In addition, at any time your Total New Balance exceeds your Credit Line, you must immediately pay the excess upon our demand. We will apply payments in the following manner: first to previous late fees, then to previous cash advances finance charges, then to previous purchase finance charges, then to current late fees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. Visa' Credit Carcl regiment and Truth In Lending Disclosure (continued) 7. FINANCE CHARGES - Yo;r can a.oiJ the Finance Char, a ur rurc! az Li r;"ig the full amount of tt-.e Nevi + al; n Jf Purc 1 , r s -1 t mc.ntn 5 da"'; then statenr.nt cla; nq r; ,e U', i_r. r f•,_,, L . ar,. c1 Pur, ,n;l ,sequ.rJ pw'-'hases from t . r;,t,c , ./... {,,, •.er,. ,..,,; t .'I e s t to fiance Charge. Cash adv nr s afe 0, ,;,s ,,.t. act to I ar,rco C far,, foci tl,o IWO they Cite pool d to ,oL.r iccuh rt. Purchases We cair ul rt yr r r r t rr 0 ago L y III; tiplyayJ Viu? ,;v r t e ;ci;u ;d daily balance (see expl., union bcloFv), I,n,luc,;,ty nr_,r purchn„os, for ;!ie bilking cyr l:; by Pie rttonthly periodic purCL,i,se late and corn, porii1nq ANNUAL PERCENTAGE HATE as disclosed on the Addendum. Cash Advances: Wr, ca culate your finance chargo on crash tdv t :'.s Ly rnultiplying the average adiustud daily balance (sue explanation below) for ,ash j advarces during the billing cycle by the monthly periodic advance rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on Ilia Addotidurn. Balance Computation Method Average Daily Balance for Purchases - The Average Daily Balance for Purchase f "Transactions is calculated by adding the Daily Balances (Purchase Transaclion) for each day in the billing cycle, arid then dividing by ilia number of days in the billing cycle. To calculate the Daily Balance for purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day in the billing cycle. This gives us the Daily Balance for purchases. Average Daily ailance for Cash Advances - Cash Advance Transactions which are posted to your account are not included in the Average Daily Balance calculation for purchases, and are therefore not subject to the monthly periodic rate foe purchases. The• Average Daily Balance is calculated separately for Cash Advances and is subject to the Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions is calculated by adding the Daily Balances (Cash Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for cash each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of.all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Thrin Wa alsn Ruhtrarl thin arnmint nr any Purchase Transactions that poctc'4 t^ you account on that day or in any piuvious day in the billing cycle. This gives us the Daily Balance for Cash AdvancoTransactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account. Payments are applied in the following manner: first to previous late fees, then to previous cash advances financo charges, then to previous purchase finance charges, than to current late foes, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. Credits are applied first to the particular type of debt which is being credited, if any, and then to the balance of your account. Note also that if the total of ilia payments and credits which are posted to your account by the Payment Due Data shown on a statement is equal to or exceeds the New Balance shown on that statement, we will not apply the Monthly Periodic Rate to your Account on your next statement. 8. DEFAULT-You will be in default if you fail to make any Minimum Payment within 25 days after your monthly statement closing date. You authorize us to transfer funds sufficient to make the minimum payment due if your Visa loan is in default. You will also be ill default If your ability to repay us is materially reduced by a change in your employment, an increase in your obligations, bankruptcy or insolvency proceedings involving you, your death or your failure to abide by this. Agreement, or if the value of our security interest materially declines. We have the right to demand immediate payment of your full account balance if you default, subject to our giving you any notice required by law. To the extent permitted by law, you will also be required to pay our collection expanses, including court costs and reasonable attorney fees. 9. USING THE CARD - To make a purchase or cash advance, there are two alternative procedures to be followed. One is for you to present the card to a participating Visa plan merchant, or another financial institution, and sign the sales or cash advance draft which will be imprinted with your card. The other is to complete the transaction by using your Personal Identification Number (PIN) in conjunction with the card in an Automated Teller Machine or other type of electronic terminal that provides access to the Visa system. You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. The monthly statement will identify Ilia merchant, electronic terminal or financial institution at which transactions were made, but sale, cash advance, credit or other slips cannot he re!..,rned th t'-a re,,t r u ;! r t n a c , y s.j fern snei it tl.o Gr of the transaction in crier to vcr ly t. -1l .,lily rare, t I o Crec. t Ur'C.ttn.-y m1.,, a rcasonah;'e I"Irge fur f i t t , !c {r 1. j 10. OVERDRAFT OPTION - If ,,.,r . ecl u t ..1 i r r _.ECU -.a Cr,r'JI! and the cwr -i Ian p !i y t, r: t, r :I , v J'rs J r t t t ! ? ov rd art V:ih L r n.,i J rr J t:o tat r 'I r h r u ,„ r f ?LCIJ Vi 1 r,;e?Ll CavJ ,.^d th,,t 6r. c'..rter t u njai i'.'rc, r.1t J F r k r•s Vail y v 11. RETURNS AND ADJUSTt TENTS - f r ! u , t .J ?I ri v. 117 honor ,I c-;r:i may give credit for rc ttr s and a.l{.,. t t en,,, <.r 1 t t y ,:ll (k) ..o i:y s(,•nding ,s a Cre't G n-, i t] yc,,r Visa ine of aeoll it your r rr tit ano paymews exceed oat you 0:ve us, vie viol au:ort t ici0y pool the ex(,r s. cnrdit bal:mce to y'GUr :.it Shales within r:) clays. it 0) o balance is nne, rlr,llnr r,r worn, upi111 your Vrntlen request, we will re'und the cred,l ba!;mcn Ic you 12. FOREIGN TRANSACTIONS - flto exchange rate between the transaction currency and the billing currency used for processing international transactions is a rale selected by Visa front the rany0 of rates available in wholesale currency markets for the applicable central processing date, which rate may vary from Ilia rate Visa itself receives, or a government-mandated rate in effect for the applicable central processing date. In each instance, an adjustment may be assessed based on the ISA fee imposed by Visa. This fee, which totals I of the transaction amount, will be assessed on all transactions where the merchant country differs from the country of the card issuer. 13. SPECIAL RULES FOR VISA PURCHASES - If you disagree or find an error with a Visa transaction, and have tried. Ili good faith to correct the problem with 1110 merchant or the charges are the result of unauthorized or fraudulent use, or your purchase cost more than $50 and was made from a plan merchant in your state within 100 miles of your home, contact PSECU. 14. DISPUTED TRANSACTIONS -You are required to notify PSECU in writing within 60 days following the data on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transaction on your account. Telephoning PSECU does riot preserve your dispute rights. You may be required to provide us with documentation to support your dispute claims. In addition, you may be required to complete a standard dispute form outlining the details of your dispute. In cases of fraudulent card use, PSECU will also require a notarized affidavit. In some cases we may ask you to notify the local authorities. If we do not receive the proper requested documentation in ilia time specified, you may be held responsible for the transaction(s) in question. PSECU must adhero to strict dispute timaframes sat forth by Visa. 15, SECURITY INTEREST - To secure your account, you grant us a purchase money security interest undnr thin Ilnifnrm Commorcins :ode in any goods you I purchase through the account. if you dufauft, wu will have the right to recover any of these goods which we have not been paid for through our application of your payments in the manner described in the Monthly Payment section. With respect to this account only, we will riot assert any statutory right we may have if you are in default to prevent withdrawal of your unpledgad credit union shares (Deposits) below ilia unpaid balance of your account. However, if you give or have given us a specific pledge of your credit union shares (Deposits) by signing the Pledge of Shares or otherwise, or any other security interests for all your debts, your account will be secured by your pledged shares (Deposits) and by the property described in those other security agreements, except for your home, 16. EFFECT OF AGREEMENT-This Agreement is the contract which applies to all transactions on your account even though the sales, cash advance, credit or other slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance written notice required by law. Your use of the card thereafter will indicate your agreement to the amendments. To the extent ilia law permits, and we Indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. 17. LATE PAYMENT CHARGE - If your Minimum Payment is riot received by the first day of the month following your due date, you will be subject to a $20 charge. 18. RUSH. FEES -You may incur additional charges for rush processing and rush delivery of cards and/or PIN mailer. 19- OVER LIMIT FEE -A $20 foe will be applied for each monthly statement closing ditto on which the outstanding balance exceeds the assigned credit limit by more than $100. 20. DRAFT COPIES - You may incur an additional charge for transaction summary/sale draft documentation. 21. COPY RECEIVED - You acknowledge receipt of at copy of this Agreement. 22. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will riot use your card for any transaction that is illegal under applicable federal, state, or local law. 23. NO USE - Inactive Visa accounts that have no purchase or cash activity (nay be closed without notice to you after 18 months of no activity. 24. NEURAL NETWORK - PSECU uses neural network systems to predict and prevent. unauthorized transactions. There may be occasions when a transaction is declined because it is indicative of possible fraudulent activity. Ci :1 rn O o t n r . o n ° r ? r F • f C') (7 f ( . J (! ("J C`+ 1 .- ' (O .) • i (•, ? ( I) J V I' i 1 I ' N J E o y C_u C> O O <? t7 0 0 U G ?' -, o r c> o G r7 r) n n o u o t? ) o tog li ni 11 4 i r n n u , y` r N g . ? , E• lJ G o o r,) ;7 O EJ O - -1 -? T O O J - ,, c U J l) S ' O U f1 C r ) r :> o C) C 4 C.>O ()O. 0 C'n C) ? 2 GC_lO Qt7 C7O[? - - u , u1 w( 1 41 )? ) f i) ) u? ) ) c) I : F•- l.) Z ? O rJ C] O o0 t7 o r7 t7 ) O C)._ ) O.l. O O v -n n. tJ OU Ov,no • n Mi (•+ ( N E > i ) ? ) ) J ( , i- a f r? E n) ci , t (,. E LLl _(] n . r:. CJ. 4o h. r ? o ?) N .- ? .- •-- '- •-- ._ .- CJ (T CJ h. Y) u> •'r M C J !J (? ° N C - n lJ .. ) v) ? ) ` I n) N ) ) I? 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L?rl f".S I r; D'JLT SLATUS 77 BODY TYPE EUP _FA.i C,.-i' F-F 7 I f :, c ? ?h I I a 1 12/12/06 I I 6/74/07 0111-ADlSl viorFiT I,V4lR frvfr{ TITLE BRANDS €.,f DATE PA TILLED [)ATE OF 13SUE L \..; nEGIS'TFRED OwNER(S) . NATHAN LIDDICK 466 DAVIS ST `a! HARRISBURG PA 1,7109 i IREI t r? I r• ?11y. F-ni61 I IEN FAVOR Or: • s?r-.. NI' n. e+r Tar SECOND LIEN FAVOR Olr: ODOIAFTER SI'ri EELS n : ACTUAL huLEi•.CE I = I.M.1_AGE EXCEEDS THE MECHANICAL LIMI rS NOT TIIE ACIUAL MILEAGE :1 = NOT THE ACTUAL l.IltTM;F:-OD01jrTF:n T.ANIFERxIG VERIf"II--.D 4 = EXEMPT FROM ODOMETER DISCLUSURE THL[ BRANDS A ANTIOUE.VE"ICLE C. CLASSIC VEHICLE D = COI.I.ECTIME VEIIIGLE F OUT OF GCU!4TIY G eORIGINALLY. 141110, FOR NOW U.S DISTTUau ROW H 5 ArnICLH.TuRAL VEHICLE L - LOC;'114 VEHICLG P = ISIWAS A POLICE VLI IICI C It RECCIN. TR ICTED ; S InErT floe T nECOV.ERE D THEFT vrHlcl r V VEHICLE CONTAINS V S;ttM D VIN W FLOOD lEHIC I X - IWAS A TALI I L 1 ? •- - If a sormid flonixrldor is listed ujim siilulrlcalon. ul Ihn t,n l n, the fl,0 - ILonhnhfor roust forward this I IIM to Iho nnrea, rd FA Nor Vv I id- Ilh Ihn A - f r ! v I ,, FIRST LIEN nFLEASED_..? tyrlunlxlalo fall., tux! Inu. i r-' DATE - ; rrr111III SECOND LIEN RELEASED ALI FfORIZED FlF I1[IrSFN TAT'IVF D E j > _ . MAILING ADDRESS fly__ AT e AEl'I' orvED nErnFSCNTATIVE 'I PSECU i W. P 0 BOX 67013 O HARRISBURG PA 17106 1" l a4?? x ny T ? ° r?h ALLEN D "BIEHLER I I codify as of ale dots of Issue, the official recoils of Me Penct;ylvanla Dolmarn:nl of Tran"llaliun fallact 4xd file person(s) or company named hereto is Illo lawful minor } of vie sam rchMIo. Scerwfary of Trln.9mortatiinr d ?? 6-7L il'I I 1 {MI6 1 II CII ')II?°I t14? I-I0iil) dIBSCnIGED AND swonN If a co-purchaser other than your spouse is listed and you want the We to be listed as "Joint Tenants With Flight of Survivorship" iOn dctatlt.ot ono FORE ME: reD. DAY WAIT owner, title Hoeg to surviving Owner) CHECK,HtFiE ?. Otherwise, Iha`title " ' wi11 bo issued as "Tenants in Common" (On death oP one oivnor" interns] of or floes to his/her heirs or, estate). . deceased own SIGNAWrIF OF PRISON AlY.AINISTMING OATH 1sT LIEIJ DATE: --O' IF NO LIMN, CHECK, L JI ! IST LIENHOLDER STREET CITY STATE - 'LIP IF THIS IS AN FLT, CHECK HERE ? FINANCIAL.r NOTE: FIN Rfi0U1HED I14S7ITUTION NO. Tta u ws:?neJ h-o/ ,r..d:bs af.u:eCCn for G:r56pt. cl Tn:o W u a a4.iCa tlaco: a'.e0 al:o:. ,9.:1 m as u:wm?a-.:es ard o:n,,, :o,n c,..,. ? wn„ Acre. OF %=LIC:,•:T AA:.JTHZZ I:_0 S,,,%-ES 2ND LIEN DATE: -- IF HO LIEN, CHECK 2ND LIENHOLDER STREET la CITY STATE ZIP k?} -- ' IF TI !5 15 AN' ELT, CHECK HERE ? :!NV!--IAL ' A a.a h*....? OF Ce.. ,}u.:• .; T47E CF AJ1,;D.:._s S,Gf:FA. NOTE: Flit RFOORED It:;-ITUTION NO. ...., .. ..., .. ... ......... ...... ..... ..... .... .... .... ? .., ,..... ... .., ,.-....,. ., .. .... .. ,-_..., ..., Lam:-. ,?., .,.,. (i `( 11 -. . (c. J i(i S j -- ire I -",f• . I:i r, . 1, _•?J (ic.., :r I u.i i 41?il el,J fci ilia LJ. 1 I lr G ?fl' ? ?`) v t?t : \ ?? l=1 ' ? a -I ^ I r-. ?. U I -+ r 1 . -1 F .T I I ?.E I? + I t i I I HF I :R ri -- - C cF,S:.I f' F,'.iLUP'E i t . I: _ I 1 CR (? I AFALSE S I Eil_7 A R_SULT P; ISC 1 . I ^v ?:: .:._ ... - O I- In D i ( ' , L? ; r r T :....; ('Ai I I , .- o? l - - - TU AND C11 HA •? F f,'.IJST CO ? [-) i- J 1 DPr.pll it,,; 1 IiF;rF _._-- J r I cr; UREOf fltit rn S CI 1(IU fQF CC) 1.IIFI7 - - - -- ?SELLER nND oil C ? SEI LEA MUST HANDPRINT NAME I ICRC l '? r T . t l ?n r J')r 3. t t w. t°-9-J'I Tt;,1 C,(If I ( !!rt I) j5??11?. d I {I`1) 4 d? Si ?1?-Sll?-t t J (.r ?. '??^1r- l ll . Y.a..S:' t_.m?.,- .L + `I'rk n ?j N?T t "x I ^" 7y" 1 ?ri+,.{ o`r,al?L ,.nF(erfT3rF;,•ti?SJ`r ?Yyr rl(.... 2..: r ?.'r. .I.. I.! 11: ? .UJSI t."5?:?.. tl.. _A,...I..c...L.?,ri.rtl .3: i -L.'uS?:tr"ii::{?•'• rrrtily, to The best of my.'onr I:navAe!Ir: 111.1 the. c n9 wh lnn xaor rraduv1 is I;W/e n:nT: to LAST r MST M.I. %\ milts and raflrrlc the actual mileaga of the mthicle, > -- - PIIRCIIASFI7 On PULL auINr:SG n1n+aE unless am of the following bores is cLau;l:od: LI II )l (loflocts the amo unt of rnlluago is NOT the actual mdcayc U CO PJI ICI IAorm --_-- -- in in ercens of 115 ntcv:hauical limits WARNING: Odonlolcr dLtl:mpanry ST11F.E7 - ---------- - 4Wu IuillnxcmlNy Ilia] the Ytillldi is free of any orcmnbrance and that Ihn ownership is hereby l :f d t th Ih l d W d ADORSS -- ------------• - ran: erm o o person(s) or o ea er c . - __-__.-____--_. ---------- - SUB!;cRIDED AND SWORN CITY ------- - -------- -- - TO BEFORE ME: -- - ---- PUnc IAISE PRICE - SrATE ZIl' H1O. DAY YEAR OR DIN 51 'NATUnI OF I Lli ( f ' 1 Nl A IRIIJl57 CnUlG C1Alll PLJilCIIA,ElI SIG A rU) IF _ _ _ _ COPIJn(:I IA.^,E1151r,NA1'tll ll: ,cE CO-PURGI-IASER MUST - LU HANOPRjN(NAMFI InF__-- .- UJ GI l I OF SF_r_ .. _ _- SELLER MUST ( IIANIX'RINT NAME I IERE pp( y/ (y - L u ? ?tl f)W ,(}. ::? :,?L a tl ' LY.. ITW- 11 1!Z' a "W,. corlFly. In lfte best d mylour krwwdedry: that Iho omkenotor mrkis LnST Flf iST M.I. f TENTHS . >< mllos rind relloclo Ilia actual mileage of the Vehicle. PkincilliGI-Al oil 1,011. . IJ1151NESS NAME - - -' -' unltes a,%, of Th.. follo virr) bgxuc is chocked: ------------"-`--• - Re(Ixls tiro mnornd. of nrilaano It, NOT The actual mileage U I? CO-PUI CHASFII 6t eurrss (if its maditnrical limits WARNING: Odometer discrepancy --7 STREET 11Wo timber carlity Oil] The "hicae is iroo "[any ewumbraa:e end that Ilia rtwnorshil) is hereby Iran.,Aotred to tire or ;o (o) or the doalur li ted AnOrtFss -------- - p . . n s --- --- - - - SUBSCRIBE=D AND SWORN CITY - --------- TO BEFORE ME: PurK iA'E ('111011 tirA7E ZIP DAY YEAR Oil DIN _------.91GPIATUIIE OF EHSON A1 1MI141S IIING OATU _--'--- P1111CRASfn SK;NATI[w . GOPV lCj .FIA'jUj LIONARIHE J - PURCHASER ANWn CO PURGI IASER MAST LN HANOPRINT NAME HERE C!) SIONATURr OF RELI_Fn - - SELLER MUST HANDPRINT NAME HERE ; i 71"?Fi.l,l ri`` l i'f ?' g o 1I ?."; . (; ' IAA cenily, to the bust of my/au I.nov:kidgP. Thal the of]omemr reading is TENTHS - LAST FIRST M.I. X miles and rcgec]s Rio actual mieage of the velridn, - r - - -- PURCKNCL4ISER OR FULL BUSINESS NAME - - - wilrss one. of The lollov,Ying bores is checked: '-- F? Rcllocts Ilia amount of miluaijo f ?1 Is NOT Ilia actual mileage U CO PUnCl IASER _ - ki arcrss of its machrmL^al links I-I WARNING: Odometer discrepancy STRECT ---- IA:Va Further cer6ly Ihat The vehicl:) is Ifee of any encurnbrn co and Rtat the mmamhfp is hefcby Ir -J d i lh Ili d k li t d AOnRESS - a arre o a parson(s) or a oa <r s e . ------- ---------- -- ------- SUBSCRIBED AND SWORN CITY TO BEFORE t:•IE: PJRCHA-..L PRICE STATE ZIP ta0. DAY YFAR on Oin I., r SlGtdnTU?c__•F PERSON A(iVI P.STERVJG CATH P•JIICHASFR SIGI•VTURc CO-PURCHASER SiGNATLME J I <C I PUR-HASEn AND6;OR GO-PJF,CibIZ-ER 4UST UJ H.1_1L7PiF1T!. IAF,JE HERE cn ? SELLF R %'U---T - I - H4f:'?•R7iJ-Idfi?c flEilE IK O .r r. } 1 L.,.rn lit I-t,i U .': I II'I Li. 17.]11) (A)],, T-I r- JFYlr)rj 1') '1 Ill lidi; 1 t4:I-S S CD m (n N m a N w CD Cl CD m W tD tT 3 CD -o ro 7 N .L W 7 A) N m 0 0 w a M N O m f ra a c n C N rn CD ro w m rn w D cl U) fU ro N .6 ro N 0 U) N D7 m N O =_ m rn (!J 7 Iv L= m 7 (DU 0 C.i O PSE( 02/26/2009 Via Certified and First Class Mail NATHAN LIDDICK 406 DAVIS ST HARRISBURG, PA 17109-4019 NOTICE OF REPOSSESSION AND RIGHT TO REDEEM You are hereby notified that your 2006 BMW Mini Cooper VIN# WMWRE33586TL23413 has been repossessed by the Pennsylvania State Employees Credit Union ("PSECU" ). You have failed to pay the 09/21/2007 installment due under the above Loan and Secuirty Agreement (the "Contract"). The motor vehicle is currently being stored by: Richard & Associates, 3999 Spring Rd. Shermans Dale PA 17090. (717) 241-5884. You may redeem the motor vehicle and terminate the Contract by paying the following amounts on or before 5:00 p.m. on 03/13/2009. Unpaid principal balance $29,163.49 Accrued Interest $3,438.45 ADDITIONAL COST IF REPOSSESSED MORE THAN 15 DAYS AFTER DEFAULT Repossession Expense $350.00 Storage expense @ $20 per day (2/24/09-3/13/09) $360.00 Late Fees $347.10 Total Cost to Redeem $33,704.04 Payment to redeem must be in cash, certified funds or a cashier's check. We will sell the 2006 BMW Mini Cooper at private sale sometime after 03/13/2009. The money that we get from the sale (after paying our costs) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get more money than you owe, you will get the extra money unless we must pay it to someone else, or use it to pay other loans you owe to PSECU. You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. If you want us to explain to you in writing how we have figured the amount that you owe us or you need more information about the sale, you may call us at (717) 234-8484, ext. 3116 or (800) 237-7328 or write us at PSECU, P.O. Box 67013, Harrisburg, Pa. 17110-2990, and request a written explanation. You should also contact us if you are unable to pay the foregoing amount in full prior to the above deadline. PSECU mav allow you to reinstate your loan, if you qualify, upon payment of the arrears and additional costs only. We are sending this notice to the following other people who have an interest in the collateral listed or who owe money under your agreement: (Names of all other debtors and obligors, if any) You have 30 days to make arrangements to take possession of the personal effects found in the vehicle. Failure to recover them in this time period will result in disposal of such personal effects. Jodie Ross Account Advisorpennsylvania State Employees Credit Union Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 - 717.234.8484 - 800.237.7328 Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 - 717.777.2100 (TDD) - 800.472.1967 (TDD) V7ff psecu.com This credit union is rederally insured by the National Credit Union Administration. Equal Opportunity Lender C1 O ?? a -' o m O ?? L ? ' m m o m' > C ? m a _cr a: 0 O } c O W ? ? d x m d u ru , ?I C3 m (mU? ® i N Q M ? E L T m Y C E 1.0 I l /? -~ v m ? a w = E"" E -o r? f6 ? ? N O - ? W U E?oc A! c 0 ?I m VJ Q ?i ?r cC t - H m Z K yQ 0 Q O _a m a E a 9 N (0 U - co co ch LL 8/ 0L 606 II -?? oz o a ^' r- `'?M I ? ? ? G E-' srI - ? ? ., • ` L L r - cy la, l f - .• ci c i c rl ? - .n Fc c i ???? Lr-r c rrnnn nrrca hnw. F ILE0-J F i4 ;p• 201 1 FEB 23 PM 3: PEHNSY `.AIM ' BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NATHAN LIDDICK, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 2011-778-Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned action. BARLEY SNYDER LLC Dated: 1 zl?/? hawn M. ng, Esquire Attorneys or Plaintiff Pennsylvania State Employees Credit Union Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 3133532 SHERIFF'S Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OF CUMBERLAND COUNTY IFF FILED-OFFICE OF THE PROTHONOTARY 2011 MAR 25 PM 2: 42 CUMBERLAND COUNTY PENNSYLVANIA Pennsylvania State Employees Credit Union vs. Nathan Liddick O FICE Case Number 2011-778 SHERIFF'S RETURN OF SERVICE 02/24/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Nathan Liddick, but was unable to locate him in his bailiwick. He therefore deputize the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint and Notice according to law. 03/17/2011 05:39 PM - Dauphin County Ret Dauphin County, Pennsylvania, Complaint and Notice, upon the himself personally, at 406 Davis handing to him personally the sa SHERIFF COST: $37.00 March 23, 2011 is And now March 17, 2011 at 1739 hours I, Jack Lotwick, Sheriff of hereby certify and return that I served a true copy of the within thin named defendant, to wit: Nathan Liddick by making known unto reet, Harrisburg, Pennsylvania 17109 its contents and at the same time true and correct copy of the same. i ^I Soon?,Suite She off. -.ehos,; !j In::. SO ANSWERS, RON R ANDERSON, SHERIFF Of the ?$I?-vrff William T. Tully Solicitor • Dauphin County 101 Market Street larrisburg, Pennsylvania 17101-2079 : (717) 780-6590 fax: (717) 255-2889 Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS NATHAN LIDDICK Sheriff s Return No. 2011-T-0754 OTHER COUNTY NO. 2011778 And now: MARCH 17, 2011 at 5:19:00 PM served the within REINSTATED COMPLAINT upon NATHAN LIDDICK by personally handing to NATHAN LIDDICK 1 true attested copy of the original REINSTATED COMPLAIN and making known to him/her the contents thereof at 406 DAVIS STREET HARRISBURG PA 17109 Sworn and subscribed to before me this 21 ST day of Marc A ? COMMONWEALTH OF PENNSYL` Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin Count, r Commission Exnires August IT 2 So Answers, 2011 ?4 Sheriff >< ?" ., • g? MANIA Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $58 2/28/2011 No. 2011-778-Civil Term ICE 1 ':'1Y 17 Al 10: 2. U BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NATHAN LIDDICK, Defendant r: UIIBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff Pennsylvania State Employees Credit Union COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 2011-778-Civil Term PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Nathan Liddick, for want of an answer in the amount of $22,385.69 plus costs of suit. (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( ) Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. 3215276 OAf$ //4 6po'af?l LAW? fymtc- Wl???l No. 2011-778-Civil Term (X) Pursuant to Pa. R.C.P. 237. 1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: dt, BARLEY SNYDER LLC By: Shawn M. Long, Court I.D. No. 8 require 74 Attorneys for Plaintiff, Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602 717.299.5201 NOW, , 2011 JUDGMENT IS ENTERED AS ABOVE. Prothonotary/Clerk, Civil Division By: J9 , Deputy S 3215276 No. 2011-778-Civil Term BARLEY SNYDER LLC Shawn M. Long, Esquire Troy B. Rider, Esquire Court I.D. No. 83774; 206319 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NATHAN LIDDICK, Defendants COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 2011-778-Civil Term To: Nathan Liddick 406 Davis Street Harrisburg, PA 17109 Date of Notice: April 11, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, 3191853 No. 2011-778-Civil Term 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 A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 BARLEY SNYDER LLC Date: April 11, 2011 By; Shawn ong, Esquire Troy. Rider, Esquire Attorneys for Plaintiff Pennsylvania State Employees Credit Union Court I.D. No. 83774; 206319 126 East King Street Lancaster, PA 17602 717.299.5201 3191853 No. 2011-778-Civil Term BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NATHAN LIDDICK, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 2011-778-Civil Term AFFIDAVIT OF SERVICE Colleen Brelje, Paralegal, doth depose and say that she served a true and correct copy of the 10-Day Default Notice upon Nathan Liddick, 406 Davis Street, Harrisburg, Pennsylvania 17109 by regular mail on April 11, 2011 at 5:00 p.m. The statements set forth in this Affidavit are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: , 2011 -5? (1 BARLEY SNYDER LLC By: Colleen Brelje, Paralegal 126 East King Street Lancaster, PA 17602-2893 717.299.5201 3191853 No. 2011-778-Civil Term BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NATHAN LIDDICK, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 2011-778-Civil Term AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE, PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 The undersigned, Shawn M. Long, Esquire, doth depose and say that Nathan Liddick, Defendant is not in the military service of the United States of America, based on the following facts: Age of Defendant is unknown; present place of employment is unknown; present place of residence is: 406 Davis Street, Harrisburg, PA 17109 as of the date of this affidavit. ADDITIONAL FACTS, if any. The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. BARLEY SNYDER LLC By: Sha n M. Long, Esqu' e Attorneys for Plainti Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 3215276