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Home My WebLink About11-09011r= Tr?s? Pti0Yad00 "FAY 2011 JAN 27 AN 1,,: 14 CUMBERLAND COUNTY PENINSYLVANIA 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. HARRY THOMAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. -? 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. 3082064 %?7i A 14 - 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 Street Carlisle, PA 17013 (717) 249-3166 3082064 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 US"TED 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 Street Carlisle, PA 17013 (717) 249-3166 3082064 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. HARRY THOMAS, 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, Harry Thomas, is an adult individual with a last known address of 207 N. College Street, Carlisle, Pennsylvania 17013-2305. 3. On or about March 10, 2008 Defendant entered into a PSECU Loanliner Advance Proceeds Voucher and Security Agreement and Loanliner Credit and Security Agreement and Loanliner Addendum ("Agreement") with Plaintiff for the purchase of a 2002 BMW 745i, 3082064 VIN #WBAGL63452DP50655 ("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 falsifying loan documents. 6. Defendant is currently due for the months of April 9, 2009 and thereafter. 7. The Vehicle was impounded for drugs. 8. By letter dated March 11, 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. 9. 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. 10. Defendant remains liable to Plaintiff under the Agreement as follows: Principal Balance $23,556.03 20% Collection/Attorney's Fees 4,711.21 Total $28,267.24 plus costs of suit. 11. PSECU has demanded payment from Defendant, but despite these demands, the Defendant has refused and continues to refuse to make payments. 12. 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 writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and 3082064 2 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, Harry Thomas in the amount of $28,267.24, and costs of suit. BARLEY SN R L C By: Shawn M. Long, Esquire Court I.D. 83774 126 East Kiang Street Lancaster, PA 17602-2J 717.299.5201 Attorneys for Plaintiff 3082064 3 VERIFICATION Pennsylvania State Employees Credit Union v. Harry Thomas 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: q 17 01 Gregory R. Diffenderfer 3082064 C? i ua U i40. ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT ® Pennsylvania State P E Employees Credit Uniotl= P O Box 67013 . . Harrisburg, PA 17106-7013 717.234.8484 800.237.7328 MEMBER NAME : BATE `ME?SBER ACCOUNT NtlhjBER '. NOTE NUMBER HARRY THOMAS 3/10/2008 8052714517/110 0006839280 207 N COLLEGE AVENUE CARLISLE, PA 17013 PURPOSE: Dealer Purchase TRANSACTION TYPE ? OPEN-END ? OTHER ? HOME i NEW LOAN 2. LO AN ADVANCE 3. (DESCRIBE) 4. EQUITY ADVANCE YOU HAVE PREVIOUSLY ELECTED TO'HAVE THIS ADVANCE CREDIT DISABILITY SINGLE CREDIT LI JOINT CREDIT Y INSURED WrrH THE FOLLOWING COVERAGE YES El NO YE YE NO DAILY PERIODIC RATE ANNUAL PER- INTEREST RATE IS AMOUNT REQUESTED :' AMOUNT ADVANCED PREVIOUS BALANCE NEW BALANCE (CHANGE IN TERMS ONLY) CENTAGE RATE +OTHER CHARGES ? ' { FIXED VARIABLE+ .Ci. .r?;?..•.w::;:.'+ ...,:, .: r ... . T - 9 0 00 39 679 82 .0198356 7 .240/, ] ? 39,679.82 .39 . 6 '2; j- : <<.:.. , . , . PAYMENT DUE DATE PAYMENT FREQUENCY PROJECTED LOAN TERM 603.60 4/9/2008 Monthly SECURITY OFFERED IF THIS IS A HOME EQUITY ADVANCE, THE ONLYSECURITY FOR THIS ADVANCE ISTHE REAL PROPERTY (IN MOST CASES YOUR HOME) WHICHYOU GAVE AS SECURITY WHEN YOUR ACCOUNT WAS ESTABUSHEEL , 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 PROPERTY . ... MQDE6 YEARw% .. a .. . % LO, NUMBE Ryr' : ? r'.: `TYPE', .° _ *' YAI UEt?::3,"? += 1• nMrAj 2. c?_• C 3. 45T 2002 c?1 . BAGT,63452DP50655 SDN I ` 33, 010.00 4. OTHER YOU PLEDGE SHARES AND/Oft DEPOSITS OF $ IN ACCOUNT NUMBER OLD ACCOUNTILOAN NUMBER (A PAYOFF R1NC_+ IN7 OLD ACCOUNTILOAN NUMBER (B) PAYOFF (PRINC.+ INT.) OLD ACCOUNT/LOAN NUMBER (C) PAYOFF (PRINC.+ INT.) OLD ACCOUNTILOAN NUMBER (D PAYOFF (PRINC. + INT. OLD ACCOUNT/LOAN NUMBER E) PAYOFF (PRINC,+ INT.) OLD ACCOUNT/LOAN 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 referenced above will secure"the advance and any other advances you have now or receive in the future under the LOANLINEW 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 abovo In accordance with the terms of the Plan. 0 CUNA MUTUAL GROUP, 1980.82, 84, 86, 89,98, 99, 2000, 01, 04,06, ALL R:GRTS RESERVED FNNIBIT A PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM 43175 JVXXO1OO.1 037.2092-1 (=6) q 1-76 /Z- E? L& A IN N E 9) IRITTEN & NUMERICAL AMOUNTS _DONT MhNlisylvania State Employees , Credit Union No. 6839280 PO Box 67013 a Hamshury, PA 17106-7013 a (717) 234-8454 or; 800) 237.7329 BR MA?TCEP?CT & IN,;T46EAAV700 ? -. REFERENCE 8054714517 VOID 1:0 DAYS AFTER, 42/19/2008 PAY. TO THE d ?- - ORCOF (DEALER), ,?' I. $ ?sLL?j{L 1/DOLLARS t IMPORTANT: VOID UNLESS DEALER END ORSEMENT,COMPLETED ENDORSEMENT . Ewer's Ord J DJr at Sale 114e. and used Vet+clesi and tztory nrdre< P' W VehAle tdursmgthis AulD7ieh;;l/We agree to the terms listed on the reverse side, mu tb a yeAbt the Au,.D,aft's rec.sed by pSECU,of. it. Au;(` ft IIbJ Ihe'Jratt "Compleu thofollowing repayment. inlorr[titan i --I+e[u n a r! port t the Proceeds °t the-AU•oDt I?•shall be, pad [o the B erlsT .. - I l., to "'v Ne [ of D rrowc I 1 Th AutoDraft shall not be usad to pub 1 rTetm IMo ,h I - -R I r to Mas mum T m n the At otor Ve .de I.8 h• o°.1moad, eommere,al, classic. It It, salt 3 tl or Bo.d t el.d -hld s or .Ncl.. Meshed. ?A o Tr I ? rtrne.utk rx3 ? P yroll - ? h on,hy ..o?..-t ? D'. e_[ Pa,r ,_ tt °tted..I.de the UNI.d States Dv gong the p 4c<eds.1 tlvs Drat[ .. ao ", to F'_-,c nM terms bsteo on the reverse ade - PSECU FAA1717-787-D3h3 vma _ J -? - ErEVy vse Mantiter Endorser -In-- p Y JTA Y TNOSIAS, ' MI?EAGF yE/JI AUx IA L . ' , t? 7.SZ5? Co-Applicant Endorsement uEUra 1D.n ucAr oreAUMdc". NO C0-AP11 LICAN'f 85 S6 ?', ?• 6 ?. 3o d , B.,, 27 70?11'6a39260Ill. 1:231313 311161: 310S4S2to 13 2He 44 1'000 396 7913 2,1' n c^ ?a$$ N o k ' 3 m 2 O? i n n 3 0^ v gv 9.02 M n IT TIM -' s3rit•i ?I L3 ? •t Y4 'I f/J "*0W c- ?°-; °f A mmm0 y !,' ?•oa"''o 7?w?woD 3n»4 ^ t?aU `' m m - NE - !L it On, 3QQ3 m o• r `oSp O , v 3?c•72 c `Z Sk 77 g'gi3 i"^R ov" D .Orr. ^ v a 3 A 5 k "o 2 "-'D , 010 nu t7 ?q$ ? _sUkl Z Pyp- s n3 fl°. r mr f ;K r L7 .,y .. Q.,T..'r) - _t•-7 "-ww^=? O WC j52,7244 BEG e...i a)?F7 •?11: ?.) e=2 WP'b'io33 F y °e o'er w Z aC ' 1rm ,c:z N+.-; l' •: .ti R °£ Eir pu m Ee° yn 6't9 SD -1 CY C r j- r;. s r Y•Ij,?i., I ry j t1 s t., :2 Q13 ?• ' .. t .? m_ n K - n °« o m m r I` `r?'r'.Fyflt?'k V1J t.. uLyu t_O-••..-,;:'1 ?'or-3m soS9rRdd~ ° ?... O#1f fy 6190 +FC=5594 PK=OL a m;no"d 3 !.t 00= M. ry Ut-1OQ±{v O FRB-P1iL 333,. 1 '4 ,= •.?':,' s o ^: s?3s X E T= 4v£1TRC=fi 5 42 m =1 3D r0 I IJCJ V`?„ C? 4 eta-^- •fi$3? ;?-o^$M?R 0-z 2V - AF - .a' ( n33 rix-<- ?ps u y'=^-° -t OR.. °^kZi a8 ? Xk2 t5 <?_5° »? tn?? - r n!I- : FITS 3itZ 6 `n z Pennsylvania State Employees Credit Union P S E Ck LPO BrX 757013 O liaff!sluwo, P:1 17108-7013 • (717) P34-8484 k0rrs,,;ry, !7300) W-73?29 J.f;„n.v";e Loan Disclosures 44:1 r + 'I ?1 G?9/*f(i?l fl3? f ;4;?r '?C ? . t '1xQ..t..r..i?i.s. .,+wa.._.? ,??<.a.l?.,.._, . _.... _ .,r ?. ..l ., ... .? t,+.-.wk, ..ice.. r... r....u ..a?.._ ... ... ... .... .., _,t .. x. ..i.. _,2... ?i i?4:?w.",?tn k This LOANLINFR` G ac t and ?rihy Ay?ee?ne it rci1 „Iur'r;S .Le Truth n .e a:'1 _?_, ;w or in li? i,;twe except tiny lost ? - d ,;y your principal (N%erinrt. Lending DlscioSUR;s 'A be ref,,rr? i to :is the Plan Ti-F-' Plan daimon!, ircl.,de tt^., Property ;;curing otnar loins you have ,, th .is ?-ey a ) -,cure the Plan. agreement and an Addendum You, your and borrower rean any person -ho signs VOLUNTARY PAYMENT PROTECTION - 'Ale may erfer Voh;ntary Payment the Plan. Credit union, we, our and us main PSE-CU or anyonc to v:hom the Credit Protection to you. Voluntary Paymonl Prater.lion is rnt necessary to obtain credit. If Union transfers its I'lyntc finder !ho Plri il. fe you pijrr,'-lase `Jo1?,?tary Payr^r...r , nrtcctlon 1.c^i u°, y ;.i -.,,(h?)r ze s to add the es HOW THIS PLAN WORKS - T!'is is an open-end, multi-featured credit plea oki or insurance charges monrhly to your loan balance rind charge you Interost on the anticipate that, from time to tirne, you will borrow money (called 'advances') under entire balance. At our option we will chmtuge your payrnr;nt or The period of tirne the Plan We are not required to make advances to you under the Plan and can necessary to repay the loan halance. The rile us°d to determine the fees or j refuse a request for an advance at any time. The Addendum describes the insurance charges may change in the future If thr: rate changes, we will provide any different types of credit (called "subaccOUnts") available under the Plan, the current i notices required by applicable law. interest rate for each subaccount expressed as a daily periodic rate and corresponding annual percentage rate and other chaigns. It may also have other PERIODIC STATEMENT - On a regular basis you will receive a statement showing I d b th t t m nt Pl i th d d d h terms and a schedule for determining the payment amounts covere y e s e ur ng e perio a e an all transactions un er t e Statements and notices will be sent to you at the most recent address you have CREDIT LIMIT - We may, but do not have to, establish a credit limit on certain I given us in writing. Unless applicable law requires notice to each joint borrower, subaccounts..If a credit limit is set for a subaccount, you promise not to oxceed the notice to any one of you will be notice to all, established credit limit. If you exceed the credit limit, you promise to repay JOINT ACCOUNTS - If this is a joint account, each of you is individually and jointly immediately the amount which exceeds the credit limit. responsible for paying all amounts owed. That means we can enforce our rights REPAYMENT - You promise to repay all amounts you owe under the Plan plus under the Plan against any one of you individually or against all of you together, if you interest. Payments are due on the last day of the month unless we set a.differenl day give us inconsistent instructions, we can refuse to follow your instructions. Unless our at the time of an advance. If the Addendum has no payment schedule for a written policy requires all of you to sign for an advance, each of you authorizes the subaccount, your payment will be determined at the time of each advance. Payments other(s) to obtain advances individually and agrees to repay advances made to the must include any amount past due and any amount by which you have exceeded any other(s). Any joint accountholder may terminate the Plan by giving us prior written credit limit you have been given for a subaccount. You may repay all or part of what notice- If any of you terminate the Plan, the Plan is terminated for all of you. You you owe at any time without any prepayment penalty. Even if you prepay, you will still remain liable individually and jointly for all advances incurred before termination. be required to make the regularly scheduled payments unless we agree in writing to FEES AND CHARGES - It you give us a security interest in certain types of a change in the payment schedule. If you have a joint sharedraft account, you will be property, we may charge you a filing fee to perfect our interest in the property. If we responsible for paying all overdraft advances obtained by a joint holder of the d, you at the time you obtain do the amount of the fee will disclosed an advance. sharedraft account. Unless otherwise required by law, payments will be applied to We may also charge you other r fees connection with the Plan. Our current fees are amounts owed under the Plan, in the manner the Credit Union chooses. disclosed on the Addendum and will be added to your loan balance unless you pay PLAN ACCESS -You can obtain credit advances in any manner authorized by us. If them in cash. we allow you to use your ATM/ Debit card to access the Plan, you may be liable for the UPDATING CREDIT INFORMATION -You promise that you will promptly give us unauthorized use of your ATM/Debit card. You will not be liable for unauthorized use f l ' written notice if you move, change your name or employment, or if any other f o. .... -^ t, or poSsib e l ho -s, the ihai occurs aiier you nuiiy us, uEnlly -itrr y-, 6 unauthorized use. It you believe your ATM/Debit card has been lost or stolen, information you provided to us changes. Upon our request, you also agree iu immediately inform the Credit Union by calling or writing us at the telephone number or provide us updated financial information. address that appears elsewhere in the Plan If the card is used to obtain unauthorized DEFAULT - The following paragraph applies to borrowers in Idaho, Kansas, advances directly from the Plan, your liability will not exceed $50. If the unauthorized Maine and South Carolina: You will be in default if you do not make a payment of withdrawal is from a sharedraft account, your liability is governed by the Regulation E the amount required when it is due. You will also be in default if we believe the disclosures you received at the time you received your ATM/Debit card, even if the prospect of payment, performance, or realization on any property given as security withdrawal results in an advance being made from your overdraft subaccount. is significantly impaired FINANCE CHARGE -The dollar amount you pay for money borrowed is called a The following paragraph applies only to borrowers in Wisconsin: You will be in "finance charge" and begins on the date of each advance. A finance charge will be default if you fail to make a payment when due two times during any 12 month computed separately for each separate balance under the Plan. To compute the period. You will be in default if breaking any promise made under the Plan materially. finance charge, the unpaid balance for each day since your last payment (or since impairs your ability to repay what you owe or materially impairs the condition, value, an advance if you have not yet made a payment) is multiplied by the applicable daily or protection of or our right in any property you gave as security. periodic rate. The sum of these amounts is the finance charge owed. The balance The following paragraph applies only to borrowers in Iowa: You will be in used to compute the finance charge is the unpaid balance each day after payments default if you are more than 10 days late in making a payment. You will also be in and credits to that balance have been subtracted and any additions to the balance default if you do not comply with the terms of the Plan and your failure to comply have been made. In addition to interest, we may charge other finance charges which materially impairs any property you gave as security or your ability to repay what you are disclosed on the Addendum. If the interest rate is a variable interest rate, the owe under the Plan. Addendum explains how the variable interest rate works. The following paragraph applies to borrowers in all other states: You will be in SECURITY-You pledge as security for the Plan all shares and dividends and, if any, default if you do not make a payment of the amount required when it is due. You will all deposits and interest in all joint and individual accounts you have with us now and be in default if you break any promise you made under the Plan or if anyone is in in the future. If a specific dollar amount is pledged for an advance, we will freeze default under any security agreement made in connection with an advance under shares in that account to the extent of the outstanding balance for the advance. the Plan. You will be in default if you die, file for bankruptcy, become insolvent, if you Otherwise, your pledged shares may be withdrawn unless you are in default. In make any false or misleading statements in any credit application or update of credit addition to your pledge of shares, we may also have what is known as a statutory lien information, or if something happens we believe may substantially reduce your on all individual and joint accounts you have with us. A statutory lien means we have ability to repay what you owe, You will be in default if any property you have given the right under federal law and many state laws to claim an interest in your accounts. us as security is repossessed by someone else, seized under a forfeiture or similar We can enforce a statutory lien against your shares and dividends, and if any, interest law, or if anything else happens that significantly affects the value of the property or and deposits, in all individual and joint accounts you have with us to satisfy any our security interest in it. You will also be in default under the Plan if you are in default outstanding financial obligation that is due and payable to us. We may exercise our under any other loan agreement with us. You will be in default if any property you right to enforce this lien without further notice to you, to the extent permitted by law, have given us as security is repossessed by someone else, seized under a forfeiture For all borrowers: The statutory lien and/or your pledge will allow us to apply or similar law, or if anything a se happens that significantly affects the value of the the funds in your account(s) to what you owe when you are in default. The property or our security interest in it. 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 ACTIONS AFTER DEFAULT -- The following paragraph applies to borrowers in given as security. Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Additional security for the Plan may be required at the time of an advance. If a Nebraska, South Carolina and West Virginia: When you are in default and after subaccount identifies a type of property (such as "New Cars") you must give that expiration of any right you have under applicable state law to.cure your default, we can type of property as security when you get an advance under that subaccount. A demand immediate payment of the entire unpaid balance under the Plan without subaccount name such as "Other Secured" means you must provide security giving you advance notice. acceptable to us when you obtain an advance under that subaccount. Property you The following paragraph applies to borrowers in all otherstates except Wisconsin give as security will secure all amounts owed under the Plan and all other loans you and Louisiana: When you are in default. we can require immediate payment :71 CUNA MUTUAL GROUP. 1989, 2006. 07, 08. ALL RIGHTS RESERVED - , .' •?,! ' CPSM01 _ _ _ _. PSECU FORM #3146_ JBXX0601-2 037-20921 (2r08) i j LOANLINERI Credit and Secant Credit Agreement (continued) (acceleration) of the entire unpaid balance under the Plan. You waive any; ight you have to 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 ,,ntil what you o,r.,e has been repaid at the app,icable Interest rates in effect or if applicable. at the default rate disclosed on the Addendur If a demand for immedate payment has been made, your shares and.!or deposits can be applied towards what you ov.,e as provided in the section above called 'Security ;' We can also exercise any other rights given by law when you are in defaUll You agree the Credit Union has .he right to take possession of any property given as security under the Plan, w snout judicial process, if this can be done without breach of the peace. If we ask, you promise to deliver the property at a time and place we choose. If the property is a motor vehicle or boat, you agree that we may obtain a key or other device necessary to unlock and operate it, when you are in default. We will not be responsible for any other property, not covered by this Agreement, that you leave inside the property or that is attached to the property. We will try to return that property to you or make it available for you to claim. After we have possession of the property, we can sell it and apply the money to any amounts you owe us. We will give you notice of any public 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 costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded under the Bankruptcy Code. 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 immediate payment of your outstanding loan balance under the Plan and seek possession of property given as security. You may voluntarily give the property to us if you choose, or we may seek to take possession of the property by judicial process or any other method authorized by applicable law. If we repossess the property, you agree to pay reasonable expenses incurred in disposing of the property. If the property is a motor vehicle, mobile home, trailer, 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 at the same rate as the advance, or, if applicable, at the default rate 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 any right you have to demand for 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: We can change 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 terms 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 if 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 states: 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 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 i terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancei the Plan at any time by g; ping us prior ,.siren notice. Your obligation to pay the unpaid balances under the terms cf the Plan continues whether you or the Credit Union cancel the Plan. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN - We can delay enforcing any of our rig!-,t3 under tins Plan ariy n,.rnher of times wltnoul losing the ab'fty to exerc.se e-r nyrts lwer `Ne can cnrace ,,is Plan against your nelrs or legal representatives If v.e change the ?erms of th. Plan yo i agree that this Plan ,vlll continue to protect Us. CONTINUED EFFECTIVENESS -- If any par; of t?rs ilian is determined by a court to be unenforceable. the rest wul remain in effect. NOTICE TO UTAH BORROWERS -Tits wrwen agreement is a final expression of i the agreement between you and the Credit Union. This written agreement may not be contradicted by evidence of any oral agreement The 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. USE OF ACCOUNT - You promise to use your account for consumer (personal, family or household) purposes, unless the credit union gives you written permission to use the account also for agricultural or commercial purposes. The following paragraphs apply if you give security in connection with an advance under the Plan. They apply to borrowers in all states 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 ("tne 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 the property which you buy within 10 days of the Advance or any extensions, renewals or refinancing of the Advance. It also includes any money you receive from selling the property or from insurance you have on the property. If the value of the property declines, you promise to give us more property as security if asked to do so. 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 avid arty other amounts ov 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 the 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 security or if the Advance is to buy the property, you promise 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 not already told us about You promise not to sell or lease the property or to use it as security for a loan with another creditor until the Advance is repaid. You promise you will allow no other security interest or lien to attach to the property either by your actions or by operation of law. 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 insurance settlement to repair the property or apply it toward 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 taxes and fees (like registration fees) due on the property. If you do not pay the taxes or fees on the property when due or keep it insured, we may pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the 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 oayments 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 term of the advance. INSURANCE NOTICE - If you do not purchase the required property insurance, the insurance we may purchase and charge you for will cover only our interest in the property. The premium for this insurance may be higher because the insurance LOANLINER" Credit and Security Credit Agreement (continued) company may have given us the right to purchase Iinsurance 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 slate issues a title for the property, YOU promise to -Ave oir security interest shov:n on the title. We may have to file what is called a financing statement to protect our security interest from the claims of others. You irrevocably authorize us to execute (on yo.u behalf), if applicable, and file one or more financing, continuation or arnenament statements pursuant to the Uniform Commercial Code (UCC) in form satisfactory to us. You also promise to do whatever else we think is necessary to protect our securty interest in the property. vou prom?se 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 app!icabie iaw. USE OF PROPERTY - Until the Advance has been paid off, you promise you will: (1) Use the property carefully and keep it in good repair. (2) Obtain our written permission before making major changes to the property or changing the address where the property is kept. (3) Inform us in writing before changing your address. (4) Allow us to inspect the property (5) Promptly notify us if the property is damaged, stolen or abused. (6) Not use the property for any unlawful purpose. (7) Not to retitle property in another state without telling us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, 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 unauthorized 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 sheet 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 may 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 you have authorized us to pay a credit card account automatically from your share 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 AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE D!FFEPENCE. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is un'awful for you to fail to return a motor vehicle t )at is subject to a secucty in'e est v.i:Nn thirty days after you have received notice of default. The notice v. II be mailed to the address you gave us. It is your responslblCty to nobly us if your address changes. The max,mum penalty for unlaevful fa,lurc to -etrrrn a motor vehlse , ode year in l and'or a fine of S150.000. 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 car 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 antount. 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 tell anyone we report you to that you have question siaierr-fri Anrl wt riiusi tell you the name of anyone about yoL! we reported you to. We ni 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. SPECIAL RULE FOR CREDIT CARD PURCHASES - If you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining 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. 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 notify 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 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 other 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 credi' 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 Paymew within 25 days of your statement closing date. By separate Visa" Credit Card Aoaeement and Truth In Lending Disclosure (continued) agreement you may authorize us to charge the minimum payment automatically 10 your share or checking account with us. You may, of course, pay more frequently, pay mane 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 Ine balance owed, we drill automatically post the cred!t l0 your S1 shares The minimum payment will be (a) 215 of your Total New Balance, rounded up to the next even dollar, or (b) 520.00, whichever is greater. In addition, at any time yo-,,r Total New Balance exceeds your Credit Line, you rrwst 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 lase fees, then to previous cash advance halances tnen 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. 7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by paying the full amount of the New Balance of Purchases each month within 25 days of your statement closing date. Otherwise, the New Balance of Purchases, and the subsequent purchases from the date they are posted to your account, will be subject I to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average adjusted daily balance (see explanation below), including new purchases, for the billing cycle by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Cash Advances: We calculate your finance charge on cash advances by multiplying the average adjusted daily balance (see explanation below) for cast) advances during the billing cycle by the monthly periodic advance rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Daily Balance for Purchases - The Average Daily Balance for Purchase Transactions is calculated by adding the Daily Balances (Purchase 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 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 Balance 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 for 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. Then we also subtract the amount of any Purchase 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 Cash Advance Transactions. 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 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. 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 the payments and credits which are posted to your account by the Payment Due Date 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 in 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 expenses, 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 i the iransaction by using you? Perso, cle tficat,on Number (PIN) in conjunction ,e,gth the card in an Automated Teller Machine or other type of electronic terminal that provides access to t'ie Visa system. You agree that vo.r will not use your card for any transaction that is illegal under applicable federal, state, or local law. The monthly slatement v 11 :centify the merchant elocron?c terminal or financial instltullon at which transactions we,e made, bcr, sale, cash advance credit or other slips cannot be returned vnth the statement. You wit retain a ropy of urt) slips furnished at the time of the transaction in order to verily the monthly slatement The Credit Union may make a reasonable charge for photocopies of slips you may request. 10. OVERDRAFT OPTION - If you e'ect to overdraft to your PSECU Visa Credit Card, that election is subject to the existing credit limit and the agreement it represents ano the current loan policy at the time of tine overdraft. You also understand that an overdraft will he considered the same as a cash advance on your PSECU Visa Credit Card and that the rurrant Annrial Percentage Rate for cash advances will apply. 11. RETURNS AND ADJUSTMENTS - Merchants and others who honor the card may give credit for returns and adjustments, and they will do so by sending us a credit slip which we will post to your Visa line of credit. If your credit and payments exceed what you owe us, we will automatically post the excess credit balance to your S1 Shares within 75 days. If the balance is one dollar or more, upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS - The exchange rate between the transaction currency and the billing currency used for processing international transactions is a rate selected by Visa from the range of rates available in wholesale currency markets for the applicable central processing date, which rate may vary from the rate Visa itself receives, or a government-mandated rate in effect for the applicable central processing date. Ir each instance, an adjustment may be assessed based on the ISA fee imposed by Visa. This fee generally totals 1% of the transaction amount. In all cases, we will assess 1% on all transaction amounts where the merchant country differs from the country of the card issuer. 13. DISPUTED TRANSACTIONS - If you disagree or find an error with a Visa transaction, and have tried in good faith to correct the problem with the 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. You are required to notify PSECU 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 transaction on your account. Telephoning PSECU does not 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 disnuta. In cases of fraudulent card use. PSECU will also require a notarized affidavit. In some cases we may ask you to notify the local auiiwritles. If we do not receive the proper requested documentation in the time specified you may be held responsible for the transaction(s) in question. PSECU must adhere to strict dispute timeframes set forth by Visa. 14. SECURITY INTEREST - To secure your account, you grant us a purchase money security interest under the Uniform Commercial Code in any goods you purchase through the account. If you default, we 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 not assert any statutory right we may have if you are in default to prevent withdrawal of your unpledged credit union shares (Deposits) below the 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 15. 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 the law permits, and we indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. 16. LATE PAYMENT CHARGE - If your Minimum Payment is not received by the first day of the month following your due date, you will be subject to a $20 charge. 17. RUSH FEES -You may incur additional charges for rush processing and rush delivery of cards and/or PIN mailer. 18. DRAFT COPIES - "ou may incur an additional charge for transaction summary/sale draft documentation. 19. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement. 20. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. 21. NO USE - Inactive Visa accounts that have no purchase or cash activity may be closed without notice to you after 18 months of no activity. 22. 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. LOANLINERO Addendum Instructions: This addendum is incorporaied into and becomes part of your LOANLINER Credit Agreement. Please keep attached. First Payment: Your first payment is due and payable within 30 days from the date of the loan advance. The Annual Percentage Rates, corresponding daily periodic rates and amount of payment for each loan subaccount are shown below. If there is no payment schedule, the cmount and due dote of payments will be determined at the time of each advance and disclosed on the Advance Request Voucher, Advance Proceeds Check, or eny other loan voucher or receipt. OtinerCnargas that may be imposed are also shown below fi.e., late charges, filing fees, collection tests). All rates are subject to change. Default Rate: The credit union reserves the right to charge the highest unsecured interest rote currently in effect at PSECU. Auto Loan to Value Financing: Rates reflect loan amounts up to 100% of the rNISRP, the Kelley Blue Booker's or other author.zed guide's retail value of the vehicle. PSECU will charge an additional percentage point to the current interest rate when financing a vehicle for more than 100% and up to 1301 of the retail value. PSECU makes all final decisions regarding vehicle ,Clues and proper rate. Loan Subaccount Description Approx. Tenn in Months Percent Above Index Daily Periodic Rate Present Annual Percentage Rate Minimum Paymenf (For each 5100 or fraction of 5100 of your unpaid amount) . Without With APS Without With APS Without With APS Auto Loan (1) Automatic Payment Automatic l Automatic Ito ? Ne.. Vehicle Service seivice Saiv ice $40,D001aanandvalue orgreater 120 .00020521 .000198336 7.49% 7.24% 51.19 $1.18 $20,000 value or greater 84 .00018466 .00017781 6.74% 6.49% $1.50 51.49 $12,000 wa1,eor9reat- 72 .00018466 .00017781 6.74% 6.4?% 31.70 51.69 $ 8.000 -1.. or y...... 60 .00017096 03016411 124% 599% S 1.95 51.94 S6,0C?3 value or 9,ea1er 48 .00017096 .00016411 6.24°d 5.999; $2.36 52 35 $3,000 value or greater 36 .00017096 .00016411 6.24° 5.99% $3.06 . $3.05 13,000 vulue of g,ealer 24 .00014356 .00013671 5.24% 4.99% $4.40 54.39 U:-d Vehdes Only $4U00 1- ond vol., or greater 120 .00020521 00019836 749°: 2 1.19 51 18 120,000 value or greater - W .00018466 00017761 6.7.1% 9% 6.4,°c $ 51.50 . 51 49 n 12,000 value or greater 72 .00018466 .00017781 6.74% 6.49% $1.70 . $1.69 18,000 waloeor y,eater 60 .00017096 .00016411 624% 5.99:; $195 $1.94 $6,000 vole or 9-1 48 .00017096 .00016111 6.24°; 5.99-% $2.36 $2.35 13,000 value or greater 35 .00017096 .00016411 6. 24% 5.99% $3.06 $3 05 $3,000 value .r greater 24 .00014356 .CW13671 5.24% 499% 54.40 . _439 Pccrearonal Veh,d, New/Used (2) n amavnt $15,000 and up 84 .00024384 N/A 8.90% N,A S1.60 N/A i nn ant $8,000 - 14,999 60 .00024384 N/A 8.90% rl;A 52.07 N!A Loon -,-n $5,000 - 7.999 _ .00024384 N!A 8913% N/' 52.48 N/A Loran .nn-it $3 (700 -4,999 36 .00024384 N/A 8.90% Nil 18 WA IRA Loan (3) 12 <._ .-_7008877 NiA 3.24% Nil 18.49 N,A Shore Loan (3, 4) Upto 51,0001 19 2.0 .00006577 N/A 3245 1 1.A _3.31 14 A 41,001 - $4,000 48 2.0 0OW8877 N;A 3.24% rIJA $223 Owe $4,000 120 20 .00008877 N/A 3.22 N/A $0.93 inn IC ?ertiricate Loan (3, 4, 5) d::dz,-:> 20 N/A _ ar?_e_res NSA N;A ersonal Service Loan (PSL)(6) 77 .00035342 N/A 12Q% NSA N;A not Service up 1. 6= S,gnotvre Loon (PSSL) *?onthz O-ZC2712 NrA 9.90% N/A Automatic Payment Service (APS): In ardor to qualify for the Za% redu.fon, et the t me the loan is se: u? you must sled io have your' :ehiale loan payments made via anew om aticservice'. Automatic TronsferService, Payroll Deductior, Cash Includes psecuChorns :and Self Service Telephone), Wire Transfer, ond Direct Payment. If you remove, discontinue, charge or posipa.v'he au!o-„afic transferatanytime cfler' your loan is setup, your interest rate will immediately be increased by 0.25% (as of the date of your last poymeri) for any outstanding balonca' -.'he loan. If your interest rate is increased due to ar y of these reasons, yourloon paymen+cmount will remain the same, however the term of, your loan will be extended for the appropriate,pmcunt of time until all inte e-t, orincipal, and fees nave been paid acca ding -o vq•Pr_Plan. PRE C 8oa67C13,fiarrisburg PA 171C6J01 PSL Minimum Payment Ranges (per thousand portion thereof)" FIRST PAYMENT: Your first payment is due and payable within 30 days from the date of the loan advance. Minimum M,ontnly Minimum Biweekly Loan Balance at Time of Advance Payment Payment 19,000.01 io 20.000.00 400 200 18,000.01 to 19,000.00 380 19D 17,000.01 to 18,000.00 360 80 16,000.01 to 17,000.00 340 170 15,000.01 to 16,000.00 320 16J 14,000.01 to 15,000.00 300 150 13,000.01 to 14,000.00 280 140 12,000.01 to 13,000.00 260 130 11,000.01 to 12,000.00 240 120 10,000.01 to 11,000.00 220 10 9,000.01 to 10,000.00 200 11,10 8,000.01 to 9,000.00 180 po 7,000.01 to 8,000.00 i60 80 6,000.01 to 7,000.00 140 5,000.01 to 6,000.00 120 :i0 4,000.01 to 5,000.00 100 '70 3,000.01 to 4,000.00 80 40 2,000.01 to 3.000.00 60 3r) 1,000.01 to 2,000.00 40 ?0 Up to 1,000.0D 20 10 "Personal Service Signature Loan Minimum Monthly Payment: $ 100 for original balances from $1,000 - $5,000, $200 for original balances from 55,000.01 -$10,000 Visa Disclosures Finance Charge: Fincnce CFarce(interest) is caicolgie;, a. -ire o ^d ; r^.,:n Inc on the average daily balances of pu•cres_s ena test aavc,Ce, Visa (Purchases) Monthly Periodic Rate OGS2S Annuol Percentage Rate Visa (Cash Advances, Checks) Monthly Periodic Rate 0 i ;1? : Annuol Percentaoe Rate - 1 ? 9 Minimum Payment: Tie m'rimum monthly poyme-t .ill 2.i, ul ;tU-VU, s f iev?r ., create., or (o) you, Total new balance if it's less than 520.00, L v ,,, s-atementfslrwhicn mci,isunpaid. Collection Costs: You pramse to ray all fees ant .._>a Such fees ena tests shall include crtfor-ev fees of 20"; o":ne o d-n „. in connection with onematin to colleC the amouni you o-ve. Late Charge: You p octise 4c paw a late charge o' S20 :;jr yof i, -r o allowing your due date. Over Limit Charge: You aror^' e io pay . _r kin:- vr_•e S1'2 g Overdraft Optian: L yc? eiec o __rdr3 ,r PHCU V zc Ct_ ea..neni _+ond' annuah _r?e rcg=. _ _cstladvorc s fit'g_,ph _u_ts?{? _ vFC1?, csr57e,e. c. d i. ,ne Vise Ciec: ,_..,cn,, Ti-,--. ',r l _ i .,_ ._ i 1 i. • „ t-;, .,,, . 000.237.7328 net , ide, or r' tel= Un cr PSECU, P.O. C i 3. Credit Life and Credit Disability Insurance (aeer,a tt,ror,9t, cuNA Mutoet Insurance Satety) CUNA Mutual Insurance Society Credit Life Insurance ;cost per $100 of monthly loan balance): Single Credit Life - $.070 5910 Mineral Point Road, Joint Credit Life - 5.123 Madison, Wisconsin 53701 Credit Disability Insurance: The Schedule of Rates shown belowaregross boloncerates, This meonstheraiesoreapplied iothesumofiheperiodicloonpoymenis which remain to be paid on your loan. The rate we use is determined by the projected loan term of your loan (See your loan plan .a find the projected term of your loon). For example, ii the projected term of your loan is 24 months and the benefit plan is a 14 day nonretroactive, the rate for the term is .2950 oer $100 of cross balonce. If the amount of vour periodic loon payment is $100, the gross balance of vour loon during the first month of your Icon is $2,400 (24 x $100). Our charge to you for msuronce for the lirsi month of your loon term would be $ 2,400 x.2950 x 0.0 1, or $ 7.08. Afteryou have mode yourfirst $100 periodic loan payment, the gross bolance of your loon would then be $2,300 (23 x $100) and our charge to you for your insurance fort :he second month would be $2,300 x.2950 x 0.01, or $6.79 etc. The charges we actually maketoyou foryour insurance are shown in your periodic statement which you receive from PSECU. Please remember, whenever you odd a new advance to your loon, you recast the loon and c new projected loan term is determined occording to your loon plan. Please note alsothot ifthe amount of your periodic loon payment is grecterthan the maximum benefit oer month shown in the insurance schedule of • our certificate of insurance, our chargetoyou is based onthe sum of the maximum benefits per month times the number of periodic loan payments remaining to be paid on your loon. For example, r your periodic loan payment is $400 and the maximum benefit per month is $ 300 and you have 24 payments remaining to be paid, the gross balance of your loan for purposes of this insurance would be $7,200 (not $9,600) and ourchorgeto you forinsurance thefirst month would be $21,24 ($7,200x 2950 x 0.01). Pennsylvania Monthly Renewable Credit Disability - Disclosure Rates Per 5100 of Coverage Per Month TERM RATE TERM RATE TERM RATE TERM RATE 1 0.0000 31 0 2561 61 0.1791 91 0 1485 2 0.0000 32 0.2519 62 0.1783 92 . 0 1480 3 0.0000 33 0.2479 63 0.1766 93 . 0 1468 4 0.5395 34 0.2443 64 0.1753 94 . 0 1460 5 0.5627 35 0.2408 65 0.1742 95 . 0 1454 6 0.5796 36 0.2367 66 0.1730 96 . 0.1449 7 0.5372 37 0.2322 67 0.1716 97 0 1442 8 0.5070 38 0.2300 68 0.1700 98 . 0 1438 9 0.4804 39 0.2260 69 0.1695 99 . 0 1428 10 0.4587 40 0.2234 70 0.1681 100 . 0 1422 11 0.4407 41 0.2203 71 0.1667 101 . 0 1418 12 0.4254 42 0.2180 72 0.1658 102 . 0.1411 13 0.4069 43 0.2152 73 0.1645 103 0 1405 14 0.3924 44 0.2125 74 0.1633 104 . 0 1396 15 16 0.3784 0 3643 45 46 0.2099 0 2074 75 0.1624 105 . 0.1391 17 . 0.3548 47 . 0.2056 76 77 0.1613 0 1605 106 107 0.1387 0 1379 18 0.3448 48 0.2028 78 . 0.1593 108 . 0.1375 19 0.3346 49 0.2012 79 0 1583 109 0 1370 20 0.3242 50 0.1985 80 . 0 1573 110 . 0 1365 21 0.3171 51 0.1966 81 . 0 1565 111 . 0 1362 22 23 0.3083 0 3013 52 53 0.1947 0 1934 82 . 0.1556 112 . 0.1355 24 . 0.2950 54 . 0.1910 83 84 0.1545 0.1539 113 114 0.1352 0.1347 25 0.2882 55 0.1889 85 0 1530 115 0 1342 26 0.2817 56 57 0.1878 86 . 0.1521 116 . 0.1336 27 0.2759 0.1858 87 0 1514 117 0 1333 28 29 0.2713 0 2670 58 59 0.1837 0 1828 88 . 0.1507 118 . 0.1327 30 . 0.2614 60 . 0.1809 89 90 0.1498 0.1493 119 120 0.1320 0.1316 loon Disclosures :. e percent 3fthe scheduled payment. Collection Costs: You oromr_e to pay cll e,f cc _ ?v. _r r'nis agreement, including ear ; cross ono, tee.: up re 20 oercenf of i'n<_ outsh.:mina loon balance. Footnotes: jl) AT t^e cJ•ient IrTeres` rcTe, PSKU „, Ii Suggested Retoif Price (MSRP) of o ne c,,: e . . el ),.c_ _ :_le :, r,! ?I value of a ne•:,,, pr or year vehicle ( led); ,- , to 100. _ ;•3d •.,;I-C . .: usud vehicle lotted.) Atthecurrentlnierestrateplusoneoerce ace N i' r" .,Jf!Inuncec.?: 1005; :-. i_. x1305 of the AASRP of a current model a-,.e 'r, i au, . 100'/ vi ,07, o :e:o l value of a new, prior-year vehicle (unti.led);or o.cr1OJ°r::od oI C3L.;',t?e:utallvol?:e1:ia13ed motorveh:cleft:-led).i.iax:mumfina : 'no o-u =ir.., (in ._z- '.PSKU loon is 100% of i..e retail value. For usedanoonor-yearrewvencles,PSE-Cs!' Keley sic- r , of Kelley Blue Bock, Co., Inc.) or other aur.,arreu , lo, s to n:• e vC:i... Vehide loans Can:^•ai be used to purchase; col, -ci , -nk _.:I_e i l: enraeo. Tin- ,eh,--lem•.st be tdlw'o :he Borrow=_- ofI;fle mcy no- bea or!:ess, co-pcruiiun or fro ry, Vch _s . •-,?i :;I:,< $3,0"jcl and must be titled in the U.S. and moy not be ta'k-en cat of ?h,, U S. (21 PSECU will t-nonce up to 90 oer ert o; the .I . t j, I ycori of 53,333. Used Ua:;.rea Role pSPR ur aor .,.,eaulars o..s;Index)on'ne,.c-eo1 =oc:arc=_I_s .? ,..r -P??:-_r r,.?u._ Index column ., 1=lhere is an ex!s• na aolan__ or ',;, _ ale c _ h , „ ..'uu?_ •._c va _odded-o•henewadvencea •c-he nfr ^.Ic r ,,P r - a,. cra ge reflect a^ychonge n!^-elroex.A y: _„__ 'n I f- h_ some amount until not you cwe nus been Loon rote; un Certif,ccic acct IPA luuns w,il not fluctuate during the course of the loan. ? 'ftlea) re,::eai anal I ,, .•, v t, . , c. ? !h c ant c. :,e used rata.Ivah,•e.TheKallzy6Iu..Bc-.k?-o.o•i,e.?,;•: ;,:?I-;c.,c. _.,_e•,I me re: x.iono ! veh de's retail PSECU's m:ini:^?um RV oon?s S^ OOU 1,. RV recreafiai3iTh -,nn al uof Pe; vehicle. f4) Shores or e-r rica es pleoged m?,, hone or Cer.ficofe owner o '^o zes' e pladge it , (51PSECUwifl _ :loansse_.ve,uvcno• _ • _, , ., ., . . . ol e `ce The. --ciPerce, iaoeRote Arv-`.-, _ __ c u.. on'hec ?:ir•e eur n _ ..e-_::i _ _,_ .. ?.. .. .:. -., l:v ., tae crti„n is not _ r!^ed o e L cn .,,. rt. Mor .lt. ...._ J,prepQi _.. -.:? .. _. .I. tCl.. .i ._:, the C....:co,e to N ..: iao? _ai;. .. - .. <:. v.... -ene,- of oft- Ce 1_.-- ciecaed c no; JI . hh . ?•d ... -. , La .pry ,<.,,PO , n,r. r:,.?<, ? ,. , .._? _? ,. .r. .. .: :.,, ? 1 t ?? X11 :. ?It?f ?l?1!?'~ELV ?l +SY3 CERTIFICATE OF TITLE FOR A VEHICLE i ' y ' 377 Ir; "y=?< 082429999004323-001 j WBAGL63452DP50655 SDN 3011Y TrPE ; DL'F SE IT (:AP t: F' 12/16/02 3/18/08 DATE Po: RTI_ED I DATE OF ISS UF_ 2002 BMW 58297613104 TH vE.1 n' ...,r.E OF VEHICLE TITLE NL'i.':1=,'cR 3/18/081 067193' 0 PF,(-h+ Ti TI E S ATC. I C )CM PFOCD DATE CCOM. MILES I ODO`.f STATUS IRA ALEN 17EIGI IT GVV?R 1 GCVJR TITLE BRANDS REGIS] ERFD OWNER(S) HARRY THOMAS II 207 N COLLEGE ST CARLISLE PA 17013 PSECU FIRST LIEN FAVOR OF; SEGO^ID LIEN FAVOR OF. ODOI,11:'i ER STA I'US 11- ACTUAL MILE?.GE I MILEAGE EXCEEDS -'IF MECHANICAL LIMITS 2- NO'r THE ACTUAL MILEAGE J -- NOT 1'HI ACTl1AL IAY f--A ,F-ODOF.IETER TAMPE=RING VERIFIED 9 - EXEMPT FROM ODOMETER DISCLOSURE TITLE BRANDS A ANTIOUE VEHICLE C = CLASSIC VEI ROLE D = COLLECTIBLE VEHICLF F OUT OF COUNTRY G = ORIGINALLY MFGD. F09 NON-U. S. DISTRIBUTION H = AGRICULTURAL VEHICLE L = LOGGING VF.HICLF P . ISrWAS A POLICE VEHICLE H = RECONSTRUCTED . S = STREET ROD T = RECOVERED THEFT VI_HICLE V = VEHICLE CONTAINS REISSUED VIN W = FLOOD VEHICLE X = ISNJAS A TAXI If a second lienholdcr is listed upon satisfaction of the first Ilan, the !h 'A lionholder must forward Ihis Title to the Bureau of Motor Vehlclos with the FIRST LIEN RELEASED aPPmp,iala form and fee. DATE RY_ SECOND LIEN RELEASED AUTHORIZED D REPRESENTATIVE DATE MAILING ADDRESS BV_` AUTHORIZED REPRESENTATIVE PSECU P 0 BOX 67013 HARRISBURG PA 17106 EXHIBIT 11?1 I certify as of the date of issue, file official records of the Pennsylvania Depamnont of Transportation reflect hat the person(s) or company named herein is the lawful owner • of the Bald vehicle. SUBSCRIBED AND SWORN TO BEFORE ME: 9 1 1:- ] n pl- 1 C wl. T1e 1o he - t. .s...,t..;l ..,,-E Cr 11%'C:A',' OR AU11101IZED S13'.71. s l3ri:.T J:: CF CC.2a PLICA'11 T' -,I E CF AU7I:JR42E] S13%u,1 ALLEN D BIEHLER Secretory of TraesprB9atioe If a co-purchaser other than your spouse is listed and you want the title to be listed as "Joint Tenants With Right of Survivorship" (On death of one owne,, title goes to surviving owner.) CHECK HERE O. Otherwise, the title will be issued as "Tenants in Common' (On death of one owner, Interest of deceased owner goes to his/her heirs or estate). IF NO LIEN, CHECK ? IS THIS AN ELT? (IF YES, FIN REQUIRED) YES ? NOD i 1ST LIENHOLDER FINANCIAL INSTITUTION NUMBER I 1ST I I--NHOLDER NAME STREET 1 CITY STATE ZIP IF NO 2ND LIEN, CHECK ? IS THIS AN ELT I (IF YES, FIN REQUIRED) YES ? NO ? 2ND LIGNHOLDER FINANCIAL INSTITUTION NUMBER. 2ND LIENHOL DER NAME STREET CITY STATE ZIP (TYI L O F. PRIN F) C '1`c? rl l - ar : u:1_'i s a I n _7a(,'ij . Ja: hnkiinq the vehicle for resale. D WARNING rr c ' T E L r r F Hx-1 t ,E 1! JI CTIG 1 H THE T I'ISFc R CF ON FIERSHIP. FAILURE O T., r r 5 ' T; F ES OR Ir.lFfwl t 1. f l A, ASSIGNMENT Or TITLE " ' n :DDLE r,r,!:aE 0 c DIN SE PLAICE 07, DIN _+. G:+, TO BEFG;F i:lF_ ? 7JNE _ n' ?. F-U ?I R'1U ST N l H,1_%"?1,±1T r:Afv1E hiL;l C- N < CD O SIGNATURE OF SFLLER ry a 2! n Q SIGNATURE OF_CO SELLER w )-, SFLLEH AND/OR CD F- I CO SELLER MUST HANDPRINT NAME HERE Q IrWe certify, to the best mf my/our kaovdedge that the odometer reading is • LAST FIRST MIDDLE NAME Cl) rIi N1115 j N 1 X miles and to rlects the actual mileage of t re vehicle, PURCHASER OR FULL BUSINESS NAME unloss one of the following hones is checked: ------'--- --- ,C CO-PURCHA_- Re flects the amount mill Is NOT the actual mileage G ? I r a-xress of its mecha anical al limit s L-1 WARNWG Odometer di;cropanry s fREET O IPNa further certify that Ilia vuh'cle is free of any em:ulnbrance and that the ownership is hereby AOORESS Iranslerred le. the porson(s) or the dealer listed. --?---------- -----" - - -- "--- - -- -- CRY Cn SUBSCRIBED AND SWORN ---------- - - -- ---- ----- w TO BEFORE ME: PURCHASE PRICE' m MO. DAY YEAR STATE Zia OR DIN 07 w a __ SIGNATURE OF PERSON ADIdINISTFRING C1ART pIJH1?11A5F.H SIGNATURE - a -- CI) w hUR?"LIA! H CO IiNA U) - PURCFI-A9Fh AND/OR _ 741aE -_ np CD CO-PURCHASER MUST r 'r 4f fpli`y( iIAA+DPRINT I` AME.IIPRT Q d ____--. 'f v IrI k? O Q / ___i __ I NAl'U1 OI SELI L= ice,, i Ty T' f SELLER MUST I U) - "1 I HANDPRINT NAME HERO al. '?u O I/We certify, to the best of my/our knowk:dgr, that the; odometer reading is LAST FIRST MG IDLE NlJdE W TENTIIa T ___ ._._ _- r -__ __ __ X ntllaG and mflarbi the actual mileage of the vehicle, PURCHASER CA FULL a ce, RUSINE:SS NAME - - unless one of the follow nu boxes Is checked: --- -- ---- --- -- -- "--- - :3 Reflects the amount of mileage Is NOT Ilia actual mileage CO PURCHASFR - - n ? In excess of Its mechanical limits E] WARNING: Odometer discrepancy STREET U) I/We further certify Ihal ilia vehicle is bee of any encumbrance and that the ownership is hereby ADDRESS 03 transferred to the parson(s) or the dealor III ------ - ----- -- - - - - --.---T CD CITY -? SUBSCRIBED AND SWORN - - CD TO BEFORE ME: PURCHASE PRICE m MO. DAY YEAR S-I-ATE ZIP OR DIN O 3 DO SIGNAT'JRL OF PERSON.ADMINISTFRING OATIi KIHCHASEP SI ;'NATURE a -- (D W Cl) : CO_-PURCHA_ R S GNF71jF PURCHASER AND/OR ,A) Q RINT tJA E E E d1 p." r!:. cc (,,E RCHASER MUS cD N SIGNATURE OF ScU ER UST RlNT NAME HERE ILe- 1I II?J:id1?..M??_ ?`r'1 -•I'? ?? ' , C I/We certify, to the best of my/our knowledge that the odometer reading is LAST FIRST Ml[ v[ E NAM-- 73 TENTHS - X miles and reflects The aclual mileage of the vehicle, PURCHASER OF FULL CD r I RUSNF.SS NAM= C unless one of The following boxes is checked: -- - O ? URCHASER J R-llects the amount of mileage is NOT the actual mileage I CO v in excess of its mechanical imits WARNING: Odometer discrepancy ST,,, O IANe further certify that the veh le is tree of any enC a bia rce and that Ilia o•r:nerchip is hereby ADDRESS pT transferred to Il a parsam(' 1 0 the dealer listed. ------ -- N' w SUBSCRIBED AND SWORN j ---------- TO BEFORE ME' I Sli -ATP ZIP PURCHASE PRICE o YEAR OR DIN Q j W G7 C o O v S' > Qi + r- t. i1;ST i.iNi)P,"4iFr7 NAME riERIE PSE(?k 03/11/2009 Via Certified and First Class Mail HARRY THOMAS 207 N COLLEGE ST CARLISLE, PA 17013-2305 NOTICE OF REPOSSESSION AND RIGHT TO REDEEM You are hereby notified that your 2002 BMW 7451 VIN# WBAGL63452DP50655 has been repossessed by the Pennsylvania State Employees Credit Union ("PSECU"). Due to falsified Loan Documentation. The motor vehicle is currently being stored by: Harrisburg Auto Auction, 1100 S York St. Mechanicsburg PA 17055. (717) 697-2222. You may redeem the motor vehicle and terminate the Contract by paying the following amounts on or before 5:00 p.m, on 03/26/2009. Unpaid principal balance $37,429.91 Accrued Interest $230.15 ADDITIONAL COST IF REPOSSESSED MORE THAN 15 DAYS AFTER DEFAULT Storage expense @ $10 per day (3/10/09-3/26/09) $170.00 Total Cost to Redeem $35,515.70 Payment to redeem must be in cash, certified funds or a cashier's check. We will sell the 2002 BMW 7451 at private sale sometime after 03/26/2009. 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. 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. 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. Sincerely, k,- JodiooS 1 Account Advisor 19181tc Pennsylvania State Employees Credit Union Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328 Mailing Address: PO. Box 67013, Harrisburg, PA 17106-7013 • 71 7.777.2100 (TDD) • 800.472.1967 (TDD) psecu.com This vedit union is federally insured by the Nationol Credit Union Adminisfration. Equal Opportunity Lender f C3 • e _ .? r . • -_? . "Ul Postage A .._ i C3 ct'dified Fee !) I M c ... , P(efil ?l It O Return Receipt Fee H SS ! ?? Mere (rndorsament Required) f Restricted Delivery Fee .- (?J? I U C r c ed D' - rO T-9 Total PostE u7 C3 , Sent To - HARRY T I-10 M.-tS _.. _.... , ? S?re2t, Apc _ _ _ - , crPCiHnxP 207 N COLLEGE ST CARLISLE, PA 17013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE Jody S Smith Chief Deputy 0 F T H E P R 0 T11-';N 9 E"'? Richard W Stewart FEB 15 PPS 4: C" Solicitor Pennsylvania State Employees Credit Union Case Number vs. Harry Thomas 2011-901 SHERIFF'S RETURN OF SERVICE 01/27/2011 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: Harry Thomas, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Cambria County, Pennsylvania to serve the within Complaint and Notice according to law. 02/03/2011 09:10 AM - Cambria County Return: And now February 3, 2011 at 0910 hours I, Bob Kolar, Sheriff of Cambria County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Harry Thomas by making known unto himself personally, at FCI Loretta Federal Correctional Institution, RR 276, Loretto, Pennsylvania 15940 it,, contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 February 11, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF No. 11-901-CIVIL FILED-OFFIC, GI .I IIE ?' sOT; 901'dJTAI .. 2N I MAR 24 Ali 11: 17 CUMBERLAND COUNT`,'' PENNSYLVANIA 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. HARRY THOMAS, Defendant No. 11-901-CIVIL PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Harry Thomas, for want of an answer in the amount of $28,267.24 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. O 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. 3159465 am oo (-1 aµ`1 a5?Pa? W,b-ce JAa;(ed No. 11-901-CIVIL (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. BARLEY SNYD LLC Date: By: Shaw . Long, Esquire Court I.D. No. 83774 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: 3159465 No. 11-901-CIVIL 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. HARRY THOMAS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 11-901-CIVIL To: Harry Thomas FCI Loretto Federal Correctional Institution RR 276 Loretto, Pennsylvania 15940 Date of Notice: February 25, 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, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU 31445851 No. 11-901-CIVIL 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 By: Shawn5Xong, Esquire TroyXRider, Esquire Court I.D. No. 83774; 206319 Attorneys for Plaintiff, Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17603 717.299.5201 31445851 No. 11-901-CIVIL 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. HARRY THOMAS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 11-901-CIVIL PROOF OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF LANCASTER : ss. Colleen Brelje, Paralegal, being sworn according to law, deposes and says that she served a true and correct copy of the 10-day Default Notice upon Harry Thomas, FCI Loretto Federal Correctional Institution, RR276, Loretto, Pennsylvania 15940 by regular mail on February 25, 2011 at 5:00 p.m. BARLEY SNYDER LLC By: - bx?c)?? ? a" Colleen Brelje, Paralegal Swoopand subscribed before me 126 East King Street this 9 )"day of M , 2011 Lancaster, PA 17602 717.299.5201 OZ CWWAM& i OF PENNSYLVANIA Notary Public ?ry Public Lisa DesanoSano, Gty Of Rwing,l? county 2014 3144585_1 My Comma Member. Pennvivania Association of Notaries No. 11-901-CIVIL 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 HARRY THOMAS, V. Defendant Attorneys for Plaintiff Pennsylvania State Employees Credit Union COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 11-901-CIVIL 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 Harry Thomas, 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: FCI Loretto Federal Correctional Institution, RR 276, Loretto, PA 15940, 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 unswom falsification to authorities. BARLEY SNYDER LLC By: awn . Long, Esquire Attorneys for Plaintiff Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 3159465