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Home My WebLink About11-2898lna4 a l?? ?n amt, EGOKRT' 0? C p/?/?OX/ P,C? c-owy P"woAof . G?v?'? i9? 1? ? Law , 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 AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION f' 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 r; 1-800-990-9108 717-249-316 co k-4 ;,S-1,3407 a MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. DOCKET NO. / - CIVIL TERM ANGELA M. BRUNGARD, CIVIL ACTION - LAW Defendant COMPLAINT AND NOW, comes the Plaintiff, Michelle Mason, by and through her counsel, R. Mark Thomas, Esquire, and files this Complaint against the Defendant, Angela M. Brungard, and in support thereof respectfully represents: 1. Michelle Mason is an adult individual whose principal residence is located at 806 Grantham Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Angela M. Brungard's last known address was 806 Grantham Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. It is believed that she is currently residing at 13 Andes Drive, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff and Defendant are sisters. 4. By Order dated October 1, 2007, pursuant to a petition filed by the Estate of Richard G. Steele, indexed at Estate No. 21-07-0277, Cumberland County, Pennsylvania, Defendant, Angela M. Brungard, was appointed as Trustee of all proceeds from the Estate of Richard G. Steele payable to Plaintiff, Michelle Mason, who was a minor at that time (attached hereto and marked Exhibit "A" is a copy of the Order dated October 1, 2007). 5. Defendant established a custodial account at Members 1" Federal Credit Union. 6. The monies placed into the account were divided between a Certificate of Deposit and a Money Management Account. 7. The total funds held in the custodial account by Defendant were in excess of $21,000.00. 8. Plaintiff obtained the age of majority on November 12, 2009. 9. Since obtaining the age of majority, plaintiff has made numerous requests and demands of Defendant to transfer control over the funds held in the custodial account to Plaintiff. 10. To date, Defendant continues to refuse to turn these proceeds over to the Plaintiff. 11. Plaintiff has made inquiries at Members 1 sc Federal Credit Union and has been advised that the monies held in the custodial account were withdrawn by Defendant. BREACH OF FIDUCIARY DUTY - COUNT I 12. Paragraphs 1 through 11 are incorporated herein as if set forth at length. 13. As Trustee of the custodial account for the benefit of Plaintiff, Defendant owed Plaintiff a fiduciary duty of care with respect to the monies held in trust. 14. It is believed and, therefore, averred that the Defendant has removed the monies held in trust and used them for her personal benefit. WHEREFORE, Plaintiff, Michelle Mason, prays that this Honorable Court will enter judgment in favor of Plaintiff and against the Defendant, Angela M. Brungard, in an amount at least equal to $21,521.29 plus costs, attorneys fees, and any other monies recoverable. COUNT II - CONVERSION 15. Paragraphs 1 through 14 are incorporated herein as if set forth at length. 16. It is believed and, therefore, averred that the Defendant has unlawfully converted monies belonging to plaintiff to Defendant's use and benefit. WHEREFORE, Plaintiff, Michelle Mason, prays that this Honorable Court will enter judgment in favor of plaintiff and against the Defendant, Angela M. Brungard, in an amount at least equal to $21,521.29 plus costs, attorneys fees, and any other monies recoverable. Respectfully submitted, /7? '4( -AA R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 Email: rmarkthomasna amail com IN RE: ESTATE OF RICHARD G. STEELE . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA ESTATE NO. 21-07-0277 ORDER APPROVING JOINT PETITION TO TERMINATE SPECIAL NEEDS TRUST PURSUANT TO 20 PA. C.S.A. SECTION 6102(a) AND NOW, this / a day of 0cxv ? , 2007, after consideration of the Joint Petition to Terminate DEBRA MASON SPECIAL NEEDS TRUST pursuant to Section 6102 (a) of the Probate, Estates and Fiduciaries Code of 1972, as amended, and following a hearing there- on, and it is Ordered and Decreed that the DEBRA MASON SPECIAL NEEDS TRUST established under ITEM 2 C. of the Last Will and Testament of Richard G. Steele, is hereby TERMINATED. It is further Ordered and Decreed that any vested or non-vested, minor beneficial rights, entitlements, interests or claims in the DEBRA MASON SPECIAL NEEDS TRUST established under paragraph 2 C of the Last Will and Testament of Richard G. Steele, are hereby EXTINGUISHED. Any and all estate proceeds payable to Michelle Mason, a minor, in accordance with the the attached Petition shall be held in trust through acustodial account, by Angela Brungard, until the majority of said Michelle Mason, upon which said funds shall be paid to Michelle Mason. BY THE COIIRT_ -- Andrew C. Sheely, Esquire Attorney for Petitioners bl-I0/TT `? r VERIFICATION I, MICHELLE MASON, hereby verify that the statements made in the foregoing Injunction are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: Z 2,3 261 MICHELLE MASON MICHELLE MASON, IN THE COURT OF COMMON PLW A I C7- Plaintiff CUMBERLAND COUNTY, PENNS ,VANIA' ...0 ? ---- - vs. DOCKET NO. _? CIVIC & Ra co ANGELA M. BRUNGARD, CIVIL ACTION - LAW' Defendant -; . INJUNCTION AND NOW, comes the Plaintiff, Michelle Mason, by and through her counsel, R. Mark Thomas, and hereby requests this Court to enter an injunction in favor of Plaintiff and against the Defendant and in support thereof respectfully represents: 1. Attached hereto and marked Exhibit "A" is a Complaint filed by the Plaintiff alleging a breach of fiduciary duty and conversion against the Defendant, Angela M. Brungard. 2. Due to statements made by the Defendant, Angela M. Brungard, admitting that she no longer has all the monies previously held by Defendant in a custodial account for the benefit of Plaintiff, Plaintiff believes and therefore avers that Defendant has not only converted Plaintiff's funds to Defendant's personal use in the past, but continues to do so. 3. In addition, Plaintiff has received two (2) 1099-INT forms from Members 1 ` Federal Credit Union which indicates that Plaintiff owes tax on interest income she never received (attached hereto and marked Exhibit `B"). 4. Plaintiff received an income statement from Metro Bank stating that Plaintiff redeemed Bonds on December 27, 2010, when, in fact, Plaintiff did not redeem any bonds (attached hereto and marked Exhibit "C"). 5. It is believed and therefore averred that Defendant is withdrawing funds which belong to Plaintiff, and concealing from Plaintiff the amounts and location of these funds. 6. Defendant refuses to divulge to Plaintiff any information regarding the Plaintiff s monies held by Defendant. 7. Defendant is without sufficient means to replace the funds already converted to Defendant's benefit and will not be able to replenish any funds hereafter converted to the Defendant's benefit. 8. Plaintiff will be irreparably harmed if this Court does not enjoin the Defendant from the use of funds properly belonging to Plaintiff. WHEREFORE, Plaintiff, Michelle Mason, request that this Court enter the Order attached hereto which sets forth the following items of relief for the benefit of Plaintiff: A. Defendant, Angela M. Brungard, is hereby ordered to provide the Court with an accounting for all funds held by Defendant for the benefit of Plaintiff pursuant to the Court Order of October 1, 2007; B. To the extent that any funds belonging to Plaintiff are still held by the Defendant, the Defendant is hereby enjoined from the use of such funds; C. The Defendant is hereby directed to deposit any funds remaining in Defendant's possession and belonging to the Plaintiff into the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania; and D. A hearing on this request for an injunction is hereby scheduled for the day of .2011. Plaintiff further prays that this Honorable Court will award Plaintiff attorneys fees from the Defendant incurred as a result of the filing of this Injunction. Respectfully submitted, R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 Email: rmarkthomasAgmail.com J J VERIFICATION I, MICHELLE MASON, hereby verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: MICHELLE MASON MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. DOCKET NO. CIVIL TERM ANGELA M. BRUNGARD, CIVIL ACTION -LAW Defendant COMPLAINT AND NOW, comes the Plaintiff, Michelle Mason, by and through her counsel, R. Mark Thomas, Esquire, and files this Complaint against the Defendant, Angela M. Brungard, and in support thereof respectfully represents: 1. Michelle Mason is an adult individual whose principal residence is located at 806 Grantham Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Angela M. Brungard's last known address was 806 Grantham Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. It is believed that she is currently residing at 13 Andes Drive, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff and Defendant are sisters. 4. By Order dated October 1, 2007, pursuant to a petition filed by the Estate of Richard G. Steele, indexed at Estate No. 21-07-0277, Cumberland County, Pennsylvania, Defendant, Angela M. Brungard, was appointed as Trustee of all proceeds from the Estate of Richard G. Steele payable to Plaintiff, Michelle Mason, who was a minor at that time (attached hereto and marked Exhibit "A" is a copy of the Order dated October 1, 2007). 5. Defendant established a custodial account at Members 1s' Federal Credit Union. 6. The monies placed into the account were divided between a Certificate of Deposit and a Money Management Account. 7. The total funds held in the custodial account by Defendant were in excess of $21,000.00. 8. Plaintiff obtained the age of majority on November 12, 2009. 9. Since obtaining the age of majority, Plaintiff has made numerous requests and demands of Defendant to transfer control over the funds held in the custodial account to Plaintiff. 10. To date, Defendant continues to refuse to turn these proceeds over to the Plaintiff. 11. Plaintiff has made inquiries at Members 1 s' Federal Credit Union and has been advised that the monies held in the custodial account were withdrawn by Defendant. BREACH OF FIDUCIARY DUTY - COUNT I 12. Paragraphs 1 through 11 are incorporated herein as if set forth at length. 13. As Trustee of the custodial account for the benefit of Plaintiff, Defendant owed Plaintiff a fiduciary duty of care with respect to the monies held in trust. 14. It is believed and, therefore, averred that the Defendant has removed the monies held in trust and used them for her personal benefit. WHEREFORE, Plaintiff, Michelle Mason, prays that this Honorable Court will enter judgment in favor of Plaintiff and against the Defendant, Angela M. Brungard, in an amount at least equal to $21,521.29 plus costs, attorneys fees, and any other monies recoverable. COUNT II - CONVERSION 15. Paragraphs 1 through 14 are incorporated herein as if set forth at length. 16. It is believed and, therefore, averred that the Defendant has unlawfully converted monies belonging to Plaintiff to Defendant's use and benefit. WHEREFORE, Plaintiff, Michelle Mason, prays that this Honorable Court will enter judgment in favor of Plaintiff and against the Defendant, Angela M. Brungard, in an amount at least equal to $21,521.29 plus costs, attorneys fees, and any other monies recoverable. Respectfully submitted, R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 Email: rmarkthomasa mail com OCT 012007 r I IN RE: ESTATE OF RICHARD G. STEELE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE NO. 2.1-07-0277 ORDER APPROVING JOINT PETITION TO TERMINATE SPECIAL NEEDS TRUST PURSUANT TO 20 PA. C.S.A. SECTION 6102(a) AND NOW, this / rr day of occy d--r- , 2007, after consideration of the Joint Petition to Terminate DEBRA MASON SPECIAL NEEDS TRUST pursuant to Section 6102 (a) of the Probate, Estates and Fiduciaries Code of 1972,.as amended, and following a hearing there- on, and it is ordered and Decreed that the DEBRA MASON SPECIAL NEEDS TRUST established under ITEM 2 C. of the Last Will and Testament of Richard G. Steele, is hereby TERMINATED. It is further ordered and Decreed that any vested or non-vested, minor beneficial rights, entitlements, interests or claims in the DEBRA MASON SPECIAL NEEDS TRUST established under paragraph 2 C of the Last Will and Testament of Richard G. Steele, are hereby EXTINGUISHED. Any and all estate proceeds payable to. Michelle Mason, a minor, in accordance with the the attached Petition shall be held in trust through a'..custod Al account, by Angela Brungard, until the majority of said Mi.ehelle Mason, upon which said funds shall be paid to Michelle Mason. BY THE COURT. Andrew C. Sheely, Esquire Attorney for Petitioners 1 VERIFICATION I, MICHELLE MASON, hereby verify that the statements made in the foregoing Injunction are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: 22,3 -2-61 MICHELLE MASON a ? CORRECTED (d checked) PAYER'S na, ,rreet address, city, state, and ZIP , .. a and telephone no. Payer's RTN (optional) 1MB No. 1545-0112 MEMBERS 1ST FEDERAL CREDIT UNION 1 Interest income 2j Oj O 5000 LOUISE DRIVE P.O. BOX 40 $ 19.10 [L? MECHANICSBURG PA 17055 2 Early withdrawal penalty (800) 283-2328 $ 12.56 Form 1099-INT PAYERS federal idard ication number RECIPIENTS identification number 3 Interest on U.S. Savings Bonds and Treas. obligations 23-1360906 XXX-XX-4979 $ 0.00 RECIPIENTS name Street address (including apt no.) City, state, and ZIP code 4 Federal income tax withhe 5 Investment expense: MICHELLE N MASON 806 GRANTHAM RD MECHANICSBURG PA 17055 Account number (see instructions) 0000291730 Form 1099-INT Interest Income Copy B For Recipient This is important tax information and is being fumished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if this income is taxable and the IRS determines that it has not been 0.00 $ 0.00 6 Foreign tax paid 7 Foreign country or U.S. $ 0.00 possession 8 Tax-exempt interest 9 Specified private acWly bond btereet $ 0.00 $ 0.00 10 Tax-exempt bond CUSIP no. (see instructions) (keep for your records) Department of the Treasury - Internal Revenue Service U CORRECTED (if checked) PAYER'S nau, .,reel address, city, state, and ZIP and telephone no. Payers RTN (optional) I -vtB No. 1545-0112 MEMBERS 1ST FEDERAL CREDIT UNION 1 Interest income 5000 LOUISE DRIVE P.O. BOX 40 $ 177.80 0IO I MECHANICSBURG PA 17055 2 Early withdrawal penalty ( 800) 283-2328 $ 165.87 Form 1099-INT PAYERS federal identification number RECIPIENTS identification number 3 Interest on U.S. Savings Bonds and Treas. obligations 23-1360906 XXX-XX-4979 $ 0.00 iECIP1ENT'S name Street address (including apt. no.) City, state, and ZIP code 4 Federal income tax withhe 5 Investment expense: MICHELLE N MASON C/O ANGELA M BRUNGARD 806 GRANTHAM RD MECHANICSBURG PA 17055 Account number (see instructions) 0000317303 Form 1099-INT -,/I Interest Income 0.00 $ 0.00 6 Foreign tax paid 7 Foreign country or U.S. $ 0.00 possession 8 Tax-exempt interest 9 Speaifed private acWly bond nterem $ 0.00 $ 0.00 0 Tax-exempt bond CUSIP no. (see instructions) (keep for your records) I>k / BIT Copy B For Recipient This is important tax information and is being famished to the Internal Revenue Service. If you are required to fie a return, a negligence penalty or other sanction may be imposed on yourf this income is taxable and the IRS determines that it has not been Department of the Treasury - Internal Revenue Service 2010 FORM 1099-INT 6 ACCOUNT NO. ACCOUNT NAME 3314015659 BONDS REDEEMED 12/27/10 - INTEREST INCOME STATEMENT INTEREST INCOME EARLY WITHDRAWAL BOND INTEREST FEDERAL PENALTY INCOME TAX 00 .00 WITHHELD 196 88 - . .00 - .00 00 196.88 00 TAX EXEMPT INTEREST: 00 TAX EXEMPT BOND CUSIP NUMBER: PAYER FEDERAL ID NUMBER: 23 2324730 SPECIFIED PRIVATE ACTIVITY BOND INTEREST: .00 FOREIGN TAX PAID: RECIPIENT TAX ID NUMBER: XXX XX 4979 .00 FOREIGN COUNTRY: Copy B for Recipient This Is Important tax Information and Is being furnished to the Internal Revenue Service. H you are required to file a return. a negligence penalty or other sanction may be imposed on you if this income is taxable and the IRS determines that it has not been reported. (Keep for your records) orae 1545-01 12 Instructions for Recipient The amount listed under "Interest Income" is the amount of interest paid to you during the calendar year. It may be a total of alt interest paid for the year or it may represent interest paid to you on a single transaction. Financial institutions may report to you either way. If you receive a Form 1099-INT for interest paid on a tax-exempt obligation. please see the instructions for your income tax return Any amount identified as "Federal Tax Withheld" represents backup withholding. For example, persons not furnishing their laxoayer identification number to the payer become subject to backup withholding at a 289; rate on payments shown as "Interest Income". See Form W-9. Request for Taxcayer Identification Number and Certification, for information on backup withholding. Include this amount on your tax return as tax withheld. Any interest or principal that was forfeited due to early withdrawal of time savings may be deducted on your Federal income tax return to calculate your adjusted gross income. See the instructions for Form 1040 for information about where to take the deduction. Interest earned on U. S. Savings Bonds. Treasury Bills, Treasury Bonds, and Treasury Notes may or may not be all taxable. see Publication 550. Investment Income and Expenses. This interest is exempt from state and local income taxes. This interest is not included in the first column entitled Interest Income. You may be able to claim the foreign tax paid as a deduction or a credit on your Form 1040. See your Form 1040 for instructions. If your Federal identification number is shown on this form and the form includes amounts belonging to another person, you are considered a nominee recipient. Complete Form 1099-INT foreach of the other owners showing the income allocable to each. File CopyA of the form with the IRS. Furnish Copy B to each owner. On each Form 1099-INT. list yourself as the "payer" and other owner(s) as the "recipient". File Form(s) 1099-INT with Form 1096. Annual Summary and Transmittal of U.S. Information Returns. with the Internal Revenue Service Center for your area. On Form 1096 list yourself as the "fifer". A husband or wife is not required to file a nominee return to show amounts owned by the other. Any amount identified as tax-exempt interest may be subject to backup withholding. Any Specified Private Activity Bond Interest is subject to the alternative minimum tax. This amount is included in the line entitled Tax-Exempt Interest. See the instructions for Form 6251. PayerslBorrowers identification number. For yourgpotection. this form may show only the last four digits of your SSN, ITIN, or ATTN. However. the issuer has reported your complete identification number to the IF1S and. where applicable, to state and/or local governments. SAYER FEDERAL ID NUMBER: 23-2324730 METRO BANK - 3801 PAXTON ST HARRISBURG PA 17111 (888) 937-0004 RECIPIENT TAX ID NUMBER: XXX-XX-4979 MICHELLE N MASON 806 GRANTHAM RD MECHANICSBURG PA 17055-5880 5 MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSY?VEMIA n I vs DOCKET NO. f - ? CIVI 17j . ANGELA M. BRUNGARD, CIVIL ACTION - LAW ' Defendant ORDER AND NOW, this e day of Z , 2011, the Court being advised that a Complaint has been filed alleging breach of fiduciary duty on the part of Defendant, and an allegation that the Defendant has converted Plaintiff's property to Defendant's personal use, and further, the Court being advised'that Plaintiff remains in possession of at least some of the Plaintiffs property, consisting entirely of cash monies, the Court hereby orders and decrees the following: 1. Defendant, ANGELA BRUNGARD, is hereby ordered to provide the Court with an accounting for all funds held by Defendant for the benefit of Plaintiff pursuant to the Court Order of October 1, 2007; 2. To the extent that any funds belonging to Plaintiff are still held by the Defendant, the Defendant is hereby enjoined from the use of such funds; 3. The Defendant is''hereby directed to deposit any funds remaining in Defendant's possession and belonging to the !Plaintiff into the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania; and Q'4) 4. A hearing on this request for an injunction is hereby scheduled for the ) day of , 20111 OY, a, 5D P•?' i n QbUdkotw- `U. 5 . By the Court, DISTRIBUTION: ""'R. Mark Thomas, Esquire, 101 South Market Street, Mechanicsburg, PA 17055 Angela M. Brungard, 13 Andes Drive, Mechanicsburg, Pennsylvania 17055 006e, Mojled 311011( DKO SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ???w?1tr Qt ?tuuber?i?? 17 PM % L LA Michelle Mason vs. Case Number Angela M. Brungard 2011-2898 SHERIFF'S RETURN OF SERVICE 03/09/2011 07:03 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March 9, 2011 at 1903 hours, he served a true copy of the within Complaint and Noti , upon the within named defendant, to wit: Angela M. Brungard, by making known unto Craig Brungar , F her of Defendant at 13 Andes Drive, Mechanicsburg, Cumberland County, Pennsylvania 1705?t me is and at the same time handing to him personally the said true and correct copy of the same. WN HARRISON, DEPUTY SHERIFF COST: $38.44 March 10, 2011 SO ANSWERS, RON ? R ANDERSON, SHERIFF (c) GQUnsySUte Shutt. Teleosoft Inc MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 11-2898 CIVIL TERM c N Y+ C S BRUNGARD ANGELA M o CIVIL ACTION - LAW r°C -" , . Defendant ,CM ? -? ;:a rn..... r- ? ?' cn 'c' v. ? ° z c a 7 Z CD n DEBRA MASON . :: r l 1 Defendant -'" 51 NOTICE TO PLEAD To: Michelle Mason C/o R. Mark Thomas, Esquire 101 S. Market Street Mechanicsburg, PA 17055 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, Law Office of Joseph L. Hitchings Date: E uire pAttomey h . HIT I.D.# 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Defendant Angela M. Brungard MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOCKET NO. 11-2898 CIVIL TERM ANGELA M. BRUNGARD, CIVIL ACTION -LAW Defendant V. DEBRA MASON Defendant To: Debra A. Mason C/o R. Mark Thomas, Esquire 101 S. Market Street Mechanicsburg, PA 17055 NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING AN ATTORNEY. 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 OR NO FEE. LAWYER REFERRAL SERVICE 4th Floor, Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 MICHELLE MASON, Plaintiff V. ANGELA M. BRUNGARD, Defendant V. DEBRA MASON Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 11-2898 CIVIL TERM : CIVIL ACTION -LAW ANSWER TO COMPLAINT WITH NEW MATTER AND JOINDER COMPLAINT AND NOW, this eday of April, 2011 comes the Defendant, Angela M. Brungard, by and through her undersigned attorney Joseph L. Hitchings, Esquire, and answers Plaintiff's Complaint with New Matter and Joinder Complaint as follows: ANSWER 1. Admitted. 2. Admitted. By way of further answer, Defendant's mailing address is P.O. Box 81, Grantham, Pennsylvania 17027. 3. Admitted. 4. Admitted. By way of further answer, the Order, as a written document speaks for itself. By still further answer, the funds that were to go into the account were an inheritance for Debra Mason, the mother of the parties. However, in order to avoid losing state welfare benefits, the funds were given to the parties and divided evenly between Plaintiff and Defendant Angela Brungard. A true and correct copy of the 2 checks from the inheritance are attached hereto and marked as Exhibit "A". 5. Admitted. 6. Admitted. 7. Denied. The total funds held in the custodial account, No. 317303, never were in excess of $21,000.00. An initial amount of $12,807.58 was placed into a Certificate of Deposit. A subsequent estate disbursement of $987.06 was placed into a Money Management account. 8. Admitted. 9. Admitted in part, Denied in part. It is admitted that Plaintiffs counsel has requested payment of the funds on behalf of his client. However, Plaintiff has never made a request directly to the Defendant for the sums held, as she knew the same was placed in an account for her, and that her mother, Debra Mason was using the funds in Defendant Angela Brungard's account on her behalf. 10. Denied. Defendant has offered to pay over the sums she has in her possession, as part of a global settlement of the issues in this litigation as well as other litigation between Defendant and Debra Mason. Said offer was refused. 11. Admitted. The Members I S` Federal Credit Union account was closed after Plaintiff reached majority age. BREACH OF FIDUCIARY DUTY - COUNT I 12. The answers to paragraphs 1 through 11 hereof are incorporated by reference, as if the same were more fully set forth at length herein. 13. Admitted in part, denied in part. While it is admitted Defendant had fiduciary duties owing to Plaintiff pursuant to the Court Order, it denied that she failed to carry out those duties. 14. Denied. The vast majority of the inheritance funds were withdrawn at the request of Debra Mason from the account belonging to Defendant Angela Brungard for the alleged benefit of Plaintiff. In exchange for Angela Brungard giving her mother access to the funds in Brungard's account, Brungard would receive the funds remaining in the Plantiff s account. WHEREFORE, Defendant, Angela M. Brungard, respectfully requests that judgment be entered against the Plaintiff and in her favor on Plaintiff's Complaint. COUNT II - CONVERSION 15. The answers to paragraphs 1 through 14 hereof are incorporated by reference, as if the same were more fully set forth at length herein. 16. Denied. See answer to paragraph 14 hereof. By way of further answer, the averments of paragraph 16 constitute conclusions of law to which no responsive pleading is required. To the extent the averments are deemed factual in nature, the same are denied and strict proof thereof is demanded at time of trial. WHEREFORE, Defendant, Angela M. Brungard, respectfully requests that judgment be entered against the Plaintiff and in her favor on Plaintiff's Complaint. NEW MATTER 17. Paragraphs 1 through 16 hereof are incorporated herein as if more fully set forth at length. 18. Plaintiff has failed to set forth a cause of action against the Defendant. 19. Plaintiff has failed a join an indispensable party to this action, namely Debra Mason. 20. Plaintiff's claims are barred by the doctrine of accord and satisfaction. WHEREFORE, Defendant, Angela M. Brungard, respectfully requests that judgment be entered against the Plaintiff and in her favor on Plaintiff's Complaint. JOINDER COMPLAINT Angela M. Brungard v Debra Mason 21. Paragraphs 1 through 20 hereof are incorporated herein as if more fully set forth at length. 22. Debra Mason is an adult individual residing at 664 Woodbourne Road, York County, Pennsylvania 17339. 23. The relationship between Angela Brungard and Debra Mason is that of daughter and mother. 24. The relationship between Plaintiff, Michelle Mason and Debra Mason is that of daughter and mother. 25. At all times material hereto, while the Plaintiff, Michelle Mason, was a minor, she was in the custodial care of Debra Mason. 26. At the time of Debra Mason's fathers passing, Debra Mason was to inherit money from the estate. 27. In order to remain eligible for state welfare benefits, it was agreed to split Debra Mason's inheritance between Plaintiff Michelle Mason, and Defendant Angela M. Brungard. 28. At the time of her father's passing, Debra Mason was not working and had limited funds to care for Plaintiff, Michelle Mason. 29. Debra Mason asked Defendant Angela M. Brungard to give her Ms. Brungard's half of the inheritance to use for Plaintiff Michelle Mason, with the agreement that when Michelle Mason turned 18, Defendant Angela Brungard would get Michelle Mason's half of the inheritance. 30. Debra Mason repeatedly came to Defendant Angela Brungard and asked her to remove funds from her inheritance account to be used for Plaintiff, Michelle Mason's benefit. 31. Defendant Angela M. Brungard provided the funds requested to Debra Mason. 32. It is believed and therefore averred that Debra Mason made some withdraws from the account without Defendant Angela M. Brungard's knowledge. 33. It is believed and therefore averred that Debra Mason may have used funds received from Defendant Angela M. Brungard for her own behalf, and not for Plaintiff Michelle Mason. 34. To the extent that Defendant Angela M. Brungard is deemed liable to Plaintiff, Michelle Mason, she asserts a claim for contribution and/or indemnity against Debra Mason, and asserts that she is solely liable to the Plaintiff, or in the alternative is liable over to Defendant Angela M. Brungard for contribution and/or indemnity on the claims raised in Plaintiff's Complaint. Respectfully submitted, Law Office of Joseph L. Hitchings Date: At-(j--j ( _ -? ;Joseph L. rtchings, uir Attorney I.D.# 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Defendant Angela M. Brungard VERIFICATION I, Angela M. Brungard, verify that the statements made in this Answer are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date Angela M. Brungard EXHIBIT "A" Richard Steele Estate 1K,enneth D Steele, Administrator 1929 Fisher Rd Mechanicsburg, PA 17055 BELCO !;mMu j(y credit UnIm wv v b,d..-g (7)7)232-3526 - (800)612.4492 >I: 1:2 3 1 38099 71: 0008606154 1009 Richard Steele Estate Kenneth D Steele, Administrator 1929 Fisher Rd Mechanicsburg, PA 17055 1009 60-809912313 J_ ? - zeepA??,aATE 1010 60-8098/2313 ?? 26 Zm " oArE PAYTOTHEyei??u ORDER TV 7 s ,arsa? /Y?bLLARS a.BELCO wwwbeim.ory (717) 232-3526 - (800) 642.4482 1 'OR :2 3 1 38099 71: 0008606154?i 1010 MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOCKET NO. 11-2898 CIVIL TERM ANGELA M. BRUNGARD, CIVIL ACTION -LAW Defendant V. : DEBRA MASON Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service via First Class US Postal Services Postage Pre-paid R. Mark Thomas, Esquire 101 S. Market Street Mechanicsburg, PA 17055 Law Office of Joseph L. Hitchings Date: W-):f- I I - oseph L. itchings, squire Attorney I.D.# 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Defendant Angela M. Brungard MICHELLE MASON, Plaintiff V. ANGELA M. BRUNGARD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 11-2898 CIVIL TERM CIVIL ACTION - LAW ANSWER TO INJUNCTION REQUEST rn Cc A =-n cn r -<> - ? CJ- o, ;z ---+c? F ca -C -n < AND NOW, this 46ay of April, 2011 comes the Defendant, Angela M. Brungard, by and through her undersigned attorney Joseph L. Hitchings, Esquire, and answers Plaintiff s Injunction request as follows: ANSWER 1. The Complaint as a written document speaks for itself. Defendant herein incorporates her Answer with New Matter and Joinder Complaint as if the same were more fully set forth at length. 2. See Answer to paragraphs 11 through 16 of Defendants Answer to Plaintiff s Complaint. 3. Admitted in part, denied in part. While it may be admitted that Plaintiff received 2 1099 -INT forms from Members 1 S` Federal Credit Union, it is denied that she didn't receive the income on the accounts, particularly account No. 291730, which is Plaintiff s personal account. 4. Denied. Defendant has never redeemed any bonds belonging to the Plaintiff at Metro Bank. 5. Denied. Prior to this litigation, Defendant had not spoken to Plaintiff since July 6, 2010. Moreover it is believed and therefore averred that representatives of Members 1" Federal Credit Union advised the Plaintiff where the funds were transferred and the amount transferred. By way of further answer and as alleged in response to Plaintiff s Complaint, Plaintiff s mother Debra Mason, requested withdrawals from Defendant Angela M. Brungard's account over a period of time to be used for Plaintiff. The understanding was in exchange for granting access to her account; Defendant Brungard would receive the funds in Plaintiff s account after she turned age 18. 6. Denied. By way of further answer see answer to paragraph 5 hereof. 7. Admitted in part, denied in part. Defendant does not have the funds withdrawn by Debra Mason, nor is she able to account for what Debra Mason may have done with the funds. As stated above, the inheritance funds were divided evenly between Plaintiff and Defendant Brungard. Each was to receive 50%. Debra mason used the 50% belonging to Plaintiff over a period of time. The remaining 50% was used by the Defendant. 8. Denied. Any funds the Defendant may have used were the funds belonging to her based on the agreement she had with Debra Mason. WHEREFORE, Defendant Angela M. Brungard respectfully requests that the Court deny Plaintiffs request for injunctive relief. Respectfully submitted, Law Office of Joseph L. Hitchings Date: /Attorney eph L. Hitching , squire I.D.# 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Defendant Angela M. Brungard VERIFICATION I, Angela M. Brungard, verify that the statements made in this Answer are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date Ange a M. Brung d MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 11-2898 CIVIL TERM ANGELA M. BRUNGARD, CIVIL ACTION -LAW Defendant V. CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service via First Class US Postal Services Postage Pre-paid R. Mark Thomas, Esquire 101 S. Market Street Mechanicsburg, PA 17055 Law Office of Joseph L. Hitchings Date:. y ? - ?'. V?oseph L i chings, uire Attorney I.D.# 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Defendant Angela M. Brungard ', f - . 1 MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 11-2898 CIVIL TERM ANGELA M. BRUNGARD, CIVIL ACTION -LAW Defendant M ` --a ' s u ACCOUNTING OF DEFENDANT ANGELA M. BRUNGA, AND NOW, this '? b?day of April, 2011 comes the Defendant, Angela M. Brungard, by and through her undersigned attorney Joseph L. Hitchings, Esquire, and files the following accounting: EXHIBIT A : Bank Account Statements of Defendant's Members 1St Federal Credit Union from June 25, 2010 through March 15, 2011. The funds that were transferred into this account were used for the living expenses of Defendant, including, rent, car maintenance, groceries, and school related expenses. EXHIBIT B: Members 1St Federal Credit Union receipt reflecting withdraw from Defendant's account in the amount of $ 836.99 EXHIBIT C : Receipt for Payment from the Cumberland County Prothonotary's office for payment in the amount of $ 836.99, dated April 15, 2011. Respectfully submitted, 71C Office of Joseph L. Hitchings Date: 44-At-It seph L. H tc mgs, Es Attorney I.D.# 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Defendant Angela M. Brungard EXHIBIT "A" St MEMBERS 1St FEDERAL CREDIT UNION Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.mambersIst.org Main Switchboard: (717) 697-1161 or (800) 283-2328 EZ Cali: (717) 697-4372 or (800) 283-4372 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (717) 795-6049 or (800) 237-7288 ANGELA M BRUNGARD P.O. BOX 81 GRANTHAM PA 17027 Statement of Accounts Jun 25, 2010 thru Jul 24, 2010 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates: 4,519.15 Loans: 0.00 Money Management: 11,719.75 Swipe 5 YTD Reward: 0.50 Page: 1 of 2 Your current Member Loyalty Rewards level is Silver. Your aggregate balance as of July 1st is $6,610.37. An aggregate balance of $15,000 and having 3 products will move you to the Gold level. Member Loyalty Rewards. Advice that saves you money. Please read the enclosed insert for more details. CHECKING ACCOUNTS 0011- FOOD MONEY Date Transaction Description Additions Subtractions Balance Jun 25 Balance Forward 0.00 Jul 24 Ending Balance 0.00 SAVINGS ACCOUNTS 0000- ATLANTIC CITY MONEY Jun 25 Jul 02 Jul 02 Jul 24 Balance Forward Deposit Transfer From Share 0005 Withdrawal Ending Balance 1,085.62 1,085.84- 5. 22 1,090.84 5.00 5.00 , f = Date Transaction Description Additions Subtractions Balance Jun 25 Balance Forward 1,085.53 Jun 30 Deposit Dividend "tiered Rate 0.09 1;085.62 Annual Percentage Yield Earned 0. 100% from 0610117010 through 0613012010 Jul 02 Withdrawal Transfer To Share 0000 1,085.62- 0.00 Jul 02 Deposit Transfer From MASON MlCHELt1rX7C , ° 'Shar$ 0x40 13,935.24 13,935.24 Jul 02 , Deposit Transfer ' 2,655.37 16,590.61 From MASON,MICHELLE'XXXXXXXX' Sh'ale 0000 Jul 02 Withdrawal 1,020.38- 15,570.23 Jul 07 Withdrawal 850.48- 14,719.75 Jul 07 Withdrawal 1,000.00- 13,719.75 Jul 23 Withdrawal 2,000.00- 11,719.75 Jul 24 Ending Balance 11,719.75 --- Continued on following page --- nd Inquires to: Y Se 5000 Louise Drri ve Main Switchboard: (717) 697-1161 or (800) 283-2328 Po sox ao Ez call: (717) 697-4372 or (800) 283-4372 Jun 25, 2010 thru Jul 24, 2010 1VT Mechanicsburg, PA 17055 Too: (717) 697-5312 or (800) 283-2328 ext. 5312 Account Number: 283092 LEERS-11 i TeleBranch: (717) 795-6049 or (800) 237-7288 www.memberslst.org Page: 2 of 2 CERTIFICATE ACCOUNTS 0046 - 11 MONTH CERT Maturity Date - Apr 03, 2011 Date Transaction Description Additions Subtractions Balance Jun 25 Balance Forward 3,324.00 Jun 30 Deposit Dividend 1. 390% 3.80 3,327.80 Annual Percentage Yield Earned 1.400% from 06/01/2010 through 0613012010 Jul 24 Ending Balance 3,327.80 0047 - 19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Jun 25 Balance Forward 1,189.75 Jun 30 Deposit Dividend 1. 640°/n 1.60 1,191.35 Annual Percentage Yield Earned 1. 650% from 0610112010 through 0613012010 Jul 24 Ending Balance 1,191.35 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 0.53 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 7.34 0047 19 MONTH CERT 2.88 Total Year To Date Dividends Paid 50.04 NOTE: Total includes closed shares' Add Your Photo For Security Your pemonal safety and financial security are top priorities at Members 1st. As a result of increased,scams and fraudulent activity throughout the entire country, we are strongly encouraging members to have their photos added to their account records. When visiting our branch s, you may be asked by one of our Associates to allow us to take your photo. Th is member identification program will assist in our fraud deterrence initiatives and will take our ident ' theft prevention program to the next level. We are experiencing an increasing number of attemp.W fraudulent act ivities and as a result, we need to be able to verify your identity immediately upon retrieving your account information. In addition to having your photo in our files you may be required to show additional forms of identification base on the type of transacts n you are seeks g This is for your protection and security and we appreciate your ongoing cooperation and understanding. St MEMBERS 1St FEDERAL CREDIT UNION Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.memberslst.org Main Switchboard: (717) 697-1161 or (800) 283-2328 EZ Call: (717) 697-4372 or (800) 283-4372 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (717) 795-6049 or(800)237-7288 ANGELA M BRUNGARD P.O. BOX 81 GRANTHAM PA 17027 Statement of Accounts Jul 25, 2010 thru Aug 24, 2010 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates: 4,524.74 Loans: 0.00 Money Management: 10,523.97 Swipe 5 YTD Reward: 0.50 Page: 1 of 2 Your current Member Loyalty Rewards level is Gold. Your aggregate balance as of August 1st is $16,794.48. An aggregate balance of $35,000 and having 3 products willmove you to the Platinum level. Buying or building a home? Attend one of our FREE seminars! See the enclosed insert for more details. CHECKING ACCOUNTS 0011 - FOOD MONEY Date Transaction Description Additions Subtractions Balance Jul 25 Balance Forward 0.00 Aug 24 Ending Balance 0.00 SAVINGS ACCOUNTS 0000 ATLANTIC CITY MONEY ?ul, zo ralarance Forward 5.00 Aug 24 Ending Balance 5.00 natty Tcma*artinnrlaanr:infinn' AA.lt+i- Jul 4o Malance Forward 11, 719.75 Jul 31 Deposit Dividend Tiered Rate 4.42 11,724.17 Annual Percentage Yield Earned 0. 400'/ from 0 7101120 1 01hro ugh 0'71312010 Aug 23 Withdrawal 1,200.20- 10,523.97 Aug 24 Ending Balance 10,523.97 CERTIFICATE ACCOUNT" ; 0046 - 11 MONTH CERT Maturity 'Datb Apr 03,x:.24'11. DateTransat:lion Description Additions Subtractions Balance Jul 25 Balance Forward 3,327.80 Jul 31 Deposit Dividend 1. 390% 3.93 3,331.73 Annual Percentage Yield Earned 1. 400% from 071012010 through 07/31/2010 Aug 24 Ending Balance 3,331.73 --- Continued on following page --- t Send Inquires to: Main Switchboard: (717) 697-1161 or (800) 283-2328 rVT 5000 Louise Drive EiZ Call: (717) 697-4372 or (800) 283-4372 Po Box 40 TDD Jul 25, 2010 thru Aug 24, 2010 Mechanicsburg, PA 17055 (717) 697-5312 or (800) 283 2328 ext. 5312 Account Number: 283092 MEMBERS I* TeleBranch: (717) 795-6049 or (800) 237-7288 .. o? , .. www.membersist.org Page: 2 Of 2 0047 - 19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Jul 25 Balance Forward 1,191.35 Jul 31 Deposit Dividend 1. 640% 1.66 1,193.01 Annual Percentage Yield Earned 1.650% from 0710112010 through 07/31/2010 Aug 24 Ending Balance 1,193.01 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 4.95 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 11.27 004719 MONTH CERT 4.54 Total Year To Date Dividends Paid 60.05 NOTE: Total includes closed shares Don't forget about our new Member Loyalty Rewards Program. The more products you have with us, the more benefits you'll receive. Ask an associate for details or visit our website at www.memberslst.org for details. St MEMBERS 1St FEDERAL CREDIT UNION Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.membersl st.org Main Switchboard: (717) 697-1161 or (800) 283-2328 EZ Call: (717) 6974372 or (800) 2834372 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (717) 795-6049 or(800)237-7288 ANGELA M BRUNGARD P.O. BOX 81 GRANTHAM PA 17027 Statement of Accounts Aug 25, 2010 thru Sep 24, 2010 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates: 4,530.33 Loans: 0.00 Money Management: 9,350.24 Swipe 5 YTD Reward: 0.50 Page: 1 of 2 Your current Member Loyalty Rewards level is Gold. Your aggregate balance as of September 1st is $15,419.36. An aggregate balance of $35,000 and having 3 products will move you to the Platinum level. Visit any of our branch locations on Thursday, October 21, 2010 and join us in celebrating International Credit Union Day. CHECKING ACCOUNTS 0011 - FOOD MONEY Date Transaction Description Additions Subtractions Balance Aug 25 Balance Forward 0.00 Sep 24 Ending Balance 0.00 SAVINGS ACCOUNTS 0000 - ATLANTIC CITY MONEY Aug 31 Deposit Dividend Tiered Rate 3.86 10,527.83 Annual Percentage Yleld Earned 0.400% from 68101120104hrough 0813112010 Sep 08 Withdrawal 677.59- 9,850.24 Sep 08 Withdrawal 500.00- 9,350.24 Sep 24 Ending Balance 9,350.24 CERTIFICATE ACCOUNTS 0046. 11 MONTH CERT Maturity Date - Apr 03, 2011 Aug 25 Balance Forward 3,331.73 Aug 31 Deposit Dividend 1. 390% 3.93 3,335.66 Annual Percentage Yield Earned 1. 400% from 0810112010 through 0813112010 Sep 24 Ending Balance 3,335.66 --- Continued on following page --- t Send Inquires t Main Switchboard: (717) 697-1161 or (800) 283-2328 fVT 5000 Louise Drive EZ Call: Po Box ao (717) 697-4372 or (800) 283-4372 Aug 25, 2010 thru Sep 24, 2010 Mechanicsburg, PA 17055 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 Account Number: 283092 MEMBERS V TeleBranch: (717) 795-6049 or (800) 237-7288 www.memberslst.org Page: 2 of 2 0047 - 19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Aug 25 Balance Forward 1,193.01 Aug 31 Deposit Dividend 1 .640% 1.66 1,194.67 Annual Percentage Yield Earned 1. 650% from 0810112010 through 0813112010 Sep 24 Ending Balance 1,194.67 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 8.81 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 15.20 004719 MONTH CERT 6.20 Total Year To Date Dividends Paid 69.50 NOTE: Total includes closed shares Add Your Photo For Security Your personal safety and financial security are top priorities at Members 1 St. As a result of increased scams and fraudulent activity throughout the entire country, we are strongi encouraging members to have their photos added to their account records. When visiying our branch offices, you may be asked by one of our Associates to allow us to take your photo. This member identification program will assist in our fraud deterrence initiatives and will take our Identity theft prevention program to the next level. We are experiencing an increasing number of attempted fraudulent activities and as a result, we need to be able to verify your identity immediately upon retrieving your account information. In addition to having your photo in our files, you may be required to show additional forms of iden ication based on the type of transaction you are seeking This is for your protection and security and we appreciate your ongoing cooperation and understanding. 1ki MEMBERS 1St FEDERAL CREDIT UNION Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.membersist.org Main Switchboard: (717) 697-1161 or (800) 283-2328 EZ Call: (717) 697-4372 or (800) 283-4372 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (717) 795-6049 or(800)237-7288 ANGELA M BRUNGARD P.O. BOX 81 GRANTHAM PA 17027 Statement of Accounts Sep 25, 2010 thru Oct 24, 2010 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates: 4,535.75 Loans: 0.00 Money Management: 320.24 Swipe 5 YTD Reward: 0.50 Page: 1 of 2 Your current Member Loyal Rewards level is Silver. Your aggregate balance as of October 1st is $12,564.21. An aggregate balance of $15,000 and having 3 products will move you to the Gold level. We make it easy to transfer between financial institutions. See the enclosed insert for more details. CHECKING ACCOUNTS 0011 - FOOD MONEY Date Transaction Description Additions Subtractions Balance Sep 25 Balance Forward 0.00 Oct 24 Ending Balance 0.00 SAVINGS ACCOUNTS 0000- ATLANTIC CITY MONEY ding Bstance lance 5.00 5.00 #i13Di6 -,;-1t1lT , Date Transap oa Description Additions Subtractions Balance Sep 25 Balance Forward 9,350.24 Sep 27 Withdrawal 545.80- 8,804.44 Sep 27 Withdrawal 850.00- 7,954.44 Sep 30 Deposit Dividend Tiered Rate 3.10 7,957.54 Annual Percentage Yield Earned 0. 400% from 0910112010 through 0913012010 Oct 12 Withdrawal 637.30- 7,320.24 Oct 12 Withdrawal by Check 7,000.00- 320. 24 Oct 24 Ending Balance 320. 24 CERTIFICATE ACCOUNTS 0046 - 11 MONTH CERT Maturity Date - Apr 03, 2011 Date Transaction Description Additions Subtractions Balance Sep 25 Balance Forward 3,335.66 Sep 30 Deposit Dividend 1 .390% 3.81 3,339.47 Annual Percentage Yield Earned 1. 400% from 0910112010 through 0913012010 ... Continued on following page --- twit MEMBERS I' Send Inquires to: Main Switchboard: (717) 697-1161 or (800) 283-2328 5000 Louise Drive EZ Call: (717) 697-4372 or (800) 283-4372 Po sox ao Sep 25, 2010 thru Oct 24, 2010 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 Mechanicsburg, 17055 TeleBranch: (717) 795-6049 or (800) 237-7288 Account Number: 283092 www.memberslst.org Page: 2 of 2 Date Transaction Description Additions Subtractions Balance Oct 24 Ending Balance 3,339.47 0047- 19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Sep 25 Balance Forward 1,194.67 Sep 30 Deposit Dividend 1.640% 1.61 1,196.28 Annual Percentage Yield Earned 1. 650% from 0910112010 through 0913012010 Oct 24 Ending Balance 1,196.28 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 11.91 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 19.01 0047 19 MONTH CERT 7.81 Total Year To Date Dividends Paid 78.02 NOTE: Total includes closed shares Don't forget about our new Member Loyalty Rewards Program. The more roducts ou have with th s b efit 'll i p y e more u , en s you rece ve. Ask an associate for details or visit our website at www.memberslst.org for details. A MEMBERS 1St FEDERAL CREDIT UNION Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.membemist.org Main Switchboard: (717) 697-1161 or (800) 283-2328 EZ Calf: (717) 697-4372 or (800) 283.4372 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (717) 795-6049 or(800)237-7288 ANGELA M BRUNGARD P.O. BOX 81 GRANTHAM PA 17027 Statement of Accounts Oct 25, 2010 thru Nov 24, 2010 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates: 4,541.36 Loans: 0.00 Money Management: 4,219.58 Swipe 5 YTD Reward: 0.50 Page: 1 of 2 Your current Member Loyalty Rewards level is Silver. Your aggregate balance as of November 1st is $5,372.59. An aggregate balance of $15,000 and having 3 products will move you to the Gold level. Need the perfect gift for someone on your gift list? Give them a Visa Prepaid Gift Card. For more information visit www.memberslst.org/VisaGiftCards.aspx. CHECKING ACCOUNTS 0011 - FOOT) MONEY - Date Transaction Description _ Additions - Subtractions Balance Oct 25 Balance Forward 0.00 Nov 24 Ending Balance 0.00 SAVINGS ACCOUNTS 0000- ATLANTIC CITY MONEY Oct 25 Balance Forward 5.00 Nov 24 Ending Balance 5.00 Date Transaction Description Additions Subtractions Balance Oct 25 Balance Forward 320.24 Oct 31 Deposit Dividend Tiered Rate 0.98 321.22 Annual Percentage Yield Earned 0. 380.9 from J010112010=through 1013112010 Nov 03 Deposit by Check 5,800.22 6,121.44 Nov 23 Withdrawal 401 , 86- 5,719.58 Nov 23 Withdrawal 1,500.00- 4,219.58 Nov 24 Ending Balance 4,219.58 CERTIFICATE ACCOUNTS ; 0046 - 11 MONTH CIRT Maturity Date - Apr 03, 2011 Date Transaction Description Additions Subtractions Balance Oct 25 Balance Forward 3,339.47 Oct 31 Deposit Dividend 1. 390% 3.94 3,343.41 Annual Percentage Yield Earned 1. 400% from 1010112010 through 1013112010 Nov 24 Ending Balance 3,343.41 --- Continued on following page --- T t Send Inquires to: Main Switchboard: (717) 697-1161 or (800) 283-2328 5000 ?PO Box 40 Louise Drive EZ Call: (717) 697-4372 or (800) 283-4372 Oct 25, 2010 thru Nov 24, 2010 Mechanicsburg, PA 17055 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 Account Number: 283092 MEMBERS r TeleBranch: (717) 795-6049 or (800) 237-7288 ?.. a? www.memberslst.org Page: 2 of 2 0047 - 19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Oct 25 Balance Forward 1,186.28 Oct 31 Deposit Dividend 1.640%0 1.67 1,197.95 Annual Percentage Yield Earned 1. 660% from 1010112010 through 1013112010 Nov 24 Ending Balance 1,197.95 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 12.89 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 22.95 0047 19 MONTH CERT 9.48 Total Year To Date Dividends Paid 84.61 NOTE: Total includes closed shares Add Your Photo For Security Your personal safety and financial security are top priorities at Members 1st. As a result of increased scams and fraudulent activity throughout the entire country, we are strongly encouraging members to have their photos added to their account records. When visiting our branch offices, you may be asked by one of our Associates to allow us to take your photo. This member identification program will assist in our fraud deterrence initiatives and will take our identity theft prevention program to the next level. We are experiencing an increasing number of attempted fraudulent activities and as a result, we need to be able to verify your identity immediately upon retrieving your account information. In addition to having your photo In our files, you may be required to show additional forms of Identification 'based on t11e type of transaction you.are seeking. This is for your protection and security and we appreciate your ongoing cooperation and understanding. t I S MEMBERS PI FEDERAL CREDIT UNION Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.membersl storg Main Switchboard: (717) 697-1161 or (800) 283-2328 EZ Call: (717) 697-4372 or (800) 283-4372 Too: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (717) 795-6049 or (800) 237-7288 ANGELA M BRUNGARD P.O. BOX 81 GRANTHAM PA 17027 Statement of Accounts Nov 25 , 2010 thru Dec 24 , 2010 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates: 4,546.79 Loans: 0.00 Money Management: 4,221.29 Swipe 5 YTD Reward: 0.50 Page: 1 of 2 Your current Member Loyalty Rewards level is Silver. Your aggregate balance as of December 1st is $9,036.94. An aggregate balance of $15,000 and having 3 products will move you to the Gold level. 10994NT's are not included in this statement. If you earned at least $10 in dividends on your account for 2010, you will receive your 1099-INT in a separate mailing in early January 2011. 1099-INT information will also be available on Members 1st Online early in January. CHECKING ACCOUNTS 0011 - FOOD MONEY Date Transaction Description Additions Subtractions Balance Nov 25 Balance Forward - 0.00 Dec 24 Ending Balance 0.00 SAYINGS ACCOUNTS 0000- ATLANTIC CITY MONEY WOW 1401reaw "WIN vexacr?wwvn r+uu1uuna OULM44AIV115 Daiarice Nov 25 Balance' Forward 5.00 Dec 24 Ending Balance' 5.00 T OW- "MMY Date Transaction Description Additions Subtractions Balance Nov 25 Balance Forward 4,219.58 Nov 30 Deposit Dividend Tiered Rate 1.71 4,221.29 Annual Percentage Weld 'Earned 0.400'/ from 11101/20104hrough 1113012010 Dec 24` Ending Balance 4,221.29 CERTIFICATE ACCOUNTS ; 0046 - 11 MONTH GERT Maturity Date Apr 03'?; `1'1 Date Transaction Description Additions Subtractions Balance Nov 25 Balance Forward 3,343.41 Nov 30 Deposit Dividend 1. 390% 3.82 3,347.23 Annual Percentage Yield Earned 1. 400% from 11/01/2010 through 1113012010 Dec 24 Ending; Balance 3,347.23 --- Continued on following page --- t Send Inquires to: Main Switchboard: (717) 697-1161 or (800) 283-2328 fVT 5000 Louise Drive E:Z Call: (717) 697-4372 or (800) 283-4372 PO Box 40 NOV 25, 2010 thru Dec 24, 2010 Mechanicsburg, PA 17055 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 Account Number: 283092 MEMBERS 11 TeleBranch: (717) 795-6049 or (800) 237-7288 www.membersist.org Page: 2 of 2 0047 - 19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Nov 25 Balance Forward 1,197.95 Nov 30 Deposit Dividend 1 .640% 1.61 1,199.56 Annual Percentage Yield Earned 1. 650% from 11/01/2010 through 11/30/2010 Dec 24 Ending Balance 1,199.56 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 14.60 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 26.77 0047 19 MONTH CERT 11.09 Total Year To Date Dividends Paid 91.75 NOTE: Total includes closed shares Add Your Photo For Security Your personal safety and financial security are top priorities at Members 1st. As a result of increased scams and fraudulent activity throughout the entire country, we are strongly encouraging members to have their photos added to their account records. When visiting our branch offices you may be asked by one of our Associatesto allow us to take your photo. This member IdenlPiication program will assist in our fraud deterrence initiatives and will take our identity theft prevention program to the next level'. We are experiencing an increasing number of attempted fraudulent activities and as a result, we need to be able to verify your identity immediately upon retrieving your account' information. In addition to having your photo in our files, you may be required to show additional forms of identification based on the type of transaction you are seekingg This is for your protection and security and we appreciate vour ongoing cooperation and understanding. St MEMBERS 1St FEDERAL CREDIT UNION Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.memberslst.org Main Switchboard: (717) 697-1161 or (800) 283-2328 EZ Call: (717) 6974372 or (800) 283-4372 TDO: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (717) 795-6049 or (800) 237-7288 Statement of Accounts Dec 25, 2010 thru Jan 24, 2011 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates: 4,552.41 Loans: 0.00 Money Management: 3,572.72 Swipe 5 YTD Reward: 0.50 Page: 1 of 2 ANGELA M BRUNGARD P.O. BOX 81 GRANTHAM PA 17027 will move you to the Gold level. Want to earn some extra cash? Take advantage of our CASH4U referral program. Ask an associate for details. CHECKING ACCOUNTS 0011 - FOOD MONEY Date Transaction Description _ Additions Subtractions Balance Dec 25 Balance Forward 0.00 Jan 24 Ending Balance 0.00 2010 Dividends Paid 0.00 SAVINGS ACCOUNTS 0000 - ATLANTIC CITY MONEY Date Transactioon Description Additions Subtractions Balance Dec 25 Balance Forward 5.00 Jan 24 Ending Balance 5.00 2010 Dividends Paid 0.00 in-, OWN paxam Date Transaction Description Additions Subtractions Balance Dec 25 Balance Forward 4,221.29 Dec 31 Deposit Dividend Tiered Rate 1.43 4,222.72 Annual Percentage Yield Earned 0. 400% from 12/01/2010 through 12/31/2010 Jan 24 Withdrawal 650.00- 3,572.72 TRANSACTION DATE I;0/Q1i2011 Jan 24 Ending Balance 3,572.72 2010 Dividends Paid CERTIFICATE ACCOUNTS 0046 - 11 MONTH CERT Maturity Date - Apr 03, 2011 Date Transaction Description Additions Doc 25 Balance Forward Dec 31 Deposit Dividend 1. 390% 3.95 --- Continued on following page --- - - Your Your current Member Loyalty Rewards level is Silver. o1`January 1 st is $10,244.27 Your An aggregate aggregate balance balance of as $15,000 and having 3 products actions Balance 3,347.23 3,351.18 St Send Inquires to: Main Switchboard: (717) 697-1161 or (800) 283-2328 5000 Louise Drive ?? EZ Call: (717) 697-4372 or (800) 283.4372 Dec 25, 2010 thru Jan PO Box 40 24, 2011 . TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 Mechanicsburg, PA 17055 Account Number: 283092 MLEEMBERLI" www.memberslst.org (717) 795-6049 or (800) 237-7288 .org Page: 2 of 2 Date Transaction Description Additions Subtractions Balance Annual Percentage Yield Earned 1.400% from 12/01/2010 through 12131/2010 Jan 24 Ending Balance 3,351.18 2010 Dividends Paid 30.72 0047- 19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Dec 25 Balance Forward 1,199.56 Dec 31 Deposit Dividend 1. 640% 1.67 1,201.23 Annual Percentage Yield Earned 1. 650% from 12101/2010 through 12131/2010 Jan 24 Ending Balance 1,201.23 2010 Dividends Paid 12.76 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 0.00 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 0.00 0047 19 MONTH CERT 0.00 Total Year To Date Dividends Paid 0.00 NOTE: Total includes closed shares Total 2010 Dividends Paid 98.80 Don't forget about our new Member Loyalty Rewards Program. The more products you have with US, the more benefits you'll receive. Ask an associate for details or visit our website at www.members1 st.org for details. IN(I MEMBERS 1St FEDERAL CREDIT UNION Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.memberslst.org Main Switchboard: (717) 697-1161 or (800) 283-2328 EZ Call: (717) 697-4372 or (800) 283-4372 Too: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (717) 795-6049 or(800)237-7288 ANGELA M BRUNGARD P.O. BOX 81 GRANTHAM PA 17027 Statement of Accounts Jan 25, 2011 thru Feb 24, 2011 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates: 4,558.04 Loans: 0.00 Money Management: 3,573.78 Swipe 5 YTD Reward: 0.50 Page: 1 of 2 Your current Member Loyalty Rewards level is Silver. Your aggregate balance as of February 1st is $10,091.85. An aggregate balance of $15,000 and having 3 products will move you to the Gold level. Ready to take control of your financial future? You're ready to try MoneyCoach. See the enclosed insert for more details. CHECKING ACCOUNTS 0011 - FOOD MONEY Date Transaction Description Additions Subtractions Balance Jan 25 Balance Forward 0.00 Feb 24 Ending Balance 0.00 SAVINGS ACCOUNTS 0000 ATLANTIC CITY MONEY Jan 25 Balance Forward 5.00 Feb 24 Ending Balance 5.00 MAMISEVENT Date Transaction Description Additions Subtractions Balance Jan 25 Balance Forward 3,572.72 Jan 31 Deposit Dividend Tiered Rate 1.06 3,573.78 Annual Percentage Yield Earned 0. 350•1a from 01/01/2011-through 01/31/2011 Feb 24 Ending Balance 3,573.78 CERTIFICATE ACCOUNT S h 0046 - 11 MONTH CERT Maturity Date4 dprr 03 2d1'I Date Transaction Description Additions Subtractions Balance Jan 25 Balance Forward 3,351.18 Jan 31 Deposit dividend 1. 390% 3.96 3,355.14 Annual Percentage Yield Earned 1. 400% from 01/01/2011 through 01/31/2011 Feb 24 Ending Balance 3,355.14 --- Continued on following page --- St Send Inquires to: Main Switchboard: (717) 697-1161 or (800) 283-2328 ??. 5000 Louise Drive EZ Call: (717) 697-4372 or (800) 283-4372 Jan 25, 2011 thru Feb 24, 2011 PO Box 40 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 Mechanicsburg, PA 17055 Account Number: 283092 MEMBERS n TeleBranch: (717) 795-6049 or (800) 237-7288 Page: 2 of 2 www.memberslst.org 9e: 0047 - 19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Jan 25 Balance Forward 1,201.23 Jan 31 Deposit Dividend 1.640% 1.67 1,202.90 Annual Percentage Yield Earned 1. 650% from 01/01/2011 through 01/31/2011 Feb 24 Ending Balance 1,202.90 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 1.06 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 3.96 0047 19 MONTH CERT 1.67 Total Year To Date Dividends Paid 6.69 NOTE: Total includes closed shares Don't forget about our new Member Loyalty Rewards Program. The more products you have with us, the more benefits you'll receive. Ask an associate for details or visit our website at www.membersist.org for details. St MEMBERS 1St FEDERAL CREDIT UNION N Send Inquires to: 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 www.membemist.org Main Switchboard: (800) 283-2328 EZ Call: (717) 697-4372 or (800) 283-4372 TOD: (717) 697-5312 or (800) 283-2328 ext. 5312 TeleBranch: (800) 237-7288 25240 1 AT 0.357 50479-25240 11111111111111111111111111111111111111111111111111111111111111 ANGELA M BRUNGARD P-0. BOX 81 GRANTHAM PA 17027 Statement of Accounts Feb 25, 2011 thru Mar 24, 2011 Account Number: 283092 Balances at a Glance: Checking: 0.00 Savings: 5.00 Certificates : 4,563.13 Loans: 0.00 Money Management: 836.82 Swipe 5 YTD Reward : 0.50 Page: 1 of 2 Your current Member Loyalty Rewards level is Silver. Your aggregate balance as of March 1st is $10,506.62. An aggregate balance of $15,000 and having 3 products will move you to the Gold level. National Credit Union Youth Week is April 17-23. Celebrate the week with us! See the enclosed insert for more details. CHECKING ACCOUNTS 0011 -FOOD MONEY Date Transactim Description Additions Subtractions Balance Feb 2S Bade Forward 0.00 Mar 24 Endi7g 8aiarwe 0.00 SAVINGS ACCOUNTS 0000 - ATLANTIC CITY MONEY Date Transaetiart Dtiort Additions Subtractions Balance Feb 25 Balance Fonvwd 5.00 Mw 24 Endhg Vaki6we 5.00 0005 - MONEY M;A1NAZEMENT t® Transaction Description Additions Subtractions Balance Feb 25 Bahnce Forwwd 3,573.78 Feb 28 Deposit Dividend Tiered Rate 0.96 3,574.74 Ann&W Pertaerifage rm d Evened 0.35% from 0410112011 rough 02128121911 Mar 04 Withdrawal 50.00- 3,524.74 Mar 04 Deposit by Check 6.00 3,530.74 Mar 04 Withdrawal 2,393.92- 1,136.82 Mar 04 Withdrawal 300.00- 836.82 Mar 24 En&V Balance 836.82 T' 0 CERTIFICATE ACCOMM-l' 0046 -11 MONTH CERT Maturity Date - Apr 03, 2011 Date Tr?rt"c, ttion Additions subtractions Balances 26 fiakr&e turd 3,355.14 Feb 28 Deposit Dividend 1.390% 3.58 3,358.72 Anus/ Pev wbgie Yo+d Eamed 1.406% from 0210112011 0mugph 0212812011 --- Continued on following page --- St Send Inquires to: Main Switchboard: (800) 283-2328 5000 Louise Drive EZ Call: (717) 697-4372 or (800) 283-4372 PO Box 40 Feb 25 , 2011 thru Mar 24, 2011 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 Mechanicsburg, PA 17055 50680-25760 Account Number: 283092 NI MBS)FRS11 TeleBranch: (800) 237-7288 www.membemist.org Page: 2 of 2 Date Transaction Description Additions Subtractions Balance Mar 24 Ending Balance 3,358.72 0047 -19 MONTH CERT Maturity Date - Dec 06, 2011 Date Transaction Description Additions Subtractions Balance Feb 25 Balance Forward 1,202.90 ?- Feb 28 Deposit Dividend 1.640% 1.51 1,204.41 N Annual Percentage Yield Earned 1.656% from 0210112011 through 0212812011 s Agar 24 N Ending Balance 1,204.41 YTD SUMMARIES TOTAL DIVIDENDS PAID 0000 ATLANTIC CITY MONEY 0.00 0005 MONEY MANAGEMENT 2.02 0011 FOOD MONEY 0.00 0046 11 MONTH CERT 7.54 0047 19 MONTH CERT 3.18 Total Year To Date Dividends Paid 12.74 NOTE: Total includes closed shares Add Your Photo For Security Your personal safety and financial security are top priorities at Members 1 st. As a result of increased scams and fraudulent activity throughout the entire country, we are strongt encouraging, members to have their photos added to their account records. When visiting our branch offices, you may be asked by one of our Associates to allow us to take,your to. This member identification program will assist in our fraud detervence IrdUatives and our identity theft prevention program to the next level. We are exp eclencing an iticvl n$ number of attempted fraudulent activities and as a result, we need to be able to verify your identity immediately upon retrieving your account information. In addition to having your photo in our files, you may be required to show additional forms of identification based on the type of transaction you are seeking. This is for your protection and security and we appreciate your ongoing cooperation and understanding. N N sF co CD z Do r? ? ? ? C 0 M N It Cl) ( 7 r > O 0 0 O M M M co O > L ^^ ca E E c O) 0 f0 N a ? o O v D U C%J r ? ? N o co G _ M M M N r- 0 L m 00? OO O c vi M n 0 N O? Z O M O N O 0 0 O 4) 00 O O Q LL 0 0 0 0 O O O O O C D o 0 0 0 0 co 0 o0 00 0 0 C a 0 C'4 co co W t 00) 0 0 0 2 00 (DO D W 8 ' N m N O Q ns Z M O a 0? oo ? Q 0 o w 00W ??o C14 C co M C7 - N Q 0 0M 9 O O ? O .• C > > c O c vL 0v(0 Q d o « 3 -=w0 m a M m a c t N O Q N t U U Z p V) N m ` 0 to > = Q I` = C(S U?UUUa o J w 2 00 00 0 Z (0 N N N ?V N O W ? Y N C ) O O Cf) O a C) Z O O O O O O O O O O m U) U) (1) U) cn N O 0 00 N 00 00 00 0 N N N Q N N O O Co O 0 n M M CV) M N C 00 0 0 O 0 O7 f0 CL EXHIBIT "B" MEMBERS lit 111411PPAL Ck r?r.?r r° °unr'ktia Carlisle Pike 6280 Carlisle Pike Mechanicsburg PA 17050 Inquiries Call; Acct XXXXXXX092 Eff: 04/14/11 Tlr: 2016 717-697-4432 BRUNGARD,ANGELA Date: 04/14/11 Time: 2:52pm Withdrwl from MONEY MANAGEMENT 0005 Prev Bal: 836.99 Amount: 836.99 New Sal: 0.00 Seq° #456138 Cash Dispense Clearing -36.00 Ref number: 055 Cash Disbursed -800.99 Hundreds Disbursed 800.00 Other Disbursed 0.99 Cash Received by ID Source: Drv Lic SigCard Known FR Other VISA Balance Transfer 1.90% APR No balance transfer fees. Ask an associate for details. BRUNGARD EXHIBIT "C" RECEIPT FOR PAYMENT ------------------- ------------------- Cumberland County Prothonotary's Office Carlisle, Pa 17013 MASON MICHELLE (VS) BRUNGARD ANGELA M Case Number 2011-02898 Received of PD ATTY HITCHINGS DKB Total Non-Cash..... + 836.99 Check# Total Cash......... + .00 Change ............. - .00 Receipt total...... = $836.99 Receipt Date 4/15/2011 Receipt Time 11:40:17 Receipt No. 258019 1309 ------------------------ Distribution Of Payment ----------------------------- Transaction Description Payment Amount BOND 836.99 PROTHONOTARY ESCROW $836.99 MICHELLE MASON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 11-2898 CIVIL TERM ANGELA M. BRUNGARD, CIVIL ACTION -LAW Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service via Hand Delivery R. Mark Thomas, Esquire 101 S. Market Street Mechanicsburg, PA 17055 Law Office of Joseph L. Hitchings Date: 9-A?- t -' Joseph L. itchi s, squire Attorney I.D.# 655 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Defendant Angela M. Brungard MICHELLE MASON, PLAINTIFF V. ANGELA M. BRUNGARD, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 11-2898 CIVIL TERM ORDER OF COURT AND NOW, this day of April, 2011, the hearing scheduled for this date is cancelled and rescheduled to commence at 8:45 a.m., Friday, May 13, 2011, in Courtroom Number 5, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, .i R. Mark Thomas, Esquire For Plaintiff Joseph Hitchings, Esquire For Defendant saa CD ?S en.ac LL OVAV / Albert H. Masland, J. r? PJ `D rnCZ) X90. .y. ca k ? i r ..r r MICHELLE MASON, Plaintiff vs. ANGELA M. BRUNGARD, Defendant DEBRA MASON Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN~i DOCKET NO. 11-2898 CIVIL TERM ' c :CIVIL ACTION -LAW .~ a ,~, • s~• c c~ : ~~ o G ^v ]~,~, ~c ANTS JOINDER COMPLAIN"~'z c ~ -~ AND NOW, comes Debra Mason, a Defendant pursuant to a Joinder complaint filed 1 Angela M. Brungard, Defendant, and files this answer to the Joinder Complaint: --+ ~ „r; ~c5 ~~~ -.,g: 21. No answer required. 22. Admitted. 23. Admitted. 24. Admitted 25. Admitted 26. Admitted 27. Admitted. Further, due to serious, debilitating and permanent injuries, Debra Mason's husband was in need of 24 hour nursing care which was provided primarily by Debra Mason with no income and no medical coverage. It is admitted that Debra Mason's i under her father's estate would result in a loss of needed Medicare benefits. Admitted also Debra Mason, pursuant to an agreement with Plaintiff and Defendant, disclaimed her inheri 28. Admitted in part, denied in part. It is admitted that additional Defendant was not working at the time of her father's passing, but it is denied that additional Defendant had sufficient funds to care for Michelle Mason. ,___.. - 1 29. Denied. Additional Defendant denies this allegation as stated. This allegation is complete fabrication and additional Defendant Debra Mason demands strict proof of this allegation at trial. Byway of further answer, pursuant to an agreement, all of the inheritance went to Plaintiff and Defendant under a trust arrangement for the benefit of additianal Defendant, Debra Mason. 30. Denied. Additional Defendant denies this allegation as stated. This allegation is ; complete fabrication and additional Defendant Debra Mason demands strict proof of this allegation at trial. By way of further answer, additional Defendant made request for funds in trust under additional Defendant's name, but no requests were made for funds from Plaintif.~'s custodial account. 31. Admitted in part, denied in part. It is admitted that Angela M. Brungard did funds to additional Defendant, Debra Mason, but it is denied that these funds were to come the account established for Plaintiff, Michelle Mason. 32. Denied. Additional Defendant had no access to the custodial account belonging to the Plaintiff. 33. Admitted. The agreement between the parties was that the money was to be used Debra Mason's benefit. Defendant, Angela M. Brungard had full knowledge that monies withdrawn by Angela M. Brungard for Additional Defendant, Debra Mason's benefit were for additional Defendant's personal use as well as for the benefit of Michelle Mason, as this the agreement that parties had agreed to. 34. Denied. This allegation is a conclusion of law to which no responsive pleading is required. r WHEREFORE, Additional Defendant, Debra Mason, prays this honorable court will enter judgment in favor of Additional Defendant in this Joinder Complaint. Respectfully submitted, R. Mark Thomas, Esquire #41301 101 S. Market Street Mechanicsburg, PA 17055 717-796-2100 VERIFICATION I, Debra Mason, verify that the statements made in this Answer are true and correct to best of my knowledge. I understand that false statements herein aze made subject to the of 1$ Pa.C.S. § 4904 relating to unsworn falsification to authorities. ~~ ~G~/ Date ~,