HomeMy WebLinkAbout11-3645SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION,
PLAINTIFF
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
RONALD E. KANE AND
EUGENIA M. KANE
DEFENDANTS NO. 3 tl? S C?
NOTICE??
CD -'fi'r
?)
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGQ T •TH?f r,
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION 4111 `
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 RELIEF REQUESTED BY
THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT
RIGHTS.
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 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.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166`
By:
S?Ien Hovfell, Esquire
Cowell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063a
&{ vcmco real a4
Ck,;' 7aq
V,6 2:571Y2
SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION,
PLAINTIFF
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
RONALD E. KANE AND
EUGENIA M. KANE
DEFENDANTS NO.
COMPLAINT
1. The Plaintiff is the Susquehanna Valley Federal Credit Union with a principal place of
business located at 3850 Hartzdale Drive, Cumberland County, Camp Hill PA 17011.
Plaintiff is a federally chartered nonprofit credit union.
2. The Defendants Ronald E. Kane and Eugenia M. Kane are adults individual residing at
2718 Hillsdale Road, Elizabethtown, PA 17022.
3. The Defendants are not a current members of the Armed Forces.
COUNT I: SVFCU LOAN
4. On October 17, 2008 Defendants executed a Loan Agreement attached as Exhibit "A"
in the amount of Fourteen Thousand Three Hundred Eight One and 36/100 ($14,381.36) Dollars
at 10.000% interest and pledged as collateral a 2004 Polaris (VIN 4XACH42A74A344466).
Defendants were the borrower under this Loan Agreement.
5. The terms of Exhibit "A" required timely monthly payments of $300.00.
6. Defendant failed to make timely payments.
7. There remains a principal balance due of $11,021.53 plus past due interest at 10.000%
with a $2.91 per diem from April 7, 2011.
8. Defendants have made no regular payments despite repeated requests.
9. Pursuant to the Loan Agreement the Defendants agreed to pay all "court costs and
reasonable attorney fees" incurred in any collection action.
WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount of
$11,021.53 (principal plus past interest) at 10.000% interest from April 7, 2011 and a per
diem of $2.91 together with all court costs and an award of reasonable attorneys' fees.
Respectfully submitted,
By:
JU6well Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
"412.'. _ : 4.? 7 .77701278 HOWELL LAI'A FIRM PAGE 02/12
Verification
verify that the statements made in the forgoing document are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn. falsification, to authorities. I verify that I am the President of the Susquehanna Valley
Federal credit Union and that I atn authorized to execute this document.
By: A?Q
Steven I rindamour, President
SVFCU
Date: 4/1 J/4
SUSQUEHANNA VALLEY
FEDERAL CREDIT UNION
3850 Hartzdale Drive
Camp Hill, PA 17011-7809
1 wilz% L i 1k kk\l - -
(717)737-4152 Open-End Voucher
and Security Agreement
<.
BORROWER 1 NAME ACCOUNT NUMBER AMOUNT REQUESTED DATE
Ronald E Kane s 14,381.36 1011712008
BORROWER 1 ADDRESS HOME TELE t NUMBER SOCIAL SECURITY NUMBER PURPOSE: ConSo L idat i on
2718 Hillsdale Rd ?W"W_
Elizabethtown, PA 17022
BORROWER 2 NAME ACCOUNT NUMBER DEPOSIT CHECK IN ACCOUNT NUMBER/OTHER:
Eugenia M Kane
BORROWER 2 ADDRESS SOCIAL SECURITY NUMBER
2718 Hillsdale Rd CHECK PAYABLE TO:
Elizabethtown, PA 17022
REPAYMENT METHOD: Cash
LIST ALL DEBTS OTHER THAN TO THIS CREDIT UNION (Attach additional sheet(s) if necessary.) PRESENT BALANCE MONTHLY PAYMENT CURRENT INTEREST RATE
%
9 g WN :OR
1. :..1f '' .. AR PAY ME
NV?
C EC? . .
You can now voluntarily elect to become insured with the coverage(s) shown below, in order for coverage to become effective you must meet all
+nsurance eligibility-Faquirements stated in the Credit Insurance Application/Schedule. NOTE-The insurance you're applying for contains certain
terms and exclusions; Refer to your certificate for coverage details. If you need a copy of the Insurance Certificate, just ask. By signing below,
you authorize us to add the charges for the insurance to your outstanding balance each month. Coverage election applies to the entire balance on this
subaccount. Insurance rates are subject to change.
YOU ELECT THE FOLLOWING:
COST PER $100 OF YOUR
MONTHLY LOAN BALANCE
NAME OF INSURED(S)
No Single Credit Disability SEE SEPARATE -
RATE SCHEDULE - No Single Credit Life .070
No Joint Credit Life ,123
..::..
..:::.; ..:..::...::::...:::::.:
`REPA'
WENT
E.:. MIS.. .............. ::.::::::...::.:.
>. DAILY PERIODIC RATE ANNUAL PERCENTAGE RATE
"'l INTEREST RATE IS: OTHER FEES (Amount and Description) NEW BALANCE THIS SUBACCOUNT
OZ .0273972 X 10.00000 % Fixed $ s 14,381.36
MOUNT ADVANCED PAYMENT AMOUNT DATE DUE PAYMENT FREQUENCY LINE OF CREDIT LIMIT REMAINING LIMIT
x14,381.36 x300.00 11/15/2008 Monthly s a
Z PROJECTED LOAN TERM FOR INSURANCE: 62 MONTHS
O
IT LSEEIPARA-0
THE ADVANCE IS SECURED BY YOUR SHARES, ALL PROPERTY SECURING OTHER PLAN ADVANCES AND LOANS RECEIVED IN THE PAST OR IN THE FUTURE, AND THE FOLLOWING
O PROPERTY/MODEL YEAR I.D. NUMBER VALUE KEY NUMBER
U Cotnaker 8 Title to 2004 Polaris 2004 4XACH42A74A344466 s 2,905.00
9
O
LL s
PLEDGE OF SHARES
AND/OR DEPOSITS $
ACCOUNT
NUMBER
PLEDGE OF SHARES
AND/OR DEPOSITS $
ACCOUNT
NUMBER
By signing below, by endorsing the pros check or by using the amount advanced and deposited into your share/share draft account you agree:
1. To make and be bound by the terms of his Security Agreement including the cross collateral clause;
2. The above information is true and con and the Credit Union wig rely on that information and your credit report to make a credit decision;
3. To make is Iosed bov n accordance with the terms of your Plan.
C ISEAL) t}?""`? [ `C^i b yv_ (SEAL) ` -
OWER 1 SI AT RE DATE BORROWER 2 SIGN URE DATE
(SEAL) (SEAL)
SIGNATURE OWNER OF COLLATERAL (Other than a Borrower) DATE SIGNATURE OWNER 0 ) DATE
ay iF
C CUNA MUTUAL GROUP, 1980, 82, 84, 86, 89, 98, 99, 2000, 02 ALL RIGHTS RESERVED CREDIT UNION COPY 6 VXX065 (LASER)
,T i I
`Susqueharr_,a Valley Federal Credit Union (Ronald E Kane hate 10/17/2008 1
SECURITY AGREEMENT
In this agreement all references to "credit union," "we," "our," or
"us" mean the credit union whose name appears on this agreement
and anyone to whom the credit union assigns or transfers this
agreement. All references to "you," "your," and "borrower" mean
each person who signs this agreement. All references to "the
advance" mean the amount in the box labeled "Amount Advanced"
on page one. All references to "the Plan" mean the Credit
Agreement under which the advance was obtained. Some of the
provisions of this agreement apply only if the Credit Union is state
chartered. A credit union has a state charter if its name does not
include the words "Federal Credit Union" or "FCU". This is a
multi-state document which may be used to lend to borrowers in all
states except Louisiana and Wisconsin.
1. THE SECURITY FOR THE PLAN -- By signing this security
agreement in the signature area or under the statement referring to
this agreement which is on the back of the check you receive for
the advance, you give us what is known as a security interest in
the property described in the "Security Offered" section on page
one. 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 refinancings 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.
2. WHAT THE SECURITY INTEREST COVERS -- The security
interest secures the advance and any extensions, renewals or
refinancings of the advance. It also secures any other advances
you have now or receive in the future under, the Plan and any other
amounts or loans, including any credit card loan, you owe us for
any reason now or in the future, except any loan secured by your
principal residence. If 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
)we.
3. OWNERSHIP OF THE PROPERTY -- You promise that you own
:he property you--give as security or if the Advance is to buy the
)roperty, you promise you will use the Advance for that purpose.
(ou promise that no one else has any interest in or claim against
he property that you have not already told us about. You promise
lot to sell or lease the property or to use it as security for a loan
vith another creditor until the advance is repaid. You promise you
will allow no other security interest or lien to attach to the property
tither by your actions or by operation of law.
1. PROTECTING THE SECURITY INTEREST -- If your state issues
I title for the property, you promise to have our security interest
hown on the title. We may have to file what is called a financing
tatement to protect our security interest from the claims of
thers. If asked to do so, you promise to sign a financing
tatement. You also promise to do whatever else. we think is
ecessary to protect our security interest in the property. You
romise to pay all costs, including but not limited to any attorney
:es, we incur in protecting our security interest and rights in the
roperty, to the extent permitted by applicable law.
. USE OF PROPERTY -- Until the advance has been paid off, you
romise you will: (1) Use the property carefully and keep it in good
:pair. (2) Obtain our written permission before making major
ranges to the property or changing the address where the
•operty is kept. (3) Inform us in writing before changing your
idress. (4) Allow us to inspect the property. (5) Promptly notify
if the property is damaged, stolen or abused. (6) Not use the
operty for any unlawful purpose.
CONSUMERS' CLAIMS AND DEFENSES NOTICE - The
/lowing paragraph applies only when the box on page one is
lecked.
?I
1v
100, ?tk_
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 PURSUANT
HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT EXCEED
AMOUNTS PAID BY THE DEBTOR HEREUNDER.
7. 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 towards
what you owe. You authorize us to endorse any draft or check
which may be payable to you in order for us to collect any refund
or benefits due undef your insurance policy. You also promise to
pay all taxes and feesr 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 advatasa-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 the advance may
include (1) the insurance company's payments to us and (2) the
cost of determining compliance with the insurance requirements. If
we add amounts for taxes, fees or -insurance to the unpaid balance
of the advance, we may increase your payments to pay the
amount added within the term of the insurance or approximate
term of the advance.
8. 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 insurance will not be
liability insurance and will not satisfy any state financial
responsibility or no fault laws.
9. DEFAULT -- You will be in default if you break any promise
you make under this agreement. You will also be in default if you
are in default under the Plan. If you are pledging property, but have
not signed the Plan, you will be in default if anyone is in default
who has signed the Plan.
10. WHAT HAPPENS IF YOU ARE IN DEFAULT -- The following
paragraph applies to borrowers in Colorado, District of Columbia,
Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, West
Virginia and state chartered credit unions lending to South Carolina
borrowers. When you are in default and after expiration of any
right you have under applicable state law to cure your default, we
can demand immediate payment of the entire unpaid balance under
the Plan without giving you advance notice.
The following paragraph applies to borrowers in all other states
and federally chartered credit unions lending to South Carolina
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.
(Continued on next page)
CUNA MUTUAL GROUP, 1980, 82, 84. 86, 89, 98, 99, 2000, 02, ALL RIGHTS RESERVED CREDIT UNION COPY VXX065 (LASER)
Susquehanna Valley Federal. Credit Union
The following paragraphs apply to a// borrowers.
You agree the Credit Union has the right to take possession of the
property given as security under the Plan, without 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. 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 to 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 sale or the date after which a private sale 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. The rest of the sale money
will be applied to what you owe under the Plan.
If you have agreed to pay the Advance, you will also have to pay
any amount that remains unpaid after the sale money has been
applied to the unpaid balance of the Advance and to what you owe
under this agreement. 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.
I THE PROPERTY DESCRIPTION ON PAGE ONE IS PART OF THIS AGREEMENT. NOTICE: SIGN THIS AGREEMENT ON PAGE ONE.
. >:C><:::;FOR: CE?'EDt?'<.UI1CE(21??;E??)=, tdNLY
REQUESTED: : ..:.:.....
05/30/2008 MEMBER PAYS CHECK NUMBER.
PREMIUM FOR: BRANCH NUMBER. Main
J PLAN/SUBACCOUNT NO.: 6 PROCESSED BY: LNS
DATE
HXAPPROVE D-APPROVED -SIGNATURE LINE OF CREDIT OTHER OTHER
ENIED LIMITS: DEBT RATIO/SCORE
1 D/ 17/20D8 dverse Action Notice Sent) $ $ $ 14 381.36 $ BEFORE AFTER
LOAN OFFICER COMMENTS: **** OveraI I Recommendation: REVIEW **** r 3.9816
SIGNATURES:
X
X
DATE DATE
Ronald E Kane
Date 10/17/2008
11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN
-- We can delay enforcing any of our rights under this agreement
any number of times without losing the ability to exercise our
rights later. We can enforce this agreement against your heirs or
legal representatives. If we change the terms of the Plan, you
agree that this agreement will continue to protect us.
12. CONTINUED EFFECTIVENESS -- If any part of this agreement
is determined by a court to be unenforceable, the rest will remain
in effect.
13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A
MOTOR VEHICLE ---THE MOTOR VEHICLE IN THIS TRANS-
ACTION MAY BE SUBJECT TO REPOSSESSION, IF IT IS
REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL
AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN
THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE.
14. NOTICE FOR ARIZONA OWNERS OF PROPERTY -- It is
unlawful for you to fail to return a motor vehicle that is subject to
a security interest, within thirty days after you have received
notice of default. The notice will be mailed to the address you
gave us. It is your responsibility to notify us if your address
changes. The maximum penalty for unlawful failure to return a
motor vehicle is one year in prison and/or a fine of $150,000.
CUNA MUTUAL GROUP, 1980, 82, 84, 86, 89, 98, 99, 2000, 02, ALL RIGHTS RESERVED CREDIT UNION COPY VXX065 (LASER)
SUSQUEHANNA
ALLEY
FEDERAL C R E D I T U N I O N
Addendum to LOANLINER Credit Agreement
8
Truth-In-Lending Disclosure
This addendum is incorporated into and becomes a part of your LOANLINER Credit Agreement.
The term APR refers to Annual Percentage Rate. Please keep this attached to your Loonliner
Credit Agreement.
The interest rate on your loan/line-of-credit_
is 10.0000% APR: Daily Periodic Rate
027397
dated 10/17/2008 ,
The "ANNUAL PERCENTAGE RATE" for a Loan or Line-of-Credit is based on certain credit-
worthiness criteria. The Line-of-Credit will have a draw period of five (5) years. On the fifth
anniversary date of this Line-of-Credit we will evaluate your credit-worthiness and either extend
the draw period another five years with a rate you qualify for at the time of your evaluation,
increase, decrease or remove the credit limit amount. You will be notified of any changes in
terms. Your monthly payment for your Line-of-Credit will depend upon your loan balance, and
will be determined at the time of the last advance. The following payments will apply:
-- ---Balance--
$100 - $2,000
$2,001 - $4,000
$4,001 - $6,000
$6,001 - $8,000
$8,001 - $11,000
$?fi001 - $15,000
$15,000.01+
Payment -
$50
$100
$150
$200
$275
$375
2.5% of balance
Share Secured Loans/Lines of Credit
If your Share Secured Loan is past due, the Credit Union will notify you. An account delinquent
45 days or more will be brought current only once by the Credit Union transferring funds from
shares/certificate. A second instance of 45 days or more delinquent will result in the Credit Union
satisfying the loan in full with your shares/certificate.
Other Charges
Collectfon Costs: You agree to pay all collection costs, including court costs and attorney's fees,
as permitted by law.
Late Fees: A $20 late fee will be charged on all payments received more than 14 days past the
due date.
NSF Charge: You will be charged a $25 fee if your payment is made with a non-sufficient funds
check.
Filing Fees: If a security interest is taken, you will be charged the fee that particular government
agency levies to perfect that security interest.
14271-6
3850 Hartzdale Drive - Camp Hill, PA 17011-7809
Local: (717) 737-4152 Toll Free: (800) 948-1454 Fax: (717) 737-0589
- ' " 1 1 f 4416U66 t'. U4
SUSQUEHANNA
ALLEY
FEDERAL CREDIT UNION
BY SIGNING, YOU VERIFY THAT YOU HAVE BEEN GIVEN A COPY AND AGREED TO THE TERMS OF
THIS ADDENDUM.
SIGNATURE ?'?i_ SIGNATURE_ 61i1 '
Ronald E Kane ugenia Kane
3M Hartzdale Drive - Camp Hill, PA 17011-7809
Local: (717) 737-4152 Toll Free: (800) 948- l 454 Fax: (717) 737-0589
(Cf
Jq? FEDERAL CREDIT UNION
3850 Hanzdale Drive
(717) 737-4152
:. ! yy!1Gvhb r . U$j
_-
Notice to Cosigner
I SUSQUEHANNA VALLEY
Camp HK H4, 1go11-7809
ou are being asked to guarantee this debt. Think carefully before you do. If the borrower doesn't pay thin debt, you will have to. Be
ure you can afford to pay if you have to, and that you want to accept this responsibility.
ou may have to pay up to the full amount of the debt if the borrower does not pay. You may also have -0 pay late fees or collection
Data, which increase this amount.
notice is not the contract that makes you liable for the debt.
Guaranty Agreement
BASIC GUARANTY - To induce Susquehame'Valley Federal credit union (t a "Credit Union") to lend money or give
credit to Kane, Ronald E (the "Borrower(Account Number),
you (the Guarantor(s)"), jointly and severally if more than one, guarantee prompt and full payment, when due, the following debt,
including principal and interest.
ACCT. 11111111111111110 NOTE NUMBER: 6 LOAN AMOUNT: $14,381.36
Plus any cost of collection including reasonable attorney fees.
w,H_W_ YOU MUST PAY -- If the Borrower fails to-Pa Y-the debt when due,-you-promise to pay the debt to the Credit-Union upon dem
The Credit Union can demand that'you pay the debt even if it does not try to collect from the Borrower and without enforcing
security interests the Borrower has given the Credit Union,
SECURITY - You pledge ell shares and/or deMits..jn-arty of your anctirMitviduel accounts at the Credit Union as security for
prmdae. The cr4m* Union has the right to apply your shares u?d/or deposits towwds what you owe if you are in defeWt under
Agreetrlent. Shares and/or deposits in an .k4W".Retironvim Aocount and any other account that would lone special tax treaty
under state or federal later if given as security are not subject to the security interest you have given in your shares and deposits.
NO NOTICE B UIRM -- This guaranty remains in effect even though you ar"ot given notice of the following: -
(1) H the Borrower fails to pey'sn1'?y"8Tnoff[ m. °-
(2) Of any action taken by the Credit Union with respect to property given by the Borrower as security for the debt.
(3) Of any new debts with the Credit Union incurred by the Borrower.
(4) Of any renewal, extension or substitution-of-any'6f-the°Borrower's debts.
(5) Of the acceptance by the Credit Union of this guaranty.
PAYMENTS - The Credit Union ha&the-right-te apply-payments by the Borrower to any of the Borrower's debts in any order the Cr
Union elects.
YOU MAY BE SUED -- You may be sued for payrner?t of the debt if the Borrower Is In default and you do not pay the amount you
guararrteed.
GUARANTORS -- If more than one Guarantor signs this Agreement, the Credit Union can release or settle with any of
ors at any time without affecting the liability of the others.
NO WAIVER OF NGHTS -- The Credit Union can delay enforcing any of its rights under this Agreement without losing them.
WHO 18 BOUND - Each person who signs below is bound jointly and severally. The Credit Union can enforce this Agreement al
your heirs and legal representatives.
DAME NAME
A
TIA
creditor can collect this debt from you without first trying to collect from the borrower. The creditor can use the same collection)
Nods against you that can be used against the borrower, such as suing you, garnishing your wages, etc. If this debt is ever in default,
fact may become part of your credit record.
DA7r MTNM
NAME
ss??u
DATE YIATNESS
(UAL) /C
DATE
lSRAU
DATE
0 CUNA MUTUAL GROUp, 1980, 82,$4,90,89.98. 3003, ALL RIGHTS RESERvm CREDIT UN ION COPT GXX111 tLASEM
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
? r GR cluNb"rf?
44
Li`?9? a Il.r
F iLL
Pi Ti H
2.311 JUN -1 AM 10' 29)
IT"
I
GUMQERLAhU OOL ti t
PENNSYLVANIN
Susquehanna Valley Federal Credit Union
vs.
Ronald E. Kane (et al.)
Case Number
2011-3645
SHERIFF'S RETURN OF SERVICE
05/19/2011 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: Ronald E. Kane, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within
Complaint and Notice according to law.
05/19/2011 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: Eugenia M. Kane, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within
Complaint and Notice according to law.
05/31/2011 04:39 PM - Dauphin County Return: And now May 31, 2011 at 1639 hours I, Jack Lotwick, Sheriff of
Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within
Complaint and Notice, upon the within named defendant, to wit: Eugenia M. Kane by making known unto
herself personally, at The Dauphin County Sheriffs Office, 101 Market Street, Harrisburg, Pennsylvania
17101 its contents and at the same time handing to her personally the said true and correct copy of the
same.
05/31/2011 04:39 PM - Dauphin County Return: And now May 31, 2011 at 1639 hours I, Jack Lotwick, Sheriff of
Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within
Complaint and Notice, upon the within named defendant, to wit: Ronald E. Kane by making known unto
himself personally, at The Dauphin County Sheriffs Office, 101 Market Street, Harrisburg, Pennsylvania
17101 its contents and at the same time handing to him personally the said true and correct copy of the
same.
SHERIFF COST: $53.00
June 06, 2011
!Ci C;nunf, quite herrff. feleosoft. Inc.
SO ANSWERS,
RbNI'VY R ANDERSON, SHERIFF
(Ptfirt o t+??=
William T. Tully
Solicitor
Dauphin County
101 Market Street
Harrisburg, Pennsylvania 17101-2079
ph: (717) 780-6590 fax: (717) 255-2889
Jack Duignan
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
RONALD E KANE
Sheriff s Return
No. 2011-T-2417
OTHER COUNTY NO. 20113645
And now: MAY 31, 2011 at 4:39:00 PM served the within COMPLAINT upon RONALD E KANE
by personally handing to RONALD E KANE 1 true attested copy of the original COMPLAINT and
making known to him/her the contents thereof at DAUPHIN COUNTY COURTHOUSE 101 MARKET
STREET HARRISBURG PA 17101
Sworn and subscribed to
before me this 2ND day of June, 2011
-)P? Z
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Karen M. Hoffman, Notary Public
City of Harrisburg, Dauphin County
M Commission Expires August 17, 2014
SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION
VS
So Answers,!
Sheriff of Dauphin unty, Va. f., ,
By
Deputy Sheriff
Deputy: G MILLER
Sheriffs Costs: $68.5 5/23/2011
(Atlirg of the,*hvrifj?
William T. Tully
Solicitor
Dauphin County
101 Market Street
Harrisburg, Pennsylvania 17101-2079
ph: (717) 780-6590 fax: (717) 255-2889
Jack Duignan
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
RONALD E KANE
Sheriff s Return
No. 2011-T-2417
OTHER COUNTY NO. 20113645
And now: MAY 31, 2011 at 4:39:00 PM served the within COMPLAINT upon EUGENIA M
KANE by personally handing to EUGENIA M KANE 1 true attested copy of the original
COMPLAINT and making known to him/her the contents thereof at DAUPHIN COUNTY
COURTHOUSE 101 MARKET STREET HARRISBURG PA 17101
Sworn and subscribed to
before me this 2ND day of June, 2011
-)P*Z
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Karen M. Hoffman, Notary Public
City of Harrisburg, Dauphin County
M Commission Expires August 17, 2014
SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION
VS
So Answers,
/eZ5?;4
Sheriff of Dauphin ounty, Pa.
By
Deputy Sheriff
Deputy: G MILLER
Sheriffs Costs: $68.5 5/23/2011
t
SUSQUEHANNA VALLEY FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION, CUMBERLAND COUNTY
PLAINTIFF PENNSYLVANIA
V.
RONALD E. KANE AND
EUGENIA M. KANE
DEFENDANTS
TO: Ronald E. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
Eugenia M. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
DATE OF NOTICE: June 22, 2011
CIVIL ACTION - LAW
NO.11-3645
IMPORTANT NOTICE
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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
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
0
AVISO IMPORTANTE
A: Ronald E. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
Eugenia M. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
ECHA DEL AVISO: June 22, 2011
USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO
Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS
QUE SE HAN PRESETADO CONTRA USTED. A MEMOS QUE USTED ACTUE
DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA
VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS
IMPORTANTES.
USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A
LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE.
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO
A PERSONAS QUE CALIFICAN.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Respectfully submitted,
By:
well Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: June 22, 2011
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
Ronald E. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
Eugenia M. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
By:
Date: June 22, 2011
SUSQUEHANNA VALLEY
FEDERAL CREDIT UNION
PLAINTIFF
V.
RONALD E. KANE AND
EUGENIA M. KANE
DEFENDANTS
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
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NO. 11-3645 ?'-
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PRAECIPE FOR ENTRY OF DEFAULT JUDGMENV a: N
TO THE PROTHONOTARY:
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Please enter a DEFAULT JUDGMENT against RONALD E. KANE AND EUGENIA
M. KANE for their failure to file an Answer to the Complaint served May 31, 2011 by the Office
of the Sheriff of Dauphin County as shown on Exhibit "A-1" in accordance with PA R.C.P. 404
and 403. A Notice of Intention to Take a Default Judgment was filed on June 23, 2011 and
served using a U.S. Postal Certificate of Mailing by first class prepaid postage on June 22, 2011
as shown on Exhibit "A-2" (Certificate of Mailing USPS Form 3817 is attached showing
service). No answer or response having been filed with the Prothonotary as of July 7, 2011
please enter a Default Judgment in the following amount as of $11,736.34 plus all costs:
Count I $11,021.53
Interest Count I $ 264.81 ($2.91 Per Diem from April 7, 2011)
Fees 450.00 (Attorney Fees per Contract)
$11,736.34 plus all costs
Respectfully submitted,
By:
Date: July 7, 2011
S
'619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Attorney for Plaintiff
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Nblice._ ( o4to i
Jack Duignan
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
101 Market Street
Harrisburg, Pennsylvania 17101-2079
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
a iii rr tl E aH l h ,nnsylvania SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION
VS
1 as I: f !C a u ?RONALD E KANE
Sheriff s Return
No. 2011-T-2417
OTHER COUNTY NO. 20113645
01:1. 11(1)7 1?v[A , 2011 at 4:39:00 PM served the within COMPLAINT upon EUGENIA M
tl';' E? :,ry. jx r orl a . anding to EUGENIA M KANE 1 true attested copy of the original
C?iwiP'L'IRT' all :king known to him/her the contents thereof at DAUPHIN COUNTY
(?1.1T;T:EaOl1SE 1'. 4ARKET STREET HARRISBURG PA 17101
Swol°r subscribed to
be GD:re me t17:i 4D day of June, 2011
A '
CO]VIMONW)EA ]. H OF PENNSYLVANIA
7771","" AL SEAL
Karen M. Ho' an, Notary Public
City of Ilarri tl. ,, Dauphin County
M Commission I )ires Au Rust 17, 2014
So Answers,
Sheriff of Dauphin ounty, Pa.
By
Deputy Sheriff
Deputy: G MILLER
Sheriffs Costs: $68.5 5/23/2011
4 ?
(.0f1jr.t Ulf tfIr 'She IV
Dauphin County
101 Market Street
Harrisburg, Pennsylvania 17101-2079
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Jack Duignan
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
C'ommomealth of F :nnsylvania SUSQUEHANNA VALLEY FEDERAL
CREDIT UNION
VS
County of Dauphin RONALD E KANE
Sheriff s Return
No. 2011-T-2417
OTHER COUNTY NO. 20113645
And now: MAY 3 , 2011 at 4:39:00 PM served the within COMPLAINT upon RONALD E KANE
by personally handing to RONALD E KANE 1 true attested copy of the original COMPLAINT and
making known to hirr her the contents thereof at DAUPHIN COUNTY COURTHOUSE 101 MARKET
STREET IIARRISBt ZG PA 17101
Sworn an subscribed to
before me this 2 'ID day of June, 2011
COMMONWEAL? J OF PENNSYLVANIA
NOTARIALSEAL
Karen M. Hoffr i in, Notary Public
City of Harrisbui ! Dauphin County
M Commission Eai Tres August 17, 2014
So Answers,
Sheriff of Dauphin unty, Va.
By i wA t
Deputy Sheriff
Deputy: G MILLER
Sheriffs Costs: $68.5 5/23/2011
SUSQUEHANNA VALLEY FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION, CUMBERLAND COUNTY
PLAINTIFF PENNSYLVANIA
V.
CIVIL ACTION - LAW
RONALD E. KANE AND
EUGENIA M. KANE
DEFENDANTS NO.11-3645
TO: Ronald E. Kane r? t 1,11j=
2718 Hillsdale Road
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Elizabethtown PA 17022 `x.
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Eugenia M. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
DATE OF NOTICE: June 22, 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
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE T
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.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
AVISO IMPORTANTE
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1,%022
22, 2011
: DELDIA PORQUE HA FALLADO DE REGISTRAR
cc.'RITA POR SI MISMO O A TRAVES DE UN ABOGADO
:1: E SUS DEFENSAS U OBJECCIONES A LOS CARGOS
i=,DO CONTRA USTED. A MEMOS QUE USTED ACTUE
N( CONTRA SUYA SIN TENER DERECHOS A UNA
i 1;.DE PERDER SU PROPIEDAD U OTRO S DERECHOS
VAR EST DOCUMENTO A SU ABOGADO
USTED NO TIENE UN ABOGADO, LLAME O VAYA A
::FICINA. ESTA OFICINA PUEDE PROVEERLE.
:I a J DE COMO CONSEGUIR UN ABOGADO.
°d I ; ?AGAR POR LOS SERVICIOS DE UN ABOGADO, ES
() FICINA LE` PUEI
-,'AN SERVICIOS LEGALES SIN CARGO O BAJO COSTO
1 [I AN.
':'11CE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
11ABERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
:ARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Respectfully submitted,
By:
Owell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Certificate of Service
i on the date set forth below a true and, correct copy of the
;crved upon the party/parties set forth below by postage
hates Mail addressed as follows:
By:
Respectfully submitted,
By:
bY6well Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Date: June 22, 2011
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This Certificate ofMailin9 Drovides eJidenoe Chet mail has been presented to U:
This f,ian mau t?n„=cddNno=1. _-
I hereby certify tl Fr Steven Howell
foregoing document was Attorney At Law
prepaid, first class Unite( 619 Bridge Street
New Cumberland, PA 17070
Ronald E. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
Eugenia M. Kane
2718 Hillsdale Road
Elizabethtown PA 17022
To: C3 Z f'7 C
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PS Form 3817, April 2007 PSN 7530-02-000-9065
By: _ / / 0&
Ste n Ho 1
Date: June 22, 2011
UNITWSMTO
• Certificate Of FI
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This CaIIifiS,atd of teailiD4nmv tle= a Ieennalhat.medbas tre8iwre4anted_t2
This
Steven Howell 5 i , o
Fro
Attorney At Law
619 Bridge Street -
New Cumberland, PA 17070
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To: / ?/? ` D3 N
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PS Form 3817, April 2007 PSN 7530-02-000-9065