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BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
PASCUAL MARTINEZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
r,o.I l- JI1/1 I
NOTICE TO DEFEND
Pursuant to PA RCP No. 1018.1
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be entered
against you by the Court without further notice to you for any money claimed in the Complaint
or for any other claim or relief requested by Plaintiff(s).
other rights important to you.
30554061
You may lose money or property or
ya1- 9; G
et# yA 7I( 6-
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
800.999.9108
30554061
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
V.
PASCUAL MARTINEZ,
No.
Defendant
AVISO PARA DEFENDER
Conforme a RCP No. 1018,1 del PA
LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas
dispuestas en las paginas siguientes, usted debe tomar la accion en el plazo de veinte (20) dias
despuds de esta queja y el aviso es servido, incorporando un aspecto escrito personalmente o por
el abogado y archivando en escribir con la corte sus defensas u objeciones a las demandas
dispuestas contra usted. Le advierten que si usted no puede hacer asi que el caso puede proceder
sin usted y un juicio se puede incorporar contra usted por la corte sin aviso adicional a usted para
cualquier dinero demandado en la queja o para cualquier otra demanda o relevaci6n pedida por
Plaintiff(s). Usted puede perder el dinero o la caracteristica u otra endereza importante a usted.
30554061
USTED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE Un ABOGADO, VAYA A O LLAME POR TELEFONO La OFICINA
DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De USTED La INFORMACION
SOBRE EMPLEAR A un ABOGADO.
SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA
PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE
LOS SERVICIOS JURIDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES
EN Un HONORARIO REDUCIDO O NINGON HONORARIO.
Cumberland County Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
800.999.9108
30554061
BARLEY SNYDER LLC
Shawn M. Long, Esquire
Court I.D. No. 83774
126 East King Street
Lancaster, PA 17602
(717) 299-5201
Attorneys for Plaintiff
Pennsylvania State Employees Credit Union
PENNSYLVANIA STATE EMPLOYEES
CREDIT UNION,
Plaintiff
V.
PASCUAL MARTINEZ,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. _
Defendant
COMPLAINT
Plaintiff, Pennsylvania State Employees Credit Union ("PSECU"), is a
Pennsylvania financial institution having an office at One Credit Union Place, Harrisburg,
Pennsylvania 17110.
2. Defendant, Pascual Martinez, is an adult individual with a last known address of
789 Lee Lane, Enola, Pennsylvania 17025-1503.
3. On or about May 9, 2006, Defendant entered into a PSECU Loanliner Advance
Proceeds Voucher and Security Agreement and Loanliner Credit and Security Agreement and
Loanliner Addendum (the "Agreement ") with Plaintiff for the purchase of a 2002 Ford Escape
30554061
SW, VIN #1FMYU04192KA50411 ("Vehicle"). A true and correct copy of the Agreement is
attached hereto as Exhibit "A" and incorporated herein by reference.
4. Plaintiff's perfected security interest in the Vehicle is evidenced by a
Commonwealth of Pennsylvania Certificate of Title (the "Title"), a true and correct copy of
which is attached hereto as Exhibit "B" and incorporated herein by reference.
5. Defendant defaulted under the Agreement by failing to pay the monthly
payments when due and is currently due for the months of October 8, 2009 and thereafter.
6. Based on Defendant's default, Plaintiff repossessed the Vehicle on or about
February 24, 2009.
7. By letter dated February 24, 2009, Plaintiff provided Defendant with Notice of
Repossession and Right to Redeem (the "Notice"), a true and correct copy of which is attached
hereto as Exhibit "C" and incorporated herein by reference.
8. Defendant remains liable to Plaintiff under the Agreement as follows:
Principal $8,093.00
Collection/Attorneys' Fees 980.60
TOTAL $9,073.60
plus costs of suit.
9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.,
Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in
writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and
provide Defendant with written verification thereof, otherwise, the debt will be assumed to be
valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for
Plaintiff will send Defendant the name and address of the original creditor if different from the
above.
30554061 2
WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment
in its favor and against Defendant, Pascual Martinez, in the amount of $9,073.60, and costs of
suit.
BARLEY SNYEYS>Y LLC
By:
Shawn M. Long, Esqu' e
Court I.D. 83774
126 East King Stre
Lancaster, PA 17 2-2893
717.299.5201
Attorneys for P intiff
30554061
VERIFICATION
Pennsylvania State Employees Credit Union
v. Pascual Martinez
I, Gregory R. Diffenderfer, being duly affirmed according to law, depose and say that I
am the Collection Manager for Pennsylvania State Employees Credit Union; that I am authorized
to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are
true and correct to the best of my knowledge, information, and belief.
To the extent that any of the averments in the foregoing document are based upon the
understanding or application of law, I have relied upon counsel in making this Verification.
This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to
unsworn falsification to authorities.
Dated: IZ b ZD l.(
Gregory R. Diffenderfer
30554061
EXHIBIT "A"
t' r _
ADVANCE PROCEEDS VOUCHER
AND SECURITY AGREEMENT
Pennsylvania State
Employees Credit Union
PSECO P. O. Box 67013
Harrisburg, PA 17106-7013
(717) 234-8484
the financial link,,, (800) 237-7328
MEMHER NAME ': ', °;
PASCUAL MARTINEZ
2704 GREEN STREET "` D¢i
5/9/2006 MEMt?ER AgCO?JNT NUMeR , :. ,`
63/L10 r.. NOT,NUMBER - ,
0005339100
APT B
HARRISBURG, PA 17104-2237 PLIHPOSE:
Dealer Pur - `-
chase
TRANSACTION
YPE
. ?
EW LOAN 2. []
-END
DVANCE
LOAN A
3
OTHER
(DESCRIBE)
.
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EQUITY ADVANCE
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-, °---? - r-...... vj wr -111W U V IUIIUJ HUVaftcea Etna aeposltea into your share/share draft account, you agree (1) that the property referenced above
will secure the advance and any other advances you have now or receive In the future under the LOANLINER° Credit and Security Agreement (the Plan) and
any other amounts you owe us for any reason now or in the future in accordance with the terms of the Plan and (2) to make payments as disclosed above in
accordance with the terms of the Plan.
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Pennsylvania ?Stafe Employees'rCredit Union
PO Box 67013 a Hmntbwg, eA 17106.7013 - (717) 7348464 or (600) 737-7326 No 5339100 -
AUTODRAFT. VOID OVER 17,065,:00','., REFERENCE .l 8720438863',-VOID 120 DAYS AFTER 05102106
PAY TO E
ORDER OF ' 1DEALER) L (N?/L.I ? C,gvF/? $ { 9, ?y
ORDER OF ' •. -
L-rl i? *v f ?T??-O -v? 1 K i `t' "r'? ?? /?t'y,' /?'°,J??
re
DOLLARS
IMPORTANT: VOID UNLESS DEALER ENDORSEMENT COMPLETED,
Burry s Ord r JEW of Sale 1New and Used VeNdesl and factoryinvoice thew Vah;clisl
mun be received beiw; the AutaDratt la lecelved
6y PSECU or the AvroDrast wnl bey
.
retwned. No portion of the pmaeedi of ux Awonratt'shall bs paid tc Irv Borrowerlsl
or to any agent of the Borrowedd. This AdloDraft shall not bs wad to purchase '
ncanstnrctad. cortvr .iA rlesaiq th.ftt adveged, or flood tided vehtdes or vetddes
tided ovlsido the Urvtod Sales. By -p1ing the procceds of this deli, you agree to -
the terms Imid on the reversa ad Ir PSECU FAR/ 717.707.6364 '•
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MEMBER ENDORSEMENT-.r f•?,•?,.
By endorsm? k.'Aut.6' if ; I[We agree to, the terms listed on the reverse s da .
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?'ol thridraft/CcmplaU th° following npayrrN nt intom>•tion: i '(',r' TERM: C7r M. thod Q Aw. Tnmsfsr E3Pawro11 D•du.d_ %AMontNy Ca pms _
IKtonthsl Fragrancy: Ipmonlhly ?N-WaeAly 0Semi40o Uly
Member Endorsement
PASCUAL Co-Applicant Endorsement
NO CO-APPLICANT
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1is t0A'rLPIER Cfcidit ant Sccunty Agmemont, r:hicIh Ind, les the Bull) n
t n i g D ) uie II be rerr.recJ to as the Plan.The Plan (locur ,file udc hi;
trli( urx;n and in r!(1;-ndum You, your an-I borrower n can my ho,
t, e ?1 mil Credit union we, our a;)d us mean I'ol_CtJ or;lily wo to a.h,m tl? Cr al t
t nicm inin f(.rs its gh? -, under the Plan.
HOW THIN PLAN WORI(S -- this is an open-end, multi feature(I r:re(ht plan vlo
cintv.,pate _r, at, fron time to time, ynu %vill bnnow money fciilled "advances"1 undor
the Plan. We are not required to make advances to you under the Plan and can
refuse a request for an advance at any time. lhn Addonrluin rlesniihos tho
different types of credit (called "subacceUnts") available Wider the Plan, the current
interest r'ade for each subaccount expressed as a daily periodic rate and
correspondinrj annum percentage rate and other charges. It may also havo other
terms and it schedule for determining the payment amounts.
CREDIT LIMIT - We may, but do not have to, estiihIish a crodit limit on certain
subaccount s. If a credit limit is set for a subaccount, you prornise not to exceed the
established credit lirnit. If YOU exceed the credit limit, you prornise to repay
immediately the amount which exceeds the credit limit.
REPAYMENT - You promise to repay all amounts you owe under the Plan plu
interest. Payments are due on the last (Jay of the month unless we set a different clay
at the time of an advance. If the Addendum has no payment schedule for a
subaccount, your payment will be determined at the firne of each advance.
Payments must include any amount past clue and any amount by which you have
exceeded any credit limit you have been given for a subaccount. You may repay all
or part of what you owe at any time without any prepayment penalty. Even if you
prepay, you will still be required to make the regularly scheduled payments unless
we agree in writing to a change in the payment schedule. If you have a joint
sharedraft account, you will be responsible for paying all overdraft advances
obtained by a joint holder of the sharedraft account. Unless otherwise required by
law, payrnents will be applied to amounts owed under the Plan, in the manner the;
Credit Union chooses.
PLAN ACCESS -You can obtain credit advances in any manner authorized by us. If
we allow you to use your ATM/Debit card to access the Plan, you may be liable for the
unauthorized use of your ATM/Debit card. You will not be liable for unauthorized use
that occurs after you notify us, orally or in willing, u'i tfie loss, iiieft, or poSsiblc
unauthorized use. If you believe your ATM/Debit card has been lost or Stolen,
immediately inform the Credit Union by calling or writing us at the telephone number or
address that appears elsewhere in the Plan. If the card is used to obtain unauthorized
advances directly from the Plan, your liability will not exceed $50. If the unauthorizod
withdrawal is from a sharedraft account, your liability is governed by the Regulation E
disclosures you received at the time you received) your ATM/Debit card, even if the
withdrawal rasults in in advance being made from your overdraft subaccount.
FINANCE CHARGE - The dollar amount you pay for money borrowed is called a
"finance charge" and begins on the date of each advance. A finance charge will be
computed separately for each separate balance under the Plan. To compute the
finance charge, the unpaid balance for each day since your last payment (or since
an advance if you have not yet made a payment) is multiplied by the applicable daily
periodic rate. The sum of these amounts is the finance charge owed. The balance
used to compute the finance charge is the unpaid balance each day after payments
and credits to that balance have been subtracted and any additions to the balance
have been made. In addition to interest, we may charge other finance charges which
are disclosed on the Addendum. If the interest rate is a variable interest rate, the
Addendum explains how the variable interest rate works.
SECURITY -You pledge as security for the Plan all shares and dividends and, if any,
all deposits and interest in all joint and individual accounts you have with us now and
in the future. If a specific dollar amount is pledged for an advance, we will freeze
shares in that account to the extent of the outstanding balance for the advance.
Otherwise, your pledged shares may be withdrawn unless you are in default. The
following paragraph applies in all states except in Ohio, Rhode Island and
Massachusetts: We have a statutory lien on the shares and dividends and, if any, the
deposits and interest in all individual and joint accounts you have with us and may
exercise our rights under the lien to the extent permitted by state law. (We are state
chartered if our name does not include the term "Federal Credit Union") For all
borrowers: The statutory lien and/or your pledge will allow us to apply the funds
in your account(s) to what you owe when you are in default. The statutory lien and
your pledge do not apply to any Individual Retirement Account or any other account
that would lose special tax treatment under state or federal law if given as security.
Additional security for the Plan may be required at the time of an advance. If a
subaccount identifies a type of property (such as "New Cars") you must give that
type of property as security when you get an advance under that subaccount. A
subaccount name such as 'Other Secured" means you must provide security
acceptable to us when you obtain an advance under that subaccount. Property you
give as security will secure all amounts owed under the Plan and all other loans you
have with us now or in the future, except any loan secured by your principal dwelling.
Property securing other loans you have with us may also secure the Plan.
C CUNA MUTUAL GRJUP 1930.2006.ALL PFiHT5 EQER','EG f -je
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I:.-.I < G(?r 67013 0 Harrisr ?rg. Fa 17106-.'01.3 0 (I17) 224 t34f3=i H:rrrr;hur y. (' %O) ?,3 i3_dl , , r. „Jch
C
L Dare Disclosures, -----
CREDIT INSURANCE - Credit r c'c (,ra,Jit d strbil;y ;1) tirance i; nptirrnal
under the Plan. If yon quality for nil Irnrc'h i I' :. ?s??n3nce from us, yon oull-iinn/.o
I us to add tho insurance ffe lams mr:ntl,!y fo jr rroan I)alance, and ch:ucfe ynu
intECa?t on tlic ontie halance. It ,nu c,lcct cr Jl m uianpe yo.rr poyjt of imry
ncrease or the period of limo nerc ?iy to rr p,ry ycic r nrlvrnce may hr)
cr d H incur rn, e r<<t?;., nmy ??hn 1 r li ,i'?n;J ' ill r,1 If thr? n'r
provide my notice, required by apt r ,tl,lr, h w
PERIODIC STATEMENT-On it r(rjilkn h,ir ; you ,Al wceive n t?tatr,mi;nf shoving ?
all transactions under the Plar during lho, pciiod covered try the ;latemont.
Statements and notices will be SEnt to you at the most recent ndclress you have
given us in writing, Unless applicable law requires notice to each joint borrrnnror,
notice to any one of you will be notice to rill.
JOINT ACCOUNTS - If this is a joint account, each of you is individually and jointly
responsible for paying all arnuunls owed Th(rt means we can enforce our righls
under the Plan against any one of you individually or against all of you together. If you
give us inconsistent instructions, we can refuse to follow your instructions. Unless our
written policy requires all of you to sign for in advance, each of you authorizes the
other(s) to obtain advances individually and agrees to repay advances niado to ill(,,
other(s). Any joint accountholder may terminate the Plan by giving us prior written
notice. If any of you terminate the Plan, the Plan is terminated for all of you. You
remain liable individually and jointly for all advances incurred before termination.
FEES AND CHARGES - If you give Us a security interest in certain types of
property, we may charge you a filing fee to perfect our interest in the property. If we
do, the amount of the fee will be disclosed to you at the time you obtain an advance.
We may also charge you other fees in connection with the Plan. Our current fees are
disclosed on the Addendum and will be added to your loan balance unless you pay
them in cash.
UPDATING CREDIT INFORMATION -- You prornise that you will promptly give us
written notice if you move, change your name or employment, or if any other
information you provided to us changes. Upon our request, you also agree to
provide us updated financial information.
DEFAULT -- The following paragraph applies to borrowers in Idaho, Kansas,
Mninn nnrl South Carolina: You will be in default if you do not make a payment of
the amount required when it is due. You will also be in default if we believe the
prospect of payment, performance, or realization on any property given as security
is significantly impaired.
The following paragraph applies only to borrowers in Wisconsin: You will be in
default if you fail to make a payment when due two times during any 12 month
period. You will be in default if breaking any promise made under the Plan materially
impairs your ability to repay what you owe or materially impairs the condition, value,
or protection of or our right in any property you gave as security.
The following paragraph applies only to borrowers in Iowa: You will be in
default if you are more than 10 days late in making a payment. You will also be in
default if you do not comply with the terms of the Plan and your failure to comply
materially impairs any property you gave as security or your ability to repay what you
owe under the Plan.
The following paragraph applies to borrowers in all other states: You will be in
default if you do not make a payment Of the amount required when it is due. You will
be in default if you break any promise you made under the Plan or if anyone is in
default under any security agreement made in connection with an advance under
the Plan. You will be in default if you die, file for bankruptcy, become insolvent, if you
make any false or misleading statements in any credit application or update of credit
information, or if something happens we believe may substantially reduce your
ability to repay what you owe. You will be in default if any property you have given
us as security is repossessed by someone else, seized under a forfeiture or similar
law, or if anything else happens that significantly affects the value of the property or
our security interest in it. You will also be in default under the Plan if you are in default
under any other loan agreement with Us.
ACTIONS AFTER DEFAULT - The following paragraph applies to borrowers in
Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri,
Nebraska, South Carolina and West Virginia: When you are in default and after
expiration of any right you have under applicable state law to cure your default, we can
demand immediate payment of the entire unpaid balance under the Plan without
giving you advance notice.
The following paragraph applies to borrowers in all other states except Wisconsin
and Louisiana: When you are in default, we can require immediate payment
(acceleration) of the entire unpaid balance under the Plan. You waive any right you have
to demand for payment, notice of intent to accelerate and notice of acceleration.
The following paragraphs apply to borrowers in all states except Wisconsin and
Louisiana: If immediate payment is demanded, you will continue to pay interest until
what you owe has been repaid at the applicable interest rates in effect or, if applicable,
_, _.--- CPsr,101 P SECU FORM 3116
JBXX0001-2037-2092-1 (3:06)
LOANLINER° Credit and Security Credit Agreement (continued)
at the default rate disclosed on the Addendum. If a demand for immediate payment
has neon mane, m_ir shares and/or deposits can be applied towards what you owe
as provided in the section above called 'Security' We can also exercise any other
rights given by 12w when you are in default.
You agree the Credit Union has the right to take possession of any 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. If the property is a motor vehicle or boat, you agree that we may
obtain a key or other device necessary to unlock and operate it, when you are in
default. We will not be responsible for any other property, not covered by this
Agreement, that you leave inside the property or that is attached to the property. We
will try to return that property to you or make it available for you to claim.
After we have possession of the property, we can sell it and apply the money to any
amounts you owe u5.'Alo ,.ill give you notice of any public disposition or the date after
which a private disposition will be held. Our expenses for taking possession of and
selling the property will be deducted from the money received from the sale. Those
costs may include the cost of storing the property, preparing it for sale and attorney's
fees to the extent permitted under state law or awarded under the Bankruptcy Code.
You must pay any amount that remains unpaid after the sale money has been applied
to any unpaid balance under the Plan. You agree to pay interest on that amount at the
same rate as the advance, or, if applicable, at the default rate disclosed on the
Addendum, until that amount has been paid.
The following paragraph applies only to Wisconsin borrowers: When you are in
default and after expiration of any right you have under applicable state law to cure your
default, we may require immediate payment of your outstanding loan balance under the
Plan and seek possession of property given as security. You may voluntarily give the
property to us if you choose, or we may seek to take possession of the property by
judicial process. If we repossess the property, you agree to pay reasonable expenses
incurred in disposing of the property. If the property is a motor vehicle, mobile home,
trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted
by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains
unpaid after the sale money has been applied to what you owe under the Plan. You
agree to pay interest on any unpaid amount at the same rate as the advance, or, if
applicable, at the default rate disclosed on the Addendum, until that amount is paid.
If the property is located outside Wisconsin at the time of default, we may take
possession of the property without judicial process, if permitted by the state where
the property is located.
The following paragraph applies only to Louisiana borrowers: When you are in
default, we can require immediate payment (acceleration) of the entire unpaid
.....+....h., oi.,., vo ,•,nivn nnv right you have to demand for navment nntira
_ -- - . ,
of intent to accelerate and notice of acceleration. If immediate payment is
demanded, you will continue to pay interest until what you owe has been repaid at
the applicable interest rates in effect unless a default rate is disclosed on the
Addendum, If a demand for immediate payment has been made, the shares and
deposits given as security for the Plan can be applied towards what you owe. We
can also exercise any other rights given by law when you are in default and our
rights under any security agreements you have with us.
CANCELLING OR CHANGING THE PLAN - The following paragraph applies
only to borrowers In Illinois: We have the right to change the terms of the Plan from
time to time after giving you any advance notice required by law. Any change to the
interest rate or other charges will apply to future advances.
The following paragraph applies only to borrowers In Wisconsin: We can
change the terms of the Plan from time to time in accordance with Section 422.415
of the Wisconsin Statutes. You will be notified of any change in terms. An increase
in the daily periodic rate under a variable rate interest rate is not considered a
change in terms under the Plan. We can cancel the entire Plan or any part of the
Plan at any time. You may cancel the Plan at any time by giving us prior written
notice. Your obligation to pay the unpaid balances under the terms of the Plan
continues whether you or the credit union cancel the Plan, except to the extent that
your liability is limited by Section 422.4155 of the Wisconsin Statutes.
The following paragraph applies only to borrowers in Iowa: We can change the
terms of the Plan from time to time after giving you any advance notice required by
law. A change that increases the rate of finance charge or other charge, that
increases the amount of your payments, or that otherwise adversely affects existing
balances will apply to existing balances only if you agree to the change or you use
the Plan after receiving notice that your use of the Plan means you agree the
change applies to existing balances.
The following paragraph applies to borrowers in all other states: We have the
right to change the terms of the Plan from time to time after giving you any advance
notice required by law. Any change in the interest rate will apply to future advances,
and at our discretion and subject to any requirements of applicable law, will also
apply to unpaid balances.
The following paragraph applies to all but Wisconsin borrowers: An increase in
the daily periodic rate under a variable interest rate is not considered a change in
terms under the Plan. We can cancel the entire Plan or any part of the Plan at any
time. You may cancel the Plan at any time by giving us prior written notice. Your
obligation to pay the unpaid balances under the terms of the Plan continues whether
you or the Credit Union cancel the Plan.
DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN -We can delay
enforcing any of our rights under this Plan any number of times without losing the
ability to exercise our rights later. We can enforce this Plan against your heirs or
legal representatives. If we change the terms of the Plan, you agree that this Plan
will continue to protect us.
CONTINUED EFFECTIVENESS - If any part of this Pian is determined by a court
to be unenforceable, the rest will remain in effect
NOTICE TO UTAH BORROWERS - This written agreement is a final expression of
the agreement between you and the Credit Union. This written agreement may not
be contradicted by evidence of any oral agreement
The following is required by Vermont law - NOTICE TO CO-SIGNER - YOUR
SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE
FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY,
THE.LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU.
The following paragraphs apply if you give security in connection with an
advance under the PIan.They apply to borrowers in a!I states except Louisiana.
Louisiana borrowers will execute a separate security agreement. Borrowers in
other states may also be asked to execute a separate security agreement.
THE SECURITY FOR THE PLAN - You give us what is known as a security
interest in all property described in any receipt, voucher or other document you
receive for an advance ("the Advance'). The security interest you give includes all
accessions. Accessions are things which are attached to or installed in the property
now or in the future. The security interest also includes any replacements for the
property which you buy within 10 days of the Advance or any extensions, renewals
or refinancing of the Advance. It also includes any money you receive from selling
the property or from insurance you have on the property. If the value of the property
declines, you promise to give us more property as security if asked to do so.
WHATTHE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS
-The security interest secures the Advance described in the receipt, voucher or any
other document you receive at the time of the Advance and any extensions, renewals
or refinancings of the Advance. It also secures any other advances you have now
or receive in the future under the Plan 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 owe.
OWNERSHIP OF THE PROPERTY - You promise that you own all property you
give as security or if the Advance is to buy the property, you promise you will use
the Advance for that purpose. You promise that no one else has any interest in or
claim against the property that you have not already told us about. You promise not
to sell or lease the property or to use it as security for a loan with another creditor
until the Adva.n.r_.a is renaid. You promise you will allow no other security interest or
lien to attach to the property either by your actions or by operation of law.
PROPERTY INSURANCE, TAXES AND FEES - You must maintain property
insurance on all property that you give as security under the Plan. You may purchase
the property insurance from anyone you choose who is acceptable to the Credit
Union. The amount and coverage of the property insurance must be acceptable to
us. You may provide the property insurance through a policy you already have, or
through a policy you get and pay for. You promise to make the insurance policy
payable to us and to deliver the policy or proof of coverage to us if asked to do so.
If you cancel your insuranc6 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
properly or apply it towards what you owe. You authorize us to endorse any draft or
check which may be payable to you in order for us to collect any refund or benefits
due under your insurance policy. You also promise to pay all taxes and fees (like
registration fees) due on the property.
If you do not pay the taxes or fees on the property when due or keep it insured, we may
pay these obligations, but we are not required to do so. Any money we spend for taxes,
fees or insurance will be added to the unpaid balance of the advance and you will pay
interest on those amounts at the same rate you agreed to pay on the advance. We may
receive payments in connection with the insurance from a company which provides the
insurance. We may monitor our loans for the purpose of determining whether you and
other borrowers have complied with the insurance requirements of our loan agreements
or may engage others to do so. The insurance charge added to an advance may include
(1) the insurance company's payments to us and (2) the cost of determining compliance
with the insurance requirements. If we add amounts for taxes, fees or insurance to the
unpaid balance of an advance, we may increase your payments to pay the amount
added within the term of the insurance or approximate term of the advance.
INSURANCE NOTICE - If you do not purchase the required property insurance,
the insurance we may purchase and charge you for will cover only our interest in the
property. The premium for this insurance may be higher because the insurance
company may have given us the right to purchase insurance after uninsured
collateral is lost or damaged. The insurance will not be liability insurance and
will not satisfy any state financial responsibility or no fault laws.
PROTECTING THE SECURITY INTEREST - If your state issues a title for the
property, you promise to have our security interest shown on the title. We may have
to file what is called a financing statement to protect our security interest from the
claims of others. If asked to do so, you promise to sign a financing statement. You
also promise to do whatever else we think is necessary to protect our security
interest in the property. You promise to pay all costs, including but not limited to any
attorney fees, we incur in protecting our security interest and rights in the property,
to the extent permitted by applicable law.
LOANLINER' Credit and Security Credit Agreement (continued)
USE OF PROPERTY - Until the Advance has been paid oaf, you promise you will:
(1) lJse the property carefully and keep it in hood repair (2)Obtain our written
permission before making major changes to the property or changing the address
where the property is kept (3) Inform us in writing before changing your address. (4)
Allow us to inspect the property. (5) Promptly notify us if the property is damaged,
stolen or abused. ;6) Not use the property for any unla.vful purpose (7) Not to retitle
property in another state without telling us.
NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE
- THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO
REPOSSESSION. iF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE,
AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN
THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE
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
This notice contains important information about your rights and our responsibilities
under the Fair Credit Billing Act. You are advised to read your monthly statement
and review it for any error discrepancies or unauthorized transactions.
NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR
STATEMENT. If you think your statement is wrong, or if you need more information
about a transaction on your statement, write us on a separate sheet at the address
listed on your statement. You are required to notify us in writing within 60 days
following the date on which we sent your statement wherein the error or problem
first appeared regarding any discrepancy or unauthorized transactions on your
account. Failure to notify us may result in your acceptance of any responsibility for
payment or reimbursement to us for any such error or discrepancy on your account.
Write to us as soon as possible. You can telephone us, but doing so will not
preserve your rights.
In your letter, give us the following information:
Your name and account number.
The dollar amount of the suspected error.
Describe the error and explain, if you can, why you believe there is an error.
If you need more information, describe the item you are not sure about.
__ .`._. _ --•~c -- l -- pirfl nn-rd . n, ar;ta„ntlc ally from u, share
account or checking account, you can stop the payment on any amount you think is
wrong. To stop the payment your letter must reach us three business days before the
automatic payment is scheduled to occur.
YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR
WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we
have corrected the error by then. Within 90 days, we must either correct the error or
explain why we believe the statement was correct.
In this Agreement, the words you and your means each and all of those who apply
for the card or who signs this Agreement. Card means the Visa Credit Card and any
duplicates and renewals we issue. Account means your Visa Credit Card Line of
Credit account with us. We, us, and ours means this Credit Union.
1. RESPONSIBILITY— If we issue you-e eard,-you agree to-repay efl-debts and the
Finance Charge arising from the use of the card and the card account. For example,
you are responsible for charges made by yourself, your spouse and minor children.
You are also responsible for charges made by anyone else to whom you give the
card, and this responsibility continues until the card is recovered. You cannot disclaim
responsibility by notifying us, but we will close the account for new transactions if you
so request and return all cards. Your obligation to pay the account balance continues
even though an agreement, divorce decree or other court judgment to which we are
not a party may direct you or one of the other persons responsible to pay the account.
The cards remain our property and you must recover and surrender to us all cards
upon our request and upon termination of this Agreement.
2. LOST CARD NOTIFICATION - If you believe the card has been lost or stolen,
you will immediately call the Credit Union at (717) 234-8484 or (800) 237-7328. After
hours call (800) 556-5678.
3. LIABILITY FOR UNAUTHORIZED USE -You agree to notify us immediately, orally
or in writing of the loss, theft or unauthorized use of your Credit Card. You may be liable
for the unauthorized use of your Credit Card. You will not be liable for unauthorized use
that occurs after you notify us of the loss, theft, or possible unauthorized use. You will have
no liability for unauthorized purchases made with your Credit Card, unless you are grossly
negligent in the handling of your Card. In any case, your liability will not exceed $50.
4. CREDIT LINE - if we approve your application, we will establish a self-
replenishing Line of Credit for you and notify you of its amount when we issue the
card. You agree not to let the account balance exceed this approved Credit Line. Each
payment you make on the account will restore your Credit Line by the amount of the
payment which is applied to the principal. You may request an increase in your Credit
penalty for unlawful failure to return a motor vehicle is one year in prison and!or a
fine of $150,000.
va, those members who purchase a vehicle u^dl°r the
DRIVe Program, please review the following FTC Notice:
NOTICE
ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT
IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH
THE DEBTOR COULD ASSERT AGAINST THE SELLER
OF GOODS OR SERVICES OBTAINED WITH THE
PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE
DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY T HE
DEBTOR HEREUNDER.
After we receive your letter, we cannot try to collect any amount you question, or report
you as delinquent. We can continue to send statements to you for the amount you
question, including finance charges, and we can apply any unpaid amount against your
credit limit. You do not have to pay any questioned amount while we are investigating,
but you are still obligated to pay the parts of your statement that are not in question.
If we find that we made a mistake on your statement, you will not have to pay any
finance charges related to any questioned amount. If we didn't make a mistake, you
may have to pay finance charges, and you will have to make up any missed
payments on the questioned amount. In either case, we will send you a statement
of the amount you owe and the date that it is due.
If you fail to pay the amount that we think you owe, we may report you as delinquent.
However, if our explanation does not satisfy you and you write to us within ten days
telling us that you still refuse to pay, we must tell anyone we report you to that you
have a question about your statement. And, we must tell you the name of anyone
we reported you to. We must tell anyone we report you to that the matter has been
settled between us when it finally is.
If we don't follow these rules, we can't collect the first $50 of the questioned amount,
even if your statement was correct.
SPECIAL RULE FOR CREDIT CARD PURCHASES - If you have a problem with
have tried in good faith to correct the problem with the merchant, you may have the
right not to pay the remaining amount due on the property or services. There are two
limitations on this right: (a) You must have made the purchase in your home state or,
if not within your home state, within 100 miles of your current mailing address; and
(b) The purchase price must have been more than $50.
These limitations do not apply if we own or operate the merchant, or if we mailed
you the advertisement for the property or services.
Line only by written application to us, which must be approved by our credit committee
or loan officer. By giving you written notice we may reduce your Credit Line from time
to time, or with good cause, revoke your card and terminate this Agreement. Good
cause includes your failure to comply with this Agreement or any other agreement with
us,_Qr our adverse reevgluatiQn...of yQur.creditworthiness. You may-also. terminate this
Agreement at any time, but termination by either of us does not affect your obligation
to pay the account balance.
5. CREDIT INFORMATION -You authorize us to investigate your credit standing
when opening, renewing or reviewing your account, and you authorize us to disclose
information regarding your account to credit bureaus and other creditors who inquire
of us about your credit standing.
6. MONTHLY PAYMENT - We will mail you a statement every month showing your
Previous Balances of purchases and cash advances, the current transactions on your
account, the remaining credit available under your Credit Line, the New Balances of
purchases and cash advances, the Total New Balance, the Finance Charge due to date,
and any other billed fees, and the Minimum Payment required. Every month you must pay
at least the Minimum Payment within 25 days of your statement closing date. By separate
agreement you may authorize us to charge the minimum payment automatically to your
share or checking account with us. You may, of course, pay more frequently, pay more
than the Minimum Payment, or pay the Total New Balance in full, and you will reduce the
finance charge by doing so. If your monthly payment exceeds the total credit line balance
owed, we will automatically post the credit to your S1 shares.
The minimum payment will be (a) 2% of your Total New Balance, rounded up to the
next even dollar, or (b) $20.00, whichever is greater. In addition, at any time your Total
New Balance exceeds your Credit Line, you must immediately pay the excess upon our
demand. We will apply payments in the following manner: first to previous late fees,
then to previous cash advances finance charges, then to previous purchase finance
charges, then to current late fees, then to previous cash advance balances, then to
previous purchase balances in the order that they were posted to your account, then
to current cash advance balances, and then to current purchase balances.
Visa' Credit Card Agreement and Truth In Lending Disclosure (continued)
7. FINANCE CHARGES - You can avoid the Finance Charge on purchases by
paying the full amount of the, New Ralance of Purchases each month within 25 days
of your statement closing date. Otherwise, the New Balance of Purchases, and the
subsequent purchases from the date they are posted to your account, will be subject
to Finance Charge. Cash advarces are always subject to Finance Charge from the
date they are posted to your account.
Purchases: We calculate your finance charge by multiplying the average adjusted
daily balance (see explanation below), including new purchases, for the billing cycle
by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE
RATE as disclosed on the Addendum.
Cash Advances: We calculate your finance charge on cash advances by
multiplying the average adjusted daily balance (see explanation below) for cash
advances during the billing cycle by the monthly periodic advance rate and
corresponding ANNUAL PERCENTAGE RATE aS dISCIoSed uri the Adderiduni.
Balance Computation Method
Average Daily Balance for Purchases - The Average Daily Balance for Purchase
Transactions is calculated by adding the Daily Balances (Purchase Transaction) for
each day in the billing cycle, and then dividing by the number of days in the billing
cycle. To calculate the Daily Balance for purchases each day, we take the following
steps: We take the outstanding balance (all amounts you owe) at the start of the day.
Then, in the sequence in which amounts are posted to your account, we add the
amounts of all debits and subtract the amounts of all credits or payments which post
to your account that day. After applying payments and credits, we subtract the
amount of any unpaid Finance Charges or Late Charges. Then we also subtract the
amount of any Cash Advance transactions that posted to your account on that day or
in any previous day in the billing cycle. This gives us the Daily Balance for purchases.
Average Daily Balance for Cash Advances - Cash Advance Transactions which are
posted to your account are not included in the Average Daily Balance calculation for
purchases, and are therefore not subject to the monthly periodic rate for purchases. The
Average Daily Balance is calculated separately for Cash Advances and is subject to the
Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions
is calculated by adding the Daily Balances (Cash Transaction) for each day in the billing
cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily
Balance for cash each day, we take the following steps: We take the outstanding balance
(all amounts you owe) at the start of the day. Then, in the sequence in which amounts
are posted to your account, we add the amounts of all debits and subtract the amounts
of all credits or payments which post to your account that day. After applying payments
and credits, we subtract the amount of any unpaid Finance Charges or Late Charges.
Then we also subtract the amount of any Purchase Transactions that posted to your
. :.,I :_ y, :..
account on that ca , o, in any p. ..v, us ?. -. .+.., ..,. Th;c ^ CJ c thn n^IL.
Balance for Cash Advance Transactions. Note: Cash Advances are always subject to
finance charges and from the day they are posted to your account.
Payments are applied in the following manner: first to previous late fees, then to
previous cash advances finance charges, then to previous purchase finance
charges, then to current late fees, then to previous cash advance balances, then to
previous purchase balances in the order that they were posted to your account, then
to current cash advance balances, and then to current purchase balances. Credits
are applied first to the particular type of debt which is being credited, if any, and then
to the balance of your account.
Note also that if the total of the payments and credits which are posted to your
account by the Payment Due Date shown on a statement is equal to or exceeds the
New Balance shown on that statement, we will not apply the Monthly Periodic Rate
to your Account on your next statement.
8. DEFAULT-You will be in default if you fail to make any Minimum Payment within
25 days after your monthly statement closing date. You authorize us to transfer funds
sufficient to make the minimum payment due if your Visa loan is in default. You will
also be in default if your ability to repay us is materially reduced by a change in your
employment, an increase in your obligations, bankruptcy or insolvency proceedings
involving you, your death or your failure to abide by this Agreement, or if the value of
our security interest materially declines. We have the right to demand immediate
payment of your full account balance if you default, subject to our giving you any
notice required by law. To the extent permitted by law, you will also be required to pay
our collection expenses, including court costs and reasonable attorney fees.
9. USING THE CARD - To make a purchase or cash advance, there are two
alternative procedures to be followed. One is for you to present the card to a
participating Visa plan merchant, or another financial institution, and sign the sales
or cash advance draft which will be imprinted with your card. The other is to complete
the transaction by using your Personal Identification Number (PIN) in conjunction
with the card in an Automated Teller Machine or other type of electronic terminal that
provides access to the Visa system. You agree that you will not use your card for any
transaction that is illegal under applicable federal, state, or local law. The monthly
statement will identify the merchant, electronic terminal or financial institution at
which transactions were made, but sale, cash advance, credit or other slips cannot
1' be returned with the statement. You viill retain a copy of such slips furnished at the
time of the transaction in order to verify the monthly statement. The Credit Union may
make a reasonable charge for photocopies of slips you may request.
10. OVERDRAFT OPTION - If yo c!ect to _..,^draft to y, PSFCt! Visa Credit
Card, that election is subject to the existing credit mit and the agreement it represents
and the current loan policy at the time of the overdraft. You also understand that an
overdraft will be considered the same as a cash advance on your PSECU Visa Credit
Card and that the current Annual Percentage Rate for cash advances will apply.
11. RETURNS AND ADJUSTMENTS - Merchants and others who honor the card
may give credit for returns and adjustments, and they will do so by sending us a
credit slip which we will post to your Visa line of credit. If your credit and payments
exceed what you owe us, we will automatically post the excess credit balance to
your S1 Shares within 75 days. If the balance is one dollar or more, upon your
written request, we will refund the credit balance to you.
12. FOREIGN TRANSACTIONS - The exchange rate between the transaction
currency and the billing currency used for processing international transactions is a rate
selected by Visa from the range of rates available in wholesale currency markets for the
applicable central processing date, which rate may vary from the rate Visa itself
receives, or a government-mandated rate in effect for the applicable central processing
date. In each instance, an adjustment may be assessed based on the ISA fee imposed
by Visa. This fee, which totals 1 % of the transaction amount, will be assessed on all
transactions where the merchant country differs from the country of the card issuer.
13. SPECIAL RULES FOR VISA PURCHASES - If you disagree or find an error
with a Visa transaction, and have tried in good faith to correct the problem with the
merchant or the charges are the result of unauthorized or fraudulent use, or your
purchase cost more than $50 and was made from a plan merchant in your state
within 100 miles of your home, contact PSECU.
14. DISPUTED TRANSACTIONS - You are required to notify PSECU in writing
within 60 days following the date on which we sent your statement wherein the error
or problem first appeared regarding any discrepancy or unauthorized transaction on
your account. Telephoning PSECU does not preserve your dispute rights. You may
be required to provide us with documentation to support your dispute claims. In
addition, you may be required to complete a standard dispute form outlining the
details of your dispute. In cases of fraudulent card use, PSECU will also require a
notarized affidavit. In some cases we may ask you to notify the local authorities.
If we do not receive the proper requested documentation in the time specified you
may be held responsible for the transaction(s) in question. PSECU must adhere to
strict dispute timeframes set forth by Visa.
15. SECURITY INTEREST - To secure your account, you grant us a purchase
money security interest under the Uniform Commercial Code in any goods you
purchase through the account. If you default, we will have the right to recover any of
these goods which we have not been paid for through our application of your
payments in the manner described in the Monthly Payment section. With respect to
this account only, we will not assert any statutory right we may have if you are in
default to prevent withdrawal of your unpledged credit union shares (Deposits)
below the unpaid balance of your account. However, if you give or have given us a
specific pledge of your credit union shares (Deposits) by signing the Pledge of
Shares or otherwise, or any other security interests for all your debts, your account
will be secured by your pledged shares (Deposits) and by the property described in
those other security agreements, except for your home.
16. EFFECT OF AGREEMENT This Agreement is the contract which applies to
all transactions on your account even though the sales, cash advance, credit or
other slips you sign or receive may contain different terms. We may amend the
Agreement from time to time by sending you the advance written notice required by
law. Your use of the card thereafter will indicate your agreement to the amendments.
To the extent the law permits, and we indicate in our notice, amendments will apply
to your existing account balance as well as to future transactions.
17. LATE PAYMENT CHARGE - If your Minimum Payment is not received by the
first day of the month following your due date, you will be subject to a $20 charge.
18. RUSH FEES - You may incur additional charges for rush processing and rush
delivery of cards and/or PIN mailer.
19. OVER LIMIT FEE -A $20 fee will be applied for each monthly statement closing date
on which the outstanding balance exceeds the assigned credit limit by more than $100.
20. DRAFT COPIES - You may incur an additional charge for transaction
summary/sale draft documentation.
21. COPY RECEIVED - You acknowledge receipt of a copy of this Agreement.
22. ILLEGAL TRANSACTIONS PROHIBITED - You agree that you will not use
your card for any transaction that is illegal under applicable federal, state, or local law.
23. NO USE - Inactive Visa accounts that have no purchase or cash activity may
be closed without notice to you after 18 months of no activity.
24. NEURAL NETWORK - PSECU uses neural network systems to predict and
prevent unauthorized transactions. There may be occasions when a transaction is
declined because it is indicative of possible fraudulent activity.
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EXHIBIT "B"
l,C
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CERTIFICATE OF TITLE FOR A VEHICLE
568
090559999006584-001
1FMYU04192KA50411
VEHICLE tDENTRCATION NU11RER
SW ?
BODY TYPE DUE SEAT CAP
10/03/01 5/111/06
DATE PA TITLED DATE OF ISSUE
2002 FORD 56657268203 MA
YEAR MAKE OF VEHICI E TITLE N0,MBER
5/10/061 1147969 ?
PRIOR TITLE STATE CDON PROCD. DATE ODOM. MILES ODOM. STATUS
UNLADEN WEIGHT GVWR GCVJR TITLE BRANDS
REGISTERED OWNER(S)
PASCUAL MARTINEZ ----
769 LEE LN
ENOLA PA 17025
FIRST LIEN FAVOR OF:
PSECU
FIRST LIEN RELEASED _ k
DATE 01
BY_
AUTHORIZED REPRESENTATIVE
MAILING ADDRESS
SECOND LIEN FAVOR OF:
ODOhIEI'ER STATUS
0 = ACTUAL MILEAGE
1 MILEAGE EXCEEDS THE MECHANICAL
LIrAlT6
2 NOT THE ACTUAL L11LEAGE
3 = NOT THE ACTUAL IAILE.AGE-ODOMETER
TAMPERING VERIFIED
4 = EXEMPT FROM ODOMETER DISCLOSURE
TITLE BRANDS
A = ANTIQUE VEHICLE
C = CLASSIC VEHICLE
D . COLLECTIBLE VEHICLE
F = OUT OF COUNTRY
G =. ORIGINALLY MFGD. FOR NON-U. S.,
DISTRIBUTION
it = AGRICULTURAL VEHICLE
L = LOGGING VEHICLE
P = &WAS A POLICE VEHICLE
R = RECONSTRUCTED
S = STREET ROD
T = RECOVERED IHEFT VEHICLE.;
V . VEHICLE CONTAINS REISSUED VIN
W = FLOOD VEHICLE
X = ISANAS A TAXI -
If ? second lienholder Is listed upon satisfaction of thn first fen, the
Ilonholder must forward this Title to the Bureau of MotorVOhi;aas will
appropriate form and fee.
SECOND LIEN RELEASE[',
DATE
BY
AUTHORIZED REPRESENTATIVE
PSECU
P 0 BOX 67013
HARRISBURG PA 17106
I certify as of the date of issue, the official records of the Pennsylvania Department
of Transportation reflect that the person(s) or company named herein is the lawful owner
a • of the said vehicle.
SUBSCRIBED AND SWORN
TO BEFORE ME:
r
-ph
Q
CI 00
?
`
W t
l The w:da: ene 1-eby -kes applic 1- for Cenili-l of Till, to me .ehv,Ie tlxscnbe
? //-??
CO
ii stiN Ct to the enCUmv;.nces arb ctner Iega! claims Set 1-1 here.
O SIGNATURE OF APPLICANT OR AUTHORIZED S[0!1=n
/
lJ !
! SIGNATOFE OF CO APPUCANT.!-LE OF AUT--ZF:F.' Si,,%ER
ALLEN D BIEHLER
Secretary of Transportation
If a co-purchaser other than your spouse is listed and you want the title to
be listed as "Joint Tenants With Right of Survivorship" (On death of one
owner, title goes to surviving owner,) CHECK HERE O. Otherwise, the title
will be issued as "Tenants in Common" (On death of one owner, interest of
deceased owner goes to his/her heirs or estate)
1 IF NO LIEN, CHECK ? IS THIS AN ELT? (IF YES, FIN REQUIRED) YES D NICE]
1ST LIENHOLDER FINANCIAL INSTITUTION NUMBER:
1ST LIENHOLDER NAME
STREET
CITY STATE ZIP
IF NO 2ND LIEN, CHECK ? IS THIS AN ELT? (IF YES, FIN REQUIRED) YES ? NO?
! 2ND LIENHOLDER FINANCIAL INSTITUTON NUMBER'
1
2ND LIENHOLDER NAME
I STREET
CIT'/ STATE ZIP
(TYPE OR PRINT) Cemfica Fit :c must be submi( cd within 20 days a JOSS file purch, s a registered dealer holrfing the vehicle for resale
Ftul_RAL AND STATE LAWS REQUIRE THAT YOU STATE THE t.11LF/ GE IFi CV JfJECTION V ITH TF F f t FE=R OF 04'JFJERSHIP FAILURE WARNING - TO COMPLETE OR PROVIDING A FALSE STAT EbIENT MAY RESULT IN FINES OR IN'PP.ISONMENT
:? MIDDLE NAC.IE
A. ASSIGNMENT OF TITLE F --- LAST - -- -
t .;1 [ IPR('HASER On F'.,LL
.c ,.?r..,. I iI E Lest a' r".pc r knee: cote Inert ire cden-eter reading is - F' TJESS HAKE
rr'E I P
CG PUC"AS?R
i _ X miles and fa!:'EC,':: ire actual moe3ge cf mr, vehicie.
IRE
I t-
F?- NOT the actual miie'?E
sc f r r^ cJ r cal I ra L WARNING G omelet d crerancy ,r
. and that the ov:ners - - _ --- -- - ---
r -.e c t t n.e pride s tea t ei cu• L3tr n is h rec./ Z P P„a ? -E a,cE
1 ?ire,iiUe es?uslrih dearer ste i. S,a? of, l
SUBSCRIBED AND SWORN j -- - --_ -_-- _-- TO BEFORE N1E:
SIGNATURE OF PERSON ADNI
NI
I
STERING OATH
J
Q _CO PURCIIASE.l 51(' JATl1FT
PURCHASERANDOR
CO PURCHASER NiU
AiUST
LLJ HANDPRINTNAME HERE _____
Q _ SIGNATURE OF SE11EH
n. _-_
c
Q
_ SIGNATURE OF CO5EL1_ER
SELLER AND/OR -
ONDPR
N
AME
I
HERE
HA
TN
B. ? 1 1
•
-
IANe certify, to the best of my/our knowledge that the odometer reading Is LAST
FIRST MIDDLE NAME
TENTHS
X miles and reflects the actual mileage of the vehicle,
r PURCHASER OR FULL
l
f
h BUSINESS NAME
un
ess one o
t
e following boxes is checked:
I-1 Reflects the amount of mileage 0 Is NOT the actual mileage
t
J i
f it
h
i CO-PURCHASER -
_
n excess o
s mec
an
cal limits WARNING: Odometer discrepancy STREET
INVe further certify that the vehicle is free of any encumbrance and that the ownership is hereby
transferred to the person(s) or the dealer listed ADDRESS
--
.
- CITY
SUBSCRIBED AND SWORN
TO BEFORE ME PURCHASE PRICE
STATE ZIP
MO. DAY YEAR OR IAN
-
SIGNATURC OF PERSON ADMINISTERING OATH PURCHASER SIGNATURE
Q
W
C0 CO-PUHCHASFR SIGNATURE___
COR
URCH
S
12 P
A
ER MUST. -
Q HANDPRINT NAME HER,
S
Q . SIUNAI UHE OF SELLEN
I" ..
F- SELLER MUST
-
HANDPRINT NAME HERE
121AU
• 1 aim=
I/Wo certify, to the best of my/our knowledge that the odometer reading Is be completed.,
LAST FIRST MIDDI F NAME
TENTHS
X miles and reflects the actual mileage of the vehicle, PURCHASER OR FULL -
unles
f th
ll
f
i
b
i BUSINESS NAME
s one o
e
o
ow
ng
oxes
s checked:
f 1 Reflects the amount of mileage Is NOT the actual mileage ?l
L
I in excess of its mecha
i
l li
it
'?
e -----
CO-PURCHASER
-
-
n
ca
m
s
WARNING: Odometer discr
pancy
lM further certify that the vehicle Is free of any encumbrance and that the ownership is hereby
ransfermd to the person(s) or Ilia dealer listed - -------
STREET
.
--- _
CITY --
SUBSCRIBED AND SWORN -- -
TO BEFORE ME: PURCHASE PRICE
STATE -
_ MO. DAY YEAR ZIP OR DIN
)
_ SIGNATURE OF PERSON ADMINISTERING OATH
J
_ PURCHASER SIGNATURE
W
CO-PURCHASER SIGNATURE
PURCHASER -
CO-PURCHASER ER MUST
OP ill NAME HEflE
Q SI NATU C OF SELLER
_
NANDP
7
A
N
ME HERE
R N
t 1
INJa certify, to the best of my/our knowledge that the odometer reading Is
TENTHS LAST FIRST MIDDLE NAME
-
X miles and reflects the actual mileage of the vehicle, PURCHASER OR FULL
unless one of the followin
boxes i
ch
k
d BUSINESS NAME
g
s
ec
e
:
r? Reflects the amount of mileage El Is NOT the actual mileage
?J in excess of its mechani
l li
it CO-PURCHASER
ca
m
s WARNING: Odometer discrepancy i
1IVV
f
th
f STREET
e
ur
er certi
y that the vehicle is free of any encumbrance and that the ownership Is hereby
transferred to the person(s) or the dealor'isted. ADDRESS
-
CITY
SUBSCRIBED AND SWORN
TO BEFORE ME:
MO. DAY YEAR PURCHASE PRICE
STATE ZIP On DIN
SIGNATURE OF PERSON ADMINISTERING OATH PURCHASER SIGNATURE
W
co ? __ __ CO-PURCHASER S:GHA7URE
____,
PURCHASER AND(OR
CO-PURCHASER (.RUST
HArIOPRINT NANIE HERE
n_ I Z
v S
SICNATJRE OF SF'.
_FR
s f
c
o _
SELLER MUST "
_ I HA,NDPR;NT NAME HERE
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EXHIBIT "C"
PSE(
02/24/2009
Via Certified and First Class Mail
PASCUAL MARTINEZ
789 LEE LN
ENOLA, PA 17025-1503
NOTICE OF REPOSSESSION AND RIGHT TO REDEEM
You are hereby notified that your 2002 Ford Escape VIN# IFMYU04192KA50411 has been repossessed
by the Pennsylvania State Employees Credit Union ("PSECU"). Yoy have failed to pay the 01/08/2009
installment due under the above Loan and Secuirty Agreement (the "Contract").
The motor vehicle is currently being stored by: Richard & Associates, 3999 Spring Rd. Shermans Dale PA
17090. (717) 241-5884. You may redeem the motor vehicle and terminate the Contract by paying the
following amounts on or before 5:00 p.m. on 03/11/2009.
Unpaid principal balance $10,778.66
Accrued Interest $67.08
ADDITIONAL COST IF REPOSSESSED MORE THAN 15 DAYS AFTER DEFAULT
Repossession Expense $350.00
Storage expense @ $20 per day (2/24/09-3/11/09) $320.00
Late Fees $14.34
Total Cost to Redeem $11,530.08
Payment to redeem must be in cash, certified funds or a cashier's check.
We will sell the 2002 Ford Escape at private sale sometime after 03/11/2009. The money that we get from
the sale (after paying our costs) will reduce the amount you owe. If we get less money than you owe, you
will still owe us the difference. If we get more money than you owe, you will get the extra money
unless we must pay it to someone else, or use it to pay other loans you owe to PSECU. You can get the
property back at any time before we sell it by paying us the full amount you owe (not just the past due
payments), including our expenses. If you want us to explain to you in writing how we have figured the
amount that you owe us or you need more information about the sale, you may call us at
(717) 234-8484, ext. 3116 or (800) 237-7328 or write us at PSECU, P.O. Box 67013, 11arrisburg, Pa.
17110-2990, and request a written explanation. You should also contact us if you are unable to pay the
foregoing amount in full prior to the above deadline. PSECU niay allow you to reinstate your loan, if
you qualify, upon payment of the arrears and additional costs only.
We are sending this notice to the following other people who have an interest in the collateral listed or who
owe money under your agreement: (Names of all other debtors and obligors, if any)
You have 30 days to make arrangements to take possession of the personal effects found in the vehicle.
Failure to recover them in this time period will result in disposal of such personal effects.
Sincerely, _ T
,
Q j` i
> 9l
Jodie Ross
Account Advisor Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD)
psecu.com
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson
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Sheriff
Jody S Smith
Chief Deputy E3
Richard W Stewart
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Solicito r'
Pennsylvania State Employees Credit Union Case Number
vs. 2011-4844
Pascual Martinez
SHERIFF'S RETURN OF SERVICE
06/13/2011 05:27 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
June 13, 2011 at 1727 hours, he served a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: Pascual Martinez, by making known unto herself personally, at 789 Lee Lane,
Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her
personally the said true and correct copy of the same.
GERALD WORT HINGTO EPUTY
SHERIFF COST: $43.00
June 15, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
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