HomeMy WebLinkAbout12-3695IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVA.J?L? , _'
ASSET ACCEPTANCE, LLC No: )a - SOS GVI
Plaintiff rT1
:_,J -
VS. CIVIL ACTION - LAW
KERRY F CRUM C-)
-: ?'
- -
Defendant(s) ;. -.;
NOTICE TO DEFEND
You have been sued in Court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after this Complaint and Notice are served, by entering a
written appearance personally or by an attorney and filing in writing with the Court your defenses or
objections to the claims set forth against you. You are warned that if you fail to do so, the case may
proceed without you and a judgment may be entered against you by the court without further notice for
any money claimed or for any other claim or relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET HELP. 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 - COURT ADMINISTRATOR
32 S BEDFORD ST.
CARLSILE PA 17013
Telephone 717-249-3166
PA_0101 File No.: 12-10578
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE, LLC I No:
Plaintiff
vs. I CIVIL ACTION - LAW
KERRY F CRUM
Defendant(s)
AVISO PARA DEFENDER
USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defenderse de las demandas que
se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20)
dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un
abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a,
las demandas presentadas aqui en contra suya. Se le advierte de que si usted fall de tomar accion como se
describe anteriormente, el caso pude proceder sin usted y un fallo por cualquier suma de dinero reclamada
en la demanda o cualquier reclamacion o remedio solicitado por el demandante puede ser dictado en
contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad an otros
derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED
NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUENTE 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 POSSIBLE QUE
ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN
SERVICIOS LEGALES SIN CARGO O BAJO COSO A PERSONAS QUE CALIFICAN.
CUMBERLAND COUNTY - COURT ADMINISTRATOR
32 S BEDFORD ST.
CARLSILE PA 17013
Telephone 717-249-3166
PA_0101 File No.: 12-10578
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE, LLC
28405 VAN DYKE
WARREN, MI 48093
Plaintiff
No:
CIVIL ACTION - LAW
vs.
KERRY F CRUM
Defendant(s)
COMPLAINT
AND NOW, comes Plaintiff, by and through its attorneys, FULTON, FREEDMAN &
GULLACE, LLP, and files this Complaint and in support avers as follows:
1. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was
assigned all rights, title and interest to Defendant's CHASE BANK/ HERITAGE FIRST
USA/CHASE account XXXXXXXXXXXX-3108 (ASSET ACCEPTANCE, LLC Number
41232874) (hereinafter "the account").
2. Upon information and belief, Defendant(s), KERRY F CRUM, has a last known address(es)
of: 717 MARKET ST APT 305, LEMOYNE, PA 170431581.
3. Upon information and belief, the account is based on a written credit agreement entered into
between Defendant and the original grantor; as provided to Plaintiff, the material terms of the
agreement applicable to accounts issued by CHASE BANK/ HERITAGE FIRST USA/CHASE
are attached hereto.
4. Upon information and belief, Defendant(s) used or authorized the use of the account to obtain
loans from the original credit grantor for the purpose of obtaining goods, and/or services and/or
cash advances.
5. Defendant(s) failed to make full payment of the amount owed on the account.
6. Upon information and belief, the last payment posted to the account on July 02, 2008.
7. The account shows that the Defendant(s) owe(s) a balance of $19,405.35 plus interest which
has accrued from the date of assignment at a rate of 6.00 % per year, the amount of interest
which has accrued is $2,569.85.
PA_0100 File No.: 12-10578 Client Acct No.: 41232874
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in
favor of the Plaintiff and against Defendant(s) in the amount of $21,975.20, plus costs of this
action and any other relief this Court deems just and reasonable.
DAVID R. GALLOWAY 87326
FULTON, FRIEDMAN & GULLA , LLP
130B GETTYSBURG PIKE
MECHANICSBURG, PA 17055
(877) 386-5383
Attorneys for Plaintiff
PA_0100 File No.: 12-10578 Client Acct No.: 41232874
VERIFICATION
I verify that the facts set forth on this Complaint are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities.
Because of my title, I am authorized to make this verification on behalf of Plaintiff.
Date: IaE) J By:
CHRISTINE NIEMAN
Print Name
Signature
? en ?-i,
Title with Plaintiff
PA_0100 File No.: 12-10578 Client Acct No.: 41232874
EXHIBIT A
PA_0100 File No.: 12-10578 Client Acct No.: 41232874
F®-25-2004 09:46 CHASE BAW SA.210 5865911 P-02
The Chase Manhattan Bank (US ft."
MasterCard
CREDIT AGR9EMENT
Please read this Agreement carefully It contains this , ? {
and terms that govem your Account, including the,
member" fee of $20 and a monddy. periodic rate ..
(nominal ANNUAL PERCENTAGE RATE 198VA,a?
tells you what to do if you no longer NO the Ate....
rrw '
•
INDEX
Definitions .................................. Use Of Your MasterCard Account .... ......... .
Authorizations .........., .................
Obligations On Your MasterCard Account .......... '
Your Credit line ........................... . 1
Periodic Statement ...................... . ..... 3
3
Payments On Your Account ......................
The Minimum Monthly Payment .................. 4•
Application of Payments ........... . . ......... ... 5
Credit Balances and Overpayments ........... ... . .
Fnance Charges ............................... 5
Other Charges ................................. 7
Default ....... -.--..-. ---....----••- . -• 2
Cogecoon Costs And Aftomey's Fees ............... 4•
Amendments To This Agreement ..................:a
Cancellation -.........., ..,...... ..............0
No Security Interest ............ . ......... , ..S.
Credit Reporting ... ... ................, ... .8
Notices And Change Of Your Address ............. . 0
When This Agreement Becomes Effective .......:.0
Delayed Enforcement ....... ....... . ........ , ..
Severability ........... ... .............. .... V
Law That Applies ...... .......................1O
Inquiries Or Ouestions .......... .......... - 10
Your Liability For Unauthorized Use Of Your Card'... 11
F®-25-2004 0946 CHASE HANG SA.210 5865911 P.03
1
' Dafinitloas.-ln*this Agreement, the words "*Uand "your" mean any pawn (if more than one;olw '
vidually and jointly) who is-4e nsible for
NI~asterl ard'AccdUk. " Vkk' itus;' and "our" reW,
'
The Chase Manhattan Bank (USA), National Assgdl*-I;.
tion. "Card" refers to the MasterCard Credit
which we issue to you. "Account" refers to..yopp,
MasterCard Account with us_ "
Use Of Your MasterCwrd Aocount. We. r ,
sent you the,MasterCard Card(s) you asked for.,Ym&
agree to sign It promptly upon receipt. You u"
the Card to lease or purchase goods and =o
services on credit frofn any person who a0cep*1Card ("Purchase(s)"), and to obtain loans ("Cash /W
vance(s)") from us or from anyone who win aqt*
the Card. In additbn to the Card, we may Issue Cpaaet'
MasterChecking checks ("Chock(s)") to you
may also be used to obtain Cash Advances. Vri?aa:-not promise that everyone will honor the C&d :0.
Checks, and we have no obligation to you if
refuses to accept either of them. We will not be
«
if any merchant, any bank or other person doe* no(';
honor your Card, Check, or other form of reque*.I*;,
a Purchase or Cash Advance, or fails to provid*
service made available to you by us. From time toiittl
you may be required to furnish identification wW.,'
your Card is presented for use.
Obtaining Credit Without a Card. If-)0U of.,
someone you authorize to use your Account si•d; .
sales slip, obtains a Cash Advance, or gives yogr Aa '
count number to make a Purchase or obtain a.r
Advance without presenting the Card (such ae; ' A,
mail order or a telephone pur+cttase), or if youislfi?a
a Check, the legal effect will be the same as i tbv'
Card itself was used by you.
Use of Chase Masteriftecking Chrplm
Each Check contains your MasterCard AdgpWt
number and may be used only by the person(s) y ,
name(s) is printed on it. Each must be compleftard,.
signed in the same way as a regular personal Aec
A Cash Advance is considered to be made arrd t
funds received by you on the date we pay the Cosgk:'
You may not use a Check to pay any amounts ybu
.1
FEB-25-2004 09:47 CHPSE BANG SA.210 5865911 P.04
;a
I
owe under this Agreement,
We do not have to certify ar)y Check and
not otat+ad to pay a- Cheat that is Post-W: '
Chkks paid by us will not be returned to you••
your periodic statement, but will be idekifl9d o it: •
Credits for Refunds. If you obtain
justment or credit for a Purchase made with thefind,
you will recelvve a credit to your bunt, not
cowd-
Owner"* of Comb And Checks. The
Card(s) and Ohecks that we gW you remain our pspp..
MV. We have the right to repoesm them at any.',
Ybu agree to surrender them at our request.
Aathorisations. Purchases above ce"*a,
amounts and all Cash Advances require our prior,W.
proval. Our prior approval may be required in ; '
circumstances a$ well. These approvals are "authorizations." ft may limit the number oraucaW?
ilor•
izations we will give your Account on any one,
At times when our authorisation system is not Jul
working, we may not be able to give our approv W ,far•
some transactions even though they would not n?
your credit limit. These restrictions are for so"*,.,
.
reasons. For these security reawns we cannot art irr';
the details of how our authorizftn system works,.,)bgl:
agree that neither we nor our authorization agent do''
be liable for not giving an authorization.
Obliletlons on Y ur• M Gerd Acea?wt,?,;
*u authorize us to pay and charge your Acc ou*llw-,
all Purchases and Cash Advarsm resulting frolittitf•'
use of the Card, Checks or your Account. You •'
to pay us for all of these Purchases and Cash;
vacce& You also agree to pay us the fi=an ce
than are assessed on your Acwunt, any `
amounts that you may owe us, according to the Mt" ,
of this Agreement. Each person who signed t*•So.
piication to open an Account with us or ot,
agrees is obligated to pay the full amount owed •on .
it. We may require that you pay the full amount w0l opt,'
our first asking the other petso
ro) to pay.
We are not obligated to aufrize avansactio i
ing your Card or your Account or to pay a Clte*
(1) Your credit line or Cash Access line has
exceeded or would be exceeded by the transa+c&M;,
FEB-25-2004 09:47 CHASE BANK SA.210 5865911 P.05
i
(2) you have fgiied to pay amounts cywed to us
due or have failed to follow any of the terms
Agreement; (3) you have notified in or we haw `
Mined that-the Card or your Check have or .. ;
been lost or stolen, • or that there may bq u
ized access to your Account; or (4) you erg inn .
or your dghxs under this Agreement have exorgd; tai
been revoked. '
Your Craft lane. Your credit line is shown aq t
folder contaiping your Card and on each mai*'•
periodic statement. The total C#M AidV9 nos- ?.•
dancing on your Account at ary one time *No- .
exce" 5500.00 (VW "Cash.AeeeN" fine)
amount available In your creft line, wrhictoot,14 - -
IN& You agree not to make any Purchases or to.o
tain any Cash Advances that would males the
balance of your Account eneed these limits.
do. we may demand that you pay the excess ad yoga'
agree to pay it immediately. You also agree-d-- -
may change or cancel your credit line andlbr..
Access line at any time without prior notice an4lA _ •
out affecting your obligation to pay amounts tWd y" .
owe under this Agreement. Any such change or,.•aain,
collation may result from our periodic review d ft
performance on your Account andkw consumer
reports we may obtain from consumer reporting
ties (credit bureaus).
Pededla StateaotiL INr will send ym.;
periodic statement for each monthly Ding cycle
there is any debit or credit balance of more than; .
or when a finance charge has been imp '
agree to notify us if you do not receive any piii?
statement.
ftYlnonts On lfkwr Aeooa nL AN pay ,,.1
must be made by check or money order deliva md,tar'
mailed to us at the address In Delaware it tm,
your periodic statement. Any such payment nwbai,
returned without applying it to your Account f0. reason including, if the check or money order - {?'.
not drawn on the LLS. Post Office or a flnarnotsk•
tution located in the United Shaw; (2) missing s;
nature; (3) drawn with different numeric and voMn.
amounts; (4) made payable to other than "C"*M .
FEB-25-2004 09:4? CHASE BANG SR. 210 5865911 P.06
MasterCard postdated: or (6) not payable ruts ltd;'
dollars.
We can a '
crept ate or al PaYmi•; ,,-
payments that are rmariked-with .mStrkMW
Monts such as "
• ' payment to foil", without to ;
of our rights,
The WnImum Monthiv I nwrn#, You.
pay us the'total amount you owe or a
at any time, provided that you pay us the minigre.
monthly periodic payment that we require by thR•l i.
meat Due Date on your periodic st
month. On your periodic stmwy*.&, we refer
minimum monthly p6riodia payment due as `?11t,
mum Due This Billing'
Your required minimum monthly periodic paONrtt.,:
is the total of:
(1) 1/40 (disregarding cents) Of your PurchaseJ141w,.
Balance, but:
(a) if there have been no new Purchases or••••,
Advances charged to your Account for 24 m'
consecutive months, this part of your m '
monthly periodic payment will be fl>wd for'
statements at 1140 (disregarding cents) of they p*
chases New Balance shown on the statement tw VW,
24th month of inactivity, or
(b) if your Account is dosed by us and them ,
been no new Purchases or Cash Advances
to your Account, this pad-of your minimum
Periodic payment will be fnoed Tor future state
at the last calculated amount.
This part of your minimum monthly pwiodl6pay:•
ment will be at least $10.0 if the applicable
tion is INS than SIM or your entire purchaeej.
Balance if that amount is lass than $10A0, p
(2) 1/40 (dia Warding canto) of the amount d tfaf
Cash Advances New Balance shown on your wo
Sntternent which shows a new Caah Advance or ft
debit to your Cash Advance balance, but at •bW.
$14:00 if this calculation is lace than $10.M Orr
?x
entire Cash Advances New Balance if that ar"".
is less than $1000, plus,
(3) any past due amount.
At our option, we may include any amount in
(4)
FEB-25-2004 0948
CHASE BAW SR. 210 5865911 p,07
of your creditfine as part of the "Minimum Due.:
Billing'
If the' ' '
• mrrnmum monthly periodic payment as C'
lgted above is 1ee84han S1
_ a00 and your annual -,., .
bership fee has been billed to your Account is;
outstanding, your required minimum m thly pew,;
payment is ,10.00, or the total amount owed on pw'
Account if that total is less than 610.00. As prOr.
for in other sections of this Agreement, in certalrW.,
abOns we may require that you pay more VWNR ft,
minimum monthly periodic peyMent described irtft;
section.
AWIleatlon of Pri?ane s. The amount c*aW
payment on your Account win be arpplied in the f ft- '
Ing order: the annual membe ahip fee, the minis;
monthly periodic payment for Cash AdvanM,
viously billed, the entire baaWm of p
previously billed, the remaining bakMe of Calf A&'
vances previously billed, new Cash Advances 4M' .•
new Purchases.
CrrOM li homes and OvwM wnbL if ie:
is a credit balance on your Account or you msfef.ep,
overpayment which creates a credit balance, wen w1W,
apply it to future amounts owed. If you aak, w*r •'
refund any credit balance owed to you. Even
do not ask, if a credit balance greater than $1d?D';ig:•
mains in your Account for .0 montlts, we will at- .
ically send you the credit balance outstanding atw11#>wrtr ;,
time. VVfe may charge to your Account and you
to pay us for any credit balance(s) that is
to you in error.
Elnanen Charges. Finance Charges on yowl-,
count will be determined by applying a WkdC ,ra1t,:,
to an avenge daily bvjance and agsm@shg transiVN*,
fees. The circumstances under which these w1g be,
assessed and an explanation of how they are defer.
mined are described below
mere Charges De?tanmkiied by porww,
. Recto.
Purehas?es. We determine a portion of.' Imo;
finance charge to your Account by applying a p
rate described below to the "Purchase average, t
balance' of your Account, an arnount that will In*Ws.,
FEB-25-2004 09:48
CHASE BANG SA.210 5865911
P.08
1
. r.
current transactibris. Tb get the "Purchase at
daily balance;' we take the beginning P=91111
ante of your .Account each day, add any now.,,.
6h8ses or debits; and subtract any payme cr,
credits. This gives us the Purchase dally bal?
Then, we add' up all the Purchase daily baianoie for.,
the billing cycle and divide the total by the ntapbeirl;
of days in the billing cycle. This gives us the V*-r
chasd average daily balance".
Cash Am' - a i ote . We determine a portion oft .: ,
finance charge on your Account by applying a e
odic rate described below to the "Cash Admjjn W;,; .
average daily balance" of your Account. To gel the,
"Cash Advance average daily balance," we taus ths,*;
beginning Cash Advance balance of your Amt"
each day, add any new Cash Advances or deb 11'8gfl,•.
subtract any payments or credits. This gives
Cash Advance dally balance. Then, we add up t!N`
Cash Advance daily balances for the billing Cy*"
divide the total by the number of days in the O@bW.,
cycle. This gives us the "Cash Advance averaga ,
balance".
The "Purchase average daily balance" is muft%*W ,
by the monthly periodic rate of J Ag% {the nowt ,
ANNUAL PERCENTAGE IRM is 1 V
If that result is less than SOe, a minimum FIN .
CNARBE of 8 ft is imposed,
the "Cash Advance average dally balanoei" tt;
multiplied by the monthly pedodic.raw of 1
nominal ANNUAL PE1RCjWTIh®E- RA Is'.'
The results of these two calculations are fir,.,
added together to compute this portion of the finanpe',
charge.
There is no Purchases Finance Charge 1W ,.W,
monthly billing cycle if the Purchases New 8ale,;
is paid and credited in full by the and of that b}
cycle, or If the Purchases previous, balance is *et.M
If neither of these conditions apply, Finance Char:
are imposed on Purchases from the day they; onI
posted to your Account.
Finance Charges are imposed on Cash Adva %m:
from the day they are posted to your Account until,ppl,
FEB-25-2004 09:4B CHRSE BANK SA.210 5865911 P.09
r'
• I y
ment in full is received, ;
Finance Charles Domed Sy A ;
action Rae. You will be d and agreed
us a transaction fee F'M1 U CM&pAg
the amount of each Cash Advance that you
However, we will charge for this fee not less 1100.0
nor more than $10.00 for each Cash Advarn*
This Agreement provides for the compotwjW .
Finance Charges (interest).
"Other
Annual ?
when bred each You agrNS lc? ?
yam' rxxwftndabie annUij
bership fee of MM for your participaWna n;
Agreement. You agree to pay this fee wig or •
you use the Account at any tune during dw yM.
Sys $ft or ?lu_Www e s to nant a .' '
part because we are charged by other
agree to pay us 55,00 for each ??'
slip and X0.00 for each orow ? of ? ,
from us. You also agree to sales slip 14
duplicate monthly statement yo s
uu r se
if a request for sales slips or dupats ' .
•,
reveals a billing error as defined by the
Reserve Board's Regulation Z, vm will not i
will credit your Account for the salsa slip or nd
statement fees. Any amounts you owe us
added to your Account and treated
as a P
Late Pa"Ment OW6
For any
monthly Periodic ?`•
Payment which is not pa,bV.
Payment Due Date shown on your periodic
YOU may be charged, and you, agree to pay 40.
payment charges as follows- $5 for any SNO
payment, $10 for any h ft payer where anotper,pa
ment remains unpaid, and $15 for any late
where two or more other payments remain
Any late payment charge you owe us will be xkWO
to your Account and treated as a Purchase, ll
be charged only one late payment charge liar
MON.
minimum monthly periodic payrnent which is net pod,,
by its Payment Due Date.
CnxNt Mwrano4L If you we offered credit;iryW.
ance in connection with your Account, ar4d •yp?
choose to purchase it through us, you autho*e ups
?T
FEB-25-2004 09=49 CHASE BANG SA.210 5865911 P.10
• to.bili you its cost each month on
your period
ifiR.st??';
Mont and you agree to pay for it.
Returned Payment tbs. If your b".'*
;
not honor the check you gavae us to pay amp ;
owe under this Agreement, or % must MUM It .46"
you because it is not signed, you agree to ply,
fee of SE00. Any amounts you em us will be,acfdard
to your Account and treated as a Purchase.
state Es mptlous. The Sales Slip or Dypii ,
Statement Fees, Late
Payment Char+gsa, said : ?. •
turned Paynrentha? do not eppiyy and Wilt
imposed your Wing address is in Cowador•
Indiana, Iowa, Kan" WMW MhMMOUk
South Carolina, Utah, West Vionia, Wlscorµl '
Wyoming, unless the law of any of these sob.
changed to permit such charges,
DWMU. lrbur Account will be. in debutit
can requirethat the URI ouNilanding balance 4b
(this is known as the-right of UNNI) !Pl}.
ei 9W the credit limit in effect on your Act
you fail to pay any amount owed under this y,j•
Mont when due: or (3) your am
'NY to pay., us '14.
materially Impaired (including. but not limll0d t
bankruptcy or insolvency proceedings that a? in •
aced by or against you). V* do not have to nol la?u=
Of demand payment in order to We this anion,'
applicable law requires that we give you a nonce, Of,
S. right to cure your debuft.
t,.oReeertlon Costs And A ores P160W 4
Permitted by applicable law, you agree to pay arcs ,
and other collection costs acdrelly incurred bye, u *1
the collection of any amounts you owe to unVtl_
Agreement. In the event we color your Accour#t APr
it is in default to an attorney who is not our
employee to collect such amounts, to the "to* per-
mitted by applcable taw, you agree to pay 3s
fees of 20% of the amount you owe us, a I?r
if it is reasonable, or such other amount as mq, &I,
permitted by a court or agreed to by you and, UL-
ft 7b This Awes nMnt. 1I1*404
amend any of the twma of Vft A enrent ,
VMS, and vMe can set the elircrttve ?Lv
such amsrrdrnertt. We will note/ you by nudl a" t. ,
FEB-25-2004 09:49
r
CHASE BANK SA.210 5865911 P.11
+i
ng u?
acdtona on your Amount. Any chattgarwhich.
Increase the rate of Finance C twg% other:
or Impose.a fee not set forth In'this Ag ?
be effective only If you agree to It. Wfe can
your consent to any such arnerximerrt in One. e4:
two ways, 4* sekwW by us and disclosed
with the notice of change of terns. Undyt,,wW
method, you consent to the
we give notice of the cheng% you sit to
Account afar the effective daa of the r `
or 2) you ague In writing to the charge Ll
. rr.
other mediod, you conssnt to the •rnertdrw
1) within 30 days after via mail you noftnoll;
change, you do not give us written rota
ing the change at the addmes we
you use your Account afar 30 slays from
we mail you notice of the charge,
whether you 0iw us notice re?scting the
Canoeffation. Va can at any time
notice cancel your privNeges under this I wpm
(and we can list your Card In warning bulletirl?),
will notify you of a cancellation. Ybu agree th'bt
will not try to make any Purchase or obtain ant(: CZ
Advance sitar you have bash notified that yots pig-
loge to use the Card or Checks has been cap.
You may cancel your Account at any time by," I
ing us and cutting all Cards issued on your A?,c
in half. You will remain liable for any charge
.to your Account (by you, a joint accountL
-
or anyone to whom y have lent, given or
a Card on your A?ocount) prior to your cutting In half and notifying us of the cancellation. Fbr
cancellation of your Account, we can require return to us all Cards issued on your AccousIL
No geourity lntwm& For your Acco .. ,tie
specifically waive any security -interest in your.
arty that we may have under any other a
with you.
. Crrdlt I?porttnp. You agree that a ccoupim
credit report may be requested periodically ft m am
such amendment as required by law. The
terms of this Agreement car apply to ail
fi !d = tndebtedrress ?d ft?t+e
FEB-25-2004 09:50
.i
CHPSE BANG SA.210 5865911
P.12
? .r
or more consumm reporting agencies (credit
and used in connection with your app: ,
update, renewal or extension of credit on ;
count: If you; request:. _ywx will be informed
any consumer report
was regtreeted and, if ac?
name and. address of the consumer reporq '
oy that furnished the report. You agree that "
exchange credit information about you with k•t
connection with your apptic4tion, your Aocoght. AM,
any credit. we extend to you.
Notlees And Chan" Of Vmr *"' m:
can send statements and any other -#
the address showrefor you In our files, if this iea j*
Account, we can send staummmts and nvpCgAl;s;
qyuc ,
either of you. You promise to hft n us=114*
any changes in your address. ybu may the address hated below.
When TM* Awseme NaRoweMS'1 ;.',
r
is Aoreement becomes effective upon our epp
In Delaware of your Account.
Dellinped 8 GoItst We can detay sii?ilp
our rights under this Agreement without toe of them.
Seweretellitx The invalidity of any provision
Agreement shall not affect the validity of any: provision.
Low That AppRea The laws of the :,
States of America and the State of
ply to this Agreement end to yaw use of yore,,
your Checim, and your Account.
Inpulrles Or Quoatlons. You may e?ddrgj
billing errors, inquiries or questions which yew
about your Account to:
The Chase Manhattan Bank (USA), Natlohai•,
Association
MasterCard
P.O. Box 15093
WlWngton DE 1985 -SM
or, you may call us at (302) e66.M&
If you telephone us instead of write
certain rights the law ng, YOU 'lose
gives -you to dispute jtfl liag
errors.
FEH-25-2004 0950 CHASE BANK SA.210 5865911 P.13
r' lfbwrWb f or 1lew11q d U"U'
,.
Cwrd. You may be liable for the unauthorised', ,#:
your Card. You w not
urewtho ,
that dabut y+oa notlty
Bank, National Asaociadan, by wry fi
Avenue, DG*. 5111, (3arden City, New York 11M' ` lr;
orally by calling us toll free at 14W-M ,
loess, theft, or pole unauthorized use of you?;?
In any case, yaw Ilabltity for u use rf ,rs ,,
a
exceed Mm You agree the anyone who is.
Card for your Account (or anyone to whom y •;
Met
or give your Card) is authorized to make to
your Account to the Imm exw% as you and Mao
authority cannot be limited by you. Such
continuo until you revoke it by'"Jurrn9 us,
the Card in your physical poese?eiun, and it- M'{d,
Card issued to an authorized user, by also' c7rt
in half.
THE CHASE MANNAFTTAN BANK''
NATIONAL ASSO ..
I
0M1(L) 10488 pEY 1.0
TOTAL P.13
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff w
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OFF1uE dF THE SHERIFF
Asset Acceptance LLC
vs. Case Number
Kerry F. Crum 2012-3695
SHERIFF'S RETURN OF SERVICE
06/19/2012 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: Kerry F. Crum, but was unable to locate him in his
bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kerry F.
Crum. Request for service at 717 Market Street, Apartment 305, Lemoyne, Pennsylvania 17043 is a UPS
Store.
SHERIFF COST: $49.00 SO ANSWERS,
June 19, 2012 RON R ANDERSON, SHERIFF
f0 CountySuite Sheriff, T'eleosoft. Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
ASSET ACCEPTANCE,LLC No: 12-3695-CIVIL
Plaintiff
vs. CIVIL ACTION- LAW
KERRY F CRUM
Defendant(s) 4;,
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Please mark the above captioned action as discontinued w'th r ejudice. cn --.
Respectfully b � ..-d,
MICHAEL OLK#88553
RACHEL A. CLARK#311484
FULTON,FRIEDMAN&GULLACE,LLP
6 KACEY COURT SUI'11 203
MECHANICSBURG,PA 17055
(877) 386-5383
Attorneys for Plaintiff
PA 0303 File No 12-10578