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Home My WebLink About12-7660~+ ~.W ~ arr 1u~~~~,C21 ~r~~~~~~' C~tt~~~~AND CCUNT'Y ~~~~$ YIVA~lA BARLEYSNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299-5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff v. LINDSEY B. SGRIGNOLI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ACTIO(N~IN REPLEVIN No. ~d - ~ ~ ~~ ~ NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice to you for any money claimed in the Complaint or for any other claim or relief requested by Plaintiff(s). You may lose money or property or other rights important to you. 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 LAWYE~B ~~`~~,~Sx~ a I 3767073 Q~ ~ 3 a ~y g Ck'~ R~rs a~ ~~. a 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 Effective September 1, 2003 3767073 BARLEYSNYDER 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. LINDSEY B. SGRIGNOLI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ACTION IN REPLEVIN No. AVISO PARR 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 despues 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 relevacion pedida por Plaintiff(s). Usted puede perder el dinero o la caracteristica u otra endereza importante a usted. 3767073 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 NINGIJN HONORARIO. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 Efectivo 1 de Septiembre, 2003 Queja 3767073 BARLEYSNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintif v. LINDSEY B. SGRIGNOLI, Attorneys for Plaintiff Pennsylvania State Employees Credit Union IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ACTION IN REPLEVIN No. ~~ - 7G 6d ~ ~, I ~-~~~ Defendant COMPLAINT 1. Plaintiff, Pennsylvania State Employees Credit Union ("PSECU"), is a Pennsylvania financial institution having an office at One Credit Union Place, Harrisburg, Pennsylvania 17110. 2. Defendant, Lindsey B. Sgrignoli, is an adult individual with a last known address of 6822 Wertzville Road, Enola, PA 17025-1032. 3. On or about June 23, 2011, Defendant entered into a Motor Vehicle Installment Contract (the "Contract") with Plaintiff for the purchase of a 2003 Lincoln Navigator, VIN 3767073 #SLMFU28R23LJ43301 (the "Vehicle"). A true and correct copy of the Contract is attached hereto as Exhibit "A" and incorporated herein by reference. 4. Plaintiff s perfected security interest in the Vehicle is evidenced by a State 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 as if fully set forth. 5. Defendant defaulted under the Contract by failing to make monthly payments when due beginning May 30, 2012 and on the twenty-third (23rd) day of each month thereafter. 6. Pursuant to the Contract, in the event of default, Plaintiff may and did make the entire balance and other agreed charges owed by Defendant immediately due and demanded such sum by letter dated November 1, 2012 (the "Demand Letter"), a true and correct copy of which is attached hereto as Exhibit "C" and incorporated herein by reference as if fully set forth. 7. In the Demand Letter, Plaintiff provided Defendant with the option to either pay all amounts due and owing to Plaintiff or surrender possession of the Vehicle to Plaintiff's designated repossession agent. See Exhibit "C." COUNT I -ACTION IN REPLEVIN 8. Paragraphs 1 through 7 above are incorporated herein by reference. 9. As a result of Defendant's default under the Contract, Plaintiff is entitled to immediate possession of the Vehicle. 10. The present fair market wholesale value of the Vehicle is approximately $7,100.00. 11. Upon information and belief, the Defendant has possession and control of the Vehicle at 6822 Wertzville Road, Enola, PA 17025-1032. 3767073 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, demands judgment in replevin against Defendant, Lindsey B. Sgrignoli, for possession of the Vehicle, plus costs, special damages thereon in the amount to be determined, attorneys' fees, and such other relief as this Court deems just. COUNT II -BREACH OF CONTRACT 12. Paragraphs 1 through 11 above are incorporated herein by reference. 13. Defendant remains liable to Plaintiff under the Contract in the amount of $19,364.74. 14. PSECU has demanded payment from Defendant, but despite these demands, the Defendant has refused and continues to refuse to make payments. 15. 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. 3767073 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment in its favor and against Defendant, Lindsey B. Sgrignoli, in the amount of $19,364.74, and costs of suit. BARLEY By: S~ha,~m b~ Long, Esc~ire urt LD. 83774 / 126 East King Street Lancaster, PA 17602-2893 717.299.5201 Attorneys for Plaintiff 3767073 EXHIBIT "A 3767073 IF DEBT CANCELLATION IS SOLD, A SEPARATE DISCLOSURE AND AGREEMENT FOR DEBT CANCELLATION MUST ACCOMPANY THIS CONTRACT. NnHneytixtAt cL~E IiISTALtMEIYT STALE CONTRACT, Dated 6/23/2011 SIMPLE INTEREST ANNUAL FINANCE PERCENTAGE RATE CHARGE The cast of your credit as The dollar amount the a yearly rate. credit wit cost you. 7.24 %~ $ 4,970.91 Amount Financed The amount of credit provided to you or on your behalf. i 21,077.25 Total of Payments The amew-t you will have paid after you have made all scheduled payments. 3 26,048.16 Total Saie Price The total cost of your purchase on credit, includkrg your downpayment of ~ N/A S 26,048.16 ..,,...w.. _.....~ Na of Payments ~ .... pnronot of Paynreats Yfhen Payments Are Due 72 S 961.?O Monthiy,be¢inning x/23/2011 S Security: You are giving a security interest in the motor vehicle being purchased. Prepayment: If you pay ofi early, you wilt not have to pay a penalty. Filing Feer. S ~ - u ~ fate Charge: If a payment is fate, you will he charged 296 of the portion of the payment which is late far each month, er part of a month greater than 10 days, that it remains unpaid. See bebw and any other Oontract documents For any addifiona( information about nonpayment, defauR, any required repayment in full before the scheduled date and prepayment ret~ds ~ p~~ a means estimate IF YOU DO NOT MEET YOUR CON7tiACt In this Contract KEIM p~_Oy,~II OBUOATIONS, YOU MAY LASE THE MOTOR we are YEHIGLE AND PROPERTY THAT YOU the SELLER. 1910 Maahe:im Pike Laaeaeite:r P3i 3.7601 BOUGHT WITH THIS CONTRACT, AND/OR Name Addrrss Zip Code MONEY ON DEPOSITVtq'HTHEASSIGNEE. County This Conirads between Soler and Buyer. AG d~OSUres have bemt made by Seller. Soler You are LIIIIDSEY BROOISE 3t~tI6N~QLI y .6B22 WERT9VIbLE RD. EN6T~1! Pb~ 17025 intendstoass~rthisCordradtotireAsstgnee. the BUYER(S). - - Itetni action of Amount Financed Name(s) Address{es} Zip Code(s) Cnch 7'rneteAinrr eMteu~a sT- County contractand/or warrardies in the e a m au rt ~ N If there h more than one Buyer, each promises, separetely and together, to pay all sums due us and to perform ~ agreemerds in this Contract pa d th NONE TRADE-IN: &salestaxof>; 5945.75 -: You have traded in 2000 Cadillac: DEVILLE ' SN 1G61?;D;i4Y8YT]201289 the foftawing vehicle: Cash Price Year and Make Description S Cash Donpaayment If a balance is still rnrKrg on the vehicle you have traded in, the Seger will pay o(f thk amount on ymrr behalf You warrant and represent to us that " $ any trade-in is tree from lien, claim, eru:uarbramx ar secudty interest, extxpt as shown k~ the'Ite~aiion of Anwurrt Fnarrced" as the "Lisa Payoff. Trado-In PROPERTY INSURANCE: You may choose the peraon•throuGlr whom insurance is obtMn~ against loss or damage to the Vehicle and against Value of Trade-in fiabi'ity sriskg out of use m ownership of the Yehhde. In this Corrhact, yea are pranising b insure the Vehicle and keep it irrsured DEBT CANCELLATION (GUARANTEED AUTO PROTECTION) AGREEMENT IS VOLUNTARY AND NOT REQUIRED AS A CONDITION OF THE $ 4 , 232 _ 5i CREDIT. This agreement wiN not be provMed unless you srgn below, agree to pay dte additianef charge, and ~gn the separate dlsd~rxe and Lien Payoff to: __ agreement page, which fs part of this Contract This agreemart wiM apply during the erdire term of the Contract. This a~nerd may not cover 3 - yorrr entire hrdebtedr~ see the MAXIMUM PROTECTIO N amount statedm the separete disdosure and agreement. Unpaid Cash Price Balance Type of Debt Cancellation Agreement Charge ~ ~ Guaranteed auto prot~tion {GAP} $ N/A BY ~gnM& you select guarardeed sofa protection Optional Dent CancMlation {GAP} Signature of Buyer IDacument SERVICE CONTRACT OR tMARRANTY AGREt7AEN1- IS YDLUNTARY ANU NU1 rtetfurxr:rr AS a wrnurrtun ur rnn crctuu. ins serva:e canuaci or warranty agremrent wM not be provided unless you sign the separate agreement with the Ehird party provider, who is not the Seller named p; rn Fee 03. above, and agree to pay the additrorral charge. This section does not apply to any warranty that you may reserve for whrch there is nM separate To Pubic OfRcials for: charge. Ucense, Tags and Registration CREDIT INSURANCE IS -NOT REQUIRED: CredR Life insurance and Credit Accident & Health {Ofsabilty) Insurance are not required to obtain $ 28.50 crerhT, and wit not be provided urrless you sign below and agree to pay the eddianal cost(s). Please read the NOTICE OF PROPOSED CREDIT INSURANCE on the reverse side. Your insurance certificate or poky vril tel you the MAXIMUM amourd of inswance available. AR insurance lien fee purchased wrTl be for the term of the credit We may receive a financial benefit from your purchase of credit insurance. g By signing, you select Single Crerjit Life Insurance, What is your By signing, you select Single CredR Acchfent & What is your Taxes Not Included in Cash Price which costs b i ~13y, aget Years Health Insurance, which costs S ,_ age? . Years -: S Ta Signature of Royer to be insured tar Single Credit life Insurance I Signature of Buyer to be insured forSingle Cm.~tAccident & Health Irrsurance By siWring, you bosh select Joint - Creditlife Insurance, which costs; N/A 1, What are ` ~ sgnprg, ~ ~ ~~ Credd What are Percentage youiagest I ~~~&Heakhlnsur_ance,whichcostss 1~7/A youragcs? to be ' insured -- `7' ~ N/A For Messenger Service S N/A signature ul ouyer w ue ursureu wr aulgle aBmr ore msuran~' ~ - By sigaing,youboth select Joint What are Credit Life Insurance, which costs $ N'/A/A your eges~ 2. Signatures of both Buyers to he insured for Joint Credit uTe Insurance OIa11G{Yle VI WIrW W YISaNU1eU IVI OIIfa1C 1rIg111MWiUp110t f1e01U' Illl:e Bysig:gng,youbotltxlectJantCredit Whatare Percentage ror Accident & Health Insurance, which costs $.~~, y~„r egg? to be To • insured i. 96 For N/A Service N!A To Credit insurance Company z. _~ $ N/A Signatures of both Buyers to be insured for kint For CredR Aceident & HeaRh Insurance VEHICLE: You here agreed to purchase, under the terms of this Contract, the following motor vehicle and its extra equipment, which is called the'Vehicle' in this Contract To _ $ for !9L!! Y&aIIR~IJIIRk& $sile~s ~dY;:tY1@ I1.4.~ I[ll&kT~.~f ;~INitt>i~.[ $ _ USED 2003 LINCQLI`J NAdTGii'I'QR JW 5LMFU28R83LJ43301 For Equipped ._ A.T. -. P:S. . AM-FM Stereo _ 5 Spd. Other with _ A.C. _ P.W. _ AM•FM Tape _ Vinyl Tap _ _ ____ ASSIGWEE: We may assign this Conhail and Security Agreement to a sales finance company which is the "Assigcee.' If the Assignee assigns the Contrail to a subsequent assignee, the term also refers to such subsequent assignee. After the assignment, all rights and b~atits of the Seller in thLs Contract and in the Security Agreement shall bebng to and be enforceable by the Assignee. The Assignee w~ notify you when and if Seller makes an assignment. N/A N!A * N/A ~ N/A `' r',~ (7~V' V ~. for - .t~/ To CO-SIGNER: Any pennon signing the Co-Simmer's Agreement 6etow promises separately and together with ail Ca-Signeris) and Buyer(s}, to pay $ N/A * aW sums due and to perform aU agreements in this Contract. Co-Signer will not he an Owner of the Yebicte. For CO-OWNER: Any person signing the Co-Owner's Security Agreemeil below gives us a security interest in the Vehicle and agrees separatily and Amount Financed Pmn ise to Pay'section.~) and Buyer(s), to perform all agreements in the Security Agreement and ab otiter parts of this. Contract except the $ 21 077.26 TERMS: 7ha terms shown in the boxes above are part of this Contract. We may retain a portion of aunts marked' PROMISE i0 PAY: Vat agree b pay. as the Tall Sale Price for the Yeiucle by making the Cash DownpaymeM and assignkrg the Trade•In, if shown above, on er before the date il ttas Contract, and dying ~ the AmourttFnanced phis interest You promise to make payments in accordance with the Payment Schelde. You promise to make payments on or before the same day of each month as the fast payment drre date. You to pay alt other amaurrts which may become due under the lenas of this Contract Yar agree to pay the Sager or Assignee t~s1s of suit You a}so agree to pay reasatabie attorneys' (ees if Salter or Assignee hires an attorney to cdkct amounts due order ti~ Contract or to protect or get possession of the Vide. You agree to make payments at the place or to send paymards to the address wh~h ibe Assrgrtea most recentiy ~dres in the wrRben notax ~ you. the Annual Percerlfage Rafe may be negotiable with fhe Seller. ADDITIONAL DISCLOSURES, TERMS AND CONDITIONS: The Seller may assign this contract and retain its right to Buyeosares: Before signing this Contract, be sure that you receive and read the Disclasuro fa receive a part of the Frnance Charge, Terms and Conditions: Before signing this Contract, be sure you receive and read the fetiowing, if marked X, which are addfional pages to and part of this Contract ®This Contract continues ar the reverse side. ^ Debt Cancellation (guaranteed auto protection) separate disclosure and agreemenk By signing below, we agree to sell the Vehicle to you under the terms of this Contract. SELLER BY: NOTICE TO BUYER-DO NOT SIGN THIS CONTRACT IN BLANK. YOU ARE ENTITLED TO AN EXACT COPY OF THE CONTRACT YOU SIGN. KEEP IT TO PROTECT YOUR LEGAL RIGHTS. BUYE ~ ~ r D~ ah BUYER Date COy^IGNER: U SHOULD R$AD THE NOTICE TO COSIGNER, WHICH FIAS BEEN GIVEN TO YOU ON A SEPARATE DOCU;VIENT, BEFORE SIGNING THE O~IGiYERS AGREEMENT. CO-SIGNER'S AGiREEMENT: You, the poraoa (or persona) signing below ea "Co-signer," promise to pay to us a6 sums due on this Contrast and to perform all agreements in this Cot-tract You intend to bo legalty bound by al! the teams of this Contract, separately sail together, with the Buyer. You are making this proadao to tadtrce us to make this Contract with the Buyer, even though we will use the proceeds only for the Buyers benefit. You agree to pay even though we may not have made any prior demand for payment on the Buyer or exerctsed our security interest. You also acknowledge receiving a completed copy of this Contract. Co-Signer's Signature Address Date Co-Signcrk Signature Address Date CO-OWNERS SECURITY AGREEMENT: You, the person signing below as °Co-Owner," together with the Buyer or otherwise being alt of the Owacrs of the Vehicle, give us a security interest is the Vehicle ident~ed above. You agree to ba bound by the terms of the Security Agreement and all other pans of this Contract except the "Premiss To Pay" section. You are giving us the security interest to induce us to make this Contract with the Buyer, and to secure the payment by the Buyer of all sours due on this Contract. You will not be responsible for any deiiciency which might bo due after repossession and sale of the Vehicle. Co-Owner's Signature ~ Address ~ Date BUYER, CO-SIGNER AND CO-OWNER, IF APPLICABLE, ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS CONTRACT AT THE TIME OF SIGNING, INCLUDING THE ADDITIONAL•DISCLOSURES AND PAGES LISTED IN THE SECTION CALIED ADDITiONAI DISCLOSURES, TERM AND CONDITIONS. ADDITIONAL TERMS AND CONDITIONS 1. SECURITY AGREEMENT: To secure the payment of ail sums due and the periorrrmnce of ail required obtigatiora under thh Contract, you grve a security interest in the Vehicle, in aU parts (called 'acc~ons7 attached b the Vehwle at any later time, and in any proceeds of ~ y~;,,~, incksdirtg irattrance proceeds, The Ass~nea may set-off any amounts due and unpaid under tlds Contrail against aay of your money as deft with Assignee. This irmfud~ any Haney width is now or may in the future be deposited with Assignee by you. Assignee may do this without aay prior notice to you. 2. HOW THE TOTAL OF PAYMENTS IS COMPUTED: The Total of Payments is the sum of the Amount Fnancal and the Firuasce Charge. The Finarsce Charge consists solely o{ ]nterest computed daily as the outatand'asg balance of the Amoupt Flnanced. The Rnanoe Charge shown on the front side has been computed on the assumption that we will receive all payments on thilr scheduled duo dates. 3. COMPUTING INTEREST: We wM charge interest on a daily 6esis en the outstanding balanrx subjxt to irsbereat on ~h day of the loan Cann, inclurUng any paiad for which a fate charge is oho imaoaod. Tlnz daffy inEara~t rate is equal to the Annual Percerdage Rate divtded by the numtuv of days in that calendar year. Buyer agreos.that because interest (s calculated an a daily basis, late payments wiA resuU in additional interest (and, if applicable, a late charge}. Early faymerds will result in less interest being charged. Early and/or late paymends wrTl cause the amount of the Ersal payment In change. 4. LATE CHARGE: Buyer agr~s to pay a late charge fa aay payment not made wiUrin 10 days after its fine date. The fate clmrge will im 2'K'per mordh on the unpaid amount o{ the payment We will corssider any part of a month in excess of 10 days to 6e a fuU month. The late charge wRl be due when earned. No late charge wilt be due if the reason that the payment is Cabe is because; other dehult the ersUre outstanding balance on this Contract is due. No late charge wit he due if this only reason that the paymerd h late is because of a late charge asses~d on an earlier payment . 5. APPLICATION OF PAYMENTS: We wiU appty ~yments in the following order of priority: first to inlerest; and then to-late charges, fees, pnneipal and any other amornsts you owe in the order that we choose. &. PREPAYMENT: Vas may prepay, fn full or in part, the amount owed on this Contract at any time wilhoat penally. if you prepay the Contract in part you agree to continue to make regsrtarly sciredulad payments anti you pay aN amarnh due utsder this Contract This will reduce the number of payments you wit make. 7. WAIVERS. a. WAIVER BY SELLER AND ASSIGNEE: We and Assignee waive the right to treat any property as security for the rapeynusnt of this Contract except for the Vehicle era! the other security speeMCally pterdiorsed is tlrh Contrail. b. WAIVERS BY BUYER, CO-STONER AND CO-ONfNER: Yar agr~ to make all payrsu;nts on or helots they are duo withart au having to ask If yea don't we may enforce our rights wittrout notifying yes in advance. You give up any right You may have to require that we enforce err rights apisut snare other person a property before we enforce our rights a~isut you: Yau agree that wo may ghre up our rights against sarrre other person but not against you. You waive due dlfigence in coiection and aN defenses based on suretyship and impairmerd of collaienl a security. 8. INTEREST AFTER MATURITY AND JUDGMENT: Interest at the rate provided in this Contract shag txsrrtinue to accrue on Ure unpaid balarae anti paid in fuN, even agar maturRy and/or after we gat a judMnent agaksst you !or the amounts due. This wii apply evens if the maturity occurs because of acceleration. U at any Ume interest as provided for in this paragraph h not perasRted by law, interest shat accrue at the highest rate allowed by appgcable law begfming at that time. 0. YOUR PROMISES ABOUT OUR SECURITY INTEREST: You vdU. not paring anyone other flan us to obtain a aecurlty interest ~ ilher rights in the Vehida You wUl pay aU fling few rrecassary for us to a6faks and mahitain our security ksterest in the Vehicle. You wit assist us •In.imving air secwRy interest srot~ on the Carh~cate of Title to the Vehicle. You wii not sell or give away the Vehicle. If someone puts a Uen on the Vehicle, you will pay the ohUgatia- and -clear the Uen. • 10. YOUR PROMISES ABOUT THE VEHICLE: You wUl keep the Vehicle in goad condHlen end repair. You wM pay alt texas and charges en the Vehicle. You will pay all costs of maintaining the Vehicle. You wli not abuse the Velacle or permit anything to be done to the Yehide which wiN reduce its value, other than fa normal wear and use. You will not use the Yehicte for illegal purposes or fa hire or (ease. You wii not move the Vehicle from you address shown on the front of this Contract to a new permanent place of garaging without notifying us in advance. 11. YOUR PROMISES ABOUT INSURANCE: You wUl keep the Yehtcie insured against fire, thilt and cill'~ioa until ai sums due us are paid in full. Thor insurance coverage must ha satis(actay to us and protect your interests and our interests at the time of any insured lass. The insurance mast Brame us as 'loss-payee' an the policy. The insurance must be written by an insurance company gmlified to do tnssiness in Pennsylvania and licensed to sell insurance in the state where Use Vehicle is petman~dy gareged. The insurance poicy must provide us with at feast ten (10) days prior written notice of any cancellation or reduction in coverage. On request, you shall deliver the policy or other. evidence of insurance coverage to us. In the event of the Its or damage to the Vehicle, you will immediately notify us in writing and file a proof of loss with the insurer. a. OUR RIGH7 TO FILE PROOF OF LOSS: In the event of any lass or damage to the Vehicle, IF you fail or refuse to fife a dalm or proof of Inca with the insurance company, you .agree that the Seger, Assignee, any Suh~queM assignee, or any authorized employee of any of them ~ } may,fUe a proof of loss with the krsurance company, in your name and acUrsg as your agent wRh respect to Use insured claim. You agree that you do not have the right to, 'and wiU not, revoke the power you have given us to file a proof of bss. You agree that we may 12. OUR R{GHTS IF YOU BREAK YOUR PROMISES ABOUT THE SECURITY INTEREST, VEHICLE OR INSURANCE: If you fai.to keep your ~amises to pay filing fees, taxes, Uens or the costs tw~ssary to keep the Vehsde in good coratthan and repatr, we may advance any money you promised thpay. If-you toff to keep your promises about required irarrraru:e, we may advance money to obtain insurance to carer loss or damage to the Vetdde. Wa have the choice of whether a not to advance any money far these purposes. Such insurance will be limited to an amount not greeter than you owe on this Contract THE INSURANCE WE PURCHASE MAY BE SIGNIFICANTLY MORE EXPENSIVE AND PROVIDE YOU LESS COVERAGE THAN INSURANCE YOU COUtD PURCHASE YOURSELF. We will add aay money we advance on your bef-alf to the balance on which we impose Fnanca Charges at the Annual Percentage Rate of this Contrail. Yau agree to repay the matey advanced as we alone may specify: hj immedittely an demand, or Gl along wRh your .monthly payrnersts. If we choo~ ~ allow you to; repay the matey advanced~rbag wRh your muathty payments, wa can choose Ilia amount of Uusse paymerds and how bng you have to ray. If amt of our rights shted in this paragraph are rwt pan-iited bylaw, we still have the other rgKsts mentioned. Our payments ar your behalf wit not cure your faiure to perform your promises in this Contrail. 13. DEFAULT: !n this paragraph "You" mean the Buyer, Cosigner and Co•Owaer, or any one of them. Yau will be in "[hdault" of the Contract if any one or more of the following itdngs happen: a. You do not make any payment on a before it is due; or b. You do ant keep any promise you made in this Contraci; or c. You do not keep any P~~ Y~ made in another Contract Mote, Loan er Agreement with Seller or Assignee; or d. Vat made any untrue statement in the creditappticallers lerthis Contract; or e. You committed any forgery in conrsectioa with Ekes Coniracr; ar f. You die, ere cemlebed o(a crime invohdng fraud or dishonesty, or are found by a court with jurisdiciian to do sa to be incepaciated; or g. Yau file bankruptcy or insolvency proceedings, or anyone files bankruptcy or insolvency proceadfngs against your or h. You take the Vehicle outside the UnRai States a Canada wiUrout our wrUtas consent or L You use the Vehicle or allew someone else to use it in a way that causes it not to be covered by your insurance; or j. You de something that causes the Vehicle fo be subject to confiscation by govemment authorities; or k The Vehickt h lost stolen, destroged or damaged beyond economical repair, and not fixed a fouaf within a reasonabty lime; or L Another creditor tries la take the Vehicle or your money on deposit with Assigcee by legal process. 14.OUR RIGHTS IF YOU ARE IN DEFAULT OF THIS CONTRACT: if you are in DefauU of this Contrail, wa may ersfarce our rights accor~sg to isw. We may aLm do the Udngs apeaUraUy ntentiarsed in this Contract. We may do one of these things and at the same time or later do another. Some il the things we may do are the followirs~, a. ACCEIERAT~tf: Vfo can demand that you pay to us flee entire unpaid balance owing on the Contrail and ai unpaid finance Charges and o0sar money due. You agree that you twTl pay this mosey to cat in one sirMle paym~t immedratety upon rxeiving our demaltd. h: REPOSSESSION: We can repossess the Vehicle, unless prohibited by law. We can do this ourselves, have a gnatiied person de it for us, or Isave a garemment ofiidal (by replevin) do R for us. You agree that we can peaceaby cilrse ar to your property to do thh. We may take amt other thirWs kurnd in the Vehicle, but wRl return these things to you if you ask If you want ih~ things back, you may reclaim them wRhhin thirty (~) days of our mating you a NoUrm of Repossession. If you ~ not reclaim the things found le the Vehicle wRhin thatt-me, we may dispose of those thkrgs in the same rrvtnner as the tailor vehicle. You agree Usat we may use your icense pletes in rgsassessing the Vehicle and taking U to a place far storage. c. VOLUNTARY DELIVERY: We can ask you to give us the Vehicle at a reasonably converdent place. You agree to give us the Vehicle if we ask d. DELAY IN ENFORCEMENT: We can delay enforcing our rights under this Contract without kssing any rights. 15. SOME THINGS YOU SHOULD KNOW IF WE REPOSSESS THE VEHICLE: If we repossess wittwut using a government ofUclal (by replevin): a. NOTICE: We will send you a Notice of Repossession to your last address we know about This Notice will till you how to buy back (redeem] the Vehicle. You wUl NOT have.the fight to reinstate the Contract This moans you wit have 1o pay the thtaf balance on the Contract and ocher amounts duo. You may not get the Vehicle back by paying delinquent instagments. This Notice will tai you other information required bylaw. b. REDEMPTION: You have the right to buy back (redeem] the Yehtde within 15 days of the mailing of the Notice and of any later 6me before we sell the Vehicle. If ya, redeem the Vehicle, we will deliver the Vehicle to you at a place as provided by law, as soon as is rea~nab{y passible, but in not more than ten (10} business days of our receipt of the funds required. if you do Hat redeem, you give up all claim to the Vehicle. c. SALE: If you don't redeem, we will sell the VrJsicks. The money received at sale will be used to pay costs and expenses you owe, and then to pay the amount you owe on the Contract. d. SURPLUS OR DEFICIENCY: If there is money IeEt, we will pay R to the Buyer. If there is not enough money from the sale to pay what you owe, Buyer and Co•Signer agree to pay wlmt is still seed #o us. e. EXPENSES: You agree to pay the costs of repossessing, storing, repairing, preparing for sate and selling the Vehicle as may t-e ed b w. be e' 1.OefauR exceeds fifteen (15} of 2. The amount of costs are act rY a 3. We can prove the costs war a. uun nimn ,v ~ .L~ ~ nuv~ vi w+.r, w uw crmn ui and waa v~ uomayc w u~o Vehicle, if you faB er refuse to file a claim or proof of ions with the insurance cemparry, you agree that the Seger, Ass~rree, any subsequent assignee, er any suthoraed employee of any of them ('we') may fife a proof of toss with the insurence company, in your name and acting as your agent, with respect to the insured claim. You agree that you do not have the right to, and wilt not, revoke the power you have given us to file a proof of foss. You agree that we may exercise this power for our benefit and not for your benefit, except as provlded in this Contract and by law. b. DUR RIGNT TO ENDORSE INSURANCE CHECKS: Yau agree that the Seller, Assignee, any subsequent ass~nee, or an authorized empbyee of any of them ["wa"y may endorse your same, acting as your agent, to any check, draft or other instrument we receive in payment of an Insured loss or return of insurance premiums. You agree that you do not have the right to, and will not, revoke the power you have given us to make your endorsement You agree that we may exorcise this power for our benefit and not for your benefit, except as provided in this Contract and by law. c. USE OF PROCEEDS: We may apply any insurance proceeds we receive to repair or replace the Vehicle if, in our opinion, it is economicagy feasible and you are not then in default of this Contract Otherwise, we will ably the insurance proceeds to reduce the unpaid balance due us. Alter the balance due us is paid, any excess wiH belong to you. w .xui unw .u u.r. e. IXPENSES: You agree to pay the costs of repossessing, storing, repairing, preparing for sale and selling the Vehicle as may be allowed bylaw. These costs vdk only be due Ifi 1. Default exceeds fifteen {15) days atthe time of repossession; 2. The amount of costs are actual, necessary and reasonable; and 3. We can prove the costs were paid. Ili. HEIRS AND PERSONAL REPRESENTATIVES 80UND: After your death, tins Contract shall be enforceable against your heirs and personal representatives of your estate. 17. GOVERNING LAW: This Contract is to be interpreted according to the law of Pennsylvania. 18. SEVERABILITY OF PROVISIONS: If for any reason any part of this Contract shag become ilfegai, void or unenforceable, that part shag not he a part of this Contract 19. ASSIGNMENT BY BUYER: Buyer shall not assign this Contract 20. THERE ARE NO WARRANTIES BY SELLER, EXPRESSED OR IMPLIED, INCLUDING THE WARRANTIES OF MERCNANTABIIITY AND FITNESS FORA PARTICULAR PURPOSE, UNLESS WE HAVE GIVEN YOU A SEPARATE WRITTEN WARRANTY OR UNLESS SELLER ENTERS INTO A SERVICE CONTRACT: WITH BUYER WITHIN 90 DAYS FROM THE DATE OF THIS CONTRACT. .. Buyer's Guide Window Sticker. If the Car which is described on the face of this Cotltract has a Buyer's txtlide Window Sticker required by the Federal Trade Commission Used Car Trade Regulation Rule, the following notice applies: The information you see an the window form for this Vehicle is part of this Contract. Information on the window form overrides any contrary provisions in the contract of sale. NOT[CE-ANY HOLDER OF TH[S CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. NOTICE OF PROPOSED CREDIT INSURANCE The signer{s}.of this Contract hereby take{s} notice that Group Credit GTo insurance covera~ or Group Credit Accident and Disability Insurance coverage wRl be applicable to this Contract if so marked on the front of this Contract, and each such type of coverage wlll be written by the insurance company named. This insurance, subj~t to acceptance by the insurer, covers only the person or persons signing the request for such insurance. The amount of charge is indicated for each type of Credit Insurance to ba purohased. The teen of insurance wRl commence as of the date the indebtedness rs mcurced and wiU expire on the original scheduled maturity date of the indebtedness. Sub)ect to acceptance by the insurer and within 30 days, there roll be delivered to the insured debtors} a certificate of insurance more fogy describing the insurance. In the event of prepayment of the indebtedness, a refund of insurance charges will be made when due. NOTICE: SEE OTHER SIDE FOR IMPORTANT INFORMATION. THE PROVISION BELOW tS NOT PART OF THE PENNSYLVANIA MOTOR VEHICLE INSTALLMENT SALE CONTRACT BETWEEN THE BUYER AND SELLER. ASSIGNMENT To induce you, the "Assignee" identified on the lace of this Contract or as fdlaws, (Name) to purchase the within Contract, the Seller hereby warrants and represents, and continues to warrant and represent that the sale has been made in strict conformity witlr ail applicable federal, state and local laws and regulations, including, but not limited to, Article 2 of the Pennsylvania Uniform Commercial Code .(13 Pa. C.SA §§Z101 et seq}; our title to the Contract and the Vehicle covered thereby is absolute, free of all liens, encumbrances and security interests, and is subject Doty to the rights of the Buyer as set forth tf>erein; the Contract is genuine, the signatures tfreraon are oat forgeries, arose from the sale of the Vehicle therein described, and all parties thereto era of full age and had capacity to contract; the description of the Vehicle and extra equfpmerrt is complete and correct; the. cash downpayment and/or trade•in allowance xere actuahy received and no part thereof consisted of Hates, postdated, checks, other credit advanced by us to Buyer or rebates ar sim0ar payments from us to the Buyer {however manufacturer retains may constitute a0 or a part of the downpayment}; all warranties and statemalts therein are true; there fs owing thereon the Amount Financed plus interest at the Mnual Percentage Rate of the Coldract s~ forth ttrerein; we are duly licensed under the Peru~sylvania Motor Yehfcle Sales Finance Act and have duly complied wRh all requirements thereof with respect to the transaction and witl- the federal Truth-iri•Lending Act and with any other federal ~ state law, rule a regulation applicable to this'CentracG a molar vehicle title certificate showing a lien or encumhrence fn iaro< of AuiMlee has boon or wRl be applied for promptly; the regafration of the Yahick: has not been suspended and the Seller knows of no facts which may result in the suspension of said registration under the Pennsylvania Motor Vehicle Financial Responsl'bllity Act; the Buyers} named In the within Contract is (are) personalty known to the Seller to be the same identical persons) whose signalure{sy is (are) affixed to this Contract: and Seger has no knowledge of facts inrpairing the, validity or value of the Contract If any such hercanties or roprecentations should be breached at any time, Seller shag repurchase said Contract from Assignee, on demand, and wig pay therefor, in cash, the amarnt owing thereon, computed as set Lath below, and said remedy shag be cumulative and not exclusive, and shall trot affect arty other right or remedy that Assignee might bare at law or in equity against Sellcr. In the event that Buyer fags or refines to make any payment due hereunder on the assertion, either oral ar written, that the Vehicle is defective, not as represented to the Buyer by SeHar, or that Seger refuses to honor any warranty or service agreement of Seger or manufacturer, Seller agrees that, on being advised by Assignce of such claim of Buyer, SegerwiH repurchase the Contract from Assignee and pay Assignee for same immediately in accordance with the repurchase terms set forth bebw, and Seiler further agrees to hold Assignee harmless from any other claims of Buyer, including attorneys' fees, costs ahd expenses incurred in defending against claims asserted by Buyer and Including claims for refund of payments made by Buyer to Assignee. If the Seger contracts to purobase property insurance on behalf of the Buyer; and that insurance is cancelled by th insurance company prier to its ~heduled expiration date, Seller wiN attempt to place comparable coverage vrith another insurance company on behalf of the Boyar. If Seller is unable fo do so, Seller will notify Buyer and pay to Boyar atry additional casts incurred by the Buyer In obtaining replacement insurance for the unexpired period.of the original insurance policy. By signing acrd dating the Coninct, as Seger, delivering the Contract to the Assignee and accepting payment for it, Seller authorizes the Assignee to act as the Seller's agent far the purpose of completing or corcectimg the identification of the Assignee in the Assignment to reflect the true Assignee who purcha~d the Contract and/or for the purpose of signing Seller's name to this Assignment, without rewur~, iE the Assignment is delivered without the Seller's signature. Assignee may exercise the power given in this paragraph for the benefit of the Assignee and not for the benefit o(the Seller, Ballot does not have the right to and agrees not to revoke the power given in this paragraph. In the event that Seller is required by this Assignment to repurchase fhe Contract and/or Vehicle, Seller shalt pay to Assignee, In cash, the full unpaid balance of the Contract as o'. the date of repurchase, plus any then earned Finance Charge and any and ail costs and expenses paid or incurred by Assignee in respect thereto, including reasonable attorneys' fees, in conrcectian with claims by or against arty Buyer, Owner or pereau In possession of the Vehicle and/or by or against Seller. For value received, Seller hereby sells, assigns and #ransfere unto the A~ignee, its suaressors and assigns, the within Contract, all moneys due and to become due thereunder, and all right, title and interest in and to the Vehicle therein described, with full power in the Assignee In its or our name to take such legal er other action which we might have taken save for this Assignment Unless Seller marls either of the endorsements below, titled "WITH FUIL RECOURSE" or "WfTH REPURCHASE;' Seller's assignmerd shall, except for the provisions of the paragraph titled "Assignment," be without recourse. 0 WITH FULL RECOURSE-Seger agrees that, in addition to the paragraph above titled "Assignment," in the event of default by Buyer fn the foil payment on the duo date thereof of any installment payable under the Contractor in the prompt performance of any other obligation to be performed under the Contract by Buyer, Seller will, on demand by Assignee, forthwith repurchase the Contract from Assignee far a repurchase price, in cash, computed asset forth above. ^ WfTH REPURCHASE-Seller agrees that, in addition to the provisions of the paragraph above titled "Assignment," in the event of any default by Buyer which shall entitle Assignee to repossess the Vehicle, Seller wig, if the Vehicle is ropossessed by Assignee and delivered to Seller, and without regard to the then candiiion of the Vehicle, forthwith repurchase the Contract and the Vehicle from Assignee for a repurchase price, in cash, computed as set forth above. By signing below, we agree to the terms of the Assignment Seller By Date waters Kluwer To Reorder Forth: 1•e00.562 8410 Addendum to PA MotorVehitle InstallmerrC Sale tontr~ct ~ ~SE~~ This Addendum is incorporated into and becomes pert of your Contract The Anrusl Percentage Betas, COrre4JOrdtrg dopy periodic rates and a^iount of payment for each loan are shown below, All ra6es ere subject to change. Default Rase: TFe credit glen reserves mo r'sgnt to char>je the highest unsecs:red ~~serest rate currently In effect at PSECU Auto loan-lo-Value Fir-andr[gr Races retlect loar..amotxtts up to i0J% of the hASRP, [ho Kelley Bfue Book `'s ar other. atNhoti~ed~ gukia's retail value of the vehicle. PSECU wUl charge an addaionel 2% to the wrrert interest rate vvttor+ flnnr'cing a vericle for more loan 1 1;096 and ~ :o i 30% of the rtttatl vakro: PSECU makes ell final decislans regarding vohtcle values and proper rate (Kelley Blue Book' is a registered trademark of the Kelley BF1e Boor'Co.. Inc } ' Aab loan` Without Autoaafic Payment 5ervtce YVI~r ~ Wit{rout AuFomal'e ?aymeerf Service ~~ APS IJsw Vehicle _ 540,000 ban and value « greutx l20 0 022546 OA2i896 8 2 y76 7.9996 EZ0,000 value or greeter 84 0 Ot 1036 0 016446 6 2496 59996 f12,000value«groater 72 0.07439; 0.013676 32471 4.9996 fa000 vsrus «gamer fi0 00088% 0000796 3 2476 2.9946 E8.000 value « grearor 4B 0008896 0008146 3.24X. 2 99% 53,000wlue«greater 36 0004776 0004076 17e9i 7,#996 53,000 value «gnmlar 24 D 004796 00040'6 ~ 747= !.#976 IhadVainclniOnly ~ 540,000 Ioart and vatus « greaser 120 O.CZ25°b C.021t376 8 245x 7.9996 EZ0,000 vn4m «greater 84 O 0170)6 0 0 t 8476 6 24'+, 5.9946 fl2,000value «greater J? 0 014395 0.013696 5 3x96 499% fa000va'ue«gr~at~r 6C 0008876 00087% 724% ?.9916 f6,000 value a grainer 48 0 OOt98Yo 00081 % 3 2aq, 2.99% E3,000vttk[e«greder 36 0004776 0004095 ' 7496 tA955 53,000 value «grenter 24 ').004796 D 00407r } 1495 1 4976 RaaaaliartoiYahirla Flaw/Qsedt loan amount f 15.000 and up 84 C 027196 NlA 99056 N/A loss emoux 515.000 o:w up 7? 0.021176 N/A 29076 N/A lom~ ertwun[ Sa000 - 14,999 60 0 027195 NIA 990% NIA loan amoun 55,000.7,999 48 0 027196 N/A 93x96 N/A loan amotmt 53.000. 4,999 36 0.0271°b N!A 9 9x'15 ;4/A Automatic PayntertF Service (APB)s In order to qualify for the .2596 reduction, at the time the loan is sot up, you maul soietx to have your vehicle loan paymerus made via an atROmatic service: Automatic Transfer 5ervfco, Payroll Dedualon, Cash (includes psecu(lphomo' and Selr-Service Telephone), W-ro Transfer, anti DErect Payment. If you remove, discontinue, change or postpone the automatic transfer at arty time after your tote k ssxup Your Irttorest rate wilt imrnodlatey ba increased by 0.2596 {as of the date of your test payment) far any outstanding balatce on the loan. If your Irxerost rate 's increased due to any of those masons, yol.r loan payment ernotmt watt remain. the same. however the form of your loan :viii bo extended for the epproprfate amour: of limo ants! all tn:erest, p:lnclpal. and fees have beet paid according to your Plan. Footnotes: (1) At the current intore~ rata, PSECU will finance up to 1 1]096 or the Mant,factt.rce:'s Suggested Rotal: W,~ (MSRP} of a r:ew, current incest year vehicle {untitled); tip to 10096 of the rotall vakre of a raw pr;or-year vehicle (un[t:ted), o: up to 10046 of the retai' value or a used vehicle (tttlad ) At the current interest rate plus 296, PSECU will finance over l 0096 and up to 13096 of the MSRP or a new cur-. art nicest year vet•icle (united), over 100% and up to 130% of the retail vahx3 of a r~ prior-year vehicle (tu+titied); or over 10096 and up to 13046 or t'~e retell value of a used motor vehkJe (titled). Maximum financing for amember-owned vehicle or rofinanang an extst'ng PSECU loan Is 70096 of the mail value For load and prior-year new vehicles, PSECi! consults the Kelley Bluo Book" (regls;ered irademaWt of KoBoy Bluo 8ook..:o .Inc.} or other authorized guides to determine value. Vehicle loans catrtat bo used to purchase commerGai theft, salvaged or flood-titled vehteles. The vericle must be tNtad to the Borrower, Co-Borrower or both. The regtstored ava~c on the CaKiticate of Tltte may not be a business, corpon:tton or trust entity Veh'cles mist have e : rininwm value of $3,000 and must be titled in the U.S. and may not betaken out of the U.S. 2} PSECU will finance up to 90 percent of the retell votue of a new {untitled, current mode; year} :ecreaLOnaf vo'tlclo Usod (tilted) recreaUOnet vehicles may be financed up to g0 percent of the used retell value. Tha Kelley 8kle Book" or other autt~rued gulden will bo used ro determine the recrea;tonal vehicle"s retell value PSECU's minimum RV loan is $3.000. Your RV must have a minimum retell value of $3.333. I/We have read and agree to the farms and conditions as stated in the Addendum to the PA Motor Vehicfa Installment Sale Contract. Nofice to arty Co-applicant: I (the co-applicant) odcttowledge that I am eligible for membership in PSECU, and I promise to establish membarship:a'ilt PSECU as soon as possible, ___ X App icant Signalu Date Co-applicant Signature Data THISCRED1TElNIONISFEDEltAILYINSUREDBY?HENATIONAI.CREdITUNIOkAQAIINISTRATION.EQUALOPPORTUIiIiylEktlER. ~'w-.~sylva~rStnuGSrpt[ryeasCreCRUnpnFwmB31595/11 SCANNED EXHIBIT "B" 3767073 .~.I~ ~.. c`• '. RAT' CITE OF TITLE FOR A VEH:[CLE SBUE UNLADEN~WEIGFIT A ~-' F ~ OVWFi GCWR~ D TE~O i DATE PA TITLED ~ ,.,.r '` ( l3'-r r '-~~: - ~ i , ' !` ~ _ yyr +.,g . .., ~•. ,i:~ 14. DmAPT(~OM IN8IX.08DRE ~n:vT J. r-. :-.TREE tlRMOS.:. ' f A . ANTIOIiE~-'iy' ~.~ :~, :: ~_ o 7a ~~ ~ -- F <~OUT OF COIlNiBY~ '~ ~ G . ORIOMYlLYII :.. :._y .a". Ot8TgB17710N ~: ~ ,-y . ~' ~ - _. .` _. .. ~ ~ H-AORIDdLIURAL - P.-ISIWAB APOLICE VBtH)lE aL~ ~ P ,. L~oz ~ ~ ~ .~ s :.~°" ~ = ~ s f T .-R~'OVERm TH~fVEJi1C1a ~!_- ~~ ~.~ G' .~ W . FL-0OD VBilq_E ajv X . ISMIA6 A TAXI sFA F. a FN~AVOR-OF: '-: ~ ~ ~ - .,n.:... P E Cll a-:. _ ~ E; - II'. e nwrd Yedlolder k -.YSted ~P~ ~~+~I r ,' _." FerJwiier' rtxiW .forward tlir: Tltle to the Braeeu d r+,i, ' ~:r<pproprlate farm and tee: ~r x' .L$ _ k• ;fi' DATA ~'"~" ^* ` BY 6ECONDLIFIJ.RELEASED 4 AUTHORIZED REPHESE7iTAT1YE - DATE ~Il1UN6 ADDRESS - - _ BY ' AUTtiOR® REPRESENTATNE ;~'; R~ECU P 0 B4X 67613 HAt~RI BURG PA 17.106 ,~ pennsyl~rana ' DEPARTMENT OF TRANSPORTATION y. . .t' ~~' ~ ~ r~ d.~ a lave, u,e al~al.n of The l'elfnsylYafia DapsrVnsnt $ARRY J • SCHOCH, P . E of:T+aruponen«r reflect ttrat tl,e paraanie)-a comPanY nnned tbreuf m tn. IarNrd owner H w TT a co-purd~eser Sher Than your.aparee M Bl:md and you weM the tltla to. , D swoR 'Jdnt Tanertte WNh Right d SuMvorahip'.' be Ysted as . ti~trr one r ., owmep~:flUe'goas to .survlvirip owrtet') f~iECK]i6RE l3 x ,.i ~w~9~e ieaued iis-'Tenente fn CatYllon' (l]n;death dfcOna-. deceased rnmer to Mafier Neks tx assets) '-::. ;,i .. ,: .• ~.. ~ ` ~ . :,. CFiEC.K^ - IS TFe3 AN E11'9 (IF YES, FIN REGIUTAEQ),~ JF NO17EN, ` ~ '~''~ '~ - 7ST LIENHOLDER FINANGAL INSTRUTION NUMBER: ~ •-. '~~ Y ,,xy ,. NAME ~' 1 Y szjjtt ~ ~f i ~'~»~ S ~ 7< ^ v ' F 1a~ f ~;i~ + .Tack` ~,~, ; STATE Y~rv uu ~ f ~ t ;a:~,. ~, _.: t :.. wf a T e d ~ . e e e - -IF IJC> 2NO L1EN~ CHECK ^ IS THIS AN ELT? (IF YES; FlN fiEOUI " " , )' ^ w w ~ ti .. e Y o fa x. . a .pp tl .,. b wdde,Yri,p~l tiYna iM lun Iwr< nk.. .., . .. R~' /'~/~ ~7D llF_NHOLDER FlNANGAL INSTITIfDON N ~_ ., t ~} .: ' 2ND LIENHOLDER NAME ~b~ - ,.. ..,: SKaihTLlnE OF;QPPUCMl7 DR AUIIIDN~D SIaNEA ~. - .r~~ ~ ' _. STREET ^ V 1 .: eNYMttl/1E aF COdPPUGU~DrtttP of AUIlgN~D BKiNB1 GTY - STATE ZIP An employee of an issuing agent licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons may verify a person's signature in lieu of notarization. yy . ~ _, ~; i ~ WW ss~ ~ LL 2 - 1 ~{ 5 ~ '~: t. ~'{~ ~ ~~'k'~ „ ~ ~~' s ~.. ' ~~, ~ ~' r ~~ ~~' ~ g~= u. ~ Y ,• ms's - ~] I N~ . K ~ ~~ ~ ~: = ~ w ~s N- fA ~ ~„ .~. ~ (S F , T. f, ~ _. f K , ~ ' j~ ~ ~ i. 54 a r .: i i •k@7~ ~ ~ ~~. ~ .. •.. .'f7 - W:. ~F + . t~§ R~I~ ;~%~.t if ~ `#..~'~~ } ~ ~.~ ~ ~K w~~ ; C L'~ ~ ~1 ~ ~~rZ. -J< Z W 1 3 y • •t ~. S _ O~ F j ~ a R ~ ~ --' q ~ ~ ., F- ~ q .. ~ g p ~ : W Z ¢ ZQ Q ~ ~ ~ _v- ~ ~ t st. fr it ~ ~ / ~ ~ ~¢ '~ Q W _ ~i r„~. W UZ Z ~ W Z .{ ~ : ~ - ~ ~ ~ _: ¢ ~ W ~ r~ {., 't ~ t '~ - ~ f, ~~~ $ . ~ r ~ O ~ ~ ~ ~~ - Nl ~i ~ L rJ ¢ .. O ~ F3 ~ "~," ~ ~ .,. .: Y §r9' ~ L ) x v S ~. w y y 7 ~~ , Q - . ~' - "'o # ~ ~ ~ ~, ~ x~ y~• r ~t~c rte. S ~ oC $ ~ as ~1! '~~ ~ ' -,~ ,~ ~ "~ ~ ~ ~ ~, ~ ~ z' p y0 3 ,s r , 45. i ~ ,y ~ ~ ! { e ~ S~ S4+ Y r` ~ :` _~ v W ~~ 'w ~ ~ ~ ~ ~ z ; ~ ~ ~ a ~r '~ z ~ d ~ [ O r t F- ~ ~~ap ~ z ~ re ,~ , ~ .: , •'~ - ~~ ~ o . ~ ~ ~~ f. ~~ ~x ~ -~, '' '~r,~'~'~~ - zdt'~• ,e z~~` ;` •s r x~'"=~ ~ c• e z qW ~ s ~~ W ~ ~ ~ -~ a Zi ~ q6 W ij: p~~3 Qa~ )elf ~jJ' n , _ ~t~.. ~ ~ t; ~ Sr ~.£ ~ ~~ 1a j~'y~f~.yH. 'te ) ~;~y~l ~,' s~ •O~ ~}}}[[ c Ilm~~~l~' ~ y~ .. ~ y } ~ Q W W BI 5 m~ U ~ ¢ ~ _ ~,~~ ~~ f~. V3S ' ,} ~ °~, ~ `~ ~ ~~ c. ~ .~~ :r '" a~ ~S'~IdWN1S L n .: (Franz-nil a-raw ~ . EXHIBIT "C" 3767073 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www barleycorn VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL Lindsey B. Sgrignoli 6822 Wertzville Road Enola, PA 17025-1032 November 1, 2012 Shawn M. Long, Esquire Direct Dial Number: 717.399.1512 E-mail: slong@barley.com Re: Pennsylvania State Employees Credit Union/2003 Lincoln Navigator Dear Ms. Sgrignoli: This firm represents Pennsylvania State Employees Credit Union ("PSECU") in connection with the Loanliner Credit and Security Agreement (the "Agreement") you entered into for the purchase of your 2003 Lincoln Navigator (the "Vehicle") under which you granted PSECU a security interest in the Vehicle until the loan was paid in full and agreed to list PSECU as a lienholder on the Certificate of Title for the Vehicle. This letter and any future letters from our firm are an attempt to collect a debt, and any information obtained will be used for that purpose. Despite requests from PSECU to bring this account current, you have failed to do so. You are currently due for the May 30, 2012 payment in the amount of $362.37 and each monthly payment thereafter. This failure is a default under the Agreement, which entitles PSECU to exercise various remedies including, among other things, the acceleration of the remaining balance of the loan and repossession of the Vehicle. The balance due and owing on the account is $19,364.74 to date (the "Debt"). PSECU has authorized me to demand that you pay the Debt in full or make arrangements to deliver possession of the Vehicle to PSECU's designated repossession agent within thirty (30) days from the date of this letter. If you do not comply with this demand, PSECU is prepared to initiate legal proceedings against you, and to exercise its other available remedies. Should you decide to pay the Debt in full, you should send payment by mail to PSECU, One Credit Union Place, Harrisburg, Pennsylvania 17110 or you may send it to my attention. If you decide to make arrangements to deliver possession of the Vehicle to PSECU's designated repossession agent, Richard & Associates, Inc., they should be contacted at (888) 873-9861 or you may contact me. You have the right to dispute the- validity of the Debt in its entirety i .. fit. :. Unless you dispute the validity of the Debt or any portion thereof, within 0) ~' Lancaster • York • lteadin~ • Malvern • Hanover November 1, 2012 Page 2 receipt of this notice, we will assume that the Debt is valid. If you notify this office in writing within the thirty-day (30-day) period that the Debt, or any portion thereof, is disputed, we will obtain the verification of the Debt and mail a copy of such verification to you. Upon your written request within the thirty-day (30-day) period, we will provide you with the name and address of the original creditor, if different from the current creditor. If you do not act in accordance with the terms as stated above within thirty (30) days from your receipt of this letter, our client is prepazed to initiate civil litigation proceedings to collect the Debt, together with interest and costs of collection allowable by law, and intends to exercise its rights and remedies in connection with the Vehicle and your account. 3736103 Very truly yours, ~~ Shawn M. Long cc: PSECU, Attn: Mr. Greg Diffenderfer U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAiL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER R~e(ce~ived` From: + M -~ ~ ~; y~ ~n ~ ~ c~/'~ ..JJ _t o~~. ~ k ti~ S+ One piece of ordinary mail addressed to: r~ ~ n.r~ 1 a , ~ q ~~v2 ~ -log z r~ rorm dtf I /, Mar, l qtly TO: LINDSEY B. SGRIGNOLI 6822 WERTZVLLE RD ENOLA, PA 17025 Affix fee hE or meter I post mark Postmaste fee. S>s 5, t[~ ~'~W " dd any- o N _.. -o .~ , N V ~~ ~~ ~ N SENDER: REFERH~E: PSECU/ SGRIGNOLI 1 .~ ,_,`` ^ _i IW l O N ~ ~ ..l • O N O ~, 10 RETURN Postage ~ RECEIPT Certified Fee ~ SERVICE Retum Receipt Fee ~ i Restricted Delivery Total Postage & Fees LISPS' POSTMARK W71/ATE ~ Receipt for ` I ~~ j i i ~ Certified. Mail'" E No Inwrance Coverage Provided Do Not Uae for International MaA Wa1z, C`crtifiedPro .NET ~~ wcurtty + 1 kcunneen(Loaout) Home Overview User Info Help Links Contact Us QUICK TRACKING Enter the Article Number: -T ------ Submit rs .r~ gage r_ of 1 CertifiedPro.Net Create Transaction Create Multiple Transactions Tracking Process Retums Retums Look L p Mail Center Settings Upload Address Book Last Login: 11/1/2012 Recipient: LINDSEY B. SGRIGNOLI 6822 WERTZVLLE RD ENOLA, PA 17025 Transaction created by: kcunneen User ID: 4931 Firm Mailing Book ID: None Transaction Information: Tracking #: 71969008904012907503 Service Options: Return Receipt -Electronic: Electronic Confirmation Mail Service: Certified Reference #: PSECU/ SGRIGNOLI 1 Postage: 0.9 Fees: 4.10 Status: Delivered Transaction History: _ Event DeacNptbn Evert Date Detail USPSO Download 11-O1-2012 [WALZ] -ELECTRONIC SHIPPING INFO RECEIVED at TEMECULA,CA USPSO Download 11-02-2012 [WALZ] -PROCESSED THROUGH USPS SORT FACILITY at HARRISBURG,PA USPS® Download i1-02-2012 [WALZ] -DELIVERED at ENOLA,PA Download View Description RRE Image https://www.certifiedpro.net/w 1 /SearchResultDetail.aspx?id=2321411 11 /5/2012 Date Produced: 11 /05/2012 WALZ CERTIFIED MAIL SOLUTIONS LLC The following is the delivery information for Certified MaiIT"" item number 7196 9008 9040 1290 7503. Our records indicate that this item was delivered on 11/02/2012 at 02:25 p.m. in ENOLA, PA, 17025. The scanned image of the recipient information is provided below. ONiwry ~euon Signature of Recipient: ~ °y'' .~------ ~ ~ Address of Recipient: ~ ` ~ ~ L Z /,, „~ ~ T~ Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representative. Sincerely, United States Postal Service VERIFICATION Pennsylvania State Employees Credit Union v. Lindsey B. Sgrignoli 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: 7 Gregory . Diffenderfer 3767073