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HomeMy WebLinkAbout13-3690 Supreme C Pennsylvania COU - 'In O leas For Prothonotary Use Only: ver, C �v Docket No: SLPq u County � It The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S X Complaint 0 Writ of Summons Petition Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiffs Name: Lead Defendant's Name: SYSTEMS & SERVICES TECHNOLOGIES, INC. AS Sg ANGELA M. HILBERT T Dollar Amount Requested: nwithin arbitration limits I Are money damages requested? 0 Yes 0 No (check one) Doutside arbitration limits 0 N Is this a Class Action Suit? 0 Yes X No Is this an MDJAppeal? 0 Yes ED No j A Name of Plaintiff /Appellant's Attorney: WILLIAM T. MOLCZAN, ESQ, PA ID #47437 w Check here if you have no attorney (are a Self- Represented (Pro Sel Litigant) ' Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional f_i Buyer Plaintiff Administrative Agencies M, Malicious Prosecution LJ Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle Debt Collection: Other ] Board of Elections 0 Nuisance CONTRACT Dept. of Transportation U Premises Liability Statutory Appeal: Other S Product Liability (does not include Employment Dispute: mass tort) r E Discrimination Slander/Libel/ Defamation Employment Dispute: Other Zoning Board C 0 Other: Other: T T L Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste Ejectment 0 Common Law /Statutory Arbitration 0 Other: F Eminent Domain/Condemnation 0 Declaratory Judgment B Mj Ground Rent 0 Mandamus Landlord/Tenant Dispute 0 Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental _1 Partition i Replevin i_i Legal -i Quiet Title 0 Other: 0 Medical 0 Other: f 0 Other Professional: i i L Updated 1/1/2011 WELTMAN. WEINBERG & REIS CO. OF THE PROT F diOTARY Attorney for Plaintiff(s) 70 } a JU G z - ! : t BY: William T. Molczan, Esquire I.D. No.47437 CUMBERLAND COUNTY 436 Seventh Avenue, Suite 1400 P EN N SYLVAN I A Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 20145854 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SYSTEMS & SERVICES TECHNOLOGIES, INC. AS SERVICING AGENT FOR MEDALLION BANK Plaintiff vs. Civil Action No. J ANGELA M. HILBERT Defendant(s) COMPLAINT AND 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 in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249 -3166 t �1 sad �� a9 a 3 s i COMPLAINT 1. Plaintiff is a corporation having offices in 4315 Pickett Road, St. Joseph, MO 64503. 2. Defendant is an adult individual residing at 214 South Enola Dr, Enola, PA 17025. 3. On or about July 6, 2012, Defendant duly executed a Simple Interest Note and Security Agreement (hereinafter the "Agreement "), a true and correct copy of said Agreement is attached hereto, marked as Exhibit "1" and made a part hereof. 4. Pursuant to said Agreement, CT Install America - 79384 performed certain home improvements more particularly identified in the Agreement. 5. Pursuant to the terms and conditions provided by the Agreement, Defendant financed the home improvements by borrowing certain funds from the Plaintiff.. 6. Plaintiff avers that Defendant is in default of the Agreement by having not made payment to Plaintiff as promised, thereby rendering the entire balance immediately due and payable. 7. Plaintiff avers that a balance of $16,189.99 is due from Defendant as of May 13, 2013. 8. Plaintiff avers that the Agreement between the parties provides that Plaintiff is entitled to interest at the rate of 10.49% per annum. 9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and /or refused to pay the principal balance, interest, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment against Defendant, Angela M. Hilbert, individually, in the amount of $16,189.99 with continuing interest thereon at the Contract rate of 10.49% per annum from May 13, 2013, and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molczan, Esq ' e I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 20145854 SIMPLE INTEREST Medallion Bank ( "Lender") 1100 East 6600 South, Suite 510 NOTE AND SECURITY AGREEMENT Salt Lake City, Utah 84121 THIS IS A CONSUMER CREDIT TRANSACTION (801) 284 -7065 Borrower: Angela Hilbert Address: 214 South Enola Dr Co- Borrower. Lemoyne, PA 17043 Seller: CT Install Ameri - 7 938 4 Meaning of Words. This agreement is a simple interest note and security agreement ( "Note "). The Note will finance all or a portion of the purchase price of certain home improvements (the "Work ") from the Seller identified above. In this Agreement, the words "you" and "your" refer to the Borrower and Co- Borrower. The words "we," "us," "our," and "Lender" refer to Medallion Bank, a Utah industrial bank, and its assignees. Medallion Bank, and not the Seller, is the Lender in this transaction. Promise to Pay. You promise to pay to us the principal sum identified below as the "Amount Financed" plus interest at the simple annual interest rate identified below as the "Annual Percentage Rate" ('Interest Rate "). You promise to make payments in accordance with the "Payment Schedule" below on or before the same day of each month as the first payment due date. Payments and other credits will be applied as described on page two of this Note and as required by applicable law. You promise to pay all other amounts that may become due under this Note. Each person who signs this Note as Borrower or Co- Borrower is individually liable for the sums owed under this Note. The Amount Financed will be funded in a single disbursement as soon as reasonably possible following the "Completion Date," which shall be the date following completion of the Work and our receipt of a properly executed Completion Certificate. Interest will begin to accrue upon disbursement of the Amount Financed. The Lender will not be obligated to disburse the Amount Financed if the Completion Date does not occur within 120 days after the date of this Note or if an event exists that constitutes a default under this Note. Description of Property. As security for this Note, you giving Lender a purchase money security interest in the following Property, and all additions and attachments: siding (the "Property"). TRUTH -IN- LENDING DISCLOSURES ANNUAL PERCENTAGE FINANCE CHARGE Amount Financed Total of Payments RATE The dollar amount the credit The amount of credit provided The amount you will have paid The cost of your credit as a will cost you. to you or on your behalf. after you have made all yearly rate. payments as scheduled. 10.49. % E $ $9,346.00 $ $15,110.0 E $ $24,456.0 YOUR PAYMENT SCHEDULE WILL BE: Number of Payments Amount of Each Payment When Payments Are Due Monthly, beginning approximately one month after interest begins to 120 203.80 accrue. We will inform you at the time the Amount Financed is disbursed of the day of each month on which payments are due. Late Charge. If a payment is not paid in full within 10 days after it is due, Security Interest. You are giving a security interest in the you will pay a late charge of the greater of $30 or 5% of the unpaid Property being purchased. amount of the late payment. Prepayment. You may prepay all or any portion of your debt under this Additional Information. Read this Agreement for additional Note at any time without penalty. information about security interests, non - payment, default, prepayment refunds, and any required repayment in full before the scheduled date. E means "estimate ". F X Promotional Feature Not Available ITEMIZATION OF THE AMOUNT FINANCED Promotional Same as Cash ( "SAC') Feature 1. Amount Given to You Directly $ 0.00 Amount Paid to Others on Your Behalf The SAC period is months. If checked and completed above, this Note contains a SAC a. Seller CT Install America - 79384 $ 15,000.00 promotional feature which will begin upon disbursement of the b. Public Officials: Filing Fees Amount Financed. The SAC period runs concurrently with your (for perfecting security, seepage two) E $ 110.00 monthly payments. For example, a six month SAC would end on $ 0.00 the due date of your sixth payment. You will pay no interest if you c. To: pay the entire Amount Financed and any charges on or before the Total Amount Paid to Others on Your last day.of the SAC period. You are required to make the 2. Behalf (a +b +c) $ 15,110.00 scheduled monthly payments described in the Payment Schedule above throughout the SAC period. Payments made during the Amount Financed (1 +2) $ 15,110.00 SAC period will be credited to the payoff amount due. c BIT iviedallion Bank Multist �: c % C r020�;2 G - -- j 3 Page 1 of 3 ° stat Mote � , (F �.4. i712D12: HI #4838 -6 - � mul rottate L_ EEP DociD# 7e 10 OTHER IMPORTANT PROVISIONS the Property, and you agree that we may, at our option, receive from you Payment.,Time is of the essence in this Note. You agree to promptly pay full reimbursement upon demand. Unless required by applicable law, we us all you owe under this Note even if the Property is damaged, destroyed, will not notify you of our intention to repossess the property. You or missing. Any payment amount that you remit shall be applied first to acknowledge an express intent to grant a security interest in the Property interest, then to principal, then to other charges, with all other charges, if and hereby waive and abandon, to the extent permitted by law, all personal any (including without limitation all charges for repair bills, storage bills, property exemptions granted upon the Property, which is the subject of this taxes, assessments, fees, fines, and other charges on the Property which Note. NOTICE: BY GIVING US A SECURITY INTEREST IN THE we pay), due upon demand or upon termination of this Note or as we PROPERTY, YOU WAIVE, TO THE EXTENT PERMITTED BY LAW, ALL otherwise designate. The final payment may be more or less than the RIGHTS PROVIDED BY LAW TO CLAIM SUCH PROPERTY EXEMPT monthly payment amount depending upon the timing of prior payments. FROM PROCESS. Acceptance by us of partial or late payments shall not modify the terms of Collection Costs. You agree to pay all costs and expenses we incur in this Note and shall not constitute a waiver of any subsequent default. collecting any late payment or in enforcing any term, condition, or covenant Prepayment. You may prepay this Note in full or in part at any time of this Note, including reasonable attorneys' fees and court costs, and without penalty. No refund of interest is required and none will be given. collection agency fees, to the extent permitted by applicable law. If you reside in Iowa, and the amount financed is $25,000 or less, you will pay Ownership and Risk c Loss. You agree to take the following action to only those costs and expenses we incur in realizing on our security interest. protect the Lender's security under this Note: (a) maintain the Property in good condition; (b) pay all taxes, fees, fines, bills, and any other charges Returned Check Handling Charge. We may assess a charge not assessed or levied against the Property; (c) not sell, transfer, or assign exceeding $20 for each check you send to us which is dishonored or your right, title, or interest in the Property without our prior written consent; returned to us for any reason. In addition, with respect to such dishonored and (d) not allow any lien, encumbrance, or security interest against the or returned checks, you authorize us to initiate ACH debit entries for the Property other than ours without our prior written consent. amount of such check and you authorize the depository, institution to debit the same to your deposit account. You agree to be bound by and comply Security Interest. You hereby grant us a security interest in the Property with the Rules of the National Automated Clearing House Association in and in all additions and attachments to the Property. This security interest effect from time to time. You agree that our ACH authority described in this also covers: (a) proceeds of any insurance policies or service contracts Section is coupled with an interest and is irrevocable until all of your covering the Property; and (b) proceeds of any sale of the Property. This obligations under this Note are satisfied. secures payment of all amounts you owe under this Note and in any renewal, extension, modification, refinancing or assignment of this Note. It General. This Note shall be governed by and construed in accordance with also secures your other agreements in this Note. You authorize us to file a Utah law (excluding Utah law concerning choice of law or conflict of law) UCC Fixture Financing Statement to perfect our security interest in the and Federal law pursuant to 12 USC § 1831 d. Any provision hereof held by Property and you agree to pay us all fees associated with such filing. You a court to be invalid shall not affect the remainder of this Note. Waiver of agree to pay us any deficiency from the filing fee amounts we collected any default shall not constitute a waiver of subsequent default. The from you and we agree to apply any surplus from the filing fee amounts we obligations of all persons signing this Note as borrowers or co- borrowers collected from you to the unpaid balance of this Note, so long as the are joint and several. You may not assign this Note except with our prior deficiency or surplus exceeds $5. To the extent permitted by applicable written consent, and subject to the foregoing this Note shall be binding law, you authorize us as your attomey4 -fact to sign your name on any upon the parties' heirs, personal representatives, successors, and assigns. documents necessary to properly perfect our security interest if you fail to Unless otherwise required by applicable law, any written notice that we are do so. obligated to send you under this Note shall be sufficient if sent by regular Late Charge. You will pay a late charge on the unpaid amount of each mail, postage prepaid, to your address shown on page one of this Note (or payment that has not been received by us within ten (10) days after its due any more recent address if you have sent us written notice, to our address date. The charge is shown on page one of this Note. Acceptance of a late on page one of this Note, your address change). not have payment or late charge does not mean that you can keep making exercise any of our other rights before collecting from m y youu. . You agree e payments later than the due date. We may also exercise any other give us updated financial information any time request it. You waive remedies available to us under this Note, demand, presentment, protest, notice of dishonor or and notice of protest to the extent permitted by law. This Note constitutes the entire agreement Events of Default. Any one of the following constitutes a default under between you and us and may not be altered or amended except by a this Note: (a) we do not receive any payment when due; or (b) our writing signed by both you and us. As required by Utah law, you are hereby prospect of payment, performance, or realization of collateral is notified that a negative credit report reflecting on your credit record may be significantly impaired, which may include: (1) you fail to perform any submitted to a credit reporting agency if you fail to fulfill the terms of your obligation under this Note or any other agreement with us; (2) any credit obligations. information furnished in connection with this Note proves to have been Interest after Maturity. To the extent permitted by applicable law, you. false or materially misleading; (3) you sell or transfer your interest in the further agree to pay interest at the Interest Rate, not to exceed the highest Property; (4) you experience any adverse financial change that we lawful rate, on any amounts which remain unpaid after the maturity of this consider material; (5) you generally fail to meet debt obligations as they Note, either by lapse of time or by acceleration, or upon judgment in a become due; (6) any proceeding is commenced or petition filed under any court of law. bankruptcy or insolvency law by or against you; (7) you die or become incompetent or incapacitated; (8) the Property is levied upon or seized Notice of Limited Agency. This Note is a direct loan from us to you. For under any legal process; or (9) the Property suffers substantial damage. your convenience, we asked the Seller of the Property you are purchasing To the extent required by applicable law, we bear the burden of with the proceeds of this Note to prepare and obtain your signature on this establishing significant impairment. Note. Seller has no authority to approve or make this Note. Seller is not our Upon Default. If you default under this Note, agent in connection with the sale of the Property or in connection with any Rights and Remedies subject to any right cure you have under applicable law, we can down payment or for any purpose whatsoever other than for preparing and obtaining your signature on this Note. No employee or agent of Seller is demand that you pay all you owe on this Note at once. We also will have authorized to make any promises or agreements with you about this Note. all rights, options, and remedies of a secured party under applicable laws, No oral or written promises or agreements between you and the Seller and under this Note, including without limitation the following: (a) you must about this Note are enforceable. Any representations, promises, or deliver the Property to us if we so direct; (b) with or without demanding agreements between you and the Seller in connection with the Property or delivery from you, and with or without resorting to legal process, we may any down payment or other matter associated with the purchase must be repossess the Property and to do so we may peacefully and lawfully enter resolved between you and the Seller. If you have any questions about upon the property where the Property is kept; (c) you authorize us, at our Seller's authority in connection with this Note, contact us at the address on option and without obligation to do so, to make or have made any repairs page one. that we deem desirable; and (d) you authorize us, at our option without obligation to do so, to pay insurance premiums covering the Property, as Florida Tax. If executed in Florida, the Florida documentary stamp tax well as repair or storage bills, taxes, fees, fines or other charges on required by law in the amount shown on page one will be paid directly to the Department of Revenue. Certificate of Registration No.78-8013498263- 9. I0eca11ion 5 ank IUNI state i late H1 (R E:'. 4!17!20'12: HC• # 483E - 6520-49';2 multistate L - - -- • Uoc01 # 7 46 0 9 Page 2 Y3 ARBITRATION. Either you or we may choose to have any dispute arising under this Note resolved by binding arbitration under the rules then in effect of the American Arbitration Association ( "AAA ") or any other arbitration organization you choose and that we approve in writing ( "the Arbitration Organization "). The arbitration shall be conducted under the then current rules of the Arbitration Organization and is governed by the Federal Arbitration Act. Either of us may elect to arbitrate even if an action has been filed in court, so long as no judgment has been rendered; provided however, that we will not elect to arbitrate any individual claim (as opposed to any class action claim), not including any counter - claims, you bring against us with a total amount in controversy of $10,000 or less. A single arbitrator shall hold the arbitration hearing at a location near where you signed this Note (or, if you have since moved, in the federal judicial district where you live). The arbitrator shall apply applicable law. The arbitrator's award shall be final and binding on all parties, except that in the event of an award in excess of $100,000, the nonprevailing party may request a new arbitration under Arbitration Organization's rules by a three - arbitrator panel. Each party shall pay its own arbitration costs and expenses, including attorneys' fees, except that the arbitrator may award attorneys' fees, court costs and other charges if applicable law permits. Either party may enter judgment on the award in the highest local, state or federal court or before any administrative body. This Arbitration Clause shall survive termination or expiration of this Note. No class action arbitration may be brought or ordered under this Arbitration Clause and there shall be no joinder of parties, except for joinder of parties to this Note. IF EITHER YOU OR WE CHOOSE TO ARBITRATE, THE FOLLOWING WARNINGS APPLY: ALL DISPUTES BETWEEN YOU AND US WILL BE RESOLVED BY BINDING ARBITRATION; YOU WILL GIVE UP THE RIGHT TO.SEEK REMEDIES IN COURT, INCLUDING THE RIGHT TO A JURY TRIAL; YOUR ABILITY TO COMPEL OTHER PARTIES TO PRODUCE DOCUMENTS OR BE EXAMINED WILL BE MORE LIMITED IN ARBITRATION THAN IN A LAWSUIT; AND, YOUR RIGHTS TO APPEAL OR CHANGE AN ARBITRATION AWARD IN COURT WILL BE VERY LIMITED. 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 BE LIMITED TO AMOUNTS PAID BY THE DEBTOR HEREUNDER. If executed in Rhode Island: THIS IS A NON - NEGOTIABLE CONSUMER NOTE. IMPORTANT: THE TERMS AND CONDITIONS ON ALL PAGES OF THIS DOCUMENT ARE PART OF THIS NOTE. NOTICE TO BORROWER: 1. DO NOT SIGN THIS NOTE BEFORE YOU READ IT. 2. YOU ARE ENTITLED TO A COPY OF THIS NOTE. 3. YOU MAY PREPAY THE UNPAID BALANCE AT ANY TIME WITHOUT PENALTY. 4. YOU ACKNOWLEDGE THAT YOU HAVE RECEIVED, AT THE TIME OF EXECUTION, A FULLY COMPLETED COPY OF THIS NOTE. YOU ACKNOWLEDGE THAT THIS NOTE CONTAINS THE ARBITRATION CLAUSE ABOVE, AND THAT YOU HAVE READ THE CLAUSE AND UNDERSTAND AND AGREE TO IT. CAUTION - IT IS IMPORTANT THAT YOU THOROUGHLY READ THE CONTRACT BEFORE YOU SIGN IT. Borrower. Date: '� f, - I Co- Borrower: Date: Medaliion Bank, Multistate rbi-m, Hi (R =V, µ/'17I2012; HC # 4338 -;5620 1942 multistate !_E i = EP) D=0#746 Page 3 of 3 MEDALLION BANK PRIVACY POLICY Your Private Information is not for sale at Medallion Bank Medallion Bank ( "MB ") is committed to providing you, our customers, with the highest quality products and services while protecting your personal information. Providing the highest quality products and services requires us to collect, maintain and use certain personal and financial customer information about you and your activities with us. Protecting this private information, however, remains our highest priority. Forthis reason, this Privacy Policy outlines our procedures and our pledge to constantly protect the private information you have entrusted us with: We Do Not Sell Your Customer Information To Anyone We do not sell your Customer Information (described below) to anyone. We also do not disclose your Customer Information to any nonaffiliated third parties, other than as allowed by law or as described in this Privacy Policy. This means that to protect your Customer Information you do not have to "opt out" or formally request that we not disclose your Customer Information to parties that are not affiliated with MB. We may, however, sometimes disclose your nonpublic personal information to our contracted service providers and affiliates as permitted by law in an effort to better serve your needs or to provide better products or services to you. For example, we may share certain relevant Customer Information with the mailing service we contract with to print and mail monthly customer account statements to you. Please note that to protect your privacy we cannot accept or respond to communications from someone claiming to represent you, unless that person is your attorney, guardian, trustee or is otherwise authorized by law to represent you. Collection and Use of Customer Information We collect, retain and utilize information about you we believe is necessary to operate our business, to provide you with quality products and services, and to ensure the protection of your account. We obtain this nonpublic personal information (collectively, "Customer Information ") abdut you from the following sources: * Information we receive from you on applications and other forms, such as your name, address, phone number, social security number, employment, assets, income and debt; * Information about your transactions with us, our affiliates or others, such as your account balances and payment history; and * Information we receive from a consumer reporting agency, including your credit history and creditworthiness. Also, when you visit any of our websites, we may collect information to measure the use of our website and to assist us in improving the content of our site. We may also collect information from you that will permit us to offer more personalized service, which may include the use of "cookies." When you interact with our websites, our web server may send a "cookie" to your computer to allow us to help make your experience easier and more meaningful. A cookie is an electronic file that holds small items of information, but not Customer Information as described above. When you connect with our website and request to look at certain pages on the website the cookie will allow our web server to recognize your computer. Unless you choose to contact us through our website, you will remain anonymous to us as a website user. Maintaining Accurate Customer Information We have established policies and procedures to ensure that your Customer Information is accurate, current and complete. We will work to correct inaccurate Customer Information in a timely manner. If you have any reason to believe that your Customer Information is incorrect, please contact your customer service or account representafive at the toll free number listed on your account statement. We will promptly investigate the situation and, when appropriate, update our records accordingly. Protection of Information We maintain appropriate policies and procedures to protect the security of your Customer Information. All of our employees have agreed to comply with our Privacy Policy and receive training to better understand the importance of confidentiality and customer privacy. We restrict access to your Customer Information to those employees who have a business reason for using such information. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your Customer Information. Even if you decide to close your account(s) and/or repay your loan(s) or other obligation(s) or otherwise become an inactive customer, any Customer Information we have about you will remain subject to the practices described in this Privacy Policy. Customer Information We May Disclose or Share In the course of conducting our business and servicing your needs, we do not disclose any Customer Information to anyone except as permitted or required by law. To conduct our business we may disclose Customer Information to, (1) financial service providers and other financial institutions with which we may enter into joint marketing agreements from time to time, and (2) as otherwise permitted by law, under the following circumstances: Third -Parry Service Providers. We may disclose all Customer Information to third -party service providers that we have engaged to help deliver our services and products to you, and that have agreed to keep your Customer Information confidential. * Among Our Affiliates. We may share certain Customer Information about transactions and experiences with you with our affiliates. This Customer Information may include identification information, account balances, and payment history. * With Other Non - Affiliated Third Parties. In addition, we may share Customer Information about you with other non - affiliated third parties, as permitted by law. For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus. Application of Our Privacy Policy This Privacy Policy applies both during and after your customer relationship with us. In the event we revise this Privacy Policy, we will send our customers a copy of the new policy. Our former customers will also receive a copy of the new policy to the extent required by law. Please read this Privacy Policy carefully and keep it for your records. , VERIFICATION i i j The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating 1 I to unsworn falsifications to authorities, that he /she is (NAME) 7 Tar —1 1, 1 �(�SLC'eCL� �-C.o� 1�2` 9,,.D of y� }2r�s f r ' � c , Plaintiff 1 (TITLE) — r (COMPANY) herein, that he /she is duly authorized to make this verification, and that the facts set, forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. 1 A � j (SIGNATURE) s' 1 i WWR# 20145854 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - �-�,�E P� .�. � ������ Sheriff 7 A F� ; Jody S Smith 0 13 JUL Chief Deputy 12 ' Richard W Stewart C-UMBBLAND COUINTY Solicitor OUICE F THE WERI F P NS` LVAf?1A Systems&Services Technologies, Inc.As Servicing Agent For Medallion Case Number V& 2013-3690 Angela M Hilbert SHERIFF'S RETURN OF SERVICE 06/28/2013 08:59 PM-Deputy Tim Black, being duly sworn according to law, served the requested Complaint& Notice by"personally"handing a true copy to a person representing themselves to be the Defendant,to wit:Angela M Hilbert at 214 South Enola Drive, East Pennsboro, Enola, PA 17025. TIM BLACK,BLACK, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, July 05, 2013 RONIrY R ANDERSON, SHERIFF tc)CountySuite She ,Teleosoft,Inc.