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14-0615
Supreme Co " : , ennsylvania Cour f Commo leas For Prothonotary Use Only: C Ch lit Docket No: s, cunNb County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the f ling and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S S Complaint O Writ of Summons ® Petition Q Transfer from Another Jurisdiction n Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Pennsylvania State Employees Credit Union Robert K. Burns T Dollar Amount Requested: El within arbitration limits I Are money damages requested? ER Yes 0 No check one) ) outside arbitration limits N Is this a Class Action Suit? © Yes D No Is this an MDJAppeal? a Yes 0 No A Name of Plaintiff /Appellant's Attorney: SHAWN M. LONG, ESQUIRE 83774 0 Check here if you have no attorney (are a Self- Represented [Pro Se] 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 Buyer Plaintiff Administrative Agencies Malicious Prosecution © Debt Collection: Credit Card ® Board of Assessment Motor Vehicle Debt Collection: Other 0 Board of Elections El Nuisance ® Dept. of Transportation ® Premises Liability 0 Statutory Appeal: Other S n Product Liability (does not include ©Employment Dispute: E mass tort) 0 Slander/Libel/ Defamation Discrimination C El Other: [3 Employment Dispute: Other Q Zoning Board T Other: I Other: O MASS TORT ® Asbestos N ® Tobacco r] Toxic Tort -DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS © Toxic Waste ® Other: ®Ejectment ®Common Law /Statutory Arbitration B ® Eminent Domain/Condemnation [3 Declaratory Judgment El Ground Rent ® Mandamus © Landlord/Tenant Dispute ® Non - Domestic Relations © Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY [3 Mortgage Foreclosure: Commercial 13 Quo Warranto ® Dental ® Partition El Replevin Legal 0 Quiet Title 0 Other: Medical © Other: Other Professional: i Updated 1/112011 laE. j " r l, J1 a� 1�i 1N3/ 4,H 0 t PEt'�SYCa � A y BARLEY SNYDER ' 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 IN THE COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaint f CIVIL ACTION - LAW V. ACTION IN REPLEVIN ROBERT K. BURNS, No. Defendant 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. C K) n1 � /� a- 4181246 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 Effective September 1, 2003 4181246 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 IN THE COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaints CIVIL ACTION - LAW V. ACTION IN REPLEVIN ROBERT K. BURNS, No. Defendant AVISO PARA DEFENDER Conforme a RCP No. 1018,1 del PA LE RAN 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. 4181246 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 INFORMACI6N SOBRE EMPLEAR A un ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACI6N SOBRE LAS AGENCIAS QUE LOS SERVICIOS JURiDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES EN Un HONORARIO REDUCIDO O NINGUN HONORARIO. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 C Efectivo I de Septiembre, 2003 Queja 4181246 BARLEY SNYDER 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 IN THE COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff' CIVIL ACTION - LAW V. ACTION IN REPLEVIN ROBERT K. BURNS, No. 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, Robert K. Burns, is an adult individual with a last known address of 402 Pawnee Drive, Mechanicsburg, PA 18050 -2546. 3. On or about September 1, 2006, Defendant entered into a Loanliner Advance Proceeds Voucher and Security Agreement (the "Agr�ment ") with Plaintiff for the purchase of . a 2006 Chrysler 300, VIN #2C3KA43R36H366549 (the "Vehicle "). A true and correct copy of the Agreement is attached hereto as Exhibit "A" and incorporated herein by reference. 4181246 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 Agreement by failing to make monthly payments when due beginning March 1, 2013 and on the first (1 st) day of each month thereafter. 6. Pursuant to the Agreement, 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 December 12, 2013 (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 Agreement, Plaintiff is entitled to immediate possession of the Vehicle. 10. The present fair market wholesale value of the Vehicle is approximately $6,650.00. 11. Upon information and belief, the Defendant has possession and control of the Vehicle at 402 Pawnee Drive, Mechanicsburg, PA 18050 -2546. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, demands judgment in replevin against Defendant, Robert K. Burns, for possession of the Vehicle, plus 4181246 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 $8,094.60. 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. 4181246 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment in its favor and against Defendant, Robert K. Burns, in the amount of $8,094.60, and costs of suit. BARLEY S D R By: S awn ong, Esquir ourt I.D. 83774 126 East King Street Lancaster, PA 17602- 893 717.299.5201 Attorneys for Plaintiff 4181246 EXHIBIT "A" 4181246 1 liaT 1 y S Pennsylvania State �® Employees Credit Union P. O. Box 67013 ADVANCE PROCEEDS VOUCHER Harrisburg, PA 17106 -7013 717.234.8484 AND SECURITY AGREEMENT 800 .237.7328 MEMBERNAME. 4 � DATa� =*. ;FfaEtfiGecpVN707naE r _• i�:'s" NOTEPTU ROBERT K BURNS 9/1/2006 1101111�I UUVj 50 510 RIDGEVIEW DRIVE DILLSBURG, PA 17019 PURPOSE: Dealer Purchase T ON 1 ❑ NEW LOAN 2 ❑ LOAN ADVANCE S. � (DESCRIBE) 4. ❑ EOURY ADVANCE DISBURSEMENT BRE AKDOWN AND REPA YMENT YOU HAVE PREVIOUSLY ELECTED TO HAVETHIS ADVANCE CREDIT DISABILITY SINGLE CREDIT LIFF JOINT N FEv INSURED WITH THE FOLLOWING COVERAGE YES El NO. YES El NO U YES R L L � I DAILY PER'oOIC RATE ANNUAL PER- INTEREST RATE IS AMOUNT REQUESTED AMOUNT ADVANCED PREVIOUS BALANCE NEW BALANCE (CHANGEINTERMSONLY) CENTACE RATE FIXED VARIABLE. +OTHER CHARGES �g "•�� '+ _ 0177808 6.490 % [] 24, 994.58- 2;QY_9; 4:s� 8.� 0.00 24, 994.58 r . t. PAYMENT DUE DATE PAYMENT FREQUENCY PROJECTED LOAN TERM 371.07 10/1/2006 Monthly O FFERED SECURITY IFTHIS IS A HOME EQUITY ADVANCE, THE ONLYSECURITY FOR THIS ADVANCE IS THE REAL PROPERTY (IN MOST CASES YOUR HOME) WHICHYOU GAVE AS SECURITY WHEN YOUR ACCOUNT WAS ESTABLISHED. IF THIS Is NOTA HOME EQUITY ADVANCE, IN ADDITION TO THE PLEDGE OF SHARES.IN YOUR LOANLINER' CREDIT AGREEMENT, THE FOLLOWING PROPERTY SECURESTHIS ADVAN ITEM PROPERTY'. ro CHRYSLER 0 2006 2 SDN 25,380.00 2. 3. 4. OTHER YOU PLEDGE SHARES AND/OR DEPOSITS OF $ IN ACCOUNT NUMBER OLD ACCOUNT(LOAN NUMBER (A ) PAYOFF (PRINC. + INT.) OLD A06OUNTILOAN NUMBER (B) PAYOFF (PRINC. +INT ) OLD ACCOUNTILOAN NUMBER (C ) PAYOFF (PRINC.+ INT.) OLD ACCOUNTILOAN. NUMBER (D) PAYOFF (PRINC.+ INT.) OLD ACCOUNTAAAN NUMBER (E) PAYOFF (PRINC.+ INT.) OLD ACCOUNTILOAN NUMBER (F) PAYOFF PRINC .+I By accepting the proceeds or by using the funds advanced and deposited into your share/share draft account, you agree (1) that the property referenced above will secure the advance and any other advances you have now or receive in the future under the LOANLINER° Credit and Security Agreement (the Plan) and any other amounts you owe us for any reason now or in the future In accordance with the terms of the Plan and (2) to matte payments as disclosed above in accordance with the terms of the Plan. 0 CU.VAMUTUAL GROUP, 1980, 82, 84, 88, 89,98.99, 2000, 0t,04, MALL RIGU98 RESERVED PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM #3176 JVXX010D -1 037 - 2082 -1 (8100) COM LILIr—M PSECO Pennsylvania State Employees Credit Anion P.O. Box 67013 O Harrisburg, PA 171 06 -7013 6 (7f 7) 234 -8484 Harrisburg, (800) 237 -7328 Nationwide Loan Disciosures Iv i t This LOANLINER° Credit and Security Agreement, which includes the Truth in CREDIT INSURANCE — Credit life and /or credit disability insurance is optional Lending Disclosures, will be referred to as the Plan. The Plan documents include this under the Plan. If you quality for and purchase the insurance from us, you authorize agreement and an Addendum. You, your and borrower mean any person who signs us to add the Insurance premiums monthly to your loan balance and charge you the Plan. Credit union, we, our and us mean PSECU or anyone to whom the Credit interest on the entire balance. If you elect credit insurance, your payments may Union transfers its rights under the Plan. increase or the period of time necessary to repay your advance may be extended. HOW THIS PLAN WORKS — This is an open -end, multi- featured credit plan. We The credit insurance rates may change during the Plan. If the rates change, we will anticipate that, from time to time, you will borrow money (called "advances ") under provide any notices required by applicable law. the Plan. We are not required to make advances to you under the Plan and can PERIODIC STATEMENT— On a regular basis you will receive a statement showing refuse a request for an advance at any time. The Addendum describes the all transactions under the Plan during the period covered by the statement. different types of credit (called "subaccounts ") available under the Plan, the current Statements and notices will be sent to you at the most recent address you have Interest rate for each subaccount expressed as a daily_ periodic rate and given us in writing. Unless applicable law requires notice to each joint borrower, corresponding annual percentage rate and other charges. It may also have other notice to any one of you will be notice to all. terms and a schedule for determining the payment amounts. JOINT ACCOUNTS — If this is a joint account, each of you Is individually and jointly CREDIT LIMIT — We may, but do not have to, establish a credit limit on certain responsible for paying all amounts owed. That means we can enforce our rights subaccounts. If a credit limit is set for a subaccount, you promise not to exceed the under the Plan against any one of you individually or against all of you together. It you established credit limit. If you exceed the credit limit, you promise to repay give us inconsistent instructions, we can refuse to follow your Instructions. Unless our immediately the amount which exceeds the credit limit. written policy requires all of you to sign for an advance, each of you authorizes the REPAYMENT — You promise to repay all amounts you owe under the Plan plus other(s) to obtain advances individually and agrees to repay advances made to the interest. Payments are due on the last day of the month unless we set a different day other(s). Any joint accountholder may terminate the Plan by giving us prior written at the time of an advance. If the Addendum has no payment schedule for a notice. If any of you terminate the Plan, the Plan is terminated for all of you. You subaccount, your payment will be determined at the time of each advance. remain liable individually and jointly for all advances incurred before termination. Payments must include any amount past due and any amount by which you have FEES AND CHARGES — if you give us a security interest in certain types of exceeded any credit limit you have been given for a subaccount. You may repay all property, we may charge you a filing fee to perfect our interest in the property. If we or part of what you owe at any time without any prepayment penalty, Even if you do, the amount of the fee will be disclosed to you at the time you obtain an advance. prepay, you will still be required to make the regularly scheduled payments unless We may also charge you other fees In connection with the Plan. Our current fees are we agree in writing to a change In the payment schedule. If you have a joint disclosed on the Addendum and will be added to your loan balance unless you pay sharedraft account, you will be responsible for paying all overdraft advances them in cash. obtained by a joint holder of the sharedraft• account. Unless otherwise required by UPDATING CREDIT INFORMATION — You promise that you will promptly give us law, payments will be applied to amounts owed under the Plan, in the manner the written notice if you move, change your name or employment, or if any other Credit Union chooses. information you provided to us changes. Upon our request, you also agree to PLAN ACCESS —You can obtain credit advances in any manner authorized by us. If provide us updated financial information. we allow you to use your ATM /Debit card to access the Plan, you may be liable for the DEFAULT — The following paragraph applies to borrowers in Idaho, Kansas, unauthorized use -of your ATM/Debit card. You will not be liable for unauthorized use Maine and South Carolina: You will be in default if you do not make a payment of that occurs after you notify us, orally or In writing, of the loss, theft, or possible the amount required when it is due. You will also be in default if we believe the unauthorized use. If you believe your ATM /Debit cans has been lost or stolen, prospect a Property as security immediately inform the Credit Union by calling or writing us at the telephone number or p p ect of payment, ment, rformance, or realization on any p p ert y g lven address that appears elsewhere in the Plan. If the card is used to obtain unauthorized is significantly Impaired, advances directly from the Plan, your liability will not exceed $50. If the unauthorized The following paragraph applies only to borrowers In Wisconsin: You will be In withdrawal is from a sharedraft account, your liability is governed by the Regulation E default if you fail to make a payment when due two times during any 12 month disclosures you received at the time you received your ATM /Debit card, even if the period, You will be In default if breaking any promise made under the Plan materially withdrawal results in an advance being made from your overdraft subaccount. Impairs your ability to repay what you owe or materially impairs the condition, value, FINANCE CHARGE — The dollar amount you pay for money borrowed is called a or protection of or our right in any property you gave as security. "Finance charge" and begins on the date of each advance. A finance charge will be The following paragraph applies only to borrowers in Iowa: You will be in computed separately for each separate balance under the Plan. To compute the default if you are more than 10 days late in making a payment, You will also be in finance charge, the unpaid balance for each day since your last payment (or since default if you do not comply with the terms of the Plan and your failure to comply an advance if you have not yet made a payment) is multiplied by the applicable dally materially impairs any property you gave as security or your ability to repay what you periodic rate. The sum of these amounts is the finance charge owed. The balance owe under the Plan. used to compute the finance charge is the unpaid balance each day after payments The following paragraph applies to borrowers in all other states: You will be in and credits to that balance have been subtracted and any additions to the balance default if you do not make a payment of the amount required when it is due. You will have been made, in addition to interest, we may charge other finance charges which be in default If you break any promise you made under the Plan or if anyone is In are disclosed on the Addendum. If the interest rate is a variable Interest rate, the default under any security agreement made in connection with an advance under Addendum explains how the variable interest rate works, the Plan. You will be in default if you die, file for bankruptcy, become insolvent, if you SECURITY —You pledge as security for the Plan all shares and dividends and, if any, make any false or misleading statements In any credit application or update of credit all deposits and interest in all joint and Individual accounts you have with us now and information, or if something happens we believe may substantially reduce your in the future. If a specific dollar amount is pledged for an advance, we will freeze ability to repay what you owe. You will be in default if any property you have given shares in that account to the extent of the outstanding balance for the advance. us as security is repossessed by someone else, seized under a forfeiture or similar Otherwise, your pledged shares may be withdrawn unless you are in default. The law, or if anything else happens that significantly affects the value of the property or following paragraph applies in all states except in Ohio, Rhode Island and our security interest in it. You will also be in default under the Plan If you are In default Massachusetts: We have a statutory lien on the shares .and dividends and, if any, the under any other loan agreement with u& deposits and interest in all individual and joint accounts you have with us and may ACTIONS AFTER DEFAULT — The following paragraph applies to borrowers in exercise our rights under the lien to the extent permitted by state law, (We are state Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, chartered if our name does not include the term "Federal Credit Union ") For all Nebraska, South Carolina and West Virginia: When you are in default and after borrowers: The statutory lien and /or your pledge will allow us to apply the funds expiration of any right you have under applicable state law to cure your default, we can in your account(s) to what you owe when you are in default, The statutory lien and demand Immediate payment of the entire unpaid balance under the Plan without your pledge do not apply to any Individual Retirement Account or any other account giving you advance notice. that would lose special tax 4reatmerit under state or federal law if given as. security. Additional security for the Plan may be required at the time of an advance. If a following paragraph applies to borrowers e all e except Wisconsin subaccount identifies a type of property (such as "New Cars ") you must give that and d Louisiana: When you are i default, can n require i mmediate payment type of property as security when you get an advance under that subaccount. A (acceleration) of the entire unpaid balance under the Plan. You waive any right you have . to demand for payment, notice of intent to accelerate and notice of acceleration. subaccount name such as "Other Secured" means you must provide security acceptable to us when you obtain an advance under that subaccount. Property you The following paragraphs apply to borrowers in all states except Wisconsin and give as security will secure all amounts owed under the Plan and all other loans you Louisiana: If immediate payment is demanded, you will continue to pay Interest until have with us now or in the future, except any loan secured by your principal dwelling. what you owe has been repaid at the applicable interest rates in effect or, if applicable, Property securing other loans you have with us may also secure the Plan. © CUNA MUTUAL GROUP, 1960, 2006. ALL BIGHTS RESERVED CPSM01 - PSECU FORM #3146 I JBXX0601 -2 037 - 2092 -1 (8106) F at ANLINER° Credit and Security Credit Agreement (continued) ability to exercise our rights later. We can enforce this Plan against your heirs or he default rate disclosed on the Addendum. If a demand for immediate payment legal representatives. If we change the terms of the Plan, you agree that this Plan as beep made, your shares and/or deposits can be applied towards what you owe. will continue to protect us. as provided in the section above called "Security." We can also exercise any other CONTINUED EFFECTIVENESS — If any part of this Plan is determined by a court rights given by law when you are in default. to be unenforceable, the rest will remain in effect. You agree the Credit Union has the right to take possession of any property given NOTICE TO UTAH BORROWERS — This written agreement is a final expression of as security under the Plan, without judicial process, if this can be done without the agreement between you and the Credit Union. This written agreement may not breach of the peace. If we ask, you promise to deliver the property at a time and be contradicted by evidence of any oral agreement. place we choose. If the property is a motor vehicle or boat, you agree that we may The following is required by Vermont law — NOTICE TO CO-SIGNER — YOUR obtain a key or other 'device necessary to unlock and operate it, when you are in SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE default. We will not be responsible for any other property, not covered by this Agreement, that you leave inside the property or that is attached to the property. We FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, will try to return that property to you or make it available for you to claim. THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. After we have possession of the property, we can sell it and apply the money to any The following paragraphs apply If you give security in connection with an amounts you owe us. We will give you notice of any public disposition or the date after advance under the Plan. They apply to borrowers in all states except Louisiana. which a private disposition will be held. Our expenses for taking possession of and Louisiana borrowers will execute a separate security agreement, Borrowers in selling the property will be deducted from the money received from the sale. Those other states may also be asked to execute a separate security agreement. costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded under the Bankruptcy Code. THE SECURITY FOR THE PLAN — You give us what is known as a security You must pay any amount that remains unpaid after the sale money has been applied interest in all property described in any receipt, voucher or other document you to any unpaid balance under the Plan. You agree to pay interest on that amount at the receive for , A advance ('the Advance"). The security interest you give includes all same rate as the advance, or, if applicable, at the default rate disclosed on the accessions. Accessions are things which are attached e a installed in the property Addendum, until that amount has been paid. now or in the future. The security interest also includes any replacements for the property which you buy within 10 days of the Advance or any extensions, renewals The following paragraph applies only to Wisconsin borrowers: When you are in or refinancing of the Advance. It also includes any money you receive from selling default and after expiration of any right you have under applicable, state law to cure your the property or from insurance you have on the property. If the value of the property default, we may require immediate payment of your outstanding loan balance under the declines, you promise to give us more property as security if asked to do so. Plan and seek possession of property given as security. You may voluntarily give the WHATTHE SECURITY INTEREST COVERS /CROSS COLLATERAL PROVISIONS property to us if you choose, or we may seek to take possession of the property by — The security interest secures the Advance described in the receipt, voucher or any judicial process, if we repossess the property, you agree to pay reasonable expenses other document you receive at the time of the Advance and any extensions, renewals incurred in disposing of the property. If the property is a motor vehicle, mobile home, or refinancings of the Advance. It also secures any other advances you have now traller, snowmobile, boat or aircraft, you will also be required to pay any costs permitted or receive in the future under the Plan and any other amounts or loans, by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains including any credit card loan, you owe us for any reason now or in the future, unpaid after the sale money has been applied to what you owe under the Plan. You except any loan secured by your principal residence. If the property is household agree to pay interest on any unpaid amount at the same rate as the advance, or, If goods as defined by the Federal Trade Commission Credit Practices Rule, the applicable, at the default rate disclosed on the Addendum, until that amount is paid. property Will secure only the Advance and not other amounts you owe. If the property is located outside Wisconsin at the time of default, we may take OWNERSHIP OF THE PROPERTY — You promise that you own all property you possession of the property without judicial process, if permitted by the state where give as security or if the Advance is to buy the property, you promise you will use the property is located. the Advance for that purpose. You promise that no one else has any interest in or The following paragraph applies only to Louisiana borrowers: When you are in claim against the property that you have not already told us about. You promise not default, we can require immediate payment (acceleration) of the entire unpaid to sell or lease the property or to use it as security for a loan with another creditor balance under the Plan. You waive any right you have to demand for payment, notice until the Advance is repaid. You promise you will allow no other security interest or of intent to accelerate and notice of acceleration. If immediate payment Is lien to attach to the property either by your actions or by operation of law. demanded, you will continue to pay interest until what you owe has been repaid at PROPERTY INSURANCE, TAXES AND FEES —You must maintain property the applicable interest rates in effect unless a default rate is disclosed on the Insurance on all property that you give as security under the Plan. You may purchase Addendum. If a demand for immediate payment has been made, the shares and the property insurance from anyone you choose who is acceptable to the Credit deposits given as security for the Plan can be applied towards what you owe. We Union. The amount and coverage of the property insurance must be acceptable to can also exercise any other rights given by law when you are in default and our us. You may provide the property insurance through a policy you already have, or rights under any security agreements you have with us. through a policy you get and pay for. You promise to make the insurance policy CANCELLING OR CHANGING THE PLAN — The following paragraph applies payable to us and to deliver the policy or proof of coverage to us if asked to do so. only to borrowers in Illinois: We have the right to change the terms of the Plan from If time to time after giving you any advance notice required by law. Any change to the you cancel your insurance and get a refund, we have a right to the refund. If the property is lost or damaged, we can use the insurance settlement to repair the Interest rate or other charges will apply to future advances. property or apply it towards what you owe. You authorize us to endorse any draft or The following paragraph applies only to borrowers in tsconsin: We can check which may be payable to you In order for us to collect any refund or benefits change the terms of the Plan from time to time In accordance with Section 422.415 due under your insurance policy. You also promise to pay all taxes and fees (like of the Wisconsin Statutes. You will be notified of any change in terms. An increase registration fees) due on the property. in the daily periodic rate under a variable rate interest rate is not considered a if you do not pay the taxes or fees on the.property when .due or keep it insured, we may change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any time by giving us prior written pay these obligations, but we are not required to do so. Any money we spend for taxes, notice. Your obligation to pay the unpaid balances under the terms of the Plan fees or insurance will be added to the unpaid balance of the advance and you will pay continues whether you or the credit union cancel the Plan, except to the extent that interest on those amounts at the same rate you agreed to pay on the advance. We may your liability is limited by Section 422.4155 of the Wisconsin Statutes. receive payments in connection with the insurance from a company which provides the insurance. We may monitor our loans for the purpose of determining whether you and The following paragraph applies only to borrowers in Iowa: We can change the other borrowers have complied with the insurance requirements of our loan agreements terms of the Plan from time to time after giving you any advance notice required by or may engage others to do so. The Insurance charge added to an advance may include ` law. A change that increases the rate of finance charge or other charge, that (1) the insurance company's payments to us and (2) the cost of determining compliance increases the amount of your payments, or that otherwise adversely affects existing with the insurance requirements. If we add amounts for taxes, fees or Insurance to the balances will apply to existing balances only If you agree to the change or you use unpaid balance of an advance, we may increase your payments to pay the amount the Plan after receiving notice that your use of the Plan means you agree the added within the term of the Insurance or approximate term of the advance. change applies to existing balances. The following paragraph app lies to borrowers in all other states. We have the INSURANCE NOTICE ur If you do not purchase the required property insurance, right to change the terms of the Plan from time to time after giving you any advance the insurance we may purchase and charge you for will cover only our interest in the property. The premium for this insurance may be higher because the insurance notice required by law. Any change in the interest rate will apply to future advances, company may have given us the right to purchase insurance after uninsured and at our discretion and subject to any requirements of applicable law, will also collateral is lost or damaged, The insurance will not be liability insurance and apply to unpaid balances. will not satisfy any state financial responsibility or no fault laws. The following paragraph applies to all but Wisconsin borrowers: An increase In PROTECTING THE SECURITY INTEREST — If your state issues a title for the the daily periodic rate under a variable Interest rate is not considered a change In property, you promise to have our security interest shown on the title. We may have terms under the Plan. We can cancel the entire Plan or any part of the Plan at any to file what is called a financing statement to protect our security interest from the time.. You may cancel the Plan at any time.by giving us prior written notice. Your claims of others. if asked to do so, you promise to sign a financing statement. You obligation to pay the unpaid balances under the terms of the Plan continues whether also promise to do whatever else we think is necessary to protect our security you or the Credit Union cancel the Plan. Interest In the property. You promise to pay all costs, including but not limited to any DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN — We can delay attorney fees, we incur in protecting our security interest and rights in the property, enforcing any of our rights under this Plan any number of times without losing the to the extent permitted by applicable law. Fthe 9 Credit and Security Credit Agreement (continued) penalty for unlawful failure to return a motor vehicle is one year in prison and /or a OPERTY — Until the Advance has been paid off, you promise you will: fine of $150,000. property carefully and keep it in good repair: (2) Obtain our written For those members who purchase a vehicle. under the before making major changes to the property or changing the address operty is kept. (3) Inform us in writing before changing y our address. (4) . DRIVe Program, please review the following FTC Notice: inspect the property. (5) Promptly notify us if the property is damaged, stolen or abused. (6) Not use the property for any unlawful purpose. (7) Not to retitle NOTICE property in another state without telling us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT — THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH REPOSSESSION. IF IT IS REPOSSESSED AND SOLD TO SOMEONE ELSE THE DEBTOR COULD ASSERT AGAINST THE SELLER AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. OF GOODS OR SERVICES OBTAINED WiTH THE NOTICE FOR ARIZONA OWNERS OF PROPERTY — It is unlawful for you to fail PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE to return a motor vehicle that is subject to a security interest, within thirty days after DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE you have received notice of default. The notice will be mailed to the address you DEBTOR HEREUNDER. gave us, It is your responsibility to notify us if your address changes. The maximum This notice contains Important Information about your rights and our responsibilities After we receive your letter, we cannot try to collect any amount you question, or report under the Fair Credit Billing Act. You are advised to read your monthly statement you as delinquent. We can continue to send statements to you for the amount you and review it for any error discrepancies or unauthorized transactions. question, including finance charges, and we can apply any unpaid amount against your NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR credit limn. You do not have to pay any questioned amount while we are investigating, STATEMENT. If you think your statement is wrong, or if you need more information but you are still obligated to pay the parts of your statement that are not in question. about a transaction on your statement, write us on a separate sheet at the address If we find that we made a mistake on your statement, you will not have to pay any . listed on your statement, You are required to notify us in writing within 60 days finance charges related to any questioned amount. If we didn't make a mistake, you following the date on which we sent your statement wherein the error or problem may have to pay finance charges, and you will have to make up any missed first appeared regarding any discrepancy or unauthorized transactions on your payments on the questioned amount. In either case, we will send you a statement account. Failure to notify us may result in your acceptance of any responsibility for of the amount you owe and the date that it is due. payment or reimbursement to us for any such error or discrepancy on your account. If you fall to pay the amount that we think you owe, we may report you as delinquent, Write to us as soon as possible. You can telephone us, but doing so will not However, if our explanation does not satisfy you and you write to us within ten days preserve your rights. telling us that you still refuse to pay, we must tell anyone we report you to that you In your letter, give us the following information: have a question about your statement. And, we must tell you the name of anyone Your name and account number, we reported you to. We must tell anyone we report you to that the matter has been The dollar amount of the suspected error. settled between us when it finally is: Describe the error and explain, if you can, why you'believe there is an error. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your statement was correct. If you need more information, describe the Item you are not sure about. SPECIAL RULE FOR CREDIT CARD PURCHASES — If you have a problem with It you have authorized us to pay a credit card account automatically from your share the quality of property or services that you purchased with a credit card, and you account or checking account, you can stop the payment on any amount you think is have tried in good faith to correct the problem with the merchant, you may have the wrong. To stop the payment your fetter must reach us three business days before the right not to pay the remaining amount due on the property or services. There are two automatic payment is scheduled to occur. limitations on this right: (a) You must have made the purchase in your home state or, YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR if not within your home state, within 100 miles of your current mailing address; and WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we (b) The purchase price must have been more than $50. have corrected the error by then. Within 90 days, we must either correct the error or These limitations do not apply if we own or operate the merchant, or if we mailed explain why we believe the statement was correct, you the advertisement for the property or services. In this Agreement, the words you and your means each and all of those who apply Line only by written application to us, which must be approved by our credit committee for the card or who signs this Agreement. Card means the Visa Credit Card and any or loan officer. By giving you written notice we may reduce your Credit Line from time duplicates and renewals we issue. Account means your Visa Credit Card Line of to time, or with good cause, revoke your card and terminate this Agreement. Good Credit account with us. We, us, and ours means this Credit Union. cause includes your failure to comply with this Agreement or any other agreement with 1. RESPONSIBILITY— If we issue you a card, you agree to repay all debts and the us, or our adverse reevaluation of creditworthiness. You may also terminate this Finance Charge arising from the use of the card and the card account. For example, Agreement at any time, but termination by either of us does not affect your obligation you are responsible for charges made by yourself, your spouse and minor children, to pay the account balance. You are also responsible for charges made by anyone else to whom you give the 5. CREDIT INFORMATION — You authorize us to investigate your credit standing card, and this responsibility continues until the card is recovered. You cannot disclaim when opening, renewing or reviewing your account, and you authorize us to disclose responsibility by notifying us, but we will close the account for new transactions if you information regarding your account to credit bureaus and other creditors who Inquire so request and return all cards. Your obligation to pay the account balance continues of us about your credit standing. even though an agreement, divorce decree or other court judgment to which we are 6. MONTHLY PAYMENT — We will mail you a statement every month showing your not a party may direct you or one of the other persons responsible to pay the account. Previous Balances of purchases and cash advances, the current transactions on your The cards remain our property and you must recover and surrender to us all cards account, the remaining credit available under your Credit Line, the New Balances of upon our request and upon termination of this Agreement. purchases and cash advances, the Total New Balance, the Finance Charge due to -date, 2. LOST CARD NOTIFICATION — If you believe the card has been lost or stolen, and any other billed fees, and the Minimum Payment required. Every month you must pay you will immediately call the Credit Union at (717) 234 -8484 or (800) 237 -7328. After at least the Minimum Payment within 25 days of your statement closing date. By separate hours call (800) 556 -5678, agreement you may authorize us to charge the minimum payment automatically to your share or checking account with us. You may, of course, pay more frequently, pay more 3. LIABILITY FOR UNAUTHORIZED USE —You agree to notify us immediately, orally than the Minimum Payment, or pay the. Total New Balance in full, and you will reduce the or in writing of the loss, theft or unauthorized use of your Credit Card. You may be liable finance charge by doing so. If your monthly payment exceeds the total credit line balance for the unauthorized use of your Credit Card. You will not be liable for unauthorized use owed, we will automatically post the credit to your St shares. that occurs after you notify us of the loss, theft, or possible unauthorized use. You will have The minimum payment will be (a) 2 % of your Total New Balance, rounded up to the no liability for unauthorized purchases made with your Credit Card, unless you are grossly negligent in the handling of your Card. In any case, your liability will not exceed $50. next even dollar, or (b) $20.00, whichever is greater. In addition, at any time your Total New, Balance exceeds your Credit Line, you must Immediately pay the excess upon our 4. CREDIT LINE — If we approve your application, we will establish a self- demand. We will apply payments'in the following manner: first to previous late fees, replenishing Line of Credit for you and notify you of its amount when we issue the then to previous cash advances finance charges, then to previous purchase finance card. You agree not to let the account balance exceed this approved Credit Line. Each charges, then to current late fees, then to previous cash advance balances, then to payment you�make on the account will restore your Credit Line by the amount of the previous purchase balances in the order that they were posted to your account, then payment which Is applied to the principal. You may request an increase in your Credit to current cash advance balances, and then to current purchase balances. ..Visa' Credit Card Agreement and Truth In Lending Disclosure (continued) be returned with the statement, You will retain a copy of such slips furnished at the time of the transaction in order to verify the monthly statement. The Credit Union may 7. FINANCE CHARGES — You can avoid the Finance Charge on purchases'by make a reasonable charge for photocopies of slips you may request. paying the full amount of the New Balance of Purchases each month within 25 days 10. OVERDRAFT OPTION — If you elect to overdraft to your PSECU Visa Credit of your statement closing date. Otherwise, the New Balance of Purchases, and the Card, that election is subject to the existing credit limit and the agreement it represents subsequent purchases from the date they are posted to your account, will be subject and the current loan policy at the time of the overdraft. You also understand that an to Finance Charge. Cash advances are always subject to Finance Charge from the overdraft will be considered the same as a cash advance on your PSECU Visa Credit date they are posted to your account. Card and that the current Annual Percentage Rate for cash advances will apply. Purchases: We calculate your finance charge by multiplying the average adjusted 11, RETURNS AND ADJUSTMENTS— Merchants and o' 'hers who honor the card daily balance (see explanation below), including new purchases, for the billing cycle may give credit for returns and adjustments, and they will do so by sending us a by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE credit sfip which we will post to your Visa line of credit. If your credit and payments RATE as disclosed on the Addendum. exceed what you owe us, we will automatically post the excess credit balance to . Cash Advances: We calculate your finance charge on cash advances by your S1 Shares within 75 days. If the balance is one dollar or more, upon your multiplying the average adjusted daily balance (see explanation below) for cash written request, we will refund the credit balance to you. advances during the billing cycle by the monthly periodic advance rate and 12, FOREIGN TRANSACTIONS — The exchange rate between the transaction corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. currency and the billing currency used for processing international transactions is a rate Balance Computation Method selected by Visa from the range of rates available in wholesale currency markets for the Average Daily Balance for Purchases - The Average Daily Balance for Purchase applicable central processing date, which rate may vary from the rate Visa itself Transactions is calculated by adding the Daily Balances. (Purchase Transaction) for receives, or a government- mandated rate in effect for the applicable central processing each day in the billing cycle, and then dividing by the number of days in the billing date. In each instance, an adjustment may be assessed based on the iSA fee imposed cycle. To calculate the Daily Balance for purchases each day, we take the following by Visa. This fee, which totals 1 % of the transaction amount, will be assessed on all steps: We take the outstanding balance (all amounts you owe) at the start of the day. transactions where the merchant country differs from the country of the card Issuer. Then, in the sequence in which amounts are posted to your account, we add the 13. SPECIAL RULES FOR VISA PURCHASES — If you disagree or find an error amounts of all debits and subtract the amounts of all credits or payments which post with a Visa transaction, and have tried in good faith to correct the problem with the to your account that day. After applying payments and credits, we subtract the merchant or the charges are the result of unauthorized or fraudulent use, or your amount of any unpaid Finance Charges or Late Charges. Then we also subtract the purchase cost more than $50 and was made from a plan merchant in your state amount of any Cash Advance transactions that posted to your account on that day or within 100 miles of your home, contact PSECU. In any previous day in the billing cycle. This gives us the Daily Balance for purchases. 14, DISPUTED TRANSACTIONS — You are required to notify PSECU In writing Average Daily. Balance for Cash Advances - Cash Advance Transactions which are within 60 days following the date on which we sent your statement wherein the error posted to your account are not included in the Average Daily Balance calculation for or problem first appeared regarding any discrepancy or unauthorized transaction on purchases, and are therefore not subject to the monthly periodic rate for purchases. The your account. Telephoning PSECU does not preserve your dispute rights.,You may Average Daily Balance is calculated separately for Cash Advances and is subject to the be required to provide us with documentation to support your dispute claims, In Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions addition, you may be required to complete a standard dispute form outlining the is calculated by adding the Dally Balances (Cash Transaction) for each day in the billing details of your dispute. In cases of fraudulent card use, PSECU will also require a cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily notarized affidavit. In some cases we may ask you to notify the local authorities. Balance for cash each day, we take the following steps: We take the outstanding balance If we do not receive the proper requested documentation in the time specified you (all amounts you owe) at the start of the day, Then, in the sequence in which amounts may be held responsible for the transaction(s) in question. PSECU must adhere to are posted to your account, we add the amounts of all debits and subtract the amounts strict dispute timeframes set forth by Visa. of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. 15. SECURITY INTEREST — To secure your account, you grant us a purchase Then we also subtract the amount.of any Purchase Transactions that posted to your money security interest under the Uniform Commercial Code in any goods you account on that day or in any previous day in. the billing cycle. Thls gives us the Daily purchase through the account. If you default, we will have the right to recover any of Balance for Cash Advance Transactions. Note: Cash Advances are always subject to these goods which we have not been paid for through our application of your finance charges and from the day they are posted to your account. payments in the manner described in the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have if you are in Payments are applied in the following manner: first to previous late fees, then to default to prevent withdrawal of your unpledged credit union shares (Deposits) previous cash advances finance charges, then to previous purchase finance below the unpaid balance of your account. However, if you give or have given us a charges, then to current late fees, then to previous cash advance balances, then to specific pledge of your credit union shares (Deposits) by signing the Pledge of previous purchase balances in the order that they were posted to your account, then Shares or otherwise, or any other security interests for all your debts, your account to current cash advance balances, and then to current purchase balances. Credits will be secured by your pledged shares (Deposits) and by the property described in are applied first to the particular type of debt which is being credited, if any, and then those other security agreements, except for your home. to the balance of your - account. 16. EFFECT OF AGREEMENT — This Agreement is the contract which applies to Note also that if the total of the payments and credits which are posted to your all transactions on your account even though the sales, cash advance, credit or account by the Payment Due Date shown on a statement is equal to or exceeds the other slips you sign or receive may contain different terms. We may amend the New Balance shown on that statement, we will not apply the Monthly Periodic Rate Agreement from time to time by sending you the advance written notice required by to your Account on your next statement. law. -Your use of the card thereafter will indicate your agreement to the amendments. B. DEFAULT —You will be in default if you fail to make any Minimum Payment within To the extent the law permits, and we indicate In our notice, amendments will apply 25 days after your monthly statement closing date. You authorize us to transfer funds to your existing account balance as well as to future transactions. sufficient to make the minimum payment due If your Visa loan is in default. You will 17. LATE PAYMENT CHARGE — If your Minimum Payment is not received by the also be in default if your ability to repay us is materially reduced by a change in your first day of the month following your due date, you will be subject to a $20 charge. employment, an increase in your obligations, bankruptcy or insolvency proceedings 16. RUSH FEES — You may incur additional charges for rush processing and rush involving you, your death or your failure to abide by this Agreement, or if the value of delivery of cards and/or PIN mailer. our security interest materially declines. We have the right to demand immediate payment of your full account balance if you default, subject to our giving you any 19. OVER LIMIT FEE — A$ 20 fee will be applied for each monthly statement closing date notice required by law. To the extent permitted by law, you will also be required to pay on which the outstanding balance exceeds the assigned credit limit by more than $100. our collection expenses, Including court costs and reasonable attorney fees. 20. DRAFT COPIES — You may incur an additional charge for transaction 9. USING THE CARD — To make a purchase or cash advance, there are two summary /sale draft documentation. alternative procedures to be followed. One is for you to present the card to a 21. COPY RECEIVED —You acknowledge receipt of a copy of this Agreement. participating Visa plan merchant, or another financial institution, and sign the sales 22. ILLEGAL TRANSACTIONS PROHIBITED — You agree that you will not use or cash advance draft which will be imprinted with your card. The other is to complete your card for any transaction that is illegal under applicable federal, state, or local law, the transaction by using your Personal Identification Number (PIN) in conjunction with the card In an Automated Teller Machine or other type of electronic terminal that 23. NO USE — Inactive Visa accounts that have no purchase or cash activity may provides access to the Visa system. You agree that you will not use your card for any be closed without notice to you after 18 months of no activity, transaction that is illegal under applicable federal, state, or .local law. The monthly 24. NEURAL NETWORK — PSECU uses neural network systems to predict and statement will identify the merchant, electronic terminal or financial Institution at prevent unauthorized transactions. There may be occasions when a transaction is which transactions were made, but sale, cash advance, credit or other slips cannot declined because it is indicative of possible fraudulent activity. I i LOANLFNER° Addendum P�E� Instructions: This addendum is incorporaled inlo and becomes pad of your LOANLINER Credit Agreemeni. Please keep P- 0, Box67013,- Hordsburg,PA 17106-7013 attached. PSL Minimum Payment Ranges (per thousand portion thereof "` 1 First Payment: Your first payment Is due and poyoble within 30 days from The date of The loan advance. FIRST PAYMENT: Your first payment is due and payable within 30 days from the date of The Annual Per Rate :, corresponding daily periodic tales and amount o1 payment for each loon subaccount are the loan advance. shown below. If There is no payment schedule, the amount and due dote of payments will be determined at the lime of each Minimum Monthly Minimum Biweekly advance and disclosed on the Advance Request Voucher, Advance Proceeds Check, or any other loan vovcher or receipt: Other Loan Balance at Time of Advance Payment Payment charges That may be imposed are also shown below (T,e. late charges, filing lees, collection costs). All rates are subject to 19,000.01 to 20,000.00 400 200 dwnge, 18,000.01 to 19,600.00 380 190 Default Rafe: If your loan i3 in defavIl the credit union reserves the right to charge The highest unsecured interest rc11g cufrently 17,000.01 10 18,000.00 360 180 in effect at PSECU.. 16,000.01 to 17,000.00 340 170 15,0 00 01 to 16,000.00 320 160 . Loon $ubeccount Approx. Percent Present Annual Mintmtim Payment 14,000.01 To 15,000.00 300 150 Description Term In Above Daily Perlodlc Rate Percentage (For each $100 or Months Rote traction .of $100 of your 13,000.01 to 14,000.00 280 140 Index unpald ... :atoeveq : 12,000,01 to 13,000.00 260 130 Without With APS' Withoul With APS Without With APS 11,000.01 to 12,000.00 240 120 Aura Leon '(1) Apugm�nf A . _10,000.01 to 11,000.00 220 110 Itaw ve14cL - S.rvt�• S..ric• s•rvle. 9,000.01 to 10,000.00 200 100 S-16,0001oun or greet•, 120 .00019836 .00019151. 7.24% 6.99% 11,1.8 11.17 8,000.01 to 9,000.00 180 90 .06 520,000 ..lu•or grdgta. 84 617781 .00017696 6,49% 6.24% f1.49 SIAS 7 to $,000.00 160 � 80 112,000 yuluro,gieular 72' .0091778) 00617096 649% 6.21% S1.69 11.67 6,000.01 to - 7,000.00 140 70 S8,0D0v I.e.'9r.ar.r 60 .00016411 00015126.. 5.99% 6.74% 31.94 $1.93 S6,000vuluemproutnr 48 .00016411. .00015716 5:99% 5.74% 5235 52.34 5,000.01 to 6,000,00 120 60 13,000 pa1u•ar 9-11. 36 .00016411- ...60015726 5.99% 5.74% 113:65 $3.04 •1,000,01 to 5,000,00 100 50 13,01>0 vo6• 24 - .0001367) ,000 12986 4.996 4.74% 54.39: $4.38 3,000.01 to 4,000.00 80 40 '. u,.d vehid., onl 2,000.01 To 3,000.00 60 30 540.0001.wn or Tp.w.r 120 .00019836 .000 19 151 7,24% 6.99% $1.18 51.17 1,000.01 to 2,000.00 40 20 1220.000 vnly. ar greyior 84 .06017781 .00617696 6.49% 624% $1.49 11.48 11 ?,000ndueog,.:igr 72 ,00017781 .00017096 6.49% 04% - $1.69 $1.67 Up to 1;000.00 20 10 38,000 •e,hr of greaWr Ur .00016411 00015726 5 99% 5.74% 11.94 11.93 16.600 va1.. o, tutu$, 48 .00016411 .00015726 5.99% 5.74% 12.35 .5234 "Personal Service Signolure Loan Minimum Monthly Payment: $100 for original $3.000 vnlrie or IT-I., 1 36 .00016411 00015726 5.99% .74% 19.05 57104 13,000 -6. vgromer - 24 .00013671 .00012986 4.99?: 4.74.0 14.39 1438 balances from $1,000 - $5,000, $200 for original balances from 25,000;01 - .$10,000 . IL•avnhonul v,hmla; I4evfLh.d (21 V'ta Disclosures Lean.. w mi 115,000 and up - 84 - .00024384 1I /A 8.90% N/A 11.60 NIA Finance Charge: Finance Charge (interest) is calculated at the monthly periodic role and corresponding annual ercenta a rate ' Lv.n nmounr 38,000- 14,999 t0 :60024384 rl /A 896 N/A $2.07 N/A P g torn u,nouat S5,000, 7,999 48 .00024304 N/A 8,90'\, 14 /A 12.46 r4 /A on the ovaroge doily balances of purchases and cash advances as eJescribed below: Lunn umount 13,000 r 4,999 36 .00021384 N/A 8.90% 14 /A $3.18 N/A - Viso (Purchases) Monthly Periodic Rate OOB25 Annual Percentage Rate - 9.9% IRA Loon (31 li 2.0 - .00008904 N/A 3.25% I•I!A .18.49 14 /A Visa (Cash Advances, Checks) Monthly Periodic Rote .01075 Annual Percentage Rate -12.9% Sher. Lou. J3, 4)'. . uP la &1,000 . 19 2.0 .00608904 NLA 3.25% N/A - $5.41 rVA Minimum Payment: The minimum monthly payment will be either (a) 2.0% of your total new balance or $20.00, whichever is 11,001 • 54,000 - _ 48 - i.o :00008904 1I /A 325% N/A 52.73 N/A greater; or (b) your total new balance if it is less Than 520.00, plus (c) any portion of the minimum paymenl(s) shown on prior 0 - 54,000 (o�.,.a, 7 st,axt ep 120 2.0 .00008904 11 /A .. 3.25% N/A $0.98 N/A sialement(s) which remains unpaid. • ", m -n 'f iu r...1 Collection Costs; You promise to pay all cosh of collecting the amount you owe under this agreement including court costs 0.,111 c.l. Loan (3, 4, 5) w.dF,•:lo,ue 20 ,s. d; Jmarra N/A n '6J. N/A n/A and reasonable attorney fees. Late Charge: You promise to pay a lute chuige of S20 if your Minimum Payment is not received by the first day of the month Personal S•rvic• loan (PSL)(6) 77 .00035342 NLA 12.9%1 11 /A I't /A following your due dole. P•nanal S."i.. upi.65. Over Limit Charge: You promise to pay an over limit charge of S20 if you exceed your credit limit by $100 or more, Signal... Lo n (PSSL) nth 0002712 11 /A 990% .N /A t4 /A Overdraft Option: If you elect 10 overdraft to your PSECU Visa Credil Card, that election is subject to The existing credit • , fife c' "6511 '"` - - j' - - ... l imit, This addendum and the agreement tl represents and the current loan policy at The time of the overdraft. You also under- ! tAuj Nc Povmenf _ars4ce LA In orrJar tq guah(y forlhe 2506 eduction, oi' hme,t ta,laon Is of up you mast seletel 10 hq�a yoeri stand that an overdroh will be considered the some as n cash advance on our PSECU Visa credit cord and that the currant i lautolgon o menl3rtio`d yr oil uforitolicse`(YIce AutomahcTrgnsler$ernce - Pa' roil DedueJlop Cosh tnc udes sar;u o homei�,andSa Y P I Y ( j ?, ., _ f: annual percentage role for cosh advances will apply. TELEPHONE INFORMATION AND MAILING ADDRESS: For all p t b q7 P 9 pP Y p P ISer4JreTolaphohq) Wir fpi,djt4�DtyecfPuyrryenh Ifypu romp9u; iliscontinuu; chgng3oCpoaipone111 (grpfanyllmagfrii(. .os referenced in the Visa Credit Card A greement and Truth in Lending Disclosure toll PSECU at 717.23.1.8x84 in Harrisburg of T g g 9 T yourlgon' issetup- 61jr1 r�fgrgsjlof�W{ I�f01r114glate) ybalncregser16y0 ; 2596foso'f)hedateof,yuurla_sl. ylnQnl )tpragyoufs }pndtngllglonch. . ,, , P.O. 17106 -7013. �dnlh9loon If u bleemmIts Lndr 411 it e' eon tiffhetetsasons ourooh a gntarri 8002377328 nationwide or write the Credit Union at: PSECU P Box 67013 Harrisburg, qunl I of Utesumet oyreveslhalarmo(1 9' P yfs r� r 1R 4i, f y y I P Ym >Kl1 rn, n h Iyourfoo _,if!1gex,Ua't_da�(ortI, opprop.`ornou fotfirrli1e ililuiljnie/ es f phriclpaf , ; ondlee3.ha: Je `begn.pgd�, °c ordrgioyabtPlon -_ j reran: yl.. nto5iat. Empbsan.CwdRU „ianron„R3+00' /05 i Credit Life and Credit Disability Insurgnortott.,.e mrouyn cur+w Mitu�I M.ennc. axt.ryl I Loan Disclosures CUNA Mutual Insurance Society Credit Lire Iniurance (cost par ¢100 of monthly loan balance): Singte Credit Life - 3.070 i 6916 Mineral Point Road, - . Joint Credit life - $.123 t Late Charge: II you are more than 15 days late in making q payment, you Will pay a Madison,.WisooneinS3701 late charge equal to five percent of the scheduled payment. I Collection Costs You promise to pay all costs of collecting the amount you'owe under Credit Disability Insurance: 1 The Schedule of Rotes shown below are gross balance rates. This means the roles ore applied to the sum of the periodic loan payments I this agreement, including court costs and fees paid to outside colleciors or collection which remain to be pp' ufd on your loon. The rate we use is determined bythe projected loan term of your loan (See your loon plan to find agencies up l0 20 percent of the outstanding loan balance, the projecfed let m olyourloon). Forexample, if the projected lerm of yourloon is 24 months and the benefit plan is a 14 doy nonrelroactive, (1) PS will finance up to 100 percent o(Ihe retail value of new, current model yeorvehide the rate for the lelm is .2950 per S100 of gross balance. lithe amount of your periodic loan payment is S 100, the gross bolonce of your loan during the first month of your loan is $2,400 (24 x 1106). Our charge to you for Insumne i for the first month of your loan j (untitled). PSECU will finance up to 1.00 percent of the retail value of a used motor vehicle Iermpouldbe52;40Dx. 2950x0. O1, or57. Oa. Aft erYouhpye made yourfirstS100periodlclopnpoymenl , the grossbnlanceofyour ( filled). The Kelley Blue Book ®(regisleredtrademarko {Kelley Blue Book Co:lnc)orolher' loan would then be $2,300 (23 x S 100) and ouLChar I to you for your insurance for tl a second month would be 52,300 x .2950 x authorized guides will be used to.determine yourvehicle's value. Auto loans cannot be used O etc. Thec are shown in you rperiodic statement which you receive from ( topurcliosecommercial, theft salvayedorflood titled vehicles. Thevehicle must be titled to 1 the Borrower, Co- Borrower, or both. The registered owner the Certificate o(Title may not Please remember, whenever you add a new advance toyDurloon ,.yourecositheloonandonewp ecled loon term is determined according ( beabusiness, corporatiionortrustentity. Vehicles must have a minimum value of $3,000and to your loon pion. Please note also that if the amount of yourperiodic loan payment is greater than the maximum benefit per month shown i I . Ind ieinsurance schedule of your certificateofinsuronce, ourchargeto you i's bosedanlhesumoflhemazimumbenefilspermonthtimes must be titled in the U.S. and may not be taken out of the U.S. the number of periodic loon payments remaining to be paid on your loon. Far exampte, if your periodic loan payment is 5400 and the t (2) PSECU will finance up to 90 percent of the retail value of a new (untitled current model i maximum benef iiper month is $300 and you have 24 p6ymenis remaining to be paid the gross balance of pour loan for purposes of 1 yeo4 recreational vehicle. Used (tilled!) recreational vehicles may be financed up to 90 percent th is 0.0 i s urance would be 57;200 (not.$9 :600) and our charge to you for insurance the firs) month would be 521.24 (57,200 x .2950 j of the used retail value,. The Kelley Blue BookOn or other authorized guides will be used to j I 1 determine the recreational vehicle's retail volue. PSECU's minimum RV loon Is $3,000. Your 1 Pennsylvania Monthly Renewable Credit Disability - Disclosure Rates Per $100 of Coverage Per Month RV must have a minimum relgil value of $3,333. TERM R6U TERM BATE IE M BAIE IBM BALE � (3) The Annual Percentage Rate (APR) for share secured and IRA advances will be the 1 0.0000 31 0.2561 61 0.1791 91 0.1485 i dividend rate being paid on regular shares (Index) on the date of the advance plus the 2 0.0000 32 0.2519 62 0.1783 92 0.1480 percentage shown in The "Percent Above Index" column. If there is an existing balance on 3 0.0000 33 0.2479 63 0.1766 93 0.1468 the date of the new advance, the existing balance will be added to the new advance and 4 0.5395 34 0.2443 64 0.1753 94 0.1460 the entire balance will be of the newA.PR. The rates are subject to cha to reflect an l 5 0:5627 35 0.2408 .65 0.1742 95 0.1454 _ I g Y ( �i 6 0,5796 36 0.2367 66 0.1730 96 0.1449 ) change in The index. Any increase in the APR will take the form of more payments of the 7 0.5372 37 0.2322 67 0.1716 97 0.7442 I some amount unlit what you owe has been repaid. Loan rates on Certificate and IRA 8 0:5070 38 0.2300 68 0. 700 98 0.1438 loons will not fluctuate during the course of the loan. 9 0.4804 39 0,2260 69 0.1695 99 0.1428 I (4) Shares or certificates pledged must be owned by the Borrower or Co- Borrower unless 10 0.4587 40 0.2234 70 0,1681 100 0.1422 the Share or Certificate owner authorizes the pledge in writing, 11 0.4407 " 41 0.2203 71 0,1667 101 0.1418 12 0.4254 42 0.2180 I (5) PSECU will grant loans secured by Share Certificates, Maximum financing is 90% of 72 0.1658 102 0.1411 the Certificate pledged. The Annual Percentage Rate (APR) for Certificate-loans secured by 13 0.4069 43 0.2152 73 0.1645 103 0.1405 l multiple certificates will be based on the certificate earning the greater dividend, The term 1 14 0.3924 44 02125 74 0.1633 104 0.1391 for Certificate loans secured b multiple certificates will be limited to the. longest term 15 0:9784 45 0.2099 75 0.1624 105 0.1391 y P 9 16 0.3643 46 0.2074 76 0.1613 106 0.1387 +'? ?° remaining among them. Early withdrawal of the unsecured portion is not permitted and t 17 0.3548 47 0.2056 77 0.1605 107 0.1379 the loan balance will be due in full if the Certificate is withdrawn prior to maturity. 18 0.3448 48 0,2028 78 0.1593 108 0.1375 I I Monthly dividends are paid into the Certificate. At maturity, you authorize PSECU to 19 0.3346 49 0.2012 79 0.1583 109 0.1370 I redeem the Certificate to pay any remaining loon balance. Funds remaining after 20 0.3242 50 0.1985 80 0.1573 1 10 0:1365 repayment of the loan will be deposited to Regular Shares if you do not contact PSECU on 21 0.3171 51 0.1966 81 0.1565 ill 0.1362 orbefore the maturity dote. Automatic renewal of the Certificate pledged cannot occur 22 0.3083 52 0.1947 82 0.1556 112 0.1355 23 0.3013 53 0.1934 83 0.1545 113 0.1352 i until the loon balance is paid in full. 24 0,2950 54 0.1910 84 0:1539 119 0.1347 (6) If you have been approved for credit under this account, you will be given a specific 25 0.2882 55 0.1889 85 0.1530 115 .0.1342 I credit limit. 1 26. 0.2817 56 0.1878 86 0.1521 116 0.1336 27 0.2759 57 0.1858 87 0.1514 117 0.1333 28 0.2713 58 0.1837 88 0.1507 118 0.1327 29 0.2670 59 0.1828 89 0.1498 119 0.1320 30 0.2614 60 0.1809 90 0.1493 120 Gil 316 _ Thi, u.dit .rnion 6 I.d.rnlly iruured 6y the Nail ... I C,edM1 U "Ion Adminbhntlon. Eq„ot Opponvnily L.M.r < r Pennsylvania State Em io ees Credit Union ". Y P Y No. 5600150 t PD P.ox�70f3 • HaatsbrV, PA 17106.7013 (717) 234.8484 or(800) 737 -7] ?8 ._ A6fODRAFT: ' ' VOID OVER S:28,000.00r -:REFERENCE ,8847930107 VOID 120 DAYS'•AFT 08 / 1812006 ��.'_ .. i , 'A •\ - �: � +�.r��'r�% �/f .r r; - . -- Grr. O' . >. -: _ ;.. ' - '.PAY,TO.THE: ,, DEA 'ORDERbF :�c�J}JC?li�. s r ' y '' y l' F�'�. $` ' �' -�� 1 .1 .r:. r. Y . ' ,• v 't" DOLLARS - ;(..� =� IMPORTANT; VOID UNLESS DEALER ENDORSEMENT COMPLETED MEMBER ENDORSEMEWT.;; :''< •.+" ;; �,� / Buycr'i Oroer /B,II of Sate lNew and Used Vehiclesj and faciory invoice INew Vetudesl 9y eridorstng,lhis gotoDfat[,•I /We agree t0 the terms listed on the feverse side '! must be received befor cc e the AuloDratt is re,ved by PSECU or the Drall will be �.- : of the drett.e Complete reaprymmt Infonmatbn. 1 •'.''i. rtlrrned. No porlrtxt of the prOeeeos of the AuloDrall shalt be pad to the Bonowerla): j �.� Jr "'i - 'I'� • , � `. -, f'. cr to any agent of the IBanowerls). This AutoDnll shall not be u..d to r.rmh... Term IMonit sl: . g Refer to Maxlmti n Terms in llhe eAr Vehok C..n. Brochure, nconnrvet.d, commercial, Ues.le, trtdt, aalvag.d, ar flood tlll.d yehkb. or vefddet Method I'-�•I�e7' .1 -ater Horriebanking (3 Payroll Monthly Coupon ❑ Dn t Paymant tnlW outdd. th. Uoh d Stn... By arrcptutg Ihe'pr°eeads of thrs digit; • you agtee to ! _ Frepu �ne�r' Y1 • Monthly , ❑ &)-Weekly ❑ ❑' Semi -Month the term. listed on the ieverm gale!: f .' PSECU FAXI 7 I7- 767.8364 •.'. . �\ , •'r^ !�✓f, ` �,( .Member Endorsement ROBERT K BURNS vE MAKE M M a - - C 1 Co- Applicant Endorsement ' DEALER OINI r LERPHOaEMljl� — � 0 C PPLICANT', r ' - 11'SC300ISO"',1:.23 138 1 1 161: 310370423111' 1, �''OOOZL 't 513 it' Crn a ° Z ;gm 0 i8 2 1399 649' 2E8 " �i q s.'a�a ?� o me,sz = f W my - a ° °o�arkk..oDm cg'S^Go o ln �r-r,- 1 '� Qc' _�R = -SO °vr r3 i 1 (n`O '4700. 06)2, 6/7.440 •2 .�1 ' S72iS= e , ' xa1e� -° 5•x� rtf nga - -D 9 m O Oo P025 B 1 F' 1 c' 80VERE.I GTI'm� $ <`; � s � a 'a `& : m 3.�$' x 3 a v m--1 OR: 040 FRE —PHILA 08/31'/2006 OYOKISSI a-,* �� < " -•� 3 g� N o <s 3 a mD E a ! 04 ,TRL =1305 PK =2£J CD x rrt o 3 g€ � a e o p m- v <��NF °cS�Kn to nc hr � ° ° T om O ik ��. r n -1 a m �9C N _ as K ° � �' °, ohn �D i p F, nnY�on < -o4 =3 m ° o _p m m ^0 � &n�31 _D 'v ' ^�ae_O m9 aZ m r nSi .eC °. ' ° a`ovnl1 'urn mn '� .n h..� "3 a o.0 33�"�3 R m p2 TO ° c a n • v x , g •c tr -•$� °a 5'n $ AEo.o o . g-1 Om NrCr, In In Z EXHIBIT "B" 4181246 i ► y ,. CERTIFICATE OF TITLE FOR A VEHICLE Via � __._..---_—'-_..__.._.-..._._.._.__.____.--____....-._..__.____._.....-__-_. ._._...._._._.._...._._- .._._ -- _ 506 — ..... Q927999.99QQ5725-0Q1 _:. :r.. 2C3KA43R36H366549 2QQ6 C.HRY�LER 63683gQ4Q1' BU -•°� VEHICLE IDENTIFICATION NUMBER YEAR MAKE OF VEHICLE T1T(F NUMBER Snnr o q /6Zrp6 p��na� p f:, c - BODY TYPE CUP SEAT CAP PRIOR TITLE STATE ODOM PROCD DATE ODOM MILES ODOM S ATUS DATE grQ1 Q6 DATE PA TITLED DATE OF ISSUE UNLADEN WEIGHT GVWR GCWR S , ODOMETER STATUS y) r 0 =ACTUAL MILEAGE I = MILEAGE EXCEEDS THE MECHANICAL LIMITS 2 = NOT THE ACTUAL MILEAGE 3 = NOT THE ACTUAL MILEAGE - ODOMETER TAMPERING VERIFlED r'�rs• 4 = EXEMPT FROM ODOMETER DISCLOSURE °5A' i REGISTERED OWNERS)t�s -- TITLE BRANDS .(lV` A = ANTIQUE VEHICLE C CLASSIC VEHIC V ►�1 C^ =.LE k ROBERT K B j 5 �``" ._ „• D = COLLECTIBLE VEHICLE a .� "tI ; '"` t F ,= t)LIT OF COUIdTRV G ORIGIN 510 RIDGEVIEW DR =ALLY.MFGD FOR NONUSaM )„ � •� ry/� p •f �. / tea:,\ P + '�•. .DISTRIBUTION D I L L S B U R G PA 1 01 1 H= AGRICULTURAL VEHICLE I S l L = LOGGING VEHICLE P = ISN✓ASA POLICE VEHICLE R = RECONSTRUCTED;;, S = STREET ROD T = REDOVERED:THEFT,VEHiCLE V VEHICLE CONTAINS REISSUED VIN ,. W • FLOOD VEHICLE X IS/WAS A TAXI .lz FIRST LIEN FAVOR OF: - SECOND LIEN FAVOR OF: y _ K� PSECU u I It a second lienhalder Is listed upon satisfaction of tho first Ifen the '�1r §t III d 3 lienholder must forward this Title to the Bureau - ot Motor Vehicles with l pp FIRST LIEN RELEASED t�et dli )Ihi� aroprlate form and lee. r F {.f DATE � ' s I f y ) prJ'�I. V. BY SECOND LIEN RELEASED AUTHORIZED REPRESENTATIVE - DATE MAILING ADDRESS - BY F 4 AUTHORIZED REPRESENTATIVE ' PSECU ;ill P 0 BOX 67013 HARRISBURG PA 171016 o.. I certify as of the date of issue, the official records of the Pennsylvania Department ALLEN D BIEHLER ;?,t ° •,.'. u of Transportation reflect that the person(s) or company named herein is the lawful owner - - - •, : :A`� of the said vehide. s. Secretary of Transportahon - I� � 1. � 4. .., i���S...L � � ±. xrvar �...,.�.4� it ,� ...: �. •t < m d` If a co- purchaser other than your spouse is listed and you want the title to SUBSCRIBED AND SWORN en r ✓ :. -� be listed "Joint Tenants With Right of Survivorship" (On deat of one - I TO BEFORE ME: as h , Mo DAY YEAR owner, title goes to surviving owner.) CHECK HERE ❑. Otherwise, the tit le. 1. r I will be issued as "Tenants In Common" (On death Of one owner interns} of 7 deceased owner goes to his/her heirs or estate):.. ,;, r•ti� L ei';' • ;•1.• RIf.,MATURE OF PERSON ADMINISTERING OATH �ti;(t % %'•'� IF NO LIEN, CHECK❑ IS THIS AN ELT7 (IF YES, FIN REQUIRED) YES ❑ NOD c, -- TW 1ST LIENHOLDER FINANCIAL INSTITUTION NUMBER:' Tim Y 0 1ST LIENHOLDER NAME O STREET S 4 CITY STATE ZIP 7, f V U) I (• %;, -� IF NO 2ND LIEN, CHECK D IS THIS AN ELT? (IF YES, FIN REOUIRED) YES D NOD ( ! A r i a ii The undornED hmehy makes appkralim for Cenilicele of Till, la ,he vohicio dmcr'ued eu 0 0 �: aom•a, dw,ea to me cnainmances end omen Ieyi dorms set form hem. 2ND LIENHOLDER FINANCIAL INSTITUTION NUMBER: i' M I 2ND LIENHOLDER NAME W j SIGNATURE OF APPLICANT On AUTHORIZED SIGNER CO ti STREET :A I CITY STATE III S(G,NATI/RE OF CO APPLICANTITITLE OF AUTHORIZED SIGNER j{ Z I: .... ....- .:.- .,.n.w..++...— ..r. -».• ..:Wor «:, -. .... ... - — ...,., . . qtr- >z -✓�,, T, �.�::., . , � 13u,+ `. `. EXHIBIT "C" 4181246 r z ATTORNEYS Barley S der 126 East King Street Shawn M. Long, Esquire Lancaster, PA 17602 -2893 Direct Dial Number: 717.399.1512 Tel 717.299.5201 Fax 717.291.4660 E -mail: slong @barley.com www.barley.com December 12, 2013 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL Mr. Robert K. Burns 402 Pawnee Drive Mechanicsburg, PA 18050 -2546 Re: Pennsylvania State Employees Credit Union/2006 Chrysler 300 Dear Mr. Robert K. Burns: 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 2006 Chrysler 300 (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 March 1, 2013 payment in the amount of $352.52 and each monthly payment thereafter in the amount of $371.07. 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 $8,094.60 as of November 20, 2013 (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. You have the right to dispute the validity of the Debt in its entirety or any portion of it. Unless you dispute the validity of the Debt or any portion thereof, within thirty (30) days after 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 Lancaster • York • Reading • Malvern • Hanover December 3, 2013 Page 2 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 prepared 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. Very truly yours, Shawn M. Lo g 4134195 cc: Mr. Greg Diffenderfer . 4 VERIFICATION Pennsylvania State Employees Credit Union v. Robert K. Burns I, Julie Serino, being duly affirmed according to law, depose and say that I am the Director, Member Services 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: odl Julie rino 4181246 2/21/2014 c PSECU Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. #14-0615 /CIVIL TERM) fr1 rr� IN: PSECU Complaint _ V. r• . ROBERT K. BURNS c, Defendant -< Complaint Reply to THE COURT AND NOW, this 19th day of Feb , 20_14_ this petitioner avers the following and petitions the court to accept this complaint disputed REPEPLY in response to a complaint filed by Barley Snyder LLC on behalf of PSECU. My reply points out both inaccuracies and/or disputes listed in the complaint for the reasons set forth below. 1. History. Barley on behalf of PSECU billed my account incorrectly in Jan 2010 on this same said loan listed in this most recent complaint. I asked for the verified documentation of their (PSECU) numbers versus mine numerous times, disputing my PSECU loan corrections and speedy corrected resolution if warranted. I received no feedback on my numbers requests until May 2010. The dispute lied in 3 areas. First, the current amount due ($xxx.52). Second, the credit not yet applied to my account ($xxx.55). Last, the loan payoff balance in the amount of$xxx.80. Finally, but not until, May 18th 2010 did I get my requested information. I was correct on all 3 areas to the penny. Point, if the cents as listed above are correct, then my numbers were correct. 2. This current complaint is no different than the above #1 History scenario. See Exhibit A that addresses this complaint both chapter and verse. I was never aware there was an error until a call from a 3rd party contacted rryS last May 2013. I tried numerous times to address this issue. Not until Dec. 2013 via a letter was I contacted by anyone in the PSECU camp, 7 months. The claim in the complaint is wrong. 3. I was forced to file with the Pa Banking Commission in the form of a complaint Form. 4. Exhibit B. They B. Snyder letter dated 12/12/13 stated my reply needed within 30 days or it be assumed the amount owed was correct. At that time I would be provided with verification. I complied and yet I received nothing from PSECU or Barley, They went right to the complaint. 5. The only documentation provided in their complaint was the loan agreement and a statement printout. I have my recent PSECU bank statements, from that 2013 May/June/July time period directly refuting that $8,094 claim. 6. I borrowed $24.9K in 2006. Depending on whose numbers you're looking at, I have paid back PSECU in the mid $30.5K back. I have never missed an arrangement. Most of this is listed in Exhibit A Exhibit A ZWAltifie F S, LLC© Robert K. Burns, Sales Operations Manager 510 i evi , Dilisburg, PA 1"7019 fi I e:///C:/Users/M IKE/AppData/Local/M icrosott ndows/TemporaryP/o20Internet%20Fi Ies/Content.lE5/I2ZCKF LX/complaintrply._.psecu3.htm 1/4 2/21/2014 c r ki18675 3O9 r.t inialLcorn January 16, 2014 Shawn Long, esq. Barley Snyder Attorneys at Law 126 E. King Street Lancaster,PA 17602-2893 Dear Mr. Long: I am just now in receipt of your letter dated 12/12/13 (post marked Dec.13th reg mail; never received any certified mail as your letter states) regarding my auto loan with PSECU originating 08-25-06 in the amt. of$24,994.58. It is worth noting that both my Home address and Contact [phone number] have not changed since 2006 and PSECU has this information on file. I am well aware that PSECU presently retains the Title for my vehicle. Addressing the purpose for your correspondence, I disagree with the premise that I'm in default of the loan. Many factors are involved in categorizing a default status including fair business practices and deviation from the original agreement by either or both parties, not just the lendee. Additionally, it is also worth noting that even though the loan has not reached full term, my total loan repayment to date far exceeds the monies lent to me by PSECU. The rest is a matter of dispute, as you so asked of my response in your Dec.l2th 2013 letter, I put forth. Citing the particulars of your letter, I'll begin with the inaccuracy of the March 1, 2013 payment amount due of $352.52. That was an adjusted split (2-part) payment that was paid with an additional 10% (x2) $35.26 totaling $387.78 rcv'd & requested by PSECU's contracted 3rd party according to records. Somehow, the 3rd party entity erred encoding my payments &/Or requested a wrong amt due by me leaving an $18.55 deficit. They were paid their commission regardless and that $18 shorted my monthly note, kicking me into some other 30 day past due status per PSECU. Never once, did anyone from either PSECU or its contracted entity notify me on any of this. Furthermore, I made payments on (3-20-13) $183.78, [4-22-13] $342.91 & again on [5-23-13] $371.07. Yet, you state $352.52 owed for 03-01-13 when I made 3 additional pmts post March 1. I was unaware of my acct jeopardy per the above misguided record keeping, miscalculations, & posting inaccuracies until I returned a May `13 message from an unknown party that ended up being another PSECU contracted party in repossession. The gentleman contacted me. He must have gotten my number from PSECU. Therefore, reiterating once again, PSECU has always had my contact information, which hasn't changed since 2006. This is essentially where your involvement begins in this latest PSECU matter. That being the case, I will further address the pertinent detailed particulars of your correspondence. Immediately following that May 2013 repossession manager phone call, I spoke with PSECU representation concerning that conversation as well as relaying everything else above in this letter with the representative. At that time, I also discussed my Apr 2013 & subsequently my May PSECU monthly statements confirming unapplied account funds listed on my statements & acknowledged by PSECU. Additionally, I then discovered there had been previous repossession fees charged to my account even though there had been no attempts to repossess. Adding insult to injury, this was during time frames where I had approved payment arrangements in place. I never broke a payment arrangement going back to `06. At most, I've readjusted some arrangements, but with prior notification & approval. Let's speak to the Here and Now. Since my loan's inception, I have always been proactive handling issues and requests with PSECU. Dealing with communication,I've always met all requests & returned any call promptly. It's 2014 and I have yet to hear back from PSECU since last May/June. The first and only communication has been your correspondence dated December 2013, 6-7 months later after begging their written followup documentation reply addressing all above concerns and issues in an effort to steer this account back on track, alleviating any confusion with my account status. I did not complicate the matter. My requests were straight up and file:///C:/Users/MIKE/AppData/Local/Microsoft/Windows/Temporary%20lnternet%20Files/Content.IE5/12ZCKFLX/complaintrply._.psecu3.htm 2/4 2/21/2014 c involved virtually no workload. They were three-fold. First, all payments or monies paid PSECU that did not go toward the balance of my loan balance and why. My conversation with the PSECU representative confirmed two, one of which was on the current statement in front me during our conversation. Second, every repossession fee ($175), being inappropriate, charged to my account during the life of the loan. Third, and last, all fess and 3rd party commissions I've paid out during the course my loan and why. That was not part of my loan agreement. Adapting to change is one thing. However, when 31.d party misguided information, mistake cover-up and down right falsehoods affect my pocket and loan status it becomes my problem. I asked for this documentation 7 months ago and nothing in way of feedback. Though you're sworn to secrecy, I believe you might agree that my 3 requests are in-line. Was & am I supposed to continue to make monthly payments with a multi-layered unresolved issue not knowing how and if my payments are applied directly toward my note? That's throwing good money after bad. To clarify, permit me to use the following example. You have an Institution Loan Balance (ILB) of$900 carrying a monthly note of$200/mo. Your records indicate, with Your Loan Dispute (YLD), the actual balance to be $700 and you inform ILB of the dispute. Unresolved, YLD continues to pay your monthly note in good faith with the hopes ILB will address your concerns. At the end of the three months, is your (YLD) balance $100 or $300 (ILB)? If its $300, you just threw good money after bad. Remember, this is not my or your first rodeo with this type PSECU issue. It occurred in Jan 2010 and didn't get resolved until May of that year when you got involved. That former 5-month debacle involved a conflict in monies owed on the account while asking for documentation to that said issue. Again, it took five months and your involvement to get the documented paperwork & issue resolved. Sound familiar? As it turned out, my numbers were correct to the penny. It's not about right or wrong. But, I was correct then and I'm correct now until someone shows otherwise. I even went so far as to suggest PSECU sell the remainder of my loan. But,I may have to initiate or sign off on that process. The above is a brief background encapsulating the step-by-step, all the while demonstrating how a simple clarification requesting written disputed documentation from PSECU on my remaining loan balance. All this could have been avoided. As such,now we're staring at unfair business practices. As mentioned, the above is a synopsis. Now, I'll address your correspondence specifics. Before that, I would be remiss if I didn't put on record the timeframe and timing of PSECU's inaction. First,I am in compliance with your 30-day disputed request as it applies to 30 days "upon receipt of this notice." That said, I do believe it is a little suspect on the PSECU timing in conjunction with your 30-day written notification. You requested 30 days. Still unresolved, PSECU had 7 months. Why? Is it about the remaining loan balance or about the year-end shareholders' report? Either way, the loan balance is minimal and even considering PSECU's own numbers, the remaining balance is far lower than the $8,095 you state in your letter. Also stated in your letter is "debt or portion thereof disputed, we will obtain verification of the debt." I am curious as to why I am being asked to put forth specifics on what the true loan balance is from my standpoint. Seven months ago I asked PSECU for the documentation to cross reference against my numbers. It's impossible for me to accurately dispute PSECU's numbers when they refuse to provide me their numbers. However, I will comply with your request & provide you my numbers on the loan payoff balance at this reply's end. Upon receiving my reply concerning the bottom line balance as I calculate it, I anticipate PSECU's speedy response & the legality of any future action PSECU intends to take in connection with my vehicle and my account. This, incidentally, is the final line in your correspondence. Keep in mind the legal stipulations.when I have repaid more than 60% of the loan. It's obvious that I have met that obligation when I've already paid PSECU far more monies than the loan check they wrote me in 2006. I'm not going to cite chapter and verse of the "right to cure." You and I are well informed of all that. However, this current dispute does involve fair business practices compounded with a PSECU out of state 3rd party making it Federal, not just state. As the debtor, I don't care whether it is the creditor or a third party contacting me. But under the law,whether it is the creditor itself or a third party makes a big difference. Federal law prohibits any conduct that is deemed false or misleading. That is considered an unfair act or practice and a violation. PSECU's 3rd party San Antonio operation did just that on a file:///C:/Users/MIKE/AppData/Local/Microsoft ndowsfTemporary%201nternet%20Files/Content.lE5/12ZCKFLX/complaintrply._.psecu3.htm 3/4 2/21/2014 c few occasions. Violating the "Federal Debt Collection Act" makes them liable for actual damages as well as penalties. All of this stems from a discrepancy on default which boiled over because PSECU refused to provide me the information on a balance dispute at the tail end of a loan complicated by lack of communication & unfair business practices, 3rd party and otherwise. When you look at the remaining term loan, the payoff balance if settled today would be $4,703.84. Thanks for your cooperation. Regards, Robert K. Burns Robert k. Burns PSU Alumnus '84 file:///C:/Users/MIKE/AppData/Local/Microso ndows/Temporary%201nternet%20Files/Content.lE5/I2ZCKFLX/complai ntrply._.psecu3.htm 4/4 EdeAleigi° Bade Sn der tic ATTORNEYS AT LAW 126 East King Street Shawn M. Long,Esquire Lancaster,PA 17602-2893 Direct Dial Number: 717 399 1512 , Tel 717.299.5201 Fax 717.291.4660 E-mail:slong @batley.corn www.barley.com May 18, 2010 Mr. Robert Burns 402 Pawnee Drive Mechanicsburg, PA 17050 Re: Pennsylvania State Employees Credit Union 2006 Chrysler 300, V.LN: 2C3KA43R36H366549 Dear Mr. Burns: As you are aware, 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 the above-referenced vehicle (the "Vehicle"). This letter is an attempt to collect a debt, and any information obtained will be used for that purpose. Enclosed please find your check in the amount of$1,113.21, which was made payable to PSECU. This check is being returned because it is not in an amount sufficient to pay off the balance owed under the Agreement. Based on your default under the Agreement, the balance of the loan was accelerated, as you were advised in my April 27, 2010 letter to you. Even if your check had been for an amount that was enough to cure the monthly payment default, the loan balance already had been accelerated, and payment in full is required. I have also enclosed a copy of PSECU's accounting of your loan account, as you had requested, along with a copy of PSECU's payoff for your loan account. Please note that the payoff, if made by May 31, 2010, is $17,448.81. As mentioned in my April 27, 2010 letter, you must pay off the loan in full or make arrangements to deliver possession of the Vehicle to PSECU's designated repossession agent within thirty (30) days from April 27, 2010. If not, PSECU is prepared to initiate legal proceedings against you, and to exercise its other available remedies. Very truly yours, • awn. M. Long 2913963., Enclosures cc: Mr. Greg Diffenderfet Mr. Craig Killian Lancaster•York•Reading•Berwyn•Hanover ' J3ai\1e Sn der , A.,,de-/-4e ATTORNEYS AT LAW 126 East King Street Shawn M.Long,Esquire Lancaster,PA 17602-2893 Direct Dial Number:717.399.1512 Tel 717.299.5201 Fax 717.291.4660 E-mail:slong @barley.com www.barley.com December 12, 2013 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL Mr. Robert K. Burns 402 Pawnee Drive Mechanicsburg, PA 18050-2546 Re: Pennsylvania State Employees Credit Union/2006 Chrysler 300 Dear Mr. Robert K. Burns: This firm represents Pennsylvania State Employees Credit Union ("PSECU")in connection with the Loan liner Credit and Security Agreement(the"Agreement") you entered into for the purchase of your 2006 Chrysler 300 (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 March 1, 2013 payment in the amount of$352.52 and each monthly payment thereafter in the amount of$371.07. 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 $8,094.60 as of November 20, 2013 (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. You have the right to dispute the validity of the Debt in its entirety or any portion of it. Unless you dispute the validity of the Debt or any portion thereof, within thirty(30) days after 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 Lancaster•York•Reading•Malvern•Hanover Aris,e/r 2 4.9) December 3, 2013 Page 2 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 prepared 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. Very truly yours, /Z/7� Shawn M. Lo g 4134195 cc: Mr. Greg Diffenderfer /4 /4010 C/:76 • 61+ 15mMeS : /0g/AA3 4.4/4 • * s'A-4 /4?7/41 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY -OFF:C,7 (P.0 NiCl'i'idt':1;Y f:113 12 NI 2: 1 CUMP:ERLAND COUPTY PENNSYLVANA' OFV.1.01-; OF TiiF. ER1F Pennsylvania State Employees Credit Union VS. Robert K. Burns Case Number 2014-615 SHERIFF'S RETURN OF SERVICE 03/05/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert K. Burns, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 402 Pawnee Drive, Hamdpen Township, Mechanicsburg, PA 17050. Twelve attempts at service were made but deputies were unable to make contact with anyone at the residence to make service. SHERIFF COST: $73.20 SO ANSWERS, March 05, 2014 RON R ANDERSON, SHERIFF (c) ShuntySuite Sheriff, Teleosoft, BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299 -5201 2014 -615 7.011i tifT, 24 PCA I.: 35 CUMBE RLA1°d000U d i,+, PElt4SY LVAEalr`\ Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, v. ROBERT K. BURNS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014 -615 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above - captioned action. BARLEY SNYD ' LLP hawn M. Long, Esquire Court I.D. No. 83774 Attorneys for Plaintiff Pennsylvania State Emp 126 East King Street Lancaster, PA 17602 (717) 299 -5201 4245402_1 yees Credit Union Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY a THE PR` 1-101 t PR f 5 AN I©. 30 f4 CUMBERLAND £OilN T Y PENNSYLVANIA , ! 14 Orc c;: ^' TAW ItERIF Pennsylvania State Employees Credit Union vs. Robert K. Burns Case Number 2014 -615 SHERIFF'S RETURN OF SERVICE 03/27/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert K. Burns, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint & Notice according to law. 04/02/2014 03:25 PM - The requested Complaint & Notice returned by the Sheriff of York County, the within named Defendant Robert K. Burns, not found. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, April 10, 2014 RONNY R ANDERSON, SHERIFF (c).CountySuite Sheriff, Te'eosofi, Inc. Richard P Keuerleber Sheriff Michael S. Hose Chief Deputy, Operations SHERIFF'S OFFICE OF YORK COUNTY PENNSYLVANIA STATE EMPLOYEES CREDIT UNION vs. ROBERT K. BURNS PETER J. MANGAN, ES Solid Richard E Rice Chief Deputy, Administrate Case Number 14 -615 CIVIL 04/02/2014 04/07/2014 SHERIFF'S RETURN OF SERVICE 03:25 PM - DEPUTY MICHAEL S. ECKARD, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: ROBERT K. BURNS AT 510 RIDGEVIEW DRIVE, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED. I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: ROBERT K. BURNS, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT & NOTICE AS "NOT FOUND" AT 510 RIDGEVIEW DRIVE, DILLSBURG, PA 17019. SHERIFF COST: $44.20 April 07, 2014 NOTARY Affirmed and subscribed to before me this 7TH day of APRIL 2014 ERS, IC RD P KEUERLE: ER, SHERIFF COMMONWEALTH ©P PENNSYLVANIA Notarial Seal Sheila E. Cook, Notary Public City of York, York County My Commission Expires Feb. 1, 2017 DIRER, PENNSYLVANIA ASSOCIATION OF NOTARIES EXP: 04/23/2014 Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY it OFFICE Or TM E SgERIPF Richard W Stewart Solicitor Pennsylvania State Employees Credit Union vs. Robert K. Burns Case Number 2014-615 Service Details: — Category: Manner: Notes: a. rServe To: cs cc Name: u) Primary –I Address: Phone: Alternate Address: 5 Phone: (.9 a 0 re SERVICE COVER SHEET Civil Action - Complaint & Notice Deputize Expires: 04/23/2014 Zone: Warrant: Robert K. Burns 510 Ridgeview Drive Dilisburg, PA 17019 DOB: [Final Service: Served: Personally • Adult In Charge • Posted • Other Adult In Charge: Relation: Date: Deputy: Time: Mileage: Attorney / Originator: Name: Shawn M. Long [–Service Attempts: Date: Time: Mileage: Deputy: Phone: ['Notes / Special Instructions: 2 rnuJ Now, March 27, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of York County to 0 execute service of the documents herewith and make return thereof according to law. re z Return To: se Cumberland County Sheriffs Office co One Courthouse Square Carlisle, PA 17013 (c) CountySulte Sheriff, Teleosoft, Inc. Ronny R Anderson, Sheriff BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 THE PROTHONOTiAi'i 2014 Alt —6 PM I: i CUMBE PEf'/!'LAND s y� `�� frau `'; y Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff v. ROBERT K. BURNS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014-615 MOTION OF PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT PA.R.C.P. 430(a) Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Barley Snyder, moves this Court for a Order directing the method of service of certified copies and posting of any Notices pursuant to Pa.R.C.P. Nos. 430(a) and in support of said Motion, avers the following: 1. On January 31, 2014, the Plaintiff filed its Complaint against the Defendant. A true and correct copy of the Complaint is attached hereto, made a part hereof and marked Exhibit «A„ 2. On or about March 5, 2014, the Sheriff of Cumberland County attempted service at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. The Sheriff returned the Return of Service to Plaintiff indicating "Not served; twelve attempts at service were made but deputies were unable to make contact with anyone at the residence to make service." A true and correct copy of the Return of Service is attached hereto, made a part hereof and marked Exhibit "B". 3. On or about March 18, 2014, Plaintiff performed an Lexis search on www.Lexis.com. The address listed on the Lexis search is 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. A true and correct copy of the Lexis Search is attached hereto, made a part hereof and marked Exhibit "C". 4. On or about March 24, 2014, the Plaintiff reinstated the Complaint. 5. On or about April 2, 2014, the Sheriff of Cumberland County deputized the Sheriff of York County and attempted service at 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. The Sheriff returned the Return of Service to Plaintiff indicating "The Defendant was found to have moved." A true and correct copy of the Return of Service is attached hereto, made a part hereof and marked Exhibit "D". 6. On or about April 22, 2014, the Plaintiff's counsel prepared and mailed a Request for Change of Address to the Mechanicsburg Postmaster for the address 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. The Request for Change of Address was not returned. A true and correct copy of the Request for Change of Address is attached hereto, made a part hereof and marked Exhibit "E". 7. On or about April 22, 2014, the Plaintiff's counsel prepared and mailed a Request for Change of Address to the Dillsburg Postmaster for the address 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. The response to the Request for Change of Address indicates "no change of address on file." A true and correct copy of the response to the Request for Change of Address is attached hereto, made a part hereof and marked Exhibit "F". 8. On or about July 18, 2014, Plaintiff performed West Law search on www.WestLaw.com. The address listed on the West Law search is 510 Ridgeview Drive, 4392763-1 2 Dillsburg, Pennsylvania 17019. A true and correct copy of the West Law search is attached hereto, made a part hereof and marked Exhibit "G". 9. On or about July 28, 2014, Plaintiff performed a ZABA Search on www.zabasearch.com. The Defendant is listed to 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019 as well as two other possible addresses on the ZABA Search. A true and correct copy of the ZABA Search is attached hereto, made a part hereof and marked Exhibit "H". 10. On or about July 28, 2014, Plaintiff performed a People Finders search on www.peoplefinders.com. There is no address listed to the Defendant on the People Finder search. A true and correct copy of the People Finders Search is attached hereto, made a part hereof and marked Exhibit "I". 11. On or about July 28, 2014, Plaintiff performed a White Pages search on www.whitepages.com. There are multiple addresses listed to the Defendant on the White Pages search. A true and correct copy of the People Finders Search is attached hereto, made a part hereof and marked Exhibit "J". 12. Plaintiff and the undersigned have not located an alternate address for the Defendant and have confirmed 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019 is the correct addresses for the Defendant by several of the above resources. 4392763-1 3 WHEREFORE, Plaintiff respectfully request this Court to grant its Motion, and enter an Order permitting service on the Defendant of the Complaint, Writ of Execution and Notices of Sheriff Sale and/or Sheriff's Handbill by posting the most visible part of 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019, by mailing the Defendant by certified mail, return receipt requested, and regular first-class mail at 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019, and permitting service on the Defendant with any additional notices or documents requiring personal service on the Defendant by mailing to the Defendant by certified mail, return receipt requested, and regular first-class mail at 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. BARLEY SNYIER Dated: Ti S714- By: 1 Shawn M. Long, Es uire Attorneys for Plai iff Pennsylvania Stat Employees Credit Union Court I.D. No. 83 74 126 East King Street Lancaster, PA 17602-2893 717-299-5201 4392763-1 4 Distribution: Shawn M. Long, Esquire Barley Snyder 126 East King Street Lancaster, PA 17602-2893 Robert K. Burns 510 Ridgeview Drive Dillsburg, PA 17019 4392763.1 BARLEY SNYDER 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. ROBERT K. BURNS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014-615 AFFIDAVIT IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF LANCASTER SHAWN M. LONG, ESQUIRE, being duly sworn according to law, deposes and says that he is the attorney of record for the Plaintiff, Pennsylvania State Employees Credit Union, and that the following is an itemization of the efforts taken by the Plaintiff to locate Defendant, Robert K. Burns to effect service under the provisions of the Pennsylvania Rules of Civil Procedure, without success. 1. On or about March 5, 2014, the Sheriff of Cumberland County attempted service at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. The Sheriff returned the Return of Service to Plaintiff indicating "Not served; twelve attempts at service were made but deputies were unable to make contact with anyone at the residence to make service." 4392763.1 2. On or about March 18, 2014, Plaintiff performed an Lexis search on www.Lexis.com. The address listed on the Lexis search is 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. 3. On or about April 2, 2014, the Sheriff of Cumberland County deputized the Sheriff of York County and attempted service at 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. The Sheriff returned the Return of Service to Plaintiff indicating "The Defendant was found to have moved." 4. • On or about April 22, 2014, the Plaintiffs counsel prepared and mailed a Request for Change of Address to the Mechanicsburg Postmaster for the address 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. The Request for Change of Address was not returned. 5. On or about April 22, 2014, the Plaintiffs counsel prepared and mailed a Request for Change of Address to the Dillsburg Postmaster for the address 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. The response to the Request for Change of Address indicates "no change of address on file." 6. On or about July 18, 2014, Plaintiff performed West Law search on www.WestLaw.com. The address listed on the West Law search is 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. 7. On or about July 28, 2014, Plaintiff performed a ZABA Search on www.zabasearch.com. The Defendant is listed to 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019 as well as two other possible addresses on the ZABA Search. 8. On or about July 28, 2014, Plaintiff performed a People Finders search on www.peoplefinders.com. There is no address listed to the Defendant on the People Finder search. 4392763.1 9. On or about July 28, 2014, Plaintiff performed a White Pages search on www.whitepages.com. There are multiple addresses listed to the Defendant on the White Pages search. 10. The Plaintiff has exhausted all reasonable efforts to serve the Defendant, Robert K. Burns. Sw to and subscribed before me thi da , , 2014. Notary Public My Commission Expires: 4392763.1 Shawn M. Long, Esqui ,e COMMONWEALTH OF PENNSYLVANIA Notarial Seal Deena L. Kearney, Notary Public City of Lancaster, Lancaster County My Commission Expires Jan. 14, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES EXHIBIT «A BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street` Lancaster, PA 17602 (717) 299-.5201 TAFD 'F i t` D o F frE CU/18ERL AND PENNSY C�qNla COIJNrY Attorneys for Plaintiff' Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, • V. ROBERT K. BURNS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. G 1 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 forthin 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. 4181246 TRUE COPY 1:R M RECORD In Testimony whereof, I h re yritos.et my hand and the eel of said Court at"CErlish, Pa. This day of F?rothonotary /1..-.. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 Effective September 1, 2003 4181246 BARLEY SNYDER 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, V. ROBERT K. BURNS, Plaintij Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. AVISO PARA DEFENDER Conforme a RCP No. 1018,1 del PA LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas dispuestas en las paginas siguientes, usted debe tomar la acciOn en el plaza 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 carte 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. 4181246 US 1'ED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE Un ABOGADO, VAYA A 0 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 0 NINGUN HONORARIO. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 Efectivo 1 de Septiembre, 2003 Queja 4181246 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774. 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaint Pennsylvania State Employees Credit Union PENNSYLVANIA STA I EMPLOYEES CREDIT UNION, V. ROBERT K. BURNS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 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, Robert K. Burns, is an adult individual with a last known address of 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. 3. On or about September 1, 2006, Defendant entered into a Loanliner Advance Proceeds Voucher and Security Agreement (the "Agrrment ") with Plaintiff for the purchase of a 2006 Chrysler 300, VIN #2C3KA43R36H366549 (the "Vehicle"). A true and correct copy of the Agreement is attached hereto as Exhibit "A" and incorporated herein by reference. 4181246 4. Plaintiffs 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 Agreement by failing to make monthly payments when due beginning March 1, 2013 and on the first (1st) day of each month thereafter. 6. Pursuant to the Agreement, 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 December 12, 2013 (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 Plaintiffs 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 Agreement, Plaintiff is entitled to immediate possession of the Vehicle. 10. The present fair market wholesale value of the Vehicle is approximately $6,650.00. 11. Upon information and belief, the Defendant has possession and control of the Vehicle at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, demands judgment in replevin against Defendant, Robert K. Burns, for possession of the Vehicle, plus 4181246 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 $8,094.60. 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. 4181246 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment in its favor and against Defendant, Robert K. Bums, in the amount of $8,094.60, and costs of suit. BARLEY S By: 4181246 S ong, Esquir ourt I.D. 83774 126 East King Street Lancaster, PA 17602- 893 / 717.299.5201 / Attorneys for Plaintiff E)IIB 4181246 ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT PSE€ ELT • Pennsylvania State • Employees Credit Union P. 0. Box 67013 Harrisburg, PA 17106-7013 717.234.8484 800.237.7328 . me.^Eift taiva:•_,: '1:,. : .z-":4.7.'•,":.-•.f1Lt.''..; .:::.`,.....-::6-A*5-71t.*:•:':ific.E.giikiggittialvKinl?.iii:: ANNUAL PER- CENTAGE RATE 6.490% • ..r.;.:5.i.FA7i.. .,A______.:::iid,f5.. ROBERT K BURNS ...-,!" 510 RIDGEVIEW DRIVE DILLSBURG , PA 17019 . • 9/1/2006 IMMIMMS107/L10 . ITRMIIMME50 PURPOSE: . Dealer Purchase . . . TRANSACTION TYPE _ _ '7' :•.•'''.•-.7.1.4400gtn••••••••. OPEN-END OTHER HOME 1. NEW LOAN 2. LOAN ADVANCE 2. (DESCRIBE) 4. EQUITY ADVANCE DISBURSEMENT BREAKDOWN AND REPAYMENT SCHEDULE YOU HAVE PREVIOUSLY ELECTED TO HAVE mos AovANce CREDIT DISABIUTYSINGLE CREDIT LIF, JOINT CREDIT LIFE INSURED WISH THE FOLLOWING COVERAGE YES 0 NO.r:_i YES 0 NO tIll YES 0 NO LI DAILY PERIODIC RATE (CHANGE IN TERMS ONLY) .0177808 ANNUAL PER- CENTAGE RATE 6.490% ... • . INTEREST RATE IS I AMOUNT REQUESTED Is OUNT ADVANCED 1 PREVIOUS BALANCE 1 NEW BALANCE OTHER CHARGES FIXED j VARIABLE + .=,..... ::::-.....-•-•-..-:-,:•,:...,-..---,--, .4 .74 El I 24,994.587.-2,4;i-9:.V.ti--!5z8m 0.00, 24,994.58 PAYMENT 371.07 DUE DATE 10/1/2006 PAYMENT FREQUENCY Monthly PROJECTED LOAN TERM SECURITY OFFERED IF THIS ISA HOME EQUITY ADVANCE. THE ONLYSECURITY FOR THIS ADVANCE IS THE REAL PROPERTY (IN MOST CASES YOUR HOME) WHICH YOU GAVE AS SECURITY WHEN YOUR ACCOUNT WAS ESTABLISHED. IF THIS IS NOTA HOME EQUITY ADVANCE, IN ADDITION TO THE PLEDGE OF SHARES .IN YOUR LOANUNER' CREDIT AGREEMENT, THE FOLLOWING PROPERTY SECURES THIS ADVANCE. ITEM eRoPERtr• . • • •''•• • .' '7' :•.•'''.•-.7.1.4400gtn••••••••. •;--..4YEAR--;:.',. "So-F:•‘::,:-•-••••.:Y.443.•Ntrioentr.:,:•i•••;::•.;-;....4:24-', s- • - ' ;:'••:,....;•;•-.jfV:=:=1;•NAL'im'Fl•-•:,-•;•.:4::, 1. CHRYSLER 2. 3. 300 2006 2C3KA43R36H366549 SDN 25,380.00 4. OTHER YOU PLEDGE SHARES AND/OR DEPOSITS OF $ . IN ACCOUNT NUMBER OLD ACCOUNT/LOAN NUMBER (A) PAYOFF (PRINC. + INT.) OLD ACCOUNT/LOAN NUMBER (B) PAYOFF (PRINC. + INT.) OLD ACCOUNT/LOAN NUMBER (C) PAYOFF (PRINC. + INT.) OW ACCOUNT/LOAN. NUMBER (0) PAYOFF (PRIMO, + INT.) OLD ACCOUNT/LOAN NUMBER (E) PAYOFF (PHING. + INT.) OLD ACCOUNT/LOAN NUMBER (F) PAYOFF (MIND. + INT) By accepting the proceeds or by using the funds advanced and deposited into your share/share draft account, you agree (1) that the property referenced above will secure the advance and any other advances you have now or receive in the future under the LOANLINER° Credit and Security Agreement (the Plan) and any other amounts you owe us for any reason now or In the future In accordance with the terms of the Flan and (2) to make payments as disclosed above In accordance with the terms of the Plan. ©DUNA MUTUAL GROUP, 1980,132, 84, 86, 89,91.89,2000, 01,04, 06, ALL RIGHTS RESERVED PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM 83170 JVXXOIOO-1 037-2092-1 (W00) %83 PSEC Pennsylvania State Employees Credit Union P.O. Box 67013 0 Harrisburg, PA 17106-7013 0 k'! Loan Dis (717) 234-8484 Harrisburg, (B00) 237-7328 Nationwide closures afiartaitibitrArbi tar 1Y i4GREE%UIEN.T This LOANLINER` Credit and Security Agreement, which includes the Truth in Lending Disclosures, will be referred to as the Plan. The Plan documents include this agreement and an Addendum. You, your and borrower mean any person who signs the Plan. Credit union, we, our and us mean PSECU or anyone to whom the Credit Union -transfers its rights under the Plan. HOW THIS PLAN WORKS — This is an open-end, multi -featured credit plan. We anticipate that, from time to time, you will borrow money (called "advances") under the Plan. We are not required to make advances to you under the Plan and can refuse a request for an advance at any time. The Addendum describes the different types of credit (called "subaccounts") available under the Plan, the current interest rate for each subaccount expressed as a daily periodic rate and corresponding annual percentage rate and other charges. It may also have other terms and a schedule for determining the payment amounts. CREDIT LIMiT — We may, but do not have to, establish a credit limit on certain subaccounts. If a credit limit is set for a subaccount, you promise not to exceed the established credit limit If you exceed the credit limit, you promise to repay immediately the amount which exceeds the credit limit REPAYMENT — You promise to repay all amounts you owe under the Plan plus interest. Payments are due on the last day of the month unless we set a different day at the time of an advance. If the Addendum has no payment schedule for a subaccount, your payment will be. determined at the time of each advance. Payments must include any amount past due and any amount by which you have exceeded any credit limit you have been given for a subaccount. You may repay all or part of what you owe at any time without any prepayment penalty. Even if you prepay, you will still be required to make the regularly scheduled payments unless we agree in writing to a change In the payment schedule. Ifyou have a joint sharedraft account, you will be responsible for paying all overdraft advances obtained by a joint holder of the sharedraft•account. Unless otherwise required by law, payments will be applied to amounts owed under the Plan, in the manner the Credit Union chooses. PLAN ACCESS — You can obtain credit advances in any manner authorized by us. If we allow you to use your ATM/Debit card to access the Plan, you may be liable for the unauthorized use_ of your ATM/Deblt card. You will not be liable for unauthorized use that occurs after you notify us, orally or in writing, of the loss, theft, or possible unauthorized use. If you believe your ATM/Debit card has been lost or stolen, immediately inform the Credit Union by calling or writing us at the telephone number or address that appears elsewhere in the Plan. If the card Is used to obtain unauthorized advances directly from the Plan, your liability will not exceed $50. If the unauthorized withdrawal is from a sharedraft account, your liability is governed by the Regulation E disclosures you received at the time you received your ATM/Debit card, even if the withdrawal results In an advance being made from your overdraft subaccount. FINANCE CHARGE — The dollar amount you pay for money borrowed is called a "finance charge" and begins on the date of each advance. A finance charge will be computed separately for each separate balance under the Plan. To compute the finance charge, the unpaid balance for each day since your last payment (or since an advance if you have not yet made a payment) is multiplied by the applicable daily periodic rate. The sum of these amounts is the finance charge owed. The balance used to compute the finance charge is the unpaid balance each day after payments and credits to that balance have been subtracted and any additions to the balance have been made. In addition to Interest, we may charge other finance charges which are disclosed on the Addendum, If the interest rate is a variable interest rate, the Addendum explains how the variable Interest rate works. SECURITY —You pledge as security for the Plan all shares and dividends and, if any, all deposits and Interest in all joint and Individual accounts you have with usnow and in the future. If a specific dollar amount is pledged for an advance, we will freeze shares in that account to the extent of the outstanding balance for the advance. Otherwise, your pledged shares may be withdrawn unless you are in default. The following paragraph applies in all states except In Ohio, Rhode Island .and Massachusetts: We have a statutory lien on the shares and dividends and, If any, the - deposits and interest in all individual and joint accounts you have with us and may exercise our rights under the lien to the extent permitted by state law. (We are state chartered If our name does not include the term "Federal Credit Union."). For all borrowers:The statutory lien and/or your pledge will allow us to apply the funds in youraccount(s) to what you owe when you are in default. The statutory lien and your pledge do not apply to any Individual Retirement Account or any other account that would lose special tax: treatment under state or federal law if given as. security. Additional security for the Plan may be required at the time of an advance, If a subaccount identifies a type of property (such as "New Cars") you must give that type of property as security when you get an advance under that subaccount. A subaccount name such as 'Other Secured" means you must provide security acceptable to us when you obtain an advance under that subaccount. Property you give as security will secure all amounts owed .under the Plan and all other loans you have with us now or in the future, except any loan secured by your principal dwelling. Property securing other loans you have with us may also secure the Plan. © CUNA MUTUAL GROUP. 1980, 2006. ALL RIGHTS RESERVED CREDIT INSURANCE — Credit life and/or credit disability insurance is optional under the Plan. If you qualify for and purchase the insurance from us, you authorize us to add the Insurance premiums monthly to your loan balance and charge you interest on the entire balance. If you elect credit insurance, your payments may Increase or the period of time necessary to repay your advance may be extended. The credit insurance rates may change during the Plan, If the rates change, we will provide any notices required by applicable law. PERIODIC STATEMENT— On a regular basis you will receive a statement showing all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each joint borrower, notice to any one of you will be notice to all. JOINT ACCOUNTS — If this is a joint account, each of you Is individually and Jointly responsible for paying all amounts owed. That means we can enforce our rights under the Plan against any one of you individually or against all of you together. If you give us inconsistent instructions, we can refuse to follow your instructions. Unless our written policy requires all of you to sign for an advance, each of you authorizes the other(s) to obtain advances individually and agrees to repay advances made to the other(s). Any joint accountholder may terminate the Plan by giving us prior written notice. If any of you terminate the Plan, the Plan is terminated for all of you. You remain liable individually and jointly for all advances incurred before termination. FEES AND CHARGES — If you give us a security interest in certain types of property, we may charge you a filing fee to perfect our interest in the property. If we do, the amount of the fee will be disclosed to you at the time you obtain an advance. - We may also charge you other fees In connection with the Plan. Our current fees are disclosed on the Addendum and will be added to your loan balance unless you pay them in cash. UPDATING CREDIT INFORMATION — You promise that you will promptly give us written notice if you move, change your name or employment, or if any other information you provided to us changes. Upon our request, you also agree to provide us updated financial information. DEFAULT — The following paragraph applies to borrowers in Idaho, Kansas, Maine and South Carolina: You will be In default if you do not make a payment of the amount required when it is due. You will also be in default if we believe the prospect of payment, performance, or realization on any property given as security is significantly Impaired. The following paragraph applies only to borrowers In Wisconsin: You will be In default if you fail to make a payment when due two times during any 12 month period, You will be in default If breaking any promise made under the Plan materially impairs your ability to repay what you owe or materially impairs the condition, value, or protection of or our right in any property you gave as security. The following paragraph applies only to borrowers in Iowa: You will be in default if you are more than 10 days late in making a payment. You will also be in default if you do not comply with the terms of the Plan and your failure to comply materially impairs any property you gave as security or your ability to repay what you owe under the Plan. The following paragraph applies to borrowers in all other states:'You will be in default if you do not make a payment of the amount required when it is due. You will be in default If you break any promise you made under the Plan or If anyone is In default under any security agreement made in connection with an advance under the Plan. You will be in default if you die, file for bankruptcy, become insolvent, if you make any false or misleading statements in any credit application or update of credit Information, or if something happens we believe may substantially reduce your ability to repay what you owe. You will be in default if any property you have given us as security Is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value ofthe property or our security interest in It. You will also be in default under the Plan If you are in default under any other loan agreement with us. ACTIONS AFTER DEFAULT — The following paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: When you are in default and after expiration of any right you have under applicable state law to cure your -default, we can demand immediate payment of the entire unpaid balance under the Plan without giving you advance notice. The following paragraph applies to borrowers in all other states except Wisconsin and Louisiana: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. The following paragraphs apply to borrowers in all states except Wisconsin and Louisiana: If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the applicable interest rates in effect or, if applicable, CPSM01 PSECU FORM 83146 LOANLINER' Credit and Security Credit Agreement (continued) at the default rate disclosed on the Addendum. If a demand for immediate payment has beep made, your shares and/or deposits can be applied towards what you owe. as provided in the section above called "Security." We can also exercise any other rights given by law when you are in default. You agree the Credit Union has the right to take possession of any property given as security under the Plan, without judicial process, if this can be done without breach of the peace. If we ask, you promise to deliver the property at a time and place we choose. If the property is a motor vehicle or boat, you agree that we may obtain a key or other 'device necessary to unlock and operate it, when you are in default. We will not be responsible for any other property, not covered by this Agreement, that you leave inside the property or that is attached to the property. We will try to return that property to you or make it available for you to claim. After we have possession of the property, we can sell it and apply the money to any amounts you owe us. We will give you notice of any public disposition or the date after which a private disposition will be held. Our expenses for taking possession of and selling the property will be deducted from the money received from the sale. Those costs may Include the cost of storing the property, preparing It for sale and attorney's fees to the extent permitted under stale law or awarded under the Bankruptcy Code. You must pay any amount that remains unpaid after the sale money has been applied to any unpaid balance under the Plan. You agree to pay interest on that amount at the same rate as the advance, or, if applicable, at the default rate disclosed on the Addendum, until that amount has been paid. The following paragraph applies only to Wisconsin borrowers: When you are In default and after expiration of any right you have under applicable state law to cure your default, we may require immediate payment of your outstanding loan balance under the Plan and seek possession of property given as security. You may voluntarily give the property to us if you choose, or we may seek to take possession of the property by judicial process. If we repossess the property, you agree to pay reasonable expenses Incurred in disposing of the property. If the property is a motor vehicle, mobile home, trailer, snowmobile, boat or aircraft, you will also be required to pay any costs permitted by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains unpaid after the sale money has been applied to what you owe under the Plan. You agree to pay interest on any unpaid amount at the same rate as the advance, or, if applicable, at the default.rate disclosed on the Addendum, until that amount is paid. If the property is located outside Wisconsin at the time of default, we may take possession of the property without judicial process, If permitted by the state where the property Is located. The following paragraph applies only to Louisiana borrowers: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the applicable Interest rates In effect unless a default rate is disclosed on the Addendum. If a demand for immediate. payment has been made, the shares and deposits given as security for the Plan can be applied towards what you owe. We can also exercise any other rights given by law when you are in default and our rights under any security agreements you have with us. CANCELLING OR CHANGING THE PLAN — The following paragraph applies only to borrowers in Illinois: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change to the interest rate or bther charges will apply to future advances. The following paragraph applies only to borrowers in Wisconsin: We can change the terms of the Plan from time to time In accordance with Section 422.415 of the Wisconsin Statutes. You will be notified of any change in terms. An increase in the daily periodic rate under a variable rate interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at, any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the credit union cancel the Plan, except to the extent that your (lability is limited by Section 422.4155 of the Wisconsin Statutes, The following paragraph applies only to borrowers in Iowa: We can change the terms of the Plan from time to time after giving you any advance notice required by law. A change that increases the rate of finance charge or other charge, that increases the amount of your payments, or that otherwise adversely affects existing balances will apply to existing balances only If you agree to the change or you use the Plan after receiving notice that your use of the Plan means you agree the change applies to existing balances. The following paragraph applies t right to change the terms of the Plan apply to unpaid balances. The following paragraph applies to time., You may cancel the Plan at you or the Credit Union cancel the Pla DELAY IN ENFORCING RIGHTS AN o borrowers in all other states: We have the from time to time after giving you any advance notice required by law. Any change in the Interest rate will apply to future advances, and at our discretion and subject to any requirements of applicable law, will also all but Wisconsin borrowers: An Increase in the daily periodic rate under a variable Interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any any time by giving.us prior written notice. Your • obligation to pay the unpaid balances under the terms of the Plan continues whether R. D CHANGES IN THE PLAN — We can delay enforcing any of our rights under this Plan any number of times without losing the ability to exercise our rights later. We can enforce this Plan against your heirs or legal representatives. If we change the terms of the Plan, you agree that this Plan will continue to protect us. CONTINUED EFFECTIVENESS — If any part of tills Plan is determined by a court to be unenforceable, the rest will remain in effect. NOTICE TO UTAH BORROWERS — This written agreement is a final expression of the agreement between you and the Credit Union. This written agreement may not be contradicted by evidence of any oral agreement. The following is required by Vermont law — NOTICE TO CO-SIGNER — YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. The following paragraphs apply if you give security in connection with an advance under the Plan. They apply to borrowers in all states except Louisiana. Louisiana borrowers will execute a separate security agreement. Borrowers in other states may also be asked to execute a separate security agreement. THE SECURITY FOR THE PLAN — You give us what is known as a security interest in all property 'described in any receipt, voucher or other document you receive for an advance ("the Advance"). The security interest you give includes all accessions, Accessions are things which are attached to or installed In the property now or in the future. The security interest also Includes any replacements for the property which you buy within 10 days of the Advance or any extensions, renewals or refinancing of the Advance, It also includes any money you receive from selling the property or from insurance you have on the property, If the value of the property declines, you promise to give us more property as security If asked to do so, WHATTHE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS — The security interest secures the Advance described in the receipt, voucher or any other document you receive at the time of the Advance and any extensions, renewals or refinancings of the Advance. It also secures any other advances you have now or receive in the future under the Plan and any other amounts or loans, includingany credit card loan, you owe us for any reason now or in the future, except any loan secured by your principal residence, If the property is household goods as defined by the Federal Trade Commission Credit Practices Rule, the property Will secure only the Advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY — You promise that you own all property you give as security or II the Advance is to buy the property, you promise you will use the Advance for that purpose. You promise that no one else has any Interest in or claim against the property that you have not already told us about. You promise not to sell or lease the property or to use it as security for a loan with another creditor until the Advance Is repaid. You promise you will allow no other security interest or lien to attach to the property either by your actions or by operation of law. PROPERTY INSURANCE, TAXES AND FEES — You must maintain property Insurance on all property that you give as security under the Plan, You may purchase the property Insurance from anyone you choose who is acceptable to the Credit Union. The amount and coverage of the property Insurance must be acceptable to us. You may provide the property Insurance through a policy you already have, or through a policy you get and pay for. You promise to make the insurance policy payable to us and to deliver the policy or proof of coverage to us if asked to do so. If you cancel your insurance and get a refund, we have a right to the refund. If the property is lost or damaged, we can use the insurance settlement to repair the property or apply It towards what you owe, You authorize us to endorse any draft or check which may be payable to you In order for us to collectany refund or benefits due under your insurance policy. You also promise to pay all taxes and fees (like registration fees) due on the property. If you do not pay the taxes or fees on the property when due or keep it insured, we may pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the advance and you will pay Interest on those amounts at the same rate you agreed to pay on the advance. We may receive payments in connection with the Insurance from a company which provides the insurance. We may monitor our loans for the purpose of determining whether you and other borrowers have complied with the insurance requirements of our loan agreements or may engage others to do so. The Insurance charge added to an advance may Include (1) the Insurance company's payments to us and (2) the cosi of determining compliance with the insurance requirements. If we add amounts for taxes, fees or Insurance to the unpaid balance of an advance, we may increase your payments to pay the amount added within the term of the Insurance or approximate term of the advance. INSURANCE NOTICE — If you do not purchase the required property insurance, the insurance we may purchase and charge you for will cover only our interest in the property. The premium for this Insurance may be higher because the Insurance company may have given us the right to purchase insurance after uninsured collateral islost or damaged, The insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. PROTECTING THE .SECURITY INTEREST — If your state issues a title for the property, you promise to have our security Interest shown on the title. We may have to file what is called a financing statement to protect our security interest from the claims of others. If asked to do so, you promise to sign a financing statement. You also promise to do whatever else we think is necessary to protect our security Interest In the property. You promise to pay all costs, Including but not limited to any attorney fees, we incur in protecting our security interest and rights In the property, to the extent permitted by applicable law. LOANLiNER9 Credit and Security Credit Agreement (continued) USE OF PROPERTY — Until the Advance has been paid off, you promise you will: (1) Use the property carefully and keep it in good repair. (2) Obtain our written permission before making major changes to the property or changing the address where -the property is kept. (3) Inform us in writing before changing your address. (4) Allow us to inspect the property. (5) Promptly notify us if the property is damaged, stolen or abused. (6) Not use the property for any unlawful purpose. (7) Not to retitle property in another state without telling us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE — THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF iT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. NOTICE FOR ARIZONA OWNERS OF PROPERTY — It is unlawful for you to fail to return a motor vehicle that is subject to a security interest, within thirty days after you have received notice of default. The notice will be mailed to the address you gave us, It is your responsibility to notify us if your address changes. The maximum penalty for unlawful failure to return a motor vehicle is one year in prison and/or a fine of $150,000. For those members who purchase a vehicleunder the DRIVe Program, please review the following FTC Notice: NOTICE ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. LLING RIGHTS KEEP:,ThES NOT%CErFOR.FU.tURE'US This notice contains Important Information about your rights and our responsibilities under the Fair Credit Billing Act You are advised to read your monthly statement and review it for any error discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT. If you think your statement Is wrong, or if you need more information about a transaction on your statement, write us on a separate sheet at the address listed on your statement. You are required to notify us in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transactions on your account. Failure to notify us may result In your acceptance of any responsibility for payment or reimbursement to us for any such error or discrepancy on your account. Write to us as soon as possible. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: ' Your name and account number. • The dollar amount of the suspected error. • Describe the error and explain, if you can, why you' believe there is an error. If you need more information, describe the Item you are not sure about. If you have authorized us to pay a credit card account automatically from your share account or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us three business days before the automatic payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe .the statement was correct. •- ,zupyEDI �''t;�(R % fietilat N..1 ri9 After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent We can continue to send statements to you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit limit You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your statement that are not in question. If we find that we made a mistake on your statement, you will not have to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed • payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date that it Is due. If you fall to pay the amount that we think you owe, we may report you as delinquent, However, if our explanation does not satisfy you and you write to us within ten days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your statement. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your statement was correct. SPECIAL RULE FOR CREDIT CARD PURCHASES — If you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay theremaining amount due on the property or services. There are two limitations an this right: (a) You must have made the purchase in your home state or, if not within your home state, within 100 miles of your current mailing address; and (b) The purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or If we mailed you the advertisement for the property or services. NU►;TR• r,`�f' In this Agreement, the words you and your means each and all of those who apply for the card or who signs this Agreement. Card means the Visa Credit Card and any duplicates and renewals we issue. Account means your Visa Credit Card Line of Credit account with us. We, us, and ours means this Credit Union. 1. RESPONSIBILITY — If we issue you a card, you agree to repay all debts and the Finance Charge arising from the use of the card and the card account. For example, you are responsible for charges made by yourself, your spouse and minor children. You are also responsible for charges made by anyone else to whom you give the card, and this responsibility continues until the card is recovered. You cannot disclaim responsibility by notifying us, but we will close the account for new transactions if you so request and return all cards. Your obligation to pay the account balance continues even though an agreement, divorce decree or other court judgment to which we are not a party may direct you or one of the other persons responsible to pay the account. The cards remain our property and you must recover and surrender to us all cards upon our request and upon termination of this Agreement 2. LOST CARD NOTIFICATION — If you believe the card has been lost or stolen, you will immediately call the Credit Union at (717) 234-8484 or (800) 237-7328. After hours call (800) 556-5678. 3. LIABILITY FOR UNAUTHORIZED USE—You agree to notify us immediately,orally or in writing of the loss, theft or unauthorized use of your Credit Card. You may be liable for the unauthorized use of your Credit Card. You will not be liable for unauthorized use that occurs after you notifyus of the loss, theft, or possible unauthorized use. You will have no liability for unauthorized purchases made with your Credit Card, unless you are grossly negligent in the handling of your Card. In any case, your liability will not exceed $50. 4. CREDIT LINE — If we approve your application, we will establish a self - replenishing Line of Credit for you and notify you of its amount when we issue the card. You agree not to let the account balance exceed this approved Credit Line. Each payment you make on the account will restore your Credit Line by the amount of the payment which is applied to the principal. You may request an increase in your Credit I L11i171NG.:D'" 'CMUR� Line only by written application to us, which must be approved by our credit committee or loan officer. By giving you written notice we may reduce your Credit Line from time to time, or with good cause, revoke your card and terminate this Agreement. Good cause includes your failure to comply with this Agreement or any other agreement with us, or our adverse reevaluation of.your creditworthiness. You may also terminate this Agreement at any time, but termination by either of us does not affect your obligation to pay the account balance. .5. CREDIT INFORMATION — You authorize us to investigate your credit standing when opening, renewing or reviewing your account, and you authorize us to disclose information regarding your account to credit bureaus and other creditors who Inquire of us about your credit standing. 6. MONTHLY PAYMENT — We will mall you a statement every month showing your Previous Balances of purchases and cash advances, the current transactions on your account, the remaining credit available under your Credit Line, the New Balances of purchases and cash advances, .the Total New Balance, the Finance Charge due todate, and any other billed fees, and the Minimum Payment required. Every month you must pay at least the Minimum Payment within 25 days of your statement closing date. By separate agreement you may authorize us to charge the minimum payment automatically to your share or checking account with us. You may, of course, pay more frequently, pay more than the Minimum Payment, or pay the. Total New Balance in full, and you will reduce the finance charge by doing so. If your monthly payment exceeds the total credit line balance owed, we will automatically post the credit to your S1 shares. The minimum payment will be (a) 2°k of your Total New Balance, rounded up to the next even dollar, or (b) $20.00, whichever Is greater. In addition, at any time your Total New. Balance exceeds your Credit Line, you must Immediately pay the excess upon our demand. We will apply payments in the following manner: first to previous late fees, then to previous cash advances finance charges, then to previous purchasefinance charges, then to current late fees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. -Paige 3a ..Visa' Credit Card Agreement and Truth In Lending Disclosure (continued) 7. FINANCE CHARGES — You can avoid the Finance Charge on purchases•by paying the full amount of the New Balance of Purchases each month within 25 days of your statement closing date. Otherwise, the New Balance of Purchases, and the subsequent purchases from the date they are posted to your account, will be subject to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average adjusted daily balance (see explanation below), including new purchases, for the billing cycle by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum, Cash Advances: We calculate your finance charge on cash advances by multiplying the average adjusted daily balance (see explanation below) for cash advances during the billing cycle by the monthly periodic advance rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Daily Balance for Purchases - The Average Daily Balance for Purchase Transactions is calculated by adding the Daily Balances. (Purchase Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges, Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or In any previous day in the billing cycle, This gives us the Daily Balance for purchases. Average Daily. Balance (or Cash Advances - Cash Advance Transactions which are posted to your account are not included in the Average Daily Balance calculation for purchases, and are therefore not subject to the monthly periodic rate for purchases. The Average Daily Balance Is calculated separately for Cash Advances and is subject to the Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions is calculated by adding the Daily Balances (Cash Transaction) for each day In the billing cycle, and then diving by the number of days in the billing cycle.To calculate the Daily Balance for cash each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence In which amounts are posted to your account, we add the amounts of all debits and subtract the amounts 01 all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount.of any Purchase Transactions that posted to your account on that day or in any previous day In the billingcycle.ThIs gives us the Daily Balance for Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your -account. Payments are applied In the following manner: first to previous late lees, then to previous cash advances finance charges, then to previous purchase finance charges, then to current late fees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances, Credits are applied first to the particular type of debt which is being credited, if any, and then to the balance of youraccount. Note also that If the total of the payments and credits which are posted to your account by the Payment Due Date shown on a statement is equal to or exceeds the New Balance shown on that statement, we will not apply the Monthly Periodic Rate to your Account on your next statement,' 8. DEFAULT—You will be in default if you fail to make any Minimum Payment within 25 days after your monthly statement closing date. You authorize us to transfer funds sufficient to make the minimum payment due If your Visa loan is in default. You will also be In default If your ability to repay us is materially reduced by a change in your employment, an increase in your obligations, bankruptcy or insolvency proceedings involving you, your death or your failure to abide by this Agreement, or if the value of our security interest materially declines. We have the right to demand immediate payment of your full account balance if you default, subject to our giving you any notice required by law. To the extent permittedbylaw, you will also be required to pay 'our collection expenses, Including court costs and reasonable attorney fees. 9. USING THE CARD — To make a purchase or cash advance, there are two alternative procedures to be followed. One is for you to present the card to a participating Visa plan merchant, or another financial institution, and sign the sales or cash advance draft which will be imprinted with your card. The other is to complete the transaction by using your Personal Identification Number (PIN) in conjunction with the card In an Automated Teller Machine or other type of electronic terminal that provides access to the Visa system. You agree that you will not use your card for any transaction that is Illegal under applicable federal, state, or local law. The monthly statement will identify the merchant, electronic terminal or financial Institution at which transactions were made,but sale, cash advance, credit or other slips cannot M be returned with the statement. You will retain a copy of such slips furnished at the time of the transaction in order to verify the monthly statement The Credit Union may make a reasonable charge for photocopies of slips you may request. 10. OVERDRAFT OPTION — If you elect to overdraft to your PSECU Visa Credit Card, that election is subject to the existing credit limit and the agreement It represents and the current loan policy at the time of the overdraft: You also understand that an overdraft will be considered the same as a cash advance on your PSECU Visa Credit Card and that the current Annual Percentage Rate for cash advances will apply. 11. RETURNS AND ADJUSTMENTS — Merchants and others who honor the card may give credit for returns and adjustments, and they will do so by sending us a credit slip which we will post to your Visa line of credit. If your credit and payments exceed what you owe us, we will automatically post the excess credit balance to your Si Shares within 75 days. If the balance is one dollar or more, upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS — The exchange rate between the transaction currency and the billing currency used for processing international transactions is a rate selected by Visa from the range of rates available in wholesale currency markets for the applicable central processing date, which rate may vary from the rate Visa itself receives, or a government -mandated rate in effect for the applicable central processing date. In each instance, an adjustment may be assessed based on the ISA fee Imposed by Visa. This fee, which totals 1% of the transaction amount, will be assessed on all transactions where the merchant country differs from the country of the card Issuer. 13. SPECIAL RULES FOR VISA PURCHASES — If you disagree or find an error with a Visa transaction, and have tried in good faith to correct the problem with the merchant or the charges are the result of unauthorized or fraudulent use, or your purchase cost more than $50 and was made from a plan merchant in your state within 100 miles of your home, contact PSECU. 14. DISPUTED TRANSACTIONS — You are required 10 notify PSECU In writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transaction on your account. Telephoning PSECU does not preserve your dispute rights.,You may be required to provide us with documentation to support your dispute claims, In addition, you may be required to complete a standard dispute form outlining the details of your dispute. In cases of fraudulent card use, PSECU will also require a notarized affidavit. In some cases we may ask you to notify the local authorities. It we do not receive the proper requested documentation in the time specified you may be held responsible for the transaction(s) in question, PSECU must adhere to strict dispute timeframes set forth by Visa. 15. SECURITY INTEREST — To secure your account, you grant us a purchase money security interest under the Uniform Commercial Code in any goods you purchase through the account. If you default, we will have the right to recover any of these goods which we have not been paid for through our application of your payments in the manner described in the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have if you are In default to prevent withdrawal of your unpledged credit union shares (Deposits) below the unpaid balance of your account. However, If you give or have given us a specific pledge of your credit union shares (Deposits) by signing the Pledge of Shares or otherwise, or any other security interests for all your debts, your account will be secured by your pledged shares (Deposits) and by the property described in those other security agreements, except for your home. 16. EFFECT. OF AGREEMENT —This Agreement is the contract which applies to all transactions on your account even though the sales, cash advance, credit or other slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance written notice required by law.•Your-use of the card thereafter will indicate your agreement to the amendments. To the extent the law permits, and we indicate in our notice, amendments will apply to your existing account balance as well as to future transactions. 17. LATE PAYMENT CHARGE — II your Minimum Payment is not received by the first day of the month following your due date, you will be subject to a $20 charge. 18. RUSH FEES — You may incur additional charges for rush processing and rush delivery of cards and/or PIN mailer. 19. OVER LIMIT FEE —A $20 fee will be applied for each monthly statement closing date on which the outstanding balance exceeds the assigned credit limit by more than $100. 20. DRAFT COPIES — You may incur an additional charge for transaction summary/sale draft documentation. 21. COPY RECEIVED —You acknowledge receipt of a copy of this Agreement. 22. ILLEGAL TRANSACTIONS PROHIBITED — You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law. 23. NO USE — Inactive Visa accounts that have no purchase or cash activity may be closed without notice to you after 18 months of no activity. 24. NEURAL NETWORK — PSECU uses neural network systems to predict and prevent unauthorized transactions, There may be occasions when a transaction is declined because it is indicative of possible fraudulent activity. �.OANI T I R° Addertdvrn Instrvctians.•7liis addendum is Incorporated into and becomes port of your I.OANLINER Credit Agreement. Please keep attached. ' First Paymenti•Your first payment Is'dye and payable within 30 days from thedate of the loan advance. The Annual" Percentage Rates, corresponding daily periodic rates "and amount of payment for each loon subaccount ore shown below- If therein no.payment schedule, th'e amount and•due dotes "of payments will be determined at the time of each advance and disclosed on the Advance Request Voucher, Advance Proceeds Check,"or ony other loon Youcher,or receipt: Other charges thaat'may be imposed are•alto shown below (i. e; tole choi'gesi filing lees, collection costs): All rates ate -subject to change. • • Default"Rate;" If: your loon is in;default,"the crediilunionreserves,fie rightto charge the highest unsecured interest rate in effect at PSECU,, ally Loon .$vbgccount Descripttan APprox Term In Monihf ; Percent Above index:: Dolly Periodic Rate -loll . Present Annual - Percentage Rate. MinimumPayment (far rash Ito_ or trod, un of 3100 of • jour Ii ii ' .,:olnount) . Auto Loon 411 164 Va14da5.rYiC• $40,000 loon or g,eaipr 320,000 +arae a, omelet." _ yokes . 56.0607giueorgraarnr 36,000n.thun orgroow', 53,000 Yeller ei"grant4r 23.000noloo,,rgianinf Used Vehicles Only $40.404 loot, or gteotar• " _ 520.000 vatur. of ;heater 212,000 whin o.yreroi,,r '. 58,000vulrngigreorur' t6.000valo. orirruaIor - 53.000 vv,I.ic. or gloater ". " 53.000 ,,aloe or grentar ' - " Rn!.anho„al Vehicle: Iinw/lised 121 torso amount $15,000 on3 up . ' lonnomou.a55,000-14,999'. m tonn nam¢ 85,000 ; 7,999 " Loon omen,) 33,000•.4,999 IRA loan (3) Share Loon (3, 4)'- Up lo 51,000. 11,001 . $4,000. Ola. 54,000 ton. ,.a, / 21.006 na to o maAmvr, ul 10 rep,. i C.,itlicata Loon (3; 4, 5) Personal Serrico loon (P51116) Personal Service Signalers! loon 1P551.). • 120 - 84: " ''72' 60 , 48 .36 24 126" e4 72 60' 48.' - 36 24 84 60" 48 36 12 19 ' 48 '. 120 :redislorute. 77 ,up io 65; non)hs . - .2.0 ', 2.0' . - 2.Q :..00008904 ' 2.0 2.0 - . wsthaul Aptomulio, p ym.ni .00019836 .00077781' .0091778,1 .00016411 .00016411. .00016411:" :.00013671 .Ort0iQ836 :0001778) .00017781 .00016411 ..00015726... ".00016411 .00016411 .00013271 • .04024384 da1.021381 .00024364 ._00024384 .00008404 '00002904, ',00668Y64 se d d'..nm" ".000353,12 •0002712 " wtrt,''APt . .00019151'. -700 i 7096' 00017096` .00015716.. .00015726..- . _00015726"' .70012986""• "...O.00019151.. 14i51 .00017096 " .00017096. .00015726. 00015726 .00012986 11/A ti/A N/A I t/A 14/A " N/A_ 14/A FILA _ N/A N/A t)/A wrtheut ' Autemaiic P.eymenl S rvlce 7.24% : ' 6,49% :-6.49% 5.9914 • 5'"99% 5.99°1 4.99: 7,24% 6.49% 6.49% 599% '5.99% '5.99% .199% 8.90% 890' ,- •8,90% 8.90% 3.25% .' 3.255%" " '3.25% 3.25% .tneaniow',. 129% ..990% with APS 6.99% 6.24% 6.24% 5.74%, 5.74% 5.74% 4.74% 6.99% 6.24% 6.24% 5.74% 2.14`k 5.74% 4.74% ' N/A. N/A .-t1/A . bUA 19/A.58.49 N/A N/A - N/A 14/A N/A .N/A ' with tat 'Automatfo . Paymogl. Snob . ..81.18 $1.49. $1.69 11.94 ' 52.35 • 53:05 $4.39'- • 51.18 21.49 " 11.69 $1.94 52.35 _ 13.05 $439 51.60 N/A 52.07 - ' .$2.48 -53.18 . " 55 2 i $2.23 '20.98 -- Wilk `APS 91.17 31,48 $1.67 21.93 52.34 $3.04 24.38 21.17 51.48 $1.67 "51.93 .1234 ' 33;04 34.38 N/A N/A N/A 14/A AI/A N/A N/A It/A 14/A - .'14/A cw,loll ............. ,1 !ulorifaJle,&ymenf""yervl ye {7AR+� .loll. ,:.. ^ n"• _Sot.. .•. ::j:f't ;ti. ,..,; ptrlqtq gtraly fir the' 2506 teduelis?n, m Ilse Irijle tl�i8 loan le set p you {nus) sq)q t fn {love your o ie tc `,. {o x Ha trans{er" st Pa r :i edsi to "i 1r` " dee '44..? 4-. .�S?1t�, ,. 91Au a- yS. Ila 91). ( (S? ,.t?f f.} p!It y t �y..,•,, �-,:,r,.-r,.; �.:; IY:. }' � tr +ax In ecu fi e�and5 1 d00l/eclPl%rvned'n1.Ifuourahi 0i) llsaontinuu,r}rnn,4nrilctiinnii:414'a;driM/,/'i,ita1,1 wiseOn,>1iili' ti?u olgo) 'P 1„. d,y o l P mn. srtl'•s.-..�.,;�,,7i+� . �..r,.:, •: 1Ser.9lcoTeleehaFetr tr Trda,fen. ' 1 SEC P -O, 6oe67013','.1-1orrisbvr9, PA 17106-7013 PSL Mlnikiutn'Poymen: Ramp (pet thousand portion thereof)" FIRST PAYMENT: Your (first payment' is due and payable within 30 days from the dote of the loan advance, Minimum Monthly' Minimum. Biweekly Loan Balance at Time of Advance Payment Payment 19,000,01 to"' 20,000:00 400 200 18 000.01 to. 19,400.00 380 190 't 7,000:01-to'18;000;00 360 180 16",000.01 toI7;000.00 340 170 . 15;000:01 too 16,000.00 320 160 14,000.01 10 15,600.00 -300 1,50 13,000,01 Id 14,000.00 280 140 12,000,01"io 13,000,00 260 130 1 1,000.01 to 12,400.00 240 120 .10,000.01 to 1.1,000.00 220 110 9,000.01 to 10,000.00 200 100 8,000.014O. 9,000.00 180 90 7000.01 to _8,000:00 160 80 6,000.01 to 7,000.00 140 70 5,000.01 to 6,000.00 120 60 4,000,01 to 5,000.00 10.0 50 3,000,01.10 4,000.00 80 40 2;000.01 to 3,000.00 60 30 1,000.01 to 2,000.00 40 20 Up to 1;000.00 20 10 "Personal Service Signalure Loan Mtnlmum Monthly Payment; $100 for original balances from '$1,000 - $5,00,:1700 for original balances from $5,000,01 -510,000 View • Disclosures Finance Charge: inonce Charge (interest) is calculated al the monthly periodic ro on:the average dolly balances of purchases and cosh advances as described below: nd corresponding onnuol percentage rale Viso (Purchases) - Monthly Periodic Rote .00825. Annual Percentage Rote - 9.9% Viso (Cash Advances, Checks) 'Monthly Periodic Rate :01075 Annual Percentage' Rote. =12,9% Minimum Payment:"The minimum monthly payment will be either (o) 2.0% of your total new balance ar $20,00, 'whichever is greater; or (b) your total new balance if it is less than $20.00, plus (c) ony portion of the minrmum payments) shown on prior streemenl(s) which remains unpaid. Collection Costs; You promise to pay all costs of collecting the amount you owe under this agreement including court costs and reasonable attorney fees. Late Charge: You promise to pay a lute charge of 520 if your Minimum Payment is not received by the first day of the month following your due date. Over Limit Charge: You promise to pay on -over limit charge of S20 if you exceed your credit limit by $100 or more. Overdraft Option: If you elect to overdraft to your PSECU Visa Credit Card, that election is subject to the existing credit limit this oddendum and the agreement it represents andthe current loan oliog p p i at the lime o{ the overdraft. You also Y under- stand ,hot an overdraft wilt be considered the some as a cash advance on your PSECU Viso credit cord and that the Current annual percentage rote for cosh advances will apply. TELEPHONE INFORMATION AND MAILING ADDRESS: For all purposes . cis referenced in the Visa Credit Cord Agreement and Truth in Lending Disd6sure, call PSECU of 717.234:8484 in Harrisburg au 800.237.7328 nationwide, or write the Credit Union at: PSECU, P.O. Box 67013, Harrisburg, PA 1'7106-701:3. Pennsytvonto Stora Employaus C,adn Union 90111, #3100 7/08 Cr•dip Lite and:Cro I1•9111 btlllyJnsynpoe:ion.regmlouy6 cutin M_yWa In��nnp. sooleryi • CUtp,MuiesitrisdretiOsoots (cosiPer'$100 of monthly loan balance): single Credit Life- 3.070 6910:*ineral Point Road, Joint. Credit life • 5.123 •Madison, Wisoinsln 5J70i Gredit D(sp611ity Insurance: TheSchedule of Roles shown below ore gross balance rates. This means the rotes ore oppliedto the sunt of the periodic loon payments which remain to be paid on your loon..The rote we rise is deferniined by lite projected loon tern', of your loon (See your loon plan to find the protected term'of yourloan), Forexample, lithe proleded term of your loon is 24 months and the benefit plan iso 14 day nonretroactive, the rote for thetetmis .2950 per 3'100 of gross balance, If the amount.ofyour periodic loonppymenl is.$100, the gross balance of your.loan during the first month of.your loan is $2,400 (14.x .51li100),...0yr:cherige to you for insurance, for the first Month of your loon Ierni would be 52,400 x ,2950 x0.01, or $ 7 08: F:fteryouhays made your lirst$100 periodic loan payment; l he gross balance of your loon would then be $2,300 (23 z cloy and our:charge to you for your insurance for the second month would be $2,300 x .2950 x 0.01; or $ 6.79ietc: The charges we actually make (a you f or yotir insurance are shown in your periodic statement which you receive from PSECU. . • Please remember, whenever you add a new advance toydur loon,.you recast, the loan endo new: p'ro)eded loan term is determined according to your loon plan, Please note also that lithe amount of yourperiodic loon paymentis greater than the maximum benefit per month shown tlithe insurance schedule of your certificofeof insurance ourchdrgeto you is bored onthe sum of the maximum benefits per Month times the number of periodic loon payments rernainingto be paid an your loan, Forexample, If yourpetiodic loon-poyment.is S400 and the maximum benefit permonth is $300and you have 24 payments remainingto be paid, the gross bolonce ofour loon for purposes of this insurance would:be $7,200 (01:V;600)and our:charge to you for insurance the first month. would be 121:24 (57,200 x .2950 x0.01). Pennsylvania Monthly Renewable Credit Disability - Disclosure Rotes Per $100 of Coverage Per Month TERM RATE TERM RATE. IEBM .R ATF TERM MTE 0000 31 33 34 35 36 2 0.0000 3 0:0000 4 0.5.395 5 0.5627 6 0,5796 7 0.5372 8 0:5070 9 0:4804 10 0:4587 11 0.4407 12 0.4254 13 0.4069 14 0.392.4 15 0.3784 16 0.3643 17 0.3548 18 0.3448, 19 0.3346 20 0.3242 21 . 0.3171 22 0.3083 23 0.3013 24 0,2950 25 0.2882 26 0.2817 27' 0.2759 28 0.2713 29 0.2670 30 0.2614 38 39' 40 42 43 0.2561 0:2519 0.2479: 0.2443: 0.2408. 0,2367 0.2322 0.2300 0.2260 0.2234 0.2203 0:2180 0.2152. 44 0:2125 45 0.2099 46 0.2074 47 0.2056 48 0,2028 49 50 51 52 53 54 55 56 58 60 0.2012 0.1985 0.1966 0.1947 0.193.4 0.1910 0.1889 0.1878 0;1858 0.1837 0.1828 0.1809 61 62 64 66 67 68 7D 72 0.1791 0.1783 0.1.766 0.1753 0.1742 0`.1730 0.1716 0.1700 0.1695 0.1681 0:1667 0:1658 73 0.1645 74 0,1633 75 0.1624 76 0.1613 77 0.1605 78 0:1593 79 80 81 82 .83 84 85 86 88 90 0.1583 0:1573 0.1565 0.1556 0.1545 0:1539 0.1530 0:1521 0.151.4 0,1507. 0.1498 0:1493 91 0.1485- 92 0.1480 93 .0.1468. 94 0:1.460 95 0.1454 96 0.1449 97 98 100 011 102 103 105 106 108 0.1442 0.1438 0:1428 0.1422 0.1418 0.1411 0.1405 0.1396 0.1391 0.1387 ;3z= 0.1379 0.1375 109 0.1370 110 0:1365 112 0.1.355 113 0.1352 114 0.1347 115 1167 119 120 0.1342 0.1336 0.1333 0.1327 0.1320 011316 • Loan Disclosures Late Charge: If you ore more' than 15 days tote in making q payment, you will:pay. a lute charge equal to five percent of the scheduled payment. Collection Costs: You promise to'poy all costs of collecting the amount you': owe under this agreernent, including court casts and fees paid to outside collectors or collection agencies up to 20 percent of, the outstanding loon balance, (1) PSECU will finance up to 100 percent of the -retail value of a new, current model yeorvehide (untitled). PSECU will firionce up to 103 percent of the retail value of a'used motor vehicle (titled): The Kelley Blue Book® (registered trademark of Kelley Blue Book Co. Inc.) or -other outhoriied.guides will used to determine yourvehicle's value. Auto loans cannot be used to purchase' commercial,theft; salvaged or flood titled vehicles. The vehicle'muslbetitled Fe; the Borrower, Co -Borrower, or both. The registered owner on the Certificate of Title May not . be a business, corporation ortrust entity. Vehicles must have a minimum value of $3,000 and must -he titled in' the U.S: and may not betaken out of the U.S. (2) PSECU will finance up to 90 percent of the retail value of o new (untitled, current model year) recreational vehicle. Used(tilled) recreational vehicles may befinanced up to90 percent of the used retail volue;_The:Kell'ey Blue Book®. or other authorized guides will be used to determine the recreational vehicle's retailvalue.. PS ECU's minimum RV loon Is $3,000. Your RV must have a minimum reboil value of $3,333. (3) The Annual Percentage: Rate (APR) for share secured and IRA advances will.be the. dividend rote being paid anregulorshares. (Index) on the date of the advance plus the percentage shown. in the'!PercentAbove Index" column. If there is an existing balance on the date of the new advance, the existing balance will be added to the new advance and the entire balance will be at the.newAPR. The rates are subject t6 change td reflect any change in the index; Arty increase in the.APR will take the form of more payments of the . some amount until what youowe:has been repaid. Loan rates on Certificate and IRA loons will riot.fluctuate during the course of the loan. (4) Shares or certificates pledged must be owned by the Borrower or Co -Borrower unless the Share or Certificate owner authorlies the pledge in writing. (5) PSECU will grunt loans secured by Shore Certificates; Maximum financing. is 90% of the Certificate pledged. The Annual Percentage: Rote (APR):for Certificateldans secured by mulliple'cettificotes will be based on the certificate earning the greaterdividend; The term for Certificate (bans secured by multiple certificates will be limited to the longest term remaining among then. Early withdrawal of the unsecured portion is not.permifted and the loan balance will be due in full if the Certificate is withdrawn prior to maturity. Monthly.dlvidends are paid into the Certificate. At maturity, you authorize PSECU to redeem the Certificate to pay any remaining loan balance, Funds remaining after repayment of the loan will be deposited to Regular Shares if you do not contact PSECU on orbefore the maturity date; Automolic renewal of the Certificate pledged cannot occur until the loan balance is paid in full. (6) if you have been approved for credit under this account, you will be given a specific credit limit. This audit union is ledo,olly insured 6y the Notional Crede Union Admintstrailoa. Equal Opponunity Londe, 1523 ,OM (kmhoriK. lion .1(o3 571 repo • Pennsylvania State Employees Credit Union •••• ORDER OF (DEALER) • otaL .4, AGTODRFT : . ,.• ,».• , PO Box..)67013 • tlantsburg, PA 17104.70i3 (717) 234.8484 or MOO) 2374328 • • VOPD OVEFP s;280011:00.:Z-"•:-',REFERENc, E- .8847930107 VOID .120 .DAYSIAFTER., 08/18/2906 ' • ,.•.j -•-• • • • •••• • ' • ' ' 51:cOlj -• p • - !.• • •• • " • ' ' r • • t -r•-•." ct. • %.* /CC DOLLARS . • IMPORTANT; VDU) UNLESS DEALER ENDORSEMENT COMPLETED ..1...., 13..tritei.t...0r4ir ilMccii Sleierew end Llseri.Vehloley and fociory imrorte (N;vi Vehoffesi must be'rece-ded behrie'the AmoDratt is reotived by PSECU or the.Atfobrott moll be', • ri ren.erred. fro portion of the proceeds at the AuloOrof t shall be.pard to the. Borrower's) ..• cr to any agent at the BerrowcrieL This tterloOralr shaft not bo used to yerrehros tsconstructeeL carnmetciel, classlc,,Malt, salyagscl, or flood Iltled.frehlelas or vehicles toted QUM& Ws polled States. By.00r..cii,trg theirroceeds of ihre dr'Sit 'you awe' to • the tents bend on Oho 'reverse ode. ; :/.. .,.../ PSlitli Klika• 7ii-7r743364 ,-./ VIN S , ' , ,,, • _ '.• ..., Y....- N , . YE HOSEMAKE , M005 • . He prem”Sth— ..'.' . puoCM tam , t •_„&s..fp * • , • r. ,,,„ • MEMBER Et•tpoctsem*T.%.• • or • ' ..r.• • • • eneorsing,this i)ptpprati,"..1tWe agree to ttie terms listed. on The reverse sizie tfiridrort:etorriploteMel.fallowing repayment intormailon, Term Months): Re! et to Mothrerrn TAMS in the thcJoigir Vehrcle Loans Brochure.. . , oupon 0 °Kett Payment Method cm Transfer 0 HOrnebewtica 0 Pyran &Moflthi Freliuency: iMonihly ;0 13r -Weekly 0 Weekly 0 ' SamilAtinth :Meni6t EC;40T;errie ,13-444/1 ^ • r. • • ; • ROBERT K BURNS , • , • • .•• •• - • • . • Co -Applicant Endorsement • ..,4/13b2_ / " •,`; • ., t• • •• ppLicarsr:).: ' • es6001,0„..1;.231:381116t: • • 3103 ?Ott 23 .44 .0'000 249945E10 37842 090406 6492 4780. 06 040 FT,'E-PH31-P, 04 TRC=1305 PK ='26 • 0327675440 P025 1:11 P 06/3i/2006 in in 321 rn te -Im Dr 0 M 0 cri or" Sim z r - m -i rn as Ore 31)> Min t- 031 m z (O -o -m zm El 'l 4181246 EXHIBIT "B" CERTIFICATE OF TITLE FOR A VEHICLE ODOMETER STATUS . ." =:ACTUAL MILEAGE - • I = MILEAGE EXCEEDS THE MECHANICAL-I:I LIMITS 2 = NOT THE ACTUAL miLaAdE -?.:!! 3 = NOT THE ACTUAL MILEAGE-ODOMETER:'4 TAMPERING VERIFIED 4 = EXEMPT FROM ODOMETER DISCLOSURE . • ...TITLE BRANDS . A = ANTIQUE VEHICLE. C CLASSIC )/EHICLB-•. = COLLECT/BLE.VEHICLE F OUT OF COURTiily,y4: • G = ORIGINALLV:MFGD:,'EbR'isti .DISTRIBITTION H = AGRICULTURAL VEHICLE L LOGGING VEHICLE'' •• P ISMIAS A POLICE VEHICLE R = TIECONSTRUCTEV›, S = STREET ROD T RECOVERED.TH4FT,yau V =•VEHICLE cONTAINSRE.SSJE W = FLOOD VEHICLE •-**',..•'ss,. X ='ISANASA TAXI If a second Penholder Is listed upon satiated* of th first Ilen2411 Penholder must (reward this Title to the Bureau of IthftZ appropriate Rion and fee. SECOND LIEN RELEASED - - PSECU P 0 BOX 67013 HARRISBURG PA 17106 I certify as of the date of Issue, the official records et the Pennsylvania Department of Transportation rennet that the person(s) or company named herein is the lawful owner of the said vehicle., av:ritimo.6,•Atr- -J4'4._,Tv;:. eragiyii SUBSCRIBED AND SWORN TO BEFORE ME: ALLEN D .BIEHLER. Secretory of Transportation .,1148046SETC,,WttEqtF,Y.E:ltr9LE-Osl,iSol4r- !PP_ THE ,.COMEVE V17 R47SFrA' 'T,PA4C)U!1'5W-- ARE If a co -purchaser other than your spouse is listed and you Warit the title t be listed as 'Joint Tenants With Right of Survivorthip° (On de0,9(„,,,nne owner, title goes to surviving owner) CHECK HERE 1:2 Othenvisettitillti will be issued as 'Tenants In Common” (On death of one-owner-(nthTMtof deceased owner goes to his/her heirs or estate)., IF NO LIEN, CHECK0 IS THIS AN ELT? (IF YES, FIN REQUIRED) YES 0NO0 1ST LIENHOLDER FINANCIAL IFISTITUDON NUMBER:* 1ST LIENHOLDER NAME STREET. r\) 00 OD OD CO The uodetstgned booby motion appltradon ter Cedillude of Tile to the venue described above, collect Is lilaencumbrances and other legal cleans set ions hero. CITY STATE IF NO 2ND LIEN, CHECK 0 IS THIS AN ELT? (IF YES, FIN REQUIRED) YES 0 NO0 2ND LIENHOLDER FINANCIAL INSTITUTION NUMBER: 2ND LIENHOLDER NAME SIGNATURE OF APPLICANT OR AU'n'IORIZED SIGNER CITY STATE ZIP EXHIBIT "C" 4181246 ATTORNEYS AT LAW 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com December 12, 2013 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL Mr. Robert K. Burns 402 Pawnee Drive Mechanicsburg, PA 18050-2546 Shawn M. Long, Esquire Direct Dial Number: 717.399.1512 E-mail: slong@barley.com Re: Pennsylvania State Employees Credit Union/2006 Chrysler 300 Dear Mr. Robert K. Burns: 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 2006 Chrysler 300 (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 March 1, 2013 payment in the amount of $352.52 and each monthly payment thereafter in the amount of $371.07. 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 $8,094.60 as of November 20, 2013 (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. You have the right to dispute the validity of the Debt in its entirety or any portion of it. Unless you dispute the validity of the Debt or any portion thereof, within thirty (30) days after 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 -. _ v_ 1_ T)....4:...... 1 . Bark Sn der ATTORNEYS AT 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com December 12, 2013 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL Mr. Robert K. Burns 402 Pawnee Drive Mechanicsburg, PA 18050-2546 Shawn M. Long, Esquire Direct Dial Number: 717.399.1512 E-mail: slong@barley.com Re: Pennsylvania State Employees Credit Union/2006 Chrysler 300 Dear Mr. Robert K. Bums: 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 2006 Chrysler 300 (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 March 1, 2013 payment in the amount of $352.52 and each monthly payment thereafter in the amount of $371.07. 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 $8,094.60 as of November 20, 2013 (the "Debt"). PSECU has authorized me to demand that you pay the Debt in full or make arrangements to deliver possession of the Vehicle to PSECU's designated repossession agent within thirty (30) days from the date of this letter. If you do not comply with this demand, PSECU is prepared to initiate legal proceedings against you, and to exercise its other available remedies. You have the right to dispute the validity of the Debt in its entirety or any portion of it. Unless you dispute the validity of the Debt or any portion thereof, within thirty (30) days after receipt of this notice, we will assume that the Debt is valid. If you notify this office in writing within the thirty -day (30 -day) period that the Debt, or any portion thereof, is disputed, we will obtain the verification of the Debt and mail a copy of such verification to you. Upon your Lancaster • York • Reading • Malvern • Hanover December 3, 2013 Page 2 written request within the thirty -day (30 -day) period, we will provide you with the name and address of the original creditor, if different from the current creditor. If you do not act in accordance with the terms as stated above within thirty (30) days from your receipt of this letter, our client is prepared to initiate civil litigation proceedings to collect the Debt, together with interest and costs of collection allowable by law, and intends to exercise its rights and remedies in connection with the Vehicle and your account. 4134195 cc: Mr. Greg Diffenderfer Very truly yours, UNITED STATES POSTAL SERVICE ion " U.S. POSTAGE PAID READING,PA 19601 DEC 13.'13 AMOUNT 1n T i 00033113-07 ca h L TO:ROBERT K. BURNS 413i . VITME NP$. 050 MECHANICSBURG, PA 18050 010 $3,1,0 07 $0.00 SENDER: $0.00 KC REFERENCE: $3,56 12/13/2013 PSECU/ BURNS 7196 9008 9040 2198 3086 PS Form 3800, January 2005 RETURN Postage RECEIPT SERVICE Certified Fee Return Receipt Fee Restricted Delivery 0.92 10 1.25 0.00 Total Postage & Fees LISPS' Receipt for Certified Mail" No Insurance Coverage Provided Do Not Use for International Mail 1'O§TMAR Gl 23 VERIFICATION Pennsylvania State Employees Credit Union v. Robert K. Burns I, Julie Serino, being duly affirmed according to law, depose and say that I am the Director, Member Services 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: 1,1/a�� 4181246 EXHIBIT "B" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ‘0.0.,,,,Vti t CUM OFFICE OF 'NE SI-tfiRIPC Pennsylvania State. Employees Credit Union vs. Robert K. Burns Case Number 2014-615 SHERIFF'S RETURN OF SERVICE 03/05/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert K. Burns, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 402 Pawnee Drive, Hamdpen Township, Mechanicsburg, PA 17050. Twelve attempts at service were made but deputies were unable to make contact with anyone at the residence to make service. SHERIFF COST: $73.20 SO ANSWERS, March 05, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Shoritf, Teleosoff. Inc. EXHIBIT "C" Results View: Results List I Full I Visualize Re 1 of 1 Search: Public Records > Comprehensive Person Report > Search Results > Source Documents Terms: ssn(163-58-8871 state(ALL) radius(30) ( Edit Search I New Search ) Report Contents Top of Report Subiect Summary Others Using SSN Address Summary (15) Voter Registrations Driver Licenses Professional Licenses Health Care Providers Health Care Sanctions Pilot Licenses Sport Licenses Weapon Permits Real Property Assets (2) Motor Vehicle Registrations Boats Aircraft Bankruptcy Information Judgments/Liens (4) UCC Liens Fictitious Businesses Notice Of Defaults Potential Relatives (81 Business Associates Pers p c1orl W 04,eesseu by: Nei. YDER (100VJ2) Employment Locator (1) Crim'iFalll=i1a131(4) Sexui®URT KEITH Cellulicl Ol Aite I [cite FOR INFORMATIONAL PURPOSES ONLY Copyright 2014 LexisNexis a division of Reed Elsevier Inc. All Rights Reserved. Page 1 of 7 Save as Alert 17 Select for Delivery Address 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 County YORK Phone 4111111111100-0387 Morl§OtilITIONAL PERSONAL INFORMATION iources (108) SSN DOB Gender LexID(sm) 11/1960 (Age:53) 000328471896 1163-58-XXXX Further Searches Health Care View All Name Variations Sources Provider Heap Subject Summary PrON�rrSerVheltBtiOs Marti � W T K RecQ uRNs, BOB ForeciOstmActlivitv I Statl i I5URNs, ROBERT Real Skids$, ROBERT K VOIU IIPW�9 a ROBERT KEITH Transaction https : //r3 .lexis. com/lexi sprma/ReportResults. aspx?doclD=1 &nextReportDo cID=&previou... 3/18/2014 Results SSNs Summary Page 2 of 7 View All SSN' Sources No. SSN State Iss. Date Iss. Warnings Most frequent SSN attributed to subject: 1: 163-58-XXXX Pennsylvania 1977-1979 NAQJ SMotor V e n d p AE£isls Aborts : 11/1960 1961 View All DOB Sources Possible E -Mail Addresses View All E -Mail Sources AUSTIN 1539@COMCAST. N ET YOUKNOWITl@AOL.COM El Address Summary - 15 records found View All Address Variations Sources No. Address Actions 1: 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 YORK COUNTY Get Report View Details 2: 402 PAWNEE DR MECHANICSBURG, PA 17050-2546 CUMBERLAND COUNTY Get Report View Details 3: 402 PAWNEE DR • DILLSBURG, PA 17019 YORK COUNTYView Get Report Details 4: 144000 ELLA BLVD 1203 HOUSTON, TX 77014 HARRIS COUNTY Get Report View Details 5: 4989 COLUMBIA RD APT 103 COLUMBIA, MD 21044-5541 HOWARD COUNTY Get Report View Details 6: 136 ANNIE LN ROCHESTER, NY 14626-4373 MONROE COUNTY Get Report View Details 7: 4989 103 COLUMBIA RD COLUMBIA, MD 21044 HOWARD COUNTY Get Report View Details 8: 4505 STEARNS HILL RD WALTHAM, MA 02451-7146 MIDDLESEX COUNTY Get Report View Details 9: 4505 STEARNS RD WALTHAM, MA 02154 Get Report - View Details 10: 14000 ELLA BLVD APT 1203 HOUSTON, TX 77014-2577 HARRIS COUNTY Get Report View Details 11: 303 FRATERNITY ROW STATE COLLEGE, PA 16801-5402 CENTRE COUNTY Get Report View Details 12: 2527 POLOMAK RICHMOND, VA 23233 HENRICO COUNTY Get Report View Details 13: 1400 ELLA BLVD APT HOUSTON, TX 77008-5142 HARRIS COUNTY- Get Report View Details 14: . 2527 POTOMAC HUNT LN APT 1 HENRICO, VA 23233-1553 HENRICO COUNTY Get Report View Details 15: 402 PAWNEE LN CAMP HILL, PA 17011 CUMBERLAND COUNTY Get Report View Details Address Details 1: 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Address Dates Phone Actions` 510 RIDGEVIEW DR " DILLSBURG, PA 17019-1379 YORK COUNTY 9/1996 - 3/2014 (1 387 Get Report , • Neighbors(10) https://r3 .lexis.con/lexi sprma/ReportResults. aspx?doclD=1 &nextReportDoclD=&previous .. 3/18/2014 Results Page 3 of 7 Census Data for Geographical Region Median Head of Household Age: 38 Median Income: $64,442 Median Home Value: $168,640 Median Education: 14 years Household Members BURNS, LAUREN A Get Report Other Associates DEWEES, JEFFREY M Get Report 2: 402 PAWNEE DR MECHANICSBURG, PA 17050-2546 Address -T Dates ' Phone Actions 402 PAWNEE DR MECHANICSBURG, PA 17050-2546 CUMBERLAND COUNTY 4/1983 - 2/2012 ,-0082 Get Report Census Data for Geographical Region Median Head of Household Age: 44 Median Income: $96,658 Median Home Value: $205,090 Median Education: 15 years Household Members BURNS, ELIZABETH A Get Report BURNS, ELIZABETH A Get Report BURNS, ELIZABETH A Get Report ,BURNS, ROBERT E Get Report BURNS, ROBERT EDWARD Get Report BURNS, ROBERT F Get Report DAVIS, DEBORAH ANN Get Report Other Associates None Listed 3: 402 PAWNEE DR DILLSBURG, PA 17019 Address Dates Phone Actions 402 PAWNEE DR DILLSBURG, PA 17019 YORK COUNTY 11/2010 - 1/2011 0082 Get Report Census Data for Geographical Region Median Head of Household Age: 32 Median Income: $53,966 Median Home Value: $128,958 Median Education: 13 years Household Members None Listed Other Associates None Listed 4: 144000 ELLA BLVD 1203 HOUSTON, TX 77014 Address Dates Phone Actions 144000 ELLA BLVD 1203 HOUSTON, TX 77014 HARRIS COUNTY 4/2003 - 4/2003 Get Report Household Members None Listed Other Associates None Listed 5: 4989 COLUMBIA RD APT 103 COLUMBIA, MD 21044-5541 Address Dates Phone Actions 4989 COLUMBIA RD APT 103 •4/1983 COLUMBIA, MD 21044-5541 HOWARD COUNTY - 1/1999 (273 Get Report https://r3.lexis.com/lexisprma/ReportResults.aspx?doclD=1 &nextReportDocID=&previou... 3/18/2014 Results Page 4 of 7 Census Data for Geographical Region Median Head of Household Age: 31 Median Income: $88,010 Median Home Value: $399,524 Median Education: 15 years Household Members None Listed Other Associates None Listed 6: 136 ANNIE LN ROCHESTER, NY 14626-4373 Address Dates ! Phone 1/1996 11/1998 !(273 E• Actions Get Report 136 ANNIE LN ROCHESTER, NY 14626-4373 MONROE COUNTY Census Data for Geographical Region Median Head of Household Age: 39 Median Income: $78,512 Median Home Value: $163,835 Median Education: 14 years Household Members. None Listed Other Associates None Listed 7: 4989 103 COLUMBIA RD COLUMBIA, MD 21044 Address Dates Phone Actions 4989 103 COLUMBIA RD COLUMBIA, MD 21044 HOWARD COUNTY 1/1996 - 1/1996 '2273 Get Report Census Data for Geographical Region Median Head of Household Age: 38 Median Income: $103,819 Median Home Value: $379,882 Median Education: 16 years Household Members None Listed Other Associates None Listed 8: 4505 STEARNS HILL RD WALTHAM, MA 02451-7146 Address Dates Phone Actions 4505 STEARNS HILL RD WALTHAM, MA 02451-7146 MIDDLESEX COUNTY 12/1991 - 12/1995 (48 Get Repor Census Data for Geographical Region Median Head of Household Age: 35 Median Income: $81,824 Median Home Value: $355,882 Median Education: 15 years Household Members None Listed Other Associates None Listed 9: 4505 STEARNS RD WALTHAM, MA 02154 Address Dates Phone Actions 4505 STEARNS RD WALTHAM, MA 02154 10/1995 - 10/1995 Get Report Household Members None Listed • https://r3.lexis.com/lexisprma/ReportResults.aspx?doclD=1 &nextReportDoclD=&previou... 3/18/2014 Results Page 5 of 7 Other Associates None Listed 10: 14000 ELLA BLVD APT 1203 HOUSTON, TX 77014-2577 Address Dates Phone Actions 14000 ELLA BLVD APT 1203 HOUSTON, TX 77014-2577 HARRIS COUNTY 10/1988 - 2/1992 Get Report Census Data for Geographical Region Median Head of Household Age: 24 Median Income: $27,582 Median Home Value: $0 Median Education: 13 years Household Members None Listed Other Associates None Listed 11: 303 FRATERNITY ROW STATE COLLEGE, PA 16801-5402 Address Dates Phone Actions 303 FRATERNITY ROW STATE COLLEGE, PA 16801-5402 CENTRE COUNTY 4/1983 - 12/1991 082 Get Report Census Data for Geographical Region Median Head of Household Age: 21 Median Income: $10,748 Median Home Value: $65,000 Median Education: 13 years Household Members None Listed Other Associates None Listed . 12: 2527 POLOMAK RICHMOND, VA 23233 Address Dates Phone Actions 2527 POLOMAK RICHMOND, VA 23233 HENRICO COUNTY 11/1989 - 11/1989 Get Report Census Data for Geographical Region Median Head of Household Age: 34 Median Income: $103,989 Median Home Value: $291,092 Median Education: 15 years Household Members None Listed Other Associates None Listed 13: 1400 ELLA BLVD APT HOUSTON, TX 77008-5142 Address ' Dates Phone Actions 1400 ELLA BLVD APT HOUSTON, TX 77008-5142 HARRIS COUNTY 11/1988 - 11/1988 Get Report Household Members None Listed Other Associates None Listed 14: 2527 POTOMAC HUNT LN APT 1 HENRICO, VA 23233-1553 Address I Dates Phone i Actions https://r3.lexis. com/lexisprma/ReportResults. aspx?doclD=1 &nextReportDocID=&previou... 3/18/2014 ttp 7r3' 1exis.com/lexisprma/Kepoortr X U1ts.aspx?doc1D=1 &nextReportDoclD=&previou... 3/18/2014 Results Page 6 of 7 12527 POTOMAC HUNT LN APT 1 1HENRICO, VA 23233-1553 HENRICO COUNTY 111/1987 -11/1987 Get Report Census Data for Geographical Region Median Head of Household Age: 36 Median Income: $65,947 Median Home Value: $190,774 tMedian Education: i Household Members 15 years None Listed Other Associates None Listed 15: 402 PAWNEE LN CAMP HILL, PA 17011 Address Dates Phone Actions 402 PAWNEE LN CAMP HILL, PA 17011 CUMBERLAND COUNTY 11/1985 - 4/1986 0082 Get Report Census Data for Geographical Region Median Head of Household Age: 42 Median Income: $82,500 Median Home Value: $171,814 Median Education: 13 years Household Members None Listed Other Associates None Listed El Real Property - 2 records found View Real Property Sources 1: Assessment Record for YORK County, PA Owner Information Name:'BURNS LAUREN A Name:,BURNS ROBERT K Address: 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Automated Valuation Report County/FIPS:YORK Property Information Address:1510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Automated Valuation Report County/FIPS: YORK Data Source: A Legal Information Assessor's Parcel Number: 58-000-03-0080-00-00000 Book/Page: 1273/6145 Sale Information Sale Date:. 09/30/1996 Sale Price: $149000 Assessment Information Assessed Value: $177830 Market Land Value: $40220 Market Improvement Value: $137610 Total Market Value: $177830 2: Deed Record for YORK County Buyer Information Name: BURNS, ROBERT K Name: 'BURNS, LAUREN A Address:1510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 County/FIPS: IYORK Automated Valuation Report Seller Information https://r3.lexis.com/lexisprma/ReportResults.aspx?doclD=1 &nextReportDoclD=&previou... 3/18/2014 Results Page 7 of 7 Name: BURNS, LAUREN A Name: BURNS, ROBERT K Name: DEWEES, LAUREN A Address: 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Automated Valuation Report County/FIPS: YORK Property Information Address: 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Automated Valuation Report County/FIPS: YORK Data Source: B Lender Information Name: COLUMBIA NATIONAL INC Legal Information Assessor's Parcel Number: 58-03-0080 Contract Date: 11/09/2000 Recording Date: 11/22/2000 Document Number: 2000066830 Document Type: INTERFAMILY TRANSFER & DISSOLUTION Book/Page: 1417/4554 Mortgage Information Loan Amount: $123950 Loan Type: FHA Title Company: LAWYERS TITLE INSURANCE CORP https://r3.lexis. com/lexisprma/ReportResults. aspx?doclD=1 &nextReportDoclD=&previou... 3/18/2014 EXHIBIT "D" Richard P Keuerleber Sheriff Michael S. Hose Chief Deputy, Operations SHERIFF'S OFFICE OF YORK COUNTY PENNSYLVANIA STATE EMPLOYEES CREDIT UNION vs. ROBERT K. BURNS PETER J. MANGAN, ES Soiici Richard E Rice Chief Deputy, Administrate Case Number 14-615 CIVIL 04/02/2014 04/07/2014 SHERIFF'S RETURN OF SERVICE 03:25 PM - DEPUTY MICHAEL S. ECKARD, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: ROBERT K. BURNS AT 510 RIDGEVIEW DRIVE, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED. I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: ROBERT K. BURNS, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT & NOTICE AS "NOT FOUND" AT 510 RIDGEVIEW DRIVE, DILLSBURG, PA 17019. SHERIFF COST $44.20 April 07, 2014 NOTARY Affirmed and subscribed to before me this 7TH day of APRIL 2014 S, N VERS, IC RD P KEUERLEBER, SHERIFF cor MoNWEALm OF PENNSYLVANIA Notarial.Seal Sheila E. Cook, Notary Public City of York, York County My Commission Expires Feb. 1, 2017 P FNNSYL. ,,,N'fq ASSOC.ATION OF NOTARIES EXHI13IT "Esq ATTORNEYS AT LAW 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com Kelly Neumann, Paralegal Direct Dial Number: 717.399.1528 E-mail: kneumann@barley.com April 22, 2014 To: Postmaster U. S. Postal Service MECHANICSBURG, PA 17050 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION Please furnish the new address for the following individual or verify whether or not the address given below is one at which mail for this individual is currently being delivered. If the following address is a post office box, please furnish the street address as recorded on the boxholder's application form. Also include any address listed on a permanent change of address order application (Form 3575): Name (if known) ROBERT K. BURNS Last Known Address 402 PAWNEE DR City, State, ZIP Code MECHANICSBURG, PA 17050 The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii): 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney. 2. The names of all known parties to the litigation: Pennsylvania State Employees Credit Union vs. ROBERT K. BURNS. 3. The court in which the case has been or will be heard: CUMBERLAND County Court of Common Pleas. 4. The docket or other identifying number if one has been issued: 2014-615 5. The capacity in which the customer is to be served (e.g., defendant or witness): Defendant, ROBERT K. BURNS. 6. A brief description of the nature of the litigation (e.g., domestic relations, personal injury, property damage, indebtedness): indebtedness. Lancaster • York • Reading • Malvern • Hanover Bane Sn der ATTORNEYS AT LAW April 22, 2014 126 Eastfa�Stfet Lancaster, 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com I certify that the above information is true and that the name and/or street address of the customer is needed and will be used solely for service of legal process in connection with actual or prospective litigation. FORWARDING: Signature (J Kelly Neumann, Paralegal Printed Name Barley Snyder Address 50 N. Fifth Street, P.O. Box 942 Addres's Reading, PA 19603-0942 City, State, ZIP Code FOR POST OFFICE USE ONLY Name Street Address City, State, ZIP Code 4287451_1 No change of address on file. Not known at address given Moved, left no forwarding address. No such address. Postmark Lancaster • York • Reading • Malvern • Hanover EXHIBIT "F" Bane Sn der ATTORNEYS AT LAW 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com Kelly Neumann, Paralegal Direct Dial Number: 717.399.1528 E-mail: kneumann@barley.com April 22, 2014 To: Postmaster U. S. Postal Service DILLSBURG, PA 17019 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION Please furnish the new address for the following individual or verify whether or not the address given below is one at which mail for this individual is currently being delivered. If the following address is a post office box, please furnish the street address as recorded on the boxholder's application form. Also include any address listed on a permanent change of address order application (Form 3575): Name (if known) ROBERT K. BURNS Last Known Address 510 RIDGEVIEW DR City, State, ZIP Code DILLSBURG, PA 17019 The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii): 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney. 2. The names of all known parties to the litigation: Pennsylvania State Employees Credit Union vs. ROBERT K. BURNS. 3. The court in which the case has been or will be heard: CUMBERLAND County Court of Common Pleas. 4. The docket or other identifying number if one has been issued: 2014-615 5. The capacity in which the customer is to be served (e.g., defendant or witness): Defendant, ROBERT K. BURNS. 6. A brief description of the nature of the litigation (e.g., domestic relations, personal injury, property damage, indebtedness): indebtedness. Lancaster • York • Reading • Malvern • Hanover Bane Sn der ATTORNEYS AT LAW pn 126 Eastii gASt eet Lancaster, PX 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.c°"' I certify that the above information is true and that the name and/or street address of the customer is needed and will be used solely for service of legal process in connection with actual or prospective litigation. FORWARDING: 4287451_1 Kelly Neumann, Paralegal Printed Name Barley Snyder Address 50 N. Fifth Street, P.O. Box 942 Address Reading, PA 19603-0942 City, State, ZIP Code FOR POST OFFICE USE ONLY Name Street Address City, State, ZIP Code No change of address on file. Not known at address given Moved, left no forwarding address. No such address. Lancaster • York • Reading • Malvern • Hanover EXHIBIT "G" PeopleMap Report (Premier) 7/18/2014 12:16:32 PM ROBERT K BURNS Client ID:OFFICE Possible People Information Person Overview ROBERT K BURNS 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Phone Number(s): AINEMB-4599 SSN: 163-58-XXXX - issued in PA in 1977-1979 Date of Birth Summary Date of Birth Source Experian Credit Header Real Time SSN Summary SSN 163-58-XXXX - issued in PA in 1977-1979 Source I Experian Credit Header Real Time { People Historical Phone Numbers Phone Source Lr 0387 Experian Credit Header Real Time X4599 Experian Credit Header Real Time Name Variations Name Source ROBERT KEITH BURNS '� Experian Credit Header Real Time ROBERT K BURN ± Experian Credit Header Real Time i ROBERT BURNS Experian Credit Header Real Time i BOB BURNS f Experian Credit Header Real Time j BURNS ROBERT r f Experian Credit Header Real Time ROBERT K BURNS � Experian Credit Header Real Time I Addresses WestlawNext- © 2014Thomson Reuters. No claim to original U.S. Government Works. 2 EXHIBIT "1-1" Robert K Burns Phone and Address Zabasearch.com Free People Search Page 1 of 2 ZA BA® SEARCH Find People SeaPeople in HonestlyUSA. Free!Free Search by Name. rch.the People Like 9.6k 1.8k White Pages Reverse Phone Lookup ZabaSearch Advanced Free Search Menu Top 25 Name Searches Premium Services: Run a Background Check 1 Search by Phone Number Robert K Bums Search Narrow your results by: j Filter 1 Public Information Results Summary: 3 Results found for Robert K Burns Robert K Burns - Detailed Background Report Comprehensive Report. Criminal Records. Latest Contact Information. Find Robert K Burns Get Current Phone and Address Can't find Robert K Burns? 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Intelius.com/Premier-Trial http://www.zabasearch.com/people/robert+k+burns/pa/ 7/28/2014 EXHIBIT I Search Results for Robert Burns - PeopleFinders.com Page 1 of 3 - advertisement - peopfef nde s - People Search Background Check Criminal Records Public Records My Account 1 My Reports 1 Log In Sign up for a membership» Genealogy Search Reverse Phone First Name:MI: Last Name: City: State: Age: Date of Birth: Rri-obert _ _ _ Burns j J Pennsylvania I I Month I Day i i Year d, Update Search 20 people named Name Robert A Bums Robert A A Burns Burns R Bums R A Robert Age 84 Burns in PA Has Lived In West Chester, PA Berwyn, PA Bryn Mawr, PA Newtown Sq, PA Wayne, PA Found! Click a Name to Possible Relations Brian Burns Carol H Bums Floranne M Burns Lindsay F.Burns Robert Brian Bums More relatives... View More Info. Phone Number, Address & Other Details View Details 2. Robert A Bums Robert A Bums SR Robt A Burns JR 42 Moscow, PA Milford, PA Peckville, PA Madison Township, PA Lake Ariel, PA Brian R Bennett Brian Randall Bennett Linda E Bums Paul D Bums Roberta Burns More relatives... View Details 3. Robert B Bums Robert B Bums JR Robt 6 Bums JR 67 Uniontown, PA Morgantown, WV Belle Vemon, PA Mount Morris, PA Sioux Falls, SD Gilbert J Bums Gilbert J Bums Robert C Burns Robert J Bums Sharon L Burns More relatives... View Details 4. Robert C Burns Cartland Cartland Burns Robert G Burns Bums R Burns R C 50 Orlando, FL Pittsburgh, PA Batesville, VA Omaha, NE Crozet, VA Arthur Wellwood Burns Linda L Bums David R Hemeter Jill Marie Kohlscheen David Ruffin Redwine More relatives... View Details 5. Robert C Burns Robert Cheri Burns JR Rob Charl Bums SR Robt Charl Bums SR 55 Du Bois, PA Reynoldsville, PA Dubois, PA Dawn M Burns Georgene M Bums Jon Michael Bums Leighann Burns Robert C Burns More relatives... - View Details 6. Robert C Burns Robert W Burns 39 Towson, MD Rosedale, MD York, PA New Freedom, PA Middle River, MD • Bree Mcilvaine Burns Robert W Bums Robert W Bums Gail Frances Keeling Curtis Monroe Tabor More relatives... View Details 7. Robert C Burns Robert C Burns SR 70 WAYNESBORO, PA York, PA Waynesboro, PA Nancy M Bums Robbin Stover Burns Robert C Burns Tammy Lynn Burns Anthony Lowell Stover More relatives... View Details 8. Robert C Burns Robert Charles Burns JR 49 Waynesboro, PA Zullinger, PA Potsdam, NY Nancy M Burns Robbin Stover Bums Robert C Burns Tammy Lynn Bums Jenna G Rodgers More relatives... View Details http://www.peoplefinders. com/search/searchpreview. aspx?searchtype=people-name&fn=R... 7/28/2014 Search Results for Robert Burns - PeopleFinders.com Page 2 of 3 9. Name Robert E Burns Robert E Bums III Robert E Ums JR Age 57 Has Lived In Philadelphia, PA Bensalem, PA Andalusia, PA Possible Relations E Bums Robert E Burns Burns Valerie Pisieczko Connie W Pisieczko Walter E Wakefield More relatives... Phone Number, Address & Other Details View Details 10. Robert E Bums Robert L Bums JR 67 Levittown, PA Detroit, MI Bensalem, PA McLean, TX Carson City, MI Adam C Bums Jerome R Burns Joseph L Burns Marshall Burns Ryan Patrick Bums More relatives... View Details 11. Robert F Burns Robt F Bums JR Rober T Burns JR 54 Trucksville, PA Wilkes Barre, PA Bear Creek Township, PA Michael T Bums Michael T Bums Robert Bums Robert F Burns Laura Sarah Dimarzo More relatives... View Details 12. Robert G Burns Robert A Burns Robert F Burns 48 Castle Creek, NY Susquehanna, PA Vestal, NY Wilkes Barre, PA Ann Petroski Bums Lori Ann Burns Robert Bums Susan H Bums Brian James Mcfadden More relatives... View Details 13. Robert J Burns Janet M Bums James Robert Burns Jan Robert Burns Jane T Burns 77 Danville, PA Lewisburg, PA Milton, PA Bryan D Bums Jennifer L Slease Michael G Slease Nancy S Slease Suzanne M Slease More relatives... View Details 14. Robert J Bums Jr Robert J Burns JR 53 Pottsville, PA Seltzer, PA View Details 15. Robert J Burns 59 Philadelphia, PA Jeanne M Burns Jeanne M Burns Judith Stairiker Bums Liam Stairiker Burns Robert J Burns View Details 16. Robert Jospeh Bums 57 Allentown, PA Mount Carmel, PA Hightstown, NJ Robert Burns Susan Irene Burns Beatrice I Derk Clyde M Derk Mary C Derk More relatives... View Details 17. Robert L Burns Richard C Burns Robert C Burns Robert L Bumsdr 67 Reedsville, PA Lewistown, PA Richard Charles Burns Robert C Burns Susan L Burns Michael A Jacobson Sarash C Jacobson More relatives... View Details 18. Robert M Burns Robert A Bums III 49 York, PA Seven Valleys, PA Daytona Beach, FL Tallahassee, FL Dania, FL Gregory William Bums Karen Baum Bums Melody D Lesh Ruth M Vaughn Samuel G Vaughn More relatives... View Details 19. Robert 0 Burns 76 Harrisburg, PA York, PA ' Lenore F Bums Robert 0 Bums Rose Marie Burns Marjorie L Jaeger Thomas M Jaeger More relatives... View Details 20. Robert W Burns 34 York, PA Elizabethtown, KY Radcliff, KY Leeta M Burns Letta M Burns Letta M Burns Robert C Burns Robert W Bums More relatives... View Details http://www.peoplefinders. com/search/searchpreview. aspx?searchtype=people-name&fn=R... 7/28/2014 Search Results for Robert Burns - PeopleFinders.com Personal Records for Robert Robert William Burns Robert William Burns Robert William Burns Robert William Burns Robert William Burns Page 3 of 3 sponsored by InstantCheckmate.com Phone— -- Social Profiles Arrest Records y Email Address GET ADDRESS RECORDS GET PHONE NUMBER GET SOCIAL PROFILES GET ARREST RECORDS 1 GET EMAIL ADDRESS VITAL RECORDS for Robert Burns Robert Burns Census Robert Burns Robert Burns Robert Burns Robert Burns Birth Records Marriage Records Divorce Records Death Records SPONSORED by MyRelatives.com Continue Continue Continue [Continue j Continue PeopleFinders is dedicated to helping you find people and leam more about them in a safe and responsible manner. PeopleFinders is not a Consumer Reporting Agency (CRA) as defined by the Fair Credit Reporting Act (FCRA). 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Powered by DataTsunami" se_unot11,1 no`v'+ecr by 5r+rartec RCCRCDITED Dun 4ES5 TRUSTe Cetttrle4 Prruaey http://www.peoplefinders. com/search/searchpreview. aspx?searchtype=people-name&fn=R... 7/28/2014 EXHIBIT "1" Robert Burns in PA WhitePages Page 1 of 3 Robert K Burns Jr Address Phone Age: 50-54 Lives in: Altoona PA Knows: Jennifer R Burns, Sherri L Burns, Mark R Pulcinello Lived in: No known previous cities View Full Profile View Address Robert K Burns Jr Address Phone Age: 45-49 Lives in: Bainbridge PA Knows: Audrey J Burns Lived in: No known previous cities View Full Profile View Address Robert K Burns Address Phone Age: Unknown Lives in: Philadelphia PA Knows: Calvin A Austin Ii Lived in: Philadelphia PA, Cleveland OH, Lakewood OH, Euclid OH View Full Profile View Address Robert K Burns Jr Address Phone Age: 5o-54 Lives in: Duncansville PA Knows: Kathleen Yoder, Sherri L Burns, Marsha J Bell Lived in: No known previous cities View Full Profile View Address Sponsored by PeopleSmart.com Robert William Burns 40 years old Drexel Hill, PA Email 1 Public Records 1 Phone View full details Sponsored by PeopleSmart.com Robert C Burns 54 years old Du Bois, PA Email 1 Public Records 1 Phone View full details Robert Burns Address Phone Age: 55-59 Lives in: New Wilmngtn PA Knows: Dorothy R Burns, Andrea Burns, Joshua Burns Lived in: New Wilmington PA, Mercer PA, New Wilmngtn PA View Full Profile View Address Robert J Burns Address Phone Age: 65+ http://www.whitepages.com/name/Robert-K.-Burns/Pennsylvania 7/28/2014 Robert Burns in PA I WhitePages Page 2 of 3 Lives in: Yardley PA Knows: No known associations Lived in: Doylestown PA, Bristol PA, Yardley PA, Levittown PA View Full Profile View Address & Phone Number Robert Burns Address Phone Age: Unknown Lives in: Pittsburgh PA Knows: No known associations Lived in: No known previous cities View Full Profile View Address Robert F Burns Address Phone Age: 65+ Lives in: Phila PA Knows: Geraldine A Burns Lived in: Philadelphia PA View Full Profile View Address & Phone Number Robert Burns Address Phone Age: 25-29 Lives in: Jefferson Township PA Knows: Renee A Calabro, Gaetano J Calabro IV Lived in: Scranton PA, Pensacola FL View Full Profile View Address Robert E Burns Address Phone Age: 65+ Lives in: Mechanicsburg PA Knows: Elizabeth A Burns Lived in: Dillsburg PA, State College PA, Rochester NY, Henrico VA, Houston TX, Waltham MA, Columbia MD View Full Profile View Address & Phone Number Prev 1. 1 2. 2 3. 3 4. 4 5. 5 6. 6 7. 7 8. 8 9. 9 10. 10 Next © 2014 WhitePages Inc. - Privacy Policy and Terms of Use http://www.whitepages.com/name/Robert-K.-Burns/Pennsylvania 7/28/2014 8/12/2014 c PSECU IN THE COURT OF COMMON PLEAS [Plaintiff] CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT K. BURNS [Defendant] t., TrtE t' i2 i 1i 0 $li I;,�i`1, o . v 73!!•i AUG 12 PM 3: 0 CIVIL ACTION — LAW CUMBERLAND COUNTY PENNSYLVANIA NO. 2014-615 [Civil Term] IN: Counter Action in Replevin (Reply) Reply to PSECU Motion for Service Pursuant to SPECIAL Order of Court PA.R.C.P.430a with Counter Motion to Stop PSECU (and their affiliated parties) from Posting to Property Defendant Counter Motion support in asking this court to impose a cease and desist action of any postings pursuant notices by Plaintiff. Defendant, in counter motion, support of stop moving Plaintiff's 08-05-14 said Motion avers the following: 1. No valid reason to post to property as PSECU & all of their contracted parties have had my contact information since the loan's inception on 09-06-06. This includes PSECU themselves, Barley Snyder, Richard & Associates and APAccount Services since 04-27-10. My contact information has not changed. I have the 09-06-06 same 510 Ridgeview Drive, York County address (which PSECU has concluded in this Motion), email address & phone number. 2. This PSECU/BarleySnyder08-05-14 latest Motion is in reference to a complaint filed 02-06-14. As you can see, I replied to their complaint on 02-19-14 having never been served. The purpose of this Motion should have been easily resolved, hence canceling out any need for this Motion and/by settling my dispute which would have also negated the need for their 02-06-14 filed complaint. Simply put, had PSECU & their associates lived up to their written documented commitment {exhibit—LB dated 12-12-13 [para 4, disputing the validity of the debt] and exhibit - RkB2 dated 01-16-14 [concerning the last two sentences which reference my provided $4,703 true loan settlement balance], accordingly} to disclose the promised shared PSECU loan balance perspective as I did. Regardless of the lack of PSECU/Barley input, the Plaintiff went directly to filing a complaint instead of first contacting me prior to their complaint filing. Therefore, their 02-06-14 Complaint on some level is not valid. It can't be, as they never had all the information (my input) to formulate the basis for its 02-06-14 complaint, the numbers part. This is a mirror situation to May 2010, excluding the complaint part. They retracted, realizing they were wrong, before filing their complaint. 3. *Within the law, "under the event that the individual has paid back more than 1/3 of the money, the lending company cannot repossess the vehicle without permission. Even if the borrower has paid back less than 1/3 of the sum, the lenders cannot enter the borrower's residence or other property to fi I e:///a/U sers/M IKE/AppD ata/Local/M crosoftNVi ndows/Temporary%201nternet%20Files/Content.lE5/xPIEC84LM/eb8914.Psecu countrMo.htm 1R 8/12/2014 c repossess the vehicle without a valid court permit". PSECU's 02-06-14 complaint is not valid, so as everything after that is not valid. As noted, I paid back 82% (inclusive of all monies paid) of the loan & paid back more dollars than PSECU lent me in 2006. 4. 02-06-14 complaint Validity I. As PSECU has not lived up to their commitments and expending their attorney resources to arrive back @ 510 Ridgeview Drive leading to this Motion posting, I'm not responsible for their claimed $909.52attorneyfeesnoted in exhibit-PS2. 5. 02-06-14 complaint Validity II. Outside being stonewalled by the Postmaster, to arrive back at 510 Ridgeview (covered in their Motion, No.'s #6 their exhibit E, #7 their exhibit F), address tracking websites (covered in their Motion, No.'s #8 thru #12 their exhibits G -J), & not able to locate me at the times the Sheriff's Dept(s) were solicited to serve me a complaint (covered in their Motion, No.'s #1 their exhibit A, #2 their exhibit B, #3 their exhibit C, #5 their exhibit D), there is no unearthly valid reason for the Plaintiff to search my property and publicly post its value. Furthermore, I'm not responsible for their time, efforts and fees. I wasn't even aware this was being conducted. 6. Validity III 02-06-14 complaint itself. Inside the PSECU numbers. On 06-15-14, I entertained a phone call from (PSECU's contracted) Richards & Associates that concerned repossession, unbeknownst to me. I had an approved payment arrangement in place at the time. I followed up with a phone call to PSECU. During my call, 1 discovered billed and then canceled repossessions at $175 ea even though they had been cancelled prior to any action taken. (My exhibit - PS2). In addition, during my PSECU conversation I learned there were multiple canceled/yet $175 billings to my account & additionally learned that there were others monies I paid toward my note but were held back & not applied to my loan. (Shown in my exhibit - RkB3, RkB3a & RkB3b covering APR 1 thru MAY 31, 2013) This shows payments paid through 2 -month span, but the loan balance remaining the same, $7,675. There was at least one loan pymt of $371.07 not applied & one canceled $175 repo fee applied. Using just that 2 - month activity, the total loan balance to full term would go down to $7,129.33; that excludes any response addressing my documented dispute request initiated 06-17-13. This was further PSECU confirmed by (exhibit - PS2) If/when a paymt arrangement is in place, a member full delinquency status (causing repossession stoppage) is avoided. It was during that PSECU conversation I asked to be provided with all fees from the inception of my loan & all repo charges be disclosed before I pay out any more monies. That never happened, though PSECU [exhibit D- (1) & D (2)] claims they mailed it out to me on 06-17-13. I'd like to see the proof on that matter. Furthermore, I just learned about that 06-17- 13 claim 2nd hand through two PSECU documents, one dated 02-28-14 (exhibit PS1, P52). The other document was dated 03-05-14 [exhibit D- (1) & D (2)]. Neither document was addressed to me nor was 1 copied on either, having a pro se status on this matter. Even still, I would have received this claim from Barley post June 17,2013. The first and only time Barley addressed this dispute was in their letter to me 12-12-13 (exhibit LB1 & 2) & Jn 17th 2013 was not mentioned. 7. Validity IV Inside the PSECU Numbers . I have clearly laid out the numbers on the amount I would owe allowing the loan to go to term versus the payoff amt if I were to close out the loan today, tomorrow, or yesterday and proceed to refinance the loan. That payoff amt is $4,700. Continuing with total remaining loan balance of$7,129.33from the above #6, there's more activity. Subtracting from it, my JL 2013 PSECU statement displays my dividend balance $376.52. My 2013 year -ending loan balance still shows $7,675.40. There was no dividend payment made to me. Apply this to the $7,129.33, and my loan balance now becomes $6,752.81. Lastly, referring back to exhibit P51, PSECU claims it applied a file:///C:/Users/MIKE/AppData/Local/Microso ndows/Temporag/.201nternet%20Files/Content.lES/xPIEC84L/Web8914.Psecu_countrMo.htm 2/7 8/12/2014 c payment of $371.07 on 12-01-13 (exhibit-PS1). In this document, PSECU claims the aftermath of this applied payment, yet my loan balance still rested at $7,675.40. Reviewing, this is the same unchanging balance since the beginning of my May/June 2013 initiated dispute. If one deducts this $371.07, my new loan balance is $6,381.74. Remember, this cumulative balance has been based on PSECU numbers and account statements, not my calculations. 8. ValiditvV Posting an Invalid Complaint. The defendant (my) PSECU balance dispute was initiated June 2013. This Defendant asked to have the concerns addressed. They have not been to date. In fact, a better term would be resistance. Including PSECU Corporate and their contracted entities, there are 4 groups in their camp. There has not been one email or one phone call in an attempt to settle this dispute by PSECU or any party in their camp. There has only been one written correspondence piece by their attorney Barley asking me to provide his office in writing with "any dispute on the validity of the debt or any portion thereof." I did respond directly to his office and no further reply by his firm. As well documented, their next step was to file a complaint without my input. Now my reply to with office is a matter of court record included in my required timely response to their PSECU complaint, having never been served. A question begs of this Defendant; why don't they know that? 9. ValidityVI Posting an Invalid Complaint. One would expect for a valid claim to be filed the numbers to be true and accurate and the correct processes, chronologically, follow a consistent path deeming it valid. This was not the case here. On June 15th 2013 I raised a dispute over my loan balance of $7,675.40 where at least one payment of $376.41 not applied and to date balance dividends not credited. (Shown in APR/MAY 2013 exhibits — RkB, RkB3a, & RkB3b) which would have made the loan balance lower. On June 17,2013, PSECU documents show & PSECU admits receiving 2 pymts (March 1st — May 30th timeframe) were received, but only one applied shown in the 3 RkB exhibits. Either way, one payment was applied and one not ($371.o7 or $352.52). The 2nd payment was not applied until 12-01- 13. (Exhibit—PS1) Also, PSECU reported the one pymt not immediately applied (until 12-01-13) was a result of pymt returned for insufficient funds; that was not the case. PSECU had the payment and returned the pymt willing after my bank showed the account closed. That was the result of my intention to close the account at a documented later date in June, but the funds were secure and released at the time of PSECU's draft. I replaced that pymt ASAP after learning of the screw up. In 6 years, of a 7 yr loan, that was my camps' one and only misstep. PSECU also had one to their end in the course of this loan when they incorrectly drafted funds inputting the wrong routing number. PSECU reports my ongoing delinquency status. When they report a member would not be deemed delinquent (and not be reported as such) as long as a pymt arrangement is place, I expect that misinformation not be presented to a misinformed 3rd party as evidenced throughout exhibit D (1) & (2). Additionally, there was a mishap with their contracted APServices account where 1 paid them what I was asked along with a 15% handling fee. They forgot to include their commission by shorting themselves $19. PSECU paid APS their commission and charged my account $19 causing my acct to be placed in another 30 -day bracket, never informing me. This has been PSECU's SOP in an effort to make an account look more delinquent than it actually is. Chronologically continuing from May 30th 2013, PSECU charged off my account on 11-23-30, unbeknownst to me. After the chg-off PSECU, on Dec. 01, 2013 PSECU claims they applied the 2nd of the two $300 pymts listed above. Yet, my balance remained at $7,675.40. On 02-12- 14, APServices claimed I owed $9,210.48 (exhibit-PS3). Then on 02-28-14, PSECU reported I owed $8,759.92 (exhibit-PS2). Which of these PSECU claimed balances is correct or was when they filed their 02-06-14 Complaint? Is it the $7,675.40, the $9,210.48 or the $8,759.92? If they cannot decide, their file:///C:/Users/MIKE/AppData/Local/MicrosoftMl ndows/Temporary%201nternet%20Files/Content.lE5D<PIEC84LM/eb8914.Ps ecu countrMo.htm 3/7 8/12/2014 c Complaint is invalid. This does not even address my dispute numbers. 10. Given this response, this Defendant feels the PSECU 02-06-14 Complaint can't be valid if they can't get their own 'ducks in a row' qualifying their own numbers before levying allegations in a Complaint form. Therefore, I ask this court not to grant the PSECU Motion to Post to Property. Thanks for the Court' eration. Robert k.,,ins ,//12/1 V���� Robert K. Burns Signature of Petitioner Shawn Long, Esquire (Barley Snyder) For the Plaintiff Robert K. Burns Defendant Exhibit — RkBI PSECU Plaintiff v. Robert K. Burns Defendant Date IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. #14-0615 (CIVIL TERM) IN: PSECU Complaint Complaint Reply to THE COURT... APD NOW, this 19th day of Feb, 2014 1. History. Barley on behalf of PSECU billed my account incorrectly in Jan 2010 on this same said loan listed in this most recent complaint. I asked for the verified documentation of their (PSECU) numbers versus mine numerous times, disputing my PSECU loan corrections and speedy corrected resolution if warranted. I received no feedback on my numbers requests until May 2010. The dispute lied in 3 areas. First, the current amount due ($xxx.52). Second, the credit not yet applied to my account ($xxx.55). Last, the loan payoff balance in the amount of $xxx.80. Finally, but not until, May 18th 2010 did I get my requested information. I was correct on all 3 areas to the penny. Point, if the cents as listed above are correct, then my numbers were correct. 2. This current complaint is no different than the above #1 History scenario... addresses this complaint both chapter and verse. I was never aware there was an error until a call from a 3rd party contacted my last May 2013. I tried numerous times to address this issue. Not until Dec. 2013 via a letter was I contacted by anyone in the PSECU camp, 7 months. The claim in the complaint is wrong 4. The B. Snyder letter dated 12/12/13 stated my reply needed within 30 days or it be assumed the amount owed was correct. At that time I would be provided with verification. I complied and yet I received nothing from PSECU or Barley, They went right to the complaint. 5. The only documentation provided in their complaint was the loan agreement file:///C:/Users/MIKE/AppData/Local/Microsof ndows/Temporary%201nternet%20Files/Content.IE5/xPIEC84Uweb8914.Psecu countrMo.htm 4/7 8/12/2014 c and a statement printout. I have my recent PSECU bank statements, from that 2013 May/June/July time period directly refuting that $8,094 claim. -- ------ 6. I borrowed $24.9K in 2006. Depending on whose numbers you're looking at, I have paid back PSECU in the mid $30.5K back. I have never missed an arrangement. ---- Exhibit — RkB2 FGS, LLC© Robert K. Burns, Sales Operations Manager 510 Ridgeview, Dillsburg, PA 17019 rkb8675309@Gmail.com January 16, 2014 Shawn Long, esq. Barley Snyder Attorneys at Law 126 E. King Street Lancaster, PA 17602-2893 Dear Mr. Long: I am just now in receipt of your letter dated 12/12/13 (post marked Dec.13th reg mail; never received any certified mail as your letter states) regarding my auto loan with PSECU originating 08- 25-06 in the amt. of $24,994.58. It is worth noting that both my Home address and Contact [phone number] have not changed since 2006 and PSECU has this information on file. I am well aware that PSECU presently retains the Title for my vehicle. Addressing the purpose for your correspondence, I disagree with the premise that I'm in default of the loan. Many factors are involved in categorizing a default status including fair business practices and deviation from the original agreement by either or both parties, not just the lendee. Additionally, it is also worth noting that even though the loan has not reached full term, my total loan repayment to date far exceeds the monies lent to me by PSECU. The rest is a matter of dispute, as you so asked of my response in your Dec.l2th 2013 letter, I put forth. Citing the particulars of your letter, I'll begin with the inaccuracy of the March 1, 2013 payment amount due of $352.52. That was an adjusted split (2 -part) payment that was paid with an additional 10% (x2) $35.26 totaling $387.78 rcv'd & requested by PSECU's contracted 31-d party according to records. Somehow, the 3rd party entity erred encoding my payments &/Or requested a wrong amt due by me leaving an $18.55 deficit. They were paid their commission regardless and that $18 shorted my monthly note, kicking me into some other 30 day past due status per PSECU. Never once, did anyone from either PSECU or its contracted entity notify me on any of this. Furthermore, I made payments on (3-20-13) $183.78, [4-22-13] $342.91 & again on [5-23- 13] $371.07. Yet, you state $352.52 owed for 03-01-13 when I made 3 additional pmts post March 1. I was unaware of my acct jeopardy per the above misguided record keeping, miscalculations, & posting inaccuracies until I returned a May '13 message from an unknown party that ended up being another PSECU contracted party in repossession. The gentleman contacted me. He must have gotten my number from PSECU. Therefore, reiterating once again, PSECU has always had my contact information, which hasn't changed since 2006. This is essentially where your involvement begins in this latest PSECU matter. file:///C:/Users/MIKE/AppData/Local/Microsoft/windows!temporary'/o201nternet%20Files/Content.lE5/XPIEC84WVeb8914.Psecu countrMo.htm 5/7 8/12/2014 c That being the case, I will further address the pertinent detailed particulars of your correspondence. Immediately following that May 2013 repossession manager phone call, I spoke with PSECU representation concerning that conversation as well as relaying everything else above in this letter with the representative. At that time, I also discussed my Apr 2013 & subsequently my May PSECU monthly statements confirming unapplied account funds listed on my statements & acknowledged by PSECU. Additionally, I then discovered there had been previous repossession fees charged to my account even though there had been no attempts to repossess. Adding insult to injury, this was during time frames where I had approved payment arrangements in place. I never broke a payment arrangement going back to '06. At most, I've readjusted some arrangements, but with prior notification & approval Let's speak to the Here and Now. Since my loan's inception, I have always been proactive handling issues and requests with PSECU. Dealing with communication, I've always met all requests & returned any call promptly. It's 2014 and I have yet to hear back from PSECU since last May/June. The first and only communication has been your correspondence dated December 2013, 6- 7 months later after begging their written followup documentation reply addressing all above concerns and issues in an effort to steer this account back on track, alleviating any confusion with my account status. I did not complicate the matter. My requests were straight up and involved virtually no workload. They were three -fold. First, all payments or monies paid PSECU that did not go toward the balance of my loan balance and why. My conversation with the PSECU representative confirmed two, one of which was on the current statement in front me during our conversation. Second, every repossession fee ($175), being inappropriate, charged to my account during the life of the loan. Third, and last, all fess and 3rd party commissions I've paid out during the course my loan and why. That was not part of my loan agreement. Adapting to change is one thing. However, when 3rd party misguided information, mistake cover-up and down right falsehoods affect my pocket and loan status it becomes my problem. I asked for this documentation 7 months ago and nothing in way of feedback. Though you're sworn to secrecy, I believe you might agree that my 3 requests are in-line. Was & am I supposed to continue to make monthly payments with a multi- layered unresolved issue not knowing how and if my payments are applied directly toward my note? That's throwing good money after bad. To clarify, permit me to use the following example. You have an Institution Loan Balance (ILB) of $900 carrying a monthly note of $200/mo. Your records indicate, with Your Loan Dispute (YLD), the actual balance to be $700 and you inform ILB of the dispute. Unresolved, YLD continues to pay your monthly note in good faith with the hopes ILB will address your concerns. At the end of the three months, is your (YLD) balance $100 or $300 (ILB)? If its $300, you just threw good money after bad. Remember, this is not my or your first rodeo with this type PSECU issue. It occurred in Jan 2010 and didn't get resolved until May of that year when you got involved. That former 5 -month debacle involved a conflict in monies owed on the account while asking for documentation to that said issue. Again, it took five months and your involvement to get the documented paperwork & issue resolved. Sound familiar? As it turned out, my numbers were correct to the penny. It's not about right or wrong. But, I was correct then and I'm correct now until someone shows otherwise. I even went so far as to suggest PSECU sell the remainder of my loan. But, I may have to initiate or sign off on that process. The above is a brief background encapsulating the step-by-step, all the while demonstrating how a simple clarification requesting written disputed documentation from PSECU on my remaining loan balance. All this could have been avoided. As such, now we're staring at unfair business practices. As mentioned, the above is a synopsis. Now, I'll address your correspondence specifics. Before that, I would be remiss if I didn't put on record the timeframe and timing of PSECU's inaction. First, file:///C:Nsers/M1KE/AppData/Local/MicrosoftM!ndows(femporanj3/0201nternet%20Files/Content.IES/XPIEC84L/Web8914.Psecu_countrMohtm 617 8/12/2014 c I am in compliance with your 30 -day disputed request as it applies to 30 days "upon receipt of this notice." That said, I do believe it is a little suspect on the PSECU timing in conjunction with your 30 -day written notification. You requested 30 days. Still unresolved, PSECU had 7 months. Why? Is it about the remaining loan balance or about the year-end shareholders' report? Either way, the loan balance is minimal and even considering PSECU's own numbers, the remaining balance is far lower than the $8,095 you state in your letter. Also stated in your letter is "debt or portion thereof disputed, we will obtain verification of the debt." I am curious as to why I am being asked to put forth specifics on what the true loan balance is from my standpoint. Seven months ago I asked PSECU for the documentation to cross reference against my numbers. It's impossible for me to accurately dispute PSECU's numbers when they refuse to provide me their numbers. However, I will comply with your request & provide you my numbers on the loan payoff balance at this reply's end. Upon receiving my reply concerning the bottom line balance as I calculate it, I anticipate PSECU's speedy response & the legality of any future action PSECU intends to take in connection with my vehicle and my account. This, incidentally, is the final line in your correspondence. Keep in mind the legal stipulations when I have repaid more than 60% of the loan. It's obvious that I have met that obligation when I've already paid PSECU far more monies than the loan check they wrote me in 2006. I'm not going to cite chapter and verse of the "right to cure." You and I are well informed of all that. However, this current dispute does involve fair business practices compounded with a PSECU out of state 3rd party making it Federal, not just state. As the debtor, I don't care whether it is the creditor or a third party contacting me. But under the law, whether it is the creditor itself or a third party makes a big difference. Federal law prohibits any conduct that is deemed false or misleading. That is considered an unfair act or practice and a violation. PSECU's 3rd party San Antonio operation did just that on a few occasions. Violating the "Federal Debt Collection Act" makes them liable for actual damages as well as penalties. All of this stems from a discrepancy on default which boiled over because PSECU refused to provide me the information on a balance dispute at the tail end of a loan complicated by lack of communication & unfair business practices, 3rd party and otherwise. When you look at the remaining term loan, the payoff balance if settled today would be $4,703.84. Thanks for your cooperation. Regards, Robert K. Burns Robert k. Burns file:/f/C:/Users/MIKE/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.IE5/XPIEC84WVeb8914.Psecu countrM o.htm 7/7 1.26 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL Mr. Robert K. Burns 402 Pawnee Drive Mechanicsburg, PA 18050-2546 Re: December 12, 2013 161 Shawnsquire Direct Dial Number: 717.399.1512 E-mail: slong@barley.com Pennsylvania State Employees Credit Union/2006 Chrysler 300 Dear Mr. Robert K. Bums: 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 2006 Chrysler 300 (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 March 1, 2013 payment in the amount of $352.52 and each monthly payment thereafter in the amount of $371.07. 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 $8,094.60 as of November 20, 2013 (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. You have the right to dispute the validity of the Debt in its entirety or any portion of it. Unless you dispute the validity of the Debt or any portion thereof, within thirty (30) days after 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 Lancaster • York • Reading • Malvern • Hanover Page 2 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 prepared 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. 4134195 cc: Mr. Greg Diffenderfer Very truly yours, 1pennsylvania DEPARTMENT OF BANKING AND SECURITIES March 5, 2014 Mr. Robert Burns 510 Ridgeview Drive Dillsburg, PA 17019 Dear Mr. Burns: ish3;•rpo.) Thank you for contacting the Pennsylvania Department of Banking and Securities ("Department") regarding issues you are experiencing with Pennsylvania State Employees Credit Union ("PSECU"). Your complaint is regarding an auto loan you have with PSECU. You disagree with the premise that you are in default of the loan. Additionally, you are disputing a payment amount that PSECU claims you owe and repossession fees. In an effort to assist you, I forwarded a copy of your correspondence to Ms. Tammy Heimbaugh, Chief Administration Officer at PSECU. On February 28, 2014, I received a response from Ms. Heimbaugh. A copy of the response is enclosed for your convenience. According to Ms. Heimbaugh, you received a seven year term auto loan from PSECU in the amount of $24,994.58 at a 6.49% Annual Percentage Rate which went into effect on September 1, 2006. You agreed to the loan disclosures displaying in Attachment A. Additional review of your account showed that during the life of the loan, you were 31 — 60 days delinquent 19 times, 61 — 90 days delinquent 15 times, 91 — 120 days delinquent five times, and 121 — 180 days delinquent one time. As of February 28, 2014, your account is 364 days past due. Your last payment was made on May 23, 2013 in the amount of $371.07. Your outstanding loan balance , was charged off on November 21, 2013 in the amount of $7,675.40. The fees you are disputing originated from numerous late payments and a loan balance that was not kept current. PSECU's process is to charge a fee of 5% of the minimum amount due for each payment that was more than 15 days late. Additionally, fees are assessed when a third party company is used to assist with collecting the funds when members become increasingly delinquent. Furthermore, repossession fees are transferred to the member if PSECU is assessed fees by a third party company. In regards to your statement that a payment made on March 1, 2013 was inaccurate ._ and you incurred a third party collection fee, the total amount due.. n_March 1, 2013 was not' •�„ v -\ \ \C) f\O‘k %• Airrb(4) pennsylvania e DEPARTMENT OF BANKING AND SECURITIES wP,-e ,zi;�P,a rn ou. Furthermore, the letter mentioned by you dated December 12, 2013 was from Barley Snyder Attorney at Law representing PSECU to collect on the loan. As of February 28, 2014, a bill for $909.52 from the attorney was charged to you and has yet to be paid. In order to cancel the repossession and pending legal action, you need to pay the vehicle loan balance of $7,675.40, the $909.52 in attorney fees, and a $175.00 repossession cancellation fee. If you pay the full amount. of $8,7 -59,92T -you may keep your vehicle. I real' tha{you may be less than satisfied with this respu ,, however, the Department cannot t; e exception to the information provided by GFC. Jennifer Loudin Consumer Services Specialist Enclosure(s) cc: Ms. Tammy Heimbaugh, PSECU -Department of Banking and Securities — Office of Consumer Services 17 North Second Street, Suite 1300 !Harrisburg, PA 17101 1 717.787.1854 IF 717.787.8773 1 www.dobs.state.pa.us PSE* Ms. Jennifer Loudin Consumer Services Specialist Department of Banking and Securities Office of Consumer Services 17 North Second Street, Suite 1300 iarrisburg, PA 17101 Dear Ms. Loudin, 02/x0/2014 06:38 0009 002/0 February 28, 2014 am writing in response to your letter dated January 31, 2014, concerning correspondence from Dur member, Mr. Robert Burns. in Mr. Bums' letter to the Department of Banking, he disputed the default status of his auto loan. Mr. Bums explained that all repossession fees were inappropriately charged and that all fees and 3rd party commissions were not part of his loan agreement. Additionally, he stated that the remaining balance is far lower than the $8,095 stated in a fetter from PSECU dated December 12, 2013. He also stated that the March 1, 2013 payment amount due of $352.52 was inaccurate which resulted in an $18.55 deficit. Furthermore, he mentioned a lack of corre pondence by PSECU since Moor June 2013 in providing records on the loan. ' Through the review of Mr. Bums' account, I determined that he received a?`yea, Lerm auto loan from PSECU in the amount of $24,994.58 at 6.49% Annual Percentage Rate which went into effect on September 1, 2006. Mr. Burns agreed to the loan disclosures displayed in Attachment A. 1 have highlighted the sections that address 'Late Charge' and 'Collection Costs'. Through additional review of Mr. Bums' account, I determined that during the life of the loan, Mr. ;Burns was 31 — 60 days delinquent 19 times, 61 — 90 days delinquent 15 times, 91 — 120 days delinquent 5 times, and 121 — 180 days delinquent 1 time. As of February 28, 2014, Mr. Burns is 364 days past due. His last payment was made on May 23, 2013 in the amount of $371.07. His outstanding loan balance.was charged off on NovPmher 21 7(113 in the amount of $7,675.40. To further address Mr. Burns' comment concerning tees;°they onginated from numerous late payments and a loan balance that was not kept current. PSECU's process is to charge a fee of 5% of the minimum due for each payment that was more than 15 days late. Additionally, fees are assessed when a third party company is used to assist with collecting the funds when members become increasingly delinquent. Furthermore, repossession fees are transferred to the member if PSECU is assessed fees by a third party company. In regards to Mr. Bums' statement that a payment made on March 1,2013 was inaccurate and he incurred a third party collection fee, 1 would like to clarify further. The total amount due on March 1, 2013 was not $352.52 but the entire $1,113.21 that was past due, the equivalent of three $371.07 payments. Also, PSECU did not receive a payment from Mr. Bums on March 1, 2013. We received two payments on March 11, 2013. One of the payments was later returned due to Non -Sufficient Funds. The other payment dIrl clear and was applied to the December 1, 2013 amount due (see Attachment B). P. O. BOX 67013 HARRISBURG, PA 1 71 06-7013 800.439.7338 >: psecu.com THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL d DIyUNION ADMINISTRATION. EQUALPORTUNITY LENDER. y , From: Department of Banking (cont.) Mr. Robert Burns February 28, 2014 92/28/2014 06:38 On May 22, 2013, at 82 days delinquent and $1,112.78 past due, fhe'vehicle was assigned for repossession. Mr. Burns's May 23, 2013 payment was placed on hold and not applied to his March 1, 2013 amount due because of the repossession status. It is PSECU's policy not to apply payments under the full delinquency amount once an auto loan has been placed on repossession. PSECU's last phone conversation with Mr. Bums was conducted on June 15, 2013 in which he contested the delinquent status of his auto loan and r est9d reco is on the loan. On Jute 17,,. 2013, the loan records were mailed to Mr. Burnt .�' /J /4:'��;� Furthermore, the letter mentioned by Mr. Burns dated December 12, 2013 was from Barley Snyder Attorney at Law representing PSECU to collect on the loan (see Attachment C). As of February 28, 2014, a bill for $909.52 from our attorney was charged to the member and has yet to be paid. In order to cancel the repossession and pending legal action, Mr. Burns needs to pay the vehicle loan balance of $7,675.40, the $909.52 in attorney fees, and a $175.00 repossession cancellation fee. If Mr. Burns pays the full amount of $8,759.92, he may keep his vehicle. This non-public information is being disclosed to you in accordance with Regulation P "§ 1016.15(a)(1), (2)(iii) and (7)(iii). It is our intention that this information be strictly used for those limited purposes; i.e., for resolving consumer disputes or inquiries and regulatory investigation. Mr. Burns may contact our Collections department at 717-777-3119 to make the payment. Sincerely, -uji) Tammy Heihbaugh Chief Administration Officer PSCC Pennsylvania State Employees Credit Union P.O. Box 67013 Harrisburg, PA 1 71 06-701 3 800.237.7328 psecu.com Direct inquiries regarding preauthorized electronic transfer or account errors to the above address. 29277 1 AV 0.360 00.583 00.054 T96 P1 319 ROBERT K BURNS 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 IIIII�IIIIII�I��IIIIIIIIIIIIIIIIIIII�'II1'III44IIIddIiiiIiIIIIIII 000817 07 004144 001 D S2 SAP: 1,2,3,4 „eXpite F-4003 Member Number: Statem Page Numb f Regular 1 of 2 Account Balances at a Glance Total Shares: Total Certificates: $0.00 Total Loans: $7,675.40 ON61NE BANKING 611- Payer ryce; -e-Statements account alerts and more. »psecu.com/online SHARES Posting Effective Date Date Transaction Description REGULAR SHARE ID 01 04/01 Beginning Balance 04/30 Ending Balance Dividend YTD: Year to Date . MONEYHANDLER ID 04 04/01 Beginning Balance 04/30 Ending Balance Dividend YTD: Year to Date LOANS Trans Post Date Date Transaction Description nsaction New A ount Balance 4111111111 0.00 0.00 Payments, Credits Finance Fees or Transaction New or Debits Charge Charges Amount Balance ID 10 2006 CHRYSLER 300 *** ANNUAL PERCENTAGE RATE 6.490% *** 04/01 Beginning Balance 04/15 Payments By Check 04/22 Payments By Check 04/30 Ending Balance As of 05/01/2013 : Past Due Amount: Current Amount Due: Total Amount Due: Interest Charged YTD Periodic Rate (Daily) .017780% 8,018.31 8,018.31 7,675.40 7,675.40 Pennsylvania State Employees Credit Union P.O. Box 67013 Harrisburg, PA 17106-7013 800.237.7328 psecu.com Direct inquiries regarding preauthorized electronic transfer or aocount errors.to tt ove address. 29885 1 AV 0.360 00.582 00.054 T92 P1 330 ROBERT K BURNS 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 InlitiillllliiIIIIIIIuniitIlllll,i,iitii„n„ii,il,lli,uiliii 000834 07 004571 001 D S2 SAP: 1,2,3,4 N1.mber Number: Statement Period: Page Number: 884707",* /01/13 to 05/31/13 Regular 1 of 2 Account Balances at a Glance Total Shares: Total Certificates: Totaj._oans: Share Your Credit Union Withspur Immediate Family »psecu.com/ in S,, ''N YEAR TO DATE INFORMATION Description Total Dividends Year to Date SHARES Posting Effective Date Date Transaction Description %Amount $0 0; REGULAR SHARE ID 01 05/01 Beginning Balance 05/23 Payment: By Check 05/31 Payment: Dividend 0.150% Annual Percentage Yield Earned 0.100% from 05/01/13 through 05/31/13 Based on Average Daily Balance of 113.07 05/31 Ending Balance Dividend YTD: Year to Date MONEYHANDLER ID 04 05/01 Beginning Balance 05/31 Ending Balance Dividend YTD: Year to Date LOANS Trans Post Date Date Transaction Description $376.43 $0.00 $7,675.40 IAN I Transaction New Amount Balance allialbiksudimp 376.41 ,/Payments, Credits Finance Fees or Transaction New or Debits Charge Charges Amount /Balance ID 10 2006 CHRYSLER 300 `'*'° ANNUAL PERCENTAGE RATE 9.490% *** Periodic Rate (Daily) .017780% 05/01 Beginning Balance - 675.40 PSEt, Pennsylvania State Employees Credit Union P.O. Box 67013 Harrisburg, PA 1 71 06-701 3 800.237.7328 ecu.coit r� ROBERT K BURNS Member Number: 8847****** Statement Period: 05/01/13 to 05/31/13 Page Number: Regular 2 of 2 1 Trans Post Payments, Credits Finance Fees or Transaction Date Date Transaction Description New or Debits Charge Charges Amount Balance 05/31 Ending Balance As of 06/01/2013 : Past Due Amount: 112.7::; Current Amount Due: Total Amount Due: ?:�. Interest Charged YTD **The balance used to compute interest is the unpaid balance each day after payments and credits to that balancr have been subtracted and any additions to the balance have been made. -0‘01 ********* FEES ******,.** TOTAL FEES FOR THIS PERIOD ********* INTEREST CHARGED ********* Interest Charge on Loan 0010 - 2006 CHRYSLER 300 TOTAL INTEREST FOR THIS PERIOD 2013 Totals Year To Date Fees Charged YTD $0.00 $0.00 $0.00 7,675.40 PSEL „Is Pennsylvania State Employees, Credit Union P.O. Box 67013 Harrisburg,PA 17106-7013 800.237.7328 psecu.com Direct inquiries regarding preauthorized electronic transfer or account errors to the above address. 45366 1 AV 0.360 00.582 00.056 T145 P1 357 ROBERT K BURNS 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 11iI11111iiuII111111111"I'IIIIi1i"iIIiI1111i111111111"II11"11 000869 07 020064 001 D S2 SAP: 1,2,3,4 GET OUR A ANNUAL PERCENTAGE PATE YEAR TO DATE INFORMATION Description 1715A psecu.com/visa Member Number: Statement Period: Page Number: 8847*** 07/ Regular 1 of 2 Account Balances at a Glance Total Shares: Total Certificates: Total Loans: $376.53 $0.00 $7,675.40 Amount Total Dividends Year to Date SHARES Posting Effective Date Date Transaction Description $0.11 N 0 ANNUAL FEE INACTIVITY FEE BALANCE TRANSFER FEE (from us) Transaction Amount New Balance REGULAR SHARE ID 01 07/01 Beginning Balance 07/31 Payment: Dividend 0.150% Annual Percentage Yield Earned 0.160% from 07/01/13 through 07/31/13 Based on Average Daily Balance of 376.47 07/31 Ending Balance Dividend YTD: Year to Date MONEYHANDLER ID 04 07/01 Beginning Balance 07/31 Ending Balance Dividend YTD: Year to Date LOANS Trans Post Date Date Transaction Description 0.05 0.11 0.00 0.01 0.01 Payments, Credits Finance Fees or Transaction New or Debits Charge Charges Amount Balance ID 10 2006 CHRYSLER 300 *** ANNUAL PERCENTAGE RATE 6.490% *** 07/01 Beginning Balance 07/31 Ending Balance As of 08/01/2013 : Past Due Amount: $1,854.92 Periodic Rate (Daily) .017780% 7,675.40 7,675.40 Rke,1 ACCOUNT SERVICES 1802 N.E. LOOP 410, SUITE 400 * SAN ANTONIO, TEXAS 78217 (210) 882-1782 * (866) 293-0273 February 12, 2014 444:4 ir‘ m gal) RE: PSECU Balance Due: $9,210.48 Account Number: AUTO LOAN L10 File Number: 01-13-326-0416 Dear ROBERT K BURNS, You have ignored previous requests for payment on this seriously delinquent debt. We are attempting to resolve this account amicably, but you should be aware that our efforts to collect this debt will not end with this letter. We have an obligation to our client to pursue their accounts just as vigorously as we would pursue our own. They are entitled to payment in full for services rendered in good faith. We urge you to take this opportunity to resolve your account. Unless we receive your payment for the amount owed, we will continue collection activity. Please call our office toll free at (866) 293-0273 to discuss your account. This is an attempt to collect a debt. Any information obtained will be used for that purpose. This communication is from a debt collector. Sincerely, Account Services AGA INTERNATIONAL Thc. Association of Crcdit and Collection Professionals Member **** For prompt credit, all payments and correspondence must be mailed directly to my office. **** *** Se Habla Espanol*** Please Note Your File Number On All Mailings *** C For your convenience ou ma •a online at www. accountservices-usa.conil a manta "` Please detach and return with payment"— DEPT 612 6736044314029 PO BOX 4115 CONCORD, CA 94524 111111111111111111 I I 111111111111111111111111111111111111111111111111111101111 01133260416 ADDRESS SERVICE REQUESTED #BWNFTZF #ACT6736044314029# IIIIIiiil11111IIIIIIIiiIIIIiiIII,I„III„IIIIIIIIII„iIIIIIIIrI ROBERT K BURNS 510 RIDGEVIEW DR DILLSBURG PA 1 701 9-1 379 New Address: AGTRH-02 i 3-445654415-00716-716 New Phone: RE: PSECU File#: 01-13-326-0416 p D p, /LA Card # Exp. Date Name On Card Signature (An Additional $6.95 Service Fee May Be Added) Amount Enclosed: Account Services PO Box 659818 San Antonio, TX 78265-9118 IIII'IIII'IIIIII.IIIIIIIii'II'11111'II'I " II'111111'I'IIII " 'III' RH • Yr` f )63 BARLEY SNYDER 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. ROBERT K. BURNS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014-615 ORDER AND NOW, this irOlay of A u4 , 2014, upon consideration of the Motion of Pennsylvania State Employees Credit Union for Special Service Order, and the Affidavit attached thereto pursuant to Pa. R.C.P. Nos. 430(a), it is hereby ORDERED and DECREED as follows: rr6- 1. That service of the Complaint, Sale areftrfterifftitarrdibill on the Defendant shall be made by: a. posting on the most visible part of 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019; b. regular and certified mail, return receipt requested, to the Defendant at 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. 4392763-1 5 r r{ on the I: • V �.;-_-- -_�� �. .• -.' � -ii • 1— I •..-•. 3. That the posting and the mailing by regular and certified mail, return receipt FF(r requested of any service of the Complaint, Vb t or Sh Defendant shall be deemed served upon the Defendant upon the later of the date of posting or the date of mailing. C) it CJ -,- Cf f"' CD cD2 copy elf9Ar 4392763-1 6 , J. AJ CZ) Cr) CD C BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 J j rC l; , r i1�P O THONO A f1 Zul1i SEP - P , CUt�g � �' I: 20PENNSAND COUNTY Attorneys for Plaintiff Nib Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, v. ROBERT K. BURNS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014-615 SECOND MOTION OF PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT PA.R.C.P. 430(a) Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Barley Snyder, moves this Court for a Order directing the method of service of certified copies and posting of any Notices pursuant to Pa.R.C.P. Nos. 430(a) and in support of said Motion, avers the following: 1. On January 31, 2014, the Plaintiff filed its Complaint against the Defendant. A true and correct copy of the Complaint is attached hereto, made a part hereof and marked Exhibit «A„ 2. On or about March 5, 2014, the Sheriff of Cumberland County attempted service at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. The Sheriff returned the Return of Service to Plaintiff indicating "Not served; twelve attempts at service were made but deputies were unable to make contact with anyone at the residence to make service." A true and correct copy of the Return of Service is attached hereto, made a part hereof and marked Exhibit "B". 4421843.1 3. On or about March 18, 2014, Plaintiff performed a Lexis search on www.Lexis.com. The address listed on the Lexis search is 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. A true and correct copy of the Lexis Search is attached hereto, made a part hereof and marked Exhibit "C". 4. On or about March 24, 2014, the Plaintiff reinstated the Complaint. 5. On or about April 2, 2014, the Sheriff of Cumberland County deputized the Sheriff of York County and attempted service at 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. The Sheriff returned the Return of Service to Plaintiff indicating "The Defendant was found to have moved." A true and correct copy of the Return of Service is attached hereto, made a part hereof and marked Exhibit "D". 6. On or about April 22, 2014, the Plaintiffs counsel prepared and mailed a Request for Change of Address to the Mechanicsburg Postmaster for the address 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. The Request for Change of Address was not returned. A true and correct copy of the Request for Change of Address is attached hereto, made a part hereof and marked Exhibit "E". 7. On or about April 22, 2014, the Plaintiffs counsel prepared and mailed a Request for Change of Address to the Dillsburg Postmaster for the address 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. The response to the Request for Change of Address indicates "no change of address on file." A true and correct copy of the response to the Request for Change of Address is attached hereto, made a part hereof and marked Exhibit "F". 8. On or about July 18, 2014, Plaintiff performed West Law search on www.WestLaw.com. The address listed on the West Law search is 510 Ridgeview Drive, 2 4421843.1 Dillsburg, Pennsylvania 17019. A true and correct copy of the West Law search is attached hereto, made a part hereof and marked Exhibit "G". 9. On or about July 28, 2014, Plaintiff performed a ZABA Search on www.zabasearch.com. The Defendant is listed to 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019 as well as two other possible addresses on the ZABA Search. A true and correct copy of the ZABA Search is attached hereto, made a part hereof and marked Exhibit "H". 10. On or about July 28, 2014, Plaintiff performed a People Finders search on www.peoplefinders.com. There is no address listed to the Defendant on the People Finder search. A true and correct copy of the People Finders Search is attached hereto, made a part hereof and marked Exhibit "I". 11. On or about July 28, 2014, Plaintiff performed a White Pages search on www.whitepages.com. There are multiple addresses listed to the Defendant on the White Pages search. A true and correct copy of the People Finders Search is attached hereto, made a part hereof and marked Exhibit "J". 12. On or about August 25, 2014, Plaintiff searched the online records of the Cumberland County Court of Common Pleas with respect to Defendant and discovered the record of Defendant's pending divorce proceedings at Docket No. 07-5908 Civil (the "Divorce Action"), which record contains, among other things, several Orders of Court showing Defendant's address at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. A true and correct copy of one such Order, dated August 16, 2011, is attached hereto, made a part hereof and marked Exhibit "K". 13. Plaintiff and the undersigned have not located an alternate address for the Defendant and have confirmed 402 Pawnee Drive, Mechanicsburg, PA 18050-2546 is the correct 3 4421843.1 addresses for the Defendant by several of the above resources, including this Court's record in the Divorce Action. WHEREFORE, Plaintiff respectfully request this Court to grant its Motion, and enter an Order permitting service on the Defendant of the Complaint by posting the most visible part of 402 Pawnee Drive, Mechanicsburg, PA 18050-2546, by mailing the Defendant by certified mail, return receipt requested, and regular first-class mail at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546 and to the Defendant's attorney in the Divorce Action, Andrew H. Shaw, Esquire, 200 S Spring Garden St, Carlisle, PA 17013, and permitting service on the Defendant with any additional notices or documents requiring personal service on the Defendant by mailing to the Defendant by certified mail, return receipt requested, and regular first-class mail at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546 and to the Defendant's Attorney in the Divorce Action, Andrew H. Shaw, Esquire, 200 S Spring Garden St, Carlisle, PA 17013. Dated: G1/41 14 4421843.1 BARLEY S ER By: 4 Shawn M. Long, Esqu'. e Attorneys for Plaintif Pennsylvania State E, ployees Credit Union Court I.D. No. 83774 126 East King Street Lancaster, PA 17602-2893 717-299-5201 BARLEY SNYDER 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. ROBERT K. BURNS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014-615 SECOND AFFIDAVIT IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF LANCASTER SHAWN M. LONG, ESQUIRE, being duly sworn according to law, deposes and says that he is the attorney of record for the Plaintiff, Pennsylvania State Employees Credit Union, and that the following is an itemization of the efforts taken by the Plaintiff to locate Defendant, Robert K. Burns to effect service under the provisions of the Pennsylvania Rules of Civil Procedure, without success. 4. On or about March 5, 2014, the Sheriff of Cumberland County attempted service at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. The Sheriff returned the Return of Service to Plaintiff indicating "Not served; twelve attempts at service were made but deputies were unable to make contact with anyone at the residence to make service." 4421843.1 5. On or about March 18, 2014, Plaintiff performed a Lexis search on www.Lexis.com. The address listed on the Lexis search is 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. 6. - On or about April 2, 2014, the Sheriff of Cumberland County deputized the Sheriff of York County and attempted service at 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. The Sheriff returned the Return of Service to Plaintiff indicating "The Defendant was found to have moved." 7. On or about April 22, 2014, the Plaintiff's counsel prepared and mailed a Request for Change of Address to the Mechanicsburg Postmaster for the address 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. The Request for Change of Address was not returned. 8. On or about April 22, 2014, the Plaintiff's counsel prepared and mailed a Request for Change of Address to the Dillsburg Postmaster for the address 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. The response to the Request for Change of Address indicates "no change of address on file." 9. On or about July 18, 2014, Plaintiff performed West Law search on www.WestLaw.com. The address listed on the West Law search is 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019. 10. On or about July 28, 2014, Plaintiff performed a ZABA Search on www.zabasearch.com. The Defendant is listed to 510 Ridgeview Drive, Dillsburg, Pennsylvania 17019 as well as two other possible addresses on the ZABA Search. 11. On or about July 28, 2014, Plaintiff performed a People Finders search on www.peoplefinders.com. There is no address listed to the Defendant on the People Finder search. 4421843.1 12. On or about July 28, 2014, Plaintiff performed a White Pages search on www.whitepages.com. There are multiple addresses listed to the Defendant on the White Pages search. 13. On or about August 25, 2014, Plaintiff searched the online records of the Cumberland County Court of Common Pleas with respect to Defendant and discovered the record of Defendant's pending divorce proceedings at Docket No. 2007-5908 Civil, which record contains, among other things, several Orders of Court showing Defendant's address at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. 14. The Plaintiff has exhausted all reasonable efforts to serve the Defendant, Robert K. Burns. S to and subs 'bed before me thi °` day �f , ��. , 2014. bun - Notary Public My Commission Expires: 4421843.1 wn M. Long, Esquire Notarial al Da4Fa GYKgal"rt4Yv ip ubHc CNT-42 ces 1 e woo erCounty toy'02nirliiii6(00130 - an.,,14, 2018 MEM6Eit._ppost,RNUAS? RTION'OF NOTARIES EXHIBIT "A" BARLEY SNYDER 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, V. ROBERT K. BURNS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 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 forthin 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. 4181246 In TC.. i,T :; i)r 4'i;c: 'uf. I r ar!O th': Gal of sad This day of : ! .,rand Prom o iotar; YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR "TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO -ELIGIBLE -PERSONS AT A._REDUCED_FEE OR NO_FEE.__ Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 Effective September 1, 2003 4181246 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CRED1'1 UNION, V. ROBERT K. BURNS, Plaintij Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. AVISO PARA DEFENDER Conforme a RCP No. 1018,1 del PA LE HAN DEMANDADO EN COR IE. Si usted desea defender contra las demandas dispuestas en las paginas siguientes, usted debe tomar la accion en el plazo de veinte (20) dias despue's 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. 4.151174A US 1'ED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE Un ABOGADO, VAYA A 0 LLAME POR 1ELEFONO La OFICINA DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De US 1'ED La INFORMACION SOBRE EMPLEAR A un ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA PUEDE PODER PRO_VEER DE LISTED LA INFORMACIONSOBRE LAS AGENCIAS QUE LOS SERVICIOS JURIDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES EN Un HONORARIO REDUCIDO 0 NINGUN HONORARIO. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 Efectivo 1 de Septiembre, 2003 Queja 4181246 BARLEY SNYDER 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, V. ROBERT K. BURNS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 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, Robert K. Burns, is an adult individual with a last known address of 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. 3. On or about September 1, 2006, Defendant entered into a Loanliner Advance Proceeds Voucher and Security Agreement (the "Agrrment ") with Plaintiff for the purchase of a 2006 Chrysler 300, VIN #2C3KA43R36H366549 (the "Vehicle"). A true and correct copy of the Agreement is attached hereto as Exhibit "A" and incorporated herein by reference. 4181246 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 Agreement by failing to make monthly payments when due beginning March 1, 2013 and on the first (1st) day of each month thereafter. 6. Pursuant to .the. Agreement, 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 December 12, 2013 (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 Agreement, Plaintiff is entitled to immediate possession of the Vehicle. 10. The present fair market wholesale value of the Vehicle is approximately $6,650.00. 11. Upon information and belief, the Defendant has possession and control of the Vehicle at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, demands judgment in replevin against Defendant, Robert K. Burns, for possession of the Vehicle, plus 4181246 costs, special damages thereon in the amount to be deteiliiined, 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 $8,094.60. 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. 4181246 WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment in its favor and against Defendant, Robert K. Burns, in the amount of $8,094.60, and costs of suit. BARLEY S By: Sawn ong, Esquir (Court I.D. 83774 126 East King Street Lancaster, PA 17602- 893 717.299.5201 Attorneys for Plaintiff EXHIBIT "A" 4181246 ADVANCE PROCEEDS VOUCHER AND SECURITY AGREEMENT PSEC 3 Pennsylvania State Employees Credit Union P.O. Box 67013 Harrisburg, PA 17106-7013 717.234.8484 800.237.7328 '�� MEMEERNAME. ':, •:a-' ;''`.-.DAT::'.4.-_ `9/Y1/2006� ,- RE -is ifT a--I.'W, �-".^ _'� E�- ..4T'.ali [1 B t'.,.. 'm107/L10 n::...,o_ -.:,y": N�OTEFIt1�I6ER::'�.� �.,`.S� ROBERT K BURNS 510 RIDGEVIEW DRIVE DILLSBURG, PA 17 019 PAYMENT 371.07 DUE DATE 10/1/2006 50 PURPOSE: Dealer Purchase TRANSACTION TYPE ITEM PROPERTY'. • ' - .' .. -, MODEL' ; OPEN-END OTHER HOME 1. NEW LOAN '2. LOAN ADVANCE B. (DESCRIBE) 4. EQUITY.ADVANCE DISBURSEMENT BREAKDOWN AND REPAYMENT SCHEDULE - YOU HAVE PREVIOUSLY ELECTED TO HAVETHIS ADVANCE CREDIT DISABILITY _ SINGLE CREDIT LIF JOINT CREDIT LIFE,,,,_ INSURED WITH THE FOLLOWING COVERAGE YES ❑ NO. YES ❑ NO YES El NO DAILY PERIODIC RATE (CHANGE IN TERMS ONLY) :0177808 ANNUAL PER- CENTAGE RATE 6.490 0 /o INTEREST RATE IS I AMOUNT REQUESTED �'� AMOUNT ADVANCED :� PREVIOUS BALANCE I NEW BALANCE + OTHER CHARGES • j • m FIXED VARIABLE L. 24 994. 58Tz.2?.9;•44: ��a+ . 0.00 24, 994.58 t- 1 ❑ t .. . xx >�.-;. µTi PAYMENT 371.07 DUE DATE 10/1/2006 PAYMENT FREQUENCY Monthly PROJECTED LOAN TERM " SECURITY OFFERED IFTHIS IS A HOME EQUITY ADVANCE,THE ONLYSECURITY FOR THIS ADVANCE IS THE REAL PROPERTY (IN MOST CASES YOUR HOME) WHICH YOU GAVE AS SECURITY WHEN YOUR ACCOUNT WAS ESTABLISHED. IF THIS IS NOTA HOME EQUITY ADVANCE, IN ADDITION TO THE PLEDGE OF SHARES. IN YOUR LOANUNER' CREDIT AGREEMENT, THE FOLLOWING PROPERTY SECURES THIS ADVANCE. ITEM PROPERTY'. • ' - .' .. -, MODEL' ; <YEAR7•:,.'7....:l : 'X•);D: f` LIMBER 74- •;, ":::3: -.'7, ,,... ;.i.':» jYPE1i . , 1.YAF:tJE`« ":_w 1. CHRYSLER 2, 3. 300 2006 2C3KA43R36H366549 SDN 25,380.00 4. OTHER YOU FLEDGE SHARES AND/OR DEPOSITS CF $ IN ACCOUNT NUMBER OLD ACCOUNT/LOAN NUMBER (A) PAYOFF (PRINC.+INT.) OLD ACCOUNT/LOAN NUMBER (B) PAYOFF (PRINC.+INT) OLD ACCOUNT/LOAN NUMBER (C) PAYOFF (PRINC. + INT) OLD ACCOUNT/LOAN. NUMBER (D) PAYOFF (PRINC.+ INT.) OLD ACCOUNT/LOAN NUMBER (E) PAYOFF (PRINC.+ (NT.) OLD ACCOUNT/LOAN NUMBER (F) PAYOFF (PRINC. + INT.) By accepting the proceeds or by using the funds advanced and deposited into your share/share draft account, you agree (1) that the property referenced above will secure the advance and any other advances you have now or receive in the future under the LOANLINER° Credit and Security Agreement (the Plan) and any other amounts you owe us for any reason now or in the future In accordance with the terms of the Plan and (2) to make paymentsas disclosed above In accordance with the terms of the Plan. @ CU.NA MUTUAL GROUP, 198% 82, 84, 86, 89,98.Anna, 01,04, 06, ALL RIGHTS RESERVED PENNSYLVANIA STATE EMPLOYEES CREDIT UNION FORM 93175 JVXXO-1O0-1 037-2092-1 (8/00 (0%839 70 PSEC Pennsylvania State Employees Credit 'Union P.O. Box 67013 0 Harrisburg, PA 17106-7013 0 (717) 234-8484 Harrisburg, (800) 237-7328 Nationwide Loan Disclosures pT r 17' -All cuRiytY REE, This LOANLINER° Credit and Security Agreement, which includes the Truth in Lending Disclosures, will be referred to as the Plan. The Plan documents include this agreement and an Addendum. You, your and borrower mean any person who signs the Plan. Credit union, we, our and us mean PSECU or anyone to whom the Credit Union transfers its rights under the Plan. HOW THIS PLAN WORKS — This is an open-end, multi -featured credit plan. We anticipate that, from time to -time, you will borrow money (called "advances") under the Plan. We are not required to make advances to you under the Plan and can refuse a request for an advance at any time. The Addendum describes the different types of credit (called "subaccounts") available under the Plan, the current interest rate for each subaccount expressed as a daily periodic rate and corresponding annual percentage rate and other charges. It may also have other terms and a schedule for determining the payment amounts. CREDIT LIMiT — We may, but do not have to, establish a credit limit on certain subaccounts. If a credit limit is set for a subaccount, you promise not to exceed the established credit limit. If you exceed the credit limit, you promise to repay immediately the amount which exceeds the credit limit. REPAYMENT — You promise to repay all amounts you owe under the Plan plus interest. Payments are due on the -last day of the month unless we set a different day at the time of an advance. If the Addendum has no payment schedule for a subaccount, your payment will be determined at the time of each advance. Payments must include any amount past due and any -amount by which you have exceeded any credit limit you have been given for a subaccount. You may repay all or part of what you owe at any time without any prepayment penalty. Even if you prepay, you will still be required to make the regularly scheduled payments unless we agree in writing to a change in the payment schedule. Ifyou have a joint sharedraft account, you will be responsible for paying all overdraft advances obtained by a joint holder of the sharedraft•account. Unless otherwise required by law, payments will be applied to amounts owed under the Plan, in themanner the Credit Union chooses. PLAN ACCESS —You can obtain credit advances In any manner authorized by us. if we allow you to use your ATM/Debit card to access the Plan, you may be liable for the unauthorized use, of your ATM/Debit card. You will not be liable for unauthorized -use that occurs after you notify us, orally or In writing, of the loss, .theft, or possible unauthorized use. If you believe your ATM/Debit card has been lost or stolen, immediately inform the Credit Union by calling or writing us at the telephone number or address that appears elsewhere in the Plan. If the card Is used to obtain unauthorized advances directly from the Plan, your liability will not exceed $50. If the unauthorized withdrawal is from a sharedraft account, your liability is governed by the Regulation E disclosures you received at the time you received your ATM/Debit card, even if the withdrawal results In an advance being made from your overdraft subaccount, FINANCE CHARGE — The dollar amount you pay for money borrowed is called a "finance charge" and begins on the date of each advance. A finance charge will be computed separately for each separate balance under the Plan. To compute the finance charge, the unpaid balance for each day since your last payment (or since an advance if you have not yet made a payment) Is multiplied by the applicable daily periodic rate:The sum of these amounts Is the finance charge owed. The balance used to compute the finance charge is the unpaid balance each day after payments and credits to that balance have been subtracted and any additions to the balance have been made, In addition to interest, we may charge other finance charges which are disclosed on the Addendum. If the interest rate is a variable Interest rate, the Addendum explains how the variable interest rate works. SECURITY —You pledge as security for the Plan all shares and dividends and, if any, - all deposits and Interestin all joint and Individual accounts you have with us.now and in the future. If a specific dollar amount is pledged for an advance, we will freeze shares in that account to the extent of the outstanding balance for the advance. Otherwise, your pledged shares may be withdrawn unless you are In default. The following paragraph applies in all states except In Ohio, Rhode Island .and Massachusetts: We have a statutory lien on the shares and dividends and, II any, the deposits and interest in -all individual and joint accounts you have -with us and may exercise our rights under the lien to the extent permitted by state law. (We are state chartered If our name does hot include the term "Federal Credit Union.") For all borrowers: The statutory lien and/or your pledge will allow us to apply the funds in youraccount(s) to what you owe when you are in default. The -statutory lien and your pledge do not apply to any Individual Retirement Account or any other account that would lose special tax treatment under state or federal law if given as. security. Additional security for the Plan may be required at the time of an advance. If a subaccount identifies a type of property (such as "New Cars") you must give that type of property as security when you get an advance under that subaccount. A subaccount name such as "Other Secured" means you must provide security acceptable to us when you obtain an advance under that subaccount. Property you give as security will secure all amounts owed under the Plan and all other loans you have with us now or in the future, except any loan secured by your principal dwelling. Property securing other loans you have with us may also secure the Plan. CREDIT INSURANCE — Credit life and/or credit disability insurance is optional under the Plan. If you qualify for and purchase the insurance from us, you authorize us to add the Insurance premiums monthly to your loan balance and charge you interest on the entire balance. If you elect credit Insurance, your payments may increase or the period of time necessary to repay your advance may be extended. The credit insurance rates may change during the Plan, If the rates change, we will provide any notices required by applicable law. PERIODIC STATEMENT—On a regular basis you will receive a statement showing all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each joint borrower, notice to any one of you will be notice to all. JOINT ACCOUNTS — If this Is a joint account, each of you Is individually and jointly responsible for paying all amounts owed, That means we can enforce our rights under the Plan against any one of you individually, or against all of you together. If you give us inconsistent instructions, we can refuse to follow your instructions. Unless our written policyrequires at of you to sign for an advance, each of you authorizes the other(s) to obtain advances Individually and agrees to repay advances made to the other(s). Any joint accountholder may terminate the Plan by giving us prior written notice. If any of you terminate the Plan, the Plan is terminated for all of you. You remain liable individually and jointly for all advances incurred before termination. FEES AND CHARGES — If you give us a security interest in certain types of property, we may charge you a filing fee to perfect our interest in the property. If we do, the amount of the fee will be disclosed to you at the time you obtain an advance. We may also charge you other fees In connection with the Plan. Our current fees are disclosed on the Addendum and will be added to your loan balance unless you pay them in cash. UPDATING CREDIT INFORMATION — You promise that you will promptly give us written notice if you move, change your name or employment, or if any other information you provided to us changes, Upon our request, you also agree to provide us updated financial information. DEFAULT — The following paragraph applies to borrowers in Idaho, Kansas, Maine and South Carolina: You will be in default if you do not make a payment of the amount required when it is due. You will also be in default If we believe the prospect of payment, performance, or realization on any property given as security is significantly Impaired. The following paragraph applies only to borrowers in Wisconsin: You will be In default if you tail to make a payment when due two times during any 12 month period. You will be In default If breaking any promise made under the Plan materially impairs your ability to repay what you owe or materially impairs the condition, value, or protection of or our right in any property you gave as security. The following paragraph applies only to borrowers in Iowa: You will be in default if you are more than 10 days late in making a payment. You will also be in default If you do not comply with the terms of the Plan and your failure to comply materially impairs any property you gave as security or -your ability to repay what you owe under the Plan. The following paragraph applies to borrowers in all other states:You will be in default if you do not make a payment of the amount required when it is due. You will be in default If you break any promise you made under the Plan or If anyone is in default under any security agreement made in connection with an advance under the Plan. You will be in default if you die, file for bankruptcy, become insolvent, if you make any false or misleading statements In any credit application or update of credit Information, or if something happens we believe may substantially reduce your .ability to repay what you owe. You will be in default if any property you have given us as security is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value oftheproperty or our security interest in It. You will also be in default under the Plan if you are in default under any other loan agreement with us. ACTIONS AFTER DEFAULT — The following paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, South Carolina and West Virginia: When you are in default and after expiration of any right you have under applicable state law to cure your -default, we can demand immediate payment of the entire unpaid balance under the Plan without giving you advance notice. The following paragraph applies to borrowers In ali other states except Wisconsin and Louisiana: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. The following paragraphs apply to borrowers in all states except Wisconsin and Louisiana: If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the applicable interest rates in effect or, If applicable, LOANLUNEFr Credit and Security Credit Agreement (continued) at the default rate disclosed on the Addendum. If a demand for immediate payment has beelh made, your shares and/or deposits can be applied towards what you owe. as provided in the section above called "Security." We can also exercise any other rights given by law when you are in default. You agree the Credit Union has the right to take possession of any property given as security under the Plan, without judicial process, if this can be done without breach of the peace. If we ask, you promise to deliver the property at a time and place we choose. If the property is a motor vehicle or boat, you agree that we may obtain a key or other 'device necessary to unlock and operate it, when you are in default. We will not be responsible for any other property, not covered by this Agreement, that you leave inside the property or that is attached to the property. We will try to return that property to you or make it available for you to claim. After we have possession of the property, we can sell it and apply the money to any amounts you owe us. We will give you notice of any public disposition or the date after which a private disposition will be held. Our expenses for taking possession of and selling the property will be deducted from the money received from the sale. Those costs may include the cost of storing the property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded under the Bankruptcy Code. You must pay any amount that remains unpaid after the sale money has been applied to any unpaid balance under the Plan. You agree to pay interest on that amount at the same rate as the advance, or, if applicable, at the default rate disclosed on the Addendum, until that amount has been paid. The following paragraph applies only to Wisconsin borrowers: When you are in default and after expiration of any right you have under applicable state law to cure your default, we may require immediate payment of your outstanding loan balance under the Plan and seek possession of property given as security. You may voluntarily give the property to us if you choose, or we may seek to' take possession of the property by judicial process. If we repossess the property, you agree to pay reasonable expenses Incurred in disposing of the property. If the property is a motor vehicle, mobile home, trailer, snowmobile, boat or aircraft, you will also berequired to pay any costs permitted by Section 422.413 of the Wisconsin Statutes. You must pay any amount that remains unpaid after the sale money has been applied to what you owe under the Plan. You agree to pay interest on any unpaid amount at the same rate as the advance, or, if applicable, at the default rate disclosed on the Addendum, until that amount is paid. If the property is located outside Wisconsin at the time of default, we may take possession of the property without judicial process, if permitted by the state where the property Is located. The following paragraph applies only to Louisiana borrowers: When you are in default, we can require immediate payment (acceleration) of the entire unpaid balance under the Plan. You waive any right you have to demand for payment, notice of intent to accelerate and notice of acceleration. If immediate payment is demanded, you will continue to pay interest until what you owe has been repaid at the applicable Interest rates in effect unless a default rate is disclosed on the Addendum. If a demand for immediate payment has been made, the shares and deposits given as security for the Plan can be applied towards what you owe. We can also exercise any other rights given by law when you are in default and our rights under any security agreements you have with us. CANCELLING OR CHANGING THE PLAN — The following paragraph applies only to borrowers. in Illinois: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change to the interest rate or bther charges will apply to future advances. The following paragraph applies only to borrowers in Wisconsin: We can change the terms of the Plan from time to time In accordance with Section 422.415 of the Wisconsin Statutes. You will be notified of any change in terms. An increase in the daily periodic rate under a variable rate interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at, any time by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the credit union cancel the Plan, except to the extent that your liability is limited by Section 422.4155 of the Wisconsin Statutes. The following paragraph applies only.to borrowers in Iowa: We can change the terms of the Plan from time to time after giving you any advance notice required by law. A change that increases the rate of finance charge or other charge, that increases the amount of your payments, or that otherwise adversely affects existing balances will apply to existing balances only If you agree to the change or you use the Plan after receiving notice that your use of the Plan means you agree the change applies to existing balances. The following paragraph applies to borrowers in all other states: We have the right to change the terms of the Plan from time to time after giving you any advance notice required by law. Any change in the interest rate will apply to future advances, and at our discretion and subject to any requirements of applicable law, will also apply to unpaid balances. The following paragraph applies to all but Wisconsin borrowers: An increase in the daily periodic rate under a variable Interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the Plan at any time., You may cancel the Plan at any time .by giving us prior written notice. Your obligation to pay the unpaid balances under the terms of the Plan continues whether you or the Credit Union cancel the Plan. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN — We ban delay enforcing any of our rights under this Plan any number of times without losing the ability to exercise our rights later. We can enforce this Plan against your heirs or legal representatives. If we change the terms of the Plan, you agree that this Plan will continue to protect us. CONTINUED EFFECTIVENESS — If any part of this Plan is determined by a court to be unenforceable, the rest will remain in effect. NOTICE TO UTAH BORROWERS — This written agreement is a final expression of the agreement between you and the. Credit Union. This written agreement may not be contradicted by evidence of any oral agreement. The following is required by Vermont law — NOTICE TO CO-SIGNER — YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RiGHT TO COLLECT FROM YOU. The following paragraphs apply if you give security in connection with an advance under the PIan.They apply. to borrowers in all states except Louisiana. Louisiana borrowers will execute a separate security agreement. Borrowers in other states may also be asked to execute a separate security agreement. THE SECURITY FOR THE PLAN — You give us what is known as a security interest in all property described in any receipt, voucher or other document you receive for an advance ("the Advance"). The security interest you give includes all accessions. Accessions are things which are attached to or installed In the property now or in the future. The security interest also includes any replacements for the property which you buy within 10 days of the Advance or any extensions, renewals or refinancing of the Advance. It also includes any money you receive from selling the property or from insurance you have on the property. If the value of the property declines, you promise to give us more property as security If asked to do so, WHATTHE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS — The security interest secures the Advance described in,the receipt, voucher or any other document you receive at the time of the Advance and any extensions, renewals or refinancings of the Advance. It also secures any other advances you have now or receive in the future under the Plan and any other amounts or loans, including any credit card loan, you owe us for any reason now or in the future, except any loan secured by your principal residence, If the property is household goods as defined by the Federal Trade Commission Credit Practices Rule, the property Will secure only the Advance and not other amounts you owe. OWNERSHIP OF THE PROPERTY — You promise that you own all property you give as security or if the Advance is to buy the property, you promise you will use the Advance for that purpose. You promise that no one else has any Interest in or claim against the property that you have not already told us about. You promise not to sell or lease the property or to use it as security for a loan with another creditor until the Advance is repaid. You promise you will allow no other security interest or lien to attach to the property either by your actions or by operation of law. PROPERTY INSURANCE, TAXES AND FEES — You must maintain property insurance on all property that you give as security under the Plan. You may purchase the property insurance from anyone you choose who is acceptable to the Credit Union. The amount and coverage of the property insurance must 'be acceptable to us. You may provide the property Insurance through a policy you already have, or through a policy you get and pay for. You promise to make the insurance policy payable to us and to deliver the policy or proof of coverage to us if asked to do so. If you cancel your insurance and get a refund, we have a right to the refund. If the property is lost or damaged, we can use the insurance settlement to repair the property or apply it towards what you owe. You authorize us to endorse any draft or check which may be payable to you In order for us to collect any refund or benefits due under your insurance policy. You also promise to pay all taxes and fees (like registration fees) due on the property. If you do not pay the taxes or fees on the property when due or keep it insured, we may pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the advance and you will pay interest on those amounts at the same rate you agreed to pay on the advance. We may receive payments in connection with the insurance from a company which,provldes the insurance. We may monitor our loans for the purpose of determining whether you and other borrowers have complied with the insurance requirements of our loan agreements or may engage others to do so. The Insurance charge added to an advance may include (1) the insurance company's payments to us and (2) the cost of determining compliance with the insurance requirements. If we add amounts for taxes, fees or Insurance to the unpaid balance of an advance, we may increase your payments to pay the amount added within the term of the Insurance or approximate term of the advance. INSURANCE NOTICE — if you do not purchase the required property insurance, the insurance we may purchase and charge you for will cover only our interest in the property. The premium for this insurance may be higher because the insurance company may have given us the right to purchase insurance after uninsured collateral is lost or damaged, The insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. PROTECTING THE SECURITY INTEREST — If your state issues a title for the property, you promise to have our security interest shown on the title. We may have to file what is called a financing statement to protect our security interest from the claims of others. If asked to do so, you promise to sign a financing statement. You also promise to do whatever else we think is necessary to protect our security Interest in the property. You promise to pay all costs, including but not limited to any attorney fees, we incur in protecting our security interest and rights in the property, to the extent permitted by applicable law. LOANLINER9 Credit and Security Credit Agreement (continued) USE OF PROPERTY — Until the Advance has been paid off, you promise you will: (1) Use the property carefully and keep it in good repair. (2) Obtain our written permission before making major changes to the property or changing the address where -the property is kept. (3) Inform us in writing before changing your address. (4) Allow us to inspect the property. (5) Promptly notify us If the property is damaged, stolen or abused, (6) Not use the property for any unlawful purpose. (7) Not to retitle property in another state without telling us. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE — THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF iT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. NOTICE FOR ARIZONA OWNERS OF PROPERTY — It is unlawful for you to fail to return a motor vehicle that is subject to a security interest, within thirty days atter you have received notice of defaulL The notice will be mailed to the address you gave us, It is your responsibility to notify us if your address changes. The maximum penalty for unlawful failure to return a motor vehicle is one year In prison and/or a fine of $150,000. For those members who purchase a vehicleunder the DRIVe Program, please review the following FTC Notice: NOTICE ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED WiTH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. This notice contains Important Information about your rights and our responsibilities under the Fair Credit Billing Act. You are advised to read your monthly statement and review it for any error discrepancies or unauthorized transactions. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR STATEMENT. If you think your statement Is wrong, or if you need more information about a transaction on your statement, write us on a separate sheet at the address fisted on your statement. You are required to notify us in writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorized transactions on your account. Failure to notify us may result In your acceptance of any responsibility for payment or reimbursement to us for any such error or discrepancy on your account. Write to us as soon as possible. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: ' Your name and account number. ' The dollar amount of the suspected error. • Describe the error and explain, If you can, -why you 'believe there is an error, If you need more information, describe the Item you are not sure about. It you have authorized us to pay a credit card account automatically from your share account or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us three business days before the automatic payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE - We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the statement was correct. a; :1 �" � ARE N! ,f11 A d rYc �.e'hZ. . In this Agreement, the words you and your means each and all of those who apply for the card or who signs this Agreement. Card means the Visa Credit Card and any duplicates and renewals we issue. Account means your Visa -Credit Card Line of Credit account with us. We, us, and ours means this Credit Union. 1. RESPONSIBILITY — If we issue you a card, you agree to repay at debts and the Finance Charge arising from the use of the card and the card account. For example, you are responsible for charges made by yourself, your spouse and minor children. You are also responsible for charges made by anyone else to whom you give the card, and this responsibility continues until the card is recovered. You cannot disclaim responsibility by notifying us, but we will close the account for new transactions if you so request and return all cards. Your obligation to pay the account balance continues even though an agreement, divorce decree or other court judgment to which we are not a party may direct you or one of the other persons responsible to pay the account. The cards remain our property and you must recover and surrender to us all cards upon our request and upon termination of this Agreement. 2. LOST CARD NOTIFICATION — If you believe the card has been lost or stolen, you will immediately call the Credit Union at (717) 234-8484 or (800) 237-7328. Atter hours call (800) 556-5578. 3. LIABILITY FOR UNAUTHORIZED USE —You agree to notify us immediately,orally or in writing of the loss, theft or unauthorized use of your Credit Card, You may be liable for the unauthorized use of your Credit Card. You will not be table for unauthorized use that occurs after you notify us of the loss, theft, or possible unauthorized use.You will have no liability for unauthorized purchases made with your Credit Card, unless you are grossly negligent in the handling of your Card. In any case, your liability will not exceed $50. 4. CREDIT LINE — If we approve your application, we will establish a self - replenishing Line of Credit for you and notify you of Its amount when we issue the card. You agree not to let the account balance exceed this approved Credit Line. Each payment you -make on the account will restore your Credit Line by the amount of the payment which is applied to the principal. You may request an increase in your Credit After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue -to send statements to you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit limit. You do not have to pay any questioned amount while we are Investigating, but you are still obligated to pay the parts of your statement that are not in question. If we find that we made a mistake on your statement, you will not have to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date that it Is due. If you fall to pay the amount -that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within len days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your statement. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is: If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your statement was correct. SPECIAL RULE FOR CREDIT CARD PURCHASES — If you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay theremaining amount due on the property or services. There are two limitations on this right: (a) You must have made the purchase in your home state or, If not within your home state, within 100 miles of your current mailing address; and (b) The purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or If we mailed you the advertisement for the property or services. �i.in7x� Ct, tib L JV 11afG.;i? SGaU1E •;,. .��.. ,,. .,�,,.. , A.tt_. Line only by written application to us, which must be approved by our credit committee or loan officer. By giving you written notice we may reduce your Credit Line from time to time, or with good cause, revoke your card and terminate this Agreement. Good cause includes your failure to comply with this Agreement or any other agreement with us, or our adverse reevaluation of.your creditworthiness. You may also terminate this Agreement at any time, but termination by either of us does not affect your obligation to pay the account balance. 5. CREDIT INFORMATION — You authorize us to investigate your credit standing when opening, renewing or reviewing your account, and you authorize us to disclose information regarding your account to credit bureaus and other creditors who Inquire of us about your credit standing. 6. MONTHLY PAYMENT — We will mat you a statement every month showing your Previous Balances of purchases and cash advances, the current transactions on your account, the remaining credit available under your Credit Line, the New Balances of purchases and cash advances, the Total New Balance, the Finance Charge due to -date, and any other billed fees, and the Minimum Payment required. Every month you must pay at least the Minimum Payment within 25 days of your statement closing date. By separate agreement you may authorize us to charge the minimum payment automatically to your share or checking account with us. You may, of course, pay more frequently, pay more than the Minimum Payment, or pay the. Total New Balance in full, and you will reduce the finance charge by doing so. If your monthly payment exceeds the total credit. line balance owed, we will automatically post the credit to your SI shares. The minimum payment will -be (a) 2°/ of your Total New Balance, rounded up to the next even dollar, or (b) $20.00, whichever is greater. In addition, at any time your Total New,Balance exceeds your Credit Line, you must Immediately pay the excess upon our demand. We will apply payments in the following manner: first to previous late lees, then to previous cash advances finance charges, then to previous purchasefinance charges, then to current late fees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. [x IFOTTIKOXIIITENS ..Visa' Credit Card Agreement and Truth In Lending Disclosure (continued) 7. FINANCE CHARGES — You can avoid the Finance Charge on purchases'by paying the full amount of the New Balance of Purchases each month within 25 days of your statement closing date. Otherwise, the New Balance of Purchases, and the subsequent purchases from the date they are posted to your account, will be subject to Finance Charge. Cash advances are always subject to Finance Charge from the date they are posted to your account. Purchases: We calculate your finance charge by multiplying the average adjusted daily balance (see explanation below), including new purchases, for the billing cycle by the monthly periodic purchase rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Cash Advances: We calculate your finance charge on cash advances by multiplying the average adjusted daily balance (see explanation below) for cash advances during the billing cycle by the monthly periodic advance rate and corresponding ANNUAL PERCENTAGE RATE as disclosed on the Addendum. Balance Computation Method Average Daily Balance for Purchases - The Average 'Daily Balance for Purchase Transactions is calculated by adding the Daily Balances.(Purchase Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for purchases each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, 'In the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. Atter applying payments and credits, we subtract the amount of any unpaid Finance Charges or Late Charges. Then we also subtract the amount of any Cash Advance transactions that posted to your account on that day or in any previous day inthe billing cycle. This gives us the Daily Balance for purchases. Average Daily. Balance for Cash Advances - Cash Advance Transactions which are posted to your account are not included in the Average. Daily Balance calculation for purchases, and are therefore not subject to the monthly periodic rate for purchases. The Average Daily Balance is calculated separately for Cash Advances and is subject to the Cash Advance Monthly Periodic Rate. The Average Daily Balance for Cash Transactions is calculated by adding the Daily Balances (Cash Transaction) for each day in the billing cycle, and then dividing by the number of days in the billing cycle. To calculate the Daily Balance for cash each day, we take the following steps: We take the outstanding balance (all amounts you owe) at the start of the day. Then, in the sequence in which amounts are posted to your account, we add the amounts of all debits and subtract the amounts of all credits or payments which post to your account that day. After applying payments and credits, we subtract the amount of any -unpaid Finance Charges or Late Charges. Then we also subtract the amount.of any Purchase Transactions that posted to your account on that day or in any previous day in the billing. cycle. This gives us the Daily Balance for Cash Advance Transactions. Note: Cash Advances are always subject to finance charges and from the day they are posted to your account. Payments are applied In the following manner: first to previous late fees, then to previous cash advances finance charges,' then to previous purchase finance charges, then to current late fees, then to previous cash advance balances, then to previous purchase balances in the order that they were posted to your account, then to current cash advance balances, and then to current purchase balances. Credits are applied first to the particular type of debt which is being credited, if any, and then to the balance of your -account. Note also that If the total of the payments and credits which are posted to your account by the Payment Due Date shown on a statement is equal to or exceeds the New Balance shown on that statement, we will not apply the Monthly Periodic Rate to your Account on your next statement.' 8. DEFAULT—You will be In default if you fall to make any Minimum Payment within 25 days after your monthly statement closing date. You authorize us to transfer funds sufficient to make the minimum payment due If your Visa loan is in default. You will also be In default if your ability to repay us is materially reduced by a change in your employment, an increase- in your obligations, bankruptcy or insolvency proceedings involving you, your death or your failure to abide by this Agreement, or If the value of - our security interest materially declines. We have the right to demand immediate payment of your full account balance if you default, subject to our giving you any notice required by law. To the extent permitted by law, you will also be required to pay 'our collection expenses, Including court costs and reasonable attorney fees. 9. USING THE CARD — To make a purchase or cash advance, there are two alternative procedures to be followed. One is for you to present the card to a participating Visa plan merchant, or another financial institution, and sign the sales or cash advance draft which will be imprinted with your card. The other is to complete the transaction by using your Personal Identification Number (PIN) in conjunction with the card In an Automated Teller Machine or other type of electronic terminal that provides access to the Visa system. You agree that you will not use your card for any transaction that is Illegal under applicable federal, state, or local law. The monthly statement will identify the merchant, electronic terminal or financial Institution at which transactions were made, but sale, cash advance, credit or other slips cannot be returned with the statement. You will retain a copy of such slips furnishedatthe time of the transaction in order to verify the monthly statement. The Credit Union may make a reasonable charge for photocopies of slips you may request. 10. OVERDRAFT OPTION — If you elect to overdraft to your PSECU Visa Credit Card, that election is subject to the existing credit limit and the agreement It represents and the current loan policy at the time of the overdraft You also understand that an overdraft will be considered the same as a cash advance on your PSECU Visa Credit Card and that the current Annual Percentage Rate for cash advances will apply. 11. RETURNS AND ADJUSTMENTS — Merchants and others who honor the card may give credit for returns and adjustments, and they will do so by sending us a credit slip which we will post to your Visa line of credit, If your credit and payments exceed what you owe us, we will automatically post the excess credit balance to . your Si Shares within 75 days. If the balance is one dollar or more, upon your written request, we will refund the credit balance to you. 12. FOREIGN TRANSACTIONS — The exchange rate between the transaction currency and the billing currency used for processing international transactions is a rate selected by Visa from the range of rates available in wholesale currency markets for the applicable central processing date, which rate may vary from the rate Visa itself receives, or a government -mandated rate in effect for the applicable central processing date. In each instance, an adjustment may be assessed based on the ISA fee imposed by Visa. This fee, which totals 1% of the transaction amount, will be assessed on all transactions where the merchant country differs from the country of the card issuer. 13. SPECIAL RULES FOR VISA PURCHASES — If you disagree or find an error with a Visa transaction, and have tried in good faith to correct the problem with the merchant or the charges are the result of unauthorized or fraudulent use, or your purchase cost more than $50 and was made from a plan merchant in your state within 100 miles of your home, contact PSECU. 14. DISPUTED TRANSACTIONS — You are required to notify PSECU In writing within 60 days following the date on which we sent your statement wherein the error or problem first appeared regarding any discrepancy or unauthorlied transaction on your account. Telephoning PSECU does not preserve your dispute rights.,You may be required to provide us with documentation to support your dispute claims, In addition, you may be required to complete a standard dispute form outlining the details of your dispute. In cases of fraudulent card use, PSECU will also require a notarized affidavit. In some cases we may ask you to notify the local authorities. If we do not receive the proper requested documentation in the lime specified you may be held responsible for the transaction(s) in question. PSECU must adhere to strict dispute timeframes set forth by Visa. 15. SECURITY INTEREST — To secure your account, you grant us a purchase money security interest under the Uniform Commercial Code in any goods you purchase through the account. If you default, we will have the right to recover any of these goods which we have not been paid for through our application of your payments in the manner described in the Monthly Payment section. With respect to this account only, we will not assert any statutory right we may have if you are in default to prevent withdrawal of your unpledged credit union shares (Deposits) below the unpaid balance of your account. However, If you give or have given us a specific pledge of your credit union shares (Deposits) by signing the Pledge of Shares or otherwise, or any other security interests for all your debts, your account will be secured by your pledged shares (Deposits) and by the property described in those other security agreements, except for your home, 16. EFFECT OF AGREEMENT — This Agreement is the contract which applies to all transactions on your account even though the sales, cash advance, credit or other slips you sign or receive may contain different terms. We may amend the Agreement from time to time by sending you the advance written notice required by Iaw..Youruse of the card thereafter will indicate your agreement to the amendments. To the extent the law permits, and we indicate In our notice, amendments will apply to your existing account balance as well as to future transactions. 17. LATE PAYMENT CHARGE — If your Minimum Payment is not received by the first day of the month following your due date, you will be subject to a $20 charge. 16. RUSH FEES — You may incur additional charges for rush processing and rush delivery of cards and/or PIN mailer. 19. OVER LIMIT FEE —A $20 fee will be applied for each monthly statement closing date on which the outstanding balance exceeds the assigned credit limit by more than $100. 20. DRAFT COPIES — You may incur an additional charge for transaction summary/sale draft documentation. 21. COPY RECEIVED — You acknowledge receipt of a copy of this Agreement, 22. ILLEGAL TRANSACTIONS PROHIBITED — You agree that you will not use your card for any transaction that is illegal under applicable federal, state, or local law, 23. 'NO USE — Inactive Visa accounts that have no purchase or cash activity may be closed without notice to you after 18 months of no activity. 24. NEURAL NETWORK — PSECU uses neural network systems to predict and prevent unauthorized transactions, There may be occasions when a transaction Is declined because it is indicative of possible fraudulent activity. ictioni,:•This:addendurri is. incorporated into and becomes pert of your LOANLINER Credit Agreement. Please keep heL Payment Your fir'41 payment Is'dkie and payable within 30 days from the date of the loan advance. Annual. Peiceniage Rates, corresponding doily periodic rotes 'and amount of payment for each loan sabaccount ore en below. If there.ifito.payment schedule, the amount and cluedpti: Of payments will be determined ot the time of each soca and disclosed on the Advance Request Voucher, Advance Proceeds Check, or any other loan Yout4r.or receipt : Other rges that ritay be imposed are-alSoshoWn below (i.e,; late chargegi filing lees, collection costs): All rate ardsubjed to - . .. , suit Rote If your loan IS lii default Ike credil'unian reserves the right lo'charge the highest unsecured IntereSt tote'cufrenily Ifect at l'5ECU...• ' . . ..... • Leon .30baCComrit DegEriptIon 4.‘PPC9S.: Percent T!tritl Months index - . . • Dolly 'Perleclic Redo - Present Annual Percentage Rate. Mini�svin . : PaYntici VP; gush 1100 er • toction .61 • of yovt. • Loan 01) • - .40.000 loon or gamier ;212,000,ole6 {12,000 ,o10 or gtPolor • • 115.0113,1pluapNiacitor 16,000 lee orprositop i3,000olve co•prooi4r 53,000 Moe or gr.coiel dI/chicles Only 040.00$ loop pr wootor • • 120,000 wrists, vi' 5rPo1Py 5.12,00.0soltiOosspppipt Slo0oyoe,:;40.044' 96..000veld,, 01 sirwies 13.000 wiloppr firoolos 03.000 V.,10!/ Csf Oitithlt nn/soul NowNsol (2) omoopi 115;000 pp/1 op.: 111.n oo094 08,000 14.999 loon mnoun,t '10,000 7,999 Leon uniounl$8,000. 4.999 A Loon (3) • ;are Loon 13, 411. Up In 31,000 5.1.061 • 34,000 . OYU, 04 ,000 loon soot r1 iDOl) op no o roas1;ropo of 110 04910 minicabs teen (3; 4, 6) orsorsol Stork* 1:son (951114) assorted Service itosoluto Loon (9051.1 414.8;!9•9h*.''' &Melo 11., fyi Yourigonmalb 64: 60 48 36 2-1 120' 84 P- 24 84, 60- .18 36 12 19 '• 120 !yedird.ei. 77 ,itRto 65: 2,0 W11hpul, ' 'Wish' APS', •• AP:ernillis.. • ' veyeissi 49914)46 '00fi177111. ,p001770) .08016411 M01641) 90014/11% :,99913071- .909518u ,Oriot 7781. .b6617*- .OPQ) .00016411 100016411 .00016411 ,0001367f .00024.3:84 tows 384 .00024304 '..0002.064 .00008904 „opeoe904 : .90008404 '00906494 Ilsoci1iPoiorto ..00015343 .0002712 ... • , -11111houl• Auto m 1.111P PayrOOPE .00910.81.. 740 .00017096' 6,49%4 00017090 . 6.49% 01.01111416-, 6.9915 000015724' 5..99% 0001 5726,' 8.99% .,00012984,. 4.99% X0019151 .00617096 ' .D0917094 • .00015728 - *.016726 .0012986 6.49% 649% r" • 0.991: '5.99% 4.99% 1-1/A 8.90% 1•1/e‘ 8 90% N/A • .0,90% N/A 0.90% I-I/A 3.25% I4/A 3.25%' 14/A '3.25% 3.25% PI/A lot gi..10.rn N/A 12 9% .. 990% ilh APS WillieVt ..,. '"Wilt, 'APS erojnoIle- . . : Poyo,80. SA Wks '11.18" 11,49.• 51.45 4.24% 51.69 91.67 01.94 ' .01.513 5.74% $2.35' • 5.74% "63,05 4.7/1%. $1139'. 6.99% • 6.24% $1.17 6.99% 6.24% 6.24% 5.74% 5.74% 5.74% 4.7410L • N/A. N/A I4/A PI/A N/A • PI/A N/A N/A I•I/A .14/A ' !1-49 $!!' 01.94 1?:35 03.05 $4 .311' $1.60 02.67 12.48 03.10 18.49' 1641 $2.23 "10.90 12-81 $3.01 51.17 11.48 $1.67 $234 $304 $4.38 N/A N/A' N/A N/A N/A 14/A N/A N/A I I/A N/A 'N/A V!!" -0400 e D CE143 .11 jiA.391' P_0,Eier.6i0t3..Heresburefo7i0o-7013 PSL :MlnrrriuM --Payment:Ranges li(per 1houtand .portion -thereof)" FIRST PAYMENti ' Your first payment' is due and payable within 30 days from the date of the loan advance, Minimirrn Monthly' Minimum. Biweekly Loan Balance at. Time of Advance Payment Payment 19,090,01 tO20,600.00. 400 200 .1E1,000.0110 19,000.00 380 190 .17,600,01-1918000;09: 360 180 16,000,61 to1;000:00 340 (70 15,000:0i 1.0-16,000.00 320 160 14,001101 to 15,000.00 '300 1.50 '1,000,011.514,9pp.90 2814 140 12,000,01.6 13,00(00 260 130 11 000 Oi to 12 006.00 240 120 .10,000.01 6 t000.00 220 110 '200 .100 18.0 90 '160 80 9,000.01 to 10,000.00' 8,000.01 to 9,000.00 7,000.01 to 8.,000;00 6,006.01 lo 7,060.00 5,000,01 to 6,000.00 4,000,01 to 5,000,00 3,000.01 to 4,000.00 2;060.01 to 3,000.00 1,000.01 to 2,000.00' Up to 1000.00 140 120 100 80 60 40 • 20 70 60 50 40 30 20 10 "Personal Service' Signature Loan Minimum Monthly Payment: 1 po for onglnpl balances 'from $1,000- - $5,000, $200 for original %balances from $5,000;01 410,000 Vigo :DIsclovares Pinanee:hetrap: finance Charge (lowest) is calculated at the monthly periodic role and corresponding annual percentage rale Ort'llie average doily balances of ptirchasei arid cosh advances os described below: Visa (PurchaieS) . Monthly -Periodic Rote .00825'. Annual Percentage Rate • 9.9% Visa (Cash Advances, Checks) -Monthly Periodic fkidly :01075 Annual Percentage gate. .12.9% •Mlnimum Payment; -The minimum monthly Payrnen1 will be either (a) 2.0% of your total new balance or $20.00, whichever is • greater; or (b) your,10101 new balance il hi less Than 520.00, plus (c) any portion of the minimum payment(s) Shown 011 prior statement(s) which remains ungold. Collection Cosisi You promise to pay all' costs of collecting the amount you awe under thlt agreement Including court costs or;dreosonoble attorney fees. Lute Charge; You promise to pay a tole charge of $20 if your Minimum Payment Is not received by the first day of the Month following your due dole. Over Limit Chorges -You promise to pay on over limll charge al 520 if you exceed your credit limit by $100 or more.. Overdraft Option: If you elect to overdraft to your PSECU Visa Credit Cord, 'hot election is sublecl to the existing credit this addendum and the agreement II represents and the current loan poky at the tilos al the overdraft. You also under- stand that an overdraft will be considered the same os n cash advance on your PSECU Visa credit cord and that the current annual percentage role for cosh advances will apply. TELEPHONE INFORMATION AND MAILING ADDRESS: For all purposes os referenced in the Vise Credit cord Agreement and Truth in Lending DisglosUre, call PSECU 01 717.234:8484 in Harrisburg ot 800.237.7328 nationwide, or wrile the Credit Union at: PSECU, P.O. Box 67013, Harrisburg, PA 17106.701:3. Formsylsoniu Slate Employoup Credit Union Point #3100 7106 r°514.911ti'l104"ITT#1'16!**111'4 " JNA Mut 41 Os:sariMO Society... insurance per $100 at monthly loan balance) Single Credit - .070 lii"407.09!nt 400., joint. Credit Ore - 5.123 . . Wison0ln 53701• • edit Dlaahtlity OseurierieSera Schedule of Roles shown below ore arose balance rates. Thiemeons the rotes ore r3pplieclio the sum of the periodic loan payments licii.rematrito be paid on your loon. rate* weISsatedelerpiined bythe pro(ected lion term at your laonf$ee your loon plan to find epral'ecfed tepli.;pfy;;),,,rteen), rorexdosple,if.the piajecled tei tolyaurlaonis 24 months rind the benefit plan is o 4 cloy noriretrosictiire, e rots for thvterrn-ls .2950 per 5100 of rass kjloncv, II the Orpourit:of*Yotir periodic payment I OD, the gross balance a run loan daring the first month of your loan is S7,400.(24.x4.100)...0yr.cherge ta you for insurance for the first Month of your loan an would be $1400x ,29$0 0.01, er.$7;(18: Afieryou have mode your iirs1.$1()Cinffirioilickiori.noireenrilhe gross balance of your an would fhealde $2,800 X $im and our chore to you far your insurance for ho second month would be 52,300 x .2950 x .01; or 56:79:44c,The charges We OclUally Makele you faryear insane -ice areshown in your periodit statement which you receive Iraqi SECO:. . • eoqe rerriember,v,theneyeryou odd a heiry arivpnce1PYOur160, you reposttheloan and a ney/PrOisicted lean term is determined according your loon plan Please note aka that gth@amouptOf i4qr ori64ic199n pcsymer4 is greater than the incriirnurn benefit per month shown t insurance schedule of your'cidilicole:Of inserence;ourVictrgilayouts based on thesum Of the maximum benefits *month times se number of Periodic loon payments remaining to he paid on your loon, ,Forexarnple, if,yoUrperiadi Clear...payment is $400 and the teiirnum benefit per month is 5300 anyou hove 24 remaining lobe paid, the gross balance Of your loon for purposes of tis insurandyWould be $ 7;200 (Pa:59;600).0nd our change to you for insurance the {fret month.yroUld be $21:24 (5 7,200s .2950 0.01). snnsyroania Monthly Renewable Credit Pisability - PisClosure Rates Per $100 of Coverage Pyr Month 1141.E.. 1E8E4 .RATF igmg. 1 0.0000 31 0.2561 61 0.1791 2 0.0000 0:25,19 62 0.1783 91 0.1485 92 0.1480 3 00000 33 0.2479. 63 0.1766 93 0.1468 4 0.5395 34 0.2443 64 0.1753 5 05627 02408 65 0.1742 94 01460 95 0.1454 6 0,5796 36 0.2367 66 111730 96 0.1449 0.2322 0,2300 02260 02234 0,2203' 0218Q 7 0.5372 3767 0.1716 8 05070 38 68 021700 9 * 0,4804 39 -69 .0 .1695 : 10 0.4537 40 70 0,1681 11 0.4407 41 71 0,1:667 1 2 0.4254 42 72 0.1 658 13 0.4.069 43 0.2152. 73 0.1445 14 0:3924 44 0.2125 74 0,1633 15 0:3784 45 0.2099 '75 0.1624 16 0.3643 46 0.2074 76 0.1613 17 0.3548 47 0.2056 77 0,1605 18 0.3448 48 0,2028 78 0:1593 0,2012 0.1985 0.1966' 0.1947 0.1934 0.1910 19 20 21 22 23 24 25 26 27 28 29 30 0,3346 0.3242 0.3171 0.3083 0.3013 0,2950 0.2882 0.2817 0.2759 0.2713 0.2670 0.2614 49 50 51 52 53 54. 55 56 57 58 59 60 0.1889 0.1878 • 0.1858 -0.1837 0.1828 0.1809 79 80 81 82 83 84 85 - 86 87 88 89 90 0.1583 0:1573 01565 0.1556 0,1545 01539 0.1530 01521 0.1514 0.1507 0.1498 0:1493 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 1(4 115 116 117 1.18 119 120 0,1442 0.1438 0,1428 0.1422 0.1418 0.1411 0,1405 0.1396 0.1391 0.1387 1i'r• 0.1379 0.1375 -0.1370 0.1365 0.1.362 0.1355 0.1352 0.1347 0.1342 0.1336 0,1333 0.1327 0.1320 Cti1316 Loan Disclosures late Charge; If you ore morelhon. 15 days late in making q poYrnent,y0a AyilLpciy. . late.charge equal.to live percent 9f the scheduled Payment. Collection Costs : You promise to pay all coste of collecting Ito amount you awe under this dor-denier-it, Including court costs and fees paid ho outside collectors or collection agencies up lo 20 Percent 0f.the outstanding loon balance, (1) PSECU will finance up 10100 percent of tieretailvalue of a new, current Model yearvehicle (untitled). PSECU will fincioCe-ap to 100 percent of the retail value of erased Motar vehicle (titled). The Kelley Blue Book® (registered trademark of Kelley Blue Book Co, Inc.) oeather • autherized.guideS will be used to deterrnine your vehicle's value, Auto loans connot be used to puicliciSe'forritner'cial, theft; salvaged at flood titled vehicles. Thevehicle-MUsthe tilled to The Borrower, Co-Barrowecor both.The registered owner on the Certificate Of Title may not be a business, corporation ortrusl entity. Vehicles must have a minimum4Olue of $3,000 and mLisi.he titled in the U.S. and may not be" taken out of the U.S. (2) PSECU will finance up to 90 percent of the retail value ala new (untitled, Carrent model year) recreational vehicle. Used(tilled) recreational vehicles may be financed Upt090 percent of he used retoilValueTheKelley OlueBOokOr, or other authorized guides will be used to . determine the recreational vehicle's.retail.volue. P5ECU's •niirilmum RV loon Is.53,1360..Your RV musthave o minirrium rtrtil value of fl,333. (3) The Annual Percentage Rate (APR) for Shore secured and IRA advances wil).he the, dividend rote heinEfpctici on. regular shores. (Index) on the date of the advance plus the percentage shoWn.16 the ''Percent Above Index" Column. If there is an existing balance on the dote of the new odvance, the existing balance.wifl be added to the new advance and the entire balance will be at the oeWAPR. The roles are.subjed to change 16 reflect any change In the index, Any'increase-in the.APR take' the farm of mars payments of the some amount until what you owehas been repaid. Loan rates On Certilicaleand IRA loenswilf not.fluc-tUate chiringThe course of the lOon. (4) Shares or certifier' tes pledged roust be owned by the Borrower or Co7Barrower unless the Share or Certificate owner authorizes the pledge in wilting. (5) PSECU will'grani loons secured.by Share. Certificates; Maximum financing. is 90% of the Certificate pledged. The Annual Reraentag Ra (APRPor Certilicate.lcions secured by multiplecertificates will be based on the certificate earning the greater dividend, The term for Certificate loans secured by multiple certificates will be limited lo the lOngest 'term remaining among ihern. Early withdrawal of the unsecured portion is not pennitted and the loan botanCewill b.echle In full if theCedificate is wilhdrawn prior la maturity. Monthly.dIVidends-ore paid IMO the CertifiOote. Al maturity, yOu authorize PSECU to redeem the Cedilicate to pay any remaining loan balance. Funds remaining otter repayment of the lean will be deposited to Regular Shores if you do nal contact PSECU on orbefore the maturity Ogle. Aulomqlic renewal of the Certificate pledged cannot occur until the loan balance' is paid in full. • (6) If you hove been approved for credit under this account, you will be given a specific credit limit, t;ITioni lOckonllyinsured by ika Wallonal Crede Union AdmInbirollon, M23 AM (Moho' Ia. MN 1g AlTODRAFT • . Irla. PAY,.TO.THE. ..I I •• ORDER'OF#DEALER( Pennsylvania State Employees -Credit Union -• ND. 5600150 , : - 'y 'r• , • PO Box )7013 • Harrisburg PA 17t0b_7013 .• (717) 234.8484 or (800) 237-7328 • VOID OVER S:28,000:00 r �,-�'rREFERENCE" < ,8847930107 VOID .120 DAYSIAFTER•-.. 08/18/2006 IMPORTANT; VOID UNLESS DEALER ENDORSEMENT COMPLETED " Buyer,'z Order / &1I of Sate INGvr and Used Vehlclesl and laciory invce INew V.hld'esl must bereceiv'od betare-the AutoDratt is received by PSECU t)4 them'AutoOratl will ba..1.....; reitrrled. tit) portion of the proceeds 01 the AutoOr'elt shall be•pa.d to ttr B000werUl= or to any agent of the Boroowensl. This RotaOran shall not be ua.d to Purehass leconslruct.d. commercial, classic, lh.lt, safveg.d, or Hood Iltled e.hlcl s or vehicle. lnta12 outside the Bolted States. Byx'ctptm`g Ihe'prrreceds of 'Bo. draft''you agree to • the toima Irned on the reverse lade. ; / ``;' PSECU FAX( 717-787.8304 I'. 1r UP.4,r ,', NEVI • usEA , !irt 4/f... MAKE/ C4f -7\/.. M •111 . M a .... OEALEN OINI G f t(.4I4OT E (40844 .4 ' • i'0E600L5011'.':-2 MEMBER ENDORSEMENT' s 'J;• t" •il,. �.r'• By endarsing,lhis ljutoDrolt,%.i/We agree to tie terms fisted on the reverse side :of the dratt;rConiRlete tha:tOIIowing repayment Informttlon. Term 4Monihst: ' Refer to Maximum Terms in ih r Ve1elo Brochure.. Broct. ' Method uto Transfer 0 liomebo1.ing 0 Payton ,Monthly Coupon 0 Direct Payment ftenue, ' .'Mdn4hly+0 8,-Wbeley 0 Weedy 0lSemi-Month Men2lbar Endorsement �� t " -t ` �L/✓ •` ROBERT K BURNS (Cr DOLLARS Co -Applicant Endorsement Ll 13 LoZ 7 PLICANT',.t: L,313 11L61: .• ' 310370423111' 44 '00024994 37342 090186 649' P'3 �m Rel -NICD ii m ca O D 17 m37 I 4��'a^;"OS y c3�'^,;°a nap nm _ o ->��.-a..r•� s.,'• r�.-I �. /•r. tri £ca,@'yucRf �Rrrl "3o�SP. �5 i m Q%QQ. t�LtG: U/ Ali-saiVCJ1�3/ CLf7 •Ty K a 0 4 D 06 FtOa5 BI P 5 2 SD'JEFt'E1C�TIam�a�,,O�9r o` � «e a� Z. "- m � $:�«3 a v rte' -n --Ii 040 PRE-PT{7Lf, 08/ 1'/cQOE WYUI4.ISS] T �a "g p o ' g ° n mD 04 TRC -1305 PK =2a . o= rn m a _g�_; g 0 G N-s� a D m v.10 awn tn�oao..;-n N $rn—S• we Z re LIT r�i Q 2$Qc�S15Rn.m �c_i v<K.om Om b '.�.IcrPO � n� poS.a--I—^-01337 rn F n�=era.; a '�v k��'"�alm10 0 �°sn�s7.�%ar3 `�o n 2 ZrN . si s o f e.o u� g 1 pm t ft -'7: EZ m 5.1i p K © p ref -x) 4181246 EXHIBIT "B" CERTIFICATE OF TITLE FOR A VEHICLE 9/01106 9/01/06 I DATE PA TITLED DATE OF ISSUE UNLADEN WEIGHT ODOMETER STATUS s•„. 0 ..:ACTUAL MILEAGE • I•L' I MILEAGE EXCEEDS THE MECHANICAL.:;;; UNITS 5'- NOT THE ACTUAL MILEAGE 3 = NOT THE ACTUAL. mrtoe-o004trin,, TAMPERING VERIFIED 4 = EXEMPT FROM ODOMETER DISCLOSURE A = ANTIQUE VEHICLE • ,.CLASSIC VSrI,CLIe • D COLLECTOLE VEHICLE- I' F OUT OF OCILNTOY.,,,,,: • G ORIGINALLY1mR913.05 ' .orarnisi.rnOni H AGRICULTURAL VEHICLE L = LOGGING VEHICLE''' P ISIWAS A POLICE VEHICLE = RECONSTRUCTED , S STREET. ROD T = RECOVEREEXTHEFTMEHLOL V . VEHICLE coNTArrieegithap. w = FLOOD VEHICLE • x = IS/WAS'A TAXI ", if a second lienholder is listed upon sitleactIOn AI lisP fIrst 000,1,,d0e !tot fienholdei must forward this Title to the Bureau of Motor Vehicles wIthj appropriate form and tee. A.. 'tilt PSECU P 0 BOX 67013 HARRISBURG PA 17106 I certify as of Me date of issue, the official records of the Pennsylvania Department of Transportation reflect that the person(s) or company narned herein is the lawful owner of the said vehicle. 7.0,1•-•41 - • SUBSCRIBED AND SWORN TO BEFORE ME: rIca_ oH FLO The ondarsigned hereby makes applteatIon ler Certificate of Title to the vehicle described asses, sultieet 10 1110- encumbrances and other legal Mime set forth here. !!' If a co -purchaser other than your spouse is listed and youWant the tit e to be listed as °Joint Tenants With Right of Survivorship ° (On death of One% owner, title goes to surviving owner4 CHECK HERE a Otherwisei.,:AtiOltie . will be issued as 'Tenants In Common(On death of one ewner,,,Ifater0 Of deceased owner goes to his/her heirs or estate): IF NO LIEN, CHECKO IS THIS AN ELT? (IF YES, FIN REQUIRED) YESOjNOD 1ST LIENHOLDER FINANCIAL INSTITUTION NUMBER 1ST LIENHOLDER NAME STREET. CITY STATE IF NO 2ND LIEN, CHECK 0 Is THIS AN ELT? (IF YES, FIN REQUIRED) YES 0 NOD 2ND LIENHOLDER FINANCIAL INSTITUTION NUMBER: SIGNATURE OF APPLICANT on AUTHORIZED SIGNER 2ND LIENHOLDER NAME STREET Bade Sn der ATTORNEYS AT LAW 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com December 12, 2013 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL Mr. Robert K. Burns 402 Pawnee Drive Mechanicsburg, PA 18050-2546 Shawn M. Long, Esquire Direct Dial Number: 717.399.1512 E-mail: slong@barley.com Re: Pennsylvania State Employees Credit Union/2006 Chrysler 300 Dear Mr. Robert K. Burns: 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 2006 Chrysler 300 (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 March 1, 2013 payment in the amount of $352.52 and each monthly payment thereafter in the amount of $371.07. 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 $8,094.60 as of November 20, 2013 (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. You have the right to dispute the validity of the Debt in its entirety or any portion of it. Unless you dispute the validity of the Debt or any portion thereof, within thirty (30) days after 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 ATTORNEYS AT LAW 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL Mr Robert K. Burns 402 Pawnee Drive Mechanicsburg, PA 18050-2546 December 12, 2013 Shawn M. Long, Esquire Direct Dial Number: 717.399.1512 E-mail: slong@barley.com Re: Pennsylvania State Employees Credit Union/2006 Chrysler 300 Dear Mr. Robert K. Burns: 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 2006 Chrysler 300 (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 March 1, 2013 payment in the amount of $352.52 and each monthly payment thereafter in the amount of $371.07. 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 $8,094.60 as of November 20, 2013 (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. You have the right to dispute the validity of the Debt in its entirety or any portion of it. Unless you dispute the validity of the Debt or any portion thereof, within thirty (30) days after 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 December 3, 2013 Page 2 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 prepared 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. 4134195 cc: Mr. Greg Diffenderfer Very truly yours, 10 - UNITED STATES POSIZI. SERVICE U.S. POSTAGE PAID READING,PA 19601 DEC 13. 13 AMOUN1 5i Ai 0003£3113-07 MI F. 630 TO:ROBERT K. BURNS ; /KR nonimM051-3 MECHANICSBURG, PA 18050 S0.46 0103 SENDER: KC REFERENCE: 1.]‘17/2013 PSECU/ BURNS 719L 9008 9040 2198 30813 $3.10 $0.00 $0.00 PS Form 3800, Janua ry 2005 RETURN RECEIPT SERVICE Postage Certified Fee Return Receipt Fee Restricted Delivery 0.92 10 115 0 00 Total Postage & Fees LISPS. Receipt for Certified Mail"' No Insurance Coverage Provided Do Not Use for International Mail • PCSTMAR R DAT bag. VERIFICATION Pennsylvania State Employees Credit Union v. Robert K. Burns I, Julie Serino, being duly affirmed according to law, depose and say that I am the Director, Member Services 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: 0,14/* 4181246 EXHIBIT "B" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Pennsylvania State Employees Credit Union vs. Robert K. Burns Case Number 2014-615 SHERIFF'S RETURN OF SERVICE 0205/2014 Sheriff RonR Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert K. Burns„ but was unable to locate the Defendant in his --'-'--'-'-bai|ieick7-fha'ShohffAhonshoreratometho'withinreqoesb*d1Crnnplain[&1NUdt-J-a-s-'NntSemed"§7-4O2 PawneeDhve,HamdponTownship.PWechonicaburg.PA17O5O.Twe/vaaMam[tootsomionmenamado but deputies were unable to make contact with anyone at the residence to make service. , SHERIFF COST: $73.20 SO ANSWERS, March 05, 2014 RONNYRANDERSON, SHERIFF (c) Co=*SuimSheriff, releaso,Inc, EXHIBIT "C" Results Page 1 of 7 View: Results List I Full I Visualize Re( ( 1 of 1 —") Search: Public Records > Comprehensive Person Report > Search Results > Source Documents Terms: ssn(163-58-8871) state(ALL) radius(30) ( Edit Search I New Search ) Report Contents To of Report Subject Summary Others Using SSN Address Summary (15) Voter Registrations Driver Licenses Professional Licenses Health Care Providers Health Care Sanctions Pilot Licenses Sport Licenses Weapon Permits Real Property -� Assets (2) Motor Vehicle Registrations Boats Aircraft Bankruptcy Information Judgments/Liens (4) UCC Liens Fictitious Businesses Notice Of Defaults Potential Relatives (8) Business Associates Pers ss�c1 eport rocesd by: Nei.:.! - c , YDER (100V32) FOR INFORMATIONAL PURPOSES ONLY Copyright 2014 LexisNexis a division of Reed Elsevier Inc. All Rights Reserved. Employment Locator (1) CrimiFaillibligm(e1) Sexual-legRT KEITH Cellular & Alternate PhonleiOtilTIONAL PERSONAL Sources (108) SSN 163 58 XX -X -X , Further Searches Health Care Provider Hear eject Summary ProlNlarrEarlflithitions Man- igiA "Di - K Recoieil•t URNS, BOB Fore:4,osi(ji NActivity Stat lg %URNS, ROBERT Rea! Vrtl4113, ROBERT K Volur6taIVIDWn ROBERT KEITH Transaction Address 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 INFORMATION DOB 11/1960 (Age:53) Save as Alert ❑ Select for Delivery County Phone YORK -0387 Gender LexID(sm) 000328471896 View All Name Variations Sources Results Page 2 of 7 SSNs Summary No. SSN 1: 163-58-XXXX ' NAi$Motor Vers: 11/1960 1961 State Iss. Date Iss. Most frequent SSN attributed to subject: Pennsylvania 1977-1979 Possible E -Mail Addresses AUSTIN 1539@COMCAST. N ET YOUKNOWITl@AOL.COM 0 Address Summary - 15 records found View All SSN Sources Warnings View All DOB Sources View All E -Mail Sources View All Address Variations Sources No. Address Actions 1: 510 RIDGEVIEW DR Get Report DILLSBURG, PA 17019-1379 YORK COUNTY View Details 2: 402 PAWNEE DR Get Report MECHANICSBURG, PA 17050-2546 CUMBERLAND COUNTY View Details 3: 402 PAWNEE DR Get Report DILLSBURG, PA 17019 YORK COUNTY View Details 4: 144000 ELLA BLVD 1203 Get Report HOUSTON, TX 77014 HARRIS COUNTY View Details 5: 4989 COLUMBIA RD APT 103 Get Report COLUMBIA, MD 21044-5541 HOWARD COUNTY View Details 6: 136 ANNIE LN Get Report ROCHESTER, NY 14626-4373 MONROE COUNTY View Details 7: 4989 103 COLUMBIA RD Get Report COLUMBIA, MD 21044 HOWARD COUNTY View Details 8: 4505 STEARNS HILL RD Get Report WALTHAM, MA 02451-7146 MIDDLESEX COUNTY View Details 9: 4505 STEARNS RD Get Report WALTHAM, MA 02154 View Details 10: 14000 ELLA BLVD APT 1203 Get Report HOUSTON, TX 77014-2577 HARRIS COUNTY View Details 11: 303 FRATERNITY ROW Get Report STATE COLLEGE, PA 16801-5402 CENTRE COUNTY View Details 12: 2527 POLOMAK Get Report RICHMOND, VA 23233 HENRICO COUNTY View Details 13: 1400 ELLA BLVD APT Get Report HOUSTON, TX 77008-5142 HARRIS COUNTY View Details 14: 2527 POTOMAC HUNT LN APT 1 Get Report HENRICO, VA 23233-1553 HENRICO COUNTY View Details 15: 402 PAWNEE LN Get Report CAMP HILL, PA 17011 CUMBERLAND COUNTY View Details Address Details 1: 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Address 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 YORK COUNTY Dates Phone Actions 9/1996 - 3/2014 (1 387 Get Report Neighbors(101. Results Page 3 of 7 Census Data for Geographical Region Median Head of Household Age: 38 Median Income: $64,442 Median Home Value: $168,640 Median Education: 14 years Household Members BURNS, LAUREN A Get Report Other Associates DEWEES, JEFFREY M Get Report 2: 402 PAWNEE DR MECHANICSBURG, PA 17050-2546 Address Dates Phone Actions 402 PAWNEE DR 4/1983 - 2/2012-0082 Get Report MECHANICSBURG, PA 17050-2546 CUMBERLAND COUNTY Census Data for Geographical Region Median Head of Household Age: 44 Median Income: $96,658 Median Home Value: $205,090 Median Education: 15 years -Household Members BURNS, ELIZABETH A Get Report BURNS, ELIZABETH A Get Report BURNS, ELIZABETH A Get Report BURNS, ROBERT E Get Report BURNS, ROBERT EDWARD Get Report BURNS, ROBERT F Get Report DAVIS, DEBORAH ANN Get Report Other Associates None Listed 3: 402 PAWNEE DR DILLSBURG, PA 17019 Address Dates Phone Actions 402 PAWNEE DR 11/2010 - 1/2011 0082 Get Report DILLSBURG, PA 17019 YORK COUNTY Census Data for Geographical Region Median Head of Household Age: 32 Median Income: $53,966 Median Home Value: $128,958 Median Education: 13 years Household Members None Listed Other Associates None Listed 4: 144000 ELLA BLVD 1203 HOUSTON, TX 77014 Address Dates 144000 ELLA BLVD 1203 '4/2003 - 4/2003 HOUSTON, TX 77014 HARRIS COUNTY Household Members None Listed Other Associates None Listed Phone Actions Get Report 5: 4989 COLUMBIA RD APT 103 COLUMBIA, MD 21044-5541 Address Dates Phone Actions 4989 COLUMBIA RD APT 103 4/1983 - 1/1999 (273 Get Report COLUMBIA, MD 21044-5541 HOWARD COUNTY Results Page 4 of 7 Census Data for Geographical Region Median Head of Household Age: 31 Median Income: $88,010 Median Home Value: $399,524 Median Education: 15 years Household Members None Listed Other Associates None Listed 6: 136 ANNIE LN ROCHESTER, NY 14626-4373 Address Dates Phone Actions 136 ANNIE LN 1/1996 - 11/1998 (273 Get Report ROCHESTER, NY 14626-4373 MONROE COUNTY Census Data for Geographical Region Median Head of Household Age: 39 Median Income: $78,512 Median Home Value: $163,835 Median Education: _ 14 years Household Members None Listed Other Associates None Listed 7: 4989 103 COLUMBIA RD COLUMBIA, MD 21044 Address Dates Phone Actions 4989 103 COLUMBIA RD 1/1996 - 1/1996 2273 Get Report COLUMBIA, MD 21044 HOWARD COUNTY Census Data for Geographical Region Median Head of Household Age: 38 Median Income: $103,819 Median Home Value: $379,882 Median Education: 16 years Household Members None Listed Other Associates None Listed 8: 4505 STEARNS HILL RD WALTHAM, MA 02451-7146 Address Dates Phone Actions 4505 STEARNS HILL RD 12/1991 - 12/1995 (48 Get Report WALTHAM, MA 02451-7146 MIDDLESEX COUNTY Census Data for Geographical Region Median Head of Household Age: 35 Median Income: $81,824 Median Home Value: $355,882 Median Education: 15 years Household Members None Listed Other Associates None Listed 9: 4505 STEARNS RD WALTHAM, MA 02154 Address 4505 STEARNS RD WALTHAM, MA 02154 Household Members None Listed Dates 10/1995 - 10/1995 Phone Actions Get Report Results Page 5 of 7 Other Associates None Listed 10: 14000 ELLA BLVD APT 1203 HOUSTON, TX 77014-2577 Address Dates 14000 ELLA BLVD APT 1203 10/1988 - 2/1992 HOUSTON, TX 77014-2577 HARRIS COUNTY Census Data for Geographical Region Median Head of Household Age: Median Income: Median Home Value: Median Education: Household Members None Listed Other Associates None Listed 11: 303 FRATERNITY ROW STATE COLLEGE, PA 16801-5402 Phone Actions Get Report 24 $27,582 $0 13 years Address Dates Phone Actions 303 FRATERNITY ROW 4/1983 12/1991 )082 Get Report STATE COLLEGE, PA 16801-5402 CENTRE COUNTY Census Data for Geographical Region Median Head of Household Age: 21 Median Income: $10,748 Median Home Value: $65,000 Median Education: 13 years Household Members None Listed Other Associates None Listed 12: 2527 POLOMAK RICHMOND, VA 23233 Address 2527 POLOMAK RICHMOND, VA 23233 HEN RICO COUNTY Census Data for Geographical Region Median Head of Household Age: Median Income: Median Home Value: Median Education: Household Members None Listed Other Associates None Listed Dates Phone 11/1989 - 11/1989 Actions Get Report 34 $103,989 $291,092 15 years 13: 1400 ELLA BLVD APT HOUSTON, TX 77008-5142 Address Dates Phone Actions 1400 ELLA BLVD APT 11/1988 - 11/1988 Get Report HOUSTON, TX 77008-5142 HARRIS COUNTY Household Members None Listed Other Associates None Listed 14: 2527 POTOMAC HUNT LN APT 1 HENRICO, VA 23.233-1553 Address Dates Phone Actions Results Page 6 of 7 2527 POTOMAC HUNT LN APT 1 11/1987 - 11/1987 Get Report HENRICO, VA 23233-1553 HENRICO COUNTY Census Data for Geographical Region Median Head of Household Age: 36 Median Income: $65,947 Median Home Value: $190,774 Median Education: 15 years Household Members None Listed Other Associates None Listed 15: 402 PAWNEE LN CAMP HILL, PA 17011 Address Dates Phone Actions 402 PAWNEE LN 11/1985 - 4/1986 111111111.-0082 Get Report CAMP HILL, PA 17011 CUMBERLAND COUNTY Census Data for Geographical Region Median Head of Household Age: 42 Median Income: $82,500 Median Home Value: $171,814 Median Education: 13 years Household Members None Listed Other Associates None Listed E. Real Property - 2 records found 1: Assessment Record for YORK County, PA Owner Information Name: BURNS LAUREN A Name: BURNS ROBERT K Address: 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 County/FIPS: YORK Property Information Address: 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 County/FIPS: YORK Data Source: A Legal Information Assessor's Parcel Number: 58-000-03-0080-00-00000 Book/Page: 1273/6145 Sale Information Sale Date: 09/30/1996 Sale Price: $149000 Assessment Information Assessed Value: $177830 Market Land Value: $40220 Market Improvement Value: $137610 Total Market Value: $177830 2: Deed Record for YORK County View Real Property Sources Automated Valuation Report Automated Valuation Report Buyer Information Name: BURNS, ROBERT K Name: BURNS, LAUREN A Address: 510 RIDGEVIEW DR DILLSBIJRG, PA 17019-1379 Automated Valuation Report County/FIPS: YORK Seller Information Results Name: Name: Name: Address: County/FIPS: Address: County/FIPS: Data Source: • • Page 7 of 7 BURNS, LAUREN A BURNS, ROBERT K DEWEES, LAUREN A 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Automated Valuation Report YORK Property Information 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Automated Valuation Report YORK B Name: COLUMBIA NA Lender Information ONAL INC Legal Information Assessor's Parcel Number: 58-03-0080 Contract Date: 11/09/2000 Recording Date: 11/22/2000 Document Number: 2000066830 Document Type: INTERFAMILY TRANSFER & DISSOLUTION Book/Page: 1417/4554 Loan Amount: $123950 Loan Type: FHA Title Company: LAWYERS TITLE INSURANCE CORP Mortgage Information EXHIBIT "D" Richard P Keuerleber Sheriff Michael S. Hose Chief Deputy, Operations SHERIFF'S OFFICE OF YORK COUNTY PETER J. MANGAN, ES Solici Richard E Rice Chief Deputy, Administrate PENNSYLVANIA STATE EMPLOYEES CREDIT UNION vs. ROBERT K. BURNS Case Number 14-615 CIVIL SHERIFF'S RETURN OF SERVICE 04/02/2014 03:25 PM - DEPUTY MICHAEL S. ECKARD, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: ROBERT K. BURNS AT 510 RIDGEVIEW DRIVE, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED. 04/07/2014 _I, RICHARD P KEUERLEBER,...SHERIFF, WHO BEING .DULY SWORN.ACCORDI.NG TO_LAW,._STATES . . HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: ROBERT K. BURNS, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT & NOTICE AS "NOT FOUND" AT 510 RIDGEVIEW DRIVE, DILLSBURG, PA 17019. SHERIFF COST $44.20 April 07, 2014 NOTARY Affirmed and subscribed to before me this SJp IERS, IC RD P KEUERLEBER, SHERIFF COMMONWEALTH OP PENNSYLVANIA Notarial Seal Sheila E. Cook, Notary Pubis City of York, York County My Commission n Expires Feb. 1, 2017 ...::R. --. A%'iiA ASS0C TION O F (ES EXHIBIT "E" ATTORNEYS AT LAW 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barlev.corn To: Postmaster U. S. Postal Service MECHANICSBURG, PA 17050 April 22, 2014 REQUEST -FOR -CHANGE -OF ADDRESS OR BOXHOLDER INFORMATION Kelly Neumann, Paralegal Direct Dial Number: 717.399.1528 E-mail: kneumann@barley.com Please furnish the new address for the following individual or verify whether or not the address given below is one at which mail for this individual is currently being delivered. If the following address is a post office box, please furnish the street address as recorded on the boxholder's application form. Also include any address listed on a permanent change of address order application (Form 3575): Name (if known) ROBERT K. BURNS Last Known Address 402 PAWNEE DR City, State, ZIP Code MECHANICSBURG, PA 17050 The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii): 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney. 2. The names of all known parties to the litigation: Pennsylvania State Employees Credit Union vs. ROBERT K. BURNS. 3. The court in which the case has been or will be heard: CUMBERLAND County Court of Common Pleas. 4. The docket or other identifying number if one has been issued: 2014-615 5. The capacity in which the customer is to be served (e.g., defendant or witness): Defendant, ROBERT K. BURNS. 6. A brief description of the nature of the litigation (e.g., domestic relations, personal injury, property damage, indebtedness): indebtedness. ATTORNEYS AT LAW April 22, 2014 126 Eastf}i,e tet Lancaster, Pg. 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com I certify that the above information is true and that the name and/or street address of the customer is needed and will be used solely for service of legal process in connection with actual or prospective litigation. FORWARDING: 4287451 1 Name Signature Kelly Neumann, Paralegal Printed Name - - Barley Snyder Address 50 N. Fifth Street, P.O. Box 942 Address Reading, PA 19603-0942 City, State, ZIP Code FOR POST OFFICE USE ONLY Street Address City, State, ZIP Code No change of address on file. Not known at address given Moved, left no forwarding address. No such address. Postmark EXHIBIT "F" Barle Sn der ATTORNEYS AT LAW 126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.corn Kelly Neumann, Paralegal Direct Dial Number: 717.399.1528 E-mail: kneumann@barley.com To: Postmaster U. S. Postal Service DILLSBURG, PA 17019 April 22, 2014 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION Please furnish the new address for the following individual or verify whether or not the address given below is one at which mail for this individual is currently being delivered. If the following address is a post office box, please furnish the street address as recorded on the boxholder's application form. Also include any address listed on a permanent change of address order application (Form 3575): Name (if known) ROBERT K. BURNS Last Known Address 510 RIDGEVIEW DR City, State, ZIP Code DILLSBURG, PA 17019 The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii): 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney. 2. The names of all known parties to the litigation: Pennsylvania State Employees Credit Union vs. ROBERT K. BURNS. 3. The court in which the case has been or will be heard: CUMBERLAND County Court of Common Pleas. 4. The docket or other identifying number if one has been issued: 2014-615 5. The capacity in which the customer is to be served (e.g., defendant or witness): Defendant, ROBERT K. BURNS. 6. A brief description of the nature of the litigation (e.g., domestic relations, personal injury, property damage, indebtedness): indebtedness. Barle Sn der ATTORNEYS AT LAW prt 126 East ISWt2eet Lancaster, PX 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com I certify that the above information is true and that the name and/or street address of the customer is needed and will be used solely for service of legal process in connection with actual or prospective litigation. FORWARDING: 4287451_1 Signature Kelly Neuma Printed Name Barley Snyder Paralegal Address 50 N. Fifth Street, P.O. Box 942 Address Reading, PA 19603-0942 City, State, ZIP Code FOR POST OFFICE USE ONLY Name Street Address City, State, ZIP Code No change of address on file. Not known at address given Moved, left no forwarding address. No such address. EXHIBIT "G" PeopleMap Report (Premier) ROBERT K BURNS 7/18/2014 12:16:32 PM Client ID:OFFICE Possible People Information Person Overview ROBERT K BURNS 510 RIDGEVIEW DR DILLSBURG, PA 17019-1379 Phone Number(s): rlT2-O3 87 -4599 SSN: ..163-58-XXXX - issued in PA in 1977-1979 Date of Birth Summary Date of Birth SSN Summary SSN 163-58-XXXX - issued in PA in 1977-1979 Phone Numbers Phone 0387 dalia-4599 z- Bc to 0 O Source Experian Credit Header Real Time Source Experian Credit Header Real Time People Historical Source Experian Credit Header Real Time Experian Credit Header Real Time Name Variations Name Source ROBERT KEITH BURNS Experian Credit Header Real Time ROBERT K BURN Experian Credit Header Real Time ROBERT BURNS Experian Credit Header Real Time BOB BURNS Experian Credit Header Real Time BURNS ROBERT Experian Credit Header Real Time ROBERT K BURNS Experian Credit Header Real Time Addresses WestlawNexr © 2014Thomson Reuters. No claim to original U.S. Government Works. 2 EXHIBIT "H" :'.44/WHileeretaW Robert K Burns Phone and Address I Zabasearch.com Free People Search Page 1 of 2 ZABA® People Search. Honestly Free! Search by Name. Find People in the USA. Free People Finder. Like 9.6k White Pages Reverse Phone Lookup IZabaSearch Advanced Free Search Menu Top 25 Name Searches Premium Services: Run a Background Check 1 Search by Phone Number Robert K Burns Pennsylvania Search Narrow your results by: Filter Public Information Results Summary: 3 Results found for Robert K Burns Robert K Burns - Detailed Background Report Comprehensive Report. Criminal Records. Latest Contact Information, Find Robert K Burns Get Current Phone and Address Can't find Robert K Burns? 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I ntelius.com/P remier-Trial http://www.zabasearch.com/neonle robert+k+burns/na/ 7/28/2014 EXHIBIT «I„ Search Results for Robert Burns - PeopleFinders.com Page 1 of 3 - advertisement - rir =tires apt:west _ r r) peoplefinders- 7,1 My Account I My Reports Log In Sign up for a membership » People Search Background Check Criminal Records Public Records Genealogy Search Reverse Phone 1. MI: Last Name: City: State* Age: Date of Birth: Robert -Bums Pennsylvania •• Month 'Lid Day E• Year i Update Search j . . Robert A Burns 20 people named Robert Burns in PA Found! Click a Name to View More Info. Name Age Has Lived In i 84 West Chester, PA Possible Relations Brian Bums Phone Number, Address & Other Details Robert A A Bums Bums R Burns R A Berwyn, PA l • • - Bryn Mawr, PA Newtown Sq, PA Wayne. PA Carol H Burns Floranne M Burns Lindsay F Burns Robert Brian Burns More relatives... - View Details 2. Robert A Bums l 42 Robert A Burns SR Robt A Burns JR Moscow, PA Milford, PA Peckville, PA Madison Township, PA Lake Ariel, PA Brian R Bennett Brian Randall Bennett Linda E Burns Paul D Burns Roberta Burns More relatives... View Details 3. 4. Robert B Burrs Robert B Bums JR Robt B Bums JR Robert C Bums Cartland Cartland Burns Robert G Burns Bums R Burns R C 67 50 I I Uniontown, PA Morgantown, WV Belle Vernon, PA Mount Morris, PA Sioux Falls, SD Orlando, FL Pittsburgh, PA Batesville, VA Omaha, NE Crozet, VA Gilbert J Burns Gilbert J Burns Robert C Burns Robert J Burns Sharon L Bums More relatives... View Details Arthur Wellwood Burns Linda L Bums David R Hemeter Jill Marie Kohlscheen David Ruffin Redwine More relatives... View Details 5. Robert C Burns 55 Robert Cheri Burns JR Rob Chart Burns SR Robt Cheri Burns SR Du Bois, PA Reynoldsville, PA Dubois, PA Dawn M Burns Georgene M Burns Jon Michael Bums Leighann Burns Robert C Burns More relatives... View Details 6. Robert C Burns Robert W Bums 39 Towson, MD Rosedale, MD York, PA New Freedom, PA Middle River, MD Bree Mcilvaine Bums Robert W Bums Robert W Bums Gail Frances Keeling Curtis Monroe Tabor More relatives... View Details 7. j Robert C Burns 70 Robert C Bums SR WAYNESBORO, PA York, PA Waynesboro, PA Nancy M Bums Robbin Stover Burns Robert C Burns Tammy Lynn Bums Anthony Lowell Stover More relatives... View Details 8. l Robert C Burns 1 49 Robert Charles Bums JR Waynesboro, PA Zullinger, PA Potsdam, NY Nancy M Burns Robbin Stover Burns Robert C Bums Tammy Lynn Burns Jenne G Rodgers More relatives... View Details Search Results for Robert Burns - PeopleFinders.com Page 2 of 3 9, Name Robert E Burns Robert E Burns III Robert E Urns JR Age 57 Has Lived In Philadelphia, PA Bensalem, PA Andalusia, PA Possible Relations E Burns Robert E Bums Burns Valerie Pisieczko Connie W Pisieczko Walter E Wakefield More relatives... Phone Number, Address & Other Details View Details 10. Robert E Bums Robert L Burns JR 67 Levittown, PA Detroit, MI Bensalem, PA McLean, TX Carson City, MI Adam C Burns Jerome R Bums Joseph L Burns Marshall Burns Ryan Patrick Burns More relatives.,. View Details 11. n -1 12. , ' 13. i Robert F Bums Robt F Burns JR Rober T Burns JR Robert G Burns Robert A Burns Robert F Bums j 54 1 48 .L._ Trucksville, PA Wilkes Barre, PA Bear Creek Township, PA f_ Castle Creek, NY Susquehanna, PA Vestal, NY Wilkes Barre, PA Michael T Burns Michael T Burns Robert Burns Robert F Burns Laura Sarah Dimarzo More relatives... View Details 1 Ann Petroski Burns Lori Ann Burns Robert Bums Susan H Bums Brian James Mcfadden More relatives... View Details -- Robert J Bums Janet M Burns James Robert Burns Jan Robert Burns Jane T Burns 77 Danville, PA Lewisburg, PA Milton, PA Bryan D Bums Jennifer L Slease Michael G Slease Nancy S Slease Suzanne M Slease More relatives... View Details 14, Robert J Burns Jr Robert J Bums JR 1_ ' 53 Pottsville, PA Seltzer, PA View Details 15. Robert J Burns 59 Philadelphia, PA Jeanne M Burns Jeanne M Burns Judith Stairiker Bums Liam Stairiker Burns Robert J Burns View Details 16. Robert Jospeh Bums 57 Allentown, PA Mount Carmel, PA Hightstown, NJ Robert Bums Susan Irene Burns Beatrice I Derk Clyde M Derk Mary C Derk More relatives... View Details 17. jRobert L Bums Richard C Bums Robert C Burns Robert L Bumsdr -,-- 67 Reedsville, PA Lewistown, PA Richard Charles Burns Robert C Bums Susan L Burns Michael A Jacobson Sarash C Jacobson More relatives... View Details 18. Robert M Burns Robert A Burns III 49 York, PA Seven Valleys, PA Daytona Beach, FL Tallahassee, FL Dania, FL Gregory William Burns Karen Baum Bums Melody D Lesh Ruth M Vaughn Samuel G Vaughn More relatives... View Details 19. Robert 0 Burns 76 Harrisburg, PA York, PA Lenore F Burns Robert 0 Burns Rose Marie Burns Marjorie L Jaeger Thomas M Jaeger More relatives... View Details 20. Robert W Bums 34 York, PA Elizabethtown, KY Radcliff, KY Leeta M Bums Letta M Burns Letta M Burns Robert C Burns RobertW Bums More relatives... 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Powered by DataTsunami"" http://www.peoplefinders.com/search/searchpreview.asnx?searchtvne=neonle-namprfn=R '70R/1n i a EXHIBIT "J" Robert Burns in PA 1 WhitePages Page 1 of 3 Robert K Burns Jr Address Phone Age: 50-54 Lives in: Altoona PA Knows: Jennifer R Burns, Sherri L Burns, Mark R Pulcinello Lived in: No known previous cities View Full Profile View Address Robert K Burns Jr Address Phone Age: 45-49 Lives in: Bainbridge PA Knows: Audrey J Burns Lived in: No known previous cities View Full Profile View Address Robert K Burns Address Phone Age: Unknown Lives in: Philadelphia PA KriciWS: Calvin A Austin li Lived in: Philadelphia PA, Cleveland OH, Lakewood OH, Euclid OH View Full Profile View Address Robert K Burns Jr Address Phone Age: 50-54 Lives in: Duncansville PA Knows: Kathleen Yoder, Sherri L Burns, Marsha J Bell Lived in: No known previous cities View Full Profile View Address Sponsored by PeopleSmart.com Robert William Burns 40 years old Drexel Hill, PA Email I Public Records I Phone View full details Sponsored by PeopleSmart.com Robert C Burns 54 years old Du Bois, PA Email I Public Records I Phone View full details Robert Burns Address Phone Age: 55-59 Lives in: New Wilmngtn PA Knows: Dorothy R Burns, Andrea Burns, Joshua Burns Lived in: New Wilmington PA, Mercer PA, New Wilmngtn PA View Full Profile View Address Robert J Burns Address Phone Age: 65+ http://www.whitepages.corniname/Robert-K.-Burns/Pennsylvania 7/")52/N.11 Lt Robert Burns in PA 1 WhitePages Page 2 of 3 Lives in: Yardley PA Knows: No known associations Lived in: Doylestown PA, Bristol PA, Yardley PA, Levittown PA View Full Profile View Address & Phone Number Robert Burns Address Phone Age: Unknown Lives in: Pittsburgh PA Knows: No known associations Lived in: No known previous cities View Full Profile View Address Robert F Burns Address Phone Age: 65+ Lives in: Phila PA Knows: Geraldine A Burns Lived in: Philadelphia PA View Full Profile View Address & Phone Number Robert Burns Address Rhone - Age: 25-29 Lives in: Jefferson Township PA Knows: Renee A Calabro, Gaetano J Calabro IV Lived in: Scranton PA, Pensacola FL View Full Profile View Address Robert E Burns Address Phone Age: 65+ Lives in: Mechanicsburg PA Knows: Elizabeth A Burns Lived in: Dillsburg PA, State College PA, Rochester NY, Henrico VA, Houston TX, Waltham MA, Columbia MD View Full Profile View Address & Phone Number Prev 1. 1 2. 2 3. 3 4. 4 5. 5 6. 6 7. 7 8. 8 9. 9 10. 10 Next © 2014 WhitePages Inc. - Privacy Policy and Terms of Use httn•//www whiten crcAc r•nrt, 1i. o,, ID Tr ID,— - IT - EXHIBIT "K" LAUREN A. BURNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. ROBERT K. BURNS, Defendant : NO. 2007-5908 CIVIL TERM ORDER OF COURT AND NOW, this 16th day of August, 2011, the Petition is granted, and it is ordered and directed that the Defendant's Social Security number be deleted from all public records. Samuel L. Andes, Esquire ,For the Plaintiff Robert Burns, Pro se 402 Pawnee Drive Mechanicsburg, PA 17050 Sheriff — srs By the Court, Edward E. Guido, J. -0 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 I� r; R0 i H0NQ ir\R a 201 y SEP 10 PH 3: f 5 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, v. ROBERT K. BURNS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014-615 AND NOW, this ASA of ORDER , 2014, upon consideration of the Motion of Pennsylvania State Employees Credit Union for Special Service Order, and the Affidavit attached thereto pursuant to Pa. R.C.P. Nos. 430(a), it is hereby ORDERED and DECREED as follows: 1. 18050-2546; That service of the Complaint on the Defendant shall be made by: a. posting on the most visible part of 402 Pawnee Drive, Mechanicsburg, PA b. regular and certified mail, return receipt requested, to the Defendant at 402 Pawnee Drive, Mechanicsburg, PA 18050-2546, ?)3 a,c-ceuleu.R- ‘1,1-4JW toe -v.4 tfAru-givA-e-. 5 4421843.1 en ng persona service on the , re receip requested, to - an o e e endant's 11. n St, 3. That the postin and the mailing by regular and certified mail, return receipt A • requested of any service of the Complaint g persurral-sepAictiwkwit shall be deemed served upon the Defendant upon the later of the date of posting or the date of mailingf cop/ ritv_:.1.c..L 144i P. koi 4421843.1 6 , J. . Distribution: Shawn M. Long, Esquire Barley Snyder 126 East King Street Lancaster, PA 17602-2893 Robert K. Burns 402 Pawnee Drive Mechanicsburg, PA 18050-2546 Andrew H. Shaw, Esquire 200 S Spring Garden St Carlisle, PA 17013 4421843.1 9/11/2014 PSECU IN THE COURT OF COMMON PLEAS [Plaintiff] CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT K. BURNS [Defendant] CIVIL ACTION LAW NO. 2014-615 16;1.1"1erm IN: Counter Action in Replevin (Reply) C") T a Reply objection to 09-08-14 Plaintiff. PSECU (Court Reconsideration) 2I -Motion for Service Pursuant to SPECIAL Order of Court PA.R.C.P.430a with Counter Motion to Stop PSECU (and their affiliated parties) from Posting to Property already ruled upon by this Court 08-18-2014 Defendant Counter Motion support in asking this court to impose a cease and desist action .of any postings pursuant notices by Plaintiff as his Honor has already ruled on this matter. Defendant, in this latest counter motion reply, objects to this refiling of an already ruled upon Plaintiff motion of an existing Complaint Service &/or posting to 402 Pawnee Drive, Mechanicsburg, PA 17050. Defendant support to stop moving Plaintiff's 09-08-14 said second Motion "to Reconsider" avers the following: 1. No valid or legal reason for this latest motion to post to a secondary property. First, in Plaintiff original motion (ruled upon) it went to great lengths for the posting at my owned, legal address of 510 Ridgeview Drive, Dillsburg, PA. In Plaintiff original motion, it's supporting evidence considered every legal address (exception of one) of myself, this Defendant. Plaintiff, itself, considered and dismissed 402 Pawnee Drive in its original complaint to post at 510 Ridgeview Drive. As brought before this court in Defendant's original motion reply, PSECU & all of their contracted parties have had my contact information since the loan's inception on 09-06-06. This includes PSECU themselves, Barley Snyder, Richard & Associates and APAccount Services since 04-27-10. My contact information has not changed. I have the 09-06-06 same 510 Ridgeview Drive, York County address (which PSECU has concluded in this Motion), email address & phone number. 2. This Plaintiffs second motion is a result of this Court's original motion ruling whereas Plaintiff moves Court to reconsider. Apparently, Plaintiff not only "objects," but it must strenuously object. 3. There's no need for this Defendant to address every Plaintiff supposed point (inaccuracies noted) and exhibits as they are a regurgitated/recycling of Plaintiff original ruled upon motion and they've already been addressed by this defendant in the counter reply to Plaintiff original motion. That said, there are some Plaintiff supporting points to address (with a broad brush). #1, Plaintiff prematurely filed a complaint by their own admission and documentation on failure of their commitment to address a dispute before filing their Complaint 01-31-14. They did not fulfill their commitment, did not address the dispute & did prematurely file an inaccurate Complaint. To date, still no movement on addressing, let alone settling the Defendant dispute. 4. The Defendant dispute refresher. Plaintiff issued a $24,900 check for a loan grant in Sept 2006. 9/11/2014 Though ther 's and existing dispute on unauthorized charges and monies paid toward loan not applied in cess o $30,000 by this Defendant, I never missed a pymt or promise to pay in the six years. 5. The Plaintiff's original and now this second Complaint posting centers around a 01-31-14 Complaint that I answered within the allotted time, even though never served. Defendant's point, if I answered the Complaint, this defendant obviously received it at the owned 510 Ridgeview Drive property address. In addition, this Defendant has answered every Plaintiff motion & court motion promptly proving I am in receipt. 6. This Plaintiff's 09-08-14 motion points #2 - #11 all involve plaintiff background research and Sheriff's Dept solicitation and service. Defendant erred in his assumption that if a complaint was answered but never served to its party, the system would cancel out the continued need of service. This Defendant has since corrected his action by calling the CC Sheriff's Dept directly on an issue pending. Last call was 09-04-14 that was before learning of this 09-08-14 Plaintiff filing. 7. #12 - #13. Plaintiff claim of a service or posting to a 402 Pawnee Drive address is now, but previously dismissed by them, a defendant residence is inaccurate. It's Not! They obtained it from a Divorce complaint in 2007. That was for documentation in "currently resides at" by opposing attorney. It's not my address and I never provided that information. This defendant washes his hands of any legal action taken toward the Plaintiff at this address by its owners. #12 Plaintiff cannot confirm 402 Pawnee Drive address residence. #13 Defendant requests sources of 402 Pawnee Drive address confirmation. Postmaster, neutral 3rd party, doesn't confirm Plaintiff request, and Plaintiff own research brings them back to 510 Ridgeview Drive. Defendant respectfully requests the source of this sudden 402 Pawnee Drive residence revelation. (Side Note: Plaintiff in Divorce action refuses to move forward; this defendant has been notified to propose action before 10-23-14 to be keep case open) 8. Defendant cannot address (but requests plea of not contacting Andrew Shaw) any response by my former attorney in the Divorce action. If Plaintiff did their homework, they should have known that. Thanks for the Court's consideration. Robert k. Burns 09/11/14 Robert K. Burns Signature of Petitioner Date Shawn Long, Esquire (Barley Snyder) For the Plaintiff Robert K. Burns Defendant BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 2014-615 -.,LED' UFF,L. THE PROTHONO T/ MI, SEP 2 L Pr's if: 5L CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff v. ROBERT K. BURNS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014-615 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above -captioned action. BARLEY SNYDER LLP Sha n Long, Es. ire C. 'rt I.D. No. 8377 Attorneys for Plai iff Pennsylvania Sta - Employees Credit Union 126 East King Stieet Lancaster, PA 17602 (717) 299-5201 4245402_1 4245402.1 CD a OF- Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY N -LO -OF OF THE PROMO() zatii OCT 13 1 07 CUMBERLAND COUNTY PENNSYLVANIA OF; C.E. QV THE; $',HER1FF Pennsylvania State Employees Credit Union vs. Robert K. Burns Case Number 2014-615 SHERIFF'S RETURN OF SERVICE 09/30/2014 01:07 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint & Notice upon the within named Defendant, to wit: Robert K. Burns, pursuant to Order of Court by "Posting" the premises located at 402 Pawnee Drive, Hamdpen Township, Mechanicsburg, PA 17050 with a true and correct copy according to law. GUTSHALL, DEPUTY SHERIFF COST: $45.30 SO ANSWERS, October 01, 2014 RONO R ANDERSON, SHERIFF (C) CouritySuRe Sheriff, Teierisoft, nC 10/28/2014 c PSECU IN THE COURT OF COMMON PLEAS [Plaintiff] CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT K. BURNS [Defendant] CIVIL ACTION — LAW NO. 2014-615 [Civil Term] IN: Counter Action in Replevin (Reply) C=3 Zr ma) (9 rn .% _<)". oo < , r) — .„<, rJ Counter Complaint Reply to PSECU ongoing Complaint served/posted 10-08-14 Defendant Counter Motion support in asking this court to consider PSECU misrepresentation on auto loan granted in Sept. 2006. This counter motion reputes DEFAULT status requests the court to consider the following as a basis to refute default: 1. OCC Advisory Letter AL 2003-2 describes predatory lending as including the following: • Loan "flipping" - frequent refinancing(s) that result in little or no economic benefit to the borrower and are undertaken with the primary or sole objective of generating additional loan fees, prepayment penalties, and fees from the financing of credit related products; • - Refinancing(s) that result in the loss of beneficial loan terms; - "Packing" of excessive and sometimes "hidden" fees in the amount financed; • Using loan terms or structures - such as negative amortization - to make it more difficult or impossible for borrowers to reduce or repay their indebtedness; • Targeting inappropriate or excessively expensive credit products to older borrowers, to persons who are not financially sophisticated or who may be otherwise vulnerable to abusive practices, and to persons who could qualify for mainstream credit products and terms; Inadequate disclosure of true costs, risks & where necessary, appropriateness to borrower of loan transactions; 2. Defendant dispute has been covered on in previous counter complaint discovery and exhibits already on record. 3. Defendant has already paid to PSECU at least $4,000 more than the borrowed amount. a. PSECU has refused to disclose fees and charges applied to this loan where monies paid were not applied, also before the court. b. Borrower refused to provide defendant this documentation making it impossible to refinance to loan through another lender. fil e:///CJUsers/M IKE/AppData/Local /M icrosoftANindows/Tem porary%20Internet%20Fi I es/Content.IE5/3UZGNPQY/86-2014Psecu_countrM o.htm 1/2 10/28/2014 •'than}s for the Court's consideration. Robert k. Burns Robert K. Burns Signature of Petitioner Date file:///C:/Users/M IKE/AppDate/Local/M icrosofl/W indowvs/Tem porary%201nternet%20Files/C ontent.lE5/3UZGN PQY/862014Psecu_countrM o.htm 2/2 1T BARLEY SNYDER 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, v. ROBERT K. BURNS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION IN REPLEVIN No. 2014-615 VERIFICATION Kelly Neumann, hereby verifies that on October 10, 2014 service of the Reissued Revival was served by publication upon the Defendant, Robert K. Burns, in accordance with Order of Court dated September 10, 2014 in the Sentinel and the Cumberland Law Journal. Service of the Reissued Revival was also served by posting by the Cumberland County Sheriff on September 30, 2014 upon the Defendant's last known address of 402 Pawnee Drive, Mechanicsburg, PA 18050-2546 and by regular and certified mail on October 2, 2014 at the same address. Proofs of publication in the Sentinel and the Cumberland Law Journal, posting, and mailing by regular and certified mail are attached hereto and marked Exhibit "A". BARLEY SNYDER Dated: October 30, 2014 By. Kelly Neu nn, Paralegal 126 East g Street Lancaster, PA 17602 717.299.5201 4487983.1 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz October 10, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 10 day of October, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action—Law 2014-615 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff vs. ROBERT K. BURNS, Defendant NOTICE To: ROBERT K. BURNS You are hereby notified that on January 31, 2014, Plaintiff, Penn- sylvania State Employees Credit Union, filed a Complaint endorsed with a Notice to Defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 2014-615, which has been reinstated, wherein Plaintiff seeks to enforce its rights under its loan documents. Since your current whereabouts are unknown, the Court by Order dated September 10, 2014, ordered notice of said facts and the filing of the Complaint to be served upon you as provided by R.C.P. 430(b). You are hereby notified to plead to the above referenced Complaint on or before 20 DAYS from the date of this publication or Judgment will be entered against you. NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, the case may proceed without you and a Judgment may be entered against you without further notice for 13 the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OF- FICE 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 AGEN- CIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 SHAWN M. LONG, ESQUIRE BARLEY SNYDER 126 East King Street Lancaster, PA 17602 (717) 299-5201 Oct. 10 VS99Z91.10 1,1•0 ZO9L dIZ zi0E. 1-0$ TO: ROBERT K BURNS 402 PAWNEE DR MECHANICSBURG, PA 18050 SENDER: REFEREME: PSECU/ BURNS OZ/ZO Aaiseti (T14:341, •144A-9120[34 OD D 81.0n 14 1. PS F RETURN RECEIPT SERVICE Postage Certified Fee Return Receipt Fee Restricted Delivery 2.03 3 n 1 9 Total Postage & Fees US Postal Service® Receipt for Certified Mair No Insurance Coverage Provided Do Not Use for International Mail 0.00 POSTMARK Ofii:WE PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Cathy Clark, Advertising Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of October 10, 2014. COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication true. OCcLtilz) Sworn to and subscribed before me this \4 dad �I-��e d l4 . ,,611-kniA Notary Public My commission expires: COMMONWEALrt4 OF PENNSYLVANIA Notarial Seal Bethany M. Hoitry, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 26, 2015 MEMBER p'o;c,:. ;;,r.�r -r.,70N OF NOTARIES NOTICE IN THE COURT OF PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -.LAW PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, • Plaintiff vs. ROBERT K. BURNS Defendant CIVIL ACTION -.LAW 2014.615 NOTICE ,To: ROBERT K. BURNS You are hereby notified that on January 31, 2014, Plaintiff, Pennsylvania State Employees•Credit Union, filed a 'Complaint endorsed with a Notice to Defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to,No. 2014-615, which has been reinstated, wherein Plaintiff seeks to enforce its rights under its loan documents. Since your current whereabouts are unknown, the Court by Order dated September 10, 2014; ordered notice of said facts and the filing of the Complaint to be served upon you as provided by R.C.P.430(b). • You are hereby notified to plead to the above referenced Complaint on or before 20 DAYS from the date of this publication or,Judgment will be entered against you. NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or obligations in writing with the Court. You are warned that if you fail to do so, the case may proceed without you and a Judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD.TAKE.THIS NOTICE 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 71.7-249-3166 Shawn M. Long, Esquire BARLEY SNYDER 126 East King Street • Lancaster, PA 17602 717-299-5201' • SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor cit C:I/Orcr V, fl .$4-,ER1Pr, Pennsylvania State Employees Credit Union vs. Robert K. Burns Case Number 2014-615 SHERIFF'S RETURN OF SERVICE 09/30/2014 01:07 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint & Notice upon the within named Defendant, to wit: Robert K. Burns, pursuant to Order of Court by "Posting" the premises located at 402 Pawnee Drive, Hamdpen Township, Mechanicsburg, PA 17050 with a true and correct copy according to law. GUTSHALL, DEPUTY SHERIFF COST: $45.30 SO ANSWERS, October 01, 2014 (c) COuntySuito Sheriff, Tnleosoft inc. RONNY R ANDERSON, SHERIFF