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Home My WebLink About05-1213 SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION f/k/a WEST SHORE TEACHERS FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA Plaintitf v. NO. or - 1';1./2, C;f->~L 'L(rL~ JOHN E. MINICH CIVIL DIVISION - LA W Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, yon mnst take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the conrt yonr defenses or objections to the claims set forth against you. Yon are warned that if yon fail to do so the case may proceed withont yon and ajudgment may be entered against you by the conrt without fnrther notice for any money claimed in the complaint or for any other claim or relief requested by the plaintitf. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LA WYER. THIS OFFICE MAYBE 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 ASSOCIA nON TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249,3166 SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION tlk/a WEST SHORE TEACHERS FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA PlaintitT v. NO. Of; - 1~/j GuL Y CULl/, .JOliN E. MINICH CIVIL DIVISION - LAW Defendant COMPLAiNT The Plaintiff: SUSQUEHANNA V ALLEY fEDERAL CREDIT UNION, by its attorneys, KNUPP, KODAK & IMBLUM, P,C.. brings this action of Assumpsit againstthe Defendant to recover the sum of ELEVEN THOUSAND, FOUR IIUNDRED SEVENTY,EIGHT DOLLARS AND SEVENTY-TWO CENTS ($11,478.72), along with interest thereon from March 1,2005, at the rates as agreed upon between the parties, upon a cause of action of which the following is a statement: I. The Plaintiff, SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, is a corporation organized and existing under Fcderal Laws, having its principal office and place of business at 3850 Hartzdale Drive, Camp Hill, Cumbcr/and County, Pennsylvania, 17011-7809. 2. The Defendant, JOHN E. MINICH, is an adult individual residingat4334 Enola Road, Newville, Cumberland County, Pennsylvania 17241. COUNT I - SUSOUEHANNA V ALLEY FEDERAL CREDiT UNION VS, JOHN E, MINICH 3. Paragraphs I and 2 are incorporated herein as iffully and at length set forth. F:\USr -:!{\Sl^( 'Y\C '( 'jl ('( )MPI AINTS\ WORK\sVC1l3122gU .1&11.\\pd:2HFcb05 4. On or about October 26, 200 I, the Defendant did submit a Visa Card Application tothe Plaintiffat Plaintiff's omce in Cumberland County, Pennsylvania and, atier review and approval, a Visa Card was subsequently issued to Defendant, thereby creating the situs for the Contract between the parties. A copy of said Visa Card Application is attached hereto, marked as Exhibit" A" and made a part hereof. 5. Defendant has defaulted under the terms of the Application by failing to make monthly payments when due and o\ving. 6. The principal balance due and owing by Defendant to Plaintiffis the sum of Four Thousand, Two Hundred Twenty-Six Dollars and Seventy,Eight Cents ($4,226.78) as appears by Plaintiff's Statement of Account hereto attached, marked as Exhibit uBI! and made a pal1 hereof. 7. Due to Defendant's default in payment of said amount due and owing as aforesaid, interest and late charges have been added to said account in the total amount of One Hundred Eight Dollars and Three Cents ($108.03) as shown on said Exhibit "8", 8. Due to the default of Defendant, and pursuant to the terms and conditions of the Visa Credit Card Agreement, hereto attached, marked Exhibit "C" and made a part hereof. attorney's fces in the total amount of Eight Hundred Fifty-Six Dollars and Twenty-Three Cents ($856.23) have been added to said account. 9. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof. F:\l ,lSU{'\STACY\CCP CO!\1PLA fNTS\ WORK\svcu3122RLLI&ll.wpd:2XFeb05 3 WHEREFORE, Plaintiff brings this suit to recover trom Defendant the sum of Five Thousand, One Hundred Ninety- Onc Dollars and Four Cents ($5,191.04) along with interest thereon Irom March 1.2005. COUNT n - SUSOUEHANNA V ALLEY FEDERAL CREDIT UNION vs, .JOHN E, MINICH 10. Plaintiff incorporates Paragraphs I through 9 inclusive as iffully and at length set forth herein. II. On or about June 23, 2003. Defendant, did apply for credit with Plaintiff through its Loanliner Program. A true and correct copy ofthe LoanlinerOpen-End Voucher and Security Agreement, cxecuted by the Defendant, is attached hereto, marked as Exhibit "0" and made a pal1 hereof. 12. Defendant has defaulted under the terms of the Loanliner Agreement by failing to make monthly payments \vhen due and owing. 13. The principal balance due and owing by Defendant to Plaintiff is the sum of Four Thousand, Nine Hundred Seventy-Eight Dollars and Nineteen Cents ($4,978.19) as appears by Plaintiffs Statement of Account hereto attached, marked as Exhibit "Ell and made a part hereof. 14. Due to Defendant's default in payment of said amount due and owing as aforesaid, interest and late charges have been added to said account in the total amount of Two Hundred Seventy-Four Dollars and Forty-Three Cents ($274.43) [IS sho\vn on said Exhibit liE", 15. Due to the default of Defendant, and pursuant to the terms and conditions of the Loanliner Agreement, attorncy's fees in the total amount of One Thousand, Thirty-Five Dollars and Six Cents ($1.035.06) have been added to said :lCCOlll1t as shown on said Exhibit "E", F:\I J'S!:l(\STACY\( '( 'I' ('OM PI .^INTS\ WORK\svcu3] 221\[ L/&I r .\vpd:2HFcb05 4 16. Plaintiffhas frequently demanded payment li'om Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof. WHEREfORE, Plaintiff brings this suit to recover ti-om Defendant: (A) Count I - The StUll of fiVE THOUSAND. ONE HUNDRED NINETY-ONE DOLLARS AND FOUR CENTS ($5,191.074), along with interest thereon from March 1,2005; and (B) Count II, The sum of SIX THOUSAND, TWO HUNDRED EIGHTY-SEVEN DOLLARS AND SIXTY- EIGHT CENTS ($6,287.68), together with interest thereon ti-om March 1.2005; tilr a Judgment in favor of Plaintilf and against Defendant in the amount of ELEVEN THOUSAND, FOUR HUNDRED SEVENTY-EIGHT DOLLARS AND SEVENTY-TWO CENTS ($11 A78. 72). Respectfully submitted, ~~.c Robert D. Kodak 407 North front Street Post Office Box # 11848 Harrisburg. I' A 17108- 1848 (717) 238-7151 Attorney ID No. 18041 Attorney li1r Plaintiff F:\1 JSj.:R\.STA( 'V\{ '( '/' ('OMPIAINTS\ \V()R~\svcu3122R[ .L1&JI.wpd:2XFcb05 _ _. .......n..~ VALL.EY ,~~ ~._~ ,ORAL CREDIT UNION 1213.Slate Hill Road . Camp Hill. PA 17011 717 737-4152 A table that inctudes the APRs and other required cost disclosures lor credit card applications is on the reverse side of this application. lim~uested iJIiif!!!I $ ',CC ~ CREDIT CARD APPLlCATIOI o Individual Credit: You must complete the Applicant section about yourself and the Other section about your spouse if: (1) you live in or the property pledged as collateral is located in a community property state (AK. AZ. CA, 10, LA, NM. NV. TX. WA. WI) (2) your spouse Will use the account, or.. . (3) you are relying on your spouse's income as a basIs for repayment. If you are relYIng on income from alimony. child support, or separate mamtenance, I complete the Other section to the extent possible about the person on whose payments you are reiYlng. OJoint Credit: It you are applying With another person. complete the Applicant and Other sections. . YEARS AT THIS ADDRESS i'.z... INrE~E:ST RATE Divorced-Widowed) om<> lY'i,.jY>/j/( CN/pi? ! Cri"/I_"'1<"- A v."; ("J~~~ NOTICE: AUMONy, CHILD SUPPORT, OR SEPARATE MAiNTENANCE INCOME NEED NOT BE REVEALEO IF D NOT CH 5E TO HAVE IT CON$ID R 0. EMPLOYMENT INCOME OTHER INC9ME S J~I J-II-~ PER S "":l.4: PER o N.ET 0 GROSS SOURCE sit Aecbunt Name & Account Number ACCOUNT NUMBE.R DRIVER'S LICENSE NUMSEA f STATE BIRTH OATE WORK PHONE! EXT. HOME PHONE E.MAlL ADDAESS PRESENT ADDRESS {$\'E!el . CJry - State - lip) DOWN 0 RENT ~6~~i~ THIS MORTGAGE/REfill OWED TO' % MOR'TGIIGE BALANCE MC"'THLY RAYMENT , , COMPLETE FOR JOINT CREDIt SECURED CREDIT OR IFYOU LlVe IN A COMMUNITY PROPERTY STATE; o MARRIED 0 SEPARATED 0 UNMARRIED (Sir'lgre. Oivorc~ . Widow~d) Em mentt1ncome NAME AND ADDRESS OF EMPLOYER . STAAT DATE <" INTCREST Af.TE POSITION NOTICE: AUMONY. CHtLD SUPPORT. OR SEPARATE MAINTENANCE INCOME NEED NOT Be REVEALED IF U 0 T CH OS TO HAVE IT CONSIDERED EMPLOYMENT INCOME OTHER INCOME S___PER S __PEA _____~__ o NET 0 GROSS SOURCE SAVINGS CHECKING OUler Information AboutYou $ $ CREDITOR CREDITOR Creditor Name 5: Account Number MONTHLY PAYMENT $ $ VALUE BALANCE $ $ IFYOU ANSWER "YES"TO ANY QUESTION OTHEATHAN ~1, EXPLAIN ON AN ATTACHED SHEET. APPUCANT OTHER YES NO yES NO ,. ARE YOU A U,$. CITIZEN OR Pl!AMANENT RESIOl!NT AllEN? 2. 00 \(()IJ CURRENTlY HAVE ANY OUTSTANDING JUDGMENTS OR HAVE 'IOU EVER FILED FOR BANKRUPTCY.. HAD A DEBT ADJUSTMENT P.LAN CONfiRMED UNDER CHAPTER 13. HAD PROPERTY FORECLOSED UPON OR REPOSSESSED IN THE LAST 7 YEARS. OR BEEN A PARTY IN A LAWSUIT? 3. ARE YOU A CO.MAKER. CO-SIONEA OR GUARANTOR ON ANY lOAN NOT USTEO ABOVE? FOR WHOM {Name ot orners Obh'i}:III&d on Loan~; "TO WHOM {Name ot Creditor}: Personal Reference RELATIONSHIP: NAME AND ADDRESS OF NEAREST RElATIVE NOT LIVING WITH YOU; State Law.Notices OHIO RESIDENTS ONLY: The Ohio laws against discrimination. require that all craditors make credit equally available to- aU creditwortt'ry customers, and that credit reporting agenci~ maintain separate credit histories en each individual upon request. The Ohio Civil Rights Commission administers compliance with this law. WISCONSIN RESIDENTS ONLY: (1) No provision 01 any mantal property agreement, unilateral statement under Section 766.59, af court decree under Section 766.70 will adversely affect the rights at the Credit Union unless tha Credit Union is furnished a copy HOME PHONE: of the agreetttent. statemen.t or det:ree, or has actual knowledge 01 its terms, before the credills granted or Ihe account is opened. (2) Please sign if you are not applying lor this account or loan with your spouse. The credit being app(~ lor, if granted, will be incurred in the iotefesl 01 the marriage or family of the undersigned. IX SIGNATURE FOA WISCONStN RESIOENTS ONLY DATE Signatures You promise that everything you have stated in this appllcation is correct to the best of your knowiedga. It there are any important changes you will notify us in writing immediately. You authorize the Credit Union to obtain credit raports in connection with this application for credit and for any update, increase. renewal, extension, or collection of the credil received. You unders1and that the Credit Union will rely on the informalion in this application and your credit report to make Its decision. If you request, e Credit Union wtll tell you the name and address of any credit bureau trom . it received a credit rep rt on you. It is a federal crime to willfully and delib y provide incomplel r incorrect information on loan application d.~ federal credit unions or, te chartered credit unions insured X AP F CREDIT UNION USE ONLY SEAL DATE ~ NO.OF~-L.0~~..~.Y CRrotT~oRlOl\NOf'l'lOER'~E ANT'S SIGNA: AE ~ o DECUNal lOCVNAMUTUAlGROUP,I99S,2001..AllR\GHTSIlESERI/fO TOOAOER',QOO-J56.5012 by NCUA. You understand 1hat the use of your card will constitute acknowledgment of receipt and agreemenl to the terms 01 the credit card a.greement A condition of your accoun1: is your granting us .. security interest in your share accounts. By signing below you grant us a seaurity interest in all individual and joint share anc1for deposit accounts you have with us now and in the future to secure your credit card account. Shares and deposits In an Individual Retirement Account and any other account that would lose special tax treatment under state or federal law If given as security are not subject to this security interest. When you are In default W9 may apply the balance in these accounts to any amounts due under the credit card agreem.ent. ~ X~sEAlll OTHER SIGNATURE DATE " '''''''""'''''-- (} ,r<.' . ... DETACH AND RETURN THIS APPLICATION TO YOUR CREDIT UNION ACAV205101 283 t Qcvc FEB-28-2005 10:21 SUSQ, VAL, Feu 7174412022 P.01/01 SUSQUEHANNA ~ ~ VALLEY FEDERAL CREDIT UNION ( Statement of Account Date: February 28, 2005 Maker: John E, Minich Co maker: None Home Address: 4334 Enola Road Newville PAl 725 I r Home Phone Number: 717-776-6023 Our Account Number: 11083-10 Your File # 31228 Maker Social Security # 185-38- I 983 Co maker Social Security: # Principal Amount Owed Interest Owed Penalty (20 % of Principal& Interest) Late Payment Fee: Total Amount Claimed: ~ @ $4,226.78 $88.03 $856,23 $20,00 $5,191.04 3850 HARTZDALE DRNE . CAMP HILL, PA 17011-7809 LOCAL: (717) 737-4152 TOLL FREE: (BOO) 948-1454 FAX: (717) 737-0589 @ ~",:~ ~~f1: .,_ '. '-'_,i ~~;~~~j ,..1lI,..".::.."'....,,-~ ~~~fr~'~:;,I:~ , ft. SUSQUEHANNA VALLEY FEDERALCREDITUNlON 385Q Hart.dale Drive . Camp Hill, PA 17QU.7809 (717) 737-4152 = CLASSIC VISA CREDlT CARD AGREEMENT In thisAgreement the words "'you. and "'your" mean each and all of those who egree to be bound by thisAgreement;"Card" means the VISAcredit card and any duplicates. renewals, or substitutions the Credit Union issues to you; .Aceoun~ means your VlSAc:ndit card line of credit account with th. Credit Union, and "Credit UZlion- means the Credit Union whose name appears on this Agreement or anyone to whom the Credit Union _era thisAgreement. i UMnflYntn"A(!(!()uut. Ifyou'areapprovedfor anAccount;. the Cndit Union will establish a Une of credit for you and notify you of your creditliD>it. You agree that yourc:redit limit is the meximam emount (p\U'Chases. cash advances, finance c:harges, plus .other c:harRes,,) that you will have outstanding onyour Account at any time. It you are over your credit limit--you must pay the amount you are over before payments will begin to restore your credit limit. You may request an increase in your credit limit only by a method acceptable to the Credit Union. The Credit Union has the right to reduce your credit limit. refuse to make an advance and/or terminate your Account at any time for-any reason not prohibited by law. Usin?Ynnr Ca.rd.. You mayuseyourCard to make purchases from merchaD.ts and others who accept VISA Cards. However, you :may not use your Card to initiate any type of gambling transaction. In addition.- YOU:Ql.ay obtain cash advances from. the Credit Union and from other :financial institutions that acct!~t VISACards. and from. 8Omeautom:ated teller maehines(ATMs). (NotallATM.s ac:ceptVlSA Cards.) 'Th obtain cash advances from an ATM. you must use the Personal Identification Number (PIN) that is issued to you for use with your Card. You a~ that you will not use your Card for any traDsactlou that is illegal under applicable federal, state or local law. . . Rem1Onltihilitv. You agree to pay aU charges (pun::hasee and cash advances) to your AJ:count that are made by you or anyone whom you authorize to use your Account. You also agree to pay all finance ~ and other char~ added to your Account UDder the terms of this Agreement or another agreement you made with the Credit Union. If this is a joint Account,. Section 17 below also applies to your Account. 4. Finance Cltal"l"P.l'lo New purchases posted to your account dUring a billing cycle will not inew: a finance charge for that billing cycle if you had a zero or credit balance at the beginning of that billing cycle or you paid the entire New Balance on the previous cycle's billing statement by the Payment Due Date of that statement; otherwise a 6nance cha~ will accrue from the date a purchase is posted to your accoUXlt. Th avoid an additional finance charge on the balance of purchases , you must pay the entire New Ba1an~ on the billing statement by the Payment Due Date of that statexn.ent. A finance chaIie begins to aeaue on cash advances from the date you get the cash advance or from the first day of the billing cycle in which thecash advance is po.sted.to yow.' account, whichever is later. 1. 2. 3, The finance charge: is calculated separately Cor ptirchase$ and cash adv-. Forpuiclreses, thelioenatcharov acomputed by~~~ the monthly periodic rate t()the average cfaily balance ofp To get the average daily bal. ance of purchases , we take the beginning outstanding balance ofpurcl1ases each day; add any new purchases" and subtract 8.l3.y paymenta and/or credits. This gives us the daily balance of purchases. Then, we add all the daily balances of purchases for the billing cycle together and divide the total by the uumber of clays in the billing cycle. This gives us the average daily balance 0{ plU'cl1ases. . For cash advances, the finance charge is computed by applying the monthly periodic rate to the average daily balance of cash advances. To $et the average daily balance of cash advances, we take the beginninr outstanding balance of cash advances each day, add in any new cash advan~ and subtract. any payments andfor credits that we apply to the eash advance balance. This gives us the daily balance of Cash advances. Then, we add all the daily balances of cash advances for the b\lli>!l! ~ together and divide the total by tha number of days in the billing cycle. This gives us the average daily balance of' cash advaDces. . Th. monthly periodic rate for plll"Chases is 1.075K. which is an ANNUAL PERCENTAGE RATE of 12.9%. Tbe monthly periodic rate for cash advances is 1.0750%, which is an ANNUAL PERCENTAGE RATE of12.9%. 5. Other Chal'2"M The following other charges (fees) will be added to your Account, as applicable: a. Late Payment Fee: If you are ten (1Q) or more days late in making a payment, a late charge of SO.DO mll be added to your account. b. Returu Check Fee: If a::heck or sbare drafl; used to meke. payment on your aexount is returned UIlpaid.. you will be i:bernd a fee of$'J,5,QQ for each item returned. c. Card Replacemeut Fee: We re:seml tho right to charov $5,00 for eoch lIdditional repJacemeut card if more than tIiree (3) cards are requested within one year. Additiol1al fees may be incurred if other than standard deliveryofthe card is requested. d.. Documeut Copy Fee: We reserve the right to charge $5.00 for reqU8$ted sales draft copies ifnot aAOciated with a billing error or fraudulent charges. . e. Collection Costs: You agree to pay all costs of collecting the amount you owe under this Agreement, including court costs and reasonable attorney's fees. f. C8l"d Capture Fee: $65.00. g. Emergency Limit: You may be charged $5.00 for each emergenqolimit increase requested ifmore than three (3) are requested per year. ; 6. Pavntenbf Each month YOU. must pay at least the arlnimum payment shown on your statement by the date ~ on the statement or no later than twenty.tive (25) days from the statement closing date, whichever is later. IfyOUT statement says the payment is '"Now Due,. your payment is due no later than twentSfive (25) days from the statement closing date. You may ~y IDore uently, pAl mOA than the minimwn paymentorpay the TotalNew alam:e m full. ICyou make extraor larger payments, you are still required to make at least the minimum ~yment each month your Account bas a beIeuce (other than. credit beIeuce), Tbe minimum paymeot is- 49& of your Total New Balance, or $20.00, whichever is greater. I2luI the amount of any prior minimum. payments that you have not made, and any amount you are over your credit limit. The Credit Union also has the right to demand immediate payment of any amount by which yocz are over your credit limit. Pavn1ent AllbclItibn. Subject to applicable law, your payments may be applied to what you owe the Credit Union in ant': manner .the Credit Union chooses. We may accept checks marked payment in full. or with words of similar effect without losing any of our rights to collect the full balance of your a~unt with us. Security Interest. If you give the Credit Union a specific pledge of $hares by signing a separate pledgeofshares,yoUJ:' pledged shares will secure your Account. You may not withdraw amounts that have been specifically pledged to secure your kount until the credit union agrees to release all orpartofthe pledged amount. In addition, your Account is.secund by all other-shares ,you have in,any'~ndiYidual or joint account with the Credit Union, except for shares in an Individual Retirement Account or in any other account that would lose special tax treatment under state or federal law if given as security.. These other shares ~y be withdrawn w:lless you are in deCault under this agreement. You authorize the Credit Union to apply the balance in your individual or joint share accounts to pay any amounts due on your Account if you should default._ CoHateral sewring other loans you have with the Credit Union may also secure this Joan, except that a dweUingwill never be considered as securit.y for this Account., notwithstanding anything to the con~ry in any other agreement. ~ You will be in default if you fail to make any minimUlIl payment or ather required payment by the date that it is due. Yo.tl will be in default if you break any promise you make under thil Agreement. You will he in default if you die, file for bankruptcy OJ become iusolvent, that is, unable to pay your obliga,tions when the) _me due. You willbein defiwlt ifyoun1ake any false or misleodioi statements in any credit application or credit update. You will alSl be in default if something hap~ns that the Credit Union believe may substantially reduce your ability to repay what you owe. 7. 8. 9. When you a.nt in default,. the Credit Union has the right to demanl immediate payment of your fullAccount balance without giving)'Ol notice. If immediate payment is demanded. you agree to continu paying nnance charges, at the periodic rate charged before defaull until what you owe has been paid, and any shares that were give as security for your Account may be applied towards what you Q\Vl CONTINUED ON REVERSE SIDE o CUNA Mulu8II GA:Iup. 1991. 2Clln 10. "Liability for Unauthorized Use-LostJStolen Card Notification. You agree to notify us immediately, orally or in writing at 3350 Hartzdale Drive, Camp Hill, PAI7011.7809 or telephone (717) 737-4152 Monday through Friday 9:00 am - 5:30 pm, (8001 433-0505 Monday through Friday 8:00 am - 6:00 pm or (800) 991-4961 twenty four (24) hours a day, seven (7) days a week, of the loss, theft. or unauthorized use or your Credit Card. You may be liable for the unauthorized use of your Credit Card. You will not be liable for unauthorized use that OCCUl'S after you notify us of the loss, theft:. or possible unauthorized use. You will have no liability for unauthorized purchases made with yourcredit card, unless you are grossly negligent in the handling of your card. In any case, your liability will not exceed $50. 11. Changinsr or TerminatingYour Account. The Credit Union may change the terms of this Agreement from time to time. Notice of any change will be given in accordance with applicable law. Ifpermitted by law and specified in the notice tq you, the change will apply to your existing Account balance as well as to future transactions. Either you or the Credit Union may terminate this Agreement at anytime, but termination by you or the Credit Uuiou will uot affect yourob1igation to paytheAocoant.belance plus any finance and other charges.you owe under'tlrlsAgreement. You are also responsible for all transactions made to your .Account after termination. unless the transactions were unauthorized. The Card or Cards you receive remain the property of the Credit Union and you must recover and smrender to. the Credit Union all Cards upon request or upon termination ofthisAgreernent whether by you or the Credit Union. The Credit Union has the right to require you to pay your full Account balance at any time after JOur Account is terminated, whether it is terminated by you or the Credit Union. Ifthis is ajointAccount. Section 17 of this Agreement also applies to termination of the Account. 12. Credit Information. You authorize the Credit Union to investigate your credit standing when opening or reviewing your Account. You authorize the Credit Union to disclose information regarding your ACcount to credit bureaus and creditors who inquire about your credit standing; . . . Return..~ and Adtustments. Merchants and others who honor your Card may give credit for returns or adjustments, and they will do so by seading the Credit Union a credit slip which will be posted to your Account. Ifyourcreditsand payments exceed what you owe the Credit Union, the amount will be applied against future purchases and cash advances. If the credit balance amount is $1 or more, it will be refunded upon your written requestor automatically after six (6) months. Additional Benefit.<>ICard Enhancement.c; The Credit Union may from time to time offer additional services to your Account, such as travel accident insurance, at no additional cost to you. You understand that the Credit Union is not obligated to offer such services and may withdraw or change them at any time. Foreim Transactions. Purchases and cash withdrawals made in foreign countries and fo:reign currencies will be debited from your account in U.S. dollars. The conversion rate to dollars will be determined in accordance with the operating regulations established by VISA International. Currently the currency conversion rate used to deternllpe the transaction amount in U.S. dollars is g~neralIy either a government-mandated rate or the wholesale ratein effect the day before the transaction processing date, increased by one percentage point. The currency conversion rate used on the. processing date may differ from the rate that would have been used OfJ the purchase date or cardholder statement posting date. Merchant Disnute..<:;;. The Credit Union is not responsible for the refusal of any merchant or liuandalinstitution to honor your Card. The Credit Union is subject to claims and defenses (other than tort claims) arising out ofgoods orservicesyoupurchase'with the Card if you have made a good faith attempt but have been unable to obtain satisfaction from the merchant .or service provider, and (a) l'~ur purchase was made in response to ap. advertisement the Credit Union sent or participated in sending to you; or (b) your purchase cost more than $50 and was made in your state or within one hundred (100) miles of your home. JointAeconnts. If this is ajointAccount, each person on the Account must sign theARreement (by signing on the application). Each of you will be individually and jointly responsible for paying all amounts owed under this Agreement. This means that the Credit Union can require anyone ,of you individually to repay the entire amount owed under tbisA2reement. Each olyou authorizes theother(s}to make purchases or cash advances individually.. ,Any ODe of you may terminate the Aocoant and the termination will be effective as to all of you. Effect of AD'reenJent. ThisAgreement is the contract which applies to all transactions on your Account even though the sales, cash advances, credit or other slips you. sign or receive may contain different terms. 19. No Waive':. The Credit Union can delay enforcing any of its rights any number of times without losing them. 13. 14. 15. 16. 17; 18. r Statemenb and Notices. Statements and notices will be to you at the most recent address you have given the Credit Notice sent to anyone of you will be considered notice to al Final Exnression. This Agreement is. the final expressiOi terms and conditions of this VISA line of credit between you Credit Union. This written Agreement may not be contradi evidence of any alleged oral agreement.. 22. CODV Received. You acknowledge that you have received a this Agreement. 20. 21. 23. Sismatures. By signing in the Signature area of the app form that was attached to this Agreement when you receive< agree to the terms of this Agreement. YDU should deta Agreement from the application and retain it for your recor YOUR BILLING RIGHTS KEEPTBIS NOTICE FORFUTUllE USE This notice contains important information about your rights I: respollSibilities under the Fair Credit BillingAct. Notify Us In Case oCErron or Questions About Your Bill If you think your bill is wrong, or if you need more information I transaction on your bill~ write us on a separate sheet at the addres on your bill Write to US as soon as possible. We must hear from later than sixty (60) days after we sent you the first bill on wh error or problem appeared. You can telephone us~ but doing so '; 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 thel error. If you need more informatio~ describe the item you are 01 ahout. If you have authorized us to pay your credit card bill automaticall your savings or share draft account, you can stop the payment I amount you think is wrong. To stop the payment your letter must rE three (3) business days before the automatic payment is scheduled t< Your Rights and Our Responsibilities Mter We Receive Written Notice .. '.,' . We must acknowledge your letter within thirty (30) days, unless w corrected the error by then. Within ninety (90) days, we must correct the error or explain why we believe the bill was correct. After we receive your letter, we cannot try to collect any smOUl question, or report you as delinquent. We can continue to bill you J amoup.t you questio;n, including fi.n~c~ charges. and we can apl unpald amount against your credlt'hm.lt. You do not have to~. questioned amOQDt while we are investigating, but you are still obI: to pay the parts of your bill that are not inques~oD. Ifwe find that we made a mistake on your bill, you will not have to ~ finance. charges related to any questioned amount. If .we didn't n; mistalte, you may have to pay..finance charges". and you will have to up any missedpayments on the questioned amount. In either case ~ sendy-ou astatemeot oIthe amount you owe and the date that it is: If you fail to pay the amount that we think you owe, we may report ~ delinquent.. However, if our explanation does not satisfy you aD: write l!>u.s within ten (10) days telling us that you still refuse to P' must tell anyone we report you to that you have a question about bill. And, we must tell you the name of anyone we repOrted you U must t~ll anyone we report you to that the matter has been & between us when it finally is. If we don't follow these rules, we can't collect the first $50 of the quest amount, even if your bill was correct. . Special Rule Cor Credit Card Purchases If you have a problem with the quality of property, or services tha purchased with a credit card, and you have tned in goodJaith to co the problem with the merchant, you may have the right oot to pa remaining amount. due on the property or services. There are tvi limitations on this right: (8) Youmustha-ve made the purchase in your home state or, unot w your home state. withiu one hundred (100) '!'ileaofyourcurreut m. address; and. (b). The purchase price must have Peen: more than $50 . These limitations do not apply if we .own or operate' the merchant we mailed you the advertisement for the property or services. ' 0~: SUSQUEHANNA VALLEY ~, FEDERAL CREDIT UNION . 3850 HArl7dale Drive V-......,....... CampHllI,PA 17011-7809 "--/ (717) 737-4152 iLQ4;HUNER Open-End Voucher and Security Agreemen L__ __________.BQJlf!QWE1LlrlEQBM~IIQN. fIf)nnnWfR 1 NIIMr John E. Minich 11083-5 ~ 2,848.60 !,An Q6/23120' M.rfjllrlrll'!Ml'\rrl' "'..~( II NT ~H; H IF:"' II r> 1\1)~fI(IWr'1 I I\IJ[lf{(~.S 4334 Enoln RMd Newville, PA 17241 \1(,'-'1' IHf,Hlllif tJIlMBf.H { 117)-776-6023 ,,(}<.11\\ SfC.V111T" t~UMAI_R 185-38-1983 "IJ~lr'(I:'.;~, Consol idat ion HflrmOWFR :z NM}I[ ^CtOllr~T NU'AR~R Dl:YOf,ll CIIE(:~: IN ACCOUNT NUMRH1/(lltir-11 RORR()WER "1 ALJDnESS SOCIAl 5ECURJ1Y NUMBER CHECK PA~AaLE:. TO: Fll:rl\YMlNT MEllton: Cash BORROWER 1 EMI'LOY(n NAMt" Messiah College BORROWER 2 EMPLOYER NAME Wlm, '~II'l'HOIJr Nl IMF:flt l'Alr I'IRo.1 GR(lS~ N'fltjflll> ':,~l ^-'I' 02/1 Sly!!!~.__~~_~~.?~~,..__ wonK TILErI-lf1Nf: tJl!MH(I1 p...rE IIl1ln\ l:;nfJ:,s "lnN' 111' '\1 _~_p. NOTlCE- vnll Ilflwr HAVE TO INCH/Of INCOMf. FROM CHili) SlJ1'POlH. SH'A1l^fF MAINT(N~Nr.[. OR AllMotJY \JNlESF. WIU WAr,H THE cm-DlT I!NlON rocnNSll,IEn If '5()(-,A~1' nF lllHFfI INn''''F I)THf.Jl MflNlllI' lH("".41 r- WHA T YOU OWE UST Al.L DEBI 5 OTHE:A THJ\N TO 0-115 C~EOI1 UN!()N lAIl"r.h ~lrliljo"l'Il ~I~I{~I j'I"":"~_\l_\ r'RtSENT BAl ^NC~ MOI./IHI.\ f'^,MH->l1 f I jI'II,-t,11 I'll rHl -, 1 ~i' SVFCU VISA PHH FLEET 330.00 51,100.00 11,700 _ 00 160.00 486.00 63.00 SUBSEQUENT ELECTION FOR VOLUNTARY PAYMENT PROTECTION You con nflW voluntarily elect to her-orne insurnd with rhl'! c()vl!m!lf'!ls~ shown hHlow. In orrlm for r:ovl~m!1e In hf'!COOle rdfe-\':tivI1 you mll"t ,mwl ft insurnnCH eligibility requirements stated in thl~ Cmdil Insllranr.t~ Application/Schedule. NOTE: The insurance you're applying for contains cp.rtn;, terms and exclusions; Refer to your certificate for coverage details. It you need a copy of ,he Insurftnce Cflrliticate. just ask. By si111linH belli'" you authori,w us to adel the charges for the insurance In your outslanding balance each month. Covcr-mJo n'p.c';on applies 10 the nnlilt' IHlhulO! mllhi subaccount. InSlInmce rates are suhject to change. 'l'OlJHf(f 1~11' FOI!11WIN(; r.n<;II'H\ '1110 OF Vnl!R MI'I,JI'll' 1(I/lN II/ll-".'/\.[ NI\MF nF IfJ::;IIR!,OrS\ NO Single Credit DistlbHity NO NO Single Credit Lif~ NO Joint Credi t life SEE SEPARATE RATE SCHEDULE .070 .123 REPA YMENT TFRMS .- >- DAllY t'fRIOl'W riA rr ANNUAL PERCENT AGE RATE lNTERrsr AArEIS OtHER 'FfS fA''''ltll>l m.I !)".~,-""o;''''1 NHV 11AI MWI llll';,.IU;l\rr;)\1 -' ~03;?O~5% % 11 .70000 " Fixed ' MIA , 7,298.79 Z 0 - MOUNT ADVANCED I'AYMfNT AMOUNT uP.n DUE ~AYMENrFRlOUENCY lfflCQFCR(lJtrVfI.'lr .FlFMAI1l,11NG liMn uJ :; 2,848.60 !ll00.DO 07/24/2003 Bi-weekly . , <Il ::l YClur term will be approximately 90 payments, which may be more or less, dependi ng on whether you prepoy, have Z tate payments.. or insurance is added,: etc. 0 ! Z ::l SECURITY OF"'ER"D IXI CONSUMERS' CLAIMS AND DEFENS"S --IF CHECKED SEE' PARAGRAPI-I 6 FOI3NQIIC ~ THE ArvANCE IS SECIJArD BY YOUR ::;HAflES. All PnQPEfln SECURING OTHER PLAN ^OV^NC~S AND I.OANS RECE1Vl::O IN THF. PASf OR IN THE. HJ1UFlr. ANll fH~ Foum",IW. C I'AOPERT'f/MonF.:L .YEAR 1.0. NUMBER V,\LUE ~.T\ NUMt uJ Signature , 0: 0000 () , 0: , 0 , u.. rlE[lfiE ()F SHAms "'("COUNt Pt,WGE OF SHMFS Ar:r.oum ANOIOR DEPOSITS . NUMBER ANO:OR DEPOS.fS , tMMAER SIGNATURES By signing hl!low, by endo"mg t.... procelHfs check or by It!'ling thll I'Imount ad\/anc~d JIlnd deposited into your !'IhJlt"I~ha"'t drl'tH IIr.count you 1'19rl'l": 1. To m"ke "nd be b d by the terms of Ihi, Security Agrllement MICludklg the cross co"aterat clause; 2, The aboye intor tOn i. true and correct and the Credit Union will rely 00 thai information and your crlldi1 report to lIlaklt A credit decisirm: 3. T mek. paym 85 disclosed .boy . accordance with the terms of yO\lr Plan. ..f / 15t'ALI PAH 1~,1 foil R I ~1r,NMlIRf OAT't;. 1)1 rSF-Al) l~~~, AI \ (IWNFR OF r:Olt^fFf'lAI lOlh.., Ihilll" R''''',wNI 0" '" ~ r.\lNJ\ MI!1ljt,1 (,ROUP. 1''1110. BJ, 8,1. Rfi_ R:l. <)A. !Vl. lOO(l. 02 I\U RIGH1S nfSHl'IE'O 'Ixxnfi', Ii SU$qul'ha'lfic.l Valley Feder;:!l Credit Union Date 06/23/200: John E. MinIch SECURITY AGREEMENT III thIs agrt:elllt':llt ~lIleferences to "~I~dit uniull," "we," "Olll," UI "us" mean the credit union whose name appears on this agreement and ctllyon~ to whom the credit union assigns or transfers this agreement. All leferellces to "you," "your," and "borrower" mean each pl:fSOIl who siUns this agreement. All references to "the t1dVilft(:t/' 1l'~~lIi the i.trllOUllt ill the box labeled "Amount Advanced" Oil JJuye Olll~ All refereflcHS to "tht: Plan" mean the Credit Agreellhlllt under which the arlvance was obtained_ Some of the p.ovision~ of tills aureHfTlent apply ullly if the Credit Union is state chartored. A credit ullion has a state charter if its name does not include th~ words "Federal Credit Union" or '"FeU". This IS a fTlulti-srate dOCllIllent which may be used to lend to borrowers in all states tlxct::pr Louisiana and Wiscon$in 1. H-tE Si::CUfUlY FOR THE PLAN n By :>iynillY [his s~curity i1{JIf:ellhHlI ill tile ::.;iUIl~HlIre area or under the statement referring to Ihis au,eeflltmT which is on the back of the check you receive for Ihe adVdllt~I:. you Uivt~ LIS what is known as a security interest in the prnpt~rty described in the "Security Offered" section on page one. The '~m;U1itv interest you give includes all accessions. Acces~:ioll~ we thillgs whicll are attat:hed to or installed in tt1e propeny IlfJ\I'II or in The future. The security interest also includes any rupl<:Il.;UlIltHlts for the property whidl YOll buy within 10 days of the advl:lllce or any exten:>ions, renewals or refinancings of the advance. It also includes any money you receive from selling the property or froln insurance you have on the property. If the value of the properly declines. you promise to give us more property as security it asked to do so. 2. WHAT THE SECURITY INTEREST COVERS -- The security interest secures the advance and any extensions, renewals or refinancings of the advance. It also secures any other advances YOll have !lOW or reellivo in the future under the Plan and any other amoullls Of 100l1"lS, including any credit card loan, you owe us for (my redsun now or in the future, except any loan ~ecured by your pliflcipal H:tsidence. If the property is household gOf)ds as defined hy the Federal Trade COlllmission Cledit Practices Rule, the properry will sm;ure unly the advance 0111(1 not oIlier alllOUlHs you lJIIVP. J. OWNERSHIP OF THE PROPERTY -- You promise that you own the properly yuu give as security or if the Advance is to buy the properry, you pfondse you will use the Advance for that purpose. VOll promise that no one else has any interest in or claim against the ,.lIuperly that you have nor aheady told us about. You promise flot ro ~tlll ur Itwse the property or to use it as security for a loan with allort,t:'( eledirnr until the advance is repaid. You promise you will allow no other st}eurity inlt:rest or lien.to attach to the property either by YOllr lIctions or by operation of law. 4. PROTECTING THE SECURITY INTEREST -- II your state issues a title fllr lilt: property, you promise to have our security interest ~lln\I'Vn UIl lilt: Ilrll;~ W~-: may have to file what is called a financing ~ti.llCllli.:llt l/) IJruH:L.:t uur security interest ;from the claims of OHldl~. If il~kt:d tll do su, you promise to sign a financing ~t~1tellll~11I YOla crlso prolllise to do whatever else we think is f1l::(;e$~i1ly 10 fllOtt-:ct our seclIrity ifltefe~t in the property. You pfollli~d tu pay all t;osts, illcluding but not limited to any attorney fe~s, we illClIf in protecting our security intetest and rights in the property, to thtl extent permitted by applicable law. 5. USE OF PROPERTY -- Until the advance has been paid off, you promise yO\.1 will: (1) Use the property carefully and keep it in good repair. (2) Oblaill ollr written permission before making major chi;tnge~ tu the pfOperty Of changing the address where the property is kept. l3) Inform us in writing before changing your address. (4) Allow us to inspect the property. (5) Promptly notify us if the pwp.arty is damaged, stolen or abused. (6) Not use the propeny tOl any unlawful purpose. 6. CONSUMERS' CLAIMS ANO DEFENSES NOTICE The fullow",,!) puragruph dPfJlit:~ unly wlwl1 tlrt! box un puye unt! is cht!cJ..e<l. !l.Qo.HlIiNf1 ~- --- .' - - - NOTICE: ANY HOLDER OF THIS CONSUMER CRE CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFEN! WHICH THE DEBTOR COULD ASSERT AGAINST 1 SELLER OF GOODS OR SERVICES OBTAINED PURSUA HERETO OR WITH THE PROCEEDS HEREOF. RECOVE HEREUNDER BY THE DEBTOR SHALL NOT EXCE AMOUNTS PAID BY THE DEBTOR HEREUNDER. 7. PROPERTY INSURANCE. TAXES AND FEES n You m maintain proJ)erty insurance 011 all property that you give security under t"li Plan. YOll rnay purchase the property insura from anyone you choose who is acceptable to the Credit Uni The amount and coverage of the property insurance must acceptable to us. You fllay provide the property illSUri.iIlCe throl a policy you already have, or through a policy you get and pay You promise to make the insurance policy payable to us and 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 .righl the refund. If th~ property is lost or damaged, we can use insurance settlement to repair the property or apply it towa what you owe. You authorize U~ to endorse any draft or ch which may be payable to you in order for us to collect any ref I or benefits due under your insurance policy. You also promise pay all taxes and fees (like registration feesl due on the prope.t~ If you do not pay the taxes or fees on the property when dUE keep it insured. we may pay these obligations. but we are required to do so. Any money we spend for taxes. fees insurance will be added to the unpaid balance of the advance i you will pay inturest on those amounts at the same rate 1 agreed to pay on the advance. We may .eceive payments connection with the insurance froll) a company which provides insurance. We may monitor our loans for the purpose determining whether you and other borrowers have complied V1 the insurance requirements ot our loan aureements or llIay enU' others 10 do so. Tile insurance dwrye adutHJ to tile advance fl illduue (11 the insurance cOfllpilny's paymenls to us ami (2) cost 01 determining compliance with the insuldllce rtlquirellHmt~ we add amounts for taxes. lees Of insurance Iu the unpaid balal of the advance. we may increase your payments to pay amount added within the term of the insurance or (Ipproxim term of the advance. 8. NOTICE -- If you do not purchase the required proptl insurance, the insuHlnce we may purchase and charge you tor \ cover only our intert:st in the property. The insurance will not liability insurance and will not satisfy any state finanl responsibility or no fault laws. 9. DEFAUlT.- You will be in default if you break any prom you make ulldor this agreelllent. You will also be in default if '1 are in default under the Plan. I f you are pledging property, but hi: not signed the Plan. you will be in default if anyone is in defa who has signed the Plan. 10. WHAT HAPPENS IF YOU ARE IN DEFAULT - ThB follow. paragraph applies to borrowers in Colorado, District of Columb Iowa, Kansas, Maine. Massachusetts, Missouri. Nebraska, W~ Virginia and state chartered credit unions lending to South CarolJ borrowers. When you are in default and after expiration of a right you have under apl>licable state law to cure your default, \ can demand immediate payment of the entire unpaid balance unc the Plan without giving you advance notice. The following paragraph applies to borrowers in all other stat and federaHy chartBrt1d. Cl'8dit unions lending to South Carol; borrowers. When you are in default. we can ret!llire immedis payment (acceleration) 01 the entire unpaid balance under the PIc: You waive any right you have to demand for payment. notice intEmt to accelerate and notice of acceleration. (Continued on flexl pd!J~1 -0 'IN'',;.l'!_i'I.< '.HI"Il. "";" .>::.H~ Ion iI'! 'Hi,'J') .',j(lt!."-' 1111 IW;IIIC..'Il:a-f".'lj, CREDlf UNION CUr'y '."",',"/.1 SUSQI ~h;)nll') Vnl Icy Fed,.,fCiI C,"(yJj t Ullion natc nf>l?~/f'll(1~ ,John E. Mini(h The following paragraphs apply to all borrowers. Ynll ilqrce tllP. Credit Uninfj hits the ri~lht to take pOSSWiSln!l 1)( fh~, property given as seCl.Ility lllldm thp Plilll, withollf illC/ICldl rlfocess. if this can be done without breach of the peace If we ask, YOlJ pFomise to deliver the property at [-f time film place we choose. We will not be responsible for any other property not covered by this agreement that you leave inside the property 01 that IS at ti'lched to thp. property, We will try to retllrn that property to you or make it available to you to claim. After we h:'lvp. possession of lhl~ propmfy, we can $f;/I it and apply the nloney to any amounts you owe us. We will give you notice of any public safe or the date after which Ii privaw sale will be held Our expenses for taking possession of and selling the property will he deducted Irmn the money Iflceived from the sale Thosp- costs may include the cost of storing tht~ property, prepClring i1 for saff! and attofnp.y's fees to the extent permitted under !;tale law 01 awmded under the Bankruptcy Code. The rest of the sille monr,y will be applied to what YOII owe under the Plan. If YOlI havp i'lqH)~rl tn pRy thl:~ Adv;:u)Cf>, ynll will also 11Plvp. to pny ;my Clmollnt that rem~in.<; unpaid rlHer ItlH $illp. Illonny h<ls hElPn ;JppJit?d to thl' llnpnid bal;)nce of the Ad"","c€! ()t)d to what you owe IIndm Ihis ;HJlcflJlWnl You agrpp In P<lY illtf~rnSI Oil tllill ;lI11011nt at 11m Sillne 1;:l1e as the Adv;Jllce, OF, it applicable, at the dHtault rate disclosed on the Addendum, until thM amount hCls been Pilie/. 11. OElA Y IN ~NFORCING RIGHTS AND CHANGFS IN 1 flf PIt We can delav ellfOfGi1l9 any of our rinhls llllth'r II\!': ;-HII!"'lIl<' dny number of times WIthout Insitl(! Ih~ dhility I') r~H'rr:i',f' II 'IU/lIS fillr~l We call r'f1trl1'-~ thi'", ;HPI,.'tlIPl\l .l11.!1!)" iiHlr h"II'; leU"l reprp.S'llltilllve~. 11 we (:IHl!lq(~ the 1('1111<; of IIlI' Phfl. V' aqree that this ilgremnent will contulUf) to pr()U~Cl (IS 12. CONTINUED EFfECTIVENESS n JI allY pFlrl (II 11\1': ,1.itPPnll' is (Ielermineo by ;1 cowt to hf! It!)jllllrnceahln, 1111' p':,1 ',(,fill [Plll;- in effect. 13. NOTICE TO NORTH DAKOTA BORROWERS PUf{CHASING MOTOR V~HICL~ - .THE MOTOR VEHICl ~ IN I HI', fllMI ACTION MAY BE SUB-IFCT TO REPOSSE;SION If If REPOSSESSED ANO SOLD TO SOMEONE u,;r. ANP AI AMOUNTS PUE TO THE SECURED PARTY ARE NOl IH UII/W THA T SALE. YOU MA Y HAVE TO PAY THF DlrFLlH Ner:. 14. NOTICE FOR ARIZONA OWNERS OF PROPFR 1Y It linlawful for you to fail to return a In!)tor vehic(f) th;lf j~ suhie!:t (l security interest. within thllly days 1ftI'! ynu ILl\/" r,'n~IVI nOli..p of def~\Ilt Thn notice \l\Ii/l II.. fllflilf"?d 11) tin' ;jdfh~,,;~~ Yf uave US It is YO\U rP.<;pr-llsihllitv to IIotify liS II '11.tH ~lflrtrft chanqe~; The Ilw~.;rnlUn 'JfHl(JItV tm lJlllnwfrII l;"jIIlP Ir) I"IlIm rnoto~ vehicle i5 one VE'ar;n prisoll ancl/or t'l I ill/: 01 -; 1 ~iC'.fJO(l THE PROP~RTY O~SCRIPTION ON PAG~ ON~ IS PART OF THIS AGREEM~NT_ NOTIC~: SIGN THIS AGR~~M~NT ON PAGF ONE. r--- REOUfSTfO MEMB~R r-'A) S PREMIUM ~Of1 FOR CREDIT UNION USE ONLY RRANr;H NIII'~f1~H ~--- flPPfl()l/flJ UMlrs X 1If'I'HOVftl DfNlfO IAdYNSt> An,,,,, Nllf"'" s"un "rC;~I^ TiIRf 06/23/2003 $ I ('^N ill r lI:E-fI r-I'M~~[f.JTc; (HECK NUMBFR Pl Af.J."UBACCOUNT NO IIl\iF OF r;1'IE'DfI nT/1FR $ $ PROCf:S:,/:IJ BY WSt flTHFR rlf"r-il:;;-tl(\ ;,-i'r!f1i- Pff(,r'f "rill; $ /.6.813600 11f1Tf ----_.~--_.-_..,--- ._-----,...-~_.,.--~-_.- _.__._----_._._-~-- .__._-----------~_.__.__.- --.---,..-.-------.--..----.--- h\IL ';I(;To)/ITI}I1I:; x x 'u l(r!J-\MUllil>II,!!!)I;I' l'Ifl(Jf])fH_f'.{iWl.'lH,'l....)\1(l()!-,), AII111(,IIT':;Hj:,t:fl,jf[) CREDIT UNION COpy "H' . Susquehanna Valle} Federal Credit Union 3850 Hartzdale Dr. Camp Hill, PA 17011-8035 LOANLINEH INTEREST RATES EFFECTIVE MAY I, 2003 UNTIL FURTHER NOTICE ADDENDUM TO LOANLINER CREDIT AGREEMENT AND TRUTH-fN-LENDING DISCLOSURE. This addendum is incorporated hIto and becomes a part of your LOANLINER Credit Agreement. By signing, you,ve~ha~/.a..COPY oft~1ilirdum was given to you. SIGNATUREY!6~// t((!/-- SIGNATURE: .'/. ~.. Y " Loan Subaccount Description Approximate Term Daily Periodic Rate Present Annual Percentage Rate Payment Share Secu red 1 - 24 Months 0.OJ09589 4.00% 25 - 60 Months 0.0116438 4.25% 61 - 96 Months 0.0143836 5.25% Vehicles: Model Years 1999-Present* 1 - 24 Months 0.0108219 3.95% 25 - 60 Months 0.0135616 4,95% 61 - 72 Months 0.0]63014 5,95% 1996-1998** 1 - 36 Months 0.0163014 5.95% 37-48 Months 0.0169863 5.95% Signature! 1 - 36 Months 0.0287671 10.50% Unsecured ;jJ 37- 60 Months 0.0320548 11.70% Lines of Credit: . -- Shared Secured 0,01l6438 4.25% Unsecured 0.0320548 11.70% Other Charges: The amount and due date of your payment will be established at the time of each advance and will be disclosed on the voucher accompanying the advance. Your minimum monthly loan payment will never be less * 1999 Ma:e term 48 mo. * * 1996-1997 Max term 36 mo. Collection Costs: The borrower(s) agree to pay all collection costs, including court costs and attorney's fees as permitted by law. Late Fees: All payments received more than 14 days past their due date will be charged a $20 late fee. NSF Charge: You will be charged a $25 fee if your payment is made with a check drawn on an aCCOUnI with insufficient funds. Filing Fees: If a security interest is taken you will be charged the fee the particular government agency levies to perfect that security interest. . .. LUNA MUTUAL (jIWIJP PFNNSYtV'\'~IA ~1(1NTHLY RFNEWAf11 F CRFDn' DlSABIUry DISCLOSURE RA [FS PER SIOO OF COVERAGE PER MONTH TERM 1 2 3 4 5 6 7 8 9 10 11 12 RATE 13 14 15 16 17 18 19 20 21 22 2J 24 0.2844 0.2966 0.3055 0.2831 0.2672 0.2532 0.2418 0.2323 0.2243 0.2145 0.2069 0.1994 0.1920 0.1870 0.1818 0.1764 0.1709 0.1671 0.1625 0.1588 0.1555 0.1519 0.14&5 0.1455 0.1430 0.1408 0.1378 0.1350 0.1328 0.1307 0.1288 0.1270 0.1248 0.1224 0.1212 0.1191 0.1178 0.1161 O. 1149 0.1134 0.1120 0.11 06 0.1093 0.1084 0.1069 0.1061 0.1047 0.1036 0.1026 0.1019 0.1007 0.0996 0.0990 0.0979 0.0968 0.0%4 0.0953 2.5 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 5& 59 60 TER."I 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 III 112 113 114 115 116 117 118 119 120 RATE - 0.0944 0.0940 0.0931 0.0924 0.0918 0.0912 0.0904 0.0896 0.0894 0.0886 0.0879 0.0874 0.0867 0.0861 0.0856 0.0850 0.0846 0.0840 0.0834 0.0829 0.0825 0.0820 0.0815 0.0811 0.0806 0.0802 0.079& 0.0794 0.0789 0.0787 0.0783 0.0780 0.0774 0.0770 0.0766 0.0764 0.0760 0.0758 0.0753 0.0749 0.0747 0.0744 0.0741 0.0736 0.0733 0.0731 0.0727 0.0725 0.0722 0.0719 0.0718 0.0714 0.0713 0.0710 0.0707 0.0704 0.0702 0.0700 0.0696 0.0694 MONTHL Y RENEWABLE CREDIT DISABILITY DISCLOSURE FORM The Schedule of Rates shown here are gross balance rates. This means the rates are applied to the sum of the periodic loan payments which remain to be paid on your loan. The rate we use is determinefby the projected loan term of your loan (see you loan plan to find the projected term of your loan). For example, if the projected term of your loan is 24 months and the benefit plan is 14 Day Non-Retroactive, the rate for that term is .1555 per $100 of gross balance. If the amount of your periodic loan pavment is $100, the ~oss balance of your loan during the first month of your loan is $2.400 (24 x $100). Our charge to you for insurance for the first month of your loan term would be $2,400 x .1555 x 0.0 I, or $3.73. After you have made your first $1 00 periodic loan payment, the gross balance of your .]oan would then be 2,300 (23 x $100) and our charge to you for your insurance for the second month would be $2,300 x .1555 x 0.01, or $3.58, etc. The charges we actually make to you for your insurance are shown in your periodic statement which YOll receive from the Credit Union. Please remember: Whenever you add a new advance to your loan, you recast the loan and a new projected loan term is determined according to your Loan Plan. Please note also that if the amount of your periodic loan payment is greater than the maximum benefit per month shown in the Insurance Schedule of your Certificate of Insurance, our charge to you is based on the sum of the maximum benefits per month times the number of periodic loan payments remaining to be paid on your loan. For example, if your periodic loan payment is $400 and the maximum benefit per month is S300 and you have 24 payments remaining to be paid, the gross balance of your loan for purposes of this insurance would be $7,200 (not $9,600) and our charge to you for insurance the first month would be $11.20 ($7,200 x .1555 x 0.0 I). ~ SUSQUEHANNA ~ '"'- VALLEY FEDERAL CREDIT UNION Statement of Account Date: February 23,2005 Maker: John E. Minich Co maker: None Home Address: 4334 Enola Road NewvillePA 17251 Home Phone Number: 717-776-6023 Our Account Number: 11083-5 Your File # 31228 Maker Social Security # 185-38-1983 Co maker Social Security: # Principal Amount Owed Interest Owed Penalty (20 % ofPrincipal& Interest) Late Payment Fee: Total Amount Claimed: $4,978.1 9 $254.43 $1,035.06 $20.00 $6,287.68 3850 HARTZDALE DRIVE. CAMP HILL, PA 17011-7809 LOCAL: (717) 737-4152 TOLL FREE: (800) 948-1454 FAX: (717) 737-0589 rC~~ .~ FEB-28-2006 14:67 SUSQ. VAL. FCU . - -- -- -- -- ,. ".-' - .~..... , .... 7174412022 r. , P.02 VERIFICATION I, SUSAN J. BRUBA.KER, LOANS/COLLECTION MANAGER of SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, verify fhaf1l11 stalemenllmadc In the afo"'ioln~ document are true and correct. I understand 1I1at falle statements heroin arc made subject to the ptln.lties of 18 Pa. C. S. ~4904, relating to ullsworn falsification to aLllhoritic.. SUSQUEHANNA VALLEY FEDERAL CREDiT UNION " " \ fJ j I I} \ "j.' / I ,.- 111,'X,I, /_/ 1/ ,-A/-,.' or,/ .....,"..>. ." slCollec:tion Manapr ,....,... y'....7. Dated: ,/ J 11 .,..,..-" \ I 1/-') .J....,. 31228 P,\USCI\I.!lT ACYlCCP COMPLAINTSlWOllK"_~ IUat.ultll."'Ild ,zafcb05 6 TOTAL P.02 ~ i>G P\l Vl VI. --- Crt ~ () \" tn ~ VI ~ ...:l t I- -c n' "~ f;' .-' c~:) .;::.,> -ef' ~\:n (\ :r,&j'~ \,)\t} -1-' ~\:' '-I.J ::: \~~ ;'{0. ;'::~~ t"'-' .' ''<:). f".:" '.'~j.:.. -' -;$ ~l \ cP - ----- SHERIFF'S R~ NOT FOUND CASE NO: 2005-01213 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL VS MINICH JOHN E R. Thomas Kline ,Sheriff or Deputy Sheriff, who eing duly sworn according to law, says, that he made a diligent sea ch and inquiry for the within named DEFENDANT MINICH JOHN E :JUt was unable to locate Him in his bailiwick. He therefore returns _he COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , MINICH JOHN E 4334 ENOLA ROAD NEWVILLE, PA 17241 DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge Postage 18.00 8.14 5.00 10.00 .37 41.51 So answers: -':" , _2~/:;..;,;:~. _ .... _--"_. -;7 (' .;?'c_.. 1......-.- '- R. Thomas Kline Sheriff of Cumberland County / 00/00/0000 this and subscribed to ~ before me Sworn day of '/./ ./1... J Q.. II ,~/h~ A.D. t I.: ~8~. Prothonotary 0 :v~~'- SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION flkla WEST SHORE TEACHERS FEDERAL CREDIT UNION Plaintiff v. JOHN E. MINICH Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005.01213 : CIVIL DIVISION - LAW PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint filed to the above term and number and forward same to the Sherifffor certified mail service upon Defendant at: 12300 PHILLIPS LANE, LOT 15 GIBSONTON, FLORIDA 33534-5571 ___-----:J . /~ TO CUMBERLAND County Prothonotary Dated: May 20. 2005 r-=\ \~" \ ~._-_.j :"...J .... (,' ~,- ~.---' - SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2005-01213 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL VS. MINICH JOHN E R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,MINICH JOHN E by United States Certified Mail postage prepaid, on the 24th day of May ,2005 at 0000:00 HOURS, at 12300 PHILLIPS LANE LOT 15 GIBSONTON, FL 33534-5571 , a true and attested copy of the attached COMPLAINT & NOTICE Together with The returned receipt card was signed by SIGNATURE ILLEGIBLE 06/01/2005 on Additional Comments: Docketing Cert Mail Postage Surcharge 18.00 5.11 .37 10.00 .00 33.48 /~~~/ ~s Kline Sheriff of Cumberland County Sheriff's Costs: Paid by KNUPP KODAK IMBLUM on 06/09/2005 . Sworn and subscri~d to before me this ,J:'~ day of ~ ,XtfIJ6 A.D. (~, Q nAb~<<' ,'l~ P othonotary " Qt'l-''-' "\ . - 'O'~~g ~. g?;g~~g [Jl 0 9- g~::ya33 g t;;Ot'l ~ _::r~<.p."Q. 0. =1.... 0 ~~ ~ rt ;31" a. ro 2". ~ E;. jJ CD Cl g a =:-(/l tl) :J ell ;::;; ",.::;: UI goO tll: (II ro Cl ~\:l' \ ....~~3S.3 ~ JO 9- ~a.....(l)u.(I) ~ ""t" ~o~~~:'" <0 ~& c b' ~S-3o..0!'> !!l. '" uJ uJ (D~S~~~ g ,lJ"\ uJ t' Cl \5' ~ ""%\l,l(D g-(l) 0. ~ uJ 39:g$.2~ Cl ..,. ro _" 0 a. (/l 'fiJ""J': I $_ 0 '-" C\ \5' . _....? o..~ ::fo .....{() C\ \5' m-< :T""~ uJ --l ::lO([ltV l-' ~. 'F- ca ?- \ ~ -6 <. - b' " !!\ ~ o <ft JO P @ ..,j 6" t U1 rr ~ b' !> ~ >' ~ rr ." OOO\(' ;::;;fii ~ ~ ~ ~?J~. ~~ o' ! !l€.~(b 'l~ ~ (0"-<' CJ i!~~ ~~ ~ 0-0- = ~ . ~ < d, ~ ~ ~%l 1 000 . . 0 O."W 0. ~ g.~ <J1 '0 'Ja."O- ~ ~ , ! . c @ l-' '9 '3 VI " " ~. '" ~ ~;:ll' l-' ~ ~ uJ ~. --=' r> "9. ~ ~ (') g '" ~. 00 ~ < a ",. ~ z~ 9- l-' . o . m .. <: . '< ." ro <l- -"' '" .~& 6 1II'" 0 ~~ .~ ~l!!\\l~ u.l<ga. \ , - - - - // , ~.;, '"' ~ Ijj ;i tn 8- ~ i' en o OJ t: "'_ :z ::> --.--- ~. . I II' -c i." X; ~ I \.!!l' :S .s; "1 ; , \ IQ: N 1'6 ! <0 Ii ~ C "0 ~ "0 ',,<0 u.. u.. J a: w u.J :r: a:: . (1)< l'l ~6c<> :z:u>~ ::>WO t: 0"'..... .", <->:::>~ 0- 00< $ :z::r:a.. -<:1- <0 .J<>=t.W 0> e:r:;:::>..J 0:: wOu> ;..: WO- O> :EUJ~ "0 :::>2< c: 000 0> en . - - - :: == .--=. , :::: <1",1 "'"1 {:t (.) -to \') _j..J I", (. _..----..1-- ..- <-' .'- - _. .-...-.--~--- SUSQUEHANNA VALLEY FEDERAL CREDIT UNION flk/a WEST SHORE TEACHERS FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY,PENNSYLVANIA Plaintiff v. : NO. 2005-01213 CIVIL JOHN E. MINICH : CIVILDMSION-LAW Defendant TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) JOHN E. MINICH, named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiff's damages as follows: Amount claimed in Plaintiff's Complaint $11,478.72 Interest from March 1, 2005 at the legal rate of 6% per annum $258.25 Total $1l,736.97 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant(s) and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached. LUM, P.C. By ~ Robert D. Kodak, Attorney for Plaintiff DATED t1 \ ~~ """'" ... "'-, """'" M """" Prothonotary Robert L, Knupp Robert D, Kodak Gary J, Imblum LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 717/238-7158 email: kki.laW@Verizon.net f.' ". ~Lt Gaf~y Robert Ewing Knupp (1900-1976) Robert H. Maurer (1923-1998) June 23, 2005 JOHN E MINICH 12300 PHILLIPS LANE LOT 15 GIBSONTON FL 33534-5571 RE: Susquehanna Valley Federal Credit Union flk/a West Shore Teachers Federal Credit Union VS: John E. Minich No. 2005-01213 Civil, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 31228 Dear Mr. Minich: In accordance with Pennsylvania Rules of Civil Procedure 237.1 (a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & IMBLUM, P.C. Robert D, Kodak, Esq. THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDKlkqb enclosure cc: SUSAN J BRUBAKER COLL MGR SUSQUEHANNA VALLEY FEDE 3850 HARTZDALE DRIVE CAMP HILL PA 17011-7809 #11083-5 & #11083-10 fiLE CO '1;.' \ ! SUSQUEHANNA VALLEY FEDERAL : IN TIIE COURT OF COMMON PLEAS CREDIT UNION ti'kla WEST SHORE TEACHERS : CUMBERLAND COUN1Y, PENNSYLVANIA FEDERAL CREDIT UNION Plaintiff v. : NO. 2005-01213 CIVIL JOHN E. MINICH : CIVIL DMSION - LAW Defendant IMPORTANT NOTICE TO: JOHN E. MINICH. Defendant(s) DATE OF NOTICE: JUNE 23. 2005 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITIllN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE. A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING. AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, TIllS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO IDRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTIIAT MAY OFFER LEGAL SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LmERTY AVENUE CARLISLEPA 17013 (717) 249-3166 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION flkla WEST SHORE TEACHERS FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 200~1213 CIVIL JOHN E. MINICH : CIVIL DIVJSION - LAW Defendant To JOHN E. MINICH, Defendant(s) You are hereby notified that on, ) J,--~ I q (Judgment) has been entered against you in the abo e-capnoned case. , 2G::!S the following Jud!!Il1ellt entered in the amount of $1 1.736,97, DATE: r-; /1 q /6.S I , I hereby certify that the name and address of the proper person( s) to r JOHN E MINICH 12300 PHILLIPS LANE LOT 15 GIDSONTON FL 33534-5571 C- D (:J ;q. [ -a ~ it \) () p ", M - ~ C:-J '.~---' ~ en ~ c~ r c~, ~ ~ r... tI\ ttJ ,0 \If - C> '4J - , :;:;- ~ roO? c.) -