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Home My WebLink About05-3892 ORIGINAL SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 05- 3S''7.2- Cund. 1;- LEWIS H. REESE CIVIL DIVISION - LAW Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON 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 TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249-3166 SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 05.~'39;2.~:.J. Iv-- LEWIS H. REESE 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 against the Defendant to recover the sum of THIRTY THOUSAND THREE HUNDRED EIGHTY-FIVE DOLLARS AND SIXTY-NINE CENTS ($30,385.69), along with interest thereon from July 13, 2005, at the rates as agreed upon between the parties, upon a cause of action of which the following is a statement: 1. The Plaintiff, SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, is a corporation organized and existing under Federal Laws, having its principal office and place of business at 3850 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania, 17011-7809. 2. The Defendant, LEWIS H. REESE, is an adult individual residing at 336 Fourth Avenue, West Fairview, Cumberland County, Pennsylvania 17025. COUNT I - SUSOUEHANNA VALLEY FEDERAL CREDIT UNION vs. LEWIS H. REESE 3. Paragraphs 1 and 2 are incorporated herein as if fully and at length set forth. 4. Defendant, did apply for credit with Plaintiff through its Loanliner Program. A true and correct copy of the Loanliner Application executed by the Defendant is attached hereto, marked as Exhibit "A" and made a part hereof. F:IUSERIST ACYICCP COMPLAINTSIWORKlsvcu31579LLI&IL wpd:27JulO5 5. On our about November 2, 2004, Plaintiff did issue Defendant a loan for the purpose of purchasing a mobile home in the amount of Twenty-one Thousand Six Hundred Seventy-Three Dollars and Thirty-Seven Cents ($21,673.37). A true and correct copy of the Loan and Security Agreement is attached hereto, marked as Exhibit "8" and made a part hereof. 6. Due to Defendant's failure to make payments as scheduled, interest and late fees have been added to said account in the total amount of Four Thousand Six Hundred Thirty Three Dollars and Thirty Two Cents ($4,633.32), as shown on said Plaintiffs Statement of Account hereto attached, marked Exhibit "C" and made a part hereof. 7. Due to Defendant's default and pursuant to the terms of the Loan and Security Agreement, attorney's fees in the amount of One Thousand Five Hundred Eighty-Eight Dollars and Seventy-four Cents ($1,588.74) have been added to said account as shown on said Exhibit "C". 8. 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. WHEREFORE, Plaintiff brings this suit to recover from Defendants, the sum of TWENTY SEVEN THOUSAND EIGHT HUNDRED NINETY -FIVE DOLLARS AND FORTY-THREE CENTS ($27,895.43), along with interest thereon from July 13, 2005, at the rates as agreed upon between the parties. COUNT II - SUSOUEHANNA VALLEY FEDERAL CREDIT UNION vS. LEWIS H. REESE 9. Plaintiff incorporates Paragraphs I through 8 inclusive as if fully and at length set forth herein. F:IUSERIST ACYlCCP COMPLA INTSI WORKIsvcu31579LLl&IL wpd:27Jul05 3 10. On or about November 2,2004, Defendant did apply for credit with Plaintiff through its Loanliner Program. A true and correct copy ofthe Loanliner Open-End Voucher and Security Agreement, executed by the Defendant, is attached hereto, marked as Exhibit "D" and made a part hereof. 11. Defendant has defaulted under the terms of the Loanliner Agreement by failing to make monthly payments when due and owing. 13. The principal balance due and owing by Defendant to Plaintiff is the sum of One Thousand Nine Hundred Seventy-One Dollars and Seventeen Cents ($1,971.17) as appears by Plaintiffs Statement of Account hereto attached, marked as Exhibit "E" 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 One Hundred Eight Dollars and Fifty-Two Cents ($108.52) as shown on said Exhibit "E". 15. Due to the default of Defendant, and pursuant to the terms and conditions of the Loanliner Agreement, attorney's fees in the total amount of Four Hundred Ten Dollars and Fifty-Seven Cents ($410.57) have been added to said account as shown on said Exhibit "E". 16. 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. WHEREFORE, Plaintiff brings this suit to recover from Defendant: (A) Count I - The sum ofTWENTY SEVEN THOUSAND EIGHT HUNDRED NINETY FIVE DOLLARS AND F:IUSER\ST ACY\CCP COMPLAINTSIWORKIsvcu3I 579LLI&ll.wpd:27JuI05 4 FORTY THREE CENTS ($27,895.43), along with interest thereon from July 13, 2005; and (B) Count II - The sum ofTWO THOUSAND FOUR HUNDRED NINETY DOLLARS AND TWENTY-SIX CENTS ($2,490.26), together with interest thereon from July 13, 2005; for a Judgment in favor of Plaintiff and against Defendant in the amount of THIRTY THOUSAND THREE HUNDRED EIGHTY-FIVE DOLLARS AND SIXTY-NINE CENTS ($30,385.69). Respectfully submitted, KNUPP, KODAK & IMBLUM, P.c. ~ ------- Robert D. Kodak 407 North Front Street Post Office Box # 11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ill No. 18041 Attorney for Plaintiff F:\USER\ST ACYlCCP COMPLAINTS\ WORK\svcu3 I 579LLl&1I. wpd:27 JuI05 JUL-27-200S 15:50 suso. VAL. F'CU VERIFIC A TION 7174412022 P.01/01 I, SUSAN J. BRUBAKER, LOANS/COLLECTION MANAGER of SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, verify that the statements made in the aforegoing documenlllIe true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. ~4904, relating to unswom falsification to authorities. SUSQUWANNA ~RWITumON r, Loans/Collection Manager Dated: ? P.7/0S- F:\USER\ST ACYlCCP COMPLAlNTSlWORKlsvcu31579LLI&I1.wpd:27JuJOS 31579 6 "'^~... .... TOTAL P. 01 '-''''.....''' .n.....rvv 7174412022 P.02 KJt~WUNB. h<)~ ~ SUSQUEHANNA VALLEY FEDEP.A.L CREDlT UNION 38SO HanWale om.. Camp HIU. ~ 17011-7809 (717) 737-4152 Application Married Appicants: May apply tor oil sapar"t., account 'ndivKtual Credit: You mtJSt complete the Applicanf section about yourself and rhe Other section ""bout 'fGUr s;>:luse if: 1. you live in or the property pledged as collateral is located in a community pro;>erty stare (AIC. AZ. CA, ID, lA, NM, NV. TX, WA. wr~, 2. your spouse ..,.,ill use [he aCCOVllt. Of 3. you ar~ r~lyj("lg on your ~\"lotJ.sp-"s income as :'II bils;is for repayment. H you are relying on income from alimony, child support, or separate maintcnan:;e. compfete the OThet' sectiDn to the eJ(tent possible "bout th. person on whose payments you are relying" Joint Credit: It you illS aPPlying with another person, compleu: the Applicant and Other- se<:t\OftS. GUiII"antoc: Complet.e. tho Other ~c;tion if you arc a gU3r:mtor on an s.~!Jr'lt!loan. l.OANUNER AccoumlLoan: {lncJvding A TM/OeM ~'d Acc~$$ to rhe Account ;1 A vai/able} Amount Requested $ Purpose!CoJlate",I: Repay~nt: Credit Card' Account: {See Disclosure Table or Agreement for Terms} Credit Urn;t ReQt.Pesred 5' If Authorin-d User, Name: Sing(e Cr~i~ Disability Single Credit life Joint Credit llfe ^C:SOUN"'1 NlJM9~q MOTM"'R'S \l4,I::H'.... "lAME A.CCOUNT NUMBER OAIVER'S I.IC~N.$E MJMBE"'-'5TATi. 115).03"633 SOCIAL SECURITY NUMBER o;;tIVEA"S UCEIII :: I'lIUM'BERISTATE AGe> 0;: :Jf;>ENDEf,;,S BIRT~ 0.4, Tf JofQMfPHQIIlE aUSIN€SS P'I"ICNM:XT. P'RE5f:,"'T .4,Dtl~S5 LENGTH ...1 Rt5IDCf'JCC 3mv~ l.lNGlH"', RESI NC~ P'REVIOVS .OORESS lENGTH AT ff I LfN HAT RE$IDE;NCf nO' 5 .JOI"'T CR.l:OfT. SECLI'EO C"f!:on 01'1' '" YOu UVf IN /I. CO TC M" COMPf.ETE "011 JOINTCAEOlT. SCCUR~ c;:l.EDlT 0;:: IF you uvE IN A COMlW~TV f'WOPEffTY STATE: IlCAA'T"L SfAnJ$: o :M".t6_"MeN+.Ilt.~~; ,- $ Iqq'i '~~'1,,\ ir,l~ .?~'::'; ~~,~~"\) . .~~lc-.)b ADf. s ~lE .,,~"^<.Z L:> IPERVISOR'"S NAME , ~ ..... M.0i1'+t.,. ",...RlTALSTArvS; ,,~:::,:.:'t1~~g~~; JICA.,e "'''''D """"""'''' "..\.0.... . ..... tAME AND DOR6S Of ...~o..."", 't(,M .neE.- AlIMONY; SUI"PORT. OR SEPARATE ..AlNTENANCE l"'fCo..e NEED NOT .f IlE'VfALI!:O IF YOU 00 NOT OtOoSE TO tfAVE IT" CON90ERED. HE~ INCOME TflWG.'-"" $T ,toRT 0.... TC ~1'f$""TWO"( SUPERViSOR'S NAME. IF U' EMPl..OYED. TYPE Of 8\J$lNES$ Jf(JTICE::' Aol._c:>NV, CHIlD "SuPf>OI\T. OR SiPAAA, "'.....NreN.AK:E. INCO""~ M;.:lO H01 .. R.f:VEALED If You 1)0 NOT" CHOOSE TO HAve IT CONS'D!:REO. OTHER INCOME "'" SOURCE Pf"" SOURCe PVI SOllfCE PE' """"'" TARY;ISOOTYS1ATlONTR~EA.EXP'ECT- ~MUI;. ,.Ooif,! . PE' SOUOC:. . p," SOURcr . PER SOURQ; $ ..". SOVOCE .YlU'rAJl,Y:t$ C\JTy S't...TION TR.ANSft,!\ XrS:TE.!) 0URlNG. NEXT '!'"EAP.? J"I.E fHDWGJSUMAnON D-,n -... ENOlNCiJSD"..."...llON [).I,TE 'lOllS EN'I"'LOYEA N.....e...NO AODA:eSS JI' fM,"-OYEO LESS tHAN YEARS srAJfTlJrlG DATf P"IEVIOVS E"""-OYER ~IIIE "NO AOONSS IF EMp\.OY1::0 lESS THA.H FNf 1V'''' STARTING OAn f:fIIIOlJ-.GDATf ENOl D....n \fA "-'UTUAL GROUP. '9'I5O.lS1...... 66. eOJ 1000, "&.Al~" ~~,:~~;~;tt~t~t1i0)t}:;ftg; N......E AND A..ClO'lESS Of' HEA.AEST RELAnv~ NOT UVING WITH YOU OIE..ll.-;-IOrIISHIP ~~~fi~l1tJ!Wf0f~~%f ~i1-er """ Al>D~ NEAREST RElATIVE NOT I.M.NG Wl'TI-r YOU ,'..'0 ~EI"KC;..:( 7- '~)~r-' ~ (}4 110 (::'97(.ntG3 "'O~e.Pl1ONE AXX123 tlASERl211D:) L'....s..J J V .:.VV...) V:1.::>~ , /- ;:jU::;U VAL. feu .1 r- ~ ((0)., liST f>.l'l'f N...MES lofflOU! WtilCH YO~ CREDIT RF.FEAENCES "'N:J C.A:EOIT ""STOMY CA.'" ~f c,..,~,~o; UST l.OCAnON 0': ~Of"'ERTT Olf FinANCIAL I.'ISTnvrlOH Ctf'At;R:;f;~Fb'RM'A:TidN:jiI60'i.':y-oo\K .-.- .-...-.,.-..'-'..,'.:-.....-.-.:-.-:..'..--.-.,..,.>,.;--.---.,.,...-...-,..,-_..".-.-,-,-".,;.:.:- , $ $ $ $ $ $ $ $ $ , . TOTALS , 7174412022 /' , , , $ , , P.03 $ , $ $ , MARI(ET VALUE PLEDGEe AS COUA71:RA.l FOR AIfO'fHEJII. lOAN OWNeD a, A....uCAlllr OTll(.R , , , , , . ::;>':'-';.--,;'-" If you ,6.N$Wfll;-'fE:S4 TO A.n aVES,lON OTH~ THAN "'. f..XJ"\..AJri ON A.."'ATTACHEt) SHi:CT A,PUCAl{f OTI-IOI ~ I. A1t( YO~ A :J-S. =InZENORP'9tMANe'-':TRESIOEI\fT AlIEN~ 2. 00 YOU CURAfWTlY" ......Vi: AN'f OvrS-TANOtNC )UDG,UfNTS OJII HAVE you Ev::F1 FIlE!) ~OR 9AN'(R\JPTCY. HAD A DE8T AOJ:.;STt\I[~T PLAi'ol CONl'IIU.lfO lJNOE'~ CHAPTER I.J. I'iAO PAO~T'f FORECt.OSEO UPON OR AEPQSS!:SSfO IN n+E ust 1 'fEA~. OR llEEN A PARTY IN A LAW$Uln 3. IS TOIJR INCO\lE ul(a'f--,-O DECLtNE 111I THE NEXT Tw';l YUoAS7 ... A.A[ YOU A CO-lIAAI(ER. CO.SIGNfR OR GUARANTOR O~ ANY t.OAN NOrUSTeD ABOvE:1 FOA WI-IOM {N...... of Q,.....s Obl,~,.d or- Loa"'~, TO WH'.;l/lol {Nam.. (>1 C,~i'''rj: ?i~f.Er~ygp;!!f.#.~?;l~:~:: ~9~~~st ~~:~~;:n:~ionO~~~~re i;aet ir,h:~d~~;: make credit equillly <Jv..ilabJe to ~II creditworthy customers. and that. credit fepOr1ing agsncies maintain separate credit histories on each individual upon reQlJe'st. The Ohio CiVif Right,; Commission administers compliance with tM tew. (\J" , c ."J\.,;. vnles!: the Credit Union is furnished ~ copy of the agreement. stateme-nJ or i decree. Dr has actual know/edger of ,ts terms. before the credit is gfOlnred or the accounl is. opened. \2\ Pleas.e 50\91'\ il you ale not ;Jpplying lor this ilccount or loan with your spouse. The crecit baing applied tor, if grlnltd. will be incurred in the interest ot the marriage or family of ne \.I00efStgned. WfSCONSIN RESIDENTS ONLY: (1' No pr'ovision of any marital property X agreement. unU~t~rat statement vntiet Section 766.5.9. or court decree under Section 166.70 will adversely ,affect the rights 01 the Credit Union SIGNATURE FOR WISCONSIN RfStQEHTSONL'f OATE J. You promisll!J that everything you nave stated in this app.1icCltion is correct to the best of your knowredge and that the above informar;on is a complete listing of what you owe. It the-re are any impor(ant changes you wJI notify us it1 writing immedi.tely. You authoriUt the Cr.,dir Union to obtain credit reports in connection with tn;.s application for credit 6nd 'or any update'. increase. renewal. extension Of collection of the credit received. You understand that the Credit Union will relv on tho information in this application nnd your credit report to make irs decision. H yolJ request, the Cn:dir Union wit: [ell you the name aIld adc1ress of a:tV credit bureau from wn;ch it re-::.etved a credit report on you. It is a federal crime to wiUfully .nd delj~rBteJy orovide incomplete or jncomect informafion on loan applictJt10ns made to federal credit unions. or stine. chotnered credit unions insured by NeVA. J X~A/td ahc~ <2---' A,.,.,...C-A $lGfl,l.A.TU"W IS''''' out: 2. If you art!' apPtyng tor a credir card. YOIJ und8'rst8nd thar the U~ of yOU1' card wUl constitute acknowledgm&nt of rec.ipr and agreement to tJe httmS of the credit card agreem4ilnt 3I1d di$Closures. You grant us . sBcurity int.,.st in aU indi",idual and joint 511..... and/or deposit ;tc:-c:Ol,IfIfS you hzrve with U:lt no....,- and '" tt'le Mure to secur!! your Clecfrt cwd OtCcount. When you arc in defiilult. you .uthClriu uc to apply the blftena in these BCCOunts to any amounts due. Shares a"d deposits iff an fndilPidual Retirement AccounL and any other account thar woutd lose sp~iaI '-'ll: ~reiltmEnt uMier state or fed!:rallaw if given as secl.lrilr. are not subjet'1 to the security interKt you hit"'~ given in your .dIares and depo$irs. , J ""'" ~ x OTHEr'- SKiNATOfl:f. DATf LOAN oF~Vl Cor.trotEfrrtTS: SlGlrfATUAES; X OAT!: x DATE PAGE 2 4XXI2.J U,.A$ERll7UO ~ susaUEHANNAVALLEY FEDERAL CREDIT UNION 3850 Harlzdate Drive Camp Hill. PA 17011-7809 (717) 737.4152 :lQ' "~~A.~'.', "."l' ~I~,,:~IC~~ ~\ " "L I 'II = , ~~ Jill' ",==II'~ ~\.~ LOAN AND SECURITY AGREEMENTS AND DISCLOSURE STATEMENT LOAN DATE 11/02/2004 LOAN NUMBER 1 ACCOUNT NUMBER 14335 GROUP POLICY NUMBER 037,1661,8 MA TURITY DA TE 11/15/2019 I BORROWER 1 BORROWER 2 I ~JAME AND ADDRESS NAME lAND ADDRESS IF QIFFERENTFRQM BORROWER 11 Lewi s H Reese 336 Fourth St Enola, PA 17025 TRUTH IN LENDING DISCLOSURE 'e' means an estimate " ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price The cost of your credit as a yearly rate. The dollar amount the The amount of credit The amount you will have The total cost of your purchase on credit is credit will cost you. provided to you or on paid after you have made $ your behalf. all payments as scheduled. which includes your 14.25000 % $31,203.22 e $21,673 .37 $52,876.59 e down payment of $ Your Payment Schedule Will Be: Prepayment: If you payoff early you will not have to Number of Payments Amount of Payments When Payments Are Due pay a penalty. 179 $ 293.77 Month l y Beginning 12/15/2004 Required Deposit: The Annual Percentage Rate does 1 $ 291.76 11/15/2019 not take into account your required deposIt, if any. Property Insurance: You may obtain insurance from anyone ~ Assumption: Someone buying your mobile home property you cannot assume the remainder of the loan on the want that is acceptable to the credit union. If you get the insurance from us, original terms. you will pay $ Demand: 0 This obligation has a demand feature. Late Charge: 0 All disclosures are based on an assumed All payments received more than 14 days past their due date will be charged maturity of one year. a $20 late fee. Filing Fees N.,:m-riling Insurance $ .00 $ .00 Security: Collateral securing other loans with the credit union may also secure this loan. You are giving a security interest in your shares and dividends and, if any, your deposits and interest in the credit union; and the property described below: Collateral Property/Model Year I.D. Number Type Value Key Number MOBILE HOME TITLE OLYMPIC 19B9 ZZP22861 ZIMMER $ 24,081.52 $ $ Other (Describe) YOUR CREDIT UNION SHARES Pledge of Shares $ in Account No. $ in Account No. See your contract documents for any additional information about nonpayment, default, and any required repayment in full before the scheduled date. SIGNATURES CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT. By signing as Borrower, you agree to the terms of the Loan Agreement. If property is described in the "Security"section of the Truth in Lending Disclosure, you also agree to the terms of the Security Agreement. If you sign as "Owner of Property" you agree only to the terms of the Security Agreement. ~?1~U~;i 71 ~fV<' ~ ,_'P=lc)h'~fl: I X -..v'7?2-ot Ilx DATE BORROWER 2 'SEAL) IIII X DATE ~ OTHER BORROWER lSEALJ II OAT:: II OTHER BORROWER OWNER OF PROPERTY WITNESS (SEALI OWNER OF PROPERTY WITNESS DATE ] CIJ~!A MUTUAL GROUP 1999.2000,2001. ALl. RIGHTS RESERVED NXX022 (LASERI Creait Union Susquehanna Vat ley Federal ered; t uni on Borrower(s) Lewis H Reese Loan No. 1 Acet. No_ i4335 ITEMIZATION OF THE AMOUNT FINANCED Itemization of Amount Financed of $21,673.37 Amounts Paid to Others on Your Behalf: $ To $ To $ To $ To $ To $ To $ To Amount Given to You Directly Amount Paid on Your Account Prepaid Finance Charge $21,673.37 $ .00 $ (If an amount is marked with an asterisk (*) we will be retaining a portion of the amount.) $ To $ To $ To $ To $ To $ To $ To I LOAN AGREEMENT In this Loan Agreement ("Agreement") all references to "Credit Union," "we," "our," or "us," mean the Credit Union whose name appears above and anyone to whom the Credit Union assigns or transfers this Agreement. All references to "you," or "your" mean each person who signs this Agreement as a borrower. 1. PROMISE TO PAY. You pl"omlse to pay $ 21,673.37 to the Credit Union pLus interest on the unpaid balance until what you owe has been repaid. For fixed rate loans the interest rate is 14.25 % per year. Collection Costs: You promise to pay all costs of collecting the amount you owe under this agreement including court costs and reasonable attorney fees. 2. PAYMENTS . You promise to make QaVments of the amount and at the time shown in the Truth in LendinQ Disclosure. You may prepay any amount without penalty. 11 YOlJ prepay any part of what you O'N8, \{OU are stIli reqUIred to make tlie regularly scheduled payments, unless we have agreed to a change In the payment schedule. Because this is a simple interest loan, if you do not make payments exactly as scheduled, '{our final payment may be more or less than the amount 0 the final payment that is disclosed. If you elect credit insurance, we will either include the premium in your payments or extend the term of your loan. If the term is extended you will be required to make additional payments of the scheduled amount, until what you owe has been paid. You promise to make all payments to the place we choose. If thiS loan refinances another loan we have with you, the other loan will be canceled and refinanced as of the date of this loan. 3. LOAN PROCEEDS BY MAIL - If the proceeds of this loan are mailed to you, interest on this loan begins on the date the loan J)roceeds are mailed to '{au. 4. SECURITY FOR LOAN - This Agreement is secured by all property described in the "Security" section of the Truth in Lending Disclosure. Property. securing other loans you have with us also secures this loan, unfess the property is a dwellin>L A dwelling secures this loan only if it is described in the '"Security" section of the Truth in Lending Disclosure for this loan. If Credit Union has a federal charter: Statutory Lien ' If you are in default on a financial obligation to us, federal law give us the right to apply the balance of shares and dividendS in all indivlaual ana joint accounts you have with us to satisfy that obligation. After you are in default, we may exercise this right without further notice to you. (We have a federal charter if our name includes the term 'Federal Credit Union.") If Credit Union has a state charter, except in Ohio and Rhode Island: We have a statutory lien on tf1e 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 have a state charter if our name does not include the term "Federal Credit Union.") For all borrowers: You pledge as security. for this loan all shares and dividends and, if any, all deposits and interest in all joint and individual accounts you have with the credit union now and in the future. The statutory Ijen andlor your pledge will allow us to apply the funds in your account(s) to wnat 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 specia' tax treatment under state or federal law if given as securlty:. 5. DEFAULT, You will be in default under this Agreement if you do not make a payment of the amount required on or iO CUNA MUTUAL GROUP, 1999. 2000, 2001, ALL RIGHTS RESERVED CRED IT UNION before the. date it is due.You will be in default,if you break any prOrTll~e you made In connectlO.n With thiS Joan or if anyone IS In default under any security. agreement made in connection with this AQreement. You will De in default if you die, file for bankruptcy: become insolvent (that iSf unable to pay your bills and lo~ns as they become due), or i you made any false or misleading statements in your loan application. You will also be in cfefault if something happens that we believe may seriously affect your ability to repay what you owe under this Agreement or if you are in default under any other loan agreement 'LOU have with us. 6. ACTIONS AFTER DEFAULT - When you are in default, we may demand immediate payment of the entire unpaid balance under this Agreement. You waive any right you have to receive demand for payment, notice of intent to demand immediate [)ayment and no~ice at demand for immediate paYl'(lent. If we. demand Immediate paYment, you will continue to pay' Interest at the rate provided for in this Agreement, until what you owe has been repaid. We will also apply against what you owe any shares and/or deposits given as security under this Agreement. We may also exercise any other rights given 5'1. law when you are in default. 7.. EACH PERSON RESPO.N!)IBLE - Ea<;h. person who sig,ns thiS. Agreemen\ will be individually and 10lfltly responsible ~for paYing the enllre amount ow€!d under thiS Agreement. This means we can enforce our fights against anyone of you individually or against all of you togetner, 8. LATE CHARGE. If you are late in making a paVment you [)romlse to pay the late charge shown in the Truth in Lending Disclosure. If no late charge is shown, you will not be charged one. 9. DELAY IN ENFORCING RIGHTS - We can delay enforcing any' of our rights under this Agreement any number of times without losing the ability to exercise our rights later. We can enforce this Agreement against your heirs or legal representatives. 10. CONTINUED EFFECTIVENESS ' If any part of this Agreement is determined by a court to be unenforceable, the rest will remain in effect. 11. NOTICES - Notices \l\(ill be s\'lnt t9. you at the most recent address you have gIven us In wfltlng. Notice to any one of you will be notice to all. 12. OTHER PROVISIONS - COpy NXX022 (LASER Credit Union Susquehanna Valley Federal Credit Union Borr~wer(s) Lewis H Reese Loan No. 1 Aeet. No. 14335 SECURITY AGREEMENT In this Agreement all references to "credit union," "we," "our" or "us" mean the credit union whose name appears on this document and anyone to whom the credit union assigns or transfers this Agreement. All references to the" Loan" mean the loan described in the Loan Agreement that is part of this document. All references to "you," or "your" mean any person who signs this Agreement. 1. THE SECURITY FOR THE LOAN - You give us what is known as a security interest in the property described in the "Security" section of the Truth in Lending Disclosure that is part of this document ("the Property"). 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 Loan and any extensions, renewals or refinancings of the Loan. 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. 2. WHAT THE SECURITY INTEREST COVERS, The Property secures the Loan and any extensions, renewals or refinancings of the Loan. If the Property is not a dwelling, it also secures any other loans, including any credit card loan, you have now or receive in the future from us and any other amounts 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 or your principal residence, the Property will secure only this Loan and not other loans or amounts you owe us. 3. OWNERSHIP OF THE PROPERTY, You promise that you own the Property or, if this Loan is to buy the Property, you promise you will use the Loan proceeds 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 Loan 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. 4. 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 promise to do whatever else we think is necessary to protect our security interest in the Property. You also 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. 5. USE OF PROPERTY, Until the Loan 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. 6. PROPERTY INSURANCE, TAXES AND FEES - You promise to pay all taxes and fees (like registration fees) due on the Property and to keep the Property insured against loss and damage. The amount and coverage of the property insurance must be acceptable to us. You may provide the property insurance through 3 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 :ieliver the policy or proof of coverage to us if asked to do so. f you cancel your insurance and get a refund, we have a right to he refund. If the Property is lost or damaged, we can use the nsurance settlement to repair the Property or apply it towards Nhat you owe. You authorize us to endorse any draft or check Nhich may be payable to you in order for us to collect any refund )r benefits due under your insurance policy. f you do not pay the taxes or fees on the Property when due or :eep it insured, we may pay these obligations, but we are not equired to do so. Any money we spend for taxes, fees or lsurance will be added to the unpaid balance of the Loan and you viII pay interest on those amounts at the same rate you agreed to lay on the Loan. We may receive payments in connection with the lsurance from a company which provides the insurance. We may lonitor our loans for the purpose of determining whether you and ther borrowers have complied with the insurance requirements of ur loan agreements or may engage others to do so. The insurance harge added to the Loan may include (1) the insurance company's ayments to us and (2) the cost of determining compliance with JCU\JA ,',!\UTUAL GROUP, 1999. 2000, 2001, ALL RIGHTS RESERVED CREDIT UNION the insurance requirements. If we add amounts for taxes, fees or insurance to the unpaid balance of the Loan, we may increase your payments to pay the amount added within the term of the insurance or term of the Loan. 7. 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 insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. 8. DEFAULT - You will be in default if you break any promise you make or fail to perform any obligation you have under this Agreement. You will also be in default under this Agreement if the Loan is in default. 9. WHAT HAPPENS IF YOU ARE IN DEFAULT, When you are in default, we may demand immediate payment of the outstanding balance of the Loan without giving you advance notice and take possession of the Property. You agree the Credit Union has the right to take possession of the Property 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. 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 to 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 sale or the date after which a private sale 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. The rest of the sale money will be applied to what you owe under the Loan. If you have agreed to pay the Loan, you will also have to pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the Loan and to what you owe under this Agreement. You agree to pay interest on that amount at the same rate as the Loan until that amount has been paid. 10. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE LOAN, We can delay enforcing any of our rights under this Agreement any number of times without losing the ability to exercise our rights later. We can enforce this Agreement against your heirs or legal representatives. If we change the terms of the Loan, you agree that this Agreement will remain in effect. 11. CONTINUED EFFECTIVENESS - If any part of this Agreement is determined by a court to be unenforceable, the rest will remain in effect. 12. NORTH DAKOTA NOTICE TO BORROWERS PURCHASING A MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF IT IS NOT REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MA Y HAVE TO PAY THE DIFFERENCE. 13. 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 $150,000.00. o The following notice applies ONi Y when the box at left is marked. 14. 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 PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. 15. OTHER PROVISIONS- COpy NXX022 {lASERI SUSQUEHANNA ~ ~ VALLEY FEDERAL CREDIT UNION Statement of Account Date: July 12,2005 Maker: Lewis H. Reese Co maker: NONE Home Address: c/o Jeff Watt 336 Fourth Ave Enola, PA 17025 Home Phone Number: Cell 717-645-0737 Our Account Number: ]4335-] and #14335-2 Your File Number: 3] 579 Maker Social Security # 171-52-2557 Co maker Social Security: # Loan # 1 Loan # 2 Principal Amount Owed Interest Owed Penalty (20 % of Principal& Interest) Late Payment Fee: Total Amount Claimed: $23,282.11 $46\3.32 $1588.74 $20.00 $27,895.43 $1,971.17 $88.52 $410.57 $20.00 $2,490.26 ~Q \IY 3850 HARTZDALE DRIVE. CAMP HILL, PA 17011-7809 LOCAL: (717) 737.4152 TOLL FREE: (800) 948-1454 FAX: (717) 737-0 ~~ \JY SUSQUEHANNA VALLEY FEDERAL CREDIT UNION 3850 Hartzdale Drive Camp Hill, PA 17011-7809 (717) 737.4152 ill.""\ -~ iA~I'l<~;~~,r~~ 1o\..6.'_'J~, BORROWER 1 NAME Lewis H Reese BORROWER INFORMATION ACCOUNT NUMBER 14335'2 Open-End Voucher and Security Agreement I 30RRDWER 1 ADDRESS 336 Fourth St Enola, PA 17025 HOME TELEPHONE NUMBER (717)-645-2779 SOCIAL SECURITY NUMBER 171-52'2557 AMOUNT REQUESTED DATE $ 1,996.63 11/06/1004 PURPOSE: Other I) ~ t I) j L .~- tl~.11 /I! ," .-:-.::::. ~... ...., .) 30RROWER 2 NAME ACCOUNT NUMBER DEPOSIT CHECK IN ACCOUNT NUMBER/OTHER: BORROWER 2 ADDRESS SOCIAL SECURITY NUMBER CHECK PAYABLE TO: REPAYMENT METHOD: Cash BORROWER 1 EMPLOYER NAME AFFILIATED ASSOCIATES, INC. BORROWER 2 EMPLOYER NAME WORK TELEPHONE NUMBER DATE HIRED 01/01/1996 GROSS MONTHLY SALARY $1,995.07 GROSS MDNTHL Y SALARY $ WOAK TELEPHONE NUMBER DATE HIRED ~!OTICE: YOU DON'T HAVE TO INCLUDE INCOME FROM CHILD SUPPORT, SEPARATE ~/lAI~,TENANCE, OR ALIMONY UNLESS YOU WANT THE CREDIT UNION TO CONSIDER IT. SOURCE OF OTHER INCOME OTHER MONTHL Y INCOME $ WHAT YOU OWE liST ALL DEBTS OTHER THAN TO THIS CREDIT UNION IAttach additional sheet(sl if necessaly.) PRESENT BALANCE MONTHLY PAYMENT CURRENT iNTEREST RATE LOT RENT SVFCU 21,673.37 250.00 319.32 " " , SUBSEQUENT ELECTION FOR VOLUNTARY PAYMENT PROTECTION % You can now voluntarily elect to becorra insured with the coverage's) shown below. In order for coverage to become effective you must meet all insurance eligibility requirements stated in the Credit Insurance Application/Schedule. NOTE: The insurance you're applying for contains certain terms and exclusions; Refer to your certificate for coverage details. If you need a copy of the Insurance Certificate, just ask. By signing below, ','0,1 "Iuthorize us to add the charges for the insurance to your outstanding balance each month. Coverage election applies to the entire balance on this s,jbaccount. Insurance rates are subject to change. YOU ELECT THE FOLLOWING: NO Single Credit Disabi l ity NO NO Single Credit Life NO Joint Credit Life COST PER $100 OF YOUR MQNTHL Y LOAN BALANCE NAME OF INSUREDISl REPAYMENT TERMS I >- DAILY PERIODIC RATE ANNUAL PERCENT AGE RATE INTEREST RATE is; OTHER FEES IAmount and Description) NEW BALANCE THIS SUBACCOUNT ...J .027945% % 10.20000 % Fixed $ N/A $ 1,996.63 Z 0 MOUNT ADVANCEO PA YMENT AMOUNT DATE DUE PAYMENTFREGUENCY LINE OF CREDIT LIMIT REMAINING LIMIT W $1,996.63 $ 64.76 12/15/2004 Monthly $ $ 13 Your term wi II be approximately 36 payments, which may be more or less, dependi og on whether you prepay, have Z late payments, or insurance is added, etc. Q Z SECURITY OFFERED IX! CONSUMERS' CLAIMS AND DEFENSES -- IF CHECKED SEE PARAGRAPH 6 FOR NOTICE I ::l I- THE AD'.'MJCE is SECURED BY YQUR SHARES, ALL PROPERTY SECURING OTHER PLAN ADVANCES AND LOANS RECEIVED IN THE PAST OR IN THE FUTURE. AND THE FOLLOWING 0 PROPERTY/MODEL YEAR t.D. NUMBER VALUE KEY NUMBER W a: SiGNATURE 0000 $ U $ a: $ 0 $ "- PLEDGE OF SHARES ACCOUNT PLEDGE OF SHARES ACCOUNT AND.'QR DEPOSITS $ NUMBER ANDlOR DEPOSITS $ NUMBER SIGNATURES I SEE SEPARATE RATE SCHEDULE .070 123 3y signing below. by endorsing the proceeds check or by using the amount advanced and deposited into your share/share draft account you agree: I. To make and be bound by the terms of this Security Agreement including the cross collateral clause: !. The above information is true and correct and the Credit Union will rely on that information and your credit report to make a credit decision; rT make payments as disclosed above in accordance with the terms of your Plan. (SEA ISEALI RROWER 1 SIGNATURE DATE x (SEALl (SEALl IGNATURE DOWNER OF COLLATERAL (Other than a Borrower) AL IOther than a Borrowerl DATE l CUNA MUTUAL GROUP, 1980.82.84,86.89,98.99.2000,02 ALL RIGHTS RESERVED VXX065 ILASERI Susquehanna Valley Federal Credit Union Lewis H Reese Date 11/06/2004 SECURITY AGREEMENT In this agreement all references to "credit union," "we," "our," or "us" mean the credit union whose name appears on this agreement and anyone to whom the credit union assigns or transfers this agreement. All references to "you," "your," and "borrower" mean each person who signs this agreement. All references to "the advance" mean the amount in the box labeled" Amount Advanced" on page one. All references to "the Plan" mean the Credit Agreement under which the advance was obtained. Some of the provisions of this agreement apply only if the Credit Union is state chartered. A credit union has a state charter if its name does not include the words "Federal Credit Union" or "FCU". This is a multi~state document which may be used to lend to borrowers in all states except Louisiana and Wisconsin. 1. THE SECURITY FOR THE PLAN .. By signing this security agreement in the signature area or under the statement referring to this agreement which is on the back of the check you receive for the advance, you give us what is known as a security interest in the property described in the "Security Offered" section on page one. 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 refinancings 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 jf 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 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. 3. OWNERSHIP OF THE PROPERTY n You promise that you own the 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. 4. PROTECTING THE SECURITY INTEREST n 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. 5. USE OF PROPERTY -- Until the advance has been paid off, you promise you wilt: (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. 6. CONSUMERS' CLAIMS AND DEFENSES NOTICE The following paragraph applies only when the box on page one is checked. I.OfjMILI~il~;;1) D~"IllIf'!I~I~", 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 PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. 7. PROPERTY INSURANCE. TAXES AND FEES n 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 ror. You promise to make the insurance policy payable to us andtto deliver the policy or proof of coverage to us if as ked 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. Yau 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 the 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 the advance, we may increase your payments to pay the amount added within the term of the insurance or approximate term of the advance. 8. 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 insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. 9. DEFAULT -- You witl be in default if you break any promise you make under this agreement. You will also be in default if you are in default under the Plan. If you are pledging property, but have not signed the Plan, you will be in default if anyone is in default who has signed the Plan. 10. WHAT HAPPENS IF YOU ARE IN DEFAULT '. The fol/owing paragraph applies to borrowers in Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Missouri, Nebraska, West Virginia and state chartered credit unions lending to South Carolina borrowers. 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 and federally chartered credit unions lending to South Carolina 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. (Continued on next page) o CUNA MUTUAL GROUP, 1980, 82. 84. 86. 89. 98, 99. 2000. 02. ALL RIGHTS RESERVED CRED IT UN ION COPY VXX065 {LASER) S'lsque'hanna Valley Federal Credit Union Lewis H Reese The following paragraphs apply to all borrowers. You agree the Credit Union has the right to take possession of the 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. We wilt 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 to 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 sale or the date after which a private sale 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. The rest of the sale money will be applied to what you owe under the Plan. If you have agreed to pay the Advance, you will also have to pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the Advance and to what you owe under this agreement. 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. Date 11/06/2004 11. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE PLAN -- We can delay enforcing any of our rights under this agreement any number of times without losing the ability to exercise our rights later. We can enforce this agreement against your heirs or legal representatives. If we change the terms of the Plan, you agree that this agreement will continue to protect us. 12. CONTINUED EFFECTIVENESS.. If any part of this agreement is determined by a court to be unenforceable, the rest will remain in effect. 13. NOTICE TO NORTH DAKOTA BORROWERS PURCHASING A MOTOR VEHICLE ..,THE MOTOR VEHICLE IN THIS TRANS, ACTION 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. 14. NOTICE FOR ARI20NA 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. THE PROPERTY DESCRIPTION ON PAGE ONE IS PART OF THIS AGREEMENT. NOTICE: SIGN THIS AGREEMENT ON PAGE ONE. REOUESTED MEMBER PAYS PREMIUM FOR' FOR CREDIT UNION USE ONLY DATE X APPROVED APPROVED SIGNATURE DENIED LIMITS: IAdverse Action Notice Sent) $ 11/06/2004 '_DAN OFFICER COMMENTS: CHECK NUMBER: PLAN/SUBACCOUNT NO.: LINE OF CREDIT OTHER BRANCH NUMBER: PROCESSED BY TEL OTHER DEBT RATIO..SCORE BEFORE AFTER $ 31. 78200 % $ $ DATE DATE SIGNATURES' X X , CUNA MUTUAL GROUP. 1980. 82, 84. 86. 89. 98. 99. 2000, 02. ALL RIGHTS RESERVED CREDI T UN ION COPY VXX065 ILASERJ (~."'-..'\ , ~ I \ ~ ""-~--------- SUSQUEHANNA VALLEY FEDERAL CREDIT UNION 3850 Hartlda!e Drive Camp Hill, PA 17011.8035 (717) 737-4152 lC'ltMUlr,Ir-~\t BORROWER 1 NAME (Please Print) BORROWER 2 NAME (Please Print) Open-End Plan Signatures I ACCOUNT NUMBER This LOAN LINER" Credit Agreement, which includes the Truth in Lending Oisclosures, 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 the Credit Union whose name appears on the Plan or anyone to whom the Credit Union transfers its rights under the Plan. 1. HOW THIS PLAN WORKS - This is an open'end, multi,leatured 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 01 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. II may also have other terms and a schedule for determining the payment amounts. 2. 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. 3. REPAYMENT - You promise to repay all amounts you owe under the Plan plus interest Payments are due on the last day ot the month unless we set a different day at the time 01 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 tor 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 (continued on reverse side) Signatures 1. You have received and read the LOANLlNER' Credit Agreement, including the Addendum ("Agreement") and a Credit Insurance Certificate. By signing below you agree to be bound by the terms of the Agreement 2. You grant us a security interest in all individual and joint share and/or de it a,Pcounts you have with us now and in the future to secure what you owe under the LOANLlNERo Credit Agreement. When you are in defauII, you authorize us to apply the balance in these accounts to any amounls due. 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 the security interest you have given in your shares and deposits. Ix (SEAL) CUNA Mutuall"surance Society' Madison, WI 53701.0391 . Phone: 800/937,2644 "You" or "Your" means the member and the joint insured (if applicable) these charges the same as it accrues on amounts of advances which are added to Credit insurance is voluntary and not required in order 10 oblain your loan. You may your Loan Balance. select any Insurer 01 your choice. You have established an open,end Loan Plan with 00 NOT SIGN THIS APPLICATION IF IT CONTAINS ANY BLANK SPACES. This the Credit ~nion. Your ~oan Plan may consist of one or more Loans. You are applying application is void and will not be used in a contest if all blank spaces have not to the Society for credttmsurance. You authorize the charges for insurance to be been completed, ilthe member has not signed and dated the Application, and if added to your Loan Balance each month and understand thalmterest will accrue on the Application has nol beell witnessed. NOTE: The insurance you're applying for contains certain terms and exclusions; Refer to your certificate for coverage details. MEMBER'S DATE OF BIRTH ACCOUNT NUMBER DATE OF ISSUE OF THIS CERTIFICATE INSURED MEMBER L-ew;s H. JOINT INSURED MEMBER R ~", 5 c; I 0 .<t . 5 7 JOINT INSUREDS DATE OF BIRTH I 'i33 5 GHOUIO POLICY NUMBER' I I" b' 0'/ SECONDARY BENEFICIARY III V"'III~w", In """" """~ 037,1661,B THE FOLLOWING STATEMENTS MADE BY YOU ARE REPRESENTATIONS AND ARE TRUE TO THE BEST OF YOUR KNOWLEDGE AND BELIEF: CREDIT LIFE INSURANCE CREDIT DISABILITY INSURANCE [vEST NO COVERAGE SELECTED i I S!NGlE CREDIT UFE ! COST PER $100 1_115 I OF YOUR MONTHLY $.07 I lOAN BALANCE COST PER $100 X JOINT CREDIT LIFE OF YOUR MONTHLY $.123 LOAN BALANCE X ARE YOU 65 MAXIMUM AGE 65' UNDER AGE ---.-.-- - , FOR INSURANCE MAXIMUM INSURABLE BALANCE 'UNDER CREDIT LIFE AND UISABILlTY. THE PER LOAN ACCOUNT MAXIMUM ELIGIBILITY AGE FOR COVERAGE ; 50,000 IS 65, WITH NO MAXIMUM TERMINATION AGE olGNATURE OF JOINT INSURED MEMBER DATE I VEsT NOI COVERAGE SELECTED PREMIUM SCHEOULE I I ! -, X I SiNGLE CREDIT DISAB!LiTY SEE SEPARATE , , RArE SCHEDULE )( ON THIS DATE. ARE YOU PHYSICALLY WORKING FOR A SALARY OR WAGES A MINIMUM OF 25 HOURS A WEEK? X ARE YOU 65 MAXIMUM AGE 65" UNDER AGE . -, , FOR INSURANCE MAXIMUM MONTHLY TOTAL 'UNDER CREDIT LIFE AND DISABILITY. Tf-IE DISABILITY BENEFIT MAXIMUM ELIGIBILITY AGE FOR COVERAGF. S 850.00 IS 65. WITH NO MAXIMUM TERMINATION AG~ If you are totally disabled for more than disability benefit will begin with the WITNESS 14 days, then the day of disability. DATE ( 'iITNESS 15th DATE DATE ATURE OF MEMBER (Be sure to cheek one ollhe bolles above) APP801-07B6PA ( . -m.......,.....J2..P /I. %.'D"I .1 UAE OF MEMBER e sure to check one ollhe b<ues above) PP811.Q7B6PA CUNAMUTUALGROUP, 1980.82.84, 86. 89, 98.99. 2000. All RIGHTS RESERVED :J ORDER: 1-800.356-5012 CREDIT UNION COPY FLEXIBLE AGREEMENT SYSTEM BXX023 ___ _ _ _____ ________ _._____n. __ ___ _. _ __ __~_r~_~J_t__A9.~~_cf!l~_~!j~9n-~1 nuc~) rl,;; I': 1I:,f:-;0 to mJke tile reuularl;/ scheduled payil1e,:lts Uille3S ';'" ;lgr~e In tc ,:i i~S up<!a>_'d flr'i!I;'.>1! ::', r'l,~tl'.J1 ,;hanue !n trle fHVillent scneniile If j"JU have ajoint snare ~lla;! aCCoullt, YOiJ Je 13. WAIVER - v'/~ Cdrl deiJY ur ,'JdiVe enforcing any of our rights under this Plan ;t,Spc,,!c;::)i:' fell ;';i,'illg .1:II)I/e;d',-,;: ad'iJllV)S otJtaiilea by.j jO:::: ~'JI;-;er or tilE' shale ';CILI(U:Q jOiH c:bl'(jClt:U'l to :-;lrtY,8 tilll.:lj' payments. withollt losirlg our ngh! to enforce (!rod! account Ulliess othen."Jise re(jll!red by iav.J, pa/rnents ,:/:11 tie applied to a;ll(]Unts the terms CJ~ t!l"~ ?I,1J1 at a Jat'lr tlille. If the law makes anv lerm(s) at the Plan 'I"'/!;ci 11!1"1el th~ PiJrl in the rllanner the Credit Union chooses unenforceJtJ~e tilP oHler terms \'^/ili remain in effRct ' ,to PLAN ACCESS - You can obtain cr;:;Ciit JdVdllCes III ailj fllann'~1 dLit!10flzecl by (IS 14. DEFAULT ~ Tile following paragraph applies to barrowers in Idaho, Kansas, I;'."; ,ti:J"./ /C1<.: ,:.1 Jse '.'llLir Ani1' ['2!)l~ CeJl"! to access :he P!;:ln/Cii i~1J'/ be !iJble f!)r iHaine and state chartered credit unions fending to South Carolina borrowers: You the unauthOriZed use of your ATfvllDebit carel. You v-IIII not be liable lor unauthorized '..viii bt; i:l default II you do not make a payment of the amount required when it is due. use that occurs after you notify us, orally or In writing, of the loss. theft. or possible You v,nll also be in default if we believe the prospect of payment. performance. or unauthorized use. If you believe your ATM/Debrt card has been iosl or stolen fi;aliL.1tion orl an,! IHoperty given as security is significantly Impaired Immedlate!y infonT) !he Credit Union by calling or 'Nrlting us at the telephone number or acldress tnat appears elsewhere in the Plan. If the card is usee! to obtain unauthorlzea The following paragraph applies only to borrowers in Wisconsin: You will be In default ]d'f(lnCeS rJln:'ctiv irO!Tl the Plan. your liability 1I'lillnot exceed SSO Ii the unauthorized lr ,/Oll fail to make ~ p3Yl1lent 'Nhen due two times during an~' 12 month period. Vou wi I! I j I'd ft 'bT ' h R be ;n rJef~ulllf breaking any orornise made under the Plan materially impairs your ability \':i,n! raWl~ !S lIon 1 ~ S,lart: ra account. your II?. I II)' IS governed .1,/ the egulation E :~} repay ':!hClt \/ou '1",le. You will also be in default if breaking any promise made under a dlsclosures/oel received at the time you recel'led your AHA/OeM card, even if the i;"-/ithdra'i'Jal results Irl an advance Deinq made from your overdraft subaccount Secui"lty ..~gr~0I;lcnt lTlade in connection With an advance, materially impairs the condition, vJlue, or protection of or our right in any property :lOll gave as security. 5. FINANCE CHARGE - The c10llar Jmount you pay for money borrowed is called a fll1anr.e cf1arge'" and begins on the date of each advance A finance charge Will be The fol/owing paragraph applies only to borrowers in Iowa: You will be in default if comouted separately for each separate balance under the Plan, To compute the finance yOll are more than 10 days late in making a payment. You will also be in default if you charge, th€! unpaid balance for e<lch dav since your last payment (or since an advance do not com pl/ 'Nith the terms of the Plan andyour failure to comply materially impairs it 'IOU hav? :lllt yet made a payment) is multiplied by the applicable oaliv periodiC rate any propert} you CjJ\'e as security or your ability to repay what you owe under the Plan. Th;; <:'(JITl 01 tllese (lnlounts is tile iill3nce charge O',',;ed, The bai(lw;e IJsed 10, compute The folfowing paragraph applies to borrowers in alf other states and federaffy chartered tho; finance charge IS the unpaid b':llance each day after payments 2nd credits to that credit unions lending to South Carolina borrowers: You will be in default if you do not balance have been subtracted and any additIOns to the balance have been made. In ITlake a payment of the amount required when it is due. You will be in default if you break addition to interest we may charge other finance charges which are disclosed on the any promise you made under the Plan or if anyone is in default under any security Addendum. If the Interest rate is a vanable Interest rate, the Addendum explains how agreement made in connection VJith an advance under the Plan. You will be in default if you the 'Jar!able Interest rate works die, file for bankruptcy, become Insolvent, If you make any false or misleading statements 6 SECURITY v I In any credit Jppilc3tlon or update of credit Information, or if something happens we . - . all p edge as security for tne Plan all shares ann dividends and. if any. belie',j8 rna~/ sllb~LJ.ntia:''/ reduce your ability to repay what you mve. You will also be in ~~!e df~~3~~:slfa~ds~I~~~~rCs~~~I:~1 ~~~~~~1si~~~~J~~Jlf~~~~lu~~~,1r~cUe,h~;~e v~;f;f~r~~zl~o~~aar~~ :~ defauit under the ?ian Ii you are in default under any other loan agreement '1Jith us. that account to the ext~nt of the outstanding balance for the advance. Otherwise, your 15. ACTIONS AFTER DEFAULT - The (of/owing paragraph applies to borrowers in pledgeu sllares mav be withdia~'m unless you are in default. If credit union has a federal Colorado, District of Cofumbia, Iowa, Kansas, Maine, Massachusetts, Missouri, charter: Staturor~1 lien - If you are in defauil on a ftnanclal obligatlllrl to us, tederallaw Nebraska, West Virginia, Wisconsin and state chartered credit unions lending to gives us the liqht to apply ttle balance ot shares and dividenas in all individual and joint South Carofina borrowers: When you are in default and after expiration of any right you accounts you have '.'lith us to satisfy that obligalion. After you are in default. we ma:v ha''i8 unrJer aDplic3ble state 11\11 to cure your default. '.-'ie can demand immediate eXdrl;ise tillS fight ',vilhout further notice to you. (We have a federal charter if our name payment of tile entire unpaid balance under the Plan without giving you advance notice. includes the term ';Federal Credit Union") If credit union is stale chartered, except in The following paragraph applies to borrowers in all other states and to federally Ohio, Rhode Island, and Massachusetts: We have a statutory lien 011 the shares ane! chartered credit unions lending to South Carolina borrowers: When you are In default dividends 3110, it all/. trl8 deposils and interest in all individual and jOint accounts you "'.'e can require imfT1ecllate payment (acceleration) of the entire unpaid balance underthe have VJrth us anCi ;'1',1'/ exercise our rights under the lien to the extent permit~ed by slate Plan You waive anv light you have to demand for payment. notice of intenlto accelerate lav-l. (VVe are stale chartered It our l1ame does not IIlclu(Je tile term "Fedel'al Credit ClJ:C! /lotlce of acceleration Union, '",I For all borrowers: The statutory lien and/or your pledge will allow us to apply The fol/awing paragraph applies to all borrowers: If immediate payment IS demanded. the funds in your accounl(s) 10 what you owe when you are in defaull. The statutory lien you Villi continue to pay interest until what you owe has been repaid. at the applicable and j!our pledge do not apply to an'llndividual Retirement Account or any other account interesl rates in eftec: or, if app!icable, at the default rate disclosed on the Addendum, thaI wOL;ld lose speciElI tax treatment under state or federal law if given as security. !f a demand for immediate payment llas been made, your shares and/or deposits can .~d(!ition;jJ security for the Plan may be required at the lime of an advance. !f a be appiied to';.Jards what you owe as provided in the Section above called "Security". subaccount Identifles a type of property (such 3S "Nev: Cars") you must give that type of We can also exercise any other rights given by law when you are in default, and any property as security I,'ihen you get an advance under that subaccount. A subaccount rights we have under any Security Agreements you have with us. name such as "Other Secured" means you must provide security acceptable to us 'ilhen 16. CANCELLING OR CHANGING THE PLAN - The follow;ng paragraph applies onfy to vou obtain an advance under that subaccount Property you give as security will secure state chartered credit unions lending to Illinois borrowers: We have the right to change all amOu:HS owed under the Plan Jnd aii other loans vou have witll us now or In thJ the terms of the Plan from time to time after giving you an}' advance notice required by future, except an110an secured by your principal dwellirig. Property securing ether loans ia'v'{ I'..IlY c~lcHlge to the interest rale or other charges will apply to future advances. you have with us may also secure the Plan The following paragraph applies only to borrowers in Wisconsin: We can change the 7. PROPERTY INSURANCE - You \I/ill be required to purchase property insurance on terms of the Plan from time to time in accordance with Section 422.415 of the Wisconsin certain 'vpes of security that you give for advances. You may purchase the property Statutes. YOLl ',:viII be notified of any change In terms. An increase In the daily periodiC rate Insurance from anyone you choose that IS acceptable to the Credit Union undel' a variable interest rate is not conSidered a change in terms under the Plan, We can 8. CREDIT INSURANCE - Credit life and/or credit disability insurance is optional cancel the entire Plan or any part of the Plan at any time. You may cancel the Plan at any undar the Plan, If j/OLl qualify for and purchase the insurance from us, you authOrize us time oy giving us priur 'Nritten notice, Your obligation to pay the unpaid balances under to add the Insurance premiums monthly to your loan balance and charge you interest the terms of the Plan continues whether you or the credit union cancel the Plan, except to on the entlre balance. If you elect credit insurance, your payments may increase or the the extent thai your liablllty IS limited by Section 422.4155 of the Wisconsin Statutes period of time necessflry to repa'! YOur advance may be extended. The credit insurance The following paragraph applies only to borrowers;n Iowa: We can change the terms 1?[~3 l'lay cl'1anlJp. rllJling till'! PIJil If the rates change. 'Ne I!Jilt orov!cle ar:j1 notices of the PIJn fmm tir;-]e to time after givlr1g you any advance notice required by law. A reqliired OJ! app!icable law chanae Hlat Hlcreases the rate of finance charge or other charge, that increases the 9. PERIODIC STATEMENT - On a regular basis 1/OU ~v!l: receive a statement S!lOWIflL] a!]lDlll.: of 'lour pa;/meilts, or that othenvise Jd'.'ersely affects existing balances will apply all transactions under the ?Ian during the period covered by the statement. Statements to eXisting balances only if you agree to the change or you use the Plan after receiving and notices will be sent to you at the most recent address you have given us in writing notice that yOi..Jr use of the Plan means you agree the change applies to eXisting balances Unless applicable law requires notice to each joint borrower, notice to anyone of you The following paragraph applies to borrowers in all other states and federally i'vill be notice to all chartered credit unions lending fo Illinois borrowers: We have the right to change the 10. JOINT ACCOUNTS - If thiS is a joint 3ccount. each of yOll IS indivldually and terms of ttle Plan frulll time totlme after giving you any advance notice required by law jomtly respons:ble for paylIlg all amounts Q\ved. That means we can enforce OLlr rights Any change i~1 me i~lterest rate vlill apply to future advances, and at our discretion and under the Plan against anyone of you indiVidually or against all of you together. If you subject to any requirements of applicable la'.,'.}. \vIII also apply to unpaid balances. give us rncoilsistent iIls!ructions, we can refuse to follow your instructions Unless our The fof/owing paragraph applies to all but Wisconsin borr&wers: An increase in the written policy requires all of you to sign for an advance, each of you authorizes tile daily periodiC rate under a variable interest rate is not considered a change in terms otner(s) 10 obtain aavances individually and agrees to repay advances made to the under tile Plan We can cancel the entire Plan or any part of the Plan at any time, You (,tl-Jer(s). Any loilll ~ccountholder may terminate the Plan by giving us prior vlntten can cancel the Plan at dny tirne by giving us prior written notice. Your obligation to pay IV'!I!'.~ If "':"/ ot ~,'C1U terll1;rJ:e til~ Plan, the Plan is ~erminated for all of you You remain Ult L:!l03'C! ~'i1lances u:vler the terms of tile Plan continues whether you or the Credit ii,,:,:e i!lrtjvidl:JI!y al;d j']lrt\, f'~\f 311 dd'/al1ces iqcurred before termlfiCition Urliun calle:>1 lIiP Plcln 11. FEES AND CHARGES - If YDU give us a secuflty interest In certalO types 01 17. The following is required by Vermont law: NOTICE TO CO-SIGNER _ property. 'Ie may charg' yOll a lilmg lee to perfect Ollr interest 10 the property II '.'Ie do. YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUAllY theomoullt of the lee will be dISclosed to you at the time you obtam an ad'Jance. We may LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER ODES also charge you other fees in connection vlith the Plan Our current fees are disclosed on the Mdendum and Will be added fa your loan balance unless you pay them In cash. NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. 12. UPDATING CREDIT INFORMATION - You promIse that you ViiI! promptly give us 18. NOTICE TO UTAH BORROWERS: This 'mitten agreement is a flllal expression 01 viritten notice If you move. change your name or employment or If any other tile agreement betvieen you and the Credit Union. This written agrf'ement may not bE information i'O'J provided to us changes. Upon our request. you also agree to proVide contradicted by el.'idence of any oral agreement. --~-l ..____1 SUSQUEHANNA ~ """-.. VALLEY FEDERAL CREDIT UNION Statement of Account Date: July 12,2005 Maker: Lewis H. Reese Co maker: NONE Home Address: clo Jeff Watt 336 Fourth Ave Enola, P A 17025 Home Phone Number: Cell 717-645-0737 Our Account Number: 14335-1 and #14335-2 Your Fite Number: 31579 Maker Social Security # 171-52-2557 Co maker Social Security: # Loan # I Principal Amount Owed Interest Owed Penalty (20 % of Principal& Interest) Late Payment Fee: Total Amount Claimed: $23,282.11 $4613.32 $1588.74 $20.00 $27,895.43 @ 3850 HARTZDALE DRIVE . CAMP HILL, PA 17011-7809 LOCAL: (717) 737-4152 TOLL FREE: (800) 948-1454 FAX: (717) 737 Loan # 2 $1,971.17 $88.52 $410.57 $20.00 $2,490.26 ~,J.)l' , ~.' .', r~ F j r -J c- C() ~ r "? ..t> ..) (r, -<> k Ii' 6 (") _r'" ~... c:' f",,", ;.:-:: ,"--,,'1 GJ o -n :-1 .1, 'T1 \11---' r-_., ~) ~' "I- SHERIFF'S RETURN - REGULAR CASE NO: 2005-03892 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FED CR UNIO VS REESE LEWIS H RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REESE LEWIS H the DEFENDANT , at 1918:00 HOURS, on the 22nd day of August 2005 at 313D WEST SHADY LANE ENOLA, PA 17025 by handing to LEWIS REESE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 12.00 .37 10.00 .00 40.37 .r~~~~ R. Thomas Kline 08/23/2005 KNUPP KODAK Sworn and Subscribed to before By: "----' me this Sheriff arYl SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2005-03892 CML LEWIS H. REESE : CML DMSION - 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) LEWIS H. REESE, 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 $30,385.69 Interest from July 13,2005 at the legal rate of 14.25% per annum $992.28 Total $31,377.97 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 defau1t occurred and at leastten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached. KNUPP~UM,PC By ~ Robert D. Kodak, Attorney for Plaintiff DATED: ~~\()& \D Judgment entered and damages assessed as above. i!~ 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 I L E RCfifgtupp (1009-1976) Robert H. Maurer (1923-1998) September 12, 2005 LEWIS H REESE 3130 WEST SHADY LANE ENOLA PA 17025 Re: Susquehanna Valley FCU VS: Lewis H. Reese No. 2005-03892 Civil. Court of Common Pleas Cumberland County. Commonwealth of Pennsylvania Our File No. 31579 Dear Mr. Reese: 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: ATTN SUSAN J BRUBAKER LOAN COLL MGR SUSQUEHANNA VALLEY FCU 3850 HARTZDALE DRIVE CAMP HILL PA 17011-7809 #14335-1 fiLE COpy SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2005-03892 LEWIS H. REESE : CIVIL DMSION - LAW Defendant IMPORTANT NOTICE TO: LEWIS H. REESE, Defendant(s) DATE OF NOTICE: SEPTEMBER 12. 2005 YOU ARE IN DEF AUL T BECAUSE YOU HA VB 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 WITHIN 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 HA VB 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 HIRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTHAT MAY OFFER LEGAL SERVICES TO ELlGffiLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LffiERTY AVENUE CARLISLE P A 17013 (717) 249-3166 ~ G -p "*- ~~ ~ ~ ~ ~ ~ ~ -- ~ -. ~ ~ B ~ :t:> 4- .r '. C) c~ ~s ~ '31 -' o ;FI ~~ :::\ . b. ~T-~ q~ i,"1 '-:'~;,/, .".-," 3 [?t\~~, '? ~~ ~:~ .r;- - SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2005-03892 CML LEWIS H. REESE : CML DMSION - LAW Defendant TO: LEWIS H. REESE, Defendant(s) You are hereby notified that on Clc..t-- ....J: (Judgment) has been entered against you in the above-captioned case. , 20Q,S the following DATE: 10/ K /0.5 , I hereby certifY that the name and address of the proper person( s) to receive this notice is: LEWIS H REESE 313D WEST SHADY LANE ENOLA PA 17025 AI LEWIS H. REESE, Defendido/a Defendidos/as Por este medio se Ie esta notificando que el de de1200S, ellla siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: LEWIS H REESE 313D WEST SHADY LANE ENOLA PA 17025 Abogado del Demandante PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 Plaintiff NO. 2005-03892 CIVIL TERM Term 20~ vs Amount due $ 31.377.97 LEWIS H. REESE 313 D WEST SHADY LANE ENOLA PA 17025 Interest FROM DATE OF JUDG. 10/05/05 Atty's Comm. $ 1.568.90 and CostsTO BE DETEIlMINED$ Defendant (s) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Ctn(BE~ County, Pennsylvania; (2) against LEWIS H. REESE (3) and against (4) and index this writ (a) against LEWIS H. REESE (b) against Defendant (s) Garnishee (s) , Defendant(s) and Garnishee ( s) . as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UpON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING BUT NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, AND A 1989 OLYMPIC ZIMMER MOBILE HOME AT AN ADDITIONAL ADDRESS OF 7073 CARLISLE PIKE, LOT 206, CARLISLE PA (5) Exemption has (not) been waived. A Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Attorney For Plaintiff(s) Dated 10/19/05 .(~lvotr aTn~ aas 'paJ!sap S1 suapued s1T B se fm::xapu1 PU;? pal/;;)~::j.~e S1 aal.lsTU.1BD eq~ JO ~W9U eq'J, uT A:pado.1d T'2~::r rf kruo pe:!,aTd\11oo aq pynoqs (q) (v) l.{de.ID~.Ied . (q) vOlE arn'tl ailS .,u9'J,OU04,:\O.Id aq~ ^q ^'J,uno~ 'J,e4~ uT eS.1noo JO se pa.llnba.I S1 5uTxapUr ^'J,unoo .Iaq~oti~ o~ s~nssT 1T.1M al.l1 u3l/M '(elvotE atn~ lq pazT.IoQ~ne se pa.1Tsap s1 'aoueJnss1 JO A'J,uno~ al/1 tiT 5uo\4noaxa 8l/1 JO 6UrX3pu1 JT AltiO paleTdwoo aq Plnol.ls (e) {v1 qde.I6e~ed . (:n.IM er.p u1 papnpuT aq OJ, s1 eel/sTti.re.o paul'C!u e UT htuo p;:qaTdUlo~ eq PTnol/S' eAoqe) !E) 1..ld-e.IO'2.IE'd 'panS'sT lfo11.jM. 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WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-3892 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Plaintiff (s) From LEWIS H. REESE, 313 D WEST SHADY LANE, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING BUT NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, AND A 1989 OLYMPIC MOBILE HOME AT AN ADDITIONAL ADDRESS OF 7073 CARLISLE PIKE, LOT 206, CARLISLE, P A 17013 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated, Amount Due $31,377.97 Interest FROM DATE OF JUDG 10/5/05 L.L. $.50 Atty's Comm % $1,568.90 Due Prothy $1.00 Other Costs Atty Paid $122.37 Plaintiff Paid Date: OCTOBER 20, 2005 (Seal) By: Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 fJ:JJ <?~:~.' C:-,,:c'.: IT; I.hl. (:7 ':"....,....., R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertifing Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 18.00 2.40 .50 1.00 20.16 40.00 40.00 122.06 ) ~ (,.o~.o(, V So Ans 2006 A.D. P othonotary Advance Costs: 150.00 Sheriffs Costs 122.06 27.94 Refunded to Atty on 5/16/06 Sworn and Subscribed to be~e me ;",fltIf:..--< ~ < ,f _.~_ R. Thomas Kline, Sheriff U By G . ~~~/~ ~ 9iiJ '=ifU '=::Q :.~ if1ilJ ~ v- , \ ~ C? 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