HomeMy WebLinkAbout05-5482MEMBERS 11T FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
AMY D. COLEMAN
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: D S - S"4Pk
CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTHNG TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20) days after this
Complaint and Notice are served by entering a written appearance personally or by
attorney and filing in writing 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 claims 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 OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166 OR (800) 990-9108
MEMBERS IsT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PLAINTIFF PENNSYLVANIA
Vs. : NO.:
AMY D. COLEMAN
DEFENDANT CIVIL ACTION - LAW
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y ]a notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o
sus objectiones a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 or 1-800-990-9108
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
AMY D. COLEMAN
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: Ds -_50
CIVIL ACTION-LAW
COMPLAINT
LtvLl l
AND NOW, comes Members I" Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1. Plaintiff, Members 15t Federal Credit Union ("Members 1 Sr), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Amy D. Coleman ("Defendant'), is an adult individual having a last known
address of 6180 Kerrick Drive, La Plata, MD 20646.
3. On or about November 22, 1999, Defendant borrowed from and agreed to
repay to Members 1St THIRTY-THREE THOUSAND FOUR HUNDRED
EINGT AND 281100 ($33,408.28) dollars (the "Loan"). The Loan is
evidenced by a Closed-End Note, Disclosure, Loan and Security Agreements
dated November 22, 1999 (the "Note") executed and delivered to Members 1St
by Defendant in Cumberland County, Pennsylvania. A copy of the Note is
attached hereto as Exhibit "A" and made part hereof.
1
4. The Note has never been assigned by Members I" and is still held by it as a
valid and subsisting obligation of Defendant.
Pursuant to the terms and conditions of the Note, Defendant agreed to pay to
Members 1 st bi-weekly installments of principal and interest in the amount of
at least $281.95 each beginning on January 7, 2000 and continuing every two
weeks thereafter.
6. Defendant is in default of Defendant's obligations under the Note as a result
of Defendant's failure to make the payments due to Plaintiff as set forth in the
Note.
By letter dated September 9, 2005, addressed to Defendant, Members 1 st
exercised its rights under the Note and accelerated all amounts due under the
Note and demanded the payment of all amounts due under the Note. A copy
of Plaintiff's Demand is attached hereto as Exhibit "B" and made part hereof.
8. As of October 18, 2005, Defendant is indebted to Members 15' in the amount
of SIX THOUSAND THREE HUNDRED SEVENTY-SIX AND 98/100
($6,376.98) dollars itemized as follows:
a. Outstanding principal $5,165.92
b. Interest to October 18, 2005 151.06
c. Attorney's fees 1,060.00
e. Total due to Members 1st as of October 18, 2005 $6,376.98
Legal fees are estimated in accordance with the terms and conditions of the
Note. Defendant will owe to Members 151 its actual reasonable legal fees as of
the date of payment of all amounts due under the Note subject to any
limitation set forth in the Note.
9. Defendant also agreed under the terms and conditions of the Note that in the
Respectfully submitted,
event of default there under Defendant would pay, in addition to the amounts
set forth in paragraph 8 above, costs incurred by Members 1 st as a result of
the institution of these legal proceeding.
10. Defendant is also responsible for the payment of interest from October 18,
2005 at the rate of $.9610 per day.
11. As set forth above, Members 1 s` has made demand upon Defendant to make
payment of all amounts due to Members 1 s` under the Note and, as of the date
hereof, Defendant has failed and refused to make payment of all such amounts
due to Members 1 g`.
WHEREFORE, Plaintiff, Members Is` Federal Credit Union, demands judgment
against Amy D. Coleman in the amount of SIX THOUSAND THREE HUNDRED
SEVENTY-SIX AND 98/100 ($6,376.98) dollars plus interest at the rate of $.9610 per
day from October 18, 2005 through the date of judgment entered on this complaint and at
the legal rate thereafter and costs of suit.
Dated: October 18, 2005
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Supreme Court ID # : 59012
P.O. Box 173
CLOSED-END NOTE, DISCLOSURE,
LOAN AND SECURITY AGREEMENTS
IAI
Members
FEDERAL CREDIT UNION
5000 Louise Drive " P.O. Box 40
Mechanicsburg, PA 17055
30CIAL SECURITY NUMBER
AA60430
11--E2-99
6.71400
is 04.0
DEBTOR'S NAME AND ADDRESS
38 N 5TH STREET
HARRISFURG, F'A 17110
ACCOUNT NUMBER
159613,--1211
-01
DO-DEBTOR's NAME
1AIC
FIXED VARIABLE
06-17--05 _X_ PREFERRED
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed: The Total of Payments: The e" means estimate 11
RATE: The cost of your
The dollar amount the credit amount of credit provided
to you or on your behalf. amount you will have paid
after you have made all Prepayment: If you pay off early, you
will not have to pay a penalty.
credit as a yearly rate. will cost you. payments as scheduled. See your contract documents for any
additional information about nonpayment.
default, any required repayment in full
r7
Jr
0
$ 31..00, c:]
$ 44121 318. 855 before the scheduled date and
prepayment refunds and penalties.
6. 7900 % .
$ 69 1
Variable More: The Annual Percentage Rate may increase during the term of this transaction it the (Index)
changes. We add a margin of N/A to the Index value. The rate will change monthly on the first day of the month. The rate will never be higher than the
Ix) x A
maximum rate allowed by law, and it will never be less than Any interest rate increases will result in more payments of the same amount. For Example,
if your loan was for $5,000 at 15% for 48 months and the Annual Percentage Rate increased by 2% after one year, the term of your loan would increase by two months.
Number of Payments Amount of Payments When Payments Are Due Property Insurance: You may obtain property insurance II,
Your 1 4 t!3 1 r_, r•=r e, I- j, - W e e li J, y R e 17 'i. rI 0 J. --171 r --00 from anyone you want that is acceptable to the credit
Payment = r union. If you get the insurance from the credit union you
schedules cp1.9`,e Final dl..te 06--17-05 will pay
will be: r' N/A
Security: Collateral securing other loans with the credit union the goods or
will also secure this loan. You are giving a security interest in property being Other
your shares and/or deposit in the credit union, and. purchased. (Describe): AU 0
Late Charge: If a payment is late by 10 days or Required Deposit Balance: The Annual Filing Fees: Non-Filing Insurance:
more, you will be charged a late fee of 5% of your Percentage Rate does not take into account your n /a N/A
scheduled payment. required deposit balance. $ $
I I Ovum I4"IN ur I nc MIVIuuIV I r11VNIVUMU
SENT FINANCED OF AMOUNT GIVEN TO you DIRECTLY AMOUNT PAID ON YOUR ACCOUNT PREPAID FINANCE CHP
3408. 28 g x3403. c' $ n/a $ n/a
Amount
Paid to $ n/a TcCi- edit; J.TI£I-tr•anc.e $n/a To
Others on $ n/a ToEnc Fee $ To
Your Behalf $ To
$ n/a To
NOTE AND SECURITY AGREEMENT (CONTINUED ON REVERSE SIDE)
The following paragraph applies only if this is a variable rate loan, The initial rate of interest is "I /A /.
Interest. Interest will be charged from the date of this loan until you have paid what you owe under this Agreement. The interest rate is subject to change as follows.
If the N/A (Index) changes. We will add a margin of 1`d/A to the index value.
The rate will change monthly on the first day of the month. The rate will never be higher than the maximum rate allowed by law, and it will never be less thari?l'
Any interest rate increases will result in more payments of the same amount.
Promise to Pay: You promise to ; ,_';4 VTH,r-`"' to the credit union plus interest on the unpaid balance at
pay $ o per year
until what you owe has been repaid.
SECURITY INFORMATION
MAKE MODEL YEAR I.D. NUMBER TYPE VALUE
LEXUS RX300 2000 JTGHFIOUBYOI07777 AIJTO r1/a
n/a
OTHER (Describe):
You Pledge Shares AMOUNT ACCOUNT NUMBER AMOUNT ACCOUNT NUMBER
a
and/or Deposits of $ n r/ 2s $ r l
I agree that the terms and conditions in the disclosure statement above and the loan and security agreements located on the reverse side of this document shall apply
to this loan. If there is more than one borrower, we agree that all the conditions of the loan and security agreements governing this loan shall apply to both jointly and
severally, knowledge that I have received a copy of the loan and security agreements and disclosure statement.
a
D T,OR'S SI NAT RE / ., DATA, ,:,- "vi ? CO MAKER `OTHER OWNER El '-GUARANTOR DATE
vll rseAU EXHI 1 X,,AII IsEAu
IN THESE AGREEMENTS. THE WORDS 'i: "ME." *MY' AND "MINE MEAN -.: 'r1,)SE NAMED DG? 'ITt 7T >='?: "'I , ;L
'YOURS' MEAN THE CREDIT UNION.
LOAN AGREEMENT
Payments/Finance Charges: For value received. I promise to pay. at your
office- all amounts due- AIT payments shall be made pursuant to the
disclosure statement on the face of this document. I understand that the
finance charge and total of payments shown on the reverse side of this
page are based on the assumption that all installment payments will be
!Wade on the scheduled due dates. If I fail to pay any installment by the
time if is due. I will pay additional interest on the overdue amount.
Late Charges: If 1 make a late payment, I agree to pay a late charge it
one is disclosed on the face of this document.
Property Insurance: If I obtain a loan secured by a motor vehicle or other
tangfole oroperty. I must obtain insurance which protects the credit union
from financial loss. The amount and coverage of the property insurance
must be acceptable to the credit union. Such a policy must provide at least
tiro, That, combined additional coverages and collision insurance. It must
contain a Loss Payable clause endorsement naming the credit union as
I]en holder- I may obtain this insurance from any agent of my choice and
direct the agent to send you a copy of the policy.
Debtor Responsibility: I promise to notify you of any change in my name.
address or employment. I promise not to apply for a loan if I know there is
a reasonable probability that I will be unable to repay my obligation
according to the terms of the credit extension. I promise to inform you of
any new information which relates to my ability to repay my obligation. 1
promise not to submit false or inaccurate information or willfully conceal
information regarding my creditworthiness. credit standing, or credit
capacity.
Default: 11) If I break any promise made under this Loan Agreement or
under the Security Agreement; or (2) if I do not use the money you loaned
me for the purpose stated in my application; or (3) if you should. in good
faith. believe that prospect of payment. performance or realization of the
collateral, if any, is impaired: or (4) if I die: or (5) if I file a petition in
bankruptcy. insolvency, or receivership or am put involuntarily into such
proceedings: or (6) if the collateral, if any, given as security for this loan is
lost. damaged or destroyed, or if it is levied against, attached or garnished
or i7i If I do not pay on time any of my other or future debts to you, you
may, at your option and without prior notice, declare this loan immediately
due and payable. and I must immediately pay the total unpaid balance, as
well as the Finance Charge to date, any late charges and costs of
collection permitted under law, Including reasonable attorney's fees, that
you may incur. up to 20% of the unpaid principal and interest. Costs of
collection include, but are riot limited to. repossession fees, appraisals.
environmental site assessments. casualty damage insurance coverage,
and attorney `s fees for any action taken by an attorney in order to collect
this loan or preserve or protect the credit union's rights and remedies,
including, without limitation, pre-suit demands for payment, pre-suit
mediation or settlement negotiations, investigation and assessment of the
credit unions' rights. participation in bankruptcy cases, matters, and
proceedings {including, without limitation, filing proofs of claim, pursuing
reaffirmation concerni attending meetings of creditors. and pursuing
complaints, motions. and objections that relate in any way to the credit
union's collateral or right to payment). collateral disposition- non-
bankruptcy suits and/or administrative actions, and appeals. The principal
ance in default shall bear interest at the contract rate.
Delay in Enforcement: You may delay enforcing any of your rights under
this agreement without losing them.
Irregular Payments: You may accept late payments or partial payments.
even though marked 'payment in full," without losing any of your rights
under this agreement
Co-makers: If I am signing this agreement as a co-maker, I agree to be
equally respons'rhle wdh the borrower. but you may sue either or both of
us. you do not have to notify me that this agreement has not been paid.
von may extend the terms of payment and release any security without
notifying or releasing me from responsibility on this agreement.
Contractual Pledge of Shares: I pledge all my shares and deposits
in the credit union, including future additions, as security for this
loan. in case I default, you may apply these shares and deposits to
the payment of all sums due at the time of default, including costs
of collection and reasonable attorney's fees. No lien or right to
impress a lien on shares and deposits shall apply to any of my
shares which may be held in an 'Individual Retirement Account" or
'Keogh Plan."
SECURITY AGREEMENT
1. To secure payment of this loan and all expenditures incurred by
the credit union in connection with this loan. or in reaiizina on a
security interesi, i grant to you a security interest in the oroperty
described on the reverse side at this document. The security interest
includes all increases, substitutions and additions to the secured
property, proceeds from any insurance on the secured property and
all earnings received +rom the secured property.
Crass-collateralization. Property given as security for This loan or for
any other loan will secure all amounts I owe the :credit union now eno
in the future. However, property securing another debt will not secure
this loan if such property is my cornmeal dweilina or are household
goods.
2. 1 will not change the location of. sell d I_ Iht r I jW
'nave your prior written consent.
3- 1 warrant that have good title to the collars ai. free of all secwtty
interests except that given to the credit union and except for afly merest of
a non-co-maker owner of the r uaterai woo a, r;r" h greemenr in
the indicated place.
I I will pay all rtes asses men s. ;; " tons tgains; i i hec to the
property described and further agree 10 Keep the moorrul it good
condition, housed in a suitable shelter. I agree to exect!fo financing
statements and security agreement amendments at ,Our request and will
defend the property against adverse third party, claims.
5. 1 will maintain insurance to cover any vehicle or other property I- which
you have a security interest. This insurance will be in a form and an
amount satisfactory to you. I will supply you with prcot of such insurance
until all sums owed to you and secured by this property are repaid !f t fail
to maintain such insurance, you may, but aro not required to. obtain
insurance of your own and add the cost of ucn to Ina ;ums owed. his
cost will bear interest at the contract rate until Iiard. i insider _iss pi to you
the right to receive the proceeds of any insurcnge on such propenv. and
direct any insurer to pay those oroceeds direr t v to you wihori to you to
endorse any check or draft provided as the proceeds ni ;uch nmimrce.
and apply those proceeds to [tie sums owed to you.
I further authorize you to provide your Insurance Service Center with the
necessary information for verification of adequate coverage -
I acknowledge that insurance, or any extension thereof. placed by you Is
without benefit to me individually but is primarily for the protection of you.
6. Should you feel at any time that the security preserved has diminished
in value, or for any reason feel that additional security is required. I agree
to assign to you within ten (10) days whatever additional securty you lee]
is necessary to protect vourself against possible lose.
If a default as defined in the Loan Agreement should occur, you have
the authri upon such default to repossess uin se .!I f rrGt o[; n a
lawful mariner. In such case.. you or your -.uthonzed r iresent: rives may.
at your option. enter the premises where 'he NlulmraI r_ Kole ono lake
possession. subject to applicable laws- You r vr. t,e right to sender the
property pledged as collateral unusable um arry dispo c .t the :ollateral
on the premises where the collateral is kept. if you decide to sell the
collateral at a public sale, private sale or )mrnwise -;pose rf 'hn
collateral. you will notify me of 'he time and place of the intended
disposition ten (10) days prior to the sale or disposition. If you sell or
otherwise dispose of the collateral you may collect from me a s unable
expenses mounted in the retaking, holdlnq and preparing th collateral Tor
and arranging the sale of the collateral. You Inay also collect reasonable
attorney's fees and legal expenses. permitted by applicable law, incurred
in connection with disposition of the property. Unless I default. I may keep
possession of the property (collateral) described and use it in any lawful
manner consistent with this agreement or with the insurance policy on the
collateral. I understand that you have certain rights and legal remedies
available to you under the Un:fonn Commercial Clods -rd then arc rca o'e
laws, and that you may use these rights to nt rye payi fnr t oefawt. ;n
the event, 1 will at your request assemble the nr mcr,, I0oilaterah and
make it ava!labte to you at a place of your io rg. 1f ton lecide to larva
this default, it wlil nor wns5tute waiver of arardts
S. You are hereby Appow e , is rnv shot Fact ?c r arc, ar i,TJ
which you test are necessary to protect :hr cllateral anc _ .., ,
interest which this adre;ement creates
9. If there is mcit, than one r o car ru ntu ah ;ns nJer this
agreement are loin[ and sevc i ac`s bar rq ar , l,, re y r in to ulfiil
the terms of this agreement
10. This security agreement not only bind' r;?, but my xr dor;.
administrators, heirs, and assigns.
EXHIBIT "An
r=.d2_169 4/97 6 t00 ;1199
KARL M. LEDEBOHM
ATTORNEY-AT LAW
P.O. BOX 173
New Cumberland, PA 17070-0173
Phone: 717-938-6929
Fax: 717-932-0317
September 9, 2005
(Via Certified and regular mail)
Amy D. Coleman
6180 Kerrick Drive
La Plata MD 20646
RE: Members I" Account No.: 0000159613-01
Dear Ms. Coleman:
THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE FROM
THIS OFFICE IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. AN
IMPORTANT STATEMENT OF RIGHTS IS INCLUDED ON THE REVERSE
OF THE SECOND PAGE OF THIS LETTER.
Members 1" Federal Credit Union ("Members I"") has requested my office to
collect the amounts due to Member's I" under the above account.
As you know, you are in default of your obligations under the above account (the
"Account") evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement
dated November 22, 1999 in the original principal amount of $33,408.28 (the "Note")
due to your failure to make the payments required under the Note in a timely manner. As
a result of your defaults, Members I" hereby accelerates all remaining amounts due to
Members 151 under the Account and the Note and hereby demands the payment of all
amounts due to Members 151 under the Account and the Note in the amount of $5,375.71
itemized as follows:
I. Principal $5,030.92
2. Interest to 9/12105 116.99
3. Late fees 112.80
4. Legal Fees 115.00
5. Total due to Member I" as of 9/12/05 $5,375.71
Interest continues to accrue on the above obligation at the rate of $.9359 per day.
If you fail to deliver payment of the $5,375.71 together with additional
interest to the date that payment is delivered to Members I" within thirty (30) days
EXHIBIT "B"
of the date of this letter, Members I" will have no choice but to file a legal action
against you to collect all of the amounts due under the Account and the
corresponding Note without further notice. In such event, in addition to the above
amounts, you may also be responsible for the payment of additional reasonable legal fees
and costs of suit incurred by Members I".
Nothing herein shall constitute or be construed as an agreement on behalf of
Members 151 to accept any terms and conditions in exchange for payment of the amounts
due under the Account except for the immediate payment of all amounts due to Members
1St . Nothing herein shall constitute a waiver of any rights or remedies which Members
I" may have under any written agreement or at law or in equity to collect the balance of
the indebtedness due under the Account without further notice, including, without
limitation, the right to accept and apply any partial payments made on the Account
without waiver of any demand for payment in full of all amounts due under the Account.
Nothing herein shall constitute an agreement on behalf of Members 1't to postpone or
extend the maturity date under the Note.
Members I" looks forward to the payment of the $5,375.71 together with
additional interest to the date that payment is delivered to Members 151 on or before
October 10. 2005.
Very t71y yours,
TCarl M.` Ledebohm V
CC: Stephanie McCreary, Collections Officer
NOTICE
This letter is an attempt to collect a debt.
It you dispute the validity of this debt, or any portion thereof, and you contact the
undersigned within thirty (30) days after receipt of this Notice, you will be furnished with
written verification of the debt, provided, that if a lawsuit has been filed against you to
collect this debt before the expiration of the thirty (30) days, the complaint filed in said
lawsuit will constitute written verification of the debt.
If you do not dispute the debt or any portion thereof as stated above, the
undersigned will assume the debt is valid.
If the original creditor of this debt is different from the creditor stated on the front
page of this letter, the undersigned will provide you with the name and address of the
original creditor upon written request from you within thirty (30) days of receipt of this
notice.
The undersigned means the name signed at the end of this letter appearing in print
at the top of this letter.
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V)CItMCAT[ON
I, Stephanie McCreary, Collections Officer for Members 1" Federal Credit Union,
being authorized 1b do So on behalf of Members I" Federal Credit Union, hereby verify
that the statements made in the foregoing pleading are true and correct to the best of my
information knowledge and belief I understand that false statements are made subject to
the penalties of 18 Pa C.S.A. Section 4904, relating to unsworn falsification to
authorities.
Members I" Federal Credit Union
Stephanie McCreary, Collections
OMeer
Amy D Coleman
-o
P
?f
I ;
Curtis R. Long
Prothonotary
Office of the Protbonotarp
Cumberlanb Countp
Renee R. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
,?'_ s ..CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
n..a r`.,,,rrhn„cr Crniare • Carlisle. Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573