HomeMy WebLinkAbout05-5622
MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
PLAINTIFF
Vs.
NO. 0 S- - 9oJ.d.-..
C;u;l'1&~
HELEN M GElLING
MICHAEL 1 GEILING
DEFENDANTS
. CIVIL ACTION-LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
A TTEMPTIING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
YOU HA VB 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 fDrth 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 Y DU
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 HA VB 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 LmERTV AVENUE
CARLISLE, PA 17013
(717) 249-3166 OR (800) 990-9108
MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NO.:
HELEN M GElLING
MICHAEL J GEILING
DEFENDANTS
: CIVIL ACTION-LAW
NOTlCIA
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 la notification Usted debe presentar una apariencia
escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0
sus objectiones alas 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 0 notification y por cualquier queja 0 alivio que
es pedido en la peticion de demanda USTED PUEDE PERDER DINERO 0 OTROS
DERECHOS IMPORT ANTES PARA USTED,
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE 0 CONOCES UN ABOGADO, VAYA EN PERSONA 0
LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DON DE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
(717)249-3166 or 1-800-990-9108
MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NO. OS- - :/(,22..- C'ulL /Efl-~
HELEN M GElLING
MICHAEL 1 GEILING
DEFENDANTS
. CIVIL ACTION-LAW
COMPLAINT
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
I. Plaintiff, Members 1" Federal Credit Union ("Members I"'), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055,
2. Helen M. Geiling is an adult individual having a last known address of 16
Rockaway Drive, Camp Hill, P A 17011.
3. Michael J. Geiling is an adult individual having a last known address of 360 1
Brisban Street, Harrisburg, P A 17111. Helen M. Geiling and Michael J.
Geiling are referred to herein collectively as "Defendants"
4. On or about August 1,2003, Defendants borrowed from and agreed to repay
to Members I" THIRTY -ONE THOUSAND SIX HUNDRED NINETY-
FOUR AND 87/100 ($31,694.87) dollars (the "LDan"). The Loan is
evidenced by a Closed-End NDte, Disclosure, LDan and Security Agreements
dated August 1, 2003 (the "Note") executed and delivered to Members 1'" by
Defendants, A copy of the Note is attached hereto as Exhibit "A" and made
part hereof
5. The Note has never been assigned by Members I" and is still held by it as a
valid and subsisting obligation of Defendants
6. Pursuant to the terms and conditions of the Note, Defendants agreed to pay to
Members l't monthly installments of principal and interest in the amount of at
least $382.02 each beginning on September 16,2003 and continuing on the
sixteenth day of each month thereafter, which payments were later adjusted to
at least $37753 per month.
7. Defendants are in default of Defendants' obligations under the Note as a result
of Defendants' failure to make the payments due to Plaintiff as set forth in the
Note
8. Pursuant to the Act ofJanuary 30, 1974, PL. 13, No.6, 41 P.S section 101,
et seq, and in particular section 403 thereof, Members 1" gave written notice
to Defendants of its intent to foreclose by letter dated July 18,2005, addressed
to Defendants via certified mail, return receipt requested A copy of the said
notice is attached hereto as Exhibit "B" and made part hereof
9. In accordance with the Homeowners' Emergency Mortgage Assistance Act,
Act of December 23, 1983, PL. 385, No 91, 35 PS Section 168040l(c), et.
seq, a Notice ofIntent to Foreclose and of Defendants' rights under said Act
was forwarded to the Defendants on July 18, 2005, via certified mail, return
receipt requested. Members 1" believes and therefore aVtors that Defendants
have not applied for assistance under the Act. A copy of the said notice is
attached hereto as Exhibit "c" and made part hereof
I 0 A copy of Postal forms 3877 evidencing the mailing of said Notice is attached
hereto as Exhibit "D" and made part hereof
11. By letter dated September 22,2005, addressed to Defendants, Members 1st
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 "E" and made part hereof
12. As of September 16,2005, Defendants are indebted to Members 1" in the
amount of THIRTY-TWO THOUSAND FOUR HUNDRED SIXTY-EIGHT
and 08/100 ($32,468.08) dollars itemized as follows
c. Attorney's fees
d. Total due to Members 1 ,( as of 10/25/05
$29,880.83
8725
2.50000
$32,468.08
a. Outstanding principal
b Interest to 10/25/05
The above attorney's fees are estimated and are in accordance with
Defendant's agreements as set forth in the underlying Mortgage and Note.
13 Defendants also agreed under the terms and conditions of the Note that in
the event of default there under Defendants would pay, in addition to the
amounts set forth in paragraph 9 above, costs incurred by Members 1'( as a
result of the institution of these legal proceedings as well as additional interest
which continues to accrue at the rate of$4,9037 per day
14. As set forth above, Members I ,( has made demand upon Defendants to make
payment of all amounts due to Members 1 ,t under the Note and, as of the date
hereof, Defendants have failed and refused to make payment Df all such
amounts due to Members 1 ,( .
WHEREFORE, Plaintiff, Members 1'" Federal Credit Union, demands judgment
against Helen M, Geiling and Michael 1. Geiling in the amount of THIRTY-TWO
THOUSAND FOUR HUNDRED SIXTY-EIGHT and 08/100 ($32,468,08) dollars, plus
interest at the rate of $4.8592 per day, through the date of judgment on this Complaint
and at the legal rate thereafter, additional attorney's fees and costs of suit
Respectfully submitted,
Date f/) z. f'{'~,'-
(t00( ,! ).) f) /).'Q/
( . I~~ '- .. )I,~. ,fC
^-- ,j/ - " ',f',/, _,_
arl M. e ebohm, Esq.
Supreme Court 10 # : 59012
PO Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney for Plaintiff
_ .t...._~_'_4_'~.~..,.._._. ._.~~_,~"",,--~~~
Mewber~
"'1-~CLl-'tNU NU, 1;, U1~I-U::tUru:,
LOAN AND SEClJRllY AGREEMENT
UNtO. BORRO\IVER'S NAME ANCADOf!!'SS
PBDEKAl. . .,. HELEN M GElLING
~ooo Loul3e Drive, P,O Box 40 1'0 ROC'AAWAY OR
Med18nk;sbu.rg, PA17055 CAMP HilL, PA 17011
SOaAl. SEctlRITY NUMBER AA-rnOF INTt'REST ACCOtWr NUMBER
176-22-2115 5,990% 21Ml-ll~
Pll.lNCIPALAMClUNT LOAN NUMBER CO-ElOORO'MOR.SN.......E
'~l,ea.I~7 "00' MlC!1JILlGEIUNdo
DATEOFlOAN 8/112003 /M,lURlfYo.o.TE S1W2:Cl1$ 0F\XEO OVNUI>aL!;'
~N~~AL PERCENTAGE fiNANCE CHARGE: ,Amount Financed: The amount of Total of payments: The amounl
A : The cost of your credit as a The dallarat'OOo.J\'\l.l.M credit wi" crod\\ provlded to you or on your you will have paid after you have
yearly rate. . cost you. behalf. made all payment5QS sdleduled,
5.99% % e , 10,926.54 e , 31.694,67 , ,45.841.54 e
V..-Iabl" Raw; If your loan has a variable rat.. as indic.aled above the Annual Percentage Rate may Increase during the term of lhlsIrnnsacllon If the NlA
g~~~h~~~~~h~a=~~~ :i,u;,: ~ym~~,i~~ II win ntw::e 1m Ihan 10 lh 'W~~ valu~'A~eJ~~J r~:nl~~~~~IYw~un ~u11~n d~~ ~:y'~~~\~' ~~:Ie w~1 nrvlr
sa~ amol,lnl. For Examplfl, it your loan ...as fOf $5,!lOO at 15'1. (or 4e monlll" &1\d the Mnual f'ementa\le Rala ,nQ"euld by 2% slte.1 onl year, Ihl tlml of your loan WOlJld
jn~aSflbYlwomonlhs.
-rtJfer.ed Rite: Itchecked,lllefollowlng appJles 10 your 10,,":
.j AutrJmatito Ptr.mlnl Discountld Rall: Beoal,lse yOI,l ~ave "9reed 10 ma~ ~our ~C\Ul<<ld llIOOlt\ly ~ytrnlnl" thrwgh 1lTl automal'lc dlductlon from J:our Chad<ino/savinlls
A<:<:xmol. 'f')1I1 ANN AL f'i:RCEN1AGE RA,l: has t>een df$COunte by _20...., Tlle ANNUAL PERCENTA E RATE dlscloood ,OOVEt In the ANNUAL PER ENTAGE RA E bOx II
~:;u~::~~~~~I~~~~nl~~u~t~. ~~.i'~: :1:~~~~~s: I~~~~ U;f~ ";'::'d~;d a~~~~c ,f1~"::7b:;,~gre:~~~~~1 ~~~,~~~~:';.,n;,~~~~~Xl~~r R~oc::t,~
on a $5,000_00 loan for 80 monlh~ and you cease l/le autom;lllc paymenl ammgemlll1l, 'lour rail wUl Incretl5e to 10.:20%, ~wl\il\ll in1 9rtlI1\it>nt1l paymanl,
Va.b.bl. Rata Pf.tlI~d Loans. If tOU110an is a varlllb\e IBle loan Ind you qualify far a prefelTlld raIEt'.r.'l,Ir p.eft!r7&d dillcountls laken slthe ~me you lake oul your loan. Tills
InlUal ~rererred ANNUAl-. PERCEN AGE RATE wllllhen 'rIM'f ltCcordlng \0 dlan~es In thl ,nllloMu iscloSld ebovl). FO( examploly" avarlabll raIl loan's ini~1I ANNUAL
PERC NTAGE RATE is 12% at lI>e limfl you lake lhl loan, yourinlllfll preferrea A NUAl PERCE AGE AATE will bl NlA %, IJuT Jnlllal plllforted ANNUAl
PERCEr-rTAGE RATE wm thin val)' according to!tl. Index, as d1sdol.d In Ihe 'Va~at:>l. Rale- provision abo~.
Flxld Ratl Prslerred Loa"". If ~ou. 1.....\\ It. flllx&\i ",\elw.n and you quality for s plelerred rale. your ANNUAL PERCENTAGE RATE will be tIl. preferred ANNUAL
PERCENTAGE RATE diSclosed above for as long es YOUt prelelTlld status rema.ns in Iffect
Numb"rofPaymflnts Amount at Paymlnb Whe-nPsym.nbAreOuI Property Insuranct): You may oblain pro~rty
YOl,lr '" $382.02 Monlhlybeglnning 0911512003 i~~U~~ ~~~n~n(fo~;;J~~tl~~t ~~~~~~eCt1~lrhlg
Paymenl credit union you will PIlY
Schedule , $381.16 0011612013
wjllt>l. $
secUrily:COllalera,lsecur;n90ttlllrloanswllhlhecrsdllunion0thegOOdsorpropflrty 0 Oll1er
WIll al~o secure thll loan. You are glvjng a ,...c~MIy jntere51ln ./ beIng purdlased (Oesatb&):
YOllrsl1al1lsandlord9posltln thecredll union. and:
Late Charge; IfEt paymenlls lale by 10day' or more you wi~ Rllqul'lId C\'poslt Balane\': TI\II Annual Peroemage Rale doesl ~lllng Feu: l~ol}.f"illng Insurance'
be chMgea a la(alee of"'" ot yQur.c;heduled paymenl nol take Inlo accounl your rl'!qlllfed dllpO~ltbalanca, l{ lI\'\y. $
J>ro,l'Oy",,",*:~yWP..,.ofMlt1,YOU""rDlhlMrlOp8t.peI"lI<ly_ S""yo.r<D\Roldocun_kr8ll'y~1~<rlIlhoul~derlIul~""'Y"'qo.Wt<lrejl"l"'...-"Itin,",,_
-a.ffl\I;Inultimlll.t me~_lIOdprap&ymentl1llo1ds<llllpllr1Olllea
ITEMIZATION OF ,31,694.87
AMOUNT RWANCEO OF" Amount Paid to others on your behalf (Describe)
AMCJJNT GIVEN TO YOU DIRECTLY $ 3,000,00 ! \0."",," !? o><corroos..-rEIlc>w<"~.,,c ! '0
$ 7....... To &o.NK""'~ To
AMOUNT PAID 00 YOUR ACCOJNT $ 2.474.27 $ T.~_'lO To tlI9COVl;F\CJJll> , To
PREPAID Fl/'WCE ~ $ , To $ To
, To $ To
III , ,I , , I , L , , "
"""
MODEL
"'"
1.0. NUMBER
""
VAlUE
OTHER (Describe):
You Pledge-Shares
andlDf Deposlts of
16 ROCKAWAY DR
AMOUNT
,
ACCOUNTNUJ,lBER
'.0'''"
$
A:COUN1NUMeEI'l
YOll agree 11I81lha lerms Ind condWons In 1t11 dlldo.ure S1alllment and lhe loan and slO.JMly agf1ten1enls located on PIce 2 of \hIs dommel\\ ohllU 1l~ I<> Ihls lean_ 11 \heJ"flIS roora
lhan ana borrower. we agr.e thaI allltla coMd.<<l<\" 0{ \11'11 \Pan >/II\d SlItl.lr\ly agreemenls- lIO'Ieming this loan shall apply 10 bolh Joinlly and seVllralty. You aoIu1owledg8 IhEtI you nave
tecoived a copy of ttle 10M end &eCUrlly a~relments 8IId diSclosure slalemen!. Co-signor: Jf YOI,l ..... ~nlng u co-afgner, you 8c<oowll<lg. nlclrpl of the noUoe 10 eo-&lgnll
conlained on page 2.
8ORR::tr::.N71j H_,~ ~"
X;' , ISEAll'-.,.....-;-::
OCO-MAK.ER D'lY"HEROWNER' O"COSIGNER ~"
X ....,
o CD-MAKER o .O'HEROWNER O"CC-SlGNCR """
X ....,
~OOT
o CO-MAKER 'OTHER(7,'M!;R
X
o CO.MAKER 0 'cm'lER O\M'l2"R
X
!W '"co.SIGNER
, 0
O"CQ..SIGNER
~"
..",
"""
.'-'"
O"Co.SIGNER
~fE:.'n~.A~l.,';;,~~.\'f.:~,,;;~w:r.~~J=':-J'1:Ui"$:~).~~..I:::-''''.!~~~''~~I,::~~..J:~:~'r::~~~~.~.ls~":':.:;'~Y~"J:='mb~"J..""",,~,~~
g...'.nklt_.I."".....,..h/ehlu...h.-wl_b.tDIItloOl'I'low.
..:'_:\'&~.~'t'J~F,~~~t\J:>!GREtiW~N'sbi~.P.;N:CE;";.. ,..', "!'~ ':;:-':>";:';' '.';
~lrhEt~r: ';;f~k~gl~jhl~~~~~~.n~(~~)~n:;:~~d~~n;~ctplll,l~~~:' gr~~gl~'~~rf;;lih::,~~~~~ ~~:nu~'~~i:"~dn1:r:J~~I~h~~~~S~);!.~~i((,~,'; ~~~~~~~1"~
hme. I fWB).underSI8n;<l1l1..1 j[ joint ~fe Ulsurance Js sel<lcted, we must ba joln-tly am:! i~dMdl,l&Hy ~able unoor lll. \08\'\. ~ \ha'i <<-1ii91'1!ln and lIuar.llOlors are nc:teliglble for insurnnca.
Th~ fo lOWIng quutlons, 1 and 2, must be ..1'l1o..........tl to determlnl my (our) .!igibiJity for Insurance: ~f.r-~~>lT co.#ILJ~Nl
l, (Applicable 10 UhI Insurance """erage only) Are yoo undlr "!;Ifl 10 on Il'll. dale? 0 ex []I: 0
2_ jAppljCabte 10 disability coverage only) he you I,lnder Ige 611 on fhl. dlte AND are you preunlly working ootslde your home
In addt[I;:~ty~'\:'~O~;~,hlodu;s~~ b'gr.'Or:h:;~~I=Il~a;::~~:m~~!Q~ ~::~~d~~~~II~ ~~t~~~1 IIlglDllJty. 0 ~ [l 0
3_ ~~~;~ ~~~:fl:~~ ~~~ralldarri;~~:;~~ Id:~~~~~~: t'1.1g-lrlt!d lor: """c!!(. hurl allac~ or cQronal)' a~ dissase, 0 G 0 (3
My (Ol,lr) answers 10 the 8(}OW ql,lellllon.sam lrue to \h..besl 01 my {our! knowllldgl and belief. ltrn~ ~Iieen'.<<l~.t<<>"\oqul!ft\\on 1 or2,_W\d6l$lan<!lNIllhlspe.-on
~,n~.eIiglbJe for lncurs~ and will !lO\ be murad. If my ct>-appneanl or I WlIJWe. "Yes" 10 quesllon 3. we undsrsland that we!ll"(l eligible for lnstJral1CG! up 10 "" amoun! no! exceeding
Tfi'8iiffectivedelootmy (Ql,lrJ Insurance will belhll dale of lhl, appUClIllon
~~rl~I~'j~:~.~Ol<~r~~~.i~~~ ~~~:;:~~~.ro~ ~h~~~S~na~~r:~gl~~~~r~;J.'lf.o~t~:ri~:~rn~ :~~; :..nc~~~:;~~~~h:~:~~;:'~~O~ fr::~l:~~ i~I.~I~I:~~~a~rct ,.."~
crtmeaJldSubJecta.uChPGr'$onIOCrjmlna,andclv,'plnatllu.
Do not~llln 1111. IPPUcltion If any Ipplluble .plel. "I blan~. Till.. appllutfon wlU not 1HI uSld In a conwst if.ll appllC.llbl. I;lllnk spole... lI.vI nol been~1hI
~b~lrSsu~~C'dNt1~dQ~lfA-fi~&L~ioN~I~El!U'AYNitJGY'oBENWFrrs'fiAYABlE.
[! Yes 0 f\tI Slrigle Credit Life Total Prerrium ~. Yes 0 No Credit Disability Total Prenium
o Yell []; No join! Credit Ufa
Indicatewhichapplicanl(s): 0 AppHCllnl [iCo-Ap~lcanl i -5 $1,094.44 tndicaI6vmlchapp~c:ant($): 0 AIIpllcanl ~CO-Ap~iCllnl -5 $2,125.69
you....~<xty~lrI<!l)'~cl<overagooforwl\ld'I.ChoIrgelljndial&daotli."'plicdN'r'-
APPLICJ\NT"SSIGNAlURE OATEOF BlRTl1 OAT~
Paqet 012
COPI'RlGhl2002Io1ionesot..MuLooIC,",panl",Inc.AI~rN.""l<l
EXHIBIT "An
'....1
"'-1
~,..,.,~~_., ."'-'--..~..."-----_._-
BORROWER'S NAME
HELEN M GElLING
LOAN NUMBER
4560a
I "^~~"'"'
21067.03 8/1/2003
TI-lE WORDS "YOU: "YOUR" AND "YOURS" MEAN THOSE
ACCOUNT NUMBER
IN THESE AGREEMENTS, THE 'NORDS 'CREDlT UNION" MEANS't,!EMBERS f' FEDERAL CREDIT UNION.
NA/l.-lED AS 80RROVVER(S).
SECURlT1 AGREEMENT
LOAN AGREEMENT
Paym.J"f~s/FJ!1anc. ct1ar"r8: For value received, you promise, 10 pay, at
the Credll Urllon's Offll:9, a-I amounts due. All ps~nts sh<ll be made
pursuant t9 the disclosure statement on !lage 1 of this documenl. You
unoElrstancl thaI the flnpnce chpf!le ancllol~1 01 pS'(Il1!lf1ls shovm on page 1
of thiS doCtlment are based on tIie asswnption tha1 alllllSlallmant payments
will be made on the schedl,J,led we daW' and, if .you have qualified for
preferred rate, that YOLl continue 10 sati ~ ~n'41iqns of that greftrred
:arti~n1.Wni:~~? J.,.:~'te~~;\~~~~mt time It IS due, yo WI pay
AIIQcation QJ P"yme I1d Ad Itlonal Payments: PlMnerts an:! CIllCh
shall be app,Ued i/1the er: any amO.unts p03st duej {Jny fees or
chatges. OWIng, iI\clud ranee ~rermums, Ilcc:rueo Interest or
finance chargf;ls; 0 ndpal. avrnents made in addition to
regularly schE!'dUled all be app 1e(l11\ the S<ltne order.
Preferred Rate: If YOlJ qUltlifV for aDreferred rate <IS disdosed on .J1age 1 01
this. dOCl,lmen\ or in ill geparalr> preferred nue aclOelldurn'r:OU undelstand
1tJat you must meet the conditions disclosed to you in Qrder 0 Qualifv fortlle
preferred rate, aod m\,Jst contirwe to meet thoSll! condruans n ordei'"to keep
your preferred rate. Jf '{au fail to meet Inose coooilJor\$, your-rate Yv'in
Incn;ase, 1J\ereby extending too jemw. of vour loan. Y1;I\l pronise\l:.~
makinq payments and to meet a t obiiClalibns under thiS Agreement even If
rou no longer receive the preferred rale.
ate CharQU: If you make a late payment. you agree to pay.<lla!e. "'. iOlrg6
if one is dlsctos.ed on ?a';je 1 of this occumer\t. .. .'
proPlrty Insurance: If you obtain a IQan secured 9Y. a.motor vehicle or
olher angiblEl, prop~rtv you mlJst oblain lI1surance whlC/1 protects the credit
union from finanClal'loss. The amount and coverage of the property
insural"lOe musl hi!. ao;;:ce,p\ab\e ic \he- Cl<!,OI\ mien. Such a polio,o must.
prOVide at least fire, th~fl, pomblned additIOnal coverages aM collision
Insurance. It must contain a lOSS Payable dause endorsement naming the
credit union as lien )lolder. You ma~ obtain lhis ;nsur,lI'1cefrom any agent ot
~~~~y~hOlce and dlrecl the agent 0 send Il\e: cre<:ht IJnion a copy <If the
Debtor Rc-sponslbmty: You promise to notify credit union of any change in
your oameh address or employ,menl You promise notlo apply lor a loan If
Yg~rk~~~li~~ 1~;ji~~ot~a~~ t~g;>:~~j~h~a~~~n~To~~~~ ~~~;t
Yo Inform credll union of anY new information which relat~s to your abiJI'l; 10
f~fo~lt~u~ o~~~rJi~nCo~~afl~~~J6~t r~a~i~i~}~rS~rt~~T~e~~:
creclilslandmg,orcredilcapacily.
O~Ja~~~roci'nsna~o~i~n~~a~eduWd~tg,~~ if~~ o..P~~~~~~ Z~~ U~f
Security Agre~Jent: or {2) if you do not use the ~oney the credit union
10~ned~ou forllle purP.Qse S1r1ed in YOl.:r application; or (3) lIme credit
~~I~enaFlZ~Wb~ ~f ~~6fl~n:r~ W"aen~~s ~~~::eca;obfrJT1~'fjie?~~~gfil
you file a petition in bankruptcy, Insolv!:'1CV or receivership or ~re put
lI"I\lolunlar\\y into such prot;eed\rigs~ or (5) I"he conaleral, if a.ny/ gIVer! as
security for thiS accounl Is lost, uamllged or destroyed, or If I IS levied
afhainst, ~pachad or ~amishedd.or (7) If XOll do not t&aYi on ti~ any ofJ;our
~t ft{~r cr~ftc U~i~~'So 6~M:( B~~(~i~tV}u,oPrt~fanou~e ~lr~n~{i. \o~rl
ImmediatelY due and PBlable, and you must immediately Day to the credit
uniQn at tM.t time the !<It I unpaid wlance, B:j. well as the Fina,nce Charge
10 date, any late charges and costs of coilect on permitted under law,
If1Ch,ldi.OO reasonable allomey's lees, that the crEldll: Uflicn may i[lcur, up to
20% of the unpaid principal and nteres!. Costs Qf collection in~ud8 out are
not limited to, repossession fees, appraISals. environmen\al site
assessments, casualtv damaQe insurance covelEl, and attorneys feesfCf
any action taken by ah attom't:y in order to colle this loan or preseN9 or
Pffi'ect \he credit union's rights and remecflesj in udlng. without limil<ltion,
pre-sl,lil demands foJ pavmenl. pre-sui mediation or settl(;:rnent
neQ9tlations. )nvestiQatlan and assessment of the credit unions' nghts,
pafhcipation in banKruptcy cases, matters, and proceedlf1gs 0nciuainQ,
Wlt!"l~\ hm\ta\ICf\, fllinJ} p~ of clalm, pursutQi , n a ~ernen!:t
~gj~nc:t.i'~Rs 7he;;ti~?:te in C~dl~y t~n:U~~i1G ' m lion;:, a
payment), collateral dispos~on,non-bankruPtcy
actions, and appeals. The pnoopat bal-ance
lhecontractrate.
Statutory LIen: !fyou are in default federal law gives lhe credit union the
rhgeht;geagr~e\~'tt~~if~CUs~ ~~~a~~cg~~i~~~~ i~ Ydoe~~~l~~tm&i
union may exerCise this ngtit withoLl\ further notice to you.
~~~~ r!~Tsn~~d~~~fsn:b~~~~~~~JYo~r~Y~~~dng any of the ~red[t
IrrQ91,.\!f\f Pa'fments: lhe r;fed'l\ unIon may ll..CGepllaie pa_vmenls or Plrtlal
payrrent;:, even thouah mamed "payment In rull,.wllho0j rosing any 0 lhe
crcdit union rights uni'ler thiS agreement.
r;:~e~~~lfr~~~~ibr ~hi~~h~~~~~J a~: goe~~j6,f~gree~
either or iroth of yoo. ~he crlildlt union dQes nol hilVe to notitv you ~bl5J:1l!
agreement h3S not been paid. The credit union may extend (he !errT1S of
feaiprg~~bfli.~ 6:i.1~~~~~~~~ty without notifying or releasing you from
~~~~~~~~~:l~~f1.edr:gs(~~~: ll~o.slt~~~~:s'~ii~~~~'J,~n~:~~:;.s~~~ :~~
~;f:nl;~~.s cd~~\~n:~~ ':;~ '6rJafl1'a~~~ ~~r~:I~~dc~~~':'s ~J~:J:::t~ri::
reasQn.ble attorn'y',fM',lfl.lth.. credll union m.y incur, up 10 20% ofth.
unpilidprlnclp.l.ndlnt""'.t.NoU.norrtQhtto'Im-p~"..IlIM\Ol'I,"M.~.nd
d..pCl.lttlll.llapplytoanyofyours.hllTllswhlcl1m.ybG heldln.n'ndlvlduill
Reli,-.mll1tAccounr or "Keollh Plan."
ro"cuTlIplym.ntofthllloln.ndan.xp.ndllurelincurrad by tll. credit
~~~r ~ ~~n~:;}If~n~~ ;"~~~~ f:t~~:tl~~ ~~:=~~~
page 1 otthll d.x:um.nt. Th. uellrily interullnclud'l .Hlner...",
.ub.titUlionlll.ndll.ddi1lonltotll.ucurad propertY, procudl from any
Inlu...nc. on the s.curad property .nd.1I earnings ",cely..d frnm the
tleur.dprop.rty.
Croal-<:oll.taralizalion.Prop.rtygiv.n as ucurlty for this lo.norlorlny
"Ih.r lOin Borrower has with Ih. er.dlt union wlll ..cure III ImounD
Borrower own th' credit union now Ind In th.lullir.. HOWly.r, prop.rty
",curlng.noth.r d.bt will notueu... 11111 loan. If.ueltpfOl"lrty I.
l3orrow.('Iprlnelpll.l'..id...e..(ulll.....th.pn;lP1lrra.einlonnotleu.re
givan.ndlnYDth.rl"lllll...qulremenlaareullsfi.dJ,orare-non-purchase
,-oon.y houaellold good'.
YC>Il wi!! not e/1aogflll1f1loca~on 01, &ll~ ,~r transte( Il\e ~ uC\l6U y<lI.Il'1"~fI
lhecredllunlon'sprlorWlitleneonsent.
You wamrntlllBt ycu havc gOOll Iltle 10 Ille collalerat.frea DrfiU security Inleresls
e~cepl lhl1' 91"en to Ihe cnldil union and l:IJ(Q(lpt ror aoy Inlere~t or e non........
ma~er awner ot the collateral who haS signed the. agream.w In the. llIdl<:aw.d
p1..ce.
~~1~na: ~ri:r ~;':'S~~~pil: ~~~~I~$Ig~::~~~o~~ ~~u~~
~uitablfl shellef. '{ou aqree to el\\lCU~ lInaIId.ng llatlfMnt1; .no;! ~e~
ilgteemeol'rnlllndl1lents Btll1l! <;fl!dil unlon's Illqueat and will defend tha property
agalnsl adwrlIethird party claims.
~di~~n:lnh~~ ~~~nri": ~I~::{ ~~ ":'n~o:~r ~:Ofne~y~~~ ~~
~~~~ s;'~~~~~~ ~o~e aT~~~IO~~OU ~~~ft~n\~~ ~~il~~dl~~f
p,op&rty;lrerep..ld.llyoufalJtom..lOtaloSUCt'lknsurance,eredilunionmay,bul
I. nol requRd to, Dblwn Il1$uranea 01 Our own and addllleCQstof.tUl:l\loll\.
SUms owod. This eoSI will bear Inferest e\ the contract ,all U"t11 paid. You furihlr
Mslgn 10 lhe eredlt union the rI_llhttDrl(;fllyelneprocaBdsolanYlnlu",nCeon
suchProperty.anddlrectany,nsurertopaylhnseprooeadsdirecllyfocredll
union_ Yoululhorize till! credlturllon to endorse any checl< nrd'Bft pro\IJded as
ttr"'pTo~t:tI1lofl;lJchlnSl1rant:a.andapoly\hcseproceedsloll1e.umsowedto
Iha eredlt union.
~?~ ~~hn";e~U;:~~lll~I~~m~~~t ~~I~~rl;:~~ci~~(~~;~~:t~.,n"c:~~ICfI C.nler
YOu acknowledgelhat InSurMlle, or eny ,",lensIOlllh~reof. pieced bylhe aedif
union is W,lhoutb&lle.rit IOyQllllldiyjduall~t>ullsprimanlyforlheproleClion nlft.e
c:re-dJtunlon.
~it;;i~\~h~d\' ':I~, ~~ifo~ :~:'re~~nlc"Yll.~t ~J-JrU~al=~ I~:i~, ~~
agree to assign 10 credit uOlon wolhm ten (1C) days w!l8lever addih'lI\.1 IICUrtty
lhecredllunionl....lsisnecessaryloprol&etlheeredllunlonllgalnsfpoulble
m,.
Ifadel",ullllsdellnedlnlhCloanAo,",menl~OlJldoCCUr,lh"crednunionhas
lI1eaulhority, upon such d/lfaull. lo repcssus and sell 111. oc\lalefal;nlawf\J I
maM\!(. In such ease, \Ill credit union or Iha credit union's sulil0ri2&d
representatives may, atlhaCredllunioo'sopllon, eTller lhe pnl:ll,sas where lhe
coTIataral is 'Kepi ano;! lake possession. SUbject to appllcabie laws The credil
union has the ngMt to render lha plope;;y p1ed~ed ueoHat.ralunuubleand
~~it~~~a ~~:,,~~I~:;;I ~~eth~~:le~t a e~u~i~ c:~~e~~~~I~e~I~I~ ~~
oUmwiae~' oIll'1l> collaler8l, Il'1I> c.redll union will nDUty you 01 me lima and
~~;:;iruenl~~e~:I~: 0~"J:~:~~ete;~1~~e~6f~~ari~I\~I~~I~~~ ~~~i,s~~~o~'a~
collea rOfm you reasonable expenses Inwrred in 111" relaldng. hold!ng and
pot~act"9ll\a collatcrnlltl< aM anutgl''9 \II'" r.are oIlheCQ\\alaral. Thaaedll
union ma~ also collectreesonabl" atlorney's (e.1 and legale~pen"s. perTTlltl&d
by eppJICllble law. InClJrrad in CQnn"ctlon with disposition 01 Ih" property. Unless
you dalaull. you mayke-eppossusloncllhe proparty (coUaleral) deaa1beda .1d
use It In anylllw/l)1 mannerconslSlenlwltllthlll agrl!erntn\ or wltl\ lt1eln....renee
~~~reQ~1 ':'.."m:II:~al~~~e ul~d:h':~drr~~~~e~3:;t,~~t~,?;~ ~~~':n:~~~
Code and olher.pplleable leWI. and th.tlha Cflldlt union m8\l llse these nghlS
tn enforce payment If yOlJ def~ull. In lh81 event, you will althe cr(>dlt union's
~:s~ II:-;;::;:e o~~~(~:Jr s~~,;e~~~:'~g~~aR c:...'1rja~~To~o d~~d':s~
W~IV8 this detauH,lI will not ocnsmule waiver of any t>lher subsequent daraull3.
The Cradll union Is hereby ~ppolnled at; your Attome~ -in-Fact 10 ~erfotm a~~
Ilcta whl~h 1M. endlt union leela Sre newssary to prnlect tile ""1I8Ie,,,l.nd Ihe
securily ,nlerllstwhlch fhl" agreemafll crealas,
Ifll1ere IS more tIlan one tXlIlowllr, your obllgatlonsvnder Ihls Ig",eroonl are
joinl and seyer"l, MCII being equllH~ re"llonsibJe io fulll111M terms o( this
aQreement.
to This ""curlty ~greemenl not only binds you, bul your lIxecutorl;. adminlstrnlars.
helno.andassigns.
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You are being asket.i\o guaranlee \his deb\:. Think C8lltfully before you do. If the borrOWer doesn't pay ihe debl, you will have to. BB sure yOll can affClrd to
pay if you have 10, and that you wanl to accept this responsibility.
You may have 10 pay upto lhe full amounl oithe debt if the botTowefdoes t'lOt pay. You may also have to pay Jatefees orcoaeclion costs, which increase lhls
amount.
ihe CJedilor can colll'lct lhis deblfrom you wilhout tlrst trying 10 collect from the borrower. The credltorcan use the same colledionrnetlodsaganstyouthal
can be used against the borrower, SUch as suing you, garnishU1g your wages, etc. If this debt is ever In default, that fact may become a part of your credit
record. This nolice is not lhe contract thai rmtkes you liable fer the debt.
F.580.43
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July 18,2005
CERTIFIED MAIL NO. 70033110000024714337
RETURN RECEIPT REQUESTED
RE: Michael Geiling & Helen M Geiling
Mortgage Account # 27067 Loan # 03
Mortgage Premises: 16 Rockaway Dr., Camp Hill, P A 17011
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The mortgage held by Members 1st Federal Credit Union, (hereinafter we, us or ours) on your
property located at 16 Rockaway Dr., Camp Hill, P A 17011 is in serious default because yOU have
not made the Monthly payments of$20.31 for May 16, $377.53 for June 16, and $377.53 for
July 16,2005. The total amount now required to cure this default, or in other words get caught up in
your payments, as of the date of this letter is $775.37.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the
above amount of$775.37 plus any additional Monthly payments and late charges which may fall due
during the period. Such payment must be made either by cash, cashier's check, certified check or
money order, and made at Members 1st Federal Credit Union, 5000 Louise Drive,
Mechanicsburg, PA 17055, Attention: Stephanie McCreary.
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to
accelerate the mortgage payments, This means that whatever is owing on the original amount
borrowed will be considered due immediately and you may lose the chance to pay off the original
mortgage in Monthly installments. If full payment of the amount of default is not made within
THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your
mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the
sheriffto pay off the mortgage debt. Ifwe refer your case to our attorneys, but you cure the default
before they begin legal proceedings against you, you will still have to pay the reasonable attorney's
fees, even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which
may also include our reasonable costs. If yOU cure the default within the thirty day period, yOU will
not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings
have begun, you have the right to cure the default and prevent the sale at ,my time UP to one hour
before the Sheriffs foreclosure sale. You may do so by paving the total amount of the unpaid
Monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees
and costs connected with the foreclosure sale (and perform any other requirements under the
mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be
approximately NINETY (90) DAYS from the date ofthis letter. A notice ofthe date ofthe Sheriffs
EXHIBIT "B"
sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payments will
be by calling us at the following number (717) 795-5135. This payment must be in cash, cashier's
check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriffs sale will end your ownership ofthe mortgaged property and your
right to remain in it. If you continue to live in the property after the Sherin's sale, a lawsuit could be
started to evict you.
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
(YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO
THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS,
CHARGES AND ATTORNEY'S FEES AND COST ARE PAID PRIOR TO OR AT THE SALE,
AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED).
CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCE THIS RIGHT MIGHT
EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
If YOU cure the default, the mortgage will be restored to the same position as if no default had
occurred. However, you are not entitled to this right to cure your default more than three times in
any calendar year.
Sincerely,
~W~e
Stephanie McCreary
Collections
IMPORTANT NOTICE TO HOMEOWNERS
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
PLEASE READ THIS NOTICE. YOU MAY BE ELIGD3LE FOR
FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS
July 18, 2005
TO:
FROM:
RE:
Michael Geiling & Helen M. Geiling
Members 151 Federal Credit Union, 5000 Louise Drive, Mech;micsburg, PA 17055
Account # 27067 Loan # 03
Your mortgage is in serious default because you have failed to pay promptly installments of
principal and interest, as required, for a period of at least sixty (60) days. The total amount of the
delinquency is $775.37. That sum includes the following: $20.31 due for May 16, $377.53 due
for June 16, and $377.53 due for July 16, 2005.
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you
comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983
(the "Act"). You may be eligible for emergency temporary assistance if your default has been
caused by circumstances beyond your control, and if you meet the eligibility requirements of the
Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice.
It contains an explanation of your rights.
Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty
(30) days from the date of this Notice. During that time you must arrange and attend a "face-to-
face" meeting with a representative of this lender, or with a designated consumer credit
counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to
otherwise settle your delinquency. This meeting must occur in the next thirty (30) days.
If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency
identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty
(30) days after the date of this meeting.
The name, address, and telephone number of our representative is:
Stephanie McCreary, Members 151 Federal Credit Union
5000 Louise Drive
Mechanicsburg, P A 17055
(717) 795-5135
The name and address of a designated consumer credit counseling agency is:
Consumer Credit Counseling Service of
Greater Harrisburg
2000 Linglestown Road
Harrisburg, PAl 7110
(717) 541-1757
EXHIBIT "COO
It is only necessary to schedule one face-to-face meeting. You should advise this lender
immediately of your intentions.
If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you
have the right to apply for financial assistance from the Homeowners' Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners'
Emergency Assistance Application with the consumer credit counseling agency listed above. An
application for assistance may only be obtained from a consumer credit counseling agency. The
consumer credit counseling agency will assist you in filling out your application and will submit
your completed application to the Pennsylvania Housing Finance Agency. Your application
must be filed or postmarked, within thirty (30) days of your face-to-face meeting.
"It is extremely important that you file your application promptly. If you do not do so, or if
you do not follow the other time periods set forth in this letter, foreclosure may proceed
against your home immediately and you will forfeit your eligibility for assistance".
Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act.
"It is extremely important that your application is accurate and complete in every respect".
The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it
received your application. During that additional time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified
directly by that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 211 North Front Street, P. O. Box
15530, Harrisburg, P A 17105-8029. Telephone No. (717) 780-3940 or 1-800-342-2397 (toll free
number).
Enclosed also is another notice from this lender under Act 6 of 1974. That notice is called a
"Notice of Intention to Foreclose Mortgage". You must read both notices, since they both
explain rights that you now have under Pennsylvania law. However, if you choose to exercise
your rights described in this notice, we cannot foreclose upon you during that time. Also, if you
receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot
be foreclosed upon while you are receiving that assistance.
Sincerely, ~
~J1Q
Stephanie McCreary
Collections
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CERTIFIED MAil," RECEIPT
(Do verage Provided)
Stephanie McCreary
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!2 O.h.. Helen M Geiling
1- ..':>treet
0' eo 16 Rockaway Dr.
ci,y,., Camp Hill, PA 17011
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Return Redept Fee
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Total Po:stage & Fees $ ~ .y ::l-- I
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KARL M. LEDEBOHM
A TTORNEY -AT LAW
P.O. BOX 173
New Cumberland, P A 17070-0173
Phone: 717-938-6929
Fax: 717-932-0317
September 22, 2005
(Via Certified and regular mail)
Michael 1. Geiling
3601 Brisban Street
Harrisburg, P A 17111
Helen M. Geiling
16 Rockaway Drive
Camp Hill, PA 17011
RE: Members 1 st Account No.: 0000027067-03
Dear Ms. Geiling:
Dear Mr. Geiling:
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 sl Federal Credit Union ("Members 1st") has requested my office to
collect the amounts due to Member's I st 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 August 1, 2003 in the original principal amount of $31 ,694.87 (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 st hereby accelerates all amounts due to Members 1st
under the Account and the Note and hereby demands the payment of all amounts due to
Members 1 st under the Account and the Note in the amount of $30,770.07 itemized as
follows:
1. Principal
2. Interest to 9/22/05
3. Legal Fees
4. Total due to Member 15t as of 9/22/05
$29,828.87
61.20
880.00
$30,770.07
EXHIBIT
"EI'"
Interest continues to accrue on the above obligation at the rate of $4.8867 per day.
If you fail to deliver payment of the $30,770.07 together with additional interest
to the date that payment is delivered to Members I st within thirty (30) days of the date of
this letter, Members I st 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 st.
Nothing herein shall constitute or be construed as an agreement on behalf of
Members 1 st 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
1 st . Nothing herein shall constitute a waiver of any rights or remedies which Members
I st 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
andlor the right to commence foreclosure proceedings with respect to the real estate
known as 16 Rockaway Drive, Camp Hill, P A 170 1 I. Nothing herein shall constitute an
agreement on behalf of Members I st to postpone or extend the maturity date under the
Note.
Members 1st looks forward to the payment of the $30,770.07 together with
additional interest to the date that payment is delivered to Members 1 st on or before
October 22,2005.
Very trUly yours,
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CC: Stephanie McCreary, Collections Officer
NOTICE
This letter is an attempt to collect a debt.
It you dispute the validity ofthis debt, or any portion thereoj~ and you contact the
undersigned within thirty (30) days after receipt of this Notice, you Mil 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.
U.S. Postal Service",
CERTIFIED MAIL" RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
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VERIFICA nON
I, Stephanie McCreary, Collections Officer for Members I" Federal Credit
Union, being authorized to 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 IS Pa. C SA Section 4904, relating to unsworn falsification to
authorities.
Members I" Federal Credit Union
BY~1UtlL a;lLULr
Step am cCreary
Collections Officer
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-05622 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT
VS
GElLING HELEN M ET AL
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
GElLING HELEN M
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, GElLING HELEN M
16 ROCKAWAY DRIVE
CAMP HILL, PA 17011
HOUSE VACANT AND POSTED FOR SALE.
NO FORWARDING ADDRESS ON FILE AT POST OFFICE.
Sheriff's Costs:
Docketing
Service
Not found
Surcharge
Postage
18.00
14.40
5.00
10.00
1.11
48.51
So a:~~~
-:;~~~ -------
R. ThomasCKline
Sheriff of Cumberland County
KARL LEDEBOHM
11/17/2005
Sworn and subscribed to before me
this
L. !!-
day of ;'Jjw~.<-<--
OM, it~
{hI ,
Pr@'thonot . . y
SHERIFF'S RETURN - OUT OF COUNT"
CASE NO: 2005-05622 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT
VS
GElLING HELEN M ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
GElLING MICHAEL J
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On November 17th, 2005 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Dauphin County
6.00
9.00
10.00
35.25
.00
60.25
11/17/2005
KARL LEDEBOHM
So answers: --~ /c;7 . ~
~~~--
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this
LEe.
day of ~rt#L~
,)/Yu5 t~
~{L
Pr nota y
.. ./
In The Court of Common Pleas of Cumberland County, Pennsylvania
MEmbers 1st Federal Credit Union
vs.
Helen M. Geiling et al
SERVE: Michael J. Geiling
NO.
05-5622 civil
Now,
November 2, 2005
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
~~~~J'
Sheriff of Cumherland County, PA
Affidavit of Service
Now,
, 20_, at
o'clock
M. served the
within
upon
at
by handing to
copy of the original
a
and made known to
the contents thereof
So answers,
Sheriff of
County, P A
Sworn and subscribed before
me this day of , 20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
@flit~ of tltr ~4priff
William T. Tully
Solicitor
Charles E. Sheaffer
Chief Deputy
Mary Jane Snyder
Real Estate Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
MEMBERS 1ST FEDERAL CREDIT UNION
vs
County of Dauphin
GElLING MICHAEL J
Sheriff's Return
No. 1880-T - -2005
OTHER COUNTY NO. 05-5622
AND NOW:Novernber 10, 2005 at 7:49AM served the within
COMPLAINT
upon
GElLING MICHAEL J
by personally handing
to MICHAEL GElLING DEFT
1 true attested copy(ies)
of the original
COMPLAINT and making known
to him/her the contents thereof at 3601 BRISBAN ST
HBG, PA 17111-0000
Sworn and subscribed to
So Answers,
Jf~ .
,he"" 0' D.U~~~~
By
before me this 14TH day of NOVEMBER, 2005
~A/
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. l, 2006
Deputy Sheriff
Sheriff's Costs: $35.25 PD 11/03/2005
RCPT NO 211981
GM
MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL V MilA
PLAINTIFF
Vs.
NO. 05-5622 Civil Term
HELEN M. GElLING
MICHAEL J GElLING
DEFENDANTS
. CIVIL ACTION.LA W
PRAECIPE TO SETTLE. DISCONTINUE AND END
To the Prothonotary
Please mark the docket ill the above captioned matter settled, discontinued and
ended.
Respectfully submitted,
Date January 3,2006
jf;]
.... /
arl M. . ~ ebo m, ~s .
Supreme Court ID # . 59012
PO Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney fix Plaintiff
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