The URL can be used to link to this page

Home My WebLink About05-6324 SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO, OS" - f.s,.J.~..'{ CIULIE.f2-~ ANDREW C, VAN GORDER : CIVIL DIVISION - LAW Defendants 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 INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 AVISO U5TEO HA 5100 OEMANOAOO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tamar accion dentro de 105 proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente 0 por media de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demand as presentadas aqui en contra suya, Se Ie advierte de que si usted falla de tamar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamacion 0 remedio solicitado par el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos importantes para usted, USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO, SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALlFICAN, CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (71 7) 249-3166 SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO. O~ - c,,3.2 'I C~o'lL~82-~ ANDREW C. VAN GORDER CIVIL DIVISION - LAW Defendants 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 ELEVEN THOUSAND SIX HUNDRED FIFTY ONE DOLLARS AND FIFTY THREE CENTS ($11,651.53), along with interest thereon at the rate of 12,9% from December 5,2005, upon a cause of action of which the following is a statement: I, The Plaintiff, SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, is a corporation organized and existing under Federal Laws, having its principal office and place of business at 3850 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania, 17011-7809, 2. The Defendant, ANDREW C, VAN GORDER, is an adult individual residing at 2417 Wooded Acres Drive, Waco, McLennan County, Texas 76710-1559, Defendant is employed at Baylor University, 3, On or about November 26,2004, Defendant borrowed funds from Plaintiff at the rate of 11,2% per annum. A true and correct copy of said November 26. 2004 Open End Voucher and Security Agreement is attached hereto. marked Exhibit "A" and made a part hereof. F:\USER\ROBlN\CCP&DJ CMPSICCP COMPLAINTSIsvcu 31909,wpd:08Dec05 2 .,- 4, Defendant has failed, neglected and/or refused to make payment as promised on the aforesaid Open End Voucher and Security Agreement. 5, 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 Three Hundred Forty Two Dollars and Seventy Two Cents ($342,72), as shown on said Plaintiffs Statement of Account hereto attached, marked Exhibit "8" and made a part hereof. 6, 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 Nine Hundred Twenty Three Dollars and Sixty Five Cents ($1,923.65) have been added to said account. 7. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendants, the sum of ELEVEN THOUSAND SIX HUNDRED FIFTY ONE DOLLARS AND FIFTY THREE CENTS ($] 1,651.53), along with interest thereon from December 5, 2005, at the rates as agreed upon between the parties. Respectfully submitted, 7 IMBLUM, P.C. v / Robert D. Kodak, Esquire 407 North Front Street Post Office Box #1 ] 848 Harrisburg, P A 17108-1848 (7] 7) 238-7151 Attorney ill No, ] 8041 Attorney for Plaintiff F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\svcu 31909.wpd:15Dec05 3 (~~ \u SUSQUEHANNA VALLEY FEDERAL CREDIT UNION 3850 Hartzdate Drive Camp Hill. PA 17011-7809 (717) 737-4152 11""'\\ A,:li.h'LJ~lt'S:- ,'!Con: "' 1.\..4...lllll~ --.--' -.... .~_ ... / -----' ..-'ii) SCRRQI",:,,,! 1 ADDRESS PO BOX 5992 WACO, TX 76708 BORROWER INFORMATION ACCOUNT NUMBER 11408.5 Open-End Voucher and Security Agreement I 5-)'lP'J "I~:;; . \j':"ME Andrew C. Van Gorder AMOUNT REQUESTED ; 2,999,00 DATE 11/26/2004 HOME TE~EPHONE NUMBER (717)-258-0878 SOCIAL SECURITY ,\lU:'.13Efl 1B6.40.2723 PURPOSE: BALANCE FOR AUTO PURCHASE 80P.."lOWER 2 NA.v1E ACCOUNT NUMBER CJ<;PQSIT CHECK IN ACCOUNT NUM9!:Ft'OTHER a2,"':;,:\",o.8 2 ADCRESS SOCIAL SECURITY NUMBEF: :,..E':K ?AYABLE ~O 2o,~"=t:)'//ER ' Efvl?LOYER NAME BAYLOR UNIVERSITY REPAY~.lENT METHOD: Cash WORK TELEPHONE NUMBER :lATE HIRED 08/01/2004 GROSS MONTHL Y SALARY $5,558,33 ,'3~';:l'>C".' e" : EI.l"'LDYErl NAME WORK TELEPHONE NUMBER DATE HIRED GROSS MONTHL Y SALARY $ NOTICE: VOU DON'T HAVE TO INCLUDE INCOME FROM CHILD SUPPORT. SEPARATE ~.~:l,:~H=NANCE, OR ALIMONY UNLESS you WANT THE CREDIT UNION TO CONSIDER IT. SOURCE OF OTHER r~ICO\ilE OT~E~ MNJTHL Y INCO~,1E WHAT YOU OWE LIST ALL OE8TS OTHER THAN TO THIS CREDIT UNION IAttachadditional sheet Is) if necessary.! PRESENT BALANCE MONTHLY PAYMENT CURRENT INTEREST RATE PRINCIPAL RESIDENTIAL NAT CITY JT RENT IN TEXAS TOYOTA MTG 95,600,00 642.00 5.709.00 57.00 400,00 21,000.00 350.00 SUBSEQUENT ElECTION FOR VOLUNTARY PAYMENT PROTECTION '0 " " You can now voluntarily elect to become 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. It you need a copy of the Insurance Certificate, just ask. By signing below, you authorize us to add the charges for the ,insurance to your outstanding balance each m(,nth. Coverage election applies to the entire balance on .this subaccount. Insurance rates are subject to cnange. YOU ELECT THE FOLLOWING: NO Single Credit Disability NO NO Single Credit Life NO Joint Credit Life COST PER $100 OF YOUR MONTHLY lOAN BALANCE SEE SEPARATE RATE SCHEDULE .070 .123 NAME OF INSURE01Sl REPA YMENT TERMS I >- D~ll'( PERIODtC RATE ANNUAL PERCENTAGE RATE INTEREST RATE IS: OTHER FEES lAmount aM Description) NEW BALANCE THIS SUBACCOUNT ...J .030685% % 11.20000 % Fixed $ N/A $ 9,864.15 z 0 MOUN7 ADVANCED PA YMENT AMOUNT DATE DUE PAYMENT FREQUENCY LINE OF CREDIT LIMIT REMAINING LIMIT W $ 2,999.00 $ 216.38 01110/2005 Monthly $ $ '" :::> Your term Wl L l be approximately 60 pa~nts, which may be more or less, depending on whether you prepay, have 2 Late payments, or insurance is added, etc. 0 2 SECURITY OFFERED I X I CONSUMERS' CLAIMS AND DEFENSES -- IF CHECKED SEE PARAGRAPH 6 FOR NOTICE I :::> I- T,-.e ,lID'JANCE IS SECURED BY YOUR SHARES. ALL PROPERTY SECURING OTHER PLAN ADVANCES AND LOANS RECEIVED IN THE PAST OR IN THE FUTURE, AND THE ~OLLOWING 10 P;:;OPER7YMODEL YEAR I,D. NUMBER VALUE KEY NUM8:.R w SIGNATURE a:: 0000 $ U $ a:: $ 0 $ Ll. PLEDGE OF SHARES ACCOUNT PLWGE OF SHARES ACCOUNT AND/OR DEPOSITS $ NUMBER AND/OR DEPOSITS $ NUMBER ........ ... .. . . .... . SIGNATURES .. .. . .. .. ... .. i .... I By signing below. by endorsing the proceeds check or by using the amount advanced and deposited into your share/share draft account you agree: 1. To make and be bound by the terms of this Security Agreement including the cross collateral clause: 2. The above information is troe and correct and the Credit Union will rely on that infonnation and your credit report to make a credit decision: 3. To make payments as disclosed above in accordance with the terms of your Plan. /', x //'1 , v IS' II ISEAll ;l'J"'''',,~,' '~p : Sl~,,':"", LRE TURE ~ATE x IS' (SEAL! SIGNA-URE OOW~IER OF COLLATERAL (Other than a 6orroweO ER OF COLLA TERAl (Other than a Borrower) DATE 1:1 CUNA ~,1UTUAL GROUP. 1980. 82. 84.86.89,98.99.2000.02 ALL RIGH y VXX0651LASERI Susquehanna Valley Federal Credit Union I ~ate 11/26/2004 Andrew C. Van Gorder 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 jf 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 "FeU". 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 if 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 -- 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 -- 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 necesS8ry 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 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. CONSUMERS' CLAIMS AND DEFENSES NOTICE The folfow;ng paragraph applies only when the box on page one is checked. lQA~UNf.R NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST TetE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF, RECOVER Y HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER, 7. PROPERTY INSURANCE. TAXES AND FEES -- You must maintain property insurance on all property that you give as security under the Plan. You may purchase the property insurailc~ from anyone you choose who is acceptable to the Credit Unior--.. The amount and coverage of the property insurance must Of! acceptable to us. You may provide the property insurance throuqh a policy you already have, or through a policy you get and pay for. You promise to make the insurance policy payable to LIS :'!nd to deliver the policy or proof of coverage to us if asked to do so. If you cancel your insurance and get a refund. we have a right to the refund. If the property is lost or damaged, we can use the insurance settlement to repair the property or apply it towards what you owe. You authorize us to endorse any draft or check which may be payable to you in order for us to collect any refund or benefits due under your insurance policy. You also promise to pay all taxes and fees (like registration fees) due on the property. If you do not pay the taxes or fees on the property when due or keep it insured, we may pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the advance and you will pay interest on those amounts at the same rate you agreed to pay on the advance. We may receIve payments in connection with the insurance from a company which 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 loon 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 will 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 following 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) ""C65 (eG" .J @ C:J'\A MUTUAL CROUP. 1980.82.8".86,89.93.99.2000.02, ALL RIGHTS RESERVED CREDIT UNION COPY , . I~~squehanna Vulley Federal Credit Union '--- _. Andre~ C. Van Gorder 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 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 avail<'lble to you to claim. After INe 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 anI,' public sale or the date after which a private sale will be held. O~lr 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, Of, if applicable, at the default rate disclosed on the Addendum, until that amount has been paid. Date 11/26/2004 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 ANO 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. 14, 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. THE PROPERTY DESCRIPTION ON PAGE ONE IS PART OF THIS AGREEMENT, NOTICE: SIGN THIS AGREEMENT ON PAGE ONE, RfQUESTEO: MEMBER PAYS PREMIUM FOR: FOR CREDIT UNION USE ONLY !:lATE APPROVED SIGNATURE LIMITS. X APPROVED DENIED (Adverse AClion Notice San!) $ 11/26/2004 I_.~M! a;:::ICER COMME~TS. r;,';.\ ~,_:p~S x DATE CHECK NUMBER: PLAN!SUBACCOUNT NO.: LINE OF CREDIT OTHER $ $ BRANCH NUMBER: PROCESSED BY: lNS OTHER DEBT RATIO/SCORE BEFORE AFTER $ 29.96200 % x DATE @ CUNA MUTUAL GROUP, 1980. 82, 84. 86. 89, 98, 99. 2000. 02. ALL RIGHTS RESERVED CREDI T UN ION COPY VXX065 (LASER) SUSQUEHANNA ~"""- VALLEY FEDERAL CREDIT UNION Statement of Account Date: December 5, 2005 Maker: Andrew C. Van Gorder Co maker: None Home Address: 2417 Wooded Acres Drive Waco, TX 7671 0 Home Phone Number: 254-296-1032 Our Account Number: 11408-5 Your File #: 31909 Maker Social Security # 186-40-2723 Co maker Social Security: # None Principal Amount Owed Interest Owed Penalty (20 '/'1 of Principal& Interest) Late Payment Fee: Total Amount Claimed: $9,385.16 $322.72 $1,923.65 $20.00 $11.651.53 ~-j'\ I ~ \\ ~ '-,----/ 3850 HARTZDAL LOCAL: (717) 737-4152 ,PA 17011-7809 54 FAX: (717) 737-0589 (~ \,-y DEC-08-2005 11:46 SUSQ. VAL. FCU 7174412022 P.01/01 VERIFICATION I. SUSAN ], W ASILITTON, LOANS/COLLECTION MANAGER of SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, verify that the statements made in the aforegoing document are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. ~4904. relating to unsworn falsification to authorities. SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION /~!r/([JS- . , Loans/Collection Manager Dated: 31909 ':\USERIROBINICCP&DJ CMPSICCP COMPLAlNTSI,vcu J1909.wpt\:O&DecOS 5 TOTAL P.Ol D {g. 1:J U1 8 \ ~ ~ " ",'J " U( , ,."l I ........ ~ ~ () ~ i'" ~ ,..- .!:::. r-,.) ~ -lJ .......() -F -,.- .. ) ':') - SHERIFF'S RETURN - U.S. CERTIFIED ['!AIL CASE NO: 2005-06324 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL VS. VAN GORDER ANDREW C R. Thomas Kline Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,VAN GORDER ANDREW C by United States Certified Mail postage prepaid, on the 13th day of December ,2005 at 0000:00 HOURS, at 2417 WOODED ACRES DRIVE WACO, TX 76710-1559 , a true and attested copy of the attached COMPLAINT & NOTICE Together with The returned receipt card was signed by TIM MACHLAN 01/05/2006 on Additional Comments: Sheriff's Costs: Docketing Service Postage Surcharge 18.00 4.42 .39 10.00 .00 32.81 So answers:..' --'J ___ c;;>-- -~~/':;:;->-'~:'~":';' ,,- -:..,.,...... /~'r/ L / ./" " R. Thomas-Kiine Sheriff of Cumberland County Paid by KNUPP KODAK IMBLUM on 01/11/2006 . Sworn and subscri~ed to before me this ol'ie day o( 1,4 '~'!!:tfil) SENDER C;UfI;IPU:./f:: {HI::' ;:.t:>..- IIViv . Complete nems 1. 2. and 3. Also complete item 4 If Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece. or on the front If space permits. 1. Article Addressed to: And~ C. Van Gorder 2417 Wooded Acres Drive Waco, TX 76710-1559 ~ ~ ~ct~l(u\ ~.nt D Addressee C. Date of Delivery (. B. R D. Is delivery address different from item 11 If YES, enter delivery address below: 3. Service Type ....Certlfied Mall 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes PS Fonn 3811. February 2004 7005 0390 0003 2635 0449 10259S-02-M-154Q DomestIc Return Receipt ~()t .. SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2005-06324 CIVIL ANDREW C. VAN GORDER : CIVIL DIVISION - LAW Defendants TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAEOPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) ANDREW C. VAN GORDER, 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: Interest from December 5,2005 at the rate of 12.9% per annum $11,651.53 $1,346.43 $12,997.96 Amount claimed in Plaintiffs Complaint Total It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant(s) and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached. By Robert D. Kodak, Attorney for Plaintiff DATED: ():j. ~~ J..Q:)b Judgment entered and damages assessed as above. ( 1~ ... Robert D. Kodak Gary J. Imblum LAW OFFICES OF KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, P A 17108-1848 kki.law@venzon.net website: kki-law.com fILE CtI_~~9 Ul.~e 717.238.7158 October 3, 2006 ANDREW CHRISTIAN VAN GORDER 2417 WOODED ACRES DRIVE WACO TEXAS 7671()"1559 RE: Susquehanna Valley Federal Credit Union VS: Andrew C. van Gorder No. 2005-06324, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 31909 Dear Mr. van Gorder: 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, KODAK & IMBLUM, P.C. Robert D. Kodak THIS LEITER IS AN ATTEMPT TO COLLECf A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDK/kqb enclosure cc: MATT WHITE COLL SUPERVISOR SUSQUEHANNA V ALLEY FE 3850 HARTZDALE DRIVE CAMP HILL PA 17011 #11408-5 ON A . . . FIL E. rtnoy ~ LnJi SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2005-06324 CIVIL ANDREW C. VAN GORDER Defendants : CIVIL DIVISION - LAW IMPORTANT NOTICE TO: ANDREW C. V AN GORDER Defendant(s) DATE OF NOTICE: OCTOBER 3, 2006 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRfITEN 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 THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOUMA Y LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERA T ONCE. IF YOU 00 NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249-3166 !'i:'x............... ~ .. . .... . ! ~ "4- t ;:J \ -:C ~ () ~ (J - 4 r ---- ~J ~ J:: ~ t ~ 0 C,;,J Lv r ~ ".. ~ [ ~ r a ~, ...n\;:~' ;'l' \ ~' --~ --;0' cT]. ~c:; '~\~;, "2 ~ -1:n \'I1r- -nl:2J N ',-~ 2 '-[ 0.... "J"e;> -:~ ';11 -;i. ';;,~ ~, _ S:\ ,_ 'P" .r;: ':2, 0.... ~ ~ o CJ. ~ '" .... SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2005.06324 CNIL ANDREW C. VAN GORDER : CIVIL DIVISION - LAW Defendants TO: ANDREW C. VAN GORDER, Defendant(s) You are hereby notified that on ~+ ,,2..~ ' 20~e following Gudgment) has been entered against you in the above-captioned case. Tud&ment entered in the amount of $12,997.96. DATE: l~/~.f(J(p I d~ I hereby certify that the name and address of the proper person(s) to receive this notice is: ANDREW CHRISTIAN V AN GORDER 2417 WOODED ACRES DRNE WACO TEXAS 76710-1559 AI ANDREW c. V AN GORDER, Defendidol a Defendidosl as Por este medio se Ie esta notificando que el de del 2005, eljla siguiente(Fallo) ha sido anotado en contra suya en el caso mendonado en eI epigrafe. PECHA: Protonotario Certificao que la siguiente direcdon es Ia del defendido I a segun indicada en el cetificado de residenda: ANDREW CHRISTIAN VAN GORDER 2417 WOODED ACRES DRNE WACO TEXAS 76710-1559 Abogado del Demandante