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Home My WebLink About05-6670 SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, : NO, OS' - L,l./ID C-wll~~ SAMUEL J. BERNARD, : CIVIL DIVISION - LAW Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff, You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249-3166 SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, : NO, OS - &1...10 C'LU',CT8Li SAMUEL J. BERNARD, CIVIL DIVISION ' LAW Defendant COMPLAINT The Plaintiff, SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, by its attorneys, KNUPP, KODAK & IMBLUM, P.c., brings this action of Assumpsit against the Defendant to recover the sum of TWENTY TWO THOUSAND FIVE HUNDRED THIRTY FIVE DOLLARS AND THIRTY CENTS ($22,535,30), along with interest thereon at the rate of 12,9% per annum from November 30,2005, upon a cause of action of which the following is a statement: 1, The Plaintiff, SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, is a corporation organized and existing under Federal Laws, having its principal office and place of business at 3850 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania, 17011-7809, 2, The Defendant, SAMUEL J, BERNARD, is an adult individual residing at 343 North Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant, did apply for credit with Plaintiff through its Loanliner Program, A true and correct copy of the Loanliner Application executed by the Defendant is attached hereto, marked as Exhibit "A" and made a part hereof. F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\svcu31957. wpd: 19Dec05 4. On our about April 16, 2004, Plaintiff did issue Defendant a loan for the purpose of purchasing a mobile home in the amount of Sixteen Thousand One Hundred Ten Dollars ($16,110,00), A true and correct copy of the Loan and Security Agreement is attached hereto, marked as Exhibit "B" and made a part. hereof. 5, Said mobile home, a 1984 Hauser, VIN THPAI170, Title Number 36640205303, was posted as collateral for the aforesaid loan, Said collateral has been completely destroyed and is of no economic value whatsoever, 6, Defendant has failed and/or refused to made payments as promised and is therefore in default of said loan agreement with the Plaintiff. 7. 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 Eight Hundred Eighty Eight Dollars and Thirty Six Cents ($888.36), as shown on said Plaintiff's Statement of Account hereto attached, marked Exhibit "C" and made a part hereof. 8, Due to Defendant's default and pursuant to the terms of the Loan and Security Agreement, attorney/collection fees in the amount of Four Thousand Five Hundred Fifty Dollars and Twenty Three Cents ($4,550,23) have been added to said account as shown on said Exhibit "C", 9, Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof. F:\USER\ROB1N\CCP&DJ CMPSICCP COMPLA1NTSIsvcu31957.wpd: 19Dec05 3 WHEREFORE, Plaintiffbrings this suit to recover from Defendants, the sum ofTWENTY TWO THOUSAND FIVE HUNDRED THIRTY FIVE DOLLARS AND THIRTY CENTS ($22,535.30), along with interest thereon at the rate of [2,9% per annum from November 30,2005, Respectfully submitted, KNUPP, KODAK & IMBLUM, P.c. #~ Robert D, Kodak 407 North Front Street Post Office Box # 11848 Harrisburg, P A 17108,1848 (717) 238-7151 Attorney ill No, 18041 Attorney for Plaintiff F:IUSERIROBINICCP&DJ CMPSICCP COMPLAINTS\svcuJ 1957 ,wpd: 19Dec05 U~~'lb-Z003 09:54 ~" SUSQUEHANNA VALLEY I r ~ FEDEP.AL CREQlT UM10W \ 3850Hart2daleDnve \. ,,~ Camp HW, p!\ 17011-7"'" "'--- PH) 737-4152 SUSrJ VAL. feu M"uried Appkcants; May apply tor a separate aCCOl1nt 7174412022 P,02 Kr.~J;"'lfl~~ _= ~J~f~ Application I tndivtdual Credft: You must complete the Applicant section about y;:,urse[f and: the Othef section about your s.p:JLlse if: 1. you live in or the property pledged as col!ateral is located in a communiry property state (AI(, AZ. CA., to. l..\. NM. NV, TX. WA, WIL 2. your $;:>OU$C 1,N;l! use the aCCOuf1t. or 13. YO'J <Jr~ ',""lying on YO!.lf s.P0\J~~'::; inr:nme <=J~ ~ h;:J."j,. for repayme~r. H you are relying on jncome from <}limoolY, cl1ild support, or SepM<lte rn(:l;"ll~nal1::e. I complete the Other section to the extent possible about the person on whose payments you are' relying IJoint Credit: If you are applying wittl another person. complete the A.pplteant 30d Other sections. Guarana>>": Ccmpktc the Other ~ction if yOu arc 0) g,...:H3ntor on 3n 3C'"'--o~nt!!oan_ lOANUN'ER Accour1t!LQan.: /lnClud;ng A TM/Debit w,d Access to rhe ACCOUflt il A vililiJbi~} Amount Requested $ Pu,..pose!CoUatera1: Repayment; Credit Card Accoum: (See Oisi;Josure taMe or Agreemc;1r for Terms) Credit lirnit Requested $ If Authorized User, Name: Slngte Credit Disability 5ingte Credi t life JOl nr tredi t li te " '--1 ~-------_. #f~~~,~s~;:r!.iH'\:(r~\@:a)fl ~~~TIONs.1oP; . "'~ADDRf:SSOFNE.ARESTReLATIVENOTI..lV\NGWlTKVOU ,.;\~ 111 ~~ " () _ ,- HOlooCE !'"HONE V <,::L.,'-"'-' . (1-71.7) 5')2- oS' v, I :2 SI~V-;6-fI;'>;, Sh,ir;(~-j.L-," fIA- l'i2< I axB1T CV", MV'U^, GROUP, ".0, ." ", SO, '" 2,"00 Ale ",C,,<S "'5'''''{[) -B--- j IA?..LICI\IIl1' l.....cvAz::::.,.. \ I.,,?, " I .....__/(}...fl .ll l ".....-...~-s ~ "-'""':-; :"<f'-N.O: r~:~:; ISOCIAL SEC;UFUTY NUM6U\ _' t /0'1 ,~u LtIU';5 !A(,..E~ 01= lJi:i-'ENO::<J'-S IBIR";"I-' ~t~../ HOME i"H:JN~ 8USJIIl::S,:> f'HONU1'-Xl_ ! ;:J2'1I) >, (11'/) 243 / <to s /\,!fJ. /PR_ E:NT ,AOOR<,SS ; I . , ~ .?,:-f -=S;\J n00c->';er.. lfJ>;';TH...T RE5IOC'NCf: !I';',\'<;.I<" 0A 1703 3;:)",,::. ' r'"'E-.....1CU5 "'DDReS; .j LE....GTH AI H61DE-NCE COMP\..E'TEJ'OF\ JOINT C~EOlT. ScClJ1ilU)CJll:EOll OK IF yOu LIVE IN'" CO"",MI.IHfTV PROP~Rn' 51 A TE: ,'..URIT....t S7ATtJS, 1fI"t!'r:d ~:~f~2:~~~Kf:n~:SP~d s ') -;::;> - ' \ ri-(\(\.,-Q I v...,..,"u~... "" ,,'.l'>~"l j'- '-- )DRJVUf'S L,'ceNSE M)~~~~Ti. 10<::;.(."" i./. <f':' pc", "'AM E Af'lD ADOAESS OF f""f"LOVJ:A UnE/GAADc. START 010 H rOU~.5 ... r WOR" IF SE1.f EIIoIPlOVED. T"I'PE OF B"JSINE:SS , $UPEHvIS0f<5 NAMe I'fOTIC!: ALIMO"""', CI-tILO $(JPPORT, OA $EPofJtA.TE MNN'TEHANCE I"<ICOlol'e NEED NOT Q.. ltfVEA.l~O IF yOU 00 ....OT CI-fQOS!:: TO HIWE IT CONSlOERED. ::n-1!:RiN!:.D"'lE. $ 371- f'D\ t1{..,H'(t, SOURCE -:-:cciC.\ ~'>.._______. 'it", '; 1$'17:5 ?€R ,11~11#'l SO~CE kdc:l:"J ;<;.",~__,,-~.\4 1 :.3")1../ P'E~ SOURCi: "./ f\ ?:e0,,-,":'-+ , ;Z-S'l "'" $,'-It. SWAC'S;"J"d SS: .>c~ f- WUl A.MV 'IS vuTY ST A,7101'1 L"RJU.l5i-ER EX;>ECiro DURING "'l=x.. YEAR? IH:s"l~ rHD'NGJSE.1'>^~.....nON O^---n: >;EVIOVS ENI"l...OYU\ NA.lotf. AN() ADDRESS IF- EMP\.DyED LESS THAN Vf YEARS st...;:rrll"G DATE ENDING OATf ~ I l~:ER 1''''0->-10'''<; V:.\.F~1t:'J ";','v:!' ._u~ -l ----, SOCIAL ~CUFllry NlJMBfA I A.CCOUNT NUtJlBHI I \ O~IIIEA-S UCEr.:~::: Nl,J"," SE.I'\/Sl A. Tf. A.:;Gi.;p-;;;fF1;r..;c;o,r;:; I""'"DA" PRtSE-.r>l P.l)D~~S:. M-QM!F'HONE BIJ$lNfSS PHONE/EXT. L::NGT~.Il, ':' !:l,$t~f.r~:;C:. , PREVIOtJ$ '-'ODl'lESS LlNG'TH AT R~S.I[)!::NC~ CO,,",PLEn; FOR JOfNT C/OlEOfr. se.,-i.J"~ 0<:01', OR It you uvi :t-<A CQ,\!.\ofU","7Y ".opeRTY STATE.: "...R1T.-.LSTA;US, ~~~E,roII'lCOM" j , NA....E AND AOORESS 00: EMf'I..OVEFI <'E" Trrl..tlG-"IAO~ ,START DATi: j'"'O\..IRS M V<'OR1, SUPEFlVlSD!f'S NA.ME -T'" seLf EMYl..QVt:.Q T'fM:: OF E:lU$IN'5$ 1WOllC~ AULlI(J-IIIY, CI'OIUJ S~C>RT. OR $i:P"'''A.1"f MAIJ.iTENAHCE. 1N{:,::H.;f 1',,100 Ni.n ili: REV",...LEO IF yo:; 00 NOT CHOOSE TO H"~ I";' CONSI~"":D, OTHER INCCMe . "'A souRCE $ '" soURCE $ "'" SOURC' $ "'" souACE "'~Lr. AJ\Y; ;SC:J"Y S"';J.Tl:).t>I ';'R"'KSf~?l; E.XPEC1~!:I .:J!JRIN(i Nf)l;,. '!s-.?:~ WNEAIE: ENOINGISEPA,RAT!ON CAn PRE\I'lOVS f.~P\.OvER ,..AME "'N.O A!};:)RES$li tMP\..OY€O lESS nI."'", RVEY"..ARS ST4RnNG O"'T: E~Oto.G:>...TE ~ 28. "'......E .-.NO }t.OOAESS 01' NEA~S'r R:':lAnVE NQT UVING WITH' YOU rltlA"CWSf.;~ '10MEPH!Y.'iE .; A.X)(1;>3ILASERI7Hi:> DEC-16-2003 SUSO V,>,L. Feu 09:55 717 4412022 P,03 I =t=. t IS /' I I' . I r-- i s . =-t f , I $ . I , , I I $ $ I , I . . , $ . I $ . , $ . I . $ $ $ . $ usr !>NY NAMES U",OCPO WHICH YO:.tR CREDIT R~F"ERENC~S J<NOJ CREDI1 MfsrQR'I' C"'I'O ~E CHt::l(~O; TOTALS . $ PLEDGED .tS COUATE.AAl O\o\:~ED81' ",M" /': US'T lOCATION OF PflO~RTY 0" FI/'jAI\ICIAlIHSTlTUTIO'" MAAAt'f VALUE fOR .<).IT:)THER LOAN APPUCAf,;T OTHlR $ f . i $ I I I ! $ I ! , ! ! I I I i , I I , I- I ! , , ()i8E~;:_~,~'f_8~.~AT!~'j'~.-,Af3.q,UI:Y; Oll ..,. : >):',:J If 'Y0lJ ANsweA -ns- 'rO ....'n aUES1IQr,; O'1~'E1l THAN '1. ~'" t;;lN I\.NATII'i.CI~C;C SHi:l:"1 A'PUCANT OTHtR . ~~ HZl I rJC I t. All.( YOU A U.s. ...rn2eN OR PVlMANfl'\;T RC$';:)CNT AurN; ~ 00 YOU Cl.lR.RO.I11- V H"'VE ....",y OUTSTANOINC JuDGMENTS 0'1 HAVE "OU EvER r:l~eo ;:01'1 :9A.NI:"RI.!PTC". tjA.O '" nEST AaJ;;STMe~T PLAi'II COHFIRJ.AEO UNDER OlAPTfA IJ. HAO PROPERT'f rOA[CtO$ED UPON OR REPOSSESSEO IN TI"+f LAST 7 YE....~. OR eHN... PAATv J~ A lAWS:JIH J. IS TOUR rNCDlol( u"-av TO OEC'.JNl:. I... n1E ""EX. oW:) Y.EAf'lsr .., A"'E YOU A Co.lJIA.(ER, CO.SIGNtR OR GUARANTOR ON ANY lOAN NOT LISTED A90vEr FOil. WHOM IN....,. 0' 0'....'3 O~'pat..d 0" lO."'" TO W~O,\l !N~:,~ ,,' ::;'~O;!"rI' .. u..._._,.__...._..___..__. srAtE:Q{v{'NOT!CES.': OHIO RESIDENTS ONLY: the 01'1'0 tllWS againSt discrimination require that all creditors mok-e Cfe6h eQuall'l' 3"aila~e to all creditworthy c\JSlomerS. and that credit teporting agencies main:ain separate credit hiSTories on each individual vpon request. ihe Ohio Civil KightS- Commission administers compliance with this faw. WISCONSIN RfSIOENT$ ONLY; {1) No provision of any marital property agreen"lent. unilateral staremcn.t u.nd.~t Sect~n 766.59. or court decree under Section 766.70 will adversely affect the rights of the Credit Union 1. You promise that everything you have stated in this 3ppliCi:ltion ',s correct to the best of your knowfedge iJnd thllt the ebove information is a compiete listing of wnM you owe. it there are any important changes you will notify uS ;11 wriring immediatelv. You authorize the Credie Union to obtain credit reports in connection with this application for credit en(l for any update, increase. rerlew"f, ext~nsjon Of collection of [he credit rece;vqd. You understand thai the CrediC Union _;11 rely on (he i"form8tion in this BPplication llfld your credit: report to mak.e its deCision. H you reQues.t. me C~dir Union wil: tell you [he name and address of al'l)' credit bu:eau hom whj~h it re:;eived a ere-e;it report on you_ Ie is a federal crime to wiUtvllv a"" deliberately provide incomplete Dr incorrect information on loan applico!ftions made :0 federal credit unions. or state chartered Credit unions ins~fed by NeLIA. ~ X Jc"W.. 0 J...,\-,...0 "-~/ AP'PUCANT"S SlGNATUl'l{" "..j rSEAU OATE 0,-,( SIGNATUA.t,; JV"?I'lOVED ~III.lITS: APf>POVEO OE.'l1lfD {~~.~ "'Clion NOI;":'" $erul $ lOAN OfI=ICEl't CONl""'fIVTS: SIG"'ATlJRCS; X OAn unres~ the Credi::Jnion is furnished a copy of the 8:;peement, s:CHernenl or! decree. or has actual knowledge of its Terrrs. before the credit is Qr<ln:ed Of the acco-unl is opened. (2) Please sign if you Bre oot applying lor &lis ~ccovnt or loan with your spouse. The credit being applied for. i/ granted. will be incurred in Ihe interest 01 the marriage or family of lhe lJoderslgned. x 51GNATVRl FO,ll WISCONSIN RESIDENTS ONL't' PATE z. If you are applying for a credit card. you understilnd th"t the lIS.t of your CZtTd will cOfl$'titute acknowledgment 01 receipt and agreement tQ t\e 18fm.! ot the credi1: card agreemf/m and disclosures. You grant us . secl.Jrity interest in ali ;,.di"jdual and joint ...hare and/or depo~jf accounts you hllve with LI.:I now and ;n the future to $ecur~ ,!,OUI cr~dit c;a-d account. When you lire in defilult. you authorize us to Zl'pply the bDlonce tn- these llIccounts to &n.'f amounts due. Shares and deposits in an Individuaf Retirement Account. and any other account that would )cse special 101 x treatment under staTe or federal law if given as security. are not subj~tto toa s~urity ln1eres-t you have given in your .$hares and deposits. ~ rX IS!AU ~ OTHER StGN....TUf'lE OATE I..Nt \>>- C1'l~t>rJ OTl--\ER Dun RA'tIO/'SCOl\t 8'"..FORE AFro OT>1:EH $ x [lAT! PAGE 2 UXI:;,>J lU.S~Il.: :nuo ~~ SUSQUEHANNA VALLEY FEDERAL CREDIT UNION 3850 Hartzdale Drive Camp Hill, PA 17011-7809 (717) 737.4152 !lQ{lN'tKNER@ I' "'.' ,-,," ~'(" 7 ,,( " 0:.-/ . ~ '" " I J LOAN AND SECURITY AGREEMENTS AND DISCLOSURE STATEMENT LOAN OA TE 04/16/2004 lOAN NUMBER 1 ACCOUNT NUMBER 14052 GROUP POLICY NUMBER 037-1661-8 MA TURITY DATE 05/01/2019 I BORROWER 1 BORROWER 2 I ~;"'M~.l,,\lD ADOCl"SS NAME (AND ADDRESS IF DIFFERENT FROM S:)RROWE" 11 Samuel J Bernard 343 N Hanover St Carl isle, PA 17013 TRUTH IN LENDING DISCLOSURE 'e' means an estimate ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price The CO"", 01 your credit as a yearly rate. The dollar amount Ihe The amount of credit The amount you will have The total cost of your purchase on credit is credit will cost you. provided to YOIJ or on paid after you have made $ your behalf. all payments as scheduled. which includes your 12.90000 % $20,601.20 e $16,110,00 $36.111.20 e downpayment of $ Your Payment Schedule Will Be: Prepayment: If you payoff early you will not have to Number of Payments Amount of Payments When Payments Are Due pay a penalty. 179 $ 203.95 Monthly Beginning 06/01/2004 Required Deposit: The Annual Percentage Rate does 1 $ 204.15 05/01/2019 not take into account your required deposit, i'f any. Property Insurance: You obtain insurance from I2J Assumption: Someone buying your mobile home may property anyone you cannot assume the remainder of the loan on the want that is acceptable to the credit union. If you get the insurance from us, original terms. you will pay $ Demand; 0 This obligation has a demand feature. Late Charge: 0 AI) disclosures are based on an assumed All payments received more than 14 days past their due date witL be charged maturity of one year. a $20 late fee. Filing Fees Non-Filing Insurance $ ,DO $ ,00 Security: Co~lateral securing other loans with the credit union may also secure this loan. You are giving a security interest in your shares and dividends and, if any, your deposits and interest in the credit union; and the property described below; Collateral Property/Model Year l.D. Number Type Value Key Number MOBILE HOME TITLE 1984 THPA1170 HAUSER $ 22,473.00 $ $ Other (Describe) YOUR CRED IT UNION SHARES Pledge of Shares $ in Account No. $ in Account No. See your contract documents for any additional information about nonpayment, default. and any required repayment in full before the scheduled date. SIGNATURES CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT, By signing as Borrower, you agree to the terms of the Loan Agreement, If property is described in 1he "Security"sec1ion of 1he Truth in Lending Disclosure, you also agree to the 1erms of 1he Security Agreement, If you sign as "Owner of Property" you agree only 10 the terms of 1he Security Agreement, F) .c),'-,....."', ~ '\ I), V~ ~\ '1, 1(. - C; '1 edRRoWER 1 '.. IIXi 'J ' i"'." ..J-Y OTHER BORROWER '~OWNER OF PROPERTY '~WITNESS !SEALI 1IIIx DATE BORROWER 2 ISEAl) ~i - I:"~ -0 'ill II X DA TE j'J OTHER BORROWER U OWNER OF PROPERTY ISEAL! II DATE II ISEAL! WITNESS DATE @CUNAMUTUALGROUP. 1999. 2000. 2001. ALL RIGHTS RESERVED 11 NXX022 ILASER) c Credit Union Susquehanna Valley Federal Credit union' Borrower(s) Samuel J Bernard loan No. 1 Acct. No. 14052 ITEMIZATION OF THE AMOUNT FINANCED Itemization of Amount Financed of $16,110.00 Amounts Paid to Others on Your Behalf: $ To $ To $ To $ To $ To $ To $ To Amourlt Given to You Directly Amount Paid on Your Account Prepaid Finance Charge $16,110.00 $ .00 $ (If an amount is marked with an asterisk (*) we will be retaining a portion of the amount.) $ To $ To $ To $ To $ To $ To $ To I LOAN AGREEMENT In this Loan Agreement ("Agreement") all references to "Credit Union," "we," "our," or "us," mean the Credit Union whose name appears above and anyone to whom the Credit Union assigns or transfers this Agreement, All references to "you," or "your" mean each person who signs this Agreement as a borrower, 1. PROMISE TO PAY. You promise to pay $ 16,110.00 to the Credit Union plus interest on the unpaid balance until what you owe has been repa)d. For fiKed rate loans the interest rate is 12.9 % per year. Collection Costs: You promise to pay all cos.ts of eol Leeting the amount you owe under this agreement including court costs and reasonable attorney fees. 2, PAYMENTS. You promise to make Qayments of the amount and at the time shown in the Truth in Lendin~ Disclosure, You may prepay any amount without penalty, IT you prepay any part of what you owe, you are stili required to make the regularly scheduled payments, unless we have agreed to a change In the payment schedule, Because this is a simple interest loan, if you do not make payments exactly as scheduled, your final payment may be more or less than the amount ot the final payment that is disclosed, If you elect credit insurance, we will either include the premium in your payments or extend the term of your loan. If the term is extended you will be required to make additional payments of the scheduled amount, until what you owe has been paid, You promise to make all payments to the place we choose, If thiS loan refinances another loan we have with you, the other loan will be canceled and refinanced as of the date of this loan, 3, LOAN PROCEEDS BY MAIL. If the proceeds of this loan are mailed to you, interest on this loan begins on the date the loan proceeds are mailed to you. ~, SECURITY FOR lOAN - This Agreement is secured by all )roperty described in the "Security" section of the Truth in _ending Disclosure. Property securing other loans you have Nith us also secures this loan, unfess the property is a Jwellinq. A dwelling secures this loan only if it is described n the '"Security" section of the Truth in Lending Disclosure or this loan, If Credit Union has a federal charter: Statutory .ien ' If you are in default on a financial obligation to us, ederal law give us the right to apply the balance of shares md dividends in all indiVidual and ioint accounts you have vith us to satisfy that obligation, After you are in default, ve may exercise this ri~ht without further notice to you, We have a federal charIer if our name includes the term Federal Credit Union,") If Credit Union has a state charter, 'xcept in Ohio and Rhode Island: We have a statutory lien n the shares and dividends and, if any, the deposits and lterest in all individual and joint accounts you have with us nd may exercise our rights under the lien to the extent ermitted by state law, (We have a state charter if our ame does not include the term "federal Credir Union, ") or all borrowers: You pledge as security for thiS loan all hares and dividends ana, if any, all deposits and interest in II joint and individual accounts you have with the credit nion now and in the future, The statutory lien andlor your led~e will allow us to apply the funds in your account(s) ) wl1at you owe when you are in default. The statutory In, and your pledge do not apply to any Individual etlrement Account or any other account that would lose lecial tax treatment under state or federal law if given as ~cunt\l. . , DEFAULT. You will be in default under this Agreement if lU do not make a payment of the amount required on or CREDIT UNION COpy CUNA MUTUAL GROUP. 1999, 2000. 2001, ALL RIGHTS RESERVED before the date it is due, You will be in default if you break any promise you made in connectJon with this roan or if anyone is in default under any security agreement made in connection with this Agreement, You will De in default if you die, file for bankruptcy, become insolvent (that is! unable to pay your bills and loans as they become due), or i you made any false or mIsleading statements 'In your loan application. You will also be in default if something happens that we believe may seriously affect your ability to repay what you owe under this Agreement or if you are in default under any other loan tlgreement you have with us. 6. ACTIONS AF,TER DEFAULT - When you are in <;Jefaull, we may demand Immediate payment of the enttre unpaid balance under this Agreement. You waive any right you have to receive demand tor payment, notice of intent to demand immediate payment and notice of demand for immediate payment. If we demand immediate payment, you will continue to pay' interest at the rate provided for in this Agreement, until what you owe has been repaid. We will also apply against what you owe any shares andlor deposits given as S8currty under thiS A~reement. We may also exercise any other rights given 5y law when you are in default, ]" EACH PERSO", RESPON,SIBlE - Ea<;:h, person who signs thiS. Agreemen, Will be IndiVidually and JOlptly responsible for paYing the entire amount ow'!d under rhls Agreement. This means we can enforce our fights against anyone of you individually or against all of you togetner, 8, LATE CHARGE, If you are late in making a payment you Q~omise to pay the late charge stlOwn in the Truth in Lending Disclosure, If no late charge IS shown, you will not be charged one, 9. DELAY IN ENFORCING RIGHTS - We can delay enforcing any of our rights uncler this Agreement any number of times without losing the ability to exer,cise our rights later. We can enforce this Agreement agamst your heirs or legal representatives. 10, CONTINUED EFFECTIVENESS . If any part of this Agreement is determined by a court to be unenforceable, the rest will remain in effect. 11. NOTICES - Notices will be sent to you at the most recent address you have given us in writing, Notice to any one of y.ou will De notice to all. 12, OTHER PROVISIONS. NXX022 (LASER) Credit I)nion Susquehanna Valley Federal Credit Union Borrower(s} Samuel J Bernard loan No. 1 Acct. No. 14052 r- In i:his Agreement all references to "credit union," "we," "our" or "us" mean the credit union whose name appears on this document and anyone to whom the credit union assigns or transfers this Agreement. AI! references to the "Loan" mean the loan described in the Loan Agreement that is part of this document. All references to "you," or "your" mean any person who signs this Agreement. 1. THE SECURITY FOR THE LOAN - You give us what is known as a security interest in the property described in the "Security" section of the Truth in Lending Disclosure that is part of this document ("the Property"l. The security interest you give 'Includes all accessions. Accessions are things which are attached to or installed in the Property now or in the future, The security interest also includes any replacements for the Property which you buy within 10 days of the Loan and any extensions, renewals or refinancings of the Loan. It also includes any money you receive from selling the Property or from insurance you have on the Property. If the value of the Property declines, you promise to give us more property as security if asked to do so. 2. WHAT THE SECURITY INTEREST COVERS - The Property secures the Loan and any extensions, renewals or refinancings of the Loan. If the Property is not a dwelling, it also secures any other Joans, including any credit card loan, you have now or receive in the future from us and any other amounts you owe us for any reason now or in the future, except any loan secured by your principal residence. If the Property is household goods as defined by the Federal Trade Commission Credit Practices Rule or your principal residence, the Property will seCure only this Loan and not other loans or amounts you owe us. 3. OWNERSHIP OF THE PROPERTY, You promise that you own the Property or, if this Loan is to buy the Property, you promise you will use the Loan proceeds for that purpose. You promise that no one else has any interest in or claim against the Property that you have not already told us about. You promise not to sell or lease the Property or to use it as security for a loan with another creditor until the Loan is repaid. You promise you will allow no other security interest or lien to attach to the Property either by your actions or by operation of law. 4, PROTECTING THE SECURITY INTEREST - If your state issues a title for the Property, you promise to have our security interest shown on the title. We may have to file what is called a financing statement to protect our security interest from the claims of others. If asked to do so, you promise to sign a financing statement. You promise to do whatever else we think is necessary to protect our security lnterest in the Property. You also promise to pay all costs, including but not limited to any attorney fees, we incur in protecting our security interest and rights in the Property, to the extent permitted by applicable law. 5, USE OF PROPERTY, Until the Loan has been paid off, you promise you will: {1 ) Use the Property carefully and keep it in good repair. (2) Obtain our written permission before making major changes to the Property or changing the address where the Property is kept. (3) Inform us in writing before changing your address. (4) Allow us to inspect the Property. (5) Promptly notify us if the Property is damaged, stolen or abused. (6) Not use the Property for any unlawful purpose. 6, PROPERTY INSURANCE, TAXES AND FEES - You promise to pay all taxes and fees (like registration fees) due on the Property and to keep the Property insured against loss and damage. The amount and coverage of the property insurance must be acceptable to us. You may provide the property insurance through a policy you already have, or through a policy you get and pay for. You promise to make the insurance policy payable to us and to 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. 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 Loan and you will pay interest on those amounts at the same rate you agreed to pay on the Loan, We may receive payments in connection with the nsurallce from a company which provides the insurance. We may Tlonitor our loans for the purpose of determining whether you and )ther borrowers have complied with the insurance requirements of )ur loan agreements or may engage others to do so. The insurance ::harge added to the Loan may include (1) the insurance company's )ayments to us and (2) the cost of determining compliance with Cl CUNA MUTUAL GROUP. 1999, 2000, 2001, ALL RiGHTS RESERVED CREDI T UN I ON SECURITY AGREEMENT the insurance requirements. If we add amounts for taxes, fees or insurance to the unpaid balance of the Loan, we may increase your payments to pay the amount added within the term of the insurance or term of the Loan. 7, INSURANCE NOTICE - If you do not purchase the required property insurance, the insurance we may purchase and charge you for will cover only our interest in the Property. The insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. 8. DEFAULT - YOLl will be in default if you break any promise you make or fail to perform any obligation you have under this Agreement. You will also be in default under this Agreement if the Loan is in default. 9, WHAT HAPPENS IF YOU ARE IN DEFAULT - When you are in default, we may demand immediate payment of the outstanding balance of the Loan without giving you advance notice and take possession of the Property. You agree the Credit Union has the right to take possession of the Property without judicial process if this can be done without breach of the peace. If we ask, you promise to deliver the Property at a time and place we choose, We will not be responsible for any other property not covered by this Agreement that you leave inside the Property or that is attached to the Property. We will try to return that property to you or make it available to you to claim. After we have possession of the Property, we can sell it and apply the money to any amounts you owe us. We will give you notice of any public sale or the date after which a private sale will be held. Our expenses for taking possession of and selling the Property will be deducted from the money received from the sale, Those costs may include the cost of storing the Property, preparing it for sale and attorney's fees to the extent permitted under state Jawor awarded under the Bankruptcy Code. The rest of the sale money will be applied to what you owe under the Loan, If you have agreed to pay the Loan, you will also have to pay any amount that remains unpaid after the sale money has been applied to the unpaid balance ot the Loan and to what you owe under this Agreement. You agree to pay interest on that amount at the same rate as the Loan until that amount has been paid. 10, DELAY IN ENFORCING RIGHTS AND CHANGES IN THE LOAN _ We can delay enforcing any of our rights under this Agreement any number ot times w'lthout losing the ability to exercise our rights later. We can enforce this Agreement against your heirs or legal representatives, If we change the terms of the Loan, you agree that this Agreement will remain in effect. 11, CONTINUED EFFECTIVENESS - If any part of this Agreement is determined by a court to be unenforceable, the rest will remain in effect, 12, NORTH DAKOTA NOTICE TO BORROWERS PURCHASING A MOTOR VEHICLE - THE MOTOR VEHICLE IN THIS TRANSACTION MA Y BE SUBJECT TO REPOSSESSION, IF IT IS NOT REPOSSESSED AND SOLD TO SOMEONE ELSE, ANO ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. 13, NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for you to fail to return a motor vehicle that is subject to a security interest, within thirty days after you have received notice of default. The notice will be mailed to the address you gave us. It is your responsibility to notify us if your address changes. The maximum penalty for unlawful failure to return a motor vehicle is one year in prison and/or a fine of $150,000.00. o The following notice applies ONL Y when the box at left is marked. 14, NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHAll NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER, 15, OTHER PROVISIONS- COpy Nxxon (LASER) SUSQUEHANNA ~"""- VALLEY FEDERAL CREDIT UNION Statement of Account Date: December 14,2005 Maker: Samuel J, Bernard Co maker: NONE Home Address: 343 N. Hanover Street Carlisle, P A 17013 Home Phone Number: 717-243-1403 Our Account Number: 14052-1 Your File #: 31957 Maker Social Security # 164-30-4] 08 Co maker Social Security: # None Principal Amount Owed 1 nterest Owed Penalty (20 % ofPrincipal& Interest) Late Payment Fee: Suit Fees: Total Amount Claimed: $17,096.71 $868,36 $3,550.23 $20.00 $1,000.00 $22,535,30 This is the mobile home loan. ~/-~" ! ~ ( \'''---~ 3850 HARTZDALE LOCAL: (717) 737-4152 T e-~- -.-..-..-,.-..-..-...:_...-:'...-..-."...-.-.-.....,. ,....'. PA 17011-7809 4 FAX: (717) 737-0589 f.~~ \~ "-._--_./ DEC~14~2Q05 11:50 KNUPP KODAK & lM8LUM 717 238 7158 P,06 VERIFICATION 1, SUSAN 1. BRUBAKER, LOANS/COLLECTION MANAGER of SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, verify that the statements made in the aforegoing document arc true and correct. I understand that false stateluents herein are made subject to the penalties of 18 Pa, C. S, !l4904, relating to unsworn falsification to authorities, SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION Dated IJ /; Y /V s;- f . 'lweu--J 319579 F:\USERIROBIN\CCP&DI CMPS\CCP COMPLAINTSlsvcu319S7,wpd: 14Dec05 5 TOTAL P,06 ""- I? 2 Crt ~'\.~ u- vc. 'S \) V) ~ ~ :p J: - ~ - ..J:::. ~ ~, 0 (") = 8 c: \:=' -n en -4 -0 CJ :J::n n r"l f11r~ ,l "r'11 1'.J :0r;) <.. <::) \~2~ , -n ~.',~ (') ::x; ~>,)rn '-.j! ':.\ ,.-" ".~~ :'J .,,- "iJ '< ", -~-- -----... ..---- .---~~--~.- ..-~.,~ SHERIFF'S RETURN - REGULAR CASE NO: 2005-06670 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL CRE VS BERNARD SAMUEL J SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BERNARD SAMUEL J the DEFENDANT at 2105:00 HOURS, on the 27th day of December, 2005 at 343 NORTH HANOVER STREET CARLISLE, PA 17013 by handing to BETTY BERNARD, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Postage Surcharge 18.00 4,80 .37 10,00 .00 33,17 So Answers: _~.-r; /1'/. r~ /;::~~~~/'~' f;t~:~ . _,,:.'<.~C.F R, Thomas Kline 12/28/2005 KNUPP KODAK Sworn and Subscribed to before By: I(~~:UM ~ Z 'f~ f );?; Deputy Sher'ff me this "'" il ~ day of ;) ()"'0 A.D, y . . SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, : NO, 2005-06670 SAMUEL J BERNARD : CML DIVISION - LAW Defendant TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant( s) SAMUEL J BERNARD, named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaint $22,535,30 Interest from November 30,2005 at Agreement rate of 12,9% per annum $484,50 Total $23,019,80 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 fE..-b I, ;;too "" Judgment entered and damages assessed as above, k J a~tb, ~~ ~if I ( Prothonotary ~ i/T) Robert L Knupp Robert D. Kodak Gary J. 1mblum LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile; 717/238-7158 email: kki.law@verizon.net filE COpy Robert Ewing Knupp (1909-1976) Robert H, Maurer (1923-1998) January 16, 2006 SAMUEL J BERNARD 343 NORTH HANOVER STREET CARLISLE PA 17013 RE: Susquehanna Valley Federal Credit Union VS: Samuel J. Bernard No. 2005-6670 Civil, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 31957 Greetings: 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 or your attorney have not filed responsive pleadings to the Complaint filed against you to the above term and number or an attorney has not entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak, Esq. THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDK/kqb enclosure cc: SUSAN J WASILlTION COLL MGR SUSQUEHANNA VALLEY FCU 3850 HARTZDALE DRIVE CAMP HILL PA 17011-7809 #14052-1 HAROLD S IRWIN III ESQUIRE 64 SOUTH PITT STREET CARLISLE PA 17013 EXHIBIT I.-A- filE COpy SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO, 2005-06670 SAMUEL 1. BERNARD : CIVIL DIVISION - LAW Defendant IMPORTANT NOTICE TO: SAMUEL 1. BERNARD, Defendant(s) DATE OF NOTICE: JANUARY 16. 2006 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTHBELOW. TIllS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTHAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LffiERTY AVENUE CARLISLE P A 17013 (717) 249-3166 EX f-L ~ ,..., 0 c - 0 "'" C,:'"l 4'1 A.J ~ -G 0-' ""' ::C l- \\::. r> f-I'~ \) OJ -0;::1(0'"1 C>- \ \,0 f\ - .,:.~~ (~) ~ ~ -0 -c {~~~'~,\ w -'"',.. ~ -t .:'jrn ~ ?-J r- 'i? -+A r - ~'iJ III ,-...c;:: 0 r.) ...;. ~ D ~ j=- .-.... SUSQUEHANNA VALLEY FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaiotiff v, : NO, 2005-06670 SAMUEL 1. BERNARD : CIVIL DIVISION - LAW Defendant TO: SAMUEL 1. BERNARD, Defendant(s) You are hereby notified that on Y E:.b I (Judgment) has been entered against you in the above-captioned case, , 2M !cthe following Judgment entered in the amount of $23.019,80, DATE: Jp,b I Prothonotary "--r,. I hereby certify that the name and address of the proper person( s) to rec;L this notice is: ::l r~fc, SAMUEL J BERNARD 343 NORTH HANOVER STREET CARLISLE P A 17013 AI SAMUEL 1. BERNARD, Defendido/a Defendidos/as Por este medio se Ie esta notificando que el de del 2005, ellla siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe, FECHA: Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: SAMUEL J BERNARD 343 NORTH HANOVER STREET CARLISLE PA 17013 Abogado del Demandante .... PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 SUSOUEHANNA VALLEY FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 Plaintiff NO. 2005-06670 CIVIL Term 20!2!!...- vs Amount due $ 23,019.80 SAMUEL J. BERNARD 343 N. HANOVER STREET CARLISLE PA 17013 Interest FROM DATE OF JUDG. (02/01/06) Atty's Corrun. $ 1,150.99 Defendant (s) vs and Costs TO BE DETERMINED$ MEMBERS 1ST FEDERAL CREDIT UNION Garnishee TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against SAMUEL J. BERNARD (3) and against MEMBERS FIRST FEDERAL CREDIT UNION Defendant (s) Garnishee (5), (4) and index this writ (a) against SAMUEL J. BERNARD (b) against MEMBERS FIRST FEDERAL CREDIT UNION Defendant(s) and Garnishee (s) I as a lis pendens against the real property of the defendant{s) in the name of the Garnishee(s} as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) DO NO~ LEVY UPON ANY PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) HOWEVER, PLEASE GARNISH MEMBERS FIRST FEDERAL CREDIT UNION, AT THE ADDRESS OF 5000 LOUISE DRIVE, MECHANICS BURG PA 17055, ANY ACCOuw.rS UNDER DEFENDAN'r'S NAME AND/OR ACCOuw.r #7836. /..../ (5) Exemption has (not) been waived. ~~~_ Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Attorney For Plaintiff(s) Dated 03/01/06 . (::-,) 70lE dTne! adS .pa.:r1sap S;: s'Japuad s''''i.- '2 ;0" 6u1xapuT put? ,?a~:::>e:n_2 s1 a2lljsTu.1'?6 au) JO aweu atn liT A)-xado.:rd 1ea-1 P ^lUO pa~aTdw:o:) aq PTrlO'.{S (q) (t>) Cjd!?JDeJ2d Aq /;:)uno2> 1124) 'c11 as-.:rooo JO S2 ;::>;,un1be.:r s1 6u1xepU"; A:+uno:J .:r~lj~ou" 0:+ se pa-lssap S1 'eoue-lnss1 JO ^:+unoo all=+ u1 svo1=+noaxe all:+ JO 6u1xepu1 JT . [ql~DIZ aTnB aaS r;anss- =+1.:rM 84=+ US4M . (P) ~OlE AIVO pa:+aTQUJO:' a<.; P--:nclIs (2) (to) 'A.:rP=+OU04:+0Jd all=+ aTn~ Aq pa~1Jo4:+n~ t[de.:r6e.:red . (:+L:.1M all=l li1 papn--;:::>uT aq 0) S1 aallfiTUJ126 paweu e UT ,Z{Tl0 pa~aTQWo:) aq ;::--:noll" <.:l^oqe) ([) l1dlnbe.1ed .pans-51 4::> TIF'\ UT A)Uno::> 214) JO 111.1a48 8114 a) AlUO pa=+:::>8.11P aq Aeill =+uaill6pn~ pa-l.1aJsue.1) e vo pans-s-1 :+r.JM 2 (::>)(01( aTnB .:repun 'pa1eo1puT aq PTn048 A:+uno::> elf:;' '(q)(C[[ arn~ i~q pazpO\~:),ne S8 ^:+unoo Je'j":j.oue].o JJ"PB4s B'-i=+ 0:), pa~;)B.:rTP Sl: 11-".:r..", 0iJ,:+ UBt.jM (1) lIde.:r5eJed .1apun I o '" Ei '-> \lJ 8 o z .w -.., '-> ~ r',: Ce,':_ ;':') C"\.,! , ~. . "~ . ~... 1-- " C '- ~ : , c'"" :gl o N ~ W Q rLI "" ;>; Z WO HH HZ ~::J f-; ~8 ~~ w ::J ()l U) ::J U) Ei '-> \lJ 8 H H :> H U o .-. '" '" 0' I CO o o N o Z Q ~ ~ W CO U) :> CJ H ; U) f/;:;' ~ ~J <J l.r) trj -... ~ Z o H f-; ::J u rLI >< W ~ o "" rLI 04 H U ~ 04 ::: ::: ~ --- I / 4 ~ a ~O-ri 0) rYJ 3,lON ~ '- J <:- ..j lJi ...... ...... "9-- o 10 Q o ~ o ~ ~ "' 4-1 4-1 'rl +J c: -M III .-'<c-f III 04 '0 o '-' :-<:: 0 'H Q ;>, I!J .w c: '"' '-' I!J 0 ~.w o .w ~~ :I It S( C) ~ <'-> f i ~ <) 'Q ~ <' ....... 1 Jl ~ ~ ~ ~ c:o ~ -+ '(d 3 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-6670 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, Plaintiff (s) From SAMUEL J. BERNARD, 343 N, HANOVER STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS FIRST FEDERAL CREDIT UNION, 50000 LOUISE DRIVE, MECHANICSBURG, PA 17055 - ANY ACCOUNTS UNDER DEFENDANT'S NAME AND/OR ACCOUNT #7836 GARNISHEE(S) as follows: and to notify the gamishee(s) thal: (a) an attachment has been issued: (b) tbe garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone otlier than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $23,019.80 Interest FROM DATE OF JUDG. 2/1/06 Atty's Comrn % $1,150.99 Atty Paid $115.67 Plaintiff Paid Date: MARCH 2, 2006 L.L. $,50 Due Proth y $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No, 18041 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, SAMUEL J, BERNARD NO, 2005 -06670 Defendant( s) V, MEMBERS FIRST FEDERAL CREDIT UNION: Garnishee CIVIL DIVISION - LAW PRAECIPE TO THE PROTHONOTARY: Please dissolve the Garnishment against MEMBERS FIRST FEDERAL CREDIT UNION issued in the above-captioned matter, TO: Cumberland County Prothonotary Dated: 3/YJ/o~ { /~ ~4!!f/} Robert D, Kodak Attorney for Plaintiff Attorney I.D, No. 18041 31957 7CJ ~ - ~ \r) "'0 C> ----{) (:> 75- h ...::! -- D L -0 ~ :2:::n f'l cr~ -c,'b -,-) , :~::'{I~ ~~-~\ -0 (::i (,.7~ -'~ . --- ~\ ;~\;S :::;;. -\.Q. Vt c- o -J r D ~ ( ~ ,'-") "'" {~ ,=" ::::: -~""'" ?o N <;'? o ,-" SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-06670 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SUSQUEHANNA VALLEY FEDERAL CRE VS BERNARD SAMUEL J And now ROBERT BITNER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:40 Hours, on the 8th day of March , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BERNARD SAMUEL J , in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to LISA WARNER (BUSINESS REP,) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So a.~we;;r;/ ~. ~t~~ __~ . . ~ ... R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me 03/09/2006 ~u1--6:cl~ Deputy Sheriff this J.D~ day of~ J~C A~ ?tu.' / prot'notary Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ 18.00 1.66 .50 1.00 4.40 30.00 20.00 9,00 84.56 Sworn and Subscribed to before me This /~ day of 2006 A.D, ~'/i 1iil1"~ ~9 OS :b V L-l:IVH qOOl 'v'd 'Alhno~} 0I1\1liJ38Wn:J .:l.:lllJ3HS 3Hl .:10 3:J1.:l.:l0 Advance Costs: 150,00 Sheriff's Costs: 84.56 $ 65.44 Refunded to Atty on 04/03/06 I:- ';, So Answers; {"- " ..j C R. Thomas Kline, Sheriff cJf) 11 A 1,-- Q. ~bt J By Cliiiidia A. Brewbaker . "iJ"" ')if !/)l .~ <>it (t/J /;~/~ Qf ~ AI ,) \,0' e..t.... .)'3~-1f~ I ~ /771'1;L WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6670 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy tbe debt, interest and costs due SUSQUEHANNA V ALLEY FEDERAL CREDIT UNION, Plaintiff (s) From SAMUEL J. BERNARD, 343 N. HANOVER STREET, CARLISLE, PA 17013 (1) You are directed to levy upon tbe property of the defendant (s land to sell (2) You are also directed to attach tbe property oftbe defendant(s) not levied upon in tbe possession of MEMBERS FIRST FEDERAL CREDIT UNION, 50000 LOillSE DRIVE, MECHANICSBURG, PA 17055 - ANY ACCOUNTS UNDER DEFENDANT'S NAME AND/OR ACCOUNT #7836 GARNISHEE(S) as follows: and to notify the gamishee(s) tbat: (a) an attachment has been issued; (b) tbe gamishee(s) is enjoined from paying any debt to or for tbe account of the defendant (s) and from delivering any property of the defendant (s) or otberwise disposing tbereof; (3) Ifproperty oftbe defendant(s) not levied upon an subject to attachment is found in tbe possession of anyone otber tban a named garnishee, you are directed to notify him/her tbat he/she has been added as a garnishee and is enj oined as above stated, Amount Due $23,019.80 Interest FROM DATE OF JUDG. 2/1106 Atty's Corum % $1,150.99 Atty Paid $115.67 Plaintiff Paid Date: MARCH 2, 2006 L.L. $.50 Due Protby $1.00 Other Costs Protbonota (Seal) By: Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQillRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ill No, 18041