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HomeMy WebLinkAbout02-2350COMMONWEALTH OF PENNSYLVANIA ~.~,~ JUINCIAL DISTRICT / / NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the appelkmt has filed in the above Court of Common Pteas an cq~eol from the judgment refldemd by the District Justice an the date and in the case mefltlaned belo~ I - /, z ~b ~ck wi, ~ ~ ONLY ~ this ~mfi~ is ~qui~ ~ P~ R.C~J~. ~ ff ~ll~t ~ OL~IMANT (~ ~. R.O.P.J.P. No. 1~8~ ~ ~ of A~I, ~ ~ei~ ~ ~ Dis~t Jus~e, will ~ as a ~I(~) Jn ~tJ~ ~ Diarist ~tioe, ~ ~T ~PER~EAS ~ ~ j~ ~ ~s~ in ~is case FILE A OO~AINT within t~ty (20) ~ el~er filing h~ ~TIOE of A~EAL. ~ ~ ~t~y ~ ~ty PRAEClPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be sen/ed upon appellee). (1) You are notified that a rule is hamby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule u~.~ you by personal service or by certified cx registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAIN,ST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. AOPC312-g0 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (Th/a proo! of service MUST [~E FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal, Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF__ ; ~s AFFIDAVIT: t hereby swear or affirm that ! served [.~J a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein or~ (date of service) E~ by personal service [] by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on , 19 r-I by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. [] and further that ~ served the Ru~e t~ FiIe ~ C~mp~aint acc~mpanying the ab~ve N~tice ~f Appea~ up~n the appe~~ee(s) t~ wh~m the Rule was addressed on , 19 . [] by persona~ service [] by (certified) (registered) mail, sender's receipt attached hereto SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS --- DAYOF __ , 19__ Signature of affiant 0 c:~ 0 o .~.~,,.. COMMONWEALTH OF PENNSYLVANIA COUNTY OF: ~ut4~ERLA.ND 09-2-01 PAUI~ P. CORREAL i COURTHOUSE SQUARE CARLISLE, PA (717~ 240-6564 17013-0000 DAVID R. YODER 1422 BRADLEY DRIVE ~PT.# CARLISLE, PA 17013-1266 C313 CIVIL CASE PLAINTIFF: NAME and ADDRESS FPA STATE EMPLOYEES CREDIT UNION 3211 N FRONT STREET C/O STEVEN C. COUNTNEY ~HARRISBURG, PA 17110-0300 VS. DEFENDANT; NAME and ADDRESS FYODER, DAVID R. 1422 BRADLEY DRIVE APT.# C313 CARLISLE, PA 17013-1266 NOTICE OF JUDGMENT/TRANSCRIPT b Docket No.: CV~ 0000099- 02 Date F led: 2/27/02 TI'tlS IS TO NOTIFY YOU THAT. Judgment: [~] Judgment was en[ered for: (Name] ~'-~ Judgmem was entered against: (Name) DAVID R- in the amount of $ on: [Date of Judgment) ] Defendants are jointly and severally liable. ] Damages will be assessed on: [] This case dismissed without prejudice. --]Amount of Judgment Subject to Attachment/Act 5 of 1996 $_ [--~ Levy is stayed for days or [] generally stayed. ~-~ Objection to levy has been filed and hearing will be held: (Date & Time) $ 3.594.22 Amount of Judgment Judgment Costs $ 85 o 98 Interest on Judgment $ " .00 Attorney Fees $ .00 Total $ 3,680.20 Post Judgment Credits Post Judgment Costs Certified Judgment Total Date: Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTll ISCRIPT FORM WITH YOUR :E OF APPEAL. 4-15-02 Date I certify that this is a true My commission expires first Monday of January, AOPC 315-99 2006 , i d ~Distri¢t Jusii,cf~ PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (Thi~ proof of service MUST BE FILED WITHIN TEN (10) DA YS AFTER firing the notice of appeal Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT: I hereby swear or affirm that I served ~ oooy ,the Not~oe of ^ooea~, Common P~eas No, 0s? ',~350 ¢ , .,o. ~,~ ~,~r~o~ ~.~,~. e~,~.a~ ~h.,.~. o~ ~;dat;of%.rv,ce) ~--~ ,_. ~ ~ personal ser~,~: ~ by (C~'~¢d~ (re~.~[.d)mail sender's receipt att!chad hereto, and upon the appellee, (name) ~ ~'~ ~¢/¢¢f3f:r¢~i'¢ ~n, ~ __, on ~.6Ei_~ ! ~_ , ~ by personal se~ice ~ by (c%r~!¢~ (regi~t~¢) mail, sender's receipt attached hereto. ~nd further that t served the Rule to Fi~q Complaint accompanying the above Notice of Appeal upo~the appellee(s) to whom the Ru~e was addressed on ~113 , ~ ~ by personal service ~by (certified) (registered) malt, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME / ~fgnature of affiant CQMMON~VEALTH OF PENNSYLV~ANIA COURT OF COMMON PLEAS t~ JUDICIAL DISTRICT FROM DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the appeqlant has filed in the above Court of Commo~ Pleas an appeal from the judgment rendered by the District Justice on the This black will be' ~OI~iL~ when this r~otofian is required under Pcx R£J~JJ~. Ncx If R._r~llant wa~ O£~.//~qNT (see Pa, R.O.P.J.P. No. 1008B. This Notice of Appeal, when received by the District Justice, will operote as a 1001 (6)in action before District Justice, he MUST SUPERSEDEAS to the judgment for possession in this cos,~ FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE ,,,-; .... .. (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action~..~.l~'Jdct~'" IF NOT USED, detach from copy of notice of appeal to be served upon ~ ,~_ llee). ~..~. ,~ ut , cmpoUee(s). ( 1 ) You am notified that ~ rule is hamby entered upl~ ,,t,al~e a ~in~ .t~, ~, within lwer~y{20).clays.aft~r the drate 6f t~'vic~,e of ~ mleCupon you blt. I:~W~:mol'service 'or by c~tored"n~ail. / ~' '(2) ff you do not file c a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of mail is the date of moiling, AOPC 312-g0 C~[R1~ FILE . Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees · Complete items 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: (Transfer from service label) PS Form 3811, August 2001 A. Signature [] Agent X [] Addressee B, Received by (Printed Name) C. Date of Delivery D. Is delivery address different from item 17 [] Yes If YES, enter delivery address below: [] No 3. Service Type ~ertified Mail [] Express Mail [] Registered I~!~,turn Receipt for Merchandise [] Insured Mail n C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes Domestic Return Receipt 102595-01-M-2509: Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees · Complete items 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. Ar[icle Addressed to: A. Signature r"q Agent X [] Addressee B, Received by (Printed Name) C. Date of Delivery D. Is delivery address different from item 17 [] Yes If YES, enter delivery address below: [] No 3. Service Type ~=¢ertified Mail [] Express Mail [] Registered ~.Return Receipt for Merchandise [] insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes PS Form 3811, August 2001 Domestic Return Receipt 102595-01-M-2509 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VSo DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complak~t and Notice is served, by entering a written appearance, personally or by 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 document, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICIA Le han demandado a used en la corte. Si used quiere defenderse de estas demandas expuestas en las paginas siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notificacion. Used debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y puede entrar una orden contra used sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Used puede perder dinero o sus propiedades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 800-990-9108 Document #: 234204.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Steven C. Courtney, Esquire and Metzger, Wickersham, Knauss & Erb, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, David Yoder, is an adult individual with a last known address of 1422 Bradley Drive Apartment C-313, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant is, and at all relevant times material hereto was, the applicant for a Visa Loan with Plaintiff. 4. On or about February 1, 1997, Defendant applied to Plaintiff for a Visa Loan. A true and correct copy of the loan application is attached hereto, incorporated herein and marked as Exhibit "A". Document #: 234204.1 5. Pursuant to the loan application marked as Exhibit "A", Defendant agreed to the terms and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (hereinafter referred to as "Contract"). A true and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 6. The contract marked as Exhibit "B" contains the terms and conditions of the extension of credit agreed to by Defendant. Various charges and/or purchases were made by Defendant on the Visa Loan with Plaintiff. 8. Defendant has not made a payment on account of the Visa Loan with Plaintiffsince March 30, 2001. 9. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 10. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 11. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 12. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay ail sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. 13. As of May 13, 2002, the balance due, owing and unpaid on Defendant's Visa Loan account with Plaintiff is the sum of Two Thousand Nine Hundred Ninety-five and 18/100 Dollars ($2,995.18). Document #: 234204.1 14. Pursuant to the terms and conditions of the extension of credit contained on the loan application, Plaintiff is entitled to receive and Defendant agreed to pay an annual interest charge on the principal loan balance. 15. Pursuant to the temxs and conditions of the extension of credit, Defendant agreed to pay reasonable attorney's fees and all court and collection costs. 16. Plaintiff has retained the services of the law firm ofMetzger, Wickersham, Knauss & Erb, P.C. in the collection of the amounts due and owing by Defendant. 17. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Metzger, Wickersham, Knauss & Erb, P.C. in the collection of the amounts due from Defendant incident to the within action, and Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 18. The amount of attorney' s fees and prior district justice costs incurred in this matter is the sum of Six Hundred Eighty-five and 02/100 Dollars ($685.02). 19. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 20. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration.. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, David R. Yoder, in the amount of Two Thousand Nine Hundred Ninety-five and 18/100 Dollars ($2,995.18), plus interest, reasonable attorney's fees and prior district justice costs in the amount of Six Hundred Document it: 234204.1 Eighty-five and 02/100 Dollars ($685.02), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, Dated: ~ 2002 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Box 5300 Harrisburg, PA 17110 (717) 238-8187 I.D. # 74669 Attorney for Plaintiff Document #: 234204.1 VERIFICATION I, Bonnie L. Berkoski, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel md/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. -fo the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in m~king this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Bonnie L. Berkoski Date: Docut,Ja,lt #: 180122.1 Exhibit A 'A "WI. '~'IN" OFFER FRO~I~I PSECU! You're Pre-Approved for up to $10,000 on our 9.9% APR Capitol Card ®VISA®! DAVID R YODER 1422 BRADLEY DR APT C 313 CARLISLE PA 17013-1266 ~o~ do ~/ou u,qnP There's ne~er bee~ a better time :o take advantage of PSECU's Capitol Card ®VISA! With our (./' 9.9% APR rate for purchases and our 12.9% APR ~;' for ca.~h advances and VISA Checks, there's no better card on the market! And to make it even better, you're p~-&ppmved! Just take a minute to fill out and tdgn the short application below and we'll' send you a Capitol Card VISA. Your good credit h/story aJ. lov~ us to make you th/s '\yin-win" offer - you'll receive our 9.9% VISA w-ith no az-muaI fee. - 9.9% APR for purchases, 12.9% APR for Chee, Jr, s or Cash VISA Chec~s - to pay off higher interest credit cards elsewhere. No Annual Fee. No Cash Adv~noe Fee. Up to 25 days of grace on purchases. Combination VISA/MAC')card. How does P$~CU win? * We have your business[ Huro'! Offer F-a:t~ires February 28, t997 (Offer good only to individ,al named kelow) 289.~vlK708A$69 Please print all r~quested information. Incomplete forms m~y muse deIays in processing yotzr application or a uerd~l. Name Home ~one B~ Date DAV~ YODER (717) ~8~718 iZ/27/61 S~iffi S~ N~r/A~t N~r Gross ~ In.me ~ Up m $15,000 ~ $30,001 to $36,0~ ~ $60,001 to ~72,000  $15,~1 - $22,500 ~ $~,001 to $48,000 ~ $72,001 to $84,000 ' ' : 2~,501 - $30,000 ~ $48,001 to $60,000 ~ ~er $84,000 .... L, Please send an additL~na! m.,-d at no ~ ~ [er [please p~.nt clearly): Fimt Na.m~ Mtddic Init:al Last Name mad this form and ~'erF'J~in~ 1 haue .~l~t~d in it ~ tree Y~a ~e outlined to obtain ~ e~/o~nent hislo~ or ~y vl~r info--on re~n m 0~ su~ ~o~ion ~d ~di~ ex~n'e~ w~th ~, f ~ee that ~h~ a~pt~ s~ll ~ go[~med by all ~ te~ ~ ~i~ of t~ ~A~[NER C~dit A~e~ ~'th t~ ~edit Unio~ afl ~dendu~, ~es m ~ thoro ~d all the':e~ ~d ~it~ ~ se: fo~ on ~e ~a~ed d~cl~ures ~ all t~se do~n~ a~ll ~ in~mt~ herein b~ t~s ~fe~ SCANNED Exhibit B P.O. Box 67013 , ~ Harrisburg. PA17106.70*13 ~ ' (717) 234"8484 Harrfsburg, (800) 237.7328 NationE I PSEC 't:m ,o eesc'recI,Un,o' Loan Disclosures This LOANLINER· Credit and Security Agreement, which Inc~das the Truth In Lending Disclo~uras, will be mfermd to as the Plan. The Plan documents Include this Agreement and an Addendum. You, your and borr~ver mean any person who signs the Plan. Cradlt Unlofl, ~e, our and ua mean PSECU or anyone to whom the Credit Union transfers its rights under the Ptan. This is a multi-state document which may be used to lend to borrowem in all states. 1. HOW THIS PLAN WORKS -- This is an open-end, multi-featured credit plan. We anticipate that, from time to time, you will Ix)n'ow money (called 'advances") under. the Plan. We am not required to make advancea to you under the Plan and refuse a request for an advance et any time. The Addendum dasc~bes the different types of credit (celled 'subaccounts") available under the Plan, the interest rote for each suhaccount expressed as a daily periodic rate and corresponding annual percentage rote and other charges. It may also have other terms and a schedule for determining the payment amounts. 2. CREDIT LIMIT ~ We may, but do not have to, establish a ct'edit limit on certain subeccoonts. If a credit limit is set for a subaccount, you pmmiso not to exceed the established credit limit. If you exceed the credit limit, you promise to repay immediataly the amount which exceeds the credit limit. 3. REPAYMENT ~You promise to repay all amounts you owe under the Plan plus interest, Payments are due on the last day of the month tadass we set a different date at the time of an advance. If the Addendum has no payment schedule fo~ a subaccount, your payment will be determined at the time of each advance. Payments must include any amount past due and any amount by which you have exceeded · - · . a~ a ~ymen~ .~'leaule. II you have a johlt ~hem draIf account, you will be responsible for paying all overdraft advancea obtained by a joint holder of the sham draft account. Payments will be applied In the order the Credit Union chooses. · wu m~w you ~o use your ATM/Oeblt card to access the Plan, you may be llabl~ for the unauthorized use of your ATM/Deblt card. you will not be liable for unauthorized use that occurs after you notify us, orally or in writing, of the loss, theft, or possible unauthorized use. If you believe your ATIWDeblt card has been lost or stolen, immediately inform the Credit Union by ceiling or writing us at the telephone number or address that appears elsewhere in the Plan· If the card is used to obtain advances directly from the Plan. your liability will not exceed $S0. ff the unauthorized withdrawal is from a sham draft account, your liability is govemed by the Regulation E dis~Jo~uras you received at the time you received your AT'lvl~bit nard, even if the withdrawal results in an adverse being mede from your overdraft SUba~:;ount. 5. RNANCE CHARGE ~ The dollar amount you pay for money bcrtowed is celled a ffinanee ctmrge' and begins on the date of each advance. A finanoe charge will be computed separately for each separate balance under ~ Plan. To oompute the per~xse rate ~- ....L.~._.._~_~_,, .~.ym~..m/?_mump~d. by the amaoa~ daity ~ ,~ compute me finance charge is em unpaid balance ea~ day [~t~' .? .e. n meae. In aa~llon to Interast, we may charga other ~u,~:e ..,, a.? .a~ on the Addendum. ff the Interest r~e is ........ ~_.~,? · ,~aaanaum explains how Ibe variable Interest rote ~,~s~. .a,m~.~ mmraSt rate, 6, SECURITY INTEREST --The I:~an is secured by the shares and deposits In all joint '' and individual accounts you have with the Craa~ Union now and I~ the futura. Shares and deposits In an Individual Retirement Account and any other account ~ ,,~,~ ~,uu]~,~ ~ ~e secumy ~nmrast you nave give~ in your share~ and delx~lts advance is requested. For example, a subaccount calfed 'New Car Advances" means the security will be a new car. A aupaccoont called "Other Secured Advances' means you must offer security acceptable to the Credit Union for the advance. Property given as ascurit7 for any advance u~der the Plan will secure all other amounts you owe under the Plan or undor any other Agreement with us now or in the future. Properly securing other k)ans with us may also secure the Plan. However, if you have gwan your dwelling as sscu~h/for a loan with us, that o'Y,~lllng will not secure an advance made under the Plan. Purohese the omo~n'v Insum~ ~-*-- -:2----"? '" .x~,~ ~ .~f aavansss. YOU may · may provide the propar~y insurance mm.nh a ,~.~.. ........... ~ptabfe ~CUNA MUTUAL GROUP, 1980. 82, 84.86. 89, 97, ALL RIGHTS RESERVED If you cancel your insurance and get a refund, we have a right to the refund. If the Pr°party or apply It towards what you owe. you aulhodze us to check which may be payable to you in order for us to cdilect any refund or benefits endorse any draft or due under your insurance poli,~/. You premiss to pay all taxes and lees (like registration fees) clue on Iha property and to keep the properly insured against loss If Y°U d° nof pay the taxes or fees on the properly wben doe or keep If losured, we may PaY these obflgetions, but we ara not raqu red 1o do so Any mon we for laxss, fees or Insurance will be added to the un,~id ~,=~'-'~ -, ~ e~. spend you will pay interest on theae 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 Its loan agreements or may e~gage others to do so. The Insurance charged added to your advance may include (1) the insurance compan~$ payments 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 purc~se the required properly insurance, the insurance we may purchase and charge you for will cover only our interest lo the property. The Inaurance will not be liability Insurance. g. CREDIT INSURANCE ~ Credit life and/or cmdit disability Insurance is optional under the Plan. If you qualify for and purchase the insurance from us, you authorize us to add the Insorance premiums monthly to your loan balance and charge you interest on the entire balance. If you elect credit insurance, your payments may Increase or the period of time necessary to repay your advance may be extended beyond the approximate term stated on the Addendum. The ct'edit insurance rates may change during the Plan. If the rates change, we will provide any notices required by applicable law. 10. PERIODIC STATEMENT ~ On a regular basis you will receive a statement showing all transactions under the Plan during the period covered by the statement. Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each joint borrower, notice to any one of you will be notice to all. 11. JOINT ACCOUNTS -- If this is a joint account, each of you is indivfdually and jdintiy responsible for paying all amounts owed. That means we can enforce our rights under the Plan against any one of you Individually or against all of ,u~mu~,~. unmss our wntten pol~-,y requires all of you to sign for an advance, each ). LL_T_~. ,- . ~.?ve ~au omar mas in connection with the Plan. Those fees are them In cash. 13. UPDA'rING CREDIT INFORMATION ~you promise that you will promptly give us wriften notice If you move, change your nares o~ employmem, or if any other information you provided to us changes. Upon our request you also agree to provide us updated financial information. 14. DEFAULT -- The follOWing paragraph applies to borrowera In Idaho, Kansas, Maine and Sou~h Carolina: You- will be In default If you do not make a payment of the amount required when it is due. You will also be in default if we believe the prospect of payment, parinrmsnoe, or realization on any properly given as security is sigelflnantly impaired. The following paragraph applies only to borrovve~ In Wisconsin: You will be in defeuif if you fall to make a payment when due two times during any 12'mortth parind, you will be in defeuti if breaking any promise made under the Ptsn materially impairs your ability to repay what you owe. You will also be in default if breaking any PmraO~ei.se.. made under a Security Agreement made in connection with an advance, atenslly impairs the condition, value, or protection of or our right in the property you gave aS sec~. r~ fo,o~ng paraaraph ~lea o. ly to ~"ra fo ~.~:you ;~i~ be in defeu, ff you are more man 10 daya late in tasking a payment, you will atso be In default ff PSECU FORM #3146 JeXX060~-~ 037-2og2.1 (3,'o01 The following I~ragrsph applies to borrowetw In all other states: you will be ir mu" "YOu °ma~ any Prem~e you made under the plan or If anyone le ~ defauif under auly seaJfltv aareemeflt ma,4~ ~, .... ~ ....... the Plan. You v/dlbe in defauRIf vm~ di~ e,-,.. .......... under information or If ':LT-~"~-";LT ~-T ..... ,,a .. any aean appl~cetion or update of a'ed;t 15. ACTIONS AFTER DEFAULT ~ The following paragraph applies to borrowers In ¢olorsdo, District of ~olumbla, Iowa, Kansas, Maine. Massachusetts, Missouri, Naif'asks, West ¥1rglnls end ~ou~h Carolina: When you am in defauR and after expiration of any right you have under appr~tt~e state ~Wla~C~t.r_e~_Y~_ r_de_~ulL .we. ceo demand .mediate payment of the entire unpaid The following paragraph Koplle~ to borrowers In ell other atate~ ~l.n end Loulafana: When you ere in dofau- we ........... ex?f,. payment (acceleration) of the entire unpaid balance ~;~- ~-.~,_ ,...,_~4u.? arnmea~ate right you have to demand for ............. ,..m. um ran. YOU waive any aceeleraUon. ;.,~.w,., ~oace or Intent to accelerate and notice of ~o(~:s~ana: n~mmeamte oavn~,nt a= a,,~=.,.t~, ..~, . '/~ In until wflat you owe has been repaid, at ltm app~ca~e interest mte~ In effe~ unless · default rate le ere~osed on Ifm Addendum. ff a demand kx Immec~ate payment ap.p~lad towar~ v~nat you owe. We can also exercise any other rights given by law when you ere in default. ~a-k~,.* k.----~ ..... ~' --'~ ,~.,~ L J~.~X.~ p~.S fl ~ Carl be peace t we ask, you promise to delwer the property et a time and place we choose. We will not be ~ble for any other property, not covered by mis Agreement, that you leave inside the property or that le attached to the property. We will try to return that p~rty to you or make If available to you to claim. · m ~y p~3gc 8ale. or trle G~te alter a sale will be held. Our expenses for taldng possession of and selling the ~ rm,~,~4 .--~ ..... ;5'-""'"' ~""~"~" ~ '; [u[ ~tue mia aRom~e ~ to the 15. ACTIONS AFTER DEFAULT -- WISCONSIN -- The folfowlng IMm~rsph applies only to Wisconsin/x~'meers: When you are In default and after explra:Jon of any right you have under applicet~ state law to cum your default weulm ~<)seession of the Pn0partY. YOU may volurdadly give the proparly to us If you choose, m we may ..~:~ to take ~ of the property by judlcfal prooese. If we 422.413 of theWleco~sin Statutes. pay m~ permitted by 8ecrm unla~ a defauif n~e b ~eecl on the Addendum. 0 a demand ~ immedla~ payment In illinois: We have the dght to the term~ the Plan ~'om Ifma to t~ma a _ ~. of fter give. YOu any advance notk~e red law change to the intereat rete or other cmugea wgl apply to lutum areqdv~e~ .Any cl~l~rmsParsgrsphs apply only to borrowe~ In Wisconsin. w,, of the Pfan from Ifme to tlma in acoordance with SecUre 422.415 °f the Wlecor~Sin Stetutes. You wltl be nofltlad of any change in terms. An incrsasa in the dally padoa3c mm under a vadal~ rate inter~t rate le not conaldered a c~mge In terms under Iha Plan. We can cencel ltm entire Plan or sny pan of the Plan at any lime~ You may canoel the Plan at any t~ma by giving us prior written notloe. Your obligation to pay the unpakl balances under the terms of ~ Plan oo~nuea whether you'or the crndlt urdon cancel ttm Plan, except to Itm extent Ifmt your Ila~ le fimifed by 8ec~k~ 4~..4155 of I~e W"~acormin 8tatutse · the Plan after re~ nodce Ihat change appllas to exisdng bafanc~. ' - - usa of tha Pten means YOU agree th( ~:~ ~e~ ~ ~ rote u~r a ~ ~ ~ ~ ~  ~ ~ ~r~ ~n. We ~n ~m ~-- . o~ me .~ m ~y ~. You ~ ~1 ~ P~n at --, '-- -- ~ ~ a~ ~y ~ un~H ~ ~ ~ te~ of ~e -,~ --~r ~i~n tc ~r~ Un~ ~ ~ ~. ~ 21-~ apply ~ ~ give ~ ~1~ ending ~y of ~ ~ u~ ~11 ~ ~ p~ ~ 20. ~NUED mu~ to E~NE~ -- ~ ~e.~ ~1 ~ ~ e~ 21. ~E SE~R~ ~R~EL~ --y~ P~ ~ ~ 10 d~ ~ ~ or ~ ~ m~ or m~na~ ~ ~ ~. If a~ ~u~ ~ ~ ~ r~ ~ ~Ding ~e P~ m~m I~u~ ~u ~ ~ ~ pm~ ~ ~ ~ ~ ~llnes, ~u ~ to ~ us mm pm~ ~ W~T~E SECUR~ I;ERE~ · e A~ ~ ~ ~ ~ip~ ~r or any ~er ~ ~ ~ at A~' ~ ~ ~ ~o~r a~ ~ ~m ~ ~ ~ ~ ~m ~m~n C~ Pm~ Rule. ~ p~ ~11 ~m ~ b ~ ~d not o~er a~ ~u ~. ~. ~NERSHIP OF~E PROPE~ --y~ P~e~~ m~~w. ~e~ ~ ~ p~. ~1: (~) U~ ~ ~~ ~ ~ ~ ~ ~ ~c (2) ~ ~n ~en ~ ~- (8) ~ ~ ~ p~ ~ ~ ~1 ~. 2~. NO~ DAK~A N~E ~ BORR~S PUR~IN~ A M~R ~HIC~E M~R ~ IN~ ~A~ON ~Y BE 8U~E~ ~O A~ ~OU~ DUE~ ~E 8E~REo p~ ~E N~ RE~O IN ~T 8~, YOU MAY ~ ~ PAY ~E 27. VERMONT NOTICE TO. O~SI~NER ~ YOUR SIGNATURE ON THIS NOTE M~NS THAT YOU ARE EQUALLY UABLE FOR REPAYME~ OF~IS LOAN. IF~E BORROWER DOES N~ PAY, ~E LENDER HAS A LEGAL RIGHT TO OOLLE~ FROM YOU. TI~ noifca eeetalns ~nt Info~catfon about r under ~e Fair Credit Billing Act. . 17 rights and our msPensrdiliites NOTIFY US IN CASE OF ERRORS OR QUESTIONS AROUTYOUR STATEMENT. If yo4J think your statement Is wrong, or ff yo~J need more Infofmafiofl about a your statement. Write to us as soon as poss~l~e. We must hear from you no later L%ctle~ o~ your statement, write us on a eaPamte sheet at the address listed oe days after we sent you the first statement on which the error or pro~em In your letter, give us the following information: ' ' Your name and account number. * Thedollaramountofthesuspactedorror. ' Dascdbe the error and explain, If YOu can, wby you believe there'is an erroc If you need more Infommtlen, desorl~ the Item you am not sure about. If you have · . authorized us to pay a credit card account automatically from your share account or chec~ng account, you can stop the ~ent -- ~"~"" un any amount you think IS wrong· To stop the payment your letter must reach us three Ix~inass days before the automatic payment Is scheduled to occur. expm. m why we believe ~ ,~;.:--'---" ~' u~r~, we must either con'est the error or After we receive your letter we cannot *,., to co/f--,, --- - report You as delinquent. ~ M- ___.. '; ~"m]yamountyouquesttoa or you question fnofudi,,,, ti~-~-"'=~"~"~m- noet°as, ndstatementstoYouforthe~m CredIt account with us w .... =_.~,~.~Jm means your VISA Credit Cam · -.-, ,,, eno ours mem,,s thIs Credit Union. '- --~ 1. RESPONSIBILri'Y _ If we issue you a card, you agree to re the Finance Change erisin~ from ~ ,, ...... pay all debts and exm-nple, you are rasPonsi~e ~.,. --~-.:: -~u o~.m~ can] and the card accotmL children. You am also ,.~,-~.-,,-,- ~-ng? oe by .yourself, your se a responsibility continues unal the card is cannot disc~im mspoflsibility by notifying us but we recovered. You trancacfions Jf you so request and re. .. , . will cfose the account for naw ~urn mi cards. Your obligation to pay the account balance continues even though an agreement, divorce decree or other court judgment to which we are not a party may direct you or one of the other persons rasponaible to pay the aCCount. 2. LO.ST CARD NOTIFICATION _ If you believe the card you will ~mmed'mtely call the Credit Unle = ba?_been lost or stolen, hours call (800) 556-5678. n .t (717) 234-8484 or (800) 237-7328. After filfnaocewe find that we mede a mistake on your stmam,m~ ,,,,,, ..,, . _ Ch~ related to any n,.~-ta.,...~ .__::~'-.;~ ~ -m r,o[ nave to oav an "'~ ~""xm~ you owe and the date that It is due.- .... ~'u You a ststemor telii us that tlefy you you vatte to ~_ng you still refuse to pay we must te, .____. us v/4hin ton day. rep(xt YOU to. We must teli an~.,,. ....... _.YOu Itm name of anvom I1 we don't lollow these rules, we can't collect the first $50 of the questioned amount even ff your statement was con'ect. SPECIAL RULE FOR CREDIT CARD PURCRASES ~ ff you have a pmblam will ~tbe q.u?lity of property or senaces Ihat ~u purchased ~ - right not to pay the remalnl ....... ?,~,m..w]m m.e merchant, you may have '~.~ lim~lfona ou this r~'t:. 'a' ~'~u'=-'m' '°~--'n~ aue on me property or services The'r~ · -u.. · ~ / ~ mu~ nave mede the porchase ~ .--..-',-'-' Thase Ilmltatlena de not apPlY If we own or operato the morchant, or if we you the advertisefnent for the property or senecas, mallea to ~'-~a ,~ um order tha~ w~e -'---. a"u om m current punc~ase belencas. · rchases each month within 25 days of your statement diosing date. Otherwise, the New Balance of Purchases, and subsequent pun:bases from the date they am ed to the aa~e uley are posted to your account. ..... =.y~, ~,uojec~ ~o Pmance Charge from the Purchaee~: We calculate your finance change by multi the dai~ balance (see explanation below) ~-. ...... p~.ng . average adjusted , your account, the remaining cmclit avallal~e - ~ - ,anoas of P~rchasas .,..~ ..... un<mr your C, redlt Line ~ _Change due to date and .n,, other ~'.-~ ;-%" ltm Total New Balance the F3nanee ve~ month , and the Minimum Pa you must pay at least the Mini ymem requ red. · payment automaitcaliv to v~ ...~, ..... _m~u~ _ ~.m.a.Y. authorize us to charge the ~ m~w~m get'em wa be (e) ~ of your To~ .New ealenoe, munda~ up to ~e · in aac~on, at any ~me your To~/ a~ du~ng ~ bili~ ~e ~ ~-~ (~ ~ ~) ~ ~ · ~ ~bll ~s 4..~E~ UNE-- ~ ~ ~~ ~ ~ . ~ A~ D~y ~ ~ ~ ~ ~ "'~r~a~ ........ ;'; ....... ~ ~a,~ ....... - e~~ _ ~~m · ~te ~ .~n .... -,- ~ $ubJ~ ~ nmn~ ~ and ~n~ ~ ~ ~ ~ ~ ~r: fl~ to p~ ~ ~. Note ~ that If the ~ of the payments and cmdite which am posted te .your to your A,'~__ Jnt co your next statement. ~: DEFAULT ~ You w~ be in default If you fall to make any Minimum Payment .......... ~,, p~/m~m aue, your VISA loan Is in default. · "-~-v '<' miry us m matenam/ reduced by a chanco in your ~ ~,r..~..,, ................ .~..w,.,~/pfoceso ngs Invelvleg you imorast materially decliRe~ We have the -=-,~ ...... :.~,_ --- .:-: ...... seco, ~.??, nt ~mce If yo~ de~u~ subject to oar giving yoa any notice reoulrsd ~, m me extent permitted by law, yco will also be required to pay our ~ollecti<~ expenses, including court costs and reasonable attorney fees. 9. USING THE CARD -- To mal~ a purchase or ,~,_~h advance, there are two ,.-~, ..,u, .m ~.~ru ~. afl .w. Romated Teller ~ or other type Of electronic monthly statement will identify the merchant, electronic terminal or f~anclal Ir~itutio~ 10. RETURNs AND ADJUSTMENTS ~ Memhams and o~ers who hcoor the card may give credit to~ returns and adjustments, and ~ will do so by sand'.~l us a credit slip which we will post to your account. If your credit and payments exceed amomascally rater six mon~. .-- ..... -,-... v. your MAC card(s) constifutes acceptance of the terms and conditions of this Agreement, You understand that MAC· is a credit-related service and you authorize PSECU to obtain a credit report on any users of this account. 1. Acoounte and U~es of MONEY ACCESS CARD You have the account(s) (including Chacideg and Regular Shares), which we set forth on your ap~ication form with this Agreement. You hereby request that we issue to you one or more MONEY ACCESS CARD(s) to be used in connection .with such accounts as described In this Agreement. You understand you may use the MONEY AC~ES~ CARD at a MONEY AC~ES~ CENTER· to (1) withdrew cash from. (2) make or arrange lor deposits In. (3) effect trar~ffers to or from your account, (4) receive info~natico regarding tha balance In your account(s) or (5) make cash advances from your credit account(s) iR the amounts you request, yoa may also use automated teller bear the PLUS SY~ I eM" name and lego (1) to make wtihdrawala from. (2) effect ~.nders to or from. (3) recolve iRtom~atlco regarding Iha balances In your avallal~ and whk~ we edv~se you are offered iR coanect:on wi~ your ascount(s) Io the relas and regulstlans of esch account whlch is _m~.._ __.~sod by ~uoh Card' 2. Use of Pemonal Identlflcation Number (~PiN-) wtth MONEY ACCESS CARD You understand that a MONEY ACCESS CENTER or a PLUS SYSTEM ATM is an automated teller, It can and will perk)rm many of the came tasks as a human teller, You acfmow~ that the Personal Identifmatico Number or PIN which you uae with the MONEY ACCESS CARD is your signature, Identifies the bearer of the Card to the MONEY',,(CCESS CENTER, PLUS SYSTEM ATM, or other nebvo,'l< ArM and authenticates and validates the directions glvan just as your ' actuat elgnatum and oemr proof Identify you and authenticate and validate'your validate the directions given just as your actual signature will authantJcate and validate your directions given to us. You acknowledge that your PIN is an identification code that is personal and confidential and that the use of the PIN N-- ~, ,~/~ ~mc= ,,..) I,Pa'd:: ALL REASONABLE PRECAUTIONS THAT O ONE ELSE LEARNS YOUR PIN. 3. Uablll~/for Unauthorized Tranesctlons You agree to contact us at once if you believe the MONEY ACCESS CARD(s) issued to you or PIN has been lost or stolen or money is missing from your account(s). You also agree that ff your mor~ statement ~hows transactions statement was mailed to you, you may not get any money ~ after that time. YOU A~REE THAT IF YOU GIVE YOUR MONEY ACCESS GARD($) and PIN TO SOMEONE ELSE TO USE YOU ARE AUTHORIZING THEM TO ACT ON YOUR BEHALF AND YOU WILL BE RESPONSISLE FOR ANY USE OF THE t° notify PSECU of the Ioas of your MONEy ACCEl8 CARD or PiN. Safeguard your Persorml ide~ Number (PIN). Do not tell ~ ~ ~ PIN to any keep a wflttan recoed of your PIN near your MONEY N::~'~=,.~ CARD. Do not · chooes a PIN that la caslly Idonflrmble. retained by the MONEY ACX;ESS CENTER, PLUS SYSTEM, or HONOR ArM. 4. Ct~gea You egree to pay a 50 cont charge lot esc~ depeslt or wit~:lrawal ex__,~_~eding 1~ a month. You egres t0 Pay fha S0 cent penaity charge an any caah dlabu~emant or tmr-'oan~Ion fes~ whic~ are cha~ged by us for these ~ewk~as or lot asnacas from time to flma. You agree that wtten you make a depeait at a MONEY ACCESS CENTER that avaaaUla for Immedlete wie, drewa] and mst fha avallal~lay of your deposit ahall ~CENTE~FIS nmy accept depesJts and e~me MONEY ACCESS CE 6. -,.,- ~ -.o ,~,.memem aha the agreement foe such account. You agree tinst if make account(s) with Items other then c~shyo~c~ ~ or.payments to your t , oraes or o;ner ifeme) and we are not collected or, ~,,,,~,,= u, suc~ runes from your acoount(s) which if the funds In your account(s) are insufficient at such time you will promptly pay to us any amount of such funds which are not collected. 7. Amendment of thle Agreement You agree that from time to time we may amend or ctmnge the terms of.INs agreement Inc~udlng amendments or changes to add further MONEY ACCESS CARD servloes or to amend m chenge the ,~,~,,.,~ for ,,. of the M .-- -I,I ul SUCh 8mendmerlts or $ and ONEY ACCESS CARD after the effective dab change your use or change shall constitute your acceptance of end agreement to such amendment or change. 8. Ownership You agree that the MONEY ACCESS CARD is our property and you will surrender it to us upa~ sur request. You agree that the MONEY ACCESs CAFID is non-transferrable. g. Dieclo~uree You hereby acknowledge receipt of the discfosure statement informing you of y°ur dghts under the Electronic Futx~s Transfer Act and a copy of this Agreement. REGULATION "E" DISCLOSURE 1. Summmy of Consumer Ltebitl~ ' MAC'ACHandSST'Tellusatonoeifyoupalleveyourcardhasbeenlustor stolen. Telephoning is the best way to keep your passible losses down. You could ~ all the money in your account plus your maximum overdraft line of credit. If You palieve your card has been lest or stolen, end ~,~:~u taft us wlihin two business days after you foam of the loss or theft, you can loss no mere than $50 if If you do nut tell us within two business days after you learn of the ~ or theft ~'~u war'out YOor parmissldn if you had told, ~ '~u ........ r~ your Also, -~,,v ~'.~,u ~ose es mus~ es $500. if your statement shows transfers ttmt you did not make, tell us et once. If ~oe~t ~c~elal nU~v _w~__~..60_.d. ,a_y?. aff.~r the statement was mailed ,o you, youme¥ if a goud reeson such es a long ~p or a hespltal stay kept you from telling us' 2. Telephone Number and Address to NOtify of Unautho~tzedTranefera * MAC. Contact PSECU at (800) 237-7328 or Money A~cees Sewice (MAC) at (800) 523-4175 during PSECU non-lx~nees hours, ~en follow up by contacting . PSECU at (800) 237-7328 the next business day. AC/./ and SST - Contact PSECU at (800) 237-7328 (nationwide) or Or write to us at: Ponnaylvanla State Empteyoel Credft Union RO. 8ox 67013 Hards~rg. PA PSECU Buslnes. Hour, 7.~0 a.m. - 5.~0 p.m. M - F 8:00 a.m. - Noon ~tum~ TDD (800) 472-1967 Haflonwlda ]. Financial In~tl~ution.e Bu, lnese ~ ' .MA.C, ACff and ~. PSECU'$ Bu~ness Days are Monday through Friday, 4. ~ of Etectronl¢ Transfers a Consumer May Make g. · MAC - Balance inquiries on checking, eavthgs and PSL; withdrawals from * cheoldng/savfogs; cash advance from PSL; deposits to checldng/savfogs; purchase goods and services at any accepling retail estal~ishment. · ACH - Preauthodzed debits and a. edits to cheoldng and savthgs. · SST. 8alenus inquftles end tmn,~_ _c.,j~on histories on ali .hare, certitiCate and loan --'Y~--.,nt~; trausfors from any share to another ,ham or ldan m~oount from s. ~y C~rges for FJestronlc ~;~~~~r 15 ~ ~ e~ ~ ~ ~r ~, a~ a ~ ~nt 6. ' ACHa~.y~a~~ a~nt, ~~ ~ ~ ~ ~, , PSECU ~y Im~ dufl~ ~e ~ ~ ~ ~ ~us If ~ · ~o ~~ror~t ~ ~n ~' 7, ~ · ~Ca~- N~ ~. · AC~. Right Un~ RO ~6~*eu~ZL.' -. ~h .... =x'~~~ ~:"_: ~' ~..r~y'~ nm'~, ~ 171~7013, ~ ~ ~r ~ ~ ~ ~-;~ ~ ~ ~n 14~r~. ~r pr~o~ ~, or ~t. us~st~ o~of · ~er b ~u~, ~ ~ ~ ~ ~ ~, ~ ~1 ~ ~ ~r ~r ~ or ~ ~1 to g~ us ~foc 8. Sum~ of ~e R~nclal InatE~on's Faitum to Make or Stop ~ln Tin.f em ' MAC.~ECU~bto~tea~~orln~~u~ (6) ~ur ~ or ~ A~; (9) ~ ~m ~ ~ ~ ~ ~ ~, ~, ~ ~r m~, ~ ~ ~ ~r m~ ~ ~; (10) ff ~ aff~ to ~ sub]~ to ~ ~1~ ~t ~ ~ ~ a~ ~ ~, ~m, or ~r ~, ~ ~ ~r ~~ ~to~e~. Di~osum to -w, ~ a ~ ~r~u; (3) to ~ ~ ~ a~ ~ ~m; (4) ~ a~ ~ ~r ~ ~M~; (5) ~ ~ ~ ~m or a~ a~ ~ ~. m ~n ~m; ~6) ~ ~ of ;'---~--~lc Fund= ~-,~. MAC A=~=~,~-,~nt and R~ulatl~n 'E' DlsctOsur~ (c.~_-__.,~d)_ 10. MONEY ACCESS CENTER Servfoea Ide~T~catJon Number (PIN) at MONEY ACCESS CENTERS located In Delaware, a) Deteml~e the ~z~ount balance(s) of ),our Chec~ng your Fl~oular Shares and your Pemorml Service Loan (PSL). b) W*~rew cash from your Checking and your Regular Shares. c) Make a cash advance from your Personal Service Loan (PGL). d) Dep<~dt currency, checks, or dra~ (cains ere no{ ecceptab~) for transmlaslo~ to PSECU for deport in your Checking and your Regular Shares. NOTE: There are limited lecafione in Maryland where deposits may be made. We wish to inform you that some MONEY ACCESS CENTERs located in these areas may o~ly provide access to your Checking, your Regular Shares, and your Perseeal Service Loan. Not all MONEY ACCESS CENTERs may accept deposits. There may also be limits on the amount of funds which you may deposit in certain MONEY ACCESS CENTERS. 11. PLUS SYSTEM* Services ° MAC Only - You may use your MONEY ACCESS CARD with your Perao~al Identification Number (PIN) at arE PLUS SY,~i EM automated teller machine (PLUS SYSTEM ArM) located throughout the United States, Puerto Rico, Canada, Great Bntaln and Japan to conduct any of the following transactione on the accounts accessed by your MONEY ACCESS CARD. a) Determine the account balance(s) Of your Chactdng, your Regular Shares, and your Personal Service Loan (PSL). b) Withdraw cash from your Checking and your Regular Shares. c) Make a cash advance from your Personal Sera'ice Loan (PSL). NOTE: Deposits are not available through PLUS SYSTEM ArMs. These are the MONEY ACCESS CENTER sen4x:as currontiy available through the PLUS SYSTEM network. Other services may be offered in the future. 12. HONOR' System Sen~lces * MAC Only - You may use your MONEY ACCESS CARD wflh your Pemonal Identitk'.ation Number (PIN) at any HONOR automated toiler machine (HONOR ArM) located throughout Florida and other areas where therp are HONOR ATMs. The following transactions may be done on the aCcouhts accessed by your MONEY ACCESS CARD. a) Determine the account balanoe(s) of your Checking, your Regular Shares, and your Personal Service Loan (PSL). b) W'~xJraw cash from your Chacldng and your Regular Shares. c) Make a cash advance from your Personal Sen. ice Loan (PSL). NOTE.: Deposits are not available through HONOR SYSTEM ArMs. ............. ,,~u~ur sefv,,ces may De oltared in the futura. 13. Other ATM Network Access * MACOnly-Fromtirnetofime, PSECUmaymakearrangementswithotherATM networks to grant access to MONEY ACCESS CARDs. PSECU shall ioform you whert such anangaments are made and describe the services that are available to you. Any charges will also be described. 14. Purchase Treneactlons * MACOnly'YoumayasetheMoNEYACCESSCARDtopurchesegoodeand ash, rices ("Purchase") at any retail establishmeN ('Merchon~) where MONEY ACCESS CARDs are accepted by such ~L The amount of ali Purchases will be deducted from your ~. When you make a Purchase using the MONEY ACCESS CARD, you will be requesting PSECU to withdraw funds from your ChacHeg In the amount of the Purchase and directing PSECU to PaY these funds fo such Morchan[ 15. Umlt~on~ on IJte Use of your MONEY ACCESS CARD * MAC On/y' You may withdraw up to $500 bar day from one or a combluatlon of your accounts by Dethg a MONEY ACCESS CARD Ixovided the funds are focusers: PSE(~I re.ryes Ifm fight to reduce this daliy limit at may time. In limitation. The cl~ for wttndrewal limits staris at 12 midnight each day ~ ends these limitations are not revealed Un/on Is not obliged to maintain such I~italions, You will be denied use of your MONEY ACCESS CARD it you ex~:~ed the daily w'CdxlrawaVpumhasa limit, it you de net have adequate funds available in your account, do not enter the correct Personal Identif~satlon Number (PIN), or e MONEY c~=rt, PLUS SYSTEM. or HONOR System ATM; or Merchant terminal will notify yo~ of the denial. There Is a limit on the number of such denials permitled. Attempts to exceed the limit will result in machine retention of 16. Err~.'~ Reeolutlon Procedures ' ' 1 * _MA.C, ACH and SST - In case of errom or questions about - - U~rect Indulriss to PSECU at (800) 237-7328 Natlenwld. -------. ,~,u [~O) 472-1967 Nation, (717) 777-2100 In Ha~rg, or write PSECU at: Pennsy~ State Emplc..c~-.- Credit Uniee, P.O. Sex 67013, Har~,~3urg, PA 17106-7013, es more information about · transecti~ listed on the statement or reDelp~ PSECU must hear from you no later thon 60 days after It sent you the flint statement on which the problem or en~' appeared. You must provide the foitowlng k~xmalion: la) Your name, account number, and MONEY ACCESS CARD number (if a MAC error or Itm tmneactiou you are .na.,~ .~,.... --'-~"~'~. ~_/; ........ ,=.,uu,, an~ ex~n es cleerty as Y°U con why you believe it is an error or why you noed the inforrne and; lc) The dollar amount Of the suspected error. ._tion. If you tell PSECU orally, you must send your complaint or questiofl in wrffJn~ within 10 I~sinass days. PSECU will toll you the resutts Of the ONEY ACCESS cENTE., PLUS ~YSTEM, SELF-SERVICE TELEPHONE, or DIRECT DEBFi:/~ TRANSACTIONS, or 20 days for MONEY ACCESS CENTER purchase transactions. If we need more time, however, we may take up to 45 days for MONEY ACCESS CENTER, PLUS SYSTEM, HONOR SYSTEM, SELF- SERVICE TELEPHONE, or DIRECT DEBFI'/CRED(T TRANSACTIONS or 90 days for MONEY ACCESS CENTER purchase transactions, ff PSECU dec~des .~T ~WC~ ~JIc. N I I=PI, PLUS 8Y8'1P_.M SYSTEM SELF-SEm~-',c '~- ............ HONOR transaction, ,,.,.-,~ ,~-~'n~.,r~c, or uIRECT DEBIT/CREDT or 20 businoas days ff it is · MONEY ACCESS CENTER purchase treneactiorc you will have the use of tha money dudeg the time it takes to complete the investigation. If PSECU does not receive your comp~nt or question in writing within 10 business days, PSECU may not recmdit your account. If PSECU decides 1here is no error, you will he advised w~hin three business days after the investigation is completed. You may ask for copies of the documents PSECU used in the inveslJgation. If PSECU credits your account while investigating, you must repay ~ funds if PSECU concfudes no error has occurred. Notice To Coneumere Using ATM'a * Be alert to your surroundings, If you doubt the safety of a particular location,, choose another ATM. * If the ATM has an entry door, close the door prior to initiating your transaction. * Put your cash away immediately. * Direct complaints conceroing ArM security to an appropriate department of the owner of the ArM. New Jersey realdents: you may call Ute New Jersey Department of Banking at (609) 292o7272. those members who purchase a vehicle under the DRIV Program, please review the following FTC 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 WITH THE PROCEEDS HEREOF. 'RECOVERY HEREUNDER BYTHE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW AND NOW, this ~ day of ~ , 2002, I, Steven C. Courtney, Esq., of Metzger, Wickersham, Knauss & Erb, P.C.J attorneys for Plaintiff, hereby certify that I served the foregoing Complaint this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 By: Document #: 234204.1 l'#0'2Pt'~ :# tuomnoo(l 09£8 t Vd ,itmqspnox~s 1,oxlS qux~S LIL o~.nbs~I 'IO$O.Pd llm[t o/D ~opoA p~u(I 3AV'-I' MOI&DV "IIAID AD-OSgZO't;O 'OM lugpua~a(I '}I~IO0.X '1t OIAVO 'MOIMfl .LI(ISII:ID S~I~IXO"IdlAI~I ~I&V£S VIMVA'-IA, siq-M~Id ViNiVA~L~S~Id 'A.I.MflOD tlNIVTtI~tItlAIflD SVWId NIOIAIIAIOD AO .LltflO;D ~IH.L MI COURT OF COMMON pi F~.S OF CUMBERLAND COUNTY PENNSYLVANIA PA State Employees Credit Union, Plaintiff, David R. Yoder, Defendant. 02-2350 CV DJ Appeal AFFIDAVIT OF SERVICE I, Brett J. Riegel, Esq., being duly sworn according to law, deposes and says: That on May 17, 2002, he mailed a true and correct copy of the District Justice Appeal by Certified Mail, Return Receipt requested to PA State Employees Credit Union, c/o their attorney, Steven C. Courtney. A copy of the Certified Mail Receipt and the original signed Return Receipt Card are attached as Exhibit A. That on May 17, 2002, he mailed a true and correct copy of the District Justice Appeal by Certified Mail, Return Receipt requested to The Honorable Paula P. Correal. The original signed return receipt card and the Receipt for Certified Mail are attached collectively as Exhibit "B" and are incorporated by reference. Brett J. Riegel, E~squire f Sworn to and subscribed I~J before me this ~,~J,- day of 3LIC ' '1 Stro~lsburg Bom, Monroe County My Commlaal-on Explrel ,J.fle 19, Mm'nl3er, Pennsylvania Asso(~atlon O~ N0WI# ,2002. r'-I Postage IJ'J Certified Fee Return Receipt Fee (Endorsement Required) I-'1 Restricted Delivery Fee r-i (Endorsement Required) Total Postage & Fees Here · ~ iterns 1, 2, and 3. Aiso COmplete item 4 if Restricted Deliver/is de~ired. · Print your name and addmee oa the reveme ~so that we can tatum the card to you. · ~,ttacl~. this card to the back of the mailplece, Nam*) D. M d~Nee/address different from item 17 r'lyes ::If YES, eater delivery addmes below: [] No / mi ' Se~ice Type ~ Mail [] ~ MS}I [] Registered l~J~l~um Receipt for Memhandise [] Insured Mall [] C.O.D. · Restricted Daiiveoj? (Ex~a Fee) [] Yes 2. A~ Number ~s mx, 3811, ~ust 2ffil -:'.' '~c R~ur2 R~eim 102595-01 -M-2509 Return Receipt Fee ' i H/~ .............. LLC . · Complete Items 1, 2, and 3. Also complete item 4 If Fle~trlcted 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, D, Is ddvaY ;=:ldrem cilb,ent tram ~.m 17 ' If YES, en~ c~lve~y adclm~ bek)w:. [] Insured Mall r'lNo Express Mai ~,Retum Receipt for Memhandi~e C.O.D. 4. Resbicted Del~? (Exlra Fee) [] Yes 2. Article Number PS Form 3811, August 2001 Domesti~l~a;~eceipt 102595-01-M-2509 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW PROOF OF SERVICE BY MAIL I, Steven C. Courtney, Esquire, do hereby certify that onMay 22, 2002, a copy of the Complaint was received by the following person by certified mail, as is evidenced by the Certified Mail Return Receipt Card attached hereto as Exhibit "A." David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 Respectfully submitted'/ M~AUSS & ERB, P.C. By: Steven ~ou~ney~, Esq~ 3211 N. Front Street Box 5300 Harrisburg, PA 17110 (717) 238-8187 I.D. # 74669 Attorney for Plaintiff Document #: 204237.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION PSECU, Plaintiff V. David R. Yoder, Defendant No. 02-02350-CV Civil Action Law NOTICE To the Plaintiff, Pennsylvania State Employees Credit Union you must answer the enclosed preliminary objections or file an amended pleading within twenty days. If you take neither of these steps, a judgment may be entered against you. Brett J. Riegel,/Esq. / Date: x~/~[/O 7_~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION PSECU, Plaintiff : . V. : .- David R. Yoder, Defendant : No. 02-02350-CV Civil Action Law PRELIMINARY OBJECTIONS Defendant, David R. Yoder, objects to the Complaint of Plaintiff on the following basis: 1. PARCP 1019 (i) requires the attachment of any writings which form a basis for the Complaint. 2. The Complaint references in Paragraph nine and ten certain statements of account. 3. Defendant submits that the failure to attach these statements of account are a violation of PARCP 1019 (i). 4. The statements of account prior to the alleged date of default, March 30, 2001 do not need to be attached. WHEREFORE, the Defendant, David R. Yoder respectfully request the court dismiss the Complaint for failure to comply with a rule of law as contemplated under PARCP 1028 (a) (2). Respectfully submitted, Amori & Riegel, LLC 717 Sarah Street Stroudsburg, PA 18360 Atty. ID# 76448 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION PSECU, Plaintiff V. David R. Yoder, Defendant no. 02-02350-cv Civil Action Law CERTIFICATE OF SERVICE I, Sara Fisher, of Amofi and Riegel, LLC hereby certify that service of the foregoing documents were made upon: Steven C. Courtney 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 by mailing, first class, postage prepaid on May,~, 2002. Sara Fisher of Amofi & Riegel, LLC 717 Sarah St. Stroudsburg, PA 18360 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaht and Notice is served, by entering a written appearance, personally or by 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 document, or for any other claim or relief requested by the Plaintiff. You may lose money or property or other fights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICIA Le han demandado a used en la corte. Si used quiere defenderse de estas demandas expuestas en las paginas siguientes, used fiene viente (20) dias de plazo al partir de la fecha de lademanda y la nofificacion. Used debe presentar una apariencia escfita o en persona o pot abogado y archivar en la corte en forma escfita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y puede entrar una orden contra used sin previo aviso o nofificacion y por cualquier queja o alivio que es pedido en la petition de demanda. Used puede perder dinero o sus propiedades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVI2IO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 800-990-9108 Document #: 234204.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW AMENDED COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Steven C. Courtney, Esquire and Metzger, Wickersham, Knauss & Erb, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Union, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, David Yoder, is an adult individual with a last known address of 1422 Bradley Drive Apartment C-313, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant is, and at all relevant times material hereto was, the applicant for a Visa Loan with Plaintiff. 4. On or about February 1, 1997, Defendant applied to Plaintifffor a Visa Loan. A true and correct copy of the loan application is attached hereto, incorporated herein and marked as Exhibit "A". Document #: 234204. I 5. Pursuant to the loan application marked as Exhibit "A", Defendant agreed to the terms and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (hereinafter referred to as "Contract"). A true and correct copy of the Loanliner Credit and Security Agreement is attached hereto, incorporated herein and marked as Exhibit "B". 6. The contract marked as Exhibit "B" contains the temts and conditions of the extension of credit agreed to by Defendant. Various charges and/or purchases were made by Defendant on the Visa Loan with Plaintiff. 8. Defendant has not made a payment on account of the Visa Loan with Plaintiff since March 30, 2001. 9. Plaintiff has maintained a statement of account keeping an accurate and running amount of debits and credits made on Defendant's account. 10. Plaintiff has submitted to Defendant a copy of the statement of account accurately showing all debits and credits for transactions with Defendant. 11. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 12. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay ail sums due and owing on Defendant's loan account balance, all to the damage of Plaintiff. 13. As of May 13, 2002, the balance due, owing and unpaid on Defendant's Visa Loan account with Plaintiff is the sum of Two Thousand Nine Hundred Ninety-five and 18/100 Dollars Document #: 234204.1 ($2,995.18). A true and correct copy of the Statement of Account is attached hereto, incorporated herein and marked as Exhibit "C". 14. Pursuant to the terms and conditions of the extension of credit contained on the loan application, Plaintiffis entitled to receive and Defendant agreed to pay an annual interest charge on the principal loan balance. 15. Pursuant to the t¢i-iiis and conditions of the extension of credit, Defendant agreed to pay reasonable attorney's fees and ail court and collection costs. 16. Plaintiffhas retained the services of the law firm ofMetzger, Wickersham, Knauss & Erb, P.C. in the collection of the amounts due and owing by Defendant. 17. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office ofMetzger, Wickersham, Knauss & Erb, P.C. in the collection of the amounts due from Defendant incident to the within action, and Plaintiffshall continue to incur such attorney's fees throughout the conclusion of the proceedings. 18. The amount of attorney's fees and prior district justice costs incurred in this matter is the sum of Six Hundred Eighty-five and 02/100 Dollars ($685.02). 19. Any and ail conditions precedent to the bringing of this action have been performed by Plaintiff. 20. The amount in controversy is within the jursdicfional amount requiring compulsory arbitration.. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, David R. Yoder, in the amount of Two Thousand Nine Hundred Ninety-five and 18/100 Dollars ($2,995.18), plus Document #: 234204.1 interest, reasonable attorney's fees and prior district justice costs in the amount of Six Hundred Eighty-five and 02/100 Dollars ($685.02), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, Dated: 2002 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. 3211 N. Front Street Box 5300 Harrisburg, PA 17110 (717) 238-8187 I.D. # 74669 Attorney for Plaintiff Document #: 234204.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW AND NOW, this __~y of 4~,-l~ ~-~ , 2002, I, Steven C. Courtney, Esq., of Metzger, Wickersham, Knaff~sss & Erb, P.~., attorneys for Plaintiff, hereby certify that I served the foregoing Amended Complaint this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 Document #: 234204.1 VERIFICATION I, Bonnie L. Berkoski, hereby certify that the following is correct: 1-he facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by coUnSel and/or others acting on my behalf in this matter. The language of the Complaim is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have givento counsel, it is true and correct to the best of my knowledge, information, and belief. '1-o the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Bonnie L. Berkoski ' ~ Date: Docum*nt it,, 180122.1 PSEC A "WI. '~IN" OFFER FRO~I PSECU! You're Pre-ApproVed for up to $10,000 on our 9.9% APR Capitol Card ®VISAS! DAVID R YODER 1422 BRADLEY DP. APT C 313 CARLISLE PA 170t3-1266 //om do l~ou urin? FEB 0 6 1997 There's never been a better time to take advantage of PSECU's Capitol C~d ~VISA~ With our 9.9% APR rate for p~cha~s ~d o~ 12.9% ~R for c~h adv~ces ~d VISA Checks, ~ere's no better c~d on ~e m~kefl And to make it even better, you're pre-approved! Just take a minute to fill out and s/gn the short applicaflon below, and we'l~ send you a Capitol Card VISA. You.r good credit history allows us to make you fi-ds 'kvin-win" offer - you'l.1 receive our ' 9.9% YqsA w/th no annual fee. - * 9.9% APR'for purchases, 12.9% APR for Chee. l~ or Cash Advances. * . VISA Che~s - to pay off ~ ~terest c[e~t c~ds elsewhere. * No ~nu~'F~. * No C~h Ad~ F~. * Up ~ 25 da~ of ~ on pu~. * ~m~st~n ~SA/~~. How does PBEC'U urln? * We have your business! Hurt>,/ Offer Expires February 28, 1997 (Offer good only to indh'idual named ~elow) 289PJVlK708A569 PI~ p~t ~ ~uest~ ~fomtion. [n~mple~ fo~s may ~u~ ~e~ys ~ p~ss~g yo~ apportion or a ~c~. Home ~o~ B~ Date DA~ YODER (717) ~8~718 1Z/27/61 S~i~ 8~, N~r/Ac~t OrossAnnusllncome [] Upm$1S,000 [] tI5,0Ol - $2~,=oo [~22,501 - $30,000 Please send an additional e~.~l ~.t wa ~--~ ~ loc (please ~,nt clearly): Ft~L Na~ ~ S30,00l to $36,000 [] $36,001 to $48,000 [] $48,001 to $60,000 M~ddle Ink:al Last Name ! ha~ read this form and et/er-,~ir~ I ha~ stated in it is t~e You ar~ authorized to obtain ~ empro$onen'~ ~iisior~ or any other infan'no. Mon a~d [o re~r~ to ot~ *u~ ~o~ion ~d ~dit e~n'~ with ~ I ~ee that ~ .~t~ s~ll ~ gc~med by all ~ te~ ~ ~i~ o/the ~A~N~R ~dt~ A~e~ ~'~ t~ ~it Unio~ all ~dend~. ~ ~ ~ th~to ~d all [he'~ ~d ~it~ ~ ~ .ro~ on ~ ~a~ed d~cl~ure~ ~ ail th~e do~n~ s~ll ~ (n~ he.in by [~s ~fe~ - - ~, / . , / ~ -- ~ ml~e~ e~dl~ ~ o. ~0 to. $ ,~0 ~d im yeu~ ¢~dt~ orL%,nel~ and ,n~me We ~ll de~ * .....~t O/)'our :~dit ~ne bated on ~e SCANNED. Hard~butg, PA IXt06.70*13 : , (717) ~ Harrisbu~g, (800) 237.X328 NaSOnV,~e Loan D sclosures "this LOANLINER' Credit and Security Agreement, which includes the Truth in I.ending Disclosures, will be referred to as the Plan. The ~ documents Include this Agreement and an Addendum. Yo~, your and borrower mean any pemo~ who signs the Ptem Credit Union, we, our and ua mean PSECU or anyone to whom the Credit Unlo~ transfers Its rights under the Plan. This is a multl-alste document which may be used to lend to borrowers in all states. 1. ROW'THIS PLAN WORKS --This is an open-end, multi-featured credit plan. We anticipate that, from time to time, you will borrow money (called 'advances*) under the Plan. We are not required to make advances to you under the Plan and can refuse · request for en advance et any time. The Addendum describes 'Ihs different {ypes of credit (called "subaccounts') available under the Plan, the ourrast interest rets for each subaccount expressed as a daily periodic rets and corresponding annual percentage rets and other charges. It may also have other terms and a schedule for determining the payment amounts. 2. 'CREDIT LIMIT -- We may, but do not have to, establish a credit limit un certain subaccounts. If a credit limit is set for a subaccount, you promise not to exceed the astsblished credit lim~ If you exceed the credit limit, you promise to repay immediately the amount which exceeds the credit limit. 3. REPAYMENT ~You promise to repay all amounts you owe under the Plan plus interest. Payments are due un the last day of the month unlase we set a different date at the time of an advance. If the Addendum has no payment schedule for a subaccount, your payment will be determined at the time of each advance. Payments must include any amoun~ past due and any amount by which you have exceeded any credit limit you have been given for a subeccount. You may repay all or pa~t of what you owe at any time without any prepayment penalty. Even it you prepay, you will still be required to make the regularly scheduled payments unless we agree in writing to a change in the payment schedule. If you have a joint share draft account, you will be responsible for paying all overdraft advances obtained by a joint hofdar of the share draft account. Payments will be applied in the order the Credit Union chooses. 4. PLAN ACCESS ~ You can obtain credit edvancas in any manner authorized by us. It we allow you to use your ATM/Oeblt card to access the Plan, you may be liable tot the unauthorized use of your ATM/Oebit card. You will not be liable for unauthorized use that occurs after you notify us, orally Or in writing, of the loss, tt~ft, or possible unauthorized use. If you believe your ATM/Oebit card has been lost or stolen, immediately inform the Credit Union by calling or writing us at the teisphona number or address that ~rs elsewhere in the Plan. If the card is used to obtain advances directly from the Plan, your liability will not exceed $50. If the un~utho~zed wltndrewal is from a share draft account, your liability is governed by the Regulation E disclosures you received at the time you received your ATM/Debit card, even if the withdrewat results in an advance being made from your overdreif subaccount. 5. RNANCE CHARGE ~ 'l'i~ dollar amount you p~/for money borrowed is called a'fin~nce change' and begins on the date of each advance. A finance charge will be computed separately fo~ each separate balance under the Plan. To comi~ute the an advance if YOu have not yot made a payrnant) is multiplied by the apl:~:~t~e deity )en~io reto. The sum of thase amounts is the finance charge owed.'The balance have beon made. th eddffion to interest, we may charge other tinasca charges which are disofosed on the Addendum. If the interest rets is a veriable Interest rata, the Addendum explains how ~ varlabla interest rets works. 6, SECURITY INTERE~'~I' ~ The Plan is secured by the shares and delx~lts in eli joint and individual accounts you have with the Credit Union now and I~ the future. Shares and depestts in ~n Individual Retirement Account an~ any other account which would lose ~ tax Ireatment under state or federal law if given as security are not subject fo ~e security interest you have glvon in your ~hare~ and delX~lts. advance Is requested. For example, a eobaccount called 'New Car Advances' means the security will be a new car. A suhaccount cal~d *Other Secured Advances* means you must offer security acceptable fo the Credit Union for If~ advance. Preperty given as security for any advance under the Plan will secure all other amounts you owe under the Plan or under any ofher Agreement with us now or in the future. Pre~erty asc~Jdng other loans with us may also secure the Plan. However, if you have given your dwelling as security for a loan with us, that dwelling will not SeCUre an edvance made under the Plan. 7. PROPERTY INSURANCE, TAXES AND FEES --You will be required to perchase property insurence un certain types of security thst you give fro' advances. Yo~j ~CUNA MUTUAL G~OUP. 1~0. ~2. ~4, 8~, ~. ST. ALL RIGHT~ RESERVEO If you cancel your insurance and get a refund, we have a K~ht to the refund. If the property is lost cr demaged, we can use the ins~rasce settlement to repair the c~? .or..r~/.. to~ ~ ~ owe. You su~x.~ze us fo endo~ a~/dre, or wnK:n may oe payable to you ~n order for us to collect any refund or benefits due under your Insurenoe policy. You promise to pay all taxes and fees (like registration foes) due on the property and to keep the property insured against loss and damage. If YOU do not PaY the taxes or faas on the preparty whan doe or keep it insured, we ~cn~t.y pay these o~. Igaifons, but we are not required fo do so. Any money we ~,,~,~ taxes, fees cr ~nsuranco will be added to the unpaid balance of the you will pay interest on those amounts at the same rate you agreed to pay un the advance. We may receive payments in co~neofion with the insurenco from a company which provides the insurance. We may rno~itor our loans for the purpose of determining whether you and other bonowers have complied with the Insurance requirements of its loan agreamonts or may engage others fo de so.~ insurance chaq~:l added to your advance may include (1) the insurance co~s payments wu ~ amoums ~or rexes, mas or ~suranco to the unpaid balance of your advance, we may Increase your payments to pay the amount added within the term of the insurance or aplxoximeta term of the advance. 8. NOTICE ~ If you do not purcl~ the required property insurance, the insurance we may purchase and change you for will cover only our interest in the preperly. The Insurance will not be liability Insurance. 9. CREDIT INSURANCE -- Credit lite and/or credit disability Insurenue is opfiunal under the Plan. If you qualify for and purchase the insurance from us, you authorize us to add the Insurance premiums monthly to your loan balance and charge you interest on the entire balance. If you elect credit insuranoe, your payments may increase or the period of time necessary to repay your advance may be extended beyond the approximate term stated un the Addendum. The credit insurance mtas may change during the Plan. If the rates change, we will provide any notices required by applicable law. 10. PERIODIC STATEMENT -- On a regular basis you will receive a statement showing all transactions under the Plan during the period covered by the statement, Statements and notices will be sent to you at the most recent address you have given us in writing. Unless applicable law requires notice to each joint bon'ower, notice to any one of you will be notice to all. 11. JOINT ACCOUNTS ~ If this is a joint account, each of you is in~n~lually and jointly rasponslble for paying eli amounts owed. That means we can enforce our rights under the Plan against any one of you individually or against alt of you together. If you give us inconsistant InstnJcfluns, we can refuse to follow your instructions. Unless our written policy requires all of you to sign for an advance, each of you authorizes the ofhar(s) to obtain advances ind'widually and agrees to repay advances made foJhe oihar(s). 12. FEES AND CHARGES ~ If you give us a ascu~lty Interest th certain types of property, we may change yo~ a filing fee to pad~ac~ ~ Interset in the pn:~et~/. may efao cha~ge you ofhar fees In connection ~ the Plan.Those fees are dlscfosed on the Addondum and wilt be added fo yo~Jr loan I~alance unless you pay 13. UPDATING CREDIT INFORMAllON --You ixomlse that y~J will promptly give us wrltton notise If you mova, change y~ur camo or empk~ca~t, or If any ofhar information you provided to us changes. Upon our request you aJso agree to pn~lde us updated financial information. 14. DEFAULT ~ The foil°wing paragraph applies to borrowem In Idaho, Kansas, Maine eed ..eouff~ Carolina: You. will be in default if you do not make a payment of the amount required ~ften it is due. You will also be In default if we boilave the prospect of paymont, perlormance, or realtzatiun un any pro,arty given The following paragtaplt ~ppllea only to bot~o~ I~ ~ln: You will de in default ff you fail to make a payment when due two times during any 12-m~lth period. Yo~ will be in default ff breaking any promise made under the Plan materially impairs your ability to repay what you owe. You will also be In delauit ff breaking eny promise made undm' a Security Agreement made in connsctiun with an advance, materially impairs the condition, value, or protection of or our right in the prckoerty you gave ~ setup. ff you are more than 10 days late In reeking a paymer~You will also be in datauit If PSECU JBXXOeO~.t 0~7-2092-~ (3,X)O) The following paragraph mpplte~ to borrowem In mil other mtataa: You wi# be in ~de~u~ ..do not.make a payment of the amount required whan It Is due. You will °maun · Ycu omar< eny promise you made undor the plan or It any<me IS In delault under any security agraem~t made In ocmnec~3n w~ an advance undar make enY ~ or misfaedlng s~atemems in eny cre0lt applkmtlo~ o¢ update of cradit default under any other loan agreement with us. 15. ACTIONS AFTER DEFAULT ~ The following paragraph applies to borrowers In Colorado, District of Columbia, Iowa, Kansas, Maine, Massachusetts, Ml~oud, Nebraska, West Virginia and South Carolina: When you are In default anti after expiration of any right you have under applicabla state law to cure your default, we can demand Immediate payment of the entire unpaid balance under the Plan without giving yo~ advance notice. The following paragraph applies to borrowers In ell other states except, Wlasonsln and Loulafana: When you are In default, we can require immediate payment (&cceleratien) of the entire unpaid balance under the Plan. You waive any rtghl you have to demand for payment, notice of intent to accelerate and notice of accalaration. The following paragraphs apply to borrowers In all states except, Wl~con~/n and Lou/slana: If Immediate payment is demanded, you will (x)ndnue to pay Interest until what you owe has been repaid, at ~e applicable interest ratse In effect unless a default rate is disclseed en the Addendum. If a demand for Immediate payment applied towards vd~at you owe. We can also exercise any other rights given by law when you are in default. You agree the Credit Union has the right to take pesees~lon of any property given as security for an advance under the Plan without judicial process If this can be done wilhout breach of the peace. If we ask, you promise to deliver the propert7 at a time and place we choose. We will not be respensibla for any othor property, not covered by this Agreement, that you leave inside th~ property or that is attached to the property. We will try to return that property to you or make it avaiisb~e to you to clalm. a private sale will be held. Our expenses for taldng posses_~o~ of and selling the include the cost of stodng the praderty, prapadng It for seje end attomey, s fese to the exte~ permitted under state law or awarded under ,~S06(b) of Itm Benla'uptoy Code. The rast of the sale mo~ey wili be applied to wflat you owe under the plan. 16. ACTIONS AFicR DEFAULT- WISCONSIN -- THe following paragraph sppllas only to Wisconsin bon'owem: When you are In default and ~ter expimtio~ of any right you have under a,oplicaJb~e state law to cum your default, we may require immediate payment of your outstanding loan balance under the Plan and seek or we may seek to take pe~,,.~e.,sio~ of the property by judicial prc~e__~_~_. If we of the property. If the property is a motor vehicle, mobile home, trailer, m~)wmoblla, boat or airc~ft, you will aJse be required to pay any costs pemdtted by ~ 422.413 of the Wisceesin Statutes. '17. ACTIONS AFoUl DEFAULT -- lOUISIANA -- The ~/owing paragraph 18. CANCELUNG OR CHANGING' THE PLAN ~ T~e ~o/Io~ peragrap~ applies only to borrowers In Illinois: We have the right to change the terms of the Plan from time to time after giving you any ,~dvance notice required by law. Any change to the interest rate or other charges will apply to future advance. The ~ollowing paragraphs apply o~y to bormwem in W~mmsl~: We c~ change h tarrns of the Plen from time to time in aocordenca v~h Sentlen 422.415 in the daily periodic rate under a variable rate interest rate is not considered a change in terms under the Plan. We can cancel the entire Plan or any part of the pten at any time. You may cencal the Plan at any time by giving ,~ pdor w~ten notice. Your o~gation to pay the unpaid bebncas under the terms of the Pisn continues v/nether you'or the orealt ' ne ~v/'ng P~regrslm ~ omy m oormwera m ~wa: We can cha~e tt~ ~~to~~. ~ to u~ ~lt U~ ~ ~e ~ P~ ~ ~r ~ or ~ 19. DE~Y IN ~R~ RIG~ AND CH~GES IN ~E P~ ~ We ~ d~in~, ~u pr~l~ te g~ ~ ~m pm~ ~ ~ ~ ~ to ~ ~. ~ ~ of~ A~ ~e~, ~ ~ ~ of~ ~o~n or ~. (6) N~ ~ ~ p~ ~ ~ ~1 ~. 26. NO~ DAK~A N~E ~ BOR~S PURC~NG A M~I REPO~IO~ IF E ~ ~P~S~S~ ~D SO~ ~ ~MBONE ~D A~ AMOU~ DUE ~ ~E SE~R~ P~ ARE N~ RECEW~ II ~AT ~ ~U MAY ~ ~ PAY ~E DI~RENCE 27. VERMONT NOTICE TO. C~SIGNER ~ YOU; SIGNATURE ON THIS NOTE M~NS THAT YOU AR! EQUALLY UABLE FOR REPAYME~ OF~IS LO~. IFil unlen cancel the Plan. except to the extent that your liability is limifed by Sas~m BORROWER DOES NOT PAY, THE LENDER HAS A LEGAl 422.4155 of the VVIscorts~ Statutes. ~TTO COLLECT FROM YOU. NOTIFY US IN CASE OF ERRORS Off QUESTIONS ABOUTYOUR STATEMENT- If you think your statement is wrong, or If you need more infofmatibn about a transaction on your statement, write us on a separate sheet at the address listed or ~yo~r statement. Write to us as soon as ~___.~le. We must hear from you no later In your letler, give us the following intom~ation: ' * Your name and acccunt number. ' The do~r amount of the ~spscted eno~. ° Describe the emxand explain, Ifycu can, why you believe there'is an error. If you need more IoformaUon, describe the item you are not sure about. If you have amhodzed us to pay a credit card account automatically from your share account or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us three businees days bof~e the automatic payment is scheduled to occur. YOUR RION'I~ AND OUR RESPONSIBILITIES AFl ~-R WE RECEIVE YOUR WRII'rEN NOTICE. We must a~now~ your letter within 30 da have corrected the e~or by then. Within 9<3 days, we must -~ ys, unlas~ we explain why we believe the statement was correct. ~ner correct the emor or 'After we receive your letter, we cannot t~/to collect any amount you question, or report you as delinquent. We can continue to send statements to you for the amount ~a ~ ~t~t ~ibk~ ~ ......... ~, ~ ~r ~ ~ ~f e~,;~, ,~, ~_ ~Y, E we ~'t ~ ~ ml~, we ~n't ~11~ ~e fi~ ~ of ~ q~o~ ~oun  EClAL RU~ FOR ~E~ CARD PURCH~Es ~ ff ~ ~ a ~ , qu~ of p~ ~ ~ht ~t~ . ~t ~n ~,r ham ................ ~u ~ a~ ~ ~ p~ ~ ~. duplicates and re -'" ""~'~'.r~r~t:4mnleanstheVlSACreditCa~.n~l'~. C ' newels we Issue..e, Ccount means r . -- --'- --,x redit account . ~ VISA Credit Card ~ us We, ua, and oum means this Credit Union. One of ~ R_.ESPONS_IRILrT'y __ If we iSSue you a card, you agree to re · I-;nanca c:llarge arisinn ~ ~. ......... pay all debts and cra~3ren. YOU are also ,~,..~.-,- .- :%-~- ~x x,.~(~., your spouse and minor · .-...-~-,,~,~<~ .)r charges made by anyone else to.whom you give the card, and this responsibility continues until the card is recovered. You cannot disclaim tmn~actibns ff y~Sponsibility by notifying us, Ix.,t we will cleee lhe account for so request and return all cards. Your obligation to , u .~, ~u ~rrerK purchase ~ 7. FINANCE CHA beisncas. the full am0unt of tAhtRGNEewS '~a~Un can avoid Financa Charge on ixachases by payi statement Cibsin. date ,..~...n~e~__of P~u .m..l'~se. s_ee.ch month wi~in 25 days of ~ o · ~.,~,,,v,~. ule flew UalanCe of D...~-- yO ru,~eS, alld .sub_sequont_l~urchas_es fro~ the date they are po~ed to your accou will · an [o rinanca (.;ha (.;ash nt, be su balance continues even though agreement, divorce decree other cour date they are 3sr~t; ad ~v:d~..s_.are always subject ,o Finance Charus fro~bJ~a judgment to which we are not a or parbj may d rect you or one of the other persons mspansibts to pay the account. ' pos d to your aCcou.L _ Pumhasa~s: We ca Culate your finance Charge by muitiplyl the ave ny the · ,' "'~ ..uu.,g new purchases, tot the billin houm call (800) 556.5678 ~' '14'-~'c~=~4er(800)237*732.8. Affer _ m°nth~Ypariodlcpurchaserateasdiscibeedonth~.~..~._ gcyce .3......UABlUTY FOR UNAUTHORIZED USE ~ You · --- (;ac.u~ate your finance charge on neeh li__a~i_'l-.~, to. the Credit Union shall not _ uncle.intend that your total m.ulfiplying the average adjusted dai .......... --- s by a . y u.~a~ce tsee explanation below f exceed $50 for an cam tm * a~.~ during the bdhng cycle by the monthly pertedic .dvanue ~,*- ) for cash rom me ~oas, theft or unaulhorized ..... ~ ,,. ..... ~ nsactlens resulting gwe notice to the Crodit Union. Such Ilabll~- -- [ on~u. rs prior to the Ume you uamnco Computation Method ..... ~ intelligence can ~-~e ~ . uses neum~netwo~ks, Which hv '='~ = calculated by addi the x. ~-~-~nlence this might causo. 'u e~ we alX~oglze ........ ,=,- um Oal Bala --s ..... ~,,,,,ng ate 'We ly nce for purchases each we 4. CREDIT UNE ~ ff we appnwe ~ appr~Ufon, we will ps. take the m~f=,~.~--~. ........ day, the fo(towing :'.~ _%2~. '-"'~ ~mnce ~' Ca~ Advancas. Cash ........ - ..... -: Includ~s. your ~allure to w~th ~_thlS AgrasmenL Good I"~t~ m YOUr "_ _'~'~,_ Jnt are ~-~+ ~.,.~ ........ ~v-~an~e iren~actJon~ which are Agresment of li~ of Y;)ur ~. loU may ~so SL CREDIT INFORM~'~'~" "~o~'~. _u~. ~ o~ this Agreement. each day In the blitino ~"~,',~x~.'~." -~ .?e. ueaY Ualanoas (Cash Trmmactlon) for us about your credit standing nd other creditors who Inquire oT all cteblte and subtract the amou.-~- -,~':'-:,'~--'3--)7"u' ~ we a(~ the amounts 6. MONTHLY PAYMENT ~ We will mail yon a slat ,,,~ ~, m, GreOl-.S o(' payments whk:~l post to your account that day. Aher applyinn mw,~.,.. your P~:evl°us Balances of porchasas and ,-~oh -..~-s-~a- ?--?nt~ every month showing any unpaid FInanco Charon. ~, i ........ , . utXrast the amount of ~, .,.<u ~.m~, aw current transactJo~ -- ...... - '.,. ,~,l,ws. ~ non we ~ subtract the amount of ~3aYour account, the remainS,., cmo'it lenCes of purchases -.-,., ~.-~ ~eva.ame unoer your C.,molt Line the Chame dueto date andCT.,...~J.', a~.,~a_..n~, me Total New B~anca ~ ...... ,,m,~ ~ ~te. Bv g~mt~ ...... - -x.,~,,~ mumm ~.a Gays of VOUr minimum ~ .,,j.~.~_'.;'_'_,~.'.~"~ -u,~mem you may authorfze us to (~ '-- ~-' ........... ~-.~w ~o your shat (:~ ~ oral New Balance in full and v~, ,.w~ .~.4.__ ~ a? Mirumum pa .Ymen~ ot' pay the v~.'.'.'.'.'.'.'.'.'~A- (,~emr (Mm AEreemenr*ancl Trthn In Le~aln~ Disclosure ~ ~ ~t ~ ~ ~ ~ ~ ~n~ a~ ~ ~ am ~ ~r ~ ~ ~ ~nt ~ Data ~ ~ a ~t~ b ~1 to ~ ~ ~ N~ i ~ ~ ~t ~te~ we ~ll ~ ~ ~ M~y ~ ~ta to ~r ~ ~ ~r ~ ~te~. ~ ~F~LT ~ Y~ ~1 ~ ~ ~a ~ ~ ~1 ~ ~ ~ Min~ ~e~ ~ ~ ~ aa~ ~r ~ ~nt ~ ~.~ a~ w ~ ~r ~ym~te~~a~~re~ ~e~ ~te~ ~Ms. We ~ ~ ~ to ~ ~te ~ ~11 ~nt ~ ~ ~ ~u~ ~ to our ~ ~ any ~ ~w. To ~ ~e~ ~ ~ ~w, ~ ~ll al~ ~ ~al~ to ~y ~r ~ll~ion ~es, i~i~ ~ ~s~ a~ m~e a~o~ ~. 9. U~G ~E CARD ~ To ~ ~Mpu~ ~ ~ a~, ~m am ~~ ~ to~or~~~~ ~e ~ ~ ~ ~ ~r ~ ~fl~ Nu~ (PIN) ~ ~ ~ M~ ~ an ~t~ Taler ~ ~ ~r ~ ~ ~t p~ ~ ~ ~ ~SA ~.~ eg~ ~t ~ ~1 M~ ~ ~ ~ ~t ~ ~ u~r ~1~ ~, ~, or ~ ~.~ a ~ ~ ~ ~ies ~ ~i~ ~u ~ ~ 10; R~RNS AND A~U~E~ ~ Me~ ~ ~ ~ ~ ~at ~ ~ ~, ~ ~11 ~d a~ ~ ~ ~d ~.a~i~ ~ a~ ~h a~, ~ ~ ~ ~ one dollar ~ ~re, m~ ~ on ~r ~en ~ or a~ly a~er s~ ~. 11. r'OREdON T~AGTION$ -- P~_~_ ' 8ncI ~ 8Q~Ain(~es i II1 kN'algn 1.2, PLAN. MERC _HANT DISPUTES ~ We am not respaesibla fm the rofuseJ of any of your home. Any sther cisputee you must rees~e dlrecity with the plan merchanC 13. SECURITY INTEREST ~ To secure your ~ you grant us a purchase money security interest under the Uniform Commercial Code In any goods you purchase through the account, ff you dofaufi, we will have the right to recover any of these goods which we have not been paid for through our application of your payments in the manner desc31bed in the Monthly Payment secticm: ~,rlth respect to th~ ~nt ~, ~ ~1 ~ ~ any ~t~ ~ we ~y ~ ~ ~ are in ~de,fa~.to pr~.~ .withdrawal of your u...rp~med .cr~.. u.n~ Umm~ (Dspo~) ~_m~v__me,u?a~ m~ance o~ ..your account. However, # you g~ve or have given us a specn~ pmoge of your credH urdon shams (Deports) by signing the Pledge of Shares or otherwise, or any other security intarests for all your deb~ your account will be secured by yoor pledged shares (Deposits) and by the pmporty desedbed In those other securit7 agreements, except for your home. 14. EFFECT OF AGREEMENT -- This Agreement is the contract which applies to all transactinne on your account even though the ~alee, cash edvem:e, credit or other slips you sign or receive may contain different terms. We may amend the Agreement from Ifme to tlme by sanding you the advanse written notfoe mqutred by law. Yoor use of the card thereafter wili indicate your agreement to ~e amendments. To the extent the law permits, and we indicate irt our noSce, amendments will apply to your ey__~-flng account balance as well as to future txarm~.__ctfoc~. 15. LATE PAYMENT CHARGE ~ ff your Minimum Payment is not paid within 15 days after the PaYment Due Date,.ybu will be subject to a single charge of 5% of the minimum scheduled payment. 16. COPY RECEIVED ~You 8cknowiedge receipt of a copy of this Agreement. MONEY ACCESS CARD CARDHOLDER AGREEMENT - The Undersigned (you or your), in considecation of THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION (we, our and ua) issuing to you a MONEY ACCESS CARD;lieroby agree to be legally bound by the following terms and concrdkms. You agree that the use of your MAC card(s) (~3rtstitutes acceptance of the terms and conditions of this Agreement. You understand that MAC' is a credit*related sen'ice and you author[7.e PSECU to obtain a c~ndit repoct on any usam of this account. 1. Acoounte and Uee~ of MONEY ACCESS CARD · You have the account(s) (including Checking end Regular Shares), which we set forth on your a,oplicafico form with this Agreement. You hereby request that we issue to you one or more MONEY ACCESS CARD(s) to be used In connection .with such accounts as described in this Agreement. You undemtand you may use the MONEY ACCESS CARD at a MONEY ACCESS CEh'TER' to (1) withdraw cash from, (2) make or arrange for deposits in, (3) effect tmnofors to or from your account, (4) receive information regarding the balance in your account(s) or (5) make cash advances from your credit account(s) in the amo~mts you request. You may also use automated teller machines thn3ugheut the United States and in certain foreign countries which bear the PLUS SY-~'~ ,:~' name and ingo (1) to mal<e wit~,:lrawats from, (2) eflect transfms to or from, (3) receive informmJon regarding ~e helemms in your undemtsnd you may use the MONEY ACCESS CARD to purchase goods and se~vlcee ('Purchase') at any retail estsMIshment ("Merchant") where MONEY ACCESS CARDs are ascepted by mJch Merchant. If you use the MONEY ACCESS CARD to maks a Purchese to obteln cash, # pemlitted by the · Purchase (indudleg any cash received from the Merchant) from your Checking 2. Use of Peflonal Identification Number (".PIN") w'~th MONEY ACCESS CARD You understand that a MONEY ACCESS CENTER or a PLUS SYSTEM ATM is an automated teller. It can and will perform many of the same tasks se a human tallar. You acknewk~ that the Personal IdenUflcation Number or PiN wflich you use with the MONEy ACCE. SS CARD Is your Ngnsture, Identifies the bearer of the Card to the MONEY ACCESS CENTER. PLUS SYSTEM ATM, or other nehvod( ATM and authenticates and validates the dlrestlons given Just as your · actual signature and olher proof tdent~y you and authenticate and validate'your clirectJons to a human tellar. You also understand that a Merchant which accepts the MONEY ACCESS CARD for a Pu~hase transaction may have an ek~ctronlc terminal (Merchant operated or Salf-Sep,,Ice) wh{ch requires the use of your PIN and .when your PiN is used at a Merchant's terminal, It will authenticate and validate the directions given just as your actual signature will authant]cate and validate your direct[o~s given to us. You acknow~dge that your PIN is an identificath3n code that is persocal and co~itdendal and that the use of the PIN with the MONEY ACCESS CARD is a security devise for your account(s). Therefore, YOU AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO ONE ELSE LEARNS YOUR PIN. 3. Uablllty for Unauthorized Traneectlons You agree to contact es at once if you believe the MONEY ACCESS CARD(s) ~ued to YOU or PIN ~ been fost or stolen of ~ le lng ~ ~r account(s). ~ also agree ~t E ~r ~ly ~ ~ ~ wh~ ~ did ~ make. ~ ~ ~ ~ ~ct us ~ ~ ~ a~r ~teme~ was ~ed to ~, ~ ~ ~ ~t ~ ~ ~ ~r ~t ama, YOU AGREE ~T IFYOU GI~ YOUR MONEY ~ESS ~s) ~ PIN $~EONE ELSE ~ USE YOU ~E ~O~NG ~ ~ ~ ~ ~R SE~ ~D ~ ~LL BE R~SIBI ~ ~ ~ U~ ~ THE to ~ PSECU of ~ ~ of ~ MONEY ~ESS ~D or ~N, ~ ~r Pe~ Ide~ N~ (PI~. ~ ~tea or ~ ~r ~N o~r pe~ ~ ~t ~.e ~ PIN ~ ~ ~EY ~ESS ~. ~ a ~an ~ of ~r PIN near your ~EY ~ ~. . ~ a PIN ~le e~i. A new card ~ be ~ ~ ~ at ~t Itme ~ a ~ ~ be ~ on retsl~ by ~ ~EY ~ESS C~R, PL~ SY~, or N~ 4. ~ a~ to ~a ~ cont ~ ~ ~ de~or ~ ~ 15 or ~ ~ ~ are ~ by us ~ ~ se~ or ~ se~ wh~ may later be ~ as ~ ~ o~. ~as may be ~ or ~ed ~ ama te ama. S, Dsmlte You agree ~t ~ ~ make a pa~ at a MONEY ~ESS CENTER Eiec~onl~ Fund= Transfer: MAC Aereement and R~ul~on (~,~ ~nt(s) ~ ~ ~r ~ ~ (~, dm~ ag~ ~t ~ ~ ~ a~ M ~ ~ ~r ~m(s) ~ am ~t ~1~ or, ~ ~ fu~ ~ ~r a~(s) am ~ at s~ ~me, ~ ~11 p~ pay to us a~ a~nt of s~ ~s ~ are ~t ~{1~. 7. Amendment of ~ls Ag~ment Y~ ag~ ~t ~ ~ ~ ~ ~ ~ ~ or ~D ~ ~ ~ or ~ ~ ~ ~ ~We ~y ~ ~ ~ ~ ~ In ~ ~ s~ ~ or ~s ~ ~r u~ of ~e MON~ A~ESS C~D after ~ e~ ~e or ~nge ~11 ~e ~r a~p~ of amend~m ~ ~e. 8. ~emhlp ~ ag~ ~t ~e MON~ ~E~ CARD ~ ~r ~r ~ ~ ~ u~ ~r ~ ag~ ~t ~ MON~ ~ESS C~D 9. Dl~osu~ ~r ~h~ u~ ~ Fu~T~r ~ ~ a ~ of ~ ~ REGU~N "~ DISCLOSURE 1. Summa~ of ~nsumer ~bll~ * ~C, ACHa~T-Tellusat~u~ll~r~n~or ~.Telep~l~ b ~ ~ ~y to ~p ~ur ~ ~ all ~ ~ ~ ~r a~nt ~ ~ ~m~ ~mff li~ ~ ~ If ~u ~1~ ~ur~ ~ ~n ~ or~ ~ ~ ~11 us If ~ ~ ~ tell ~ ~in ~ ~[n~ ~ a~r ~ of ~ur ~, ~ ~ ~n p~ ~ ~ ~w st~ ~ne f~ ~l~ ~ur ~rd ~ ~ur ~n ff ~ ~d ~d u~ ~u ~uld ~ ~ ~ tell ~ ~in ~ ~ a~r ~ ~te~ ~ ~d to ~, ~'~y ~t get ~ ~Y ~ ~ affer~ ~ ~ ~ ~ ~ ~ ~t ~ ~u~ 2. Telepho~ Numar a~ A~ ~ No~ of * MAC - ~ ~ECU ~ (~) ~.~ ~ ~ ~ ~ (~) at (~) ~175 du~ PS~ ~ ~ ~n PS~U at (~) ~-~ ~ ~ ~ ~y. ' A~ a~d SST - ~ PSECU ~ (~) ~7-7~8 (~fl~wlde) or ~ 2~ ~ ~). Or~~ PSECU Bu~ Hou~ ~ (~) 4~-1~ ~ ' ~C, A~ a~ ~ - PSECU'8 B~ ~ ~ ~y 4. ~s ~ ~1~ hn~em a ~nsu~ May ~ ' ~C-~ ~ul~ on ~,~ p~ $20; ~ cents kx ~ tma~lc~lcm ,over 1S p~r mofl1~, mid ~ ~ ~t MAC-~ am ~ ~ ~ a ~ r~ at ~ a~ ~ ~s ~ ~ ~ m~, ~ a~ ~ or PSE~ ~ ~ dud~ ~ ~. -- -- * ACH a~ ~T- ~ ~U ~ a ~ ~te~ ~ ~ a~ a~ ~s ~ duH~ ~ ~, ~ ~ ~s ~ ~es PSECU ~y ~ during ~e ~ * If ~ ~w a~n~ to ~w ~ dir~ de~ ~ to ~ur a~unt at ~ ~ ~ ~ ~ ~ ~ ~,~ ~ ~1 ~ at (~) ~7. 7~8~ ~ror~t ~ ~a~ ~ ~, 7. ~ ~ RIg~ - P~ ~n~ * MAC and ~T. N~ ~e. A~ - Right to S~ ~ent a~ P~um ~r doing ~. ~1~' ~.~?m'~ n~. ~ll ~ at (~) ~-~ (~) or U~, ~. ~ ~13, ~, PA 171~7013, ~ ~ ~r ~ ~. ff ~ ~1, ~ ~ ~ r~ulm ~ to p~ ~r r~u~ ~ ~ ~ get a~ ~[n 14 ~r~ ~. , No~Va~~.~u~~~ ~ ~ am ~ ~ ~y ~ll~a ~ 10 ~ ~ ~~nE . ~ly ~n ~ ~e~ ~u~ d~r ~ ~ ~ a ~n ~N pr~o~ ~nt, or ~n ~e m~nt ~ld ~[I o~i~ ~n ~t. *Uablll~ ~r Fallum to ~op Paint of P~Tmn~. ~ ~ o~r us~ ~op ~ ~ ~r~ ~ or ~m ...~rb~u~,~wedo~t~,~e~r~r~or ~g~, unl~ ~ ~ a~ ~ ~ ~ ~en ~ ~ ~N ~in 14 ~ and ~ ~er ~ p~ a~er 14 ~l to g~ us pm~r I~s ~at ~u~ ena~ ~ to p~ ~fec 8. Sum~ of ~e R~n~al In~ff~lon's Failure to Make or S~p Tin,f em * MAC- ft PSECU ~1~ to ~mplete a ~ ~ ~ or In ~e ~ ~u~ ~n ~ ~ ~ ~u, PSECU ~11 ~ ~ ~r ~ our ~um un~: (1) ~m are ~ent ~ In ~r ~t to ~ (2) ~ ~ In ~r ~m am ~; (3) ~ ~ are ~m ~ ~ ~e ~m~ p~; (5) ~ ~ ~ ~mec PLUS ~em ~ HO~ A~ ~ I~ ~ ~ ~te ~ ~; (6) ~r ~ ~ ~ m~ ~ or ~n ~ ~ ~ ~ ~; (8) ~ ~lum ~ due ~ ~ ~ul~m ~ ~t ~ ~ ~ A~; (9) ~ ~m ~ ~ ~ ~ ~ ~ ~, am, ~ ~r m~, ~ ~ ~ ~r ~ ~ ~ (10) ff ~ ~ to ~ete a ~ ~t, at.a ~ ~ ~C ~U$ ~em HONOR A~, ~ ~ ~ ~ b ~ a ~ ~ ~ ~C (2) ~ ~ ~r a~ ~; ~)~ ~ to ~1~ ~t ~ ~ ~ b ~ (6) m~ ~ ~ ~ ~ G~, tim, or ~ m~, ~ ~ ~r ~ ~ ~. In ~ ~, PSECU ~ ~ ~e ~ ~ ~n ~llum ~ ~ ~ ~ ~u~ ~ a ~ ~ e~r ~ PSEC~s ~u~ ~ ~ ~ e~. 9. Dl~os~ ~ ~1~ P~s * MAC, ACH a~ ~. PSECU ~1 ~ ~ ~ ~r 'a~N ~l~ ~: (1) ~ a b n~ ~ ~em ~; ~e~ a~ ~ ~ ~r a~um ~ PSE~ ~ ~ ~ ~ a ~ ~u; (3) to ~ly ~ ~ a~ or ~ ~m; (4) ~ ~ ~ ~r ~ ~; (5) ~ ~ ~ ~m o~ adm~ a~ ~, s~, ~ ~ ~m; [6) ~ ~ ol ~ ~ ~~ ~to ~ ~ ~ 1~8;~ ~ ~n ~ Ele~;,~,llc Funds Transfer..MAC A=reeme~t and Regulation 'E~ Dlsclosu;- 10. MONEY ACCESS CENTER Servlce~ * MAC Only - You may use ycur MONEY ACCESS CARD wilh your Personal Ide~'fioaflo~ Numl~r (PIN) at MONEY ACCESS CENTERS located in Delaware, transectkxts for the ancounts anosssed by your MONEY ACCESS CARD. a) Determine the account balance(s) of your Checking your Regular Shams, and your Forso~el SaUce Loan (PSL). b) W'~lraw cash fi'om y~Jr Cheddng and your Regular Shares. c) Make a cash advance from your Personal Service Loan (PSL). d) Deposit currenu~, checks, or drafts (coins are not ascoptabte) fo~ transmission to PSECU for deposit in your Checldng and your Regular Shams. NOTE: Then an fimited locations in Maryland when deposits may be made. We wish to inform you that some MONEY ACCESS CENTERs located in these areas may only provide access to your Checking, your Regular Shams, and your Personal Service Loan. Not all MONEY ACCESS CENTERs may accept deposits. Then may also be limits o~ the amount of funds which you may deposit in certain MONEY ACCESS CENTERS. 11. PLUS SYSTEM* Services ° MAC Only - You may use your MONEY ACCESS CARD with your Pemonal Identiitcaiton Number (PIN) at any PLUS SYSTEM automated teller machine (PLUS SYSTEM ATM) located throughout the United States, Puerto Rico, Canada, Great Britain and Japan to conduct any of the following transections an the accounts accessed by your MONEY ACCESS CARD. a) Determine the account balanue(s) of your Checking, your Regular Shams° and your Personal Sewice Loan (PSL). b) Withdraw cash from your Checking ;md you Regular Shams. c) Make a cash advance from your Pemooal Sea'{ce Loan (PSL). NOTE: Deposits 'an not available thrcugh PLUS SYSTEM ATMs. These are the MONEY ACCESS CENTER esr~ices currently available through the PLUS SYSTEM netwod(. Other services may be offered in the futura. 12. HONOR' System Services * MAC Only - You may use your MONEY ACCESS CARD w~ your Persomd Identi~atfen Number (PIN) at any HONOR automated teller machine (HONOR ATM) located throughout Florida and other ames when ther.e are HONOR ATMs. The following tmnsecitons may be done o~ the accouters accessed by your MONEY ACCESS CARD. e) Determine the account balance(s) of your Checking, your Regular Shams, and your Personal Service Loan (PSL). b) W'~dmw cash from your Checking and your Regular Shams. · c) Make a cash advance from your Personal Service Loan (PSL). NOTE..' Deposits are not avallabl? through HONOR SYSTEM ATMs. These an the MONEY ACCESS CENTER semtces currently available through the HONOR SYSTEM network. Other services may be offered in the futura. 13. Other ATM Networt; Access · MACOnly'F~omtimatoitma, PSECUmaymakeerrangemantswtthotherATM networks to grant access to MONEY ACCESS CARDs. PSECU shall inform you when such arrangements an made and desotibe the esrvioes that ere available to you. ~ charges will also be described. 14. Pumha~e Transecflone ° MACOnly-YoumayusetheMONEYACCESSCARDtopurchesegoodsand sewtces ('Purchase') at any retell establishmeN (Iderchan~ ~,~bam MONEY ACCESS CARDs are accepted by such Merchant. The amount of all such, Purchases will he deducted fro~l your C~. Whert you make a Purchase using the MONEY ACCESS CARD, you will be requesting PSECU to withdraw funds from your Checking In the amcunt of the Purchase and directing PSECU to bay thess funds to such Merchant. 15. Umltatior~ on the Use of your MONEY ACCESs CARD * MACOn~y-Youmaywtthdrawupto$5OOpordayfmmaneoracomblnatlanof your ___._._'c.__~xr,_ ts by us~g a MONEY ACCESS CARD pmv~ed the funds are available at a MONEY ACCESS CENTER, PLUS SYSTEM or HONOR System ATM. In addition, you may withdraw/purchase up to $500 at point of ~ event that your dally limit Is Iss~ than $500, PSECU will edvlae you of Ihe new limitation. The day for withdrawal limits starte at 12 midnight each day atx] ands at 12 midnight the next day, For escu~ty purpoes~, there are also sertaln dally limitations o~ the frequency of use of the MONEY ACCESS CARD. However, these limitatlo~= are not revealed for sscu~ity ~. The Pennsylvania State Employe~s Credit Union is not o~lged to maintain s~ch limitations. Ycu will be denied use of your MONEY ACCESS CARD If you e_~__~ the deity withdrawal/purchase limit, If you do nut have adequate funds available in your account, do not enter the correct Personal Idanti~oatlou Number (PIN), ~' ex__,~ed the frequency of usage limitation. The reoalpt'provtded by the MONEY ACCESS CENTER, PLUS SYSTEM.' or HONOR System ATM0 o~' Merchant terminal will nutify yo~ of the denial. There is a limit an the number of such denials permitted. Aitem,ots to exceed the limit will resoit in machine retention of cut MONEY ACCESS CARD. ~ nu~ar.~f attempts that result in machine mte~ is not revealed for es~J~ty purposes. 16. Err~'~ Re~olutlon Procedures ' ' ° MAC, ACH and SST - In case of armm or <lUeStions about your tra~sacitans: Direct Ir~uldas to PSECU at (800) 237-7328 Natlam,~de, 'I'DO (800) 472-1967 Na~<x.w~:la, (717) ,'//-2100 Ii1 I..~rg, or Write I~ECU at: Pannsytva~la State E~ofeyees Credit Urflou, P.O. Box 67013, Han, lat~, PA 17106-7013, as ~°°~ es YOu c~n If You it~nk YOu~ '-'t"temant or receipt is ~wang, o~ If you nued must near from you no later m~n ~u ~ ,,~ar ~ sent you the flint ~.temant co which the pro.em or e~or ~oge,,md.~cu must provide the foito~eg iofarmatlan: (e) Your nsme, ecoount number, and IdONEY AOCESS CARD number (if · ¢laariy as you Can v~ny you believe it is an error or wi~y you need the information. end~ (s) ~ dollar an~unt of the suspected error. It you tall PSECU omliy, you must send your comp~int ~ questiou in wri~n~ within 10 business deys. PSECU wlii tell you the resulte of the Investige~o~ ,,Ess ca, R, ,LUS SYSTEM, SELF-SERVlCE'Ir3=[EPHONE, or DIRECT DEBIT/CREDIT TRANSACTIONS, or 20 days for MONEY ACCESS CENTER purchase transactions. If we need mom time, however, we may take up to 45 days for MONEY ACCESS CENTER, PLUS SYSTEM, HONOR SYSTEM, SELF- SERVICE TELEPHONE, or DIRECT DEBIT/CREDIT TRANSACTIONS or 90 days for MONEY ACCESS CENTER pumhass tnmssotio~s, If PSECU decides to do this, it will mcmdit your acoount within 10 beelnsss days for the amount you think is in error If it is a MONEY ACCESS CENTER, PLUS SYSTEM, HONOR · SYSTEM, SELF-SERVICE TELEPHONE, or DIRECT DEBIT/CREDIT tmnseciton, or 20 business days If it is a MONEY ACCESS CENTER purchase transectto~ You will have the use of' the money cluing the time If takes t~ complete the investigation. If PSECU does not reoalva your comp~nt er- question la writing within lf~ business days, PSECU may not recreant your acc(xmt. If PSECU decides then is nu eh'or, you will be advised within three I~siness days efter the investigation is completed. You may ask for copies of the documents PSECU used in the investigation, If PSECU oredits your account while investigating, you must repay those funds if PSECU conufudes no error Nofloa To Coneumem Using ATM'= · Be alert to your surroundings, ff you doubt the safety of a particular kx:aiton,- choose another ATM. ' If the ATM has an entry door, close the door prior to Initiating your transaction. · Put your ¢~__~h away immediately. ' Direct complaints concerning ATM security to an appropriate department of the owner of the ATM. New Jersey residents: you may call the New Jersey Department of Banking et (609) 292-7272. For those members who purchase a vehicle under the DRIV Program, please review the following FTC Notice: ANY HOLDER OFTHIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED WITH THEI PROCEEDS HEREOF. 'RECOVERY HEREUNDER BYTHE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW AND NOW, this ~ day of 1[~1I'[ , 2002, I, Steven C. Courtney, Esq., of Metzger, Wickersham, Kn/uss & Erb, P.C.~ attorneys for Plaintiff, hereby certify that I served the foregoing Compla'mt this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 Document #: 234204.1 JUN-O~-2002 00:~0 >i j...~ H 0'9 T,c>~ n ID: 09 i,oar'~ ¢'.odc: CrediL Card Loan PurpoSe: 107 Lc.~n Branch: 0000 ?,~t L e :,h~raDer: 41211~40001471776 L~.~¥~' FH Date: 12/]2/01 [,arC Trar. ~.).et'~:': 10/10/01 L.=.t'L P,.rg,:: Date: 10/3]/01 02/05/97 10/30/01 00 2,817,51 001 02/05/97 Al' .!.. r ~ r..' ,'J J. Code: 0999 Al: Rrova ~ DSt &~: --/--/-- Ne;,, 6o~0 Due: From 8k~ l f.',u,~ Da~e Adv: 1 Freq Max D%;e I.).~y 1: 25 LhJ,~ Day 2: 0 D :..'.'; Date: 03/25/01 Balloon I'),'Jt e: --/--/-- ~1 lc,::n ~tt: 0,00 M~,'.ur i~ y Da%e: --J--J-- R,::. f:.md Yq'r): 0 - O0 ~,~.:[ ,.,~,.,:1 L~'fK: 0,00 D~. 7.k~t %ce: Suppr~ r:,Q biotite I')a~e: 04/26/01 DQ C,.]r'd Date: --/--/-- DQ Met.hod: ~mt Bocket Ori~L~.,~] Rat~: 0.000% A~"R; 0.000% P r,:.E:d Fi [K;hg: 0 - 00 E~' :r Ow TD: No~e ApB. l~,.':ation ID: None A'.,u.,'~akance: 1, 642.66 Old B,.--' ] ~n¢:e: 1,642.66 O~d Unpaid: 94.85 PSECU 'type: 86 C}[ARGED OFF VISA Pmt Type: Level Payment Pm: Method: Cash Pmt Coupoo: Normal Prat Freq: Monthly P[~C Skips: 0 Pm: Skip Start: 0000 ~mt Calculation Type: 0 Partial Pm:: 1.00 P:~t~ ~f~ount: 59.00 Last Pm: Date: 03/30/01 ~9~ance: Orig Bal: 3,212.40 Cred Limit: 3,500.00 C~ed AvaiL: 0.00 Cred Expiration: --/--/-- Credit Limit Group: 01 Princ YTD: 0.00 Princ Ls Yr: 65.84 LOAN Alt Pmt: Alt Pm: Effect Alt Bm~ Expire 0,00 --/--/-- LtChg Type: 9 LtChg Date: --/--/-- LtChg Accrued: 0,00 LtChg Unpaid: 0.00 LtChg YTD: 0.00 LtChg Lst Yr: 0.00 2,817.51~ Payment Count: Payments Made: 31-60 Days LQ: 61-90 Days DQ: 91-120 Days DQ 121-180 Days DQ: 181 and ~p Days LQ: Secured: Not Pledged Secured Bal: 0.00 Insurance Type: 00 Ins Maximum: 0.00 Ins Balance: 0.00 Sgl Prm Lif: 0.00 $gl Prm Dim: 0,00 NSF MTD: 0 NSF YTD: 0 NSF Last Yr: 0 Stmt Group: 90 S~mt Mail: 00 Stmt Date~ 05/31/02 SSmt Prev: 04/30/02 ECOA Code: 1 Credit Report: Normal 0 21 1 0 0 0 0 Cred Rep Co~%r~ent: None C R %: 00001685892800009 Cred Rep Status: 97 Cred Rep Occur: 04/24/01 Cred Rep Consumer: No~e Cash Advances In: Type: 12 In: Rate: 0.000% Int Date: 06/01/02 I~ Unpaid_: 177.67~ In: Unpd Billed: 0.00 In: YTD: 0.00 Irlt Lst Yr: 104.16 In: Frm Opn: 622.17 Split Rate: 0.000% Split Bal: 0.00 In: Rate Index: 00 In: Rate Margin: 0.000% In: Rate Min: 0.000% In: Rate Max: 0.000% Risk Rate: 0.000% Discount Rate: 0.000% Annual Cap: 0,000% Cap Start Ra~e: 0.000% Cap Start Date: --/--/-- Cred Rep C~pliance: No~e Avg Balance: 1,097.35 Old Balance: 1,097.35 Old Unpaid: 82.82 In: Charge: 0,00 Tran IntChg: 0.00 New Balance: 1,097.35 New Unpaid: 82.82 Avg Bal 2: 0.00 Old Bal 2: 0.00 New Bal 2: 0.00 Pm% Buck~: 59.00 Due DaLe: 06/25/02 Pm~ Bucke~: 59.00 DUe Date: 05/25/02 Pm7 Bucket: 59.00 Due Date: 04/25/02 PILL' N.~cket: 59.00 Due Date: 03/25/02 Pmu Bucket: 59,00 Due Date: 02/25/02 Pmr Bucket: 59.00 Due Date: 01/25/02 Pm¢ Bucket: 59.00 Due Dat~: 12/25/01 P~nt Bucket: 511,00 Due Date: 03/25/01 Student Code: 0 FASB 91 Code: 000 St ~dent Covered: --/--/-- Effective APR: 0.000% Ch~.:m:k Digit~; None Unamr~ Fee: 0,00 Servic~ ]: Ob Wart, 1: 02 Exp: --/--/-- DZLINQUENT LOAN Other Fee OldBal: 77.50 Fee NewBal: 77.50 Total Bal: 2,995.18 Fee Count 1: 0000 Fee Count 2: 0000 Fee Coun= 3: 0000 Fee Count 4: 0000 Use in CU To~al~: Y Min Bal: 0.00 Min Adv: 0.00 Points YTD: 0.00 Points LsY: 0,00 Reg · Count: 0 P. 02/02 TOTAL P,02 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA PSECU, Plaintiff : : V. : : David R. Yoder, Defendant : .' No. 02-02350-CV Civil Action Law NOTICE To the Plaintiff, Pennsylvania State Employees Credit Union, you must answer the enclosed preliminary objections or file an amended pleading within twenty days. If you take neither of these steps, a judgment may be entered against you. Brett J. Riegel, Date: PSECU, Plaintiff V. David R. Yoder, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA .' . No. 02-02350~CV : Civil Action Law : PRELIMINARY OBJECTIONS--AMENDED COMPLAINT Defendant, David R. Yoder, preliminarily objects to the Complaint of Plaintiff on the following basis: 1. The Complaint fails to comply and conform with a Rule of Court pursuant to PARCP 1025 (a) (2). 2. The basis for this failure to comply is that Rule 1024 requires verification by a party. PARCP 1024 (c). 3. The verification attached to the amended complaint does not identify Bonnie L. Berskoski as a party or as a duly authorized officer or representative of the Plaintiff, Pennsylvania State Employees Credit Union. 4. Additionally, the verification is not dated. 5. As such, Defendant cannot determine whether or not the complaint has been properly verified according to law. WHEREFORE, The amended complaint should be dismissed for failure to conform with a Rule of Court. Respectfully submitted, Brett J. Rieg61, Esq. Amori & Riegel, LLC 717 Sarah Street Stroudsburg, PA 18360 Atty. ID# 76448 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA PSECU, Plaintiff V. David R. Yoder, Defendant No. 02-02350-CV Civil Action Law CERTIFICATE OF SERVICE I, Francine Bresnen, of Amori and Riegel, LLC hereby certify that service of the foregoing documents were made upon: Steven C. Courtney 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 by mailing, first class, postage prepaid on July 5, 2002. o'r_apdine ~esn~ ofl/Amori & Riegel, LLC 717 Sarah St. Stroudsburg, PA 18360 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW .PROOF OF SERVICE BY MAll, I, Steven C. Courtney, Esquire, do hereby certify that on June 5, 2002, a copy of the Complaint was received by the following person by certified mail, as is evidenced by the Certified Mail Return Receipt Card attached hereto as Exhibit "A." David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 Respectfully submitted, USS & ERB, P.C. y: 3211 N. From Street Box 5300 Harrisburg, PA 171 I0 (717) 238-8187 I.D. # 74669 Attorney for Plaintiff Document #: 20423Z 1 · Complete items 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 mailptece, ' on the front if Space permit~. B. Received by ( Printed Name) s de~/ery address cfiffemnt Eom It YES, enter delivery address below: [] No [] Registered ~j~u(p_ ress Mail [ ' t.~.~eturn Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes 2. Article Number PS Fo,,-,~ 381 1, August 2001 Domestic Return Receipt 102595-01-M-2509 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW NOTICE You have been sued in Court. Ir'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 is served, by entering a written appearance, personally or by 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 document, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICIA Le hah demandado a used en la corte. Si used quiere defenderse de estas demandas ~eUeStas en las paginas siguientes, used tiene viente (20) dias de plazo al partir de la fecha de manda y la notificacion. Used debe presentar una apariencia escrita o en persona o por abogado y arehivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomara medida$ y puede entrar una orden contra used sin previo aviso o not/ficacion y pot cualqu/er queja o alivio que es .pedido en la petieion de demanda. Used puede Perder dinero o sus propiedades o otros derechos lmportantes para used. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL D/NERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 800-990-9108 IN THE COURT OF COMMON PI,F-AS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW SECOND AMENDED COMPLAINT AND NOW, comes Plaintiff, Pennsylvania State Employees Credit Union, by and through its attorneys, Steven C. Courmcy, Esquire and Metzger, Wickcrsham, Knauss & Erb, P.C., and states the following came of action and in support thereof, avers as follows: 1. Plaintiff, Pennsylvania State Employees Credit Umon, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvan/a with offices and/or a place of business situate at 1 Credit Union Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, David Yoder, is an adult individual w/th a last known address of 1422 Bradley Drive Apartment C-313, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant is, and at all relevant times material hereto was, the applicant for a Visa Loan with Plaintiff. 4. On or about February 1, 1997, Defendant applied to Plaintifffor a Visa Loan. A tree and correct copy of the loan application is attached hereto, incorporated herein and marked as Exhibit "A'. Plaintiff. 8. 5. Pursuant to the loan application marked as Exhibit "A", Defendant agreed to the terms and conditions of the extension of credit as set forth in the Loanliner Credit and Security Agreement (here/halter referred to as "Contract"). A true and correct copy of the Loanliner Credit and Security Agreemem is attached hereto, incorporated herein and marked as Exhibit "B". 6. The contract marked as Exhibit "B" contains the terms and conditions of the extension of credit agreed to by Defendant. Var/ous charges and/or purchases were made by Defendant on the Visa Loan w/th Defendant has not made a payment on account of the Visa Loan w/th Plaint/ff since March 30, 2001. 9. Plaintiff has maintained a statement of accotmt keeping an accurate and running amount of debits and credits made on Defendant's account A tree and correct copy of the statement of account is attached hereto, incorporated herein and marked as Exhibit "C". 10. Plaintiff has submitted to Defendant a copy of the statement of account accurately show/ng all debits and cred/ts for transactions voth Defendant. 11. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 12. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and ov0ng on Defendant's loan account balance, all to the damage of Plaintiff. 13. As of May 13, 2002, the balance due, owing and unpaid on Defendant's Visa Loan account with Plaintiff is the sum of Two Thousand Nine Hundred Ninety-five and 18/100 Dollars ($2,995.18). 14. Pursuant to the terms and conditions of the extension of credit conta/ned on the loan application, Plaintiff is entitled to receive and Defendant agreed to pay an annual interest charge on the principal loan balance. 15. Pursuant to the terms and conditions of the extension of credit, Defendant agreed to pay reasonable attorney's fees and all court and collection costs. 16. Plaintiff has retained the services of the law firm of Godfrey & Courtney, P.C. in the collection of the amounts due and owing by Defendant. 17. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Godfrey & Courtney, P.C. ha the collection of the amounts due from Defendant incident to the within action, and Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 18. The amount of attorney's fees and prior district justice costs incurred in this matter is the sum of Six Hundred Eighty-five and 02/100 Dollars ($685.02). Any and all conditions precedent to the bringing of this action have been performed 19. by Plaintiff. 20. arbitration.. The amount in controversy is within the jurisdictional amount requiring compulsory Wi~,REFORE, Plaintiff, Pennsylvania State Employees Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiffand against Defendant, David R. Yoder, in the amount of Two Thousand Nine Hundred Ninety-five and 18/100 Dollars ($2,995.18), plus interest, reasonable attorney's fees and prior district justice costs in the amount of Six Hundred Eighty-five and 02/100 Dollars ($685.02), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, GODFREY & COURTNEY, P.C. 2002 P.O. Box 6280 Harrisburg, PA 17112 717.540.3900 I.D. # 74669 Attorney for Plaintiff VERIFICATION I, Bonnie L. Berkoski, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon infommtion which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to flue extent that it is based upon infomxation which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set foah in the aforesaid Complaint are made subject to the penalties of Iii Pa. C.S.A. §4904 relating to unswom falsification to au~orities. Date: Bonnie L. Berkoski Collection Manager for PSECU Doe~m~u #.. I8012J. 1 You're Pre-Approved for up to $10,000 on our 9.9% APR Capitol Card ®VISK*! 0 168 ~89Z80 DAVID R YODER 1422 BRADLEY DR .APT C 313 CAP. ISLE PA 170t3-1266 ~Zow do ~jo,, w~rtP There's never been a better time to take advantage of PSECU's Capitol Card ®VISA! With our C 9.9% APR rate for purchases and our 12,9% APR ~"' for cash advances and VISA Checks, there's no ~' better card on the market! And to make it even better, you're pre-approved! Just take a minute to F:fl/out a. nd a/gn the short application below and we'11 send you a Capitol Card VISA. Yottr good credit history allows us to make you th/s 'Xv/n-w/n" offer - you'll receive our 9.9% \flSA w/th no mnnual fee. - .... 9.9% APR for purchases, 12.9% APR for Check~ or Cub Advance=. VISA Cheeks - to pay offh/gher interest cre~t c~ds elsewhere. No ~nu~ P~. No Cub Ad~ F~. Up to 25 da~ of ~ on pur~. How does PS.CO' rain? * We have your busine~! Hurry! Offer F-~ires Febr#ary 28, 1997 (Offer good only to individual named l:elow) 289A.MK708A$69 P~ p~t ~ ~ucst~ h~fomation, [n~mplc~ fores may ~u~ deMys ~ pr~css~g yo~ appH~tion or a ucC, N~e Home Phone B~ Date DA~ YODE~ (717) ~1~718 S~i~ ~' E~r/ Ac~l O~oss Annual Income [] Up to $15,000 r'~ $z5,OOl. $2'2,500 [~22,$01 $30,000 Please send a~. addlti~na! ~-a,~t at no ~ ~ fcr (plcasc print clearly): First Name [] 530,001 to $36,000 [] $36,001 tO $48,000 [] $48,001 to $60,000 [] $60,001 to $7'2,000 [] $7,2,001 to ;$84,000 [] Over $84,000 Middle Init;al Las; Name fhoz'ere~dthisf°rmar~deverttfhir~lhauesmtedinilistr~e Yo",~areauthorlzed:oo~,~.ainmyernptoymen~hisioryorimyotht;,rinforrnation a~t W re~ m o~m su~ ~o~ion ~d ~dfl ex~n~ ~fh ~. I ~e fha* ~h~ a~p:~ s~/1 ~ governed by all ~i~ or,he ~A~INER Cmdi~ ~em~ ~='th the Credit Cnio5 all ~dendu~, ~es ~ ~ ih~o ~d all the~ ~d ~i~ ~ set fo~h on ~e a~a~ed d~cl~ur~ ~ all chase do~men~ s~ll ~ in~mt~ herein by - ~., ,/ / 7~, -- SCANNED 1. HOWTHIs PLANWORKS~Thistsanopen_end multi-leatumdo'edilplan. We .... Bw~cnmay.De payable t°Y°~ in oM~' fo*' us to collect ~, ~'~e_~any draft o~' ' uue unoer your ~sumnce Yo~ ~ .... .'=:' ,~,mm ~ benefits anticipate that, from tim to lim~. you ~11 Ix~ow mo~y (cal~ 'ao~a~") __l~.__Ptan' We am n~t required to make adva~es to yo~ an~t M~ i~n a~:l ~ interest rate fo~ each subaccount ex, rest, ed as a daily pedo~c rate and oomesponding annual percentage rate and other cha~ges. It may also have other temps and a schedule for determining the payment amounts. 2. CREDIT UMIT ~We may, but do no~ have to, establish a cmoit limit on certain imm~:ratelYU~eame~twhiche~eeds~hecmditli~ ..... ye. pmn-~,.e ~o rely 4. PLAN ACCESS ~ Yo~ can obtain ~ advances in any manner a~_ed by us' If we &ll°w Y°U to use your ATM/~ebit card lo access Ihe plan, you may be liab/e f~' the u~authodzed use of your ATM/Oebit card. You will not be liab~ for unauthorized use that occu~ after you notify us, orally or in writing, of the loss or poss~le unauthorized use. If you believe your ATM/Debit card ~-~ ~ stole~, immediately inform the Credit ~ ~-~ ....... nas ueen ~ or number or 8ddre~ b'~t ....... "-."Z~! .?_~a=_~ or writin~ us ~t the :ralres' Y°U received a{ the time Y°u rec~ Y<xJr ATM/Deblt ea~ even ff e~- reseats i~ an advance beir~ made from your ove~lraff T-~ -'~. $. FINANCE CHARGE ~ The dollar amount you pay for .suDaoco~.. money bom~wed Is ~;we~ ._m~/_. PaY ?ese o~. ~a~<ms, txJt we are not required to do .~._P .'~SUred. we o,~ ~u me unpam balance of the advanc~ and Y°~ will PaY interest °~ ~3~e am°unts at ~rat~hYOU~ .gmat, to pay o~ the advance. We may receive pa~nents in ~e ~.~Jrance from a 8. NOTICE -- If yo~ do not purchase ~ ~ed prof~rty l~,umnce ~,~,~,.. 9. CREDIT INSURANCE -- Credit life and/or o'edit disabil{ly insurance is ol~,icx~l mo'ease or Ihe pedod of Ume .... to----- __ your {x~,,,'nents may beyond the approximate term ~tated o~ the Addendum. The o'edit i~surance rates may change during the Plan. If the rotes change, we will p~ovide any notices required by applicable law. ~,~lal~ t~s~sMu~:_O~_a_ ~eg.ula~.bas,$ ~ will receive, statement State-',~-ts -...-~ - -,: ..... ~ um r~an ounng ~e peno~ covered by Ihe statement. ~,-n";='"- :~,.~=:~,,, ,K~_._~. ~e _sent. to you at the most recent address you have ~+.~.~'~ ,"_.-_,,_-,_,u.. ~.,-~ss_appucame law requires notice to each joint bom~wer "~'"'~ 'v ~u~Y one m YOU wi, be notice to all. · .~ ~....Jol~r ACCOUNTS --, m~s ~s a j~t accoum, eac~ of yo~ is ~cr~dua,v a.d . _~ "esP~ ~or Pa'~ng M amoums owed. That ...... :_-' ~ under lhe {:~-~ ---~--, - ~ . ,,,~,~, ~ ~ er~ our · ~' -v-,,=~ any one m you Incrrvfdually o' against all of you are nol subject to Ihe secu.~ ....... · ~.--~,,o~ ~cudty may be mqulmd means the secudty wgl be a new car. A subacoount called .Olher ~umd o~ i~ the future. Properly sec~dng offie; roans wilh us may also secure ~e Plan. H°~ever, ~t you have give~ your dv~elr~ng as secud~y for a loan with us, Ihat o, wefli~g ~ not secure an advance made under the Plan. ?. PROPERTY ~NSURANCE, TAXES AND FEES ~You wi8 be re~uim~ to purchase .. --",,v,, ,~-yyoua~eadyhave, of - --'v" -0 mrms under Ihe pla~. . -~ .... -, not considered a ~h"l:'a~a~anyeme~,.,~,~ ....... P~nata.yame. yo~n~m,~ 27. VERMO~ NOTICE ~ C~iGNER __ 'YOUR ~~.:;_:~-:"~---=~ ~.~,~ ~ ._ ~RE ON ~IS N~ M~NS ~AT YOU ARE '~ ' ~ W~ ~ . -- ..........w ~ "u-~ER ~ N~ PAY,.~E ~DER ~ A ~  ~ ~ ~ ~M YOU. ~_.._c~.~ ~,,= FO. cnaxr C^RO "UnC.AsEs . YOUR RIGHTS AND OUR RESPONSIBILITIES -.~ ~ . ~lf ~e statement was correct. *.~..,,.~, ~, pay ~rm ' ' amoun ...... mnam. y~j -- Nte~' we receive your letter, # _~ ..-7'=.~.~' -~,~.c(a)You must have,~,.~ ~._"~:'~.._'.x ~' .~'~ce~.There are tw~ we cannM l~yto co41ect any amount yoo e.x-r~. _.._. ~ -,-m ~uu maes of ~,..~.__. --- -~,,=~a~e or_ and U~ ~ MON~ A~ C~D ~-~ ~ ~ ~ ~ ~~ ~s) to ~ ~ ~ ~-~)' ~ (5) ~ ~ a~ ~ ~ ~ ~ ~ i ~ ~.__ "--' ~ ~ ~r ~~~N~~ ~A~D ~ ~ ~ ~ ~~ ~ ~a ~US SYS~ ~ ~ ~'~~ ~t~ ~ ~ N~PiN~ ~ and .whe~ your PIN is used at a Merchanfs ten~inal, it wl authenticate and validate - - · validate the direc~ons g~ven just as ~ actual signature v~ll aulhemicate your directions given to us. You acknowledge ~ your PIN is an ider~ti°~ c°de that i~ Pe~<x~al and confi~ and U~at the use of ihe PiN wi~ ~e MONEY ACCE~ CARD is a security devise k~' your m:coum(s). T~erefom, YOU AGREE TO TAKE ALL I~NABLE PRECAUTIONS THAT NO ONE Iq_SE LF~ YOUR PIN. You agree to contact us at once if you il [ ~sued to yo~ or PIN has been Io~ Or ~tole~ m' n~ is mts~g f~tm~ your accot~t(s). Yo~J also ~gree that if your ~ ~E~net~ ~ ~.____~ REE THAT IFYOU GWEYOUR MONEY cho~e a PIN tl-4t Is early ~ ......... -- ~ ........ F'~m~/cna~ge on ~y _ _~ ~sl~mement ..... ~"~ ~'~ wrmr~ °t soc~ amendments ~ changes and yoor use o~ change shall coflslflute your acceptance of and agreement to such '* ACH- Right to Stop Payment ~nd Procedure~ f~. doing ~o. if yo~ have Is nO~rm~emeb4e. '-' ..... -v"'~ -~ um Mut4EY ACX~.G~ CARD .-. ..... .,~ q~/s o~ mom before Ihe paymem isT. _ ~ REGULATION 'E" DISC~.OSURE ----., - ,,,-,~ - ,~,~uaa Io get INs 1. Summary of Consun~. Liability · ---- m~ me money in your a,.,~,_ _ ~ ..,. Als°' if Y°Or stateme~ ~Ys transfers ~tt yoo did not make, tell us at o~ce. If · ' If a ._.g~od reason suc~ as a Io~ trip or a hosp~ stay RO. Box 6'7013 Hanisbu~, PA 1710G-7013 psc-cu mmine~ 7:00 a.m. - 5.-~0 p.m. M. F · e-'oo a.m. - Noofl Saturday ' ~'~'C' '4~H m~d '~"T ' PSECU's ~ Days am Monday mmu~ Fdd~y, .4. ~s ~ Transfe,.s. Consumer iday idake ' mqumes o~ c~. savings and pSL: ~ from ' TRANSACTIONS, or 20 d~s for MONEY ACCESS CENTER ~~~~~,~s~ · ~S~M ..... ~~ '-- your MONEY ACCE~ CARD. a) Determine the account balance(s) of your Chectdeg, your Regular Shams, and yo~Jr Persoflal Service Loan (PSL). b) W'rb4draw cash from your Chectdng and your Regular Shares. c) Make a cash advance from yOUr pef~3flaj Service L~an (pSL). NOi,-: Deposits am not available b4rough HONOR SYSTEM ATMs. These are the MONEY ~ CENTER services cun~rdy ava~a~e throegh 13. O~e~ ATM Network A~cess · ff the ATM has an entry do<)r, close the do<x. i~or to initiaUeg your tra~sactJofl' · P~ ~ur ~ a~y ' Oir~ ~1~ ~ A~ ~ lo an ~pmp~te ~em of ~ ~r ~ ~ A~ N~ ~ ~lde~: ~ ~ ~ ~ N~ ~ For those mem~m who pumhase a vehicle under ~e DRIV Program, pl~se review the following' ~C Nofl~: 14. Pufl=h4meTmnsac~N~ ANY HOLDER OFTHIS CONSUMER CREDIT CONTRACT * _~.~__O,,~,,.~..~..,~EY.:c,~_.c~,~.oood.. ~_SU_~CT TO AU. CLAMS AND DEFENSES WHlC, I - ~ .... ._ ? "' ~AY mM emeammer4 ('Memanr) v, hem ,,,~.,--- ~= OEBTOR COULD ASSERT AGAINST THE S;I I I=1:1 _ ~ .m accep~l ~ ..~ ,~-.~- ~ '"""~:' OF GOODS OR SE .~-'e~--wm~ededuc~ ...... ~"* ,~e_.!m~. ~,,,uch. * RVICES OBTAINED WITH THEI .u~g ~e MO~EY ACC~ ~f~your~ Whe~_ you m~e a Pu,~se PROCEEDS HEREOF· RECOVERY HEREUNDER BYTHE =...~... .... ~=._.. ...... .~...~..~. _D_E_B~OR S~J. NOT EXCEED AMOUNTS P~UD BYTHEI r-, -~ ...,..~ ~um ,ae~n.~ ---~.. -,-w UEBTOR HEREUNDER. v'ah~awaVp~hase ~ U Yo~ ~o n~ have adequaie fu~s .v.aa~e k Account 0168589280 YODER,DAVID R 12/27/61 168-58-9280 Date: 08/06/02 Account Name Birthday Social Sec Home Phone 0168599280 YODER,DAVID R 12/27/61 168-58-9280 717-258-6718 GP~AYBILL,MARY A 02/21/51 190-42-2780 APT C 313 1422 BRADLEY DR CARLISLE PA 17013-1266 Account Type: GENERAL MEMBERSHIP Account Branch 0000 S 01 REGULAR SHARES S 02 20% COLLECTION COSTS -1ST S 03 COLLECTION FEES 1ST LOAN L 09 CHARGED OFF VISA LOAN L 99 VISA LOST/STOLEN P 04 ACH DST GROUP 000000 P 04 ACH DST GROUP 000000 Due Date Payment Avail/DQ* 03/25/01 629.00 C 06/25/99 0.00 C 1,475.69 466.40 Relationship Code 00 Balance 5.00- 0.00 599.04- 599.04- 100.23- 100.23- 982.00* 2,995.18 0.00 0.00 IN T~E COURT OF COMMON PLEAS CUMBER! ,AND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW AND NOW, this ~ day of ,2002, I, Steven C. Courtney, Esq., of Godfiw & Courmey, P.C., attorneys for Plain{i~ffhe~by certify that I served the foregoing Complaint this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: David Yoder C/o Bret~ Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 By: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff DAVID R. YODER, Defendant NO. 02-02350-CV CIVIL ACTION -LAW PROOF OF SERVICE BY MAIL I, Steven C. Courmey, Esquire, do hereby certify that on August 9, 2002, a copy of the Court of Common Pleas Complaint filed in the above referenced matter was served upon the following person by certified mail, as is evidenced by the signed Certified Mail Return Receipt attaehedhereto. David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 Dated: GODFREY & COUTRNEY, P.C. Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717) 540-3900 Attorneys for Plaintiff · Complete items 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: '7/7 [] Agent B. R~eiv~ by ( Pdn~ed Name) J~'~elive~ D. is delive~ addm~ differ~t ~ ~?~ Yes If YES, enter delive~ address be~o~: ~ No 3. Se~::e Type [-~[-~=~i fied Mail LI Registered [] Insured Mail 2. Article Number (Transfer from service label) '7cc PS Form 3811, August 2001 Domestic Return Receipt [] Express Mail ~[~,,:~eturn Receipt for Merchandise [] C.O.D. 4, Restricted Delivery? (Extra Fee) [] Yes I02595-02-M-1035 Godfrey & Courtney, P.C. BY: Steven C. Courtney, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717) 540~3900 Attorney for Plaintiff PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-02350-CV CIVIL ACTION -LAW TO: David Yoder, Defendant You are hereby notified that on OI/lq/6~_.,, the following (Ol:de~) (tX~gr-~) (Judgment) has been entered against you in the above captioned case for your failure to file an answer to the complaint in the total amount of $3,680.20 plus costs and interest is herebyJ~tered. ·/' ' / - - Pr~-thonotary - ' ~ I hereby ce~i~ that the name and address of the proper person(s) to receive this notice is: David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 To: David Yoder, Defendido/a (Defendidos/as) Por este medio se le esta notificando que E1 de Del , El/la siguiente (Order) (Dc:rcto) (Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Prothonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 Document #: 216462.1 Godfrey & Courtney, P.C. BY: Steven C. Courtney, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (7! 7) 540-3900 Attorney for Plaintiff PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-02350-CV CIVIL ACTION -LAW PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff and against Defendant, Guy Hairston, for want of ANSWER TO COMPLAINT. ( X ) Assess damages as follows: Debt ................................................................ $ 2,995.18 Attorney's Commission .......................................... $ 685.02 Interest .............................................................. $ to be determined Filing costs ......................................................... $ to be determined TOTAL ............................................................. ~ plus costs ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. NOW /9 ( X ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judement is to be entered and to his/her Attorney of Record, if any, after the default occurred and at ~e)ast ten days prior to the date of the filing of this praecipe and a copy of the notice is attaca~eed. DATE: (~'~(~/ Signatur~ Attorney for Plaintiff P.O. Box 6280, Harrisburg, PA 17112 (717) 540-3900 ID#: 74669 , 2002, JUDGMENT IS ENT-~3~D/('~ABOVE Prothonotary/Clerk, ~i-vil~ion Document #.. 216462, I Godfrey & Courtney, P.C. BY: Steven C. Courtney, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717) 540-3900 Attorney for Plaintiff' PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff VS. DAVID R. YODER, Defendants IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-02350-CV CIVIL ACTION -LAW TO: David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 DATE OF NOTICE: September 3, 2002 ~MPORTANTNOTICE YOU ARE IN DEFAULT BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAy BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 800-990-9108 Ste~bn C. Courtney, Esq~ir~J P.O. Box 6280 Harrisburg, Pennsylvania I7112 Telephone: (717) 540-3900 I.D. # 74669 Attorney for Plaintiff Document ii. 215543. I Curt Long Prothonotary OFFICE OF TIlE PROTHONOTARY OF CUMBERLAND COUNTY Telephone: (717) 240-6100 Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff.' PENNSYLVANIA STATE EMPLOYEES CREDIT UNION versus Defendant: DAVID R. YODER Judgment No. 02-02350-CV CERTIFICATE OF RESIDENCE PA. R. C. P. 236 I, hereby certify that the precise residence of Plaintiff is: Pennsylvania State Employees Credit Union 1 Credit Union Place Harrisburg, PA 17110 and certify that the last known address of the within defendant is: David Yoder C/o Brett Riegel, Esquire 717 Sarah Street Stroudsburg, PA 18360 Steven C. Courtney, Esquire GODFREy & COURTNEY P.O. BOX 6280 Harrisburg, PA 17112 717.540.3900 Attorney for the Plaintiff Attorney ID# 74669 Document #: 216462.1