Preview
FILED
2 CITS - E-SERVE DALLAS COUNTY
9/30/2014 1:59:08 PM
GARY FITZSIMMONS
DISTRICT CLERK
Linda Schaffer
DC-14-11552
TEXANS CREDIT UNION ) IN THE DISTRlCT COURT
Plaintiff )
)
vs. ) 162nd
_ _ _ JUDICIAL DISTRICT
)
GARRY W. BELL and )
JUDY BELL, )
Jointly & Severally )
Defendants ) DALLAS COUNTY, TEXAS
PLAINTIFF'S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES TEXANS CREDIT UNION, Plaintiff, a corporation, and files this, its
Original Petition, complaining of GARRY W. BELL, Defendant, who is a resident of Dallas County,
and may be served. with process at the address of3909 Cove Road, in the City of Rowlett, Rockwall
County, Texas 75088, and who has a Texas driver's license number of TX XXXXX.278 and a social
security number ofXXX-XX-X026; and complaining of JUDY BELL, Defendant, who is a resident
of Rockwall County, and may be served with process at the address of 3909 Cove Road, in the City
of Rowlett, Dallas County, Texas 75088, and who has a Texas driver's license number of
TXXXXXX610 and a social security number of XXX-XX-X352. Venue is appropriate in this
county because the consumer contract made the basis of this lawsuit was in fact signed by
Defendants in this county.· Plaintiff would show the Court as follows:
I.
Discovery in this case is intended to be conducted under Level One. Plaintiff seeks monetary
relief of$ I 00,000 or less, including damages of any kind, penalties, costs, expenses, pre-judgment
interest and attorney fees.
Plainlifl's Original Pelilion Page I #14-45406-0
00181181.WPD
II.
That on or about August 25, 2011, Defendants, for value received, executed the Closed-End
Note, Disclosure, Loan and Security Agreement ("First Contract"), a copy of which, marked Exhibit
"A" is attached hereto and incorporated herein by reference for all purposes.
III.
That the Defendants promised to pay the sum of $24,917.20, with interest thereon at the rate
of 8.990% per annum, to the Plaintiff, who is the legal owner and holder of said note.
IV.
That the Defendants have defaulted in making the required payments under the terms of said
Note, and after allowing Defendants all just and lawful offsets, credits, and payments, the sum of
$9,009.73, with interest at the rate of 8.990% per annum from the date of last payment or credit
received on July 30, 2014, is due and payable, and though payment has been requested by the
Plaintiff, the same remains unpaid.
v.
That on or about September 21, 2011, Defendants, for value received, executed the Closed-
End Note, Disclosure, Loan and Security Agreement ("Second Contract"), a copy of which, marked
Exhibit 11 8 11 is attached hereto and incorporated herein by reference for all purposes.
VI.
That the Defendants promised to pay the sum of $10,378. 7 I, with interest thereon atthe rate
of7.990% per annum, to the Plaintiff, who is the legal owner and holder of said note.
VII.
That the Defendants have defaulted in making the required payments under the terms of said
Plaintifl's Original Petition Page 2 #1445406-0
00181181.WPD
Note, and after allowing Defendants all just and lawful offsets, credits, and payments, the sum of
$2,551.02, with interest at the rate of 7.990% per annum from the date of last payment or credit
received on August 12, 2014, is due and payable, and though payment has been requested by the
Plaintiff, the same remains unpaid.
VIII.
That on or about October 13, 2012, Defendants, for value received, executed the Closed-End
Note, Disclosure, Loan and Security Agreement ("Third Contract"), a copy of which, marked Exhibit
"C" is attached hereto and incorporated herein by reference for all purposes.
IX.
That the Defendants promised to pay the sum of $5,000.00, with interest thereon at the rate
of 17.750% per annum, to the Plaintiff, who is the legal owner and holder of said note.
x.
That the Defendants have defaulted in making the required payments under the terms of said
Note, and after allowing Defendants all just and lawful offsets, credits, and payments, the sum of
$3,454.09, with interest at the rate of 17.750% per annum from the date of last payment or credit
received on March 3, 2014, is due and payable, and though payment has been requested by the
Plaintiff, the same remains unpaid.
XI.
All conditions precedent to Plaintiff's right of recovery on this claim have occurred or have
been perfonned.
XII.
As a result of the abovedescribed defaults, it was necessary for Plaintiff to employ the
Plaintiff's Original Petition Page 3 # 14-45406-0
00181181.WPD
undersigned attorney and that Plaintiffs counsel is entitled to attorney's fees in the amount of
$1,500.00.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that the Defendants, GARRY
W. BELL and JUDY BELL, be cited to appear and answer this Petition and Plaintiff have judgment
against both Defendants, Jointly & Severally, in the sum of at least $9,009. 73, together with interest
at the rate of 8.990% per annum from the date of last payment or credit received on July 30, 2014,
in the sum of at least $2,551.02, together with interest at the rate of 7 .990% per annum from the date
oflast payment or credit received on August 12, 2014, and in the sum of at least $3,454.09, together
with interest at the rate of 17. 750% per annum from the date of last payment or credit received on
March 3, 2014; together with attorney's fees in the sum of$1,500.00; all together with interest from
the date of judgment; and all costs of suit, and for such other and further relief, both general and
special, at law and in equity, to which it may show itself justly entitled.
Respectfully submitted,
BY:
Chris Blalack, ID# 24038770
cblalack@blalack.com
John G. Jackson, Jr., ID# 24079778
jjackson@blalack.com
Robert A. Woodcock, ID# 24010490
rwoodcock@blalack.com
5550 LBJ Freeway, Ste. 400
Dallas, TX 75240
214/630-1916; 214/630-1112 (fax)
* * * PLEASE SEE ATTACHED NOTICE ***
Plaintifl's Original Petition Page 4 # 14-45406-0
00181181.WPD
NOTICE
In accordance with federal law, you are notified that:
The law firm of Blalack & Williams, P.C. is legal counsel for the
Plaintiff in the above-captioned and described lawsuit and we are
attempting to collect a debt for the Plaintiff.
Accordingly,
**This communication is from a debt collector, and this is an attempt to collect a debt and
any information obtained will be used for that purpose.** ·
Unless you dispute this debt, or any portion ofit, within thirty (30) days after you receive this
notice, we will assume that it is valid.
If you notify us in writing within the thirty (30) day period that you dispute this debt or any
portion of it, we will obtain verification of the debt or a copy of any judgment and mail it to you.
If the Plaintiff is not your original creditor and you submit a written request within the thirty
(30) day period for the name and address of the original creditor, we will supply such information
to you.
If you do dispute this debt in writing within the thirty (30) day period, we will suspend our
collection efforts, through litigation or otherwise, until we send you verification.
**This advice pertains to your dealings with our law firm as a debt collector. It does not
affect your dealings with the court, and in particular, it does not change the time at which you must
answer the Petition. The Citation is a command from the court, not from our law firm, and you must
follow its instructions even if you dispute the validity or amount of the debt. The advice in this
Notice also does not affect our relations with the court. As lawyers, we may file papers in the suit
according to the court's rules and the judge's instructions.**
Plaintitl's Original Petition Pages # 14-45406-0
00181181.WPD
• l
~TEXANS
r ll CREDIT UNION
LOAN AND SECURITY AGREEMENTS
AND DISCLOSURE STATEMENT
LOAN DATE LOAN NUMBER GROUP POLICY NUMBER MATURITY DATE
812512011 20010657211 10/22/2016
-Judy Bau
3909Cove Rd
•: ~ :."::.l,. . ..
Rowlett, TX 75088
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· BORROWEFf2\'.'.::.. ·..
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NAME !AND ADDRESS IF DIFFERENT FROM BORROWER 1)
GarryW.BaU
3909Cove Rd
Rowlett, TX 75088
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_,_., '
.. : ... TRUTH IN LENDING DISCLOSURE 'e"':·means an estimate
·,• .. ,.
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ANNUAL PERCENTAGE RATE ANANCE CHARGE Amount Ananced Total of Payments TotaJ Sale Price
Thocost or your credit es o yearly rate.
The dollar amount
tho The amount you wlQ havo
Thu 8m0Wlt or crudlt The total cost or your purchase on c:redlt Is
provided to you or on
credit wlll cost you. paidafter you have made
yowbaha1'. $
all paymsnts as sc:hodulCld.
8.99% which Includes your
$6,557.21 • $24,917.20 $31,474.41 • downpaymunt or $
Your Payment Schedule WiD Be: Prepayment: If you pay off early you wlU not have to
Number of Payments Amount of Payments When Payments Are Due pay a penalty.
59 $524.58 Monthly (12/yr)
Beginning '112212011 Required Deposit:The Annual Percentasa Rate does
not take Into account your required depos t, 1.f any.
1 $524.19 Ending 10/22/2016
AssumrtJon: Someone ~Ing your mobne home
Property Insurance: You may obtain 1>roperty Insurancefrom anyone you
D canno assume the rema nder of the loan on the
orlglnal terms.
want ttiat Is acceptable to the credit union. If you get the Insurance from us,
youwlll pays
Demand:~ This obligation has a demand feature.
Late Charge: All disclosures are based on an assumed
If your P.BY!Mnl la received 10 days or more after the due date, you w!ll be maturity of one year.
c:liargei:I a late fee of 5% of lhe payment due.
Filing Fees Non-Fmng Insurance
$ $
the credit union may also secure this loan. You are givl~ a security Interest in your
Security: Collateral securln¥ other loans with
shares and dividends and, Iany, your deposits and Interest In tha credit union; and the property describe
below:
Collateral Property/Model/Maka Year l.D. Number Type Value Key Number
MERCEDES.BENZ R Class 2007 4JGCB85ES7A054537 $
$
$
Other (Describe)
Pledge of Shares In Account No. In Account No.
See your contract documents for any addl'llonal Information about nonpayment, default, and any required repayment In full before the
scheauled date.
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·~ 'SIGNATURES'" · :.,, ... .. ..•• ••.:.,' . ; ."4:·t-.:'
By signing as Borrowerbyou agree to the terms of the Loan Agreement. lf_property Is described in the "Security"section of
tfie TruttiIn Lending rsclosure, you also l!_greeto the terms of the Security Agreement. If you sign as "Owner of
Property" you agree only to the terms of the S"'ecurlty Agreement.
CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT.
!SEAL)812512011
DATE
lx-/()b
BORR 2
(SEAL)
DATE
I
812512011
812512011 I
8125/2011
CSEAl) llx (SEAL)
QOTHER llOAllOWER OWNER OF PROP£R1Y WITNESS DATC 0 OTHDI BORROWER 0 OWNER OF PROPERTY0 WITNESS DAlt
OcuNA MUTUAL GROUP. 1999, 2000, 01, 02. 05, 06. All RIGHTS RESEllll[O NXX026 (LASER)
Credit UnlonTaxans CU Loan No.20010657211 Acct. No.(
Bonowl!f(s) Judy Bell GanyW.Bell .
I .I
Itemization of Amount Financed of Amount Given to You Directly Amount Paid on Your Account Prepaid Finance Charge
$24,917.20 $0.0D $0.00 $
Amounts Paid to Others on Your Behalf: (If an amount Is marked with an asterisk (•) we wW be retaining a portion of the amount.)
Tu Tu
$24,904.20 To
MERCEDESBENZ FINANCIAL SERVICES To
To To
To $13.00 To Overnight MaB Fee
Tu Tu
Tu Tu
To To
In thisLoan Agreement "Agreement" allreferences to "Credit Union, 'we" "our," or us,• mean the Credit nlon whose name
appears above and anyone to whom the Credit Union assigns or transfers this Agreement. All references to "you,• or "your" mean each
person who signs thlS Agreement as a borrower. ·
1. PROMISE TO PAV. You i:iromlse to pay $24,917.20to the Credit Union plus Interest on the unpaid balance until what you owe
has been repaid. For fixed rate loans the mterest rate Is8.99% per year. . ·
CoDectlon Costs:
You agree to pay aD costs of collectlng the amount you owe under this Agreement; lndud!ng court coats and reasonable attorney fees.
2. PAYMENTS • You promise to make navments of the application. You will also be In deJ.Jult If someth~n happens
amount and at the time shown In the Tnlth In Le11dlng tnAt we believe may seriously affect your abillt to r~pay
Disclosure. You may pre~y any amount without penalty. ll what ~ou owe under this ~reement of if you a in derault
vou prepay any part Of What YO'U owe, you are stlll req\Jlred under::BnY..~thJ!r_1QJl.1111Qteet y~u have with us.
to make tl'le rd'iilJlarlrr schedured payments, unless we hm'e 6. ACTIONS AFTER DEFA • When ~ou are in default, we
pgreedimto a c;h.!'Jle 1n the p.iwment:dschedule.kBecause t Is rnav dema11d thlm mediate patyroent o the rienhtltre
Ul'!Pald
1s a s 1P1e 1oan,
1ni.a1est ir v~u o not ma e payments ba1anetl under 1s A..qreemeh • You wave1 a11v g . you nave
exactly els scheduled, your filfal.Jayment may bl! lfloreor ·to receive demand ror payinent, notice of lrften'l td" demand
ess tnan the amount of the nna ay111ent that Is disclosed. Immediate gayment arid ·notice of demand for Immediate
lf you elect credit Insurance, e will ·eitherInclude
remlum In y9ur payments or extend the term of your loan.
the ~avroent.
ofltinue to
Ifwe
pa'l
demand
interest at
Immediate
the rate
payment,
pro{flded
vou
fof in
will
this
Hf the term 1s exnmded. you Will be required to make greement, llnfllwhat lsou owe has lieen repaid. We will
additional payments 9f ~e sched1.1led amount, untilwhat a So apply against what ou Qwe any shares 11a::id/or deposits
you owe has'llee11 paid. OLJ _prpmlse to make all Pavments given as- securltv und r this Aal'bement. we may also
to the elace we chdose. f thfs loan refinances anOttfer loan exercise any oth'er rights given Dy law when you are In
'fee nh~e with ,Y.~':{ dthe
orers 10:~. will be canceled and 9~ffl'bH PERSON RESPONSIBLE • Each erson who sl ns
3.~~A'fnR&8£~os l\F ~~ . l?the proceeds of this loan this Afreeinent will be lndivlduallv and loi.Jliy responsib1a._9t'9r
are rnailed to you, Interest on this loan begins on the date fn1yln the entire amount owed Onder lhfs" ~gre&ment.f This
the lgan .Pr~eeds are mailed to you. l!an we can enforce our rights against any one o you
4. SECUR TY ~OR LOAN • This 1'.~eement Is secured by all mdMd.YBllY.OC aaalnstfall of vOt.ftog,etHerkl
properti descnbed In the "Securi " section of the TruDl in a. LATE CHARGE· 11 you irre late in ma nu Pevrnent, you
Lendln Disclosure. Pro11erty sec Ina other loans~u ~ave ~romlse to pa_y the latlf charge shown In thelnltlf In Lending
with u also secures thlS 10an, unress the rnro s a Dlsclo~e. tr no late charge Is shown, you will not be
dwellll'l!I.. A dw~lllng secures this.Joan only- If
Is de c bed charm AnQ,
in the ''Securltrrs«rction of the Truth In L:end na Disclosure 9. D~ .v INENFORCING RIGHTS • We can delay enforcln2
~Y~otW:J~~atn1s'~~ ~~ ~0~JsP~.Q~li~~ sJ1~~f\n~~1WJ~ :ir.igr.ioigsr!,~h~~gRft~~~ :g:a~e~~an~h~Ta~:r; 0'1~~:n
and loint accounts you have wiih 'ds. A statuto~ lien enforce this Agreement against your heirs or legal
meal'fs we have the naht under federal law_ and man state reprQ.entatlY.es.
laws to clplm interestln your accounts: We can en orce a 10. CONTINUED EFFECTIVENESS • If any _part of this
statutory lien aaainst your shaf8$ 2'nd davide~s, and If anv, A'reement is detennlned by a court to be unenrorceable, the
interest and dl!poslts,In all1ndlv1dual and olnt accounts re t wlll_remllln In_ pffect.
vou have with us to satisa any di~
outs_t_it financial 1 • NOTICES • Notices will be st1ntto vou at the most
bbllm1tion that is due and pa ble to us. we m 1v exercise recent address ~u have given us 1n writing. Notice to any
ourliaht to enforce this lien thout further no Ce to YQU, Qne 8f vo..u. will oatlce. t6 all.
to the extent Permitted by law. For all bonowers: -You 12. ITitER PRO ISIONS •
pledge aS SeCLJrityfor this loan allShares and dividends If you are in dd&Ult UEldllr
any tonl8 Ot: thiD agrHmont,
bnd, jf anli, all de~Slts and inter&Sl in all joint and in addition to all other ri9bta, we may iDCrO&H tho
l~dl~~UrJi~r~~Llfl: ~ta~~ 1m 1:~cD:'1~9u~niog"te~i': ~rm =e:u~:~..~TB t:orany or all outatandiD9
allow us to apply the funds ln wur accoul1l(s t wn-at~ou
owe when y6u are In default. Iha statutor1 len and our
Pledge do rrot apply to any Individual Reth1tment Ace unt
br arz other account that would lose special tax treatment
undt ...suite or federal law if a!ven as seturitv.
5. D FAULT· You will be lnllefault under tnls Agreement if
you do not make a paym_e_nt of the amount reqDlred on or
before the date It Is Hult.You will be In default ff you break
an~ prom1$e vou made In connection with this Toan or if
an ohe is in aefault under anv se~~rltv agreement made In
co nectlon with this Agreeml!lnt. Yolf will be In d~fault If
vou die, filefor banktlJptcy, become Insolvent lt:ha\Is,
Onable to pay your bills and loans as they become i:iue , or
If you made any false or misleading statements In your oan
0 CUNA MUTUAL GROUP. 19&8. 2000. 01, OZ. 05, 08, All RIGHTS RESERVED NXX026 (LASER)
.. Credit Union Texans CU Loan No. 20010657211 Acct. No. 6
Borrower(s)Judy Bell GanyW. Bell
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In thisAgreement all references to "credit union,""we," "our" or 7. INSURANCE NOTICE • Ifyou do not purchase the required
"us" mean the credit union whose name apf>!!Srs on this document prop~ Insurance, the Insurance we may purchase and charge you
and anyone to whom the creditunion assigns or transfers thisfor WIU cover only our Interest In the Property. The premium fOr this
AgreemenL All references to the "Loan" mean the loan described InInsurance may b8 higher because the Insurance company may have
the Loan ~reement that Is pan of this document. All references togiven us the i'lght to purchase Insurance after uninsured collateral Is
"you," or "your" mean IID.Y person who signs this Agreement. rost or damaged. 1h8 Insurance wlD not be liability Insurance and
r. THE SECURITY FOR TFIE LOAN - You give us wfiat Is known as wm not satlsry any state financial res~~ or no fault laws.
a securltv InterestIn the property described In the "Securltv" a. DEFAULT. You will be In default If you breek any promise you
section o'lthe Truth In Lending Disclosure that Ispart of th1smake or fall to perform any obllgatlon you have under this
Agreement. You wm be In default If any propei:iy you have given us
document {"the Propertv!'). The segurtty Interest you give Includes
all accessions. Ac:Cessfonsare things which are attached to or as security ts repossessed by someone elSe, seized under a
Installed In the Property now or In the future. The security Interest
forfeiture or slmllar taw, or If anything else happens that
also Includes any ·l'el>racements
for the Property Which you buy slanlficantlyaffects the value of the property or our security
within 10 days of lhe Loan and any extenslOns, renewals or tnferest In It. You will also be In default under thlS Agreement If the
reflnanclngs of theLoan. It alsolncluy federal Trade default.We "'!fill
not be responsible for any olher propeny not
Commission Credit PracticesRule or your prlnclP.al
residence,the covered by· thisAgreement that you leave Inside the Property or
Property will secure only this Loan ana not other loans or amounts
that ls attached to"lhe ProP-erty. We will try to return that propeny
you owe us to you or make It available for you to clalm.
J. OWNERSHIP OF THE PROPERTY. You promise that you own the Affer we have possession of the PropertY. we can sell It and apply
Property or, If this Loan Is to b~ the Prope!\Y. you P.fOmlse you will
the mon~ to any amounts you owe us. We· will give you notice oT
use the Loan proceeds for that purpose. You promise that no one any publlc dls_posltlon or the date after VJhlch a prlvafe disposition
else has any Interest In or claim against the Propeny that you have
wm be held. Our expenses for taking possession of and seDlng the
not alreadYtold us about. You promise not to sellor rease the Property will be deducted from the money received from the sale.
Property or to use It as securltv for a loan with another creditor unlll
Those costs may Include the cost of storliig the Propet:ty, P.feparlng
the Loan is repaid.You prorrilse youwillallow no other security It for sale and attorney's fees to the extent permitted unc.ter state
Interest or lien lo attach to the Property either by your actions or by
law or awarded under lhe Bankruptcy Code.
o~ratlon of law. If you have agreed to pay the loan, you must pay any amount that
4. PROTECTING THE SECURITY INTEREST - If your state Issues a remains unpafd after the sale moneyllas been appllecfto the unpaid
titlefor the Property,you promise to have our security Interestbalance of the Loan and to what you owe under this Agreement.
shown on the title. We may have to file what Is called a financing
You agree to pay Interest on that amount at the same ra1e as the
Loan until that amount has bee1:1_~ald.
statement to protect our security Interest from the claims of others.
You Irrevocablyauthorize us to execute (on your behalf), If10. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE'LOAN •
applicable, ana me one or more financing, continuation or We can delay enforcing any of our rights under this Aareement any
amendment statements pursuant to the Uniform Commercial Code number of tlrnes wlthOut losing the ability to
exercfSe our rights
(UCCl In form satisfactory to us.
You promise to do whatever else later.We can enforce thisAgreement against your heirs or 18gal
we think Is necessary to protect our securitv InterestIn the representatives. If we change Ihe terms or the l.Oan, you agree tllat
Property. You also promise to pay all costs, Including but not limited' this Agreement wtll remain rn effect. ·
to any attorney fees, we Incur In F.Qtectlng our secuii~ Interest and
11. CONTINUED EFFECTIVENESS • If any part of this Agreement Is
rights In the PropertvcJ!> the extent permitted by appllCable law.
determined by a coun to be unenforeeable, the rest wtn remain In
5.USE OF PROPER 1 T • Untilthe Loan has ceen paid off, you effect
promise you will: (1) Use tf!e Property carefully and keep It In good
12. N.ORTH DAKOTA NOTICE TO BORROWERS PURCHASING A
repair. {Z) Obtalriour written permission t>efore maldng · majorMOTOR VEHICLE • THE MOTOR VEHICLE IN THIS TRANSACTION
cHanges to the Property or chang~ the address where the Prope~ MAy BE SUBJECT TO REPOSSESSION. IF IT IS REPOSSESSED
Is kept.(3l lnfonn us ln writing befor§ changing your address. (4)
AND SOLD TO SOMEONE ELSE AND ALL AMOUNTS DUE TO THE
Allow us to Inspect the Prope!'lY.(SJ Promrtry notifyus If the SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY
Propertv Is damaged, stolen or abUs~. (6) No use the Property forHAVE TO PAV THE DIFFERENCE.
a~~ unrawtul purpose. (7) Not to retitle property In
anotller State13 NOTICE FOR ARIZONA OWNERS OF PROPERTY • It Is unlawful
trP8m.~~l~SURANCE. TAXES AND FEES. Vou_promlse to pay for· you to fan to retum a motor vehicle that Is subject to a security
ali taxes and fees Olke registration fees) due on the Property and to
Interest, within thirty days after you have received notice of default
keep the ~ insurecragainst loss and damage. The amount and The notice wlllbe malfed to the address you gave us. It Is your
coverage of the pro~lriSurance must be acceP!Bble to us. You respqnslblllty to notify us It your address changes. The maxlrilum
may provide the pro Insurance through a policy you alrea{Jy~nalty for unlawful failure to return a motor vehicle Is one year In
~Ison and/or a fine of $150,000.00.
have, or through a po Icy you get and pay for. You promlse to make
the Insurance policy payable to us and to dellver the policy or proof
of coverage to us tr aslted to do so. 14. NOTICE: ANY HOL R OF
whtms'"°
[Jlb• foDow/09 llfl.fiCJI JIP.Pl~D,,sEONL r
THI~
lx»t.S11f111t_Rls JM,R1cked.
CON~:UMEI CRED 11
If you cancel~our Insurance and get a refund, we have a right to CONTRACT IS SUBJECT TO AU CLAIMS AND DEFENSES
the refund.Ir the PropertyIs losl or damaged, we can use the WHICH THE DEBTOR COULD ASSERT AGAINST THE
Insurance settlement to repair the Property or apply It towards what
SEUER OF GOODS OR SERVICES OBTAINED PURSUANT
you owe.
may be
You authorize us to
payable to you
endorse any
In orderfor us to
draft or check
collect any
which
refund or HERETO
oR
WITH THE PROCEEDS HEREOF
•
RECOVERY
benefits due under your Insurance policy. · HEREUNDER BY THE DEBTOR. SHALL NOT EXCEED
If you do not pay lhe taxes or feeson the Proper:ty when due or AMOUNTS PAID BY THE DEBTOR HEREUNDER.
keep ItInsurean. .
fr
zooo. 01, OZ. 05, 08, ALL RICHTS RESERVED
0CUNA MUTUAL GROUP. 11199. NXXOZ6 (LASER)
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LOAN AND SECURITY AGREEMENTS
AND DISCLOSURE STATEMENT
LOAN DATE LOAN NUMBER ACCOUNT NUMBER GROUP POLICY NUMBER MATURITY DATE
9/21/2011 20010848167 10/22./2015
.. I~I•
!'
' BORROWER 1 . .,... ''uvcR.2 '..... ·~1
11N4 AND ADDie&» NAME (AND ADDRESS If DIFfEJIENT FROM BORROWER 1)
GanyW. Bell JudyBeU
.
3909CoveRd •·.3909 Cove Rd
Rowlett, TX 75088 .. ...
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..;~owletl, TX 75088
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ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Flrianced· Total of Payments Total Sale Price
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The total cott at your pun:hasa on credit It
credit wlD cost you.pnMded to you or on
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