HomeMy WebLinkAbout07-1389MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7154
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
JAMES S FERGUSON
111 Parker Street
Carlisle, Pa 17013
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 complaint and notice are 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
for any other claim or relief requested by the
plaintiff. You may lose money or property or
other rights important to you.
Le ban demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta asentar una comparencia escrita o en
persona o can un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se defiende, la corte tomara medidas y
puede continuar la demanda en contra soya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del demandante
y requiere que usted cumpla con todas las provisioner de esta demanda.
Usted puede perder dinero o sus propiedades u otros derechos
importantes parr usted.
LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA
-GO-TOO[LT-ELEPHONETHEOFFICE SETFORTH BELOW TO _---_O-LLAMEPORTELEFONO-A-LADFICINACUYADIRECCION-------------
FIND OUT WHERE YOU CAN GET LEGAL HELP. SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE
SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
2 Liberty Avenue,
Carlisle, PA 17013
(717) 249-3166
Defendant(s).
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 67 - 13?p Otut
CIVIL ACTION COMPLAINT
AVISO
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7151
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
JAMES S FERGUSON
111 Parker Street
Carlisle, Pa 17013
Defendant(s).
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 617- !3pl? ?luc ('1
CIVIL ACTION COMPLAINT
1. Plaintiff, Ford Motor Credit Company, is a Corporation with its place of business
at P.O. Box 6508 Mesa, Az 85216-6508.
2. Defendant, James S Ferguson, is an individual who resides at 111 Parker Street,
Carlisle, Pa 17013.
3. At all times relevant, the Plaintiff was in the business of loaning money on motor
vehicle installment sales contracts, including but not limited to the note signed by Defendant(s),
hereinafter more fully described.
4. On or about April 12, 2005, the Defendant(s) entered into a written Motor Vehicle
Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of
obtaining financing in the amount of $32,525.44 at an annual percentage rate of 11.490%, in
order to purchase a certain motor vehicle, 2005 Ford Explorer more particularly described in the
Contract (hereinafter referred to as the "Vehicle")
marked as Exhibit A.
A copy of the Contract is attached and
5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in
the amount of $627.28 for a period of 72 months until the loan was paid in full all as is more
fully set forth in the Contract.
6. Defendant(s) made monthly payments until November 16, 2005, but has failed to
make any further payments thereafter, and are therefore in default of the Contract.
7. As a result of the default by Defendant(s), and pursuant to the terms of the
Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to
the Defendant(s) giving the Defendant(s) the opportunity to redeem the Vehicle as well as notice
of the sale date. A copy of the notice of repossession and notice of sale date are attached and
marked as Exhibit B.
8. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at
auction with a credit given to the Defendant in the amount of $18800.00, however a balance of
$13602.62 is still due and owing, and a notice of the deficiency balance was sent to the
Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C.
9. Pursuant to the terms of the contract, Defendant is required to pay all amounts due
and owing, including any balance that may remain after the sale of the vehicle, and the
Defendant failed to do so, thereby in default of the Contract.
10. In addition to the foregoing, there is interest due and owing on the deficiency
balance which at this time amounts to $1117.61 and which will continue to accrue.
11. The total amount due and owing- at the time of the filing of this complaint is
$14720.23.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $14720.23, well as any additional interest and costs that may accrue and such
other and further relief as this Court may deem equitable and just.
VERIFICATION
I, JOANN NEEDLEMAN, ESQUIRE, verify that I am the Attorney of record for
Plaintiff, FORD MOTOR CREDIT COMPANY, and duly authorized to make this verification
on its behalf, that statements made in the foregoing Complaint are true and correct to the best of
my knowledge, information and belief.
These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to
unsworn falsification to authorities.
DATED: March 1, 2007
,PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT nATE 04/ ta/ms
BuvarlaDd Co-BtNODSlama and Address (including County and Zip Code) CREDkTDIt_r9dlal I. and Address)
15 E. HARMON DR. QP{2 1 4 2Up5 170 YORK RD. 4
CARLISLE, PR 17013 CARLISLE, PA 17013 X `era
You, the Buyer (and CoBuyar, If my), may buy the vehlcle Aeaodbed below for core or onendll. The'Cmah Price shown below is the cerh price of the Yahick. Into
Tobt Sels Price' shown below to the crooh prim. By sgnirg this contract, you choose to buy co aeon under the agreements an the front and beck a tnte comrooL
NEW , 2005 FORD I ??rW w..I I 1FMZU74WS5UA40945 I l]Aoommardel O Aylowturet
ITradrir 1995 OLDS CIERA s 6701.00 $ N/A l"UHANGE
Year and Make Gnus Allowance Amount Devg YOU MAY OBTAIN VEHICLE INSURAN
ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE.
T. Cash Price ._...................... 42300.00 (1)
2. Down Payment $000, 00
Third Party Rebate Assigned to Creditor.._ ......................... $
Cash Down Paymem ............... ..... ., $?
Trade-in 95 OLDS $ 67fA1.33......5.... _....... fl%q' $-.673-1 $0
Y_. Mar. eves A11- M e.kv
Total Down Payment., ............. . ...... . . ...................................... $ 11701.00 (2)
3. Unpaid Balance of Cash Price (t minus 2)......... ............ ............. $ (3)
4. Amounts paid on your behalf (Seater may be retaining a portion of these amounts)
To Insurance Companies for
Credit LUs Insurance (for tens of contract)..,,.,,.....„,„....... $ N/A
Credit Disability Insurance (for term of contract) .......___. $- N/A
[Term -Months (Estimate $ N/A
To Public Officials (i) for ficense ($ 6, 00? title (S ), 8
registration ($ Nli6 5 $0pper/ '
(it) for filing fees $ 1840.94 1874.44
(iii) for taxes (not in Cash Price) $ $?A
To for $_ M
To for
To FAMIL FORD -for NOTARY 6 DOE Tm-
$
To for $__ R7A
Total .»_........ ............... _..._........._....._.._......_._....._.._..._.............b2 .44 (4)
5. Amount Financed 3 plus 4 _._.._...._..._...._............... 4
FEDERAL TRUTH4N-LENDING DISCLOSURES
ANNUAL FINANCE Amount Total of Total Sale
PERCENTAGE CHARGE Financed Payments. Price
RATE The dons, sebum The amount of The amount The total cast
The cost of your 0e Credit we Credo provided b you will have of your purchase on
credit as a yeay rate we you you or on your paid when you Cre61,
behaf he" made,all maludng your
scheduled downpeymem
paymerar or $ 11 7011 - 0e
err 40% $ 32524 114--A51114.
Payment Schedule Number of Amount of Each Wlgrt Payments
?)firyaads Payment am do
Your payment schedule --'•^+ $--C. 28 (mOMhN starting)
we la t fatal $__ coo,
Pnpayesnt: If you pay off your debt pray, you will not have to pay a penalty.
Lots PWmWg' You must pay a by charge on the portion of each payment receNed more
Stan 10 days Idea. The charge Is 2 percent of she sate amount or $50.00 whichever is less.
SaataNy Interest You we giving a saaaiy Intered in fora vehicle being purchased.
contract, Please we Via quire contract for on
re nonpayment
dGMA the right to your debt in kill of socuilty tiled d,
repayment of your debt in fill before the e scheduled data. and
'Prepriment penalty.
Ifyou deMmeMyearCWMdoMoo ra,youa Wbaa the vetldafMlyouorennatio g orderelleatract
as wait as brh Dab Sold woo out an ore w "ad mare w med. rm,ked mr taro vM,ida.
NON-MODIFICATION DISCLOSURE
Any Chpange in time txxtbact nest be in wdnng and Signed by you and tie Creditor.
M_ X
&GNB Y
At?
YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO BE BOUND
BY THE ARBITRATION PROVISION ON THE REVERSE SIDE OF THIS
CONTRACT.
- NOTI TO-BUYER_
Do not sign this contract in blank.
You are entitled to an exact copy of the contract you sign.
Keep it to protect your legal rights,
Buyer (and Co-Buyer) acknowledge that (1) before sianina this
contract Buyer and Co-Buyer) received and revitiWBG a we
and pletely Nlied M copy of this contract and (IQ at the
time of sji in this contract Buyer (and Co-Buyer) re c-qTv-Q1
agWancicompliKeiyfiii in copy Of this contract
Bu SIGNS Yam sore
By signing below. tine so naaapb this N Aeaferw 4?trued In a ""raft
sslgmnens aaaoned to tiler trorlhad, the N C dtf??' 4
®"? err Tab
nmwsum tPra+de awx+.gNcaret sea eAClt FOR AoomoNAL AUFMOWNTS
PA
ORIGINAL
YOU ARE NOT REQUIRED TO OB
CREDIT LIFE, CREDIT DISABILITY
OTHER OPTIONAL INSURANCE.
CONTRACT WILL NOT INCLUDE T
UNLESS YOU SIGN AND AGREE TO
THE PREMIUM.
THIS CONTRACT DOES NOT INC[
LIABILITY INSURANCE COVERAGE
BODILY INJURY AND PROPI
DAMAGE CAUSED TO OTHERS.
O Credit Life
Insurer
$ N/A
Premium Insured(s)
Signature
Credit
? Disabi ty
Insurer
$ N/A
Premium Insured
Signature
O
Other Optionallnsuranoe Tenn
S N/A
Insurer Premium
i nor re
Cade UN and credit pliability Insurance we
for the term of the eon"M "Am amount and
coveregpa ere .!,curt, In e notice or egresmem
given to Yon today.
You must Imwa the VOW& lf a charge Is
shoran below the creditor will try b terry the
coverages aecked fall the term eleven.
Bas will be based an the cash value of
Ilse flmae of the Amo of policy. lone not more man
? Ceetpeherrowe ? SAkDeducable
Coaairn
? Fire- TM4Cotnbkrai Additional Coverage
? Toweg and Labor
? Tear Months (Estimate)
Premium $ ---NOR--
?DOM cancellation waiver Addendum (Oplloneg
N On box lsdirt W you have pwdesud a date
",Cocoon wake. Pacts" of sus coverage is
:O=M-4. t ram gWrod stem ands. The ante
al ere tote ratruhelan waiver am rat
fast in •a atbdad Addendum welch U tnmry ad
nil 66 crdmCL ThS ?w for as debt tanaaSatlorh
weer beat brat on ties wanner in the
senlrasm
of Amount Financed undw Salt 4.
Buyer
Program No.
QUESTIONS?
OR
PLEASE CALL US AT 1-800.727.7000
or
Visit us at www.foMcredlLcom
owl
EXHIBIT
••.PRN"'
Ford Motor Credit Company
P.O. Box 3076
COLUMBIA, MD 21045-6076
(800) 677-0730
P04J8100200010
JAMES S. FERGUSON
111 TARKER STREET
CARLISLE PA 17013
Date of Repossession 0404-2006
Date of Notice
04-06-2006 Date of Contract
0412-2005
Account Number: 036676046
Buyer JAMES S. FERGUSON
Cobuyer
DESCRIPTION OF PROPERTY
Year
2005 Make
FORD ?x New
? Used
Vehicle Identification Number:
IFMZU74W55UA40945
Model
EXPLR Body
74DR -
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
PRIVATE SALE: We will sell the property described above at
private sale sometime after 15 days from the Date or Notice
shown above unless redeemed by you prior to such sale.
? PUBLIC SALE: We will sell the prop" described above at pubic
sale to the highest bidder on the date below (or any adoumment
date). The sate will be held as follows:
Date of Sate Time of Sale Plaice of Sale
You may attend the sate and bring bidders if you want.
The money that we get from the sale (after paying our costs,
including reasonable attorney's fees and legal expenses if
permitted by law) will reduce the amount you owe. If we get
less money than you owe, you will still owe us the difference. If
we get more money than you owe, you will get the extra money
unless we must pay it to someone else.
You can get the property back at any time before we sell it by
paying us the full amount you owe (not just the past due
payments), including our expenses. See How To Get Your
Property Back for an itemization of amount owing. To learn the
exact amount you must pay, call us at the telephone number
above.
If you need more information about the sale call us at the
telephone number above, or write us at the address above.
If you want us to explain to you in writing how we have figured
the amount that you owe us, you may call us at the telephone
number above, or write us at the address above and request a
written explanation.
We are sending this notice to the following people who have an
interest in the property described above or who owe money unde
your agreement: 1) The buyer and any cobuyer named above;
2) Any dealer/original creditor named below; 3) If there are other
people, they are named on an attachment sent with this notice.
NOTICE OF REPOSSESSION
The property is presently stored at: BEN RECOVERY BEN
REM WAY ETTER9 PA
HOW TO GET YOUR PROPERTY BACK
To get your property back, pay us this amount by certified check or
money order before the vehicle is sold.
Unpaid Balance $ 31,643.92
Plus Costs: Repo Expenses $ 305.00
$
Pius Late Charges $ 50.20
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 32,079.12
(Plus expenses incurred if default at the time of repossession exceeded
16 days and less rebate received after the date of this notice.)
Your properly worm be sold until 16 days after the date of this notice at
the EARLIEST. After that you can still get it back any time before its
actually sold.
If you do, we'll have no further claim on It But the longer you wait, the
more costs including repairs) you may have to pay.
If you have any questions about this, please call us.
- - - The propertyFas-been (or will be) returned to:
(dealer/original credhor)
Under our agreement with your dealer/original creditor, the dealerWglnal creditor is to sell the property and pay you any money left over. If you rnve money
after the sale, you wit pay It to the dealerloriginal creditor.
PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by
contacting this office. Thereafter, the personal property shall be disposed of accordingly.
Creditor has assigned to its qualified intermediary (QI Exchange, LLC) its rights (but not its obligations) with reaped to the sale of each vehicle listed above.
PAYMENTS: AN payments to us must be by certified check or money order.
MILEAGE DISCLOSURE: If you are aware that the mileage refleoted on the vehicle's odometer is not accurate for any reason, please contact us so that we
can accurately report the vehicle's nrleage.
INSURANCE RIGHTS: If you dont want to get your property back, tail the insurance company or the dew/original creditor to make sure that any insurance
has been cancelled. You have a right to get credit for all premium refunds.
JESSICA A. SNYDER
FFNA 1IOU-37 Jan 02 PwAws WWOM may N(r be used. CUSTOMERICUSTOMER FILE
Ptlnmd In U.S.A.
EXHIBIT
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Name and Address pf $gD ..
38120 Amrhein
Livonia, MI 48150
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AM-031759317 CATHERINE M. SMALL ?QQS Q
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SAMUEL S
R. PHILLIPS 7005 2570 OQQQ 9962 6916 3646 PHILADELPHIA GENESEE DRIVE
6943 MIDDLE RD PA 19154 QQQQ
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RACINE WI 53402 00405/20569793 9960 69Sy
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-0226170617888661 1 70[15 2570 OO?Q 9962 6923 6416OVERBROOKAVE QS?Q
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CARLENE S. MORRIS PHILA PA 19151
9132W DIXON ST APT 104 ----- ---- - ?_4 U0405/20569794
MILWAUKEE W153214 1362 - ---- - -- V_ A-038878046 Q 99b? 6962
AMES S. FERGUSON
111TARKER STREET C G ,Q 41
-- - CARLISLE PA 17013 dr a m
BA-02967669790 2S?0
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BO2ss76640 Q 0000 9962 6930 -- - OQOD 4968
DEAN DARWIN CAPILI -_ 72
562161 ST ST # 2L
MASPETH NY 11378-2427 -- - _ _ I I ` -
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U0406120569791 48150 ed
BA-038926110
NICOLAS BALESTIERI 700$ 2570 0000 9962 6947 O taf
2406 DAIRY LANE •. '
NORRISTOWN PA 19403
Tqy Nmtleerd Pleop Toro)
RataAed .0d M M Pest PVeae tMaca Putrueter. Per (Nameof,ece{vJ,rg - _ oyes) I ?y? - t i
tlslad Ey Sendr r 1 ? i- .. .
I Sea Privacy Act Statement on Reverse
Ford Motor Credit Company
PO BOX 3076
COLUMBIA MD 21045-6076
800 6770730
DATE: 2006-05-17
P04Z6400000040
JAMES S. FERGUSON
111 TARKER STREET
CARLISLE PA 17013
STATEMENT OF SALE
Account Number: 038876046
The following property has been sold.
Year Make Model
2005 FORD EXPLR
Balance owing on your contract
Deduct: Finance Charge Rebate
Balance less Finance Charge Rebate (1 - 2)
Deduct: gross proceeds of the sale
Balance less gross proceeds of the sale (3 - 4)
Add: Expenses of retaking and storing, and
any attorneys' fees allowed by law, and
expenses of reconditioning and selling.
Deduct: Insurance Premium Rebate
Other:
Deficiency-
Vehicle Identification Number:
1 FMZU74W55UA40945
(2) $ 0.00
(4) $ 18,800.00
(6) $ 708.50
(7) $ 0.00
(8) $ 0.00
(1) $ 31,694.12
(3) $ 31.694.12
(5) $ 12,894.12
(9) $ 13602.62
Surplus* (10) $ N/A
The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest
added to your account (debits).
Surplus* or Deficiency"
* If the sale resulted in a surplus, a refund for the difference will be mailed to you.
If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for
payments shown below.
For additional information call or write: Mail deficiency payment to:
Ford Motor Credit Company Ford Motor Credit Company
P.O. BOX 6508 DEPT 194101
MESA ARIZONA 85216-6508 P.O. BOX 55000
(800) 732-2264 DETROIT MI 48255-1941 EXHIBIT
FFNA11990 01/04 Previous ed@ions may NOT be used.
L I C-"'
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-01389 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
FERGUSON JAMES S
SHAWN HARRISON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
FERGUSON JAMES S the
DEFENDANT , at 1738:00 HOURS, on the 15th day of March 2007
at 111 PARKER STREET
CARLISLE, PA 17013 by handing to
JAMES S FERFUSON
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 4.80
Affidavit .00 •
Surcharge 10.00 R. Thomas Kline
00 Do
32.80 03/16/2007
-001 MAURICE & NEEDL MAN
Sworn and Subscibed to I By:
before me this day eputy Sheriff
of A.D.
'0.
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(215) 789-7161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JAMES S FERGUSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 07-1389 CIVIL TERM
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
No answer having been filed in the above Civil Action, kindly enter Judgment in favor of
Plaintiff, and against Defendant, JAMES S FERGUSON in the amount as follows:
Principal Amount $ 13602.62
Interest to Date $ 1528.68
Costs $ 88.30
Attorneys Fees $ 0.00
TOTAL $ 15219.60
MAURICE & NEEDLEMAN, P.C.
BY:
JOA ZEDLEMAN, ESQ.
Atto v for Plaintiff
Date: May 9, 2007
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
1 J ) / Z59-7161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JAMES S FERGUSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 07-1389 CIVIL TERM
AFFIDAVIT OF MAIL SERVICE
STATE OF PENNSYLVANIA
SS.
COUNTY OF PHILADELPHIA
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she is an attorney at law and that on 04/10/2007 she mailed a written Notice of
Intention to File the Praecipe to Defendant, JAMES S FERGUSON, at 11 I PARKER STREET
CARLISLE, PA 17013 by regular and certified mail, article nos. 7155 5474 4100 4606 2711.
Copies of the receipts evidencing said mailing are attached hereto.
A copy of the signed green card evidencing receipt of said mailing is attached hereto as
well.
MAURIC8L\NEEDLEMAN, P.C.
SWORN TO AND SUBSCRIBED
before me this 16 day
of 'PI IAy , 200 7.
Notary Public ? dv-'??4
BY:
fEEDLEMAN, ESQ.
for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
Notarial Seat
Agnes hladel??,' Notary public
city a P
CO? Expires Jar, 20,2W9
y
Member, Pennsyiyania Association of Notaries
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(l 1S) /69- /1 61
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JAMES S FERGUSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 07-1389 CIVIL TERM
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on
04/10/2007 to Defendant, JAMES S FERGUSON, against whom judgment is to be entered after
the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A
copy of said Notice dated 04/10/2007, a copy of the receipt for certified mailing to the Defendant
and affidavits of service of said notice are all attached hereto.
MAURICE & NEEDLEMAN, P.C.
BY:
JO
Ati
, ESQ.
Date: May 9, 2007
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(115) /259-71b1
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JAMES S FERGUSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 07-1389 CIVIL TERM
CERTIFICATION OF ADDRESSES
It is hereby certified that the parties have the following addresses:
Plaintiff: FORD MOTOR CREDIT COMPANY
P.O. Box 6058
MESA AZ 85216
Defendant: JAMES S FERGUSON,
I I I PARKER STREET,
CARLISLE, PA 17013
MAURICE & NEEDLEMAN, P.C.
BY:
NEEDLEMAN, ESQ.
for Plaintiff
Date: May 9, 2007
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
151 /?39- / 161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JAMES S FERGUSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 07-1389 CIVIL TERM
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
SS.
COUNTY OF PHILADELPHIA
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she represents the Plaintiff in the above entitled case and that Defendant, JAMES S
FERGUSON, is over 18 years of age; the occupation of Defendant is unknown and to the best of
Plaintiffs knowledge, information and belief, Defendant is not in the military service of the
United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and
Sailors' Civil Relief Act of 1940 and the amendments thereto.
MA
BY:
, P.C.
JEEDLEMAN, ESQ.
for Plaintiff
SWORN TO AND SUBSCRIBED
before me this /? day
of /+ i / , 2007
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Agnes Beiland, Notary Public
City Of Philadelphia, PMladeohia County
My Commiselon Expires Jan. 20, 2009
Member. Pennsylvania Association of Notaries
April 10, 2007
Our File No. 5077
Attorneys at Law
Suite 935, One Penn (enter
1617 John F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.665.1133
fox 215.563.8970
VIA CERTIFIED & REGULAR MAIL
www.mnlowpc.com JAMES S FERGUSON
111 PARKER STREET
Donald S. Maurice CARLISLE, PA ,17013
Member NJ Bar
Board (erlified
(reditors'lights Low
RE: FORD MOTOR CREDIT COMPANY v. JAMES S
American Board of (edification FERGUSON
Joann Needleman CUMBERLAND COUNTY COURT OF COMMON PLEAS,
Member PA d NJ Bar
CASE NO. 07-1389 CIVIL TERM
Thomas B. Dominc:yk
Member NJ, NY & PA Bar
Charlene Taylor
Member r PA But
Dear JAMES S FERGUSON:
Enclosed please find a ten (10) day notice of default which is self-
explanatory. This is being served upon you due to your failure to respond to
Plaintiffs Complaint served upon you on 03/15/2007. Unless an answer to
Plaintiffs Complaint is filed with the Court within ten (10) days from the date of
this notice, a default judgment may be entered against you.
If you would like to discuss a resolution to this matter, please call our office at
908-237-4571 and ask for Kim Crosby.
Thank you for your prompt attention to this matter.
Ver} truly yours,
ICE & NEEDLEMAN, P.C.
J e eman, sq,
/jm
ARTICLE NUMBER
7155 5474 4100 4606 2711
ARTICLE ADDRESS TO:
JAMES S FERGUSON
111 PARKER ST
CARLISLE PA 17013-2821
FEES
Postage per piece
Certified Fee
RetLrn Receipt Fee
Total Postage & Fees:
$0.40
2.40 IMPT TO COLLECT A
1.85 DINED WILL BE USED
$4•64 DEBT COLLECTOR
Postmark
Here
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
15) 789-/155
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JAMES S FERGUSON
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 07-1389 CIVIL TERM
IMPORTANT NOTICE
TO: JAMES S FERGUSON DATE: April 10, 2007
111 PARKER STREET
CARLISLE, PA 17013
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
, P.C.
BY
N NEEDLEMAN, ESQ
Attorney for Plaintiff
MAU12.4015& NEEDLEMAN, P.C.
935 One Penn Center
Philadelphia, PA 19103
i CER
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A. sly tors: (? Addnasse or? Agent)
aceiv y: (PUsse Print cwdy)
C. DaI4 of Delivery
D. Addressee's Address (M rant Fom Adds Used by Swxw.)
Secondary Address i Sulu i Apt. i Floor (Pissss Print CNMy)
Delivery Address
City State ZIP + 4 Code
7155 5474 4100 4606 2711
RETURN RECEIPT REQUESTED
AAlole Address" To:
I?ttllirtrlllttrttrlirtllrrtlrlltrittrirlttrllrr,Ilrtrilr,ifrl
JAMES S FERGUSON
111 PARKER ST
CARLISLE PA 17013-2821
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MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(215) 189-110 1
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JAMES S FERGUSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 07-1389 CIVIL TERM
(X) Notice is hereby given that a judgment in the above-captioned matter has
been entered against you in the amount of $15219.60 on p, ZOC)7
(X) A copy of all documents filed with the Prothonotary in support of the
within judgment is enclosed.
// pl'"L
Pro t
by:
If you have any questions regarding this matter, please contact the filing party:
Name: Joann Needleman, Esquire
Address: Suite 935, One Penn Center at Suburban Station
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Telephone No.: 215-789-7161
(This Notice is given in accordance with Pa.R.C.P. §236)