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Home My WebLink About98-04297 i ! ~'I ~'I ell .....; qi \ I i21 .1 c1! I 1--1 -- 'I ~I V" '\ ~ '\ ~ \ ~ \, \ -c( ~ Lt , I I I , i ,/ .' _,,1' " " J:'" , I I I I ,I \. ~I I ~I '.. I 01 ~, ~I "'JI ~I I - I ~I (j--' 't';:) ~, ,', I I;, CIVIL ACTION 1. Plaintiff, Ford Motor Credit Company, is a corporation duly organized and existing under the laws of the State of Delaware, and authorized to do business in the Commonwealth of Pennsylvania, with offices located at One American Road, Dearborn, Michigan 48122. 2. Defendant (s) Dennis L. Dick, Jr. is/are individual (s) residing at the addressees) contained in the caption of the case. 3. On or about July 21, 1995, Defendant(s) (buyer) entered into a written Automobile Instalment Contract (hereinafter called the Contract) to purchase a "Vehicle" from a dealer (creditor) as fully described in said Contract, said purchase to be made according to the terms, prices and conditions contained within the aforesaid Contract, a true and correct copy of said Contract being attached hereto, made a part hereof, and marked Exhibit "A". 4. "Creditor" subsequently assigned the aforesaid Contract to Plaintiff, Ford Motor Credit Company. 5. Subsequently, Defendant (s) did default upon the aforesaid Contract by failing to make timely installment payment to Plaintiff and in accordance therewith the entire remaining balance becanle due and payable immediately. 6. The aforesaid Contract further provides that in the event of default, Plaintiff may repossess the "vehicle" and sell same in accord with the terms of the aforesaid Contract. 7. The aforesaid Contract further provides that buyer agrees to pay lawyers fees and legal costs per.mitted by law. 8. As a consequence of the foregoing, there is currently due and owing to Plaintiff by the Defendant(s) the following sums: i i , BALANCE WHEN REPOSSESSED LESS: Sale Proceeds Physical Damage Insurance Premium Refund ESP Refund Accident & Health Insurance Premium Refund Finance Charge Refund ADD: Earned But Unpaid Credit Charges Unpaid Late Charges Repossession Expense Balance Owing Customer Payments Received after establishment of Deficiency SUBTOTAL Interest plus Attorney's fees of 20% TOTAL DUE $14,443.85 8,300.00 .00 177.00 .00 .00 .00 26.91 198.50 $ 6,192.26 4.302.26 $ 1,890.00 264.60 430.92 $ 2,585.52 9. Despite repeated demand by Plaintiff, Defendant(s) has/have failed and refused to pay the aforesaid sum. CORRECTION / Previous Image. Refilmed to Correct. ' i ( Possible Error, '; .( , ,:') ~' STATE OF MICHIGAN SS COUNTY OF WAYNE AFFIDA VIT Barbara Sears being duly sworn according to law, deposes and says that she is Administrative Supervisor for Ford Motor Credit Company, and that she is duly authorized to take this affidavit on behalf of Ford Motor Credit Company, and that the facts contained in the attached pleading are true and correct to the best of her information, knowledge and belief, ~Jc€tA/4 /' L1r AJr/r Barbara Sears Administrative Supervisor Sworn to and Subscribed before me this 14th day of Ju 1y ,19 98 ~frbY~ otary P blic g{ptmy~~Cmmty MidUgan "ry c..~n ~i"" July 2.9, WI , , ,. j ,- L IN THE COURT or COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Oft1G1NAL CIVIL DIVISION FORD MOTOR CREDIT COMPANY Ottrl'!;!NAL vs. NUMBER: 98-4297 CIVIL DENNIS L. DICK. JR, PRAECIPE FOR DErAUL T JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against the Defendant(s) Dennis L. Dick, Jr, for failure to answer Plaintiffs Complaint, endorsed with twenty (20) day notice to plead, served upon Defendant(s) on July 27, 1998 and assess damages as follows: Unpaid Balance $ 1,890,00 Plus Interest 264,60 Late Charges ,00 Plus Attorney's Fees 430,92 Less Credits, if any ,00 TOT AL DUE: $ 2,585,52 Pursuant to PaR,C,P, 237,1, I hereby certify that notice to file this Praecipe was mailed to the above named Defendant(s) and the Attorney of Record (if applicable) on August 20, 1998 and copy/copies of same is/are attached hereto, \ 'I I I I \ I I ,~~".! "i ARTHUR LASHIN, ESQ IRE #23425 Attorney For Plaintiff HAYT, HAYT & LANDAU 400 Market Street 6th Floor Philadelphia, Pennsylvania 19106 (215) 928.1400 i 1 I 1 I , ! I , I '-' ,. COUR1' OF COMMON PLEAS AFFIDAVIT OF NON-MILI'rARY SERVICE FORD MOTOR CREDIT COflPANY VS. DENNIS L. DICK, JR, STATE OF PENNSYLVANIA SS COUNTY OF ~HILAD~LPHIA Arthur Lashin ,being duly sworn according to Law, deposes and says ,thauhe represents the Plaintiff in the above entitled case, that he is authorized to make this Affidavit on behalf of the Plaintiff; and that the above named Defendant (s) is (are) 18+ years of age; the address of Defendant(s) is 50 Fairview Street, Carlisle, Pennsylvania 17013 Occupation of Defendant(s) is unknown; and the Defendant(s) is (are) not in the Military Service of the United States, nor any State or Territory thereof or its Allies as defined in the Soldiers' and the Sailors' Civil Relief Act of 1940 and' amendments thereto, I HAYT, IlAYT AND LANDAU ATTORNEY FOR PLAINTIFF Prothonotary Sworn to and subscribed before me this 31st day of August ~ 19 98 A.D., Notary Public My commission expires: , Notorlal Seot ShllrI Deana Outen, Notary PullIlc Ph!ladelpl1la, Philadejphla County My Colmris&Ion EJqllres June 27, 2OQ2 Mambel, PIlMsyIVanla _"'" 01 NoIarlll HAYT, HAYT & LANDAU BY: IDENT~mf.}Jb~ASHlN, ESQUIRE SIXTH FLOOR 23425 400 MARKET STREET PHILADELPHIA. PA 19106,2509 (215) 928,1400 AiTORNEY FOR PLAINTIFF DATE: AUGUST 20, 1998 CUMBERLAND COUNTY COUR T OF COMMON PLEAS CIVIL DIVISION FORD HOTOR ell 1m I T eOft!' ANY One Americnn Rond Dearborn, Hichlgnn 48122 TERM, vs. DENNIS L, DICK, .JR. 50 Fairview Street Carlisle, Pennsylvania 17013 No, 98-4297 CIVIL NOTICE OF INTENTION TO TAKE DEFAULT PURSUANT TO PA.R,C.P. 237.1 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 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: Court Administrator Cumberland County Courthouse Carlise, PA 17013 (717) 240-6200 ARTHUR LASHIN, ESQUIRE, #23425 '~' ~ .: J ;'1 ~ ~ ..'") ~ :-~ .-, '-:'1 J ~ I c..i , , ': ~.) ~ " ~ . ' --'I .'?j \ . . ._:C) ~ .-., i"".~ ,lTI ~ ':..J \) , ~'-I .. 'C'" CJ \) =< (n :~~ ~ "i:., ~ ~ .1 Three Hundred Dollars ($300,00) II month pllYlIble on the 20th dll)' of elleh month commencing September 211 1998, until the aforesaid judgment blllllnce is paid. 3. That in the event of default upon the aforesaid payment schedule by Defendant, Plaintiff may immediately, without further notice to Defendant, proceed with execution upon the aforesaid judgment for the full amount as entered in favor of Plaintiff and against Defendant, less any sums received by Plaintiff from the date of entry of judgment. 4. That upon receipt of payment in full of the aforesaid judgment, Plaintiff, through its attorney, shall have the aforesaid judgment marked satisfied, It is hereby represented by counsel to this Stipulation that they execute the same under and pursuant to the instructions and authorizations of their respective clients, Date: By: ARTHUR LASHIN, ESQUIRE, #23425 Attorney for Plaintiff Hayt, Hayt & Landau 400 Market Street 6th Floor Philadelphia, PA 19106 (215) 928-1400 Date: By C2~w- JA~ONES, ES - ' Attorney for Defendant 7 Irvine Row Carlisle, PA 17013-3019 (717) 240-0296 '" fx.. S? ~ Pv \ ~ 'C'- ~ ,-<:\ r:::- ~ /'<. ~ ~N ~ 'f- 9Z =t-t ~ \J ~ d: \) t , ~ ~ ~ ( ~:. .. ':,1 , , ',"t "I) ) -I '1) :, ,\.) , c: '::; h, , () , " :;~'! , , ...) ,,) 'I " " , .J ;,-2 -< (;'l ~'i..-I -< 0 \.0 0 f. m c ::0 "1'\' ;::" '- :;:I T' -o<)j C iii~' ~ ("111'n r- 7.:.:0 r;l:. 0 ;?C" l" "~e3 .r;;- :0 ~ ~ ~5.-. 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