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HomeMy WebLinkAbout07-1610ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED 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 (215) 789-7161 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. CARRI E REED 9 Village Ct Mechanicsburg, Pa 17050-9161 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. Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. (??' ! Q CIVIL ACTION COMPLAINT AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene venue (20) dias de plazo at partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o can on 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 suya sin previo aviso o notificacion. Adernas, 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 para usted. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAIO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 11 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 ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff (21J} /Zsg-/101 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. a -7?1G 10 Plaintiff, V. CARRI E REED 9 Village Ct Mechanicsburg, Pa 17050-9161 Defendant(s). 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, Carri E Reed, is an individual who resides at 9 Village Ct Mechanicsburg, Pa 17050-9161. 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 February 8, 2003, 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 $10,558.10 at an annual percentage rate of 18.000%, in order to purchase a certain motor vehicle, 2000 Pontiac Grand Am more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A. 5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $268.11 for a period of 60 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 February 24, 2006, 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 $4100.00, however a balance of $4407.22 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 $656.37 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $5063.59. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $5063.59, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. C ARLENE A. TAY O , ESQUIRE Attorney for Plaintiff VERIFICATION I, CHARLENE A. TAYLOR, 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. BY CHARLENE A. TAYLO ESQUIRE DATED: March 13, 2007 CmaaR M VEHIC.EB: Th.16W shown in tin aeons ear tar I" MIMM OWN-0 ma odes OUESTIONS? purdrsa dt a Oss• ml ulw wdi al to MM ISSAW Rw L I It YYid. yw Pua9rad Ms. gnla 'rodesMN.l?*db@Wlb4g -a+d# W"0Wd a Ua wa4t Wit%ftM? rwlu Wbandgsods ilirtl?n rY«0^^badwldoa. Ford NOWMODIRCAMON DISCI OSURE Credit Any CIUW In d* wmW must be In vw" m10 Wrwd by you and R» Cmdbr. BUYER ( CO-0UYER: Do not sign this contract in thank. YOU are entitled to an exact copy of the contract you sign. PLEASE CALL US AT 1-800.727-7000 Keep It t Ngal,}iglts- ( surm alma (00) BUYER MNS Buyer aclmQwied?a of a ? and completely filled in copy of this contract at the time of signing. N.r ?a a11..arllf..t. a RNs COIIKIOC tla 801.r a BRANCH COPY w n®lr oa as IF..nwy aaw..w xer a coal SEE BACK FOR ADDITIONAL AOREEaE -- ---------- ------------------- Ford Motor Credit Company Pr Awaxi-Payment Plan Enrollment Authorization a?rnMpar wwrc 4?aaWwaw _WWWamimpift CalaYyrW OawlwYlwl0a0mY1.Yw0 mnawrayl ..p 1: Oa. pv na.. p?a??wr? ..VYOtal Vam nemiw Orwf.Mnr - an0y r saw. M at aye k lA. ly.baw sWa aaMr w.l AP Oe0 aW M NilnOw P1'^.a MaalwhA00 bin .OwYPO.llybn .y1On1a 100alomyl0rn.eaY.gM1YMr _ .aPa l?Mr, aOq .10.k 11rOMMOeeplt Fa. EXHIBIT .arcrual+aly?.aw.elr s.awalalu.y.,ywwoyr•wa... wlaa.ayrayyea.hw.a : aq..a a.y s..a..ws.. ? ,ya. ssewaswl sear ...s:lsal lws. wwad x.+.r w?.. . ? •+ ?? / ? ry?yy a.ja ? coal 6 w enslwFa .alto b /epwY 01I?A10ar1111w1 afaVl./wYaWW w Ou. i / ? Yal is ?A.Om aOa ryy ?y r.e ra Plz a/III y1u IclOa Ow.00,118 alKlila / ' ? \ OuWtii FGt® .IOa aMZ 0aY10101-1000 Yaw Faa y0al0ayH nPFOaYdF0 w11r 14Y/r ulllyw plr•nlefld?l'll•l•• as1•ww. cwrlcser FMS•ala.alraaY DATE 02/08/03 PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT Buyer (and GF Bup1 gRwd Addrau (Including Counly NO ZiP cage) CREDITOR (S ?p•IrgNy'n wdd Addrrtss) ? ` ?i,,4 (?• ? ? ^? CAR )IR *?} C E ' PA 11050 ?EMgYNE@KETOS?RE Ail 17043-1654 • E`If A U ... - -- -_.,. ,?...........• .r,,..,.. w.,a. w ?.a arw a ms vaaat. n» •••PRN"' Ford Motor Credit Company P.O. Box 3076 COLUMBIA, MD 21045.6076 (800) 677-0730 P04C71,100300011 CARRI E. REED 9 VILLAGE CT MECHANICSBURG PA 17650-9161 Date of Repossession 03.16.2006 Date of Notice 03-17-2006 Date of Contract 02-013-2003 Account Number: 034004699 Buyer CARRI E. REED Cobuyer DESCRIPTION OF PROPERTY Year 2000 Make PONT ? New Used Vehicle Identification Number: 1G2NF52T1YM712065 Model GRNDA Body NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. ?x PRIVATE SALE: We wig sell the property described above at private sale sometime after 16 days from the Date of Notice shown above unless redeemed by you prior to such sale. ? PUBLIC SALE: We will sell the property described above at public sale to the highest bidder on the date below (or any adjournment date). The sale will be held as follows: Date of Sale Time of Sale Placeof Sale You may attend the sale and bring bidders if you want. NOTICE OF REPOSSESSION 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. The property is presently stored at: BEN RECOVERY BEN ifECOVEMY ETTER APAP _ 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 $ 8,113.93 Plus Costs: Repo Expenses $ 200.00 $ Plus Late Charges $ 3439 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 8,348.72 (Plus expenses incurred if default at the time of repossession exceeded 16 days and less rebate received after the date of this notice.) Your property won't 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 it's actually sdd. If you do, well have no further claim on it But the longer you wait the more costa (including repairs) you may have to pay. If you have any questions about this. please call us. ? The property has been (or will be) returned to: (dealer/original creditor) Under our agreement with your dealer/original creditor, the dealer/orginat creditor is to sell the property and pay you any money left over. If you owe money after the sale, you will pay it to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 80 days or, in accordance with state law, by contacting this office. Thereafter, the personal property shell be disposed of accordingly. ? Creditor has assigned to its qualified intermediary (01 Exchange, LLC) its rights (tut not its obligations) with respect to the sale of each vehicle listed above PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer Is not accurate for any, reason, please contact us so that we can accurately report the vehicle's mileage. INSURANCE RIGHTS: If you don't want to get your property back, cal the insurance company or the dealer/original creditor to make sure that any insurance has been caneeged. You have a right to get credit for all premium refunds. JESSICA A. SNYDER FFNA 11988-37 Jan 02 Previous editions may NOT be used. CUSTOMERICUSTOMER FILE POW In U.S.A. EXHIBIT I B E 1. name and AddreslIgNSO t 38120 Amrhein Livonia, Mi 48150 Arrole Number i. I i I • ck type I or service: Affix Stamp Here arefred 0 ReeordedDeewn (Internstionait (ftsuedasa aerrRGf?amerha, coo ? Reabterea orltrtrddJronN .: 09eavery Confirmation O Return Recelpt for M*mSwd» cvpJerdMJs>? - 0 Express Mail 0 9lgneoxa Confirmation Pbslmerh airs( . Immured Dek Of Addreeaee O*m Street, Dry, 9Aa, d ZJPCbde) p Actual Value Inaxad Due Sander DC SC SII RD RR tier,dlY,r7um. a w.N. @-, n , ,...... r C. Fee Fee FN PN Fee U0316/20567730 CR-031520197 U0316/20567726 TOMMIE K. CAIN 7QOb OZ00 AM-037973345 7006 0111[1 0007 2777 7713 780 THE HIDEOUT OpQ7 2777 7751 MELVIN M. KAQUATOSH LAKEARIEL PA 18436 PO BOX 237 NEOPIT WI 54130 _ U0316/20567731 t U0316120567727 BA-034238513 NICOLE CLEMENS 1332 CORRY AVE BENSALEM PA 19020 U0316l20567728 MA-039829545 ----- -' DJ JUDY '152 WYOMING AVE p •t OLA PA 17025 7006 0100 0007 2777 7720 _ f,UO 8/20s67732 34004699 ?_- ___ RRI E. REED 9 VILLAGE CT ` MECHANICSBURG F BA-034155149 7006 0100 0007 2777 7737 GARY J. PHIPPS -- 1310 STACKHOUSE MILL RD -?--- NEWTOWNSQUARE PA 19073 --- - -- ----- -- U0316/20567729 --? --- BA-039784240 -? !-^ EVELYNJ. MERRICK 7006 0100 0007 2777 7744 410 S 54TH ST PHILADELPHIA PA 18143 -- Taal N~n t peas 'Received a poet Olflee 7006 0100 0007 2777 ?768 ? m 7006 0100 0007 e? 2777 7775 }•. 'A 17050-9161 00, See Privacy Act Statement on Reverse PS Form 3877• Febn&y 2002 (Page 1 df2) Complete by TVP&Wrker. Ink, or Ball Paint Pen t ._ . • V':'P.'t .1? o .v'- :k ::?i it?'?li?'? iiJ. ?'s ??i '?ti11^-. f . :•,.:? -- • ? li, tin ? :,,8 .r •.7?•, 9' Sgy:i :i', ? i'; ? i i ii•.:ii.i. iaiy:?i' `•i {? ' ? ' ?: :It?r:i,?,?, S r x'ti uk" -`: r-•1 i(,..''.1 ?y.?•?-: ,n: ., ;ii.'' ,.Fi:: :.a! . Vtif.7•$.i• %?t?r' ?lz' ;I..-?: ?;??al.• .i ?:i 1i? e?; .i..^ "t ?'1'? ?$•?''. +? 'r'" .. .J.f;., .•t" 'vii'i ?., ,3 11 : 't•G : S.' 'aal .f? .k-i.•.i:' ? :iii::; i ?f •.' .?• ,YS'?fi;? ? ?; :? . ,l4.,.j ? Is iir • ..t .i:.?; 'i.t, i ?.i! .•;ili3• •. r 4?,?•: N' ? . U..Y,'• ?,?+'..r•f ,:jc:.'r.rt {,:' ?? ' lr,[{[{. '?i i'{''• . ?J.7"F' a.:Y • ?e Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 21045-6076 800 6770730 DATE: 2006-04-26 P04QWL00000026 CARRI E. REED 9 VILLAGE CT - MECHANICSBURG PA 17050-9161 STATEMENT OF SALE Account Number: 034004699 The following property has been sold. Year Make Model Vehicle Identification Number: 2000 PONT GRNDA 1G2NF52T1YM712065 Balance owing on your contract (1) $ 8,148.72 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 8148.72 Deduct: gross proceeds of the sale (4) $ 4,100.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 4,048.72 Add: Expenses of retaking and storing, and (6) $ 358.50 any attomeys' fees allowed by law, and expenses of reconditioning and selling. (7) $ 0.00 Deduct: Insurance Premium Rebate (8) $ 0.00 Other. (9) $ 4407.22 Deficiency*" (10) $ N/A Surplus* 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 FFNA11990 01104 Previous editions may NOT be used. EXHIBIT Ov 0. 09 act m U i ? O ? e Q rrSA ?O A$ P 111 O 13 ?m fi? m Z b r o? W 111M ica M? c r xrr rim i? NZ -- to -- N p9 m m ° of ?l M ro m" 41- ru o o ,4 0 Q Z N Ag, m o -- V ---` g J. m c T N a o F --JJv m r•• "a z V. N ? zz a 114 zz z 0 m 0 o " a m b n a $ Z m v c 0 w b ID) z z o 0 ? El x x ? x 19 K A X ?x x ? a •? x g max D NEE) o g!, z V 20 V ? M CJ1 to 9 N 4 v NNr `P Lq ro a r J 0. 10 I o? 0 o? w I? w ro ro N S? w a co r a w o- Q ? 1 \ V w•_ v t'z t' n? :Cs=. C7 CO co GO O n? ?rn 5j n SHERIFF'S RETURN - REGULAR CASE NO: 2007-01610 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS REED CARRI E TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REED CARRIE E the DEFENDANT , at 2025:00 HOURS, on the 27th day of March 2007 at 9 VILLAGE COURT MECHANICSBURG, PA 17050 CARRIE E REED by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.48 Affidavit .00 Surcharge 10.00 .00 40.48 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/28/2007 MAURICE & NEEDLEMAN By- Dep/ty' Sheri A.D. 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. CARRI E REED Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-1610 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, CARRI E REED in the amount as follows: Principal Amount $ 4407.22 Interest to Date $ 836.77 Costs $ 74.98 Attorneys Fees $ 0.00 TOTAL $ 5318.97 MAURICE & NEEDLEMAN, P.C. BY: JOA IVEOLEMAN, ESQ. Atto e for Plaintiff Date: May 16, 2007 ? ? 0 0 f 0 -1 . 0o a 4 ` L CC) 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 1J1 /89-/161 FORD MOTOR CREDIT COMPANY Plaintiff V. CARRI E REED Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-1610 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 04/24/2007 she mailed a written Notice of Intention to File the Praecipe to Defendant, CARRI E REED, at 9 VILLAGE CT , MECHANICSBURG, PA 17050-9161 by certified mail, article nos. 7155 5474 4100 4606 3251. 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. , P.C. SWORN TO AND SUBSCRIBED before me this /fday of v? ' 2001. Notary/ ( VubUliWc C,OM ONWEALTH OF PENNSYLY A NOTARIAL SEAL MICHAEL B. GERSTEIN, Notary Public Cfty of PhBadelphia, PNIa. County Cq rwasion Expires February 28,M. BY: fEEDLEMAN, ESQ. for Plaintiff (? N ?lJ `^) " 3l L.. .__s ?? t...?..,. ? -r; (?'t Z r,=. ? _" i'•.3 _ r^ 'i 7, ?, , ?? L _ 1 ?? ?, i. -,. N •. ,:?, - "sJ _ ?; ""`^ 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) -/89--/161 FORD MOTOR CREDIT COMPANY Plaintiff V. CARRI E REED Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-1610 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 04/24/2007 to Defendant, CARRI E REED, 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 04/24/2007, 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: ESQ. Date: May 16, 2007 ?-? a , ___ :v ':;? ?'} " ,7 l i ? ?" q ? i ?+/ { ? .4 ,? w 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 (1,1J) /2SV-/1(31 FORD MOTOR CREDIT COMPANY Plaintiff V. CARRI E REED Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-1610 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: CARRI E REED, 9 VILLAGE CT, MECHANICSBURG, PA 17050-9161 MAURICE & NEEDLEMAN, P.C. BY: JO At for Plaintiff , ESQ. Date: May 16, 2007 c C c C'D P v ? i ?'l CD S V" MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 93 5 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff 15) 89-7161 FORD MOTOR CREDIT COMPANY Plaintiff V. CARRI E REED Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-1610 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, CARRI E REED, 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 SWORN TO AND SUBSCRIBED before me this /? day of ur-g- , 200' Notary Public COMMONWEALTH OF PENNSYLV BY: P.C. , ESQ. NOTARIAL SEAL MICHAEL EL GERSTEIN, Notary Public City of Philadelphia, Phila. County Cgn mksion Expires February28, 2" C_ c 3 -Sl t ? ells= cy ;tea _, April 24, 2007 Attorneys at law Suite 935, One Penn (enter 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.665.1133 fax 215.563.8970 www.mnlewpc.com Donald S. Maurice Member NJ Bar Board Certified (reditors' Bights Law American Board of (edification Joann Needleman Member PA S NJ Bar Thomas R. Dominczyk Member NJ, NY 8 PA Bar Charlene A. Taylor Member PA Bar VIA CERTIFIED & REGULAR MAIL CARRI E REED 9 VILLAGE CT MECHANICSBURG, PA 17050-9161 Our File No. 5115 RE: FORD MOTOR CREDIT COMPANY v. CARRI E REED CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 07-1610 CIVIL TERM Dear CARRI E REED: 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 03/27/2007. 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. Very truly yours, LEMAN, P.C. Esq, ARTICLE NUMBER 7155 5474 4100 4606 3251 ARTICLE ADDRESS TO: CARRI E REED 9 VILLAGE CT MECHANICSBURG PA 17050-9161 FEES Postage per piece Certified Fee Return Receipt Fee Total Postage 8r Fees: PT TO COLLECT A NED WILL BE USED $0.39 EBT COLLECTOR 2.40 1.85 $4.61 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 1J?/My=/1JJ FORD MOTOR CREDIT COMPANY Plaintiff V. CARRI E REED CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-1610 CIVIL TERM IMPORTANT NOTICE TO: CARRI E REED DATE: April 24, 2007 9 VILLAGE CT MECHANICSBURG, PA 17050-9161 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 MAURICE "I EDLEMAN, P.C. BY , ESQ for Plaintiff CERTIFIED MAIL N MAURICE & NEL'MIMN, P.C. 935 One Penn Center Philadelphia, PA 19103 LL 4 A.31 nature: (O Adtlrys se or 33 Agent) B. Received By: (Plos P I t Cleeriy) . F ; C. Da777- Delivery o-7 54 essee's Address (Miftrent rem Addna used ey s ed«.) D. Addr Secondary Address / Suite / Apt. / Ploor (Please Print Cleary) Delivery Address City State ZIP + 4 Code 7155 5474 4100 4606 3251 RETURN RECEIPT REQUESTED Artiols Addressed To: IiWK711 ???„ 11I1?1'I111 ?, I11111 " Il?l,lil'II?1111'11111" CARRI E REED 9 VILLAGE CT MECHANICSBURG PA 17050-9161 X115, I =!l ill _ ..1 1 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) 789-7161 FORD MOTOR CREDIT COMPANY Plaintiff V. CARRI E REED Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-1610 CIVIL TERM (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $5318.97 on P7 (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. Lax Prothono /Clerk by: &A #1 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) .0 4h it, CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Caption: ( ) Confessed Judgment ( ) Other Ford Motor Credit Company vs. File No. 07-1610 Civil Term 4 Amount Due a Interest 7/2-0200'7 J4 - 7/ Atty's Comm CARRI E REED Costs 9 Village, Oourt, Meeli , PA 1#7050 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below. does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but If it does, it is based on the appropriate original Proceeding filed pursuant to Act 7 of 1966 as amendedT and for real property pursuant to Act 6 of 1974 as amended. Issue a writ of execution in the above matter to the Sheriff of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) County, any and all accounts and property in the name-of the above Defendant. SS# xxx-xx-1402 GARNISHMENT ONLY PRAECIPE FOR ATTACHMENT EXECUTION and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 0 (indicate) Index this writ against the gamishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Signature: Print Name- ?t?lK [emSn Address: 050.P-Ma ©ft( ren-I C E4, PMlaadphia, Pa 19103 r t?N p GI lci 0 L ? 103 Attorney for: PhwailP 1 ?Lc? «''R- Telephone: 2157897150 Supreme Court ID No.: 7j2 - (over) Issue writ of attachment to the Sheriff ofCumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) COMMERCE BANK - any and all accounts and property in the name of the above Defendant. SS# xxx-xx-1402 GARNISHMENT ONLY ti !? 9 00 ? C> J . a 01 10 w V-1 " .? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1610 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From CARRI E. REED, 9 VILLAGE COURT, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: COMMERCE BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013 ANY AND ALL ACCOUNTS AND PROPERTY IN THE NAME OF THE ABOVE DEFENDANT. SS# xxx-xx-1402 GARNISHMENT ONLY and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $5,318.97 Interest 7/26/07 - $43.71 Atty's Comm % Atty Paid $159.98 Plaintiff Paid Date: 9/19/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs ais R. Long, Prothonotary By: L Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: MAURICE & NEEDLEMAN PC 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Supreme Court ID No. 74276 SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-01610 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS REED CARRI E And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0009:47 Hours, on the 25th day of September, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT REED CARRIE E hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to DENEEN RAUDABAUGH (TELLER personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . , in the true and made Sheriff's Costs: So answers:. Docketing .00 Service .00C r Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 00 ?/°?to-5) 09/25/2007 Sworn and Subscribed to before me this day of By A.D MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Attorneys for Plaintiff Identification No. 74276 BY: Charlene Taylor Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 121J) i69-i1Jt FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF - Plaintiff,- COMMON PLEAS V. CARRI E REED Defendant(s). Case No. 07-1610 Civil Term PRAECIPE TO DISSOLVE/WITHDRAW GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve/withdraw garnishment upon Commerce Bank forthwith. Respectfully Submitted, MAUWC,E & NEEDLEMAN, P.C. Esq. Date: October 4, 2007 ip ? - r,a o -Ti ? "'{ ... R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, DUE TO BANKRUPTCY. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs: 86.83 Docketing $ 18.00 63.17 _ Poundage 1.71 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 10/04/07 Mileage 4.80 Surcharge 30.00 Levy 20.00 Post Pone Sale Garnishee 9.00 Postage .82 TOTAL $ 86.83 ?°???/?, So Answers- 4- le? R. Thomas Kline, Sheriff By o, d WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1610 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From CARRI E. REED, 9 VILLAGE COURT, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: COMMERCE BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013 ANY AND ALL ACCOUNTS AND PROPERTY IN THE NAME OF THE ABOVE DEFENDANT. SS# xxx-xx-1402 GARNISHMENT ONLY and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $5,318.97 Interest 7/26/07 - $43.71 Atty's Comm % Atty Paid $159.98 Plaintiff Paid Date: 9/19/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs Long, Prothonot By'' Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: MAURICE & NEEDLEMAN PC 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Supreme Court ID No. 74276