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Home My WebLink About07-2535ARBITRATION 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. TREVOR M KECK 387 Pin Oak Lane 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. Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 01 S t 0 ?1 CIVIL ACTION COMPLAINT AVISO Le ban demandado a usted en la cone. 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 con 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 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. 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. 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 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 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. TREVOR M KECK 387 Pin Oak Lane Carlisle, Pa 17013 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 6 7 - ? LFs 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, Trevor M Keck, is an individual who resides at 387 Pin Oak Lane 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 February 24, 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 $18,748.01 at an annual percentage rate of 12.500%, in order to purchase a certain motor vehicle, 2002 Mercury Cougar 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 $421.88 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 May 2, 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 $3900.00, however a balance of $7879.58 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 $531.60 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $8411.18. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $8411.18, 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. CHARLEftTTAA , ESQ UIRE 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: Aqk?m CHARLENE A. TAYLOR, ESQUIRE DATED: April 25, 2007 PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE 02/24/2003 Buyer land Co-Buyer) Name and Address (including County and Zip Code) CREDITOR (Seller Name and Address) TREVOR M KECK CROWN FORD SALES, INC J,%AS';-7AY1 387 PIN OAK LANE 2024 LINCOLN WAY EAST CARLISLE PA 17013 CHAMBERSBURG PA 17201 .?...?e._-..._.,,._e._.__ ..__ . MAR - 6 2003 'Total awls Price, Chown below b tie erode »r ?•• ..r..c.. avscrrwo crow ran eeeh or on crodN. The'Caeh Prim- et o below is the eaeh pnw o1 the vehicle. Tae Pries. By slpning this control YOU choow to buy oe credit under the agreements 0" 1110 front d b k NawNsed Veer end Make Model GVW If Truck lbs. Yehkle IdeMiicelbn Number an ac of ads commeL Use For Wit' USED I MERCURY COUGR 1ZWFT61L925614413 OX Personal ? Avtcukuraf D Corn -ai 1995 TOYOTA 9400.00 Trade-Nit 5105 99 DISUfiANCE.::..: - : $ Yearand Make Gross Allowance U . Amourd Owing YOU MAY OBTAIN VEHICLE INSURANCE ITEMIZATION OF AMO NT FINANCED FROM A PERSON OF YOUR CHOICE. t. Cash Price ................................ _................ ......... ».» $ 21990.32 (1) 2. Down Payment Third Party Rebels Assigned to Creditor ...... » .................... C $ N/A ash DowRf#Nnt)tB?OP $° 94dP:00 $ - SIOS:49 Tndaln $-T29OT Yw w m" 60rr whowrce Anand Owes Total Down Payment .................»...............».............»»»......... 3 U ...... $ 4894.01 (2) . npaid EWORCO of Cash Price (1 minus 2)............ -.._...._..._ ....- $ (3) 4. Amounts Paid on your behalf (Seller may be retaining a portion of these amounts) To Insurance Companies for Credit Life Insurance (for term of contract) .._,,,,,-•,,,, „ $ MIA Credit Disability Insurance (for term of contract) ,...,,,,»».. $ WA [f ern --r&.-Wnths (ES111" ] 50 N/A W. To Pulolie Officials (I) icer $ ise ( ?), title (S registration ($-5) ?8a $ ti . (It) for filing leas $ 751.20 (ii) for taxes (rho in Cash Price) ; $ 796.70 To EXTRA nor MesServlos._._ »...._ T sl $?A -'80V'QO' o r To CROWN ?jr $ --55-w To for Tot l $ RIK 'Z6ST 70 a . ......... ...... .. ......»....»...... ..... !i. Amount Fin, c- 13 olus 41_._..____ ZZ8?;iBafF ?4) FEDERAL TRUTH-IN-LENDING DISCLOSURES ranhVUAL. 1•INAIUCE Amount Total Of Total Sale PERCENTAGE CHARGE Financed Payments Price RATE The dollar amoutd The amottrht of The amount The total cost Tha cost of your the credit we C1ed" Provided to you will have of your purchase on credit as a yearly rate cost you you or on your paid when you credit. behalf have media 60 Including your scheduled Ifflyn ffl ! 09 4 1 1 1 12.50 % $6564.79 1 16748 01 2580 d $ 30 2 06 . 1 $ , 8 1 payment Schedule Number of Amount of Each When Payments 7® Paymsnb P"-t Your a m 59 t d are due p y en s tedul e $ 421.88 nWy tabling) will be: t Area $ 421.88 03 0/26/20 Prepayaroft lf you pay off your debt early, you will not have to pay a penalty. Lab Paymmr: You must pay a late charge on the portion of each payment received more dron 10 days lure. The char" Is 2 pament of the lab amount or $50.00 whichever M Mss, Security Irtteraat: You are giving a security interest In fits vNyche botrg phxdusad, 1 fto Please as this conste f for additional Information on security YNereet, ar of your debt h hill before 1110 achetkrled tlMS 0repaymam pare4uire repaymr ?an? Ay COWIptdAL VENMUM The clangs shows in the above box for MM payments appeas whore the vehlde NmhMd his a J711", valeadar weight of less shah 15,000 pounds, a We vehicle you purchased hoc a gross vafssAar welgld 00 pounds or roe, you met pay a late darge an do podia! of each payment recewed more U10n 10 days tars. The chrge is 4 patient of the We amount or $11% whichever is loss. 0 you do not mod as both your contract obigoaom you may bee to vehicle that you am aencirg under Oft conlin ct, its will Parts and goods lxd on she vehicle and money or goods moslimd for the vaivdo. NOWMODIFICATION DISCLOSURE Any d10rge M ""a ?Rliaaof must be -,wI" and signed by you arc the Creditor NOTICE TO BUYER -I Do not sign this contract in blank. You are entitled to an oxact copy of the contract you sign. Keep!jjo protvict Y4ur)egal rights. YOU ARE NOT REQUIRED TO OBTAIN CREDIT LIFE, CREDIT DISABILITY AND OTHER OPTIONAL INSURANCE. THIS CONTRACT WILL NOT INCLUDE THEM UNLESS YOU SIGN AND AGREE TO PAY THE PREMIUM. THIS CONTRACT DOES NOT INCLUDE LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS. o Credit Life N/A Insurer $ N/A Premium Insureds) Signature Craig D Disability N/A Insurer $ N/A Premium Insured Signature ? Type of Insurance Term Insurer $ N/A Premium n to redo for Ctiro tLieao ns a s of Cthis reekcoirbano sa grew a M ?oovenrageate! yX = In a notice ar agreement You mud Insure ft vehicle. It a drolge Is shorn below ?L the . Creditor editor wW by b buy Uhe am M ceCovarrag psa v based on tthhs cash val of the lknft s of Was, but not mfrs than of the poky. 0 Compebenstve 13 $ N/A Deductible Collision r3 Fee- Theft-Comhinwi Additional Cweri ge Ill Towing and Labor 0 Toren N/A Months (EsBmate) Premium $ N/A QUESTIONS? PLEASE CALL us AT 14wcl-727-7000 00401 and completely filled in copy of this contract at the time of arielpgmant i6il-. fn tl?M oon4apt, Ear lelr? r named in a separate CROWN FORD SALES INc By To c°"'°"" Fc new.a od 00 Wrwhes W ft w coq Nor be Md.) SEE BACK FOR ADDMONAL AOREBMENTS ORIGINAL EXHIBIT Ford Motor Credit Company P.O. Box 3076 Columbia MD 21045-6076 800-677-0730 PMV700100087 TREVOR M KECK 387 PIN OAK LANE CARLISLE PA 17013 Date of Notice Account Number June 13, 2006 00000034116985 Description of Property Year Model 2002 =MERC COUGR Vehicle Identification Number: 1ZWFT611-925614413 Date of Contract Current Balance(Net to cbse and unpaid late charges) February 24, 2003 $11,084.78 CURE DATE: June 23, 2006 NOTICE OF DEFAULT AND INTENT TO REPOSSESS This is your notice that you've broken your contract. Overdue Payment(s) Due Date April 26, 2006 $ 371 36 May 26 2006 $ 420-20 $ Late Charges/Other Fees Due ............. ............. .......................... - ..................... $ --- -.- 39.47. TOTAL AMOUNT NOW DUE (Not including amounts that become due after the date of this notice) ..................................... ..................._..-- ............................. .......... $ 831.03 If you don't pay the TOTAL AMOUNT NOW DUE by the CURE DATE stated above, we plan to repossess the above described property. If we do, you'll have the following rights. RIGHT TO GET YOUR PROPERTY BACK: You can get your property back by paying the net unpaid balance plus costs of repossession. Your balance now is stated above. If you do that before the property is sold, it will be yours. We'll have no further claim on it. This is called your right to "Redeem". Your property will not be sold until at least 15 days after we repossess it. You can get it back by paying the balance plus costs any time before its actually sold. The longer you wait, the more costs (including repairs) you may have to pay. RIGHT TO MONEY LEFT OVER FROM SALE: When your property is sold, the sale price minus expenses will be deducted from your debt. If any money is left over, it must be paid to you within 45 days after the sale. If you don't get this money, you may have a right to sue for it, plus penalties, under state law. In some areas, we return repossessed property to the dealer/original creditor who sold the property. If we do that with yours, our agreement with your dealer/original creditor says that the dealer/original creditor is to sell it and pay you any money left over. INSURANCE RIGHTS: If we repossess your property, all insurance should be cancelled. You have a right to get credit for all premium refunds. REMAINING DEBT: The sale price might not cover your debt and expenses. If that happens, you'll owe the difference to us or the dealer/original creditor. If you want to know more about these matters, please call us. Ford Motor Credit Company C A ROSSON NOTICE: The acceptance by us of these or other late payments does NOT waive our right to repossess or take other a WITHOUT NOTICE, if you fail to make future payments on time. YOU ARE REQUIRED TO MAKE ALL PAYMENTS ON TIME. EXHIBIT FFNA 1188637 08!04 Previous editions may NOT be used. ?. 5; A . p t, - Name and Addrsaa of Sender LaSon 38120 Awhein Livonia, MI 48150 - Aftle NumW U0706/20580733 BA-035660533 SHILYN M. MURPHY 19 A EAST MOUNT KIRK AVE NORRISTOWN PA 19403 pi 1 i. { r U0706/20580734 BA-024113378 MICHELE LASHER 831 PEAR ST SCRANTON PA 18505 U0706120580735 BA-039139915 TANESHA BETSILL 1227 S 59TH ST PHILADELPHIA PA 19143 T. 00706/20580736 BA-039442419 8 PHYLLIS RANSOME 5223 W GIRARD AVE PHILADELPHIA PA 19131 7(1r ?' %I?? r Cherk f mail or service: GnMed 0 Recorded Detlve y (Inbmatbnal) too 0 Reyisteree 0 D@llv" C"off"n bn G Retun RecNpt for Merchandlse 0 Expeu Mall 0 SlanNUe Gnhmclbn'tI{/.}[q/?f Added - I Adaeeeee p'ernlb 9eeG d'y, Sefe 6 DPCLdy 7004 2510 D007 4153 9297 + 7004 2510 0007 4153 9303 7004 2510 0007 4153 9310 - ots F.hLOOy SSneel xaera"boat Realvedat Post Oabe 7004 2510 0007 4153 9327 Ink. nr Flag PrdIN P'e r Affix Stamp Fiore p1W lrsd ea s .sNhtare dmmrhg, a/aeddrtionsl =q•?iss d das M!p v Q4 /4 O Poffimark Daffy 7 ,e0 y-0)06/20580737 I 7 I -i ? _ _W-034116985 7004 2510 00137 4153 9334 `` REVOR M. KECK 387 PIN OAK LANE CARLISLE PA 17013 U0706/20580738 - 13A-035660533 LINDA S. MURPHY 7004 2510 0007 4153 9343 13 ORCHARD CT ROYERSFORD PA 19468 00 T U0706/20580676 6K-031146771 HA. CAHILL _ 7004 2510 0007 4153 93SB 329 RESERVOIR HILL RD f NORWICH NY 13815 a to fL' I f7 1 ?? `?X IJ I ?. Act Stosment on Reverse Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 8773495260 DATE: 2006-08-16 F%17800000063 TREVOR M. KECK 387 PIN OAK LANE CARLISLE PA 17013 STATEMENT OF SALE Account Number: 034116985 The following property has been sold. Year Make Model Vehicle Identification Number: 2002 MERC COUGR 1ZWFT61L925614413 Balance owing on your contract (1) $ 11,170.58 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 11.170.58 Deduct: gross proceeds of the sale (4) $ 3,900.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 7,270.58 Add: Expenses of retaking and storing, and (6) $ 609.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ 0.00 Other. (8) $ 0.00 Deficiency** (9) $ 7879.58 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 editions may NOT be used. 8 4t I'-- W 1 a 1-41 t'? Cv i y* .. y .. 4 G -"J N CJ d C -G OV) SHERIFF'S RETURN - REGULAR CASE NO: 2007-02535 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS KECK TREVOR M STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KECK TREVOR M the DEFENDANT , at 1515:00 HOURS, on the 11th day of May , 2007 at 387 PIN OAK LANE CARLISLE, PA 17013 TREVOR KECK by handing to 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: Docketing Service Affidavit Surcharge ? 0167 Q, Sworn and Subscibed to before me this So Answers: 18.00 5.76 .00 10.00 R. Thomas Kline .00 33.76 05/14/2007 MAURICE & NEEDLEMAN By: day eputy Sheriff of A. D. L 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 (llJ) /2Sy-/161 FORD MOTOR CREDIT COMPANY Plaintiff V. TREVOR M KECK Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-2535 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 7/25/2007 to Defendant, TREVOR M KECK, 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 7/25/2007, 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: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: October 9, 2007 A. 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 (22-15) ./Zsg-1161 FORD MOTOR CREDIT COMPANY Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS - CASE NO. 07-2535 Civil Term TREVOR M KECK Defendant(s) 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: TREVOR M KECK, 387 PIN OAK LANE, CARLISLE, PA 17013 MAURICE & NEEDLEMAN, P.C. BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: October 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 (215) 789-7161 FORD MOTOR CREDIT COMPANY Plaintiff - - V. TREVOR M KECK Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-2535 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, TREVOR M KECK in the amount as follows: Principal Amount Interest to Date Costs TOTAL $ 7879.58 $ 1127.97 $ 112.26 $ 9119.80 MAURIC NEEDLE N, P.C. Nff BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: October 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 151789-71M FORD MOTOR CREDIT COMPANY Plaintiff V. TREVOR M KECK Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-2535 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, CHARLENE A._TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she represents the Plaintiff in the above entitled case and that Defendant, TREVOR M KECK, 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. MAURICE & NEEDLEMAN, P.C. aw)?- BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff SWORN TO AND SUBSCRIBED before me this /0 day of &Zt , 2007 Notary Public "6c?? COMMONWEALTH OF PENNSYLVANIA Apnublic CNy Of PN CojV MY Jan. ?,z009 -:::7 Mambaf, Pennsylvania Association of Notadas 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 /Z59- / 161 FORD MOTOR CREDIT COMPANY Plaintiff V. TREVOR M KECK Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-2535 Civil Term AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that she is an _attorney at law and that on 7/25/2007 she mailed a written Notice of Intention to File the Praecipe to Defendant, TREVOR M KECK, at 387 PIN OAK LANE, CARLISLE, PA 17013 by certified mail, article nos.. Copies of the receipts evidencing said mailing are attached hereto. Neither the certified or regular mail was returned to Counsel's office, therefore, pursuant to Pa.R.C.P. §403 (1), service has been perfected by regular mail due to the fact that the Notice has not been returned to sender within fifteen (15) days after mailing. MAURICE & NEEDLEMAN, P.C. BY: cfl&k4\? CHARLENE A. TAYLOR, ESQ. SWORN TO AND SUBSCRIBED before me this 16 day of 0-d , 2007. Notary Public C?? pij Attorney for Plaintiff COMMONWEA TH OF PENNSYLVANIA Notarial Seal Agnes ftlam, Notary Public City Of ohIladelphla, phtladeiphla County My Carfmie M E)Orn Jan. 20, Eow Mambst, pannaylvanla Asaoofatlon of Notaries Attorneys at Law Suite 935, One Penn (enter 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tell. 215.665.1133 fax 215.563.8970 www.mnlawpc.com Donald S. Maurice Member NJ Bar Board (ertified Creditors' Rights Law American Board of Certification Joann Needleman Member PA & NJ Bar Thomas R. Dominczyk Member NJ, NY & PA Bar (harlene A. Taylor Member PA Bar July 25, 2007 VIA CERTIFIED & REGULAR MAIL TREVOR M KECK 387 PIN OAK LANE CARLISLE, PA 17013 Our File No. 5263 RE: FORD MOTOR CREDIT COMPANY v. TREVOR M KECK CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 07-2535 Civil Term Dear TREVOR M KECK: 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 05! IV 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. tl New Jersey Office Maarice I Needleman, P.(. Suite 1007 5 Wolter E. Foran Blvd. Flemington, NJ 08822 tel. 908.137.4550 tox 908.237.4551 Enc THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR AIMCLE R 7155 5471 %M M73 5637 ARTICLE ADDRESS TO: TREVOR M KECK 387 PIN OAK Ln CARLISLE PA 17015-7825 Postage per piece $0.41 Certified Fee 2.65 Retum Receipt Fee 2.15 Total PoMW & Fees: $5.21 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 1S) "RSy-"/1SS FORD MOTOR CREDIT COMPANY Plaintiff V. TREVOR M KECK CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-2535 Civil Term IMPORTANT NOTICE TO: TREVOR M KECK DATE: July 25, 2007 387 PIN OAK LANE 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 MAURICE & NEEDLEMAN, P.C. BY 2 NEEDLEMAN, ESQ rnv for Plaintiff trnpe 6 <? r 'd ter,-, cW. .3 00 d ` fb b ? ' } C;? .,rw a m cx? ?a t } 4 LA? ^ti r^? i ?l C.1"1 ("s3 . 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) -/89-7161 FORD MOTOR CREDIT COMPANY Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-2535 Civil Term TREVOR M KECK Defendant(s) (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $9119.80 on 0-7 (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. Al . Prothonot /Clerk by: 'All at If you have any questions regarding this matter, please contact the filing party: Name: Charlene A. Taylor, 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)