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HomeMy WebLinkAbout07-2536ARBITRATION 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. KATHLEEN P NEECE 405 High St Enola, Pa 17025 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 s3? CIV 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 veinte (20) dial de plazo al partir de la fecha de la demands 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 [as 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 demandame y requiere que usted cumpla con todas las provisions 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. KATHLEEN P NEECE 405 High St Enola, Pa 17025 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. & - e-t v ? L 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, Kathleen P Neece, is an individual who resides at 405 High St Enola, Pa 17025. 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 May 19, 2004, 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 $33,536.23 at an annual percentage rate of 8.250%, in order to purchase a certain motor vehicle, 2004 Ford E-250 more particularly described in the Contract (hereinafter referred to as the "Vehicle"). Exhibit A. A copy of the Contract is attached and marked as 5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $594.13 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 July 19, 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 $11400.00, however a balance of $14542.60 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 $555.51 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $15098.11. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $15098.11, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. NEEDLEMAN, .C. Respectfully submitted, 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. TAE ED: April 25, 2007 DAT eENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE 05/ 1912004 &ryer (and CO-Buyer) Name and Address (including County and Zip Code) CREDITOR (Sauer Name and Address) MAY 2 1 ZW i KATHLEEN P 808 RUTH FORD, INC. 406 HIGH STNEECE 700 MR RTE 15 NORTH 3J)q°4* 'U 53 WEST FAIRVIEW PA 17025 OILLSBURG, PA 17019 ......w» .,,.'e .u Prtna• snauan bdow to the emb prla of the vehicle TIP You. this Buyer (aria G 11.1fie, n -"1. tar ter e,o .."....,o....-_ -._...-- _ 'Taal Sole Price' shown below Is the ""It Pta. By signing this Contract YOU on node under to "Memo m the froM and MCK M ors axnncr. tiewNred rear Rro rnaw _ _ --__- _ I [X Personal ?ApIk 7 NEW 2004 FORD E260 VAN 8600 1FTNE24L84HA41605 o Co miedall CHEVROLET s 10205.00 $ Yea and Mske 6roes Aafwana ITEMIZATION OF AMOUNT FINANCED S ail 3? 7. Cash Price .................... _.......................................... . ........... .............. _ 41) 2. Down Payment Third Party Rebate Assigned to Creditor .._..... ................. 500-00- GOO nn Cash Down Payment.._ ..................................... ...... _._......... .._ Trade-in 97 CNFV S IfIX16.0 S 995901 $--2.45,-99- y-ens Male apes AP-P Amen10"', .................. $ 274r,.99 (2) Total Down Payment ....... _........... ......... _ ............... 3. Unpaid Balance of Cash Price 0 minus 2)._..... ._........ ............... $ _2811236 (3) 4. Amounts paid on your behalf (Seller may be retaining a portion of these amounts) To Insurance Companies for 1006.26 Credit Life ingUrBrrce (fa term Of contract) .....................- $ 11 R9.2I Credit Disability Insurance (for term of contract) ............. S N/A (Term --mor-ths (Estimata?j To Public Officials (i t« Ikons- (S- 18.00 utle ($-). g registration ($ 55gtees S 99.00 ; (a) for filling fees S 40 (i'0 for taxes (not in Cash Price) $1215. $ $ 131 131 .40 To-M- for N/A TO SVC CONTRACT $ 1520.00 To B RUTH FORD J(C DOCUMENT FEE $ 40.00 To F RO for GAP $ 360.00 Total .......... ._....___......._......................... __..---------- _.._..._._...._ $ 5423.87 (4) 5 Amount Financed (3 Plus 4) S 33536.23 (S) FEDERAL TRUTH4N-LENDING DISCLOSURES ANNUAL FINANCE AntouM Total of Tote) Sale PERCENTAGE CHARGE Firrsnced Payments Price The M11ar amount == The amount The total cost RATE the Cted, wti to you Coal have of your purchase on The post of your, you or on your taw When YOU credit. credit as a yearly rate cost v betwf he" made all Knehrding Your scheduled dog"WwA r Amount of EWA ?i laayntmt Schedule 19 ?Number of your payment sclledule $ v94' 13 (AN will be: 1 total S 13 priepsymsnt It you pay of your debt early, you will not have to pay a penaay. payinhirm: You must pay a Use charge on the portion of each payment rec~ more then 10 tgya We. The drerye Is Poniard at the toe amowd or $50.00 whichever is him secudly Interest: YOU are gang a security Interest in ate vehicle baling ptsche"a Contract Pksas see ilia contract (or adraWW adormNian on sec ally Interest, n paYnrant delauft, fire right to repayment of Y? debt in Pull belors ate Wmk*ed dale, 0 YOU MAY OBTAIN VEHICLE INSURAN FROM A PERSON OF YOUR CHOICE. YOU ARE NOT REQUIRED TO OBT CREDIT LIFE, CREDIT DISABILITY A OTHER OPTIONAL INSURANCE T CONTRACT WILL NOT INCLUDE TH UNLESS YOU SIGN AND AGREE TO I THE PREMIUM. THIS CONTRACT DOES NOT INCU LIABILITY INSURANCE COVERAGE I BODILY INJURY AND PROPEI DAMAGE CAUSED TO OTHERS. LKCrsdit Life An REPUBLIC LIFE Insurer KATHLEEN P NEECE- y P 1005.26 insureds) SigtaWre Credit l)I Disability AM REPUBLIC LIFE Insurer 1189.21 KATHLEEN P NEECE 3 Pr m' ?9 n Insured Signature o N/A MIA Other Optional Insurance Term N/A g N/A insurer Premium sorature credit Las and Credit ohesti b aourat" an ler the WM of lie CGRbeat The amourd and covaragea era afdn In a "011108 or agreement grin to Yon 1o 7 You must Insure aw vehicle. B a charge Is o'a g ' el the Cr@dftw vAN by us buy " dw for the tam shhaen. Will be based an the cash VOW Of ths s at dm of loss, rid apt rams than the Writs of the poaey. ? Comprehenslvs ? S N/A Deductible Coasion ? Rm Theft-Combined Additianal Coverage ? Towing end labor ? Term N/A Moran (Est te) Premium - W It YOU M rat mast Your odNrsCt oergsrar. YW may low rim vNdds arN You an 11nertcln8 order 11is aadrad, as Cost a bolo Palk and goods put a ens wNa. ant matey or goods eoeiwa for the vehldw NON-MODIFICATION DISCLOSURE Any change in dts cord cl must ben Z9 end signed by you and to Creditor. X YOU ISION ON SAND A BEEGIVE EOFOTHIS CONTRACT. NOTICE TO BUYER Do not sign this contract in blank You are dNditled to an exact copy of the contract you sign. Xm" it to protect your legal rights. Buyer (and Co-Buyer) acknowledge that 0) before signing this contra Buyer (and Co-Buyer) received and revlewea a True an?co` surly (liked In copy of this contract and pi) at the time of nin-a this Buyer (and Co-Buyer) race-ivva a mean copy Of thin contract. A&ae DWER SOW If By siprnaq Whew, M 11Ww aeaspk aw atdrYsat N no other Avegrm ls n- In a aaparsto 01 C_ ?omgny. gagptmera Btia 8 RUTH FAD rraNl,NfM Saner asst N F rd Title Ix/FL/---- r017p7. jW Oa (RA- -A- ear lie win) I'M MAURP?ANUrrrene,e?weensra,e...v PA ORIGINAL om Camellias" walirw Addend= g tl" bbmr is cre aid ym have pu P-Wd* a = aneeftim waiver. Pumbaris of Oft wampe Is oplionN and le not required to ebiaan we& The krrra and oorrdaora of the Mat anoadaYan walrN tie sat fain N the Mantled Mdr dean which Is Incorporated into rlia canasa. The pda Im 00 debt carAskOm waiver Is act Pith mara in the aaNreadn of Amount Femrnced under Seam a. Buyer Program No QUESTIONS? PLEASE CALL US AT 1-90G727-7000 or Visit us at www.fordcredlLcom 03,0111 EXHIBIT ••.PRN"` Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631.3111 (877) 349-5260 po5POJ0o200012 KATHLEEN P. NEECE 405 HIGH ST WESTFAIRVIEW PA 17025 Date of Repossession 07-20-2006 Date of Notice 07-21-2006 Dale of Contract 05-19-2004 Account Number: 037004431 Buyer KATHLEEN P. NEECE Cobuyer DESCRIPTION OF PROPERTY Year 2004 Make FORD 0 New ? Used Vehicle Identification Number: 1FTNE24L84HA41605 Model E250 Body CARGO NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. x PRIVATE SALE: We will sell the property described above at private sale sometime after 15 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 ad)otanment date). The sale will be held as follows: Date of Sale Time of Sate Place of Sate You may attend the sale and bring bidders if you want. NOTICE OF REP055tssttJN The property is presently stored at: MANHEIM AUTO AUCTION 1190 LANCASTER ROAD 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 under your agreement: 1) The buyer and any cobuyer named above; 2) Any dealerioriginal creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. HOW TO GET YOUR PR®RE6llt1'I'SACK To get your property back, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 26897.69 PIUS Costs: Repo Expenses $ 385.00 $ Plus Late Charges $ 100.45 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 27,383.14 (Plus expenses incurred if default at the time of repossession exceeded 15 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 d's actually sold. If you do, well have no father claim on it. But the longer you wall, the more costs (Including repairs) you may have to pay. If you have any questions about this, please eel us. ? The properly has been (or will be) returned to: (dealedorlgfttel creditor) Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money after the sale, you will pay l to the dealer/original creator. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance wim state law, by contacting this office. Thereafter, the personal properly shall be disposed of accordingly. Creditor has assigned to its qualified intermediary (01 Exchange, LLC) its rights (but 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 somata for any reason, please contact us so that we can accurately report the vehicle's mleage. INSURANCE RIGHTS: If you don't want to gel your property back, cal the Insurance company or the dealer/original creditor to make sure that any insurance has been cancelled. You have a right to get credit for all premium refunds. CAROLYN L. CASSICK FFNA tteee37 ,ten 02 PreAws editions may NOT be used. CUSTOMERICUSTOMER FILE Pdrdsd In U.S.A. EXHIBIT ,5 ,I 1• E,C.;?• ir•I .i1•.;?, • ; Vic; ?•' ,`rj;,,. ? 'i;..r,: I??7?>ep 1 FEE Check of mel or service: Affix Stamp Here Nerve and Address of Sander - +YPe (h issued es a / 11 ws wn ,?rpled ? Recorded Dellvary (Inlamatlonel) a aka, V?pV 0 COO 0 Registered 38120Amrhein 0 DeaveryContematlon C Return Receipt for Merchandise eagles andsbnq Mi ?' ?,ry ? Express Mel 0 signature Comumation Pcstmadr and :rw p Insured oste of Row 0t J U L 2 12006 r$ r r w. I IQ Addresses (AMte, reset ply stets, d IIPCadsJ Hendl,g Actual VsWe Insured Due sender uc: :,^ Feo Fea Fee 1lrtlcle NUmtfar V Cher9a gReglaterad Vahw I VOW zwzuDntu°f 7004 2510 0007 4151 9404 C7-039127337 ___--.. 00720120582671 7004 2510 13007 4151 9442 MICHAEL SZYPULSKI - - P-029942208 410 COTTAGE LN MONROEVILLE PA 15146 HAMISI O. SMITH ?- ----- -_ 5204 WILSON COURT CLAIRTON PA 15025 U0720/20582668 71304 25111 0007 4151 9411 U0720/20.i32672 7004 2510 0007 4151 9459 MA-032023512 P-023967-.'.33 MARK CHADWICK YVETTE ROBINSON 80 AIRPORT RD 5532 MALCOLM ST PINEGROVE PA 17963 PHILADEI.?HIA PA 19143 1 I f j --- - U0720/20582673 7004 2510 0007 4151 9466 --- - AM-038769686 -- -- - CINDY SAVARD rr 0720/20562669 ' DOW GREEN DR 7004 2510 0007 4151 9428 2272 MEADOW 6 J A 037004431 ---- - NEENAH'NI 54956 $ THLEEN P. NEECE . 405 HIGH 3T --- WESTFAIRVIEW PA 17025 00720/20582670 7004 2510 0007 4151 9435 MA-040404164 - -- I JEREMY M. GRAY 216 VINE ST. DANVILLE PA 17821 f Trial Mira ar aPoaoaa Tetal Number of 1Neoee l.Mtad by Sander /? Received at Gast Office G ft g !t ? Ail See Privacy Act Statement on Ravens 11 -71 Ford Motor Credit Company P 0 BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2006-09-13 PMEUBM000048 KATHLEEN P. NEECE 405 HIGH ST WEST FAIRVIEW PA 17025 STATEMENT OF SALE Account Number: 037004431 The following property has been sold. Year Make Model Vehicle Identification Number: 2004 FORD E250 1FTNE24 L84HA41605 Balance owing on your contract (1) $ 26,998.14 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 26.998.14 Deduct: gross proceeds of the sale (4) $ 11,400.00 (5) $ 15,598.14 Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and (6) $ 777.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. (7) $ 0.00 Deduct: Insurance Premium Rebate (8) $ 1,832.54 Other: (9) $ 14542.60 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 EXHIBIT FFNA11990 01/04 Previous editions may NOT be used. i C-' 4 W W C7 C: N C-1 V -rt C.J W 0 t-r%U 1AnNWFe1 T11 nF PFNN-RYLVANIA COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT I COMMON PLEAS No. 07- a,A6(,q 6,tjr4`I Term NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. TME OF APPELLANT ?.? ? Re MAG. DIST. NO. o -- fir' U.J. R Ak ')fl tvt?l o . DD SS OF APPE!PNT CC CITY q S ,?EJ t ZIP/CODE AT OF JUD MENT ? ? - 0 7 1 I CAS OF ( intif() 1) C. t /t, /Jr (Defendant)' Vs VIAIIJ e, v_ c)ooo0,3o- ©7 This block will be signed ONLY when this notation is required under Pa. R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. was Claimant (see Pa. action before a District Justice, A COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s), to file a complaint in this appeal Name of appellae(s) (Common Pleas No. Vi ) within twenty (20) days after service of rule or suffer entry of judgment of hon pros. Signattue of appellant or attorney or gent RULE: To appellee(s) Name of appellees) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this r".-- T" 6y6iu by personal service or by certified or registered mail. 41f you do not file a cor I16int within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. q)? The date of service of tMs rifle if service was by mail is the date of the mailing. Date: Mda : , 20 7 p At W:A kA )t . , 4048 7T Sig re of Prothonotary or Deputy YOU, MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE -COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANT'S COPY PINK -COPY TO BE SERVED ON APPELLEE GOLD -COPY TO BE SERVED ON DISTRICT JUSTICE ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: f i A. Signature ? ? 01"nt y 'tea./ ??/?./?? C? ? Add. E Received by (Punted Name) C. Date of Del D. Is delivery address different from item 1? '0 Yes If YES, enter delivery address below: )w No •?` ? / Q I C ? SI//J? (/p?` / Q 3. Service Type Dm" ' ,;Eftertified Mail ? Express Mail i ! e di h -c rl r" r-- an s ? Registered ? Return Receipt for Merc - , , 5 ?V ? Insured Mail ? C.O.D. F ? Y . ee) es 4. Restricted Delivery? (Extra 2. Article Number (Transfer from service label) 7`001 1940 0006 8634 2108 P- PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 O CAI __ _?....w? yr rrV r1{C yr Fl _ OMPLA/NT is proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice dif appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT I hereby (swear) (affirm) that I served ? a copy of the Notice of Appeal, Common Pleas , upon the District Justice designated therein on (date of service) , 20 , ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on ,20 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF -,20 Signature of o belts ardavit ww mede Tithe of official My commission expires on Signature of afRant ¦ Complete items 1, 2, and 3. Also complete A. Signature ent item 4 if Restricted Delivery is desired, 4;??Qilclressee ¦ Print your name and address on the reverse X ` t i so that we can return the card to you. Receivgd b rint C. Date of Delivery ¦ Attach this card to the back of the mailpiece, 5 , `? or on the front if space permits. ADe)o i D. Is delivery a ss different from it', Article Addressed to: If YES, en elivery address beloJ$ o l W10, / /? k ? m Uj MONO ?o0? 3. Service Type [3 Certified Mail ? Express Mail /l C. ? Registered ? Return Receipt for Merchandise G 7 It] Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? yes 2. Article Number SHERIFF'S RETURN - REGULAR CASE NO: 2007-02536 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS NEECE KATHLEEN P SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pe nnsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NEECE KATHLEEN P the DEFENDANT , at 1834:00 HOURS, on the 17th day of May 2007 at 405 HIGH STREET ENOLA, PA 17025 by handing to KATHLEEN NEECE 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: So Answers: Docketing Service 18.00 14.40 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 6`l3a?o? ? 42.40 05/18/2007 MAURICE & NEED C Sworn and Subscibed to By: before me this day /Aputy Sheriff of A.D. Sheri D. Coover, Esquire Attorney for Defendant Attorney Id 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500 telephone (717) 221- 9400 facsimile FORD MOTOR CREDIT COMPANY: CUMBERLAND CTY COURT P.O. Box 6508 : OF COMMON PLEAS Mesa, AZ 85216-6508 V. KATHLEEN P. NEECE, 405 High Street Enola, PA 17025 CASE NO. 07-2536 DEFENDANT'S ANSWER WITH COUNTER-CLAIM AND NEW MATTER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. -5. Admitted. 6. Denied. It is admitted that the Defendant made payments to the Plaintiff. It is denied that payments were made each month between May 19, 2004 and July 19, 2006. In fact, when the Defendant had financial difficulties she had been able to enter into an agreement with the Defendant whereby alternative financial arrangements were made. It is further denied that the Plaintiff was in default of their agreement. The Defendant had called the Plaintiff, as she had done on previous occasions when she was having financial difficulties and made alternative financial arrangements. The last payment that the Defendant made toward the repayment to the Plaintiff was on July 19, 2006. The vehicle was repossessed the following day on July 20, 2006. As the Defendant had indicated to the Plaintiff when she had called to make alternative loan arrangements, the Plaintiff intended to bring her loan payments current with the Plaintiff. 7. Denied. It is admitted that the vehicle was repossessed on July 20, 2006, the day after payment had been collected on the account held between the Plaintiff and the Defendant. As stated above, it is denied that the Defendant was in default on their loan with the Plaintiff. It is further denied that notice of repossession was sent by the Plaintiff as no such notice was received by the Defendant. 8. Denied. It is admitted that the Defendant failed to redeem the vehicle as the Defendant never received notice of repossession. After thorough investigation, Plaintiff is without knowledge or information to form a belief as to the accuracy of the Plaintiff's assertions that the vehicle was sold for $11,400.00 and demands proof of the same. Further, Defendant disputes the accuracy of the balance that the Plaintiff claims is due and owing on the account. 9. Denied. It is admitted that the terms of the agreement require that the Defendant make all payments due and owing, but it is denied that the Plaintiff was in default. 10. Denied. After thorough investigation, Defendant disputes the accuracy of the balance that is claimed to be due and owing by the Defendant to the Plaintiff and demands proof of the same. 11. Denied. After thorough investigation, Defendant disputes the accuracy of the amount that the Plaintiff claims to be due on the contract and demands proof of the same. WHEREFORE, Defendant respectfully requests that this Court deny the Plaintiffs request for judgment and enter judgment in her favor and against the Plaintiff, and impose costs and fees upon the Plaintiff, including fees, costs attorney fees and all other costs that this Court deems to be just and proper. COUNTERCLAIM/NEW MATTER 12. Plaintiff incorporates paragraphs 1 through 11 as contained above in full in their entirety. 13. Plaintiff and Defendant entered into a valid written contract whereby the Plaintiff agreed to finance a motor vehicle for the Defendant in exchange for the Defendant making payments toward the amount financed. (Attached as Exhibit A to Plaintiff s Complaint). 14. On or around May 15, 2006, Defendant called and spoke to a representative of the Plaintiff's company who agreed to a payment extension due to the fact that the Defendant had been ill. 15. On or around June 5, 2006, Defendant made a payment to the Plaintiff company of $400.00 toward the payment of the vehicle. 16. In or about July 2006, Defendant spoke to a representative of the Plaintiffs company who assured the Plaintiff that ulterior payment arrangements could be made to bring the Plaintiff current on the amount that she was in arrears on the account. 17. At that time, the Plaintiffs representative informed the Defendant that he would send information to her about the Plaintiff's proposed ulterior arrangements. 18. On or around July 19, 2006, Defendant made a payment of $400.00 toward the vehicle although she had not received the proposed payment arrangements in a good faith effort to make payment on the account. 19. Without any notification to the Defendant, the vehicle was repossessed by the Plaintiff on or around July 20, 2006, despite the fact that the Defendant had consistently made payments toward the payment of the vehicle and had entered into an agreement with the Plaintiff's representative to engage in an ulterior payment arrangement to bring the outstanding account current. 20. At no time did the Defendant ever intend to stop making payments toward the vehicle and had made every effort possible, given her available financial resources at the time, to make payment toward the debt. 21. The agreement that the Defendant and Plaintiff's representative had reached on the telephone to cure any lateness in payments was a valid oral contract between the parties. -22, On at least one previous occasion, Defendant had entered into a verbal agreement with the Plaintiff to make ulterior financial plans until Defendant was able to resume the regularly agreed upon financial schedule, leading the Defendant to justifiably rely on the Plaintiff's assurances that they would honor the verbal contract that the parties entered into on the telephone. 23. Despite the fact that the Defendant made payment as agreed upon in their superseding oral contract, including a payment made on July 19, 2006, the Plaintiff breached their contractual agreement by repossessing the vehicle on July 20, 2006. 24. Defendant maintains a business in which she used the vehicle that was wrongfully repossessed by the Plaintiff to transport equipment that she uses to perform her business services. 25. As a result of the breach of contract by the Plaintiff, by repossessing the vehicle, the Defendant has not been able to maintain her normal business as she is not able to transport the equipment used to perform her services as she had done previously. 26. As a result of the Plaintiff's breach, the Defendant has suffered a loss in wages in excess of $2,000.00 per month due to losing the transportation provided by the repossessed vehicle. WHEREFORE, Defendant respectfully requests that this Court find in her favor and against the Plaintiff and grant judgment to her in the amount of $24,000.00, along with fees, costs, attorney fees and all other costs that this Court deems to be just and proper. Resp tfu submitted, ' C S erl D. Coover, Esquire Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 06,22/2007 10:18 7172219400 FORD MOTOR CREDIT COWA.NY: CUMBERLAND CTY COURT P.O. Box 6508 : OF COMMON PLEAS Mesa, AZ 85216-6508 , V. CASE NO. 07-2536 KATHLEEN P. NEECE, 405 Hugh Street Enola, PA 17025 I, Kathleen Neece, hereby verify that I have reviewed the foregoing document and all of the assertions and allegations contained therein are true and correct to the best of my knowledge, information and belief I understand that these statements are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unAworn falsification to authorities. PAGE 07/08 Kathleen Neece Date: WWI 0`7 FORD MOTOR CREDIT COMPANY: CUMBERLAND CTY COURT P.O. Box 6508 OF COMMON PLEAS Mesa, AZ 85216-6508 V. CASE NO. 07-2536 KATHLEEN P. NEECE, 405 High Street Enola, PA 17025 CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this jqM day of June, 2007, I caused the foregoing ANSWER WITH COUNTERCLAIM AND NEW MATTER to be served upon Plaintiff s counsel addressed as follows: Charlene A. Taylor, Esquire Maurice & Needleman, P.C. 935 One Penn Center 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 ?Heri D. Coover, Esquire Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 O f TI MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 BY: Charlene Taylor Identification No 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (115) "/tig-"/151 FORD MOTOR CREDIT COMPANY Plaintiff, V. KATHLEEN P NEECE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 07-2536 Civil Term NOTICE TO PLEAD TO: Kathlen P. Neece, Esq. c/o Sherri D. Coover, Esq. 4311 N. 6 h Street Harrisburg, PA 17110 YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER TO COUNTER-CLAIM OF THE PLAINTIFF WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF, OR A JUDGMENT MAY BE ENTERED AGAINST YOU. Respectfully Submitted, MAUVE* r*EEDLEMAN, P.C. J Esq. Date: July 23, 2007 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 BY: Charlene Taylor Identification No 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff, V. KATHLEEN P NEECE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 07-2536 Civil Term PLAINITFF'S REPLY TO NEW MATTER AND ANSWER TO COUNTER CLAIM WITH NEW MATTER Plaintiff, Ford Motor Credit, by and through its counsel, Joann Needleman, Esq. and Charlene Taylor, Esq. respond to Defendants' New Matter and Counter Claim as follows: REPLY TO COUNTER CLAIM/NEW MATTER 12. No response is required. 13. Admitted. 14. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. 15. Admitted in part. It is admitted that a partial payment of $400.00 was made to the Plaintiff. Plaintiff however denies any inference that said payment was made in regard to any payment extension or agreed upon payment plan, therefore strict proof of same is demanded at trial. 16. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. 17. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. 18. Admitted in part. It is admitted that a partial payment of $400.00 was made to the Plaintiff. Plaintiff however denies any inference that said payment was made in regard to any payment extension or agreed upon payment plan, therefore strict proof of same is demanded at trial. 19. Admitted in part. It is admitted that the vehicle was repossessed on July 20, 2007. Plaintiff denies any inference that said repossession was in anyway improper or that the parties had entered into any payment extension or agreed upon payment plan at the time. To the extent Defendant alleges that it made consistent payments to the Plaintiff same is denied. Plaintiff demand strict proof of same at trial. 20. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. 21. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. By way of a further response and to the extent said allegation is a conclusion of law, no response is required. 22. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. By way of a further response and to the extent said allegation is a conclusion of law, no response is required. 23. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. By way of a further response and to the extent said allegation is a conclusion of law, no response is required. 24. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. 25. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. By way of a further response and to the extent said allegation is a conclusion of law, no response is required. 26. Denied. Plaintiff is without knowledge or information to form a belief or opinion as to the truth or veracity of this allegation therefore strict proof of same is required. By way of a further response and to the extent said allegation is a conclusion of law, no response is required. WHEREFORE, Plaintiff requests this Court to dismiss Defendant's Counter-Claim and enter judgment in its favor. NEW MATTER TO COUNTER-CLAIM 27. Defendant's counter-claim fails to state a cause of action for which relief can be granted. 28. Defendant's counter-claim is barred by the applicable statute of limitations. 29. Defendant's counter-claim is barred due to a lack of consideration. 30. Defendant's counter-claim is barred by the doctrine of laches. 31. Defendant's counter-claim is barred due to the failure to mitigate her damages. 32. Defendant's counter-claim is barred due to lack of a valid or enforceable contract. 33. Defendant's counter-claim is barred by the doctrines of waiver and estoppel. 34. If Defendant did suffer any injuries therein, same were not proximately caused by the acts or omissions of the Plaintiff. WHEREFORE, Plaintiff requests this Court to dismiss Defendant's Counter-Claim and enter judgment in its favor. Respectfully Submitted, MAURICE a N#] DLEMAN, P.C. Date: August 1, 2007 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 BY: Charlene Taylor Identification No 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff, V. KATHLEEN P NEECE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 07-2536 Civil Term CERTIFICATE OF SERVICE I, JOANN NEEDLEMAN, ESQ., do hereby certify that I have caused a true and correct copy of Plaintiff s Answer to New Matter and Counter-Claim to be served by United States 1St Class mail, postage prepaid upon the following: Sherri D. Coover, Esq. 4311 N. 66' Street Harrisburg, PA 17110 Date: August 1, 2007 Respectfully MAVM EMAN, P.C. C ?r_, ? ?rrz -D 721 ? €'t't C r" 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) 789-7151 I FORD MOTOR CREDIT COMPANY Plaintiff, - - V. KATHLEEN P NEECE CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 07-2536 civil term Defendant(s). PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S RESPONSE TO DISCOVERY Plaintiff, FORD MOTOR CREDIT COMPANY, (hereinafter referred to as "Plaintiff'), by and through its attorneys, Joann Needleman, Esquire and Charlene Taylor, Esquire, hereby respectfully requests this Honorable Court to grant its Motion to Compel Defendant's Answers to Plaintiffs Interrogatories and Request for the Production of Documents. In support thereof, Plaintiff avers the following: 1.) This matter stems from a Civil Action Complaint filed by the Plaintiff against the Defendant(s), KATHLEEN P NEECE and (hereinafter referred to as "Defendant") on or about May 2, 2007. 2.) On or about October 3, 2007, Plaintiff served Defendant with Interrogatories Directed to the Defendant as well as Plaintiff's Request for the Production of Documents. (See Discovery Requests attached and marked as Exhibit A . 3.) On or about November 28, 2007, Plaintiff's attorney sent a letter to Defendant's attorney, advising that the Discovery requests were overdue, and failure to respond to same by December 8, 2007 would force Plaintiff's counsel to file this Motion to Compel. (See demand for discovery letter attached and marked as Exhibit B . 4.) To date, Defendant has failed to provide responses to Plaintiff's Interrogatories or Request for the Production of Documents. WHEREFORE, Plaintiff hereby requests this Honorable Court to grant its Motion to Compel Discovery Requests. Respectfully J0 ESQUIRE fEDLEMAN, & NEEDLEMAN, P.C. Date: December 20, 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 (l1 J) /z5y-71") 1 FORD MOTOR CREDIT COMPANY Plaintiff, V. KATHLEEN P NEECE Defendant(s). 1 CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 07-2536 civil term ATTORNEY CERTIFICATION OF GOOD FAITH The undersigned counsel for movant hereby certifies and attests that: Counsel has contacted the opposing counsel regarding the discovery matter contained in the foregoing motion in an effort to resolve the specific discovery dispute at issue and, further, that despite counsel's good faith attempts to resolve the dispute, counsel has been unable to do so. CERTIFIED TO TH$, CQURT BY: XEEDLEMAN, ESQ. for Movant/Plaintiff Date: December 20, 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 (215) 789-7151 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff, V. KATHLEEN P NEECE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 07-2536 civil term CERTIFICATE OF SERVICE The undersigned attorney for Plaintiff, hereby certifies that service of a true and correct copy of the foregoing Motion was made on December 20, 2007, upon the above-named counsel for Defendant, by United States Mail, postage prepaid. SHERI D. COOVER, ESQUIRE 4311 N. SIXTH STREET HARRISBURG PA 17110 VERIFICATION I, JOANN NEEDLEMAN, ESQUIRE, hereby certify and affirm that I am the attorney of record for the Plaintiff, FORD MOTOR CREDIT COMPANY, that I am authorized to make this verification on the Plaintiff's behalf and that the facts set forth in Plaintiff's Motion to Compel are true and correct to the best of my knowledge, information and belief. The undersigned hereby makes this verification subject to the penalties pursuant to 18 Pa.C.S.A. §4904. MAURICE & NEEDLEMAN, P.C. Date: December 20, 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) /259-/1J1 _ FORD MOTOR CREDIT COMPANY Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 07-2536 Civil Term KATHLEEN P NEECE Defendant(s). PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to Pennsylvania Rule of Civil Procedure 4009, the Plaintiff, FORD MOTOR CREDIT COMPANY, hereby requests that Defendant, KATHLEEN P NEECE, produce for inspection and copying within thirty (30) days after service hereof, the documents described herein at Maurice & Needleman, P.C., 935 One Penn Center, 1617 John F. Kennedy Blvd., Philadelphia, PA 19103. This discovery request is continuing in nature and requires supplemental answers if additional information is obtained prior to trial. INSTRUCTIONS 1. Production of documents requested herein shall be made at Maurice & Needleman, P.C., 935 One Penn Center, 1617 John F. Kennedy Blvd., Philadelphia, PA 19103 within thirty (30) days from the service date indicated on the certificate of service attached hereto. 2. In responding to this request for production of documents, please set forth verbatim the request for production of documents to which you are responding and then set forth EXHIBIT your written response thereto. 3. In the event that any document called for by any of the following requests for production of documents is not produced for any reason, identify each such document in writing so as to indicate the nature of the document, its date, if applicable, its authors, if applicable, the identity of the person or persons, if any, who received the original or any copy thereof, and the reason or reasons for withholding the document from production. Additionally, any other information necessary for a court to ascertain independently the legal sufficiency of any reasons asserted for withholding a document shall be disclosed in writing. All such information pertaining to information or documents so withheld shall be furnished to the undersigned counsel on or before the time for which responses to these discovery requests are due. 4. If any document called for by any of the following requests for production of documents is missing, or has been destroyed or otherwise lost, identify it in writing, in as much detail as possible, and state the circumstances under which it became missing, destroyed, or otherwise lost. Additionally, all persons having, at any time, possession, custody, or control of such document, or copy thereof, and all persons having any knowledge of the circumstances referred to in the immediately preceding sentence shall be identified in writing, by name, title, if applicable, home and business telephone numbers. All such information shall be furnished to the undersigned counsel on or before the time that responses to these discovery requests are due. 5. Strict compliance with Pa.R.C.P. 4009 is hereby demanded. Defendant shall separately respond, in writing, with respect to each item or category contained in any of the following requests for production of documents and shall identify each document produced, withheld, or missing that is or would be responsive to each of the following requests for production of documents. In the event that you have possession, custody, or control of no documents fairly responsive to a particular request, please so state in writing as your response to that request. Please also state whether the documents that you are producing in response to any of the following requests are being produced as they are kept in the usual course of business or whether they are organized and labeled to correspond with the categories of the request. To the extent that they are not superseded by the foregoing, the Instructions and Definitions set forth in Plaintiff's Initial Interrogatories to Defendant are incorporated herein by reference. As used herein, the following terms are ascribed the following meanings, consistent with the reason and good faith: 1. The terms "Document" and "Documents" means any writing or record of any type or description, including but not limited to the original and any non-identical copy, regardless of origin or location, of any correspondence, records, tables, charts, analyses, graphs, schedules, reports, memoranda, notes, diaries, letters, telegrams, messages ( including, but not limited to, reports of telephone conversations and conferences), studies, books, periodicals, magazines, booklets, circulars, bulletins, instructions, minutes, other communications (including, but not limited to, inter- and intra-tabulations, questionnaires, surveys, contracts, options to purchase, memoranda of agreements, assignments, licenses, books of account, orders, invoices, statements, bills, checks, vouchers, notebooks, data sheets, data processing cards, recordings, wire recordings, transcripts or recordings, drawings, catalogues, brochures, all other written or printed matter of any kind, or any other and all other data, compilations from which information can be obtained and translated if necessary. Each request for a document or documents shall be deemed to call for the production of the original document or documents, to the extent that they are in or subject to, directly or indirectly, the control of Plaintiffs/Defendants. In addition, each request should be considered as, including all copies and to the extent applicable, preliminary drafts of documents which, as to content, differ in any respect from the original or final draft or from each other (e.g., by reason of handwritten notes or comments having been added to one copy of a document but not on the original or other copies thereto). 2. The terms "communication" and "communications" include the transmission of facts, opinions, beliefs, and any other form of information or expression of thought between or among persons or entities or other rendition of such information or expression of thought by a person or entity to himself, itself, or to a file. 3. The term "Complaint" means any complaint, amended complaint or subsequent amendment thereto filed by the Defendant in the above-captioned matter. 4. The terms "you" and "your" refer to the Defendants answering these discovery requests, his family members, employees, agents and representatives, including legal representatives. 5. The term "correspondence" includes letters, notes, memoranda, telegrams, recordings, or any other record of a communication or communications. REQUEST FOR PRODUCTION OF DOCUMENTS 1. Copies of any and all payments made to the Plaintiff by the Defendant, including but not limited to, copies of cancelled checks, money order receipts, etc. 2. Any and all documents you intend to introduce at trial. 3. Each and every document which relates or refers to the facts and circumstances alleged in the Answer, New Matter and Counter-Claim. 4. All statements by all parties and all witnesses, including statements of Plaintiff(s) and Defendant(s). 5. The names and home and business addresses, if any, of all individuals contacted as potential fact witnesses. 6. Any other documents or writings in your possession or the possession of your client pertaining to the subject matter of the present law suit. 7. If you have withheld any documents from your response to this Request, describe below said documents withheld and the reasons therefor. 8. Names, both home and business addresses, and reports of all expert witnesses who will testify at trial. 9. Copies of all expert reports. 10. Names and addresses of all witnesses that you intend to call at the trial of this matter (including, but not limited to factual, medical and expert witnesses). 11. Any and all documents which support your claim for damages. 12. Any and all documents which you have identified in your responses to Plaintiff's Interrogatories (Set I). 13. Copies of any and all correspondence or communication between the Plaintiff and the Defendant. Respectfully Submitted, MAVMI?E & NEEDLEMAN, P.C. LEMAN, ESQ. Date: October 3, 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 (Z 15) /89-/151 FORD MOTOR CREDIT COMPANY Plaintiff, V. KATHLEEN P NEECE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 07-2536 Civil Term PLAINTIFF'S INTERROGATORIES (SET I) ADDRESSED TO DEFENDANT Plaintiffs in the above action hereby makes demand that the defendants answer the following interrogatories under oath within thirty (30) days of service hereof, pursuant to Rules Nos. 4005 and 4006 of the Pennsylvania Rules of Civil Procedure. These interrogatories shall be deemed continuing so as to require further and additional and subsequent information as obtained by the defendant. DEFINITIONS A. "Plaintiff' refers to FORD MOTOR CREDIT COMPANY, including its agents, attorneys, representatives, employees. B. "Communication" refers to any verbal or written message and any recording of image, sound or voice, transmitted by printed word, voice, or other means of telecommunications including, but not limited to, telephone, facsimile, telex or computer. C. " Defendant", "you", or "your", means KATHLEEN P NEECE including any agent, attorney, representative, employee or any other person which has direct or had direct control over or over which has or had direct control. D. "Document" or "documents" means any written, typed, printed, recorded or graphic matter, however produced or reproduced, of any type of description, regardless or origin or location, including without limitation all correspondence, records, tables, charts, analyses, graphs, schedules, reports, memoranda, notes, lists, calendar and diary entries, letters (sent or received), telegrams, telexes, messages (including, but not limited to, reports of telephone conversations and conferences), studies, books, periodicals, magazines, booklets, circulars, bulletins, instructions, papers, files, minutes, other communications (including, but not limited to, inter - and intra- office communications), questionnaires, contracts, memoranda of agreements, assignments, licenses, ledgers, books of account, orders, invoices, statements, bills, checks, vouchers, notebooks, receipts, acknowledgments, data processing cards, computer generated matter, photographs, photographic ' negatives, phonograph records, tape recordings, wire recordings, other mechanical recordings, transcripts or logs of any such recordings, all other data compilations from which information can be obtained, or translated if necessary, and any other tangible thing of a similar nature. Each request for a document or documents shall be deemed to call for the production of the original document or documents to the extent that they are in or subject to, directly or indirectly, the control of the party to whom this notice is directed. In addition, each request should be considered as including all copies and, to the extent applicable, preliminary drafts of documents that differ in any respect from the original or final draft or from each other (e.g., by reason of differences in form or content or by reason of handwritten notes or comments having been added to one copy of a document, but not on the original or other copies thereof. E. "Oral communications" or "discussions" means any verbal conversation or other statement from one person to another, including, but not limited to, any interview, conference, meeting or telephone conversation which has been memorialized in any written or documentary form. F. "Person" means natural person, firms, proprietorship, associates, partnership, limited partnership, corporations and their subsidiaries or related business entities, and every other type of organization or entity and their officers, directors, agents, representatives and employees. G. "Identify" or "identification" means, when used in reference to: (1) A Person: (a) His or her full name and present address; (b) Occupation; and, (c) Relationship to any of the parties. (2) A document: (a) Its description (e.g., letter, report, memorandum, etc); (b) Its title and date, and the number of changes thereto; (c) The date of preparation, receipt and/or filing or other disposition; (d) Its subject matter; (e) The identity of its authority and signer; (f) The identity of its addressee or recipients; (g) The identity of each person to whom copies were sent and each person by whom copies were received; and, (h) Its present location and identity of its custodian. (If any such document was, but it is no longer in your possession or subject to your control, state what and when disposition was made of it.) (3) An oral statement, communication, conference, conversation or discussion means to state separately: (a) Its date and the place where it occurred; (b) Its substance; (c) The identity of each person making such statement, each person to whom such statement was made, and each person who was present when such statement was made; (d) If by telephone-, the identity of person participating in the telephone call, the person making the call, and the places where the persons participating in the call were located; (e) The identity of all notes, memoranda or other documents memorializing, referring or relating to the subject matter of the statement. (4) An act, action, omission or event: (a) Its date and place where it occurred; (b) Its description with particularity; and, (c) The identity of each person present or participating. INSTRUCTIONS I . The documents produced shall be organized in accordance with the individual requests made herein. Each document shall be labeled to correspond with the categories in this request. 2. This request is continuing request for all documents and information which are now or may hereafter come in your actual or constructive possession, custody or control. 3. If you do not have or cannot obtain an item or category of items requested, please so indicate in writing. INTERROGATORIES Please set forth those facts and identify all documents which are your basis for your denial of the allegations of the Sixth Paragraph of Plaintiff's Complaint, namely that Defendant made monthly payments until July 19, 2006, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 2. Please identify all persons who have knowledge of the facts which are the basis for the denial _of the allegations of the Sixth Paragraph of Plaintiff's Complaint, namely that Defendant made monthly payments until July 19, 2006, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 3. Please set forth those facts and identify all documents which are your basis for your denial of the allegations of the Seventh Paragraph of Plaintiff's Complaint, namely that as a result of the default by Defendant, and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant giving the Defendant the opportunity to redeem the Vehicle as well as notice of the sale date. 4. Please identify all persons who have knowledge of the facts which are the basis for the denial of the allegations of the Seventh Paragraph of Plaintiff's Complaint, namely that as a result of the default by Defendant, and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant giving the Defendant the opportunity to redeem the Vehicle as well as notice of the sale date. 5. Please set forth those facts and identify all documents which are your basis for your denial of the allegations of the Eighth Paragraph of Plaintiff's Complaint, namely that the Defendant failed to redeem the Vehicle and the Vehicle was sold at auction with a credit given to the Defendant in the amount of $11400.00, however a balance of $14542.60 is still due and owing, and a notice of the deficiency balance was sent to the Defendant. 6. Please identify all persons who have knowledge of the facts which are the basis for the denial of the allegations of the Eighth Paragraph of Plaintiff's Complaint, namely that the Defendant failed to redeem the Vehicle and the Vehicle was sold at auction with a credit given to the Defendant in the amount of $11400.00, however a balance of $14542.60 is still due and owing, and a notice of the deficiency balance was sent to the Defendant. 7. Please set forth those facts and identify all documents which are your basis for your denial of the allegations of the Ninth Paragraph of Plaintiff s Complaint, namely that 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. 8. Please identify all persons who have knowledge of the facts which are the basis for the denial of the allegations of the Ninth Paragraph of Plaintiff s Complaint, namely that 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. 9. Please set forth those facts and identify all documents which are your basis for your denial of the allegations of the Tenth Paragraph of Plaintiffs Complaint, namely that in addition to the foregoing, there is interest due and owing on the deficiency balance which at the time of the filing of the complaint amounted to $555.51 and which will continue to accrue. 10. Please identify all persons who have knowledge of the facts which are the basis for the denial of the allegations of the Tenth Paragraph of Plaintiff s Complaint, namely that in addition to the foregoing, there is interest due and owing on the deficiency balance which at the time of the filing of the complaint amounted to $555.51 and which will continue to accrue. 11. Please set forth those facts and identify all documents which are your basis for your denial of the allegations of the Eleventh Paragraph of Plaintiffs Complaint, namely that the total amount due and owing at the time of the filing of the complaint is $15098.11. 12. Please identify all persons who have knowledge of the facts which are the basis for the denial of the allegations of the Eleventh Paragraph of Plaintiff s Complaint, namely that the total amount due and owing at the time of the filing of the complaint is $15098.11. 13. Please set forth those facts and identify all documents which are your basis for your allegations of the Fourteenth Paragraph of Defendant's Counterclaim/New Matter, namely that on or about May 15, 2006, Defendant called and spoke to a representative of the Plaintiff's company who agreed to a payment extension due to the fact that the Defendant had been ill. 14. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Fourteenth Paragraph of Defendant's Counterclaim/New Matter, namely that on or about May 15, 2006, Defendant called and spoke to a representative of the Plaintiff's company who agreed to a payment extension due to the fact that the Defendant had been ill. 15. Please set forth those facts and identify all documents which are your basis for your allegations of the Fifteenth Paragraph of Defendant's Counterclaim/New Matter, namely that on or about June 5, 2006, Defendant made a payment to the Plaintiff company in the amount of $400.00 toward the payment of the vehicle. 16. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Fifteenth Paragraph of Defendant's Counterclaim/New Matter, namely that on or about June 5, 2006, Defendant made a payment to the Plaintiff company in the amount of $400.00 toward the payment of the vehicle. 17. Please set forth those facts and identify all documents which are your basis for your allegations of the Sixteenth Paragraph of Defendant's Counterclaim/New Matter, namely that in or about July 2006, Defendant spoke to a representative of Plaintiff company who assured Defendant that ulterior payment arrangements could be made to bring the Defendant current on the amount she was in arrears on the account. 18. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Sixteenth Paragraph of Defendant's Counterclaim/New Matter, namely that in or about July 2006, Defendant spoke to a representative of Plaintiff company who assured Defendant that ulterior payment arrangements could be made to bring the Defendant current on the amount she was in arrears on the account. 19. Please set forth those facts and identify all documents which are your basis for your allegations of the Seventeenth Paragraph of Defendant's Counterclaim/New Matter, namely that at the time of the telephone conversation, Plaintiff's representative allegedly informed Defendant that he would send information to her about the Plaintiff's proposed ulterior arrangements. 20. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Seventeenth Paragraph of Defendant's Counterclaim/New Matter, namely that at the time of the telephone conversation, Plaintiff's-representative allegedly informed Defendant that he would send information to her about the Plaintiff s proposed ulterior arrangements. 21. Please set forth those facts and identify all documents which are your basis for your allegations of the Eighteenth Paragraph of Defendant's Counterclaim/New Matter, namely that on or about July 19, 2006, Defendant made a payment of $400.00 toward the vehicle although she had not received the proposed payment arrangements, in a good faith effort to make payment on the account. 22. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Eighteenth Paragraph of Defendant's Counterclaim/New Matter, namely that on or about July 19, 2006, Defendant made a payment of $400.00 toward the vehicle although she had not received the proposed payment arrangements, in a good faith effort to make payment on the account. 23. Please set forth those facts and identify all documents which are your basis for your allegations of the Nineteenth Paragraph of Defendant's Counterclaim/New Matter, namely that without any notification to the Defendant, the vehicle was repossessed by the Plaintiff on or around July 20, 2006, despite the fact that the Defendant had consistently made payments toward the payment of the vehicle and had entered into an agreement with the Plaintiff representative to engage in an ulterior payment arrangement to bring the outstanding account current. 24. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Nineteenth Paragraph of Defendant's Counterclaim/New Matter, namely that without any notification to the Defendant, the vehicle was repossessed by the Plaintiff on or around July 20, 2006, despite the fact that the Defendant had consistently made payments toward the payment of the vehicle and had entered into an agreement with the Plaintiff representative to engage in an ulterior payment arrangement to bring the outstanding account current. 25. Please set forth those facts and identify all documents which are your basis for your allegations of the Twentieth Paragraph of Defendant's Counterclaim/New Matter, namely that at no time did the Defendant ever intend to stop making payments toward the vehicle and had made every effort possible, given her financial resources at the time, to make payment toward the debt. - 26_ - . -..Please identify-all persons -who.have knowledge of the facts which are the basis for your allegations of the Twentieth Paragraph of Defendant's Counterclaim/New Matter, namely that at no time did the Defendant ever intend to stop making payments toward the vehicle and had made every effort possible, given her financial resources at the time, to make payment toward the debt. 27. Please set forth those facts and identify all documents which are your basis for your allegations of the Twenty-First Paragraph of Defendant's Counterclaim/New Matter, namely that the alleged agreement that the Defendant and Plaintiffs representative reached on the telephone to cure any late payments was a valid oral contract between the parties. 28. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Twenty-First Paragraph of Defendant's Counterclaim/New Matter, namely that the alleged agreement that the Defendant and Plaintiff's representative reached on the telephone to cure any late payments was a valid oral contract between the parties. 29. Please set forth those facts and identify all documents which are your basis for your allegations of the Twenty-Second Paragraph of Defendant's Counterclaim/New Matter, namely that on at least one previous occasion, Defendant had entered into a verbal agreement with Plaintiff to make ulterior payment arrangements, leading the Defendant to justifiably rely on the Plaintiff's assurances that they would honor the verbal contract between the parties. 30. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Twenty-Second Paragraph of Defendant's Counterclaim/New Matter, namely that on at least one previous occasion, Defendant had entered into a verbal agreement with Plaintiff to make ulterior payment arrangements, leading the Defendant to justifiably rely on the Plaintiff's assurances that they would honor the verbal contract between the parties. 31. Please set forth those facts and identify all documents which are your basis for your allegations of the Twenty-Third Paragraph of Defendant's Counterclaim/New Matter, namely that Plaintiff breached the oral contract by repossessing the vehicle. 32. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Twenty-Third Paragraph of Defendant's Counterclaim/New Matter, namely that Plaintiff breached the oral contract by repossessing the vehicle. 33. Please set forth those facts and identify all documents which are your basis for your allegations of the Twenty-Fifth Paragraph of Defendant's Counterclaim/New Matter, namely that as a result of the alleged breach of oral agreement by the Plaintiff, Defendant is unable to maintain her normal business and transport equipment. 34. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Twenty-Fifth Paragraph of Defendant's Counterclaim/New Matter, namely that as a result of the alleged breach of oral agreement by the Plaintiff, Defendant is unable to maintain her normal business and transport equipment. 35. Please set forth those facts and identify all documents which are your basis for your allegations of the Twenty-Sixth Paragraph of Defendant's Counterclaim/New Matter, namely that Defendant has suffered damages in the amount of $2,000.00 as a result of the vehicle being repossessed. 36. Please identify all persons who have knowledge of the facts which are the basis for your allegations of the Twenty-Sixth Paragraph of Defendant's Counterclaim/New Matter, namely that Defendant has suffered damages in the amount of $2,000.00 as a result of the vehicle being repossessed. 37. Please set forth any and all statutes upon which you intend to rely at the time of trial. 38. Please identify each treatise, law review article and/or other legal publication on which you intend to rely at trial. 39. Please identify any written or oral statements (including, but not limited to, admissions, statements against interests, Res gestae, or statements which may be introduced into evidence at trial) relevant to this matter, not already set forth in your answers to these interrogatories. 40. Identify any audio recording made of any oral communications relevant to this matter. 41. Please identify the name and address of each person you expect to call as a witness at the trial of this matter and state the subject matter on which and the substance of the facts to which each witness is expected to testify. 42. Please identify each document which you expect to use during the testimony of a witness or to introduce as an exhibit during the trial of this matter, and with respect to each such document state the witness(es) through whom you expect to introduce such document and state any other person having knowledge of the contents of said document. 43. Please set forth the name and address of each proposed expert witness whom you expect to call at trial and as to each state: a) the colleges or schools of any kind attended, in chronological order following the expert's graduation from high school; b) the expert's age; C) a complete list of all articles or books published by the expert; d) the expert's employers and places of employment commencing with the expert's graduation from high school; e) any other facts on which you will rely to qualify the expert as an expert; f) the subject matter on which the expert is expected to testify; g) the substance of the facts and opinions to which the expert is expected to testify; h) the summary of the grounds for each opinion; i) detail the substance of all materials examined by the expert; D the nature and content of all facts and all materials submitted to the expert in preparation for the formulation of his or her opinions; k) attach true and exact copies of the entire report or reports rendered by the expert including copies of all preliminary drafts; 1) the--substance and content of all verbal or oral reports; M) the date the expert was first contacted by you or someone on your behalf; n) the date the expert was first retained by you. 44. State the name and address of each expert who has been consulted by you in preparation for this litigation who is not expected to be called as a witness at a trial and as to each state: a) The colleges or schools of any kind attended in chronological order following the expert's graduation from high school; b) the expert's age; C) a complete list of all articles or books published by the expert; d) the expert's employers and places of employment commencing with the expert's graduation from high school; e) any other facts on which you will rely to qualify the expert as an expert; f) the subject matter on which the expert if expected to testify; g) the substance of the facts and opinions to which the expert if expected to testify; h) the summary of the grounds for each opinion; i) the substance of all materials examined by the expert; D attach true and exact copies of the entire report or reports rendered by the expert including copies of all preliminary drafts; k) the substance and content of all verbal or oral reports 1) the date the expert was first contacted by you or someone on your behalf; m) the date you determined that you would not call such expert to testify at the time of trial. 45. Set forth whether you have obtained any statements relevant to the subject matter of this litigation from any person or persons. 46. If the answer to the precedent Interrogatory is affirmative, state: a) a) b) C) d) identify the persons from whom you obtained the statement(s); the date the statement was obtained; if written, whether signed by that person; if oral, the name-and current address of the person who obtained the statement and if recorded, the nature and present location of the recording or of any transcript thereof; attach hereto true and exact copies of each statement. 47. Please set forth in complete detail the substance of all oral or recorded statements and attach a transcript of each recorded statement. Respectfully submitted, MAURW,E & NEEDLEMAN, P.C. J Plaintiff Date: October 3, 2007 Attorneys at Law Suite 935, One Penn Center 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 te1.215.665.1133 fax 215.563.8970 November 28, 2007 Sheri D. Coover, Esq, 4311 N. Sixth Street Harrisburg, PA 17110 Creditor: FORD MOTOR CREDIT COMPANY Ref: KATHLEEN P NEECE - Account: 48063000000037004431 Balance due: $16113.07 as of this date Please refer to our file: 5188 Good Morning: On October 3, 2007, my office forward to you Plaintiff's Interrogatories and Request for the Production of Documents. Thirty days have passed and to date, your client's responses have not been received. Kindly respond to same within ten (10) days of the date of this letter or risk the filing of a Motion to Compel. Thank you for your attention to this matter. Very truly yours, ??C-l JOANN NEEDLEMAN ATTORNEY - Phone Ext: 215-789-7151 JOANN@MNLAWPC.COM EXHIBIT ?°°> t ,, `?? W FORD MOTOR CREDIT COMPANY, Plaintiff Vs. KATHLEEN P. NEECE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2536 CIVIL IN RE: PLAINTIFF'S MOTION TO COMPEL ORDER AND NOW, this 3'? day of January, 2008, a rule is issued on the defendant to show why the relief requested in the within motion ought not to be granted. This rule returnable twenty (20) days after service. BY THE COURT, ' Al Ke n A. Hess, J. 11-0 j' ?,r-- l?3iv 1 ', s ono soul jl -Q+?11 ?46-0 b JAN 842006 /Y? Sheri D. Coover, Esquire Attorney for Defendant Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500 telephone (717) 221-9400 facisimile FORD MOTOR CREDIT CO., Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS 4-9 SZ6 KATHLEEN P. NEECE, Defendant ORDER " hill" AND NOW, this 3o' day of , 2008, the tent's Motion to Compel Defendant's Response to 'Plaintiffs Discovery Requests is hereby DISTRIBUTION LIST: vd'o?nn Needleman, Esquire 935 One Penn Center, 1617 John F. Kennedy Blvd, Philadelphia, PA 19103 Attorney for Plaintiff Xeri D. Coover, Esquire 4311 N. Sixth Street, Harrisburg, PA 17110 Attorney for Defendant MNVAIASNNad 9z c wd oc wvr oooz Sheri D. Coover, Esquire Attorney for Defendant Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500-telephone (717) 221-9400 facisimile FORD MOTOR CREDIT CO., Plaintiff V. KATHLEEN P. NEECE, Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS DEFENDANT'S RESPONSE TO THE RULE TO SHOW CAUSE AND NOW, comes Defendant, Kathleen P. Neece, by and through her counsel, Sheri D. Coover, Esquire and files this response to the Rule to Show Cause that was issued by this Court on January 3, 2008 and in support thereof avers as follows: 1. The Plaintiff filed a Motion to Compel with this Court to request this Court to issue an Order directing the Defendant to respond to Interrogatory and Production of Document Requests which were propounded upon the Defendant by the Plaintiff. 2. In response, on January 3, 2008, this Court issued a Rule to Show Cause upon Defendant why the relief requested by the Plaintiff should not be granted. 3. Defendant has sent responses to the Plaintiff to both the Plaintiffs Interrogatories and Plaintiffs Request for Production of Documents. (Copies of Defendant's Responses have been attached as Exhibit 1 and Exhibit 2). 4. Defendant is not aware of the existence of any further discovery requests that need to be made in response to the requests made by Plaintiff. 5. Any other documentation pertaining to the disputed account would 'be in the possession of the Plaintiff, the creditor. WHEREFORE, Defendant requests that this Court determine that the Defendant is in compliance with the discovery requests propounded upon her by the Plaintiff and determine that it is not necessary to issue an Order to compel their response to Plaintiff s Interrogatories and Production of Document Requests. y 4 ri D. Coover, Esquire torney ID 93285 311 N. Sixth Street Harrisburg, PA 17110 Sheri D. Coover, Esquire Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500 telephone (717) 221-9400 facisimile Attorney for Defendant FORD MOTOR CREDIT CO., Plaintiff V. KATHLEEN P. NEECE, Defendant : CUMBERLAND COUNTY COURT : OF COMMON PLEAS CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certifies that on this 23`d day of January, 2008, the foregoing DEFENDANT'S RESPONSE TO THE RULE TO SHOW CAUSE was served upon Defendant's counsel via facsimile and U.S. First Class mail addressed as follows: TRANSMITTED VIA FACISIMILE (215) 563-8970 Joann Needleman, Esquire 935 One Penn Center 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 Coover, Esquire ID 93285 4T11 N. Sixth Street Harrisburg, PA 17110 Sheri D. Coover, Esquire Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500 (717) 221-9400 (Fax) FORD MOTOR CREDIT CO., Plaintiff V. KATHLEEN P. NEECE, Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS : Case No. 07-2536 Civil Term DEFENDANT'S RESPONSE PLAINTIFF'S INTERROGATORIES (SET b ADDRESSED TO DEFENDANT Defendant, Kathleen P. Neece, hereby responds to Plaintiff's Interrogatories Addressed to Defendant as follows: 1. The Plaintiff denies that at all times prior to July 19, 2006 she had made monthly payments on the vehicle. The payments that the Plaintiff made to the Defendant toward the payments of the vehicle were as follows: DATE CHECK # AMOUNT 7/6/2004 2701 $594.13 8/5/2004 2743 $594.13 9/13/2004 2773 $594.13 10/11/2004 2820 $597.63 1/7/2005 2952 $594.13 2/12/2005 2982 $609.51 3/15/2005 3030 $594.13 4/15/2005 3084 $606.01 6/15/2005 533 $594.13 7/10/2005 596 $606.01 8/12/2005 190 $606.01 9/11/2005 215 $594.13 10/14/2005 259 $606.01 12/6/2005 310 $621.39 1/3/2006 366 $606.13 3/3/2006 405 $594.13 EX 1H BIT 1 4/4/2006 Auto payment $597.63 4/18/2006 468 $594.13 6/5/2006 510 $400.00 7/19/2006 556 $400.00 The Defendant previously missed monthly payments in November 2004, December 2004, November 2005, February 2006, and May 2006. In November 2004, the Plaintiff, Ford Motor Credit, sent a letter to the Defendant that she did not have to make the monthly payments for November 2004 and December 2004 because of the flooding conditions in the township in which the Defendant resided. In November 2005, the Defendant was very ill. She called the Plaintiff's offices and a representative gave her an extension due to her illness and informed her that the expenses for that month would be added to the end of the loan. In February 2006, the Defendant called the Plaintiff and informed them that her payments would be late because she was waiting on a check from the company with whom she contracted. The representative for the Plaintiff informed the Defendant that that was acceptable. The Defendant made three payments between 3/3/2006 and 4/18/2006 to catch up with the payments due. In May of 2006, the Defendant was ill again. The Defendant called the Plaintiff and informed them of her illness. The representative for the Plaintiff told the Defendant to get the payment to their offices as soon as possible. The Defendant made a payment of $400.00 toward the payment of the van in May of 2006. Shortly thereafter, a representative of the Plaintiff called the Defendant about the account. The Defendant told the representative (a woman) that she was ill and she would get caught up on the payments as soon as possible. The representative told the Defendant that they could repossess the van, but the Defendant was not informed that it actually would be repossessed. In July of 2006, another representative of the Plaintiff (a man) called the Defendant and inquired about her payments. The Defendant told the representative that she had been ill and was planning on getting caught up with the account. The representative told the Defendant that he was going to speak to his supervisor about the account and get back in touch with the Defendant. The Defendant did not hear from the representative again. Nevertheless, she sent a payment of $400.00 to the Ford Motor Credit Company toward the payment of the vehicle on July 19, 2006. The vehicle was repossessed without any notice to the Defendant on July 20, 2006. The Defendant had planned to pay all past due monies owed that week, but did not make any further payments after the vehicle had been repossessed. Therefore, no default was caused by the failure of the Defendant to make any payments after July 29, 2006. 2. Shannon Elaine Neece 319 Second Street West Fairview, Pennsylvania (717) 315-5265 She lived up the street from the Defendant and shared the use of the vehicle with the Defendant. Vicky Helm Hershey, Pennsylvania (717) 813-9013 Contractor who worked for the Defendant. She had knowledge of the use of the vehicle and knew when it was repossessed. 3. The Defendant denies that she was in default of the agreement that she had with the Plaintiff. (See, Defendant's Response to Plaintiff's Interrogatory #1). Defendant also denies that she ever received the notice of repossession and never saw it until it was attached as an exhibit to the Plaintiff's Complaint that was filed in the Cumberland County Court of Common Pleas. Defendant therefore denies that she was ever given the opportunity to redeem the vehicle. 4. None other than the Defendant. 5. Defendant disputes that the balance owing on her contract was $26,998.14. Defendant had made payments totaling $11,603.50 toward the van (see Defendant's Response to Plaintiff's Interrogatory #1). The Defendant is in the process of locating the original contract. Defendant never saw any proof that the vehicle was sold at the auction for $11,400.00 and therefore cannot agree with the Plaintiff's allegations that the vehicle was sold at the auction for $11,400.00. 6. None other than the Defendant. 7. In their Answer, the Defendant admits that the agreement provides that the Defendant is required to pay all amounts that are due and owing under the contract. The Defendant however denies that she was in default of the contract. The Defendant made a payment toward the vehicle the day before it was repossessed. See, Defendant's Response to Plaintiff's Interrogatory $1. 8. None other than the Defendant. 9. As explained above, the Defendant denies that she was in default of the agreement between the Plaintiff and herself and therefore denies that there is any deficiency balance owing. As stated above, the Defendant thought that she was working with the Plaintiff and had made a payment in good faith of that belief on July 19, 2006, the day before the vehicle was repossessed. 10. None other than the Defendant. 11. As previously stated, the Defendant disputes the accuracy of the amounts declared to be due and owing by the Plaintiff, as described above in Defendant's Response to Plaintiff's Interrogatories # 5, 7 and 9. 12. None other than the Defendant. 13. As described in the Defendant's Response to the Plaintiff s Interrogatory #1, the Defendant called and spoke to representative (a male) about her illness. The representative told the Defendant to get her payment in as soon as possible and agreed to an extension of time for which the Plaintiff could make the payment. The Defendant never received any documentation from the Plaintiff to confirm their conversation. The Defendant thereafter made an honest effort toward the payment of the vehicle and sent the Plaintiff a payment of $400.00 in June 2006. 14. None other than the Defendant and the male representative of the Plaintiff. 15. The Defendant sent a payment to the Plaintiff by check #510 in the amount of $400.00. The Defendant is in the process of obtaining a copy of the check and will forward the same to the Plaintiff. 16. None other than the Defendant and the Plaintiff. 17. A male representative of the Plaintiff called and spoke to the Defendant in July of 2006. The male representative assured the Plaintiff that ulterior payment arrangements could be made to bring the account current. The representative told the Defendant that he would speak to his supervisor about it and get back in touch with the Defendant about the matter. The Defendant never received a return telephone call from the representative. The Defendant never received any documentation from the Plaintiff to confirm the conversation. 18. None other than the Defendant and the male representative of the Plaintiff. 19. The allegations contained in paragraph 17 of the Defendant's Answer and New Matter are based solely upon the telephone conversation that she had with the male representative in July of 2006. The Defendant never received any documentation to confirm this conversation. 20. None other than the Defendant and the male representative of the Plaintiff. 21. The allegations contained in paragraph 18 of the Defendant's Answer and New Matter are based solely upon the payment of $400.00 made to the Plaintiff on July 19, 2006 with check # 556. 22. None other than the Defendant and the Plaintiff. 23. The allegations contained in this paragraph are supported by the Defendants claims that she had consistently made payments to the Plaintiff for the van (See, Defendant's Response to Interrogatory #1) and that she had believed that she had entered into an agreement with the Plaintiff's representative that arrangements would be made by which she could make payment arrangements that would bring her account current without default on the agreement. (See, Defendant's Response to Plaintiff's Interrogatories #19 and 21). 24. None other than the Defendant and the Plaintiff. 25. The Defendant had the intention to make all payments toward the vehicle but was having some financial difficulties due to illness and the fact that she was waiting on the payment of monies owed to her by some clients. The Defendant made every effort possible to make payments toward the vehicle and to make arrangements with the Plaintiff to bring the account current, including attempting to make ulterior payment arrangements with the Plaintiff. (See, Defendant's Response to Plaintiff s Interrogaties #19 and 21). 26. None other than the Defendant and the Plaintiff. 27. The Defendant entered into an agreement with the Plaintiff's representative that ulterior payment arrangements would be made to allow the Defendant an opportunity to bring the account current. 28. None other than the Defendant and the Plaintiff. 29. As identified in Defendant's Response to Plaintiff s Interrogatory Number 1, on previous occasions, when the Defendant had financial difficulties in the past, she had been able to make ulterior payment arrangements with the Plaintiff. In the past, these arrangements had been acceptable to the Plaintiff, leading the Defendant to believe that she could justifiably rely upon the statements by the Plaintiff's representatives that ulterior payment arrangements could be made. 30. None other than the Defendant and the Plaintiff. 31. During the conversation between the Defendant and the representative of the Plaintiff, the parties discussed that the Defendant intended to come current with her payments and the Plaintiffs representative that she spoke to said that would be acceptable. He told her that he would speak to his supervisor and get back in touch with the Defendant. That did not happen. However, in reliance upon their conversation, the Plaintiff made a payment of $400.00 toward the payment of the vehicle on July 19, 2006. The Defendant would have brought the payments current, as she discussed with the Plaintiff s representatives, during the week of July 19, 2006, however, the vehicle was repossessed prior to her being afforded the opportunity to make the payments to bring the account current as she had discussed with the Plaintiff s representative. 32. None other than the Defendant and the male representative of the Plaintiff. 33. The Defendant depended upon this vehicle for her business. Her business is to perform carpet and upholstery cleaning as well as sub-contracting with Restore Core to do flood and fire restoration. The Defendant used this vehicle to transport equipment and supplies necessary to perform these jobs. This vehicle was able to transport the equipment and supplies because of its size. After the vehicle was repossessed, the Defendant had no vehicle to transport her equipment and supplies and therefore had to cancel work appointments that had already been scheduled and was unable to accept future job assignments. This is supported by the 1099s that had been issued to the Defendant for her work that she performed for Restore Core. 34. Tony Stauffer (717) 773-1053 Project manager with Restore Core. He referred the job assignments to the Defendant. Pat Brennerman (717) 232-1500 Accountant for Restore Core. Can verify that the amount paid by Restore Core to the Defendant dramatically decreased after the vehicle was repossessed by the Plaintiff. 35. As a result of the loss of the vehicle, the Defendant had to cancel work appointments and refuse offers of assignments with Restore Core for work. As a result, the Defendant lost potential wages. 36. Please see Defendant's Response to Plaintiff's Interrogatory #34. 37. Defendant is not aware of any statutes upon which she intend to rely upon at the time of trial. Defendant will update her response to this interrogatory as necessary and appropriate up to the time of trial. 38. Defendant is not aware of any treatise, law review article and/or other legal publication upon which she intends to rely upon at the time of trial. Defendant will update her response to this interrogatory as necessary and appropriate up to the time of trial. 39. Defendant is not aware of any written or oral statements relevant to this matter, not already set forth in her answer to these interrogatories. Defendant will update her response to this interrogatory as necessary and appropriate up until the time of trial. 40. Defendant is not aware of the existence of any audio recordings made of the oral communications between herself and the Plaintiff's representatives. Defendant will update her response to this interrogatory as necessary and appropriate up until the time of trial. 41. A trial, the Plaintiff may call the following individuals as witnesses in support of her claims: a) Shannon Elaine Neece 319 Second Street West Fairview, Pennsylvania (717) 315-5265 She shared the use of the vehicle with the Defendant. She was immediately contacted by the Defendant as soon as she realized that the van was repossessed by the Plaintiff. b). Vicky Helm Hershey, Pennsylvania (717) 813-9013 She was immediately contacted by the Defendant. She can verify that the Defendant used her vehicle for work and that after the vehicle was repossessed by the Plaintiff, the Plaintiffs ability to take jobs was negatively affected. c). Tony Stauffer (717) 773-1053 He was the Project manager with Restore Core. He referred the job assignments to the Defendant. He can testify that the Defendant was not able to accept as many job assignments from Restore Core after the van had been repossessed. d). Pat Brennerman (717) 232-1500 Accountant for Restore Core. Can verify that the amount paid by Restore Core to the Defendant dramatically decreased after the vehicle was repossessed by the Plaintiff. 42. Defendant is not aware of the existence of any documents which she expects to use during the testimony of any witnesses that she expects to introduce as an exhibit at trial. Defendant will update her response to this interrogatory as necessary and appropriate up until the time of trial. 43. Defendant has not identified any expert witness that she expects to call at trial. Defendant will update her response to this interrogatory as necessary and appropriate up until the time of trial. 44. Defendant has not consulted with any expert witnesses that she intend to call as a witness at trial. 45. Defendant has -not obtained any statements relevant to the subject matter of this litigation from any person or persons. 46. N/A 47. Defendant is not in the possession of any oral or recorded statements pertaining to this matter. submitted, S ri D. Coover, Esquire tomey ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 Sheri D. Coover, Esquire Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500 (717) 221-9400 (Fax) FORD MOTOR CREDIT CO., CUMBERLAND COUNTY COURT OF Plaintiff COMMON PLEAS Vi. Case No. 07-2536 Civil Term KATHLEEN P. NEECE, Defendant VERIFICATION I, Kathleen Neece, hereby verify that I have reviewed the foregoing document and all of the assertions and allegations contained therein are true and correct to the best of my knowledge, information and belief. I understand that these statements are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Kathleen Neece Date: /S r Sheri D. Coover, Esquire Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500 (717) 221-9400 (Fax) FORD MOTOR CREDIT CO., Plaintiff V. KATHLEEN P. NEECE, Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS : Case No. 07-2536 Civil Term CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 15th day of January, 2008, I caused to be served the foregoing DEFENDANT'S RESPONSE TO PLAINTIFF'S INTERROGATORIES upon Defendant's counsel addressed as follows: Charlene A. Taylor, Esquire Maurice & Needleman, P.C. 935 One Penn Center 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 Res c Ily submitted, Sfieri D. Coover, Esquire Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 Sheri D. Coover, Esquire Attorney for Defendant Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500 telephone (717) 221-9400 facisimile FORD MOTOR CREDIT CO., Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS V. KATHLEEN P. NEECE, Defendant DEFENDANT'S RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to Pennsylvania Rule of Civil Procedure Rule 4009, the Defendant, Kathleen P. Neece, responds to the Plaintiff's Request for Production of Documents as follows: 1. Attached please find copies of the Plaintiffs checks and payments made to Ford Motor Credit toward the payment of the account identified in the Plaintiff's complaint during 2004, 2005 and 2006. 2. Attached please find a copy of the itemized payment history of the Defendant's account dated October 11, 2004. Also please find copies of the Defendant's For 1099-Misc for the tax years 2003, 2004, 2005 and 2006. 3. Please see Defendant's Response to Plaintiffs Request for Production of Documents numbers 1 and 2. At the present time, Defendant is not aware of any additional documents that relate or refers to the facts and circumstances alleged in the Answer, New Matter and Counter-claim. Defendant will update her response to this Enn production of document request as necessary and appropriate. EXHIBIT 4. Defendant is not aware of the existence of any written statements by any parties or witnesses. Defendant will update her response to this production of document request as necessary and appropriate. 5. Defendant is not aware of any written documents that contain the names and business addresses of any individuals contacted as potential fact witnesses. The names and addresses of any potential fact witnesses have previously been provided in Defendant's Response to Plaintiff's Interrogatories. 6. Please see Defendant's Responses to Plaintiffs Production of Document Requests numbers 1 and 2 above. Defendant is not aware of any other documents that are in her position that pertain to the subject matter of the present lawsuit. Defendant will update her response to this production of document request as necessary and appropriate. 7. Defendant has not withheld any documents in response to any requests made in Plaintiff s Request for Production of Documents. 8. Defendant is not aware of any expert witnesses who will testify at a trial in this matter. Defendant is not in the possession of any expert reports pertaining to this lawsuit. Defendant will update her response to this production of document request as necessary and appropriate. 9. Defendant is not in the possession of any expert reports that pertain to this lawsuit. Defendant will update her response to this production of document request as necessary and appropriate. 10. Defendant has provided the names and addresses of all witnesses that she intended to call at the trial of this matter in response to Plaintiffs Interrogatories. Defendant will update her response to this production of document request as necessary and appropriate. 11. Please see Defendant's Form 1099-Misc for tax years 2003, 2004, 2005 and 2006 previously provided in response to Defendant's Request for Production of Document number 2. Defendant will update her response to this production of document request as necessary and appropriate. 12. Defendant has produced all documents that she has identified in response to Plaintiffs Interrogatories (Set 1). Defendant will update her response to this production of document request as necessary and appropriate. 13. Defendant has produced copies of any and all correspondence or communication between herself and the Plaintiff that have been retained by her. y Sher D. Coover, Esquire ey ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 Sheri D. Coover, Esquire Attorney for Defendant Attorney ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 (717) 221-9500 telephone (717) 221-9400 facisimile FORD MOTOR CREDIT CO., Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS V. KATHLEEN P. NEECE, Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify on January 22, 2008, that the foregoing DEFENDANT'S RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS was served upon Defendant's counsel via facisimile and U.S. First Class mail addressed as follows: TRANSMITTED VIA FACISIMILE (215)563-8970 Joann Needleman, Esquire 935 One Penn Center 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 submitted, . Coover, Esquire v ID 93285 4311 N. Sixth Street Harrisburg, PA 17110 Waypoint BANK vv DaW. Wyk Accoma At the time your sWanreM was prepared, 8u6 dNCk kmW was unav4WWe. U you require a copy of this dw&. please coded telephone barddng- 7106104 2697 150.00 r h., f6( POD-SO3 (2W-) • IC) ^ (Q-J 2698 a?w ?cxw ft 1? bL'? Ml?S? 1?5 ^ p? wa+« s' OJ' ?t?'i . . -C2333723B?CD7000tiiTSir 2698 100000i858D1 7102104 2698 185.80 u A GiYM ?-,I--<ot- faS" Hots - 2699 Account # 700041751 j Page # 6 -? fjj:,41'?U -[Ot-QS •?? 2703 i o{ VAM stnc? b? 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C i342?g 1COT00D4i453? 243 rD00DDi4t4ir C23L3T23B4C POQDDO it tt it Account # Page # 6 700041751 i i .ttsao 2740 118 CLEAN ACAN ,yx { Y16IfARVLW 11075 F? 1 f P=6 }; la?noNr wBC C ; Gy C23137238X07000%&?S&r 2740 r00000&4Z25r 8110/04 2740 142.25 142.41 { ocean .2735 [R C1EAW Ai.ABV a? ms 15(.71 A 1 SYFST iwaMW,M 1]01^ 11!HOJn) is f1 rig wAwroNr BANK P.?ssc??soo ?•?.?_ r,231i42387C04000ti75ir 2435 j000007t?SSr 8104/04 2735 727.55 ?` ads _l;fl&Sau 2736 1?-10t ns fLPAN «1.w sT.n M ia7S t>67 UKVlW 0 1 oq { . t? WAVPOW SAM r.23&3T23a7C0700041f5&r 2736 J000000201V 8103104 2736 20.13 ?y aisau 2737 trs CLEAN AGASYxO`A «N(i1 S T I w61 FNIWRW, M l1[QS sok13: - n.rw.n-4??i1 U OA4POMr SAM . i I I bt q!ZcCM C23&3?238TC0?00016&?Sir 2737 00000022368r 8111104 2737 223.68 ara5ao 2738 IiS CYAN ARrYN ? . ffS > A 1>1 4167 MRNRM, M 716015 a ??. wATPONf BAKK 5:2313?238?CO?000163?Sir 2738 D O 8/09/04 2738 60.46 clean ? 2741 t1s tIFAN ACI 1 ?o. sxm ?J) t C 1 9 1 y s 1 VON . 1 1? -ic?>rE?++-? ? Are) _ _ C? ?,Y kk8 1• i WA1POBfrUIII ?S i ti ! -3(pO"(t US^dj1iJ 7 ' -g23i3723a7C040004i75iB' 2747 r0pt70006i,89! 8112104 2741 66.89 tTSCLbw?#-21--Ib1-/2S- •."m 2742 .s !SOU Snm yL=-°?' w6T M0MIW, M I (?3 s X0.13 15A4POalT YI/C .C23i3?238?C0700D4i?S&V 27 2 fOOOwD20i3r w- W* Cale: ACcoLot SuA58hft Imew Document At Me tale your staWMM was prepared. UBS t?1i lack b-P wn uwvailaW Ifyou require a cepy of this check. please 80 Aw lekp _ Nick 9 r1/ 04 2743 594.13 wta>a5w 2745 Its QM ACAN V'+? 7 M 1]a5 i N0t77ir0M V . -'y 1 ( ? i° o [t r .. r.a -?. . fi r o:23&3T23a?CD?DOO16 roooooeioaor i &7Sir 27165 •I,aan 2739 77S CL MI AGUN '?ttt>t fwRYt . M 17015 a=1 wAYPOWT BANK C23&3?2387C07000%&T5&r 2739 OWOOOOLSAV 8/09104 2739 15.85 11/04 2745 30.00 v'Z wa Jp_o.t Own: r ACOOdt Subsoulp ta{Bp. Document At the time your stotement was prepared, this Ched1089e was unavailaW if you regwm a copy or this check, please contad i kmhom bBlift. 8110/04 2746 60.00 P00-503 (?. W Wa int ?¦ BAN K Member FDIC Dow CM.W ' ` W J}:o t,FwF AC SrrbsEihas Imago Docaaant At the time your stamment was prepared. this deck stage was unavailable. N you require a copy of Nis dmmk plesse canted telephone barking. Aomunt , Jr r: ?N atxw( eon Us v.4•t? GFT YOU ,.,FwF /? SUhaJ;W WNW Doamlant -1, At the lime your statwmnt was prepared. this died image., was unavailabw If you require a copy of this dwa, please conlad lel Owne barking. 9110104 2773 594.1 a„? z r r • IMS CUM AGAIN ,Mff M?YfW. M 1/l9S :aaa •, . Al c.?>.?.? s tp?eD ! \-1.t cf ?.].fA 1? f l 1 1 ['? .f1A ? ? ?o.... ®H«-." Account # 700041751 Page # 8 'c2776 U5 CUM AGAIN r wESrr tmt ? Jt wAVPOW M K C23i372387V070004375ir -2778 /'00000333844 ? 9110104 2778 333.84 o,nFOll 2779 m CLEAN AGO" .es..>. r SVKi fMp[W. M 1Tg5 CAT hCAU 0 WAWOW amt C231342387CO70004i75ir 2749 4000000201x,4 9115104 2779 20.14 v 'S 'VAVPOD" CLANK E -R-4LCEO%; K2313?238?x:0700041?510 2?71. 9107104 2774 100.00 ona+en 2775 IBS (MAN AGAIN q, F Y61 F.tlwIF\Y_ M UprS WAWOW AMK ..1_Z?s_ C23i37238?x:07000i3751r 2445 400D000iOSDt 9114104 2775 10.5( ?7 CZ ?? -lDl-l ?,++?a ITS CLEAN n 2776 ArrAaa . ,wrsxnew. M .ms ?i WAWOW WNK ` J C234372387raMOCI41?Sir 2??6 J00000t735904 9/08/04 2776 35.90 M SOA. 1•-101 l teen 2777 MIS CLEAN MAIN 0 Mom Mm. mo`? .1 ,MSFiMxMIW.M ,?, 31 4 .a..OM. sAKxc r R711--c5`fLM _ r:2313?2387C07000E.1?Sir 2?7? 40?00092i24 9/09104 2777 92.12 aoauan 2760 IIIIS Qwa,AGAaa l0 {`? S Y61 "MAW. M 1. A?.ura _i aUtPa11R &AM D?- _ _}• ` f1J.i.?.la/ r:231342384x:040001.OSir 2780 9113104 2780 33.92 {}o».?n 27ex M GEM AGAIN F VMS, FNxVIM[M 11W5 l ?S3t h?a $ WAVPOWTMW ??glSt a5 a'tr+1c? r,23i342384r,0700041T5ir 2?82 t00000i153i4 9114104 2782 115.3 POO-503 421021 CI I ITS CLEAN AGAIN p 405 HIGH STREET 7` j 025 WEST FAIRVIEW, PA 11 ?I P ay To T he Order Of 60-7238-2313 2820 ?o WAYPOINT BANK z ©! a For - - 1: 2313723871:07000405L11' 2820 v D ?r? VjWa P yP R Account # 700041751 N K E P.O. Box 1711. Harrisburg. Pennsylvania 17105-1711 Page # 3 Member FDIC vow = ? {`. D al j? W TIS CLEAN AGAIN wnwse 2958 J ? j? AOCar t ?l? , e r.laws • ?0s MW AYHI l clef MMMMlM, M ItQS I ^ .. ll] - . v u ?oew fow uz wa ?t cca (][? pp?? ??• STONStlia Mww Domment ITZ" l4oiM ?? Y At the tarle your Wlereentvras Prepared, this clack was unavallable. Byou require a copy oi8lis check. ) awt p i t 00134S 002E 012605 ?? OO }?p 9 Y 0 phase owilad teleph«ro bar"V. 14oo-u-r a Sy r \ -- -.? J.2_sl 00 s r 1( f C23i342384C07000?1?Si? 2958 JOOp000T50DJ ?, 1/21105 2952 594.13 1128105 2958 75.00 Y 4:? wi?lOl? l •? ?+ 2953 makAr+AG d" OWN S? e6r MOM. FA IMS sanrar ? s^a?. hJv I `{ Z r - 7? amwaarr MANK 42313Y23879OYO 0%17Sl1' 2953 !0000002750! 7 17/J inM 94ti14 27 511 - wass+ 2954 ffS CLEAN ??M . alAYf4aR aMl1C - _ -. =C23i3T238TC0T00D1.1?Sir 2954 1/20/05 2954 30.00 rs.sa 2959 ? FFS CUM AGAIN { tti? .il1.I..1 M?rr1.o0„j?ha? ?ar ®i? 1 WAVPMTMW --11'1, q1? 7M r.? C2333723$7CD700DS637S11' 2959 OTIM000LL2YJ 1128105 2959 66.27 2960 ITS abW AGAIN 1 VAM tmwmw. M Inn Pf ',k1f1 or. r-- . { wlelORf ?l 11=ai4oS! n cos ??A C2313Y238YC070001.iY51r 29LD 00 00130EPRI 0J 1127/05 2960 90.00 ` w+sae 2961 . nS nHw AGAIN'. ?/ y1pS(.IIMIaM1,M eRS rti?? s.`?.3?ca? ? n t vompowsw D 1?J.A?. _ ACS r . 1A r iicc Saw ?C23i34238TK04?04i751r 296i JOD00023i29r 1/31/05 2961 236.29 l fa"*- 3?j es.a^n? ? x(2955 40 "U" 511 , M lAtS .?.SiL1-s_56? 43 111i.?1.?sC?nO Co L O& WAMM EMI w. X74-1'743 nA- a4C C.. C23337238TCDY0DD1.3153r 2955 J11 rn D3843J rlsao -2956 ITS CLEW AGAIN N6T 00e1N. M 11MD M- nw s 300 0[7 r.._ . • . `' I, -.lf 4 1Ji ?r ?,? h0 Tw ar„ A V-? 111/lYPOarr SANK 22 .RI-MAlr- 42.1 02313723 mom l6i7 w 2956 wl..aa 2957 ITS CLEAN AGAIN S np 4 3 $'I ?/twoe`?A.POfZ LA M,M., 6 s>s= ( jT 098 2412895:97 Mrc ilrl+rosrr = .;.4--/ e,* 7 ?yl?t o? 10- ,238YCDYDODti3753IP C231310 2957 ODDDDDD%iaT/ w/Y.a e 2962 11S QEAN ALAN -l=..G VOWF? M 11Ma! br` 'La Irorar_ ..? '?? t?nll 1 d_ ? -,-m e n.er ®aisr IpRTOafraAlaC. t ... . ' ??pDO 1 D ..w !•C23 342384CD40001.1TSir 2962 s • . 1/26105 2962 50.0 Wauu?poiNrl?t A Aemurk `` ?? ..oow few w. wa•a? Nat ,w., n.awa. 9ubMibrU YmpM D0cmw* Af the time your statement was prepared, Slit check image was unavailable. if you Mqube a copy of oft check, piano conlad telephone ba * ft. 7 1-502(81021 wwwwauDointbank.com 1-877-SOV-BANK (1-877-768-2265) www.sovereignbank.com TOTALLY FRW CHKICH Checks Posted (Cont. for Acct# 771036558) t Check # Date. Paid Amount Reference # Check # Date Paid Amount Referettc M IF 50( $ 3027 03/10 $50.00 615936160' 36 Check(s) Posted = $4,284.86 An asterisk(*) indicates a;skip in sequential check numbers. Acp.6UM Activity Date DescEiption. Additiai?s `. Subtractions Balani . 02 `1 Beginning $2,5911 $1,804.; 02=14 PPOAssoc?a#?n / ._ ::$99:9 $1,704.; HealthCa?e Q50210 Ba3o2 afi9 4 page 4 of 10 771036558 1-877-SOV-BANK (1-877-768-2265) WWW.sovereionbank.com Checks Posted (Cont. for Acct# 771036558) TOTALLY FREE CHEClrINO Check # Date Paid Amount ?Y?"<?I k S„S ? -i Yk???Y d' FN _ RT 33 Reference # Check # 7 't Date Paid Amount Referen&o? VV.x.`03/0-a ?d ? ?G"156 3070 04/11 $316 8 3064 03/29 $200.00 v a?i 5 i `xJ? . 6 611081 10, _ 618915410 11, w ' 3066: 04/01 $ 101 70 2040 `= 3072 04/11 $4Q0,00 - ,.. 613E) # - . 641390530 3068 04101 $400.00 ` 3074 ' 6/6873010 04/1 $103:8$. x . .r,. 3 3076 . ~ 04/12 $50 00 6156 46 k Chec s Posted ? ) = $5164 59 . , . . An asterisk:(* ) indicates a Skip in sequential check numbers. Account Activity, } t Date Description 0 15 B .9 nning?Balance a4•• Additions Subtractions Baj" . $2,3$2' 03 ,1.5 _ FORD MOTOR CREDI. ; " CHECKpMTPA 031405,', $2 F.' - - 3030 . 1 Q3 15 CHECK =3034 I! i: 'Mai X4 1 t.. 03 16 CHECK 3032 ENS` 26:47 t}3-17-CHECK 3033 $.: ?$63'_6D $4 03-21 DEPOSkT V-477:07 Y 03=21 CAST-£HK 3047 ' - ?. 50:00$1 TC 03-21 4S1QP:(?AYMECT I=EE F X000004691 50 22 i CHECK 3037 l $1 5$"::t it! 03-?2t > . -CHECK ?: 3D39 :. > - $2471,50' k' 03-23 CHECK glig; 3042 . Q M.: $,1,229:44" . . Page s of ! L 771036558 1-877-SOV-BANK (1-877-768-2265) wwW.svvereignbankxom TOTALLY (FREE CHE-061 6', Checks Posted (Cont. for Acct# 771036558) i? Chock # Date Paid Amount' Reference # Check # Date Paid Amount Referenc44 , F E .3090 = Q4%22 $83 1,1111,11011 INS 3083, ':04/1.9: $17 .Q0::. 617237790 x 3093-* 04/21$6 04-18_. MORTGAGE PAYME=NT, 90 40 J + t t 4 J ' x r t CHECKPAYMT 041505 `- ?4^ z ? G-? 1 CCI 04-13 Yy 4 ,$1 t" CHECK 308(T "r"t: } ? VnI xwd4; j 'd'zr 44 4 L i_ .??f V?Itut?'s. ?1 a ri i}, 3 7 l CHEC AYMTI <i 04 2 _ DE iET;-"?} ; }?x $2?1 Q? t;;;?;? rv f ;t z t .:. nQ?G-22` , ?GASi•t CHK 0422 SN CHK 504 F x:00; ?` 1 Vii , V t VL ?"f 'I - J ' t I rLfY' page 4 of I I . t . 771036558 ?Tr?ak u? lprnfi?... rnx 14064 lllllt 111M L] Mortgage / Rem ?TraimporceBon ? Emerbunment a Travel DO NOT U S E ?Gas / Electric ?CreO card ?Medlc.W / Dental FOR REORDERING 3 66 . 0-ohone ?raxes ?Daporrkm Cam ? Food ?", Mare, AUb) [_ W^oe & kweainent []Clothing ?(M0aNft"a cs a) ?Odter BAL. FORD _ .-l J _ • 1- THIS PAYMENT r e4AllL77A? J O4R ... Elm's Mow: Carry balance forward BAL. • Check typo of expense _ / . • Add deteik: on memo lie FORD • Reim duplicates in Deluxe Check box ...?, ?. ?., L Q/ NOT NEGOTIABLE W0.Wrll1 5 ?TrackYourIrponNs•,. .• ?. rAk 14110, 11011' 11 M rl ?Mortgege 1 dent L]rranepo wiw L]Enlertelnrnenl A t,nvol DO NOT U S E 0-a socoie Elcrea Card ElMedlew / Dental FOR REORDERING (? ?. [IT.*-- DT- ?DBperxled care QF- - El ie. Auto) 08arkgs,k lrivestment -;l ` o ?(maintuwce mpruvw1wd, Omer BAL. - FORD H? THIS PAYMENT I .L ?. OTHER NOW. Wlence kxward d expelul?; - BAL. Addmenw wie FORD } . • F,etain duplicate! In Dekwo Cheek box • - .. . _. . . . ? 7dn 14 4 "`` NOT NEGOTIABLE 1-877-SOV-BANK (1-877-768-2265) www.Soverolgnbank.com TOTALLY FREE CHECKING Electronic Checks Posted Check # Date Paid Amount, Payee -Check # Date Paid, Ainount Payee 468 04/24 $594.13 FORD 'MOTOR G 3 Check(s) Posted Electronically-- $664.40 Please note: - The merchant you paid has converted these checks into an electronic transaction.,Becadse we'did not'receive the-original check or a copy of the check, we cannot provide the check with this, statement. - ?" If the check number is, zero, it means the merchant did not provide the check number in thatroper fora at Please r?fiar to the 'Account Activity' section below to locate the check number in the transaction description. /account Activity Date, Description Additions Su4ra Oeis1 Bata?ihe S 4: 04-01 Beginning Balances t :? DES? W-4 M MA ter. 0 03 HOME DEPOT/EXPO :$25,00' 2 0 9X31 ;; CHECK PYMT 060331.* 0448 <04-0% Ford'Credit F ?? ? $5J41'3 `X475 5, Auto Pymt 060403 FRDF00035556284 'r x' ,,_ 4K0 04-04 CHECK ;con 4-04 Ford Cree 3 060403 Y t #*uY FRDF0003555 285 ;04 -10 DEOSIT$637.00 4-11 CHECK 458 s $38 7Z . ?j ,alr pav;F?11 a [j MOnpaye 1 Ren1 ulrwuiwrinlion ?,?,f,Me11NNe1N/N ? TrNVN 00 'N ?Gas/SeL4io ?Creat Card ?Medkel/Dental FOR R E O R 1 ERIN 4,' , t r ?--plwrw ?f00d ?Taxee ?Dependent Care E)Insu Aft) ?SavNga 6lMrestrlreM C] ?W Home Improvemem ?(MaNtterlarlos, Repairs) ?OMe? 1 - FBAL . - t THIS PAYMENT . ` ...Flows Mow: . -:6 - Can •cant' wiance forward • Check type d expense • Add details on memo line FORD • Retain duplkates In Dehnn C heck box .. ?, ? McMO U ] ! QU `-4 11111 43 1 "a; {:'' ;, a? 2F9 Ll,? ` NOT NEGO IAB LE c 051605 nave 4 of II 771036558 1-877-SOV-BANK (1-877-768-2265) www.sovereignbank.com TOTALLY Mk. Account Activity (Cont. for Acct# 771036558) Date Description Additions Subtractions Bala, 06-16, ;`. . FORCE; PAYCHECK ?/ " $22,41 $1,824.25,. - 588 -,06-17 FORCE FLAY CHECK 5 $102.92 $1 598.36 'D?-20 FORD MOTOR CR #696 $594.13: $974:23 ;'; ' - 06/1 T ? Z.) oil -0-•,, FORCE PAYCHECK Q6-?21 , MR! $53.61 $130.22 QO r 4Q y rte' FORCE PAY CHECK $17.29 $72.93 .. . 59? - z - 07-14 Ending`Balance _ . $0.00 page 4 of 4 771036558 1-877-SOV-BANK (1-877-76&2265) www.sovereignbank.com TOTALLY FREE CHECKING Account Activity (Cont. for Acct# 921778287) Date Description Additions Subtractions Balance 07-06 CHECK 137 $70.06 $1,861.78 07-Q7 CHECK 138 w ' t}7_`11U DEPOSIT, 4 y a , µx' ,y $641.8G $2,21?64F; f? <<_. =.: ?s.. $223.95 '11,992.619 07=1 k CHECK 141 DHECK 139 $204.36 78 33„ $53.53 $1,734.80 0.11 CHECK 143 CHECK , ?K ' ';, ?' E $71:55 _ X$1,(3 3 25 .' 142:-?:..; 07.=1 CHECK 133 $18 22 $1,645 Q3 DEP.OSIT w? 7x- -?$1T 60,E ` $127 a rfi r. r . 07 14 DEPOSIT $265 00$2042 80 MORTGAGE PAYMENT `rte iy? 40 CHECKPAYMT Q75 ft f " -}'A ,r'?* r. U-t DEPOSIT K $450 00 $1,79 A0, a.,_ ly..c ..?" - 4µ,t, 6 ;: ?'_3 YM. ? ? ? r t ` ? CREI3l??t ?iG.T `?. wr,?'1}t ii?.ti i ac 'awl sue, fi • ,.,,, 731s1 , : $623 28 0'X=19 CHECK 145 $4. r t: 0 2U k CHECK. 148 $169 59 53169 71 - } 2 ,- a 5rA Yiri ?o -. ?r ;i fP 1 6 G7 i Z '?L?S!.yf'i?.Sy Srff f2t???'..?`Y 9C?. Y.. $795.00 ?? $1,240 98 fl7.25 DEPOSIT qT 2s5 "DEPOSIT` y f$512.1,8? 1: r $1, .531E ,-. 152.6 $1;6Q1 10 Q7 X25, CINGUL:AR CARE CELtCIIrAR 072205 34fj 94,52.00140 e y ??y ?T ?' K :152 ray ???'?'? ? .?? 1 .• `'.IBS 07 25 <° ., CHECK- 151 $45 7$ $1455 31 7L2 CHE K ?$2Q 66.'4' ,x'1,50 " 5 w .a $11'M05- 07 27 DEPOSIT` $400.00 y r} .¢7 .••.K n.,N .s, ?G'a C'SECfYz-???.r.l`? U`?28 € CHECK .153 $114 58 $1,89&fl5 28 ; < « ECK r i 55 w x?z? 37 59 ?i§ i 967 ?. , rOZ ,,,,2W-1,-.` 170 $22 78 $1,637 68 Ill r? ?1r ` 07-29 CHECK..:. 161 ;.$93.13 55<.07-31Ending Balance $1,42855, 921778287 page 4 of 9 f Sovereign Bank 1-877-SOV-BANK (1-877-768-2265) - vAm.sovereignbank.com Account Activity (Cont. for Acct# 921778287) Date Description' Additions 00-12. CASH CHK _ 187 N 08-"15 CINGULAR-CHECK PYMT MI - 9013,185 r, 1- 0&? 6 OHECK 72 r, 0&16 1'$6 . . :. - 0&16 AARP HEALTH CARE` - PREMIUM 3028424141 ?NCORTGAGE PAYMENT ryr? s ?? ECKPAYMT-081605 1 - F 9.11 rvl r 'D&18 {C7EPOSIT $265.00 y ti x `_ G ESC 1J? ti STATEMENT F Acc®U NTS page 5 of 11 921778287 1-877-SOV-BANK(1-877-768-2265) www.sovereignbank.com TOTALLY FREE CHECKING Account Activity (Cont. for Acct# 921778287) Date Description Additions Subtractions Balance 09-06 CHECK :. .203 $31.08 $668.20 0 WON 09-08 DEPOSIT'' $212.00 $858.01 y 09-12 'DEPOSIT $455.00 $2,314.01 ' 09=12 CASH CHK 210 $100.00 $2,063.01 09=12 ECHOSTARCOMMUNI 7.8 '+ $1,895.19 DISHCKPYMT 091105 r 0208 ;. at 09-14 gammas CAP,ITALOVE ARC $84. $1,798197 CHECK PYMT 050913 206 `09 15 MORTGAGE PAYMENT 790.40 $958 57 kt a.. 1 CHECKPAYMT 091406 , 0214 t S? i ?s `t19 1' : Q!' GULAR CHECK PYMT 183 %13 . ' $181 ?1± ' 050914 21.3 y . s v- 1 5 CHECK 217 ' 128.90 9 , ?- R . „ . ? %R1 W 0 Ma r n - ' DEPOSIT ip'"09-1 x$319.96 F $383 ??,. a 20 CHECK 218 _'. $200A0 $36391 t: ,. {.. -f O9-2q CHECK 220 $40:79 $268.12 , . x.09-21 CHECK 219 s: h $73.13' $4C1 09=23 DEPOSIT $126,14 $478.131 page 4 of 10 921778287 Sovereign Bank- STATEMENT OF ACCOUNTS , 1-877-SOV-BANK (1-877-768-2265) 'www.sovereignbank.com TOULLY FREE CHECKING Account Activity (Cont. for Acct# 921778287) Date Description Additions k Subtraitfions 4 Balance 1.4DDI ?.1V- CH s 10-18- µ FO -CH F 02, S.v IWO J. page 5 of 10 921778287 ,?v y 1-877-SOV-BANK (1-877-768-2265) www.sovereignbank.com TOTALLY FREE CHECKING Electronic Checks Posted ak Check # 'Date Paid r' AitaoL I Payee Check # Date Paid Amount- 2 ` 75 . ViwF .' y330 X113 ., 325 `_ 12/14' .gd ? 362:00;:. HOME t?EPbT: ? ? '? x a N I zy + .y ecic( )Posted El trdniicaily- 51;094.1 T 5 a n d" ?ease,nd a =w g9. i ? t 4C ' ? e ch ittiyoti paid ha co irej tecl es it Ck It t0 p nic tran§actio ecausek id, r t,?e vst& went `? v final .. + _ GnetC, wa r nnot' „e as°aco 4 s r.ti vi i@ ck r;uM in, he proper fo nat . e? feF t r . t rrc n(,mti8r ls z mews themerchant did o pr che '? ' ? to ha 'A&60 nt?A' n t eioyt+to *ate the check nurriberi tie rah iWctio sdriptrori" All t 4"QQ11`,,,,,,.,,ntt1Cu ate pt o". itf ns mice 1 y 1 `l' ,v ?i n + 'fir ?A 7.I 1 K ?t+ '4 y 1 '+I-'4 5 ,. 4 f r , x 1 ?'y. n ti? - r R- f1€_ tCSFT.'' sue: ".. .? ?4. kT yti?' is ? ? Thy ? F r Credit S 4 .Zr h :? Aao Pymt 05120 50 pF000314$5 ord Credit cony fed z , +F2F00031485509 L `" s =} IrEP IN ?F st BSc u fi h . -x:320 C ECk All 2 r ;1 1 ; DEPQSIT ,(?'?, ` 4 Y ?d -tia r e - ,{ L + ' 'F .b .,i ?•. ?? ,df .y'Ga? ?{q'i ?4 t, 't 4 ..,? +s? 4 - - c"'' 4 '?.? 1y 11 page 4 of9 921778287 FCUS Ford Credit P.O. Box 3076 Columbia, MD 21045-6076 OCTOBER 11, 2004 KATHLEEN P NEECE 405 HIGH ST WEST FAIRVIEW, PA 17025 ACCOUNT NUMBER: 00000037004431 YEAR: 2004 MAKE: FORD MODEL: E250 VIN: 1FTNE24L84HA41605 DEAR CUSTOMER: BELOW IS THE ITEMIZED HISTORY OF YOUR ACCOUNT BEGINNING WITH THE CONTRACT DATE OF 05/19/04 AND REFLECTING ACTIVITY THROUGH 10/11/04. zzzrrzz,ex***zzxs::zz*zz*z*zz*z::sz:xsz*z*z:szzz::z::::::zz:*zzszz*sxzxxz:z*xxx:*z CURRENT ACCOUNT STATUS NUM LATE LATE OTHER OTHER CURR PMTS CURRENT CHARGES CHARGES FEES FEES RATE DUE DATE REM BALANCE AMT DUE ASSESSED DUE ASSESSED DUE 8.25 11/03/04 68 32,243.64 594.13 0.00 0.00 0.00 0.00 zzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz zzzzz INVOICE TRANS DAYS TRANSACTION ---------- TRAN DESCRIPTION - --------- PRINCIPAL DUE DATE --------- DATE LATE ------------ -- AMOUNT ------------ PRINCIPAL INTEREST ------------------------------ FEES ---------- BALANCE ----- 05/19/04 29466.76 CONTRACT AMOUNT 33536.23 07/03/04 07/09/04 6 594.13 208.61 385.52 0.00 33327.62 08/03/04 08/09/04 6 594.13 361.24 232.89 0.00 32966.38 09/03/04 09/09/04 6 594.13 363.77 230.36 0.00 32602.61 10/03/04 10/11/04 8 594.13 358.97 235.16 0.00 32243.64 FCUS OCTOBER 11, 2004 KATHLEEN P NEECE 405 HIGH ST WEST FAIRVIEW, PA 17025 IF YOU HAVE ANY QUESTIONS CONCERNING THIS HISTORY, PLEASE FEEL FREE TO CONTACT US AT: ( 800 ) 727-7000. SINCERELY, CUSTOMER SERVICES REPRESENTATIVE F-1 CORRECTED fif checked) PAYER'S name, street address, city, state. ZIP code. and telephone no. 1 Rents OMB No. 1545-0115 DoubleGold Inc. dba RestoreCore $ ©O Miscellaneous Michael Goldberg Contractor 2 Royalties V Income 2322 North 7th Street Harrisburg, PA 17110 $ Form 1099-MISC 3 Other income 4 Federal Income tax withheld 717-232-1500 $ copy is PAYER'S Federal identification RECIPIENT'S identification 5 Fishing boat proceeds 6 Medica! am health care payments For Recipient number number 25-1767775 25-1843073 $ RECIPIENT'S name, address (including apt. no.). city. state. and ZIP code 7 Nonemployee. rompensation 8 Substitute payrnerts in lieu of dividends or interest This is important tax information and is It's Clean Again being furnished to 13877.16 $ $ the Internal Revenue If you are Service 9 Payer made direct sales of 10 Crop insurance proceeds . required to file a 55,000 or oxxe of consumer return, a negligence 405 High Street products ? re a ? penalty or other for le s $ sanction may be Enola, PA 17025-3104 11 12 / imposed on you / this income is taxable and the IRS Account number (optional) 13 Excess golden parachute 14 Gross proceeds paid to determines that it payments an attorney has not been reported. 75 16 State tax withheld 17 State/Payer's state no. 18 State income --------------------------- PA 25-1767775 -----.. --- - ------------- $ $ Form 1099-MISC (keep for your records) Cepar rnent of the Treasury - Internal Revenue Service F-1 vnin F] CORRECTED PAYER'S name, street address, city, state, ZIP code, and telephone no. 1 Rents OMB No. 1545-0115 Re.?toreCore Central PA $ 004 Miscellaneous Michael Goldberg Contractor 2 Royalties Income 2322 North 7th Street Harrisburg, PA 17110 $ Form 1099-MISC 3 Other income 4 Federal income tax withheld 717-232-1500 Copy C $ $ For Payer PAYER'S Federal identification RECIPIENT'S identification 5 Fishing boat proceeds 6 Medical and health care payments or State Copy number number 25-1767775 25-1843073 or Copy 2 RECIPIENT'S name, address, and ZIP code i ' 7 Nonemployee compensation 8 Substitute payments in lieu of dividends or interest For Privacy Act n s Clean Aga It 405 High Street and Paperwork $ 28538.21 $ Reduction Act 9 Payer made direct sales of 10 Crop insurance proceeds Notice, see the $5,000 or more of consumer 2004 General products to a buyer (recipient) for resale ? ? $ Instructions for Forms 1099, Enola, PA 17025-3104 11 12 1098, 5498, d W 2G Account number (optional) 2nd TIN not. 13 Excess golden parachute 14 Gross proceeds paid to - . an payments an attorney $ 15 16 State tax withheld 17 State/Payer's state no. 18 State income $ 25-1767775 ------ . -- $ PA Form 1099-MISC ® Printed on Recycled Paper Department of the Treasury - Internal Revenue Service I Z_t J; c Qcc G? I Wi: 0: L? i LU 00 T i i I UI i Q? IJ.J ? v, i ? VOID ? CORF PAYER'S name, street address, city, state, ZIP code, and telephone no. RestoreCore Central PA Michael Goldberg Contractor 232-2 North 7th Street Harrisburg, PA 17110 717-232-1500 PAYER'S Federal identdication RECIPIENT'S identification number number 25-1767775 25-1843073 RECIPIENT'S name, address, and ZIP code It's Clean Again 405 High Street Enola, PA 17025- Account number (see instructions) 15a Section 409A deferrals Form 1099-MISC Section 409A income Printed on Recycled Paper 1 Rents OMB No. 1545-0115 0 U I Miscellaneous J F 29005 2 Royalties F Income v Q U Form 1099-MISC F 3 Other income 4 Federal income tax withheld a W "= Copy C F P Cc g 5 Fishing boat proceeds 6 Medical and health care payments or ayer u O or State Copy or Copy 2 W n a 7 Nonemployee compensation 8 Substitute payments in lieu of C dividends or interest For Privacy Act = 2 and Paperwork a V Reduction Act u i 27913.3.5 $ Q a 9 Payer made direct sales of 10 Crop insurance proceeds Notice, see the ~ $5,000 or more of consumer roducts a buyer 2005 General a p (recipient) ) for resale 10- 0 Instructions for Q C C 11 12 Forms 1099, LL 1098, 5498, d W 2G TIN not. 13 Excess golden parachute 14 Gross proceeds paid to an LL payments an attorney a G 16 State tax withheld 17 State/Payer's state no. 18 State income C a --------------------------- ------ PA- 25-1767775 v. Department of the Treasury - Internal Revenue Service Z C LL C 4 r V, I ? VOID ? CORRECTED PAYER'S name, street address, city, state, ZIP code, and telephone no. 1 Rents OMB No. 1545-0115 RestoreCore, Inc. $ 006 Miscellaneous 2322 N 7th Street 2 Royalties Income PA 17110 Harrisburg $ Form 1099-MISC , 717-232-1500 3 Other income 4 Federal income tax withheld $ $ Co C ' ' py PAYER S federal identification b RECIPIENT S identification 5 Fishing boat proceeds 6 Medical and health care payrnen For Payer num er number 25-1767775 25-1843073 $ $ RECIPIENT'S name 7 Nonempioyee compensation 8 Substitute payments in lieu of dividends or interest For Privacy Act It's Clean Again and Paperwork Kathleen Neece $ 19674.84 Reduction Act Street address (including apt. no.) 9 Payer made direct sales of 10 Crop insurance proceeds Notice, see the 405 High Street oWs more of consumer 2006 General rt ye (recipient) for resale ? ? $ Instructions for Q , sta e, a IP c r?A ' N l 11 12 Forms 1099, 025-3104 o a, 1098, 6498, Account number (see instructions) 2nd TIN not. 13 Excess golden parachute 14 Gross proceeds paid to and W-2G. payments an attorney itscle ? $ $ 15a Section 409A deferrals 15b Section 409A income 16 State tax withheld 17 State/Payer's state no. 18 State income -•---•-°•••----••°--- ----•---------••------------------------ -- $ - Form 1099-MISC vr, 0 Department of the Treasury - Internal Revenue Service i, l