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Home My WebLink About07-2761ARBITRATION 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. JASON A HOWER 459 Garden Dr Mechanicsburg, Pa 17055 NOTICE You have been sued in court. If you wish [o defend against the claims set foRh 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 couR 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. ~7 ~- .2 ~4~ ~ ~ V'~ C CIVIL ACTION COMPLAINT AVISO Le han demandado a usted en la come. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted time veinte (20) dial de plazo al partir de la fecha de la demands y la notification. Hate falls asentar una comparencia escrita o en persona o can un abogado y entregar a la torte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la cone tomara medidas y puede continuar la demands en contra suya sin previo aviso 0 notification. Adernas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas Ias provisiones de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importances pars 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 SUF[CIENTE 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. JASON A HOWER 459 Garden Dr Mechanicsburg, Pa 17055 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. D'7 a2 `1 ~~~~`Z4 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, Jason A Hower, is an individual who resides at 459 Garden Dr Mechanicsburg, Pa 17055. 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 September 29, 2001, 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 $13,955.88 in order to purchase a certain motor vehicle, 2001 Ford Focus more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A, 5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $232.59 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 6. Defendant(s) made monthly payments until February 14, 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 $400.00, however a balance of $4248.88 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. The total amount due and owing at the time of the filing of this complaint is $4248.88. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $4248.88, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully submitted, M ICE N DLEM N, P.C. CHARLENE A. TAYL SQUIRE 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. TA R, ESQUIRE DATED: Apri126, 2007 O~IIO SIMPLE INTEREST PROMISSORY NOTE AND SECURITY AGREEMEN - Buyer (and Co•Buyer) Nam d A LOAN DATE e an ddress (Indudmg County and 7_ip Code) CREDITOR (Lender Name and Address) JASON A HOWE R Ford Motor Credit Company FORD MOTOR CREDIT COMPANY 179 RICHMOND RD 5700 LOMBARDO CTR N SUITE 100 RICHMOND HTS OH 44143 SEVEN HILLS OHIO 44131 44092 The words 'you' and 'your' refer to the Borrower (and Co-Borrower, if any) who signs this contract. The word 'Creditor' refers to Ford Motor Credit Company. The word 'conVad' refers b this Promissory Note and Security Agreemem. Promise to pay. You prwnlse to pay the Creditor the Amount Financed plus interest earned on the unpaid Amount Financed as set form in the agreements contained in this contred. Finance charges begin to accrue an the Loan Date shown above. Oeserlptlon o1 Property. '. T ~ , /~ ~ ~ ~ ~~ Properly NewlUSEd Year and Make uMe~ ,.,..., y NElil Ol FOCUS ITEMIZATION OF AMOUNT FINANCED 1. Amount Garen To You Directty.,»,,,,,,,,,,,,„,_, ,,,,,,,,, g_ N, A (y) 2. Amount Paid on Your Account ....„............„.... 3. Amounts Pald to Others on Your Behalf {pester may be retainin » 9 ~~_ (2) a .••»-~~ $ Portion of these amounts) To Public Ofliciats (i) for license, title & registraCron fees $ , ~ T~_ (if) for filing fees $-- ' - (iii) for taxes $ 5~ To Insurance C rfl for: $-9'Jb:'S8-"- Credl! Life Insuranoe..... .........................._............_....._.._..._. Credit Disability Insurance : ........ S-~_ ........„.......„ .... $ _. _ To for To for $ ~ ~'- To for $ S~~' T f ~• gt~nr Totaf . ~ IIEC-~..~- _ .............. N. A. ........................._.............._................._...................... -13955-8$- (3) 4. Amount Financed (1+2+3) . . .......» ............. ..._. $ . ___ ANNUAL PERCENTAGE FINANCE CHARGE Amount Total ~ RATE Finant~ed Payments The cost of your The ddlar amount The amount of credk the credo will pn ~ ya„ «~ The amount you wlu have paid when you credit as a yearly rete cost you yow behalf have made all ~~~ scheduled DaYmems ~ ._% $ ~ $ Payment Schedule - n f °f Amount of Eatch Whert Payrrtente Your payment schedule ~[' Paymer[ts - Pay~t - are due (mtxtthly stardrx 1 w3 he: t ~ a fig ~ 3 ^ .>'4 ~ P-epatrment: If you pay oft eady, You wtll not have to pay a perratly. Ser:urlt~r Ingrest: You are giving a security interest in; ^ tl1e Pr~rtY treing purdrased ~ ~~~Y ~e~a u meet pay a late charge on Urs portion of eadt ppasyment reeeivsd more than t 0 rge is 5 percent a Ina late amount w St5.00, wfrEltever b greater. dafeAtrhh~ Please see this contract for additional [nfomredan on txcudty Interest, nt, PfePaymem ~lH retpdre repayment of yow debt In tWl before the acFreduladnd Any tiurtge M tlris contrast must 6e In wrhirrg and signori by you and the Creator. -° NOTICE TO THE BORROWER Do not sign this twrttract before you read it or H it t any Wank spaces. You are entltlad to an exact copy of the Cotttrect prat you sign. You acknourlsdge ntxelpt of a Mue and tmtrlpbtety filled in copy of this tmntreot at the time ~ signing. You authoriaoe Pte CreWtor to dlstwrae funds as apeciflad above in the Itemization of Amount Financed, ~ /A=3 J fY~ 3.yy BOROtlYer ~~ (Co) Borrower Signs i76~s61 Oat GO (Dnrbw Weee mq N07 tM urtM.l 313618248454 ~ ~ Pereonal OAgdeueurel ^ Commercial INSURANCE PROPERTY INSURANCE MAY BE OBTAINEp FROM A PERSON OF YOUR CHOICE. INSURANCE DOES NOT COVER PERSONAL LIABILITY AND PROPERTY DAMAGE CAUSED TO OTHERS. CREDIT UFE, CREDIT DISABILITY AND OTHER OPTIONAL INSURANCE ARE NOT REQUIRED TO OBTAIN CREDIT AND WILL NOT BE PROVIDED UNLESS YOU SIGN AND AGREE TO PAY THE PREMIUM. []Credit Life Insurer $ ar, n. Premium Insureds) O Disablity Insurer Premwm Insured $Ign8tUr8 Type of Insurance Term Insurer $' p~ Signature credit Life and Credit DlsabtGty kraurarrce are for are farm d the contract, me amoum and coverages are shown In a rtodce or agreement ghran to you on this date. Optional Crept Meurance Cancellation Rlgfd. You have the right for twerdy-five days tram the date of dris contract b cancel as credit Nfe and credit disability, accident and hteaNlt Insurance obtained at your request in conrredan w~itr aria oetttraet. tt you carroet the irrsurarrce, You wA receive a full refund of the Inaurarrce premkrm. To cancel, You must give a wmlen rrotke tp itte Credaor and return all credit intwrarx:e parldea of certificates, or rrotlces oT ProP~ed credit inaurence to the Credftor within the twenty-flue days. QUESTIONS? PLEASE CALL US AT 1-BOa727-7ppD SEE BACK FOR ADDITIONAL, AORt?EIfENTS ~~~ EXHIBIT ADDITIONAL AGREEMENTS A. Payments: You must make elf payments when they are due. You may prepay your debt at any time without penalty. This is a simple interest contract. Tht;~actual finance_chatge you agree to chargellmay exceed herd~§closed'Fnance Ch~geCtfyou eke your payment§'later than the scheduled dates of in iess`ttiaA•the scheduled amount. Your payment will be applied first to the earned and unpaid pert of the Finance Charge and then to the unpaid Amount Financed. The Finance Charge is earned by applying the Annual Percentage Rate to the unpaid Amount Financed for the actual lime that the unpaid Amount Financed is outstanding. B. Security Interest: You give the creditor a security interest in: t. The property and ad parts or o'tfiei goods ptit'oh the property, 2. All money or goods received for the Property, and 3. AN insurance premiums and servbe contracts Ilnartced for you. This secures payment of all amounts you owe in this contract. It also secures your other agreements in this contract. C. Use of Vehicle -Warranties: You must take care of the vehicle and obey ell laws in using it. You may not sell or rent the vehicle. You must keep d free from the claims of others. You will not take the vehicle outside of the United States for more than thirty (30) days without the creditor's prior written consent. if the vehicle is of a type normaity used for personal use and the Creditor, or the vehicle's manufacturer, extends a written warranty or service contract covering the vehicle wlthlft 90 days from tfte date of this contract, you gat ~[mpiit:d warranties of merchantability and fitness for a particular purpose covering the vtettlcfe. Otherwise, you understand and agree that there are no such implied warrantiesc .:' D. Property Insurance: You must insure yourself end• the Creditor against loss or damage. to the vehicle. The Creditor must approve the type and amount of insurance. Whether or rtot the vehicle is insured, you must pay for it if it is lost,_darriagecf or` destroyed. ~ '; :.'i E. Late Payment: You will have to pay a late charge on the portion of each payment received more than ten days late. The charge is shown on the front. You must also pay any costs paid by the Creditor to collect any•tate payment, as allowed by taw. Acceptance of a late payment or late charge does not excuse your default or mean that you can keep making payments after the ea s any defauftr The Credit may sue you ttoo collect the amount you owe under this contract or to obtain possession of the property after default You must pay any cost or disbursement that the Creditor is entitled to by taw should the creditor sue you. :a~~; F-~ Default: You will be in default iF. You do not make a payment when it is due, You gave false or misleading irtiormation on your application relating to this contract, You do not keep enY Promise h this contract, ., , , You file a bankruptcy petition or one is filed against you; or Your vehicle is seized by any local, state, or federal authority and is not promptly and unconditionally returned to you. If you default, the Creditor may require you to pay at once the unpaid Amount Financed, the earned and:~npaidtp;Brt of•the Finance Charge and all other amounts due under this corit~act.•! Me may repossess (take back) the property,, too. He may also take goods found in the property when repbssedsed~and~Mold them for you. ,_. - If the property is taken back, he will send you a notice. The notice will state that you may redeem {buy back} the property. It will also show the amount needed to redeem. You may redeem the property up to the lime the Creditor sells it or agrees to sell it: If you do not redeem the property, it will be sold. The money from the sale, less allowed expenses, will be used! to pay the amount still owed on this contract. Allower( expenses are costs or disbursements which the Creditor is•1s'ntitled to by law in connecFan with any: 7,:- 1. Suit to collect the amount you owe under this contract; ~ or 2. Lawful activity to obtain possession of, and dispose of,' the property after default. (f there is any money left {a surplus), it will be paid to you. If the ~ money from the sale is not enough to pay off this contract arx costs, you will pay what fs sttfl owed to the Creditor if allowed b~ law. _ _ G. General: To contara Ford Motdr Credit Company about thi; account, calf 1-800-727-7000. The law of Ohio applies to thl; contract If that law does not allow aU the agreements in this contract, the ones that are not allowed will be void. The rest o' this contract wfU still be good. H. Payment Deferrals: You may be able to deter a payment 1 the Creditor agrees. However, interest will continue to accrut until the next payment is received. Any deferral would not extent any Purchased insurance coverage you may have. FTC Nonces NOTICE -ANY HQLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST' THE SELLER OF GOODS OR SERVICES. OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR, HEREIMnrn • t _ 'Does not aPPIY H loan proeeeda are used for commercial c r agricultural use. In that case, You (dsbtoe~ wdf not assert agslm t the Creditor or any assignee or trirbsequant holder of pits Comrm t ,, any Natma, defenses or setoffs tahich you may have atfeinst Ill's . •aeller.w manufacturer of the property. ~ :._ ,. cuaRarfsY -- To cause the seder b sap dre property deacdbed on the ~mtry mfails tCOrWect ~ ~ ~Yer. ~ C/edit, each pereorr wtro siyrra below ee a 'Guararrlor' guar- antees are payment of this cornratd. This meanB that if Ute 8 will pay d when asked. Each pereori who td below ICY any money Brat is owed on eNS . trash one who etgns as a tararanta this Otraren . Ne also ~° ~~ that he will be dtdxe for ttre while amount owed even if one or more other parsons abc PBYmeme, or (b) gives a release in lud a inn paw ff -he Creditor does orw or more of ttre fodowtng (e) gives tya BtrYer more time to pay orw or more received a completed copy of ttds contract and Nib Cwaranty et the dma of sing, (c} uses any security. Each Guarantor also states that he has Guarantor 3uarantor Address Address .•-••,, ...., w rnenam ewa~a may rrDr fb used) 1 FC 17634-g1 OCT 00 ••"PRN'•` Ford Motor Credit Company P.O. Box 17948 GREENVILLE, SC 29606-8948 (877) 805-7187 P051 HT00200031 JASON A. HOWER APT 1 347 E BURD ST SHIPPENSBURG PA 17257-1461 NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. ~x PRNATE SALE: We wiU sell the property descrited above al private sale sometlme after t5 days irom 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 higtlest bidder on the date bekxv (or erry adjaxrunent date). Tha sale will be held as fellows: Date of Sale Time of Sale Place of Sale You may attend the sale and bring bidders if you want. The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To team the exact amoulrt 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 uncle your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. NOTICE OF REPOSSESSION The property is presently stored at: BUTLER AUTO AUCTION 21095__ HOW TO GET YOUR PROPERTTY B ECKY TwP PA To get your property back, pay us this amount by certifred check or money order before the vehicle is sold. Unpaid Balance $ 3954 Plus Costs: Repo Expenses $ 399 ~ ---__ $ $ Pkrs Late Charges $ ~ ~ Less Finance Charge Ret1~e $ Less Insurance Premium Rebate $ TOTAL $ 4,383.03 (Plus expenses incurred if deteuU at the time of repossession exceeded 15 days and less rebate received after the date of this notice.) Your property won't be sob until 15 days after the date of this notice at the EARLIEST. After that you can slip get U beak any lima before irs actually soa. fl you do, we'll have no hxtller claim on U. But the longer you waU, the mare costs (kx:luding repairs) you may have to pay. If you have arty questions abotrt thks, please caN us. ^ The property h~ bean (or wiU be) returned to: Under our agreement with your deatxloriginal creditor, the dcelerkuiginal creditor is to sell the property and pay you (/od~~ ~) after the sale, you wUl pay U to the de~erfidginal creditor. arty money left over. If you owe ~ceY ^ PERSONAL PROPERTY: Any personal Property found in the vehicle may be reclaimed by you wdhin the next 60 days or, in acwrdarxx with state law, by corltactlrtg thb office. Thereafter, the personal Property shall be disposed of accorringly. ^ Credtor has assigned to its quapfred Intermediary (OI Ext~ange, LLC) its rights (brA not its obllgattons) with respect to the sale o} each vehicle Us6ed above. PAYMENTS: AU payrlems to us must be by oradfied check or ~~, ~. MILEAGE DISCLOSURE: If you are aware that the mil~ge reUeded on the vehiGe's odometer is not accurate for any reason, please contact us so tflat vre can accuretely report the vehk:le's mileage INSURANCE RICiHT3: If you donY want to get your has been cancelled. You have a rlgM to get credU for allali prerntum r~undl s~ Inarance canpany or the dealer/original creator to make sure that any insurance FELICW M. SMES FFNA 1198837 Jan 02 p,avbea atl8bns mat, NOT be used PrinpW in U.SA. CUSTOMER/Ct13TOMER FILE EXHIBIT ..~::'~;3~' :lil.lk •~• ~(" s : :It~ d~ ' :.t~.jf /:r;~4 'I - iI+~C>~: tl.!a' 7 ttl; .' ~ :~ . i'I .~.:~ ~'t ~ :.t 1 - ( 1' ~.. (( j .~: +J ~' y ,t (i~ ' lil" ~ (• , ~ , .p y~~ ~ ~' ''I::• -'~; v :n.' .t Jj y f .,1 , ,' 1' S • 't • ~~ ..~, i•: .t• +9 .~ , 1 : ~. i ., ., , .',.. ~E •fjli +II:', ~' ~; i; . ~f ! , ~~ ..ro , +; (r" :i• . •1. ~~ ti' ifi , ,:F ,.~ , 'ro' • f :D '! : j. ~~.. ~' '~g~ 1' y~ F :IM l a f ~~ ~'1: ~'I'~I NF's f"f~::Q .ti~ jf. ,' 'S ~~• .t• .,I~ •~ {[; .,~i, SFr :~ , ;+1~r •~ ~. i :I .j; ! •.. {. I~ ~ Ir ~ r ~ d~• ii~l ' ~:,~'~,'>a~,' °;'~s, X~!% '~9 F 1 ~, i ;t~.~! y"i~j~':~"~j~. ,:f, ~ p, ' fl"i~:il ~ ~ ,F:k" .1; ' ~ } I r411 I y !:' r{r 'il ;}t'~S ~»I,•~r~ !~ '~ (r , - ` i , ,1 F F ! 'I 1 I ~ i ~ t , ! p 1:.; ' .'t E :' .M::: ~~^ f. .>?l~~:;h. ^.i~ v(., ~~:f•: ,I,.jF~fj ~,,, F u+lf .jo~(;;y,;;.i47 f, ~~§; ;.f'r•- .....- •'R~'}n il;i:i(6 i'ff;;'o r;f:': l~~'i:, rl:y; a: ,:(,. Name and Address of Sender Check type I a ssrvl .. _.. _ . ._, .:.r ;;y~li ce. AfRz Stamp Here ~.BSOn ~j~ ^ R adDeM Imernelbnel (aheeedese ^ COD ^ b~rod MY f ) r:eM,teats olmeF6p, / 38120 Amrhetn ~ ^ Ixu~.nceerom.lw,~ wm..e,,,rra„t - 48150 ^ ~"B••s'w ~F~•n Repw wrM«eh..a.. «wNwmn e4~ ~Y,~ F] Inwres epneuse Cansrrnaeoe Pgtfm ti ~~ . Atfli:le ('N,m6er Addasr O~ SOSK OMy, SIW. 6 DO ~ f l ~„ 1 ~ HentlNsO ~Me~ F Nraed OurcC~ OC SC BH +/ Fee FM FN F»' F .~j t ~ - !-- 00522/20575202 ~ I _ _ - ~; 00522/20575198 _ _-- AV.032135875 70D6 oZDD ODOD 5453 8339 AV•o3779757s 7DD6 OZ00 0000 5453 8377 SHAWN 0. DILLER I ~ MAMA'S PIZZA INC _ 1930 35TH ST j 411 BEECHWOOD DR _ CUYAHO - . GALION OH 44833-1403 ~~`-""---- GAFALLS OH 44221 3 - ~_ uuoeu[uDiae~o " ,. ~ 00522/20575199 - AV-032145690 RONALD MORGAN AV-036574708 -_-'_--~ - - 2236 EASTON ST NE 4 : RICHARD A. CILENTI 7006 DZDO DODO 5453 836D _ _ CANTON OH 44721 I 9016 MERCHANT DR. - 7DD6 DZDO ODDD 5 `: STREETSBORO OH 44241 _. r X53 83 2 D7 --- ~ _ ' S. 00522/20575200 ~ ------ ' ~ ~ ~ ~ _ AV-034881884 _ U052y2Q575204 ----`----- AV-028964383 VERSATILE IMAGING CO "---- JASON A, ROWER ~ m 4119 WHIFFLE AVE Nyy C ~ I Y I 8. CANTON OH44718 --- ..._ APT 1 ~ 7DD6 OZ00 GOOD 5453 8353 347EBURDST 7DOb OZDO DOOp 5453 8315 - ' SHIPPENSBORG PA 17257-1481 . ' 00522/20575201 '-----"--- ~ y AV-035411218 ---- ~-~' 7• VERSATILE IMAGING CO INC ~~-. b a ' 4119 WHIFFLE AVE NW #D ~ CANTON OH 44718 ~ 'y a_ = - -=_-_____---_ ( sir '~~ , 7DD6 DZOD DODD 5453 8346 t I =- v 7oW RUbardpteaw To41tMEerdPbas PMCIIpdy per (Netrr er I sp$ ' Llwe Eysender ,neosir.a a Frost oaks "`µ"'O - ~ ~. ` _ no r..~ aos+ ._,._.__...,,,,, . - _- • .. _. 3~a Aet Stalernent on Revenls - ~• "3 - . Jul 27 2006 9:07RM Ford Motor Credit 864-254-5738 p.l ~OR~ A~DT~OR ~~ PO Bt~C 1 ~9~3 GREEt~la'i, .sc BATE: JULY 26, JA50N A. HOWER 347 E BURD ST AF SHIPPENSBURG, f 1 17257-1461 STATEMENT Otr SALE Account Number: 289 4588 The foNowing property as been sold. Year Make Model Vehide Identitication Piumt-er. 2001 FORD FOCUS 3FAFP31361R248454 Gross balance Awing o your contract (1) $ 3984.t~3 Deduct: Finance Char a Rebate (Z) $ Otl Balance owing prior to ale {3) $ 3984.03 Deducts gross procee fi3 of the sale (4) $ 400.00 Balance less gross pro ads of the sale (3 - 4) {5) 3 3584.03 Add: Expenses of rata ing and storing, and (s) $ 684.85 arty atbomeys' fe s allowed by taw, and expenses of retso ditioning and sailing. Deduct; Insurance Pre iurn Rebate (7) S OtJ Other: (8) 3 0Q Defiaency'w (9) $ 4,248.88 Surplus" (10) $ ~ The Surplus/Deficiency wil added to ur account de change based on monies Its . received by us (credits) or additlonfisl allowed expanses & interest Surplus' or Deficiency"* ff the Sate resulted in a u " r~us, a refund for the difference wiM be mail d t If the sate resulted in a e fficiency, yot, should imm ® o you. ediately remit the amount sho Payments shown bebw wn on {fin e s to the address for For additlonai informatlo FORD MOTOR CREDIT C M call or write: PAPIY Mall Wflclency payment to- f'O BOX 6508 FgRp MOTOR CREDIT COMPANY MESA, AZ 85276-8508 PO BOX 56000 800-732.2294 DEPT 184101 DETROIT. Mi48256-194f FFn~'17980 O~Aq FroNOw BdkbM may N hs utatl EXHIBIT ~ '69. ~ ~~ ~ -rt ~ ~ ~ ` "_ ,+} ~ ~~~ - ~ -r-~ r^ ~ _ -, w7 - r-. -:~ ~; ~ _ !V _r ;~' `;^~ j `~' SHERIFF'S RETURN - REGULAR CASE NO: 2007-02761 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS ROWER JASON A BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ROWER JASON A the DEFENDANT at 1954:00 HOURS, on the 14th day of May 2007 at 459 GARDEN DRIVE MECHANICSBURG, PA 17055 by handing to JASON ROWER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.48 Affidavit .00 Surcharge 10.00 00 s~~o~o ~ ~.. 0 8 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 05/16/2007 MAURICE & NEEDLE]Y~AN By: day A.D. Deputy S