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HomeMy WebLinkAbout07-5755 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 LLC, A CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMPANY COMMON PLEAS P.O. Box 6508 Mesa, Az 85216-6508 Case No. 47_ 5f755 aivi( lem Plaintiff, V. SHAUN M YOUKERS 1810 Willow Rd Camp Hill, Pa 17011 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CIVIL ACTION COMPLAINT NOTICE AVISO You have been sued in court. If you wish to defend Le ban demandado a usted en la torte. Si usted quiere defenderse against the claims set forth in the following pages, de estas demandas expuestas en las paginas siguientes, usted tiene you must take action within twenty (20) days after veinte (20) dias de plazo al partir de la fecha de la demanda y In this complaint and notice are served, by entering notificacion. Hace falta asentar una comparencia escrita o en a written appearance personally or by attorney and persona o can un abogado y entregar a la torte en forma escrita sus filing in writing with the court your defenses or defensas o sus objeciones a las demandas en contra de so persona. objections to the claims set forth against you. Sea avisado que si usted no se defiende, la torte tomara medidas y You are warned that if you fail to do so the case puede continuar la demanda en contra suya sin previo aviso o may proceed without you and a judgment may be notificacion. Adernas, la cone puede decidir a favor del demandante entered against you by the court without further y requiere que usted cumpla con todas las provisions de esta demanda. notice for any money claimed in the complaint or Usted puede perder dinero o sus propiedades u otros derechos for any other claim or relief requested by the importantes para usted. plaintiff. You may lose money or property or other rights important to you. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION FIND OUT WHERE YOU CAN GET LEGAL HELP . 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 ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff (21J) /uy-/101 - FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. SHAUN M YOUKERS 1810 Willow Rd Camp Hill, Pa 17011 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. J'7- 59 -6y ('c;-c.! -7?---- CIVIL ACTION COMPLAINT 1. Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A Delaware Limited Liability Company, is a Corporation with its place of business at P.O. Box 6508 Mesa, Az 85216-6508. 2. Defendant, Shaun M Youkers, is an individual who resides at 1810 Willow Rd Camp Hill, Pa 17011. 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 18, 2006, 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 $23266.56 at an annual percentage rate of 17.340%, in order to purchase a certain motor vehicle, 2006 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 $281.48 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 August 10, 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 $9800.00, however a balance of $3203.76 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 $391.75 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $3595.51. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $3595.51, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully submitted, MAURICE & N 6EDLEMAN, P.C. CHARLENE A. TAYLOR, ESQUIRE Attorney for Plaintiff VERIFICATION I, CHARLENE A. TAYLOR, ESQUIRE, verify that I am the Attorney of record for Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY 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. TAYL. , ESQUIRE DATED: September 21, 2007 Do not sign this contract In blank. You are entitled to an exact Copy of the Contract that you sign. Keep It to protect your legal rights. ear.rtl ' ? 'A Coe,m, X afar. «w Buyer (and Co-Buyer) Acknowledge that (1) before slonfno this contract. Buyer (and C"uyer) reeafved and reviewed a true and completely ed in copy of this contract and (U) at the ame Of elonilm this contract, Buyer (and Co-Buyer) received a true and completely filled In-am Warls contract. 1 71118 CONTRACT IS NOT VAUD UNTIL VOU AND SELLER SIGN rr. ASSIGWMMff BYr brr brrfa Wr mesr b rellw pr? T a" Sror.rlp?Ab??aayireb?wemagb END ROTOY mM."[ORDCRADIT con .H1 .• no p- Mr 1a. hb. r SMI1Ir N/b, PNMarh nr HmNYa Ar WrnY adm aw CREDIT Comm CA P.^ 1-BOO-777-7000 r r + 6Ylrf B SHIM EM ITC M - rm. 'J ` q rrr?wrrwl Sea onam am FOR ADnrnOrrL AORErAS:Nre wniaM. ORKMAL EXHIBIT A Q ?Y YOU ACAAIDYVLaUOE THAT YOU NAVE FW" AND AGREE TO BE BOUND BY THE ARBITRATION PROVISION ON 1 THE REVERSE SIDE OF THIS CONTRACT. III T11a MmW Parwntag. !tale may b. MSIIBa1ad ant Me S.Iler. The Seller may aalpn Uds contract and may r.IWn as dent m reC.Ne • aeraarl M 111. yianrs [Jur'.a "'PRN"' Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631.3111 (677) 349-5260 P0631100200005 SHAUN M. YOUKERS 1810 WILLOW RD CAMPHILL PA 17011 Date of Repossession 08-17-2006 Date of Notice 08-19-2006 Date of Contract 05.18-2006 Account Number: 040791760 Buyer SHAUN M. YOUKERS Cobuyer DESCRIPTION OF PROPERTY Year 2006 Make FORD Q New ? used Vehicle Identification Number. iFAFP31N36W153534 Model FOCUS Body 3DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. Q PRIVATE SALE: We wilt 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 adjournment date). The sale will be held as follows: Data or Sale Time of Sale Place of Sate You may attend the sale and bring bidders if you want. NOTICE OF REPOSSESSION The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) will reduce the amount you owe. If we get less money than you owe, you will stilt 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 fallowing people who have an interest in the property described above or who owe money unde your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. The property is presently stored at: MANHEIM AUTO AUCTION 1190 LANCASTER ROAD HOW TO GET YOUR PRIIDRItilMIBACK To get your property back, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance - - - $ 12,605.66 Plus Costs: Repo Expenses $ 200.00 $ Plus Late Charges $ 5.63 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 13,011.49 (Plus expenses Incurred if default at the time of repossession exceeded 16 days and less rebate received after the date of this notice.) Your property won't be sold until 16 days alter the date of this notice at the EARLIEST. After that you can still get It back any tine before irs actually sad. If you do, we'll have no further claim on ft. But the longer you wait, the more costs (rduding rapers) you may have to pay. If you have any questions about this, please call us. ? The property has been (or will be) returned to: (dealerlorignal creditor) Under our agreement with your dealerforiginal creditor, the dealer"inal creditor is to sell the property and pay you arty money left over. If you owe money after the sale, you will pay d to the dealerloriginal creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with slate law, by contacting this office. Thereafter, the personal property shall be disposed of accordingly. ? Creditor has assigned to its qualified intermediary (OI Exchange, LLC) its rights (bud not its obligations) wth respect to the sale of each vehice fisted above PAYMENTS: AN payments to us must be by cwgied check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer is not accurate for any reason, please contact us so that we can accurately report the vehicle's mileage. INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealerioriginal creditor to make sure that any insurance has been cane led. You have a right to get credit for all premlum refunds. _ CAROLYN L. CASSICK EXHIBIT 1e5e37 can 02 Previwa edidwrc may NOT lr usetl. CU8TOMERlCU3TOMER FILE PrinW Printed in USA -r ;, + r ' t 1111 ) 4 1 ?; ?, !r r.k ' ? r f ! ? I}', I {t t t , ? ill, ; I:r:;E: {„I tF[t t sssl, ? M;+ 1??tii ll. ??i),. IM Ir, f•)•rr.i+:+., tads .( r?- y?'t1t1Y, Ilj l Il • 1 . EI{ r1 1r+ (u Z" ,l )? i ? j; ,? 'f???(.;1•e'; i !1'?? 1i• •kt . { ry Name and Address of Sander Check type or service: 1A1liz Stamp Here ('?' /? CanMed O Recorded Delivery flnlernadorwl) frcudecersdme!'1nA AV V 1 9 zO1 H1 Lason a COD 0 Raphwrea aM1raddaoner 38120 Amrheln 0 DsllvaryConMmatfon 0 Rehm ReeNpt for Mwhandlee ctplesorthf-biv [] Express Map 0 stpneture Ccnnrmou" Postmark and ??}y,?p(a M1 48150 inured OsfeolReoe f w sesee (fMre, Street, Ow. Sds. 6 APO ode) P-1008 Fee „ ? Aaue1 Vatua Insured Doe t Chetpa HR Idsrad Value MO 7006 0100 0007 2769 1064 -- _( U0818=686534 SP-030635435 JEFFREY M. POWELL C O NILES V POWELL PO BOX 262 EMLENTON PA 16373 00818/20586535 MA-039960340 ` RUSSEL L. SMITH JR 3813 LOCHEARN DR GWYNNOAK MD 21207 18/20586536 MA 040791760 SHAUN M. YOUKERS 6 1810 WILLOW RD CAMPHILL PA 17011 U0818/20SM37 MA-035769854 '- BRIAN R. GREENWAY 421 LARRY DRIVE 8 HARRISBURG PA 17109 s„ F U0818120586538 700 ( I - P-040504490 6 0100 OQ07 2769 1101 -- IVAN MARTINEZ _ APT. f 11 7006 0100 0007 2769 1071 - - 141 CHERRY ANN ST. L _ HAMDEN CT 06514 ?, U0818120586539 I CF411- 7006 0100 0 007 2769 1118 REBECCA TREMARKI C C 0 220 LAWNTON RD WILLOWGROVE PA 19090 ae 6 7006 0100 0007 27691(88 -I /??- --! c c '.° 1 = 1 y ' 7006 0100 0007 2769 1095 Lhda by Sadder Redalved at Pod Olllce I ?N vp? See Privacy Act Statement on Reverse PC Frvrn 3R77 Fs nr onr» ro?..n r ..? 7f CmnnlaM M TvnewlMr Ink. nr Rdl plltnr pw ? Ford Motor Credit Company P 0 BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2006-10-18 P06XDB00000081 SHAUN M.YOUKERS 1810 WILLOW RD CAMP HILL PA 17011 STATEMENT OF SALE Account Number: 040791760 The following property has been sold. Year Make Model Vehicle Identification Number: 2006 FORD FOCUS 1FAFP31N36W153534 Balance owing on your contract (1) $ 12,811.49 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 12.811.49 Deduct: gross proceeds of the sale (4) $ 9,800.00 (5) $ 3,011.49 Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and (6) $ 592.27 any attorneys' fees allowed by law, and expenses of reconditioning and selling. $ 0.00 (7) Deduct: Insurance Premium Rebate (8) $ 0.00 Other: (9) $ y 3603.76 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 MESA ARIZONA 85216-6508 DEPT 194101 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 EXHIBIT 1 FFNA11M 01104 Previous editions may NOT be used. i C? 1 CID _v Cu -C O SHERIFF'S RETURN - REGULAR CASE NO: 2007-05755 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY LLC VS YOUKERS SHAUN M KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VnTTVT4T?C CTJLTTKT M the DEFENDANT at 1949:00 HOURS, on the 9th day of October 2007 at 1810 WILLOW ROAD CAMP HILL, PA 17011 by handing to ROBERT A YOUKERS FATHER 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: So Answers: Docketing 18.00 Service 14.40 ` 4iyrhGt? Affidavit .00 7 Surcharge 10.00 R. Thomas Kline 9- 1f jo(f b7 .00 ? 42.40 10/10/2007 MAURICE & NEEDLEMAN Sworn and Subscibed to By: 1/1 before me this day De y Sh f of A.D. MAR 1 9 2008 641 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 (2. 15) '/Z59- / 161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff I V. SHAUN M YOUKERS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-5755 CIVIL TERM - PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: No answer having been filed in the above Civil Action, kindly enter Judgment in favor of Plaintiff, and against Defendant, SHAUN M YOUKERS in the amount as follows: Principal Amount $ 3203.76 Interest to Date $ 17.34 Costs $ 120.90 (9) SOP- TOTAL $ -33?5-983QA1. 10 MAURICE EEDLEMAN, P.C. BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: March 6, 2008 w :s> °oc ?,. ? } c °-h 1 q,? -?- 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 (21S) 189-1161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. SHAUN M YOUKERS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-5755 CIVIL TERM CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 11/21/2007 to Defendant, SHAUN M YOUKERS , against whom judgment is to be entered after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A copy of said Notice dated 11/21/2007, a copy of the receipt for certified mailing to the Defendant and affidavits of service of said notice are all attached hereto. MAURICE EEDLEMAN, P.C. BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: March 6, 2008 • 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) /69- /101 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. SHAUN M YOUKERS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE-NO. 07-5755 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she represents the Plaintiff in the above entitled case and that Defendant, SHAUN M YOUKERS , is over 18 years of age; the occupation of Defendant is unknown and to the best of Plaintiffs knowledge, information and belief, Defendant is not in the military service of the United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. MAURICE PREEDLEM.A4$ P.C. BY: LR&LENE A. TAYLOR, ESQ. Attorney for Plaintiff SWORN TO AND SUBSCRIBED before me thisly day of ? ?. 200ti?. r Notary Public MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (215) 789-7161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED ITY COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS LIABIL - _ I - - Plaintiff - - - _ -1 CASE NO. 07-5755 CIVIL TERM V. SHAUN M YOUKERS Defendant(s) AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA - SS. COUNTY OF PHILADELPHIA I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she is an attorney at law and that on 11/21/2007 she mailed a written Notice of Intention to File the Praecipe to Defendant, SHAUN M YOUKERS , at1810 WILLOW RD, CAMP HILL, PA 17011 by certified mail, article nos. 7155 5474 4100 4843 5315. Copies of the receipts evidencing said mailing are attached hereto. Neither the certified or regular mail was returned to Counsel's office, therefore, pursuant to Pa.R.C.P. §403 (1), service has been perfected by regular mail due to the fact that the Notice has not been returned to sender within fifteen (15) days after mailing. MAURIC NEEDL AN, P.C. BY: VARLENE A. TAYLOR, ESQ. Attorney for Plaintiff SWORN TO AND SUBSCRIBED before me this/0 day of yJ , 200 e6 Notary Public Not- j fl, i Jt 5 `I 4 Y 7 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (215) "/89--/ 161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. SHAUN M YOUKERS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-5755 CIVIL TERM CERTIFICATION OF ADDRESSES It is hereby certified that the parties have the following addresses: Plaintiff. FORD MOTOR CREDIT COMPANY P.O. Box 6058 MESA AZ 85216 Defendant: SHAUN M YOUKERS, 1810 WILLOW RD, CAMP HILL, PA 17011 MAURICE EDLEMAN, P.C. BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: March 6, 2008 Allormys at Law Suite 935, One Penn (enter 1611 John F. Kennedy Blvd. Philadelphia, PA 19103 tal.215.665.1133 fox 215.563.8910 ww wmnlowpc.com Donald S. Maurice Member NJ ear Beard (ertified Creditors' Bights Law American Board of Certification Joaen Needleman Men her PA 9 NJ Bar Thomas B. Dominayk Member NJ, NY & PA Bar Charlene A. Taylor Member PA Bar November 21, 2007 VIA CERTIFIED & REGULAR MAIL SHAUN M YOUKERS 1810 WILLOW RD CAMP HILL, PA 17011 Our File No. 5657 RE: FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY v. SHAUN M YOUKERS CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 07-5755 CIVIL TERM Dear SHAUN M YOUKERS: Enclosed please find a ten (10) day notice of default which is self- explanatory. This is being served upon you due to your failure to respond to Plaintiffs Complaint served upon you on October 9, 2007. Unless an answer to Plaintiff's Complaint is filed with the Court within ten (10) days from the date of this notice, a default judgment may be entered against you. If you would like to discuss a resolution to this matter, please call our office at 908-237-4571 and ask for Kim Crosby. Thank you for your prompt attention to this matter. Very truly yours, M CE & NEEDLEMAN, P.C. y-Jo eedleman, Esq. ARTICLE HABER 155 5474 4100 4643 5315 ARTICLE ADDRESS TO: SHAUN M YOUKERS 1810 WILLOW RD CAMP HILL PA 17011-7451 FEES Postage per piece $0.41 GerdW Fee 2.65 Retum Receipt Fee 2.15 Total Postage & Fees: $5.21 TO COLLECT A ) WILL BE USED ['COLLECTOR Postmark Here MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (115) 7259-7155 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. SHAUN M YOUKERS CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-5755 CIVIL TERM - IMPORTANT NOTICE TO: SHAUN M YOUKERS DATE: November 21, 2007 1810_WILLOW RD CAMP BILL, PA 17011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICEEDLEMAN, P.C. BY ' \ V NEEDLEMAN, ESQ rnev for Plaintiff C)i -0 `D iFl r (7X3 bra ' ` W wy MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff 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) 7sy-nol FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF LLC, A DELAWARE LIMITED COMMON PLEAS LIABILITY COMPANY Plaintiff CASE NO. 07-575-5 CIVIL TERM - V. SHAUN M YOUKERS Defendant(s) (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $3&§.08 on 3 13 saa I to It f (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. Prothonot Jerk by: If you have any questions regarding this matter, please contact the filing party: Name: Charlene A. Taylor, Esquire Address: Suite 935, One Penn Center at Suburban Station 1617 J.F.K. Boulevard Philadelphia, PA 19103 Telephone No.: 215-789-7161 (This Notice is given in accordance with Pa.R.C.P. §236)