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HomeMy WebLinkAbout07-7092 ARBITRATION 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 LLC, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. e)7 - Lovg,- (2 ! u ; C Plaintiff, V. STEPHANIE OGDEN 59 Garden Parkway Carlisle, Pa 17013 Defendant(s). - CIVIL ACTION COMPLAINT NOTICE AVISO You have been sued in court. If you wish to defend Le ham demandado a usted en ]a corte. 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 at partir de la fecha de la demanda y la 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 corte en forma escrita sus filing in writing with the court your defenses or defensas o sus objeciones a las demandas en contra de su persona. objections to the claims set forth against you. Sea avisado que si usted no se defiende, la corte 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 corte 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 demands. 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 (215) 789-7161 FORD MOTOR CREDIT COMPANY LLC, A CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY P.O. Box 6508 Case No. Mesa, Az 85216-6508 Plaintiff, V. STEPHANIE OGDEN 59 Garden Parkway Carlisle, Pa 17013 Defendant(s). 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, Stephanie Ogden, is an individual who resides at 59 Garden Parkway Carlisle, Pa 17013. 3. At all times relevant, the Plaintiff was in the business of loaning money on motor vehicle installment sales contracts, including but not limited to the note signed by Defendant(s), hereinafter more fully described. 4. On or about July 31, 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 $29581.60 at an annual percentage rate of 11.240%, in ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff order to purchase a certain motor vehicle, 2004 Ford Taurus 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 $366.36 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 August 9, 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 $4600.00, however a balance of $8964.14 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 $756.37 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $9720.51. WHEREFORE, Plaintiff, requests judgment in its- favor and against the Defendant(s), in the amount of $9720.51, 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, MA RICE & NEEDLEMAN, P.C. CHARLENE A. TAYLOR, ESQUIRE Attorney for Plaintiff Date: November 16, 2007 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 R, ESQUIRE DATED: November 16, 2007 I , 07/31/20 ON YLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE Buyer (and Co-OWer) Neme and Address (including County and.Op Code) CREDITOR (Malley Name and Addrvss) STEPHANIE L OGDEN RSONS INTERSTATE FORD LLC 30 WEST GLEBE AVE AUG 0 4 2004 6 WALNUT BOTTOH RD NEWVILLE PA 17241 PA 17257 ,a A r P S You, ter Borer land Co-Buter. It WWI may bur the vehldo drmdbW "lew fer rasa er on aredit The 'Cuh FvW shown barA Is the each prim of do vehicle. The 'Toth Bale ir1ce" shorn below Is the week phi". My slaMn g IN. amb*A you oboe" to buy on credit under the apreamaraa w dw front and seek of No eordeat. aid Year and hake model rude a r Us* For Which PWOMW 2004 14 Personal ? Agdgrlwrrel TAURUS IF ANP66S146148067 ? Commarew INSUR'ANO Tr¦d" _42 FORD 9)(11 OBER S 6t10 00 S N/A YOU MAY OBTAIN VEHICLE INSURANCE veer sro IAa1re e,nes Atowanee Annoy OrACg FROM A PERSON OF YOUR CHOICE. ITEMIZATIM OF AMOUNT.M*00 • 22367.0 YOU ARE NOT REQUIRED TO OBTAIN t. Cash Price .......................... ...................................... ..... ............. s of CREDIT LIFE, CREDIT DISABILITY AND 2. Down Payment OTHER OPTIONAL INSURANCE. THIS Third Party Rebels Assigrad to Cradlior..... ......... ...._._.... $ 4000.00 CONTRACT WILL NOT INCLUDE THEM Cash Down Paymant...__._.___._ ___....._.........._........._..... S 3000.00 UNLESS YOU SIGN AND AGREE TO PAY Trada-in 42 F01111 $ 600.00 $ N/A S 600.00 THE PREMIUM. YWWMike aioeeAerreere Mbarrove THIS CONTRACT DOES NOT INCLUDE Total Down Psyrrwnt._ ............... .............. ._..... ................... _....... $ 7600.00 (2) LIABILITY INSURANCE COVERAGE FOR 3. Unpaid aslams of Cash Prise it minus 2)..._.._ .................. $ 14767.02 (3) BODILY INJURY AND PROPERTY 4. Amounts paid on your behalf (Seder may be retaining a portion of time amounts) DAMAGE CAUSED TO OTHERS. To insurance Companies for N/A Credit L"a Insurance (for tens of Credit Disability Insurance (for forte of contract) .._........... (Terre --months (Esti mata)) S II II! To Public Officials (1) for license title (S_ 27.90. a ? Credit Lite registration (S___N.//_) fees s 5-n0 Insurer (6) for filing fees S c nn $ NIA (Id) for taxes (not In Cash Price) $ I t t 6 _ l A $ 1194.6 8 Premium Insured(s) To for $ To F0R0 per EXT WARRANTY s 646. Signature To for s____"LA To for s_ N/A Credit Total ........ ....... ............ ..... ........»..... _.....W.?.... $ 2 .66(4) ?Disability Insurer 5. Amount Financed 3 plus a $ I •7 (5) 1 N/A i $ Premium Insured di - ML ANNUAL FINANCE Amount Total of Total Safe Signature PERCENTAGE CHARGE Flnanead Payments Price RATE The door amount The amowa of The ornount The aw wet the cram wit ereek provided to you well have of your purchase on of Vow vela aea yearly ate OM you you or on your paid when you ?credit. ? belhae have made d Other Optional Insurance Term scheduled - - --- N/A - Insurer $ Promiu rn t t .94 % s I;923.a0 = 16767.70 Is 21981. Zjd Amount at tech When PSig nit r Member of PeymeM 9cttedule an credit ua and Crsdt Disability krwence en You payment schedule ?PR 60 ei - (rnODmhttar obey area of the cannot. lM amount am ere storm In a notice or aatesnurrl wN (q: 1Mtal E 9/ gh es you =- You tiwM Imwe tta veklste. N • eherae r slam m Below the Cmdkw vM try to but the coverages based est o ? . storee.. vdw If= t law but not more Mums 0 the p1. Prepaynrni: a you pay ON your debt eery, you wei not have to pay a penalty. ? reh°rrshia ? t N/A Deduems LM Payment You must pay a fees ahaW on it* poNan of Mad, payment ncelved man cdow" Run 70 days late. The charge Is 2 parcent of do I? amount or 11MOD wtddlewr is low ? RO- TMn'CanbMad Additional Wmrape Seaukq Interest: YOU ors gldng a socially Interest in No vehicle help purchased. ? Towing and Labor CaMnet Ftaaw no this coneaa for adealortal bdanatlorh on saeudy la list na?aymw ? Term -p7? month e (Esomete) dsfaua, to mgt ic more repayment of your debt In kill balm the sduduled dtlw cyst pmef en S pmt gb ty asywiella titre o abagsane.rV*AbNo *myv or goods fee to voldele. as both Paris and "oft NON-MODIFICATION DISCLOSURE Any chanoe in 1Me wnti mud bey in wddng and dW*O by you and they Cmdkey. B"YE?k ODaIIYErt X I MI SIGNS i YOU FC 17WAILa 1Prelows Wars nitbe wee.) ED- You are "led to an and copy of the oontract you sign. PA M1?HACK FOR eD RKINAL AGREEMIM M ORIGINAL BOUND BY THE ARBITR/?TiONTMAPRON CN?TFN: R?EV?SE SIDE OF I PARSON I N 10111116 ? DWI Csmmllaeon walrer Addwduat (OoROrhri CONTRACT. NOTM TO 8 Do not sign this contract In Wank. Keep It to protect your legal rights' Buyer (and Co-Buyer) acknowledge that 1) B1gnln? hi co co Buyer (and Co-Buyer) received an re ewe?a ancTt completely filled in copy of this contract and (N) at the time of sl nt this contract, Buyer (and Co-Buyer) rim-Dili a us and completely in copy of this contract. x vjM a" f1P _& fool, alive" tee By slenlag baNgO%tth?e MNter me" reds eerk eer. Y so Cotter AS&W*"* III Ina a Rhin but Is Ctwekad you hew purchteW a ddeabbl/ eano wm wsNer. u a,a" of tr option and e ti ro e tie dekt n toM In the et4cled Adderdw which Is inmrpbraled Inb Ras convect. The P&G for Inc deb cancellMal waiver is alit form on Rd7 Contract In to IMrtilseon of Amorsn Fhwxed under Ssdrrn 4 surer Program No. QUESTIONS? PLEASE CALL US AT 1-NO-727.7000 or Vlaa us at wrrw.forderadlLoom 034M EXHIBIT A • •PRN••• Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631-3111 (877) 349-5260 PON"00200017 STEPHANIE OGDEN 59 GARDEN PARKWAY CARLISLE PA 17013 Date of Repossession 10-152006 Date of Notice 10-17-2006 Date of Contract 07-31-2004 Account Number: 037463075 Buyer STEPHANIE OGDEN Cobuyer DESCRIPTION OF PROPERTY Year 2004 Make FORD ? New ? Used Vehicts Identification Number: 1FAHP55St4G146067 Model TAURS Body SEDAN NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises In our agreement. Q PRIVATE SALE: Ws will sell-the propdtr deee?beiaboWat 0 PUBLIC SALE: .We will sell theproperty described above at.public private sale sometime after 15 days from the Date of Notice sale to the highest bidder on the date below (or any adjournment shown above unless redeemed by you prior to such sale. date). The sale will be held as follows: Date of Sale Time of Sale Place of sale You may aftend 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, thart you owe;-you wiltstilFoweusthe difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. The property is presently stored at: MANHEIM AUTO AUCTION 1190LA S - HOW TO GET YOUR PR(19R IBACK To get your property back, pay us this amount by certified check or money order before the veNde is sokl. unpaiatmance _ $ 13,027.94. Plus Costs: Repo Expenses $ 20000 $ $ 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 Bade 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 aloe money unde your agreement: 1) The buyer and any cotwyer 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. Plus Late charges $ 115.79 Lou Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 13,343.73 (Plus expenses incurred If defauk at the time of repossession exceeded 13 days and less gate received after the dale of this notice.) Your property won't be sold urd 15 days alter the date of this notice at the EARLIEST. After that you can still get it hack any flme before I's actually sold. If you do, we'll have no further claim on it. But the longer you wait, the more costs (moluding repairs) you may have to pay. If you have any questions about this, please call us. ? The property has been (or Wit be) returned to: (dealerlwiginal credfitor) Under our agreerned with your deakrloriginal creditor, the dealerhrigirml creditor is to sell the property and pay you any money left over. If you owe money after the sale, you will pay it to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by contacting this office. Thereafter, the personal property shalt be disposed of acwrdingy. ? Creditor has assigned to its qualified intermediary (OI Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above. PAYMENTS: All pa mteMe to us must be by certified check or money order, MILEAGE DISCLOSURE: If you are aware 11at the mileage reflected on the vehicle's odometer is not accurate for any reason, please ooMact us so that we can acc rstlly report the vehicle's mileage. INSURANCE RIGHTS: If you donl want to get your property beck, 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. MICFELLE L. HEAPS FFNA t+&ee37 Jan 02 Previous editions may NOT be used, CUSTOMERICUSTOMER FILE PrinEM N U.S.A. EXHIBIT :j •? ?, ? l, ylll : I I Name and Address, WaBav 38120 Amrhein Livonia, MI 4 8150 Adttlle NwMer 1 U1016120%4158 EA-040536710 o-f. I:•.. {? I IaIE h <:If• h. t f. Check type of mat or servka: ow 06*" pnkrneOm* p R? ? 0 odvery ConMtaatlon 0 tlerom R&OW for Merchandise Cl Espeu Mae 13 Ineurod D OWNfure Conarmstba Adbesao Pta 901t Al. Aft S LP OW Peyada 2150 Deus 1674 1085 t , ri • ir: ' {? iK7' :i y?l , f J• .i ' i. Stamp Haa tnd ee • of ahb boy Fee O CT 17 200s TINA C. HENRY N8099 OAK LANE IXTON WI 5 635 7006 2150 0005 1674 1722 U1016f20594061 _.-_ __.__ H 4 _ BA-038840437 CORNERSTONE TREE LAWN & LAND n n ?" - 1 92 1?7 329 STONEY BROOK LANE MARLFfNNJ 08053-. --- pp0 z15a _-- U1016120594159 7QOb ------ --- - MA-037463075 ------- - - STEPHANIE OGDEN - - - •---- - -_ 59 GARDEN PARKWAY U1016120594082 QpS BK 039539411 2150 13005 167 4 1 1311 CARLISLE PA 17013 - 7QQ6 LUIS MERCADO a m - 144 BOND ST C C Q U1016UO594160 7006 2150 0005 1674 1108 BRIDGEPORT CT 06610 G d+ BA-032110304 GLENN E. GARNER - --- - 13L -?? A t: 0 25 Q6 2150 U10161205WO83 - L2 167 4 ~ 7y46 204 HESTER LLOYD C S (9013 -- ?Q SK-028285656 ? - --' ' ' - TRACY R. MITCHELL NT ST E C ? V 25 PL ASA tv --- I DANBURY CT 06810 - -- Ulal&WS94161 _ _ __.706_al_50 Q005 1674 1115 BP-027337743 MARY EMERICK 70 VOYAGER ESTATES WEST NEWTON PA 15089 Wned by 8wrder 12 I RNOMM of Paw OMi * PC Fnn IR77 CA--, •'V- -- , . ?4rn Av Tv..,..vNwe ML n? AM7 e,a-. e•.. Sea Privacy Ad Statement on Rovem Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2007-02-14 POSS9Y00000059 STEPHANIE OGDEN 59 GARDEN PARKWAY CARLISLE PA 17013 STATEMENT OF SALE Account Number: 037463075 The following property has been sold. Year Make Model 2004 FORD TAURS Vehicle Identification Number: 1FAHP55814G148067 Ba ance owing-on your contract -(1) $ _13,143.73_._ Deduct: Finance Charge Rebate (2) $ 0.00 'r Balance less Finance Charge Rebate (1 - 2) (3) $ 13.143.73 Deduct: gross proceeds of the sale (4) $ 4,600.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 8.543.73 Add: Expenses of retaking and storing, and (6) $ 74629 any attomeys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ 0.00 Other: (8) $ 0.00 Deficiency** (9) $ 9290.02 Surplus* (10) $ N/A The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest added to your account (debits). Surplus* or Deficiency' * If the sale resulted in a surplus, a refund for the difference will be mailed to you. ** If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional Information call or write: Mail deficiency payment to: Ford Motor Credit Company Ford Motor Credit Company P.O. BOX 6508 DEPT 194101 MESA ARIZONA 85216-D50B P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 FFNA11990 01/04 Previous edidans may NOT be used. EXHIBIT OD /v c Q -4rj 41 „ V Ca ? 7 ri"i --t 10(113 SHERIFF'S RETURN - REGULAR CASE NO: 2007-07092 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY LLC VS OGDEN STEPHANIE SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon OGDEN STEPHANIE the DEFENDANT at 1919:00 HOURS, on the 3rd day of December , 2007 at 59 GARDEN PARKWAY CARLISLE, PA 17013 STEPHANIE OGDEN by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit 01 Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 4.80 00 10.00 R. Thomas Kline .00 32.80 12/04/2007 MAURICE & NEED By: day eputy Sheriff A.D. MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (215) 789-7161 FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF LLC, A DELAWARE LIMITED COMMON PLEAS LIABILITY COMPANY - -Plaintiff CASE NO.07-7092 CIVIL TERM V. STEPHANIE OGDEN Defendant(s) - 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, STEPHANIE OGDEN in the amount as follows: Principal Amount $ 8964.14 Interest to Date $ 1369.19 TOTAL $10333.33 MAURICE & NEEDLEMAN, P.C. BY: Date: October 16, 2008 CHAR'tENE A. TAYLOR, ESQ. Attorney for Plaintiff MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. January 31, 2008 Attorneys at Law Suite 935, One Penn (enter 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 lot. 215.665.1133 fox 215.563.8970 www.mnlowpc.com Donald 1- Mawia lAem1. NJBar Board (ertilied (reditors' Bights Lew American Board of Certification Joann Needleman Mem ber PA d NJ Bar Thomas B. Dominay1 Member NJ, MY E PA Bm (harlene A. Taylor Member PA Bar VIA CERTIFIED & REGULAR MAIL STEPHANIE OGDEN 59 GARDEN PARKWAY CARLISLE, PA 17013 Our File No. 6250 RE: FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY v. STEPHANIE OGDEN_ CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 07-7092 CIVIL TERM Dear STEPHANIE OGDEN: 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 December 3, 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. I. _, Now Jersey Office Alourke a Needleman, P.C. Saito 2007 5 Walter F. Feron Blvd. Remi", NJ OU22 tel. 908.237.4550 fax 901.237.4551 Very.truly yours,_,_:-_ ti- M CE & NEEDLEMAN, P.C. Jo* Needleman, Esq. JN/jm Enc THIS CORRESPONDENCE IS-AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR ii ?mss . ? 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) 789-7155 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. STEPHANIE OGDEN CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7092 CIVIL TERM IMPORTANT NOTICE TO: STEPHANIE OGDEN DATE: January 31, 2008 59 GARDEN PARKWAY. CARLISLE, PA 17013 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 &;1*&WYER,,CiO.' 0,Q&-jW, -HONE 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 _- T "-MAURCE'=& NEEDLEMAN, P.C. BY J NEEDLEMAN, ESQ y rney for Plaintiff 6"MIPS o Com Certified Mail WITHOUT Return Receipt Service (No Return Receipt Card) O Certified Mail Label with Postage Attached D O U IL M UJ V-- 0) W F- Z J WUa ZZ= W WC'J BOO LLJ Q M = 2 05 CL Q Individual Receipt .- in a ,- It (p - N E ?NN? LL a J- LL m W E° a ° LL a UIr I- M1 b M1 b ..O m M1 S M1 61 c a T to r- C o ? o z: W a' V t N N Ln ? N SDC-3900 © Delivery Address 0 or Return Address 0 V CV 04 W 0 o Wza ?Q?rj F L.U ?COLo0 I& Top of the Page -Ak-- 0 Certified Mail WITH Return Receipt Service (Uses Return Receipt Card) © Certified Mail Label, Card, and Postage F0 M1 N ?S m m M1 O w?+? S M1 s Ln ?? ut W"d Sd a Z 1 ?Q w Z W Zz!5 wa-j UZW Dog LOY cr) rna W a U O Delivery Address V- N N O) z A W V- Oar W za Z W W _ WC0 W C9 W CO ?U CCI CIO W V- _ O0.Q - - W z 0- •? Q s fn v7 U y + E LL ? Q l" a q M C ¦ v ?$? O b v I ???ry +L90[ KI•?OVpOlks Sender's Address t ttlGt '166L 0KA hGhs SstG ;=?y s • rs* run a Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUN-29-2007 07:57:28 ,K Last Name First/Middle Begin Date Active Duty Status Service/Agency OGDEN STEPHANIE Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.htmi WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/29/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:ELCAJTQKXF https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/29/2007 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) /ZSy- /lbl FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. STEPHANIE OGDEN Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7092 CIVIL TERM AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that she is an attorney at law and that on 11/26/2007 she mailed a written Notice of Intention to File the Praecipe to Defendant, STEPHANIE OGDEN, at 59 GARDEN PARKWAY, CARLISLE, PA 17013 by regular mail. MA BY: Attorney for Plaintiff SWORN TO AND SUBSCRIBED before me this? day of 200 G Notary Public Notarial Seal Agnes Beiland, Notary Public City Of Philadelphia, Philadelphia County My Commission Expires Jan. 20, 2009 k,ernbcr, P, srr,sy; ,-.U oc _;CI rr C... ? C. R, ESQ. 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 LIABILITY COMPANY Plaintiff V. STEPHANIE OGDEN Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7092 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that she represents the Plaintiff in the above entitled case and that Defendant, STEPHANIE OGDEN, 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 servir 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 B4fE-RDLEMAN, P.C. BY: ESQ. for Plaintiff SWORN TO AND SUBSCRIBED before me this`` 2 day OG , 200 - Notary Public Notarial Seal Agnes Beiland, Notary Public City Of Philadeipnia, Philadelphia County My Commission Expires Jan. 2©, 2009 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. STEPHANIE OGDEN Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7092 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 /26/2007 to Defendant, STEPHANIE OGDEN , 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 11/26/2007 , a copy of the receipt for certified mailing to the Defendant and affidavits of service of said notice are all attached hereto. MAURICE & NEEDLEMAN, P.C. Date: June 24, 2008 BY: QnARLENE A. TAYLOR, ESQ. Attorney for Plaintiff 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 LIABILITY COMPANY Plaintiff V. STEPHANIE OGDEN Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7092 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: STEPHANIE OGDEN, 59 GARDEN PARKWAY, CARLISLE, PA 17013 MAURICE,4 NEEDLEMAN, P.C. BY: e*(RLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: June 24, 2008 0 P%J IL c-no Q -.a O + t 'fit _ ..... -< crz S 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 (21)) -/89- / 161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. STEPHANIE OGDEN Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7092 CIVIL TERM (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $10333.33 on (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. Prothon erk 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)