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HomeMy WebLinkAbout07-7667ARBITRATION 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 Attorneys for Plaintiff 15)'/69-7 161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. HEATHER A HOWARD 4201 Gettysburg Rd Lot 16 Camp Hill, Pa 117011 CAROL K MURRAY 2316 Chestnut St Camp Hill, Pa 17011 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 67 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. CIVIL ACTION COMPLAINT AVISO Le ban demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demands y la notificacion. Hace falta asentar una comparencia escrita o en persona o can un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notifkacion. Adernas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demands. 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 Sl 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 LLC, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. HEATHER A HOWARD 4201 Gettysburg Rd Lot 16 Camp Hill, Pa 117011 CAROL K MURRAY 2316 Chestnut St Camp Hill, Pa 17011 Defendant(s) ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. CIVIL ACTION COMPLAINT I. 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, Heather A Howard, is an individual who resides at 4201 Gettysburg Rd Lot 16 Camp Hill, Pa 117011. 3. Defendant, Carol K Murray, is an individual who resides at 2316 Chestnut St Camp Hill, Pa 17011. 4. 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. 5. On or about October 19, 2005, 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 $26050.60 at an annual percentage rate of 15.390%, 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. 6. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $392.51 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 7. Defendant(s) made monthly payments until June 25, 2007, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 8. 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. 9. 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 $9300.00, however a balance of $5745.86 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. 10. 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. If. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to $414.28 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $6160.14. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $6160.14, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. Lt-FARLENE A. TAYLOR ESQUIRE Attorney for Plaintiff Date: December 14, 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: ,E DATED: December 14, 2007 PENNSYLVANIA SIMPLE INTEREST VFNlef a Nrr........?.. - DATE HEATHER A HOWARD nCT Z 1 2003 CAROL K MURRAY L D SMITH FORD INC 4655 CREEKVI EN RD ® MECHANICSBURG J1100 MARKET 57 CUMBERLAND PA 17050 LEMOYNE PA 17043 NEW I -- OPewa.1 0AyAanba O Canesewy RtSaRAT10N OF AMOUNT FlNANCED bi&1RANCE f. Cosh Prba..._. ................ YOU ARE REN46 NC INaURE THE ??._...-..-.._._-..„.._..___....... s?6-e65?e(TI VEHICLE YOU MAY Z. Darn Peynbfa Third Party RebaN Awpnaa ro EMar_.__....... .. ..... INSURANCE OBTAIN VEHICLE FROM A PERSON OF YOUR CHOICE Cwb Dawn Psyrrbnt_........._....____._.__......_._._„._____...i T rrr.no SOioee i-_sLO?? S--i=BB?? t1AB0.nY Na11RANCE COVERAGE er"°'w?-ca°e -'53?. ab FOR BODILY IWURY AND ioW Down Nyman„?„„_ DAMAGE CAUS RTY ED TO OTfIFA91S NOT ...._.„.».__.__..„_.._...... .._._._...5 E INCLUDED. i. A`Y aeMna W 1 I l eou e Pubis DpbWr boles (SNbr -w be rsWnbe ¦ ParRan d Ihetr?OOwiramrsOj CREOIT LIFE CREDIipSANUTY AND OTHER O%IONAL INSURANCE ARE 14 W ken. (S n 1, fib IS L NOT REQUIRED TO OBTAIN CREMT bibbason (S 1. lens S ?)• AND WILL NOT BE PROVIDED UNL IN 1. ling sew .A n e YOU SIGN AND AGREE TO PAY THE PREMIUM. (a) h mores Ind w Gal Pdw) II ' To Mrnrln CemPe0ke ror:'?' i-efie:-9rr CnMN Cmdft i CrMS ?DIeebRry hisumn(tar ee ? U1A114c Iralf (rorronCe g COn"nY TN_w _ Ram ?_ Ataehe)._._, S - You wem Creed Lite Irbup,", i To 11rIR4iR-' F:-i To ha s -'»?NYA o- &ryer 9ipne Te mr ! -NYit- To far i -H7Yr- T•bl».__.__. __..._..»__..__...._.._..__.._..._._. C"- Siors '. 5. A- Fbrfwd (3 Hue 41_ F7'1 1111 L TFKM 44ENDINO gSC.OSURES O Ole" VA Inseams Company ANNUAL FINANCE Amount Tote of Sale Total PERCENTAGE CHARGE Floanc d s _ Premium Inrur a P e aymenls Pries RATE 7M Oebr anaunl nw IoW ail b ? i y- moss Croon pleb! b •r seance. ? sranAra p sd an .. err Yoe o1>'we Pr?we ? N b yc. a m I user u.yeeM rab h eod M tl 1.0 Yoww. y0tl mow eelell w 15.39 7 SUysr 9gr1E _ .192.55 16,35905 %w ? v yw ?'?Y•r wisYmaPaeww eArabwateese w OTHER OPTIONAL INSURANCE ON O OA C M uq ? irba I.- Co Term b AeenW /A !/_ plwr rnb Ilyo.wy."yew diet 0". ra..e m hm b per apW0, mN/A N/A seaalb s: vw ere p6p:w uwy Meow b we vWd. beep VoOmd l eO'^$S. carry ? S N]n m . efe?ryaeeb Ya, ewe PryaWa.ge aAPalma ear dqa lee nRdwbebeO PacwaaeW .:...r rePessrowaa. ewr ra CmO.ee Pww w M. ae?a Ia seawr blmm.len an ea?as?rrq P•oeReeha Pr+M rogilre np.Pew. a yew Ma b hn eaas sNriOras ales. see ???CHEQ 72 Y= wn1 Me OPLI-el inemance for wHOh Perfdrerw we k-%Ww Noose. lkaa Ya msY bete your yeMtle u A as WIN . m. PI!I on Yogis vefYde arq money a Goods rrs:avea hx i Q Yes ba I*"* sm P.FnwN burr so owbea b a be- P.,.. ? C>Buyer Sods EXCi_= r.e YaE A/6 YLAAm CrM{ Lee ew CbM pYWb Ilenrrb,p sb I IN w only sYOw Is aunbs. 11W actlen. FrWels & ens Pe.0" C d rw Yr rw a xe 66 wet .asr.r. nr a.or arE a nwm.l M. . you ab ?•r0M W e.wsaw.reer W rb.rf -- w.rbwN v- I b ysua .hewn o. a .arts. >..,.m,an oglpf? sb v.Nas be* to SsMu Ume, ' drParoPh 9 You iPM pry b s.NU SW A Pa mR. for a.M mro w arcoe rnibE draMf Pn &A adallMa. ? - O.erYwbe Weer AYmdwh(Cy EXTRA HAw aPOOw CaEllrl' Y ft bw h amA. ye. hove rwaene a diet Y ON. Cawed Owlbbs • h peynrd (w brecwea wire. Purtlew tl Yds aevwepe 4 beisal v. .Oorp, wfd you spwrtl sM k rrw weew b aetW asel Tile eremlwO sour CpYan b ppWgyaepb vetJOls b IIw 8sM blew Psrpepa B. bb wrbeendw.Ntlwretl Md.w Rnabronwpsr 1-04, a~e?y rl/ApAl I'm r'abwM Ma tl pl. oawaal. You RY ?YwpyareW bMYaawan AdaiMee MYm s b..- N/F yb b/](•awa wpb w ft nmi4r d urugs mlw a?o/bwaWaYMbrbarr Mb mwad bets owe rrwer tlfs mnlred. You MI nd woWe 'Nee •? snrorwMf You mow" a Amawl FTYXSd w,ft lwsm d. cawed oleo serly, ar you an A tiara, Yw?.dl neI nnM rwdae b ae.eoysq ear Iwo Ubn =1.01 srry aedt II tle eroeY b euyw /r NON•MODIFICATION DISCLOSURE Arys w" lam. i u_aaIn 1wiw,e ud xPw byNbr wd.e 11- to ReM ally be Negotiated w0h tlr tiller. 7h Sear POTION Of the Fla. Chrae, my easlgn nfie oorwaet ON Its r RIeY rehln Do not sign this contract In blerdL You are entitled to an exact of the contract that you sign. Keep it to protest your legal rights, Sauerer /-??uy.. X GY Buyer (and Co Buyer) acNTtowledge that (t) before stoning thle contrast, Buyer ( Co-6 receiv r es and revlerYes a true and completely fated In copy or this Contract and (b) IN fist Dmi s1RnMo this contras Buyer (and Co-Buyer) received a true and c coTdract ITItlpleiely }Bled in copy o?lhis r1 _ An . I r1 i.IILrB s>ra, FaRD 1xc _ THIS CONTRACT 15 NOT VALID L NT L YOUUAAND S -to-an ills -to-aR SKIN IT. ABBKf WENT moles nwy Ineaa rte earrhwl b wsea Paeew TM Partin Mtl rsn hew x fYW? rbh14 Pmaeew ens wwdbe. T. warty mob see.etl p eryehw boles, me Ts least Aeelyrwe Van Thle ererwu TASaeew1 /eaY wbeM w sy K mr r•s./ rC ?rwf?rwL nOnw:0 wwnr e.rae err, EEE Oe6l ebE rOR A9DRXIN/y, AeIENwHT$ i ORIGINAL EXHIBIT A "'PRN... Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631.3111 (877) 3495260 1`07e3M00Y00016 HEATHER A. HOWARD PO BOX 1131 MECHANICSBURG PA 17055 NOTICE OF OUR PLAN TO SELL PROPERTY Wile have your property described above because you broke promises in our agreement. Q PRIVATE SALE: We will sell the property described above at private sale somen rte after 15 days from the Date of Notice shown above unless redeemed by you Prior to such sale. ? PUBLIC SALE. We wig saline property desorltiedabove at public- sale to the highest bidder on the date below (or any adlOumment date). The sale will be held as follows. pm--yat-ten, Titre of Sale the sale and bring bidders f 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 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 dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. ? The property has been (or will be) returned to NOTICE OF REPOSSESSION The property is presently stored at: MANHEIM AUTO AUCTION HOW TO GET YOUR PROPERTY BACKR H I TO get Your Property back, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 15481 91 Plus Costs: Repo Expenses $ 20000 $ Plus Late Charges $ 20.77 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 15 692.68 (Plus expenses incurred if default at the time of repossession exceeded 16 days and less rebate received after the date of this notice.) Your PmPsny-1 be sold until 15 days after the date of this notice at Your EARLIEST. After that you can slit get it back any time before irs actually sold. If you do, we'll have no further claim on A. But the kxnger you wait, the more costs (includrng repaks) you may have to pay. If you have any questions about this please cog us Under our agreement with your dealedodginal creditor the dealedorigirw creditor is to sell U* properly and ( -titlnai creditor) after the sale, You will Pay it to the dealer/original creditor. PeY You any money left over. If you owe money ? PERSONAL PROPERTY: Any personal Property found in the vehicle may be reclaimed by You within the next eo days or, in accordance with state law, by contacnil this oftkx Thereafter, the personal property shall be disposed of accordingly. e e ? Creditor has assigned to its qualified intermediary (ql Exchange, LLC) its rights (but not its 061110lorns) 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 tits mileage reflected on the vehice'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, cal the insurance company or the dealerforiginal creditor to crake sure that any insurance has been cancelled. You have a right to get credit for all premium refolds. LEOLA M. MILLER EXt f FFNA ileee-.A Jan 01 Ravioua adirions may NOT bar uaad. ?t7 ra'iMad in IASA, CUSTOMER/CUSTOMER FILE 11 .. PRN-- Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33531-3111 (877) 349-5260 P0793"200020 CAROL K. MURRAY 2316 CHESTNUT ST CAMP HILL PA 17011 NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. Q PRNATE SALE: We will sell the Property described above at private sale sometime after 16 days from the Date of Notice shown above unless redeemed by you prior to such sale. ? PUBLIC SALE: We" sell the Property described above at pubic sale to the highest bidder on the date below (or any adjournment date). The Sale will be hold as follows: Date of Sale Time of Sate 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 attomey'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 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. NOTICE OF REPOSSESSION The property is presently stored at- MANHEIM AUTO AUCTION HOW TO GET YOUR PRISPPERTY BACK D To get your property beck, pay us this amount by certified check or money order before the vehicle is sold, Unpaid Balance Plus Costs: Plus Late Charges Leas Finance Charge Rebate Less Insurance Premium Rebate TOTAL $ 20.77 $ 15,682.68 (Plus expenses incurred if duNaut at the time of repossession exceeded 16 days and less rebate racafved after the date of this notice.) Your Property wont be sold unit 15 days after the date of this notice at the EARLIEST. Alder that you can still get t back any time before is actually sold. H you do, well have no further claim on N. But the longer you wait, the more oosts (WiWing repairs) you may have to pay. H you he" any questions about this, please cat us. ? The Property has been (or wi6 be) returned to Under the sale, with your dealer/odghat creditor the the dealer/original cracltor is to sell the ( /ate aid" after You wit pay t to the desisdoriginsl credit pfOPerty and pay you any money left over. If you owe money ? 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, ft personel Property ehal be disposed of sccordingly. ? Creditor has assigned to Its qualified intemtediary (OI Exchange, LLC) its rights (bur not is obligations) with respect to the sale of each vehicle listed above. PAYMENTS: At payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehkde's odometer is not accurate for any reason, please cordaet us so that we can accurately report the vehicle's mileage. INSURANCE RIGHTS: If you don't want to get your property back, cat the insurance company or the dealerMrlginal creditor to make sure that any insurance has been cancelled. You have a right to get credit for all premium refunds. FFNA 1198837 Jan o2 Prwbys editions may NOT be . W. Printed in U.S.A. LEOLA M. MILLER $ 15,461.91 Retw E- x -pMSes $ 200.00 $ $ CUSTOMER/CUSTOMER FILE Name e11e Aeefap of S&w& Lason 38120 vonla I 48 LIV011?8150 , M Artk4le11nEer U 1106/20596991 BP-033787029 DARWIN W. SEESE - 452 FLATROCK ROAD MARKLEYSBURG PA 15459 U1106/20595992 BP-039751523 SCOTT E. LESICK 3 70 CRESTVIEW DR TARENTUM PA '15084 4. • . x•,.$,1.'1.:..,.: ia;i:r•"•1? oG:; •S .; ? •..'? ::76:1• ^: . , , .. :rt:, h. 'iris +:t { .h ?A r ..r ?7sdc Sypa gj?eii a aeMct AMK S-V Here ?:.?^)?j.: ' :??,•:• is i; eomew Q :=-" Qeumatbnr) a? Jay/? ,/ nn ? FrIpquMee ? ? O Ohe poefrasrK arb NU VO ? 20u6. Debd e'JaeeeeeRM7R SeeK Oty, Seis. a M, cxv Pnll" iN H.rgeny rewwf ve7ue ualeee oa vw f 7006 2150 0005 1688 8254 7006 2150 0005 1688 6261 U111060596995 BA-MOS72035 RENEE BREINER 500 EAST ELM TAMAQUA PA 18252 U1106/20598993 7006 2150 0005 1688 8276 - JQ-037463849 5 AU HORAISI JR 1827 METZ ORIVE GERMANTOWN MD 20806 39759946 A. HOWARD PO BOX 1131 MECHANICSBURG PA 17055 V + 8EATHER 7006 2150 0005 1688 8285 ac cne„ ten R.M: „ xw,•, ,o.... , .,r et U1106/205969M - BA-031079271 REGINA L ROBINSON 14 TEAROSE LANE LEVITTOWN PA 19054 5 7666 2156 aft05 1686 8292 .. 7006 2150 0005 1686 8308 Fit. SN Prlwq Act StetamaM on Rovarao .. -•?_ .sue.:?',+st °:r:: 38120 Amrheln Livonia, MI 481 S0 • ArIF.Y Mn,t•?r U1106/20626997 BP-033787029 ROBERT E. SEESE --- 164 DINNER BELL OHIOPYLE /-_?NRMINGTON PA 15437 : 1 ? ..1.•,: ::? . {... tt , l . •.?r'f'[ 't.7:t;}. ;.YS•'• Ji.'t;' ;fC;,•sr t ?:,,i:. ? ' • • • --.. -,?.+?1'-ty'it'?i9.y?-.? .-? , _ t!?ij;!':. Il:.:.:. ? •''. ? H' ? a ... __.__-.. ?°i ?tf:?? .j" '•??.? • IChseit a30+Y1C0: -.,. - ??_._...._ ,[ .a. _ .nL14 ' io?- 3larnp "w. -. NOV07W%, ?OOiM (lyyq yspK qy, Vet 6 Dp(?y 7nrn » rn nnnr .. .. ...... L ?U 06/20596998 .039759946 '? -?--- -- ---- CAROL K. MURRAY 7006 2150 DODS 6688 8382 2316 CHESTNUT ST -• - --- _ _ _ CAMP HILL PA 17011 q - - - -- - 7006 2150 0005 1688 8339 ----,- - 0 6882 AM-036916631 RAYMOND G. W EISS 861 VISTA RIDGE OR MOUNTHOREB WI 53572-2394 - - -- U1106/20598883 7006 2150 0005 1688 8346 7. BA-032184581 AMOS MANLEY _ 914 SPRUCE AVE - " -- - PLEASANTVILLE NJ 08232 U1106/20696884 7006 2150 0005 1688'8353 BA-036605012 SPRUCE GENERAL CONTRACTORS 914 SPRUCE AVE PLEASANTVILLE NJ 08232 7006 2150 0005 1688 8360 399 Privacy Act Stagnant m Revar" Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 877349526o DATE: 2006-12-29 POWM0000052 HEATHER A. HOWARD CAROL K. MURRAY PO BOX 1131 2316 CHESTNUT ST MECHANICSBURG PA 17055 CAMP HILL PA 17011 STATEMENT OF SALE Account Number. 039759946 The following property has been sold. Year Make Model Vehicle Identification Number : 2006 FORD FOCUS 1 FAFP34N96W 127368 Balance owing on your contract Deduct: Finance Charge Rebate (1) $ 15,482.68 (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale (4) $ (3) $ 15 482.68 9,300.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 6182.68 Add: Expenses of retaking and storing, and (6) $ any attorneys' fees allowed by law, and 392.00 expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ 0.00 Other: (8) $ 578.82 Deficiency** (9) $ 5995.86 Surplus* (10) $ N/A The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed ex added to your account (debits) . SUrOIUS* or nor, fe...,.* penses & interest * 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: Ford Motor Credit Company Mail deficiency payment to: P.O. BOX 6508 Ford Motor Credit Company MESA ARIZONA 85216-6508 DEPT 194101 (800) 732-2264 P.O. BOX 55000 DETROIT MI 48255-1941 EXHIBIT FFNA11990 01/04 Previous editions rimy NOT be used. a Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2006-12-29 P08UV300000053 HEATHER A. HOWARD CAROL K. MURRAY PO BOX 1131 2316 CHESTNUT ST MECHANICSBURG PA 17055 CAMP HILL PA 17011 STATEMENT OF SALE Account Number: 039759946 The following property has been sold. Year Make Model Vehicle Identification Number: 2006 FORD FOCUS 1FAFP34N96W127368 Balance owing on your contract Deduct: Finance Charge Rebate (2) $ 0.00 (1) $ 15,482.68 Balance less Finance Charge Rebate (1 - 2) (3) $ 15 482.68 Deduct: gross proceeds of the sale (4) $ 9,300.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 6.182.68 Add: Expenses of retaking and storing, and any attomeys' fees allowed by law, and expenses of reconditioning and selling. (6) $ 392.00 Deduct: Insurance Premium Rebate (7) $ 0.00 Other: (8) $ 578.82 Deficiency** (9) $ 5995.86 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: Ford Motor Credit Company P.O. BOX 6508 MESA ARIZONA 85216-6508 (800) 732-2264 Mail deficiency payment to: Ford Motor Credit Company DEPT 194101 P.O. BOX 55000 DETROIT MI 48255-1941 FFNA11990 01104 PreNous edibons may NOT be used. PA +V `` "" ` - C 11^` I . i ? l I oo 1 SHERIFF'S RETURN - REGULAR CASE NO: 2007-07667 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY LLC VS HOWARD HEATHER A ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MURRAY CAROL K DEFENDANT the , at 1910:00 HOURS, on the 31st day of December , 2007 at 2316 CHESTNUT ST CAMP HILL, PA 17011 by handing to CAROL MURRAY 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 6.00 Service 15.36 Affidavit .00 Surcharge 10.00 lldal a 9- 00 31.36 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 01/10/2008 MAURICE & NEEDLEMAN By: Deputy Sheriff of , A. D. 4 CASE NO: 2007-07667 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY LLC VS HOWARD HEATHER A ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOWARD HEATHER A the DEFENDANT , at 1239:00 HOURS, on the 10th day of January , 2008 at 4201 GETTYSBURG RD LOT 16 CAMP HILL, PA 17011 HEATHER HOWARD 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: So Answers: Docketing 18.00 , Service 15.36 Affidavit .00=° Surcharge 10.00 R. Thomas Kline a2 0? .00 3.36 01/10/2008 MAURICE & NEEDLEMAN Sworn and Subscibed to By: before me this day Deputy Sheriff of 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 (11)) -/89--/ 161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. HEATHER A HOWARD & CAROL K MURRAY Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 Civil Term PRAECIPE TO ENTER JUDGMENT MAUR BY: P.C. CHARLENE A. OR, ESQ. Attorney for Plaintiff TO THE PROTHONOTARY: No answer having been filed in the above Civil Action, kindly enter Judgment in favor of Plaintiff, and against Defendants, HEATHER A HOWARD AND CAROL K MURRAY in the amount as follows: Principal Amount Interest to Date TOTAL $ 5745.86 $ 1291.30 $ 7037.16 Date: December 9, 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) 789-7161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. HEATHER A HOWARD & CAROL K MURRAY Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 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 3/28/08 to Defendants, HEATHER A HOWARD AND CAROL K MURRAY, 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 Notices dated 3/28/08, a copy of the mailing to the Defendants and affidavits of service are all attached hereto. MAUR BY: .C. R, ESQ. Attorney for Plaintiff Date: December 9, 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 (11J) /z59 /lbl FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. HEATHER A HOWARD & CAROL K MURRAY Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 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: HEATHER A HOWARD, 4201 GETTYSBURG RD LOT 16, CAMP HILL, PA 17011 CAROL K MURRAY 2316 CHESTNUT ST CAMP HILL, PA 17011 MAUR BY: P.C. CHAkkENE A. OR, ESQ. Attorney for Plaintiff Date: December 9, 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) -/89--/161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. HEATHER A HOWARD & CAROL K MURRAY Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 Civil Term AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she is an attorney at law and that on 3/28/08 he/she mailed a written Notice of Intention to File the Praecipe to Defendants, HEATHER A HOWARD, at 4201 GETTYSBURG RD LOT 16, CAMP HILL, PA 17011 AND CAROL K MURRAY at 2316 CHESTNUT ST, CAMP HILL, PA 17011 by regular mail. MAUR BY: ESQ. SWORN TO AND SUBSCRIBED before me thisl,2- day of Cz_e _ , 2008. Notary Public Attorney for Plaintiff uJMMONVVEALTH OF PENNSYLVANIA Notarial Seal Agnes Belland, Notary Public City Of PhNadelphla, PiWdWft Cot* My Ca V*MNM Egkn Jan. 20, 2008 Member, Pennsylvania AssoOiatlnn Cf Notaries 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-% 161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. HEATHER A HOWARD & CAROL K MURRAY CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 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 Defendants, HEATHER A HOWARD AND CAROL K MURRAY, are over 18 years of age; the occupation of Defendants is unknown and to the best of Plaintiffs knowledge, information and belief, Defendants are 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. MA BY: P.C. ,OR, ESQ. SWORN TO AND SUBSCRIBED before me tl"s day of 0,0? , 20/0$ Notary Public arx,& UUMMONWEALTH OF PENNSYLVANIA Notarial Seal Agnes Bedand, Notary Public City OI R* delpttie, PtWadelPhia County My Conn*slon Expires Jan. 20, XOW Member, Pennsylvania Association of Notaries- Attorney for Plaintiff March 28, 2008 A. ttorneysof lw Suite 935, One Pens (enter 1617 John F. Kennedy Blvd. PhNods lphia, PA 19103 tel. 215.665.1133 fox 215.5634910 ww w.mnlowy(.(om Donald S. Nearke Member NJ Nor Board (atified Creditors' Rights law Ameri(an Board of (ertie(alion Joann Nieman Member PA d NJ Boy Thomas R. Domin(:yk Member NJ, NY 8 ?A Bar Charlene A. Taylor Member PA Bar VIA CERTIFIED & REGULAR MAIL HEATHER A HOWARD 4201 GETTYSBURG RD LOT 16 CAMP HILL, PA 17011 Our File No. 6354 RE: FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY v. HEATHER A HOWARD & CAROL K MURRAY CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 Civil Term Dear Ms. Howard: 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 January 10; 2008. -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. UCen/eTaylor, Esq. CT/tam Enclosure New Jersey Office Mauna d Needleman, P.(. Suite 2007 THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A 5 Walter E. Foran Blvd. DEBT, AND ANY INFORMATION OBTAINED WILL BE USED Remington, N1 ON22 te1.908.237.4550 FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR fax 908.237.4551 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. HEATHER A HOWARD & CAROL K MURRAY CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 Civil Term TO: HEATHERA HOWARD. : . 4201 GETTYSBURG RD LOT 16 CAMP HILL, PA 17011 IMPORTANT NOTICE - DATE: March 28, 2008 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 MAURI E & NEEDLEMAN, P.C. BY lene A. Taylor, Esquire Attorney for Plaintiff stem s Certified Mail WITHOUT Return Receipt Service (No Return Receipt Card) 0 Certified Mail Label with Postage Attached D O -e 93 r- Q .r7. .T r? U. M n M!Lwo d - SDC-3900 Top of the Page -dki- Certified Mail WITH Return Receipt Service (Uses Return Receipt Card) Delivery Address Qor Certified Mail Label, a Delivery Address Return Address ® © Card, and Postage O MoicotuJn?.- Z M AMA o W ~ C) J Z WUWaa. W Z Q Z Z = W W aa ?Z? O < Lo Mrna O Individual Receipt 00 to LQ l0e'- {'?9 fV N H N O ? LL "a am ?- W o?u?p U. a co J r W ?ti m~ o= Na e as QQ?= L N= J J fVll Q V ..? E o # id m 0 _ 0 a °o ?Np O V co O ?Q "22 IX 2O 0 ? r _ ?a Q?- .c O CL 0 =VU .?.. ca o _ co r- .0 w I t- ., - _ 0 -j W G G .? S v O L - O r - -'--"'-_ a a = to a Ln _ L N = 0 A -?...?? Z e i- N N N OOet W":§ Sd a Z Ce) W r w0a ZZZ W W iL J ?ZQ Wog `M_ MIL C O • a i^ w S. 9 0 .00 !ffi •` '.p a a a g o l < o Li C 'W ?O t) 0 1 ' 6ort . Sender's Address 1D4Y Lost aura hLMi SstL m j Certified Mail Recel • 'M + cLrurs W MM 4 ? A ttorneys at law Suite 935, O ne Penn Cooler 1617 John F - Kennedy Blvd. Philadelphia, PA 19103 to 1.215.665.1133 fox 215.5632910 www.mnlowpc.com d S. Alawiu DoEn ba Nl Ba d Cerfl o Creditors' tights law American Board of Certification -Jotinn NeedMittbi Member PA B Nl Ber Thomas t. Dominczyk Member NJ, NY E PA Is Charlene A. Taylor Member PA Ber March 28, 2008 VIA CERTIFIED & REGULAR MAIL CAROL K MURRAY 2316 CHESTNUT ST CAMP HILL, PA 17011 Our File No. 6354 RE: FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY v. HEATHER A HOWARD &' CAROL K MURRAY CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 Civil Term Dear Ms. Murray: 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 31, 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 215-237-4571 and ask for Kim Crosby. Thank you for your prompt attention to this matter. Very truly yours, MAU CE & NEEDLEMAN, P.C. Ye-ne. Taylor, Esq. CT/tam Enclosure New Jusey Office Maurice 6 Noedlema, P.C. seite 2007 5 Wafter E. Foram Mycl. Flemiroon, NJ OU22 lel. 908.237.1558 fox 948.231.1551 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 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 (213) /89--/161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY. Plaintiff V. HEATHER A HOWARD & CAROL K MURRAY Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS IMPORTANT NOTICE _ _ CAROL KIVIURRAY DATE:-March-28; 200.8- 2316 CHESTNUT ST CAMP HILL, PA 17011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 JUDGMENT 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 ELIGLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURI & NEEDLEMAN, P.C. BY C'Wene A. Taylor, Esquire Attorney for Plaintiff Top Of the page -! ?m S µail yVCtH4UT Certified eceipt service f Return R Rece+pt card) (No R•turn Certified Mail Label 0 with Postage Attached D O SDC'magoo + + + + Address 100' pe'verY Return Address + tr N c- a v CL. 'rt C. '11 rn r DULL 133 et Z UJ Q= o- W Uj w 070, ?0 200- Certified Mail WITH 0 Return Receipt Service Itece;pt cord, (Uses Return Certified Mai' Label, Card, and Postage t m` E-- v 0 t individual Receipt 4! ?; ?cv N w to r am? a c` cti r U. 0 w F? 0 enders AddreSS CL r 0 N ? ? Q aYV= M aVNU 0 r p o t'f r7" W w I w 009£ W10:1 sa U 0. M own=. U301 ?c ISO. to r e- No t3 Q N ?G U = CL. c? V NU '= r a o ? c`'a c`h U (? N .........,,,... a :$s a Oak pptig SSU Vommo EYi? ZOSC i 0 pei'very Address • ,1""'= , LO?.ur{,rt?rS?. SHERIFF'S RETURN - REGULAR. CASE NO: 2007-07667 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY LLC VS HOWARD HEATHER A ET AL SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOWARD HEATHER A the DEFENDANT -at 1239:00 HOURS, on the 10th day of-January 2008 at 4201 GETTYSBURG RD LOT 16 CAMP HILL, PA 17011 by handing to HEATHER HOWARD 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 Surcharg3 So Answers: 18.00 15.36 , 00 10.00 R. Thomas Kline .00 43.36 01/10/2008 MAURICE & ATL'GDLEMAN Sworn and Subscibed to E before me this day of , A.E 0?4 SHERIFF'S RETURN - REGULAR CASE NO: 2007-07667 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY LLC . VS HOWARD HEATHER A ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MURRAY CAROL K the DEFENDANT- , at 1910:00 HOURS, on the 31st-day of December , 2007 at 2316 CHESTNUT ST CAMP HILL, PA 17011 by handing to CAROL MURRAY 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 6.00 Service 15.36 Affidavit .00 Surcharge 10.00 .00 31.36 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 01/10/2008 MAURICE & NEEDLEMAN By : Deputy Sheriff A. D. 0?4 Request for Military Status Department of Defense Manpower Data Center ANNSAk, Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUL-23-2007 07:02:24 Last Name First/Middle Begin Date Active Duty Status Service/Agency MURRAY CAROL 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. 14 )6t fox. 010141t4_ A?M_ 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.dpfenselin_k.mil/fao/pis/PC09SLDR.html 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 7/23/2007 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: BVXSBADMQUO https://www.dmdc.osd.miVscra/owa/scra.prc_Select 7/23/2007 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUL-23-2007 07:01:12 ,c Last Name First/Middle Begin Date Active Duty Status Service/Agency HOWARD HEATHER 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. 14 y6t If[. 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/t)is/PC09SLDR.ht_mi 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 7/23/2007 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:BWDVSJKAKXM https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/23/2007 t3? ?t 0 ? O 03 a b n cz M c ?:=t` t , 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-/161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7667 Civil Term V. HEATHER A HOWARD & CAROL K MURRAY Defendant(s) (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $7037.16 on J41710$ (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. Protho /Clerk 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)