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HomeMy WebLinkAbout07-7671,r 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 Defendant(s). Plaintiff, V. 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. DEBORAH ANDERSON 411 N 2nd St # 1 Lemoyne, Pa 17043-1107 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 Attorneys for Plaintiff Le han demandado a usted en la corte. 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 demanda 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 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. DEBORAH ANDERSON 411 N 2nd St # 1 Lemoyne, Pa 17043-1107 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, Deborah Anderson, is an individual who resides at 411 N 2nd St # 1 Lemoyne, Pa 17043-1107. 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 January 31, 2006, the Defendant(s) entered into a written M t 0 or Vehicle Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of obtaining financing in the amount of $22115.94 at an annual percentage rate of 16.890%, in order to purchase a certain motor vehicle, 2006 Ford Focus more particularly described in the Contract (hereinafter referred to as the "Vehicle") marked as Exhibit A. A copy of the Contract is attached and 5. Pursuant to the Contract, Defendant was required to make monthly payments in the amount of $391.98 for a period of 48 months until the loan was paid in full all as is more fully set forth in the Contract. 6. Defendant failed to make any payments, and is therefore in default of the Contract. 7. As a result of the default by Defendant, and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant giving the Defendant the opportunity to redeem the Vehicle as well as notice of the sale date. 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 $8600.00, however a balance of $6136.09 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 $1533.28 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $7669.37. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant, in the amount of $7669.37, 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. A C ARLENE A. TAYLO , 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. r BY: CHARLENE A. TAYLOR, ESQUIRE DATED: December 14, 2007 cis" D LIN Comparry s p.-WJ#A inaree(9) You want Creg9 LNe hqurarne. Buyef Sgrs 004k", ft- Ctes ? DWbIINy,r.j-- 5 P;;;--WVA Insured(s) You ware CrsdN Obabeky hwwand- Buyer Signs Co-Uuyef Sins OTHER OMONAL RMLI IANCE C.-". a.a P-W--M m...... 010JIM T.aa . u.an. MI9 , S Av-N;A JI FIB -tirM--- s--Nf By No* .1. You wwe nr op9ww tnwr..n for wht.h W-*- naee.d b-. ew.34- Cssulw sigm AANI"PNT !m- .1N9w wd.. ?. s.er mn..nsr ar moor ??.1... r 9.u.Ya eenr, oer..9? ..e moor. of Mlw siwpn thb ernnar _ c'?ti T JIB' .'?6Fd1P7di'?.°i'ai? `°"'O? °n _. >/wee .rh .ne.ir . 9? 1NC ? MECW1111Sf O'71.?/ ra. l?H.?? iei?aavWO; ww?vwrww? See 07WA WE FOR A001IpN1L AGMER ITS ----- ORKiMAL .. EXHIBIT E14 "'PRN"' Ford Motor Credit Company P.O. Box 3076 COLUMBIA, MD 21045-6076 (600) 677-0730 P04XAFW200010 DEBORAH ANDERSON 411N2NDST#1 LEMOYNE PA 17043-1107 NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. Ox PRIVATE SALE: We will sell the property described above at private sale sometime after 15 days from the Date of Notice shown above unless redeemed by You prior to such sale. PUBLIC SALE: We will sell the property described above at public sale to the highest bidder on the date below (or any adioumment date). The sale wil be held as follows: Date of sate Time of Sale Place of Sale You may attend the sale and bring bidders if You want. NOTICE OF REP0551=*51U v The property is presently stored at: BEN RECOVERY BEN ?Y?7Ti?S?n - 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 unde your agreement; 1) The buyer and any cotwyer named above; 2) Any dealer/original creditor named below; 3) If there are other OeoDle. they are named on an attachment sent with this notice. Date of Repossession 05-11-2006 Date of Notice 05-12-2005 Date of Contract 01-31-2006 Account Number: 040203260 Buyer DEBORAH ANDERSON Cobuyer DESCRIPTION OF PROPERTY Year 2006 Make FORD Q New ? Used Vehicle ldentir i n Number: 1FAFP34N06W116355 Model FOCUS Body 4DR HOW TO GET YOUR PROPERTY BACK To get your property back, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 14,143.41 Plus Costs: Repo Expenses $ 385.00 $ $ Plus Late Charges $ 15.66 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ - TOTAL $ 14,544.09 (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 15 days altar the date of this notice at the EARLIEST. After that you can still get it back any time before It's actually sold. If you do, wall have no further claim on IL But the longer you wait, the more costs (Including repairs) you may have to pay. if you have any questions about this, please call us. ? The properly has been (or will be) returned to: (desler/original credrW Under out agreement with your dealer/original creditor, the dealerforiginal creditor is to sell the property and pay you any money left over. if you owe moray 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 bus office. Thereafter, the personal property shall be disposed of accordingly. ? Creditor has assigned to its qualified Intermediary (QI Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above PAYMENTS: AM payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer is not accurffie 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 dealedoriginal creditor to make sure that any insurance has been cancelled. You have a right to get credit for all premium refunds. JESSICA A. SNYDER CUSTOMERICUSTOMER FFNA 11ee6-37 Jan OZ PreNMis bAlons may NOT be used. whines: U.S.A. EXHIBIT D Name and Address of Sender Lason Ch typgyLl?li or senim. 38120 Amrhe(n /10 ? coop o R*cwftd Nery('^mw110^ao Livonia, MI 48150 ° OWN rycor,R_w. 0 RNUM geco" kr Merdnrm . Md ? swabxs confir+nalion Inured nnY• ? • U0519120573 3983 83 h1eN..e Qldne, $H6 Ch5 aYw 6 DP ? Penq MA-037388895 7006 0100 0007 2781 2094 MARK G. SHUGARS 1428 ROBERTS VALLEY RD RISBURG PA 17110 ---- '? I utu?roaor 040203260 I r SLOW Nere TAY 12 20M 4 ...ly S k! ? .4 I --_ -: :'k EBORAHANDERSON 7006 0100 0007 2781 2100 U0511/20573967 7006 0100 g007 2781 2131 I _ 411 N2NOST#1 GLORfALORIA J- 3 LEMOYNE PA 17043-1107 1 J. WINSLOW 1 I ; 4 U0511/20573965 7006 0100 0007 2781 2117 P-028665897 - - -- --- --•- •-----._ _ _. _ DENISE ADENS 5• 6037 GERMANTOWN AVE PHILADELPHIA PA 19144 __..- 8. 00511/20573966 7006 0100 0007 2781 2124 P-038509841 7 DAVID A. ROWAN 900 NORTHWESTERN AVE PHILADELPHIA PA 19128 8. - -- 1 W-7 I IlOcw"d Y No oh .1.__-or-._. meue.Per(Nem.o/mewlyyemplor.y .. I _ 392 SPRINGHOUSE RD I HARRISBURG PA 17111 I U0511/20573968 , BA-039954614 7006 0100 0007 4-D GLADYS SANCHEZ 2781 27,48 98 BLUE RIDGE _ w LEVITTOWN PA 19057 77 L ? w •, - ?v _u w Sea Privaey Act Statement on Raveme Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 21045-6076 800 6770730 DATE: 2006-06-21 P050MO0000075 DEBORAH ANDERSON 411 N2NDST#1 LEMOYNE PA 17043-1107 STATEMENT OF SALE Account Number. 040203260 The following property has been sold. Year Make Model Vehicle Identification Number: 2006 FORD FOCUS 1 FAFP34N06W1 16355 Balance owing on your contract (1) $ 14,159.09 Deduct: Finance Charge Rebate (2) $ _ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 14.159.09 Deduct: gross proceeds of the sale (4) $ 8,600.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 5,559.09 Add: Expenses of retaking and storing, and (6) $ 543.50 any attomeys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ 0.00 Other: (8) $ 0.00 (9) $ 6102.59 Deficiency** 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 85216-6508 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 EXHIBIT FFNA11990 01/04 Previous editions may NOT be used. ^ -43 c) F rv oN l -43 c7 Y C-) ni rx) p rn' co C SHERIFF'S RETURN - REGULAR CASE NO: 2007-07671 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY LLC VS ANDERSON DEBORAH MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ANDERSON DEBORAH the DEFENDANT at 1040:00 HOURS, on the 28th day of December 2007 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013-1107 DEBORAH ANDERSON 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 18.00 Service 19.20 Affidavit .00 Surcharge 10.00 00 /47.20 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 12/28/2007 MAURICE & NEED 1 By: Deputy 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 15) 789-7161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff, V. DEBORAH ANDERSON Defendant. CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7671 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 the Plaintiff, and against the Defendant, DEBORAH ANDERSON in the amount as follows: Principal Amount $6,136.09 Interest to Date $1,908.09 -Gests- 95.918- a,04*48 TOTAL 68'17 j&8 MAURICE & NEEDLEMAN, P.C. BY: HARLENE A. AYLOR, ESQ. Attorney for Plaintiff Date: April 23, 2008 a\4 t ???aptp 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 CUMBERLAND COUNTY LLC, A DELAWARE LIMITED COURT OF COMMON PLEAS LIABILITY COMPANY Plaintiff, CASE NO. 07-7671 Civil Term V. DEBORAH ANDERSON Defendant. CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on February 13, 2008, to Defendant, DEBORAH ANDERSON, 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 February 13, 2008, 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. BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: April 23, 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 15) 789-7161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff, V. DEBORAH ANDERSON Defendant. CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7671 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: DEBORAH ANDERSON 411N2NDST#1 LEMOYNE, PA 17043-1107 MAURICE & NEEDLEMAN, P.C. BY: ARLENE A. YLOR, ESQ. Attorney for Plaintiff Date: April 23, 2008 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 215 789-7161 FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY LLC, A DELAWARE LIMITED COURT OF COMMON PLEAS LIABILITY COMPANY Plaintiff, CASE NO. 07-7671 Civil Term V. DEBORAH ANDERSON Defendant. 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 February 13, 2008, she mailed a written Notice of Intention to File the Praecipe to Defendant, DEBORAH ANDERSON, at 411 N 2ND ST # 1, LEMOYNE, PA 17043-1107 by certified mail, article number 7155 5474 4100 7336 7674. A copies of the receipt evidencing said mailing is 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. MAURICE & EDLEMAN, P.C. l BY: C RL NE A. T LOR, ESQ. Attorney for Plaintiff SWORN TO AND SUBSCRIBED befor in tlys,;L?day of , 2008. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Agnes geiland, Notary Public City of Philadelphia, Ptnadhla County .20, U09 Jan My Cornfnission ?' L-- Member, Pennsylvania Association of Notaries February 13, 2008 Our File No. 6193 ptiorneys at ka Suits 935, One Penn (eater 1617 John F. Kannsdy Blyd. Philadelphia, PA 19163 tol.215.665.1133 fox 215363.8910 ww w.mnlawpc.com Donald S. Maurice Member NJ Mr Board Cedif6xl (roMfors' Nights UV American loord of Catilkatisn Joann Needleman Men her PA a N) Ba Thomas B. Domioczyk Member NJ, NY E PA Nor Charlene A.7oylm Member PA Is VIA CERTIFIED & REGULAR MAIL DEBORAH ANDERSON 1101 CLAREMONT RD CARLISLE, PA 17013 RE: FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY v. DEBORAH ANDERSON CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 07-7671 Civil Term Dear Ms ANDERSON: 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 12/28/2007 . Unless an answer to Plaintiffs 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, AKVRICE & NEEDLEMAN, P.C. Charlene Taylor sq. CT/jm Enc New Jersey Olike "rice 8 Nowleamn, P.C. Sells 2007 51BaNer E Tom Blvd. Flemington, NJ 08822 iel. 901.237.4550 fax 908.237.4551 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 /?3y--/ IX) FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. DEBORAH ANDERSON CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7671 Civil Term IMPORTANT NOTICE TO: DEBORAH ANDERSON 1101 CLAREMONT RD CARLISLE, PA 17013 DATE: February 13, 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 MAUFjhtTN 8c NEEDLE , P.C. BY CHARLENE A. TAYLOR, ESQ Attorney for Plaintiff SDC-3900 '! Top of the Page -! p . .com Q Certified Mail WITHOUT Return Receipt Service (No Retum Receipt Card) O Certified Mail Label with Postage Attached D O M1 `O m M 1? M1 G C2 roll S name S NONE © Sender's Address © Delivery Address 10 or Return Address 'J cc i M C UWu wog Q rl 1 jI. .4L O Indivjuaf:Rijceipt 43 .? i E o • 1 LP ,yr) A 1L •r ?r- m oe m W M1 u rr yy ? l ..ap Q fv ?... ? r / V W: V o: u,. l ' Certified Mail WITH Return Receipt Service O (Uses Return Receipt Card) © Certified Mail Label, O Delivery Address Card, and Postage rat ?' ?, :D '.M1 m C - :r V - H N Wj0j $d R `'i ' ?11ti3 G ti? L 1 a Vm, CO LO ? Ir Lib 00 IX F- qr' O 0 0 Q w as ? gW 0U? O 0 ?U T- Z ? D' Ln r 0 00 Q wa = gW UCf) M r N W O 1.10 ?U i ! j o I £ 1 lil c !1 M '4q ? ? ao e ? l o 1 ? M O ; .i X( o v d a o • + IApI KI'1i47 VUU4+ M0A 19E4 COtb 11l.A5 SSSC • Ew'fKt• MtN'S • LLtCLG's+l-IV + 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) 89-/161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff, V. DEBORAH ANDERSON Defendant. CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7671 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 she represents the Plaintiff in the above entitled case and that the Defendant, DEBORAH ANDERSON, is over 18 years of age; the occupation of Defendant is unknown and to the best of Plaintiffs knowledge, information and belief, the 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 & NEEDLEMAN, P.C. SWORN TO AND SUBSCRIBED before me is )day of aH- , 2008. Notary Public BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA Notarial Seal Agnes Beiland, Notary Public City Of PhlladelpNa, Phlledelphia County MY Cmnmisslon Expires Jan. 20,20M Member, Pennsylvania Association of Notaries C?o -(k CIO, : T ? , • ` 00 r CC;J '-C 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 Z59- / 161 FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff, V. DEBORAH ANDERSON Defendant. CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 07-7671 Civil Term (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of-$&I- $ on 01 $S,M4,18 (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. ? gk*y/ Prothoneti *CIer 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)