HomeMy WebLinkAbout07-7782MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene 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 COURT OF
Plaintiff COMMON PLEAS
V. CASE NO. 67- 7ggar &VO
GEORGE W LONGAKER JR
Defendant(s) j
PRAECIPE
TO THE PROTHONOTARY:
Kindly enter judgment against the Defendant(s) in the amount of $11266.96, in
accordance with the attached Certified/Exemplified Judgment of Docket No.. 287-06 of the Pike
County Court of Common Pleas and index said judgment against the Defendant(s).
MAURICE & NEEDLfMAN, P.C.
BY:
JO/NEEDLEMAN, ESQ.
A mev for Plaintiff
Date: November 30, 2007
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene Taylor, Esq
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7161
Attorneys for Plaintiff
- -- - -- -FORD MOTOR-CREDIT COMPANY - Cumberland COUNTY COURT OF
Plaintiff COMMON PLEAS
V. CASE NO.
GEORGE W LONGAKER JR
Defendant(s)
AFFIDAVIT
STATE OF PENNSYLVANIA
COUNTY OF PHILADELPHIA
SS.
JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she is an attorney for the FORD MOTOR CREDIT COMPANY; that she is authorized
to make this Affidavit on its behalf; the address of the Plaintiff is P.O. Box 6508, Meza, AZ
85216-6508; and to the best of her knowledge, the last know address of the Defendant,
GEORGE W LONGAKER JR, is 3345 SUNRISE LAKE, MILFORD, PA 18337 and the
judgment reflected by F-150 of the Ford is valid, enforceable and unsatisfied.
These statements are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to
unsworn falsification to authorities.
ivi Kier N L AN, P.C.
BY:
JOA N L AN, ESQ.
Atto e or Plaintiff
SWORN TO AND SUBSCRIBED
before me this 14 day
of DAI , 200.
r
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Agnes tseiiand, Notary Public
City Of Philadelphia, Philadelphia County
My Commission Expires Jan. 20, 2009
Member, Pennsylvania Association of Notaries
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene Taylor, Esq
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7161
FORD MOTOR CREDIT COMPANY
Plaintiff - -- -- - - -
V.
GEORGE W LONGAKER JR
Defendant(s)
CASE NO.
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
COUNTY OF PHILADELPHIA SS.
JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she represents the Plaintiff in the above entitled case and that Defendant, GEORGE W
LONGAKER JR, is over 18 years of age; the occupation of Defendant is unknown and to the
best of Plaintiffs knowledge, information and belief, Defendant is not in the military service of
the United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and
Sailors' Civil Relief Act of 1940 and the amendments thereto.
MAURICE
Attorneys for Plaintiff
I CUMBERLAND COUNTY COURT OF
- - - -COMMON PLEAS-- - - ---
, P.C.
BY: ?--
E LEMAN, ESQ.
A ey for Plaintiff
SWORN TO AND SUBSCRIBED
before me this j I day
of J)tt,, , 200/
Notary Public
COMMONWEA_,. LTHOF PENNSYLVANIA
H,nad t;r r•;uea?Y Public
itw ?r iadeiphia Coon'
Sir (?[?{'tn tF 1
_ i.:a on I=empires Jan. 20 2009
ASSOClation of Notaries
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene Taylor, Esq
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
GEORGE W LONGAKER JR
Defendant(s)
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO.
CERTIFICATION OF ADDRESSES
It is hereby certified that the parties have the following addresses:
Plaintiff. FORD MOTOR CREDIT
P.O. Box 6508
Mesa, AZ 85216-6508
Defendant: GEORGE W LONGAKER JR
3345 SUNRISE LAKE,
MILFORD, PA 18337
MAURICE &
Date: November 30, 2007
BY:
P.C.
NEEDLEMAN, ESQ.
for Plaintiff
COMMONWEALTH OF PENNSYL VANIA/
COUNTY OF PIKE I ss.
I, DENISE FITZPATRICK,
Prothonotary in and for theCounty of Pike and
Commonwealth of Pennsylvania do hereby
certify that the foregoing is a copy of the
Orders of Court in the matter of FORD MOTOR
CREDIT COMPANY VS. GEORGE W.
LONGAKER JR. Defendant, filed to No. 287-2006
Judgment, that I have compared said copies with the
record thereof now remaining in this office, and have
found the same to be transcripts therefrom. All of
which I have caused by these presents to be
exemplified.
In Testimony Whereof, I have hereunto set my hand and affixed my official seal this 41h
Day of December ,A.D., Two Thousa d Seven.
Prothonotary
I, The Honorable Joseph F. Kameen President Judge of the 60th Judicial District, composed of the County of
Pike, do certt& thatDENISE FITZPA TRICK, by whom the annexed record, certificate and attestation were made and
given, and who, in her.own proper handwriting, thereunto subscribed her name and affixed the seal of the
Prothonotary Of the said County, was at the time of so doing and now is Prothonotary in and for said County of
Pike, in the Commonwealth of Pennsylvania, duly commissioned and qualified, to all of whose acts, as such, full faith
and credit are and ought to be given, a's?well in Courts of Judicature as elsewhere, and that the said record, certificate.
and attestation are in due form of laws and made by the proper officer. ---l
....Pr... ?...........
..........................
COMMONWEALTH OF PENNSYL VA NIA} de dge Judicial District
COUNTY OF PIKE ) ss.
I, DENISE FITZPA TRICK, Prothonotary of the Court of Common Pleas in and for said County, do certify that The
Honorable President Judge Joseph F. Kameen by whom the foregoing attestation was made, and who has thereunto
subscribed him name, was at the time of making thereof and is President Judge of the 60th Judicial District,
Commonwealth of Pennsylvania, Pike County, duly commissioned and qualified, to all whose acts, as such, full
faith and credit are and ought to be given, as well in Courts of Judicature as elsewhere.
IN TESTIMONY WHEREOF, I have hereunto set my hand
nd affixed the seal of the said Court this day of
C'? AA .D. 2007.
..........
Prothonotary
1G ??-,u
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7151
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
GEORGE W LONGAKER JR
3345 Sunrise Lake
Milford, Pa 18337
Defendant(s),
NOTICE
You have been sued in court. !f you wish to defend
against the claims set forth in the following pages
you must take action within twenty
this complaint and notice are served( b) days alter
a written a p entering
pearance D personally or by attomeyand
filing in writing ting with th the court your defenses or
objections to the claims :;et forth against
You are warned that if you fail you. may to do so the case
enuYred Proceed without you and a judgment may be
against you by tfC court without further
notice for any money claimed in the complaint or
for anv other claim or relief requested by the
other rig You may lose money or property or
other rights important to you
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
PIKE COUNTY COURT O
F COMMON PLEA S
Case No. '
M N
a
?.J -... -j J ...
--i_ y?
-------------
CIVIL ACTION COMPLAINT
A VISO
Le ban demandado a -led en la cotte. Si usted gttiere defenders,
de estas demandas expuestas en lass pagittas sed dunesfe terse
1111111c (ZO) dias de plazo al partir de la fecha de la demanda y la
notirxacion. Hace falta asentar una comparencia escrita o e11
n
persona o curt un abogado y entregar a ?a torte en
defensas o sus objeciones a las dentandas toms escrica sus
en contra de su persona.
Sca a0sado que si cured no se dchende, la torte tomara medidas y
Puede cmrtinuar la dentanda en Contra suya sine t 0
Y requ oma d Ise
notification. Ademas, la torte puede decidir a favor del drmandantc
Uste Pw que
i usted cumpla con todas 'as provisiottes de esta demanda,
rnPo rtanles nces pr para s us usted. o sus proPiedades u otros dercchos
mpor
YOU SHOULD TAKF. THIS PAPER TO YOUR LAWYER AT ONCE
IF YOU DO NOT HAVE A LAWYER OR CANNO"f AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
PENNSYLVANIA BAR ASSO('1AT10N
LAWYER REFERRAL SERVICE
P.O. BOX 186 HARRISBURG PA 17108
(717) 238-6807 or (800) 692-7375
LLEVE ESTA DFMANDA A UN ABOGADOIMMEDIATAMENTE.
Sl NO 7'IfiN1 ggOGgDO O SI NO TIENE EL DINERO
UFICIENTE DE PAGAR TAI. SF:RVICO, VAYA EN PERSONA
O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENC'UENTRA ESCRITA ABAJO PARA A AVERIGUAR DONDE
SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7151
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
GEORGE W LONGAKER JR
3345 Sunrise Lake
Milford, Pa 18337
Defendant(s).
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
PIKE COUNTY COURT OF COMMON
PLEAS
Case No.
J
CIVIL ACTION COMPLAINT
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•
Cy§ -- ,,,? , } -
,
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Plaintiff, Ford Motor Credit Company, is a Corporation with its lace
Box 6508 esa, Az 85216-6508. place of busyness at P.O
2. Defendant, George W
Longaker Jr, i
Milford, Pa 18337, Is an individual who resides at 3345 Sunrise Lake
.
3. At all times relevant, the Plaintiff was in the business of loaning
installment sales contracts, including but not limited to the note si e g money on motor vehicle
hereinafter more fully described. d by Defendant(s),
4. On or about May 31, 2001, the Defendant(s) entered into a written
installment Contract, (hereinafter referred to as the "Contract"), for the purpose of obtaining
financing in the amount of $30,249.94 at an annual percentage rate of 6.900%, in order to
purchase a certain motor vehicle, 2001 Ford F-150 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 $597.56 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 October 26, 2004, 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 $7200.00, however a balance of
$12263.12 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 $622.51 and which will continue to accrue.
11. The total amount due and owing at the time of the filing of this complaint is $10977.87.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $10977.87, well as any additional interest and costs that may accrue and such
other and further relief as this Court may deem equitable and just.
? submitted,
& NEEDLEMAN, P.C.
1Ovt?*S U. DOMINCZYK, ESQUIRE I ERU
Attorney for Plaintiff
VERIFICATION
I, THOMAS R. DOMINCZYK, ESQUIRE, verify that I am the Attorney of
record for Plaintiff, FORD MOTOR CREDIT COMPANY, and duly authorized to make this
verification on its behalf; that statements made in the foregoing Complaint are true and correct to
the best of my knowledge, information and belief.
These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to
unsworn falsification to authorities.
BY:
DOMINCZYK, ESQUIRE
DATED: January 31, 2006
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DINONANN¢ FIRMA 18328. ??
rcmwavywpdCaiy..IfowLnowbe06v.rwaw?AreNr.krn/? 1'-, lost' ? •qr
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s. Atnosnb paid on yen WMW (Sasar may be ml amino b portion of otees amountl
To Imurenad Compwlirae for .
Credit Lih lnatssrtos (tor tsnn of eorwaa)........
,._........... S N ??I
craft DisaWNq Insurance Ifor born of
(Term Months (EdlmMs I S-- -M / A. .
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ANNUAL FINANCE Amount:. T9W of ofil sew
PERCEE1jTAGE CHARGE- Flnwmd ' Pyaw t ! I Price-
RATE Tty"Aw m The aMWMIof 1 The annuw % .: The wtw .or
The oast a<your the weds wo ?1 P &Adod yeu wr he.j, a.y. puroheee an
mewh as a Yaarty nds cow yop You ? dar"'R'en y- a"%
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i 05/31/01
T„--- DATE
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(yftrarlplorwsrvMiMS The
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rrte.-aM..? w
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YOU MAY OBTAN VEHICLE INSURANCE
FROM A PERSON OF YOUR CHOICE, `
YOU ARE NOT RP_QIMM TO OWAIN
MM UFE -CREDIT MANUTY AND
OTHER OMONAL Rt@LntA#m TM
CONTRACT V&L MT INCLUDE THEM
UNLESS YOU SKIN AND AGREE TO PAY
THE PREMUM.'
THIB CONTRACT DOES NOT MICLUDE
LIABILITY VAURANCE COMRAGE FOR
GwLr INJURY) AND PROPERTY
DAMAGE CAUSM TO OTIIEW
-------------------------------------
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ADDITIONAL AGREEMENTS T
Paibt yrnamite and rqwmwy meam You not male am' - F. D*hw You WE be In defoult ft.
' May are .
tkhme wNhoul 0 km & fib b You Y Prepay your d.bl N arty
am* Man- ono," yw apw b? pay IMr wN . F- Id
an R The
an your
P 11 Pwma The §dM tlrlarhq dWp stay 89010W #0
Fl-- I Y. -ties your PaPnalb later than
ad*duMd dew or If im ytatt Qa KhedWed aarowk TM
MCNW % YaN PDPMft 01141 b aW 1141011141 and unpaW
PCart
or a*
TI'* ua? Saar Cl-00 than 1D ft AVOM FUlarbed.
PNDelttapa Rail to ft WOW M1? Fk by appift gad (Or e ft adW
610 ft unpaid Mart Fvwwsd b ouiltandrg, w Bra , m w
? VA not Its" a mm to mkmkab ft cWhe
agrees•
6. Security b11enak You 9t- the Creditor a naaskyr tflig" kh.
2. An Yom :
2. rt+nay or 9001111 noaww to f vehicle: aM
Banos Ilree11um11 and aaavl- coryra0y onam d for you.
4o aB 8000114 Pymant or N amomit you awe in a" cwtinm . r
your 011- apeananh in we contrad.
C. Use d VahlOle - wARRMfnm : You mop take Cara d
a
an vehide. » v OkM and obey all taws In usln9 k. You may rhot ate or rang
YOU wN 110 110 and you must Keep h tee from to sums d others.
Yo1 rree or pehwrk the hrp of Vre vehlols oubme of ate
LWW States, err-pt far UP 430 dye In Carlado or mask o.
alw the PON waft" eorh- t d a* Creditor. M the vafails is
at tm used for peesoerl we and Mrs Creditor, or
n a>d•11? a MR)ItPn wrartany or
date fo Yrb eadre`R y MlrepNep arrrMMa ft
ou I* mwdwMaw-y sad mm" for a Partfoutr Pumme no w no such
undarebnd and tr9raa am tlr
lappit"
D
less . Raufsww you moat ktttee yo~ NW ,ft Credior monat
type - Nnotme or ord dente" to the wrhk;b. The Creditor "Wel approve 911
ktftww ca. H the Cradibr Obbifle a rdaahd on
tataar" or aarvlee 0106"0011. 011 Credbr oil
6*0111 aom ow you owe. Mather or net tea yektrye Is
dmab You must pay for It M H b, lost dannpaq or
Gadl ell try b? kh§Jmm sea srrawn an as front an
Oa
w not mrRapp 0mucad for ma term .craw,.
Creditor
00"era0aa CoN mm viim go arawra corn for as if to"
0000" ft" 0 (odor rm ? for a atorbr term or he may on 1u
00
ME taw You once for the rrhota11?* Cannot he seY oa. M
to a* wat payments sue. The Cratlk VAT vwV be to made
0' Lob (maw: Poraon of each Payment You will lhave b psy s boa dome on V*
chrps k show on 110 m.L de m s Ilan ten dye ba. The
not canna your debuh or ffwmn I- yoof a u wn Mpgynwg
M n 11011
ve1Y idler they" we dw. The C?adlor may inks pe >?
mntad, t two b any dabyq.
t. You do not make • payeha11 when 1 10 dtN; of
2. Y rft* 08*4 MtbmWlon an yar crock
l Your rN11ob rs aabad by inY klod, tM-alts or Aiparw
s
r2fimmad lowly and b no PVn;dy and aro ndaa Ral?
4. Y b you; or
5. You 110 nab-w*kY Paulon or oft in Mad apairm y., or
beep any dha promba in I* cww at.
90 You - L, deft^ as Credlbr nray mgtdra You to Pay at
t Arnow* orrp
Fi
He "y repowe" nn- 0-96 and at o cr? dw undo dw thin o0 Part eq '
am -- SS Y ",
MY And
Lab 9000 bww in a on _fill vdNcld When MPoaee11ed and
hdd Own for you
M
*0 may that ine -rd- re MKan bads, ha Mt serW a nonce. The nodoe
Maw on ar te RIWY n (buy twdc ttla velNtla, k wit also
".Nets up b the orna 0111 CredOpt 11114 It p? my hdaMn Me
you do 1111 redeem the veMde, it will be odd. - to aN R If
TTa Cradab wit tlae an mpney film ft *0#&, lMa the allowed
-DM+ees. b pay the a,nwH etkt 9wrd on m
x conlreot
hot for am*. nd into it * Of h0ft b Make ft
are. M P.14.d in, *
allowed, b, Vw's e. LM'Yas' flea and W* 01111111 P-Itad by bow we
The CradItor wit pay you any monay bft (a
Pay any molly SMI oaft atier ft sets b ate
If you do not pay ft nowt *tw the Creditor OW.
U* You ? Pay may d-" you Interest N the hlphset tawM rats
C. Ganes: To Caved Ford Motor CadH Company about of
4
10 this c= K -t (-(900) 727 mw. The taw or Pautaylverk apptp
in ahla oor11tecL H VW M cop not allow as of ft o9r0em is
rear of ? ones PW am not alowed wat be void. The
tact Will M be good.
NOT" - HOLDER
CONTRACTNL9 OF THIS COMSUNM CREDIT SUSJWT DEFENSES VVMCH THE DEBTOR COULD ASSM
AGAINST THE SELLER OF ADS OR SERy
O$TAMiEO PURSUANT HEREOOTO OR ttfTF1?3TILE
PH DEBTOR ROCEEDS
SNAIL HMOF. NOT : EXCEED HMEIINOER BY
THE DEBTOR HEREUNDSL AMOUNTS PAID BY
Ua W 1feb: VaAbte SO)MS Guide, if
you We vat11ale Wt h rhea oawaoL h11wel recumdOns m ? i used
.Pedal Buyers Guld11.b be dbpbyad on rte wyldow Of to
v*dcb. THE INFORMATION YOU SEE ON THE
W
THIS INDOW FORM FOR THIS VOWLE IS PART OF
FORM OCT- INFORMATRTM ON THE VANDOW ANY IN THE CONTTRRA?SOFF SA Y PROVISIONS
aU11RAMY
70 Cause Un aster to sell Ilte vehkla deots bas on the ftta of t11s Marva b ete ftYsr, on Cradle Seeh onse"leae oanbae<. each "P&P- of 111111 mntrad pay any person na,
alPn se a Title m..* am Il ate -&W fiIla to ?a below Ile a
hi owed an lift
wlhob amore11 owed am ram orm" orwwAitw "ails ?? Person Mb alprh116elow ape11a a?ql k11 wlp
Il11111a br Ile
one or mac Of ON toaohvkha (a) 91"ea ft more, on pay area GLtanl`nly
- lie arse " apeee to bs b to even Il Ile Credit. dap
WWI* n W- drarhvrrbr; w k) mere" my ??b!faun Gum anbr abo Na t shi r a n 111see N R +t o In pet to
anyDOIIbaCt ad fttb Quarant7 r IlW arm of altnil
Gu received a
aa for -. oomf11elad DOPY Of
tMa.
411111'111111
rohnga 0e? P?.r?..u.,, •^?
FC I *=
.»PRN-
Ford Mob Credl Comperny
P.O. Boa 31111
TAMPA, FL 336313111
(a7T) 349-52M
GEORGE W. LONGAKER JR
PO BOX 85
DINGMANSFERRY, PA t5328-0M
Dolled Repossession 0146.2005
Dec of Notice Doll of Convect
01-082005 0531-2001
Account Num1 w: 027581084
Buter GEORGE W. LONOAKER JR
Ccibuvor
DESCRIPTION OF PROPERTY
Yaw hMka
2001 FORD Q New
? used
V4tk* Idsntlfkefa+ Number.
IFTRXIO SIN1A573M
Model
F150 9ody
4X4
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke proaisaa in our agrsomorit.
?x PRNATE SALE: W willsal the property described above at
pnvws sale sometime sfor 13 days from On Doll of Notice
shown abovs Has redeemed by you prior to such sacs.
KMM JC SALE: We will see the prop" described above at public
ode to the highest bidder an Vne date below (or any adpummerd
dale). The sale will be held as follows:
Dots a Sell Time of Sale Place of Sao
You may atterd 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 this amount you owe. If we get
less money than you owe, you YMI 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.
The proWy is presenlly,swred at: NATIONAL AUTO DEALERS
EXCKANC E POBOX 539
NOW TO GET YOUR P.ROti111111IPfdtt1f10111
To gat your property beds. pay in this smart by certified check or
money order before the vehicle is sold,. ,
Unpaid Balance E 18.822.at
Plus Cosb: Retire M!s $ 395.00
s
S
Plus Late Charges $ 71,21
Less Finance Charge Rebate S
Laos Imun A Premium Rsbso S
TOTAL S 19.280.62
If you need more information about the sate call us at the (Pk,s exper a"' incurred N default at the finis of repossession weesdw
telephone number above, or write us at the address above. 16 days and lose rebses Moved after Me eve of this noeca)
Your property wont be sold wtil 15 drys after the does, of this ndke at
If you want us to explain to you in writing how we have figured Via EARLIEST. AM or that you ern sell get n beck awry fir's before it's
the amount that you owe us, you may call us at the telephone saw
number above, or write u8 at the address above and request a if you do, weU have no further e4im an it out to longer you wait, the
written explanation. n+are wee (including reps") you may thews to pay.
If you have any quesdom about leis, please call us.
We are sending this notice to the following people who have an j
interest in the property described above or who owe money under!
your agreement: 1) The buyer and any oobuyer 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:
(drler/aigiral creditor)
Under our agroor et with your oealwforigind credloir to daderlaiginsl aredilix Is b see the property and pay You any money left over. If you awe morey
after the ride, you will pay N to the deelw/origind creditor.
? PERSONAL PROPERTY: Any pwsagl property farad In the vdnlcle may be r0clelmed or you witiln sic rod 00 days or, In accordance with stall low, by
earbrc6ng en ofNcs. Thersofter, the personal property shall be disposed or accardingty.
? Credhor has assigned to Its qudl9ed intermediary (QI Excherpe, LLC) he rights (but not its eblipatlora) will respoet to the sale a each vehicle listed above,
PAYMENTS: All payments to w must be by e"fied cheek or money order.
MILEAGE DISCLOSURE: It you are swam the the rritsege reflectW on the wtieN'a odormler is not accurste for any reran, phase contact us so VW we
can accurately repo. the vehicles mileage.
INSURANCE RIGHTS: It you don't well to gat your property beak. call the Insurance cc- .wry or the dealerwdrigkmd ced0or to make owe Met any kronaence
has been cancelled. You have a right to gall credit for all premium refuels.
CAROLYN L CASSICK
FRM 1ION47 Jw ox P- w¦-"NO1 W weer --- .... ?_-..- - - CUSTOMER/CUSTOMER FILE
p,o,re.. Ursa.
Ford Motor Credit Company
PO BOX 3076
COLUMBIA MD 210456076
800 6T70730
DATE: 2005-03-19
POIRGH00000037
GEORGE W.LONGAKER
PO BOX 85
DINGMANS FERRY PA 18328-0085
STATEMENT OF SALE
Account Number: 027564084
The following property has been sold.
Year Make Model
Vehicle Identification Number:
2001 FORD F150
1FTRX18L51NA57306
Balance owing on your contract
Deduct: Finance Charge Rebate
Balance less Finance Charge Rebate (1 - 2)
Deduct: gross proceeds of the sale (4) $ 7,200 00
Balance less gross proceeds of the sale (3 - 4)
Add: Expenses of retaking and storing
and
,
any attorneys, fees allowed by law, and (6) $ -- _569.50
expenses of reconditioning and selling.
Deduct: Insurance Premium Rebate (7) $ ___0 00
Other: (8) $ _ -_0.o0
(1) $ _ _ 18,893.62
(3) $ 1 8 3. 2..
(5) $ -11A93.62
Deficiency'' (9) $ ?- 12? 26312
Surplus' (10) $ _ N/A
The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses 8 interest
added to your account (debits).
Surplus* or
-
' 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
194 101
MESA ARIZONA 85216-6508 DEPT P .
O. X1,6
(800) 732-2264 .O. BOX V1,6000
DETROIT MI 48255-1941
FFNA 11000 01104 previous edjbi , may Na, by yyd.
SHERIFF'S OFFICE
P'---,CE COUNTY, PENNSYLI" NIA
500 BROAD STk-cT, MILFORD, PENNSYLVANIA 18337
SHERIFF SERVICE - ----- (570) 296-6459
- --
PROCESS RECEIPT, and AFFIDAVIT OF RETURN 5) copy rfOnls `-OR ,E13VICE OF PR 'SS or the reverse u; the rapt
1 copy 1 tnis term rl.,ice type or ? r n rt Dc not detach any ,;OprE
1. PLA1pIilFF/S/ - - -?
COt1RTNUMBER
N NT/S/ / J. TYPE F WRIT OR COMPLAINT' -
er
SERVE 5. ME OF DIVIDUAL COMPAN . CORPORATION. TC.. TO SERVICE OR DESCRIPTION Of PROPERTY TO B - LEVIE ATTACHED OR SOLD
rc
6. A ORE v reef or RFD, Apartment No.. (NIfy, Boro, Twp.. St to and ZIP Code) -' ---- `-? ?L '
AT
7. INDICATE UNUSUAL SERVICE ERSONAL O PERSON iN CHARGE C DEPUTIZE ] CERT MAIL O RE I5TRE %IAIL? p p ? L.] OTHER ' y!
NoW, 20 I OSTED OTHER
SHERIFF OF PIKE COUNTY, PA., do hereby deputize the Sheriff of
-- Count to execute
to law. This deputation being made
at the request and risk of the plaintiff. this Writ and make return thereof according
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: JHEFUrr OF %KE cpueTY / `?
!dam{ '?f? -
$-? g-? S-,
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION-N.B. WAIVER OF WATCHMAN - Arry deputy sheriff levying upon or attachinc an
may leave same without a watchman, in custody of whomever is found in possession after notifying h y a property under within writ
deputy or the sheriff to any plaintiff herein for any loss, destruction or removal person of levy or attachment, without liability on the part of such
9. SIGNATURE of ATTORNEY or ottx,, ORIGINATOR y such property before sheriff's sale thereof.
10. TELEPHONE NUMBER 11. FAX NUMBER
12. Advance Costs f.?+ - -7
Total Costs COST DUE OR REFUND
. , ae , uv!reOge receipt of the writ I
?'_{.t „a???ffX77vc?/?//1 tb. Expiration/Hearing
16 1 hereby CERTIFY and RETURN that have C O ---- --L2-y y _ C? ??
writ or complaint fd biA ?rsonally served, ave legal evidence of service as shown in Remarks
by descri handling bed on th i
inserted below b ; p have executed as shown in "Remarks '. the
a TRUE and r dualTTIt comppany, PY corporN thereof , etc , at the address shown above or on the individual, company. exu te
,
poration. etc., at the address
17. O 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above- (See remarks below)
113. Name and title of individual served (if not shown above)
19. A person of suitable aeand discretion `?? C ` ?'` ?[•' V ???-?? ?? Y then residing in the de plant
fen's usual
20. Address of where served (comple•e Only if different than Shown above) (Street o RFp, Apartment No., City, place of abode. C3
State and Zip Code) Boro, Twp, 21 , Dace of Service 22. Time
' ' i,5
23. ATTEMPTS •- ?`L'
Date Miles Dep. Int. D to Miles Dep.Int. Date Miles Dep . Int. Date Mil s
?/ > e Dep.lnt. Date Miles Deg
?? LPL
24. TIME OF _
ATTEMPTS Y j
AFFIRMED and subscribed to before me this
day of A _. 20 (? t _C
MY COMMISSION EXPIRES J -)•! L/ . 0(1
I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE
OF AUTHORIZED ISSUING AUTHORITY AND TITLE.
C 7)
, SO ANSV?R. J
7s ff/Dep. Sheriff) (Please Print orb Type) -- - "
ignature of Sheriff
to
SHERIFF OF PIKE COUNTY V I
Di1LFf-",. _ 39. Date Received
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7154
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
Atto s-2rLtaint fjp
10P to Dew a.-ri
ar l: rra. ,lass F
t?lo
PIKE COUNTY COURT OF COMMON
PLEAS
CASE NO. 287-06
GEORGE W LONGAKER JR
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, GEORGE W LONGAKER JR in the amount
as follows:
Principal Amount
Interest to Date
Costs
Attorneys Fees
TOTAL $ 11266.96
MAURICE &-NP-P
$ 10355.36
$ 761.50
$ 150.10
$ 0.00
BY:
LEMAN, P.C.
THOMAS D04CZYK, ESQ.
Attorney for Plaintiff
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7154
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
GEORGE W LONGAKER JR
Defendant(s)
Attorneys for Plaintiff
PIKE COUNTY COURT OF COMMON
PLEAS
CASE No. 287-06
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF NEW JERSEY
COUNTY OF SOMERSET
SS.
THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law,
deposes and says that she represents the Plaintiff in the above entitled case and that
Defendant, GEORGE W LONGAKER JR, is over 18 years of age; the occupation of
Defendant is unknown and to the best of Plaintiffs knowledge, information and belief,
Defendant is not in the military service of the United States, nor any State of Territory
thereof or its Allies as defined in the Soldiers' and Sailor' ivil Relief Act of 1940 and
the amendments thereto.
MA 1? & E?LEMAN, P.C.
BY:
SWORN TO A?VD SUBSCRIBED
bef me thas•_-<?Ico
?'LC•f , 200 .
14
A NOTARY PUBLIi OF NEW ,TERSE
Mv(:nmmiS,ginn Exoiref? 1;tt) 1/20%
THOMASbbT;UNCZYK, ESQ.
Attorney for Plaintiff
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
Attorneys for Plaintiff
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7154
FORD MOTOR CREDIT COMPANY
Plaintiff
PIKE COUNTY COURT OF COMMON
PLEAS
V.
GEORGE W LONGAKER JR
Defendant(s)
CASE NO. 287-06
AFFIDAVIT OF MAIL SERVICE
STATE OF NEW JERSEY
COUNTY OF SOMERSET
SS.
THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law,
deposes and says that she is an attorney at law and that on 03/24/2006(date) he/she
mailed a written Notice of Intention to File the Praecipe to Defendant, GEORGE W
LONGAKER JR, at3345 SUNRISE LAKE
,MILFORD, PA 18337 by certified mail,
article nos. 71555474410024491496. Copies of the receipts evidencing said mailing are
attached hereto.
Neither the certified or regular mail was returned to Counsel's office, therefore,
pursuant to Pa.R.C.P. §403 (1), service has been perfected by regular mail due to the fact
that the Notice has not been returned to sender with' i n (15) days after mailing.
MA RI ?DLEMAN, P.C.
BY:
SWORN TO A?4lJ,"SCRIBED
befo} r)e this, d y'
I of -.... . ,? , 200
' `Notary "OL+'.cf. ?
kNNIAFRLY L -APER.A
A NOTARY PUBLIC OF NEW JERSE1
My Commission Expires 11101/2009
THOMAS00MINCZYK, ESQ.
Attorney for Plaintiff
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7154
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
GEORGE W LONGAKER JR
Defendant(s)
Attorneys for Plaintiff
PIKE COUNTY COURT OF COMMON
PLEAS
CASE NO. 287-06
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was
mailed on 03/24/2006 to Defendant, GEORGE W LONGAKER JR, 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 03/24/2006, a copy of the
receipt for certified mailing to the Defendant and affidavits of service of said notice are
all attached hereto.
MAURICE & EEDLEMAN, P.C.
BY:
THOMAS DO CZYK, ESQ.
Attorney for Plaintiff
Suite 935, one Penn center
1617 John F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.665.1133
fax 215.563.8970
W*"ntawpc.com
Donald S. Maurio
Member NJ Ba
Board Certifies
Creditors' Rights Law
American Board of Certificatior
Joann Needleman
Member PA 8 NJ Bar
Thomas R. Dominczyk
Member NJ, NY, 8 PA Bar
March 24, 2006
VIA CERTIFIED & REGULAR MAIL
GEORGE W LONGAKER JR
3345 SUNRISE LAKE
MILFORD, PA 18337
Our File No. 3073
RE: FORD MOTOR CREDIT COMPANY v. GEORGE W
LONGAKERJR
PIKE COUNTY COURT OF COMMON PLEAS, CASE
NO. 287-06
Dear GEORGE W LONGAKER JR:
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 03/03/2006. Unless
answer to Plaintiffs an
Complaint is filed with the Court within ten (10) days
from the date ofthis 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 908-575-0220 ex. 21.
Thank you for your prompt attention to this matter.
ESQ.
ARTICLE NUMBER:
7155 5474 4100 2449 1496 FEES
Postage per piece
Certified Fee 2.40
ARTICLE ADDRESS TO: Retum Receipt Fee 2 18 40 TTEMPT TO COLLECT A
1.85
George W. Longaker Jr Total PosUge & Fees.
OBTAINED WILL BE USED
3345 Sunrise Lk rS A DEBT COLLECTOR
Milford PA 18337-9648
Postmark
Here
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 742
76
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
215 789-7151
FORD MOTOR CREDIT COMpg Ny
Plaintiff
V.
GEORGE W LONGAKER JR
Attorneys for Plaintiff
PIKE COUNTY COURT OF COMMON
PLEAS
CASE NO. 287-06
IMPORTANT NOTICE
TO: GEORGE W LONGA
3345 SUNRISE L KER JR
MILFO AKE DATE: March 24
?, PA 18337 , 2006
YOU ARE IN DEFAULT BECAUSE YOU H
ANSWER L?] THIS CASE. AVE FAILED TO FILE AN
FROM THE DATE OF THIUNLESS YOU TAKE ACTION
AGAINST YOU WITHOUT A NOTICE, WITHIN TEN
A JUDGMENT MAY BE ENTERED O) DAYS
TO DEFEND AND THEREBY LOSE PROPERTY U MAY LOSE YOUR
RIGHTS . YOU SHOULD T OR OTHER RIGHTS
NOT HAVE A LA TAKE THIS NOTICE TO A LA IMPORTANT
TELEPHONE THE FOLLOWING OFIF`1NICOET TO AFFORD DER AT ONCE IF YOU
LEGAL HELP: ONE, GO TO OR
FIND OUT WHERE YOU CAN GET
PENNSYLVANIA BAR ASSOCIATION
LAWYER REFERRAL SERVICE
P.O. BOX 186 HARRISBURG P
?8
(717) 238.6807 or (800) 692-7375
BYC lr? i??? "/I LI1VIAN' P. C.
THOMAS D F NCZY
Attorney for Plaintiff K' ESQ
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7154
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
GEORGE W LONGAKER JR
Defendant(s)
Attorneys for Plaintiff
PIKE COUNTY COURT OF COMMON
PLEAS
CASE NO. 287-06
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: GEORGE W LONGAKER JR,
3345 SUNRISE LAKE,
MILFORD, PA 18337
MAURICE & N DLEMAN, P.C.
BY:
THOMAS CZYK, ESQ.
Attorney for Plai tiff
na
-64- t - TI
Z
7 91, -i
4 r7l
r-,
01
=
- { 3
n
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
GEORGE W LONGAKER JR
Defendant(s)
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO 67- O Wi
erm
(X) Notice is hereby given that a judgment in the above-captioned matter has
been entered in the amount of $11266.96 on ? 1 /,7-
(X) A copy of all documents filed with the Prothonotary in support of the
within judgment is enclosed.
s
Prothonotary/Clerk
by: k.
If you have any questions regarding this matter, please contact the filing party:
Name: JOANN NEEDLEMAN, ESQ.
Address: Suite 935, One Penn Center at Suburban Station
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Telephone No.: 215-789-7154
(This Notice is given in accordance with Pa.R.C.P. §236)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
( ) Other
FORD MOTOR CREDIT COMPANY
vs.
GEORGE W LONGAKER JR
TO THE PROTHONOTARY OF THE SAID COURT:
( ) Confessed Judgment
File No. 07-7782 CIVIL TERM
Amount Due $11266.96
Interest 4/24/06 $1155.71
.. Atty's Comm
Costs
The undersigned hereby certifies that the below. does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but If it does, it is based on the appropriate original Proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue a writ of execution in the above matter to the Sheriff of Cumberland
for debt, interest and costs, upon the following described property of the defendant(s)
County,
any and all accounts and property in the name of the above Defendant. S S# xxx-xx-5631
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff ofcumberland County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
_A:?k -any and all accounts and property in the name of the above Defendant. SS# xxx-xx-5631
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
0 (indicate) Index this writ against the gamishee(s) as a lis pende ain re tate of the
defendant(s) described in the attached exhibit. /"'1
Date Signature:
Print Name-
Address: 93510,1E PENN CENTER
PHILADELPHIA, PA 19103
Attorney for:
Telephone: 215-789-7154
PLAINTIFF
Supreme Court ID No.: 74276
(over)
` ? t9 ? Otis
d C?
c
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7782 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff' (s)
From GEORGE W. LONGAKER, JR., 3345 SUNRISE LK, MILFORD, PA 18337-9648
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of MEMBERS 1sT FCU, 1000 BRYN MAWR RD., CARLISLE, PA - ANY AND ALL ACCOUNTS
AND PROPERTY IN THE NAME OF THE ABOVE DEFENDANT - SS# XXX-XX-5631
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $11,266.96
Interest 4/24/06 - $1155.71
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: JANUARY 11, 2008
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
C s R. Long, ono aryBy:
Deputy
REQUESTING PARTY:
Name JOANN NEEDLEMAN, ESQ.
Address: 935 ONE PENN CENTER
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-789-7154
Supreme Court ID No. 74276
RECFiVED
r JAN 2 Z ZUU8
FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF COMMON
Plaintiff, PLEAS
V.
Case No. 07-7782 CIVIL TERM
GEORGE W LONGAKER JR
3345 SUNRISE LAKE
MILFORD, PA 18337
Defendant(s). -
MEMBERS 1ST FCU
4PW m? +(J .
INTERROGATORIES IN ATTACHMENT
TO: MEMBERS 1sT FCU
You are required to file answers to the following interrogatories within twenty (20) days
after service upon you. Failure to do so may result in a default judgment against you.
1. At the time you were served with Plaintiffs writ of execution, or at any
subsequent time, did you owe the defendant (SS # xxx-xx-5631) any money or were you liable to
defendant on any negotiation or other written instrument, or did the defendant claim that you
owe him/her any money or were liable to him/her for any reason? If your answer is in the
affirmative, please advise the amount of money you owe the Defendant, or the amount you are
s,rv?r? s a.SS
liable to the Defendant. 2S9 763 C tech l nS (?)6. GL4
2. At the time you were served or at any subsequent dime, was there in your
possession, custody or control or in the joint possession, custody or control of yourself and one
or more other persons any property of any nature owned solely or in part by the defendant?
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a1 4N 2008
3. 'At the time you were served or at any subsequent time, did you hold legal title to
any property of any nature owned solely or in part by the defendant or in which defendant held
or claimed any interest?
4. At the time you were served or any subsequent time, did you hold as fiduciary
any property in which defendant had an interest? n
5. At any time before or after you were served, did the defendant transfer or delivery
any property to you or to any person or place pursuant to your direction or consent, and if so
what was the consideration therefor? no
6.
At any time after you were served, did you pay, transfer or deliver any money or property to the
defendant or any person or place rp?ursuant to his direction or otherwise discharge any claim of
l1
the defendant against you?
7. If you are a bank or other financial institution, at the time you were served or at
any subsequent time did the defendant have funds on deposit in an account in which funds are
deposited electronically on a recurring basis and which are identified as being funds that upon
deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so,
please identify each account and state the reason for the exemption, the amount being withheld
under each exemption and the entity electronically depositing those funds on a recurring basis. n "
8. If you are a bank or other financial institution, at the time you were served or at
any subsequent time did the defendant have funds on deposit in an account in which the funds on
deposit, not including any otherwise exempt funds, did not exceed the amount of the general
monetary exemption under 42 Pa. C.S.A §8123? If so, please identify each account.
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RECEIVED
JAN z z 2008
9. At the time you were served or at any subsequent time, did you have any safe
deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral,
checking, savings, tax or other accounts or deposits in which defendant has an interest? If the
answer is in the affirmative, please advise the amount of defendant's interest thereto at the time
--- oftho servi-Ge of the writ. n
J EOLEMAN, ESQUIRE
Att y or Plaintiff
93 ne Penn Center
Ph' adelphia, PA 19103
215-789-7154
Date: January 8, 2008
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-07782 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
LONGAKER GEORGE W JR
And now MARK CONKLIN Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0012:25 Hours, on the 16th day of January , 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
LONGAKER GEORGE W JR in the
hands, possession, or control of the within named Garnishee
MEMBERS 1ST FCU 1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BRIAN PETERS (BRANCH MANAGER)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
Sworn and Subscribed to
before me this day of
and made
So answers
4n- F
R. Thomas Kline
Sheriff of Cumberland County
01/17/2008
By - ?z -"-I -
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
(215) 789-7154
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF
Plaintiff, COMMON PLEAS
V.
Case No. 07-7782 Civil
GEORGE W LONGAKER JR
Defendant(s).
_ PRAECIPE TO DISSOLVE[W-ITHDRAW GARNISHMENT
TO THE PROTHONOTARY:
Kindly dissolve/withdraw garnishment upon Member Is` Federal Credit Union forthwith.
Respectfully Submitted,
MAcMCE,4 NEEDLEMAN, P.C.
J
Date: January 23, 2008
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Milage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
Advance Costs: 150.00
85.99
18.00 64.01
1.69
Refunded on 11/05/08
.50
2.00
4.80
30.00
20.00
85.99 ?irrd y?b P-_ 1-
9.00
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So Answers,
R. Thomas Kline, Sheriff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7782 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s)
From GEORGE W. LONGAKER, JR., 3345 SUNRISE LK, MILFORD, PA 18337-9648
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of MEMBERS 1sT FCU, 1000 BRYN MAWR RD., CARLISLE, PA - ANY AND ALL ACCOUNTS
AND PROPERTY IN THE NAME OF THE ABOVE DEFENDANT - SS# XXX-XX-5631
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $11,266.96
L.L. $.50
Interest 4/24/06 - $1155.71
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: JANUARY 11, 2008
(Seal)
C Long, P
By:
Deputy
REQUESTING PARTY:
Now JOANN NEEDLEMAN, ESQ.
Ad6Cess: 935 ONE PENN CENTER
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-789-7154
Supreme Court ID No. 74276