Loading...
HomeMy WebLinkAbout08-0778IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff NO. DS- 17?8 Civil Telrpc V.. DAVID M HARDER Defendant(s) COMPLAINT IN CIVIL ACTION Filed on behalf of: FORD MOTOR CREDIT COMPANY Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PF_PA_11 Cmplt Cvr Sht P&F File No. 07-6351 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY ) Plaintiff ) NO. V. ) DAVID M HARMER ) Defendant(s) ) NOTICE TO DEFEND You have been sued in Court. If you wish to defend against the claims set forth i i 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 an attorney, anu 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. 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 LitWYER Usted ha sido demandado en corte. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted fall de tomar accion como se describe anteriormente, el caso pude proceder sin usted y un fallo por cualquier sums de dinero reclamada en la demanda o cualquier reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad au otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO IF YOU CANNOT APFORD 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 32 SOUTF BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PA 21Notice to Defend SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 P&F File No. 07-6351 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, " PENNSYLVANIA FORD MOTOR CREDIT COMPANY V. Plaintiff NO. ©J?- 7,7-P &• T- DAVID M HARNER Defendant(s) COMPLAINT IN CIVIL ACTION AND NOW, comes Plaintiff, FORD MOTOR CREDIT COMPANY, by and through its attorney, GREGG'MORRIS, ESQUIRE and the law offices of PATENAUDE & FELIX, A.P.C. and files the following Complaint in Civil Action, and in support thereof aver as follows: 1. Plaintiff, FORD MOTOR CREDIT COMPANY, is a corporation with offices at 1335 S CLEARVIEW AVE MESA, ARIZONA 85208. 2. Defendant is DAVID M HARMER, an adult individual, believed to currently reside at 98 FRONT ST ENOLA, PENNSYLVANIA 17025. 3. On or about March 12, 2002, the aforesaid Defendant(s) entered into a written Automobile Retail'Installment Contract (Hereinafter "Contract") to purchase a "Vehicle" from a dealer (Seller) as more fully set forth in said Contract. A true and correct copy of the Contract is attached hereto, marked as Plaintiffs Exhibit "A" and incorporated by reference. 4. "Seller" thereafter assigned the Contract to Plaintiff, FORD MOTOR CREDIT COMPANY. 5. Pursuant to the terms of the Contract, Defendant(s) was/were to make 60 of PA-07 Civil Cmplt Auto Ln P&F File No. 07-6351 $195.14 commencing on April 26, 2002. 6.' The terms of the Contract provide for termination upon satisfaction by Defendant of all obligations provided thereunder. 7. Plaintiff avers that Defendant(s) defaulted under the Contract by failing to make payments to Plaintiff as promised. 8. Due to Defendant's default under the Contract, Plaintiff exercised its rights to terminate the Contract and retake possession of the vehicle. 9. After calculating early termination charges due to Plaintiff, and proceeds from sale, if any, Plaintiff avers that a deficiency balance of $2,168.54 is due from Defendant(s) as of August 06, 2007. 10. The terms of the Contract provide that Defendant(s) will pay Plaintiffs reasonable attorney's fees. 11. Plaintiff avers that such attorney's fees will amount to $725.00. 12. Despite repeated requests, Defendant(s) have willfully failed and/or refused to pay the aforesaid sum due. PA-07 Civil Cmplt Auto Ln P&F File No. 07-6351 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $2,168.54, interest from the date of breach, reasonable attorney's fees in the amount of $725.00 with continuing interest at the legal rate thereon from the date of Judgment plus costs. The damages requested are less than the maximum amount for compulsory arbitration as set by the Court. submitted: &Y?elix, A.P.C. Date: gg L. o ' , Esquire 3 E. Main S eet Carnegie, PA 6 (412) 429-7675 PA-07 Civil Cmplt Auto Ln P&F File No. 07-6351 PENNSYLVANWSAPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE 03/17,/02 Bu*vr (and Co-Buyer) Name and Address (including County and Zip Code) CREDITOR (Seller Name and Address) DAVID ppNNM?THSASpRRNER' 11L 1109p SMAI'1H FORD INC ?f`.((A c G ?FAIRVIEW PA 1707 LBMSYNERKET STREET JIAY (`(t rkbe PA 17043-1654 You, the Buyer (and Cmeuyer, a any), may buy the vehicle described' for essh or on cmdlL The •C=h Price' shown below la dr. Bah price of lira vehicle. The 'Told Bale Prim' shown below Is the credft price. By owns this contract, you choose to buy on credit under the agrwnents on the front and beak of ads con"M ue,.,nr..,r ?.._.__..._,._ .. .. - _. USED FORD INDSTA4 I 2E7DA5148hHiL55375? Personal ?Agricultural ? Commardw Tredaln 91 CHEVROLET $ 7000.00 = 317.31 Year and Make Grose Andeance Amount Owing YOU MAY OBTAIN VEHICLE INSURANCE '4•T=°::,` - jt? N FROM A PERSON OF YOUR CHOICE. 1. Cash Price ..................... $ 13995. OD (1) YOU ARE NOT REQUIRED TO OBTAIN ...............................................................,.....,, 2. Down Payment CREDIT LIFE, CREDIT DISABILITY ANC Third Party Rebate Assigned to Creditor ......... _ .................. $ WA OTHER OPTIONAL INSURANCE. THIS CONTRACT WILL NOT INCLUDE THEM Cash Down Pafrment .................................................................. $ WA UNLESS YOU SIGN AND AGREE TO PAY Trade-in 91 6HEVR $ 7000,00 $ 317.31 $ 6682.69 THE PREMIUM. You ono me' arse A*-- Aeq:nr oeae Total Down Payment .................................. "'• $ 6682.69 (2) THIS CONTRACT DOES NOT INCLUDE 3. Unpaid Balance of Cash Prig (1 minus 2) ...................... $ 7312, 31 (3) LIABILITY INSURANCE COVERAGE FOR 4. Amounts paid on your behalf (Seller may be retaining a portion of these amounts) BODILY INJURY AND PROPERTY rti To Insurance Companies for DAMAGE CAUSED TO OTHERS. Credit Ufa Insurance (for term of contrail) ........................ $ Credit Disability Insurance '(for term of contract) ,,,,,,,,,,,,,• $--593-46- [Term _Months (Estimate)] $-- To Public Officials (i) for license ($ u• n) ), title ($---92 50 ), & =Life registration ($ WA ) fees $ 33.50 . (11) for filing fees $ 14.00 (iii) for taxes (not in Cash Price) $ 4.1 70 $ 467. 20 To for Messenger Swvice ..... $ bVA To FORD OTOR COMP for $ N/A L 5 SMITH rCRD To for DOC FEE $ 5 555. .00 To for s WA Credit Total ................................................................................................. $ 1025.66 (4) 1' DisabflityC£!?r - 5. Amount Financed (3 plus 4) ............................................................. s 8337. 97 8 FEDERAL TRUTHJN-LENDING DISCLOSURES $ ANNUAL FINANCE Amount Total of Total Sale PERCENTAGE CHARGE Financed Payments Price Signature RATE The dollar amount T^e amount Of The amount The total cost The cost of your the credit will credit provk:d to you will have of your purchase on credit as a yearly rate cost you you or on your paid when you credo, behaa have made all Including your Type of Insurance Term scheduled downpayment C) Payments of $ -66ft 69 $ ?" x s-,3 s s Insurer PreNRF Payment Schedule Number of Amount of Each When Payments I na ure It Payments Paynwht are due credit Life and Credit Disability Insure'"* are Your payment schedule 54 $ 195. 14 (monthly starprlg) for the term of the contract. The amount and will be: 1 final S I9S _AA ARA ZF 14 02 given coverages nto you today. In a nodes or agreement You must Insure the vehicle. It a charge Is shown below, the Creditor will try to buy the Cover coverages hocked be based on the cash value of the vehim at time of lose, but not more thin . . ' the thrifts of the policy. Prepayment: If you pay off your debt early, you wit1v A have to pay a penalty. ? Comprehensive ? $ WA Deductible LOU Payment: You must Pay a late charge on the portion of each payment received more Collision than 10 days late. The charge Is 2 percent of rile late-amount or $50.00 whichever is ,more ? Fire- Theft-Combined Additional Coverage Security Interest: You are giving a security interest A the vehicle being purchased. ? Towing and Labor Contract: Please see this contract for additional Iftr6nnation on security Interest, nonpayment ? Term default, the right to require repayment of your debt in full before the scheduled date, and • P?? $ Months (Estimate) Prepayment penalty. N/A COMMERCIAL VEHICLES: The charge shown in the above box for late payments applies where the vehicle Purchased has a Gross vehicular weight of lea than 15,000'latmds. If 0* vehicle you purchased has a gross QUESTIONS? vehicular weight d 15.000 pounds or mac. You mtgt pay a late charge on the portion of each mnm Men to d. rm. payment received 6?, A SUS BACK FOR ADDITIONAL AGREEMENTS A?q ADDITIONAL AGREEMENTS .A.. Payments and Summalry Notice: You must make all payments when they are ddb. You may prepay your debt al'any F. Default:- You will be in aelault (f: time without penalty. This is a simple. interest contract,. The actual finance charge you agree Io pay will depehd ' i. You do not make a payment when It is du:':, 9; or on your Payment patterns. The eekrtif Opance charge•may exceed the 2. You gave false or misleading infomnalion on 'your credit ' application relating to this contraoh i disclosed Finance Charge Ii you make your payments later than the scheduled dales or in leas than the'acheduled amount Th or t 3. Your vehicle is seized by a local, stale, o federal ' ` y . e Creator will apply your payments first to the' earned and uhpaid authortty and Is not proplly end uncondilionally returned to You; or part of the Finance Charge and then to the Amount I'mallced. The Creditor earns the Finance Charge by applying the A l ' 4. You file if bankruptcy'petition or one Is filed agalrist you; or ' 5 Y nnua Percentage Rate to the. unpaid Amount Financed for the actual . ou do not keep any other promise in this contract time the unpaid Amount Financed Is otitstandirig.11 the vefikle.is e o ill t h d If you are in default, the Creditor ma re ui e you.t o pay at once aid I Y q the un A F p r ssesse , you w no ave a right to reinstate the contract unless the Creditor agrees. and uh0 p mount inanced, the earned and unpaid part the Finance C C harge s all other amounts due under thi • 8. Sectufty Interest You give:Ute Credihx a security interest In: tr He may s contras, may repossess s (take back) the vehicle, too. He may also lake goods found in or on the vehicle when repossessed end • bold them for you. 1. The vehide and all parts or other goods put on the vehicle; Z AN money dr goods reoarild lor.the vehlelb;.anQ 3. All Insurance premiums and service contracts financed for ou. If the vehicle is'taken back,' he will send you a notice. The notice will say that you may redeem (buy back) the vehicle It will y This secures -payment of all amounts you owe In this contract. It . also show the amodnf needed to 'redeem., You rgay redegm the vehicle up to the time the Creditor sells it or agrees to sell it It also secWsj your olher•egreements In this contras. . you do not redeem the-vehicle, It will be sold. C. Use of Vehicle - WARRANTIES: You must lake' care of 'The Creditor wily use the money from the sale, leas the allowed the vehicle and obey all lo s•tn yyafny it. You may not $01 or rent the vehicle, and you must keep X .ft from the dahrls of'others lt of h owed • thle contras, Expenses expenses, paid as pay a the direct result t amount having rate " th h , . You will not use or'pamR life use of tie vehicle oulside•ol the e ve icle, hold it a for sale; and sell it are, ar ed by law allowed Drilled Sbusa, • except for up to 30 days in Canada or Mexico, without the prior written boiisefu orifie Creditor. If the vehicle'is :a ` stwp , expenses Lawyers' tees and legal dolts annAlad by law are afoytW, too The Creditor wtil °pey'you, ny matey'fell (a l of a type normally used for personal use and the Crad tar, or ' surp us). You will pay any money shill owing-atter.the sale to Ube the vehicle s manufacturer, extends a wrltten warranty or service contrast co-wing the vehicle within 80 da s } o h Creditor. it you do not pay this amount when the Creditor.aska, the Creditor ma charge you interest at th hi y n m t e 'date of thls, contrast. You get implied warranties of y e, ghest lawful rate until you Pay' = merchantability and ilhress for a particular Pugreet covering the vehicle. Othm"Ise, you understand and agree that there t there re are no such Implied wnrmtle& G. Generalt To'oonlact Ford Motor CredR•Compery about this account cap 11- 1100 27 , ( ) 7 -7D00. Thar law of Pennsylvania applies to this conkscL It the lawt does not allow sit f 0. Ineurencw You mutt insure youroeR end the Creditor abalnai loss or damage to the velnkls. Tie Creditor must approve o the agreements ,tn this contract.-the onss'fhat are not allowed will be void. The rest of this contract will still be good. type and amount of insurance. If the Creditor obtalos a rehind on. Insurance or service contracts, are Creditor will subtrapt the refund from what you owe. Whether or 'not the vehicle is .r?.- ' Insured, you must pay for it it it Is lost, damaged,, or destroyed - FTC NOTICES ` It a charge for vehicle insurance Is shown on the -i.; the NOTICE -'ANY HOLDER OF THIS CON T " Creditor will try, to buy the coverages dxdred for the tens shown. The Creditor Is not Ifenbfe. though: W he cannot do ao M th CONTRACT :IS SUBJECT TO ALL D DEFENSES WHICH THE DEBTOR C ese coverages cost more than the amount shown for Insurance the T AGAINST THE SELLER • OF GOODS nSERVICF s , Creditor may buy ft ft for a shorter term or he may.&M you credit for the amount shown. It he,cannot buy ay insura m, he ll - OBTAINED PROCEEDS -HEREOF- PURSUANT 'HERETO RECOVERY HEOEE wi give you credit for the amount shown. The credit will be made to the last payments due THE DEBTOfjSHALL NOT EXCEED AMO ' . 1. .THE DE13TOH HEREUNDER. E., Late Charge:- You will"have to pay a late charge, tin the poi lon of each payment made more than ten d4& fats, The .• UsediM6tor Vehicle Buyers.Guldw 11 you are buying ' l a used -vehicle With No contract lade starlit Is shown an the front. Acceptance of a late not excuse your defaull or mean that paYfient'ifoes You:can kee ' ki , re fed on.t s may rogof the spertdal 9 N _dlsplay on to window of the : p ma ng payments after they are sus The Creston may mice the steps set -ronh In this contract if there is any default TH I F I S VOND Hr RMI FO ' THIL N YOU SEE ON WINDOW FORM FOR THIS VEHICLE IS PART OE . , r _ THIS CoNTFEACT: INFORMATION ON THE WINDOW ; FORM OVERRIDES ANY CONTRARY PROVISION S IN TH# CONTRACT OF SALE. It- I To eause'the S4811r1o`seq the vehicle described on the front of ills centred to the Buyer, on credit cacti arson. a '0uerant- gusranleas the payment of this contract. This means•ihat R the Buyer fells.to ay man at o15lgns below is , conimcl, each one who signs as a guarantor will pay it when asked. Each person who signs. bet agrees mat he wlfl•bte fla'fathja the whole amount owed even if one or more other peroons also signs this Gyanenly. )ie also,agreee to be geltle,even g the Creston tdosa one or more of thel following:((') gives thi Buyer more. ekne to pay one.or more payments; of (b) gNes,a release lit hIN o4ln part eonl?ra?ta d thla Guannty ei the tim of signing aeauRy,:Each Quarentor also states that he has recalvAd a eomp(ated copy of this Guarantor _ ;Address ' c Guarantor Address - r t• Fa """ act 00 tr,Maur .SMetu•Ituy HOT W usq.t - . FC 17637 SI OCT 00 r VERIFICATION THe undersigned is an authorized agent of the Plaintiff and verifies that the facts and statements made herein are true and correct based upon my knowledge, information and belief. Counsel has signed the verification as a matter of time and convenience. The verification of the party can be provided if requested. The statements are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authoritixc Date: Ur2W L. Mo s, Esquire Patenaude Felix, A.P.C. 213 E. Main - Carnegie, PA 15106 (412) 429-7675 PA_0 1 Atty Verification P&F File No. 07-6351 oho O C. l ' rm . na is .. co L SHERIFF'S RETURN - REGULAR CASE NO: 2008-00778 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS HARNER DAVID M TIMOTHY REITZ Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HARNER DAVID M was served upon DEFENDANT at 98 FRONT ST WEST FAIRVIEW, PA 17025 DAVID M HARNER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. the , at 1930:00 HOURS, on the 5th day of February-, 2008 Sheriff or Deputy Sheriff of Sheriff's Costs: Docketing Service Affidavit Surcharge j / /0 8 <?, 18.00 15.36 .00 10.00 .00 43.36 So Answers: Sworn and Subscibed to before me this day of , s R. Thomas Kline 02/07/2008 PATENAUDE & FELIX By. Dep t Sh riff A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff NO. 08-778 CIVIL TERM V. DAVID M HARNER Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT Filed on behalf of: FORD MOTOR CREDIT COMPANY Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_117 Prcp Def Jg D1 P&F File No. 07-6351 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff V. DAVID M HARNER Defendant(s) NO. 08-778 CIVIL TERM PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT AGAINST DAVID M HARNER ONLY TO: PROTHONOTARY Please enter a judgment against the defendant, above named, for failure to file an Answer to Plaintiffs complaint. Amount claimed in Complaint $2,168.54 Interest from August 06, 2007 $180.33 Less payments received $0.00 Attorney's fees $750.00 TOTAL $3,098.87 With continuing interest on the principal amount of $3,098.87, with interest at the legal rate, plus costs of suit. I hereby certify that a written notice of intention to file this praecipe was mailed to the defendants and defendants' counsel (if known), after the default had occurred and at least ten (10) days prior to the date of the filing of this praecipe. A copy of the Notice is attached. submitted: & Felix, A.P.C. Date: / / ?re LM 's, E PA_ 117 Prcp DefJg D1 213 E. Mai reet Carnegie, PA 15106 (412) 429-7675 P&F File No. 07-6351 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff V. DAVID M HARNER Defendant(s) NO. 08-778 CIVIL TERM PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA.R.C.P.1037(b) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared GREGG MORRIS, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and states that the defendant(s), DAVID M HARNER, is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that Notice of Intent to take Default Judgment was mailed in accordance with Pa.R.C.P.237.1, as evidenced by the attached copy. submitted: & Felix, A.P.C. Date: Sworn to and subscribed before me this J? day of , 20M. Notary Pubhoe camp COMMONWI AI LH! F FFg Nla VANIA Nabptel $081 Carolyn I > 1t, Naha isublle Camto+a pore, A#%#W y Cau* My Commission Wres Aug. 14, 2011 Member, Pennsylvania Association of Notaries Wegg L. Morris, Esquire 13 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-1 20 Aff of Non Mil P&F File No. 07-6351 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff NO. 08-778 CIVIL TERM V. DAVID M HARNER Defendant(s) IMPORTANT NOTICE Filed on behalf of: FORD MOTOR CREDIT COMPANY Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA 111 10 Day D1 P&F File No. 07-6351 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff V. DAVID M HARNER Defendant(s) To: David M Hamer 98 Front St Enola Pennsylvania 17025 Date of Notice: February 27, 2008 NO. 08-778 CIVIL TERM 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 JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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 32 South Bedford Street Carlisle PA 17013 717-249-3166 Respeully submitted: & Felix, A.P.C. Date: tr is, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_III IODay DI P&F File No. 07-6351 I, GREGG MORRIS, attorney for Plaintiff, FORD MOTOR CREDIT COMPANY, hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Date: David M Harper 98 Front St Enola PA 17025 L. Morris, Esquire ude & Felix, C. 213 E. street Carnegie, PA 15106 (412) 429-7675 PA_l l 1 10 Day D1 P&F File No. 07-6351 N ? :?" ?? ?o ? ? ?H? ? ?``? i 'i ;"; ( ? ? V" ? ?' , p ? T' ? _.. i . ?. y y . ," am .'J ?} 1 ..{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff NO. 08-778 CIVIL TERM V. DAVID M HARNER Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: FORD MOTOR CREDIT COMPANY Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-1 23 Ntc Jgmt Both P&F File No. 07-6351 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff V. DAVID M HARNER Defendant(s) NO. 08-778 CIVIL TERM NOTICE OF ORDER, DECREE OR JUDGMENT AGAINST DAVID M HARNER ONLY TO:( )Plaintiff ( x )Defendant ( )Garnishee ( )Additional Defendant You are hereby notified that the following Order, Decree, or Judgment has been entered against you on 3 a9 105Z ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( X ) Judgment of ( ) Confession ( ) Verdict ( ) Court Order ( X) Default ( ) Non-suit ( ) Non-Pros ( ) Arbitration Award ( X) Judgment in the amount of $2,168.54, plus costs. ( ) District Justice Transcript of Judgment in the amount of $ , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotary By Depff ty?-/ If you have questions concerning the above, please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 PA_123 Ntc Jgmt Both P&F File No. 07-6351 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY ) Plaintiff ) V. ) DAVID M HARMER ) Defendant(s) ) NO. 08-778 CIVIL TERM NOTICE OF ORDER DECREE OR JUDGMENT TO:( )Plaintiff ( x )Defendant ( )Garnishee ( )Additional Defendant You are hereby notified that the following Order, Decree, or Judgment has been entered against you on ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( X) Judgment of ( ) Confession ( ) Verdict ( ) Court Order ( X) Default ( ) Non-suit ( ) Non-Pros ( ) Arbitration Award ( X) Judgment in the amount of 53,098.87, plus costs. ( ) District Justice Transcript of Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotary By If you have questions concerning the above, please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 PA 121 Ntc Jgmt D1 P&F File No. 07-6351