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Home My WebLink About08-65581 V. 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 Plaintiff, 15) 789-7161 FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMPANY COMMON PLEAS P.O. Box 6508 Mesa, Az 85216-6508 Case No. S58 CI Vi WAYNE E HOCH 1 Naugle Rd Shippensburg, Pa 17257 ANGELA M HOCH 1 Naugle Rd Shippensburg, Pa 17257 Defendant(s). 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. UI V IL AUTWIN UUMPLAINT ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff AVISO Le ban 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 at partir de Is fecha de la demands y Is notificacion. Hace falta asentar una comparencia escrita o en persona o can un abogado y entregar a Is corte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, Is corte tomara medidas y puede continuar Is demands en contra suya sin previo aviso o notificacion. Adernas, Is corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demands. Usted puede perder dine 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. Sl 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 ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff (215) 759-7161 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. WAYNE E HOCH 1 Naugle Rd Shippensburg, Pa 17257 ANGELA M HOCH 1 Naugle Rd Shippensburg, Pa 17257 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. Q 8 -6Y,5-' ct';.-4 liz- CIVIL ACTION COMPLAINT 1. Plaintiff, FORD MOTOR CREDIT COMPANY, A Delaware Limited Liability Company, is a Corporation with its place of business at P.O. Box 6508 Mesa, Az 85216-6508. 2. Defendant, Wayne E Hoch, is an individual who resides at 1 Naugle Rd Shippensburg, Pa 17257. 3. Defendant, Angela M Hoch, is an individual who resides at 1 Naugle Rd Shippensburg, Pa 17257. 4. At all times relevant, the Plaintiff was in the business of loaning money on motor vehicle installment sales contracts, including but not limited to the note signed by Defendant(s), hereinafter more fully described. 5. On or about February 21, 2006, the Defendant(s) entered into a written Motor Vehicle Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of obtaining financing in the amount of $39710.72 at an annual percentage rate of 17.990%, in order to purchase a certain motor vehicle, 2006 Ford Focus more particularly described in the Contract (hereinafter referred to as the "Vehicle") A copy of the Contract is attached and marked as Exhibit A. 6. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $523.76 for a period of 72 months until the loan was paid in full all as is more fully set forth in the Contract. 7. Defendant(s) made monthly payments until August 2, 2007, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 8. As a result of the default by Defendant(s), and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant(s) giving the Defendant(s) the opportunity to redeem the Vehicle as well as notice of the sale date. A copy of the notice of repossession and notice of sale date are attached and marked as Exhibit B. 9. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at auction with a credit given to the Defendant in the amount of $11400.00, however a balance of $11064.36 is still due and owing, and a notice of the deficiency balance was sent to the Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C. 10. Pursuant to the terms of the contract, Defendant is required to pay all amounts due and owing, including any balance that may remain after the sale of the vehicle, and the Defendant failed to do so, thereby in default of the Contract. 11. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to $1608.74 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $12673.10. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $12673.10, 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, MAU ICE & NE LEMAN, P.C. CH A. TA LOR, ESQUIRE Attorney for Plaintiff Date: October 30, 2008 VERIFICATION I, CHARLENE A. TAYLOR, ESQUIRE, verify that I am the Attorney of record for Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY, and duly authorized to make this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. BY: CH E A. TAYLOR, ESQUIRE DATED: October 30, 2008 ' PEreffiYLYANU OAPLE wmRESr vanCLE RET4l. MISTALLmEwr CONTRACT DATE 02/21/2006 WAYNE E HUN PARSONS INTERSTATE FORD LLC ANGELA N HOCH 196 WALNUT BOTTOM RD I NAUGLE RD SHIPPENSBURG, PA 17257 ® SHIPPENSBURG PA 17257 www.fardLTSSdN.mm Tlr (rtl ventdla«rW bur -lb nouns M.TW bm ws;..y..«°sala.°raw an vwwdruuaa Th. T-i W I'- Wbg1:w+a'on uar hi wned?aaaa`?rm°we.a"aa..w.... wrswvnrn.?erwbuw.o+e.n,rw -cift R.wnlmd Ml? rev wd aer WWI vwtb aenwason Itrniper um F«wHm Rrdumd NEW tBl F00.D 31AFP07146R117051 )? cw wcw mrrw R®QATtON OF AMOIRIT PN4MAM 23060.00 YOU ARE REOLOPOW TO NIWRE THE 1. Ceaf tibe i (1) VOOM. YOU MAY 01IFFAIR VEHICLE 2. Dow P+I•++rA 1000.00 YOUR INSURANCE FROM A PERSON OF TWM hrty Re.r A"IPW to S+Illr_........._._._..__..-._._i ' CHOICE. ?.,Uu-" t 664ii PsRaaa___.`.?.IF _.-_._.._ FOR BODILY TY 94111" INSURANCE AND PROPERTY Yead adr Gnw Ak-- Anrw Owe DAMAGE CAUOTHERS 18 NOT NL NOT 2000.00 O Tall Oaor pbT++r+?.._--'___'--"--'-------.__i fs9 NICLUOED. a to pod Asodeb MM a OW On VTM+ ceaf tvas (t meue 2) __?_._ Y,_t ?lA ?? LFE CREDR DISABItJIY AND wrx peM +I+Y r rebhllq a POrdon d tlaw ewoule) OTHER 0?T10NK EMURANCE ARE 'i To PfaSe OlNdrw NOT R TO OBTAN CIDDIT (0 for kew p N/A ). Im is 22.60 ). A AND WILL IIOT BE PROVIDED 1NLM Iepwafon Im Ste- ; YOU NOW AND AGREE TO PAY THE mf Xkq bre N3? PREWAR. (i0 b lass Olot h Cale Pda) iZ - s 1434.82 Credit T. amen CarrewWe+ I- Lw sour LIM aleweKa Hw ban d comma) _...__._.__._..._... $ /q N/A Imuranoe COrIPeOy c.mM.eety Ivrlw pw bmr a mnbael)-._._..._ s N? (T_ _S N// T91Tamt-NOndwl Y' want CmdH LS, I" ou. ?tl i N../A TO w To Ion S TO br i N/A ro 1er s N A f 1909-82 M A. Amaalt wror p pw 4)..______..._.._.._.__._..____ i 22969.92 PERCENTAGE CHARGE Pklancsd Papnsnb P"m Tt»rmuma Tb.- Tne lrr.sw RATE Tlr sorr Pybw Yeu.0Ire d yw m-,&- rn.o.Iayw dr oew eS bra.«mer'"ra. aZ1 awI w e rwM rev meI yra eba bOd edry,sa 17.99 ., , 14740.90 2969.82 a/ 770 10 2 3 /bbl . 72 r [[?t1 ?iJ13 777 R L71 aa0 bm. l O 37 IA Frprrwl I rev pry.ll y«r Orbt.erM. Yw rA rrl h.w b per. purlry. e.e+r+y tew..e Ym r. Wev • rw•W blw.p :,+,. v.Na. erq puNbe.a . r.r r.Prwrr rw.,w +r p«um a.w wrrrwe r.aima non ern to .lie w.7h. rAnae i. "== M cwraee Pfere me e a I« .&*Ww edomwbn m ..wear .+.nw. d~, _b dal -u rpam Spa, d I" dew in M e.lu. me aMatluYO bb, rn1 a you m m maw yaw oonraa oeopmo s, you may Ipee yov vehltle, r iron r bdh paid veal 9rdt put on yoW vahide and money o Moods mdred for vow vehds. ? You as hebbbm payrrnl undw ft crowed is e bwoon paWmom tDtQes WEAR UK AND IREAOE CHARGES C.w Lw W =.M=:: d Ir bat y re b drdad. di. eaWon, Imrq.pn B, errI P+r+P+ph C a r w err d dYe obnhed+Iplr. Yeu may M .a-M, lwq.d for ewAaeAa err hued upon au mrrderd. °? w ar.ww b • ..dm w eP.w.wd for -.d - N ym rrlebe II. epewS?.tli dr vaa$ Irek b Selsr under frM r« f.a.y A yr mw O+r tlr 9drf0.-- pr mle for a.cRndlsb seew Oralw Nehv Aefrilwn ppMny a ear eMw r 11. od..M,. W - fi AW EM E OPnw CrAMW mrwewwl . . M1ntrw a w mmr.pe r e x si -0" -ftbr • We - pr- (- balml.d .bee), YW y- Irv. ow d h nd "*W b ow er&L Th. au.ew w mialwr aMdra o.wlsYwr.etar rw d.w V- 00111- b d h -d". W M S.R. uww P.repreph e, 0,1& ar ed fwb dbelra Awwelr den Y N --? reeW. •• d SG mwd m1. Yen Nr E d dr w wvrb.abrb en e m f k nni ar I w unuw belw+r Arid mar, bur wy .m«.w Yau ci v Am 4 sunlnml d Arun Firalred uMw w. awe unto IN oowsl. rat rdl w mew erry are a dr vwd. b deesor.a, Ile y~' r A A`"" .anew ends say, w you eve in dada. y- wl rlel meow m "a I IF. ww s ?? b m bur Imll f1Al. NON4AODN40AT10N DISCLOSURE Any tlrp b we e«r.a,«m w in wore -0 sqw by yw -1 b. 8mw . Nrrr r X 2?-'a- L N-< X\ YY."o, M kl WA YOU ACKNOW WM TNAT YOU WIVE READ AND AGREE TO BE SOUND BY THE MMMTION PROVISION ON THE REVEa9E SIDE OF THIS CONTRACT. The Awme Poisonings Raw wry be nlgotI wNh No SWIsr. The sear may madam MN connect and may rNNn He aafl to r , I a pw I of Me Fblrma Chwaa. Do mat sign fns furdraet in blank. You are entitled to on exit copy of the contract that you sign. Keep it x V- X, to pn tset your legal rights. M I' ' Cos!qw Buyer (and CaBuyer) acknowledge that p) before tleMltD this . Buysr (and Co-curer) reoskvd and reviewed a tme and cotltpletsiy nWTcopy o?tlds contract and (iq at the time of slonkw this cortmet. Buyer lard Co-Buyer) receWed a trim and completely, filled In?T contract. ln' say.. X V-v- c :dr..?.? c+a+r•r X \ YV?OF r b ) J. M CQ (?- 91 wan. awry PARSONS INTERSTATE FORD Y TW THEM CONTRACT K NOT VALID IINII YOU AND SELLER SM R. armwerr00 aarr FONDRO O?A CttESrT' wdona mwamr.gr,Pkftre, rev ni r g.Wftsaw.w dWr wdapaYaewmelw C+•eVle.9 pe?lT r? arwwt ad 4100 727 1 7000 _ rbd mrt rred. w PARSONS INTERSTATE FORD yI,C?.j? 1tr C?e!><c.A m OTHER 9IOE rp1 ApaTgNAL AOAEw1DRe o S N/A PralMurll Inaxed(s) Buyer Si9^a Co-BUYw 31Qm Cwelt O DIrblNpr_ s NIA Prwmten hound(s) You TARO Coral ONW Wy IIwIrAllca. SLwSign Co-StW OTHER OPTIONAL NISL*A"a Car+r+S+and PMWAM and InarenEe Cmptltef_ Term In m." i NIA N N/A y--do. optlena in- f r praaumw'vuhrded aove. b a7+r? Cedryer ? u:..f' MTN I .M 0 tt.. Ii 111. rut, ... I. ul w tYPu malty usad for personal Dee end the serer, or the _F cie'. manula t coveti.q ng the I, extend. ve a wHItM Warranty or Wn 90 day. from Ina " dM, r th" -nkle INI of Ihl. cmrf you get Imptfed.,P- e. covof an memnaMh!" d - lor me partkn perpona eting the re-1, _:pf agree ma: them are eo a??h o ,Ipli.d ....... arrantd d a„d implied wies, eneepf as otnerwine prarided by I- F Vefiirle insurance. f ut.5n1-]I READ"I 01TRATION PFOVISIOf ARBETI AGAI TQ S WHEiI' BROAD BIGHTS TO RM.HT TO APPEAL TII- • OTHER RIGHT"'I .'. :.. .i Vht. lo lrl E b Ce obfaun - ? , Finarke Fl-- 4 L Ilatkrfa I, ?'n-2' - r hrr. t 9 U rc'. r [ oa na•,ex - - FTC M07ICE$._.. 27: SP.F.EE': d1 TICE - ANY HOLDER OF THIS CONSUMER CA -T ? ''-JNTRACT IS SUBJECT TO ALL CLAIMS AND'. DEFENSES WHICH THE DEBTOR COULD ASSERT; AGAINST T, HE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID D'! THE DEBTOR HEREUNDER.' Used Moto V h cie SBuyers G.1- , ,-o „ene? c V ft . a spec,[ Btyers, - to ne -:s Yeu nE ehicla. THE INFORMATION YOU SEE ON I THE WINDOW FORM FOR THIS VEHICLE PART OF! THIS CONTRACT. INFORMATI ATION ON THE E WINDOW' I FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT CT OF SALE. POen nrn npprv T mechnxd for T77-, as tvunur.,l 5 Y?r idehtvj pII tKt agetn,:: -- segwnthcWCrIXt?.sGmrtr l[5 AND IN ITS ENTIRETY ---- - ha Bpr;'Keole ruk0 Ut 'iulP :uhf I Ih.r`c IAMI ' rvhern apn raMe V a nl•,;rtrv,?,r3 u rk ,?a:?nsrrncD?;ame?s rai,rk, BACKER (HEAD TO-HEAD) & SCREENED SD'S. "'PRN"` Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631-3111 (877)349.5260 PMKGTW200008 WAYNE E. HOCH 1 NAUGLE RD SHIPPENSBURG PA 17257 Date of Repossession 11-25-20o7 Date of Notice 11-27-2007 Date of Contract 02-21-2006 Account Number: 040206836 Bu r WAYNE E. HOCH Cobuyer ANGELA M. HOCH DESCRIPTION OF PROPERTY Year 2006 Make FORD ?x New ? Used Vehicle Identification Number: 3FAFP07WR117051 Model FUSION Body 4DR ;Sttl? M s NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. 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 adjournment date). The sale will be held as tohows: Date or Sak Tine of Sale Place of Sale You may attend the sale and bring bidders if you want. NOTICE OF REPOSSESSION The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number above. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money undE your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) if there are other people, they are named on an attachment sent with this notice. The property is presently stored at: MANHEIM A A 1190 LANCASTERTtD-WNHEIM PA 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 soli. Unpaid Balance $ 22,013.18 Plus Costs: Repo Expenses $ 415.00 Plus Late Charges $ 20.96 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 22,448.14 (Plus expenses incurred if default at the time of repossession exceeded 16 days and Leas rebate received after the date of this nolice.) Your property won't be sold until 16 days after the date of this notice at the EARLIEST. After that you ran still get k back any time before irs actually sold. If you do, well have no further claim on ft. But the lounger you waft, the more costs (including repels) you pray have to pay. If you have any questions about this, please call us. ? The property has been (or will be) returned to: (dealer/original creditor) Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money after the sale, you will pay ft to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the rnext 60 days or, in accordance with state law, by contacting this 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: All 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 rat accurate for any reason, please contact us so that we can accurately report the vehicle's mileage. INSURANCE RIGHTS: If you don't wank to gel your property back, call the Insurance company or the dealer/odgkral creditor to make sure #* any nwmq has been cancelled. You have a right to get credit for ant premium refunds. CHRISTOPHER E. BELCHER FFNA 11DW37 Jan 02 Previous editions may NOT be used. CUSTOMERlCUSTOMER FILE Prinked in U.S.A. "'PRN'- Ford Motor Credit Company P.O. Box 31111 TAMPA, FL33631-3111 (877) 349-5260 PGEKGT00200013 ANGELA M. HOCH 1 NAUGLE RD SHIPPENSBURG PA 17257 Date of Repossession 11-25-2007 Date of Notice 11-27-2007 Date of Contract 02-21-2006 Account Number: 040266836 Buyer WAYNE E. HOCH Cobuyer ANGELA M. HOCH DESCRIPTION OF PROPERTY Year 2006 Make FORD ?x Neyy ? Used Vehicle Identification Number: 3FAFP07146R117051 Model FUSION r4O NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. o. Q 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 dale below (or any adjournment date). The sale will be held as follows: Date of Sale Time of Sale Place of Sale You may attend the sale and bring bidders if you want. NOTICE OF REPOSSESSION The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number above. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money under your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. The property is presently stored at: MANHEIM A A 1190 LANCASTER RD?fv NHEIM PA 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 $ 22,013.18 Plus Costs: Repo Expenses $ 415000 $ Plus Late Charges $ 20.96 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 22,449.14 (Plus expenses incurred if default at the time of repossession exceeded 15 days and less rebate received after the date of this notice.) Your property won't be sold until 15 days otter 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, we'll have no furtive claim on it. But the longer you wait, the more costs (including repairs) you may have to pay. If you have any questions about this, please cal us. ? The property has been (or will be) returned to (dealer/original creditor) Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money after the sale, you will pay it to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal property found In the vehicle may be reclaimed by you within the neat 60 days or, In accordance with state law, by contacting this office. Thereafter, the personal property shall be disposed of accordingly. ? Creditor has assigned to its qualified intermediary (Of Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer is not accurate for any reason, please contact us so that we can accurately report the vehicle's mileage. INSURANCE RIGHTS: If you don't want to gat your property track, call the insurance company or the deafer/original creditor to nuke sure that any Insurance has been cancelled. You have a right to got credit for all premium refunds. CHRISTOPHER E. BELCHER FFNA 1193&37 aan 02 Previous editions may NOT be used. CUSTOMER/CUSTOMER FILE NOW in U.S.A. t ' t ' i .7 ?m to IL U? U) LL Um OLL .m CO °o v 4= 0 °m m R ?B t? M ® _gcr Q4$??UI Ea: ?.a 1 a ?1 a11Ix x Qi E 4 v c c a o a S r E $ t 0000 to A Ln m S O C} CJ C3 C3 Ln ru r %- C3 C7 IN t to C3 _o m S C3 C3 C3 m C3 to ru r- 0 C3 N wo ell t- is ca N rZ 3:0 0: 0 0 (.6 a z N_4WZz ?mC7S> ru tq ? I m S ` C3 C3 C] cl 0 .A r.n ti r% C3 N ? J 17 00 J N N U cc zz w>w ?C)waz N.- N - WJU ?ca? Ln M1 Ln m S C3 C3 C3 C3 0 ..O Ln w r %- C3 C] M1 t I I 1 i 1 .f c" ' ti i m S C3 C3 C3 C3 C3 -a - --Ln ru r- Ca C3 r- M 0 c•? Q WWO `e > 0 *t?Wa W4SW N p in v J rl J U?toL) ni Ln m I C3 C3 t C3 I C3 M A ILn ru M G r- Aso t i, t Q J 1. lvl m m c E I rN la a 1 tr fr rn in 0 C3 C3 C3 -D to flu i? C) CS N o? II ? cl-I q I r w 1o0 cli C 00 aC Q = a z N w U) ? $ 8 V p _ cr W z IX IL r-JZ0 SOD CO rtiUN =Q p?WOi-N _IZ t?-Z? N1?1?UJ? N 0 ??e+fZ NOg(S11J C%l ?Mz 4 ,?• ib U, j) 0. z 00 N?yZ4V? C4 cIL ?ciCL > cmQvl.a(= s M W Q W i , ?aaZNX us E 2 0?n,oow m I Ll! ?1. nt N? I m o a Ea I n I?$ co ( -- o C3 - i - ?0 3 O I? O C3 Ln p i I n IU . -r.- 3t t p - ,? L n' Ln n' n C3 i n w C7 ?- Q N i NAN !c w w t Q ti A g cotiw a ?? n^uxj y? t NOw aa: a M ?2mr-z m e s. ?DOO 3 ?OC r U Z C) C0 ti .Q 00 0 i co C3 i ? O C3 a ? t r` m I ! ? Q C3 C3 C7 M !ru r 0 O M1 a r w?a ip ?`-w? c?0 L) U w:% O Q ?z M p4 crozwQ z 0 N O V J 4} N= D2!?u=iq dal--tea t i N fU C3 i a i r- m -11 f a I i3 f C] t7 f .0 ti t?- a n M1 i t E t ? u a v ; I ' N f m r O i r. ! Ln N m i o n C3 a f i 13 o E f j $ o ! 'a ° Ln I n i ! A I • 1 ro ? w CM 1%- 1 C:3 C3 N w i W C7 z N >? Eu- --Jj IL Z zzw? wg3 c"i?,WZa' VCO)m N Z=I rQ0 l M J O? W Z M?U=' o^Q?fan NO(a? N0 J(?}W 7- M CL ?QW?WI Qfi J NC' lu N >Q Q0. 7mU' cVm? - - r'Q Q- - ?Q2NV --?Q-.zT - s? Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2008-01-24 POFVIUOO100138 ANGELA M. HOCH WAYNE E. HOCH 1 NAUGLE RD 1 NAUGLE RD SHIPPENSBURG PA 17257 SHIPPENSBURG PA 17257 STATEMENT OF SALE Account Number: 040286836 The following property has been sold. Year Make Model Vehicle Identification Number: 2006 FORD FUSION 3FAFP07146R117051 Balance owing on your contract (1) $ 22,034.14 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 22.034.14 Deduct: gross proceeds of the sale (4) $ 11,400.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 10,634.14 Add: Expenses of retaking and storing, and (6) $ 635.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. (7) $ 0.00 Deduct: Insurance Premium Rebate (8) $ 203.77 Other: (9) $ 11065.37 Deficiency** (10) $ N/A Surplus* 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 FFNA11990 01104 Previous editions may NOT be used. Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2008-01-24 POFVl000100139 ANGELA M. HOCH 1 NAUGLE RD SHIPPENSBURG PA 17257 WAYNE E. HOCH 1 NAUGLE RD SHIPPENSBURG PA 17257 STATEMENT OF SALE Account Number: 040286836 The following property has been sold. Year Make Model 2006 FORD FUSION Balance owing on your contract Deduct: Finance Charge Rebate Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any attomeys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Vehicle Identification Number: 3FAFP07146R117051 (1) $ 22,034.14 (2) $ 0.00 (3) $ 22.034.14 (4) $ 11,400.00 (5) $ 10,634.14 (6) $ 635.00 (7) $ 0.00 Other: (8) $ 203.77 (9) $ 11065.37 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 FFNA11990 01/04 Previous editions may NOT be used. lot- r_ ? .ICJ f7' co CASE NO: 2008-06558 P HOCH WAYNE E ET AL COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS MARK CONKLIN day Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HOCH ANGELA M was served upon the DEFENDANT , at 1045:00 HOURS, on the 7th day of November , 2008 at 1 NAUGLE ROAD SHIPPENSBURG, PA 17257 T TTn T?T T TTr NrITT 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 RETURN - REGULAR 6.00 .00 .00 10.00 .00 16.00 Sheriff's Costs: Docketing Service Affidavit Surcharge 1111114 9?, Sworn and Subscibed to before me this of Sheriff or Deputy Sheriff of So Answers: R. Thomas Kline 11/12/2008 MAURICE & NEEDLEMAN By. Deputy Sheriff A. D. R ` CASE NO: 2008-06558 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS HOCH WAYNE E ET AL MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOCH WAYNE E the DEFENDANT , at 1045:00 HOURS, on the 7th day of November-, 2008 at 1 NAUGLE ROAD SHIPPENSBURG, PA 17257 ANGELA HOCH, WIFE by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge } i+f 1 RIbr ?-/'- 18.00 15.00 .00 10.00 00 43.00 Sworn and Subscibed to before me this day So Answers: R. "Thomas Kline 11/12/2008 MAURICE & NEEDLEMAN By. Deputy Sheriff of A. D. 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) 161 FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. 08-6558 Civil Term V. WAYNE E HOCH AND ANGELA M HOCH 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 Defendants, WAYNE E HOCH AND ANGELA M HOCH in the amount as follows: Principal Amount $ 11064.36 Interest to Date $ 2099.55 TOTAL $ 13163.91 MAURICE & NEEDLEMAN, P.C. BY: CHARLE A. TAYLOR, ESQ. Attorney pr Plaintiff Date: January 27, 2009 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (21-')) 169-1161 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WAYNE E HOCH AND ANGELA M HOCH Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE N0.08-6558 Civil Term CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 12/31/08 to Defendants, WAYNE E HOCH AND ANGELA M HOCH, 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 12/31/08, a copy of the mailing to the Defendants and affidavits of service are all attached hereto. MAURICE & NEEDLEMAN, P.C. BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: January 27, 2009 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 (21.-)) /69-/101 FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. 08-6558 Civil Term i v. WAYNE E HOCH AND ANGELA M HOCH Defendant(s) 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: WAYNE E HOCH, 1 NAUGLE RD, _ SHIPPENSBURG, PA 17257 ANGELA M HOCH 1 NAUGLE RD SHIPPENSBURG, PA 17257 MAURICE & NEEDLEMAN., P.C. BY: CHARLENE A. TAYLOR, ESQ. Attorney for Plaintiff Date: January 27, 2009 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WAYNE E HOCH AND ANGELA M HOCH Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE N0.48-6558 Civil Term AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she is an attorney at law and that on 12/31/08 he/she mailed a written Notice of Intention to File the Praecipe to Defendants, WAYNE E HOCH AND ANGELA M HOCH, at 1 NAUGLE RD, SHIPPENSBURG, PA 17257 by regular mail. MAURICE & EEDLEMAN, P.C. U SWORN TO AND SUBSCRIBED before me thWj day of0„? , , 200 C Notary Public AQV3 BE LMD, No ry Pubk C4 of Ph?ede lx* Mb. co" Convrncsi?n E *m Joug 20, 2013 BY: ? - ?.. CHA E A. TAYLOR, ESQ. Attorney for Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff 1J17259-/161 FORD MOTOR CREDIT COMPANY, A I CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO.08-6558 Civil Term v. WAYNE E HOCH AND ANGELA M HOCH AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she represents the Plaintiff in the above entitled case and that Defendants, WAYNE E HOCH AND ANGELA M HOCH, are over 18 years of age; the occupations of Defendants are unknown and to the best of Plaintiffs knowledge, information and belief, Defendants are not in the military service of the United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. MAURIC & 4NEEDL AN, P.C. 1 BY: C RYLOR, ESQ. Attorney for Plaintiff SWORN TO AND SUBSCRIBED before me th} day of , 2U(- C Notary Public a? NOTARUII. SEAL. AGM MEMO, Notary Pd* ??aiPhiedeiPNa, ? 20 13 C,ommisaion ?, . f`. December 31, 2008 A. florneys al Low Suite 935, One Penn (enter 1617 John F. Kennedy Blvd. Philade lphia, PA 19103 le 1.115.665.1133 fa x 115.563.8970 www.mnlawpc.com Darnak S. Maurice Member NJ Ba Board (erlified Creditors' Rights Law nlr_B_o_9td ofEerliffcatian Joann Needleman Member PA 8 NJ Bar Thomas R. Dominczyk Member NJ, NT 9 PA Bar fNetlenb A. Taylor Member PA Bar ANGELA M HOCH 1 NAUGLE RD SHIPPENSBURG, PA 17257 Our File No. 8468 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. WAYNE E HOCH AND ANGELA-M HOCH CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 08-6558 Civil Term Dear Ms HOCH: 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 11/17/2008. Unless an answer to Plaintiff s Complaint is filed with the Court within ten (10) days from the date of this notice, a default judgment may be entered against you. If you would like to discuss a resolution to this matter, please call our office at 908-237-4571 and ask for Kim Crosby. Thank you for your prompt attention to this matter. Very truly yours, MA C EEDLEMAN, P.C. I Ch le . Tay , Esq. CT/jm Enc THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR New Jersey Office I Maurice 8 Needlemn, U. Suite 2007 5 Walter E. Faros 914 Flemiegton, NJ 08822 td. 906.237.1550 fax 908137.1551 e 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 (L1J) /tSy-/1?J FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WAYNE E HOCH AND ANGELA M HOCH CUMBERLAND COUNTY- COUI7 COMMON PLEAS CASE NO. 08-6558 Civil Term IMPORTANT NOTICE TO: ANGELA M HOCH DATE: December 31, 2008 1 NAUGLE RD SHIPPENSBURG, PA 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICE E LE14AN, P.C. BY N C NE A. TAYLOR, ESQ Attorney for Plaintiff ?2gpp05583191 •/W' `Mw Wd.l1-- 0 aw ?acu.a 1 . GO -- tD .i i N Q U v -_ p C) =aCm WN s uj ..: _ W CL L Z Z S U cr> IU° r WUd Q c w CL °" w w UZo wag o co f CY) a December 31, 2008 Attorneys of Law Suite 935, One Penn (enter 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.665.1133 fax 215.563.8970 www.mnlowpt.com Donald S. Maurice Member NJ Bar Board Certified (redi tors' Rights Law American Board of (edification Joann Needleman Main bar PA & BJ Bar Thomas R. Dominayk Member NJ, NY & PA Bar Charlene A. Taylor Member PA Bar New Jersey Office Maurice & Needleman, P.C. Suite 2601 S Walter E Foran Blvd. Flemington, NJ 66&22 W. 966.237.4550 fax 906.237.4551 WAYNE E HOCH 1 NAUGLE RD SHIPPENSBURG, PA 17257 Our File No. 8468 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. WAYNE E HOCH ANDANGELA M-HOCH- - - - -- - - ----- CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 08-6558 Civil Term Dear Mr/Mrs/Ms HOCH: 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 11/17/2008. Unless an answer to Plaintiff's Complaint is filed with the Court within ten (10) days from the date of this notice, a default judgment may be entered against you. If you would like to discuss a resolution to this matter, please call our office at 908-237-4571 and ask for Kim Crosby. Thank you for your prompt attention to this matter. EEDLEMAN, P.C. nea0y rs, or, CT/jm Enc THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR 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) 789-7155 FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. 08-6558 Civil Term V. WAYNE E HOCH AND ANGELA M HOCH Defendant(s) IMPORTANT NOTICE TO: WAYNE E HOCH DATE: December 31, 2008 1 NAUGLE RD SHIPPENSBURG, PA 17257 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 MAURICE LE , P.C. BY YLOR,ESQ Attorney for Plaintiff 62SOOp5`'?3191 4 MN JJ ? %aa?o su -- _ ? O i ..? r i N .:"- i r- s - ! ? r i S ?: oo - ac C us j w ! ry i _' 4 Z = U 0. 4 pG W N? w °' ?c w C w °" w U 7- ?O ?Y 0? n- SHERIFF'S RETURN - REGULAR CASE NO: 2008-06558 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS I40CH WAYNE E ET AL MARK CONKLIN.' Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOCH ANGELA M the DEFENDANT at 1045:00 HOURS, on the 7th day of November 2008 at 1 NAUGLE ROAD SHIPPENSBURG, PA 17257 by handing to ANGELA HOCH a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 6.00 t If_ , 3r -0 V .00 .00 o ,10.00 R'. Thomas Kline .00 16.00 11/12/2008 MAURICE & NEEDLEMAN By: day Deputy Sheriff A. D. ??U? SHERIFF'S RETURN - REGULAR CASE NO: 2008-06558 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS HOCH WAYNE E ET AL MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOCH WAYNE E the DEFENDANT at 1045:00 HOURS, on the 7th day of November., 2008 at 1 NAUGLE ROAD SHIPPENSBURG, PA 17257 by handing to ANGELA HOCH, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. - Sheriff's Costs: So Answers: Docketing 18.00 Service 15.00 Affidavit .00 Surcharge 10.00 T-. "Thomas Kline .00 43.00 11/12/2008 MAURICE & NEEDLEMAN Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. OW Request for Military Status Department of Defense Manpower Data Center •? Military Status Report rW Pursuant to the Servicemembers Civil Relief Act x Page 1 of 2 JUN-03-2008 08:32:31 Last Name First/Middle Begin Date Active Duty Status Service/Agency HOCH ANGELA Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based --on the-information that you provided, the above is the current status of the-individual as to all branches of the Military. . joi nw? fol 1014t4_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate.- In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: httt) /ww v.dcfcnselink mil/fa /pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/3/2008 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:ZGITKCDHFT https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/3/2008 . Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUN-03-2008 08:31:00 Last Name First/Middle Begin Date Active Duty Status Service/Agency HOCH WAYNE Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based onrthe informatimrthatyou-provided, the-above-is the current status of the individual as to all branches of the Military. n1121 )4. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: littp_ /ww\v.defcnselink.mil/faa/nis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/3/2008 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:ZWELYVTMME hqs://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/3/2008 ? JF °- , 10 Q 5A i 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, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WAYNE E HOCH AND ANGELA M HOCH Defendant(s) Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 08-6558 Civil Term (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $13163.91 on (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. s " R. Prothonotary/Cl k by: K 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)