HomeMy WebLinkAbout08-6842o/
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
?Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Plaintiff,
V.
Defendant(s).
115) "/?39- / 161
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. pg - 04 11 Terrt
BUSINESS FINANCIAL SOLUTIONS INC
3440 Spring Rd
Carlisle, Pa 17013
NOTICE
You have been sued in court. If you wish to defend
against the claims set forth in the following pages,
you must take action within twenty (20) days after
this complaint and notice are served by entering
a written appearance personally or by attorney and
filing in writing with the court your defenses or
objections to the claims set forth against you.
You are warned that if you fail to do so the case
may proceed without you and a judgment may be
entered against you by the court without further
notice for any money claimed in the complaint or
for any other claim or relief requested by the
plaintiff. You may lose money or property or
other rights important to you.
CIVIL ACTION COMPLAINT
AVISO
Attorneys for Plaintiff
Le han demandado a usted en la carte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta asentar una comparencia escrita o en
persona o can un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se defiende, la corte tomara medidas y
puede continuar la demands en contra suya sin previo aviso o
notifrcacion. Adernas, la corte puede decidir a favor del demandante
y requiere que usted cumpla con todas las provisions de esta demanda.
Usted puede perder dinero o sus propiedades u otros derechos
importantes para usted.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE.
SI NO TIENE ABOGADO O SI NO TIENE EL DINERO
SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA
O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE
SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
(21J) /Z59- / 161
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
BUSINESS FINANCIAL SOLUTIONS INC
3440 Spring Rd
Carlisle, Pa 17013
Defendant(s).
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 0 9- L f y a-
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, Business Financial Solutions Inc, is an individual who resides at 3440
Spring Rd Carlisle, Pa 17013.
3. At all times relevant, the Plaintiff was in the business of loaning money on motor
vehicle installment sales contracts, including but not limited to the note signed by Defendant(s),
hereinafter more fully described.
4. On or about February 24, 2005, the Defendant(s) entered into a written Motor
Vehicle Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of
obtaining financing in the amount of $82705.80 at an annual percentage rate of 9.240%, in order
to purchase a certain motor vehicle, 2005 Ford F-250 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 $1348.48 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 November 29, 2007, 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 $23000.00, however a balance of
$16995.69 is still due and owing.
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 $1067.01 and which will continue to accrue.
11. The total amount due and owing at the time of the filing of this complaint is
$18062.70.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $18062.70, 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 submi
1P.C.
CHA4(LWNE A. TAYLOR, ESQUIRE
Attorney for Plaintiff
Date: November 14, 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:
DATED: November 14, 2008
1ORIDA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT Ci a DATE 02/2412005
Buyer (alb toeuyer) Name and Address (including County and Zip Code) CREDITOR f5eer Nacre slid Address)
BUSINESS FINANCIAL SOLUTIONS. INC. JARRETT FORD OF PLANT CITY INC.
5561 NEST MATERS AVE #481 2000 E. BAKER ST
TAMPA HILLSBOROUGH FL 33634 PLANT CITY FL 33566
You, the Buyer (and Co-Buyer, it any), may buy the vehicle described below for rash or on credit. The cash price is shown below
as 'Cash Prim.' The credit price is shown below as 'Total Sale Price.' By signing this contract, you choose to buy the vehicle
on credit under the agreements on the front and back of INS contract.
1:3 Awicull-W
cmmcw
MGM I 2Cfl?Rn TRllr K I S-DTY F-350 6920 I IFTSN2IPX5EC27009 I 15Y w o
Trans s N/A s N/A
Year and Mare Grog All- Amwrrx Onbg
ITEMIZATION OF AMOUNT FINANCED
t. Cash Price .............. .................... ................ $ 61493.5 T
2. Down PsyRard
(a) Third Party Rebate Assigned to Creditor........... ..... $
(b) Cash Paid .._........ ......... .... ......... .... .................. ..... $
A
(c) Dow. Down Payment Due $
(d) Cash Dorm Payment (a, b, plus c) .................... .... $ N/A
(e) Trede4n (Description Above) ...... _..._ .......................
Total Down Paynterd (d plus e) _.......... _..._ ........ ..... $ 1808:
............. ........ $
596
3. Unpaid Balance d Cash Price (1 mil m 2)............... _ .
iL Amounts paid on your belted (SeW may be retaining a portion of these amounts)
To Public Officials
(i) for license, title B registration
N/A
lees $
(ii) for offictaf fees $ N/A
225
414
.
(i) for documerdary stamps $
(iv) for taxes (rat In Cash Price) $ N/A $ 225.40
To Insurance companies for.
Credit Lie Insurance .................. ....... _......... ........ .. .... $ N/A
Crstll Dlsabalty Insurance ...... _.._..._._..._._....«._« ._.. $ N/A
NIA _...... ..................... _.... .... $ N/A
To rw $ N/A
To ter $ N/A
To einTG rIG GI ter TAY ON SVC C aIT $ 290. 15
Tot!non GCD nor SGRUtrg CONT $ 4145.08
Total ......... _...«.«___. 4668.55
PERCENTAGE CHARGE Firwnced Paylllalts Price
RATE The soar amoart 7M amount d TM arrant The IM curt
The aml of your ma cranit we credit provided you we hew of your purchase
ram as a yearly rand cost you to you or on Maid corn you on credil,
yon hehee freve medle tee y
ou
r
Including
urn
yynn
ro
S wn
pfyrceris d
?..B
n Aamberd Amount MFach When Paymrds am due
payment Sd." _ Ifty?ft Your payment schedule S 1 saR. AR monthly sarMg
O $ 114A.4B B4/141/2B8S _
will lea: 1 ffiP
-mpayment: you pay o your early. account you will pry a penalty.
portform d esa paymsM received more
Las/ Payment: You moat pay a fate charge on the
amcurit or $50.00. whichever le lass.
than 10 days fate. The large is 5 percent of the late
Seorntly Interest You are giving a security Interest in the vehicle being pumdwead.
Contract Please see this contract for additional xdometion on secumy, interest, non Payment,
default, on right to require repsymaw of your deb in hrti betas the scMASed dam and
Prepayment PaOy-
.Any chenga6rurr c/7 on n wrldn rbl.,910= you end de (swirl.
BurERCODER: X
YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO BE BOUND
BY THE ARBITRATION PROVISION ON THE REVERSE SIDE OF THIS
CONTRACT.
=E .O' '. e RoYER
a. not o codrtreat vw r ary sms
b. You tee rmmW to an exact copy of the contract you elfin. Keep a to promo year legal
?• one- ? j?myleby
d elprtrq. C? .r, on?at? .his read In copy of We contract at the Um
X X
Bryn sign (co) swr Signs
h elgnmg Maw, rte Seer accepteBit oawact. tl w otlw A slgree Is named In a Separate
asa4pm rd attached to this contract the Soo pwwr l?a r company.
TaRRETT FORD OF PLANT INC. Tae
w 1'reDee rrer or IweAaa cabs mry won ter uee.l
law'
rcd by
dccumEntary s1amP •?xre4? be Paid
Far ?r??nh.?j??? L(1Q='as bond Paid or e i11
amount o1 ""' yT11-ent of R? Snue.133(6). lle S.11 . to -ale 001 qe s1 a i0 36 1612444.39-01.(200
CREDIT LIFE, CREDIT DMMMJ Y AND
OTHER OPTIONAL INSURANCE ARE NOT
REQUIRED TO OBTAIN CREDIT AND WILL
NOT BE PROVIDED UNLESS YOU SIGN AND
AGREE TO PAY THE PREMIUM.
1.Buyr understands cat he has the option of
assigning any other poscy or policies buyer owns
or my prowls for the Wpm of covering TMs
retail instalment sale and the poesy need not be
Purchased from the creditor in order to obtain
credit
Buyer Signs
Co-Buyer Sign
2.Buyer understands that tee credit its coverage
may be deferred e, at the time of application,
buyer is unable to engage in employment or
unable to perform normal activities of a person
of like age and sex, Y the proposed credit fie
imurence policy contain INS restriction.
Co•euysr Signs
3.Buyr understands that the benefits under the
policy vita teentnam when buyer reaches* certain
age and that buyer's ape Is accurately
represented on the application or policy.
Buyer Sgre
Co-Buyer Signs
? Credit Life
Insurer
$ N/A
Premium In-,ad(s)
signature(s)
Credit
? Disability
Inaru.r
$ N/A
Premhaw Insured
SgrWrre
DXX SERVICE CONTRACT 60
odor optimal Inau na,e Term
FORD EW $ 4145.
I r Premium
saw-
C.0 lice and Credit Disability Insurance re for the
term of the contract. Tae amount and coverages are
shown in a noaa or agreement given to you cloy.
You am required to fide the while. R a charge
is shown below. On Cm&W vie try to buy the
coverages, cha&M for lie farm $horrn. Coverages
we be based on the air vase of se vehicle at
fare of loss, but rat more than the IborM of the
Poky
ricompmherwive of; N/A Deductible
Collision
?Fae-Theft-combined Additional Coverage
OTOwing and Labor
OTemn N/A taorMs Wahmeb)
?Premium $ N/A
YOU MAY OBTAIN VEHICLE INSURANCE
FROM A PERSON OF YOUR CHOICE
UABILRY INSURANCE COVERAGE FOR
BODILY INJURY AND PROPERTY DAMAGE
Rehm Program #
QUESTK W
9
PLEASE CALL US AT 1-NO-727-7000
or
Visit us at www.fdrdcrediLe
SEE BACK FOR AOr110NrtL MRrJMUD"IL
01401
ORIGINAL
In:- 7TH.. IFTtT:T44!.14,'iF9
A Payments: You must make all payments when they are due. You
may prepay your debt at any time without penalty. This is a simple interest
contract. The actualMAnixt,Vlargi $¢eo to p>•y?at daPenOnxthy r
payment patterns. The actual finance charge, mryjexceed theAiselosed
Finance Charge it you make your paymerits#er than ifte5 died 1es
or in less than the scheduled amount. our payment will be ap?fle irrst
to the earned and unpaid pan of the Finance Charge and then to the
unpaid Amount Financed. The Finance Charge is earned by applying the
Annual Percentage Rate to the unpaid Amount Financed for the actual
lime that the unpaid Amount Financed is outstanding.
Upon your request, Creditor may agree to allow you to extend the dus
date of all or any pan of my inslaement Payment for an extension lee of
S1S.00. You will also be:required tarpJr(e0dsyrerxe rxrverage
required by the contract to cover the exlehsion-pe-ih: lFratldigorl to tlta
extension lee, you wig also be required to pay arty eddbonal finance
cherges which -" as a result of your being alloweb 4o extend your r t
payment.
B. Security Interest: You give the creditor a seamy interest in:
1. The vehicle and all parts or ottwr goods put on ttie'velhicl?;? i
2. All money Or goods received for the vehicle; tiro
3. AN insurance plants s and service consacls financed tor yft M8
This secures payment of alt amounts you owe in this contred.AN-
seaures your other agreements M this contma
_ q? v h(]t '
C. U96 of
obey at laws inn using of mayynot sell or krerd Iha"b l T , rid ayou
must keep it tree from the claims of others. You wis-1 oiWo6i=permit
the use of the vehicle outside of the United States, except for up to 30
days m Canada or Mexk:o, without the prior written consent ol the Creditor.
If the vehicle is of a type normally used for personal use and the
Creditor, or the vehicle's manWeeturar, extends a written warranty
or sarvke contract covering ON vehicle within 90 days from the dab
at Ibis conitack you gat implied wenrartlas Of merchantability and
Writes For • particular purpose covering the vehicle. Olhowlas, you
understand and agree that mere are no such hall wannaa
r.nro
D. Vehicle Inver-Oo: You must Insure Yourself and Me
Creditor against loss or damage to the vaNCle. The type and amount d
Insurance must he approved by the Creit., Whether .,net the vahlelo
Is insured, you must pay for It if it to last, damaged, Or destroyed.
II a charge for the vehicle insurance is shown on the4oAL the Creditor
will try to buy the coverages checked for the term 3MWO. This Creditor
is not liable, though, it he can not do so. N Mess coverages tom more
than the amount shown for-insurance, the Credior spy diem for a
shorter term or he may give YOU credit for the amount shown the cannot
buy any insuran-, he will give you credit for the ambumr'aho?wh. The
credit will be made to the last payments due.
E. Lab Charge: You will haw to pay a late charge on the portion of
each payment received more than ten days lab. The dame Is shown
on the from. You must also pay any out paid by the Creditor to collect
any late payment, as allowed by low. Acceptance of a late payment or
late charge does not excuse your default or mean that you can keep
making payments after they are due. The Creditor may take the steps
set lorlh above If there is any default.
-" 3"UR32 ••
-P.a-
F. Default: You will be in default it:
I. You do not.mpke silly. le h)$!?a 8r;LWPenat,lAdue;prC
?,,.••2?e ,
2. You gave 1&6 or'dlls I)aYbn ydur credd'
appliwbon relating to Rt trk14!'br="?A-+ ?23a tr"
3. Your vehicle is seized-by i6y Idisl; dffite'.RR,tkGdre(ri C "':.'
authority and is not promptly and unconditionally
refused to you: or
o. You file a bankruptcy petition or one is filed against you; or
S. You do not keep any other promise in this contract.
If you are in default, the Creditor may require you to pay at Once the
unpaid Amount Financed, the earned and unpaid pan of the Finance
Charge. and all other amounts due under this coeditel.'He may repossess
-(take tu&F16e v'efii W, WZ. He may alaolaFe'gddB9Teund in meyphk:le
when repossessed and hold them lot you.
It the vehicle is taken back. he will send you a notice. The notice will
say that you may redeem (buy back) are vehids. ft wig else show the
amount needed to redeem. You may redeem the
vehicle up to the lime the Creditor sets it or agrees to sell e. 11 you do
red redeem the vehicle, it will be sold.
The money from the sale, less the allowed expanses, will be used to
pay the amount AN owed on this contract. Allowed expenses are those
paid as a dined result of having to retake the vehicle, hold it, prepare 9
or sale, and sell b. Lawyers' tees and legal coals permitted by law are
allowed, too. It there is my money left is swphu), d will be paid to you.
If the money from the sale is not enough to pay off this comraet and
costs, you will pay what is sts owed to the Creditor.
G. Consumer Reports: You authorize Ford Motor Credit Company to
obtain consumer cmda reports from comma reporting agandes (cede
bureaus) for any reason and at any time In connection with this account.
H. General; To contact Fad Moor Creole Company aboul this account,
call 1-SOC6-n,7-7000. Also, you may mks address and other selected
changes glwyr-fordcr"Lcorn. The law of Ronda appNes to this con-
tract. It t?p!taw does not allow all of the agreements in Ibis convect,
the ones Ifiet'are? not Mowed will be void. The real of this contract will
51HI be goo'd.•- !
NOTICE - ANY HOLDER OF THIS CONSUMER CREDIT
CONTRACT IS SUBJECT TO ALL CLAMS AND DEFENSES
WHICH THE DEBTOR COULD ASSERT AGAINST THE
SF1 I ER OF GOODS OR SERVICES OBTAINED PUR-
SUANT- HERETV OR' WITH THE7 P ED4 HEREOF.
RECOVERY-HEREUNDER BY THE OMETOR?HALL NOT
EXCEED AMOUNTS PAR) BY THE DEBTOR HEREUNDER.'
Used Motor Vehicle Buyers Guide. U you are buying a used
vehicle wind lane contract, tederal regulations may require a
special Buyers Guide to be displayed on ft window of the
vehicle- THE INFORMATION YOU SEE ON THE WINDOW
FORM FOR THIS VEHICLE IS PART OF THIS
CONTRACT, RWORMATION ON THE WINDOW FORM
OVERRIDES ANY CONTRARY PROVISIONS IN THE
CONTRACT OF SALE
'Does not apply If purbltseed for commamlel or agricultural
use. In that case, you (debtor) will not assort against any
^B . dCa .orb uepL hM Hof this contraetany elahne,
daienses, or? whl?eft you may haw ergalnst the seller
or manufacturer of the vehicle.
• REAB3311SoARBTTRATION PROVISION CAREFULLY AND IN ITS ENTIRETY
ARBITRATION a:.BrFt -
Arbitration is a melhOn of resclvkg any calm, dispute, or contreveasy,;op?activelyr a 'Claim') the)d PYy,tg a lawsuit in con. Either you a Creditor ('os' or
'we-) (each, a 'Pam) may choose at any ems. including alter a wsua Is Tiled, o have any Cfarm-bb ad odes contract decided by arOwaed. Such
Calms Inside but am not limited to rile khlowhg: 1) Claims in contract, kA regulabry or ellwrmse; 2) Claims regarding the interpretation. scope, or
valift of this clause, or arWlradlily of any issue; 3) Claims between you and us, our employees, agwas, successors, assigns, subsWlades, or afMatas; a)
Claims arising out of or relmig to your apperalkn for credit, ehb contract, or any rasuleng trersacdon or relationship, tnclu Ping that with the dealer, OF any
such res9otrlap with third parties who do not sign this contract.
RIG/frS YOU AND WE AGREE TO OWE UP
Ae'llther you or wit choose to a rate a CIO". Men you kin we agree to welve the I.Nowfng new
• RIGHT TO A TRIAL, WHETHER BY A JUDGE OR JURY
• RIGHT TO PARTICIPATE AS A CUSS REPRESENTATIVE OR A CLASS MEMBER W ANY CLASS CLAW YOU MAY HAVE
AGAINST US WHETHER W COURT OR IN ARBTRATION
• BROAD RIGHTS TO DISCOVERY AS ARE AVAILABLE IN A LAWSUIT
• RIGHT TO APPEAL THE DECISION OF AN ARBITRATOR
• OTHER RIGHTS THAT ARE AVAILABLE IN A LAWSUIT • y a
y
Rla1hb Yeu led We 00 Not Cave Ua: It s CWm is arbitrated, you and we wig continue to have 0w following rgi wiMOhd *at, im this arbitration pt-
and es b any Claim: 1) Right b file bsnkruprey In count 2) Right to enlace the saauay Interest in the vends, whether by repossession or through a i
esun of law. 3) Right to lags legal action to enforce the arbituri decision: and 4) Right to request that a court of law review whether the arbitrator
exceeded ea milt".
Either Patty =at contact my association below and the other Patty to start arbitration. The applicable noes (the'Rolesry may be obtained from the aoso-
detierL
• Anudcart MbMatko Aswcarksh ('AAA'). at 1.800-778-7879, or wwoodr.org;
• JJLM.SJErdlspute, at 1-80104411-1890, or
www.pmcedr rnn;
National ArhssOen Fown, at 1.800474.2371, or www.erb-Ioum.com.
9 there is a coo between Bat Rues and this contract, this contract shag govem. This contract is sublect to ttw Federal Arbitration Act
to U.S.C. S t at all.) and the Federal Russ of Evidence. The arbitration decision shal be In adding with a supporting opalion. We will pay your bW nes-
sarMble arbitration fees and expenses (hilt Inch dig asarney fees, except where eppliude law dMW*im provides) in ammi of $126. We oil pay ft
whole Nag hie 8 we demand arbitration Trot. Any portion of this adahafbn dam that is unardo"able ahefi be swaraL end the rernWthg provisions
shin be enforced-
. GUARANTY --I .v--- -,p . -,I rFr-
To cause th e Seller to sell the whfole described on the hoot of this contract to the W*, on credit, each person Who signs below as a
'Guarantor guarantees the payment of this contract. This rnsans that if the Buyer talk to pay any money that k owed an this
contract, each one who signs as a guarantor will pay It when asked Each person who signs below agrees to he will be Noble for the
whole anhmmt owed even I one or more other persons also signs On Guaranty. He also agrees to be Noble oven R tin CredltoF does
one on more of the following: (a) gives the Buyer nitre time to pay one or more payments, or (b) gives a release in lull or in part to
any of ft OVMr G a (c releases any security. Each Guar9rNor also states that he has neceNed a completed copy of this
contract and this G at ne of sighing.
Guarantor, z ?C Address
Guarantor Address
,.w.w ,w• v, v..wa. rwuo. sec coo, excow
"`PRN"'
Ford Motor Credit Company
P.O. Box 31111
TAMPA, FL 33631-31 1 1
(877) 349-5260
POGHRN00200038
BUSINESS FINANCIAL SOLUTIONS INC
19046 BRUCE B DOWNS BLVD
TAMPA FL 33647-2434
Date of Repossession 02-20-2008
Date of Notice
02-21-2008 Date of Contract
02-24-2005
Account Number: 038620656
Buyer BUSINESS FINANCIAL SOLUTIONS INC
Cobuyer
DESCRIPTION OF PROPERTY
Year
2005 Make
FORD ?x New
? Used
Vehicle Identification Number:
1 FTSW21 PX5EC27009
Model
F250 Body
4X4
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
o?
o?
g=
x] PRIVATE SALE: We will sell the property described above at
private sale sometime after 10 days from the Date of Notice
shown above.
? 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 follows:
Date of Sale Time of Sale Place of Sale
You may attend the sale and bring bidders if you want.
The money that we get from the sale (after paying our costs, including reasonable 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. To learn the exact amount you must pay, call us at the telephone number 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.
If you need more information about the sale call us at the telephone number above, or write us at the address above.
We are sending this notice to the following people who have an interest in the property described above or who owe
money under your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below;
3) If there are other people, they are named on an attachment sent with this notice.
? The property has been (or will be) returned to:
(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.
Q PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by
contacting this office. Thereafter, 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 not accurate for any reason, please contact us so that we
can accurately report the vehicle's mileage.
INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealer/original creditor to make sure that any insurance
has been cancelled. You have a right to get credit for all premium refunds.
VICTORIANO RAMOS
FFNA 11988 Jan 02 Previous editions may NOT be used. CUSTOMER/CUSTOMER FILE
Printed in U.S.A.
OGHRN_002 E00038-1000238 2!2
Ford Motor Credit Company
P.O. Box 31111
TAMPA, FL 33631-3111
(877) 349-5260
o.
POGHRN00200038
BUSINESS FINANCIAL SOLUTIONS INC
19046 BRUCE B DOWNS BLVD
TAMPA FL 33647-2434
OGHRN_002 E00038-1000237 1/2
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-06842 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
BUSINESS FINANCIAL SOLUTIONS
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
BUSINESS FINANCIAL SOLUTIONS INC but was
unable to locate Them in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
,
NOT FOUND , as to
the within named DEFENDANT BUSINESS FINANCIAL SOLUTIONS
INC
3440 SPRING RD
CARLISLE, PA 17013
BUSINESS ALLEGEDLY WENT BANKRUPT OVER 1 YEAR AGO IN FLORIDA;
BUSINESS WAS NEVER LOCATED IN CARLISLE, ONLY IN FLORIDA.
Sheriff's Costs: So answers:
Docketing 18.00
Service 5.00 Affidavit .00 R. Ttiomas Kline
Surcharge 10.00 Sheriff of Cumberland County
Not Found 5.00
i2-I1?LjoY ? 38.00 MAURICE & NEEDLEMAN
11/24/2008
Sworn and Subscribed to before
me this day of ,
A.D.
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
BY: Charlene 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
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff,
V.
BUSINESS FINANCIAL SOLUTIONS INC
Defendant(s).
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 08-6842 Civil Term
PRAECIPE TO WITHDRAW COMPLAINT
TO THE PROTHONOTARY:
Kindly Withdraw the Complaint originally filed with the Court on 11/19/2008.
MAURICF? NEEDLEMAN, P.C.
BY:
Charlene Taylor, Esq.
Attorney for Plaintiff
Date: December 18, 2008
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