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Home My WebLink About08-7334ARBITRATION 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 Attorneys for Plaintiff [-5)'/89-'/1()1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. THOMAS W LANDER 93 Big Springs Terrace Newville, Pa 17241 CAROLYN L LANDER 93 Big Springs Terrace Newville, Pa 17241 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. p$ - ?33M C iv i 1 Term 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. 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. AVISO Le hen demandado a usted en la carte. Si usted quiere defenderse de estas demandas expuestas en les paginas siguientes, usted tiene vemte (20) dias de plaza at partir de la fecha de la demanda y la notification. Hace faha asentar una compareneia 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, to carte tomara medidas y puede continuer la demanda en contra suya sin previo aviso a notification. Ademas, la corte puede decidir a favor del demandante y requiere gut usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFiCIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor; Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7161 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. THOMAS W LANDER 93 Big Springs Terrace Newville, Pa 17241 CAROLYN L LANDER 93 Big Springs Terrace Newville, Pa 17241 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. CIVIL ACTION COMPLAINT 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, Thomas W Lander, is an individual who resides at 93 Big Springs Terrace Newville, Pa 17241. 3. Defendant, Carolyn L Lander, is an individual who resides at 93 Big Springs Terrace Newville, Pa 17241. 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 December 4, 2003, 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 $23910.60 at an annual percentage rate of 11.900%, in order to purchase a certain motor vehicle, 2003 Saturn Vue 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 $390.31 for a period of 60 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 20, 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 $2600.00, however a balance of $7141.24 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 $621.64 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $7762.88. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $7762.88, 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, , P.C. Attorney for AVLOR, ESQUIRE Date: December 12, 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: CHARLENE A. TAYLOR, ESQUIRE DATED: December 12, 2008 YCIVINIWLVOW011 lnwrtc anrCnCOr vcrwan-c ncrwrt. in rnaww Buyer (and Co-Buyer) Name and Address (including County and ZIP Coft) CREWTOR (Seller Name and Affiliates) DEC p 5 2p? THOMAS W LANDER CAROLYN L LANDER SUTLIFF CAPITAL FORD 93 BIG NEWVILLEPPAN17241RRACENEWVILLEPPAN17241RRACE HARRISBURG1000 177105X 1737 \\ l1Sc??h You, the Buyer (and Ce4yuyar. If any), may buy the vehicle described below for cash or on emdlL The'Caeh Prka' shoaw below lathe cash price d tin vehicle. The -Total agile pike' shown baba Nair credit Price. By signing this comrwt. you chows to buy on credit under me arteeman s on the frmq and beck of this contract. I I i I ?Ag irrel USED 103 SATURN VUE N/A SGZCZ63803SS12697 13 consnerdel I Trads-in OOCnaD FOCUS a 6706 .? "0 a-b-Z06--4?- Vet and Make Gross Alcwance Amount O2;; ITEMIZATION OF AMOUNT FINANCED 1. Cash Price ................. _._................ 16995.00 2. Down Payment Third Party Rebate Assigned to Creditor .................. _.__... $ M/A Cash Down Pa ment..._ .............._..............._.................... .... $ 500_(1(1 Tracl&4n 00 F R §706.40 $ 6706.40 $ MIA Yw..a Paw. arcs Abase AnsreA DAV Total Down Payment ....... ................ _......_..............._._._......_.... $ GOO nn (2) 3 Unpaid Balance of Cash Price (I minus 2)......... ............. ........_. $16496 09- (3) 4. Amounb paid on your behalf (Seller may be retaining a portion of these amounts) To Insurance Companies for Croft Life Insurance (for term of contract) $ N / A Credit Disability Insurance (for tone of contract)............. $ -NI!A? (Tenn ---Months (Estimate)) $-N/A To Public Officials (f) for license tale registration ($- NIA ) tees $z2e.5e (d) for filing fees $ 5 00 (iii) for taxes (not in Cash Price) $ 637.12 S 67th 62 To SUTI IFF GAnrTAr fin E$ 55 nn To for $_ IA To EVERGREEk ORr for GAP IN $??.00 To for $ N/A Total __ ...................... ............................. _............. ................. $ 1065.69 (4) FEDERAL TRUTH-IN-LENDING DISCLOSURES ANNUAL FINANCE Amount Total of Total Sale PERCENTAGE CHARGE Finarmed Payments Price RATE The dollar amourd The arrant of rare arnamt The kw eoel The oust of your the credit will credit Wokled to you ova have of your ptnctrse on txadit as a yearly role ° you you or on your Paw when you teed 1, behalf have roeffs M including V= adrdurad downpayment Payments d s-398Tgg_ all % $--6g67-g8 755g 62- 2 $ Paymett Schedule Number of Aloud of Each When Payments ? PsymMb Payment we due Your payment sctiedde 69 $ 3go-31 (monthly staling) all be: 1 " $ 399.31 ei;063 2004 POWOVIVO y gi p YY ou i pay off Payaa Igo debt sairly, dirge c you an to vA not how to Pam of end paym meirttr Lab receNed more than 10 drys b*. The dwgs M 2 paca of to leas sagwn or SSIL00 whbhinow lsMae. SWL%* bdsraat You are ghring a 88mn r ktMreat in go V*kb ban purdord. Contract PW? ? this CMWM additional Information lly I debuh. OW night b require MOM" 01 Yw OW in ld beforecetronsclhedn? dace. PrePaY?1 PanAlhr• N you do not meet Vote contract oblpMMro. you may iae lr vii Brat you ate Msiebq rxtMr 91111oontram as wed as both Pale NO goods pt on the vehicle and matey or goods recwhad Our the vehicle. U044660ICATiON DISCLOSURE Any charge In tlW contract must be in willing and signed by you and the Creditor. Y TH ARBrrRRATWN PROVISION ON THE REVERSE SIDE B OF 71NN8 CONTRACT NOTICE TO BUYER Do not sign this contract in blank You are entitled to an exact copy of the contract you sign. Keep It to protect your legal rights. Buyer (and Co-Buyer) acknowledge that (1) before signing this contract Buyer ((and Co-Buyer) received and. reviewed a `rue and Cem letely tied in copy of this contract and (11) at the time of sic rain this contracts Buyer (and Co-Buyer) recerv d a true an complet IN y e n copy of this contract. I A" n ay atgnrirg below, So sailer accepts tds mtrsef. E no afar Assiaass is mailed in a eepanaM eeelgrnanert sYached to tts contract No SBW X== aa Credit SUTLIFF CAPITAL FOR ?Title Fc 17W.M cad O (hrASa adrwe ear b rreeal SEE B11CR FOR ADOmONAL AOREENENrS PA YOU MAY OBTAIN VEHICLE INSURANCE FROM A PERSON OF YOUR CHOICE. YOU ARE NOT REQUIRED TO OBTAIN CREDIT LIFE, CREDIT DISABILITY AND OTHER OPTIONAL INSURANCE. THIS CONTRACT WILL NOT INCLUDE THEM UNLESS YOU SIGN AND AGREE TO PAY THE PREMIUM. THIS CONTRACT DOES NOT INCLUDE LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS. ? Credit Life Insurer $ N/n Premium Insured(s) SI(pheture credit ? Disability Insurer $ N/A Premium Insured Signature Other Optional Insurance Team $ rite Insurer Pramrem m? Credit Lae said =IooOsaft Y Yqunrrpe are for ate win of ire MreL 11n rnoua rain =11=0 M a ace or agreement You avert bare the Yatlolat. N a Charge b at1 , below Use Gabler wit try b Wry eovverrva se c) for do COMat on to Cash value of vNreM rt W to badaIOes, but not hnorat Uhan the Use Inrtts d tW potty. ? ? $ Deductible ? Fie. YhMC=bW" Additional Coverage ? Towing and Labor ? Tema Months (Eeamarts) 1f INt ells b dih.dbd you iew puigpad ~&dsM trorrcaYbn wakwr. 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Start bmat Yw on M on" S M.; NdBSd k f.1M vsYab td r pSA r aBr pads pd a M wIiIK ! N rmameyrptrraSdrOdlrMvYidSl d r. M tmBtmett plMdrRrt d tents tRitub Srtrrttdli yau. TNS tanma PWmt d Sr amMO yor Sari b /lb tam N tit taoareyew abr tpadauda b Nt toWAIL ,?' "'PRN"' Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631-3111 (877) 349-5260 P0E9W3W300031 CAROLYN L. LANDER 93 BIG SPRINGS TERRACE NEWVILLE PA 17241 Date of Repossession 11-11-2007 Date of Notice 11-13-2007 1 Date of Contract 12-04-2003 Account Number: 035734895 Buyer THOMAS W. LANDER Cobuyer CAROLYN L. LANDER DESCRIPTION OF PROPERTY Year 2003 Make SATRN ? New Used Vehicle Identification Number: 5GZCZ63B03S812697 Model VUE Body NOTICE OF OUR PLAN TO SELL PROPERTY C a S. m We have your property described above because you broke promises in our agreernent. ?x PRIVATE SALE: We wile sell the properly described above at ? private sale sometime after 15 days from the Date of Notice shown above unless redeemed by you prior to such sale. 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. PUBLIC SALE: We will sell the property described-above at public sale to the highest bidder on the date below (or any adjoumment date). The sale will be held as follows: Date of Sale Time of Sale Place of Sate You may attend the sale and bring bidders it you want. _ - -- -- -- T NOTICE OF REPOSSESSION The property is presently stored at. NATIONAL AUTO DEALERS_ 0( HAN 730 ROSE 68 HOW TO GET YOUR PR C9*010 To get your properly back, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 9,135.07 Plus Costs: Repo Expenses $ 399.00 $ s Plus Late Charges $ 3124 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 9,565.31 (Plus expenses incurred N default at the, time of repossession exceeded 15 days and Was rebate received after the date of this notice.) Your property wont be sold txW 16 days alter the date of this notice at the EARLIEST. After that you can still get It beck any time before it's actually sold. If you do, well have no further claim on it. But the longer you wad, the more costs (including repairs) you may have to pay. If you have any questions about this, please call us. ? The property has been (or will be) returned to: (dederloriginal creditor) Under our agreement with your dealer/original creditor, the dealerloriginal 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 next 60 days or, in accordance with state law, by contacting this office. Thereafter, the personal property sham be disposed of accordingly. ? Creditor has assigned to its qualified intermediary (OI 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 vehicles 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 caraefled. You have a right to get credit for all premium refunds. JACKIE X. RIVERA FFNA 119M.37 Jan 02 Previous eddB may NOT be used. CUSTOMER/CUSTOMER FILE Printed in U S.A. "'PRN"` Ford Motor Credit Company P.O. Box 31111 TAMPA, FL33631-3111 (877) 349-5260 P0E9w3w300027 THOMAS W. LANDER 93 BIG SPRINGS TERRACE NEWVILLE PA 17241 g = LANDER Cobuyer CAROLYN L. LANDER DESCRIPTION OF PROPERTY Year 2OD3 Make SATRN ? New ? Used Vehicle Identification Number: 5GZCZ63603S812697 Model VUE odY NOTICE OF OUR PLAN TO SELL PROPERTY .._ ._.._ .._.._ ... , w.e..rrved aMve because you broke promises in our agreenreM. u s i.. i= I1S. ?x PRIVATE SALE: We will sell the property described above at ? private sale sometime after 16 days from the Date of Notice shown above unless redeemed by you prior to such sale. The money that we get from the sale (after paying our costs, including reasonable attomey'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 callus at the telephone number above, or write us at the address above. If you ward 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 toyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other Deople, they are named on an attachment sent with this notice. PUBLIC SALE: we wa am me pnupa c7 uc.+..,,.+_.. - - r--1- 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. 1 NOTICE OF REPOSSESSION The property is presently stored at: NATIONAL AUTO DEALERS EXCHANGE 730 ROUTE 68 HOW TO GET YOUR PR®BBEPfM*= To get your property back, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 9,135.07 Plus Costs: Repo Expenses $ 399.00 $ $ Plus Late Charges $ 31.24 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 9,565.31 (phis expenses incurred if default atttne time of repossession exceeded 15 days and less rebels received after the date of this notice.) Your property won't be sold until 15 days after the date of this notice at the EARLIEST. After that you can still gat It back any time before irs actually sold. If you do, well have no further claim on it. But the longer you waft, the more costs (inckrdi(V repairs) you may 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 it to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or. in accordance with state law, by contacting this office. Thereafter, the personal property shall be disposed of accordingly. ? Creditor has assigned to its qualified intermediary (OI Exchange, U-C) 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 hack, cap the insurance company or the daafer/original creditor to make sure that any insurance has been canceled. You have a no to gat credit for al premium refunds. JACKIE X. RIVERA FFNA 1199&37 Jan 02 Previous editions may NOT be used. CUSTOMER/CUSTOMER FILE Pnrrted in U.S.A. all A '•3•, I _ ::?` -`•;;;; 01300 - : -_ o00 cc i- m _ ru s -rr G C C C J u n r c c r am U'l 0°04 NV-Ja ,-g ?a?40CL ra m M nr s m a- 1 Cr n 0 nu ?Ln (r` 0 I° , r- cc.?a: ?:. =.?.. 'rMo LU -3 00 C', us fn z :..... J-:. ?j.:;n .r vJV? w¦yv0 0 cu Bu fpusN I m m a u 14cuum uo1;E o O O O O 1° ..0 G Q a ^M, W •Y ru r` Q m c C3 cv r` a¦ Q r• r` .CF Uzz W ru toc, Mw ri0W.CO -J r3 °"i-jZno? I--crwm° ?Q-?'? t?C*-i -1 14 32 g4Uv? ?V O adz: z r` _o M ru a- m 0 C O O 0 .A m ni r` 0 0 r- W W mom 0 o? Z >- W V-J:jm? V- 3 r` m ru M S, Q 0 O 0 O Jn Ln ni N 0 C7 r` AAQA rq ep m ru -r m s ?C C c c ?c J n U r c c r I W i t W UJ C1-N ti ix CL c w? cW ?CL a) w ' In A3`W -l c 0 O E a a z a. Ll a a 0 Ily ' 1= ,ir 40 P. n?ey ?_. _$ N ny --r A -r ru all m ue? C! 7-F. LL ? o O 4 y y. O O O M Q O O e O C3 . 13 a ;c? = wniy = s U O ' r te .e:: _ ::.t = su; O y1 F-r _n ru Z ru r%- M1 O U G ? r• a -> Q M1 .21 LLJ c4 .'?57s" .Y- a Q A 0 w 0 R ""' sSaa Y; ?5?? f' to V Q Z 7p o ? uj:9 3 ?, o Q L'i a ?cc`?aYR?Q? J NgNz?m ?jZmW ?S?ltl i $ S r O W r =mh ?3??,,oC Yf'tiQ r YUON Dm?thC? Co 1L. $ d s' ru DDDI? $ 4; Q ?p ra a tf 1 1 N 0 DOE \ ` j O V C7 1 Q in T-4 tu 0•, Y a W Z G Sh m •a ?"'gza om??Wr3 O a zOCW ?o-i 3 m h 00 l'n - ^jr0) CO) 4 oo ?Q4QP?u ,MID ?UtoZ V-u N NaaONZ ?z°o 8 J-? a?3 d ... .: % ^- I Q Tz a N}fNpQNE V W l+7 m m N N Gf a {' J ?. 1 It l o U MmW.CO-- , a QIL I t i • Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2008-03-19 CAROLYN L. LANDER POH4Y"100071 93 BIG SPRINGS TERRACE THOMAS W. LANDER NEWVILLE PA 17241 93 BIG SPRINGS TERRACE NEWVILLE PA 17241 STATEMENT OF SALE Account Number: 035734895 The following property has been sold. Year Make Model Vehicle Identification Number: 2003 SATRN VUE 5GZCZ63B03S812697 Balance owing on your contract (1) $ 9,166.31 Deduct: Finance Charge Rebate (2) $ 0.00 (3) $ 9.166.31_ Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale $ _ _2 600.00_ (4) (5) $ 6,566.31_ Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and (6) $ 589.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. (7) $ o.oo Deduct: Insurance Premium Rebate (g) $ 14.07 Other: (9) $ 7141.24 Deficiency" (10) $ NIA Surplus" will change based on monies received by us (credits) or additional allowed expenses & interest i fi ency c The Surplus/De 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. amount shown on line 9 to the address for it th ** If the sale resulted in a deficiency, you should im e mediately rem 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 MESA ARIZONA 85216-6508 DEPT 194101 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 FFNA11990 01/04 Previous editions may NOT be used. Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2008-03-19 THOMAS W. LANDER 100072 PoH4vNOO 93 BIG SPRINGS TERRACE CAROLYN L L. LANDER 93 BIG SPRINGS TERRACE NEWVILLE PA 17241 NEWVILLE PA 17241 STATEMENT OF SALE Account Number: 035734895 The following property has been sold. Year Make Model Vehicle Identification Number: 2003 SATRN VUE 5GZCZ63B03S812697 - (1) $ 9,166.31 Balance owing on your contract` f2) $ 0.00 Deduct: Finance Charge Rebate (3) $ 9.166.31 Balance less Finance Charge Rebate (1 - 2) (4) $ 2,600.00_ Deduct: gross proceeds of the sale 6 566.31 Balance less gross proceeds of the sale (3 - 4) (5) $ Add: Expenses of retaking and storing, and (6) $ 589.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. (7) $ 0.00 Deduct: Insurance Premium Rebate (g) $ 14.07 Other: (9) $ 7141.24 Deficiency*" (10) $ N/A Surplue 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: Ford Motor Credit Company P.O. BOX 6508 MESA ARIZONA 85216-6508 (800) 732-2264 Mail deficiency payment to: Ford Motor Credit Company DEPT 194101 P.O. BOX 55000 DETROIT MI 48255-1941 FFNA11990 01/o4 Previous editions may NOT be used. O 44- qu Fo-l w ? (?j/?yy' T CLA) SHERIFF'S RETURN - REGULAR CASE NO: 2008-07334 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS LANDER THOMAS W ET AL TIMOTHY BLACK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LANDER THOMAS W the DEFENDANT at 1000:00 HOURS, on the 29th day of December , 2008 at 82 BIG SPRING TERRACE NEWVILLE, PA 17241 by handing to THOMAS W LANDER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 10.80 00 ;400 .00 10.00 R. Thomas Kline .00 38.80 12/30/2008 MAURICE & NEEDLEMAN By. day Deputy Sheriff A.D. w? ,.?„? ' ? ?,# .as..? ?. ¢ ?.... r e;-; ?, ?:. _7 r `'w? SHERIFF'S RETURN - REGULAR CASE NO: 2008-07334 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS LANDER THOMAS W ET AL TIMOTHY BLACK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LANDER CAROLYN L the DEFENDANT , at 1000:00 HOURS, on the 29th day of December , 2008 at 82 BIG SPRING TERRACE NEWVILLE, PA 17241 by handing to THOMAS W LANDER ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of 6.00 .00 .00 10.00 .00 16.00 day So Answers: f R. Thomas Kline 12/30/2008 MAURICE & NEEDLEMAN By: Deputy Sheriff A. D. m? f ..?k l..i } 1% . MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 85248 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. THOMAS W LANDER CAROLYN L LANDER Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 08-7334 Civil Term PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the verification of the Plaintiff, FORD MOTOR CREDIT COMPANY, A Delaware Limited Liability Company, for that of the verification previously filed. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. Date: February 19, 2009 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Charlene A. Taylor, Esq. hereby certify that on this date I have caused a true and correct copy of the foregoing Praecipe to Substitute Verification on behalf of FORD MOTOR CREDIT COMPANY, A Delaware Limited Liability Company, to be served by regular, first class mail, postage pre-paid upon: THOMAS W LANDER 93 Big Springs Terrace Newville, Pa 17241 CAROLYN L LANDER 93 Big Springs Terrace Newville, Pa 17241 Respectfully Submitted, MAURI & NE DLE AN, P.C. BY: Charlene . r, wire Attorney for Plaintiff DATED: February 19, 2009 VERIFICATION I Judv Aden_, verify that I am the Authorized Representative for Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A Delaware Limited Liability Company, and are duly authorized to take 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: Kepre a tative Plaintiff, FO OTO REDIT COMPANY LLC, A Delaware Limited Liability Company DATE: WC 12 20M THOMAS W LANDER Our file no. 8902 48063000000035734895 5- N d. :Mv 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 (215) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. THOMAS W LANDER AND CAROLYN L LANDER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 08-7334 Civil Term PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: No answer having been filed in the above Civil Action, kindly enter Judgment in favor of Plaintiff, and against Defendant, THOMAS W LANDER and CAROLYN L LANDER in the amount as follows: Principal Amount $ 7141.24 Interest to Date $ 831.18 TOTAL $ 7972.42 MAURICE & NEEDLEMAN, P.C. J BY: I CH"ARLENWA. TAYLOR, ESQ. Attorney for Plaintiff Date: April 10, 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 ("115) /89-/15?) FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. THOMAS W LANDER AND CAROLYN L LANDER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 08-7334 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 02/12/2009 to Defendants, THOMAS W LANDER and CAROLYN L LANDER, 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 02/12/2009, a copy of the mailing to the Defendants and affidavits of service are all attached hereto. MAURICE & NEEDLEMAN, P.C. BY: CHARLENEA. 'T'AYLOR, ESQ. Attorney for Plaintiff Date: March 11, 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 (L1J) /Z59-nn, FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. THOMAS W LANDER AND CAROLYN L LANDER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 08-7334 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 02/12/2009 he/she mailed a written Notice of Intention to File the Praecipe to Defendants, THOMAS W LANDER and CAROLYN L LANDER, at 93 BIG SPRINGS TERRACE, NEWVILLE, PA 17241 by regular mail. MAURIC YNEEL N,P.C. BY: C YLOR, ESQ. Attorney for Plaintiff SWORN TO AND SUBSCRIBED before me this / S day of 97142e'Q00 r, Notary Public ASM _+ 3 .?, Pift cau* 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 (213) /259-1133 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. THOMAS W LANDER AND CAROLYN L LANDER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 08-7334 Civil Term CERTIFICATION OF ADDRESSES It is hereby certified that the parties have the following addresses: Plaintiff: FORD MOTOR CREDIT COMPANY P.O. BOX 6058 MESA AZ 85216 Defendant: THOMAS W LANDER, CAROLYN L LANDER 93 BIG SPRINGS TERRACE, NEWVILLE, PA 17241 tAN, P.C. TAYLOR, ESQ. Attorney for Plaintiff Date: March 11, 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 (Z1J) 7iSy-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. THOMAS W LANDER AND CAROLYN L LANDER s CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 08-7334 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she represents the Plaintiff in the above entitled case and that Defendants, THOMAS W LANDER and CAROLYN L LANDER, are over 18 years of age; the occupation of Defendants is 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. MAUR BY: Attorney for Plaintiff , P.C. LOR, ESQ. SWORN TO AND SUBSCRIBED before me this 1 day of 7na,7? 200q. MOT _ Notary Public bpi Attorneys at Lee Suite 935, One Pea" Cello 1611 John F. Kennedy 81rd. moods lphie, PA 19103 to 1.215.665.1133 lax 215.563.8910 WW w.mnlowyc.con Darrow S, amin Member NJ to toard certified Creditors' Ryles Low American Ward of Certtfitalim Joann Mew Mem bar PA R NJ Wr Thomas I. Domincslk Member 811, NY i PA Nor Charlene A. Taylor Member M Bo New Jorsey Offics Maurice d Meedlemon, P.C. Suite 2001 5 Walter E. Force fled. Flemington, NJ OU22 tel. 901237AS50 fax 901.231.1551 February 11, 2009 CAROLYN L LANDER 93 BIG SPRINGS TERRACE NEWVILLE, PA 17241 Our File No. 8902 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. THOMAS W LANDER AND CAROLYN L LANDER CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 08-7334 Civil Term Dear Ms LANDER: 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 Plaintiff's Complaint served upon you on 12/29/2008. 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, M,MMCE EEDLEMAN, P.C. Ch ne A. Taylor, 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 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)) 789-715.) FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. THOMAS W LANDER AND CAROLYN L.LANDER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 08-7334 Civil Term IMPORTANT NOTICE TO: CAROLYN L LANDER DATE: February 11, 2009 93 BIG SPRINGS TERRACE NEWVILLE, PA 17241 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 r 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 MAURICI.k & NEEDLEMAN, P.C. BY ARLENE AV TAYLOR, ESQ Attorney for Plaintiff 1 06280005583191 18 0 N LL o Q LN g?Q rna - J C CO - V! _3 LL W ? _ U0)Z U ,. a z V) ?w? wZ? W U a ZZ= waJ Sao wog ?L C4) X rnM d February 11, 2009 Attorneyseler Suite 935, One Penn Center 1617 John F. KemmdyNW. tMiedel}lis, PA 19103 fol. 215.665.1133 fox 215.563.1970 aww.endawyr.com Donald S. Nuke NemberN! her bard CerKCted creditors 1islikL- American loerd of Cedifiatioe bane Neediness Member PA a U Sur Tbomos 1.9omieayl Member NJ, BY a PA Off Chalene A. Tyler Member PA In THOMAS W LANDER 93 BIG SPRINGS TERRACE NEWVILLE, PA 17241 Our File No. 8902 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. THOMAS W LANDER AND CAROLYN L LANDER _ CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 08-7334 Civil Term Dear MR LANDER: Enclosed please find a ten (10) day notice of default which is self- explanatory. This is being served upon you due to your failure to respond to Plaintiffs Complaint served upon you on 12/29/2008. Unless an answer to PlaintifFs Complaint is filed with the Court within ten (10) days from the date of this notice, a default judgment may be entered against you. If you would like to discuss a resolution to this matter, please call our office at 908-237-4571 and ask for Kim Crosby. Thank you for your prompt attention to this matter. MAURICE & NEEDLEMAN, P.C. C Wed Esq. CT/jm Enc New lorsey "ke Mawke & Neelemon, P.C. sate 2007 5 Walter E form qrd. Flemift", KJ 00122 le1.9MI37ASSO fox 911.23WS) THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (215) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. THOMAS W LANDER AND CAROLYN L LANDER CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO.08-7334 Civil Term IMPORTANT NOTICE TO: THOMAS W LANDER DATE: February 11, 2009 93 BIG SPRINGS TERRACE NEWVILLE, PA 17241 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 YO_ UR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA'191A(K"Gd TO'OIt TEI PTIONE THE O FICIr SIT FORM Bh`W it-."MS 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 P.C. BY CHARLENE A. TAYLOR, ESQ Attorney for Plaintiff 062S 191 Allal I?r?LL W v O L tV Z > QJ QCOJ s ?0 =cr)W = s F- w Z v a o WT W Zw WUa wzQ zzy Wa-a -Zo >O= wa Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 AUG-07-2008 13:46:37 Last Name First/Middle Begin Date Active Duty Status Service/Agency LANDER THOMAS 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. A 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: http:/,'www.defentielink.mil/_faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BHEPQKUQTSO hiVs://www.dmdc.os(Lmil/scra/t)w"cra.iDrc Select 8/712008 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 AUG-07-2008 13:49:22 'C. Last Name First/Middle Begin Date Active Duty Status Service/Agency LANDER CAROLYN 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. 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://www.defenselink.mil/faq/pis/PC09SLDR.littii] WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BGQQYXPCONK hqs://www.dmdc.osd.mil/scra/owa/scra.prc Select w 8/7/2008 ;, THE jp?? V THE i7 o-. s 1M2? 2009 APR 14. AM 9. 4 3 CUr? ? ;-1-1 UNITY P C, ???? tsylqaa3??4 4CO, P?O';-Ud r 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 Iby-!!JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. THOMAS W LANDER AND CAROLYN L LANDER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 08-7334 Civil Term (X) Notice is hereby given that a judgment in the above-captioned after has been entered against you in the amount of $7972.42 on 4 .1 (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. 117 or wpm ENG 0 P • not Clerk by: If you have any questions regarding this matter, please contact the filing party: Name: Charlene A. Taylor, Esquire Address: Suite 935, One Penn Center at Suburban Station 1617 J.F.K. Boulevard Philadelphia, PA 19103 Telephone No.: 215-789-7161 (This Notice is given in accordance with Pa.R.C.P. §236) M.II Lloyd S. Markind, Esquire (ID #52507) Markind Law Group, P.C. 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: FT112616 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CIVIL Jr oFf THONOTA;,. HAY 16 PM 3: 55 CU5BERL/ OF CUMB,iqcou_tyriyi , PENNSYLVANIA abiNI5CCNN ACTION - LAW FORD MOTOR CREDIT COMPANY, a Delaware limited liability company Plaintiff(s) V. THOMAS W LANDER AND CAROLYN L LANDER Defendant(s) No. 08-7334 Civil T Term CIVIL ACTION PRAECIPE FOR SUBSTITUTION OF COUNSEL TO THE PROTHONOTARY: Kindly substitute Lloyd S. Markind, Esquire of the Markind Law Group, P.C., 102 Browning Lane, Building B, Ste 1, Cherry Hill, New Jersey 08003 as counsel for the Plaintiff in the above entitled matter. The undersigned hereby consents to this substitution. Lloyd S. arkind, Esquire (ID #52507) Superseding Attorneys Markind Law Group, P.C. 102 Browning Lane, Bldg B, Ste 1 Cherry Hill, NJ 08003 Dated: May 9, 2014 oann Needleman, Esquire* Withdrawing attorney Maurice & Needleman, P.C. 935 One Penn Center Philadelphia, PA 19103 ID#74276 Dated: May 9, 2014 * Signed with permission of Joann Needleman, Esq.