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HomeMy WebLinkAbout09-0608r 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 Attorneys for Plaintiff 1J) /89-/101 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. WILLIAM D CACESE 11 Apache Dr Shippensburg, Pa 17257 PAMELA A SWITALSKI 11 Apache Dr Shippensburg, Pa 17257 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. CA - DOB alVil tark NOTICE You have been sued in court. Ifyou 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 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 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 notificacion. 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. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O Sl NO TIENE EL DINERO SURCIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA)O PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 Y- MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Sharlene 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 (21.-)) /?39- / 161 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. WILLIAM D CACESE 11 Apache Dr Shippensburg, Pa 17257 PAMELA A SWITALSKI 11 Apache Dr Shippensburg, Pa 17257 CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 0 9 - G d 8' L,c? Defendant(s). 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, William D Cacese, is an individual who resides at 11 Apache Dr Shippensburg, Pa 17257. 3. Defendant, Pamela A Switalski, is an individual who resides at I1 Apache Dr 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. z r 5. On or about August 28, 2004, 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 $33117.20 at an annual percentage rate of 11.240%, in order to purchase a certain motor vehicle, 2004 Ford Taurus 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 $456.12 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 October 30, 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 $7200.00, however a balance of $6045.26 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 $418.86 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $6464.12. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $6464.12, 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, MAURItE &c NEtDJ,EMAN, P.C. CHWENE'A-TAYLOR, ESQUIRE Attorney for Plaintiff Date: January 29, 2009 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. i BY: R' ) CHA NE A. TAYLOR, ESQUIRE DATED: January 29, 2009 V6WYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT SEP 0 2 2006ATE 08/28/2001 elf (and Co-B r) Name and Address (including County and tip Code) W LLIAM D CACESE PAMELA A SWITALSKI CREDITOR (SNlar Name and Address) ( 50 y 11 APACHE OR 11 APACHE DR l l PARSONS INTERSTATE FORD LLC SHIPPENSBURG PA 17257 SHIPPENSBURG PA 17257 CUMBERLAND V 196 WALNUT BOTTOM RD q CUMBERLAND ? SHIPPENSBURG, PA 17257 OO ..+?..,. ouyw taro n:o•wryer, a why), mry auy the vehicle described below for soh or an credit The `Cash Price' shown below is the cash price of the vehicle. The 'TOW Sale Price' ehplyn below le are tasdt pdoe. By along this contract. You choose to buy en credit under the agreements on to front end back of this contract. Ek Persona ? Agdadturai O C.ommaiclel Trade.m_NLa/A N/A s?/e_s Year and Make Drees Allowance ITEMIZATION OF AMOUNT FINANCED 1 1. Cash Prim ............................. .........._............................._................ .... $- jlb(1) 2. Down Payment Third Party Rebate Assigned to Creditor ..................... . $ S750.00 Cash Down Payment ................ _.......... ..................................... $ N/A Trade-in N/A $ N/A $ N/A $ n.00 Yar wd New Gas All- Mann 0., Total Down Payment ................................................ .......... ...... ..... $ S7,n AA(2) 3. Unpaid Balance of Cash Price (1 minus 2)....... _..... ............... ..... $ ?g400.$613) 4. Amounts paid on your behalf (Seller may be retaining a portion of time amounts) To Insurance Companies for Credit Life Insurance (for term of contract) ..... _._ ............ III A $ % .. Credit Disability insurance (for term of contract) .............. . N a !Term -Months (Estimate)] $---NA To Public OIIlclais (f) for license ($-S_OO._), title g registration ($?2 .n M fees $ S rn (N) for Rtlng fees $ rn (lei) for taxes (not in Cash Price) $ -11.64.05 $1222rrS Te GA VISE for $X0..00 To for $ r/A To for $_ 0/A To for $ r/A Total._ .........................._......._._........................._......................_.. ... $ 1462.1: (4) 9. Amount Financed (3 thus 41 a ?Aoee .. ... I FEDERAL TRUTI44N-LENDING DISCLOSURES ANNUAL PERCENTAGE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price RATE The cost of your aerie as a yearly rate The dollar amount the credit will cost you The amount or credit provided to you or on your behalf The amount you will have paid when you have made ere scheduled The lout cost or your purchase on cram. incwkidiings your payments ??? of $ Payment Schedule Number of Amount of Each When Payments 0(Paymatds are due Your Paplatt w he" en $ 156.12 will be: 1 final $ /? A - _ (071 20l/ Prepayment If You Pay Off Yom debt eery, YOU Will na have 10 pay a penalty. Late Payment: You must pay a hit longs On ate portion Of each payment received more Ran 10 days late. The charge is 2 percent of the late amount or $50.00 whichever is less. Sscurfty Interest: You are giving a security interest in the vehicle being purchased. Contract Pleats am this contract for addNbrml mfonnsson on security Intereal, nonpayment default Rio right to regWre repayment of your data in till before the ac adtded dale, and pop""-* Perrly lf you do not mast you contract olMipaeorr, you cosy Isere the vMki art you '!!-der this corarect, as wee as both parts and goods put m err vefYda and haw n aaark,..,br,,.d w e.. ,,_,.... NON-MODIFICATION DiSCLO U E Any change l t a ea ccomad must be in writing and aP+ad oY Yco a Creditor. ? f l BUYER: j&BUYER- SIGNS YOU ACKNOWLEDGE THAT YOU HAVE READ A AGREE TO BE BOUND BY THE ARBITRATION PROVISION ON THE SID :REVERSE E OF THIS 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 a rev ewe a true r a pletely tiled in copy of contract and (ii) at the time of si ----- this contract, 8u r d Co-Bu er) rece v a true an Comp e y filled in co o this con CIL BUYER SIGNS aUYER By slgning below, the Seem accepts tilde contract. It no other Assfilip4ils nam a aplgnmernt attached to this cornnect, eaagna B C himip? PARSONS INTERST E T FC 17037-M M 03 04"i-e.face mw be awe) SEE BAER FOR AD6tT1ONAL AGREEMENTS vA (,/ YOU MAY OBTAIN VEHICLE INSURAN 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/A Premium Insured(s) Signature Credit ? Disability Insurer $ r/a Premium Insured Signature Other Optional Insurance Term N/A Insurer $ Premium na are Crean Life and Credit Gluon ly insurance are for the ham of the contract. The amount and ?Oavar to yr t= n In a notice or agraamrrrt YOU mot imsae the vehicle. it a chests Is shown below do Credaor will try to buy the coveragee Will be basefor d on the C the cash va of the vah Ike of the Ibdts of tMpWteyloss, . but W repro than e ? Compreterrlva ? s N/A Deductible collision ? Firer- Theft-Combined Addtionei Coverage ? Towing and Labor ? Term Months (Estimate) P,Wrihim$ NJA ADebt Cancellation Wetver Addendum (Oplfonal) 1 0 box Is checked you have purchased a debt anceNtlon waver. Purchase of Oft coveram is and cond and is not m ? ra? ? 9abon credit, The form walver am set font in the attached Addendum which Is Incorporated ins the contract. The porice for the debt cancsNabon waiver Is set font an on contract in the hembason Of Amount Financed Under Section 4. Program No. QUESTIONS? /PLEASE CALL US AT 1.800.727.7000 or Visit us at www.fordcredit.com 03-001 ORIGINAL (% ADOM)NAL AGR@III A pttl"?IN smd SMIMMy Naha- YOU "M male M pops lnU.R. bnda mm m dm Yw mty your dohliSIr*0wftWPM* TNNka ?= MoaMnol The aoW Nwlaa a1Mg?a rpbMU IgrM b?? tow" ftow OWN I you mina ytwr tlM odw Mld a" or In INt MMn N» aArduYd amanl Th• Citlkr M/ tppp yaw Paytfanl oft b M aatnfd and WV W CiNdaNxI* elm " MPUMnw C wa MbuMThe yapMpNaMdg14 nMa flumidr FMaaNSf Rift is to wood AnMUd 7MwMNis Nr who 4*00 Ae INOSW AmotaN Fbl/laad b totawdrq X. wshbla k dQ w vA nM haw a dyld b ntNioMaTo badract S, So"* Mwa h You on w• COON a 1 '? n aaaaNr taNral m: t. The vehkb and d party a ofw Ooade put on fe wlide; >L AA Yhpianoa plantar and ww" oo , grww#& you. TNe Mawaa paymen of all anowft you owt in tit wn"a). N da sm- pa ofw aprowwft in fie oorriraot p Q Un of VW" - WARRANTS& You mum Wr tore of Nit vt ,Mid yar rmMt hu*v k aed p M 1ftloYm ar altbnt d aka. 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YOUN•abbl 91rypNEenaamNNNdst"Mtyat or L YOU da red btp any shay pants info - , - N you of In dabrN, to Cnd or MW rraa??11wrf ou b at mea fa WPM Amowo to aaw=:Iy-"4; Pet of do FFlwaa h oats „'""•- ' 1IM ?wldw wider th Ww bund b 60 oh-the vflt b whad'fponsaad and hotel Som for you. N Ma wlUda k Wen bale. tows sand you a woe. TM nofa VA aM m o you may Mdsaw (buy baolt) fr vm N wB mo show ft araorar r*WW b ra mm You wry (dean M Vd" up b fr fm do Cfdbr sob f or spat to •d a. N YOU do rat re I Nw whbk. N wE be NW. TM Qs!dMOr wE tMa pr ntprwy Nom fe Wi. lip fp aNorred axpwMas. b Pay the &TAW dA owed on ode ooraacl hEONI N?IOr alb and aid ?* a hoop b ra w, vNrlola tow a pon by co ft by bkw, y loam aapawaaa LNNPW ka and Myal coat pamif d s by kw of dowad, ka Cr•dAa wN pay mu any nary NS (a mP1W You we pay any "w" 0 aw the ab b MM Cradift. N you do Rd pay fds ammaa whm to Cr•dkr aNM, w" CNAN may dwp you bar et at ft niphm bsw fb d you pay. Q Cawwar.Rapert•; YOU aUwadn Fad MOW Cm* Caro- pay to obbm =mmw afdt fpont Nom awwaw wpmom +ptndes (afdt bursae) for arty na•m and at any Mae In corn necum wm fib wet,". K, Gemrd: To sans Fad Mohr Cwdt Cordparw aba d wb aoeorrt ad 1-M727 7000. Ala, you fry mWo adbta ab olm nNoNd dwpn at www.NrdmdLomw, The bw of Pan. rAmtagonbfelta *a&Nfelawdonrratallowda00 sofemor" m INt as MA aL fw enn wY an not dowel will be waW. The seat d Ewe corrbad wN ad be ON& N a awpa for .141 meurarw b drown on f»`lort'tlrt Cfd•r wo or b by ft dralyd for ft Wm dw %. TM 61adNor Is not Aabk, fbu N he rarest do too. N lira aowraa•• sad Tame Ihm to snort shown for mews", fe Cedar may buy own for a ahollm an or to may ow you a" for to amowf dwm N he osmrd buy any kowann, ho w 0m yyeu asdt lorfw snows shown. The deck wB be made paymsrrb due. NOTICE - ANY HOLDER OF THIS CONSUMER CREorr CONTRACT N Busavy TO ALL CLAIMS AND DEFENSES WISCH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF OOOOB OR SERVICES OBTAINED PURBUANr HERETO on WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SMALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. UeeO Meer V Buyers N you of brylrq a and V*k* vow fit aonb%4 I I fquNlwo may fquye a gmW Brryea Oracle b be dep"wl on tee wtrdow a to Vddde. THE WORISA71ON YOU SEE ON THE WINDOW FORM FOR THIS VEHICLE B PART OF THE CONTRACT. INPONMATION ON THE WINDOW FORM OVERT ANY CONTRARY PROVISIONS M THE CONTRACT OF SALE. E L4%qapcSe? each You WIN haw to pay a bb dwoe on fe pollim of ch Ba Pewee d omb mme Mm ion days tan. The ftt Aoapim a a Nk p?wr don not amm your Oof&A or mom fW you am k6p ma'Mrp Io?Cro*w T Bdscm*&: tlrmb? eny ddarN nay like au slaps sa ? To 42 owe tle 8etsr b sd fe velddt deenarad m tlr front a drk coraraa b fr dryer m atilt. taah pertm wtro tgnt blow n ?Sewarnn to plow d fie a *s& rink metro fW N Nw Buyw Wk b Pay wry mm" the k owed an fit fe wok anMa tow awn k orai• a womnw weiw ply k whssa •IOrM Esch Pure, wM dwu peaty span fW he wB be kW br donaranefaMlm-m -WWonefr Buywmanfmabpaytowaurora. •NoaPw ba Adbstye life Ofdbr o b say of ft allow Gumum , or ntltse•e ? ? 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The applicable ndn (ft Tidal my 1a waBm? i ,? ,,,PAAA1. d t spo.777t 7a7f. a www.edr orp ft p weraws prau•aYr.rrtr,w.aR M 03/10;2008 08:32 AM 7ORD MOTOR CREDIT COMPANY lO BOX 6508 AESA, AZ 85216-6508 -800-732-2264 PAMELA A SW ITALSKI 11 APACHE OR SHIPPENSBURG. PA 17257 Automotive Fin Svs 8665885855 7/48 Oate d R !Nsion 016M e ca 03!07 ?- -?- -- Due at Contract S Burer WILLIAM D C2WW P LA A atfrMal(l DESCRIPTION OF PROPERTY ser 2004 FORD 0 Now 0 Used Vehicle Ident! H, i u . 1FAFP65S74A163876 Model TAURUS Y NOTICE OF OUR PLAN TO SELL PROPERTY alb baw your property described above because you' J, e promioss in ors agrwnsnL © PRNATE SALE; Ws willsell the property ktaecrlbed abae at rl PUBLIC SALE: We wr sail tie properly dwabW above d puWic groats ask somalme aaer If days horn the Dtle of Nolte sale to the highest Wolder on the dab below (or any soloumment shown above unless redeemed by you prior to such sob den). The sale wa be held as fdowe. Oats d eal? Titel d Mace dllaN You may tlland the ark and bring bidders If you ward. The money that we get from the sale (after paying our costs, including reasonable aftomey's fees and legal expenses if permitted by law4 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 h 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 pall due parer fits), Including our expenses. See Now To Got Your Property Back for an fiernization of amount ovAng. To loam 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 rant 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 w he 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: MANHEIMA PA HOW TO GET YOUR PROPERTY BACK To gal your qty back. pay us this smart by certified check or money ceder lsfarn the vahlele b sold. Unpaid Seknce Plus Coda: REPO FEES Plus Lab Ching" Law Finanw Cheraw Rebate Lass Insurance PrnMdurn Rebels TOTAL s ,zses.se = 41S.Ixl s 00 s 0.00 S 0.00 $ 0.00 $ 13054.26 (PUS expenses Incurred It default d tie tiro: of reposewalau ameeded 16 days and low rebate received :gar On data of auk rwtics.) Your property wont be sold Intl 15 drys Nbr the date cl this notice at the EARLIEST. Afar that you on dill gel l back any time bake n 8"W/ sold. a you do, well have no bather claim on it, But the ImW you wait, the more 0081116 (fndudeg 10P SIM) YOU MANY have to Ply. If you have any questions about 9%, pbeaa eel as. The property has been (or era be) rdlerad 10: - WIRWISMaw Under our #a w w.A wish your d sifflo lginai dherBor. SAN lee- 1, groat moor is to see the Properly and pay you any mnry left over. N you owe moray after tie tall, you we pay l to the dealeA Inal adder. © PERSONAL PROPERTY: Any persons! properly round in the vehicle may be reclabned by you within the net e0 days or. In a0wrdence with state law, by contactlng this of les. Thereafter, the personal property shed be I , ", of accordingly. Creditor has anond to Its qualRad illarmadery (QI Exchange, LLC) the right (IPA not its obligations) with real Ate the oak d each vehicle listed above. PAYMENTS: All Paymsnk to us mud be by certified check or Money order. MILEAGE DISCLOSURE: If you ere ewer: l h l themileage rsfkered an the veNcds odometer is not accurate for any reason, please cadsot us eo that we can accurately report the V*"'a mfeW. INSURANCE RIGHTS: If you dorm want to gel your property buck eel the kmusos conpny or ft dedlerlaigNd Creditor to rake sure that any ksurwca No been Canceled. You have a TIMM to ad and! for all prerMum refunds, FFNA 11ea6J7 ,tan 02 ft%Ma eaeerw may NOT be uwd. PmOednU.BA. SI6aLYla7__ M CUSTOMERICUSTOMER FILE 03/10/2008 08:32 AM ORD MOTOR CREDIT COMPANY O BOX 6508 IESA, AZ 852I6-6508 400-732-2264 WILLIAM D CACESE 11 APACHE OR SHIPPENSBURG,PA 17257 Automotive Fin Svs 8655895855 6/48 Date of R 03!OSrOs •0 01 03J07l08 - q -0$12&004 480830000000376&0343 CobLbw PAMELA A SWITA.SXI DE SCRIPTION OF PROPERTY Year 2t)4 FORD sales 0 Now D used Vehicle kmrdwAoum Number: 1FAFP55S74A163876 Model TAURUS NOTICE OF OUR PLAN TO SELL PROPERTY we have your property described above because you broke pramrdas in our agreamsn6 Vj r iw^TE SALE: we wall ale the property daalbed above d Whata We aauratlma star U days from the Dent of Natter shown above unless redeemed by you prior to such sate. PUBLIC SALE: we vdl set We property described above at pubic mob to to hWud bidder on the dab below (a ay adj unrlremrt dab). The sale vrB be held a follows: Data of sale hies at eats Mere of sea You mW Mteed to sale and bring bidders If you wad. The money that we get from the sate (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by paw) 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 properly 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. ti 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 Cap 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 intenut in the property described above or who owe money under your agreement: 1) The buyer and any cobuyer named above; 2) Any dealedoriginal creditor named below; 3) If there are other people, they are named on an atlachment sent with this notice. The property is presently stored at MANHEIMA PA NOW TO GET YOUR PROPERTY BACK To 0M your Property beck, pry us this wnount by Mated eMck or money order bobre the vehkde a add. Uhpeid Babnce Plut Coats: - REPO FEES Plus Late Charities Lora Fklerca Cheap Rebels Las kaumce Pmmkm Rebate TOTAL S _ 12040,09 $ 418.OD s o.oo s 0.00 s 50.57 a o.oo 0.00 $ t3084.28 (Plus sapaase incurred if debut at are tine of repossession eacmded if drysandbarebetsmeshed alterMedebofoftnga, .) aEARL ISIE ?tMso unit if days WW to data of this notice at sohwly soy. Yw can eta gd t trek any ten before irs If you do, well haw no fuaar calm on it. Bud to tongs you wit, on more costs (Moknifna reWed) I- may h- to pay. If you !sew any quaellens about tab, ptsaa cal us. V r fie prepeny run been (or WE be) returned to: a dseler/origirlel oredlar is eel the property and pay you my monry MR over. R you owe mpfley ater tea sale, your will ? toiJWtU?dalal" that cna;tkor PERSONAL PROPERTY: Any peraond preperty found In to whlca may be re dai bed by you whin the nod W days or, in accordance wilh atele low, by ounta wg this oMoe. TN-%r, to personal property Mat be disposed of woon*,*. n Creditor has sated to Is qualified kdernadbry (pre Exchange, LLC) lib rW b (but not hte oblgslbns) wMh raapaot to to sob of each vahyge listed above PAYMENTS: M peymenis to w m* be by cer lie clock or mart', ntfer, MILEAGE DISCLOSURE: t you as aware thel to n+Msge relbeted on Its vehicle'. odorrAW le not accurate for any nelson, plan ooraad us m that we om wcww* report the vehicle's rnlleaga. INSURANCE RIGHTS: if you den l werd to 0 your property back wit the IrwAance compat a the deltutripisap mKft to rralre aura that any kwunwc. has bow conceited. You hsva a rVe to gat tawk for al premium raNnds. FFINA 119110437 Jan 02 Prams edeaa may rear be load PriWW in U S.A SaaN ny/Krtra CUSTOMERICUSTOMER FILE 03/11/2008 09:41 AM Automotive Fin Svs n\9 V Ln M Iti U € ru ?l.l rn Vim moo. ' I rl- `odred Fos o(. 0 DO (? ? Paark Han O (Erwloraarrmt r ti © m Tdal POOkW a F'asa s 0 . A ° ........'r. - 4Cht M awPo& ...? r ._.. - -- .. ... ?.__ ? - en5 r----A14 - 77..-- ffc ni r %- C3 ru °m V ( 6l POAr W s f rq COOMP" (4, CG o Rapa1, ii?ft*4w,pt Faa (Eaaowwaad " POSWwk Hare ? o l M TOW Palfepa a Fe" $ U ?O t r%- C3 lb ese- 8665895855 28/42 ,06/1`9/2008 06:40 AM Automotive Fin Svs 8665895855 38/49 FORD MOTOR CREDIT COMPANY PO BOX 6508 MESA, AZ 85216-6508 1-800-732-2264 DATE: 06/18/08 CACESE,WILLIAM D 11 APACHE OR SHIPPENSBURG,PA 17257 Account Numb 48063-37860343 The following pr d Year Make Model 2004 FORD TAURUS SWITALSKI, PAMELA A ATEMENT OF SALE Gross balance owing on your contract Deduct: Finance Charge Rebate Balance owing prior to sale Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Vehicle Identification Number: 1FAFP55S74A163876 (1) $ 12639.26 (2) $ 0.00 (4) $ 7200.00 (6) $ 606.00 (7) $ 0.00 (3) $ 12639.26 (5) $ 5439.26 Other: (6) S 0.00 Deficiency" (9) $ , 6045.26 Surplus" (10) $ 0.00 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: Mall deficiency payment to: FORD MOTOR CREDIT COMPANY FORD MOTOR CREDIT COMPANY PO BOX 6508 PO BOX 55000 MESA, AZ 85216-6508 DEPT 194101 1-800-732-2264 DETROIT, MI 48255-1941 FFMA11 M 0104 PIYNas K twa may NOT be used. 06/19/2008 06:40 AM FORD MOTOR CREDIT COMPANY PO BOX 6508 MESA, AZ 85216-6508 1-800-732-2264 DATE: 06/18/08 SWITALSKI,PAMELA A 11 APACHE DR SHIPPENSBURG ,PA 17257 bW. 48063-37660343 Account Num The following pro heea said Year Make Model 2004 FORD TAURUS Gross balance owing on your contract Deduct: Finance Charge Rebate Automotive Fin Svs 8565895855 37/49 CACESE,WILLIAM D ENT OF SALE Vehicle Identification Number: 1FAFP55S74A163876 (2) $ 0.00 Balance owing prior to sale Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (4) $ 7200.00 (6) $ 606.00 (7) $ 0.00 8 (1) $ 12639.26 (3) $ 12639.26 (5) $ 5439.26 Other: ( ) $ 0.00 Deficiency** (9) $ 6045.26 Surplus* (10) $ 0.00 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: Matt deft lency payment to. FORD MOTOR CREDIT COMPANY FORD MOTOR CREDIT COMPANY PO BOX 6508 PO BOX 55000 MESA, AZ 65216-6508 DEPT 194101 1800-732-2264 DETROIT, MI 48255-1941 FFNA11M 01A4 Piadom aditions may NOT be uw& oe D ? ? a U) D C7 rn .Ly ? - c? s r , SHERIFF'S RETURN - REGULAR CASE NO: 2009-00608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS CACESE WILLIAM D ET AL GERALD N WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CACESE WILLIAM D the DEFENDANT at 11 APACHE DR , at 0018:12 HOURS, on the 9th day of February-, 2009 SHIPPENSBURG, PA 17257 by handing to RONALD SWITALSKI 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 So Answers: 18.00 17.10 .00 10.00 R. Thomas Kline .00 45.10 02/11/2009 MAURICE & NEEDLEMAN By: day Deputy Sh iff A.D. LLJ < ` LLJ { ;a LL. Ta C, 4 ta ? e SHERIFF'S RETURN - REGULAR CASE NO: 2009-00608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS CACESE WILLIAM D ET AL GERALD N WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SWITALSKI PAMELA A the DEFENDANT at 11 APACHE DR at 0018:12 HOURS, on the 9th day of February-, 2009 SHIPPENSBURG, PA 17257 RONALD SWITALSKI by handing to BROTHER OF DEFENDANT 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 02/11/2009 MAURICE & NEEDLEMAN By: Depu y She ff of A. D. C ; C\j : s t ~ rt L ° U t 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 (ll?) /ISy-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WILLIAM D CACESE AND PAMELA A SWITALSKI Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-608 Civil 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, WILLIAM D CACESE and PAMELA A SWITALSKI in the amount as follows: Principal Amount $ 6045.26 Interest to Date $ 549.17 TOTAL $ 6594-.433 /? MAURICE & 1VAAEMAN, P.C. BY: CHARAgXE Al. TAYLOR, ESQ. Attorney for Plaintiff Date: April 9, 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) /2Sy-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WILLIAM D CACESE AND PAMELA A SWITALSKI Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-608 Civil CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 3/18/09 to Defendants, WILLIAM D CACESE and PAMELA A SWITALSKI, 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 3/18/09, a copy of the mailing to the Defendant and affidavits of service are all attached hereto. MA BY: VIAN, P.C. TAYLOR, ESQ. Attorney for Plaintiff Date: April 9, 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. WILLIAM D CACESE AND PAMELA A SWITALSKI Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-608 Civil AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that she is an attorney at law and that on 3/18/09 she mailed a written Notice of Intention to File the Praecipe to Defendants, WILLIAM D CACESE and PAMELA A SWITALSKI, at 11 APACHE DR, SHIPPENSBURG, PA 17257 by regular mail. MAURICE,&J- y f DI/EMAN, P.C. BY: CHI,?/ENEI? TAYLOR, ESQ. Attorney for Plaintiff SWORN TO AND SUBSCRIBED before me this 13 day of ?' 2009. Notary Public A OM MAND, flc?r F P dt PMIa ?_ 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) 72Sy-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. WILLIAM D CACESE AND PAMELA A SWITALSKI Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-608 Civil 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: WILLIAM D CACESE, 11 APACHE DR, SHIPPENSBURG, PA 17257 PAMELA A SWITALSKI 11 APACHE DR, SHIPPENSBURG, PA 17257 MAURICE BY: Attorney for LEMAN, P.C. TAYLOR, ESQ. Date: April 9, 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 (215) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WILLIAM D CACESE AND PAMELA A SWITALSKI Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-608 Civil AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that she represents the Plaintiff in the above entitled case and that Defendants, WILLIAM D CACESE and PAMELA A SWITALSKI, are over 18 years of age; the occupations of Defendants are unknown and to the best of Plaintiffs knowledge, information and belief, Defendant 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: , P.C. I OR, ESQ. SWORN TO AND SUBSCRIBED before me this 13 day of , 2007. 000 XUrARMLSM Notary Public,ii AM" PIb1o :y.,, . ? - .. March 18, 2009 Attorneys m ur Our File No. 9262 Suite 935, One Peen (enhr 1617 John F. Kennedy BM. Philadelphia, PA 1910 tel.215AS.1133 fax 215.563.098 WILLIAM D CACESE WW W.msderpc.ome 11 APACHE DR SHIPPENSBURG, PA 17257 Donald S.Mauim Member NJ Br Board CROW RE: FORD MOTOR CREDIT COMPANY A DELAWARE , Creditors' Bights Low LIMITED LIABILITY COMPANY v. WILLIAM D CACESE American bard of CerNBcatiee AND PAMELA A SWITALSKI Joaee Neesllemm CUMBERLAND COUNTY COURT OF COMMON PLEAS , Member PA i 11) Irr CASE NO. 09-608 Civil Thomas K. DemiK* Member N), NY A PA Br Charlene A. TV* Member PA Br Dear Mr CACESE: 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 02/09/2009. 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, NEEDLEMAN, P.C. 7 emne r, Esq . CT/jm Enc THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A NerJuseynce DEBT, AND ANY INFORMATION OBTAINED WILL BE USED ' °a6NeadieS ite 200i FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR 5 Woher E. Fenn" Remington, NJ ON22 tel. 900.237.1550 fax 900.237.1551 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 131 /759-/133 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WILLIAM D CACESE AND PAMELA A SWITALSKI CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-608 Civil IMPORTANT NOTICE TO: WILLIAM D CACESE DATE: March 18, 2009 11 APACHE DR 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 , P.C. BY CIE A. TAYLOR, ESQ for Plaintiff o? old o r ? r N l+? r i W r ? r r ? 1 U3 (J) r? ?vW 4 2 0 D. ?? Z ? WU 4 lu =4" 0.- Ww W 070 cmq ATlorneys at In Suite 935, CIAO Penn Center 1617 John F. Kmn* aW Philode (phis, PA 19123 tell. 215.665.1133 fa,015.5632970 WW%VMnlar'r.Caa Donald S. boxim Member U Nor Board (Or" Creditors Nights Low American Noard of Cerli"Oa Joann Needinna Member PA d NJ Nor Thomas N. Domiaulk Member NJ, NY E PA No Charlene A. To*r Member PA Nor New Jersey Office Maurice i Needleman, P.C. S06 2067 5 Walter E. forma tied. Ftead", NJ OU22 te1.908137.4550 fax 908137ASS1 e March 18, 2009 PAMELA A SWITALSKI 11 APACHE DR SHIPPENSBURG, PA 17257 Our File No. 9262 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. WILLIAM D CACESE AND PAMELA A SWITALSKI CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 09-608 Civil Dear Ms SWITALSKI: 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 02/09/2009. 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, EEDLEMAN, P.C. MAUNCEE CLenR?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 /tfy=/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WILLIAM D CACESE AND PAMELA A SWTTALSKI Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-608 Civil IMPORTANT NOTICE TO: PAMELA A SWITALSIU DATE: March 18, 2009 11 APACHE DR 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 MAURI , P.C. BY ED A TAYLOR, ESQ Attorney for Plaintiff WWSA C1 r V-j m? r+ ? r r N ? r N z m. cn '? U Z d W or °' CL ? ty a W i Lu. d 000. Ul 7. ZWa 06 a. W ag Ito SHERIFF'S RETURN - REGULAR CASE NO: 2009-00608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS CACESE WILLIAM D ET AL GERALD N WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, Says, the within COMPLAINT & NOTICE was served upon CACESE WILLIAM D the DEFENDANT , at 0018:12 HOURS, on the 9th day of February., 2009 at 11 APACHE DR SHIPPENSBURG, PA 17257 by handing to RONALD SWITALSKI 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: So Answers: Docketing 18.00 .-Service 17.10 Affidavit .00 40101'.OQr? Surcharge 10.00 R. Thomas Kline .00 45.10 02/11/2009 MAURICE & NEEDLEMAN Sworn and Subscibed to By: ' 24 -0-t - I A JA= j?_ before me this day Deputy Sh iff of , A.D. 4?0 qjug- ........................... SHERIFF'S RETURN - REGULAR CASE NO: 2009-00608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS CACESE WILLIAM D ET AL GERALD N WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE SWITALSKI PAMELA A was served upon the DEFENDANT at 0018:12 HOURS, on the 9th day of February 2009 at 11 APACHE DR SHIPPENSBURG, PA 17257 by handing to RONALD SWITALSKI BROTHER OF DEFENDANT 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: So Answers: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 R. ThomasKline .00 16.00 02/11/2009 MAURICE & NEEDLEMAN Sworn and Subscibed to By: before me this day Deputy She f of A.D. qqul, Request for Military Status Department of Defense Manpower Data Center ID Military Status Report Pursuant to the Servicemembers Civil Relief Act Pagel of 2 OCT-01-2008 08:07:41 Last Name First/Middle Begin Date Active Duty Status Service/Agency CACESE WILLIAM 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. AAY IM . A?*V_ 4WJ7- * 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.defenselink.mil/faq./pis/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 10/1/2008 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: WCMIEAGSID https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/l/2008 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Pagel of 2 OCT-01-2008 08:09:33 ' Last Name First/Middle Begin Date Active Duty Status Service/Agency SWITALSKI PAMELA 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 A LA.J - , 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.defenselink.mil/faq./Pis/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 10/1/2008 , 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: VNNKQOZXJO https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/l/2008 OF THE P 7rj`' j/ dy hpV ? i 2CB Af- A 22 i IA Y, Lt 4pl+.00 PO ATrt`? Z+ aaa I aA 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 15) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. WILLIAM D CACESE AND PAMELA A SWITALSKI Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-608 Civil (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $6594.43 on 120 (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. 21, on ary/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) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY : No. 09-608 Civil Plaintiff vs. WILLIAM D CACESE and PAMELA A :CIVIL ACTION M C— SWITALSKI 2.-;o r-- - ! Defendant I> CA PRAECIPE FOR SUBSTITUTION OF COUNSEL C''^ TO THE PROTHONOTARY: Kindly substitute Lloyd S. Markind, Esquire of the law offices of Sklar—Markind, 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. 00,v'V, ltiA, � , Lloyd S. Mark 6d, Esquire (ID # 52507) Joann Needleman, Esquire* Amy F. Doyle, Esquire (ID #87062) Withdrawing attorney Superseding Attorney Maurice &Needleman, P.C. Sklar—Markind 935 One Penn Center 102 Browning Lane, Bldg B, Ste 1 Philadelphia, PA 19103 Cherry Hill,NJ 08003 ID#74276 Dated: July 23, 2013 Dated: July 23, 2013 * Signed with permission of Joann Needleman, Esq. FILE NO.: FT112816