HomeMy WebLinkAbout09-4959ARBITRATION 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
Defendant(s).
/2SJ-/IJJ
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
MICHAEL J FORD
52 C Erford Rd
Camp Hill, Pa 17011
CIVIL ACTION COMPLAINT
AVISO
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.
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 09-44-54 0'-(&rM
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo at partir de la fecha de ha demanda y la
notificacion. Hace falta asentar una comparencia escrita o en
persona o can on abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de so 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 pars 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
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
(215) 789-7155
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
MICHAEL J FORD
52 C Erford Rd
Camp Hill, Pa 17011
Defendant(s).
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 09. 8459 CU?? 7Z-
CIVIL ACTION COMPLAINT
1. Plaintiff, Ford Motor Credit Company, is a Corporation with its place of business
at P.O. Box 6508 Mesa, Az 85216-6508.
2. Defendant, Michael J Ford, is an individual who resides at 52 C Erford Rd Camp
Hill, Pa 17011.
3. At all times relevant, the Plaintiff was in the business of loaning money on motor
vehicle installment sales contracts, including but not limited to the note signed by Defendant(s),
hereinafter more fully described.
4. On or about July 28, 2005, the Defendant(s) entered into a written Motor Vehicle
Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of
obtaining financing in the amount of $59576.94 at an annual percentage rate of 14.290%, in
order to purchase a certain motor vehicle, 2008 Ford Explorer more particularly described in the
Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and
marked as Exhibit A.
5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in
the amount of $881.31 for a period of 60 months until the loan was paid in full all as is more
fully set forth in the Contract.
6. Defendant(s) made monthly payments until August 12, 2008, but has failed to
make any further payments thereafter, and are therefore in default of the Contract.
7. As a result of the default by Defendant(s), and pursuant to the terms of the
Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to
the Defendant(s) giving the Defendant(s) the opportunity to redeem the Vehicle as well as notice
of the sale date. A copy of the notice of repossession and notice of sale date are attached and
marked as Exhibit B.
8. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at
auction with a credit given to the Defendant in the amount of $7800.00, however a balance of
$17776.35 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.
9. Pursuant to the terms of the contract, Defendant is required to pay all amounts due
and owing, including any balance that may remain after the sale of the vehicle, and the
Defendant failed to do so, thereby in default of the Contract.
10. In addition to the foregoing, there is interest due and owing on the deficiency
balance which at this time amounts to $1412.79 and which will continue to accrue.
11. The total amount due and owing at the time of the filing of this complaint is
$19189.14.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $19189.14, well as any additional interest and costs that may accrue and such
other and further relief as this Court may deem equitable and just.
MAURIC$ &114EFPLEMAN, P.C.
Attorney
R, ESQUIRE
Date: July 16, 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.
BY:
DATED: July 16, 2009
PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT GUNTNAGI UAIC 07/28/2005
Buyer and Co-Buyer) Name and Address (including County and Zip Code) CREDITOR (Seller Name and Address)
0 BBCORAAEH L FORD 10'2'4 D ppcc
M1bNLEE ANNOCOURT AUG 1 2005 TLINCSLNINA1f EAST r /? J? p
ENOLA CUMBERLAND PA 17025 CHAMBERSBUR6 PA 17201 A.3?n 6 It 1
Veu. the Buyer tarot CoA~. If amyl. may low the vehicle daaalbad below lee nth or on credit . The 'Cub Pia' sham b l le the cash aloe of the vahioe. The
-Total Sale Pros' Mown below b the credit prim By starting tae contract, you choose to buy ea aedh under as agreaheants on the nom and lack of this contract.
2005 I I ?xRersorel ? Agricultural
NEW FORD TRUCK EXPLORER I FM7117ACAFIIA9SAna ? commercial
Tredein 1999 OLDSMOBILE a 10390.00= 10390.00
year and bloke Gross Allowance Amount Owing
ITEMIZATION OF AMOUNT FINANCED
1. Cash Price ..... _..... .............................. -..... ..................... _.................. $ 418_46.25(1)
2. Doren Payment
Third Party Rebate Assigned to Creditor ........... __ ............ . $ N/A
Cash In $ 6697.34
f'XT L'DSRV rU3sts:11o.........3b §o:ao
o
oo
Trade-in
zz- $
.
year cod Nelo nwo AM- Awe OWM
Total Down Payment .... ._ ..................................... .... ........ ......... $ 6697.34(2)
3. Unpaid Balance of Cash Price (1 minus 2) .......................... ..... _._ $ 35148.91(3)
4. Amounts paid on your behalf (Seiler may be retaining a portion of these amounts)
To insurance Companies for
$ N /A
Credit Life Insurance (for term of contract) ........... .......
MIA
Crn/Kedit Dleability Insurance (for term ql contract).......... _ $ N/A
[Term // nths (Estimate))
To Public Officials (i)?or Ii09nse ($ /A ), title ($ 22.50 ), d -
58. 50.
registration ($ b U?fgCS
(if) for filing fees $ J ti 1906.72
(iri)'fd A(Qot in Cash Pricel_j,
A
$ 1970.22
253
T.
for
--
-
$
.
MIA
Wfx
TO
for
-
- 1
*
CREST
FURU. INCfa DOC EE $ 55.00
To nn
$ 55
To N/A for N/A $ N /A
Total .._....... _._................ ...................... _._....... _._ ........................... $ 227A 29.(4)
FEDERAL TRUTH-IN-LENDING DISCLOSURES
ANNUAL FINANCE Amount Total of Total Safe
PERCENTAGE CHARGE Financed Payments Price
RATE The doper amount The amount of The amount The total cost
The cost of your the credit will cretin provided to you will have of your purchase on
Yco you or on your paid when you credit,
credit as a yearly rate cost you behalf have., ade as including your
scheduled down
payments of $ a m
14.29 % s 15451.47 is 37427.13 $ $ 5957.x, fad
Payment Schedule Number of Amoutt of Each When Payments
ISIXpa s Payment are due
Your payment schedule 39 $ 1181 .31 (monthly starling)
WWI be: I final $ 88i.31 09/11 /,-nn.,,
Prepayment: If you pay off your debt early, you will not have to pay a penalty.
Late Payment: You rrkat pay a late charge on the portion of each payment received more
then 10 days We. The charge Is 2 percent of the late amount or $50.00 whichever is less.
Security Interest: You are giving a security interest in the vehicle being purchased.
Contract: Please see this contract for additional Infomation on security Interest, nonpayment
,=r= lo require repayment of your deft in full before the scheduled date, arced
alty
h you do not meet your lore. you may loss the vehicle the you are
W WhOk?a 97 sontact.
as well as both parts and put tie vehicle and money or goods reoely for the
DIFICATION DISCLOSURE
Achy change in wdtlng hnrW signed by you and the b
BUYER: Ct}BUYER:
SIGNS 31ON3
YOU AC LE AT YOU HAVE READ AND AGR TO BE BOUND
BY THE RBtTRATION PROVISION ON THE REVERSE SIDE 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 (i) before si rain this
contract, Buyer and Co-Buyer) received an reviews a true
and completely filled in copy of this contract and (ii) at the
Co- er) paq-we-li-id
t1 slanind-tbis contract, BuyT'*?'7?/
a rue ps C X
BUYER '(CO R NS
By algnleg bit Milhor accepts this
epfa? ZDls.contreoC tM 9eU?r sea) any.
FC VMS .col m eiavim,r eeeb,w vey W ,ava.l SEE BACK FOR ADDITIONAL AGREEMENTS
PA
YOU MAY OBTAIN VEHICLE INSURAN
FROM A PERSON OF YOUR CHOICE.
YOU ARE NOT REQUIRED TO OR
CREDIT LIFE, CREDIT DISABILITY
OTHER OPTIONAL INSURANCE.
CONTRACT WILL NOT INCLUDE T
UNLESS YOU SIGN AND AGREE TO
THE PREMIUM.
THIS CONTRACT DOES NOT INCL
LIABILITY INSURANCE COVERAGE
BODILY INJURY AND PROPI
DAMAGE CAUSED TO OTHERS.
? Credit Life N /A
Insurer
$ N/A
Premium Insureds)
Signature
Credit
? Disability uie
Insurer
$ N/A _
Premium Insured
Signature
i
? NIAp?
Other Optional Insurance TW
Credit Life and Credit Disability insurance are
for the farm of the contract The amount anti,
btrya/aaaa ere athOWm In a notice or agreement
Bin fa trou 1?Y•
You must Insure the vehicle. If a charge k
shown below, the Creditor will try to buy the
coverages term Col will based on thee ash value of
the at time of loss, but not more than
the limits at the policy.
? Comprehensive ? $ DaduCtbla
Collision ,
? Fire- Then-Canbaard Additional Coverage
? Towing and Labor
? Term N/A _ Monthe(Estimate)
Premium $ MIA
.
? Debt Cancellation Waiver Addendum (optional)
H this box is cledred you have purchased a data
arm tion waiver. Purdue of tic coverage ro
opliiuul and is not raqulnrd to obtain credit. The terms
and andaiore of the debt cancellation waive are set
kith m the attached Addendum which Is momporated
Into ties contract. The price for the debt cancellation
walwr is set forth on this contract in the henixatch
of Amesa Fnarxed under SocW 4.
Program No. -
QUESTIONS?
PLEASE CALL US AT 1-800-727-7000
or
Visit us at unarw.fordcredh.com
034101
ORIGINAL
- - ----------
' 1pL' ?ayOnBNRb SRO S..yy yNO. You a:I* mds all
In UA knLt When we w You OIOf d vq 0:b MNaO I Ibl. lira IS a shipM Y?MP"COnI X01
7110 @dW I I aM/ya Pit pPM,b 1? ,ur
dtltdesad Frew i>fwf ' ou main fW" W04, n11 1Yn VISI
NM scheduled doW or bM Ow fn aaibdOSd antosd. The
pC/rrwttdaall1.g nwill e" Yo r paI ' 1>?St b En aannd and urc
CrSdb? save fe FlbrMa;p q by pN1Or? Mn T Annuli
Pwmftpe Rub to fro unpaid ArM 1°I:wMNIr wB a"
San to wlpdd A tiou d FIMrtoW IS ov*WNBtp. X, ySldob b
=91011 d. you we RN hme a " b RdnMrla M boRlnot
M CredNw spew.
B SSeaAq b*m* You fore Me Cmdbr a eacury IOwaa b:
1. The vel" and M prM or des pales put on fe vdkkn
L Af nowy or goads realwd br fie undoes; and
L AN kmarrw prrrdrno and SSrvbe coreaob fnarrosd fbi you
Tt4 aeal/es psyrnrd of all smoums you owe In gds aonlNpl h
sho swim your char aprsrrwrM In fre oomraN P
C, the of Yahlob • WARRANTIE& You must We ban of
to vsl*M and obey sit lews In i 111. You a" not well or mil
In vat , and you MA keep I We Romthe clause of b"M.
You will not use or permit fe use a the whbb culefda'01,111c,
W" SINK tow kw up to 30 days h CrMda a me",
No t o glor wrNan banner a d* CM1Nw 11W va-P, Is
of a typo welully used for prserW us s and ria Creditor, or
1* VOODWS mamdaearre?, awtrres s WARM warrrdy r
IN "In cararaat aawerbp ft v Adds NM* gg deya from the
dub of Dlb oc aaet, yea ON 1 0 Neldnupwoa --we of
ft waft OtieW widwsl end agree 1Mt1
ere no such Inydbd vranraMlsa
0. Insurance: You read beam you" out IM Credta against
toes or danege b do vehlde. The Cmdibr mud app ovY the
tips sod arnKW of' u -' as. N the Creditor obblrra a Uterine on
Irs"M or servos dorrmob, ft Cndbr WE Kftv tors
heard Mom what you owe. VnwNer or not OM vNra. Is
Inexpecl, you mat pay for N E N In bet, demaOSd, or
destroyed.
N a NrsrDa for wMcie Muana Is dawn M
Creditor w? Iy b py IM drdaed for me farm alawe.
The Cledibr b not Mlrs, rio ,fy M cwra do aw M maw
aoverapsa mN ntors for fro amour shown for kerrrroa, to
Creditor may buy fern kr • whetter tone w M may the you
ersdl ter fe amount atrwwn. N M Oawrd buy fey Nwraancs, M
wN eve Yeu aedll tsar for arlroar slawm. The aedt all be made
b for lad payrrerds des.
a You will
o doe of each p aymirr nrdm ean &ann bn o days late. 'Te
dugs Is show. on On front Acceptance of a lab dew
not acme your def" or roan fat you can?matdrg
Py fait, we due. The Creditor may Inks M apps act
any debuL
F. DSTMk You Will M In ddMd It
1. You do not train a pigeraM w hm N b dui! or :41P.
2. You ! ve lobe air nibSAdp krom:pll?P On YlNF.?ld
Sp?la?on fds ocrtb?ok or :..
a Maur wlYab N any bail, abb. ,I
&A" W4 M not p wrq* and
4. You M • pelMon w are M Nbd apalrM ytaR w
a You m nail km anti ov w pal I b fdS aarsaL
N you we M de* 94 SU Cm dW nay reragqaiainn you
FI b pay M ones
e» wpaid Anbuf fe earned Ind, upBld Pon of Eb
Mnw Clrgawd ill QSKW angada dime undw ft aowacf
No qv mpossesa OMSdp".fe vehlOa,?o. Meim also
1SIM'6oo0S bund in al'ea•ff vNdss whrl'mposeeww and
hold Tram foryou.
N tie v "-'- is bhen bsak, he will well you a noNoa. The notion
trE say frai you myr redara ptuy baaq for Vd*N . N will do
thew fe enema nSatbd b redaMt You may nears M
v*Me up Is fe ems ft CmAor ads I or agmea to sell L N
you de nr redarn Oe vNrde, N WN be am.
TM Q *dir 1w uw Ihft "* Mall IM Sail, bSS fe slowed
Eaeprew, b psy M_srnasR @1111 owed on ft ocn. -
hold S for an* and sell it v% as pamdbd by law, stowed
erpenw. tMWW bM and Ispd ooala pemAm d by law ant
slowed, too. The Cr dbr will par you any mrrey We N
surow). You WE Pay any rnarety sal sang ow No sob to to
Creditor. N You Oo rra pay tlds owint when fe Cm0w sake,
to Creditor may charge you bderaN N for W" Wod rob
art you pay.
O. Cosaa w R"wta: You aupwdm Fad Motor COW Coon
perry b Wish Mourner well mpafs warn conrmne
agencies (credit bursars) for any reason and N any time oorr
nation with fry oadmd:
M.' Oer rah To comes Fad Motor Cmdl Cordpany about 16
aocoarr, ad 14 7877WO, Alto. you may rrWM a 111 rM
other esbobd deranges a wwwJxdaedLmm. The tow of Phan
sylwnb apples b fns camerae. N ft bar does not abw all N the
agmemeres ones aria 9ElwE 0 be Sooind.na allowed will be
vokL The me =*M
NOTICE • ANY MOLDER OF THIS CONBUMM CREDIT
CONTRACT IS SUBJECT TO ALL CLAIMS AND
DEFENSES WHICH THE DEBTOR COULD ASSERT
AGAINST THE SELLER OF 00008 OR SERVICES
OBTAINED PURSUANT HERETO OR WITH THE
PROCEEDS HEREOF. RECOVERY HEREUNDER BY
THE DEBTOR SHALL NOT EXCEED AMOUNT'S PAID BY
THE DEBTOR HEREUNDER.
Usid Moller V =. 8, "you are buying a used
vends with ft corrad. bderal regullriow may mcium a
special Buys OWIM to be displayed m Ihe window a ft
VON*. THE INFORMATION YOU SEE ON THE
WINDOW FORM FOR THIS VEHICLE 13 PART OF
THIS CONTRACT. INFORMATION ON THE WINDOW
FORM OVEIIRDBS ANY CONTRARY PROVTSWNS
IN THE CONTRACT OF SALE
QUAnAMY
To awe the Eater to ad to wNcls described on the frond of Orb contract to to Buyer. on onnia, each person who signs below an
oordnK UM one who 9" a pay a guarantor will pay whThis mears OW If dut en ado& Each p Sayer who signs 1W v agre t wney that *d he w Is will be liable, for
ft whole amount owed awn g ore or mom odw pease aft* Nona SW Guaranty. He also agrees b be MW wen t ft Creditor
Ones on or atom of M lclbwlrG (y gores the Buyer more 9rns to pay one or mom papnsr W, or (b) gives a mbswe In full or In pen
to any of the safer Guenve m, or ((? miaow any security. Each Guarantor also dale mN he has moW W a compbbd coy of fhb
t> Mwa and this GjMW at the Irrr of soft.
Ar Address
everemor Address
AKMIPWIILM
to, or conl oveuy (cM elk y, a 'pawn') wfhout Nng a ward N caaL,Ektw y
mt ry LLre SIW a IaweNl b toed, to hrA any Claws related to ON a
:: nit rNbd b fe 1) paws In ton, derwlsR
IT of to era., a • a ar?y rrrs E) alms w M=A
era us r
ti or aMlMIW 4) Claims Srlsbg out a w rNYNq to your atlion for creel, I
Uikd DWI bofup ON with to dollar, asay such NatloneHp wAO were do r
RI4HIS YOU AeO If! AGREE TO GIVE
e Beer YOU air ors ciao.. r ME' a Ulmthe, den you and we agme b wales tie Nowbg rvft
RIGHT TO PATA&VOIfftHER BY JIM= OR JURY
CLAN RELATIVE OR A CLASS MEMBER W ANY CLASS CLAW YOU MAY HAVE
• IO I§QKTS TO DOUS VA*rTHM IN OOVO COUNT AS AM AVAILABLEn N
BR A LAWSUIT
• RIGHT 70 APPEAL TIE DECISION OF AN ARBITRATOR
• OTHER RIGHTS TfATARE AVAILABLE IN A LAWSUIT
WHIM You had M.2116 -So Its N a palm Is arbbabd, you had we will owdraM to haw
wpwwrbnea frotghai mot W. "M to an W*PJM is ft
t to abetOnaerap?r?R r a?i whsbft
nut a tow revlaW tNnfnr fe arbl= Is
cry aseodNm below srrd the odor Party to shat siblbauon. The apptoable rubs (Ihe 'Rules') may
Asrosbfop 1'MA9. at , OQt}T78 inO. or -A *-F .
This ow t d b wlopd to the Faft Arbil albn AN
n
shall be +Mewraftq *0 MM rrWo w?dR ',allow ,- iprovi )) iwill
Pr+brr a tds drw.tlM(1A uroftme"
A freeJlMW Pw,Yw ?owwMwl)
M
"'PRN"'
Ford Motor Credit Company
P.O. Box 31111
TAMPA, FL33631-31 1 1
(677) 349-5260
POMYIAD0200021
MICHAEL J. FORD
52 C ERFORD RD
CAMP HILL PA 17011
Date of Repossession 10-25-2008
Date of Notice
10-29-2008 Date of Contract
07-26421005
Account Number: 039424993
Buyer DEBORAH L. FORD
Cobuyer MICHAEL J. FORD
DESCRIPTION OF PROPERTY
Year
2005 Make
FORD 0 New
? Used
Vehicle Identification Number:
1FMZU74K85UA66B08
Model
EXPLR Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
?x PRIVATE SALE: We will sell the property described ? PUBLIC SALE: We will sell the property described above at public
above at private sale sometime after 15 days from the sale to the highest bidder on the date below (or any adjournment
Date of Notice shown above unless redeemed by you date). The sale will be held as follows:
prior to such sale. Date of Sale Time of Sale Place of Sale
You may attend the sale and bring bidders if you want.
NOTICE OF REPOSSESSION
The money that we get from the sale (after paying our costs,
including reasonable attorney's fees and legal expenses if
permitted by law) will reduce the amount you owe. If we get
less money than you owe, you will still owe us the difference. If
we get more money than you owe, you will get the extra money,
unless we must pay it to someone else.
The property is presently stored at: MANHEIM PA 1190
LANCASTER RD LANCASTER
PA
HOW TO GET YOUR PROPERTY BACK
To get your property back, pay us this amount by certified check or
money order before the vehicle is sold.
Unpaid Balance $ 25,143.75
Plus Costs: Repo Expenses _ $
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 undo
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.
$
Plus Late Charges $ 64.54
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 25,206.29
(Plus expenses incurred if default at the time of repossession exceeded
15 days and less rebate received after the date of this notice.)
Your property won't be sold until 15 days after the date of this notice at
the EARLIEST. After that you can still get it back any time before is
actually sold.
If you do, we'll have no further claim on ft. But the longer you waft, 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:
(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, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above
PAYMENTS: All payments to us must be by certified check or money order.
MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer is not accurate for any reasons, please contact us so that we
can accurately report the vehicle's mileage.
INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealer/original creditor to make sure that any insurance
has been cancelled. You have a right to get credit for all premium refunds.
CHERIA L. WILSON
FFNA 11988-37 Jan 02 Previous editions may NOT be used. CUSTOMER/CUSTOMER FILE
Printed m U.S.A.
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Ford Motor Credit Company
P O BOX 17948
GREENVILLE SC 29606-7948
877 8057187
DATE: 2008-12-25
POODOH00100102
MICHAEL J. FORD
52 C ERFORD RD
CAMP HILL PA 17011
DEBORAH L. FORD
52 C ERFORD RD
CAMP HILL PA 17011
STATEMENT OF SALE
Account Number: 039424993
The following property has been sold.
Year Make Model Vehicle Identification Number:
2005 FORD EXPLR 1FMZU74K85UA66808
Balance owing on your contract (1) $ 25,208.29
Deduct: Finance Charge Rebate (2) $ 0.00
Balance less Finance Charge Rebate (1 - 2) (3) $ 25.208.29
Deduct: gross proceeds of the sale (4) $ 7,800.00
Balance less gross proceeds of the sale (3 - 4) (5) $ 17,408.29
Add: Expenses of retaking and storing, and (6) $ 377.50
any attomeys' fees allowed by law, and
expenses of reconditioning and selling.
Deduct: Insurance Premium Rebate (7) $ 0.00
(8) $ 31.94
Other:
(9) $ 17753.85
Deficiency"
Surplus*
(10) $ N/A
The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses 8r interest
added to your account (debits).
Surplus* or Deficiency"
* If the sale resulted in a surplus, a refund for the difference will be mailed to you.
** If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for
payments shown below.
For additional information call or write: Mail deficiency payment to:
Ford Motor Credit Company Ford Motor Credit Company
P.O. BOX 6508 DEPT 194101
MESA ARIZONA 85216-6508 P.O. BOX 55000
(800) 732-2264 DETROIT MI 48255-1941
FFNA11990 01/04 Previous editions may NOT be used.
CS)
CF TH,
.: Tr
Y
2009 , 22 PH
-,JMTY
+'7s .5o Pa AT Y
Cr-* 1'75174
Sheriffs Office of Cumberland County
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
?o??tr at'':uu?brr?fib
0"jCE QF -Hr SHERIFF
FILET,:-.,?.=a=1CE
OF THE fiRf-Y7;..'.1`N0TARY
2009 JUL 27 AN 9* 2 5
Ford Motor Credit Company Case Number
vs. 2009-4959
Michael J. Ford
SHERIFF'S RETURN OF SERVICE
07/2312009 07:16 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 23,
2009 at 1916 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Michael J. Ford, by making known unto himself personally, defendant at 52 C Erford
Road Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $41.50
July 24, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
Deputy Sheriff
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
(L 15) /tiy-/ 155
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
MICHAEL JFORD
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 09-4959
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, MICHAEL J FORD in the amount as follows:
Principal Amount $ 17776.35
Interest to Date $ 1990.43
Costs $ 120.00
TOTAL $ 19886.79
MAURICE &/NljEPLkMAN, P.C.
BY:
for
TAYLOR, ESQ.
Date : October 7, 2009
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
/89-' / 155
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
MICHAEL JFORD
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 09-4959
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 9/15/2009 he/she mailed a written Notice of
Intention to File the Praecipe to Defendant, MICHAEL J FORD, at 52 C ERFORD RD, CAMP
HILL, PA 17011 by regular mail ,.1
MAURICE #. NEIJDL]IMAN, P.C.
BY:
TAYLOR, ESQ.
ntiff
SWORN TO AND SUBSCRIBED
before me this l day
of ? , 200F.
Notary Public
.I
k yy >:.
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(L1J) /tSy-/15S
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
MICHAEL JFORD
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 09-4959
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on
9/15/2009 to Defendant, MICHAEL J FORD , 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 9/15/2009, a copy of themailing to the Defendant and affidavits of service
are all attached hereto.
Attorney for
MAURICE
BY:
P.C.
TAYLOR;,C,%& __
Date: October 7, 2009
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(21-5) 789-7155
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
MICHAEL JFORD
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 09-4959
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: MICHAEL J FORD,
52 C ERFORD RD,
CAMP HILL, PA 17011
MAUR
BY:
, P.C.
?OR, ESQ.
Date: October 7, 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
15) /tSy-/15?
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
MICHAEL JFORD
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 09-4959
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 he/she represents the Plaintiff in the above entitled case and that Defendant,
DEBORAH L MICHAEL J FORD is over 18 years of age; the occupation of Defendant is
unknown and to the best of Plaintiffs knowledge, information and belief, Defendant is 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.
MAURICE
BY:
Attorney for
, P.C.
A. TAYLO?R.r
Attorneys at law
Suite 935, One Para Center
1617 John F. [atlady Blvd.
Pbifad&**, PA 19103
te1.215.665.1133
fox 215.5639910
www.mnlawPc.wm
DomW S. Maurice
N mbar NJ Nor
Beard Certified
Creditors' BiBlgs Low
American Board of Certification
Joam Ileadleawn
Member PA & NJ Nor
Thomas B. Domiaayb
Member NJr NP 8 PA Aar
Charlene A. Toylor
Member PA Bar
New Jersey ONice
11.1. t Needleman, P.C.
Suite 2001
5 Walter E. Forge Bird.
Fkatiapa,1hOU22
tol.90A331ASS0
tax 906.231.4551
September 14, 2009
MICHAEL JFORD
52 C ERFORD RD
CAMP HILL, PA 17011
Our File No. 10123
RE: FORD MOTOR CREDIT COMPANY v. MICHAEL J FORD
CUMBERLAND COUNTY COURT OF COMMON PLEAS,
CASE NO. 694959
Dear Mr. Ford:
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 July 23, 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,
CE & NEEDLEMAN, P.C.
e 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
(215) 789-71.55
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
MICHAEL J FORD
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 09-4959
IMPORTANT NOTICE
TO: NUCHAEL J FORD DATE: September 14,2M
52 C ERFORD RD
CAMP HILL, PA 17011
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH
THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING
AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGLE PERSONS AT A REDUCED FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue,
Carlisle, PA 17013
(717) 249-3166
MAURICE & NEEDLEMAN,.P.C.
r
BY
C LENS A. TAYLOR, ESQ
Attorney for Plaintiff
Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
Ronny R Anderson a( eet 444"
Chief Deputy r? .
:, ,..:.
Jody S Smith
a
Civil Process Sergeant as ar IMF eFF
Edward L Schorpp
Solicitor
Ford Motor Credit Company
VS. Case Number
Michael J. Ford 2009-4959
SHERIFF'S RETURN OF SERVICE
07123/2009 07:16 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 23,
2009 at 1916 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Michael J. Ford, by making known unto himself personally, defendant at 52 C Erford
Road Camp Hill, Cumberland County Pennsylvania 17011 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $41.50
July 24, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
Deputy Sheriff
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Pagel of 2
FEB-13-2009 06:37:18
'? Last Name First/Middle Begin Date Active Duty Status Service/Agency
FORD MICHAEL 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.
rte, 14.
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 2/13/2009
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:BAYAUQQUFAT
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 2/13/2009
OF THE RY
2009 Oe T t 5 Pj I,:
O I
414•o:) p o A"rW
cir-* t gtor7 dt
Nahee 1,.1a.JW
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7155
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
MICHAEL J FORD
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 09-4959
(X) Notice is hereby given that a judgment in the above-captioned matter has
been entered against you in the amount of $19886.79 on /p
(X) A copy of all documents filed with the Prothonotary in support of the
within judgment is enclosed.
S ?.
Prothonotary/ lerk D"
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)
MAURICE & NEEDLEMAN, P.C.
Attorneys for Plaintiff