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Home My WebLink About09-5614ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Iddontificat, ion No. 74276 vetharlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff 15) 7259-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. JEREMY MASSIE 364 Maple Lane Carlisle, Pa 17015 JULIE MASSIF 364 Maple Lane Carlisle, Pa 17013 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. Oq - rJ(p 4 0l4 l ( -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. 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 vemte (20) dial de plazo at partir de la fecha de la demands 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 demanda en contra soya 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O ST 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 (2-15) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. JEREMY MASSIE 364 Maple Lane Carlisle, Pa 17015 JULIE MASSIE 364 Maple Lane Carlisle, Pa 17013 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 09-- S'G 1 y C.u q 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, Jeremy Massie, is an individual who resides at 364 Maple Lane Carlisle, Pa 17015. 3. Defendant, Julie Massie, is an individual who resides at 364 Maple Lane Carlisle, Pa 17013. 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 March 7, 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 $29351.60 at an annual percentage rate of 11.000%, in order to purchase a certain motor vehicle, 2005 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 $405.86 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 July 22, 2008, 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 $2900.00, however a balance of $9262.13 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 $616.88 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $9879.01. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $9879.01, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Date: August 6, 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: August 6, 2009 PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CnNTRAC-T nerc 03/6'710`11; r) Name and Address (including County and 21p Cade) CREDrTOR (Seller Name and Address) ?' ric D '561 HASSIe JULIE A MASSIE MAR 0 9 2505 L B SMITH FORD INC / C $ ? D PA 17013 jj88&RKET ST PA 17013-1654 You, the Buyer (and Colluyef, it any), may buy ae vehicle described below for cash or on credit. The'Caah Price' shown beiow Is an cash price of the vehicle. The 'Total Sals Prime shown telow Is the credit price. By signing ]his contract you choose to buy on credit under the sentiments on the from sod back of this contract. Now/Used Year and Make Modal GVW it Truclt lbs. Venkle Identiliealion Number Use Fo which PoroMsatl I NEW LORD AURUS 1t•AFF532X6A 95 CHEVROLET s 3623.94 s? Tradain 36.94 Year and Make Gross Allowance Amount Owns ITEMIZATION OF AMOUNT FINANCED 1. Cash Price ..... » ..................................................................................... $ 2171%, 10 (1) 2. Down Payment Third Party Rebate Assigned to Creditor ............................. $ Stn 00 Cash Down Payment ......................................................... ..:...... $ N/a Trade-In 95 CHEVR $ 361194 $ 35ziyg $ 1,,, year ale MW Grow Aa- Amwue Owkv Total Down Payment...._._._._._._...._._ ........................................ $-3000.00- (2) 3. Unpaid Balance of Cash Price (1 minus 2)-,,, $ _ICZ15? 19 (3) 4. Amounts paid on your behalf (Seller may be retaining a portion of thew amourds) To Insurance Companles for Credit Life Insurance (for term of contract) ........................ $ -lam - Credit Disability Insurance (for term of Contract).-.-.-..... $- W1111;- rremn -Months (Estimate)) $'-AVIt To Public Officials (f) for license ($ 16_ j ), title ($-22--M-), 8 registration ($-._ ) fees $ j 9n ; (ii) for filing fees $ ?- g (iii) for taxes (not in Cash Price) $ 8129.28 $ ma » To for $ *% To BOLD MD1% CRED for SEffin P cl moarw $- 30.00 TO for $ %;a To N/A for MAR $_ M Total ......................... ....... _..............................._...._.-._._._......... $ 16jj ;Q (4) 5. Amount Financed (3 plus 4) .................................. _ _._._. $ earax .? (5) FEDERAL TRUTH-IN-LENDING DISCLOSURES ANNUAL FINANCE Amount Total Of Total Sale PERCENTAGE CHARGE Financed Payments Price RATE The dollar, amount The amount of The amount The total cost The coat or your the CrMM win Credo provided to you will he" of your purchase on Credit as a yearly rate cost you you or an your paid when you Croft, behalf have made all including your scheduled downpayment payments of $ _ xr a s $ s payment Schedule Ibanber of Amount of Each When Payments Payments recanted are due Your payment schedule 6 $ .86 (monody sterling) wig be: 1 final $--yam 'repsymem: If you pay off your debt eery, you will not have to pay a penalty. ate Psymem: You mint pay a late charge on the portion of each payment received more han 10 days late. The charge is 2 percent of the tats amount or 550.00 whichever is lase. lecurlty Interest: You are giving a security Interest in the vehide being purchased. ontraet: Please gee this Contract for additional information on security interest, nonpayment 'eiaub, the right to require repayment of your debt In fug before the scheduled data, and repayment penally. you do not meet your Contract oblieadore, you may losethe vvehlcla that you ere financing under this Contract. well se boat Dana and cootie an on eve veNda and NON-MODIFICATION DISCLOSURE Any change in IN conbed must be in wdgng and signed by You redibr. v SIGNS Q.OaNBUYE YOU ACKNOWLEDGE THAT YOU HAVE r RESA E TO BE BOUND BY THE ARBITRATION 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 (1) before all nln this contract, Buyer nd Co-Buyer) received an rev a rue and completety tiled in copy of this contract and (ii) at the time of si nit this contract Buyer (and Co-Buyer) riac-eiv-id a rue an completely filled In co this contr ct. YER $MO W R &G By signing below, the Seiler accepts thiseo other E% w Is nsmed In a sip assign a" attached to this contract, the Seller asei to It B SMITH rm IN: By 'w A ? Personal El Agricullunl ;A .r,,.- n. w t- - r s esa.) ash DACA FOR ADDITIONAL AGREEMENTS 147806 ? com erciel INSURANCE YOU MAY OBTAIN VEHICLE INSURANCE FROM A PERSON OF YOUR CHOICE. YOU ARE NOT REOUIRED 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 $di um Insured(s) Signature Credit ? Disability Insurer FWN um Insured Signature Other Optional Insurance Term $ Insurer Prell0lim Signature Credit Ufa and Credit Obtabi ty Insurance are for the term of the contract. The amount and o we shown In a toil" or agreement given y? today. You must Insure the vehicle. it a charge is to buy the shown below the Creditor WIN tryrmshown. coverages aiteakad for the ts Covens- will be based on the Cruh value of th n i e va at t me of toss, but not more than the limits of the policy. ? Comprehensive ? Sam/ Deducdoe Collision ? Fire- Theft-Combined Additional Coverage ? Towing and Labor ? Term Months (Estimate) Premium $ I*% ? Debt Concohnion Waiver Addendum (OptionN t this box 4 rdracttetl you have purchased a debt oa rarceiletbn waymr. Pwcnase of IN1 Coverage is colonel and is not required to obtain credit. The fame and conditions of the debt carwemon waiter are set forth in tlM Reached Addendum which is Incorporated Into this Contract. The prim for the debt conalk on wwivw 4 set font on this contract in the Itemization of Amount Financed under Section 4. Buyer Program No. QUESTIONS? PLEASE CALL US AT 1-800-727-7000 1 or Visit us at www.forcicreditcom 03-001 ORIGINAL ADDR10NxL AeBBBWU*a In UAL wo whist .0 mussom11Y?rNol. Yo. w" .Mb an Axel of *RO wMrak HOMY. llb do m You b a ddOo Mt1 pl no a" ywMrt PONanB. sharp "m p".10 yg0bupr?_ .?{.,, .dledtdsd dMOO ai Nh.Y?hn to so mom M *SOW WE OPPIF YOW PaYlmsttb 10 to IW sanwl and totpold The coo" OO.rO on Aetna p ? wa E?uyAOla?gyo?rA?pP ? N PsBardogw Rte b M W Wd Aw" rYwtn..d" for b0 oAMW w Ira. th. tatp.w Arngrd Fbsroad la aw.largllW, X. , YNdole ts der You we not haw a " b r.YWONvabOrdrect b lemr" kWaresb You gnus iha Credb?a y '? eawky baeeM Ya 1. The whkM and all parts of otrar goods put on the varlets; L AN, ta ha prmdWns and ssrefa oansiob Bwoed & you. TMs wrap psymaw d all rnwds You owe Its fhb matb,t} h atss eeourve your Orlin agreements in tds ao WNL ,. C. Use of Whlole - WARRANTRS: You must ma ten at volricle Wld obey all lows In u*q L You troy not sell or tont tote vslift and you rtwN keep N We wom the dalm of b6tin. YOU WE not use a Penh VW use of Nte " HIM a lelo'clAhe L%md S1We, except for up to 90 drys in Cants a mw*o, wmled tra Plor wrEm leers d M Credlor N 1M vM b of a type tuormatY us" for peeseM as and in Cr, odbr, or Ble vwlaele'a raawlaaww, ar ende a WABa Normal or aafvbe.stars" coverlag tfw vMh A wNhhf W days btm Ike dole of NO 0-tract, You got Implieddurww-*- of rearchantsbillty a Iwo psAkalr ft y ire no vAh lahPNM %. Me, a Ores Utah 0. Imetworm: You newt Irmwe yourself slid tha CredWr epakpt bra or damps to .n "Mr. Wo Cmata mwl app,, tW "a wW emend d bmaaha. N the Oed W otram a r1yhih8 on k*ww a or savbe contracts, ttre Cake rare KWAO the tebdo born what you owe. WMNrer or not go v ela Is in urK you must pay for It N It Is lost, damaged, or M a drarpe for vsltida bwtrarhn is shown an tea Mad, fha Crpbr will try b buy tb dram Ited fat tW brm eharWt. Tha Credlle Is not swft sou t he anol of sm N Ma oowmpee cost more ttm the amount shown for Inat area, fW Osabr may buy tram for a dwhw farm or he army plus You wS on you east for amaUd drowns. The great will be made b tW lee po merles Are. E. Late Charge: You will haw to pay a late dwp on ow pabn d each paymera made man tun ten days tats. -Site clump Is shown on star had. Aooefdartoe of a tale don not Wows your debut or mush that you conp MdrtO Peymmb after mots are dire. The Creator may talc tar staps set brill h Ws cw*w.Y, Y Drew Is any default. P. OslaVII: You TA be h dtdart F. 1. YOU do act wake a who I Is dYil or :.Ill:. 2. YOU y?hw0 on or Ip Inbnn t gnip m" ?. TO4r YM.a..I.?wgb1? oMY-Oh, CI r .. Ofhd b reel ProigAy?ond anlgndlYua"'? to or 4. Yo0 tle a bonyou;Iaupq powm a erw b mod sp kw your a & Vat do a1 heap shy orbs phatllla mods. - t, v you era In deWrE,rso Cmdw Ty y?o.Y?0 ale once PPMw?gw Am" WN =vm, and, du.lepst byp?aa of F20 ir; l IM raP" as OOll?Nr?ldQ•tle nhldat??pa, f(s Avg aloe w.% la 60.6*0N vNdals W harl'repoeseeeed end hold from fw ycKL M tle veldala Is Ishm baalr, he will smd a hobs. The nodom we ON stall You mats ndaMn (Duty baag rise Vol N wet aloe slow, ft amour needed 10 tadam You cry redsan M b to St" to Cmcmw soft A or VSWG not radaan tW hreldole. k wet be ab.agaa to ad L N TM QapolW WE m Sh'.htlrtbn kmm tra SO, loss ft dowel epenw, b pay ft mom sire awed on oft I I ' -l h snwmL old N for ts?aale, 1ha anct sell It era, as gpom 41M by ? air woo s ioa Gfm andiv? coo pfd by bav as .' ck arrpka). YOU WE 2 you any many felt (a Cedbor. I you dowel pay s t4 mWIWIN f Cnrmor am ?Cmd or mats dregs you bdenM M the hbtist WAd aft you pay. tL Consunner:Reparte You autlhorhe Ford Moor CNN Carr tarry b ataebt Caaursar asdlt feponls ben oonsumwr repeBtp agWtdes (arodt bureaus) for ay ream and of any stns In oar_ rr ,a,rr WIM tt? mnu": H: Gamral: To monad Ford Mohr Om* Gon4wry about .see socorat, all 1.100.787 7000. Alm, YOU my nubs adores and other selected dwWN al vrww.fordwMLoom. The law of Per. eylvsrds appba b fhb ounbuL t to bw doe not abw M d the vft The fast In ft cm*vA Ow ones IM o ia rib O YA toll be gad.na .bead will be NOTICE - ANY HOLDER OF THIS CONBUMM CREDIT CONTRACT IS SUBJICT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF OOODB OR SERVICES OBTAINED PURSUANT HERETO OR WIT" THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. Uwd Maur A" Buyers N You are b4ft a used veNcle with 0dt contract. federal regulations may require a epaW Bitter; Gdde b be depwrod an No wbtdoor d .W veNde. THE INFORMATION YOU SEE ON THE WINDOW FORM FOR THIS' VEHICLE M PART OF THIS CONTRACT. INFORMATION ON THE WINDOW FORM OMMIDES ANY CONTRARY PROV181)NS To (aLhrt.e do Saber to sell to vaNde desabed on the Mart d ddt oorftcl b mu Buyer, m apt, each pram who signs below a aaanMrrd' gunoraas M psynaard a ft mesa This means tlef N the Super fob to pay any messy #W Is Owed an tits ft whole, ansud eal am me a guarantor will pay It when malmd. Each orm or mom o porsaw alm ftm 116 par"" who sgrhe below spear to M will N be Cmc for w doer as or more of M faNahd V W gtva the Bye more *m to pay ore or more ? IN dw s, eerr r M p (b to be e awn N ft Cnabr psyrnmr at ary of fir cow emarmu ,err (??? reberes onY seaaMy. Each Gwrator aloe sfstr to em to t ha flee a a w baa In tut or In pM comae and ft Gu &W W at the late of dphbup Me rooehrW a aarglefed ooPY a tds Guvahbr Address mbt0 . beaul b aoutt Etlw a comb-ow kobdablerMba, a 'C a"'m lal MMb st .era bvrs le reed haw sy Claire releled b tlhts r e not to the 1) Otalnra b contral tat, err odrndm a , ra d ay«ts 0; 8) Cblate .pp=ie? You and us, dtaNrp did it to do" a my such re W* wib lftrd partltii wto do RlGFII'S YOU AND W! AdItB< TO GIVE LM a ewer yw or We aroma w ale thm you aid we agree b wee t» blowt, fights: • TO A TTy.????,,1IIf grM BY A JUDGE OR JURY • TO PARTIINPATE AS A C BIT Nrr LAM REPFS=WATVE OR A CLAW MEMBER tN ANY CLASS CLAW YOU MAY HAVE ION • BROAD IBLifMM TO MDIBOBDEY{M V All AM AVAILABLET A LAWKW 11110111 TO APPEAL • OTM RNWM TTMTAM VAnA LA W AR ARjETMTCR A LAWSM - Rfdlb You Athd TYa DU Net GM L?!• N a Clelm Is arbbl lsd, you Mutt we will cardbara b how sp IObwNW will walvUW ttla r waem prevapa a b 1Vty tam 1) RWII.t?oyM? In aiuC W RIOtt to etas the maagr ti the wfdufs. whtdra O?Ohat?d nlmYlaw vain or" albMratsr aa6errltd Ili spa arm b etas to @ Mbaloh da mM and J) ft* to requ od turf a l obh r Pair to aefxlabd SOW seemdatm babe and pre cow Potty to am ablbabn. The appbabN nder (era T~ my be s eimft-lon .Aseodat?mR??AA11•I?M ti?0 77!7!7!. or -m. ,* mg Tttb shat PoOSarwha Iw+e.rerrnrrr•..el - M ... PRN••• Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631-3111 (877) 349-5260 POMED100200041 JEREMY MASSIE 364 MAPLE LANE CARLISLE PA 17015 Date of Repossession 10.05-2008 Date of Notice 10-07-2008 Date of Contract 03-07-2005 Account Number: 038674595 Buyer JEREMY MASSIE Cobuyer JULIE MASSIE DESCRIPTION OF PROPERTY Year 2005 M Vehicle Identification Number: 1FAFP532x5A147806 Model TAURS Body 4DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. ? PRIVATE SALE: We will sell the property described ? 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 Salle Place of Sale You may attend the sale and bring bidders if you want. NOTICE OF REPOSSESSION The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) Will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get more money than you owe, you will get the extra money unless we must pay it to someone else. You can get the pr perty back at any time before we sell it by paying us the full amount you owe (not just the past due payments), includi g our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number above. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money unde your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. The property is presently stored at: Manheim Auto Auction 1190 Lancaster Road Manheim 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 $ 11 59259 Plus Costs: Repo Expenses $ 370.00 Plus Late Charges $ 1588 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 11,978.47 (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 wont be soy until 15 days after the date of this notice at the EARLIEST. After that you can still get it back any time before its actually sold. If you do, we'll have no further claim on it. But the longer you wait, the more casts (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: Under our agreement With (dealer/original creditor) your dealer/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money after the sale, you will pay ft to the deader/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 riot its obligations) with rasped to the sale of each vehicle listed above. PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer is not accurate for any reason, please contact us so that we can accurately report the vehicle's mileage. INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealer/original creditor to make sure that any insurance has been cancelled. You have a right to get credit for all premium refunds. CAROLYN L. CASSICK FFNA 11988-37 Jan 02 Previous editions may NOT be used. CUSTOMER/CUSTOMER FILE PnMed in U.S.A. "'PRN"' Ford Motor Credit Company P.O. Box 31111 TAMPA, FL33631-3111 (877) 349-5260 POMED100200045 JULIE MASSIE 364 MAPLE LANE CARLISLE PA 17013 Date of Repossession 10 05 2008 Date of Notice 10-07-2008 Date of Contract 03-07-2005 Account Number: 038874595 B r JEREMY MASSIF Cobuyer JULIE MASSIE DESCRIPTION OF PROPERTY Year 2005 Make FORD Q New ? Used Vehicle Identification Number: 1FAFP532x5A147806 Model TAURS 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. You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number above. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money under your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. LJ The property has been (or will be) returned to: Under our a regiment with (dealer/original creditor) 9 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 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 reason, please contact us so that we can accurately report the vehicle's mileage. INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealer/original creditor to make sure that any insurance has been cancelled. You have a right to get credit for all premium refunds. FFNA 11988.37 Jan 02 Previous editions may NOT fro used. Printed in U.S.A. CAROLYN L. CASSICK CUSTOMERICUSTOMER FILE The property is presently stored at: Manheim Auto Auction 1190 Lancaster Road Manheim 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 $ 11 59259 Plus Costs: Repo Expenses $ 370.00 $ Plus Late Charges $ 1588 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 11,978.47 (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 its 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. AlfIr's r? owl i ? $ g pO o o $ o 0 $ a?$? $? ? ? ? h O N N W N pp H pp N h ?,? a o S p O O S O 0 p ??yy NN N N Q ° N N h N N M qSf Wr _u 441, I Wr c; do M ci h -p i ?J in N "D V) O co m A cm r $ g o i1' $zv W- vieC r _ g-WW^ f ` NWzo? : Q DD I S O JJ o O 3 O?OW ov?_O J O ?Ag o A g a N t - I Ym a m ? r+i o- Q" o- O o Ln C3 e- $ O O O O •p to ? O O rq E o p 0 o ?' S S ? ? O O C N y r ? W, q ' 00„ ' . ! M J ' M1 '' ? N v Eh66h5000TDOOh9OO6T4 O W ~ ^ Off O le- N !O1 W w co o w Ir An th M~ui -W- s->zQ W? - C'O3 ppN W o ?Q o-?Q 0 z (D N O Z o Z C4 J W N>- Z Q p W W OwZQ °o g'? $C70co wM W m ?W2y GQ?W o +•= 0 CV 0 ¦o N m ri fU N MD m to p o o co ul Ln m s Ll N Ln Ln O p O O O O O 0 C3 A A O O C3 C3 ° o 0 0 O O O O O C3 S S O O O O it 00" O T W, N ? ti M1 v ? N ? O co .0 -C r._at3 p Co W oo30K0 eh WZWz ?CCCDLu S G' m c- S V'1 O O O 0 O O S .A O O Q' A N a m two M W W ' < o a? _ _J ?yx3 ?W N Y? 3 s Q CO x CD Q x 0 O S a- S C O O O Z o ?a O O S .A O O Ar s rq Is n Q? ffi g d LL i 1 I I 1 k 4 - i Yo\ r 9' y? 7 • Y.r .. 0 0 L c $ oo $ 8 d o $ o c o 0 0 Og pp pp Q o 0 S. 6 N N h h y y N N y? $ Mika ^ $ S o » N y y y y lV h N !! f09 N N H W a h M N O ^ W 40 Ul) 0 P N C*4 ???pp A $ N l'N7 tp 17 A W Go A, r Ql CD to ? CND M ? t? CD t0 Nf tff c cv M M o $ZO? $ a Jag c ?a ?wwA NOZ? M W? >z' W0 U)?i ?SQ " yE $`?sa $aW= ppau?ia Dna dA4 NO?JW C30J $?W(7 NoZZ " jW 00 IL N}Z} N co vZ o>.aN onJ?LU o?wtQ- oZa oO IL 00(70 03co W Z Z o CC 2 n? LUW W lo4ZNg °w ? a ow§? 0Qmw c?zzmo 2ww M.% to 2 V) LU Zi- 2 2 R m Cc Ln m ra s r O ra 0 o Q. 0 0 N N q co m s N L ? m c Ln Ln Ln Ln Ln C LO O O O O 0 00 O C3 C3 C3 = C 2r9 O O ra ra .C d O p O O C3 C O O ca cm C3 C3 O OS O E 22 .O .O _-r .A . D C N = p D O O O O aaa O p 0 C2 r> Q' 0" C' Q' Ir QO O CO w J M J N ti rq A ra M1 ~ M1 E h66 hS000'000l*006TL m IS w cm t- F o cm 0 Q W A a? O oW_Jin X 6 ?aWS3 02 w a° 62NV w>CCDp S C) t?t O O ? a S O O O ra 0 O O S .A O O ? rR b N z°? ? O ti W M U. 8 Ford Motor Credit Company P O BOX 17948 GREENVILLE SC 29606-7948 877 8057187 DATE: 2008-12-27 POOMY00100144 JULIE MASSIE 364 MAPLE LANE CARLISLE PA 17013 JEREMY MASSIE 364 MAPLE LANE CARLISLE PA 17015 STATEMENT OF SALE Account Number: 038674595 The following property has been sold. Year Make Model 2005 FORD TAURS Balance owing on your contract Vehicle Identification Number: 1 FAFP532X5A1 47806 Deduct: Finance Charge Rebate Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Other: Deficiency** (1) $ 11,608.47 (3) $ 11-60847 (5) $ _ 8,708.47 (9) $ 9239.63 Surplus* (10) $ N/A The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest added to your account (debits). Surplus* or Deficiency" * If the sale resulted in a surplus, a refund for the difference will be mailed to you. ** If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional information call or write: 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 (2) $ 0.00 (4) $ 2,900.00 (6) $ 531.16 (7) $ 0.00 (8) $ 0.00 FFNA11990 01/04 Previous editions may NOT be used. 0 RL" r . E ,nr 7 V p P * q8. 5o Pp Ar i n 8f9 ?.1? aa9ia3 Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor a??ttitr of 4?n+n?crt,? OFF CF .RIFF OF THE Ford Motor Credit Company vs. Jeremy Massie 2009 AUG 19 AK 9' 14 pENWbYLVANIA Case Number 2009-5614 SHERIFF'S RETURN OF SERVICE 08/15/2009 08:40 AM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 15, 2009 at 0840 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeremy Massie, by making known unto Julie Massie, wife of defendant,at 364 Maple Lane Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 08/15/2009 08:40 AM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 15, 2009 at 0840 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jule Massie, by making known unto herself personally, defendant?at 364 Maple Lane Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $49.40 SO ANSWERS, -to A-0-00101lew? V&? August 17, 2009 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) /Z59- / 155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. JEREMY MASSIE AND JULIE MASSIE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-5614 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, JEREMY MASSIE in the amount as follows: Principal Amount $ 9262.13 Interest to Date $ 870.89 Costs $ 127.90 TOTAL $ 10260.93 MAURICE BY: Attorney for LEMAN, P.C. TAYLOR, ESQ. Date: November 4, 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 /69-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. JEREMY MASSIE AND JULIE MASSIE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-5614 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 Defendant, JEREMY MASSIE AND JULIE MASSIE, 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. MAUR BY: , P.C. . OR, ESQ. SWORN TO AND SUBSCRIBED before me this day of , 200. Notary Public 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 (zo) nsq-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. JEREMY MASSIE AND JULIE MASSIE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-5614 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 9/24/2009 he/she mailed a written Notice of Intention to File the Praecipe to Defendant, JEREMY MASSIE AND JULIE MASSIE, at 364 MAPLE LANE, CARLISLE, PA 17015 by regular mail. MAURICE &/NEVDI/EMAN, P.C. SWORN TO AND SUBSCRIBED before me this day of , 200 . CF?Nia TAYLOR, ESQ. Att ev f0 P intiff BY: Notary Public r? ftftbla F 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 l J) /2Sy-71 ?J FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. JEREMY MASSIE AND JULIE MASSIE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-5614 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 9/24/2009 to Defendant, JEREMY MASSIE AND JULIE MASSIE, 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 9/24/2009, a copy of the mailing to the Defendant and affidavits of service are all attached hereto. MAURICE &,NEJ IQLEMAN, P.C. BY: A. TAYLOR, ESQ. Date: November 4, 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 (11J) /2Sy-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. JEREMY MASSIE AND JULIE MASSIE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 09-5614 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: JEREMY MASSIE, 364 MAPLE LANE, CARLISLE, PA 17015 Attorney JULIE MASSIE 364 MAPLE LANE CARLISLE, PA 17015 MAURICE BY: LEMAN, P.C. A. TAYLOR, ESQ. Date: November 4, 2009 -? w Zp G y070 Z m imp ? Za z mm ? ?14 Z -t7 r ? = v? cn 00 r ?r J J -n G 0-n%(0 N - or tjo a ?s"?90? Attorneys of Low Suite 935, One Penn Center 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.665.1133 fax 215.563.8970 www.mniawpt.com Donald S. Maurice Member NJ Bar Board (vilified Creditors' Rights Low Welling Board of Certification Joann Needleman Member PA 6 NJ Hot Thomas R. Dominczyk Member NJ, NT & PA Bar Charlene A. Taylor Member PA But September 23, 2009 JEREMY MASSIE 364 MAPLE LANE CARLISLE, PA 17015 Our File No. 10610 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. JEREMY MASSIE AND JULIE MASSIE CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 09-5614 Dear Mr/Mrs/Ms MASSIE: 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 8 /15 /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 maybe 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 MAE yours, 1 & NEEDLEMAN, P.C. Esq. New Jersey Office Maurice & Needleman, P.C. Suite 2007 5 Walter E. Foran Blvd. Fleminglon, NJ 08822 tel. 908.237.4550 fax 908137.4551 CT/jm Enc THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 lip X69-1l?a FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMPANY COMMON PLEAS Plaintiff CASE NO. 09-5614 JEREMY MASSIE AND JULIE MASSIE IMPORTANT NOTICE TO: JEREMY MASSIE DATE: September 23, 2009 364 MAPLE LANE CARLISLE, PA 1.7015 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR. BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICE & II(EEI)Iol MAN, P.C. BY %-... CHA TAYLOR, ESQ Attorney for Plaintiff Attorneys at law Suite 935, One Penn Center 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.665.1133 fox 215.563.6970 www.mnldwpc.com Donald S. Maurice Member N1 Bar Board Certified Creditors' Bights Low American Board of Certification Joann Needleman Member YA B NJ Bar Thomas R. Dommayk Member NJ, NY R PA Bar Chorlene A. Taylor Member ?A Bar September 23, 2009 JULIE MASSIE 364 MAPLE LANE CARLISLE, PA 17013 Our File No. 10610 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. JEREMY MASSIE AND JULIE MASSIE CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 09-5614 Dear Mr/Mrs/Ms MASSIE: 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 8/15 /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 tru Yrs, MAU CE NEEDLEMAN, P.C. , Esq. New Jersey Office Mortice & Needleman, P.C. Suite 2007 5 Walter E. Foran Blvd. Flemington, NJ 08822 tel. 908237.1550 fax 908.237.1551 e CT/jm Enc THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. Identification No. 74276 Charlene A Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7155 FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMPANY COMMON PLEAS Plaintiff CASE NO. 09-56I4 JEREMY MASSIE AND JULIE MASSIE Defendant(s) IMPORTANT NOTICE TO: JULIE MASSIE DATE: September 23, 2009 364 MAPLE LANE CARLISLE, PA 17013 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 8f NEEIALEMAN, P.C. BY_ ? 1A I CHA A. TAYLOR, ESQ Attorney for Plaintiff Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson . Chief Deputy p1? Jody S Smith . Civil Process Sergeant ;Fn(CE OF rHE s46RiFF Edward L Schorpp Solicitor Ford Motor Credit Company vs. Jeremy Massie Case Number 2009-5614 SHERIFF'S RETURN OF SERVICE 08/15/2009 08:40 AM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 15, 2009 at 0840 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeremy Massie, by making known unto Julie Massie, wife of defendan4at 364 Maple Lane Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 08/15/2009 08:40 AM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 15, 2009 at 0840 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jule Massie, by making known unto herself personally, defendant at 364 Maple Lane Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $49.40 August 17, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Sheriff IW Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAY-01-2009 09:55:50 ' . Last Name First/Middle Begin Date Active Duty Status Service/Agency MASSIE JEREMY 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. mgr fri_ of 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 obtath 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://ww_ N._.defenselink.mil/faa/Dis/1'C 09Si DR..htiiiI 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 5/1/2009 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: BEUKXFLQJVX https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/ 1 /2009 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAY-01-2009 09:57:35 '4. Last Name First/Middle Begin Date Active Duty Status Service/Agency MASSIE JULIE 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. 4101 )4. it 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.defen5elink.mil/faa/pi_s/l')C'09S].,DR..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 5/'1/2009 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: BEHXWGCZMOC https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/l/2009 I ?7 '? 1 j t r. ? t tt o L'L,r"J. 1[_ r. .._ J r . $14. oo PQ prM &-e 18Ra`l zr* a334a7 MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 /89-/IJS FORD MOTOR CREDIT COMPANY, A I CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. 09-5614 V. JEREMY MASSIE AND JULIE MASSIE Defendant(s) (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $10260.93 on it a(X) A copy of all documents filed with the Prothonotary in support of the within judgment is enc osed. Prothonotary/Clerk may} 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)