HomeMy WebLinkAbout09-7572IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
GEORGE VOGT,
Plaintiff,
Vs.
FORD MOTOR COMPANY,
Defendant.
CIVIL DIVISION
NO.: CA -'75'7A 0.,tvit Term
COMPLAINT IN CIVIL ACTION
Filed on behalf of Plaintiff:
George Vogt
COUNSEL OF RECORD FOR THIS PARTY:
Robert A. Rapkin, Esquire
Identification No. 61628
KIMMEL & SILVERMAN, P.C.
210 Grant Street, Suite 202
Pittsburgh PA 15219
(412) 566-1001
WRIT WAIVED
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
GEORGE VOGT,
Plaintiff,
VS.
FORD MOTOR COMPANY,
Defendant.
No.:
NOTICE TO DEFEND
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.
Lawyer Referral Service
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
GEORGE VOGT,
Plaintiff,
VS.
No.: (99. -IS 7 ,;L- CAZ,-P -FU-
FORD MOTOR COMPANY,
Defendant.
COMPLAINT
1. Plaintiff, George Vogt, is an adult individual citizen and legal resident of the
Commonwealth of Pennsylvania, 1902 Douglas Drive, Carlisle, PA 17013.
2. Defendant, Ford Motor Company, is a corporation qualified to do and regularly
conduct business in the Commonwealth of Pennsylvania, with its address and principal place of
business located at 300 Renaissance Center, P.O. Box 43301, Detroit, MI 48243, and can be
served at Office of the Secretary, One American Road, 10th Floor, Dearborn, MI 48126.
BACKGROUND
3. On or about April 14, 2008, Plaintiff purchased a new 2008 Ford Mustang,
manufactured and warranted by Defendant, bearing the Vehicle Identification Number
1ZVHT821-1185141862.
4. The vehicle was purchased in the Commonwealth of Pennsylvania and is
registered in the Commonwealth of Pennsylvania.
1
5. The contract price of the vehicle, including registration charges, document fees,
sales tax, finance and bank charges, but excluding other collateral charges not specified, yet
defined by the Lemon Law, totaled more than $36,505.08. A true and correct copy of the
contract is attached hereto, made a part hereof, and marked Exhibit "A".
6. In consideration for the purchase of said vehicle, Defendant issued to Plaintiff
several warranties, guarantees, affirmations or undertakings with respect to the material or
workmanship of the vehicle and/or remedial action in the event the vehicle fails to meet the
promised specifications.
7. The above-referenced warranties, guarantees, affirmations or undertakings
are/were part of the basis of the bargain between Defendant and Plaintiff.
8. The parties' bargain includes an express 3-year / 36,000 mile warranty, as well as
other guarantees, affirmations and undertakings as stated in Defendant's warranty materials and
owner's manual.
9. However, as a result of the ineffective repair attempts made by Defendant through
its authorized dealer(s), the vehicle is rendered substantially impaired, unable to be utilized for
its intended purposes, and is worthless to Plaintiff.
During the first 12 months and/or 12,000 miles, Plaintiff complained on at least three (3)
occasions about defects and or non-conformities to the following vehicle components:
Transmission Shifting Hard and Grinding and Oil Leak. True and correct copies of all invoices
in Plaintiff possession are attached hereto, made a part hereof, and marked Exhibit "B".
2
COUNTI
PENNSYLVANIA AUTOMOBILE LEMON LAW
11. Plaintiff hereby incorporates all facts and allegations set forth in this Complaint
by reference as if fully set forth at length herein.
12. Plaintiff is a "Purchaser" as defined by 73 P.S. §1952.
13. Defendant is a "Manufacturer" as defined by 73 P.S. §1952.
14. Parsons Interstate Ford LLC is and/or was at the time of sale a Motor Vehicle
Dealer in the business of buying, selling, and/or exchanging vehicles as defined by 73 P.S.
§1952.
15. On or about April 14, 2008, Plaintiff took possession of the above mentioned
vehicle and experienced nonconformities as defined by 73 P.S §1951 et seg., which substantially
impair the use, value and/or safety of the vehicle.
16. The nonconformities described violate the express written warranties issued to
Plaintiff by Defendant.
17. Section 1955 of the Pennsylvania Automobile Lemon Law provides:
If a manufacturer fails to repair or correct a nonconformity after a reasonable number of
attempts, the manufacturer shall, at the option of the purchaser, replace the motor
vehicle... or accept return of the vehicle from the purchaser, and refund to the purchaser
the full purchase price, including all collateral charges, less a reasonable allowance for
the purchasers use of the vehicle, not exceeding $.10 per mile driven or 10% of the
purchase price of the vehicle, whichever is less.
18. Section 1956 of the Pennsylvania Automobile Lemon Law provides a
presumption of a reasonable number of repair attempts if.
(1) The same nonconformity has been subject to repair three times by the
manufacturer, its agents or authorized dealers and the nonconformity still exists;
or
(2) The vehicle is out-of-service by reason of any nonconformity for a cumulative
total of thirty or more calendar days.
3
19. Plaintiff has satisfied the above definition as the vehicle has been subject to repair
more than three (3) times for the same nonconformity, and the nonconformity remained
uncorrected.
20. In addition, the above vehicle has or will be out-of-service by reason of the
nonconformities complained of for a cumulative total of thirty (30) or more calendar days.
21. Plaintiff has delivered the nonconforming vehicle to an authorized service and
repair facility of the Defendant on numerous occasions as outlined below.
22. After a reasonable number of attempts, Defendant was unable to repair the
nonconformities.
23. Plaintiff avers the vehicle has been subject to additional repair attempts for
defects and conditions for which Defendant's warranty dealer did not provide or maintain
itemized statements as required by 73 P.S. § 1957.
24. Plaintiff avers that such itemized statements, which were not provided as required
by 73 P.S. § 1957 also include technicians' notes of diagnostic procedures and repairs, and
Defendant's Technical Service Bulletins relating to this vehicle.
25. Plaintiff avers the vehicle has been subject to additional repair attempts for
defects and conditions for which Defendant's warranty dealer did not provide the notification
required by 73 P.S. § 1957.
26. Plaintiff has and will continue to suffer damages due to Defendant's failure to
comply with the provisions of 73 P.S. §§ 1954 (repair obligations), 1955 (manufacturer's duty for
refund or replacement), and 1957 (itemized statements required).
4
27. Pursuant to 73 P.S. § 1958, Plaintiff seeks relief for losses due to the vehicle's
nonconformities, including the award of reasonable attorneys' fees and all court costs.
WHEREFORE, Plaintiff respectfully demands judgment against Defendant in an
amount equal to the price of the subject vehicle, plus all collateral charges, attorneys' fees, and
court costs.
COUNT II
MAGNUSON-MOSS (FTC) WARRANTY IMPROVEMENT ACT
28. Plaintiff hereby incorporates all facts and allegations set forth in this Complaint
by reference as if fully set forth at length herein.
29. Plaintiff has or may have resorted to Defendant's informal dispute settlement
procedure, to the extent said procedure complies with 16 CFR 703.
30. Plaintiff avers that the Federal Trade Commission (FTC) has determined that no
automobile manufacturer complies with 16 CFR 703. See, Fed. Reg. 15636, Vol. 62, No. 63
(Apr. 2, 1997).
31. Plaintiff is a "Consumer" as defined by 15 U.S.C. §2301(3).
32. Defendant is a "supplier", "warrantor", and a "service contractor" as defined by 15
U.S.C. § 2301 (4),(5) and (8).
33. The subject vehicle is a "consumer product" as defined by 15 U.S.C. § 2301(1).
34. By the terms of its written warranties, affirmations, promises, or service contracts,
Defendant agreed to perform effective repairs at no charge for parts and/or labor.
5
35. The Magnuson-Moss Warranty Improvement Act requires Defendant to be bound
by all warranties implied by state law. Said warranties are imposed on all transactions in the state
in which the vehicle was delivered.
36. Defendant has made attempts on several occasions to comply with the terms of its
express warranties; however, such repair attempts have been ineffective.
37. The Magnuson-Moss Warranty Improvement Act, 15 U.S.C. §2310(d)(2)
provides:
If a consumer fmally prevails on an action brought under paragraph (1) of this subsection, he may be
allowed by the court to recover as part of the judgment a sum equal to the amount of aggregate amount of
costs and expenses (including attorney fees based upon actual time expended), determined by the court to
have been reasonably incurred by the Plaintiff for, or in connection with the commencement and
prosecution of such action, unless the court, in its discretion shall determine that such an award of
attorney's fees would be inappropriate.
38. Plaintiff has afforded Defendant a reasonable number of opportunities to conform
the vehicle to the aforementioned express warranties, implied warranties and contracts.
39. As a direct and proximate result of Defendant's failure to comply with the express
written warranties, Plaintiff has suffered damages and, in accordance with 15 U.S.C.
§2310(d)(1), Plaintiff is entitled to bring suit for such damages and other legal and equitable
relief.
40. Defendant's failure is a breach of Defendant's contractual and statutory
obligations constituting a violation of the Magnuson-Moss Warranty Improvement Act,
including but not limited to: breach of express warranties; breach of implied warranty of
merchantability; breach of implied warranty of fitness for a particular purpose; breach of
contract; and constitutes an Unfair Trade Practice.
6
41. Plaintiff avers that Defendant's warranty was not provided to Plaintiff until after
the vehicle was delivered, making any and all limitations, disclaimers and/or alternative dispute
provisions ineffective for a failure of consideration.
42. Plaintiff avers Defendant's Dispute Resolution Program was not in compliance
with 16 CFR 703 for the model year of the subject vehicle.
43. Plaintiff avers that Defendant's warranty did not require Plaintiff to first resort to
a Dispute Resolution Program before filing suit.
44. Plaintiff avers that upon successfully prevailing upon the Magnuson-Moss claim
herein, all attorney fees are recoverable and are demanded against Defendant.
WHEREFORE, Plaintiff respectfully demands judgment against Defendant in an amount
equal to the price of the subject vehicle, plus all collateral charges, incidental and consequential
damages, reasonable attorneys' fees, and all court costs.
COUNT III
PENNSYLVANIA UNFAIR TRADE
PRACTICES AND CONSUMER PROTECTION LAW
45. Plaintiff hereby incorporates all facts and allegations set forth in this Complaint
by reference as if fully set forth at length herein.
46. Plaintiff is a "Person" as defined by 73 P.S. §201-2(2).
47. Defendant is a "Person" as defined by 73 P.S. §201-2(2).
48. Section 201-9.2(a) of the Act authorizes a private cause of action for any person
"who purchases or leases goods or services primarily for personal, family or household
purposes."
7
49. Section 1961 of the Pennsylvania Automobile Lemon Law, provides that a
violation of its provisions shall automatically constitute a violation of the Pennsylvania Unfair
Trade Practices and Consumer Protection Act, 73 P.S. 201-1 et SeMc .
50. In addition, the Pennsylvania Unfair Trade Practices and Consumer Protection
Act, 73 P.S. §201-2(4), defines "unfair or deceptive acts or practices" to include the following
conduct:
(vii). Representing that goods or services are of a particular standard, quality or grade,
or that goods are of a particular style or model, if they are of another;
(xiv). Failing to comply with the terms of any written guarantee or warranty given to
the buyer at, prior to, or after a contract for the purchase of goods or services is
made;
(xv). Knowingly misrepresenting that services, replacements or repairs are needed if
they are not needed;
(xvi). Making repairs, improvements or replacements on tangible, real or personal
property of a nature or quality inferior to or below the standard of that agreed to
in writing;
(xvii). Engaging in any other fraudulent or deceptive conduct which creates a
likelihood of confusion or of misunderstanding.
51. Plaintiff avers Defendant has violated these, as well as other provisions, of 73 P.S.
§201-2 et sue.
52. Section 201-3.1 of the Act provides that the Automotive Industry Trade Practice
rules and regulations adopted by the Attorney General for the enforcement of this Act shall
constitute additional violations of the Act.
53. Defendant's conduct surrounding the sale and servicing of the subject vehicle falls
within the aforementioned definitions of "unfair or deceptive acts or practices."
54. The Act also authorizes the Court, in its discretion, to award up to three (3) times
the actual damages sustained for violations.
8
WHEREFORE, Plaintiff respectfully demands judgment against Defendant in an
amount not in excess of , together with all collateral charges, attorneys' fees, all court costs and
treble damages.
KIMMEL & SILVERMAN, P.C.
By:
Robert A.
Attorney for Plaintiff
210 Grant Street, e 202
Pittsburgh PA 15
(412) 566-1001
VERIFICATION
Robert A. Rapkin, states that he is the attorney for the Plaintiff herein; that he is
acquainted with the facts set forth in the foregoing Complaint; that same are true and correct to
the best of his knowledge, information and belief; and that this statement is made subject to the
Penalties of 18 Pa. C.S.A. §4904, relating to unswom falsifications to authorities.
EXHIBIT A
MM&T CREDIT SERVICES, LLC
PENNSYLVANIA
MOTOR VEHICLE INSTALLMENT SALE COKIWACT, DOW Account N
Unpaid Gash
ti",?; :: eta n
To Credit
S
Your Paymant Schadulo will be:
Yn' of Yowmentr ammrnt of Pwmonic riheaRme.aoar am fkw 3w
Lien F
Prepayment; If you pay off early, you will not have to pay a penalty.
LF11ini ees: i Wm: If a pay m?I is lafa, yar wlll be dalrAeri 276 of IMe p,rtaea of fife petwhidi a dlrtll, or pa ft eF r mordh Vetter than t 0 days. that rt remains Unpaid.
mw ylld 1ny otitei? dtlCUAlentc for lttlr dk1 ? deisah argr rewired repsyaerd in fuq before the heduld date and prepeymerrt
a means estimate
In NNC ('ontract IE.1[OU DO NOT MEET YOU CONTRACT
THE MOTOR 11 0, we arc PARSONS INTERSM-f FORD LLC
the 211.1.1111. o. R THAI' YOU
. WH l''i $itmr. AWOR
ti Address - ' tip Code MONEY ON DEPOSIT WITH THE ASSIGNEE.
Tou are This Cordracf i;; between Seigr and Buyer. AN
the BUYER(S), V_rnncr diseloW s have been made py sew. S+elkr
WOW, r Zip Code(s) irilendstoassignfhi:COnkbt{felbeAssiiee_
i
It there i3 more than oat m all agreements in this Contract Itemhation of Amount FineneM
TRADE-IN.
Ysu have tydad in
'the following vehiclQ Cash Downpayment
ear and Make Description S Ism (to
tta bahmce is stilt awing On the Vehicle YOUhave traded in, the Seller will pay off this amount on your bA& You warrant and represent to us Trade-In
that any tr449-in is froe from lion, claim, encumbrance or security interest, except as shown in the 9temization of Amount Financed' as the Value of Trade-In
i 'IN Payoff."
MY
and against li?i Payoff tN 170001-00
CREDIT INSURANf3E 14 NOT REQUIRED: Credit Life Insurance and Geait Disability Insurance are not required to obtain credit and will not be
fKBVi[tetf unlm you sign how and agree to pay the additional . Your.insiuance eta or policy will W you do MAIM amount
of insurance available. Alt insurance purchased will be for the term of the (>aP ' reetiir4 fimmew befit"hm wjr pwc>I w
Crodtt lnsurmF1_
by sienine you 5rkct Single Gredit Life VOW is your By suing, you select Single Credit Disability What is your
Insuranen, which costs ` A ase? Years ( which costs= Syr
-A /A
Buyer to be insu red for Single Credit Life Insurance Signature of Buyer to be rmned for Sine Credit Disability Inswance
Ry eignieil, you boo 104d Joint Whdart tiny sefertJoint CA!" Yftare Percentage
6rc K We ln3unince, which G03t4 i _ yent agxt t elydr?lsi?_ "wow mrnm?red
i L L 4??r n
it wre>d-for J0* Jns. T
[ I U Checked, the call (1111W Iflum m setiorth above is estRUIR . Yea wi tie Aol? W of ON a0elsweni in the pow ef; ?v iAegraaoe wt
the time your`i 3WWM 'tt.
VIWCLE! You hove std to purehhoW andar tha.tarnw of this Contract, the tolMokitA tpi' vehicle and its extra equipment, which is called,
i the 'Yehic 11 in this Contract
i
L r e, i yL ii 'Make 'o BY , We 111 pyl IuKk Tell ?&W& <
I" 20M FORD WSTANG V',Q
Eouiomd _ A.T P.5 _ AM-FM Stereo 5 Spd. Other
r
Tip Vin To
rueaanwe..e.c...?.w.....«......r.??? _..Y
FINANCE Amount Financed Total of Payments Total Sale Office
*1 At3f RATE CHME The amount of credit provided The amount you, will have paid atl YOU. The Iotal cost of your purchase on
The cost of your credit as The dollar amount the to you or on your behalf. have made all scheduled;paymeal:L credit, including your downpayment
a yearly rate. credit will cost your
of $ GZ12.44
% 21222 CA as
SIMPLE INTEREST
to motor uahicle behtg
iat5 for:
e
55 ;
Y aa: N/A
for
t N/A I
?rd? M
Ammptt Fhancad
?- ,-.., .vt the-Co?Tiliti. ' . Q7ECTfi?1 eroeugt ?I the se?ateati9ctasnreanda>t..:-- ;. ,
i
Typo vl Dobt Cancellation Agreement Charge Signature
Guaranteed auto protection (GAP) $ T I want guarantees auto protection
N/A
- - -- --
Signature of Buyer
SIRC -1DNbN R1
A i l S 8Cl1 "AN1 NOT-RIMMED AS A WDtffNF THE G)li. The: air contract or warranty agreement miff ote
Draw" unless you sign the gaparate agreement with the. third party provider, who is not 'he Setlernamed above„ and agree to-pay the additional charge. This section does not apply to
any warranty that you may receive for which there is not a separate charge. _
ASSIQKE: We rand to sasionihis Contract and Security Agreement le the Assignee named in this. provision. It the Assignee assigns this Contract to a subsequent assignee, the term
'Alloignen" also rafets to such subWoeet =W m Alter the Wit; all<rights.and beneftof the fiefler in this- Contract. and in the Security Agreement shall belong to and be
emorceable by the Assignee 'ihiftfptee's namsAMAdd=iK Y&T CI D T iERVICES, LLC
Installment Loan
One Foun?taln' Plaza, P.O. Box 4005
Buffalo, New York 14240
W914111111. Any person signing the Co-Signer's Agreeivient below'promises separately and together with all Co-Signer(s)-and Buyer(s), to pay all sums due and to perlorm all agreemeM in
thiCEotitriC[.'Gii+wiMfTfMtyINfIMIAbt ?h.
CO-OWNER: Any person signing the Co-Owners. Security Agreement below gives us a.security interest in the Vehicle and agrees separately and together with all Co-Owner(s) and Buyer(s),
to perform all agreements in the 6ocurity Agreement and all other parts of this Contract except the 'Promise to Pay" section.
TERMS: The terms Wwwn in the bom above are part of this Contract
-PROMISETO FAY: You 3gr°69 to pay us the Total Sale Prim N the VeM* by pgtite Cash -unpaid under this Contra", gainst any -of your money on deposit with Assignee: This
Dvrmpeymint and'ossigningOn Trakin, d sliown abm on er boron the dole of ft Contract includes any mloney: wh(eh is now or may in the future be deposited with Assignee by you.
and paying ue the Amount Financed olds Finarn Charge. You `promise to Make payments in Assignee may do this wiEhout any prior notice to you.
the Pa Schedule. You promise to make payments on or bete the same ADDITIONAL DISCLOSURES MO TERMS AND CONDITIONS.
Which may
es: ..
Before signing this Contract, be sure that you receive and road the Dklinure
Ixtiorltc otlc ui tlic
skit. You *0 aurae to M rmeamatAe allerpoys' Mesa
co#gd amounts due under this Contract or to probed or get possession of the Vehicle, as Terms acrd L' :
permitted by applicable law. You agree to WM payments at the place orb sold payments to tollowingi which are additional p&M to and part of this Cont?aet
On mWrosa which the Assignao most rem* spoclies in the wribn notice to you. • This Contract continues on the reverse side.
SEBURITY'AGREEMENT: To secure the payment of all sums due and the perfom once of all ' Debt Cancellation (Guaranteed Auto Pmtection) separate disclosure and.-agrasmenti It
raquiNd ebligstiens under this Contract, you glue a security interest in the Vehicle, in all purchased as part of this Contract and disclosed above.
parts (called -accessions') attache to ttre Yehicle at any later time, and in any proceeds of THIS CONTRACT CONTINUES ON T14E ROOM SIDE. YOU ARE ODLFOATED TO ALL THE
the Vehicle, including inauranca proc4pds,:The racy set any !!!T is due and TERMS Of THE C014MTWHICH APPEAR ON THE FRONT AND RfYERSESIDES.
Tft M+
?
-?./i7?M[ PWUNAKO: ROD OW *r grft No'Se/tr,_ TJ* Saga may a 9Sn gig Colibatd and t*Wq %h rW to
metre a pan Of am ftowe c1largas:
TO BUYER-DO NOT SIGN THIS CONTRACT IN BLANK. YOU ARE
:D TO AN EXACT COPY OF THE CONTRACT YOU SIGN. KEEP IT TO
(SEAL) QdJD1d,LQB
eta
OW310KI: YOU 3NOULD READ Tiff NOTICE TO CO.516ft. NEW HAS BEEN GIVEN TO YOU ON A SEPARATE DOCUMENT, BEFW SIB U THE t 914111 NEWS AGREEMENT-
W214111th AGACtIll Nf. You, the person (or persona):signing below as 'Co-Sigrw," promise to fay to us aN sums due on this Cadract and to perform all ausen*ft ig ft Contix:t..
Tau intt#nd to ba WHY bound by all the terms of this Contract, separately and together, with the Buyer. You are making this promise io induce "mull this Cooba*t11W1ye;;filrfkir,
even though we will ux the proceeds only for the BuW3-bwcfit. You agree to pay even though we may not have made any prior demand for papodsa the BuyvA t
saeurify interest. You also acknowledge receiving a Fampiafed copy of this Contract ai
C"igrtar+a SigA lira
By aigning bulow, we agree to x1l the Vehicle to you under the terms of this Contract. - NOTIC
ENTITI
.:.
NO Not,
By.
gtlti•ER`-
Address am
00-O NNERI SECURITY AGREEMENT: You, the il?ple ale ?' S ? tfie Buyer or otbei*W being all of the Owners of the Vehicle, aft us a sneer inUh O in
the Vehicle ide,>tifiad shwa You site to be 1sruMii i11e1ws+s t1lE Aeieemewt*A all other parts of finis Contrxt except #w `Promise To Pay" section. You are giving us the
»y MIMI fe mduee Pit to 11101/111 it fellltraet va ilia ffuw. cad b secure the payment by the Buyer of all sums due on this Contract. You will not be responsible for any deficiency
am" mWit of an clam and safe of the Vehicle.
(SEAU
1 Ca-Owner ? signature 4 Address pate
1 ?
Ire 0117 * *010OWLEDGE "WEIPT OF A CO "MD-MY OF TOM
CONTRACT AT THE TIME OF SIGNING, INCLUDING THE ADDITIONAL DISCLOSURES AND PAGES LIST
ED IN THE
SECTION CAL?.ED ADDITIONAL DISCLOSURES, TERMS AND CONDITIONS.
6UYER BUYER CO-SIGNER GO-S#GNER OR GO-OWNER
I i FAIN WKMVLFDCDA IOA923e M117l1/M NOTICE, SFF OFVFRSF SInF FAO IYpAQTANT 111MIDNATIAN
EXHIBIT B
140
CUSTOMER #: 2492180
GEORGE R VOGT JR
1902 DOUGLAS DR
CARLISLE, PA 17013-1019
HOME:717-249-2180 CONT:N/A
RTTq . C'WT.T. "
46493
r PARSONS INTERSTATE FORD, LLC.
INVOICE 196 Walnut Bottom Rd.
Shippensburg, PA 17257
' Phone: 717-532-8888
Toll Free: 888-436-3673
PAGE 1
SERVICE ADVISOR: 1 7R T?n1:1PP ' MTT.T.-PP
COLOR YEAR MAKEIMODEL VIN LICENSE MILEAGE IN/ OUT TAG
WHITE 08 O MUSTANG VH 1 2 10184 10198 4
DEL DATE PROD: DATE' ' WARR'. EXP. PROMIS ED - PO NO. RATE PAYMENT INV, DATE
14APR08 D 24S P07 17:00 24 EP09 CA H 060CT09
R.O. OPENED READY OPTIONS: STK:900 DLR:09764
09:17 24SEP09
10:09 06OCT09 ENG:4.6L_3V
TRN:S-SPEED _OHC_V8_ENGINE
MANUAL TRANSMISSION
LINE OPCODE TECH TYPE HOURS LIST NET TOTAL
A CUST STATES HARD TO 'SHIFT FROM 18T - 2ND OCCAISIONALLY GRINDS WHEN
SHIFTING, SEEMS LIKE CLUTCH MUST BE FULL DEPRESSED AND SHIFT
VERY SLOW TO GET INTO GEAR I
CAUSE: VERIFY CUST CONCERN, CAR IS HARD TO SHIFT 1-2 3-4 AT TIMES,
REFER _TO'TSB 09-19-07, CONTACTED HOTLINE AND INQUIRED ABOUT
WHAT DIRECTION SHO
091917A REPL SYNCRO&BLOCKING RINGS PER TSB
6323 W94 (N/C)
1 1R3Z*7109*AA SNAP RING _ (N/C)
1 3R3Z*7107*AB KIT (N/C)
1 1R3Z*7107*BA RING - SYNCHRONIZER (N/C)
1 TA*29* SEALANT - SILICONE (N/C}
3 XT*5*QM FLUID -'TRANSMISSION (N/C)
FC: P01 42
PART#: 3R3Z*7107*AB
COUNT:
CLAIM TYPE:
AUTH CODE:
PARTS: 0.00 LABOR: 0.00 OTHER: 0.00 TOTAL LINE A: 0.00
10184 BLOCKER RINGS VERIFY CUST CONCERN, CAR IS HARD TO SHIFT 1-2
3-4 AT TIMES, REFER TO TSB 09-19-07, CONTACTED HOTLINE AND, INQUIRED
ABOUT WHAT DIRECTION SHOULD BE TAKEN SINCE TSB 08-09-06 WAS PREVIOUSLY
PERFORMED. HOTLINE ADVISED TO REMOVE; TRANSMISSION AND INSPECT, INSTALL
UPDATED PARTS FROM LATEST.TSB 9-19-7. INSTALL NEW UPDATED BLOCKING
RINGS 1,2,3,4. SERVICE FLUID. ROAD TEST,'OPERATING NORMALAT THIS TIrE.
ROAD TEST BY S/M OPERATING NORMAL AT THIS TIME.
Any warranties on the item/items sold hereby are those made by :the; manufacturer. The seller hereby
expressly disclaims all warranties, either express or implied, including any implied warranty of merchantability
or fitness for a particular purpose and neither assumes nor authorizes any other person to assume for it any
liability in connection with the sale of this itemlitems.
CUSTOMER SIGNATURE X
DESCRIPTION TOTALS
LABOR AMOUNT -
PARTS AMOUNT
GAS, OIL, LUBE
SUBLET AMOUNT
MISC. CHARGES
TOTAL CHARGES
LESS INSURANCE
SALES TAX
CUSTOMER #: 2492180
GEORGE R VOGT JR
1902 DOUGLAS DR
CARLISLE, PA 17013-1019
HOME:717-249-2180 CONT:N/A
RT74 • r:r T.T. .
46493
PARSONS INTERSTATE FORD, LLC.
INVOICE 196 Walnut Bottom Rd.
Shippensburg, PA 17257
Phone: 717-532-8888
Toll Free: 888-436-3673
PAGE 2
SFR\/I('F An\/IC()R•
COLOR YEAR MAKE/MODEL VIN LICENSE, . y `MIL AGE IN/ OUT TAG -
T 8 F Hl 51 2 10184 10198 4
DEL DATE PROD. DATE ' WARR EXP. PROMISED PO NO. RATE PAYMENT INV. DATE
14APR08 D 24SEP07 17:00 24SEP09 CASH 060CT09
R.O: OPENED READY OPTIONS: STK.-900 DLR : 0 9 7 6 4
09:17 24SEP09
10:09 060CT09 E
TRN:5-SPEED E
MANUAL TRANSMISSION
LINE OPCODE TECH TYPE HOURS LIST NET TOTAL
YOU WILL BE RECEIVING 'A SURVEY FROM `FORD IF
YOU ARE UNABLE TO STATE COMPLETLEY SATISFIED
PLEASE CONTACT THE SERVICE MANAGER WITH ANY
QUESTIONS OR CONCERNS
THANK YOU,
BOBBY MILLER
Any warranties on the item/items sold hereby are those made by the manufacturer. The seller hereby
expressly disclaims all warranties, either express of Implied, including any implied warranty of merchantability
or fitness for a particular purpose and neither assumes nor authorizes any' other person to assume for it any
liability in connection with the sale of this item/items.
CUSTOMER SIGNATURE X
DESCRIPTION TOTALS
LABOR AMOUNT 0.00
PARTS AMOUNT 0.00
GAS, OIL, LUBE 0. 00
SUBLET AMOUNT 0.00
MISC. CHARGES 0.00
TOTAL CHARGES 0.00
LESS INSURANCE 00
SALES TAX 0.00
PLEASE PAY
TLl1[• 1111p AIt111T
_.
.0 41-
CUSTOMER #: 2492180
GEORGE R VOGT JR
1902 DOUGLAS DR
CARLISLE, PA 17013-1019
HOME:717-249-2180 CONT:N/A
DtTO f1VT T .
45420
PARSONS INTERSTATE FORD, LLC.
*INVOICE* 196 Walnut Bottom Rd.
Shippensburg, PA 17257
li Phone: 717-532-8888
Toll Free: 888-436-3673
PAGE 1
SERVICE ADVISOR: -7a A(1T2Fi?T MTT.T.FR
COLOR YEAR MAKE/MODEL. VIN LICENSE MILEAGE IN/ OUT TAG
WHITE 08 D MUSTANG GT Z T 5 4
DEL DATE PROD. DATE WARR. EXP. PROMISED PO NO. RATE PAYMENT INV. DATE
14APR08 D 24SEP07 17:00 15JI,Trd09 CASH 18JUN09
R.O. OPENED READY OPTIONS: STK:900 DLR:09764
07:20 15JUN09
109:06 18JUN09 I ENG:4.6L3VOHCV8ENGINE
TPM:5-SP-EED-MAI?-UAL-TRANSMISSION
LINE OPCODE TECH TYPE HOURS L1S'1' Nla'1' 1'U'1'AL
A CUST STATES GRINDS BETWEEN 1ST AND 2ND GEARS
CAUSE: 9081 VERIFY CUST CONCERN, CHECK OASIS, FOUND NO RELEVANT TSBS OR
SSMS. UNHOOK 'SHIFTER, FOUND TIGHT SPOT IN SHIFTER, REPLACED
SHIFTER, ROAD
7210A GEAR SELECTOR LEVER - REPLACE (7210.) - L
6323 W94 (N/C)
1 8R3Z*7210*AA HOUSING ASY - GEAR SHIFT (N/C)'
FC: N18 42
PART#: 8R3Z*7210*AA
COUNT:
CLAIM TYPE:
AUTH CODE: v
PARTS: 0.00 LABOR: 0.00 OTHER: 0.00 TOTAL LINE A: I „i
11fLOty j
1
/
r
(
9081 VERIFY CUST CONCERN, CHECK OASIS, FOUND NO RELEVANT TSB'S OR .
SSMIS. UNHOOK SHIFTER, FOUND TIGHT SPOT IN SHIFTER, REPLACED SHIFTER, '-? ? t
ROAD TEST, OPERATING OK AT THIS TIME.
B CHANGE OIL AND FILTER, RESET OIL REMINDER 4&
LOF CHANGE OIL AND FILTER, RESET OIL REMINDER
6323 CR 13.45 13.45
1 FL*820*S FILTER'ASY _ OIL 9.05 9,05 9.05
6 OIL1 5W20 3.00 3.00 18.00
PARTS: 27.05 LABOR: 13.45 OTHER: 0.00 TOTAL LINE B: 40.50
9081 PERFORM OIL AND FILTER CHANGE
C PERFORM MULTI-POINT INSPECTION
M99P PERFORM MULTI-POINT INSPECTION
6323 CR 0.00 0.00
PARTS: 0.00 LABOR: 0.00 OTHER: 0.00 TOTAL LINE C: 0.00
Any warranties on the item/items sold hereby are those-.made by. the manufacturer. The seller hereby
expressly disclaims all warranties, either express or implied, including any implied warranty of merchantability
or fitness for a particular purpose and neither assumes nor authorizes any other person to assume for it any
liability in connection with the sale of this item/items.
CUSTOMER SIGNATURE X
DESCRIPTION TOTALS
LABOR AMOUNT
PARTS AMOUNT
GAS, OIL, LURE
SUBLET AMOUNT
MISC. CHARGES
LESS INSURANCE
SALES TAX
PLEASE PAY
THIS AMOUNT
? w
'-USTOMER #: 2492180
3EORGE R VOGT JR
1902 DOUGLAS DR
2ARLISLE, PA 17013-1019
HOME:717-249-2180 CONT:N/A
45420
me PARSONS INTERSTATE FORD, LLC.
196 Walnut Bottom Rd.
*INVOICE* Shippensburg. PA 17257
Phone: 717-532-8888
Toll Free: 888-436-3673
PAGE 2
CPR\/Irr- An\/ISC1R• -1 -70 Dn=-VD r MTT.T.VD
DUO COLOR YEAR MAKE/MODEL VIN LICENSE ' MILEAGE IN/ OUT TAG
WHITE
DEL DATE 081 FOR MUSTANG
PROD. DATE WARR. EXP. 1ZVHT82H1 1 2 1 9085 IT9081
PROMISED PO NO. RATE PAYMENT iNV. DATE
14APR08 D 24SEP07 17:00 15JUN09 CASH 18JUN0
R.O. OPENED READY OPTIONS: STK• 900 DLR- 09764
07:20 1SJUN09
09:06 18JUN09 ENG:4.6L_3V_OHC_V8_ENGINE
TRN:5-SPEED MANUAL TRANSMISSION
LINE OPCODE TECH TYPE HOURS L1?'1' fvr r rvlti,,
CUSTOMER PAY HAZ WASTE/SP CHG FOR 'REPAIR ORDER 4.00
YOU WILL BE RECEIVING A SURVEY FROM FORD IF
YOU ARE UNABLE TO. STATE COMPLETLEY SATISFIED.
PLEASE CONTACT THE SERVICE MANAGER WITH ANY
QUESTIONS OR CONCERNS
THANK YOU,
BOBBY MILLER ,
DESCRIPTION TOTALS
Any warranties on the item/items sold hereby, are those made bby- the manufacturer, The seller hereby
bili
' LABOR AMOUNT
13
45
ty
including any implied warrant of merchanta
expressly disclaims all warranties, either 'express or implied, .
or fitness for a particular purpose andv neither assumes nor 'authorizes any other person to assume for it any PARTS AMOUNT 2 ] , Q 5
liability in connection with the sale of this item/items: .
GAS, OIL, LUBE
0 .00
SUBLET AMOUNT 0.00
CUSTOMER SIGNATURE X MISC. CHARGES 4.00
TOTAL CHARGES 4 4 , 5 0
LESS INSURANCE 0.00
SALES TAX 2.67
PLEASE PAY
THIS AMOUNT A 7 1'7
l
CUS'J OMER #: 2492180
GEORGE R VOGT JR
1902 DOUGLAS DR
CARLISLE, PA 17013-1019
HOME:717-249-2180 CONT:N/A
BTTS - !'T: T.T. .
11,
41868
0m, PARSONS INTERSTATE FORD, LLC.
*INVOICE* 196 Walnut Bottom Rd.
Shippensburg, PA 17257
Phone: 717-532-8888
DUPLICATE 1 Toll Free: 888-436-3673
PAGE 1
COLOR
YEAR
MAKE/MODEL - - - _ -_ - -- -. ..
VIN -.. r 0 itVDG
LICENSE A.L i•111jLL't[
MILEAGE INI OUT >
TAG
WH D M (7 GT. 1 TE2H 8 2
DEL DATE PROD.'DATE WARR. EXP. PROMISED PO NO. RATE PAYMENT INV. DATE
14APR08 D 24SEP07 WAIT 2_)JU%LQ1! l CASH 2 JUL08
R.O. OPENED READY OPTIONS: STK:900 DLR:09764
ENG:4.6L
3V OHC V8 ENGINE
08:42 09JUL08 09:02 25JUL08 _
TRN:S-SPEED MANT7AT, TRAMgMTg.gTnNT
LINE OPCODE TECH TYPE HOURS LIST NET TOTAL
A CUST STATES OIL LEAK
CAUSE: 2143 VERIFY CUSTOMERS CONCERN, DIAG OIL LEAK AT REAR OF ENGINE.
CHECK TOP OF ENGINE FOR OIL LEAK, NO LEAKS FOUND. OIL DRIPPING
OFF OIL PAN
6007D ENGINE OIL LEAKS DIAGNOSIS - L
3783 W94 (N/C)
1 164*R3705* ROTUNDA GAS ENG. OIL DYE (N/C)
2 WA*9* TIE WIRE & CAB (N/C)
6701A SEAL CRANKSHAFT REAR MAIN (FULL CIRCLE
TYPE) - REPLACE (6701) - L
3783 W94 (N/C)
1 F6AZ*6310*AB SLINGER (N/C)
1 F4AZ*6701*A SEAL ASY - CRANKSHAFT OIL (N/C)
FC: L65 42
PAR-#: F4AZ*6701*A
COUNT:
CLAIM TYPE:
AUTH CODE:
PARTS: 0.00 LABOR: 0.00 OTHER: 0.00 TOTAL LINE A: 0.00
2143 VERIFY CUSTOMERS CONCERN, DIAG OIL LEAK AT REAR OF ENGINE.
CHECK TOP OF ENGINE FOR OIL LEAK, NO LEAKS FOUND. OIL DRIPPING OFF OIL
PAN, CHECKED ALL OIL PAN BOLTS FOR TIGHTNESS, ALL OK. CLEAN OIL OFF I
ENGINE OIL PAN, INSTALL OIL DYE IN ENGINE OIL, RUN ENGINE: RUN OASIS,
AND CHECK FOR TSB OR SSM, NONE FOUND. GAVE CAR BACK TO CUSTOMER TO
DRIVE FOR A FEW DAYS AND ADVISE CUST TO BRING IT BACK IN FOR A RECHECK.
CUST RETURNED CAR, REVERIFY CUST CONCERN, OIL LEAK AT REAR OF ENGINE,
RECHECK TOP OF ENGINE FOR OIL LEAKS, NO LEAKS FOUND, RECHECK OIL PAN
BOLTS FOR TIGHTNESS, ALL OK. CHECK WITH BLACKLIGHT AND FOUND OIL TO BE
COMING FROM REAR OF OIL PAN AREA. REMOVED TRANS,CLUCTCH,AND
FLYWHEEL,FOUND REAR MAIN CRANKSHAFT OIL SEAL TO BE LEAKING, VERIFIED
WITH BLACK LIGHT. REMOVE UND REPLACE OTL SEAL AND SLEEVE. CLEAN
Any warranties on the item/items- sold hereby are those made by the manufacturer. The seller hereby OESCRIP7101
expressly disclaims all warranties, either express or implied, including any implied warranty of merchantability LABOR AMOUNT
or fitness for a particular purpose and neither assumes nor authorizes any other person to assume for it any
liability in connection with the sale of this item/items. PARTS AMOUNT
GAS, OIL, LURE
CUSTOMER SIGNATURE X
SUBLET AMOUNT
MISC. CHARGES
TOTAL CHARGES
LESS INSURANCE
SALES TAX
PLEASE PAY
J_
CUSTOMER #: 2492180
GEORGE R VOGT JR
1902 DOUGLAS DR
CARLISLE, PA 17013-1019
HOME:717-249-2180 CONT:N/A
RTTq . (PT.T. .
1
41868
PARSONS INTERSTATE FORD, LLC.
*INVOICE* 196 Walnut Bottom Rd.
Shipp4nsburg, PA 17257
Phone: 717-532-8888
DUPLICATE 1 Toll Free: 888-436-3673
PAGE 2 t
SFRi/IrF Anvi-qoR• ,
COLOR YEAR MAKE/MODEL VIN LICENSE' MILEAGE IN/ OUT TAG
WHITE T T82H18SI41862 2143 2155 T914-4
DEL DATE PROD: DATE WARR. EXP. PROMISED PO NO. RATE PAYMENT _INV. DATE
1 APRO D 24 P07 WAIT 25JUL00 CAS 25JUL08
R.O. OPENED READY OPTIONS: STK: 900 DLR• 09764
08:42 09JUL08
109:02 25JUL08 ENG:4.6L_3V_OHC_V8_ENGINE
TRN_:5-SPEED MANUAL TRANSMISSION
LINE OPCODE TECH TYPE HOURS LIST NET TOTAL
AND TOPPED OFF. ROADTEST VEHICLE, RECHECK FOR OIL LEAKS, NONE FOUND AT
THIS TIME.
B CUST STATES BULB IS OUT
CAUSE: 2143 VERIFY CUST CONCERN, LF,GRILLE BULB IS OUT, ORDERED NEW
BULB. R&R BULB AND LIGHT ASSY. RECHECK ALL LIGHTS, ALL OK AT
THIS TIME
13465A BULBS-EXTERIOR - REPLACE (13465/13466) - L
3783 W94 (NIC)
1 XL3Z*13466*AA BULB (N[C)
15200A FOG LAMP ASSEMBLY' REPLACE (15200) L
3783 W94 (N/C)
1 4R3Z*15200*AB LAMP ASY - FOG FRONT (N/C)
FC: L26 46
PART#: XL3Z*13466*AA
COUNT:
CLAIM TYPE:
AUTH CODE:
PARTS: 0.00 LABOR: 0.00 OTHER: 0.00 TOTAL LINE B: 0.00
2143 VERIFY CUST CONCERN, LF GRILLE BULB IS OUT, ORDERED NEW BULB.
R&R BULB AND LIGHT ASSY. WHEN REMOVING BULB, THE METAL REFLECTOR FELL
OUT OF PLACE, SINCE ITS A SEALED ASSEMBLY THERE WAS NO WAY TO REATTACH
IT, ORDERED NEW LAMP ASSY. R&R FOG LAMP ASSY. RECHECK ALL LIGHTS, ALL
OK AT THIS TIME.
C PERFORM MULTI-POINT INSPECTION
M99P PERFORM MULTI-POINT INSPECTION
3783 CR 0.00 0.00
PARTS: 0.00 LABOR 0.00 OTHER: 0.00 TOTAL LINE C: 0.00
2143 PERFORM MULTIPOINT INSPECTION.
Any warranties on the item/items sold hereby are those made by the manufacturer. The seller hereby DESCRIPTION
expressly disclaims all warranties, either express or implied, including any implied warranty of merchantability
or fitness for a
articular
ur
s
d
ith LABOR AMOUNT
p
p
po
e an
ne
er assumes nor authorizes any other person to assume for it any
liability in connection with the sale of this item/items. PARTS AMOUNT
GAS, OIL, LUKE
CUSTOMER SIGNATURE X SUBLET AMOUNT
MISC
CHARGES
.
TOTAL CHARGES
LESS INSURANCE
SALES TAX
r
CUSTOMER #: 2492180
GEORGE R VOGT JR
1902 DOUGLAS DR
CARLISLE, PA 17013-1019
HOME:717-249-2180 CONT:N/A
BUS : rRT.T.
I'
41868
PARSONS INTERSTATE FORD, I.I.C.
*INVOICE* 196 Walnut Bottom Rd.
Shippensburg, PA 17257
Phone: 717-532-8888
DUPLICATE 1 Toll Free: 888-436-3673
PAGE 3
SERVICE ADVISOR- , '74 r)nDL'DT MTT T LSD
COLOR YEAR MAKE/MODEL VIN LICENSE r MILEAGE IN/ OUT TAG
WHITE 8 FO MUSTANG T 1 2 2143
DEL DATE PROD. DATE WARR, EXP.' PROMISED PO NO. RATE PAYMENT' INV. DATE
14APR08 D 24SEP07 WAIT 5JUL03 CASH tSJUI-0
R.O. OPENED READY OPTIONS: STK : 9 0 0 DLR : 0 9 764
08:42 09JUL08
09:02 25JUI,08 ENG:4.6L_3V_OHC_V8_ENGINE
TRN:5-SPEED MANUAL TRANSMISSION
LINE OPCODE TECH TYPE HOURS LIST NET TOTAL
D** TAP PROGRAM
CAUSE: 2155 PROVIDE CUSTOMER NO CHARGE LOANER. 3 DAYS
TAP PROVIDED CUSTOMER WITH NO CHARGE LOANER
9999 W94 (N/C)
FC: A99 51 PART#: COUNT: -
CLAIM TYPE: TAP
AUTH CODE:
PARTS: 0.00 LABOR: 0.00 OTHER: 0.00 TOTAL LINE D: 0.00
2155 PROVIDE CUSTOMER NO CHARGE LOANER. 3 DAYS
****************************************************
YOU WILL BE RECEIVING A SURVEY FROM FORD IF
YOU ARE UNABLE TO STATE COMPLETLEY SATISFIED
PLEASE CONTACT THE SERVICE 14MAGER WITH ANY'
QUESTIONS OR CONCERNS
THANK YOU,
BOBBY MILLER
Any warranties on the item/items sold hereby are those made by the manufacturer. The seller hereby
expressly disclaims all warranties, eithei express or implied, including any implied warranty of merchantability
or fitness for a particular purpose and neither assumes.nor authorizes any other person to assume for it any
liability in connection with the sale of this item/items.
CUSTOMER SIGNATURE X
DESCRtP710N TOTALS
LABOR AMOUNT 0.00
PARTS AMOUNT 0 . 00
GAS, OIL, LUBE 0.00
SUBLET AMOUNT 0.00
MISC. CHARGES 0.00
TOTAL CHARGES 0.00
LESS INSURANCE 0.00
SALES TAX 0,00
PLEASE PAY
Q
ii M
Tl ?c??,'v?'"lAY
1019 NOY -2 Fh 3: 35
N
$178.50 piD ATrq
Co aa8rjv
u*Cnam
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
George Vogt,
Plaintiff,
VS.
Ford Motor Company,
Defendant.
CIVIL DIVISION
NO.: 09-7572
PROOF OF SERVICE
Filed on behalf of Plaintiff.
George Vogt
COUNSEL OF RECORD FOR THIS PARTY:
Robert A. Rapkin, Esquire
Identification No. 61628
KIMMEL & SILVERMAN, P.C.
30 East Butler Pike
Ambler, PA 19002
(215) 540-8888
a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
George Vogt, CIVIL DIVISION
Plaintiff,
V.
Ford Motor Company,
Defendant.
TO THE PROTHONOTARY:
No.: 09-7572
PROOF OF SERVICE
Service of the complaint regarding the above captioned matter was made to Ford Motor
Company, Office of the Secretary, One American Road, 10th Floor Dearborn, MI 48126, on
11/05/09, via U.S. First Class Mail, Certified /Return Receipt Requested. A representative of
Defendant signed the return receipt on 11/12/09, a copy of which is attached.
KIMMEL & SILVERMAN, P.C.
Robert A. Rapkin, Esquire
Attorneys for Plaintiff(s)
30 East Butler Pike
Ambler, PA 19002
(215) 540-8888
7, WY
L f!7 7 K i-., , ?1 o f i L ? ,3 ? i n• "'
4 0u
1J
¦ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece, NA
or on the front if space permits.
1. Article Addressed to:
A. Signature
BOWES ? Agent
`X ?eu-e?,yypt ?0YV ES ? Addressee
olew to Delivery
PRRV Gil
ivery add differentfro m Rem 11 ? Yes (s
__i?' & J ter del .ad26,za hninw, ? No
Ford motor Company
Office of ti>e Secretary Floor
One American Road, 10th a Service Type
Mal
l o Dress Mail
Dearborn, N 1 49126 An
istered Olietum Recelpt for Merchandise
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? yes
2. Article Number 7009 0960 0000 (Transfer from service label) - 3 3 9 6 8 516
Ps Form 3811, February 2004 Domestic Return Receipt -••+a...95-02-M-1540
GEORGE VOGT, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS. NO. 09-7572 CIVIL
FORD MOTOR COMPANY,
Defendant
ORDER
AND NOW, this F r day of December, 2010, the appointment of a Board of
Arbitrators in the above-captioned case is VACATED. Vicky Ann Trimmer, Esquire,
Chairman, shall be paid the sum of $50.00.
ick Ann Trimmer, Esquire
Y
Court Administrator --- C Iken l
:rlm
?? y
BY THE COURT, f ?lI Q / !C)
t=yyl
Kevin ess, P. J.
o n
rn p M-n
my rrn -u
,r rn
00
--<>
r- ? Co `aQ
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A o
yc "
N Z c?
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
George Vogt
CIVIL DIVISION
Plaintiff, NO.: 09-7572
vs. PRAECIPE TO SETTLE,
DISCONTINUE AND END
Ford Motor Company,
Defendant. Filed on behalf of Plaintiff:
George Vogt
Counsel of Record for this Party:
Craig Thor Kimmel, Esq.
PA I.D. No.: 57100
-' Ln
C Cn i
ciQ -.-
?Cn .
U-= Q. ?<
czx
w
fn
Robert A. Rapkin, Esq.
PA I.D. No.: 61628
KIMMEL & SILVERMAN, P.C.
210 Grant St., Suite 202
Pittsburgh, PA 15219
(412) 566-1001
IN THE COURT OF COMMON PLEAS OF Cumberland County, PENNSYLVANIA
CIVIL DIVISION
George Vogt
Plaintiff,
vs.
Ford Motor Company,
Defendant.
NO.: 09-7572
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above-captioned matter as settled and discontinued.
Respectfully submitted,
0
Robert A. Ra n, Esquire
KIMMEL & LVERMAN, P.C.
Attorneys f4 ,Plaintiff
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the within Praecipe to Settle,
Discontinue, and End was served on December 7, 2010, via U.S. Mail and facsimile,
receipt confirmed, to:
James P. Peterson
Dobis, Russell & Peterson P.C.
326 South Livingston Avenue
Livingston, NJ 07039
973-740-2474
Robert A. Rapki Esquire
KIMMEL & SI ERMAN, P.C.