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HomeMy WebLinkAbout10-0685MAURICE & 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 REQUA2EIa., Attorneys for Plaintiff 1-1))'/89-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. RICHARD L WEBBER 76 N High St Newville, Pa 17241 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. l0 - (c$5 o'?v? l le-rrr`r1 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 Is come. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de Is fecha de Is demands y Is notificacion. Hace falta asentar una comparencia escrita o en persona o can un abogado y entregar a Is corte en forma escrita sus defensas o sus objeciones a las demandas en contra de so persona. Sea avisado que si usted no se defiende, Is corte tomara medidas y puede continuar Is demands en contra suya sin previo aviso o notificacion. Adernas, Is corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. SI NO TIENE ABOGADO O St NO TIENE EL DINERO IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SURCIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO O LLAME POR TELEFONO A LA OFiCINA CUYA DIRECCION FIND OUT WHERE YOU CAN GET LEGAL HELP. SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION O Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 AR-co PI) ATW CL# N77b 9.T11 01SC0890 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. RICHARD L WEBBER 76 N High St Newville, Pa 17241 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. CIVIL ACTION COMPLAINT 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, Richard L Webber, is an individual who resides at 76 N High St Newville, Pa 17241. 3. At all times relevant, the Plaintiff was in the business of loaning money on motor vehicle installment sales contracts, including but not limited to the note signed by Defendant(s), hereinafter more fully described. 4. On or about April 8, 2008, 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 $31918.38 at an annual percentage rate of 3.900%, in order to purchase a certain motor vehicle, 2008 Ford F-150 more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A. 5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $408.59 for a period of 72 months until the loan was paid in full all as is more fully set forth in the Contract. 6. Defendant(s) made monthly payments until February 23, 2009, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 7. As a result of the default by Defendant(s), and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant(s) giving the Defendant(s) the opportunity to redeem the Vehicle as well as notice of the sale date. A copy of the notice of repossession and notice of sale date are attached and marked as Exhibit B. 8. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at auction with a credit given to the Defendant in the amount of $17800.00, however a balance of $7189.96 is still due and owing, and a notice of the deficiency balance was sent to the Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C. 9. Pursuant to the terms of the contract, Defendant is required to pay all amounts due and owing, including any balance that may remain after the sale of the vehicle, and the Defendant failed to do so, thereby in default of the Contract. 10. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to $195.90 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $7385.86. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $7385.86, 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: January 22, 2010 Respectfully submitted, 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: January 22, 2010 PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALLMENT CONTRACT DATE _ 11410R/2008 1-880727-7008 ?BUyeCr a(bW Co-Buynl Name altl erect (MpudnN Couny pb 9ELLERICNEdTea (Baler Nxrr aid AMw) RICHARD L UEBBER JR. MCCAFFERTY FORD 76 M HIGH ST 6320 CARLISLE PIKE NEUVILLE PA 172411123 MECHANICSBURG PA 17050 ?y .« axar.n, rw th Pumntaad O Apbasxsl ITEMIZATION OF AMOUNT FINANCED INSURANCE t. Cash Price ...... ....... _.------- _._. ........ ....... . YOU ARE REQUIRED TO INSURE THE ._....._._.__......__... s26422.go (f) VEHICLE. YOU MAY OBTAIN VEHICLE 2. Dews Payment INSURANCE FROM A PERSON OF Third Parry Resale Aaslprad to Salmr........... .... _.......... _.3 g YOUR CHOICE Cash Down Payment.......... __•_....... ......._._.._.___.......__.__....3_._gltA Trade-in 3?_,,ff?/(( fl? LIABILITY INSURANCE COVERAGE ram em aleka s Gm AYOwwca 3 Amanq Owvq FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS IS NOT Total Daayn Payment .......................................................... f J{00.00 (2) INCLUDED. 7. UnPaa Salem of Cash Price (1 maws 21 ._._........................ S 21922-01)(3) 4. Amounts paid an your bslwf (Seiler may he r. WYng a Pomen of dleae .meum) CREDIT LIFE, CREDIT DISASUM AND To Public Officials OTHER OPTIONAL INSURANCE ARE (D 1., license is 10.00 1, tine Is 22 50 a NOT REQUIRED TO OBTAIN CREDIT AND WILL rapmtration(f 51.00 Llose s 113.50 YOU SIGN A DBAGREITEDPAUYLTTHE pU for filing fees $ 5.00 PREMIUM. (iin for cases trot M Cash Pace) f 1477. 60 3 1501.10 Credit To fi-- Companlee W: O Lffe ' Crack Ufa 4uuram (for Cerro of cmxad) .__.._..__ a MIA /+ Irls+lrerlce ^DerlY Credit ObaMmy Iralaanee (far term of Corctr11C0.. .......... s N/A $ , n M/A (Term II/A m_ftl..__._s N/A Premium Isurad (Ttron To /N far GAP WAIVER )It ulp Vpu ward Credit Ufa Msuranta. It c8a To 141A IA for N/A a_ NIA To N AFF RTY FORD for 00r FE i c 00/0tlI OF Inn 4{ To 118 for f elil To Srpns To N/A forf N/A To N/A for N/A Tom[..._._.__._ s 111A ._._...__.._......_.__._.__._.__..._..._..__..._ ___._.?._a 7229 c{ (4) crew Sgnc 3. Amount Financed (3 P. !)_....___..___...__.. _..3 7AI S1 {{ (sl CroNt Disability ",'A FEDERAL TRUTHJNIENDING C"CLOSIRtES 3 InMNartce Company ANNUAL FINANCE Amount Total of Total Sale Pramfun -h-red(a) PERCENTAGE CHARGE Fira no d Paymards Price You went C.& Disability lfeurellCe. RATE Tla., crams TM are d Tla snows, Tns taw mm The coact yea 1M cads .0 prmldae ma wan neve a Your pacr«e asst « e y«dy w. alp to You or m °as alien you asst, l'oirt cases, acaclwiscl danMwyrnem Buyer Signs saylranis w e 7cnn nn Vier OTHER OPTIONAL INSURANCE Coyeraga and Premh« orb 72 Msurarna CTerm n Month fl/A $ 'vu By ll/A n/A Pm«ys em: n you pry oN your dept eery. you will tat tam b per a paraly. S.wdy mrert: you are ItmM.-y ..resat n eb wore Wins ou ch d. 7IA s-?1f?'r Lars Parmam: y_;-' b Is «m?1Panbn or asm Press I nol mats man 10 arya W. In. drarwiszo Par«nld Ms BY R., NIA cem , va cs e« ma mmraoc Ica aesamal klbrrrrnan on aaariy anmL nmpaynrn4 tlwesun. ma te1N to rpWm npaPranc d yew Net b Mc Mlo,a ma adorns.. lien. and you wen the apbaral it-- ts for v4AM pmpa= Many prenalm9 tare kldudee above. If you "o not meet your contract obligation, you may lose your vehicle, se, well as both Pans and gooos put of your vehicle and money or goods received far your vehicle. Boyar Son ? Vow all as"ohnenl Palmer's under lids Centred is e bs,bon paymerm. Co4hyer Sq. EXOEBB WEAR USE AND MILAOE CHARGES Cr.dt Lee and Crach canny instance en r the boa directly escorts is cracked, Mi. nolism, Pa of Paragraph C of far the rrn or me cmm«s Tine amormt aid this coma) apply. You may be O urged br mcas id amar been talon ote a Nrltlat dc covenal'ar am elbwi me nou« er graw«m for norms, user it you exercise ass Option to MN mN hicle ve back to SaWr e we r pl«n b you eery. namprapn B. yeu muu pay the Ses4ar $0. It /A MI Term for each mots in etce6s 1 d/p m4N enmwl on the Womsear. Rte. yy/yaw canealbb« wehw Addeate r IoPtww) EJRRA MILEAGE OPTION CREDIT a °i1i tiD1 is d1NA'a° wv r«a prxdaaee n lip raronwipn carer. Pucnasa d lib aAarape is Ir Mo metre I comeam s belsbn payment (lie indicated above), and you have Wow and w".4 W b eewn oa a_ TM Warned ya„ Option to nil Net, VaNde b ft SaNw under Paragapn S. this came rw mndam.dwdaMenbaeetim ws,«r Para9rmh applies 10 your Wnsact. At 0a aCMdulad and of an Contract, You so lib awl In me shored Adamstown laesl+ W smr aweeim es mnNeacrmijl Ol$0. 0/? Per walaad "We for the number of unused m4« p a s caw TM pee Wtla can tanaegMweher.- ThHd. far ittam sellorm.o ban- NlA and __Nj° mime, b cry announce you e corrosion d Amami Ramon u oa, sapEoo a owe under the COnsacl. You will not recalw any aadN if me vehicle is d8srayed, this . • or you are IT "emus. You 'AN tad reoehra any made N the credit is :l - / I 2,_.__ m« then ,pp, m Spm NON-MODIRCATION DISCLOSURE Any comp. n Iles aaerw/s rod Dos, wn.a an.pad or you ere tlro Beam. Bwm?-_ '1 % 2 _ , c X oauyw uyer (and Co-Buyer) acknowledge that (1) before signing this contract, Buyer (and Co-Buyer) acefved end reviewed a true and completely filled In copy of this Contract and (RI) at the time fN gning this contract, Buyer (and Co-Buyer) received a true and completely filled In copy of this ontrac .(/`? C ry rrr _ '__ /L ORIGINAL M ,?'u'? " ---r BEE OTHER ape FOR AcomONAL AGREEMENTS ADDITIONAL AGREEMENTS A. Peymanta and summary Notice; You must make all pay- ments in U.S. funds when MY are des. You may prepay your debt Many time withoul penally- Thiele a simple illiberal contract. The actual fahance charge you agree o levy will depend on your Payment patterns. The ...at anance charge may excises IN d Wpeed Flrarlw Charge if you make Your Payments later than Hhe ed"Md tlates or in lea than dre aNdulad amount. Your payment will be apPlbd first o the earned and unpaid part Of the Fmence Charge and men to the unpaid Amount Fin.M,.d. The Fkence Charge is eerhed by applying tat Annual Percentage Rate b iM unpaid Amount Fawned lor the .dual time that the unpaid Amounl Finathced is plalanding. If IM vehxle is repos sassed. You "it not have the fight to reinsbb IM loitered urwm the "I., egress. B. Balloon Pay ma Contracts: If Your last insallmore Payment under this contract is . balloon Payment as Indicates on the front of the contract, YOU MY handle the last instalknent Payment in one of three ways. FIIat, you MY Pay all that YOU owe when the al met.1hr nl payment . due and keep your fiord, vehicle. Second You may refirence the sal installment payment unless you $a m default under this contract. It the Sefbr Miss advanced funds to one any defeull. you muef Pay beck the Belief bailee the refinancing. You also must Provide prod ot insurance acwpt- ble to 3elbr before IN refinancing. TM Annual Percohage pate (APR) for the refiandng will be me low, of tat APR agreed to by YOU and lea Seller at the time ot the refinandng or me memmum file permitted by law. The term of the referencing will be bewtl m the Morin ro1nMlded, the rate, and the amount of IM monthly payment. The reffnanuad monthly Payment shall be Ihe soma as m this clefil n IN neatened emoum will be fully Pied wlthm 3s rrh0rd16 d me due clot, of the fast Incallmem Payment. Otherwise ms monlNy Paymwt amount efan be the mount ne clod to hilly pay IM refiheroed .mount within 35 menthe d Nhe the Ms of IM lost kwbllmenl payment. H you wish o ra5nancs. YOU must notay, she sdar In wmkg. Exmpl as diecussad in this section. the notice must be recalved no later than 30 it"Phor to the due dab of the last kwallment payment. Third, you may sell iM vahide to IN Sailer for an amount equal Io tat ant h rtadmenl payment. You MM pay to the SaWr any Other amomt Owed uroar Ilia COMM Ar "' you owe will M bawd, a pan, m the Who a mileage. YOU Mw Inver pay Ic Ihe Sauer the ebllnlaled pea Ot all repaw o the vehicle that are IM room d -costa wear and we, ss Bet forth below. You must .it. the Wade to a Pam Waclod by the Seder for inspection M at,, than 15 days prior to the ant imesi ment payment due tab. AMr tat inspection, 11 you dedda ro loan the Wide to me Sslbr, you must give the vehicle to me Seder no alp, man Pre last kl llrhent Payment due date. Al the, tone, you must ebo D. the Selby a ON. which ahom he lien. Omer than IN Sellers Fen, lrerefamnq -.hip o the Steer Pr a Derecn selected by M Swan. Ape, IM mipamon, d you tlecitle rim to 0811 Vehicle to rid s.wI. you must Immedately woad Me Seller and Inform this Seer whirl you want to refinance tat last matallment Paymuent. C- Damage Rstalr. pay your test irlnesmest paymen tet m0er cob con Vacl is a besoon ment and YoU sell ma vesicle hack to the Seller under Paragraph B, you are responsible r recalls of all tlartayp to the vehid. That ere not ore res et Of ormal wear ant use. These MIMIM node, but are not kwwnad e, those nwasery to: (i) replace Any ire rid part Of a "Who" set of our Marry tire which Ise less Man 118 inch of MMhng tread; (if) repair all mechare al delecl& foil repair p ,place all dereed, watched. chiPeed. rusted or atoned bogy peat., paint or vanlW idenalicalim Mama; an demw, urekMd, rllalad, dMd. bheken or muting ldm antl grill wink; all eCrakned, o bro. bided glees; all faulty Window hic iwns; all broken We b.Win.Out out lign or all Mo. .et nto . MI 11 Manage interior rips, be bums or worm Mmes: arws: ant -W w covered by coluefm or mr ne" I MWanhPe WhIIeer be 1Mr M not such Mae is actually r1lwdy m I_' 11 you have rim maw iM repairs, before ila-cm of the vehicle under Paragraph B, You will owe the estimated Costs Of such rears. even it the ,pain are not med. PMr 10 your ale of tat vehicle to IM Seller. 11 you disprae wkh the admflb0 costs 0l r"iu% you may have IM repairs made at your expense prior to your vets d the veicle to me Seller. D. see`Whiol6 antl Interest: you give tat SW.r a esclxlty Inbrat in. 1. TM all Parts M d d Wr geode pill on whlolo; Als Or goods receives for the voice: and d Al: l insurance ura urencs premomc and servos amuads rynarlcetl for you. Tiswclarais V g you Oweuofil CMiract. It oleo secures Vow other r agreements In this contract. E. Use of Vehicle • Wammas: you mwl boa cede of the vesicle and obey all laws In wing u. You may not sell or rent the vesicle, am you mull heed a free from the deal 01 or.- YOU Mu ,lot Ise or permit the Iae of the YoNds outsaW of the Udlw Staes, "pad for UP to 30 days in Canada or Maico. without rte Prior written consent of the Seller. I the vahlrUe Is of a type --by us ad toy pa .1 uw and Bit Sa1Mr, or Bit vehi- cb'e manuactuler, manse • wrMen ammy or th traot eo ,a log the vehkle within w days From Ma='* I. eMrlr ' you ON Implied veer W" of matehentolmy and Ibleas for a Particular Purpose eovadng the whole. Olhatslse, You undM.t-d and agree seat mate am m such fmPfled ""note. escapt a otherwise Provided by taw. F. Vehicle meuyense: You -91 insure the vehoNa speed lass or damage from Cosaon, fire or then. You cowl Mnla SOW, as the mas pay.. Under iM ineurarhoe policy. The Seller meal approve IN type and amount d Insurance. 11 the vehicle a lost, damaged or destroyed, you mUM pay the Seller what is still owed, You agree that the Sailer cal make a deem under the insurance pulley. You auUOnia the insurance company fo prows Seller any infomution Seller believes necaewry to make a Wkn. You must use mans oe P-Mids to repair tat vehow unless the damage to IN vehicle is considered a total loss. H IM camel M tat vefucle is considered a total bu. YOU must use the insw- ance Proceeds to pay what you owe Me Sallar. 11 your veu,anoe on the vehicle dosan't pay all you owe, you must pay what's still Owed G. Returned Inowshoo Premiums and Service Confined Charges: This contract may Wis. charges lot insurance. service =1l , or other omcall You agree that IM SOI r can claim careful under IMSe pPrwaCis it ume. prohibited by Law, huni them to oll refunds of untamed charges to recluse what you owe. It fat Sal gets a refund on inRnnce. wervoe confiHds, or other contract,, the Seder will sutural It from What You owe. Odra all amours owes udder this contract are Paid. any remaining refunds will be paid 10 You. H. Default: You will be in defaun if 1. You do rot make a PelYmanl when II is due; or 2. You gave ales or misleading infor ishon on your criedh applicator n atmg to this Coned: or 3. Your vehide is Named by any local, sate, M lydemi authority and is not Promptly and .-Pre st elly retumw to You: or 4. You Nis =1 cy peation or one Is filed agaeat you or 5. You do arty other prom.. in this contract. If you default, SOtIM can ese,dw Seller, a right, under this com- bed and Seller's Other rights undo, fat law. I. Iiposseaaion: H you deleult the Seller may squire YOU IG PRY of Once the unpaid Amount Financed, led eamad and unpef. Pan Of tat Fronds Charge and all other amwma due tinder this mined. Se they rOPUSeas (take back) the vehicle, too. Selby may also take goods fount in or on IN vehicle when repossessed and hold them for you J. Your Right To Red-m: If the -wade is taken back. SMler wig sand you a nonce. The -l Will city met You MY M- (buy back) the vehicle and will explain how 10 mdeem the vMide You may red_ me venide up to me tame IM Sailer sells a or ones to sag 4. It you do not redeem me mind., it WHI be sold. X. DiapMiMOn M Motor Vehicle: If Me vehicle it, taken back and sdd, the money them eye sat., lose .sowed spend. will : uwd to Pay I BrrlOUnI eel === Allowes expeaea include these.itl u e to retake IN Whole, hold k, Prapera it for We. and wll H. Ressonabla awyere Nee and .gel cosy are slowed, too. II there . any maey Wit . d" fir, .oils), it will be pea N you. It me money torn the wb 1. . un t.1 pay be this contract am mats, you will pay What Is MITI owed to the "Mr. H you tlo not pay mis amount when IM Seller asks, the Sage may charge You interest at the highest lawful ale UnU you pay. L. C-IIWU- Cosa: Except u otMnw.e Provided by law, you must pay any and all expeau reNated o edorrxng they mono, mdldmg mllaci expenses, awyMa' tees and other Nagel expaneas_ - M. Coheanar Rpar"M YOU aulfion.a the Aaignee Mun d on the Ihent of this conned to obtain conaumsr credit reports from corn sumer reporting agendas (dell" burets) for any ream and at any HIM in con.sorron Mm tare contrail. N. APplleba Law: You agree that ft- coned will be governed by Me laws of the stale of Penrsylumia. 0. Daniel This confined oonams the Share agreement between Sefbr and you Me" b the stab and ryrandng of IM motor _Note. If arry pan ot ma cdxred it, not = ell oiler pane May valid. If Solar doesn't entorco Sir . riglma every gins, $N. can sell mf- men later. Saner veil Mums, all of Sellers ribs In a Wall way. R the ash ansfanmesl Payment der this contend ey a balloon WYmem. 0.ulpnee hu auignw to OI E¢hanga. m its cePecav as Assignee's gwflfietl intermwisry, ds mints (but not its wloaame) with respect to the pads. and ale of IN. Whoa. NOTICE • ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.- Used Motor Vehicle Buyers Guide. If you are buying a uwd vehicle with ther contra i, ideal =o.rs may require a special Buyers Guide to Oe tlfaoayed m Me window of the WMde. THE INFORMATION YOU SEE ON THE WINDOW FORM FOR THIS VEHICLE IS PART OF THIS CONTRACT. INFORMATION ON THE WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE. ^eC w You es a pew "I tar wnaaYelal a apndWlwef Cede. M mat Cue, Idralorl WA not rent epabat airy seelarw or .alessekaagce.yousuer Irw w er Sad, er a Irstasr dyencob Geneve wry eblma,arruulaMetaaranors,et tarsorvMwa w+rr. GUARANTY To rauw IM SefNr o WI tlhe venide tlesenbw m the irmt of Ilia Cmined to mm= m eresH, eesh Pereon who sins below u . aWl 'Gwrannr• gwrantea clue peymah or as coned. Th. means that if IM BuyM ads o pay tarry money met is owed on this contact, peroon aid Ngns a a guarantor win Pay It -led. Fxh Glanrser wed Ngna below MM M wdl be Mia or the Irda amount owes awn if me m more der persona efw signs this Guaronry. Fadh GuaranM Wp agraa o be gaols awn It cop in peon to any of the after oGUam a (c)) grdaws enaeaniy. F GuM:, elm - r"l fie he a (b) iaN. m aMI.Doow .. l Or a or this conned and mile Guaranty at the foe of soling. Guarantor Addess Guaranror Atltlress oral ha 'Ile' 'wB' wco. a Such nch Calms aim, Incbbe ledeypub,d or comroversy Imes nm , a 'Clam') whhwd filing a lawsuit in court. Esher you connpt dxdes er)bilrollon fish dePw at ay a_, irhdulkrg eMr a "*V` . m contrafiled. tO have wry Calm ralebtl to tnh- e: M eA IkhYled o the blbwi!g t) Clsima ct, trvl, reguarory a*ed to i 2Ycor ?m wegerding des inarp,eabon, amps, or wlohyrid ot eke Wine. or ammadYly d any ease; 3) Cairns between, Ym taw w, r pbveea. e.nI , su=e fi , esrpna, nDai.anas, a anuata; o) Caima .sing obi d or roaorg to yd,r epdictitpn fur who co not sign this Cordrapl, m. a amy lewttkg lreheedion M releHarehip, inrJuaCn9 ihM With Me dealer, or any, win reWOmip wr a dartl pemiee who canVRCI. RIOIRB YOU AND WE AGREE TD GNE UP H enter you or we Mpoaa toe 'tab a ,clan you and 'AO spree a waive fie blI-ib rights • RNiHT TO A TRIAL. WHETHER BY A JUDGE OR JURY • RIGNT AGAINST PARTICpATE AS A C LASSBREPRESENTATWE OR A CLASS MEMBER IN ANY CLASP CL11M YOU MAY HAVE • BOAp RNOHT$ L _'" V Y A ARE AVAILABLEOW A LAWSUIT • GTHE TO APPEAL THE DECISION OF AN ARBRRATOp ' i11E/1 Rg11T5 71UT ARE AVAILABLE W A LAWSUIT 11. x Is Uaton Mro 1 U im: ;04., file is s se'. d, Ym erl0 we we continue ro have Hie idbwirg fifes, wallout wanting prwaon eMr bergvlryoy In open; Rom to ..brce the wmriry aroroat in me vehlok. WIMM, by =:a_ M riroagn a court d taw; 3) Rohl b loos legal .do 2) n to "0" M ammatM4 call an 4) Right to agirwt Ihet d efir whethM the emnralor aceeded he aumonty. ==== d Ile ons listed Ill and ge other Pally o .tan arbgyaMn,_Ths npplieeDl. rubs (fM'R.May ericasOdekm. A'rmher;^° • " Arbitwion Aa9odegon (•AAA•J, et 1-800-778-7e]G, or wW W.adr.org; NahMW ArbRraam Foam, al 1-pDe, 4-2371, or a wwamdaum.ram. ;Mr. e coelFlejln iM Rube end ins cormen. Mi. domed aihnl 9overrl Ttos COraracl i-==FR dkregon .S.C. § i at ep.) and Me Fweal RWa of Evidwlce. TM arbitralim dac.i0n ehw M a them .. ........... TS cctraSr-w,OC,Osl IF,awsuaae'nWa nor lam auw.l SEE OTHER WOE FORADDMONAL hGREEMl FG 1)sT$su C 11-Ko "'PRN"' Ford Motor Credit Company P.O. Box 17948 GREENVILLE, SC 29606-8948 (877) 805-7187 POPYTV00200037 RICHARD L. WEBBER 76 N HIGH ST NEWVILLE PA 17241 Date of Reposse 2009 2009 Date of Notice 02-26.2009 ate of Contract ..08-2008 Account Numbe Buyer RICHAR K Cobuyer DEPROPERTY Year 2008 New ? Used Vehicle Identifica1 FT RF14W88KD70591 Model F150 gpdy (4X4) 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 13 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 Sate Place of Sale You may attend the sale and bring bidders if you want. NOTICE OF REPOSSESSION The property is presently stored at: MANHEIM AUTO AUCTION The money that we get from the sale (after paying our costs PATER RD , including reasonable attorney's fees and legal expenses if IM MANHEIM PA AN 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 HOW TO GET YOUR PROPERTY BACK T . we get more money than you owe, you will get the extra money, o get your property back, pay us this amount by certified check or money order before the vehicle is sold. unless we must pay it to someone else. Unpaid Balance $ 24,565.41 You can get the property back at any time before we sell it b Plus Costs: Repo Expenses $ 370.00 y 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 Pius Late Charges $ 16 34 exact amount you must pay, call us at the telephone number Less Finance Charge Rebate $ above. Less Insurance Premium Rebate $ If you need more information about the sale call us at the TOTAL $ 24,951.75 telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured ina urred if default (Plus 5 da e) exceeded s ame dM he e h not 1 the amount that you owe us you may call us at the tele ho te ba y n ess after dat of t is iic , p ne number above, or write us at the address above and request a Your property wont be sold until 15 days after the date of this notice at th EARL written explanation. e IEST. After that you can still get d back any time before it's actually sold. We are sending this notice to the following people who have an If u do, o s have no nger you wait, the rs r m a cost (including repai ) you may have to pay interest in the property described above or who owe money under', If you have any questions about this please call us 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 has been (or will be) returned to: Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the ro rtand a (dealer/original creditor) after the sale, you will pay it to the dealer/original creditor. P Pe y P y you any money left over. If you owe money ? 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 (01 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. VERONICA D. NOGUERA FFNA 11998-37 Jan 02 Previous editions may NOT be used Printed in U.S.A. CUSTOMER/CUSTOMER FILE ?? r. .i asp. . 3 _i •:.. - c ?_ ? _ ,,W ? '` ?. - _ !!-,s - r M1?r+ Awl. _ , _ r • rr 3 _'3 a ?[ } ? _ L•3 ' ? ? .cwt s, .?i? ? • t • J' ? ....? w.r- tR ?.. n g L6 a? oo g ° p o o° o° iA N M y N O W 1~ N ° _ Al- O ,Q p M N a N y N N CV aa N y co co CD CD co CD f°A N ~ y N 4 K a u oC w u 9 ? a? F- ?O Ci O C ? E C O a? o E o to T J ii J I N e S I z N r ('7 co 0 M M O1 N a I? J 0 N co 'It 0,9 C? 01 M N W ?,o0 IL o v ozcr w v r°i .N- a co }yN $?QN vv?-z ?w c7W ^ e? LL1N N O? -W N a in SLU N?' °ow0C9 §ui =1 $yMm S?Na $a.°F-°o, 8 >w 8 3a a -On g?0'a a (0 ONpQ?X J CM Wg N j;;5 111?V) rr??I` X000 0 =! LU it co W (A Cf) -J u 0 CL aaa Na: CLpC, i ?a can oz? a0°= a? ? oaN oa.-n. c?.- M1 M1 s a ? a' m o s Ln p O ?` Ln S s Ln LPG -a M1 M1 0' Q" Q' Q" M1 M1 M1 M1 M1 O O C3 O 0 M M O O p O G O O C3 o 0 o a ° o o M -_O° o ° 0 0 0 s s S ° ° ° 0 -0 S S ° ° O ° 0 O a^ C^ ° ° ° 0 0 ra r9 r-l ? FA Q' Q' M1 M1 M1 M1 M1 M1 N Z IM IN IM 6th hz6OODT000h4OO6TL co IM - -4 - N ? S• E ? O? u7 co 3 co co C& N Eta M $ J N ~ Y ?za A IL ?3 g w vs ? d U- i M1 ? tt cr 3 R O d O E ra ? . o- O s O b Q' a ° M1 $oo $' Z$ O F- ..1 ui N U U. a U E Ford Motor Credit Company P O BOX 17948 GREENVILLE SC 29606-7948 877 8057187 DATE: 2009-05-12 PORZ0000100199 RICHARD L. WEBBER 76 N HIGH ST NEWVILLE PA 17241 STATEMENT OF SALE Account Number: 043717937 The following property has been sold. Year Make Model 2008 FORD F150 Balance owing on your contract 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: Vehicle Identification Number: 1 FTRF14W88KD70591 (1) $ 24,581.75 (2) $ 0.00 (3) $ 24 581.75 (4) $ 17 800.00 (5) $ 6,781.75 (6) $ 864.00 (7) $ 0.00 (8) $ 455.79 Deficiency** (9) $ 7189.96 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: Mail deficiency payment to: Ford Motor Credit Company Ford Motor Credit Company P.O. BOX 6508 DEPT 194101 MESA ARIZONA 85216-6508 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 FFNA11990 01/04 Previous editions may NOT be used. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Flj.,~~--V~~t~~ Sheriff r S s~ '(~{4 P~t)~'F?^p()'~ ~4~,ttt44 pt Orin+brr~br~ Jody S Smith Chief Deputy ~. ~,~. ~ ~~~` ~~~ . ~~ ~ ~ ~E~ ` a ~~ { Edward L Schorpp Solicitor ~; ~ ~.~;..~~~~~ C~~di~,~ ,:~;:,, ~: • ,~u'l.'•iV"~Y Ford Motor Credit Company vs. Richard L. Webber Case Number 2010-685 SHERIFF'S RETURN OF SERVICE 02/01/2010 06:00 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 1, 2010 at 1800 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard L. Webber, by making known unto Judy Webber, Wife of defendant at 76 N. High Street, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handinc to her personally the said true and correct copy of the same. SHERIFF COST: $38.80 February 03, 2010 SO ANS ERS, R Y R ANDERSON, SHERIFF Deputy Sheriff ipi CountYSuitc nhen$ Teleo~oR. Inc. =.r . MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 C? ° '=n L o <_>. --+ -r Attorneys for Plaintiff `-'' - f__ _ ~, ;~, - ~ __ - ::- a, - -,. , --.. __ , ._ _..~, _ --t ~ ~ ~ °'a ;4 ~ , ..~ ~a (115) "/2Sy-~/ 155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. RICHARD L WEBBER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-685 CIVIL TERM PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: No answer having been filed in the above Civil Action, kindly enter Judgment in favor of Plaintiff, and against Defendant, RICHARD L WEBBER in the amount as follows: Principal Amount $ 7189.96 Interest to Date $ 270.42 TOTAL $ 7460.38 MAURICE & NFpE19,~,E~v1AN, P.C. BY: Attorney Date: June 16, 2010 YLOR, ESQ. ~I~•oo P p AT'H c# aaB& i ~ ay~~$ ~o~ee ~lo~ t _ MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (~1J) /2Sy-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. RICHARD L WEBBER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-685 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she represents the Plaintiff in the above entitled case and that Defendant, RICHARD L WEBBER , is over 18 years of age; the occupation of Defendant is unknown and to the best of Plaintiff s knowledge, information and belief, Defendant is not in the military service of the United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. MAURICE & SWORN TO A~TD SUBSCRIBED before a this/~ day of 010 . Notary Public BY: ~~ ,,t ~. s ... `.. ; ,- ,.. ~ - , r Attorneys at Law Suite 435, Qne Penn tenter lbl7 Jofin F. Kennedy Bird. PhifadelAitia, Pd ! 9103 tel. 2TS.bb5.1133 fa:21S.563Jl970 www.mnlawpctom Donald S. Maurim Member NJ Bar Baord (edified Creditors' Rhthts Low Ametl[en Board of Certification Joann Needleman Member PA 8 NJ Bar Thomas Y. Domin[zyk Member NJ, NY 8 PA Bar (hadene d. Toylar Member PA Bar New brsey Office Mourice & Needleman, P.C. Suite 2007 S Wafter E. Faran Blvd. Nemingtan, NJ 08812 te1.908.231.4550 fez 908.237.4511 Apri17, 2010 RICHARD L WEBBER 76 :~' HIGH ST NEV~TVILLE, PA 17241 Our fiile No. 11955 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY ~~. RICHARD L WEBBER CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 14-685 CIVIL TERM. Dear Mr/NIrsIMs ~VEBBER: 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 February 1, 2010 . 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 yoT~. If you would Iike 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 trizly yours, MAURICE NEEDLEMAN, P.C. Charle a or, Esq. CT/jxn Enc THIS CORRESPONDENCE IS A1V' ATTEMPT TO COLLECT A DEBT, AND Ari"k' INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRIVI IS A DEBT COLLECTOR MAURICE & NEEDLEMAN, P.C. BY: 3oann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Pew Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys far Plaintiff / tf y-7155 FORD MOTOR. CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. RICHARD L WEBBER D CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-685 CIVIL TERM IMPORTANT NOTICE TU: RICHARD I, WEBBER DATE: April 7, 2010 76 N HIGH ST NEVV-t~ILLE, PA 17241 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOL' WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIlZE A LAVi'YER, 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 (7?7}249-3166 MAURICE ~.,dV~E~LEMAN, P.C. BY ,~ CH. ENE TAYLOR, ESQ Attomev for Plaintiff £.'s- 062S0005583197 .. ~ ti Ot41MM0 E d.~yo~ ~$ ~~gO~N ~ . Lq ~a~p~ ~~u~.Q f M T j,= T N `1 ~ __ m N - ~ m ti = W T` -_ S'1-a -~ ~ _ Q ~ ~ (i' J _ =Z~ _' .= U W ~tiZ Z Q w~° °z~ ww¢ Zva. zZQ W= Waa U CLJ W Z ~ =0g Erna Request for Military Status Department of Defense Manpower Data Center ~~~~'' Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 OCT-13-2009 l 0:38:01 "~~~ Last Name First/Middle Begin Date Active Duty Status Service/Agency WEBBER RICHARD 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. r~ r~ ,c..~y_~- 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:/iwww.defenselink mil/fagipis/PC09SLDR html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/13/2009 ^ Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BFCIXKPKILM https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/13/2009 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 (L15) "/tSy-"/155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. RICHARD L WEBBER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-685 CIVIL TERM AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, CHARLENE A. TAYLOR, ESQUIRE, being duly sworn according to law, deposes and says that he/she is an attorney at law and that on 04/08/2010 he/she mailed a written Notice of Intention to File the Praecipe to Defendant, RICHARD L WEBBER , at 76 N HIGH ST , NEWVILLE, PA 17241 by regular mail. MAURICE & N~ED~,EJ~IAN, P.C. BY: Attorney for SWORN TO A D SUBSCRIBED before e this day of ~ J f~ 20~ . ESQ. Notary Public ~o~ HARRisu-N~tilpeAE; l~otery PubCc ~Y ~ Pt~sdMplaa, PMa. Co~aKy My ConHr~ssioo Expires l4larah 93, 12 ~1'. MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (215) 7~Sy-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. RICHARD L WEBBER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-685 CIVIL TERM CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 04/08/10 to Defendant, RICHARD L WEBBER ,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 04/08/10, a copy of the mailing to the Defendant and affidavits of service are all attached hereto. MAURICE & NF,yEDL~1~AN, P.C. BY: Attorney YLOR, ESQ. Date: June 16, 2010 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 (Z15) 7tSy-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. RICHARD L WEBBER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-685 CIVIL TERM CERTIFICATION OF ADDRESSES It is hereby certified that the parties have the following addresses: Plaintiff: FORD MOTOR CREDIT COMPANY P.O. Box 6058 MESA AZ 85216 Defendant: RICHARD L WEBBER , 76 N HIGH ST , NEWVILLE, PA 17241 MAURICE & BY: Attorney for P.C. YLOR, ESQ. Date: June lb, 2010 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 S) ~/tiy-~/ 155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY. COMPANY Plaintiff v. RICHARD L WEBBER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-685 CIVIL TERM (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $7460.38 on p (X) A copy of all documents filed with the Prothonotary in support of the within judgment is ended. ~lcl ~_~~ 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)