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HomeMy WebLinkAbout10-2830MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 ,,,,earlene 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 C) C- -- - I-- CD c, 15) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. BOX 6508 Mesa, Az 85216-6508 V. EXCLUSIVE CAR CARE INC 235 Hunters Rd Newville, Pa 17241 MICHAEL D HADAWAY 235 Hunters Rd Newville, Pa 17241 Plaintiff, Defendant(s). CUMBERLAND COUNTY COURT ire COMMON PLEAS n Case No. 10 -(2630 C1 V 1 I Pry 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 tights important to you. UJI V IL AUTION COMPLAINT AV ISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de Is demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o can un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de so persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuer In demands en contra suya sin previo aviso o notificacion. Adernas, la corte puede decidir a favor del demandante y requiere que usted cumpla con codas las provisions de esta demanda. 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 SI NO TIENE EL DINERO IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SUFICIENTE 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 Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 0S (717) 249-3166 9a. oo P!i A` -N ecw ?'l33 2,' aN1a57 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff (215) "/89-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. EXCLUSIVE CAR CARE INC 235 Hunters Rd Newville, Pa 17241 MICHAEL D HADAWAY 235 Hunters Rd Newville, Pa 17241 Defendant(s). 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, Exclusive Car Care Inc, is an individual who resides at 235 Hunters Rd Newville, Pa 17241. 3. Defendant, Michael D Hadaway, is an individual who resides at 235 Hunters Rd Newville, Pa 17241. 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 June 30, 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 $45870.48 at an annual percentage rate of 7.200%, in order to purchase a certain motor vehicle, 2005 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. 6. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $612.09 for a period of 72 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 June 16, 2009, 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 $9600.00, however a balance of $7405.08 is still due and owing. 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 $217.65 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $7622.73. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $7622.73, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully sub 1 , MAURICE & Zb EMAN, P.C. Attorney ESQUIRE Date: April 22, 2010 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: A. TAYLOR, ESQUIRE DATED: April 22, 2010 PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE 06130/2005 tutrer (and uyer) Name and Address (kckrdfng County and Zip Code) CREDITOR (Seiler Nam and Aloft) 1 1 2005 - • _1 • -- -- EXELVIVE CAR CARE INC V NI N L UU HADANAY JUL 0 5 PHILLIPS FORD SALES vvvv 235 HUNTERS RD 1005 300 S MAIN ST, P.O BOX 68 ?-{co NFMVTIIF PA 17741 HANHFIN PA 17545 You, We Buyer (arW CO'"F, It earl. MY amY eta 081" da Abed below ter cash or an credit. The 'cash Prim' shown below Is the cash prim at the "hick. The 'TOroI Sale Price' shown below Is arm craft price. by 4pdng this conireei, you choose to buy on eredlt under as apwrwrta an the front and beak of eda comrecL NswlUsed Year and Make - Model OVW it Tuck Ms.) Vehicle ki-fificalim Nunl»r I I- F- wR,inh a,,.i....,r NEW FO ?g93 ypRpD FORGps F150 IFTPX14511 Trade•in 200E s 21000.00 s 23503.82 Year and Lake Gross All-ca Amount Owing ITEMIZATION OF AMOUNT FINANCED 1. Cash Price ........................ _.... _....... ._............ _..... ._....... _...... _......... $ 33765.00(1) 2. Down Payment Third Party Roberts Assigned to Creditor ............... _............ $ 1800.00 Cash Down Payment .._._.. ................ ................................ $ MIA Trade-in 2003 FOR $, 21GOD.00 $ 23503:82-$ 0.00 Yew .it Mw. Gee. AN- Ammon owns Total Down Payment ................................................ _.................... $ 1800.00(2) 3. Unpaid Balance of Cash Price (1 minus 2) ................._................. $ 31965.00(3) 4. Amounts paid on your betmN (Seller may be retaining a portion of these amounts) To Insurance Companies for Y /A Credit Lee insurance (for tens of contract) ............... _....... $ Credit Disability Insurance (for term of contract)............ $ NIA -??- - -?- [fens Months (Estimate)) $ To Pub c Of icia-R Is (i) for license ($ ,M), title registration ($.-$4,.rgees S-1]I„00: (ii) for filing fees $ 5ee?er (Iti) for taxes (not in Cash Price) $ ?cn s2 $ 2 0202 To INAA to $ To PHILLIPS FOR for DOC$ 55.00/NOTARY $ 65.00 To SUSQUEHANNA M--NEGATIVE EOUITY $ 2503.82 Total ............... _.......... _..._...................... ............................................ $ 5073.04(4) 5. Amount Financed (3 plus 4) ............................. _.... _........................ S 37038.0 ft) FEDERAL TRUTH-IN-LENDING DISCLOSURES ANNUAL FINANCE Amount Total of Total Sale PERCENTAGE CHARGE Financed Payments Price RATE The dollar WOW The amount of The amount The tow cost The cost of your am credit will credit provided to you will have of your purchase on credit as a yearly rata cost you you or on your paid when you credit, behall haveulsed all do nt payments of $ BM 00 Payment Schedule Number of Amount of Each When Payments 9&menle "am are due Your payment schedule 71- $ 612.09 (mar" starting) WAR be: Ifinal $ 612.09 07/30/2005 Prepayment: If you pay off your debt eady, you WE rat have to pay a Penalty. Lets Payment: You mutt pay a lass charge on the portion of each psymsm received more than 10 clays lift. The charge is 2 percent of the Was amount or $50.00 whichever is ass. Security Interest; You are giving a security intereat.in the_vehide.bwv purchased. Contraw: Plesse me contract for additional t1et Pre paYmert Pwtely npht toto requires repayment of you debt in full before the schedr19d da=ym9m It you do not meet your contract obpptliwa, you may Iwo the vehicle that you are tin" M under aft meradt. u wall as hoth nine .M ON MODIFICATION DISCLOSURE Any charge I?tpjg ba •n9 aptl ei?pgnetl M You erW the Credi r. BUY R: Y KN E THAT YOU HAVE READ A GREE TO BE BOUND BY THE XFNBITRATION PROVISION ON TH ERSE 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 legs) rights. Buyer (and Co-Buyer) acknowledge that (i) before signing this contract, Buyer Zed Co-Buyer) received and rev)ewed a As an Completely filled in copy of this contract and (Ii) at the time of si nin this contra Buyer (and Co-Buyer) receTv? a true a ate Cof this contract. aassignment ataehaad Seller et arbset, the Seller scam no Motor Cso In redit cony eaaaa PHILLIPS FORD SALES By rga r-w .ens ry,.w.+e,..w ar .ese.l SEE BACK FOR ADDITIONAL AGREEMENTS PA ? Personal ? Agricultural N896613 rci.i INSURANCE YOU MAY OBTAIN VEHICLE INSURANCE FROM A PERSON OF YOUR CHOICE. YOU ARE NOT REQUIRED TO OBTAIN CREDIT LIFE, CREDIT DISABILITY AND OTHER OPTIONAL INSURANCE. THIS CONTRACT WILL NOT INCLUDE THEM UNLESS YOU SIGN AND AGREE TO PAY THE PREMIUM. THIS CONTRACT DOES NOT INCLUDE LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS. ? Credit Life N/A Insurer $ N/a Premium Insured(s) Signature credit ? Disability MIA Insurer $ Y/e Premium Insured Signature MIA O ptional Insurance Tenn N!A $ _-N Insurer Premium l nor ure Credit Lee and Credit OUapiaV Imunnca are I., the tam m the conlacL Tier amount and coverages we shown In a notice or agreement given b you today. You must Insws the vehicle. If a charge Is shown Itelow ea creditor will try b buy tint Cevemaes will on the rash walls of the veh at tam f l b t o oss, u not more than the limits of the policy. ? Comprehensive L3 Collision ? Fire- Thoitl:crnbined Additional Coverage ? Towing and Labor ? Term N/A months (Estimate) Premium s N/A ` Noseir, t Cww wwj nn waiver AddxWUm j0pmut) tC „ purchasad p a cancellation waiver. Im a oww.ge oPtbnd and is hat squired to obWn croft. The rormc and condeorre of the debt nroebaeon waiver are set font in the atledrod Adderidun Which is incorporated "this contract. The trice for ye- debt rndtlahon waiver is ast forth on this coned in the homastion at Mount Froiced under Section 4. Buyer I Program No. QUESTIONS? PLEASE CALL US AT 1-800-727-7000 or Visit us at tawwr.fordcreditcoln Mai ORIGINAL "'PRN"' Ford Motor Credit Company P.O. Box 17948 GREENVILLE, SC 29606-8948 (877) 805-7187 PM713500200050 EXCLUSIVE CAR CARE INC 235 HUNTERS RD NEWVILLE PA 17241 Date of Repossession 10-05-2009 Date of Notice 10-07-2009 Date of Contract 06-30-2005 Account Number: 039292427 Buyer EXCLUSIVE CAR CARE INC Cobuyer MICHAEL D HADAWAY DESCRIPTION OF PROPERTY Year 2005 Make FORD New ? Used Vehicle Identification Number: 1 FTPX1451 SNB96613 Model F150 Body (4X4) NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke prorrrses In our agreement. Q 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. The property is presently stored at: MANHEIM AUTO AUCTION 1190 LATER RD 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 $ 16,555.59 Plus Costs: Repo Expenses $ 370.00 $ Plus Late Charges $ Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 16,925.59 (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 it's actually sold. If you do, we'll have no further claim an it. But the longer you wait, the more costs (including repairs) you may have to pay. If you have any questions about this, please call us. ? The property has been (or will be) returned to: (dealer/original creditor) Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money after the sale, you will pay it to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by contacting this office. Thereafter, the personal property shall be disposed of accordingly. ? Creditor has assigned to Its qualified intermediary (OI Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer is not accurate for any 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. BELINDA VEGA FFNA 119W-37 Jan 02 Previan editions may NOT be used. CUSTOMERICUSTOMER FILE Printed in USA . "'PRN"' Ford Motor Credit Company P.O. Box 17948 GREENVILLE, SC 29608-8948 (877) 805-7187 PM7G5002110056 MICHAEL D HADAWAY 235 HUNTERS RD NEWVILLE PA 17241 Date of Repossession 10-05-2009 Date of Notice 10-07-21 Date of Contract 06-30-2005 Account Number: 039292427 Buyer EXCLUSIVE CAR CARE INC Cobuyer MICHAEL D HADAWAY DESCRIPTION OF PROPERTY Year 2005 Make FORD xQ New ? Used Vehicle Identification Number: 1FTPX14515NB96613 Model F150 Body (4X4) NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. IIIS IC I. ?C 0 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 went. 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. The property is presently stored at: MANHEIM AUTO AUCTION 1190 LANCASTER RD MANHEIM PA HOW TO GET YOUR PROPERTY BACK To get your property hack, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 16.555.59 Plus Costs: Repo Expenses $ 370.00 $ Plus Late Charges $ Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 16,925.59 If you want us to explain to you in writing how we have figured (Plus expenses incurred if default at the time of repossession exceeded 15 days and less rebate received after the date of this notice.) the amount that you owe us, you may call us at the telephone Your property won't be sold until 15 days after the date of this notice at number above, or write us at the address above and request a the EARLIEST. After that you ran still get it back any time before its written explanation. actually sold. We are sending this notice to the following people who have an If you do, we'll have no further claim on it. But the longer you waft, the more costs (including repairs) 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: (dealer/original creditor) Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money after the sale, you will pay it to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by contacting this office. Thereafter, the personal property shall be disposed of accordingly. ? Creditor has assigned to its qualified intermediary (QI 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. BELINDA VEGA FFNA 1198837 Jan 02 Previous editions may NOT be used. CUSTOMER/CUSTOMER FILE P-ted in U.S.A. r . o - Q - - - --ROYP? ? ? g O $ $ c $ o g S - o --S o a O o a° e ¢ 41% o 4OA K 44 o H w 40 - 5; ° -a y g S O O O Co O C) O 0 oO O 0 O O M. 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P .;5 N a x X0 13 C 4H -0 S% -- 0 Z M 0 N ° «.. 01 (A ga ??n to N s $ M m? 3 ?'? ty 3 o F -mi c°, m M m N m mr., ° 0 So oL w Er c o m =. o x 81 .. 0 0 0 m V 10 0 0 m M m v .... H .. .. H r In N r r M _ ? . c3.' m M 0° o G ? M MD q oZ r Nz 0 M .,.. O M U} M N z 0 x r 6 -+ N .. n 'i ? n ?O w Fi 0 0- M ru X 0 H 0 o,4D mV. v 0 N GJ CO ?N Cc) N 0w •0 r+ o LA m SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~~t~t, of ~u+ubr~.~~~~~ 4 ~; ., .~. ~~' '' , _ , Jody S Smith Chief Deputy Edward L Schorpp Solicitor ,~ r„ ~-_ Zt+~~~r,;~f '~ t ii ~~ L7 ,, - > -~, C~:y. ~' __. ~. _, . Ford Motor Credit Company vs. Exclusive Car Care Inc. (et al.) Case Number 2010-2830 SHERIFF'S RETURN OF SERVICE 05/03/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Exclusive Car Care, Inc., but was unable to locate them in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Exclusive Car Care, Inc. Request for service at 235 Hunters Road, Newville, PA 17241 is vacant. The Newville Postmaster has advised the defendant has moved to 65 Taylor Road, Etters, PA 17319. 05/03/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Michael D. Hadaway, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Michael D. Hadaway. Request for service at 235 Hunters Road, Newville, PA 17241 is vacant. The Newville Postmaster has advised the defendant has moved to 65 Taylor Road, Etters, PA 17319. SHERIFF COST: $64.80 May 03, 2010 SO ANSWERS, ~~~ RON R ANDERSON, SHERIFF (c Coun',Suite SF6;nff. Te:eosuft. Inc. MAURICE & NEEDLEMAN, P.C. ~ ° BY: Joann Needleman, Esq. Attorneys for Plaintiff ~' ~ _ ~.. s~ Identification No. 74276 . ~ ~- _ ~ ' Charlene A. Taylor, Esq. ~ .=`_ r-- ~ - ~ :~ ~ ~ _ Identification No. 203920 s` -~, , =~ €~= 935 One Penn Center .j~.~= `=`c 1617 John F. Kennedy Blvd N ';:fin Philadelphia, PA 19103 ~ .z -mac (l15) "/~Sy-"/ 155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. EXCLUSIVE CAR CARE INC MICHAEL D HADAWAY Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 2010-2830 PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the above matter without prejudice. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. CHARLENE A. T~Y~LOR, ESQ Attorney for Plaintiff Date: May 21, 2010 CERTIFICATE OF SERVICE I, Charlene A. Taylor, Esq. hereby certify that on this date I have caused a true and correct copy of the foregoing Praecipe to Withdraw Complaint on behalf of FORD MOTOR CREDIT COMPANY, A Delaware Limited Liability Company, to be served by regular, first class mail, postage pre-paid upon: EXCLUSIVE CAR CARE INC 65 Taylor Rd Etters, Pa 17319 MICHAEL D HADAWAY 68 Taylor Rd Etters, Pa 17319 Respectfully Sub tted, MAURICE & N~I1,~EMAN, P.C. BY: C;harlen Tl4ylor, Esquire Attorney r Plaintiff DATED: May 21, 2010