HomeMy WebLinkAbout10-4112MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
(215) 789-7155
FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF
DELAWARE LIMITED LIABILITY COMPANY COMMON PLEAS
P.O. Box 6508
Mesa, Az 85216-6508 Case No. 10 - 411 A 0,ly i ITe1' -A
Plaintiff,
n
V. r
EDWARD KENNEDY F
247 F St - -
Carlisle, Pa 17013 ^c co
-??
Defendant(s).,
CIVIL ACTION COMPLAINT
NOTICE AVISO
You have been sued in court. If you wish to defend Le ban demandado a usted en la cone. Si usted quiere defendeise
against the claims set forth in the following pages, de estas demandas expuestas en las paginas siguientes, usted tiene
you must take action within twenty (20) days after veinte (20) digs de plazo al partir de la fecha de la demanda y la
this complaint and notice are served, by entering notificacion. Hace falta asentar una comparencia escrita o en
a written appearance personally or by attorney and persona o can un abogado y entregar a la torte en forma escrita sus
filing in writing with the court your defenses or defensas o sus objeciones a las demandas en contra de so persona.
objections to the claims set forth against you. Sea avisado que si usted no se defiende, la Corte tomara medidas y
You are warned that if you fail to do so the case puede continuar la demands en contra suya sin previo aviso o
may proceed without you and a judgment may be notificacion. Adernas, la torte puede decidir a favor del demandante
entered against you by the court without further y requiere que usted cumpla con todas las provisions de esta demanda.
notice for any money claimed in the complaint or Usted puede perder dinero o sus propiedades u otros derechos
for any other claim or relief requested by the importantes para usted.
plaintiff. You may lose money or property or
other rights important to you.
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 O
(717) 249-3166 -*9a1.00 P(J ?11TT b
aIait 3
Ro ay3g&y
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq.
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
(215) 789-7155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
EDWARD KENNEDY
247 F St
Carlisle, Pa 17013
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, Edward Kennedy, is an individual who resides at 247 F St Carlisle,
Pa 17013.
3. At all times relevant, the Plaintiff was in the business of loaning money on motor
vehicle installment sales contracts, including but not limited to the note signed by Defendant(s),
hereinafter more fully described.
4. On or about July 6, 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 $38919.12 at an annual percentage rate of 12.040%, in
order to purchase a certain motor vehicle, 2005 Ford F-250 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 $432.22 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 January 20, 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 $9400.00, however a balance of
$5728.17 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 $544.18 and which will continue to accrue.
11. The total amount due and owing at the time of the filing of this complaint is
$6272.35.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $6272.35, 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 su ivi M
AURICE <4i T, EMAN, P.C.
Attorney for
ESQUIRE
Date: May 20, 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:
DATED: May 20, 2010
rENMYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT pq W/06 OE
Buyer (and C"wer) Name antl Atldrsas (induomg County and Zip Code) CREDITOR (9 Nee Name and Address)
EDWARD RKENNEDY JUL j 3 LIB S??MAIITH FORD INC yy?
MIT." PA 1701313
7013 mo5 LEMOYNERKET ST PA 1704?r654
"" an.r tyre wwyar, a anyF may aaY tle raleri tlaaoriped below for mob or on CreAL TM'Cph Prlos' alromr below Is 1M Gent piste of No vamtle. The
'rehl BaM Prks' alrown_beiow is an woo piste. aY agrriq sae ooatraeL yw drooee to buy an weAt under the aperrerue on ate }rout and back of We
ararsL
NEW FORD -250 SD 1PTS)(21565EB44429 C Personal O AaricUldf°i
O conuremw
Trscl. $WA VA INSURANCE
Yee Ora Make Grove Allowance $ Arn,aun Owing YOU MAY OBTAIN VEHICLE INSURANCE
1?
FROM A PERSON OF YOUR CHOKE
ITEMIZATION OF AMOUNT FINANCED
1. Cash Price .___._._._..._._...._............. _._......_........._._.„.._ ._. $ 28100.00 (?)
2. Down Payment
Third Party Rsbs% Assigned to CWMr_.,,...... _.._...._.. $ 2800.00
Cash Down Payment__.____.
._._.__
__. $ 5000.00
?
_.....
Trade4n $ $ WA
V_w.0 ea® G- AM- Anawt OMnp
Total Down payment ........... __._..._...._........._._.___..__._.. $ 7800.00 (2)
3. Unpaid Balance of Cash Pries (1 minus Z)............... __. „. _.... $ 20600. 00 (3)
4. Amounts paid on yore beh N (Geller nay be retaining a portion of time amounts)
To Insurance Conweniea for
Credit LIle klsuranca (for tern of contract) _...............
$ r"
Credit Diasbilky Insurance (far term of contract)........... $ W4A
(Term Months (Eailmate ] $ *rti
To Public pffldala for license ($ = 1 title (S 22.50 a, 8
15 50 .
registration ($ OD I?-
es
.
(i) for filing fees $
(IN) for taxes (not in Cash Price) $ 1518.00 $ 1728.95
To for $ W-A
To for $ WA
To ME $ 55.00
TO for NA - $ !VA
Total ..... ......... ..._ „_._._._...__....__..._____._......._._ ._. $ 1783.95 (4)
FEDERAL TRUTH-IN-LENDING DISCLOSURES
ANNUAL FINANCE Amount Tsai of Total Sale
PERCENTAGE CHARGE Financed Payments Prix
RATE The dour amount The amount or The amaa,t The tort cost
The oust of your
c me cede wa cradh proWded to you will hero of your purchase an
credit
a yearly rate cost you you or on your peld when you credit.
behtM haw meat all ffmkx g you
scheduled 00wr4)y
psyrner" or S "me• n
Peyrram schedrds Number of Amount of Each When Payments
Q pay 0 Psywe due
Your pW M sdrdilParallel 432.21 (monit y slsrting)
will be: 1 Nnai $ 477.21 ter. rxtw lax
Late pylr- If OU ? your dabs aunt, you visa not haw to pay a Panahy.
t 0 days late. The char RY We charge on the portion of each Payment received more
then then 10 y dInteraft ays 101 You are percent of the late amount or $50.00 whichwer IS less.
giving a secuAty kneeat in the vehicle bang purclrsed.
Contre : Passes sea On contact for additional information an security Mdens4 npayr?nt
delaum, tie Aght to requie repayment of your debt in full before the scheduled dne?and
prepayment
portly.
N youdo not tee your awwad abupesore, yw may by tie vahids atei
ac ww9 a bath eeaa rwf .w.d...w ..., w....?..?._ .r ?._ - __ _ _ Yda N farneirp Greer for aenvact,
NON-MODIFICATION DISCLOSURE ` -
Any drnga. In tlws oorrad mss be n wA I g a4nad M you era tfr creditor.
BUYER: C,b-BUYER: X
O
YOU ACKNOWLEDGE THAT YOU NAVE READ AND AGREE TO BE BOUND
BY THE ARBITRATION PROVISION ON THE REVERSE SIDE OF THIS
CONTRACT.
NOTICE TO BUYER
not ientitlthis ed to an min blsnk
You
of the contract you sign.
Keep it to protect your legal rights.
Buyer (and Co-Buyer) acknowledge that (1) before signing this
contract, Buyer (and Co-Buyer) received a reviewed a true
an completely filled to copy of this contract and (I`I) a- ?
at ?the
time of si nin this corytra Buyer (and Co-Buyer) recavs?
a true mp y n copy of this contract.
{
X
son
co) surER facets
By alprip Widow, fee this eormraet. e ro oarw aegrrr r earnea te •
eertannrere arrohad b eels oorttreat. is aslrm N a ad Gear
11 all 2W---B' Ter
PA ...-. ?.._.. .
--?^•. ace wwn rVn ~u,jRMftL AGnEEMENy$
YOU ARE NOT REOUIRED TO OBTAIN
CREDIT LIFE, CREDIT DISASUM AND
OTHER • OPTIONAL INSURANCE. THIS
CONTRACT WILL NOT INCLUDE THEM
UNLESS YOU SIGN AND AGREE TO PAY
THE PREMIUM.
THIS CONTRACT DOES NOT ICLUDE
LIABILITY INSURANCE COVERALL FOR
BODILY INJURY AND PROPERTY
DAMAGE CAUSED TO OTHERS.
? Credit Lffe
Insurer
PrreertAs`um Insureds)
Signature
Credit
? Disability
Insurer
$ Pramium Insured
Signature
O
Other Optional Insurance Term
insurer $ rramfOfn
re
Cndk Life and Crsda DIp61Ntyy lrrrsarrea are
for the term of an oaAract 7M orma t and
el=1 you 7 r s noew or agreement
You must Mrurs tar Wall IN a char" Is
attmn below, era Creditor will by to buy the
_9 9 s beforo o the n the cash MI~w
WAS na la at liras d lea but not more era
no IYnNs of the pokey.
? Carnpreherrive ? y ty/A
Deductible
Coumm
? Sw Thef4Cornbined AdMioal Ccewage
? TMV V and Labor
? Term Months (Easter)
Rem. $ WA
?OM Cancellation Wider Addendum MINNOW)
If ass boa it decI you hers punYand a debt
orwellason weNer. Purchase of One oasmiia b
octional db?a s not required to obtain The hame
ft debt cwmftbrwanam&wakw we 80
fors, In er stla I Addendum which is Inmrpcaled
Goo [Ns contact. The price for the duct ancellation
waiver is se brat on des corwaet In the
learnt lrellatbrr
d Amount Flawnosd rase Section 4.
Bayer
Program No.
QUESTIONS?
PLEASE CALL US AT 1400-727-70W
or
Visit us at taww.fordt redLoom
034M
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NOTICE - ANY HOLDER OF THIN COINIMIlR CREDR
CONTRACT w SUSJEOT To ALL CLAW AND
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A wCN THE OF OR [RO MTOROWORWS p1ASYSEM,ES
alAllliT THENSB.1.
OBTANOW MIRNUAMr INTO OR TNNrM TNN
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THE DEBTOR HEREUNDER.
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"•PRN•"
Ford Motor Credit Company
P.O. Box 17948
GREENVILLE, SC 29606-8948
(877) 805-7187
POT3DA00200027
EDWARD KENNEDY
247 F ST
CARLISLE PA 17013
f Repossession 06 1 &
f Notice
2009
t
DContract
0
EMS
Accou
ntNumber0393388 92
EDWARD KENNEDY
Cobuyer
DESCRIPTION OF PROPERTY
Year
2005 Make
FORD ?x New
? Used
Vehicle Identification Number:
IFTSX21565EB44429
Model
F250 Body
4X4
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your Property described above because you broke promises In our agreement.
t.
Z
i
sssss?
x? PRIVATE SALE: We will sell the property described ? PUBLIC SALE: We will sell the property described above at public
above at private sale sometime after 15 days from the sale to the highest bidder on the date below (or any adjournment
Date of Notice shown above unless redeemed by you date). The sale will be held as follows:
prior to such sale.
Date of Sale Time of Sale Place of Sale
You may attend the sale and bring bidders if you want.
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 unde
your agreement: 1) The buyer and any cobuyer named above;
2) Any dealer/original creditor named below; 3) If there are other
people, they are named on an attachment sent with this notice.
NOTICE OF REPOSSESSION
The property is presently stored at: MANHEIM 1190 LANCASTER
D MANN I A
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 $ 14,503.67
Plus Costs: Repo Expenses $ 370.00
$
Plus Late Charges
Less Finance Charge Rebate
Less Insurance Premium Rebate
TOTAL
$ 32.50
$ 14,906.17
(Plus expenses incurred If default at the time of repossession exceeded
15 days and less rebate received after the date of this notice.)
Your property wont be sold until 16 days after the date of this notice at
the EARLIEST. After that you can still get it back any time before its
actually sold.
If you do, we'll have no further claim on it. But the longer you waft, the
more coats (including repairs) you may have to pay.
If you have any questions about this, please call us.
LJ 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 property arid pay you any (dealerioriginal creditor)
after the sale, you will pay it to the dealer/original creditor: money left over. if f 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 (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 rat 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 11 OW-37 Jan 02 Provioas edibms may NOT be used.
Primed in U.S.A. CUSTOMER/CUSTOMER FILE
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KEITH D. GILLAM
652 WOODLAND DR
POTTSTOWN PA 194642833
M1 26 OT3DA002000261039467251
7190 0640 0010 0128 0067 JOSEPH F. EMPER III
1835 TOMLINSON RD
PHILADELPHIA PA 19116-3849
27
OT3DA002000271039338892
tt? 7190 0640 0010 0128 0074 EDWARD KENNEDY
247 F ST
CARLISLE PA 17013-1314
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517 DALLY RD
COAL CENTER PA 15423-1208
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1033 782 WORTH BLVD
APT 310
POTTSTOWN PA 19465-7790
OT3DA002000301037843703
9979 MARCUS V. DASFLORES
5114 TRAFALGER PL
MADISON W153714-2024
OT3DA002000311043156150
9986 REBECCA J. PATT
410 5TH ST
NEENAH WI 54958-2867
OT3DA002000321043086885
9993 PETER J. LABELLE
W141 HILDEBRAND LAKE RD
RHINELANDER WI 54501-9013
Date Rwald
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Ford Motor Credit Company
P O BOX 17948
GREENVILLE SC 29606-7948
877 8057187
DATE: 2009-08-05
POUD9=100083
EDWARD KENNEDY
247 F ST
CARLISLE PA 17013
STATEMENT OF SALE
Account Number: 039338892
The following property has been sold.
Year Make Model Vehicle Identification Number:
2005 FORD F250 1FTSX21565EB44429
Balance owing on your contract
(1) $ 14,536.17
Deduct: Finance Charge Rebate (2) $ 0.00
Balance less Finance Charge Rebate (1 - 2)
(3) $ 14.536 17
Deduct: gross proceeds of the sale (4) $ 9,400.00
Balance less gross proceeds of the sale (3 - 4) (5) $ 5.136.17
Add: Expenses of retaking and storing, and (6) $
any attomeys' fees allowed by law, and 592.00
expenses of reconditioning and selling.
Deduct: Insurance Premium Rebate (7) $ 0.00
Other: (8) $ 0.00
Deficiency** (9) $ 5728.17
Surplus* (10) $ N/A
The Surplus/Deficiency will change based on monies
added to your account (debits). received by us (credits) or additional all owed expenses & interest
Surplus` or Deficien
"
cy
` If the sale resulted in a surplus, a refund for the diff erence 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
P.O. BOX 6508 Ford Motor Credit Company
MESA ARIZONA 85216-6508 DEPT 194101
(800) 732-2264 P.O. BOX 55000
DETROIT MI 48255-1941
FFNA11990 01104 Previous editions may NOT be used.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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Ford Motor Credit Company
Case Number
vs.
Edward Kennedy 2010-4112
SHERIFF'S RETURN OF SERVICE
07/02/2010 03:27 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on July 2,
2010 at 1520 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Edward Kennedy, by making known unto Larry Kennedy, Father of defendant at 247 F
Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to
him personally the said true and correct copy of the same.
STEPHEN BENDER, DEPUTY
SHERIFF COST: $38.80
July 06, 2010
SO ANSWERS,
M
RON R ANDERSON, SHERIFF
~ci Conn+, Suite Sheriff. Teleosntt. Irc.
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
Ff~r__ f.~i ` _
,fi.- T ;~,, ,.. , ~4,
. ~ ._
2010 Ju'_ 22 ~'•; 6~~~ u
i~ A'. ^~
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(L1J) /2Sy-/1J1
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
v.
EDWARD KENNEDY
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 10-4112 Civil Term
Defendant(s).
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the verification of the Plaintiff, FORD MOTOR CREDIT COMPANY,
A Delaware Limited Liability Company, for that of the verification previously filed.
Respectfully submitted,
MAURICE & NEEDLEMAN, P.C.
JOA MAN, ESQUIRE
Attorn for Plaintiff
Date: July 20, 2010
CERTIFICATE OF SERVICE
I, Joann Needleman, Esq. hereby certify that on this date I have caused a true and correct
copy of the foregoing Praecipe to Substitute Verification on behalf of FORD MOTOR CREDIT
COMPANY, A Delaware Limited Liability Company, to be served by regular, first class mail,
postage pre-paid upon:
EDWARD KENNEDY
247 F St
Carlisle, Pa 17013
Respectfully Submitted,
MAURICE & l~EEDLEMAN, P.C.
~-
BY:
Jo an, Esquire
Attorney for Plaintiff
DATED: July 20, 2010
v ~ R
VERIFICATION
I, Bi~lVBt~"~% 4/1~8i1t1@1/~. ,verify that I am the Authorized Representative for
Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A Delaware Limited Liability
Company, and are duly authorized to take 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: !/
Representative of Plaintif~ j;
FORD MOTOR CREDIT COMPANY LLC,
A Delaware Limited Liability Company
DATE: ~LD~ 0 4 2~"
EDWARD KENNEDY
Ow file no. 11862
48063000000039338892
v
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7151
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
v
EDWARD KENNEDY
Defendant(s)
? "a?-?11=EICE
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i`tJ
Attome ` o` aiof
+}=4rOEf?LAND COUNT
:
PEKASYI.\IANt
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-4112 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, EDWARD KENNEDY in the amount as follows:
Principal Amount $ 5728.17
Interest to Date $ 1351.00
Costs $ 130.80
TOTAL
Date: July 21, 2011
MAU
BY
JOANN NEEDLEMAN, ESQ.
Attorney for Plaintiff
04n+-al4.00?d a?
4*,Qw (9
?V (I wc?ted
$ 7209.97
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
/Z5V-/1J1
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
v
EDWARD KENNEDY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-4112 CIVIL TERM
AFFIDAVIT OF MAIL SERVICE
STATE OF PENNSYLVANIA
SS.
COUNTY OF PHILADELPHIA
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she is an attorney at law and that on 7/6/2011 she mailed a written Notice of Intention
to File the Praecipe to Defendant, EDWARD KENNEDY, at 247 F ST, CARLISLE, PA 17013
by regular mail.
MAURIC EEDLEMAN, P.C.
BY:
OANN NEEDLEMAN, ESQ.
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED
before m this pa
O1? '
otary ublic
F OTARIAL SEAL
ETTA ROBINSON
Notary Public
ITY, PHILADELPHIA COUNTY
ion Expires Mar 23, 20' S
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
I N 7x9-7151
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
EDWARD KENNEDY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-4112 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
7/6/2011 to Defendant, EDWARD KENNEDY, 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 7/6/2011, a copy of the mailing to the Defendant and affidavits of
service are all attached hereto.
MAZA DLEMAN, P.C.
BY:
NEEDLEM
AN, , ESQ.
Attorney for Plaintiff
Date: July 21, 2011
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(215) iZ5y-/ 1J1
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
v
EDWARD KENNEDY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-4112 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: EDWARD KENNEDY,
247 F ST ,
CARLISLE, PA 17013
MAU ICE LEMAN, P.C.
BY:
JOANN NEEDLEMAN, ESQ.
Attorney for Plaintiff
Date: July 21, 2011
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
/bV-71 J 1
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
EDWARD KENNEDY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-4112 CIVIL TERM
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
SS.
COUNTY OF PHILADELPHIA
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she represents the Plaintiff in the above entitled case and that Defendant, EDWARD
KENNEDY, is over 18 years of age; the occupation of Defendant is unknown and to the best of
Plaintiffs knowledge, information and belief, Defendant is not in the military service of the
United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and
Sailors' Civil Relief Act of 1940 and the amendments thereto.
MAURICE/& 1EIILEMAN, P.C.
BY:
ANN NEEDLEMAN, ESQ.
Attorney for Plaintiff
SWORN TO WNUBSCRIBED
before me tO , 201) NOTARIAL SEAL
RASHETTA ROBINSON
Notary Pub is Notary Public
PHILADELPHIA CITY. PHILADELPHIA COUNTY
My commission Exoires Mar ?3 ?015
Attorneys at Law
cite 935, One Penn Center
17 John F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215,665.1133
fax 215.563.8970
www.mnlawpc.com
Donald S. Maurice
Member NJ Bar
Board Certified
Creditors' Rights Law
rican Board of Certification
Joann Needleman
Member PA & NJ Bar
Thomas R. Dominczyk
Member NJ, NY & PA Bar
Rachel Marin
Member NY & NJ Bars
New Jersey Office
Aaurice & Needleman, P.C.
Suite 2007
5 Walter E. Foran Blvd.
Flemington, NJ 08822
tel. 908237.4550
fax 908.237.4551
July 6, 2011.
EDWARD KENNEDY
247 F ST
CARLISLE, PA 17013
RE: FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY v. EDWARD KENNEDY
CUMBERLAND COUNTY COURT OF
COMMON PLEAS, CASE NO. 10-4112 CIVIL
TERM
Dear MT/Mrs/Ms KENNEDY:
Our File No. 11862
Enclosed please find a ten (1.0) day notice of default which is self-
explanatory. This is being served upon you due to your failure to respond to
Plaintiff s Complaint served upon you on "14/0- unless an answer to Plaintiff s
Complaint is filed with the Court within ten (10) days from the date of this notice,
a default judgment may be entered against you.
If you would like to discuss a resolution to this matter, please call our office at
908-237-4571. and ask for Kim Crosby.
Thank you for your prompt attention to this matter.
Very truly yours,
MAURICE & NEEDLEMAN, P.C.
i
Joann eedleman, Esq.
JN/dlh
Enc
THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A
DEBT, AND ANY INFORMATION OBTAINED WILL BE USED
FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
/69-/1JS
FORD MOTOR. CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
EDWARD KENNEDY
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-4112 CIVIL TERM
IMPORTANT NOTICE
TO: EDWARD KENNEDY DATE: July 6, 2011
247 F ST
CARLISLE, PA 17013
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 TIES NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
MAU CE & NEEDLEMAN, P.C.
I
BY
JOA NEEDLEMAN, ESQUIRE
Attorney for Plaintiff
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith°
Chief Deputy
Richard W Stewart
Solicitor OFFICA CIF THE SnRIF€
Ford Motor Credit Company
vs. Case Number
Edward Kennedy 2010-4112
SHERIFF'S RETURN OF SERVICE
07/02/2010 03:27 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on July 2,
2010 at 1520 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Edward Kennedy, by making known unto Larry Kennedy, Father of defendant at 247 F
Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $38.80
July 06, 2010
49Z???
STEPHEN BENDER, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
+sj cmn!"Sulte sherM, 1 ereasoft. Inc
Request for Military Status
Department of Defense Manpower Data Center
Yj` Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Aug-03-2011 09:00:44
-< Last First/Middle Begin Date Active Duty Status Active Duty End Date Service
Name Agency
Based on the information you have furnished, the DMDC does not possess
KENNEDY EDWARD any information indicating the individual status.
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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
14
4b,
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 DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as 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 status by contacting that person's Service via the
"defenselink.mil" URL http://www.defenselink.mil/fag/pis/PC09SLDR.htm1. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional 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 active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.mil/appj/scra/popreport.do 8/3/2011
Request for Military Status
Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:80QVGOUMFJ
https://www.dmdc.osd.mil/appj/scra/popreport.do 8/3/2011
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
Our file no. 11862
(21J) /89-/1J1
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
v
EDWARD KENNEDY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-4112 CIVIL TERM
(X) Notice is hereby given that a judgment in the above-captioned matter has
been entered against you in the amount of $7209.97 on
(X) A copy of all documents filed ith the Protho ary in suppo f the
within judgment is enclosed.
erk
MC . of o ry
by:
If you have any questions regarding this matter, please contact the filing party:
Name: Joann Needleman, Esquire
Address: Suite 935, One Penn Center at Suburban Station
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Telephone No.: 215-789-7155
(This Notice is given in accordance with Pa.R.C.P. §236)