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Home My WebLink About10-4214MAURICE & 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 C7 ARBITRATION MATTR m ASSESSMENT OF D , G HEARING NOT RE(_ )f#EDIV ??t? Attorneys for Plaintiff y - ? r _ l? _ Li L ! - w, -7 15) 7219-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. BRIAN M HEINRICH 2 W Springville Rd Boiling Sprgs, Pa 17007-9739 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 10 - 4 a l q 0,, j 1 T°U'141 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. CIVIL ACTION COMPLAINT AVISO Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demands y Is notificacion. Hace falta asentar una comparencia escrits o en persona o can un abogado y entregar a la cone en forma escrita sus defensas o sus objeciones a las demandas en contra de su 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, la 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 para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SURCIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 (1-0 -0a . op PA ATN 6+ as lsy w* a&Naoo 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 ("L 15) "/tSy-/ 155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. BRIAN M HEINRICH 2 W Springville Rd Boiling Sprgs, Pa 17007-9739 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, Brian M Heinrich, is an individual who resides at 2 W Springville Rd Boiling Sprgs, Pa 17007-9739. 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 September 2, 2006, 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 $24315.00 at an annual percentage rate of 0.000%, in order to purchase a certain motor vehicle, 2006 Mercury Milan 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 $337.70 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 July 29, 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 $5000.00, however a balance of $9682.76 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. The total amount due and owing at the time of the filing of this complaint is $9682.76. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $9682.76, 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 submitted, MAURICE & NEEDLEMAN, P.C. Attorney A.)rAkYLOR, ESQUIRE Date: June 17, 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: June 17, 2010 DELAWARE SIMPLE INTEREST VEHICLE RETAIL INSTALLMENT CONTRACT DATE e91132/Mm Coauyal Nrn..uitl llaem (MU6q Oonq NM NUMB REDROM (war Hur a d Aeswl 14NW727-700D Wqw I'll a Zb ALBERT 11EI9EHFELD BRIAN M HEINRICH HERTRICH'S OF MILFORD 18646 SNDMYISS RUN 693 DUPONT BLVD ® REHOBOTH DE 19971 MILFORD DE 19%3 Iaww.fortleratliLeam Pon, d Yw. Is ehhY.r led Ce boar b RhwrnW ti !Ye wyt, Phim.Ea By .'Byerip'•O ng Ihs -0.0, pN0am aadicTMompinb sanern'GN TM en • •i• ewwbl V. d-lo0w 10 b toy tlr w Ner on -0 -0. On Yr ep.rnRw on w k et Ond w b.sk of Yb NEII 7 1 j 2m I MERCURY ILAN 1ENIS7286R666BB3 1311 0 As-- Camnmdel TwarN 2882 FORD TRIM .need vwranww itw.rArarr. INSURANCE ITEMIZATION OF AMOUNT FINANCED YOU ARE REQUIRED TO INSURE 1. Cash Gain Price t °•?> THE VEHICLE. YOU MAY OBTAIN 2 Dorn Payarnt VEHICLE INSURANCE FROM A Third Perly Rabat Assigned to Creditor a PERSON OF YOUR CHOICE. C Pay on III/a N/A LIABILRY INSURANCE COVER- i Tnd.4a (dsrrlpton.bow) AGE FOR BODILY INJURY AND Tolr Down l y an PROPERTY DAMAGE CAUSED 3, UnPlId Bamlw N Cash a010 Pdon (1 minus 2) .._..__..?_.. t oil= ) TO OTHERS IS NOT INCLUDED. Amount@ paid on your R (Sollor MW be ro a d ???1 ~ T PIeBO pool. CREDIT UFE, CREDIT DISABIL- m for sorwe, aw A comes" ITY AND OTHER OPTIONAL IN- wes s _125. M SURANCE ARE NOT REQUIRED t0r oar b°6 i TO OBTAIN CREDIT AND WILL 01) INS feria (rot I. Cash SW Pike) t 294. Bit tg? NOT BE PROVIDED UNLESS rortiurrwa Comentsea for. Credit Ub InwMaw._-_--------_.r.-_..--- YOU SKIN AND AGREE TO PAY Cost DlaawM Ilwnww. a NOR THE PREMIUM. N/A Credit To NERTRITI/'S DF inn Ity... menu ccs i__ OLbe-wee To N/A bit N/a tNOR Insurance Company To N/A for min S - AA $ To RHIS fw Dee rNam.mr S_{ryD'8- KW hwune(a) To N/A fm el/a You want Credit Life kwurarpa. To - N/A for ./. i Tom.__.____..._?--__._._-_--.____..-._._- t? IA t. Arrwa FThnarhb.d (i qua 1)__...__-__ _.. iN(e) Buyer Sipes FE DERAL TRUTH 4&iMNWM DMCLOSUM S ANNUAL PERCENTAGE FINANCE CHARGE Amount Fi d Total P Total Sal" CO-Buyer Signs RATE nance a Prteb Cradb TM d.br n n um Tie awwua of Th..hrheas Tos tom ern O DlaabiMy TM- ol? end b as y.sM roe tlr a.a we WN Ypl oeaa rWUpa sari. ywr erne. .111hom vaMld rlwn wu lhase we. d of yen pee ses al era, rw.aq Yew Inuunbe It u'A "A .ana?ws d.wriP.Yrrer. Premium Irtwred(s) You wall Credit DW W ty bra. v "a*r tl swear. Buyer Sipe Alllaab of em-ft Teton Re a me w mw Ollsontift D OAam.y Co-Buyer $iprls N/A OTHER OPTIONAL INSURANCE Covens I Cis x Premium Mo u Pnp.yerahb .ywpayryewd ftft.Yoneranitleasbpry.moby. Lae. P.Ywwnt Yon aW pry. W tliwP m M poraw tl ..rah plant nawrW awn tan 10 N/e t s.y. br.1» awed. r o view. a se w.mwn a shoo, wiww,w r w.. e..attr bale..! Yw w *AV - --IIY.wa.e In w w vary pu lonoi BY N/e I IM Conbonh Pkno .- Rr noon.. for .dowel .weawli.h w n-y sni..I. IheeP•Yr•.r4 d.%A on, " In neem nP-Mea a ywt one In w elan she .deewal d.1R artl N/e a N-A BALLOON CONTRACT PROVISIONS Bllu'A yyp--- - ? Your IM bmeirM U P•yrem udw this oonboa 0 a baboon payment. You went tie optional b omens for Mich Ear'PCB WEANS. INS! AND 111"RoE CHARM p.neueu w Inckdad.bow. 11 a , bw dbecay abaw is ch dwd, ens section, Propnph B, and Pwsgwh c S one oonbaa W01Y You -lay w .-Toed IN Wall" war bond upon our standards for Bw r Sign nrnW we. it you aarwr raw option to 1411 the vehlele bast In Creditor Moor Pwpaph B, you must pay ae CNIV- SO /a pr man br ran man in ease.. of WA man Shown w the hdomewr. Coauyer Sion Credit Lim a w Cod! OWbNC k Ant, ayhpe bit rlo nh healr mate one er raw C.~. y raaraar wforthatam Ntlla earalrLTM araaulrM and w.ara0ae w ahem M ¦ now or, tyuyr Sltrra atParart alvr b You bd.p. 54br1omens n Warr Asersaa lapo.w) Ce•auyar alto X ? I[i6L/L7C(L a we er r ard.e fm hero P.Srsw s haw " araRm.ebr. Ph.Wle.aer onl.per p YOU THAT You HAVE READ AND AGREE TO BE BOUND 4 .Ion of i on n din bmrr w an TM habeas In m sea sl.rn n N on w In ON ! BY THE E ARBRpA710N PROVISION ON THE REVERE! SID! OF THIS ARBITRATION s' O e rrsin w, IN erea.e. T? on pdo, law br Ackbolm w Man ba era nswa e, em, r CONTRACT. 1 r ion on sw wwrl I. sr H.W.M. n a Tile Annual Is Can tope Rob may be nwpotiated with On Seller. The Better F a aa may nation tFas ..resat and may ratan ft right to noaha a poMlon of the F Fineness, CM allm NOTICE TO TN UVER I- Do not sign this contrast beta- you read it or N N contents any blank specs& 2. You we entitled 10 an ebeet Copy of the eoNaet you sign, Buyer (and Co"BNTM aNmarled" Bet n) bafae INIMM this Lrontract Buyer (and Co•Buper) reeaived and reeler-d a true and eompbtey Hand M now or Ilea contract and (B) N tin Won, o s g*w this -Buyer (and Co-Bayer) rerived a trite. an eomple" Rlad in spy of this aarl6oet. f Buy. 7(/• 'I r X SNbr1ERTRlb1'S OF MILFORD By Ti ` ,yam` .?/ lde THIS CONTRACT IS NOT VALID UNTIL YOU AND BELLtDt SIGN R. 6 ¦?yerwp, 7rw y?egn AAssedNYINT won any ban.wr ern wahraJa rRr hNn GNEDIT Lp?R11Y M.n nerd w wV. AebP. Prl.wtiw. aW me en.. my .ylhbip Mrw, as FNRD sw an, nape awn tshV W b i 1'A..yaw'l. To ®rhwa Anipso abae qft cement siBM) 727-7BaB r.fd uhn4.aeaa. anon r OROCII?7-T Cell IIERTRl0VS OF MILFORD ay x t W is iieoiala ' ' -' •.._..._.._-- °•..,•. ° ""°., se Dotal ea rM AprDp..L AaMaelsrrs ' OR-rAL a51 u LE --------------- ------------------------------P E9 2TSaRETII . H, IS SUBJEQI K) ALL CL). MS AN 'DEFENSES WHICH THE DEBTOR COULD ASSER. , AGAINST THE SELLER OF GOODS OF SERVICE- - u.. :OBTAINED PURSUA% HERETO OR WITH TNT PROCEEDS HEREOF RECOVERY HEREUNDER Be THE DEBTOR SHALL NO' -USED AMOUNTS PAID! nr tlv'IHE DEei'OR ME rao-Y.' 1 -13ATION v- ?I 'rtMALION ON IN, WIJ.' 1NY CONTRARY PROD, JTRP,: )F SALE, ' ayrv?inr 5ACY.EH ALL PTS lf-0-1'O-HCAUI 5 SCRE-EC - '-PRN"' Ford Motor Credit Company P.O. Box 17948 GREENVILLE, SC 296068948 (877) 8057187 POWI00002=1 BRIAN M. HEINRICH 20 W SPRINGVILLE RD BOILING SPRGS PA 17007-9739 Date of Repossession 10-14-2009 Date of Notice 10-162009 Date of Contract 09-02-2006 Account Number. 041429008 Buyer BRIAN M. HEINRICH Co buyer ALBERT WEISENFELD DESCRIPTION OF PROPERTY Year 2006 Make MERC Q New ? Used Vehicle Identification Number. 3MEHM072.86R686803 Model 7 MILAN dy 4DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke prornises in our agreement. It. t1. 7x 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 alcove unless redeemed by you date). The sale will be held as follows: prior to such sale. Date of Sale row 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 unde your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. The property is presently stored at: MANHEIM AUTO AUCTION 1190 LA AST 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 $ 14,198.90 Plus Costs: Repo Expenses $ 370.00 Plus Late Charges $ 32.70 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 14,601.80 (Plus expenses incurred If default at the time of repossession exceeded 16 days and less rebate received after the date of this notice.) Your property won't be sold until 15 days after the date of this notice at the EARLIEST. After that you can still get it back any time before its actually sold. If you do, we'll have no further claim on 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 ft to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the net 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 (tut 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 1198"7 Jan 02 Precious editions may NOT be used. CUSTOMER/CUSTOMER FILE Printed in U.S.A. "'PRN'•' Ford Motor Credit Company P.O. Box 17948 GREENVILLE, SC 29608.8948 (877) 8057187 PMIOC D0200006 ALBERT WEISENFELD 6351 SPRING RIDGE PARKWAY APT 311 FREDERICK MD 21701 Date of Repossession 10-14-2009 Date of Notice 10-16-2009 Date of Contract 09.02-2006 Account Number. 041429008 Buyer BRIAN M. HEINRICH Cobuyer ALBERT WEISENFELD DESCRIPTION OF PROPERTY Year 2006 Make MERC ?x New ? Used Vehicle Identification Number: 3MEHM07Z86R666803 Model MILAN Body 4DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke prornises in our agreement. 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 16 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 attomey'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. The property is presently stored aY. MANHEIM AUTO AUCTION 1100 LANC ER R 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 $ 14,198.90 Plus Costs: Repo Expenses $ 370.00 $ Plus Late Charges $ 32.70 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 14,601.60 (Plus expenses incurred If default at the time of repossession exceeded 16 days and less rebate received after the date of this notice.) Your property won't 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 ki ger you wait, the more costs (including repairs) you may have to pay. If you have any questions about this, please call us. L1 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. VERONICA D. NOGSUERA FFNA 11QW37 Jan 02 Previous editions may NOT be used. Printed in U.S.A CUSTOMERlCUSTOMER FILE U.S.A. M M1 M C3 C3 C3 r-q C3 C3 C] s _o C3 C3 IT M1 1 Name and Address of Sender Type of Mail Affix Stamp Here Lason Systems, Inc. L1 certified (If Issued as a Certificate Of 38120Amrhein C?1 Rctuntkewpt malling,orfor additional Livonia MI 48150-5016 copies of this bill) Postmark and Date ofRec ' _ 1 Article Number Addressee (Name, Street, City, Stale, Zip) a Postage Fee RR Fee 1 OW 10000200001 10416,16775 7190 0640 0010 0164 0373 CARLA MOATS 18 COOLPOND CT $0.357 $2.800 $1.100 HALETHORPE MD 21227-3838 2 OW100002000021042026608 7190 0640 0010 0164 1165 LEE D. TRENT 1613 WISE RD '. $0.357 $2.800 $1.100 POINT OF ROCKS MD 21777-2054 3 OW 10006200003 1040499345 7190 0640 0010 0164 1172 PAULA M. COLWELL $0 357 $2 800 $1 100 2434 KNAPPS WAY t . . . ODENTON MD 21113-3226 4 OW 10000200004 1 042651922 7190 0640 0010 0164 1189 PO DAVID BOXT. 1164 SMALL SR PO BO $0.357 $2.800 $1.100 EDGEWOOD MD 21040-0464 5 I OW100002000051044852843 7190 0640 0010 0164 1202 ANTHONY B. MALONE $0 357 $2 800 $1 100 4417 FALLS BRIDGE DR , . . BALTIMORE MD 21211-1035 6 OW10000200006 042934594 7190 0640 0010 0164 1219 PO ROB BOX 14OX 1473WEYANT; $0.357 $2.800 $1.100 FREDERICK MD 21702=0473 C STp 7 OW10000200007 041616775 ' ?? \ : ?? \ G 7190 0640 0010 0164 1561 WILLIAM R. LANDIS - 1076 DOWNTON RD - $0.357 $2.800 $1.100 t ?? ?n t Oct I I HALETHORPE MD 21227-3944 Ala 1 8 OW10000200008 1041429008 7190 0640 0010 0164 1585 ALBERT WEISENFELD 6351 SPRING RIDGE PARKWAY APT 311 $0.357 $2.800 $0.000 FREDERICK MD 21701-5926 Total No of Pieces Total Number of Pieces Postmaster, Per (Name of Receiving Employee) Listed by Sender Received at Post Offc Lason F MCC PostRepo Certificate of Mailing October 16, 2009 1 Page f of 5 Narne and Address of Sender Ln,1 Lason Systems, Inc. 38120 Amrhein o? Livonia MI 48150-5016 O! Type d Mail Affix Stamp Here (If Issued as a Certified canifieate of Rettim Receipt i mailing, or for additional copies of INS Gip) Postmark and Date of Receipt a' Article Number Addressee (N". Street. City. State, Zip) 5 C OW 100002000251039908746 7190 0640 0010 0164 1554 JAMARRJ. RAMEY A 4051 BOYER RIDGE CANAL WINCHESTER OH 43110-7822 26 M1 OW100002000261043262479 7190 0640 0010 0164 1615 RENEE HALL 4776 W. LAGOON ROAD !!! t WEST FARMINGTON OH 44491-9796 1;. ( j 27 OW100002000271041472626 I' 7190 0640 0010 0164 0380 JEFFREY A. PHILLIPS ; 596 FINGERBOARD RD 1 WARFORDSBURG PA 11267-8003 28 OW100002000281044327509 7190 0640 0010 0164 0397 GARRYL.BOYER 4291 W CANAL RD t DOVER PA 17315-4019 r 29 OW100002000291042426942 ' 7190 0640 0010 0164 0403 LAWRENCE HOOVER 1137 W ELM ST SCRANTON PA 18504-2138 t 30 i OW 100002000301040928055 i 7190 0640 0010 0164 0410 DONALD HARTMAN ; 228 EWE RD 1 MECHANICSBURG PA 17055-4872 1 ` OW100002000311041429008 7190 0640 0010 0164 0427 BRIAN M. HEINRICH ' . 20 W SPRINGVILLE RD ' BOILING SPRGS PA 17007-9739 i 32 OW100002000321043319033 7190 0640 0010 0164 0434 KRISTINE K. FICK 1378 GRANDVIEW DR HANOVER PA 17331-9541 I Total No of Pieces Total Number of Pieces Postmaster, Per (Name of Receiving Employee) Listed by Sender Received at Post Office -Cason FMCC PostRepo Certificated Mailing October 16, 2009 Postage I Fee I RR Fee $0.3571 $2.8001 $1.100 $0.3571 $2.8001 $1.100 $0.3571 $2.8001 $0.000 $0.3571 $2.8001 $0.000 $0.3571 $2.8001 $0.000 $0.3571 $2.8001 $0.000 $0.3571 $2.8001 $0.000 $0.357 1 $2.8001 $0.000 eo_ posr'q a t i Page 4 of 5 Ford Motor Credit Company P.O. Box 17948 Greenville, SC 29606 1-877-805-7187 DATE: 18 NOVEMBER 2009 ALBERT WEISENFELD 6351 SPRING RIDGE PARKWAY APT 311 FREDERICK, MD 21701 STATEMENT OF SALE Account Number: 041429008 The following property has been sold. Year Make Model Vehicle Identification Number. 2006 MERC MILAN 3MEHM07Z86R666803 Gross balance owing on your contract (1) $ 14,231.60 Deduct: Finance Charge Rebate (2) $ 0.00 Balance owing prior to sale (3) $ 14,231.60 Deduct: gross proceeds of the sale (4) $ 5,000.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 9,231.60 Add: Expenses of retaking and storing, and (6) $ 595.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ 143.84 Other: (8) $ 0.00 (9) $ 9,682.76 Deficiency` Surplus* (10) $ 0.00 The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest added tour 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 CREDIT NATIONAL RECOVERY CENTER FORD MOTOR CREDIT COMPANY P.O. BOX 6508 P.O. BOX 55000 MESA, AZ 85216-6508 DEPT 194101 1-800-732-2264 DETROIT, Ml 482551941 FFNA11990 01104 Prewous ealom may NOT be used. ot;/li£ 29TL9T£ST9 dnc)jo anT4OwO4ny -xaTwasd Hd Z£ ° 1i0 6002-noH-gT Ford Motor Credit Company P.O. Box 17948 Greenville, SC 29606 1-877-805-7187 DATE: 18 NOVEMBER 2009 BRIAN M. HEINRICH 2 W SPRINGVILLE RD BOILING SPRGS, PA 17007-9739 STATEMENT OF SALE Account Number: 041429008 The following property has been sold. Year Make Model 2006 MERC MILAN Gross balance owing on your contract Deduct: Finance Charge Rebate Balance owing prior to sale Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and staring, and any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Other: Deficiency" Vehicle Identification Number. 3MEHM07Z86R666803 (2) $ 0.00 (4) $ 5,000.00 (6) $ 595.00 (7) $ 143.84 (8) $ 0.00 (1) $ 14,231.60 (3) $ 14,231.60 (5) $ _ 9,231.60 (9) $ 9,682.76 Surplus* (10) $ 0.00 The SurpluelDeficiency will change based on monies received by us (credits) or additional allowed expenses & interest added to your acoount (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 CREDIT NATIONAL RECOVERY CENTER FORD MOTOR CREDIT COMPANY P.O. BOX 6508 P.O. BOX 55000 MESA, AZ 85216-6508 DEPT 194101 1-800-732-2264 DETROIT, MI 482551941 FFMI1990 01104 PMv100 sd M may NOTbe used, Otr/EL Z9TL9TE9T9 dno.z0 anT4ouioj?ny saTwa..rd Kd ZL'ir0 6002-nON-BT SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ., Sheriff ;; <'~~ ` ~~ Jody S Smith ~' ~~ '~ }-,~ Chief Deputy ~~ ~-~ ~'~~ ~~~~ ~~~ _~ ~~~ ~j: 4~ Richard W Stewart ~ " SOiICltOr 4Ff i4E C`= "~•~ SHERIFF ~j ,~ cut,~~.~~ A ;.~., ~I ~ :~a. Ford Motor Credit Company Case Number vs. Brian M. Heinrich 2010-4214 SHERIFF'S RETURN OF SERVICE 06/30/2010 05:12 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 30, 2010 at 1710 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Brian M. Heinrich, by making known unto Mark Heinrich, Fathe f defendant at 2 W. Springville Road, Boiling Springs, Cumberland County, Pennsylvania 7 its o tents and at the same time handing to him personally the said true and correct copy of the c AWN HA ISON, DEPUTY SHERIFF COST: $33.40 July 01, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ;c) CountySuite St?eriff. Teieosoft. Inc. 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 (11J) /z59-/I.-)l FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. BRIAN M HEINRICH AND ALBERT WEISENFELD Defendant(s) r? PRAECIPE TO ENTER JUDGMENT v .a TO THE PROTHONOTARY: _ =t No answer having been filed in the above Civil Action, kindly enter Judgment in favor of Plaintiff, and against Defendant, BRIAN M HEINRICH in the amount as follows: Principal Amount $ 9682.76 Costs $ 125.40 TOTAL $ 9808.16 Date: October 29, 2010 Pd, ?/N40 9#q dll9dkmltn 00 ;sra4? ti1654u rykcGrl CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4214 MAURICE & NE LEMAN, P.C. BY: JOA EEDLEMAN, ESQ. Attorney for Plaintiff . I 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 15) 789-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. BRIAN M HEINRICH AND ALBERT WEISENFELD CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4214 Defendant(s) (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $9808.16 on p (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. Prothonotary/Clerk 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) 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 15) 789-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. BRIAN M HEINRICH AND ALBERT WEISENFELD CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4214 Defendant(s) AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she is an attorney at law and that on October 14, 2010 she mailed a written Notice of Intention to File the Praecipe to Defendant, BRIAN M HEINRICH, at 2 W SPRINGVILLE RD , BOILING SPRGS, PA 17007-9739 by regular mail. MAURICE & NEEDLEMAN, P.C. BY: (Y- JOAN"EEDLEMAN, ESQ. Atto ey for Plaintiff ORN TO AND SUBSCRIBED fore me thisa' day 00 o 0 , 2000. No tary A d I ?C. I ` COMMONWEALTH OF PEW4SYLM%ta NOTAF SEAL Tausha P. MPublic City of Philadelphiy Cq?, M Common 20112 Membor, RWWWMVonioAmOclabnof 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) 789-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. BRIAN M HEINRICH AND ALBERT WEISENFELD Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4214 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on October 14, 2010 to Defendant, BRIAN M HEINRICH , 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 October 14, 2010, a copy of the mailing to the Defendant and affidavits of service are all attached hereto. MAURICE & NEEDLEMAN, P.C. BY: for Plaintiff , ESQ. Date: October 29, 2010 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 15) 789-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. BRIAN M HEINRICH AND ALBERT WEISENFELD Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4214 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: BRIAN M HEINRICH, 2 W SPRINGVILLE RD, BOILING SPRGS, PA 17007-9739 MAURICE & EDLEMAN, P.C. BY: (A' JOA NEEDLEMAN, ESQ. Attorney for Plaintiff Date: October 29, 2010 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 /z59-/1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. BRIAN M HEINRICH AND ALBERT WEISENFELD Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4214 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that he/she represents the Plaintiff in the above entitled case and that Defendant, BRIAN M HEINRICH, 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. MAURIC2&EEDLEMAN, P.C. BY: JO EDLEMAN, ESQ. Attorney for Plaintiff WORN TO AND SUBSCRIBED fore me thisQjtay 4?_ 2000. ubli- COWX*MMTH OF PENNSYLVNM NOYAR" SEAL Tausto P. MaW. ary Pubk Commission . Ph ad$Wft COU* M [c-EWfttAffit2? ?1 I Q rem pwWw vam Aetwww d SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Or dcwh6p V. .KY'As OFF C& OF ( RIFF / 333 Jody S Smith Chief Deputy Richard W Stewart Solicitor Ford Motor Credit Company Case Number VS. Brian M. Heinrich 2010-4214 SHERIFF'S RETURN OF SERVICE 06/30/2010 05:12 PM - Shawn Harrison, Deputy Sheriff, who being duly swom according to law, states that on June 30, 2010 at 1710 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Brian M. Heinrich, by making known unto Mark Heinrich, Fath f defendant at 2 W. Springville Road, Boiling Springs, Cumberland County, Pennsylvania 7 its tents and at the same time handing to him personally the said true and correct copy of the c DEPUTY SHERIFF COST: $33.40 July 01, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF c; COtrtySul(e Shen1. TefeoW..'(, ircC co r. D E O;u vn mm r m =ZZ vzv DmZ Z m v w?M v z -D 0 00 N W 0 * Cl) D G) Z CA z= _ XCm Q) r ? D;u 2 -4 0 o = 6 _ -4 CA) to O'?+ vci -4 MVP Nm?y:p ?o°wtNi?mlo L6L£9SS000SZ90 Attoreeys of Low Suite 935, Dan Penn Center 1617 John F. Keemdy Blvd. Philadoon, PA 19103 te1.215.665.1133 fax 215.563.A970 www.mniawpc ma Donald L Maurice Member NJ Aar Hoard Certified Creditors tights law American lewd of Certification Joann Needleman Banker PA & NJ Bar Thomas R. Domincxyk Member N1, NY A PA Bar October 13, 2010 BRIAN M HEINRICH 2 W SPRINGVILLE RD BOILING SPRGS, PA 17007-9739 Our File No. 13337 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. BRIAN M HEINRICH AND ALBERT WEISENFELD CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 104214 Dear Mr/Mrs/Ms HEINRICH: Enclosed please find a ten (10) day notice of default which is self- explanatory. This is being served upon you due to your failure to respond to Plaintiff's Complaint served upon you on 6/30/10. Unless an answer to Plaintiffs 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. Esq. New Jersey Office Mourke & Needleman, P.C. Suite 2007 5 Welter E Foran Blvd. Ffaudngton, NJ OAA22 tel.90A137A550 fax 908.237.4551 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 15) -189 / 1:)l FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. BRIAN M HEINRICH AND ALBERT WEISENFELD CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4214 IMPORTANT NOTICE TO: BRIAN M HEINRICH DATE: October 13, 2010 2 W SPRINGVILLE RD BOILING SPRGS, PA 17007-9739 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICE & NEEDLEMAN, P.C. BY ',. JO LEMAN, ESQUIRE Atto Y for Plaintiff request for Military Status ? tus response retlects active duty status inducing date ttle individual was last on active dtiit y, if it was within i:he preceding 367 days. For historical information, please contact the Service SCRA points- Department of Defense Manpower Data Center Mar-11-2010 08:09:12 of-contact. Military Status Report Pursuant to the Service Members Civil Relief Act Last ?1rs s'ln Date Active Ditty mss' Active Dotty Ant e 1Fla?r?e Arme Based on the information you have furnished, the DMDC does not possess any information HEINRICH BRL4N 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). Mary M. Snavely-Dixon 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 hM://www.defenselink.mil/fag/i)is/PC09SLDR.html. 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. 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 Request for Military ?tatu? 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:BA2BDL094M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, a : No. 10-4214 Delaware limited liability Company • Plaintiff • vs. :CIVIL ACTION BRIAN M. HEINRICH and ALBERT • WEISENFELD Defendant -f C PRAECIPE FOR SUBSTITUTION OF COUNSEL TO THE PROTHONOTARY: Kindly substitute the undersigned as counsel for the Plaintiff in the above entitled matter. The undersigned hereby consents to this substitution. OS— Ll oy d S. Markind, Esquire (ID # 52507) Jo<nn Needleman, E sq uire* Amy F. Doyle, Esquire (ID #87062) Withdrawing attorney Superseding Attorney Maurice &Needleman, P.C. Sklar–Markind 935 One Penn Center 102 Browning Lane, Bldg B, Ste 1 Philadelphia, PA 19103 Cherry Hill,NJ 08003 ID#74276 Dated: July 23, 2013 Dated: July 23, 2013 * Signed with permission of Joann Needleman, Esq. FILE NO.: FT114893