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Home My WebLink About10-3630MAURICE & 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 15) 759-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. CHARLOTTE A BOYLES 139 Cme Newville Newville, Pa 17241 CHARLES R BOYLES 139 Cme Newville Newville, Pa 17241 Defendant(s). 4 IV c._ m r:I Z .- . Z 1 - ca 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. l.1 V 11L AUTIU y COMPLAINT AVISO Le ban demandado a usted en ]a Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dies de plazo al partir de Is fecha de Is demands y Is notification. Haze falta asentar una comparencia escrita o en persona o can un abogado y entregar a Is Corte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, Is torte tomara medidas y puede continuar Is demands en contra suya sin previo aviso o notification. Adernas, Is Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demands. Usted puede perder dinem o sus propiedades u otros derechos importantes Para 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 OFICWA 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 c? 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 4Qa.6O pp AT" e a( ala e4g3W7 CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 10 - 3(pW C?vil I?.x a? 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 (21-5) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. CHARLOTTE A BOYLES 139 Cme Newville Newville, Pa 17241 CHARLES R BOYLES 139 Cme Newville 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, Charlotte A Boyles, is an individual who resides at 139 Cme Newville Newville, Pa 17241. 3. Defendant, Charles R Boyles, is an individual who resides at 139 Cme Newville 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 February 15, 2008, the Defendant(s) entered into a written Motor Vehicle Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of obtaining financing in the amount of $25019.40 at an annual percentage rate of 11.040%, in order to purchase a certain motor vehicle, 2008 Ford Focus 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 $366.99 for a period of 60 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 July 7, 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 $9900.00, however a balance of $4163.28 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. 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 $342.52 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $4505.80. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $4505.80, 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 ed, MAURICE DLEMAN, P.C. Attorney YLOR, ESQUIRE Date: May 26, 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 26, 2010 PENNSYLV SIMPLE INTEREST VEHCLE RETAIL NBTALLNENTT.OIe pW6 DATE 741011, Tam eve. Iww a-araq wm..ee bees. I*elalw er?ly wan 7tauACNmnon ylb :10ORC. 2b Cea) aa ff ggaayyLL 55 yyAMRCLLE?SEq BOYLESEJR ROB RUpTHHg FORDO5 EDRE PA 17251 b4LLSBDR6. ?A TH 17019CUMBERLAND COUNTY .rs.?'? re WaWtl eaa.meW MwNW.ar.ew.r areeere,m Naea.at wf w.r....... aY acre lr Pane, ma ' eeae,l YM11 i Idlndflu?on fierer IM Far YA1Y11 PWrp NEU 2008 FORD I qPw.°? ° V"- ew.emarl IYHIOJITION OF AMOUNT FINANCED INSURANCE C.h Prke}}gg}.44[1) YOU ARE REQUIRED TO IIISIRE THE VBRCLE. YOU MAY OBTAIN VEHICLE L D ew, L Peyeent INSURANCE FROM A PERSON OF 71dm PaNY RaIse Aaalgrwd b BeMr?_._._?._?S2ppp,go YOUR CHOICE. Crh Day )109 0. LIABILITY IN . Tnw-M Pita- f_•?ua-f_._,?y,f_ A Y- one wows aw sbeMw nrrlea o+bY SURANCE COVERAGE FOR BOOAY INJURY AND PIIOPERTY ToYI lbwn Pmnmrt,__. ) DAMAGE CAUSED TO OTHERS IS NOT INCLUDED. a. "We"a aalerw a Caen Peas 0 naea 2) f _}S9B4?f) a. Aeee,mb Dad e. Yae Islas (f Wsr may be ,wYrlep Y ywlbn a alwe ellruu) OEM O CCRE ? T. PubSk OlfalaN y) tal.ra.If ). ale G A ? ra THER EMI OPTIONAL NOT REaLWED TO OBTAIN CREDIT AND YRLL NOT M PROVIDED IRa88B cn nepanMm N e ). y.: YOU SON AND AGUE To PAr THE (1) for cans y. f PREIfEIY. PO ta.. (mbbCash Prim) ! f-ff.SB- Clod me Te.l.relRm tea.pra. sat. ° Lim OWN LIy aewaeae oar teml a aaw.eaf ? Imtralaa Goat Db..Nbr Yoram e a 11ar cam a oan.tl>.__?.f f nrel (Tams 10A M-ft)-_-_-.f / (I- Jl(A-- -)---S PEA Iruued(s) Y To 906-RIAILFDRO,--[1L1er .06 FFF i. rn.T[NENTN far_sno f - - ?? ou was Creow LNa ft.. }p58O?B - To b Byer Sip. r To - III, Pa P ar To F E - LE br_ 91 ar... F1 6E FEE f Tow L Co-Buyer Signe I - S Amrwnt PrarwM la Pllm IL_-?_?_,_______. Ste' Uq Orem PEDMAL TRUTKO"ZNDEIO DISCLOSURES f ANNUAL P&MME Amount Tom M Tam $ala fir - Inrngs) PERCENTAGE CHARGE FlYWY. Papnew Price you caw Creels Ob bill i RATE Tbawat ar Re dMacases Saar" Rr canna a °r partli0 rb elerep W M Tb m ant a m y a muroa. arwel..yaa aau y. 1O?raa o YIN Irm w. ° ? awsew 6061 er ewP Vgmj Bryn-we na A .Prenre 491 a S-?ggBr6& a PR A34 ML Co-BuY.r &pw eewrar r.r..r. OTHM OPTIONAL INIMmA Ca ° ° Cwarape ant Prar,nan ww larar. Cwm.rw Tem, in Mama f -1qA ? - - ETR _ TY..nre: XYm PaYmrow aaa any, eve Nro,bmb.ya pmmsy. aeenmYYrwM; Yw ra saes. arwN.Y Ym1enM N Pla reNaa arq ream".. a .0 A =sew rsaFa,aa.?e YYm=l w a aal plow. mmma nq aw to e,Y. r. Tb y Il e.aea: Pteaee e..e, awract b aeramar wamrwi m .roue ww.L mryaP+wA swam Iayewx a caw sea r as ewe aw .mrdr W4 rm b ? Yw wad aw sacra ee..aras b . le swrmg PleP.P?w . Pram" am FaMeed.bw. N YOU (10 = Milan Your Contract ob6pMprw. You may boa your veN,,, as veal t re 9000 put on your vehicle and money or ooce r m d b : s e ve r vel.cla : Bnryer frsne GALLOON COI/IIMCT PROwepNB 0 Yaw had baab ara PaImIll l IMId r eft mama Y e babes Payment. Ca6aRr mg. umn wam m AND INLUM Der TIN, and emsr seems, aaaa- w N tlr bar daeaey res. I. dmMed. Ye, a.elon, P.mpapn B, ant Par.~ C a b ele cam a ar awrrt Tlr snore rye tle, marry flay. Yoe my Is arras for ea1.Ya caw c "upon m i d m. I. wale. a eDeewa w for aura use. M Yw aeemre am apam b .NI " velar back b Says uMer Ue B.M So Paragraph & yes nna el p yes ry . - Per ea l-M mle b.m.s a,_-NNAWpllm etmrrm m ar amnMr. Per naerar.n warn Aeeaaer U.elleeef aIIT11A MLi1ae OPTION CR®•T lie ar o,ar arara laa bye e.. a .a• d leam oar. newt a sae merepe 4 r X a.s mama . .below PaMw t.m .ao.Rd ebwm), and yw hors aallae a. Y m veer. b eeYY car. Tb c' e.aroIse Yaw OUm b .X was Yree b me Bays L.W. P.".ol 6. 9y P.nefrlsa, No- b Yew myna. M b eclra.d as a tas Yw we maY rerw rmmrr.aMaM aenoelYbn.eawr M rein b ar sesame Attwew aWm r k .Y n I.." a work a f0 0 per Ia.esad new, Icr ft mblpar at IYYlled IlYlee mwey beaarYSa Tbpbeb.we,Y .maYlw,eawnYMealmay aanYtl Yer =-.-,,L ?? andd.--??_ waste. bar any ,name, Yw amwea. YIN MI tM' r f ft n a Man FYma. aaow w nI a. y mar s ar YYaae Y dMay., Ms OD, ar YIN we b 4bR . Y w we hat mcae any mu, a tlr Mr I. Mw ihwflw 7t ry /y wYe( . Slane NONMODIPIC DISCLOSURE AM amKe b.I.aa..m mat. bwY aeVra al Ka ra ft Sam. p w BMm // ? , .ear f?VBL2! C. Syr X /xwy? i A,, YOU ACIOgaRAOIIE THAT YOU NAVE READ AND AGREE TO BE BOUND BY THE ARBITRATION PROVI SION ON THE REVEME an OF TIM CONTRACT. TM Merl Rob my'. I. reEeOalaa YINh No sow. 70 8.1w may resign o PPnwW ala as rlBm b n.ealve . OorLlan at Una FlnlarlPe t:lwaa. wry hewn NoncE To BurER Do not sign this oc, hoct in blank. You are entBled to an exact copy Of the Cruntract VW you sign . Keep N to prOteOt your I s y el rights. ?/ 1 /r n A,) Oa.6lerar /_'([? /fur L/ J sac Buyer (and Co Buyer) strumm/iedge ills[ p) eeton efaHm ih{? C01dIBSX Buyer (andd 004krUyR ) leeaived and Pwhwed a trite and eo spigeMy of }g?-?Y ?, ttiM contract and (B) 9e, _ OT sianMa this txlmract, Buyer (ant Co•Buyer) reeeivstl a true and -MPMBly Riisd In copy ft2 this convect. 1LraJ?__ wy.r X ,T r.:. al w a.aareDR .lrtu coon nor ay X R.. ?? THIS ODNTRACT IS NOT VALID. UWM YOU AND SELLER SON IT. A681GRMIEPR enter ear erwb a. awltrrn b rwllrr senor. Thr Paw. r a,wl mien. sacra claw. PY.aPe• ass naweelea M erang...l... a. 'tear.arrar arr.tb" -_ .- - - - _ 1'?F Te mmal.MJiwwa sows se, aw,..a, ar.W rnesay a M X ye. Si1dCf AturP6mL a nmwtc nwarwm'?rmr aor..rl ? ol,en ace ran AoonloaL AoRre,mNm '. ORIGINAL PLY t.- OIIIMNAL PLY 2.11UYER'S COPY PLY 3 . O04It YE1yaUARA"" COPY PLY 4 - BELLER'S CO" moN•TRAraaFEAAeLEI ADDITION minor iP U?9 n dsSeem rY Noriom YOU mm M. ON N.Y. when My •re M. YOU mm prpey Yin, dap u NOT mrbwmmat Pwn.ay. TINS b ¦.urlpla i.rest coned. T"' M"UM P" 0 PaW?m . The act N nb P NY rim apex te yo« _ I too _ Wym, eep r oa spud Vr aMed.a door or don"sawdoNd anbmt. YOU, PAYasre M be.VPSM moo bur monad are n MpartdM Fkmw Chop Wes *or to or Unfold ArMal Fmewa. The Fiat= Corge is erred by oppyUq the Amuel Pamanbpe Ram b or Iatpao AmouR FimMM M me •wrl tlM dm M WOW Amoral FbmncNO N, mU SIWdln. n Net ve icb b rpw. Mired, you.0 not Kew *. fight to rommor or connect -Asia A S.M. U. AGREEMENTS epprow Nb ypr and«rbun d MOP, ... It the oiwrif I- wort, .red. d Or daarrYON, YOU am =the Sen. Mat is so .red. You Now art the Seder can Motor a dskn under m amerna pONq YOU rUNnaiM the Nirrar"ca wmpanY to mavba Satlr .try NlaMOan SWr We- mac-.R' Or Mk. a Met- YOU need UM ratrmdo pINONMa to roper the wNdi, were, to damp. to the vMAM is Pereidered a toed tar. R On ti mep to NN V*W. it OOfOMWed a toml iM you must use ft kwr- mna Proar. b Day Most YOU Gee IM SsN d. N YOrairerarece r M rahbb Ow.nY Pry oil you aw, you mwf Per, whit Is sill Prof. apart wore live Oormm a bWk- NAM t Wym•M tl ildbmbd Pis the fart 4 Ow -Parmt, YOU my are Mole OF 11- e M me mammMM poyrtlen it, Mat Bill& YOU may PW M ow you Nom *- M red trsrmrrd PayrteM m our end MOM, your now vairet. YOU may ra%M= the inn MidY1bO pyMM Weeds YOU M in ON!" UraW tlM =&act IN rb Same hM Mwrbod kris b aaa ON dyed YOU mist pry bWk the SOW Mon a.b8 net rabaoroo90 M wNOOK POW of owerem Nl M E. rTh. Around PMOWNWRaft (APR) tar Mmlog Vr lower at Ow APR.wpraM to by you end er Seer a ar tied of tlr ramrwbk d a M mmo rom rob ParrreOOd by low. The term e M bmrrbng wN be onto on to Mooted roon,"d, Vb rob. Ma net rmm ,a Nr nor" prMont. The ,e5rbnctl morBAN poyrnrt MNI Ito M wr M In Pro corow Nora m mww.mwe ME M kmy paid WNW 35 rim le Of the dr dam of or tee ktatemnenI pmIr.aM. O"F*iW or m.naW PNI reed araouO Mull be ore amarl boded to it* Pay M MWWMd arrive edlin 36 mores d Vr M Nid 1 die Met N.00.MN P.YrrMrIL N you wbh b Muse. you Mot ncWy f Saw b rung. Except M de isw In dM Mean, tlb OPIUM mutt be mated ne labor for 30 rep pwbtlo d odabdOr bN baMroad paPrme. Dkil, you M wood. b M Swtlr, b, M WtroMl earl PoPene. YOU must pry b M Saw my 0 w anlolre Ord ran oW OPneooL AM." you Nom IN M basod In pre, on old wed r. nANps. YOU MOP reed pay b 3ne Mew Vr MYllnal.a oat M M nfrYS b re vMkM Pled an do raw- Of N QMNed MOM and we, M M kw" bear. YOU mid bed .e rablN to • poor s.mdM by the SOW tar iep.Olgn no mar obn 15 do" Poor b Nor Mst ktelaNmmt payMM tin did. Area M knPaOmalr. N YOU dale. M W tlM veNM b tlN Sow. YOU mwt goo V. YsNNIS b M S.M. no law pan me me kubNMnl Ply-nt do tlMN. At Ana tied, you Fort MO 9" the SoWr A tl., MYeh Maw no meta otherdr ft SMbr's Wis. orndordg Nr.MI14 to the SOW or A Poor tlbodM by mr Beier. Al- M Napo . 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Yee vMbb m aaMd by My bwL sleU. or Orion, autlwiy And m not promptly red u condirinally returned b YOU, or 4. Yp M a brNryrcy P~ Or one is find aganet YOU; or 5. YOU do not lop my porn P ome, in NW cuuad. If Y U detull, SeNr M anMW some. toms under I" mn- Md red SNOW. ovw ANN" wrdn ow low. L MpatMMfru m YOU ddaul% the Seer a" rapine yoo to Pay M Prlw ON, -gab Amato Fi a nod, on MANN are urmid park of M Fiance ChNrp and ON dam ornuures court carne oft marred. Sear My riM- 0" or*) M MHCm, WO. Seer My "a Nor good. fat" N Orr ft vela" Wien repwtswtl are add tlbin kr YOU. J. YM Right To Ra.MC h to vWda Is IMMn book, Grow wS .ores you • reltrw. 7M nalia YrNI say mot you my rMOOm YOU mry auk) 1e.1'loon, oY eb wt•udAM p to M ME to Mw Porr e me saw iMvf ft or YOU agar.r to 00 N X. . X you do not rw..rn M relAaN. X MB 6. X or M eon. L Dtey.NOtem of Mora Veh1ob: N M w1Yate IN tMr book .ad add, M a-" umn ft ere, bed Mla-d epenes, rill M wad 0 Pry fed oMrt "I and m me CMMd. 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N Sew dawny .NOrCS Sewn alp. awry moo, 8rlar an Nor- BomerwR edorcm. "-of SaNh ridke b e hadw way. N M mM InYbm«A Primed ruder this mdrad to t Proton .mpbd to Ol Eednnp, In its r:pWy mYMrday. N ANON (but nOl ne •amOraonel Mm rMp•M b M purtd"sM and Mete a tlw r=hIcle. FTC NOTICES NOTICE -ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAYS AND DEFENSES WHICH TIE DEBTOR COULD ASIM AOAYBT THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT MMM OR WITH THE PROCEEDS "it". RECOVERY HEREUNDER BY THE DEBTOR SWILL MOT EXCEED AMOUNTS PAID BY THE DEBTOR NEREUkMER.• Urad Motor Vehicle Buyrn GUMS. S you w buyhg r used vehicle with orb contract tederel reprbtlae army Were a apedel Barre Odds to to cls loyed w the widow Mtlb vehicle. THE WORMATION YOU SEE ON THE WINDOW FORM FOR TIES VEHICLE 19 PART OF THIS CONTRACT. INFORMATION ON THE WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN' THE CONTRACT OF BALE tlm Mee. Nan Nrkrd wR a•1 .r?Ml ? « op as b sa, :==ft= d •a+r, des..., w rrN •arreM WaraMMMAwr.1-NolM. allARAIM TO ear N» SOW Or MN M V*d b0-6M-On ft korA of ft mrmMt to M &y« m areal. M h P- Mb Moe Mow No . M rlrm ofdIpw1eet M prynwe ON NW c-OM L Title rows NM I w Buyer Eke to pY key Per" me m area on did donlorm who e?MtM OMNO ewr1 No - N orb P, role ONO Per a omn Mew preen. Yo .Far &- repa1prw beow apw 00 M wB be IYW Seer die ar r are d M ktmONirp dl glraa Net SrrYrt n Witema y. EaM iilr•rrOOr ids Mg- b be YMb ewr N M N PM b my of M Now Guer•row, or (C) rerWN Nr' Pare a men peP MorMY. Eadt OwrWMr Moo steed tlrN M to low (b) reoeNkeewd t a rMMe N C any « d VON omsAd ea ore Ovate ty e M war M OF". ebnpNlM Pepy ?•OM Ad*- I GUM,~ Add- "101 re metred d rMdwa Wry Omw. Nmpdi.«mrmomsY Ior* y.•'CWm') wnut Nov o mMW in court, EBwM « aaw (od. a've9 (MM. R. •rk+l MY Chows a dry med. Ire «w a mr«YI m N•4 b Ora My CWm m«•d b Net aawaCl dOM! byWtlnor. Sur wAxe bee notmnNM to too 1)CmNwin I Not' n P""Oroobrew: 2) dint M kerlpr«eoar". eeape. a d K aNr, « d dry OMM: 3) dome beer ee, You tax Ir ••?« Or NnMmn•• « •Nmaw; 2- rmNlp am d a rtmng b Y«a sppmwdw w omit. nil loNd- p• krekrag om r, a am name" releaNnWp,atlt tlma peWi 0 0=1 RNNTIB You ANO 1oE Ao1iaE TO OIrS w m •?Y"r - oft Lei . owe you ad wr or- b wove ft beara, roger.. ijONt TO A TRIAL. WHWMMN BY A JUOOE Ole JURY • MW TO PARTICIPATE AS A CLASS RMWJM RATIYE OR A CUSS MEMBER IN ANY CLASS CLAY YOU MAY NAVE • M AMWRMIRB TO pdtCO01 COURT ON 11M1Y AII! AYALABLET MT1 LAWSUIT RM • HT TO APPEAL TIIE DECMIDII OF AN ATO • OTHER MOM THAT ARE AVALABLE IN A ARBURRMATOR Few- ]M AM vrr • t • CNN" IN epo«M, you and w red carnkars b hM re, 1.1mr, AME rrIAwg u«.auoo Pmaerr ?• b ?nl'?Mn: ,) pryl7MM? b mm bre.lalOy N oaut Z) RqM b •dwr M N. ki- N wale. F nPer, M a rum worrier tle Ma roordeddlm Mtlw M «tl«w M ««trtlOYe dedewr, «x d) RpO m earn of tor =p=`=.d odMene Nrd b.bw.nd M MOM Pub, b mor arbitration. TM spombl• nor Auw-) form ore eMO.ten.'. • AmMkarl Ade•er A.eWAYbn rAAA•I, « 120P77i7Sir, or ww.ytloq' eq ?• a tlrale N o A b•. Fpr..At 1ldaIT4NaercL ?7JY,. «waAeww M/jy or(Ww Mod vi• pmr•q py?rm. TNe «wr•d m enlM, b M =P1, t «w4) end M FM«« Ride d ENd« n TM •nm ow sty MON. MM M b "eMY Awed a «OPOMO a N dr3lM. We ON` wyMwhMlMa -7p"" lw4 rk"rrdmEw.rNm.w/runipain d r prof- wren enonewewre errsr ) Near M NwrrM, dal M nlrlskmg PIwOrNirrM :ll Mwwaub«biY«iwd «« m ?t F "warar bCI rl Iewwra Moe rrY bYr Marti 6EE OTHER SCE FOR ApOarp(AL AOREBiORt M rrbrie-a 1RWaM:O '-PRN- Ford Motor Credit Company P.O. Box 17948 GREENVILLE, SC 29606.8948 (677) 605-7187 POT01010200025 CHARLES R. BOYLES 139 CME NEWVILLE NEWVILLE PA 17241 Date of Repossession 07-03-2009 Date of Notice 07-06-2009 =Date t Account Number: 043518079 Buyer CHARLOTTE A. BOYLES Cobuyer CHARLES R. BOYLES DESCRIPTION OF PROPERTY Year 2008 M Vehicle Identification Number: 1 FAHP35NOBW178476 Model FOCUS Body 4DR NOTICE OF OUR PLAN TO SELL PROPERTY we have your property described above because you broke promises In our agreement. a? I? Q PRIVATE SALE: We will sell the property described ? PUBLIC SALE: We will sell the property described abovir at public above at private sale sometime alter 15 days from the sale to the highest bidder on the date below (or any adjoummerd Date of Notice shown above unless redeemed by you date). The sale will be held as follows: prior to such sale. Date oT Sale Tane of Sale Place of Sale You may attend the sale and bring bkkiere 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 loam 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 AUTO AUCTION 1190 LAN A D MANHEIM PA HOW TO GET YOUR PROPERTY BACK To get your property back, pay in this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 1489862 Plus Costs: Repo Expenses $ 370.00 $ Plus Late Charges $ 78.27 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 15,346.69 (Plus expenses incurred If defauk 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 16 days after the date of this notice at the EARLIEST. After that you can still get it back any time before ins actually sold. If you do, we'll have no further claim on ft. But the longer you wait, the more coots (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 (dealer/original creditor) a9 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 contacting . this office The item, tt1?na? property found in the vehicle may be reclaimed by you within the next 8o days or, in accordance with state law, by property shall be disposed of accordingly. ? Creditor has assigned to its qualified intermediary (QI Exchange, LLC) its rights (but rot 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 11988-37 Jan 02 P-mus editions may NOT be used. Pmroed in U.S.A. CUSTOMER/CUSTOMER FILE ... PRN••• Ford Motor Credit Company P.O. Box 17948 GREENVILLE, SC 296058948 (877) 8057187 PDTKNO020DO17 CHARLOTTE A. BOYLES 139 CME NEWVILLE NEWVILLE PA 17241 Date of Repossession 07-03 2009 Date orNoti ce 07-0609 Dat e of Contract 02-152008 AccoNumber. 043518079 B r CHARLOTTE A. BOYLES COW r CHARLES R. BOYLES DESCRIPTION OF PROPERTY Year 2008 Make FORD Q New ? Used Vehicle Identifuetion Number: 1 FAH P35NOBW 178476 Model FOCUS Bey 4DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreernerit. S t3 .S S _S S S x? PRnfATE SALE: We will sell the property described ? PUBLIC SALE: We will sell the property described above at public above at private sale sometime alter 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 dale). The sale will be held as follows: prior to such sale. Data 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 11 LA A 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 $ 1489862 Plus Costs: Repo Expenses $ 370.00 $ Plus Late Charges $ 78.27 Lees Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 15,346.89 (Plus exrpenses incurred if default at the time of repossession exceeded 15 days and less rebete 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 ft. 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) retumed to: Under our a reement with (dealer/original creditor) 9 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 low, 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. VERONICA D. NOGUERA FFNA 11998-37 Jan 02 P-- edrbo may NOT be umd Priruetl in U.S.A. CUSTOMER/CUSTOMER FILE -- -?.? w ??C? :.w:?•,;,r„? a??. ? l ??-?' _'?- _ - -..rte - - :_. .?r.r- .? _ • - - Rim .. r<i - - : _ .. • plc a. _ - --- ' - - - • -- --'•'? - ' -- - ?. .O y ? ' Q(SY?' `- O p O O O O ? g O Qo O C O O v 00 40 aLL N DO N "1 C, $ ig y H N N N m y y y $ ppCi ppCi po !O•! ppM ppV! `pper ppCi N N N N y M y y ? a to co g $ m J N o?! p? co C%I 1r! ? O r m ~ (L! d ? z ?" ? 1? If! O CD ENO le?? h a CO) y?w NV aDO? O a? ?f0 Nj K W .o oo`?c $m ^ `-zy°?a g 00 °z} >o $IQZ?? ?t $w° s AQS" aoZW> o!W= o ? ?U1r+ -?Zc - Qm -2 `?? ? N }Q 2°O pT 40 r Z ?W jd -=50 U-! N IL C) M -i ED a j CD J IL 0 W 9 1 HMO Iw U, rove o&F x o (Ij ? o?.-0 o?vC! D M1 r Ln m Ln 16n O A rru ? Ln 'n _o .o .a em go co so co so no so Ir co n m ni a ni rv ru ru n i ri r-1 A rq m m '^ m C7 o o v o c o cw 0 0 0 o a o 0 0 v z o m dGo oa 0 0 o a o C3 'E c 0 0 C3 C3 0 a -AK c o 0 0 o c a v Q O r O wg O N a y .- O o 0 0 0 0 0 o Q f a cr CL M1 M1 M1 ? M1 r` M1 M1 $? ? Z r• O O O N N N N? OE5?2E'CO)Ir 0119 06`LL v .?. _ - V ICE Q 0 cb. ~a o § 2S to c; Go °oy .4i a LL ° ° C ; S S S H C4 N y N M W M ` A ? A ? A ? Q M p N p °y M pp b M p ? M U ? A t0 N {y NNA ?? ? F M '_ W N .p ? N In IC-4 S Iwo 8S'W^?3oaZ}' co tzLmiq? h a -0 Lu -0 z 1NZw d c? V ?3 e .UO O w ? w d wv? ?z °wOC9 &M z ?CY w LL CD a. LL oU.-Z oZoom H-0 ° 03.-? 0 Q3v? N a o a, m ° .q ru a n- o- s ul Ir co ca s co ca so rti N N rq m m a v o 0 0 0 o c c u S o o E. O O 00 G O 0 c3 4.6 0) -E O O O O O O c M' S Z- S .a -0 -0 A N = O O O O O O g O 0 C3 T- Ir Gam"' O O O tr a Jm M J N A A U. Z N N N N N ?7 T6E62ETOOT000 4006T4 Ford Motor Credit Company P O BOX 17948 GREENVILLE SC 29606-7948 877 8057187 DATE: 2009-08-26 POUZMXOOIOW45 CHARLOTTE A. BOYLES 139 CME NEWVILLE NEWVILLE PA 17241 CHARLES R. BOYLES 139 CME NEWVILLE NEWVILLE PA 17241 STATEMENT OF SALE Account Number: 043518079 The following property has been sold. Year Make Model 2008 FORD FOCUS Balance owing on your contract Deduct: Finance Charge Rebate Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any attomeys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Other: Deficiency- (9) $ 4546.76 Surplus* (10) $ N/A The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest added to your account (debits). Surplus* or Deficiency" * If the sale resulted in a surplus, a refund for the difference will be mailed to you. If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional information call or write: Mail deficiency payment to: Ford Motor Credit Company Ford Motor Credit Company P.O. BOX 6508 DEPT 194101 MESA ARIZONA 85216-6508 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 Vehicle Identification Number: 1 FAHP35N08W 178476 (1) $ 14,976.89 (2) $ 0.00 (4) $ 9,900.00 (3) $ 14.976.89 (5) $ 5,076.89 (6) $ 595.00 (7) $ 0.00 (8) $ 1,125.13 FFNA11990 01104 Previous editions may NOT be used. t ? Ford Motor Credit Company P O BOX 17948 GREENVILLE SC 29606-7948 877 8057187 DATE: 2009-08-26 POUZMX00100046 CHARLES R. BOYLES 139 CME NEWVILLE NEWVILLE PA 17241 CHARLOTTE A. BOYLES 139 CME NEWVILLE NEWVILLE PA 17241 STATEMENT OF SALE Account Number: 043518079 The following property has been sold. Year Make Model 2008 FORD FOCUS Balance owing on your contract Deduct: Finance Charge Rebate Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any attomeys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Other: Deficiency- (1) $ 14,976.89 (3) $ 14.976.89 (5) $ _ 5.076.89 (9) $ 4546.76 Surplus* (10) $ N/A The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest added to your account (debits). Surplus* or Deficiency- If the sale resulted in a surplus, a refund for the difference will be mailed to you. If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional information call or write: Ford Motor Credit Company P. 0. BOX 6508 MESA ARIZONA 85216-6508 (800) 732-2264 Vehicle Identification Number: 1 FAHP35N08W 178476 (2) $ 0.00 (4) $ 91900.00 (6) $ 595.00 (7) $ 0.00 (8) $ 1,125.13 Mail deficiency payment to: Ford Motor Credit Company DEPT 194101 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 ?r F1Lri_?. r :t ? at rrie?robPrl IF THE • ; ' i 1?Y Jody S Smith . a? ` ?F ? Chief Deputy . , 2010 JUH 14 Ph 1: 19 Richard W Stewart ' Solicitor OFFICE OF 'HE cMERIFF CUMB "(.:UNTY 'ENNSYLVA,NIA Ford Motor Credit Company VS. Case Number Charles R. Boyles (et al.) 2010-3630 SHERIFF'S RETURN OF SERVICE 06/10/2010 08:54 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2010 at 2054 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Charles R. Boyles, by making known unto himself personally, at 139 Conodoguinet Mobile Estates, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. DENNI 'RY, DEPU'P 06/10/2010 08:54 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2010 at 2054 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Charlotte A. Boyles, by making known unto herself personally, at 139 Conodoguinet Mobile Estates, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $54.80 June 11, 2010 '00V lr? DENN FRY,DEPU SO ANSWERS, RON R ANDERSON, SHERIFF (C? CounlySURO Sheriff, Teleosoft. Inc. 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 2010 22 , iii ? t:,• ?j CU Pt! 1-5) 789-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. CHARLOTTE A BOYLES CHARLES R BOYLES CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 10-3630 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 & NE DLEMAN, P.C. JOANN , ESQUIRE Attorney 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: CHARLOTTE A BOYLES 139 Cme Newville Newville, Pa 17241 CHARLES R BOYLES 139 Cme Newville Newville, Pa 17241 Respectfully Submitted, MAURICE & NEEDLEMAN, P.C. BY: Jo eman, Esquire Atto ey for Plaintiff DATED: July 20, 2010 E VERIFICATION 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: JJOC-K?1? Representative of Plaintiff, FORD MOTOR CREDIT COMPANY LL C A Delaware Limited Liability Company DATE: JUN 0 .4 7010 CHARLOTTE A BOYLES Our file no. 13100 48063000000043518079 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) /tSy-/1S1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. CHARLOTTE A BOYLES AND CHARLES R BOYLES Defendant(s) r? cis =rn d? M PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATI04AD, CONSENT =o ... -4 w TO THE PROTHONOTARY: Pursuant to the attached Workout Agreement for Payment and Consent to the Entry of Judgment, kindly enter Judgment in favor of Plaintiff, and against Defendant, CHARLOTTE A BOYLES and CHARLES R BOYLES in the amount as follows: Principal per Workout Agreement $ 4724.24 Less: Payments to date ($725.00 ) TOTAL $ 3999.24 MAU CE BY: LEMAN, P.C. c°= "[a rTIF: ?? r)I -4 C" =-n a-Tj =F CD v JOANN NEEDLEMAN, ESQ. Attorney for Plaintiff Date: June 28, 2011 CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-3630 CIVIL TERM 0Lty& %14 0o pd 04+ CUB ??aC?t 33a IVohc? IMat(?? 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 I CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMPANY Plaintiff COMMON PLEAS CASE NO. 10-3630 CIVIL TERM V. CHARLOTTE A BOYLES AND CHARLES R BOYLES Defendant(s) AFFIDAVIT OF CONSENT TO JUDGMENT STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. JOANN NEEDLEMNA, ESQUIRE, being duly sworn according to law, deposes and says that Defendant, CHARLOTTE A BOYLES and CHARLES R BOYLES has entered into a Workout Agreement for Payment and Consents to the Entry of Judgment, a copy of which is attached hereto. MAURICE N EDLEMAN, P.C. BY: SWORN TO ANUBSCRIBED before me this day -q-?20' otary Public -JOANN NEEDLEM -- - Attorney for Plaintiff NOTARIAL SEAL RASHETTA ROBINSON Notary Public PHILADELPHIA CITY, PHILADELPHIA COUNTY My Commission Expues Ma! 23 2015 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 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY, A I CUMBERLAND COUNTY COURT OF DELAWARE LIMITED LIABILITY COMPANY Plaintiff COMMON PLEAS CASE NO. 10-3630 CIVIL TERM V. CHARLOTTE A BOYLES AND CHARLES R BOYLES Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. 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, CHARLOTTE A BOYLES and CHARLES R BOYLES, 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. MAU NEEDLEMAN, P.C. BY: JOANN NEEDLEM AN, ESQ. Attorney for Plaintiff SWORN TO ANSUBSCRIBED bef e me this2"t day 204 ?. -°? NOTARIAL SEALON Notary Public RASHETTA ROBINS Notary PubliC PHILADELPHIA CITY, PHILADELPHIA COUNTY My Commission Expues Mar 73 2015 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) /69 /1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. CHARLOTTE A BOYLES AND CHARLES R BOYLES Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-3630 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: CHARLOTTE A BOYLES 139 CME NEWVILLE NEWVILLE, PA 17241 CHARLES R BOYLES 139 CME NEWVILLE NEWVILLE, PA 17241 LEMAN, P.C. BY: OANN NEEDLEMAN, ESQ. Attorney for Plaintiff Date : June 28, 2011 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (11J) /25y-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. CHARLOTTE A BOYLES AND CHARLES R BOYLES s CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-3630 CIVIL TERM WORKOUT AGREEMENT FOR PAYMENT AND CONSENT TO THE ENTRY OF JUDGMENT THIS AGREEMENT is made between FORD MOTOR CREDIT COMPANY, a Delaware limited liability company c/o Maurice & Needleman, P.C. 1617 John F. Kennedy Boulevard, Suite 935, Philadelphia, Pennsylvania 19103, hereinafter called the "Plaintiff' and CHARLOTTE A BOYLES and CHARLES R BOYLES of 139 CME NEWVILLE, NEWVILLE, PA 17241, hereinafter collectively called the "Defendant" WHEREFORE: 1. The Defendant acknowledges having executed to the Plaintiff a Retail Installment Contract ("Note") under the terms of which Defendant promised to make certain payments of principal and interest to the Plaintiff according to a schedule more specifically set forth in the terms of the Note. 2. The Defendant acknowledges having failed to pay interest and principal as required by the terms of the Note and is in default of the Note. 3. The Defendant acknowledges that there is immediately due and owing from him to the Plaintiff under the Note $4724.24, consisting of principal, interest, and attorney's fees (hereinafter the "Amount Due") and the Defendant acknowledges having no set-off, credit, or claim against the Amount Due. 4. The Defendant desires to satisfy the Amount Due and therefore makes the above representations to induce the Plaintiff to enter into the within agreement for the payment of the Amount Due. 5. NOW THEREFORE: For good and valuable consideration described below, the parties agree as follows: a. Plaintiff may enter judgment against Defendant for the amount due, less any payments made before the entry of judgment, and the Defendant consents to the entry thereof. b. The Defendant shall make payments of $200.00 a MONTH due 06/26/2010 and on the same day of each month thereafter until it is paid in full. C. As of the date that Defendant signs this Workout Agreement, interest on the Note and for all subsequent payments shall accrue at the rate of 6%, including interest from the date of the entry of the judgment; d. All other terms of the Note, unless otherwise set forth herein will remain unchanged. e. All payments under this Agreement will be made by check payable to "Maurice & Needleman, P.C. FMC Attorney Trust Account" at 1617 John F. Kennedy Boulevard, 2 Suite 935, Philadelphia, Pennsylvania 19103. Please reference the file number 13100 on all Payments. 6. During the term of this Agreement, the Plaintiff will forebear from enforcing its judgment for the collection of the Amount Due provided the Defendant is not in default of any of the terms or conditions of this Agreement and makes all payments timely. 7. The Defendant will deliver to the Plaintiff, with a signed copy of this Agreement, answers to the "Questionnaire" simultaneously supplied to the Defendant with this Agreement. EVENTS OF DEFAULT. The following shall constitute an Event of Default under this Agreement: a. The Defendant fails to pay, when due and payable, any scheduled payment as set forth in paragraph 5 b. above, and such scheduled payment remains unpaid for more than ten (10) days b. The Defendant fails to return the Questionnaire. 9. PLAINTIFF'S REMEDIES UPON DEFENDANTS' DEFAULT. In the event Defendant fails to cure any default of as described above, Plaintiff will be permitted to commence execution proceedings forthwith. 10. This Agreement does not alter, amend or modify the Defendant's obligations to the Plaintiff under the above Note, unless otherwise set forth herein. This Agreement does not alter, amend or modify the Defendant's obligations to the Plaintiff under any other document which is not named herein. 11. The Defendant acknowledges that as of the date of this Agreement he has no claim, 3 whether known or unknown, against the Plaintiff AND HEREBY WAIVES AND GIVES UP ANY AND ALL CLAIMS HE MAY HAVE AGAINST THE PLAINTIFF AS OF THE DATE OF THIS AGREEMENT, WHETHER KNOWN OR UNKNOWN. 12. THE UNDERSIGNEDACKNOWLEDGES HAVING READ THIS AGREEMENT, UNDERSTANDS IT, AGREES TO ITS TERMS AND HAS RECEIVED A COPY OF IT, WITHOUT CHARGE. HARLOTTE A BOYLE , Defendant 96 Dated: ` 621- l0 CHARLES R WYLES Defendant Dated: ` -1 /0 --LA By: Dated: , I b Charlene Taylor, Esq. ,? Attorney for Ford Motor Credit Company 4 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-17-2010 04:41:51 Last Nam First/Middle Begin Date Active Duty Status Active Duty End Date Service e Agency BOYLES CHARLOTTE Based on the information you have furnished, the DMDC does not possess 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 Auk lot 04*4,441M.- 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 littp://,A,,xkw.defenselink.mil/faq/pis/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. 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 2/17/2010 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:BEC02NOT12 https://www.dmdc.osd.mil/appj/scra/popreport.do 2/17/2010 Request for Military Status Page 1 of 2 Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Feb-17-2010 04:44:23 s; Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency BOYLES CHARLES Based on the information you have furnished, the DMDC does not possess 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). A 14 %t 404?- 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.defe.nselink.mil/faa/Dis/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. 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 2/17/2010 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:PT4JQSAH6R https://www.dmdc.osd.mil/appj/scraJpopreport.do 2/17/2010