HomeMy WebLinkAbout10-6687ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
AVISO
(215) 789-7155
FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY
DELAWARE LIMITED LIABILITY COMPANY COURT OF COMMON PLEAS
P.O. Box 6508
Mesa, Az 85216-6508 Case No. I ?$
Plaintiff,
V.
JAMES D NELSON
1713 Cedar Cliff Dr.
Camp Hill, Pa 17011 -I7
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JENNIFER N NELSON
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1713 Cedar Cliff Dr ?, Iv
Camp Hill, Pa 17011 c W , "
Defendant(s).
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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.
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.
Attorneys for Plaintiff
Our file no. 14384
Le ban demandado a usted en la 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 la demands y Is
notificacion. Hace falta asentar una comparencia escrita o en
persona o con un abogado y entregar a Is torte en forma escrita sus
defensas o sus objeciones a las demandas en contra de so persona.
Sea avisado que si usted no se defiende, Is corte tomara medidas y
puede continuer Is demands en contra soya sin previo aviso o
notificacion. Adernas, Is corte puede decidir a favor del demandante
y requiere que usted cumpla con todas las provisions de esta demanda.
Usted puede perder dinero o sus propiedades u otros derechos
importantes pars usted.
LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE.
SI NO TIENE ABOGADO O SI NO TIENE EL DINERO
SUFICIENTE 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
??ay
lie
MAURICE& NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
(215) 789-7155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
JAMES D NELSON
1713 Cedar Cliff Dr.
Camp Hill, Pa 17011
JENNIFER N NELSON
1713 Cedar Cliff Dr
Camp Hill, Pa 17011
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, James D Nelson, is an individual who resides at 1713 Cedar Cliff Dr.
Camp Hill, Pa 17011.
3. Defendant, Jennifer N Nelson, is an individual who resides at 1713 Cedar Cliff Dr
Camp Hill, Pa 17011.
4. At all times relevant, the Plaintiff was in the business of loaning money on motor
vehicle installment sales contracts, including but not limited to the note signed by Defendant(s),
hereinafter more fully described.
5. On or about June 5, 2007, 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 $27538.05 at an annual percentage rate of 8.900%, in order
to purchase a certain motor vehicle, 2007 Ford Fusion 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 $495.02 for a period of 72 months until the loan was paid in full all as is more
fully set forth in the Contract.
7. Defendant(s) made monthly payments until January 19, 2010, 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 xhibit 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 $12900.00, however a balance of
$8174.09 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 filed 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 whi h at this time amounts to $117.59 and which will continue to accrue.
I
i
12. In addition to the foregoing, there is due from the Defendant(s), reasonable
attorneys fees in the amount of $2221.00.
13. The total amount due and owing at the time of the filing of this complaint is
$10512.68.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $10512.68, 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.
JOANN NE LEMAN, ESQUIRE
Attorney f Plaintiff
Date: October 15, 2010
VERIFICATION
I, JOANN NEEDLEMAN, 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:
JOANN NEADEEM-AN, ESQUIRE
DATED: October 15, 2010
PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL MSTALLMET CONTRACT DATE 1i/ns/,n07
12006rn-7000 r lab Co-BUyNI Hmu dig ben.Ice coon, County as. fEtLEAR7RnnOR lYfr IW? atl Ilaerw)
zP goer)
JAMES D NELSON
JENNIFER N NELSON B SMITH FORD INC
1917 RENT DR 1100 MARKET ST
® CAMP HILL PA 17011 EMOYNE PA 17043
CUMBERLAND
DEMO 15712 (FORD rv'a . I 3FAHP08147R190039 I ? Cooanoa o Ap"'e"s
ITENIMAT10N OF AMOUNT FINANCED INSURANCE
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6. ARlael Fnra.o 43 Pk. 41. 0.7, 538.05 is)
PERCENTAGE CHARGE FNacced Payments Prim
RATE T.Mw Te-of
ware Pow TlY atbYx
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raaaeraprrra Aaraaprarna
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2007
W. I A
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Credit
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heuaae Co PWW
$ WA
PrBrNUn insured(s)
You ware Credit Life Insurance.
Surer Signs
CoBuyer Signs
Crada
C1 OlaaNaYA
Insurance Coneeny
$ WA
Prerreum Insured(s)
You were Credit Disability Insurance,
Buyer Signs
Co•Buyer Sign,
OTHER OPrx1MAL !INSURANCE
Iwalt?es c?oora Ra „a d
/> f
BWA
$1000 gp_
B)RMO rfT'to t9tT ^??_
You went nth optionY nsursnd for which
Pr.aun a mow.
C043LW 815n.
II'
Pnpryooab. M you ry or Yaw Cos ady. Woo ws r losre b aY s eawb.
srrwy xrr.r.ae rue r Wes • rray brier Y m. woes. o'ev Psdard.
P.PnYa You moony • YY ar aveon a(aCa WYmaa rarwd Mwa woo 10
Gaya its.. TNe drew Y xo paoprt a?n iewa.
lab aatlm d au.ey Meat, na?M,
Cbaat: PNar M ft coned for .0,1111-1 Inb
Ushua, d» nest m roles nP.lwwrt of
Yea Cris b row saP. eve ranrola0 .d Y. rd
If you do rot hW your Conn uc oblWTiorN, yes fnsy Ides your rafilrle. Y wee
es both pede ared goods put on you vehicle entl nlortey or goods recahed for
Q Yaor lea IrrWnl.rn prynrot under bids Contr.ct b . baoan NynrL
Exc?wEAR. NNE AND MILEAGE c11AnGm
8 err ba directly Wow I. used" INS aadnn, PM91.ph B. and Paragraph C of
9- conked .PPIY. You ryy be d-v d for -welve saw b.aa upon our aandls.
- -1 use. II yd raeir IM ePbd b W sne .hero bedo b goon lobar
CoaC w. ura CraM uorawY Naurm a.
br tr trnn d ewmorn Tw awrwu W
e-Mea w shown In rww or
eaearoe
when b you wry
P4gpreprl B. Y. cowl Pry tla sow fdl(?_ pv miY for eeCll mIM n ado
o?n?n n m Nbam on 1M odneur. dot pMYaee wdw M.woer
N by Pa Y diodes Wu Iw Wdweid ra
EXTRA MIEAGE OP71DN CREDIT
If swn contract PwyMd • INleon payinent (a Sledbtl Wow). and you Iran. o ,re"wel wawa. P.&- d OW Cawmp Y
rterrl end Y net rrrre b arts drx Tlr
eeedew your Option W M the Mw1e b era Bahr under Per.~ E. des
am.eL
ear andmar-rdawd as in Addends.aam b
r M
Y
peaPaph
ppaa b your Cdaad. N sue .dndda sad a eY oanlYSrl, Yes wB coven- Tlr es
buw
pwr
ra
A
b
s
b
M
rr.M a d f0. N/Ap?a!!??uaMed mow for de nmbar d uaewd race
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- onwW w o.-Iobnbm
aoYeo wd
rw
yW
m
ad
b
w
bshYaan N A wood siL_ ntlaa. era ay rnous. Mau
. eadarir a wow aadlon 4.
ows under this cordre s. You wa not ndiae any crew N ihs vehicle a dark W , tl1%
eororWl ands eery, or you M In daautl. You will net weave any Pods N the .eel Y -
Iw tlalt 51.00. &Oor _
NON-MOOIFIC/ITION -L--E
Ary dales in des ooner ms. r u rwrq ad a Fwd or co YW nM ea-.
=w" It
I
YOU A LEDGE THAT YOU HAVE READ AND AGREE TO BE SOUND BY THE AIMTRATION PROVIMM ON
The Annual right to Per lent.gs Rds, way be tM the 8eesr. The WW may adgn this contract Red may ratan pas"on of the Firsoncis, NOTICE TO BUYER
Do not sign this Consul In blank. You are enthled to an exact copy of the eontragt that you sign.
Keep it to protect your legal rights.
ow- x ehCO°w.m •r X
Buyer (and Co-Blryer) aeknowkKl" that (1) before skWno this contract Buyer (and Co-Buyer)
rageilre0 and ravktamd a true and Completely filled n copy of the Contract and (11) at the time of
signing thts Contract Buyer (and Co-Buyer) received a true and Completely filled m?tfiis
Contract -A 1 n
ev f4? . eI -TVA
Tra6 CONTRACT M NOT VALID Is4nL Y AND SELLER SIGN I -r.
ASSIGNMENT
sear cosy dub- fob aware b annum earn Trl Paswr a.l err Yew M esrr•a donor, Plaerna. W rwas.. M alsr+e erw, err
sa-aayaaWrne-sic' MOTOa fPPOTT CItNOaur l'Aaapw'6
To ward Arrrr wart elw rrusa, sou-AGO-737 _TnnO ..salsa d
kp snot. RDCaeDlr.coM
J •r X d n? 'Z
tatD Iec ,t(U
80 OTTER Slow FOR ADWKI L AIaIEFIIEMe
PLY 1 - ORIGINAL PLY 2 - BUYER'S COPY PLY 3 - C04BUIT OUARAWOR COPY PLY 4 - SELLER'S COPY PWN-TRANSFERABLE)
ADDITIONAL AGREEMENTS
A. P,ay emb, end Summary Nonce: You mat make .II Psy-
rrrma in U.S. funds when may an due. You may prepay your
deb as any now -MM Pne". The is a RrlTm nlerestcelpredl.
The actual finance Charlie you Was ft Pay MII depend on your
Payne ml paaana The WhAl tW n charge may mudad the
dleUaad Fine- Charlie N you mm your parlance ku, Own
MS scheduled dsfM or in Iest than the scheduled amount. Your
Payment Will be appded JIM to Me carded and unpaid pan Of the
Fenn Gwlge and Men to the unpaid Amu t Financed. The
Fkance Charge a Monad by applying the Annusl Parpntpa
firs to Me unpaid Amrunl Financed for the actual time tlM ale
unpaid Amount Fkewad Is outstanding. If the vehicle q npoe-
mased,youWShadIww the right bM.thecor veal, anees
aPProw did type and arrment of inla enc e. "Ow vehicle is bat,
aaam flak Pr deatro1 . You meal Pay the Sms, weal N MNI
card.
You age" ads the Sales can mm a dean undr the eNnrca
color. You auhenes aid nwrace Wmpany W Provide Salver
any Inton SOW believes necessary to make a dam. You
mat we M-M,Ca Proceeds ro rpeir the valable. Lrllem m
d." to the whisk a Combilteatl a ben bas. 0 Was drrepe
to did vehicle IS arWdelsd a bleu lees, You must use did MI
once Proceeds to pay what you owe the sour. M your murarlPe
on the vahble dornt Pry aN you owe, you must pay what is 01
owed.
m Seller sg-. G. Returned laeurrws PrrM- and Srvloe C.R rW
0. BaYOOn Payaera T.emltraela: IM CChwSmThis Co of col may comin ctempm tnr aanrre.,
0. Sr noacontrscl fa e beacon your, IIM musenard payment Mannoe contracts, or over contracts. You agree chat the SOW
payment Y in&WW on m fnm an Wrn benene under thaw CrMecfa and press PrrdaNad
of did Perrsd, you may herhdle to last mWmnt pa rnrn in by kw, wrmmate them b obwb refunds of urennad enaVas b
on of MIN ways, reduce what you ode. N the Sailer 9ata a mha nd on if-.
MR. you may Pay Y del you Pws when the Not k mnwd
Partners N clue and keep your mob, -hid..
9NMM, you my mammas me Mai mater vent payment areas
you m in default under the orated. N m Smar half Nvrawd
legs to clm any default. you must pay back on Seller before
ft Mrwoolng. You We met Provide PINE d it-.-rapt.
able b SaNarhefon Me rWwnrJ q TM Annual Mramalls Ran
(APR) for ft rakmalp w0 N the bwer of the APR agmedb
My you Mtl the SsNar a m tape ol aid m6aaroeng or Me
mximm Mae permitted by low. TM tam of ft mbunaN will
be based on me amunt INmansW. m rats, and the - M
M. hwaNy Jey_sI The r.fiorom Monthly payment arm be
the .erne all, in MI. CdnNd n the raeeaeW - will be fury
paid WDan 36 everms of ft did data of Me JIM mmNma"a
Peymerd. OMerydss, the monthly paymahi Mound abed be me
amount needed ro Why pay the mkw tmd amounn when 36
n hMS of the clue dste of We fast MmOrnerlt prymant. N you
wish b ml.. you mid nplMy to See M W",. Ea dept N
discussed in ma -Sol, the nMice mat be rsawed no later
Men 30 drys Pherro the Mardi" of M fast kMMlmMt paymnl.
TT M, you my sell aid Vehicle M the Saner for as amount pual
m the MI infalknem pay-nt. You met pry to aM Seller Jmy
other amwm owed elder this contract. Mllolmla you owe will be
based, in Pad. on the MW. .9-P. V. .1. Mllt Pay to
m Sailor did Nkrww case of e repam b Me Va." to ads
the mum of a- waar and use, as eel fbM baiow. You must
tam ft valid. W a place We C by he Shier for Inspection
W IM" than 18 days Prior ro the hat InstdMwt payment did
did.. After did kapedbn, n you d.dtle to w In vehicle W Ma
Sailer, you must give the varde to the SOYA n later Man m
fads MaWlmnt paymnl dPe tlai.. At Mkt tint, you must elan
g m Ma Salver • We. which at- no a- chef than the Same.
Yen, henat.rsp bwnnNp b m SOW r e person .neded by
the S.W. After the mapecim, Y you decide hat M dl vehicle
b the Sear, you mw! u nlWwwly Corned the Spar Md Miami
the Sailor washer you want b nfima Me Waft wOMmnt
P-Y rs.
C. D.M." Rw i,: N your fast ntlesmnl payment Lndr this
contract ls . bat w. Pat- and you M' the valid. "'t M
Me Sally user Parsipso B, you m MpoMkq ter regain of
NO "Maps m m vehiW net m not aid rearb at nrml weer
ads new.. Them Mpaea means, but m trot WOW to Mae
envy m:
(1) MA-"fie hatPenaa mmhip.r o Ira or any fin
which has tae Man 1R Inch of "meeting treed:
(H) repair all mparaal dYlstm;
(A) repair or m.pface all dsnNO. welshed, ceIPPed, rusted or
mera0dwd boy P. Ms, pant or Bawls kmmmMpm mm;
AM daMW. m"mmd, rlwW, Mated. broken or missing tarn
end gdN wok: as seratcad, - so, plead r broken them;
eat haey wroow mmhMmm; ak bmk.n a bead Mull alias:
all slscfronic maMu ctions: a Interior rep., aMna, limn a
pan amt and ail dampp which weed be corned by
COlli.bn are Com thensWe swlerroe wlMh.r or W such
nnanrrance Is ammlly n bra.
M you raw not m.a the moo m baton Wm d- a the vMitls
under Paragraph S, you we der. ae eWnMd costa of such
MP.N, even a m spore me rid made pnur to your and olm
vehicle b m Seen II you dMrpm with Yid eWmkd costs of
mPaira, you mry hid the "pain mde at you ezpenm prior to
your mid of the vehicle m are Swr.
D. Searsy IMereat: Y. gfve de Sailer . secorsy I- In:
f. TM vehicle and an pan or other goods WA on the vehicle;
2. An m ." or good; mcewm for ae vNtla: and
3. An aea.nce p"mium and sarYka contracts ImMohd for
you.
h also serum payment CI N a pmnmt you owe moor mle Prnrad.
aacem your deerr nanenq n this contract.
E. Use at Vehicle - Warr.lem: You muds fam car. of Me
vo it m andsay aN Wm to Loft N. You my not esll or mt the
vehida, and you mat WOW Y am Iron Mi Wims of Messrs. YW
wB no use ar Pe, are use of ae vehicle uw" .1 me United
Bfam. srmapt ter op b 30 aye ell Canada or aasako, wRed"
be Prot when Coll.ern o m. S.ser. N ion venkle I. a a ""
rasmry Lad for personal use rid the illy, or gun vend
me.. mrwiptmr, exwrM.. vrNkn wM wty r e.rvk.
cmtrao cowMnt the whim Maim Wide" haw aedaw of
ft" co t. you flat Implied Warmakim of
mmhenmrlay
are fen... la . Iprtleakr pulp- eswenhg the
veMaN.
Om-1m' you urwM.Ww aid Ares ads mac muse such
WOW wrrrdlm, .ampt as ods,nalee provided by mw.
F. Vold 1. In- ass: You h.nt W- m whkd..pNM bon
or damp. ham mlNWon, fin or limit. You must nam SONG es
Me Me Payee udr the mu- Policy. The S.A., mat
rinks conersolf, ordd .m%M .. ft Sour.0 strbtredit horn
What you owe. Once all arrpmk owed aMr tlse OMWW am
paid. any WIWI" rawaw wg be paid b you.
H. Doloulk You will be On Maim n:
1. YW de not make a paymn own ft to dPe; or
2. You JIM false or miSMWip nfrmbon on your credit
applbawf raaltrp to 0. contract; or
3. Your vehicle is sized by any local, W , a federal
authority and is stmt prD p&i and rnmWilbnaiy asserted
ro you; or
4. YW ase a banmuoky petition or ones it NW against you: a
5. You do not leap any Other prahase in the contract.
II you default, Saner an samcwe Same$ War under ask con-
tract are SWW. O , pea rover the fah.
1. Repomm abn: It you defaI the Sour my rather. you M
Pay r - M. Moab Amount Financed. Me -.ad rhd unpaid
pan of the Fnama CA" Lid all cater aeroum due alder me
drltract. Saner My "Pew;. (take back) aid wlade. eo. Soar
My 9100 tam garM bend in r on the Miele Whim repostamml
and hob Mrn ter you.
J. Your Riga To Rad• : If Me vehicle is taken back. Sant
will sand you a nonce. The nobs win say that you may ndesm
(buy beck) ale which and will aplW how b moment the ve im.
YW MY radeBtn IM wlide a to to clam Me Sailer nine ft r
apses ro men ft. It you do not reclesrn ft whld•. a WM be Sold.
K; DWPDONI o of Mar Vehicle: II the vehicle Is whim bdblk
and said, m many from the sale, Naa allowed ezperem, will
be mad b Pay aid -1 60 owed en ft dement. Allowed
.penm. Mum those Paid as • direct ankle of laving b seeks
the whkle, hold It, prepare a for saw. and teen X ReaMxaM ?
lawyer's fw and label pals an allowed, M. It them 1. any
mOlwy ash a (aurpde), ft MI be paid as you. It did many tram
the soft is stmt enough to pay off he paled and and, you WIn
Pry What b 80 owed to Me Sailer. 11 you do not pay to allrrnl
when me Sear aaks. Ion Saler my charge you Interest at to
highest aMul rap until you pay.
L. CWN"m Coat: Except m oftersh a paned by law, you
mash Pay any and all exPerwes Mated to mWdM Ma Wnbar,
WOW" collection expense, lewy.W ices and W her, "al
mmmes.
M. Cmaaesr R" : You submrlm M. Assimar sided on the
Irom of Mi. comsct b d". OonNrrer o m raprla trrn can-
sufer W." agencies (..0 resew) Me sty maen and w
My Jim in comeattlon with this centre.
N. APPkebw LaW:You Dg aMWCConlndw'Ngovamsd
by ft ewe of the fame of Parmywarks
OMNaI: Tina Conlrect order Ma emN pmaarlnarnl bahhvean
0.
Seller and you "leap a tlw SM and leaning of the motor
Wade. It any pat of this contract Is no ald. a DOW parts a"
wend. n Sear d-I entanw se.r. pm. awry am. 5esar
ar.mura mem laer.9aKKMY.wmbe Ml a Seller's nghq
In a mwful way.
II the last Mefanmrs partners under this mnbeCt is a baibM
payment, AssfpMe has asegnsel to OI Exchange. M Its capacity
m Ampnae's,"Maed Wftnvw dlery. its does (Wt Me ds
obfip6 .) with respect to ft purchases and and at Ills whtM.
NOTICE - ANY HOLDER OF THIS CONSUMER CREDIT
CONTRACT IS SUBJECT TO ALL CLAMAS AND
DEFENSES WMCH THE DEBTOR COULD ASSERT
AGAINST THE SELLER OF GOODS OR SERVICES
OBTAINED PURSUANT HERETO OR WITH THE
PROCEEDS HEREOF. RECOVERY HEREUNDER BY
THE DEBTOR SMALL NOT EXCEED AMOUNTS PAID
BY THE DEBTOR HEREUNDER.-
Used UN. Vehicle Buyan Gouda. N you are buykp a
used whole with tea corral. aderai rafa6baw my
require a aPedai Bury- Gouda W he diepkyad on the
wr1110. of We vehicle. THE NFORMATION YOU BEE ON
THE WIRDOW FORM FOR THIS VEHICLE IB PART OF
THIS CONTRACT. INFORMATION ON THE WINDOW
FORM OVER=ES ANY CONTRARY PROVISIONS N
THE CONTRACT OF SALE.
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w taaaastvC ItesrAW
"'PRN-
Ford Motor Credit Company
P.O. Box 17948
GREENVILLE, SC 29606-8948
(877)8Q5-7187
P111AD00200027
JAMES D. NELSON
11713 CEDAR CLIFF DR.
CAMP HILL PA 17011
Date of Repossession 03-11-2010
Date of Notice
03-13-2010 Date of Contract
06-05-2007
Account Number: 042568766
Buyer JAMES D. NELSON
Cobuyer JENNIFER N. NELSON
DESCRIPTION OF PROPERTY
Year
2007 Make
FORD ?x New
? Used
Vehicle Identification Number.
3FAHPD8147R190039
Model
FUSION Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
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 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,
includin reasonable attorney's fees and legal expenses if
permittz by law) will reduce the amount you owe. If we get
less motley than you owe, you will still owe us the difference. If
we get ore money than you owe, you will get the extra money,
unless we must pay R 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
paymeros), 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 ekolanation.
The property is presently stored at: MANHEIM AUTO AUCTION
1190 LAN ASTER RD
MANHEIM PA
HOW TO GET YOUR PROPERTY BACK
To get your property back, pay us this amount by certified check or
money order before the vehicle is sold.
Unpaid Balance $ 20,723.59
Plus Costs: Repo Expenses $ 370.00
Plus Late Charges
Less Finance Charge Rebate
Less Insurance Premium Rebate
TOTAL
$
$ 40.97
$ 21,134.56
(Plus expenses incurred If default at the time of repossession exceeded
15 days and less rebate received after the date of this notice.)
Your property won't be sold until 15 days after the date of this notice at
the EARLIEST. After that you can still get It back any time before its
actually sold.
We are ending this notice to the following people who have an
interest i the property described above or who owe money unde
your agnlement: 1) The buyer and any cobuyer named above;
2) Any d aler/original creditor named below; 3) If there are other
people, grey are named on an attachment sent with this notice.
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 greement with your dealer/original creditor, the dealer/originai 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.
0 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
cents ing this office. Thereafter, the personal property shall be disposed of accordingly.
? Credit r 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.
PAYMENT : 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 accura ly 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 ncelled. You have a right to get credit for all premium refunds.
BELINDA VEGA
F'FNA 11688-37 Jan 02 Previous edb=S may NOT be used.
Printedin U.S.A CUSTOMER/CUSTOMER FILE
.
"'PRN'•'
Ford Motor Credit Company
P.O. Box 17M
GREENVILLE, SC 29606-8948
(877) 800-7187
P111A000200037
JENNIFER N. NELSON
19117 KENT DR
CAMP HILL PA 17011
Date of Repossession 0311-2010
Date of Notice
03-132010 Date of Contract
06-05-2007
Account Number. 042568766
Buyer JAMES D. NELSON
Cobuyer JENNIFER N. NELSON
DESCRIPTION OF PROPERTY
Year
2007 Make
FORD Q New
? Used
Vehicle Identification Number.
3FAHP08147R19003g
Model
FUSION Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
S
S
7x PRIVATE SALE: We will sell the property described ? PUBLIC SALE: We will sell the property described above at public
above let 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 date). The sale will be hell as follows:
prior to such sale.
Date of Sale Time of Sale Place of Sale
You may attend the sale and bring bidders If you want.
The money that we get from the sale (after paying our costs,
including] reasonable attorney's fees and legal expenses if
permitted by law) will reduce the amount you owe. If we get
less money than you owe, you will still owe us the difference. If
we get njore 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 u? 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 eXDlanation.
We are sending this notice to the following people who have an
interest in the property described above or who owe money under
your agr ement: 1) The buyer and any cobuyer named above;
2) Any d$aler/original creditor named below; 3) If there are other
people, they are named on an attachment sent with this notice.
? The property has been (or will be) returned to
NOTICE OF REPOSSESSION
The property is presently stored at: MANHEIM AUTO AUCTION
1190 LANCASTER RD
MANHEIM PA
HOW TO GET YOUR PROPERTY BACK
To get your property back, pay us this amount by certified check or
money order before the vehicle is sold.
Unpaid Balance $ 20,723.59
Plus Costs: Repo Expenses $ 37000
Plus Late Charges
Less Finance Charge Rebate
Less Insurance Premium Rebate
TOTAL
$
$
$ 40.97
$ 21,134.56
(Plus expenses incurred if default at the time of repossession exceeded
15 days and less rebate received after the date of this notice.)
Your property won't be sold until 15 days after the data of this notice at
the EARLIEST. After that you can still get it back any time before its
actually sold.
If you do, we'll have no further claim on it. But the longer you waft, the
more costs (including repairs) you may have to pay.
If you have any questions about this, please call us.
(dealer/original creditor)
Under our agreement with your daaler/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money
after the salt, you will pay it to the dealer/original creditor.
0 PERS NAL 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.
? Credit r has assigned to its qualified intermediary (01 Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above.
PAYMENT : 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 aeeurat ly 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 neelled. You have a right to get credit for all premium refunds.
BELINDA VEGA
FFNA 11988-31 Jan 02 Previous ed1bons may NOT be used. CUSTOMER/CUSTOMER FILE
Printed in U.S.A.
05/19/2010 11:32 AM
Ford Motor Credit Company
P.O. Bo 17948
Greenvill , SC 29606
1-877-8 7187
DATE: May 19, 2010
JAMES NELSON
1713 CEDAR CLIFF DR
CAMP ILL PA 17011
STATEMENT OF SALE
Ford 6153152608 14/18
Account Number: 042568766
The following property has been sold.
Year Make Model
2007 FORD FUSION
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: Exp nses of retaking and storing, and
any ttomeys' fees allowed by law, and
expo ses of reconditioning and selling.
Deduct: Insurance Premium Rebate
Outer:
Deficiency`*
Surplus*
The Surplus
added to yoi
Surplus" or C
' If the sale
" If the sale
payments
For addltl
FORD CRI
P.Q. BOX
MESA, AZ
1-800-732-
(1) $ 20,394.56
(3) $ 20,394.56
(5) $ 7.494.56
(9) $ 8,174.09
(10) $ 0.00
will change based on monies received by us (credits) or additional allowed expenses & interest
I in a surplus, a refund for the difference will be mailed to you.
I in a deficiency, you should immediately remit the amount shown on line 9 to the address for
below.
Information call or write:
NATIONAL RECOVERY CENTER
6-6508
Vehicle Identification Number.
3FAHP08147R190039
(2) $ 0.00
(4) s 12,900.00
(6) $ 1,235.44
(7) $ 555.91
(8) $ 0.00
Mall deficiency payment to:
FORD MOTOR CREDIT COMPANY
P.O. BOX 55000
DEPT 194101
DETROIT, M148255 1941
FFNA119M 01104 Previous ed1bone may NOT be U"d.
05/19/2010 11:32 AM
Ford Motor Credit Company
P.Q. Box;17948
Greenville, SC 29606
1-877-87187
DATE: May 19, 2010
JENNIFER N NELSON
1917 KENT DR
CAMP HILL PA 17011
STATEMENT OF SALE
Account Number: 042568766
The following property has been sold.
Year Make Model
2007 FORD FUSION
Gross balance owing on your contract
Deduct: Finance Charge Rebate
Balance owing prior to sale
Deduct: grass proceeds of the sale
Balance less gross proceeds of the sale (3 - 4)
Add: Expe ses of retaking and storing, and
any a mays' fees allowed by law, and
expe ses of reconditioning and selling.
Deduct: Insurance Premium Rebate
Other:
Deficiency"`
Vehicle Identification Number:
3FAHP08147R190039
(2) $ 0.00
(4) $ 12,900.00
(5) $ 1,235.44
(7) $ 555.91
(8) $ 0.00
Ford 6153152606 15/16
(1) $ 20,394.56
(3) $ 20,394.56
(5) $ 7,494.56
(9) $ 8,174.09
Surplus` (10) $ 0.00
The Surplu&Tf I eficiency will change based on monies received by us (credits) or additional allowed expenses & interest
added to your?account debits).
Surplus` or D cienw*
If the sale resulted in a surplus, a refund for the difference will be mailed to you.
" ff the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for
payments own below.
For additional Information tall or write: Mail deficiency payment to:
FORD CREDIT NATIONAL RECOVERY CENTER FORD MOTOR CREDIT COMPANY
P.O. BOX 5508 P.O. BOX 55800
MESA, AZ 852-16-6508 DEPT 194101
1-800-732-226 DETROIT, Ml 48255 1941
FFNA11M 01104 Predom *W1o z may NOTDe wed.
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ORIGINAL 5/14/2010
VEHICLE CONDITION REPORT
Manheim
MANHEIM PkNNSYLVANIA CUSTOMER FORD MOTOR CREDIT COMPANY,LLC
1190 LANCASTER ROAD ACCT. NAME FMC/REPO
MANSEIM, PA 17545 ACCT. UNIT NO. 48063000000000000042568766 RTR
800-822-2086 INSPECTOR LARRYH INSP DATE 4/24/2010
VIN 3FABP0814 8190039 2010 29 14 645 ARRIVAL DATE 4/23/2010 STOCK " 158246
DESCRIPTION 2 07 FORD FUSION SEL 4DSN 42 Moon Roof, TAN wlTAN Leather
MECHANICAL 3. Liter 6 Cylinder Gas, Automatic, Pwr Brakes, Pwr Steering
MILEAGE 4 ,790 MI, 6 DG, Digital TM_
RADIO C Player, Aux - USB Input, CD Changer/OEM-06-Dash, MP3 Compatible
EQUIPMENT P r Locks, Pwr Windows, Pwr Seats - Drivers Only, AC, Cruise, Rear Defroster, Tilt Wheel„ ABS Brakes,
MMR $ 11,900 A?r Bags/Dual-FrontFloor Mats, Heated Seats, Sec System, St Wh Audio Ctl, Traction Ctrl, Trip Computer,
Trip Counter, Telesep Str Whl, Woodgrain Int, Alloy Wheels, Fog Lamps, Heated Mirrors, Pwr Mirrors,
P*r Trunk/Gate, Spoiler, Two-Wheel Drive, Regular Dash, 49 St Emis, Own Manual, EPA Label, Wmty Book
Labor
NON CHARGEABLE (Normal Pear & Tear)
nish Tear)
E:3 Front Bumper Cover Mult Scratches 4?? (Excess RefiNear
4IN TOTAL.
? LF Wheel Curb Rash
13 LRDoor Dent/No Paint 1/2" to 1" R
it
PDR/2 Pp
? LR Tire Worn
? Rear Bumper Coveri Scratch Heavy
? RF D
A Repplacement Req Replace
1/S" to 1/2" Touch Up
oor
pplique Dent/No Paint
6E5Z 5420555 Ai
A Replacement Req Replace 2
? RR Door App Iigqae DenvNo Paint
6E5Z 54255A34 AA Replacement Req Replace .2
? RR Tire Worn
? Keyless Remote Missing
? O
l Replacement Req Replace
None Replace
t
Dirty Unacceptable Replace
Parts
Labor & Paint 3. 2 Hrs.
Mechanical .4 Hrs.
PDR
CHARGEABLE DAMAGE TOTAL:
Announced Cond4 ion........ . REPO;MNRF;ABS
Consign To..: Fi ancial TOTAL DAMAGE
Color Code..: N /YC Parts
Driveable ...: Ye Labor & Paint 3
2 Hrs
Int . Cond ...: Di ;
y, OK Odor .
.
Mechanical .4 Hrs
Cert. Cared... .
PDR
berlot.... u
Oil Cored....: Po? c
r/Dirty
A DAMAGE TOTALS:
Keys ....._:M '
..: Mss
Tires
LF
1 Trk N Spr N Val N Rem N Inf N Cmb N KGo N
.......: 7 GENERIC 22515OR17 LR 2 MICHELIN 225/50817
RF
Service .....: Sc 7 GENERIC 225/50R17 RR 2 MICHELIN 22950817
eduled Maint. No Date - Mileage - Location -
Category Code.., RTR
Labor Part
Fees cow
I
3.2 105.60
1.00
45.00
1.00
6.00
6.00
7.50
500.88
115.10
12.00
45.00
672.98
500.88
115.10
12.00
45.00
.00
672.98
Average
SP Mini Spare
185.00
56.74
49.14
185.00
25.00
Grade 3.9 - Average (Manheim AutoGrade)
Title Received......: 5/06/2010 Acceptance Date:
Approved By: Date:
Last Updated By: Dam:
Detail Fees No( Included. Page 1
2010 029 14 0645
SOFT COPY WORK ORDER 158246
PA
CUSTOMER
4910256
ESf. ? T Rl
5/14/2010 QTIo
FORD MOTOR CREDIT COMPANY,LLC
ONE AMERICAN RD
DEARBORN, MI 48126
VIN 3FAHP08147R?90039 ARRIVAL DATE 4/23/2010 WORK ORDER 158246
YEAR MA10$ MODE.
2007 FORD FUSI BODY COLOR MILES ENG R TRY PS PS AC SIP ES TOP CC EL INT CLR 4X4 TL SRS SI DF
SEL
SOLD 5/14/2010 S # 41)SN TAN 041790 60 C A
LEASE 48063000000000000042568766 X X X X D
TITLE MR X X L TAN 2 X D F X
i DESCRIPTION PART/INV# OTYIHR COST AMOUNT TOTAL
LR,RR TIRES
RR DOOR APPLIQUE 694537 400.28 440.28
RF DOOR APPLIQUE 697789
697789 35.07
30
38 38.58
33
42
TOTAL PARTS & MATERIAL . .
512.28
REPL LR,RR Ti
S
REPL RR DOOR APPLIQUE
15.00
15.00
REPL RF DOOR A LIQUE .20
.20 30.00
30
00 6.00
6
00
TOTAL LABOR . .
27.00
REF:LF WHEEL
PDR LRDR 822 50.00 55.00
TOTAL SUBLET REPAIRS 0401165602 .00 45.00
100.00
GAS 2 GALLONS
TOTAL MISCELLANE!6US EXPENSE 3.66 3.66
3.66
VALUE DETAIL 72.50
TOTAL APPEARANCE RECO
72.50
72.50
NDITIONING
* NON-DEDUCTIBLE CHARGES
REPO;MNRF;ABS
SOLD TO: 5075930 2?
INVOICE PRICE
SALE PRICE
SALE FEES
i A/R AMT
RECON TOT
DLR RECON
CERTIFIED
SALES TAX
PRIME FEE
SIMLCST SAT FEE
SELLER PROMO FEE
TOTAL EXPENSES
NET SALE PRICE
ENTRY #
CHECK OR DFT #
14,775.00
87& 12,900.00
85.00
715.44
30.00
830.44
-------------
82% 12,069.56
029 2010 14 0645
7374936
72.50
PARTS & MATBRIAL 512.28
LABOR 27.00
CR/INSPECTIOKB/IMS
SUBLET REPAIRS 100.00
MISCELLANEOUS EXPENSE 3.66
APPEARANCE RECONDITIONING 72.50
BELLI= & ADMIPISTRATm FEES
ADVANCE CHARGES
TRANSPORTATION
RECON TOTAL 715.44
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Ford Motor Credit Company
Case Number
vs.
James D. Nelson (et al.) 2010-6687
SHERIFF'S RETURN OF SERVICE
11/02/2010 07:19 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
November 2, 2010 at 1919 hours, she served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: James D. Nelson, by making known unto Jennifer Nelson, Wife of
defendant at 1713 Cedar Cliff Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and
at the same time handing to her personally the said true and correct copy of the same:
/I
AMA DAC GH, bEPUTY¢
11/02/2010 07:19 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
November 2, 2010 at 1919 hours, she served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Jennifer N. Nelson, by making known unto herself personally, at 1713
Cedar Cliff Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time
handing to her personally the said true and correct copy of the same.
A ND J`COBAUGN; DEPUTY ?6
SHERIFF COST: $57.50 SO ANSWERS,
a/ y
November 05, 2010 RONW R ANDERSON, SHERIFF,
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
FILED-OFFICE
OF THE PP'OTHONGTARY
Attorneys for Plainti'f,11 JAN 3 I PM 2: 07
CUMBERLAND COUNTY
PENNSYLVANIA
(215) 789-7151
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
JAMES D NELSON
JENNIFER N NELSON
Defendant(s).
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 10-6687
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the verification of the Plaintiff, FORD MOTOR CREDIT COMPANY,
A Delaware Limited Liability Company, for that of the verification previously filed.
Respectfully submitted,
MAURICE & NEEDLEMAN, P.C.
JOANN
Attorney
, ESQUIRE
Date: January 11, 2011
CERTIFICATE OF SERVICE
I, Joann Needleman, Esq. hereby certify that on this date [ 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:
JAMES D NELSON
1713 Cedar Cliff Dr.
Camp Hill, Pa 17011
JENNIFER N NELSON
1713 Cedar Cliff Dr
Camp Hill, Pa 17011
Respectfully Submitted,
MAURICE & NEEDLEMAN, P.C.
BY:
Jo eedleman, Esquire
At rney for Plaintiff
DATED: January 11, 2011
VERIFICATION
I, Patsy Gutierrez 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 any knowledge, information and
belief.
These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to
unworn falsification to authorities.
BY:
Representative of Plaintiff,
FORD MOTOR CREDIT COMPANY LLC,
A Delaware Limited Liability Company
DATE: OCT 2 4 2010
JAMES D NELSON
Our file no. 14384
48063000000042568766
t
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) 789-7155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
CUMBERLAND COUNTY COURT
COMMON PLEAS
CASE NO. 10-6687
n
c") r--3 -n
C:)
V.
JAMES D NELSON AND JENNIFER N
NELSON
Defendant(s)
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
No answer having been filed in the above Civil Action, kindly enter Judgment in favor of
Plaintiff, and against Defendant(s), JAMES D NELSON and JENNIFER N NELSON in the
amount as follows:
Principal Amount $ 8174.09
Interest to Date $ 348.80
Attorneys Fees $ 2221.00
TOTAL $ 10743.89
Date: February 7, 2011
DLEMAN, ESQ.
Attorney f r Plaintiff
W14 q. Do 4
5
si -1 q
MAURICE & NEEDLEMAN, P.C.
BY:
JOANN N
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
1J) /tSy-/1J?
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-6687
V.
JAMES D NELSON AND JENNIFER N
NELSON
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 December 21, 2010 she mailed a written Notice of
Intention to File the Praecipe to Defendant(s), JAMES D NELSON, at 1713 CEDAR CLIFF
DR. , CAMP HILL, PA 17011 and JENNIFER N NELSON, at 1713 CEDAR CLIFF DR CAMP
HILL, PA 17011 by regular mail.
MAURICE & NEEDLEMAN, P.C.
BY:
JOANTY NEEDLEMAN, ESQ.
SWORN TO AND SUBSCRIBED
before me this-)"day
of "yam v ,0.7 , 2011 .
Notary Public
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
I C. SUSAN TREPACZKA, Notary Public
City of Philadelphia, Phila. Counttyy
j My Commission Expires March 23.. X012
U
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
(L15) /?Sy-/1J?
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
JAMES D NELSON AND JENNIFER N
NELSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-6687
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on
December 21, 2010 to Defendant(s), JAMES D NELSON and JENNIFER N NELSON, 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 December 21, 2010 a copy of the
mailing to the Defendant and affidavits of service are all attached hereto.
MAURICE & NEEDLEMAN, P.C.
BY:
JOANY NEED EMAN, ESQ.
Attorney for Plaintiff
Date: February 7, 2011
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(L1J) /Z59-/1JJ
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
JAMES D NELSON AND JENNIFER N
NELSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-6687
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(s): JAMES D NELSON,
1713 CEDAR CLIFF DR.,
CAMP HILL, PA 17011
JENNIFER N NELSON
1713 CEDAR CLIFF DR,
CAMP HILL, PA 17011
Date: February 7, 2011
MAURICE EEDLEMAN, P.C.
BY:
JO EEDLEMAN, ESQ.
Attorney for Plaintiff
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
IN 789-7155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
JAMES D NELSON AND JENNIFER N
NELSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-6687
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
SS.
COUNTY OF PHILADELPHIA
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she represents the Plaintiff in the above entitled case and that Defendant(s), JAMES D
NELSON and JENNIFER N NELSON, are over 18 years of age; the occupations of Defendants
are unknown and to the best of Plaintiffs knowledge, information and belief, Defendants are not
in the military service of the United States, nor any State of Territory thereof or its Allies as
defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto.
MAURICE & N *EE?MAN, P.C.
BY:
SWORN TO AND SUBSCRIBED
before me this ay
of I, 2011.
Notary Public
NOTARIAL SEAL
C. SUSAN TREPACZKA' Notary Pubk
city of Ph is, Phila. Coun
M COMM" Expires March 23__ t_012
JOANN NEEDLEMAN, ESQ.
Attorney for Plaintiff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
M???i?` of t"•#:lte?rj?f?b
eFord Motor Credit Company
vs.
James D. Nelson (et al.)
Case Number
2010-6687
SHERIFF'S RETURN OF SERVICE
11/02/2010 07:19 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
November 2, 2010 at 1919 hours, she served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: James D. Nelson, by making known unto Jennifer Nelson, Wife of
defendant at 1713 Cedar Cliff Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and
at the same time handing to her personally the said true and correct c y of the same. }
1 n n / 3 rF
AMA DA C k0dH, DEPUTY r?
11102/2010 07:19 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
November 2, 2010 at 1919 hours, she served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Jennifer N. Nelson, by making known unto herself personally, at 1713
Cedar Cliff Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time
handing to her personally the said true and correct copy of the same.
Ir
A D COSAUG DEPUTY
SHERIFF COST: $57.50
November 05, 2010
SO ANSWERS,
RONK R ANDERSON, SHERIFF
t s?. :r-tr .. _
December 20, 2010
Attorneys of law
Suite 935, One Penn Carder
1617 John f. Kennedy Blvd.
Philodet*' PA 19103
tel. 215.665.1133
fax 215.563.8970
www.mnlowp(.cem
Doaoid S. Mount.
Member NJ Bar
Board Certified
Creditors Rights Low
American Boord of Cerffficafion
Joann Needleman
Member PA & KJ Bar
Themes R. Dominczyk
Member NJ, NY & PA Bar
Rachel Morin
Member NY & NJ Bars
Kew Jersey Office
Maurice & Needlemon, P.C.
Suite 2007
5 Walter F. Farah Blvd.
Flemington, N108822
tel. 908.237.4550
fox 906.237.4551
JAMES D NELSON
1713 CEDAR CLIFF DR.
CAMP HILL, PA 1701.1
RE: FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY v. JAMES D NELSON AND
JENNIFER N NELSON
CUMBERLAND COUNTY COURT OF
COMMON PLEAS, CASE NO. 10-6687
Dear Mr/Mrs/Ms NELSON:
Our File No. 14384
Enclosed please find a ten (10) day notice of default which is self-
explanatory. This is being served upon you due to your failure to respond to
Plaintiffs Complaint served upon you on November 2, 2010. Unless an answer to
Plaintiff's Complaint is filed with the Court within ten (10) days from the date of
this notice, a default judgment 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.
Joan eredleman, Esq.
JN/d h
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
IJl -/z59-71J1
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
JAMES D NELSON AND JENNIFER N
NELSON
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-6687
IMPORTANT NOTICE
TO: JAMES D NELSON DATE: December 20, 2010
1713 CEDAR CLIFF DR.
CAMP HILL, PA 17011
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 1.7013
(717) 249-3166
MAURICE & NEEDLEMAN, F.C.
BY
JOANN -1 . tEDLEMAN, ESQUIRE
Attorn4ior Plaintiff
2 CA)
D
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December 20, 201.0
Our File No. 14384
Attorneys at law
Suite 935, One Penn {enter
1617 Jahn F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.665.1133
fax 215.563.6970
www.mnlawpc.com
Donald S. Maurice
Member NJ tar
Beard fortified
Creditors' Rights Low
American Board of Cerilication
Joann Needleman
Member PA & NJ Bar
Thomas R. Dominczyk
Member NJ, NY & PA Bar
Rachel Morin
Member NY & N1 Bars
New Jersey Office
Maurice & Needleman, P.C.
Suite 2007
5 Waller E. Foran Blvd.
Flemington, NJ 08822
tel. 908.237.4550
fax 909137.4551
JENNIFER N NELSON
1713 CEDAR CLIFF DR
CAMP HILL, PA 17011
RE: FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY v. JAMES D NELSON AND
JENNIFER N NELSON
CUMBERLAND COUNTY COURT OF
COMMON PLEAS, CASE NO. 10-6687
Dear Mr/Mrs/Ms NELSON:
Enclosed please find a ten (10) day notice of default which is self-explanatory.
This is being served upon you due to your failure to respond to Plaintiffs
Complaint served upon you on November 2, 2010. Unless an answer to Plaintiff's
Complaint is filed with the Court within ten (10) days from the date of this notice,
a default judgment may be entered against you.
If you would like to discuss a resolution to this matter, please call our office at
408-237-4571 and ask for Kim Crosby.
Thank you for your prompt attention to this matter.
Very truly yours,
MAURICE & NEEDLEMAN, P.C.
1
Joann j eedleman, Esq.
JN Id
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
(215) 789-7151
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
JAMES D NELSON AND JENNIFER N
NELSON
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-6687
IMPORTANT NOTICE
TO: JENNIFER N NELSON DATE: December 20, 2010
1713 CEDAR CLIFF DR
CAMP HILL, PA 17011
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY AN 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 JUDGMENT 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 ELIGLE
PERSONS AT A REDUCED FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
MAURIC-A & NEEDLEMAN P.C.
BY -
JOAN VNEEDLEMAN, ESQ
Attornty for Plaintiff
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Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Sep-10-2010 09:01:02
Last irst/Middle Begin Date Active Duty Status Active Duty End Date Service
en
A
Name cy
g
Based on the information you have furnished, the DMDC does not possess any information
NELSON JAMES 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
i
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 htW://www.defenselink.mil/fac?pis/PCQ9SLDR.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.
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
https:'/ww,A.dmdc.osd.mil,,appi ?scra/poprenort.do[9/ 10/2010 12:02:35 PMl
Request for Military Status
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:LJRCUBAGGQ
https://www.dmdc.osd.millappj/scrvpopreport.do[9/]0,'2010 12:02:3 PM
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Sep-10-2010 09:03:28
Last First/Wddle Begin Date Active Duty Stets Active Duty End Date Service
Agency
Name
Based on the information you have furnished, the DMDC does not possess any information
NELSON JENNIFER 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 littl2://,N-xA,,.defenselink.mil/faq/12is/PC09SLDR.ht-n-il. 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.
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 Si rvice
https:;iwwxN,.dmdc.osd.mil/app_i/scra/pooreport.do[9/10/2010 12:04:52 PM'
Request for Military Status
or the National Oceanic and Atmospheric Administration (NOAH 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:GEDPUAW52
htti)s:,,www.dmdc.osd.miliappi%scrainonreport.do[9,i10'2010 12:04:52 PM]