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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 7 7 fr7 JENNIFER N NELSON < -+ - 1713 Cedar Cliff Dr ?, Iv Camp Hill, Pa 17011 c W , " Defendant(s). > - cD " -r n f TVilf . S CTIFnV CnX4VR A IIAT'T '- I --- ?" y 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 $10512.68, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. JOANN NE LEMAN, ESQUIRE Attorney f Plaintiff Date: October 15, 2010 VERIFICATION I, JOANN NEEDLEMAN, ESQUIRE verify that I am the Attorney of record for Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A DELAWARE LIMITED LIABILITY COMPANY, and duly authorized to make this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. BY: JOANN NEADEEM-AN, ESQUIRE DATED: October 15, 2010 PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL MSTALLMET CONTRACT DATE 1i/ns/,n07 12006rn-7000 r lab Co-BUyNI Hmu dig ben.Ice coon, County as. fEtLEAR7RnnOR lYfr IW? atl Ilaerw) zP goer) JAMES D NELSON JENNIFER N NELSON B SMITH FORD INC 1917 RENT DR 1100 MARKET ST ® CAMP HILL PA 17011 EMOYNE PA 17043 CUMBERLAND DEMO 15712 (FORD rv'a . I 3FAHP08147R190039 I ? Cooanoa o Ap"'e"s ITENIMAT10N OF AMOUNT FINANCED INSURANCE 2. Oaa PeYelutl SOO OD . lllnd Pafy r116a1. Awignad b MMr.-.......-.._..__.?-3 -WA ° f4$°r,DaD DD i - IYR""_sTODD. 00 YrrW uar Grow Abwaas AoaaM Owes 'R.W Down P-reent___..f 1. 500.00 3. Wesse ftWM at IYW PrIU (I rte 2l $24, 340.00 (3) 4. Amaups psd on your Was (Baer nay, to nelakup a a.r11PU of thaw amata) To pl -Ic.na(< ?ebib oflM ($ 20.00 MS(f 22. 50 ).f r.ONlraofl M ). fora • . 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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 !N - 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. tle! ones. Yes Wakes") vn'I M eswra .mkrt sev mela- r er.seevsa hersr a am CeNesh new el.m., deMws, r adem W awn yon haw I.w.P.l"n m. Wmlr. r ea.m W N. a ton wwM.. GUARANTY To mum tea Sour ro 00 On WhI N desrb.0 on the from a the tread b m Buyer en reel .wen Pelson who Sign below as a Guamne r' pMMmm M p.ym.m or WS Nract. TW mans bid N Me Suryr mm b pry My money tlW Is Meted on the porract, each Pena Whe sips, as • gumarler WB Pry h when asked. Each Guarantor am, slow below apaaa ads he Will m'able for ion whole arrant owed sawn N cra or mre other parson m:I alpha bYS GlrerannlY. FJOn Gparantr aeo apma b N tWla M11 a tlw SOW does new or mom of ae folovrhg (a) gape aid Buyer mn err b Per ms, a mom paYr"hsrnq, a W) gwas a r.le.a. in Ind or l a as ads INS lyjy ol mealy aadey. Facln Gwarmbr ago Nerve tllat he has neaiwd s CMOmd copy Games, Admm Gnarsnmr Address Ardbabon le • mWmd of Mne, dlspute, or arrMray (cell.dwsy. a'CfaknI without seep • fawsMt I. court. Either you Seder 1'us' a -w') I a may dxrom d try kn, Mw ads a ewauk a DW, m Iww .try Cblm Mtlsd m see aMr.ot dCw.d by erotraibh. BnM irnakd•burmnot Ymn1110bm 11CMm MOOraraCi. rom4 npYairyaolMMn: 2) Clakrns tle ksspreWce, acePe, a a mle drum. r a a sty sere: ns bstwem you new as. youdmr . WM aPM almrmn, asslpn, r bW*A- or aMgaNa: a) Claim arkrp Wt of r3)1h ro eve rt you and ter your Mew dorol .n O. rNrp t"Madbl or Maps.", mdWrp mt WM the deals. or any.( wfih Mkd Pram pp?as?yy ro?!ru? AND w" AOREE m arvE Ile lapXTr'r A TIgAL, TY=ER BT Itnk?,R?J00E OR,NM?s m wrw me mYowng nom: . RKNIT TO PARTICIPATE AS A CLAW WPRW9RATIVE OR A CLAM M DER N ANY CLAIMS CLAN YOU aNY HAVE AtiAN18T S "*THE" N COIIRr OR N ARNTRATION • BROAD MUUM TO DISCOVERY AS ARE A' .ASU! 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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. ? x ro U. o ? x -? • a N ? w x 9.4 if) x • v ?O N a r7 N ? ? ? n? w o I I I I ? I H l O • a x x 0 cc tulo ¢ L) V w O J % w It? J c to F- w Q j 1 a o 0 -1 Cr. U a z Co ul a m A Q N m W a 4 w m 2 ?w LL (n Y ? Q r? 0 LL. 2 Cu 1.0 1 W J v W =a r ? , g 13- z - -- z Z 0 in w l? 0 z H a -- ?J LL J J z 0 rn U) En o a. ..LL W °ozir it or J V .n H zIL aw ir .. .. w w Q L7 -0 9 S N LOu t? m 49?2_ '0? (U F O 1 ti Q' %t U. o m° O O a m ° m N m tl? iR tlF iR W1-4 W w cwn a laic Q z . V- a ? e W S tb=??ji w w W'i c yC ZO t Fr E $ y W y ¢ 6a jj z Cr 7 S w O °hi ?? ?? ? O?? aW p 0 mgj Cp- r% LU f??7? Z 8 LL. Ct U) E0H ? ? \ V4 -, lull D S X X L v •0 SIB t 9 IL L F .9 O ) Im, 3 _ o . R r_ ° Fs ION N? en 2z T in C. 91, jo ; ?J CL M Ir 0 T -Cr (n w Cr LL 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 Cil C O- oz r m m =mz 5z0 Dm z m -, z m o oM M D z m 0 D-4 > - ?wm =m Ao DZ = _ Dnr- - Cl) =- -4-0 z 71 - ?4 ;U ompv, OO 40 o°o??cnO m?u ofOnn? ?r3.hi nti:'. 6fil£ASSOOOSZ90 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 rtnc O mmn r- -0 m = z z DZ0 Dm z m (0-Z-jo C) ;oM D z T n ??-4 M Z KW Z fin- _ Mn = r = r> 0;0 Z D()Z r m r - = -nC/) O .s - 0-" M;oa 0? "041 0-4 to O o?an.P CA 46 L6L£9SS000SZ90 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]