HomeMy WebLinkAbout11-3859ARBITRATION 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
Attorneys for Plaintiff
Our file no. 15386
(215) 789-7155
FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF
DELAWARE LIMITED LIABILITY COMPANY COMMON PLEAS'
P.O. Box 6508
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Mesa, Az 85216-6508 Case No.
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Plaintiff, ?
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V. Z 3 -ta
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ERIC P DOUGLAS
79 W Main St - +
Carlisle, Pa 17015
BRIDGET J DOUGLAS
79 W Main St
Carlisle, Pa 17015
Defendant(s).
CIVIL ACTION COMPLAINT
NOTICE AVISO
You have been sued in court. If you wish to defend Le ban demandado a usted en la corte. Si usted quiere defenderse
against the claims set forth in the following pages, de estas demandas expuestas en las paginas siguientes, usted tiene
you must take action within twenty (20) days after veinte (20) dias de platy al partir de la fecha de la demanda y la
this complaint and notice are served, by entering notificacion. Hace falta asentar una comparencia escrita o en
a written appearance personally or by attorney and persona o can un abogado y entregar a la corte en forma escrita sus
filing in writing with the court your defenses or defensas o sus objeciones a las demandas en contra de su persona.
objections to the claims set forth against you. Sea avisado que si usted no se defiende, la come tomara medidas y
)'on are warned that if you fail to do so the case puede cominuar la demanda en contra suya sin previo aviso o
may proceed without you and a judgment may be notificacion. Adernas, la corte puede decidir a favor del demandante
entered against you by the court without further y requiere que usted cumpla con todas las provisions de esta demands.
notice for any money claimed in the complaint or Usted puede perder dinero o sus propiedades u otros derechos
for any other claim or relief requested by the importances para usted.
plaintiff. You may lose money or property or
other rights important to you.
LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SURCIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
FIND OUT WHERE YOU CAN GET LEGAL HELP . SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE
SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
2 Liberty Avenue,
Carlisle, PA 17013
(717) 249-3166
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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
(L15) 7tSy-"/155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
ERIC P DOUGLAS
79 W Main St
Carlisle, Pa 17015
BRIDGET J DOUGLAS
79 W Main St
Carlisle, Pa 17015
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, Eric P Douglas, is an individual who resides at 79 W Main St
Carlisle, Pa 17015.
3. Defendant, Bridget J Douglas, is an individual who resides at 79 W Main St
Carlisle, Pa 17015.
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 May 17, 2008, the Defendant(s) entered into a written Motor Vehicle
Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of
obtaining financing in the amount of $22193.53 at an annual percentage rate of 17.290%, in
order to purchase a certain motor vehicle, 2008 Ford Focus more particularly described in the
Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and
marked as Exhibit A.
6. Pursuant to the Contract, Defendant(s) was required to make monthly payments in
the amount of $499.94 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 June 18, 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 Exhibit B.
9. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at
auction with a credit given to the Defendant in the amount of $9100.00, however a balance of
$10476.17 is still due and owing, and a notice of the deficiency balance was sent to the
Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C.
10. Pursuant to the terms of the contract, Defendant is required to pay all amounts due
and owing, including any balance that may remain after the sale of the vehicle, and the
Defendant failed to do so, thereby in default of the Contract.
11. In addition to the foregoing, there is interest due and owing on the deficiency
balance which at this time amounts to $243.16 and which will continue to accrue.
12. The total amount due and owing at the time of the filing of this complaint is
$10,798.73.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $10,798.73, 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 EMAN, ESQUIRE
Attorney fo Plaintiff
Date: April 14, 2011
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:
JO EEDLEMAN, ESQUIRE
DATED: April 14, 2011
INSYLVANIMBIMPLE INTEREST VEHICLE RETAIL ItMALLMEN7GO&it*O DATE 0511710.
SELLEaICIIEmiOR lsrrr Ner rem AtlMaaaf
14100.727.7000 Irer Intl Coeuyer) Nan' am Aadre (""'M Caunly and
2p Coe) Ep[C p p?O?p?
INC.
BRID6EiDJ D0U6LAS 700 MITT RTE RDrNORTH 608
77PLAINFIlLO PPA917061 DILLSSURG, A 17019
CUMBERLAND COUNTY
w.rareDr.elaem raV g 0
you
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08 1 aru 20
I I .-- ,ra.Pa[Y2aD, a-yTao ? cm.n.ea
II ITEMIZATION OF AMOUNT FINANCED I I INSURANCE I
• t. Calls _........ ............... ...... _._._...... Smolt)
2. Down PSI se
Third Party Raises Am*" to Surer.... _.._....... _._.... _.._..5 3090. e
Cash Down Payment........ ........................ _....... _....... _...... S"0..?
7-*41 eqU ja= S fZ=M f_ ?
Total Down _.__.... _.............. _.......... S_1 1
3. Unpaid Behoem at Cash Price (l rarus 2) ..._..... _......... _..... _.....f )
4. Anahada paid on Vau balmt Miairr may be W A.9 a parson e11M?i"ae5 I
To Public O"idw
(i) for Hams O Heck (S ??3a a
(H) an my res S
(Hi) for arms (not o Cob Pdoe) S _..N S
To Havana Coffowiaa tor:
Crude LNe Inam a for ear of contrast) ._..._.__.__.._.... f ?
Crude [emblYly Inwarma (for rrhn of cawea)........ _......... f
(Term _ MafM) _...._.... N/A
TO IIfA row Rrem ?11iF Id°"nm)._..._._. i - lair 00
To?IOr? To GOST 6Brao;9-bb:?t eONT -t09T.W
To BERS-- --11H!RA8E-PAYOFF
-6QIh:'9Y
To ST OF P:r r fIRE FEE _ f .9 0
Ta?PµFp?br ?E? f
__ __._......... ...... ...__...._._.._._.__._.._.._.__..._._...... S 1
ToYT.
L Armand Renewed is pan 4)-..
5.--'?
!Q You IOU oaWment payment under this urwast I. • balloon pay.-.
EIICf86 WEA0. USE AND ME.EAGE CHARGES
If ere bon decker abdw r aleckud. this samon. Paragraph B, aro Parepnph C a
Hie comae apply. You may a charged for -.1w, wear bawd pa our slamor de
.br amml use. It you amaee oe option to ee the vehicle back to Seller urtlar
neb far each ale m eraau
.Paragraph B. you must pay the :=W7,
a?_ rd.-on p1TRA MLFAfiE OPM0/1 CREDIT
H ere mdrwA maarle a ladearh payma rt fee inoioNO abow), and you mart
axaraMd your Option b so to w" o me so. older Paragraph a. eis
paragraph applies to your ale o, At SIN volhaeAao am a ere Cpapl. you we
hacaiwi a pea a SD. par u-W nib br me numnr a tofu ed roles
?Wmasn -Eye real mina, rat any arrmlmr you
owe rndp edS'canbacl, You MI rmt'MMVe vy Cndlt If Me vMrr I. destroyed this
amreas ame mary, der you are In m a s you wa not naM any credit H the proof Is
Les than $1.00.
My tlrnga m am mNrKY mug M M armed, der .0w A wu and M Sala.
DISCLOSURE
YOU ARE REQUIRED TO INSURE THE
VEHICLE YOU MAY OBTAIN VEHICLE
INSURANCE FROM A PERSON OF
YOUR CHOICE.
LIABILITY INSURANCE COVERAGE
FOR BODILY NYURY AND PROPERTY
DAMAGE CAUSED TO OTHERS IS NOT
INCLUDED.
CREDIT LIFE, CREDIT DISABILITY AND
OTHER OPTIONAL INSURANCE ARE
NOT REODIRED TO OBTAIN CREDIT
AND WILL NOT BE PROVIDED UNLESS
YOU SIGN AND AGREE TO PAY THE
PREMIUM.
Crawl
? Llle
Inwrance Company
$
Preen Inismalls)
You want Credit Lee Insurance.
Buyer Signs
Co Buyer Signs
Credit
? Dis"Iry
Insurance Company
P Insured(s)
You ward Credit Dicabeily Insurance,
Buyer Signs
Co-Buyer Signs
OTHER OPTIONAL INSURANCE
Covarape end Premium and
Ireurerce Camanv Term in Matlr
$
BY
S Y/A
By_
You area ne .- Fuurna for warn
Pmmlume an rauded above.
Buyer Signs
CpBuyre Sign,
QaM Loa and Greek DI aO" rrrrema aud:
tar e r ems a em canreL Thrarcs
peamsr en arwn r a minor re aprarm
0- n toe ra".
C==wt- imaO
Urn • tlaa
. l aaathe
e
omrm as - mowrr uire m err as aaMap. The
rpeanal and is m ere
maram mmlrrs emeelarnarlawarn
t
an act ion M Yla pare-Tm prbb h peach wI I
iraxrprealatl H1b Ma.lo,e em rdr eq
rannlrlb 0 -r aWWm IM
1- a Ama nit Idir r1 iaaramo uma aemn 6.
YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO BE BOUND BY THE ARBITRATION PROVISION ON I
The Annual PulrOWMVa Ram may be negotlMad with the Seller. The SMIw may assign thick eontreet and may retain
its ripe to roealVa a pmtka of the FiMnee Charge.
Do not sign this contract in blank. You are entRlad to an exact copy of the contract that you sign.
'Keep it to protect your legal rights.
Buyer (and Co-Buyer) acknowledge that (I) before aignlIt this Contrast, Buyer (and Co-Buyer)
receNed and rsvbwed a true and consplemely mime In copIf, t s Contract and (I1) at the time of
starting this contract, Buyer (and Co-Buyer) received a true and completely filled In copy of this
Contract
Ire sear X canna x t&- 4je N?y
aqn. agy.
V
LS4st
r X Ties
I
7teS CONTRACT IS A I DID U
NRL YOU AND SELLER 9G
1lifiT.
ASSIGNMENT
arr. ray rr.raa ,N. aonr.ar m,rnahXar Paradn. rack Paraan wu amn Ira an arr. dais., prwlrara. am amwra. or rremm wow, ram
arlw rrtpr der aarw.r m (•Aarrew')•
To Naar, AWyra .ran der . a area mrr ,..ease r
,rhlu. or ore t .con ?n
srha ere X wr ?e r 1/! ?
Nara moon meow asw rrmnawAi SEE DTIER SIDE POR AOmTIl-ADREEUE S
ORIGINAL
PLY I - 0R AL PLY 2 - aUYER9 COPY PLY 3 - CO4IUYERIGUARANTOR COPY PLY 4 . SELLERS COPY (NON-TRANSFERADLE)
? I
AnAlAil At. AGREEMENTS
A. Pays and Summary Nolice: You must make all pay-
nwnb in U.S. funds when May tiro due. You -Y prepay your
debt et cry time wMldlt Penalty. That e If simple interest contract.
The acual Pounce dung. you agree to pay will depend on Your
Palming poems. The actual islands charge may exceed Me
decksed Fn Charge H you make your payments later than
the scheduled Dabs or m Ins than the.Mheduted amount. Your
payment will he applied find to the ended and unpaid pad of taw
France Charge and Men b am unpaid Amount Financed. TN
Fkenco Charge is ..do by applying the Annual Percentage
Rate to We unpaid A-MA Farmed ha the scbral rime that ale
unpald Amount Fn-Iced Is auMandng. If 8e vehkle is repOs-
saluad, you will nil have the right to raMate the contract these
the Seller agrees.
B. Section Paymalt Contneb: N your am installment payment
under this commcl is a baton pay-. as indicated on the I-
01 the cnNram. you may hands the teal klaellment payment ,n
ore of three ways.
Fin g, you may pay al that you awe when IM last mslaymenl
payment re due and keep your motor vehicle.
.Second, you may relsunca the last instolWwt payment unless
you are in Default under this conned. D the Seller has advanced
funds 0 Oise any damdt, you must pay back DO, Stier betas
the refinancing. You shad must provide proof d insurama accept.
Wet* Baker behoralMrehns ng. The Annual Percentage Rate
(APR) for the refMancng will be ft laver of the APR agreed to
by you and rise Seiler at the miss of aw refinancing or Me
mandmum run padded by ear. The tent of the nmisuveng mil
be based on the amount nrinsnced, Me nil, and the amount of
the monthly Peymant The rofnanced mo ley payment hall be
Mar same as In flue compact H the arldr need .mound will be fully
paid wwio 36 domms of the due data of me [set imtaament
payment. Otherwise. Me maHMy payment amount Shall he the
mount needed b fully pay the rakanced amount mthin 36
months d tie due data of the fag inMOw m payment. II you
wash a MfiMnca, you mug Many, fns Sent- In wmslg. Eaceld as
disneaed in this ammn, Me notice mug he naeived M later
Then 30 days pna b1M dad Date d the lag nMUti tpayment.
Third, you may awl the vehicle to the Sager tar an amount must
M the laid Mstwmem payment. You must pay to the Seller any
her amount owed under this contract. Amounts you owe aria be
based, In pert ash tie vehk 'e mileage. You also most Pay W
the Batter the emersted come d w ipaks to the vehtde Mal are
Ihe resift d emdu caw and use, as as brill bebw. You must
take the velw le to a place effected by the Saner for respecaon
rod later than 15 days prior to the last intrallmMt payment due
ders. Alter 1M sepection. H you decide b well the vehtcle 10 Me
Salver, you mull give she Assets m lee Baker no later given Me
fag Lykl ant payment due call At Met lima, you must alp
give the Seller a aM, which grows no Hens other than the Seller's
lam, wnsWrkV owMn ip to Me Se"r or a person Worded by
the Scaler. After the inspelaan. 'd you deride .1 to .11 -hid.
tome Seller, you must i.--nary Gonad Me Satyr and Imam
the Better whWmr you want to roNnanca Me laid imtofteM
P.Yment.
C. Damage Repel: It your leg inatwkMnt payment under this
.no.p[ fa a namon payment .M you tar the wide back to
the Seller under Paragraph B, you acs responsible lot repass of
ail damage to the vehicle that are not ins msuH of Mma mar
end .Se. Than. repairs include, bid and ,hat Im m a, theSe
necwsay to
(s) Ali any am rid pert d a makeng set of four or arty the
which Ms ten tlhan 1/6 'ms of leaning wad:
(ii) repair all i edlanscal dwells:
(III) repair or replace all denad. scratched, chspped, -lad a
mismaMetl body panels, pairs or vehicle kentimali- Hans:
all of Arm. sCmtdwd, Need. said, broken or missing Mm
and gra woM; all Saakhed. MCkad, paced a brWan glass;
ell faulty vandow, rrefJhani-a; w broken or brmed our rights;
all seclforo malfunctions; ell nterior rips, Mr., but. or
word arose; and all dotage which would be ,canted by
core bn a campmherrve insurance whether or let such
rice b --y M tents.
II you have not mans he race" broom supecom, .1 em vehicle
under Paragraph B, you it owe the wMMated pate of such
.Pa., 01 at In. Pat,. an nil rasa. prior to your. 1. of the
Seller. If you disigme with the wilco W caste of
vehicle
rep- you may have Me handle made at your Om-80 prior W
you aeb of Ma vehicle a the Bailer.
0. Security W a . You give IN Stier. s eculy Mlereg In:
I. The vehade and all parts or star goods pa an the vehicle;
2. All money «goods repelved for the vml and
3. All imlaenca pmmlumc and serMOe commcts financed for
you.
Thle secures psYour Oof ail Yn ay- owe unar Dee c-wcl.
it also secures your other egreemrss in Mis eorsmct.
E. Use of Va l• • WarraMiw: You mug lake care Of 1.
vehicle and obey of laws in using H. You may nil MR or rim the
vehicle , and you mug keep H has from Me h farms of Shan. You
will not use «psmH the lab of Me vankN ouaida of We Unketl
sm_, saepl for p a 30 Days in Ganda Or Mexico, without
the pder wnhen consent of the Baker. S Visa v-Iesa a of • type
deriver -ly tasted far paneMl use and Via 8eb-, or the vahl-
de's nonawetunr, eStand. a wrNlen Manny « serves
contract war kq the veMofe wahb b bye hem the idle of
this a -t' Yee Bet MrplNd Mn-des.1 rn-oh sty
.rid IMeea ter a p-Ikuar pmpee• covering the Melee.
OIMnWee, Yal -Nerg-q -eel agrM lMl team an no se.h
frnPCed w-mliM, eaxp ee eth.Wd provided by law.
F. Vehicle komnm: You mvsl issue the vsole against bas
« Pomace from coUsiOn. in. a Men. You mwt Mme Selo, as
the I.. payee under ate i.ur-ca policy. The Boller dual
f
approve the type and amount Of Insurence. N the vehloes, Is lost
d-wged or destroyed, you most Pay the SeI W what is still
owed.
You agree Mal the Seller can make a claim miler the murenoe
polity. You au hicrize the Insurance tompafIly to provRle Wier
any m omuuon Baker believes Moeswery to make a claim. You
must use ineuunce proceeds to A meir the vehicle, unless the
damage to the vehicle is considered a -ual loss. It Ma Mmage
to the vehicle s. considered a total loss. You must - Ihe rown
ce proceeds, to pay calla you old the Seller. It your insurance
on the vehicle doesn't pay all you owe, you mull pay what is Still
owed
G. R-om.If 1Mur-ne PMelalla and Service Contract
Charges: This contract may,cmmeln charges for Inlumnce.
commons. or other conlracla. You agree that the Sell
can Iaim benefits under these contracts and unless prohibited
by law, brmklele them to Obtain wharfs d .-,Id .1.19.1.
reduce what you owe. It Me Saw gas a refund on nwm c a.
contracts, or other cmitimi the Sale, WI submecl Hiram
Service wnal you owe. Once all amounts care, under this commot an
paid, any rem anng retunds will be Paid to you.
N. Default: You will be in defmdt it
1. You do not make a payment when it u due; or
2. You gave false or mlalesdlag Intimation on your credit
apphcadon rebong to ft. comtmcl; or
3. Your vehicle is sized by any 1-1. sears, m f l
Mimomy and is not promptly and uncondllbneHy, rammed
to you or
6. You file a bankNmcY pemron or orb Is filed agafMt you; or
5. You oo not keep any Oder promise n this contract.
II you default, Sigler can a mcm Sahara rights under this con,
it= and Seger s Deer rights under the law.
1. Repoweesion: If you default, the Seller may require you to
Pay at ortco the unpaid Amount Firamed. the earned and Unpaid
pen d the FlMnce Charge and all other amounts dwe under Mle
contract. Seller may mp n IQ" back) the vehicle, M. Sander
may Stem take good. found in or on me wallas when repOeetwe•d
and Mid Poem 10, you.
J. Your Rigm To Radeam: It me vahidle is faker back, Seller
will Send you a notice. The nob" IN coy tell you may redeem
(coy back) tare vehicle eM wet MP MM now b redeem Me velvde:
You may redeem Me vehicle up s, Me time the MW soft It Or
agrees to sell it. II You do nil redeem the vehids. H will be arid.
K. Dkposltion Of Motor Vehicle: II the vaMCle I. elan back
and Sold, the money hod the eat, bas slowed agma . wig
N used to pry the amount still oared on the contract. Allowed
ekpentme include thnae paid as a cards result of having a retake
the vehicle. Mid It, prepare k for sale, and Sell It. Reasonable
lawyer's lees and legal ,meta ale allmved, Ip. II them a my
-,my left a (surpus), it will hepao in you. If the money from
the sale Is not enough to may on. this contract and comb, You will
pay wail is Sfill owed to the Salver. It you do elf pay thle amount
when Me Sailer Saks, the Sander may 0nsr9e you interest at the
highs., lawful to unlit you pay.
L CohCVim Cana: E=ve as dhawise provided by law you
must Pay any and all emenses misled to mbrcing this canrect.
mclnding collection expenees, (lawyers' tees and Other legal
expenses.
M. ConslNrtar Report.: You authorize the A iWm Need on the
front of MIS comes,- to titan conwrmer Crean r"WAS ham sumer reporting agaMiss laadt bureaus) for any caste- and at
any time In connection wiM this contract.
N. Applicable Law: You agme bull M us contract will be Dammed
try the laws of the stale of P-Mylvenla.
General: This eontreclctinleMSthe entire aprwemenrbwween
0.
Saber end you mlamg to the asks and finny" of the motor
vehicle. It any pen of the contract is feu valid, all othun pans stay
void. If Seller doe-T -force Sellers lights every timm. BMW
do gill amOme Inam Idler. Selbrwin...mme all of Swes- rights
,A a lawful way.
If the last uNlsllarent payment under this condact is a balloon
payment. Msighee flee assigned o OI Exchangs, in its capacity
as Aagami Qualified samrdwfary, Hs hghw (out rid Its
oalgaeang with reaped to the pmmhaee end We d In. wide.
FTC NOTICES
NOTICE-ANY HOLDER OF THIS CONSUMER CREDIT
CONTRACT IS SUBJECT TO ALL CLAIMS AND
DEFENSES WHICH 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
Ueetl Motor Vehicfe Buyers Guide. It you are buying a
used vehicle with this contract federal regulations may
require a special Buyers Guile to be disparyed on the
window of the vehicle. THE INFORMATION YOU SEE ON
THE WINDOW FORM FOR THIS VEHICLE IS PART OF
THIS CONTRACT. INFORMATION ON THE WINDOW
FORM OVERRIDES ANY CONTRARY PROVISIONS IN
THE CONTRACT OF SALE.
,gy was apply c wow for eaniva l Or apric" use. 1,
ulw caw. You (aeo) was reg? amasms astral wy s,-4- Or
wkeeewm Itataw a IMO Cwwwm shy w.w., aahMr, «aadla
adtkn rodnlry awe.llanalM e.k.rormaMlaaumaNwvwvd.i
GUARANTY
To cau. MISS Baker b cal the van" d-albe l on Me from of M. -I- W IM Buyer on tract apn person who Signs below as a
'GuMntar glwaadesa Me paymilof this coded. This me•M eat H the Beyer falls to wY -Y mcday put b o - aq -m ,
oath pare- hero ag. ties glsaranbr wIH pry h when asked, Each Gu m nbr wig sips below Post M wile he Iie1Ne for ft
whole amount owns awn ii aria or mast oMw mcoa also sips Mb Guaranty. Eeeh Gwrant« elSaapreeS M be liable av- II dsa
SeH- dew ohe or am of dsa tokowirg: (a) II= 1M Buver more MM a pry -e a more eeymanb I (b) gmee a release M IIrH or
in pan b any of the other Geemntors, «(e) mleuwe any Seaacy. Each Guaremor also gates that he has rewired a completed copy
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• R HT TO PARIICIPME AB A CLABB L041E8ENTATVE OR A CLASS MEMBER N ANY CLASS CLAN YOU MAY HAVE
AGAINST US WWMN M COUNT OR IN ARBRRATION
• BROAD RIONTS TO DMCOVERY AS ARE AVALABLE M A U "UIT
• RIGHT TO APPEAL THE DECraION OF AN ARBOIIATOR
• OTHER MOMS THAT ARE AVAILABLE N A LAWSNT
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f tr-r.bnKd I-oc
"'PRN""
Ford Motor Credit Company
P.O. Box 17948
GREENVILLE, SC 29806-8948
(877) 805-7187
P17KWAW20X)22
BRIDGET J. DOUGLAS
79 W MAIN ST
CARLISLE PA 17015
Date of Repossession 08-16-2010
Date of Notice
08-27-2010 Date of Contract
05-17-2008
Account Number: 043875927
Buyer ERIC P. DOUGLAS
Cobuyer BRIDGET J. DOUGLAS
DESCRIPTION OF PROPERTY
Year
2008 Make
FORD ?x New
? Used
Vehicle Identification Number:
1 FAHP35N28W 197398
Model
FOCUS Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
MENNEN
FX7 ?C
PRIVATE SALE: We will sell the property described ? PUBLIC SALE: We will sell the property described above at public
above at private sale sometime after 16 days from the sale to the highest bidder on the date below (or any adjournment
Date of Notice shown above unless redeemed by you date). The sale will be held as follows:
prior to such sale. Date of Safe Time of Sale Place of Sale
You may attend the sale and bring bidders if you want.
NOTICE OF REPOSSESSION
The money that we get from the sale (after paying our costs,
including reasonable attorney's fees and legal expenses if
permitted by law) will reduce the amount you owe. If we get
less money than you owe, you will still owe us the difference. If
we get more money than you owe, you will get the extra money,
unless we must pay it to someone else.
You can get the property back at any time before we sell it by
paying us the full amount you owe (not just the past due
payments), including our expenses. See How To Get Your
Property Back for an itemization of amount owing. To learn the
exact amount you must pay, call us at the telephone number
above.
If you need more information about the sale call us at the
telephone number above, or write us at the address above.
If you want us to explain to you in writing how we have figured
the amount that you owe us, you may call us at the telephone
number above, or write us at the address above and request a
written explanation.
We are sending this notice to the following people who have an
interest in the property described above or who owe money under
your agreement: 1) The buyer and any cobuyer named above;
2) Any dealer/original creditor named below; 3) If there are other
people, they are named on an attachment sent with this notice.
The property is presently stored at: MANHEIM AUTO AUCTION
1190 LANCASTER RD 1190
LANCASTER RD 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 $ 19,826.38
Plus Costs: Repo Expenses $ 200,00
MISC FEE $ 5.00
$
Plus Late Charges $ 149.69
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 20,181.07
(Plus expenses incurred if default at the time of repossession exceeded
16 days and less rebate received after the date of this notice.)
Your property won't be sold until 16 days after the date of this notice at
the EARLIEST. After that you can still get it hack any time before its
actually sold.
If you do, we'll have no further claim on it. But the longer you wad, the
more costs (including repairs) you may have to pay.
If you have any questions about this, please call us.
? The property has been (or will be) returned to:
(dealer/original creditor)
Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money
after the sale, you will pay it to the dealer/original creditor.
? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by
contacting this office. Thereafter, the personal property shall be disposed of accordingly.
? Creditor has assigned to its qualified intermediary (01 Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above
PAYMENTS: All payments to us must be by certified check or money order.
MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer is not accurate for any reason, please contact us so that we
can accurately report the vehicle's mileage.
INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealer/original creditor to make sure that any insurance
has been cancelled. You have a right to get credit for all premium refunds.
KYDIA S. EDWARD
FFNA 11988-37 tan 02 Pu-ous editions may NOT be used. CUSTOMER/CUSTOMER FILE
Printed m U.S.A.
"'PRN-
Ford Motor Credit Company
P.O. Box 17948
GREENVILLE, SC 29606-8948
(877) 805-7187
P17KWAW200019
ERIC P. DOUGLAS
79 W MAIN ST
CARLISLE PA 17015
Date of Repossession 08-16-2010
Date of Notice
08-27-2010 Date of Contract
05-17-2008
Account Number: 043875927
Buyer ERIC P. DOUGLAS
Cobuyer BRIDGET J. DOUGLAS
DESCRIPTION OF PROPERTY
Year
2008 Make
FORD Q New
? Used
Vehicle Identification Number:
1 FAHP35N28W 197398
Model
FOCUS Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
?td
s
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 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.
-? NOTICE OF REPOSSESSION
The money that we get from the sale (after paying our costs,
including reasonable attorney's fees and legal expenses if
permitted by law) will reduce the amount you owe. If we get
less money than you owe, you will still owe us the difference. If
we get more money than you owe, you will get the extra money,
unless we must pay it to someone else.
You can get the property back at any time before we sell it by
paying us the full amount you owe (not just the past due
payments), including our expenses. See How To Get Your
Property Back for an itemization of amount owing. To learn the
exact amount you must pay, call us at the telephone number
above.
If you need more information about the sale call us at the
telephone number above, or write us at the address above
If you want us to explain to you in writing how we have figured
the amount that you owe us, you may call us at the telephone
number above, or write us at the address above and request a
written explanation.
We are sending this notice to the following people who have an
interest in the property described above or who owe money unde
your agreement: 1) The buyer and any cobuyer named above;
2) Any dealer/original creditor named below; 3) If there are other
people, they are named on an attachment sent with this notice.
The property is presently stored at: MANHEIM AUTO AUCTION
1190 LANCASTER RD 1190
LANCASTER RD 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 $ 19,826.38
Plus Costs: Repo Expenses $ 2DO.00
MISC FEE $ 5.00
Plus Late Charges $ 149.69
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 20,181.07
(Plus expenses incurred if default at the time of repossession exceeded
15 days and less rebate received after the date of this notice.)
Your property wont be sold until 15 days after the date of this notice at
the EARLIEST. After that you can still get ft back any time before it's
actually sold.
If you do, we'll have no further claim on it. But the longer you wad, the
more costs (including repairs) you may have to pay.
If you have any questions about this, please call us
? The property has been (or will be) returned to:
(dealer/original creditor)
Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money
after the sale, you will pay it to the dealerloriginal creditor.
? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by
contacting this office. Thereafter, the personal property shall be disposed of accordingly.
? Creditor has assigned to its qualified intermediary (OI Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above
PAYMENTS: All payments to us must be by certified check or money order.
MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer is not accurate for any reason, please contact us so that we
can accurately report the vehicle's mileage.
INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealer/original creditor to make sure that any insurance
has been cancelled. You have a right to get credit for all premium refunds.
KYDIA S. EDWARD
FFNA 11985-37 Jan 02 P-ous ednons may NOT be used. CUSTOMER/CUSTOMER FILE
Pnmed in U.S.A.
13-Oct-2010 12:51 PM Nashville Service Center 6153152809
Ford Motor Credit Company
P.O. Box 17948
Greenville, SC 29606
1-877-805-7187
DATE, October 13, 2010
ERIC P DOUGLAS
79 W MAIN ST
CARLISLE PA 17015
STATEMENT OF SALE
Account Number: 043875927
The following proporty has been sold.
Year Make Model Vehicle Identification Number:
2008 FORD FOCUS 1FAHP35N28W197398
Gross balance owing on your contract (1) $ 19,981.07
Deduct: Finance Charge Rebate. (2) g 0.00
Balance owing prior to sale (3) $ 19,981.07
Deduct: gross proceeds of tho sale (4) $ 9.100.00
Balance less gross proceeds of the sale (3 - 4) (5) $ , 10,881.07
Add: Expenses of retaking and storing, and (6) $ 470.00
any attomeys' fees allowod by law, and
expenses of reconditioning and selling.
Deduct: Insurance Premium Rebate (7) $ 874.90
Other: (a) $ 0.00
(9) $ 10,476.17
DefcicncyYx
Surplus" (10) $ 0.00
The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest
added to your account (debits).
Surplus" or Deficiency"
If the sale resulted in a surplus, a refund for the differenco will be mailed to you.
" If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for
payments shown below.
For additional information call or write: Mail deficiency payment to:
FORD CREDIT NATIONAL RECOVERY CENTER FORD MOTOR CREDIT COMPANY
P.O. BOX 6508 P.O, BOX 55000
MESA, AZ 85216-6508 DEPT 194101
1-800-732-2264 DETROIT, MI 48255 1941
8/9
FFNA119DO 011(14 Pm,%;ous C&ions may NOT be usetl.
13-Oct-2010 12:51 PM Nashville Service Center 6153152809 9/9
Ford Motor Credit Company
P.O. Box 17948
Greenville, SC 29506
1-877-805-7187
DATE: October 13, 2010
BRIDGET J DOUGLAS
79 W MAIN ST
CARLISLE PA 17015
STATEMENT OF SALE
Account Number: 043875927
The following property has been sold.
Year Make Model Vehicle IdenHication Number:
2008 FORD FOCUS 1 FAHP35N28W1 97398
Gross balance owing on your contract (1) $ 19,981.07
Deduct: Finance Charge Rebate (2) $ 0.00
Balance owing prior to sale (3) $ 19,981.07
Deduct: gross proceeds of the sale (4) $ 9,100.00
Balance less gross proceeds of the sate (3 - 4) (5) $ 10,881.07
Add: Expenses of retaking and storing, and (6) $ 470.00
any attorneys' fees allowed by law, and
expensos of reconditioning and selling.
(7) $ 874.90
Deduct: Insurance Premium Rebate
(8) $ 0.00
Othor:
(9) $ 10,476.17
Deficiency'
Surplus" (10) 0.00
The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest
added to your account (debits).
-
Surplus' or IOoflciencyWW +
If the sale resulted in a surplus, a refund for tho difference will be mailed to you.
.W If the sale resulted in a deficiency, you should immediatoly remit the amount shown on lino 9 to the address for
payments shown below.
For additional Information call or write: Mail doficiancy payment to:
FORD CREDIT NATIONAL RECOV>:RY CENTER FORD MOTOR CREDIT COMPANY
P.O. BOX 6508 P.O. BOX 55000
MESA, A7 85216-6508 DEPT 194101
1-800-732-2264 DETROIT, Ml 48255 1941
r-FNAI1990 01104 Proviov5 oftone may NCYr be used.
AUCTION (:UFY
WEIR PENL9YL'WWIA
1190 1 AFTER 'IIOAD
rAKIR PA 17345
(ON) &-M FAX(717) 665-IM
vEAR MAKE MOC
.BID* 1385 ?i 0-860--140049
FAHP35N28N197398
RIES BOGY COLOR-.
O
".T. PS
N fi PB
9830500 r4-Wafts
0/08/2014
]F( jCUS
ANN CONDif
REPO;
RETAIL REPOSSESSION
*46ol d e On, Stfllub:;90t**
NOTESs
I I e IPSI 7 IPSI 141
REEN sSUAR'TEEI s iFULL IFILL f
oR??r E aF as+ Pua? aft saNauaE? ?f?r rc? io wrr 630000000
910256 1'606si
zm=; 1DT(R CREDIT-CO
ICAN RD
'RI 'I '481116
5057231 1 1385
P NEW SRE>ED AUTO 6X8 INC
U 1317 1389 36 ST
R 18ROOA.1fN ' W1, 111118
(718) iW111E3
C
H I&WC BERBER , .
S
E
R X
PRINTED PURCHASERS K" MUYEAI '
1jignature On File
PUROHASERS SIGNATURE MUYER) -
RM"ASER MUST RETURN SIONrEDCOPY OFODOMEI ER DISCLOSURE STATEMENT (FRONT i
SACK OF THE IF MADE ON TRLE) TO TRANSFEROR (SELLER) OR eE tKlB.IECT To CIVIL A
CAW4ALPENAI.TIRA, LNMUDINO FMIIIANDJAIL.TNhMM ISPAdd 1904@C.F.R.aee.a(S.
AUCTION ASSUNU NO RRPONifRJUTIf NOR GUARANTEES
THN ACCURACY OF TM-ODOIiRMII.fU[ADING
DOCUMENT NOT VALID FOR EXPORT
=BCs BA r' 1
? V.
Matih6im
NOT A RECEIPT OF PAYMENT
IDECLINI
PSI i I
tuz
ODOMETER DISCLOSURE STATEMENT Seotlon 580.5 Disclosure form
FEDERAL LAW (AND STATE L.AW, IF APPLICABLE) REQUIRES THAT YOU STATE THE
MILEAGE UPON TRANSFER OF OWNERSHIP, FAILURE TO COMPLETE OR
PROVIDING A FALSE STATEMENT MAY RESULT IN FINES ANOIOR IMPRISONMENT.
? (1) I hereby certify to the best Of my 1nowedge the odometer reading
reflects the amount of mileage In excess of Its mechanical limits.
? (2)•I hereby certlty that the odometer reading Is NOT the actual mileage
-WARNING - ODOMETER DISCREPANCY
FORD 1101 CREDIT COPANYaLLC
STALE TrW THE ODOMETER NOW READS
MILES (NO TENTHS) AND TO THE BEST OF MY
IWOWLEDGE THAT IT REFLECTS THE ACTUAL MILEAGE OF THE VEHICLE
DESCRIBED HEREIN, UNLESS NOTED DIFFERENTLY ABOVE.
For value rseNved I hereby eel. asegn or tram ar Me vehicle desedbW on this docurrmU
to the pumMaer named at left.
X
TRANSFEROR'S, SIGNATURE (SELLER)
XSI'ONATURE ' ON FILE
PRINTED NAME OF(SIGNOR) '
EL 14X
I IF I CLERK= SOLD BY
I 1 MOH I SOR
LICENSE NO.- I TAB
9UYEA PUME CHECK ONE
? CLEAN ? ROUGH 11 AVERAGE
(1) (2) (3)
NOTICE:
• Do not re-purchase or finance
without certificate of title.
• Auction retains security interest in
vehicle until good funds received.
NS
s
ORIGINAL 10/12/2010 Manheim(D
VEHICLE CONDITION REPORT 4910256
MANHEIM PENNSYLVANIA CUSTOMER FORD MOTOR CREDIT COMPANY,LLC
1190 LANCASTER ROAD ACCT. NAME
MANHEIM, PA 17545 ACCT. UNIT NO. 48063000000000000043875927 RTR .
800-822-2886 INSPECTOR DAWNW INSPDATE • 8/30/2010
VIN 1FAHP35N28H197398 2010 60 14 48 ARRIVAL DATE 8/30/2010 tMORKOR0ERN0 160893
SHOCK NO
DESCRIPTION 2008 FORD FOCUS SE 4DSN Hard Top, BLACK w/GRY Cloth
MECHANICAL 2.0 Liter 4 Cylinder Gas, Automatic w O/D, Pwr Brakes, Pwr Steering
MILEAGE 37,363 MI, Digital TM-
RADIO CD Player, Aux - USB Input, CD Changer/FACT-06-Dash, Satellite Radio/SIRIUS
EQUIPMENT Pwr Locks, Pwr Windows, AC, Cruise, Rear Defroster, Tilt Wheel, Air Bags/Dual-Front, Frt Cntr Consol,
Floor Mats, Sec System, St Wh Audio Ctl, Tire Press Mon, Trip Computer, Trip Counter, Alloy Wheels,
Pwr Mirrors, Pwr Trunk/Gate, Two-Wheel Drive, 5 Passenger, 4 Door, Regular Dash, 50 St Emis, Own Manual,
EPA Label, Wtnty Book
Labor Labor Pabst L&W
NON CHARGEABLE (Normal Near & Tear)
CHARGEABLE (Excess Near & Tear)
? Front Bumper Curb Rash 6" to 7" Repair 1.5 3.4 161.70
LFT,RT
? LF Door Dent/No Paint PDR/1 PDR 45.00
? L Qtr Panel Dent/No Paint PDR/1 PDR 45.00
? Deck Lid Dent/No Paint PDR/1 PDR 45.00
? R Bumper Cover Center Scratch Heavy 3" to 4" Partial Repair 80.00
? RR Door Dent/No Paint PDR/1 PDR 45.00
? Gas Missing Replacement Req Replace
Parts 1.00
Labor & Paint 4. 9 Hrs. 241.70
PDR 180.00
CHARGEABLE DAMAGE TOTAL: 422.70
Announced Condition......... REPO;
Consign To..: Financial TOTAL DAMAGE
Color Code..: UA/FW Parts 1.00
Driveable...: Yes Labor& Paint 4.9 Hrs. 241.70
Int. Cond...: Average, OK Odor Mechanical 00
Cert. Cand..: PDR 180.00
Cyberlot....: Ineligible Air Brush .00
Oil Cond....: Fair DAMAGE TOTALS: 422.70
Keys ........: Mst 2 Trk N Spr N Val N Rem N Inf N Cmb N KGo N
Tires .......: LF 5 HANKOOK 195/60RIS LR 6 HANKOOK 195/60R15 Average
RF 4 HANKOOK 195/60R15 RR 5 HANKOOK 195/60R15 SP Mini Spare
Fuel Level..: Empty
Service .....: Scheduled Maint. No Date - Mileaee - Location -
Category Code..: RTR
Part
1.00
Grade 4.2 - Clean (Manheim AutoGrade)
Title Received......: 9/27/2010 Acceptance Date:
Approved By: Date:
Last Updated By: Date:
Detail Fees Not Included. Page 1
2010 060 14 0048 ,1•tHEl,?
SOFT COPY WORK ORDER 160893 10/12/2010 L'TI?
MANHEIM PENNSYLVANIA CUSTOMER FORD MOTOR CREDIT COMPANY,LLC
1190 LANCASTER ROAD 4910256 ONE AMERICAN RD
MANHEIM, PA 17545 DEARBORN, MI 48126
VIN 1FAHP35N28N197398 ARRIVAL DATE 8/30/2010 WORK ORDER 160893
YEAR MAKE MODEL BODY COLOR MILES ENG R TRN PS PS AC EN ES TOP CC EL INT CLR 4X4 TL SRS SI DF
2008 FORD FOCUS SE 4DSN BLACK 037363 4G C 0 X X X X HT X X C GRY X D F X
SOLD 10/08/2010 STOCK# LEASE 48063000000000000043875927 TITLE
DESCRIPTION PARVINV# QTY/HR COST AMOUNT TOTAL
PDR RRDR 0401179092 .00 45.00
TOTAL SUBLET REPAIRS 45.00
VALUE DETAIL 72.50 72.50 72.50
TOTAL APPEARANCE RECONDITIONING 72.50
* NON-DEDUCTIBLE CHARGES
REPO;
SOLD TO: 975603 00
NEW BREED AUTO SALES INC
1317-1329 36 ST
BROOKLYN, NY 11218
INVOICE PRICE 10,000.00
SALE PRICE 91t 9,100.00
SALE FEES 65.00
A/R ANT
RECON TOT 117.50
DLR RECON
CERTIFIED
SALES TAX
PRIME FEE
S33U.CST SAT FEE 30.00
SELLER PROMO FEE
TOTAL EXPENSES 232.50
------
NET SALE PRICE 89% -------
8,867.50
ENTRY # 060 2010 14 0048
CHECK OR DFT # 7433141
PARTS & MATERIAL
LABOR
CR/INSPECTIONS/IMS
SUBLET REPAIRS
MISCELLANEOUS EXPENSE
APPEARANCE RECOaIDITICNING
TITLE FEES
SELLING 6 ADMINISTRATIVE PHBS
ADVANCE CHARGES
TRANSPORTATION
RECON TOTAL 117.50
45.00
i
72.50
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
' 215) 789-7155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 2011-3859 CIVIL
ERIC P DOUGLAS AND BRIDGET J
DOUGLAS "03
Defendant(s) 2" -Orn
N
<? UP
PRAECIPE TO ENTER JUDGMENT .;
?z am
TO THE PROTHONOTARY: .-? cn a
No answer having been filed in the above Civil Action, kindly enter Judgment in favor of
Plaintiff, and against Defendant(s), ERIC P DOUGLAS and BRIDGET J DOUGLAS in the
amount as follows:
Principal Amount $ 10476.17
Interest to Date $ 550.84
Costs $ 142.00
TOTAL $ 11169.01
Date: June 15, 2011
MAURICE & NEEDLEMAN, P.C.
BY:
JOANN EDLEMAN, ESQ.
Attorney for Plaintiff
LA"A 41y6ppa a4?
ca* b69A-7
vuh-a M OAP- ?
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
15) '/?59-'/ 155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
ERIC P DOUGLAS AND BRIDGET J
DOUGLAS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 2011-3859 CIVIL
AFFIDAVIT OF MAIL SERVICE
STATE OF PENNSYLVANIA
SS.
COUNTY OF PHILADELPHIA
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she is an attorney at law and that on 06/01/2011 she mailed a written Notice of
Intention to File the Praecipe to Defendant(s), ERIC P DOUGLAS, at 79 W MAIN ST ,
CARLISLE, PA 17015 and BRIDGET J DOUGLAS, at 79 W MAIN ST CARLISLE, PA 17015 by
regular mail.
J04NN
mey for Plaintiff
SWORN TO AND SUBSCRIBED
before me this2D y
O1)
otary Public NOTARIAL SEAL
RASHETTA ROBINSON
Notary Public
PHILADELPHIA CITY, PHILADELPHIA COUNTY
My Commission Expires Mar 23, 2015
MAURICE & NEEDLEMAN, P.C.
BY:
NEEDLEMAN, ESQ
A me for Plaintiff
..a .?_,
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
/89-'/ 1 S5
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
ERIC P DOUGLAS AND BRIDGET J
DOUGLAS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 2011-3859 CIVIL
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on
06/01/2011 to Defendant(s), ERIC P DOUGLAS and BRIDGET J DOUGLAS, 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 06/01/2011, a copy of the mailing to the
Defendant and affidavits of service are all attached hereto.
MAURICE & EDLEMAN, P.C.
t
BY: -
JO NEEDLEMAN, ESQ.
Attorney for Plaintiff
Date: June 15, 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
(L15) "ItSy-"7155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
ERIC P DOUGLAS AND BRIDGET J
DOUGLAS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 2011-3859 CIVIL
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): ERIC P DOUGLAS,
79 W MAIN ST,
CARLISLE, PA 17015
BRIDGET J DOUGLAS
79 W MAIN ST,
CARLISLE, PA 17015
MAURICE & NIPEDLEMAN, P.C.
BY:
JOANN NEEDLEMAN, ESQ.
Attorney for Plaintiff
Date: June 15, 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
/z59--/ 15J
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
ERIC P DOUGLAS AND BRIDGET J
DOUGLAS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 2011-3859 CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
COUNTY OF PHILADELPHIA
SS.
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she represents the Plaintiff in the above entitled case and that Defendant(s), ERIC P
DOUGLAS and BRIDGET J DOUGLAS, 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.
SWORN TO AN?DaUBSCRIBED
before me this ZM-ay
O1(`
otary ?Pub?lic?
M
AURICE & NEEDLEMAN, P.C.
BY:
JOANN T?WLEMAN, ESQ.
Attorney fo laintiff
NOTARIAL SEAL
RASHETTA ROBINSON
Notary Public
PHILADELPHIA CITY. PHILADELPHIA COUNTY
My Commission Expires Mar 23, 2015
ili;? olri
Attorneys at Law
jibe 935, One Penn Center
117 John F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.665.1133
fax 215.563.6970
www.mnlawpc.com
Donald S. Maurice
Member NJ Bar
Board Certified
Creditors' Rights Law
rican Board of Certification
Joann Needleman
Member PA & NJ Bar
Thomas R. Dominczyk
Member NJ, NY & PA Bar
Rachel Mahn
Member NY & NJ Bars
New Jersey Office
Maurice & Needleman, P.C.
suite 2007
5 Walker E. Foran Blvd.
Flemington, NJ 08822
tel. 908.237.4550
tax 906.237.4551
June 1, 2011
ERIC P DOUGLAS
79 W MAIN ST
CARLISLE, PA 17015
RE: FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY v. ERIC P DOUGLAS AND
BRIDGET J DOUGLAS
CUMBERLAND COUNTY COURT OF
COMMON PLEAS, CASE NO. 2011-3859
CIVIL
Dear Mr/Mrs/Ms DOUGLAS:
Our File No. 15386
Enclosed please find a ten (1.0) day notice of default which is self-
explanatory. This is being served upon you due to your failure to respond to
Plaintiffs Complaint served upon you on May 3, 2011 . Unless an answer to
Plaintiffs Complaint is filed. with the Court within ten (10) days from the date of
this notice, a default judgment maybe 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,
"IrICE & NEEDLEMAN, P.C.
f
Jo' Needleman, Esq.
JN/dlh
Enc
THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A
DEBT, AND ANY INFORMATION OBTAINED WILL BE USED
FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
1J) /759-11JJ
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
ERIC P DOUGLAS AND BRIDGET J
DOUGLAS
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 2011-3859 CIVIL
IMPORTANT NOTICE
TO: ERIC P DOUGLAS DATE: June 1, 2011
79 W MAIN ST
CARLISLE, PA 17015
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS
FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE;
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
MA &. NEEDLEMAN, P.C.
BY
JOANN EDLEMAN, ESQUIRE
Attorney or Plaintiff
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Attorneys at Law
Suite 935, One Penn Center
1617 John F. Kennedy Blvd.
Phiiadellohia, PA 19103
tel. 215.665.1133
fax 215.563.6970
www.mnlawpc.com
Donald S. Maurice
Member NJ Bar
Board Certified
Creditors' Rights law
,merican Board of Certification
Joann Needleman
Member PA & NJ Bar
Thomas R. Dominczyk
Member NJ. NY & PA Bar
Rachel Marin
Member NY & NJ Bars
New Jersey Office
Maurice & Needleman, P.C.
Suite 2007
5 Walter E. Foran Blvd.
Flemington, NJ 08622
tel. 908237.4550
tax 906237.4551
June 1, 2011
BRIDGET J DOUGLAS
79 W MAIN ST
CARLISLE, PA 17015
RE: FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY v. ERIC P DOUGLAS AND
BRIDGET J DOUGLAS
CUMBERLAND COUNTY COURT OF
COMMON PLEAS, CASE NO. 2011-3859
CIVIL
Dear Mr/Mrs/Ms DOUGLAS:
Our File No. 15386
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 May 3, 2011. 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.
Joann edleman, Esq.
JN/dlh
Enc.
THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A
DEBT, AND ANY INFORMATION OBTAINED WILL BE USED
FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7155
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
v.
ERIC P DOUGLAS AND BRIDGET J
DOUGLAS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO.2011-3859 CIVIL
IMPORTANT NOTICE
TO: BRIDGET J DOUGLAS DATE: June 1, 2011
79 W MAIN ST
CARLISLE, PA 17015
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
(71.7)249-31.66
MA C & NEEDLEMAN, P.C.
BY
JOANN EDLEMAN, ESQ
Attorney for Plaintiff
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ?--?
Sheriff
Jody S Smith ??a?rn of ?reon3?r?fi?
Chief Deputy }
T . Y.
Richard W Stewart
Solicitor 4 MC4 OF ViB VI;:F
Ford Motor Credit Company
VS. Case Number
Eric P. Douglas (et al.) 2011-3859
SHERIFF'S RETURN OF SERVICE
05/03/2011 07:39 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on May 3,
2011 at 1939 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Bridget J. Douglas, by making known unto Eric P. Douglas, H and of Defendant at 79
W. Main Street, Carlisle, Cumberland County, Pennsylvania 17015 its nten an at the same time
handing to him personally the said true and correct copy of the same. M ^
SON,DEPUTY
05/03/2011 07:39 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on May 3,
2011 at 1939 hours, he served a true copy of the within Complaint and Notice, up the within named
defendant, to wit: Eric P. Douglas, by making known unto himself personally, at W. Main Street,
Carlisle, Cumberland County, Pennsylvania 17015 its contents and at t ?sam tirr a handing to him
personally the said true and correct copy of the same.
DEPUTY
SHERIFF COST: $50.00
May 04, 2011
SO ANSWERS,
4z X?4?
?---?
RON R ANDERSON, SHERIFF
icj CountySWie Sherri. 7Heosoft. Inc.
Request for Military Status
Department of Defense Manpower Data Center
40 Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Mar-07-2011 08:40:52
Last
FirstlMiddle
Begin Date
Active Duty Status
Active Duty End Date Service
S
Name Agency
DOUGLAS ERIC Based on the information you have furnished, the DMDC does not possess
any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
14. Il$jd4, -
Aakk lot flW?_
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://urww.defenselink.mit,fag/pis/PC09SLDR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.mil/appj/scra/popreport.do 3/7/2011
Request for Military Status
Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:EEFV319ADS
https://www.dmdc.osd.mil/appj/scra/popreport.do 3/7/2011
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Mar-07-2011 08:44:38
?.. Last
First/Middle
Begin Date
Active Duty Status
Active Duty End Date Service
S
Name Agency
DOUGLAS BRIDGET Based on the information you have furnished, the DMDC does not possess
any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
rte r? ,?.,?,_a?.
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://",ww.defenselink.mil/fag/pis./PC09SLDR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.mil/appj/scra/popreport.do 3/7/2011
Request for Military Status
Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be. inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:67VG93GRR5
https://www.dmde.osd.mil/appj/scra/popreport.do 3/7/2011