HomeMy WebLinkAbout11-3864ARBITRATION 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. 15424
15) /69-/155
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
LISA A BONAFEDE
5315 Winthrop Ave
Mechanicsburg, Pa 17050-7369
Defendant(s).
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No.
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NOTICE
You have been sued in court. If you wish to defend
against the claims set forth in the following pages,
you must take action within twenty (20) days after
this complaint and notice are served, by entering
a written appearance personally or by attorney and
filing in writing with the court your defenses or
objections to the claims set forth against you.
l'ou are warned that if you fail to do so the case
may proceed without you and a judgment may be
entered against you by the court without further
notice for any money claimed in the complaint or
for any other claim or relief requested by the
plaintiff. You may lose money or property or
other rights important to you.
CIVIL ACTION COMPLAINT
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demands y la
notificacion. Hace falta asentar una comparencia escrita o en
persona o can un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se defiende, Is corte tomara medidas y
puede continuer la demands en contra suya sin previo aviso o
notificacion. Adernas, la corte puede decidir a favor del demandante
y requiere que usted cumpla con todas las provisions de esta demands.
Usted puede perder dinero o sus propiedades u otros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO O LLAME POR TELEFONO A LA 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, /S
Carlisle, PA 17013 C
(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
(11 J) /259-/1JJ
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
LISA A BONAFEDE
5315 Winthrop Ave
Mechanicsburg, Pa 17050-7369
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, Lisa A Bonafede, is an individual who resides at 5315 Winthrop Ave
Mechanicsburg, Pa 17050-7369.
3. At all times relevant, the Plaintiff was in the business of loaning money on motor
vehicle installment sales contracts, including but not limited to the note signed by Defendant(s),
hereinafter more fully described.
4. On or about January 25, 2006, the Defendant(s) entered into a written Motor
Vehicle Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of
obtaining financing in the amount of $35053.44 at an annual percentage rate of 13.250%, in
order to purchase a certain motor vehicle, 2005 Ford Explorer more particularly described in the
Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and
marked as Exhibit A.
5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in
the amount of $712.15 for a period of 72 months until the loan was paid in full all as is more
fully set forth in the Contract.
6. Defendant(s) made monthly payments until July 13, 2010, but has failed to make
any further payments thereafter, and are therefore in default of the Contract.
7. As a result of the default by Defendant(s), and pursuant to the terms of the
Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to
the Defendant(s) giving the Defendant(s) the opportunity to redeem the Vehicle as well as notice
of the sale date. A copy of the notice of repossession and notice of sale date are attached and
marked as Exhibit B.
8. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at
auction with a credit given to the Defendant in the amount of $8900.00, however a balance of
$11648.95 is still due and owing, and a notice of the deficiency balance was sent to the
Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C.
9. Pursuant to the terms of the contract, Defendant is required to pay all amounts due
and owing, including any balance that may remain after the sale of the vehicle, and the
Defendant failed to do so, thereby in default of the Contract.
10. In addition to the foregoing, there is interest due and owing on the deficiency
balance which at this time amounts to $152.23 and which will continue to accrue.
11. The total amount due and owing at the time of the filing of this complaint is
$11801.18.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $11801.18, 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.
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JOAN"PtDLEMAN, ESQUIRE
Attorney or 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:
JOANN NEED EMAN, ESQUIRE
DATED: April 14, 2011
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Ford Motor Credit Company
P.O. Box 17948
GREENVILLE, SC 29606-8948
(877) 805-7187
P17RAT00200008
LISA A. BONAFEDE
5315 WINTHROP AVE
MECHANICSBURG PA 17050-7369
Date of Repossession 08-31-2010
Date of Notice
09-01-2010 Date of Contract
01-25-2006
Account Number: 040179676
Buyer LISA A. BONAFEDE
Cobuyer
DESCRIPTION OF PROPERTY
Year
2005 Make
FORD Q New
? Used
Vehicle Identification Number:
1FMZU73WB5UA25857
Model
EXPLR Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
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x? 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,
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 ROAD 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 $ 20,132.21
Plus Costs: Repo Expenses $ 22000
$
$
Plus Late Charges $ 4.24
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 20,356.45
(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 16 days after the date of this notice at
the EARLIEST. After that you can still get it 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 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.
M NIROSHA
FFNA 11988-37 Jan G2 Precious editions may NOT be used. CUSTOMER/CUSTOMER FILE
Printed in U.S.A.
Ford Motor Credit Company
P.O. Box 17948
Greenville, SC 29808
1-877-805-7187
DATE: October 27, 2010
LISA A BONAFEDE
5315 WINTHROP AVE
MECHANICSBURG PA 17050 7389
STATEMENT OF SALE
Account Number. 040179876
The folkwing property has been Wd.
Year Make Model
2005 FORD EXPLR
Gross balance awing on your contract
Deduct: Finance Charge Rebate
Balance awing prior to sate
Deduct: gross proceeds of the sale
Balance less gross proceeds of the sale (3 - 4)
Add: Expenses of retaK)ng and storing, and
any attorneys' fees allowed by law, and
expenses of reconditioning and selling.
Deduct: Inwmnoe Premium Rebate
Other:
Vehicle Identtfication Number.
1 FMZU73W85UA25857
(2) $ 0.00
(4) $ 8,900.00
(1) $ 20,138.45
(3) $ 20,138.45
(5) $ 11,236.45
(6) $ 4`12.50
(7) $ 0.00
(8) $ 0.00
Deficiency'" (9) $ 11,648.95
Surplus" (10) $ 0.00
The Surpka/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 dWerence WIN be malled 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: Mall daflcleney payment to:
FORD CREDIT NATIONAL RECOVERY CENTER FORD MOTOR CREDIT COMPANY
P.O. BOX 6508 P.O. BOX 55000
MESA, AZ 65216-0508 DEPT 194101
1-800-732-2284 DETROIT, MI 482551941
FFMI19M 01`104 PmiwAeaWm may NoTbe twW.
L114 808Z91£919 Pjod Wd 89:10 010ZILZ/01
KEY SALE DATE FNTRY MO.
AUCTION COPY BID* 1555 E010-063-140314 11e44:41 14-0314
NA KIN 1118NIM-yo IA CHONO 10/22/2010
1190 LAN CNM ROAD
NANIEIN' PA 17315
(800) 8 6 FAX(717) 665-9%5 MMIZU73M85UA2585,7. .MI..- . 10/1.5/,20.10„ .,.,
D X 5691345
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YEAR MAKE MODEOSUB•SERIES ar '''BODYI' 1' ' :='GOL'OR''1' fN(} ?'INT ' INT R' PS Pl3 AC ES TOP` CC EL' 4X TL $RS' SI RD
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2005 FORD • ; EXPORR " - -,- .- +•A :Ott 'uC. 1. , i•. ' ,, i::, . x , , :, ,
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REPO MNRF 4X4` RA%C; 3RD ST
*REAh DIU. NbISE AS IS
RETAIL REPOBSESSION
kED fl AS'.I8 ' .1 YELLOW:CAUTION I PSI. 7 I PSI' 14:1'-'-- IDECL IN I I IF' ICLERK I SOLID BY
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ME AMERICAN RD BUYER PLEASE CHECK ONE -
,,;NI,. 481PA ? CLEAN ? ROUGH ? AVERAGE
50E M5 1 1555 (1) (2) (3)
P TMITCiER'AUM SAL® ,
em - ITALY RD
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567,
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R EXPOIIT PA 1563@ ] ',i Do not re-purchase,or.?nance;,,
(7E4i) X8'/-8433
Without certificate of title...
H ROBERT TWITOR • Auction retalnweecuft'interest In
vehicle IS
untiPgood funds recehred.
ODOMETER DISCLOSURE STATEMENT Section 650.5 Disclosure
form '
S ,. FEDERAL LAW (AND STATE LAY!. IF.,APPLICAem REQUIRES THAT-YOU SATE THE
MLEAGE UPON TRANSFER OF OWNERSHIP, FAILURE, TO COMPLETE OR
E PROVII) OA FALSE STATEMENTMAYRESULT INFINESANDAORIMPRISONMENL
'
X ? (1) I hereby airy to=ffie best Of my knowledge the odometer reacong
R reflects the amount of mi eage In excess of lie medwical limits SELL I N6' '
PRINTED PURCHASE" NAME (9UYE01) .. .
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-WARNING - ODOMETER DISCREPANCY
RWMWERBSIONgUAS(11MR) •'
PURCHASER MUSTRMANSONEDCOPY OF000MEM DISCLOSURE SUTEMEWJFRONTa r +;
1.. .i .... ., -
BACK OF TITLE F MADE ON ME) To TRANSFEROR ( RLM OR eE SUaIECT TO Cw •
cFR.Aa
CwMwALPENUa>Ea,?rcLUOragnEtAND wL nuaRMw.aAaa»a;wsl?. 1
I
FORD WO CRE'DIT, CQIF!Ai(Y,LLC - .
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AUCTION ASSUMES NO M8PONSId1LITY NOR GUARANTEES SM THAT THE ODOMETER NOW'READS
THE ACCURACY OF THE ODOMETER
EADING MtES 00 TEN I- S) AND TO THE BM of: MY --
R
. 512676
1lOC-f MENT NOT VALID FOR EXPORT KNOWLEDGE THAT IT REFLECTS THE ACTUAL MILEAGE OF THE VEHICLE _,.
F S DESCRIBED HEREIN, UNLESS NOTED DIFFERENTLY ABOVE.
sell, assign or Iranslsr Me vSNde dwabo on M dowmerd BE
to
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ORIGINAL 10/25/2010 MVEHICLE CONDITION REPORT 4910256
MANHEIM PENNSYLVANIA CUSTOMER FORD MOTOR CREDIT COMPANY, LLC
1190 LANCASTER ROAD ACCT. NAME
HANHEIM, PA 17545 ACCT. UNIT NO. 48063000000000000040179876 RTR
800-822-2886 INSPECTOR DAWNW INSP DATE . 8/31/2010
VIN 1FMZU73W85UA25857 2010 63 14 '314 ARRIVAL DATE 8/31/2010 WORK ORDERNO ' 160986
STOCK NO
DESCRIPTION 2005 FORD EXPLORER 4X4 XLT 4SUV 4x4 Moon Roof, RED w/R/G Cloth
MECHANICAL 4.6 Liter 8 Cylinder Gas, Automatic w O/D, Pwr Brakes, Pwr Steering
MILEAGE 1 52,676 MI, Digital, OCT0608PUL TM-
RADIO CD Player, CD Changer/FACT-06-Dash
EQUIPMENT Pwr Locks, Pwr Windows, Pwr Seats - Drivers Only, AC, Cruise, Rear Defroster, Tilt Wheel, Air Bags/Dual,
MMR 10,400 ABS Brakes, Frt Cntr Consol, Floor Mats, Sec System, Tire Press Mon, Traction Ctrl, Trip Computer,
Trip Counter, Alloy Wheels, Fog Lamps, Heated Mirrors, Keyless Entry, Luggage Rack, Pwr Mirrors,
Rear Wiper, Tinted Windows, Rear A/C, 7 Passenger, Third Seat, 4 Door, Rear Tail/Lift, Running Board,
Trailering Pckg, Regular Dash, 50 St £mis, Own Manual, EPA Label, Wmty Book
Part DescryJan
e T Labor Labor
sew* operadon Hours Paint
Hours Labor Part
Fees Costs
NON CHARGEABLE (Normal Wear & Tear)
? Front Bumper Prev Touchup Repair Required Included
? Front Bumper Prev Repair Acceptable No Action Requ
D LF Fender Dent/Paint Ding 3" to 4" Included
? LR Door Prev Repair Acceptable No Action Requ
? Rear Bumper Prev Repair Acceptable No Action Requ
? RF Fender Prey Repair Acceptable No Action Requ
? RF Door Mult Scratches 5 Included
CHARGEABLE (Excess Wear & Tear)
? Front Bumper Mult Dents/Pai 3 Repair 5.0 2.9 260.70
? Hood Prev Repair Substd Repair Repair 1.0 3.4 145.20
? LF Fender Prev Repair Substd Repair Repair 5.0 3.1 267.30
? LF Door Prev Repair Substd Repair Repair 3.5 3.0 214.50
? L Qtr Panel Prey Repair Substd Repair Repair 1.0 3.4 145.20
? Rear Bumper Mult Scratches 7 Refinish 2.2 72.60
? RF Fender Mult Dents/Pai 2 Repair 2.0 3.1 168.30
? RF Door Dent/Paint Dmg 3" to 4" Repair 1.0 3.0 132.00
? RR Door Mult Dents/Pai 2 Repair 2.0 2.8 158.40
? R Qtr Panel Dent/Paint Dmg 2" to 3" Repair 2.0 3.4 178.20
? Gas Missing Replacement Req Replace 1.00
Parts 1.00
Labor& Paint 52.8 Hrs. 1,742.40
CHARGEABLE DAMAGE TOTAL: 1,743.40
Announced Condition........: REPO;MNRF;4X4•RA/C;3RD ST
Notes to Consignor .........: *REAR DIFF. NOISE AS IS
Consign To.. : Financial TOTAL DAMAGE
Color Code.. : G2/7M Parts 1.00
Driveable. . . : Yes Labor & Paint 52.8 His. 1,742.40
Int. Cond... : Average, OK Odor Mechanical .00
Cert. Cared.. : PDR .00
Cxberlot .... : ineligible Air Brush .00
Oil Cond.... : DAMAGE TOTALS: 1,743.40
Keys ........ : Mst 2 Trk N Spr N Val N Rem 2 Inf N Cmb N KGo N
Tires ....... : LF 10 YOKOHAMA 245165RI7 LR 10 GENERIC 245/65RI7 Good
RF 10 YOKOHAMA 245/65R17 RR10 GENERIC 245/65RI7 SP 11 GENERIC 245/65R17
Fuel Level..:Emp
S ice ch le Maint. o Date - Mileage - Location -
'rade 21-
low Average (Manheim AutoGrade)
Category Cod f
e..: T
Title Received......: 10/15/2010 Acceptance Date:
Approved By: Date:
Last Updated By: Date:
Detail Fes Not Included. Page 1
2010 063 14 0314
fSl ??? CIS
SOFT COPY WORK ORDER 160986 10/25/2010 9°oTI
MAMMIM PENNSYLVANIA CUSTOMER FORD MOTOR CREDIT COMPANY,LLC
1190 LANCASTER ROAD 4910256 ONE'AMERICAN RD
MANHEIM, PA 17545 DEARBORN, MI 48126
VIN 1FMZU73W85UA25857 ARRIVAL DATE 8/31/2010 WORK ORDER 160986
YEAR MAKE MODEL BODY COLOR MILES ENG R. TRW PS PB AC EW ES TOP CC EL INT CLR 4X4 TL SRS SI DF
2005 FORD EXPLORER 4X4 XLT 4SUV RED 052676 8G C O X X X X D MR X X C R/G X X D X
SOLD 10/22/2010 STOCK# LEASE 48063000000000000040179876 TITLE
DESCRIPTION PARTIINV# 07Y1HR COST AMOUNT TOTAL
VALUE DETAIL 72.50 72.50 72.50
TOTAL APPEARANCE RECONDITIONING 72.50
* NON-DEDUCTIBLE CHARGES
REPO;MNRF;4X4;RA/C;3RD ST
SOLD TO: 978205 00
THATCHER AUTO SALES
2903 ITALY RD PO BOX 567
EXPORT, PA 15632
INVOICE PRICE 11,950.00
SALE PRICE 70 8,900.00
SALE FEES 85.00
A/R All
REC044 TOT 72.50
DLR RECON
CERTIFIED
SALES TAX
PRIME FEE
SINLCST SAT FEE
SELLER PROMO FEE
TOTAL EXPENSES 157.50
NET SALE PRICE
73% _
--_8,742.50
ENTRY # 063 2010 14 0314
CHECK OR DFT # 7437612
PARTS 6 MATERIAL
LABOR
CR/INSPECTIOHS/INS
SUBLET REPAIRS
MISCELLANEOUS EXPENSE
APPEARANCE RECONDITIONING 72.50
TITLE FEES
SELLING & ADMINISTRATIVE PEES
ADVANCE CHARGES
TRANSPORTATION
RECON TOTAL 72.50
f
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
(21J) /69-/151
FORD MOTOR CREDIT COMPANY, A CUMBERLAND COUNTY COURT OF
DELAWARE LIMITED LIABILITY COMMON PLEAS
COMPANY C-,
Plaintiff CASE NO. 11-3864 CIVIL
rn
LISA A BONAFEDE Cc?
Defendant(s) =o
.5, C
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
G.
a
C:lr-
No answer having been filed in the above Civil Action, kindly enter Judgment in favor of
Plaintiff, and against Defendant, LISA A BONAFEDE in the amount as follows:
Principal Amount
Interest to Date
Costs
$ 11648.95
$ 444.02
$ 130.44
TOTAL
$ 12223.41
LEMAN, P.C.
BY:
JOANN NEEDLEMAN, ESQ.
Attorney for Plaintiff
Date: June 22, 2011
QAA $ 1y. oo P4 a
7
?6 (2- 33s
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. 15424
(115) /6y-/151
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
LISA A BONAFEDE
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 11-3864 CIVIL
(X) Notice is hereby given that a judgment in the above-captioned matter has
been entered against you in the amount of $12223.41 on ::7 ) S /1 /
(X) A copy of all documents fil the Prothonotary in suof the
within judgment is enclose)-'with
ro erk
by:
If you have any questions regarding this matter, please contact the filing party:
Name: Joann Needleman, Esquire
Address: Suite 935, One Penn Center at Suburban Station
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Telephone No.: 215-789-7155
(This Notice is given in accordance with Pa.R.C.P. §236)
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
1J) /89-/151
FORD MOTOR CREDIT COMPANY, A I CUMBERLAND COUNTY COURT OF
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
LISA A BONAFEDE
Defendant(s)
COMMON PLEAS
CASE NO. 11-3864 CIVIL
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 6/10/2011 she mailed a written Notice of
Intention to File the Praecipe to Defendant, LISA A BONAFEDE , at 5315 WINTHROP AVE,
MECHANICSBURG, PA 17050-7369 by regular mail.
MAURI & DLEMAN, P.C.
BY:
ANN NEEDLEMAN, ES
Q.
.
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED
before me this y
2011. '
Notary Public
NOTARIAL SEAL
JRASHETTA ROBINSON
Notary Public
PHILADELPHIA CITY, PHILADELPHIA COUNTY
My Commission Expires Mar 23 7015
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
(2.1?) /89-/iM
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
LISA A BONAFEDE
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 11-3864 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
6/10/2011 to Defendant, LISA A BONAFEDE , 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 6/10/2011, a copy of the mailing to the Defendant and affidavits of
service are all attached hereto.
MAURICE DLEMAN. P.C.
BY:
J ANN NEEDLEMAN, ESQ.
Attorney for Plaintiff
Date: June 22, 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
(L1-) /z59-71-1
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
LISA A BONAFEDE
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 11-3864 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: LISA A BONAFEDE,
5315 WINTHROP AVE,
MECHANICSBURG, PA 17050-7369
MAURI & N DLEMAN. P.C.
BY:
J NEEDLEMAN,
Attorney for Plaintiff
Date: June 22, 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
15) 789-7151
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
v.
LISA A BONAFEDE
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 11-3864 CIVIL
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, LISA A
BONAFEDE , is over 18 years of age; the occupation of Defendant is unknown and to the best
of Plaintiffs knowledge, information and belief, Defendant is not in the military service of the
United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and
Sailors' Civil Relief Act of 1940 and the amendments thereto.
MAURICE E LEMAN, P.C.
BY:
JO NEEDLEMAN, ESQ.
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED
bef me thisay
201 °
NOTARIAL SEAL
ot ?ar ub licRASHETTA ROBINSON
yP Notary Public
PHILADELPHIA CITY, PHILADELPHIA COUNTY
My Commission Expires Mar 23, 2015
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(zt?)) izsy-/ I:)I
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
V.
LISA A BONAFEDE
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 11-3864 CIVIL
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, LISA A
BONAFEDE , is over 18 years of age; the occupation of Defendant is unknown and to the best
of Plaintiffs knowledge, information and belief, Defendant is not in the military service of the
United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and
Sailors' Civil Relief Act of 1940 and the amendments thereto.
MAURICE E LEMAN, P.C.
BY:
JO NEEDLEMAN, ESQ.
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED
bef me thJMy
0 2011. NOTARIAL SEAL
C- RASHETTA ROBINSON
oNotary Public
PHILADELPHIA CITY, PHILADELPHIA COUNtY
My Commission Expires Mar 23, 2015
Attorneys at Law
jite 935, One Penn Center
117 John F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.665.1133
fax 215.563.8970
www.mniawpc.com
Donald S. Maurice
Member NJ Bar
Board Certified
Creditors' Rights Law
Titan 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
vUunce & Needleman, P.C.
Suite 2007
5 Waiter E. Foran Blvd.
Flemington, NJ 08822
tel. 908.237.4550
fax 906237.4551
June 10, 2011
LISA A BONAFEDE
5315 WINTHROP AVE
MECHANICSBURG, PA 17050-7369
Our File No. 15424
RE* FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY v. LISA A BONAFEDE
CUMBERLAND COUNTY COURT OF
COMMON PLEAS, CASE NO. 1.13864 CIVIL
Dear Mr/Mrs/Ms BONAFEDE:
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 5, 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 Nei -man, Esq.
JN/dlh
Eric
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
f6v- l1DD
FORD MOTOR CREDIT COMPANY, A
DELAWARE LIMITED LIABILITY
COMPANY
Plaintiff
z?.
LISA A BONAFEDE
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 11-3864 CIVIL
IMPORTANT NOTICE
TO: LISA A BONAFEDE DATE: June 10, 2011
5315 WINTHROP AVE
MECHANICSBURG, PA 17050-7369
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR. BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS
FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER. AT ONCE. IF YOU DO NOT HAVE A
LAWYER. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A. LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
MAURICE &, NEEDLEMAN, P.C.
BY «.
JOANN NEDLEMAN, ESQUIRE
Attornev O'Plaintiff
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Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1_ of 2
Mar-10-2011 08:36:22
Last
First/Middle
Begin Date
Active Duty Status
Active Duty End Date Service
Agency
Name
Based on the information you have furnished, the DMDC does not possess
BONAFEDE LISA 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
y6t Pf- 4&0?_
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 ht?t?www defenselink.mil%fzid/pisiPC 09SLDR.htm1. 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 3/10/2011
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:827AFKT9DF
https://www.dmdc.osd.mil/appj)'scra/popreport.do 3/10/2011
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriffq?,?tr a;un,ifrfr
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor F Tlia- sK?`FF
Ford Motor Credit Company
vs.
Lisa A. Bonafede
Case Number
2011-3864
SHERIFF'S RETURN OF SERVICE
05105/2011 05:36 PM - Noah Cline, Deputy Sheriff, who being duly swom according to law, states that on May 5, 2011
at 1736 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Lisa A. Bonafede, by making known unto herself personally, at 5315 Winthrop Avenue,
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
her personally the said true and correct copy of the same.
SHERIFF COST: $38.44
May 06, 2011
NOAH CLINE, DEPUTY
SO ANSWERS,
RbNl`V R ANDERSON, SHERIFF
%C) Gcunlpsk:o Sher ' 1eieoso`l, Inc
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FORD MOTOR CREDIT COMPANY : No. 11-3864 CIVIL
Plaintiff y�
•
vs. C/7°` N
LISA A BONAFEDE :CIVIL ACTION C-
Defendant c=
•
•
• 'r
PRAECIPE FOR SUBSTITUTION OF COUNSEL
TO THE PROTHONOTARY:
Kindly substitute Lloyd S. Markind, Esquire of the law offices of Sklar,., Markind, 102
Browning Lane, Building B, Ste 1, Cherry Hill,New Jersey 08003 as counsel for the Plaintiff in
the above entitled matter. The undersigned hereby consents to this substitution.
/ \\O-CA/Y‘rt,
•
Lloyd S. Markind,'' squire (ID # 52507) Joann Needleman, Esquire*
Amy F. Doyle, Esquire (ID #87062) Withdrawing attorney
Superseding Attorney Maurice &Needleman, P.C.
Sklar-- Markind 935 One Penn Center
102 Browning Lane, Bldg B, Ste 1 Philadelphia, PA 19103
Cherry Hill, NJ 08003 ID#74276
Dated: June 25, 2013 Dated: June 25, 2013
* Signed with permission of Joann Needleman, Esq.
FILE NO.: FT116436