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HomeMy WebLinkAbout12-4478T - FILED-OFFICE SKLAR-MARKIND OF THE PROTHONOTARY Andrew Sklar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID #52507) 2012 JUL 19 AM 11: 01 102 Browning Lane Building B, Suite 1 CUMBERLAND COUNTY Cherry Hill, NJ 08003 PENNSYLVANIA File No.: F1100760 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY LLC Plaintiff vs. LEANN N KRIMM and CHRISTOPHER M KRIMM Defendant No. 19 - qL/,? Ovit TERM CIVIL ACTION NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you mu 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 a& you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND O WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: 717-249-3166 AVISO Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientas, usted tiene veinte (2) dias de plazo al partir de la fecha de la demanda y la notificaion. Hace falta ase ar una comparencia escrita o en persona o con 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, la corte tomara med' as y puede continuar la demanda en contra sya sin previo aviso o notificaion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL A LA OFICINA CUY A DIRECION SE ENCUENTRA ESCRITA ABAJO PARA AVERGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: 717-249-3166 6) } tIo3 .7 pj aLw G'a- 139 Andrew Sklar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID #52507) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: F1100760 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY LLC I 1335 S. Clearview Avenue I No. Mesa, AZ 85209 Term I Plaintiff(s) ! I CIVIL ACTION I V. I LEANN N KRIMM and CHRISTOPHER M ! KRIMM { i Defendant(s) CIVIL ACTION COMPLAINT 1. Plaintiff, FORD MOTOR CREDIT COMPANY LLC , is a Corporation with its place of business at 1335 S. Clearview Avenue Mesa, AZ 85209. 2. Defendant, LEANN N KRIMM, is an individual who resides at 5304 OXFORD DRIVE APT. 89, MECHANICSBURG PA 17055. Defendant, CHRISTOPHER M KRIMM, is an individual who resides at 5304 OXFORD DR. APT. 89, MECHANICSBURG PA 17055. 3. At all times relevant hereto, 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 (the Contract as hereafter defined). 4. On or about August 25, 2007, the Defendant(s) entered into a written Motor Vehicle Retail Installment Contract, Account Number 48063000000042936719, (hereinafter referred to as the r "Contract"), for the purpose of obtaining financing in the amount of $29,443,49 at an annual percentage rate of 5.9%, in order to purchase a certain motor vehicle, 2007 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 $487,72 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 March 7, 2011, 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(s) in the amount of $12,000.00, however a balance of $6,791.01 is still due and owing, and a notice of the deficiency balance was sent to the Defendant(s). See copy of the notice of the deficiency balance attached and marked as Exhibit C. 9. Pursuant to the terms of the contract, Defendant(s) is required to pay all amounts due and owing, including any balance that may remain after the sale of the vehicle, and the Defendant(s) 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 $463.79 and which will continue to accrue. 11. In addition to the foregoing, there is due from the Defendant(s), reasonable attorneys fees in the amount of $1,697.75. 12. The total amount due and owing at the date of this complaint is $8,952.55. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), jointly and severally, if more than one, in the amount of $8,952,55, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. SKL Date: March 22, 2012 rew S Mar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID #52507) Attorneys for Plaintiff 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 VERIFICATION I, Victoria MJ^Ker+hrge , verify that am an Authorized Representative for the Plaintiff, FORD MOTOR CREDIT COMPANY LLC , and are duly authorized to take this verification on its behalf, that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. r BY:/'? Representative of Plaintiff, FORD MOTOR CREDIT COMPANY LLC DATE: J UN 2 r' 2012 48063000000042936719 Our File No.: F1100760 LEANN N KRIMM and CHRISTOPHER M KRIMM Exhibit A g? 7 gi ? S }• `; a???i Nisgy ` ? ?ia ? 3 • 3 a ?I ^ •! l ??i ? ?i ~ s p T} ' ? f t ? ? ' i l ? } ? ? 1 I ? 2i ? ? C l _ ? ? [ 1 ? ? l / ? ? 3?? T °s (}73 a a! 3 ? ?i, ? i ! • ii g ? [ a ! l e ' 3 ??? a i I [Y i s? 3 d t # y ? if ? }`. ? ? ? { fa ? 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A.. i I BEAD T1ti5i AaBiTFA11G'ti PafY1SW :' I;AII+:MIJG•Y Ann 1'J At S r: n t?I.l:'!V All:Sr'NAilDti I I i Exhibit B "PRN"' Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631-3111 (877) 349-5260 PlFILE00200045 LEANN N. KRIMM 1483 FIX RD. MONROE MI 48182 Date of Repossession 03-07.2011 Date of Notice 03.09.2011 Date of Contrail 03-25-2007 Account Number. Buyer LEANN N. KRIMM Cab r CHRISTOPHER M . KRIMM DESCRIPTION OF PROPERTY Year 2007 Make FORD [] New ? used Vehicle Identification Number: sommoommor? Model EXPLR Body 4DR its M NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises In our agreement. x0 PRIVATE SALE: We vAl sell the property described above at ? PUSUC SALE: We vAII sell the property described above at public private sale sometime after 10 days from the Date of Notice sale to the highest bidder on the date below (or any adioumment shown above, date). The sale wig be held as follows: I Date of Sate I Time of Safe I Place of Sale I You may attend the sale and bring bidders if you want. The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses If permitted by law) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get 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. To learn the exact amount you must pay, call us at the telephone number 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. If you need more information about the sale call us at the telephone number above, or write us at the address above. 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 has been (or will be) returned Under our agreement with your dealer/original creddor, the deelerloriginai creditor is to sell the property and pay you any money left over. If you owe money after ft sale, you will pay it to the deaier/crlginal creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you vvithin the next 60 days or, In accordance with state law, contacting this office. Thereafter, the personal property shag be disposed of accordingly. ? Creditor has assigned to As qualified intermediary (01 Exchange, LLC) its rights (tat not do obligations) with respect to the sale of each vehicle listed abt PAYMENTS: AN payments to us must be by certified check or money order. MILEAGE DISCLOSURE: It 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/origirial creditor to make sure that any insurance has been cancelled. You have a right to get credit for of premkxn refunds. SUDHARSHAN,SUDHARSHAN FFNA 11998 An 02 P ev aus edlions may NOT be umd. CUSTOMER/CUSTOMER FILE Pdntetl n U.S.A. MLLE 002 E000464000342 212 "PRN"' Ford Motor Credit Company P.O. Box 31111 TAMPA, FL 33631.311 t (877) 349-5260 PIFILEM200064 CHRISTOPHER M. KRIMM 167 JOYA CIRCLE HARRISBURG PA 17112 Date or Repossession 03-07-2011 Date of Notice Date of Contract 03.09.2011 05-25-2007 Account Number: Buyer LEANN N. KRIMM Cobuyer CHRISTOPHER M. KRIMM DESCRIPTION OF PROPERTY Year 2007 Make FORD Q New ? Used Vehicle Identification Number: i? Model EXPLR Body 4DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises In our agreement. Q PRIVATE SALE: We will eel the property described above at ? PUBLIC SALE: We will sell the property described above at public private sale sometime after 10 days from the Date of Notice sale to the highest bidder on the date below (or any adjournment shown above. date). The sale will be hold as follows: I Date of Sale I Time of Sale I Piece of Sale I You may attend the sale and bring bidders If you went. 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 w111 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. To learn the exact amount you must pay, call us at the telephone number 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, If you need more information about the sale call us at the telephone number above, or write us at the address above. 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 oobuyer 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 has been (or will be) returned Under our agreement with your dealer/original creditor, the dealerloriginal 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 dealar/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 (OI Exchange, LLC) its rights (tut not Re obligations) with respect to the sale of each vehicle listed above PAYMENTS: AN payments to us must be by certified aleck 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 dealerloriginal creditor to make sure that any insurance has been cancelled. You have a right to get credit for all premium refuels. SUDHARSHAN.SUDHARSHAN FFNA 11998 Jan 02 Prevaus ednions may NOT be used. Printed in U.S.A CUSTOMER/CUSTOMER FILE U.S.A. IFILE_002 E00084-1000340 2/2 Exhibit C Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-3111 877 3495260 DATE: 2011-04-20 PIHNVV00100002 LEANN N. KRIMM 1483 FIX RD. MONROE MI 48162 CHRISTOPHER M. KRIMM 167 JOYA CIRCLE HARRISBURG PA 17112 STATEMENT OF SALE Account Number: M?W The following property has been sold. Year Make Model Vehicle Identification Number: 2007 FORD EXPLR NNW Balance owing on your contract (1) $ 18,409.12 Deduct: Finance Charge Rebate (2) $ 0.00 2 Ch R b t 1 B l l Fi (3) $ 18.409.12 ) nance arge e a e ( - a ance ess Deduct: gross proceeds of the sale (4) $ 12,000.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 6,409.12 Add: Expenses of retaking and storing, and (6) $ 565.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. (7) $ 178.14 Deduct: Insurance Premium Rebate (8) $ 4.97 Other. (9) $ 6791.01 Deficiency- (10) $ N/A Surplus" The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest added to your account (debits). Surplus" or Deficiency" ' if the sale resulted in a surplus, a refund for the difference will be mailed to you. •' If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional information call or write: Mail deficiency payment to: Ford Motor Credit Company Ford Motor Credit Company P.O. BOX 6508 DEPT 194101 MESA ARIZONA 85216-6508 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 FFNn119M QW4 Proymus edbons may NOT be used Ford Motor Credit Company P O BOX 31111 TAMPA FL 33631-31 11 877 3495260 DATE: 2011-04-20 PIHIVW00100003 LEANN N. KRIMM CHRISTOPHER M. KRIMM 1483 FIX RD. 167 JOYA CIRCLE MONROE MI 481e2 HARRISBURG PA 17112 STATEMENT OF SALE Account Number: The following property has been sold. Year Make Model Vehicle Identification Number: 2007 FORD EXPLR Balance owing on your contract (1) $ 18,409.12 Deduct; Finance Charge Rebate (2) $ T 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 18,409.12 Deduct: gross proceeds of the sale (4) $ 12,000.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 6,409.12 Add: Expenses of retaking and storing, and (6) $ 565.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. (7) $ 178.14 Deduct: Insurance Premium Rebate (8) $ _ 4.97 Other: (9) $ 6791.01 Deficiency- (10) $ _ NIA Surplus' The Surplus/Defloiency will change based on monies received by us (credits) or additional allowed expenses 8 interest added to your account (debits). Surplus' or Deficiency- If the sale resulted in a surplus, a refund for the difference will be mailed to you. " If the sale resulted in a deficiency, you should Immediately remit the amount shown on line 9 to the address for payments shown below. For additional information call or write: Mail deficiency payment to: Ford Motor Credit Company Ford Motor Credit Company P.O. BOX 6508 DEPT 194101 MESA ARIZONA 85216-8508 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 FFNAI IWO 01104 PreAoUS YAWoni rfay NQT be wW. AUCTION COPY BID # 431 MANHEIM PENNMYANIA 1190 LANCASTER ROM MANHEIN PA 17545 -(am) &'8-2886 FAX(717) 665-4265 YEAR MAKE MODEMUS SERIES BODY COLOR 2007 FORD EXPLORER 4X2 4SUV BLACK ANN COND: REPO-RTR;3RD SEAT RETAIL REPOSSESSION GREEN ZGUARGTEEI IFULL7 IFULLI4 oN rol! mme ? ?1Aa 5067856 11 431 FISHER AUTO SALES INC } 1101 LINCOLN HISR AY NORTH VERSAILLES, PA 15137 I412I 829-7666 -! BRAtIDf1Il VARNER la X ?RN!au FVR X A•e FALVAIWIS CIVr84 MWP"MEMWDOPWOF0WN5 eADaOA6URE5llUB nWFltWl 1Q QK t CNWIAtra tTlEteuximrlsRlli ===% eedalp• UekM Gf eL AUCTRON A=UK NO RUPONSORMY NOR OIUARANTI[n TM ACCURACY OF TM 000WrMR READING DOCUMENT NOT VALID FOR EXPORT FBC: TF Nlmheirn NOT A RECEIPT OF PAYMENT 2011-023-130212 10:42:41 WRENICKY 4/15/2011 t AR 4/11/2011 5594108 • TI-'LE RECID ENG INT NT R PS PB AC ES TOP C EL 4X TL SRS SI R E3Ci BLK L. C A X X X X D HT X X 2 X D F X NOTES- c IP I 48126 t - IlF rL.ERK (SOLD BY - I MGH I JN6 I I I I 3 I _ LICENSE NO. TAB sum Oft= CHMWOW C} CLEAN ? WOUGI I ? AVERM F ni m m NOTICE:- * Do not re-purchase or fYlance without card" of #f. • Aucdon retains semutty Interest In vehicle ung pool funds received. OOOME 1 OMCLASURE STATEMENT Section 580.5 Diseftwe form FEOEFVL U {AND STAGE L AK IF APMJCADLM MUJPM TMAT VDU S81TE THE MILEAGE UPON TRANSFER Of OWNEASHP, fMLURE TO COWLETS OR F RNMNOAfAtSE SPRENENTMM PIESULT W FINESANDMWWR1$OMON:NT. ? (1) I hereby cedlly to the bee ol my I aWledpe the odometer mW rjo refMde the aMOMf 01 mlleaye In 6CM of 8e aadfe kal Omit. ? (2)1 hereby CerWit that Vo odouteter rtadlnp 4 NOT the actual mileepa -WARNWa - ODOMETER MSMEIMNCY /F= MOTOR CREDIT COMPANY,= STATE TW4 'n E ODOME M NON! READS 517841 MtESMTUM"Me'10TIEBEST OFMY IWOWUWW THAT IT REELECTS THE ACTUAL MILEAGE OF THE VeNCLE DESC MW Ft It l UNLESS NOTED OUTERENTLY ABOVE- Fdrvdue reaMd I Maly wE w 0p or bander t vehfde dmabed on 1Ne dommerM 10 00 prrdueer aenurd d MA X TRANSFERORS SRiNAMPE (SEU•ER} PRINTED NAME OF (SIGNORI s A- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Of'r a T4E PPMTKCNC bw 2912 SEP -6 AM 10: 13 CUMBERLAND COUNTY PEI SYE VARIA Ford Motor Credit Company vs. Leann N. Krimm (et al.) Case Number 2012-4478 SHERIFF'S RETURN OF SERVICE 08/27/2012 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Christopher M. Krimm, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Christopher M. Krimm. Deputies attempted service at 5304 Oxford Drive, Apartment 89, Mechanicsburg, Pennsylvania 17055, but were advised by the current resident Christopher M. Krimm was the previous tenant ending occupancy January 2012. To date The Mechanicsburg Postmaster has been unable to provide a good forwarding address for the Defendant. 08/27/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Leann N. Krimm, but was unable to locate her in his bail6ick. He therefore returns the within Complaint and Notice as not found as to the defendant Leann N. K?timm. Deputies attempted service at 5304 Oxford Drive, Apartment 89, Mechanicsburg, Pennsylvania 17055, but were advised by the current resident Leann N. Krimm was the previous tenant ending occupancy January 2012. To date The Mechanicsburg Postmaster has been unable to provide a good forwarding address for the Defendant. SHERIFF COST: $59.00 August 29, 2012 SO ANSWERS, t? RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. FILED-OFFICE Andrew Sklar, Esquire (ID #65332) OF THE PROTHONOTARY Lloyd S. Markind, Esquire (ID#52507) 2013 APR -8 PM 4.' 15 Jordan W. Felzer, Esquire (ID #38670) Sklar—Markind PUMBERLAND COUNTY 102 Browning Lane, Building B, Suite 1 PENNSYLVANIA Cherry Hill,NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: F 1100760 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW FORD MOTOR CREDIT COMPANY LLC : No. 2012-4478 Plaintiff TERM vs. CIVIL ACTION LEANN N KRIMM and CHRISTOPHER M KRIMM Defendant PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly mark this action as discontinued without prejudice. Date: Andrew Sklar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID #52507) Jordan W. Felzer, Esquire (ID #38670) Attorneys for Plaintiff Sklar—Markind 102 Browning Lane, Bldg B, Suite 1 Cherry Hill,NJ 08003 (856) 616-8710 phone (856) 616-8716 fax I depose and say that the facts set forth in this filing are true and correct and acknowledge that I am subject to the penalties of 18 P.S.4904 relating to Unswom Falsifications to Authorities.