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HomeMy WebLinkAbout13-3031 c Supreme Co nnsylvania Cour of,Commo ' Pleas For Prothonotary Use Only: �-�-,� Ci il' r Co�e s -' hr Docket No: 'Sr CUMBERCAN� County 7. 7 fl The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S 19 Complaint [S Writ of Summons 13 Petition ® Transfer from Another Jurisdiction rl Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: FORD MOTOR CREDIT COMPANY, LLC GENERAL REMODELERS INC T Dollar Amount Requested: Elwithin arbitration limits I Are money damages requested? i] Yes El No (check one) outside arbitration limits 0 N Is this a Class Action Suit? p Yes i] No Is this an MDJAppeal? rl Yes i] No A Name of Plaintiff /Appellant's Attorney: LLOYD S MARKIND Check here if you have no attorney (are a Self - Represented (Pro Sep Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional Buyer Plaintiff - Administrative Agencies Malicious Prosecution Debt Collection: Credit Card ® Board of Assessment 0 Motor Vehicle Debt Collection: Other Board of Elections n Nuisance CAR LOAN Dept. of Transportation Premises Liability Statutory Appeal: Other S r_1 Product Liability (does not include E mass tort) � Employment Dispute: Slander/Libel /Defamation Discrimination C Other: Employment Dispute: Other Zoning Board , n-j Other: I I] Other: O MASS TORT 0 Asbestos N rl Tobacco Toxic Tort -DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste El Ejectment rl Other: El Common Law /Statutory Arbitration B El Eminent Domain/Condemnation Q Declaratory Judgment El Ground Rent Q Mandamus El Landlord/Tenant Dispute Q Non- Domestic Relations El Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY [I Mortgage Foreclosure: Commercial Q Quo Warranto 0 Dental Q Partition 0 Replevin Legal 0 Quiet Title 0 Other: Medical Other: Other Professional: Updated 1/1/2011 Sklar - Markind Lloyd S. Markind, Esquire (ID #52507) 102 Browning Lane Building B, Suite 1 Cherry Hill, NJ 08003 File No.: F1101117 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC :No. 3 °J/ I J C) Plaintiff TERM M CC VS. ; CIVIL ACTION ` c c -:. --+c:) GENERAL REMODELERS INC AND c n MIKE GOODHART :;; o = CD c=, Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: 717- 249 -3166 c� nv) 3 AVISO Le han 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 asentar 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 medidas 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 o 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 Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer, Esquire (ID #38670) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616 -8710 FILE NO.: F 1101117 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 I Term I Plaintiff(s) I CIVIL ACTION I V. I I GENERAL REMODELERS INC and MIKE GOODHART I Defendant(s) CIVIL ACTION COMPLAINT 1. Plaintiff, Ford Motor Credit Company , is a Limited Liability Company with a place of business at 1335 S. Clearview Avenue Mesa, AZ 85209. 2. Upon information and belief, Defendant, GENERAL REMODELERS INC , is is a business which is located at 184 TEXACO RD, Mechanicsburg PA 17050. Defendant, MIKE GOODHART , is an individual who resides at 184 TEXACO RD, Mechanicsburg PA 17050. 3. At all times relevant hereto, the Plaintiff was in the business of financing the purchase of motor vehicles, including but not limited to the motor vehicle installment sales contract signed by Defendant(s), hereinafter more fully described (the Contract as hereafter defined). 4. On or about FEBRUARY 4, 2004, the Defendant(s) entered into a written Motor Vehicle Retail Installment Contract, Account Number 48063000000036469860, (hereinafter referred to as the "Contract "), for the purpose of obtaining financing in the amount of $23,718.10 at an annual percentage rate of 6.75 %, in order to purchase a certain motor vehicle, 2004 FORD s ' ECONOLINE, 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 $466.84 for a period of 60 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 APRIL, 19, 2004, 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 $16,700.00, however a balance of $7,323.58 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 $5,366.51 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 $1,871.26. 12. The total amount due and owing at the date of this complaint is $14,561.35. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), jointly and severally, if more than one, in the amount of $14,561.35, 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 MARKIND Date: April 30, 2013 Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer, Esquire (ID #38670) Attorneys for Plaintiff 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616 -8710 VERIFICATION I, Victoria McKechnlc , verify that am an Authorized Representative for the Plaintiff, Ford Motor Credit Company , and are duly authorized to take this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of 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: Victoria McKcchnic Representative of Plaintiff, Ford Motor Credit Company DATE: HAY 1 10 2013 48063000000036469860 Our File No.: F1101117 GENERAL REMODELERS INC and MIKE GOODHART Exhibit A PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE 02/04/2004 Btrysr I Cq- Buy @rLNa ant go tlrees (including County and Zip Code) CREOROR (Seller Nome srd Address) G N ( ELERS INC 1 MIKE G00 A FEB 0 5 2004 MCCAFFERTY FORD 246 PROGRESS AVE 6320 CARLISLE PIKE HARRISBURG PA 17109 MECHANICSBURG PA 17050 You, the Buyer (and C"guyer, If my), may buy the vehicle described Mow for cash or on credit The'Cmb Rice' shown below M the cosh price of the vehicle. The "Total Sale Price' shown below Is the credit price. By signing this contract, you ahmao to buy on credit under the agrecrosnts on the front and back of this contract. NevrUaR Yaflr and Maka raatlel Gvw x Treax IW. Vehicle Idernteatlan Number Use For Which Purchased NEW 2004 ID( Personal d Agricultural FORD TRUCK ECONOLINE O Comm mel INSURANCE Trade - In s NIA s N/A YOU MAY OBTAIN VEHICLE INSURANCE Year and Malin cross Allowance Nrwunt Owing ITEMIZATION OF AMOUNT FINANCED F—M A PERSON OF YOUR CHOICE YOU ARE NOT REQUIRED TO OBTAIN 1. Cash Price .......... .. .... _ ............................... _.... ........_..._..._._........._.. $ 4� 1 CREDIT LIFE, CREDIT DISABILITY AND 2. Down Payment OTHER OPTIONAL INSURANCE. THIS Third Party Rebate Assigned to Creditor ..,..,.,. ................... $_25OO –D0- CONTRACT WILL NOT INCLUDE THEM Cash Down Payment ............... _ .......... ...._.... ......... ...... $ NIA UNLESS YOU SIGN AND AGREE TO PAY Trade -in $ N/A $ N/A $ NIA THE PREMIUM. Yin, wa ua.e sae. uubv eem„eh o deo THIS CONTRACT DOES NOT INCLUDE Total Down Payment .._ ........ ............................. ......... $ 7SO0.n0 (2) LIABILITY INSURANCE COVERAGE FOR 3. Unpaid Balance of Cash Price (t minus 2) ......... _ ......................... $ 29090.00 (3) BODILY INJURY AND PROPERTY 4. Amounts paid on your behalf (Seller may be ratalning a portion of these amounts) DAMAGE CAUSED TO OTHERS. To Insuranca Companies for $ NIA Credit Life Insurance (for term of contract) ............_._....... N/A Credit Disability Insurance (for term of contract) ..... _....... $ NIA N/A [Term RLLM onths(Estimate))$ To Public Officials (i) for license ( 10.00 ). tale ($22..50_), 8 17 Credit Life NIA Insurer registration fees $230.2; NIA (it) for filing fees $ 5.00 $ (ie) for taxes (not In Cash Price) $ I328, 60 s 1 S64 - I n Premium Insured(s) To N/A for $ NIA To N/A for N/A $ NIA Signature To MCCAFFERTY FORD FEE I 55.00 - /ONLI Es 94 -1m To N/A for N/A $ NIA Credit Total....._._ ................ ..... ..... ........................... _.._...._..._._..._.... $ 1658 -1n (4) ❑Disability NIA 5. Amount Financed 3 plus 4) .. .............. . ...... _ ....... __. " " "' ................. $ 23778. ]0 Insurer 5 $ NIA FEDERAL TRUTH -IN- LENDING DISCLOSURES Premium Insured ANNUAL FINANCE Amount Total of Total Sate Signature PERCENTAGE CHARGE Financed Payments- Price RATE The dollar amount The amount of The amount The total cost the credit wit credit provided to you will have of your purchase on craO 'the cost as rate ads[ you you or on your gold when you credo. C _N/ NIA Y behalf have made as including your Other Optional Insurance Term schedulea downpe m payments" of UA _ Jl1A $ � 6.75 %IS 4292.30 g 23718.10 s 2801 n. 4n s 3nGln_0_ insurer PremiurrS Number of Amours of Each Whgn Payments 5' rii`t e Payment Schedule )101 Pe ems Payment are due credit ufe and credit olcablg insurance are Your payment schedule $ 466.84 (monthly slartytg) for the term of the contracL The amount and will be: 1 final $ 466.84 na /nS /90n4 gW�n to toda In o nonce or agreemerd You must Insure the vehicle, or wit wile bu II a cf k edi shown below, t Crtor try to buy the coverages checked for the tens ahawn. Coverages will be based on the cash value of the vehicle at time of foes, but cwt more Mmrr the Ikehs of the policy. Prepayment: If you pay off your debt early, You will not have to pay a penalty. ❑ COrn{Nahenelve ❑ $- —Dtiducl Cogro Late Peyment: You must pay a late charge on the portion of each payment received more than 10 days late. The charge is 2 percent of the late amount or $50.00 whichever is less. E3 Rre- Thee Combined Additional Coverage Security Interest: You are giving a security Interest In me vehicle being purchased. ❑ Towing and Labor Contract: Please see this contract for additional information on security interest norrpeyment p Term N / A Months (Estimate) default the right to require repayment or your debt in full before the scheduled dale. and Premium S NIA prepaymertl penalty. 1 II you do not meet your contract abligatims, you my lose the vehicle that you are financing under this contract, as well as both pans and goods phi on the vehicle and money or goods received for the vehide. ❑ Debt Cancellation Waiver Addendum (OPIIxIeq NON-MODIFICATION DISCLOSURE If itds box is checked you have purchased a debt cancellation waiver. Purchase at this coverage is I Any change in this contract must he in writing and signed by yolt and the Creditor. aptionat and is not regWred to obtan crack. The terms end oorxFliors of she dent cancellation waver ere eat forth in the aaachad Addendum which Is Incorporated gllYE is X !Y�" - brio this contract. The price for the debt mncallaoon IGN SIGNS waiver is eel Wit on this contract in the asmization YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO BE BOUND of Amount Financed under Section 4. BY THE ARBITRATION PROVISION ON THE REVERSE SIDE OF THIS CONTRACT. NOTICE TO BUYER Do not sign this contract In blank.' You are entitled to an exact copy of the contract you sign. Keep it to protect your legal rights. Guyer (and Co- Buyer) acknowledge that (1) before si rein this contract, Buyer (and Co- Ruyer) received an rev ewes a true Program No. and — completely tilted in copy of this contract and (ii) at the QUESTIONS? time of si rein this contract Buyer (and Co- Buyer) recei e� a true an compete y i1led in copy of this contract BAYER SIGNS CO BAYER SIGNS i By signing bbiow, IM Sailer accepts this contract it no other Aasignee Is nsmed in a separate PLEASE CALL US AT 1-800 -727 -7000 Dr assign 1 a ��yy�tii ed to this contract, the Bell salgns it to owe Credit Company. WA RTY FORD Visit us at tordcredlt coin M IMP -51 a. oa (Pndma aamn. may a „sec.) 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Payments and Summa Notice: You must make all G. Use of Vehicle — Warranties: You must take care of the payments in U.S. funds when t ey are due. You may prepay your vehicle and obey all laws in using It. You may not sell ar :rent the debt at any time without penalty. This is a simple interest contract, vehicle, and you must keep it free from the claims of others. You The actual finance charge you agree to pay will depend on your will not use or permit the use of the vehicle outside of the .5Z; payment patterns. The actual finance charge may exceed the States, except for up to 30 days in Canada or Mexico, without. disclosed Finance Charge it you make your payments later than the prior written consent of the Creditor. If the vehicle Is of a the scheduled dates or in less titan the scheduled amount. The type normally used for personal use and the Creditor, or the Creditor will apply your payments first to the earned and unpaid vehicle's manufacturer, extends a written warranty -or part of the Finance Charge .and then to the unpaid Amount service contract covering the vehicle within 90 days from Financed. The Creditor earns the Finance Charge by applying the date of this contract you get Implied warranties of the Annual Percentage Rate to the unpaid Amount Financed for merchantability and fitness for a particular purpose the actual time the unpaid Amount Financed is outstanding.. If the covering -the vehicle. Otherwise, you understand= and ;agree vehicle is repossessed, you will not have a right to reinstate the that there are no such implied warranties, except as contract unless the Creditor agrees, provided by law. B, Final Payment- You mays handle your originally scheduled H. Insurance: You must insure yourself and the Creditor final payment obligation In one of three ways. First, you may against loss or damage to the vehicle. The Creditor must make the final payment Second, you may refinance the final approve the type and amount of insurance. The Creditor may payment as set.forth below. Third, you may .sell the vehicle to buy the insurance if you do not, but he does not have to do. so. Creditor as set forth below. If the Creditor buys the insurance, he will insure .both you and himself. You must pay back-to the Creditor what he pays for the insurance plus interest at the highest rate allowed by law. C. Refinancing: You may refinance the originally scheduled Whether or not the vehicle is Insured final payment unless you are in default under this contrail. If the : Y ou must pay for it if Creditor has advanced funds to cure any default, you must pay it is lost, damaged, or destroyed. back the Creditor before the refinancing. You also must provide If a charge for vehicle insurance is shown on the front, the proof of insurance acceptable to Creditor before the refinancing. Creditor will try to buy the coverages chocked for the term The Creditor will refinance the originally scheduled final payment shown. The Creditor is not liable, though, If he cannot do so. If at the lower of the rate contained in this contract or the maximum these coverages cost more than the amount ra e.perm e y a w'. 7 fi� Cie ttor w, . e ermine rs3 taint of the insurance, 'th6 Creditor may buy them for a shorter term or he refinancing based on the amount refinanced, the rate, and the may give you credit for the amount shown. If he cannot buy any amount of the monthly payment. The term of the refinancing will insurance, he will give you credit for the amount shown. The be based on the amount refinanced, the rate, and the amount of Credit will be made to the last payments due. the monthly payment. If you wish to refinance, you must notify the Creditor In writing. Except as discussed In Paragraph Q, the 1. Late Charge: You will have to pay a late charge on the Creditor must receive the notice no latorthan 30 days prior to the portion of each payment received more than ten days late. The final payment due date, charge Is shown on the front. You must also pay any cost paid by the Creditor to collect any late payment.as allowed by law. D. Sale to Creditor: You may sell the vehicle to the Creditor for Acceptance of a We payment or late charge does not excuse an amount equal to the originally scheduled final payment less a your default or mean that you can keep mating payment.% after $250.00 disposal fee. You must pay to the Creditor the $250.00 they are due. The Creditor may take the steps set forth below if and any other amounts owed under this contract. Amounts you there Is any default. owe, will be based,_ in.part,._oni the vehicle's.. mileage. You also mlrst pay fo.fie Creditor the cost of all repairs to the vehicle that J. Default: You will be in default it. are the result of excess wear and use, as set forth below. You 1. You do not make a payment when it is due; or must take the vehicle to a, place selected by the Creditor for 2 You gave false or misleading informatlon on your credit inspection no laterthen 15 days prior to the final payment due application relating to this contract; or date. After the inspection, If you decide to sell the vehicle to the 3, Your vehicle is seized by any local, state, or federal Creditor, you must give the vehicle to the Creditor no later than authority andis not promptlyarid unconditionally returned to the final payment due date. At that time, you must also give the Creditor a title, which shows no liens other than the Creditor's You: or 4. You file a bankruptcy petition or lien. transferring ownership to the Creditor or a person selected s e in this contract a Is hied against you; or by the Creditor. After the inspection, if you decide not to sell the S. You do not keep any other promise vehicle to the Creditor, you must immediately contact the Creditor If you detauh, you must pay any legally permitted expenses related to and inform the Creditor whether you want to refinance the final enforcing this contract, including collection expenses. lawyers fees payment. and other legal expenses. Also. if you default, the Creditor may require You to pay at once the unpaid Amount Financed. the earned and E. Exoess Wear and Use: You are responsible far all repairs unpaid part of the Finance Charge, and all other amounts due under and damages to the vehicle that am not the result of normal this contract He may repossess (take brick) the vehicle too. He may wear and tear. These repairs ln4lude, but are not limited to, those also take goods found in the vehicle when repossessed and hold them necessary to: I for you. (I) replace any lire not part of a-mm ping -set of four or any tire which has less than 118 inch of remaining tread: If the vehicle is taken back, he will send you a notice. The notice will (ii) repair all mechanical defects; say that you may redeem (buy back) the vehicle, and will explain how (iii) repair or replace all dented, scratched, chipped, rusted, to redeem the vehicle. You may redeem the vehicle up to the rime the or mismatched body panels. paint, or vehicle Creditor sells ft or agrees to sell ft. If you do not redeem the vehicle, it Identification items; all dented, scratched, rusted, pitted, will be sold, broken, or missing trim and grill work; all scratched, cracked, pitted, or broken glass; all faulty window The money from the sale, less allowed expenses, will be used to pay mechanisms; all broken or burned out lights; all at amounts still owed on this contract. Allowed expenses Includethose electronic maffunctions: all Interior rips, stains, burns, or paid as a dreat result of having to retake the vehicle, hold r., prepare wom areas; and all damage which would be covered by ft for sale, and sell ti. 11 there is any money left (a surplus), it will be collision or comprehensive insurance whether or not paid to you. lt the money from the sale is not enough to pay off this such insurance is actually in force. contract and costs, you Mr11 pay what is still owed to the Creditor. If you You must make the repairs before the inspection of the vehicle do riot pay this amount when the Creditor asks, the Creditor may - .paragrapb- LL-Oitienufss..You ed cost charge you interest at the highest law, ra!e uMS yeu pay. under of such repairs to itte Creditor. The Creditor, however, need not make the repa p rior to y o u r sale of the vehicle to ft Creditor. K. Consumer Reports: You authorize Ford Motor Credit Company :of= svch:xepatrs o Itte Creditor., Thea:4oi1•dor,- vet deed not ; rroake ttae tepaus to:y'ourale cf:lhe:vetucte 6o.the ,Creditor K ;Consumer Re ports 'You sutharize`Ford Motor Credit Comparry • .... .. - - .. •to otitain. ooaStiriior�crad' e: ieporis. Yrflrrrxonsurr +er:•repor F. Security.tntemst- You give the Creditor a security interest in: (credit bureaus) .for any reason end at any time- In connection with Ws contract. 1. The vehicle and all parts or other goods put on the vehicle;. L. General: You .and the Creditor must sign a document-io make 2. All money or goods received for the vehicle; and any change in this contract. To contact Ford Motor.Credi: Company 3. All insurance premiums and ser Vice contracts financed for about this account, call 1 - 727.7000. Also, you may make you. addtass and other selected changes at x -Atir.forderedit.com. The law of Pennsylvania applies to ibis contract. If that law does not allow all This secures payment of all amounts you owe in this contract, it of the agreements in this contract, the ores that are not allowed will also secures your other agreements in this contract. be void. The rest of dtia contract will still.be good. Ford Credit has assigned to 'intermediary' as defined in the Agreement to Terms of Assignment, its tights (tut not its - obligations) with respect to the purchase of this vehicle and the sale.of this vehicle at contract termination. NOTICE -- ANY - HOLDER 10F THIS--CONSUMER CRM!F!0W CT TO ALL CLAIMS AND DEfEIdSES WHICH THE DEBTOR COULD ,ASSERT AGAINST R SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RTHE DEBTOR SHALL NOT EKCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER." Used Motor Vehicle Buyeis Guide. If you are buying a used vehicle with this contract, federal regulations may require a special Buyers Guide to be displayed 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. 'Does not apply 11 purchased for commercial or agricultural use. In that case, you (dabtor) will not assert against any assignee or subsequent holder of this Contract any claims, defenses, or satoffs which you mg have against the Seller or manufacturer of the vehicle. l GUARANTY To cause the Seller to sell fhe' vehicle described on the front of this contract to the Buyer, on credit. each person who signs below as a 'Guarantor' guarantees the payment of this contract. This means that if the Buyer fails to pay any money that is awed on this contract, each one w signs ass g uarantor A ply k w hen asked. Each person who signs below.agtetts.1bat h"ILbe tiablo toc�le. -. -- - amount owed even it one or more other persons also signs this Guaranty. He also agrees to be liable even if the Creditor does one or more of the following: (a) gives the Buyer more time to pay one or more payments, or (b) gives a release in full or In part to any of the other Guarantors, or (c) releases any seaway. Each Guarantor also states that he has received a completed copy of this contract and this Guaranty at the time of signing. Guarantor Address Guarantor Address READ THIS ARBITRATION PROVISION CAREFULLY AND IN ITS ENTIRETY ARBITRATION Arbitration is a method of resolving any claim, dispute, or controversy (collectively, a 'Claim') without fling a lawsuit in court. Either you or Creditor {'LS" or'w.e.)..(each a Party').may choose at any time, including after a lawsuit is filed. fo have any CA related to this con - tract decided by arbitration. Such Claims include but are not limited to the following: 1) Claims in contract, tort, regulatory or Otherwise; 2) Claims regarding the interpretation, scope, or validity of this clause, or arbitrahility of any issue; 3) Claims between you and us. our employees, agents, successors, assigns, subsidiaries, or affiliates; 4) Gaims arising out of or totaling to your application for credit, this contract, or any resulting transaction or relationship, including that with the dealer, or any such relationship with third parties who do not sign this contract. RIGHTS YOU AND WE AGREE TO GIVE UP it either you or we choose to art a egg, then you and we agree to waive the following rights: • RIGHT TO A TRIAL, WHETHER BY A JUDGE OR JURY • RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR A CLASS MEMBER IN ANY CLASS CLAIM YOU MAY HAVE AGAINST US 7NHETHER.IN COURT OR IN ARBITRATION • BROAD RIGHTS TO DISCOVERY AS ARE AVAILABLE IN A LAWSUIT • RIGHT TO APPEAL THE DECISION Of AN ARBITRATOR • OTHER RIGHTS THAT ARE AVAILABLE IN A LAWSUIT Ri hts You And We Do Not Give U : if a Claim is arbitrated. you and we hilt continue to have the following rights, without waiving this a dratron provision as to any arm: 1) Right to file bankruptcy to covet 2) Right to enforos the security interest in the vehicle, whether by repossession or through a court of law; 3) Fight to take legal action to entoree the arbitrators decision; and 4) Right to request that a court of Jaw review wwhether the arbitrator - exceeded its authority. Either Party must contact any association below and the other Party to start arbitration. The applicable rules (the "ROW) may be obtained from the association. • American Arbitration Association ("AAA'), at 14WO -77 8-7879. or www.adr.org: • JA.A4.SJEr4spute, at I- 800 -448 -1660, or www.jamsadr corn; • National Arbitration Forum, at 1 -800. 474 -2371. or www.arb- forum.com. if there is a conflict between the Rules and this contract, this contract shall govern. This contract is subject to the Federal Arbitration Act (9 U.S.C. § 1 at seq.) and the Federal Rules of Evidence. The arbitration decision shall be In writing with a supporting opinion. We will pay your total reasonable arbitration fees and expenses (not including attorney fees, except where applicable law othelx7se provides) In excess of $125. We will pay the whole filing fee it we demand arbitration first. Any portion of this arbitration douse that is unenforceable shall be severed, and the remaining provisions shall be enforced. F 37.8$Sr Jul lie (Prvnox 6vM wt may be wad.) PA i I I Exhibit B e Date of Repossession 07 -07 -2004 — 'PRN ^' Date of Notice Date of Contract Ford Motor Credit Company P.O, Box 3076 07- 09.2004 02-04 -2004 COLUMBIA, MD 21045 -6076 Account Number (80)) 677 -0730 Buyer GENERAL "MRS INC Cobuyer MIKE GOODHART DESCRIPTION OF PROPERTY Year Make New 2004 FORD ❑ Used Vehicle Identification Number: GENERAL REMODELERS INC 246 PROGRESS AVE ffl"' HARRISBURG, PA 17109 E350 NOTICE OF OUR PLAN TO SELL PROPERTY We have your properly described above because you broke promises In our agreement, Q PRIVATE SALE: We will sell the property described above at ❑ PUBLIC SALE: We will sell the property described above at public private sale sometime after 15 days from the Date of Notice sale to the highest bidder on the date below (or any adjournment shown above unless redeemed by you prior to such sale. date). The sale will be hold as follows: Date of Sale Time of Sale Place of Sale You may attend the sale and bring bidders if you want NOTICE OF REPOSSESSION The property is presently stored at: BEN RECOVERY ETTERS PA The money that we get from the sale (after paying our costs, HOW TO GET YOUR PROPERTY BACK including reasonable attorney's fees and legal expenses if To get your property back, pay us this amount by certified check or money order before the vehicle Is sold. permitted by law) will reduce the amount you owe. If we get Unpaid Balance $ 23.447.06 less money than you owe, you will still owe us the difference. If Repo Expenses 367,06 we get more money than you owe, you will get the extra money, Plus Costs: S unless we must pay it to someone else. $ S You can get the property back at any time before we sell it by Plus Late Charges $ 28.02 paying us the full amount you owe (not just the past due Less Finance Charge Rebate $ payments), including our expenses. See How To Get Your Less Insurance Premium Rebate $ Property Back for an itemization of amount owing. To learn the TOTAL $ 23,835.08 exact amount you must pay, call us at the telephone number above. you need more information about the sale call us at the (Plus expenses Incurred If default attthe time of repossesslon exceeded If y 15 days and less rebate received after the date of this notice.) telephone number above, or write us at the address above. Your property won't be sold until 15 days after the date of this notice at If you want us to explain to you in writing how we have figured the EARLIEST. After that you can still get it back anytime before Ifs the amount that you owe us, you may call us at the telephone actually sold. number above, or write us at the address above and request a If you do, we'll have no further claim on It But the longer you wale, the Written explanation. more costs (including repairs) you may have to pay. If you have any questions about this, please cell us. 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 to: (dealer/orl9lnalcreclitor) Under our agreement with your dealer /original creditor, the dealer /original cred 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 vehlcle 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 credh for all premium refunds. NINA A. MORROW FFNA 1teS"l Jen 02 Pre awe edlii— may NOT be wed. CUSTOMERICUSTOMER FILE Painted in V.S.A. Date of Repossession 07 -07 -2004 °'PRN ^' Date of Notice Date of Contract Ford Motor Credit Company P.O. Box 3076 07-09-2004 02-04 -2004 COLUMBIA, MD 21045 -6076 Account Numb . (800) 677 -0730 Buyer GENERAL R ODELERS INC Cobuyer MIKE GOODHART DESCRIPTION OF PROPERTY Year Make Q New 2004 FORD ❑ Used Vehicle Identification Number. MIKE GOODHART 246 PROGRESS AVE Model Body HARRISBURG. PA 17109 E350 CARGO NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. x❑ PRIVATE SALE: We will sell the property described above at ❑ PUBLIC SALE: We will sell the property described above at public private sale sometime after 15 days from the Date of Notice sale to the highest bidder on the date below (or any adjournment shorn above unless redeemed by you prior to such sale. date). The sale will be held as follows: Date of Sale Time of sale Place of Sale You may attend the sale and bring bidders if you want. NOTICE OF REPOSSESSION The property is presently stored al: BEN RECOVERY ETTERS PA The money that we get from the sale (after paying our costs, HOW TO GET YOUR PROPERTY BACK including reasonable attorney's fees and legal expenses if To get your property back, payus this amount by certified checker permitted by law) will reduce the amount you owe. If we get money order before the vehicle is add. less money than you owe, you will still owe us the difference. If Unpaid Balance $ 23.447.06 we get more money than you owe, you will get the extra money. Plus Costs: Repo Expenses g 360.00 unless we must pay it to someone else. S S You can get the property back at any time before we sell it by Plus Late charges $ 26.02 paying us the full amount you owe (not just the past due Less Finance Charge Rebate $ payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the Less Insurance Pram um Rebate $ exact amount you must pay, call us at the telephone number Tr,Ta $ 23.835.08 above. If you need more information about the sale call us at the (Plus expenses Incurred if default atthe time of repossession exceeded Y 15 days and less rebate received after the date of this notice.) telephone number above, or write us at the address above. Your property won't be sold until 15 days after the date of this notice at If you want us to explain to you in writing how we have figured the EARLIEST. After that you can still get it back anytime before We the amount that you owe us, you may call us at the telephone wally sold. number above, or write us at the address above and request a If you do, well have no further claim on k But the longer you wait. the have to pay. written explanation. if you have any questions a this please call us. 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 dealerloriginal creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. ❑ The property has been (or will be) returned to: (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 propertyfound 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 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 aright to get credit for all premium refunds. NINA A. MORROW FFNA I19 8W Jan 02 P.-M —. edits n. may NOT be wed. CUSTOMERICUSTOMER FILE Pdnted In U.S.A. i .. E r __ - • — • SELLER'S COPY 2004 - 053 - 150616 9.-1 2 ; 08 15 -0616 WNW AWO AUCTION �DKNIER 9/03/2004 1190 LANCASTER ROAD I;AI&EIN PA 175459789 (717) 6b 7 =1 FAM717) 665 -9M PA 8/25/2004 573483! * PAID �s 1 YEAR MAKE MODEL/SUB SERIES BODY COLOR ENG TNT TNT R PS PB AC EW ES TOP CC EL 0 TL SRS SI RD 2004 FORD TRUCK E350 ECONOLINE VAN WHITE 88 GRY C F A X X X X D CARGO EXT 4X2 +� Sold On Internet ** ANN COND; NOTESs REPO RETAIL REPOSSESSION ) I GREEN I I NO I R.B. I NO 1' SOS I I IF 1 CLERK I SOLD BY ILIGHTSILI©HTSILIGHTSILIGHTSI I t I i I I RLBI JOL I I I i I SALE I ISELLERI i t I I O WE BY tSE CF OUR 14,0712 OR AMICA2ED FEREDY AGREE TO PAY - - - -- - — _ LICENSE NO. TAB I ["TED SALE PRICE FOR THE V9-fICLE iFIS VOUCHER TINDER THE TERMS AND RULES OF THE ABOVE NAMED AUCTON AND SUBJECT TO 28570 ! 1�C881 ?>MU 0631 AGREEMENTON REVERSE SIDE FMRD NOTOR CREDIT C ( B (PANY BUYER PLEASE CHECK ONE A)ERICAN RD PO BOX 1732 ❑ CLEAN ❑ ROUGH ❑ AYERAOE 5OP-70'70 5 1539 D * HI 48121 (t) (2) (3) ; P WHITED FORD TRUCK C81TER NOTICE: `. U 207 PEM ROAD • Do not re- purchase or finance R BAILOR KE 04401 Without certificate of title. C (207) 447 - 3673 L. • Auction retains security interest in H R&M TOZIER vemcle until good funds received. A ODOMETER DISCLOSURE STATEMENT Section $80.5 Disclosure form S. / FEDERAL LAW (AND STATE LAW, IF APPLICABLE) REQUIRES THAT YOU STATE THE - MILEAGE UPON TRANSFER OF OWNERSHIP, FAILURE TO COMPLETE OR E PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. R X ❑ (T) 1 hereby certify to the best of my knowledge the odometer rearing Light Legends reflects the amount of mileage in excess of its mechanical limits. PRINTED PURCHASER'S NAME (BUYER) W /DRIVE it 0 (2)l hereby certify that the odometer reading is NOT the actual mileage X - WARNING • ODOMETER DISCREPANCY PURCHASER'S S IGNATURE "G11.) PURCHASER MIST RETURN SIGNED COPYOF ODOMETER DISCLOSURE STATEMEW (FRONT 6 BACK OF TITLE IF WADE ON TITLE) TO TRANSFEROR [SELLER) OR BE SUBJECT TO CIVIL 6 D NOM GfiEDIT CQP(PANY CRIMINAL PENALTIES, INCLUDINGFINESANDJAR -TMh is Wasp•Actal 19W •e C.FJT.5•e.b(f). I AUCTION ASSUMES NO RESPONSIBILITY NOR GUARANTEES STATE THAT THE ODOMETER NOW F4EADS SELLING THE ACCURACY OF THE ODOMETER READING MLES (NO TENTHS) AND TO THE BEST OF W PRICE $ 16 ,700.00 DOCUMENT NOT VALID FOR EXPORT KNOWLEDGE THAT IT REFLECTS THE ACTUAL MILEAGE OF THE VEHICLE $ A4 F BC; JJ DESCRIBED HEREIN, UNLESS NOTED DIFFERENTLY ABOVE. B UYER'S For value received 1 hereby sell, assign or transfer the vericla described ai thls document FEE $ ` r� � 15. 00 / to the Purchaser named at left. $ X AD.T � z- - UAj_ TRANSFEROR S SIGNATUAE�(St LE 1 ( BUYE x�tJ/ Z ADJ $ 50.00 Buy N A RECEIPT OF PAYMENT PRINTED NAME OF (SIGNOR) NET $ 17,065.00 ,4kICINAL 7/13/2004 Manhel m 1 VEHICLE CONDITION REP ORT 47295 MANSEIM AUTO AUCTION .' FORD ' . , MOTOR CREDIT COMPANY STOCK 1190 LANCASTER ROAD AC�VAlNE= z;> MANgEIM, PA 175459789 RTR 717- 665 -3571 INSPECTOR ,RgECgER INSPAATE 7/13/2004 WORICARM vo 112881 VIN.:.. .A RF?_�VAL D�4TE „ > ;=,. �rocxiro .,., 7/12/200 , DESCRIPTION 2004 FORD TRUCK E350 ECONOLINE CARGO EXT VAN 4x2, WHITE w /GRY Cloth i MECHANICAL 5.4 Liter 8 Cylinder Gas, Automatic, Pwr Brakes, Pwr Steering MILEAGE 8 ,530 MI ROD AM/FM Radio EQUIPMENT AC , Tilt Wheel, Air Bags/Dual, Trip Counter, ABS Brakes, Steel Wheels, Regular Dash MMR $18,474 air• a>< Pal- DescrfOM Danive Type 3e6e* Operation Hours 'Hw n; :Fees CO& NON CHARGEABLE (Normal Bear & Tear) i CHARGEABLE (Excess Near 6 Tear 0 Front Bumper Bent Repplace 1.2 1 8 9 .40' 238.65 ❑ LF Door Dings PDR 1 to 7 PDR 4 .00 ❑ L Qtr Panel Dent 1 to 2 Repair 1.0 6.6 250.80't ❑ Rear Bumper Bent Replace 1.0 1.8 89.40 382.32 13 RF Wheel Cover Missing Replace 37.03 ❑ R Sliding Door Multiple Dents GR 12" Repair 3.6 316-80 ❑ RF Mirror Broken Replace .3 9.00 92.57 ❑ R Qtr Panel Multiple Dents GR 12" Repair 6.0 4.4 343.20 C3 RR Wheel Cover Missing Replace 37.03 i O Gas Unknown Replace .3 9.00 Parts 787.60 Labor & Paint 31.2 Hrs. 1,029.60 PDR Mech anical 2.8 Hrs. 84.00 45.00 CHARGEABLE DAMAGE TOTAL: 1,946.20 Announced Condition........: REPO Comments for Consignor Only: CARGO VAN TOTAL DAMAGE Color Code..: nonetnone Parts 787.60 Driveable...: Yes Labor & Paint 31.2 Hrs. 1,029.60 Int. Cond...: Dirty, OK Odor Mechanical 2.8 Hrs. 84.00 Cert. Cand..: PDR 45.00 Cyberlot....: Air Brush .00 Oil Cond ....: Fair DAMAGE TOTALS: 1,946. 0 Keys........ : Mgt 2 N Val N Rem N Inf N Tires .......: LF 7 GOODY�f�R 245/75R16 LR 7 GOODYEAR 245/15R16 RF 7 GOODY R 245 RR 7 GOODYEAR 245nSR16 SP 12 GOODYEAR 245n5R16 Fuel Level ..: Empty �( 1L� m a y" - GLU Service.....: Scheduled Maint. -No Date - Mileage - d' Location - Category Code..: RTR Grade 3, Average Title Received......: Acceptance Date: I Account Signature: Date: Detail Fees Not Included. Page 1 Exhibit C CURR THRU DATE 09/08/04 HISTORY CARD CHARGE -OFF CTL1 48 CTL2 063 CTL3 000 CTL4 0000 ACCOUNT NUMBER 9860 CUSTOMER CTL2 063 CTL3 000 CTL4 0000 CUSTOMER NUMBER 9860 ADDRESS NUMBER 000 APPLICATION RL GENERAL REMODELERS INC PRIMARY PHONE 717 795 -8099 246 PROGRESS AVE BUSINESS PHONE 717 540 -5259 HARRISBURG, PA 17109 SSN /TID 200346209 OFF /EMP CODE 0 CREDIT SCORE 00000 PRIMARY OFFICER REGION ALT OFFICER COLLECTION OFFICER PROCESS TYPE 03 LOAN RATE 6.7500000 LOAN TYPE 001 INTEREST TYPE F COLLATERAL CODE 0001 FDIC CODE 000 REG CODE 200 COMP CALL CODE 06B0 UCLASSI CODE UCLASS2 CODE REGION CODE 0101 SIC CODE 9900 ACCT STATUS PF ORIG CONTRACT DATE 02/04/04 DATE ACCT STAT SET 09/08/04 CURR EFFECTIVE DATE 02/04/04 LEGAL STATUS CURR MATUR DATE 02/05/09 PROC STATUS CF POST DATE 09/09/04 DATE PROC STAT SET 09/08/04 LAST ADV DATE 02/04/04 ACCRUAL STATUS AC LAST MAINT DATE 09/08/04 STOP PAYMENT IND N LAST TRAN DATE 09/08/04 STOP ADVANCE IND N NEXT DUE DATE 10/05/04 STOP DLQ NTC IND N NEXT BILL DATE 09/15/04 AUTO RECOVERY IND N REPO DATE 07/07/04 BILL CHGOFF IND N TIMES REWRITTEN 0 RENEGOTIATED CD 0 DATE LAST RENEWED STOP ALL IND Y NUM TIMES RENEWED 000 CASH BASIS IND Y TOT TIME EXTENDED ITD 0 UCCC IND N TOT MOS EXTENDED ITD 0 BILL NON - ACCRUAL Y DATE LAST EXTENDED ,PAYOFF SUS REASON 00 DEALER NUMBER 072230 0001 0001 PRODUCT RSI ECON ACCR IND N YTD INTEREST PD 325.93 ORIG LOAN AMT 23,718.10 ORIG PROCEEDS 23,674.10 CURR AMT DUE 0.00 PAYOFF AMOUNT 0.00 PARTIAL PAID AMT 0.00 DATE OF BIRTH COMPASS LOAN NUMBER -DEALER LIABILITY 1 CREDIT RISK ORIG TERM 060 POP SCORE 99.0 GL CODE O1 STATE CODE PA MARKET SOURCE PRIVATE LABEL FCUS TIMES EXTENDED ITD 000 MONTHS EXTENDED ID 0 PLAN CODE PO1 CO1 BUY RATE 5.7500000 AUTO DEBIT ABA NUM AUTO DEBIT ACCT NM COMPASS DEALER NUM JJ A221 KK59 DEALER NAME SEBRING FORD & LINC MERC LLC SUB REGION 2004 LOAN ENTRY DATE 0101 ------------------- - - - - -- CUSTOMER RELATIONSHIP DATA --------------------------- CTL1 48 CTL2 063 CTL3 000 CTL4 0000 MIKE GOODHART CUSTOMER NUMBER 00023600659182 246 PROGRESS AVE RELATIONSHIP TYPE 4 HARRISBURG, PA 17109 LIABILITY TYPE 2 NUMBER OF RELATIONSHIPS 1 r 1 GENERAL REMODELERS INC PAGE 419 CTL1 48 CTL2 063 CTL3 000 CTL4 0000 ACCOUNT NUMBER 860 -------- ---------------- -- - - -- SUMMARY BALANCES ------------------------------ PRINCIPAL BAL 0.00 ACCRUED INS 0.00 FINANCE CHRG 0.00 _ INS REBATE 0.00 FINANCE CHRG REB 0.00 ASSD LATE CHRG 0.00 DLR RES FIN CHRG 0.00 ACCR LATE CHRG 0.00 DLR RES REBATE 0.00 LATE CHRG ACCR BAL 0.00 ACCRUED FEES 0.00 COST OF FUNDS 0.00 ASSESSED FEES 0.00 INS FIN CHRG 0.00 FEE EARNING /REB 0.00 INS FIN CHRG REB 0.00 COMMITMENT BAL 0.00 CHARGED OFF AMT 7,323.58 ACCR COFF BAL 0.00 -- ------ -- --------- -- ---- - - -- -- BALANCE DATA ---------------------------------- CURRENT BALANCE 0.00 AMT BILLED NOT PD 0.00 ORIGINAL BALANCE 23,718.10 AMT PAID YTD 17,307.75 BILLED NOT DUE 0.00 CHARGEOFF BALANCE 6,410.35 TOT AMT ADVANCED 23,674.10 CHARGEOFF BAL YTD 6,410.35 CURR COMM AMOUNT 0.00 OVERLINE BALANCE 0.00 ORIG COMM AMOUNT 0.00 TOTAL AMT USED 0.00 AVAILABLE BALANCE 0.00 OUTSTANDING BAL 0.00 ----------------------------- - - - - -- INSURANCE DATA ----------------------------- INS TYPE #1 INS TERM 0 INS CODE 00 CALC CODE COMPANY ID POLICY NUMBER PREM AMOUNT 0.00 PREM TYPE END DATE EXP NOTICE CODE INS TYPE #2 INS TERM 0 INS CODE 00 CALC CODE COMPANY ID POLICY NUMBER PREM AMOUNT 0.00 PREM TYPE END DATE EXP NOTICE CODE ------ ---- ---------------- - - - - -- ACCRUAL DATA ---------------------------------- DESCRIPTION ORIG REM ORIG LST INT PMT/ ACCRUAL PER TERM TERM UNEARN CUR UNEARN EARNED DIEM EFNO1 60 53 25.80 0.00 0.00 DEALER EARN 60 53 635.90 0.00, 0.60 INTEREST 0 0 4,292.30 0.00 0.00 ADDED EARN SI RATE/ DESCRIPTION DATE DAYS AO RATE EFNO1 02/05/04 5 6.7500000 DEALER EARN 02/05/04 6 6.7500000 INTEREST 02/04/04 6.7500000 ------------- ------------ - - - --- BILLING DEFINITION ---------------------------- BILLING DEFN 001 ORIG NUM PMTS 60 BILLING METHOD ST ACTL NUM PMTS REM 0 BILL TYPE 04 NEXT AUTO DEBIT DATE NEXT DUE DATE 10/05/04 AUTO ACCT NUMBER BILL LEAD DAYS 20 AUTO ABA NUMBER 000000000 --------------------- - - - - -- BILLING SCHEDULE DATA ----------------------------- PAYMENT METHOD PMT CALC CODE NUMBER OF PMTS 0 PERCENTAGE 0.0000000 START DATE PMT FREQ STOP DATE PMT INCREMENT 0 FLAT AMOUNT 0.00 BALANCE CALC CODE y ,SCHEDULE TYPE A v GENERAL REMODELERS INC PAGE 420 CTL1 48 CTL2 063 CTL3 000 CTL4 0000 ACCOUNT NUMBER 9860 ------------------------------- COLLATERAL DATA - - - - -- -- - ITEM NUMBER 1 EFF DATE 20040908 YEAR 2004 MAKE CD /DESC 0001 FORD TYPE 02 MODEL CD /DESC S6 E350 VIN INVOICE AMT 0.00 MARK -UP AMT 0.00 ORIG VALUE 24,559.00 WHOLESALE VALUE 19,900.00 BASE MSRP 0.00 TOTAL MSRP 0.00 -------------- ------------- - - -- -- DELINQUENCY DATA ----------------------------- DAYS 11 21 31 61 91 121 TOTAL AMT PAST DUE 0.00 TIMES PDUE 1 0 1 1 1 1 BORROWER BNDRY 11 21 31 61 91 121 LATE CHRG TYPE LTC BORROWER NOTICE N N N N N N .LATE CHRG CODE 1 0 0 0 0 0 ------- -- -------------- - -- - -- BEHAVIORAL SCORING DATA -------------------- - - - - -- SCORE LST CHG DT CUST PROF RO CUST PROF SUBSET O1 17023 CHAMPIOBRO1T0900 BEHAVIOR.SCORE INDEX 686 COLL STRAT PH12PH45-- 00-- 00-- 00 - -00- -0005 AT RISK AMT 0.00 ----------------------- - - - - -- FEE FINANCIAL DATA ------------------------------- FEE TYPE FFD ASSESSED ITD 44.00 PAID ITD 44.00 WAIVED ITD 0.00 CHARGED OFF ITD 0.00 FEE TYPE FRC ASSESSED ITD 72.50 PAID ITD 0.00 WAIVED ITD 0.00 CHARGED OFF ITD 72.50 FEE TYPE FRD ASSESSED ITD 1.00 PAID ITD 0.00 WAIVED ITD 0.00 CHARGED OFF ITD 1.00 FEE TYPE FR7 ASSESSED ITD 360.00 PAID ITD 0.00 WAIVED ITD 0.00 CHARGED OFF ITD 360.00 FEE TYPE FR8 ASSESSED ITD 115.00 PAID ITD 0.00 WAIVED ITD 0.00 CHARGED OFF ITD 115.00 FEE TYPE LTC ASSESSED ITD 28.02 PAID ITD 0.00 WAIVED ITD 0.00 CHARGED OFF ITD 28.02 ------ --- -------------- --- - - - - -- TRANSACTION DETAIL ---------------------------- R EFF DATE POST DATE TRAN TRAN KEY AMOUNT DESC 02/04/04 02/05/04 7001 PRI01 23,674.10 LOAN FUNDING 02/06/04 02/08/04 2813 0.00 BEHAV SCORE UPD 03/08/04 03/08/04 2813 0.00 BEHAV SCORE UPD 03/12/04 03/12/04 8080 00 466.84 REGULAR PAYMENT 04/06/04 04/06/04 2813 0.00 BEHAV SCORE UPD 04/15/04 7011 LTCO1 9.34 FEE ASSESSMENT 04/19/04 04/19/04 8080 00 466.84 REGULAR PAYMENT 05/06/04 05/06/04 2813 0.00 BEHAV SCORE UPD 05/17/04 7011 LTCO1 9.34 FEE ASSESSMENT 05/27/04 05/27/04 2082 0.00 MESSAGE ADD 06/04/04 06/04/04 3606 0.00 CUST /ACCT SYNC 06/04/04 06/04/04 2082 0.00 MESSAGE ADD GENERAL REMODELERS INC PAGE 421 CTL1 48 CTL2 063 CTL3 000 CTL4 0000 ACCOUNT NUMBER 9860 --------------------- ----- -- - - -- TRANSACTION DETAIL ------- - ----- R EFF DATE POST DATE TRAN TRAN KEY AMOUNT DESC 06/08/04 06/08/04 2813 0.00 BEHAV SCORE UPD 06/15/04 7011 LTCO1 9.34 FEE ASSESSMENT 07/07/04 07/07/04 2813 0.00 BEHAV SCORE UPD 07/07/04 07/07/04 2082 0.00 MESSAGE ADD 07/07/04 07/08/04 3811 0000001 0.00 AUTO REPO SETUP 07/07/04 07/08/04 2089 0000001 0.00 MESSAGE DELETE 07/07/04 07/08/04 3030 EFNO101 0.00 SET NONACCRUAL 07/07/04 07/08/04 3030 IDRO101 0.00 SET NONACCRUAL 07/07/04 07/08/04 3030 INTO101 0.00 SET NONACCRUAL 07/08/04 07/08/04 8011 FR701 360.00 FEE ASSESSMENT 07/08/04 2013 0.00 ACCT F/M UPDATE 08/06/04 08/08/04 2813 0.00 BEHAV SCORE UPD 09/03/04 09/07/04 3040 00 16,700.00 AUCTION PRCDS 09/03/04 7047 EFNO1 0.73 DEC NONACC ADJ 09/03/04 3530 EFNO1 0.00 REMOVE NONACCR 09/03/04 7047 IDRO1 34.39 DEC NONACC ADJ 09/03/04 3530 IDRO1 0.00 REMOVE NONACCR 09/03/04 7047 INT01 24 DEC NONACC ADJ 09/03/04 3530 INTO1 0.00 REMOVE NONACCR 09/03/04 7989 PRI01 16,700.00 POST AUCTION 09/03/04 09/07/04 7911 FR801 1 ASSESS DISB FEE 09/03/04 09/07/04 7911 FRDO1 1.00 ASSESS DISB FEE 09/03/04 09/07/04 7911 FRCO1 72.50 ASSESS DISK FEE 09/08/04 09/08/04 2813 0.00 BEHAV SCORE UPD 09/08/04 09/08/04 3815 0.00 AUTO REPO CLOSE 09/08/04 7241 EFNO1 21.16 DECR UNEARNED 09/08/04 7241 IDRO1 537.88 DECR UNEARNED 09/08/04 7049 IDRO1 1.16 DECR CYC CUR UN 09/08/04 7285 IDR010002 635.90 DLR RESV REBATE 96.86 CH EARN 539.04 CH UNEARN 09/08/04 7083 7,323.58 CHARGEOFF 09/08/04 3029 INTO1 0.00 ACCR GRP ST CHG 09/08/04 7084 0.00 UNALLOC PAYOFF 09/08/04 2013 0.00 ACCT F/M UPDATE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i- :LLJ-Of FiC; snana HE PROTHOIIO Jody S Smith Chief Deputy 2913 JUN 14 AM & 58 Richard W Stewart CUMBERLAND COUNl'Y Solicitor ':'' " ' " ° '- PENNSYLVANIA Ford Motor Credit Company, LLC Case Number vs. General Remodelers(et al.) 2013-3031 SHERIFF'S RETURN OF SERVICE 05/3012013 03:48 PM- Deputy Ronald Hoover, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Tracy Goodhart, Secretary who accepted as"Adult Person in Charge"for General Remodelers at 184 Texaco Road, Silver Spring Township, Mechanicsburg, PA 17050. RONALD HOOVER, DEPUTY 05/30/2013 03.48 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Tracy Goodhart, Wfe of defendant,who accepted as"Adult Person in Charge"for Michael S. Goodhart at 184 Texaco Road, Silver Spring Township, Mechanicsburg, PA 17050. _ RONALD HOOVER, DEPUTY SHERIFF COST: $5530 SO ANSWERS, 7 May 31, 2013 RONNY R ANDERSON, SHERIFF Lloyd S. Markind, Esquire (ID #52507) Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: F1101117 FILED -OFFICE CE OF THE PPOThONOTAR 20I4OCT -9 AM II: 56 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC Plaintiff vs. GENERAL REMODELERS INC AND MIKE GOODHART Defendant : No. 13-3031 CIVIL : TERM : CIVIL ACTION PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, Ford Motor Credit Company, LLC , and against Defendant, GENERAL REMODELERS INC AND MIKE GOODHART , for failure to answer or otherwise respond to the Complaint. 1. The Complaint was served upon defendant on by Sheriff. A copy of the Proof of Service is attached hereto as Exhibit A. 2. A Notice Praecipe to Enter Default Judgment was served upon Defendant by regular mail on August 27, 2014. 3. A copy of the Notice is attached hereto as Exhibit B. A copy of the Certification of Service of the Notice is attached hereto as Exhibit C. Pursuant to the Notice, Defendant had 10 days in which to answer the Complaint. The ten (10) days expired on September 6, 2014. Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Assess damages in the principal amount of $7,323.58, being the amount demanded in the Complaint, together with contractual attorney fees of $1,871.26 and interest of $6,238.82 for a total of $15,433.66, together with costs of this action. Date: si*I4 RKIND LAWOUP, P.C. Lloyd S. Markind, Esquire (ID #52507) ATTORNEY FOR PLAINTIFF 4/6. 5-0 eci C .2235-417 p 3gati Mbce ,4 vZeoa Lloyd S. Markind, Esquire (ID #52507) Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: F1101117 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P CIVIL ACTION - LAW (Rule of Civil Procedure No. 236) Revised Ford Motor Credit Company, LLC Plaintiff vs. GENERAL REMODELERS INC AND MIKE GOODHART Defendant : No. 13-3031 CIVIL : TERM : CIVIL ACTION FILE0-0 FICE THE PROTHONOTARY 2014 OCT -9 AMM 1156 COUNTY NIA CERTIFICATION OF NON-MILITARY SERVICE Lloyd S. Markind, Esquire, hereby certifies and says that he is the attorney for the plaintiff; that he is authorized to make this certification on behalf of plaintiff; that the above-named defendants GENERAL REMODELERS INC AND MIKE GOODHART reside(s) at 184 TEXACO RD, Mechanicsburg PA 17050; and that the defendant(s) GENERAL REMODELERS INC AND MIKE GOODHART is/are not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Affidavit also certifies that the address of the plaintiff is 1335 S. Clearview Avenue, Mesa, AZ, 85209. I verify that the foregoing statement of facts are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA. C.S.A. 4904 relating to unsworn falsifications to authorities. Date: MARKIND LAW GROUP, P.C. Lloyd S. Markind, Esquire (ID #52507) ATTORNEY FOR PLAINTIFF Department of Defense Manpower Data Center Status Report Pursuant to Servieenterabets. Civil Relief Att Last Name: GOODHART First Name: MIKE Middle Name: Active Duty Status As Of: Sep -02-2014 Results as of : Sep -02-2014 07:28:00 AM SCRA 3.0 Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Oi Actluei15diVbn:Active;buty:Status?bete AcBvo bitty Status bate -.: Active tufy StatuDule : Ac6ve Csty Es6 Oslo:.:. .: - : : ' Status : ' : so rvtce Qomponont NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 I;e$ halve buly:W'ilhlr 36x.baYsot AcBvo bitty Status bate .:.: .. : Qr40rNotlicOliyrt StOrt:l?ale': :.,.:. Act{vp Puty.$tart Pate :.:>:: :.:::.: . ..:.:.:. AGnve 4utyEnd Qate : :;:: .::::. ...:.:.: ..:. Status .::::: .:.:.; SerAceorn 0 ......... . NA No NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Dale Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 114Memheiorttis/Nerdlali Mos INetifedofaFutured all-tipisAetfvetlutyuryAdike.buryStoutsbate .:.: .. : Qr40rNotlicOliyrt StOrt:l?ale': ..::.: : :.: Order Notilcatiop End:Oslo <>: -::f: $tot tb. .:.:.: .. :.: :.:. Service CrOMOonenf NA NA No NA ThIs response reflects whether the Individual or his/her unit has received eady notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the offidal source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers 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 only 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 was on active duty for the active duty status date, 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:llwww.defenselink.miVfaq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(1) 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 Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (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). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(dX1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: DCED68AEUOABX00 Exhibit A Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY bt Ford Motor Credit Company, LLC vs. General Remodelers Case Num aer 2013-3791 SHERIFF'S RETURN OF SERVICE 07/05/2013 03:04 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Comp aint & Notice by handing a true copy to a person representing themselves to be Tami Goodhart, wife of owner she handled business matters of company, who accepted as "Adult Person in Charge" for General Remodelers at 184 Texaco Road, Silver Spring Township, Mechanicsburg, PA 17050. '�1 A IE DIMA , DEPUTY SHERIFF COST: 539.30 SO ANSWERS, July 08, 2013 RONNY R ANDERSON, SHERI F (c) CourrySui;o Sheriff, Teleosol: Ino. Exhibit B Lloyd S. Markind, Esquire (1D#52507) Markind Law Group, P.C. 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 (856) 616-8710 Attorney for Plaintiff File No.: F1101117 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW (Rule of Civil Procedure No. 236) Revised Ford Motor Credit Company, LLC : No. 13-3031 CIVIL Plaintiff : TERM vs. : CIVIL ACTION GENERAL REMODELERS INC AND MIKE GOODHART Defendant NOTICE OF INTENTION TO TAKE DEFAULT TO: GENERAL REMODELERS INC 184 TEXACO RD Mechanicsburg PA 17050 MIKE GOODHART 184 TEXACO RD Mechanicsburg PA 1705 DATE OF NOTICE: August272 10 4 IMPORTANT NOTICE 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 (10) days from the date of this notice as set forth above, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST CARLISLE, PA 17013 717/249-3166 Disclosu re ind La Lloyi S. Markind, Esquire Attorneys for Plaintiff You are hereby advised, pursuant to the Fair Debt Collection Practices Act, that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. Exhibit C 'Lloyd S. Markind, Esquire (ID #52507) `Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: F1101117 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW (Rule of Civil Procedure No. 236) Revised Ford Motor Credit Company, LLC Plaintiff vs. GENERAL REMODELERS INC AND MIKE GOODHART Defendant : No. 13-3031 CIVIL : TERM : CIVIL ACTION CERTIFICATION PURSUANT TO Pa. R.C.P. 237 The undersigned hereby certifies that on August 27, 2014 I mailed a true and correct copy ,by regular mail, of NOTICE OF INTENTION TO TAKE DEFAULT to: GENERAL REMODELERS INC 184 TEXACO RD Mechanicsburg PA 17050 MIKE GOODHART 184 TEXACO RD Mechanicsburg PA 17050 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. MARKIND LAW GROUP, P.C. Lloyd S. arkind, Esquire (ID #52507) ATTORNEY FOR PLAINTIFF Lloyd S. Markind, Esquire (ID #52507) Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 `Cherry Hill, NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: F1101117 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC : No. 13-3031 CIVIL Plaintiff : TERM vs. : CIVIL ACTION GENERAL REMODELERS INC AND MIKE GOODHART Defendant TO: GENERAL REMODELERS INC 184 TEXACO RD Mechanicsburg PA 17050 MIKE GOODHART 184 TEXACO RD Mechanicsburg PA 17050 Date: September 25, 2014 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Confession of Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Markind Law Group, P.C. Lloyd S. Markind, Esquire at this telephone number: 856-616-8710