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Supreme Cour "t of 'Pennsylvania Courtf'ofXo�mmo leas For Prothonotary Use Only: �. Cvil�` o Sheet #� o I Docket No: ri CUMBERLAND l`¢ C ou n t y 13 - 3 �R� ��� ► I�rm ,�. 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 Complaint 0 Writ of Summons (] Petition Q Transfer from Another Jurisdiction 10 Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: C FORD MOTOR CREDIT COMPANY, LLC GENERAL REMODELERS T Dollar Amount Requested: Swithin arbitration limits I Are money damages requested? ll Yes 0 No (check one) []outside arbitration limits O N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? 0 Yes IX No A Name of Plaintiff/Appellant's Attorney: LLOYD S MARKIND 0 Check here if you have no attorney (are a Self- Represented JPro Sel 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 0 Intentional 0 Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection: Credit Card IO Board of Assessment 0 Motor Vehicle Ix Debt Collection: Other Q Board of Elections 0 Nuisance CAR LOAN 0 Dept. of Transportation 0 Premises Liability 0 Statutory Appeal: Other S 0 Product Liability (does not include � Employment Dispute: F' mass fort) Discrimination 0 Slander/Libel/ Defamation C El Other: 0 Employment Dispute: Other � Zoning Board Other: T I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS Toxic Waste 0 Ejectment 0 f Common Law /Statutory Arbitration B Other: 0 Eminent Domain /Condemnation Q Declaratory Judgment 0 Ground Rent 0 Mandamus Landlord/Tenant Dispute 0 Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 17, Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental 0 Partition 0 Replevin 0 Legal 0 Quiet Title 0 Other: 0 Medical Q Other: 0 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.: F 1101176 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC : No. 13 ~:5r1Q og 1 V ► l b erm ,- Plaintiff TERM �3 - C O V : �'"' CIVIL ACTION C GENERAL REMODELERS AND MIKE GOODHART Defendant v r> 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 *1o3. PO C# 1yq17 9f 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 D1NERO 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.: F1101176 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 V. I I GENERAL REMODELERS AND MIKE GOODHART I Defendant(s) CIVIL ACTION COMPLAINT 1. Plaintiff, Ford Motor Credit Company, LLC , 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 , is an individual who resides at 184 TEXACO RD, MECHANICSBURG PA 17050 -4626. 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 SEPTEMBER 4,2003, the Defendant(s) entered into a written Motor Vehicle Retail Installment Contract, Account Number 48063000000035364008, (hereinafter referred to as the "Contract "), for the purpose of obtaining financing in the amount of $30,886.07 at an annual percentage rate of 6.25 %, in order to purchase a certain motor vehicle, 2003 FORD S -DTY F -250, 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 $602.15 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 JANUARY 19, 2005, 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 $17,500.00, however a balance of $9,713.62 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 $6,095.08 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 $2,480.72. 12. The total amount due and owing at the date of this complaint is $18,289.42. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), jointly and severally, if more than one, in the amount of $18,289.42, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. SKLAR RKIND Date: June 11, 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 McKe , 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. BY:r� Representative of Plaintiff, Ford Motor Credit Company, LLC DATE: J 1 201 48063000000035364008 Our File No.: F 1 I01176 GENERAL REMODELERS AND MIKE GOODHART Exhibit A PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE 09124/2003 ¥ ( C a � red G aa�� Name LE and A do less (including County and ZIP COW) CREDITOR (Seller Name anti Acidness) GENERAEMODERS ` MIKE GOODHART MCCAFFERTY FORD ✓ 628 NACLAY ST 6320 CARLISLE PIKE HARRISBURG PA 17110 MECHANICSBURG PA 1.1050 SEP 2 5 2003 You, tree amr (and co�euyer Nary), may buy the Mich dsscrawd below for cash a on Credit. The 'Cash Price shown below to the cash fvtn d the .hlcl& The ?old 8Ye Pmoe' shown below la me oredN Prise. Dy el ff ing this contract you choose to buy on cede radw ee egrwrmi nts on the hurt sad back of this contract NewNsed Year and Make, I Model I GM it Tuck Vehicle Idemiticalion Number I Use For Which Purchased NEW 2003 )m Poraonal 13 Aglcui urral FORD TRUCK -OTY F -25 ❑ Commercial INSURANCE Trada•In s N/A S N/A YOU MAY OBTAIN VEHICLE INSURANCE Year and Make Gross Allowere® Amount Oatng ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE. _ .. ... ..._. f 35751 .48 (1) YOU ARE NOT REOUIRED TO OBTAIN 1. Cash Price ..,,....._....... ................... ._ ............._._..._._......._. CREDIT LIFE, CREDIT DISABILITY AND 2. Down Payment OTHER OPTIONAL INSURANCE. THIS Third Parry Rebate Assigned to Creditor ....... ......... ......... $ 5000.00 CONTRACT WILL NOT INCLUDE THEM Cash Down Payment .......... .„ ...... ....... ..... ............... ._.......... $ 200I1 UNLESS YOU SIGN AND AGREE TO PAY Trode•In $ N/A S _.A /A. s.. N/A THE PREMIUM. ob end make QT AlwrMal /mount Oennp Total Down Payment ............ ..... f 1000_[M_ (2) THIS CONTRACT DOES NOT INCLUDE ........ "' °"•" •"""" °""""""""' °"" LIABILITY INSURANCE COVERAGE FOR 3. Unpaid Balance of Cash Price (1 minus 2) „, „, „.......... ......_........ $ 28751.46 (3) BODILY INJURY AND PROPERTY m 4. Amounts paid on your behalf (Seller may be retaining a portlon of these amounts) D AMAGE CAUSED TO OTHERS. To Insurance Companies for Credit Life insurance (for term of contract) ....... ...... .... $ NIA Credit Disability Insurance (for tern of contract) ........... $ N (A N/A (TemH/B_Monthe minimalan KJe To Public OfBelsls (I} f li cense ($1Q...Q�)� title ($ 7,2_ 50 1„ 8 ❑ Credit Ufe N/A registration ($ 53 rl ) fees S18 Insurer (u) for riling fees $ 5.00 ; $ N (1. for taxes (not In Cash Price) $ 1850.09 $ 2040.59 Premium Insured(s) To N/A for $ N/A To N/A f $ N/A Signature To MCCAFFERTY FORD b r 00C FEE $ 55.00 1ONLIN 94.00 TO A t $ N/A Credit Total ........................... _ ........... . .................... ..._ ............................... f 2134.50 (4) ❑ Disability N S. Amount Financed 3 plus 4 ........ ..... .... ._ ............................... . $ 30886.07__ 8 Insurer FEDERAL TRUTH -IN- LENDING DISCLOSURES $ Premium Insured ANNUAL FINANCE Amount Total of Total Sale Signature PERCENTAGE CHARGE Financed Payments Price RATE The dollar amount The amount of The amount The total cost The cost d ur the creek will credll provided to you wit have of yaw yo purchase on YO cost you or on your Petri when you cre61, ❑ Nt. ),(IA credit as a yearly rate behoN hsva made all Including your scheeWm g �ow�npg ye Other Optional Insurance Term of 6 % $ 5242.93 $ 30886.07 $ 36t129MDO s 4319 � b!A insurer $ Premium Payment Schedule Number of Amount of Each when Payments Ina ure .__._. X)�) PayRleflte Payment are due Credit Life end Credit 01"bi Th Insurance are Your paymem schedule 59 f 602 1S (,,, N s e a m) for the term m nee contract e amount and will be: 1 Glal f 602.15 11108/.2003r� y� ��Y ” in a nobles or agreement You must mews the vehicle. If a change Is shown below the Creditor will try to bud the coverages ;Iv"ed for the term shown. Coversggssss will be based an the cash value of the vshleN at time of rote, but not more than the Ihntta of the policy. Prepayment: 11 you pay off your debt eery. you wan not he” 10 Pay a penalty. C Comprehensive ❑ S NSA 0eds Lat Payment 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 S50.00 whichever Is less. ❑ Fire- ThoNCombueed Additional coverage Security mtomt: You are giving a security Interest in the Vehicle being purchased. ❑ Towing and labor Contract: se Please e this contract for addit nail Info l before an � �t6 e�ndyment ❑ Term N.fA _ Months (Estimate) default the right to require repayment at t Premlum s N /A prapaymant penalty. N you do rat meet your contract obapadont, you may lose the vahkla that you are finger g cider die coalmot as wag n both pons and goods put an rive vehicle and money or goods received for ua vMtcie. ❑ Debt Ca waiver Addendum (optional) NON -MODIFICATION DISCLOSURE It the cox B cracked you hsva purchased a data lunge in this Contra must in writ and sig ned by you aril the G cancellation g red too *I INS co ver a ge . The to U Any n . 1 �1. � ���nt0 opson:t and U not elR to e leln cre The tame ,ffi& v`^+” 'Y - r>. eUYER: x and 10T d t h e d ebt dda nncn whic n wai I nto ere set g q, form In d seeded a price which t Ineorpo ion SIGNS X SIGNS wooer Is S fo on dis f contt d in the IItte cancellation 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 Oo not sign this contract In blank. Boyer You are entltled to an exact copy of the contract you sign. Keep it to protect your legal rights. Buyer (and Co-Buyer) acknowledge that (1) before si rein this contract, Buyer (and Co- Buyer) received an rev ewe a rue Program No. an costpletely filled In copy of this contract and (11) at the OUESTIONS4 time of sfpnlnq this contract, Buyer (and Co-Buyer) reeeWe�r a true and completel fill In copy of this ntract. X ER X BU SIGNS (00) BUYER S By signing below, the Sonar accepts this contract. It no oiler Assignee 1e seamed in a aeparete PLEASE CALL US 1-600 -727 -7000 asstgnam aaachad to thus contract, the 80Nw gns tl to FOK t9 relit company Or r m MCCAFFERTY FORD Visit us at wtmY.tordcreditcoftl By 03-001 a 1tW7E1 ,af 03 (PnNeo. dEoeu mar M t SEE BACK FOR ADDITIONAL AGREEMENTS PA ORIGINAL t 1 t t i �� a � a�� ° a<W� € 5• �� °. o ���l.sx l �� 8 ���g � � €Sa �$ ^$ I a aa8 �_£§ ge 46n'8 t aZ> m< 1 a�• ��' '�� ��$_ � R gs gg �t� =� � ¢< s a sc s$ g €in Hugo Q YW1n ° a�afrfr s o ,s I �g , v I mo y g • . °ma¢�o a a �g� g 6aC 9ie I'? g 3 I I S S bs g g V O N = e�g��fi 5 � {� oo °� �� �g a. � I ag @a F °$�_ §p =�a Lf a g yc y��WZa B g B ° e6F$ fi -ggP 8.$ n� > a88n ?ao � a ��g 8� � Y• � °'3 � 6E g �8 8 F �W i F ° =aa >S 5� � a $ffi ° - a�u a i i €` ��a�6. 1 I� SS '�$j a•�gS.gs�a�s��� �sa gg� ��$g��� ���� s� & < `�� =�W'y s§ €3 d g l �gs� 4 ���� � g � t I �e � E p ��' i ll � :y �8 LS as Sv 6 8§ F Fzs�acmm 3 dg ot¢ m o � g R $ ayy5 .or aS o k oo umcz o ° � RT €gg I I u .a n °nl $Ql� F $ $ g 2u t p o 66 $ g Q g H 7c 1 i � MEN a o - s .8' Spa Mp ig s a g 5g Es g s.9 0 �$ s��ts LP Ek �gt i F 5 R 5 L E SY � .2 Y c 80 � � � S"�I P gjsg w &` s ssg Y S I $ 3 rg p 8 $$ gS�� 1i - g i g .6 �& $ IS .i b b' zw - i • 1 a -gi ' s$ S aF€ s s� ri60 i° �o <�� pn� ` `ag'.a It 1 g� pgY g $$ty d.s -5�)aa F a e a g ay t ¢ '�a� I I $ g3 g a L $ g � 1'' ° W ' WU4 a_ 8 a } 1 °_� .4s 8 s 1177 `g as a8g2�e� t i Z V a B c `� ' 5 ' - 2I E ' $ ��� g $ << °g s 8 s auuma ° $ 1 E' �$� $ °Lag € a a $ �� —r � �� ° € °R N � # � 2 tc g a�g ' sg � a e °d •R� uw L p £qs� q 'j �, 555b t P I 1 mSE�T.iSg� E6OEgsS(g� '6 s g v aglgs yB O p U L ap£ S F�bQ .{ a g g ° $ . 1 ah �a p E ss a ag S SS53 E S g II� CCC 88L • a� 8$as as° S $3 a$ � ply g ¢Q % ; BB I A L SS a R gE. �$S� _ ' a 2b °tH A g- 1 s9 H 111 1. § €g °8 S° '� a 1 g ' aS : u7g en's $ e R- a n ° e § t a r as ° ° <m A 1 l if t' ��'i3�- _ _ . 2g1�1$ -N.1 €4 > §o$S�$S s$e?� _ ° �l�g �ifl ra�$`�¢'' da� i 1 I � I I - t ADDITIONAL AGREEMENTS A. Payments and Summary No ice: You must make all F. Default• You will be in default if: payments in U.S. funds when they ari6 duo. you may prepay your debt at any lime without penalty. This is a sifople.interest contract. l . You do not make a payment when it is due; or The actual finance charge you agree to pay will depend on your 2. You gave false or misleading information on your credit payment patterns. The actual finance charge may exceed the application relating to this contract; or disclosed Finance Charge if you make your payments later than 3. Your vehicle is seized by any local, state, or federal ! the scheduled dates or in less than the scheduled amount. The authority and is not promptly and unconditionally Creditor will apply your payments first to the earned and unpaid returned to you; or part of the Finance Charge and then to the Amount Financed. The a. You file a bankruptcy petition or one is fired against you; or j Creditor eams the Finance Charge by applying the Annual 5. You do not keep any other promise in this contract. i Percentage Rate to the unpaid Amount Financed for the actual If you are in default, the Creditor may require you to pay at once time the unpaid Amount Financed is outstanding. If the vehicle is the unpaid Amount Fnanced, the earned acid -unpaid part - of -#ho repossessed, you will not have a right to .reinstate the .contract Finance Charge and 'ail other amounts doe under i;ointtact; `` ` • . unless the Creditor agrees. He may repossess (take back) the vehicle, too. He may also B. Security interest You give the Creditor a security interest in: take goods found in or on the vehicle when repossessed .and.. . hold them for you. 1. The vehicle and all parts or other goods put on the vehicle; It the vehicle is taken back, he will send you a notice. The notice 2. All money or goods received for the vehicle; and will say that you may redeem (buy back) the vehicle. It will also 3. All insurance premiums and'sorvi9e contracts financed for you. show the amount needed to redeem. You may redeem the i vehicle up to the lime the Creditor sells it or agrees to .sell it If This secures payment of all amounts you owe in this contract. It you do not redeem the vehicle, it will be sold. also secures your other , agreements iri this contract. The Creditor will use the money from the sale, less the allowed C. Use of Vehicle - WARRANTIES: You must take care of expenses, to pay the amount still owed on this contract. the vehicle and obey all laws in using it. You may not sell or rent Expenses paid as a direct result of having to retake the vehicle the vehicle, and you must keep it free from the claims of others. hold it f or sale, and sell it are, as permitted by law; - allowed expenses. i "awyers lees ar4 Tegai co s per itfcU by Jaw. -are United Slatcis. exc%pt for up to 30 days in Canada or Mexico, allowed, too. The Creditor will pay you any money left (.a without the prior written consent of the Creditor. If the vehicle Is surplus). You will pay any money still owing after the sale to the of a type normally used for personal use and the Creditor. or Creditor. If you do not pay this amount when the Creditor asks. the vehicles manufacturer, extends a written warranty or the Creditor may charge you interest at the highest lawful rate service contract covering'the vehic wit hin g0 d ays f rom the until. nu--pay. date of -- thTs._tbhfr Y you �tivarranfl - es of • merchantability and f4riess.for a particular purpose covering G. Consumer Reports: You authorize Ford Motor Credit Com- the 'vehicle. Otherwlse, you understand and agree that there pany to obtain consumer credit repots from consumer reporting are no such Implied warranties, agencies (credit bureaus) for any reason and at any time in con - D. Insurance; You must insure yourself and the Creditor against nection with this contract. Ws. or damage to the vehicle. The !Creditor must approve the H. General: To contact Ford Motor Credit Company about this type and amount of insurance. If the Creditor obtains a refund on mount, call 1-800 -727 -7000. Also, you may make address and insurance or service contracts, the Creditor will subtract the other selected changes at www.fordcrecit.com. The law of Penn - refund from what you owe. Whether or not the vehicle is Sylvania applies to this contract. It the law does not allow all of the Insured, you must pay for it if it is lost, damaged, or agreements in this contract, the ones that are not allowed will be destroyed. void. The rest of this contract will still be good. ' If a charge for vehicle insurance is shown on the front, the Creditor will try to buy the coverages checked for the term shown. The Creditor is not liable, though, if;he cannot do so. If these NOTICE - ANY HOLDER OF THIS CONSUMER CREDIT - coverages cost•raore than .theamou tshoum forAnsuranee,. -the � CONTRACT tS` S1;1f3JECT 70 ALL CLAIMS Creditor may buy them for a shorten term or he may give you DEFENSES WHICH THE DEBTOR COULD ASSERT. credit for. the amount shown. If he cannot, buy any insurance, he will give you credit for the amount shown: Ttte"eredit will be 'made' AGAiNST SELLER_ OF GOODS OR' SERVICES .... to the last,payments due. OBTAINED PURSUANT HERETO OR WiTH THE - _PROCEEDS HEREOF. RECOVERY HEREUNDER BY I- late Charge You will have to pay a late charge on the THE DEBTOR SHALL, NOT EXCEED AMOUNTS PAID BY • .. pod;on - of each' payment'rr►ade irioio than ten days late - . 'The - THE -- DEBTOR MERt"ti - NDER. charge is shown on the front. Acceptance of a late payment does not excuse your default or mean that you can keep making Used Motor Vehicle Buyers Guide. If you are buying a used payments -after they are due. The Creditor may take the steps set vehicle with this contract, federal regulations may require a forth in this oontracL if there is any default. special Buyers Guide to be displayed on the window of the 1 vehicle. THE INFORMATION YOU SEE ON THE WINDOW FORM FOR THIS VEHICLE IS PART OF THIS CONTIR NFORMATION ON THE WINDOW FORM OV D ANY CONTRARY PROVISIONS IN OF SALE. A To cause the Seller to sell the vehicle describe this ct o e Buyer, on credit, each i person who signs:tielow as' • a "Guarantor° guarantees the payment or s r ans at ii tt— Buyer fails to pay any money- that is owed -on this contract, each.-one who signs .as a I n . Each Gerson who signs below agrees that will be ' liable lbr ' ' the whole amount owed even if one o r he o signs this Guaranty. He also agrees to be fiable even if:the Creditor • •. does one or more of the following: (a) g e B re Gme to pay one or more payments, or (b) gives a release in full or in part to any of the other Guarantors. or (c) rel s any ecurity. Each Guarantor also states that he has received a completed copy of this contract and this Guaranty at ft time of g. Guarantor Address Gua'r'antor Address READ THIS ARBITRATION! PROVISION CAREFULLY AND IN ITS ENTIRETY - ARBITRATION rbitration is a method of resolving any claim, dispute, or controversy (collectively, a "Claim ") without filing a lawsuit in court. Either .you r Creditor ( "us" or '\ore') (each, a Party") may choose at any time, including after a lawsuit is filed; - to have any Claim related to this con - act decided by arbitration. Such Claims include but are not limited to the following: 1) Claims in contract, tort. regulatory or othery i §e; 2) [aims regarding the interpretation, scope, or validity of this clause, or arbitrabiiity of any issue; 3) Claims between you and us; our mpioyees, agents, successors, assigns, subsidiaries. or affiliates; 4) Claims arising out of or relating to your application for credit, this mtraet, or any resulting transaction or relationship, including that with the dealer, or any such relationship with third parties who do not gn this contract. IGHTS YOU AND WE AGREE TO GIVE UP , eith er . you or we choose to arbitrate a Claim, 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 WHETHER IN COURT, OR IN ARBITRATION X. • BROAD RIGHTS TO DI AR A /YAIL&D E IN A�.A,�4 f, UIT • •• RIGHT TO - 1PPEA4.- THE. DECISION OF AN ARBITRATOR • OTHER RIGHTS THAT ARE-AVAILABLE IN A LAWSUIT lights You And We Do Not Glve U • It a Claim is arbitrated, you and we will continue to have the following rights, without waiving this t 1trati on provision as to any arm: 1) Flight to file bankruptcy in court 2) Right to enforce the security interest in the vehicle. whether r repossession or through a court of tativ; Right to take to ag_I a ction to enforce the arbitrators_ decision; and 4) Right to req�reest t t • _ wrt of law review whether df4 exceeded its auttionty. ither Party must. contact any association below and the other Party to start arbitration. The applicable rules (the `Rules') may be riained from the association. • American Arbitration Association ( "AAA"), at 1- 800 - 778 =7879, or wwwAdr.org; • J.A.M.SJEnd%spute, at 1- 800 - 448.1660, or wNvw.jamsadr.00m; • National Arbitration Forum. at 1- 800. 474 -2371, or www.arb- forum.com. there is a conflict between the Rules and this eontracL this contract shall oovem. This contract is subject to the Federal Arbitration Act U.S.C. § 1 et seq.) and the Federal Rules of Evidence. The arbitration decision shall be in writing with a supporting opinion. We will iy your total reasonable arbitration fees and expenses (not i!iqucling attorney fees, except where applicable law otherwise provides) in tcess of $125. We will .pay the :whole filing fee if we demand arbitration first. Any portion of this arbitration clause that is unenforceable %all be severed, and the remaining provisions shall be enforced. %�%r� �� � ;rtoious oaWx�s mx7 d �m•1i ' . -- -- — — — — — — — — — — — — PERF — — — . --- — — — — — — — — — — — — — — — — — — — — — — — — — — f - Exhibit B SELLER'S COPY/ KE 2005 - 034--160527 9: 05tt 26 16 -•0527 NANKIN AUTO AUCTION SHIRLEYK 6/ 10/2005 1190 L N IR RWD Na�IN eA 175454789 (717) 3571 FAX(717) 655 -tit265 tr� t{!Y 5/31 /2005 5640242 * PAID »~ INV VIN TITLE NO. STATE YEAR MAKE MODEUSUB SERIES BODY COLOR ENG INT INT R N PS PB AC EW ES TOP CC Et 4X TL SRS SI RD 2003 FORD TRUCK Fe5O 4.X4 RE.G PUT SILVER 36 3RY ( D X1 4XL f - I ANN COND: NOIES: ` REPO; 4X4 ¢ RETAIL REPOSS3ESSION I ( 16REEN 1 - - 2 M 'a R,b. f NO : SOS 1 - -- 1 IF CLERK SOLD BY 1LIGHTS1LIGHTS1LIGHTSILIGHTS1 1 I 1 1 : ' 1 M3301 LLL 1 1 1 1 1 SALE f 1SELLERI i 1 1 1 LORYUF�y USE OF OUR PL THE t VEHICLE FFItEBYACiTEET LICENSE NO. TAB T r� A SALE PRICE FORT ABOV IMIED AU TI TN �E T Lnm in THE 13E AND 8116 OF THE ABOVE N!<I+® AUCTION AJa) l0 Ac�Nr ON ttEVl3+st: sme 10D ApR 8S'10 1 4A're�► 1 t�"s = HDIOR CREDIT 4 BUYER PLEASE CHECK ONE MERICAN RD PO 9DX 1732 ❑ CLEAN ❑ ROUGH ❑ AVERAGE 5135195 2 '730 NARBOIO3, NI 48121 (,) (2) (3) u FORD avE NOTICE: • Do not re purchase or finance E R PATCHM , fit► 11772 480630000000900 035364008 without Certificate of title. C (631) 475-1133 L FE • Auction retains security interest in H FMBERT 6l7f'FS vehicle until good funds received. A I= ID METER DISCLOSURE STATEMENT Section 580.5 Disclosure form S DERAL 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 ❑ (1) 1 hereby certify to the best of my knowledge the odometer reading L i gt�t s Legends reflects the amount of mileage in excess of its mechanical limits, R PRnrrEO T ER) VU R•'CEE. ❑ (2)1 hereby certify that the odometer reading is NOT the actual mileage X -WARNING - ODOMETER DISCREPANCY PU ENS l (BUY DUST $* NEDCOPYOFODOMETEROMLOSURW ESEMENT (FRW& BACK OF E IF TRLE) TO TRANSFERDR (SELLER) OR BE SUBJECT TO CIVIL a CRINNIALP U0MFO ESANDJAILTnAUn1014" MAd 1 FORD foIOR CREDIT CGi'Pt ANY AUCTION ASSUMES NO RESPONSIBILITY NOR GUARANTEES STATE THAT T ER HE ODOMETER NOW READS SELLING THE ACCURACY OF THE ODOMETER READING _ MILES (NO TEMHS) AND TO THE BEST OF MY PRI S 17.500.00 DOCUMENT NOT VALID FOR EXPORT KNOWLEDGE T MILEAGE IT REFLECTS THE ACTUAL MI AGE OFT14EVEHICLE $ F9C I JJ DESCRIBED HEREIN, UNLESS NOTED DIFFERENTLY ABOVE. �� For value received I hereDr sef, assignor transfer the vehicle described on this dowmem FEE 325. 00 to the purchaser named left 1`j X r � AD1 2 TRAN ROR'S SIGN it (SE X tJ� �� AID $ BUY NOT A RECEIPT OF PAYMENT PRINTED NAME OF (SIGNOR) NET 9t 17,825.00 Manheim u 3/11/2005 , YEHICLE CONDITION REPORT 47295 MAMIN AUTO AUCTION •CUS- TOE&A ;: , , FORD MOTOR CREDIT COMPANY ' STOCK 1190 LANCASTER ROAD ACG7,N1= ' '�''' MANHBIM, PA 175459789 ACCT =1VIl�`IVQ _ UNR 717.665 -3571 i INSf?ETORa 3/11/2005 VIN f • AlZRl,V D T -,: 3/11/2005 118294 T. DE CRIPT!,ON 2003 FORD WUCK F250 4X4 PEG 4x4, SILVER w/GRY Vinyl MECHA!"4 - L '� 5.4 Liter 8 Cylinder as, u omatic, Pwr Brakes, Pwr Steering ' j4 t ''r 28,706 MI, 6 DG, Digital R�taro, Cassette Tape E�Ujp': j j 7 : AC, Cruise, Tilt Wheel, Air Bags/Dual, Steel Wheels, Regular Dash, Own Manual, EPA Label, Wrnty Book .I I s 3;d .•'i 's r u• 'ii. 'if `rM 9 agaxlR� &::•f' z9L•c�•.'' ,':�.,i_,; -t; .a. i. �,. . •. ,. ;,. 9 01 � • �•• ., �,:•�• •�:a• -•,�. . � •• c i(• '�x�;. _. '•ebbr`�:,.�_��_• � ,f:ab0%.•..:z�ll�_ �aR�r:' i ',' ^�'{ i r � .�R; , 3 t , F�5 `,� .. �;-�.' .m; 4!:, �• m• -i. rt� �} f- r. r �?!:. • � �• ^, ,.kr ; �:. "f r „ . a ` `� '.t+ F'BIf •' r ' i.+ '.�gn�lW. �P l �s ?:6. 4. m » : . .: 6 �M3 v'�i_�lS `:: y.•1!�.Wf °+si.. {..tPes.' :'. <'S', :., SC08t6' ' NON CHARGEABLE (Normal Bear & Tear) Cl Hood Dent V to 2 Repair 1.0 3.6 151.80 ❑ Roof Multiple Dents 6" to 7" Repair 1.0 3.2 138.60 i ❑ LF Fender Ding PDR/1 PDR 45.00 ❑ LF Door Multiple Dents GR 12" Repair 2.0 3.4 178.20 ❑ L Qtr Panel Multi Dents 4" to 5" Repair 1.0 4.1 168.30 E3 Qtr D � A ell Pinstripe Add'l Damage Remove/install .2 6.00 18.56 ❑ Tailgate Replaced ❑ R "B" Pillar Prev Repair ❑ R Cab Side Multiple Dents GR 12" Repair 3.0 2.6 184.80 ❑ LF Seat Cut Sublet 80.00 ❑ Oil Dirty Replace . Parts 98.56 Labor & Paint 24.9 Hrs. 821.70 ' Mechanical .2 Hrs. 6.00 PDR 45.00 NON CHARGEABLE DAMAGE TOTAL: 971.26 CHARGEABLE (B=ees Near & Tear) O Tailgate Poor Repair ❑ RF Door Poor Repair ❑ R Qtr Panel Poor Repair ❑ R C ab Side Poor Repair CHARGEABLE DAMAGE TOTAL: E3 Tailgate Emblem Add'1 Damage DEDUCTIBLE Remove/Install .4 12.00 46.20 Pam 46.20 Mechanical .4 His. 12.00 DEDUCTIBLE DAMAGE TOTAL: 58.20 TOTAL DAMAGE Color Codle... uone/none Parts 46.20 Driveable ...: Yes Labor & Paint .00 Int Cond...: Dirty, OK Odor Mechanical .4 Hrs. 12.00 Cert. Cared..: PDR . Cyberlot .... Air Brush . 0 0 Oil Cond. ...:Poor/Dirty DAMAGE TOTALS: 58.20 I - Page 1 /Cont. , O$IGnUL 3/11/2005 Nbnheirn( VEHICLE CONDITION REPORT . _.. ,_.. 47295 I MAMI14 AUTO AUCTION ''•,'Ct�SFOMER asp FORA MOTOR CREDIT COMPANY STOCK 1190 LANCASTER ROAD L AW-: MAIM, PA 175459789 .:A'CCT UNK 1. S daft?, 717 - 665 -3571 �c;;: RBEC 3/11/2005 V(N. 6`;� n.r,,. 3/11 /2005 118294 /^► r.. DCRIPT ON ' " : 2003 FORD UC 50 4X4 REG XL 2P 4x4, SILVER w /GRY Vinyl MCy� 5.4 Liter 8 Cy ' r Gas, Automatic rakes, Pwr Steering M10E�4 - "' 28,706 MI, 6 DG, Digita R4 Q1Q Cassette Tape FQ(�jpjd(Ejl ' AC, Cruise, Tilt Wheel, Air Bags/Dual, Steel Wheels, Regular Dash, Own Manual, EPA Label, Wrmy Book ;z .: r a.r c ri; :El. ui "•''e.�I1:t,. ; F;.. •: ^gs.�1, s'�. v :'; IAADOf- ''i !:.; +€: f f per... '� + r :.r . ; :. . ., - r I' 4 L$..r ` '.�? •, �.I � 1 � X'.�. •r' . f.,.e Y�' �:S dYft�.0 (J' Iy�� � Yi• 4 p' ?tit+,r, :Q' :'y`:!•'`i�.... '". . , •s Fs 1•: r�5. •`!' '`� "`•''...s ._u. •.1G8 �.i Ys,i;:. 1'i7 x:r;,OSf6_ . PdltI185Q11(l�M: ~,�' ,OdMCQeTpps . k: et i� � •..��, l8�011,•� '�-:� „t•' •e.. �;. C'.t�r Keys ........: Mst 1 Trk N Spr N Val N Rem N Iuf N Tires.......: LF 6 GENERAL 235/85RI6 LR 5 GENERAL 235/8SR16 RF 6 GENERAL 235/85RI 6 RR 5 GENERAL 235 /85RI6 SP Puel bevel..: Empty service .....: Scheduled Maint. -T Date- Mileage - Location - category Code..: UNK I i Grade Z, Ron gn Title Received......: Acceptance Date: Account Signature: Date: Detail Fees Not Included. Page 2 i Date: 6/15/2005 GENERAL REMODELERS Customers Name 1 84 TEXACO RD GENERAL REMODELERS MECHANICSBURG, PA 17050 -4626 Account Number MIKE GOODHART ao08 184 TEXACO RD MECHANICSBURG, PA 17050 vehicle Identification Number If STATEMENT OF SALE Account Number. 3 6384008 The foibwhg property has been sold. YW MAKE mow 2003 FORD F250 Gross balance owing on your contract (1) 28,894.12 Deduct: Finance Charge Rebate (2) 0,D0 Balance owing prior to sale (3) 28,894.12 Deduct: Gross proceeds of sale (4) 17,500.00 Balance less gross proceeds of the sale (3-4) 6 $9,394 Add: Expense of retaking and staring, and any atbomays' fees allowed by law, and expenses of reconditioning and selling. (8) $ 319.50 Deduct: Insurance Premium Rebate (7) 0 Other: U (8) 0 Deficiency (9) 9,713.82 Surplus (10) Deduct.. Amounts paid on subordinate liens {11) 0 Adjusted Surplus (12) The supluslDef olencywit change based on monies received by us (credits) or additional allowed expenses & Interest 0 Surplus Any surplus shown on line 12 will be paid to you, 0 Deficiency The sale resulted In a deficiency. Immediately remit the amount shown on fine 9. Uncollecteble 0 Deficency We cannot collect the deflolency shown an Ilne 9. You are not liable for this deficiency. Bankruptcy 0 Surplus The Surplus wil be paid to the Bankruptcy Trustee for distribution in compliance with federal bmivuptcy law. SenWuptcy X + Deficiency The deficiency wfll be handled in compllance with federal bankruptcy law. 0 Paid Surplus The surplus on line 10 will be paid to you. ..��r.�..`� For additional Information cell at write: Na*wW Recovery Center PO Box 6508 Mesa, AZ 6508 (8D0)732 -2284 FFNA 11990-M JUL 01 PREVIOUS editions may NOT be used OI'd OEEE 13C213Sd dH WW09:01 S002 Si unC Date: 6/15/2005 GENERAL REMODELERS Customer's Name < T84 TEXACO RD GENERAL REMODELERS MECHANICSBURG, PA 17050 -4626 MIKE GOODHART OL 94008 Account Number 184 TEXACO RD MECHANICSBURG, PA 17050 Vehicle Identification Number STATEMENT OF SALE Account Number_ 35384DOS The f0110*1119 property has been sold. Year MAKE Vehicle Identiik atl n —Numbs 2003 FORD F250 1FTNF21L33ES76170 Gross balance awing on your contract (1) 26,894.12 Deduct: Finance Charge Rebate (2) 000 Balance owing prior to sale (3) 26,894.92 Deduct Gross proceeds of sale (4) 17,500.00 Balance lass gross proceeds o` the sale (3-4) (5) 9,394.12 Add: EMenea of retaking and storing, and r3ny attomeys' fees allowed by law, and expenses of reconditioning and selling. (6) 319.5 DWuct: Insurance Premium Rebate (7) 0 Other.. 0 (8) 0 Deficiency (9) _9,713.62 Surplus (10) 0.00 Deduct: Amounts paid on subordinate liens (11} 0 Adjusted Surplus (12) 0.00 The supluslDeficiencywlll Change based on monies received by us (credits) or additional e110wed expenses & Interest 0 Surplus Any surplus sham line 12 will be paid to you. O r ven Deficiency The sale resulted Ina dwkiency. Immediately remit the amount shown online 9. Uncollectabie 0 Deficency We cannot collect the deficiency shaven an line P. You are nc: liable for this deficiency. Bankruptcy 0 Surplus The Surplus will be paid to 1hsBankruptcy Trustee for dishibution In compliance with federal bankruptcy law. Bankruptcy X Deficiency The deliciency will be handled In compliance with federal bankruptcy law. 0 Paid Surplus The surplus on line 10 will be paid to you. For additional information call or write: National Recovery Center PO Box 6508 Mesa, Ag 8521x -8508 (80D) 732.2264 FFNA 119W411 JUL 01 PREVIOUS editions may NOT be used T T -aI OEEE 131783Sd dH WHOS =0T SOOZ ST urlr 7003 2260 0005 5795 6447 Fad Motor Credit Corapaoy P.O. am 3076 cotomw MD 21ots-ilam j- 800 677 0 130 oata on 03/1112000 I" alf contract o a 03f1G/.t0ab OBI2aRDai ACOount Nam Empr (2 Re MIKE GOODHART DESCRIPTION OF PROPERTY 1a4 TEXACO RD Yew IYew MECHANICSBURCi, PA 17060 1626 20M FORD C] used r F2b0 4X4 NOTICE OF OUR PLAN TO SELL PROPERTY era have your property described above bacauae you broke promises in our agra meat. El PAIYATE SALE VA wilt "I the prapely dreamed taboo, at 13 PUBLIC SALE We Hill all the props fly described above at pU:ft prtrale ale somdme after 16 days tom Na the 1) sk of No ssls to Its Ngihat bkWw an ttw data bat'v far any rdiourm and shorn above unless redeemed by you prior to such sal,. deb). The We era be (hold n falowe: Data d aW foal of sell Plan of era You mry atbnd the tats and bring bidders if you want. NOTICE OF REP033ESSION The property it presently stored at Ben Re--EX 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 got yow property b** pay us this amount byornhllsddhatkor permitted bylaw) will reduce the amount you awe. If we get mm" ordar belom the rilede Is 00W. less honey than you owe, you! still awe us the difference. If Unpaid Baatoa s a7 2aae4 we get more money than you owe( you will gist the extra money, Pus coda: R roo Pee° S 120'00 unless yve must pay It to someone else. 3 s You can get the property back at any time before we sail It by Put late charges s 24.08 paying us the full amount you ogre (not just the pest due LmFhencs Charge Rebels s payments). Including our expenses. See How To Get Your Lwa Insurance Prernun Rebak i Property Back for an Itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number TOTAL s 27019A2 above, (Pus ewnses t cwW if deaut et dhrdnu of tapaaaaton ahtcrsdad If you need more Information about the sale call us at the l8" a nd left rebale ceatiedo rthwdauOfINSnala.) Your rfir tefephone number above, or wile us at the address above. EAR Anaer0*yaWanaltlgotitbackckanyt ice at If you want us to explain to you In writing how we have figured Ifyou clo vii if you do, Wert three no Atrther claim an N. But the longer you watt, tit» the amount that you owe us, you may call us at the telephone ml» coats 0 -kmktp repary you may havato pay, number above, or write us at the address above and request e N you Ism any questwm abort IN*, plan call us. written explanation. We are sendirg this notice to the following people vMo have an Interest In the prcpedy described above or who owe money under your agreement: 1) The buyer and any cobuyer nomad above; 2) Arty dealedodglnal creditor named below, 3) If there am other people, they are named on an ettechmem seat with this notice. The property has beat (or wil be) returned kr. LWer our tore anent with your deatcraigins creditor, the dameft igMa creditor is to so prop" and pay you any money kn over. iryou ore rroney Or the sale, you thin puny 0 to the dntahbriginei aeiitor. PERSONAL PROPERTY: Any pgrWnl property round in the vehicle may be reclaimed by yes within the rod 50 days or, In a toordence with We ton, by contesting this curse. Thereafter, an oveoul Vaperty shell be disposed ofacc nasty. Creditor has oast rut k Its qualified i termeBary (of Exchange, LLC) Its dghle (but rot Its obigaaona) Wet respecito the eels of each vaNds Itafad above. PAYMENTS: All pWftrrs to us must be by cartilled cluck or many ordw. MILEAGE DISCLOSURE: If you are oware Rut the mileage ranaoled an the veMane odanabr ls rot oocutate fa any maaat, plemse contact us so anon we can sacuratey report the vehlemi mreege. INSURANCE Rlrif -TS: If you tlmV Yard to or yeir property back of the trawan st canperhy ar the deelw/orfghal weditortamab aurelthat any huurahce has ban canaMd. You have a right to gat crWt for M p emium refunds. FFNA 1'•88831 Jar 02 PleNea ed8bbe may NOT be used a unoonw Prtrq,o In u.sA. CUSTOMERICUSTOMER FILE -Cl OEEE 131783Sb3 dH Wd� =21 9002 91 JeW 7nQ� 22ho a 5795 Faro Mew Ortem Gotetipesy 6 4 3 [ P.O. B" JIM cobmbia, Wp 2181;S.M I- SOM774D'1l0 oGigaRG Gseoaion 03/1'112006 e .s or co asr 1612006 OW24MOS AcccuM N 098 mJY GENERAL E GENERAL REMODELERS kttE SCRIP T 184 TEXACO RD a OESGRIPTION OF PROPERTY MECHANICSBURG, PA 17050 Maw 2663 FORD Used TMIcts MEN] ""a" an valexpowwoommo NOW . , F260 4X4 NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described oboe because yoo broke prat. u In our sgrreemeed. © PRNATE SALT— We vfill Bell the property descrmedsttove at ❑ PUBIL SALE WO VAI feral the property demLKbod a bove st public private sate eom atIme arler 16 days tom the Date of Notice sale to the hlyhest bidder an the date below (or any adiournment ahmvn above unless redeemed by you prior to such eale. deto). The We WI be held as folovle: Cafe of aeM nn or Bawl Phil of Bel* You mey tfllred the tats and btYffi bidder* x you ward. NOTICE OF REPCME3310N The property Is presently stored at flan Re000ven The money that we get from the sale (after paying our costs, HOW TO GET YOUR PROPERTY BACK Including reasonable tanomey 'sfeas end legal expenses If To get yow property be* pay uattissmourdtycerlineddor permitted by lava) will reduce the amount you owe. f<we get money aft before the va** lssdd. less money than you owe, you ply still owe us the difference. If Unpaid Balance 5 288TO.o4 We get more money than you , you will get the extra money, Plug Cow °eoe s t2B.0o unless we must pay it to someone else. L s You Can get the property back at any time before we sell it by Pius Late Cht gw E 24.08 paying us the full amount you owe (not just the past due Meet Finance Chaps Rebate $ payments), Including our expenses. See How To Get Your Lea Insurance Prumum Rebate s Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number TOTAL s 27010.12 above. ( Pius aVertaes hounad IT detia A at the time (if ra paaaeaalan examded If you need more Information about the sale call us at the 16 days end less rebate moeMd after the date of this man.) telephone number above, or write us at the address above. tt e��pUeEetys v t you can still) g et beck a ny of th rrotr 1� g u>i ems bedore W e y ou went us to e x pl ain to y ou In writing how we have figured acoulyao6' if Y � Y g g If you do, vvet here re father Balm on IL ever ern. brtger you vrit, IM the amount that you owe us, you may call us at the telephone more Coats (Including repaln) you may have to pay. number above, or write us at the address above and request a If you hain any queorans about this, phase all us. written explanation. We are sending this notice to the following people who have an Interest In the property described above or vft 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 an an attachment sent with this notice. Tta prop" has been (or vAl be) reUr ed to a Under our agreement with your deal er /original creditor, the dealer/original creditor Is to sell tin property and pay you any roomy left aver. If you ova naney ' after the sate, you va9 pay It to the deale*d0rtal caed'dar. 3 PERSONAL PROPERTY: Any pertohel property fours ktltre veiidemay berccleimad by you vAtNn the rued 60 days or, Jn a000rdance with state low, by camacling this office. Thereafter, ttw peso M ptapanty stall 4s diepcsad of accordingly. Creditor hire assflined to h mafified htlamtedary (01 Exohanpa, LLC)b dgttfa (hut not be eblp 5 mrw) with ratpeot loft Gals of each vewlels owd s ve. PAYMENTS: All paymehtetous must baby arGReddexkor moray order. J , r~ MILEAGE DISCLOSURE: If yft ere wan that the mWaga reflicted of flea vahfelQe cadon a of Is rot =Willa W arty raaIIQt pease contact us ao inert We can exm atety report the vehicles mAeape. INSURANCE RIGHTS: If youdorrt wantto get your property bock ay flee Instirsnce company or the daaxeN tathal craditorto make nee twat any iwuranoe has teen cancelled. You have a dgM to pet credo for all prurdum refund*. FFWA 11911937 Jan M Pre4mm adhkns may R'oT be mad. Mnled tnU.S.A a unaarnu CUSTOM1AF.R/CUST01WER FILE g•d 0666 13r83SU dH WdSS :ZT 9002 91 JeW Exhibit C FORD CREDIT Ford Motor Credit Companv General Remodelers Inc Mike Goodhart RE: Account Number: 9687 SCHEDULED PAYOFF. $48,234.01 LESS: Auction Proceeds $39,100.00 Service Charge Refund $0.00 Extension Fee Refund $0.00 Payments $0.00 Credit Life Insurance Refund (if applicable) $0.00 Accident and Health Insurance Refund (if applic $0.00 Other: $0.00 SUB -TOTAL $9,134.01 ADD: Late Charges $64.26 Expenses of Retaking and Selling $915.50 Other: Interest $1,059.40 Other: $0.00 Other: $0.00 SUB TOTAL $2,039.16 BALANCE NOW DUE: $11,173.17 If you have any questions concerning this history, please feel free to contact us. Sincerely, Ford Motor Credit Company 1- 877 - 231 -8641 ext. 00703 DOC 613- 008N -1 3/13/12 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson i F!-LED-OffjCt- Sheriff 4,�xav at far+ht+ t ' �i E FF;0TH011gb M,F�). #r Jody S Smith 2013 JUL III AM 10: 30 Chief Deputy Richard W Stewart "' ° CUMBERLAND COUNTY Solicitor OFFICE`rT�I` ERIFF PENNSYLVANIA Ford Motor Credit Company LLC Case Number vs. 2013-3792 General Remodelers SHERIFF'S RETURN OF SERVICE 07/05/2013 03:04 PM- Deputy Jamie DiMartle, being duly sworn according to law, served the requested Complaint& 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. t1l IE DIM RT DEPUTY SHERIFF COST: $39.30 SO ANSWERS, July 08, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Shoriff,Telnosoft.Inc. Lloyd S. Markind, Esquire (ID#52507) SKLAR—MARKIND 102 BROWNING LANE, BLDG B, STE 1 CHERRY HILL,NJ 08003 (856) 616-8710 Attorney for Plaintiff(s) Our File Number: F1101176 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC : No. 13-3792 CIVIL ° Plaintiff : • TERM Fri t.1 VS. • !U - G3 : CIVIL ACTION GENERAL REMODELERS AND MIKE GOODHART • a- :°' Defendant • PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint in the above matter. Lloyd S. Markind, Esquire Attorney for Plaintiff ID #52507 Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: F1101176 4/I.PIS -- A- N c. - ,L83y R4k- a,4?G4.3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith r444 1 r ..i _4� r , Chief Deputy ' A '44 r Richard W Stewart Solicitor -� r ti, c�' I' ' E Ford Motor Credit Company LLC Case Number vs. 2013-3792 Michael S. Goodhart(et al.) SHERIFF'S RETURN OF SERVICE 12/26/2013 05:45 PM -Deputy Amanda Ebersole, 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, wife, who accepted as"Adult Person in Charge"for Michael S. Goodhart at 184 Texaco Road, Silver Spring Township, Mechanicsburg, PA 17050. 11 ALI ANDA EBERSOLE, DEPUTY SHERIFF COST: $39.76 SO ANSWERS, X6: December 27, 2013 RONI41 R ANDERSON, SHERIFF Lloyd S. Markind, Esquire (ID#52507) MARKIND LAW GROUP, P.C. 102 BROWNING LANE, BLDG B, STE 1 CHERRY HILL, NJ 08003 (856) 616-8710 Attorney for Plaintiff(s) Our File Number: F1101176 1 A 1 ki't 10: 3 COU:1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC Plaintiff VS. GENERAL REMODELERS AND MIKE GOODHART Defendant : No. 13-3792 CIVIL TERM : CIVIL ACTION PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint in the above matter. 00 1 Lloyd S. Markind, Esquire Attorney for Plaintiff ID #52507 Markind Law Group, P.C. 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: F1101176 otol pc4 C /qb Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OF1, ICE OFTH $�mRIFF ErLEJ-OFFICE IF PROTHOWIT 2014 APR 28 rei 2 =5I CUMBERLAND COUNTY PENNSYLVANIA Ford Motor Credit Company LLC vs. Michael S. Goodhart (et al.) Case Number 2013 -3792 SHERIFF'S RETURN OF SERVICE 04/17/2014 03:06 PM - Deputy Dawn Kell, 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, Wife /Secretary, who accepted as "Adult Person in Charge" for General Remodelers at 184 Texaco Road, Silver Spring Township, Mechanicsburg, PA 17050. DAWN KELL, DEPUTY vat 04/17/2014 03:06 PM - Deputy Dawn Kell, 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, Wife, who accepted as "Adult Person in Charge" for Michael S. Goodhart at 184 Texaco Road, Silver Spring Township, Mechanicsburg, PA 17050. au,,* koa_ DAWN KELL, DEPUTY SHERIFF COST: $55.30 SO ANSWERS, April 22, 2014 (c) County it Sheriff; Te eoscl. RON�R ANDERSON, SHERIFF Lloyd S. Markind, Esquire (ID#52507) MARKIND LAW GROUP, P.C. 102 BROWNING LANE, BLDG B, STE 1 CHERRY HILL, NJ 08003 (856) 616-8710 Attorney for Plaintiff(s) Our File Number: F1101176 OF THE ZGf 4 JUS 2 ©� r CUNB PE NS ANVCOUNTY ANIq IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC Plaintiff vs. GENERAL REMODELERS AND MIKE GOODHART Defendant : No. 13-3792 CIVIL TERM : CIVIL ACTION PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint in the above matter. Lloyd S. Markind, Esquire Attorney for Plaintiff ID #52507 Markind Law Group, P.C. 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: F1101176 0001/4:\ DC,H 91160o 0 2bSc1103 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r;l ED-OFF1(r` Sheriff i};C PRO THOU,)Ta 1, of Lalu.n.t+rrrr Irif� Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFOF THE E!?ERIFF AUG -3 AM II: 02 CUMBERLAND COUNTY PENNSYLVANIA Ford Motor Credit Company LLC vs. Michael S. Goodhart (et al.) Case Number 2013-3792 SHERIFF'S RETURN OF SERVICE 08/05/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael S. Goodhart, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 184 Texaco Road, Silver Spring Township, Mechanicsburg, PA 17050. Residence is vacant. SHERIFF COST: $39.79 SO ANSWERS, 7. August 05, 2014 RONR ANDERSON, SHERIFF (c) CountySuito Sheriff, Teleosoft, Inc. 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.: F1101176 ,-`LET tr 2014 All 23 PH 2: I CLI,PE ;�LAikin IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO[1NTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC Plaintiff vs. GENERAL REMODELERS AND MIKE GOODHART Defendant : No. 13-3792 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 AND MIKE GOODHART , for failure to answer or otherwise respond to the Complaint. 1. The Complaint was served upon defendant on July 5, 2013 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 7/16/14. 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 7/26/14. 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 $9,713.62, being the amount demanded in the Complaint, together with contractual attorney fees of $2,480.72 and interest of $6,984.56 for a total of $19,178.90, together with costs of this action. Date: 4/f I'ic/ MARKIND LA�.,:� y_ .: P.C. Lloyd S. a kind, Esquire (ID #52507) ATTORNEY FOR PLAINTIFF ‘).), A gl(o.S6P1-1-ti ?_;k:0-joaar-7 No a /2 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.: F1101176 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company, LLC Plaintiff vs. GENERAL REMODELERS AND MIKE GOODI-TART Defendant TO: : No. 13-3792 CIVIL : TERM : CIVIL ACTION GENERAL REMODELERS 184 TEXACO RD MECHANICSBURG PA 17050-4626 Date: August 11, 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 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.: F1101176 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 AND MIKE GOODHART Defendant : No. 13-3792 CIVIL : TERM : CIVIL ACTION 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 AND MIKE GOODHART reside(s) at 184 TEXACO RD, MECHANICSBURG PA 17050-4626; and that the defendant(s) GENERAL REMODELERS 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. MARKIND LAW GROUP, P.C. Lloyd S. Ma kind, Esquire (ID #52507) ATTORNEY FOR PLAINTIFF Date: Department of Defense Manpower Data Center Status }Upon Pursuant to Servicetnembers Civil Relief Act Last Name: GOODHART First Name: MIKE Middle Name: Active Duty Status As Of: Aucl-22-2013 NA NA s _av y. No vG Results as or: Aug -22,201306111:08 SCRA 3.0 NA lids response redacts ee ha Aj,ls' solve duty Milos based on Ne Mike Duly Stake Date €v...: Y.. - .....� i..'w.g,..: > . <" .>. ; :".'g'.''•.:isS!>ufY+r6ilR��'dlldtirOO@`IMsre ... . _:...'',T,',1*,.. 4Li�1DY14: , ...' .. :, .Nl4**6NtCi1t - ` rls. i E NA NA No NA fib response rdedts whore Ne IndMduel lea solve duly stabs waiIn 367 dayspecedrg the Arise Day 8lelus Date .x.......Y :xx•e<%. :%>xx%•.;."'"1%'+""' :ax': - ,. ..r ..x::' .,[. x....<. to'A houi.' x,x 44:. [x::vr::i[xx%:>:xxx'::rt�:xxx:.! ,;xx;:%x;:ThrLtaATsra:tOltNerslllalfl�aijl>�IldSata.Firte: ral4r�n on[i4dlf�ia. . BWfzt7apfe i. ^ 'Y ` ; ` ;:.:" , . :" `.. t ..5: ::xTr>.x ... .t:::Tx T.:;. y...,..:::.:: a, .s,r.eax...d S:e..).,kT.a s..a:,.t>..:..tx%S.._5....::,.:..., . L1td1.. 6...... t,816t1f>k ?.<%,:•x%.•yderIiMIdrAIMI,IAA.md'blYY ..,,..,..,.,..t_,.,:._:.,........._,.:....:...:.tr.:k...:.;s,::Yk ::::..::.::: ::::::.::';`: , ' ;..:.., K9in11plFFdl�ftliKrttit.. NA NA No NA Tata response relents Mythic the Individual or hkuber sal hes res lead eery notaalon 10 rtdeort for Reeve 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 alive duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Pubic Health, and Coast Guard). This status Includes information on a Servicemember or hislher unit receiving notification of future orders to report for Active Duty. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATNELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. r� haatiarDii:erk. 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 official source of data on eligibility for miitery medical care and other eligibility systems. The Doo strongly supports the enforcement of the Servicemembers CM Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Salbrs' Civil Refef Act 011940). 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 peruses status by contacting that person's Service via the "defenselink.mN' URL: http:llwww.defenselink.mWiegfple/PC09SLOR.huN. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service vertiioatlon, punitive provisions of the SCRA may be Invoked against you. See 50 USC App. § 521(c). This response reflects the folowing 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) Whetter the individual or hiss 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 certiicate 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(f) for purposes of responding to a national emergency dedared by the President and supported by Federal funds. Alt Active Guard Reserve (AGR) members must be assigned against en authorized mobilization position in the unit they support. This Includes Navy Training and Administration of the Reserves (rARs), Marine Corps Active Reserve (AR5) and Coast Guard Reserve Program Administrator (RPAs). Acive 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 end Atmospheric Administration (NOM 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 § 1010V). Many times orders are emended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should ohedt to make sure the orders on which SCRA protections aro based have not been amended to extend the indusive 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 include*. 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 quailed legal counsel to ensure that all rights guaranteed to Service members under the SCRA we protected WARNING: This certificate was provided based on a last name, SSWdate of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 7401 H7F3X0B9F40 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SC Solicitor NEED Fu al Ford Motor Credit Company LLC vs.Cane Number General Remodelers 2013-3792 SHERIFF'S RETURN OF SERVICE 07105/2013 03:04 PM - Deputy Jamie Di1Vlarlle, being duty sworn according to law, served the requested Complaint & 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, Sliver Spring Township, Mechanicsburg, PA 17050. SHERIFF COST: 539.30 July 08, 2013 ic) CounyS4I. S4*W. to 1, SO ANSWERS, RONPTY R ANDERSON, SHERIFF 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.: F1101176 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. 13-3792 CIVIL Plaintiff vs. GENERAL REMODELERS AND MIKE GOODHART Defendant : TERM : CIVIL ACTION NOTICE OF INTENTION TO TAKE DEFAULT TO: GENERAL REMODELERS 184 TEXACO RD MECHANICSBURG PA 17050-4626 DATE OF NOTICE: Julyl(i2014 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 Disclosure Ind LaC. LI yd 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.: F1101176 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. 13-3792 CIVIL Plaintiff : TERM vs. : CIVIL ACTION GENERAL REMODELERS AND MIKE GOODHART Defendant CERTIFICATION PURSUANT TO Pa. R.C.P. 237 The undersigned hereby certifies that on 7/16/14 I mailed a true and correct copy ,by regular mail, of NOTICE OF INTENTION TO TAKE DEFAULT to: GENERAL REMODELERS 184 TEXACO RD MECHANICSBURG PA 17050-4626 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. a 'lid, Esquire (ID #52507) ATTORNEY FOR PLAINTIFF