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Home My WebLink About14-4886 t t Supreme Co :ennsylvania Con , ,, pIki mo leas For Prothonotary Use Only; Docket No: Cts lard r f:lf�; County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. r� Commencement of Action: S 0 Complaint [3 Writ of Summons ® Petition ® Transfer from Another Jurisdiction [3 Declaration of Taking E C Lead Plaintiffs Name: Lead Defendant's Name: Stephen J Roy Ford Motor Company Z' Dollar Amount Requested: Qwithin arbitration limits I Are money damages requested? IM Yes [3 No (check one) ®outside arbitration limits 0 N Is this a Class Action Suit? ®Yes ED No Is this an MDJAppeal? 0 Yes IR No A Name of Plaintiff/Appellant's Attorney: Christina Gill Roseman ® Check here if you have no attorney(are a Self-.Represented [Pro SeJ 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 ® Motor Vehicle ® Debt Collection:Other ® Board of Elections ®Nuisance Dept.of Transportation ®Premises Liability r3 Statutory Appeal:Other S ® Product Liability(does not include mass tort) ®Employment Dispute: E ® Slander/Libel/Defamation Discrimination [3 Employment Dispute:Other ® Zoning Board ,r ® Other: Other: 0 MASS TORT Breach of warranty ® Asbestos Unfair trade N ® Tobacco ® Toxic Tort-DES ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other. ® Ejectment a Common Law/Statutory Arbitration B ® Eminent Domain/Condemnation ® Declaratory Judgment ® Ground Rent ® Mandamus E3 Landlord/Tenant Dispute Q Non-Domestic Relations 11 Mortgage Foreclosure:Residential Restraining Order E PROFESSIONAL LIABLITY [I Mortgage Foreclosure:Commercial ®Quo Warranto ® Dental ®Partition ®Replevin ® Legal ®Quiet Title ®Other: ® Medical ® Other: ® Other Professional: Updated 111/1011 Fi 0 16 AUC ! 13 ! CUMBERLAND CCUt � IN THE COURT OF C(hl�`IVI5?'-LPdi JVAS JF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN J. ROY and NO.: ILI, KAREN ANN ROY, Plaintiffs, COMPLAINT IN CIVIL ACTION VS. Filed on behalf of Plaintiffs: FORD MOTOR COMPANY, Stephen Roy and Karen Roy Defendant. COUNSEL OF RECORD FOR THESE PARTIES: Christina Gill Roseman,Esquire Identification No. 71492 ROSEMAN LAW FIRM,PLLC 4885-A McKnight Road,No. 428 Pittsburgh, PA 15237 cro semankhelpforlemoncars.com (800) 745-5259 WRIT WAIVED a�� a C �� icy f Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN J. ROY and KAREN ANN ROY, Plaintiffs, VS. No.: FORD MOTOR COMPANY, Defendant. NOTICE TO DEFEND 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,property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. If you do not have a lawyer, go to or telephone the office set forth below. This office can provide you with information about hiring a lawyer. IF YOU CANNOT AFFORD TO HIRE A LAWYER, this office may be able to provide you with information about agencies that may offer legal service to eligible persons at a reduced fee or no fee. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania Telephone number 717-249-3166 f r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN J. ROY and KAREN ANN ROY, Plaintiffs, VS. No.: FORD MOTOR COMPANY, Defendant. COMPLAINT 1. Plaintiff, Stephen J. Roy is an adult individual citizen and legal resident of the Commonwealth of Pennsylvania, residing at 67 Meadowlark Trail, Fairfield PA 17320. 2. Plaintiff, Karen Ann Roy, is an adult individual citizen and a legal resident of the Commonwealth of Pennsylvania, residing at 59 Lori Circle Mechanicsburg PA 17050. 3. Defendant, Ford Motor Company, is a corporation qualified to do business and which regularly conducts business in the Commonwealth of Pennsylvania, with its address and principal place of business located at Consumer Affairs, 16800 Executive Plaza Drive, 3 NE-B, Dearborn, Michigan 48126-4207, and can be served at that address. 4. Plaintiffs purchased a new 2012 Ford Fiesta on June 16, 2012, manufactured and warranted by Defendant,with a Vehicle Identification Number of 3FADP4BJ7CM207664. 5. The vehicle was purchased in the Commonwealth of Virginia and is registered in the Commonwealth of Pennsylvania. 1 6. The purchase price of the vehicle, including registration charges, document fees, sales tax and finance charges totaled more than $19,621.16. A true and correct copy of the buyer's order is attached hereto as Exhibit 1. 7. In consideration for the purchase of the vehicle, Defendant issued to Plaintiffs several express written warranties, including a 3 year/36,000 mile bumper-to-bumper warranty and a 5 year/60,000 mile powertrain warranty. A true and correct copy of the 2012 Model Year Ford Warranty Guide is attached hereto as Exhibit 2. 8. The written express warranties were part of the basis of the bargain between Defendant and Plaintiffs. 9. As a result of ineffective warranty repair attempts made by Defendant through its authorized dealer(s), the vehicle is rendered substantially impaired in value and safety and, unable to be utilized for its intended purposes. 10. Plaintiffs presented the vehicle to Defendant's authorized warranty repair facility on October 23, 2013 at 16,431 miles on the odometer for a repair attempt under warranty for a noise in the transmission. A true and correct copy of a repair invoice dated October 23, 2013 is attached hereto as Exhibit 3. 11. Plaintiffs presented the vehicle to Defendant's authorized warranty repair facility on October 29, 2013 at 16,605 miles on the odometer for a repair attempt under warranty for the transmission. A true and correct copy of a repair invoice dated October 29, 2013 is attached hereto as Exhibit 4. 12. Plaintiffs presented the vehicle to Defendant's authorized warranty repair facility on November 18, 2013 at 17,096 miles for a noise at 35 miles per hour or under. A true and correct copy of the November 18, 2013 repair order is attached as Exhibit 5. 2 f n 13. Plaintiffs presented the vehicle to Defendant's authorized warranty repair facility on November 30, 2013 at 17,238 miles on the odometer for a noise when going and the right front axle shaft was replaced. A true and correct copy of the repair order dated November 30, 2013 is attached as Exhibit 6. 14. Additional repair attempts were made after November 30, 2013. True and correct copies of the repair orders after November 30, 2013 are attached as Exhibit 7. 15. The nonconformities have not been repaired and substantially impair the vehicle's use, safety and value. COUNT MAGNUSON-MOSS (FTC)WARRANTY IMPROVEMENT ACT 16. Plaintiffs hereby incorporate all facts and allegations set forth in this Complaint by reference as if fully set forth at length herein. 17. Plaintiffs are "Consumers" as defined by 15 U.S.C. §2301(3) of the Magnuson Moss Warranty Act. 18. Defendant is a"supplier", "warrantor", and a "service contractor" as defined by 15 U.S.C. § 2301 (4),(5) and (8). 19. Plaintiffs' vehicle is a"consumer product" as defined by 15 U.S.C. § 2301(1). 20. The Magnuson Moss Warranty Act at 15 U.S.C. § 2310 provides for the enforcement of state warranty laws, including laws regarding express and implied warranties. 21. By the terms of its written warranties, Defendant agreed to perform effective repairs to the vehicle at no charge for parts and/or labor. 22. The Magnuson-Moss Warranty Improvement Act at 15 U.S.C. § 2308 prevents the disclaimer of implied warranties if an express warranty is offered at the time of the sale. 3 23. Plaintiffs provided to Defendant a reasonable number of repair attempts to repair the defects and nonconformities with the vehicle pursuant to Defendant's express written warranties, but these repair attempts were ineffective. 24. The vehicle was delivered to Plaintiff in a condition that did not meet the standards of the implied warranty of merchantability at 13 Pa.C.S. § 2314. 25. As a direct and proximate result of Defendant's failure to comply with the express written warranties and the implied warranty of merchantability, Plaintiffs have suffered damages and are entitled to bring suit under the Magnuson Moss Warranty Act. 26. Plaintiffs aver that Defendant's warranty was not provided to Plaintiffs until after the vehicle was delivered, making any and all limitations, disclaimers and/or alternative dispute provisions ineffective for a failure of consideration. 27. Defendant did not require Plaintiffs to first resort to a Dispute Resolution Program before filing suit. 28. Plaintiffs are entitled to the recovery of damages and attorneys' fees and costs against Defendant. WHEREFORE, Plaintiffs respectfully demand judgment against Defendant in an amount equal to the price of the subject vehicle, plus all collateral charges, incidental and consequential damages in an amount not in excess of $50,000 plus reasonable attorneys' fees, and all court costs. COUNT II PENNSYLVANIA UNFAIR TRADE PRACTICES AND CONSUMER PROTECTION LAW 29. Plaintiffs hereby incorporate all facts and allegations set forth in this Complaint by reference as if fully set forth at length herein. 4 30. Plaintiffs are 'Persons" as defined by the Unfair Trade Practices and Consumer Protection Law at 73 P.S. §201-2(2). 31. Defendant is a"Person" as defined by 73 P.S. §201-2(2). 32. The Unfair Trade Practices and Consumer Protection Law at 201-9.2(a) of the Act authorizes a private cause of action for any person "who purchases or leases goods or services primarily for personal, family or household purposes." 33. A violation of the Pennsylvania Automobile Lemon Law automatically constitutes a violation of the Pennsylvania Unfair Trade Practices and Consumer Protection Act, 73 P.S. 201-1 et§gq. 34. The Pennsylvania Unfair Trade Practices and Consumer Protection Act, 73 P.S. §201-2(4), defines "unfair or deceptive acts or practices" to include the following conduct: (vii). Representing that goods or services are of a particular standard,quality or grade, or that goods are of a particular style or model,if they are of another; (xiv). Failing to comply with the terms of any written guarantee or warranty given to the buyer at,prior to, or after a contract for the purchase of goods or services is made; (xv). Knowingly misrepresenting that services, replacements or repairs are needed if they are not needed; (xvi). Making repairs, improvements or replacements on tangible, real or personal property of a nature or quality inferior to or below the standard of that agreed to in writing; (xvii). Engaging in any other fraudulent or deceptive conduct which creates a likelihood of confusion or of misunderstanding. 35. Defendant's actions including but not limited to failing to provide a merchantable vehicle, failing to comply with the terms of its warranty and, failing to remedy the defects with the vehicle at no charge and failing to provide documentation of repair attempts have violated the Unfair Trade Practices and Consumer Protection Law. 5 36. The UTPCPL at 73 P.S. § 201-3.1 specifically authorizes the Attorney General to enact rules and regulations in support of the enforcement and administration of the UTPCPL, which rules and regulations shall have the force of law. 37. The Automotive Industry Trade Practices regulations, 37 Pa. Code § 301.2 were promulgated pursuant to the authority of 73 P.S. § 201-3.1. 38. Defendant's conduct in failing to provide documentation of warranty repair attempts violates the express terms of Section 301.5. Pennsylvania Automotive Trade Practices regulations which provide: General provisions—repair shop. With regard to a repair shop, the following is considered unfair methods of competition and unfair or deceptive acts or practices: . (8) Failing to provide a customer at the completion of repair or maintenance work, including warranty repair work,performed on the vehicle of the customer a dated, written invoice containing the following information: (i) The name and address of the customer and repair shop. (ii) The date the vehicle of the customer was delivered for service. (iii) The year, make and registration number of the vehicle of the customer and the odometer reading of the vehicle at the time the repairs were completed. (iv) An itemized list of the specific repair or maintenance services performed on the motor vehicle of the customer. (v) A list of the parts supplied by name or number, the price charged for the parts and the total amount charged the customer for the parts. (vi) If a part supplied was not new, a statement that the part was either used, reconditioned or rebuilt. (vii) The labor charge for the repair work, setting forth the number of hours,the price charged for each hour and the total amount charged the customer for labor. 6 (viii) The total amount charged to the customer for parts and labor; provided,however,that the price information required by this subparagraph and subparagraphs (v) and(vii) need not be provided if the price charged to the customer for the repair or maintenance work is a single charge for the particular service which charge was included in a schedule of charges posted in a clear and conspicuous manner on the premises of the repair shop or otherwise disclosed to the customer at the time the vehicle was delivered for service or repair.No other charges are permitted by this paragraph unless they are clearly and conspicuously disclosed to the customer prior to the commencement of repairs. 39. Plaintiffs have suffered damages as a result of Defendant's violations of the Unfair Trade Practices and Consumer Protection Law. 40. Plaintiffs are entitled to actual damages and treble damages for Defendant's violations of the Unfair Trade Practices and Consumer Protection Law. WHEREFORE, Plaintiffs respectfully demand judgment against Defendant in an amount not in excess of Fifty Thousand Dollars ($50,000), together with all collateral charges, attorneys' fees, all court costs and treble damages. By: Christina Gill Roseman,Esquire Roseman Law Firm, PLLC Attorney for Plaintiffs 4885-A McKnight Rd.,No. 428 Pittsburgh, Pennsylvania 15237 croseman@helpforlemoncars.com (800) 745-5259 7 t 1 VERIFICATION I,Karen Ann Roy,hereby state that I am a Plaintiff in the captioned matter; that I am acquainted with the facts set forth in the foregoing Complaint;that same are true and correct to the best of my knowledge, information and belief; and that this statement is made subject to the Penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsifications to authorities. LJ no rin� Date. v a Karen Ann Y- 8 r Mcc,"'M CD ' BUYERIS flR ER 46M HMfrf SYM PhW STOW G,VA 20464 t DAT 703430-7700 PURCHAS i's ?HEN J ROY —------ FULLINIAM PURCHAS R.s ROY X�A I F. ANN FULL NAM Z,p _.k IRCHAS 'S SIRLET ly STATE 2 169 w N M MAPTINSBUII( wvI254_05 (yj 2 7-- 3941 Q-_ COLOR C WXIEL PEAR 7,(l 12( lj(;4 CUSTOMER NO. TO BE DEL.ON MAKE Sol E-MAIL i�i Or ABOUT F014) fTR-,-,PA ?10 1,2 1 38501 9 06/L6/12 SIOCKNC, TSE NO. MILFAGE NEW 1 USED IDSMO, FJ 1214' ' kAD.P4BJ -lCIj207664 1b I t[Wl CASH PRI(E OF EHiCLE _'33 5. il;?, 00 FOU IF ) N'r GROUP G U 'A PROCESSING FEE PREMIUM SNO W/6 SPKRS 8( W T SUB-TO TA I UIl,[NUMWL( PN*rD 5. 3E. _794i HE evil—" ctrwfftla TAX 16 15 99JJ . 6r,' T'IVCT QURkeECIT DOM 14 mAr sx AN1111 - - AUTO T tl 00 Q RAM, PURCHASERS ON-LINE SYSTEMS FILING FEE ' � OEALIER'S BUSINESS LICENSE TAX 57 WA Temp !V 14 ' 00 C) Lien t4/A TRIP $LO ransfer 0 T i C3 LiBILITY INSURANCE INCLUDED TOTAL CASH.DEIJVERED PRICE DEPC jIT DU WITH OMER(This Buyers Order is not a Cash receipt) to �00. 00 Twulmm WAni, w 85 00. 00 -Ac_—Lo ANCE FOR USED CAR TRADE-IN �54 LU LE P API`ROXIMrE BALANCE OWING TO- q q HiDNOA FJ &MM_E_X_Q'_H_AN NETA:LOWA CEONTRADE-IN S 1149. 54 - TRADE INfALFAGE DESCRIPT NOF TRADE-41, VINATOTAL CREDITS jHM%F,2[I75AS043095 74000 i - . I , 49. 54- NIAKF MODELPr TYPE YEAR 7010 BALANCE DUE ON I 1(0) 'DA INSIGHT DELTVERY T TO EN URE MY C*APLETE SATISFACTION NG. ,I- I S_ INITIAL I UND RST ND X. PROMISES MUST BE IN WR)TI YOU ARE PROPOSING TO ENTER INTO A EASE READ THIS NOTICE: IF MAR--- FININCING THIS VEHICLE PL ER.PART OF YOUR CONTRACT INVOLVES FINANC NG THE RETAIL!INS rALLMENT SALES CONTRACt WITH THE DEAL LE AND THE DEALER INTENDS TO TRANSFE R YOUR W PURC�ASE OF YOUR VEHICLE.IFYOU ARE FINANCING THIS VEHIC N OR OTHER LENDER,YOUR VEHICLE PUI tCHASE FINANNG TO A FINANCE PROVIDER SUCH ASA BANK CREDITUNIO DEPS S 9! COOf TRACT. N THE FINANCE PROVIDER'S APPROVAL 6F YOUR PROPOSED RETAIL INSTALLMENT SALES ROVED WITHOUT A CHANGE THAT INCREASES TI- E COST IF Y0 , R AILJNSTALLMENT SALES CONTRACT IS APP CANCELLED. IF YOUR RETAIL INSTA .LMENT OR R Tp Q OR THE DEALER, YOUR PURCHASE CANNOT BE 0 "10 AC. U VERBALLY OR IN WRITING.YOU C N THEN _S:C SALE: r IS NOT APPROVED THE DEALER WILL NOTIFY YOU LE IN SOME OTHER WAY OR YOU OR THE DEALER CAN CANCEL YOUR PUF CHASE. DECID `TO PAY FOR THE VEHIC :R WITHIN 24 ERBAL HE ALE IS'CANCELLED,YOU NEED TO RETURN THE VEHICLE TO THE DEALER HOURS OF 11 IF T ION IT WAS GIVEN TO YOU,EXCEPT FOR NORMAL WEAR AND rr-hR.ANY 0 OR WR TT N NOTICE IN THE SAME CONDITION )T RET RN THE DOWN DAY WENVOR TRADE-IN YOU GAVE THE DEALER WILL BE RETURNED TO YOU. IF YOU 0 MAY L0 VEHIC E A ITHINK24 HOURS OF VERBAL OR WRITTEN NOTICE OF CANCELLATION, THE DEALER MAY LC E THE A 4D T E IT BACK WITHOUT FURTHER NOTICE TO YOU AS LONG AS THE DEALER FOLLOWS E LAW c 'LE BACK. IF THE DEALER D ES NOT VEHI ANDD ES NOT.CAUSE A BREACH OF THE PEACE WHEN TAKING THE VEHI( RETU YOUR 10OWN PAYMENT AND ANY TRADE-IN WHEN THE DEALER GETS THE VEHICLE BACK IN TH SAME CONDI 10� IT WAS GIVEN TO YOU, EXCEPT FOR NORMAL WEAR AND TEAR.THE DEALER MAY BE LIABLE TO YOU PROTECTION ACT.IF YOU ARE LEASING THIS VEHICLE,THE SAME PROCEE DURES, UNDE H �VIRGINIA CONSUMER AiRETAIL INSTALLMENT SALES CO TRACT RIGHT AN OBLIGATIONS APPLICABLE TO A TRANSACTION INVOLVING STATE A OVE'APPLY TO THIS TRANSACTION. 'ANSACT'ON T R C T E E T PLAINPLAINTIFF'S HIBIT TIFF'S NCE( LU EXHIBIT gtX? AOENTS PHONE NO. lN3U" 25 84L-3000 SAI YC ) I AT TH IS kS IS"iAqTH ALL FAULTS AND IS NOT I-OVERIED" J %IRS AF I BUY FOR"A SAL# NLY�.I UNDERSTAND THAT THIS� IS" T H MAKE ANY REP) I ER A A I SIRED TO .1 RRANTY.I UNDERSTAND'T I �A THK BY AN)i!DEi LER 0 A, REVERSE SIDE), THIS V1 MIC�'_E.TWILL HAVE TO PAY FOR ANY RE I. tD.(SE`E#18ON . � _ I. , - - - t . . r � IIIIAI�II�IIIIGII � r� Y Your satisfaction is our#1 goaL,If you have any questions or concerns,or 2012 Modelare unsatisfied with the service you are receiving.follow these steps: F-65005Q II.Contact your Sales Representative or Service Advisor at your selling/servicing deatersMp. 2.It your Inquiry or concern remains unresolved,contact the Sales Manapr,Service Manager or Customer Relations Manager. 3.U you require assistance or clarification on Ford Motor Company policies or procedures,please contact the For.Customer RelattonsNp Center. ALL-STATE LEGAL" J lbd Maio yup mnm an.—ftc— D.—9119191 PO.Pox IOW t90a9 nCroIm) Ommb161651 V1 - t'roo In-, aeaaara i-0�'�`oodsaw yroaa) rn �.� mm r1aJ99�mmt dn4o0 TeM mwmYvul ir,^ AA heG�umneI4lWan a..F.O.BoapC�4R Warranty Nr>,.ammm,e t,owv,ue tac+on«9utor a.+r,9:a uroe+.� tlw 9mWm rum (GY9p Am. m .aw.meaeanm Guide 9U •�� I I I I �Po.Om 1t1 �� PYad,IMhd ArW Crt4ero ' roc mlwtincoe9 � m.eee enra+es u» mewm Anerm eoo9vrl�s ��01aptro�is �� >= rti m1a19rzss :.,A P.mde emn9et•faCean mnA6ran ,� oJC e7t r: specified in the Scheduled Maintenance Guide will invalidate warranty,'- 7. ADDITIONAL INFORMATION ABOUT YOUR coverage on parts affected by the lack of maintenance..Make sure that EMISSIONS WARRANTY COVERAGE,-UNDER recetpts for completed'mahttenance work are retained with the vehicle FEDERAL AND CALIFORNIA REQUIREMENTS 30 IF YOU NEED CUSTOMER ASSISTANCE - mxl dulled Man to maintenance a work is always entered hi your g, NOISE EMISSIONS WARRANTY 32 Ford Motor Company and your selling dealer thank you for selecting '. Scheduled Maintenance Guide: one of our quality products.Our commitment to you and your vehicle Your Ford Motor Company dealer is available to assist you with all your Your Ford or Lincoln deeleraW,or Ford or Lincoln Auto Care Service 9. FORD EXTENDED SERVICE PLAN 33 begins with quality protection and service, automotive needs.Please follow the procedures outlined on the front Center,has factory-trained technicians who can perform the required 10. BETTER BUSINESS BUREAU(BBB) When you need warranty repairs,your selling dealer would like you to page of this booklet. maintenance using genuine Ford parte The dealership looks forward to - . AUTO LINE PROGRAM 34 return to it for that service,but you may also take your vehicle to in addition,if you are an eligible U.S.owner,you may use-at no cost- meeting your every service need to masimire Your satisfaction with your another Ford Motor Company dealership authorized for warranty repairs. the,"rviees of the BBB AUTO LINEprogramFor details,see Better vehicle. - 1t. STATE WARRANTY ENFORCEMENT LAWS 3S Certain warranty repairs require special training though,so not all Business Bureau(BBB)AUTO LDIS program,Page 34 or call WHO PAYS FOR WARRANTY REPAIRS? - 12. IMPORTANT INFORMATION ABOUT - dealers are authorized to perform all warranty repairs.That means that, 1-8WI1Ga"-6100. - AMBULANCE CONVERSIONS 3S depending on the warranty repair needed,the vehicle may need to be KNOW WHEN YOUR WARRANTY BEGINS You will not be charged for repairs covered by any applicable warranty taken to another dealer.R a particular dealership cannot assist you,then during the stated coverage periods,unless specifically stated elsewhere 13. IMPORTANT INFORMATION ABOUT FORD 36 contact the Customer Relationship Center at 1-8004392-3673. Your Warranty Start Date is the day you take delivery of your new in this grade. - LIMOUSINE CONVERSIONS. vehicle or the day it is first put into service(for example,as a dealer Some states have mandated alternate time coverage periods for parts of This booklet ar or lig it ruck.the warranty coverages that apply[o Yew 2012-model car or light truck.If You bought a previously awned demonstrator),whichever me=first. your vehicle(e.g.seatbelts). .. !i 2013-model vehicle,you are eligible for any remaining warranty CHECK YOUR VEHICLE Some states and/or'local governments may require a In on a portion of - - coverages. � We try to check vehicles earehdly at the assembly plant and the warranty repairs.When applicable law allows,the tax must be paid by Ford Motor Company provides the Emissions Defect Warranties and dealership,and we usually correct any damage to paint,sheet metal, you,the owner of the vehicle, Emissions Performance Warnatles which cover your emissions upholal.ery,or other appearance items.But occasionally something may During the Bumper to Bumper Warranty Period,dealers mwreceive control systems,and Noise Emission Warranty,which applies only to sup past us,and a customer may And that a vehicle was damaged before instructions to provide no-cost,service-type improvements-not medium1heavy duty trucks over 10,000 pounds Gross Vehicle Weight . he or she took delivery.If you see any damage when Yeu receive Your originally included in your Scheduled Maintenance Guide-untended to Rating(pages 17-32). vehicle,notify your dealership within one week. increase your overall satisfaction with your vehicle, MAINTAIN YOUR VEHICLE PROPERLY - Sometimes Ford may offer a special adjustment program to pay all or - li Your glove compartment contains an Owner Guide and a Scheduled part of thecast of certain repairs beyond the terms of the app8cable Maintenance Guide which indicate the scheduled maintenance warranty.Check with your dealer or call 1-800-392-3673 to learn whether required for your vehicle.Proper maintenance guards against major any adjustment program is applicable to your vehicle.Please have your repair expenses resulting from neglect u inadequate maintenance,may vehicle identification number available. help increase the value you receive when you sell or trade your vehicle, and is important in allowing your vehicle to comply with applicable emissions standards. - - It is your responsibility to make sura that all of the scheduled maintenance a performed and that the materials used meet Ford engineering specifications.Failure to perform scheduled maintenance as 2 3 1 _..J -........................................................ ...._..........._...�.,.w._...a_..w...,......,.�.,-. DO WARRANTR-S APPLY IN OTHER COUNTRIES? - The New Yebicle Limited Warranty and the Emlasioae Warranties described in this booklet apply toyou vehicle If: _ •it was originally purchased through the Ford Export Operations Military Sales Program;or •it was originally sold or leased by Ford Motor Company or one of its dealers in the United States or U.S.Federalized Territories,and it was originally registered/licensed and operated in.the United States,U.S. Federalized Territories,or Canada. U you meet either of these two requirements;you do have warranty coverage when you travel with this vehicle outside the United States, U.S.Federalized Territories,or Canada.In some cases,however,you may have to pay the servicing Ford dealer in a foreign country or U.S. Federalized Territory for a repair that is covered under the US, warranty.If this happens,be sure to save the paid repair order or invoice.You should present this document to a U.S.Ford Motor Company dealer for warranty refund consideration Refer to www.Ford.com for additional customer assistance reference Information 6 7 4 5 For vehicles within the New Vehicle Limited Warranty time in service 'Daasmlaaimu au internal parts,clutch cover,seats and gaakets,torque QUICK REFERENCE:WARRANTY COVERAGE _ •was taken to a Ford dealership ter a warranted repair during the + and mileage coverage.period,defective tires will be replaced on a pro converter,transfer case(including all mtemal parts),trammiladem case, warranty period, mta adjustment basis according to the following miltage-bowed by F chart gives o general under the N you warranty coverage Provided - adjus ring aB transmission mounts;F4on4Wheel IMve:aria shags,bearings(Omar by Ford Moroi Company under[he-New Vehicle limited WarrantR then authmrized Ford Motor Company dealers will,without charge, Hebabutaeinw.it Schedule: and rear),center support hearing,drive shafts,final drive housing Please refer Co the description of warranty coverage.for more specific repair,replace,or adjust all parts on your vehicle that malfunction or fail tm.va nntvgN PRRCE:RT OF eaxrs cuvgRRp BY Fd1Rn (including a0 internal parts),hubs-automatic tion[Cocking(four-wtheel Into[mati0n during normal use during the applicable coverage period due to a t-i 000 100% drive),locking rings(tour-wheel drive),shahs and gaskets,universal and - nnanufachring defect U tactoty-supplied materials or factory workmanship. 12 Om- 000 Solis constant velocity joints;Re Wheel Drive:aide shafts,bearings(front For each type of coverage,the chart shows two measures: -. This warranty does not mean that each Ford vehicle is defect free. 24,0CU-3aODD p0% - - and rear),center support bearing,drive axis housing(Including all • years in.service • miles driven - d design may a unintentionallycturiprocesses introduced into vehicles could the The tire manufacturer also provides you with a separate tire warranty that internal Parts),drive shaft,propeller shafts,retainers,supports,scala and desi{Pn and manufacturing processes and such detects could result in the Your Now Vehicle Liaised Waw may extend beyond the New Vehicle Limited Warranty coverage.You will gaskets,universal and constant velocity joints. rny need for repairs.For this reason,Ford provides the New Vehicle Limited find the m wufscmrwr 3 lite warranty with the owner literature supplied' ierni''er�i in Warranty in order to remedy any such defects Nat result in vehicle pan with your vehicle.You have the option of having a tire warranty repair (2)Your vehicles safety belts and air bag Supplemental Restraint System owverr malhmction or failure during the warranty period. Performed by the tire manufacturers authorized service center.if you go (SRS)are covered for an extended Safety Restraint Coverage Period, The re+nedv under fids written warranty,and any implied warranty,is to a tie service center for a repair covered by the New Vehicle limited which lasts for five years or 60,000 miles,whichever occurs fust. fmrited to repair,replacemernt,oradjusunent of deCeoLive pats This R'arranty.you may be.charged a prorated amount for wear or other Your vehicles body sheet metal panels are covered for an extended excursive remedy stat not be deemed to terve failed its Band abl purpose charges.V so,you should present your paid invoice detaifrng the nature of (� so long as Ford,through its authorized dealers,is willing and able to the charges to any Ford Motor Company dealership for refund Corrosion Coverage Period,which lasts for five years,regardless of miles repay,replace,or adjust defective pans in the prescribed manner.Ford's consideration.When making warranty repaim an yew vehicle,the dealer driven.The extended warranty coverage only applies if a body sheet liability,if any,shall ts t event exceed the cost aof correcting will we Ford or Motorcraft parts or mamnufactured or other parts that metal panel becomes perforated due to corrosion during normal use due manufacturing defects as herein provided and upon expiration of this are authorized by Ford.In certain instances,Ford may allthoTtze repairs at to a manufacturing defect in factory-supplied materials or factory warranty,any such liability shall terminate. other than Ford dealer facilities.lyre replacements under warranty will be workmanship.For damage caused by airborne material(environmental Conditions that are not covered by the New Vehicle Limited Warranty made with the same brand and model as originally equipped with the fallout)where there is no factory-related defect involved and therefore are described on pages 12-15.When making warranty repairs on your vehicle ant's the same brand and model is no longer available,in which no warranty—our policy is to provide free repair of paint damage due to 'k', vehicle,the dealer will use Ford or Motorcraft pans or nahanufactured rase a tie of the same trend,size,toad,speed and tread type will be the airborne material for 12 months or 12,000 miles,whichever occurs or other parts that are authorized by Ford,at the discretion of Ford or used.In"me circumstances,Ford may authorize another brand and/or fret. The measure that occurs first detemdnes hourlong your coverage lasts the Ford dealership, model to substitute for the original brand and model,even if still available. For example:Yom Bumper to Bumper Coverage lasts for three pears- Nothing in this warranty should he construed as requiring defective Rants Normal fire wear or damage is not reimbursable.See page 14 for details (4)Your nts me direct injection t diesel engine and certain engine lasses You drive more than 36,000 miles before three .ars elapse.[n. to be re er components are covered during the PowerStroke Diesel Engine Coverage years placed with Pacts of a different type or design than the original of what is not covered. t acase,your coverage ends at 36,000 miles. part,so long as the vehicle hmetions properly with the replacement part. Period,which lasts for five years or 100,000 miles,whichever occurs that Moreover,Ford and its authorized dealers are entitled to a reasonable Extended warranty coverage periods are svailabie for certain fast.The following parts arc covered during this extended coverage For more details on corerage,see: vehicle parte and conditions.Specifically, period:the engine,cylinder block,heads and aft bdernal parts,Intake • What is Coveredl es&12 - `bre and a reasonable number s attempts within which to diagnose and and exhaust manifolds,tlmn%gear,harmonic balancer,valve covem,oil ) Psi'any detect covered by this warranty. (1)Your vehicle's Powertrain components are covered for five yeas or + What Is Not Covered?(pages 12-15) In certain instances,Ford may authorize repairs at other than Ford 60,000 aures,wtvclrevar occurs fust.The extended coverage applies to .pan and pump,water pump,fuel system(excluding fuel lines,fuel tank dealer facilities. the Engine:all internal lubricated parts,cylinder block,cylinder heads, and frame mounted Orel conditioning module sometimes referred to as WHAT IS COVERED? electrical Orel pump.electronic engine control unit,engine mounts, the frame mounted pump/flter/water separator),high pressure Wes, separate warranties apply to tires on inaw vehicle.The New Your NEW V'EI[ICLE LIMITED WARRANTY gives you specific legal Vehicle cle Limited Warranty rovers fire defectss in factory supplied material flywheel,injection pump,manifold(exhaust and'retake),manifold bolts, gaskets and seals,glow plugs,turbocharger,two-stage turbocharger rights.you may have other m that or workma ahiD for 100%of labor costs and on a pro rata adjustment assembly,turbocharger actuator, wertrain control module,a riots vary from state to state.Under oft pan,oil pump,seats and gaskets,thermostat,thermostat housing, p° �°° your New Vehicle Limited Warranty if: basis for parts.(See the reimbursement schedule below). timing chain cover,timing chain(gem or belt), control module,high pressure fuel injection pump assembly,electronic turbaharger/superchuger unit,valve covers,water pump; drives hmtc,injectors,injection pressure sensor,fuel rail presame sensor, -year Fond vehicle is propexly operated aid maintained,and 10 11 8 9 g ..,_ __._... ... Where a vehicle has no factory-related defect,and isthereforeact Other Items or Comittlons Not Covered high pressure oil regulator,exhaust back pressure regulator and sensor, ties,roll bars,cellular phones,alarm systems,automatic starting entitled to a warranty related repair,replacement or adjustment,it is exhaust pressure sensor,manifold pressure sensor,intake air systems and performance-enhancing powertrain components or Ford Policy nonetheless to provide certain maintenance items,when - The New Vehicle Limited Warranty does not cover. temperature sensor,crankshaft position sensor,camshaft position sensor, - software and performance"chips" necessary,fee of charge dining a limited period: - •vehicles that have had the odometer disconnected,altered,or accelerator switch. - inoperative for m extended period of time with the result that the Damage Caused by Use and/or tits EnviEnvironmentnme •wiper Tilade replacernenm will be provided during the hist six months P NOTE:Some components may also be covered by the Endssions in service,regardless of utiles drives actual mileage cannot be determined Warranties.For more information,see pages I731. The New Vehicle Limited Warranty does not rover surface rust, •wheel alignments and Lire balancing(unless required by a warranty . •vehicles that have ever been labeled or branded as dismantled,fire, deterioration and damage of paint,trim,upholstery,and other repair)will be provided during the first 12 months or 12,000 miles in flood,junk,rebuilt,reconstructed,or salvaged;this will void the New WHAT IS NOT COVERED UNDER THE NEW VEHICLE LIMITED appearance items that result from use and/or exposure to the elements. service,whichever occurs first Vehicle Limited Warranty WARRANTY? You,as the owner,are responsible for these items.Some examples are: •Brake pad/lining replacements will be provided during the first •vehicles that have been determined to be a total loss by an insurance Damage Caused By; •dings,dents 12 months or 15,000 miles in service,whichever occurs fust company;this will void the New Vehicle Limited Warranty •accidents,collision or objects striking the vehicle(including driving •cuts,bnmre,prrhetmes or tear SYNC Hands-Fres Communications and Entertainment System •converted Expedition EL limousines that are not equipped with the through a ca wash) read salt If your vehicle is equipped with SYNC,the New Vehicle Limited Warranty - limousine Builders Package(17L)Option,or if the wheelbase is .theft,vandalism,or riot •tree sap,bbd and bee droppings does not cover repairs under certainconditions.Some examples include: - extended beyond 140 inches,or if the Gross Vehicle Weight Rating (GVWR)exceeds 9,900 pounds,See important information about •fire or explosion •windstorm,lightening,W.Loss o[personal recording media,software or data Expedition EL limousine conversion(page 36). •using contaminated or Improper f ieVftufds •earthquake •Failure to provide proper installation environment •any other Ford vehicles that are converted to limousines.This will •customer-applied chemicals or accidental spills •freezing,water or food •Damage caused by: void the New Vehicle Limited Warranty.See important information •driving through water deep enough to cause water to be ingested into •stone chips,scratches(some examples are on paint and glass) +abnormal use such as hserdon of foreign objects,fluid spillage about conversions(page 36) the engine •windshield stress cracks.However,limited coverage on windshield •unauthorized modification to alter functionality or capability - converted ambulances that are not equipped with the Ford Ambulance •-computer or internet viruses,bugs,worms,T mjan Horses,cancelbots •misuse a the cleasvehicle,such a driving neer curbs,overloading,racing or stress cracks will ri provided for the first se months or 12,000 miles •installation of unauthorized software,peripherals and attachments Prep Package,see important information about ambulance conversions using the vehicle as a Permanent stationary power source, (which ever nus. fust),even though caused by use and/or exposure •unauUwrized,unapproved and/or incompatible repairs,upgrades and (Page ) Damage Caused by Alteration or Modification - to the elements. modification •Aftermarket pans or components,sometimes instated by Ford Motor MalManancEdWasr •the defective function of you cellular phone or digital media device Company or an authorized Ford dealership,may not be covered by the The New Vehicle Limited Warranty does not cover arty damage caused by: 0.e.,inadequate signal reception by the external antenna,viruses or New Vehicle Limited Warranty Any damage caused to Ford •alterations or modifications of the vehicle,including the body,chassis, The New Vehicle L'united Warranty does not cover:(1)parts and labor other software problems) components due to the failure of aftermarket parts(other than a or components,atter the vehicle leaves the control of Ford Motor needed Co maintain in the vehicle;and(2)the replacement for parts due to certified emissions part)is not covered. Company normal wear and tear. int,sa the owner,are responsible.exapesfor thine items. Tis Weer W Damage r, Sem your Scheduled Maintenance Guide.Some examples of maintenance I The New Vehicle Limited Warranty does not cover normal wear or worn - •tampering with the vehicle,tampering with the emissions systems or and normal wear are: with the other parts that affect these systems(for example,but rat .oil changes •clutch linings out tires.Tres will not be replaced(unless required by a warranty repair)for wear or damage including: r the insted al exhaust and inane systems) •oils,lubricants,other(hide •Wiper blades •tie damage from road hazard such as cuts,snags,bruises,bulges, the rusted ami or use of a non-Ford Motor dor non-pan(other than r •of lair filters •Wheel aligmmnts and ire puncture,and impact breaks a certified emissions Dart)or any part(Ford or non-Furl)designed balancing for off-mad me only installed after the vehicle leaves the control of .•tie rotation/idiation •tire damage due to under or over Motion,tire chain use,rating, Ford Motor Company,if the installed pan fails or causes a Ford part •cleaning/polishing •Brake pad&..g spinning(as when stuck in snow or mud),improper mounting or to W.Examples include,but are not limited to lift lits,oversized dismounting,or tie repair 14 1s 12 13 EXPLANATION OF CALIFORNIA EMISSIONS WARRANTIES For Vehicles Eligible for California PZEV Emission Warranty Coverage •Subject W change,the fellawing states have adopted and are enforcing California emission warranty regulations: Your Warranty Rights ami Obligations For 16 years or 160,000 miles(whichever first occurs): -Passenger Car.&Light-dirty Tucks(up to 8,500 pounds GVWR)- ' The Cabf.nmia Art Resources BoardandFord Motor Company are 1.If an emissions-related part on your vehicle is detective,the part will - Arizona,California,Connecticut;Maine,Maryland,Massachusetts,New pleased to explain the emission control system warranty on your be repaired or replated by Ford.This is your emissions control system QUICK REFERENCE:EMISSIONS WARRANTY COVERAGE Jersey,Oregon,Pennsylvania,Rhode island,Vermont and Washington 2012-model vehicle.In California,new motor vehicles must be designed, DEFECTS WARRANTY. This chart shows the emission warranty that Ford Motor Company (NOTE:New York adopted California emissions standards,but not the built,and equipped to meet the State's stringent ami-smog standards. 2.If your vehicle faits a,Smog Check inspection,all necessary repairs provides for your vehicle under the emissions control warranty in California Emissions Warranty;theFederal Emission Control Warranty Ford must warrant the emission control system on your vehicle for the and adjustments will be made by Ford to ensure that your vehicle accordance with the regulations of the California Air Resources Board. applies to all non-PZEV vehicles in New York) periods of time listed on pages 24-25,Provided them has been no abuse, passes the Inspection.This Is your emission control system This coverage lain addition to Federal Emission warranties(Page 17).. •Medisrm-Duty Passenger Vehicles(up to 10,000 pounds GVWR neglect,or improper maintenance of your vehicle. PERFDRMANCE WARRANTY. - - Your emission control system may include parts such as the carburetor Fmnionawaea�br CMINal Camasyhkila incomplete primarily for Use transportation of persons.Excludes or fuel injection system,the ignition system,catalytic converter,and the Owner's Warranty Responsibilities _ Person Tete l or over locks with a seating capacity either over twelve persons total or over rano persons rcazurerd of the driver)i seat;or engine computer.Also included may be hoses,belts,connectors,and other As the vehicle owner,you are responsible for the performance of the p1Y°' trucks with an open cargo area of at least six feet of interior length): emissions-related assemblies. required maintenance listed In your owner's manual.Ford Motor AAzem California.Connecticut Maine,Maryland,Massachusetts, Where a warrantable condition exists,Ford Motor Company will repair Company recommends that you retain all receipts covering maintenance Oregon,Rhode Island Vermont and Washugcon your vehicle at no cost to you including diagnosis,parts,and labor. on your vehicle,but Ford cannot deny warranty coverage solely for the -Medi®-Duty Vehicles(over 8,500 poaWa CVWR up to 14,000 Manufacturer's warranty Coverage lack of receipts or for your fathrre to ensure the performance of all pounds GVWR)-Arizona,California,Connecticut Maine.,Maryland, scheduled maintenance. r, Massachusetts,Oregon,Rhode island,and Vermont. For Vehicles Ves cls Wei for acnglEmission Warranty Coverage '• -Mot Heavy-Duty Diesel Engine Vehicles(over 14,000 pounds If Gross Vehicle Weight Rating Californian 14,000 lbs.or less: Yen are responsible for presenting your vehicle to a Ford Motor # GVWR up to 19,600 pounds GVWR)-California,Maine,and For 3 yens or 60,000 miles(whichever first occurs): Company dealer as seen as a problem exists.The warranty repairs f Pennsylvania should be.completed in a reasonable amount.of time.,not to exceed 30 P' 1.R your vehicle fails a Smog Check inspection,all necessary repaim and days. I'' - Vehicles,Eligible for California PZEV Emission Warranty Coverage adjustments will be.made by Ford to ensure that your vehicle Passes the California Partial Zero Emission Vehicles(PZEV)have extended coverage on inspection.This is your emission control system PERFORMANCE WARRANTY As the vehirle°weer,you should alas be aware that Ford Motor all emission related parts.This extended warranty coverage applies if your 2.If any emissions-related part on your vehicle is defective,lite Dart will Company may deity you warmaty coverage if your vehicle or a part has li vehicle i P'LEV certified as indicated on.the VECI label and is registered in a [ailed due W abuse,neglect,improper maintenance,or unapproved vmw•wayvrau, � sure that has adopted and Is ems California PZEV emissions warranty, be repaired or replaced by Ford.This is your short-term emission control JV —'sem sras •s mf°8 system DEFECTS WARRANTY. modiftcat°ns- a,.'m,, which may include the following states,subject to change:California ea.a aawew.ama ry ea nrummc<•uamcwat •••�ew•..e�me•.sasses.^m,ovwa+,.�.�te•sr�+•'s+amm� Connecticut,Maine,Maryland,Massachusetts,New Jamey,New�York,Rhode For 7,years or 70,000 miles(whichever fust occurs):: If you have any questions regarding your warranty rights and •••• vaamem.n•r®a mr+,mw,wn If aneMssions-related part listed on page 27 with coverage for 7 years or responsibilities,or if you want to report what you believe to be violations t `°14`"bnb°1nmitl" Island or Verman 70,000 miles is defective,the pan will be repaired or replaced by Ford- of the terms of this warranty,you may contact the Ford Customeror Hill details about coverage under California requirements for This is your long-term emission control system DEFECTS WARRANTY. Relationship Center at l-8W�82-3673(FORD)or the California Air ! Vehicles Eligible Wa for CaliforniaCagtomle Emission Warranty Coverage emissions control,see: Resources Board at: j California emission warranty coverage applies if your vehicle meets the •Defeeta Warranties(pages 24-30) If Grass Which,Weight rating is over 14,000 lbs.: following two requirements: +Performance lRexpanty(pages 2425) For 6 yearn or 60,000 miles(gasoline powered engines mid vehicles)or Stets of California Air Resources board You vehicle R registered in a state'that has adopted and is enforcing •What Is Covered?(pages 26-29) 5 years or 100,000 miles(diesel powered engines and vehicles) Mobile Source Operations DfvJsion California emission warranty regulations applicable for your vehicle at -What Is Not Covered?(page 29) (whichever first occurs): 9528 Telstar Arence If an emissions-related part on your vehicle is defective;the part will be El Monte,CaBforafa 91731.2990 the time of repair,and f repaired or replaced by Fox.This is your emission control system •Your vehicle is certified for sale In California as Indicated on the DEFECTS WARRANTY. vehicle emission control information label. 24 28 1 22 E Important Information about LJst of Parts WHAT IS COVERED? ."w•s^re w• There may be additional coverage for these parts through the Bumper to V the parts on the following list contains a defect that.affects.emissions, ,,,•,",says"""""" " I Bumper,Powertrain,or Diesel Engine limited warranties.In any case,the they are covered by the Defects Warranties. awx^sa•air" warranty with the broadest coverage applies. •Air Flow Sensor •Fuel Injection System w,e•a. Also covered by this warranty are all emissions-related bulbs,hoses, •Air/Fuel Feedback Control •Fuel Injector Supply Manifold "'"^^''• "••'°9'•v"""" clamps,brackets,tubes,gaskets,seals,belts,connectors,non diesel ilei System and Sensors Fuel Tank(nondiesel only) " Lines,and wiring harnesses that are used with components on the list of •Air Induction SystemFuel Tank Pressure Control . r ws rs Y • parts above. •Catalytic Converters(including Valve "wea•s• aA Concerning parts that should be replaced on a certain ahrtomnce Selective Catalytic Reduction •idle Air Bypass Valve rn schedule:these parts remain under warranty until the first required and Diesel Oxidation Catalysts) •Ignition e Coil and/or Control •, v ME replacement time that is specified in your Owner Guide and the •Cold Start Enrichment System Module 5 " 6 Scheduled Maintenance Guide. I (diesel only) Intake Manifold _ NOTE:If the diagiosis does not reveal a defect,the Defects Warranty •Controls for Deceleration .•Interecoler Assembly-Engine w•.+vas" ws " it does not apply. E (diesel only) Charger(diesel and 2.66 � + S Your Ford Motor Company dealer maintains a complete list of covered Diesel Exhaust Fluid System I EcoBoost engines only) 'Ls wr parts.For more details about the specific parts that are covered by the i •Dim)Particulate Filter .Malfunction Indicator Lamp " rn wv7 Defects Warranty,contact your dealer. •Electronic Ignition System (MB.)/Ori Board Diagnostic _ •$ WHAT IS NOT COVERED? Cdiesel only) (ODD)System , Ford Motor Company may deny you emissions warranty coverage R your .Electronic Engine Control •PCV System and OR Filler Cap 333 wee ser" vehicle or a part does not contain a defect that affects emissions or has Sensors and Switches +Secondary Air Weetion.System failed because of abuse,neglect,improper maintenance,unapproved •Electronic Engine Control Unit .Spark Control Components P a•esv sae. modifications,or any items included in What Is Not Covered?,pages (ECU). •Spark Phrgs and ignition Wires gg qg +•save. g °oe we w 1245. •Evaporative Emission Control C E C .woe" •Thermostat System � 3 +Exhaust Gas Recirculation Throttle Body Assembly(ME") > hyo " (ECR)System •Transmission Control Module " Y " • Exhaust Manifold (TCM)and Solenoids 8 g •Exhaust Pipe(Manifold to 'T)uboChatger Assembly gC g d 8ig e: 8g $ - Catalyst) fie •Vacuum Distribution System A^t g 4 ! 3 !gg gg g ! d �••5- � �V� ! •Fuel Filter Cap and Neek . y Restrictor(nor iesel only) S $ fi8g •Includes hardware and emiasiens related software changes only MAN ME JIM 27 26 29 2e ....._... iii ®� WHAT REPLACEMENT PARTS SHOULD t USE? I Ford Motor Company recommends that You use genuine Ford a replacement parts.however,when you are having non-warranty work NOISE EMISSIONS WARRANTY FOR CERTAIN LIGHT TRUCKS MORE PROTECTION FOR YOUR VEHICLE HOW 00 1 GET WARRANTY SERVICE? donee t your vehicle,you may choose to use equivalent parts.if you You can et additional protection for yaw new car or light truck by To get service under your emissions vvarranttes,take your vehicle to any deride to use tion-Ford parts,be sure they are equivalent to Ford parts Ford Motor Company warrants to the first person who Purchases tluis g in performance,quality,and durability.If you use replacement parts that vehicle for purposes other than resale and to each subsequent purchaser purchasing a Ford Extended Service Plan(Ford ESP).Ford ESP service Ford Motor Company dealer as soon as Possible after illumination of the are not equivalent to Ford parts,your vehicle's endsaions control systems ] that this vehicle m manufactured by Ford,was designed,built and connects are backed by Ford Motor Company and they provide: Malfunction Indicator Light or it flea failed anEPA-approved teat ora may not work as effectively,and you may Jeopardize your emissions equipped to conform at the time it left Fort's control with all applicable •additional benefits during the warranty period depending on the plan California Smog Check inspection.Be sure to show the dealer the warranty coverage U.S.EPA Noise Control Regulations.. you purchase(such as:a]temative transportation and coverage for document that says your vehicle has failed Ute test. This warranty covers this vehicle as designed;-built and equipped by certain mairaterance and weaz ibeme;cove raga for certain maintenance Your dealer will determine whether the repair is covered by the warranty. For vehicles within the warranty period,Ford will repair at no cost to and.. It the dealer has a question about Emissions Performance Warranty the owner,under the Federal Emissions Warranty,covered emersion and wear nntena Ford Motor Company,and is not limited to any particular part, coverage,it will forward the question to Ford Motor Company,which failures caused by properlq.installed Fart parte or non-Ford parts that component or system of the vehicle as manufactured by Ford Defects in •extended protection after your Bumper to Bumper Warranty expires, must make a final decision within 30 days after you brig[your vetilcle,in have been certified by the U.A.Environmental Protection Agency(EPA): design,assembly or in any part;component or system of the vehicle as You may purchase Ford ESP from any Ford Motor Company dealer or for repair.(The decision will be made within a shorter time if state,local, Ford is not responsible for the cost of repairing any emission failures manufactured by Ford,which,at the time It left Ford's control,Mused visit our website at Ford-ESP.com.There are several Ford ESP plans or federal law requires you to have the vehicle reptined more quickly in caused by non-Ford parts that have not been certified by the EP& noise emissions to exceed Federal standards,are covered by this available in various time,distance and deductible combinations.Each order to avoid additional penalties.)The deadline for a determination warranty for the life of the vehicle. about Emissions Performance Warranty Coverage does not need to be The mdnr s once'replacement,or ed by of emissionsiii control plan fa tailored to fit your own driving needs,including reimbursement devlcee or eyatema ten be performed tiY coq antomoiive repair THENOISEEMISSIONS WARRANTY 013L IGATIONS DO NOT APPLY TO: for towing and rental vehicles. met R you request a delay,agree to a delay in writing,or V the delay is establishment or individual using Ford replacement parts or EPA •loss of time,inconvenience,loss of use of the vehicle,commercial loss When you purchase Ford ESP,you receive ecce-of-mind Protection mused by an event for n about neither Ford nor your dealer r fo��prep hs dura voiding w gene federal er i warranty coverage P coverage is.if a question about Emissions Performance Warranty for future repairs during the warranty period. or,other consequential damages. throughout the United States and Canada,provided by a network of coverage is referred to Ford Motor Company,you will be notified by Forel •any vehicle which is not covered by the U.S.EPA Medium and Heavy more than 4,600 Ford Motor Company dealers. Motor Company in writing if your claim for wmranl-v coverage is denied. PROPER MAINTENANCE PRESERVES YOUR WARRANTY Trucks Noise Emission Standards(40 C.F.R.Part 205,SubpartB). This information is subject to change.Ask your dealer for complete The notice will explain the basis for denying your claim.If you fail to If you do not maintain your vehicle properly,Ford may have the right to Among the non-covered vehicles are those lacking a Partially or fully details about Ford ESP coverage. - receive this notice.within a timely manner,as determined above,Ford deny you warranty coverage. enclosed operators compartment,such as a basic stopped chassis, will perform the warranty repair for you free of charge. To have repairs made under this warranty.You may have to show that those having a Gross Vehicle Weight Rating of 10,000 pounds or less, HOW DO I HANDLE EMERGENCY REPAIRS? you have followed Fords inatmetiorw on properly,maintaining and using and those soldoutside the United States and its territories.lb the extent permitted by law,THIS WARRANTY IS EXPRESSLY INSTEAD R your vehicle needs an emergency f arFord le repair and a Ford Motor your vehicle.You will find these.Be sue to your Owner Guide and of any express or implied warranty,condition,or guarantee, cannot PerforCompany mwarrantable is not available, within 30odays of yotor u bringing and dealer to keep uled Maintenance records of all maintenance works service receipts agreement,or representation,by any person with respect to conformity of this vehicle with the U.S.EPA Noise Control your vehicle to the dealer,repairs may iv Performed at any service CUSTOMER ASSISTANCE Regulations,including ANY IMPLIED WARRANTY OF - establishment or se you or using Ford equivalent replacement parts. MERCHANTABILITY OR FITNESS. Ford will reimburse you for the cost of these warranty repairs including U you are not satisfied with the handling of warrenLyand matter,see diagnosis,V yrxr take the parts)that are replaced and the repair Customer Assistance,on the inside hunt cover,and Hatter Business. receipt(s)to a Ford Motor Company dealer.The reimbursement shall not. Bureau(BBS)AUTO LINE program,page 34. exceed Ford's suggested retail price for thewarranted parts that we replaced and labor charges based on Fords recommended time allowance for the warranty repair and the geographically appropriate hourly rate. 32 33 30 31 You may ce prep whether the vehicle g the equipped with the Ford Ambulance Prep Package by inspecting the information plate on the drivers rear door pillar. . You may determine whether the ambulance manufacturer has followed - Your satisfaction is important to Ford Motor Company and to your dealer. These state laws-sometimes railed lemon laws-allow-owners to receive Ford's mcomm,ndations by contacting the ambulance manufacturer of If a warranty concern has not beers resolved using the three-step a replacement vehicle or a refund of the purchase price,under certain Your vehicle. procedure outlined on the first page of the Customer Assistance section, circumstances.The laws vary from state to state. ® you may be eligible to participate in the BAB AUTO LINE Program. To the extent your state law allows,Ford Motor Company requires that The BBB AUTO L INE program consists of two puts—mediation and you fust send us a written notification of any defects or non-confornuties arbitration.During mediation,a representative of the BBB vdn contact that you have experienced with your vehicle.(This will.give us the both you and Ford Motor Company to explore options for settlement of opportunity to make any needed repairs before you pursue the remedies the claim.If an agreement is not reached during mediation and your provided by your state's law) Ford Motor Company authorizes only Ford QluaBed Vehicle Modifiers claim is eligible,i you may participate in the arbitration resentprocey An (QVhis)to perform Ford Expedition EL conversions.To obtain a list of in ninon hearing will of scheduled so that you can present your case In all other states where not specifically required by state few,Ford in an infornal setting before an impartial person.The arbitrator willMotor Company requests that you give us the written notice.Send your QVM's,visit our website at wwwAeet.ford.comAimo or call consider the testimony provided and snake a decision after the heating. written noLifcativn to: 1.800-34-FLEET.Expedition EL is suitablefor limoushis conversion only Ford Limousine Builders Package.11te You are not bound by the decision,but should you choose to accept the Ford Motor Company if equipped with the proper Fwith the Limousine B Package. BBB AUTO LINE decision,Ford must abide by the accepted decision as Customer Relationship Center wheelbase on the Expedition or wail.Disputes submitted to the BBB AUTO LINE program are usually (17L)may NOT be extended beyond 140"(258.89 total wheelbase)or N P.O.Boz 8248 a manner that results in a Gross Vehicle Weight Rating(GV WR) decided within forty days after you file your claim with the BBB. Dearborn,I1II 48126 exceeding 9,900 pounds. BHB AUTO LINE Application:Using the information provided below, please can or write to request a program application.You will be asked B an Expedition EL Limousine is NOT equipped with the Limousine for your name and address,general utformation about your new vehicle, Builders Package or it is equipped with the Limousine Builder's Package information about your warranty concerns,and any steps you have but its wheelbase is extended beyond its limitations or if it's GV WR already taken to try to resolve them A Customer Claim Form will he exceeds the weight limitations,than the New Vehicle Limited Warranty is mailed that will need to be completed,signed,and returned to the.BBB - voided,any Ford Extended Service Plan(ESP)contmct is voided, along with proof of ownership.Upon request,the BBB will review the Ford vehicles are suitable for producing ambulances only if equipped applicable Emissions warranties may be voided,and the vehicle modifier claim for eligibility under Program Summary Guidelines. with the Ford Ambulance Prep Package.In addition,Ford urges may be considered the vehide'manufacturer"for Emissions Warranty You can get more information by caling SBB AUTO LINE at ambulance manufacturers to follow the recommendations of the Ford coverage purposes(including responsibilities for emissiom,warranty, 1400-9665300,or writing to Incomplete Vehicle Manual and the Ford Tknck Body Builders recall,and in-use compliance). - BBB AUTO LINE Wont Book(and pertinent supplements). Any other Ford vehicle converted to a limousine will void the New 4200 Wilson Boulevard,Suite 800 Using a Ford vehicle without the Ford Ambulance Prep Package Vehicle Limited Warranty. Arlington,Virginia 22203-1833 to produce an ambulance could result in elevated underbodq BBB AUTO LINE,applications*can also be requested by calling the Font temperatures,fuel.overpreasenization,and the risk of fuel Motor Company Customer Relationship Center at 1-800392-3673. expulsion and area.Such use also voids the Ford Bumper to Note:Ford Motor Company reserves the right to change eligibility Bumper Warranty and may void the Emleefons Warranties. fimitations,modify procedures,or to discontinue this process at any time without notice and without obligation. 35 35 34 _._....,,.„,,.,..w.,.......,...... ._...... .. ................ .. .__ _.................. ' i 1 CUSTOMER #:•1016251 146140 L . B . S M ITIH LINCOLN *INVOICE* KAREN ROY 1 100 MARKET ST LEMOYNE, PA 1704 3 (717) 761-6700 (800) 422-3173 1075 LJxNCASTER BLVD APT 1 www.lbsmithford.Com MECHANJCSBU.RG, PA 17055-4473 PAGE 1 HOME: CONT-N/A BUS: CELL:717-425-8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS COLOR; YEAR 3(JhAKE(MODEL'. VIN LICENSE/REG.it MILEAGE 113/OUT TAG GRAY 12 ' FORD FIESTA 3FADP4BJ7CM207664 JFC5717 16431 1643 E59 DEL. DATE PROD. DATE WARS. EXP... PROMISED PO NO. RATE PAYMENT INV. D 03MAR1-J D WAIT 23OCT13 90 .00 CASH 230CT1 R.O.OPENEp READY OPTIONS: ENG:1 .6_Liter_Ti—VCT 1 01: 54 23OCT13 08:39 230CT13 LIST NET TO L LINE OPCODE TECH TYPE HOURS A C/S 'TRANS MAKES FUNNY NOISE HAVE SOMEONE ROADTEST W/HER MISC RUN DIAGNOSTICS AND ROAD TEST. TRANS NEEDS REPAIRS DONE TO IT. CUSTOMER TO RETURN AT LATER DATE. (NIC) . 193 ISP 0 .60 PARTS: , .0. 00 LABOR: 0 . 00 OTHER _ 0 . 00 TOTAL LINE A: 0 . 00 .rs; is 1. Q PLAINTIFF'S J EXHIBIT W WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE DESCRIPTION - TOT S RSHIP ASIS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT. WARRANTIES` EXPRESS AND—I10IFLIED, INCLUDING ANY IMPLIED WARRANTIES OF HOURS LABOR AMOUNT 0. 00 MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR AUTHORIZES ANY OTHER PERSON TO ASSUME FOR ANY LIABILITY IN CONNECTION WITH THE MON-FRI PARTS AMOUNT 0. 00 IT SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS,OIL,LUBE 0 00 ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES.CUSTOMER SHALL NOT BE ENTITLED TO SAT SUBLET AMOUNT O O 0 RECOVER FROM THE DEALERSHIP ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, SAM TO 4PM MISC.CHARGES DAMAGES FOR LOSS OF�USE,LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER INCIDENTAL I AMAGES. TOTAL CHARGES I 0 0 0 By signing below,, You acknowledge that you were notified of and authorized the ALL PARTS ARE NEW Dealership to perform the s6rvices/repairs itemized in this Invoice and that you received UNLESS OTHERW'Iff LESS INSURANCE I 0 00 (or had the pportunity to inspect)any replaced parts as requested by you.The vehicle INDICATED. SALES TAX 3 0 0 0 i ..no in r rn h for r m nAmount DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY THIS AMOUNT 0' 00 CUSTOMER COPY D a e—<AP 2006 ADP(03(091 SERVICE INVOICE TYPE 2.2SI2C-'ASIS'-PENNSYLVANIA-9698082 s CUSTOMER #: 1016251 146622 L . B . SMITH *INVOICE* LINCOLN KAREN ROY 1100 MARKET ST LEMOYNE, PA 1704. 1075 LANCASTER BLVD APT 1 DUPLICATE 1 (717)www.lbsmithford.com(8001413 w.l MECHANICSBURG, PA 17055-4473 PAGE 1 HOME: CONT: 737-4511 102 BUS : .717-737-.4511 CELL: 717-425-8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS COLOR YEAR MAKE/MODEL VIN LICENSE/REG, # MILEAGE IN/OUTI TAG GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 16605/1660$ 6 DEL. DATE PROD. DATE WARR.:EXP. PROMISED PO NO. RATE PAYMENT INV. D E 03MAR12 D 18 : 00 290CT13 90 . 00 CASH 05NOV1 R.O. OPENED READY OPTIONS: ENG: 1 . 6—Liter—Ti-VCT 07: 50 290CT13- 15: 19 05NOV13 LINE OPCODE .TECH TYPE HOURS LIST NET TOTIL A CUSTOMER STATES TRANMSSION IS ACTING UP OPULLING OUT AND NOISEY CAUSE: . CHECK AND REPAIR TRANS 70.00F AUTOMATIC TRANSMISSION ELECTRONIC DIAGNOSIS DIAGNOSIS (7000) - L 193 W 0 . 60 (N/,) 1 .CA6Z*7A508*D CYLINDER ASY - CLUTCH SLAVE (N/: ) 1 BV6Z*7B546*D CLUTCH ASY r -• --• (N/ ) 7.0b3A •R&R TRANS ASSY 193 W 4 .:30. . . CN/ ) 70:03A3 REPLACE TRANS CLUTCH; 'AND. >SLAVE. 193 W 0 . 70: (N/ ) FC:, P66 42 PART# : COUNT: CLAIM TYPE: AUTH' CODE: 00472 PARTS: 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 TOTAL LINE A: 0 . )0 16605 CHECK OUT AND R&R TRANS, DISASSEMBLE AND REPLACE CLUTCH AND SLAVE CYL. REPROGRAM AND ROAD TEST. B .CK L/F SPEAKER RATTLES CAUSE: CHECK AND REPLACE LT FT SPEAKER. 188.08AF•.CHECK AND REPLACE LT FT DOOR SPEAKER. 158 W 0 .40 i(N 1 BE8Z*18808*A SPEAKER ASY FC: A-06 42 PART# : BE 8 Z*18 8 08*A ¢ w PLAINTI FF'S COUNT': W EXHIBIT CLAIM TYPE: RUTH CODE: ' 00228 - PARTS: 0 . 00 LABOR: 0 . 00 OTHER: AL LINE B: O . DO 16605 COMPLETED ORDERD SPEAKER FORD. R R DRIVERS DOOR PANEL WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE DESCRIPTION tOTA UT 1Mt RSHIP AS-IS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT. WARRANTIES, EXPRESS AND 7IORSLIED, INCLUDING ANY IMPLIED WARRANTIES OF HOURS LABOR AMOUNT MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR AUTHORIZES ANY OTHER.PERSON T0,ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE MON-FRI PARTS AMOUNT SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS,OIL, LUBE ORIGINAL.PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES.CUSTOMER SHALL NOT BE ENTITLED TO SAT SUBLET AMOUNT RECOVER FROM THE DEALERSHIP ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, 8AM TO 4PM MISC. CHARGES DAMAGES FOR LOSS OF USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER INCIDENTAL DAMAGES. . TOTAL CHARGES By signing below, you acknowledge that you were notified of and authorized the ALL PARTS ARE NEW Dealership to perform the services/repairs itemized in this Invoice and that you received UNLESS OTHERWISE LESS INSURANCE (or had the opportunity to inspect)any replaced parts as requested by you.The vehicle INDICATED. SALES TAX i i r u'n n for r m n h Am un Due, -- — - --_ DATE: CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY THIS AMOUNT j CUSTOMER COPY (14 Pr'rAP 02.006 ADP 103/091• SERVICE INVOICE TYPE 2•2S12C-"AS-IS'•PENNSYLVANIA•9698082 CUSTOMER #: 1016251 146622 L ■ ■ SMITH! LINCOLN *INVOICE* KAREN ROY 1 100 MARKET ST LEMOYNE, PA 1 704 10.75 LANCASTER BLVD APT 1 DUPLICATE 1 (717) ws (800) 422-3683 ww.lw.lbsmithford.com MECHANICSBURG, .PA .17055-4473 PAGE 2 HOME: CONT: 737-4511 102 BUS : 717=737-4511 CELL: 717-425-8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS COLOR YEAR MAKE/MODEL VIN LICENSE/REG. # MILEAGE IN /OU TAG GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 1660S/16605 6 DEL. DATE PROD:'DATE WARR.:EXP PROMISED PO NO. RATE PAYMENT IN1 D TE 03MAR12 D 18 : 00 290CT13 T90 . 00 CASH 05NOV1 R.O. OPENED,' ' READY OPTIONS: ENG: 1. 6 Liter Ti-VCT 07 : 50 290CT1.3 15 : 19 05NOV13 LINE OPCODE TECH TYPE HOURS LIST NET 'TOT L REPLACE SPEAKER. C CK BRAKES DO .NOT FEEL TIGHT SEE RUSS CAUSE: CHECK AND ADJUST BRAKES MT2000 CHECK OUT AND ADJUST REAR BRAKES . 158 W 0 . 30 FC" HOS 07 :. I FART#: 2200 -r COUNT: , r CLAIM TYPE: AUTH CODE: 00228 PARTS : 0 . 00 LABOR: O:. 00x OTH R d:. 00 -TOTAL LINE C: j0 . 0 16605 COMPLETED, TEST DROVE CNV. CHECK BRAKES AND ADJUST REAR BRAKES. D TAP LOANER CAUSE: TAP .LOANER 77 TAP LOANER 999 WL 0 . 00 KN/; ) FC: A99 82 PART# : TAP1 I COUNT:. CLAIM TYPE: TAP1 AUTH CODE: PARTS : 0 . 0 0 LABOR: 0 . 0'0 {1 "HER 0 0 0 y'," TOTAL LINE D: ; 0 . 0 E COMPLETED MULTI-POINT INSPECTION REPORT CARD- 40 99P COMPLETED MULTI-POINT INSPECTION REPORT CARD- 40 '158 CP 0 . 30 0 . 00 ; 0 .' 0 WARRANTY DISCLAIMER: ALL PARTS 'AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE DESCRIPTION TOTAL, "UVIUk:U by. HE DEALERSHIP AS-IS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT. WARRANTIES, EXPRESS AND WrFLIED, INCLUDING ANY IMPLIED WARRANTIES OF HOURS LABOR AMOUNT I MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR AUTHORIZES ANY OTHER PERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE MON"FRI PARTS AMOUNT SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS,OIL, LUBE ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES.CUSTOMER SHALL NOT BE ENTITLED TO SAT SUBLET AMOUNT RECOVER FROM THE DEALERSHIP, ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, gAM TO 4PM MISC. CHARGES ' DAMAGES FOR LOSS OF USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER INCIDENTAL DAMAGES. TOTAL CHARGES By signing below, you acknowledge that- you were notified of and authorized the ALL PARTS ARE NEW Dealership to perform the services/repairs itemized in this Invoice and that you received UNLESS OTHERWISE LESS INSURANCE (or had the opportunity to inspect)any replaced parts as requested by you.The vehicle INDICATED. SALES TAX is in returned r in han or our a h Amount e. DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY THIS AMOUNT CUSTOMER COPY D612rtAP©2006 ADP,103/09) SERVICE INVOICE TYPE 2-2S12C-"AS-IS"-PENNSYLVANIA•9698082 CUSTOMER #: 1016251 146622 L . B . SM 'T • *INVOICE* LINCOLN KAREN ROY" 1100 MARKET ST LEMOYNE, PA 170', 3 1075 .LANCASTER BLVD APT 1 DUPLICATE 1 (717) 761-6700 (800) 422-3573 www.lbsmithford.com MECHANICSBURG; . PA 17055-4473 PAGE 3 HOME: '• CONT: 737-4511 102 BUS : 717-737.4511 CELL: 717-425-8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS COLOR YEAR MAKE/MODEL VIN LICENSE/REG. tt. MILEAGE IN /OUT TAG GRAY 12 FORD.:FIESTA 3FADP4BJ7CM207664 JFC5717 16605/16605 T6 DEL. DATE '::PROD.:DATE: `WARR.;EXP. PROMISED;:. :, PO NO. RATE PAYMENT INV. C ATE 03MAR12 DEJ 18 : 00 290CT13 1 90 . 00 CASH 105NOV13 R.O.-OPENED..:: READY OPTIONS: ENG: 1 . 6 Liter Ti-VCT 07 : 50 290CT13 15 : 19 05NOV13 LINE OPCODE TECH TYPE HOURS LIST NET TOIEL GBATT BATTERY CHECKS GOOD .158 CP 0 . 00 0 . 00 0 .00 GBK BRAKE LINING WEAR CHECKED. BRAKES WEARING OK AT THIS TIME 158' CP 0 . 00 0 . 00 0 .100 .GTIRE. TIRE TREAD WEAR CHECKED. T.IRES. .WEARING OK AT THIS TIME . x 158 CP 0 . 00.. ' 0 . 00 0 . 00 PARTS : 0 . 00 LABOR 0.00 4T ` �. 000 TOTAL LINE E: 0 . 00 16605 COMPLETED + IMPORTANT You may receive a survey from Ford Motor Company shortly. Your Complete Satisfaction is our goal. If for any reason you cannot give us an "Excellent Rating" please contact your service manager, Steve Vancena before mailing the survey. L.B. Smith Ford Lincoln 717-761-6700. WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE DESCRIPTION TOTAL; V.000t:0b RSHIP AS-IS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT. WARRANTIES, ' EXPRESS AND FLIED, INCLUDING ANY IMPLIED WARRANTIES OF HOURS LABOR AMOUNT Q Q MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR AUTHORIZES.ANY OTHER•PERSOWTO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE MON-FRI PARTS AMOUNT SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS,OIL, LUBE 0 . 0 ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES.CUSTOMER SHALL NOT BE ENTITLED TO SAT SUBLET AMOUNT Q , Q RECOVER FROM THE DEALERSHIP ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, SAM TO 4PM DAMAGES FOR -LOSS OF*USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER MISC. CHARGES Q INCIDENTAL DAMAGES. By signing below, you acknowledge that you were notified of and authorized the ALL PARTS ARE NEW TOTAL CHARGES Q , Q Dealership to perform the services/repairs itemized in this Invoice and that you received UNLESS OTHERWISE LESS INSURANCE 0 , 0 (or had.the opportunity to'inspectl any replaced parts as requested by you.The vehicle INDICATED is being returned to you in exchange for Your payment of the Amount Due . SALES TAX Q , 0 DATE -CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY THIS AMOUNT 10 . to ,,� CUSTOMER COPY D6a_1 rCAP 02006 AOP(03/09) SERVICE INVOICE TYPE 2.2S12C-"AS-IS"-PENNSYLVANIA-9698082 Q) 148312 L . B . S M IT CUSTOMER, # : 1016251 / LINCOLN *INVOICE* 01&&I $ KAREN ROY 1 100 11MARKET1- 6700L(8 0) 422- 0 4 3 3673 1075 LANCASTER BLVD APT 1 www.lbsmithford.com MECHANICSBURG, PA 17055-4473 PAGE 1 HOME: CONT:425-8455 BUS : 717-737-4511 CELL: 717-425-8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS `COLOR' YEAR MAKE/MODEL VIN LICENSE i REG.41 MILEAGE IN /OUTAG GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 17096/170961563- ©EL.DATE PROD.DATE ..WARR..EXP: PROMISED PO NO. RATE: PAYMENT INV.V. D TE 03MAR12 D 16 : 00 18NOV13 90 . 00 CASH 27NOV1:_ R.O.'OPENED READY OPTIONS: ENG: 1 . 6 Liter Ti-VCT 07 : 32 18NOV13 14 : 55 27NOV13 - LINE OPCODE TECH TYPE HOURS LIST NET' TOT L __ A CUSTOMER STATES WHEN DRIVING AROUND 35 MPH AND UNDER MAKES A NOISE , JUST IN CAUSE: CHECK OUT AND REPAIR TRANS . I 7000F AUTOMATIC TRANSMISSION ELECTRONIC DIAGNOSIS - DIAGNOSIS (7000) - L - 221 W 0 . 60 _ - I{N/ ) 1 AE8Z*7060*A SHAFT ASY 1 AE8Z*7052*C SEAL:A:AY .-` ;OZL (NI' ) 1 AE8Z*7064*B SNA;P.t;RTNG . (NI: ) 2 *W705448*S441 NU T• (N/ ) 1 AE8Z*7007*A PLA CY ItNDE�t ��;OQK. 'REAR (NI ) 1 2S6Z*9450*A GASKET (N/7) 2 *W703662*S403 NUT -+ KEX \ 2 *W709618*S442 BOLT (N1 ) 2 *W5202.03*S442 NUT - HEX. (N� ) 1 YS4Z*3N324*AA RETAINER - BEARING (NIC) 2 *W520102*S442 NUT - LOCKING (NIC) 1 BRS*172* SEAL ._{,_. (NIC) 1 AE8Z*7118*A BEARING ASY - NEEDLE: ': (NIC) 2 *W790208*S900 BOLT (N/ ) 1 *W790236*S900 BOLT (NIC) 2 AE8Z*7B498*A SEAL (NIC) 3 AE8Z*7B498*B SEAL (NIC) 1 *W790198*S900 BOLT (NIC) 1 9U7Z*19A506*BA GREASE - CHASSIS LUBRICATION (NIC) 1 PM*4*A BRAKE CLEANER (NIC) 1 XL*2* LUBRICANT - UNIVE.RSAL ,ANTL-SEI . (NIC) 1 TA*16* ADHESIVE `I a PLAINTIFF'S (NIC) 2 XT*11*QDC FLUID - TRANSMISSI'ON -1 EXHIBIT (N ) 7003A R&R TRANS ASSY. a 221 W 4 . 30 (NIC) J 7003A2 MANUAL TRANSMISSION ASSEMBLY - OVERHAUL a (7003) - LT.7 �n _ (Nf_-) SERVICE DEPT. DESCRIPTION IOT ,AS FWAF tiI1-10RI .{. I HOURS LABOR AMOUNT MER AUT MON-FRI PARTS AMOUNT SALI ACC You may receive a survey from Ford Motor 7:30AM TO 6PM GAS,OIL, LUBE ORK SAT SUBLET AMOUNT R n Company shortly. Your Complete Satisfaction is our 8AM TO 4PM MISC. CHARGES " By goal. If for any reason you cannot give us an %LL PARTS ARE NEW TOTAL CHARGES DeaUNLESS OTHERWIff LESS INSURANCE `F kcrllent Ratitig" please contact your service INDICATED. SALES TAX is b D, SENTATIVE SIGNATURE PLEASE PAY .� manager, Steve Vancena before mailing the survey. THIS AMOUNT L.B. Smith Ford Lincoln 717-761-6700. - - - ,�/�— COPY f- 'rrCAP©2006 ADP,03/091 SERVICE INVOICE TYPE 2-2S12C-'AS-IS"-PENNSYLVANIA-9698082 I 148312 L . B . SMITH CUSTOMER #: 1016251 '�� 1, LINCOLN *INVOICE* 1100 MARKET ST LEMOYNE, PA 1704 KAREN ROY (717) 761-6700 (800) 422-3673 1075 LANCASTER BLVD APT 1 www.lbsmithford.com MECHANICSBURG, PA 17055-4473 PAGE 2 HOME: CONT:425-8455 BUS: 717-737-4511 CELL: 717-425-8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS COLOR: YEAR 1VIAKE/MODEL '' VIN LICENSE/REG,# MILEAGE IN/OUT TAG GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 17096/17096 563 DEt.'OAT1 PROD. DATE V1/AFtR, EXP' ;; PROMISED PO NO. RATE f?AYMENT INU. D TE 03MAR12 D 16 : 00 18NOV13 90 . 00 CASH 27NOV1 R'.O: pPENED READY OPTIONS: ENG: 1 . 6_Liter_Ti-VCT 07 : 32 18NOV13 14 : 55 27NOV13 LIST NET TOT L LINE OPCODE TECH TYPE HOURS FC: N12 42 PART#: COUNT: CLAIM TYPE: AUTH CODE: 00076 PARTS : 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 TOTAL LINE A: 0 . 0 17096 ROAD TEST AND RUN DIAGNOSTICS.... REMOVE AND DISASSEMBLE TRANS. REPAIR LOOSE BEARING SUPPORT" R'EASS.EMBLE AND REINSTAILL REPROGRAM PCM/TCM. ..r B CHECK E BRAKE, CIS TOO .TIGHT VERY HARD TO I?GP ?IiY. CAUSE: CHECK AND ADJUST EBRAKE 2780B PARKING BRAKE - ADJOST (:2780)` (N/ 221 W 0 . 60 FC: H04 07 PART#: COUNT: CLAIM TYPE: AUTH CODE: 00076 3 PARTS: 0 . 00 LABOR: 0 . 00 OTHER:; ,; 0 . 00 TOTAL LINE B: O . Do 17096 INSPECT PARKING BRAKE SYSTEM. VER,JFI,EU LEVER HANDLE HARD TO PLULL. ADJUST CABLE SLACK. VERIFIED CORRECT OPERATION. C TAP LOANER CAUSE: TAP LOANER 77 TAP LOANER (NIC) 999 W 0 . 00 FC: A99 82 PART#: TAP1 COUNT: CLAIM TYPE: TAP1 AUTH CODE: PARTS : 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 TOTAL LINE C: 0 .100 WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE ',' DESCRIPTION: . _IOTA,S RSHIP AS-IS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT.13 - - WARRANTIES, EXPRESS AND —f ITUED, INCLUDING ANY IMPLIED WARRANTIES OF HOURS LABOR AMOUNT _ MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR AUTHORIZES ANY OTHER PERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE MON-FRI PARTS AMOUNT SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS,OIL, LUBE _ ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE SAT SUBLET AMOUNT _ LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES.CUSTOMER SHALL NOT BE ENTITLED TO -- -- -- RECOVER FROM THE DEALERSHIP ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, 8AM TO 4PM MISC. CHARGES DAMAGES FOR LOSS OF USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER - INCIDENTAL DAMAGES. TOTAL CHARGES By signing below, you acknowledge that you were notified of and authorized the ALL PARTS ARE NEW Dealership to perform the services/repairs itemized in this Invoice and that you received UNLESS OTHERWISE LESS INSURANCE (or had the opportunity to inspect)any replaced parts as requested by you.The vehicle INDICATED. SALES TAX _ is beinoreturned ou in exchanger your payment of the Amoun Due. DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY THIS AMOUNT I CUSTOMER COPY aD_er AP @2006 ADP 103/091 SERVICE INVOICE TYPE 2.2S12C-'AS•IS"-PENNSYLVANIA•9698082 CUSTOMER #: 1016251 148312 L ' B ' SMITH LINCOLN *INVOICE* 1100 MARKET ST LEMOYNE, PA 1704 KAREN ROY (717) 761-6700 (800) 422-3673 1075 LANCASTER BLVD APT 1 www.lbsmithford.com MECHANICSBURG, PA 17055-4473 PAGE 3 HOME: CONT:425-8455 BUS: 717-737-4511 CELL: 717-425-8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS COLOR.. YEAR MAKE/MODEL - VIN' LICENSE-/REG.# MILEAGE.:IN/OUTi TAG 3FADP4BJ7CM207664 JFC5717 17096 1709 563 GRAY 12 FORD FIESTA PO NO: RATE PAYMENT INN. D; TE DEL:DATE. '::: 'PROD.:DATE .WAAR:'EXP. PROMISED ' 03MAR12 D 16 : 00 18NOV13 7-9-0 . 00 CASH 27NOV1 R.O.'OPENED READY OPTIONS: ENG: 1. 6_Liter_Ti-VCT 07 : 32 18NOV13 14 : 55 27NOV13 LIST NET TOTIML LINE OPCODE TECH TYPE HOURS D COMPLETE STATE INSPECTION 03 COMPLETE STATE INSPECTION 221 CP 0 . 30 14 . 95 14 . 5 PARTS: 0 . 00 LABOR: 14 . 95 OTHER: 0 . 00 TOTAL LINE D: 14 . 5 17096 COMPLETED. BRAKES : FT9B AND RR,4B TIRES 8/32 E COMPLETE EMISSION TEST m 22 COMPLETE EMISSION TEST 1 ....... .. 221 CP 0-150i `N 39 . 95 39 . 5 PARTS: 0 . 00 LABOR: X9 . 95 OTHER $'r 6• © TOTAL` LINE E: 39 . 5 F COMPLETED MULTI-POINT INSPECTION, REPORT. QW- 0 99P COMPLETED MULTI-POINT INSPECTION REPORT CARD- 40 221 CP 0 .30 0 . 00 0 . 0 GBATT BATTERY CHECKS GOOD 221 CP 0 . 00 0 . 00 0 . )o GBK BRAKE LINING WEAR CHECKED. BRAKES WEARING OK AT THIS TIME 221 CP 0 . 00 0 . 00 0 . )o GTIRE TIRE TREAD WEAR CHECKED. TIRES :WEARING OK AT THIS TIME. 221 CP 0 . 00 0 . 00 0 . )0 PARTS: 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 TOTAL LINE F: 0 . 0 WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE -DESCRIPTION t`OTAyBY THE RSHIP AS-IS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT. WARRANTIES, EXPRESS AND �I�IFLIED, INCLUDING ANY IMPLIED WARRANTIES OF HOURS LABOR AMOUNT 54 .',V0 MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR AUTHORIZES ANY OTHER PERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE MON-FRI PARTS AMOUNT 0 •! 0 SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS,OIL, LUBE 0 • 0 ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES,CUSTOMER SHALL NOT BE ENTITLED TO SAT SUBLET AMOUNT 0 0 RECOVER FROM THE DEALERSHIP ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, 8AM TO 4PM MISC.CHARGES " 0 0 DAMAGES FOR LOSS OF USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER - ---- INCIDENTAL DAMAGES. TOTAL CHARGES 54 •: 0 _ By signingbelow, you acknowledge that you were notified of and authorized the ALL PARTS ARE NEW Dealership to perform the services/repairs itemized in this Invoice and that you received UNLESS OTHERWISE LESS INSURANCE , 0 • 0 (or had the opportunity to inspect)any replaced parts as requested by you.The vehicle INDICATED. SALES TAX 3 9 i in returned inexchangef r payment f h Am •n -- - DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY THIS AMOUNT 5$ 1 9 CUSTOMER COPY D60kAP©2006 ADP 103/091 SERVICE INVOICE TYPE 2.2S12C-"AS-IS"-PENNSYLVANIA-9698082 CUSTOMER #: 1016251 149304 L ' B ' S M 'T j& J! LINCQL *INVOICE* 1100 MARKET ST LEMOYNE, PA 17*3 KAREN ROY (717) 761-6700 (800) 422-31673 1075 LANCASTER BLVD APT 1 DUPLICATE 1 www.lbsmithford.com MECHANICSBURG, PA 17055-4473 PAGE 1 HOME: CONT:N/A BUS : 717-737-4511 CELL: 717-425 8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS COLOR ;: YEAR MAKE/MODEL. VIN LICENSE/REG.# MILEAGE IN /OUT TAG GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 17238/17238 T486 __ DEL. D47E PROD, DATE WARR. EXP. PROMISED PO'.NO. RATE' PAYMENT; GNV. ATE 03MAR12 D 18 : 00 27DEC13 90 . 00 CASH 27DEC. 3_ _ R.O. OPENED : READY OPTIONS: ENG: 1 . 6 Liter Ti-VCT 10 :45 30NOV13 16 : 10 27DEC13 LINE OPCODE TECH TYPE HOURS LIST NET TO AL A TAP LOANER CAUSE: TAP LOANER 77 TAP LOANER (N C) 999 WL 0 . 00 FC: A99 82 PART#: TAP1 ,... COUNT: CLAIM TYPE: TAP1 AUTH CODE: ; PARTS : 0 . 00 LABOR:".:: 0'. 00 Y OTHER tT 90 TOTAL LINE A: 0! 00 B CUSTOMER STATES BRAKE FADE AND"MUSHY--W,,,,HEN......SaOPPING` NP NO PROBLEM FOUND 193 ISP 0 . 30 (N C) PARTS : 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 TOTAL LINE B: 0 00 17238 ROAD TEST AND CHECK. NO PROBLEM FOUND. C CUSTOMER STATES THAT THE VEHICLE WHJEN}'.0,O.jNG UP V HILLS MAKES NOISE IN THE TRANMSSION WHEN GOING UP HELLS AND DRIVIING CAUSE: REPLACE RT FT AXLE SHAFT AND BRG 4462AR REPLACE RT FT AXLE SHAFT ASSY 3— 193 W 1. 10 (N) C) 1 TX*626* SHAFT - FRONT AXLE (N' C) 1 YS4Z*3N324*AA RETAINER BEARING (N' C) 4462A4 REPLACE INTERMEDIATE 'SHAFVBRGL TIFF'S 193 W 0 .40 (N' C) FC: N5 0 42 BIT PART#: TX*626* COUNT: CLAIM TYPE: AUTH CODE: RA SERVICE DEPT. DESCRIPTION jTOTA S E%lPOR rANT BOOR HOURS LABOR AMOUNT _J rHE MON-FRI PARTS AMOUNT ND You may receive a survey from Ford MotorBE 7:30AM TO 6PM GAS,OIL, LUBE TO SAT SUBLET AMOUNT Company shortly. Your Complete Satisfaction is our T IER 8AM TO 4PM MISC. CHARGES " goal. If for any reason you cannot give us an the ALL PARTS ARE NEW TOTAL CHARGES. ied UNLESS OTHERW-Iff LESS INSURANCE �- "Excellent Ratinh"" please contact your service cle INDICATED. SALES TAX 'REPRESENTATIVE SIGNATURE manager, Steve Vancena before mailing the survey. PLEASE PAY THIS AMOUNT L.B. Smith Ford Lincoln 717-761-6700. -- 4ER COPY %I UG'dle'rL/iC WZVUn Aur IU/U`JI SERVICE INVOICE TYPE 2-2SI2C--AS-IS"-PENNSYLVANIA-9698082 CUSTOMER #: 1016251 149304 L ' 13 ' SMITH � LINCOLN *INVOICE* 1100 MARKET ST LEMOYNE, PA 11704 KAREN ROY (717) 761-6700 (800) 422-3673 DUPLICATE 1075 LANCASTER BLVD APT 1 www.lbsmithford.com MECHANICSBURG, PA 17055-4473 PAGE 2 HOME: CONT:N/A BUS : 717-737-4511 CELL: SERVICE ADVISOR: 213 RUSSELL GIBBONS 717-425-8455 GOLOR YEAR MAKE/MODEL VIN LiCEN5E/REG.# MILEAGE IN /OUTi TAG GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 17238 17238 486 DEL.'DATE PROD. DATE VVARR:-EXP. PROMISED. PO NO. RATE . PAYMENT INV:D E 03MAR12 D 18 : 00 27DEC13 90 . 00 CASH 27D C1 R.O. OPENED READY OPTIONS: ENG: 1 . 6_LiteY'_Tl—VCT 10 :45 30NOV13 16 : 10 27DEC13 LIST NET TOTIL LINE OPCODE TECH TYPE HOURS 00472 PARTS: 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 TOTAL LINE C: 0 17238 ROAD TEST*AND ******CHECK. REPLACE RT FT AXLE ***AND*BRIG*ASSY. ********* D CKL FUEL WHEN DRIVING 100 MILES USED HALF .A TANKS MISC RUN DIAGNOSTICS . REPROGRAM-{PGM.:- 193 ISP 0 - 80 (N/ ' ) ..... ; 0.:..:90 LINE D: 0 . 0 PARTS : 0 . 00 LABOR: 000 QTHER TOTAL 17238 RUN DIAGNOSTICS AND `CHECK. REPROG JAM' P;'CM . tYi******fit*ir**ic*********.******* E** CHECK FOR NOISE IN TRANS ESPtCYALLY" Pl'ILL9 CAUSE: CHECK AND REPAIR. -•------ ADD ADD-ON REPAIR. (NI ) 193 W 0 . 00 (N/` ) 1 AE8Z*7060*A SHAFT ASY - OUTPUT (N/ ) 1 AE8Z*7007*A PLATE - CYLINDER BLOCK REAR (N/ 1 9U7Z*19A506*BA GREASE - CHASSIS �LUBRICATION (N/- ) 1 TA*16* ADHESIVE ry (N/ 1 BRS*172* SEAL - -•" _ (N/ 1 AE8Z*7118*A BEARING ASY - NEEDLE. (N/ 2 *W709618*S442 BOLT (N/ 1 2S6Z*9450*A GASKET 1 AE8Z*7B498*A SEAL �(N/ 1 AE8Z*7052*C SEAL ASY - OIL (N/ ) 1 AE8Z*7064*B SNAP RING (N/' � 1 YS4Z*3N324*AA RETAINER SEARING (N 2 *W520102*S442 NUT -'•.LOCKING ' (N/' 3 AE8Z*7B498*B SEAL (N/' ) 2 *W705448*S441 NUT .(N/' ) 2 *W703662*S403 NUT - HEX. (N/ 2 *W520203*S442 NUT - HEX. '(N/ 1 PM*4*A BRAKE CLEANER (N/' ) WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE DESCRIPTION IOTA� WARIANfl"BP'rRE-6EAZERSHIP AS-IS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT. MERCHANTABILITYPANDSAND FITNESS FOR A PARTICULARNG ANY PUR OSE, ANOLNEITHEREIAASSUMIES OF ES NOR HOURS LABOR AMOUNT AUTHORIZES ANY OTHER PERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE MON-FRI PARTS AMOUNT SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS, OIL, LUBE ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BEABLE FOR SAT SUBLET AMOUNTLI _ RECOVER FROM PERFORMANCE EALERSHIP ANY UNDER HCONSEQUENTIAL UDAMAGES, DAMAGES TOSTOMER SHALL NOT BE N PROPERTY,RTY, DAMAGES FOR LOSS OF USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER 6AM TO 4PM MISC.CHARGES " INCIDENTAL DAMAGES. TOTAL CHARGES _ By signing below, you acknowledge that you were notified of and authorized the ALL PARTS ARE NEW Dealership to perform the services/repairs itemized in this Invoice and that you received UNLESS OTHERWISE LESS INSURANCE (or had the opportunity to inspect)any replaced parts as requested by you.The vehicle INDICATED. SALES TAX is i r rn i e chan e r m f Amount . DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY . THIS AMOUNT CUSTOMER COPY D691—erCAP©2006 ADP(03/09) SERVICE INVOICE TYPE 2-2S12C•'AS-IS"•PENNSYLVANIA-9698082 r. CUSTOMER # : 1016251 149304 L . B . SMITH' `` T LINCOLN *INVOICE* 1100 MARKET ST LEMOYNE, PA 1704 KAREN ROY (717) 761-6700 (800) 422-3673 DUPLICATE 1075 LANCASTER BLVD APT 1 www.lbsmithford.com MECHANICSBURG, PA 17055-4473 PAGE 3 HOME: CONT:N/A BUS: 717-737-4511 CELL: 717-425-8455 SERVIC�ENADVISOR: 213 LCENSE REG.#EL GIBBION�/OUT TAG COLOR YEAR MAKE/MODEL GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 17238 17238 486 DEL. DATE PROD.DATE 'WARR. EXP. PROMISED PO N0. RATE PAYMENT INV, D TE 03MAR12 D 18 : 00 27DEC13 90 . 00 CASH 27DEC1 R.O. OPENED READY OPTIONS: EN : 1 . 6—Liter—Ti-VCT 10 :45 30NOV13 16 : 10 27DEC13 LIST NET TOT L LINE OPCODE TECH TYPE HOURS (N/ ) 2 XT*11*QDC FLUID - TRANSMISSION (N/ ) 2 AE8Z*7D000*B TUBE - OIL (N/ ) 2 AE8Z*7M037*C BEARING ASY - NEEDLE 1 AE8Z*7048*B SEAL ASY - OIL 7003A MANUAL TRANSMISSION / AUTOMATIC SHIFTING MANUAL TRANSMISSION ASSEMBLY.-_.- REMOVE.. AND INSTALL (7003) - L (N/ ) 193 W 4 . 30i 7 0 0 3A2 MANUAL TRANSMI SS3ON AS 5`E i.Y"< = _ ER.HAU '.. ':.. (7003) - L 193 W 3 30 � (NIC) FC: N18 42 PART#: COUNT:: y CLAIM TYPE: AUTH CODE: 00472 PARTS: 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 TOTAL LINE E: 0 • 17238 ROAD TEST AND CHECK. REMOVE AND DISASSEMBLE TRANS . REPLACE SHAFT CLUSTER AND CLEAN CLUTCH. REASSEM�LE' AND REINSTALL TRANS . REPROGRAM PCM/TCM. ROAD TEST. **************************************************** LC: E REF. RO: SVC PART DATE: SVC PART DISTANCE: WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE DESCRIPTION IOTA' RSHIP AS-IS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT. WARRANTIES, EXPRESS AND 703LIED, INCLUDING ANY IMPLIED WARRANTIES OF HOURS LABOR AMOUNT 0 o _ MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR 0 0 AUTHORIZES ANY OTHER PERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE MON-FRI PARTS AMOUNT SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS,OIL, LUBE 0 • 0 ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES.CUSTOMER SHALL NOT BE ENTITLED TO SAT SUBLET AMOUNT 0 ADO RECOVER FROM THE DEALERSHIP ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, SAM TO 4PM MISC. CHARGES " 0 •i _0 DAMAGES FOR LOSS OF USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER - — - INCIDENTAL DAMAGES. TOTAL CHARGES 0 0 By signing below, you acknowledge that you were notified of and authorized the ALL PARTS ARE NEW LESS INSURANCE 0 0 Dealership to perform the services/repairs Itemized In this Invoice and that you received UNLESS OTHERWISTE (or had the opportunity to inspect)any replaced parts as requested by you.The vehicle INDICATED. SALES TAX 0 •i 0 is being rAturne to you in exchanoe for your nnyment of the-Amount Due. DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY THIS AMOUNT ! 0 :to CUSTOMER COPY De_TerCAP.©2006 ADP 103/091 SERVICE INVOICE TYPE 2.2S12C--AS-Is--PENNSYLVANIA-9698082 !n l� CUSTOMER #: 1016251 151563 L ' B ' S M 'T I LINCOL *INVOICE* � 1100 MARKET ST LEMOYNE, PA 17. 43 (7 KAREN ROY 17) 761-6700 (800) 422-3673 1075 LANCASTER BLVD APT 1 www.lbsmithford.com PAGE 1 MECHANICSBURG, PA 17055-4473 HOME: CONT:N/A 213 l BUS: 717-737-4511 CELL: 717-425-8455 SERVICE NADVISOR: LICENSE REG.#EL MILEpgBONSO T 1 TAG COLOR YEAR MAKE/MODEL GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 17440 17440 T57-7 DEL. DATE PROD: DAfE WARR. EXP. PROMISED PO NO. RATE PAYMENT INV.? ATE 03MAR12 D 18 : 00 03JAN14 90 . 00 CASH 09JAN 4 R.O. OPENEQ READY OPTIONS: ENG: 1 . 6_Llter_Ti-VCT 06 : 03 03JAN14 13 : 59 0 ___ LIST NET TO AL LINE OPCODE TECH TYPE HOURS A COM99PTED COMPLETED PMULTI-POINT OINT TINSPECTION ORT CARD- 40 ION REPORT CARD- 40 0 . 00 0' 00 244 CP 0 . 30 1 GBATT BATTERY CHECKS GOOD 0 . 00 000 244 CP 0 . 00 I GBK BRAKE LINING WEAR CHECKED..: .BRAKES—WEARING 'OK AT THIS TIME 0 . 00 I 0> 00 244 CP 0 .-00. GTIRE TIRE TREAD WEAR CHECKED. 'TIRES WEARING OK AT THIS TIME. 0 . 00 0 00 244 CP 0 . 00. 0 00 PARTS: 0 . 00 LABOR: 0.. 0"0' QT)2ER s'"" 0''': 0 0 TOTAL LINE A i 17440 COMPLETED **************************************************** B TAP LOANER CAUSE: TAP LOANER 77 TAP LOANER FU) FF'S I (N C) 999 WL 0 . 00 IT FC: A99 82 .i PART#: TAP1 COUNT: CLAIM TYPE: TAP1 AUTH CODE: PARTS: 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 .1 TOTAL LINE B: 0 !00 C CUSTOMER STATES VEHICLE IS MAKING A CHAIN TYPE NOISE WHEN DRIVING UP l BIG HILLS, REEESER SUMMINT. , NOT SHIFTINIG RIGHT MISC RUN DIAGNOSTICS . NO CODES . ROAD TEST SEVERAL TIMES . CANNOT DUPLICATE CONCERN. NX) 193 ISP 1 . 00 OTAI WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRa DESCRIPTION RSHIP AS-IS. THE DE_ALERSHtP HERFRv BOR AMOUNT WARRANTIESAND _T MERCHANTABILITY ANDSFITNESSM Icn -- AUTHORIZES ANY OTHER PERSON 1!'1PORTANT RTS AMOUNT SALE OF PARTS OR PRODUCTS S,OIL, LUBE ACCESSORIES OR REPAIRS ARE THC Ford Motor ORIGINAL PARTS DISTRIBUTOR A� survey from KET AMOUNT LIABLE FOR PERFORMANCE UNDER RECOVER FROM THE DEALERSHIP you may receive a fete Satisfaction is our :C.CHARGES " DAMAGES FOR LOSS OF USE, L0: INCIDENTAL DAMAGES. shortly" your COmp -AL CHARGES By signing below, you acknovcompany of Ave US an S INSURANCE Dealership to perform the service reason you cane g - lor had the opportunity to inspec gUal" If for any _ is beino returned to you in excha our service ES TAX DATE CUSTOMER SIG att»�� please contact y ASE PAY E�celle»t R the survey. ; AMOUNT manager, Steve Vancena before ro7r76g 6700" 1 u cmith Ford L><n r 151563 LB . SMIT CUSTOMER #: 1016 2 51OJE&I, I LINCOLN *INVOICE* 1100 MARKET ST LEMOYNE, PA;170 3 KAREN ROY (717) 761-6700 (800) 422-3673 www.lbsmithford.com 1075 LANCASTER BLVD APT 1 PAGE 2 MECHANICSBURG, PA 17055-4473 HOME: CONT:N/A BUS : 717-737-4511 CELL: 717-425-8455 SERVICENADVISOR: LICENSE REG.4EL MIEAGEEIIN /OU TAG COLOR YEAR MAKEIMODEL`: 3FADP4BJ7CM207664 JFC5717 17440 1744 577 GRAY 12 FORD FIESTA PROMISED PO N0. RATE PAYMENT INV. D TE DEL. DATE PROD.:DATA VNARR. EXP. CASH 09JAN1 03MAR12 D 18 : 00 03JAN14 90 . 00 R:0 OPENED READY OPTIONS: ENG: 1 .6_LiteY_T1—VC 06 : 03 03JAN14 13 : 59 09JAN 14 LIST NET TO L LINE OPCODE TECH TYPE HOURS0 . 00 TOTAL LINE C: 0 . 0 PARTS: 0 . 00 LABOR: 0 . 00 OTHER: NO CODES . ROAD TESTED SEVERAL TIMES . CANNOT 17440 RUN DIAGNOSTICS . DUPLICATE CONCERN. *************************************************** D CHECK ROUGH IDLE CAUSE: CHECK OUT AND REPLACE #4 SPARK PLUG.: 12650D EEC SYSTEM DIAGNOSIS — '(QUICK TEST) — L !(N/ ) 244 W (N/ ) 1 SP*525* SPARK PLUGL e t 12405A SPARK PLUGS REPLACE' (124.05) '(N/ ) 244 W 0 .2-0 FC: D13 42 PART#: SP*525* M.... COUNT: CLAIM TYPE: AUTH CODE: 0 ! 0 PARTS: 0 . 00 LABOR: 0 . 00 OTHER::: ., 0 . 00 TOTAL LINE D: SIX 17440 VERIFY CONCERN 1 TIME ON CE CYLINDERROAD TEST, C4ESPARKDPLUGS,DROAD TEST, CYLINDER 4 SHOWS MISFIRE, REPLA VERIFY REPAIR DESCRIPTION TIOTAU WARRANTY DISCLAIMER: RALL PARTS SHIP AS-IS. DEALERSH PND SHEREBVARE OEXOAND P ESSLYLDISCLAIMS AL REPAIRS LL SERVICE DEPT. I 0 _ 0 HOURS LABOR AMOUNT WARRANTIES, EXPRESS AND 79PILIED, INCLUDING ANY IMPLIED WARRANTIES OF 0 0 MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR MON-FRI PARTS AMOUNT AUTHORIZES ANY OTHER PERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE GAS,OIL,LUBE 0 ' 0 — SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND - ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30A AT BPM SUBLET AMOUNT 0 ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE - LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES.CUSTOMER SHALL NOT BE ENTITLED TO 8AM TO 4PM MISC. CHARGES ' 0 ' 0 RECOVER FROM THE DEALERSHIP ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, 0 0 DAMAGES FOR LOSS OF USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER TOTAL CHARGES - INCIDENTAL DAMAGES. By signing below, you acknowledge that you were notified of and authorized the ALL PARTS ARE NEW 0 . 0 – Dealership to perform the services/repairs Itemized In this Invoice and that you received UNLESS OTHERWISE LESS INSURANCE 0 _ 0 for had the opportunity to inspect)any replaced parts as requested by you.The vehicle SALES TAX – — i ein returned t In x n e f r r PLEASE PAY DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE THIS AMOUNT O_. 0 CUSTOMER COPY D141—erCAP®2006 ADP 103/091 SERVICE INVOICE TYPE 2.2S12C-"AS-IS"-PENNSYLVANIA-9698082 CUSTOMER #: 1016251 152302 L ' B ' SM 'T 40*1 1LINCOL *INVOICE* 1100 MARKET ST LEMOYNE, RA 17, 43 KAREN ROY (717) 761-6700 (800) 422-367 www.lbsmithford.com 1 1075 LANCASTER BLVD APT 1 PAGE 1 MECHANICSBURG, PA 17055-4473 HOME: CONT:425-8455 BUS: 717-737-4511 CELL: 717-425-8455 SERVICVEN ADVISOR: EL LICENSE REG.# MILEAGE IIN�/OUT TAG COLOR ' 'YEAR MAKE/MODEL 3FADP48J PO NO�7664 R TE 5717 1763 PAYMENT 17611N V. ATE GRAY 12 FORD FIESTA DEL. DATE PROD. DATE WARR...EXP. PROMISED 90 00 CASH 16J 4 03MAR12 D 18 : 00 17JAN14 . AN R.O. OPENED READY OPTIONS: ENG:1 . 6_Liter_Ti-VCT 08 : 54 13JAN14 10 :40 16JAN14 LIST NET TO AL LINE OPCODE TECH TYPE HOURS A CHECK ENG, CIS IDLES ROUGH, VIBRATES, POOR GAS MILAGE, 33 MPG ON HIGHWAY, SEEMS TO IDLE FAST CAUSE: CHECK AND PER TSB 13-09-04 UPDATE PCM/TCM AND DO ADAP LEARNING i 130904A PERFORM TSB 130904A UPDATE PCM/TCM. DO ADAP LEARN � (N I C) 221 W 1. 10 FC': P66 14 PART#: 7B546 i COUNT: CLAIM TYPE: ; AUTH CODE: 00076 0 , 00 PARTS : 0 . 00 LABOR: 0 . 0`O" OTHER: "'•0:'0 0 TOTAL LINE A 17653 ROADTEST. IDS EEC TEST CODE P2832 . PERFORMED PPT AS PER WSM. IDS PERFORMED TRANSMISSION ADAPTIVE LEARNING. PERFORMED TRANSMISSION RANGE SELECTOR , SHIFT DRUM , CLUTCH ADAPTIVE , CLUTCH SYSTEM AND SPEED SENSOR TESTS . PERFORMED DRIVE CYCLE. VERI-FIED CORRECT OPERATION. IDS RETEST EEC, PASS . B CLEAN CAR, CIS GREASE - DIRT ON L/F SILL..PLATE AREA I MISC COMPLETED. 0 . 00 0 .; 0 999 CP 0 . 00 . 00 OTHER: 0 . 00 TOTAL LINE B: Ol 0 PARTS : 0 . 00 LABOR: 0 I I 17653 COMPLETED-MIKE N ; **************************************************** C REINSTALL CUSHION MISC MISC REPAIRS 0 . 00 ' 0 •t0 221 CP 0 . 00 PARTS: 0 . 00 LABOR: 0 . 00 OTHER: 0 . 00 TOTAL LINE C: ; 0 . 0 ( D CK BLUE TOOTH NOT ALWAY CONNECTING TTAL' WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE __ -PT. DESCRIPTION _ - RSHIP °c-1c Tuc ncn�=no��,.+ LABOR AMOUNT WARRANTIES, ERPF l.ti1PORTANT MERCHANTABILITY F I PARTS AMOUNT AUTHORIZES ANY 01 SALE OF PARTS OF IPM GAS,OIL, LUBE ACCESSORIES OR REI ORIGINAL PARTS DIEyou may receive a survey from Ford Motor SUBLET AMOUNT LIABLE FOR PERFORty RECOVER FROM THE M MISC. CHARGES • DAMAGES FOR LOS:_/'. INCIDENTAL DAMAGECompany Shortly. Your Complete Satisfaction is our TOTAL CHARGES _ -- By signing below, i Dealership to perfo goal. If for any reason you cannot give us an WISE LESS INSURANCE (or had the opportu SALES TAX is being returned tc cc a" please contact your service DATE Excellent Rating TURE PLEASE PAY manager, Steve Vancena before mailing the survey. THIS AMOUNT L.B. Smith Ford Lincoln 717-761-6700. II D6g1_erCAP.©zoos Ac CUSTOMER #: 1016251 152302 L . B . SMI T 1 LINCOLN, KAREN ROY *INVOICE* 1100 MARKET ST LEMOYNE, PA 170 3 17171 761-6700 (800) 422-3673 1075 LANCASTER BLVD APT 1 www.lbsmithford.com MECHANICSBURG, PA 17055-4473 PAGE 2 HOME: CONT: 425-8455 BUS : 717-737-4511 CELL: 717-425-8455 SERVICE ADVISOR: 213 RUSSELL GIBBONS COLOR YEAR' MAKE/MODEL VIN LICENSE /'REG.# MILEAGE IN/OUT TAG GRAY 12 FORD FIESTA 3FADP4BJ7CM207664 JFC5717 17653 176513 234 DEL. DATE PROD. DATE I WARR. EXP. PROMISED PO NO. RATE PAYMENT INV. TE 03MAR12 DE 18 : 00 17JAN14 an Q01 CASH 16 4 R.O, OPEN.ED READY OPTIONS: ENG: 1 . 6 Liter Ti-VCT 08 : 54 13JAN14 10 : 40 16JAN14 LINE OPCODE TECH TYPE HOURS LIST NET TO L CAUSE: CHECK OUT AND UPDATE APIM. 12652D RUN DIAGNOSTICS ON SYNC SYSTEM 221 W 0 . 30 �N� FC: A86 42 PART#: 14D212 COUNT: CLAIM TYPE: AUTH CODE: 00076 PARTS: 0 . 00 LABOR 0. 00 . :.OTHER 0 . 00 : TOTAL LINE D: 0 ., 0 17653 'IDS PERFORMED SYNC UPDATE,. WARRANTY DISCLAIMER: ALL PARTS AND ACCESSORIES ARE SOLD AND ALL REPAIRS ARE TQTAL�. W RSHIP AS-IS. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL SERVICE DEPT. DESCRIPTION ---- - -TO - ARNT RAIES, EXPRESS AND -77FLIED, INCLUDING ANY IMPLIED WARRANTIES OF HOURS LABOR AMOUNT 0 0 MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NEITHER ASSUMES NOR --- - AUTHORIZES ANY OTHER PERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE MON-FRI PARTS AMOUNT ,0 . 0 _ SALE OF PARTS OR PRODUCTS OR THE REPAIR. THE ONLY WARRANTIES ON PARTS AND _ - -- -- --- - `- ACCESSORIES OR REPAIRS ARE THOSE WHICH MAY BE OFFERED BY THE MANUFACTURER OR THE 7:30AM TO 6PM GAS,OIL, LUBE _ ,.0 ORIGINAL PARTS DISTRIBUTOR AND ONLY SUCH MANUFACTURER OR DISTRIBUTOR SHALL BE LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES.CUSTOMER SHALL NOT BE ENTITLED TO SAT SUBLET AMOUNT _ _ _ 0 . 0 RECOVER FROM THE DEALERSHIP ANY CONSEQUENTIAL DAMAGES, DAMAGES TO PROPERTY, BAM TO 4PM MISC. CHARGES ' _ �0 0 DAMAGES FOR LOSS OF USE, LOSS OF TIME, LOSS OF PROFIT OR INCOME, OR ANY OTHER INCIDENTAL DAMAGES. TOTAL CHARGES _ .0 . 10 By signing below, you acknowledge that you were notified of and authorized the ALL PARTS ARE NEW - - Dealership to perform the services/repairs itemized in this Invoice and that you received UNLESS OTHERWISE LESS INSURANCE 0 . 0 (or had the opportunity to inspect)an replaced arts as requested b - y p p q y you.The vehicle INDICATED. SALES TAX ;0 . is being returned to you in ex�ha�e�r your oavment of the Amount Due.. - _ _ - _ - DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE PLEASE PAY THIS AMOUNT CUSTOMER COPY T Ir Deg erCAP©2006 ADP 103/091 SERVICE INVOICE TYPE 2.2S12C--AS-IS"-PENNSYLVANIA-9698082 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN J. ROY and NO.: 14 — 4886 Civil KAREN ANN ROY, Plaintiffs, vs. FORD MOTOR COMPANY, Defendant. RETURN OF SERVICE OF COMPLAINT Filed on behalf of Plaintiffs: Stephen Roy and Karen Roy COUNSEL OF RECORD FOR THESE PARTIES: Christina Gill Roseman, Esquire Identification No. 71492 ROSEMAN LAW FIRM, PLLC 4885-A McKnight Road, No. 428 Pittsburgh, PA 15237 croseman@heipforlemoncars.com (800) 745-5259 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN J. ROY and KAREN ANN ROY, Plaintiffs, vs. FORD MOTOR COMPANY, Defendant. No.: 14 — 4886 Civil RETURN OF SERVICE OF COMPLAINT Plaintiffs, Stephen J. Roy and Karen Ann Roy, by and through their counsel, Christina Gill Roseman, Esq., submit the following as their Return of Service of Complaint: The Complaint was served upon Defendant in this matter through the U.S. Postal Service by certified mail, return receipt requested to Ford Motor Company, Consumer Affairs, 16800 Executive Plaza Dr., 3 NE -B, Dearborn Michigan, 48126-4207. A representative of Defendant signed the return receipt on August 25 2014. A copy of the signed delivery receipt is attached. By:%41& ;i_e_64(te, ow- ,ogge Christina Gill Roseman, Esquire Roseman Law Firm, PLLC Attorney for Plaintiffs 4885-A McKnight Rd., No. 428 Pittsburgh, Pennsylvania 15237 croseman@helpforlemoncars.com (800) 745-5259 SENDER: COMPLETE THIS SECTION ..iPt. E ,E IRIS SECTION ON DELIVERY ptoptete4iernt 1, 2, and 3. Alsocomplete it" if flestricted Delivery is desired: ntyoir name and address on the reverse so That we;can return 'the card to you. 7e: Attach .this card •to,the;back of the mailpiece,. lir Ott the frattf:if space pentiifs: icie°Addn sed to: B.. Received by (PrintedIk.ra d Agent El, Addressee Date of Delivery I Ford Motor Company Consumer Affairs 16800 Executive Plaza Drive, 3 NE- B Dearborn, Michigan 48126-4207 © Registe G3 Insured M 4.. Restricted Delivery? (Exits Fee) Yes fer..trot» service fabeij "- - - - - 15989 3010 PS:forni':3811,. July 2073 :: . Domestic Return Receipt CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the within RETURN OF SERVICE OF COMPLAINT, was served on August 3/ , 2014, via U.S. Mail to: Ford Motor Company Consumer Affairs 16800 Executive Plaza Drive, 3 NE -B Dearborn, Michigan 48126-4207 Christina Gill Roseman, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION STEPHEN J. ROY and KAREN ANN ROY, Plaintiff(s), V. FORD MOTOR COMPANY, Defendant. CASE NO. 14-4886 Civil Civil Action PRAECIPE FOR ENTRY OF APPEARANCE rri M r. cr) <ED zcz (7) -4 TO THE PROTHONOTARY/CLERK OF SAID COURT: Kindly enter my appearance in the above -captioned matter on behalf of Defendant, Ford Motor Company. Papers may be served at the address set forth below. DATED: October 9, 2014 DOBIS, RUSSELL & PETERSON, P.C. Attorneys for defendant, Ford Motor Co ny BY: PAUL K. RUSSELL, E I.D. #70882 213 Yates Avenue Woodlyn, Pennsylvania 19094 (610) 689-8698 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION STEPHEN J. ROY and KAREN ANN ROY, Plaintiff(s), v. FORD MOTOR COMPANY, Defendant. : CASE NO. 14-4886 Civil Civil Action ANSWER AND NEW MATTER AND NOW, comes defendant, Ford Motor Company ("Ford"), by its attorneys, Dobis, Russell & Peterson, P.C., and files the within Answer and New Matter as follows: ANSWER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Ford denies that this is an accurate statement regarding the purchase price of the subject vehicle. 7. Ford denies that this is an accurate or complete statement regarding the limited warranty applicable to the subject vehicle. 4,1 8. Ford denies that this is an accurate or complete statement regarding the limited warranty applicable to the subject vehicle. 9. Ford specifically denies the allegations contained within this averment. 10. Ford admits that a copy of the document is attached to the Complaint, but specifically denies the balance of the allegations contained within this averment. 11. Ford admits that a copy of the document is attached to the Complaint, but specifically denies the balance of the allegations contained within this averment. 12. Ford admits that a copy of the document is attached to the Complaint, but specifically denies the balance of the allegations contained within this averment. 13. Ford admits that a copy of the document is attached to the Complaint, but specifically denies the balance of the allegations contained within this averment. 14. Ford admits that a copy of the document is attached to the Complaint, but specifically denies the balance of the allegations contained within this averment. 15. Ford denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle. AS TO COUNT I 16. Ford repeats and reiterates its answers to the allegations of paragraphs 1 —15 with full force and effect as though more fully set forth. 17. This averment constitutes a conclusion of law to which no response is required. 18. This averment constitutes a conclusion of law to which no response is required. 19. This averment constitutes a conclusion of law to which no response is required. 20. This averment constitutes a conclusion of law to which no response is required. 21. Ford denies that this is an accurate or complete statement regarding the limited warranty applicable to the subject vehicle. 22. This averment constitutes a conclusion of law to which no response is required. 23. Ford specifically denies the allegations contained within this averment. 24. Ford specifically denies the allegations contained within this averment. 25. Ford specifically denies the allegations contained within this averment. 26. Ford specifically denies the allegations contained within this averment. 27. Ford specifically denies the allegations contained within this averment. 28. Ford specifically denies the allegations contained within this averment. AS TO COUNT II 29. Ford repeats and reiterates its answers to the allegations of paragraphs 1 — 28 with full force and effect as though more fully set forth. 30. This averment constitutes a conclusion of law to which no response is required. 31. This averment constitutes a conclusion of law to which no response is required. 32. This averment constitutes a conclusion of law to which no response is required. 33. This averment constitutes a conclusion of law to which no response is required. 34. This averment constitutes a conclusion of law to which no response is required. 35. Ford specifically denies the allegations contained within this averment. 36. This averment constitutes a conclusion of law to which no response is required. 37. This averment constitutes a conclusion of law to which no response is required. 38. This averment constitutes a conclusion of law to which no response is required. 39. Ford specifically denies the allegations contained within this averment. 40. This averment constitutes a conclusion of law to which no response is required. NEW MATTER 41. The subject vehicle does not have a non -conformity, defect or condition which substantially impairs its use, value or safety. 42. Plaintiff failed to permit defendant a reasonable number of attempts to repair the alleged non -conformity, defect, or condition, or otherwise failed to give defendant a reasonable opportunity to cure the defect. WHEREFORE, this defendant requests this Honorable Court to enter judgment in its favor. DESIGNATION OF TRIAL COUNSEL PLEASE TAKE NOTICE that PAUL K. RUSSELL, ESQ., is hereby designated as trial counsel. CERTIFICATION OF COUNSEL 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. CERTIFICATION I hereby certify that a copy of the within document has been filed with the Prothonotary's Office in the Court of Common Pleas of Cumberland County, PA, Civil Action and that a copy of the same was served upon all interested attorneys within the period of time allowed in accordance with the Rules of the Court. DOBIS, RUSSELL & PETERSON, P.C. Attorneys for Defendant, Ford Motor Company BY: DATED: October 9, 2014 PAUL K. RUS LL, E I.D. #70882 213 Yates Avenue Woodlyn, Pennsylvania 19094 (610) 689-8698 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION STEPHEN J. ROY and KAREN ANN ROY, Plaintiff(s), V. FORD MOTOR COMPANY, Defendant. CASE NO. 14-4886 Civil Civil Action CERTIFICATE OF MAILING -a IN) (J1 I, Paul K. Russell, Esq., do hereby certify that service of a true and correct copy of the within Defendant, Ford Motor Company's Answer with New Matter to Plaintiffs' Complaint was made on this 9th day of October, 2014, to the below listed counsel by United States mail, postage prepaid. Christina GIII Roseman, Esq. ROSEMAN LAW FIRM, PLLC 4885-A McKnight Road, No. 428 Pittsburgh, PA 15237 PAUL K. RU SELL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN J. ROY and NO.: 14 — 4886 Civil KAREN ANN ROY, Plaintiffs, vs. FORD MOTOR COMPANY, Defendant. PLAINTIFFS' REPLY TO NEW MATTER Filed on behalf of Plaintiffs: Stephen Roy and Karen Roy COUNSEL OF RECORD FOR THESE PARTIES: Christina Gill Roseman, Esquire Identification No. 71492 ROSEMAN LAW FIRM, PLLC 4885-A McKnight Road, No. 428 Pittsburgh, PA 15237 croseman@helpforlemoncars.com (800) 745-5259 cp D [� `sem IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN J. ROY and KAREN ANN ROY, Plaintiffs, vs. FORD MOTOR COMPANY, Defendant. No.: 14 — 4886 Civil PLAINTIFFS' REPLY TO NEW MATTER Plaintiffs, Stephen J. Roy and Karen Ann Roy, by and through their attorneys, Roseman Law Firm, PLLC, and Christina Gill Roseman, Esquire, submit the following as their Reply to New Matter of Ford Motor Company: 41. Denied. The allegations of this paragraph constitute conclusions of law to which no responsive pleading is required. To the extent that a response is deemed necessary, the allegations of this paragraph are specifically denied and strict proof thereof is demanded at the time of trial. 42. Denied. The allegations of this paragraph constitute conclusions of law to which no responsive pleading is required. To the extent that a response is deemed necessary, the allegations of this paragraph are specifically denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Plaintiffs respectfully demand judgment against Defendant in an amount not in excess of Fifty Thousand Dollars ($50,000), together with all collateral charges, attorneys' fees, all court costs and treble damages. By: Christina Gill Roseman, Esquire Roseman Law Firm, PLLC Attorney for Plaintiffs 4885-A McKnight Rd., No. 428 Pittsburgh, Pennsylvania 15237 croseman@helpforlemoncars.com (800) 745-8584 2 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the within PLAINTIFFS' REPLY TO NEW MATTER, was served on November / , 2014, via U.S. Mail to: Paul K. Russell, Esq. Dobis Russell & Peterson, PC 213 Yates Ave. Woodlyn, PA 19094 3 Christina Gill Roseman, Esquire Roseman Law Firm, PLLC