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HomeMy WebLinkAbout14-6531S E C T I 0 N A S E C T I 0 N Supreme Cod t o Cour oCo hrno Cil oShe �,�1c, CUMBERLAND.''z „t'" Pennsylvania ,A leas County For Prothonotary Use Only: ?},ir ST -11'�,, Docket No: 14 - 6E31 eivilrem The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service of pleadings or other papers as required by law or rules of court. Commencement of Action: Petition Declaration of Taking D Complaint Writ of Summons R ® Transfer from Another Jurisdiction � Lead Plaintiff's Name: DOROTHY ZURITA Lead Defendant's Name: FORD MOTOR COMPANY Dollar Amount Requested: within arbitration limits Are money damages requested? '�• Yes No (check one) • outside arbitration limits Is this a Class Action Suit? i ; Yes No Is this an MDJAppeal? 1 Yes I No Name of Plaintiff/Appellant's Attorney: David J. Gorberg, Esquire a Self -Represented [Pro Se] Litigant) Check here if you have no attorney (are 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) O Intentional O Malicious Prosecution • Motor Vehicle O Nuisance Premises Liability 0 Product Liability (does not include mass tort) O Slander/Libel/ Defamation O Other: MASS TORT O Asbestos DI Tobacco 0 Toxic Tort - DES O Toxic Tort - Implant O Toxic Waste O Other: PROFESSIONAL LIABLITY O Dental O Legal O Medical O Other Professional: CONTRACT (do not include Judgments) El Buyer Plaintiff 0 Debt Collection: Credit Card O Debt Collection: Other 121 Employment Dispute: Discrimination 0 Employment Dispute: Other O Other: REAL PROPERTY Ejectment O Eminent Domain/Condemnation El Ground Rent ID Landlord/Tenant Dispute • Mortgage Foreclosure: Residential 0 Mortgage Foreclosure: Commercial 0 Partition O Quiet Title O Other: CIVIL APPEALS Administrative Agencies O Board of Assessment 0 Board of Elections O Dept. of Transportation O Statutory Appeal: Other O Zoning Board O Other: MISCELLANEOUS O Common Law/Statutory Arbitration 0 Declaratory Judgment 0 Mandamus ID Non -Domestic Relations Restraining Order © Quo Warranto ID Replevin El Other: Updated 1/1/2011 DOROTHY ZURITA Plaintiff FORD MOTOR COMPANY Defendant 1 �!�_ rJ �D..CFF C�. �T' e fir ThE PP,OTHONCITARY 2011-i NOV 10 P1912: 46 CUMBERLAND COUNTY ;PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. (4 -- 1.053! Civil Term �ava ITer14 20 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 AN ATTORNEY AND FILLING 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 JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PEOPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET, FORTH BELOW TO FIND WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 b./ 115.`15 PA X111' eit (aa5r1 i?' 3 /3a3q DAVID J. GORBERG & ASSOCIATES, P.C. By: DAVID J. GORBERG Identification No.: 53084 32 Parking Plaza Suite 700 Ardmore, PA 19003 215-665-7660 Dorothy Zurita 7027 Kuhn Road Greencastle, PA 17225 vs. Ford Motor Company C/O CT CORPORATION 116 PINE STREET SUITE 320 HARRISBURGH PA 17101 Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COMPLAINT 1. Plaintiff, Dorothy Zurita, is an adult individual citizen an legal resident of the Commonwealth of Pennsylvania residing at 7027 Kuhn Road Greencastle, PA 17225. 2. Defendant, Ford Motor Company is a business corporation qualified to do business and regularly conducts business in the Commonwealth of Pennsylvania and can be served c/o CT Corporation, 116 Pine Street, Suite 320, Harrisburg, PA 17101. BACKGROUND 3. Plaintiff incorporates by reference paragraphs 1 and 2 as fully as if set forth here length. 4. On or about May 2012, Plaintiff purchased a new 2012 Ford Focus (hereinafter referred to as the "vehicle"), manufactured and warranted by Defendant bearing the Vehicle Identification Number 1FAHP3J24CL408526. The vehicle was purchased and registered in the Commonwealth of Pennsylvania. 5. The price of the vehicle, including registration charges, document fees, sales tax, but, excluding other collateral charges not specified, totaled $34,350.64. 6. Plaintiff avers that as a result of the ineffective repair attempts made by Defendant through its authorized dealer, the vehicle cannot be utilized for the purposes intended by Plaintiff at the time of acquisition and as such, the vehicle is worthless. 7. In consideration of the purchase of the above vehicle, Defendant, issued to Plaintiff several warranties, fully outlined in the warranty booklet. 8. On or about May 2012, Plaintiff took possession of the above mentioned vehicle and experienced nonconformities, which substantially impaired the use, value and/or safety of the vehicle. 9. Said nonconformities consisted of but was not limited to defective transmission and sync sytem. Copies of repair receipts are attached hereto and marked as Exhibit "A". 10. The nonconformities violate the express written warranties issued to Plaintiff by Defendant. 11. Plaintiff avers the vehicle has been subject to repair more than two (2) times for the same nonconformity, and the nonconformity remains uncorrected. 12. Plaintiff has delivered the nonconforming vehicle to an authorized service and repair facility of the defendant on numerous occasions. After a reasonable number of attempts, Defendant was unable to repair the nonconformities. 13. In addition, the above vehicle has or will in the future be out of service by reason of the non -conformities complained of for a cumulative total of thirty (30) days or more. 14. The vehicle continues to exhibit defects and nonconformities which substantially impair it's use, value and/or safety. 15. Plaintiff avers the vehicle has been subject to additional repair attempts for defects and/or nonconformities and/or conditions for which the Defendant and or it's authorized service center, may not have maintained records. 16. Plaintiff has been and will continue to be financially damaged due to Defendant's failure to comply with the provisions of its' warranty. 17. Plaintiff seeks relief for losses due to the nonconformities and defects in the above mentioned vehicle in addition to attorney fees and all court costs. COUNT PENNSYLVANIA AUTOMOBILE LEMON LAW CLAIM 18. Plaintiff hereby incorporates all facts and allegations set forth in this Complaint by reference as if fully set forth at length herein. 19. Plaintiff is a "Purchaser" as defined by 73 P.S. §1952. 20. Defendant is a "Manufacturer" as defined by 73 P.S. §1952. 21. Plaintiffs vehicle is a "New Motor Vehicle" as defined by 73 P.S. §1952. 22. Said vehicle experienced non conformities within the first year of purchase, which substantially impairs the use, value and safety of said vehicle. 23. Defendant failed to correct and or repair said nonconformities. 24. The vehicle continues to exhibit defects and nonconformities which substantially impair it's use, value and/or safety. 25. Defendant does not require participation in any informal dispute settlement program prior to filing suit. 26. As a direct and proximate result of Defendant's failure to repair the nonconfoii ities , Plaintiff has suffered damages and, in accordance with 73 P.S. §1958, Plaintiff is entitled to bring suit for such damages and other legal and equitable relief. 27. Plaintiff avers that upon successfully prevailing upon the Lemon Law claim herein, all attorney fees are recoverable and are demanded against the Defendant. WHEREFORE, Plaintiff respectfully demands judgment in his favor and against the Defendant in an amount equal to three (3) times the purchase price of the subject vehicle, plus all available collateral changes and attorney fees. Amount not in excess of $50,000.00. COUNT II MAGNUSON-MOSS FEDERAL TRADE COMMISSION IMPROVEMENT ACT 28. Plaintiff hereby incorporates all facts and allegations set forth in this Complaint by reference as if fully set forth at length herein. 29. Plaintiff is a "Consumer" as defined by 15 U.S.C. §2301(3). 30. Defendant is a "Warrantor" as defined by 15 U.S.C. §2301(5). 31. Plaintiff uses the subject product for personal, family and household purposes. 32. By the terms of the express written warranties referred to in this Complaint, Defendant agreed to perform effective warranty repairs at no charge for parts and/or labor. 33. Defendant failed to make effective repairs. 34. As a direct and proximate result of Defendant's failure to comply with the express written warranties, Plaintiff has suffered damages and, in accordance with 15 U.S.C. §2310(d) (1), Plaintiff is entitled to bring suit for such damages and other legal and equitable relief. 35. Section 15 U.S.C. §2310 (d) (1) provides: If a consumer finally prevails on an action brought under paragraph (1) of this subsection, he may be allowed by the Court to recover as part of the judgment a sum equal to the amount of aggregate amount of costs and expenses (including attorney fees based upon actual time expended), determined by the Court to have been reasonably incurred by the Plaintiff for, or in connection with the commencement and prosecution of such action, unless the Court, in its discretion shall determine that such an award of attorney's fees would be inappropriate. 36. Plaintiff avers that upon successfully prevailing upon the Magnuson -Moss claim herein, all attorney fees are recoverable and are demanded against the Defendant. WHEREFORE, Plaintiff respectfully demands judgment in his favor and against the Defendant in an amount equal to three (3) times the purchase price of the subject vehicle, plus all available collateral changes and attorney fees. Amount not in excess of $50,000.00. COUNT III UNIFORM COMMERCIAL CODE 37. Plaintiff hereby incorporates all the paragraphs of this Complaint by reference as if fully set forth at length herein. 38. The defects and nonconformities existing within the vehicle constitute a breach of contractual and statutory obligations of the Defendant, including but not limited to the following; a. Breach of Express Warranty b. Breach of Implied Warranty of Merchantability; c. Breach of Implied Warranty of Fitness For a Particular Purpose; d. Breach of Duty of Good Faith. 39. The purpose for which Plaintiff purchased the vehicle include but are not limited to his personal, family and household use. 40. At the time of this purchase and at all times subsequent thereto, Plaintiff has justifiably relied upon Defendant's express warranties and implied warranties of fitness for a particular purpose and implied warranty of merchantability. 41. At the time of the purchase and at all times subsequent thereto, Defendant was aware Plaintiff was relying upon Defendant's express and implied warranties, obligations, and representations with regard to the subject vehicle. 42. Plaintiff has incurred damages as a direct and proximate result of the breach and failure of Defendant to honor its express and implied warranties. 43. Such damages include, but are not limited to, the purchase price of the vehicle plus all collateral charges, including attorney fees and costs, as well as other expenses, the full extent of which are not yet known. WHEREFORE, Plaintiff respectfully demands judgment in his favor and against the Defendant in an amount equal to three (3) times the purchase price of the subject vehicle, plus all available collateral changes and attorney fees. Amount not in excess of $50,000.00. COUNT IV PENNSYLVANIA UNFAIR TRADE PRACTICES AND CONSUMER PROTECTION CLAIM 44. Plaintiff hereby incorporates all the paragraphs of this Complaint by reference as if set forth at length herein. 45. The Unfair Trade Practices and Consumer Protection Law defines unfair methods of competition to include the following: (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. 46. Plaintiff, as a Pennsylvania resident, believes, and therefore, avers Defendant's failure to comply with the terms of the written warranty constitutes an unfair method of competition. 47. Section 201-9.2(a) of the Unfair Trade Practices and Consumer Protection Law, authorizes the Court, in its discretion, to award up to three (3) times the actual damages sustained for violations of the Act. WHEREFORE, Plaintiff respectfully demands judgment in his favor and against the Defendant in an amount equal to three (3) times the purchase price of the subject vehicle, plus all available collateral changes and attorney fees. Amount not in excess of $50,000.00. DAVID J. GORBERGS BY: CIATES, P.C. DAVID J. GORBERG, ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned, after having read the attached pleading verifies that the within Civil Action Complaint is based on information furnished to counsel, which information has been gathered by counsel in the course of this lawsuit. The language of the Civil Action Complaint is that of counsel and not of signer. Signer verifies that he has read the within Civil Action Complaint and that they are true and correct to the best of the signer's knowledge, information and belief. To the extent that the contents of the Civil Action Complaint are that of counsel, verifier has relied upon counsel in taking this verification. This verification is made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: J. GORBERG • ,DATE:: INVOICE NO. APRII.25,2012 L408526 VEHICLE IDENTIFICATION NO. YEAR AME 1FABP3024CL408526 2012 FORD 'BODY TWE' FOCUS 4DR SEDAN TITANIUM NO. CYLS. SERIES OR MODEL 19..0Q* • N/R 4 ,P33- SHIPPING P3J SNIPPING WEIGHT 2804 LBS. 0 CERTIFIED .FOR SALE IN CALIFORNIA 1, the undersigned 'authorized represehtotive,of the company firm or corporation.named below, hereby cer- tlfy:that the new vehicle "described above is the property of the _aid comtiany,firm or corporotion and Is transferredon the above date and under the Invoice Number indicated -to the -following distributor or dealer. NAP:1E OF DISTRIBUTOR; DEALER, ETC. Keystone Ford 301 .•Walker `Road Chambersburg' RA: 17201 27D523: It is further certified that this was the first transfer of such new motor vehicle in ordinary trode and commerce. 'MEMO. DATA FINANCE SOURCE' 000001 Ford Motor Credit Co Box 1732, ' Room Dearborn . • MI 48121 1111111111111111111111111111111 FORD -.MOTOR COMPANY BY. BRADLEY M GAYTON,SECRETARY GAN 110111111111111uuiuiiiiiiiniiiiiiiimiiuiii (AGENT) �7 RBS Citizens - Dealer Number - . Buyer: .,. r , - _r_ ix. RETAIL INSTALLMENT CONTRACT Dale PA (Prim Fun Name and Address of Principal Resrderce) Co -Buyer: . : .' ':.,.: (Print Full Name and Address of Principal Residence) Creditor -Seller:. ; , _ .'. • - (Print Full Narne and Address) WHO IS BOUND: You, the Buyer (and Co -Buyer, if any), may buy the vehicle described below for cash or on credit. By signing below, you -choose to buy the vehicle on credit under the terms on the front and back of this Contract and are individually liable for any amount due. In this Contract, we", "us", and "our" mean the creditor named above and, atter assignment. the creditor's assignee ("Assignee"). • You agree to buy and we agree to sell the following vehicle: New, Used! or Demo Year '— Make and Model Body Type Vehicle Identification Number Key Number . , . - . --, .. a . f . .. -1- T ., .--7,'!P:. ( -',.f.1',.. t :.,..7 IF YOU DO NOT MEET YOUR CONTRACT,OBLIGATIONS,YOU MAY LOSE THE VEHICLE. If truck or recreational vehicle — Describe body, gross vehicle weight and major items of equipment sold: The vehicle is being purchased primarily for personal, family or household, or business purposes. NOTICE TO BUYERS OF USED OR DEMONSTRATION VEHICLES: THE INFORMATION YOU SEE ON THE WINDOW FORM FOR 'THIS VEHICLE IS PART OF THIS CONTRACT. INFORMATION ON THE WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE. AVISO A LOS COMPRADORES DE AUTOS DE USO 0 DE DEMOSTRACION: LA INFORMACION QUE LISTED VE EN LA FORMA DE VENTANILLA PARA ESTE VEHICULO ES PARTE DE ESTE CONTRATO. LA INFORMACION EN LA FORMA DE VENTANILLA DOMINA CUALESQUIER ESTIPULACION CONTARIA EN EL CONTRATO DE VENTA. TRUTH -IN -LENDING DISCLOSURES ANNUAL PERCENTAGE RATE FINANCE CHARGE AMOUNT FINANCED TOTAL OF PAYMENTS TOTAL SALE PRICE The cost of your credit as a yearly rate. The dollar amount the credit will cost you. The amount of credit pro- vided to you or on your behalf. The amount you will have paid after you have made all payments as scheduled. The total cost o1 your pur- chase on credit, including your downpaymenl.of PAYMENT SCHE_DU_LE: Your payment schedule will be - _ -. monthly payments of $ _ __ __ each, due on the same day of each month starting on _- __ . - - _ . PREPAYMENT: You have the right to pay off this Contract early. If you do so. you will not have to pay a penalty. SECURITY: You are giving us a security interest in the motor vehicle being purchased. LATE CHARGE: If all or any portion of a payment is late, you will be charged a default charge of Iwo percent per month of the unpaid amount of the installment. OTHER TERMS: Please read this Contract, including the reverse side, for additional information on security interests, nonpayment, default, and our right to require repayment in full before the scheduled maturity date. IF YOU DO NOT MEET YOUR CONTRACT,OBLIGATIONS,YOU MAY LOSE THE VEHICLE. ITEMIZATION OF THE AMOUNT FINANCED 1. Cash Price of Vehicle (including any accessories, installation. services, repairs, taxes and other permitted costs): 2. Downpayment: A. Trade-in. Your Trade-in is a tr Gross Allowance $ _ . .._ _ :_ Tess Amount Owing $ 1 equats Net Trade-in $ (If Amount Owing exceeds Gross Allowance, enter "0" as Net Trade-in and enter excess as Prior Credit or Lease Balance in Item 4D) B. Cash Downpayment C. Manufacturer's Rebate Applied to Downpayment D. Total Downpayment (A plus B plus C) 3. Unpaid Balance of Cash Price (1 minus 2D): 4. Other Charges Including Amounts Paid to Others on Your Behalf: A. Amounts Paid to Insurance Companies (Amounts paid to Insurance Companies as per insurance disclosures below)*: 1. Optional Credit Life Insurance 2. Optional Credit Accident and Health Insurance B. Amounts Paid to Public Officials: 1. Government License and/or Registration Fees 2. Certificate of Title Fees 3. Lien Recording Fees 4. Other (Specify) 5. Other (Specify) 6. Other (Specify) C. Seller's Documentary Fee (not a governmental fee) $ , 1. To - For Prior Credit or Lease Balance . . $ * 2. To —_ ----------- -- - ._-For _ . $ 3. To __ _ . _ _.— __ For _ _ * $ -- 4. To - _ _........ . . .. . For * $ E. Total Other Charges and Amounts Paid to Others on Your Behalf (A plus B plus C plus D) $ - — — (4) 5. Amount Financed/ Unpaid Balance (3 plus 4E): $ 1.:_.: t ___L:._!. :__ (5) 6. Finance Charge $ -- ..._ _ (6) 7. Time Balance. $ 4:— -"- - and dTe BPayment Schedule: One payment of $ and __ payments of $ each, beginning on the dates shown in the PAYMENT SCHEDULE above. *To the extent permitted by applicable law. we may be receiving a portion of these amounts._ _ PROMISE TO PAY: You promise to pay us the Amount Financed shown above, plus a Finance Charge determined by applying a daily rate of 1/365th (11366th in a leap year) of the Annual Percentage Rale shown above to the unpaid balance in the Amount Financed for each day this Contract remains unpaid. You agree to make payments in accordance with the Payment Schedule shown in the Truth in Lending Disclosure Box shown above. You also agree to pay any late charge you incur. PAYMENTS BEFORE OR AFTER DUE DATE: This is a simple interest Contract. This means that the amount of the Finance Charge shown above may vary depending upon when your payments ere received. The earlier you make payments before their due dates, the less Finance Charge you will owe. The later you make payments after they are due, the greater the Finance Charge. We credit each payment in any manner we choose, unless applicable law requires a particular method of payment allocation. We will send you a check for any amount owed you (it it is 51.00 or more) after you make your last payment; we will advise you of any additional amount owed (if it is $1.00 or more).There is a possibility that a supplemental payment of interest might be due if earlier payments were received after their due date. LOCATION OF VEHICLE: The vehicle will be kept at the above address of the Buyer, unless another address is listed below: V.T111.010 wzrL-sz•r11,471=. -1"01.1 ort0o0C NOT TO BUY CREDIT INSURANCE. CREDIT LIFE INSURANCE AND CREDIT ACCIDENT AND HEALTH INSURANCE ARE NOT REQUIRED TO OBTAIN CREDIT. INSURANCE WILL NOT BE PROVIDED UNLESS YOU SIGN AND AGREE TO PAY THE ADDITIONAL CHARGE. The policies or certificates issued by the insurer will describe Ihe terms and conditions in further detail. If you want the following insurance, sign below. Life ( Buyer Co -Buyer Both) at a premium of $ for a term of _ Credit life insurance will pay your debt on this Contract up to $ Disability, Accident and Heatth (Buyer Only) at a premium of $ _ for a term of Credit disability, accident and health insurance will pay your debt on this Contract up to $ The name of the insurer is of X Buyer Signature Date Co -Buyer Signature X Date THIS CONTRACT DOES NOT PROVIDE FOR AUTOMOBILE LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS. IMPORTANT: THE TERMS OF THIS CONTRACT ARE CONTAINED ON BOTH SIDES OF THIS PAGE. READ THE ADDITIONAL TERMS ON REVERSE SIDE BEFORE SIGNING BELOW. DUE TO THE PASSAGE OF THE °USA PATRIOT ACT" WE ARE REQUIRED TO NOTIFY OUR CUSTOMERS OF THE FOLLOWING: VERIFICATION OF CUSTOMER IDENTITY - Federal laws and regulations require us to request information from you prior to opening an account or adding an additional signatory to an account. The information we request may vary depending on the circumstances, but at a minimum, will include your name, address, an identification number such as your social security or taxpayer identification number, and tor individuals, your date of birth. We are also required to verify the information you provide to us. This verification process may require you to provide us with supporting documentation that we dem appropriate. We may also seek to verify the information by other means. We reserve the right lo request additional information and/or signatures from you from time to time. In all cases, the protection of our customers identity and confidentiality is our pledge to you. The Annual Percentage Rate may be negotiable with the Creditor -Seller. The Creditor -Seller may assign this Contract and retain its right to receive a part of the Finance Charge. NOTICE TO BUYER. DO NOT SIGN THIS CONTRACT IN BLANK. YOU ARE ENTITLED TO AN EXACT COPY OF THE CONTRACT YOU SIGN. KEEP IT TO PROTECT YOUR LEGAL RIGHTS. Buyer Co -Buyer Signs : : Signs BY SIGNING BELOW, YOU ACKNOWLEDGE THAT YOU HAVE READ BOTH SIDES OF THIS CONTRACT. YOU ALSO ACKNOWLEDGE RECEIPT OF A TRUE AND COMPLETELY FILLED IN COPY OF THIS CONTRACT AND A COPY OF THE CITIZENS FINANCIAL GROUP, INC. PRIVACY NOTICE AT THE TIME YOU SIGN THE CONTRACT. X x -- '--Buyer's Signatu Date_ - . (Co) Buyer's Signature Date Creditor-Selle'r_. - By signing here, the Creditor -Seller accepts this Contract and also agrees - - i Signs •-• ... . - to the terms of the Sellers Assignment on the reverse side. Date CjSTOMEIR COPY 602163939/11) stone '-Date 301 Walker Road Chambersburg, PA 17201-9798 Phone (717) 264-5104 Fax (717) 264-8585 www.keystoneford.com Salesperson ' ` — _ VEHICLE BUYERS ORDER Buyer's Name Address (City, State and Zip Code) Li -1' ' Residential Phone Email Address Business Phone Mobile Phone Co- Buyer's Name Address (City, State and Zip Code) Residential Phone Business Phone Email Address Mobile Phone THIS BUYERS ORDER I5 FOR THE FOLLOWING • tt NEW ❑ USED 0 DEMONSTRATION Y'0 CAR 0 TRUCK 0 PRIOR USE: TO BE DELIVERED ON OR ABOUT , Year Make Model Type Trim Color Mileage Stock # 1 :%15 _A .iY' , . 3 ei.. :-.5.: YR._ MAKE 1-'t_'. _:1 TRADE IN - .. I RECORD MODEL . TYPE ':!,i 1 i.. .—.j7.: I VIN f = 1 rl I i 1,= 1 �} 1. 1. I ,F , PRICE OF VEHICLE ,• ,.,,• coLOR TRIM MnEAGE VIN TITLE NO. PLATE NO EXP. DATE OWNER 1 : •-• - '1' - LOAN ' • , LIE$IHOLOER - ! s1 ';1•;T : I.!.• :;1:/t»tI e:.s:_,ill-�;.?Iv PHONE '' I-: _ _ r . ADDRESS 7, -CI :0: 7C•.:..:1-;..:::— i CO. 1•+:1!..{•:1.• I_:- } E! r SPOKE WITH Pr. ! '. _ . : •, AMOUNT COLLISION NAME OF AGENT GOODTILL COVERAGE VERIFIED BY PHONE •• .-" • _ • ._ . ADDRESS POLICY NUMBER CO ;SION DEDUCTIBLE INSURANCE CO. SPOKE WITH EFFECTIVE DATE EXP. DATE �+ VERIFIED BY Cash Price of Vehicle & Accessories WARRANTY INFORMATION Sales Tax :' c :' C( r-ACTORY WARRANTY - The manufacturer's warranty constitutes esped to the sale of Gds es al of the warranties with r iterMtems. The Seiler hereby expressly disclaims aft warranties, either expressed or Implied Including eny Implied warremy of merchantability or fitness for a particular purpose, and the Seiler neiCror assumes nor authorizes any other parson to assume far it any fiabf ity In connection with the sale of this Wernfdem3. kn 0 USED CAR WARRANTY . Used car Is covered by a Woad warranty detailed In a separate document. You may obtain a lull coNofany appt ewarrantyfromus. 0 ASIS - THIS MOTOR VEHICLE IS SOLD 'AS IS' WITHOUTAm' WARRANTY EITHER EXPRESSED OR IMPLIED. THE PURCHASER WILL BEAR THE ENTIRE EXPENSE OF REPAIRING OR CORRECTING ANY DEFECT THAT PRESENTLY EXISTS OR THAT MAY OCCUR IN THE VEHICLE. PURCHASEt3 S t_' SIGNATURV X} "r-' ' •r t �^ PTA Tax ($1.00 PER TIRE) -- . REGISTRATION TITLE TRANSFER ENCUMBRANCE - �tl ' L''r `' ' ` Temporary Registration Plate Fee r Documentary Fee , 1._2,, c—.7 Notary Fee „ . On -Line Registration Fee : •, , '7.5 USED CAR BUYERS GUIDE: THE INFORMATION YOU SEE ON THE WINDOW FORM FOR THIS VEHICLE IS PART OF THE CONTRACT. INFORMATION ON THE WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE. GUTA PARA COMPRADORES DE VEHICULOS USADOS. LA INFORMACION DUE VE EN EL FORMULARIO DE LA VENTANILLA �` ` , I ,; l ,--.-21:`' '� ` 1=: Total Price '. t , '., -; : , - ADDITIONAL TERMS AND CONDITIONS 1. These definitions appy to this Agreement. • 'Dealer' "us" "our' and ''we" mean or refer to the authorized Dealer named on the face of this Agreement and 4:ho becomes a party to this Agreement by accepting it • "Buyer' and' you" mean or refer to the party executing this Agreement as such. • "Manufacturer" means the corporation that manufactured the Vehicle. • `Vehicle" is the vehicle or chassis that is the subect of this Agreement. • 'Trade-in" is the used vehide that Buyer intends to use as part of the consideration for the purchase price of the Vehicle or otherwise is to be trans`encd to Dealer. We are not the fvtanufacturers agentYou and ?..;e are the sole partes to this Agreement. References in this Agreement to Manufacturer are for the purpose of describing certain contractual relationships between. the Manufacturer and us relating to new vehicles. 2. We may chnn;a the cash delivered price of the Vehicle before it is delivered to you. We may only do finis if the increase is because a low or regulation of the United States or Pennsylvania i5 passed v.rhich (a) requires the addition of new egu prnsnt to:wehic, es of the series and body type of the Vehicle; (b) changes trancpprtation costs or existing tax rates; or (c) if the Vehicle is a foreign -made vehicle, is due to a revaluation of Ilia United States dollar vs -ii -vis the currency of the ccuntr, of manufacture. If we do, you may cancel this Agreement. If you cancel, we yid return any Trade-in to }du, unless ,r;e have sold it Ycu ape to pay reasonable storage and repair charges. If v,e have sold the Trade-in, :•:e will pay you the sales price, less a saes commission of 15', and any expense in storing, insuring, conditioning or advertising it for sale. 3. If you don't deliver your Trade-in to us untl we deliver the Vehicle to you, we gull reappraise the Trade-in at that time, sub;ect to applicable la',. The rears rateed value :'iii1 be the allowance for the Trade-in. If the reappraised value is loser than the. amount shown in this Agreement. you may cancel the Agreement. You must exercise your right to cancel before we deliver the Vehicle to you and you surrender the Trade-in to us. 4. You agree to give us satisfactory evidence of tittle to any Trade-in when you defr.-er it to us. You warrant any Trade-in to be your property. You 4varrant Het the Trade-in is ire and dear of all liens and encumbrances unless otherwise noted in this Agreerrent, and that the Trade-in has never had a salvage or branded'tile. You represent that the Trade-in's mileage shown in this Agreement is the actual mileage on the Trade-in unless you have noted other mueege on this Agreement. You authorize us to rely on this representation in entering into this transaction. If you provide false information, you will repurchase the related trade-in from us for the full price allowed to you plus all costs we incur in resolving this matter including but not limited to reconditioning costs, legal fees, court and collection costs. 5. If you tail or refuse to accept delivery of the Vehicle or comply :ciln this Agreement, we may keep as liquidated damages any cash deposit you made, to the extent not prohibited by law. We may reimburse ourselves for any expenses and lasses we incur or suffer as a result of your falure or refusal. Such expen es and losses gray include our reasonable attorneys' fees. This section doesn't appy if you cancel this Agreement under section 2 or 3. 6. The Manufacturer may change the design of any vehicle, chassis, accessories, or parts at any time without notice and without obligation. The Manufacturer may also make the same or any similar change upon any vehide, chassis, accessories, or parts already bought by or shipped to us or being manufactured or sold in accordance with our orders. If the Manufacturer makes such a change, we have no obligation to you to make the same or any similar change in the Vehicle or its parts either before or after we deliver the Vehicle to you. 7. We aren't liable for failure to deliver or delay in delivering the Vehicle where such failure or delay is due, in whole or in part, to any cause beyond our control or without our fault or negligence. 8.TheVehicle price includes reimbursement for Federal Excise taxes. The Vehicle price doesn't include sales taxes, use taxes or occupational taxes based on sales volume, (federal, state or local) unless expressly so stated. You agree to pay, unless prohibited by law, any such taxes imposed on or that apply to the transaction reflected by this Agreement, regardless of who has primary liability for the tax. r 9. If this Agreement shows a charge for Credit Insurance, this paragraph applies. The Credit Insurance provisions in any retail installment contract you later sign related to this Agreement will apply If such insurance is wholly or partly unavailable under the designated policy, we wilt deduct the applicable part of the Credit Insurance charge shown in this Agreement and the related finance charge from the Total Time Balance. ff such insurance dors not become effective, we vtill notify you of that fact. This Agreeerrent and stmoo IY031 NMA ti (10A tvfSKO :va0i Suis, d0 3SOdHnd aoi SS3rati t!O 1t43U:03 OS SY YI3rMWiHO SS3114X3 :l1t4 45M0$ S3xat7antatid3H1 .tu% dwop splou,ted pug spicuRoa agl of r1i91O s'°'"scti J.Sn3-tld-0a 'ON W!104 ,MV7 a 31Va IaluasaJday poWaVl^V W As pa4da3 v as IsnWj pia X SNOWS H3Af18-03 • 1VAOHddV S4H39VNVW X MIS 113Af18 1N3W3389V SIHI NI SNOIIIONO3 ONV SWH3111V 01 S331WV ONV 1N3W33H9V SIH110 S39Vd 11V 0V38 SVH 83Afla •3SfV10 NOi1VH118IHV NV SNIVINO31N31413389V SIH1 `03X3383 SI X08 SIH1111VH1 S39031MON)l3V H3Af18 0 '831V30 01 NO11V1133NV3 30 33110N N311111M ONIA19 A9 3Ai1VJN3S3Hd3H 831V30 03ZIHOH1flV NV A8 03NHIS 1N3W33H5V 3H1 10 Ad03 V 301413338 380138 31A111 ANV ONI133H 11111 V 31113338 (INV 1N3W331191/ SIH1 133NV3 AVW'H3An8 381 `(l0A •antleluasaidaJ'aleap paz!iogine ue Aq pauars !gun iaAng Jo JaIea0 aaylla uodn Bulpulq lou s! luawaat6V sfyl luawaai6y sly{ 10 ,Sdoo anal e paA!eaaJ set pue swnal sp peas set ay ley; sabpaimou>loe '{uawaai6V sly{ 6u!u6!s Aq 'iar(n8 •luawaaj6V slyl Aq paranoa sjapew laafgns ay{ o; 6ullelaa Iuawaa,ee ay{sola{ ay{ Io {uawalels anlsnlaxa pue aleidwoa ay{ 'I3ea1u03 ales luawlle'sul Melee Aue yl1M 'sashdwoa Molaq Rep ay{ {o se pue `sluawaaa6e !en 6ulpnlaui luawaa46e Jo!id Aue sapasjadns pue walled IuawaaJ6V sfyl leyl'loamy apes rlaeq pue1U0.11 ayl uo suolllpuoa pue swaal aqi to He sapnlaul luawaaJ6v slyl ley'seaa6e JaAna a.4 aloud 1 °J.10 aouelea pledull luawAed umoa leloi ,GatiiaQ + 1!sodaa + apgtl = 410 4SS3 IaN rtJanirea uo use •tri f psode 4._ ul apea . iiaN ualeVtaA of Ipaigng sl i. goiled ssa-i wnouv Uo,(ed, , ul-apeJi 0 X 311n1VNOIS S.1:13SVHOFlnd sa6ewe seS 10 lunowe all P lla}rol `uopdo ono le'llegs noA'iw Aq papIw1ed se ldaaxa `paiapjo a13140A ail 10 v.zo liap aqui of asn;ai to luawaaJ6e eseyaind situ laoueo noA p •V1N3A 30 OlYliW0313 N3 VOIN31NO3 OIHVaDNO3 N3 N013IS0dSI0 V001 013313 NIS tfr30 V11INVIN311 Vl 30 OIHVIfWH03 130 NQI3VWUOINI til-01V»1NO3 11.Al1C111.111n.._2LU11..LK1A1W11 nintuuan_atea_iuuul Where the customer always comes first) 301 WALKER ROAD CHAMBERSBURG, PA 17201 (717) 264-5104 Owner Advantage Members Reward # SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday R/O Open Date RIO Number R/0 Close Date 5/31/12 Status Mileage In Mileage Out 11 11 Service Advisor / Tag # DAVID SANOCKI Inventoried V659 Year 2012 FO Make FOCUS Model Work hone Home Phone Body 4DR SDN TIT Vehi e Identi 'cation Number FAHP3J24CL408526 Delivery Date In -Service Date 5/31/12 5/31/12 RED Color Y License Number DESCRIPTION OF SERVICE AND PARTS - MR CFL: CLEAN FOR LOT Work performed by ROGER WILLIS(803) Sub Total: Labor: 35.30 Parts: .00 Total: 35.30 #2 - MR CFD: CLEAN FOR DELIVERY Work performed by ROGER WILLIS(803) Sub Total: Labor: 100.00 Parts: .00 TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 'thereby authorize the repair LABOR work hereinafter 10 be done along with the necessary material and agree that you are not respons- PARTS itile for loss or damage to vehicle a articles left in the vehicle in case or fire. Urex, or any other Total: 100.00 cause beyond your contra or for any de'ays caused by unavailability of parts or delays In parts DEDUCTIBLE shipments by the supplier or transporter. I hereby gran: you or your employees permission to operate the vehicle herein described on streets. highways. a elsewhere for the purpose of testing end/or inspection. An express mechhanic's Gen Is hereby atiutowledged on above vehicle to secure the amount of repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are Nose made by the manufacturer. The seller hereby expressly disclaims all warranties either express or implied, Includ ing any implied warranty of merchantability or fitness for parioular purpose, and the seller neither assumes nor authorizes any other person to assume for it any liability in connection with Ole sale of said products. Any limitation contained herein does not apply where prohibited by law. SUBLET _SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX I.D. r SPECIAL ORDER DEPOSIT AMOUNT Internal Internal DISCOUNTS TOTAL DUE NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. x 20,8 0•850.0. 8 . D.AeNm AMunon Oro. r,W111G0oE .00 .00 . 00 .00 .00 .00 .00 .00 . 00 .00 Where the customer always comes first! 301 WALKER ROAD - CHAMBERSBIIRG, PA 17201 (717) 254-5104 Owner Advantage Members Reward A SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday RIO Open Date 6/04/12 RIO Close Date 6/04/12 Mileage In 2 RIO Number 8557715/1 Status Reprin Mileage Out Service Advisor / Tag # DAVID SANOCK 2 ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 Year 2012 FORD Make FOCUS Model Work Phone Home Phone 505-879-7000 Body 4DR SDN TITANIUM Vehicle Identification Number 1FAHP3J24CL408526 Delivery Date 5/31/12 Color RED CANDY In -Service Date License Number 2659 DESCRIPTION OF SERVICE AND PARTS fl - MR SS5: ZURICH SHIELD - APPLICATION AMOUNT Work performed by REX FORSHEY(196) TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 1 hereby authorize the repair work hereinafter to be done along with the necessary material and agree that you are nal respons- ible for loss or damage to vehicle or articles left In the vehicle in case of fire, theft. a any other muse beyond your control or for any delays caused by unavailability of parts or delays in parts shipments by No supplier or transporter. I hereby grant you or your employees permission 10 operate the vehicle herein described on streets. highways. or elsewhere for the purpose of testing and/or inspection. An express mechanic's lien Is hereby acknowledged on above vehicle to secure the amount o1 repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are those made by Inc manufacturer, The seller hereby expressly disclaims all warranties either express or implied, includ., ing any implied warranty of merchantability or fitness for a particular purpose, and the seller neither assumes nor authorizes any other person 10 assume lor any liebility in connection with the sale of said products. Any limitation contained herein does not apply where prohibited by law. NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. x _Lamas AflKONA Ysc-ner.nthtF ON121.11.1211 LABOR PARTS Infernal DEDUCTIBLE - SUBLET SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX I,D. 1 SPECIAL ORDER DEPOSIT DISCOUNTS TOTAL DUE .00 00 .00 .00 .00 .00 .00 ,00 .00 .00 CUSTG;NER 4: 100112 DOROTHY ZURITA 7027 KUHN RD GREENCASTLE, PA 17225 HOME: CONT:N/A BUS: CELL:505-879-7000 147548 *INVOICE* PAGE 1 SERVICE ADVISOR: �a�errotouir� 1714 Massey Blvd., Hagerstown. MD 21740 Ph: 1301) 733-3673 • Fax: 1301) 733-5836 www.hagerstowntord.com KingAuto .com 5709 CODY BELCASTRO COLOR YEAR MAKE/MODEL VIN LICENSE MILEAGE IN / OUT TAG RED 12 FORD FOCUS 1FAHP3J24CL408526 11333/11333 T827 DEL. DATE PROD. DATE WARR. EXP. PROMISED PO NO. RATE PAYMENT INV. DATE 01JAN12 DE WAIT 230CT12 CASH 230CT12 R.O. OPENED READY OPTIONS: DLR:01401 ENG:2.0 Liter GDI 16:22 230CT12 17:13 230CT12 LINE OPCODE TECH TYPE HOURS A MULTI ?OINT INSPECTT CAUSE: COURTESY INSPECTION 16FOZZ99P MULTI POINT INSPECT 95600 CP GBATT BATTERY TEST GOOD 95600 CP GTIRE TIRES IN GOOD CONDITION, 7/32"AND GREATER 95600 CP GBRK BRAKE CONDITION GOOD, OVER 5MM OR 7/32" (DISC), AND OVER 2MM OR3/32" (DRUM) 95600 CP PARTS: 0-00 LABOR: 0.00 OTHER: LIST NET TOTAL 0.00 0.00 0.00 0.00 0.00 TOTAL LINE A: B "THE WORKS" PACKAGE, OIL AND FILTER••CHANGE'(S QTS); ROTATE TIRES AND PERFORM MULTI POINT INSPECTION WRKS "THE WORKS" PACKAGE; OIL AND.FII1TER CHANGE (5 QTS), ROTATE TIRES AND PERFORM MULTI POINT INSPECTION 95600 CP 1 BE8Z*6731*AB KIT-- ELEMENT & GASKET-•OILF:F 5 XO*5W20*BSP 5W20 OIL 23.25 LABOR: 16.70 OTHER: 0.00 PARTS: 16.70 8.33 5.50 3.55 3.55 TOTAL LINE B: **************************************************** CUSTOMER PAY SHOP SUPPLIES FOR REPAIR ORDER \,6 \�rzfV7 0.00 0-00 0.00 0.00 0.00 16.70 5.50 17.75 39.95 1.84 't -01 -QC‘ C1 Manufacturer Special Policy Adjustment Programs: Federal law requires manufacturers to Impish the National Highway Tref lie Safety Admrmslrntion (N. FI T.S.0.1 wnh bulletin describing any detect in their vehicles. You may obtain copies 01 these bulletins from either the mor.ufecwrer or 0.H.T.S.6. In addition, certain consumer puble a:ions or organizations oublIsh this information. which may evelable for a fee or for teat,. DESCRIPTION TOTALS LABOR AMOUNT WARRANTY STATEMENT: PURSUANT TO MARYLAND LAW. CONSUMERS HAVE SPECIFIC IMPLIED WARRANTY RIGHTS IN CONNECTION WITH THE SALE rECRWIrral SERVICES. ANY WARRANTIES BY A MANUFACTURER 00 SUPPLIER OTHER THAN OUR DEALERSHIP. HOWEVER. ARE THEIRS. NO1 OURS, AND ONLY SUCH MANUFACTURER OR SUPPLIER SHALL BE LIABLE FOR PERFORMANCE UNDER SUCH WARRANTIES. NO EXPRESS IV 5RANTIES ARE GIVEN 01 OUR DEALERSHIP. 1F THIS REPAIR 15 NOT PERFORMED IN CONNECTION WITH A CONSUMER TRANSACTION. THE DEALERSHIP HEREBY EXPRESSLY DISCLAIMS ALL WARRANTIES. EXPRESS AND IMPLIED, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY ANO FITNESS 10A A PARTICULAR PURPOSE. AND NEITHER ASSUMES NOR AUTHORIZES ANY OTHER PERSON TO ASSUME 008 IT ANY LIABILITY IN CONNECTION WITH THE SALE OE PARTS OR PRODUCTS OR 114E REPAIR. PARTS AMOUNT GAS, OIL, LUBE SUBLET AMOUNT 'SHOP SUPPLY COSTS: We have added a charge equal to 10% of the total cost of labor and pans, not to exceed 525.00. to the Repair Order tor shop supplies used in connection with this repair. MISC. CHARGES ' TOTAL CHARGES I hereby acknowledge that the Dealershipis not responsible for loss or damage to the vehicle or articles lett in the vehicle in case offire, theft, or any other cause eyv nd its control (please direct questions !elating to the extent of the Dealership's reSPOOSIb I ly or insurance coverage to a ealershlp Representative). By slgnirog below. you acknowledge that you were notified of and authorized the Dealership to perform the services/repairs itemized in this Invoice and that you received for had the opportunity to inspect) any replaced parts as requested by you. The vehicle is being returned to you in exchange for your payment el the Amount Due. LESS INSURANCE SALES TAX 16.70 23.25 0.00 0.00 1.84 41.79 0.00 1.51 PLEASE PAY THIS AMOUNT DATE CUSTOMER SIGNATURE AUTHORIZED DEALERSHIP REPRESENTATIVE SIGNATURE Deo F AQ 02006 POP I/11081 SERVICE INVOICE TYPE 7 . 7970 'LIMITED WARRANTY' co COPY 43,30 ALL PARTS ARE NEW UNLESS OTHERWISE INDICATED. VEHICLE REPORT CARD MULTI; POINTr1NSPECTION AS RECOMMENDED BYLFORDMOOR COMPANY Date: /o/Z Name: t T} RO/Tag ff / 4ti Email: Year/Make/Model I z— (—`--- --. VIN #: C- w6 t 2,(0 Plate ft: Odometer: / / -333 Inspect. Month: Owner Advantage Rewardsc St: Service Balance. Ford Extended Service Plan: ❑ YES ❑ NO SYNC VHR Activation: ❑ YES ❑ NO [1 N/A SCHEDULED MAINTENANCE ITEMS* DUE SERVICED Y-14 0 ( Oil Change & Filter 0 1/. 1( n Engine Coolant DUE SERVICED [2 Tire Rotation D 1 !Transmission Fluid BJor Filter 1 ] Multi -Point Inspection Cabin Air Filter 0 (— I Fuel Filter Spark Plugs n K Scheduled Maintenance 'This Is only a partial list of vehicle maintenance items and is NOT ail -Inclusive. Please consult your Owner's Manual or visit FordOwner.com for vehicle•speciflc maintenance requirements. ®C Oil and/or fluid leaks FLUIDrI!EVELS SERVICED n OKrrLlFILL _ 1 1 Engine Oil 1 1 Brake Reservoir OK pia nPower Steering 7 Window Washer T I(I 0 Wiper Test Performed OK FILL C WIAERIBLADES 1I Transmission (f ecuq:D-d v,:r dipstick) LICoolant Recovery Reservoir ❑ n Wiper Blades iSERVICED BATTERY SERVICED ago State of Health Battery Condition lion % Won Factory spec cold cranking amps Actual cold cranking amps qic 1 FORD SERVICE LEGEND 0 May contribute to vehicle efficiency and promote a greener environment DChecked and OK at this time nMay require future attention irrr Note any existing exterior body damage or detects on diagram 7� _r , EXTERIOR BODY ni Requires immediate attention SYSTEMS / COMPONENTS SERVICED II Operation of hom, interior lights, exterior lamps, turn signals, hazard and brake lamps II ® ❑ W• indshield for cracks, chips and pitting I d- r' SERVICED II nH• VAC system and hoses / lines tor leaks and/or damage II nEngine Cooling System, radiator, hoses and clamps Ii nAccessory drive belt(s) i:.•1 = . - SERVICED ou❑ Brake system (including lines, hoses, and parking brake) 0 n SERVICED ra 11 nShocks / struts and other suspension components for leaks and/or damage 11 1I Steering, steering linkages and ball joints (visual) II 1I ❑ Exhaust system and heat shield (leaks. damage, loose parts) 0 SERVICED ❑ SERVICED ❑ C• lutch operation (t equipped) 1I n C• onstant velocity (CV) drive axle boots (if equipped) I1 ( ; Drive shaft, transmission, u -joint and shift linkage (if equipped) l�1 and lubricate (as needed) n (_1 Ii TIRE TREAD 7132" a d Over5mm0 7132' (Disc or Over 2mmor3132"(Oro m) SERVICED nAlignment check needed n TIRE►/BRAKE WEAR 4/2"to 6/32 - Over 5yrim o 13T 3 to imm or Oar' to7rlT (Disc) or 1.01 to 2mm (Drum) or 2/3T to 31T 01 IC Tire Tread Depth q /32" Tire Age SERVICED SERVICED 1I ®n n Tire Tread Depth / /32" Tire Age Wheel balance needed nn❑ Tire Wear Pattern / Damage n710 Tire Wear Pattern / Damage Brake measurements not % taken this service visit Comments: r II nTire Pressure set to factory -recommended PSI ❑ Brake Lining mm /32" 43 - U SERVICED ❑ Tire Pressure set to factory -recommended PSI Finn Brake Lining mm /32" ellgt"iTt :0 Ej❑ n Tire Tread Depth "I /32" Tire Age n vin ❑ Tire Wear Pattem / Damage n Tire Tread Depth 9 _/32" Tire Age 1/1111-1 171 1 (n Tire Wear Pattem / Damage SERVICED n DIn❑ Tire Pressure set to factory -recommended PSI 1711 in Tire Pressure set to factory -recommended PSI 11 rtIEE Brake Lining mm /32" n Fin n Brake Lining mm /32" II :11.'`t • 'rclj1 0 SERVICED OfIE Tire Pressure set Tire Age Advisor: S --4v l Customer Signature: Technician: FordOwner"com One site tor all your vehicle needs Customer Copy Dealer eSrore Item #VRC-FORDGAS-ENG. Rev. 07112 02012. Ford Motor Company. All Rights Reserved Wys Where the customer always comes first! 301 WALKER ROAD - CHAMBERSBURG, PA 17201 (717) 2645104 Owner Advantage Members Reward # SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday RIO Open Dale 11/26/12 R/O Number 8567009/1 R/O Close Date. Status 11/28/12 Reprint Mileage In MileageOut 6454 16457 Service Advisor / Tag # DARIAN FALCONE 0989 ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 ort ' hone Vehicle Idents icatlon umber 1FAHP3J24CL408526 Home Phone Delivery Date In -Service Date 505-879-7000 5/31/12 5/31/12 Year Make Model Body Color License Number 2012 FORD FOCUS 4DR SDN TIT IUM RED CANDY 12659 DESCRIPTION OF SERVICE AND PARTS AMOUNT 1 - MR 10FOZ: ELECTRICAL RADIO DISPLAY GOES BLANK AND NAV MAP DISAPPEARS Work performed by DAVE STOKES(881) UPDATED THE FICM MODULE TO VEHICLE - MR 10FOZ: ELECTRICAL REAR VIEW CAMERA STAYS HICLE PLACED IN DRIVE. Work performed by DAVE UPDATED MODULE RELATED ON FOR A LONG TIME AFTER VE STOKES(881) TO LINE 1 - MR 10FOZ: ELECTRICAL WIPERS COME ON AT WILL. WINDSHIELD IS RAIN SENSORE D Corrected by 999A: (W03) (42) ADDITIONAL - MISC. REPAIRS L Work performed by MIKE CORDELL(718) Installed BV6Z 17D547 A (FP):PROCESSOR - WINDSHIEL Qty: REPLACE RAIN SENSOR 1 - MR 07FOZ: TRANSMISSIONS CUSTOMER STATES MUCH HESITATION AND VEHICLE SHAKES AT PULL OUT. ALSO HAS RATTLE SOUND Work performed by DAVE STOKES(881) UPDATE THE TRANSMISSION CONTROL MODULE AND THE POWER CONTROL MODULE SETTINGS - MR MISC: MISC. OP CODE RENTAL COORDINATED FOR MONDAY AFTERNOON DROP OFF. TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 1 hereby authorize the repair LABOR worts hereinafter to be done along with the necessary material and agree that you ere not respons- ible for loss or damage to vehicle or articles left in the vehicle in case of fire, theft, or any other PARTS cause beyond your control or for any delays caused by unavailability of parts or delays in parts DEDUCTIBLE shipments by the supplier or transporter. I hereby grant you or your employees permission to - —.- operate the vehicle herein described on streets, highways. or elsewhere for the purpose of testing SUBLET and/or inspection. An express mechanics lien is hereby adutowledged on above vehicle to secure Internal Internal Warranty Warranty Internal Me amount of repairs thereto.' SHOP SUPPLIES DISCLAIMER OF WARRANTIES. A warranlies on theHAZARDOUS MATERIALS Any productsnsed hereby are those made by I SALES TAX OR TAX I.D. -r— the the menufadurer. The seller hereby expressly disclaims ad warranties either express or implied, induct- ing any implied warranty of merchantability or fitness tor a particular purpose. and the seller neither assumes nor authorizes any other person to assume for it any liability in connection with the sale of said products. Any (imitation contained herein does not apply where prohibited by law. SPECIAL ORDER DEPOSIT NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. IC) MONA 0, . 3 v.n reaows.roa DISCOUNTS TOTAL DUE \KySt. Where the customer always comes first! 301 WALKER ROAD - CHAMSERSRURG, PA 17201 (717) 284.5104 Owner Advantage Members Reward # ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 Year 1 2012 FORD Make FOCUS Model SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday RIO Open Date R/O Number 11/26/12 R/O Close Date 8567009/2 Status 11/28/12 Reprint Mileage In 16454 Mileage Out 16457 Service Advisor / Tag # DARIAN FALCONE/0989 Work Phone Horne Phone 505-879-7000 Body 4DR SDN TITANIUM Vehicle Identification Number 1FAHP3J24CL408526 Delivery Date 5/31/12 In -Service Date 5/31/12 Color I License Number RED CANDY 12659 DESCRIPTION OF SERVICE AND PARTS AMOUNT 6 * MR BUFF: BUFF VEHICLE IN ADDITION TO RECON HOOD, WASH BUFF AND REAPPLY ZURICH SHIELD Work performed by REX FORSHEY(196) Work performed by JOE SCHIANODICOLA(843) 7 * MR GBATT: BATTERY CONDITION IS GOOD Sub Total: Labor: .00 Parts: .00 Total: .00 8 * MR GTIRE: TIRES CHECKED AND OK, TREAD 7/32 OR GREATER Sub Total: Labor: .00 Parts: .00 Total: .00 TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. "1 hereby authorize the repair work herelnaher ro be done along with the ne ncsary material and agree that you are not respons. ible for loss or damage to vehicle or articles left in the vehicle in case of fire. theft, or any other cause beyond your coned or for arty delays caused by unavailability ol parts or delays in parts shipments by the supplier or transporter. 1 hereby grant you or your employees permission to operate the vehicle herein described on streets. highways, Or elsewhere for the purpose of tes ng and/or inspection. An express mechanic's Gen is hereby acknowledged on above vehicle to secure the amount of repairs thereto' DISCLAIMER OF WARRANTIES Any warranties on the products sold hereby are those made by the manufacturer. The seller hereby expressly disdeims as warranties either express or implied. includ- ing any implied warranty of merchantability or fitness for a particular purpose, and the seller neither assumes nor authorizes any other person to assume for it any liability in connection with the sale of said products Any limitation contained herein does not apply where prohibited by law. LABOR PARTS DEDUCTIBLE Internal Internal .00 .00 SUBLET SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX I.D. SPECIAL ORDER DEPOSIT DISCOUNTS TOTAL DUE NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. .00 .00 _ .00 .00 .00 .00 .00 00 K st Where the customer always comes first! 301 WALKER ROAD - CHAMBERSSURG, PA17?01 (71 7) 2645104 Owner Advan Reward SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday RIO Open Date /2 3 R/O Close Date 1/25/13 Mileage In RIO Number 8569856 Status Reprint Mileage Out Service Advisor / Tag DARIAN FALCONE/045 ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 Year 2012 i FO Make FOCUS Model Work Phone Honie Phone 505-879-7000 Body 4DR SDN TIT Vehicle Identification Number 1F P3J24CL408526 Delivery Date In -Service Date 5/31/12 5/31/12 Color D CANDY License Number 2659 DESCRIPTION OF SERVICE AND PARTS AMOUNT 2 - MR 12FOZ: BODY CUSTOMER STATES WHEN IN REVERSE AND PUTTING THE VEHICLE INTO DRIVE THE REVERSE CAMERA IS STAYING ON Work performed by DAVE STOKES(881) Sub Total: Labor: .00 Parts: .00 Total: .00 WORKING FINE AT THIS TIME - MR 12FOZ: BODY CUSTOMER STATES THE MY TOUCH SCREEN IS NOT COMING AT TIMES WHEN STARTING VEHICLE FOR A FEW MINUTES Work performed by JASON CHRONISTER(072) Sub Total: Labor: .00 Parts: .00 Total: .00 RELATED TO RECALL - MR 12FOZ: BODY Sub Total: Labor: .00 Parts: .00 Total: .00 CUSTOMER STATES THE MY TOUCH SCREEN WILL GO BLANK AT TIMES AND NONE OF THE HEATER OPTIONS OR RADIO OPTIONS COME ON AND WHEN THE SCREEN COMES BACK ON THE RADIO PRESET OPTIONS ARE NOT ON THERE - MR 12FOZ: BODY CUSTOMER STATES THE HEATER BUTTONS ON CENTER CONSULE WILL NOT WORK AT TIMES THEN HAD TO A WAIT A FEW MOMENTS FOR THEM TO WORK TE- RMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 1 hereby authorize the repair work hereinafter 10 be done along with the necessary material and agree that you are not respons- ible for loss or damage to vehicle or articles left in the vehicle in case or fire, the& or any other cause beyond your control or for arty delays caused by unavailability of parts or delays in parts shipments by the supplier Or transporter. I hereby grant you or your employees permission to operate the vehicle nerein described on streets. highways, or elsewhere for the purpose of testing and/or inspection. An express mechanic's lien is hereby acknowledged on above vehicle 10 secure the amount of repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are those made by the manufacturer. The seller hereby expressly disclaims all warranties either express or implied, includ- ing any implied warranty of merchantability or fitness for a particular purpose. and the seller neither assumes no; authorizes any other person to assume tor it any liability in connection with the sale of said products. Any limitation contained herein does not apply where prohibited by taw. LABOR PARTS DEDUCTIBLE SUBLET NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. rrr Md ARxrMA ht .Nom, n AaWn6+n Gown r6001E.15-12211 SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX ID. I SPECIAL ORDER DEPOSIT DISCOUNTS TOTAL DUE Where the customer always comes first) 301 WALKER ROAD CHAM8ERSBURG, PA 17201 (717) 264.5104 Owner Advantage Members Reward # ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 2012 FORD FOCUS Ivlodel SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday RIO Open Date RIO Close Date 1/25/13 R/O Number 8569856/2 Status Reprint Mileage In I Mileage Out 18569 Service Advisor / Tag # DARIAN FALCONE 0458 Work Phone Vehicle Identification Number 1FAHP3J24CL408526 Home Phone Delivery Date In -Service Date 505-879-7000 4DR SDN TIT 5/31/12 Color RED CANDY 5/31/12 License Number 2659 DESCRIPTION OF SERVICE AND PARTS '6 - MR 07FOZ: TRANSMISSIONS AMCUNT CUSTOMER STATES THERE IS A SPUTTER FROM THE TRANSMISSION AT 1700-1900 RPMS Caused by 111213A Work perfoLIned by JASON CHRONISTER(072) Work performed by DAVE STOKES(881) Installed BV6Z 7B546 B :CLUTCH ASY Installed AE8Z 7052 A :SEAL ASY - OIL Installed AE8Z 7048 A :SEAL ASY - OIL Installed XT 11 QDC :FLUID - TRANSMISSION FOUND TRANS FLUID LEAK FROM INPUT SHAFT SEAL. INST ALLED NEW INPUT SHAFT SEALS AND CLUTCH ASSEMBLY PE R TSB 11-12-13 Qty: 1 Qty: 1 Qty: 1 Qty: 2 - MR 99P: PERFORM COMPLIMENTARY VEHICLE REPORT CARD Sub Total: Labor: .00 Parts: .00 Total: .00 #8 * MR LOANER: RENTAL VEHICLE Sub Total: Labor: .00 Parts: .00 Total: .00 #9 * MR 13FOZ: RECALL RECALL 12A04 SYNC/MY TOUCH PERFORMANCE UPDATE Caused by 12A04B Work performed by JASON CHRONISTER(072) Installed DM5Z 19H449 AA :CARD - MEMORY UPDATED SYNC TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 1 hereby authorize the repair work hereinafter to be done along with the necessary materiel and agree that you are not respons- ible for loss or damaoe to vehicle or articles left in the vehicle in case of fire, theft. or any other Cause beyond your control or for any delays caused by unavailability of parts or delays in parts shipments by the supplier or transporter. I hereby grant you or your employees permission to Operate the vehrde herein described on streets, highways. or elsewhere for the purpose of testing anduor inspection. An expos mechanic's lien is hereby acknowledged on above vehicle to secure the amount of repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are those made by the manuladurer, The seller hereby expressly disclaims all warranties either express or implied, induc- ing any implied warranty of merchantability or fitness for a particular purpose, and the seller neither assumes nor authorizes any other person to assume for 11 any liability in connection with the sale of said products. Any limitation contained herein does not apply where prohibited by law. LABOR__ PARTS DEDUCTIBLE SUBLET Qty: 1 Warranty Warranty Warranty Warranty Warranty Warranty Warranty Warranty .00 -.00 SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX ID. SPECIAL ORDER DEPOSIT DISCOUNTS TOTAL DUE NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. X fraMANxQJA lnc ,DaceteMare., an::14S5.tntn .00 .00 .00 .00 .00 .00 .00 .00 8571149/1 K y s Where the customer always comes first) 301 WALKER ROAD - CHAMBERS8URG, PA 17201 (717) 284-5104 Owner Advantage Members Reward # ZUR I TA , DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday RIO Open Date 2/19/1 RIO Close Date 2/22/13 Mileage In RIO Number Status Reprint Mileage Out 29369 29497 Service Advisor/Tag # STACEY BARTLES Year 2012 FO Make FOCUS Model Work Phone Home Phone 505-879-7000 Body 4DR SDN TITANIUM Vehicle Identification Number 1FAHP3J24CL408526 Delivery Date In -Service Date Color f License Number 5/31/12 RED CANDY 12659 DESCRIPTION OF SERVICE AND PARTS - MR 10FOZ: ELECTRICAL AMOUNT BACK UP CAMERA STAYS ON FOR APPROX A FEW MINUTES A FTER MOVE FORWARD INTERMITTENT Work performed by MIKE KELLEY(812) Sub Total: Labor: .00 Parts: .00 Total: .00 CHANGED CAMARA SETTING IN VEHICLE TURNED OFF DELAY OPTION #2 - MR 10FOZ: ELECTRICAL BLOWER MOTOR INOP DURING INITIAL START UP FOR APPR OX 10 MIN INTERMITTENT Work performed by MIKE KELLEY(812) Sub Total: Labor: .00 Parts: .00 Total: .00 CHECK TEMP CONTROL CHECK BLOWER MOTOR OPERATION UN ABLE TO DUPLICATE CONCERN AT THIS TIME #3 - MR 03FOZ: STEERING/SUSPENSION WHEN FIRST START UP AND START MOVING APPROX 2-3 MI N OF DRIVING MAKES NOISE SOUNDS LIKE DRIVERS FRONT AREA LIKE RUBBING NOISE FOR APPROX 5-10 SEC WONT REOCCUR DURING DRIVING Work performed by MIKE KELLEY(812) Sub Total: Labor: .00 Parts: .00 Total: .00 ROADTEST CHECK FOR NOISE NORMAL ABS MOTOR PROVE OU T OPERATION NOTE TIRES NOISEY CUPPED #4 - MR 07FOZ: TRANSMISSIONS CHECK FOR HESITATION SLIGHT BUCK ON INCLINES APPRO X 30 TO 45 MPH TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 1 hereby authorize the repair work hereinaher lo be done along with the necessary material and agree that you are not respons- ible for loss or damage to vehlde or articles left In the vehicle in case of fire. theft, or any other cause beyond your control or for any delays caused by unavailability of pens or delays in parts shipments by the supplier or transposer. 1 hereby grant you or your employees permission to operate the vehicle herein described on streets. highways, or elsewhere for the purpose of testing and/or inspection. An express mechanic's lien is hereby acknowledged on above vehicle to secure the amount ce repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are those made by ne manufacturer. The seller hereby expressly disclaims all warranties either express or implied, rnclud- no any implied wenanty of merchantability or fitness for a particular purpose, and the seller neither, rssumes nor authorizes any other person to assume for It any liability In connection with the sale of .aid products. Any limitation contained herein does not apply where prohibited by law. LABOR PARTS DEDUCTIBLE SUBLET SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX I.D. SPECIAL ORDER DEPOSIT DN ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. DISCOUNTS TOTAL DUE 1abSt Where the customer always comes first! 3171 WALKER ROAD - CHAMBERSBURG. PA 17201 (717) 264-5104 weer Advantage Members Reward # ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 Year 2012 FORD IM -lake FOCUS Model SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday R/O Open Date RIO Number 2/19/13 8571149/2; R/O Close Date Status 2/22 3 Mileage In 29369 Reprint Mileage Out 29497 Service Advisor / Tag # STACEY BARTLES Work Phone Home Phone 505-879-7000 Body 4DR SDN TITANIUM Vehicle Identification Number 1FAHP3J24CL408526 Delivery Date 5/31/12 Color RED CANDY In -Service Date 5/31/12 License Number 2659 DESCRIPTION OF SERVICE AND PARTS Wor per Orme• •y MIKE KELLEY 812 ROADTEST CHECK TRANSMISSION OPERATION ELECTRONIC T EST NO ABNORMAL CODES PERFORM ADAPTIVE STRATEGY AN D DRIVE NORMAL OPERATION #5 * MR FUEL: PUT FUEL IN VEHICLE Work performed by 84227 : 885713 () TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE, 1 hereby authorize Me repair work hereinafter 10 be done along with the necessary material and agree that you are not respons- ible for loss or damage to vehicle or articles left in the vehicle in case of fire, theft, or any other cause beyond your control or for eny delays caused by unavailability of parts or delays in parts shipments by the supplier or transporter. I hereby grant you or your employees permission to operate The vehicle herein described on streets, highways, or elsewhere for the purpose of testing and/or inspection. An express mechanic's Gen is hereby acknowledged on above vehicle td secure fhe amount of repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are those made by the manufacturer. The seller hereby expressly disclaims all warranties either express or implied, includ- ng any implied warranty of merchantability or fitness for a particular purpose. and the seller neither assumes nor authorizes any other person to assume for it any liability in connection with the sale of LABOR PARTS _ _ _ _ DEDUCTIBLE - 'SUBLET _ SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX I.D. 1 SPECIAL ORDER DEPOSIT AMOUNT Interna Internal said products. Any limitation conlained herein does not appy where prohiblled by law. DISCOUNTS TOTAL DUE .00 .00 •00 .00 .00 .00 NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. X fC) SOte ARAIX1. Mt . DehMMAoaiprfon da'u remxrts'hoze 04 • 00 .00 s Where the customer always comes first) 301 WALKER ROAD - CHAMBERSBURG, PA 17201 (717) 264-5104 r Advantage Members Re SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday R/O Open Date 3/06/ 3 RIO Number 8571842/1 RIO Close Date Status 3/07/13 Reprint lvlileage In Mileage Out 31667 31667 Service Advisor / Tag # TODD GARDENER ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 Year 2012 FORD Make FOCUS Model Work Phone Horne Phone 505-879-7000 Body 4DR SDN TITANIUM Vehicle Identification Number 1FAHP3J24CL408526 Delivery Date 5/31/12 Color RED CANDY In -Service Date 5/31/12 License Number 2659 DESCRIPTION OF SERVICE AND PARTS AMOUNT 1 - MR 99P: PERFORM COMPLIMENTARY VEHICLE REPORT CARD Sub Total: Labor: .00 Parts: .00 Total: .00 - MR 12FOZ: BODY WHEN USING BLUE TOOTH CUSTOMER IS NOT HEARD CLEARLY BY PERSON SHE IS TALKING TO Caused by NO PROBLEM FOUND Work performed by MIKE KELLEY(812) Sub Total: Labor: .00 Parts: .00 Total: .00 3 - MR WRKS: THE WORKS PACKAGE - GAS OIL CHANGE UP TO 5 QTS Work performed by MIKE KELLEY(812) Installed BE8Z 6731 AC :KIT - ELEMENT & GASKET - 0 1@5.99 Installed XO 5W20 BSP :MOTORCRAFT SAE 5W-20 API GF 4@3-60 Installed XO 5W20 BSP.5 :MOTORCRAFT SAE 5W-20 API 1@1.80 Sub Total: Labor: 15.96 Parts: 22.19 Total: 38.15 WORKS - MR 12FOZ: BODY WHEN TURNING ON THE VENTILATION SYSTEM IT WILL NOT COME ON RIGHT AWAY IT WILL NOT WORK FOR 5 TO 10 MILES Caused by NO PROBLEM FOUND Work performed by MIKE KELLEY(812) Sub Total: Labor: .00 Parts: .00 Total: .00 TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE, 'I hereby authorize the repair work hereinafter to be done along with the necessary material and agree that you are not respons- ible for loss or damage to vehicle Or articles left in the vehicle in case of fire, theft. or any other cause heyond your control or for any delays caused by unavailability of parts or delays in pads shipments by the supplier or transporter. I hereby grant you or your employees permission to operate the vehicle herein described on streets, highways. or elsewhere for the purpose of testing and/or inspection. An express mechanic's lien Is hereby acknowledged on above vehicle to secure the amount of repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby ere those made by the manufacturer. The seller hereby expressly disclaims all warranties either express or implied. includ- ing any implied warranty of merchantability or fitness for a particular purpose, and the seller neither )assumes nor authorizes any other person 10 assume for it any liability in connection with the sale of said products. Any limitation contained herein does not apply where prohibited by We. LABOR PARTS DEDUCTIBLE SUBLET SHOP SHOP SUPPLIES `HAZARDOUS MATERIALS__ SALES TAX OR TAX I.D. 1 SPECIAL ORDER DEPOSIT DISCOUNTS TOTAL DUE NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. ICI209E ARK05A Int . Oer4+Re Aminimn Gloss 11005441028 15.96 5.99 14.40 1.80 • \Kyst Where the customer always comes first! 301 WALKER ROAD • CHAMBERS&URG, PA 17201 (717) 264.5104 Owner Advantage Members Reward # ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 12659 FOCUS SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday RIO Open Date R/O Number 3/06/13 8571842/2 R/O Close Date Status 3/07/13 Reprint Mileage In Mileage Out 31667 31667 Service Advisor / Tag # TODD GARDENER Work Phone Vehicle Identification Number 1FAHP3J24CL408526 Honie Phone Delivery Date In -Service Date 505-879-7000 4DR SDN TITANIUM 5/31/12 RED CANDY 5/31/12 License Number DESCRIPTION OF SERVICE AND PARTS - MR LOANER: RENTAL VEHICLE Sub Total: Labor: .00 Parts: .00 Total: .00 AMOUNT - MR 12FOZ: BODY BLOWER SOUNDS LIKE ITS KNOCKING Caused by NO PROBLEM FOUND Work performed by MIKE KELLEY(812) Sub Total: Labor: .00 Parts: .00 Total: .00 #7 * MR PASI: PA STATE INSPECTION 812 Caused by NEEDS FOUR NEW TIRES TO PASS INSPECTION Work performed by MIKE KELLEY(812) Sub Total: Labor: 26.95 Parts: .00 Total: 26.95 26.95 #8 * MR GBATT: BATTERY CONDITION IS GOOD Sub Total: Labor: .00 Parts: .00 Total: .00 #9 * MR RTIRE: TIRES WORN, TREAD DEPTH AT OR BELOW 3/32, TIRES Sub Total: Labor: .00 Parts: .00 Total: .00 TREAD BAR IS SHOWING #10 *MR GBK: BRAKE LININGS ARE OK AT THIS TIME ALL AT 10/32 TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 1 hereby authorize the repair work hereinafter to be done along with the necessary material and agree that you are not respons- ible for loss or damage to vehicle or articles lett in the vehicle in case of fire, theft, or any other cause beyond your control or for any delays caused by unavailability of parts or delays in parts shipments by the supplier or transporter. I hereby grant you or your employees permission to operate the vehicle herein described on streets, highways. or elsewhere for the purpose of testing and/or inspection. An express mechanic's Gen is hereby acknowledged on above vehicle to secure the amount of repairs thereto' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are those made by the manufacturer. The seller hereby expressly disclaims all warranties either express or implied, includ- ing any implied warranty of merchantability or fitness for a particular purpose, and the seller neither assumes nor authorizes any other person to assume for it any liability in connection with the sale of said products. Any limitation contained herein does not apply where prohibited by taw. LABOR PARTS DEDUCTIBLE 42.91 SUBLET SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX SPECIAL ORDER DEPOSIT NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. ICI2COIARK0rr. Inc -nf.. ,,.o cesc.0Ip IE49V45-IQ7G DISCOUNTS TOTAL DUE Cham VS/MC/DISC H72315 22 19 .00 .00 -00 .00 3.91 .00 .00 69.01 69.01 Wyst Where the customer always comes first! 301 WALKER ROAD - CHAMBERSBURG.PA17201 (717) 264.5104 Owner Advantage Members Reward ft ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1:00 p.m. Saturday RIO Open Date RIO Number RIO Close Date 5/21/13 Status Reprint Mileage In Mileage Out 32054 32054 Service Advisor / Tag # TODD GARDENER Work • one ehicle dent' (cation umber 1FAHP3J24CL408526 Home Phone Delivery Date In -Service Date 505-879-7000 5/31/12 5/31/12 Year 1 Ivlake Model Body Color License Number 2012 FORD FOCUS 4DR SDN TITANIUM RED CANDY 12659 DESCRIPTION OF SERVICE AND PARTS 12FOZ: BODY SYNC FOR PHONE NOT WORKING ORDER NEW APIM Caused by CP: 14D212 Corrected by 999A: (A18) (42) ADDITIONAL - MISC. - L Work performed by AARON WAGAMAN(254) REMOVED AND REPLACED APIM. FORD SITE WAS DOWN UNABLE TO PROGRAM NEW APIM WILL NEED TO BRING VEHICLE BACK MR REPAIRS #2 * MR PASI: PA STATE INSPECTION OK PER STACY Caused by TIRES ALL AT 9/32 BRAKES 10/32 FRONT 8/32 REAR Work performed by AARON WAGAMAN(254) TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 1 hereby authorize the repair work hereinafter to be done along with the necessary material and agree that you are not respons- ble for loss or damage to vehicle or articles left in the vehicle in case of fire. theft. or any other cause beyond your control or for any delays caused by unavailability of parts or delays In parts shipments by the supplier or transporter. I hereby grant you or your employees permission to operate the vehicle herein described on streets. highways. or elsewhere for the purpose of testing andtor inspection. An express mechanic's fen is hereby acknowledged on above vehicle to segue the amount of repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are those made by the manufacturer. The seller hereby expressly disclaims aft warranties either express or implied. indud- ng any implied warranty of merchantability or fitness for a particular purpose. and me setter neither assumes nor authorizes any other person to assume tor it any liability in connection with the sale of said products. Any limitation contained herein does not apply where prohibited by law. LABOR PARTS DEDUCTIBLE SUBLET SHOP SUPPLIES AMOUNT Warranty Internal HAZARDOUS MATERIALS SALES TAX OR TAX I.D. SPECIAL ORDER DEPOSIT DISCOUNTS TOTAL DUE NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. Ii1 J000AAK*M1 Irtt Amkraten Gown IOT]41S 107• .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 Ky Stolle Where the customer always comes first! 301 WALKER ROAD - CHAMBERSBURG RA 17201 1717) 264-51C' ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 I 2012 1 112659 FORD Make° Model SERVICE DEPARTMENT HOURS 8:00 a.m. to 5.00 p m. Monday - Friday 8.00 a.m - 1.00 p m. Saturday T ork hone RIO Open Date RIO Number 8575652/1 RIO Close Date Status Pre-Invoic Mileage In Mileage Out 38266 38266 Service Advisor / Ta • # STACEY BARTLES Home Phone 505-879-7000 Vehicle Identification Number 1FAHP3J24CL408526 Delive Date In -Service Date FOCUS 4DR SDN TITANIUM Color License Number RED CANDY DESCRIPTION OF SERVICE AND PARTS : CHANGE ENGINE OIL AND OIL FILTER Work performed by AARON WAGAMAN (254) Installed BE8Z 6731 AC :KIT - ELEMENT & GASKET - 0 Installed X0 5W20 BSP :OIL Installed XO 5W20 BSP -5 :5W20 1/2 QT OIL #2 - 12FOZ: BODY STEERING WHEEL CHROME PEELING Installed DM5Z 58043B13 CA :MODULE AMOUNT Internal Internal Internal Internal Internal ITERMS STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE 1 hereby authonze the repair worx hereinafter to oe done along with the necessary matenal and agree that you are not respons- ible for less or damage to vehicle or anrctesheli in the vehicle In case of bre. theft, or any other cause beyond your control or for any delays caused by unavailability of pans or delays In pans snlpmenls by :he supplier o• transporter I Hereby grant you or your employees permission to operate the vehicle herein described on streets, highways, or elsewhere for the purpose of testing sand o: inspection An express mechanic's lien is Hereby acknowledged on above vehicle 10 secure j;re amount of repairs Iherelo' DISCLAIMER Or WARRANTIES Any warranties on the products sold hereby are those made by nc manufacturer The seller hereby expressly d.sclaims all warranties either express or implied. induct ::rig any nnphed warranty of merchantability or hlnes5 for a panteutar purpose, and the seller neither lassurnes nor authorizes any other person to assume for .1 any liability in connection with me sale of Isad products Any limitation contained herein does 001 apply where prohibited by law NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. IX LABOR .00 PARTS .00 DEDUCTIBLE SUBLET .00 .00 SHOP SUPPLIES -00 HAZARDOUS MATERIALS .00 SALES TAX OR TAX I.D. -00 SPECIAL ORDER DEPOSIT .00 DISCOUNTS .00 TOTAL DUE -00 Wyst Where the customer always comes first! 301 WALKER ROAO CHAMBERSBURG, PA 17201 (717) 264.5104 Owner Advantage Members Reward # SERVICE DEPARTMENT HOURS 8:00 a.m. to 5:00 p.m. Monday - Friday 8:00 a.m. - 1.00 p.m. Saturday RIO Open Date 10/28/14 - RIO Close Date 10/28/14 Mileage In 85889 RIO Number 8604201/1 Status Mileage Out 85889 Service Advisor / Tag't; TRACY WELSH/634*W* ZURITA, DOROTHY 7027 KUHN RD 246-450-573 GREENCASTLE, PA 17225 Year 1 Make 2012 FORD 1 Model FOCUS Work hone Home Phone 505-879-7000 body 4DR SDN TITANIUM ehicle Idents [cation um.er 1FAHP3J24CL408526 Delivery Date 5/31/12 Color RED CANDY In -Service Date 5/31/12 License Number 12659 DESCRIPTION OF SERVICE AND PARTS 1 - MISC: MISC. OP CODE CUSTOMER CHELSEA RENGLER SAYS THAT SHE HAS A PAPER STATING THAT SHE CAN GET WORK DONE ON HER FOCUS F OR HER TRANSMISSION, WOULDNT SPECIFY BUT TOLD SAID TO BRING THE PAPER ALONG - 07FOZ: TRANSMISSIONS SHUTTERS ON TAKE OFF WITH HESITATION Work performed by JASON CHRONISTER (072) REPROGRAMMED PCM/TCM PER TSB 14-0197. CHECKED FOR FLUID LEAKS, NONE PRESENT. MONITORED PIDS AND PERF ORMED ADAPTIVE LEARNING. PIDS WITH RPM SPEC TERMS: STRICTLY CASH UNLESS ARRANGEMENTS ARE MADE. 1 hereby authorize the repair work hereinafter to be done along with the necessary material and agree that you are not respons- ible for loss or damage to vehicle or articles left in the vehicle in case of fire. theft, or any other cause beyond your control or for any delays caused by unavailabftity of parts or delays in pans shipments by the supplier or transporter. I hereby grant you or your employees permission 10 operate the vehicle herein described on streets. highways, or elsewhere for the prpose of testing and/or inspection. An express mechanic's lien is hereby acknowledged on above vehicle to secure the amount of repairs thereto.' DISCLAIMER OF WARRANTIES. Any warranties on the products sold hereby are Mose made by the manufacturer. The seller hereby expressly disclaims all warranties either express or implied, includ- ing any implied warranty of merchantability or fitness for a particular purpose. and the seller neither assumes nor authorizes any other person to assume for it any liability In connection with the sale of said products. Any limitation contained herein does not apply where prohibited by law. LABOR PARTS DEDUCTIBLE SUBLET SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX I.D. SPECIAL ORDER DEPOSIT DISCOUNTS TOTAL DUE NO RETURN ON ELECTRICAL OR SAFETY ITEMS OR SPECIAL ORDERS. tome Acwoto,wt_ ne.t,.s�Twmceyorawe/p?9feS}70n AMOUNT Warranty .00 .00 .00 00 .00 .00 .00 .00 .00 .00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DOROTHY ZURITA, Plaintiff, CASE NO. 14-6531 Civil v. FORD MOTOR COMPANY, Defendant. Civil Action C- 7. Fri ry PRAECIPE FOR ENTRY OF APPEARANCE r%) 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 fort Date: January 9, 2015 elow. JAM P. PETERSON, ESQ. (ID No. 77315) A,- rney for Defendant, Ford Motor Company DOBIS, RUSSELL & PETERSON, P.C. 213 Yates Avenue Woodlyn, PA 19094 Phone: 610-689-8698 Fax: 973-740-2474 Email: jpeterson@drp-law.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DOROTHY ZURITA, Plaintiff, CASE NO. 14-6531 Civil v. FORD MOTOR COMPANY, Defendant. 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. BACKGROUND 3. Ford repeats and reiterates its answers to the allegations of paragraphs 1 and 2 with full force and effect as though more fully set forth. 4. Admitted. 5. Denied. Ford denies that this is the price of the subject vehicle. 6. Denied. Ford denies ineffective repairs. Ford also denies that the vehicle cannot be utilized for its intended purposes and is worthless. 7. Denied. Ford Motor Company was not a party to the retail sales contract. 8. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle. 9. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle. However, Ford does admit that copies of repair documents are attached as Exhibit "A". 10. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehiicle. 11. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle and that the vehicle was subject to two (2) repair attempts. 12. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle. 13. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle and 30 days out of service. 14. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 15. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 16. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 17. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. AS TOCOUNT I 18. Ford repeats and reiterates its answers to the allegations of paragraphs 1 —17 with full force and effect as though more fully set forth. 19. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 20. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 21. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 22. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle. 2. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle. 24. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle. 25. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 26. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 27. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. AS TO COUNT II 28. Ford repeats and reiterates its answers to the allegations of paragraphs 1 — 27 with full force and effect as though more fully set forth. 29. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 30. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 31. Upon reasonable investigation, Ford Motor Company does not have enough information to admit or deny. As such, this averment is denied. Strict proof is demanded at trial if material. 32. Admitted, during the term of the original warranty only. 33. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 34. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 35. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 36. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. AS TO COUNT III 37. Ford repeats and reiterates its answers to the allegations of paragraphs 1 — 36 with full force and effect as though more fully set forth. 38. Defendant denies the existence of any defects or non -conformities that substantially impair the use, value or safety of the subject vehicle. Ford also denies breach of warranties, express and implied. 39. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 40. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 41. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 42. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 43. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. AS TO COUNT.IV 44. Ford repeats and reiterates its answers to the allegations of paragraphs 1 — 43 with full force and effect as though more fully set forth. 45. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 46. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. 47. This is a conclusion of law to which no responsive pleading is required. Strict proof is demanded at trial. NEW MATTER 48. The subject vehicle does not have a non -conformity; defect or condition which substantially impairs its use, value or safety. 49. Plaintiff has failed to state a claim upon which relief may be granted. 50. Plaintiffs claims are barred by the Doctrine of Accord and 8atisfaction. 51. Plaintiffs claims are barred by the applicable statute of limitations. 52. Plaintiffs claims are barred by the Doctrine of Res Judicata. 53. The alleged non -conformity, defect or condition is the result of abuse, neglect or unauthorized modifications or alterations of the motor vehicle. WHEREFORE, this defendant requests this Honorable Court to enter judgment in its favor. DESIGNATION OF TRIAL COUNSEL PLEASE TAKE NOTICE that JAMES P. PETERSON, 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: January 9, 2015 P. PETERSON, ESQ. #77315 213 Yates Avenue Woodlyn, Pennsylvania 19094 (610) 689-8698 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DOROTHY ZURITA, Plaintiff, CASE NO. 14-6531 Civil v. FORD MOTOR COMPANY, Defendant. Civil Action CERTIFICATE OF MAILING c rJ L. 27 7,0 • --, N) > () I, JAMES P. PETERSON, do hereby certify that service of a true and correct copy of the within defendant's, Ford, Answer with New Matter to Plaintiffs Complaint and Entry of Appearance was made on this 9th day of January, 2015 to the below listed counsel by United States mail, postage prepaid. David J. Gorberg, Esq. DAVID J. GORBERG & ASSOCIATES, P.C. 32 Parking Plaza Suite 700 Ardmore, PA 19003 JAMES P. PETERSON