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Home My WebLink About05-3249ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Attorney's for Plaintiff Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY 1335 S. Clearview Avenue Mesa, AZ 85216 Plaintiff, v. BRADLEY A STUMP 15 S. Baltimore Ave. Mt. Holly Springs, Pa 17065 NOTICE You have been sued in cam If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. Le ban demandado a usted en Is cone. St used quiem defeaderse de estas dernandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plaza al partir de la fecha de Is demands y la notificacion. Howe Salta asentar east COnTarencia escriu o an persona o can an abogado y entregar a la corn en forma escrita sus defenses o sus objeciones a his demandas en contra de so persona. Sea avisado que si usted no se defiende, la corte lamas medidas y puede coatis o ar Is demanda en conm says sin pmvio aviso a notificacion. Adernas, la cone puede decidir a favor del demandante y requiere qua usted compile con todas las provisions de estz demanda. Usted puede perder dinero o sus propiedades a ones derechos importaums part usted. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SURCIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION FIND OUT WHERE YOU CAN GET LEGAL HELP. SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 Defendant. CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. Q$ - Z,q Q (?t U l l CIVIL ACTION COMPLAINT AVISO MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Attorney's for Plaintiff Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY 1335 S. Clearview Avenue Mesa, AZ 85216 Plaintiff, V. BRADLEY A STUMP 15 S. Baltimore Ave. Mt. Holly Springs, Pa 17065 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED CUMBERLAND C COMMON PLEAS Case No. Q $" _3?q CIVIL ACTION COMPLAINT T OF 1. Plaintiff, Ford Motor Credit Company, is a Corporation with its place of business at 1335 S. Clearview Avenue Mesa, AZ 85216. 2. Defendant, Bradley A Stump, is an individual who resides at 15 S. Baltimore Ave. Mt. Holly Springs, Pa 17065. 3. At all times relevant, the Plaintiff was in the business of loaning money on motor vehicle installment sales contracts, including but not limited to the note signed by Defendant, hereinafter more fully described. 4. On or about 9/17/2003, the Defendant entered into a written Motor Vehicle Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of obtaining financing in the amount of $14,933.82 at an annual percentage rate of 10.99%, in order to purchase a certain motor vehicle, more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A. 5. Pursuant to the Contract, Defendant was required to make monthly payments in the amount of $326.08 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 6. Defendant made monthly payments until 6/25/2004, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 7. As a result of the default by Defendant, and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant giving the Defendant the opportunity to redeem the Vehicle as well as notice of the sale date. A copy of the notice of repossession and notice of sale date are attached and marked as Exhibit B. 8. The Defendant failed to redeem the Vehicle and the Vehicle was sold at auction with a credit given to the Defendant in the amount of $8,200.00. 9. After providing the aforesaid credit, a balance of $6,839.59 was still due and owing, and a notice of the deficiency balance was sent to the Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C. 10. Pursuant to the terms of the contract, Defendant is required to pay all amounts due and owing, including any balance that may remain after the sale of the vehicle. The Defendant failed to do so. Defendant is indebted to Plaintiff for the balance of $6,839.59. 11. The total amount due and owing at the time of the filing of this complaint is $6,839.59. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant, in the amount of $6,839.59, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully submitted, MA EDLEMAN, P.C. A D MINC ESQUIRE Attorney for Plaintiff VERIFICATION I, THOMAS DOMINCZYK, ESQUIRE, verify that I am the Attorney of record for Plaintiff, FORD MOTOR CREDIT COMPANY, and duly authorized to make this verification on its behalf, that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unworn falsification to authorities. BY: THOMAS DOMIN YK, ESQUIRE DATED: (I ( 1 ^9I V SIMPLE 15 S. BALTIMORE AVE. MT. HOLLY SPRINGS, PA 17065 SEP 2 3 20x4 race, me BuymlaM CoBUyer, n envA mry euYme wnkle demntladbddwM bNw on aetllt Tre'Creh Pha' ehwn bNw N wcM pHn d1M wnlea. Tb 'TOW Stle Ann' efim,n CNpw Is tb crMlt prltt. 6Y abnlne wls centratt vNCnceb b Wv an c,Ml un6r Nau,eenwa. w.Nrbenl.na boa a m. nm,.w ruw? Ka P N ? Aaabliura NEW 200'5 FORD iF{1FP34313W337)81 ? Wmmmtiel 1995 FDRD F150 INSURANCE rtwa;n 54310.00 53715. 12 vw end Ww G. amonanp YOU MAY OBTAIN VEHICLE INSURANI AmxXm O"kq ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE. t Cash Prke._..................... ...... .................. ..._............ _ $ 16780. 00 YOU ARE NOT REQUIRED TO 08TA It1 CREDIT LIFE, CREDIT DISABILITY At 2. Down Payment OTHER OPTIONAL INSURANCE. TH Third Pony Rebate Assigned W Creeper ............................. $ 2000.00 CONTRACT WILL NOT INCLUDE THE Caen Down Payment ........... ..... ....... ............ ...................._....... $ N/A UNLESS YOU SIGN AND AGREE TO PI Tradeirt?5 FDRD $4310,00 g 3715.12 $ 594.68 THE PREMIUM. avanOMW GrMS xJ4royn NnvM OMnp Total Down Payment ..................................................................... S 2594.88 (21 3. Unpaid Babnce M Cartel Price (1 minus 2) ............. .._................... $ t4185,12 (3) 4. Amounts paid on your behail (Selby may ba ON&AI , a ponbn of these an owls) To Insurance Companies for Oredit t3N Insurance Ilor term d venires) $--?.:m- . . . .. . . . . . . . . . . . . . . . . . . Credit Disebill InWrance (for tam, a rmmra $---??'=T N m)........e (Term W _ _MnrlMa To PuMk OHklela (i) IN Ilcenae tithe (E (& 2 ($__ 3(1_00 ), 22.. 50 ), 8 re915trellbn 4S N/g lees$ N7P; (ii) for fillip lees S 5. 0a (111) far taxes (ON in Cash Pd.) $ 633, 20 $ 696.70 To for Measarger Service ................. S N/A Te for S N/A To`AMILY FORD-MERM416Y NOTARY S DOC FEE $ 52.80 To for $ N/A TOW ............... --............................. ............... _............. ..._................. f 748.70 (4) Amount Financed IS PIUS 4) ......... ...................... . . ; 1-0933. B2 IS! FEDERAL TRUTH-IN-LENDING DISCLOSURES ANNUAL FINANCE Amount ToUI of Total Sale ERCENTAGE CHARGE Fbaneard Pgmenfe Price RATE amwad The e of me emounl a Toe amour tta wW coN ray ray aYm? :% al wedt OnNdee ld you wa b z w pw TUa on MW of oe. warn nn cnr You wa w on Ymf Odnott M,d Wan l hme mom YI seen. IIx:Wdnq your ieawad dmbipaymere - PoMame of as'•• ^^ RETAIL INSTALMENT CONTRACT and LP Code) CREDITOR ($anx Name 170 YORK RD. CARLISLE, PA 17013 THIS CONTRACT DOES NOT INCLU .ABILITY INSURANCE COVERAGE FI BODILY INJURY AND PROPER DAMAGE CAUSED TO OTHERS. ? Oredit Life insurer $ i/n Premium Insuretl(s) Signature Credit ? Disability Insurer $ nfa Premium Inwred Signature Other Op0onel Inaumnce Tenn Insurer $Pre ure creek Lear and peen moral InrunMa an W the som of the cameel TM rnwm uq Yal~, tlNe wn M a nodb a elYeenwnl Payment Sdedub Number W Ammnl of EWi when Psymmb g3p•yo payment are dw Yml payment oolmoule _ 59 I ?ro8 (mgntllty, dMoving) wT be: - f final f-?aw8 iN3N?c--83- ay. I, Piet gong wUi more NON-MODIFICATION DISCLOSURE 1rn &mnp0 in pie comrsa my b In wMft aM eKned by you and M cretliiw. BBAttR. SION / G?BOYER:X swxs YOU ACKNOWLEDGEE THAT YOU HAVE READ AND AGREE TO BE BOUND BY THE ARBITRATION PROVISION ON THE REVERSE SIDE OF THIS CONTRACT. NOTICE TO BUYER Do .rot sign this contract In blank You are entitled to an exact Copy M the contract you Sign. Keep N to protect your legal rights. Buyer (and Co-Buyer) acknowledge that (1) before starting this eordraM, Buyer tend Comovyer) received an rev e a true ampletely filled In Copy of this contract and (11) at the tip o} si rain this contract, Buyer (and Co-Buyer) renal-d e rue an Comp ate y e IT Copy of this contract. e oxa sun %e1P,bp over.., tlw NllMecbpb m4 Hnb bnemedbeeelmnb ueramnbm has an We conbaN, tM a C.mparry. ?.R121/LYFAXI?'a„ n a,Tmrs wv m (... aaa.I.T re .,a.l SEa BACK FOR AOpITp ADNEENBITB l'A Ym, map maces Hb whiek. K e elver, fie ahpan Micw, the Crrabr WII by b buy Hb corebps cocked for me Iwrn aMKn. We be bered on Me ben wlw of irre, IN 10 room own one YrtNr Mod", C3 LpmprenenWe ? $.451-DowNble c maven ? Fks T -al,oirad gmgipbl Cowroge ? TawirN an d d ubw ? T.nn Mpela JEw l.1 Pmnnun$ ? Prb carmenal we. Addnown poundal) m ub bra da d you bee pummm d a deem nncoarl miner. Furclose of ape omeare b vr? cmdmsaw e s a all a wnm'?inw,m''aaw am W nM . en amabd Admnd,m.mbn b kKwpaaYO No eae q.MCL The MW M ram mb nrinNdm ea e, a dal mM mn d,Y entlW in Me renwake d Amcun 1'rancW one sarmn 4. Program No. OUESTKNIS? 9 PLEASE CALLUS AT f-OM727-7000 or Vlsil us at wma.brdmoditcdm 41001 ORIGINAL r ADDITIONAL AGREEMENTS ?cn 0uc re "Ia and Summary NoUFa: You mud make alt F. Default. You will be M doWA R: Ay g Y y your payments M U.S. IundA. ONUOY 0 JUAV ? C60 ny tkm wit t contract. 1. You do net make a payment when It to W e ; « Ta echll Rllsroe lMrge plltiBprfd7Na?(I tlmyour w?p?g o s v 2. YW gew bbswmlek(tdlpq M(pmWbnlC'iStU Uldl S pMmerx TTw hpWGeRNkpIHWCMI Ma Charge vow payments e y ow apptirapon nleBrg ro dNYdRNdb;4N S. I W M p car or than scheduled scheduled an nt. The ic ll add unconditionally authority mom" Cnloor WE apply your payments gnat at the Moved and urryaid named at you; w Fed of In Rrunw Charge and Nan So do knows Financed The 4. You fits a bankruptcy, ppetition m oink Mae against yotsw Cladbr same M Faun Charge by applying the Annul M doe comment. S. YW donot keep m2 Pawmage Rea to areANPWd Amount Financed for Vaql? aa?g1tul tlia aw unpaid Amoum FinamaG b aa&Id061?EB'Mf.NeMdl is If you are 1 C 4200& peY lMSlb S mm"" W, you will rid haw a right m rlmLb ft cwnrad la unWW ncad. Ond unpaid pad of Me F'trlmoa Charge And all other amounts due under efts conoacf. unless do CWIW agrees. A\N A\kM May r"cmm (asks back) efts "HION, loo. MANmy aiso 0. SspurNy Inuraal: YW it" IM Credbr a Security Interest W. fake goods found in or m me vehicle when mponessed and fa Hold them for you. 1. The vehicle And n pm Or One, goods Put on the vehicle; a. All money or goods received for to vnbh; snd If Me vehicle is taken back, he"send you a nollce. The notice 3. Alhwumrae FrenBUns and service convects Z?, WIN soy Mat you may mdeam (buy back) the vehicle. it wR Ober sMVr the amml needed to redeem. You may redeem me This eacwes Payment Of all en oums you owe In this cog"Bi8S vaNds up to the time me Cralbr "Na it ce agrees to SO N. It abn secures your Other agreements in this contract. 00.00E you do not mdeem Me vehicle, h will be add. A ed The CIO& wed user morwy from the eats, ass ter allowed Q. Use of Vehicle • WARRANRES: You must take c 0 dts Vehicle and obey at haws M wing N. You may nl expenses, M pay Me amount aM owed on this contract. Me whole, and you must keep f free hmn the dal 0 Expenses paid as a duect result of naelg b mtave lm vehicle, hold ft ton "Is, and an it am, as permed by taw, allowed You Will monk use w permit don we of the Almost Unhed $Miss, except for up M 30 days M Canada Or Mexico, expanses. Lawyers' fees and too cosh permitted by law are without don pion Written coneanl of the Crellor. N the vehicle Is allowed, loo. The Creditor will pay You any moray kit (a olus). You will pay any moat' after e sale b the owing rr a type mcnncNy wed for panoW use and ter C , or of r«A ' C ount Wh hen ft C n It you m net pay efts amount re Mahn. don i men con 0 wohicle s ex tends s l M i h l Cra st lenses may char e you IMered at me Mghe C rak 9 ce th mvMi np t days Na thaw e a In h sd 90 f vehic e Wa of e ed dab of this co ou lint Insisted wamn w mnehanMMlhy and Sh1YUylw a particular purpose eovsdn9 o. p N A\M g A1N well ed L U d Od. lnn ' f afa whole. OlberMee. YW untlenbM and agree roar there aa: YW a Cnsum• ?N {epp gq rortl Motor Cmdn Com- M obtain`ntMSLTn r from cones"r reportin an are no such Implied wamaARYF. Y1?F g P t a9ndep¢?(credl buresuVYYO any reason aid At any tkm M con. 98N 0. Ineuance: You must haure Yourself orb the CmMt acdon VAn contract. A\N bee or damage M the YeNcle. The Cnedhor must ap typo and amount of Mswance. If me Cradles Wtatrw a M• rams « s rvi ontract Cracker E a wRd fil e th NAYIpg?pJyI"HIN{T ayfN9IId 1Mat Credk Caom?p?o a(bpow ft ' ? 9 u e c s. u . c e W 01l%/'6ll16cNd e 'ifRWN.i t .TFefewUPem- Mond from whet you awe. Whether or m[ the w b m wrad, You vud M for It N a 1• logo r?lor sylvan appl ss to this contract. N the kw does at allow as of the I r m nts In role c mr w Me ma Mg a n t sn w d wR b destroyed' , o ee e o a n, m o e e ag f O. UTSE I I void. The rest of this contract will still be geed. a e Marge tar vAMA kndlidAMlce IS Shown on Me honL Me Creditor vast by to but, the cowend as checked f« ter term shown. The Credaw Is ml liable, though. N he cannot do so. II these wvarep0a COI more Men the RMOUN shown tar Meumnce, Me Cmdmr may buy them for a garter ram or he may give no troll for the amount Mown, It a c0xWsA buy any Insurance. N lown. Tim credit will a made will give You credit mfd?e amount A\ SO MAW Payments due AIR Leer Charge: You will have WgRy a let n Me Ice of each a t made mofa`ihen ten ?Arp?9@?? me AWrge k shown on I?haei rot Aaeplerkw d a lam ayMAm Upes U?' na excuse your default or mean that you can keep .0mg payments aaer May are due. The Creditor may take most" al hoer M Wa contract, If Mere Is any tletsult. EO WE OUA FTC NORCES NOTICE • ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY oRf DERTP0%I yfEUNlt.LEOk 20.01 Used Motor Vehicle Buyers Guide. N you am buying a used whale with this contract, Hearst regulations may equms a Special Guyem Guido to W deplayed m the window of the vnlcIff, RK INFORMATIOR YOU SEE ON THE WIN gqORM FOR THIS VEHICLE IS PART OF THI O YRACT. INFORMATION ON THE WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE. GUARANTY To yy?qyypsee the Slbr ro Sell tiro vehkfe described m to"M a" contract In Sts Buyer, on trade. each person who signs blow as a'61Mlanfor gubantese Me Payment of re contract. This masm ml N the DtYer fah M pay any more, bed b owed m this agrew Sy M ft contr amours awed even 0 me gw rmr? win pay ft who asked. person who cash, pa? a" Nis Gum". He also signs baled taw lBwl he will be A" for SAM Me who Sign ft a lebb e aven R Uw r M M par, men h mere Of tm fow (a)glee la Sfryer mom mach b PAY Me or more Oe he Or M) b M) gives arelease le tut py pan to any of the otlWr ", on let ofs "0^. "0^. Each Guarerllor also claret Met that he has received a compged ropy Of INS contrastal( anmrob0 ` at e time song. ng Guarantor n Address (Awarder Address Users regsmmg the narprg , Scene, Or vlway, of shot dew . or amantaay or is : 3) Chains between you and I OMftR oor balleeds, Successions. y ewNN tit m urton ne abomhq Inch p u et' w(M tlwedeaaber, or emlb h releUrgtio hip »flh?Mlm?pe des for w s, Sir a" Omani Y U ANO A R TO Glut uP yW or wa c o e L9eTm. Own you and we agree ro wlw don following dghle: • RNGHT TO A TRIAL, WHETHER BY A JUDGE OR JURY • RIGHT TO PARTICIPATE AS A CLASS REPPAWNTATTYE OR A CUSS MEMBER IN ANY CUSS CLAIM YOU MAY AGAINST US WPEMER M COURT OR E ARBRMTWN • BROAD INGHTB TO DISCOVERY AS ARE AVAN Am w E A LAWSUIT MWff OTHER RIAPPEAL. TTHA AREE AVAILABLE IN A LAWSUIT m.•...,, •....u... ,,. a,.••.,w. ,7NI LTJAL UNUi NMIHg11J I aceatledon blow and the Wtsr Pty for Wrl wbi agora. Te applicable ROO (yon •Ruin') may b xlaram ('AAXL g 140M770.71171, «wew.ahorg; WnWbwYw pwMw •ya•nri 1910•wmJ M Ford Motor Credit Company PO BOX 3076 COLUMBIA, MD 21045-6076 (800) 677-0730 BRADLEY A STUMP 15 S. BALTIMORE AVE. MT. HOLLY SPRINGS, PA 17065 NOTICE OF DEFAULT AND INTENT TO REPOSSESS This is your notice that you+re broken your contract. Date of Notice Account Number June 18, 2004 35345788 Description of Property Year Make Model 2003 FORD FOCUS Serial Number: 1FAFP34313Wd37781 Date of Contract Current Balance (Net to close and unpaid late charges) Se Osmber 17 2003 ill 14503.67 CURE DATE: June 28, 2004 Overdue Payment(s) Due Date Amount Due $ 241.28 Late Charges............ TOTAL AMOUNT NOW DUE ................... (Not including amounts that become due after the date of this notice) May 01, 2004 June 01. 2004 $ 306.26 $ 51.77 599.31 N you don't pay the TOTAL AMOUNT NOW DUE by the cure date, stated above, we plan to repossess the above described property. If we do, you'll have the following rights. RIGHT TO GET YOUR PROPERTY BACK: If default at the time of repossession exceeds 15 days, you can get your property back by paying the net unpaid balance plus costs of repossession. If detauft at the time of repossessions 15 days or less you can get your propeflyback by paging the net unpaid balance. Your balance now is stated above. If you do that before the property is sold, it will be yours. We91 have no further claim on it. Thia is called your right to "Redeem". Your property will not be sold until at least 15 days after we repossess h. You can get it back by paying the balance plus costs (it costs are allowed by law) any time before it's actually sold. The longer you wait, the more costs (including repairs) you may have to pay. p GHT TO MONEY LEFT %yER FROM SALE: When your property 1s so d, the sale price minus expenses (if expenses are allowed by law) will be deducted from your debt. If any money is left over, it must be paid to you within 45 days after the sale. If you don't get this money, you may have a right to sue for it, plus penalities under state few. In some areas, we return repossessed property to the dealer who sold the property. If we do that with yours, our agreement with your dealer says that the dealer is to sell it and pay you any money left over. I NSURANCE RIGHTS: f we repossess your property, all insurance should be cancelled. You have a right to get credit for all premium refunds. IAEMAINING DEBT: e safe price might not cover your debt and expenses allowed bylaw It that happens, you'll owe the difference to us or the dealer. It you want to know more about these matters, please call us FORD MOTOR CREDIT COMPANY Nepo?as or ?hlm o tance Ford a Moto WIT OUT NOTICE, it you kA To make hibe payments anTtime. YU Ford ARE REQUIRED TO MAKE ALL PAYMENTS ON TIME. FC11p9637 MAgeO CUSTOMEWCUSTOMER FILE Fwd Motor Credit Company PO BOX 3076 COLUMBIA MD 210456076 800 6770730 DATE: 2004-12-08 00426 BRADLEY A. STUMP 15 S. BALTIMORE AVE. MT. HOLLY SPRINGS PA 17065 STATEMENT OF SALE Account Number: 035345788 The following property has been sold. Year Make Model 2003 FORD FOCUS Balance owing on your contract Vehicle Identification Number: 1FAFP34313W337781 Deduct: Finance Charge Rebate Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any attomeys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Other: Deficiency** (1) $ 14,292.37 (3) $ 14 292.37 (5) $ 6 092.37 (9) $ 6843.77 (10) $ - - - - N/A Surplus* The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses 8 interest added to your account (debits). Surplus" or Deficiency** " If the sale resulted in a surplus, a refund for the difference will be mailed to you. If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional information call or write: Ford Motor Credit Company P.O. BOX 6508 MESA ARIZONA 85216-6508 (800) 732-2264 Mail deficiency payment to: Ford Motor Credit Company DEPT 194101 P.O. BOX 55000 DETROIT MI 48255-1941 (2) $ - 0.00 (4) $ 8,200.00 (6) $ 751,40 (7) $ 0.00 (8) $ _ 0.00 FFH4'I t900 DI M4 Previous editions may NOT be used. "•PRN"' Ford Motor Credit Company P.O. Box 3076 COLUMBIA, MD210456076 (800) 677-0730 SRADLEVA STUMP 15 S. BALTIMORE AVE. MT.HOLLYSPRINGS, PA 17065 Dateof Repoesesslon 09-01-2104 Date of Notice Date of Contract 09032004 09-17-2003 Account Number. 035345788 Buyer BRADLEY A. STUMP cobaryea DE SCRIPTION OF PROPERTY Year 2003 make FORD ?x New ? Used Vehicle Identification Number. 1FAFP34313W337781 Model FOCUS Body 4DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement ? PRIVATE SALE: We will sell the property described above at Q PUBLIC SALE: We will sell the property described above at public private sale sometime after 15 days from the Data of Notice sale to the highest bidder on the data below (o any adjournment shown above unless redeemed by you prior to such Sale. dab). The a" Mt b , raid as foerrae: Date of Sala Tine of Sale Place of SW 09117/2009 9::0 MANHEIM AUT AAUCTION 1190 LANCASTER RD MANHEIM PA 17545 You may mard the sale and bring bidders if you want. NOTICE OF REPOSSESSION The money that we get from the Sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) will reduce the amount you owe. If we get less money than you owe, you Will still Owe us the difference. If we get more money than you owe, you Will get the extra money, unless we must pay it to someone else. The property is presently stored at: BEN RECOVERY BEN RECOVERY BEN HOW TO GET YOUR PROPERTY BACKECOVERY To get your property back, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 14,227.56 Plus Costs: Repo Expenses $ 380,00 $ You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number above. Plus Late Charges $ 64.81 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 14.652.37 If you need more information about the sale call us at the (Plus eaparses incurred if default at the erne of repossession exceeded telephone number above, or write us at the address above . 15 days and less rebate received after the date of this ndke.) Your properly wont be add until 15 days after the date of this notice at If you want us to explain to you in writing how we have figured the EARLIEST. AfterMat you can $till get it back anytime before it's the amount that you owe us, you may call us at the telephone actually sad. number above, or write us at the address above and request a If you do, we'll haw no further clam on it But the longer you wait he written explanation. more costs (i"d"dkg f8?1E>'/dd may have to pay. It you haw any questions about this, please call see. We are sending this notice to the following people who have an interest in the property described above or who owe money under your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent With this notice. ? The property has been (or will be) returned W. (dealer/oigirel creditor) under our agreement with your dealmoriginal credits, the dealer/original creditor is to sell the property and pay you any rr" left over. If you awe money after the sale, you will Pay it to the dealmoriginal creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by contacting this office. Thereafter, the Personal prop" shell be disposed of accordingly. ? Creditor has assigned M its qualified intermediary (OI Exchange. LLC) its rights (but not its obllgeflo s) with respect to the $am of each val listed above PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the mhVAs odo errs, is no accurate for any reason, please contact us so that we can accurately report the vehicles mileage. INSURANCE RIGHTS; If you dwI want to get your property back. callthe insurance company or the dedelodginal creditor to make sum that any insurance has been canceled. You haw a right M get credit for all premium refunds. SHERI GEORGE FFN1 I IWI Jan 02 Pab ous eeuons may Nor be uses. CUSTOMER/CUSTOMER FILE PnnW In UI ?- ICI i o 'i"1 O c u ? i ro n . b fin vo iv < SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-03249 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS STUMP BRADLEY A R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT STUMP BRADLEY A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , STUMP BRADLEY A 15 S BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 MOVED OVER A YEAR AGO. NO FORWARDING ON FILE AT P Sheriff's Costs: Docketing 18.00 Service 5.18 Not Found 5.00 Surcharge 10.00 .00 38.18 T OFFICE. So , NOT FOUND , as to rH. Thomas Kline ff of Cumberland County 4AURICE & NEEDLEMAN 06/29/2005 Sworn and subscribed to before me this ?? day of A. D. Protlorlotary MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (21?) /6Y-/1?1 FORD MOTOR CREDIT COMPANY Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-3249 BRADLEY A STUMP Defendant(s). PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the attached Complaint originally filed with the Court on 06/27/2005. MAURICE & NEEDLEMAN, P.C. BY: THOMAS DO 'PL ESQ. Attorney for Plaintiff Date: January 26, 2006 DATED: SHERIFF'S RETURN - REGULAR CASE NO: 2005-03249 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS STUMP BRADLEY TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STUMP BRADLEY A the DEFENDANT , at 1428:00 HOURS, on the 2nd day of March 2006 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to BRADLEY A STUMP a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service .00 Postage .39 Surcharge 10.00 .00 28.39 Sworn and Subscribed to before me this /4 ? day of A. D . roth ary So Answers: R. Thomas Kline 03/02/2006 MAURICE & NEEDLEMAN /,... By: Depu y Sherif MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Plaintiff V. COMPANY BRADLEY A STUMP Defendant(s) TO THE PROTHONOTARY: CUMBERLAND COMMON PLE6 CASE NO. No answer having been filed in the above Civil Action, favor of Plaintiff, and against Defendant, BRADLEY A STUMP follows: Principal Amount $ 6839.59 Interest to Date $ 0.00 Costs $ 122.07 Attorneys Fees $ 0.00 TOTAL $ 6961.66 for Plaintiff enter Judgment in the amount as P.C. BY: THOMAS D Attorney for ESQ. MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 FORD MOTOR CREDIT COMPANY Plaintiff V. BRADLEY A STUMP Defendant(s) STATE OF NEW JERSEY COMMON CASE NO. SS. COUNTY OF SOMERSET THOMAS DOMINCZYK, ESQUIRE, being duly sworn deposes and says that she represents the Plaintiff in the above en Defendant, BRADLEY A STUMP, is over 18 years of age; the is unknown and to the best of Plaintiffs knowledge, information not in the military service of the United States, nor any State of Allies as defined in the Soldiers' and Sailors' Civil Relief Act of amendments thereto. A for Plaintiff COURT OF )rding to law, i case and that pation of Defendant belief, Defendant is tory thereof or its ) and the P.C. SWORN T SUBSCRIBED be a me th isa?y a lot t1 LY L. APEP RA .11 A NOTARY P BLIC OF NEW JERSEY My Commission Expires 11/01/2009 BY: THOMAS D Attorney for ESQ. March 24, 2006 Suite 935, One Penn Center Our File No. 310 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.665.1133 tax 215.563.8970 www.mnlawpc.com Donald S. Maurice Member NJ Bar Board Certl Creditors' Rights Law American Board of Certification VIA CERTIFIED & REGULAR MAIL BRADLEY A STUMP 747 BLOSERVILLE ROAD #2 NEWVILLE, PA 17241 Joann Needleman RE: FORD MOTOR CREDIT COMP Member PA 8 NJ Bar STUMP Thomas R. Domincxyk CUMBERLAND COUNTY COL Member NJ & PA Bar PLEAS, CASE NO. 05-3249 Dear BRADLEY A STUMP: ARTICLE NUMBER: 7155 5474 4100 2449 1489 ARTICLE ADDRESS TO: Bradley A. Stump 747 Bloserville Rd # 2 Newville PA 17241-9710 Thank you for your prompt attention to this `/?? E?PNPG03 _.._ ONORIGTERoUT ?Og1307 0 2y0 SGE a :, 8B1D FEES Postage per piece Certified Fee Return Receipt Fee $0.39 2.40 1.85 Total Postage & Fees: $4.84 Postmark Here , - i Enclosed please find a ten (10) day notice of default explanatory. This is being served upon you due to yt to Plaintiffs Complaint served upon you on 03/02/2, answer to Plaintiff's Complaint is filed with the Cou from the date of this notice, a default judgment may you. If you would like to discuss a resolution to this matter office at 908-575-0220 ex. 21. v. BRADLEY A COMMON hich is self- r failure to respond 6. Unless an within ten (10) days : entered against call our 7 ` 5y 1,? q? R?QVS m %V''% P 2 B4dg1? e?,n111'2Q?-g7?0 ?I r f, I it6TuRN i i t MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY Plaintiff V. BRADLEY A STUMP CUMBERLAND COMMON PLE) CASE NO. IMPORTANT NOTICE TO: BRADLEY A STUMP DA 747 BLOSERVILLE ROAD #2 NEWVILLE, PA 17241 YOU ARE IN DEFAULT BECAUSE YOU HAVE F ANSWER IN THIS CASE. UNLESS YOU TAKE ACTION V FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY AGAINST YOU WITHOUT A HEARING, AND YOU MAY TO DEFEND AND THEREBY LOSE PROPERTY OR OTHI RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWS DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, TELEPHONE THE FOLLOWING OFFICE TO FIND OUT A LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIA LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 for Plaintiff COURT OF March 24, 2006 ;D TO FILE AN HIN TEN (10) DAYS ;ENTERED SE YOUR RIGHTS IMPORTANT t AT ONCE. IF YOU i TO OR 'RE YOU CAN GET 8 MAN, P.C. THOMAS D OMINCZYK, ESQ Attorney fo Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 FORD MOTOR CREDIT COMPANY Plaintiff V. BRADLEY A STUMP Defendant(s) CUMBERLAND COMMON PLEA CASE NO. It is hereby certified that a written Notice of Intention to mailed on 03/24/2006 to Defendant, BRADLEY A STUMP, to be entered after the default occurred and at least ten (10) days filing of the Praecipe. A copy of said Notice dated 03/24/2006, a certified mailing to the Defendant and affidavits of service hereto. Attorneys for Plaintiff COURT OF the Praecipe was whom judgment is to the date of the of the receipt for are all attached P.C. BY: THOMAS D, Attorney for ESQ. MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 FORD MOTOR CREDIT COMPANY Plaintiff V. BRADLEY A STUMP Defendant(s) CUMBERLAND COMMON PLEE CASE NO. CERTIFICATION OF ADDRESSES It is hereby certified that the parties have the following Plaintiff: FORD MOTOR CREDIT COMPANY P.O. Box 6058 MESA AZ 85216 Defendant: BRADLEY A STUMP, 747 BLOSERVILLE ROAD #2, NEWVILLE, PA 17241 for Plaintiff COURT OF P.C. BY: THOMAS D Attorney for ESQ. MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 FORD MOTOR Plaintiff V. BRADLEY A STUMP Defendant(s) CUMBERLAND COMMON PLEE CASE NO. AFFIDAVIT OF MAIL SERVICE STATE OF NEW JERSEY COUNTY OF SOMERSET SS. THOMAS DOMINCZYK, ESQUIRE, being duly sworn ; deposes and says that she is an attorney at law and that on 03/24/: mailed a written Notice of Intention to File the Praecipe to Defen STUMP, at747 BLOSERVILLE ROAD #2, NEWVILLE, PA 1 article nos. 71555474410024491489. Copies of the receipts evide attached hereto. A copy of the signed green card evidencing receipt of saic hereto as well. for Plaintiff COURT OF )rding to law, 6(date) he/she t, BRADLEY A 1 by certified mail, ng said mailing are mailing is attached , P.C. Attorney for b S2K FRLYL, UBSCRIBED oL?? LGv APERA A N . RYPUBLIC OF NEW JERSEY My Commission Expires 11/01/2009 ESQ. C C 1? T? ( ? n ? O X r - O _ 1^ W 11 ? Ap i G MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 FORD MOTOR CREDIT COMPANY Plaintiff V. BRADLEY A STUMP Defendant(s) CUMBERLAND COMMON PLE7 CASE NO. () Notice is hereby given that a judgment in the abc been entered against you in the amount of $6961 () A copy of all documents filed with the within judgment is enclosed. n for Plaintiff COURT OF matter has on in support of the If you have any questions regarding this matter, please Name: THOMAS DOMINCZYK, Address: Suite 935, One Penn Center at 1617 J.F.K. Boulevard Philadelphia, PA 19103 Telephone No.: 215-789-7154 the filing party: Station (This Notice is given in accordance with Pa.R.C.P. §236) lip IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( ) Confessed Judgment ( ) Other FORD MOTOR CREDIT COMPANY File No. 05-2-349 - 312(9 vs. Amount Due 6961.66 Interest 5/31/2006 $442.88 11 Atty's Comm BRADLEY A STUMP Costs 7Y7 2tvsetvi TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below. does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but If it does, it is based on the appropriate original Proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue a writ of execution in the above matter to the Sheriff. of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) County, ANY AND ALL ACCOUNTS IN THE NAME OF THE ABOVE DEFENDANT SS# xxx-xx-6523 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff: ofcumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) -ANY AND ALL ACCOUNTS IN THE NAME OF THE ABOVE DEFENDANT SS# xxx-xx-6523 in the possession of Members 1 st FCU , I Lq ? 4 S ct Z' jyrr d(?c ! d (-q ?, t C41__? So p/l and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 0 (indicate) Index this writ against the gamishee(s) as a lis p7oann ainst real estate of the defendant(s) described in the attached exhibit. Date Signature: ---ice Print Name- edl ema,Esq Address: 935 One Penn Center, Philadelphia, Pa 19103 Attorney for: Plaintiff Telephone: 215 789 7154 Supreme Court ID No.: 74276 (over) E f r ?6 ? 9?, 1 ' 4 S Ci 1? ? o C ? r + (I ll?j Iii i? tv C o f? ? `'t {{mow^\y\\ - 1 w f c? ^' o I" l WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-3249 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From BRADLEY A. STUMP, 747 BLOSERVILLE RD. #2, NEWVILLE, PA 17241-9710 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1" FCU, 1 CARLISLE BARRACKS, #842, CARLISLE, PA 17013 - ANY AND ALL ACCOUNTS IN THE NAME OF THE ABOVE DEFENDANT SS# XXX-XX-6523 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6961.66 Interest 5/31/06 -- $442.88 Atty's Comm % Atty Paid $149.07 Plaintiff Paid Date: JUNE 27, 2007 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Supreme Court ID No. 74276 r /' 1 FORD MOTOR CREDIT COMPANY Plaintiff, V. BRADLEY A STUMP Defendant(s). MEMBERS 1sT FCU CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-3249 )4n6 was 7r INTERROGATORIES IN ATTACHMENT TO: MEMBERS 1sT FCU You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment against you. 1. At the time you were served with Plaintiffs writ of execution, or at any subsequent time, did you owe the defendant (SS# xxx-xx-6523) any money or were you liable to defendant on any negotiation or other written instrument, or did the defendant claim that you owe him/her any money or were liable to him/her for any reason? If your answer is in the affirmative, please advise the amount of money you owe the Defendant, or the amount you are liable to the Defendant. N V 2. At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? NO 3. At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? N 4. At the time you were served or any subsequent time, did you hold as fiduciary any property in which defendant had an interest? 5. At any time before or after you were served, did the defendant transfer or delivery any property to you or to any person or place pursuant to your direction or consent, and if so what was the consideration therefor? F40 6. At any time after you were served, did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? NO 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax or other accounts or deposits in which defendant has an interest? If the answer is in the affirmative, please advise the amount of defendant's interest thereto at the time of the service of the writ. I "U J nDLEMAN, ESQUIRE V35 rney for Plaintiff One Penn Center Philadelphia, PA 19103 215 789 7154 N C`? ?=", 1.?. ? CJ -r? ' - ?: ,rr; _ ,..? -°? _:. .' f:- .::? C.?3 °?.' MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (11J) /z59-/151 FORD MOTOR CREDIT COMPANY Plaintiff, V. BRADLEY A STUMP Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-3249 PRAECIPE TO DISSOLVE/WITHDRAW GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve/withdraw garnishment upon Member 1 s` FCU forthwith. Respectfully Submitted, MAURICE & NEEDLI eedleman, Esq. P.C. Date: July 23, 2007 00 LA i31 S b C"3 L-W MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 BY : Charlene Taylor Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 FORD MOTOR CREDIT COMPANY Plaintiff, V. BRADLEY A STUMP Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-3249 CERTIFICATE PREREQUISITE TO SERVICE OF SUPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Plaintiff, FORD MOTOR CREDIT COMPANY, certifies that: (1) a notice of intent to serve subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at lease (20) twenty days prop rot the date on which the subpoena is sought to be served; (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate; (3) no objection to the subpoena has been received; and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve subpoena. Date: December 27, 2007 November 13, 2007 Attorneys at Law Suite 935, One Penn Center 1517 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.665.1133 fax 215.563.8970 www.mnlowpc.com Donald S. Maurice Member NJ Bar Board Certified Creditors' Bights Law American Board of Certification Member PA & NJ Bar --- Joe" Ifeedlemcm Thomas R. Dominczyk Member NJ, NY & PA Bar (horlene A. Taylor Member PA lot BRADLEY A STUMP 747 BLOSERVILLE ROAD #2 NEWVILLE, PA 17241 RE: FORD MOTOR CREDIT COMPANY v. BRADLEY A STUMP CUMBERLAND COUNTY COURT OF COMMON PLEAS 05- 3249 ear r. STUMP: Enclosed please find Notice pursuant to Pa.R.C.P. §4009.24 advising you of Plaintiffs intention to serve subpoena upon Citifinancial. A copy of the subpoena is attached and which will have the Prothonotary's seal upon service to Citifinancial. Thank you for your attention to this matter. Very Truly Yours, NjAUr,I9V & NEEDLEMAN, P.C. Firm Esq. Enc. THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR New Jersey Office Maurice & Needleman, P.C. Suite 2007 5 Waller E. Foran Blvd. Flemington, NJ 08822 tel.908.237.4550 fax 908.231.4551 MAURICE & NEEDLEMAN, P.C. By: Joann Needleman, Esq. Identification No. 74276 BY : Charlene Taylor Identification No. 203920 Suite 935, One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7161 Attorney for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff, V. BRADLEY A STUMP Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-3249 NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff, FORD MOTOR CREDIT COMPANY, by and through its attorney, Joann Needleman, Esq., intends to serve a subpoena, identical to the one that is attached to this notice and which will be sealed by the Prothonotary. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: November 13, 2007 Respectfully Submitted, MAURICE & NEEDLEMAN, P.C. COMMONWEALTH OF PENNSYLVANIA W6 crt COUN'T'Y OF CUMBERLAND v File No, o s -3 2 q SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY RSUANT TO-RULE-400912 - TO: C? ?'nCsc ' (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: as C,r titres,- c r???fiw, s? - ,?- ccl e ?.?eti c??,??; S 5 3- s at ?Gc(,? ?tCG 6? h (1 C ` (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things- sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: IC PI O ,h e5v ADt c?.R n is C?fa TELEPHONE: ( SUPREME COURT ID # -7!56 ?4 -7 ATTORNEY FOR: 12 ry ck BY THE Civil Division Date D Seal of the C urt Deputy r-a t? G ? s p= r ;. +'~ r ? y r. Ford Motor Credit Company VS Bradley A. Stump Writ of Execution Docket No. 2005-3249 Civil Term Fl t D-,? C OF }-fE ' ARY 229 SEP 25 in: 2 '- R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. No action has been taken in the last six months. Sheriff's Costs: Docketing $18.00 Surcharge 30.00 Garnishee 9.00 Levy 20.00 Mileage 4.80 Prothonotary 2.50 Poundage 1.69 $85.99 ? (?" q P cloy So Answers: R. Thomas Kline, Sheriff BY Serge t 0-0 C sv ? 7a ?? 2 3/dq?