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Home My WebLink About05-3350ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED 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 Defendant(s). izsv- /IDI FORD MOTOR CREDIT COMPANY 1335 S. Clearview Avenue Mesa, AZ 85216 Plaintiff, V. ANTHONY R SNOW 17 Railroad Ave #E Shiremanstown, Pa 17011 TORY M SNOW 17 Railroad Ave #E Shiremanstown, Pa 17011 CIVIL ACTION COMPLAINT AVISO NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. L) 5- 3.35"6 nwi( t Le ban demandado a tested en la cone. Si tested quiere defenderse de estas demandas expuestas en has paginas siguientes, usted tiene veinte (20) dial de plazo at partir de Is fecha de Is demands y la notificacion. Face falta asentar um comparencia escrita o en persona o can on abogado y entregar a Is cone en forma escrita sus defensas o sus objeciones a las demandas en contra de so persona. Sea avisado que si usted no se defiende, la conic ton-am medidas y puede continuar la demanda en contra says sin previo aviso o notificacion. Adernas, la cone puede decidir a favor del demandante y requiere qua usted cumpla con todas las provisions de esta demands. Usted puede perder dinero o sus propiedades u ones derechos importantes pars tested. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION 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 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 1335 S. Clearview Avenue Mesa, AZ 85216 Plaintiff, V. ANTHONY R SNOW 17 Railroad Ave #E Shiremanstown, Pa 17011 TORY M SNOW 17 Railroad Ave #E Shiremanstown, Pa 17011 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. DS - .33Sb e t u LC?F CIVIL ACTION COMPLAINT 1. Plaintiff, Ford Motor Credit Company, is a Corporation with its place of business at 1335 S. Clearview Avenue Mesa, AZ 85216. 2. Defendant, Anthony R Snow, is an individual who resides at 17 Railroad Ave #E Shiremanstown, Pa 17011. 3. Defendant, Tory M Snow, is an individual who resides at 17 Railroad Ave #E Shiremanstown, Pa 17011. 4. 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(s), hereinafter more fully described. 5. On or about 8/11/2003, the Defendant(s) 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 17,149.04 at an annual percentage rate of 13.80%, in order to purchase a certain motor vehicle, 2004 KIA OPTIMA more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A. 6. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $399.36 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 7. Defendant(s) made monthly payments until 7/30/2004, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 8. As a result of the default by Defendant(s), and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant(s) giving the Defendant(s) the opportunity to redeem the Vehicle as well as notice of the sale date. A copy of the notice of repossession and notice of sale date are attached and marked as Exhibit B. 9. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at auction with a credit given to the Defendant in the amount of $6,300.00. 10. After providing the aforesaid credit, a balance of $11,212.36 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. 11. 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 $9,840.99. 13. The total amount due and owing at the time of the filing of this complaint is $9,840.99. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $9840.99, well as any additional costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully submitted, MA & NEEDLEMAN, P.C. THO S R. DOMINCZYK, ESQUIRE Attorney for Plaintiff VERIFICATION I, THOMAS R. 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 unsworn falsification to authorities. BY: ARE DATED: G (vL V PENNSYLVANIA PIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE Buyer (and Cc Buyer) Nacre and Address (Inducting County and Zip Cade) CREDITOR (Seller Name am Address) AUG 14 P ANTHONY R SNOW TORY M SNOW MCCAFFERTY KIA 23 POPLAR ST 6302 CARLISLE PIKE \ WORM YS URG A 7 LJ red, Me Manor (end Co6unr, If wH, mw our ter wnNN Meenbee Mlav Wmen or on rnpn. 1M'C.an PMa' snwm relent I. me ITN mi. a as wn1eY. lid 'TmN 9ele Mce' eMntn rebw b me crpW Pnn. By.lpnl?a W. mnlrxt. You claws to Wy on crgl uMSr Me prNmenY on tlwfipll end recd oltnle ceMM. ?y Petarel OAgeuAaM )M commBn,Tl luau FUNU Ywrnwmuns Goeo n - Amwn YOU MAY OBTAIN VEHICLE INSURANCI ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE. 1. Cash Pdce ............. _........................................ ,.... $ 17374 On (1) . . ...... . . YOU ARE NOT REQUIRED TO OBTAI . .......... .... . .. ... CREDIT LIFE. CREDIT DISABILITY ANI 2. Down Payment OTHER OPTIONAL INSURANCE. THII Third Parry RebMe Assigned to Creditor ............................. $ I SINE On CONTRACT WILL NOT INCLUDE THEO Cash Down Payment.._ .............................................................. $ I OnO III) UNLESS YOU SIGN AND AGREE TO PA' Trade-in 1988- FORD $ 50.00 $ N/A $ 50 On THE PREMIUM. Ywanuou sewnwnm mcvm owe THIS CONTRACT DOES NOT INCLUDE Total Down Payment ...................................................................... $ 25511 nn (2) LIABILITY INSURANCE COVERAGE FOI 3. Unpaid Balance of Cash Pdce (1 minus 2) ............................... _._ $ 14774 nn I3) 4. Amounts paid on your behalf (Seller may be rebistnp a portion M these amounb) BODILY INJURY AND PROPERT DAMAGE CAUSED TO OTHERS. To I...moce companies far $ MIA Credit Life Imwance (far term of contract) ..._........... _._... NIA Credut Disability Insurance (for fern d contract)............. $ MIA N/A ITnmN/d_eeonta(EanmamH$ To Public Officials (i) for license (T 1 n nn ), tine it 72 50 ), b ? Credit LNe N/A regbirenm 1E-_35..00) tees AS So Insurer (it) for flung lees E 5 nn ; $ N/A Cash Prins) E 1077 54 $ 17106 04 (iii Premium Insureds) To Au XXXXXXXXXXXXX SAP $ 3571 00 1;519 To FASY CARF tNNFC-RNTn $ 835.00 Signature To NCLAFFFRTY KIA torOOC FEE E 55.011/01111 NE$ 94 00 To N/A forN/A$ N/A Credit Total ..._ .............. _..........._ _ .............._ ...................... _ ....... 2375.04 (4) ?Dlsabllity, N/A S. Amount Financed 3 Plus 4 ...................._._... . $ 17149.04 (EI Insurer FEDERAL TRUTH-IN-LENDING DISCLOSURES Premium Insured ANNUAL FINANCE CHARGE Amount Total of Total Sale Signature PERCENTAGE Finenged Payments price RATE TM Golly mlloYm Tre imdMt M TM emout TIa IOW Wet TM msl n your weds as a o eI f w rata uw seen win oon doer medic prmbetl lO rw or w your yes:g have psis vaen yes of your w hh W cram. ? N/A N/A y baton here made all Mmmw your Other Optional Insurance Term ecnetluletl rments N/A $ N/A 13.80 X E 68]2.56 $ 17199.04 E 23 $26511.60 Insurer Premium Number of Amount of Each When Payments Signature, Payment Schedule %(] Payments Payment ero Are 9 36 Careen LW .w Credh DWWI ... wo I h f . Your payment scledu e _51- $ 39 rrloNhryBlMnrhg) m t e tnm o the w tam, woman am TM ad be: I nml $ 399.36 09/2/2003 gir°ne ew you tiw? M e wnw m esraament rymmt It you pay on your debt early, you eMl not nave to pay a parWry. Payment You mot pry a His crarga w des pmim of each Mymenl received come 10 days late. Tree charge b 2 (Intern d the lab amount w 550.00 a1hlcme"a Is boa. dry Mbreat Yw w giving a woudty inteeeat h Ire whiele belrq purohmed. set: Plows aw this compact bar additional lnbmation on security forward, nonpayment n the none b moubs repayment of put door m NI before the schodu ed dab, end Ym cot penalty. K sm men your morbwt oNlgenone, yes may lure ft rehtde not yes me the" under the coned, m we in. and pestle put w Me w1Yce and money or good; lsnw for me reNde. NON-MODIFICATION DISCLOSURE Any MW M onto sundae mud rein emir, end gCgnnedObyy you we to CreMbr. &(iN3 - SIGNSER: YOU ACKNOWLE GE THAT YOU HAVE READ AND AGR TO BE BOUND BY THE ARBITRATION PROVISION ON THE REVERSE SIDE OF THIS CONTRACT. NOTICE TO BUYER DO not sign this contract In blank You are entitled to an exact copy of the contract you sign. Keep it to proteM your legal rights. Buyer an Co-BuyOr) SO noWledge that (1) before sl niinthis contract, Buyer an Co-Buyer) received an rd evlewed a true empbtely Ilsd in copy of this contract and (II) at the time of si nin this contract, Buyer (and Co-Buyer) race v a true an completely alyd7n Copy of this contract euyBR . m eu R s BMaonlna Mow, me seflw eewpb mle corrtracL N no aMw Melpree b nanad M • aepwefe • Ig^'^RNCNPYIRTSVNSIPntnR Uhw uer.xlawn c7Z Cemparry. n w rnv.ai.wn Inwm,anme nor ae wwal SEE BACK FOR ADDITIONAL AGREEMENr6 You mum Inmre Me words, N e Marge b shown W. The C will by b DW tlls cmm,iieekASmin la, awd on the Moon v to. of Me vM of ms p M y. fan wt awn tam Me Wnlb o/ poky. 0 C'Monnewlre ? S N/A Deductible Owelon ? Fire Theft m lure Addtlolal Corerpe ? TMriN O Tmn N/A Monde (Eternally) Premium a Program No. QUESTIONS? OR PLEASE CALL US AT 1-80( TM-7000 or Visit us at wwar.tordwedit.com m-0Ot ORIONAL ADD1190NAL AGREEMENTS lent male AS F. D"ft You WM be M dente E dmb piname of t 0 ? f" pd M-PDM Warr EN eleduNd dMN « sees Ben Be s&a&M amount. The Cmdb WIN apply For payment, *9 to the earned and upend P?eaten MS C pW den b M Mature Famcm. The Cheaper Chop by ofal Me, Annual P,ICMY,p, Ran to the arms" Amoea ter Be a" Bens tle Imtpeld Amount FMMtcad in VASW* p.,B.pppe = e mporaNd you will not haw a light b mWoWa'tle bOniw uname the Creditor 9. Security Inbn L You of" the Cremes a maturity biervit In: I. The wNde am am pen or other goods par m Me Vehicle; 2. A8 money or geode resolved for Not whites; aid 8. NI Insurance eemapa are samba contracts around for you. TWA aware, payment of all emoar you owe in this coref?cl. A Am amass your other agmarMMS In this "not. , C. the of Vmtoe - WARRARRES: You mail take tam of t A. You may not "had the ethics, and you mum asp it Me from the Claim ai bdismt You tll not um or perms this use of the "*Is WWWO obMa lasted SIMS, wwxfpl for up ro 30 days in Canada of Mexlbo, WNW the prim written Content or the Creditor. RIM vehick Is «. yve rbmraly tined for pointed use and the Creditor, or Be vebieb's mmuMMwra, exenC, a wrMm warranty or data of Me t ral, you oM Implied wmmnUn at marchmdatel ty and Upeae for a particular purpose coved the "h[CW dMMlse, you understand and seg. Mat Merl M• M loo Implied warranties. 0. commerce: You mml ksura yourself and the Creditor against lose or damage to are vehble. The Creditor mud appmvy, she pore and mount of cwnMroe. If the Creditor Claims a rehint on gammas m serAw contracts, the OnrfA« sea stun" to asAmd from owl you sew. Whether or not tin voldle Is measured, you met ay for it M it Is Ind. damoded. or deelroyed. - e a charge tot while Issuance Qe, Is shown on Me`fronl.' IM shown. The hOedit r try buy We, that ,a ? do checked I he menM w II Own cowry, min more Men Me amount down for hourmn, hie Qsdtor may buy them for a mortar tam or he may gist you aYam for se amount shown. U he cannot buy my Insurance, he Y,B gin you ,slit for Me ,moan shown. The Credit we be male b M YM WYnenta rile. E. Laos C1wfa: You will have to pay a late wage on Me portion of each payment mob win; Man Ian days We. The Charge Is shown on Me front. Ameptenm of a late path" does . not exoum your dereult or mean drat wu Can kdep mailing payments, after May ore due. The Creditor may take Me steps pat bin In lies comraa. It Mere b my thrown. 1. You do nal made a payment whm it is du8l « ' AW, x. You good lace or naW Wy a a m atlbn enfflW;D .M ,pPYaearm rN.DrD qmb mmrwI or 9. Your whams b by airy iaCel, aIM0. « nl,j rity, ed to yo he ; or P PBy end mcon w. You III* a baraotpay pMltlen «ana Is Bed against Yang or d. You do nil keep My at hear PM*o In sae omdnal H yen Ms In deem, Ms Cn lW m2y nnqqum yen b payM «be Me urpaltl Amouft Be p4and upMd pm of the Panama Charge hid i1 abler mauls due enter this cants Hp Y recce,, (hike brag Me whNs. boo. Me Army all aide Bootle bold M ar`en•Me whams when npoNeaeW arid hold them for you. It the vehicle is token book he win NW you a notice, The house Me fey Met You MSY M&M rely hoop to Vehicle. A WIN Wo slaw to amcuM needed to redeem. You may rodsem Be whole up to do Mpa the Cre mgr sea e or agrees to ad k. a You ed not edam the whale, it WIN be sold. The Creah« WIN we Me. ngrej' from the sale, hies me allowed expwse, b pwy Me ,moll 800 owed on ma, Contrast- Eastman geld a e drool raeuN of"b Intake me whtoN, hold h for eau, and @01 a an, as perMAW by law, allowed expenses. Lawyers' lea min legal Conte pamattad by tow are allowed, too. The Creditor will pay you my money all (a surplus). You win pay my money sea owing after It sla to the Creditor. N you do not pay ft menot o who the Creditor of% see Cmdlor may charge you IrMest M the highest lowha rata unit You pay. 0. Consumer Roporre: You auderaza Ford Motor Credit Cam- parry b obtain Cmeumer made reports hen Consumer as agenda (Crede burew) for any reason and at any Uwe In em- recUon with We comsat: H: General: To commit Fad Moor Credit Cantpeny about Mb acmW, Cep 14011.727-7000. Alm, you may mine "*an and omM seloma merges M www.ronoredl.oom. The tow of Pam Wavams applka b mks Contract. N am law does not allow a of the agreements In Oda centred. Mews MM ere not slowed we M veld. The red of tlae contract 008 sit be good. NOTICE - ANY MOLDER 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 THE DEBTOR HEREUNDER. Used Moor Vehicle Buyers Gu e. U you are buybq a used wide with this oonbscL federal regulations may ramhe a spade! Buys. Guide W M deployed on the window ode whrore. THE INFORMATION YOU SEE ON THE WINDOW FORM FOR THIS VEHICLE IS PART OF To cause Me 9Mbr b sa Me paymeda tDed m me hurl d Ihb aoM sew ls o y, my paean who we below es w boSfpeor go tae payment of this canted. when mew tlW V U the Buyer yer falls to pay wry money get M o owed on ode mmxtl'mrs ons ne who $ in othinness will pay it when aced. Each uperson w ego below en that he a M Yams for to wove ,room owed ~ even N mN or coons other persons ado tore this n Guaranty. H Hs ado agrees to b be alb awn If N Me Creditor dam ens more of u IV,or(w) more yvm On se er etas We to ay one, or psyments, M heo In Pon to my it Ma mw Guam nw Wm(C) massive any na' seanriry. Each Guarantor also atatam Met Mat he has mcaNW wCorniPleaW Copyotlob Commit And this (hiremy M the tlma of wooing. A 6ouenror Atldesv er care wr made w, for dodo In Who do YOU AND 2, Mraw -? you a em v a U . Ben you and we agra b want Ma beoWMB mints: • RIGHT TO A TFAA WHETHER BY A JUDGE OR JURY • RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR A OLASS MEMBER N ANY CLASS CLAIM YOU MAY Ha AGAINST US WHETHER N COURT ON N ARBITRATION DISCOVER • BROAD TOO APPPErUO. THE OEfXBgNY OFAN Ail TOR A lAW81M • OTHER MGNM THAT ARE AVARABLE N A LAWSNT RIOT You hid We Oo Not.GM Ilr N a CWm A UMMU4 You And M WIN m ftl b house the blomnp wmdd Welsly' arelemen pasWRm tl M arty ra,m: 1) 1BMSIX?bmB?e M m«k 2) IV* b Oft" 1M security In whoa eel r exdeeded its ?n b samM the araw sees daoMon; W Q Right b rectal as d?OmM nY1,M M r MpRralc how, Eater Pry rose cartlaG My wesWNW Maw herd the OUrsr Party No Marl arbiwllon. The applicable palm (the -Rulesq may obtained Ram IN aeeodatlm. • American Albllmatbn AMoolOw CAM-L M 14G07784117). or W WwadrArg: - Wt-Mb m wwswwwww vs Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 210456076 8006770730 DATE: 2004-11-18 00089 ANTHONY R. SNOW 17 RAILROAD AVE #E SHIREMANSTOWN PA 17011 TORY M. SNOW 17 RAILROAD AVE #E SHIREMANSTOWN PA 17011 STATEMENT OF SALE Account Number: 035066599 The following property has been sold. Year Make Model 2004 KIA OPTIMA Balance owing on your contract 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 attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Other: Deficiency" (1) $ 16,980.86 (3) $ 16 980.86 (5) $ 10 680.86 (9) $ 11212.36 Surplus' (10) $ WA - The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & 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 Vehicle Identification Number: KNAGD126X45258350 (2) $ 0.00 (4) $ 6,300.00 (6) $ 531.50 (7) $ 0.00 (8) $ 0.00 Mail deficiency payment to: Ford Motor Credit Company DEPT 194101 P.O. BOX 55000 DETROIT MI 48255.1941 FFNA11990 01N Pre Ous editions may NOT be used. ford Motor Credit Company PO BOX 3076 COLUMBIA MD 210456076 8006770730 DATE: 2004-11-18 00090 TORY M. SNOW 17 RAILROAD AVE #E SHIREMANSTOWN PA 17011 ANTHONY R. SNOW 17 RAILROAD AVE #E SHIREMANSTOWN PA 17011 STATEMENT OF SALE Account Number: 035066599 The following property has been sold. Year Make Model 2004 KIA OPTIMA Balance owing on your contract 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) $ 16,980.86 (3) $ 16,980.86 (5) $ 10 680.86 (9) $ 11212.36 Surplus* (10) $ N/A The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & 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 Vehicle Identification Number: KNAGD126X45258350 (2) $ 0.00 (4) $ 6,300.00 (6) $ 531.50 (7) $ 0.00 (8) $ 0.00 Mail deficiency payment to: Ford Motor Credit Company DEPT 194101 P.O. BOX 55000 DETROIT MI 48255-1941 FFNA11980 01/04lRwous a Jihons may NOT b use . -PRN- Ford Mob Credit Company P.O. Bar 3076 COLUMBIA, MD 21045-6076 (800) 677-0730 ANTHONY R. SNOW 17 RAILROAD AVE eE SHIREMANSTOWN, PA 17011 Date of Repossession 09-29-2004 Dale of Notice Date of Contract 0930-2004 08-11-2003 Account Number. 035066599 Buyer ANTHONY R. SNOW Cobuyer TORY M. SNOW DE SCRIPTION OF PROPERTY Year 2004 Make KIA ?* New ? Used Vehicle Identification Number, KNAGD126X45258350 Model OPTIMA Body NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement. xj PRIVATE SALE: We will sell the property described above 9 pdvete sale sanetime after 15 days from the Date of Notice shown above unless redeemed by you prior to such sale. 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. ? PUBLIC SALE: We will sell the property described above at public sale to the highest bidder on the data below (or any adjournment date). The sale will be held as follows: Data of Sale Time of Sele Place of Sale You may attend the sale and bring bidders it you want NOTICE OF REPOSSESSION 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. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may Call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money unclE 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 is presently stored at: ASSET RECOVERY LEMOYNE PA HOW TO GET YOUR PROPERTY BACK To gel your property back, pay us this amount by certified check or money order before the vehicle is sold. Unpaid Balance $ 16191 Plus Costs: Repo Expenses $ 346,00 Plus Late Charges $ 44.31 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 17,320.86 (Plus expenses incurred if default at the time of repossession exceeded 15 days and less rebate received alter the date of this notice.) Your property won't be sold until 15 days after the data of this notice 9 the EARLIEST. After that you can still get it back anytime before its actually sold. If you do, "it have no further clam on h. But the longs you wait the more costs (Including repairs) you may haw to pay. If you have any questions about this, please call us. ? The property has been (orwill be) returned to: (deadmorigina creditor) Under our agreement with your dealmorlginal creditor, the deals Wginal creditor is to sell the property and pay you any money left over. If you owe rnorrey after the sale, you wit pay it to the desemoriginal 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 persona property shall be disposed of accordingly. ? Cretlttor has assigned to its qualified IMermedlay lot Exchange, LLC) its rights (but rot its obligations) wt51 respect to the sale of each vehicle listed above PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are awars that the mileage reflected or the vehicles odo arter is not accurate forany reason, please contact us so that we can accurately report the vehicles mileage. INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealer/original creditor to make aura that any insurance has been canceled. You haws a right to get credit for all premium refunds. A M. PAPARAZZO Fee 1 isesal Jan W Pe our selrwns may Nonroeuvan, CUSTOMEMCUSTOMER FILE annul In U SA. -PRN"a Ford Motor Credit Company P.O. Box 3076 COLUMBIA, MD21045-6076 (800) 677-0730 TORY M. SNOW 17 RAILROAD AVE pE SHIREMANSTOWN, PA 17011 Date of Repossession 09-29-2004 Date of Notice Date of Contract 09-30-2004 0&11-2003 Account Number: 035066599 Buyer ANTHONY R. SNOW Cobuys, TORY M. SNOW DESCRIPTION OF PROPERTY Year Make 2004 KIA (] New ? Used Vehicle Idem6flcation Number: KNAGD126x45258350 Model OPTIMA Body NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreement x1 PRIVATE SALE: W e will sell the properly described above al private sale sometime after 15 days from the Dale of Notice sham above unless redeemed by you prior to such sale. ? PUBLIC SALE: W e will sell the properly described above al public sale to the highest bidder on the data below (or any adjournment date). The sale will be hold as follows: Date of Sale Tian of Sale Race of Sale You may Wendt the sale and bring bidders if you want NOTICE OF REPOSSESSION SSET RECOVERY LEMOYNE The property is presently stored at: PA The money that we get from the sale (after paying our costs, HOW TO GET YOUR PROPERTY BACK including reasonable attorney's fees and legal expenses if To gat your property back, pay as this amount by cedl8ed check or permitted by law) will reduce the amount you owe. If we get mormy order before the vehicle is sold. less money than you owe, you will still owe us the difference. If Unpaid Balance $ 18,938.55 we get more money than you owe, you Will get the extra money, Plus costs: Repo Expenses $ 340.00 unless We must pay it to semeene else. $ 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. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money unde 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. Plus Late Charges $ 4431 Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 17,320.86 (Plus expenses Incurred if default A the time of repossession exceeded 15 days and less rebate received after the data of this null Your property won't be sold until 15 days after the dale of this notice at the EARLIEST. After that you can Will gel h back anytime before its actually sold. If you do, we'll have no further claim on it But the longer you wait, the more costs (Including repairs) you may have to pay. If you have any questions about this, please call us. ? The property has been (or will be) returned to. (die edaiginal creditor) Under our agreement with your dealmoiiginal creditor, the dealer/original creditor is to salt the property and pay you any money left over. If you owe money alter the sale, you will pay it to the dealer/original creditor. ? PERSONAL PROPERTY: Any personal properly found in the vehicle nay W reclaimed by you within the nerd 60 days a, in acccrdarroe with state low, by contacting this office. Thereafter, the personal property shall be disposed of accordingly. ? Creditor has assigned to Its qualified Intermediary (OI Exchange, LLC) Is rights (but not Its obligatlms) with respect to the a" of inch vehicle listed above PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware Mat the mileage raflecbd m the vehicles odometer is not accurale far any reason, please contact us so that we can accurately report the vehicle's mileage. INSURANCE RIGHTS: If you dorl want to 90 your property back, call the Insurance company or the dealer/original cradkor to make sure that any insurance has been cancelled. You have a right to get credit for all premium refunds. A M. PAPARAZZO FFN4l rmear Jan 02 F,e sous a4eNne may Norm used. CUSTOMEWCUSTOMER FILE PdnW In USA. a v? T ?? ? w vm _ae t'rn G SHERIFF'S RETURN - REGULAR CASE NO: 2005-03350 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS SNOW ANTHONY R KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SNOW ANTHONY R the DEFENDANT , at 1648:00 HOURS, on the 6th day of July , 2005 at 17 RAILROAD AVE #E SHIREMANSTOWN, PA 17011 TORY SNOW, WIFE by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.20 Postage .37 Surcharge 10.00 .00 39.57 So Answers: R. Thomas Kline 07/07/2005 MAURICE & NEED EMAN Sworn and Subscribed to before By: me this /?2 `= day of ?2ft A. D. TP othonotary ' SHERIFF'S RETURN - REGULAR CASE NO: 2005-03350 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS SNOW ANTHONY R ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SNOW TORY M the DEFENDANT , at 1648:00 HOURS, on the 6th day of July , 2005 at 17 RAILROAD AVE #E SHIREMANSTOWN, PA 17011 TORY SNOW by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this AZ day of ?va? A.D. / Prothonotary So Answers: y R. Thomas Kline 07/07/2005 MAURICE & NEEDLEMAN By: Curtis R. Long Prothonotary ®fffce of the i9rotbonotarp ?untberrartb ?ourttp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor -OS'- .335'6 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195