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Home My WebLink About05-5326ARBITRATION 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). /b7-/IDI FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, AZ 85216-6508 Plaintiff, V. RAYMOND A WILLOW 419 Bobcat Road Newville, Pa 17241-9724 K11\4BERLEY A WILLOW 419 Bobcat Road Newville, Pa 17241 CIVIL ACTION COMPLAINT AVISO NOTICE You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. aOOT 53Z Le ban demandado a used to Ia carte. Si usted quiere defenderse de estas deno n alas expuestas en las paginas siguientes, usted here veinte (20) dias de plazo at partir de to fecha de Is demanda y to notificacion. Hate falm asentar una comparencia escrita o en persona o can un abogado y entregar a Is cone en forma escroa sus defewas o sus objeciones a las dernandas en contra de so persona. Sea avisado que si rusted no se defiende, to come tumors medidas y puede continuer to chu anda en contra soya sin previo aviso o notificacion. Adernas, la corm, puede decidir a favor del de ns ndame y requiere qua usted cumpla con Codas ]as provisioner de esta denunda. Usted puede fender dinem o sus propiedades u corns derechos importantes parrs toted. 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 ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff FORD MOTOR CREDIT P.O. Box 6508 Mesa, AZ 85216-6508 Plaintiff, V. RAYMOND A WILLOW 419 Bobcat Road Newville, Pa 17241-9724 KIMBERLEY A WILLOW 419 Bobcat Road Newville, Pa 17241 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 0 5- s? 2 4 C11;j 17, CIVIL ACTION COMPLAINT 1. Plaintiff, Ford Motor Credit Company, is a Corporation with its place of business at P.O. Box 6508, Mesa, AZ 85216-6508. 2. Defendant, Raymond A Willow, is an individual who resides at 419 Bobcat Road Newville, Pa 17241-9724. 3. Defendant, Kimberley A Willow, is an individual who resides at 419 Bobcat Road Newville, Pa 17241. 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 3/17/2003, 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 13336.24 at an annual percentage rate of 12.50%, in order to purchase a certain motor vehicle, 2001 Ford Taurus 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 $301.57 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 1/10/2005, 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 4200.00. 10. After providing the aforesaid credit, a balance of $6793.21 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 $6793.21. 12. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to 504.84 and which will continue to accrue. 13. The total amount due and owing at the time of the filing of this complaint is $7298.05 WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $7298.05, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. submitted, i NEEDLEMAN, P.C. THOMAS 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 unswom falsification to authorities. BY: JIBE DATED: 10 r6? 0?' PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL Ih -MENT CONTRACT DATE e" , v Buyer (and CoBuyer) Name and Address (including County and Zip Code) CflEDROR (Seem Name eM Address) 1`s?? FORD INC. J RAYMOND A. WILLOW KIMBERLY A WILLOW MAGUIRE'S \paT RR4 BOX 71 RR4 BOX 71 SOUTH MAIN ST. P.O. BOX 39 NEWPORT PA 17074 NEWPORT PA 17074 DUXtANNON. PA 17020-0039 MAR 1 9 7003 Yee, moeeywcosC BU , Mann may Puyaewhkla baosWd Mow ten uvlr arse cross. iN'CrhPia'anowmm Wwx kma aeM Pau W1M wldcla. no "TOta19W Rke• sMwn babe le ma [rMk pdu. ay aMmrrp ma aubapl. you cM1OOas to arrY u craat umMr ma apwrrerma on tlw haul aos Mss W me eslnet. NewNaad Year and Metre Model am X Tos* Its. voted.) iKa - feuleer UY For Mich Riolei ? Penonel ? AprkulwN USED IFAFP55U61A288526 m Cammerdm INSURANCE Tras41"- $ TAO. nn S /A SUR NCE VE C t Ow errd sae AM.. Amount I. Gone YOU MAY OBTAIN HI LE IN A ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE. 13999.00 YOU ARE NOT REQUIRED TO OBTAIN f. Ceara Pnce ............................ _.............................................................. $ (f) CREDIT LIFE, CREDIT DISABILITY AND 2. Down Payment OTHER OP77ONAL INSURANCE THIS Third Parry Rebate Assigned to Creditor ............... ..... _._... $ X/A CONTRACT WILL NOT INCLUDE THEM Cash Dow9fgyffffa ................................ ..... ._........... ....N./A $ UNLESS YOU SIGN AND AGREE TO PAY Trade-In $3000.00 $ $ THE PREMIUM. rwwew 6-..r..n ^ "beiv 3000 . 00 THIS CONTRACT DOES HOT INCLUDE Total Down Payment ........................... ..................................... S 0999.00 (2) $ 1 i i 3 LIABILITY INSURANCE COVERAGE FOR 3. Unpaid Balance of Cash Pr ce (1 M nus 2) ........................_.......... ( ) BODILY INJURY AND PROPERTY 6. Amounts paid on your behalf (Seller may be raHinirg a portion of thee. amounts) DAMAGE CAUSED TO OTHERS. To insurance Companies for N/A $ Credit LNe insurance (for tens of contract) ........................ X/A Credit Dlsabilm Insurance (far tens of contract) y ........... (Term -Months (F St . Ir. . e . H$ N/A To Public Officials (i) for license (8-_2FL• Q,OMM ($ 22. SQ a regslradm ($. Gff." t 53.50 (if for filing fees s N/A (if!) for razes (not in Cash Price) $ 748.74 $ 802.24 To for Messenger service ..._.......... . $ N/A To c_rORB for SFRVICF CONTRACT $ 1450.00 To-4%Q9Ar&L FMfot-40CUREXTATMIL-? g 55.00 To far $ N/A Total .................................................................................................... E 2337.24(4) 5. Amount financed (3 Plus d) ........................... _..._...._..._.....__....... $ 13336.24(s) FEDERAL TRUTH-IN-LENDING DISCLOSURES ANNUAL FINANCE Amount Total of Total Sale PERCENTAGE CHARGE Financed Payments Price RATE Tlo darer amount The emoum a no amount The tow um The cost of your ae credos veil cedit provided to you At hays of your purchase on credit as a yeedy rate cast you you or on your paid amen you credos, trepan have made ate In luWg your ro smosulos be 12.50 % $ 4757.9 1 13336.24 $ 109T.2 y $ wnaAyr 21094.20 Number of Amount of Each When Payments ? Credit Life - Insurer $ N/A Premium Insured(s) Signature Credit ? Disability Insurer $ N/A Premium Insured Signature ? Type of Insurance Term $ N/I Insurer Premium na tare Payment Schedule ? Payments P nt me due U 60 57 Cross tdls nos Cross Maeblllp inauranee en r $ 3 1 Your payment schedule IngnmlvsMNng) 03 ' hea tMarrashmwvnin a?rlmWa e9namearftn l will be: 1 final $?/? UI11AT today. =9 , You must Insure the wholes M a charge Is shown below, the Creditar win by to buy tM eewragum bMCkad for the tarts shoom. Coverspn will be boost on the cash weds of f l h t i b h the ve me o icle a t oss, ut ram more t an the limits of tM Perry. Conmishenmwe ? $ M/oWUCI1Ne Prepayment M you pay off your debt early. You will not haw to pay a penalty. Collision lat. Payment: You must pay a late charge on Me portion of each payment recoved cope than 10 days let, The charge is 2 percent of the late amount or $50.00 whichever is lea. El FMB n8ftCombineo Adsiticnal C vwage Saeudty Interest, You are giving a security Interest in me vehicle being purchased. ? ToWng and tabor Cc t : Please we the conhad for additterel blo tromi on severity interest, nonpayment an: Wl me ri ht to re ent r d t i f bt i fail b th h d l d d t r p Term Marais (ESllmee) 7 , g qu on re epaym o you e a e sc u e a e. antl n e . prepayment Penalty Premium $ CONW£ L yEl ES: Tree doge shown In Ne above boa KK lee paymenk epp5s where Ne vetede QUESTIONS? eumhassd has a prose val,culs, w"M of loam man 15,000 pounds. II the m ie you purmued has a Mes vmkulerwaight W 13A00 course armors, you mud per a late merge on me comer of each payment recdved more Nan 10 days late. The charge Is 4 paned of tie lee secure or $60, wlechwar a less. If you do not meet yver ouri and otogamons, yu may toes tee wince, out you are fire" under the wntmd, F d as well Me both parts and goods put on Me whitle ant money or goods rarefied for the vehicle. or NON-MODIFICATION DL4CLOSURE Any image I mrad meet bent war asp "stilyO by you and m lCoblor. .. _ i ... _ NOTICE TO BUYER l N Do not sign this contract In blank. You are entitled to an exact copy of the contract you sign. KeepA.q protect pO?r 1 hts. PLEASE CALL US AT 1-WO-727.7000 ...U ?l//? copy cAasai v - '°? ORIGINAL rc +fineDd os Imrwbua wwu n.Y wov e. wd1 SEE awCNI ADDFMNAL AGREEMEN -PRN"" Ford Motor Credit Company P.O. Box 3076 COLUMBIA, M021045.6076 (800) 677-0730 RAYMOND A. WILLOW RR 2 BOX 144 B NEWPORT, PA 170T4 Dateof Repossession 01-10.2005 Date of Notice Data of contract 01-12-2005 0317-2003 Account Number: 034184509 Bu RAYMOND A. WILLOW Cobuys, KIMBERLEY A. WILLOW DESCRIPTION OF PROPERTY Year Make 2001 FORD ? New Q Used Vehicle Identification Number: 1FAFP55UBW88526 Model TAURS Body 4DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your prop" described above because you broke promises in our agreement. Q PRIVATE SALE: We will sell the propertydescribed abowal private sale admit. after 15 days from the Dale of Notice Shown above unless redeemed by you prig 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 al public sale to the highest bidder on the date below (a any adiOummard date). The Sale will be held ea fotaws: Debe of Sale Time of Sale Place of Sale You may attend the sale and bring bidders t 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 under your agreement: 1) The buyer and any cobuyer named above; 2) Any dealerforiginat 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: MANHEIM AUTO AUCTION MAA PA -- HOW TO GET YOUR PROPERTY BACK To gel your property back, pay us this amount by cedin®d check or money order before the vehicle is sold. Unpaid Balance $ 10,92828 Plus Costs: Repo Expenses $ 300.00 Plus Late Charges $ 18.09 Less Finance Charge Rebate $ Lass Insurance Premium Rebate $ TOTAL $ 11,306.35 (Plus ehmenses incurred if defauk at the time of repossession exceeded 15 days and less rebate recei after the dais of this notice.) Your propertyworl be sdtl until 15 days after the date of this notice at the EARLIEST. After that you can still gel it back any time before it's actually sold. If you do, we'll have no further claim on it. But the longer you wait, the morecosts (IrclAing repairs) you may have to pay. If you have any questions about this, please call us. ? The popery, has been (a wiU be) retwned to: (dealer/original creditor) Under our agreement with your dealedoiiginal creditor, the dealer/original creditor is to seI the property and pay you any money left over. If you owe money after Nov sale, you.11 pay t to the dealerlohigmal creditor ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the ned 60 days or , in accordance with state law, by contacting this office. Thereafter, the personal property shall be disposed of accordingly. Creditor has assigned to its qualified intermediary lot Exchange. LLC) its rights (but nor be obligations) with respect to the sale of each vehicle listed above. PAYMENTS: All payments to us must be by cared check or money order. MILEAGE DISCLOSURE If you are ewers lhelthe milepe retlecled or 1ha wMde's odometer is not accurate fa any reason, please contact us so that we can accurately report Me whlcles mileage. INSURANCE RIGHTS: If you dorl want to gel your propertyback, cat to insurance company or the dealer/original creditor to make Sure that any Insurance has been cancelled. You haw a right to get credit for all premium refunds. SHERI GEORGE Fv r lase sr eel os Prewls Wirer Mm NOTO uses. CUSTOMER/CUSTOMER FILE Pnnw in U.S.A. -PRN-- Fad Motor Credo Company P.O. Box 3076 COLUMBIA, MD 210456076 (800)6Tt-0730 KIMBERLEYA. WILLOW 234 MULBERRY ST NEW PORT, PA 17074 Dateof Repossession 01-10-2005 Date of Notice 01-12-2005 Date of Contract 03-17-2003 Account Number. 034184504 Buyer RAYMOND A. WILLOW Cabuyer KIMBERLEY A. WILLOW DESCRIPTION OF PROPERTY Year Make 2001 FORD ? Nev Q Used Vehicle Identification Number. 1FAFP55U61A288526 Model TAURS Body 4DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above bemuse you broke promises in our agreement. Q PRIVATE SALE: We will sell the property described above al private sale sanatime after 15 days from me Date of Notice shoes above unless redeemed by you prior to such sale ? PUBLIC SALE: We will sell the property described above at public sale to the highest bidder on the data below (s any adjourn gilled dale). The sale yho be held as follows: Date of Sale Tina of Sale Place of Sale You may attend the sale and bring bidders if you want 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 Its the difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone 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. NOTICE OF REPOSSESSION The property is presently stored al: MANHEIM AUTO AUCTION MAA PA HOW TO GET YOUR PROPERTY BACK To get your property back, pay us this amount by wed check or money order before the vehicle is sold. Unpaid Balance $ 104926.26 Plus Costs: Repo Expenses $ 360.00 Plus Late Charges $ 1a.ue Less Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 11.306.35 If need more information about the sale call us at the you (Plus expenses incurred if default at the time of repossession exceeded 15 days and less rebate received aftertha detsof this .dice.) telephone number above, or Write us at the address above. Your prop" won't be sold 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. After Mat you can still get it back anyfirre betas it's the amount that you Owe us, you may call us at the telephone actually sold' number above, or write us at the address above and request a If you do, we'll have no further clam on h. But the lager you waif, the written explanation. mice costs (i?rcluding rapers) you may haw to Pay. you have any questions about this, please call us. 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 dealerloriginal 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 to. (dealedo iginal creditor) Under our agreement with your dealer/original credits, the dessmoriginal creditor is to sell the property and pay you any naney left over. If you owe money after the Sete, you wol pay it to the dealer(oripinsl credits. ? PERSONAL PROPERTY: Any personal property found In the vehicle may ce reclaimed by you within the nett 60 days s, in accordance wkh state law, by contacting this office. Thereafter, the personal property shell he disposed of acccrdkgly. ? Creditor has assigned to ft qualified intmmedlary too Exchange, LLC) its rights (but not Its obligations) with respect to the sale of each vehicle listed above PAYMENTS: All payments to us must be by certified check or money ceder. MILEAGE DISCLOSURE: If you are aware fhatthe rnllepe reflected on the vehicle's odor bF is not accurataI "reason. please contact us so that we can accurately report the whicle's mileage. INSURANCE RIGHTS: if You don9wanttogetyea Property back, caA the insurance company or the dealer/original creditor to make sure that any insurance has been cancelled. You haw a right to get credit for all premium refunds. SHERI GEORGE 1`era11988.37pan wwmwus wiI may Nonr uaea. CUSTOMERICUSTOMER FILE NI In U.SA. Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 210456076 800 6770730 DATE: 2005-02-23 P01 LN500000114 RAYMOND A. WILLOW RR 2 BOX 144 B NEWPORT PA 17074 111 I I I I I I I I 11111 I i I 1 I I I I I 111 1111111 r n I I I t I I 1 t 1„I I I I k I II111 KIMBERLEYA. WILLOW 234 MULBERRY ST NEWPORT PA 17074 STATEMENT OF SALE Account Number: 034184504 - The following property has been sold. Year Make Model 2001 FORD TAURS Balance owing on your contract Vehicle Identification Number: 1FAFP55U61A288526 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: (2) $ 0.00 (4) $ 4 200.00 (1) $ 10,946.35 (3) $ 10 946.35 (5) $ . 6 746.35 (6) $ 607.00 (7) $ 0.00 (8) $ 560.14 (9) 6793.21 Deficiency" Surplus" (10) $ - N/A The SurPIuslDeficiency 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: Mail deficiency payment to: Ford Motor Credit Company Ford Motor Credit Company P.O. BOX 6508 DEPT 194101 MESA ARIZONA 85216-6508 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 FFNA1199001M4 Previous ettocm Me NOT be used. Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 210456076 8006770730 DATE: 2005-02-23 POlLN500000115 KIMBERLEY A. WILLOW 234 MULBERRY ST NEWPORT PA 17074 11r1111?r11111?r11111111?1??r1111??1r?11111??111111111r1111r11 RAYMOND A. WILLOW RR2BOX144B NEWPORT PA 17074 STATEMENT OF SALE Account Number: 034184504 The following property has been sold. Year Make Model 2001 FORD TAURS Balance owing on your contract Vehicle Identification Number: 1FAFP55U61A288526 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: (2) $ 0.00 (4) $ 4 200.00 (1) $ 10,946.35 (3) $ 10.946.35 (5) $ __6 746.35 (6) $ 607.00 (7) $ 0.00 (8) $ 560.14 (9) 6793.21 Deficiency** Surplus* (10) $--- NIA 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 Mail deficiency payment to: Ford Motor Credit Company DEPT 194101 P.O. BOX 55000 DETROIT MI 48255-1941 FFNA1 1990 01104 Previous edd.on may NOTh u.d. t -n SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05326 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS WILLOW RAYMOND A ET AL 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 WILLOW RAYMOND A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT WILLOW RAYMOND A NOT FOUND , as to 419 BOBCAT ROAD NEWVILLE, PA 17241 PER POST OFFICE, DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing 18.00 Service 8.64 Not Found 5.00 Surcharge 10.00 .00 41.64 So answers,;-.--- .r- Z- z R. Thomas Kline Sheriff of Cumberland County MAURICE & NEEDLEMAN 10/17/2005 Sworn and subscribed to before me this I)- ( day of A.D. Pro ono SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05326 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS WILLOW RAYMOND A ET AL 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 WILLOW KIMBERLEY A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT , WILLOW KIMBERLEY A 419 BOBCAT ROAD NEWVILLE, PA 17241 PER POST OFFICE, DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answers:-- . J R. Thomas Kline Sheriff of Cumberland County MAURICE & NEEDLEMAN 10/17/2005 Sworn and subscribed to before me this day of - A.D. 0 O' Pro honota.r 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 tzc?? iay-ic?i FORD MOTOR CREDIT COMPANY Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-5326 RAYMOND A WILLOW KIMBERLEY A WILLOW Defendant(s). PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the verification of the Plaintiff, Ford Motor Credit Company, for that of the verification previously filed. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. Attorney for Plaintiff mas R. incz Th Yk, Esq. Date: /01940 CERTIFICATE OF SERVICE I, Thomas R. Dominczyk, Esq. hereby certify that on this date I have caused a true and correct copy of the foregoing Praecipe to Substitute Verification on behalf of Ford Motor Credit Company, to be served by regular, first class mail, postage pre-paid upon: RAYMOND A WILLOW 419 Bobcat Road Newville, Pa 17241-9724 KIMBERLEY A WILLOW 419 Bobcat Road Newville, Pa 17241 Respectfully Submitted, MAU & NEEDLEMAN, P.C. BY Thomas R. Do czyk, Esq. Attorney for Plaintiff DATED: 1019-q fo</ VERIFICATION I, verify that I am the Authorized Representative for Plaintiff, Ford Motor Credit Company, and are duly authorized to take this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. BY:LII DATE 611111 /CZ RAYMOND A WILLOW KIMBERLEY A. WILLOW Our file no. 942 48063000000034184504 ) C, ct .. ? ? !' ??; %.1 Curtis R. Long Prothonotary (Office of the Protbonotarp 11 Renee K. Simpson Cumberlanb Countp Deputy Prothonotary John E. Slike Solicitor 05 - S 3.21o 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 - Fax (717) 240-6573