HomeMy WebLinkAbout05-5661ARBITRATION 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
Attorneys for Plaintiff
/6V-I IDI
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, AZ 85216-6508
Plaintiff,
JERRY L SHIELDS
27 Cleversburg Rd
Shippensburg, Pa 17257
TAMMY Y SHIELDS
27 Cleversburg Rd
Shippensburg, Pa 17257
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. CjS - SLLI C10
Defendant(s).
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 ford, against you.
You are warned that if you fail to do so the case
may proceed without you and a judgrrivnt 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.
CIVIL ACTIUN CUMPLAIIN'I
AVISO
LLEVE ESTA DEMANDA A ON ABOGADOIMMEDIATAMENTE.
SI NO TIENE ABOGADO O SI NO TIENE EL D/NERO
SUPICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA
O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE
SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Le ban demandado a usted en ha torte. Si usted quiere defenderse
de ears dernsumbs expuestas en has paginas siguientes, usted tiene
venue (20) dial de plaza ah par it de la better de ha demands y ha
notification. Hate falm asemar una comparencia escrita o an
persona o eon on abogado y enn'egar a la cone an forma estrum sus
defenses o sus objeciones a has dentandas an contra de, so persona.
Sea ava do que si usted no se defiende, ha torte tomara medidas y
puede conlinuar Is demands, an contra suya sin previo aviso o
notificacion..Ademas, Is torte puede decldir a favor del demandante
y requiere que usted cumpla con todas las provisions de esta demanda.
Usted puede pander dinero o sus propiedades u otros derechos
importantes pars, usted.
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
P.O. Box 6508
Mesa, AZ 85216-6508
Plaintiff,
V.
JERRY L SHIELDS
27 Cleversburg Rd
Shippensburg, Pa 17257
TAMMY Y SHIELDS
27 Cleversburg Rd
Shippensburg, Pa 17257
Defendant(s).
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. O$$ - at U"
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, Jerry L Shields, is an individual who resides at 27 Cleversburg Rd
Shippensburg, Pa 17257.
3. Defendant, Tammy Y Shields, is an individual who resides at 27 Cleversburg Rd
Shippensburg, Pa 17257.
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(3112004, 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 $22,253.86 at an annual percentage rate of
11.50%, in order to purchase a certain motor vehicle, 2004 Ford Escape 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 $431.33 for a period of 72 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 2/21/2005, 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 $14,500.00.
10. After providing the aforesaid credit, a balance of $8,601.41 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
$8,311.58.
12. In addition to the foregoing, there is interest due and owing on the deficiency balance
which at this time amounts to $513.27 and which will continue to accrue.
13. The total amount due and owing at the time of the filing of this complaint is
$8,824.85.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $8,824.85, well as any additional interest and costs that may accrue and such
other and further relief as this Court may deem equitable and just.
7Re ully submitted,
I &NEEDLEMAN, P.C.
THOMAS R. OMINCZYK, ESQUIRE
Attorney for Plaintiff
VERIFICATION
1, 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
JIRE
'0?
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DATED:07 -)
IMI! YLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE 03131/2004
au
JE am CoAUyer Name are Action (lma I Gounry antl ZIP Cow)
Y L SHI?LOS cREmTOR (Bale, Nelw and Admsea)
JJAits
27 TAMMY Y SHIELDS
CLEVERSBURG RD 27 CLEVERSBURG RD PARSONS INTERSTATE FORD LLC
SH PPENSBURG PA 17257 SHIPPENSBURG PA 17257 196 WALNUT BOTTOM RD
CU ERLAND CUMBERLAND SHIPPENSBURG, PA 17257 n'PR 1 u 2004
You, Buyx Paa crveuyx,It sill may 11 me IMww become pebw M ou or on which me'mM Frlq'eMe. W. 1. two uN Proa or. will Tx
'Yawl Ill PXw'shown blew h IM crsWl pPw. BY rlanwa mN wnb.q, yea Mwuro s,ry m meMt anon me sammsMS en IM sail) em smx q IMe wIKrM
Nwl ae0 Year am Make Mmel GVW it Track Sur, vMew lamlfiwEOn Nmrber use For WNcb Pawmal
2004 ?7(Pe,.ew ?Askullurto
NE FORD ESCAPE IFMYU92164KB38102 G Conshowsl
INSURANCE
Traw 97 nnnGF DAIRT4 s 14211 An It ;447 13
Year all Ache G. Nlow?Ke Amour Dem, YOU MAY OBTAIN VEHICLE INSURANCE
ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE.
1. C an Prim ...........................................................................
. $ 21128 all
.
. YOU ARE NOT REQUIRED TO OBTAIN
.
.
. CREDIT LIFE, CREDIT DISABILITY AND
2 win Payment OTHER OPTIONAL INSURANCE. THIS
T rd Parry Rebete Assigned to Creditor..._ ........................ $ 2000.00 CONTRACT WILL NOT INCLUDE THEM
on Down Payment .................... ......._................ _._.......... ... $ 500.00 UNLESS YOU SIGN AND AGREE TO PAY
7 clot 97 DOUG $ 3420.00 $ 5447.33 $ 0.00 THE PREMIUM.
YwM Wx a-Rlanm Mani Awry
.,
obi Down Payment .......................................................... _........ S 2500,13R2)
THIS CONTRACT DOES NOT INCLUDE
3. U mid Balance of Cash Price (l minus 2) 2) ...................... .._.......... S 1882AR3) LIABILITY INSURANCE COVERAGE FOR
d. A
ants W b on your behall (Seller may be rebining a portion of these amounts) BODILY INJURY AND PROPERTY
T
Insurance Companies for
for DAMAGE CAUSED TO OTHERS.
R/A
Credit Liffir insurance (tor tam of contract)
........................ f
of co
Credit Disability Insurance (for Who of centred) ..............
$
[Term-onMs(Estimate)] N/A
T Public Officials I) for license ($ A An title ($__22 SD ), 8 ? Credit LMe
egislration'($ 2(1-Oy fees $ N/A; Insurer
ii) for filing fees $ S On ; $ N/A
iE) for hexes MW In Cash Pam) It 9C4 ;1 $ 1I Premium Insured(B)
7 GAP UICF for = vv r,AP $ 390.00
T for $ N/A Signature
T for $ N/A
To 551 BANK for NEGATIVE FOUITY $ 20273 3 Credit
tal ...................... ......... ................ ............... .................... ......... _....... S 3429, 394) ? Disability
S. A ount Financed (3 Plus 4) ...................... ...... $ 2 (S Insurer
FEDERAL TRUTH-IN-LENDING DISCLOSURES Premium Insured
A NUAL FINANCE A
PER
ENTAGE
CHARGE mount
Financed Total of
P
t Total Sale
P
i Signature
ATE
The donor Bmwm
The are q
aeon Provided m aymen
s
The amewn
you will have r
ce
The tow cwt
uh your Purchase on
The
Paso .'of year
a yearty raw the cod) will
wet you you or on your mid when you [reap, ?
bebell have Made e all all yw1
c Clher Optional Insurance Term
cover
Payments ofs $ N/A
11.5 % $ 8901.90 S 22253.86 g 31OS5. J 3355 Insurer Premium
Number of Amount of Each When Payments
S
h
d Ina ure
Y
j c
e
ule
? )PaymemS '171,33 are dm
.
I
'
7
CrMN Life and Credit mwdlix Inaumnw she
th
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r m
f
h
our
nell sc hedd
e
2
RF?f R?
(m
? e
aw o
or
e contract T
e amount and
0b $ N/A
1 fin
l
",/ ?
VV 4
I
wmgw au shown Ina .atim er uses l
p
a iton ro you owl'.
If You mY oil "or door early, you will not have to pay a mmlry.
L You must my a late Merge on the Portion of eau myment meateed more
late. The Marge la 2 pamant of Me late amount or $50.00 whlMawr Is lass.
reel You em giving a security interest In the veranda being purchased,
ease see this contract for additional Information on security Interest, nonpaym
pht to require remymanl of your debt in list belore the scheduled date. and
301 your Cvn,azt oblwallana, you may hive the elude the
oxm red Dome rem,., n.. r.hke corm - n, nn,.,.
NON-MODIFICATION DISCLOSU
Any Ma Be in Into sontrnct mum be mm war, antl signed by wu and l e co3br.
BUYER:
GPBUYER:' J
` 1
SIGNS SIGNS
YOU (NO LEDGE THAT YOU HAVE HEAD AND AGREE TO BE BOUND
BY E ARBITRATION PROVISION ON THE REVERSE SIDE OF THIS
CON ACT.
NOTICE TO BUYER
Don 1 sign this contract in blank.
You re entitled to an exact copy of the contract you sign.
Kee it to protect your legal rights.
Buy
con (and Co-Buyer) acknowledge that (i) before sinning this
act, Buyer ((and Co-Buyer) received ar rev ew a true
an ompieterly illled in copy of this contract and (ii) at the
time f signing this contract, Buyer and Co-Buyer) received
a tru and completely filled in copy this contract.
.l
4
E C
.1. are
Ill ng below, the"ar ecc omi this a after I at r Aa11gn wmBa Ina Bepenle
salon at efreehea to rule coq in. "We F CrydjAp/fA1?Np//ytry.
PARSONS 1NTERST TE F9? TMN ^-?? ""`Y,
nA ea'q,0nw pn.iei..aarmq ee,neel SEE BACK MR ADDI MPIAL AGREEMENTS
You must Insane me vshids. II a Marys Is
aoysim below the coulter will by to
buy De
owmlwe oilmka0 for me term sown.
Cowuggee will be Bse eon tho cosh value of
ms vMlcb at time q bee, sal not more man
the limits of me policy.
O Co niuma reeve ? $ N/A Oser R,.
i3odwon
? File- ThaXgamslnaa Promoter Cinsual
? Towing em Labor
O Tam Montle (Eallmets)
Premium $ NIA
?(Lbl cmcenrlen Waiver AdMnaum (Omomil)
a Mh WX le mad ad you now pud,Iwe t a Pere
.11.1yan wows, Purthem Pit MB m+B?Bpf Ill
op4dW and i0 ml r"I la Pass chi TAB tents
BM wwidnone 0 IM dare cwM:611.11m wa ere am set
rush M M,.W Journal which 1, recorcharreal
Use nth cmlmot The Pont Ira the ded mcaww
ever u sal hire aw Me amvM in Me non n
of Amounl Fro 1 usher Seoul 4.
Buy ]h1
Program No.
QUESTIONS?
IF
PLEASE CALL US AT 1-000-727.7000
or
Visit us at www.fordcmdit.com
III
ORIGINAL
Ford Motor Credit Company
PO BOX 3076
COLUMBIA MD 210456076
8006770730
DATE: 2005-02-24
P01LWF00000064
JERRY L. SHIELDS
27 CLEVERSBURG RD
SHIPPENSBURG PA 17257
TAMMY Y. SHIELDS
27CLEVERSBURG RD
SHIPPENSBURG PA 17257
STATEMENT OF SALE
Account Number: 036793884 .
The following property has been sold.
Year Make Model
2004 FORD ESCAPE
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**
Vehicle Identification Number:
1FMYU92164KB38102
(2) $ 0.00
(4) $ 14 500.00
(6) $ _ 517.00
(7) $ _ -..0.00
(8) $ 0.00
(1) $ - 22,584.41
(3) $ - _ 22,584.41
(5) $ _8 084.41
(9) $ 8601.41
(10) $ N/A
- -- -
Surplus*
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: 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
FFNA11990 0104 Previous editions may NOT be used
Ford Motor Credit Company
PO BOX 3076
COLUMBIA MD 210456076
8006770730
DATE: 2005-02-24
P01LWF00000065
TAMMY Y. SHIELDS
27 CLEVERSBURG RD
SHIPPENSBURG PA 17257
11?1111111??11111?1?111?1111??11?t1?1?llll????111111??1?111?
JERRY L. SHIELDS
27 CLEVERSBURG RD
SHIPPENSBURG PA 17257
STATEMENT OF SALE
Account Number: 036793884
The following property has been sold.
Year Make Model
2004 FORD ESCAPE
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**
Vehicle Identification Number:
1FMYU92164KB38102
(1) $ 22,584.41
(2) $ 0.00
(4) $ 14,500.00
(6) $ 517.00
(7) $ 0.00
(8) $ 0.00
(3) $ __ 22 584.41
(5) $ _ _ 8,084.41
(9) $ _ 8601.41
Surplus* (10) $ N/A
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
FFNA11990 01/04 Previous editions may NOT be used.
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Ford Motor Credit Company
P.O. Box 3076
COLUMBIA, MD2104"076
(600)677-0730
JERRYL. SHIELDS
27 CLEVERSBURG RD
SHIPPENSBURG, PA 17257
Date of Repossession 01-20-2005
Date of Notice
01-22-2005 Date of Contract
0331-2004
Account Number. 0367938 84
Buyer JERRYL SHIELDS
Cobuyev TAMMYY. SHIELDS
DESCRIPTION OF PROPERTY
Year Make
2004 FORD 0 New
? Used
Vehicle Identification Number:
IFMYU92164KB38102
Model
ESCAPE Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
have your property described above because you broke promises in our agreement.
PRIVATE SALE: We will sell the property described above at ?
private sale sometime after 15 days from the Date of Notice
shown above unless redeemed by you prior to such sale.
PUBLIC SALE: We will $61 the property described above at public
sale to the highest bidder on the date below for my adjournment
date). The sale will be held as foil.;
Date of Sale Time of Sale Plato of sate
You may attend the sale and Bing bidders if You want
NOTICE OF REPOSSESSION
money that we get from the sale (after paying our costs,
luding reasonable attorney's fees and legal expenses if
mitted by law) will reduce the amount you owe. If we get
s money than you owe, you will still owe us the difference. If
get more money than you owe, you will get the extra money,
ass we must pay it to someone else.
can get the property back at any time before we, sell it by
ig us the full amount you owe (not just the past due
tents), including our expenses. See How To Get Your
any Back for an itemization of amount owing. To learn the
t amount you must pay, call us at the telephone number
need more information about the sale call us at the
Dne number above, or write us at the address above.
3u want us to explain to you in writing how we have figured
amount that you owe us, you may Gall us at the telephone
tber above, or write us at the address above and request a
ten explanation.
are sending this notice to the following people who have an
rest in the property described above or who owe money under
r agreement: 1) The buyer and any cobuyer named above;
my dealer/original creditor named below, 3) If there are other I
ple, they are named on an attachment sent with this notice
.
The property is presently stored at STEALTH RECOVERY
HARRISBURG PA
HOW TO GET YOUR PROPERTY BACK
To get your property back, pay us this amount by certified check or
money order before the vehicle's sold.
Unpaid Balance $ 22,557.31
Plus Costs: Repo Expenses $ 325.00
Plus Lets Charges $ 27.10
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 22,909.41
(Plus e»penses incurred if tlefault at the time of repossession exonded
15 days and less rebate received after the date of this ndiii
Your property won't be sold until 15 days after the date of this notice at
the EARLIEST. After that you can still get 0 back any time before it's
actually said.
If you do, well 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 tea) resumed to:
(dealer/original creditor)
er our agreement with your deelerloriginal creditor , the dealmoriginal creditor is to sell the property and pay you any money left ow. If you owe money
the sale, you will pay it to the dealer/original creditor.
PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the nest 60 days a, in accordance with state law. by
contacting this once. Thereafter, the personal property shall be disposed of accordingly.
Creditor has assigned to its qualified intermediary foil Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above
All payments to us must be by certified check or money order.
EAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicles odometer is not accurate for any reason, please contact us so that"
accurately report the vehicle's mileage.
URANCE RIGHTS: If you don 't want to get your property back, call the insurance company or the dea morigin ll creditor to make sure that any insurance
been cancelled. You have a night to get credit for all premium refunds.
A M. PAPARAZZO
ee-37Jan 02 Pravloue Wit- may NOT M used
V SA CUSTOMEfLCUSTOMER FILE
.
"'PRN"'
Fad Motor Credit Company
P.O. Box 3076
COLUMBIA, MD 21045-6076
(600) 6n-0730
TAMMYY. SHIELDS
27 CLEVERSBURG RD
SHIPPENSBURG, PA 17257
Deeof Raposaession 01-2x2005
Dale of Notice
01-22-2005 Date of Contract
0331-2004
1
Account Number. 03679386 4
Buyer JERRYL SHIELDS
Colbuyer TAMMYY. SHIELDS
DESCRIPTION OF PROPERTY
Year Make
2069 FORD ?x New
? used
Vehicle Identification Number:
1FMYU92164KB38102
Model
ESCAPE Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
have your property described above because you broke promises in our agreement
PRIVATE SALE: We will sell the property described abom at
pdmle sale sometime after 15 days from the Data of Notice
shown atom 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 (a any adjmmment
date). The sale will be held as fdlows:
Data of Sale Time of Sale Place of Sale
You may, adend the sale and bring bidders 0 you want.
F__ NOTICE OF REPOSSESSION
t money that we get from the sale (after paying our costs,
uding reasonable attorney's fees and legal expenses if
mitted by law) will reduce the amount you owe. If we get
( money than you owe, you will still owe us the difference. If
get more money than you owe, you will get the extra money,
ass we must pay it to someone else.
can get the property back at any time before we sell it by
1g us the full amount you owe (not just the past due
rents), including our expenses. See How To Get Your
)arty Back for an itemization of amount owing. To learn the
t amount you must pay, call us at the telephone number
if ou need more information about the sale call us at the
ter phone number above, or write us at the address above.
If, ou want us to explain to you in writing how we have figured
IN amount that you owe us, you may call us at the telephone
nu ber above, or write us at the address above and request a
wr ten explanation.
W are sending this notice to the following people who have an
int rest in the property described above or who owe money under
a yo r agreement: 1) The buyer and any cobuyer named above;
2) ny dealer/original creditor named below; 3) If there are other
ple, they are named on an attachment sent with this notice.
The property is presently stored at; STEALTH RECOVERY
HARRISBURG PA
HOW TO GET YOUR PROPERTY BACK
To get your property back, pay us this amount by cartifed check a
money order before the vehicle is sold.
Unpaid Balance $ 22557.31
Plus Costs: Repo Expenses $ 325.00
Plus Late Charges $ 27.10
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 22,909.41
(Plus expenses incurred if default at the time of repossession exceeded
15 days and less rebate received ahor the date of this nofce,)
Your property won't be sold until 15 days after the date of this notice at
the EARLIEST. After that you can still get it back any time before it's
actually add.
If you do, well hem no further clam on it But the longer you wait, the
more costs (including repairs) you may ham to pay.
If you ham any questions about this, please call us.
The property has been (a will be) returned to:
(dealer/original creditor)
V our agreement with your dealer/original creditor, Me dealedoriginai creditor is to sell the property and pay you any money left omr. If you owe money
the sale, you will pay tt to the desedodginal creditor.
PERSONAL PROPERTY: Any personal property found in Me vehicle may be reclaimed by you within me rend 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 (OI Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above
All payments to us must be by tertifed check or money order.
AGE DISCLOSURE: If you are aware that the mileage reflected w the vehicle's odometer is not accurate for any reason, please contact us so Met we
rccurately report the vehicle's mileage.
TRANCE RIGHTS: If You don't want to flat your property back, call the insurance company or the dealedoriginal creditor to make sure that any insurance
roan cancelled. You ham a right to get credit for all premium refunds.
A M. PAPARAZZO
rases-w.r.nrepr.,:,ou. eeuom may nor u. mee.
InV CUSTOMER/CUSTOMER FILE
I $P.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-05661 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
SHIELDS JERRY L ET AL
MICHAEL BARRI
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SHIELDS JERRY L the
DEFENDANT at 2019:00 HOURS, on the 18th day of November , 2005
at 27 CLEVERSBURG ROAD
SHIPPENSBURG, PA 17257 by handing to
JERRY SHIELDS
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 38.40
Affidavit .00
Surcharge 10.00
.00
66.40
Sworn and Subscribed to before
me this !ar day of
P othaf ry //
So Answers:
R. Thomas Kline
11/21/2005
MAURICE & NEEDLEMAN
By.
Deputy Sh iff
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-05661 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
SHIELDS JERRY L ET AL
MICHAEL BARRICK Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SHIELDS TAMMY Y
the
DEFENDANT , at 2019:00 HOURS, on the 18th day of November , 2005
at 27 CLEVERSBURG ROAD
SHIPPENSBURG, PA 17257
by handing to
JERRY SHIELDS, HUSBAND
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 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this ),,a day of
fA}A JU6' A.D.
rot 0 ary
So Answers:
R. Thomas Kline
11/21/2005
MAURICE & NEEDLEMAN
BY: ??/ i
Deputy ShEa5f i f
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
(LiJ) /ZSY-/I.i
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
WORKOUT AGREEMENT FOR PAYMENT AND STIPULATION FOR JUDGMENT
THIS AGREEMENT is made between FORD MOTOR CREDIT COMPANY c/o Maurice &
Needleman, P.C. 1617 John F. Kennedy Boulevard, Philadelphia, Pennsylvania 19103, hereinafter
called the 'Plaintiff' and JERRY L SHIELDS and TAMMY Y SHIELDS of 27 CLEVERSBURG
RD, SHIPPENSBURG, PA 17257, hereinafter collectively called the "Defendant"
WHEREFORE:
1. The Defendant acknowledges having executed to the Plaintiff a Retail Installment
Contract ("Note") under the terms of which Defendant promised to make certain payments of
principal and interest to the Plaintiff according to a schedule more specifically set forth in the terms
of the Note.
2. The Defendant acknowledges having failed to pay interest and principal as required
by the terms of the Note and is in default of the Note.
3. The Defendant acknowledges that there is immediately due and owing from him to
the Plaintiff under the Note $9229.86, consisting of principal, interest, and attorney's fees
(hereinafter the "Amount Due") and the Defendant acknowledges having no set-off, credit, or claim
against the Amount Due.
4. The Defendant desires to satisfy the Amount Due and therefore makes the above
representations to induce the Plaintiff to enter into the within agreement for the payment of the
Amount Due.
5. NOW THEREFORE: For good and valuable consideration described below, the
parties agree as follows:
a. Plaintiff may enter judgment against Defendant for the amount due and the
Defendant consents to the entry thereof
b. The Defendant shall make payments of $100.00 due on 01/15/06, 02/15/06
and 03/15/06; defendant shall make payments of $300.00 a month due on 04/15/06 and on the same
day of each month thereafter until it is paid in full.
C. Interest shall continue to accrue at the rate of 6.000%
d. All other terms of the Note, unless otherwise set forth herein will remain
unchanged.
e. All payments under this Agreement will be made by check payable to
"Maurice & Needleman, P.C. FMC Attorney Trust Account" at 1617 John F. Kennedy Boulevard,
Philadelphia, Pennsylvania 19103. Please reference the file number 1006 on all payments.
6. During the term of this Agreement, the Plaintiff will forebear from enforcing its
judgment for the collection of the Amount Due provided the Defendant is not in default of any of the
2
terms or conditions of this Agreement and makes all payments timely.
7. The Defendant will deliver to the Plaintiff, with a signed copy of this Agreement,
answers to the "Questionnaire" simultaneously supplied to the Defendant with this Agreement.
8. EVENTS OF DEFAULT. The following shall constitute an Event of Default under
this Agreement:
a. The Defendant fails to pay, when due and payable, any scheduled payment as
set forth in paragraph 5 b. above, and such scheduled payment remains unpaid for more than ten (10)
days
b. The Defendant fails to return the Questionnaire.
9. PLAINTIFF'S REMEDIES UPON DEFENDANTS' DEFAULT. In the event
Defendant fails to cure any default after Notice thereof as described in above, Plaintiff will be
permitted to commence execution proceedings forthwith.
10. This Agreement does not alter, amend or modify the Defendant's obligations to the
Plaintiff under the above Note, unless otherwise set forth herein. This Agreement does not alter,
amend or modify the Defendant's obligations to the Plaintiff under any other document which is not
named herein.
It. The Defendant acknowledges that as of the date of this Agreement he has no claim,
whether known or unknown, against the Plaintiff AND HEREBY WAIVES AND GIVES UP ANY
AND ALL CLAIMS HE MAY HAVE AGAINST THE PLAINTIFF AS OF THE DATE OF THIS
AGREEMENT, WHETHER KNOWN OR UNKNOWN.
12. THE UNDERSIGNEDACKNOWLEDGES HAVING READ THIS AGREEMENT,
3
.
UNDERSTANDS IT, AGREES TO ITS TERMS AND HAS RECEIVED A COPY OF IT,
WITHOUT CHARGE.
„t Dated:
-AERRM L -ELDS
Defendant
r
L? Dated:
TAMMY 10 SHIELDS
Dated: a /,, x-106
R.17on?czyk, Esq.
for For Motor Credit Company
4
(l
? 11
_
^' i l
_
?.? ?
?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
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
Case No. 05-5661
JERRY L SHIELDS
TAMMY Y SHIELDS
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.
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Respectfully submitted,
MAURICE & NEEDLEMAN, P.C.
Attorney for Plaintiff
ESQ
Date: 2//5--/06
CERTIFICATE OF SERVICE
I, Thomas 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:
JERRY L SHIELDS
27 Cleversburg Rd
Shippensburg, Pa 17257
TAMMY Y SHIELDS
27 Cleversburg Rd
Shippensburg, Pa 17257
Respectfully Submitted,
MAUI & NEEDLEMAN, P.C.
BY:
Attorney for
Esquire
DATED:
VERIFICATION
I, r ) 1 I T JdeA verify that I am the Authorized
A
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:
DATE: NOV 0 4 2005
JERRY L SHIELDS
Our file no. 1006
48063000000036793884
_ ;',
?
_ ,
- -
' ? ;,
,
?.?,
'
' _
:
? ? _
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
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
No answer having been filed in the above Civil Action, kindly enter Judgment in
favor of Plaintiff, and against Defendant, JERRY L SHIELDS AND TAMMY Y.
SHIELDS in the amount as follows:
Principal Amount $ 8311.58
Interest to Date $ 858.94
Costs $ 137.90
Attorneys Fees $ 0.00
TOTAL $ 9308.42
MAUR EDLEMAN, P.C.
BY:
THOMAS OMINCZYK, ESQ.
Attorney for Plaintiff
Suite 935, One Penn Center
1617 John F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.6651133
fax 215.563.8970
www.mnlawpc.mm
Donald S. Maurice
Member NJ Bar
Board Certified
Creditors' Rights Law
American Board of Certification
Joann Needleman
Member PA & NJ Bar
Thomas R. Dominczyk
Member NJ & PA Bar
December 14, 2005
VIA CERTIFIED & REGULAR MAIL
JERRY L SHIELDS
27 CLEVERSBURG RD
SHIPPENSBURG, PA 17257
Our File No. 1006
RE: FORD MOTOR CREDIT COMPANY v. JERRY L
SHIELDS AND TAMMY Y SHIELDS
CUMBERLAND COUNTY COURT OF COMMON
PLEAS, CASE NO. 05-5661
Dear JERRY L SHIELDS:
Enclosed please find a ten (10) day notice of default which is self-
explanatory. This is being served upon you due to your failure to respond
to Plaintiffs Complaint served upon you on 11/18/2005 . Unless an
answer to Plaintiff s Complaint is filed with the Court within ten (10) days
from the date of this notice, a default judgment may be entered against
you.
If you would like to discuss a resolution to this matter, please call our
office at 908-575-0220 ex. 21.
Thank you for your prompt attention to this matter.
New Jersey Office
MAURICE & NEEDLEMAN, P.C.
250 Route 28 West
Suite 203
Bridgewater, NJ 08807
tel. 908.575.0220
fax 908.575.0632
Eric
U.S . Post al Service. .
CE RTIF IED MAIL ,., RE CEI PT
(Do mestic M ail Only; No Ins urance Co
ver age Provi ded)
CO
171
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O
O
0
THIS CORRESPONDENCE IS o
DEBT, AND ANY INFORMAT U
FOR THAT PURPOSE. THIS I o
vl
0
0
M1
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
/Sy-/1:) 1
FORD MOTOR CREDIT COMPANY
Plaintiff
v.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
CUMBERLAND COUNTY
COMMON PLEAS
CASE NO. 05-5661
IMPORTANT NOTICE
TO: JERRY L SHIELDS DATE: December 14, 2005
27 CLEVERSBURG RD
SHIPPENSBURG, PA 17257
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE AN
ANSWER IN THIS CASE. UNLESS YOU TAKE ACTION WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR RIGHTS
TO DEFEND AND THEREBY LOSE PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
Attorney for Plaintiff
Suite 935, One Penn Center
1617 John R Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.665.1133
fax 215.563.8970
www.mnlawpc.com
Donald S. Maurice
Member NJ Bar
Board Cedified
Creditors Rights Law
American Board of Certification
Joann Needleman
Member PA & NJ Bar
Thomas R. Dominczyk
Member NJ & PA Bar
December 14, 2005
C3
Ir
rn
0
VIA CERTIFIED & REGULAR D Ln
TAMMY Y SHIELDS C3
27 CLEVERSBURG RD N
SHIPPENSBURG, PA 17257
RE: FORD MOTOR CREDIT COMPANY
SHIELDS AND TAMMY Y SHIELDS
CUMBERLAND COUNTY COURT OF COMMON
PLEAS, CASE NO. 05-5661
Dear TAMMY Y SHIELDS:
Enclosed please find a ten (10) day notice of default which is self-
explanatory. This is being served upon you due to your failure to
respond to Plaintiffs Complaint served upon you on 11118/2005. Unless
an answer to Plaintiff s Complaint is filed with the Court within ten (10)
days from the date of this notice, a default judgment may be entered
against you.
If you would like to discuss a resolution to this matter, please call
our office at 908-575-0220 ex.21 and ask for Kim Crosby.
Thank you for your prompt attention to this matter.
New Jersey Office
MAURICE & NEEDLEMAN, P.C.
250 Route 28 West
Suite 203
Bridgewater, NJ 08807
tel. 908.575.0220
tax 908,575.0632
Enc
ESQ.
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
i>
J;
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
/69-/1-1)1
Plaintiff
V,
CREDIT COMPANY
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
1MPORIANT NOTICE
TO: TAMMY Y SHIELDS DATE: December 14, 2005
27 CLEVERSBURG RD
SHIPPENSBURG, PA 17257
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE AN
ANSWER IN THIS CASE. UNLESS YOU TAKE ACTION WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR RIGHTS
TO DEFEND AND THEREBY LOSE PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717)
Attorney for 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
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was
mailed on 12/14/2005 to Defendant, JERRY L SHIELDS , against whom judgment is to
be entered after the default occurred and at least ten (10) days prior to the date of the
filing of the Praecipe. A copy of said Notice dated 12/14/2005, a copy of the receipt for
certified mailing to the Defendant and affidavits of service of said notice are all attached
hereto.
MAURICE & NEEDLEMAN, P.C.
BY:
T OMAS MINCZYK, ESQ.
Attorney for 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
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was
mailed on 12/14/2005 to Defendant, TAMMY Y SHIELDS, against whom judgment is
to be entered after the default occurred and at least ten (10) days prior to the date of the
filing of the Praecipe. A copy of said Notice dated 12/14/2005, a copy of the receipt for
certified mailing to the Defendant and affidavits of service of said notice are all attached
hereto.
MAURICE & NEEDLEMAN, P.C.
BY:
ESQ.
Attorney for
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
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V,
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
CERTIFICATION OF ADDRESSES
It is hereby certified that the parties have the following addresses:
Plaintiff: FORD MOTOR CREDIT COMPANY
P.O. Box 6058
MESA AZ 85216
Defendant: JERRY L SHIELDS,
27 CLEVERSBURG RD,
SHIPPENSBURG, PA 17257
MAURICE & NEEDLEMAN, P.C.
BY:
T OMAS D MINCZYK, ESQ.
Attorney for 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
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V,
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
CERTIFICATION OF ADDRESSES
It is hereby certified that the parties have the following addresses:
Plaintiff: FORD MOTOR CREDIT COMPANY
P.O. BOX 6058
MESA AZ 85216
Defendant: TAMMY Y SHIELDS,
27 CLEVERSBURG RD,
SHIPPENSBURG, PA 17257
MAUR
BY:
ESQ.
Attorney for 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
Attorneys for Plaintiff
/89-71)4
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF NEW JERSEY
COUNTY OF SOMERSET
SS.
THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law,
deposes and says that she represents the Plaintiff in the above entitled case and that
Defendant, JERRY L SHIELDS , is over 18 years of age; the occupation of Defendant is
unknown and to the best of Plaintiffs knowledge, information and belief, Defendant is
not in the military service of the United States, nor any State of Territory thereof or its
Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the
amendments thereto.
SWORN TO AND SUBSCRIBED
before me this f ay
of 200*.
N0 y PabCc
?. N07 A 4Y Pt 13 OF NEEN
my Commission Expires 1213012010
MA ?OMAS EDLEMAN, P.C.
BY:
T INCZYK, ESQ.
Attorney for 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
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF
Plaintiff COMMON PLEAS
V. I CASE NO. 05-5661
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF NEW JERSEY
COUNTY OF SOMERSET
SS.
THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law,
deposes and says that she represents the Plaintiff in the above entitled case and that
Defendant, TAMMY Y SHIELDS is over 18 years of age; the occupation of Defendant is
unknown and to the best of Plaintiffs knowledge, information and belief, Defendant is
not in the military service of the United States, nor any State of Territory thereof or its
Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the
amendments thereto.
P.C.
BY:
ESQ.
Attorney for P
SWORN TO AND SUBSCRIBED
befo e me this 11 day
of f doykAw?> 20?.
No'
Ku? r 6-?
KIMBERLY A CROSBY
A NOTARY PUBLIC OF NEW JERSEY
My COMMIssion Expires 72/30/2010
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
1?) RSy-/ll4
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
AFFIDAVIT OF MAIL SERVICE
STATE OF NEW JERSEY
COUNTY OF SOMERSET
SS.
THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law,
deposes and says that she is an attorney at law and that on 12/14/2005 (date) he/she
mailed a written Notice of Intention to File the Praecipe to Defendant, TAMMY Y
SHIELDS, at 27 CLEVERSBURG RD, SHIPPENSBURG, PA 17257 by certified mail,
article nos . Copies of the receipts evidencing said mailing are attached hereto.
The regular mail was not returned to Counsel's office, therefore, pursuant to
Pa.R.C.P. §403 (1), service has been perfected by regular mail due to the fact that the
Notice has not been returned to sender within fifteen (1 ays fter mailing.
BY:
MAU 4DTHS tINCZYK, AN, P.C.
ESQ.
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED
before me this day
yy
oay ub c
KIMBEt-41-= 11 s, NOTARY PUBLIC OF NEW JERSEY
My commission Expires 12130/2010
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
/2SY-/1J4
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
AFFIDAVIT OF MAIL SERVICE
STATE OF NEW JERSEY
SS.
COUNTY OF SOMERSET
THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law,
deposes and says that she is an attorney at law and that on 12/14/2005 (date) he/she
mailed a written Notice of Intention to File the Praecipe to Defendant, JERRY L
SHIELDS, at27 CLEVERSBURG RD, SHIPPENSBURG, PA 17257 by certified mail,
article nos.. Copies of the receipts evidencing said mailing are attached hereto.
The regular mail was not returned to Counsel's office, therefore, pursuant to
Pa.R.C.P. §403 (1), service has been perfected by regular mail due to the fact that the
Notice has not been returned to sender within fifteen (15) days after mailing.
P.C.
BY:
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED
before me this 11 day
of kJoyL<p.200? .
Notary Public
KIM RCv a CAiS
A NOTARY PUBLIC OF NEW JERSEY
My Commission Expires 12130120`10
ESQ.
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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
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 05-5661
Notice is hereby given that a judgment in the above-capf ned matter has
been entered against you in the amount of $9308.42 on 7 a.ovln
A copy of all documents filed with the Prothonotary in support of the
within judgment
If you have any questions regarding this matter, please contact the filing party:
Name: THOMAS DOMINCZYK, Esquire
Address: Suite 935, One Penn Center at Suburban Station
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Telephone No.: 215-789-7154
(This Notice is given in accordance with Pa.R.C.P. §236)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
( ) Other
FORD MOTOR CREDIT COMPANY
vs.
( ) Confessed Judgment
File No. .05-5661
Amount Due 9308.42
Interest 02/22/2006 $619.05
JERRY L SHIELDS AND TAMMY Y
SHIELDS
TO THE PROTHONOTARY OF THE SAID COURT:
,. Atty's Comm
Costs
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(s). SS # XXX-XX-8463 & 3995 GARNISHMENT ONLY!
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of 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)
• in the possession of Waypoint Bank, Garnishee, 830 N US Highway 15, Dillsburg, PA
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
Date
0 (indicate) Index this writ against the gamishee(s) as, a lis pendn nst real estate of the
defendant(s) described in the attached exhibit. A / 1
Signature:
Print Name-
Address:
Attorney for:
Telephone:
Esq
915 One Penn Center
Philadelphia, PA 19103
Plaintiff
215 789 7154
Supreme Court ID No.: 74276
(over)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-5661 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 JERRY L SHIELDS AND TAMMY Y SHIELDS , 27 CLEVERSBURG RD., IPA
(1) You are directed to levy upon the property of the defendant (s)and to sell . 17257-9410
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
WAYPOINT BANK, 17 WEST HIGH Sr., CARLISLE, PA 17013
ANY AND ALL ACCOUNTS IN THE NAME OF THE ABOVE DEFENDANTS. SS# XXX-XX-
8463 & 3995.
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 $9308.42
Interest 2-22-06 $619.05
Atty's Comm %
Atty Paid $173.90
Plaintiff Paid
Date: 05-31-07
L.L. $.50
Due Prothy $2.00
Other Costs
(Seal)
REQUESTING PARTY:
Name JOANNE NEEDLEMAN, ESQUIRE
Address: 935 ONE PENN CENTER
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-789-7154
-1-Y
Supreme Court ID No. 74276
I •
;a
FORD MOTOR CREDIT COMPANY
Plaintiff,
V.
JERRY L SHIELDS AND TAMMY Y SHIELDS
Defendant(s).
WAYPOINT BANK
CUMBERLAND COUNTY COURT OF COMMON
PLEAS
Case No. 05-5661
46wen5 -'1k)
INTERROGATORIES IN ATTACHMENT
TO: WAYPOINT BANK
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-8463 & xxx-xx-3995) 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. NO
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?
YES - SEE ATTACHED VERIFICATION
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? NO
?S
4. At the time you were served or any subsequent time, did you hold as fiduciary
any property in which defendant had an interest? No
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? NO
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. NO
JO 1YELDLEMAN, ESQUIRE
e for Plaintiff
93 e Penn Center
P adelphia, PA 19103
215-789-7154
ANSWERS TO INTERROGATORIES
Account # 3531000985 Balance: $1402.31
Account Holder: Jerry Lynn Shields
Tammy Yvonne Shields
27 Cleversburg Rd
Shippensburg, PA 17257-9410
Account # 3534001064 Balance: $35.19
Account Holder: Natasha L Shields
Tammy Yvonne Shields
27 Cleversburg Rd
Shippensburg, PA 17257-9410
Account # 3534001072 Balance: $56.21
Account Holder: Brandon R Shields
Tammy Yvonne Shields
27 Cleversburg Rd
Shippensburg, PA 17257-9410
VERIFICATION
I, Camille Neuwinger, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the
information contained in the foregoing Answers to Interrogatories in Attachment are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falsification to authorities.
Sovereign Bank
By: An,
Camille Neuwinger
C.O.P. Lead Specialist
N
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THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
Ford Motor Credit Co
VS.
Jerry L Shields and Tammy Y Shields
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
Joann Needleman, Esquire
Maurice & Needleman, PC
935 One Penn Center
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Service by certified mail addressed as follows:
Jerry Lynn Shields
Tammy Yvonne Shields
27 Cleversburg Rd
Shippensburg, PA 17257-9410
Camille Neuwinger
C.O.P. Lead Specialist
Sovereign Bank
MA1 M133-02-10
2 Morrisey Boulevard
Boston, MA 02125
June 19, 2007
°7v Pi
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SHERIFF'S RETURN - GARNISHEE
r ..
CASE NO: 2005-05661 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
SHIELDS JERRY L ET AL
And now RICHARD SMITH
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:00 Hours, on the 14th day of June , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
SHIELDS JERRY L
hands, possession, or control of the within named Garnishee
WAYPOINT BANK 17 WEST HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
RYAN BEM (CUSTOMER SERVICE)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His .
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
41sa1?7 C .00
Sworn and Subscribed to
before me this day of
in the
and made
So answers-
R. Thomas Klin
Sheriff of Cumberland County
06/15/2007
By
eputy Sheriff
A.D
L SHERIFF'S RETURN - GARNISHEE
r -
CASE NO: 2005-05661 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
SHIELDS JERRY L ET AL
And now RICHARD SMITH
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:00 Hours, on the 14th day of June , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
SHIELDS TAMMY Y
hands, possession, or control of the within named Garnishee
WAYPOINT BANK 17 WEST HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
RYAN BEM (CUSTOMER SERVICE)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His
in the
true
and made
Sheriff's Costs: So ans
Docketing 00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.0000
06/15/2007
Sworn and Subscribed to
before me this day of By
Deputy Sheriff
A.D
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
(11 J) /?39 /1.-) 1
FORD MOTOR CREDIT COMPANY
Plaintiff,
V.
JERRY L SHIELDS AND TAMMY Y
SHIELDS
Defendant(s).
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 05-5661
ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE ONLY
TO THE PROTHONOTARY:
Kindly mark judgment in this matter as against garnishee, Waypoint Bank as fully
satisfied.
Respectfully Submitted,
MAWCE & NEEDLEMAN, P.C.
eedleman, Esq.
Date: July 26, 2007
a
Sri
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R. Thomas Kline, Sheriff, who being,4u,ly sworn according to law, states this
Writ is returned ABANDONED, n6, ?tibri ,takeri'ifi's0ujppnths.
Sheriff's Costs: log' ji",' 12 Advance Costs: 150.00
`a Aertfl's Costs 96.19
Docketing 18.00 53.81
Poundage 1.89
Advertising
Law Library .50
Prothonotary 2.00
Mileage 4.80
Misc.
Surcharge 40.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00
TOTAL 96.19 ? 51a sfo P
Refunded to Atty on 04/30/08
So Answers, //.
R. Tho a Kline, S
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