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Home My WebLink About05-6330ARBITRATION 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 (215) 789-7151 PRIMUS FINANCIAL SERVICES P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. MICHAEL P FRANKS Rear Unit A9 225 W Coover St Mechanicsburg, Pa 17055 LYN MANHIRE Rear Unit A9 225 W CooveT St Mechanicsburg, Pa 17055 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 titer this complaint and notice are served, by entering a written appearance personally or by attorney and thing 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. Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. QS -L336 021ULL CIVIL ACTION COMPLAINT AVISO Le ban demandado a usted to la torte. Si usted quiere defersicow de estas demandas expuesms; en las pagirea siguientes, noted tiene veinte (20) dies de plazo at partir de la fecha the la demanda y la notification. Hate Saba asentor una comparencia escrita o en persona o curt on abogado y entregar a la Corte en forma escrita sus defenses o sus objeck nes a has demandas en contra de so persona. Sea avisado que si noted no se defoude, la torte tomam medidas y puede continuar la demanda en contra suya sin prevlo aviso o notification. Ademas, la carte puede decider a favor del demandente y requiem que usted curnpla con todas ]as provisions de esta demanda. Usted puede perder dinero o sus propiedades a otros derechos importanles para noted. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDI.ATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE Dr. PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUE.NTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. YOU SHOULD TAKE THIS PAPER 1'0 YOUR LAWYER A"F 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. 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 PRIMUS FINANCIAL SERVICES P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. MICHAEL P FRANKS Rear Unit A9 225 W Coover St Mechanicsburg, Pa 17055 LYN MANHIRE Rear Unit A9 225 W Coover St Mechanicsburg, Pa 17055 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND C COMMON PLEAS Case No. QS , Q36 CIVIL ACTION COMPLAINT COURT OF ?lv? 1 E I. Plaintiff, Primus Financial Services, is a Corporation with its place of business at P.O. Box 6508 Mesa, Az 85216-6508. 2. Defendant, Michael P Franks, is an individual who resides at Rear Unit A9 225 W Coover St Mechanicsburg, Pa 17055. 3. Defendant, Lyn Manhire, is an individual who resides at Rear Unit A9 225 W Coover St Mechanicsburg, Pa 17055. 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 December 6, 2000, 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 $9,888.00 at an annual percentage rate of 16.350%, in order to purchase a certain motor vehicle, 1999 Hyundai Accent 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 $229.62 for a period of 66 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 November 23, 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 $900.00, however a balance of $4253.21 is still due and owing, and a notice of the deficiency balance was sent to the Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C. 10. Pursuant to the terms of the contract, Defendant is required to pay all amounts due and owing, including any balance that may remain after the sale of the vehicle, and the Defendant failed to do so, thereby in default of the Contract. 11. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to $502.97 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $4756.18. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $4756.18, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. 1submitted, & NEEDLEMAN, P.C. THOMAS R. INQ INCZYK, ESQUIRE Attorney for Plaintiff VERIFICATION I, THOMAS R. DOMINCZYK, ESQUIRE, verify that I am the Attorney of record for Plaintiff, PRIMUS FINANCIAL SERVICES, 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: November 14, 2005 `1T p& 2 t" X6 zo0 OKLAHOMA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DAW0 IAEL FRANKS LYN FRANKS S 151 ST UNIT 1128 BLDG 335 4701 N. 399 0KC 1®NBfi¦ 1701 N. N. 39TH E%PRESSNAY ¦ OKC, OK 73122 700 YW.tiro ENM iad Co-erea,keery).ro"d"11M veNrmO*WftW WON for mb a n aMk. The pN W" 4 ahpAn Num a" ,,, Pda."The aedl Dda W eb«m baba a "foul Sale Price;' By 60" aue Cantrell. You &KIC11e to buy Ibe "hick' on areal uder the agmemMN an Me fnua and bark d INS alaaaa. iD 1991 HYUNDAI ACCgWT IKMKVU34NLA Tne,j/A s NIA s N/A Year and Make G Alld"np Amount OWg 1. Comb prim .................... ... .. 3Naa....,.. (') 2. vows Payment MIA (e) Rebsbt Assigned to Creditor . ..... .. .. i ..I_ (b) Cub Na/lAtl ......... ...... . . i- ? ?- (d) Cash Dean Pey111ard l"r"s 2ia). 2tb). 21c)) . . . i ' (a) Tirade-in (DescrWlon Above) ...... . U. UU .. $-500 00 Total Down Payment Iltwns 2(d) and 2(s)I .. . .. i (2) ?- e. Unpaid Balance W Cash him (1 minus 2) ... ... i (3) AAmounts pant on your beMN Mader may be iMaln i, a portion of Me-- ener, u, To Public OMsfele ne, ae. & regk'traw for (1) N es i ro /RA (10 for tang Nos s Be-00 : Ole r« tax" (not in Caen Price) MIA 88 00 S . To insurance Companies for. NIA l newense .............. Credit Life it ... i__.Ny? i } M Cred N/R Insurance. ... .. .... . N/A .... _?x- .... s_-. . ..NIA ?9r y 1 ? RTI? s s - T _._? i T oo Wil 1 or? p/p ? i >f/8-0 Total... ... ... ....... T 0 ....... 3.x(4) i. Amount Financed (3 Dlus 4) .......... ....... i Ifl tlesNnnicT:,tris?wi YK?iB'? ANNUAL FINANCE Amount Total of Total Sole PERCENTAGE CHARGE Financed Payments Price RATE dqTTatcmta Ayrm u • YeedV The NOW arnmmt the C"Wk udl Wit you The emaae of Waal I kk d royoYaM your MMa Tea awnalnn you vIe have Dale MfNn WII here maW all ul e d scmd Tbe IoW aaw Of YWr Dumae enaMh. Including your 16.35 % J266.92 88.00 du n s i154.9Z 65d-9Z? Number of Amount of M WMn PavmaMs payngnt Sahagnlau? 69"' 2 eeil.be L`WI ma?.0ulMrig Your paPnnt amwaallr 1 anal t} 01/202g0] will be: PTOPaymant: II you W aft gene debt UAY, you Will W have to PRY a penalty. securer weem t: You are giving a security Im«ast in 1M vatkls being purcland. Con&am: Plata ses tills contract for additional Information on .avidly Inlanm, ecllaf? dMa a the dent to require rapaynNntl of your dam In IuY hales ens COMMERCIAL OR ACINCULYURAL U89 CONTRACTS: ti you purchased die which, for coerwrowdal ==rah Nenelat pry s W =590 m era ponces d eaab plPlaal raWNed men ft,, to ].& Wmea d ens W .OD, WMruer Y bee Any ahenp M k' m bact ma be In asking and signed by you and the Creditor. BUY" I Mail inSNt O-? s10NS,xc YFT- Do not sign Oft agreement Wfam You read it of N N contains my WIN* speue. You am entitled to an exact copy of the contract mart you sign. Buyer acknowledges receipt of a true end complsely filled In copy of this ccw,I?? at the a 1119, 4," K IN: ?v suf a. Wake (con ew« stsra ry atodns e.bw,m MlW axapNMaeone e r Iowp euwAbel bmnW Ina panale eeslpllwrd aladnep N OIN COrNeet, m 0Mpl} Nto usp e? ?aiii0i0Rt)Ff.i19R 0KC C _ INNINN, see aieGrL ern eawrewat Aaae?NTt PAfa 1Ta6a June Intents. rdNPe coq NdT M WM.) ? Persona ? CMnMrCW MAY OBTAIN VEHICLE INSURAN N A PERSON OF YOUR CHOICE. IL1TY INSURANCE COVERAGE F ILY INJURY AND PROPER AGE CAUSED TO OTHERS IS N CREDIT DISABILITY JNAL INSURANCE AND AGREE TO PAY ? Crum Lee N/A $ NIA N/A Insurer Premium NIA Insured(s) Signstum(s) Credit ? Dlssblity NIA NIA N/A imfraT 8 prarnium N/A Insured Signature NA NIA of Insurerica TOM Note III ?iRI-TA Premium Signature Credit LN end case Obeasty Insurance, are for m earn tla mm emend and Ivan. dimeod slmrn In •awfl npllpw apeatwtt g1YMm you today. You are M40IRW to Inure to ashide e a chap b ahean eaiaN, tna On nice, are by w buy iM esNeoaes dearied tar the term shown. corr. apaMN beeeanpntlweW WwM W llr ranmb aWa Wtae.bW not IllpretlV IbenWm pWey. ? Cmarawnha El MIA Dedaoebk' CORI ? FN?Tbe1lLandnal Ablebnel Cavere2a ? TaMlp Id Labor I] Term--N}p'-tuorwer (EdkrrN) Pnmam 1• GUESTIONS7 FINANCIAL SERVICeS PLEASE CALL US AT 1400446-M 87-007 ORIGNAL Gi.C.W+ws,r.. ADDITIONAL AGREEMENTS A. payments: You must make all laymerds when they am due. You may prepay your debt at any time without penalty. This Is a filtrate interest ="a. The sewl finance Charge you ayes to pay will depend on your payment patterns. The WNW finance.charge may eaosed the abscond Finance Charge h you male your payments War man the scheduled hate or In less than the ScMtluled and". Your paymam will be applied prat to tie earned and unpaid pat of the Finance Charge and den to to unpaid Atrmsd Financed. The Finance Charge is "mad by applying the Annual Percentage Rata o ma unpaid Amount Financed for the actual tma that the unpaid Amount Financed Is outMenang. 0. So lemY interest: You give the Creditor a acurlry Warren In: 1. The white and all pets or other goods pith m the vsNde; 2. All money or goods mwatved or the vehicle: and 3. All Insurance prerNune and Service contacts firm"d for you. This Serues paymam of all amounts you owe under this comrad. It also ,,ores your other agreements in mis Contract. C. UM of Vehicle - Wamnae: You must take Caro M the vahida, end obey all ewe In using it You may rot Set or rant the vehcle, and you must keep a free from the delms of offers. You will not ues or permit as use at the vehicle outside of the United Sssas, MOW or up to W days In Canada Or Mexico, without nor Prior wMen canoe of the Creditor. If the vehicle IS of • type namte9Y used for personal use and the Creditor, w the vehicle's m U M M, Mounds a written waraty or service cornet Oovw" the vehicle within 90 days from the deft of the contract. YOU Got implied watraldes of merchantability and Rtutsa for a particular purpose covering are vehicle. Olherwla. You und1m%MI and Sara that there are no such implied warnntla, MOW fie atarWa provided by etste law. 0. Insurance: You must insure yourself and the Creditor against tea w damage te the vehicle. The type and amount of Insurance must be approved by the Creditor, If des Credit obtains a %fund on Insurance or Service Contracts. the Creditor will Suavest me refund from whet you see. Whether w hot the vehoe Is Insured; you must pry for h If It Is IoM, damaged, or nlaeUyed. F. Default: You will be In defeutt IF. 1. You do not melro a payment when It Is due; or 2. You gave false or mleeadng Informebon on your =0 application releWlg to YW CWSrwt Of 3. Your vehicle is ended by any IeW, cafe, or femoral - authorky and is not pmmp*Iaiet?alcaldlgviefa/ Msrad to You: or a. You et S bankruptcy Palion Of one is food SgAmd You; or S. You do not keep any odor Worries In this keened. _ It you default, the Creditor may require you 10 pay at once the uapae Amount Financed. the eared and unpaid pin of fie Fiance Charge. and all other amounts due under as contract. He may mPo (take back) the vehicle, too. He tray also lake goods found In the vehicle when repoaaescao and hold them for you t the vehicle is Won tack, he will sera you a notice. The notice will say that you may redeem (buy beck) On vehld6. h will ale Mow the amount needed to reclean. You may nedism to vehksa up So the ant the Cedhw ash h or agrees to sell ft. If you do nor redeem the vehicle. It we Word. The moray from fie sale, lea the Slowed ermenew, will be used 10 Pay the amount 3011 owed m this CaaadL Allowed eiop Ars those pad as a direct result or hMng to retake the vehicle, hold ft. probers ft for sale. and Nt h. Lawyers' Sam and legal cope permitted by law are slowed. too. If tlere is A" money left (a awplw), h will be pad to you. t the money from the ale is not enough to pay off this Contract and costa, you wg pay whet IS 80 owed to de, Cradtor, if aimed by law. It you do rot pay Iles amount when sew Cmdltor ache, to Creditor may charge you interest at Ue highest lawful fie until you pay. 0. GereM: To Contact PRIMUS Piratical Services abase this account call-l-(800) 9458000. The low of Oklahoma applies to this Contract. If that law does rot Slow all of the agreements In tits oonbad, the mss that we not allowed eel be void. The root of Me contact will Mil be good. 0 a canoe for vehicle Insurance is shown on the from, the Creditor will by to buy the coverages Chat ed for arm shown. The Creditor is not Itble. though, If he Cannot do W. li these Coverages odd moue than the amount Shown or Insurance, the Creditor may buy alum or a shorter arm or he may gin you credit for the arum shown. If he arnot buy any insurance, he will give you Credit for the amount shown. The oradit will be made to the last payment tla. E. Late Charge: You must pay any cost pad by the Creditor to collect any into payment, all allowed by law. Acceptance of IS late peynwd doe not esdae your deeun or man mat you tan keep making payments after they are due. If you purchased the vehlde for commendal or epfwltural use, you will hew to pay the lass charge shown m Me from, m the portion d each payment received mom than hen days late. The Creditor may take the 81604 at fall in INS contract If there Is any detut. NOTICE- ANY HOLDER OF THIS CONSUMER CREW CONTRACT 14 SUNMECFTO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR MATH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.' Used Motor Vehle(p Buyers Guide. It you are buying a used vehicle with this contract, federal regulations may require a speClal Buyers Guide to be displayed on the window of the vehicle. THE INFORMATION YOU SEE ON THE WINDOW FORM. FOR THIS VEHICLE 18 PART OF TRW CONTRACT. INFORMATION ON THE WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE. Oat nwit"M a mwahessd for aneardah or awkWheM use. in that rtes, you (Motor) will not aserl "Win ary =Maw fir "wallows near Mrole Canaltryalekme,aquaeer setter do iwawy taws pant hie ear or manulecuoer of the vehicle. GUARANTY To cause the Sean to sell the vehicle described on the front of this Contract to the Beer, on cradil, each person who signs below a a'rxlaadoP puerameas to payment of Nls contract The mans that d the Buyer falls to M, arty moray that s oaed an this contract each oM who slain tl a puerarmw will pay it when asked. Eeeh peson orb si0n belowgees mat we Wye.tor sew walla anent area ever a we or mors other pereora quo si0a iNe cuaarty. Fis also aoreea o be liable ever if the Creditor does ore or more of the folowi is (a) ghee the Buyer from arts e oar Ore w rroro payments, w Its/ Mwee a robes lo film w b pet p of tre other Ouoradwa w (c) ndb try wormy. E=h GuaarM also Seta that he has received a connected copy of this contact ertl this Guaranty at We time of elgrwhg.. Guarmor(3) must sign each spa sePwvAti. Guener Address Ownrar Address PAFS 1783 w Jvn 09 (PreNda seeds Tay NOT a useal ^PRN^ PRIMUS Financial Savicso P.O. Bolt 680D80 FRANKLIN, TN 370684090 (800) 374.7000 MICHAEL P. FRANKS REAR UNIT AS 726W COOVER ST MECHANICSBURG, PA 17055 DMo(Rpnussbn 014621105 Deo0 NoI ownd Cawed 01-062005 12-062000 AccauntNumber. 025104485 MICHAELP. FRANKS Cobu LYN MANHIRE DESCRIPTION OF PROPERTY Yoe MW ? New 1899 HYUN ?" Used vehicle Identification Numbr: KMHVD34N1XU49M2 Mode ACCENT Body NOTICE OF OUR PLAN TO SELL PROPERTY We hew your Property described ahere because you booke prop isu in our "onrtt Q PRWATE SALE: Wswiti wtt)opmpNydredbed ebowat pdrds sell somsarm after 15 dapf mdse oesd Notes shown above unlrs redeeard by you pd. to such sols. ? PUBLIC SALE: We wa slith. prprrydrerlbW•bos 0 public axisbtohighnlbiddera the dab below (or cry sdicuwx w do%). Thews will behold r folows: Deb of ask Time of asps pscedish You mry •ibrM the sale end bing bbdrs If you wart, The money that we get from the sale (after paying our costs, including reasonable attorneys fees and legal expenses H 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. You can get the properly 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 went 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 eobuyer 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: MANHEIM AA 1190 HOW TO GET YOUR PROPERTY SACK To gst you PMWty back, PRY w this an 0unt by certified check or money ado before tr whkle Is sold. Unpaid Balance $ 4.01 Plus Coats: Rape Expenses $ S $ Pbe(ab Chrnr $ Los Flnews Chase Rebalo $ lsa {manna pnnium Rebee $ TOTAL $ 4,80521 (Plus opr inured If dshuk a to ens of rpoesreon ocrded 13 clefs sW lea rebto rsWwd albr twdab d thisnodes,) Your PMPWV mlWaddud 15drysafartwdaledMb Mkso the EARLIEST.ARrtha ou ansM gth tackany8me blfcoe We actually odd. If you do, "I hM. furptr Balm on It But to longer you wall, the moo cabcushi ripen) you nay hswb pry. N you Fuw " ay Rlastlom abed fie, plsme all w. ? Tb prpprlyhe best (a vAll b•) ralumed kx (dwalalgkal aoddor) Under our aenafent with your doerloAglne coeditor. do dour/odgind aadhor Is to sell tla pmpaty and pay you " npnsy be o .Hyou owe moray aim the wa you will pay 0 b the drlryodgiw creator. ? PERSONAL PROPERTY: Any prsmY proprtytouW In Ws while mry W MWmed by you whhln M rand 60 days r, In pcadraw8h ebb low, by contacting this duce Thereaftr, the persona prop" shall be disposed of accordingly. ? cndxr tw aosgnedbw RVetledlnbmw.y(on Eadw?ga.LLC)rodvme tlxd rid n, odgalkm)wfu, nalsalbtl•w.dpch wnkle haled ebova PAYMENTS: NI paI bus coal be by cadl0ed dW-kor rnonry under. MI LEAGE DISCLOSURE If you as sere dal the milep ralleded on the ohkleicoo, ab Is nut rsursb for any noon, Plane contact a so that wo ran su uraWy spat the whkJeY Hlopa INSURANCE RIGHTS; Hyou tbnYwrdbgal your psprty hark call murbKSeomprry aria dwwyalplrW aedibrb nuke euntlutsy imusc• M been Isd. You hew. dght b gal cndft fr all prenrl refunds. PATWCIA MCHFORD srNw trvrmv.n aer,.nw..emem mywoia w.a. CUSTOMI MUSTOhER ftLE tmw4muaw. .PRN.. PRIMUS Flnsncial SoMbea P.O. Ban 680090 FRANKLIN, TN 370860000 (800) 3747000 LYN MANHIRE REAR UNIT Ae 225 W CGOVER ST MECHANICSBURG, PA 17055 Odad Rpesseselon 0145-2005 Das,d NWN Dan of CanMtct 01-&2005 12-08-20W AccwM Number. 025804485 MICHAEL P. FRANKS Cdbuysr LYN MANHIRE DESCRIPTION OF PROPERTY Yesr Melt ? New 1988 HYUN ?' UW Voids IdntlBcetlm Number, IWHVD34NIXU493M Model ACCENT Botly NOTICE OF OUR PLAN TO SELL PROPERTY We have ynur property deac nine- Wove bacameee you brat s promieeae in our agnenant. ?ee PRWAM aver c: We vAll sdl the pmWtydmcdW dxha d ? eel nN Wr16dey w Oded Ndlu e1NM1 abbeunleea f?1Wrls!byyou yNp dor100Vd10aR The money that we get from the sale (after paying OUT 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, untess we must pay it to someone else. You can get the property back at any time before we sell K 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, w 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 me 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. The property Is presently stored at: MAHHEIM AA 1190 HOW TO GET YOUR PROPERTY BACK To Beef ycur pmprty back, pates Ws an aunt by ce hied d,* a many and. Mae s e vehkAe Is add. Unpaid Balance $ 4.805.21 Plus Costs: Repo Earo.rses $ a a Plus Las, Chaves $ Los Finance Ch" Rabdee S Wee bawanu Prrrium Rabat, $ TOTAL S 4,805.21 (pNS rpmesa Ir dumat r d"It r time Ow of ryaeessbn .eesdsd 15 days and Ises rebate wcdyad after trades, of Inks n(fecr) YN pmpalywcnY ba sold unit 15 drys err the deb r this notics at tbe EARLIEST. After the yid can WII gat It back wy8ms balob Its ectuay add. If you do, war have w fwthr daimon It But the long. yw wo. V. maee ceste (Including npak*) you may have In pay. If Y. have any Wave" dxrt oft, plaesee call us. U The aapoty, has been (a will be) nbuneed b: dedadaima aedlbr) UM.4 w t pay It your the der/alplrnel rntlaa, g dWa/alplrW cndlbrb s, W the piOprtyrd pry you fry ngny Wit aver. /yw vAa many cur when aft 120 was, w you you we pry b 120 dedr/odginY aedHO.. ? PERSONAL PROPERTY: Any prswd prpetyfound In the vehicle may be rsch ms i byyw within Ibe need ro data a, in acwrdala wM ebb Iwv, by contadirg We once. Thwes W, lbe panwd WoWlyshdl be ds,paed a ed:prdbgly. ? Cnedra has asstired b ft We88ed m1amnadiry t(A F.uMgs.LLC) he dpnb tM rid ra lxAigab") with respect b the We d exh vehkb hand sbms. PAYMENTS: Allpawr bwnwstteabycrWbdcrackan werdr. MILEAGE DISCLOSURE If you an wrr+thd dr minspee rdlecbd an 8r tshkb's otlwMrbrM accurrifa snyraesm, plsew canbctw so Mdw er,a nsWyrpW the wNkles rrilepw INSURANCE RIGHTS: Hyw tlmrvveMbpd ywrproprly beck, dllheelmuMncapesya Nee dsdrlalglnY aedrorn make sun tlrM anylesurence hes beean cancelled. Yam have a right b gel credit for M premium refunts. PATRICIA LITCHFORD nnu I+bear.I MPn.w eewo. ffl wrIe u..a. CUSTOAEIVOMTONER FILE R wd In ulA. Yw may stand! dw sAeasl bop bidders a you weer PRIMUS Financial Services 9009 CAROTHERS PARKWAY FRANKLIN TN 37067 800 3747000 DATE: 2005-02-23 POILN500DO0213 MICHAEL P. FRANKS REAR UNIT A9 225 W COOVER ST MECHANICSBURG PA 17055 LYN MANHIRE REAR UNIT A9 225 W COOVER ST MECHANICSBURG PA 17055 STATEMENT OF SALE Account Number: 025804485 The following property has been sold. Year Make Model Vehicle Identification Number: 1999 HYUN ACCENT KMHVD34N1XU493932 Balance owing on your contract (1) $ 4,805.21 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 4,805.21 Deduct: gross proceeds of the sale (4) $ 900.00 Balance less grass proceeds of the sale (3 - 4) (5) $ 3,905.21 Add: Expenses of retaking and storing, and (6) $ 348,00 any attorneys' fees alloWed by law, and expenses of reconditioning and selling. (7) $ --- -----0,Q0 Deduct: Insurance Premium Rebate (8) $ 0.00 Other: (9) $ _ 4253.21 Deficiency" Surplus' (10) $ N/A The SurpluslDeficiency 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: Mail deficiency payment to: PRIMUS Financial Services PRIMUS Financial Services P.O. BOX 6508 P.O. BOX 55000 MESA ARIZONA 852165508 DEPT. 194501 (877) 492-2865 DETROIT MI 48255-1945 FFNA11M 01/04PIe OMeditionsmar NOTM, . PRIMUS Financial Services 9009 CAROTHERS PARKWAY FRANKLIN TN 37067 600 3747000 DATE: 2005-02-23 POlLN5000W214 LYN MANHIRE REAR UNIT A9 225 W COOVER ST MECHANICSBURG PA 17055 MICHAEL P. FRANKS REAR UNIT A9 225 W COOVER ST MECHANICSBURG PA 17055 STATEMENT OF SALE Account Number: 025804485 The following property has been sold. Year Make Model Vehicle Identification Number: 1999 HYUN ACCENT KMHVD34N1XU493932 Balance owing on your contract (1) $ 4,805.21 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 4.805.21 Deduct: gross proceeds of the sale (4) $ 900.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 3.905.21 Add: Expenses of retaking and storing, and (6) $ 348.00 any attomeys' fees allowed by law, and expenses of reconditioning and selling. (7) $ 0 00 Deduct: Insurance Premium Rebate (8) $ 0.00 Other: (9) $! 4253.21 Deficiency" Surplus" (10) $ N/A The SurpluslDeficiency 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: PRIMUS Financial Services PRIMUS Financial Services P.O. BOX 6508 P.O. BOX 55000 MESA ARIZONA 85218.6508 DEPT. 194501 (877) 492-2865 DETROIT MI 48255-1945 FFNA11M 01/01 R.M.. W,ibns may NOT M uu , U-z Vl CASE NC: 2005-06330 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRIMUS FINANCIAL SERVICES VS FRANKS MICHAEL P ET AL TIMOTHY REITZ Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FRANKS MICHAEL P the DEFENDANT , at 2048:00 HOURS, on the 21st day of December , 2005 at 225 W COOVER STREET REAR UNIT A9 MECHANICSBURG, PA 17055 by handing to MICHAEL P FRANKS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. SHERIFF'S RETURN - REGULAR Sheriff or Deputy Sheriff of Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 So Answers: 9.60 ,. .00 10.00 R. Thomas Kline no Sworn and Subscribed to before me this _ day of dA.D. P r of y 12/22/2005 MAURICE & NEEDLEMAN By: --7-, /l Dep ty Sheriff SHERIFF'S RETURN - REGULAR i CASE NO: 2005-06330 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRIMUS FINANCIAL SERVICES VS FRANKS MICHAEL P ET AL CPL. TIMOTHY RETIZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MANHIRE LYN DEFENDANT the at 2048:00 HOURS, on the 21st day of December , 2005 at 225 W COOVER STREET REAR UNIT A9 MECHANICSBURG, PA 17055 by handing to MICHAEL P FRANKS, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE i 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 /jw day of So Answers: R. Thomas Kline 12/22/2005 MAURICE & NEEDLEMAN By: Depu Sheriff 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 (21J)/My /I)I PRIMUS FINANCIAL SERVICES Plaintiff V. MICHAEL P FRANKS LYN MANHIRE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. OS-6330 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the verification of the Plaintiff, Primus Financial Services, for that of the verification previously filed. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. Date: ?5 A 0 ., 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 Primus Financial Services, to be served by regular, first class mail, postage pre-paid upon: MTCHAEL P FRANKS Rear Unit A9 225 W Coover St Mechanicsburg, Pa 17055 LYN MANHIRE Rear Unit A9 225 W Coover St Mechanicsburg, Pa 17055 Respectfully Submitted, MAVRLCsE & NEEDLEMAN, P.C. BY: Esquire Attorney for DATED: l/ ?? VERIFICATION i q , C-lltti c ???? verify that I am the Authorized Representative for Plaintiff, Primus Financial Services, 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: 1 MICHAEL P FRANKS LYN MANHIRE Our file no. 2388 48043000000025804485 _, c? ' . A ?.:, v c.` _. °< Curtis R. Long Prothonotary office of the Protbonotarp (fumberranb Cauntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor jOS CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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