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Home My WebLink About06-0556ARBITRATION 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 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. WENDY A LORENZ 449 Woodcrest Dr Mechanicsburg, Pa 17050 NOTICE You have been sued in court . If you wish to defend against the claims set forth in the following pages, you must lake action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally ar by attorney and fling in writing with the court your defenses or objections to the claims set forth against you. You are warned that ifyou 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 nghts important to you. Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 0(0 - .55(o G LC CIVIL ACTION COMPLAINT AVISO Le hall demandado a as'tcd en la carte. Si usted Solely defenderse the estas demandas expuestas en has pagmas siguientes, listed bent vcinle (20) dial de plazo al par-or de la ferha do la demanda y la notifieaeion. Hace falta asentar una comparencia escrita o en persona o can on abogado y entregar a la carte en forma escrita sus defenses o sus objeciones a has demandas en contra de so persona. Sea avisado que si usted no se defiende, la torte tomara medidas y pacific conlinuar la demanda en earn suya sin previo avis'o o notificimion. Adernas, la carte puede decidir a favor del demandante y requiem que usted cumpha con Indus has provisiones the esta demanda. Usted puede pcrder dinern o sus propiedades u otms derechos importanles para usted. LL EVE ESTA DEM.ANDA A UN ABOGADOIMMEDIATAMEN T F.. SI NO I IBNE ABOGADO O St NO TIENE ELDINESO SUFICIFNTE DE PAGAR TAI. SF.R V ICO, VAYA EN PERSONA O FLAME POR TELEFONO A LA OFICINA CIJYA DIRECCION SE ENCL'ENTRA ESCRITA ABAJO PARA AVERIGL'AR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. YOII SHOULD TAKE' PHIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE .A I AWYER OR CANNOT AFFORD ONE, GO TO OR 'I hLEPHONE THE OFFICE SET FORTI I BELOW TO FIND OUI 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 ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. W ENDY A LORENZ 449 Woodcrest Dr Mechanicsburg, Pa 17050 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. Q(. - 5SL el 14z CIVIL ACTION COMPLAINT I . Plaintiff, Ford Motor Credit Company, is a Corporation with its place of business at P.O. Box 6508 Mesa, Az 85216-6508. 2. Defendant, Wendy A Lorenz, is an individual who resides at 449 Woodcrest Dr Mechanicsburg, Pa 17050. 3. At all times relevant, the Plaintiff was in the business of loaning money on motor vehicle installment sales contracts, including but not limited to the note signed by Defendant(s), hereinafter more fully described. 4. On or about May 5, 2004, 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 $21,530.50 at an annual percentage rate of 21.000%, in order to purchase a certain motor vehicle, 2000 Ford Expedition more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A. 5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $582.47 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 6. Defendant(s) made monthly payments until 2/9/05, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 7. As a result of the default by Defendant(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. 8. 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 $12400.00, however a balance of $10532.12 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. 9. 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. 10. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to $1108.90 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $11641.02. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $11641.02, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. P.C. THOi rAS R. DnkMINCZy'K, ESQUIRE Attorney for Plaintiff VERIFICATION I, THOMAS R. DOMINCZYK, ESQUIRE, verify that lain 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. ARE DATED: December 8, 2005 05/05/04 PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE I4W r lao wNrY•n Nam ea Atlaau nKealrN cmntr.m as cm.) CREIIITDR (etll. la.m. ra Aee.Nl 11AY 2 0 20gq NENDYA LORENZ L B SMITH FORD INC I WOUND PA 17055 RgYMARKET STREET PA 17017-1654 Y«L tlw eweleatYanwr,tlaeYl raieW mavMKe etewllee eawrerwN aeeL lne'OxrPb'•MN Mbwbe. a+nrAeaa.+au.r TN ToW 44 Mo'rma•Wbe YIMVW Coca. eY WrW Me svreat l.rawwbwrY eneMn ubwrM 9Nmrr•mIM MnIW WYaab asne•a NbaNH, YeEr m/ M m Y Hd f Mao USED PORD EXPEDITI 1B@tDE.9Y[J08322? Q P°°a ?up1cevl ? cmmraY INSURANCE Tna.b s t'Y1t a WA YOU MAY OBTAIN VEHICLE INSURANCE very ura Cop amb Ab.•ia• Knew OnMp li ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE 23BOD. y. CaeN Ptlw........ ...._ .... ............ ....... _......... ........... _......._..._............ 5 00 YOU ARE NOT REQUIRED TO OBTAIN (fl CREDIT LIFE. CREDIT DISABILRY AND 2. Co. P.,mint OTHER OPTIONAL INSURANCE. THIS "Inn PerM RaMe Maam i to CWUKor............_....... _...... E WA CONTRACT WALL NOT INCLUDE THEM Cesb bourn Poylmm ................. ...., a W UNLESS YOU SIGN AND AGREE TO PAY ......._......1YA ?1? TnOFIn _. . .... .. .. S S E THE PREMIUM. r.mnuw om bo.mn. ,inn owe Tool Down PaymrU..,_ E (2) THIS CONTRACT DOES NOT INCLUDE DO" INBIL INSURANCE COVERAGE FDA Unpaid A. Arnou Bakinim of Cash Prim (1 womu 2) ........................... _. $ Of (3) BODILY Y INJURY AND PROPERTY RTY 4. IMnourwa "W polo o on your ur MM1Yf (Selby my M WUlnlm • pertlon of maN emaulW) DAMAGE CAUSEO AUSED TO OTHERS. To Croon LCompanbe for M lmu nnca (for W. of contract) corm...)............ a Nn NA 1 Dmdd LWtle OINMIKy Ineureme (for term 0 d cwaWd) ............. T Nem w IEebnelell E? . ' To Publk INapbb (i IKemo is --- 1L R1 IMe (T 31 . 8 ? Credit Lila "Wrat. (a ) 1v Insurer (11) for 110,11 14M; $ _IUA pip for Imes (nd In Cesn Prke) B 1428.00 a 105.50 Prsmlum Insuratl(s) To for E wk _ To f0Ufor_ S_? Signatwe Tomfor?_ S i Te for S? Cntlif 1530.50 !. Aneoum Fmemetl 3 u 4 .........._ ...................._.__.____..._. f z193D, 50 insurer $ " Insured FEDERAL TRUTHaNJ.ENDINO DISCLOSURES P WA ANNUAL FINANCE Amount Total of Total Seta PERCENTAOE CHARGE Fln ern 'd Paymama Signature Pa,s RATE m. eetle.raw r n.11 To Nwm the fowl oaf LM wr d Ywr w etl, hill IeoMO.O a You all Iww al yo« nrruoa on Y. p•b w w .aK ? <reei se a yYrlY nl• mI Yre Mnpy Ib. rrrey Y inolorrm Yon •asytl Ors, Optional Imuranu Tenn em"ormni P•Ym.w ors-ypag E n nn % i Insurer Premm- Pryeem SoheOUb Bu elr of Ameunl N Ewl, wMn Peymela ne re ?)PSYKalb PayIIINt an tlw Cnal UN •M OWN PIWgN laamur«p •n Your Paymml smeEMe 59 S 5B. 47 (nKntNy Pe2npl far tlne Wn of e• mrtax 1T• • a «a will M: t Pouf 5 82.47 .T„ = 2 CA Plw?ir m .rou b0. b a Mlw w prwrmm You mw1 we. ae Rolee If • onep• b seen Mloe a QeKMr inn by to Wry err e diectae nor as tam Mown. wnpu Mtl tl? w m a mo enw a ie Y• i a l B e I .- m aw i ee I'm a d e• pony. PWwvro•nt: It You Ny on Your NM NM. You M, WK few a wY a peWly. ? Co^rprawmrva ? E Lab Prynwm: You mW my a Be clot a on IM wroon of Nm NY•KKK rooo w moW Ctlerbn Own 10 days We. 71wi d,&W b 2 percent a our We emnure or Mom wNCbewr le lee. ? In a TMIICwnplwtl Aewtlnml Cow Seowlty Indeed: You ere pivbp • Nuorly yrleyaal b tlw yaya• Min, pumMNU. ? Tmon, mu 1.Mr Conical: Plow see IM1b awMa tar aOOllbnel Inlwmabn an e•wnty In1«eel. npbeYmenl aelaW nt b re in re Ow O a on debt in full babe tlw «b•e ment of tW D b A O ? T.- Lw Yw (EStlm•w) - / n . m p y y u . n a O pmpa meW pW Y. fj yy Pnm4m s MY Wm• b p •An rnltlnp •M Wino by You W fire CrNew. BUYEN: u?IYER: x SaiN4 YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO BE BOUND BYY THE ARBITRATION PROVISION ON THE REVERSE SIDE OF THIS CC ONTA A CT. NOTICE TO BUYER Do not sign this contract In blank. You Oro entitled to an exact copy of the Contract you sign. Keep ft to protect your legal rights. Buyer (end Co-Buyer) acknowledge that (1) before el nln this contra ct, or and Co-Buyer) recelvetl an rata EAS O rue an Completely filled in copy of this contract and (11) at the time of si nin this contract. Buyer (and Co Buyer) rac-ervia a true qp p e a y filled l'n copy of this contract. e moli%)xa j ( eVYEa Bowe ay apnlra e•1•e. N•a•wr NGpl•wb c•nbst ma 4 in wNWb aa•INmea •e4eM N tlM axmaL On BNIw • b Y C ®C O 9Q1M l01O SEC ev nN wmraa, ?G•br ofwabtle, WW« Aelleaum (Oa tl Nr M. b tlr•dM yw ft. 'ara K1 • Swirl walabn weber. Pedes• a the oreW, 6 b ePawwl xq B M nWbO acMan eM01.1Te Ymw and nltllon a N Mp rMNIYYm w•Mr an N In Mn N •e•nJnM MEwden nWA b bimW WYA erNMWr M Be eontrtl. TM dM W rw nto sNbTa1 1W oa n 1, a Amew IWnMti a ibevtl Coca sawn, e. w.mraiua rvMna•meinrNUal SEE BACK MR ADMnONAL Program No. QUESTIONS? ROF PLEASE CALL US AT 1-800.727.7000 p 1 VINE era et www.loNwedlLwm p30H ORIGINAL ^PRN"' Ford Motor Credit Company P.O. Box 3078 COLUMBIA, MD21045b076 (800) 67 4730 P0IZGXXOXp39 WENDYA. LORENZ 449 WOODCREST DR MECHANICSBURG PA 17050 Dale of Repnaseasi. 0421-2005 Dale of Notice Date of Contract 0422-2005 0541S2004 Account NUmbec 037029552 Buyer WENDYA. LORENZ Cobu r DE SCRIPTION OF PROPERTY Veer 20W Make FORD ? New ?] Used Vehicle Identification Number: 1 FMPUmI9YLA08322 Modet EXPECT Bad 40R NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you Woke promises in our agreement. PRNATE SALE: We ark eell the property dewdWd suavest L 5F] private sae, sometime after 15 days from the bate of Notice shown stow a ikni mtleemad by you poor to such sale. PUBLIC SALE: We will sell the property alleviated above at public sale to the highest bidder on are data below (or any aCpumment dale). The uk will be held as follows: Data of Sala Tyne of Safe PMea of Sale You may atlen4 the sale and bring bidders if you want. NOTICE OF REPOSSESSION The property is presently stored at. _BEN RECOVERY ETTERS PA The money that we gel from the Sale (after paying our costs, HOW TO GET YOUR PROPERTY BACK including reasonable attorney's fees and legal expenses if 1To get Your property back, pay us this amount by cartlWd check or permitted by law) will reduce the amount you owe. If we get money order before the vehicle Is sad. less money than you owe, you will still owe us the difference. If Unpaid Balance $ 22,320.01 we get more money than you owe, you will get the extra money, Plus Costs Remo Expenses $ 360.00 unless we must pay it to someone else. , $ You can get the property back at any time before we sell it by Plus Leta charges $ 27 as paying us the full amount you owe (not just the past due Lass Finance Charge Rebels $ payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the Lass insurance Premium Rebate $ exact amount you must pay, call us at the telephone number . TOTAL $ 22,707e7 above. If you need more information about the sale call us at the (Plus expenses incurred If default ache time or repossessor exceeded telephone number above, or write us at the address above. 15 days add lava rebels received after the date of this malice.) Your property want W said until 16 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 that you can Will get it backanytime before We the amount that you owe us, you may call us at the telephone actually wad, number above, or write us at the address above and request a If you do, we'll have no further claim on n. But the koger you war, the written explanation. more costs (including repairs) you may have to pay. It you have any quest,.. about this, please tell w. 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 dealedoriginal creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. ? The property he. been (or will W) returned to (distending creaiton Under our agreement astil your tlealerlorlon ore redit the 0ealar/original credher is to sal the Property and pay you any money left war. If yvu over nwney after the sale, you MII pay pay it to the dealerniginal creditor, PERSONAL PROPERTY: Any perwnalpropertyfwrM in the vehicle may be reclaimed by you within the next 60 days cir naccordancewithstalekw toy contacting this office. Thereafter, the personal property shall be des oead of accordingly. ? Creator has assigned to its qualified Plem mdery (01 Exchange, LLC) Its rights (but not its oblgabons) with respect to the sale of each vehicle listed above PAYMENTS: All payments to us must be by cart,fletl check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer Is hot accurate for any reason, please contact us w that we can accurately report the vehicle's mileage. INSURANCE RIGHTS'. If you don't want to get your property tech, call the insurance company or me dealetloo inal creditor to make sure that any insurance has been cancelled. You have a right to get crest for all premium refunds. JESSICA A. SNYDER FiR4 twee-av fan ox Frewoua e4rtsos mew aoi I» uw CUSTOMER/CUSTOMER FILE Printed,, asn. Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 21045-6076 800 6770730 DATE: 2005-06-DS P02eVM00000085 WENDY A. LORENZ 449 WOODCREST DR MECHANICSBURG PA 17050 STATEMENT OF SALE Account Number: 037029552 The following property has been sold. Year Make Model Vehicle Identification Number: 2000 FORD EXPEDT 1FMPU18L9YLA08322 Balance owing on your contract (1) $ 22,347.87 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 22.34T 7 Deduct: gross proceeds of the sale (4) $ 12 4? D0.00- Balance less gross proceeds of the sale (3 - 4) (5) $ _ _9,947 87 Add: Expenses of retaking and storing, and (5) $ 58425 any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ _ 0.00 (8) $ 0.00 Other: (9) $ 10532.12 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: 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 (8D0)732-2264 DETROIT MI 48255-1941 FFNA1I no 01104 Previous etli4one may NOT se usetl. Lrl kZ uz ? s W ZZ EJ? i ) ov) - 11 ? SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00556 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS LORENZ A WENDY 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 LORENZ WENDY A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , LORENZ WENDY A 449 WOODCREST DRIVE MECHANICSBURG. PA 17050 449 WOODCREST IS VACANT. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. Sheriff's Costs: So answers,- ! --? Docketing 18.00 Service 8.80 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 41.80 MAURICE & NEEDLEMAN 02/08/2006 Sworn and subscribed to before me this /y? day of .2oc(? A. D. Pr cno- a 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. CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-556 WENDY A LORENZ 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. THOMAS D INCZYK ESQ Attorney for Plaintiff Date: 3 ? b &? 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: WENDY A LORENZ 449 Woodcrest Dr Mechanicsburg, Pa 17050 Respectfully Submitted, P.C. DATED: 3 r? b v U Attorney for Ylamthtt I VERIFICATION h mina L. Johnson 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 unsworn falsification to authorities. BY: DATE: FEB 0 S 2006 WENDY A LORENZ Our file no. 2588 48063000000037029552 .? ,, r:, = ? >= : :? ?; r:, ,..ry - :;? ?. 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 (lio) issy-/131 FORD MOTOR CREDIT COMP Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-556 WENDY A LORENZ Defendant(s). PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the attached Complaint originally filed with the Court on 01/26/2006. MAURICE & N XDLEMAN, P.C. BY: ESQ. Attorney for Date: March 30, 2006 DATED: 7? Z; "Z ND SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00556 P , COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS LORENZ A WENDY 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 LORENZ WENDY A but was unable to locate Her in his bailiwick COMPLAINT & NOTICE , He therefore returns the the within named DEFENDANT , LORENZ WENDY A NOT FOUND , as to 135 SIMMONS ROAD MECHANICSBURG, PA 17055 PER LANDLORD. DEFENDANT MOVED OUT OVER A YEAR AGO. Sheriff's Costs: Docketing 18.00 Service 8.80 Not Found 5.00 Surcharge 10.00 .00 41.80 - So answers- R. Thomas Kline Sheriff of Cumberland County MAURICE & NEEDLEMAN 05/09/2006 Sworn and subscribed to before me this - day of D c>1 06 D. ss9zrq Prot onotar 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 (215) 789-7154 FORD MOTOR CREDIT COMPANY Plaintiff, V. WENDY A LORENZ Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-556 PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the attached Complaint originally filed with the Court on 01/26/2006. ESQ. Date: September 14, 2006 J c =- G r ; a ARBITRATION 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 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. 1: WENDY A LORENZ 449 Woodcrest Dr Mechanicsburg, Pa 17050 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fait 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. O• - r.: CIVIL ACTION COMPLAINT AVISO Le han demandado a usted en la torte. Si usted quiere defenderse " de estas demandas expuestas en ]as paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de Is. demands y la notificacion. Hace falta asentar una comparencia escrita o en persona o run un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defrende, la Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, Ia torte puede decidir a favor del demandante y requiere clue usted cumpla con todas las provisions de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. 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. 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 :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 (215) 789-7151 ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. WENDY A LORENZ 449 Woodcrest Dr Mechanicsburg, Pa 17050 Defendant(s). Case No. CUMBERLAND COUNTY COURT OF COMMON PLEAS 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, Wendy A Lorenz, is an individual who resides at 449 Woodcrest Dr Mechanicsburg, Pa 17050. 3. At all times relevant, the Plaintiff was in the business of loaning money on motor vehicle installment sales contracts, including but not limited to the note signed by Defendant(s), hereinafter more fully described. 4. On or about May 5, 2004, 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 $21,530.50 at an annual percentage rate of 21.000%, in order to purchase a certain motor vehicle, 2000 Ford Expedition more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A. 5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $582.47 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 6. Defendant(s) made monthly payments until 2/9/05, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 7. As a result of the default by Defendant(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. 8. 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 $12400.00, however a balance of $10532.12 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. 9. 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. 10. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to $1108.90 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $11641.02. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $11641.02, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. , P.C. THOMAS R. DM IINCZYK, ESQUIRE Attorney for Plaintiff VERIFICATION I, THOMAS R. DOMINCZYK, ESQUIRE, verify that I am the Attorney of record for Plaintiff, FORD MOTOR CREDIT COMPANY, and duly authorized to make this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. B ARE DATED: December 8, 2005 ---- r o?o5?ot PMOnVANA SIMPLE NRERE3T VEHICLE RETAIL INSTALMENT CONTRACT DATE OtVam (••? m•ar? qa.a and Aamtte.. is i Caw•f amend ap atnRnORpwnN?. N.?c .e.leA*bo* AN a 12MI PA 17055 / L?SIIiO?YME ?E6 PA 17043-1654 r•r??w?Iw?+Law,e•+A.awwrwevrrrwatretwwrr«Mrwwa 1M ?aMtMu'M.eewwlr0.wwl.r.•rtlwwda tl. -nwrwrrw..tr•.rr.w.w er+tr+v••.•••e•.r••w.wr..r••www.r••Se...r..r.tw.lwtw?erw..•.w.t. USED l AD E%PEDITI lEItP(II4.8ttNI0B322e O pw•wr DAVreed D Cww.edd I Try INSURANCE I" a f WA Vw all Uwe Omvaa Albwawr Anew O.tn YOU MAY OBTAIN VEHICLE INSURANCE ffEMITATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE =3B0O, 00 YOU ARE NOT REOUWED TO OBTAIN t. Cash Ma....»._.».-.»»,....._..._..,» ..............._»..._»....._._.._........_ i (1) CREDIT LIFE. CREDIT DWABN.ITY AND 2. Down Paymero !VA OTHER OPTIONAL INSURANCE. THIS ltdrd PaM Rabet• Assigned to Cnonor_...»...._.»...».._, 3 _3SM-.W CONTRACT WILL NOT INCLUDE THt7A Coon Down t UNLESS YOU SIGN AND AGREE TO PAY TmrM-W $ ? ?,$ ..._.. .,.. S--1w- THE PREMIUM. 0-wa.we w o.a CONTRACT DOER NOT INCLUDE Toth Down Psyrnelt .„.....»... »_.»..._....».._....._.....__.._.»._. f 3900' 00 THIS i=) THIS CLIABILITY TRACT DOE NOT IN COVERAGE FOR i. Unpaid BaYnd of Cash Price (1 minor 2)„.._.,.. BODILY INJURY AND PROPERTY 4. AmwawN FMd on Tow b"t (fidlar may be rgWA" a portion W thew onour") DAMAGE CAUSED TO OTHERS. To lnaunna comprw" for N/A Cf"h LKe human" por awn of c*mrwq .:.__....._ . _ i CredR DteabMKy Insurance {for term of i NIA f H& To PuMr OBlorr (IL (aI1100 IT tleeE (l :&so m, e O Credit Life rte solown (I I'VA ) as i I S- Insurer (N) for long 10" t W 1428.00 1475.50 Pranlun Insured(s) (IN) for tans (nd M ( prbe) i t To for S To Signature L Tor?t for a WW- iSs. Cndil Tom -tor i TOM 5 .50(e) ODbADWry ...Y....»„._........_._.__._....»....»..._...».._. R Arwo" FInN.ted [3 p- 4 „ » . . ... » i 21530.50 Is) Insurer FEDERAL TRUTH-W-LFNDRNGDISCLOSURES i Pre^^fuw Insured ANNUAL FINANCE Amount T101111 of T0181 Belo SigneW ro PERCENTAGE CHARGE Financed PeTmeMe Pd. RATE no dow The amwat d The aameuw TM foul cow ft aaaY ?rew co* pavNad b You ea Impe d your p.•han on you v on yaw I wa u • M•M .• °pw y0tl p IpY°w?a x" so viluding f o o e13 ther dpgr I Irfwnnoe Term 13412 „e,n kmauror m t nn % t FaYAaa( 8d+aduM Mlanbr of Amount of Exh Who Popost" Woe to Om"wo Pwym.mt at dw G4dN Ube w cra t DwnfKy lower" an your pop" wdndds 59 f . 47 (row" alaramp ter M. t.ta of M. aanbaal fe awewr and wa be I *w $ 582.47 1Al eRl 1 04 Yce today r • sure a epm••mmmenl You MM Ins ors Mme veldell. B a dww is dmoa.t d.elwd for Be was d rwm. oral be based ce ft ••aa vdw of ft ."h l p% W rR not wars awn PnpsyreM: M you pay dl yow doM awdl, you we not h we r Pay a pon". E3 C0"'a w i D•duaNbr• Late IN ynwae you must Pay a b.r dugs on Wa poftn d ersn psymrd naNed more s1on ran to do" ter. TIN **W Is 2 perad d iw k a rrmount 4w =.0o Midwrsr Is ten. E3 FNa The?Canbymw AdODW Caaap• Mawhy M11wra ,, YW ors tRh'kk s wwnMNy killed h Mrs vdide bawtiNky pumeMwed. O T04V and Labor lFiw?.mq ` Mw n .rs?eaki r vaPnamtthd r bMori nor Idmid dw Law w a Tom ?rft . ymw a „mw m•atymwr owaw mlaatmwr, yau.ury Iw• ew rWcM wr you w 1na•drq undr Law oanyad, a J r d,•, wM rd emb oust a •r ??I,Id? wd www d eeo. I•lall•a 1•I ell Ya.ma. NO DOIFICATION DISCLOSURE Any C -qo %v" area VW by you and M• O*d*W. BUYFA: X BIG 3S?? ACKNOWLEDGE ItOVISION HAVE READ AND AORGE TO Y! BOUND C REVERS! an OF TNIa ?T1BRAT ON TH . NOTICE TO BUYER Do not sign 1hls eon4aot In Wank You afr e1ltiNad to an exact copy of the wrNrael you sign. III R to protect your legal rights. Buyer (and Co-suyer) aclmowlaag.?tlut II) wfor. s nips'his Ic?orr? cc?? Buyer (and Co-8 w) r vedand revlewss a true aaly +Illad IR copy of this eomraet and (IQ at the tin" I thi Woontr of (and Co-Buyer) received a in copy of this contract. aietn im Burros WOMB .y drak t1Maw, ea smMrr.txeer w. anlr.d. .. r . r •ap••• wr.w•ma alla•Md r aria ••mme••C mM eallar • r I Y ? Not Ca wsawi mm Wdwr Adbndwa (Oaaandl Mena m is ded" you bM pwdnaW a dart La:Mdon w en pw A" of N " Or is wjowawme04 is I N uv is etch qw? W" M Id Inio IlritS•anlwThda6 rs ... w aw E an aww.l M M Nwnbwea. of AmW Powrpad ,ad. Section 4. Program No. QUESTION87 O PLEASE CALL US AT I-800.727.7000 VIII as at www.tettdweclL tim ot4+n w ,mwv-w a. w Pwan•.aww wy a u.al 309 BACK FOR ADDIMONAL Attataf 1 ORIGINAL '"PRN"' Ford Motor Credl Company P.O. Ban 3074 COLUMBIA, MD21045.6076 (800)677-0730 P01ZGXXQ0W29 WENDY A. LORENZ 449 WOODCREST DR MECHANICSBURG PA 17050 0ete of Repcaessaion 04.21-TOGS Date of Notice Date of Cordroct 04-M-21105 05-06-2004 Amount Number: 03702M ftW tNE DY A. LORENZ cobuw DESCRIIPMN OF PROPERTY Yew Make 2D00 FORD ? New Q Used Vehicle Identification Number. 1 FMPUIBL9YLA08322 Model EXPEDT T NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises M our agreement. Q PRIVATE SALC We vol sea the property described above at private sale sometime after 18 days from the Date of Notice shcyPM above UP*" redeemed by YOU Prior to such S310- 1-1 PLIBUC SALE: We wet see the property described above at public sale to the highest bidder on the data below (or awry adioumment _ date). The sale wi(I be hold as follow. Dale of Sale Time of Sale tines or sale You may Wand the sale and bring bidders it you wanL NOTICE OF REPOSSESSION The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses it permitted by law) will reduce the amount you save. 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 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. It 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 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 BEN RECOVERY ETTERS PA HOW TO GET YOUR PROPERTY BACK To get your property back, pay in this amount by certiftsd check or money order before the vehicle Is add. Unpaid Balance $ 22,820.01 Plus Costs: Repo Expenses $ 381 I = S Plus Lets Charges $ 27.88 Less Manes Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 22.707.87 (Plus expenses incurred If del" at the time of repossession exceeded 15 days and Less rebate received after the date of this ram.) Your property wont be sold untU 18 days after the date of title notice at the EARLIEST. After that you can atl0 get it back any time before Ira actually sold. it you do, vyi 1 have no kwttw claim on it. But the longer you wail, the more costs (including repairs) you may have to pay. If you have any questions about this. pease call us. ? The property has been (of oil be) returned to: (dealerforglnal credlor) Under our agreernefd with your deelerforiginal creditor, the dnsler/ Inal credhor is to sell the property and pay you any money left over, if you owe money after the ads, you will pay It to the dNkr/original creditor. ? PERSONAL PROPERTY: Any personal property found In the vehicle may be reclaimed by you within the next 00 days or, in accordance with aide law, by contacting this orrice. Thereafter, the personal property shall be disposed of accordingly. ? Creditor has as k;nad to its quarfred intermedary (OI Exchange, LLC) Re rights (but riot its obligations) with respect to the sale of each vehicle listed above PAYMENTS: AN payments to us must be by csrtlW check or money order. MILEAGE DISCLOSURE: It you are aware that the rnilenge reflected on the vehids's odometer k not accurst@ for any reason, please contact us so that sun can accurately report the vehloiVe mRengs. INSURANCE RIGHTS: If you donl went to get your property bwK call the Insurance company at the dalerlontginM usdilor to make sure that arty meuame has ban cancelled, You have a right to gat credit for art prarMurn refunds. JESSICA A. SNYDER PFNh ita5d37 yn 02 wwww adaans may NOT be ulad CUSTOMERICUSTOMER FILE Prinsd M U.S.A. Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 21045.WM 800 6770730 DATE: 2005-06-08 13029VM000OW85 WENDY A. LORENZ 449 WOODCREST DR MECHANICSBURG PA 17050 STATEMENT OF SALE Account Number: 037029552 The following property has been sold. Year Make Model Vehicle Identification Number. 2000 FORD EXPEDT 1FMPU18L9YLA08322 Balance owing on your contract (1) $ 22,347.87 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) 3 22.347.87 Deduct: gross proceeds of the sale (4) $ 12,400.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 9,947.8 Add: Expenses of retaking and storing, and (6) $ 584.25 any attomeys' fees allowed by law, and expenses of reconditioning and selling. (7) $ -0.00 Deduct: Insurance Premium Rebate (8) $ _ 0.00 Other: (9) $ 10532.12 Deficiency- (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. •• It 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 01!04 PrvAws edWcns may N0T be used. RECEIPT FOR PAYMENT Cumberland Countyy Prothonotary's Office Carlisle, Pa 17013 Receipt Date 1/26/2006 Receipt Time 15:49:30 Receipt No. 173403 FORD MOTOR CREDIT COMPANY (VS) LORENZ A WENDY Case Number 2006-00556 Received of PD MAURICE & NEEDLEMAN IM Total Non-Cash..... + 55.50 Check# 2444 Total Cash......... + .00 Change ............. - .00 Receipt total...... = 55.50 ------------------------ Distribution Of Payment -------- -------------------- Transaction Description Payment Amount COMPLAINT 35.00 CUMBERLAND CO GENERAL FUND TAX ON CMPLT .50 BUREAU OF RECEIPTS AND CONTROL SETTLEMENT 5.00 CUMBERLAND CO GENERAL FUND AUTOMATION 5.00 CUMBERLAND CO AUTOMATION FUND JCP FEE 10.00 BUREAU OF RECEIPTS AND CONTROL 55.50 I CASE NO: 2006-00556 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS LORENZ A WENDY BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LORENZ WENDY A the DEFENDANT , at 1834:00 HOURS, on the 5th day of October , 2006 at 250 REESER ROAD CAMP HILL, PA 17011 WENDY LORENZ by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 13.20 Affidavit 00 Surcharge 10.00 R. Thomas Kline nn 41.2-O-./ 10/06/2006 MAURICE & NEELDE Sworn and Subscibed to By: c before me this day Deputy Sheriff of A. D. fx 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. WENDY A LORENZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-556 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, WENDY A LORENZ in the amount as follows: Principal Amount $ 10532.12 Interest to Date $ 3635.75 Costs $ 180.30 Attorneys Fees $ 0.00 TOTAL $ 14160.32 MAURICE & NEEDLEMAN, P.C. BY: JOAW NEEDLEMAN, ESQ. Atto ev 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. WENDY A LORENZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-556 AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she is an attorney at law and that on 11/02/2006 she mailed a written Notice of Intention to File the Praecipe to Defendant, WENDY A LORENZ, at 250 REESER RD., CAMP HILL, PA 17011 by certified mail, article nos. 7155 5474 4100 4339 9971. Copies of the receipts evidencing said mailing are attached hereto. A copy of the signed green card evidencing receipt of said mailing is attached hereto as well. MAURICE/& NEEDLEMAN, P.C. for Plaintiff SWORN TO AND SUBSCRIBED before me this 1 day of,.",r , 2007. Notary Public ,?tlr? COMMONWEALTH OF PENNSYLVANIA Notarial Seal Agnes Bedard, Notary Public City Of Philadelphia, Philadelphia County My Commission Bores Jan. 20,2W9 Member, Pennsylvania Association of Notaries , ESQ. MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff V. WENDY A LORENZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-556 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 11/02/2006 to Defendant, WENDY A LORENZ, 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 11/02/2006, a copy of the receipt for certified mailing to the Defendant and affidavits of service of said notice are all attached hereto. MAURICE &_NkEDLEMAN, P.C. BY: JON?DIIEMAN, ESQ. Atto e f Plaintiff AA 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. WENDY A LORENZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-556 CERTIFICATION OF ADDRESSES It is hereby certified that the parties have the following addresses: MAURICE & NEEDLEMAN, P.C. BY: Plaintiff: FORD MOTOR CREDIT COMPANY P.O. BOX 6058 MESA AZ 85216 Defendant: WENDY A LORENZ, 250 REESER RD., CAMP HILL, PA 17011 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. WENDY A LORENZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-556 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she represents the Plaintiff in the above entitled case and that Defendant, WENDY A LORENZ, 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. MAURICE * NEEDLEMAN, P.C. for Plaintiff SWORN TO AND SUBSCRIBED ?,r, , ESQ. before me this l day of J ?" , 200 . Notary Public 6",-4 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Agnes Beiland, Notary Public Cdy Of Philadelphla, Philadelphia County My Commission Sores Jan. 20, 2009 Member, Pennsylvania Association of Notaries Suile 935, One Inn Cent" 1617 Job. F. Kennedy 114, PhilWelphia,?A 19103 te1.215.665.1133 foe 215.563.8970 www.melowpr.sgm Donald S. MwW, Member NJ 1. Board Certified Creditors' Rights law Amerken Board of CertiNwUen )Won Needleman Member PA i NJ Bar Thom" t. Dommayk Member NJ t PA B" Sandra J. SettarSfno" Menber NJ t NY Bar November 2, 2006 `VIA CERTIFIED & REGULAR MAIL WENDY A LORENZ 250 REESER RD. CAMP HILL, PA 17011 Our File No. 2588 RE: FORD MOTOR CREDIT COMPANY v. WENDY A LORENZ CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO.06-556 Tear WENDY A LORENZ: 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 10/05/2006. 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 i NEEREMAN, LC. 250 Into 28 West Solve 203 Bridgewater, NJ 08107 W. 901.575.0220 fax 908.575.0632 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 A 7US AN 4m 4m "n RM= ? t FMS Postage per piece $0.39 Certified Fee 2.40 ARTICLE ADDRESS TO: Return Receipt Fee 1.85 WENDY A LORENZ TowPostap&Fees: usa 250 REESER RD CAMP HILL PA 17011-1923 . Postmark • Here . err MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff CUMBERLAND COUNTY COMMON PLEAS OF V. WENDY A LORENZ CASE NO. 06-556 IMPORTANT NOTICE TO: WEND$ A LORENZ DATE: November 2, 2006 250 REESER RD. CAMP--UELL, PA 17011 1 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU'CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717)249-,3166 MAURICE & NEEDLEMAN, P.C., ; I 935 One Penn Center € U. Philadelphia, PA 19103 COMPLETE MIS SECTION ON DELIVERY or El Aasnt - nature: (? Addressee ) X 7155 5174 4 ecV-id y: (Plea nt clearly) RETURN RECEIPT R h C. Date of Delivery Article Addressed To: x.: (MOMAnnt hum Ad"n Wed by S-dw) Secondary Address I Suits / Apt. / Floor (P/aaae Print dearly) Delivery Addrose Clb State ZIP + 4 Code WENDY_A 250 REE$ER- RD 7 i 92 2" 11, 44 6, -, , p 1- ?? 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. WENDY A LORENZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-556 () Notice is hereby given that a judgment in the above-cap 'oned matter has been entered against you in the amount of $14160.32 onyiL 1L,,-26o7 () A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. Prothon ler by: If you have any questions regarding this matter, please contact the filing party: Name: JOANN NEEDLEMAN, Esquire Address: Suite 935, One Penn Center at Suburban Station 1617 J.F.K. Boulevard Philadelphia, PA 19103 Telephone No.: 215-789-7161 (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: FORD MOTOR CREDIT COMPANY vs. WENDY A LORENZ '50 clm? Ott ( PA bl I TO THE PROTHONOTARY OF THE SAID COURT: ( ) Confessed Judgment ( ) Other File No. 06-556 Amount Due 14160.32 Interest 2/16/07 $260.71 Atty's Comm p Costs The undersigned hereby certifies that the below. does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but If it does, it is based on the appropriate original Proceeding filed pursuant to Act 7 of 1966 as amendedT and for real property pursuant to Act 6 of 1974 as amended. Issue a writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the-following' described property of the defendant(s) ANY AND ALL ACCOUNTS IN THE NAME OF THE ABOVE DEFENDANT SS# xxx-xx-2136 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff ofCumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) -ANY AND ALL ACCOUNTS IN THE NAME OF THE ABOVE DEFENDANT SS# xxx-xx-2136 r r?.C K S I$ ?? Z ?C: v U S in the possession of Members l st FCU a/ cCG? S 6- 'G and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). O (indicate) Index this writ against the gamishee(s) as a lis defendant(s) described in the attached exhibit. Date Signature: Print Name- Address: inst real estate of the One Penn Ccenter Philadelphia, PA 19103 Attorney for: Plaintiff Telephone: 215 789 7154 Supreme Court ID No.: 74276 (over) I a? CZ, -.2 ?f Ica '?' C C a `n w C c C d Iri Cw . Y r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-556 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 WENDY A. LORENZ, 250 REESER RD., CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1sT FCU, 1 CARLISLE BARRACKS #842, CARLISLE, PA -- ANY AND ALL ACCOUNTS IN THE NAME OF THE ABOVE DEFENDANT SS # XXX-XX-2136 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $14160.32 Interest 2/16/07 - $260.71 Atty's Comm % Atty Paid $216.30 Plaintiff Paid Date: JUNE 18, 2007 L.L. $.50 Due Prothy $2.00 Other Costs C R. Lon onota (Seal) By: Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Supreme Court ID No. 74276 FORD MOTOR CREDIT COMPANY Plaintiff, V. WENDY A LORENZ Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-556 WRIT OF EXECUTION NOTICE This paper is a Writ if Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. If you wish to exercise your rights, you must act promptly. Exempt Property. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300.00. There are other exemptions which may be applicable to you. Attached is a summary of some of the major exemptions. You should do the following promptly: (1) Fill out the- attached exemption claim form and demand a prompt hearing; (2) Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. Property Belonging to Another Person. If there is property at your residence [or your bank account] that belongs to another person or that you own with another person, you should notify that person so that he/she can file a property claim or other legal papers with the Sheriffs Office to prevent his/her property from being taken or sold at Sheriffs Sale to satisfy your debt. See enclosed forms. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION FIND OUT WHERE YOU CAN GET LEGAL HELP. SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland Bar Association Lawyer Referral and Information Service Telephone: (717) 240-6195 EXHIBIT A PLAINTIFF: FORD MOTOR CREDIT COMPANY VS WENDY A LORENZ Court Term & No.: Caseno» CLAIM FOR EXEMPTION TO THE SHERIFF: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be [ ] (1) set aside in kind (specify property to be set aside in kind): [ ] (2) paid in cash following the sale of the property levied upon; or (b)I claim the following exemption(specify property and basis of exemption): (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 exemption: [] in cash [] in kind (specify property): (b) Social Security benefits on deposit in the amount of: $ ; (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Name, Address & Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unworn falsification to authorities. Date: Defendant(s): Address: City, Zip: THIS CLAIM TO BE FILED WITH: Office of the Sheriff of Cumberland County (717) 240-6195 DEFENDANT Note: Under paragraphs (1) and (2) of the writ a description of the specific property to be levied upon or attached may be set forth in the writ, or included in a separate direction to the Sheriff. Under paragraph (2) of the writ, if the attachment of a named garnishee is desired, his/her name should be set forth in the space provided. Under paragraph(3) of the writ, the Sheriff may, as under prior practice, add as a garnishee any person not named in this writ that may be found to be in possession of property of the defendant. See Rule 311 l (a). For limitations on power to attach tangible property, see Rule 3108(a). (b) Each court shall by local rule designate the officer, organization or person to be named in the notice. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW (1) $300.00 statutory exemption (2) Bibles, school books, sewing machines, uniforms and equipment (3) Most wages and unemployment compensation (4) Social Security benefits (5) Certain retirement fund and accounts (6) Certain veteran and armed forces benefits (7) Certain insurance proceeds EXHIBIT "A" FORD MOTOR CREDIT COMPANY Plaintiff, V. WENDY A LORENZ Defendant(s). MEMBER'S 1ST FCU CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-556 An-?l?er-5 4-C INTERROGATORIES IN ATTACHMENT TO: MEMBER'S 1" FCU You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment against you. 1. At the time you were served with Plaintiffs writ of execution, or at any subsequent time, did you owe the defendant (SS # xxx-xx-2136) 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. 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? (3O 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? $f4; p .r #" )-3L -I (oCi SM Acp - 3e,?. S? c?necx? --'ytQ? . 5'1 I?C.e? ? 2-tah X8'1 --?o ??1,,? wt1-'? lid scu.y l_o r e ?2 gP?v ?Rq - . 5 22 4.o I r Anf c ?uw-Q - 4. At the time you were served or any subsequent time, did you hold as fiduciary any property in which defendant had an interest? t(Z 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? T\) () 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? W 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. ,Yo eyfor plaintiff 5 ne Penn Center ladelphia, PA 19103 15 789 7154 ESQUIRE (aal G--, C99 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 (21 J) /t3y-/1J1 FORD MOTOR CREDIT COMPANY Plaintiff, V. WENDY A LORENZ Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-556 PRAECIPE TO DISSOLVE/WITHDRAW GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve/withdraw garnishment upon Members 1 Sc FCU forthwith. Respectfully Submitted, MAURICE & NEEDL Esq. , P.C. Date: July 13, 2007 n ?- a N ?a -71 i ?. ? i SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00556 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS LORENZ A WENDY And now RONALD HOOVER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:23 Hours, on the 27th day of June , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT LORENZ WENDY A in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FCU 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BRIAN M. PETERS (MANAGER) , personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: So answe s• ??? Docketing .00 Service .00 aa- - aa Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 r 'x30 0 1//0 7 ?. , 06/28/2007 Sworn and Subscribed to before me this day of By Deputy Sh riff A.D R. Thomas Kline, Sheriff, who being duly swo-in'40i ording to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: / FD 2. --• -7Mvance Costs: 150.00 Sheriff's Costs 86.83 Docketing 18.00 63.17 Poundage 1.71 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 04/02/08 Mileage 4.80 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage .82 Garnishee 9.00 TOTAL 86.83 So Ans s, we . R. Thomas Kline, Sheriff / 0 A' f )6 L - -ems. By , . s ?v .2- C k c 3 s?3 lt?c v. )a go 23 9LZbL 'oN QI PnOD auzaidnS VSIL-68L-SIZ :auogdojoL 33I.LKI V'Id :ioi Xauzolld £0161 Vd `dIHd'IHCI V'IIHd H31U213 MNHd HNIO S£6 :ssaippd XIndaQ :NCH Lzulo oid `2uoZ ? siunO 7M10F slsoD zaglO 00'Z$ Xgjozd on(I OS'$ 'T I ?IIRaS? `NPVL1i? 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