HomeMy WebLinkAbout06-0955
GREGG L MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, P A 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A 10#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY
Plaintiff,
)
)
) NO. Dlo - 9SS
)
)
)
)
)
)
)
Ctu i tT 9l..M
v.
DONALD GRIES,
Defendant(s).
COMPLAINT IN CIVIL ACTION
Filed on behalf of:
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
Counsel of Record for This Party:
Gregg 1.. Morris, Esquire
Pa 1.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff,
)
)
) NO.
)
)
)
)
)
)
)
v.
DONALD GRIES,
Defendant.
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in
the following pages, you must take action within TWENTY (20) DAYS after this Complaint and notice
are served, by entering a written appearance personally or by attorney, and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court without
further notice for any money claimed in the Complaint or for any other claim or relief requested by
the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, 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.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
)
i NO. Ol.". - 95:.5
)
)
)
)
)
)
)
(J- . C~
UL.>~ t~
v.
DONALD GRIES,
Defendant(s).
COMPLAINT IN CIVIL ACTION
AND NOW, comes Plaintiff, FORD CREDIT tldIb/a FORD MOTOR CREDIT COMPANY,
by and through its attorney,GREGG 1.. MORRIS, ESQUIRE and the law offices of PATENAUDE
& FELIX, A.P.C. and files the following Complaint in Civil Action, and in support thereof aver
as follows:
1. Plaintiff, FORD CREDIT t/dIb/a FORD MOTOR CREDIT COMPANY, IS a
corporation with offices at 575 East Swedesford Road, Suite 100, Wayne, PA 19807.
2. Defendant is DONALD GRIES, an adult individual, who is believed to currently reside
at 945 DOUBLING GAP RD , NEWVILLE, P A 17241-9782.
3. On or about September 29, 2000, the aforesaid Defendant(s) entered into a written
Automobile Retail Installment Contract (hereinafter "Contract") to purchase a "Vehicle" from a
dealer (Seller) as more fully set forth in said Contract. A true and correct copy of the Contract is
attached hereto, marked as Plaintiffs Exhibit "A" and incorporated by reference.
4. "Seller" thereafter assigned the Contract to Plaintiff, FORD CREDIT.
5. Pursuant to the terms of the Contract, Defendant(s) were to make 60 payments of
$489.80 commencing on November 13, 2000.
6. The terms of the Contract provide for termination upon satisfaction by Defendant(s) of
all obligations provided thereunder.
7. Plaintiff avers that Defendant(s) defaulted under the Contract by failing to make
payments to Plaintiff as promised.
8. Due to Defendant's default under the Contract, Plaintiff exercised its rights to terminate
the Contract.
9. After calculating early termination charges due to Plaintiff, Plaintiff avers that a
deficiency balance of $11,258.96 is due from Defendant(s) as of February 10,2005.
10. Plaintiff avers that such attorney's fees will amount to $3,300.00.
11. Despite repeated request, Defendant(s) have willfully failed and lor refused to pay the
aforesaid sum due.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the
amount of$11,258.96, plus legal interest from the date of breach, reasonable attorney's fees in the
amount of$3,300.00 with continuing interest at the legal rate thereon from the date of Judgment
plus costs. The damages requested are less than the maximum amount for compulsory arbitration as
set by the Court.
ORRIS, E
213 ain Street
Carnegie, PA 15106
(412) 429-7675
".
PEN!'!5VlV.ANIA SIMPLE INTEREST VEHICLE RETAIL INStALLMENT CONTRACT
DATE
09/19/1000
.
Bu~r (and Co-Buyer) Name ;md A.ddress (inr:ludlng County ilod lip Code)
ClNAI,D A GRIES
TO~N MILLS
HIPPENSBURG PA 17257
UMBERLAND
CREDITOR (Seller Name end Address}
INTERSTATErORD, lie.
196 ~ALNUT BOTTOM RD
SHIP~EiSBURG, PA 17157
NlIWlUsed
1199B
SED JEEP
Modol
bRAND CHE I
You, the Buyer.!and Co-auyar, If anyl. may buy the "ohlde dncrtbed below for caIIh or oJ.i:redl1. 'OM .ClUlh Prtce" ShOWll bol~ is the CQh pr1C1l of the YllI1ldo. Thoo
"Total Sale Price~ .hown below 1$ ~ cnodll price. By 81gnll)g thlll co...tract, yoo choou to,bUY on Cl1ldlt undar the ag,...,1IlInb an the front Ind bacll 01 thlr. contnlo::L
YaarandMak
GVWlfTruc\( Ibs Vehlcleldantlrlcalion Numbltf
11J4GZ4BYBUC304619
Trade-in87 FORI)
RRONro II
YellratldMllke
I 900.00
Gross Allowllnoo
NfA
Amount Owing
".,' ,-'''';;i:~~;:'
ITEMIZAnQNOi=, AP4tJU:lfr:~IP{~NC,eO"
1. Cash Price. .......... ............. ___................__...................................
2. Down Payment
Third Party Rebate Assigned To Creditor ....... .................. $
Cash Down Payment ...................................................,........ $:
Trade"\nlF I':"QIlI) $9QO 00 $ N I tJ. $
Y..randU.... Gmu-..- ~o...o.g
S-lS92~(11
If/A
1 non on
Qon no
Total Down Payment ........................................................... '" $ ] 99Q 00 (2)
3. Unpaid Balance of Cash Price (1 minus 2)-:................. ............. $ 17020 QQ {3}
'4. Amounts paid on your behalf (Seller may be retaining a portion of these amounts)
To Insurance Companies for
Credit Life In5urance (for tenn of contract)......................... $
Credit Disability Insurance (for term of contract)............... $
~_~'[rerm_Montl1s(Eslimate)J $
To Public Officlills (I) for license ($ N f tJ. , 1, tille ($~? r:::....
~9Istration($-3.6-.O..Cl-)fees$~:.
(ii) for filing fees$ II 99
(iii)fortaxes(notinCashPrice}$~_ $---1--1~.
To for Massengor Service:....;.......... $ N I ^
To POUFRTRATN for FXT UARRANTY $~..5......Oa
To DFAI FR for oor HF $ 1:;; on
To STATF OF PA for ON IINF JlFG $ ~/tJ.
Total....................................:..........:.................................._....... $ ?1?7 ?Ii (4)
5. AmQunt Financed (3 plus 4).................... .................................. $' q 1 A 7 ?O (5)
N/A
IlIA
I
iR ('U)
.F,~Il~RAL TRUJH,IN,\.Ef,(~lfIi;.,DI.SC.L()SUR~S..
FINANCE \ Amount Total of
CHARGE ;, Financed Payments
The amouruo[ I. The amount
CIl;ldilprovi6lldlo'_youwillhave-
you or on your paid when you
benalf navemadaall
scneduled
paymenls
% $ In?4n RO t9.1~ S;>q';l;f{R on
ANNUAL
P~RCENTAG~
RATE...
The rostof yOOr
credit a.s a yeany ratl!
The.dollaremount
l!liCl"f,dilw)JI
CQs/you
Total Sale
Price
The total cost
"of your;purt:hase on
credit.
including your
ofSd"l'g~~
S3128B.00
Number of
XJ payments
Your payment schedule I,iO
will be; llina!
Amount of Each
payment
$ 4.9.80
$4B9,80
When Payments
are due
(monlhlystarting)
1111312000
Payment Schedule
D
Prepayment: If you pay off your debt eany, you will nothava 10 payEl Ilenalty.
Late Pllynllml: You mU5t pay alate charge on !he portion,of each paytnl!f1t received more
than 10 days late. Thed1arga is 2 percenl oftha late amount or $50.00 wllichever is less.
Security Intere.st You are giving a security interest in !he venide being purchased.
~:'~~C:;e ~~~I~t~~J?r~ ~~~~~1r6~~i~~~r,~0~laggrofiinl~~-~~J~1~~~~~~~yment,.
prepaymenlpenalty. _ . .
I
COIIlMERClAL VEHICLES: The dlarga shown in Ina above t>ox for tata payiiiilnls applies where tna vel1ide
purrt\3sed has a gross ....nlwler :-ignt or I!Jss lhan 15.000 pounds.' If tt>e val'lici6 you purdlaaed h... e gross
venlcuI...._igtrtof15.DOOpoundso'll1Clt9.youmustpayei8lechalY"on1hep011ionofeach~lInlreooivad
mom1han 10 days late. ThlIctrargtlls4 pen:enlollhBlale lIIOOUntorS50, wt>l;:-er Is less
,
. If you ~ no! mael you, rontra<:l. obligations. you may lose the IIBhicle that you am ftnam:ing under !his conlrilcl.
\ as well as both par1S and goods put on !he ~icle and money Or goods received for !he vahicla. .
\. NON.MOOIFICA TION DISCLOSURE
leO) BUYER SIGNS
UseForwn,ct1Purclmaed
Parsonal 0 Agricultural
Co~me~a1
[>g
INS~~1>lCE: . .".
YOU MAY OBTAIN veHICLE INSURANCE
FROM A PERSON OF YOUR CHOICE.
YOU ARE NOT REQUIRED TO OBTAIN
CREDIT UFE, CREDIT DISABILITY AND
OTHER OFIlONAL INSURANCE. THIS
CONTRACT WILL NOT INCLUDE THEM
UNLESS YOU SIGN AND AGREE TO PAY
THE PREMIUM,
THIS CONTRACT DOES NOT INCLUDE
LIABILITY INSURANCE COVERAGE FOR
BODILY INJURY AND PROPERTY
DAMAGE CAUSED TO OTHERS.
o Credit Life
Insurer
$
iliA
Premium
Insured(s)
Signature(s)
Credit
o Disability
Insurer
$ N/A
Premium
Insured
Signature
o Type of Insurance
Teon
$p'<<hlium
Insurer
::>1 nature
Credit ute and Credit Oisabllity Insu!'1lnce am
for ttle term of the colJtnlct The smount and
coverages are shown in a notice or agreamtlnt
gfVllntoyoutoday.
You must Insure the vehicle. If a charge is
. :~~~~t.::~"":-~I'~rm~~u:.~ ,~...l1
CoVllraQ8s will be biJsed on the cash value of
the vehicle at t11116.of lon, but not mon tha..!!.,.
the timibl ofthe policy. . ..........
o Comprehensive. 0 ~Deductlbl;
Collision
Fire. Tnefl-Combined Addl~onal COverage ~
TowingandLatior~
Term. .; .Months(Estimale}.__~.
I PremiumS N/A " .
o
o
_"",-0;
i
QUESTIONS? .
Ford
Credit
I
~
J
PLEASE CALL US AT 1-800-727.7000
...."
.'''''.:~U!__
completely filled in copy of this contract at the time of signing.
BY.llJfl~acceplsthlscontract..
...lgnment '.. "sot>ntract,thaSsn"ram;i
~ 'I FORD. INC. 'I
FC17Sl7-S1M'R\1'9 (_'-""""l'NOTDe....oad.)
:.~ ----
BRANCH COPY
(' ,
L \ ~\L) ; t
"
A
,\
....COITIONAl AGREEMENTS
A. Payments and Summary Notice; You must make all
payments when they are due_ You may prepay your debl al any
lime without penalty. This is a simple interest contract. The
actual finance charge you agree to pay will depend on your
payment patlams_ The actual finance charge may exceed the.
disclosed Finance Charge If you make your paymenls later than
the scheduled dales or in less than the scheduled amounl. The
Creditor will apply your payments first to the earned and unpaid
part of the Finance Charge and then to the Amount Financed.
The Ctedil.or earns the Finance Charge by applying the Annual
Percentage Rate 10 the unpaid Amount Financed for the actual
time the unpaid Amounl Financed is outstanding. If the vehicle is
repossessed, you will not have a right 10 reinstate the contract
unless the Creditor agrees.
B, Security Interest: You give the Creditor a security interesl in:
1. The vehicle and all parts orother.goods putonthevehide;
2_ All money or goods received fm the vehicle; and
3. All insurance premiums and service contraclS financed for you
This secures payment of all amounts you:owe in this contraci. It
. also secures your other agreements in this contract.
C, Use of Vehicle - WARRANTIES : You must lake care of
the vehicle and obey all laws in using II. You may not sell or rent
.the vehicle, and you must keep it free from the"c1aims of others.
You will 1'101 use or permM:.the use of the vehicle outside of the
Unitel:l States, except for up to 30 days in Canada or. Mexico,
without.the prior written consent of Iha Creditor. tf the vehicle Is
of a type normally used for personal use and the Creditor, or
the vehicle's manufacturer, extends a written warranty or
service contract covering the vehicle within 90 days from the
date of this contract, you get Implied warranties of
merchantablllty and fitness for a particular purpose covering
the vehicle. Otherwise, you understand and agree that there
are no 6uch Implied warranties.
D. Insurance: You must insure yourself and the Credil.or against
loss or damage to the vehicle. The Creditor must approve lhe
type and amount of insurance, If the Creditor oblains a refund on
Insurance or service c:onlr.3cts, Ihe Creditor will subtract the
refund from what you owe. Whether or not the vehicle is
Insured, you must pay for it If it Is lost, damaged, or
dastroyed.
If a charge for vehicle insurance is shown on the fronl the"
Creditor will try to buy the coverages check!:!d for tile term shown.
The Creditor is nol liable, though, If he cannot do so, If these
coverages cost more than the amount shown for insurance, the.
Creditor ,may buy- them for a shorter_ term or he may give you
credit for the amount shown. If he cannot buy any insurance, he
will give you credit for the amount shown. The credit will be made
to the last payments due.
E, Late Charge;' You will have to pay a late charge on !he
portion of each payment made more than ten days late. The
charge is shown on the.front. Acceptance of a lale paymenl does
not excuse your default or mean that you can keep making
payments after they are due. The Creditor may take the steps set
forth lnthis conlract if there is Br'!Y default. .
',,,',
",
-,,':';'
~
F, 08f..ull; You will be in defaull if:
1. You do not make a payment when it is dl'e; or .
2. You gave false or misleading informatioT'l" on your cret'!it
application relating 10 this contract:_or
3. Your vehicle is seized by any local, state, or federal
authority and is not promptly and unconditionally
retumed to you; or
4. You file a bankruplcy petition or one is filed against you; or
5. You do not keep any other promIse in this contract.
If you are In default, the Creditor may require you to pay at once
the unpaid Amount Financed, the earned and unpaid part of the
Finance Charge and all other amounts due under this contract.
He may repossess (take back) the vehicle, too. He may alsO
lake goods found in or on the. vehicle when repossessed and
hold them for you. ' .
If the vehicle is laken back., he will send you a notice. The notice
will say that you may redeem (buy back) the vehicle. It will also
shaw the amount needed 1.0 redeem. You may redeem the
vehicle up to the lime the Creditor sells it or agrees 10 sell II. If
you go not redeem the vehicle, II will be soid. ,
The Creditor will use the money from the_ sale, less the allowed
expenses, to pay the amount still owed on this contract.
Expenses paid as a direct resull of having \0 retake the vehicle,
hold Jt for sale, and sell it are, as permitted by law, aJlawed
expenses. lawyers' fees and legal costs permitted by law are,
allowed, too. The Creditor will pay you any money left (a
surplus). You will pay any money stilrowing after the sale to the
Creditor. If you do not pay Ihis amount when the Creditor asks,
the. Creditor may charge you Inlerest at the highest lawful rate
until you pay.
G, General: To contact Ford Motor Credit Company about this
account. call1-(BOO) 727-7000. The law of PennSylvania applies
10 this contract. If that law does not allow all of the agreements
in this contract, the ones that are not allowed will be void. The
.. rest of this coniractwill stlil be good.
., -FJo;NQIlqE!t
NOnCE - ANY HOLDER OF THIS CONSUMER CREDIT
CONTRACT IS, SUBJECT TO AL.L CLAIMS AND
DEFENSES WHICH THE DEBTOR COULD ASSERT
AGAINST THE SELLER OF GOODS OR SERVICES
OBTAINED PURSUANT HERETO OR WITH THE
PROCEEDS HEREOF. RECOVERY HEREUNDER- BY
THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY
THE DEBTOR HEREUNDER.
Used Mot~r Vehicle Buyers Guide. If you are buying a used
vehicle with this contract. federal reguiations may require a
spadal Buyers Guide to be displayed on the window of the
vehicle. THE INFORMATION YOU SEE ON THE
WINDOW FORM FOR THIS VEHICLE IS PART OF
THIS'CONTRACT. INFORMATION ON THE WINDOW
FORM OVERRIDES ANY CONTRARY PROVISIONS
IN THE CONTRACT -OF SALE.
GUARANTY
. .
To cause the Seller 10 sell the vehicle described on the front of this contraCt to the Buyer, on coedit; each pernon ~ho signs belo~as a
"Guarantor" guarantees the payment of this contract, This means that if the Buyer fails lo_pay any money that is owed .on-this
contract. each one who signs as a guarantor will pay it when asked. Each person who_signs below agrees that he will be liable for the
Whole amounl owed even If one or more other persons aiso signs this Guaranty. He also agrees to be liable even if the Creditor does
one or more of the following: (a) gives the Buyer mare time _to pay one or more payments, or (b) gives a release in full or in part to
any of the other Guarantors, or (c) releases any security. Each Guarantor also states that he has received a completed copy of this
contrac;l and this Guaranty at the time of signi.ng.
Guarantor Address
Guarantor Address
FC17637-6IAPR98 1_"";b"""...~NOTbe...-l,)
II~II;_IIII~I
FC17637,SlI',PR99
.
VERIFICATION
The undersigned is an authorized agent of the Plaintiff and verifies that the facts and
statements made herein are true and correct based upon my knowledge, information and
belief, and are based upon and have been obtained from a review of the facts and
information contained in the business records of the Plaintiff supplied to us by Plaintiff.
Counsel has signed the verification as a matter of time and convenience. The verification
of the party will be provided if requested. The statements are made subject to the
penalties of l8 Pa.C.S. Section 4904, relating to unsworn falsification to aut rities.
Date: February 15,2006
.-,,'1
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GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY
Defendant(s).
)
)
) NO. 06-955 CIVIL TERM
)
)
)
)
)
)
)
Plaintiff,
v.
DONALD GRIES,
P RAE C I P E FOR
DEFAULT JUDGMENT
Filed on behalf of:
FORD CREDIT t/d!b/a FORD MOTOR
CREDIT COMP ANY,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa 1.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT tld/b/a FORD MOTOR
CREDIT COMPANY,
Defendant( s)
)
)
) NO. 06-955 CIVIL TERM
)
)
)
)
)
)
)
Plaintiff
v.
DONALD GRIES,
PLAINTIFF'S PRAECIPE FOR DEF AUL T JUDGMENT
TO: PROTHONOTARY
Please enter a judgment against the Defendant(s), above nanled, for failure to file an Answer
to Plaintiffs complaint.
Amount claimed in Complaint
Interest from February 10, 2005
Attorney's fees
TOTAL
$ll,258.96
$2,279.94
$3,300.00
$16,838.90
With continuing interest on the principal amount of $l6,838.90, with interest at the legal rate,
plus costs of suit.
I hereby certify that a written notice of intention to file this praecipe was mailed to the
Defendant(s) and Defendant(s) counsel (ifknown), after the default had occured and at least ten (lO)
days prior to the date of the filing of this praecipe. A copy of the Notice is attached.
G .MO
atenaude & Felix,
213 E. Main Street
Carnegie, P A 15106
(4l2) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
)
)
) NO. 06-955 CIVIL TERM
)
)
)
)
)
)
)
v.
DONALD GRIES,
Defendant( s)
PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF
NOTICE PURSUANT TO PA.R.C.P. 1037(b)
COMMONWEALTH OF PENNSYLVANIA )
)
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and State,
Personally appeared Gregg 1. Morris, Attorney for and authorized representative of Plaintiff, who being
duly sworn according to law, deposes and states that the Defendant(s), DONALD GRIES, is not in the
military service of the United States of America to the best of his knowledge, information and belief and
certifies that Notice ofIntent to take Default Judgment was mailed in accordance with Pa.R.C.P. 237.1,
as evidenced by the attached copy.
Sworn to.and subscribed bl;;fore me
this ~IT\ day OC..1piL\ Y 20 _..lIp
t) I (t-r, ] Yt Ltk1 ,(
N tary Public (
NOtAlIW SEAL
GRETA A JEWELL
Notary PUblic
CARNEGIE BOROUGH, ALLEGHENY COUNTY
MV CommlSllon Expl,... Nov 18, 2009
GREGG 1.. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE,PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/dIb/a FORD MOTOR
CREDIT COMPANY
Plaintiff,
)
)
) NO. 06-955 CIVIL TERM
)
)
)
)
)
)
)
v.
DONALD GRIES,
Defendant(s).
IMPORTANT NOTICE
Filed on behalf of:
FORD CREDIT t/dIb/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
Counsel of Record for This Party:
Gregg 1.. Morris, Esquire
Pa 1.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant( s)
)
)
) NO. 06-955 CIVIL TERM
)
)
)
)
)
)
)
FORD CREDIT tldlb/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
v.
DONALD GRIES,
To: DONALD GRIES
3 TOWN MILLS
SHIPPENSBURG, PA 17257
Date of Notice: March 21, 2006
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PEROSONALLY ORBY 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 JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A 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 MAYBE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIA nON
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166 /
\'-
,
I, GREGG 1. MORRIS, attorney for Plaintiff, FORD CREDIT t/dIb/a FORD
MOTOR CREDIT COMPANY, herby certify that a true and correct copy of the
foregoing document was served this day by US First Class Mail, postage prepaid upon
the following:
DONALD GRIES
3 TOWN MILLS
SHIPPENSBURG, P A
I
I
Date: March 21, 2006
, Greg Ire
a ena e & Feli ,A.P.C.
Attorneys for Plamtiff
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
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GREGG 1.. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE,PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A 10#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Defendant(s).
)
)
) NO. 06-955 CIVIL TERM
)
)
)
)
)
)
)
FORD CREDIT t/dIb/a FORD MOTOR
CREDIT COMPANY
Plaintiff,
v.
DONALD GRIES,
NOTICE OF ORDER,
DECREE OR JUDGMENT
Filed on behalf of:
FORD CREDIT t/d!b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
Counsel of Record for This Party:
Gregg 1.. Morris, Esquire
Pa 1.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, P A 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/dIb/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
)
)
) NO. 06-955 CIVIL TERM
)
)
)
)
)
)
)
v.
DONALD GRIES,
Defendant( s)
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: ( ) Plaintiff ( X) Defendant ( ) Garnishee ( ) Additional Defendant
You are hereby notified that the following Order, Decree, or Judgment has been entered
against you on ~'Vl ; l (n I J ()Q '"
( ) Decree Nisi in Equity
( ) Final Decree in Equity
(X) Judgment of ( ) Confession
( X) Default
( ) Non-Pros
( ) Verdict
( ) Non-suit
( ) Arbitration Award
( ) Court Order
(X) Judgment in the amount of$16,838.90, plus cost.
( ) District Justice Transcript of Judgment in the amount of $
plus costs.
( ) Ifnot satisfied within sixty (60) days, your motor vehicle operator's license wil be
""_dod by tho D""mro,"' OfT~""Q~
By
Deputy
If you have questions concerning the above, pI ease contact:
Name of Attorney: GREGG 1. MORRIS, ESQUIRE
213 E. Main Street
Carnegie, P A 15106
(412) 429-7675
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-00955 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FORD CREDIT T/D/B/A FORD MOTOR
VS
GRIES DONALD
ROBERT BITNER
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
GRIES DONALD
the
DEFENDANT
, at 1720:00 HOURS, on the 28th day of February
2006
at 3 TOWN MILLS
SHIPPENSBURG, PA 17257
by handing to
DONALD GRIES
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
17.60
.00
10.00
.00
45.60
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R. Thomas Kline
me this .J./.Ak
day of
03/02/2006
PATENAUDE & FELIX
~6L
Deputy Sheriff
Sworn and Subscribed to before
~ .:J.0'tJl. ~A.D.
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