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Home My WebLink About06-5554ARBITRATION 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) 789-7154 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. NICHOLAS D GOLDERMANN 1400 Bent Creek Blv Apt 112 Mechinicsburg, 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 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. ? -- sss7 01 V 1 L ` E) CIVIL ACTION COMPLAINT AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y In notificacion. Hace falta asentar una comparencia escrita o en persona o can un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Adernas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. 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. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. NICHOLAS D GOLDERMANN 1400 Bent Creek Blv Apt 112 Mechinicsburg, Pa 17050 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. O(. -- SSS'Y Cl Uz( ! ti 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, Nicholas D Goldermann, is an individual who resides at 1400 Bent Creek Blv Apt 112 Mechinicsburg, 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 August 14, 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 $16,572.59 at an annual percentage rate of 7.990%, in order to purchase a certain motor vehicle, 2004 Ford F-150 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 $291.44 for a period of 72 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 July 19, 2005, 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 $11400.00, however a balance of $4544.21 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. 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 $307.38 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $4851.59. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $4851.59, 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.L6ON INCZYK, 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. BY: DIRE DATED: September 14, 2006 DATE 08/14/2004 SrAr.An?.-....... .,xn?er ueur/rn a ecr•Atl IN9tA1'YEMT CONTRACT ?aan cR(iaofdLvAr?uw?ndlmmmrraao?,mddcnw. •.....???..?....?..._ -_-_. _ N [lMUL11J Y 1ri7LYl1l1V{IIII RciudYp County and Zip Cod) CIIlnR011(Wlw NNas and Addnu) 266 PHILADELPHIA AVE 114 PARSONS INTERSTATE FORD LLC CHAMBERSBURG PA 17201 AUG 17 2004 196 WALNUT BOTTOM RD FRANKLIN SHIPPENSBURB, PA 17257 ?J You, one Beyer laws Caw,pr. Ir eeyA may"lheveldW* deeadhed beret ter e.eh r es erda. TM •Car, ?rlw' ehewe aaerlr ta1M each prnea a me veeena Ina 'Told MY rube saeetn below Is On aedN PM& ey etanane tats eeabe•R yea eflewe b buy M Bradt w,drM.ereb^et^M a Me bat aM Mat st MY wmreaL NEW FD _ F150 Tradaln 88 HONDA PRELUDE CIF po•oW O Apktawa 1FTRF12UX4NB90668 p ('Ane,arer 1. cash Price ............. $ 23325.00(1) 2. Doom Payment Third Party Rebels A.stgre d to Credhor....................... 5000.00 t. ? D?arr?' s...TBBb:T.._?..-.217A........... C 5-2866 b0 rad.i v.r we maw ar A10- Mew OA" Total Dorm ,,,,,,,,,,., S 7886.000 1543FMI 3. Unpaid Balance of Cash Price (1 minus 2)........ ............ ...... . (3) ..... S 4. Amounts pale on your beha f (BaINr may be retaining a portion of theas amounts) To Insurance Companies for Crock Life Insurance (for term of contract) _....... .»...._. N/A t-NiA aot).-._..? onV _ Credit DINaiHy Insurance (for term of c $ r yA I t 9 (Term r ), To Public Officials (110. ( 5.0(1 E (a 50 ) a ti n feaa S i S t reg o ( -. s ra (10 for fling fees t 500 986.34 pit) for 1N1ss (nc11n Cash Prke) B f 1078.59 S t or To 1117A t To fo To-DEan, for daft FCC S St:-nn To for Y/A Total .».................,.....` ..?. .._.__..._._....... .. S 1 1 ii _ 59 (a) !L Amount Financed (3 chic 4).._._...........__.._...,........................ t 1 GS77. C9 A ANNUAL FINANCE Amount Total of Total Sale PERCENTAQE CHARGE Financed Payment prim l RATE Th• darn aaetlet the reds we The Nuum of cndl piviltlitl to Tbs sn+oum you wa t+ave The WW coo d Your punclees The men of your t oa YOU or On fr ON W Credit as • yeafy rate me Y hehaN merle InaMdrq your 06 =0 Payrrteet s,Ch.duN NUMber of Amount of hdn ?XP V'ft Front When Payments are due S u a ll (0 8%21 4 nnel 11A?- be: t ll lempsymerw N you pay off your debt early, you WE not haw to PAY a penalty- I&% Peymsnt You mug pay a late charge an to potion of each pa)mart raodved "1011, rat. t on to days low, The charge Y 2 percent of On IW amount or 111166.00 whichever Is 1 security Inlar..b You are 9" a security MMaraa In eta vettota being purchased. Contract Pleas, sea this mmrat for additional MMOnsgon on aacudty Interest, non dehult• the right b repulm miaria t of your debt In cud before do schedul d data, I prspayntartl wn.lty ltyoudo.ww1...w.. non rneel yew amrart oMapaYOrr, ==I= M venterNd. a you ra Ywdrq uMa IhY contract ....r ....,...w .w u.@* V err am a J,.e lu tr Wtelw NON-MODIFICATION DISCLOSURE Any change In thY contract neat be In wr" and dotted by you and the Creditor. D n: X Lw ACKNOWLEDGE YOU 9Y THE ARBITRATION TION PROVISION ON?TItE REVERSEE SIDE OFOTHIS CONTRACT. INCM0111 TO BUYER Do not sign this contract In blank You an entitlfid to an exact copy of the contract you sign. Keep it to protect your Isgal rights. Buyer (and Co-Buyer) acknowledge that ((1) before signing this 1Nltraet, Buyer (and Co-Buyer) recelvslf an rev ewe a rue acomplately oiled In copy of this contract and (11) at the time of aril this contract, Buyer (end Co-Buyer) received a rue an completely filled in copy of this contract. BUY amm WYER slow sy sigrrlq dradar, Ir saw atiepY we caalaet I no other mined in a Separate bbaPnnwt anadwd b a" eoraraet. eta ssagns It to TMs Fa Moran M m fr. .arre ww w 1w N are MPZX MW AUUFU M Aamxalawra M ORIGINAL YOU MAY OBTAIN VEHICLE INSURAN FROM A PERSON OF YOUR CHOICE. YOU ARE NOT REQUIRED TO OBTI CREW LIFE, CREDIT DISABILITY A OTHER OPTIONAL INSURANCE, TI CONTRACT WILL NOT INCLUDE TH UNLESS YOU SKIN AND AGREE TO P THE PREMIUM. THIS CONTRACT DOES NOT INCLU LIABILITY INSURANCE COVERAGE F BODILY INJURY AND PROPEF DAMAGE CAUSED TO OTHERS. 0 Crea Llfe Insurer N/A $ Premium Inaured(s) Signature Credit O Dlseblllty Insurer N/A s romlum Insured Ipnaturo 0 Other Optional Insurance Term S N/A Insurer Premium Signature Credit Leta and Credit: DYabillq Inewana errs for eta term at ant contrast. 1M amount and ="._'X=y" In ¦ nnuae or agreement . You must Maus the veMsta N a chaps Y e I to t= stnowrt relow the creditor wthe More e be based on the cub vatus of E ? set time 4 but not more than the, Par ? Camp.h• ft%* ? a N/A 0edwwo Colblon ? Fire. Thaft•Combiesd Adrafonel Corrags O Towing and Labor ? Term Moo" (Eamab) premiums N/A ?Iabe!n!t) Qis boy Y lslN Wd (OP hen pwdiged 1 p a.4 N mfiru 1. Meet a?r.dL Th.lenr wed aerMeom a eve cwt anadadm wWW AM as bet h ye ataaud AddenAw wtldn Y InaaporaM btp iM. wwea. Us win for set dal anoesa," wavy le to fans on drY coma In 1110 imnib*W of Amamt FrArted wider SMhm A Buyer Program No. QUESTIONS? PLEASE CALL US AT 1.800.727-7000 Or Visit us at rtlynv forderedItcom 03•x01 EE HIBIT A ADDITIONAL AGREEMENTS A' *flyiawas and Shammy Nodes: You p I in UAL ftNlds when they eb dub You may P- your dNN ai n*I?r Wna wNhout pMlNly. Thla b a d0ple kdwaN aan4aol The adlwl kwla sharps you W".10 per V* . , Frl?inci The actual firaro FROM ? PrYnlwde*IfMr Ilan ft scheduled dabs or Ise than to sc wUW mount. The Oledbr will apply yaw payteetls &a b the canted and urgald pal M NN FMwba CIWP and #Nn b MNAmount FMlrroad The Gedbr sane the Fi ence Chaps by aoohM:a the Nwwl Piece; Rate b the QpeIW Amaat PMnal.d7ol the aokW Beer tlb ahpsid Amount Film Is outeWhdmp 0.1lMM trohlM is lepaaaseed, you VA not haw a right 10 labeble'Ne bortfect idea NM Gladbr apnNs. L Semoft h*re* You Rive the Creditor a aaculiy '„brat kc coral make she F. DNrult You will be In default ll: 1. The vNlbls and all pans or doer goods put on Me vehicle; 2. N money or goods received for the vehicle; and a N Insurance prenkams and service contracts Nuanced (Er Yom This secures Payment d all amounts you owe N *6 aongplpl. M also secures your other somernerNa In NO oonbact. ,. Q the of Ysltcb • WARRANTIES: You must tale tare of the vehicle and obey all lows In using IL You may not 90 or ant On vall", and you mud lap it free from the cakns at b"rs. You wB not use or pwM the use at the vat oWNde'd,the Ik1ed Stales, except for up to 30 days In Canada w --- VOW the prior wditn consent of No Credhar. B to vehicle le woudly ve" for personal use and to Creditor. or of a the vehtore manufacturer. exlende as written wnnwMy or servtoe aomrad eovoft SN vehlde wMMn ll0 days from lee dab of this contract, you (the Implied werretbe of Merchantability and aurae for a particular purpose eoveft the vahbfe. Othwwbe; you understand and agree that ri we no such bnpdW warcwtim 0. Insurance, You must insure yourself and Me Creditor against ices or damage le the vshicle. The Credhor mud approvy Me We and amount of Irwinvkcs. II the Omdnor obtain a on Inaumnoo or service contracts, the Cmdftor will subtrapl?do refund from what you over. Whether or not thevent' Is kmmved, you must pay for R N N Is lost, damaged, or destroy" .. i d4 4- N ?., N a charge for vehicle Ideumnce is shown on ae`front the Cmaor veil try to bur the endivesQ?a checked Mr the term shown. The Creditor Is not IaWe mgt'. I he cannot do as N Mersa coverages cat more am Ow amount shown for insurance, the *96" may buy Mtem for a direr femn or he may give you aedl for lee amoure dawn. N he cannot buy any insurance. he well glee you credit for the amourd shown. The aadt will be made to the last payments due. 1. You do not make a when it Is dWi or ?o(F 2..YpapuppP" WI e?onrp lpq Not *ft. On,ypydt 8. Yailr vM 1da Is Nbaby MY 16*4:%bot 06 sulhorky and b rAt plool%* and III - is you; or 4. You ft a bwku ft pNMal or one Is filed against you; or L You de net keep any other premise In NO aorea , I N you are In debut, the Cradlor may m*ft you b M arm lee Ne uuPMd MIamN FM?a11ad, the anti, utiNp Fit of Fhance, Charge and iM seer enaade due under ft sorbed Hie NPoeee. peke.bldc)•the velres,im meAw an tahe found in 01oh•t a velydM wharref' Foess ew and hold for You. N the vW*b Is Wan back he will send you a nopoe. The notice wB say Ned you may, redeem (by baclQ the YdOdL R wB W- allow lee amount tts-F1 Is redeem. You RW redeem ft "Noe up b In Ime the Credbr tab it or agrees to ad L N you do not redeem the vehicle. It wB be add. The Ctedka will use ft. m** from the anti, less the slowed ehdpaneee, b pay the amount 80 owed on ere , - I I Ehperres paid a a dkab result of having to retake the vahtote, hold it for We. and ant it are, as pamrpad by law, allowed expanses. LawyeW bet and legal cosh permitted by few are slowed, loo. The Credlor will pay you any money left (a surplus). You will pay any moray ant owing offer the sale to to Creditor. N you do not pay rile amount when the Creditor asks, the Creditor may charge you Merest at five highest lawful We unill you pay. G. Consumer. Reports: You authoft FIrm consumer ad Motor Credit Com- parry to obtain consumer credit we& bureaus for any rowan and at any dine In con- nection with We cortrad t. H: General: To contact ford Motor Credit CoMpa y about Nrs account, call 1-800-727-7000. Abm you may melee address and otter selected changes at www.bnbrodk.oo n. The law of Pow sylvanle applies to this cordmot. N Me low doe not allow as of On agreements In this contract, l he ones that are not slowed wB be vols. The red of ere contract will still be good. NOTICE • ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL 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 abhor V ' Buyers Gu ` N you are buying a used wdrde with the contract, federal regulations may mWtro a ape" Buyers Guide to be displayed on the window, d 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. E. Lab Charge: You will have to pay a late charge on the portion of each payment nods more than ken days late. The charge Is not ascuse ofyour on the default a or mean to you can pa ekd p melting f payments after they are due. The Creditor may take the steps sal forth H Mrs contract, N there Is any default. GUARANTY To cause des Seller to ad to vehicle described on the horn of this contract to the Buyer, on crwk each parson who elps below as s'Guqr guarantees he payment of thb contract, This means Mho I Me Buyer left to pay any money that is owed on tlra oamrid"wch one who sipm as a guarantor will pay it when asked Each person who dgns below agrees Mot he will be Aube for l he whoa amount owed even I one or more other parsons also dgns this Guaranty. He am awess to be sable even N to Creditor does ads or more of In bloaI q (a) gives the Buyer more alma b pay one or more paymenn, or (b) Mhes a release In full or in pert b any of the other Gusma m, or (c) release any security. Each Guarantor der states to he has moolved a completed copy of this contract and Mrs Misoaray at the time of &W 4 A Guarantor Address ttuaranta READ TU(§ ARBITRATION PROVISION CAREFULLY AND W ITS ENTIRETY ARBITRATION Arbemtbn Is a method d aadvhp calm. dapuls. or awhUoversy (Coleadvay, a `)Minn') WNW Bkg a Iswsufl in cotat-Ektw you orCrodtor (NW or1weq (mdh. a YaanSyy?? may choose at any am, after a lawsuit Is iked, b how any Claim misled b this awn act, touf, a oahwvtsx hacl decided by adbikaNaa Such Gone" lndude but ere mot llmiked b lhe 1) Claims in You and ue, our Cblae regarding the Mupotaft% scope, or valft of are daua, or a d baue; Ste) Gahm be?a this any hereaAtkhp pwhesctldn rolaS Nnduding wlh de or arty eu fi Maaorelap wNh ifr rd Darlea who do det sign this convact. RIONTM YOU ADD W! AGREilE TO IB11E UP R ? you or we chow: is sroaeee a wan. hen you and We so. b Wales the (Wlovtrg tiphlc • RIGHT TO A TTRpI?AALL,, WHETHER BY A JUDGE OR JURY • RIGHT TO PARTMATE AS A CLASS R 11'ATIVE OR A Cl ASS MEMBER IN ANY CLASS CLAIM YOU MAY HAVE AGAINST US WHETHER IN COUNT • BROAD MOM TO OMICOVIhW AS AM AVAIL BLE 01 A LAWSUIT • NOW TO APPEAL THE DECISION OF AN ARBITRATOR • OTHER RKWFS THATAM AVAILABLE N A LAWSUIT j p You Aed Yea De Nd.2ft Ilse a a Clekn Is arbNrabd. you and era WE COWM to have tics IWowkhp rI? without w on g this arolwon 2) F plweton a o any tam t) Right to Bs N donna Right to entaa lea rawly Mond b to vdhidls wMtlw ap bn(e w1 urn a cad of Isar he adbn b arda0e the albMralol't dtNWdn; end 1) Wgha b repel set a suthorly. Ellher Pa o d Irty ? ? wq aaodatlon below and to other Party b alai arbitration. The oppaoa m rubs lee 'RCuy may be 11 • Nnulm Adillmilm Association (*AAA'), at S-.0?90p..779.7M7M, or wwwadr all • J AJAa uric, al 1400446-1 or wwacjemssaraom; • NaNaW Mblratbn 1aruNrL eI I4W .47428'11, or wvmrjA @runLcom. If lore b a oodtect 1aMwen lee i#dss end tlub aorMreot, lea o0ranol Mel 1ovwn This oaWed b sui>]al to see Falderal Arbitration Act (1 U.S.C. I 1 at "CO and In Paths -Mules of Evidence. The ad laMon I ' 'r r Mall be In wOM with a slppe ft _pI Im We will lay Your OW Ies , , " abltuabe less and evenses (not k cludim Mlaney lea, W. Mgt wMea?le bow arm r poWes In swtW hea 8125. We wB?pay to whole SBnp mowed loth IkM Any Rehear d SNe abws.tlal(FR unrtaw e ardomed. rdnmaara Fwee..atarnwarwu M "'PRW- Ford Motor Credit Company P,O. Box 3076 COLUMBIA, MD 21045.6076 (800) 677-0730 PO XWO0200027 NICHOLAS D. GOLDERMANN 9 CHESTNUT ST # 1 MOUNTHOLLYSPRINGS PA 17065-1306 Date of Repossession 10-062005 Date of Notice Date of Contract 10-062005 08-142004 Account Number. 037541858 Buyer NICHOLAS D. GOLDERMANN Cobuver DESCRIPTION OF PROPERTY Year 2004 Make FORD Q New ? Used Vehicle Identification Number: 1 FTRFI2VYX4NBfx)868 Model F1S0 Body (4(2) NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above because you broke promises in our agreanent. x? PRIVATE SALE: We ON sell the property described above at private sale sometime alter 16 days from the Date of Notice shown above unless redeemed by you prior to such sale. ? PUBLIC SALE: We will sell the property described above at public sale to the highest bidder on the date below (or any adiormment date). The sale will be held as follows: Date of Sale Time of SW Place of Sale You may attend the sale and bring bidders if you want. NOTICE OF REPOSSESSION The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number above. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may tail 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 BEN __ REC VERY S PA HOW TO GET YOUR PROPERTY BACK To get your property back, pay us this amount by certified check or money order before the vehicle Is add. Unpaid Balance $ 15,369.05 Plus Costs: Repo Expenses $ 385.00 $ Plus Late Charges $ 11.66 Less Finance Charge Rebate $ Lou Insurance Premium Rebate $ TOTAL $ 15,785.71 (Plus expenses incurred 9 default at the time of repossession exceeded 15 days and less rebate received after the date of this notice.) Your property won't be sold until 16 days after the date of this notice at the EARLIEST. After that you can still get it back any time before We actually sold. If you do, we'll have no further claim on A. But the longer you wait, the more costs (including repairs) you may have to pay. If you have any questions about this, please call us. ? The property has been (or will be) returned to. (dealer/original creditor) Under our agreement with your dealer/original creditor, the dealer/original creditor is to sell the properly and pay you any money left over. If you awe money after the sale, you will pay it to the deeler/odprlel creditor. ? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the next 60 days or, in accordance with state law, by contacting this office. Thereafter, the personal property shell be disposed of accordingly. ? Creditor has assigned to its qualified Intermediary (91 Exchange, LLC) to rights (but not As obligations) with respect to the sale of each vehicle listed above. PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the vehicle's odometer Is not accurate for any reason, please contact us so that we can accuratey report the vehicles mileage. INSURANCE RIGHTS: If you don't want to get your property back, call the insurance company or the dealer/original creditor to make sure that any insurance has been cancelled. You have a right to get credit for all premium refunds. JESSICA A. SNYDER FFNA 11986-37 Jan 02 P-A-editions may NOT be -W. Printed . USA . CUSTOMER/CUSTOMER FILE EXHIBIT 13 Cy-..'??. ?- s v?t `t¢\f{rrS fir: ',a r 4 ? ; ?, a?`i Y s ? J ? {• f • ?'1 try "f? N.'• ?„! H ?st. t • r rJ a:-?. fyf$. J NJy .. .Mll`EVVVffV rt7?J• • SCE Nome IplyaQ'R?d?'r??hein CN&typeofmrlorurvioe: 'AAASWnpHr. {v/VV ?' ?G+?NJ I/'?Z?l _M4~ Mme... 4 CT 0 8 Uvonia, MI 48150 0 Dcr.ryCaMkerdoe o tr». 2 0 EWM W 0 ftftt cw&".* a ft$"Wk and "W- Dabdit " AMft NenAr A9dmw.0'rm an,.t C* s ft a 2 axw Pprp. Fee Hnina Arwi V" hrued Oue aweMr UC sc sH ItD RR U1007=43506 I Voko rcoo Fw F« F« Ffu F« BA.030778829 .? _ 0 RICHARD L. BUSH 71105 116D 6DD3 4678 352D RR 2 BOX 2101 A STROUDSBURG PA 18380 U1007/20543512 7005 116D 0003 4878 3568 E0423038401 JOSEPH MARINO V1007=543,J09 80 HARTFORD AVE BA,021666837 - -- NEWINGTON CT 06111 GARRY RUBENSTEIN 7005 1160 0003 4878 3537 - 7 809 EDISON AVE UNIT A` - v 7005 1160 0003 4876 3575 PHILIDELPHIA PA 19116 U1007/20543513 ? JJ-037541859 m - /NICHOLAS D. GOLDERMANN > ,- 9 CHESTNUT &T l11 70D5 11,60 DOQ3 4878 MOLINTHOLLYSPRINGS PA 17085.131 C = U1007720543510 3544 -- SK-032396180 RANDALL SCOTT --- --- p .S '* q PO BOX 848 _ •' Ic , " C CORNING NY 148304846 --- --- 41 t: .?i 01007120543511 711115 1160 0003 4878 3551 F C; 024613229 m 7? b i JOHN R. DALTON n ?. 12 JUDY DR -- CRESONNA PA 17929 - -- C " Toot N~rA Tar tWd,-wa Pkwee PMentller.Pr (Nrr»anxWep.mppyey .. trw.d by Seed Q Reoehied r ha OIAae See Privacy Act SutaRlant on Roan PS Form 3677, Folgw" 2002 0381 f o f2) Complete by Typewrnei; Ink, or Ban Point Pen Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 21045-6076 800 6770730 DATE: 2005-11-09 P0350800000086 NICHOLAS D. GOLDERMANN 9 CHESTNUT ST 1t 1 MOUNT HOLLY SPRINGS PA 17065-1306 STATEMENT OF SALE Account Number: 037541859 The following property has been sold. Year Make Model Vehicle Identification Number: 2004 FORD F150 1FTRF12WX4NB90668 Balance owing on your contract (1) $ 15,400.71 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 15.400.71 Deduct: gross proceeds of the sale (4) $ 11,400.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 4,00031 Add: Expenses of retaking and storing, and (6) $ 543.50 any attomeys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ 0.00 (8) $ 0.00 Other: (9) $ 4544.21 Deficiency" (800) 732-2264 DETROIT MI 48255-1941 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 85218-6508 P.O. BOX 55000 FFNA1IWO 01104 Previous editions may NOT be used. EXHIBIT cr -13 ? `f? U1 °? C a co I ,T-) R Attorneys 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) /69- / 1 J4 FORD MOTOR CREDIT COMPANY Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-5554 NICHOLAS D GOLDERMANN 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. Date: October 13, 2006 ti CERTIFICATE OF SERVICE I, Joann Needleman, 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: NICHOLAS D GOLDERMANN 1400 Bent Creek Blv Apt 112 Mechinicsburg, Pa 17050 Respect Submitted, MAUMP NEEDLEMAN, P.C. BY: N for Plaintiff DATED: October 13, 2006 VERIFICATION Barbara Buckwalter I, verify that I am the Authorized Representative for Plaintiff, Ford Motor Credit Company, and are duly authorized to take this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. e? DATE: OCT 0 9 2006 NICHOLAS D GOLDERMANN Our file no. 4355 48063000000037541859 C ' '. t' 71 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-05554 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS GOLDERMANN NICHOLAS D 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 GOLDERMANN NICHOLAS D but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 1400 BENT CREEK BLVD APT 112 NOT FOUND , as to GOLDERMANN NICHOLAS D MECHANICSBURG, PA 17050 nFFENDANT DOES NOT RESIDE AT 1400 BENT CREEK BLVD Sheriff's Costs: So answer Docketing 18.00 Service 9.68 Not Found 5.00 R. Thoma Kline Surcharge 10.00 Sheriff of Cu erland County 42.68.,: MAURICE & NEEDLEMAN (- ll/6616L 10/17/2006 Sworn and Subscribed to before me this day of , A. D. Curtis R. Long Prothonotary Office of the i3rotbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 01, 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