HomeMy WebLinkAbout06-5555ARBITRATION 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.
SHARI A TASKER
115 W Orange St
Shippensburg, Pa 17257
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. C5L -- S.5.55
el
CIVIL ACTION COMPLAINT
AVISO
Le ban demandado a usted en la Corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
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 cn 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 provisioner de esta demanda.
Usted puede perder dinero o sus propiedades u otros derechos
importantes para 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.
SHARI A TASKER
115 W Orange St
Shippensburg, Pa 17257
Defendant(s).
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 0(. - 5555 &LLTri
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, Shari A Tasker, is an individual who resides at 115 W Orange St
Shippensburg, Pa 17257.
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 September 4, 2003, 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 $14,028.30 at an annual percentage rate of 10.990%, in
order to purchase a certain motor vehicle, 2003 Ford Focus 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 $304.93 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 October 5, 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 $6800.00, however a balance of
$4557.14 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 $279.92 and which will continue to accrue.
11. The total amount due and owing at the time of the filing of this complaint is
$4837.06.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $4837.06, 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.
THOMi.,/R. P?CZYK, ESQUIRE
Attorne. for P ainti
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.
ARE
DATED: September 14, 2006
PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE 09/94/0
SHARI yer ( RCoTuyet) time, and Addle- (ndudny County end Zip Code) FAMILY RD-hERCU NC. SEP 1 0 20?
Bu
96 112 LOCUST ST. 170 YORK RD.
SHIPPENSBURS, PA 17257 CARLISLE, PA 17013 ?\ e a39 r!r -
...w....r...n?e..,.._x... ..we?wr:.wntee.draresdrriorfer?senmda. TM'CrhPrWahambMwisthemhpraolthewhkM Th
-Tom rah Pliw shown below is tire milk price. toy algmhg dds eamrect, you choose to buy an credit under the ogror maids on tle hart and bade of this contract.
7MEWf Yew and Make ttoekl 6VW tl Tnxft VeNde khratlcatlm Nutnbe use For Yrtddt Phtalwaed
FOCUS )0 Personal O Aodculami
003 FORD 1FAFP34P83W332502 ? Commerow
INSURANCE
Trede•in : N/A 6 N/A YOU MAY OBTAIN VEHICLE INSURANCE
Yaw and Male Oroas Afowarxa Amount Dhrkg
ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE.
1. Cash Price »,.......... »............. ..................... _..... ......... S IS955.00 (1)
2. Down Payment
Third Party Rebuts Assigned to CreMW .................._._..... $ FOB%- Be
Cash Down Payment ...._.._............. ......................... _.». $ 1600. 00
Trade-in $ N/A $ N/A S N/A
Yw eA hw.. a.w ra.e.. .aoa. owe
Total Down Payment .............. _........ __.._............... .._..... -._........ S 3608.00 (2)
3. Unpaid Balance of Cash Prim (t minus 2)......... .._....._. .............. $ 12355.00 (3)
4. Amounts paid on your behalf (Safer may be retaining a portion of these amounts)
To Insurance Companies for
Credit Life Insurance (for term of contract) $--fNiA
Credit Disability Insurance (for term of contract)....... ... $-?s"?A
(Term _J ontha (Estimate)) NiA
To Public Officials (1) for license (T 35+00 _), title a
registration (S N/A fees S N/A ;
(ii) for riling fees S 5.00;
(Iii) for taxes (riot in Cash Price) $ 882• S 946.30
To for Msasenger Service............. S N/A
T?ORD for EXTENDED SERU III PLSH 675.00
TcF_NILY FORD=MERCLU0au, NOTARY A DOG FEE $ 52.00
To for S N/A
Total ...... »....... __»...._ ..... .....»........__.__ . . _._._._....._ S 1673.30 (4)
5. Amount Financed (3 plus 4).... _..... .» _ ....... ............ ._........... $ 14AZB. 3_(!)
FEDERAL TRUTH-IN-LENDING DISCLOSURES
ANNUAL FINANCE Amount Total of ToW.Sale
PERCENTAGE CHARGE Financed Payments Price
RATE The dollar amount The amount of
crack provided to TM amours
you will haw She total coal
of your purchase on
The coat of your audit will
the
c
st
ou
or m
your
Yo
when you
?
Credit.
credit as a yearly rate o
y be
half have m
ade d includ
rg w
scheduled downpaymem
payments d $--,FAR?°ea
payment Schedule Number of Amount of Each when payments
C XPsyman" payment ere due
Your payment schedule - 5---304 93 (momhb statf+ig)
all be., 1 ifmai $
-X93_----? -
O
Prepayment: 11 you pay of your debt early, you will not have to Pay A penalty.
Late Payment: You must pay a late charge on the portion of each paymerd received mare
than to days tats. The Burgs is 2 percent of to We amours or $50.00 whichever is lees.
Security Interest: You are giving a seamy In crest M the vehicle being purchased
Contract: Please see this contract for additional iMamation on security Interest, ranpey-
default, the rlgluTo require repayment of your debt in full before the scheduled date, end
if you ado not meet your mama obiWtlam, you may bee ow V it that you em M1em:ing under this contract.
r r._e, a... aa.r rare a.. a. .h. ,r.hYa..nA ...r,.,r er and -alum for ma vaWde.
NON-MODIFICATION DISCLOSURE
Any change In thi contrast mu Ong' signed by you and the Cmdilor.
UYER: X
$16N3 SIGNS
BY T1AE ARBITRATION PROVISSIO VE READ THE AREVERSE SIDE OF THIS
CONTRACT.
NOTICE TO BUYER
Do not sign this contract In blank.
You are entitled to an exact copy of the contract you sign.
Keep it to protect your legal rights
Buyer and Co-Buyer) acknowledge that (q before signing this
Contract Buyer and Co-Buyer) received and reviewed a true
amppletely led in copy of this contract and (ii) at the
time of signing this contract. Buyer (and Co-Buyer) reeeTv_e_3
a true end Completely filled in copy of this contract.
X
B air" flit
By signing below. the Sear sample thl d Miter tore to Ntase in a "Pon"
assignment aasshad to a" mrarso% tbs • a rd r ct? lt
t? FAm/may ?? gy ? Tor.
coat
fit%7W-tt..rre 0`nW_"colon oar nor be
M
sea atAGA PUN AtrWnVmLL AWMCCINIM10
YOU ARE NOT REQUIRED TO Off
CREDIT LIFE, CREDIT DISABILITY
OTHER OPTIONAL INSURANCE.
CONTRACT WILL NOT INCLUDE T
UNLESS YOU SIGN AND AGREE TO
THE PREMIUM.
THIS CONTRACT DOES NOT INCL
LIABILITY INSURANCE COVERAGE
BODILY INJURY AND PROPE
DAMAGE CAUSED TO OTHERS.
O Credit Life
Insurer
to to
Premium Insured(s)
Signature
Credit
17 Disability
Insurer
$ 11
Premium Insured
Signature
D
Other Optiona(Insurance Term
Insurer $ P wit
remium
f nit re
Credit Ufa and Credit DlsaWalryy insurance are
for the sum of the contraeL The amount and
oovsragss sn shden In a notice or agreement
given to you today.
You must Insure the vehicle, It a charge Is
shown below the Creditor will try to buy the
coverages Ancient for the term shown.
will be based on 1M ash value of
tM vehicle at time of lose, but not more than
the limits of the policy. .1
? Comprehensive C3 $! A Deducible
Collision
? Fire- ThaRLanb'vrod Addlional Coverage
I7 Toeing and Labor
? Tenth Months (Fstlmats)
premium $ _11713-
? oem Catheetladen Wolvr Addendwa (0ptkee0
If ads box Is chocwd you have purchased a debt
concelatlon waiver. Purchase of this owersoe is
ano oorman 1.6 w debt coto obtain cradi. ndetetat xvNeerr we urmal
set
h>DdpoMad
fords In ee attached Addenxm which Is
into the conesa The price for 1M debt renubhtdon
waives is set font on ids contract In The Nomination
of Amount Financed under Section 4.
Program No.
QUESTIONS?
PLEASE CALL US AT 1-800-727-7000
or
Visa as at wwwJordcrodit.com
11t:0at
ORIGINAL
exHisrt
A - I
ADDITIONAL AGREEMENTS
A. P"aft and Summary Nodes: You must make V
payments in U.S. funds when they are due. You mW prepay your
MM at any tams without penalty: This Is a ehmpialntersel uanVlict.
The scluai %W= charge you Was to-pay will deperq o"Aff
psymm patterns. The actual Inarm charge a" closed the
diedaeed Finance Charge N you make your payments kW gnat
the scheduled data or In Ise tern the aH &A-d atneernt, The
Creditor will apply your payments first to to owned and unpaid
pad of the Finer= Charge end then to the Amount Financed, The
Cmdlkw earns the Flreroo Charge by appyttg to Amur)
PsroaNage Rats b fire trhpeld AmohaN fTnwnad ter the 6Ca1e1
tmn th unpakl Amount Fk?arlced N N 1M vehidr:o
repoee•ssed, you wE net crew a right b?reln's aR elfin cattrat3
unties tin Creditor apes.
& Security Interest; You give the Creditor a security Interest in:
1. The vehicle and d parts or other goods put on to voice;
2. AN money or goods received for the vehicle; and
3. AN htaurence Premiums and service contracts financed for you.
The secures payment of ea anounts you owe In this COMICIL It
ado secures your other agreements ten We contract.
C. Use of Vehicle - WARRANTIES: You most lake csr of
are mhids and obey as laws In using IL You may teat see or rent
the vehicle, and you must beep it hoe Iron am dams at others.
You will not use or permit the use of the vehicle oubMe of to
United States, except for up to 30 days In Canada or Modco,
wahoul the prior vMNen consent of ON Creditor. H the vehicle Is
d a type rnormaly used for persarnl use and the Creditor. or
the Vehol•'a manuoehtrar, attEkil a wrlttsn warranty or
service contrail covering the vehiOle within 90 days from the
date of this contract, You got knOW warranties of
nnrchantabilhy and tlbteee Ion a particular purpose covering
the vehicle. Otherwise, you understand and agree that there
we no such Implied warrantee.
D. Inaxancen You must Insure yourself and the Creditor agepnt
loss or damage to the vehicle. The Creditor must approve•the
type and amount of Instsanco. If the Creditor obtains a refund on
Insurance or service oonlacb, the Crsdkor will subtract the.
refund from what you owe. Whether or not the Vehets is'
Insured, you must pay for It N it Is loot damaged, br
destroyed.
N a charge for vehicle insurance is shown an the front the
Creditor will try to bury the coverages docked for the term shown.
The Creditor is riot liable, though, N he cannot do sot ill these
coverages coat more than due araunt shown for Insurance, the
Creditor may buy them for a shorter term or he may give you
erect for the amount shown. N he cannot buy any Insurance. he
wig give you credit for the arrant shown. The credit will be made
to the last payments dua
E. Late Chugs: You will have to pay a late charge on the
portion of each payment, ma)e more than sect days tale. The
Marge is shown on the from. Acceptance of a lots pymerkdoes
not excuse your default or mean that you can keep making
payments after they are duo. The Creditor may take the steps set
forth in this contract, N there to any Maud.
F. Default: You wE be In del" II:
1. You do not make a payment when it Is due; br ' r
2. You gam false or mislisading Information on Your aedl the co~ or
3. Y eeb:edb by any bd ogle or federal
pmnq* and an corm"d y
or
Ishill to you; 4, You fie a bwlkr p" pegaon or one N Nod against you; or
S. You do not keep any othw promise In this contract.
N you are In do" pro Creplor may rel tilre you b pay at one
the Wpald Amount Financed, the awned and unpaid pail of the
Ronnce Charge and at other amounts due Wider who contract.
He may tepossea (late beck) the vehicle. too No may woo
take goods lead in or on tin vehicle when repossessed and
had them for you.
It the vehicle Is taken boot, he Will send you a notice. The notice
will say that you may redeem (byr bads) to vehicle. it will see
slow the amount needed to redeem. You may redeem the
vehicle up to de time to Creditor date t or egress to ad N. N
you do not redeem the vehicle, it will be sold.
The Creditor will use the many from sea sale, Ises the allowed
expenses, to pay the amount eta owed on see CCN*W.
Expenses paid as a a" result of having to retake gar veklole,
hold it for eats, and ad it are, as permitted by allowed
expenses. Lawyers' fees and legal costs permitted by law are
etio K too. The Creditor wig bey you any MOW Ian (a
surplus). You Will pay any many am owing after do sate to tin
Creditor. N you do not pay this amount when the Credbr a"
the Creditor may charge you Noted at the highest lawful rate
unntg you pay.
G,' Consuher Reports: You authorize Fad Moor Credt Com-
pany to obtain conaraner as& reports from consumer reporting
agences (aedN bureaus) for any reason and at any Nme In con.
nation with We contract.
1L General: To contact Fond Motor Credit Company about't is
smmun , call 1400727-70110. A )s% you may "lake address wd
other selected changes at www.tordaetitwn. The law Of Pwm-
sywaia appfea to this contract. N the law dose not stow ON of the
agreements In the c:ortract, the ens that are not allowed will be
void. The rest of this contract will Will 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 bEBTOR SHALL NOT EXCEED AMOUNTS PAID BY
THEPEBTOR HEREUNDER.
Used Motor VeW&% Buyers Guilds It you are buying a used
vehicle with this contract, federal regulations may require a
special Buyers Guide to be deplayed an Me window of go
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 to sell to vehicle described on the front of this contract to the Buyer, on credit each person who signs below as
a 'Guarantor' guarantees the payment of tie conbaCt. This means that If the Buyer faits to pay aey money that is owed ort We
Contract, each one who signs as a guarantor will pay it when asked Each parson who signs below agrees mat he will be Ilabte k1r
the whole aheunt owed even if one or more other persons also signs Iris Guaranty. He also agrees to be gable even It the Creditor
does one or mare of the fdloWng: (a) gives the Buyer more tkne 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 tot he has received a Computed copy of this
contract and this Guaranty at the time of signing.
Guarantor Address
Guarantor Address
nee N•lo. •.lI•I.VI. fnV?NIVi? YNrf?rY,?T Nr{V rn {r 0•GR{IRC{ ? ?? ? \? _??;
ARBITRATION
n is a method of resolving wry am, dispute, or controversy (cdlsetlvety, a 'Claim') witwut tang a lawsuit in court. Either y
w ('us' a'WS`? teschParly") d my choose at ay time, Including after a ewsut a sled, b thave any CIaIn rooted o me a
died bee ttnbtraf? Such Game inclnxe but are not amaed o to t) CleMks N aahtraa, art, «othawise;
ngardrg to Intshpretstlah, sttope, « vagdlty d this t:laues, « dMrbU?y d ieetae: yj Clakrre ?yrxt and Ue. <
fie. agante, sudxasems, aeagns. ehAadaries, or afRlalas; 4 Clalehs areltg out o(a raatkg to yes sppaadon for awn. a
of anY rauNinO treneactlon a' nlydomnhiP. odudkg tint with tk• teaor. « wy axth raetanikip wth turd pwdee who do n
RIGHTS YOU AND YsE AGREE TO GNE UP
W. you or we ON. a , Von you and we agree to waive the following rights:
• RIGHT TO A TRIAL. WHETHER BY A JUDOS OR JURY
• A OO INS U1111 WHETHER IN COURT OR 94 AARBITRA? n 1 E OR A CLASS MEMBER IN ANY CLASS CLAIM YOU MAY N/
• BROAD RIGHTS TO DISCOVERY AS ARE AVAILABLE IN A LAWSUIT
• RIGHT TO APPEAL THE DECISION OF AN ARBITRATOR
• OTHER RIGHTS THAT ARE AVALABLE N A LAWSUIT
hits You And We Do Not N
Give tl•: a Claim is aamt@d, you and we will continue to haw 10
aonra?an provision rot no any caasrc t) RI TRW to Wo b Me Danknklpelpry In court 2) Right o arntonxa this a ?kncud kterksi k?i daww
law nswsan ~w arbgrat« As ahiMhomty. tl action to onforoo It* abtreta's dscelaK and 4) Right to request to mosem
cow or
Either Paft
obtained + any aseooatan below and the cow Party to I
sts%j ilcm The appgade rules (the 'Rules' may
ftom the association.
• American Anbllnedon Association ('AAA7 at 1-gga776-7878, or ww,r.adr erg;
J.A.M.S.IEMeputs w t g00J48 1060 or www)wn conk
NsaorW Arbarathen Fenrw ar i.adak,l1L2A71 N ? .,n.a,..,,...w..
Of
This
Is &A*d to the
shall be In contract wtHw with a suix
pi
FDtawr-e L*01 prwwellaa agrdmarwrt
"'PRN••'
Ford Motor Credit Company
P.O. Box 3076
COLUMBIA, MD 21045-6076
(600) 677-0730
P03SC7t10200014
SHARI A. TASKER
115 W ORANGE ST
SHIPPENSBURG PA 17257
Date of Repossession 01-12-2006
Date of Notice Date of Contract
01-132006 09.04-2003
Account Number: 035259469
BgLw SHARI A. TASKER
Cobuyer
DESCRIPTION OF PROPERTY
Year
2003 Make
FORD ? New
? Used
Vehicle identification Number:
1FAFP34P83W332502
Model
FOCUS Body
. R
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
Mx PRIVATE SALE: We will sell the property described above at
private sale sometime after 15 days from the Date of Notice
shown above unless redeemed by you prior to such sale.
? PUBLIC SALE: We wM sell the property described above at public
sale to the highest bidder on the date below (or any adjournment
date). The sale will be held as folio":
Date of Sale Time of Sale 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, orwrite 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 unde
your agreement: 1) The buyer and any cobuyer named above;
2) Any dealer/original creditor named below; 3) If there are other
people, they are named on an attachment sent with this notice.
The property is presently stored at BEN RECOVERY BEN
EC 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 sold.
Unpaid Balance $ 10,980.34
Plus Costs: Repo Expenses $ 200,00
Plus Late Charges $ 18.30
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 11,198.64
(Plus expenses incurred if 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 15 days after the date of this notice at
the EARLIEST. After that you can slip get it back any time before irs
actually sold.
If you do, we'll have no further claim on W. But the longer you wail, the
more costs (including repairs) you may have to pay.
It you have any questions about this, please call us-
0 The property has been (or will be) returned to:
(dealer/original creditor)
Under our agreement with your dealerloriginal creditor, the dealer/original creditor is to sell the property and pay you any money left over. If you owe money
after the sale, you will pay it to the dealerloriginal creditor.
? PERSONAL PROPERTY: Any personal property found In the vehicle may be reclaimed by you within the next 80 days or, in accordance with state law, by
contacting this office. Thereafter, the personal property shall be disposed of accordingly.
? Creditor has assigned to its qualified intermediary (01 Exchange, LLC) its rights (but not its 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 accurately report the vehloWs mileage.
INSURANCE RIGHTS: It you don't want to get your properly 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 11eea.37 Jan 02 PwA-a edkbrro may NOT be used. CUSTOMER/CUSTOMER FILE
Printed in U.S.A.
OBIT
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38120 Amrhein
Livonia, M148150
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KAREN P. BARBER
48 RINEHART LN
5370
2 WAYNESBURG PA'
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CR-034752640
CHARLIE M. DAMS
60M NEW FOREST CT WALDORF MD 206D3.4748T 4
p? v 00112110559377
11-06259489
SHARI A. T KER
115 W ORANGE ST
SHIPPENSBURG PA 17257
B.
U01121zos59378
JJ-035064869
MISTI L. COYLE
7 180 SW ITH CT
YORK PA 17404
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RICKY A• WEEST 1r
6301 ROUTE 225
ELIZABETHVILLE PA 17023
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Ford Motor Credit Company
PO BOX 3076
COLUMBIA MD 21045-6076
800 6770730
DATE: 2006-02-22
P04411100000045
SHARI A. TASKER
115 W ORANGE ST
SHIPPENSBURG PA 17257
STATEMENT OF SALE
Account Number: 035259489
The following property has been sold.
Year Make Model
2003 FORD FOCUS
Balance owing on your contract
Vehicle Identification Number:
1FAFP34P83W332502
Deduct: Finance Charge Rebate
Balance less Finance Charge Rebate (1 - 2)
Deduct: gross proceeds of the sale
Balance less gross proceeds of the sale (3 - 4)
Add: Expenses of retaking and storing, and
any attorneys' fees allowed by law, and
expenses of reconditioning and selling.
Deduct: Insurance Premium Rebate
Other:
(1) $ 10, 998.64
(3) $ 10.998.64
(5) $ 4,198.64
(9) $ 4557.14
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.
** 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 EXHIBIT
(800) 732-2264 DETROIT MI 48255-1941
FFNA11990 01104 Previous editions may NOT be used.
(2) $ 0.00
(4) $ 6,800.00
(6) $ 358.50
(7) $ 0.00
(8) $ 0.00
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MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(21--)) / ZS9 I 1 J4
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
SHARI A TASKER
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 06-5555
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.
J(
A
for Plaintiff
ESQ
Date: October 13, 2006
R .?
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:
SHARI A TASKER
115 W Orange St
Shippensburg, Pa 17257
MAU44CE "EEDLEMAN, P.C.
BY:
for Plaintiff
DATED: October 13, 2006
VERIFICATION
I,
Barbara Buckwalter 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: GC,?'?1
`
?Q
DATE: OCT 0 9 2006
SHARI A TASKER
Our file no. 4515
48063000000035259489
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-05555 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
TASKER SHARI
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
TASKER SHARI A the
DEFENDANT
at 1130:00 HOURS, on the 4th day of October , 2006
at 115 W ORANGE STREET
SHIPPENSBURG, PA 17257 by handing to
SHARI A TASKER
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 17.60
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
45.60,.' 10/06/2006
MAURICE & NEEDLEMAN
Sworn and Subscibed to By: <??C
1-14
before me this day Deputy She iff
of A. D.
MAURICE & NEEDLE AN, P.C.
BY: Joann Needleman, sq.
Identification No. 74276
Charlene A. Taylor, Esq?
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
IN /69_/101
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
SHARI A TASKER
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 06-5555
(X) Notice is hereby given that a judgment in the above-captioned matter has
been entered against you in the amount of $3979.52 on 0 LV? ? -0 7
(X) A copy of all documents filed with the Prothonotary in support of the
within judgment is enclosed.
Prothonotary/Clerk
by: Lu (c
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
't'elephone No.: 215-789-7161
(This Notice is given in accordance with Pa.R.C.P. §236)
MAURICE & NEEDLE AN, P.C.
BY: Joann Needleman, sq.
Identification No. 74276
Charlene A. Taylor, Esq
Identification No. 2039210
i
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(21 ?) izsy- iidi
FORD MOTOR CRED T COMPANY CUMBERLAND COUNTY COURT OF
Plaintiff COMMON PLEAS
V. I CASE NO. 06-5555
SHARI A TASKER
Defendant(s)
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
No answer havipg been filed in the above Civil Action, kindly enter Judgment in favor of
Plaintiff, and against Defendant, SHARI A TASKER in the amount as follows:
Principal Amount $ 3258.24
Interest to Date $ 721.28
Costs $ 0.00
,Attorneys Fees $ 0.00
TOTAL $ 3979.52
MAURICE & NEEDLEMAN, P.C.
Date: September 17, 2 07
BY:
JOM)qEEDLEMAN, ESQ.
At ev for Plaintiff
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq
Identification No. 20392f0
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7161
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF
Plaintiff COMMON PLEAS
V. CASE NO. 06-5555
SHARI A TASKER
Defendant(s)
AFFIDAVIT OF MAIL SERVICE
STATE OF PENNSYLVANIA
COUNTY OF PHILADELPHIA
SS.
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she is an attorney at law and that on 11/ 01/2006 she mailed a written Notice of
Intention to File the Pr4ecipe to Defendant, SHARI A TASKER, at 115 W ORANGE ST ,
SHIPPENSBURG, PA !17257 by regular and certified mail, article nos. 7155 5474 4100 4339
7786. 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.
MAURI
BY:
JO
At
SWORN TO AND SUBSCRIBED 41
before me this 7 day
of' ' 200
Notary%y Public 6e-?J?
i
I
DLEMAN, P.C.
1 EDLEMAN, ESQ.
for Plaintiff
oi41 pNW H OF PENNSYLVANIA
N6Hafif't{ Seal
Agnes SLIM ntl, Notary Public
C1ty Of (oN19(1E1Phia, PHkdelphia County
My CommMion Expims Jan. 20,20M
Membef, Pennsylvania Association of Notaries
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Charlene A. Taylor, Esq
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103,
Attorneys for Plaintiff
(21-'))'169- /161
FORD MOTOR CRED T COMPANY CUMBERLAND COUNTY COURT OF
Plaintiff COMMON PLEAS
V. I CASE NO. 06-5555
SHARI A TASKER
Defendant(s)
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on
11/01/2006 to Defendant, SHARI A TASKER, 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 11/01/2006, a copy of the receipt for certified mailing to the Defendant and
affidavits of service of said notice are all attached hereto.
MAURICE & NEEDLEMAN, P.C.
BY:
J
for Plaintiff
, ESQ.
Date: September 17, 2007
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276',
Charlene A. Taylor, Esq.!
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(215) /69-/161
FORD MOTOR CREDI COMPANY
Plaintiff
V.
SHARI A TASKER
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 06-5555
CERTIFICATION OF ADDRESSES
It is hereby certified that the parties have the following addresses:
Plaintiff- FORD MOTOR CREDIT COMPANY
P.O. Box 6058
MESA AZ 85216
MAURICE & NEEDLEMAN, P.C.
BY:
JgAYIYNEEDLEMAN, ESQ.
A(ttq(mev for Plaintiff
Date: September 17, 2Q07
Defendant: SHARI A TASKER,
115 W RANGE ST,
SHIPPENSBURG, PA 17257
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 742761
Charlene A. Taylor, Esq?
Identification No. 20392
935 One Penn Center
1617 John F. Kennedy lvd
Philadelphia, PA 19103,
(215) 789-7161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
SHARI A TASKER
Defendant(s)
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 06-5555
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
SS.
COUNTY OF PHILADELPHIA
I, 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, SHARI A
TASKER , is over 18 y ars 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
BY:
SWORN TO AND SUBSCRIBED
before me this day
of , 2007
Notary Public
DLEMAN, P.C.
for
LEMAN, ESQ.
C IMMONV?EALTH OF PENNSYLVANIA
Notarial Seal
Apses Belland, Notary Public
City Of Phlladelphia,
re
My Cwnbslon EVree Jan. 20 ,2009
Member, Pennsylvania Association of Notaries
Suite 935, One Penn Center
1617 John F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.665,1133
fax 21 S.S63.8970
www.mnlawpc.com
Donald S. Maurice
Member NJ Bar
Board Certified
Creditors' Rights Law
American Board of Certification
Joann Needleman
Member PA 9 NJ Bar
Thomas R. Dominczyk
Member NJ & PA Bar
Sondra J. Sutton•Simanski
Member NJ 8 NY Bar
Nove?nber 1, 2006
Our File No. 4515
VIA (CERTIFIED & REGULAR MAIL
SHARI A TASKER
115 ? V ORANGE ST
SH PENSBURG, PA 17257
RE: FORD MOTOR CREDIT COMPANY v. SHARI A
TASKER
CUMBERLAND COUNTY COURT OF COMMON
PLEAS, CASE NO. 06-5555
Dear SHARI A TASKER:
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 P aintiffs Complaint served upon you on 10/04/2006. Unless an answer
to P aintiff 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
offi6e at 908-575-0220 ex. 21.
Thank you for your prompt attention to this matter.
New Jersey Office
MAURICE 6 NEEDLEMAN, P.C.
250 Route 26 West
Suite 203
Bridgewater, NJ 08807
tel. 908375.0220
fax 908.S75.0632
CORRESPONDENCE IS AN ATTEMPT TO COLLECT A
C, AND ANY INFORMATION OBTAINED WILL BE USED
THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needle ,Esq.
Identification No. 7 276
Thomas R. Dominc yk, Esq.
Identification No. 8 248
935 One Penn Cent r
1617 John F. Kenn dy Blvd
Philadelphia, PA 1 103
(215) 789-7154
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
SHARI A TASKED
Defendantrs
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 06-5555
H
TO: SHARI A
115 W,OI
YOU ARE
WRITTEN AP E1
WRITING WttH
CLAIMS SET FO
FROM THE DAT]
AGAINST YOU
PROPERTY OR
YOU Ski
DO NOT HAVE
BELOW. THIS O
HIRING A LA
IF YOU C
ABLE TO PRbV
FEE:
IMPORTANT NOTICE
rASKER DATE: November 1, 2006
ANGE ST
iBURG. PA 17257
N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
RANCE PERSONALLY OR BY ATTORNEY AND FILE IN
HE COURT YOUR DEFENSES OR OBJECTIONS TO THE
.TH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS
OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED
ITHOUT A HEARING AND YOU MAY LOSE YOUR
CHER IMPORTANT RIGHTS.
fLD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
FICE CAN PROVIDE YOU WITH INFORMATION ABOUT
JOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
MAURI NEEDLEMAN, P.C.
BY
N DLEMAN, ESQ
or ey for Plaintiff
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MAU ICE & NEEDLEMAN, P.C.
.935 ne.Penn Center E -
Phila elphia, PA 19103
n.
SECTION ON DELIVERY
A Signat ( ? Addle. er? A m)
7155 5474 410Q 4331 7766
B. ec Iv y: (Please Print C47py) RETURN RECEIPT REQUESTED
?l _ i r ' A 'd dor
C.,Date'of 61ivsry Article Addressed To:
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D. Address s'sAddress(nolNUentFrMAddressUsedbySander.) IHlII111tIIlIlItllI1111t1111iI111tI111tI111t1111I1tI111IIIIII
Secondary ddre85,8Wte,Apl,Floor (Plow-so Print Claarly) Shari A. Tasker
115 W Orange St
beLveryAdress---_. Shippensburg PA 17257-1742
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FORD MOTOR CREDIT COMPANY :No. 06-5555
Plaintiff
vs.
SHARI A TASKER :CIVIL ACTION
r'
Defendant
3cz w :
PRAECIPE FOR SUBSTITUTION OF COUNSEL TO THE PROTHONOTARY:
Kindly substitute Lloyd S. Markind, Esquire of the law offices of Sklar - Markind, 102
Browning Lane, Building B, Ste 1, Cherry Hill, New Jersey 08003 as counsel for the Plaintiff in
the above entitled matter. The undersigned hereby consents to this substitution.
Lloyd S. Markind, Esquire
Superseding Attorney
Sklar - Markind
102 Browning Lane, Bldg B, Ste 1
Cherry Hill, NJ 08003
ID #52507
i
Joann Needleman, Esquire*
Withdrawing attorney
Maurice & Needleman, P.C.
935 One Penn Center
Philadelphia, PA 19103
ID#74276
Dated: January 23, 2013
Dated: January 23, 2013
* Signed with permission of Joann Needleman, Esq.
FILE NO.: FT110706