HomeMy WebLinkAbout06-6132ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 1'9103
(215) 789-7161
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
REBECCA HAWBAKER
1125 Harrisburg Pike Apt. 7
Carlisle, Pa 17013 .
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Case No. 01. -- ?p 132.._ (2;U U 41, ?
CIVIL ACTION COMPLAINT
A V ISO
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 re4uested 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 OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Le han demandado a usted en la corte. Si usted quiere defendese
de estas demandas expuestas en ]as 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
defenses 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 pnde 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.
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. 14276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7161
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
REBECCA HAWBAKER
1125 Harrisburg Pike Apt. 7
Carlisle, Pa 17013
Defendant(s).
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Case No. Oo l,. tv t
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, Rebecca Hawbaker, is an individual who resides at 1125 Harrisburg
Pike Apt. 7 Carli4e, Pa 17013.
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 November 6, 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 $14,779.04 at an annual percentage rate of 18.000%, 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 $375.20 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 September 6, 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 $7600.00, however a balance of
$5719.24 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 Uddition to the foregoing, there is interest due and owing on the deficiency
balance which at this time amounts to $812.29 and which will continue to accrue.
11. The total amount due and owing at the time of the filing of this complaint is
$7228.18.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $7228.18, well as any additional interest and costs that may accrue and such other
and further relief as this Court may deem equitable and just.
4.
Respectfully submitted,
MAURICE & 1,WF'pLEMAN, P.C.
, ESQUIRE
VERIFICATION
I, JOANN NEEDLEMAN, 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:
DATED: October 16, 2006
PENNSYLVANIA OWFLE WFEREST VEHICLE RETAIL WSTALLM ICONYNACT
l+d co-e«wl Nrr rd Addrr P?d^0 Cewft a ao Cc&)
REBECCA N HANBAKER MCCAFFERTY FORD
125 HARRISBURG PIKE 6320 CARLISLE PIKE
LISLE PA 11013 MCCMARICSBUR PA J
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EXHIBIT
I_A_
_ ADDITIONAL AG EEWMI ---
WA M III
L' _:j'6yemmmla s w„e,StmemmaNOW vat May
k *a m Ain, » wlhaN IINIeNy7* be eNilvl. MMelaef adllraot
"I t BI"a"ry w
aylltret 4btBNe oharga you ?°"ew,dab oy RN >,?t?«NrIaa?
t0Yar wa m Amp tw rd"
Sw admddld dHba or bee 8mn Ste RlIMMI S Waft The
Qedb rr vS apple Your pWWO 8nt 0 to samneed and www Ow An"
a? tI mon"Wl iW? W pNrrredTar
PODattbps Role W M txlpda ANara1 11119 adutl
Sue pie mtpeld Aewuri FkWWW Is Ooa p. x.tYMlob is
MPOWNeK you wAl trot haw a"b oNmMs urdw
mesa the Cedbr apex.
R Sow* hHoost You pw the Ond or a todrNY Ndaeal In:
t. TM "Male and all pant or o1Mr goods put on 00 vahlds;
Y. Al many or goof remised br do WhMK and
S. Al NNlaaae werrNwn and "rube mWaft Bnanad'ibi you.
This Maxis poyal" d all aawun>soile ?? conpr q. h
*10 MOWN yearelfw agmemomle t .. .
C, Use of VNNew - WARRANTM You must tdw are of
So arstiole and obey all boa In using K. You nh-- nee sat e< nil
Se sreliele, and you mat lose N has from the OIaIrM d bdwta.
Yw wB rat mil or W" the use of the ve" "". -daps
(piled Stabs, AlmnX for up b 80 daya Car" or Me".
"broth one Prior "in" wn i of the orstmor. M Dw amde Is
N a hype rwrwrdy shed f« P«senM ail and Om Cradlor, M
aw vehicle's rmnr hicAls r, all! nde a WINO wawaay Of
Mrvfaa O«tbact cove ft this vehicle wM* 90 days from the
daM of OW eesrrad, you got NapNsd warranilm of
nwrohertrebMey ead Hine" for and?MNa covering
as a "NOW ONherwtsel YM
Al. AlUdh Nnpled warcr&- pt
boa or damage b the wrtiota The Creditor mat appmq 00
We adanunt of haeance. N theCedNor obtaNw a ftW an
NtAlnranoe or t m-m corireok..M Creditor we abbhspt t!e
milow tram what you VA's. Whother or not so vehide Is
batlra4 you mat pay for It III It Is toot, damaa90, or
N • charp br vd*W kmnanoe Is shown on db`McM 1hs
Cm~ will by to buy the aorenpes decked for the brm alwwn.
The Ctadhor Is not I" laugh, f he Caawt do as N teea
r?Y bay Swm for a s1aHa bran or he uw OW you
aadN for to arnmit dwwm. N M cannot buy any Insurance. he
wB give you credit for on amoaA shown. The credit will be male
to M last ptytnenk Alms.
E Lap Charge: You will have to pay a late chags on the
pptlon of each paymat made more than ten days Into. -Mw
darge Is shown an the frorst ack amse your detwit of ? that you can Map mmdit
paynwnIs der tley are due. The Cmdkor may take the steps set
foil In this caaraa, N there is cry ddauiL
F. OdMlb YOU we be In delta IP
i. Y40 tic Rd Mde a peyawnt v#m N b dWi or A11%
1 Yawl oaNw?anhlN or elni iNAnO Mllol^M?P ?.YAVioII?
a Y6ur wlhlab?Nd'bY aNl? dift,
and b not W"
and P"m or !. YOU ft rod pmfte i is n hM owspb *# L? Of
N you are in ae" 8N 0mcm M" "quitto YOU to? j ay BLOW
Z, K andull 0 Part d Nn
11ha tapald elicits IMbad+ NN
Fltanos Chaga ono ail ath r amoorde cue mbar Ylb aorMra A
also
No ""MNM frbpdQ•ths valiabh oAlay
tabs conic bum It. Or wo. vNiab wfiMt r P"t!""9 fi ad Will
hold them for you.
N the wthkb is mm back, M wN Aland you a ratoe. The mike
at say Ml you Rw ndam (btrY beep tM "t"Al. N wB Alba
dW tw Mama rwetbd b redMft You RW redsan 00
veNde W to Sw NmAl the Cred W Aldo t or egrMa to ad It. N
you do not redeem Ow "Mole, N will be oft
The QmcW wM use Sa•no* from Sw aali, lea the dowad ft volowt ANN wind
Fve?' dd a a dkedreaudN hahg b reMW+Ithe
h
AlMlerviss. dtl R1orp lMawbye ' law mW kko Comm I11Ala by bar an
allowecl, too. TM ondw wM par you anY monaY 141 M
Alurphw). You wB pay any nanny a61 ovAn7 aae? No oak to Ito
when do
r"m cot.redN you
the do not Prey Mderest to mo" bwkd MID
Citor may shar ps you at
ud you pay.
G. Conwmsr:RAporta: You whorba Ford Motor Credt Conn
Party to obtain anstater «aat retenk born owmxnsr mpalkg
agsrales (OrAldN brseaha) for any reeesn and at any Saw In Con-
nedbn with Nit oontr".
N: General: To OOrrlad Ford Motor Crag Oordprry about Nib
acoorxi, cal 1-OW7E7 7000. Abo. you may ehWe address and
cow selected doges aT aaWAndoe&oom. The bar d Pear
fylvalia apples b the cordrad. N tie law does not slaw me of to
apsenwnb b this contract, the one flat an not allowed we be
vokl The mist d this oonbad will SM be good.
a'n11
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 Moser Valicri Buyers O'in N you are buying a used
vsNote with to eentract. bdenl regulation may r*W" a
apedd Buyers Guide to be dsplayed on the window of the
y Dow roRM FOR THIS, VVEHICLE IS PART OF
THIS CONTRACT. INFORMATION ON THE WINDOW
FORM OVERRIDES ANY CONTRARY PROVISIONS
IN THE CONTRACT OF SALE.
GUARANiT
A- Iletar 9r+a ea -the?msiu that M wB bs Nble for
o se* ae wino gWW M a gnrarantor wo pay N %ten askod. Each person srto sip" polo" WW 11" -
cmdw
a In Part
does on of more of faSodrr? W SIB 0 WW -00 eAe yore «mme Peymais, a ? tI* be M release In kA or
to any d the Cher GAWW" ra, «(C) rslasss wry Sewdty. Eaeh Gmeranbr also cheese that he has reaHed a comdetad copy d this
ooMrad'and ft Gtivvld at ew low Of $Oft
Address
f3uarantor
Guarantor Address
ARBITRATIOH • ? •
Ad*mdon Is a awdrod ol cry Calm. dlapula, Of m*maay (cOSedbroly, a wsall ) 4to a- a any Ca in wail t you
orCraaSOOr ('w' «bre (esd4i Paty may daoea a ail Sue Alper a lawsuit is Bed to have cry Claim rWbd
had decided by arbMaabrh. Such Gshn but we not amibd b fw 1) Claim In om"A br4 yqr end ua our
Claim repriang Wayeei, agenla?aucoss , as, *ns, a' or valift afticilarkl4k or WMM e; 41 C or a WM aiakq out M or 1111a g to YOU wla do nod
arr
? contract. or any resuftv tra swilon or rembnAhip, inchAV that the dealer, «cry such rekUoMhip wBh
i
RIOIfTS Y011 AND WE A?ITIEE TOOIVE UP_
e 1Rhef yOy Or wM room All e a e m, ten You we .0. to Gal" ft fatowing right:
PAW TO A TRIAL, WHETHER BY A JUDGE OR JURY
RIGHT TO PALMATE AS A CLASS REPRESENfATiVE OR A CLASS MEMBER IN ANY CLASS CLAIM YOU MAY HAVE
AOAMr ITS WHETHER IN COURT OR IN ARBITRATION
• BROAD RIGHTS TO DISCOVERY AS ARE AVAMSLE IN A LAWSUIT
TO APPEAL THE DDOISION R
O LE NI A LAWSM
IGM THATTARE AVARJIBO
OTTIM R
N a Claim b orb mho you and we will eonumw to have to faSOMR wthout wehi g We
Too And LVL9Not
W D1111111" prevwon as sa mry vr.n..) lose In court ZI now b.okra on scarily in the ahaa. wtwlhH
by repaaeMdon err thrOhrah a uatat of k b? aclbn b anlorrw Hw arbbatora deolNo4 and 41 Pv t to tapwel tot a
cart Of law WW wMtlor to abrAIM ft i
SOW Party hung crdad any association below and do odw Party to soot arbtraton. The applicebb nda (nhe 'Rrdpy may be
abbirwd hem Sw anackdon.
Amabat hadon AAleoddon ('AAA'), at 11-800-77111-711117111, or www adr %
• J.AAL at 1400418.18M. or www.larnad?,aan:
Hal"81 oe' FOru?L at 14100.47448X, of WWWA WOMMA m.
bsMreen• the Fpd?ee and tliAl oatwd. Sda OonhaOt shM Ogaovroarr lTa oatnd Is nMW to the FedaN Addpatoe Ad
Ntime Is -*1 be h wlblg YIIII-S g Opki011. Vye WB
C.AAer...? The arbthaaM u si .Worn shall
pay yea WW "atarabts abbabn lea and ??aM
I now of $748. We writ pay to wlob fSnp lea Y wa
clot lea aawxad and tie rarrrabtug ptovlelon ahd b
Wwer/i M4 P.rAre piw?MrMwA)
VA
•.. PRN"'
Ford Motor Credit Company
P.O. Box 3075
COLUMBIA. MD 21045.5075
(500)677-0730
P010c3600 0=2
REBECCA HAWBAKER
1125 HARRISBURG PIKE'-
CARLISLE PA 17013
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your Property described above. because you broke promises in our agreement.
PUBLIC SALE: We will a" the property described above at public
x? PRIVprivate SALE: We will sent the days t describedhe of above at ? sale to the highest bidder on the date below (or any sd)ourn end Notice shown hown tall stave sometime unlesslme redee soarme e 1d by days you W prior to such agile. dde). The sale will be held as follows:
s Date of Sale Time of Sale Place of Sale
You may attend the sale and brig bidders If you want.
NOTICE Uh ItCraJaawow .
The money that we get from the sale (after paying our costs,
including reasonable aftomey'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 you o it uget the s the edifference . If
xtra money,
we get more money than you owe,
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 team the
exact amount you must pay, call i15 at the telephone number
above.
If you need more information abodt the sale tali us at the
telephone number above, or writt# us at the address above.
If you want us to explain to you iWwriting 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 dealerloriginal creditor named below; 3) If there are other
people, they are named on an attachment sent with this notice.
? The property has been (or will be) rsturlned to: (dealer/crlgirel creditor)
Under our agreement wlth your dealer/origirld Creditor, the dealer/orpinal creditor is to sell the property and pay you any money left over. If you owe money
after the sale, you will pay lt to the dealer/orfainal creditor.
? PERSONAL PROPERTY: Any personal properly found in the vehl* may be reciesned by you within the next 50 days or, in accordance with state law, by
contacting thts office. Thereafter, the personal property shag be disposed of aceorttingly.
? Creditor has assigned to Its qualified iryemnedisry (01 Exchange, LLC) its rights (but not its obligations) with respect to the sale of each vehicle listed above.
PAYMENTS: AN payments to us must be by canified check or money order.
MILEAGE DISCLOSURE: If you are aware Est the mileage reflected on the vehicle's odometer Is not accurate for any reason, Pleass contact us so that we
can acctxately report the vehicle's mileage.'
INSURANCE RIGHTS: If you don't ward to got your property back, cal tits insurance company or the deslerforgnal creditor to make sure that any insurance
has been cancelled. You have a right to gal credit for all premium refunds.
JESSICA A. SNYDER
FFNA 119W.37 Jon 02 P-. .M-- MY NOT b#Lw.
F4iMM i, U.S A
The property is presently stored at: BEN RECOVERY BEN _
REZ-MWETTER3` W----
HOW TO GET YOUR PROPERTY BACK
To gat your property bank. Pay us this amount by certified check or
money order before the vehicle is sold.
Unpaid Balance $ 12923.24
Plus Costs: _fte Expenses $ 200.00
$
$
Plus Late Charges $ 15.00
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 13,138.24
(Plus expenses incurred if default at the time of repossession exceeded
15 days and *Na rebate received after the date of this notice)
Your property wont be sold until 15 days after the date of this notice at
the EARLIEST. After that you can stilt get It back any time before"
actually sold.
If you do, well have no fuggier claim on I. But the longer you wait, the
more costs (including repairs) you may twee to pay.
if you have any questions about this, please call us.
CUSTOMERICUSTOMER FILE
EXHIBIT
0
Naaw and #A*eu of Sender
Ch met a service:
Dereeed ? RaeordW D61wry (inrmeibr+il
? DDD ? Repblwed
O
O ewer e caidn"am
Pam l"K c* a" &apoxhl
Ul121f20550870 7005 1920 OOD7 0264 7302 --
.J,I-037146488
MICHAEL E. GARLAND SR
P.O. BOX 434
BOILLINGSPRINGS PA y7007 _
V 1121/20560871
N,./ REBECCA HAW B E
1125 HARRISBURG
CARLISLE PA 17013
5.
OaD7 D264
7005 1e2a
7005 1820 0007 a264 7326
Ul121@05W872
jj.023284130
8. CLINTON R. JOHNSON 111
238 WALNUT ST
COLUMBIA PA 17512
-i-
-67
w121120550873
P-024SM75 Vi11S
I,ACRETIA S. LE
3056 WEST BLVD"I e
BETHLEHEM PA 18017.3242
.7 1820 OD07 0264 7333
i ?
comphN by Tyvaw.kar. Ink Or
(Pape r of 2)
Wild ')A
. r Y 1
M
'
:7.. ; . ??•.M+ J'.? ? :• 7 yr .
.'•'J11?1N. ,
i Hne ! V y. ,
Ul121n05M74 7005 1820 0007 0264 7340
P-034740800
DEREK F. WELCH
8004 NEW BATTLE GROVE RD
BALTIMORE MO 21222
287s
P-028591811891811
P-0
7005 162D 0007 0264 7357
AMELIA L. WALLACE
1920 KEARNY ST NE
WASHINGTON DC 20018
U1121I20550876 C C
P-029123883 7005 182 0 0007 0264 7364
LOUVENIA R. GRAY
APT N 203 O _
' « m
3318 WHEELER RD SE w la:
WASHINGTON DC 20032 .... ... d
See Prl4cy Ad Statement on Rovem
ra`r wwwr a
umeeye«ar
PS Farm 3677, Febnwy
4 '
Ford Motor Credit CompanY
PO BOX 3076
COLUMBIA MD 21045-6076
600 6770730
DATE: 2005-12-28
PMRH00000091
REBECCA HAWBAKER
1125 HARRISBURG PIKE
CARLISLE PA 17013
STATEMENT OF SALE
Account Number:-f 035610959
The following property has been sold.
Vehicle Identification Number:
Make Model
Year
FORD FOCUS 1FAFP34PX3W302451
2003
(1) $ 12,938.24
Balance owing on your contract
Deduct: Finance Charge Rebate (2) $ 0.00
$ 12.938.24
(3)
Balance less Finance Charge Rebate (1 - 2)
(4) $ 7,600.00
Deduct: gross proceeds of the sale (5) $ 5,338.24
Balance less gross proceeds of the sale (3 - 4)
Add: Expenses of retaking and storing, and (6) $ 381.00
attorneys' fees allowed by law, and
an
y
expenses of reconditioning and selling.
o.oo
(7) $
Premium Rebate
Deduct: Insurance 00
0
.
(8) $
Other: , (g) $ 5719.24
Deficiency" (10) $ NIA
Surplus"
received by us (credits) or additional allowed expenses & interest
The Surplus/Deficigncy will change based on monies
added to your account (debits).
Surplus" or Deficiency"
If the sale results 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 Ford Motor Credit redit payment to-
Ford Motor Credit Company Company
P. o. BOX 6508 DEPT Mo194101
tor C MESA ARIZONA 85216-6508 BOX DETROIT 55 55000
00 -1941
(800) 732-2264 MI 48256
FFNA11990 0104 PrMAOU8 editions may NOT be used.
EXHIBIT
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-06132 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
HAWBAKER REBECCA
MICHAEL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
HAWBAKER REBECCA the
DEFENDANT , at 0842:00 HOURS, on the 25th day of October , 2006
at 1125 HARRISBURG PIKE APT 7
CARLISLE, PA 17013
JASON HAWBAKER, HUSBAND
by handing to
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: So Answers:
Docketing 18.00
Service 4.40
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
32.40./ 10/27/2006
/I/ 04/a, MAURICE & NEEDLEMAJKJ
Sworn and Subscibed to By:
before me this day D puty S e iff
of , A. D.
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 ?) icy-/161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
REBECCA HAWBAKER
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS -
CASE NO. 06-6132-CIVIL
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
No answer having been filed in the above Civil Action, kindly enter Judgment in favor of
Plaintiff, and against Defendant, REBECCA HAWBAKER in the amount as follows:
Principal Amount $ 5719.24
Interest to Date $ 1263.56
Costs $ 155.50
TOTAL $ 7138.30
BY:
1P.C.
VEEJDLEMAN, ESQ.
for Plaintiff
MAURICE &
Date: March 21, 2007
MAURICE &
NEEDLEMAN
Suite 935, One Penn (enter
1617 John F. Kennedy Blvd.
Philadelphia, PA 19103
tel. 215.665.1133
fax 215.563.8970
www.mnlowpc.com
Donald S. Maurice
Member NJ Bar
Board Certified
Creditors' Rights Law
American Board of Certification
Joann Needleman
Member PA & NJ Bar
Thomas R. Dominczyk
Member NJ & PA Bar
Sandra J. Sutton-Simanski
Member NJ & NY Bar
November 10 2006
VIA CERTIFIED & REGULAR MAIL
REBECCA HAWBAKER
1125 HARRISBURG PIKE APT. 7
CARLISLE, PA 17013
Our File No. 4683
RE: FORD MOTOR CREDIT COMPANY v. REBECCA
HAWBAKER
CUMBERLAND COUNTY COURT OF COMMON
PLEAS, CASE NO. 06-6132-CIVIL
Dear REBECCA HAWBAKER:
Enclosed please find a ten (10) day notice of default which is self-
explanatory. This is being served upon you due to your failure to respond
to Plaintiffs Complaint served upon you on 10/25/2006. Unless an answer
to Plaintiff's Complaint is filed with the Court within ten (10) days from
the date of this notice, a default judgment may be entered against you.
If you would like to discuss a resolution to this matter, please call our
office at 908-575-0220 ex. 21.
Thank you for your prompt attention to this matter.
Very truly yours,
JOANN NEEDLEMAN, ESQ.
New Jersey Office
MAURICE & NEEDLEMAN, P.(.
250 Route 28 West
Suite 203
Bridgewater, NJ 08807
tel. 908.575.0220
fax 908.575.0632
Enc
THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A
DEBT, AND ANY INFORMATION OBTAINED WILL BE USED
FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
Thomas R. Dominczyk, Esq.
Identification No. 85248
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7154
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
REBECCA HAWBAKER
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 06-6132-CIVIL
IMPORTANT NOTICE
TO: REBECCA HAWBAKER DATE: November 10, 2006
1125 HARRISBURG PIKE APT. 7
CARLISLE, PA 17013
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
MAURICE & NEEDLEMAN, P.C.
BY
JOANN NEEDLEMAN, ESQ
Attorney for Plaintiff
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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) 789-7161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
REBECCA HAWBAKER
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 06-6132-CIVIL
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
Defendant: REBECCA HAWBAKER,
1125 HARRISBURG PIKE APT. 7,
CARLISLE, PA 17013
MAURICE & NEED
BY:
JOtN?VEIlLEM'
A o ev or Plaintiff
, P.C.
ESQ.
Date: March 21, 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
121?)J iuy-iiei
FORD MOTOR CREDIT COMPANY
Plaintiff -
V.
REBECCA HAWBAKER
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 06-6132-CIVIL
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on
11/10/2006 to Defendant, REBECCA HAWBAKER , 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 11/10/2006, 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:
VEWLEMAN, ESQ.
for Plaintiff
Date: March 21, 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) 789-7161
FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF
Plaintiff - COMMON- PLEAS
V.
CASE NO. 06-6132-CIVIL
REBECCA HAWBAKER
Defendant(s)
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
COUNTY OF PHILADELPHIA
SS.
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that he/she represents the Plaintiff in the above entitled case and that Defendant, REBECCA
HAWBAKER, is over 18 years of age; the occupation of Defendant is unknown and to the best
of Plaintiffs knowledge, information and belief, Defendant is not in the military service of the
United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and
Sailors' Civil Relief Act of 1940 and the amendments thereto.
'.C.
ESQ.
SWORN TO AND SUBSCRIBED
before me this,2,?day
of PX Z, 200-/
Notary Public W-0--
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Agnes Beiland, Notary Public
City Of Philadelphia, Philadelphia County
My Canmission F_xpires Jaffe. 20 )Fig
Member, Pennsylvania Assoeea tie:- " n utaries
Attorneys for Plaintiff
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
(215) 789-7161
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
REBECCA HAWBAKER
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 06-6132-CIVIL
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 he/she is an attorney at law and that on 11/10/2006 she mailed a written Notice of
Intention to File the Praecipe to Defendant, REBECCA HAWBAKER, at 1125 HARRISBURG
PIKE APT. 7, CARLISLE, PA 17013 by certified mail, article nos. 7155 5474 4100 4339 8066.
Copies of the receipts evidencing said mailing are attached hereto.
well.
MA
BY:
SWORN TO AND SUBSCRIBED
before me this,?day
of 2007
Notary Public
& NEEDLEWN, P.C.
for
LEMAN, ESQ.
0WONWEALTH OF PENNSYLVANIA
Notarial Seal
Agnes Beiland, Notary public
City Of Philadelphia Philadelphia Counly
My Commission Expires Jan. 2o, c Jog
Member, Pennsylvania Association of Notaries
A copy of the signed green card evidencing receipt of said mailing is attached hereto as
F
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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
(11 J) /2Sy- / l b l
FORD MOTOR CREDIT COMPANY
Plaintiff
V.
REBECCA HAWBAKER
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON-PLEAS
CASE NO. 06-6132-CIVIL
(X) Notice is hereby given that a judgment in the above-captioned matter has
been entered against you in the amount of $7138.30 on
(X) A copy of all documents filed with the Prothonotary in support of the
within judgment is enclosed.
?)U' -- -
Prot taryl lerk
by:
If you have any questions regarding this matter, please contact the filing party:
Name: Joann Needleman, Esquire
Address: Suite 935, One Penn Center at Suburban Station
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Telephone No.: 215-789-7161
(This Notice is given in accordance with Pa.R.C.P. §236)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
( ) Confessed Judgment
( ) Other
Ford Motor Credit Company
vs.
File No. 06-6132 Civil
Amount Due 7138.30
4 Interest 3/29/07 $206.52
Atty's Comm
REBECCA HAWBAKER -
11AS H?Pike, ApF 7
COtrlislt, A i rDt3-1 43
TO THE PROTHONOTARY OF THE SAID COURT:
Costs_
The undersigned hereby certifies that the below. does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but If it does, it is based on the appropriate original Proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue a writ of execution in the above matter to the Sheriff of Cumberland County,
for debt, interest and costs, upon the following described property of the defendant(s)
GARNISHEE: -SOVEREIGN BANK
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt,,interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
- Sovereign Bank 17U). H iah S'E n rliale. PA ho i -A
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
0 (indicate) Index this writ against the gamishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date Signature:
Print Name-
Address:
Attorney for:
Telephone:
215789 7154
Supreme Court ID No.:
(over)
Philadelphia, PA 19103
plaintiff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6132 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s)
From REBECCA HAWBAKER, 1125 Harrisburg Pike, Apt. 7, Carlisle, PA 17013-1643
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
SOVEREIGN BANK, 17 West High Street, Carlisle, PA 17013
ALL ACCOUNTS
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $7,138.30
Interest 3/29/07 - $206.52
Atty's Comm %
Atty Paid $128.90
Plaintiff Paid
Date: 9/26/07
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
h
?.
ss R. Long, Prothonotar3T
Q
By: ?. &'j? I
Deputy
REQUESTING PARTY:
Name JOANN NEEDLEMAN, ESQUIRE
Address: 935 ONE PENN CENTER
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-789-7154
Supreme Court ID No. 74276
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-06132 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
HAWBAKER REBECCA
And now JASON VIORAL
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0015:55 Hours, on the 2nd day of October , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
HAWBAKER REBECCA
hands, possession, or control of the within named Garnishee
SOVEREIGN BANK 17 W HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JULIE MYERS (CUSTOMER SERVICE MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
Sheriff's Costs:
Docketing .00
Service .00
Affidavit J?7 .00
Surcharge .00
00 .00
.00
in the
true
and made
S o ?annssw'e s
!
R. Thomas Kline
Sheriff of Cumberland County
10/03/2007
Sworn and Subscribed to
before me this day of By --
De t Sheriff
A.D
w
FORD MOTOR CREDIT COMPANY
Plaintiff,
V.
REBECCA HAWBAKER
Defendant(s).
SOVEREIGN BANK
CUMBERLAND COUNTY COURT OF COMMON
PLEAS
Case No. 06-6132-Civil
A -taya? Ems its
INTERROGATORIES IN ATTACHMENT
TO: SOVEREIGN BANK
You are required to file answers to the following interrogatories within twenty (20) days
after service upon you. Failure to do so may result in a default judgment against you.
1. At the time you were served with Plaintiffs writ of execution, or at any
subsequent time, did you owe the defendant (SS # xxx-xx-5188) any money or were you liable to
defendant on any negotiation or other written instrument, or did the defendant claim that you
owe him/her any money or were liable to him/her for any reason? If your answer is in the
affirmative, please advise the amount of money you owe the Defendant, or the amount you are
liable to the Defendant. No
2. At the time you were served or at any subsequent time, was there in your
possession, custody or control or in the joint possession, custody or control of yourself and one
or more other persons any property of any nature owned solely or in part by the defendant?
No
3. At the time you were served or at any subsequent time, did you hold legal title to
any property of any nature owned solely or in part by the defendant or in which defendant held
or claimed any interest? No
4. At the time you were served or any subsequent time, did you hold as fiduciary
any property in which defendant had an interest? No
At any time before or after you were served, did the defendant transfer or delivery
any property to you or to any person or place pursuant to your direction or consent, and if so
what was the consideration therefor? No
6.
At any time after you were served, did you pay, transfer or deliver any money or property to the
defendant or any person or place pursuant to his direction or otherwise discharge any claim of
the defendant against you? No
7. If you are a bank or other financial institution, at the time you were served or at
any subsequent time did the defendant have funds on deposit in an account in which funds are
deposited electronically on a recurring basis and which are identified as being funds that upon
deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so,
please identify each account and state the reason for the exemption, the amount being withheld
under each exemption and the entity electronically depositing those funds on a recurring basis.
No
8. If you are a bank or other financial institution, at the time you were served or at
any subsequent time did the defendant have funds on deposit in an account in which the funds on
deposit, not including any otherwise exempt funds, did not exceed the amount of the general
monetary exemption under 42 Pa. C.S.A §8123? If so, please identify each account.
Yes-See Attached
9. At the time you were served or at any subsequent time, did you have any safe
deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral,
checking, savings, tax or other accounts or deposits in which defendant has an interest? If the
answer is in the affirmative, please advise the amount of defendant's interest thereto at the time
of the service of the writ.
Yes-See Attached
for Plaintiff
Penn Center
Piladelphia, Pa 19103
215 789 7154
, ESQUIRE
Date: September 21, 2007
ANSWERS TO INTERROGATORIES
Account # 3381130625 Balance: $0.00
After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this
acount is $0.00
Account Holder: Rebecca M Hawbaker
1125 Harrisburg Pike, Apt 8
Carlisle, PA 17013-1643
VERIFICATION
I, Timothy J. Cooney, C.O.P. Team Leader of Sovereign Bank, hereby verify that the
information contained in the foregoing Answers to Interrogatories in Attachment are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falsification to authorities.
Sovereign Bank
ay r "'voj
Timothy J. Cooney
C.O.P. Team Leader
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
Ford Motor Credit Company
VS.
Rebecca Hawbaker
CERTIFICATE OF SERVICE
hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
Joann Needleman, Esquire
935 One Penn Center
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Service by certified mail addressed as follows:
Rebecca M Hawbaker
1125 Harrisburg Pike, Apt 8
Carlisle, PA 17013-1643
Timotl{iy J. Cooney
C.O.P. Team Leader
Sovereign Bank
MA1 M133-02-10
2 Morrisey Boulevard
Boston, MA 02125
October 16, 2007
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MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
BY : Charlene Taylor
Identification No. 203920
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(215) 789-7151
FORD MOTOR CREDIT COMPANY
Plaintiff,
V.
REBECCA HAWBAKER
Defendant(s).
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No. 06-6132-Civil
PRAECIPE TO DISSOLVE/WITHDRAW GARNISHMENT
TO THE PROTHONOTARY:
Kindly dissolve/withdraw garnishment upon Sovereign Bank forthwith.
Respec Submitted,
MA CE & N EDLEMAN, P.C.
Jo a eman, Esq.
Date: October 18, 2007
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a
R?omas Kline, Sheriff, who being duly sworn according to law, states this
is returned ABANDONED, no action taken in six months.
S ?+ s Costs: Advance Costs: 150.00 `
Sheriff's Costs 85.99
D 'ng 18.00 64.01 ?_,.a?
Poundage 1.69
Advertising
Law Library .50
Prothonotary 2.00 Refunded on 07/29/08
Mileage 4.80
Misc.
Surcharge 20.00
Levy 30.00
Post Pone Sale
Certified Mail.
Postage
Garnishee 9.00
N
TOTAL 85.99 .7?$ ,13 -Ob So Answers,
J 1. V' € L L :.'
R. Thomas Kline, eriff
By ?.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6132 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s)
From REBECCA HAWBAKER, 1125 Harrisburg Pike, Apt. 7, Carlisle, PA 17013-1643
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
SOVEREIGN BANK, 17 West High Street, Carlisle, PA 17013
ALL ACCOUNTS
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $7,138.30
L.L. $.50
Interest 3/29/07 - $206.52
Atty's Comm %
Atty Paid $128.90
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 9/26/07
(Seal)
REQUESTING PARTY:
Name JOANN NEEDLEMAN, ESQUIRE
Address: 935 ONE PENN CENTER
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-789-7154
Supreme Court ID No. 74276
Unlis R. Long, Prothonotaly
By:
Deputy