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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 R FCAI rc nrr-r a.r V??.++.r.•r.rr? ORKMAL DATE III A..r»I Nov 01200 r..+?(111a *A IVM" r ?r rr r rr rrmrl ProYrwn No. OUESTIONS4 PLEASE CALL UY AT t-00-TV-7000 w visit us at www.lorderew,00 n 08M Ford Motor Credit Con"ny Pnftn*d POY M Pion EnroNmau AUUW=110n rr..r rr or e? 4r'1??ir... ??rrw?:Y?? rw ® wr rrrrra.rr.r ??.r'rr'?i r?.Mr°f?'.r1'r?+rr+r?r?.r+r ? ?" EL'"rw ,r,..o.rn rrrrrr r.,..rr?ra o.,rr.w.rrr.r.rr.a«.r.r.r r?u w.r w N• +r'r .r.. rrerur r?..a.r.wr . `. ?.r.+rya.wo.r ?.ri eTM.r ,.° ??rrr or rrr rr.w .w.ra rrrr. r. ?,r ur wr vro.rw. ?ro.r.rr r.r+.+. rre r.wrr«r.«rnr«r a.& rr.r - r.n rr. r r w?rr w. + p?rc,r.u+.r.wra-- rnrrrr.rrrrr ?aorwr.r «rr.. prr?rrr. rar ?we?ur rrrr «rr r w rw e?.rr w .: 7Srr srr«+ ???.Y? rlrr.M u..1 rrr ? ar Yry r..1MrIMi.•rr• w • w r.1'r? .«?Yr r Y.AM ?r rlw...r ?+rewdw 'M?MCnr?r.?wT???r.. rrwrrrrar?w. :tM ??.WM?Lw 1 LL 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 d C7 rv x rn , r' ? ' "" "<7 fT7 `, , :.. C a . P - 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 - r' m°v00 CD Itt J in ?/ 0 ? W oQ [? 1D1 ' 1 S? a CO r • , ajwa- fL L11 QQ [L . LLI 0 a)vZ U, w Z C) U) - W 4 W m 04 Q W d oc • - W ?- U Y co 0 U) FL Q m Q 0 T o m Boas w,od sd W p Q (n Q U [i m y a N p = a. Q4rv W z Q _ _ 6 .. Y J V = rJ? Y M T • Q • U rw._ 8 ED F m LL s uj ce. ?A ?' W V Q m u r zca 0 0. ! E U. S, PPostal Sen dS N O Certified Mail c a0? B o • g z c Q1 V • x V C m O O _ O U1 O _ r U G Y N U1 = O 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 (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 l W O r? -c C.? ` -mss rte ?= J 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 rte.-. C,,?7 x S- d t31 Q ' - Cr+ t ?. r.? ' ., 1 T 900 (fit y( 7VS: ?Vf { ?? .. .. 'e- t O 00 il c 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 C? `? ? n ?',? ? -r; L.. n? t ?? ?. cc? _, ,? -c, ?> r' ?;, ; ,? C="? :G ._ C? 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 -ff? 0 Q C S ? ?} -cs ?: ? CA) c? 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 ?. A SO I ? CK? Gs1?3 0 w N 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