HomeMy WebLinkAbout06-6615ARBITRATION 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.
DON S DRAKE
1059 Allendale Road
Apt E
Mechanicsburg, Pa 17055
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. 01. - "Ix ` 0"'.,
CIVIL ACTION COMPLAINT
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de ptazo at partir de la fecha de la demanda y la
notificacion. Hace falta asentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de so persona.
Sea avisado que si usted no se defiende, la corte tomara medidas y
puede continuar la demands en contra suya sin previo aviso o
notificacion. Adernas, la corte puede decidir a favor del demandante
y requiere que usted cumpla con todas las provisions de esta demanda.
Usted puede perder dincro 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 ABOGADO[MMEDIATAMENTE.
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
ARBITRATION MATTER
ASSESSMENT OF DAMAGES
HEARING NOT REQUIRED
Attorneys for Plaintiff
FORD MOTOR CREDIT COMPANY
P.O. Box 6508
Mesa, Az 85216-6508
Plaintiff,
V.
DON S DRAKE
1059 Allendale Road
Apt E
Mechanicsburg, Pa 17055
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
Case No.
Defendant(s).
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, Don S Drake, is an individual who resides at 1059 Allendale Road
Apt E Mechanicsburg, Pa 17055.
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 May 5, 2004, the Defendant(s) entered into a written Motor Vehicle
Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of
obtaining financing in the amount of $18,156.00 at an annual percentage rate of 1.900%, in order
to purchase a certain motor vehicle, 2004 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 $317.44 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 December 2, 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 $9100.00, however a balance of
$4310.13 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 $37.92 and which will continue to accrue.
11. The total amount due and owing at the time of the filing of this complaint is
$4348.05.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in
the amount of $4348.05, well as any additional interest and costs that may accrue and such other
and further relief as this Court may deem equitable and just.
Respectfully submitted,
MAURICE & NEEDLEMAN, P.C.
Plaintiff
UIRE
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: November 13, 2006
IEBRASKA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATEUb nAl [UU4
Buyer (and Co-Buyer) Name and Address (Including County and Zip Code) CREDITOR (Sella Name and Address)
ON S DRAKE JEFF SCHRIEk FORD, INC-
1912 AMERADO BLVD NA316 9203 S 146TH SIP,EET
ELLEVUE, SARPY, NE 68123 OMAHA, NE 68138
You, the Buyer (and Co-Buyer, if any), may buy the vehicle described below for cash or on credit. The cash price is shown below
as "Cash Price." The credit price is shown below as "Total Sale Price." By signing this contract, you choose to buy the vehicle on
credit under the agreements on the front and back of this contract.
NEW D4 FORD
FOCU N/A
.N/A
FAFP38ZX4W137076
N/A r
VEHICLE INSURANCE MAY BE
OBTAINED FROM A PERSON OF YOUR
CHOICE.
INSURANCE DOES NOT COVER
PERSONAL LIABILITY AND PROPERTY
DAMAGE CAUSED TO OTHERS.
CREDIT LIFE, CREDIT DISABILITY AND
OTHER OPTIONAL INSURANCE ARE
NOT REQUIRED TO OBTAIN CREDIT
AND WILL NOT BE PROVIDED UNLESS
YOU SIGN AND AGREE TO PAY THE
PREMIUM.
? Personal ? Agricultural
? Commercial
Year and Make Gross Allows
ITEMIZATION OF AMOUNT FINANCED
17639
00
1. Cash Price ................................. .
(1)
2. Down Payment N / A
Third Party Rebate Assigned To Creditor .............. ............... $
NIA
Cash Down Payment ...................................................
P
t d ...............It
$ N/A
aymen
ue
Deferred Down
Trade-in (description above) .................................... $
*N/A Down Payment ...................................................................... $ (2)
-
3. Unpaid Balance of Cash Price If minus 2) ............. ..................... $
(3)
4. Amounts paid on your behalf (Seller may be retaining a portion of these amounts)
To Public Officials
(f) for ficenM tM & registration
UU
fees $
(ii) for filing fees $7.00
Ill) for taxes (not in Cash Price) $N/A $ 17.00
To Insurance Companies for: N/A
Credit Life Insurance ...............................................
I .......................... $
$1 7K
nsurance ..............................................................
Credit Disability
BALBOA GAP... no.E.u.1.4.h ....................... 600 00 _
I
To for -
-
To forty/A Ii A
$
-
f $
or
To S N/A
To for
Total .......................... ...... $ E 1
I -00 (4)
T8T
S. Amount Financed (3 plus 4) .......................................... ..... $ (5)
FEDERAL TRUTH-IN-LENDING DISCLOSURES
ANNUAL FINANCE Amount Total of Total Sale
PERCENTAGE CHARGE Financed Payments Price
RATE The dollar amount
the credit will The amount of
credit provided The amount
you will have The total 00611
of your purchase
The cost of your cost you to you or on paid when You
have made ell on credit,
including your
credit as a yearly rate behalf
your scheduled downpaymenl
payments of N/
890.40 1 B 166.00 .19046.40 " I gn46 4n
X ? Number of Amount of Each When Payments are due
Payment Schedule - Payments Payment
Your payment whaduill 69 $ 317.44 monthly starting
will be: 1 final $ 32T41F- 04 JUN 04
Prepayment: if you pay off your debt early, you will not nave to pay a penarry.
Late Payment: You must pay a late charge on the portion of each ayment received more
i than 15 days late. The charge is 5 percerntof the late amount or SZS. whi.=r is Iess.
Security Interest: You are giving a security interest in the vehicle being purchased.
Contract Please see this contract for additional information on security interest,
non payment, default, the r. ht to require repayment of your debt in full before the scheduled
date, and prepayment penglry.
COMERCIAL OR AGRICULTURAL USE CONTRACTS: The charge strewn in the above bolt
for late payment is applicable to personal,, family, or household use oomracts only. If ycu
purchased the vehicle cam mwAW or agricultural use, you must pay a late charge on tine
portion of each pa t r 15 days late of 5 percent of the late amount or
$50.00, whidrever'
Any change In in writing and s19 by you and the Creditor.
BUYER; CO-BUYER:
NOTICE TO THE BUYER
Do not sign this contract before you read It or If It contains any blank spaces. You
are entifted to an exact copy of the contract you sign.
Buyer ack (rs a true and completely filled In copy of this contract
at the time slgnin
Buyer 5)Buyer
Sighe
By signing below, the Seaar accepts this contract. If no other Assignee lanamed in a separate
assignment attached to this contract, the Sella inns It to Ford Motor Credit Com
? Credit Lift /A Insurer
O./A N/A
Premium Insured(s)
Credit
? Disabllltyll/A Insurer
#/A N/A
Premium Insured
Signature
? GAP 60
Type of Insurance Terra
EASY CA s y-00
1 rer emium
Signature
Credit Ufa and Credit Disability insurance are
for the term of the contract. The amount and
coverages are shown M a notice or sgronnent
given to you on this date.
You we required to Insure the vehicle. If a
charge Is shown below, the Creditor will try to
buy the coverages checked for the term
shown. Coverages will be based an the cash
value of the vehicle at time of loss, but not
more than the limits of the policy.
? Comprehensive ? f/A Deductible
Collision
? Fire- Theft-Combined Additional Coverage
? Towing and Labor
? Tenn Months (Estimate)
Premium $ N /A
PLEASE CALL US AT 1.800.727-7000
00-001
my No' " u"M - SEE BACK FOR A
ORIGINAL
ADDITIONAL AGREEMENTS
A. Payments: You must make all payments when they are due.
You may prepay your debt at any time without penalty. This is a
simple interest contract. The actual finance charge you agree to
pay will depend on your payment patterns. The actual finance
charge may exceed the disclosed Finance Charge if! you make
your payments later than the scheduled dales or in less than the
scheduled amount. Your payment will be applied first to the
earned and unpaid part of the Finance Charge and then to the
unpaid Amount Financed. The Finance Charge is earned by
applying the Annual Percentage Rate to the unpaid Amount
Financed for the actual time that the unpaid Amount Financed is
outstanding.
F. Default: You will be in default if:
1. You do not make a payment when it is due; or
2. You gave false or misleading information on your credit
application relating io this contract; or
3. Your vehicle is seized by any local, state, or federal
authority and is not promptly and unconditionally
returned to you; or
4. You file a bankruptcy petition or one is filed against you:
or
5. You do not keep any other promise in this contract.
S. Security Interest: You give the Creditor a security interest in
1. The vehicle and all parts or other goods put on the vehicle;
2. All money or goods received for the vehicle; and
3. All insurance premiums and service contracts financed for you.
This secures payment of all amounts you owe in this contract. It
also secures your other agreements in this contract.
C. Use of Vehicle - Warranties: You must lake care of the
vehicle and obey all laws in using it. You may not sell or rent the
vehicle, and you must keep it free from the claims of others. You
will not use or permit the use of the vehicle outside of the United
States, except for up to 30 days in Canada or Mexico, without the
prior written consent of the Creditor. If the vehicle Is ofia type
normally used for personal use and the Creditor, or the
vehicle's manufacturer, extends a written warranty or service
contract covering the vehicle within 90 days from the date of
this contract, you get implied warranties of merchantability
and fitness for a particular purpose covering the vehicle.
Otherwise, you understand and agree that there are no such
Implied warranties.
D. Insurance: You must insure yourself and the Creditor against
loss or damage to the vehicle. The type and amount of insurance
must be approved by the Creditor. If the Creditor obtains a refund
on insurance or service contracts, the Creditor will subtract the
refund Irom what you owe. Whether or not the vehicle is
Insured, you must pay for It If It is lost, damaged, or
destroyed.
If a charge for vehicle insurance is storm on the front, the
Creditor will try to buy the coverages checked for the term shown.
The Creditor is not liable, though, 0 he cannot do so. If these
coverages cod more than the amount shown for insurance, the
Creditor may bury them'for a shorter term or he may give you credit
for the amount shown. If he cannot buy insurance, he will
give you credit for the amount shown. The credit will be made to
the last payments due.
E. Late Charge: You will have to pay a late charge on each
payment received more than fifteen days late. The charge is
shown on the front. You must also pay any cost paid by the
Creditor to collect any late payment, as allowed by law.
Acceptance of a late payment or late charge does not excuse your
default or mean that you can keep making payments after they
are due. The Creditor may take the steps set forth H there is any
default.
It you do not cure a default where allowed by law, the Creditor may
require you to pay at once the unpaid Amount Financed, the earned
and unpaid part of the Finance Charge, and all other amounts due
under this contract. He may repossess (take back) the vehicle. too.
He may also take goods found in or on the vehicle when repos-
sessed and hold them for you.
If the vehicle is taken back, he will send you a notice. The notice
will say that you may redeem (buy back) the vehicle. It will also
show the amount needed to redeem. You may redeem the
vehicle up to the time the Creditor sells 0 or agrees to sell it. If you
do not redeem the vehicle, it will be sold.
The money from the sale, less the allowed expenses, will be used
to pay the amount still owed on this contract. Allowed expenses
are those paid as a direct result of having to retake the vehicle,
hold it, prepare it for sale, and sell H. Lawyer's fees and legal costs
permitted by law are allowed, too. If there is any money left (a
surplus), it will be paid to you. If the money from the sale is not
enough to pay off this contract and costs, you wAl pay what is still
owed to the Creditor. If you do not pay this amount when the
Creditor asks, the Creditor may charge you interest at the highest
lawful rate until you pay.
i
G. Generaf: To contact Ford Motor Credit Company about this
account, call 1-(800) 727-7000. The law of Nebraska applies to
this contract. It that law does not allow all the agreements in
this contract, the ones that are not allowed will be void. The rest
of this contract will still be good.
FTC NOTICES
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 Motor Vehicle Buyers Guide. If you are buying a used
vehicle with this contract, federal regulations may require a
special Buyers Guide to be displayed on the window of the
.vehicle. THE INFORMATION YOU SEE ON THE
WINDOW FORM FOR THIS VEHICLE IS PART OF
THIS CONTRACT. INFORMATION ON THE WINDOW
FORM OVERRIDES ANY CONTRARY PROVISIONS
IN THE CONTRACT OF SALE.
'Does not apply U purchased for commercial or agricultural use.
In that eau you (debtor) will not aseeA against any assignee or
subsequent: holder of this Contract any claims, defenses, or
611111-Ofte which you may hew against the Seller or manufacturer of
the vehicle.,
GUARANTY
To cause the Seller to sell the 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 this contract. This means that 0 the Buyer fails to pay any money that is owed on this oontrad,
each one who signs as a guarantor will pay it when asked. Each person who aligns below agrees that he will be liable for the whole
amount owed even if one or more other persons also signs this Guaranty. He also agrees to be liable even if the Creditor does one or
more of the following: (a) gives the Buyer more time to pay one or more payments, or (b) gives a release in full or in part to any of the
other Guarantors, or (c) releases any security. Each Guarantor also states that he has received a completed copy of this contract and
this Guaranty at the time of signing.
Guarantor Address
Guarantor Address
FC anon Om 00 [PM-e rasemr may Nor in uno
"'PRN"'
Ford Motor Credit Company
P.O. Box 152271
IRVING. TX 75015-2271
(877)898-7256
Pl/4HL4002=13
DONS. DRAKE
LOT 73
398 KINGS HWY
MARYSVILLE PA 17053
Date of Repossession 0331-2006
Date of Notice Date of Contract
0401.2006 05-05.2004
Account Number: 036944955
Buyer DON S. DRAKE
Cobuyer
DESCRIPTION OF PROPERTY
Year
2004 Make
FORD Q New
? Used
Vehicle Identification Number:
1FAFP36ZX4W137076
Model
FOCUS Body
4DR
NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
0 PRIVATE SALE: We will aell 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 will sell the property described above at public
sale to the highest bidder on the date below (or any adjournment
date). The safe will be held as follows:
Date of Sale Time of Sak Place of Sale
You may attend the sale and bring bidders if you want.
NOTICE OF REPOSSESSION
The money that we get from the sale (after paying our costs,
including reasonable attorney's fees and legal expenses if
permitted by law) Will reduce the amount you owe. If we get
less money than you owe, you will still owe us the difference. If
we get more money than you owe, you will get the extra money,
unless we must pay it to someone else.
You can get the property back at any time before we sell it by
paying us the full amount you owe (not just the past due
payments), including our expenses. See How To Get Your
Property Back for an itemization of amount owing. To learn the
exact amount you must pay, call us at the telephone number
above.
If you need more information about the sale call us at the
telephone number above, or write us at the address above.
If you want us to explain to you in writing how we have figured
the amount that you owe us, you may 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 under
your agreement: 1) The buyer and any oobuyer 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: NATIONAL AUTO DEALERS
EXCHANGE T
HOW TO GET YOUR PROPOWC11111*11=1
To get your property back, pay us this amount by certified check or
money order before the vehicle is sold.
Unpaid Balance $ 13,011.38
Plus Costs: Pepo Expenses $
a
Plus Late Charges $ 57.19
Less Finance Charge Rebate $
Less Insurance Premium Rebate $
TOTAL $ 13,06656
(Plus expenses incurred 6 default at the time of repossession exceeded
15 days and less rebate received after the date of this notice.)
Your properly wont be add until 16 days after the date of thin notice at
the EARLIEST. After that you can still gal lt back any time before lt'a
actually add.
If you do, well have no hatter claim on ft. But the longer you wait. the
more casts (including repairs) you may have to pay.
If you have any questions about this, please call us.
? The property has been (or will be) returned to:
(dealsdoriginal creditor)
Under our agreement with your dealer/kxigind creditor, fie dealer/original creditor Is to sell the properly and pay you any money left over. If you owe money
after the sale. you will pay it to the deaNr/orlgYwl creditor.
? PERSONAL PROPERTY: Any personal property found in the vehicle may be reclaimed by you within the nerd 60 days or, in accordance with dale law, by
contacting this office. Thereafter, fire personal property shell be disposed of acoordingly.
? 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 certifled cheek or money order.
MILEAGE DISCLOSURE: If you are were that the mileage reflected on the vehicle's odometer is net accurate for any reason, please contact us so that we
can accurately report the vehicle's mileage.
INSURANCE RIGHTS: If you don't went to gal your property back, call the insurance company or the dmler/origktd creditor to make surethat any insurance
has been cancelled. You have a right to gal credit for all premium refunds.
LAURIE WARD-SELL
FFNk 1100657 Jan 02 P-1- Whims rosy NOT b. .Id CUSTOMERICUSTOMER FILE
Pdnt.d in U.sA.
Name and Address of Sender Check type of mail or servlow
Lason 0 arso o? Donry MWwjom)
38120 Amrheln o DW-Cenlw-d- O R*Wm Ftwe* for MWChenE,ss
Livonia, MI 48150 O1nDgx?p Mae 0e,enaton Censn wn
At" F wdw -o ns owft avat (NMet a 7FCb4) M.1"
U0331/40569388 ------- -
BP-M705288 7005 2570 0000 9962 5087
GREG R. REED
307 LOCUST 9T
TURTLECREEK PA 15145 - ---
U0331/20589387 7005 2570 0000 996a 5094
DD-034051515
KATHLEEN M. ROTAN `-- - -
i 139 LAMPHERE RD -
MYSTIC CT 083557324 ------
c°`? `!='59365 7005 2570 0000 9962 5100
N-038944955 - -
DONS. DRAKE
E LOT 73 --
398 KINGS HWY -- -
MARYSVILLE PA 17053 -`-
7005 2570 0000 9962 3117 1
U0331/20559389 -
f MA-M6641673
RICHARD A. STOUGH SR
3251 E PHEASANT OR ,_? •_
DOVER PA 17315
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UMd Pletee TaW Okenbsr e(P4ass FaaYnsfgr. Psr (!Isms d ndMNp snmroyn) I
by Saider Rem etFastofte I
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05 2570 00 00 `1962 5124 l
U0331/20569390 70
P-028428863
KRISTY KIUPELIS
S75W35584 WILTON RD
EAGLE WI 53119-1309
7005 2570 00 00 9962 5131 -
U0331?2G569391
P-039325237
ROSEMARY MORALES -
PO BOX 7369 STEELTON PA 17113-0369 t
r
U0331/20569392 BA-033897147
5 2570 0 -
000 9962 5146 y
700
LEON MORTON III
5334 OAKLAND ST. -
PHILA PA 19124 € '? OBC I
FORD MOTOR CREDIT COMPANY
P. 0. BOX 152271
IRVING. TX 75015
DATE: May 24. 2006
DON S. DRAKE
398 KINGS HWY LOT 73
MARYSVILLE, PA 17053
STATEMENT OF SALE
Account Number: 36944955 • EN
The following property has been sold.
Year Make Model Vehicle Identification Number:
2004 FORD FOCUS 1FAFP38ZX4W137076
Balance owing on your contract (1) $ 13,068.56
Deduct: Finance Charge Rebate (2) g 0.00
Balance less Finance Charge Rebate (1 - 2) (3) $ 13,068.56
Deduct: gross proceeds of the sale (4) S 91100.00
Balance less gross proceeds of the sale (3 - 4) (5) $ 3,968.56
Add: Expenses of retaking and storing, and (6) $ 515.00
any attorneys' fees allowed by law, and
expenses of reconditioning and selling.
Deduct: Insurance Premium Rebate
(g) $ 309.43
Other:
4310.13
Deficiency"
(10) $ 0.00
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 P. 0. BOX 55000
MESA, AZ 85216.6508 DEPT. 1194-01
MI 48255-1941
DETROIT
(800)732.2264 ,
FFNA:1990 01104 Prnious editions may NOT be used.
- 1V
vt
7 TI
mr;
-43
)ham
0
e '
SHERIFFS RETURN - NOT SERVED
CASE NO: 2006-06615 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY 0:1 CUMBERLAND
FORD MOTOR CREDIT COMPANY
VS
DRAKE DON S
R. Thomas Kline , Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT to wit:
DRAKE DON S but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT , DRAKE DON S
1059 ALLENDALE ROAD APT E
MECHANICSBURG, PA 17055
PER NEIGHBOR, DEFENDANT IS IN A COMA IN
NOT SERVED , as to
HOLY SPIRIT HOSPITAL.
Sheriff's Costs: So an
Docketing 18.00
Service 9.68
Affidavit .00 tom"' ?Tfi- mas Kline
Surcharge 10.00 e iff of Cumberland County
.00
37.68 URICE & NEEDLEMAN
20/2006
1//
Sworn and Subscribed to before me
this day of ,
A. D.
Curtis R. Long
Prothonotary
Office of the Protbonotarp
(fumbertanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
e)(o -LL Lt; CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573