HomeMy WebLinkAbout94-02744
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FORD MOTOR CREDIT COMPANY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff
. CUMBERLAND COUNTY, PENNSYLVANIA
.
V.
. NO. 94-2744 CIVIL TERM
.
ALAN M. IRVIN, :
Defendant
AND NOW,
/~DER OP COURT
this ~~~ day of November,
1997, upon
consideration of the attached stipulation for Judgment, it is
hereby ORDERED as follows:
1. A judgment is entered in favor of Plaintiff and against
Defendant in the amount of SIXTEEN THOUSAND ONE HUNDRED EIGHT
DOLLARS AND THIRTY-SIX CENTS ($16,108.36), together with interest
at the rate of six percent (6%) per annum from the date of
judgment.
2. Plaintiff shall not execute on this judgment so long as
Defendant pays to Plaintiff the amount of FIFTY DOLLARS ($50.00)
per month on or before the last day of each month, beginning in
November 1997.
3. In the event that Defendant fails to make timely payment
pursuant to this stipulation and Order, Plaintiff shall file an
affidavit of non-compliance with the Prothonotary and the entire
Judgment amount less credit for any payments made prior to breach
shall be immediately due and payable and subject to the execution
process.
4. The arbitration hearing scheduled in the above-captioned
....
,/
matter for November 10, 1997, at 11:30 a.m., is cancelled.
By the court,
k/c4/ (:; - ~~
Donald S. Mazzotta, Esquire
Counsel for Plaintiff
.
~~
. 1l/7/q 7
Philip C. Br1ganti, Esquire ~w-
Counsel for Defendant
P.82
4
. .
.
.
FORD MOTOR CREDIT COMPANY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
.
.
NO. 94-2744 CIVIL TERM
ALAN M. IRVIN,
:
Defendant
STIPULATION ~OR JUDGMENT
COME NOW, this ~~ day of November, 1997, the parties in
the above-captioned action, by and through their respective
undersigned counsel, and stipulate as follows:
1. A judgment shall be entered in favor of Plaintiff and
against Defendant in the amount of SIXTEEN THOUSAND ONE HUNDRED
EIGHT DOLLARS AND THIRTY-SIX CENTS ($16,108.36), together with
interest at the rate of six percent (6%) per annum from the date
of judgment.
Z. Plaintiff shall not execute on this judgment so long as
Defendant pays to Plaintiff the amount of FIFTY DOLLARS ($50.00)
per month on or before the last day of each month, beginning in
November 1997.
3. In the event that Defendant fails to make timely payment
pursuant to this stipulation and Order, Plaintiff shall file an
affidavit of non-compliance with the Prothonotary and the entire
Judgment amount less credit for any payments made prior to breach
ahall be immediately due and payable and subject to the execution
process.
4. The parties agree that this stipulation shall be entered
as an Order of Court by the Cumberland county Court of Common
__..~..~.. ~...1
..
.
Pleas and that the arbitration hearing scheduled in the above-
captioned matter for November 10, 1997, at 11:30 a.m., shall be
cancelled.
IF
ili c. Brig i, Esquire
Counsel for Defendant
LEGAL SERVICES, INC.
a Irvine Row
carlisle, PA 17013
(717) 243-9400
ld S. Mazzo
Counsel for Plai
LAW OFFICES OF 0
MAZZOTTA, P.C.
938 Penn Avenue
Pittsburgh, PA 15222
(41.2) 471-0300
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ford Motor Credit,
vs.
) CIVIL DIVISION
)
)
l NO. q 1- d 7~ ~ (1~...:J~
)
)
)
)
) TYPE OF PLEADING: CIVIL ACTION -
) COMPLAINT
)
)
)
)
) CODE - 011 - ASSUMPSIT
)
)
)
)
) FILED ON BEHALF OF: Plaintiff,
) Ford Motor Credit
)
) COUNSEL OF RECORD FOR THIS PARTY:
)
) Donald S. Mazzotta, ESQUIRE
) Pa. I.D. #11461
) William T. Molczan, ESQUIRE
) Pa. I.D. #47437
)
)
)
) MAZZOTTA, MCCAGUE
) Firm #742
) 938 Penn Avenue
) Pittsburgh, PA 15222
)
) (412) 471-0300
Plaintiff,
Alan M. Irvin,
Defendant.
.
.
NOTICE TO DEFEND
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.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717)240-6200
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Plaintiff,
)
)
)
)
)
)
)
)
)
)
)
)
)
)
NO.
Ford Motor Credit,
CIVIL DIVISION
vs.
Alan M. Irvin,
Defendant.
COMPLAINT - CIVIL ACTION
AND NOW, COMES the Plaintiff, Ford Motor Credit, by its attorneys,
Mazzotta, McCague, and respectfully presents its complaint in civil
action against the defendant above-named upon a cause of action whereof
the following is a statement:
1. Ford Motor Credit is a corporation duly authorized to conduct
business in the Commonwealth of Pennsylvania with a place of business
located at P.O. Box 1722, Dearborn, MI 48121,
and is hereinafter
referred to as "Plaintiff."
2. Alan M. Irvin is an individual residing at 710 Hanover Mnr. Apt.
306E, Carlisle, Pennsylvania 17013, and is hereinafter referred to as
"Defendant."
3. Defendant purchased personal property and entered into a written
agreement (hereinafter "Agreement") for the purpose of financing the
purchasing of the personal property. A true and correct copy of Agreement is
marked Exhibit "A", attached hereto and made a part hereof.
4. Plaintiff is the holder of Agreement and is entitled to payment
under the terms thereof.
5. Defendant defaulted for failing to make payments when and as due,
and Plaintiff incurred a loss.
6. The outstanding balance due from Defendant to Plaintiff is
$8,028.70, plus interest from October 9, 1991, at the contract rate.
7. Demand for payment has been made upon Defendant, but Defendant has
failed or refused to pay.
WHEREFORE, Plaintiff seeks judgment against Alan M. Irvin in the amount
of $8,028.70, plus interest on the outstandillg balance at the contract rate
of 16.490% per annum from October 9, 1991 until the judgment date, and then
6.00% interest per annum on the judgment thereafter, and costs of suit.
MAZZOTTA, MCCAGUE
BY:
Ir'J/5
Donald S.
BY:
PENNSYLVANIA VEHICLE
ACCT. NO. RETAIL INSTALMENT CONTRACT
Buyer (.nd Co' Buyer) N.m. .nd Address (Includ. Counly .nd Zip Coda) CREDITOR (Seller N.me and Addrus)
ALAN M.
153 PEACH
CARLISLE,
IRVIN
LN.
PA 17013
K & H FORD, INC.
6320 CARLISLE PIKE BOX 1177
MECHANICSBURG, PA 17055
DATE
.05/16/91
You, the Buyer (and Co-Buyer, II any), may buy the vehicle ducrlbed balow lor cash or on credit. The cash price la ahown below al
"Calh Price". The cradll price II Ihown below al "Totel Sale Price". By Ilgnlng thll contract, you choole to buy the veh(cle on credit
under the agreemenll on the Iront end b.ck 01 thll contract.
II Truck
No. Ton
Cyl. Ca lelt
New or
Ulld
Body
Slylo
Vehicle
Idanlitlclllon Number
V..r and Make
S.rl..
US
FORD
CROWN V CSORIA
8
2FACP74F6MX151891
INCLUDING:
o Rodlo
Power
o Sloerlng
Automatic
o Transmission
Air
D Conditioner
o
ITEMIZATION OF AMOUNT FINANCED
(1) Calh Price .......,..' ,...... ......,..."" ......",.."...... ........"""....".... ...., ..., ....,..,...."....,...."..
(2) Down Payment
Cash Dowl!l fl\YMnt ',.....""..1 07'lt4 ~'O 0........""" '1'OB39.;1o........' ,.., ........" ,........
Trade-In $ $ ..........................
VI.r and Make
Grall Allowance
Amount Owing
Total Down Payment ""...."",..............""""....."",..,..,..,.."..",........,..,,...,.....,
(3) Unpaid Cash Price Balance (1 mlnu. 2) ...................................................................
(4) Amounts Paid on Your Behalf
To Insurance Companies for (Soo A. & B. bolow)
Vehicle Insurance (Torm Monlh. (E.llm.I.)) .........................................
Credit Life Insurance (lor '.rm of con".cl).....................................................................,
Credit Disability Insurance (lor I.rm Of eonlr.el) ..........................................................
(T.rm Month. (E.llm.'.))....................
To Public Olflclals (I) lor license ($ 4.00 ), title ($ 15.00 ), &
registration ($ N/A ) lees $ N/A
(Ii) lor liIing fees $ 5.00 ;
551.46
(Iii) for lexes (not In Cash Price) $ ...........................................
for Messenger Service ..........,...................,
for ............
for NOTARY/DOC FEE ............
for ............
Total ",.......,..,.......,.......,.......",..""...."",..,....'"",....".......",.......,...'....,...",....,..
(5) Amount Financed (3 plu.') ...................................................................,..........,......
To
To
To
To
N/A
K & H mR>, IN:.
Ula For Which
Purchllad
Perlonal 0 Agricullural
o Comm.rclal 0
o
S 19895.0~1)
S 2500.00
S -I.,;:). 10
S 2364.8~2)
S 1/:J,jU. I 3)
S N/A
S N/A
$ N/A
$ N/A
$
$
$
$
$
575.46
N/A
N/A
38.00
N/A
$
S
613.4!t4)
18143.6~5)
Amount Financed (The .mounl 01 cr.dll provld.d to you or on your beh.lI) ..................................................... $
FINANCE CHARGE (The doll.r .mount the credit will cO.1 you) .........................................."r;..ilog....... S
ANNUAL PERCENTAGE RATE (The cost of your credlt.s. ye.rly r.le) ............. . %
Total of Payments (The .mount you will h.ve p.ld when you h.ve m.de all scheduled payments) ..,............. $
Paym8Qt Schedule - Your payment echedule will be:
0' Number 01 Amount 01 Each When Peymenta
Paymenta Payment are Due
59 $ 445.96
1 Final $ 445.96
26757.60
o
monthl~ .Iartlnll
6/1~ . 19-!1
2364.84 29122.44
Total Sale Price (The 10lal price 01 your purcha.e on credil, InCluding your downpaymenl Of $ ) $
Prepayment: II you pay 011 eerly, you will not have to pey a penally.
Late Payment: You musl pay a late ch.rge on each paymenl made more Ih.n 10 d.ys lele, The charge Is 2 p.r cenl 01 the
part Of Ihe paymenl Ihal Is lale or S50.00, whichever Is less.
Security Interest: You are giving a .ecurity inleresl In Ihe vehicle being purchss.d,
Contract: PI.sse see this conlr.ct lor additional Informalion on securlly inleresl, nonpaymenl, delaull, Ihe right to require rep.ymenl
of your d.bl in lull before Ihe scheduled d.le and prepsym.nl p.n.lly. C"I.Il':l\T H. ,
_'/"'o. ..;.J t~
You are required 10 Inaure Ihe vehicle. If e cherge la ahown below, the Credllor will Iry 10 buy Ihe coverage a checked lor the lerm ahown.
Coveragea will ba baaed on Iha caah value 01 Ihe vehicle al Iha lime of loss bul nol more Ihan the IImila ollhe polley, .
, . ,
o Fire.Thell.Combined 0 Term _ Monlha (Ealimate)
Addlllonal Coverage
o Towing and Labor
o Comprahenalva
o $ _ deduclible
colliaion
Premium $
N/A
VEHICLE INSURANCE MAY BE OBTAINED FROM A PERSON OF YOUR CHOICE
INSURANCE, IF ANY, INCLUDED IN THIS RETAIL INSTALMENT SALE DOES NOT PROVIDE COVERAGE FOR PERSONAL
LIABILITY AND PROPERTY DAMAGE CAUSED TO OTHERS
B. Credit and Other Optional In8urance:
CREDIT LIFE, CREDIT DISABILITY AND OTHER OPTIONAL INSURANCE ARE NOT REQUIRED TO OB-
TAIN CREDIT AND WILL NOT BE PROVIDED UNLESS YOU SIGN AND AGREE TO PAY THE PREMIUM
o Credll Life
$
N/A
Inaurer
Inaured(a)
Premium
Slgnalure(a)
o Credll $
Dlaabllity In aurar Inaured Premium Slgnalure
Credit Llle and Credit Dlsabllily Inaurance are for Ihe lerm 01 the conlract. The amount and coverages are ahown In a nolice Or agree-
menl given to you on Ihla dale,
N/A
o
$
N/A
Premium
Slgnelure
Typa 01 Inaurance
Insurer
Term
~
,
Notice to Buyer
his contract in blank.
it d to an exact copy of the contract you Sign.
ect you~al rights.
Buyer ackno
d completely filled in copy of this contract at the time of signing.
~'x
SEE BACK FOR ADDITIONAL AGREEMENTS
By signing below, Ihe Seller accepla Ihla conlracl,
..
K & H lOR>, I1C.
B~~U'/I-"lIIe
d2f-/ ~
A88lgnment: If no olher Aaalgnee la named In a aeparale aaalgnmenl ellached 10 Ihia conlraCI Ihe Sellar aaalgna II 10 Ford Molar Credll
Company under Ihe Aaalgnmenl on Ihe back 01 Ihla conlracl,
B~~ tJl/~.)
..
K & H FORl, I1C.
Fe 17"37 AUG 87 PrevloU1 edltionl may NOT bl u..d. I
KEY.I
(Simpl. 1.'.'000 FOR SELLER'S USE ONLY
..ao 40Be ~o eO.840 al81 8 ABO 01 e.84 11IM nOA :all.840 al81 '3
'M81 Aq peMoll8 II 'enp 81uawA8d 1881 a41 01 ap8W
IKEY'G
88-001
ORIGINAL
p8u.8e a41 01 18'" pa!ldd8 aq 11IM 8luaw~8d .noA 'AI18uad Ino
-41!M eW!I AU8 18 Iqap .noA A8de.d A8W nOA 'anp e.8 A841 U84M
81uawA8d 118 a~8W IBnw nOA :aOlloN A.8wwns PU8 81uawA8d ''1
S~N3W33110V '''NOI~IOa''
EXHIBIT 8A'
h...,. ".-1'd
,~ ,
'YNIDllIO
D'''.'
100.g8
I A'NO asn s lIa"as 1I0:l (".,.,., .,OWIS)
h~3)t I
pain eq JON Aww IUOlllP. InOIAa'd .1.8 onv lt8ll 0:1
ADDITIONAL AGREEMENTS
A. Paymant. and Summary Nollca: Vou mUlt make all paymenll
whan they are due, Vou may prepay your dabl al any lime wllh.
out penalty. Vour paymenla will be applied lirat to tha earned
and unpaid part of the Flnanca Charge and then to tha unpaid
Amounl Financed. The Finance Charge il compuled and payable
on Ihe unpaid part 01 Ihe Amounl Financed. II the vehicle la reo
pou,,"ed, you will nol have Ihe rig hi 10 relnllale Ihla conlracl
unleu the Credllor agreel.
B. Sacurlty Intara.t: Vou giye the Credllor a lecurlly Inlerell In
the yehlcle, In all parta or olher goodl put on the vehicle, In ell
money or good I received lor the vehicle Ind In all Inlurance
premium I IInanced lor you. Thll lecurel paymanl 01 all amounll
you owe In thll conlrlcl, If allo lecural your other agraemenll
In thll contract.
C. U.. 01 Vahlcle - Warrantlea: Vou mUlt lake care of the vehl.
cle, and Obey all lawI In uling It. Vou may not lell or rent Ihe
vehicle, and you mUlt keep IIlrea Irom the clllml 01 olhera. In
thl. contract, there I. no proml.e a. to the merchantability,
,ullablllty or IIIne.. lor purpole 01 the vehicle. Vou may reo
celya a leparale warranty on the vehicle.
D. Vehicle In.urance: Vou musl Insure yourlell and the Credllor
agalnll lOll or damlge 10 Iha vehicle, The type and Imounl 01
Inlurance mUll be approyed by the Credllor, The Credllor may
buy the Insurance II you do nol bul he does not haye to do 10. II
tha Cradllor bUYI Ihe inluranca, he willlnlure bOlh you and him.
lell. Vou mUll pay blck 10 the Credllor what ha paYI lor the
Inlurance plul Interelt al the hlghelt rate allowad by law,
Whether or not the vehicle I. In.ured, you mUlt pay lor 111111
I. lo.t, damaged or deltroyed.
II I Charge lor yehlcle Inlurlnce il Ihown on Ihe Ironl, Ihe Credo
1I0r will Iry 10 buy the coyeregel checked lor Iha term Ihown,
The Credllor II nol liable Ihough II he cannot do 10. II thele
coverages cost more than the amount shown for insurance, the
Credilor may buy them for e Ihorter term or he may glye you
credit lor the amount shown. If he cannot buy any Insurance. he
will giye you credil for the amounf Ihown, The credll will be
mlde to the lall plymlnll due, II allowad by law,
E. Late Charga: Vou will hava 10 pay I Ille charga o~ each pay.
manl made more thIn ten dlYI lIte, The ch.rge la Ihown on the
Ironl, Vou muet alao pay any COIl plld by the Cradltor to collect
any late paymenl, II allowed by law, Acceplence of a lIte pay.
menl or late chlrge dOlI nol excuu your dalault or mean thai
you can keep mlking plymenla alter Ihey are due. The Credllor
may take the IlepI let forth below II there Ie any delault,
F. Oelaull: Vou will be In delaull II you lall to make any paymenl
when II II due, or II a blnkruptcy pelltlon II med by or egelnlt
you, or II you lalllo keep any olher agreement In Ihll conlract. II
you do not cure e delaull. where allowed by Ilw. the Credllor
may require you to PlY al once the unpaid Amounl Financed plul
Iha eerned Ind unpaid part 01 the Finance Charge, He may reo
pOllel1 (take back) the vehicle too, He may allo take gooda
lound In or on the vehicle when repol..lled and hold them lor
you,
IIlhe vahlcle la taken back, he will lend you a nollce, The nollce
will Itele that you may redaem (buy blck) the vahlcle. It will
allo ahow the omounl nleded to redeem. Vou may redeem the
vehicle up to Ihe lime the Credllor lelll II or agrees 10 lell II, II
you do nol redeem Ihe Yahlcle. It will be lold.
The money from the lale, lell allowed expenlea, will be uaed to
pay Ihe amounl ItIIl oWld on thla contract. Allowed expenaea
are thOle plld al a direcl relult of hIving to retake the vehicle.
hold II, prepare II lor sela and aell II, al permitted by law, Law.
yere' leea and legal COlla permllled by law are allowed too, II
Ihere la any money lelt (a aurplul). II will be peld to you, II Ihe
money Irom the eale la not enough to pay 011 thla conlracl and
coale, you will pay what la etlll owed to Ihe Creditor.
G. General: Any change In thll contract musl be In wrlllng end
ligned by you and the Credllor. The law 01 Penneylvlnla applies
to Ihla contrlct. II that law doea not IlIow all ollhe agraementa
In Ihl. contract, Ihe onel thai are nol allowed will be void, The
real 01 thia contracl will .1111 be good,
NOTICE - ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL
CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF
GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF.
RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE
DEBTOR HEREUNDER.
Ueed Motor Vehicle Buyere Guide. II you are buying a uaed vehicle wllh Ihia contract, federal regulatlona may require a
a~ecial Buyera Guide 10 be dlspleyed on the window of the vehlcla, THE INFORMATION YOU SEE ON THE
WINDOW FORM FOR THIS VEHICLE IS PART OF THIS CONTRACT. INFORMATION ON THE
WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE.
GUARANTY
To cau.e the Seller to aelllhe vehicle deecrlbed on the Iron I olthla conlracl to Ihe Buyer. on credll, each peraon who Ilgnl below aa a
"Guaranlor" guaranteea the paymanl 01 thla conlrlct. Thla meana that II the Buyer falla to pay eny money Ihat Ie owed on Ihia conlract
eech one who signs aa a guaranlor will pay II when aaked. Each peraon who algn. below agrees Ihat he will be liable for Ihe whole amouni
owed eyen if one or more olher peraona alao sign. Ihls Guaranty, He alao agree. to be liable even IIlhe Credllor does one or more 01 Ihe
lollowing: (a) giyea Ihe Bu,yer more lime to pay one or more payment a, or (b) give. e relea.e in lull or In part to any ollhe othar Guarantora,
or (c) releases any aecullly. Each Guaranlor al.o .talea Ihal he haa recelyed a compleled copy 01 Ihia conllact and thll Gu.ranly al the
lime 01 signing.
Guarantor
Guarantor
Addre..
Addres.
EXHl8rr ON
'..
A::l::lIUNMt:N I
The selle; (horeinoner called Seller) named on the fece 01 thb within conlrecl (hereinener celled Ihe Contract) salls, assigns'and Iranslars to
Ford Motor Credil Company (herainanar callad Ford Credil) Seller's entire righi, tille and interest in and to Ihe Conlract and the property
(hereinaner callad Ihe Proparty) dascribed Iherein and authorizes Ford Cradit 10 do avery act and thing nacossary to collact and dlscharga
obllgallons arising aula' or incidenl 10 the Contract and this Assignment. In order 10 induce Ford Credit to accept asslgnmant of tha Contract,
Seller warrants that: the Contract. and guaranty. If any, are Denuine, legally valid and enforceable and arOSG from the lale of the Property: the
Property III 8S represented to the buyer (hereinafter called Buyer) named therein who was quoted both 8 tolal 881e price and. Ie..., cash
price; the Contract was complete in all respects and Seller mode all disclosures required by law, and In tho manner required by law. prior to the
..ecutlon Ihereof by Buyer; Buyer Is not a minor, has capacity to contracl and paid the downpayment stated in the Contract with his own lunds;
all slalemenls made by or on behall of Buyer and furnished to Ford Credit by Seller are true to the best 01 Saller's knowledge and belief. end
Seller has no knowledge of any fact Ihal would impair the validity or valua of the Contract; tille to Ihe Property Is vested In Seller Iree of all
liens and encumbrances and Seller has the rlghl to assign said titla; and a certllicate 01 tille to the Property Showing a lien or encumbrence for
Ihe benefit 01 Ford Credit or Saller has been or will ba applied for forthwith II parmitted by law. II Ihere Is eny breach of any of the foregoing
warranties, withoul regard to Seller's knowledge or lack 01 knowladge with respect thereto or Ford Credit's rellence thereon. Seller hereby
sgrees unconditionally 10 purchase the Contract from Ford Credit, upon demand, 'or the lull amount then unpaid whether Ihe Contract shall then
be, or nol be, In default. Seller 'urthar agrees that In Ihe evenl Buyer or any olher parson makes a claim agelnsl Ford Credit alteglng facte
which, II Irue, would constltule a breach 01 any 0' the 'ore going warranties. Seller shalt assume the defense 0' such claim end shall Indemnlly
and save Ford Credit harmless from all loss, cost and expense arising therelrom. In addition, Ihis Asslgnmenl Includes the provlsiona 0' the
paragraph inillaled below by Seller; provided, thai II none of the paragraphs below hes been Initialed by Seiter. this Assignment shall Include
the provisions of the paragraph below entlllad "Repurchesa", The lIabltity 0' Seller shall not be affected by any eXlenslon, renewal or other
change In the time 01 payment 0' the Contract. or any change In the menner, place or tarms 0' payment thereol. or the release. settlement or
compromise alar with any party liable for the payment thereof or the release or non'perlection 0' any security thereunder. Ford Credit shall not
be bound to exhaust its recourse against Buyer or any othar person or any security Ford Credit may at any time hsve befora being entllled to
payment Irom Seller hereunder. Seller waives notice of Ihe acceptance of this Assignment and notices 0' non.payment and non.performance 01
the Contract and any othar notices requlrad by law and waives all setoffs and counlerclaims. This Assignment shall become affectlva upon
dallvery Of tha Contract to Ford Credit or upon Ford Credit's paymant of the purchase prioe therefor, whlchevar first occurs,
Initial
D
Initial
D
Initial
D
Initial
D
Initial
D
Initial
D
Initial
D
Initial
"WITHOUT RECOURSE" This Assignment of Ihe Contract is and shalt be without recourse against Saller. except as otherwise provld.
ed by the terms of the Ford Credit Retail Plan In effect el Ihe time this Assignment becomes effective,
"REPURCHASE" Seller guerantees paymenl 01 the full emount remaining unpaid under the Contract and covenante If defaull be made
in payment 01 any instalment thereunder 10 pay the lulf amount then unpaid to Ford Credit. upon demand, except as otherwise
provided by the terms of the Ford Credit Retail Plan in ellect at the time this Assignment becomes effective.
"LIMITED REPURCHASE" Seller guarantees payment of the full amount remaining unpaid under the Contract and covenants II default
be made in paymenl of any inatalment thereunder to pay the lulf amount then unpaid 10 Ford Credit, upon demand. excepl as othar.
wise provided by the terms 01 the Ford Credit Retail Plan in effect at the time Ihis Assignment becomes effective; provided. that If
Buyer satislactorlly pays the number ollnstalmenta under the Contract specilied in the Ford Credit Retail Plan, this Assignment shall
theraano.r be without recourse against Seller. except es otherwise provided by the terms of the Ford Credit Retail Plan in effect at
Ihe time this Assignment becomes effective,
"PARTIAL GUARANTY" Notwithstanding the terms 0' the Ford Credit Retail Plan. Seller unconditionally guarantees payment 0' the lull
amount remaining unpaid under the Contract, and agrees to purchese the Contract Irom Ford Credit, upon demand, for tha lull amount
then unpaid whether the Contract shall then be, or not be..ln defauit; provided, that at the time 0' any such demand by Ford Credit,
Seller may, at his election. pay to Ford Credit the aum of $ In consideration 01 baing released from such
guaranty obligation, and In such event, thia Assignment 01 the Contract Is without recourse against Seller, except aa otherwlae
provided by the terms of the Ford Credit Retail Plan in effect at the time this Assignment becomes effective,
"LIMITED TERM REPURCHASE" Seller guarantees payment 0' the full amount remaining unpaid under the Contract, and covenants If
delault be made in payment of any instalment thereunder to pay the full amount then unpaid to Ford Credit, upon demand, except as
otherwise provided by the terma 01 the Ford Credit Retail Plan In effect at the time this Assignment becomes effective; provided, that
II Buyer satlslactorily pays each 0' the llrat Instalments coming due under the Contract. this Assignment shalltherealter
be without recourse against Seller, except as otherwise provided by the terma 01 the Ford Credit Retait Plan in effect at the time this
Assignment becomes effective,
"FULL GUARANTY" Notwithstanding the terms of the Ford Credit Retail Plan, Seller unconditionally guarantees Payment 01 the lull
amount remaining unpaid under the Contract and agreee to purchesa the Contract from Ford Credit, upon demand, lor the fult amounl
then unpaid whather the Contract ahalt than be. or not be, In default,
"FORO OEALER RETAIL TRUCK FINANCE PLAN" Except 'or breach 01 any 01 the foregoing warranties this Aaslgnment shalt be
governed by the "Ford Oealar Retail Truck Financing Agreement" heretofore executed by Ford Credit and Seltar.
"FORD FLEET TRUCK FINANCE PLAN" Except for braach 01 any of the foregOing warranties this Aeslgnment ehall be govarned by
the "Truck Fleet Salee Financing Agreemant" between Ford Credit and Ford Motor Company. datad September 19 1960 and a
"Dealer Truck Financing Agreement" between Seller and Ford Motor Company, ' ,
Fe 17837 AUG 87 Previous edition' mly NOT b. Ill.d.
EXHIBIT "A"
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V E R I F I CAT ION
I, William T. Molczan, Esquire, state that I am not a party to
the action but that at the request of the Plaintiff, Ford Motor Credit,
and based upon knowledge, information, records, and documents supplied
to me by the Plaintiff, the averments set forth in the Complaint are
true. A Verification executed by the Plaintiff can be supplied at time
of trial or upon request.
I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to
authorities.
Date:
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c:c:r+lONWEAL'llI OF PENNSYLVANIA:
coum'Y OF ClM3ERLAND
SHERIFF'S RETURN
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 94-2744 Civil Term
Complaint in Ciivl Action and
Notice
Ford Motor Credit
VS
Alan M. Irvin
Daniel Peiper
, Sl4~X<<Jl(lCeputy Sheriff of
Cunberland County, Pennsylvania, who being duly sworn according to law, says,
that he served the within
Complaint in Civil Action and Notice
upon
A1'ln M. Irvin
, the defendant, at 4: 10
o'clock
p .M. ~ / EDST, on the
day of
, 19 94at
25
May
710 N. Hanover St.. Apt. 30GE, Carlisle
. Cunberland County,
Pennsylvania, by handing to Alan M. Irvin
a true and attested copy of the Complaint in Civil Action and Notice
and at the sarre time directing
his
attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
14.00
2.80
So answers:
~~~~~
R. Thomas Kline, Sheriff
bY~&~
Deputy Sheriff
2.00
18.80 Pd. by Atty.
5-26-94
Sworn and subscribed to before rre
this _ / Ai-
day of C)'u..._=--
19
C/I,
A.D.
I~ljt'- It nW(,-~ I ,,-r,l\
Prothonotary
~1
FORD MOTOR CREDIT,
Plaintirt
IN TilE COURT OF COMMON PLEAS OF
VS.
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94-2744 CIVIL TERM
ALAN M. IRVIN,
Defendant
NOTICE TO PLEAD
TO: Ford Motor Credit
You are hereby notified to file a written response to the
enclosed New Matter within twenty (20) days from service hereof
or a judgment may be entered against you.
/'
Date: (,:-.:? 7- 'I 1/
.#
Ph lip . Brigant
Attorney for Defendant
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, pa 17013
(717) 243-9400
ANSWER
COMES NOW the defendant, Alan M. Irvin, by and through
counsel, Philip C. Briganti, Esquire, Legal Services, Inc., and
as his response to Plaintiff's Complaint, states as follows:
1. Admitted.
2. Admitted.
3. Denied. As set forth below in Defendant's New Matter,
Defendant was unable to purchase personal property or enter into
a written agreement for the purpose of financing said property,
because he lacked the requisite mental capacity.
4. Admitted in part and denied in part. Defendant admits
that Plaintiff is the holder of said Agreement. However, for
reasons set forth below in Defendant's New Matter, Defendant
denies that Plaintiff is entitled to payment under the terms
thereof.
5. Denied. Defendant denies that he defaulted for failing
to make payments when and as due, or that Plaintiff incurred a
loss for which it is entitled reimbursement from Defendant,
because Defendant was not bound by the Agreement due to his lack
of capacity to enter into it.
6. Denied. Defendant denies that the outstanding balance
due from him to Plaintiff is $8,028.70, plus interest from
October 9, 1991, at the contract rate.
,-.-- .,.-.-q ;.
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I
'.
7. Admitted.
NEW MATTER
I. Holder in Due Course
8. On or about May 16, 1991, K and H Ford, Inc., through
its agent, induced Defendant to sign a contract for the purchase
of a 1991 Ford Crown Victoria vehicle. See Plaintiff's Exhibit
nAn.
9. subsequently, K and H Ford, Inc., assigned this contract
to Plaintiff.
10. Plaintiff is a "holder" of this contract within the
meaning of 69 P.S. S1402, and, pursuant thereto, is subject to
all claims and defenses which Defendant could assert against K
and H Ford, Inc. and/or its agents.
11. Pursuant to the express terms of the contract, Plaintiff
as holder of the contract, is "subject to all claims and defenses
which the debtor (Defendant) could assert against the seller of
goods or services" obtained pursuant thereto.
II. Lack of Capacity
12. Defendant repeats and incoporates by reference his
averments contained in Paragraphs 8 through 11.
13. At the time Defendant signed the purported Agreement, he
suffered from various forms of mental illness, including but not
limited to bipolar disorder and severe depression.
14. Defendant's mental health problems were obvious, and
were apparent to the salesperson who sold him the vehicle.
15. As a consequence of Defendant's mental illness, he
,
.
lacked the mental competence or capacity to understand, enter
into or consent to the Agreement, or appreciate the consequences
thereof.
III. Unconscionability
16. Defendant repeats and incorporates by reference his
averments contained in paragraphs 8 through 15.
17. This Agreement, and the circumstances surrounding its
procurement, are unconscionable, in violation of 13 P.S. S2302.
IV. Violation of Dutv of Good Faith
18. Defendant repeats and incorporates by reference his
averments contained in Paragraphs 8 through 17 herein.
19. K and H Ford violated its duty to deal with Defendant in
good faith, in violation of 13 P.S. S1203.
WHEREFORE, Defendant respectfully requests that this Court
declare that the parties' purported contract is void, and enter
judgment in favor of Defendant and against plaintiff.
1,/ '
I;W~ ~r:4~:t~'
ph11ip rt: Briga ti
Attorney for Defendant
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
~
4
FORD MOTOR CREDIT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
VS.
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94-2744 CIVIL TERM
ALAN M. IRVIN,
Defendant
CERTIFICATE OF SERVICE
I, Philip C. Briganti, hereby certify that a copy of the
foregoing Notice to Plead, Answer and New Matter, is this -<~~
day of June, 1994, being served upon Donald S. Mazzotta,
Attorney at Law, 938 Penn Avenue, pittsburgh, Pennsylvania,
15222, by first-class mail, postage prepaid.
Ph 1 P
Attorn y for Defendant
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
FORD MOTOR CREDIT COMPANY
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO. 2744 CIVIL TERM 1994
ALAN M. IRVIN
Defendant
CIVIL ACTION - LAW
NOTICE OF MEETING OF ARBITRATORS
,
Please take notice that the arbitrators appointed in the above-captioned
action will sit for the purpose of their appointment on Monday. November 10.
1997 at 11:30 a.m. in the Second Floor Ilearing Room of the Old Cumberland
County Court Ilouse. Carlisle. Pennsylvania.
Date ()rdo p pL. 1 ltit) 7
TO:
Debra Wallet. Esquire
24 N. 32nd Street
Camp Hill. PA 17011
Arbitrator
Donald S. Mazotta. Esquire
Firm 0742
938 Penn Avenue
Pittsburgh. PA 15222
Attorney for Plaintiff
Barbara Sumple-Sullivan. Esquire
749 Bridge Street
New Cumberland. PA 17070
Arbitrator
Philip C. Briganti. Esquire
Legal Services. Inc.
8 Irvine Row.
Carlisle. PA 17013
Attorney for Defendant
Thomas F. Cheffins
1 Courthouse Square
Carlisle. PA 17013
Court Administrator
Alan M. Irvin
710 Hanover Mnr.
Apt. 306E
Catlisle. PA 17013
Defendant
~
tIr~~Afi(lp;,. (>R,t/I/- C6J11I/J1/II:
Plllintiff
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~fe1 CIVIL TERM J 'i ~ 'I
~ f) '11.J
v. '
t9 L II 1./ !/J.. IJ- '" )~
po~ flAlUo, ~ I bl 0. PEn "I)
flaW,d3nt t
IN en 7" .
CIVIL ACTION - LAW
NOTICE OF MEETING OF ARBITRATORS
'.
Please take notice that the arbitrators appointed in the above-captioned
action will sit for the purpose of their appointment on ~~~d~Y, ~~t'~1~~ I~
JI: 117
1997 at ~ a.m. in the Second Floor Hearing Room of the Old Cumberland
County Court House, Carlisle,
Pennsylvania.
By: 'jjl1&.~ tJ~A-.
William A. Yocum, E re ChaHlIlan
Date ~ .
TO: '
Jl~~)-l J~.!~ft~t. Esquire !.~It:.:!~l.:~~~if(f.&eE~f'It/~(J
~H8 TdRII18 bad ;}.IIN, J21;:..J SJI-~Q.p4 tr..~< Mal.. 3ld~et FI~n,Jt?"2
Camp Hill, PA 17011 MeGha..l~abuL!;' fl, '''l:l~ 'J'Jf) PtW,," /},:./,h.,.tfJ
Arbitrator Att.orney for Plaintiff fiJl~~t" L. rA /~..,..,
, ' , .5 I ",~'2
8{)vh.,/".jJ ~""'I>/p- f1,11,,,,:J-., j;<;((H,..t PI>, l,p I'. 8i-15.:J~JI'
1Jd.sa ~Byt1t.. Eg4dira M""luILd~: F &.1~4m8RJ Esquire .
3901 ~".r-' '~~eet ')/11) /j;,IjP S'j,.""ff19'd N. 6~~u..d :hLeel tepJ 5't>vl'/rpS :r..C
'Cae.p Hill. P' 178ti }/p,>, C"",M..I?...J P"nd,uu~" 3ull..- 8::L r 1/1 h~ fpv
Arbitrator fA I~P% I V,g. BUA 984
. Ilanilrlm~ll. 1.. 17100 C ;n./d1Pj /'~ J'}~/3
Attorney for Defendant
Thomas F. Cheffins
1 Courthouse Square
Carlisle, PA 17013
Court Administrator
,
A I?IJ PJ. I y. VII,
?/tJ /JiJl7((,,'(;'/r PlhY',
) 1"1: .3i1~ E
C11-h5h'J fA 1?t'lJ
Pr.> fp" ,h." j- .
FO{e.D IlJotor (',ed;t
v
IJ 11//1 1lJ. 7,ev;'i..;
IN THE COURT OF CO~~ON PL&AS OF
CL1>IBERLAND COUNTY, PENNSYLVANIA
NO. 017/11/
CIVIL
199f
RULE 1312-1, The Petition for Appointment of Arbitrators shall be sub5tant~ally
in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE. THE JUDGES OF SAID COURT:
lbAlIJL.b, s: /lJ1J2:zdta.... , counsel for the plaintiff/d-e;"lldant; in
the above
1.
2.
action (or actions). respectfully represents that:
The above-captioned action (or actions) is (are) at issue.
The claim of the plaintiff in the action is $ 3. O;(.J'. 70
The counterclaim of the defendant in the action is
The following attorneys are ~nterested in the
wise d~squalified to sit as arbitrators:
case(s) as counselor are other-
1%'/';10 {l, ~~ 'ft)/I-t-:
WHEREFORE. your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
ORDER OF COURT
AND NOW. SE-PA.., ,J,U J5 , 1997, in consideration of the
foregoing petition, ~I 'JifA~ ~. ~".II.w71 ESq..~~
Esq., and - '"I sq.. are appointed arbitrators in the
above-captioned action (or actions) as prayed for.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ford Motor Credit,
PLAINTIFF,
)
)
)
)
)
) NO. 94-2744 Civil Term
)
)
) TYPE OF PLEADING: PRAECIPE
) FOR ARBITRATION DATE
)
) CODE - 011 - ASSUMPSIT
)
) FILED ON BEHALF OF: PLAItlTIFF,
) Ford Motor Credit
)
) COUNSEL OF RECORD FOR THIS PARTY:
)
)
)
) DONALD S. MAZZOTTA, ESQUIRE
) PA I.D. #11461
)
)
) LAW OFFICES OF DONALD S. MAZZOTTA,
) P.C.
) FIRM #742
) 938 PENN AVENUE
) PITTSBURGH, PA 15222
)
) (412) 471-0300
VB
Alan M. Irvin,
DEFENDANT.
,,-. .
-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ford Motor Credit,
)
)
)
) NO. 94-2744 Civil Term
)
)
)
)
)
)
)
)
)
PLAINTIFF,
VS
Alan M. Irvin,
DEFENDANT.
PRAECIPE FOR ARBITRATION HEARING
TO: Prothonotary of CUmberland County
SIR:
Please list the above-captioned matter on the Arbitration
Hearing list for the first available date.
Attorney for Plaintiff:
Law Offices of Donald S. Mazzotta
938 pe Avenue
Pitts gh, PA
'5
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IN THE COURT OF COMMON PLEAS OF CUMBBRLAND COUNTY, PENNSYLVANIA
FORD MOTOR CREDIT COMPANY.
Plaintiff,
vs.
ALAN M. IRVIN
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
CIVIL DIVISION
CASE NO. 94-2744
CODE:
PLAINTIFF'S REPLY TO
DEFENDANT'S NEW MATTER
FILED ON BEHALF OF:
FORD MOTOR CREDIT COMPANY
COUNSEL OF RECORD FOR THIS
PARTY:
DONALD S. MAZZOTTA, ESQUIRE
PA I.D. #11461
LAW OFFICES OF
DONALD S. MAZZOTTA, P.C.
Firm #742
938 Penn Avenue
Pittsburgh, PA 15222
(412) 471-0300
... . ........
,. . '.-..
IN THE COURT OP COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA
FORD MOTOR CREDIT COMPANY,
Plaintiff,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
CIVIL DIVISION
CASE NO. 94-2744
vs.
ALAN M. IRVIN
PLAINTIPP'S REPLY TO DEPENDANT'S NEW MATTER
AND NOW, comes the Plaintiff, FORD MOTOR CREDIT COMPANY, by
and through its attorneys, Donald S. Mazzotta, Esquire and the Law
Offices of Donald S. Mazzotta, P.C. and files the following Reply
to Defendant's New Matter as follows:
1. Paragraph 8 is admitted.
2. Paragraph 9 is admitted.
3.
Paragraph 10 is denied.
This paragraph contains a
conclusion of law to which no responsive pleading is required and
the same is therefore denied.
4.
Paragraph 11 is denied.
This paragraph contains a
conclusion of law to which no responsive pleading is required and
the same is therefore denied.
s.
Paragraph 12.
See Plaintiff's reply to paragraphs 8
through 11.
6. Paragraph 13 is denied. After reasonable investigation,
Plaintiff is unable to ascertain the truth or falsity of this
paragraph and the same is therefore denied and, if material, strict
I
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FORD MOTOR CREDIT COMPANY
I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
V.
.
.
.
.
ALAN M. IRVIN
I NO. 94-2744 CIVIL TERM ,/
.
.
I CIVIL ACTION - LAW
ORDER OF COURT
AND NOW, NOVEMBER 11, 1997, the Court having been
informed that the parties have reached a settlement, the Board of
Arbitrators previously appointed is hereby vacated. The Chairman
shall be paid the sum of $50.00.
F
Sheely, P.J.
William Yocum, Esquire
Chairman
Court Administrator
Isld
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CU'.';':;" ",!'. ,..~U'ITY
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PCI~N~\'L\~\ilii,~
~
FORD HOTOR CREDIT COMPANY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
.
.
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
.
.
: NO. 94-2744 CIVIL TERM
ALAN H. IRVIN,
.
.
Defendant
.
.
ORDER 01' COURT
AND NOW, this 7.fl...- day of November, 1997, upon
consideration of the attached Stipulation for Judgment, it is
hereby ORDERED as follows:
1. A judgment is entered in favor of Plaintiff and against
Defendant in the amount of SIXTEEN THOUSAND ONE HUNDRED EIGHT
DOLLARS AND THIRTY-SIX CENTS ($16,108.36), together with interest
at the rate of six percent (6%) per annum from the date of
judgment.
2. Plaintiff shall not execute on this judgment so long as
Defendant pays.to Plaintiff the amount of FIFTY DOLLARS ($50.00)
per month on or before the last day of each month, beginning in
November 1997.
3. In the event that Defendant fails to make timely payment
pursuant to this Stipulation anc. order, i?la.iu<..i.L:.L: ..i...:&.1 fila ::.::
affidavit of non-complianc~ with the Prothonotary and the entire
Judgment amount less credit for any payments made prior to breach
shall be immediately due and payable and subject to the execution
process.
4. The arbitration hearing scheduled in the abo"e-captioned
matter for November 10, 1997, at 11:30 a.m., is cancelled.
By the Court,
10/ ~~ fl.~
_ J.
Donald s. Mazzotta, Esquire
Counsel for Plaintiff
TRUE COpy FROM RECORD
In Testimony whoreof, I here unto III my hind
and I I ~ af said Court at Carllale, PI.
, 1
Philip C. Briganti, Esquire
Counsel for Defendant
V.
IN THE coURT 01" COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2744 CIVIL TERM
FORD MOTOR CREDIT COMPANY,
Plaintiff
ALAN M. IRVIN,
COME NOW, this
Defendant
STIPULATION ~OR JUDGKEHT
/'J!-'- . i
b day of November, 1997, the part1es n
the above-captioned action, by and through their respective
undersigned counsel, and stipulate as follows;
1. A judgment shall be entered in favor of Plaintiff and
against Defendant in the amount of SIXTEEN THOUSAND ONE HUNDRED
EIGHT DOLLARS AND THIRTY-SIX CENTS ($16,108.36), together with
interest at the rate of six percent (6t) per annum from the date
of judgment.
2. Plaintiff shall not execute on this judgment so long as
Defendant pays to Plaintiff the amount ot FIFTY DOLLARS ($50.00)
per month on or before the last day of each month, beginning in
November 1997.
3. In the event that Defendant fails to make timely payment
pursuant to this stipulat1~n ~.nci orde:r, Plai.nt:i.7;f shall fila a.,
atfidavit of non-compliance with the Prothonotary and the entire
Judgment amount less credit for any payments made prior to breach
.hall be immediately due and payable and subject to the execution
process.
4. The parties agree that this stipulation shall be entered
as an Order of Court by the CUmberland county Court of Common
.
.
Pleas and that the arbitration hearin9 scheduled 1n the above-
captioned matter for November 10, 1997, at 11:30 a.m., shall be
cancelled.
.
Id S. Mazzo
Counsel for Plai
LAW OFFICES OF 0
MAZ::OTrA, .P_C.
938 Penn Avenue
Pittsburgh, PA 15222
(412) 471-0300
i11 c. Brig i, Esquire
Counsel for Defendant
LEGAL SERVICES, INq
a Irvin!! R::w
carlisle, PA 17013
(717) 243-9400