Complaint,Petition: Ford Motor Credit Company LLC Plaintiff vs. Francisco Martin Defendant

On February 08, 2021 a Complaint,Petition was filed involving a dispute between Ford Motor Credit Company Llc, and Martin, Francisco, for 3 in the District Court of Broward County.

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Case Number: COWE-21-001216 Division: 81
Filing # 121014578 E-Filed 02/08/2021 04:01:21 PM
IN THE COUNTY COURT IN AND FOR
BROWARD COUNTY, FLORIDA

CASE NO.
Civil Division
FORD MOTOR CREDIT COMPANY LLC,
a Delaware Limited Liability Company,
Plaintiff,
vs.

FRANCISCO MARTIN
Defendant(s).
/
COMPLAINT

Plaintiff, FORD MOTOR CREDIT COMPANY LLC, a Delaware Limited Liability
Company authorized to do business in Florida, files this it’s Complaint against the Defendant(s)
and states:
1 This is an action for damages which exceed EIGHT THOUSAND ($8,000.00)
DOLLARS but are less than THIRTY THOUSAND ($30,000.00) DOLLARS.
Plaintiff, FORD MOTOR CREDIT COMPANY LLC, is a Delaware limited liability
company authorized to conduct business in Florida.
On or about 07/16/2018, Defendant(s) executed a Vehicle Retail Installment Contract, a
copy of which is attached hereto as Plaintiffs Exhibit “A.”
Plaintiff is in possession of the Vehicle Retail Installment Contract.
The Defendant(s) defaulted due to non-payment under the Vehicle Retail Installment
Contract. Plaintiff took possession of the subject vehicle, a 2018 FORD FOCUS, VIN:
1FADP3J24JL264973 on or about 10/07/2019. That Notice of Intent to sell the vehicle
was sent to the Defendant(s) in accordance with the Uniform Commercial Code. A copy
of this notice is attached hereto as Plaintiff's Exhibit “B.”
Defendant(s) failed to redeem the subject vehicle within the time set forth in Plaintiff's
notice.
Plaintiff has incurred certain expenses in retaking, holding, preparing for sale and selling
the subject vehicle.
On or about 12/03/2019, the subject vehicle was sold in a private sale.
Upon the sale of the subject vehicle and the application of the proceeds there from, there
remains a balance due and owing to Plaintiff by Defendant in the sum of $17765.52,
together with interest, which Plaintiff has demanded. A copy of the breakdown
calculations is attached hereto as Exhibit “C."

#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/08/2021 04:01:19 PM.**#*
10. Plaintiff has performed all conditions precedent to its right to recovery.
11. Plaintiff has obligated itself to pay its attorneys a reasonable fee for their services in this
cause. If Plaintiff is successful in this action, Defendant(s) is/are responsible for the
payment of these attorney’s fees under the terms of the Vehicle Retail Installment
Contract. In the event this matter is by default, a reasonable attorney’s fee would be
$500.00.

This is an attempt to collect a debt. Any information obtained will be used for that purpose.
WHEREFORE, the Plaintiff demands judgment in the amount of $17765.52, together with
interest, court costs and a reasonable attorney’s fee.
Dated: January 20, 2021.

Moody, Jones & Ingino, P.A.
Attorney for Plaintiff
1333 S. University Drive, Suite 201
Plantation, Florida 33324-4001
Telephone: 954-473-6605
Facsimile: 954-473-6855
Toll Free: 800-267-6605

By: _/s/ Michael J. Ingino 4
Michael J. Ingino, Esquire
Florida Bar No. 0057721
9000020924.001 / 250
This is a Copy of the Customer Completed signed electronic form held by RouteOne LLC.
056638397

GEORGIA VEHICLE RETAIL INSTALLMENT CONTRACT DATE 07/16/2018
Buyer (and Co-Buyer) Name and Address (Including County and Zip Codey SELLER/CREDITOR (Seller Name and Address)
FRANCISCO MAR"
746 WILLIAM H AVE BUILDING 714
Fort Stewart, GA 31315 LIBERTY
C LEW
9505 ABERCORN
SAVANNAH, GA 31406
STREET
NIA

You, the Buyer (and Co-Buyer, if any), may buy the vehicle described in this contract for cash or on credit. The cash price is shown on
Page 2 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 in this contract.
“FEDERAL TRUTI -LENDING DIS SURES oo
ae
ANNUAL FINANCE Amount Total of ~ Total Sale
PERCENTAGE CHARGE Financed Payments Price
RATE The dollar amount The amount of The amount The total cost
The cost of your the credit will credit provided you will have of your purchase
credit as a yearly rate cost you to you or on paid when you ‘on credit,
your behalf have made ail including your
scheduled downpayment
payments
1-800-727-7000
off 615.75
1.90 IS $
ZB | ronocreorr
1,875.37 31,413.83 $ 33,289.20 $ 33,904.95.
Your Payment Schedule will be:

Number of Payments www. fordcredit.com
‘Amount of Payments When Payments are Due
Monthly unless otherwise checked
1 Semi-Annually 1 Annually
72 $ 462.35 Starting: 08/30/2018

Prepayment: If you pay off your debt early, you will not have to pay a penalty.
Late Payment: You must pay a late charge on the portion of each payment received more than 10 days late.
The charge is 5 percent of the late amount or $50.00, whichever is less.
Security Interest: You are giving a security interest in the vehicle being purchased.
Contract: Please see this contract for additional information on security interest, nonpayment, default, the right
to require repayment of your debt in full before the scheduled date, and prepayment penalty.
- =
BALLOON CONTRACT PROVISIONS.
(1 Your last scheduled payment under this contract is a balloon payment.
E AND MILE,
If the box directly above is checked, this section, Paragraph B, and Paragraph C of this contract apply. You may be charged for
excessive wear based upon our standards for normal use. If you exercise the option to transfer ownership of the vehicle to Creditor
under Paragraph B, you must pay the Creditor $0. N/A per mile for each mile in excess of NIA miles shown on the
odometer.

The Annual Percentage Rate may be negotiated with the Seller. The Seller may assign this contract and may
retain its right to receive a portion of the Finance Charge.

exeueir «A?
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New/Used Mileage Year and Make Model Vehicle Identification Number Use For Which Purchased
Personal use unless otherwise
New 29 2018 Ford Focus 1FADP3J24JL264973 checked below
[Commercial [] Agricultural

Trade-in 2015 Ford $ 11,650.00 $ 13,034.25
Year and Make Gross Allowance Amount Owing

_ ITEMIZATIONOF AMOUNT FINANCED _ £
1. Cash Price .... $7631.58 (1)
2. Down Payment
Third Party Rebate Assigned to Creditor. .$ 500.00
Cash Down Payment 1,500.00
NIA NIA
Trade-in (description above)..... 1,384.25
Total Down Payment... $ 615.75 (2)
3. Unpaid Balance of Cash Sale Price (1 minus 2) $ 26,015.83 (3)
4, Amounts paid on your behalf (Seller may be retaining a portion of these amounts)
To Public Officials
(i) for license, title & registration fees $ 18.00 ;
(ii) for filing fees $ NIA ;
(iii) for taxes (not in Cash Price) $ NIA 18.00
To Insurance Companies for:
Credit Life Insurance... N/A
Credit Disability Insurance... N/A
N/A a NIA
NIA ae N/A
To Century Automotive Service Cor for Maintenance Plan 1,295.00
To JC LEWIS FORD LLC for Documentary Fee 599.00
To State of Georgia for Georgia Lemon Law Fee 3.00
To GWC Warranty Corporation for Service Contract 2,188.00
To Vantage Administration Service for Bundled Product 1,295.00
To N/A for N/A. NIA
To NIA for N/A NIA
To NA for N/A N/A
To NIA for N/A N/A
Total. 5,398.00 (4)
5. Amount Financed (3 plus 4)... 31,413.83 (5)

Debt Cancellation Waiver Addendum (Optional)

Purchase of the debt cancellation waiver is optional and is not required to obtain credit. The terms and conditions of the debt
cancellation waiver are set forth in the attached Addendum which is incorporated into the contract. By signing below you agree to
purchase the debt cancellation waiver for the price set forth on this contract in the Itemization of Amount Financed under section 4.

Buyer Signs A N/A

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a
IRANCE :
YOU ARE REQUIRED TO INSURE THE VEHICLE. YOU MAY OBTAIN VEHICLE INSURANCE FROM A PERSON
OF YOUR CHOICE.
LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS IS
NOT INCLUDED.
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.

Credit Life NIA $ NIA NA
Insurance Company Premium Insured(s)

You/We want Credit Life Insurance.

B N/A B N/A
Buyer Signs Co-Buyer Signs

Credit N/A $ N/A N/A
Disability Insurance Company Premium Insured(s)
You/We want Credit Disability Insurance.

c N/A Cc N/A
Buyer Signs Co-Buyer Signs

Other Coverage Insurance Company Premium | Term in Months
Optional 4 -
Insurance NIA _NA NIA NA
NIA NIA NIA NIA
1
You/We want the optional insurance for which premiums are included above.

N/A N/A
Buyer Signs Co-Buyer Signs

Credit Life and Credit Disability insurance are for the term of the contract. The amount and coverages are
shown in a notice or agreement given to you today.

Anti-Theft Product (Optional)
The purchase of anti-theft product(s) is optional and not required to obtain credit, even if the product(s) is already installed on the
vehicle you selected. You may purchase anti-theft product(s) from the person of your choice. By signing below, you agree to
purchase the anti-theft product(s) at the price disclosed.

NIA $ NIA Term NIA
NIA $ NIA Term NIA
NIA $ NIA Term NIA

D N/A
Buyer Signs

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aS Te
ITI. us
A Payments You must make all payments in U.S. funds when they al re due. You may prepay your debt at any time without penalty.
This is a simple finance charge 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 dates 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.
B. Balloon Payment Contracts: If your last scheduled payment under this contract is a balloon payment as indicated on Page 1 of
this contract, you have three options to handle the balloon payment.
First, you may pay all that you owe, and keep your motor vehicle.
Second, you may refinance all that you owe unless you are in default under this contract. If the Creditor has advanced funds to cure
any default, you must pay back the Creditor before the refinancing. You also must provide proof of insurance acceptable to Creditor
before the refinancing. The refinancing Annual Percentage Rate (APR) will be agreed to by you and the Creditor at the time of
refinancing and will not exceed the maximum APR permitted by law. Your refinanced monthly payment will be the same as in this
contract if the refinanced amount will be fully paid in 36 months or less. Otherwise, your monthly payment will be the amount needed
to fully pay the refinanced amount in 36 months. If you wish to refinance, you must notify the Creditor in writing no tater than 30 days
prior to the balloon payment due date.
Third, you may transfer ownership of the vehicle to the Creditor, and an amount equal to your originally scheduled balloon payment
will be applied toward the satisfaction of all that you owe. Creditor will add a $475 Disposal Fee to the amount that you owe and, if
applicable, will add any excess mileage charges (as described on Page 1 of this contract) and any estimated costs of vehicle repairs
that are the result of excess wear and use (as described in Paragraph C). If the amount of your originally scheduled balloon payment
does not satisfy all that you owe, you will pay the difference. You must take the vehicle to a place selected by the Creditor for
inspection no later than 15 days prior to the balloon payment due date. After the inspection, if you decide to transfer ownership of the
vehicle to the Creditor, you must give the vehicle to the Creditor no later than the balloon payment due date. At that time, you must.
provide the Creditor a title, which shows no liens other than the Creditor's lien, transferring ownership to the Creditor or a person
selected by the Creditor. You must also provide other documents as needed. If you decide not to transfer ownership of the vehicle
after inspection, you must immediately inform the Creditor if you want to refinance under the second option above.
Cc. Damage Repair: If your last scheduled payment under this contract is a balloon payment and you transfer ownership of the
vehicle to the Creditor under Paragraph B, you are responsible for all repairs to the vehicle that are not the result of normal wear and
use. These repairs include, but are not limited to those necessary to repair or replace: (a) tires that have sidewall damage/plugs,
exposed cords/belts, or are unmatched for vehicle or unsafe; (b) electrical or mechanical defects or malfunctions; (c) glass, paint,
body panels, trim and grill work that are broken, mismatched, chipped, scratched, pitted, cracked, or if applicable, dented; (d) interior
tips, stains, burns or damaged areas; (e) replacement of any missing equipment or parts that were in or on the vehicle when
delivered; and (f) all damage which would be covered by collision or comprehensive insurance whether or not such insurance is
actually in force. Replacement of sheet metal and all other repairs must be made with Original Equipment Manufacturer parts. Your
use or repair of the vehicle must not invalidate any warranty. You will owe the estimated costs of such repairs unless repairs are
made at your expense prior to the transfer of ownership of the vehicle to the Creditor. You will maintain the odometer of the vehicle
so that it always reflects the vehicle's actual mileage. If the odometer is at any time inoperative, you will provide reasonable evidence
of the vehicle's actual mileage. If you are unable to do so, you will pay us our estimate of any reduction of the vehicle's wholesale
value caused by the inability to determine the vehicle's actual mileage.
D. 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 under this contract. It also secures your other agreements in this contract.
E. Use of Vehicle - Warranties: You must take 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 of a 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, except as otherwise provided by law.
F. Vehicle Insurance: You must insure the vehicle against loss or damage from collision, fire or theft. You must name Creditor as
the loss payee under the insurance policy. The Creditor must approve the type and amount of insurance. If the vehicle is lost,
damaged or destroyed, you must pay the Creditor what is still owed.
You agree that the Creditor can make a claim under the insurance policy. You authorize the insurance company to provide Creditor
any information Creditor believes necessary to make a claim. You must use insurance proceeds to repair the vehicle, unless the
damage to the vehicle is considered a total loss. If the damage to the vehicle is considered a total loss, you must use the insurance
proceeds to pay what you owe the Creditor. If your insurance on the vehicle doesn't pay all you owe, you must pay what is still owed.
G. Returned Insurance Premiums and Service Contract Charges: This contract may contain charges for insurance, service
contracts, or other contracts. You agree that the Creditor can claim benefits under these contracts and unless prohibited by law,
terminate them to obtain refunds of unearned charges to reduce what you owe. If the Creditor gets a refund on insurance, service
contracts, or other contracts, the Creditor will subtract it from what you owe. Once all amounts owed under this contract are paid, any
remaining refunds will be paid to you.
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H. Default: You will be in default if:
You do not make a payment when it is due; or
You gave false or misleading information on your credit application relating to this contract; or
Your vehicle is seized by any local, state, or federal authority and is not promptly and unconditionally returned to you; or
You file a bankruptcy petition or one is filed against you; or
You do not keep any other promise in this contract.
If you default, Creditor can exercise Creditor's rights under this contract and Creditor's other rights under the law.
1. Repossession: If you default, 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. Creditor may repossess (take back) the vehicle, too.
Creditor may also take goods found in the vehicle when repossessed and hold them for you.
J. Your Right To Redeem: If the vehicle is taken back, Creditor will send you a notice. The notice will say that you may redeem
(buy back) the vehicle and will explain how to redeem the vehicle. You may redeem the vehicle up to the time the Creditor sells it or
agrees to sell it. If you do not redeem the vehicle, it will be sold.
K. Disposition of Motor Vehicle: If the vehicle is taken back and sold, the money from the sale, less allowed expenses, will be
used to pay the amount still owed on the contract. Allowed expenses are those paid as a direct result of having to retake the vehicle,
hold it, prepare it for sale, and sell it. Lawyer's fees equal to 15% of the amount still owed on the contract 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 will pay what is still owed to the Creditor. If you do not pay the amount when the Creditor asks, the
Creditor may charge you interest at the highest lawful rate until you pay.
L. Collection Costs: Except as otherwise provided by law, you must pay any and all expenses related to enforcing this contract,
including collection expenses, lawyers' fees (equal to 15% of the amount still owed on the contract) and other legal expenses.
M. Consumer Reports: You authorize the Assignee to obtain consumer credit reports from consumer reporting agencies (credit
bureaus) for any reason and at any time in connection with this contract.
N. Servicing and Collection: You agree that Creditor, Creditor's affiliates, agents and service providers may monitor and record
telephone calls regarding your account to assure the quality of our service or for other reasons. You also expressly consent and
agree that Creditor, Creditor's affiliates, agents and service providers may use written, electronic or verbal means to contact you.
This consent includes, but is not limited to, contact by manual calling methods, prerecorded or artificial voice messages, text
messages, emails and/or automatic telephone dialing systems. You agree that Creditor, Creditor's affiliates, agents and service
providers may use any email address or any telephone number you provide, now or in the future, including a number for a cellular
phone or other wireless device, regardless of whether you incur charges as a result.
0. Applicable Law: You agree that this contract will be governed by the laws of the state of Georgia.
P. General: This contract contains the entire agreement between Creditor and you relating to the sale and financing of the motor
vehicle. If any part of this contract is not valid, all other parts stay valid. If Creditor doesn't enforce Creditor's rights every time,
Creditor can still enforce them later. Creditor will exercise all of Creditor's rights in a lawful way.
Buyer acknowledges and accepts assignment of this contract to the Assignee (and any successor to Assignee). Buyer also consents
to any subsequent assignment of this contract, and accepts this provision as notice of any such assignment, by Assignee or anyone
else without further notice to Buyer. This consent and notice specifically includes any assignment of the security interest in the vehicle
financed pursuant to this contract.
R. Electronic Records and Signatures and Conversion to Paper: You agree to use electronic records and electronic signatures
to document this contract. Your electronic signatures will have the same effect as signatures on a paper contract.
There will be one authoritative copy of this contract. It will be the electronic copy in a document management system the Creditor
designates for storing it.
The Creditor may convert that authoritative copy to a paper original. The Creditor will do so by printing one paper copy marked
“Original.” This paper original will have your electronic signature on it. It will have the same effect as if you had signed it originally on
paper.
a
ES ae
ce FTCNO
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
Spanish Translation: Guia para compradors de vehiculos usados. LA INFORMACION QUE APARECE EN
LA VENTANILLA DE ESTE VEHICULO FORMA PARTE DE ESTE CONTRATO. LA INFORMACION CONTENIDA
EN EL FORMULARIO DE LA VENTANILLA ANULA CUALQUIER PREVISION QUE ESTABLEZCA LO CONTRARIO
Y QUE APAREZCA EN EL CONTRATO DE VENTA.
“Does not apply if purchased for commercial or agricultural use. In that case, you (debtor) will not assert against any assignee or
subsequent holder of this Contract any claims, defenses, or setoffs which you may have against the Seller or manufacturer of the vehicle.
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GUARANTY

To cause the Seller to sell the vehicle described in this contract to the Buyer on credit, each person who signs below as a
“Guarantor” guarantees the payment of this contract: This means that if the Buyer fails to pay any money that is owed on this
contract, each person who signs as a guarantor will pay it when asked. Each Guarantor who signs below agrees that he will be liable
for the whole amount owed even if one or more other persons also signs this Guaranty. Each Guarantor 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 paper copy of this contract and this Guaranty at the time of electronically signing.

Guarantor NIA

Address NIA

Guarantor Signs E N/A
EAD THIS ARBITRATION PROVISION CAREFULLY AND IN ITS ENTIRETY
ARBITRATION
Arbitration is a method of resolving any claim, dispute, or controversy (collectively, a “Claim") without filing a lawsuit in court. Either
you or Creditor ("us" or "we") (each, a “Party") may choose at any time, including after a lawsuit is filed, to have any Claim related to
this contract decided by arbitration. Neither party waives the right to arbitrate by first filing suit in a court of law. Claims include but are
not limited to the following: 1) Claims in contract, tort, regulatory or otherwise; 2) Claims regarding the interpretation, scope, or validity
lof this provision, or arbitrability of any issue except for class certification; 3) Claims between you and us, your/our employees, agents,
successors, assigns, subsidiaries, or affiliates; 4) Claims arising out of or relating to your application for credit, this contract, or any
resulting transaction or relationship, including that with the dealer, or any such relationship with third parties who do not sign this
contract.

RIGHTS YOU AND WE AGREE TO GIVE UP.
If either you or we choose to arbitrate a Claim, then you and we agree to waive the following rights:

. RIGHT TO A TRIAL, WHETHER BY A JUDGE OR JURY
. RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR A CLASS MEMBER IN ANY
CLASS CLAIM YOU MAY HAVE AGAINST US WHETHER IN COURT OR IN ARBITRATION
. BROAD RIGHTS TO DISCOVERY AS ARE AVAILABLE IN A LAWSUIT
. RIGHT TO APPEAL THE DECISION OF AN ARBITRATOR
. OTHER RIGHTS THAT ARE AVAILABLE IN A LAWSUIT

|RIGHTS YOU AND WE DO NOT GIVE UP: If a Claim is arbitrated, you and we will continue to have the following rights, without
waiving this arbitration provision as to any Claim: 1) Right to file bankruptcy in court; 2) Right to enforce the security interest in the
vehicle, whether by repossession or through a court of law; 3) Right to take legal action to enforce the arbitrator's decision; 4) Right to
request that a court of law review whether the arbitrator exceeded its authority; and (5) Right to seek remedies in small claims court for
disputes or claims within that court's jurisdiction.

'You or we may choose the American Arbitration Association, (www.adr.org), or any other organization subject to our approval, to
conduct the arbitration. The applicable rules (the "Rules") may be obtained from the selected organization. If there is a conflict between
the Rules and this contract, this contract shall govern. This contract is subject to the Federal Arbitration Act (9 U.S.C. § 1 et seq.). The
arbitration decision shall be in writing with a supporting opinion. Judgment upon the award rendered by the arbitrator may be entered in|
any court having jurisdiction. To the extent that the total of your filing, administration, service or case management fee and your
arbitrator or hearing fee exceeds $200, we will pay the amount in excess of $200, unless you choose to pay one-half of the total or
unless the fees are reallocated in the award under applicable law or the organization's rules.

Each party shall be responsible for its own attorney, expert and other fees, unless awarded by the arbitrator under applicable law. Any
portion of this arbitration provision that is unenforceable shall be severed, and the remaining provisions shall be enforced. If a waiver of|
class action rights is deemed or found to be unenforceable for any reason in a case in which class action allegations have been made,
ithe remainder of this arbitration provision shall be unenforceable. The validity and scope of the waiver of class action rights shall be
decided by the court and not by the arbitrator.

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Any change in this contract must be in writing and signed by you and the Creditor.

Buyer:
Signs
Ft Co-Buyer:
Signs
F N/A
YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO BE BOUND BY THE ARBITRATION PROVISION
IN THIS CONTRACT.

The Annual Percentage Rate may be negotiated with the Seller. The Seller may assign this contract and may
retain its right to receive a portion of the Finance Charge.

NOTICE
TO THE BUYER _
Do not sign this contract before you read it or if it contains any blank spaces. You are entitled to an exact
copy of the contract you sign.

Buyer (and Co-Buyer) acknowledge that (i) before electronically signing this contract, Buyer (and Co-Buyer)
received and reviewed a true and completely filled in paper copy of this contract and (ii) at the time of
electronically signing this contract, Buyer (and Co-Buyer) received a true and completely filled in paper copy of
this contract.

G ot
G N/A
Buyer Signs Co-Buyer Signs

Seller JC LEWIS FORD LLC sxH DD Title Finance Mgr
THIS CONTRACT IS NOT VALID UNTIL YOU AND SELLER SIGN IT.

ASSIGNMENT
Seller will assign this contract electronically to Ford Motor Credit Company LLC ("Assignee"). That Assignee will then have all
the Seller's rights, privileges, and remedies.

Seller JC LEWIS FORD LLC By | Da Title Finance Mgr

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Ford Motor Credit Company
PO BOX 681507
FRANKLIN, TN 37068-1507
Date: 07/17/2018
Acct Nbr: 056638397
Dealer: J C LEWIS FORD
9505 ABERCORN ST
SAVANNAH, GA 31406
Property: 2018 FORD FOCUS
Vin: 1FADP3J243L264973
Date of Contract: 07/16/2018

FRANCISCO MARTIN
746 WILLIAM H AVE BUILDING 714
FORT STEWART, GA 31315

Dear Customer:

We are pleased to service the financing on the property described above. On reviewing
the contract, we noticed and corrected the following error(s).

The name of the add-on provider or dollar amount was incorrect or left blank in
error. The correct disclosure of add-on charges of $1,295.00 should state TO: Ford
Extended Service Plan (ESP) FOR: Inside Maintenance Plan

The name of the add-on provider or dollar amount was incorrect or left blank in
error, The correct disclosure of add-on charges of $2,188.00 should state TO:
Automotive Warranty Services, In FOR: Outside Extended Service Contrac.

The name of the add-on provider or dollar amount was incorrect or left blank in
error. The correct disclosure of add-on charges of $1,295.00 should state TO:
Automotive Warranty Services, In FOR: Outside Bundled Product

No further action is required from you. Keep this notice as your record of the
change(s) made. If you have any questions do not hesitate to contact us at the
address above.

Sincerely,
Ford Motor Credit Company
Date of Repossession 10-07-2019
Date of Notice Date of Contract
*PRNN
Ford Motor Credit Company 10-09-2019 07-16-2018
P.O. Box 689007 Account Number: 056638397
FRANKLIN, TN 37068-9007 Buyer FRANCISCO MARTIN
(677) 224-1262 ‘Cobuyer
DESCRIPTION OF PROPERTY
Year Make
2018 FORD
Vehicle Identification Number:
PAVQ2F00200015 AFADP3J24JL264973
FRANCISCO MARTIN
Model Body
21521 NW 3RD PL
PEMBROKE PINES FL 33029 FOCUS 4DR

NOTICE OF OUR PLAN TO SELL PROPERTY
We have your property described above because you broke promises in our agreement.
[X] PRIVATE SALE: We wil sell the property described above at [[]PUBLIC SALE: We will sell the property described above at public
private sale sometime after 10 days from the Date of Notice sale to the highest bidder on the date below (or any adjournment
‘shown above. date). The sale will be held as follows:

Date of Sale | Time of Sale Place of Sale

You may attend the sale and bring bidders if you want.
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. To learn the exact amount you must pay, call us at the telephone number 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.

If you need more information about the sale call us at the telephone number above, or write us at the address above.

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 cobuyer named above; 2) Any dealer/original creditor named below;
3) If there are other people, they are named on an attachment sent with this notice.

2] The prope

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Complaint,Petition: Ford Motor Credit Company LLC Plaintiff vs. Francisco Martin Defendant

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