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Home My WebLink About00-03024 ., . ""~ . I",. ,-~,o "i\/;:;._ ,.-'-,~ "iBr~ .-,_.;/,Ijl"'- """ ..AiI' '~~I'~' "." ," ",. -.--~" ., .JIlI:.JI!1. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREENPOINT CREDIT LLC, CIVIL DIVISION Plaintiff, No. 60 - ~O.:<y TYPE OF PLEADING: Complaint in Replevin Cu~L~~ v. CLARENCE S. LONG, III and RANDI A. LONG, CODE: 100 Defendants. FILED ON BEHALF OF PLAINTIFF: Greenpoint Credit LLC COUNSEL OF RECORD: Edward F. Voelker, Jr. PAI.D.#55414 Voelker & Associates, P.C. Firm #332 Suite 1410, Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219-1604 (412) 765-0543 ., . .., ,- f..l:i.:-1..~_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREENPOINT CREDIT LLC, CIVIL DMSION Plaintiff, No, v. CLARENCE S. LONG, III and RAND! A. LONG, Defendants. 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 WITIllN 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 DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH ON THE NEXT PAGE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 1 COURTHOUSE SQUARE CARLISLE, P A 17013-3387 ,.- -, ,,' ,"-'- ~" ,",. -'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREENPOINT CREDIT LLC, Plaintiff, CNIL DNISION No. ()1). 3D..l'l d;;...f --r~ v. CLARENCE S. LONG, III and RANDI A. LONG, Defendants. COMPLAINT IN REPLEVIN AND NOW, comes Greenpoint Credit LLC, by and through its attorneys, Edward F. Voelker, Jr., Esq. and Voelker & Associates, P.C., and avers the following in support of its Complaint in Replevin: 1. Clarence S. Long, III and Randi A. Long, hereinafterreferred to as "Defendants", are individuals whose last known address is 67 Country View Estate, Newville, Pennsylvania 17241. 2. Greenpoint Credit LLC hereinafter referred to as "Plaintiff', is a limited liability company and is duly authorized to conduct business in the Commonwealth of Pennsylvania and has its place of business at 400 South Point Blvd., South Point Plaza #1, Suite 230, Canonsburg, Pennsylvania, 15317. , . - "'~- , 3. On or about March 13, 1999, Defendants entered into a "Retail Instalhnent Contract and Security Agreement, Waiver of Trial by Jury and Agreement to Arbitration or Reference or Trial by Judge Alone", hereinafter referred to as the "Security Agreement," whereby Defendants purchased from Country Side Village Homes, Inc., hereinafter referred to as "Seller," a new 1999 Pine Grove Manufactured Homes, Inc. model #2020-99 (serial no. GP42735A1B) with certain furnishings, equipment, appliances, and accessories included at the time of purchase, hereinafter collectively referred to as the "Manufactured Home." A true and correct copy of the Security Agreement is marked as Exhibit "A" and is attached hereto and made a part hereof. 4. The Security Agreement was assigned for value to Greenpoint Credit Corp., on or about March 13, 1999, as permitted by the Security Agreement. 5. Greenpoint Credit LLC is the successor-in-interest to Greenpoint Credit Corp. by way of corporate restructuring and is now the secured party under the Security Agreement. 6. Pursuant to the Security Agreement, Defendant promised to pay Seller or Seller's assignee the financed amount of Seventy Thousand Four Hundred Nineteen Dollars and Fifty Cents ($70,419.50) plus interest. 7. As security for the loan, Defendant, by the Security Agreement, granted Seller and Seller's assignee a security interest in the Manufactured Home. 8. Greenpoint Credit Corp. perfected its security interest in the Manufactured Home by having an encumbrance placed on the title thereto. A true and correct copy of the Certificate ~~ ~ - )--- ,-,' '" ~n ,,': 1'1 ;! " '! of Title for a Vehicle is marked as Exhibit "B" and is attached hereto and made a part hereof. 9. Plaintiff avers that the approximate retail value of the Manufactured Home is Fifty-six Thousand Seven Hundred Twenty-two Dollars ($56,722.00) 10. Defendants has defaulted under the Security Agreement by failing to make payments when due. As of March 4, 2000 the delinquent payment amount due and owing from Defendants to Plaintiff is One Thousand Four Hundred Ninety-five Dollars and Fifty-three Cents ($1,495.53). 11. As of May 4, 2000, the amount owed by Defendants to Plaintiff, not including costs, attorneys' fees and damages for the unjust retention of the Manufactured Home, is Seventy-one Thousand Five Hundred Twenty-three Dollars and Seventy Cents ($71,523.70). The interest on said amount is accruing at the daily rate of Twenty-two Dollars and Thirty-eight Cents ($22.38). 12. Defendants have failed to surrender the Manufactured Home upon Plaintiffs demand. 13. On or about March 15,2000, Plaintiff provided Defendants with a Notice of Intention to Accelerate, Commence Legal Action or Repossess, a true and correct copy of the same is marked as Exhibit "c" and is attached hereto and made a part hereof. 14. Plaintiff is now entitled to immediate possession of the Manufactured Home. WHEREFORE, Plaintiff claims judgment for possession of the Manufactured Home or .') ,-I ., _ . --~ .__ 1. _ '''., . ~- c_ " the sum of Seventy-one Thousand Five Hundred Twenty-three Dollars and Seventy Cents ($71,523.70), with costs, attorneys fees, interest from March 15, 2000, and damages for the unjust retention of the Manufactured Home. Respectfully submitted, VOELKER & ASSOCIATES, P.C. Jhy{ Edward F. Voelker, Jr. Attorneys for Greenpoint Credit LLC Voelker & Associates, P.C. Suite 1410, Allegheny Building 429 Forbes Avenue Pittsburgh,PA 15219-1604 (412) 765-0543 ~-- ',-, --"I 'I :j i ,I :) ,I ;,1 VERIFICATION !, Donald F. Turosik, Operations/Collection Manager and duly authorized representative of Oreenpoint Credit LLC, do hereby depose and say subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities, that the facts set forth in the foregoing Complaint in Replevin are true and correct to the best of my information and belief. ~~ -J.3l::::J Donald F. Turosik Operations/Collection Manager Oreenpoint Credit LLC :\ -- ,=...~= '-,~= "''''-......uj,j_"''IJ,IIl'''''"'-''=~_ili_ ~ .- ~-. . ~.= , . .~- -~ l!ioIllo:l-LiMii',,_ MAY-04-2000 14:26 ENNSYLVANIA . . :ETAIL IN$TAUMENT CONTRACT, SECURITY AGREEMENT, ,. VAIVER OF TRIAL BY JURY AND AGREEMENT TO IRBITRATION OR REFERENCE OR TRIAL BY JUDGE ALONE :::ontract) UYER(S): GREENPOINT CREDIT 61 412 873 5827 P.10/17 NAME: CLARENCE NAME: RAND I A. NAME: JYER'S NAME>: JORESS, 820 YORK RD S. LONG III LONG FOR OFFICE USE ,ONLY I , COUNTY: CUMBERLAND CI'N:CARLISLE STATE; FA ZIP: 17013 PHONE: (717) 249 - 246 5 S. SEC. lI(S): 264 - 45 - 637 5 200 -64 - 9 587 'lOPOSEO LOCATION OF MANUFACTURED HOME: 67 COUNTRY VIEW ESTATES, NEWV!LLE, PA 17241 ." "me," 'myselr or 'my' mean all persons who sign this Contract as buyer or co-buyer, jointly and severally, and 'you" or 'our" mean the Seller and any assignee. This Contract will be submitted to the Creditor indicated below, at a local office and, if ~proved. it will be assigned to that Creditor. On the date of this Contract, I buy from you on a credit sale basis the manufactured ~me described on page 2, together with furnishings, equipment, appliances and accessories included in the manufactured ~me at the time of purcha$e (called 'Manufactured Home'). :REOITOR;GREENPOIN1' CREDIT CORP. ROMISE TO PAY: I promise to pay you at such address as you may direct the Unpaid Balance shown on page 2 of this ontraet (Item 5) with interest at the initial rate 01 9 . 50 % per year. The interest rate I will pay will change in accordance 'ith the provisions of this Contract. I will pay this amount in installments as shown in the payment schedule, or as recomputed ue to changes in the interest rate, until the Unpaid Balance is fully paid. II, ,on 03/12/29 ,I still owe any amount under lis Contract, I will pay such amount in full on that date, which is called tne 'Maturity Date." Each monthly payment will be pplied as of its scheduled due date. If no interest rate is disclosed above, the initial interest rate is the Annual Percentage Rate nown below. fTEREST RATE; My initial interest rate may not be based on the index used to make later adjustments. My interest rate may nange 11 months after my first payment is due and every 12 mOnths thereafter based on movements in the monthly verage yield on United States Treasury securities adjusted to a constant maturity 01 one year, as made available by the Federal ,eserve Board, which is the index rate. My interest rate cannot increase or decrease by more than 2. 00% at any interest Ita change or by more than 5. 00 % over the term of the Contract. The interest rate will equal the index rate in effect 45 days before the interest rate change date plus a margin 01 5. 50 % (rounded to the NEAREST 1/8 f one percentage point) unless the interest rate caps limit the amount of change in the interest rate. If this index rate is no Inger available, you may c:hoose a new index that is based upon comparable Information. ANNUAL FINANCE CHARGE Amount Financed Total of Payments Total Sale Price PERCENTAGE The .mounll will have peid The total cost of my RATE .fter I h'lve made .11 purchase on eredit The dallar amauntthe The amountof credit paymenl.$ a$ schedUled (Which is subject to The cost 0' my Cledit as credit will cost me (which provided to me oron (based on the currenl change) including my a y.arty ram (which ia is subject to change): my behall: Annual Percentage Rate down p'Smanl cf I subjectto change): which Is sUbjeClIo cheng.): $ ,000.00 I 10.16 % $ 156,089.62 $ 70,419.50 $ 226,509.12 $ 234,509.12 See !f7 raaoo 2\ Fin. Ch'~e + Amount Fin. Tatal Pav. + Down ~.vment See Conrract tgrms for additiQn:W information N~!Jino:r cf ~.;:;;~tOf When Payments Are OUe about nonpayment, default, reqlJired repayment Pa ents Pa ants In full befare the scheduled daIS, and ,., 12 $ 592.13 Monltlly, beginning APRIL 12 , '9-.2.9 prepaymem roluMs and penalties. My Prepayment: If I pay cff earty, I will nat payment 348 $ 630.47 Monthly, beginning APRIL 12 ~ 2000 heve 10 pay a penalty, bUll will nct be schedule $ .00 Monlhly. beginning . 19 I enlilled 10 a refund 01 the Prepaid will be: $ .00 Monthly, boglnning .'9_ - ml Finance Charge. It any, Security: I give you a se""rlly inleresl in ltIe goods or prop.rty being purch.sed. Late Charge: II a paymant is more lIlan.J1.. day.lale, I will be charged 2 % of the Unpaid amount of such payment notte ex~ed ~ )(, s 5,00 :x Vari..ble Rate: My Contract contains a vatiable rah:t feature. Disclosures abOl,Jtthe variable rate fe2UJre have been provided to me aarller. m Assumption: Sameane buying my ManufaCbJ",d Home may, under certain circumstances. b. allowed to assu",.lhe remainder of the Can tract on !he =i artginallemls. Esdmal1os: All numerical disclosures exoept the lal. p.yment disclosure. are .stimate.. he above disclosure. are based on terms in affect on the date this c;ontract h. signed. If the interest rate changes. actual Amount , Payments, Annual Percentage Rate, Finance Charge and Total of Payments will be more or less than disclosed above. .:IS0548.(l497 r"\T"lT.....Tlll.,.... ...._......... PAGe 1 OF7 MAY-04-2000 14:26 --I GREENPOINT CREDIT 61 " --- -"~. ~._c- ~" -.~.~-_. 4128735827 P.11/17 Desc:ription of TRADE NAME: PINE GROVE MH, INC. MODEL: 202 0.99 Manufactured Home: YEAR: 99 NEW: X 72 WIDTH: 2 8 USED: LENGTH: tt. It SERIAL Gto 4'2..7~S- I4ftJ NUMBERS: I ITEM II SERIAL NUMBER I I ITEM II SERIAL NUMBER I ADDmONAL AIR CONDITNG SKIRTING AcceSSORIES ANCHORS DECKS ANO FURNISHINGS: SHED 031099 ITEMIZATION OF AMOUNT FINANCED 1. Cash Price (Including Sales Tax of $ .00):. $ 78,000.00 2. a. Cash Down Payment........ $" "'8';'0'0 0 . 00 b. Trade-In (Year, Make, Model): Length Widlh Gross Value $ . 00 Uens $ .00 (SeUer to payoff) .00 8,000.00 70,000.00 INSURANce PROPERTY INSURANCE: Property Insurance on the Manufactured Home is required for the term of this Contracll have the right to choose the person through whom it is obtained. By marking the appropriate line below, I elect to buy the coverage indicated from you for the term and premium shown, and I want it financed on this Contract. NelTrade.ln Value........... $ Total Down Payment, ........ ,........,....". $ 3. Unpaid Balance of Cash Price (1 minus 2) $ 4. Amounts paid to others on my behalf:" a. To Insurance Companies; (1) Property Insurance. . . , .' $ (2) Credit Ute Insurance"., $ b. To Public Officials: (1) CertifiCate of ;,de.,. ... .;' (2) FILING FEEs c. To Creditor: For: d. To: For: Type of Insurance Premium 1 , , ,-j , 1 , " $ .00 Term 12MOS $ $ $ LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS IS NOT INCLUDED UNLESS INDICATED IN THE PROPERTY INSURANCE SECTION ABOVE. CREDIT l.IFE INSURANCE: Credit Life Insurance is not required for this Contract or a factor in its approval. If I elect Credit Life Insurance, the name(s) of the proposed insured(s) are: Proposed Insured Proposed Insured (Only spouse can be insured jointly.) This insurance may not payoff all of my debt, and the exact amount of coverage is shown on my policy or certificate, My signature indicateS my election to obtain Credit Life Insurance coverage for the term and premium shown: X Phploal O.m~. ecvtrag. BROAD FORM 392.00 J , i , 1 I i ,I ~ I ;1 1 I I " I I 392.00 .00 $ $ 22.50 5.00 $ .00 $ .00 e. To: For: f. To: For: $ .00 g. To: For. $ Type of Coverage Term Premium h. To: For: $ $ $ Total(a+b+c+d+e+l+g+h>.. ,.. $ _ Single 419.50 Joint S. UnpaidBalance(3plus4)",...........,..... $ 70,419.50 Date (.!JiBnature) 6. Prepaid FinanceCh"'ge ..,..".......,,,..,,,,,, $ . 00 7. AmounIFinanced(5minus61..".............. $ 70,419.50 -I understand and agree that a portion of cerlain of these amounts may be retained by you or your affiliatE>. Date (algnalure) (If joint eoverase is desired, both prQpoaad insureds must sign.) P~.Qo(.,... PAG~20F" ORIGINAL COpy " ~~~ I~, ~ . ~. , , '1(;'[ ;" I II 11 I I I I I I MAY-04-2000 14:26 GREENPOINT CREDIT 61 ADDITIONAL TERMS AND CONDITIONS 4128735827 P.12/17 ll.BLE RATE: lnthly Payment Changes. My monthly payment amount will change each time my interest rate is adjusted. The monthly yment amount will fUlly amortize the remaining unpaid balance at the adjusted interest rate in equal monthly payments er the remaining term of this Contract. ltice of Inte~st Rate and Monthly Payment Changes. You will send me notice of an adjustment in the interest rate and mthly payment alleast 25 days before the adjustment. This notice will contain information about the index rate, interest :e, payment amount and remaining unpaid balance. lRversion to FIXed Rate. I may choose to convert this Contract to a fixed rate Contract at any time beginning :ERO years from the date of this Contract and ending 30 years from the date of this Contract. In ier to convert to a fIXed rate, I must not be in default under the terms of this Contract, I must notify you in writing of my sire to convert to a fixed rate, I must exeoute a revision agreement and I must pay a nonrefundable conversion fee. The w fixed interest rate will be your standard fixed interest rate for a comparable Contract on the date that you receive my illen notification. The new fixed rate will take effect on the "Conversion Date,' which shall be my next payment due date ,t is at least :3 0 days after your timely receipt of a revision agreement signed by all Borrowers together with a nrefundable conversion fee of $ 200. 00 . The new fIXed rate and the Conversion Date are subject to ange if my revision agreement and fees are received after the date specified in the revision agreement. My new payment lount will be effective with the first payment following the Conversion Date. ' , IRITY INTEREST: I grant you a security interest under the Uniform Commercial Code in (1) the Manufactured Home and in ~ds that are or may hereafter by operation of law become accessicns to it, (2) all applianoes, machinery, equipment and goods furnished with the Manufactured Home (whether or not installed or affixed to it) including but not limited to the items as 'Additional Accessories and Furnishings' on page 1 of this Contract, (3) any refunds of unearned insurance premiums 'ed in this Contract, (4) MY substitutions or replacements of the foregoing. and (5) all proceeds of such Manufactured , and accessions, and of any Additional Accessories and Furnishings. This security interest secures payment and mance Of my obligations under this Contract. including any additional debt arising because of my failure to perform my .tions under this Contract and includes any contractual extensions, renewals or modifications. My execution of this Contract lutes a waiver of my personal properly and homestead exemption rights to the personal property herein described. I will md deliver to you whatever financing statements and other documents you deem necessary to allow you 10 perfect your ty interest in any personal property and fixtures. I agree that you may file this security instrument or a reproduction thereof , real estatEl records or other appropriate index as a financing statement for any of the items specified above. Any luction of this security instrument or any other security agreement or financing statement, and any extensions, renewals, or :Imenls thereof, Shall be sufficient to perfect a security interest with respect to such items. , , " " ,I i , i :1 1 I I I i 'AYMENT: I MAY PREPAY THIS CONTRACT IN FULL OR IN PART AT ANY TIME WITHOUT PENALTY, SUT I WILL 3E ENT1TLED TO A REFUND OF THE PREPAID FINANCE CHARGE, IF ANY, IF I MAKE A PARTIAL PREPAYMENT, E WILL BE NO CHANGE IN THE DUE DATES OR AMOUNTS OF MY MONTHLY PAYMENTS, UNLESS YOU AGREE lITING TO THOSE CHANGES. 'ERTY INSURANCE: nimum Coverage. I am required to provide physical damage insurance coverage protecting the Manufactured Home for , term of this Contract against loss by fire, hazards included within the term 'extended coverage' Md any other hazards, luding flood, for which you require insurance, in an amount equal to the leSser of the actual cash value of the ,nufactured Home or the remaining unpaid balance I owe from lime to lime on this Contract (the 'Minimum Coverage'). e insurance policy will contain a loss payable clause protecting you (as your interest may appear), and provide for a .day notice of cancellation to you. Unless you consent in writing, I shall not add any additional loss payee to the insurance icy. I have the right to choose the person through whom the property insurance policy is obtained. If my insurance (erage expires or is cancelled prior to payment in full of this Contract, I must obtain no less than the Minimum Coverage at expense for the remaining term of this Contract. Should I fail to maintain the Minimum Coverage, you may. but are not igated to, obtain insurance coverage. I agree that any insurance you purchase may be for the protection of only your >rest in the Manufactured Home, may not fully protect me in the event of a loss. and may be for such reasonable psriod as I determine. If you decide, in your sole discretion, to obtain insurance. you will notify me of that fact and that the cost, plus lrest at the Contract rate, will be added to my debt I will repay such amount during the term of the policy in the manner uested by you. I understand that the insurance premiums may be higher if you must purchase the insurance than might be case if I had purchased the insurance, and that you may purchase the insurance from an affiliated company which may eive a profit for this service. ~"7 PA.GE30~' -" "--~. -.,~_i.~ ",",~,d..ia~IIIlIII~I".~ ~.:. ..,.......... I , ,_~ h _J ~~ J~"" MAY-04-2000 14:27 GREENPOINT CREDIT 61 4128735827 P.13/17 . insura.nee coverage ~~ the Manuf..~,ured Home, including any o~o~al cover"\,d, ;uch a~ earthq~ake insurance: which in type or amount is beyond the Minimum Coverage. In the event of a loss to the Manufactured Home, I shall give prompt notice to you and the insurance carrier. If I fail to promptly notify or make proof of loss to the insurance carrier, you may do so on my behalf. All physical damage insurance proceeds, including proceeds from optional coverage, shail be applied to restoration or repair of the Manufactured Home, unless you and I agree otherwise in writing or unless such restoration or repair is not economically practical or feasible, or your security interest would be lessened. If such restoration or repair is not practical or feasible, or your security interest would be lessened, you shall apply the insurance proceeds to the remaining unpaid balance of this Contract, whether or not then due, and give me any excess. I authorize any insurer to pay you directly. I hereby appoint you as my limited attorney-In-fact to sign my name to any check, draft, or other document necessary to obtain such insurance payments. LATE CHARGE: I agree to pay a late charge for late payment as set forth on the front of this Contract Only one late charge will be made on any delinquent installment regardless of the period for which that installment remains in default. After this Contract matures, whether by acceleration or otherwise, I will not be charged a late charge. RETURNED CHECK CHARGES: I will pay you the actual charge of the dishonoring institution (or such higher amount as allowed by law) if any check given to you is not honored because of insufficient funds or because no such account exists. EVENTS OF DEFAULT: I will be in default under this Contract if: (a) I fail to make any payment when due; (b) I fail to time~y make rental payments, or to pay other charges and assessments, relating to the real property and/or facility on which the" Manufactured Home is located; (c) I violate restrictive covenants, rules or regulations relating to the real properly and/or facility where the Manufactured Home is located; (d) I fail to keep the Manufactured Home in gcod repair and condition, as you may reasonably determine; (e) I remove the Manufactured Home from the address shown on this Contract unless Inctify you in advance and receive your written consent; (I) I sell cr attempt to sell or to transfer any beneficial interest in the Manufactured Home without first obtaining your written consent; (g) I allow the Manufactured Home to become part of any real .estate withcut first obtaining your written consent; (h) I encumber or abandon the Manufactured Home or use it for hire or illegally; (i) I fail to promptly pay any taxes and other liens and encumbrances on the Manufactured HOlne or on the real property on which it is looated, if this is my responsibility; and/or (j) I fail to do anything else which I have promised to do under this Contract. NOTICE OF DEFAULT: If any of the above specified Events of Default have occurred, you may do whatever is necessary to correct my defaul!. Ycu will, except as set forth below, first give me a Notice of Default and Right to Cure Default before you accelerate payment of the remaining unpaid balance I owe you or repossess or fcreclose on any property which secures this Contract. The Notice will tell me what my default is and how I can cure it. Except as required by applicable law, you are not required to send me this Notice when (1) you have already sent a Notice twice within the preceding one-year peMod. (2) I have abandoned or voluntarily surrendered the Manufactured Home, or (3) other extreme circumstances exis!. CURE OF DEFAULT: I may cure a default at any time befcre title to the Manufactured Home is transferred from me, which will be at least 45 days after receipt of the Notice of Default and Right to Cure Defaul!. Tc cure a defaull, I must pay: (a) all amounts which would have been due in the absence of default and acceleration; (b) the attorney fees set forth below; (c) any late charges that are due; and (d) reascnable costs which are actually incurred for detaching and transporting the Manufactured Home to the site of sale. I must also perform any other obligation I would have had to perform in the absence of default. REMEDIES UPON DEFAULT: III do not cure the default, ycu may do either or both of the following at the end of the notice period, as allowed by applicable law: (a) you can require me to immediately pay you the entire remaining unpaid balance due under this Contract plus accrued interest or (b) you can repossess the Manufactured Home pursuant to the security interest I give you under this Contract. If you are not required to send me the Notice of Default and Right to Cure Default, you will have these rights Immediately upon my default. Once you get pcssession of the Manufactured Home you will sell it if the amount from the sale, after expenses, is less than what I owe you, I will pay you the difference except as otherwise provided by law. All remedies are cumulative and you may enforce them separately or together In any order you deem necessary to protect your security. ARBITRATION OF DISPUTES AND WAIVER OF JURY TRIAL: a. Dispm. Resolution. Any controversy or claim between or among you and me or our assignees arising out of or relating to this Contract or any agreements or instruments relating to or delivered in connection with this Contract, including any claim based on or arising from an alleged tort, shall, if requested by either you or me, be determined by arbitration, reference, or trial by a judge as provided below, A controversy involving only a single claimant, or claimants who are related or asserting claims arising from a single transaction, shall be determined by arbitration as described below. Any other controversy shall be determined by judicial reference of the controversy to a referee appointed by the court or, if the court where the controversy is venued lacks the power to appOint a referee. by trial by a jUdIJe without a jury, as describlld below. YOU AND I AGREE P,Q5084c30049'" F',4,GE4QF7 ORIGINAL COPY ,,:: ~~,~MUiI"'IOIl"_I""_~~ .~ .1 ~~ -~ ~'--~~~-' - ~~ U~' ~~ ~~ ~~'! '-i :j MAY-04-2000 14:27 GREENPOINT CREDIT 61 4128735827 P.14/17 _....... ................_._.._ .......... .._...... _....._ _. ..._ '''__'' ._ ...u._ _. ..., ._._ ..._.._ _....__ __ '._ .._... WHETHER THE COtITROVERSY vR CLAIM IS DECIDED BY ARBITRATlvN, BY JUDICIAL REFERENCE, OR BY 'TRIAL BY A JUDGE. I ! Arbitration. Since this Contract touches and concerns interstate commerce. an arbitration under this Contract shall be conducted in accordance with the United States Arbitration Act (T'rtle 9, United States Code), notwithstanding any choice of law provision in this Contract. The Commercial Rules of the American Arbitration Association ('AAA') also shall apply, The arbitrator(s) shall follow the law and shall give effect to statutes of limitation in determining any claim. Any controversy concerning whether an issue is arbitrable shall be determined by the arbitrator(s). The award of the arbitrator(s) shall be in writing and include a statement of reasons for the award. The award shall be final. Judgment upcln the award may be entered in any court having jurisdiction. and no challenge to entry of judgment upon the award shall be entertained except as provided by Section 10 of the United States Arbitration Act or upon a finding of manWest injustice. . Judicial Reference or Trial by a Judge. If requested by either you or me, any controversy or claim under subparagraph (a) that is not submitted to arbitration as provided in subparagraph (b) shall be determined by reference to a referee appointed by the court who, sitting alone and without jury, shall decide all questions of law and fact. You and I shall designate to the court a referee selected under the auspicel of the AAA in the same manner as arbitrators are selected in AAA-Iponsored proceedings. The referee shall be an active attorney or retired judge. If the court where the controversy is venued lacks the power to appoint a refllree, the controversy instead shall be decided by trial by a judge without a jury. , , Ii I I , I I II '1 I. Self-Help, Foreclosure, and Provisional Remedies. The previsions of this paragraph shall not limit any rights that you or I may have to exercise self-help remedies such as set-off or repossession, to foreclose by power of sale or judicially against or sell any collateral or security, or to obtain any provisional or ancillary remedies from a court of competent jurisdiction before, after or during the pendency of any arbitration under subparagraph (b) above, Neither the obtaining nor the exercise of any such remedy shall serve as a waiver of the right of either you or me to demand that the related or any other dispute or controversy be determined by arbitration as provided above. iTTORNEY FEES: If I prevail in any legal action or arbitration proceeding which is commenced in connection with the Inforcement of this Contract or any instrument or agreement required under this Contract, or in connection with any dispute elating to this Contract. you will pay my reasonable attomey feel, court costs and necessary disbursements incurred in :onnection with such action or proceeding, as determined by the court, the referee, or the arbitrator(s) in accordance with the lW, If you prevail in any $uch action or proceeding, or in the exercise of any self-help remedy as described above, I will pay any :ourt costs and necessary disbursements to the full extent permitted by law, together with reasonable fees imposed on you by tn attorney who is not your lalaried employee, provided that prior to commencement of legal action such fees may not exceed 150.00 and further provided that no .attorney fees may be charged prior to my receipt of the Notice of Default and Right to Cure lefault. )THER TERMS AND CONDITIONS: I agree: (a) to pay with my monthly installments, if requested by you to do so, the lstimated amount necessary to pay yearly taxes, assellments and insurance premiums that will become due within the lext twelve-month period; (b) to pay you a transfer fee if I sell the Manufactured Home, unless such fee is prohibited by law; (0) o pay interest at the Contract rate on the remaining unpaid balance plus accrued interest, from the date of maturity until paid in ull; (d) to reimburse you, immediately upon your demand, with interest at the Contract rate, the amount of funds you actually ~dvance on my behalf to correct my default; and (e) that if I am married, and reSiding in a community property state, both my :ommunity property and separate property will be liable for all payments due under this Contract. iSSIGNMENT: You may assign this Contract to any person or entity. All rights granted to you under this Contract Shall apply to tny assignee of this Contract. :AEOIT INFORMATION: You may investigate my credit history and credit capacity in connection with opening and collecting ny account and share information about me and my acoount with credit reporting agencies. You may sell or otherwise furnish ,formation about me, including inlurance information, to all others who may lawfully receive such information. You may furnish :pecific information about the Manufactured Home and any insurance policies on the Manufactured Home to any insurance Igent to enable such agent to quote premiums to me and lolicit my insuranoe bUliness. VAIVER: Waiver of any default shall not constitute a waiver of any other default. No term of this Contract shall be changed Inless in writing and signed by one of your officers. This Contract il the entire agreement between us and J agree that no oral or nplied representations have been made to induce me to enter into this Contract. 'ALIDITY: Wherever po:lsible each provision of this Contract shall be interpreted in such manner as to be effective and vaiid ,nder applicable law. but if any provision of this Contract shall be prohibited by or invalid under applicable law. such provision hall be ineffective only b:l the extent of such prohibition or invalidity, without invalidating the remainder of such provision or the A350846.oollS7 PAGE 5 OF 7 ORIGINAL COpy J '-~~WTlf"D_"~_~""","""" ~- ~'u ~-'-"- "~ -" MAY-04-2000 14:28 GREENPOINT CREDIT 61 4128735827 P.15/17 any charge under this Contract exceed the highest amount allowed by applicable law. If any excess cha;.ge is received, such .excess.shall be refunded or applied to the amount due. GOVERNING LAW: Each provision of this Contract shall be construed in accordance with and governed by the laws of the state of Pennsylvania, provided that to the extent you have greater rights or remedies under Federal law, such choice of state law shall not be deemed to deprive you of such greater rights and remedies under Federal law. . 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. YOU AND I HAVE READ AND FULLY UNDERSTAND THIS CONTRACT, INCLUDING THE PARAGRAPH CALLING FOR RESOLVING DISPUTES BY ARBITRATION, REFERENCE, OR TRIAL BY A JUDGE, AND NOT BY JURY TRIAL, AND AGREE THAT THIS CONTRACT SETS FORTH OUR ENTIRE AGREEMENT AND THAT NO OTHER PROMISES HAVE BEEN MADE. s 172570000 If you do not meet your Contract obligations, you may lose your moln\.lfactured home. Notice to Buyer: Do not sign this Contract in blank. You are entitled to an exact copy of the Contract you sign. Keep it to protect your legal rights. BUY~R(S) SIGNATUREi(S): ~ ENCE S. NG ? i: ~ ACCEPTED: The foregoing Conlrw;t i. herebyas.igned under the !enns Of the Assignment on page 7. COUNTRY SIDE VILLAGE HOMES, I SELL5F1: SELL5R'S ADDRESS: 31 WALNUT BOTTOM ROAD S5LLER'S SIGNATURE: S5LLER'S TITLE: DATE OF THIS CONTRACT: 0f ifff I AGREE TO ALL THE TERMS ON ALL PAGES OF THIS RETAil INSTALLMENT CONTRACT AND ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS CONTRACT. /~~ ij~' ~:fg;; P..~5084tii4tl':',. PAGESOF''' ORIGINAL COpy ~ ~ -~ - - - ~ ~. ~.!fr.'. MAY-04-2000 14:28 GREENPOINT CREDIT 61 ASSIGNMENT BY SELLER 4128735827 P.16/17 o CREDITOR INDICATED ON PAGE 1 ("Creditor') With respect to this retail installment contract ("Contract") signed by one or more buyers ("Buyer"). SELLER represents nd warrants that (1) Buyer's credit statement submitted herewith is completely accurate unless otherwise specified; (2) Buyer 'as legally competent to contract at the time of Buyer's execution of this Contract; (3) this Contract arose from the bona fide ale of the merchandise descnbcd in this Contract; (4) the down payment was made by Buyer in cash unless otherwise specified nd no part thereof WlIll loaned directly or indirectly by Seller to Buyer; (5) any trade-in, or other consideration, received as any art of the down payment is accurately described on page 2 and has been valUed at its bona fide value, and any amount owed n such trade-in or other property is accurately described on page 2 and has been paid off by Seller prior to or ontemporaneously with the assignment of this Contract to Creditor; (6) there is now owing on this Contract the amount set forth erein; (7) this Contract and any guaranty submitted in connection herewith is in all respects legally enforceable against each urportecl signatory thereof: (8) Seller has the right to assign this Contract and thereby to convey good title to it, (9) in the event f any claim or defense assertBd by any Buyer, or any heirs or assigns of Buyer, with respect to the Manufactured Home or ther property or consideration transferred pursuant to this retail installment contract. Seller agrees that it will indemnify and hold :reditor harmless from all such claims and defenses as well as from all costs reasonably incurred by Creditor in connection 1erewith, including but not limited to reasonable attorney fees and court costs; and (10) in accordance with the Fair Credit leporting Act. Seller has notified Buyer that this Contract is to be submitted to Creditor. For value received, Seller hereby assigns to Creditor all its rights, title and interest in this Contract and the property Ihich is the subject matter hereof and authorizes Creditor to do everything necessary to collect and discharge same. All the ,rms of any existing written agreements between Seller and Creditor governing the purchase of Contracts are made a part ereof by reference, it being understood that Creditor relies upon the above warranties and upon said agreements in purchasing 1is Contract n ~ ii Ii [! " [i " !i \3SOa4a-a497 PAGe 70F 7 ORIGINAL COpy -", -~~"_"","~lidM.Ilo.olI I............~~""""'" "~ <l";,,~j'- ~J._~....,,,,," ........ "liIl!iilIi""'"' '-'"I;.i~,! MAY-04-2000 GREENPOINT CREDIT 61 412 873 5827 P.03/17 ..a-.............. .-..._,.,.______.. ._ _ ._~..."_~'I ,,~;~'_ Of:-;rlTl':'EFoR ANEH[CLE"~~";''''''~ .;:r.~:,;". -..' _.. .. ." <'::'. !'1 " i;" H P I:j " Ii 11 Ii " Ii ~i :1 ....,... ..... ... ,',. ... ..... .._0.. ._~.. u__ ~R' ~~~~: :::~r~;~~'irr: ~~ fi ij '~ :'] ,... :' ., "1 , .... . .....' .", .... ..' :~i:~:::!:~0:i\*.W~~~Wlt} - m 0 ~ >< I-" ::1: W ijj (.Q ::j I-' W +=- W J; ~,." - "0 "" MAY-04-2000 14:24 GREENPOINT CREDIT 61 412 873 5827 P.04/17 r~ 400 SOmhlll)inte B~}ule\.n.rd S,]uthpnintl! PlilZ:l I. Suite .230 Can~lnsburg. PA 1531 i T.l. (724) 87J-5825 Fax (124) 87:l-.;82(; I" i;: ':1 March 15. 2000 ,;' ,'i I"~ CLARENCE S. LONG III RAND I A. LONG 67 COUNTRY VIEW EST NOWVILLE PA 17241 GreenPoint ~ Credit '<; :;1 ij RE: Monufoetured Kome Loon - Aeoount #000006130222700001 j,: " Fi NOTICE OF INTENTlCN TO ACCELERATE. ctII4ENCE LEGAL ACTllIIlII REPOSSESS You are now in default en YOUt Manufactur@d Home Lean Contract. If you CQrrect the default, you may continue with the contra~t as though you did not defautt_ Your default consists of faiture to make timely ~yments of one or mgr~ installments as agreed to in tne tetmS of tne contract. ,,~ I:] m ," Thirty-one (31) daY$ after the date of this notice, we ~Y have the right to commence legal Dction ~nd repg~5e~s your manufactured home. cure of defauLt: YOUI"' may CUre YOUI"' defautt by making paynl@n.t in tha amount indicated below: ;j I;j 'i , !~ i Paot Due Monthly Payment(s) $ 1,184.26 !: ',I I~' L.te Ch.rse(o) $ 13.26 Toul Due Now $ 1,197.52 Creditor's_r;ght$: Any partial payment of the amount due which is received by us wilt be applied to your account. Yau will need to pay the full amount by the date indicated above in order to cure your default. If you do not correct your defaUlt within 31 days ~ue from the postmarked dati of this notice, we ~y exercise our rights against Yay under the law by accelerating your debt and either repossessing your manufactured home or, if nece$sary. bringing a CQYrt iction to obtain possession of your manufactur~d home~ ~ I~\we elect to exercise our rights against you by r~s~~sion of the manufactured home you may. at ~ny ti~ before we sell or otherWise dispose of the manufacturd homa or enter into a contract for its sale or other disposition. (which shalL b! at least 45 days after postmark of this notice), redeem the manufactured home by paying us all amount~ due ptu~ ex~enses reasonably inc~rred by us in detaching and transpgrting the mdnufactured home to the site of the ~a(e ~nd our rca~cnable attorney's fees, to the e~t~nt permitted by law, plus court cests. If you h.ve any questions, W~ite to u~ at tne addres~ =bove or c3ll me at the phon~ number listed above betw..n the hours of 8,00 o.m. ond 5:00 p.m., Monday through FridOY. If this default W8S coused by your failure to make a payment or payments, and you want to pay by mail, ple~$e send a check or money ordor. Do not send casn. Manager cc: File If any additionP~ regu~ar payment becomes due during this cure perlod, thi~ payment must also be paid in order to avold any further dQfault. This correspondence i~ en attempt to collect a debt and any info~tion obtained wilt be used for th~t purpose. EXHIBIT I G B ~~iiIIiw~-;"i......~~ '=~~I~~iI.b!l~.h:;Hl,f!-~';;\~0lliI1io."'tl1!J~ oJ"":" ~, ~"':,, " ~"'--"'~";'~ '. .~'1Iii; ~i :t -'9. ...t: ~ ~ D ~ . "" 0 '1 ...0 ~ 0 0 ~ I I C!) ~ up:? -::e F 1- S - < - ~,".",~'''' ' o c- ~ "1:)~' fit D:J ~r ; --'I :v -<: (J'I <:::> a ::]: ;t~ -~ ~ .., ,:1: .,.. :n~ -ODl _:"~ C> --.;' ( .7:-r; '-)::r.i ,"'::!-r) 25m ;Z -< 8 .. --- t , SHERIFF'S RETURN - REGULAR CASE NO: 2000-03024 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREENPOINT CREDIT LLC VS LONG CLARENCE S III ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon LONG CLARENCE SIll the DEFENDANT , at 0019:36 HOURS, on the 25th day of May , 2000 at 67 COUNTRY VIEW ESTATES NEWVILLE, PA 17241 by handing to CLARENCE S. LONG a true and attested copy of COMPLAINT - REPLEVIN together with NOTI CE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 7.44 .00 10.00 .00 35.44 So Answers: r~~-<~~ R. Thomas Kline OS/26/2000 VOELKER & ASSOCIATES Sworn and Subscribed to before By: b<lWY\ ~. rLJQJ Deputy Sheriff me this ~~ day of ~~ AD Q }h--O~. ~ ~ < rothonotary - - - J. '" SHERIFF'S RETURN - REGULAR nJ1 .,,'), 7.~"" _ I' '.":;~~~r' CASE NO: 2000-03024 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREENPOINT CREDIT LLC VS LONG CLARENCE SIll ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon LONG RANDI A the DEFENDANT , at 0019:36 HOURS, on the 25th day of May at 67 COUNTRY VIEW ESTATES 2000 NEWVILLE, PA 17241 by handing to CLARENCE S. LONG a true and attested copy of COMPLAINT - REPLEVIN together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ~~"i~~~t R. Thomas Kline OS/26/2000 VOELKER & ASSOCIATES Sworn and Subscribed to before By: ~~{.~ Deputy Sheriff me this )....4 day of ~... I J.pvv A.D. ~Q, n.Jp,. ~ P othonotary , .' ~,' , ",..' , _~-h ',-," ' "' I," .,", C''''',",-:', "-;",,~~ "'~'C'",,,<' _-_'*'. -",,' '__~'_"':~-<':'< ' :'-!, , ! ~' '" ... IN THE COURT OF COMMON PLEAS OF ERIE COUNTY, PENNSYLVANIA GREENPOINT CREDIT LLC, CIVIL DIVISION Plaintiff, No. NO. 00-3024 v. TYPE OF PLEADING: PRAECIPE FOR WRIT OF POSSESSION CLARENCE S. LONG, III and RANDI A. LONG, FILED ON BEHALF OF PLAINTIFF: Defendants. Greenpoint Credit LLC COUNSEL OF RECORD: Edward F. Voelker, Jr. PA 1.0.#55414 Voelker & Associates, P.C. Firm #332 Suite 1410, Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219-1604 (412) 765-0543 ,- "-" "<. -,- -' " .---"-..-",~~-:.,,,-', :,-> '.'-"", '.'.-' - ,-"'- <,-,,- ~~'. -~, d-_ ;,' ~ '" IN THE COURT OF COMMON PLEAS OF ERIE COUNTY, PENNSYLVANIA GREENPOINT CREDIT LLC, CIVIL DIVISION Plaintiff, No. NO. 00-3024 v. CLARENCE S. LONG, III and RANDI A. LONG, Defendants. PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Please issue a Writ of Possession in the above captioned matter for the following: a 1998 Northbrook model Mansion Homes, Inc. mobile home (serial number GP42735A/B) located at 67 Country view Estates, Newville, Pennsylvania 17241. ~ /1} /0 ' ~6Jd.!L:: Suite 1410, Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219-1604 (412) 765-0543 Attorney for Plaintiff Date: iMlIfI"i" .' , ,;~~~" ......illllill ~ ~."....i:...~,~Illi~~..iiIIi ~ , ,_', "M,-""'-' "., ",- '_-~-_'o~'~C I' '" (') 0 I:J -6Q. c: "Tl 6"- tv s: '-- '---, "- ....... -no] "- "f (.J '6q 0- f' .frt ~ (!]rn Z:;'J;:' "'" ~ . :c~ i'-' t :-- .J:: z~:. l,~' & -t D U)..:':~ 0:> -',1. S ...J::: -<:...e:"'. -_-::'\~-) J.:: !:20 -u ,~;;~ :~l 0 1>C' ~, 'c.":.:(; , Z' orn ,="o W ~ )> - -l c: ~ b0 ~F! ~ ?O W -< ........ ...::) ... ........ , ... 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(Jl ~> l:L .0 . f-' ;..:en ~. . zo 0 to 0 ...."'l > By virtue of this writ, on the I caused Ihe wilhin named have possession of the premises described with the appurtenances, and day of , to z z o ~ o o I W o N .... () ... <: ... f-' ;;' ;;' ..., ..., 3 ? R. Thomas Kline, Sheriff, who being duly sworn according to law, states th1S wr1t 1S returned STAYED Per 1nstruct1ons trom Attorney Speece. Sheriff's Costs: Docket1ng Prothonotary Surcharge ~~~$ ~ subscribed to before me this ~Hj.OO 1. 00 30.00 1.l:lO 1.14 $57.94 .3/ ...r- Sworn day of Advance Costs: $100.00 Sher1tt's Costs: 5/.94 $ 42.06 _::;';) /;//.\. (0/;("\:- Retund to atty on IIL4/0~'~ ~ sqA~~,,:"'~4~ By Sh~rjft. q6dLt j ~ Deputy C1 /.a" Cl1. 336"33 ^ 11'f'1'f:J..., K.."., . "~".I>"'''''"'__._'"'' ._,_,~__.....- ,"~.. ......M '. .- '~"~~""""~ ,'." '~ - WRIT OF POSSESSION (Ejectment Proceedings PRep 3160 - 3165 etc.) Greenpoint credit LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. No. 00-3024 Civil Term Term vs. Costs Clarence S. Lohg, III and Randi A. Long 67 Country Vie~ Estates Newville, PA 17241 Att'y. Pl'ff (s) Prothy. $ 66.44 $ $ 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of OJrnber land County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: Greenpoint Credit LLC Plaintiff (s) being: (Premises as follows): 1998 Northbrook model Mansion Hanes, Inc. serial number GP42735A/B 67 Country view Estates Newville, PA 17241 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell hislher (or their) interesl therein. (SEAL) Curtis R. Long Prothonotary, Common Pleas Court ofCwnberland County, Pennsylvania ~ ~o/nP 2. ~j)~ I Deputy Date June 18, 2001 - . .< -, ~> = . .~ "-~ -" ,~