HomeMy WebLinkAbout01-2683 FX
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit, LLC,
CIVIL DIVISION
Plaintiff,
No. 0/-;}&J:3 C/()~L '-T~
v.
Complaint in Civil Action - Replevin
Eldon E. Miller,
Filed on behalf of:
GreenPoint Credit, LLC
Defendant.
Counsel of Record for this Party:
Erin P. Dyer, Esquire
PA ID Number: 52748
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
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IN THE COURT OF COMMON PLEAS OF CUMBEHLAND COUNTY, PENNSYLVANIA
GreenPoint Credit, LlC,
CIVIL DIVISION
Defendant.
)
)
)
)
)
)
)
)
)
No.
Plaintiff,
v.
Complaint in Replevin
Eldon E. Miller,
NOTICE
You have been sued in court. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this Complaint
and notice are served, by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against
you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further notice for any money
claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Curt Long, Prothonotary
Prothonotary of Cumberland County
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013 - 3387
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Defendant.
),
)
)
)
)
)
)
)
)
CIVIL DIVISION
No. OI-;2i.K3 ~ '/.uA-
GreenPoint Credit, LLC,
Plaintiff,
v.
Complaint in Replevin
Eldon E. Miller,
COMPLAINT
COUNT I - REPLEVIN
AND NOW, comes GreenPoint Credit, LLC, by and through its attorney Erin P. Dyer,
Esquire and avers the following in support of its Complaint in Replevin:
1. GreenPoint Credit, LLC, hereinafter referred to as "Plaintiff' or "Green Point, "
is a corporation duly authorized to conduct business in the Commonwealth of Pennsylvania
and has its principal place of business located at 400 Southpointe Boulevard, Southpointe
Plaza I, Suite 230, Canonsburg, PA 15317.
2. Eldon E. Miller, hereinafter referred to as "Defendant," is an individual whose
last known address is 8 Robin Drive, Newville, PA 17241.
3. On or about April 18, 2000, Defendant purchased a 1998 Champion Duchess
Manufactured Home, Serial Number 14014E, (the "Mobile Home"), from Financial
Resources Inc., (the "Seller"), and entered into a written Manufactured Home Retail
Installment Contract and Security Agreement, (the "Security Agreement") for the payment
of a portion of the purchase price thereof. A true and correct copy of the Security
Agreement is attached hereto as Exhibit "A"
4. Financial Resources Inc. assigned its interest in the Security Agreement to
Plaintiff, GreenPoint. GreenPoint perfected its security interest in said Mobile Home by
having an encumbrance placed on the title thereto. A true and correct copy of the
Certificate of Title is attached hereto as Exhibit "B."
5. Plaintiff avers that the approximate retail value of said Mobile Home is
$36,500.00 and that the said Mobile Home is in the Defendant's possession and believed
to be at Defendant's address as stated above.
6. Defendant defaulted under the terms of the Security Agreement by failing to
make payments when due. As of April 19, 2001, the Defendant's payments of interest and
principal were in arrears in the amount of $1,198.27. Pursuant to the Acceleration Clause
in the Security Agreement the amount outstanding as of April 19, 2001, is $34,938.19.
7. Plaintiff provided Defendant with thirty (30) days notice of intent to repossess
the Mobile Home. A true and correct copy of the notice of intent to repossess the Mobile
Home is attached hereto as Exhibit "C."
8. Defendantfailed to cure the default or return the Mobile Home upon Plaintiff's
demand.
9. Plaintiff avers that under the terms of the Security Agreement and
Pennsylvania law it is now entitled to immediate possession of said Mobile Home.
10. The Security Agreement provides that in the event of default:
a. Defendant will pay the reasonable attorney's fees of seller or of
seller's assignee, provided that prior to commencement of legal action such
fee shall not exceed $50.00;
b. Court costs and disbursements; and
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WHEREFORE, Plaintiff, GreenPoint Credit, LLC, requests:
a) judgment against Defendant in the amount of $34,938.19 with interest and late
charges plus detention damages, special damages consisting of inter alia, detaching and
transporting the Mobile Home, shipping fees, any cost for insurance placed on the Mobile
Home by Plaintiff, late charges, and all allowable damages per the Security Agreement,
any further costs for repossession and sale, and attorney's fees and costs of litigation in
order to obtain possession ofthe Mobile Home; and
b) In the event Plaintiff repossesses said Mobile Home and resells or otherwise
disposes of said Mobile Home, a deficiency judgment in an amount to be determined by
the Court upon petition of Plaintiff, which amount shall be equal to the difference between
the amount owed pursuant to the said Security Agreement plus the damages set forth in
paragraph (a) above and the amount recovered by Plaintiff from the resale or other
disposition of the said Mobile Home, less expenses.
E"~ ~
PA ID Number: 52748
Attorney for GreenPoint Credit, LLC
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
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VERIFICATION
Don Turosik, Collection Manager and duly authorized representative of GreenPoint
Credit, LLC, deposes and says subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities that the facts set forth in the foregoing Complaint are
true and correct to the best of his knowledge, information and belief.
CJ_~
Don Turosik
Collection Manager
GreenPoint Credit, LLC
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. PENN:>YlVANIA
NOTE. DISCLOSURE AND SECURITY AGREEMENT,
AND AGREEMENT TO ARBITRATE
(Agreement) .
MH FIXEO RATE OIRECT LOAN
aORROWER(S): NAME: ELDON E, M!LLER
NAME:
NAME:
BORROWERS. NAME:
ADORESS; Q u4e LINCOLN HIGHWlI.Y
STATE: ~ 21I'COOI:: 15522
LOCATION OF MANUFACi\JREO HOMI::
'." t.OANPLAN: FO:\. 04:\.300
OFFIC6NUMSER: 79 020
I.OAN SOU~E :&1
ACCT. NO. 0 01 ( "
.
TRACS NO.:
FUNDING COOE:
COUNTY: ctJMBERLAND
CITY: BEDFORD
PHONE: (814) 623.6209 5. sec. #(5): 196 -42 - 046 2
8 ROBIN DR, NEWVILLE, PA 17241
C'Real Property")
'I,' 'me,' 'myself' or 'us' meallS all persons who sign this Agreement as borrower or co-b'lrrower, jointly and severally, and
"you" or "your" means the Lender indicated below, On the date of this Agreement, I borrow from you the Unpaid Balance shOWn
below. The manufaclurad home described below, together witn furnishings, equipment, appliances and accessories affixed to
the manufactured home (called 'Manufactured Home") secures this loan as set forth in the Security Agreement contained
herein, .'
LENDER: GREENPOINT CREDIT, LtC
PROMISE. TO PAY: 1 promise to pay you at such address as you may direct the principal sum of:
THIRTY FOUR THOUSlI.ND TWENTY ONE J>..ND 50/100 DOLr..A.RS
(US $ 34,021. 50 ), (the 'Unpaid Balance') or so much as may be outstanding, with interest at the rate of
13.25 %
per year until the debt is paiel in full. The Unpaid Balance snall include anel I will P!\Y interest on any prepaielfinance charges you
agreed to advance me. I will pay this amount in monthly installments as shown nerain in the Payment Schedule until tne Unpaid
Balance plus all accrued interest is fully paid. Additionally, I promise to pay any other charges that I may owe under the
Agreement. If on 04/17/20 .1 still owe any amount under this Agreement, I will pay such amount in lull On that elate,
wnlch Is called the 'Maturity Date.' WhEln you calculate interest, every year shall have 360 days and every month shan have 30
days and each monthly payment will be applied as .ofthe scheduled due date.
ANNUAL PERCENTAGE RATE
The "".t -01 my cr.dlt as a yearly rat.,
FINANCE CHARGE:
The dollar emounl tho cradll will
ccstmll!l:
AmOUnt FInanced
The amount of cradit provld.d
to me or on my o"heif:
Total of Payments
The amount I will have paid after I
have mad.. all paymentsa. ,cheduled:
14,01% $ 64,599.30
$ 32,521.50 $ 97,120.80
.,._;t....'"::";c,,,, ,....;,:f1ri:.,.ChAT1l. +,'Arri6~nt Fin::' .
PAYMENT SCHECUL.6:
Numo.rot....l-."...--..'.';;;;.".'.-...:.':.:<........( ...,-:, .....-.. -co -" .-.--- ... ,.. .. .'.,i,,' C'" "':.:'"
. pavmehisE. :7Ai!j~0?I:gr;f!~.~!"!:. ...... .... '" '.':' _:: :-:{.: .....~;.;:Yih~ p~ym~n~~r~ :D~.:(esli~~tedt..: '.:, .'
240 S 404 .67 Monthly. beginning MA'{ '17 2000
s . 00 Monthly. beginning
$ . 00 Monthly. beginning
.00
". ~l%\;~~_
....~c.~f!4.~rl?.
.~;I::~~i:;
...'~ .~..._.. n. "'~
Prepayment: If I payoff .arty. I will not have to pay a penallY.
SI!CtH1ty: I give ycu a security interest In;
X the Manufactured Home and nOu5shQld gcod.s.
I.." Charga, It \he Unpaid Balan.. i. graaterlhan $25.000.00 an<! ~ tl\e paymentis more ll1an 15 days late, I will!>e charged alate Charge 015% at the
unpaid amount or 'uch paym.nt not to e.""ed $5.00.
Assum~tlon: someone buying my Manufaetured Home may not assume the remaindsr Of this Agreement on the Original tetm$ without your prior wrJrten
consent
Sa.unly Inrerellt Cha'1le.: Sacurity Inlerest Fe.. $
0.00
See the terms ot lhls Agraamenllor addi~onal information about nonpayment, dotaull, required repaymantln lull before the scheduled dale. and prepaym.nt
refunds and penal~es.
If you do not meet your obligations under this
Id Home and other household goods.
EXHIBIT "A"
.....
L~ 1M . PAO"'H
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'IS?A101H)19!jl
eV<.0'd
a~8~ >:<'8 en.
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,0< , - ~ ,,_...
Oeseril'tien cf
Manufactured
Home:
TRAOE.NAM!:.: CH.AM1?l:ON i-lOgE BtiI-LD~~?..
MODEL DUenESS
YEAR, 199 8 NEW: USED:
x
t.ENGiH, 6 0
It
WIDTH: 2 8
II.
SERIAL
NUM6ERS:
ffi"l"~"'"'~"-"" '~-"'''I t "',., ...............~.I
A i... ~~~~...'~'t.!.;l.:~~.-:~:.~. ::.;.;..~.:;:i=;:.;:';~"SE~lAf'~.NU. M8EA~..";'::~".,......
.._....... n J;;;,IWI __........_. _' . ,.'~_' Q 10.' .' _, H'~ __
~'.,',3,':.c..,,;:;,;,~',tr'EMfZk1il.Ci~,(;IEf3AMOUN:r"ElNANCED,~0':='f.,2"2':-~.','
1. .. Amount of oredit provided 10 me or on my behalf,
$ 32,494,00
b. Amount oredited to my account
$
2. Amounts paid \0 others on my behalt.o
a. .To Insurance Companie"
(1) Property Insurance...... $
(2) Credit Ute Insuranoe, ... $
b. To Public Officials:
(1)Certificale of TIlle......... S
~) F!LING FEE $
c. To:
For:
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PROPERTY INSURANCE: Property Insurance on the
Manufactured Home is reqUired for the term of this
Agreement. I have the right to choose the person
through whom it is Obtained. By marking my initials
next to a "Type of Insurance" listed below, I elect to
buy the insurance coverage indicated for the term and
premium shown, and I want you to finance it on this
Agreement.
Type of Insurance Term Premium
27. so
s
s
S
LIABILITY INSURANCE COVERAGE FOR BOD1LY
INJURY AND PROPERTY DAMAGE CAUSED TO
O"tHERS IS NOT INCLUDED UNLESS INDICATED
IN THE PROPERTY INSURANCE SECTION Al30VE.
. CREDIT LIFE INSURANCE: CREDIT LIFE
INSURANCE IS NOT REQUIRED FOR THIS
AGREEMENT OR A FACTOR IN ITS APPROVAL. IT
WILL NOT BE PROVIDED UNLESS \ SIGN BELOW
AND AGREE TO PAY THE ADDITIONAL COST, If I
elect Credit Uie 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 the entire Unpaid
Balance under this Agreement. The exact amount of
coverage is shown on my policy or certificat",. My
signature indicates my election to obtain Credit Life
Insurance coverage for the term and premium shown:
Physl~t Cama,ga Coveragl
$
d. To:
For:
, $
e. To:
For:
S
'L T~ FINANCIAL RESOURCES & ASST. OF THE
For: EROKER FEE
Type of Coverage
Term
Premium
_ Slngl",
$
_ Joint
$
III
3. Amounts paid to Lender: ......................... $
For:
(signature)
Date
4. Unpaid Balance (1 a and 10. pluS 2 and 3l... $
34,021. 50
(signature)
Dale
5, Prepaid Finance Charge ......................... $
1 - 0 00 (If joint coverage is desired, both proposed insuredS must sign.)
,~O .
6:' AmoU'ItFinanced (4minus'5) .................. $ 32,521.50
. I understand and agree that a portlon of certain of these
amounts may be retained by you, your affiliate, or the Seller of
thE> goods or services.
71/R(/\"", I,P.RC, >'I.R ?:1:iJ'
041300
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;T10NAL TERMS AND CONDITIONS
SECURITY INTEREST: I grant you a security Intere.t under the Uniform Commercial Code in (1) the Manufactured Home and in
all goods that are or may hereafter by operation of law become acoessions to it, (2) all appliances, machinery, equipment and
other goods furnished and affixed to the Manufactured Home including but not limited to the Items listed as . Additional
Accessories and Furnishings' on page 1 of this Agreement, (3) any refunds of unearned insurance premiums financea in this
Agreement, (4) any substitutions or replacements of the foregoing, and (5) all proceeds of such Manufactured Home and
accessions, and of any Additional Accessories and Furnishings. This security Interest secures payment and performance of ali
my obligations Under this Agre..m..nt, including any additional debt arising because of my failure to perform my obligations under
this Agreement and includes any contractual extensions, renewals or modifications. Notwlthsjanding any other proviSion of this
Agreement you are not granted and will not have a non-purchase money security interest in household gOOds to the extent such
a security interest would be prohibited by applicable law. To the extent permitted by appl1cable law, my execution 01 this
Agreement constitutes a waiver of my personal property and. homestead elCemption rights to the Manufactured Home herein
described. I also authorize you, at my expense, to sign and file, without my signature, sUch financing and continuaticn
statements, amendments, and supplements thereto, and any other documents which you may Ir9m time to time deem necessary
to perlect, preserve and protect your security interest in the Manufactured Home. I agree that you may file this security
instrument or a reproduction thereof in the real estate records or other appropriate index as a financing statement lor any of the
items specified above. Any reproduction of this security instrument or any other security agreement or financing statement and
any extensions, renewals, or amendments thereol shall be sufficient to perfect a secUrity interest with respect to such items. I
also agree to pay any filing or recording fees necessary for you to get and keep in force your security interest, and any' release
fees aller this Agreement is paid in lull.
PREPAYMENT: I MAY PREPAY THIS 1..0AN IN FULL OR IN PART AT ANY TIME WITHOUT PENALTY. If I make a partial
prepayment, there will be no change in the due dates or amounts of my monthly payments, unless you agree in writing to those
changes. Any prepaid finance charges are earned when paid. II I prepay this loan in full or default and you demand payment of
the entire balance due, no portion of any prepaid finance charge will be refunded.
PROPERTY INSURANCE:
a. Minimum Coverage. I am required to provide uninterrupted physical damage Insurance coverage protecting the
Manufactured Home for the term of this Agreement against less by fire, hazards included within the term 'extended
coverage" and any other hazards, Inoluding flood, for which you require insurance, in an amount equal (unless state law
requires otherwise) to the lesser of the actual cash value of the ManUfactured Home or the remaining unpaid balance I OWEl
from tIme to time under this Agreement (the 'Minimum Coverage"). The insurance policy will contain a loss payable clause
protecting you (as your interest may appear), and provide for a 1 a-day notice of cancellation to you. Unless you consent in
writing, I shall not add any additional loss payee to the insurance policy. I have the right to choose the person through whom
the property Insurance policy is obtained. If my insurance coverage expires or is canceled prior to payment in full of this
Agreement, I must obtain no leSS than the Minimum Coverage at my expense for the remaining term of this Agreement.
Shouid I fall to maintain the Minimum Coverage, you may, but are not obligated to, obtain uninterrupted insurance coverage.
To the extent permitted by applicable law, iagree that any insurance you purChase may be for the protection of only your
interest in the ManUfactured Home, may not fully protect me in the event of a loss. and may be for such reasonable period as
you determine. it you decide, in your sole discretion, to obtain Insurance, you will notify me of that lact and that the cost, pluS
interest at the rata provided for in this Agreement, will be added to my debt. I will repay- such amount in the manner as
required by applicable law, or if none is required in the manner requested by you, I understand that the insurance premiums
may be higher if you must purchase the insurance than might be the case ill had purchased the insurance, and to the extent
permitted by applioable law, that you may purchase the insurance frcm an affiliated company which may receive a profit for
this service.
,. Assignment and Application of Insurance Proceeds. i hereby grant and assign to you the proceeds of any and all
insl.lrance coverage on the Manufactured Home, Including any optional coverage, such as earthquake insurance, Which in
type or amount is beyond the Minimum Coverage. In the event of a loss to the Manufa'Ctured Home, I shall give prompt notice
to you and the insurance carrier. If I fail to promptly notify or make proof of los$ to the insurance carrier, you may do so on my
behalf. All physical damage insurance proceeds, Including proceeds from optional coverage, shall be applied to restoration or
repair of the Manufactured Home, unless you and I agree otherwise in writing or uniess in your sole discretion such
restoration or repair is not economically practical or ieasible, or your security interest would be lessened. It 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 Agreilment, whether or not th~n due, and give me any excess. I authorize any in.surer 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. .
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2t/60'd ~28S [~8 2t~
tg 11a~~~ INln~N~~~~
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c. 'Canc~)lation of Required lnsuL."ee Upon Prepayment in Full. if you have' pu\rchasec any insurance on my behalf, at n
6'j(:pens61 and (f \ prepay in fun the Unpaid Balance due under this Agraement, (1) you witt provide me with any notit
required by applicable Jawr (2) I have the right to cancel the insurance and receive a refund or credlt of unearned premiuM"
or to oontlnue the insurance; but unless I specifically request cancellation, the insurance will remain in effect until tt
scheduled expiration date,
LATe: CHARGE: If the Unpaid Balanca at !he time of execution of this Agreement is more than $25,000.00, then 1 agr<>e to p.
a late charge if you have not received the full amount of any monthly payment as set forth onl'age 1 of this Agreement. On
one late charge will be made on any delinquent installment regardless of the period for which:i8at'instaflment remains in defaul
After this Agreement matures, whether by acceleration or otherwise, I will not be charged a'late charge.
,
. .', r .I~""". .
RETURNE;O CHECK CHARGES: I Will pay you $15.00 (or such higher amount Ils.eJl!<wEjd ,bY, la",) if any check given to you i
not honored because of insufficient funds or because no such account exists. ....,~....,p"'<I".......;, .
~"':-""'l.')K~,.1ot1J!.ko'" ,.'.
EVENTS OF DEFAULT: I will be in default under this Agreemerlt if: (a) [fail t~~~~tit.a7fTffint when due; (b) I breal< an'
other promise I made to you in this Agreement, (0) I fail to make timeiy rental" payments: or to pay other charges an;
assessments, relating to the Real Property and/or faciHty on which the Manufactured Home is located; (d) I violate restrictiv.
covenants, rules or regulations relating to the Real Property and/or facility where the Manufactured Home is located; (e) I fail te
keep the Manufactured Home in good repair and condition, as you may reasonably determine; (f) I remove the Manufacture:
Home from the address shown on this Agreement unless I notify you in advance and reoeive your written consent; (g) I self 6
" attempt to sell the Manufactured Home or to transfer any beneficial interest therein withouHirstobtaining your wTinen consent
(h) I allow the Manufactured Home to become part of any real estate without first obtaining your written consent; (i) I encumbel
or abandon the Manufactured Hom~ or use it for hire or iiIegally; or m If any statement of fact, representation or warranty I mak$
to you in my loan application or in this Agreement is faise, misieading, inaccurate or incomplete.
NOTICE OF DEFAUI. T: If any of the above specified Events of Default have occurrad, you may do whatever is necessary to
correct my default. You will, except as set forth below, first give me a Netice of Default and Right te Cure Default before you
accelerate payment of the remaining unpaid balance I owe you or repossess or foreclose on any property which secures this
Agreement. The Netice will tell me what my default is and hew I can cure it. Except as otherwise required by applicable iaw. you
are not required to sefid me this Notice when (1) you have already sent a Notice three times within the preceding one-year
period, (2) I have abandoned or voiuntarily surrendered the Manufactured Home, or (3) other extreme circumstances exist which
could jeopardize your security interest
REMEDIES UPON DEFAUL. T: If I do net oure the default, you may do any or all of the foUowing at the end of the notice period,
as allowed by applicable law: (a) you oan require me to immediately pay yeu the entire remaining Unpaid Balance due under this
Agreement plus accrul'!d interest; (b) you may raquire that I reimburse you in such manfler as required by applicable law, or if
none is required in the manner requested by you with intl'!rest at the rate provided fer in this Agreement, thl'! amount of funds you
actually advanoe'on my behalf to correct my default; (c) you may, but are n.ot rl'!quired to, pay taxas, insurance premiums, fees,
expenses, charges, rents or assessments respecting the Manufactured Home, or satisty liens, on or to make repairs to the
Manufactured Home if I have not done so as required in this Agreement; (d) to the extent permitted by appiicable iaw, you may
cancel any insurance ior which all er a part of the premiums or charges was; financed by you, Obtain a refund of unearned
premiums or charges, and apply those amounts against the Unpaid Balance, or (e) you can repossess the Manufactured Home.
If you are not required to send ma the Notioe of Default and Right to Cure Default, yeu will have !hese rights immediately upon
.my default. If you repossess the ManUfactured Home, and I do not exercise any right to oure or redeem the Manufactured Home
that I may have, you may dispose of it as required byapplicabie iaw. You wiH give me written notice at least fiflel'!n (15) days
before any repossession sale, The notice shall be sent to the address shown as Borrower's Address section on the first page of
this Agreement or to any other address which] later give you in writing, Before the sale 1 still may get back the Manufactured
Home if I (1) pay you all installments due or past due at the time of delivery of the Manufactured Home back to me, (2) pay you
all unpaid delinquency or deferred charges, (3) pay you your costs of suit, including but not limited to attorneys' fees to which
you have a right under Agreement, (4) cure any other defaults which may have occurred, and (5) ff my default at the time of
repossession exceeded fjfteen (15) days, the expenses of retaking, repairing and storing the Manufactured Home allowed by
law, You will apply the proceeds at any repossession sale (1) first, to your expenses In selling the Manufactured Home, then (:2)
to your oosts of retaking, repairing and storing the Manufactured Home, then (3) to your reasonaDle and actual court costs and
any attorneys' fees to Which you have a right under the terms of this Agreament, then (4) to iate charges, and !hen (5) to the
balance stili due, If there is any surplus money from the repossession sale, it wi!! be refunded to me, If there is still a balance
due you, I .must pay it to you, except as otherwise provided bY law, It you repossess, you also may take possession of any other
property anywhere in or attached to the Manufactured Home. You agree to return all such property te me upon my request. You
may hold the property for me at my risk without liabiiity on your part. If you take possession of any such property, you wi1l notify
me in wr~ing. If I do not then promptly ciaim and take possession of this property, you have my permission to dispose of it in a
reasenab!e manner. 1 wi1l pey any reasonable charges which you may incur for storing or shipping such property. All remedies
are cumulative and you may enforce lh separately or too ether in anv nrri.., ,,,'" ", . M------ii~ii"' ,e0C;-iCC:-Cldl:l
!ol~':'A1n, IJHM Q ::::tTh " t9 I TCT=1H:I I,NT nrlN=1=lr-i:!
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ARBITRATION OF I)JSPUTES:
a, Arbitration. Yow. and I agree to arbitrate any and all (1) disputes, torts, oounterclaims, or any other matter in questi,
between you and / arising out of, jn c"nneotion wan, or in any way relatIng to thfs Agreement eClatms") (including whether
Ciaim must be arbitrated) and (2) any Claims arising.out of, in oonnection with, or relating to a transaction invoMng you anc
<lnd one or more third parties who have not signed this Agreement whioh a third party elects to arbitrate ("Third Par
Claims"). However, neithe:you or' oan require the other to arbitrate (1) any proceeding in whioh a lien holder may acquire
convey title to or possession of any property which is seourity under this Agreement, or (:2)' an application by Or on behalf
me for relief unde.r the federal bankruptcy laws or any other similar laws of gener1!-! ~PP'.!io'?:tion fOr the reUet of debtor
Enforcement of th,s exception to arbKralion at any time will not waive the right to arbitrate any" other Claim or Third Par
Claim, including those asserted as a oounterolaim in a lawsuit under this exoeption to. arbitration. .
....
b. Rules. The arbitration shall be (1) binding, and (2) governed by (V the Fede~.ai:A;bjtra~Qr\f..~!. CntJe. 9 of the United State
Code); (ii) the Expedited Procedures of the Commercial Arbitration Rules.'Il/:-'theFAmerioan Arbitration Assooiation (Ih
"Arbitration Rules") in effect at the :ime arbitration is re~uested,. and (Hi) this:-6~~~~.~.2,iit~'.\:;:::~rof thQ.Arbnralicn Rules, fre
of cha~ge, may be obtamed by callmg (800) 778,7879, The ar~ltrator shal! ~aV~~f.>oio/$'r.~,,P~o.\,,.I!f,,,d,,bY ll1e Arbitration Rule
and thiS Agreement and shall apply the law, inCluding but not limited to all statutes of Dmitation, which would otherwise appl
in a judicial action to a Claim or a Third Party Claim.
The award of the arbitrator(s) shall be in writing and include a statement of reasons for the award. If the terms of thi
Agreement and the Arbitration Rules confliot, the terms 01 this Agreement shall control the extent of the conflict. Th
arbitration shail be conducted In the federal judicial district where my resIdence is located, or at any oll1er plaoe mutual!
acceptable to you and J. The arbitration hearing shall begin wIthin forty-five (45) days ofll1e demand fer arbItration.
If I hava the right to rescind this Agreemant, rescinding it will not rescind Ihis agreement to arbitrate.
You and I agree that the arbitration prooeedings are confidential. The information disclosed in such proceedings cannot b,
used for any purpose in any other prooeeding. This Agreement is the only agreement between you and I regardin;
arbitration, and takes the plaoe of any prior agreements to arbitrate Claims. This Agreement may be modified only by ,
written agreement between you and I.
THE ARBITRATION WILL TAKE THe. PLACE OF ANY COURT PROCEEDING, INCLUDING A TRIAL WfTti A JUDGE
OR AJUDGEAND JURY. THE ARBITRATOR MAY AWARD DAMAGES OR OTHER RELIEF ONLY TO YOU OR I.
THERE SHALL BE NO CL.ASS CLAIMS OR RELIEF. ANY DAMAGES AWARDED BY THE ARBITRATOR SHALL 8E
LIMITED TO ACTUAL AND DIRECT DAMAGES. YOU AND I EXPRESSL.Y WAIVE ANY RIGHT TO CONSEQUeNTIAL,
PUNITIVE OR TREBLE: DAMAGES.
ATTORNEY FeES: If J prevail in any legal action or arbitration proceeding which is commenced in connection with the
enforcement of this Agreement or any instrument or agreement required under this Agreement, or in connection with any dispute
relating to this Agreement, you will pay my reasonable attorney fees, court costs, and necessary disbursements incurred In
connection With such aclion or proceeding, as determined by the court, or the arbitrator(s) in accordanoe with tM law. If you
prevail in any suoh actIon or prooeeding, or in the exercise of any self-help remedy as described above, J will pay an~
reasonable fees paid by you to an attorney who is not your salaried employee, together with court costs and necessary
disbursements to the full extent permitted by law.
OTHER TeRMS AND CONDITIONS: I agree: (a) to pay with my monthly installments, if requested by you to do so, the
esiimated amount necessary to pay yearly taxes, assessments and insurance premiums that will beoome due within the next
twelve.month period; (b) to pay you a transf"r fee ij I sell the Manufactured Home>, unless such fee is prohibited by law; (0)
except as oth"rwise prOVided by applicable law, to pay interest at the rate provided for in this Agreement on the remaining
unpaid balance plus accrued interest, from the oate of maturity until paid in full; (d) that ff I am married and residing in a
community property state, both my community property and separate property will be liable for all payments due under this
Agreement; and (e) if another person attempts to make payments on my behalf, yeu are not obligated to accept them. If you do
accept them, you are not releasing me or waiving any of your rights against me, and I authorize you to discuss with another
person who is making payments on my account any Information about this loan, Including its status and your collection
procedures and remedies.
ASSIGNMENT: You may assign this Agreement to any person or entity. All rights granted to you under this Agreement shall
apply to any assignee of this Agreement. .
HSPA10~'.Q1S9
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c:i'd li:jlOl . . _ _ ..._, ."..... ,.. '''y ~r"OIt nlstory and credit capaCity i. .mnection with opening and collecting
my account end share information about m'e and my account with credit reporting' agencIes. Unless prohibited by "'pplicabl.. la.....,
you may sell or otherwise furnish informaticn abOyt me, including Insurance information, to all otners Who may laWfully receive
such information, including spElcffio information about the Manufactured Home, and any insurance policies on the Manufactured
Home and the Real Property to any insurance agent to enable such agent to quote premiums to me and solicit my insurance
business.
WAIVeR, MODIFICATION, INTEGRATION: Your waiver of any default shall not oonstitute a waiver Of any other default. No
term of this Agreement shall be changed unless in writing and signed by one of your officers. This Agreement and other
doouments executed by me In connection with this Agreement, Is the entire agreement between us and I agree that nO oral or
implied representations have been made to Induce me to enter into this Agreement. By choosing or exercising one or more
remedies herein, you do not waive your right to Jater use or pursue one or more other remedies. except as limited by applicable
law. .
v ALIDfTY: Wherever possible each provision of this Agreement shall be Interpreted in such a manner as to be effective and
valId under applioabIs law,' but if any provision of this Agreement shall be prohibited by or invalid under applicable iaw, such
provision shall be ineffective only to the extent of such prohibition or invalidity, without invalidating the remainder of such
provision or the remaining provisions of this Agreement. This Agreement shall be of no effect until and unless signed by me and
accepted by you. In no event shall any oharge under this Agreement exceed the highest amount allowed by applicable law. If
any excess charge is received such excess shall be refunded or applied to t!'le Unpaid Balanoe.
GOVERNING LAW: Each provision of this Agreement shall be construed in accordanoe with and governed by the laws ot the
Commonwealth 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: You will send all notices concerning this Agreement or my ioan to me at the address listed on the first page of this
Agreement unless I notify you in writing otherwise.
YOU AND IIiAVE READ AND FULLY UNDERSTAND THIS AOFlEEMENT, INCLUDING THE PARAGRAPH CALLING FOR
RESOLVING DISPUTES BY ARBITRATION, AND AGREE THAT THIS AGREEMENT SETS FORTH OUR ENTIRE
AGREJ:MENT AND THAT NO OTHER PROMISES HAVE BEEN MADE.
BORROWER ACKNOWLEDGES RECEIPT OF A COMPLETED COpy OF THIS AGREEMENT AT THE
TIME OF SIGNING
Borrower ~;....... -e '7L(~
ELDON E. MILLER
Borrower
Borrower
Borrower
DATE OF THIS
AGR!'.EMENT:
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:Qo lisliJd :is. 'Jolr.J: T\:~ W1tn Rlgnt of SUl'l"'.'I:IlRlllP' (Oil ~l'l of ~
.~or, ~l!e i9~ ta ~uM?rla CYClit,l C'.,ro.CK HERE 1::. r;m~. l:-\4 tilfo
....ilI'~~ :':;"'~I\:.s.!., ~~'\O!'l<:la.a&.<l.f~.~ee,rn~;1._a
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EXHIBIT "B"
'tV'lVlr:-~?'-(irlti
. ,
400 SOllthpointe Eoulev:r.rd
$outllpoinre?l.az.a I, Suite 230
C:u'!.Qr\sburg,?A. 1531i
TeL. (71.4) 813-5825
fax (724) 873,582'6
Janu~(y 24, 2001
El..OON E. MtLL.ER
8 ROBIN DR
Ne~It.lE PA 172<1
GreenPoint ~ Credit
RE: ManUTa~tured Home Loan ~ Acccynt #000002030101600001
NOTlcr OF INTelfUOH TO AC;O:L.r:~TE. [DIJl4ENCE LEGAL ACTION' OR REPoSSESS
fOU ar~ new in defa~lt on your ManufQctureci Home L~an Contract. 11 yell eo~r~et the defaytt, you may
continue with the contract as though you did not default. Your default consists of faiLure to maK~ timely
payments oT one' or mere installments as agreed to in the terms of th~ contract.
Thitty~on~ (31) days after the date of this no~i~e, we may have t~e right to cornmenc~ legal "aCtlOn and
re~05se3s ycyr manUfsc~ured home.
Cure of def~ult: Your may eyre your defauLt by making payment in the ~mount indi~ated b~low:
Pas: Due Mc~thly Payment(~)
$
6D9.34
l.a:r!! Chan.l'e(!t)
$
5.00
iota l Oue /.IoU
$
814.34
creditor IS rights: Ahy partial payment of the amount due which is raeeived by u: ~iLl be applied to your
ac~ount. You wiLL n~ed to p~ the full ~m6unt by the o~te indicated above in orde~ to eUfe your default. If
yov do hot correct yowr default within 31 days due from the postmar~ed date OT thi$' notj~eJ we may
exerei$e our ri9ht~ qsainst yo~ under the Law by accelerating yo~r debt and ei~h~r reposses~ing yQur
rnar~ta~~urdd home or, it n~Ges5ary, b\lnging a cou~t actton to obtain possession ot your manufactur~d
heme.
It we etect to exercise OUr rights a~ainst yo~ by repossession ot the manufactured home you may, at any
time before We sell or otherwise aispo=~ of the manuracrurd home or ent~r into a ~ontract Tor its sale or
other d1SPQ~1t1on, (wh~~h bhall be a~ l~ast 45 d~YS af~er postmarK of th1s ~o~\~e), redeem the ma~factured
home by paying ws all amounts d~e plus expenses reascn~bly incurred by us in detach ins and transporting
the man~factured home to the site ot the s~le ana Our r~asonable attorney1s fee$, to the extent permitted by
la~r pluS court costs.
jf you have any que~tionar write to U~ at the address above or calt ~ at the phon~ number listed above
betwee~ the hours of .8:00 a.m. and 5:00 p.m., Monday through Friday.
if thT~ default was causQd ~ your fai\ure to make a payment or payments, and ycu want tQ pay by mail,
please send a checx or ~ney order. Do not ~end cash~
,/
/
M~nager
cc: File
If any additional r~guLar paymen~ b~comes ~we during this awre period,
order to avoid any fUrther d~fauLt. This correspondence is an attempt
information Obtained witt b~ us~ fOF that purpose~
-'-
this p~yment must al~o be paid in
to eollect a debt and any
PA 0<4)
EXHIBIT "C"
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02683 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GREENPOINT CREDIT LLC
VS
MILLER ELDON E
JASON VIROAL
, Sheriff or Deputy Sheriff of
Cumberland county,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - REPLEVIN
was served upon
MILLER ELDON E
the
DEFENDANT
, at 2020:00 HOURS, on the 9th day of May
2001
at 8 ROBIN DRIVE
NEWVILLE, PA 17241
by handing to
ELDON MILLER
a true and attested copy of COMPLAINT - REPLEVIN
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
8.68
.00
10.00
.00
36.68
So Answers:
.~~~~
R. Thomas Kline
05/10/2001
ERIN P. DYER
~ ~1 A.D.
r;. 'j~'pr~tJ:n~~~;y ~
Sworn and Subscribed to before By:
me this ). 3 MJ. day of
--'\1;11. ".," __ ".4U
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"'.
r-~
.
-,
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit, LLC,
CIVIL DIVISION
Defendant.
)
)
)
)
)
)
)
)
)
No. 01-2683 Civil Term
Plaintiff,
v.
Eldon E. Miller,
PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To the Prothonotary:
Please enter judgment by default in favor of Plaintiff GreenPoint Credit, LLC and
against Defendant Eldon E. Miller for his failure to plead to the Complaint in this action
within the required time. The Complaint contains a Notice to Defend within twenty days
from the date of service thereof. Defendant was served with the Complaint on May 9, 2001
and his answer was due to be filed on May 29, 2001.
Attached as Exhibit "A" is a copy of plaintiff's written Notice of Intention to File
Praecipe for Entry of Default Judgment which I certify was mailed by regular mail to the
Defendant at his last known address and to his attorney of record, if any, on June 6,2001,
which is at least 10 days prior to the filing of this Praecipe.
Please enter judgment for possession of the 1998 Champion Duchess
Manufactured Home, Serial Number 14014E, that being the relief demanded in the
Complaint.
~ .-'--~
Erin P. Dyer, Esquire
PA ID Number: 52748
Attorney for GreenPoint
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
Attachments:
Ten Day Notice
Affidavit of Non-Military Service & Last Known Address
L:\GreenPointlMiller, EldonlDJ Only.wpd
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit, LLC,
CIVIL DIVISION
Plaintiff,
)
)
)
)
)
-' )
)
)
)
No. 01-2683 Civil Term
v.
Eldon E. Miller,
Defendants.
Via Certified Mail #7000-1530-0000-8486-5160
and Certificate of Mailing
Eldon E. Miller
8 Robin Drive
Newville, PA17241
Date of Notice:
June 6, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALL YOR BY ATTORNEY AND FILE IN WRITING WiTH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS:-
YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANN()T AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWI~G OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
c ~ ~
-,.. --
~'~- --
. Erin P. Dyer, Esquire
Attorney for Plaintiff
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
L:\GreenPointlMiller, Eidon\TDN_wpd
FILE
{
.~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
GreenPoint Credit, LLC,
CIVIL DIVISION
Defendant.
)
)
)
)
)
)
)
)
)
No. 01-2683 Civil Term
Plaintiff,
v.
Eldon E. Miller,
AFFIDAVIT OF NON-MILITARY SERVICE & LAST KNOWN ADDRESS
ERIN P. DYER, Attorney, being duly sworn according to law, deposes and
says that he makes this affidavit on behalf of the within Plaintiff, being so authorized
avers that Defendant's place of residence is 8 Robin Drive, Newville, PA 17241, and
that he is not in the military service of the United States or its allies, or otherwise
subject to the provisions of the Soldiers and Sailors Civil Relief Act of Congress of
1904 and its amendments, 50 U.S.C. ~ 501, et seq. This statement is made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
c,-,,:,,, -=e,
Erin P. Dyer, Esquire
PA ID Number: 52748
Attorney for GreenPoint
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
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