HomeMy WebLinkAbout01-03454
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit Corp.,
CIVIL DIVISION
Plaintiff,
No. 01 -.3'-1 r;J.j
Cu~(T~
v.
Complaint in Civil Action - Replevin
James T. Joy,
Filed on behalf of:
GreenPoint Credit Corp.
Defendant.
Counsel of Record for this Party:
Erin P. Dyer, Esquire
PA 10 Number: 52748
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit Corp., ) CIVIL DIVISION
)
Plaintiff, ) No.
)
v. ) Complaint in Replevin
)
James T. Joy, )
)
Defendant. )
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.
Richard J. Pierce, Court Administrator
Court Administrator of Cumberland County
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Defendant.
)
)
)
)
)
)
)
)
)
CIVIL DIVISION
No. OJ - 3 '1S'I CUru -r ~
GreenPoint Credit Corp.,
Plaintiff,
v.
Complaint in Replevin
James T. Joy,
COMPLAINT
COUNT I - REPLEVIN
AND NOW, comes GreenPoint Credit Corp., by and through its attorney Erin P.
Dyer, Esquire and avers the following in support of its Complaint in Replevin:
1. GreenPoint Credit Corp., hereinafter referred to as "Plaintiff' or"GreenPoint,"
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. James T. Joy, hereinafter referred to as "Defendant," is an individual whose
last known address is Lot 147, Shippensburg Mobile Estates, 500 Municipal Drive,
Shippensburg, PA 17257.
3. On oraboutAugust26, 1999, Defendant purchased a 1999 Fleetwood Stone
Creek Manufactured Home, Serial Number PAFLW22AB45200SK13 (the "Mobile Home"),
from Larry's Homes of PA (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."
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4. Seller assigned its interest in the Security Agreement to Plaintiff, GreenPoint
Credit Corp. 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
$56,000.00 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 May 16, 2001, the Defendant's payments of interest and
principal were in arrears in the amount of $1 ,657.29. Pursuant to the Acceleration Clause
in the Security Agreement the amount outstanding as of May 16, 2001, is $57,888.98.
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. Defendant failed to cure the default or return the Mobile Home upon Plaintiffs
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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c. Costs incurred by seller or of seller's assignee to foreclose on the
Mobile Home including the costs of storing, reconditioning and reselling the
Mobile Home.
11. In order to bring this action GreenPoint Credit Corp. was required to retain
an attorney and did so retain Attorney Erin P. Dyer.
WHEREFORE, Plaintiff, GreenPoint Credit Corp., requests:
a) judgment against Defendant to recover the Mobile Home, 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 of the 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.
COUNT II - DAMAGES
By way of separate and alternative pleading, Plaintiff, GreenPoint Credit Corp.,
alleges the following:
12. Paragraphs 1 through 11 of this Complaint are incorporated herein by
reference as though fully set forth.
13. This Count is brought in the alternative to the relief sought in Count I.
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WHEREFORE, Plaintiff, GreenPoint Credit Corp., requests:
a) judgment against Defendant in the amount of $57,888.98 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 of the 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.
~~
Erin . yer, Esquire
PA ID Number: 52748
Attorney for GreenPoint Credit Corp.
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
-
L:\GreenPointlJoy, James nCM.wpd
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VERIFICATION
Don Turosik, Collection Manager and duly authorized representative of GreenPoint
Credit, LLC, deposes and says subjectto 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.
C0",-~
Don Turosik
Collection Manager
GreenPoint Credit, LLC
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SUYEl'I(S):
NAME:
NAME:
NAME;
NAM<:
TIMBER
J'AME:S T. JOY
STEP PAYMENT CONTRACT
.. !i!:;:;:~. 1..0AN PLAN, Fe 1. G 8259 9
~1"';J"
.." "" OFfICE NUMBER: 7 9. 06 1
m~DEALEANO., 610023
"I' I \~.....~'-."\':>
7j, ACel'. NO.:.J 1\-1.
" FUNDING CODe:
PENNSYLVANIA
RETAIL INSTALLMENT CONTRACT, SECURITY AGREEMENT,
WAIVER OF TRIAL BY JURY AND AGREEMENT TO
ARBITRATION OR REFERENCE OR 'TRIAL BY JUDGE ALONE
Ff.OrcS!.O ~OCA110N OF MANUfACTURED HOMe:
500
Cll'Y:
PKONE: 53 0" 0793
!':-~'NICI?AL DRIVE
COUNlY CTJMBERL,,"-'lJD
S:-:IP?ENS3URG S1A1E, ?r. ZIP, 17257
S" SEC. _is}:218 . 7 0 ' 6 010
SHIPPENSBURG, FA 17257
SuYER'S
;.noRESs"13 0
!.i\..~E
':." limB." "rnyself" or "ml' mien GH person$ who :;ign thi~ ~Ormac'.: as buysr or co-buysr. jointly lmd uvertJly. an'; l'yOUII or l'yoL.lr" mean thA
s.ellet ~l!,d any essiQM8fL This contrac.t will ba submitted tD tl1e Creditor indiested below. at $ )o~61 offl<:e and. if .ap~rovad. it will be a'8Sigl"ltel to
-:het Cr,ditQr. an tns date of trli$ C::.:::lntract I buy from yOl,J Or'l a credit ule buia tMe mtnl.lf8cture~ hQme deKribed below. to~eth.r WIth
~lJrnl$hjng$. equipmsnt, Bp~:Ij.al"le&$ and Bccsascrias includeld i~ t'ha manufactured home at th. time of purchase (C:4J1ec:l "M4nuf",cturad Home").
CRSOITOR: GREENl?O!NT CREDIT CORP"
O~~t:ription of
M.e.nf.,lfedu.red
Home:
ADDITIONAl.
ACCesSORIES
ANO FUMIISHINGS:
'TMOE NAMe:FLEETWOOD MODELoGOLD KEY
YEAA, 1999 NE'N X USEe, LENG1H: 56 "" WIO'TH,28
~tAr:te1RS n"U122.~.45200SK1~-pf)~E> -1.5.2-00tSHJ3
1"",..Ii;~:i'::~J:;1 tie.M h;;:;:.:,;;',,:;,:1 li;;;~I:;'.;;;"'-d;I;'i SERlAL. NUMBER i;:~~':;~~;;;:~,,,~ ll~;:~~i:~d~i;;1 rr~J:ii;i;;i:':;:~:.i I:.; ,:...:,. :":'::I;'l SeAIAL NUMBER j~'
AIR COND~TNG I _KIRTLN~
~~CHORS . - VAPOR 3ARRI~
FOOTERS
ft"
FRO MISE TO PA.Y; J nprcmi.s;4 to pay you the Unpoid EaJ.at\~d1 shown on ~aQt!I .2 of thi$ contraet {Item 51 With jr,teru: .ot the t8te of:
13 , 25 % per
'..=sr until the debt is fully paid, I'll ,OBY this amount in lnstllllmsnts. as shown in the ~.I=luymfmt $~h!ll:lule, e~ch mcnthly pl.lymsflt Will be s~~ljec{ as
:.f i'!:$ :scheduled due ,date. MyJirst waIve monthly payments. may not be $wfficisnt to covar thl1 interut dwe fot thos.e months. Any differefl~e
;etween the inter.st due and the payment amount will ba ;!lddsd tc. the Unpaid 8sJenc::a. If no intflr'sst rete i~ disclo$ed Bbova. the ir;~ere.s.t rata is
~hi; Annl.:al Plrc8n~.aQa Aate Sht::lWM below.
ANNUAL
PERCENTAGE
RATE
FINANCE CHARGE
Amount finaneed
Total of Payments
Total Sale Price
1"1'\'1 cast af rtlV e.~d.jt &:l
,3 y<!.:uiy rate;
The dollAr ~n'lOlJnt the
cll"8d It ""';11 cos1 me:
Tha ZlmQ~nt of er6dit
prcvidad to mE! or Ol"l
my bohalf.
'i"h4 ilmount I ""';-11 ha~
paid aft.r I haw ma.da all
payment.! :l;$ .:.c::hed ulad:
The tou.l CQ$.t of my
pUN:nase on <::l"Qdit
including my da......-n
I=l_ymam Qf
Sa8 eClntf;lQ( terms t'cr sddjtionbl Jt'l1QI"rr'".a1ion
iI~"1Jt nonpayM8N. d.fa~lt. required
I'e!,ayrnent in 11.111 before the ;!e~dl,jlCld
~.!Ite. Md prepayment refund.s end
:;.aNil1i~.
$ 2,730.09
$ 51,8~~.61 $223,073.64 $225,803.73
i!j~i:~:~~:,!~~t:::t';.;';r:iQ:~Vi;flm;i~~~jiJ~J~Fl~ij~: . '''j;'''1ii~~Gr.ii:~tr.i~~n~: i:j:~;4j"..:~"ti:iii'6;owr.:~:a'''~nE~
13 ,,25 'l\
$171,229.03
Prep"';'m4n1: If I PllY off early, I will not
/'=..q 19 pay A l3ef"lI;Jlt'y. bl"lt I V'ill not 'be l~~!:lrt~ii!~!"""'"
entitled to a rerul'\d of the Prcp~id Finanae ~~ )tt~1:::t:i:'~:
Ch.argci. if any. ......'."r"..~,lt~..H..
Se~lolnty: I ,i\o1l VClu a j8CUriry inUlrolt In the good.3 or PI'O~tlrtv b~lna purr:hA$O~.
L..n8 Charge: If a pa;n'lt!ll'\t i., /"nQre than 15 daY' latll, I v\lill ba cNrgod
S 5.00 -
~~~~~J[nTIr~7~~::'~'~ii;;r;
! s ' 0 a Monthly. 'bofiinning , 19 __
2
'" Qf the un~id :lI'nOt.lnt of 4uch payml!lf"lt, net to eJl::IilClO
.:.a.sumr;rdcn: Som8CIflS huyi/'IQ mV Mamdactured HoNllll m,gy; undQr e.ill'"Ulin Qircumstal'l~a, bQ aHov.ed 1Q a.uur"l'lG the rem.::.indar of tha c:cn.tract Ot'l t/'lQ
Qriglnal terms.
~AOO!e...Q'i'M
PAC! 'o,a
EXHIBIT "A"
Security Agreement
C't/L0"d
LC'8>; >'I.R ?1t:>
'1
'''~' .,~;,' .'~ _ ~"k.'~ '" , -",,;"';'J~~"^'-"'~' "<'",
R1:n 1\O\O?-1.1-AHW
.'.'~, 'n'~'~'"--
'''''".cC;'''',=,~.e,'''"'~,",''''_ ._c.'-y.~.,_, F7 -",',,", ,-:"'7.<h .;>0""",-;-"'" . ,-.- .". ~'1'P-,l'-'i.'J,.~,;-,;<:l"~'-'-' ,<,," ,~,-
, .r.
:..".".",,:,...t'":"'~f.~_mN1:0!;l:;WMaam;:""._Eii!:m][Ji,,:'!,~;,m';,,'.t,,:~1 !im~~'i,!i,;;,m"i';::",i:t.id:::. .,.;:aNS!:lRANCE"':,.;',::,:i',.:.
1""~;~~- p;i.. (In.1. S.I~s Tax of $ . 0 "," ): $ 51, 5 ~ 0 . CO I 1 F'FlOPERTY INSURANCE: Property Insuran.e on the
Z, ". CsehoQwnp.ytnerl't........$ 2:, j30. 09 M.tn.utdotured Home fa required for the term o~ this
b" Tr.da~n NO." Mako. Modal): ccntract. I have the right to choose the person through
\' whom It Is obtained. <ly marking the appropriate line
Langth Width below. I elect to buy the <>overage indicated from you
(;ro.. Volua $ . 00 Lion. $ . 0 c tor the term and premium shown. and I want It financed
(SlIlllIf to r;.aYQfT) on thiS contract.
Nat Trade"ln Valu~."" $ . 00
Tot.1 Dewnpey",an'"""""""". $
, 3. Unpaid SaIAt1Ca of C~.h P;ic~' (', ~inua~) . $
; A. AMounts paic! t~ others on my bshaJf: .
I a. To Insurar\C6 Companilis~
(1) PropotlY Insuroneo".: $ -".. - 474, . 00
(2) Cradlt Lifs Insuranea" $ 2,015 .70
b, To PI,I!::Ilic: Official.s;
(1) Carlifi.ata of Title" "$
(2) FILING FEES $
c. To Cfaditor~
FQf~
.. :2 , 730 . 09
48,8C9.91
ry~. of Inauranea
Term
Pre mium
n. To:
!'or: S:::RVJ.CE CONTRJ\.CT
$ 495.00
ope FLOOD FEE $27.00
T()tal (1;1 "" b .c"" d + i'" f ~ g+ h) $
_ Unp.i. a.l.n..(3 plu. 4) $
c. Prapaid Finat1c& Charge $
i. Amount Firlllncecj (6 minus 5J $
3,CEl./C
:; 1, 871 . c i ,
2.i . CC
51,84...61
X Physical Oarrt~. C:lwrage 12 MO $
I BROAD FORM 0 MO $
$
I LIABILITY INSURANCE COVERAGE FOR BOOIL Y
INJURY AND PROPERTY DAMAGE CAUSED TO
i OTHERS IS NOT INCLUDED UNLESS INDICATED IN
I THE PROPERTY INSURANCE SECllON ABOVE,
'I CREDIT LIFE INSURANCE: Credit Life Insurance is
I not required for this contract or a faator in its approval.
Ilf I elect Credit Life Insuran.e, the name(s) of the
I proposed insIJred(S) are:
II Proposed Insured .
i Proposed Insured
I (Only spcuse oan be insured jointly")
I This insuranoe may nct pay oft all of my debt, and the
i exact amcunt of coverage is shown on my policy or
I certificate. My signature mdicates my election to olitaln
I Credit Life lnsurance coverage for the term and
premium shown:
I Type of Covsraa. Term (:lremium
I
i X singla 60MOS $ :2, C 15 .70
I Joint $
, i
II Date <8 ()0 -~(
. I
1 oto I
i (di~nat!"jra) I
I (If joint coverage i& desirad, both proposed in.ured. must .ign.) I
I I
474.00
.00
22.50
5.00
$
.00
d.10:
I'or: NOTARY FEES
$ 22.50
e. To:
For;
$
.00
I. IO~
For;
s
_ 00
C. 10:
For:
$
. I understand and agree that a portion of certain of these amounts
may be ratalnlld by you or your affillat8"
:02599
ADDITIONAL iEflMS AND CONDITIONS
SECURliY INTEREST: I grant you a security interest UJider the Uniform Commercjal Code in (1) the Manufactured Home> and in
all goods that are or may hereafter by operation o/Iaw become aceesslons to It, (2) all appliances, maohinery, equipment and
other goods furnished with the Manufactured Home (whether or not installed or affixed to it) including but not limited to the items
listed as 'Adllitional Accessorias and Furnishings" bn page 1 ot this contrael, (2) any refunds of unearned insurance premiums
financed in this contract, and (4) all proceeds of such Manufactured Hamil and accessions, and ot any Additional Accessories
and Furnishings. This security interest secures payment and performance ot my obligations under this contract, including" any
acdltlonal debt arising because ot my tallure to pertorm my obligations under this oontract and Induces any contractual
extensions, renewals or modifications. My execution of this contract const~utes a waiver at my personal property and
homestead exemption rights to the property heraln desoribed" I will sign and deliver to you whatavar financing statements and
other documents you deem necessary to allow ycu to pertee! your security interest in any pe~onal property and fixtures"
PREPAYMENT: I MAY PREPAY THIS CONTRACT IN FULL OR IN PART AT ANY TIME WITHOUT PENAL iY, BUT I WILL
NOT SE ENTIi\.EO TO A REFUND OFlrIE PREPAID FINANCE CHARGE, IF ANY.
H.3:~...CC36.(1ega
PAG~ ~CFa
G1/80'd ~G8S ~~8 G1p
; J~~~_ < " - '-' - ,'c- _,__' '"_~'-<''''';>?',','',:,-,\;''-'.''' ~ ,-'~""-,,_"r_,--. _ ,., '~'''''.-'''''''''
,g l1Q3~~ lNI0dN33~~
'._ . _~_ ,-',r.,_,>_ ,,_,,"< - ,--:' 0':__' _~ ~_=~, ~
5,:~, ,00G-~'-^~W
.- ~ ~
PROPERTY INSURANCE,
a. Minimum CcvONlge. I am required to provide physical damage insurance coverage protecting the Manufaelure<l Home for
the term of this ""ntract against loss by fire. hB2ards Inoluded w~hlnthe te"" "extended ooverage" and any other hazards,
including flood, for which you require Insurance, in an amount equal to the lesser of the actual cash value of the
Manufactured Home or the remaining unpaid balance I owe from time to time under thiS contract (the "Minimum Coverage")"
The insurance policy will contain a loss payable clause protecting you (as your interest may appear), and provide for a 10 day
notice of cancellation to you. Unless you C<lf\$enl in writing, I shall not add any additional loss payee to tM insurance policy. \
have the right to choose the person through whom ths property insurance policy is obtained. 11 my Insurance coverag..
expires or is cancel1eCl pnor to payment 1n full of this contract, I must obtain no less than the Minimum Coverage at my
expense for the remaining term of this contract Should I fail to maintain the Minimum Coverage. you may, but are not
obligated 10, obtain insurance coverage. I agreE! that any insurance you purohase may be for the protection of oniy your
interest in the Manu/actured Home, may not fully protect me in the event of a loss, and may be for such reasonable period as
you determino:t If you decide-;- in your sole discretion, to obtain insurance, you will notify me of lhat fact and that the cost, plus
interest at the oontract rate, will be added to my debt. I will repay such amount durtng the term of the polioy 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 if I had purche,sed the insurance, and that you may purchase the Insurance from an affiliated company which may
receive a profit for this servioe" "
b. Assignment and Applleatiol1 of lnaurance Proceeds. I hereby grant and assign to you 1he proceeds of any and all
Insurance coverage on thO Manufactured Home. inCluding any optional coverage, such as earthquake insuranc... 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 ~nier. If I fall to promptly notify or make proof of loss to the inSurance carn.er, you maydo So on my
bshalf, All physical damage insurance proceeds, including proceeds frem optional coverage, Shall be appliad to restoraticn or
repair of the Manufactured Home, unless you and I agree cthe!Wlse in writing or Ilflless such restoration or repair is not
economically practical or feasible, or your security Interest would be lessened, If suoh restoration or repair is not practical or
feasible, or your security Interest would be lessoned, you shall apply the Insurance proceeds to the remaining unpaid balance
of this contract, whether or not then due, and give me any excess.
LATE CHARGE: I agree to pay a late charge for late ps.yment as set forth on the front of this contract. Only one late eharge will
be made on any delinquent installment regardless ct the period for which that installment remains in default Atter this contract
ml!.wres, whl>ther by acceleration or otherwise, I will hOt be charged a late charge.
EVENTS OF DEFAULT: I will be In default under this contract IT: (a) I fall to make any payment when due; (b) I fail to timely
m~ke rentai payments, or to pay other charges and assessments, relating to the real property and/or facility on which the
Manufactured Home is located: (0) I violate restrictive covenants, rulas or regulations relating to the real property and/or facility
where the ManufactUred Home Is located; (d) I fail to keep the Manufactured Home In good repair and condrtion, as you may
reasonably determine; (e) I remove the Manufactured Home from the address shown on this contract unless I notify you in
a::vance and receive your written consent: (f) I sell or attempt to sell the Manufactured Harne withoul first cbtaining your written
consent: (g) I allow the ManufactUred Home to beeome part of any real estate wtthout first obtaining your written consent; (h) I
encumber or abandon the Manufactured Home or use It for hire orillegaily; (0 I faii to prcmptty pay any taxes and other liens and
encumbrances On" the Manufaotured Home or on 1M raal property on which it is located; andlor ill I fail to do anything else which
I have promised to do under thiS contract.
NOTICE OF DEFAULT: If any of the above spacffjeci Events of Default have"ocourred, you may do whatever is necessary to
correct my default You will, except as set forth below. first give me a Notioe of Oefault and Right to Cure Default before you
ac::elerate payment of the remaining unpala balance low", you or repossess or foreclose on any property which secures this
contract The NOllce will tell me what my default Is and how I can cure tt, Except as required by appiicable law, you are not
required to send me this Notioe when (1) you have >!.Iready sent a Notice twice within the preceding one-yaar period. (2) I have
abandoned or voluntarily surrendered the Manufactured Home, or (:lJ other extrE>me circumstances exist
CUBE OF DEFAULT: I may cure a defautt at any time before titla to the Manufactured Home is transferred from me. whioh will
"" at least 45 days atter receipt of the notice of defaull. To cure a default, I must pay: (a) all amounts which would have been
cue in tM abSence of default and acceleration; (b) the attorney's fees set forth below; (e) any late cnarges lhat are due: and
(C) reasonable costs which are actually incurred lor detaching and transporting the Manufactured Home to lhe site of sale" I
must also perform any other Obligation I would have ha.d to pertorm in the absenoe 6f default.
REMEOIES UPON OEFAULT: If I do not cure the doiaLIII, you may do any or all of the following at the end of the notice period,
as allowed by applicable law: (a) you can requlro me to Immediately pay you the entire remaining unpaid balance due under this
c:>ntract plus acerued interest or (b) you can r9pOS~QjlS the Manufactured Home pursuant to tha security interest I give you
under this contract. If you are not required to send me the Notiee 01 Default and Right to Cure Defauit. you will have these
rights immediately upon my default Once you get possession of the Manufactured Home you will sell it. If the ameunt from the
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sale, atter e"penses, Is less than what I 0', IOu, I will pay you the difference exoept ;u ",erwise provided by law" All remedies
are cumulative and you may enforce them separately Or tog8!har in any order you deem necessary to protect your security.
ARBITRATION c:)F DISPUTES AND WAIVER OF JURV TRIAL:
a, Dispute ResQI1Jtion. Any controversy or claim b"<ween or among you and I or our assignees arising out of or relating to this
contract or MY agreements or instrumenlll relating to or delivered in connection with this contract, including any claim based
on or ali.ing lrom an alleged tort, shall, if requestad by either you or me, be determined by arbitration, reference, or thai by e.
judge as provided below. A controversy invoiving 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 judioial referencE' 01 the controversy to a referee appointed by the court or, If the court where the
controversy is venued laoks the power to appoint a referee, by trial by a judge without a jury, as described below, You AND I
AGFlEE AND UNDEASTAND THAT WE AFlE GIVING UP 11-iE FliGHT TO 'ffiIAI. BY JURY, AND THERE SHALL BE NO
JURY WHETHER TIlE CONTFlOVERSY OF! CLAIM IS DECIDED BY ARBITRATION, BY JUDICIAL REFERENCE, OR BY
TRIAL ElY A JUDGE.
b, Arbitration. Since this contract touches and concems interstate commerce, an arb~ration under thrs contract shall be
conducted in ac:cordanoe with the United States Arbitraticn Act (Title e, United States Code), notwlthstanding any Choice of
law provision in this oontract. The Commercial Aules of the Amerloan Arbitration Association ('AM") aiSo shall apply. The
arbttrator(s) ,hall follow the law and shall give effect to statutlls of limitation in determining any ciaim. Any controversy
conoemrng whether an issue Is arbttrable shall bo 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 upon the award may be entered
in any oourt having jurisdiction, and no ohallenge to entry of judgment upcn the award shall be entertained except as
provided by Section 10 of the United Ste.tes Arb~r2.tion Act or upon a finding of manlfesllnjustice.
c. Judicial Reference or Trial by a Judge, If requested by either you or me, any controversy cr olaim under SUbparagraph (a)
that is net submitted to arbitration as provided In subparagraph (b) shail be determined by reference to a referee appointed
by the court who, sitting alone and wtthout jury, clhall decide all questions of law and fact. You and I Shall designate to the
court a referee selected under thEl auspices of the AAA In the same manner as arbitrators are selected in AM-sponsored
proceedings. ihe referee shall be an active attorney or retired judge. If the court where the controversy is venued lacks the
power to appOint a refe>ree, the controversy instead shall be decided by trial by a jUdge without a jury.
d. Self-Help, Foreclosure, and Provisional Remedies. The> provisions of this paragraph shall not limit any rights that you or I
may h..ve to e"ercise self-help remedies such as set-off or repossession, to foreciose by power of sale or judicially against or
sell any collateral or seourity, 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 exeroise of any
such remedy shall SElIVe as a waiver of" the right of either you or i tc demand that the related ""or any other dispute or
controversy be determined by arb~ration as provrded above.
A TiORNEY FEES: If I prevail in any legal action or arbitration proceeding which is commenced In connection with the
enforcement of this contract or any Instrument or agreGmant required under this contract, or in connection w~h any dispute
reiatlng to this centract, you will pay my reasonable attomey fees, costs and necessary disbursements incurred in oonnection
w~h such action or proceeding, as determined by the court, the referee, or the arbitrator(s) in accordance with the law. If you
prevail in any suoh action or proceeding, or in tM exercise of a"ny self-help remedy as described above, I will pay any
reasonable tees imposed on you by an attorney who is not your salaried employee, provided that prior to commencement of
I~al action suoh fees may not exceed $50.00 and further provided that no attomey fees may be charged prior to my receipt or
the notice of default.
CiHEA TERMS AND CONDITIONS: I agree: (a) to pay with my monthly installments, If requested by you to do so, the
estimated amount necessary to pay yearly taxes, assessments and Insurance premiums that will become due within the
next twelve month period: (b) to pay you a transfer loa if I sell the Manufactured Home, unless such fee is prohibited by law; (C)
to pay interest at the ocntract Tate en the remaining unpaid balance plus accrued interest, from the date of maturity until paid in
full; (d) to reimbl)~e you immediately upon your demand, with interest at the contract rate, the amount of tunds you actually
a.:vance on my behalf to correct my de/aun; and (<&) that ff I am married, and residing in a communrty property state, both my
community property and separate property will be liable lor all payments due under this contract.
ASSIGNMENT: You may assign this contract to any p"rson or entity. All rights granted to you under this contract shail apply to
any assignee of this contract.
CREDIT INFORMATION: You may investigate my credit history atld credit capacity in connection wfthopening and collecting
my aocount and ehare information about me and my account w~h credit reporting agencies. You may sell or otherwise fumish
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information' about me, inoluding insuranCI ormatl<:m, to all others who may lawfully r, ,ve such information, You may furnish
speQ~iQ information about the Manlltactured Home and any insuranoe policies on the Manufactured Home to any insurance
agent ta enable such Agent to quota premiums to t'no a.l"ld .sollcfi' my insurance bueineee,
WAIVER: WtJjver 01 any default shall not constitute a waiver of any other delau~, No term of this contract shall be changed
unless In writIng and signed by one of your olllcers, This <x>ntract is the entire agreement between us and I agree that no oral or
impliQd representations havGl been made to induce rna to enter into this contract,
V ALlJ:lITY: Wherever possible eaeh provision of this contraet shall be Interpreted in such manner as to be effective and valid
under applicable law, but ~ any provision 01 this contract shall be prohibited by or invalid under applicable law, "such prOVision
shall be ineffective only to the extent of such prohibition or invalldlly, without invalidating the remainder of such provision or the
remaining provisions of this contract. This contract shall be 01 no effect until and unless signed by me and you, In no event shall
any eMrge under this contract ""exceed the highest amount allowed by a.pplicable law. If any excess charge ;s received, sueh
excess shall be refunded or applied to the amcunt due"
GOVERNING LAW: Eaoh provision of this contract shall ~e construed in accordance w~h and governed by the laws of the state
where the Manufactured Home is located, provided that to the extent you have greater rtghts or remedies under Federal law,
Such choice of state law shall not be deemed to deprive you of such greater rights and remedies under Federalla.w,
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YOU AND I HAVE READ AND FUL.L.Y UNCEFlsrAND THIS CONTRACT, INC!.UDING THE PARAGRAPH CAL.L.ING FOR
RESOL.VING OISPU-reS BY ARBITRATION, R!'.FERENCe., OR TRIAL To A JUDGE, AND NOT BY JURY TRIA!., AND
AGREE TI;AT THIS CONTRACT seTS FORTH OUR ENTIRE AGREEMENT AND THAT NO OTHER PROMISES HAVE
BEEN MADE.
~~RY'S HOMES OF PA., IKC.
If you do not meet your contract obligations, you
may lose your manufact1.lred home.
NotIce to Buyer: 00 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.
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S~R'S
~o~ess: 2756 LYCOMING CREE?: RD.
W~LLIAMSPQRT, PA 177010000
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~IGNAT~~e" UL~{lY
~ER's I u: , :'-"
I DATE DFTHIS COi'ITAACT:. ,P. ;? r;
:192:9_
I AGREE TO ALL THE TERMS ON ALL jjAGES OF THIS RETAIL INSTAllMENT CONTRACT AND
ACKNOWLEDGE RECEIPT OF A COMPLETED COpy OF THIS CONTRACT.
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AtlSIClNMENT BY SELLEA
70 CREDITOR INDICATED ON PAGE 1 ("Cred~or")
With respect to this reta.il installment COntract ('contract") signed by one or more buyers ("Buyer"), SELLER represents
and warrants that: (1) Buy,,~s credit statement subh'litled herewrth is completely accurate unless otherwisa specijled; (2) Buyer
was legally competent to cantract at the time of Buyor's execution of this contract; (3) this contract arcse from the bona fide sale
af the merchandise described in this contract; (4) Ih" downpayment was made by Buyer in cash unless otherwise specified and
no part thereof was loaned directly or indirectly by Seller to Suyer, (5) any trade.in, or other consideration, received as any part
of the down payment is accurately described on page 2 and has been valued at its cona fide value, and any amount owed on
SUCh tr~de'in or other property is accura.tely described on page 2 ane has been paid off by Seller pnor to or contemporaneously
with the assignment of this contract to Creditor. (e) there is now owing on this contract the amount Silt forth herein: (7) this
eontract and any guaranty submitted in connection herewith Is in all respects legally enforceable against each purportec!
signatory therllof; (8) Seller has the right to assign this contract and thereby to convey good title to it: (g) in the event of any
claim or defense asserted by any Buyer, or any hairs or assigns of Buyer, with respect to the Manufactured Home or other
property or consideration transferred pursuant to this retail Installment contract, Selier ag rees that it will indemnify and hold
Creditor harmless from all such claims and defenses as well as from all eosts reasonably Inourred by Creditor in connection
therewith, including but not limited to reasonable attorney fees and ccurt oosts; and (1 0) in aocordance with the Fair Credit
Reporting Act, Selier has notified Suyerthatthis cot1tracl is to be submitted to Creditor.
For value received, Seller hereby Msigns 10 Creditor all rts rights, title and interest In this contract and the property
which is the subject matter hereof and al,lthorlZes Creditor to do everything Mcessary to collect aM discharge same. Au the
terms of any existing writtan agreements between SeUer and Creditor governing the purchase of "contracts are made a part
hereof by reference, it being understood that Credllor relies upon the above warranties and upon said agreaments in purchasing
this eontract,
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Certificate of Title
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400 Southpoime Boule~
SO\.l~pointe Pla2..1. I, Suite 130
C~onsburg. PA 1531'7
TeL (724) 873-;825
Fax (724) 873-5826
AprH 12, 2001
JAMES T. JOY
147 SME
SHIPPENS6URG PA 17257
GreenPoint ~ClI'edit
RE: Manufactured Home ~oan'- A~count #000006130298500001
NOTICE OF IlITElHlCl4 Yo~ctlilrnTJ;, IJHfEHCE lEC>Al ACTION OR REPOSSt:SS
TOU are. new in default on your Manl..lfactured Heme Loan Contract. - If you ccrrect the default, you May
~ontlnu~ with the contract as though you did not d~fault. Your default consists of failure to mike timely
payment~ of one or more 1nstallments as a~reed to in the terms or the ~ontract.
Thirty-one (31) d~ys after the date of this notir.e, we ~~y have the right to commQnce legal a~~ion and
repossess your manufactured home.
Cure of def8uLt~ your may cur~ yo~r defauLt by ma~;n9 Faym@nt in the smQunt indicated below;
PS$t Oue Monthly Payment(s)
!i 1,014.86
late Charg.{s)
5 5.00
Total Oue NQW
$ 1,019.86
Cl"~ditor'5 right!:: Any partial p.a.y:nent of the <1mount c:.:e which is re:eived by us w:lL, be applied to yOLir
account. "You will need-to pay the fuLl -~Fi':CUI",t by the ~a~e indic.ated ,above in ordQ!", to c:ure: your dQfaul~. U
you do not ~orreet your def~~(t within 31 days due f;cm :he postrnarktd dite Qf this no~ic:e. we may
e;<er<:ise our rights against .you under the law by accel~!"atlng your debt and either repQ5SeiSing yQL.lT
manufactured home or, if neeQ$~ary, bringing a-court aC~1on to ab!a~n po~sas~ion of your manufactured
home.
tf we elect to exercisi our rights against you by repossession of the manufactured heme you may, ~t ~~y
time before w. selt or otherwise disPQ~e of the"man~fic~wrd home or enter into a contract for it~ ~ote or
other disposition, (which $hall be :It le::lst 45. d-ay~ afte!" postmark of this notice), rl!ceem rM manurae.:::urC!d
home by paying us"all amount~ du~ plus exper,se~ rea~ongcly incurred by us in detachfns and transp9rt:r.9
the m~nuf3ctured home to the site Of the sale and our re;~onable-att~rneyls fees, to the ~xtQnt: perejt:t~d by
la~, pluc tourt cO~ts.
If you havl! any qUQstfons. write to us at ~he acdre~s a~:ve or catl me at the ~hone number listed above
bQtwQen the haur~ of 8:00 a.m. Dnd 5:00 p.m., Monday throygh Friday.
If thi$ dQfault was caused by your' failure to make a payment or payments, and you want to pay by m3il.
plei$e send. ,heck or money order. 00 not send cash.
~ana9Qr
EXHIBIT "e"
CC: Fi t.
If any acditional regular payment becomes due durine this c~re period, this payment mu~r also be p3id in
order to avoid any further default. This corresponden~e is 9n 9ttempt to 'oll~ct a debt and any
information Qbt~ "~l l;Q used for that purpose.
PA (144)
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-03454 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GREENPOINT CREDIT CORP
VS
JOY JAMES T
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - REPLEVIN
was served upon
JOY JAMES T
the
DEFENDANT
, at 1407:00 HOURS, on the 28th day of June
, 2001
at SHIPPENSBURG MOBILE ESTATES
LOT 147
500 MUNICIPAL DRIVE
SHIPPENSBURG, PA 17257
by handing to
JAMES T JOY
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
So Answers:
18.00
11.78
.00
10.00
.00
39.78
r~~
R. Thomas Kline
06/29/2001
ERIN DYER
Sworn and Subscribed to before
By:
d,<<j4~;W~ -
Deputy Sherif~
me this
day of
A.D.
~~hO
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit Corp.,
CIVIL DIVISION
Defendant.
)
)
)
)
)
)
)
)
)
No. 01-3454 Civil Term
Plaintiff,
v.
James T. Joy,
PRAECIPE TO DISCONTINUE PURSUANT TO
PENNSYLVANIA R.C.P. RULE 229
To the Prothonotary:
Please discontinue the above-captioned action at the request of Plaintiff, pursuant
to Pa.R.C.P. Rule 229. The discontinuance shall be without prejudice, and shall not be
deemed to bar the bringing of an action to collect any deficiency (or deficiency judgment)
owed to plaintiff by Defendant.
Respectfully submitted,
~
Erin P. Dyer, Esquire
PA ID Number: 52748
Attorney for GreenPoint
5743 Centre Avenue
Pittsburgh, PA 15206
(412) 361-1000
l:\GreenPointIJov. Jamas T\P2D.wpd
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