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HomeMy WebLinkAbout01-04771 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, Plaintiff, v. Richard B. Howland and Penny L. Howland, Defendants. CIVfL DIVISION i No. ~/- y7~1 Complaint in Civil Action -Replevin Filed on behalf of: GreenPoint Credit, LLC 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, Plaintiff, v. Richard B. Howland and Penny L. Howland, Defendants. CIVIL DIVISION No. ~~~ G/7 ~ Complaint in Replevin 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. Cumberland County Bar Association 2 liberty Avenue Carlisle, PA 17013 (800) 990-9108 (717)249-3166 fN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, ) CIVIL DIVISION Plaintiff, ) No. ©/,~`77 v. ) Complaint in Replevin Richard B. Howland and ) Penny L. Howland, ) Defendants. 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, hereinafterreferredtoas"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. Richard B. Howland and Penny L. Howland, hereinafter referred to as "Defendants," are individualswhose last known address is 101 Rustic Drive, Shippensburg, PA 17257. 3. On or about November 17, 1999, Defendants purchased a 1999 Titan Riverbirch Manufactured Home, Serial Number 19990653924AB (the "Mobile Home"),from Country Side Village Homes, (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. SellerassigneditsinterestintheSecurityAgreementtoPlaintiff,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 $60,000.00 and that the said Mobile Home is in the Defendants° possession and believed to be at Defendants' address as stated above. 6. Defendants defaulted under the terms of the Security Agreement by failing to make payments when due. As of July 26, 2001, the Defendants' payments of interest and principal were in arrears in the amount of $719.66. Pursuant to the Acceleration Clause in the Security Agreement the amount outstanding as of July 26, 2001, is $59,284.40. 7. Plaintiff provided Defendants 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. Defendants 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. Defendants 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 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 ordertobring this action GreenPoint Credit, LLC was required to retain an attorney and did so retain Attorney Erin P. Dyer. WHEREFORE, Plaintiff, GreenPoint Credit, LLC, requests: a) judgment against Defendants 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, LLC, 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. WHEREFORE, Plaintiff, GreenPoint Credit, LLC, requests: a) judgment against Defendants in the amount of $59,284.40 with interest and late charges p{us 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, LLC 2021 Murray Avenue, Suite B Pittsburgh, PA 15217 (412) 422-8975 L:\GreenPointU-lowland, Richard & Penny\CM.wpd 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 are true and correct to the best of his knowledge, information and belief. Don Turosik Collection Manager GreenPoint Credit, LLC JUl•-31-2001 12=43 GREENPOINT CREDIT 61 n 4^2 87`5827 ~ P_67/12 [rv1v0 r ~.v nr.,.+ `~ 1rTAll INSTALLMENT CONT«t;T, SECURITY AGREEIIPENT, LOAN PLAN: AO1 111'r 99 VAINER OF TRIAL BY JURY AND AC~REENIENT TO oFFICENUMeER:79061 _ ~RBITRATIONORREFERENCEORTRIALBYJUDGE~!LONE oFFlCE LOgNSOUacENO:7soz~o ~Oilf:~BCt) ~ ONEY :...:~ ACCT. NO,: tnf•~Q t1~_ DYER(S): NAME: PENNY L NAME: RICHARD NAME: DYER'S NAME: oDRESS:212 E BLtRD ST ~. FUNDING CODE: couNTr, CtiM3ERLAND g7y;SHIPPENSSURG sTATE:PA ZIP: 17257 32.8730 s.sEC.a(s):200-52-8856 160•ae-8°.24 'FOPOSEDLOQATIONOFMANUFACTUREDWOME:,S'rRTJ$"?'IC DR, SHIPPENSBURG, PA 17257 I," "me," "myself" or "my" mean all persons who sign this Contract as buyer or co-buyer, jointly and severally, and "you" or your" mean the Seller and any assignee. This Contract will be submitted to the Creditor indicated below, at a local office and, ff tpproved, itwill be assigned to that Creditor. On the date of this Contract, 1 buy from you on a credit sale basis the manufactured tome described on page z, together with furnishings, equipment, appliances and accessories included In the manufactured tome at the time of purchase (called "Manufactured Nome"), ~REDiTOR:GREENpOINT CREDiT, LLC oROMISE Tp PAY: I promise to pay you at such address as you may direct the Unpaid Balance shown on page 2 of this ;ontrad (Item 5) with interest at the initial rate of 8 . 5 0 % per year. The interest rate I will pay will change in accordance Nith the provisions of this Contract. I will pay this amount in installments as shown in the payment schedule, or as recomputed jue to changes in the interest rate, until the Unpaid Balance is fully paid. (f, on 11/ 19 /29 , I still owe any amount under this Contract, I will pay such amount in full on that date, which is called the "Maturity Dat®." Each monthly payment will be applied as of its Scheduled due date. If no Interest rate is disclosed above, the initial interest rate is the Annual Percentage Rate shown below, INTEREST RATE: My initial interest rate may not be based on the index used to make later adjustments. My interest rate may change 11 months after my first payment is due and every lz months thereafter based on movements in the average of interbank offered rates for one year U.S. dollar denominated deposits in the London market based upon the quotation of major banks as published in the "Money Rates" section of The Wall Street Journal on the first publication day of each month, and known as the London Interbank Offered Rates (LIBOR), which is the index rate. This is called my "interest rate change date," My interest rate cannot increase or decrease by more than 2 . 0 0 % at any interest rata 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 of 4 .25 % (rounded to the NEAREST 1/S of one percentage point) unless the interest rate caps limit the amount of change In the interest rate. li ;his index rate is no longer available, you may choose a new index that is based upon comparable information. ANNUAL FINANCE CHARGE Amount Financed Total of Payments Total Sale Price ~ PERCENTAGE The amount I will have paid The total cost df my RATE after I have made au purchaseon credit The dollar amount the The amount o1 Credit payments as scneduled (which Is subject lv The cost of my creditas credit will cost me (which provided to me or on (based on the current ohango) including my a yearly rate (wnich is subleot [o ch n e : is subject to change)' my behalf; Annual Percentage Rata which is subjeot to change); . dgown pa mentor (, D ~ ~ . 0 0 g a ) 10.i5 % S i3~,650.22 5 56,527.50 y 192,1%7.72 S 199,177.72 ..::: $ee +7 a e Z ~ Rn. Char-.e+Amount Firi.. Total Pay. ~ Down`Pa inerir i See Contract tarmstor additional informapon about nonpayment, default, required repayment 'Number of -:Pa moots "" Amdtint of - - ~ Pa' menu '" `~ ~ ~~" ~' =~ ~Whan Payments Ate Due ~ in full belore the soheduletl date, and 12 $ 452.25 o 1 Monmly,beginning DECEMBER 9 19.9 prepaymentrewndsandpenaldes. My t 3 48 $ 53 6 . 6 4 beginning DECEMBER 19 2 C 0 0 i Monthly Prepayment; It I pay oft early, I will not paymen _ , have to pay a penalty but I will not be sohedue $ i Monthly, beginning , , entitled to a refuntl of the Prepaitl wil!•br:::- $ ~; Monthly, beginning , Fnance Charge, if any. 1 Security: I give you a seta my interest in me goods er property being pun;h85ed. Late Charge: If a payment i5 more than' 5 days late, I will be charged 5 °h of the unpaid amount of such payment, not to exceed s 5.00 Vadeble Rah: My Contract contains a variable rate feature. Disclosures aboutlhe variable rate feature have been provided to me earlier. Aaaumpdvn: Someone buying my ManutacNred Hame may, antler Certain circumstances, be allowed to asaumethe remainder of the Conhaot on the ohginal Wrms• Estimates: All numerical disclosures ezwpO NBlate payment disclosures are estimates. The above disclosures are based on terms of Payments, Annual Percentage Rate, Fin PA35GB~.09993 EXHIBIT nAu It the Interest rate changes, actual Amount more or less than disclosed above. P40E 1 CF ° ., JUL-3.-c8©1 ,z:44 GREENPGIN7 CREDIT 61 y~ 412 873 5827 P.08i?e Descriptionot TRACE NAME: TITAN HOMES, 2NC. MOCEU-'~=VnRBIRCH Manufactured Home: YeAR: 1999 NEW: X USED'. ~^ LENGTH: 54 tt. WIDTH: 26 tt. SERIAL NuMeER5:19990653924AB (TEM ~''" SERtkL`NUMHER i ~ -ITEM''' i~. SERIAL NUMBER( AbDITIONAL AIR CONDITNG ACCESSORIES G',iTT~R/DOA?NS AND FUgN15HING5: DECKS SKIRT/SHED P,NC:-IORS BR, CHIMrtEY 1. Cash Price-(Including Sales PRQPERTY INSURANCE: Property Insurance on the TaxofS .CO ): ___„ ._.. S 63,500.00 Manufactured Home is required for the term of this 2 a. Cash Down Payment S 7 , 000 . o C ~ Contract. I have the right to choose the person through b. Trade•In (Year, 1Jake, Model): _ I whom it is obtain¢d, By marking the appropriate line Length width below, I elect to buy the coverage indicated from you Gross value 5 . o o Liens S . 0 0 ~ for the term and premium shown, and i want it financed (Seller to payoff) ~ onthisContract. Net TradeJn Value S . 0 0 Total Dawn Payment _ _ _ _ S 7 , 0 0 0 . 0 G ~ I TYPe of Insurance T¢rm Premium 3. Unpaid Balance of Gash Price (t minus 2) $ 56 , 5 0 0 . 0 0 ~ ~ ?nvslcal Damage coverago OMO_S S 0 0 4. amounts paid to others on my behalf` i ~ BROAD FORM S a. 7o Insurance Companies: _ ~ $ (7)Properiy lnsuranc¢ S .00 I J ~ {2) Credit Life Insurance 5 . 00 LIABILITY INSURANCE COVERAGE: FOR BODILY ~ b. To Public Officials: INJURY AND PROPER"Il' DAMAGE CAUSED 70 ~ {1) Certificate of Title 5 i 22 . ~ 0 OTHERS IS NOT INCLUDED UNLESS INDICATED IN (2) e IL~NG ^ FE5 S 5.00 THE PROPERTY INSURANCE SECTION ABOVE. a To Greditoc _ CREDIT LIFE INSURANCE: Credit LiF6 Insurance is For. ORT~ ~~ES S 2 , Z 6 2.18 ~ ~ not required for this Contract or a factor in its approval. d. To: ~ ~ !f I elect Credit Life Insurance, the name(s) of the For: I J proposed insureds) are; S , 00 ~ Proposed Insured e. To: _ Proposedlnsured • For: _ I ('Only spouse can be insured jointly ) S .CO . t. 70: This insurance may not pay oft all of my debt, and the For: exact amount of coverage is shown on my policy or S . C 0 certificate, My signature indicates my election to obtain ' g. To: GBEENPOINT CRcDIT, L Credit Life Insurance coverag¢ for the term and i For. FLOOD r EE prem um shown: S 27.00 Type of Coverage Term Premium h, To: --. For: - Single $ - S Total{a+b+c+d+e.+ }+g+h) $ 2,316.68 i ,_ Joint _ $ paid Balance (3 pN 4) _ , _S 58,.816.68 I i f g I Date 6. Prepaid Finance Char a $ 2 , 2 8 9.18 ~ ~ (signature) ' , 7. Amount Financed (S minus 6) S 56 , 52.7.50 ' 1 understand and agree that a portion of certain of these amounts may be retained by you or your affiliate. Date (signature) (Itjoint coverage is' ~-ired, both proposed insureds must sign.; ?ear z or JUL-31-28D1 12:45 GREENPOINT CREDIT 61 412 873 5827 P.B9il0 4RIA8LE RATE: ~°" Monthly Payment Changes. My monthly payment amount will change each time m crest rate is adjusted. I will pay the amount of the new monthly payment beginning the first monthly payment at the interest rate change date. The monthly payment amount would fully amortize the remaining unpaid balance I am expected to owe an Nte interest rate change date at the adjusted interest rate in equal monthly payments over the remaining Term of this Agreement. . Notice of Interest Rate and Monthly Paymcnt Changes. You will send me notice of an adjustment in the interest rate and monthly payment at least 25 days before the adjustment. This notice will contain information about the index rate, interest rate, payment amount and remaining unpaid balance. . Conversion to Fixed Rate. I may choose to convert this Contract to a fixed rate Contrail at any time beginning ZEP,O years from the date of this Contract and ending 3 o years from the date of this Contract. In order 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 desire to convert to a fixed rate, 1 must execute a revision agreement and I must pay a nonrefundable conversion fee, The new fixed interest rate will be your standard fixed interest rate for a comparable Contract on the date that you receive my written not'rfication. The new fixed rate will take effect on the "Conversion Date," which shall b® my next payment due date that is at least 3 0 days after your timely receipt of a revision agreement signed by all Borrowers together with a nonrefundable conversion tee of $ 20D .00 _. The new fixed rate and the Conversion Date are subject to change if my revision agreement and fees are received after the date specified in the revision agreement. My new payment amount will be effective with the first payment following the Conversion Date. SECURITY INTEREST: I grant you a security interest under the Un'rform Gammercial Code in (1) the Manufactured Home and in all goods that are or may hereafter by operation of law become accessions to it, (2) all appliances, machinery, equipment and other goods furnished with the Manufactured Home (whether or not installed or affixed to it) including but not limited t0 the items listed as "Additional Accessories and Furnishings" on page 1 of this Contract, (3) any refunds of unearned insurance premiums financed in this Contract, (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 my obligations under this Contract, including any additional debt arising because of my failure to perform my obligations under this Contract and includes any contractual extensions, renewals or mod'rfications. My execution of this Contract constitutes a waiver of my personal property and homestead exemption rights to the personal property herein described. I will sign and deliver to you whatever financing statements and other documents you deem necessary to allow you to perfect your security interest in any personal property and fixtures. 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 far 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 thereof, shall be sufficient to perfect a security interest with respect to such items. PREPAYMENT: I MAY PREPAY THIS CONTRACT IN FULL OR IN PART AT ANY TIME WITHOUT PENALTY, BUT I WILL NOT BE ENTITLED TO A REFUND OF THE PREPAID FINANCE CHARGE, IF ANY. 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. PROPERTY INSURANCE: a. Minimum Coverage. I am required to provide physical damage insurance coverage protecting the Manufactured Home for the term of this Contract against loss by fire, hazards included within the term "extended coverage" 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 lima on 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 f 0-day notice of cancellation to you. Unless you consent in writing, I shall not add any additional Toss 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 cancelled prior to payment in full of this Contract, 1 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 to, obtain insurance coverage, I agree 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, If you decide, in your sole discretion, 40 obtain insurance, you will notify mB of that fact and that the cost, plus interest at the Contract rate, will be added to my debt. l will repay such amount during the term of the policy in the manner requested by you. 1 understand Shat the insurance premiums may be nigher if you must purchase the insurance than might be the case if I had purchased the insurance, and that you may purchase the insurance from an affiliated company which may receive a profit for this service. PAJSOB~d999 FAG: J CF 6 ORIGZNP.L COPY .71.4 - _" E.FI;F'Cs iN'r '=RrD S ~ '' i +-rt jE b. Assic~nmcnt ar,d .z,~+~SSFaafion o1 lnsuranee Prosaeeds. 3 n,=res.y arr.nt and assign to yad the proceeds at any and aP! frtsurar`,aa coverage on the Manufactured Hame, inaiudirrg arq opUras.ai coverage, such as earthquake ,nsuranae, which in typo rr amount is beyond the tfinimum Coverage, 1n the event of a If,;s tr+ iha fAanufacturad Horne, 1 shall gyve prompt net,de to you and the crasurance carver. tt f fart to promptly r,otifi' or make proof of foss to iha insurance carrier, you may do srr on my dehaif..~,il pf;ye,aal damage insurance proceeds, inciudmg proceeds front aptiana! coaeraga, shelf ba applied to restoration or repair of the r~tanufaotursd Hams, unless you and i agree othsrr:r:e• v, vuntfng or unless such restora:ian or repair is not acanomicaify ~Srar.Yicaf or feasible, ar your security interest would br-0 t+M;cared. it sucP~ restoration ar repair is not practical nr feasible, or your secur:tg tr,tarast would be tassaned, you shelf a;,pl PI•,s rn;:uranca proraeds to the remaining unpaid balance of this Contract, •:rhetYrer ar net then due, ttnd give me any excess. Ar_uthariz® any' insurer to pay you direct}y, I hereby appoint you as rr;y limited attorney°in-tact to sign my n,.ma Yo any cheoi;, drexN, or ether 6orunrant necessary 2a obtain such insurance pay'menis, LATE CHARGE: i ag;ere to pay a late eharye for lute payment as seY forth: qn tike front cf this Cantrart. Only one Satp chargw will be msde an any deii,"tique,nt instailmsnt regardless of the period for which that instaiiment remains n dafauft, AftsC this Contract matures, wnather by aa:ef°rstion ar otherwise, } full! oat be charged a lets ch.Trgx>. EVEN76 OF DErAtJLf': I evil( da in default under this Contract if: f,ej S t~~ tc n+aka any payment when due; (ts) f fai4 to timely Hake rental payments, cr ir. pay other charges and assessments, reitalrag tt~ tf•,a rent property and(ar fadiiity on which the Aanufaatured Hdme is Cocated, {c) I v+ielafe restrictive covenants, toss cs r:-gutatians relating tc the real property andfar faciSiPy there the A{anu4ac[ured Hama ss located; (d) (fzil to keep th© Pdanutaotured liv~ma in goad repo+r and condition, as you may aasonably determine, (el i rermave the tvtanu,'acturc+d Home from the acidrrss Shawn er, th,ls Contract unless t noC~' you ~n dvance end race+ve ycwr lvritten consent; (t) 7 sell ar attempt to sal! c!' to trar+sr.~r any benetiual interest in the Manufactured oma without f~rsi abta!nmy~ your vari:#en content; (yi t a;law' the Manufactured Flame to 6ecoma part at any teat estate without si obtaining your vrsitten consent; (h) 1 encumber ar abandon the AAanutaaturesd E-iome ar use ii tar hire ar dlegalig; (i) I fail Ya cmptiy pay Any taxes and vfhar mans and encumbrances on the ~9anufacbu,fid Hama ar on the reef property an which it is sated, it tt•,is is ry r:~•arran;i6ifiYyr; andfar (j) f fat! to da anything else tehiah t `+rvae promised to do under this Contract. +TICE OF DEFAULT': !t an of the above specified Events of Jefaui± htavr;, ar:curred, you may dd whatever is necessary to reci my defauiY, '/cu w,li, except as sat forth below. first give me a 4do~wF of Uefauit and Right td Cure [3afault before ydu elprafa paym.ant vs the re,•r~aus~ng unpaid balance I owe ydu ar repossess ~,r forealase an any prcparry which secures this Bract, The Nance wail tali me wfcat my detaui# rs and Katy I can cure it. t~,,.r.~~cat as r®qulred by app;icebte tavv, you era not tired to send me. 2`e:is PVatic€: urban 11) you have airead,r s¢nt a hafice t;~.ia~ wttH,n tna preceding ono-year parted, (2) f hate tdaned or vciuntariiy surrendered the tv9anuFaaturad Hame, or (3) otner extrr?rn,-. r,rcumstances exist. E OP LYEFAUL'i': i may cure a default at any tuna before ti<(E to ti,a t+9anui;act+.rrrad kiome is transte+rrad frsm me, which vaii9 feast :~ days sitar recrript a4 the tJotice of Uefeulf and Right to Cure Oetault. 'tr, a,:re a default, 1 must pay: {a} all amounts r would have been due in the aL°s~?nc® at default and adca!eratlen; ib; the atk.1>nuy fear sat forth beloµr; (e) any late charges ,re doer and (dl reasonable costs which are actually incurred for detaching sod transporting the F+tanutacturad Home to the t sale f mutt also per`cr,n any other obligation f would have had to GarYr,m•i in file absences of default. dFJ1E5 UPpN UEFAUL°f: if t e!o rat cure it,e default, y=au may do ether or u°r,th r.,f the follan+i,^.g at the end of the notice as allowed by app!icatir= law: (mi you can require m® fa rmnrediatvly pail' y.!.t the entire remaining unpaid balance due this CantracR plus accrued interest or (b} yeu can repossess the h7anufaaturer Home pursuant to the security interest t %u under this Contract. If you area not r,aquired to send me Use Notice of t;~r r,:utr and Hight to Cure Dafauft, you will have fights i,•rrmediataiy upon r»y dcfauit. Once you gat possession of the hSarufacturer± Hama you voili sell i±. !f the amount cram s, after Expanses, is le ,than ~rvhat f awe you, A vriif pay you the diflerenca except as othervrise provided 6y law_ Alf rs era aumuiatvr ar.d }+au may coterie tfrem separately or together in anti erac~r you deem necessary to protect your A710N t3F OISpt17EE .Atdt31VA1VER OF JURY TRIAL tte Resalutian. hny controversy ar claim between or among you and mr~ a:r our assigraes arising out at ar relating to tantrect ar any agreements or' instruments relating to ar delivered in crnr,ecti~;n v,ith this Contract, incfudfng any claim ! on or analog tram air aNeagod tort, shall, g requested by either you ;;r n;n, buy determined by arbiiraticn, reference, ar / a judos as provided delaµr. A oan!rdversy invdl•,+ing anPy' a eir,gle clairr,ant, c+r r,.lai~,~ants who are r®tated or asserting arising tram a smyie transaction; she!! he deter,~,iriad by arbitrat+on as des;anb~n aa!ew. Any other controversy shaRi be tined by judiaiaf ref:3r~nce afrhe oantroversy to a referee appointed by ti•~e Ccurl' ar, if the court where the controversy red larks the power to appoint a rotate®, by trial by a judge without a iu~. a.: ~~vscribect bateau. YOU ANO I AGREE tNQ~fi57ANE? °fffAT t~°JE AREE'afVitJG U!' 7HE ii}GHT TO TRIAL t•3Y ,tt3F+Y`, AND TfiERE SHALL BE NO JURY tER THE GCfJTRe3W~f3sY esrt cLAiNtts DBc[C1Eb 6Y ARSt7RA'-"trail, rev JUt7tCtAL REFERENCE, OR BY 9Y A JUt]GE. ~ JUL-31-2001 12 4Q, , i'%`. N D V NPOINT CREDIT 61 _ 'T.IFIG'ATE.;OF TITtE'?;FOE2 nZ id ~°' 4?2 873 5827 P.63ila 1 pIXfEp g~ e 1 {, D4TE DF105-E 1 V n. :y, I„ T'a5f51 : 6 '_ I B1M1t ~'` ~. JE I.n t~l ~ ~ ODCNE[ER ETYTW ~y~ 1 r T$1' b~ v1 r a -_ ',. .. 6 PCfWLNI{FJGE dl 3 Ir ~~1 ~ >YI F 1'1~"~ t ,f ~ ~ ~~ r Mltyge GOEE09 TXENFLWINIGL, Y 41A1i5 ay U ja > _ J :NOT T"Ie,O*u,UNtFAaE , , as ~.. 1' .~R, a NDrrwu.uraevxwerenlL r € ` ..r+ !+ - ~~~ r _ ', YwrEwNO Vewt+®' f lt~A pDOnET,Eit'' DISCLUSURE~ 'EEtDERAt LAx '.E<ENmRiWOPOYETEpOl4EtDBLWE `~ I y~, ~-M1'~ r ~ TNL'ewNOS; I kFAISTEFEU OWNE9(51 1 - ~r~~~ ~ .. K I~l'y d..LMtO.£VE4LL' £ ~; I A ' atl, i.F..naw~ ! D-cDUacrmce rehlue 1 ,-; FENNY,,,..'{, 6 ;RICNARDG~:".S ~'I`6"zo ~7~s*~q D.«deaIC VENIaE .' 4 ..rte N Z I -'.WTW OpUN1RV - .Y1 ~ ~~~~%yF~R^ I: ~' 6 •:OXIGINALLT npGO. l'ORNO+YU 9.1 ~~ NONL1lND e,,; 4d-•h,Q'~c v; '~+"+ :~ olsalBUnDN 7101 '.R.USTIC',; DR `,"M•T., ~'^'~--'~.'~' ~ iwc~re`cnvin ie"~ I SHI PYEN58URG P A ''17257 ~ : ~AB~ ~ r - f`r . _ d • bmaEef 0D0 .: f i -' - ~ ~ '.Y >REOOVEPW TNFFTVDIICIE al v .vE41ClE CGMNNO nUJgVEO NN W . e1000 vEnietE r7nSTlrEN FLVOR OP ~ - rY >IYwo9 dT4Yl SECDND JEV EdvOR Of: 6REENP,gIN7:CRED.TT'CDRP ,' ' I! a wcam Ittiea4p II IiSM 0pU1 6drk(fif110R 6! Ve 0M Marl, Pq Ilrel -`-- Lenb¢er rc,w Ich:Ua :n0 rrce ro Va Duraau c! Mere~'lW,rra wU ua IRS LIEr+gEIE.I.F,] ~ >Oa~caW191gn aM lal. I OLTE 9Y'T "'~ ~ ~ ~ 6ECC9D LIEN RElEA3ED _- ~.' ~hUTH0A17E0 dFaRE6ENTdT:VE pp{a 4/JUNO dODRESg ' .... '-. fiY .. 031D07 wiFDRIIED REPRE3ENrP'IVf GRI=ENPOIN7 CREDIT'LORP 400 SpUTHPOINTE BLVD ST£ '23'0 CANONSBURG PA 7,$317 r r ~n ., a w ~. a w... a,~ ,x;w r.hb> al .n. R.aa>w>r'> wpws„~ ~ ;~BRAUE~' y ! l'~1~I:WRY d Teapprallan MAaC Pat Pe pam161 er pmpr> ramee harPlL la Ihe'aMVI Y.+e- >,~r. ^„aya" ya d Oa ..a.>enitle. , ~,; - Sanmrv e! Trna>pocutlov , , 6U96DRIBED BND BwOAN ~' I, Il a Wppttl101BE 01Daf then YGUS SpVY6C la IIgIOQ en3 YOU YrenL UIB.tli(a"JD~; ~~ ' Da Ilarod ea 'Jolrx ienae.e wnh F~9N' e! Survivorehip' (On ,deB~'oF,anP,,;' I ew~or, m:a 9aoc a surviving owner.) CHEOK MEREO. Ofherwlw Ih611tl 0.'111 DE 190060 8S TBnenb 10 Comm6n' (On c6em OhORB 0 IIBY Ig(er09L 01 ~(~' '' LtlECEOgBd pwRB! g086 ID hI5l11Bf h61R Or B6RI0). f 95T LIEU OdT6: '..>~ If NO UEN DNEDIC D J;L,' I 13i E'ELMOaDEP . I . v;. D"r .~ 6'I'4TE ~ PF YIVU.CIP11N6TRIjIION KUMBER 'i ZNO JCN DiTE iIF M~UEN ONEGO ff. 1 ©Ji:F I xlD ua.NNOLOeR ' ~ '.r r Its .a .,, - ':. I,n.. ., :: STM1TE Ta Ben , F i EXHIBIT Wages ~z .. „~. rl 4 JUt_-3.-2001 1242 g/~eGREENPOINT CREDIT 61 412 873 5827 • ~tiHf ou[hpo[n[e Boulevard uthpointe Plaza 1, Suite 280 Canonsburg, P:1 15317 Tel. (7?4) Si3-SS'?5 Fax (S00) 959.7395 June 28, 2001 PENNY L. NOULAND . • RICHARD B. NOULAND GI'eQlIP~Ilitf CTPed~$ 701 RUSTIC DRIVE SHIPPENSSURG PA 17257 RE: manufactured Home loan Account g0000D6130377600001 NOTICE of 1NTENTI ON TO ACCELERATE CLIWERCE LEGAL ACT10N LPt REPOSSESS You are now in default on your Manufactured Home Lean Contract. tt you correct the default, you may continue with the contract as though you did not default. Your deft ault consists of failure to make timely payments of bne or mare installments as ag read to in the Yerms of the contract. Thirty-one (31) days of Yer the date vt this notice, we maY have the right to commence legal action and repossess your manufactured home. Oure of default: Ycur may cure your default by making payment in the amount indicated below: Past Due Ftonthly PaymenT(s) S 1,109.66 Late Charge(s) S 60.00 Total Due Now 5 1,769.66 P.04i10 LreditoN s rights: any partial payment of the amount due which is received by us wilt be applied to your acwunt. you will need to pay the full amount by the dace indicated above in order to cure your default. if you do not correct your default within 31 days due frcm the postmarked date of this notice, we may exercise our rights aya;nst you under the law by accelerating your debt and either repossessing your manuf achred home or, if necessary, bringing a court action to obtain possession of your manufactured home. if we elect to exc cise our rights against ycu by repossession or the manufiactured hcme ycu may, at any time before we sel'. cr otherwise dispose e' the manufacturd home ar enter into a contract for its sale or ether disposition, (which shall be at least 45 days after postmark of this notice), redeem the manufactured hcme by paying us all amounts due pt us expenses reasonably incurred by us in detaehine and transporting the manufactured horns to the site of the sale and our reasonable an orney's fees, to the extent permitted by tau, plus Caurt cosu. If yru havx any questions, write to us at the address above or [ail me at the phvre number 115ted above between the hours of 8:00 a.m. and 5:00 p.m., Monday through Fritlay. if this def aide was caused by your fat lure to make a payment or pa talents, and you want :o pay by mail, please send a checE or money order. Co net send cash. Manager CC: File IF any adgiti onal regular payment becomes due during this cure period, this payment must also b¢ paid in order TO avoid any further tlefeult. Yhis corrds3ond~ee is an ea zmpt to tolleet a debt and any i ntormat ion obtui nod will be used `-" `~4* ^^~^^~_ PA (1GG) EXHIBIT "C" r6?.^~a. 0 /w `, ny ~ ~ ~~ i, ~ ~ n! ~ ~ \ C; W C ~- r`' ~C.~ '» ~ ~ ~ Ct'` -- to - ' ~,_ -- r -.~~ ~L z ~ cn { CASE NO: 2001-04771 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREENPOINT CREDIT LLC VS HOWLAND RICHARD B ET CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon HOWLAND RI DEFENDANT the at 1941:00 HOURS, on the 20th day of August 2001 at 101 RUSTIC DRIVE SHIPPENSBURG, PA 17257 by handing to PENNY L HOWLAND a true and attested copy of COMPLAINT - REPLEVIN together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.65 Affidavit .00 Surcharge 10.00 .00 41.65 So Answers: ~~~~ R. Thomas Kline 08/21/20 ERIN P D Sworn and Subscribed to before By: me this 36 `~ day of a7o-a/ A . D . Q /Yl.CXXL...+ , othonotary `''"`~ ~`, SHERIFF'S RETURN - REGULAR +CASS NO: 2001-04771 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREENPOINT CREDIT LLC VS HOWLAND RICHARD B ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon HOWLAND PENNY L DEFENDANT the at 1941:00 HOURS, on the 20th day of August 2001 at 101 RUSTIC DRIVE SHIPPENSBURG, PA 17257 PENNY L HOWLAND by handing to a true and attested copy of COMPLAINT - REPLEVIN together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 3p ~ day of So Answers: ~~ R. Thomas Kline 08/21/2001 ERIN P DYER By: Deputy Sher' f a-~v///ff A . D . - n,,, Pr tl ono y ~~/ ~, _ o-.x. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, Plaintiff, CIVIL DIVISION No. 01-4771 Civil v. Richard B. Howland and Penny L. Howland, Defendants. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT To the Prothonotary: Please enter Judgment by Default in favor of Plaintiff GreenPoint Credit, LLC and against Defendants Richard B. Howland and Penny L. Howland for their 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. Defendants were served with the Complaint on August 20, 2001 and their answer was due to be filed on September 10, 2001. Attached as Exhibit "A" is a copy of Plaintiffs written Notice of Intention to File Praecipe for Entry of Default Judgment which I certify was mailed by regular mail to the Defendants at their last known address and to their attorney of record, if any, on September 13, 2001, which is at least 10 days prior to the filing of this Praecipe. Please enter judgment for possession of the 1999 Titan Riverbirch Manufactured Home, Serial Number 19990653924AB, that being the relief demanded in the Complaint. Erin .Dyer, Esquire PAID Number: 52748 Attorney for GreenPoint 2021 Murray Avenue, Suite B Pittsburgh, PA 15217 (412) 422-8975 Attachments: Ten Day Notice -- Exhibit "A" Affidavit of Non-Military Service & Last Known Address ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN)A GreenPoint Credit, LLC, Plaintiff, v. Richard B. Howland and Penny L. Howland, Defendants. CIVIL DIVISION No. 01-4771 Civil Via Certified Mail #7000-1670-0013-4594-5550 and Certificate of Mailing Richard B. Howland 101 Rustic Drive Shippensburg, PA 17257 Date of Notice: September 13, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BYATTORNEY 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 CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Association Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 Erin P. squire Attorney for Plaintiff 2021 Murray Avenue, Suite B Pittsburgh, PA 15217 (412) 422-8975 L:\GreenPolnt\Howland, Richard & Penny\TDN - Richard.wpd ,l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, Plaintiff, v. Richard B. Howland and Penny L. Howland, Defendan#s. CIVIL DIVISION No. 01-4771 Civil Via Certified Mail #7000-1670-0013-4594-5543 and Certificate of Mailing penny L. Howland 101 Rustic Drive Shippensburg, PA 17257 Date of Notice: September 13, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR 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 AGAINSTYOU WITHOUTA HEARING ANDYOU MAY LOSEYOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Association Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 L:1GreenPOlntlHowland, Richard $ Penny\TDN - Penny.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, Plaintiff, v. Richard B. Howland and Penny L. Howland, Defendants. CIVIL DIVISION No. 01-4771 Civil 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 Defendants' place of residence is 101 Rustic Drive, Shippensburg, PA 17257, and that they are 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. Erm P. Dyer, Esquire PAID Number: 52748 Attorney for GreenPoint 2021 Murray Avenue, Suite B Pittsburgh, PA 15217 (412) 422-8975 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, Plaintiff, v. Richard B. Howland and Penny L. Howland, Defendants. Richard B. Howland 101 Rustic Drive Shippensburg, PA 17257 CIVIL DIVISION No. 01-4771 Civil NOTICE Pursuant to the requirements of Pa. R.C.P. 236, you are hereby notified that: JUDGMENT BY DEFAULT has been entered against you in the above proceeding. Prothonotary of Cumb ounty IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, Plaintiff, v. Richard B. Howland and Penny L. Howland, Defendants. Penny L. Howland 101 Rustic Drive Shippensburg, PA 17257 CIVIL DIVISION No. 01-4771 Civil NOTICE Pursuant to the requirements of Pa. R.C.P. 236, you are hereby notified that: JUDGMENT BY DEFAULT has been entered against you in the above proceeding. Prothonotary of Cum er d County ~k ~}~ J I' ~ ~, ~ d C' I Q~ r3 -~~- ~, , r-: , ~ V ( R ' .? --~ z~ (~ cr -~ (~ ~ ' - v~ .. ~i V -; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GreenPoint Credit, LLC, Plaintiff, CIVIL DIVISION No. 01-4771 Civil v. Richard B. Howland and Penny L. Howland, ~'~ Defendants. PRAECIPE FOR WRIT OF POSSESSION To the Prothonotary, kindly issue Writ of Possession in the above matter and direct the Sheriff of Cumberland County to: 1. Deliver possession of the following described property to GreenPoint Credit, LLC: 1999 Titan Riverbirch Manufactured Home, Serial Number 19990653924AB. 2. Inform Richard B. Howland and Penny L. Howland that they have ten {10) days to remove personal items. 3. After ten (10) days a motor truck will transport the 1999 Titan Riverbirch Manufactured Home to a predetermined area or the Plaintiff will secure the Mobile Home with a new lock for later transport. 4. Levy upon any property of Richard B. Howland and Penny L. Howland remaining after the above-mentioned time period and sell their interest therein. Erin P. Dyer, Esquire PA ID Number: 52748 Attorney for GreenPoint 2021 Murray Avenue, Suite B Pittsburgh, PA 15217 (412) 422-8975 O c o ~' ~~ ~~~ c c c ~ I ~ r~ ~~ ,`' C _ ' ` ~I -. _ ~ ~'f C ~ ~ ~ti ~~~~- :~ ~ ~ ~. ~~ ~ v ~ gg~ -~3 r~ ,:_, ` '~. u _ r» _ ~ ~ ~ - ~E. -~ . `-- ~=; c.: .~ ~- ' C-I 1J ~ WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.) GreenPOint Credit, LLC vs. Richard B. Howland and Penny L. Howland COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Ctnnberland IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-4771 Civil Term No. Term Costs Atty. $ 127.15 Pl'ff (s) $ Prothy. $ 1.00 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 being: (Premises as follows): 1999 Titah Riverbirch Manufactured Hatte Serial Ntunber 19990653924AB 101 Rustic Drive Shippensburg, PA 17257 Plaintiff (s) (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. Curtis R. Long Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Date October 1, 2001 ~_ ~~ ~ ~~ (SEAL) Deputy ~~, . . ~,~~_ O p C"l t7'~1 ti - Yi e_.._ N `` 4 ~ G'~ ~ Cj ~ .:.. --~ --- - _e rY ~~ `-'-~ G't d'TI `+1 5 O N Ts ~o "1 Q' (D y (D -~ 0. O- ~roN ~ N~ o Nara ~P UI ~ N ~ ~ ~~ ~ '-h U~ ~ C p b G G w N (D ~ F' ~ ."y., J -+~ G N r~F v (D ro By virtue of this writ, on the I caused the within named ~ b b '~ O O .'"'y y ~ .., ~. -~"n `.< n O b9 fH b9 b9 J N O N have possession of the premises described with the appurtenances, and O O m to Th;s action returned STAYED, No Action Taken, as per Atty on 10/12/01 Sheriff's Costs: Advance Costs: 150.00 ~errt~~, @c~ts: 63.90 Potux3ac~ 1.25 86.10 Potary 1.00 Refunded to Atty on 10/15/01 -- - is ~Su~ge 30.00 ~ y 63.90 ~~ Sworn and subscribed to before me this ~ ` ~ ~ =-, day of ~~l.~r~u-Q~.~ , ~ f ~ ('~ Sheriff y Prothonotary ~~ 3w339 i ~~~~~; rte. j ~ ~roz n~ c~ ~ z ~-] ~ x ~ !t7 ~ rtr ' ' o ~ n ~O 77 i x~ Cry d~,o r• E ~ d7 '~ ' ro ~ ma ~ ~ , ~+ b ~ < rt ~ n o~ ~ ~ DI C ~ a ~ ~- ~ N j ~ r1 ' O P 1 ~ ~ ~ C ~ Z ~ N ~' J day of