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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
GreenPoint Credit LLC, No.
Complaint in Civil Action - Replevin
Plaintiff,
Filed on behalf of:
GreenPoint Credit LLC
V.
Counsel of Record for this Party:
Erin P. Dyer, Esquire
Robert E. Garlin and Sally A. Garlin, PA ID Number: 52748
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
Defendants. (412) 422-8975
L%GreenPofnttGedin. RobeffiUmpd
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit LLC, ) CIVIL DIVISION
Plaintiff, ) No.
V. )
Robert E. Garlin and Sally A. Garlin, )
Defendants. )
NOTICE
You have been sued in court. If you wish to defend against the claims set forth
in the following pages, you must take action 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.
Court Administrator
Cumberland County Courthouse
4" Floor
Carlisle, PA 17013
(717) 240-6200
UoreenftnWadin, Robert%CM.wpd
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit LLC,
Plaintiff,
CIVIL DIVISION
No. 99 - G /9G ecu< p T1 ` "`'
V.
Robert E. Garlin and Sally A. Garlin,
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, 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. Robert E. Garlin and Sally A. Garlin, hereinafter referred to as "Defendants,"
are individuals whose last known address is 23 Big Spring Terrace, Newville, PA 17241.
3. On or about October 26, 1995, Defendants purchased a 1988 Fleetwood
Carriage Hill Manufactured Home, Serial Number PAFLJ22A00018CG, (the "Mobile
Home"), from Royal Finance of Pennyylvania, 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."
L %GreenPolnt%Gsf ln, RoberttCM.wpd
4. Seller assigned its interest in the Security Agreement to Bank of America,
FSB ("BankAmerica"). BankAmerica perfected its security interest in said Mobile Home
by having an encumbrance on the title thereto. A true and correct copy of the Certificate
of Title is attached hereto as Exhibit "B." BankAmerica assigned its interest In said
Security Agreement to Plaintiff, GreenPoint.
5. Plaintiff avers that the approximate retail value of said Mobile Home is
$26,000.00 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 September 30, 1999, the Defendants' payments of
Interest and principal were in arrears in the amount of $657.49. Pursuant to the
Acceleration Clause in the Security Agreement the amount outstanding as of September
30, 1999, is $25,718.89.
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;
LAGreenftinl%Gsdin, Robert%CM.Wpd
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 order to bring 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 interalia, 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 11 - 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.
r?
iu
L:WreenPointlGerlin, Robert%CM.wpd
WHEREFORE, Plaintiff, GreenPoint Credit LLC, requests:
a) judgment against Defendants in the amount of $25,718.89 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?. Dyer, Esquire
PA ID Number: 52748
Attorney for GreenPoint Credit LLC
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
LAGreenPoinWarlin, RoberttCM.wpd
VERIFICATION
Don Turosik, Collection Manager, and.duly authorized representative of GreenPoint
Credit Corp., 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.
Don Turosik
Collection Manager
GreenPoint Credit Corp.
L OsemPoNIGenerarNERIFICA CM wp0
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cEF-=C-1555 16: c ;FEET P-:ItJ '_FEi i T c1 .tl: .7: !Z-7 F.CE le
INSYLVANIA MH FIXED RATE CONTRACT
TAIL INSTALLMENT CONTRACT :FOa, !!!, I LOAN PLAN F01
d SECURITY AGREEMENT oFFla :: OFFICE NUMBER 79275
`i .:. `•IoraLER No. 750218 I
i ONLY;! ?;?'? Acl:rr'r. No.: •15 3co ? ? 7
NAME ROBERT E. GARLiN _
(ER(S(: NAME SALLY A. GARLIN _
NAME
NAME rourtrGL1•? ERL.=.NO
Or 3
eas. 163 BIG S?RiNG TERII.CE err `+cS1nJ._:c STATt.7A tm 17241
r?oht'717/771 4724 1, ctc•15$ 1%8•:C•4941 180.54.4448
rostOLOCATiOtigPtM UPACTUntomorAl 23 BIG S?RIY.0 a= ?r.C3 ",:--= PA 17244
.me" or "us" mans all caspns who sign this contract as buyer o• Cc.buyil ?o-Vv end severely, and or Ntwr' means the sailor and
assignee. This contract will be submitted to the Creditor indicate* below. at a :eel office end if aco,evi d. A will be assigned to thet
ditof. On the date of this contract I buy from you on a credit mle bas ro manufactured home doccriosd below. together with
ishinge, equipment appliances and accessories included in the manufactured nomo at the time of purchase (celled "Manufactured F'ome").
?DITOR:BAN W11ERICA HOUSING SERVICES, A ::VISION 0? BANK 0: AMERICA, FSH
I
escriptlon of _
snufactured mActnAME' FLEETWOOD VrCr C.43RI::3t HT_L? I
?
ems: YEAR: 88 vein Ulm 8 LtBdTH 60 if vAoTH. 28 If
SenuL ?AFLJ22AB00018CG
•• RIM t"_'" SERIAL 14;A15111 ?'CA STRIALUUrAatIR
I
AODITIONAL i
ACCESSORIES
WO FURNISHINGS.
WISE TO PAY: I promise to pay you the Uroe d E¦lance shcwr in (its- 51 with ,mil at the rata of
12.C0 %oar
• until the debt is fully paid. I'll pay this amount in installments as Mown in the pavr-ll scbadcle cash monthly payment will be spoked as
s scheduled due date. If no interest rata is disclosed above. the into-is: rata t tie Annual oarCari pets shown below.
ANNUAL
PERCENTAGE
RATE
The costal mytredit as
a early fate
12.00 st
FINANCE CHARGE I Amount Financed Total of Payments
7haamounto•arxd Troamount I•rwllnave
The dollar amount Its provided to ma a• o+ pad after I hart made all
credit will cost me r-v behalf c4imenls as sohedultd
$ 33,1C9.6C 5 28,535.CC S 61,644.60
Total Sale Price
The total cost of my
pumnius on credit
rrcludirg my down
payment or
s 1.6C2.0C
w contract 4nna or atlpiparyl In onnaUan r umoar of ;; .:rnmounroi •''
.
but nonP+Vmant. tlafaul4 sauna rPeynehla -' , PayTrara : "'A^enpaynaniaM Cu.-
_.,
:y .
oaymenun full t tofa the echedUlad
its. and oreasyment nUda aril 180
CAy...;. .'
S 342.2' vo^!n Ca n-.r f+ll ' r
y G i 19 1
r•Nba. .... ..
q.Ymurt:i $ . C C I Vo^ln y bag-111r; 19 _
sip rtment If I pay dK wily. I wit not aCt:adLLle? S E C :!on!n y, bagu•ning . 19
rve to pay a penally. but I will not to
filled to afalund at ma pr•pntl Rw•da l
-
will.fle:'! t;
.
S
='•
j
einnm
:, rtonihrf. bG o
9
, r^
urea. d any. .... .
ieumy: I give yoj a security intemst in. X ire goods or p'apsny temp pee :r axed -Nei popsMyI=Isd &I
Y Charge; It a payment is mom than 15 days lee. I will be o'argec 't at ins u,P4.4 amount of s..cn Cayman!, not 1: ancied
s 5.00
Aumphon: $*means buying my hbnuiaclwrad 1•oma may. undo cenam caLry Lyrcu to !a atA-a tie mmunder of the contract on We
anginal terms.
'0SO1!W PA _ EXHIBIT "A"
OBL.._ Security Agreement
SEP-70-1SSS IE:°S GFEEI.PCIt.T CFEi l" c1
..ITEMIUTIOH:OF'7XMOUNT•.FINANCED r=
-ash Price (Incl.Sales Taxof3 CC ) 1 29,8CC.OC
I. Cash Downpayment S 1, 6 0 2. 0 0
b. Trad?In (Veer, Make. Madmi)
Length Width
Grow Value $ . OOlims S . 00
Ow. . W'.011
Not Tradaln Value S • CO
Total Downpeymant $ 1, 6 02 . CC
Unpaid Balance of Cash Price (1 minus 2) S 2 8 , 19 E . C 0
Amounts psid to others on my beheiF.
a. TolneuranceCompariea
(1) PropeM Insurance $ 317 . CO
(2)Cra4itLifeinsurance S 00
b. To Public Officials:
(1) Certificate of Title S 15.10C
(2) FILING F8'c°.t 5.0C
c. To Sailor
For: S CO
Inw? /w? Ciugq
d. To
For:
S CC
.00
a. To:
For:
$ CO
Total(a - b -c-d - a) $ 33'7.0C
Unpaid Balance (3 plus 4) $ 28,535.00
Prepaid Finance Charge S O C
Amount Financed (S minus 6) S 22, 53:. CC
;EPTED. The foregoing contract is hereby assigned under tna terse
of the Asngnm i nt on pegs 4
""ROYAL FINANCE OF PEN-NY5LVA_N:TA
.tR 3
RSS
4701 DEVONSIRE ROAD ST? 10:
FiARRISBURC, PA 17IC9000C
EMS I
IATUNL OQ?M,%_
ERs ^ 1 -
F W `
41: E^cZ F.C7 IC
PROPERTY INSURANCE: Propertv Insurance on the. Many.
4ctured Home is required to- the term of this contract. I have
the ,ght to cnooso the person V+rougn whom it is obtained
By merging Ir, aopropriate time below. I elect to buy the
avenge ind Gated from you for the term and oremum
shown
Type of Insurance Term Premium
Broad Fpm. Comp Ci:05 S _ .00
X Mobils Moms Owners 12D:OS S 317 . 0 C
S=RS CXT3T S
L'ABILMY' INSURANCE COVERAGE: FOR BODILY INJURY AND
P1O.E=-Y :AMAGe CAUSED TO OTHEPS IS NOT INCLUDED
LNLESS MOEILE ROME OWNERS INSURANCE IS INDICATED
IN THE PROPERTY INSURANCE SECTION ABOVE.
CREDIT LIFE INSURANCE: Credit Life Insara,ce is not
reowrad for ttii::o,troct or a factor in its approval If I idect
Crean Lib Insurance. the name(s) of the proposed inwrod(s)
are
Prooosso ns.nd
P,opcsodlnsured 1
(Only spouoa can be insured,olnt y )
Ths insurance may not pay off all of my debt sna the exact
amount of coverage is shown on my policy or certificate. My
ngnature ird.eatee my olectlo, to obtain Credit Life Insuienee
coveregs or the torn, and orsmium shown
Type of Coverage Term Premium
_ Single S
:olnt S
Cate
Cate
' or•n.e
(It;aint coveruge allired, both prooeted insureds must sign )
If you do not meet your contract obligations, you may bee your
manufactured home.
Notice to Buyer: Do not oign this contract in blank. You are
ontitled to on exact copy of the contract you sign. Keep it to
protect your legal rights.
4uvlxis) V u aNal ^ ; f
..._:Y A . /S. AR:.
CATS 01 IMIS:0P.TPA:• ' .1!
3REE TO ALL THE TERMS ON ALL PAGES-OF THIS RETAIL INSTALLMENT CONTRACT AND ACKNOWLEDGE RECEIPT OF
O PLETED COPY OF THIS CONTRACT. I,
c r
1311•sws or twsn tSaGl+va e' Cnavw•)
4524224 PA ?npt 2 or s
SEF-20-1599 1e:`? GcEE?,l`CI1. :FE:IT 41: E-_ c: P.09 I^
ADDITIONAL TERMS AND CONDITIONS
CURITY INTEREST: I grant you a security interest under the Uniform Commercial Code in (1) the Manufactured Home and in all
sds that are or may hereafter by operation of law become accessions to it, (z) any refunds of unearned insurance premiums
snood in this contract, and (3) all proceeds of such Manufactured Home and accessions. This security interest secures payment
I performance of my obligations under this contract, including any additional debt arising because of my failure to perform mv
igations under this contract, and includes any contractual extensions, ronowals at mud.fications If this contract is secured by a
-rtgege or deed of trust on my real estate. then this security agreement is not exclusive. Your tights and remedies under
i contract and any mortgage or deed of trust executed herewith are cumvlativo, but my right to a Notice of Default and Right to
to Default shall not be affected by any inconsistent provision of any mortgage or deed of triist. My execution of this contract
lstrtutes a waiver of my personal property and homestead exemption rights to the personal and real property herein described.
EPAYMENT: I MAY PREPAY THIS CONTRACT IN FULL OR IN PART AT ANY 71ME WITHOUT PENALTY. BUT 1 WILL NOT BE
TITLED TO A REFUND OF THE PREPAID FINANCE CHARGE, IF ANY.
OPERTY INSURANCE: I am required to insure the Manufactured Home against physical damage for the term of the contract at
expense. The minimum coverage will be Broad Form Comprehensive in an amount equal to the lessor of the actual cash value
the Manufactured Home or the remaining unpaid balance I owe from time to time on this contract The insurance policy will
train a loss payable clause protecting you (as your interest may appear), and provide for 10 day notice of cancellation to you, I
to the right to choose the person through whom the property insurance policy is obtained. If my insurance coverage expires or
saneelled prior to payment in full of this contract. I must obtain no loss than the minimum coverage at my expense for the
naining term of the contract. Should I fail to maintain insurance coverage, you may, but are not obligated to, obtain the
iimum coverage and such additional coverage as you may reasonably require. If you do so, you will notify me of that fact and
t the cost, plus interest at the contract rate, will be added to my debt. I will repay such amount during the term of the policy in
manner requested by you. I understand that the insurance premiums may be higher if you must purchase the insurance than
7ht be the case if I had purchased the insurance, and that you may purchase the insurance from an affiliated company who
y receive a profit for this service.
TE CHARGE: I agree to pay a late charge tar late payment as set forth on the front of this contract. Only one late charge will be
de on any delinquent installment regardless of the period for which that installment remains in default After this contract
lures, whether by acceleration or otherwise, I will not be charged a late charge.
ENTS OF DEFAULT: 1 will be in default under this contract it: (a) I fail to make any payment when due, (b) I fail to timely make
ital payments, or to pay other charges and assessments, rotating to the real property and/or facility on which the Manufactured
me is located; (c) I violate rules or regulations relating to the facility where the Manufactured Home is located: (d) I fail to keep
i Manufactured Home in good repair and condition, as you may reasonably determine; (o) I remove the Manufactured Home
m the address shown on this contract unless I notify you in advance and recaivn your written consent: (f) I sell or attempt to sell
Manufactured Home without first obtaining your written consent: (g) I allow the Manufactured Home. if it is personal
sporty, to become part of any reel estate; (h) I encumber or abandon the Manufactured Home or use it for hire or illegally: (i) I
to promptly pay any taxes and other lions and encumbrances on the Manufactured Home; and/or (j) I fail to do anything else
sch I have promised to do under this contract.
ITICE OF DEFAULT: If any of the above specified Events of Default have occurred. you may do whatever is necessary to correct
default. You will, except as set forth below, first give me a Notice of Default and Fight to Cure Default before you accelerate
yment of the remaining unpaid balance I owe you or repossess or foreclose on any proport/ which secures this contract
a Notice will tell me what my default is and how I can cure it. You are no% required to send me this Notice when (1) you have
lady sent a Notice twice within the preceding one-year period, (:) 1 have abandoned or voluntarily surrendered the
inufactured Home, or (3) other extreme circumstances exist.
IRE OF DEFAULT: I may cure a default at any time before title to the Manufactured Home is transferred from me, which will be
'east 45 days after receipt of the notice of default. To cure a default. I must pay (a) all amounts which would have boon due in
absence of default and acceleration: (b) the attorneys fees set fortf. below; (c) any late charges that are due; and
reasonable costs which are actually incurred for detaching and transporting the Manufactured Home to the site of sale. I must
o perform any other obligation I would have had to perform in :he absence of default.
MEDIES UPON DEFAULT: If I do not cure the default. you may do either or both of the following at the and of the notice
•iod: (a) you can require me to immediately pay you the entire remaining unpaid balance of the contract plus accrued interest.
(b) you can repossess the Manufactured Home. If you are not required to send me the Notice of Default and Right to Cure
fault. you will have those rights immediately upon my default. Once you get pussession of the Manufactured Home, you will set;
If the amount from the sale. after expanses, is less than what I owe you. I tJII pay you the difference except as otherwise
ivided by law.
TORNEY FEES: If you hire an attorney who is not your salaried emplo•/ee to collect what I owe under this contract or to got
session of the Manufactured Home. I will pay your reasonable attorney's foes, provided that prior to commencement of legs:
Ion such fees may not exceed $$50.00 and further provided that no attorney I fees may be charged prior to my receipt of the
ice of default.
valCaea /4 PACE ] Or a
-rr .. JCS
SEP-70-ISSS 17: CC GFEEI.FCIr.T -;;Ei 1T el .IC °20' P.07- 11C
)THER TERMS AND CONDITIONS: I agree: (a) to pay with my monthly instalhnunls, it requested by you to do so, the estimated
.mount necessary to pay yearly taxes, assessments and insurance premiums that will become due within the next twelve month
ieriod: (b) to pay you a transfer fee, if I sell the Manufactured Home, unless such too to prohibited by law: (c) to pay interest at the
ontract rate on the remaining unpaid balance plus accrued interest from the data of maturity until paid in full: (d) to reimburse
cu. immediately upon your demand. with interest at the contract rate, the amount of funds you actually advance on my behalf to
:orreet my default: and (e) that if I am married, and residing in a community property slaty. both my community property and
eparate property will be liable for all payments due under this contract.
:REDIT INFORMATION: You may investigate my credit history and credit caracire in connection with opening and collecting my
idcounl and share information about me and my account with credit reporting agencies You may gall or otherwise furnish
nformation about mo. including insurance information, to all others who may la.wtulhy receive such information. You may furnish
pacific information about the Manufactured Home and any Insurance policies on the Manufactured Home to any insurance agent
o enable such agent to quote premiums to me and solicit my insurance bumne;c
LSSIGNMENT: You may assign this contract to any person or entity All rights granted to you under this contract shall apply to
my assignee of this contract.
NAIVER: Waiver of any default shall not constitute a waiver of any other default No term of this contract shall be changed unless
n writing and signed by one of your officers. This contract, and any mortgage or dood of trust executed by me in connection with
his contract, is the entire agreement between us and I agree that no ore: or implied representations have boon made to
nduce me to enter into this contract
/ALIDITY: Wherever possible each provision of this contract shall be interpreted in such manner as to be effective and valid under
ipplieable law, but if any provision of this contract shall be pichibited by or invalid under applicable law, such provision shall be
neHective only to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or the remaining
irovisions of this contract. This contract shall be of no effect until and unless signed by me and you. In no avant shall any
charge under this contract exceed the highest amount allowed by applicable law It any excess charge is received, such excess
:hall be refunded or applied to the amount due
(See Other Pag• for Consumer's and Seller's Signatures)
NOTICE
ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE
DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR
WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID '
BY THE DEBTOR HEREUNDER.
ASSIGNMENT BY SELLER
'0 CREDITOR INDICATED ON OTHER PAGE ("Creditor")
With respect to this retail installment contract ('contract") signed by one or more buyers ("Buyer"). SELLER represents and
-warrants that: (1) Buyer's credit statement submitted herewith is completely accurate unless otherwise specified: 12) Buyer was
agally competent to contract at the time of Buyer's execution of this contract: (3) this contract arose from the bona fide sale of
he merchandise described in this contract: (4) the downpayment was made by Buyer in cash unless otherwise specified and no
tart thereof was loaned directly or indirectly by Seller to Buyer; (5) any trade-in, or other consideration, received as any part of the
lownpayment is accurately described on the other page. and has boon valued at its bona fide value, and any amount owed on
iueh trade-in or other property is accurately described on the other page and has been paid off by Seller prior to or
:ontemporaneously with the assignment of this contract to Creditor, (6) there is now owing on this contract the amount sot forth
terein: (7) this contract and any guaranty submitted in connection herewith is in all respects legally enforceable against each
turported signatory thereof: (8) Seller has the right to assign this contract and thureby to convoy good title to it (9) In the event of
my claim or defense asserted by any Buyer, or any heirs or assigns of Buyer, with respect to the Manufactured Home or other
troperty or consideration transferred pursuant to this retail installment contract. Seller agrees that it will indemnify and hold
'reditor harmless from all such claims and defenses as well as from all costs reasonably incurred by Creditor in connection
herewith, including but not limited to reasonable attorney fees and court costs: and (101 in accordance with the Fair Credit
loporting Act Seller has notified Buyer that this contract is to be submitted to Croditor.
Forvalue received, Seller hereby assigns to Creditor all its rights, title and interest in this contract and the property which is
he subject matter hereof and authorizes Creditor to do everything necessar/ to collect and discharge same All the terms of any
willing written agreements between Seller and Creditor governing the purchase of contracts are made a part hereof by reference.
t being understood that Creditor relies upon the above warranties and upon said agreements in purchasing this contract.
150tlaZ42a4 PA east a ca 4
SEF-:0-15S'? 16:56 rFEE1.FC1l.T :FEC I T 11: F.O: 10
.:5i ?'• OEPARTN-NT OF TRANSPORTATION
CERTIFICATE OF TITLE FOR A VEHICILE
-1-112, 037
953390015003360-001
PAFLJ22AD0018CG 1 381 FLEETWOOD
?t+ta enr,.u•a..,.wt• I .u. I ••..I C. ,l. nl
MH ! 0 I I 112/18/95
a00rhw I C.I ifu ;a. n.a r.rtt :'+•! :]:I..i:a 7111
11/29/88 12/18/95 I 12194001
4tlh Tap p•r(;hS1t4 ,\,.CD. nI:•• Ou:•
41301804004 GA
•I:l Lau11. _
EXEMPTI 4
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ODOMETER DISCLOSURE EXEMPT BY FEDERAL LAW
JOINT OWNERSHIP WITH RIGHTS OF SURVIVORSHI
.Iamlaa a\«1.n
ROBERT E L SALLY A ----
GARLIN
23 BIG SPRING TERRACE
NEWVILLE PA 17241
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BANK OF AMERICA FS3
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EXTON PA 19341
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Tel (724)5-.3.1813
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August 26, 1999
ROBERT E. CARLIN
SALLY A. CARLIN
TER GtreenPaint lvJ` Credit
2S BIG SPRING 1N0 T
NEWILLE PA 17261.9107
RE: Manufactured Noma tosn • Account eCW007S3CC7a0000:
NOTICE Of INTENTION TO ACCELERATE, 9MNLV LEGAL ACTION Oe REPOSSESS
I
You are now in default on your Menufacturtd hc..e Loan Contrac:. If y:u C:rrect the defeult, you may
continue with the contract as though you did not default. Your default c:ntists of failure to rake tiroly
payments of one or more installments as agreed to In the tern of the tontract.
Thirty-re (31) days otter the date at this notice, we may have the right to crmenae legal a:tion and
repossess your manufactured hone.
Cure of default: Your may cure your default by raking payrent in the anvmt indicated bolou:
Past Due Monthly Payment(s) s 357.53
Late chargets) s 10.00
Total Due Now S 377.63
Creditor's rightas Any partial pyment of the ecnunt due whi:h is roceived by us Witt be applied to your
account. You will need to pay the full amount by the date Indicated abovt In order to cure your default. If
you do not correct your default within 31 day: due from the postmarked date of this notice, we ray
exercise our rights against you under the law by acccleratirg your debt Ord either reoestec:in9 your
manufactured home or, if necessary, bringing a court action to obtain p:sse:sien of your manufactured
home.
If we elect to exercise our rights against you by rtpascession of trt NM.!a:tUrcd h:rs ycu may, at any
tithe before we tall or otherwise dispose of tee manufacturd here or on-or into a contract for It: sale or
other disposition, (which shell be at least 65 days after postmark cf this retice), redetn tie manufactured
home by paying us all amounts due plus experses reasonably incurred by us in detaching and trersoorting
the manufactured hone to the Site of the fate and our rca:enabto altoney't fees, to the extent :tFMittfd by
law, plus court costs.
If you have any Questions, write to us at the aed-ess above o• call -e at tht phone nc*bsr listed above
! between the hours of 0:00 a.m. and 5tM p.n., Monday through Friday.
If this default was caused I•/ your failure to rake o parent ar paymentt, rd you wan: 10 pay ty rail,
please send a check or randy order. oa net send rah.
Manager
CC: File
If any additienal regular payment becomes doe during :his due period, this :ayrent mst ales be paid in
order to avoid any further default. this correspondenee 11 on attvrt to a deft and dry
Information obtained will be used for that purpose.
PA (1:6)
EXHIBIT "C"
Notice of Intent to Repossess
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06196 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GREENPOINT CREDIT LLC
VS.
GARLIN ROBERT E ET AL
RICHARD SMITH , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - REPLEVIN was served
upon GARLIN ROBERT E the
defendant, at 14:43 HOURS, on the 18th day of October ,
1999 at 23 BIG SPRING TERRACE
NEWVILLE, PA 17241 CUMBERLAND
,
County, Pennsylvania, by handing to SALLY A. GARLIN
a true and attested copy of the COMPLAINT - REPLEVIN ,
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
18.00
8.68
00 -?
8.00 Fn IP131fidH , 5
-10/19%199
by
Sworn and subscribed to before me
this day of
19 99 A.D.
= a TTt
CASE NO: 1999-06196 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GREENPOINT CREDIT LLC
VS.
GARLIN ROBERT E ET AL
RICHARD SMITH , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - REPLEVIN was served
upon GARLIN SALLY A the
defendant, at 14:43 HOURS, on the 18th day of October ,
1999 at 23 BIG SPRING TERRACE
NEWVILLE, PA 17241 CUMBERLAND ,
County, Pennsylvania, by handing to SALLY A. GARLIN
a true and attested copy of the COMPLAINT - REPLEVIN ,
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00 So answers:
^D??
.00
8.00 ACfilbTd38-FC17fT
-10/19%199
by
Sworn and subscribed to before me
this S?L' day of
19 C)cj A.D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
GreenPoint Credit, LLC,
Plaintiff,
CIVIL DIVISION
No. 99-6196
V.
Robert E. Garlin and Sally A.
Garlin,
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 Robert E. Garlin and Sally A. Garlin 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 October 18, 1999 and their answer was due to
be filed on November 8, 1999.
Attached as Exhibit "Xis 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
November 16, 1999, which is at least 10 days prior to the filing of this Praecipe.
Please enter judgment for possession of the 1988 Fleetwood Carriage Hill
Manufactured Home, Serial Number PAFLJ22A00018CG, that being the relief
demanded in the complaint.
Erin yer, -squire
PAID Number: 52748
Attorney for GreenPoint Credit, LLC
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
Attachments: Ten Day Notice
Affidavit of Non-Military Service & Last Known Address
w _? N
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit, LLC,
Plaintiff,
V.
Robert E. Gariin and Sally A. Gadin,
Defendant.
CIVIL DIVISION
No. 99-6196
Via Certified Mail #Z 047 928 964 and
Certificate of Mailing
Robert E. Garlin
23 Big Spring Terrace
Newville, PA 17241
Date of Notice: November 16, 1999
Via Certified Mail #Z 047 928 966 and
Certificate of Mailing
Sally A. Gadin
23 Big Spring Terrace
Newvllle, PA 17241
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 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:
Court Administrator
Cumberland County Courthouse
4" Floor
Carlisle, PA 17013
(717) 240-6200
L0,01P014G61A Ro MN -Pd
Fop . Dyer, Esq re ?? ,o/ '777 35
Attorney for Plaintiff
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
?J J
0.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
GreenPoint Credit, LLC,
Plaintiff,
V.
Robert E. Garlin and Sally A.
Garlin,
Defendants.
CIVIL DIVISION
No. 99-6196
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 23 Big Spring Terrace, Newville, PA
17241, 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 unswom
falsification to authorities.
Erin PIF)y r, squire
PAID Number: 52748
Attorney for GreenPoint Credit, LLC
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
°: r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
GreenPoint Credit, LLC, ) CIVIL DIVISION
Plaintiff, ) No. 99-6196
V. )
Robert E. Garin and Sally A. )
Garlin, )
Defendants.
Robert E. Garlin Sally A. Garlin
23 Big Spring Terrace 23 Big Spring Terrace
Newville, PA 17241 Newville, PA 17241
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 Cumberland County
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
GreenPoint Credit, LLC,
Plaintiff,
V.
Robert E. Garlin and Sally A.
Garlin,
Defendants.
A6j /7-14V
CIVIL DIVISION
No. 99-6196
PRAECIPE FOR WRIT OF POSSESSION
To the Prothonotary:
Kindly issue Writ of Possession in the above matter.
Erin P. Dyer, squire
PA ID Number: 52748
Attorney for GreenPoint Credit, LLC
2021 Murray Avenue, Suite B
Pittsburgh, PA 15217
(412) 422-8975
Q u,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
GreenPoint Credit, LLC,
Plaintiff,
V.
Robert E. Gadin and Sally A.
Garlin,
Defendants.
CIVIL DIVISION
No. 99-6196
WRIT OF POSSESSION
COMMONWEALTH OF PENNSYLVANIA )
SS
COUNTY OF CUMBERLAND )
To the Sheriff of Cumberland County:
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:
1988 Fleetwood Carriage Hill Manufactured Home, Serial Number
PAF W 22A00018CG.
2. You are directed to inform Robert E. Garlin and Sally A. Garlin thatthey
have ten (10) days to remove personal items.
3. After ten (10) days a motor truck will transport the 1988 Fleetwood.
Carriage Hill Manufactured Home to a predetermined area or the plaintiff will secure
the mobile home with a new lock for later transport.
4. To satisfy the costs against Robert E. Garlin and Sally A. Garlin, you are
directed to levy upon any property of Robert E. Garlin and Sally A. Garlin remaining
after the above-mentioned time period and sell their interest therein.
(Prothonotary/Clerk)
(Deputy)
Seal of the Court.
Date '199
_
L%GreenPolnf%Gerlin. RoberBDJ VVP.wpd
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit, LLC, ) CIVIL DIVISION
)
Plaintiff, ) No. 99-6196
V. )
Robert E. Garlin and Sally A. Garlin, )
Defendants. )
a3 9?9 S?til?-7 `76Aabcc...
w?? ((L ,pig aaclt
PRAECIPE FOR WRIT OF POSSESSION
To the Prothonotary:
Kindly issue Writ of Possession in the above matter.
Enn yer, -squire
Attorney for GreenPoint Credit, LLC
fly
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GreenPoint Credit, LLC,
Plaintiff,
V.
Robert E. Garlin and Sally A. Garlin,
Defendants.
CIVIL DIVISION
No. 99-6196
WRIT OF POSSESSION
COMMONWEALTH OF PENNSYLVANIA )
SS
COUNTY OF CUMBERLAND )
To the Sheriff of Cumberland County:
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:
1988 Fleetwood Carriage Hill Manufactured Home, Serial Number
PAFLJ22A00018CG.
2. You are directed to inform Robert E. Garlin and Sally A. Garlin that they have
ten (10) days to remove personal items.
3. After ten (10) days a motor truck will transport the 1988 Fleetwood Carriage
Hill Manufactured Home to a predetermined area or the plaintiff will secure the mobile
home with a new lock for later transport.
4. To satisfy the costs against Robert E. Garlin and Sally A. Garlin, you are
directed to levy upon any property of Robert E. Garlin and Sally A. Garlin remaining after
the above-mentioned time period and sell their interest therein.
(Prothonotary/Clerk)
(Deputy)
Seal of the Court:
Date _
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CO\lIIONWEdtL.TH OF PE-NNSYLVA,NIA:
COUNTY OF CL'NIBERL.A-W:
CUMBERLAND
To the Sheriff of __________________
Att y -------
PPff (si
?torhv. -__-__
-------------
-------------
s--IJLQale--
--- s------------
---- S-°-1-00--
Counry, Penna.
(I) To satisfy the judgmen: for possession in the shove marer you are directed :o deicer possession of the
following descr.%ed property w:
GreenPoint Credit, LLC
-----------°-----------------
------------------------ Plaintiff ;s,
being : 1. P.^etnises as foilmm) :
6-Git+il------------ -, Term 19------
.No. -------------------------------- Term 19------
Costs
1988 Fleetwood Carriage Hill
Manufactured Home, serial Number
PAFLJ22A00018CG
(^-i To satisfy :he casts 13aimi the defendant (0 you are directed to :evy upon u:;+ ?roper.) of :he deien-
dant ts) and soil his her or their; interest therein.
DDecomber 8, 1999
Date -------------------------SEAL)
( rte!.
jectment Proceedings PRCP 3160 - 3165 etc)
IN THE COURT OF CO.NINION PLEAS OF
- Ct:%IBERLAND COL\-TY, PE.. Slt 1VA -N 7A
CURTIS R. LONG
------------------------------------------°°----•
Prothororar... C.rt...og ?:ess C--u: of Cumber,=d
Cou Pca?
ty
WRIT OF POSSESSION (Ejectment Proceedings PRC P 3160 - 3163 etc)
GreenPoint Credit, LLC IN THE COURT OF COMMON PLEAS OF
•------------------------------------------- CUMBERLAND COL'N'TY, PEN-SSYLVA.N'IA
VL
1~
Robert A. and Sally A. Garlin
---------------------• .
- B g Spring Terrace
Newville PA 17241
------------------------------------------
Yo. ------------Term 19.__.__
\o. -------------------------------- Term 19------
Costs
At: -------------------------------
Pl'ff (s' ----------------------------- $------------
Ptvrhy. S-°1: 00
------------------------------
COMIIONWE.4LTH OF PENNSYLVANIA:
COUNTY OF CUNIBERL.AND:
CUMBERLAND
To the Sheriff of ........:.........
... County, Penna.
(l) To satisfy the judgment for possession in the above mar:er you are directed :o deliver possession of the
following deectised psvpetry m:
GreenPoint Credit, LLC
----------------------------------------------------------------------------------------
Plaintiff 's,
being : i. Premises as foi mw) : 1988 Fleetwood Carriage Hill
Manufactured Nome, Serial Number
PAFL322A00018CG
(^.; To sarisfy :be ^.asts against the defendant (s) you ire directed to ;evy upon ary ?toper:/ of :he deien-
dant ?s; and sell his her or :heir; Interest therein.
DDecembor 8, 1999
Date
_,.. (SE.?L)
CURTIS R. LONG
-------------------------------
Prorhonorar. --------------------
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GreenPoint Credit, LLC
-------------------------------------------•
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vs. ?
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Robert A. and Sally A. Garlin
------------------------- f
---??- egg Spring Terrace
Newville PA 17241
-°°--------- -------------°°----------
COINIONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
CUMBERLAND
To :he Sheriff of ------------------
IN THE COURT OF CO\IaION ?LEAS OF
CUNIBERL,%XD COL•\-rY. PEYNSYLVANTA
No..-"-61176-Giv,41------------ Term 19
No. -------------------------------- Term 19------
Costs
Act 'v S__I1,.@,10--
PVff (u ----------------------------- S ------------
Prorhv.------------------------------ s----1.00--
---------------- Counry•, Penna.
1) To satisfy -he judgmen: for possession in :he above marten you are directed ra delver possession of the
feilowing described propery rot
GreenPoint Credit, LLC
--------------°------------------------------ --------•
----°---°--------- ---- -- - -- --°- ----°- Plaintiff v
being : !Premises ss ioilowo) : 1968 Fleetwood Carriage [fill
Manufactured Rome, Serial Number
PAFLJ22A000IBCG
TRUE WPY FROM RECORD
IN TIgd1R10 W altered, I here undo set mY Wd
r?t[???._drfv ? Carlisle, P},
11 To satisfy :nc :airs against the defendant (sr you are directed to :evy -.Don as± proTrer:y of rite defen-
dant s, and soil his her or :heir; interest therein.
DDecember 6, 1999
Date ---------------------------------
(SEAL)
CURTIS R. LONG
--------------------------------------------------
Prothonotary. Camrno P
Cou , eas Caurt >i Cumberland
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GreenPoint Credit, LLC IN THE COURT OF CO\1\1014' PLEAS OF
°-------------°"---'..._ Ct-NrBERLAND COUNTY. PENNSYLVANIA
No..-"-6196-Giv^i1------------ Term 19._____
\o. -------------------------------- Term 19------
H.
Colts
Robert A. and Sally A. Garlin Atr'y, .....................°-----... S._?k@,1@._
-- -------------°--------• .
egg Spring Terrace
Nevrville PA 17241 Pl'ff rs ----------------------------- t------------
1.00
-- -----------------------------------' °ro chy..-- S_°'---.----
------------------------°
CO\11IONWEALTH OF PE..NNSYLV.'NIA:
COUNTY OF CL'SIBER:LA.W:
CUMBERLAND
To .he Sheriff of --------- ---------
-------- Coun;y, Penna.
l'- To satisfy the judgrr:en; for possession in :he above marer you are diree:ed :o deicer ;"session rf the
foilowing described property x:
GreenPoint Credit, LLC
----------------------------------------------------------------------------------------
-------------------------------------------- ----------___ Pwnrff s,
being : i.Pretnises as foilo%vs) : 1988 Fleetwood Carriage Hill
Manufactured Home, serial Number
PAFLJ22A00018CG
TRUE ("Y FROM RECooo
10 Tottpr>onlr vrtwgpt I two urn tot fay h"
I Pe
i 114, r -?-'.
To sazisiy :he wsts agairtst the defendant !ii you are directed ro :evy upon ary proper:{j?it :.he deien•
dant s; and sell his her or .heir; interest therein.
DDecember 8, 1999
Dace --------------------------SEAL)
CURTIS R. LONG
---------°----------------------------
Prothonotary Commo P:
C cas Caur, of Cumbe.l^ynd
osa Penns. ..
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By virtue of this tyrit, on :he --------------------- Jay ot ------------------------------------ 19......
I caused --he within named --------------------------------•-------------------------------------__-• :o
have possession of the premise. described with the appur.enance•• And ---------------------------------------
R. Thomas Kline, Sheriff, who being duly sworn according to
1aae,__statnc__this- writ--ic -raturaed-AFFFYEa---------------------------------•------•-----•
Sheriff's Costs: 6dxanCe_Cnst.s------- 5.1310..-Oa........
------------ °------ --- -
Docketing 518.00 Sheriffts Costs: 47.37
Prothonotary 1.00 S-.52-..63
-------•---°-------------------- --- --
Surcharge 20.00 Refund to atty on 3-7-00
Poundage------------------- 99 -------------------------------------------------------------------------
S47.37
d.
Swvrn and woscr;bed :o hriora :re :cis ?.--._.___.
day of -------•----- '
........... Ptnthonotarv
------------------------------------
C 9i e(ti;
-----------------------
DePutti 00
f• C/Z:r'173?
WRIT OF POSSESSION ( Ejectment Proceedings PRC P 3160 - 3165 etc)
GreenPoint Credit, LLC
I
23 Big Spring Terrace
Newvile, PA 17241
IV THE COURT OF COMMON PLEAS OF
CUMBERLAND COLYN, PENNSYLVA TA
---- ----------------- Term 19------
\n. ------------6196
No. ------ ik-0- ------------------ Term 19------
Costs
Act%-- -- g--- 133.18
Pl'ff rs; --------------------------- 3------------
Prorhv.----------------------------- 9--)-,QQ-----
CO\rMONMEALTH OF PENNSYLVANIA:
COU.M OF CUNIBERLA?ID:
To the Sheriff of ------- Cumberland ----------------- CounPenna.
-----------
(1) To satisfy the judgment for possession in :he above maser you are di ected to dei:rer possession of the
foilowing described property to:
GreenPoint Credit_ LLC
-------------------- ----------------------
---------------------------------- Plaintiff si
being : ! Prsmfses as follows) :
23 Big Spring Terrace
Newville, PA 17241
(2) To satisfy the costs against the defeudant 13j you are directed to :n., upon any ?roper-/ of the deirt•
dant s) and uB his h-.r or c^.cr; iatetrt themin.
February 10, 2000
Date ---------- `SZL?)
--- Curtis R_- Long______________
Prothonotary. Cam-non Pleas Cour: of Ctmtber:nnd