HomeMy WebLinkAbout08-0825IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company,
CIVIL DIVISION
Plaintiff,
V.
William L. Davis and Laura Lee
Chapman-Davis and Jamie Davis,
Defendants.
No. 0$ - W bvi ( Ie -K
TYPE OF PLEADING:
Complaint in Replevin
FILED ON BEHALF OF PLAINTIFF:
Green Tree Consumer Discount Company
COUNSEL OF RECORD:
Edward F. Voelker, Jr.
PA I.D. #55414
Cynthia M. Dornish
PA I.D. #59890
Voelker & Associates, P.C.
Firm #332
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company, CIVIL DIVISION
Plaintiff, No.
V.
William L. Davis, Laura Lee
Chapman-Davis and Jamie Davis,
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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company, CIVIL DIVISION
Plaintiff, No. Of- Pa25 Ct;,;.! -
-V.
William L. Davis, Laura Lee Davis-Chapman
and Jamie Davis,
Defendants.
COMPLAINT IN REPLEVIN
AND NOW, comes Green Tree Consumer Discount Company, by and through its attorneys,
Edward F. Voelker, Jr., Esq. and Voelker & Associates, P.C., and avers the following in support of
its Complaint in Replevin:
1. William L. Davis and Laura Lee Chapman-Davis, hereinafter referred to as
"Borrowers," are individuals whose last known address is 671 Shippensburg Road, Newville, PA,
17241-9476.
2. Jamie Davis is an individual. Jamie Davis is hereinafter referred to as "Tenant."
3. Upon information and belief, Plaintiff believes and therefore avers that Tenant is
presently residing in the Manufactured Home (as hereinafter defined) and located at 671
Shippensburg Road, Newville, PA, 17241-9476.
4. Green Tree Consumer Discount Company, hereinafter referred to as "Plaintiff," is a
Pennsylvania corporation and is duly authorized to conduct business in the Commonwealth of
Pennsylvania.
5. On or about June 4,1998, Borrowers entered into a "Secondary Mortgage Loan note,"
hereinafter referred to as the "Financing Contract," whereby Borrowers financed a 1999 Laurel
House Colony manufactured home (serial no. ACSX 11464AB) with certain furnishings, equipment,
appliances, and accessories included at the time of purchase, hereinafter collectively referred to as
the "Manufactured Home." A true and correct copy of the Financing Contract is marked as Exhibit
"A" and is attached hereto and made a part hereof.
6. It is believed and therefore averred that the Manufactured Home is located at 671
Shippensburg Road, Newville, PA, 17241-9476.
7. The Financing Contract was subsequently assigned for value to Plaintiff as permitted
by the Mortgage.
8. Pursuant to the Financing Contract, Borrowers promised to repay the borrowed
amount of $87,459.93.
9. On or about June 4, 1998, Borrowers made, executed and delivered a Open-End
Mortgage (the "Mortgage") whereby Borrowers granted a security interest in the Manufactured
Home to Plaintiff, which Mortgage is recorded in the Office of the Recorder of Deeds of
Cumberland County, in Mortgage Book Volume 1460, page 124. A true and correct copy of the
Mortgage is attached hereto as Exhibit "B" and made a part hereof.
-2-
10. Plaintiff perfected its security interest in the Manufactured Home by having an
encumbrance placed on the title thereto. A true and correct copy of the Certificate of Title for a
Vehicle is marked as Exhibit "C" and is attached hereto and made a part hereof.
11. Borrowers have defaulted under the Financing Contract by failing to make payments
when due. As of January 3, 2008, the delinquent payment amount due and owing from Borrowers
to Plaintiff is $1,829.68.
12. As of January 3, 2008, the amount owed by Borrowers to Plaintiff, not including
costs, attorneys' fees and damages for the unjust retention ofthe Manufactured Home, is $78,036.35.
The interest on said amount is accruing at the daily rate of $14.15.
13. Borrowers have failed to surrender the Manufactured Home upon Plaintiff s demand.
14. On November 2, 2007, Plaintiff provided Borrower with a Notice of Default, a true
and correct copy of the same is marked as Exhibit "D" and is attached hereto and made a part hereof.
15. Plaintiff is now entitled to immediate possession of the Manufactured Home.
16. Plaintiff is entitled to attorneys fees under the terms of the Financial Contract.
WHEREFORE, Plaintiff claims judgment for possession of the Manufactured Home or the
sum of $78,036.35, plus attorneys fees, costs, interest from January 3, 2008, and damages for the
unjust retention of the Manufactured Home.
-3-
Respectfully submitted,
VOELKER & ASSOCIATES, P.C.
Edward F. Voelker, Jr.
Attorneys for Plaintiff
Voelker & Associates, P.C.
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
-4-
i 111
,. . w
1105`BRADFORD RD, BLDG III,SUITE 200
WEXFORD, PA 15090
LENDER'S NAME AND ADDRESS
"You" means the Lender,
its successors and assigns.
TERMS FOLLOWING A ..•._, APPLY ONLY IF
CHE
WILLIAM L. DAVIS
LAURA LEE CHARM-DAVIS .
671 SHIPPENSBURG ROAD
NEWVILLE, PA 17241
BORROWER'S NAME AND ADDRESS
"1" includes each Borrower above,
jointly and severally.
DINTS.- G I q
Loan Y3
Date
Maturity Date W:1/zUlti
Loan Amount $ 67459.93
Renewal Of /A
CKED Secondary Mortgage Loan
This agreement is subject to the provisions of the Secondary Mortgage Loan Act.
For value received, 1 promise to pay to you at your address listed above the PRINCIPAL sum of
EIGHTY SEVEN THOUSAND FOUR HUNDRED FIFTY NINE AND 931100 DOLLARS Dollars $ 87459.93
XX Single Advance: I will receive all of this principal sum on . No additional advances are
contemplated under this note.
! Multiple Advance: The principal sum shown above is the maximum amount of principal I can borrow under this note.
Ondate of first advanc9 will receive the amount of 000(land valued future principal advances are contemplated.
You and I agree that I may borrow up to the rhaximum only one time (and subject to all other conditions).
Conditions: The conditions for future advances are tat advance(adv): real property appraisal i legal permits;
2nd adv: land improvement invoices, lien waivers, customer advance authorization ("CAA"); 2nd or 3rd adv:
home 6 setup & CAA; final adv: certificate of occupancy or inspection report & CAA.
INTEREST: I agree to pay interest on the outstanding principal balance from date of first advance. at the
rate of 6.75 % per year until - the principal balance is fully paid.
N/AVarieble Rate: Notice to borrower: This document contains provisions for a variable interest rate. This rate may then
change as stated below.
Change Dates: Each date on which the interest rate may change is called a Change Date. The interest rate may
change and on every thereafter.
The Index: Beginning with the first Change Date, the interest rate will be based on the following Index:
The most recent Index value available as of the date - 45 days _
before each Change Date is called the "Current Index."
Calculation of Change: Before each Change Date, the Lender will calculate the interest rate, which will be
1
I the Current Index. The result of this calculation will be rounded
The new interest
+ rate will become effective on each Change Date. Subject to any limitations below, this will be the new interest rate
until the next Change Date.
Limitations: The interest rate will never be greater than % or less than g6.
_ The interest rate will never change on any single Change Date by more than
Effect of Variable Rate: A change in the interest rate will have the effect of changing the amount of the scheduled
payments:
ACCRUAL METHOD: Interest will be calculated on a stele interest basis.
POST MATURITY RATE: I agree to pay interest on the unpaid balance of this note owing after maturity, and until paid in .
full, as stated below:
- on the same fixed or variable rate basis in effect before maturity (as indicated above).
- at a rate equal to
S iLATE CHARGE: I agree to pay a late charge on the portion of any payment made more than 15 days after it is
due equal to 5.00 OR 2.OOZ OF THE PAYMENT, WHICHEVER IS LESS.
-1ADDITIONAL CHARGES: In addition to interest; I agree to pay the following charges which _ are _ are not
included in the principal amount above:
PAYMENTS: I agree to pay this note as follows: INTEREST: I agree to pay accrued interest during the construction
period on a monthly basis on cumulative amounts advanced, and principal 6 interest monthly thereafter until
I the contract is fully paid.
PRINCIPAL: I agree to pay the principal in 360 monthly installments, beginning no later than 45 days
days after the completion of the construction funding period.
INSTALLMENTS: I agree to pay this note in 360 payments.*The first payment will be in the amount of
$1 567.26 (principal 4 interest) and will be due approx. 30 days from final disbursement. A payment of
i; 567.26 will be due monthly thereafter. The final payment of the entire unpaid balance of
principal and interest will be due 360 months from last construction disbursement.
The payment schedule is in addition to and shall begin subsequent to the construction period interest only payments.
PREPAYMENT REFUND: I may prepay all or part of this note without penalty. If I prepay in full, you will
± refund part of the finance charge.
REAL ESTATE NOTE
94 $4.1881.1893 Bw*en Sm me. Inc.. St. CI*W. MN Fam GTN-RENLAZPA 1122198
1
1
(3T-15-39-011 111/971 lnsos / of4J
5XNEA-T- "A "
DEC-31-2007 1.39FM US BANK DOCUMENT CENTER
NO.9340 P. 37
SECURITY This ry?pteiis.s w?ed?b (describe separate document by type (e.g., mortgage) and date); -44 oS .
. •.. ., _ pit '?
ANF''UNDIsBUJr?Sn PwiicNs of TIM A??bl?lr irnuNcsD 88p, 3N SHALL p ABBY,mm TO TIM PRINCIPAL RA7,
ADDITIONAL TERMS OF fin CONTRACT. TM W= NOT • REDUCE ffi M TBLY PAWINT AM11ir ON TIM 'CONTRACT, BUT
WILL REDUCE 79C TOTAL NO?= OF IONTBS I MT PAY TIM CONTRACT.
GENERALLY - The headings at the beginning of each
section are for convenience only and are not to be used in
interrp?retinggi?the text of the sec
DEFINITlON3 - ' I," "me. or my' means each Borrower
who suns this note and-each other persog or, legal entity
()ncludin guarantors, endorsers, and sureties) who agrees
to pay this note (together referred lo, as "us"). "You" or
w your means the Lender and its successors and assigns.
APPLICABLE LAW - This note and any agreement secunn
this note will be governed by the laws of '" state o
Pennsylvania. The fact that any part of this note cannot be
enforced will not affect the rest of this note, Any change
to this note or any a regiment securing thin, note must oe
in writing and signed by you and me.
1 agree to Cooperate f with you regarding dny requests
after closing to oorredt, errors made, concerning • this
contract or the transaction and to provide any and all
additional documentation, deemed necessary by yo to
complete this transecdoh, 1: agree that you may enforce
this agreement by judicial ,process and are entitled to
attorney's fees, costs and disbursements I. nent to such
enforcement.
PAYMENTS - Each payrrient 1 make on this loan will be
applied first do any charges 1 owe other. than principal and
interest, then to interest -that is due, and finally tq principal
that Is due. No late charge will be assessed, on any
paymerrt when the only delinquency is due to late fees
assessed on earlier payments. and the; payment is
otherwise a full payment, The actual amount of my final
payment will depend on'the interest rates (if variable) and
my payment record. If any payment due under this loan
does'not equal or exceed the amount of interest due, you
may, at your option, increase the amount of the payment
due and all future payments to an amount that will pa off
this loan in equal payments over the remaining term of this
loan.
PREPAYMENT - I may prepay this loan in whole or in part
at any time. If I prep in part, I must still make each rater
note entt i d the full gins amount as it becomes due until this
INTEREST - Interest accrues on the princiippal remaining
Unpe.id from time to timd until paid in full,, If "Variable
ate is checked on page i, I will pay interest at the rates
in effect from time to lime. The interest rate(s) and other
charges on this loan will' never exceed the highest rate or
charge allowed by Law for this loan, If the index specified
on pa e 1 ceases T exist,. I agree that you may substitute
a similar index for the original.
INDEX - If Xqu and I have agreeo that the interest rate on
this note will be variable and will bg related to an index,
then the Index you select will function only as a tool for
setting the rate on this notg. You do not guaranty, by
selecting any index, that the interest rate on this note will
have a particular relationship to the interest rate you
charge on any other loans or any type or class of loans
with your other customers,
ACCRUAL METHOD - The amount of interest that I will
pay on this loan will be calculated using the interest rate
and accrual method sited on page 1. For interest
calculation, the accrual method will determine the number
of days in a year. If no accrual method is stated, then you
may use any reasonable accrual method for calculating
interest.
SINGLE ADVANCE LOANS - If this is a single advance loan
you and I expect that you will only make one advance of
principal. However, you- may add other amounts to the
principal if You make any payments described in the
PAYMENTS BY LENDER section below.
61884. 1881. 1885 5.*sm Svotego. Ina. 9t Clow& MN Form GY"ENU1ZPA IraAe
MULTIPLE ADVANCE LOANS - If this is a multiple advance
loan, you and i expect that you will make more than one
advance of principal, subject td the conditions of any
separate aT regiment. ;:.", W.?,. y,
PAYMEN BY LENDER - If you kre'at tllA4d to pay, on
my behalf, charges I am obligated to pay (such as property
insLrancd premiums); then you may treat those payments
made by you as advances and add them to the unpaid
principal under this nova,. or you .may demand immediate
payment of the charges.
POST-?A INTEREST ' - Irndrest will accrue on the
principal ba ante remaining unpaid after final maturity at
the rata specified on page,l. For purposes of this section,
final maturity occurs:
(a) On the date of the Idat scheduled payment of principal;
or
(b) On the data you accelerate the due data of this loan
(demand Imrr?ed( REAL ESTATE OR CE SECURITY - If this loan is
secured by real emtd or a residence that is personal
pro perty the existence of a default and your remedies for
such a default will be determined by applicable law, by the
terms of any s rate instrument creating the security
interest and, to the extent not prohibited by law and not
contrary to the terms of the separate, security instrument,
b this agreement. A ISUMP ION - This note and any' document securing it
cannot be assumed by someone buying the secured
property from me. -This will be.-true. unless.:you agree in
writing to the contrary. Without such an agreement, if I try
to transfer any interest in the property sea; ir)ng this note, I
will be in default on this loan. You may proceed against me
under any due on sale clause in the security agreement,
which is incorporated bit reference.,
DEFAULT - Subject to anY limitations in the "REAL
ESTATE OR 135SIDENCE SECURITY", paragraph above, I
will be in default on this loan and any agreement securing
this loan If any one or more of th following occurs:
(a) I fail to make a payment in fullwhen due;
(b) ( die am declared incompetent, or become insolvent;
(c) I fail to keep any promise I have made in connection
with this loan;
(d) I fail to pay, or keep any other promise on, any other
loan or agreement I have with you;
(e) informatgod thattis untrue oC inaccurate at he time it is
provided;
(f) Any creditor of mine attempts to collect any debt I owe
through court proceedings, set-off or self-help
repossession;
(g) The property securing this Loan is damaged, destroyed
or stolen;
(h) I fail to provide any additional security. (fiat you may
require;
(i) Any legal entity (such as a partnership or corporation)
that has agreed to pay this note merges, dissolves,
reorganizes, ends its business or existence or a partner
or mWority stockholder dies or is declared lneompetsnt;
or
U) you wig have hdarculty hcollecctting the amouunntvI owe
ou,
IT any of us are in default on this note or any security
agreement, you may exercise your remedies against any or
all of us.
G-116151"11 1111871 lopne 2 of 41
'DEC.31.2007 1:40PM US BANK DOCUMENT CENTER
REMEDIES - Subjeot to any limitations in the "REAL
ESTATE OR RESIDENCE SECURITY" paragraph on page 2,
and after giving any appropriate notice, if I am in default
on this loan or any agreement securing this loan, you may:
(a) Make unpaid principal, earned interest and all other
agreed charges I owe you under this loan immediately
due;
(b) Use the right of set-off as explained below;
(c) Demand' more security or new. parties obligated to pay
this ban (or both) in return for not using any other
remedy;
(d) Make a claim for any and all insurance benefits or
refunds that may be available on my default;
(s) U'sde any remedy you have under state or federal law;
(f) Use any remedy given to you in any agreement
securing this loan.
By choosing any one or more of these remedies you do
not give up your right to use another remedy later. By
deciding not to use any remedy should I be in default, you
do not give up your right to consider the event a default if
it happens again,
COSTS OF COLLECTION AND ATTORNEYS' FEES' - I
agree to pay you all reasonable costs you incur to collect
this debt or realize on any security, This includes, unless
prohibited by law, reasonable attomeys` fears. This
provision also shall apply if l file a petition or any other
claim for relief under any bankruptcy rule or law of the
United States, or if such petition or other claim for relief is
filed against me by another.
SET-O- I agree that you may set off any amount due
and payable,, under. this note against any right I have to
receive money from you,
"Right to receive money from you' means;
(a) Any deposit account balance I have with you;
(b) Any money owed to me on an item presented to you or
in your possession for collection or exchange; and
(c) Any repurchase agreement or other nondeposit
obligation.
'Any amount dus and payable under this note' means
the total amount of which you are entitled to demand
under the terms of this note at the time you exercise your
right of set off. This total includes any balance the due
date for which you properly accelerate under this note.
If my right to receive money from you is also owned by
someone who has not agreed to pay this note, your right
of set-off will apply to my interest in the obligation and to
any other amounts I could withdraw on my sole request or
endorsement. Your right of set-off does not apply to an
account or other obligation where my rights arise only in a
representative capacity. It also ' does not apply to any
Individual Retirement Account or other tax-deferred
retirement account.
You will not be liable for the dishonor of any check
when the dishonor occurs because you set off this debt
againstlany--gf my accounts,, I. agree to hold you harmless
from any such claims arising as a result of your exercise of
your right of set-off.
OTHER SECURITY - Any present or future agreement
securing any other debt 1 owe you also will secure the
payment of this loan. Property securing another debt will
not secure this loan if such property is my principal
dwelling and you fail to provide any required notice of right
of rescission. Also, property securing another debt will
not secure this loan to the extent such property is in
household goods. `
OBLIGATIONS INDEPENDENT -A l understand that my
obligation to pay this loan is independent of the obligation
of any other person who has also agreed to pay It. You
may, without notice, release me or any of us, give up any
right you may have against any of us, extend new credit to
any of us, or renew or change this note one or more times
and for any term, and l,will still be obligated to pay this
loan. You may, without notice, fail to perfect your security
interest in, impair, or release any security and I will still be
obligated to pay this loan.
8IBM, 7841. 1693 Opdtas 9Vft6R4InQ. sG am. W Fmm O1FIADIL vA 1122196
NO. 9310 ?, P 38
ol
ARBITRATION - All disputes, claims, fl or controversies
arising from or relating to this contract or the relationships
which result from this - contract, or the, validity of this
arbitration clause or the entire contract, shall be resolved
byy binding arbitration one arbitrator 'selected by you
w16 consent of us. This arbitration contract is made
pursuant to a transaction in interstate commerce, and shall
bye Rovemed try the Federal Arbitration Act at 9 U.S.C.
Section 1. Judgment upon the award rendered may be
entered in any court having jurisdiction. The parties agree
and understand that they choose arbitration instead of
litigation to resolve disputes. The, parties understand that
they have a right or opportunity to litigate' disputes
throuuggh a court, but that they prefer to resolve their
dispputes throuQh? arbitration, except as provided therein.
THE_ PARTIES OLUNTARILY_ AND KNOWINGLY WAIVE
PURSUANT TO ARBITRATION UNDER THIS CLAUSE OR
PURSUANT TO A COURT ACTION BY YOU (AS
PROVIDED HEREIN). The parties agree and understand
that all disputes arising under case law, statutory law, and
all other laws including, but not limited to, all contract,
tort, and property disputes, will be subject to binding
arbitrate' in accord with this contract. The parties agree
and understand that the arbitrator shall have all powers
provided b the law and the contract. These powers shall
include all legal and equitable remedies, including, but not
limited to, money damages, declaratory relief, and
injunctive relief. Notwithstanding anything hereunto the
contrary, you retain an option to use judicial or non judicial
relief to enforce a mortgage, deed of trust, or other
security agreement relating to the real property secured in
a transaction underlying this arbitration agreement, or to
enforce the monetary obligation secured by the real
property, or to foreclose on the 'real property. Such judicial
relief would take the form of a lawsuit. The institution and
maintenance of an action for judicial relief In a court to
foreclose upon any collateral, to obtain a monetary
judgment or to enforce the mortgage or deed of trust, shall
not constitute a waiver of the right of any party to compel
arbitration regarding any other dispute or remedy subject
to arbitration in this contract, including the filing of a
counterclaim in a suit brought by you pursuant to this
- I waive (to the extent permitted by law)
presentment, protest, notice of dishonor and
PRIVACY- I e$ree that from time to time you may receive
credit information about me from others, including other
porting agencies. I agree that you may
tenders and credit re
furnish on a regular basis credit and experience information
regarding my loan to others seeking such information. To
the extent permitted by law, I agree that you will not be
liable for any claim ansing from the use of Information
provided to you by others or for providing such
information to others.
FINANCIAL STATEMENTS - I will give you any financial
statements or information that you feel is necessary.. All
financial statements and information I give you will be
correct and complete.
PURCHASE MONEY LOAN - If this is a Purchase Money
Loan, you may include the name of the seller on the check
or draft for this loan.
NOTICE OF PROPOSED INSURANCE - I take notice that
group credit life insurance and/or group credit accident and
health insurance coverage will be applicable to this
contract if so marked on page 1 of this contract and each
type of coverage will be written by the insurance company
named, This insurance, subject to acceptance by the
insurer, covers only the person signing the request for
such insurance (or each person signing the request for
joint credit life insurance). The amount of charge is
indicated for each type of credit insurance to be
purchased. The term of insurance will commence as of the
date the indebtedness is incurred and will expire on the
21nally scheduled maturity date of the Indebtedness.
ject to acceptance by the insurer and within 30 days,
e will be alivgred to me a certificate of insurance
more fully describing the insurance. In the event of
prepayment of the indebtedness, a refund of insurance
charges will be made when due.
um s-,wo7 7 11119-n tow a of 4J
NOTICE TO COSWR
You ithe cosigner) are being a ed to guaranty this
debt. Think carefully before you do. If the borrower
doesn't pay the debt, you will have to. Be sure you can
afford to pay N you have to, and that you want to
accept this responsibility.
You may have to pay up to the full amount of the
debt if the borrower does not pay. You also may have
to pay late fees or collection costs, which increase this
amount.
The creditor can collect this debt from you without
first trying to collect from the borrower. The creditor
can use the same collection methods against you that
can be used against the borrower, such as suing you.
garnishing your wages, etc. If this debt is ever in
default, that fact may become part of your credit record.
This notice is not the contract that makes you liable
for the debt.
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 WITH THE PROCEEDS HEREOF.
RECOVERY HEREUNDER BY THE DEBTOR SHALL
NOT EXCEED AMOUNTS PAID BY THE DEBTOR
HEREUNDER.
PURPOSE: The?pose of this loan-is construction on
land and home:?-
SIGNATURES: I AGREE TO THE TERMS OF THIS NOTE
{INCLUDING THOSE ON PAGES 1, 2, 3 AND 4). 1 have
rec d a cop today's date. ?
1994. 19111. 1993 Bw"m Swtam. bw.. Bt. Clad. MN Form M-RENLAZpA 122108 OT-15-3"11 1111871 10001 4 014!
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3
S T RAT>: ORD SETTLEIME,NTS
I BZyGt E'tOVY.4'AN ROAD. SUNTE 243
` lGu?. ?Q . CRANES-MIRRY Tt'JP 16?6fi '
May- A•1 d,P Coq -- 0513 Pry U-t 003 p '98 JUf; .i ?
fl1711 40
Commomeahh of Pennsylvania Space Above This Line For Recording data
CT-15.39-090 (9/94) OPEN-END MORTGAGE
This Mortgage secures future advances
1. DATE AND PARTIES. The date of this Mortgage (Security Instrument) is ... JUNE 4, 1998
.......................
and the parties, their addresses and tax.identification numbers, if required, are as follows:
MORTGAGOR: WILLIAM L. DAVIS
ca _
LAURA LEE CHAPMAN-DAVIS -
671 SHIPPENSBURG ROAD L =
NEWVILLE, PA 17241; .:>
.
.... If checked, refer to the attached Addendum incorporated herein, for additional Nl0rtgagdf$,!_their
signatures and acknowledgments. 3 .-
)?
' !ENDER: GREEN TREE CONSUMER DISCOUNT CO. -
105 BRADFORD RD, BLDG III,SUITE 200
r
WEXFORD, PA 15090
i
2. CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of which is
acknowledged, and to secure the Secured Debt (defined below) and Mortgagor's performance under
this Security Instrument, Mortgagor grants, bargains, conveys and mortgages to Lender the following
described property: All of the property located at 671 SHIPPENSBURG ROAD ,
in the City/Town/Village of NEWVILLE , County of CUMBERLAND ,
State of PA , in which the Borrower has an ownership, leasehold or other
legal interest. This property is more particularly described on the schedule titled
"Additional Property Description" which is attached hereto as Exhibit A.
together with a security interest in that certain 1998 , 66 X 28
LAUREL HOUSE mobile home, serial number STAGE FUND
The Borrower does hereby authorize the Lender or its assigns to obtain a
more detailed property description after the Borrower has signed the Mortgage,
and to attach Exhibit A after the Borrower has signed the Mortgage.
The property is located in ..............5; ........................................ at .............
................................
(county)
671 SHIPPENSBIIRG ROAD
..
OAD ....................... . ..... NEwViLLE ............................... ,Pennsylvania ...... I 2it?l...........
(Address) (c(ty) (ZIP Code)
Together with all rights, easements, appurtenances, royalties, mineral rights, oil and gas rights, all
water and riparian rights, ditches, and water stock and all existing and - future improvements,
structures, fixtures, and replacements that may now, or at any time in the future, be part of the real
estate described above (all referred to as "Property").
Bood460PAGf IN
PENNSYLVANIA - MORTGAGE (NOT FOR FNMA. "AC. Frw OR VA USE)
0 1994 Bankers Systems, Inc., St. Claud, MN (1-800.397.2341) Form CTH-MTCLAZPA 10/1'1/94 - CT-1 S-39.090 (9/94) 0Wd I of 6)
?Xkv-r- 'k "
DEC-31-2007 1:42PM US BANK DOCUMENT CENTER NO. 9340 P. 43
. l
V
3. MAXIMUM OB,L1GATiON LIMIT. The total principal „amount secured by this Security Instrument at any
one time sh II t exceed S......,. a7 This limitation of amount does no include
interest am older tees and charges, v I ma?'e pursuant to this Security Instrument. Also, this
limitation does not apply to advances a under,the. terms of this -Security Instrument to protect
Lender's security acid to perform any of the covenants contained In this Security Instrument.
4. SECURED Ddr AND FUTURE ADVANCES. The term "Secured Debt' is difined as follows:
A. Debt in erred under the terms of all promissory note(s), contract(s), guaranty(s) or other evidence
of debt Ascribed below and all their extensions, renewals, moditadons or substitutions. (When
referrrlcr gg the debts below it is suggested that )vu include Items such as borrvww*s' mimes, note
amounts, 7rrter?st rates, rr?aturity dates, etc.)
A Universal Note or Hamufactured Home Intail Install saat Contract and Security
Agreement amacuted by Buyers/Borrowers.
The above obli ation is duo and payabla on 360 months from last cvaatruction disbursement if not paid earlier.
B. All ?uture advances from Lender to Mortgagor or other future obligations of Mortgagor to Lender
under any promissory note, contract, +guaranty, or other evidence of debt executed by Mortgagor
in favor gf Lender executed after. this Security Instrument yvhether gr not this Security Instrument
is specifically referenced. If more than one person signs this SicuRty-Instrw Mt, each Mort
agrees that this Security instrument will secure all future advances and future obligations that are
given to or Incurred by any one or more Mortgagor, or any one or more Mortgagor and others. All
future advances and other future obligations are secured by this Security Instrument even though
all or part may not yet be advanced, All future advances and other future obligations are secured
as if made on the date of this Security Instrument. Nothing in this Security instrument shall
constitute a commitment to make additional or future loans or advances in any amount. Any such
commitment must be agreed to in a separate writing.
5.
6.
7.
8.
9.
C. All obligations Mortgagor owes to Lender, which may later arise, to the extent not prohibited by
'law, Including, but not limited to, liabilities fur overdrafts relating to any deposit account
agreement between Mortgagor and Lender.
D. All additional sums advanced and expenses incurred by Lender' for insuring preserving or
otherwise, protecting the Property and its value and any other- sums advanced • and expenses
incurred by Lender under the terms of this Security instrument. .,
This Security Instrument will not secure any other debt if Lender fails to give any required notice of the
right of rescission.
PAYMENTS. Mortgagor agrees that all payments under the Secured Debt will be paid when due and in
accordance with the terms of the Secured Debt and this Sec irity instrument.
WARRANTY OF TiTi E. Mortgagor warrants that Mortgagor. is or will be lawfully seized of the estate
conveyed by this Security Instrument and has the right to grant, bargain, convey, sell, and mortgage the
Property. Mortgagor also warrants that the Property is unencumi eyed, rxetpt for encumbrances of
record.
PRIOR SECURITY INTERESFS? With regard to any other mortgage, deed of trust, security agreement or
other lien document that created a'pnor security interest or encumbrance on the Property, Mortgagor
agrees:
A. To make all payments when due and to perform or comply with all covenants.
B. To promptly deliver to Lender any notices that Mortgagor receives from the holder.
C. Not to allow any modification or extension of, nor to request any,future advances under any note
or agreement secured by the lien document without Lender's prior written consent.
CLAIMS AGAINST TITLE Mortgagor will pay all taxes, assessments, liens, encumbrances lease
payments, ground rents, utilities, and other charges relating to the Property when due, Lender may
require Mortgagor to provide to Lender copies of all notices that such amounts- are due and the receipts
evidencing Mortgagors payment. Mortgagor will defend title to the Property against any claims that
would impair the en of this Security Instrument. Mortgagor agrees to assign to Lender, as requested
by Lender, any rights, claims or defenses Mortgagor may have against parties who supply labor or
materials to maintain or improve the Property.
DUE ON SALE OR ENCUMBRANICE 'Lende'r may, at its option,- declare the entire balance of the Secured
Debt to be 1611 ediaWy due and gable upon the creation of, or contract for the, creation of, any lien,
encumbrance; transfer or sale of the Property. This right is subject;.to the restrictions imposed by
federal law 52 GF.R. 591), as ap licable. This covenant shall run with the Property and shall remain in
effect until the Sewreci<ebt is, Qai •h fi,dl,and this Security Instrument is released. ,
f.s
D i 994 Bankers Systems, krc. 9G Cbud, MN (1$00 397.2341) Form CMAMLAZPA 10/11/94 cr-i sa"Do ?qp 2 of 0
80OX U60 racE Z
DEC, 31. 2007 1:42PM US BANK DOCUMENT CENTER NO, 9340 P. 44
.•101, PROPERTY CONDMON;4ALTERATICM AND INsK_CWN,,,.Mort ?r will keep the Property in good
condition and make all repairs that are feasonably s'sary Mortgagor ghalt: not commit or alloany
waste, impairment, or, deterioration of the Props ?tgagor VAII keep the Property- free of noxious
weeds and grasses. Portg or agrees that the nature ,of the occupancy and use will not substantially
change without es Nor written consent. Mortgagor will not permit any change In an license,
restrictive cpvenanr or easement witho?f llkn&es pFtor writteh consent.,*Mortgagor,,wIH noti? bender
of all demands, proceedings; claims' and actions against Mortgagor,, and of any. loss or damage to the
Property.
Lender or Lender?? agents may,. at Lender's oppti?on,' enter tfie Property at' any'Feasohable time for the
purpose of inspecting ,thc. Frro¢erty.` i?ridr r 5Ft 1 give , Mdd 'dgof`1* notice-'at the tkoe of or before an
inspeaior4 specifying a reasonable .purpose for the inspection. AnY Inspection, of the Property shall be
entirely fir Len?e?s t> neflt and Mortgagor will in nc way rely on Lerr(!ees Inspection.
11. AU77°ICIRITY'TO PERFORM. 1# Mortgagor fails to pertorm any duty or any of the covenants contained in
this Security Instrument, lender may, without notice, perform . or . cause ' them , to be performed.
Mortgagor appoints Lender as attorneeyy in fact to sign Mortg rs name or paV any amount necessary
for performance. L,endees right to pertarm for Mortgagor shalTnot create an obligatioh to perform, and
L.endees failure to perform will not'preclude Lender from exercising any-of Lender's other rights under
the law or,this Security. Instrume - t ','If any constriction ' on the Property is, • Ilkantinued or not carried
on in a reasonable manner, L _rrder may take all steps necessary to protect Lender's.security interest in
the i?rpper'ty, indudin'rompletion of the construction.
12. ASSIGNMENT OF LEASES AND RENTS, Mortga'gor irrevocably; grants, bargains,,, conveys and mortgages
to Lender as additional security all the right, tale and interest In wind to any and all existing or future
leases, subleases, and any other written or verbal agreements for the use and occupancy of any portion
of the Property, including any extensions, renewals, modifications or substitutions 'of such agreements
(all referred to as "Leases") and rents issues and profits (all -referred to as "Rents"). Mortgagor will
promptly provide Lender with true, and' correct copies of all existing and future, Leases. Mortgagor may
collect, receive, enjoy-and use the Rents so long as Mortgagor is not in default under the'terms of this
Security instrument
Mortgagor agrees that this assignment is immediately efFecti?e between theparties to this Security
Inttruinont" Mortgagor'. ees that.thiS. assignroelat is effecthre as to third pit les when lender takes
affirmative- action Qrescr?ed _y law, 'arid that this assignment will••remain - irr-effect during airy
redemption period until the Secured' Debt'Is'§atisfted. Mortgagor'' agrees than-ender may take actual
possession of the property without .the nL ssity •of. commencing legal ,action and that actual
possession is deemed to occur where Leader, or. its agent,, notifies Mortgagor of default and demands
that any tenant pay all future ken% directly to,Lender. On receivicig notice of ddf4It, Mortgagor will
endorse and deliver to Lender arty payment of Repts in Mortgagor's possession and will receive any
Rents in trust for. Lender and will not commingle the Rena with any other hands. Any amounts
collocted will be applied its provided in- this Security instrument. Mortgagor warrants that no default
exists under the Leases or an applicable landlord/tenant, law. Mortgagor .also: agrees to maintain and
require any tenant to comply with the terms of the Leases and-applicable law. art
13. LEASEHOLDS; CONDOMINIUMS; PLANNED UNIT DEVO-OPMEN7 . Mortgagor ' agrees to comply with
the provisions of any, iease if this Security Instrument is on a leasehold. I tfhe„Property includes a unit
in a condominium of a planned uni't' developmenr, Mortgagor will perform all of Mortgagor's duties
under the covenants, btrlaws, or regulations of the condominium or planned unit development.,
14. DEFAULT. Mortgagor' will be in default if any party obligated on the Secured Debt fails to make
payment when due. ioreggagor, will be in default;, if a breach' occurs under the terms of this Security
Instrument or any other docuinent executed for the putpoze of''creatl* zeuiring or guarantying the
Secured Debt. A good faith belief by Lender that Lender at any tiitire is insecure with respect to any
person or entity obligated 'on the Secured Debt or that the prospeck of any payment or the value of the
Property Is impaired shall'also constitute an event of default.
is. iIsFMED(ES Vft,13EFA,ULT..Ur some'' Instances,' federal' and state law will require ,Lender to provide
Mortgagor with *ndtlcp, of.the right to- cure' or, of r notices and may" estaffistr•'time schedules for
foreclosure actions. Subject to thse 11mitat Errs, if any; lender may accelerate. the Secured Debt and
foreclose this Security Instrument In' a mandir- provided by law if Mortgagor is in default..
At the option of Lender all or any part of the agreed fees and charges, accrued interest and principal
shall become immediately due and payable, after giving notice if:requirkl,, y law, upon the occurrence
of a default or anytirrle thereafter. In addition, Lender shall be entitled-to al ,the remedies provided by
law, the terms of thd'Secured 17ebt, this Security Instrument* and any related documents, All remedies
are distinct, cumulative and-not exclusive, 'and the Lender is entitled to all remedies. presided at law or
equity, whether or not ekc !r ssly set forth. The acceptance by Lenderof any sum in payment or partial
4ii 1 ' , .. • ' 11001(1'4s'0+1' 126
,
0 1994 Bankers srftms, b-. SC Gaud, MN (1-500.397.2341) Form ON-MTELAZPA 10/11/94 Cr 17-a9-09o (9/94) (pip 3 of 0
DEC.31.2007 1:43PM US BANK DOCUMENT CENTER NO.9340 P. 46
Unless.otterwise, "feed? in yvxktpgg,,,, all insurance proceeds, shall be applied to the restoration or repair
of the Property"cr to tFe Secured b, writ:tjler or not tAerr +fue;? ?Leii6er ' Q lain: AnY application of
proceeds to principal.shall not extend or postpone the due date of the scheduled payment nor change
the amount of any payment. Any excess vdII be id to the Mortgagor.. If the? Property is acquired by
Lender,_ Mortgagor's. right to any insurance po ides and proceeds resultinnb* from damage to the
Property before the acquisition shall pass to Lender to, the extent of the Secured Debt immediately
before the acquisition.
20. ESCROW, FOR TAXES AND INSURANCE Unless otherwise provided in a separate agreement, Mortgagor
will not be required to pay to Lender funds for taxes and insurance in escrow.
21. FINANCIAL REPORTS AND ADOMONAL DOCUMENTS. Mortgagor will provide to Lender upon
request, any financial statement or information Lender may deem reasonably necessary. Mortgagor
agrees to sign, deliver, and file any additional documents or certifications that Lender may consider
necessary to pgrfect,, continue, and preserve Mortgagor's obligations under this Security Instrument
and Lender's lien, status on the Pro party-
22. JOINT AND. INDIVIDUAL LIABILITY; CO-SIGWJLr; SUCCESSORS 'AND ASSIGNS BOUNIM All duties
under this Security Instrument aje joint and individual. If Mortgagor signs this Security instrument but
does not sign-an evidence, of debt. Mortgagor does so only to mortgage. Mortgagor's interest in the
Property to secure payment of the Secured Debt and Mortgagor does not agree to be personally liable
orr• the Secured Debt.; If this Security instrument secures a guaranty between Lender and Mortgagor,
Mortgagor agrees to' waive any rights that may prevent Lender from bringing any action or claim
against Mortgagor or any party indebted under the obligation. These rights may include, but are not
limited to, any anti-deficiency or one-action laws. Mortgagor agrees that Lender and any party to this
Security instrument may extend,. Modify or make any change- in the terms of this Security Instrument or
any evidence of debt Athout Mortgagor's consent. Such a change will not release Mortgagor from the
terms of this Security:, Instrument. :.The duties and benefits of this Security Instrument shall bind and
benefit the successors and assigns of Mortgagor and Lender.
23. APPLICABLE LAW,; SEVERAMUTY; INTERPRI rATION. This Security Instrument is governed by the laws
of the jurisdiction in which Lender is located, except to the extent otherwise required by the laws of the
julasdictionry erp, the. Property is located. This Security Instrument is complete and fully Integrated.
Tills Securi Instrument. may not be amended. or modified by oral agreement. Any section in this
Security. Instrument, attachments,. on-any agreement related to the Secured Debt that i'onflicts with
applicable, law will nqt. be effective unless that law f*pressly or Impliedly permits- the variations by
written agreement If any seuioii oi? this Setajri V Instrument cannot be enforced according to its terms,
that section will' be severed and will not affect the eftrceabirty, of the remainder of this Security
instrument. Whenever , used; the- singular shall Include the plural and the • plural the singular. The
captions and headings of the sections of this Security Instrument are for convenience only and are not
to be used to Interpret or. define the terms of this Security Instrument, Time is of the essence in this
Security instrument.
24. NOTICE Unless otherwise required by law, any notice shall be given by delivering it or mailing it by
first class mail to the appropriate party's address on page 1 of this Security Instrument, or to any other
address designated in writing. Notice to one mortgagor will be deemed to be notice to all mortgagors. .
25. WAIVERS. Except to the extent prohibited by law, Mortgagor waives -any right.•to appraisement relating
to the Property,.. ;
26. OTHER 'T'ERMS. If checked, th$, following are applicable to this. Security. Instrument.' '
...... Line of Credit. The Secured Debt includes a revolving : line of credit. provision. Although the
Secured Debt' may be reduced to a zero balance, this Security Instrumdnt 'will' remain in effect
until released..
xy-
.. Construction I.oari. This Security Instrument secures an obligation incurred fnr the construction
- of ah,-I*rovemegt on the property.
...... Fixture Filing.' Mortgagor grants to Lender a security interest in all goods that Mortgagor owns
now or in the future and that are or will become fixtures related to the Property. This Security
Instrument suffices as'a financing statement and any carbon, photographic or other reproduction
may be filed of record for purposes of Article 9 of the Uniform Commercial Code.
...... Purchase Money. This Security- Instrument secures advances by Lender used in whole or in part to
acquire the Property. Accords gly, this Security Instrument, and the lien hereunder, is and shall be
construed as a purchase V " g?4 vylth all of the rights, priorities and benefits thereof
under the laws of the Commonwealth of PennsyWanit4,vl'
. ?UOK acs
0 1994 Wker$ Systems, lei., St Gaud, MN (i-d00-397-2341) Farm GT*MTQAZPA 10/11/94 GT-15-99.090 (9/94) Omp sec t)
i
...... NOTICE TO BORROWER: THIS DOCUMENT CONTAINS PROVISIONS FOR A VARIABLE
INTEREST RATE
...... Riders. The covenants and agreements of each of the riders checked below are incorporated into
and supplement and amend the terms of this Security Instrument. [Check all applicable items)
...... Condominium Rider ...... Planned Unit Development Rider ...... Other .....................................
... Additional Terms.
I SIGNATURES: By signing below, Mortgagor, intending to be legally bound hereby, agrees to the terms
and covenants contained in this Security Instrument and in any attachments. Mortgagor also
acknowledges receipt of a copy of this Security Instrument on he dat tated on page 1.
ti fiTILLIAM L. DAMS (Date) .Glgna I.BS C -DAMS (Date)
' ........................................... ..............
(Signature) .......... (Date) (Signature) ............... ..
(Date)
iG?,• •.
? (V?Itness)
Hess) . i-.---'...'...".
ACKNOWLEDGMENT:
COMMONWEALTH OF... PENNSYLVANIA COUNTY OF., ........
j ?Ohn this, the ..... i........ day of .........JME..1998 ................. .before me.............. } ss.
(Ina"a?au ( p y ..............................
thjide
t9nVI............................. r?,eeURA rs Ea eared .................................................................................
,,,,,,,,,MAN-nAy,s,,, , known to me (or satisfactorily proven)
to be the person(s) whose name(s) is subscribed to the within instrument, and acknowledged
Y: that he/she executed the same for the purposes therein contained.
r.
In witness whereof, I hereunto set my hand and official seal.
ti My commission expires: A -q C
:,yj?• ,;
Notarial Seal .... ...... ....... ...
Greg A. Mixell, Notary PubNc •• .....• .. .............
Greene Tw Franklin Cou ` nty
My Commission Expires march 4.2WO Tt?le?otOffker'• ...... .. .. .. .
i; Member, Pennsylvania Ass iation of Notaries
. It is here
?YJBOX ce t fi dSthat the address of the Lender with'
5 WEXFORD, PA 15090 med is: .............
..................................................................................... ........ - ... ..... .......................
. ...................................
L I.. INO
eood460 ma ,40*n
s
0 1994 Bankers Systems, Inc., St. Cloud. MN (1-800-397.2341) Form CTN-MTGLAZPA 10/11/44 GT-15.39-090 (9/94) (VaW 6e/ 6)
i
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE
AND LYING AND BEING IN THE TOWNSHIP OF NORTH NEWTON IN THE
COUNTY OF CUMBERLAND AND COMMONWEALTH OF
PENNSYLVANIA, MORE PAR'T'ICULARLY DESCRIBED AS FOLLOWS:
BOUNDED AND DESCRIBED IN ACCORDANCE WITH A PLAN PREPARED
BY STANLEY JARMOLENKO, R.S. DATED NOVEMBER 13, 1984„ AND
RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR
CUMBERLAND COUNTY IN PLAN BOOK 47, PAGE 14, AS FOLLOWS, TO-
WTT:
BEGINNING AT A POINT ON THE DEDICATED RIGHT Of WAY LINE OF PA
ROUTE 533 AT CORNER OF LOT NO. 6 OF THE ABOVE MENTIONED
PLAN OF LOTS; THENCE ALONG LOT NO. 6, SOUTH 57 DEGREES 35
MINUTES EAST 300.00 FEET TO A POINT; THENCE ALONG OTHER LANDS
NOW OR FORMERLY OF KIMBA, INC. SOUTH 32 DEGREES 25 MINUTES
WEST 150.00 FEET TO A POINT AT LINE OF LOT NO.8 OF SAID PLAN;
THENCE ALONG LOT NO. 8, NORTH 57 DEGREES 35 MIN[TI'ES WEST
300.00 FEET TO A POINT ON DEDICATED RIGHT OF WAY LINE OF PA
ROUTE 533; THENCE ALONG PA ROUTE 533, NORTH 32 DEGREES 25
MINUTES EAST 150.00.
BEING LOT NO. 7 ON SAID PLAN. BEING KNOWN AND NUMBERED AS
671 SHIPPENSBURG ROAD NEWVILLE, PA 17241.
State of Pennsylvania l"r
County of Cumberland) 86
Recorded in the office for the recording of Deeds v r ?1 i -r ; `'`R
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MI, MN, MO (LH First Liens), MS, MT, NE, NV, NH, NJ (IIO), NM, NY, NC, ND, OH9 OK, OR, PA, (HO)
X RI, SD, TN, TX (HO). UT. VT. VA_ WA_ WV
NOTICE OF DEFAULT
AND
RIGHT TO CURE DEFAULT
Date of Notice: 11/02/2007
William L. Davis
Laura Lee Chapman Davis
671 Shippensburg Rd
Newville, PA 1 724 1-9476
GREI&REE
Certified Mail Receipt No. 71067112169002913024
Green Tree Consumer Discount Company
Three Executive Park Drive Suite 14
Bedford, NH 03110
800643-0202
Account No: 734244296 Creditor: Green Tree Consumer Discount
Brief identification of credit transaction: Manufactured Home Account
You are now in default on this credit transaction. You have the right to correct this default within 30 days from the postmarked
date of this Notice.
If you correct the default, you may continue with the contract as though you did not default.
Your default consists of. 2 payments past due(plus $10.00 in fees and charges) totaling $1,192.50.
Cure of default: Within 30 days from the postmarked date of this Notice, you may cure your default by paying $1,192.50, which
consists of $1,182.50 for past due payments and $10.00 for late charges, or by doing the following: NA
Creditors rights: If you do not correct your default in the time allowed, the creditor may exercise its rights against you under the
law by taking legal action to repossess or foreclose on its collateral.
If you fail to cure the total amount of your default within the cure period described above, then as of 30 days from the postmark
of this Notice, the maturity of this contract is automatically accelerated and full payment of the contract in the amount of
$78,343.77 shall be due and payable without any further notice from the creditor. Additional expenses, interest and charges
accrued after the date of this notice shall also be due and payable. You have the right to reinstate after acceleration and the right
to bring a court action to assert the nonexistence of your default or any other defense you may have to acceleration and
foreclosure.
If you have any questions, write Green Tree at the above address or call the number provided.
If this default was caused by your failure to make a payment or payments, and you want to pay by mail, send a cashier's check or
money order. Do not send cash. Other payment arrangements may be made by contacting Green Tree.
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a debt and any information
3. Service Type CERTIFIED MAIL I
4. R.-dcted DNiwry? (Eft Fee) ? Yes
1. Article Addressed to:
DF7A1 ! PS Form
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Green Tree Consumer Discount Company
Tempe III
7360 South Kyrene Rd
Tempe, AZ 85283 4583
, July 2001 Domestic Retum Receipt
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VERIFICATION
I, Jennifer Lockerman, Collections Manager, and duly authorized representative of Green
Tree Consumer Discount Company do hereby depose and say subject to the penalties of 18 Pa.
C.S. § 4904 relating to unsworn falsification to authorities, that the facts set forth in the
foregoing are true and correct to the best of my information and belief.
1
4:nnifer ockerman
lection Manager
Green Tree Consumer Discount Company
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' SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-00825 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
GREEN TREE CONSUMER DISCOUNT
VS
DAVIS WILLIAM L ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
DAVIS WILLIAM L but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - REPLEVIN ,
NOT FOUND , as to
the within named DEFENDANT
, DAVIS WILLIAM L
671 SHIPPENSBURG ROAD
NEWVILLE, PA 17241-9476
DEFENDANT IS DECEASED.
Sheriff's Costs:
Docketing
Service
,2113161 So answers:
Not Found
Surcharge
18.00 12.48 _
5.00 R. Thomas Kline
10.00 Sheriff of Cumberland County
.00
;45.48 VOELKER & ASSOCIATES
02/08/2008
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-00825 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GREEN TREE CONSUMER DISCOUNT
VS
DAVIS WILLIAM L ET AL
TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - REPLEVIN was served upon
CHAPMAN-DAVIS LAURA LEE
the
DEFENDANT , at 1825:00 HOURS, on the 7th day of February-, 2008
at 671 SHIPPENSBURG ROAD
NEWVILLE, PA 17241-9476
JAYME CHAPMAN, DAUGHTER
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
a/?3?0 Y .00
16.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
02/08/2008
VOELKER & ASSOCIATES
By: -
D ty her' f
u
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-00825 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GREEN TREE CONSUMER DISCOUNT
VS
DAVIS WILLIAM L ET AL
TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - REPLEVIN was served upon
DAVIS JAMIE
the
DEFENDANT , at 1825:00 HOURS, on the 7th day of February-, 2008
at 671 SHIPPENSBURG ROAD
NEWVILLE, PA 17241-9476
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
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
00
16. 00
Sworn and Subscibed to
before me this
day
of ,
So Answers:
R. Thomas Kline
02/08/2008
VOELKER & ASSOCIATES
By:
De ty Sheriff'
A.D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company,
Plaintiff,
V.
William L. Davis and Laura Lee Chapman-
Davis and Jamie Davis,
Defendants.
CIVIL DIVISION
No. 08-825
TYPE OF PLEADING:
Plaintiff's Praecipe for Default Judgment
Pursuant to PA. R.C.P. 1037(b)
FILED ON BEHALF OF PLAINTIFF:
Green Tree Consumer Discount Company
COUNSEL OF RECORD:
Edward F. Voelker, Jr.
PA I.D. #55414
Cynthia M. Dornish
PA I.D. #59890
Voelker & Associates, P.C.
Firm #332
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company, CIVIL DIVISION
Plaintiff, No. 08-825
V.
William L. Davis and Laura Lee Chapman-
Davis and Jamie Davis,
Defendants.
PLAINTIFF'S PRAECIPE FOR DEFAULT
JUDGMENT PURSUANT TO PA. R.C.P.1037M
TO THE PROTHONOTARY:
Kindly enter judgment for possession and in the sum specified below, in favor of
Plaintiff, and against Defendant, Laura Lee Chapman-Davis, for failure to file an Answer or
otherwise respond in the above-captioned action at the above number and term within twenty
(20) days from the date of service of the Complaint. Please assess Plaintiff's damages against
Borrower, Laura Lee Chapman-Davis, as follows:
Principal $78,036.35
Interest $1,103.70 ( 78 days x $ 14.15per
Attorneys fees $500.00
Costs to be added
TOTAL $74,640.05
I certify that a written notice of intention to file this Praecipe was mailed to Borrower
after the default had occurred and at least ten (10) days before the date of the filing of this
Praecipe. I further certify that the Borrowers, are not in active military service. Copies of the
Notices are attached hereto as Exhibit "A". The undersigned verifies that the statements of fact
in the Praecipe are true and correct and are made subject to the penalties of 18 Pa. C.S.A. § 4904
relating to unsworn falsifications to authorities.
Respectfully submitted,
VO07ASSOCIp" S, P.C. Edward F. Voelker, Jr.
Attorneys for Plaintiff
Voelker & Associates, P.C.
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
R
t
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company, CIVIL DIVISION
Plaintiff, No. 08-825 Civil Term
V.
William L. Davis and Laura Lee Chapman-
Davis and Jamie Davis„
Defendants.
TO: William L. Davis
ADDRESS: 671 Shippensburg Road, Newville, PA, 1 724 1-9476
DATE: March 4, 2008
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 AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
VOE CIA .
Edward F. Voelker, Jr.
Attorneys for Plaintiff
Voelker & Associates, P.C.
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
E*Arr "A "
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company, CIVIL DIVISION
Plaintiff, No. 08-822 Civil Term
V.
William L. Davis and Laura Lee Chapman-
Davis and Jamie Davis,
Defendants.
TO: Laura Lee Chapman-Davis
ADDRESS: 671 Shippensburg Road, Newville, PA, 17241-9476
DATE: March 4, 2008
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 AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
VOE S ES, P
Edward , oelker, Jr.
Attorneys for Plaintiff
Voelker & Associates, P.C.
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the attached was served
upon the following by first class United States mail, postage
pre-paid, this day of
9 , N , 2008.
William L. Davis and Laura Lee Chapman-Davis
671 Shippensburg Road
Newville, PA 17241-9476
VOELKER SSOCIATES, P.C.
Edward F. Voe cer, Jr.
Attorneys for Plaintiff
Voelker & Associates, P.C.
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
4 .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company,
Plaintiff,
V.
William L. Davis and Laura Lee Chapman-
Davis and Jamie Davis,
Defendants.
CIVIL DIVISION
No. 08-825
TYPE OF PLEADING:
Notice of Order, Decree or Judgment
FILED ON BEHALF OF PLAINTIFF:
Green Tree Consumer Discount Company
COUNSEL OF RECORD:
Edward F. Voelker, Jr.
PA I.D. #55414
Cynthia M. Dornish
PA I.D. #59890
Voelker & Associates, P.C.
Firm #332
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
r .? 1
N
F
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company, CIVIL DIVISION
Plaintiff, No. 08-825
V.
William L. Davis and Laura Lee Chapman-
Davis and Jamie Davis,
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: ( ) Plaintiff (X) Defendants ( ) Garnishee ( ) Additional Defendant
You are hereby notified that the following Order, Decree, or Judgement has been entered
against you on i? pry Q4
( ) Decree Nisi in Equity.
( ) Final Decree in Equity.
(X) Judgment of ( ) Confession ( ) Verdict
(X) Default ( ) Non-suit
( ) Non-Pros ( ) Arbitration Award
(X) Judgment is for possession and in the amount:
$79,640.05 Plus Costs
() District Justice Transcript of Judgement in (Assumpsit/Trespass) in the amount of
$ , PLUS COSTS.
( ) If not satisfied within sixty (60) days, your moto vehicle operato 's license will be
suspended by the Pennsylvania Department of spo
21
RO
T ARY
By
Deputy
If you have any questions concerning the above, please contact:
Name of Attorney for Plaintiff:
Edward F. Voelker, Jr.
Voelker & Associates, P.C.
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company,
Plaintiff,
V.
William L. Davis and Laura Lee Chapman-
Davis and Jamie Davis,
Defendants.
CIVIL DIVISION
No. 08-825
TYPE OF PLEADING:
Praecipe for Writ of Possession
FILED ON BEHALF OF PLAINTIFF:
Green Tree Consumer Discount Company
COUNSEL OF RECORD:
Edward F. Voelker, Jr.
PA I.D. #55414
Cynthia M. Dornish
PA I.D. 459890
Voelker & Associates, P.C.
Firm #332
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount Company, CIVIL DIVISION
Plaintiff, No. 08-825
V.
William L. Davis and Laura Lee Chapman-
Davis and Jamie Davis,
Defendants.
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Please issue a Writ of Possession in the above captioned matter for the 1999 Colony
manufactured home (serial no. ACSX11464AB) located at 671 Shippensburg Road, Newville,
PA, 17241-9476.
Respectfully submitted,
VOELKER- ASSOCIATES, P.C.
.E and F. ?Ddelker, Jr.
Attorneys for Plaintiff
Voelker & Associates, P.C.
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the attached was served
upon the following by first class United States mail, L
?,' ? postage pre-paid, this day of
C ? 2008.
William L. Davis and Laura Lee Chapman-Davis
671 Shippensburg Road
Newville, PA 17241-9476
VOELKER & ASSOC ATES, P
r'
Edward . o ker, Jr.
Attorneys for Plaintiff
Voelker & Associates, P.C.
Hampton Stoneworks Professional Building
3960 Route 8, Suite 200
Allison Park, PA 15101-3603
(412) 486-8800
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1 of 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREEN TREE CONSUMER
DISCOUNT COMPANY
VS. No. 08-825 Civil Term_
WILLIAM L. DAVIS and
LAURA LEE CHAPMAN-DAVIS and
JAMIE DAVIS
Costs
Attorney's $ 193.98
Plaintiff's $
Prothonotary $ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland 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: (Plaintiff (s))
GREEN TREE CONSUMER DISCOUNT COMPANY
being: (Premises as follows):
1999 COLONY MANUFACTURED HOME (serial no. ACSX11464AB) LOCATED AT 671
SHIPPENSBURG ROAD, NEWVILLE, PA 17241-9476
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
C is R. Long, P notary,
Common Pleas-Court' of C erland County, PA
Date 4/07/08
(Seal)
.
2of2
No 08-825 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
GREEN TREE CONSUMER DISCOUNT COMPANY
Vs.
WILLIAM L. DAVIS and LAURA LEE CHAPMAN-DAVIS
and JAMIE DAVIS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 193.98
Plff (s) $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
EDWARD F. VOELKER, JR., ESQUIRE
VOELKER & ASSOCIATES, P.C.
HAMPTON STONEWORKS PROFESSIONAL BUILDING
3960 RT 8, SUITE 200
ALLISON PARK, PA 15101-3603
412-486-8800
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the
named
appurtenances, and
day of . I caused the within
_, to have possession of the premises described with the
Sworn and subscribed to before me this
Day of
Prothonotary
So Answers,
Sheriff
By
Deputy
1 i
By virtue of this writ, on the 2 2 n&hof M a y
y 2008
I caused the within
named Green Tree Consumer
ffgwviIP8s; nly?t`?$
e
burg soa
c
lpp
ns
17241
So Answers,
Sworn and subscribed to before me this
Day of ,
Sheriff
By
Sheriff's Return: Advance Costs: 225.00
Sheriff' s Costs 106.08
Docketing 18.00 118.92
Poundage 2.08
Prothy 2.00
Milage 14.00
Possession 30.00
Surcharge 40.00
306.0$- V d J lv jb Y
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