HomeMy WebLinkAbout08-1300MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson NO: dg - (30o C iv i (, Tern
Receivables Origination, LLC and
Patrick McKnight
NOTICE OF HEARING ON PETITION TO TRANSFER STRUCTURED
SETTLEMENT PAYMENT RIGHTS
To: Metropolitan Life Insurance Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Metropolitan Insurance and Annuity Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Patrick McKnight
100 B Street
Plainfield, PA 17081
Lawrence J. Rosen, Esquire
Krevsky & Rosen, P.C.
Attorney for Patrick McKnight
1101 N. Front Street
Harrisburg, PA 17102-3324
You are hereby given notice that PATRICK MCKNIGHT has filed a petition to transfer
structured settlement payment rights. A hearing in this matter has been scheduled on
, 2008 at o'clock in courtroom no. courthouse, Cumberland County
Court of Common Pleas, Norristown, Pennsylvania.
You are entitled to support, oppose or otherwise respond to the payee's petition, either in
person or by counsel, by filing written comments with the court prior to the hearing or by
attending the hearing.
The Name, Address and Tax Identification number of the transferee is 321 H
Receivables Origination, LLC. 40 Morris Avenue, Bryn Ma , A 1,010, Tit I.D.
4728885 // //
a-115-0 2
Date
BY:
R~ A. MWt/Esfuire
Attorney for 321 Henderson
Receivables Origination, LLC.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600
(610) 275-9666(facsimile)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson NO:
Receivables Origination, LLC and
Patrick McKnight
INITIAL ORDER OF COURT
On this day of 2008, it is ordered that a hearing on this
Petition to Transfer Structured Settlement Payment Rights will be held on
, in Courtroom at o'clock. The payee shall bring
income tax returns for the prior two (2) years to the hearing.
Within sever (7) days, the transferee shall give notice of the hearing date to the
payee, the structured settlement obligor, the annuity issuer, the payee's spouse and any
person receiving child support, alimony, or alimony pendente lite. The transferee shall
attach a certificate of service to the notice of hearing date. A copy of the notice with the
certificate of service shall be filed with the court prior to the hearing.
BY THE COURT:
J.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson NO:
Receivables Origination, LLC and
Patrick McKnight
FINAL ORDER OF COURT
On this Day of , 2008, it is ordered that the Petition to
Transfer of Structured Settlement Payment Rights is granted.
The court specifically finds that:
(1) the payee has established that the transfer is in the best interests of the payee
or the payee's dependents;
(2) based on the certification by an attorney for the transferee, and the court
having not been made aware of any statute, regulation or order that would be
incompatible with the proposed transfer, the transfer will not contravene any
applicable federal or state statue or regulation, or the order of any court or
administrative authority;
(3) the transfer complies with the remaining requirements of the Structured
Settlement Protection Act, including Sections 3(a)(2), 3(a)(4), 3(a)(5) and
3(a)(6);
(4) the payments that are to be transferred are designated as
follows:
a. 1 payment of $50,000.00 on November 1, 2011.
(5) the terms of this order shall survive the death of the payee and shall be
binding on the payee's heirs, beneficiaries and assigns;
(6) the payee shall receive from the transferee, as of , the amount of
$30,865.00, from which no funds are owed for counsel fees, administrative
fees, or other costs, fees or expenses.
BY THE COURT:
J.
7 ,
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson NO: I ° 3v
Receivables Origination, LLC and
Patrick McKnight ,
JOINT PETITION FOR PARTIAL TRANSFER OF STRUCTURED
SETTLEMENT PURSUANT TO STRUCTURED SETTLEMENT PROTECTION
ACT, 40 P.S. 4000, ET SEO.
TO THE HONORABLE JUDGES OF SAID COURT:
And now comes your petitioner, 321 Henderson Receivables Origination, LLC,
by and through its attorneys, Maro & Maro, P.C., and joint petitioner, Patrick McKnight,
and in accordance with the applicable rules of Pennsylvania Civil Procedure, hereby
represents as follows:
1. Petitioner is 321 Henderson Receivables Originations, LLC. ("Buyer" or
Transferee"), with an office address located at 40 Morris Avenue, Bryn Mawr,
Pennsylvania, 19010.
2. Joint Petitioner is, Patrick McKnight ("Payee"), an adult individual who
resides at 100 B. Street, Plainfield, PA 17081.
3. This Joint Petition has been verified by the Transferee, 321 Henderson
Receivables Origination, LLC. and the Petition includes all necessary information as
prescribed by PA R.C.P. 229.2(d) et al and Section 3 of the Act, 40 P.S. §4001 et seq.
4. Pursuant to PA. R.C.P. No. 229.2(d)(3) there are four (4) attachments
incorporated herein as follows:
a. PA R.C.P. 229.2(d)(3)(i) Payee's Affidavit in Support of Petition.
Please see Attachment/Exhibit "I"; and
b. PA. R.C.P. 229.2(d)(3)(ii) An Initial Order of Court Scheduling
Hearing;
c. PA. R.C.P. 229.2(d)(3)(iii) A certification by Robert A. Maro, Esquire,
attorney for transferee, 321 Henderson Receivables Originations,
LLC.; and
d. PA. R.C.P. 229.2(d)(3)(iv) A Final Order of Court Granting
he Petition.
5. Joint Petitioner, Patrick McKnight, is the beneficiary of an annuity owned by
Metropolitan Insurance and Annuity Company and issued by Metropolitan Life Insurance
Company. The structured settlement provides payment to the petitioner as
described on Attachment/Exhibit "2".
6. Joint Petitioner, Patrick McKnight, was represented by independent counsel in
this transaction. Joint Petitioner, Patrick McKnight and her attorney have reviewed and
discussed the terms of this transaction together and fully understating the terms therein,
freely and voluntarily executed the Purchase Agreement, Exhibit "A" to the Purchase
Agreement and the Disclosure Statement. A letter of representation from the attorney for
Patrick McKnight is attached hereto, incorporated herein and marked Attachment/Exhibit
«3"
7. Joint Petitioner, Patrick McKnight, proposes to enter into a purchase
agreement with 321 Henderson Receivables Origination LLC., its nominees, successors,
or assigns, whose address is 40 Morris Avenue, Bryn Mawr, Pennsylvania, 19010, who
will purchase the following from Petitioner's structured settlement as follows:
a. 1 payment of $50,000.00 on November 1, 2011.
8. The structured settlement is currently owned by Metropolitan Insurance and
Annuity Company and issued by Metropolitan Life Insurance Company, and the
net amount in return payable to Patrick McKnight is $30,865.00 from Buyer. A copy of
the Purchase Agreement, Exhibit "A' to the Purchase Agreement and Disclosure
Statement is attached hereto, made apart hereof, and designated Attachment/Exhibit "4".
9. The net amount payable to the payee after deduction of all commissions,
fees, costs, expenses, and charges is $30,865.00.
10. Based on the net amount that the payee will receive from this transaction
$30,865.00 and the amounts and timing of the structured settlement payments that
would be assigned, the payee is, in effect, paying interest at a rate of 13.85% per
year.
11. The Buyer furnished Patrick McKnight with a Disclosure Statement pursuant
to 40 P. S. 4003 See Attachment/Exhibit "4") at least ten (10) days prior to the date on
which Patrick McKnight first incurred any obligation to the Buyer.
12. PA R.C.P. 229.2(b) requires the petition to be filed in the county in which the
payee is domiciled See also Section 4 of the Act 40 P.S. §4004). PA.R.C.P. 229.2(c)
also requires both the Transferee and Payee to be parties to the Joint Petition. Both
requirements have been fulfilled herein.
13. Written notice of the Transferee's Names, address and taxpayer identification
number has been given to the Annuity Issuer and Structured Settlement Obligor. A copy
of the Notice to the structured settlement obligor is attached hereto as Attachment/Exhibit
"5". Joint Petitioners wills also serve written notice as required by 40 P.S. 4004 upon
all interested parties.
14. The Joint Petitioner's best interest would be served by granting the relief
requested herein for the following reasons. Joint Petitioner is currently single and is
employed full time with Zero Chaos, Inc. located in Mechanicsburg, PA as a supervisor
making a very good salary. Joint Petitioner is not married and has no minor children.
Joint Petitioner is proposing to sell only a portion of his structured settlement, retaining
the large amount of his structured settlement as it becomes due under the terms of the
annuity. Joint Petitioner has never transferred payment before. The purpose of this
transaction is to purchase a home. Joint Petitioner has an opportunity to purchase a home
next door to the home that he grew up in and that his parents still live in. If the transfer is
approved, joint petitioner will use the fund as a down payment on the home. Joint
Petitioner makes enough money to cover the monthly mortgage payments and this is a
great opportunity for Mr. McKnight to own a home close to his parents in the area he
grew up. Based upon the above which will be expanded upon at the time of trial, the
transfer is clearly in the best interest of Mr. McKnight.
WHEREFORE, Joint Petitioner's respectfully requests this Honorable Court to
enter the Initial Order attached to this petition which shall schedule a hearing so that
Transferee and Payee shall have the opportunity to discuss the purpose and reasons for
the transfer and after hearing thereon, respectfully request that this Honorable Court enter
a Final Order approving the Transfer of Structured Settlement Payments Rights as is
mentioned herein.
Maro & Maro, P.C.
Respectfully Submitted:
By:
for Transferee
VERIFICATION
I, Maureen Healy, Vice President of 321 Henderson
Receivables Origination LLC, have read the foregoing Petition to Transfer Structured
Settlement Payment Rights between 321 Henderson Receivables Origination LLC and
Patrick McKnight and hereby aver that the statements contained therein are true and
correct to the best of my knowledge, information and belief.
This Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to the unworn falsification to authorities.
C964
Maureen Healy, VP
2.25.08
Date
CERTIFICATION OF ATTORNEY FOR TRANSFEREE
I, Robert A. Maro, Esquire, attorney for Transferee, 321 Henderson Receivables
Originations, LLC., hereby certify to the best of my knowledge, information and belief,
formed after reasonable inquiry, that the Transfer will comply with the requirements of
the Act (40 P.S. § 4000 et seq.) and will not contravene any other applicable federal or
state statute or regulation or the order of any court or administrative authority.
I, Robert A. Maro, Esquire, attorney for Transferee, 321 Henderson Receivables
Originations, LLC., hereby verify that the facts and statements set forth herein are true
and correct to the best of my knowledge, information and belief. I understand that false
statements made herein are subject to the penalties of 18 Pa. C.S.A. Section 4904 relating
to unsworn falsification of authorities.
,1-3.s-na
Date
?obert A. Mar6,vEsquire
Attorney for Transferee, 321
Henderson Receivables Originations,
LLC.
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson NO:
Receivables Origination, LLC and
Patrick McKnight
CERTIFICATE OF SERVICE
I, Robert A. Maro, Esquire, hereby certify that a true and correct copy of the
Petition for Transfer of Partial Structured Settlement has been served upon the following
entities via first class mail and/or certified return receipt requested and/or email on :
Metropolitan Life Insurance Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Patrick McKnight
100 B Street
Plainfield, PA 17081
Metropolitan Insurance and Annuity Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Date: X - ?-S_ o a
By:
Lawrence J. Rosen, Esquire
Krevsky & Rosen, P.C.
Attorney for Patrick McKnight
1101 N. Front Street
Harrisburg, PA 17102-3324
,Zoberf A. Mafo, Esquire
Attorney for 321 Henderson Receivables
Originations, LLC.
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson NO:
Receivables Origination, LLC and
Patrick McKnight ;
Entry of Appearance
TO THE PROTHONOTARY/CLERK OF SAID COURT
Enter my appearance on behalf of. 321 Henderson Receivables Origination, LLC.
Papers may be served at the address set forth below.
Respectfully Submitted:
Maro &
By: _ /`/t&? U
Pkobert A. Maro, Esquire
Attorney I.D. No 89585
' Maro & Maro, P.C.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600(office)
(610) 275-9666(Fax)
ATTACHMENT/EXHIBIT "1"
Payee's Affidavit in Support of petition for Transfer of Structured Settlement Rights.
1. A Praecipe to Attach same will be filed with the court prior to the time of
hearing.
ATTACHMENT/EXHIBIT "2"
• Meftiofd •
MsVopotltan LAs Insurance Company
One Madison Avenue, New York, NY 10010-3690
Metropolitan life insurance Company (heroin called MetLffe) i:ertifies that it will
make the psymente described In this certificate.
Group Annuity Contract No.
$281
Certificate No.
74755
Measuring We
/
Patrick McKnight
Date of Birlh of Measuring Life
May 4, 1984
Owner
Metropolitan Property and Casualty Company
Annuity Commencement Date
November 1, 2006
Beneficiary (if any)
Estate of Patrick McKnight
porm GL4324A
,dov-b,
01
Q
r?
hJ
N
cr?
CO
Y
MR 39dd -1NI SNOISN3WIQ ZtGLTGLLTL ZS:ET 800Z/TT/Z0
• 0 G
Payment of Annuity: Metl.ife will make payments under this certificate as follows: to
4
MetLife will make the payments shown below to the payee named by the r.
However, if the Manuring Y.& is not living on the date any such payment is payable,
and unless the Owner directs otherwise, MetLife will pay such payment to the
Beneficiary.
N
Date of Payment G
mot v
November 1, 2006 525,000.00 /
November 1, 2011 550,000.00 f
November 1, 2016 .. $74,093.00
Fdm M4324A 131
Z0/Z8 39Vd -UNI SNOISN3VIQ Zb6LT6L111 LS:61 800Z/TT/Z0
Meftifer
Mr. Patrick McKnight
100 B Street
Plainfield, PA 17081
RE. Annuitant: Patrick McKnight
Annuitant #: 74755M
Owner: Metroliiwian-Property & Casualty Company
Dear Mr. McKnight:
Per your request, enclose, please find a copy of the above-mentioned certificate Living detail of
payments that you are entitled to as payee. The schedule of payment is listed on page (3) of the
Certificate.
Pkase keep this certl, Bate in a safe place for ftrture reference,
Metropolitan Property 8c'C alty Company owns this structured settlement referenced above.
All rights incident of ownersbi of this annuity reside with the' owner of the annuity. , ' .
Please be, advised that i#-order to obtain a copy of the original settlement agreement you would
need to contact the Attorney who settled the case or the court where the case was settled.
THIS IS A STRUCTURED SETTLEMENT ANNUITY AND CANNOT BE ASSIGNED OR
USED AS COLLATERAL ON A LOAN. PAYMENTS CANNOT BE ACCELERATED,
DEFERRED, INCREASED OR DECREASED. THIS IS A TAX-FREE BENEFIT WITH NO
CASH PROVISION OR SURRENDER VALUE ALLOWED,
Should you have any further questions, please contact our Customer Serviee Center at 1-800-638-
2704. Consultants are available Monday through Friday during the hours of 8:OOAM till 11:00PM
Eastern Standard Time.
Sincerely,
EM-V 6--41
as. Pt?
Senior Structured Settlement Consultant
Registered Representative
ARC
January 31, 2008
DCN# 080116000058
Metropolitan Lifer Insurance Company (MLIC), New York, NY 1-0166. Securities offered by
MetLife Securities;'1'no., (MSn (FIN jVSIPC). MLIC-and:MSI are affiliatm. '
b0/Z0 39tid -UNI swi%34ia Z176LTGLZTL ZS:CT 800Z/T1/Ze
0 0
Rights ' f Owner. The Owner owns the annuity described in this certifx*e. 'The
Owner ill have the right at any time to designate the payee, including the Beneficiary,
to wh benefits are payable under the annuity. However, unless the Owner otherwise
directs, atLife will make all payments under the annuity to the person(s) named In the
cerlitice
In additi , at any time after the death of the Measuring Life, the Owner may direct
MetL ft ?D pay, in lieu of any term certain annuity payments described M this certificate,
the commuted value of all remaining term certain annuity payments in a single sum to a
payee npr>ned by the Owner. The commuted value of such annuity payments will be
calcuta d using the same interest rate(s) as that used in determining the purchase
price of annuity.
No such, change in payee or terms of payment will be effective until written notice of the
change a received by MetLie. However, any change in a EWWclary designation will
take efft ct as of the date the request was signed but without prejudice to Meti..ffe on
account of any payment made by it before receipt of the request. When contacting
MetL,ite the Owner should mention the Contract number and the name and certificate
number of the Measuring Life.
Proof o l Mett.ife may require proof that the Measuring Life, the Beneficiary or
other pa? Liee, as the can may be, is living on the date on which any annuity payment is
to be e. If proof is requested, no payment will be made until the proof has been
received by MetLife.
Benefl : If two or more Beneficiaries are designated and their respective interests
are not cified, their interests will be several and equal.
Change or Waiver: No sales representative or other person, except an authorized
officer MetLffe, may make or change any certificate ar make any binding promises
about a y certificate on behalf of MetLife. Any amendment, modlfFcation or waiver of
any pro sion of this certiflcata wi11 be in writing and may be made efl`ective on behalf of
Mett.lfe my by an authorized officer of MetLife.
Mhm tat.qmen%: If the age or seat of the Measuring Life or any other relevant fact has
been misstated, McWfe will not pay a greater amount of annuity than that provided by
the actu I amount received to purchase the annuity and the correct information. Any
overpay?rient of annuity will, together with interest, be deducW from future annuity
payments Any underpayment of an annuity will, todsther with interest, be paid
immed ly upon receipt of the corrected information. The interest rate(s) will be that
used In To termining the purchase price of the annuity.
Nonasnabtlity; Claims of Creditors: This certificate. and the payments provided
under re nonaseignable. and will be exempt from the claims of credit= to the
maxims extent permitted by law.
Fwm G.4*4A (2)
,Oo pal
Q
ra
h?
v,
w
170/00 3Stld '11NI SNOISN3WIa Zb6L16UTt ZS:ET 800Z/11/Z0
ATTACHMENT/EXHIBIT `13"
X'Xe? &aye?,- W..
COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-3324
Sanford A. Krevsky
Lawrence J. Rosen
Joshua M. Goldberger
February 18, 2008
J.G. WENTWORTH
40 MORRIS AVENUE
BRYN MAWR, PA 19010
To Whom it May Concern:
Tel. (717) 234-4583
Fax (717) 2343650
I have provided representation to Andrea Patrick McKnight on the structured settlement
matter.
I have provided him with legal, tax and financial advice regarding same.
Sincerely,
Lawrence J. Rosen
LJR: alr
ATTACHMENT/EXHIBIT "4"
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 10
Account ID: 356823
This Is a Purchase Agreement. The date of this Agreement is 200Patrick Mcknight is
the Seller. 321 Henderson Receivables Origination LLC, a Nevada Limited Liability Company, its
successors and/or assigns is the Buyer. In this Agreement, Patrick Mclmight is refereed to as "You" or
"Your" sued 321 Henderson Receivables origination LLC or its nominee, is referred to as "We", "Us" or
Our' .
BACKGRQUIVII) T
1. You or someone on your behalf signed a Settlement Agreement (the "Release" or the
"Settlement Agreement'), in connection with the resolution of a personal injury claim.
2. Tice insurer funded the Payments by buying an annuity contract (the "Annuity") issued by
Metropolitan Life insurance Company (the "Annuity Company").
3. A list of the Payments being sold under this Agreement is attached to this Agreement as
Exhibit "A".
4. You desire to sell and assign to Us all of Your rights to receive all or a portion of the Payments
under the Release, as described on Exhibit "A", all of the other rights You have under the Release and the
other rights as described in Section 1(a) below. We desire to purchase all of Your rights and benefits, on
the terms and under the conditions described in this Agreement.
You and We agree as follows:
11. Pure aa_ _d Sate.
a. You now sell, transfer and assign to Us all of Your rights in the "Assigned Assets" as
listed in Exhibit "A". By Our sighing this Agreement, We are hereby pumbasing and
accepting the sale and assignment of all of the Assigned Assets described aboV57O0(the
b. The Dross Purchase Pri is TilhtyThree Thousand Six Hundred Fifteen and
00/100 Cents (533,61 ). The Net Purchase Price payable to You is $30, "purchase Price"). The Net Purchase Price will be paid to You when both You and We
sign this Agreement and We have completed Our internal process.
2. Ackmowkdnmenc
it, You will agra after Your signing of this Agreement to deliver to Us, addressed as We
may require, other notices, instructions or documents, and copies of them, as we think
are necessary or proper to carry out this Agreement.
b. When You and We sigh this Agreement, You wlU also deliver to Us: (1) a letter
addressed to the Annuity Company directing that all payments of the Assigned Assets
after Your death shall be semt directly to Us, and (2) a Change of Beneficiary Form
changing the beneficiary of the Assigned Assets, after Your death, to "321 Henderson
Receivables Origination LLC", as sole beneficlary [(1) and (2) above are refernd to as
the Change of Beneficiary Form]. The Change of Beneficiary Form wiU state that the
instructions may never be revoked and that no change may be made in the instructions or
®2007 321 Headenae RaceiYM@s United PatnmWp
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 11
AccountlD: 356823
in the payments (including as to the payee or the manner or place of making such
payments) without Our prior written consent You will also, wben this Agreement is
signed by You and Us, deliver to Us, addressed as We may require, such other notices,
instructions or documents, and copies of them, as We think are necessary or proper to
canny out this Agreement.
c. Before You and We sign this Agreement, You will deliver to Us an acknowledgment of
'The Estate of Patrick McKnight, as primary beneficiary of the Assigned Assets, of the
terms of this Agreement. The Estate of Patrick McKnight will agree that they are not
entitled to any rights to any of the Assigned Assets.
d. You agree to sign all other documents which We may request forever naming Us as the
only beneficiary of the Assigned Assets, including but not limited to an agreement to
provide In Your Last Will and Testatoont that all of Your rights to the Assigned Assets
were sold to Us (a "Testamentary Agreement").
e. You acknowledge that We advised You to obtain independent professional tax advice to
determine whether this transaction will result in any adverse federal and/or state taut
consequences.
f. You acknowledge that We advised You must obtain independent legal representation
Prior to executing this Agreement and that We have advised you that We may not refer
You to any specific attorney for such propose,
3. Your resentathm and w¦rraatba You now represent and warrard to Us that:
a. You own (and are selling and assigning to Us under this Agreement) all of the
Assigned Assets, free and clear of all claims, liens, charges, security interests,
encumbrances, and agreements of any nature (other than this Agreement), and
when You and We sign this Agreement, no one other than Us shall have any
present or future right to the Assigned Assets.
b. This Agreement and all of the other documents signed in connection with this
Agreement have been properly signed by You, and they represent Your legal,
valid and binding obligation, enforoeable against You in accordance with their
terms.
c. The signing and performance of this Agreement by You and the transactions
described in this Agreement:
I. do not conflict with any other obligadoos of yours;
ii. will not cause a violation under (or create any right of termination,
cancellation or acceleration or similar right under) any contract or
agreement by which You or Your assets, including the Release, are
bound or may be affected;
iii, will not create, or give any party (other than Us) the right to create, any
lien, charge, security interest or encumbrance in, to or on any of the
Assigned Assets; and
iv. will not create a present or future right in any other party to make any
claim against You or Your assets, or any of the Assigned Assets.
®22007 321 Madam RmcivaWs t.W%d rwoxnWp
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 12
Account TD: 356823
d. You wedersnhnd the terms and provisions ofthis Agreement sad you have been
reputed by tax and accounting advisors and a lawyer in the signing of this
Agreement.
e. Neither You nor anyone else have to do anything else for (1) the proper signing
and performance by You of this Agreement and any transactions intended to be
done in this Agreement, or (2) the carrying out by Us of any of Our rights and
remedies under this Agreement. No other person has made a claim in any rights
in or to the Assigned Assets.
f You have valid reasons for selling Your ieet iv* in the Assigned Assets rather
than obtaining a loan with the Assigned Assets as collateral, and You agree that
the transaction set fords in this Agreement Is not a loan or other financing
transaction.
g. This Agreement is a valid We, transfer and assignment to Us of the Assigned
Assets.
h. Your residence and legal address is as described in Paragraph II of this
Agreement, During the last years, You have lived at such address.
i. No representation or warmty of Yours in this Agreement or in any of the
documents delivered in connection with this Agreement or in any agreement
required by this Agreement, is inaccurate or contains any untrue or misleading
statement.
j. The signing by You of this Agrament will not violate any other promise or
agreement you bave made with anyone else. You understand that any and all
restrictions on the assignability of the Scheduled Payments were included in the
Release and/or Annuity at Your request, for Your benefit and not for the benefit
of any other person. These restrictions, if any, were included by You as a
precautionary measure to snake sure You were allowed favorable tax treatment
under the Internal Revenue Code. You understated that by entering into this
Agreement, you may be giving up this favorable tax treatment You understand
that any income earned by You on any investment or use of the Purchase Price
may be taxable to You. You may have to pay tMOre in Mes as a result of this
Agar =nt. For Our benefit and the bow & of Our assigns or successors, You
agree to WAIVE AND RELEASE all of Your rights in, to, or under, such
restrictions on assignability, if any.
k. You have not before the date of this Agreemen; sold or sniped Your right to the
Assigned Assets or any part of the Assigned Assets. You do not owe any money
to Your present or forma spouse for support maintenance or similar obligations,
nor do You owe any money to any of Your children or guardians of Your
children. The Assigned Assets are not subject to any community property or
similar marital rights of any person.
10
@2007 321 Headm a Reeeivabtes Liedted Ptrrtao Wp
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 13
Amount ID: 356823
1. Your right to the Assigned Assets is not affected by any mortgage, pledge, lien,
charge, security interest, encumbrance, restriction or adverse claim of any
nature. You understand that any violation of any of Your representations in
this agreement will raault in an act of fraud by You which cnW result in
You being held responsible for damages is favor of Us, with money to be
paid by You to Us.
m. You are not in viObdion of any obligations concerning child-can, alimony or
support.
n. You now give up forever all Your rights in any agreement that says that You
cannot assign or sell Your rights in the Assigned Assets to Us. You have not
requested and You do not expect to receive from Us, a Forum 1099 or any other
documentation which could make the transaction described by this Agreement
taxable to You in any way. You fiudher understand that We have not given to
You any advice about any of Your taxes in this bmsactiion, You have relied on
Your own professional advisors concerning taxes.
o. As of the date of this Agreement, You are of legal age in the state noted as Your
address in Section 11 of this Agreement, mentally sane, and of s sound mind,
You have never been convicted of a felony or any other crime involving
dishonesty.
p. You are very familiar with Your financial affairs and condition. With that full
understanding, You certify that (1) on the date We pay You the Purchase price
and You sell to Us the Assigned Assets, the fair value of Your assets am and
will be greater than all of Your debts; (2) You presently intend to pay all of
Your creditors when such payments are due; and (3) You have not intentionally
hidden the fact 11rom any creditor of Yours that You have entered into this
Agreement and the other documents refaced to in this Agreement.
q. You do not intend to file for bankruptcy and them are no lawsuits or other
efforts by any of Your creditors to put You into bankruptcy or to take the
Assigned Assets.
r. The Pt chase Price is not Your only or most important source of income and
You do not have any mental or physical problems that would prevent You from
having a paying job.
s. You promise to us that no broker, finder, or other person other than those
pennons named in the broker statement signed by you in oo nection with this
Agreement was involved in or Important in arranging the purchase transaction in
this Agreement. No other person has a right to any fee, payment, commission,
or other compensation because of this Agreement
t. You agree that We have not forced you to give to Us copies of any confidential
documents. You agree that We told You that We only needed to see those
documents which described the Assigned Assets so we could bury from You the
Assigned Assets. You ague that We do not intend to tell any other party about
what is included in those documents. You understand that if We do so, it will
only be for the sole purpose of buying the Assigned Assets.
11
®2007 321 Henderson Rewivablcs t.imhod PzMcnWp
02;19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 14
AccouatlO: 356823
U. You understand that h usually takes six to eight weeks to compkte this process,
but that it could take longer. You undawand that you have to obtain court
approval of this transfer. YOU UNDERSTAND THAT, DUE
TO OCCASIONAL DELAYS, WE WILL HOLD
BACK THE AMOUNT EQUAL TO THE NEXT
TWO MONTHLY PAYMENTS DUE TO YOU
FROM THE ANNUITY COMPANY TO INSURE
THAT WE RECEIVE ALL OF THE PAYMENTS
THAT WE PURCHASE. YOU UNDERSTAND
THAT WE MAY EITHER PAX OR HOLD HACK
FUNDS TO SATISFY ANY JUDGMENTS, TAX
LIENS OR CHILD SUPPORT AGAINST YOU OR
THE ASSIGNED ASSETS AND DEDUCT THOSE
AMOUNTS FROM THE PURCHASE PRICE. YOU
UNDERSTAND THAT WE WILL DEDUCT FROM
THE PURCHASE PRICE ANY AMOUNTS OF
PAYMENTS RECEIVED BY YOU PRIOR TO
FUNDING, IF SUCH AMOUNTS ARE NOT
COVERED BY THE HOLD BACK FUNDS.
4. You Promise Us that:
a. You will not, and will not allow any other party (except Us or Our assignee,
if applicable) to take funds away from the Assigned Assets. You will not
do anything else to affect the Assigned Assets, You will not say You still
own the Assigned Assets. You will not do anything or allow anyone else
to do anything that could in any way interfere with or lessen Our rights in
the Assigned Assets.
b. You will not do anything that will, or could in the faun. violate the
Release, or any of the agreements required to be executed by this
A"ment. You also agree to cooperate with Us to help Us to obtain all of
the rights that We are buying from You in this Agreement and in the
Release.
c. You will give to Us at least thirty (30) days written notice of Your intention
to move Your residence or change Your legal address ft m the address in
Paragraph I I of this Agreement
d. You will not make any change in Your instructions to the Annuity
Company regarding paylatents to be made to You.
12
(§12007 321 HaA mn RmivaWn LimiW Partnership
02/19/2006 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 15
Account ID: 356823
You understand that the Annuity and the Release may say that You agree
not to sell Your rights to the Assigned Assets,
You agree to continue to cooperate with, Us. This includes Your obligation
to immediately deliver to Us any checks, funds or other form of Payment
received afl at the date of this Agreement by You or anyone other than Us. If
any Payment is ever denied, delayed, or withheld from, Us, as determined by
Us in our reasonable discretion, directly or indirectly on account of any act
or omission by You or any person acting fbr You, then You shall be in
default under this Agreement (and an Event of Defbuh under 18 shall be
deemed to have occurred). bmmiiately upon such default, and without any
f knher notice to you, you will pay to Us the following amounts:
(i) the full, dollar value of all remaining Assigned Assets as they
become due after the date of the default;
All of the remedies specified under this section shall be cumulative with all
of the remedies for default pursuant to 58.
g. If You learn before or after the signing of this Agreement of the threat or
actual beginning of any lawsuit or proceeding that has anything to do with
Our rights under this Agreement or the Assigned Assets, then You will
immediately notify Us of that and You will give Us copies of all notices and
other writings relating to It promptly after You receive them.
If You receive any notice relating to any supposedly unpaid claim affecting
the Annuity or the Assigned Assets or to any other claim against the
Annuity or the Assigned Assets, theta You will promptly notify Us and will
promptly give Us copies of all notices and other writings relating to it
received by You promptly after You receive them.
5. RIGHT T CANCE LATIQN, YOU MAY CANCEL, THIS CONTRACT
WITHOUT PENALTY OR FURTHER OBL CATION WITHIN TWENTY-ONE DAYS FROM THE
DATE YOU RECEIVE PAYMENT FROM 321 HENDERSON. In order for the cancellation to be
effective, You must mail a notice of cawceRation by registered or certified U.S. mail, postmarked within
twenty-one (21) days of receipt of the Purchase Price to Us, e% Manager of Operations at 3993 Howard
Hughes Parkway, Suite 250, Las Vegas, NV 89169-6754. Furthermore, in order for Your notice of
cancellation to be effective, Your registered or certified U.S. mail package to us must include a bank or
certified check for the full Purchase Price that We paid You under this Purchase Agreement. Any failure to
comply with the above procedure shall be a waiver of Your right to cancel this transaction.
6. Your F¦rther Promb", You "that. from time to time, at Your expense, You will
promptly sign and give to Us any and all documents to help Us realize our rights and beaefirts under this
Agreement. This promise includes signing, filing or allowing Us to file fmanci ng or continuation
statements, or amendments or assignments of those documents. You permit Us or others acting for Us to
sign our name and/or your name and file without Your signature such financing stocu ms, if that is
permitted in Your state of residence. When You sign this Agreement, You will also sign and deliver to Us
a "Special In vocable Power of Attorney" You must retain the services of an attorney and deliver an
opinion of Your attorney about the sale of Assigned Assets to Us, in it form acceptable to Us.
13
@=7 321 Hie AMw Raovivsbla Umitsd Ps embip
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 16
Account ID: 356823
7. R All of Your
representations, warranties and promises made in this Agreement will continue to be relied on by us after
this Agreement is signed.
8. Runt of Dahult. Your failure to comply with any term of this Agreement or Your
breach of any of Your representations in this Agreement will traces that You will be in default. We refer to
this as an "Event of Default." If there is an Event of Default, We have the right to sae you in court to make
You perform Your promises or to get money from You. Your Mlwv to comply with any material terms of
this Agreement will be a default.
In Paragraph 4 (c) You agree to give US at least thirty (30) days written notice after Your move to
a now residence or change of Your legal address from the address in Paragraph 1 I of this Agreement. If we
are purchasing from You certain lump sum payments, We will contact you at least 3 months before the
scheduled payment is due to determine if the address change We have offected with the annuity company is
in place and to determine if Your legal address has remained the same. If We cannot contact yon because
You have changed Your legal addraas or moved Your residence and failed to soft Us, We will
consider such (allure to notlty Us to be as EVENT OF DEFAULT and We will exercise all of our
legal rights nrsder this AgreemeaL OUR RIGHT TO PROCEED AGAINST YOU UNDER THIS
AGREEMENT SHALT. BE SOLELY LIMITED TO WHEN YOU HAVE COMMITTED AN
EVENT OF DEFAULT. WE SHALL NOT HAVE THC RIGHT TO SUE YOU IF OR BECAUSE
THE ANNUITY COMPANY IS NOT ABLE TO MAKE PAYMENTS BECAUSE IT IS NOT
FINANCIALLY ABLE TO DO SO.
9. Controlling law, This Agreement shall be governed, construed and enforced in
accordance with the internal laws of the State of your domicile without regard for the eoaflfcts of law rules
thereof or elsewhere. (For Court Orders or Notice Transfers obtained in the following jurisdictions: AK,
AR, AL, AZ, CA, CO, CT, DE, FL, GA, Hl, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO,
MS, MT, NC, NE, NJ, NM, NV, OH 01C, OR, RI, SC, SD, TN, TX, UT, VA, WA, WV and WY the laws
of those jurisdictions shall be applied in the event of a dispute regarding the transfer,) Your domicile is the
proper place of venue to bring any action arising out of a breach of thus Agreement.
10. Responsibility for this AgMement. This Agreement will hold responsible Your heirs,
executors, successors and assigns and will benefit Our representatives, successors, beneficiaries and
permitted assigns. Nothing in this Agreement is intended to give anyone other than, You or Us or each of
Our successors or assigns any benefits.
11. Notices. All notices and other communications under this Agreement will be in writing
and will be made by delivery by means by which the sender obtains a receipt of delivery from the carrier
(including without limitation, certified nail return receipt requested or overnight 0ou rier services),
addressed to the patty to whom a request or demand is to be made. Such demand or notice or request shall
be deemed given on the date which is one business day after the date sent by overnight mail or three days
after the date sent by certified mail.
The addresses of the parties are as follows:
If to You:
Patrick Mcknight
100 B St
Plainfield, PA 17081
14
®2007 321 Hawlmw Rs*vWla Limited Pulambip
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PACE 17
Account Da: 356823
If to us:
321 Henderson Receivables Origination LLC
3993 Howard Hughes Parkway
Suite 250
Las Vegas, NV 89169.6754
Attention: Manager - Operations
12. Past Actiom. Anything either You or We did or said before this Agreement was signed
will not affect Your or Our rights under this Agreement in any way.
13. Fr M Except as otherwise affirmatively set forth in this Agreement, You and We
agree that we will each pay our respective costs and expenses in connection with the carrying out of this
Agreement.
14. Headion. The section and subsection headings contained in this Agreement are for
reference purposes only and will not affect in any way the meaning or interpretation of this Agreement.
15. Counterparts. One or more originals of this Agreement may be signed with Your or Our
signature. When put together they will make one agreement and the Agreement will be considered signed
by all parties that need to sign. A facsimile signature will be considered an original.
16. Atlt;nment. We and anyone to whom We assign this Agreement may assign Our tight,
title and interest in and to this Agreement, the Annuity and the Assigned Assets without Your approval.
You and We, agree that if there is an assignment by Us to someolxe else, We shall not be responsible to
You. You must look only to the person or company that We assign this Agreement to for any payment (far
example, of the Purchase Price) and performance of this Agreement. When, asked by Us or any assignee,
You will sign and deliver any such documents as We may require to perform this transaction, as assigned.
17. Your_ spouse. You and Your spouse are fully aware of Your rights in the Assigned
Assets. You and Your spouse fully give up those rights. You and Your spouse understand that by selling
the Assigned Assets to Us, You and Your spouse are not receiving the same amount of money as You
would if You waited for all of the scheduled payments of the Assigned Assets but, rather, are receiving a
discounted value in return for receipt of the Purchase Price immediately. You and Your spouse have valid
reasons for selling the Assigned Assets. You and Your spouse fully understand the terms of the Purchase
Agreement and understand that the sale of the Assigned Assets is final. You also understand that Your
spouse gives up any property right he or she may have in the Assigned Assets that Your spouse could claim
because of Your marriage.
18. Entire Agreemnn This Agreement and the ExxIdbits and other documents You signed
make up the entire understanding and agreement between You and Us about this Agreement. This
Agreement replaces all prior agreements, whether written or oral, about this Agreement. This Agreement
may not be changed unless in a writing signed by You and Us.
19. Limftadon of iab i of IguygL. You understand that Our liability to You under this
Agreement is strictly limited to the requirement to pay the Purchase Price and under no circumstances will
We be responsible for consequential damages.
20. Coy Approval. You understand that court approval is required for this transfer.
You agree that you will obtain such court approval.
IS
@M7 321 Hetbmwn Receivables Limited Partnership
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 18
Account ID: 356823
21. &hLbIb.
Exhibit "A"
Attached to this Purchase Agreement are the Wowing Exhibits:
List of What Payments We are Buying.
Intending to be legally bound, You and We have signed this Agrament as of the due w the top of
the first page of this Agreement.
321 HENDERSON RECEIVABLES ORIGINATION LLC
Sworn to and so ribed
before we this day e1`2 00?
Notary
-w
IMMA I ft; am,
No" 8itlitft
Cfllr O Mow CIIMf v
M1t OIWJPA m Imam AW 17.1!011
d5xa?
By:
Vice President-0petbtions
Patrick Mckni SIGN HERE
Spouse
16
02007 321 Hepdmm RwWv*les limited Pvtoaft
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC
We are hereby purchasing from You under the ,Annuity:
A) 1 payment of $50,000.46 on November 1, 2011
Patrick Mcknight SitiN t RE
PAGE 19
Account ID: 356823
F
STATE OF P
COUNTY Y OF ;
On this ay of 200% before me, the above signed personally appeared before ate, personalty known to
me to be the person whose name Is subscribed to the within instrument and aekeowledged to me that he executed it.
' `-''rte
Notary
aaaaa?
NOM11111% W4
AlllllllltM
IiIM?fM? CAK OAI P110 COi1 iff
t1M OWN"" "an go 1!. !M 1
Nowammmmu?
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 05
Account ID: 356823
SCHEDULE 1
DISCLOSURE STATEMENT
PLEASE BE ADVISED THAT THE PROPOSED TRANSACTION IS A
SALE, NOT A LOAN, AND THAT YOU WILL BE SELLING ALL RIGHT'S
AND TITLE TO THE ASSIGNED ASSETS ONCE THIS TRANSACTION
IS CONSUMMATED. PLEASE BE ADVISED THAT YOU MAY BE
SUBJECT TO ADVERSE FEDERAL AND STATE INCOME TAX
CONSEQUENCES AS A RESULT OF THE PROPOSED TRANSACTION.
YOU SHOULD CONSULT YOUR OWN COUNSEL, ACCOUNTANT, OR
FINANCIAL ADVISOR REGARDING ANY FEDERAL OR STATE
INCOME TAX CONSEQUENCES ARISING FROM THE PROPOSED
TRANSFER.
YOUR PURCHASE PRICE WAS DERIVED ASSUMING A DISCOUNT
RATE SIGNIFICANTLY HIGHER THAN THE PRIME INTEREST RATES
CHARGED BY COMMERCIAL BANKS, THEREFORE, WE URGE YOU
TO EXPLORE ALL FINANCIAL OPTIONS.
WE WILL PURC ASE FROM YOU A) 1 payment of S30,0 .00 on
November 1, 201
[THE REMAINDER OF THIS PAGE LEFT BLANK INTENTIONALLY]
i
02/19/2006 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 06
' PAGE 2
AccountlD: 356823
THE AGGREGATE AMOUNT OF THE PURCHASED PAYMENTS IS
$50,000.00.
THE DISCOUNTED PRESENT VALUE OF THE AGGREGATE
PAYMENTS AT 4.20% IS $42,906.62. THE DISCOUNTED PRESENT
VALUE IS THE CALCULATION OF THE CURRENT VALUE OF THE
TRANSFERRED STRUCTURED SETTLEMENT PAYMENTS UNDER
FEDERAL, STANDARDS FOR VALUING ANNUITIES. THE GROSS
AMOUNT PAYABLE TO SELLER IS $33,615.00.
THE FOLLOWING EXPENSES ARE INCURRED BY THE SELLER
(YOU) AND WILL BE DEDUCTED TROM THE PURCHASE PRICE:
COMPLIANCE AND ADMINISTRATIVE FEE: $750.00 ,/
LEGAL FEES TO PROCURE COURT APPROVAL (THIS IS AN
ESTIMATE OF WHAT YOUR ATTORNE WILL CHARGE YOU TO
OBTAIN COURT APPROVAL) : $500.00
FILING AND RELATED EXPENSES FEE: $1,500.00
THE NET AMOUNT PAYABLE TO THE SELLER(YOU) IS $300865.00.
NO OTHER EXPENSES ARE INCURRED BY YOU.
THE DISCOUNTED PRESENT VALUE OF PAYMENTS SHALT, BE
CALCULATED AS FOLLOWS: THE APPLICABLE FEDERAL RATE
USED IN CALCULATING THE DISCOUNTED PRESENT VALUE IS
4.20%.
THE EFFECI7VE ANNUAL DISCOUNT RATE FOR THIS
TRANSACTION IS 13.85%. THE CASH PAYMENT YOU RECEIVE IN
THIS TRANSACTION FROM US WAS DETERMINED BY APPLYING
THE SPECIFIED EFFECTIVE ANNUAL DISCOUNT RATE,
COMPOUNDED MONTHLY, TO THE TOTAL AMOUN'T' OF FUTURE
PAYMENTS TO BE RECEIVED BY US, LESS THE TOTAL AMOUNT OF
COMMISSIONS, FEES, COSTS, EXPENSES AND CHARGES PAYABLE
BY YOU.
•
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 07
3CHEDULEI.PAGE3
Account M: 356823
THE NET AMOUNT THAT YOU WILL RECEIVE FROM US IN
EXCHANGE FOR YOUR FUTURE STRUCTURED SETTLEMENT
PAYMENTS REPRESENTS 71.90% OF THE ESTIMATED CURRENT
VALUE OF THE PAYMENT'S BASED UPON THE DISCOUNTED VALUE
USING THE APPLICABLE FEDERAL RATE.
THE QUOTIENT OBTAINED BY DIVIDING THE NET PAYMENT BY
THE DISCOUNTED PRESENT VALUE IS 71.90%.
BASED ON THE NET AMOUNT THAT YOU WILL RECEIVE FROM US
AND THE AMOUNTS AND TIMING OF THE STRUCTURED-
SETTLEMENT PAYMENTS THAT YOU ARE TURNING OVER TO US9
185-;?E4RR IN EFFECT, BE PAYING INTEREST TO US AT A RATE OF
YEAR. THE NET AMOUNT PAID TO YOU (THE PAYEE)
THE E TRANSFEREE) REPRESENTS AN ESTIMATE OF THE
FAIR MARKET VALUE OF THE FUTURE PERIODIC PAYMENTS
TRANSFERRED UNDER THE STRUCTURED SETTLEMENT
AGREEMENT.
NOTICE OF CANCELLATION RIGHTS:
YOU MAY CANCEL THIS TRANSACTION AT ANY TIME PRIOR TO
5:00 P.M. OF THE TWENTY-FIRST DAY FOLLOWING THE LATER OF
THE EXECUTION OF THE PURCHASE AGREEMENT, OR THE DATE
THE PAYEE BECOMES OBLIGATED UNDER THE PURCHASE
AGREEMENT WITHOUT PENALTY OR FURTHER OBLIGATION.
THIS CANCELLATION RIGHT CANNOT BE WAIVED IN ANY
MANNER.
TO CANCEL, YOU MUST PROVIDE WRITTEN NOTICE TO THE
TRANSFEREE. WRITTEN NOTICE SHOULD BE MAILED OR
DELIVERED TO THE ADDRESS BELOW BY 5:00 P.M. OF
(THE TWENTY-FIRST DAY FOLLOWING THE TRANSACTION). IT IS
BEST TO MAIL IT BY CERTIFIED MAIL, RETURN RECEIPT
ph
02/19/2008 15:03 7172343650 KREVSKY AND ROSEN PC PAGE 08
Accowt ID: 356823
S ULE 1. PAGE 4
REQUESTED, AND TO KEEP A PHOTOCOPY OF THE SIGNED FORM
AND YOUR POST OFFICE RECEIPT. ADDRESS TO WHICH
CANCELLATION IS TO BE RETURNED:
321 HENDERSON RECEIVABLES ORIGINATION LLC
3993 HOWARD HUGHES PARKWAY
SUITE 250
LAS VEGAS, NV 89169-6754
ATTENTION: MANAGER -OPERATIONS
IMPORTANT NOTICE: YOU ARE STRONGLY URGED TO CONSULT
WITH AN ATTORNEY WHO CAN ADVISE YOU OF THE POTENTIAL
TAX CONSEQUENCES OF THIS TRANSACTION.
PLEASE BE ADVISED THERE ARE NO PENALTIES OR LIQUIDATED
DAMAGES PAYABLE BY YOU IN THE EVENT OF ANY BREACH OF
THE TRANSFER AGREEMENT BY YOU. THERE ARE NO BROKERS
COMMISSIONS, SERVICE CHARGES, APPLICATION FEES,
PROCESSING FEES, CLOSING COSTS, FILING FEES,
ADMINISTRATIVE FEES, LEGAL FEES, NOTARY FEES AND OTHER
COMMISSIONS, FEES, COSTS, EXPENSES AND CHARGES PAYABLE
BY YOU OR DEDUCTED FROM GROSS AMOUNT OTHERWISE
PAYABLE TO YOU OTHER THAN THE COMPLIANCE AND
ADMINISTRATIVE FEE AND THE FILING AND RELATED EXPENSES
FEE.
IF YOU BELIEVE YOU WERE TREATED UNFAIRLY OR WERE
MISLED AS TO THE NATURE OF THE OBLIGATIONS YOU ASSUMED
UPON ENTERING INTO THIS AGREEMENT, YOU SHOULD REPORT
THOSE CIRCUMSTANCES TO YOUR LOCAL DISTRICT ATTORNEY
OR THE OFFICE OF THE ATTORNEY GENERAL.
THE EFFECTIVE DATE OF THE TRANSFER AGREEMENT SHALL BE
DEEMED TO BE THE DATE THAT THE AGREEMENT WAS SIGNED
BY THE YOU (PAYEE).
PLEASE BE ADVISED THAT PAYMENT TO YOU PURSUANT TO THE
TRANSFER AGREEMENT IS CONTINGENT UPON COURT APPROVAL
OF THE TRANSFER AGREEMENT, WHICH YOU MUST OBTAIN.
,Pb
02/19/2008 15:03 7172343650
KREVSKY AND ROSEN PC PAGE 09
A000untID: 356823
_SCH?D tr.F ? _ PA =F {
PLEASE BE ADVISED THAT PAYMENT TO YOU WILL BE DE
UP TO 30 DAYS OR MORE IN ORDER FOR LAYER
TRE AND APPROVE THE TRANSFER AGREEMENT. COURT TO REVIEW
BY SIGNING BELOW YOU ARE CONFIRMING
DISCLOSURE AT LEAST 10 DAYS PRIG RECEIPT RECEIPT OF 'S
CONTRA IPT OF THIS
PA CK MM CITIGHT ? starr
ATTACHMENT/EXHIBIT 6fP
A •
321
HENDERSON RECEIVABLES ORIGINATION, LLC
February 22, 2008
Metropolitan Life Insurance Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Attn: Legal Department/Structured Settlements
Metropolitan Property & Casualty Insurance Company
P.O. Box 350
Warwick, RI 02887
Attn: Legal Department/Structured Settlements
RE: Notice of Sale/Assignment of Payment Rights
Your Contract #: 74755RIN
Payee: Patrick Mcknight
SS #: 170-70-9053
Dear Insurer:
Please be advised that 321 Henderson Receivables Origination LLC and/or its successors and
assigns, have entered into a transaction with the above-referenced annuitant who is seeking to
transfer certain of his/her rights to the payments scheduled to be received under the above.
referenced annuity policy. We are currently seeking court approval pursuant to the applicable
structured settlement transfer statute. Pursuant to the statute, please note the following
information about the Purchaser:
321 Henderson Receivables Origination LLC
40 Morris Ave
Bryn Mawr PA 19010
Tax ID # 20-4728885
PLEASE NOTE: No payments under this annuity should be held until the courts have entered a
final order and we have forwarded this order to you.
Very truly yours,
321 Henderson Receivables Origination LLC
By:
Maureen Healy, Vice Pr ent
3993 Howard Hughes parkway - Suite 250 - Las Vegas, NV 89169-6754
PHONE: (800) 454-9368 - FAX: (215) 567-7525 - E-MAIL: IGW8TGWFUNnTxTt- r•?M
WEB SITE: WWW-JGWFUNDING.COM
- a ?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson
Receivables Origination, LLC and
Patrick McKnight
NO: D 13 D 6 (N l 4crw
INITIAL ORDER OF COURT
On this ,7 day of 2008, it is ordered that a hearing on this
P tition Transfer Structured Settlement Payment Rights will be held on
/ pb , in Courtroom_ at IL LO o'clock. The payee shall bring
i ome tax returns for the prior two (2) years to the hearing.
Within sevet 7) days, the transferee shall give notice of the hearing date to the
payee, the structured settlement obligor, the annuity issuer, the payee's spouse and any
person receiving child support, alimony, or alimony pendente lite. The transferee shall
attach a certificate of service to the notice of hearing date. A copy of the notice with the
certificate of service shall be filed with the court prior to the hearing. A
.ac
Sdx
`a
4
.3
t?
0
Maro & Maro, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600 Attorney for 321 Henderson Receivables Origination, LLC
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE: Joint Petition of 321 Henderson Receivables NO: 2008-01300
Origination, LLC and Patrick McKnight
CERTIFICATE OF SERVICE
I, Robert A. Maro, Esquire, hereby certify that a true and correct copy of the
Initial Order of Court was served upon the Payee, The Structured Settlement Obligor,
The Annuity Issuer, the Payee's Spouse and any person receiving child support, alimony
or alimony pendente lite.
A copy of the Notice is attached hDate: March 11, 2008 B Robert A. Maro, Esquire
Attorney for 321 Henderson Receivables
Origination, LLC
V
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
FEg 2 8 20D8J ?
Y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson NO: 68- 13oo C vi l -Tiem
Receivables Origination, LLC and
Patrick McKnight
NOTICE OF HEARING ON PETITION TO TRANSFER STRUCTURED
SETTLEMENT PAYMENT RIGHTS
To: Metropolitan Life Insurance Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Metropolitan Insurance and Annuity Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Patrick McKnight
100 B Street
Plainfield, PA 17081
Lawrence J. Rosen, Esquire
Krevsky & Rosen, P.C.
Attorney for Patrick McKnight
1101 N. Front Street
Harrisburg, PA 17102-3324
You are hereby given notice that PATRICK MCKNIGHT has filed a petition to transfer
structured settlement payment rights. A hearing in this matter has been scheduled on
b n\ r t 2008 at l l d o'clock in courtroom no. ,2, courthouse, Cumberland County
Court of Common Pleas, cIt ?s e:Pennsylvania. \-7a 13
You are entitled to support, oppose or otherwise respond to the payee's petition, either in
person or by counsel, by filing written comments with the court prior to the hearing or by
attending the hearing.
The Name, Address and Tax Identification number of the transferee is 321 H
Receivables Origination, LLC. 40 Morris Avenue, Bryn Ma A 1,$010, Tp?x .D.
4728885 1/7 /l
a--j-5-03
Date
BY:
R~ A: Ma*,Nuire "
Attorney for 321 Henderson
Receivables Origination, LLC.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600
(610) 275-9666(facsimile)
C Q
CIO
^- W
w
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
Attorney for 321 Henderson Receivables Origination, LLC
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: PATRICK MCKNIGHT NO: 2008-4300
PRAECIPE TO ATTACH
To the Prothonotary:
Kindly attach this document to the Joint Petitioner's Petition for Partial Transfer
of Structured Settlement.
By.
Robert A. Maro, Esquire
Attorney for 321 Henderson
Receivables Origination, LLC
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
A ..
Account ID: 356823
Payee's Affidavit in Support of
Petition to Transfer Structured Settlement Rights
I, Patrick McKnight, the payee, verify that the statements below are true and correct:
Payee's name, address and age: Patrick McKnight / 100 B Street, Plainfield,
PA 17081/ 23.
1. Marital Status:
X Never Married; _ Married; Separated; Divorced
If married or separated, name of spouse: N/A
3. Minor Children and other dependents:
Names, ages, and places of residence: N/A
4. Income:
$59,000.00 annually as a Supervisor at Zero Chaos Inc.
If presently married, spouse's monthly income and sources: N/A
5. Child support, alimony or alimony pendente lite:
Obligation to pay: Yes X No
If yes, state the amount of the obligation, to whom payable, and whether there are
arrearages:
6. Previous transfers:
Have you previously filed a petition to transfer payment rights under the
structured settlement that is the subject of this petition? Yes X No
If yes, for each petition that you filed,
(a) If the transfer was submitted for court approval, list the
court, the case caption and case number, and state whether the
s
Account ID: 356823
court approved or disapproved the transfer:
(b) If the transfer was approved,
(i) State the name of the transferee and identify (listing due
dates and payment amount(s)) the payments involved in the
transfer:
(c) Have you ever transferred payments without court approval? If so,
please explain: No
State the amount of money and the manner in which the
money was used:
7. Reasons for transfer:
Describe in detail you reasons for the proposed transfer, including an
explanation as to why a sale of a lesser amount of the structured settlement
amount will better serve your interests: I want to use the money from this transfer
to purchase a home.
8. Payment of debts:
If you seek the transfer in order to pay debts, list each debt, including the name of
the creditor and the amount presently owed:
Debt Creditor Amount Owed
Account ID: 356823
Verification
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating
to unsworn falsification to authorities.
DATED: 2 -r
If of
Signature
° a
C
3
IN RE: JOINT PETITION OF 321 : CUMBERLAND COUNTY
HENDERSON RECEIVABLES : COURT OF COMMON PLEAS
ORIGINATION, LLC AND
PATRICK MCKNIGHT
No. 2008-1300
FINAL ORDER OF COURT
On this day of Yit is ordered that
the Petition for Court Approval for Transfer of Structured Settlement Payment Rights is
granted.
The Court specifically finds that:
1. the payee has established that the transfer is in the best interest of the
payee or the payee's dependents;
2. based on the certification by an attorney for the transferee, and the court
having not been made aware of any statute, regulation or order that would be
incompatible with the proposed order, the transfer will not contravene any
applicable federal or state statute or regulation, or the order of any court or
administrative authority;
3. the transfer complies with the remaining requirements of the Structured
Settlement Protection Act, including Sections 3(a)(20, 3(a)(4), 3(a)(5) and 3(a)(6);
the payments that are to be transferred are designated as follows: one lump sum
payment of $50,000.00 on November 1, 2011;
4. The payee was advised in writing of their right to receive or waive
consultation with independent legal advice regarding the transfer;
4. the terms of this order shall survive the death of the payee and shall be
binding on the payee's heirs, beneficiaries and assigns; _
5. the payee shall receive from the transferee, as of rj the
amount of $30,865.00, from which no funds are owed for counsel fees,
administrative fees, or other costs, fees or expenses.
6. All Transferred Payments should be sent to:
321 Henderson Receivables Origination LLC
EIN #20-4728885
PO Box 7780-4244
Philadelphia, PA 19182
7. The Transferee shall be liable to the structured settlement Obligor,
Metropolitan Property & Casualty Insurance Company, and the Annuity Issuer,
Metropolitan Life Insurance Company:
a. If the transfer contravenes the terms of the structured settlement, for any
taxes incurred by the Structured Settlement Obligor or the Annuity Issuer as a
consequence of the transfer; and
b. For any liabilities or cost, including reasonable costs and attorney's
fees, arising from compliance by such parties with this order of the Court or
arising as a consequence of the Transferee's failure to comply with the Act.
The structured Settlement Obligor and Annuity Issuer shall irrevocably change
the beneficiary for the Transferred payments to the Transferee, and no other
individual or entity other than the Transferee
beneficiary for the Transferred payments.
e3
7C?