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Home My WebLink About09-8617IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST MUTUAL SALES FINANCE, INC. a subsidiary of WASHINGTON FEDERAL SAVINGS AND LOAN, FIRST, assignee of AMBASSADOR HOME IMPROVEMENT, Plaintiff, vs. TERESA COMPLESE and GERARD COMPLESE, JR- Defendants. No. OR - 807 0-ivi i -(erm COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 SHAWN P. MCCLURE, ESQUIRE PA ID #205951 ?I LY E. DICESARE, ESQUIRE PA ID #209094 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8100 BERNSTEIN FILE NO. 3192-029 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST MUTUAL SALES FINANCE, INC. a subsidiary of WASHINGTON FEDERAL SAVINGS AND LOAN, FIRST, assignee of AMBASSADOR HOME IMPROVEMENT, Plaintiff, vs. TERESA COMPLESE and GERARD COMPLESE, JR., Defendants. No. NOTICE TO DEFEND 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 upon you, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court, without further notice, for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service PA Bar Association PO Box 186 Harrisburg, PA 17108 1-800-692-7375 COMPLAINT IN CIVIL ACTION 1. Plaintiff, First Mutual Sales Finance, Inc., a subsidiary of Washington Federal Savings and Loan, (hereinafter "First Mutual") is a Delaware corporation whose address is 400 108th Avenue NE, Bellevue, Washington 98004, and, as the assignee of the rights of Ambassador Home Improvement stands in its assignor's stead. 2. Defendants, Teresa Complese and Gerard Complese, Jr., (hereinafter "Defendants"), are adult individuals with a last known address of 276 Clark Street, Lemoyne, Cumberland County, Pennsylvania 17043. 3. On or about May 10, 2004, Defendants entered into contract with Ambassador Home Improvement, The Home Improvement Contract, whereby Ambassador Home Improvement was to provide certain goods and/or services to the Defendants. A true and correct copy of said Agreement is attached hereto, marked Exhibit "'I", and made a part hereof. 4. To induce the extension of credit, the purpose of which was to finance windows, Defendants executed and delivered to Ambassador Home Improvement, a Home Improvement Installment Contract, (hereinafter the "Contract"), a true and correct copy of which is attached hereto, marked Exhibit "2", and made a part hereof. 157847.doc 12/2/2009 5. Pursuant to the Pursuant to the "Transfer" located on page two (2) of the Contract, Ambassador Home Improvement, the seller, transferred the Contract with Defendant to First Mutual Bank, the Plaintiff. See Exhibit "2." 6. Pursuant to the terms and conditions of said Contract, Defendant agreed to pay to Plaintiff the sum of Sixteen Thousand Dollars ($16,000.00) for said goods and/or services, to be paid in one hundred and twenty (120) consecutive monthly installments of Two hundred thirty eight dollars and eighty cents ($238.80) each, beginning approximately thirty (30) days from the date of completion at an annual percentage rate of 12.99%. See Exhibit "2." 7. Plaintiff avers that Defendant is in default of said Contract by failing to make the agreed- upon payments as they became due despite demand therefore. 8. Defendant has not made a payment since August 24, 2009, thereby rendering the entire balance immediately due and payable pursuant to the terms of the Contract. 9. Plaintiff avers that Plaintiff is a secured party with regard to the windows, as is more specifically shown by the UCC Financing Statement, a true and correct copy of which is attached hereto, marked Exhibit "3", and made a part hereof. 157847.doc 12/2/2009 10. Plaintiff avers that the balance due and owing from Defendant amounts to $11,037.71, as is more specifically shown by Plaintiff's Payoff Sheet, a true and correct copy of which is attached hereto, marked Exhibit "4", and made a part hereof. 11. Pursuant to the Contract, Plaintiff is entitled to ongoing interest on the unpaid balance at the annual rate of 12.99%. See Exhibit "2". 12. Plaintiff avers that interest at the aforesaid rate from November 2, 2009 to November 17, 2009 amounts to $60.48. 13. Pursuant to the terms and conditions of the Contract, Plaintiff is entitled to recover its collection costs (including reasonable attorneys' fees) of not more than 20% of the balance due. See Exhibit «2„ 14. Plaintiff avers that such collection costs (including reasonable attorneys' fees) amount to $500.00. 15. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and refused to pay the aforesaid balance, interest, attorneys' fees or any part thereof to Plaintiff. 157847.doc 12/2/2009 WHEREFORE, Plaintiff demands Judgment against Defendant in the amount of $11,598.19 with ongoing interest at the rate of 12.99% per annum and costs. Respectfully submitted, BERNSTEIN LAW FIRM, P.C. B Y* Ow vc? UV Atto e? for Plaintiff Su' 22 0 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 I57847.doc 12/2/2009 05/12/04 11:32 r Ta.dnrnepAdtr 3907 AL Front Street H%rnsW% PA 17110 Phone 1-800.425- 450 Fax 717-234.7530 vlrm ambassador-homacom This contlut is made this all Company and _LIMA Job Location __PLr_ Email Agrau DESCRIPTION OF WORK AGREED UPON: Furnish and Intl Windows as Fol lows: H" Phaat 77 R vat* Pate. Mr. - ?/ /dent Pbane Nrr. 7W-jQU ww. tmii a 1Ye 6tyk V. Color Sweet sbd -,If style ce" r ?. f? N G h eatrraALY MODIIMCATIOM,a pnaxn 14W abo~,r am to Arder rw fuse %&dmA am fhanal deanbon gdlrMlant k prier AIaR b deMntnW ea a prrw.Orllf errs ravhet a an.dderiwn to tldr t dit f omh& As1Y+AadMU1 woe "Vested Is tM ftff 4ul be eb: I, rddOorr le the aftatt FiCC /eerft hb enw Oat tat COrnpmy"asset I.yu Of dw atAlanal sh 1. N9w as iu cocas aww miatdadBtL.etwrk. ?A lA (167 p, 10, uc In 112 11J L An aAe ' WdWrA ftWrwlx btbrd rMrev&R r?rn 0140 OCanpwry >! Myst Z. 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T%k Cpuy bm* P"M to Melia "a ad tArmu as =0=1110 M areae.wd *W&W dav. AMI N KWM TO TIN! WMS AND ednblrtele oAtYrEasllaue aee.?naa,? ti.s, esdr etrt dub aoeo?rL 011JAMNO MMT AB*wtostt OComosewwRINNtabalBrytr 14..1nardrlo??a k, or Mtills bt"OPoedt clAluwwwm 1b 0PVC CaNd AbaMaum Cekm O 0f *W eon vhr4 supply color nmat ll.Are WAUtn.bdeelmrwtedt ftNo Oft LoodaK 12 An openluf SbK btlnL *AA;t0 Oyu who t.awtlorc 13.An Mr VA.d" An WW Sate? Oyu III* I&CIU ML' NOTE ! YOU, THS MM, MAY CANCEL THIS TRANSACTION AT ANY TM PRIOR TO MIDNIGHT OF IM THINS) HUSMU DAYAPM TN6 DATE OF THIS TRANSACTION, SM THE ATTACHED N071CS OF CANCUMION FORM FOR AN 6IIPl-410TION OF THIS RIGHT. NOTICE TO TXS BUYER DO NOT 3lo ML% o01i7RM:7 BEFORC YOU READ 17 YOU Date . _•_ Z&&Z 20 Qk_ AR6SN17$BDTOACOFDIE ANIN LkD•DICOPYOP BTiNE YOU SICN R. 13P IT DNOI.YFd AN 1Na1MLlJdT1t1' SAIL, WDER UNDER $TAYt STATE LM lAW YOU HAVE THE RIOtR TO MY Writ INU AMOLW OUL IH ADYANC6 AND UNDER CMAIN Ad5w fee CONDITIONS To 05" A PARTIAL MpBAATE Or TNR IINANCC CHARGE. It THE tV DR MS 1NSTRUMLNi IS CONSTR)MOTO BRA CONJgtr1ER CMIT CMf Nd? pM L? Jy f, / TRACX THB PO OV M 11011CES CNLN'ANY HOLDER OF THIS CONSUMER CRIMT COMPACT 18113MIM TO ALL CLIUM9 AND DEFBNSES WHICH THE DEBTOR COULD ASSM A" M THE SELLER OF GOODS OR SMMC94 07ADt6D MRSUWr MRNC ?b1,,,C?1wr To OR WITH TN6 raa6103 HERSOR MCOVIRY HEREUNDER BY rHE OEM ? ? -?- ..rtiVeSl SHAtbNOT L`IM AMMWS I-AM BYTNR DEBTOR HEREUNDER. *s° NO. 307 M3 STYLE OR TYPE ON.Deabla3lwq cit-ca"MaKHYpea ew.D.etiY CC-CaRAMt.NiapL au.Pro4te StdK T+u -whoear.ars 7LSOt • Tasetr, SVdr tX0[IY •'rgrl. Cat?arMt ILA IM) 14l 3LSW•IIAIn,Ir1 C301M-VKIn.1141 AWN•Atake GDN-OeNeA DAY•Ow HP-Ilegtr a0W34"L Ambassador Now Istyrwulmlls Inc. rekrred to T&utd to as BtW EXHIBIT__ t_1__',? 06/15/04 10:34 NO. 833 W2 -I& FlPst Mutual Bank Phone.. (44 452-1 Wt To)) Preen 1118E-568a60: Sties F nonce 1001081h AW Ne N4 eellees ia, %VA HWJ rue. (42* 43&1571 mpi1mg. PO &a 1647, Balk, Pa. W.l 9M-1647 Toll Frey ru: 1A&W460' F,Ipd Mutual Bank Comllletlon C.eertif;_Er ii TERE6ACOflh 8E GERARD COMPLESE owner of property located at; 110"APS046re Nernt 276 CLARK S LEMOYNE, PA 17043 f -1 (Address I do hereby accept as I omplete and satisfactory the home improvement contract between myself and M8ft$A00RI10MP IMPROVEM1R i (oeelerNram• ) I understard ft termf: and conditforte of said contract. This certificate also, when signed by the I i Notlce to Burrower DO NOT 81ON this form until the dealer has complotsd the work In accordance with the tsrmll and conditions of your contract or sales agreement. oft For Dealer Use Only AMBASSA60R. HOME fNPROVEMEI0907 N FRONT ST HARRISBURG, PA 17110 01011W WM 01WHI *VMS do hereby ct"y that • All goods and sondoes provided for in the accompanying Home improvement Contract have been dellyared and Installed In a workmanlike manner and in accordance with the terms of said cgMract. • all daldts for labi dr, material, license fees, permits, inspection fees, and all other bills pertallting to the home improvement contract between said firm and TER113A CO E I OCRARD COMPLESE 176 CLARK i LEMOYNE, PA 17045 CuNamxN4m?+v?A40re•s j have been of WI) be pt id within 30 days In full and there Is no outstanding indebtedness which might result a lien or this properly, as a result of this home improvement contract (other than note and liehpexecuted by owner) DWW or Har? Tfus Odl• ar-o,n•I,ie.?igM?ra h.,ee 56461154.16911 ??ia NOTICE OF RIGHT Seller Buyer TERESA COMPLBSE TO CANCEL AMBASSADOR HOME IMPROVEMEN GERARD COMPLESE Regarding Retail Installment 3907 N FRONT ST 276 CLARK ST Contract No. HARRISBURG, PA 17110 LEMOYNE, PA 17043 58481134309134 'Seller' means the above•named party, its "You' and 'your' mean each Buyer above, successors and as s, jointly and individually. This NOTICE OF RIGHT TO CANCEL describes your rights under the Retail Installment Contract ("Contract") that you have signed, or will sign, on the "date of transaction' given below in the NOTICE OF CANCELLATION. You acknowledge that you have received two copies of the NOTICE OF CANCELLATION section below, both completed with the Seller's name and address, the date of the Retail Installment Contract and the date by which you may give notice If you choose to cancel the Contract. You acknowledge that the Seller has also orally explained your right to cancel. Buyer(s): 14.04- Signature Today's Date Signature Today's Date NOTICE OF CANCELLATION Date of Transaction 05' ( 4 'C14- You may CANCEL this transaction, without any penalty or Obligation, within THREE BUSINESS DAYS from the above rate. H you cancel, any propertytraded In, any payments made by you under the contract or sale, and any negotiable Instrument executed by you will be returned within TEN BUSINESS DAYS following receipt by the seller of your cancellation notice, and any security Interest arising out of the transaction will be canceled. If you cancel, you must make available to the seller at your residence, In substantially as good condition as when received, any goods delivered to you under this contract or sale, or you may, If you wish, comply with the Instructions of the seller regarding the return shipment of the goods at the seller's expense and risk. If you do make the goods available to the seller and the Seiler does not pick them up within 20 days of the date of your NOTICE OF CANCELLATION, you may retain or dispose of the goods wNh wt any further obligation. If you fail to make the goods available to the seller, or H you agree to return the goods to the seller and fall to do so, then you remain liable for performance of all obligations under the contract. To cancel this transaction, mail or deliver a signed and dated copy of this NOTICE OF CANCELLATION or any other written notice, or send a telegram, to AMBASSADOR HOME IMPROVEMEN at 3907 N FRONT ST HARRISBURG, PA 17110 NOT LATER THAN MIDNIGHT OF V 5 • LJa'f Idatet I HEREBY CANCEL THIS TRANSACTION. Data Buyers Signature NOTICE OF RIGM TO CANCEL 584811343091134 FT61 nww d Bsnk (Paps 1 of 1) HOME IMPROVEMENT Seller BuyerTERESA COMPLESE INSTALLMENT CONTRACT' AMBASSADOR HOME IMPROVEMEN' GERARD COMPLESE PENNSYLVANIA 3907 N FRONT ST 278 CLARK ST No. $84811343091134 HARRISBURG, PA 17110 LEMOYNE, PA 17043 Date 0511312004 "We" and "us" moan the Seller above, and 'You' and "yowl mean each Buyer above, an transferee If we transfer this Contract ao rd and together. SALE: You agree to purchase from us the goods andfor services described below according to the terms of this Convect. The term 'Contract' means this document and any separate document which secures this ContracL Description of Goods andlor Services Purchased WINDOWS Description of other collateral (Not household goods) PROMISE TO PAY AND PAYMENT TEJ& You promise to pay us the principal amount of $ 16,000.00 plus interest on the unpaid balance at the rate of % per year until this Contract is paid in full (which will include the period after the last payment is due and after a court judgment O necessary). Interest will begin to accrue on the date of completion You agree to pay this Contract according to the payment schedule and late charge provisions shown in the TRUTH IN LENDING DISCLOSURES. You also agree to pay any additional amounts according to the terms of (his Contract. ? This Contract Is not payable in Installments of equal amounts. ? An Installment of S will be due on . ? Larger installments will be due as follows: ? MINIMUM FINANCE CHARGE: You agree to pay a minimum finance charge of $ _ if you pay this Contract in full before we have earned that much in finance charges. DOWN PAYMENT: You also agree to pay, or appty to the Cash Price, on or before today's date, any cash, rebate and net trade-in value described in the ITEMIZATION OF AMOUNT FINANCED. U You agree to make deferred payments as part of the cash down payment as reflected N your Payment Schedule. TRUTH IN LENDING DISCLOSURES ANNUAL FINANCE AMOUNT FINANCED TOTAL OF PAYMENTS TOTAL SALE PRICE PERCENTAGE RATE CHARGE The amount of Credit The amount you will have The total cost ofyour pureness on The cost of your credit as The dollar amount the provided to you or on paid when you have made eredit, Inelud r lovrn payment 00 b?1 a earl rate credt will Cost ou our behalf all scheduled ayments Z. of $ y y y . y . p . 12.99 % $ 12,856.00 e $ 16,000.00 $ 28,658.00 e $ 29,268.00 e Payment Schedule: Ycrur payment schedule will be Number of Payments Amount of Pa ments When Payments Are Due 1120 $ 238.80 Monthly, on a schedule beginning approximately 30 days from the completion date. Security: You are giving a securtty interest in ? the real property at ® the Goods purchased. ? (description of other property) ® Late Charge: If a payment is more than 10 days late, we will charge you amount 6% of the payment $5.0Q.)6MIchever is less. Prepayment: If you payoff this Contract early, you ? may ® will not have to pay a Minimum Finance Charge. Contract Provisions: You can see the terms of this Contract for any additional information about nonpayment. breaking the terms of this Contract, any required repayment before the scheduled date, and prepayment refunds and penalties. "e" means an estimate PENNSYLVANIA HOME aAPROVEMENT RETAIL INSTALLMENT CONTRACT 584811343091134 First Mutual Bank (Page 1 of b) BUYER RESTRICTIONS: If you do not most this Contract's obligations you may lose the property that you bought in this sale SECURITY: The term Property means any collateral that secures this Contract. If you do not meet your contract obligations, you may lose the Property, including: ® The Goods sold, plus all accesslor s to such Goods, plus any other Property, all as described in the SALE section. By signing this Contract you are giving us the security interest in these Goods and any such other Property. ? The real property that includes the home improved, by a separate mortgage dated CREDIT INSURANCE: Credit life, credit dlseblliry, and any other insurance coverage quoted below, me not required to obtain credit and wa will not provide them unless you sign and agree to pay the additional premium. if you want such Insurance, we will obtain it for you (if you quality for coverage). We are quoting below ONLY the coverages you have chosen to purchase. Credit Life: Insured NIA ? Single ? Joint Prem. $_bM Term NIA Credit Disabllity: Insured, NIA ? Single ? Joint Prem, $ N/A Term WA Name of Insurance Company: Your signature below means you want (only) the Insurance coverages) quoted above. N none are quoted, you have declined any coverages we offered. TRANSFER: We hereby transfer this Contract to (identify): I transfer this Contract ? under the terms of a separate agreement. 0 under she terms of the TRANSFER BY SELLER on page 5. ? We make this transfer with reeour . Soilsr: By Date?f/ Name and Title /17 ITEMIZATION OF AMOUNT FINANCED Goods and/or Services Price $ 10,612.00 (including sales tax of $ h Service Contrract, Paid to'. hj1A $ 1. Cash price $ 16,612.00 WA WA Buyer d/o/b Buyer d/o/b NIA NIA Buyer d/o/b Buyer d/o/b PROPERTY INSURANCE: You must insure the Property sacuring this CortlraeL You may purchase or provide the insurance through any Insurance company reasonably acceptable to us. The deductible amount of this Insurance may not exceed $ NIA _ . We do not offer liability insurance coverage for bodily injury andfor property damage. ? SERVICE CONTRACT: With your purchase of the Goods, you agree to purchase a Service Contract to cover This Service Contract will be in effect for NIA SELLER'S ?SIGNAJM9 X__ Name nb Manufacturer's Rebate $ _ ft/A Cash Down Payment $ 812.00 Doremed Down Payment S NIA 2. Subtotal $, 612.00 Trade-In Allowance $ _ NIA Leas: Amount Owing $ NIA To: NIA 3. Net Trai $ N/A 4. Total Down Payment (Nne 2 plus line 3) $ 612.00 b. Unpaid Balance of Cash Price (one 1 minus line 4) $ 16,000.00 Foes Paid to Others: Paid to Public Officials - Filling Fees Only $ 0.00 Paid to Public Officials-Other than riling roes s Insurance Premiums' $ To: N/A $ N/A To: NIA $ N/A To: _ NIA $ WA To: NIA $ N/A To: NIA $ NIA To, NIA $ NIA 6. Subtotal (line 6 plus all Fees Paid to Others) $ 16,000.00 7. Prepaid Finance Charges $. NIA Amount Financed (line 6 minus line 7) $ 16,000.00 We may retain or receive a portion of this amount. PENNSYLVANIA HOME IMPROVEMENT RET"AL INSTALLMENT CONTRACT 56461194:1091134 Fist Mutuw Bank (page 2 of 5) Nonce TO BUYER (1) Do rwtkin lids corttlact before you read it (2) You arearrltled bacompletMytle"coWafttlecort1 11 (3) Undortheb%you have the right b pay olf n adwince the U amount due and, under calainc ndlYons,toobreitapwWrefndofthetlrrncecharya (4) You may rescnd this contract, subject b bbllNyr for any liquidated darnege provYbn d a authormsd by law, not hater ihm to P.M. on tie buelrtea day blowing the dste hereof by gking written notice of r adeaton b the oontracior at his place of business given In the colthacibut 1 you rescind after to P.M. on the kariess day It>Ilowng, you are ad anllled b offer deletion in milliplion of damages and to pumus any righba of action or deFxrees that wise out of fie tarmaction. (You may have otter ilghb to anal tiffs t ansaclbn which ale aver mac favorable b you titan to one. Ottelwbmm vA expkdn tw* rights b yam) BY SIGNING BELOW BUYER AGREES TO THE TERMS ON PAGES I THROUGH 5 OF THIS CONTRACT AND ACKNOWLEDGES RECEIPT OF A COPY OF THIS CONTRACT. X ye .): e /') j lW j4.c%A- Signature Date X JR Signature Date X Signature Dale X Signature Date ADDITIONAL TERMS OF THIS CONTRACT GENERAL TERMS: You agree to purchase the Goods and services over time. We assume In the Total Sale Price disclosure that you will make all payments on time. The actual amount you will pay may be more or less depending on your payment record. We do riot intend to charge or collect any interest or fee that is more than state or federal law allows. If we charge or collect any amount over what the law allows, we will apply the excess first to the principal balance, and we will refund any excess 'If you have paid this Contract In full. You understand and agree that some payments to third parties as a part of this Contract may involve money retained by us or paid back to us as commissions or other remuneration. If any provision of this Contract is not enforceable, this Contract wia remain enforceable without such section or provision. N we agree with you to any exceptions to the promises or assurances In this printed Contract, such agreement must be in writing and signed by us. The law of Pennsylvania will govern this transaction, which Is where the Improvement will be done. Federal law may also apply. Any provision that appoints us as an agent is not subject to the provisions of 20 Pa. C.S.A. Section 5601 at seq. (Chapter 56; Decedents, Estates and Fiduciaries Code). By exercising any of our rights under this Contract, we do so for our sole benefit. NAME AND LOCATION: Your name and address indicated on page 1 are your axact legal name and your principal residence. You will provide us with at least 30 days notice prior to changing your name or principal residence. PREPAYMENT: You may prepay this Contract in full or in part at any tme. Any partial prepayment will not excuse any later schoduled payments until you pay in full. You may obtain from us, or the insurance company named in your policy (or certificate of insurance), a refund of any unearned insurance premiums. ADDITIONAL SECURITY: You also assign to us and give us a security interest In proceeds and premium refunds of any insurance and service contracts purchased with this Contract. OWNERSHIP AND DUTIES TOWARD PROPERTY: if you give us a security Interest or a real estate mortgage you agree to the following: A. You mill defend our interests in the Property against claims made by anyone else. You wig do whatever is necessary to keep our claim to the Property valid. B. The Security interest you are giving us in the Property comes ahead of the claim of any other creditor. except as agreed to in writing by us. You agree to sign any additional documents or provide us with any additional information we may require to keep the priority of our claim to the Property. You will not do anything to change our interest in the Property. C. You Will keep the Property in your possession in good condition, and at the address listed on page 1 of this Contract. You will use the Property for its intended and lawful purposes. D. You will not try to sail or transfer any rights in the Property. E. You will pay all taxes, fees, and expenses on the Property Men due. F. You will notiy us of any loss of damage to the Property. You will provide us reasonable access to the Property for the purpose of inspection. DEFAULT: You will break this Contract (default) if any one of the following occurs (except as prohibited by law): A. You failto make a payment In full whan tit is due. PENNSYLVANIA HOME IMPROYEMENrRE:TAIL INSTALLMENT CCNTRACT 384911343091134 First Mutual earrk (page 3 of Sj B. You fail to perform any obligation that you have undertaken In this Contract (which includes doing something you have agreed not to do). C. You make any written statement or provide any financial information that is untrue or misleading at the time you gave it to us. If you break this Contract, you agree to pay the court costs we incur and our attorneys' fees of not more than 20% of the amount due and payable, for attorneys who are not salaried em*yees of ours. If residential land secures this Contract, there are further limits on the amount of attorneys' fees, as provided by law. . If one of you breaks this Contract, then all of you break this Contract. We may collect against any one or more of you, at our choice, until we are paid in full. OUR RIGHTS TO COLLECT: If you break this Contract, we have rights we can use to collect what you owe us. These rights include those given to us by law, those given to us by this Contract, and those given to us by any separate agreement that secures this Contract. These include (see the exceptions at the end): A. We can require you to pay us all the principal you owe us, including Cie amount that would have been due in the future, plus interest. B. We can, but need not, pay taxes, fees, expenses, or charges on the Property that you fait to pay. We can then collect such payments from you, Immediately, and such amount will earn interest at the rate on this Conhact C. We may require you to make the Property available to us at a place we designate that is reasonably convenient to you and us. D. We may immediately take possession of the Property C we do so lawfully. We may then sell the Property and apply what we receive to our reasonable expenses and then toward your obligations. E. Except when prohibited by law, we may sue you for additional amounts if the amount we gel from a sale does not pay all you owe us Paragraphs C. and D. do not apply to any land which may secure this Contract, and the law imposes other limits on our rights when a residence is the security. We will tell you those limits if and when they become important to you. By choosing any one or more of these rights, we do not give up our right to later use another one. If we decide to ignore something you do (or fail to do) that breaks this Contract, we may later treat that type of event to be a break of this Contract. If we take Property that secures payment of this Contract, we must send you notice of our intention to sell it. You agree that 10 days notice mailed to you at your address on page t of this Contract is reasonable. (When land is the security, other rules apply.) If the U.S. Department of Housing and Urban Development insures this Contract under its Tolle 1 Property Improvement Loan Regulations, our right to make you pay off the entire Contract is subject to the limitations of those regulations. INSURANCE: If you secure this Contract with Property, you must Insure this Property against loss and physical damage. You must arrange for the insurance company to name us on the policy as the first to be paid in the event of a loss. If a benef t paid to us does not pay off this Contract, you remain responsible for the balance. You will keep the Insure nce In effect until you pay this Contract in full. If you do not keep these promises, we may buy insurance to protect our interest In the Property. The insurance we buy may include coverages beyond those we require you to buy, and may be from a company you might not choose. The rate we pay may be higher than what you might have to pay if you buy it yourself. We will add the premium to the amount you owe us, and you must pay interest on the amount at the contract rate, though we may require you to pay us immediately. INDEPENDENT RESPONSIBILITY: Each of you who signs this Contract is independently responsible to pay it and to keep the other promises, This is true even if: A. Someone else has also signed it 13. We release or do not try to collect from another who is also responsible to pay this Contract, C. We release any security or do not try to take back any Property. D. We give up any other rights we may have. 1=_ We extend new credit or renew this Contract WARRANTIES: We will provide any warranty information to you separately. WANER: To the extent permitted by law, you agree to give up your rights to require us to do certain things. You do not require us to: a. demand payment of amounts due; b. give notice that amounts due have not been paid, or have not been paid In the appropriate amount, time or manner; or, r,. give notice that we Intend to make, or are making, this Contract immediately due. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. PENNMVANIA HOME IMPRO%EMENTRETAIL INSTALLMENT CONTRACT 584811343091134 First MutuH Sank (page 4 of s) TRANSFER BY SELLER: The boxed part below Is between us and a "transferee." It does not apply to you. A "transferee" Is someone who may own this Contract or the right to receive your payments, or both. We will give you separate notice of a transfer. Seller transfers to the party (Transferee) listed in the TRANSFER seexion on this Contract all of Seller's rights in this Contract. Seller assures Transferee of the following. A. This Contract represents a sale by Seller to Buyer. B. The statements contained in INS Contract are true and correct. C. Buyer paid the down payment exactly as stated. D. The Seller completed the sale in accordance with all applicable laws and regulations. E. This Contract is valid and enforceable- F. The names and signatures on this Contract are true and correct, G. This Contract Is not subject to any claims or defenses on the part of Buyer. H. Seller delivered a completely filled-in copy of this Contract to Buyer at the time Buyer signed this Contract. 1. Seller delivered the goods and services to Buyer. If any of these assurances is untrue, Seller will, upon Transferee's demand, repurchase this Contract from Transferee. This repurchase will be for the amount of the unpaid balance, including interest, plus the expenses of Transferee, including attorneys' fees. Seller will repay Transferee for any loss sustained by it because of a court ordered deduction of the amount Buyer owes Transferee. Seller will repay Transferee for any loss sustained by it as the result of a recovery made against Transferee. Seiler gives up its rights to notice of acceptance of this Transfer, non-payment, non-performance, or any other notice from Transferee. Transferee may amend the terms of this Contract with Buyer and any other person obligated under this Contract. Transferee may do so without notions to Seller and without affecting the (lability, of Seller under this Transfer. WITH LIABILITY: If %vith liability" is indicated in the TRANSFER section on this Contract. Transferee takes this Transfer with certain rights of recovery against Seller. Seller agrees that if Buyer faits to pay or perform according to the terms of this Contract, Seller will, at Transferee's request, repurchase this Contract. Seller will repurchase this Contract for the amount of the unpaid balance, Including finance charges, due at that time. WITHOUT LIABILITY: If "without liability" Is Indicated in the TRANSFER section on this Contract, Transferee takes this Transfer without liability to Seller except as provided above. DISBURSEMENT DATE:: (This date Is for Title I HUD Insurance purposes and Seller may fill in this date after the Buyer signs It to reflect the actual disbursement date. It may appear only on the original form.) PENNSYLVANIA HOME IMPROVEMENT RETAIL INSTALLMENT CONTRACT 584811343091134 F6ct MUtutl Bank (p&g0 5 of Si UCC FINANCING STATEMENT FOLLOW 117AUCT1ore ` w ?adOCAREFULI' A. NAME 8 Ff4AlE OF OCKTACT AT FLER IeOeDlfe? LOAN SERVICING 425-453-5301 e. SEND ACMOWLEOOMFNT T0: RlwM wW W;i I FIRST MUTUAL SAVINGS BANK P.O. BOX 1647 BELLEVUE, WA 98009 L G 5?go 1.DEBTOR'SmL*crRILLLEGALNAME.mr "=tee oawa*•m-dmmwWYawAp-mwwr u OR 10.1 MAW COMPLESE TERESA AL 'm wuma AffoRm CRY 276 CLARK ST LEMOYNE PA 17043 US 14 TIX ID M: SNI OR BN l#Z qi0 fl IIA f OF TIDN & CR3* r. ZW pApNOATKN Oe6TOR z. ADOMONAL OESTOR'S DACT FULL LEGAL NAME -kmat mb Mde wr fwfr (2L w 21- Oonalabbmt"woombr mWm ICOMPLESE GERARD ft. MULPm ADDREee CRY STATE CDWIAY US 276 CLARK ST LEMOYNE PA 17043 0. TAX IO r: 88HOAtN AMUNFORE s 7G. T r.1 m J DFKLV A710H 0WOR S. S ECURED PARTY'S NAME t wis 01 TcrALAUM69 MAs5wmR 691•InN mMw"wv-Q1&3kO 3a oRaANUTKWS M" FIRST MUTUAL BANK OR 3b. ILASTNAME R NAME 3c. AD0P&= - PO BOX 1647 ISfY BELLEVUE WATd WA A7ALCODE 96009 COUNTRY US It. TNI ANANOW STATEYENf OW" M WWO10 *$NNW WINDOWS PARCEL# 12.22-0820-084 LEGAL DESCRIPTION: SEE ATTACHMENT A FIXTURE FILING PROPERTY ADDRESS: 276 CLARK ST LEMOYNE, PA 17043 e, A11pML1'R?11f16PORfIGL wlw DEBTOR: 52.108516.03 COMPLESE, T. FILING OFFICE COPY- NATIONAL UCC FINANCING STATEMENT (FORM UCCI) (REV. r-AHIBIT B IT 3 UCC FINANCING STATEMENTADDENDUM COMPLESE It 12. 13. TWIN WGN09TATEMEW tO m r bbr lobe wl w [j rom?eodl 1B, M4EdW aolowel ob -m "Nswok a N ow u I?t Imn al'o 14. DNW"M tl"MYr. WINDOWS PARCEL# 12.220820-084 -- LEGAL DESCRIPTION: SEE ATTACHMENT A PROPERTY ADDRESS: 276 CLARK ST LEMOYNE, PA 17043 15. NrM?pird?NCgID OYMEAtl??OrI-006dfp rld OdW ? Odfgr? rot Nwv s ilGO1tl ??«+4' THE ABOVE SPACE H FOR F1UN0 OFP A USE ONLY fi.* g* In NIYaMm Mh• MuY4eund-NOS Twealm-dl.*y 30r.- Id4Y FILINGOFFICECOPY-NATIONALUCCFlNANCWGSTATEMENT ADDENDUM (FORM UCC1Ad)(REV.07/2 ") Attachment A 8516 Legal Description ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO A SURVEY OF D. P. RAFFENSPERGER, REGISTERED SURVEYOR, DATED MAY 22, 1956, AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHERN LINE OF CLARK STREET, 298.9 FEET EAST OF THE SOUTHEAST CORNER OF THE INTERSECTION OF CLARK STREET AND THIRD STREET; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF CLARK STREET, 26 FEET TO A POINT; THENCE SOUTHWARDLY ALONG A LINE RUNNING AT RIGHT ANGLES TO CLARK STREET, 200 FEET TO A POINT; THENCE WESTWARDLY ALONG A LINE RUNNING PARALLEL TO CLARK STREET, 25 FEET TO A POINT; THENCE NORTHWARDLY ALONG THE LINE RUNNING AT RIGHT ANGLES TO CLARK STREET AND THROUGH THE CENTER OF A PARTITION WALL BETWEEN PROPERTY KNOWN AS 278 CLARK STREET AND THE HEREIN DESCRIBED PREMISES AND BEYOND, 200 FEET TO A POINT THE PLACE OF BEGINNING. BEING THE SAME PREMISES WHICH ALAN R. KRfVELOW AND ELLEN GUTHRIE KRIVELOW, HIS WIFE, AND LOIS M. GUTHRIE, BY THEIR DEED DATED JANUARY 15, 1998 AND RECORDED JANUARY 20, 1998 IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, IN RECORD BOOK 170, PAGE 1131, GRANTED AND CONVEYED UNTO GARY D. PORTA, GRANTOR HEREIN.. SITUATE IN THE COUNTY OF CUMBERLAND, STATE OF PENNSYLVANIA. 111-02-2nnc) POFF PBAL DE FI ACIN PRTL R1BL R2BL R1AI R2AI SBAL INRI LATE MISC FEES CBAL LACC LBAL 11 C) 2005 ACCT 0052 108516 3 OPEN 11,037.71 10,632.82 264.89 LOAN PAYOFF SYSTEM FUNC AA AUX AA UKTOTI PO 135.00- PO 5.00 PO AAAAAAAAAAAAAAAA 124-65-6506 1274 NXT ACCT AAAA AAAAAA AA 3.78 COMPLESE T RNUL N IBAS 1 PDBS 1 DATE 11-02-09 EXPD 11-03-09 iJKDtA?TI EVDT AAAAAAAA EVNT 14 LOCK-IN N DROP N ICCD 01 INSU/PEN CD 4 / 4 FUD PRINCIPAL DUE: INTEREST FROM: 8/24/2009 TO 11/2/2009 PER DIEM: $3.78 LATES CHARGES: FILING FEES: NSF FEE: LEGAL: TOTAL: W, Airy, $10,632.82 $264.89 $5.00 $135.00 $11,037.71 . w VERIFICATION The undersigned does hereby verify under penalty of perjury, that he/she is VICE PRESIDENT FIRST MUTUAL SALES FINANCE, INC. of , Plaintiff herein, that he/she is duly authorized to make this Verification and that the facts set forth in the foregoing COMPLAINT are true and correct to the best of his/her knowledge, information and belief. c (Sign in Blue Ink) 157847_1.aoc 11/2 1 /2009 t ( '?0' SAY 25"9 GLC 1? ale; H: 19 cL 4,ga.oo pp A7? CIG# 314??31q?S aZ%5 o41 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor r 0 7039?C 22 PH 2: 4 3 First Mutual Sales Finance Inc. vs. Teresa Complese Case Number 2009-8617 SHERIFF'S RETURN OF SERVICE 12/17/2009 07:44 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2009 at 1944 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Teresa Complese, by making known unto Gerard Complese Jr., adult in charge at 276 Clark Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. 12/17/2009 07:44 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on Decembei 17, 2009 at 1944 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gerard Complese Jr., by making known unto himself personally, at 276 Clark Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $58.40 December 18, 2009 SO ANSWERS, 00001 :?- we R THOMAS KLINE, SHERIFF BY Deputy Seri !Ci Gount,Siite Sheriff. Teleosofl, for 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST MUTUAL SALES FINANCE, INC. a subsidiary of WASHINGTON FEDERAL SAVINGS AND LOAN, FIRST, assignee of AMBASSADOR HOME IMPROVEMENT, Plaintiff, vs. TERESA COMPLESE and GERARD COMPLESE, JR., Defendants. No. n 4 0 nlej=i XA- .z t ni- cry _?. -- -orn rIM W STIPULAT][ON OF THE PARTIES FOR SETTLEMENT AND FOR THE ENTRY JUDGMENT IN THE EVENT OF DEFAULT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 SHAWN P. MCCLURE, ESQUIRE PA ID #205151 HOLLY E. DICESARE, ESQUIRE PA ID #209094 Bernstein L,-,w Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8167 42.- BERNSTEIN FILE NO. 31"-029 R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST MUTUAL SALES FINANCE, INC. a subsidiary of WASHINGTON FEDERAL SAVINGS AND LOAN, FIRST, assignee of AMBASSADOR HOME IMPROVEMENT, Plaintiff, No. 09-8617 vs. TERESA COMPLESE and GERARD COMPLESE, JR., Defendants. STIPULATION OF THE PARTIES FOR SETTLEMENT AND FOR THE ENTRY OF JUDGMENT IN THE EVENT OF DEFAULT AND NOW comes the Plaintiff, by and through counsel, and the Defendants, to Stipulate to Settlement and for the Entry of Judgment in the Event of Default, according to the following terms and conditions: 1. Defendants agree to pay and Plaintiff agrees to accept the amount of $5,074.88 in full and complete settlement of the above matter. 2. Defendants agree to pay, and Plaintiff agrees to accept said settlement sum of $5,074.88 in accordance with the following payment schedule: A. A payment of $360.60 on or before December 15, 2009; B. A payment of $360.60 on or before January 15, 2010; C. A payment of $360.60 on or before February 15, 2010; D. A payment of $360.60 on or before March 15, 2010; E. A payment of $360.60 on or before April 15, 2010; F. A payment of $360.60 on or before May 15, 2010; G. A payment of $360.60 on or before June 15, 2010; H. A payment of $360.60 on or before July 15, 2010; 1. A payment of $360.60 on or before August 15, 2011); and J. A payment of $360.60 on or before September 15, :010; K. A payment of $360.60 on or before October 15, 201.0; L. A payment of $360.60 on or before November 15, :010; M. A payment of $360.60 on or before December 15, ' , ;010; N. A payment of $360.60 on or before January 15, 2011; 0. A final payment of $26.48 on or before February 15, 2011; P. Payments are to be made to "First Mutual" and mailed to their offices. 3. To secure the repayment of said indebtedness, Defendants agree that, in the event of Defendants' default of the above payment schedule, by failing to have any payment delivered to Plaintiff within five (5) days of the due date thereof, Plaintiff shall be free to enter Judgment for the balance set forth in Plaintiff's Complaint, including interest and Court costs, by filing a Praecipe for Judgment Pursuant to Stipulation, accompanied by Plaintiffs counsel's Affidavit of Default setting forth the balance then due, giving due credit for any payments made under this Stipulation prior to default. 4. Plaintiff agrees not to enter Judgment so long as Defendants cause to be delivered into the hands of the Plaintiff the payments set forth in paragraph 2 above, within five (5) days of the due date thereof. 5. Time is of the essence in this agreement and the failure of Defendants to have any payment delivered to Plaintiff within five (5) days of the due d ite thereof, shall free Plaintiff to F enter Judgment against Defendant as aforesaid in paragraph 3 above, and to issue Execution thereon, and/or to pursue any and all other remedies Plaintiff may have, at law or in equity to collect the full balance of any Judgment entered hereunder plus appropriate additional interest and costs. 6. No act or omission of the Plaintiff, Plaintiff's agents, Plaintiff's attorneys nor of anyone alleged to be acting on Plaintiff's behalf, shall constitute ;i waiver, forfeiture, estoppel, or any other excuse for Defendants' nonperformance of any duty undertaken by the Defendants in this Stipulation, which the parties agree to be final and complete. Intending to be legally bound, the parties pray for entry of the attached Order, and set their hands and seals this 20 day of X(jW bF2009. TERESA COMPLESE By. Title: GERARD COMPLESE By: Title: IJST-EIN LAW FIRM, P.C. By: Holl DiC esare, Esquire Attorney for Plaintiff Suite 2200 C ulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO. 3192-029 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST MUTUAL SALES FINANCE, INC. a subsidiary of WASHINGTON FEDERAL SAVINGS AND LOAN, FIRST, assignee of AMBASSADOR HOME IMPROVEMENT, Plaintiff, No. vs. TERESA COMPLESE and GERARD COMPLESE, JR., Defendants. ORDER OF COURT AND NOW, to wit, this day of 2009, upon consideration of the record and the foregoing Stipulation of the Parties for Settlement, it is hereby ORDERED, ADJUDGED AND DECREED that the foregoing Stipulation is approved, and the above captioned matter is stricken from the Arbitration list. BY THE CC URT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST MUTUAL SALES FINANCE, INC. a subsidiary of WASHINGTON FEDERAL SAVINGS AND LOAN, FIRST, assignee of AMBASSADOR HOME IMPROVEMENT, Plaintiff, No. vs. TERESA COMPLESE and GERARD COMPLESE, JR., Defendants. CERTIFICATE OF SERVICE I, Holly E. DiCesare, Esquire hereby certify that a true and correct copy of the foregoing STIPULATION FOR SETTEMENT AND FOR THE ENTRY OF JUDGMENT IN THE EVENT OF DEFAULT was served on the Defendant, pro se, by regular U. S. Mail, postage prepaid, this -30- day of l.2MW2009, addressed as follows: Teresa & Gerard Compleso 276 Clark Street, Lemoyne, Pennsylvania 17043. /0 A4 I 1 E. DiCesare, Esq. • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST MUTUAL SALES FINANCE, INC. a subsidiary of WASHINGTON FEDERAL SAVINGS AND LOAN, FIRST, assignee of AMBASSADOR HOME IMPROVEMENT, Plaintiff, No. 09-8617 vs. TERESA COMPLESE and GERARD COMPLESE, JR., Defendants. 5ah.s f j PRAECIPE TO SETTLE. DISCONTINUE AND END TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (7 C r., G C:' -rt Za; rn? Z?v C x -,e r rn ?-- x --f rs Tao ° = C:) -n =o D2 x Settle, discontinue and end the above-captioned matter upon the records of the Court and mark the costs paid. BERNSTE N LAW FIRM, P.C. By:- Attorneys for Plaintiff Suite 2200 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO: 80-029 Sworn to and subscribed before this o'q/Jt- day of , 2Q 11 N .,--- - " Seal No"I Linda Bo?ft N OWN Pd*- city Of ,201 My 0omntWw a?? CcL ? ? ---,_b.e of NOU 389106 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST MUTUAL SALES FINANCE, INC. a subsidiary of WASHINGTON FEDERAL SAVINGS AND LOAN, FIRST, assignee of AMBASSADOR HOME IMPROVEMENT, Plaintiff, VS. TERESA COMPLESE and GERARD COMPLESE, JR., Defendants. No. 09-8617 CERTIFICATE OF SERVICE I, Jennifer L Tis, Esquire, hereby certify that a true and correct copy of the foregoing Praecipe to Settle, Discontinue and End was served on the Defendants by regular U. S. Mail, postage prepaid, this 2 day of June, 2011, addressed as follows: Teresa Complese Gerard Complese, Jr. 276 Clark Street, Lemoyne, Pennsylvania 17043 ?t- 389106