HomeMy WebLinkAbout12-1634NINTH JUDICIAL DISTRICT OF PENNSYLVANIA
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Deutsche Bank National Trust Company
1761 East St. Andrew Place
Santa Ana, California 92705
Plaintiff,
V.
George D. Bryson
129 Regency Woods North
Carlisle, PA 17015
and
Yvonne M. Bryson
129 Regency Woods North
Carlisle, PA 17015
Defendants.
Court Term
No. 02 6 / 9- I (l 3 (?i vl
Complaint in Replevin
COMPLAINT ON ACTION FOR REPLEVIN,
PA. R. C. P. 1073, et seq.
`R..E -OFFICE
= I 'HEE OTHONOTARY
2 i'M 14 AM, 10: 36
C'IFMERLAND COUNTY
"E HNSYLVANIA
Now comes the Plaintiff, Deutsche Bank National Trust Company, (hereinafter referred
to as "Plaintiff'), by and through its counsel, David J. Demers of Cooke, Demers & Gleason,
LLC, and for its Complaint, states as follows:
1. Plaintiff is a foreign corporation authorized to transact business in the State of
Pennsylvania.
2. Defendants, upon information and belief, are residents of Cumberland County,
Pennsylvania and upon information and belief own certain personal property (a manufactured
home) located in Cumberland County, Pennsylvania in which Deutsche Bank National Trust
Company holds a perfected security interest
3. The court has proper jurisdiction and venue over this matter because it involves
residents of Cumberland County, Pennsylvania and property that is located in Cumberland
County, Pennsylvania.
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._oanNo.'?37^^^^,nT?. °+A STA_f_f4AENT CONTRAC?=MA?NIJFA_ ED H?J'rlf_I_E
1='ECI TRUTH IN LENDING DISCLOSURE S EMENT
PURCHASE AGREEMENT, This Retail Irstaliment Sor,tra.t ("Contract') contains the terms and conditions or which Seiler is salting, and Buyer is
purchasing, the Manufactured Home cnswc:,ed below.
MEANING OF SOME WORDS. In this Cz,ntraet, the words "you" and "your" mean anyone signing this Contract as a Buyer. The words "we," "us" and
"our" mean Seller :x, If Seller assigns (sells) this C:ontrac: to it,___UNITED COMPANIES FUNDING. INC.
Ir this Contract, -he words "Manufactured Home" or_'HoTe' mean the manufactured horns and the additional Appliances, Accessories and Fumishims..--
sold with is (see Description of the M.a^ufaztured Home below). If there Is more th3fl_opg Buyer. each will be ggligated, sepecately and together,_to pay til1
sums due and to keep all promises made to us In this Contract. This Contract is betweetl Seller_ar_d Buyer All isclosures have beert_rg d;v Seller,. __-
S, - s . t-_ _- z _-_--- - `-
SELLER REGENCYHOME
Name
7098 CARLISLE Pii jQ CARLISLE, 17013-
Ad dress - -
YOUR MAILING ADDRESS. You promise to advise us of arty, change of rnafli.ng- address while this Contract, is .in- effect.. After delivery of. the
Manufactured Home, we should send any papers or notices concerning the Manufactured Horne purchased under this Contract to:
Buyer GEORGE Q YS N 129 REGENCY WOODS NORTH mo ?4R - -
Name ee or Route CUMBERLAND PENNSYLVANIA 17013-
City or own - County ti e *$ o e
CoBuyer YVONNE M BRYSON 129 REGENCY WOODS NORTH
Name ee or ou e
CARLIS CUMBERLAND PENNSYLVANIA 1 -
ty or own MOT—- ---- - - - e-------- -- - - -- rye----
CoBuyer .- -- - . --r -- _ -- --- _ _
Name - -- - e or outs
City or own - oun -Stale - ---- p Code
C:oBuyer
Name a or Route
City or own _ County 4jp Code
LOCATION OF THE MANUFACTURED HOME. After delivery to you, the Manufactured Home will be at:
129 REGENCY WOODS NORTH REGENCY WOODS19F3 _ _ __ _-
'? eat or outs ame o an er o tea'
CARUSLE CUMBER60Q ?-.x qpx-6VANIA F 1701 e
city Sit 23P
DESCRIPTION OF THE MANUFACTURED HOME (The Manufactured Home includes the additional Appliances, Accessories and Furnishings,):
New 1996 MANORWOOD SC423A TUOO647AB 56 26
New Year anu adorer s Name Model arise an_, Q. a o, It _ ?tnlt ctu[er_s_ .. Bng _.._.. _...
A A ..
-- Item --
Additional WATERHEATER _
Appliances A/C
- Serial Number -- -- Item -- --Serial Number --
FURNACE
RANGE
Accessories
and FumishlnysDISHWASHER REFRIGERATOR
PROPERTY DAMf1GE INSURANCE REQUIRED: You must insure thhe Manufactured Home agaigst h deal damage until all amounts you awe us are
ppaid In full. This I surance myst be in amounts and types aC?ptalofe to us. If the M$r?ufacfura Qpm? is to be t (1$p0rted on the hway? you must
l,u„e elnnnn An tt ihla trin irtwtraru:w- If the Manufactured Home Is to be located fn an area Et-has been Ail et1Dtfed by the l?@ era) Erl'1eroency
Ie s di o laifrier of the Insurer's le itity for tailure o Salve Such enotice, You win rovlae us wun9tne original Innsqurance
ptf}y insurance Cove at - Oobtain er with all ec or u, to insurance coverage wec an getdtrr youtRgivesyyou m more natty you reQUest. we we t insurance Tor you. Th
This Insurance sh?I b in a act for 1?A moisth? etartin and will c st $ A Yqu authorize us to furnish specific
information about the Manu actured7 ome, to any lnsuran a a®nF"w f o inar"?nriSnt to quotoe premiums an o_solic?our insurance business, _
tget insurance for you, at yrour
It at an time You fail to et or keep in fo, Ca any9 insurance required by this Contract, we mar (but arenot required tq)
expens?. If w8 pet Vou i s Ins?Uance it will 1w, aual interest insurance, You fLuthgriz us tg r?ease to third parties any in pet necessary to monitor
the status of_InsTrance on your Manufactured owe and to. get the insurance esGnbe in this ontra ,
ent -__,
You agroe that we may earn a fee or commission in connection.zdlh p1aQQ ]?tIL4f tiny insurance sold in connection with this Contract to the e-
permitted by law.
If any Insurance we' at for you is cancelled by, the insurance oompan , and reolaeement coverage results to additional costs to you for the un ired
period of the original Fnsuranbe polin 1 v?'ll reimburse You for the s. It we have purchased arty required Insurance on your beltalt, at Vour exepx?pnse
and If you rep'syf the sums dUe oh this Contract, un1dw you crospec(Tlcally request cancellation, the insurance will remain I effect until me scheduled
expiration pate. in we cancel at Vyour reCUest an required insurance wa havb, purchased on our behalf, we will credit any, Aremlum refunds to anV
matured unppaid stallments due an this ?ontracty If trtere are no matured uttpald installments ti?en due on this Contract we wllf cause to be paid to yoG
those prerri m refunds,
UCFI Form MHPA11 (Pennsylvania-Dealer) Page 1 of 5 DOS DRAFTS 01114197
E I :x
+ I_oap No.j 153700001674
CREDIT INSURANCE AUTHORIZATION. WE, DO NOT REQUIRE YO.U,.T_g_tv GAT CrREDIT LJF and/or CREDIT pl AB LfTY INSURANCE WITH THIS
CONTRACT. Credit,(1fe 4nd/or Credit Disability Insurance are not regwre tam crad?t anI will not peLpro?id unless you sir this authori anon,
agree topay the additions cost and your application for insurance is approved. r requests an approves, re It a Insurance will be issued for the
mttial Amount of Benefit, stated below, and Will be in eftec) for the numf?er of months, stated below, beginning on the effective dote of the policy; This
benefit wilt decrease across the tsrrri of our ontract. his Credit Life nsurance may not cover the entire balance due on this Contract a the time of
death. If requested tahnd approved, Cre?t Disability Insurance will be issued for th monthly Amount of Benefit, stated below, and will be in effect for
d sanumbfihefp ont o1 sat%4ilityW ow, s?iheitegTnoi otitt? coverage ate of the policy , his Cretfit Disabi ity Insurance may not cover the entire period of disa Number of
Type Amount of Months You Total Your Signature
Benefit Are Covered Premium
Single Credit Life I want credit life insurance
Insurance $ 0.00 0 $ 0.00
,
(one Buyer) per month months Signature - Buyer #1 Date
I want joint credit life insurance
Joint Credit Life
insurance $ 0.00 0 $ 0.00
(two Buyers) Signature - Buyer #1 Date
1 also went joint credit life insurance
per month months
Signature - Buyer #2
1 want credit disability insurance
Date
Credit Disability
Insurance $ 0.00 0 $ 0.00 _
(one Buyer) per month months Signature - Buyer #1 Date
"e" means estimate Security: You are giving a security interest in the Manufactured Home
_ aPt ie ate
household gootls.
Your Payment Schedule will be: _ _ _ _ _ _
_
e
Late Charge: Each time you fail to make a
payment in full within fifteen
No, of Payments Amount of Payments When Payments Are Du (15) days after it is due, you will pay a late charge of two percent (21Y.)
299 $427.43 Monthly, beginning JUNE 20, 1997 of the unpaid amount of the payment, or five dollars ($5,00),
whichever amount is less.
1 $428.96 MAY 20, 2022
Prepayment: If you pay off early, you may be entitled to a refund of
part of the Finance Charge.
Assumption: Someone buying your Manufactured Home may, subject
to conditions, be allowed to assume the remainder of this Contract on
o- original terms,
Other Information: Refer to the rest of this Contract for any additional Information about security interests, nonpayment, default, any required
repayment in full before the scheduled date, and prepayment refunds and penalties.
ANNUAL FINANCE Amount Financed Total of Payments Total Sete Price
PERCENTAGE CHARGE The amo unt of credit The amount you will have paid The total cost of your purchase
RATE The dollar amount the provided to you or on attar you have made all on credit, including your
The cost of your credit credit will cost you. your behalf. scheduled payments, downpayment of
as a yearly rate, $ 15.000.00
10.500 % $ 82,960.53 $ 45,270.00 $ 128,230.53 $ 143,230.53
PROMISE TO PAY: You romis? to a us the Total Sale Price for the '?NIOUT PENALTY.
it r vat uv rw I mcc 1 r vvn a.vn i nna. l -I ........... .......-...,...............?....
MAY LOSE YOUR HOUSE, THE PROPERTY THAT YOU BOUGHT YOUR RIGHT TO REINSTATE.
WITH THIS LOAN, OTHER HOUSEHOLD GOODS AND FURNITURE, YOU MAY PREPAY ANY AMOUNTS DUE
YOUR MOTOR VEHICLE, YOUR MANUFACTURED HOME, OR
MONEY. UNDER THIS CONTRACT ANY TIME,_
-
Mar LUfacture Home by makin the DoWvyyppa nt, and then payln us Unless we ag? differently, It
writing, amts or earl payments will not
_01_11 AN[ ANC.
215 TIN 38101-0215
the Total of Al ts When ou sign tni ntract ?ti will at p us
any Prepaid ante their e sown. You 11 pay thg Total of ?ssvv nts
by paying to us monthly payments in the number and amourt?.of -
pa nts shown in Your Payment Schedule. Your first payment will be
due on the date shown In Your. _.Payment Schedule, and subsequent
payrmie'n?tts will be dye on the $ame day of e?erV month crier thatY Each
m kehall payment ill be applied as of its sc ettlluled due date, ou v,1
k el PaYrne
U
or an of r ##ii to c we star a you in w inp son Your
aynlgn Tne in ar a shown has hee calcu T d ?s:q on a
rttract ate of ei annum, pus n re mane
?arSS77e s own. W.ntract e to paV tnteres at the a Vntra p eta until the
balance ue on this is. paid In full, Jnls9s we. reee differenoy in
wrltl or are of resuted by a hcabblle lawavments wil'
ala
app5d first to npald scheduled rhonI ly payments, next to unpb
cha our obli?ppanon to ortUnue to make pavmeets as required under
the ?aa On' Schedule, ut ma reduce the pt?ittpteat balance due and
a r tt iq taws a nts. Itvy u (1 pre a tfiis Con act in full, or `2
if ?y?u e?autt an 1<al t?cure SYtour ?efau?t an? xis, deman? payment of th?
entire bal,?ttce due . n this Contract, we will C1rve, you ? clad for an
unearned Finance Ch g alculated by the acCuanal method. Howeve?
no portion of an Prep?alrl ?inance Charge will be rebated. You then will
be Jlar d a Fhance Ch?rsle on the amoum due, from the date of the
cre?t, St the Contract Rare or it the highest rate allowed by the
app ?cab?¢ law, whichever rate then is ower. W??ether you preppay br we
demand payment in full, nQ refund or credlt of less than $1.00 wilt be
made. If you defauh on this Contract and we re ossess the Collateral
Vou m7 cure or re earn thte? Collateral, and heft',66?iol er ?-o+?trf this fCOntrrt8ac?t
may ,rtsta?tge l?HT T?oREPOSSV?S?Y?UITL?NT T8eGET
BACK YOUR HOME). R
advances we made on. your behalf, and last to any unpaid collection costs YOUR TRADE-IN. You promise that anyy proper, traded-in is free from
and late charges. - art liens security interests, enourtlbrartees or tither Gat You also
are, at the time of the trade-in, the legal owner of any
LATE CHARGE. Each tin p fail to make a payment in full within 15 Pr?missroperty that traded-you in.
l you
d fl at it Is d e o uvi u a a f to ch e o two percent (2°h of the
isle ss. OniY one late, chprpa may be collected on any installment no
matter how Ibng it remains m'rJefault.
uavsstd amoum o'? tie paymntyor five dollaYS ($5.00), whichever amount
UCFI Form MHPAIS (Pennsylvania-Dealer) 0 Page 2 of 5 D08 DRAFTS 01114197
Lean No. 153""?rrt87r
Y ITEM11ATION Of AMOUNT FINANCED:
1. CE,SH PRiCc. - - - - --
a. cash sale cr+ce $ 60,250.00
b. sales tar: $ 0.00 _
c. Total Casn Price _ - $ 60 250.00
2. DO%IVNPAYMENT -
a, cash down oayment $ 15,000.00
b. Your Trade- n;
i. trade-in allowance $ 0.00
ii, balance due on trade-In $ 0.00
iii. net trade-in allowance
(amount on line 2bi minus amount on line 2bli) $ 0.00
Year Make
Moe Size Serial # _ -- _ ° -
c. Total Down Payment 15,000.00
(amount on line 2a plus amount on line 2bil0 $
3. UNPAID BALANCE OF CASH PRICE . 4b,250 00
(amount on line 1c minus amount on line 2c) $
4, INSURANCE PREMIUM COSTS
a. Manufactured Home insurance
0 month term) $ 0.00 _
b. Gap Insurance
( 0 month term) $ 0_00 -
a Credit Life insurance ----
L 0 _ month term) $ 0.00 _
d. Credit Disability Insurance
( _0 month term) $ 0.00
ARBITRATION. A cep! as explained below, you and we 0derstand
and agree that aii disputes, claims or controversies from or relating to this
Contract (whether under case law, statutory law, or any other laws
ineludin but not limited to, all contract, tort and property disputes) shall
be resolved by binding arbitration ("Arbitration"). This Contract is made
pursuant to a transaction in interstate commerce and shall be governed
by the Federal Arbitration Act at 9 U.S.C, Section 1. Arbitration shall be
conducted by one arbitrator selected-by us with your consent. You and
we agree that the arbitrator shall have all powers provided by law and
-this Centract. These powers shall include all legal and equitable
remedies including but not limited to, money damages, declaratory relief
and Injunctive relief, Judgment upon the arbitrator's decision may be
entered in any court having jurisdiction. You and we agree and
understand that you and we choose Arbitration Instead of litigation to
resolve disputes, except as explained below. You and we understand
that you and we each have a right to litigate disputes in court, but that
cou
or t
Buyer
.1 Buyer
e. Total of Insurance Premium Costs
(sum of amounts on lines 4a through 4d) $ 0.00
5. AMOUNTS PAID TO OTHERS ON YOUR BEHALF:
a. To Public Officials
(Title & Filing Fees) $ 20.00 =
b. Other: $ 0.00
c. Total of Amounts Paid to Others on Your Behalf
(sum of amounts on lines 5a and 5b) $ 20.00
6. PRINCIPAL AMOUNT FINANCED
(sum of amounts on lines 3, 4e and 5c) $ IMMIN
7. FINANCE CHARGE $ 82.96053
6. TIME BALANCE
(sum of amounts on lines 6 and 7) - --
$ 128.259
9. PREPAID FINANCE CHARGE $( 0•? )
10. AMOUNT FINANCED
(amount on line 8 minus amount on line 9) $ 128.239.53
11. PAYMENT SCHEDULE
( 299 payments of $ 427.43 each,
i
b
i
TJOR€3A-i?
7
nn
nr
ue on"
eg
9
_
(1 payment of $ 428.9 us on 0, 2022 ) __.._._ _
Title and Filing Fees (If not financed) $ 0.00
Buyer
Buyer
BUYER ACKNOWLEDGES RECEIPT OF A
COMPLETED COPY OF THIS CONTRACT AT
ZtHE TM F SIGNING.
Buyer _ L date g;
1 f>
Buyer _ date- 7
Buyer date
M H {•iI I.•??
Buyer ax " date
GUARANTEE OF BUYER'S PROMISES. The undersigned, jointly and
severally, agree(s) to pay amounts due on this Retail Installment Contract
as of today's date and until all amounts due on this Contract are paid in
full. The undersigned also agree(s) to all the terms and conditions of this
Retail Installment Contract
On I (we) _ -read, signed, and
SELLER'S AGREEMENT. Seller agrees to this Contract, and, subject to . - received a completely filled in copy of this RETAIL
acceptance by INSTALLMENT CONTRACT.
umrmp comPeN1Es FUNDING. INC.
acceptance at its designated office, assigns it to Cosigner. X
UNITFD COMPANIES FUNDING. INC. _
in accordance with the assignment set forth herein. Notice of acceptance-is
hereby waived. Cosigner. X
Seller RE CY HO ING. WOULAIMCH Ur WA
rm ante NO WARRANTIES, EXPRESS f
By, t t ?C MERCHANTABILITY, FITNESS FOR A
OTHERWISE, HAVE BEEN MADE BY L
Signalers - °_- YOU ACKNOWLEDGE HAVING EXAMII
S IF IT IS USED ACCEPT THE CI
Tue r31tt at Ct CrQ f 'date
DISCLAIMER DONS NOT AFFECT Al
rum uuwewr-rn?n ue?ue uwru
J OR IN A COURT ACTION BY US. EXCEPTION TO
Even trough you and we agree to Arbitration, we still
ial (filing a
1 -lawsuit or nonudicial relief to enforce our
, or to otherwise collect the bl alance due on this Contract,
t a lawsuit to enforce our security interest~ or to obtain a
ment, without waiving your right or our ngght to compel
any other dispute or remedy, including the fiiin of a
y you In a lawsuit brought by us. You may stilt useudlcial
relief to seek redress for any illegal act commltt in the
ayments under this Contract or in the repossession of the
Home.
TO THE BUYER: DO NOT SIGN THIS
CT IF BLANK. YOU ARE ENTITLED
EXACT COPY OF THE CONTRACT
1N. KEEP IT TO PROTECT YOUR
5-?-q
date
date S$-? 9
date
date
UCFI Form MHPA11 (Pennsylvania-Dealer) Page 3 of 5 DOS DRAFT 8
1tjpp1??OuouCCuree Gasn n I tyormieis Cosntrll r omaln in r?eenmn ift?YoU nsav ?si t4he
oa eG? re our dacett u[tt ?s?VVgvents ogftiu an ?ourpit?t?s
GOntract o r Set ???, ?o?? Rri??,t t0? tUre YD2 ??t?TO tt sec?onSOllataral
and res?l ii see ?ur'Rtg?tt to FTepoeaess se?on oir?tes ac?.
YoM also fu anr?t us d securi InWest in any Insurance proceed;;
includf unehil tino persons of property insured tri
cconnecon wis vontrapci d al we var us i instutriance
a IIRS re to P us directly e? You an o?°rl tAus to n uyroaRYYddnuuar °anY
rou ,g
r Tr auQtnw?Ys?rt{'I w r?a''-n9ll'VJ unpaf, nc rr?I I, oX
is ?on?ram - d ---
yyYyoPu wil st u in havilt our sec rttv 1 terest noted on n Itcate
of ln+R to et?ver anur??ur??t aorr>e?. Vvtl( caue and?c e f !cafe to
be vVRgq_u tonudcsel trua n o i a s o tie later q tphe o f isd pntr4ct
ri
fic t ot?t e is or ti j-p]ti?ci t?is ajnt$nt.?y° J1r npoarnjep 6pffaralclrB ant
sie8tlurr tr Q, I
nec t0 r ran Or ifa 61e OW Q($atlle Jr1? COltaterai, OrneO
e ec LO re a Ict our secu I?eCCQT?t[ in , .0 C:o'fate[af. YOU alSlp
?ut r ze us, at ou[a nee n n i e wiOUt Vour dit7nature sucl
nanang tlonU utron ske?erns, An an u le nts
rpe r oe
oreto Ic to per a t,opreserve, anodhp?ec?a?ur scti tt?y i rrees iPC
IIf an other doc meats re n can t
0 ec t our int re st i n ?h?e
C.vllatuer>?ddrou a ornetto{o n t e u ocummeri?ts ne vetr +ou Kart OU Tull
aarv ni NnT phow the to exec f anal poe}r?So?e an en rs, a VEIN. ntetetr to s asp
attome - -fact as o .co cf so if ersoll I resent Yo to
euyse itty lRiterest, a c ?rty release teeeSy erot?tisenva is paid it ul?
We agree that L, nL f r s to act as uraaaMmo In-fact for
the or?ij n nau anr?? ac&i t oNe io ss° ion of Ens Coat it cpto
P by Y P
EVENTS OF DEFAULT. You will. be In default under this Contract if;. (1)
use thepManuT urea HO 101 pusirm
noulonaer?vournon e?Sidntee:oor
it we send u Notice of befaT and Wu do o{-c re yiirtt in the
aann r a0gij the tl11 per4od desgrlbedn in 11 t?oUce, tgr i you
erau an0 we 0 not nave to I e you Ngtlce of a au e e hgve
i e t to dec(?re rnmediatefn, ue? anrlaow?nfl?the entire aancne aue on
tits ontr ct, o tree extent rmtte by f you wave ?n:sen UIE,
em nd .or payment, prof notice o di onor, an notice of
acceeration.
OUR RIGHT TO REPOSSESS; YOUR RIGHT TO GET BACK YOUR
HOME We may rO$Tss the Collator aI ifi {) ou are in daI an
yoU go pot ffillat naayt to v ure your CtefAUl that yctu )YiaV have end (3)
CYye eC are e! pa a le I'entire pA1an°e Gue on t te s a so Accele atiori r15, ir v t w;
a?rte sta Ir, tie Notice of Acco ouI a?tai?to
t , en r rnc , ue oohh the con a? n o re an
we me ov n such event
?opu fete se p eq it ?ot?ai?raY„krttotve t e o°INa ?ainga?f?ie?8 place
to o? atets or to rage.
It we re ossess wa aisc v take ao g"nsion of an they rope
an here Tor attaotlheapto
s InVe °tlateraf 1We aareve aromptl pto return 11
ou at cue rrsk wtn4 To g on oqurP rt, i?wmeatakne `poss?SSlo?ieror?veor
Oh p?oaerty we wiK ttotty yYOU in wnOn It you do not ten Crgmpt?VV
07", m and igrce, possession oT thia ro?ert wen ve X'our permtsstorl'6
jseose of it in a r enable m>t?nn r You tI ?y arty reasonaoe
c es for,storin or s. ip n suc property whc maY incur tot e
extant permitted by app icagIejawl
If w r ossess we will San ou wr af? notice statin a Scall the
event n w anti a amo ?temtze , at you re r up to to
cure itce eau€f or ref?eyeM. ?i?tor we re sseasy art rise o not Max, r?tsT
511t r t to cur or redee that e s the Co ter
a rtv to sa e o a pulAc UCc n tln wbe i en east
t?c ?l eer ter i S0't', iis98onn ci oat arnys
"or address w'9Ic ycu?ate give us?in wrung.
B re the sale you s II may pet pack h Collate aI if r1 u all
Instal2?ants due onrvaast UU aI trfe a oft Lve o he ?o?l?t?r?l?a ?C t
°ui?' n61?ieYnustiut' u l?r?ato?a eo r errasc?i?et?so, ??. hay us ha ecos?s g?
ntler the ? of"t I;;?oa?fr?cta??re any other ?tstau?s w?itc?i rile
?tVen°?1t?' - cfa?sdnSb))e ensesh o eia4un a re re ssessi n exceed
-on?ater low by aw.? ? g p?g ancP stonng tie
We will ap Iy the Mt s of an rep ession sale 1) first t our
ex oases In a ilia t 0 Mien to our cos of r 11in
re wrtn arid sort r?'then ? fo our reasongb?e an acU,
u
qom a n a or a tow h we ve 'To' t o
Fud gel III d dt ?the; ?s tyhe?reia sit a ? fairo% of p? ?
q t is r` jol o? . S e ?°his VOn
de"911 pp4?v tv u wntten Nd n autt red b?aa ?n theeII Home or
ufhnu ?t?s7 ctrl eost{r Ces o? o oeverwlitt theb [aced n on year
?taveeto gro ?youd?Voace jq `eiQttiee ) No?ices o??efau?t,ee do not
UCFI Form MHPA11 (Pennsylvania-Dealer)
i
Page 4 of 5
D08 DRAFT 9 01114197
• 4
Loan No. 153700001674
Loan No. 153700001674 NOTICE
ANY 'HOLDER OF THIS CONSUA CREDIT CONTRACT IS SUBJECT APLL CLAIMS AND DEFENSES-WHICH
THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SE: IV ICES OBTAINED PURSUANT HERETO
OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE D :EI'TOR SHALL NOT EXCEED AMOUNTS
PAID BY THE DEBTOR HEREUNDER.
SELLER'S ASSIGNMENT AND OBLIGATION' f
FOR VAL . C D receippt of which is hereby acknowledged, Seller, named hereln, hereby sel' tr ins, transfers and sets over unto
ATE M F'UNDIN Its successors and assigns, the
foregoing eat Installment on rac reins er escriebTas t he ">?onn"ac, an .a 'IIn ' i ell a ` f rt serest anc! to the property therein described and
all monies due and to become due and all rights and remedies under the ontract, with power in ss :;nee to assign efther in Assignee's own name or in
the name of Seller, for Assignee's exclusive benefit, and to take all such legal or other proceeding: a:: Seller might have taken save for this assignment,
Acceptance of the Contractby Assignee shall occur at Its designated office when it issues its check t ,. tl a Seller(s) as payment for the Contract.
A. To induce Assignee to purchase the Contract, Seller warrants that (1) to the best of Soler'!: knowledge, Buyer(s)' credit statement submitted
herewith is true and correct unless otherwise specified in writing; (2) Buyer(s) were of legal aqq to c on! "act and otherwise legally competent to contract at
the time of the execution of the Contract; "(3)-the Contract arose. from the?ona fcl safe of the p1r4 ft. described in the Contract; (4) all signatures on the
Contract are genuine; ( Seller has ggood(Ube to the Contract, Free and clear of all liens claims a: d :,ncumbranees and Seller has full power and legal
authority to assign the ontract; (6) i-mmedtatel prior to the execution of the Contract Sreller had" oc.3" title to the Wanufactured Home and any property
sold therewith under the Contract assigned herein, free and clear of all liens, claims anti encumbrari as M any property received by Seller In trade on this
Contract is free from an liens, security interests encumbrances or any other claims, and Buyer(s) at, rte time of execution of the Contract, were the legal
owner(s) of such props (8) the down payment was made by Buyer(s) in cash andnot its equivak nt inless otherwise specified, and no part thereof was
loaned directly or indirec y by Seller to Buyer(s); (9) the Buyer {s) have accepted delivery of and art: the owners of the property described in the Contract;
(10) Assignee is acquiring a purchase money security intere?s] in the Manufactured Home tree tnc clear of any lien, claim or encumbrance; (11) A
MManufactured Home Certificate of Title showing a first priority lien or encumbrance naming tfte Ass gnae as secured party has been or will be applied for
promptly; where appropriate a UCC-1 financing statement or UCC-1 Jx_1 re fWngl i)meiy,perlegtiri Tirst priority lien or encumbrance in favor of Assignee
has been or will be filed ; (12) there is now owing under the Contract the amount set forth as 1' . of Payments" and Buyer((s) have and will have no
setoffs, counterclaims or defenses against amounts due or to become due under the Contract; L131 the Contract and eacfi guarantee submitted in
connection therewith are in all respe genuine unamended, andlegalfy` onforceable without dei ense or counterclaim against each purported signatory
thereof; (14) Seller has compiled with all applicable laws and regulations in the sale of the Manuf:ctr.red Home; (15) the design and construction of the
Manufactured Horne is In compliance with all applicable regulations of the Department of Housing and Urban Development (hereinafter known as "HUD
including, without limitation, the specifications in effect as of the date hereof prescribed in the Mangy facwred Home Construction and Safety Standards Act
of 1974, as amended; and (16) Seller has complied in full with all provisions of (a the Federal Cor sumer Credit Protection Act of 1966, as amended, and
with all regulations issued thereunder, (b) the Federal Trade Commission Act and all rules and reculations promulgated thereunder, (c) the provisions of
section 561(c) of Public Law 96-221 and the regulations of the Office of Thrift Supervision promuf¢ate ? thereunder, each as amended, (d) all provisions of
24 C.F.A. Apart 201 concerning Manufactured Home location standards and (e) any of=r appl'ical!ie ederal, State and local laws, regulations, rules and
ordinances.. .
B. In the event any of the warranties made by Seller in para?raph-A above Is determined by Assignee to have been false when made, whether or not
such false representations were knowing or intentional and whet per or not Assignee relied upon any such false representations, or in the event that any of
the foregoing warranties are breached-in any other way, and whether or not there is a default n payment, Seller shall repurchase the Contract from
Assignee, upon demand, without recourse, for an amount of cash equal to the balance due on the Antract computed as of the date of Seller's purchase,
with credit for whatever rebates would be due to the Buyer s) on the Contract It the Buyers , on the cate of Seller's purchase, had prepaid the Contract In
full. The repurchase price also shall include an additions sum equal to five percent {5h of the balance due on the Contract, as and for Ass'ignee's
liquidated damages for Assignee's profit lost on the Contract, which amount Seller and Assignee hertoby agree is reasonable in light of the anticipated or
actual harm caused Assignee by reason of Seller's act(sl-ths difficulty RLp oof of such loss, and the Inconvenience or nonfeasbbillty of otherwise obtaining
an adequate remedy. -
C. Seiler further agrees: (1) that in the event that Buyer(s) fail(s) or refuse(s) to make any Kayrnent due hereunder on the assertion, either oral or
written, that the Manufactured Home is defective, not as represented to Buyer(s? by Seller, or that Seller has refused to honor any warranty or service
agreement of Seller or manufacturer, upon being advised by Assignee of such calm of Buyer(s)', Seller will repurchase the Contract from Assignee and
ayy Assignee for same. immediately in accordance with the terms set forth in ar ra In B above a ,id 'Seller further agrees, and without the necessity of a
air ?udicfal determination to indemnify and hold Assignee harmless from`any ot>E a os?s susteaned _s a result of any claim or defense Buyer(s) may have
against Seller (b) claims of Buyer(), including but not limited to claims for refund of payments made by Buyer(s), (c) claims for Buyer(s) attorneys' fees,
whether or not any litigation occurs, and (d) claims or expenses related to the assertion of Buyer(s' claims, including but not limited to Assignee's
attorneys' fees, costs and expenses incurred, whether or ppt any liti ation occurs; (2) to sell, at the request of Asslppnee, the Manufactured Home, together.
wdth any other proppeerty purchased under the Contract, which haseen repossessed by or for Assignee; Seller-turther agrees that repossession of the
property from the Buyer(), for any cause, shall not release Seiler from the obf[gation&..of this aGVafttnepl; (3 1 Ass?igqnee is hereby authorized, but not
obligated, to correct any and all errors in the Contract; (4) that the failure to file or record this instrument or any rotated instrument when required by law
shaft not release Seller from Seller's, obligations hereunder, (5) not to make any settlement with an+i Buyer(s) on the Contract asstnod hereby without
Assignee's prior written consent; (6) tFtat Assignee does not assume an obligation or liability of Seller with respect to the Contractor otherwise and Seller,
without the necessity of a judicial determination of such liability will hold Assignee harmless from and against any expense or liability Incurred by Assignee
as the result of any obligation, liability or action of Seller including, without limitation, Assignee's attorneys' fees, costs and expenses incurred in defending
anyy such claim whether or not any litigation occurs; C1) that Assignee shall have the sole right to make collections on the Contract and to notify each Buyer
of the assignment; (61 not to solicit or make any collections with respect to the Contract after it is sold to Assignee, and that all such collections and other
pproceeds from such Contract which may be received by Salter shalt be held by it in trust for the Assignee-and promptlyy transmitted to Assignee, and to
torward to Assignee promptly all communications and inquiries which Seller may receive with reference to the Contract; ((9) that Assignee may audit Seller's
books and records relating to the Contract; (10) that the waiver of any default hereunder shall not operate as a waiver of subsequent defaults, but all rights
hereunder shall continue notwithstanding one or more waiverg.an that 4ts waiv er or c ante o, an?trision herein shall not be binding on Assignee
unless made in a writing signed by it; (? 1) that this a reement shall inure to and bind"Setter's and Assignee's respective legal representatives, heirs,
successors and assigns, and any company affliated Nth either Seller or Assignee which may transact business pursuant hereto; (112) that all obligors
hereon severally waive demand and presentment for payment, notice of nonpayment, notice of protest of this instrument and agree that their liability
hereunder shall not be affected by any extensions of the time of payment of all or any part of the amount owing hereon at any time or times; all parties
hereto also consent to any renewals, release of co-makers, any subsiilions or,ad¢itions of-rtee 9u?ec(s for any one or more of the Buyer(s) onginally
signing the Contract, substitutions of collateral releases of collateral, and any and all waivers or other modifications that may be granted or consented to by
Assignee and hereby waive notice thereof; (Ii? that Assignee's rights and remedies hereunder shall be cumulative and Assignee may exerc[se any rights or
remedies, whether against Buyer(s) under ttfe Contract, against tile security therefor, against Seiler, against security of Seiler or against any combination of
the foregoing, in suc order as Assignee sees fill without thereby releasln any other right ft may haves (14) that in the event of default the Assiggnee may
proceed against any or all of the parties hereon and shall not be required to first resort to any secun even by any or all of the parties (r15 that tfia filing of
a petition under the United States Bankruptcy Code by or against any one or more of the Buyer Is shall not release Seller from SsliePs obligations- or
liabilities hereunder; (16) that if this agreement is referred to an attorney forenforgement_or collection, Seller shall pay Assignee's reasonable attorneys'
fees d"sbu ments,, court costs and o1 er related expenses.
D. ?n a t n, thistr?e ea?tt t?? eGt to tie provisions set forth below in the pparagrapph initialed by Seller,
WITHOU? REGOU SE. The assignment of the Contract is atld srfall "be without recourse ainst Sager"exce t as set forth above.
F P FULL RECOURSE. Seller unconditionally and absolutely guarantees paymenTof f Fe fit amours rem rig unpa d antler the Contract
R and agrees to repurchase the Contract from Assignee, upon demand, whether the Contract shall then be, or not be in default, for the
N P full amount then unpaid, with credit for whatever rebates would be due Buyer(s) on_the Contract If Buyer(s), as of tfte date of Seller's
I L O payment, had prepaid the Contract in full.
T E FULL REPURCHASE, If the Manufactured Horne which secures the Contra is repossessed by or on behalf of Assi nee Seller
agrees to repurchase the Contract from Assignee, upon demand, regardless of the.condition or locobQ r of the Manufactured Home
I C S ! as is, where is"). The repurchase price shall be the balance due on the Contract, computed as of the date of. repurchase, with credit
A A for whatever rebates woufd be due to Buyer(s) on the Contract, as [f. Buyer(s`, as of the date of rg urchase, had prepaid the Contract
L B ? in full, together with Assignee's repossession expenses, including, but not limited Io, aahy ootafco§ts and attorneys fees, storage, repair
p and towing expenses. Upon payment Assignee shall reassign the Contract to Salter.
L N LIMITED REPURCHASE. Seller agrees to comply with the terms and conditions of the foregoing Full Repurchase Agreement (which
E are Incorporated herein by reference) provided however, that such obligpations of Seller shall terminate hereunder upon payment by
Buyer(s) of each of the first monthly installments, each witt_%m fifteen (15) days of its respective due date. _
UCFI Form MHPAI I (Pennsylvania-Dealer) Page 5 of 5 L108 OAAi^7` B 0111497
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Basom Pm4c, LA 70809
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DEFER3LAL AGREEMENT
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Buy=Mormwers: Georse m Bty"Ely.+oaste m Bryson
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Cara" Pa 17013
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home.
0 The Contest now belongs to Orated Companies Funding, be. MC M.
(3) (1) The iasummeat maw east, defeetsd 3 mondfs and will not be due unwom*
The ohaso for this defmral is RL92.
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(6) Except as a praaly ebaemod by tbia Agracc=% the Comma cmtm is the entire asreemeat of
BuyerMonowec(s) and UCFI CmtfQruer in full farce and P IN-
NOTICE TO BUYIC JBORKCV% WS): IF YOU DO NOT !AY THE 10$F$ILV AL CHARGE DUB,
YOU WILL B$ IN DEFAULT ON YMM COWMACTM
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LIMITED POWER OF ATTORNEY
KNOW ALI, MEN BY TH.-,SE PRESENTS, that Deutsche 13;ank National `!'rust
Company, a national banking association organized and existing
under t;ho Jaws of the United SLate;s, formerly known as Bankers
Trust Company of California, N,A. and having its principal place.
of business aL 1761 last St. Andrew Placo, SanLa Arta, Califaa,iiia,
92105, as Trustee (the "Trustee") pursuant to those Pooling and
Servicing Agreements for UCFC MH Trust 199E-2, UCFC MH Trust
199-1-2, UCFC M11 Trust 1997-3, UCFC M11 TrusL 199'2--4, UCFC MH Tru:jL
199f3-1, UC("C M11 Trust 19992 and UCFC MI1 Trust 1998-3, as
amended, supplemented and modified from time to time in
accorclanee with i.tn terms (the "Agreements."), the assignees of
Unitod C:orrtparties Funding, Inc:., united Companies Landing
Corpnra(.iont? and UNICOR MortgagOO), Inc. (col]ectively known as
hereby constit.tites and appoints Groan Tree Servicing
or i.i:s i:i.f.filiateu (the "Servicer:"), by and through any of the
Service.rl ri officers or employees duly authorized by written
rosolution on its behalf, the TrusLee's Lr.ue and lawful At.torrtcy--
tri-l"act, in the `rrusteal s name, place and stead and for the
Trustee` s berioti,t, in connection with all mortgage loraas sarvi.cad
by thu ,)(arvicer pursuant to the Agreemarrt's solely for the purpose
of performing such acts and executing such documents in tho nano
cif t,hc Trustee necessary and appropriate to effecLuate the
Following ontameraLed transactions in respect of any of tho
muri-gn9cu oz doods cL trust; (tho "Mortgages" and the "Deady of
Trust." respec:ttvely) and promissory notes sacurod thereby (the
"MovLgage Notes") for which the undersigned is acting as Trustee
fox variaus cui of icat-eholders (whet-her the undersigned is named
r.huTein as rnort:gage-e or heneficicry or has become mortgagee by
virt im, of endorsement of the Mortgage Note secured by any such
lAoa: Lclagc or t)ued of Trust) and 'tor which Green Tree Servicing I.LC
or iLs 4fiflli.aLo are acting as tho Servicer.
This Appointment shall apply only to the following enumetatod
traatgactoTis and nothing herein or in the Agreement: shall be
coribt rued to the contrary:
l.. The modi fi cEiLion or re-recording of a Mortgage or hood
of Trust, where: said modification or re-recording is
solely for, thL, purpose of correcting the Mortgage or
Deed of Trust to r_ontorm same to the original intent of
t.hc! parties thereto or to correct tiLle errors
disnoveLOd after such title ineu>:ance was issued;
V6V_" nn?7 7I nn, ^n ?u
px'ovi.dea that W said modification or re-recording, in
either instance, does noL adversely affect the lien of
the Mortgage or been of 'rust as insured and
(,i.) othcvwise conforms to the provisions of the
Agreement,
2. The subordination of the lien of a Mortgage or Deed of
Trust to an easement in favor of a public: utility
company of a government agency or unit with powers of
eminent domain; this saction shall include, withouL
limitation, the execution of partial
.,atisfactions/rcleasen, partial reconvoyanccs or the
oxeci tior? or rc-quests to t custCas to accomplish game.
3. The conveyance of the properties to the mortgage
insurer, or the closing of the title to the properly to
be acquired as roil estate owned, or conveyance of
title to real estate owned.
4. 't'he completion of loan assumption agreements.
5. The full satisfaction/release of a Mortgage or mead of
't'rust os full convoyance upon payment and discharge of
all sums secured Lherek) y, i.ncludi.rlg, wi Lhout
limitation, cancellation of the related Mortgage Note.
6. The assignment. of any Mortgage or Deed of Trust and the
related Mortgage Note, in connection with the
ropurc.hase of Lhe mortga,go loan secured and evidenced
thereby.
'I. Tho mull assignment of a Mortgage or. Deed of Trust upon
payment and dischargo of all stuns secured thereby in
core j?u?ctrion with the refinancing thereof., including,
without lin?itation, the assignmcr?t of the related
Mortgage Note.
8. With respeCL to a Mortgage or Deed of Trust, the
foreclosure, the taking of a dead in lion of
fore:clo5tire, or the completion of judicial or non--
judicial foreclosure or termination, cancellatior, or
rescission of any such foreclosure, including, wi.thouL
limitation, any and all of the following acts:
it. i.he substitution of trustee(s) serving under a
Deed of ',Crust, in accordance with state law and
tine Deed of Trust;
2
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M,av_?^-'7!'^7 ??!?'^ ?fi: ?? aN CQU tin
n?
1). the preparation and issuance of statements of
breach or non--performance;
C. Lhe preparation and filing of noticos of default
and/or notices of sale;
d. the c:ancollation/rescission of notices of default
and/or notices of sale;
o. the taring of deed in lieu of foreclosure; and
f. the preparation and execution of Such other
documents and performance of such other actions as
may be necessary under the terms of the Mortgage,
Doed of Trust or slate law to expeditiously
complete said transacLi.ons in paragraphs 8.a.
through 8.e. abovo.
With respect to the sale of property acquired through a
foreclo3ure or deed-in licu of foreclosure., including,
without limitation, the execution of the following
riocumernLat i.on:
a. listing agreements;
b. purchase and sale: agreements;
C. grant/warranty/quit claim deeds or any other deed
causing Lhe transfer of title of the property to n
party contracted -to purchase same;
ci. escrow instructions; and
e. any and all documonts necessary to ef.fecL the
transfer of property.
]Q. The modification or amendment of escrow agreements
eutahl.ished for repairs to Lhe mortgaged pr.oporty or
reserves for replacement of personal property.
11. With respect to tranaactions secured by manufactured
huusincj, whathor such transactions are secured by a
mvttgago, iien on a certificate of title or perfected
by a U,C:.C. financing statement, to execute all
doc:unjants necessary on behalf of the Trustee relating
' to loan payoffs, releases of titles, releases of
sccuriLy interests on O.C.C. financing statements oz-
other similar documcrits rolated to manufactured
housing.
3
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Thr.: tYSU.ior: ictnecl gives said Attorney-in-Fact full power, and
,auttto_it:y to execute such inst.rumQnts and to do and perform all
and tevuty act and thing necessary and proper to carry into effect
tlic; Fyower. or powers granted by or under this Limited Power of
At: Loy ney cis fully as the iindersigned might or could do, and
Xte:reh,y ooe3 ratify and confirm to all that said Attorney-in-Fact
.,hall tic: c3fferL'ive as of March 1, 2007.
Thi^ appoi.ntmonL ise Lo be construed and interpreted as a limited
power of attorney. The enumeration of spoc:ific items, rights,
act.., or powers herein is noL intended to, nor does it give rise
to, and it is not to be construed as a general power of attorney.
Nothinrl contained herein shall. (i) limit in any manner any
ijidornnificatioii provided by Lhe Service.,- to the Trustee under the
A(JrUement, or (ii) be construed to grant the Servicer the power
to iniL'iate or defend any suit, litigation or proceeding in the
rizimu of Doutschc Bank National Trust Company except as
spur:ificall.y provided for herein. If the Servicer receives any
not,ic.e; of ;Ljit, litigation or proceeding in the name: of Dout scho
flank N,atiorial Trust Company or Bankers Trust Company of
Cal.i fo nia, N.A., then the Servicer shall promptly forward a copy
of y?ama to she Indonture Trustee.
Thi. , limited power of attorney is not intended to extend thin
powt!!rs grtiYlted L4 the. Servicer under the Agreement or Lo allow
the. Storvicc r to take any acL!on with respect to Mortgages, needs
Of Tru.;L or Mor'tgagn Notes noL authorized by 1-he Agreement.
1'he ;;c.rvic:er her ehy agrees to indemnify and hold the Trustee and
i.Crc directors, otf.icers, employees and agents harmless from and
<htj 0 not any and all liabilities, obl ignitions, ios.-;es, damages,
(?cnrel r i e actions, judgmcnLs, suits, costs, expenses or
disbursements of any kind or nature whatsoever incurred by reason
or re-itil t: of or in connection with the exercise by the Servicer
cif ttzc powers grantect to it horeunder. The foregoing indemnity
:,lhll sijrvive the termination of this Limited Power of Attorney
wind thr Agreement or L•he earlier resignation or romoval of the
Trustee under" the Agreement.
`1'hi.; Limited Power of Attorney is ontered into and shall. be
governed by Lhe laws of the State of Now York, without- regard to
c.or+f.licta of. law principles of such state.
Tbi rd pt-ir.t'i.es without actual notico may rely upon the exercise of
t,ho powc:t gxantcd under this Limited Power of 2Attorney; and may
tic; sat.infiod that L•hi s Limited Power of Attorney shall continue
.ill `1211 force and effect and has not. been revoked unless an
4
A• J
j/
FAY NO,
N (j5
ins,Lr.ument of revocation has been made in writing by the
utictersir?rf?,cl.
.IN WITNESS Wflf-t'REOP, Dc.utsc:he Bank Nations] Trust, Company, as
Trustee has caused its corporate seal to be hereto affixed and
those presents to be signed and acknowledged in its name acid
i)ehalf fsy a (ItA y elected and authorized signatory this 20th day
of, March, 2007.
Deutsche Bank National Trust Company,
formerly knowti as Rankers Trust Company of
California, N.A.,
as Trus ee
By.
Name: Ronal(io ' s
Title: Vice P sid,ent
Ac:ktiuw1ndried and Agreed
G)*een 't'ree Servicing rLjLC
?? ??? lrlYlGc
By,
N?rrnc.:
Aviisfln! Errrntary
:;`PA'L'ES OF CALIFORNIA
COUNTY OF Orange
On 14arch 20, 2001, before me, tho undersigned, a Notary
Public: in and for said state, personally appeared Ronaldo Reyes,
Vice President of Deutsche Rank National Trust Company, as
Trustee, personally known to me to be the parson whose name is
subocri bc-d to the within instrument and acknowlecigod Lo ine that
he:/qhe oxr_cutod Lhat same in his/her authorised capacity, and
thi-it. by his/her signature on the instrument the entity upon
bobal.f, of which the parson acted and executed the instrument.
WITNESS my han(I and official seal.
Notrary Pub.?'?- ,gate of California
I i• 4 ` Al .„?t. y 1'u) l{Iq - (,. Mfr l+M'•? ?
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I'MMONWEALTH OF PENNSYLVANIA
'PARTMENT OF TRANSPORTATION
BUREAU OF ROTOR VEHICLES
PO BOX 8279
HARRISBURG PA 17104-2516
r INFORMATION (7:00 AM TO 9:00 PM)
WITHIN PA 1-800-932-4600
FROM OUT-OF-STATE (717)-391-6190 6th J
WITHIN PA ON A TDD 1-800-228-0676
FROM OUT-OF-STATE ON A TDD (717)-391-6191
AUG 11, 1997
GEORGE D B YVONNE M BRYSON
129 REGENCY NORTH
CARLISLE PA 17013
DEAR APPLICANT:
THE BUREAU OF MOTOR VEHICLES HAS RECEIVED YOUR APPLICATION RELATED TO THE
FOLLOWING VEHICLE: MAKE: MANORETTE, BODY TYPE: MOBILE HOME, VIN NO: TUO0647A8,
TITLE NO: 00000000
THE APPLICATION COULD NOT BE PROCESSED FOR THE FOLLOWING REASON:
THE MANUFACTURER'S CERTIFICATE OF ORIGIN IS REQUIRED IN CONJUNCTION WITH
APPLICATION FOR TITLE TO THE VEHICLE DESCRIBED ABOVE.
ANY NEGOTIABLE CHECKS OR MONEY ORDERS SUBMITTED WITH THE APPLICATION HAVE BEEN
DEPOSITED BY THE BUREAU.
PLEASE FOLLOW THE INSTRUCTION(S) LISTED ABOVE AND RETURN THIS DOCUMENT IN THE
ENCLOSED SELF-ADDRESSED ENVELOPE. IT WILL RECEIVE OUR PROMPT ATTENTION,
IF A NOTARY PUBLIC, MESSENGER OR DEALERSHIP ASSISTED YOU IN THE COMPLETION OF
YOUR APPLICATION YOU MAY DESIRE TO RETURN THIS LETTER TO THEM FOR ASSISTANCE
IN MAKING THE ABOVE CORRECTION.
THIS FORM WILL BECOME A PART OF YOUR APPLICATION, THEREFORE, YOUR SIGNATURE IS
REQUIRED BELOW. IF YOU HAVE ANY QUESTIONS, PLEASE CALL A MEMBER OF OUR SERVICE
REPRESENTATIVE TEAM AT ONE OF THE TELEPHONE NUMBERS LISTED ABOVE.
APP1,TCANT'S SIGNATURE
DATE
SINCERELY,
SERVICE REPRESENTATIVE TEAM
BUREAU OF MOTOR VEHICLES
PaPaAwvvl. _ Pe
97198 0052 000969 001 4241 "
7202 r G
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NINTH JUDICIAL DISTRICT OF PENNSYLVANIA
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Deutsche Bank National Trust Company
Plaintiff,
V.
George D. Bryson, et al.
Defendants.
l v
M
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17
?
Court Term r
' C;?
No. ?
.
=o CD -n
c
Complaint in Replevin D a t n
MOTION FOR ORDER OF POSSESSION OF PROPERTY
PURSUANT TO PA. R. C. P. 1073, et seq.
Now comes Plaintiff Deutsche Bank National Trust Company ("Plaintiff'), and hereby
moves this court pursuant to PA. R. C. P. 1073, et seq., for an Order of Possession. Plaintiff
requests that this Order of Possession direct the Sheriff of Cumberland County to seize and
forthwith deliver to Plaintiff, or accompany the Plaintiff in repossession of the following
property now in possession of Defendants and wrongfully detained by Defendants: a 1996
Manorwood manufactured home, Serial No. TU00647A/B.
Plaintiff makes its motion on the grounds that Defendants obtained possession of said
property pursuant to a Manufactured Home Retail Installment Contract ("Contract") entered into
on or about May 8, 1997. A copy of said Contract is attached to Plaintiffs Complaint as
Exhibit A and incorporated herein by reference. Plaintiff Deutsche Bank National Trust
Company is the holder of the Contract. Defendants have failed to remit to Plaintiff the monthly
payments required in the contract and said contract has been terminated by Plaintiff for
nonpayment. Said termination ended Defendants' right to further possession and use of said
property. Defendants continue to wrongfully detain the property.
s `
For the foregoing reasons, Plaintiff respectfully requests this Court grant Plaintiffs
motion and execute an Order of Possession.
Respectfully submitted,
David J. D rs (#307952)
COOKE, DE ERS & GLEASON, LLC
Three North High Street
P.O. Box 714
New Albany, Pennsylvania 43054
Telephone: 614-939-0930
Facsimile: 614-939-0987
Attorney for Deutsche Bank National Trust Company
NINTH JUDICIAL DISTRICT OF PENNSYLVANIA
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Deutsche Bank National Trust Company
Plaintiff,
V.
George D. Bryson, et al.
Defendants.
-
Court Term
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No. .
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VERIFICATION AFFIDAVIT
STATE OF PENNSYLVANIA }
} ss:
COUNTY OF FRANKLIN }
David J. Demers, Esq., a credible person, first being duly cautioned and sworn, states as
follows:
1. I am one of the attorneys for Plaintiff Deutsche Bank National Trust Company.
2. That the Plaintiff is applying herewith for recovery of a 1996 Manorwood
manufactured home, Serial No. TU00647A/B (hereinafter referred to as "Collateral"); that the
Collateral is located at 129 Regency Woods North, Carlisle, PA 17015, that to the best of
Affiant's knowledge, the Collateral is worth approximately Twenty-Five Thousand and 00/100
Dollars ($25,000.00); and there is due and owing pursuant to the terms of the Contract the net
sum of Thirty-Nine Thousand Eight Hundred Seventy-Two and 39/100 Dollars ($39,872.39) as
of December 28, 2011.
3. That the Defendants have used the Collateral, to the best of Affiant's knowledge,
for personal use.
4. That Defendants executed and delivered to Plaintiff a Manufactured Home Retail
Installment Contract and Security Agreement (hereinafter referred to as "Contract"); that a copy
of the Contract is attached to Plaintiff's Complaint as Exhibit A.
1.
5. That pursuant to the Contact, Defendants granted Plaintiff a security interest in
the Collateral, which security interest Plaintiff perfected by noting its lien on Pennsylvania's
Certificate of Title for the Collateral, a true and accurate copy of which is attached to Plaintiff's
Complaint as Exhibit C.
6. That pursuant to the terms of the Contract, Plaintiff has a right to possession of
the Collateral upon default; that Defendants have failed to make the required Contract payments
to Plaintiff; that Defendants are now in default under the terms of the Contract; and that
Defendants are presently in arrears on her account in the amount of One Thousand Six Hundred
Fourteen and 96/100 Dollars ($1,614.96).
7. That the Defendants have wrongfully detained the Collateral and have failed or
refused to return the Collateral.
8. That Plaintiff has suffered considerable injury because of Defendants' detention
of the Collateral and will continue to suffer such injury for as long as Defendants have
possession of the Collateral.
9. To the best of Affiant's knowledge, Defendants have no claim that their detention
of the vehicle is lawful.
10. After reasonable investigation, Plaintiff has determined that the manufactured
home is located at 129 Regency Woods North, Carlisle, PA 17015.
11. The vehicle was not taken for a tax, assessment, or fine pursuant to statute, or seized
under the execution of judgment against the property of Plaintiff.
FURTHER AFFIANT 5AYETH NAUGHT.
David J. D ers (#307952)
The foregoing affidavit was sworn to and subscribed before me this LO day ??day of
b 112012.
M A. MI -VA Mf:KI
NOTARY PUBLIC Notary Public U
My Commission Expires: LA-
STATE OF OHIO
Ay comm. Eas 0-
?$U' dH ,fifa!'t r 1OAP.q
?^ E
ADAM J. BENNETT WOKE, DEMERS J°HN A. GLEAsoN
ANDREW P. COOS KEN C. KECH
DAvmJ. DEMERS CWjLEASON LLC KYUE KErrcH
also admitted in Indiana KRisTA A. MRoczKoWSHI
and Pennsylvania also admitted in West Virginia
March 13, 2012
VIA FEDERAL EXPRESS
Cumberland County Prothonotary's Office
Cumberland County Court of Common Pleas
1 Courthouse Square, Suite 100
Carlisle, PA 17013
RE: Deutsche Bank National Trust Company v. George D. Bryson, et al.
Dear Clerk:
Enclosed for filing in the above referenced matter are the original and five (5) copies of
the following:
1. Complaint;
2. Motion for Order of Possession of Property;
3. Verification Affidavit;
4. Notice of the Proceeding; and
5. Notice to Defend.
In addition, please find for filing, the original and one (1) copy of the:
6. Request for Service; and
7. Civil Case Information Statement.
We request that the hearing date be scheduled at least twenty (20) days from the
filing of this action to insure that adequate time has been given to obtain service on the
Defendant(s) and make the necessary return(s) of service.
Please time-stamp one copy of each document (including this letter) and return them to
my office in the enclosed envelope with the case number, the hearing date and the name of the
judge assigned.
THREE N. HIGH STREET • P.O. BOX 714 • NEW ALBANY, OHIO 43054
office 614.939.0930 • fax 614.939.0987
www.cdgattorneys.com
Thank you in advance for your assistance in this matter. Should you have any questions
or concerns please feel free to contact our office at your convenience.
Very truly yours,
&b-td ) &Qjy? ? -r-I -
David J. Demers
COOKE, DEMERS & GLEASON, LLC
Attorney for Deutsche Bank National Trust
Company
Case No.:
Hearing Date:
Judge:
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Deutsche Bank National Trust Company
vs.
George D. Bryson (et al.)
SHERIFF'S RETURN OF SERVICE
Case Number
2012-1634
03/16/2012 08:49 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 16,
2012 at 2049 hours, he served a true copy of the within Notice, Complaint on Action for Replevin and
Motion for Order of Possession of Property, upon the within named defendant, to wit: George D. Bryson,
by making known unto himself personally, at 129 Regency Woods North, Carlisle, Cumberland County,
Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct
copy of the same.
RYAN B
03/16/2012 08:49 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 16,
2012 at 2049 hours, he served a true copy of the within Notice, Complaint on Action for Replevin and
Motion for Order of Possession of Property, upon the within named defendant, to wit: Yvonne M. Bryson,
by making known unto herself personally, at 129 Regency Woods North, Carlisle, Cumberland County,
Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct
copy of the same.
RYAN BURGETT,
SHERIFF COST: $50.45
March 19, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
T
2012 MA 28 AM 8: 41
UMSi:kLAi4D GOBI)
FENNSYLYANIA
DEUTSCHE BANK NATIONAL
TRUST COMPANY,
Plaintiff
V.
GEORGE D. BRYSON
YVONNE M. BRYSON,
Defendants
Ar-
*400 1W 4r" 4*1113%x
IN THE COURT OF COMMON PLEAS OF
THE NINTH JUDICIAL DISTRICT
NO. 2102-1634 CIVIL TERM
IN RE: MOTION FOR WRIT OF SEIZURE
?ij?i •
AND NOW, this 10TH day of April 2012, upon consideration of Plaintiff's
"Motion for Writ of Seizure," a Rule is issued upon all interested parties to show cause
why the relief requested should not be granted.
RULE RETURNABLE within twenty days from the date of service.
Thomas . Placey C.P.J.
L..
. €.:.':, ..
Distribution List: 5
E
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David J. Demers, Esq.
Three N. High Street
New Albany, Ohio 43054 =C2
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George D. Bryson C
129 Regency Woods, North
Carlisle, PA 17015
4"es via.`led 4lrolea
Pee
Yvonne M. Bryson
129 Regency woods, North
Carlisle, PA 17015