HomeMy WebLinkAbout12-2239I
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
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RE: Joint Petition of J.G. Wentworth NO: /a • x.39 01VI(TerN
Originations, LLC and Patrick McKnight :
NOTICE OF HEARING ON PETITION TO TRANSFER STRUCTURED
SETTLEMENT PAYMENT RIGHTS
J.G. Wentworth Originations, LLC
201 King of Prussia Road
Radnor, PA 19087
Patrick McKnight
100 B Street
Plainfield, PA 17601-4343
Amber Webster
100 B Street
Plainfield, PA 17601-4343
You are hereby given notice that J.G. Wentworth Originations, LLC has filed a petition
to transfer structured settlement payment rights. A hearing in this matter has been scheduled on
2012 at o'clock in courtroom no. courthouse,
Cumberland County Court of Common Pleas, Pennsylvania.
You are entitled to support, oppose or otherwise respond to the payee's petition, either in
person or by counsel, by filing written comments with the court prior to the hearing or by
attending the hearing.
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IV
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
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To: Metropolitan Life Insurance Company
Attn: Structured Settlements
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Metropolitan Property & Casualty
Insurance Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
The Name, Address and Tax Identification number of the transfe a is
Originations, LLC. 201 King of Prussia Road, Radnor, PA 19087, T,a..D?
y S-/Z
Date
BY:
Ro Waro, Esquire
Aft9fhey for J.G. Wentworth
Originations, LLC.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600
(610) 275-9666(facsimile)
85.
410.3-1-5 Po A-r ry
tZ# oZ 73 5V,,57
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO: l? ?Z39 ???G ??
Originations, LLC and Patrick McKnight :
JOINT PETITION FOR PARTIAL TRANSFER OF STRUCTURED
SETTLEMENT PURSUANT TO STRUCTURED SETTLEMENT PROTECTION
ACT, 40 P.S. 4000, ET SEQ.
TO THE HONORABLE JUDGES OF SAID COURT:
And now comes your petitioner, J.G. Wentworth Originations, LLC, by and
through its attorneys, Maro & Maro, P.C., and joint petitioner, Patrick McKnight, and in
accordance with the applicable rules of Pennsylvania Civil Procedure, hereby represents
as follows:
1. Petitioner is J.G. Wentworth Originations, LLC. ("Buyer" or Transferee"),
with an office address located at 201 King of Prussia Road, Radnor, PA 19087.
2. Joint Petitioner is, Patrick McKnight ("Payee"), an adult individual who
resides at 100 B Street, Plainfield, PA 17081.
This Joint Petition has been verified by the Transferee, J.G. Wentworth
Originations, LLC. and the Petition includes all necessary information as prescribed by
PA R.C.P. 229.2(d) et al and Section 3 of the Act, 40 P.S. §4001 et seq.
4. Pursuant to PA. R.C.P. No. 229.2(d)(3) there are four (4) attachments
incorporated herein as follows:
a. PA R.C.P. 229.2(d)(3)(i) Payee's Affidavit in Support of Petition.
Please see Attachment/Exhibit "I"; and
b. PA. R.C.P. 229.2(d)(3)(ii) An Initial Order of Court Scheduling
Hearing;
c. PA. R.C.P. 229.2(d)(3)(iii) A certification by Robert A. Maro, Esquire,
attorney for transferee, J.G. Wentworth Originations, LLC.; and
d. PA. R.C.P. 229.2(d)(3)(iv) A Final Order of Court Granting
he Petition.
5. Joint Petitioner, Patrick McKnight, is the beneficiary of an annuity
owned by Metropolitan Property & Casualty Insurance Company and issued by
Metropolitan Life Insurance Company. The structured settlement provides payment to the
petitioner as described on Attachment/Exhibit "2".
6. Joint Petitioner, Patrick McKnight, after having the opportunity to have this
matter reviewed by independent counsel of his own choosing including the implications
of the transfer and any tax ramifications, expressly waived his right to independent
counsel. A Copy of Joint petitioner's waiver is attached hereto, incorporated herein and
marked Attachment/Exhibit "3".
7. Joint Petitioner, Patrick McKnight, proposes to enter into a purchase
agreement with J.G. Wentworth Originations, LLC., its nominees, successors, or assigns,
whose address is 201 King of Prussia Road, Radnor, PA 19087, who will purchase the
following from Petitioner's structured settlement as follows:
A) 1 payment of $74,093.00 on November 1, 2016.
8. The structured settlement is currently owned by Metropolitan Property &
Casualty Insurance Company and issued by Metropolitan Life Insurance Company, and
the net amount in return payable to Patrick McKnight is $46,000.00 from Buyer. A copy
of the Purchase Agreement, Exhibit "A' to the Purchase Agreement and Disclosure
Statement is attached hereto, made apart hereof, and designated Attachment/Exhibit "4".
9. The net amount payable to the payee after deduction of all commissions,
fees, costs, expenses, and charges is $46,000.00.
10. Based on the net amount that the payee will receive from this transaction
$46,000.00 and the amounts and timing of the structured settlement payments that
would be assigned, the payee is, in effect, paying interest at a rate of 10.80% per
year.
11. The Buyer furnished Patrick McKnight with a Disclosure Statement pursuant
to 40 P. S. 4003 (See Attachment/Exhibit "4") at least ten (10) days prior to the date on
which Patrick McKnight first incurred any obligation to the Buyer.
12. PA R.C.P. 229.2(b) requires the petition to be filed in the county in which the
payee is domiciled (See also Section 4 of the Act 40 P.S. §4004). PA.R.C.P. 229.2(c)
also requires both the Transferee and Payee to be parties to the Joint Petition. Both
requirements have been fulfilled herein.
13. Written notice of the Transferee's Names, address and taxpayer identification
number has been given to the Annuity Issuer and Structured Settlement Obligor. A copy
of the Notice to the structured settlement obligor is attached hereto as Attachment/Exhibit
"5". Joint Petitioners wills also serve written notice as required by 40 P.S. 4004 upon
all interested parties.
14. The Joint Petitioner's best interest would be served by granting the relief
requested herein for the following reasons. Joint Petitioner is single and has two (2)
minor children. Joint Petitioner is employed full time. The purpose of this transfer is to
assist Petitioner with purchasing land and paying off taxes, all of which will be expanded
upon at the time of trial. Petitioner has thought about this decision thoroughly and
believes that it is in his best interest and that of his family at this time. Based upon the
foregoing which shall be expanded upon at the time of trial, the transfer is clearly within
the best interest of Petitioner and his minor children.
WHEREFORE, Joint Petitioner's respectfully requests this Honorable Court to
enter the Initial Order attached to this petition which shall schedule a hearing so that
Transferee and Payee shall have the opportunity to discuss the purpose and reasons for
the transfer and after hearing thereon, respectfully request that this Honorable Court enter
a Final Order approving the Transfer of Structured Settlement Payments Rights as is
mentioned herein.
By:
Attorney for Transferee
Maro & Maro, P.C.
VERIFICATION
I, Lori Borowski, Vice President of J.G. Wentworth Originations, LLC, have read
the foregoing Petition to Joint Petition to Transfer Structured Settlement Payment Rights
and hereby aver that the statements contained therein are true and correct to the best of
my knowledge, information and belief.
This Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to the unsworn falsification to authorities.
or orowski, Vice President
Date
CERTIFICATION OF ATTORNEY FOR TRANSFEREE
I, Robert A. Maro, Esquire, attorney for Transferee, J.G. Wentworth Originations,
LLC, hereby certify to the best of my knowledge, information and belief, formed after
reasonable inquiry, that the Transfer will comply with the requirements of the Act (40
P.S. § 4000 et seq.) and will not contravene any other applicable federal or state statute or
regulation or the order of any court or administrative authority.
I, Robert A. Maro, Esquire, attorney for Transferee, J.G. Wentworth Originations,
LLC, hereby verify that the facts and statements set forth herein are true and correct to
the best of my knowledge, information and belief. I understand that false statements
made herein are subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unworn falsification of authorities.
Date
Attorney for Transferee, J.G.
Wentworth Originations, LLC
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO:
Originations, LLC and Patrick McKnight :
CERTIFICATE OF SERVICE
I, Robert A. Maro, Esquire, hereby certify that a true and correct copy of the
Petition for Transfer of Partial Structured Settlement has been served upon the following
entities via first class mail and/or certified return receipt requested and/or email on :
To: Metropolitan Life Insurance Company
Attn: Structured Settlements
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
J.G. Wentworth Originations, LLC
201 King of Prussia Road
Radnor, PA 19087
Metropolitan Property & Casualty
Insurance Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Patrick McKnight
100 B Street
Plainfield, PA 17601-4343
Amber Webster
100 B Street
Plainfield, PA 17601-4343
Date: Z
By:
Attorney for J.G. Wentworth Originations,
LLC
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of JG Wentworth NO:
Originations, LLC and Patrick McKnight :
Entry of Appearance
TO THE PROTHONOTARY/CLERK OF SAID COURT
Enter my appearance on behalf of: JG Wentworth Originations, LLC.
Papers may be served at the address set forth below.
Respectfully Submitted:
Maro & Maro, P.C.
By:
0Cttorney I.D. No 89585
Maro & Maro, P.C.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600(office)
(610) 275-9666(Fax)
ATTACHMENT/EXHIBIT "1"
Payee's Affidavit in Support of
Petition to Transfer Structured Settlement Rights
1, Patrick McKnight, the payee, verify that the statements below are true and correct:
Payee's name, address and age: Patrick Mcknight, 100 B Street, Plainfield, PA,
17083, 29yrs old.
1. Marital Status:
X Never Married; Married; .-Separated; Divorced
If married or separated, name of spouse: N/A
2 Minor Children and other dependents:
Wesley McKnight age 3 Grant McKnight age 3 Laurel McKnight age 2, all
reside at 100 B Street, Plainfield, PA, 17083
3. Income:
Payee's monthly income and sources: I am working as a IT Manager at
Diverse Technology Corporation earning $72,000.00 annually.
4. Child support, alimony or alimony pendente lite:
Obligation to pay: _X__ Ycs No
If yes, state the amount of the obligation, to whom payable, and whether there are
arrearages: $1,270.00 a month to Amber Webster.
5. Previous transfers: Complete the below for competition deals only. If prior
transfers were with JGW then just type See Exhibit "A".
SEE EXHIBIT A
Have you previously filed a petition to transfer payment rights under the
structured settlement that is the subject of this petition? X_ Yes ___No
If yes, for each petition that you filed,
(a) If the transfer was submitted for court approval, list the
court, the case caption and case number, and state whether the
court approved or disapproved the transfer: If the transfer was
approved.
(b) State the name of the transferee and identify (listing due
dates and payment amount(s)) the payments involved in the
transfer:
State the amount of money and the manner in which the money
was used:
(c) I Tave you ever transferred payments without court
approval? If so, please explain: No
6. Reasons for transfer:
Describe in detail your reasons for the proposed transfer, including an
explanation as to why a sale of a lesser amount of the structured settlement
amount will better serve your interests: I want to use the money from this transfer
to purchase land, and pay off the taxes.
7. Payment of debts:
If you seek the transfer in order to pay debts, list each debt, including the name of
the creditor and the amount presently owed:
Debt Creditor Amount Owed
N/A
Verification
I verify that the statements made in this affidavit are true and correct. 1 understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating
to unsworn falsification to authorities.
DATED: .? ?
Vr ' / X?i
x '
Patrick McKnight
PRIOR APPROVALS
Payments Purchased Court Order, Pre-
Act or Wrap 11 $33,215.00 Court Order
DENIALS
Denial Date Payments Purchased
n/a
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t" 14 [lit',. 1. 11 V1 ,.A ,O F NO. 0/99
PQ Box 7780-4244
Philadelphia, PA 19182
7. The Transferee shall be liable to the structured settlement Obligor,
Metropolitan Property & Casualty Insurance Company, and the Annuity Issuer,
Metropolitan Life Insurance Company:
a. If the transfer contravenes the terms of the structured settlement, for my
taxes incurred by the Structured Settlement Obligor or the Annuity Issuer as a
consequence of the transfer; and
b. For any liabilities or cost, including reasonable costs and attorney's
fees, arising from compliance by such parties with this order of the Court or
arising as a consequence of the Transferee's Failure to comply with the Act.
The structured Settlement Obligor and Annuity Issuer shall irrevocably change
the beneficiary for the Transferred payments to the Transferee, and no other
individual or entity other than the Transferee shall have the authority tp.?
beneficiary for the Transferred payments,
k
YME COPY
ATTACHMENT/EXHIBIT 6`29'
.?Z,
Meftife
Mn Patrick McKn ght
100 B Strtet
Plainfield, I'A 1701
RE: Annuitant: Patrick McKnight
Annuitant #: 74755R.IN
Owner: Metroppl tan Properrty & Casualty Company
Dear Mr. McKnight
Per your request, enclose, please find a copy of the above-mentioned certificate Living detail of
payments that you are entitled to as payee. The schedule of payment is listed on page (3) of the
Certificate.
Please keep this cerdflcam in a sgFe place forfurure reference.
Metropolitan Property & Casualty Company owns this-structured settlement referenced above.
All rights incidont of ownership of this annuity reside with the- owner of the annuity.,
Please be. advised that in-order to obtain a copy of the original settlement agreement you would
need to contact the Attorney who settled the case or the court where the case was settled.
THIS IS A STRUCTURED SETTLEMENT ANNUITY AND CANNOT HE ASSIGNED OR
USED AS COLLATERAL ON A LOAN. PAYMENTS CANNOT BE ACCELERATED,
DEFERRED, INCREASED OR DECREASED. THIS IS A TAX-FREE BENEFIT WITH NO
CASH PROVISION OR SUl2HENi IR VALUE ALLOWED.
Should you have any further questions, please contact our Customer Service Center at 1-800-638-
2704. Consultants are available Monday through Friday during the hours of 8-.00AM till 11:OOPM
Eastern Standard Time.
Sincerely,
An ' Plac df e
Senior Structured Settlement Consultant
Registered Representative
/lac
Atnuary 31, 2008
DCN#t OSG1160OOa!5s
Metropolitan Safe InsuraneeCompany.(MLIC), N'®w York; NY 10166, Securities Offered by
MetLife Sucurities, Inc. (MSI) (FINRA'SIPC)' MLIGand-MSI are affiliates.- .
VOjr.0 319tid -UNI SNOTSN?dTQ Zb6L%ZLTL Z5:CT 8002; TTlZO
9 0
Payment of Annuity: MetUfe Wit make payments under this certificate as follows:
MetLife will make the payments shown below to the payee named by the Owner.
However, if the Measuring Life is not living on the date any such payment is payable,
and unless the Owner directs otherwise, MetLife will pay such payment to the
Beneficiary.
Date of Payment
November 1, 2006
November 1, 2011
November 1, 2016
Amount of
Payment
525,000.00
$50,000.00
$74,093.00
C?Op?7
FOrm G.4324A
(3)
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ATTACHMENT/EXHIBIT 663"
Please complete and sign. AccountIU: 356823
STATEMENT OF PROFESSIONAL REPRESENTATION
Please Choose Either Box A OR Box B Below.
After you have made your choice, y, "? N) Q. 1M the appropriate box signature line.
YOU SHOULD SIGN OIN L Y ) E BO THE BOX YOU HAVE CHOSEN.
s A. I HAVE BEEN ADVISED BY J.G. WENTWORTH ORIGINATIONS, LLC
1 ("JGW") THAT I SHOULD OBTAIN INDEPENDENT PROFESSIONAL.
1 REPRESENTATION CONCERNING THE LEGAL, TAX AND/OR FINANCIAL
IMPLICATIONS OF THIS TRANSACTION. I FULLY UNDERSTAND THE PURCHASE
AGREEMENT AND THE IMPLICATIONS OF THE TRANSFER, INCLUDING THE TAX
RAMIFICATIONS OF THE, TRANSFER AND I DO NOT WISH TO SEEK OUT SUCH
INDEPENDENI?PROFESSIONAL REPRESENTATION.
X X
PA' ICK WILLIAM MCKNIGHT -? Date
...........
B. I HAVE OBTAINED INDEPENDENT REPRESENTATION AND I FULLY UNDERSTAND
THE LEGAL, TAX AND/OR FINANCIAL IMPLICATIONS OF THE TRANSACTION,
THE PURCHASE AGREEMENT AND THE RELATED DOCUMENTS. I WAS NOT
REFERRED TO MY PROFESSIONAL ADVISOR BY JGW. THE NAME OF MY
PROFESSIONAL ADVISOR IS SET FORTH BELOW:
PATRICK WILLIAM MCKNIGHT Date
To Be Cornpleted By Certified Professional Advisor
Only if you have signed Box 8 Above
Name of Professional:
Phone Number:
Address:
Attorney ID #
I have personally met with and provided independent professional advice to in respect of the Purchase Contract with JGW
and the transaction contemplated thereby. Patrick William Mcknight was referred to me by the
Prof'essional's Signature
Date
aat..%- ontractl i
"I'll ; .? W,
nh+.?ath (lrrm..Uuns. LL("
ATTACHMENT/EXHIBIT "4"
Account 11): 356823
PURCHASE, CONTRACT
This is a Purchase Contract ("Contract") for the sale of structured settlement payments between
Patrick William Mcknight (You, Your), with legal residence at
100 B Street, Plainfield, PA 17081
and
J.G. Wentworth Originations, LLC (We. Us, Our)
3993 Howard Hughes Parkway, Suite 250, Las Vegas, NV 89169-6754.
BACKGROUND
A. In connection with the resolution of a personal injury claim, You or someone acting for You, signed a
Settlement Agreement that entitles You to receive certain future payments ("Settlement Payments"),
according to a set schedule.
B. Thosc Settlement Payments are being paid to You from ail annuity policy ("Annuity Policy') purchased by the Person
responsible for making the Settlement Payments to You ("Obligor").
C. Rather than wait for the Settlement Payments to be made to You in the future, You want to sell all or some of those
Settlement Payments ("Purchased Payments") to Us now for a lump sum.
D. THIS CONTRACT CONTAINS AN ARBITRATION PROVISION WHICH YOU SHOULD READ
CAREFULLY, AS IT WILL HAVE A SUBSTANTIAL IMPACT ON HOW DISPUTES BETWEEN YOU AND
US ARE RESOLVED.
DEFINED WORDS
Certain words used in this Contract have specific meanings, shown below.
Annuity Policy The policy purchased by the Obligor to ensure that the Settlement Payments are made to You as
required by the Settlement Agreement:.
Closing Documents Any documents necessary to carry out the purchase of the Purchased Payments, other
than the "Contract or Contract Documents" as defined below.
Contract or Contract
Documents Collectively, only this Contract and the Disclosure Statement.
Contract Date The date Your signature at the end of this Contract is notarized. However, if You happen
to sign this Contract before the number of days stated at the end of Your Disclosure
Statement for waiting has passed, You will have no obligation under Your Contract until
that time has passed.
Court Order A legally binding ruling issued by a judge or properly empowered administrative officer,
approving the sale of the Purchased Payments to Us ("Court Approval").
Disclosure Statement The document which identifies for You, the Purchased Payments, expenses, Purchase Price
and various other disclosures.
Encumbrance Any claim, right, lien, policy loan, or restriction. In addition, this includes any
limits on rights of ownership (such as the use, voting, transfer, receipt of income, etc.).
Funding Date The date We pay You the Net Purchase Price.
08/ `' 1 2011 J.G VJCnhNorth Oneinutions. 1 1.('
Account ID. 356823
Issuer The insurance company that issued the Annuity Policy.
Obligor The Person who is obligated to make payments to You under the Settlement Agreement.
Party One of You or Us, Parties means both You and Us.
Person Any natural person or legal entity.
Purchased Payments Only those certain payments that We are purchasing From You under this Contract.
Purchase Price:
Gross Purchase Price The amount shown as the "gross amount payable to the seller (You)" on the Disclosure
Statement. This is the sum We have agreed to pay You before any deductions as set
forth in the Contract Documents.
Net Purchase Price The amount shown as the "net amount payable to the seller (You)" on the Disclosure
Statement. This is the SUM We have agreed to pay You ufier any deductions as set. forth
in the Contract Documents.
Settlement Agreement The agreement that You and the Obligor signed to resolve Your personal injury claim.
Settlement Payments All of the payments that the Obligor has agreed to make to You in the Settlement
Agreement.
We, Our, or Us J,G. Wentworth Originations, LL,C, along with any of its successors, assigns,
and designees. Some of the Contract Documents or Closing Documents may refer to Its
as the purchaser.
You or Your The Person named on this Contract's first page. Some of the Contract Documents or
Closing Documents may refer to You as the seller.
You and We agree as follows:
1. SALE OF THE PURCHASED PAYMENTS
A. Upon the signing of this Contract and subject to certain conditions including Court Approval, You sell, transfer
and assign to Us the right to receive the Purchased Payments specifically identified in the Disclosure Statement.
B. We will pay You the Net Purchase Price as agreed to in the Contract Documents, subject to certain conditions,
including meeting Our underwriting requirements, Court Approval and satisfactory completion of the Closing
Documents. We will do this in exchange for You:
• selling the Purchased Payments to Us;
• changing the beneficiary of the Annuity Policy to Your estate and not changing it again until We have
been paid all of the Purchased Payments;
• having any current beneficiaries waive their rights to the Purchased Payments; and
• fulfilling Your promises under this Contract.
C. If We are buying only a portion of Your payments, this will have no effect upon Your rights in the unsold portion.
You will continue to receive the unsold portion unless You have already sold or encumbered that portion.
However, sometimes the Issuer, the Obligor or the court may require Us to receive the entire amount of Your
payment. If so, We will then forward the portion of the payment still due to You and You hereby agree to this
payment servicing arrangement.
Pn ac 2
0811 1 S; I t
2011 J.U. t?'cnt',{,;rh(hie:nvlions.11C
Account ID: 356823
2. PURCHASE PRICE
A. The Gross and Net Purchase Prices are shown on the Disclosure Statement and are fail- and acceptable to You and Us.
B. We will pay You the Net Purchase Price in the manner You designate for Us.
C. Before we pay You, You agree that We will adjust for the following amounts, if applicable:
• Purchased Payments Owed to Us - The Issuer may have already paid You some of the Purchased
Payments before We have paid You for them. If that happens, We will deduct the amount of those
Purchased Payments.
• Holdbacks - Due to possible delays in the Issuer beginning to make the Purchased Payments to Us
instead of You, We will hold back an amount equal to any Purchased Payments that the issuer owes Us
post Court Approval, that are due within 90 days of the Funding Date. If We subsequently receive those
particular Purchased Payments directly, We will return the amount of any related holdback to You.
• Payment of Debts Owed - If You owe any past due child support, bankruptcy payoffs or taxes, or have
any judgments or liens against You or Your assets, We may pay those amounts and deduct them from the
amount We pay You, and You hereby provide Us with specific authority to take such action. We will
provide You with notice or the amounts that We are going to pay, prior to actual payment.
D. If any Purchased Payments are mistakenly sent to You after We have paid You for them, You will immediately contact
Us. If We then determine that any deductions or holdbacks as set forth above arc not enough to reimburse Us, We will
advise You of the amount You owe Us. You agree to immediately send that amount to Us by bank or certified check.
3. YOUR REPRESENTATIONS AND WARRANTIES
You represent and warrant to Us the following:
A. You understand that THIS IS A SALE AND NOT A LOAN.
B. The Annuity Policy is in full fierce, You are the sole and undisputed recipient of the right to the Purchased Payments,
have the right to sell them free and clear of any Encumbrances and have not previously sold any of the Purchased
Payments to any other Person.
C. You understand that Court Approval is required for this purchase; and You agree to fully cooperate with Us to
obtain that approval.
D. You gave Us all requested information and signed all documents necessary to complete the purchase.
Every statement made by You in the Contract. Documents and Closing Documents is true and complete.
E. No law, divorce decree or other legal obstacle:
• requires You to keep the Purchased Payments for the benefit of a current or former spouse, dependent children,
or other person; or
legally prevents You from contracting with Us. selling the Purchased Payments or changing the Annuity
Policy's beneficiary.
Either:
• You have never tiled for bankruptcy, will not do so before the Funding Date and there are no lawsuits or efforts
by any of Your creditors to put You into bankruptcy or take any of the Purchased Payments; or
• If You filed for bankruptcy, the Purchased Payments were not subject to the claims of Your creditors. You will
give Us a copy of any of Your bankruptcy documents that We request including evidence of a final bankruptcy
payoff or case closing, if any.
Page 3
r;8!1SiII
2011 J G, Wentworth Oriainations_ L.L.(_'
Account ID: 356823
G. We can rely on Your representations, warranties, and promises in this contract. 'rhese representations, warranties, and
promises are for Our benefit and the benefit of any future owners of the Purchased Payments. You understand that Our
reliance on any intentional misrepresentation by You may result in Our enforcing Our rights against You in court.
If. You had enough time to consider the sale of the Purchased Payments, understand the terms of the Contract Documents
and Closing Documents (including the arbitration provision), are of legal contracting age and sound mind, not under the
influence of drugs or alcohol, and freely and voluntarily, enter into this Contract and agree to all of its terms.
1. You were advised by Us to obtain independent legal advice and professional tax advice about the sale of the Purchased
Payments and to have those advisors review the terms and legal, tax and other effects of this Contract with You prior to
Your execution of this Contract. You have also explored all appropriate financial options before
entering into this transaction.
1. We did not provide tax, financial, or legal advice to You about this Contract and have advised You that We may not refer
You to any specific attorney for such purpose.
K. If You are married, Your spouse understands all of the terms and conditions of this Contract including, but not limited to
the fact that, after the Funding Date, You (and Your spouse) will not receive the same amount of money on the same
payment schedule as You would have received under the Annuity Policy. Your spouse has been provided with
all information relating to the transaction and has had every opportunity to review the terms of the transaction and to
seek any advice relating thereto. Your Spouse also understands that he or she will be giving up any property or contract
rights that he or she may have in the Purchased Payments.
L. We may sell, transfer, or assign Our right to the Purchased Payments in a sale, securitization, or other financing
transaction (resale). Any resale would involve disclosing certain information about You (including Your personal
information) to the parties to a resale.
M. Any future owner of the right to the Purchased Payments will have all of the same rights We have, including the right to
the duties You owe Us under this Contract. This includes the right to make a claim against You for violating any of the
representations, warranties, or promises You made in this Contract.
4. YOUR PROMISES TO US
Before and after the Funding Date:
A. You will tell us right away if Your address or telephone number changes and do
everything necessary, including completing and signing all documents to:
• sell the right to the Purchased Payments to us;
• change the beneficiary as required by this Contract; and
• correct any documentation errurs in the Contract Documents or Closing Documents.
B. You will also tell Us if any of the following occurs:
• a violation of this Contract; or
• anything that could negatively affect the Annuity Policy, the Purchased Payments, or this Contract.
C. You will not:
• agree to sell the Purchased Payments to any Person other than Us;
• change the Annuity Policy's beneficiary to any Person other than Your estate until We have collected all of the
Purchased Payments; or
• withdraw cash from, borrow against, or change the Annuity Policy.
t-?08h1?II ?!*1 ..t; ?7'i?rLvr.r,hlrn i 1.1('
Account 11):356823
D. You will give I is information necessary to update Your representations, warranties, and promises in this Contract. You
will also update any documents and information so they will be true and complete on the Funding Date.
E. We are now, and will continue in the future, to rely on the representations and warranties You have given Us. We will
confirm the accuracy of Your representations and warranties. You must cooperate with this confirmation and provide
complete access to any information We believe necessary.
F. You agree that updating representations, warranties, promises, documents and other information will not cure a breach
of any representation or warranty made by You that was not true and complete.
G. You agree that Our obligation to You under this Contract is strictly limited to the requirement to pay You what We owe
You under the terms of this Contract, after receipt and approval of the Closing Documents, final underwriting approval
and Court Approval. Under no circumstances will We be liable for any consequential damages.
H. You hereby appoint Us and any of Our designees, with full power of substitution as your Attorney in Fact, to act in
Your name and place for the purpose of assigning and transferring ownership of any and all right, title and interest that
You have in the Purchased Payments and for Us to obtain all benefits contemplated by this transaction. You also give
Us full authority to act in any way proper and necessary to exercise this Attorney in Fact appointment including, but not
limited to: (1) negotiating, endorsing and executing checks, drafts and other instruments in Your name; and
(2) instituting, maintaining, compromising, settling and terminating any litigation or other proceedings related to the
Purchased Payments. This power of attorney is coupled with an interest and shall survive death or disability.
5. CANCELLATION BY US
We may cancel this Contract before the Funding Date W
A. You breach any representation, warranty, or promise in any Contract Documents or Closing Documents.
B. The petition for the Court Order is contested, opposed, or not approved.
C. We are sued or threatened with a lawsuit or an arbitration about this Contract or the Annuity Policy.
D. 'there is any threatened, pending, or final action, or change in law or rule challenging the legality or, or negatively
affecting this transaction.
E, You file for, or are forced into bankruptcy.
F. You die.
G. Final approval has not been given by Our underwriting department.
H. The Purchase Contract is not signed by You and received back by Us by April 24, 2012.
1. A major rating agency downgrades the issuer's credit rating.
J. The Issuer is, or becomes insolvent, or under regulatory supervision.
K. With respect to A through J above, to the extent permitted by applicable law, the arbitration provision in Section 9 of
this Contract shall survive the termination, cancellation or rescission of this Contract.
6. CANCELLATION BY YOU
A. (1) YOU MAY CANCEL THIS CONTRACT WITHOUT PENALTY OR FURTHER OBIAGATION AT ANY
TIME WITHIN FIVE (5) BUSINESS DAYS AFTER THE DATE YOU RECEIVE PAYMENT
HEREUNDER FROM US. IN ORDER FOR THE CANCELLATION TO BE EFFECTIVE, YOU MUST
SEND A NOTICE POSTMARKED AT ANY TIME WITHIN FIVE BUSINESS DAYS AFTER YOU
RECEIVE PAYMENT HEREUNDER FROM US (This is the rescission period).
I>ag.?: s
Si 151! 7 2011 J G Wt nheorth orieinations. LLC'
Account ID: 356823
(2) YOUR NOTICE IS TO BE SENT EITHER BY CERTIFIED OR REGISTERED MAIL (RETURN
RECEIPT REQUESTED) OR FEDEX OR ANOTHER MAJOR OVERNIGHT DELIVERY SERVICE. THE
NOTICE. MUST INCLUDE A BANK OR CERTIFIED CHECK MADE PAYABLE TO US, IN THE FULL
AMOUNT RECEIVED BY YOU. YOUR NOTICE MUST BE SENT TO:
J.G. Wentworth Originations, LLC
Attention: Manager of Operations
3993 Howard Hughes Parkway, Suite 250
Las Vegas, NV 89169-6754
B. GEORGIA RESIDENTS: YOU MAY CANCEL THIS TRANSACTION AT ANY TIME PRIOR TO 5:00 P.M.
OF THE TWENTY-FIRST DAY FOLLOWING RECEIPT OF THE ENCLOSED "NOTICE OF
CANCELLATION RIGHTS" FORM, OR AT THE HEARING ON THE APPLICATION FOR
AUTHORIZATION OF A TRANSFER OF STRUCTURED SETTLEMENT PAYMENT RIGHTS, OR AT ANY
TIME WITHIN FIVE (5) BUSINESS DAYS AFTER YOU RECEIVE PAYMENT HEREUNDER FROM US,
WHICHEVER EVENT OCCURS LAST (This is the Georgia rescission period). IN ORDER FOR THE
CANCELLATION TO BE EFFECTIVE, YOU MUST SIGN THE ENCLOSED "NOTICE OF
CANCELLATION RIGHTS" FORM AND MAIL OR DELIVER IT TO US AS SPECIFIED IN THAT
NOTICE AND YOU MUST RETURN ALL AMOUNTS (PURCHASE PRICE OR OTHERWISE) RECEIVED
BY YOU ACCORDING TO THE REQUIREMENTS OF 6 (A) (2) ABOVE..
C. WEST VIRGINIA RESIDENTS: IN ORDER FOR YOUR CANCELLATION TO BE EFFECTIVE, YOUR
NOTICE CAN BE SUBMITTED VIA PHONE, MAIL, OR FACSIMILE. ANY AMOUNTS ADVANCED BY
US IN CONTEMPLATION OF THE TRANSFER SHALL BE IMMEDIA'T'ELY REFUNDED TO US. IF YOU
DISMISS YOUR ACTION AFTER APPOINTMENT OF A GUARDIAN AD LITEM, OR RESCIND YOUR
TRANSFER AGREEMENT (PURCHASE CONTRACT) WITHIN THE RESCISSION PERIOD IN
6(A) (1) ABOVE, YOU SHALL BE RESPONSIBLE FOR THE FILING FEE AND ANY GUARDIAN AD
LITEM FEES.
D. With respect to A through C above, to the extent permitted by applicable law, the arbitration provision in Section
9 of this Contract shall survive the termination, cancellation or rescission of this Contract.
7. NOTICES
A. All notices about this Contract must be in writing.
B. All notices must be sent either by: (1) certified or registered mail (return receipt requested): or (2) FedEx or another major
overnight delivery service with a delivery tracking system and are considered given when delivered as follows: If to You:
to the most recent address for You listed in Our files. If to Us: to the address listed in Section 6(A) (2) of this Contract.
8. EVENTS OF DEFAULT
You will be in default if You:
A. fail to comply with any terms or conditions of this Contract; or
B. breach any of Your representations, warranties and promises in this Contract.
If You are in default, even if You have not rejected the arbitration provision (see Section 9 of this Contract), We have the right to
enforce Our rights against You in court to make You perform Your promises or to get money from You. If We sue You in court
in connection with a Claim that is subject to arbitration under the arbitration provision in Section 9 of this Contract, and You have
not reiected the arbitration provision, You will have the option of remaining in court or seeking to compel arbitration of that
Claim under the terms of the arbitration provision.
08/i s/11
Page 6
2011 .10 Wentworth Originations. LL.C
Ammnt ID 356823
9. ARBITRATION PROVISION
To the extent permitted by applicable law, You and We agree to the following arbitration provision
YOU HAVE THE RIGHT TO REJECT THIS ARBITRATION PROVISION AS SET FORTH BELOW. If You do not reject
this arbitration provision and a Claim is arbitrated, You will not have the right to: (1) have a court or a jury decide the Claim;
(2) engage in information gathering (discovery) to the same extent as in court; (3) participate in a class action in court or in
arbitration; or (4) join or consolidate a Claim with claims of any other person. The right to appeal is more limited in
arbitration than in court and other rights in court may be unavailable or limited in arbitration.
Claims Subject to Arbitration. A "Claim" subject to arbitration is any claim, dispute or controversy between You and Us (other than
an Excluded Claim or Proceeding as set forth below), whether preexisting, present or future, which arises out of, or relates to the
Contract, the negotiations related thereto, the breach thereof or any other transaction conducted with us in connection with the
Contract. "Claim" has the broadest possible meaning and includes initial claims, counterclaims, cross-claims, third-party claims and
federal, state, local and administrative claims. It includes disputes based upon contract, tort, consumer rights, fraud and other
intentional torts, constitution, statute, regulation, ordinance, common law and equity and includes claims for money damages and
injunctive or declaratory relief. Upon the demand of You or Us, Claim(s) will be resolved by individual (not class or class-wide)
binding arbitration in accordance with the terms specified in this arbitration provision.
Special Definitions. Solely for purposes of this arbitration provision, in addition to the meanings set forth in this Contract: (1) "We,"
"Us" and "Our" also (a) refer to Our employees, officers, directors. parents, controlling persons, subsidiaries and affiliates and (b)
apply to third parties if You assert a Claim against such third parties in connection with a Claim you assert against Us; and (2) "You"
or "Your" also refer to Your current or former spouse(s), children, heirs, estate, executors, successors, assigns, representatives and
beneficiaries.
Excluded Claim or Proceeding. Notwithstanding the foregoing, "Claim" does not include any dispute or controversy about the
validity, enforceability, coverage or scope of this arbitration provision or any part thereof (including, without limitation, the "Class
Action Waiver" set forth below and/or this sentence); all such disputes or controversies are for a court and not an arbitrator to decide.
I lowever, any dispute or controversy that concerns the validity or enforceability of the Contract as a whole is for the arbitrator, not a
court, to decide. In addition, We will not require You to arbitrate any individual action brought by You in small claims court or Your
state's equivalent court, unless such action is transferred, removed, or appealed to a different court.
Federal Arbitration Act. Notwithstanding any other provision in this Contract, You and We agree that this Contract evidences a
transaction involving interstate commerce and that the Federal Arbitration Act (Title 9 of the United States Code) ("FAA") shall
govern its interpretation and enforcement and proceedings pursuant thereto. To the extent state law is applicable under the FAA, the
law of the state of Your domicile (where You regularly reside on the Contract Date) shall apply.
Class Action Waiver. Notwithstanding any other provision of this Contract, if a Claim is arbitrated, neither You nor We will
have the right: (a) to participate in a class action, private attorney general action or other representative action in court or in
arbitration, either as a class representative or class member; or (b) to join or consolidate Claims with claims of any other
Persons. No arbitrator shall have authority to conduct any arbitration in violation of this provision (provided, however, that
the Class Action Waiver does not apply to any lawsuit or administrative proceeding filed against us by a state or federal
government agency even when such agency is seeking relief on behalf of a class of borrowers including You. This means that
We will not have the right to compel arbitration of any claim brought by such an agency). The Class Action Waiver is
nonseverable from this arbitration provision. If the Class Action Waiver is limited, voided or found unenforceable, then this
arbitration provision (except for this sentence) shall be null and void with respect to such proceeding, subject to the right to
appeal the limitation or invalidation of the Class Action Waiver.
Arbitration Procedures. If You or We seek to arbitrate a Claim, the Party seeking arbitration must notify the other Party in writing.
This notice can be given after the beginning of a lawsuit and can be given in papers filed in the lawsuit, such as a motion to compel
arbitration. Otherwise, Your notice must be sent to Us at the address specified in Section 6 (A) (2) of this Contract and Our notice
must be sent to the most recent address for You in our files. Any arbitration hearing that You attend will take place in a venue
reasonably convenient to where You reside. If a Party files a lawsuit in court asserting Claim(s) that are subject to arbitration, and the
other Party files a motion to compel arbitration with the court, which is granted, it will be the responsibility of the Party prosecuting
the Claim(s) to select an arbitration administrator in accordance with the paragraph below and commence the arbitration proceeding in
accordance with the administrator's rules and procedures.
11 i ;
08;15/11 20111(i
Went'a rlh t?rigintthc cs. l.1.<_:
Account 117: 356823
The arbitration will be administered by the American Arbitration Association ("AAA"), 1633 Broadway, 10"' Floor, New York, NY
10019, www.adr.org, 1-800-778-7879 or JAMS, 1920 Main Street, Suite 300, Irvine, CA 92614, www.jarnsadr.co?n. 1-800-352-5267.
The rules and forms of the AAA and JAMS may be obtained by writing to these organizations at the addresses listed above. If the
AAA and JAMS are unable or unwilling to serve as administrator, the Parties may agree upon another administrator or, if they are
unable to agree, a court shall determine the administrator, No company may serve as administrator, without the consent of all Parties,
if it adopts or has in place any formal or informal policy that is inconsistent with and purports to override the terms of this arbitration
provision. In the event of a conflict between the provisions of this arbitration provision, on the one hand, and other provisions of this
Contract or any applicable rules of the AAA or JAMS or other administrator used, on the other hand, the provisions of this arbitration
provision shall control.
A single arbitrator will be appointed by the administrator and must be a practicing attorney with ten or more years of experience or a
retired judge. The arbitrator will not be bound by judicial rules of procedure and evidence that would apply in a court, or by state or
local laws that relate to arbitration proceedings. The arbitrator will honor statutes of limitation and claims of privilege recognized
under applicable law. In determining liability or awarding damages or other relief, the arbitrator will follow this Contract and the
applicable substantive law, consistent with the FAA and this Contract, that would apply if the matter had been brought in court. At
Your written request, we will pay all filing, hearing and/or other fees charged by the administrator and arbitrator to You for Claim(s)
asserted by You in arbitration after You have paid an amount equivalent to the fee, if any, for filing such Claim(s) in state or federal
court (whichever is less) in the judicial district in which You reside. (If You have already paid a filing fee for asserting the Claim(s) in
court, You will not be required to pay that amount again). In addition, the administrator may have a procedure whereby You can seek
a waiver of fees charged to You by the administrator and arbitrator. We will always pay any fees or expenses that We are required to
pay by law or the administrator's rules or that We are required to pay for this arbitration provision to be enforced. The arbitrator will
have the authority to award attorneys' and expert witness fees and costs to the extent permitted by this Contract, the administrator's
rules or applicable law. The arbitrator will always award You reasonable attorneys' and expert witness fees and costs (a) if and to the
extent You prevail on Claims you assert against Us in an arbitration commenced by You and (b) to the extent required under
applicable law for this arbitration provision to be enforced. The arbitrator shall write a brief explanation of the grounds for the
decision. A judgment on the award may be entered by any court having jurisdiction.
Severability and Survival. If any part of this arbitration provision, other than the Class Action Waiver, is deemed or found to be
unenforceable for any reason, the remainder shall be enforceable. To the extent permitted by applicable law, this arbitration provision
shall survive the termination, cancellation or rescission of this Contract.
Effect of Arbitration Award. The arbitrator's award shall be final and binding on all Parties, except for any right of appeal provided
by the FAA. However, if the amount of the Claim exceeds $50,000 or involves a request for injunctive or declaratory relief that could
foreseeably involve a cost or benefit to either Party exceeding $50,000, any Party can, within 30 days after the entry of the award by
the arbitrator, appeal the award to a three-arbitrator panel administered by the administrator. The panel shall reconsider anew any
aspect of the initial award requested by the appealing Party. The decision of the panel shall be by majority vote. Reference in this
arbitration provision to "the arbitrator" shall mean the panel if an appeal of the arbitrator's decision has been taken. The costs of such
an appeal will be borne in accordance with the above paragraph titled "Arbitration Procedures." Any Final decision of the appeal
panel is subject to judicial review only as provided under the FAA.
Right to Reject Arbitration Provision. You may reject this arbitration provision by sending Us written notice of Your decision so
that We receive it at the address listed below within forty-five (45) days of the Contract Date. Such notice must be sent by certified or
registered mail (return receipt requested) or by Fed Ex or another major overnight delivery service with a delivery tracking system;
must include a statement that You wish to reject the arbitration provision along with Your name, address. Account I.D. number and
Your signature; and must. be delivered to Us at the address specified in Section 6 (A) (2) of this Contract. ']'his is the sole and only
method by which You can reject this arbitration provision. Upon receipt of a rejection notice, We will reimburse You for the standard
cost of a certified or registered letter or overnight delivery, Rejection of this arbitration provision will not affect any other terms of
this Contract and will not result in any adverse consequence to You. You agree that Our business records will be final and conclusive
with respect to whether You rejected this arbitration provision in a timely and proper fashion. This arbitration provision will apply
to You and Us unless you reject it by providing proper and timely notice as stated herein.
OXIl ti; I 1 , 2011 .1 G. Wentworth Originations. i i c:'
Account ID: 356823
10. MISCELLANEOUS
A. You give Us permission to conduct background checks on You, including obtaining information from the credit bureaus,
in order to verify Your legal residence, contact information, and any other information We deem necessary for this
transaction. We can also search records for UCC filings, bankruptcy filings, judgments, liens and child support
obligations against You.
B. "This Contract is the entire agreement between You and Us.
C. If there is more than one of Us or You, this Contract applies to all of those people together, and to each of thern on their
own.
D. Both Parties must agree in writing to any change to this Contract or waiver of its teens.
E. Except as set forth in the arbitration provision in Section 9 of this Contract, if a court undoes any part of this Contract,
the rest of the Contract remains valid.
You cannot voluntarily or involuntarily sell, assign, or transfer this Contract, or any of Your rights or duties under this
Contract. Any such action taken by You in violation of this section shall be void and of no effect.
G. Except as otherwise required by applicable law, the law of the state of Your domicile (where You regularly reside on the
Contract Date) will govern this Contract.
H. 'This Contract also holds responsible Your heirs, and executors. 'This Contract benefits only You and Us, and no one else.
However, if properly assigned by Us, this Contract will bind and benefit Our successors and assigns.
Failure to enforce any provision of this Contract is not a waiver of that provision.
'The Parties may sign this Contract in one or more counterparts. Each counterpart will be considered an original. All
counterparts will form one Contract. A facsimile, pdf or other electronic copy of the signed Contract or any counterpart
will be considered an original and treated as such in any court [or arbitration] proceeding.
K. We have investigated the proposed transfer of the Purchased Payments and, in light of information available to Us, have
identified no violation of any applicable state or tederal law.
L. You will not receive an IRS Forn 1099 from I.s.
M. 'ritles and headings in this Contract are for convenience only. Do not use them to interpret this Contract.
N. Except as otherwise set forth in this Contract (including the arbitration provision in Section 9 of this Contract), You and
We will pay our respective costs and expenses in carrying out this Contract.
You and We, intending to be legally bound, have signed this Contract as of the Contract Date below, and agree to all of its
terms and conditions, including the arbitration provision.
(K/i /lI
Paac 9
2011 .10. WciA%+orlh Orie.inatUt)n. LLC
ACCOUntID: 356823
By signing below, You also acknowledge that You were advised by Us in writing, that You should obtain independent legal
advice and professional tax advice about the sale of the Purchased Payments and to have those advisors review with You, the
terms and legal, tax and other effects of this Contract.
Sworn to and subscribed SELLER:
before me thib a day oft`?t;t , 20)'2- ("Contract
Date") SIGN HERE
... r >
tiotarv' Patrick William Mcknight
COMMONWEALTH qF PENNSYLVANIA
Notarial Seal
Hope L. Culley, Notary Public
Acknowledged and Agreed: Upper Allen 'rwp., Cumberland County
My Commission Expires Feb. 28, 2013 _
y?lnh?f 1'an?;";v;,,v-. Ar. cf?;!al lhP n?fH `.ii11'fN...
Sworn to and subscribed SELLER'S SPOUSE. (if applicable)
before me this _ . „ day of , 20
Notary
Spouse
US: J.G. Wentworth Originations, LLC
BY: _
Sam Gottesman, Underwriting Manager
t(I! i i : '•E'IS 1 1;" ii; Uri nl, u;mr•. LI i'
Account ID: 356823
March 9, 2012
PENNSYLVANIA.
DISCLOSURE STATEMENT
We will purchase the following payments (Purchased Payments) from You:
A) 1 payment of $74,093.00 on November 1, 2016
(The remainder of the page intentionally left blank)
„ N)I 1 .10 Wcnnvorlh Originaiwns. L.I C.
Account[D: 356823
March 9, 2012
The aggregate amount of the Purchased Payments is $74,093.00.
The discounted present value of the aggregate Purchase Payments at the federal interest
rate of 1.40% is $69,455.42. The discounted present value is the calculation of the current
value of the transferred structured settlement payments (Purchased Payments) under
federal standards for valuing annuities.
The gross amount payable to seller (You) is $46,000.00.
The net amount payable to the seller (You) is $46,000.00.
Legal fees (this is an estimate of what Your attorney will charge You if
You choose not to waive representation): $500.00
No other expenses are incurred by You.
The net amount that You will receive from Us in exchange for Your future structured
settlement payments represents 66.20% of the estimated current value of the payments
based upon the discounted value using the applicable federal rate.
Based on the net amount that You will receive in payment from Us aiod the amounts and
timing of the structured settlement payments that You are selling to Us, this is the
equivalent of interest payments to Us at a rate of 10.80% per year. PLEASE NOTE
THAT THIS IS NOT A LOAN, BUT A SALE OF PAYMENT RIGHTS AND THE
INTEREST FIGURE IS ONLY PROVIDED AS AN ILLUSTRATION OF THE
ECONOMIC IMPACT OF THE SALE.
Please be advised there are no penalties or liquidated damages payable by you in the event
of any breach of the transfer agreement by you.
By signing below, You are confirming receipt of this Disclosure Statement at least 10 days
prior to You first incurring an obligation with respect to the transfer agreement
(Purchase Contract).
?` f..
fN ?
PATRICK WILLIAM Wv --- stcrr ttcRc
KNIGHT
-2-
"?.?
IMPORTANT NOTICE
You are strongly urged to consult with an attorney who can advise you of the potential tax
consequences of this transaction.
By:
PATRICK WILLIAM MCKNIGHT
Sworn to and subscribed
ore me this ` ) day )of 2O /`2-
4
Notary
'U_ MUN4VEgt:7!-i pf- pENNSY1.VANIA
11 1
Notfirial
al
Mope L. !. Cu
?DP p en Tw Y Notary Public.
p• Cumberland County
Y Con"ISS'on Expires Feb, 2013
?'1f.?n:;n?f.r?!171^d,?•:fa tr,'r?y?
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ATTACHMENT/EXHIBIT "5"
J.G.WF' T\y/ 0RTf,t,
April 2, 2012
Metropolitan Life Insurance Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Attn: Legal Department/Structured Settlements
Metropolitan Property & Casualty Insurance Company
MRMR 2025 Leestown Road
Suite J
Lexington, KY 40511
Attn: Legal Department/Structured Settlements
RE: Notice of Sale/Assignment of Payment Rights
Your Contract #: 74755RIN
Payee: Patrick Mcknight
SS #: 170-70-9053
Dear Insurer:
Please be advised that J.G. Wentworth Originations, LLC and/or its successors and assigns, have entered
into a transaction with the above-referenced annuitant who is seeking to transfer certain of his/her rights to
the payments scheduled to be received under the above-referenced annuity policy. We are currently seeking
court approval pursuant to the applicable structured settlement transfer statute. Pursuant to the statute,
please note the following information about the Purchaser:
J.G. Wentworth Originations, LLC
201 King of Prussia Road, Suite 200
Radnor, PA 19087
Tax ID # 20-4728885
PLEASE NOTE: No payments under this annuity should be held until the courts have entered a final order
and we have forwarded this order to you.
Very truly yours,
J.G. Wentworth Originations, LLC
By:
Lori Borowski, Vice President
201 KING OF PRUSSIA ROAD, SUITE 200 • RADNOR., PA i go87
PHONE: (800) 790-4016 • FAX: (215) 567-6096
A,.
• r
Resen ed for Court Use.
1 aTR 13 Pr`-? .
.sai?1-T ERi, i l
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of 321 Henderson NO:
Receivables Origination, LLC and
Patrick McKnight
INITI ORDER OF COURT
364-
On this ( day of 2012, it is ordered
that a hearing on this Petition to Transfer Structured Settlement Payment Rights will be --2 bO A PA
held on , 2012, in Court
room at I o'clock. _(? The payee shall bring income tax returns for the prior two (2) years to the hearing.
Within sever (7) days, the transferee shall give notice of the hearing date to the
payee, the structured settlement obligor, the annuity issuer, the payee's spouse and any
person receiving child support, alimony, or alimony pendente lite. The transferee shall
attach a certificate of service to the notice of hearing date. A copy of the notice with the
certificate of service shall be filed with the court prior to the hearing.
'? arc Moro, P.o
e'Py fKa-led 4/13//a
W L
l.--- BY THE COURT:
J. Thomas A. Placey
mmon Pleas Judge
r
N
Maro & Maro, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 W. Main Street
r 4.' 7 i tV.
12 23 P11 2:
r• I q
Norristown, PA 19401i'l L,
L? ??
(610) 275-9600 Attorney foFK?l3i?y??q? ations, LLC
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE: Joint Petition of J.G. Wentworth NO: 2012-2239
Originations, LLC and Patrick McKnight
CERTIFICATE OF SERVICE
I, Robert A. Maro, Esquire, hereby certify that a true and correct copy of the
Notice of Hearing was served upon the Payee, The Structured Settlement Obligor, The
Annuity Issuer, the Payee's Spouse and any person receiving child support, alimony or
alimony pendente lite.
A copy of the Notice is attached hereto.
Date: April 17, 2012
By C?
o ert A. Maro, Esquire
Attorney for J.W. Wentworth
Originations, LLC
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO: fa
Originations, LLC and Patrick McKnight : 9
NOTICE OF HEARING ON PETITION TO TRANSFER STRUCTURED
SETTLEMENT PAYMENT RIGHTS
To: Metropolitan Life Insurance Company
Attn: Structured Settlements
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
Metropolitan Property & Casualty
Insurance Company
MRMR
2025 Leestown Road, Suite J
Lexington, KY 40511
J.G. Wentworth Originations, LLC
201 King of Prussia Road
Radnor, PA 19087
w
;T
Patrick McKnight :
100 B Street
Plainfield, PA 17601-4343
Amber Webster (.n
100 B Street
Plainfield, PA 17601-4343
You are hereby given notice that J.G. Wentworth Originations, LLC has filed a petition
to transfer structured settlement payment rights. A hearing in this matter has been scheduled on
, 2012 at i W?lock in courtroom no. courthouse,
? 31 Cumberland County Court of Common Pleas, Pennsylvania.
You are entitled to support, oppose or otherwise respond to the payee's petition, either in
person or by counsel, by filing written comments with the court prior to the hearing or by
attending the hearing.
The Name, Address and Tax Identification number of the tran?s?fe a is .G. We or
Originations, LLC. 201 King of Prussia Road, Radnor, PA 19087, i°.D, 2085
y' S _/ Z BY:
Date
,)eftgfney for J. G. Wentworth
Originations, LLC.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600
(610) 275-9666(facsimile)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO: 12-2239 Civil
Originations, LLC and Patrick McKnight
ORDER OF COURT
2012,
AND NOW, this -4k day of -,J Wac
upon consideration of the attached motion for continuance by J.G. Wentworth
Originations, LLC:
The Motion is Granted and the Joint Petition for Partial Transfer of
Structured Settlement scheduled for May 31, 2012 is continued.
The Moving Party shall promptly notify all interested parties of this Order.
It is ORDERED that a hearing on this Petition to Transfer Structured Settlement
Payment Rights will be held on ? j o ?AAA•%j •? tX1 , 2012, in Courtroom
G
at ; D o'clock. The payee shall bring income tax returns for
the prior two (2) years to the hearing.
Within sever (7) days, the transferee shall give notice of the hearing date to the
payee, the structured settlement obligor, the annuity issuer, the payee's spouse and any
person receiving child support, alimony, or alimony pendente lite. The transferee shall
attach a certificate of service to the notice of hearing date. A copy of the notice with the
certificate of service shall be filed with the court prior to the hearing.
t'd (-11F "'
:7
BY T
J. Thomas A. Piacey
Common Pleas Judge
r%ro `*- on ar& P.e.
PIAn10 11AA'?,P/1 1Aiel" 0,.,/
{
Maro & Maro, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600
for J.(3
LLC
IN THE COURT OF COMMON PLEAS Off
PENNSYLVANIA
IN RE: Joint Petition of J.G. Wentworth
Originations, LLC and Patrick McKnight
COUNTY,
NO: 2012-2239
CERTIFICATE OF SERVICE
I, Robert A. Maro, Esquire, hereby certify that a true and correct copy of the
Order of Court was served upon the Payee, The Structured Settlement Obligor, The
Annuity Issuer, the Payee's Spouse and any person receiving child support, alimony or
alimony pendente lite.
A copy of the Notice is attached hereto.
Date: June 13, 2012 By
"
Robert A. Maro, Esquire
Attorney for J.W. Wentworth
Originations, LLC
4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO: 12-2239 Civil
Originations, LLC and Patrick McKnight
ORDER OF COURT
c
Fn
AND NOW, this , day of
upon consideration of the attached motion for continuance by J.G . Wentworth -? =}-
Originations, LLC: yr -?
,? rv
The Motion is Granted and the Joint Petition for Partial Transfer of
Structured Settlement scheduled for May 31, 2012 is continued.
The Moving Party shall promptly notify all interested parties of this Order.
It is ORDERED that a hearing on this Petition to Transfer Structured Settlement
Payment Rights will be held on `7?4,k 30 " , 2012, in Courtroom
,:5;,K at I *- 30 Pm o'clock. The payee shall bring income tax returns for
the prior two (2) years to the hearing.
Within sever (7) days, the transferee shall give notice of the hearing date to the
payee, the structured settlement obligor, the annuity issuer, the payee's spouse and any
person receiving child support, alimony, or alimony pendente lite. The transferee shall
attach a certificate of service to the notice of hearing date. A copy of the notice with the
certificate of service shall be filed with the court prior to the hearing.
BY THE COURT:
J. 7An,vj?5 C- e7
cor?1~,, pte as JZ(dg -e
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO: o
Originations, LLC and Patrick McKnight :
FIN L ORDER OF COURT
, t t?'
On this Day of v , 2012, it is ordered that
the Petition to Transfer of Structured Settlement Payment Rights is granted.
The court specifically finds that:
(1) the payee has established that the transfer is in the best interests of the payee
or the payee's dependents;
(2) based on the certification by an attorney for the transferee, and the court
having not been made aware of any statute, regulation or order that would be
incompatible with the proposed transfer, the transfer will not contravene any
applicable federal or state statue or regulation, or the order of any court or
administrative authority;
(3) the transfer complies with the remaining requirements of the Structured
Settlement Protection Act, including Sections 3(a)(2), 3(a)(4), 3(a)(5) and
3(a)(6);
(4) the payments that are to be transferred are designated as
follows:
A) 1 payment of $74,093.00 on November 1, 2016.
(5) the terms of this order shall survive the death of the payee and shall be
binding on the payee's heirs, beneficiaries and assigns;
I ,
(6) the payee shall receive from the transferee, within ten (10) days from the date
of this Order, the amount of $46,000.00, from which no funds are owed for
counsel fees, administrative fees, or other costs, fees or expenses.
B
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