HomeMy WebLinkAbout12-4180MARO & 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 Jeannie Snyder
NOTICE OF HEARING ON PETITION TO TRANSFER STRUCTURED
SETTLEMENT PAYMENT RIGHTS
To: The Travelers Insurance Company, n/k/a
MetLife Insurance Company of Connecticut
Attn. Legal Dept/structured Settlements
c/o MetLife - MRMR
2025 Leestown Road - Suite J
Lexington, KY 40511
The Travelers Life And Annuity Company,
n/k/a MetLife Life Insurance Company of CT
J.G. Wentworth Originations, LLC
201 King of Prussia Road
Radnor, PA 19089
Kenneth Martin
9190 Iron Bridge Road
Orrstown, PA 17244
Attn. Legal Depbstructured Settlements Jeannie Snyder
c/o MetLife - MRMR
2025 Leestown Road, Ste. J
Lexington, KY 40511
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, City Hall, Cumberland, 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 4traeV is J . We or
Originations, LLC. 201 King of Prussia Road Radnor PA 1908 2 8885.
7 / 1 BY:
Date
?Cro, Esquire
AMyCrj e .G. Wentworth
Originations, LLC.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600
(610) 275-9666(facsimile)
P
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
t ?-
T"o
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA I
RE: Joint Petition of J.G. Wentworth
No: ? a_ y1
Originations, LLC and Jeannie Snyder
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, Jeannie Snyder, 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 19089.
2. Joint Petitioner is, Jeannie Snyder ("Payee"), an adult individual who resides in
the County of Cumberland, 35 N. Hanover Street, Apartment 5, Carlisle, PA 17013-3014.
3. 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.
C$D-
S1-2
C ?7Slrq
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, Jeannie Snyder, is the beneficiary of an annuity
owned by The Travelers Life And Annuity Company, n/k/a MetLife Life Insurance
Company of CT and issued by The Travelers Insurance Company, n/k/a MetLife
Insurance Company of Connecticut. The structured settlement provides payment to the
petitioner as described on Attachment/Exhibit "2".
6. Joint Petitioner, Jeannie Snyder, after having the opportunity to have
independent counsel review the agreement; knowingly, intelligently and voluntarily
waived his right to independent counsel. A copy of the waiver report is attached hereto,
incorporated herein and marked Attachment/Exhibit "3".
7. Joint Petitioner, Jeannie Snyder, 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 $21,025.00 on January 18, 2017.
8. The structured settlement is currently owned by The Travelers Life And
Annuity Company, n/k/a MetLife Life Insurance Company of CT and issued by The
Travelers Insurance Company, n/k/a MetLife Insurance Company of Connecticut, and the
net amount in return payable to Jeannie Snyder is $8,000.00 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 $8,000.00.
10. Based on the net amount that the payee will receive from this transaction
$8,000.00 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 23.25% per
year.
11. The Buyer furnished Jeannie Snyder 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 Jeannie Snyder first incurred any obligation to the Buyer.
12. PA R.C.P. 229.2(b) requires the petition to be filed in the county in which the
payee is domiciled (See also Section 4 of the Act 40 P.S. §4004). PA.R.C.P. 229.2(c)
also requires both the Transferee and Payee to be parties to the Joint Petition. Both
requirements have been fulfilled herein.
13. Written notice of the Transferee's Names, address and taxpayer identification
number has been given to the Annuity Issuer and Structured Settlement Obligor. A copy
of the Notice to the structured settlement obligor is attached hereto as Attachment/Exhibit
"5". Joint Petitioners wills also serve written notice as required by 40 P.S. 4004 upon
all interested parties.
14. The Joint Petitioner's best interest would be served by granting the relief
requested herein for the following reasons. Joint Petitioner is currently single and has
three minor children. Petitioner has never transferred payment under the annuity in the
past. Petitioner is looking to obtain a mobile home for herself and her family as well as a
vehicle to get her to and from work once she is done maternity leave. Petitioner is doing
everything she can to raise her three children and provide for them but needs this money
to obtain a safe residence a reliable vehicle. Without this money, petitioner has no means
of accomplishing these necessary goals and does not want to wait another five years
before she receives a payment from the annuity. Petitioner has thought about this
decision thoroughly and believes this is in her family's best interest. 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 her family.
WHEREFORE, Joint Petitioner's respectfully requests this Honorable Court to
enter the Initial Order attached to this petition which shall schedule a hearing so that
Transferee and Payee shall have the opportunity to discuss the purpose and reasons for
the transfer and after hearing thereon, respectfully request that this Honorable Court enter
a Final Order approving the Transfer of Structured Settlement Payments Rights as is
mentioned herein.
Maro & Maro, P.C.
Respectfully Submi
By:
! Marb, Esquire
for Transferee
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 Borowski, Vice President
,7 _ - 2 -,or( -L-
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.
1, 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
unsworn falsification of authorities.
Date
?Mert A`. Maro, Esquire
Attorney for Transferee, J.G.
Wentworth Originations, LLC
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1 115 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 Jeannie Snyder
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: The Travelers Insurance Company, n/k/a
MetLife Insurance Company of Connecticut
Attn. Legal Dept/structured Settlements
c/o MetLife - MRMR
2025 Leestown Road - Suite J
Lexington, KY 40511
J.G. Wentworth Originations, LLC
201 King of Prussia Road
Radnor, PA 19089
Kenneth Martin
9190 Iron Bridge Road
Orrstown, PA 17244
The Travelers Life And Annuity Company,
n/k/a MetLife Life Insurance Company of CT
Attn. Legal Dept/structured Settlements Jeannie Snyder
c/o MetLife - MRMR
2025 Leestown Road, Ste. J
Lexington, KY 40511
Date:
By:
?c6bert A. Maro, Esquire
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 Jeannie Snyder
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:
Ro A. Maro, Esquire
orney I.D. No 89585
earo & Maro, P.C.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600(office)
(610) 275-9666(Fax)
ATTACHMENT/EXHIBIT {6191
Affidavit in Support of
Petition to Transfer Structured Settlement Rights
L. Jewit-Ic; Dec Snyder, the payee, verify that the statements hrelow are true and correct:
Payee's na?ne, address and age: Jeannie I)cc Snyder. 35 N limiove:r S? { a v is c, PA
25
1. Marital Status:
Never Married; M"JI-ricd: Separated, Divorced
If rrnanied or separated, name of spousc N/A
4 Minor Children and other dependents:
Aaiden Snyder 5
Aalecia Hurrcl 3
Fernasia Wilkenson 2 mos
3. Income:
Not working presently
4. Child support, alimony or alimony pendente lite:
Obligation to pay: X Yes No
1 have an obligation to Xay Ken Martin when I :111' c!nhloyed, I ,ui) !)I
micrnploycd hok ,'c-ver ni?d hi.ive no obligation i<< fi,rcc willic :.u?c7i?plisyr?cl, and on
public assistarrce with r_cwhorn child. Presc;ttly there 11,2, nt> arc 110 1ufc;1t M'-)es.
5. Previous transfers: Complete the below for competition deals only. If prio?transfers were with JCW then ,just type See Exhibit "A
have you previously filed a petition to lrrursicr payment rt"Ilta under the
structured scttle;mc:nt that is the subject of this petition" Yee, , No
It'VUSa for each petition tllIt yoll filed,
ra) ]fthc transfer wa; submitted I' )r court :ippt,o, al, li,,t the
court, the case caption and case number, and state whether, Ille
court approved or disapproved the transfer: If the tr.=ilsrcr ,V s
approved,
(b) State the name of the transibree and identify (ii,, tin 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:
(L) Have you ever transferred payments without court
approval? If so, please explain: No
6. Reasons for transfer:
Buy a Mobile Home and a vehicle
7. Payment of debts:
If you seek the transfer in order to pay debts, list each debt, irtclud i?,r 1hc name of'
the creditor and the anlount prescaitly ov"cd:
Dcht Crcditor ;'mount Owed
06/25/2012 17:14 FAX 717 249 0637 Rowe's Print Shop 0003,0004
05/25/2012 xON 15152 Fax 219 567 7525 7.0. WENTWORTH X004/004
Verification
I verify that the statements made in tins affidavit are trne and correct. I understand
that false statements herein are made subject to the penalties of 18 pa.C.S. §4904, relating
to unswom falsification to authorities.
DATED: ?01s ta?oJo .
,,' iic Tam Sfi'yda,
ATTACHMENT/EXHIBIT 662"
Ofi/19/2005 07:39 FAX
00;i i OO:i
JUL-26-2005 02:Z5 PM RI GHI PPL.L- l 7177765562 P. Fit
CONTRACT SPECIFICATIONS (CONTINUED)
CONTRACT NO. 37936SA55449
PAYEE(S) JEANNIE SNYDER
BENEFICIARY ESTATE OF JEANNIE SNYDER
MEASURING LIFE JEANNIE SNYDER
JOINT MEASURING LIFE N/A
ANNUITY PAYMENT SINGLE PAYMENT ANNUITY
$21,025,00 SINGLE PAYMENT, PAYABLE ON 01/18/2017
PM WT.LL PAY THE BENEFIT PAYMENT (S) ON THE DATE (3) SPECIFIED. IF THE MEASURING
LIFE DIES BEFORE THE PAYMENT (3) IS DUE, THE PAYMENT (S) WILL BE PAID TO THE
BENEFICIARY.
ATTACHMENT/EXHIBIT 63"
0 5i 1 2l1 2 1,8:',T] 7.17.=...86317 LaPI OFFICE PAGE 26
Please, complete c. nd sign.
81'A I" EMENT OF PROFESSIONAL. REPRESENTATIOeN
1'l a e t noose Either Box 1. OR Bp-x_B_Belo-w.
Account ID, 261470
Ater you have made your choice, SIGN ANID DATE th.? appropriate box signature line.
`YOU ST40ULD SIGN ONLY ONE-BOX -- THE BOY YOU HA.\r) CJ-TOSFN,
> f A. I HAVE BEEN ADVISED BY J.G. WE,NTWORTH ORIGINATIONS, LLC
' ("JGW") THAT I SHOULD OBTAIN INDEPENDE,',N`T PROFESSIONAL
ICI+,PRESENTATION CON(::ERNING THE LEGAL, TAX ANDiOR FINAIvCI.Ni.,
INTPUICATIONS OF T,"IS I'RANSAC"I' ON. I FULLY 1,TtT)I RSTAND THE PURCHASE
AGREEMENT AND THE IMPLICATIONS 01 TILE TILANSFER, INCLUDING THE TAX
RA:111FICATIONS OF THE TRANSFER AND I DO, NOT WISE 1 TO SEEK OUT SUCH
INIIEPENDENT PROFESSIONAL REPRESENTATION.
, V`( N; NTE SNYDElA Dnte
B. I HAVE OBTAINED INDEPENDENT REPRESENTATION AND I FULLY ('NDERSTAND
THE LEGAL, TAX .AND/OR FINANCIAL INTPLTCATiONS OF THE TRANSACTION,
THE PURCHASE AGREEMENT AND THE RELATED DOCUMENTS. I'ii' AS NOT
REFERRED TO MY PROFH.SSIQNAI, ADVISOR BY.TGW. TIIE NAME, OF MY
PROFES`i1.0NAL ADVISOR IS SUf FORTH I3FI.OW:
.TTANNH SNYDGR Date
Name of Proftssiunal.
Phone Number: (_)
kddreSS
To Be Completed By Cerflried.Profecsinnal it dvisnr
Only if you b ave sigaerl Box B ,4 bone
Attorney ID #
I hay c persnrmlly met with and provided indepcndcnt professional advice to in respect of the Purchnsc Contract with JGW'
and the trATiMOi,n Contemplated thereby. Jeannic. Snydcr was referred Io me by the
P:afessional's Signature Date
I
t
SSC. nntract(1I -' zGl 1 j cj wQwwnrrh (; ihm trnn:: I,LC
ATTACHMENT/EXHIBIT 464"
M/12i'2012 18:20 7178336317 [-At,) OFFICE PANE i
Account ID: 261470
PUIx'UHASE CONTRACT
This is ra Purchase Contract ("Contract") for the sale of structured ,eitlernent payments hcLween
Jeannie Snyder (You, Your), with leg 1 residence it
35 N = nover St, Apt :i. Carlisle. PA 17013-'1014
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. Those Settlement Payments are being paid to You from an 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 RETWEEN YOU AND
US ARE RESOLVED.
DEYINE.D 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 A.ny documents necessary to carry out the purchase of the Purchased Payments, other
than the "Contract ul Contract Documents" as defined below,
Contract or Contract
Documents Collectively, only this Contract and the Disclosure Statement.
C.;nntract 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'oy a judge or properly empowered administrative officer,
approving the sale of the Purchased Payments to iJs ("Court Approval").
Disclosure Statcment. 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.
ON/15!I I. « 201 I J.G. >ti'cntworllr t.)rirri!tntirrs. LL.<_'
lrr /i2 12 1^:20 717Q?38G 17 t 5f T.:r RA(-E 17
issuer The insurmicr- t-4-mpany tilsil is ;-lied t?n-,: Annuity T'o?ic,.
Qbltgur Tl^.e l'erscn who is obligated to makt, payments to You under the Settlement Agreement
Party O»e of You or U's, Parties means boil, Yon and IIs,
Person Any rimutal person or legal cniity.
Purchased Payments Only those ccrtaitt :r<tvn:an^s that We Nre 1)vrcha inn from )', to tt il.er this Contrae.t.
Pur"ehase 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 pays ble to tht, seller (,Y01.6" Oil the OiSCIDS-UT-C
Strrternent. This is the sum We have agreed to pay Ycli; after any deductions as set forth
in the C:or:tract 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, ni Us J.G, Wentworth along, with ut.I of its : ucecgsors, assigns,
and designees. tion:c of the. Contract DOCIMIeT)t.? or Closing Doca_n;ents may refer to Us:
as the purchaser.
You or Your The Person nailed on this; Contract's first page. Herne of the C ontr ct ";10cumzrt5 r?r
Closing Documents may refer to You as the. seller.
You and We agree as follows:
1. SALE. OF THEePL'TZt HASEll PA'YMT,,N") S
??. Uporr the signing of this Contracv and tubjecr to certain cronditicros incLiding Court Approval: You sell, transfer
ar)J assign to Us the right to receive the Purchased Payments ?pecifcnily identified it thc: i iscirtsure Statement,
t? We will gray You the Net Purchase Price m ag-ecd to in tnc Contract Doctnnents, su jeet to certain Conditions,
including meeting Our underwriting requirement.,; Court Apprcva arld satisfactory completion o the (_;it}Sing
Doc,,tmcnts. We will do this in exchange for You:
selling the Purchased Payments to Us:
* chitnging the beneficiary of the Annuity Policy to 57our estzte and not chiangii g it alsr?in un:il We have
been paid all of the Pur(:h: sed Pavtnerts:
having any current beneficiaric s waive t)jr to the Purchased °ayrrcnts; and
• f ilfiliing Your promisee. under this Contract.
t_ if %V.- are buying only a portion of Your payments, this will Bove no effeci: urnrt Yotr rights in the unsold portion.
You w1l continue to rcccite the: unsold portiml unlcs: %'ou haul, alre.adv -ofd or encutnb tr 6 !l :.,r portion.
However, sometimes the 1ssuei, thr Ohl:gur or w c:.n;1 t tna;- t{tuire Ii5 to rC.Ceile thec entire amount of Your
payment li'so, We will then forwerd the 7rrton of the prr'n.e t stilt due to Yen <tnd Ym l w:c,y agree to this
nayrnet,t ce.n--icing arrangement.
ar i- 0 1 1G:20 17`. S ?1? i-*) CiFF=D-;E P0,6E 16
AcconntID: 21,, i470
PURCHASI, PRICE
The Cross and Nct Purrliase Pa leas are shown on the Uisclosu,re Statement and are fjir -Md rc e:t ta? le to You 011,1 Us
'vVc will pay You the Net Purcha,.c Price in the 1713nner You desiNmate for t?s.
C' Before we pay You, You agree that We will adjust fort h e ftillovving amounts, if applicable.
• Purchased Payments Owed to Us -- The issuer may have already paid You some of the Purchased
Payments before We have pnid 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 Purehased Payments to Us
instead of You, We will hold back an amount equal to any Purchused Payments that the Issuer owes Us
post Court Approval, that are due within 90 days of the Funding Date. If the subsequently receive those
particular Purchased Payments directly, We will return the Amount of any related holdback to You.
Payment of Debts Cawed -- If You owe aoy past dote child support, bankruptcy psayoffs or taxes, or hnve
any judgments or liens against Yuu or Your assets, We may pay those amounts and deduct them from the
:,mount We pay You, and You hereby provide Us with specific authority to take such action. We will
provide You with notice of the amounts that We are going to pay, prior to nctual payment.
D. If any Purchased Payments arc mistakenly sent to You aftor We have paid You for theca, Yoi vv! 11 immediately contort
Us. If We then determine that any deductions or holdbacks as c' iin?.h above are not enough to 'ciniburse Us, WC will
advise You of the amount You owe Us. You agme to immediately send that amount to Us by bank or certified check.
3 YOUR REPRCSENTAT is S 6, 0 WARRANTIES
You repr.sent and warrant to Us the foilou:ing:
A. You understand that 'ITHJS IS A SALE AND NOT A LOAN.
B. The Armuity Policy is in full force, You arc 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.
No Iavv, divorce dectcc or other legal obstacle:
• requires You co keep the Purchased Payments for the benefit of a current or for^ner spo_isa dependent children,
or oti,,er person; ar
legally prevents y'ou ft ,3m contracting with k; selling the Purchased. Paym°mts or char tiro the Annuity
Pnlicy's beneficiary.
F Either:
You have never filed for bankruptcy, will not do so before the Ftu;ding pate and there are no lawsuits or efforts
by any of Your creditors to put You inter t2nkrupLCV or utke airy o{thc- Purchased Payments; or
• Ii You filed for bankruStcv, the Purchased Yayment_ %Nere Trot s+.tirject to the ci<iir+i3 c:? )'our creditor;. You will
give L?s a copy oaf any of Your baakruptC ?10cumc:n13 that We. equest includint:± e? r1t a e ,i a final bankruptcy
pay; ciff ur case closing, if any,
ngc _
J C
E' F:!'I:1';''?0J1' 1r":20 71;'B326317 LAW OFFICE PA"T 19
Acccun, If): 261470
(7. We can rely on Your representations, warrantiCS, and j:rorniscS to this C otitract. Tluese reprasenta'icns. warranties, and
promises aie for Our bene?bt and the benefit of any future owners of the Purchased P ysrnents. Yoe( unrlerslt(rrd that 0.ir
reliance on any intentiomil misrepresCntat.ion by Y?n2 may r??s?a1t ii Our azr:Fotcing Our rights You in Court.
1.1 You had enough time to consider the sale of the Purrha.sed Payments, uiulcrstand the terms of the Contract Documents
and Closing, Documents (includingr; the arbitration provision), are of tegal contracting age and !round mind, not Lndt-r the
influence ofdmgs or alcohol, and freely and voluntarily, enter into thi, Contract and agree 10 all o`ity ter 1;13.
i You were advised by Uzs to obtain ii-I&Pendent legal advice and professional tax advice about the sale o:t ih:. Pur0'r;,sed
Pavrner,ts and to have those advisors rt±v'sew the terms and fat, Islx and other effects of this Ccntrac:t with You prior to
Yotrr execution ct this Contract. You have also explored all pprot7riate financial optior? 'r,eTore
entering into this transaction
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 informatlon 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 lie or she will be giving up any property or contract
rights that lie or she may have in the Purchased Payments.
i1 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.
IT 4ny future owner of the right to the Purchased Payments will have all of the same rights We have, including the rii ht to
the duties You mve Lis under this Contract. 'Mist includ:s the right to m,,ikr-, a claim against You for vit?lirfing any of the
representations, watrnnties, or promises N`ou riadc, in this Contract.
4. Y(3(IR,l'lkgN, itSj?_ti T) ; ti
Before and after the_I'undin'K )'tote.
4. You will tell us right away if Your address or telephone number changes and do
everything necessary, including corttpleting and signing all documents to:
• sell the right to the Purchased Payments to Us;
w change the beneficiary as required by this Contract; and
correct (any documentation errors in the Contra: ( Documents or Closing Documents,
B. Yore will als) tell Us if any of the following occurs:
• a violation of this Contract, or
• anything that could negatively affect the Annuity Polir_ -, he Purchased Payinent;. C1r this t'cntract.
C' Ycu will not
• agree to sell the Purchased Payment- to any Person other than L"r..,
chairgc t°ic Annuity Policy s t!enefc•ary to any Person outer than Your c.Aatc: until tVc };Frye, cG}1lcctect all of the
Purchased Payments; or
• withdraw cash from, barrow against, or change the Annuity Polley.
?CSI 1 7 Cl V!rnt? nrtl?!? i i-: ;1Hnn I I[
12 :2012 l;:20 7178385317 LAN ri{-FIC.:E PAGE= M
Aizcom)[ ID 761470
D You will (rive Us information necessar}' to update Yeur rcpresentations, v nrranties, and promi,es in :Ii-Contract. You
T
%viil gl3o update: any documents and information so they will be true and complete on 'lie Fundi tf? )ate-
[.• We are now, and will continue in the future, to rely on the ropresentatiors and warranties You I avr,;riven Us. We vrill
confirm the accuracy of Your represen'ations and warranties. You muse cooperate with this confirmation and provide
complete access to any information We believe necessary.
F. You agree that updating repre.scrttations, wairantics, proirl.ises, documents and other infonnat€ori aili not cure a bread-
Jany representation or warranty made by You that was not true And complete-
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 tenns of this Contraa efter receipt and £:pproval nfthe. Closing Document,,, final ondenariting approval
and Court Approval. Lander no c rcumstances will We be liable for any consequeritial 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: (l) negotiating, endorsing and executing checks, drafts and other instruments in Your nsmc; 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 Bic"' S
We nza-- cancel this Cur tract before the F;uiding Date if.
A- You breach any representation, war;snty, ar promise in any Contract Documents or C.'losi,ig Doer;meats.
B, The. petiticr for the Court Order is contested, opposed, or rot appmvt•d.
C. We arc suC or threatened with a lawsuit or an arbitration about this Contract or the Annuity Poiic
1;. There is any threatener, pending, or iital action, or change in law or Tale challenging the legality of, or negativety
affecting this transaction.
F. You file for, or arc forced into bankruptcy.
F, You dic.
G, Pinal approval has not been given by Cur undervriting department.
H. I he Purchase Contract is not sighed by You and rerc'rvcd back by Us by July I0, 2012,
1 inzl
jor rating -genet' downgrades the Issuer', credit rating-
Fhe Tssucr is, or bccorrl_s insolvent, cr under regulatory supervision
K. With respect tc A through .l above, to the extent perntittod by applicable law, the arbitration provi±"tort ir. Section 9 of
this Contrac, shall survive the ternimation, cancellation or rescission ofth,is Contract.
6 (-Ae Cr I ,? TTD,' DY YOU
A. (T) VOU AilAY CANCEL THIS COTiTRACT WITiIOUT• T'T.,sNALTY Olt FURTHER Oil'1 IGA'TTOJN AT ANNV
NTL NvurlTrr FlVE (r) 13L,'sENr.Ss t),iA'S x1F17I R,'I'lIE DA'I'S 4'OU +zA,C'rTV€ 7`;eYN11--N-1-
HEIZt%I7N'DER P`[tOM US- IN ORDER FOR TITP C-'ANCEL LA'rfON TO BE E FI:C I•tt'F, YOU NJUS't
`r':-'J? ,A NQ'1 ICE POSTIMARKED M AN)" TIME WI "Filth FTI?'1 JR ST'4ESS IJA`ir, Al7'.° YR YOU
RL'(:TAN'L PAN'.'.1EN'l TIFRF:.I ` 1)rR FRoI,,l U:S i, Vhis is tlic rc. ,Htsjon p£.ri€ d).
P?ec .
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(2) YOUR NOTICE IS TO BE SENT E',iTHER BY CERTIFIED OR REGISTERED MAIL (RETURN
RECEIPT REQUESTED) OR FEDEX OR ANOTHER MAJOR OVERNIGHTDELIVERY SER%'ICE. THE
NOTICE MUST INCLUDE; A BANK OR CFRTTFIFD CHECK MADE PAYABLE 'I O US, IN THE FULL
ANIQUNTRECEIVED BY YOU. YOUR NOTICE MUST BE SENT TO_
J.C. Wentworth Originations, LLC
Attention! Manager of Operations
3993 Cloward Hughes ParkwHy, Suite 250
Las Vegas, NV 84169-6754
it, GEORGTA RESIDENTS: YOU MAY CANCEL THIS TRANSACTION AT ANYTIME I'RIOR TO 5:00 P,NI.
OF' THE TWENTY-FIRST DAY FOLLOWING RECEIPT OF T14E ENCLOSED "NOTICE OF
CANCELLATION RIGTITS" FORM, OR AT THE HEARING ON'ITIE APPLIC ATTON FOR
ALA HORIZA110N-' OF A TRANSFER OF STRUCTURED SETTLEMENT PAYNTEN'T 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 UNCLOSED "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 OT'HER'WISE) RECE IVED
BY YOU ACCORDING TO THE REQUIRF,MENTS Ole f (A) (2) ABOVE.
:'. WE T VIRGINIA RESIbTN:r5: IN ORDER FOR YOUR. CANCIri.,LATION "TO BF'. I FrTCTIVE, YOUR
NOTICE CAN IIE SUBMITTED VIA PHONE, MAIL, OR FACS1N11LE, ANY ANTOUNTS ADVANCED 13Y
US IN CONTEMPLATION CIF THE TRANSFER SHALL BE IMMEDIATELY REFUNDED TO US. IF YOU
DISMISS YOUR ACTION AFTER APPOINTMENT OY A GUARDIAN AD LITENI T. OR RESCIND YOUR
TRANSFER AGREEMENT (PURCHASE CON'T'RACT) WITHIN THE RESCISSION PERIOD TN
6(A) (1) ABOVE, YOU STiAi,T, BE RESPONSIBL$ ItOR'I'HF FILING FEE AND ANN' GlUARDiAN AD
LiTFM FEES.
D. With respect to A through C shove, to the evt:ent permitted by applicable taw, the arbitration Provision in Section
9 of this Contract shall survive the termination, csncellation or rescission of this Contract.
7. NOTICES
All notices about this Contract must be in writing.
B. All notices must be sent e:tther by; (j) certifwd or registered ,nail (return receipt requested); or (2) Fed---'x or another major
ovemipht delivery service with a delivery tracking system and are considered given when delivered as follows: if to You:
to tha moss recom address for You listed in Out files, if to lis: to the address listed in Section O(A) (?) of this Contract.
8_ EVENTS OF DEFAULT
You will be In default if You:
A_ fail ;o comply with any teirns or conditions of this Contract, ct
Lt. breach any of Your reprmentntions, watrantie, 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 monev 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 ofthis Contract, and You have
not rejected 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.
r'a! c r.
iiS' I X111 ??? 2CI I i L(I 1V<.nnv l i Qrn:n rit i..,. LL'._
op./12/2012 12:20 7175325317 LAbJ OFFICE PAGE 22
9. ARBITRATION PROVISION
To the extent permitted by applicable law, You and We agree to the following arbitration provision.
Accqunt M] 2614 770
Y011 IIAVL THE RIGHT TO REJECT THIS ARECTPATION I'12.(7VTSTtiti AS SFT FORTH RFl OVV11" You do not reject
this arbitration provision and a Claim is arbitrated, You will not have the right to: (I) have a court or a jury- decide the Claim;
(2) Engage in informntion gathering (discovery) to the same extent as in court; (3) participate in a class notion in court or in
arbitration; or (4).joio 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 pomibic meaning and includes initial claims, counterclaims, cross-claims, third-party claims and
federal, state, local and administrative claims. It includes disputes based upon contract, toll, 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 terns specified in this arbitration provision.
Speeial 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 MTiliates 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" sot forth below and/or this sentence); all such disputes or controversies are for a court and not an arbitrator to decide.
However, any dispute or controversy that concerns the validity or enforceability of the Contract as a whole is far 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 Codc) ("PAA") shal I
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 oil 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 Glass Action Waiver is limited, voided or found unenforceable, then this
arbitration provision (t:xcept for this sentence) shall be still 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 s lawsuit in court asserting Claim(s) that are subject to arbitration, and the
other Parly files a motion to compel arbitration with the court, which is granted, it will be the responsibility of the Party prosecuting
the C'Isi n(s) to select an arbitritionn administrator in accordance with the psrsgraph below and commence thn arhitrntion proceeding in
accordance with the administrator's rules and procedures,
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The arbitration will be administered by the American Arbitration Association ("AAA'), 1633 Broadway, 10`x' Floor, New York, NY
10019, www.adr.org, 1-800-778.7879 or JAMS, 1.920 Nfain Street, Suite 300, Irvine, CA 92614, www.,jamsadncom, 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 arc
unable to agree, a court shalt 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 nrbitrator will be appointed by the administrator and must be a practicing, mtnrney with ien or name ye;irs of experience or a
retired judge 7"ne arbitrator will not be bound by judicial rules of procedure and evidence that would app'} in a court, or by stale or
local laws dint relate to arbitration proceedings. The arbitrator will honor statutes of limitation and claims oft-.rivilegC recognized
under applicable late. In determining liability or awarding damages or other relief, the arbitrator will follow thji Contract and the
appl cab'e substantive law, -onsisrent 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 ether 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 Claurm(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 i1or asser• ing the Claitr.(s) in
court, You will not he required to pray gnat amount again). in addition, the administrator may have a procedure ?xlnercby You car. seek
a waiver of fees charged to You by the administrator and arbitrator- '14e will always pay any fees or expenses that Wp are required to
pay by law or the administrator's rules or that We are required to pay for this arNt ation provision to be enforced, The arbitrator will
have the authority to award attorneys' and expt:.rt w•itne3s fees and costs to the extent permitted av ton mct, the administrator's
rules or applicable law. The arbitrator will always award You reasonable attorneys' and expert witness fees ;end costs (a) if and to the
extent von prevail on C'latim, 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 r` th> , rowirls for the
decision. A•judgment on the award may he entered by any court having ju. isdiction.
Severability and Survival. If any psrt of this arbitration provision, other than the Class Action Waiver. is de®ro;xi or found to be
unenfercenbic fn any reason, the remainder shall be enforceable. To the extent penrr.itted by applicable law, this :.trbitration nrnvis-on
shall survive the tenninat,on, cancellation or rescission of this Contract.
lEtfcct of Arbitration Award. The arbitrator's a-werd shall be final and binding or, ail Pasties, except for any righ of appeal provided
by the FAA. Iowever, if the amount of the Claim exc_eds $50,000 or involves a request for ir,functive ur de iaratc;ry Micf that could
foreseeably i i volvc a cost or benefit to either Party exceeding $50,000, any Party can, within -?0 days afltor the entry of the award b-'
the arbitrator, appeal the award to a three-arbitrator panel administered by the administrator. 'T'he panel ?,;i,all rcconsidor anew any
ai.ncct of the initial award requested by the appealing Party. The decision of the panel shall 'oe by majority vote, Rcicrence in this
arbitration provision to "the arbitrator" shall mean the panel if an appeal of the arbitrator's &,cision.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
4?anc'. is suu.jei.t to judicial review only as provided under the I Art.
Right to Reject Arbitration Provision. You may reject this arbitration provision by sendirmg Us written notice of `y'our decision so
that We receivc it at the address listed below within forty-fiv-: (45) days of the Contract Date. Such noble rrnm;t lx' writ by certified or
registered mail (return receipt requested) or by PedF,x tar 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 sigrature; and must be delivered to Us at the address specified in Section 6 (A) (2) ofthis Contract. This is the sole and only
method by w hich You can reject this arbitration provision. Upon receipt of a rcieeiion notice, We. will rcimburs4, You for the standard
cost of a certified or registered letter or overnight delivery. Rejection of this arbitration prevision will not affect any other terms of
Chic C'onmlc•t an,d 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 provi,,.ion in a timely and proper fashion. This arbitration provision will apply
to You and Cs unless you reject it by providing proper and timely uvtice as stated herein.
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A "'ow give Us permission to conduct bm kgrownd chcc;ks on You, including ohfmlinine intorrlrltion `i'ifm -ha credit bureaus,
in ordcr to veriN Your legal residence, contac,, information:, and any ot9,ez iof6nnation We deem !iecessaly for this
'rVnsactiorl +.N`e can also senrch Tccords for UCC. tilin.gs, bankrn;,rcy filings, Jucip.ments. liens .i1.d CHU sul?pert
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 ofthose people together, and to each of them on their
own.
D. Both Parties must agree in. writing to any change to this Contract or waiver of its terms.
E. Except as set forth in the arbitration provision in Section 9 of this Contract, if a court undoes any part ofthis Contract,
the rest of the Contract remains valid.
F. 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 affect.
0. Except as otherwise required by applicable law, the law of the state of Your domici le (whore You regularly reside on the
Contract Date) will govem this Contract.
IT. 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 Vs, this Contract will bind. and benefit Our successors and assigns.
1. Failure to enforce any provision of this Contract is not a waiver of that provision.
J. The Parties may sign this Contract in one or more counterparts. Each counterpart will be considered an onginal. 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 for 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 federal law.
L. Ynu will nol receive an CRS Form 1099 from Us.
M. Titles and headings in this Contract are for convenience only, Do riot use therm to interpret tills Contract.
N Except as otherwise set forth in this Contract (including the arbitration provision in ';Mt:ion 9 01^0115 Contract), You and
We will pay our respective costs and e?cpenses in carrying out this Contract
You and We, intending to be legally bound, have signed this Contract as of the t;untramet Date below, and n2rce to ail of its
terms and conditions, including the arbitration provision.
L9-I r11 C-20[1 J,fi.WcniwnrthCiri-iimiitms.LLC
12/?012 18:'20 71 ' LAW OFFICE PAGE 2F
AccnuntW: 261470
Hy signing tJelow, you also acknowtedge that You were advised by Us in writing, that You should obtain independent. $egsd
advice and professional tax advice about the sale of the Purchased Payments and to have those advisors review with You, the
tennis and li-gal, tax and other effects of this Contract.
Sovm ii to and 5 ?hscyl'I d SLLLER:
t ct.Jre me tlii= ?s(' rlfty of .)k9 , 20a ("Contract
Date") < SIGN FIBRE
otary seanme 5n? der
e
Acknowledged and Agreed:
Sworn to and subscribed
before me this _ day of , 20T
Noto ry
NOTARIAL SEAL
ELAINE L. ROBINSON
Nolity Public
PALMYRA BOROUGH, LEBANON CO[10Y
My Commission Ezptms Apr 20.2013
SELLER'S SPOUSE (if applicable)
Spouse
US: J.G. Wentworth Originations, LLC
BY:
Sam Gottesman, Undcmvriting Manager
Pzw 10
fJ•9[' $,`I,I, r? ?0! 1 1 G. Wcnnvorh CJnpr%ninns, 111
ucui?nt !D 261,470
.tune 4, 2012
PENNSYLVANIA
DISCLOSURE STATEMENT
We will purchase the following payments (Purchased Payments) from You:
A) 1 payment of $21,025.00 on January 18, 2017
(The remainder of the page intentionally left blank)
+?i I J ,..,=?•,,,r!h Cn?iriualinni. L,li'
r
\ccount:1) 261470
.tune 4, 2012
The aggregate amount of the Purchased Payments is 521,025.00.
The discounted present value of the aggregate Purchase Payments at the federal interest
rate of 1.20% is $1.9,897.26. 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 $8,000.00.
The net amount payable to the seller (You) is $8,000.00.
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 40.20% 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 and 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 23.25% per year. PLEASE NO'T'E
THAT THIS 1S NOT A LOAN, BUT A SALE OF PAYMENT RIGHTS AND THE
INTER1 ST FIGURE IS ONLY PROVIDED AS AN ILLUSTRATION OF THE
ECONOMIC IMPACT OF THE SALE.
Please be advised there are i?o penalties or liquidated dainages 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.
JEANNIE SNV6ER SIGN HERE
AF„ 12'i 2F:1 2 1 ': 20 7170310C317 Lt4,:j OFFICE PAGE 2`4
IMPORT-ANT i°+_CJTIU,
You are strongly urged to coztsult with an attorney who can advise you of the potential tax
consequences of this transaction.
, kANNIL SN-ViWR
Sworn to and subscribed
Before me this c y of jj tt/72 • . 2{f17,
Nntarv
NOTARIAL SEAL
ELAWE L. ROBINSON
Notary PubNa
PALMYRA BOROUGH. LUA14ON COUNTY
My Commission Expireo Apr 20, 2013
M2011 f,(}, V,?--?i",-:111 ,
ATTACHMENT/EXHIBIT "5"
w
filly .} 2
The Travelers Insurance Company, n/k/a MetLife Insurance Company of Connecticut
c/o MetLife - MRMR
2025 Leestown Road - Suite J
Lexington, KY 40511
Attn: Legal Department/Structured Settlements
The Travelers Life And Annuity Company, n/k/a MetLife Life Insurance Company of CT
c/o MetLife - MRMR
2025 Leestown Road, Ste. J
Lexington, KY 40511
Attn: Legal Department/Structured Settlements
RE: Notice of Sale/Assignment of Paymcnt Rights
Your Contract #: 37936SA55449
Payee: Jeannie Snyder
SS #:
Dear Insurer:
Please be advised that J.G. Wentworth Originations, LIand/or its successors and assigns, have entered
into a transaction with the above-referenced a11r1t1itant wf"lo iS Seeking to transfer ecrtaln of fits/hcr rights to
the paynlenis scheduled to he, received under the above.-te.tcrctiecd ?-iwwiiy policy. l'i'e iuo currc,ntly seeking
court approval pursuant to the applicable structured settlcmew transfer statute. PUCSU"Int to ehc statute,
please note the following information about the Purchaser:
J.U. 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 he 1101d until the courts have enicred a final order
and we have forwarded this order to vou.
Very truly yowl;
,L Z,. ll'rlawor(h Originations, I_.f.C.
i
liv:
Lori Borowski, '`Vice President
"I I KI=NG OF 111,USSiA W)AD, S;'1! F Y0O. 1?AUNON, i'A I y(;fi7
PHONE': (80CH /90-10 1(; • I?A,\: (2 1.)).)01 W)96
MARO & MARO, P.C.
By: Robert A. Maro, Esquire
Attorney I.D. No.: 89585
1115 West Main Street
Norristown, PA 19401
(610) 275-9600
i'H Pi Q HONOTARY
2012 JUL 12 PH 1: 0 9
C 0
JMBEPLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO: 2012-4180
Originations, LLC and Jeannie Snyder .
PRAECIPE TO AMEND AND SPUPPLEMENT PETITUION FOR PARTIAL
TRANSFER OF STRUCTURED SETTLEMENT IN ACCORDANCE WITH LOCAL
RULE 208.3(a)
TO THE PROTHONOTARY:
Kindly amend and supplement the petition filed in this matter with the attached Amended
petition in accordance with Cumberland County, Pennsylvania Local Rule 208.3(a)(2).
Respectfully Submitted:
T BY:
Date
Maro & Maro, P.C.
R961rt A. Maro, Esquire
PAtomey for J.G. Wentworth
Originations, LLC.
1115 W. Main Street
Norristown, PA 19401
(610) 275-9600
(610) 275-9666(facsimile)
Reserved for Court Use.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO: 2012-4180
Originations, LLC and Jeannie Snyder .
INITIAL ORDER OF COURT
On this day of
2012, it is ordered that a hearing on this
Petition to Transfer Structured Settlement Payment Rights will be held on
, in Courtroom at o'clock. The payee shall bring
income tax returns for the prior two (2) years to the hearing.
Within seven (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.
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: 2012-4180
Originations, LLC and Jeannie Snyder .
SUPPLEMENTAL 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, Jeannie Snyder, and in
accordance with the applicable rules of Pennsylvania Civil Procedure, hereby represents
as follows:
15. Petitioner hereby incorporated all paragraphs and attachments of the Original
Petition for partial transfer of structured settlement as if same were set forth
herein at length.
16. A judge has never ruled upon any other issue or related matter regarding this
case.
17. As this is a joint Petitioner, there is no opposing party. However, Notice of
this petition has been sent to all parties and counsel of interest and no
objection has been made from any interested party.
WHEREFORE, Joint Petitioner's respectfully requests this Honorable Court to
enter the Initial Order attached to this petition which shall schedule a hearing so that
Transferee and Payee shall have the opportunity to discuss the purpose and reasons for
the transfer and after hearing thereon, respectfully request that this Honorable Court enter
a Final Order approving the Transfer of Structured Settlement Payments Rights as is
mentioned herein.
Maro & Maro, P.C.
Respectfully
B)Agtttomeeyy 1!?rrt aro, Esquire
for Transferee
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 unworn falsification to authorities.
Vice President
/7-/ o - / 2
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
unsworn falsification of authorities.
Date
RoJirt A. Maro, Esquire
orney 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: 2012-4180
Originations, LLC and Jeannie Snyder .
CERTIFICATE OF SERVICE
I, Robert A. Maro, Esquire, hereby certify that a true and correct copy of the
Praecipe to Supplement and Attach 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: The Travelers Insurance Company, n/k/a
MetLife Insurance Company of Connecticut
Attn. Legal Dept/structured Settlements
c/o MetLife - MRMR
2025 Leestown Road - Suite J
Lexington, KY 40511
The Travelers Life And Annuity Company,
n/k/a MetLife Life Insurance Company of CT
Attn. Legal Dept/structured Settlements Jeannie Snyder
c/o MetLife - MRMR
2025 Leestown Road, Ste. J
Lexington, KY 40511 / J
J.G. Wentworth Originations, LLC
201 King of Prussia Road
Radnor, PA 19089
Kenneth Martin
9190 Iron Bridge Road
Orrstown, PA 17244
Date: .2 m-/ )-
By:
Esquire
Wentworth Originations,
LLC
?;..L-t1FFil?:
Tle PR0TH0NOTr`, ,.
Reserved for Court Use.
2s, 12 JUL 17 PM 2: 04
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: Joint Petition of J.G. Wentworth NO: 2012-4180
Originations, LLC and Jeannie Snyder .
INITIAL ORDER OF COURT
On this /;Z? day of 2012, it is ordered that a hearing on this
Petition to Transfer Structured Settlement Payment Rights will be held on
Goa` Pm
,in Courtroom at _4L3L o'clock. The payee shall bring
income tax returns for the prior two (2) years to the hearing.
Within seven (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.
,cry Ma.. /Pol -711'7
?i a
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: 2012-4180
Originations, LLC and Jeannie Snyder .
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, Jeannie Snyder, and in
accordance with the applicable rules of Pennsylvania Civil Procedure, hereby represents
as follows:
15. Petitioner hereby incorporated all paragraphs and attachments of the Original
Petition for partial transfer of structured settlement as if same were'set forth
herein at length.
16. A judge has never ruled upon any other issue or related matter regarding this
case.
17. As this is a joint Petitioner, there is no opposing party. However, Notice of
this petition has been sent to all parties and counsel of interest and no
objection has been made from any interested party.
WHEREFORE, Joint Petitioner's respectfully requests this Honorable Court to
enter the Initial Order attached to this petition which shall schedule a hearing so that
Transferee and Payee shall have the opportunity to discuss the purpose and reasons for
the transfer and after hearing thereon, respectfully request that this Honorable Court enter
a Final Order approving the Transfer of Structured Settlement Payments Rights as is
mentioned herein.
Maro & Maro, P.C.
By:
PNbert A. Maro, Esquire
Attorney for Transferee
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.
-##I '`
Vice P
17-
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
unsworn falsification of authorities.
7 h1'l k
Date
A. Maro, Esquire
)rt
torney for Transferee, J.G.
entworth 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: 2012-4180
Originations, LLC and Jeannie Snyder .
CERTIFICATE OF SERVICE
I, Robert A. Maro, Esquire, hereby certify that a true and correct copy of the
Praecipe to Supplement and Attach 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: The Travelers Insurance Company, n/k/a
MetLife Insurance Company of Connecticut
Attn. Legal Dept/structured Settlements
c/o MetLife - MRMR
2025 Leestown Road - Suite J
Lexington, KY 40511
The Travelers Life And Annuity Company,
n/k/a MetLife Life Insurance Company of CT
Attn. Legal Dept/structured Settlements Jeannie Snyder
c/o MetLife - MRMR
2025 Leestown Road, Ste. J
Lexington, KY 40511
J.G. Wentworth Originations, LLC
201 King of Prussia Road
Radnor, PA 19089
Kenneth Martin
9190 Iron Bridge Road
Orrstown, PA 17244
Date:
By:
Esquire
Wentworth Originations,
LLC
r 41 i ?'' 1J ?-'
Maro & Maro, P.C. j- 0-
By: Robert A. Maro, Esqu ro < V
Attorney I.D. No.: 89585 L 19 ??
1115 W. Main Street ?`? ` AKD CQV?yj`{
Norristown, PA 19401 vp,?t
(610) 275-9600??J'Ci We tworth Origination, LLC
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
/a-yigo
IN RE: Joint Petition of JG Wentworth NO ^=o?':=1
Originations, LLC and Jeannie Snyder
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: July 17, 2012 By:
Ro ert A. Maro, Esquire
Attorney for JG 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: q-
Originations, LLC and Jeannie Snyder .
NOTICE. OF HEARING ON PETITION TO TRANSFER STRUCTURED
SETTLEMENT PAYMENT RIGHTS
To: The Travelers Insurance Company, n/k/a
MetLife Insurance Company of Connecticut
Attn. Legal Dept/structured Settlements
c/o MetLife - MRMR
2025 Leestown Road - Suite J
Lexington, KY 40511
J.G. Wentworth Originations, LLC
201 King of Prussia Road
Radnor, PA 19089
Kenneth Martin
9190 Iron Bridge Road
Orrstown, PA 17244
The Travelers Life And Annuity Company,
n/k/a MetLife Life Insurance Company of CT
Attn. Legal Dept/structured Settlements Jeannie Snyder
c/o MetLife - MRMR
2025 Leestown Road, Ste. J
Lexington, KY 40511
You are hereby given notice that J.G. Wentworth Originations, LLC has filed a petition
to trans r structured settlement payment rights. A hearing i is matter has been scheduled on
2012 at ?i 3 o clock in courtroom no. courthouse, Cumberland Count
Court Common Pleas, City Hall, Cumberland, 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
Originations, LLC. 201 King of Prussia Road, Radnor, PA 1908,
7-/ BY:
Date
o, Esquire
ro-pmey 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:
Originations, LLC and Jeannie Snyder .
FINAL ORDER OF COURT
l vy
On this Day ofc?(,( , 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) aid `-;
3(a)(6); -03: _
(4) the payments that are to be transferred are designated as rrl.w CO r-,-,
follows: -< rn x
r- ?
c c1
.4 -icy
,7r:
A) 1 payment of $21,025.00 on January 18, 2017. aC-) a "t
(5) the terms of this order shall survive the death of the payee and shall be-_" 1-0 =-f
binding on the payee's heirs, beneficiaries and assigns;
(6) the payee shall receive from the transferee, within ten (10) days from the date
of this Order, the amount of $8,000.00, from which no funds are owed for
counsel fees, administrative fees, or other costs, fees or expenses.
BY THE COURT:
J
J.
COWS kVA deli" + a t?l