HomeMy WebLinkAbout05-2675
6,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount
Company, successor servicer to
GreenPoint Credit, LLC,
CIVIL DIVISION
No, 06~ ;)&7S'
~
Plaintiff,
Complaint in Civil Action. Replevin
v.
Cindy K, Reasner,
Filed on behalf of:
Green Tree Consumer Discount
Company, successor servicer to
GreenPoint Credit, LLC
Defendant.
Counsel of Record for this Party:
Erin P. Dyer, Esquire
PA ID Number: 52748
5743 Centre Avenue
Pittsburgh, PA 15206
(412) 361-1000
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S,C, S
1692 et seq, (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR
ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY
(30) DAYS OF RECEIPT OFTHIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN
AND PROVIDE DEFENDANT(S) WITH WRITIEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF
REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL
FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE
ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY
(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO
COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER
TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS,
YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF
THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF
YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE
ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON
YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO YOU, YOU SHOULD CONSULT AN
A TIORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS
SUIT.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount
Company, successor servicer to
GreenPoint Credit, LLC,
CIVIL DIVISION
Plaintiff,
)
)
)
)
)
)
)
)
)
No.
Complaint in Replevin
v,
Cindy K. Reasner,
Defendant.
NOTICE
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS
NOTICE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A
DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY,
You have been sued in court, If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this Complaint and
notice are served, by entering a written appearance personally or by attorney and filing in
writing with the court your defenses or objections to the claims set forth against you, You
are warned that if you fail to do so the case may proceed without you and a judgment may
be entered against you by the court without further notice for any money claimed in the
Complaint or for any other claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount
Company, successor servicer to
GreenPoint Credit, LLC,
Plaintiff,
v.
Cindy K. Reasner,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
CIVIL DIVISION
..-
No. OS -.;2.<0 7:J
THIS FIRM IS A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE, IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT
REAFFIRMED, THIS NOTICE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST
PROPERTY.
COMPLAINT
COUNT I - REPLEVIN
AND NOW, comes Green Tree Consumer Discount Company, successor servicer
to GreenPoint Credit, LLC, by and through its attorney Erin p, Dyer, Esquire and avers the
following in support of its Complaint in Replevin:
1. Green Tree Consumer Discount Company, successor servicerto GreenPoint
Credit, LLC, hereinafter referred to as "Plaintiff' or "Green Tree," is a corporation duly
authorized to conduct business in the Commonwealth of Pennsylvania and has its principal
place of business located at Stonewood Commons III, 105 Bradford Road, Suite 200,
Wexford, PA 15090,
2, Cindy K. Reasner, hereinafter referred to as "Defendant," is an individual
whose last known address is 123 Rustic Drive, Shippensburg, PA 17257,
3. On or about September 21,1999, Defendant purchased a 1999 Commodore
Manufactured Home, Serial Number CX34799AB, (the "Mobile Home"), from County Side
Village Homes, Inc., (the "Seller"), and entered into a written Manufactured Home Retail
Installment Contract and Security Agreement, (the "Security Agreement") for the payment
of a portion of the purchase price thereof. A true and correct copy of the Security
Agreement is attached hereto as Exhibit "A."
4. Seller assigned its interest in the Security Agreement to Plaintiff, GreenPoint
Credit Corp who perfected its security interest in said Mobile Home by having an
encumbrance placed on the title thereto. A true and correct copy of the Certificate otTitle
is attached hereto as Exhibit "B,"
5. On September 30, 1999, GreenPoint Credit Corp. and GreenPoint Credit
LLC, filed a Certificate of Merger with the Pennsylvania Department of State, Corporation
Bureau, Effective October 1, 1999, the surviving entity is GreenPoint Credit, LLC.
6. Effective November 1,2004, GreenPoint Credit, LLC, assigned its servicing
rights and responsibilities to Green Tree Consumer Discount Company.
7, Plaintiff avers that the approximate retail value of said Mobile Home is
$50,000,00 and that the said Mobile Home is in the Defendant's possession and believed
to be at Defendant's address as stated above,
8. Defendant defaulted under the terms of the Security Agreement by failing to
make payments when due. As of February 25,2005, the Defendant's payments of interest
and principal were in arrears in the amount of $940,21. Pursuant to the Acceleration
Clause in the Security Agreement the amount outstanding as of February 25, 2005, is
$56,062,88,
9, Plaintiff provided Defendant with thirty (30) days notice of intent to repossess
the Mobile Home, A true and correct copy of the notice of intent to repossess the Mobile
Home is attached hereto as Exhibit "C,"
1 0, Defendant failed to cure the default or return the Mobile Home upon Plaintiff's
demand.
11. Plaintiff avers that under the terms of the Security Agreement and
Pennsylvania law it is now entitled to immediate possession of said Mobile Home,
12. The Security Agreement provides that in the event of default, Defendant will
pay:
a, the reasonable attorney's fees of seller or of seller's assignee,
provided that prior to commencement of legal action such fee shall not
exceed $50.00;
b, court costs and disbursements; and
c, costs incurred by seller or of seller's assignee to foreclose on the
Mobile Home including the costs of storing, reconditioning and reselling the
Mobile Home.
13. In order to bring this action Green Tree Consumer Discount Company,
successor servicer to GreenPoint Credit, LLC was required to retain an attorney and did
so retain Attorney Erin P. Dyer.
WHEREFORE, Plaintiff, Green Tree Consumer Discount Company, successor
servicer to GreenPoint Credit, LLC, requests:
a) judgment against Defendant to recover the Mobile Home, plus detention
damages, special damages consisting of inter alia, detaching and transporting the Mobile
Home, shipping fees, any cost for insurance placed on the Mobile Home by Plaintiff, late
charges, and all allowable damages per the Security Agreement, any further costs for
repossession and sale, and attorney's fees and costs of litigation in order to obtain
possession of the Mobile Home; and
b) In the event Plaintiff repossesses said Mobile Home and resells or otherwise
disposes of said Mobile Home, a deficiency judgment in an amount to be determined by
the Court upon petition of Plaintiff, which amount shall be equal to the difference between
the amount owed pursuant to the said Security Agreement plus the damages set forth in
paragraph (a) above and the amount recovered by Plaintiff from the resale or other
disposition of the said Mobile Home, less expenses.
COUNT II - DAMAGES
By way of separate and alternative pleading, Plaintiff, Green Tree Consumer
Discount Company, successor servicer to GreenPoint Credit, LLC, alleges the following:
14. Paragraphs 1 through 13 of this Complaint are incorporated herein by
reference as though fully set forth.
15. This Count is brought in the alternative to the relief sought in Count I.
WHEREFORE, Plaintiff, Green Tree Consumer Discount Company, successor
servicer to GreenPoint Credit, LLC, requests:
a) judgment against Defendant in the amount of $56,062,88 with interest and late
charges plus detention damages, special damages consisting of inter alia, detaching and
transporting the Mobile Home, shipping fees, any cost for insurance placed on the Mobile
Home by Plaintiff, late charges, and all allowable damages per the Security Agreement,
any further costs for repossession and sale, and attorney's fees and costs of litigation in
order to obtain possession of the Mobile Home; and
b) In the event Plaintiff repossesses said Mobile Home and resells or otherwise
disposes of said Mobile Home, a deficiency judgment in an amount to be determined by
the Court upon petition of Plaintiff, which amount shall be equal to the difference between
the amount owed pursuant to the said Security Agreement plus the damages set forth in
paragraph (a) above and the amount recovered by Plaintiff from the resale or other
disposition of the said Mobile Home, less expenses,
~~~
..---
-,-
Erin P. Dyer, Esquire
PA 10 Number: 52748
Attorney for Plaintiff
5743 Centre Avenue
Pittsburgh, PA 15206
(412) 361-1000
L:\Green Tree\Reassner, Cindy\CM REP.wpd
VERIFICATION
Carmine M. Amelio, Regional Manager and duly authorized representative of
Green Tree Consumer Discount Company, deposes and says subject to the
penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities
that the facts set forth in the foregoing are true and correct to the best of his
knowledge, information and belief.
GREEN TREE CONSUMER DISCOUNT COMPANY
Carmine M. Amelio, Regional Manager
L:\Green Tree\General\Verification.Amelio.wpd
PENN$~LVANIA ,
J ,
.REJAIL INSTALLMENT CONTRACT, SECURITY AGREEMENT,
WAIVER OF TRIAL BY JURY AND AGREEMENT TO
ARBITRATION OR REFERENCE OR TRIAL BY JUDGE ALONE
(Contract)
BUYER(S):
MH VARIABLE RATE CONTRACT
LOANP~N:A01 091699
FOR OFRCE NUMBER: 79061
OFFICE LOAN SOURCE NO.: 750230
USE ACCT, No.:(qI~CH.R().
NAME: CINDY K. REASNER ONLY FUNDING CODE:
NAME: 5~~~" ~ _ ~.~_~~
NAME: COUNTY: - E~~t.A'rnJ'~'- =
BUYER'S NAME: ," ,_ .
ADDRESS: 48 MOBILE ESTATES CITY: $HI PPENSB'O:l<G --'STATE: PA ZIP; 172''5'7-''~
PHONE: (TI7) :;'31J"~0:).8 S.SEC.#(~ B <: -:00 -gnu ---
PROPOSED LOCATION OF MANUFACTURED HOME: 1Z3' R'U'STTC"LlR;- SH.LJ;'J;'J::f.JSB RG, J;'A ,ll <::0 I " -
'I," "me," "myse~' or 'my" mean all persons who sign this Contract as buyer or co-buyer, jointly and'severally,hand 'you' or'
"your" mean the Seller and any assignee. This Contract will be submitted.t9 .thE> C[~dilor indic~~~ b,,[owL at a local office and, if
approved, itwlll be assigned to that Creditor. On the date of this Contract, I buy from you on a "r!lpit sale b~~s the manufactllrec('
home described on page 2, together with furnishings, equipment, appliances and accessories included in the manufactured
home at the time of purchase (called "Manufactured Home").
CREDITOR: GREENPOINT CREDIT CORP. , '.. . : ' ..
PROMISE TO PAY: I promise to pay you at such- aadress- asyou may direct the Unpaid Balance sflown' on .page :!ol"this
Contract (Item 5) with interest at the initial rate of 8 . 50 % per year. The interest rate I will pay will change in accordance
with the provisions of this Contract. I will pay this amount in installmeniS as shown iii tnepayment scneauie,or as recomputea
due to changes in the interest rate, until the Unpaid Balance is fully paid. If, on 09/17/29 ,I still ov!!' any amount under
this Contract, I will pay such amount in full on that date, which is called the 'Maturity Date.' Each monthly payment will be--
applied as of its scheduled due date. If no interest rat~,is disclosed ab()ve.Jtt"jnl~i~1 jn.t~re,!! ra,te.is the An1J]!al,f',er"elltage, Rate ~
shown below.
INTEREST RATE: My initial interest rate may not be based on the Index used to make later adjustments. My interest rate may
change 11 months after my first payment is due and every 12 months thereafter based on movements in the
average of Interbank offered rates for one ye'ar U:8. dc;>lIar denommated d,,~Slts .n th" l,,6n9,o'l.l)1arket bas,ed upOillh" quotation
of major banks as published in the 'Money Rates' section of The Wall Street Journal on the first publication day of each moiith,' ,
and known as the London Interbank Offered Rates (L1BOR), which ~ the ind~x, rate. T)1is is calle.!! my "',nterest rate
change date." My Interest rate cannot increase or decrease by more than ~ . 00 % at any int~.!e,st rate ch"Dge or bl. more than' U
5 . 00 % over the term of the Contract. The interest rate will equal the index rate in effect 4, 5 da~ before the iJiterest -
rate change date plus a margin of 4.25 % jrounded to' the 'NE1ill:E-Sm ,of one percenta~e pOint) 'unless -
the interest rate caps limit the amount of change in'thlllnterest rate. If thiSTndex rate'ls nOlongefaviiiia~you'may cI10089"'-
new index that is based upon comparable information.
,n n' , , .
ANNUAL FINANCE CHARGE Amount Financed Total of Payments Total Sale Price
PERCENTAGE The amount I will have paid The lotal cost of my
RATE after I have made all purchase on credit
The dollar amount the The amount of credit payments as scheduled (which is subject 10
The cost of my credit as credit will cost me (which provided to me or on (based on the current change) Inoluding my
a yearly rate (which is is subject to change): my behalf: Annual Percentage Rate down pagn:eSlot
subject to Chang~: which is subject to change): $ ,00.00 :
10. 2 % $ 130,987.22 $ 56 , 138. 50 $ 187,125.72 $ 195,125.72
, See #7 (nane 2' Fin. Chart'le + Amount Fin. TotalPav. + Down Pa"ment
See COntract terms for additional information
about nonpayment. default, required repayment
in full before the scheduled date, and
prepayment refunds and penalties.
Prepayment: If I payoff early, t will not
have to pay a penalty, but I wiD notbe
entitled to a refund of the Prepaid
Finance Charge, If any.
NUmber of
Pa: ants
12
348
Amount of
Pa ments
449 .14
522.23
Monthly, beginning
Monthly. beginning
Monthly, beginning
Monthly. beginning
When Payments Are Due
OCTOBER 17
OCTOBER 17
1999
"
2000
My
payment
schedule
will be:
$
$
$
$
Security: I give you a security interest in the goods or property being purchased.
Late Charge: If a paymentis more than ~ days late, I wUl ~e_ ~h?lr~d 5
$ 5.00 ' ,
%ottheu!lpaidam~~~cJ!~~!-~~~!~~~ ~ ==-
~"-. --"""""- -......,..."....=-=-.,. ---- ~~--_.~
VarIable Rate: My Contract contains a variable rate feature. DisQjqsures about the variabl~r~tp f@:al4.~. ttave be~n pr9yige~tto !11~ ~?l.rile-r. - --
Assumption: Someone buying my Manufactured Home may, under certaIn circumstances, be allowed to assume the remainder at the Contract on the
anginal terms.
Estimates: All numerical disclosures except the lata payment disclosures are estimates.
The above disclosures are based on terms i
of Payments, Annual Percentage Rate, Fim
PA3S0845-0999
fthe int~'lst rate ch...nges. actual Amount
lore or less than disclosed above.
?"<l~\f::tf6
EXHIBIT "An
Description of
Manufactured
Home:
TRADE NAME: COMMODORE CORP;
YEAR: 1999 t-LEW: X
U1>.~;_
SERIAL
NUMBERS: CX3 4799 AB
ITEM II
SERIAL NUMBER
ADDITIONAL AIR CONDITNG
ACCESSORIES ANCHORS
AND FURNISHINGS: DECKS
091699
ITEMIZATION OF AMOUNT FINANCED
1. Cash Price (Including Sales
Taxof$ .00 ):"".. "...""... $ 63,500.00
2. a. Cash Down Payment. ". $ 8,000.00
b. Trade-In (Year, Make, Model):
Length Width
Gross Value $ . 00 Uens $
Net Trade-In Value $
TotaIDownPaymenl.... ".".".
3. Unpaid Balance of Cash Price (1 minus 2)
4. Amounts paid to others on my behalf:'"
8. To Insurance Companies:
(1) Property Insurance..
(2) Credit Ufe Insurance.,
b. To Public Officials:
(1) Certificate of Title $
(2) FILING FEES"'''' $
c. To Creditor:
For: ORIG FEES
d. To:
For:
:ci'o" ,
(Seller to payoff)
.00
8,000,00
55,500.00
$
$
611.00,
.00
$
$
22.50
5~ 00
$
2,246.62
$ .00
e. To:
For:
$ .00
f. To:
For:
$ .00
g. To: GREENPOINT CREDIT CO'
For: FLOOD FEE
h. To:
For:
$ 27 .00
$
Total (a+b +cTd Te TI+g +h)
$ 2,912.12
5. Unpaid Balance (3 plus 4)"
$ 58,412.12
6. Prepaid Finance Charge
$ 2, 273 .52
7. Amount Financed (5 minus 6) $ 56 , 138 . 50
*1 understand and agree that a portion of certain of these amounts
may be retained by you or your affiliate.
PA350s'46-<lSe9
-- _ MODEL:NOVA--- -:-: '
__ LEl'fGTH: 5 0
It
__W1DJl:I: 28
ft
II
I j I
-- SKIRTING
SHED
CHIMNEY
ITEM
SERIAL NUMBER
,-
INSURANCE
PROPERTY INSURANCE: Property Insurance on the
Manufactured Home Is required for the term of this
Contract. I have the right to choose the person through
whom it is obtained. By marking the appropriate line
below, I elect to buy the coverage Indicated from you
for the term and premium shown, and I want it financed
on this Contract.
Type of Insurance Term Premium
--
~ _Ph~leaI Damage Coverage 12MOS $ 611.00
B OAD FORM $
- $
-
LIABILITY INSURANCE COVERAGE FOR BODILY
INJURY AND PROPERTY DAMAGE CAUSED TO
OTHERS IS NOT INCLUDED UNLESS INDICATED IN
THE PROPERTY INSURANCE SECTION ABOVE.
CREDIT LIFE INSURANCE: Credit Life Insurance is
not required for this Contract or a factor in its approval.
If I elect Credit Life Insurance, the name(s) of the
proposed Insured(s) are:
Proposed Insured
Proposed Insured
(Only spouse can be insured joinlly.)
This Insurance may not payoff all of my debt, and the
exact amount of coverage is shown on my policy or
certificate. My signature indicates my election to obtain
Credit Life Insurance coverage for the term and
premium shown:
Type of Coverage Term Premium
-
_ Single $
_ Joint .$.
Date
(signature)
Date
(signature)
(If joint coverage is desired, both proposed insureds must sign.)
ORIGINAL COPY
PAGE 20F a
.\
ADDITIONAL TERMS AND CONDITIONS
.VAF.lIABLE RATE:
a. Monthly Payment Changes. My monthly payment amount will change each time my interest rate is adjusted. I will pay the
amount of the new monthly payment beginning the first monthly payment at the interest rate change date. The monthly
payment amount would fully amortize the remaining unpaid balance I am expected to owe on the interest rate change date at
the adjusted interest rate in equal monthly payments over the remaining Term of this Agreement.
b. Notice of Interest Rate and Monthly Payment Changes. You will send me notice of an adjustment in the interest rate and
monthly payment at least 25 days before the adjustment. This notice' will contain information about the index rate, interest
rate, payment amount and remaining unpaid balance.
c. Conversion to FIXed Rate. I may choose to convert this Contract to a fixed rate Contract at any time beginning
ZERO years from the date_of this Cl:lntract and ending -----30 years frpm,the dilte of this .Contract. In.
order to convert to a fixed rate, I must not be in default under the terms of this Contract, I must notify you in writing of my
desire to convert to a fixed rate, I must execute a revision agreement and I must pay a nonrefundable conversion fee. The
new fixed interest rate will be your standard fixed interest rate tor a comparable Contract on the date that you receive my
written notification. The new fixed rate will take effect on the "Conversion Date,' which Shall be my next payment due date
that is at least 30 days after your !imely rSl1:eipt of a revision agreement signed by all Borrowers together with a
nonrefundable conversion fee of $ 200. 00 . Th\l n~ fQ\@\l..rate -'111.11.. 1M. C;ol1'lersiqn,Date are subject to
change if my revision agreement and fees are received after the date specified in the revision agreement. My new payment
amount will be effective with the first payment following the Conversion Date.
SECURITY INTEREST: I grant you a security interest under the Uniform Commercial Code in (1) the Manufactured Home and in
all goods that are or may hereafter by operation of law become accessions to it, (2) all appliances, machinery, equipment and
other goods furnished with the Manufactured Home (whether or not installed or affixed to it) including but not limited to the Items
listed as "Additional Accessories and Furnishings' on page 1 of this Contract, (3) any refunds of unearned insurance premiums
financed in this Contract, (4) any substitutions or replacements of the foregoing, and (5) all proceeds of such Manufactured
Home and accessions, and of any Additional Accessories and Furnishings. This security interest secures payment and
performance of my obligations under this Contract, including any additional debt arising because of my failure to perform my
obligations under this Contract and Includes any contractual extensions, renewals or modifications. My execution of this Contract
constitutes a waiver of my personal property and homestead exemption rights to the personal property herein described. I will
sign and deliver to you whatever financing statements and other documents you deem necessary to aiiow you to perfect your
security interest in any personal property and fixtures. I agree that you may file this security instrument or a reproduction thereof
in the real estate records or other appropriate index as a financing statement for any of the items specified above. Any
reproduction of this security instrument or any other security agreement or financing statement, and any extensions, renewals, or
amendments thereof, shall be sufficient to perfect a security interest with respect to such items.
PREPAYMENT: I MAY PREPAY THIS CONTRACT IN FULL OR IN PART AT ANY TIME WITHOUT PENALTY, BUT I WILL
NOT BE ENTITLED TO A REFUND OF THE PREPAID RNANCE CHARGE, IF ANY. IF I MAKE A PARTIAL PREPAYMENT,
THERE WILL BE NO CHANGE IN THE DUE DATES OR AMOUNTS OF MY MONTHLY PAYMENTS, UNLESS YOU AGREE
IN WRITING TO THOSE CHANGES.
PROPERTY INSURANCE:
a. Minimum Coverage. I am required to provide physical damage insurance coverage protecting the Manufactured Home for
the term of this Contract against loss by fire, hazards included within the term 'extended coverage" and any other hazards,
including flood, for which you require Insurance, in an amount equal to the lesser of the actual cash value of the
ManUfactured Home or the remaining unpaid baiance I OWe from time to time on this Contract (the "Minimum Coverage").
The insurance polley will contain a loss payable clause protecting you (as your interest may appear), and provide for a
10-day notice of cancellation to you. Unless you consent in writing, I shall not add any additional loss payee to the insurance
policy. I have the right to choose the person through whom the property insurance policy is obtained. If my insurance
coverage expires or is cancelled prior to payment in full of this Contract, I must obtain no less than the Minimum Coverage at
my expense for the remaining term of this Contract. Should I fail to maintain the Minimum Coverage, you may, but are not
obligated to, obtain insurance coverage. I agree that any insurance you purchase may be for the protection of only your
interest in the Manufactured Home, may not fully protect me in the event of a loss, and may be for such reasonable period as
you determine. If you decide, In your sole discretion, to obtain insurance, you will notify me of that fact and that the cost, plus
interest at the Contract rate, will be added to my debt. I will repay such amount during the term of the policy in the manner
requested by you. I understand that the insurance premiums may be higher if you must purchase the insurance than might be
the case if I had purchased the insurance, and that you may purchase the Insurance from an affiliated company which may
receive a profitfor this service.
PA35084G..o999
PAGE3OF8
ORIGINAL COpy
--------------------------------------------~-------------------------
b. Assignment and Application of Insurance Proceeds. I hereby grant and assign to you the proceeds of any and all
insurance coverage on the Manufactured Home, including any optional coverage, such as earthquake insurance, which in
type or amount is beyond the Minimum Coverage. In the event of a loss to the Manufactured Home, I shall give prompt notice
to you and the insurance carrier. If I fail to promptly notify or make proof of loss to the insurance carrier, you may do so on my
behalf. All physical damage insurance proceeds, including proceeds from optional coverage, shall be applied to restoration or
repair of the Manufactured Home, unless you and I agree othelWise in writing or unless such restoration or repair is not
economically practical or feasible, or your security interest would be lessened. If such restoration or repair is not practical or
feasible, or your security interest would be lessened, you shall apply the insurance proceeds to the remaining unpaid balance
of this Contract, whether or not then due, and give me any excess. I authorize any insurer to pay you directly. I hereby
appoint you as my limited attorney-In-fact to sign my name to any check, draft, or other document necessary to obtain such
insurance payments.
LATE CHARGE: I agree to pay a late charge for late payment as set forth on the front of this Contract. Only one late charge will
be made on any delinquent installment regardless of the period for which that installment remains in default. After this Contract
matures, whether by acceleration or othelWise, I will not be charged a late charge.
EVENTS OF DEFAULT: I will be in default under this Contract if: (a) I fail to make any payment when due; (b) I fall to timely
make rental payments, or to pay other charges and assessments, relating to the real property and/or facility on which the
Manufactured Home is located; (c) I violate restrictive covenants, rules or regulations relating to the real property and/or facility
where the Manufactured Home is located; (d) I fail to keep the Manufactured Home in good repair and condition, as you may
reasonably determine; (e) I remove the ManUfactured Home from the address shown on this Contract unless I notify you in
advance and receive your written consent; (I) I sell or attempt to sell or to transfer any beneficial interest in the Manufactured
Home without first obtaining your written consent; (g) I allow the Manufactured Home to become part of any real estate without
first obtaining your written consent; (h) I encumber or abandon the Manufactured Home or use it for hire or illegally; (I) I fall to
promptly pay any taxes and other liens and encumbrances on the Manufactured Home or on the real property on which It is
located, if this is my responsibility; and/or (j) I fall to do anything else which I have promised to do under this Contract.
NOTICE OF DEFAULT: If any of the above specified Events of Default have occurred, you may do whatever is necessary to
correct my default. You will, except as set forth below, first give me a Notice of Default and Right to Cure Default before you
accelerate payment of the remaining unpaid balance I owe you or repossess or foreclose on any property which secureS this
Contract. The Notice will tell me what my default is and how I can cure it. Except as required by applicable law, you are not
required to send me this Notice when (1) you have already sent a Notice twice within the preceding one-year period, (2) I have
abandoned or voluntarily surrendered the Manufactured Home, or (3) other extreme circumstances exist.
CURE'OF DEFAULT: I may cure a default at any time before title to the Manufactured Home is transferred from me, which will
be at least 45 days after receipt of the Notice of Default and Right to Cure Default. To cure a default, I must pay: (a) all amounts
which would have been due in the absence of default and acceleration; (b) the attorney fees set forth below; (c) any late charges
that are due; and (d) reasonable costs which are actually incurred for detaching and transporting the Manufactured Home to the
site of sale. I must also perform any other obligation I would have had to perform in the absence of default.
REMEDIES UPON DEFAULT: If I do not cure the default, you may do either or both of the following at the end of the notice
period, as allowed by applicable law: (a) you can require me to immediately pay you the entire remaining unpaid balance due
under this Contract plus accrued interest or (b) you can repossess the Manufactured Home pursuant to the security interest I
give you under this Contract. If you are not required to send me the Notice of Default and Riglif to Cure Default, yell will have
these rights immediately upon my default. Once you get possession of the Manufactured Home you will sell it. If the amount from
!he sale, after expenses, is less than what I owe you, I will pay you the difference except as otherwise provided by law. All
remedies are cumulative and you may enforce them separately or together in any order you deem necessary to protect your
security.
ARBITRATION OF DISPUTES AND WAIVER OF JURY TRIAL:
a. Dispute Resolution. Any controversy or claim between or among you and me or our assignees arising out of or relating to
this Contract or any agreements or instruments relating to or delivered In connection with this Contract, Including any claim
based on or arising from an alleged tort, shall, if requested by either you or me, be determined by arbftration, reference, or
trial by a judge as provided below. A controversy involving oniy a single claimant, or claimants who are related or asserting
claims arising from a single transaction, shall be determined by arbitration as described below. A.ny other controversy shall be
determined by judicial reference of the controversy to a referee appointed by the court or, if the court where the controversy
is venued lacks the power to appoint a referee, by trial by a judge without a jury, as described below. YOU AND I AGREE
AND UNDERSTAND THAT WE ARE GIVING UP THE RIGHT TO TRIAL BY JURY, AND THERE SHALL BE NO JURY
WHETHER THE CONTROVERSY OR CLAIM IS DECIDED BY ARBITRATION, BY JUDICIAL REFERENCE, OR BY
, TRIAL BY A JUDGE.
PA3SOS'4s.09i19
P,AIJE4QF6
ORIGINAL COpy
c: Judicial Reference or Trial by a Judge. If requested by either you or me, any controversy or claim under subparagraph (a)
thnt is not submitted to arbitration as provided in subparagraph (b) shall be determined by reference to a referee appointed
, by the court who, sitting alone and without jury, shall decide all questions of law and fact You and I shall designate to the
court a referee selected under the auspices of the AM in the same manner as arbitrators are selected in AM-sponsored
proceedings. The referee shall be an active attorney or retired judge. If the court where the controversy is venued lacks the
power to appoint a referee, the controversy instead shall be decided by trial by a judge without a jury.
d. Self-Help, Foreclosure, and Provisional Remedies. The provisions of this paragraph shall not limit any rights that you or I
may have to exercise self-help remedies such as set-off or repossession, to foreclose by power of sale or judicially against or
sell any collateral or security, or to obtain any provisional or ancillary remedies from a court of competent jurisdiction before,
after or during the pendency of any arbitration under subparagraph (b) above. Neither the obtaining nor the exercise of any
such remedy shall serve as a waiver of the right of either you or me to demand that the related or any other dispute or
controversy be determined by arbitration as provided above.
ATTORNEY FEES: If I prevail in any legal action or arbitration proceeding which is commenced in connection with the
enforcement of this Contract or any instrument or agreement required under this Contract, or in connection with any dispute
relating to this Contract, you will pay my reasonable attorney fees, court costs and necessary disbursements incurred in
connection with such action or proceeding, as determined by the court, the referee, or the arbitrator(s) In accordance with the
law. If you prevail in any such action or proceeding, or In the exercise of any se~-help remedy as described above, I will pay any
court costs and necessary disbursements to the full extent permitted by Jaw, together with reasonable fees imposed on you by
an attorney who is not your salaried employee, provided that prior to commencement of legal action such fees may not exceed
$50.00 and further provided that no attorney fees may be charged prior to my receipt of the Notice of Default and Right to Cure
Default. _ ,_,_ _,___ u ~ ..,..
OTHER TERMS AND CONDITIONS: I agree: (a) to pay with my monthly installments, if requested by you to do so, the
estimated amount necessary to pay yearly taxes, assessments and insurance premiums that will become due within the
next twelve-month period; (b) to pay you a transfer fee if I sell the Manufactured Home, unless such fee is prohibited by law; (e)
to pay interest at the Contract rate on the remaining unpaid balance plus accrued interest, from the date of maturity until paid In
full; (d) to reimburse you, immediately upon your demand, with interest at the Contract rate, the amount of funds you actually
advance on my behalf to correct my default; and (e) that if I am married, and residing in a community property state, both my
community property and separate property will be liable for all payments due under this Contract.
ASSIGNMENT: You may assign this Contract to any person or entity. All rights granted to you under this Contract shall apply to
any assignee of this Contract.
CREDIT INFORMATION: You may investigate my credit history and credit capacity in connection with opening and collecting
my account and share information about me and my account with credit reporting agencies. You may sell or otherwise furnIsh
information about me, Including insurance information, to all others who may lawfully receive such information. You may furnish
specifIc information about the Manufactured Home and any insurance policies on the Manufactured Home to any insurance
agent to enable such agent to quote premiums to me and solicit my insurance business.
WAIVER: Waiver of any default shall not constitute a waiver of any other default. No term of this Contract shall be changed
unless in writing and signed by one of your officers. This Contract is the entire agreement between us and I agree that no oral or
implied representations have been made to Induce me to enter Into this Contract.
VALIDITY: Wherever possible each provision of this Contract shall be interpreted in such manner as to be effective and valid
under applicable law, but if any provision of this Contract shall be prohibited by or invalid under applicable law, such provision
shall be ineffective only to the extent of such prohibition or invalidity, without invalidating the rem!'linder of such provision or the.
remaining provisions of this Contract. This Contract shall be of no effect until and unless signed by me and you. In no event shall
any charge under this Contract exceed the highest amount allowed by applicable law. If any excess charge is received, such
excess shall be refunded or applied to the amount due.
GOVERNING LAW: Each provision of this Contract shall be construed in accordance with and governed by the laws of the state
of Pennsylvania, provided that to the extent you have greater rights or remedies under Federal law, such choice of state law
shall not be deemed to deprive you of such greater rights and remedies under Federal law.
PA350848-o999
PAGE50F 6
ORIGINAL COPY
,~
NOTICE
ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH
THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT
HERETO OR WITH THE PROCEEDS HEREOF_ RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED
AMOUNTS PAID BY THE DEBTOR HEREUNDER.
YOU AND I HAVE READ AND FULLY UNDERSTAND THIS CONTRACT, INCLUDING THE PARAGRAPH CALLING FOR
RESOLVING DISPUTES BY ARBITRATION, REFERENCE, OR TRIAL BY A JUDGE, AND NOT BY JURY TRIAL, AND
AGREE THAT THIS CONTRACT SETS FORTH OUR ENTIRE AGREEMENT AND THAT NO OTHER PROMISES HAVE
BEEN MADE.
31 WALNUT BOTTOM ROAD
If you do not meet your Contract obligations, you
may lose your manufactured home.
Notice to Buyer: Do not sign this Contract in blank.
You are entitled to an exact copy of the Contract
you sign. Keep it to protect your legal rights.
~UYER(S) ~IGNATURE(S~
~ C..w" D.lw..t.....
, 'CINDY! . R: SNER
ACCEPTED: The foregoing Contract Is hereby assIgned under the terms
of the Assignmenton page 7.
COUNTRY SIDE VILLAGE HOMES, I
SELLER:
SELLER'S
ADDRESS:
SELLER'S
SIGNATURE:
SELLER'S
TITLE:
172570000
.-
DATEo.r:!!:lli'cOm-~cT: ~%9' __ _.~.
I AGREE TO ALL THE TERMS ON ALL PAGES OF THIS RETAIL INSTALLMENT CONTRACT AND
ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS CONTRACT.
-~ ~~~~~~.~
(Sign re of Buyer)
(Signature of Co-Buyer)
,-
ASSIGNMENT BY SELLER
TO CREDITOR INDICATED ON PAGE 1 ('Creditor')
Wrth respect to this retail installment contract ('Contract") signed by one or more buyers ('Buyer'kSELLER represents
and warrants that: (1) Buyer's credit statement submitted herewith is completely accurate unless otherwise specified; (2) Buyer
was legally competent to contract at the time of Buyer's execution of this Contract; (3) this Contract arose from the bona fide
sale of the merchandise described in this Contract; (4) the down payment was made by Buyer in cash unless otherwise specified
and no part thereof was loaned directly or indirectly by Seller to Buyer; (5) any trade-In, or otl\er consideration, received as any
part of the down payment Is accurately described on page 2 and has been valued at Its bona fld\!l value, and any amount owed
on such trade-in or other property is accurately described on page 2 and has been paid off by Seller prior to or
contemporaneously with the assignment of this Contract to Creditor; (6) there is now owing on this Contract the amount set forth
herein; (7) this Contract and any guaranty submitted in connection herewith ,is in all respects legally enforceable against each
purported signatory thereof; (8) Seller has the right to assign this Contract and thereby to convey good title to it; (9) in the event
of any claim or defense asserted by any BUyer, or any heirs or assigns of Buyer, with respect to the Manufactured Home or
other property or consideration transferred pursuant to this retaUlnstallment contract, Seller agrees that it will indemnify and hold
Creditor harmiess from all such claims and defenses as well as from aU costs reasonably incurred by C[editor in connectign _
therewith, including but not limited to reasonable attorney fees and CQu,rt.costs; ;\,nd (1 0) i!l.accordanc~ with the, Fajr Crecjit.,_
Reporting Act, Seller has notified Buyer that this Contract is to be submitted to Creditor. _
For value received, Seller hereby assigns to Creditor all its lights, title and interest in this Contract and the property
which is the subject matter hereof and autholizes Creditor to do everything necessary to col~ct and dis."harge same, All the
'temi\; of any existing written agreements between Seller and Creditor go'!.erning the purchase of Contracts are made a part
hereot by reference, it being understood that Creditor relies upon the above warranties and upon said agreements In purchasing
this Con~ract.
PA350846-0999 ORIGINAL COPY PAGE6OF6
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ROCKDALE RDAL, AZ, AR, CT, DE, DC, FL, GA, IA (LH PMM), ill, IL, IN, KY, LA, MA (LH), MD, ME (LH
First Liens),
MI, MN, MO (LH First Liens), MS, MT, NE, NY, NH, NJ (HO), NM, NY, NC, ND, OH, OK, OR, I'A (HO),
RI, SD, TN, TX (HO), UT, VT, VA, WA, WI (LH First Liens), WV (LH), WY
NOTICE OF DEFAULT
AND
RIGHT TO CURE DEFAULT
Date of Notice: 4/20/05
CERTIFIED MAIL RECEIPT NO.
CINDY REASNER
123 RUSTIC DR
SIDPPENSBURG, PA 17257
GREEN TREE CONSUMER DISCOUNT CO.
105 BRADFORD ROAD StJITE 200
WEXFORD, PA 15090
1-800-245-1340
Account No: 73505181
CREDITOR: GREEN TREE CONSUMER DlS.CO.
Credit Transaction: MANUFACTURED HOME ACCOUNT
You are now in default on this credit transaction. You have the right to correct this default within 30 days from the
postmarked date of this Notice.
If you correct the default, you may continue with the contract as thought you did not default.
Your default consists of 6 payments (plus 0.00 in fees and charges) totaling $2070.76
Cure of default: Within 30 days from the postmarked date of this Notice, you may cure your default by paying $2070.76
Which consists of$2070.76 for Dast due Davments and 0.00 for late charees or bv doine the foUowin!!: N/A
Creditors rights: If you do not correct your default in the time allowed, the creditor may exercise its rights against you under
the law by taking legal action to repossess or foreclose on its collateral.
If you fail to cure the total amount of your default within the cure period described above, then as of 30 days from the
postmark of this Notice, the maturity of this contract is automatically accelerated and full payment of the contract in the
amount of $55026.79 shall be due and Davable without anv further notice from the creditor. Additional exuenses.
interest and charees accrued after the date of this notice shall also be due and Davable.
If you have questions, write areen Tree Consumer Discount Co. at the above address or call the number provided.
If this default was caused by your failure to make a payment of payments, and you want to pay by mail, send a cashier's check
or money order. Do not send cash. Other payment arrangements may be made by contacting areen Tree Consumer Dis.Co.
EXHIBIT "C"
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Green Tree Consumer Discount
Company, successor servicer to
GreenPoint Credit, LLC,
Plaintiff,
)
)
)
)
)
)
)
)
)
)
)
No. 05-2675-Civil
CIVIL DIVISION
v.
Cindy K. Reasner,
Defendant.
PRAECIPE TO DISCONTINUE PURSUANT TO
PENNSYLVANIA R.C.P. RULE 229
To the Prothonotary:
Please discontinue the above-captioned action at the request of Plaintiff, pursuant
to Pa.R.C.P. Rule 229. The discontinuance shall be without prejudice, and shall not be
deemed to bar the bringing of an action to collect any deficiency (or deficiency judgment)
owed to plaintiff by Defendant.
Respectfully submitted,
~/~
Erin P. Dyer, Esquir
PA 10 Number: 52748
Attorney for Green Tree
5743 Centre Avenue
Pittsburgh, PA 15206
(412) 361-1000
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L\Green Tree\Reassner, Cindy\P2D.wpd
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SHERIFF'S RETURN, NOT SERVED
CASE NO: 2005-02675 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
,
GREEN TREE CONSUMER DISCOUNT
VS
REASNER CINDY K
R. Thomas Kline
, Sheriff
, who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT
, to wit:
REASNER CINDY K
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
NOT SERVED , as to
the within named DEFENDANT
, REASNER CINDY K
123 RUSTIC DRIVE
SHIPPENSBURG, PA 17257
SERVICE STOPPED PER FAX FROM ATTORNEY DYER.
DEFENDANT'S CURRENT ADDRESS IS 12 MOUNTAIN STREET NEWBURG, 17240
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
14.80
.00
10.00
.00
42.80
':7~-=
Sheriff of Cumberland County
DYER LAW FIRM
06/13/2005
Sworn and subscribed to before me
this jSr.!2 day
.).iXJ '" I_A. D .
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Prothonotary
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