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Home My WebLink About02-2017MARK J. UDBEN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO.04302 1040 N. KINGS HIGH~FAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 The CIT Group Sales Financing, Inc. 5370 W. 95th Street Shawnee Mission, KS 66207-3204 -Cumberland County Plaintiff : Robert J. Thorson Jennifer L. Thorson 71 Peachy Ann Drive Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS i CiVIL DIVISION NO. COMPLAINT-CIVIL ACTION REPLEVIN/REPOSSESSION OF MOBILE/M~NUFACTURED HOME NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, 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, ~O TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumerland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 717-249-3166 AVZSO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UNABOGADO I~4EDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITAABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIALEGAL. Asociacion De Licenciados Servicio De Referencia E Informacion Legal C,,merland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 717-249-3166 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 M~RK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO.04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 The CIT Group Sales Financing, Inc. 5370 W. 95th Street Shawnee Mission, KS 66207-3204 Plaintiff V. Robert J. Thorson Jennifer L. Thorson 71 Peachy Ann Drive Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS iCIVIL DIVISION .Cumberland County NO. COMPLAINT-~IVIL ACTION 1. The Plaintiff is The CIT Group Sales Financing, Inc., a corporation with a principal place of business address as set forth in the caption, and is authorized and qualified to do business in the Commonwealth of Pennsylvania. 2. The Defendant(s) is/are Robert J. Thorson and Jennifer L. Thorson, adult individual(s), whose last known address is as set forth in the caption. 3. On or about 4/25/96, Defendant(s) entered into a Mobile/Manufactured Home Installment Sale Contract, (hereinafter referred to as "the Contract") with Carlisle Mobile Homes, Inc., for a 1996 Southern Energy Imperial, 62 X 28, Mobile/Manufactured Home, Vehicle Identification Number IH965430. A true and correct copy of said Contract is attached hereto as Exhibit "A". 4. By the terms of the Contract, the Plaintiff, and/or an Assignor/predecessor in interest, maintained a security interest in the subject mobile home. 5. The Contract was assigned to Plaintiff either by Assignment contained in the Contract, or by a subsequent Assignment, a true and correct copy of which, if applicable, is attached here to as Exhibit "B". 6. Plaintiff's security 'interest is evidenced by a Commonwealth of Pennsylvania Certificate of Title, a true and correct copy of which is attached hereto as Exhibit "C". 7. The Defendant(s), pursuant to the terms of the Contract, has/have defaulted under the Contract by failing to make monthly payments when due as follows: 6/8/01 throuqh 4/23/02 Installments @ $476.38 per month: TOTAL $5,413.94 8. The subject mobile/manufactured home has a current retail value of approximately $16,125.52. 9. Plaintiff believes, and therefore avers, that Defendant(s) has/have possession of the subject mobile/manufactured home, and that the Defendant(s) is/are in default of the Contract and therefore, inter alia, the Plaintiff has the "right" to obtain possession of the subject mobile/manufactured home. 10. The value of the subject mobile/manufactured home and the Plaintiff's interest therein will be adversely affected by the continued possession and use by Defendant(s). 11. Defendant(s) has/have failed and refused, despite repeated demands by Plaintiff, and despite Defendants' obligations under the Contract, to pay the balance due under the Contract or deliver possession of the subject mobile/manufactured home to the Plaintiff. WHEREFORE, Plaintiff respectfully requests, prays and demands that the Honorable Court grant judgment of replevin and/or possession in its favor and against the Defendant(s), together with reasonable attorney's fees, interest and costs; Order the Defendant(s) to I~DIA~L¥ deliver possession of the subject mobile/manufactured home to the Plaintiff or to I~DIATELX reveal the exact whereabouts of the mobile/ manufactured home, if applicable, for Plaintiff to take possession by its own means; and that Defendant's failure to comply with this Order shall subject Defendant(s) to the risk of appropriate sanctions which may include, but are not limited to: fine; and any and all other relief which this Court deems appropriate and just. COUN~ II BB~AC~ OF 12. Plaintiff incorporates herein by reference the allegations set forth in paragraphs 1 through 11 hereinabove as if fully set forth at length. 13. Pursuant to the terms and conditions of the Contract, Defendant(s) has/have defaulted by his/their failure and refusal to pay installment payments, the sum of which, including, inter alia, other contractual fees, is in excess of $5,413.94 and increasing monthly. 14. At all times material hereto, Plaintiff has fully and satisfactorily conformed to and complied with all terms and conditions required of it under the Contract. 15. Pursuant to the terms and conditions of the Contract, Defendants' default, inter alia, entitles Plaintiff to collect from Defendant(s), inter alia, all arrears, reasonable attorney fees for the commencement of this legal action, and all other costs incurred in connection with this collection action. 16. Through 4/23/02, the Defendant(s) owe/owes Plaintiff the following accelerated amount pursuant to the terms and conditions of the Contract: Principal of debt due and unpaid Interest at 9.5% from 5/8/01 to 4/23/02 (the per diem interest accruing on this debt is $13.85 and that sum should be added each day after 4/23/02 Attorneys Fees (anticipated and actual to 10% of principal) TOTAL $53,192.57 5,365.02 $63,876.85 WHEREFORE, Plaintiff respectfully requests, prays, and demands that the Honorable Court grant judgment in its favor and against the Defendant(s) for an amount in excess of $63,876.85 as set forth in paragraphs 15 and 16 hereinabove, along with any and all ongoing amounts due as set forth in paragraphs 15 and 16 hereinabove; and any and all other relief which the Honorable Court deems appropriate. Respectfully Submitted: Mark J. Udren & Associates By: ~ Mark J. Udren, Esquire Attorney for Plaintiff No2: eastom~r~s) Must Atso $~gn Separ~e Cred~ Ing~ranc~ ILIgcs~on On P~,ge 2 SECURITY AGREEMENT MoL~h / Day / Year For O]flce Use Only P~"]~ i Dea/er Tramac~n# __ ROBERT J. TIIORSON JENNte*:R L. TIlORSON 71 P~ACHY ANN DRIVE NEWV'ILLFq PA 192A!931S $e//~r N~ and Addre,~ CARLISLE MOBILE HOMES, 1NC. C~iSLE, PA 1~13 Thc words 'I', 'mc' and 'my' refer to the Customer and Co-Customer signing this contract jointly and severally. The wo~s 'you' ~d 'your~ refer to the Scllcr (m Bold~r ff this conUact ia ~signed). ANNUAL PERCENTAGE RATE 09.50 % -TheeMtofmycteditasayearlyram. FINANCE C'HA~GE ......... $ ea,3eg.o0 . The dollas mnoum the credit will co6t me. Amoont l~inanced ................... $ $4,525.00 . Thc amonnt of credit provided to mc or on my behalf. Total of Paymonts .................. $ ~.¢2,9~.4.o0 . Theamonntlwillbavepaidafterlhavcmadcall paymonCs as Sehoduled. Total S~]c 1~i¢~ ............. $ 145,9].4.00 . Thc total cest of my purchase on credit, including my downpayment of $ ~, 0oo.o0 Mypaymont [ NumbcrofPaymcnt~ [ AmoontofPaymonts When Paymcnts Are Due se~e..duJe 300 - $476.38 Mombly, bcgtnnJ~ .~.~ ~_ SECURITY - I am giving you a security intere-st in thc commodity purchased in this transaction. [] ff ~is box is checked I am also giving you a mortgage or deed of trust in the real estate de,seribed in the attached Exhibit A. pREPAYMt~NT - If I pay off early, I will not have to pay a penalty. AssUMPTION - Someone buying my commodity may, subject to conditions, b~ allowed to assume the r~malnder of the conWaet on the original terms. $e~ the contract document for any Idditional information about ~onpaymcnt, default, and a~y required I~pay~mmt in fllli befol~ the 8cheth~led d~te. IF I DO NOT MEET MY CON'I'KACT OBLIGATIONS, I MAY LOSE MY MOTOR ~mCL~ AND ANY O'l'U ~R PROPERTY iHAT I BOUGHT UNDER ltt~$ CONTRACT. Itemization of Amount Financed 1. Cash Price ., $ 55,205.00 c~ l::~¢;i~,;~ .............. '.'.'..'..'.'.'. ...... S ~,ooo.oo 'lYade-in (Year, Make, Model) a. Orosa $ o.0o b. t~,,- ~".7.7.'.'".'.'i $ o.oo c. Net Trade-in ........ $ 2 Total Downpayment .................................. $ 3. Unpaid Balance of Cash Price (1 m in~ 2) ........ $ 4. Insurance Charges a. Ins. on the Commodity ( __ months torm fxom the date hereof) ................. $ o .o0 b. Personal Liability Ins. ( __ months term fzom the date hereoO ................... $ o.oo c. Ctodit Life Insurance ( __ months term f~am thc d,,e hereof) .................. $ 0.0o d. Credit Accident & Health Ins. ( __ months term from thc date hcreo0 ............... $ o .oo 1nsuraace P--,aaium Costs (Total a thru d) $ o.oo 5. Other Chnzges a. Rccotding~Filtng F~,~ ....................... $ 0.0o b. Taxes (Not included in Cash Price) $ a,aa2.oo c. License Fees $ Ccnif. of Titic Fees $ 25.00 (Total) Registration Fees.,.,.. $ $ as. O0 d. Appra~! Fee ................................ $ 0.00 e TRIc Extort. Fce ................. $ 0.00 f. Title Ins. Pi~..ium .................... $ o. o o g. ~rvtce Win'rarity Contract .............. $ 0.00 h. Doem~entary Fee to Seller ............... $ o. oo Tot~l Other Charges (a thru h) ...................... $ 6. Amount Finnnced (3 + 4 + 5) .................... $ Paid To 0.00 3,000.00 52,258.00 2,257.00 56,525.00 Paid to the Insurance Company IPaid to Public Officials to Commodity and Equipment (De~.dbe) I have today bought and recoived in **fl*facto~ condition the commodity described below, including attnchtnents, equipment, a~rie~ and related services (refer~ed to collectively in this con.act as "commodity'), under the term~ and provisions of this comracL New or U~ed Year and Make Series, Mal~ or Trade. Name t De$crip~on (Aho No., ~f app~able) New 19 ~6 SOUTHERN POCOMO MAN 62 x 28 Identific~O. (Serial or Motor No.) State Re.s;o;,.~. No. Ranasber/Secial No. ge/SerialNo. T'no/~ ~/ [] Oher (I>e~ibe) [] J~/er/Sertal No. ~Reffigerator/Se~rialNo. ~'~ .~ W~ ~ C~ Will be kept at BURKHOLDER5 MItP CUbiBERLAND PA Cmmr/ Insurnn,'- Coverak~ No Coverages lnc!,,,4-d Except as Shown Below and Under Item 4 on Page I. M~nuf~:tur~d Ho~ing, Recreational Vehicle and Automobile Doductible Comptchonsive Deductible Collision F'tm and Theft Combined Additional Coverage Personal Effect~ Pwtection (except Automobile) [] Single Interest Property Insurance covering Holder's interest only, subject to policy terms. [] Other ~rancc We.~be) Munufectured Housing Only Naturui Disas~r Protection Comp~bensive Pemonal Liability Insurance ! imlt of Uabliity - Each Occurrence [] $~,ooo [] $~o,ooo DS Recreational Vehicle and Automobile Only Towing and Labor Costs Bodily Injury a~l Property D*,~-ge Liability I imlt of Liability - Each Occu~encc For term of months fwm the date hereof. Cuztomer may chcosc the agent and insurer through or by which the insurance de~'ibed above is to be placed. Total Premitm~ for insurance coverages described above if obteined from or through Seller $ 0.00 Date yon ~ chargin~ finance charge, if not the same as the date of this contract:. __, 19 (If a date is filled in, it means that I have not yet received the commodity, but cxpoct to ~ceive it by that dam.) Unle~ a Premium for Liability lnsuranc~ is Disclosed above: INSURANCE COVERAGES ABOVE DO NOT INSURE AGAINST LIABILITY FOR BODILY INIURY OR PROPERTY DAMAGE CAUSED TO OTII~RS. If in~uranco on the commodity is not included herein, I will furnish copy of policy, with long form Io~a payable clause, purchased fixun: ,,,gent's Nar~ and Addre~: Name of Insurance Company: Credit Insuranco Election Credit lesurance is not required by Seller. The undersigned (checkapplicable boxes): [] Requezt(a) Credit Life Insurance un the life of the Customer who first siges below, the cost of which is shown in Item 4c in the Itemization of Amount Financud on page 1 for the tv~n of months. [] Request(s) loint Credit Life Insurance on the livea of both Custome~ the cost of which is shown in Item 4c on paSe 1 for the term of months. [] Request(s) Credit Accident and Health hisurance on the Ct~tomer who first zi~ below, the co~t of which is Terms and Condittuns Promise to Pay - I will pay yo~ the Amour Fu~nced show~ on page I together with a Finance Charge in accordm~c wi& the payment schedule set forth on page 1. l~ym~ ~ be applied fu~t m accrued Kmanco C~e ~d ~ to the unpaid Amo~ Fmc:ed. Tbe fired paym~t in aH ~ will be the onpaid Amount Financed plus accrued and unpnid Finance Charge. Default - A Finance Charge accrucs on thc unpaid Amount F'manced at thc disclosed Annual Percentage P~to unffi my contract is paid in full. If yon aoccpt late payments or ~ paymonts, that doc~ not mcan you will accept ~ late or partial payments. If I do not n~ke any of my scheduled payments, or if 1 do not comply with any other ~cqulrcmonts of ~ contract, or if bantmiptcy or insolvency proccodin~s arc brought by or ngalust mc, thc full unpaid Amount Finanocd and pcrfom~g any other obligatiun due in rig aha'ace of acceleration, paying any late charges provided for in this conU'act, paying any reasm~ble cc~ts you actuslly in¢~l' in do~lting ~d ~]~b-porti~g the man.fly, lied housing to the site of s~le, paying reasm~ble attorney's fees paid to an nuomcy not n salaried employee of actually lncu~ed. No nttmm~¥'$ fees may be char~ed for expenses intuited prior to the time you send me the 30 day notice dea~ibad above and, prior to commencement of I¢~1 action, attorney's fee~ axe limited to $~0. If I cure a default, l will be restored to the same pusitio~ I would have been in hsd the default not occulT~ Notice is not requited as described above if I have cured defaults 3 times previously within n calendar year after receiving notice from you, or if I have abandoned or vuluntatily surrendered ll~ manufactured housing. accrued and unpaid Finance Charge which I owe will Rebate for Prepayment - At any time, I have the fight become due at your option, upon notice to me if to pay ~]s contract in full or to pay mom then my requited by inw. If you relX~ssess thc commodity and I schedule require~. If I pay in full ahead of schedule, I have not redocmed it within thc applicable time period described below, yon racy sell the commodity and you have aH the rights of a secured party under thc Uniform Commercial Code. If you sell my commodity, you have the right to sell to a dealer. The proceeds of the sale (minus attorneys' fees, court co~ and cxpen.~es of repossession, storage, repair and disposition) will be credited to my unpaid balance. If any money is left over after you have applied it to my obligation under this contract, it will be paid to me, but if any money is still owing, I agree to pay yon the balance. Commodities Other Than Manufactured Housing - ff I am in default you may accelerate the balance due, repo~'-us the commodity or commence legal action against mc on this conUact, ff the commodity is repossessed after a default, you may, at your option, give mc the right to redeem the commodity and relnstat~ thc connect. If the co,~modity has been other than by tegal proce~, you will scad mc a written notice of relx~scssion. If thc commodity is redeemed and thc contract is reinstated after selx~,cssion I m.~t pay you all past-due ius~llmonts and thc co~s of sutt, if any; provided dm if default at thc time of repoa~ession was in excc~ of 15 days, I must also pay the actual, nueessaty and t-..ason~ble cc~t of retaking, storing and repairing thc commodity. If the commodity repoe~sessed other than by legal process, 1 have thc fight to rodcem thc commodity and terminate the contract within 15 days aft~ no,ce of relX~-.~sion is mnilod to mc. To do so, I must pay the entire unpaid balance, plus accrued and unpaid fmenco charge and the cos~, chargc~ and expauses refcnv~l to ahovc. If I do not redeem the commodity as st~tod above, you may sell it, and I lore aH claim to thc commodity. Manur~tnred Honsin~ - If I am in default, and I have not abandoned ur vulunucrily surrendered the manofactm~cd housin~ to you, yon may accelerate thc balance due, rel~-?~ thc ,~,mufacmred housing, or commonce legal action agaH~t me on this contract only if you give mc 30 days prior written notice of your inte~,tio,l ~, do ~, ~cnt by ~$i~tered or certifted mail to the ~_ddre~s at which the ma~ufact~Lred housing is located. ~ notice must identify this conU'acl ss thc conU~ct involved and must state thc nature of thc default my right to eliminate the default, the performance anti, or amount of money nccossa~ to cl~mlnate thc default, thc fact thai I may ¢~iralnam thc default at any time before title to the manufactured housing is legally taken from mc (which cannot occur until at Ic~st 45 days after my receipt of your notice) and thc method or methods by which my ownership or lX~sessiou of thc manufactm'~l housing may be terminated. ! or anyone on my behalf may eliminate the default up to 3 times in any calendar year by paying thc unacceicrated amount duc at thc time of payment, ".~ will not be required to pay any portion of tho ~ Charge which you have not yet e~rned, The Finance Cha~e reprc~nts us*;mnted total charges which will be deducted from monthly payments, ~ on applicatinn of the disclosed Annual Percentage Rate to the unpaid Amount Financed. Security Interest - You will retain title to, and Commercial Code in thc commodity and all proceeds thereof and ~cessions thereto until I have paid the balanco in full and completely satisfied aH other t~quirements of this conm~ct end any modificatious to it. I assign to yon any insurance procee~ relating to the commodity, including return or uncamod premiums for application to the unpaid balanco. I direct any insurer to pay you directly, in the event of default, you may cancel all insurance and creAit any refund to thc unl~d balance. 1 w~ive aH n,atital rights, homestead exemption and all other exemptions relating to any pruperty in which I have gran~l you a security interust. if dhclused on page I of this contract, I have ~ g!von a mortgage or deed of t~-ust in the re~l estate de.~'ibad in Exhibit A to this contract and its proce~h es seau/ty for ~ con~ct. You a~rco to wulve end diseh~hn any seonrity.ints~t in thc ~al estate described in Exlfibit A to this contmot which may be c~ated in your favor by o~raHon of ¼w in connection with this mmasction innlndin~ but not limited to matcfiniman's liens, mcchaulc's liens, ·rtisan's lieus and vondur's liens ss a result of goods and scrvico~ provided in connection with transaction. Tot.~ Sa~e Pt[ce - I ~ a choice of paying either the Cash Price or the Total Sale Price and ch~e thc latter. Lieus- Use og Commodity - Proceeda - Notie~ - I agree to keep the commodity flee from all liens, and I won't move it from my uddress unless you a~.e in writing. 1 wou't sell or give the commodity aw~y, or rent it out, or use it illegally. You a~ entitled to any proceeAs from the s~le of thc commodity, but this fight de~ not wulve any fights you have in thc commodity and ooes not permit mc tc ~!! er u~fer the commodity in violation of this contract. Any notices you send me are sufficient if sent to my addre-x~ as shown on this conWact. Tax~ and Asse~mants - I will pay nil taxes and ssscssmonts un the commodity as they become due. If I fail to p~y any 1axes or a~essments on the commodity you may pay the taxes and asse~monts. I agr~ to refund to you any such taxes or asae~monts which you pay upon reool[a~ of wtittetx demaru~ together with interest ther~m frum the date of your payment at highest rate permitted by law. You may, however, in lico of making a demand for payment and in your sale discretion, add any amount you pay for taxes and (Contin~'d on nex~a~ge) (Continued I~om p~le 3) a.~e~nenu Io be~r interest ~ sho~ ~ pge 1 ~ w~ch cv~t you ~y ~nd me a ~v~ ~h~ulc of ~n~y ~n~. ~ent ~ C~t - Repr~n~flom M~om - N y~ ~i~ e~, I ~d ~t you ~ ~t ~t f~ ~e o~cr ~ to ~ive pa~en~ ~ for ~y o~r p~. No ii~m~~ ~mfi~ ~ w~ ~ b~d~g on you a~ment ~ ~ ~d~g ~ ~ y~ ~ me. c~flve. ~ ~ ~nt ~ ~w ~ ~g~nfi~ it ~ ~ c~ m~ ~ ~le~ ~ ~t it compli~. Requir~ ~ - I ~d ~t I ~ible f~ ~y ~mnge a~ to ~ ~ f~ ~e ~ of ~ ~n~ct ~e~g ~ ~iW aga~t ~ ~mnge. ~ ~ditio~ ~ I ~ve givm y~ · m~gage ~ d~ of ~ ~ my ~ ~, I ~H bw ~ ~ n f~ ~d ~o~t ~acm~ m y~ ~ve~g ~e ~ ~ ag~t ~k i,~ I o~ ~ch m~t ~ ~ac~ m y~ will contain u Io~ payable clause nsmi~g you anyone to buy ~, ~ ~ ~ ~ ~ ~ f~ ~y ~ ~ if ~ ~ I~ d~ ~ 2~ of ~ ~ I ~ ~ ~g ~ ~ ei~r of ~ ~ly ~y p~ ~ ~o~t you ~ at ~ ~ ~n~ge ~ ~ ~ ~ge 1, m ~ ~d ~t ~y ~ me · ~v~ ~h~e of m~y ~cn~. ~ver~ ~w = ~ ~ ~mp~ by f~ law, ~ ln~ of ~c S~ of ~lv~ ~ ~t ~y ~e~f o~1 si~ s~ll ~ d~ ~ ~g~l. No ~m of ~ ~g~ e~ if ~li~blc, · m~gqc ~d~of~ Used Vehich~ Notice: If this is a credit sale of a used motorized vehicle, other rhnn a motomyclc, with a gross vehicle weight m0mg (GVWR) of le~ than 8.500 lbs., a curb weight of less rhnn 6,000 lbs., and a frontal area of le~ thnn 46 sq. fL, then the following statements about the window form apply to ~ contracU The information you see on the window form for this vehieis is pm of this contraeL Information on the window form overrides any contrary provisions in the eontrart of sale. Disclaimer of Warranties: No warranties, express or implied, representations, promises or statements as to the condition, fitoe~ or merchantability of the commodity have been made by you unless envered by a separate statement delivered to me. A statement as to year model is for identification only. No changes may m made in the requirements of this paragraph unle~ in writing and signed by you and me. If an.v part of this paragraph is not permitted by law, that part will be ineffective, but the remainder of the paragraph will remain in force. NOTICE: ANY HOLDER OF TItlS CONSUMER CREDIT CONi'RACT IS SUIKIECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. NOTICE TO THE BUYER: Do not sign this contract in blank. You are entitled to an exact copy of the contFa~ct you signfKeep it to protect your legal rights. This co~atr~ct is accepted by the Seller and is asaigned Becal~ the Selrer has agreed to sell the commodity by the SeLler under the terms of the assignment deacribed un page 2 to the Customer, I agree to give the attached. Seller a security interezt in the commodity. I am not obligated to pay by signing below. Date~ /fT~/~. ~ ./ ~,~.5ignafure of Seller Signature of Non-Obligor Spouse ca~s~ Mostzz noM~ Name of Seller lvstallment Seller Lice~e CenO~core No. I (We) received an exact cop_y, of the above contract at the time I (We) signed iL Such. copy contained Seffe~' s signature ide~al with such signature on the original. //// d ~// Co.C~o~r o~Jo/po ; ~: o~ Page 4 of 4 2-2205D BODY TYPE ($DN. TK. MODEL YEAR I. TAX AND FEES RRST NAME MIDOLE INmN. DEALER~NUM~R STATE ZIP TrTLE WILL BE I.~ ~S "TENANTS IN COMMON". NO BLOCK IS CHECKED, OF SURVIVORSHIP TENANTS IN COMMON A. [] (ON DEATH ~OF ONE OWNER, ~TLE GOES TO B. [] (ON DEATH OF ONE OWNER, INTEREST OF DECE~ED SURVIVING.OWNER.) OWNER GOES TO HIS OR HER HEIRS OR ESTATE.) NOTE: IF THE VEHICLE IS BE~RG LEASED, CHECK THIS BLOCK [] . IF BLOCK IS CHECKED. COMPLETE AND ATTACH FORM MV-IL FAXABLE e~MOUNT X 6% (.06) SALES TAX X 7% (.07) PHILA. RES. *(See n~e on reverse). LESS TAX SALES TAX DUE ] ACTUAL MILEAGE DIFFERS FROM OOOMETER READING FOR MEF~GE OVER REASONS OTHER ~ CAUBRATION ERROR AND ACTUAL I I MILEAGE IS UNKNOWN WARNING: AN INACCURATE ODOMETER S~e,TEMENT MAY MAKE YOU LIABLE FOR ~ES TO YOUR mANSFEREE PURSUANT TO §40~A OF THE MOTOR VEHICLE INFORMATION AND COST SAVINGS ACT OF 1972. lb'T LIEN DATE: ~Z/~./? ¢.--~?~. '"~ IFNOLIEN, CHECKI~ 2ND LIEN DATE: ODOMETER READING TITLE FEE UEN FEE REGISTRATION OR PROCESSING FEE MAKE OF VEHICLE STATE ZIP 5. DUPLICATE REG. BODY TYPE (SDN, BUS, TK, ETC.) PASSENGER TAXI/BUS MOTORCYCLE MOTOR DRIVEN CYCLE MOPED YIN: ] MODEL YEAR ] CONDITION OF VEHICLE ~1 GOOD []FAIR [::]POOR 'PASSENGER [] TAXIi~ UMOUSINE[--I BSuC~OOL[] ~siTF~ BO~ER[-~ I SEATiNG CAPACiTY CYLINDER CAPACITY 5OCC OR LESS [] YES [] NO BRAKE 1.5 OR 1.6 TO HORSEPOWER []LESS 1--15.0 []OVERS.0 ~ DESIGN ~.u [] YES [] NO DESIGNED/ALTERED [] YES [] NO FOR ROAD USE BODY MAKE: AUTOMATIC I---lYES J'--JNo TRANSMISSION MOTOR HOME ~CtiASSISMFR: FEE NO. OF CARDS TRANSFER FEE INCREASE FEE REPLACEMENT FEE ' (ADO 1 THRU 8) Se~d O~e C~eck ORIGINAL PLATE ~ Check O~e PLATE TO BE ISSUED RY MUST BE ATTACHED.) EXCHANGE PLATE TO BE ( BUREAU TEMPORARY PLATE FULL ~,GENT INSURANCE COMPANY NAME~ ISSUING AGENT INFORMATION EXPIRES ~ Year REASON FOR REPLACEMENT [::]LOST [] STOLEN r--IDEFACED [] NEVER REC'D (LOST IN MAIL) NOTE: If "NEVER RECEIVED" block is checked, applicant must complete Form MV-44. JVIN RELATIONSHIP TO APPLICANT IISSUING AGENT (PRINT NAME) AGENT NO. CERTIFY ~-IAT OR MONTH DAY YEAR HAVE CHECKED TO DE-rERMINE THAT THE VEHICLE IS IN~JRED AND TEMPORARY REGISTRA~ON TO THE ABOVE APflfJCANT. IN ISSUING AGENTSIGNATURE ( ) '" J MESSENGER NUMBER: I 2. DEALER/ISSUING UST BE RETAINED FOR 3 YEARS) THE .~PPROP~bYTE BOX IN SECT~CN Sales Tax Information PURCHASE PRICE INCLUDES ANY LIEN OR OTHER OBLIGATION ASSUMED BY THE PURCHASER. ENTER TOTAL PURCHASE PRICE !N SECTION l, fl~CLUDIN¢~ L~'ST&LLATION CHARGES ON CONTRACT SALES OF MOBILE HOMES. IF PURCHASE PRICE IS LESS THAN PR£VAI[ING MARKET VALUE, A3 [ACH A I~RIEF EXPLANATION. IF TAX CREDIT IS CLAIMED, ATTACH EVIDENCE THAT 3AX WAS PAID. EXEMPTION REASON CODES tf you claim exemption from tax, choose the applicable exemption reason below and indicate proper reason Code and exemption Number df aeDlicablel ~,~ corresponding space r~rovided n Section I {Tax and Feesl on front of form. 1. Vehicle acr, uired for the purpose of resale '1~, Veh*cid brought ;nrc PA Dy a non-resident m conRection with the establishment of a oermanent business or residence. Indicate date bUSiness/residence established in PA in block lB Exemphon not applicable to construction contractors or to military personnel WhOSe nome of record is the Commonwealth of Pennsylvania, for wrucn a reC~s~rauon plate is obtained. 15. Incorrect tnle issu(¢o and Ho actual sale/transfer of ownership, Vehicle Transferrec [o: 16. Commonwealth agency or commission 17. Political subdivision of the Commonwealth 18. Municipal Authority created under the MuniciPal Authority Act of 1935/1945 19. Electric Co-operat~ve created under the Electric Co-ooerative Corporation Act 22. Homemade trailer with sales tax receipts attached. 23, School Bus Operator (Exemphon limited to school buses issued school bus registration plates). Other [Insert "0 on front of form in Block lA.) Explain ~n detail. VERIFICATION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in this action, that he is authorized to take this Verification, and that the statements made in the foregoing Complaint are true and correct to the best of his knowledge information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, Esquire SHERIFF'S RETURN CASE NO: 2002-02017 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CIT GROUP SALES FINANCING INC VS THORSON ROBERT J ET AL - REGULAR KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to says, the within COMPLAINT - REPLEVIN was served upon THORSON ROBERT J the law, DEFENDANT , at 1348:00 HOURS, on the 1st day of May at 120 W RIDGE STREET , 2002 CARLISLE, PA 17013 ROBERT THORSON a true and attested copy of COMPLAINT by handing to - REPLEVIN together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this /7 ~ day of ~j~ A.D. ~ot hohbt ary - ~ So Answers: R. Thomas Kline 05/02/2002 MARK UDREN By: SHERIFF'S RETURN - CASE NO: 2002-02017 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CIT GROUP SALES FINANCING INC VS THORSON ROBERT J ET AL REGULAR KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon THORSON JENNIFER L the DEFENDANT , at 1322:00 HOURS, on the 1st day of May , 2002 at 34 BROAD STREET NEWVILLE, PA 17241 JENNIFER THORSON by handing to a true and attested copy of COMPLAINT - REPLEVIN together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 8.28 Affidavit .00 Surcharge 10o00 .00 24.28 Sworn and Subscribed to before me this /7 ~ day of ~ ~(;02-~ A.D. I ~rothOnotary ~ -- So Answers: R. Thomas Kline 05/02/2002 M3LRK UDREN By: Depu/y WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.) The CIT Group Sales Financing, Inc. VS. Robert J. Thorson Jennifer L. Thorson 34 Broad Street Newville, PA 17241 No. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2017 Civil Term Term Costs Att'y. $ 125.23 Pl'ff (s) $ Prothy. $ 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Ctanberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: The CIt Group Sales Financinq, Inc. Plaintiff (s) being:(Premisesasfollows): 1996 Southern Energy Imperial Mobile/Manufactured Hcme 62 X 28 VehicleIdentification N~nber: IH965430 34 Broad Street Newville~ PA 17241 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. Date June 27, 2002 (SEAL) Curtis R. Long Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania By virtue of this writ, on the I caused the within named ? day of ~ ..... ~ .... have possession of the premises described with the appurtenances, and , to ~w~t oF Po~q~n R~t.rn~d ,qt~y~d on g./27/02; A~ p~ Attorney; Property is vacant. Sheriff's Costs: Docketing: 18.00 Po.ndagm 1.21 Prothonotary 1.00 Milage 11.73 ~qurc. h a rgt= 30. O0 61.94 Sworn and subscribed to before me this Advance Costs: 1DO.O0 Sheriff's Costs 61.94 Refunded to Atty on 9/27/02 day of ~ ~ , ,~0~ ~ / t Prothonotary Sheriff , , /