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HomeMy WebLinkAbout96-04602 -, ********************************************************************** NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ********************************************************************** 1. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. .' said Mortgage was dated 10/26/94 and is recorded in the Office of the Recorder of Deeds and Mortgages in and for CUMBERLAND County, Pennsylvania, in Mortgage Book 1239 , Page 594 , and was subsequently assigned as follows: Mortgage Book 508 , Page 8 A copy of the Mortgage, and Assignment(s) of Mortgage, if any, are attached hereto and made a part hereof as Exhibit(s) A and B respectively. 2. The mortgage secures Defendants' Note dated 10/26/94, in the amount of $84500.00, payable to Plaintiff in monthly installments with an interest rate of 0.925000. A copy of the Note is attached hereto and made a part hereof as Exhibit C. 3. The land subject to the mortgage is known as: 651 WILLOW GROVE ROAD, CARLISLE, PA, 17013. A full metes and bounds description is attached hereto. 4. The following individual(s) is/are the real owner(s) of the land subject to the mortgage and his/her/their address(es) is/are: GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA 651 WILLOW GROVE ROAD CARLISLE, PA 17013- PAGE TWO VERIFICATION SUHun deBoiHBlanc , states that he/she is the ^HHt. Vice PreHident of GE Capital Mortgage Services, Inc, Plaintiff herein; that he/she is acquainted with the facts set forth in the foregoing Complaint; that the same are true and correct to the best of his/her knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa.C.S. section 4904 relating to the unsworn falsification to authorities. V' /J. oJ \)vkill (0 /3N.,dfdJ /;/ SUSAN de IlOIS8IAHC ASST. VICE PRBIlEHr GECAPlTAUIOIITtW3ESEIIVlCEa,I<<:. 3039 o ~r. 1\ i\lllt. Cr.\li\~\6~\llCi CO~;J' . QI-t 1\\\O,.-..,u:....I~ '~) NORTH AMER I CAN MORTGAGE COMPANy,l, 1945 OLD GALLOWS RD, SUITE 500 VIENNA, VA 22182-3931 POST-CLOS I rw "61 lI,... .0.... nil II.. ,,, ~..".I., 0.101 368587-885 MORTGAGE TIllS MORTGAGE ("Security In:;trllOlcnt.') i$given on OCTOBER 26TH 1994 .Themorlg:lgori:. GREGORY RADIC MID, JULIA MAC2UGA ("norrower"), This Security In!:trllmellt i:'l:ivcn In Eau I TV ONE INCORPORATED ,which is organized and exi$ling \lnder the laws (If PENNSYLVANIA ,nndwhll:.cnJJre:::"I" 340 EAST MAPLE AVENUE, SUITE J, LANGHORNE, PA 19047 ("Lender"), Borrower OWe5 Lender the principal slim of EIGHTY FOUR THOUSArJO FIVE IlUNDRED AND 00/100 DoJ[ar,,(U.S.$ 84,500,00 ), Thi" debt is evidenced by Borrower's note dated the "a me date n:. this Secllrity Ill$lrllmcnt ("Nole"), which provides for monthlr payment:., with lhe full deht, ir nnt paid earlier, dlle :lIld paynhle nn NOVEMBER 01, 2024 ,This Security Instrument fiCCllres to Lender: {:d thc repnyment of the deht evidenced by the Nute, with interem, and all renewnls, extensions and modific:ltionfi nr the Note; (hl the payment or all other ;.1Jm~, with intere:>t, advanced under paragraph 7 to protect the !:t:cllrity or this Security Instrument; and (c) the performance of Borrower's covenanls and agreements under tlds Security Instfllment and the Nnte, For this pllrpO!le, Borrower doe-o; hereby mortgage, grant and ,"onve}' 1O Lender the following deficrihed property Incntcd in CUMBERLAND Count}', Penl\!:ylvnnia: THE LEGAL DESCRIPTION IS ATTACHED IlERETO AS A SEPARATE EXHIBIT AND IS MADE A PART HEREOF, which has the nddrcf':' of 651 WI L LOW GROVE ROAD , CARL ISLE Pennsylvania (SUull . rPrnpenr AdJre!:!:"); lellyl 1701:! (lip Cod~1 TOGETI IER WITI I nil the improvemellls now or hereafter erected nil the property, and all Cll.'>cmentfi, appurtenances, and ri~tllrcs 11011' f)r hereafter 11 p;trt of the property. All replacemenls and addition.'> sha[l nlm he covered by thi.'> SeclIritj' In:.trllmenl. All of tlte roregoing i:; referred In ill thifi Security In:;lrument Ml the ~rroperty," nORROWER COVENANTS th;]t nf)rrcl\\'e~ i:; lawfully sei:;ed of the c';{ate hereby conveyed alld ha.q the right to mortgage, grant and convey the I'rnpcrt}' nntl that the Property ifi unenrumbereJ, except for eneumhrnllces or record. BorrlllVcr Wo1rrnnl:; alltl will defend generally the title to the Property :\gainst all claims ,1nd dr:mand~, fillhjeet tn IlIlY enclIrnhralWI'!: fir record. 1'l!NNSYJ.VANIA- S'''1:1n 1'~mil)'.,t:lIl1lli" MIlf"/Frrlltlj" Mile UNIFORM INSTR tlMHNT . ~A.ft rORM :10:]') 00 I: .. n:lt;ol1al w;e alld nOll-uniform curity i1l~tr\lmellt (;()Verill~ real II1IS SECUIU Ii' I~:a'" '~Il~NT ~l)mbilj('~; llIlirurm ,q\l'II;1ll:~1 r l'OVl'llant:; with limited variatio. by j')ri~;diL:lilJn tn l'1)1j~;tlt\Jt" ;1 Illllform pnJperty. t:NIF()R~1 ('( )Vj':NAN rs. lIurroller :llld I.ender ~.tl\(,'II:lllt ;11\,] :1I:ree a~ folluw:;: I, I'aymenl lJf I'rillt:ipal and Illtcre.~t: l'repaYflwllt and I,ate (:hllri:e~. Ilorrower ~,hall promptly pay when dlH~ the prilll.:ipal Dr alld intere:;! on lhl.: Jd:t c','idt'I\l..,:d 1>) tlH': Nute alld any prepayment and late ehargc.'i dlle IllJder thl: Nole. 2, hllld~ fllr T:ue.r, :lIld Irl.~llralll'c. Sllbjn:1 hI ;Jf'pJi"abk bw or to a written waiver hy Lender, lIorrOIVtr ~;hall pay to lender Oil the dar monthly pajnH'rll~, M': dll'_' lJllder the Note, wltil the !\ule i:; paul in full. a ~;\HI\ ("hlll&,") rllr' (;d learlr 1.1);e:; ilnd a:;':~'~,:,ITH'llt~; which mar attain priority OVl'r thi.'i Security IIl.'itrlJlnellt a~; a li'':ll 011 tlw I'rupert:..; (h) Y~';lrlr It~a';l.:lrIJIJ payrn'"llt.; <lr grollnd n~llt:> OIL the I'rllpt:rt)', if any: (c) }cariy kl!ard or prlJpeny ill~:\Iran(.;e premiul11r.; (dl }1:;lrly flollt! ill~;uraJ\l.;(: pn:milllll:;, if all)': (e) yearly morlgage inr.\lran~e premi\lm;;. if any; ,1nJ (f) allY :;llm~; payahle hy 11"rrlJ\\t'r 10 Lellllt:r, ill a('~ordall~c with the provi:;iull.'i of paragraph H. in li':ll of the r;lyment of morq::igc ir,.;llraBL"C premium!;, The:;c ilem:; arc called "I':r.crow Item:;." l.'.:nder may, al all}' time, ClJllcd ;lIld hold Fund:; ill all arn(llHlt lIot to exceed the maximllm amount a lender for a federally n:Jated mortgage 11);111 may reqllire for 1l1,rro\','t'(:; t'~,~'f(IW :l('Wllnt under the reJcrnl l~eal E:;tate Settlement I'rllt:edlJfe!; ,\1.:1 (If IlI74 a:, amended from lime to time, 12 U.s.c. fj2601 If aq. ("RESI'A"). tll1le~.!; another l;'Iw th;'lt arplie~; to the 1;\lr1\I:; roc I:> a 1c:~,cr MTlOllllt. If :;0, I.cllder m.1)', at any time, collect and hold Flln&; in all amount llut to exceed the le~;:;er alllO\ll\L l.ender Illay l,~;timate the alOlJUnt I)r Fund" due on Ihe bn:;j:> of currcnt Jat,' and rca;.()nable c:;tirnale:; of (',\penditure:; or fIJtIJre r~cr()w Item:; or nthcrwir,c ill ;H;cordance with applil:able law. The Fund.'i ~1h311 hl' held ill all il1:;litlltion \dlOr,t~ dl'r'J:;il:; arc in:;llrcu by a federal agene)', ill:;tfurnentality, or entit}' (ino.:llJJill~ l,t'nder. ir I,ender i~; r.IJdl ,Hl ill~;tillltiIHl) or ill any t:ederalllume l.o:ln Ilank. LenJer :;hall apply the Fund:; tllll'a)' llle l~wJ\\' ItclTl~.. I.emler mar llot c.:h:lrge Borrower ror holding anu :Iprlyilli: Ihl: Funds, .11111ually all,llp.ing the t...~l.:roll' .1CCOlJnt, or ','I'rirying the Eserow ltem9, ul\l~;:; Lender p:lYS Borrower intere.'i! Oil the FUlld.'i and :Ippli('ahle law rermit:; I.cnder to make sllch a charge, However, Lender may reqllire Borrower to pay iI one.liml: ~hargc ror an illdcpelldcl1{ ft';,l e:;t:Jte tax reporting .'ien'icc ll.'ied hy Lender in CllllnCl.:tioll with thi.'i loan, WIle:;.>; applicahle l:lIv pro\'ide!; olllcrwil;e, Burrower and Lender may agree ill wriling, however, that illterc:>t :>1I:lI1 he paid on the Fund:;. Ixnder :;h.111 ~i\'c to Burrower, without charge, an illIlIIlal :u:wlJnting or the FUlIds, :;hl)wi{l~ nedits alii! dehil:; to lhe Funds ,11ld the purpfJ:>e for whic.:h each debit to the Fund.'i \Va:; made, The hll\d~; arc pleJl:ed 01:1 additiollal ~eclJrity fllr 1111 :;urn!; ~,el,;llfed by this Security In.'itrurnellt. If the Fund:'> held by Lender e.~o.:eeJ Ihe amullnt:; permitted tll by helt! by applicahle law, Lender r.h31l account 10 Borrower for Ihe e.~~e~O!; Funt!:,> in act:lJrJallce wilh the requirement!; of ,lpplic,lble law, If the amount of the FlJnd:; helJ hi' Lender at allY time i:; IVlt .'i\lffi~iellt to pay the I~!:.:row herO!; when due, Lender may roo notify Ilorrower in writing, :llId, in :;uch l'a~1.: Burrower :;!I:111 p;l)" to I.emler the :unutJllt l1el'c:-.:;ar}' to make up the deficiellc}'. Borrower .'ihall make up the Jdiciellcj' ill nil 1T1l'n' 111.111 twelve monthly pa)'olt'lIt:>, at Lender'.'i .'iole di:>cretioll. Upon pa}'mclIl in full of :111 :>lllll~; !:el.:ured br tld:; Security 11l';lrlllllclll, Lender !:hall promptly refund to lIorroIVcr an}' FUfl(J:; held hy Lender. If, under paragraph 21. IxmJer :;h;lll al..l{lJire or sell the Property, Lender, prior to the acqlli:;itiol1 or r.ale of the I'roperty, ~,hall ,1ppJ}' ;IIlY FUlllb Ileld hy I.endt.'r .11 the time of acqui5itioll or f,llle:J.'i a credit :lJ;ain:;t the ;.\lm;. .'iel.:ured by thi:; ~ecurilY IW;!flllnenl. 3. Applil.:alioll of Payments, Urde:-,,; aprilicah1t: law provir.ler. otherwi.'ie, :III pa}'rnentt. received by Lender under paragr:lpli.'i I alld 2 :>llall be ;lpplied: fir.'it, to ,illY pn'paymcnt char~('~; due under the Note; second, to amount:; payahle llnd':r paragraph 2: third, 10 inlcre:;t Jill:; forth, tn principal dlle; anr.lla::t, to any late charge:; Jlle Ilnder the Note. 4, Ch3q~e.~: Lien..., Bllrrower ~;h.111 p.1}' all t:l\e:;, a:;:>c:-.:;rnent:>, dl:rfJ:r~r" fille:; and impo.'iitioll.'i attributable to the Propert}' which may attaill priority o\'er Ihi:> Security In:Jtflllllent, a1ld lea~;ehold payment.') or ground rent.'i, if all}'. Borrower :;hal1 pOi}' the.'ic nhlig:ltiull.'i ill the l1lallner pf(Jvidetl ill par3graph 2, or if not p3id in that manner, lJorro\\'er :;hall pay them on time directly tn the pl'r::Oll owed payment. Borrower .'ihall promptl}' fllrniroh to I.ender all 11IlticC.'; or OlllltJunt:> to he paiJ lInder tlli:: iJaraJ.:raph. If Borroll'er makt.:; Ihc:>e pa}'ment.'i directly, Borrower :;hall promptly furlli:;h to Lcmler reccipt~ e\'idellt:illl~ the payment:;, Borrower ~ball promptly dischMge ,111j' lit'll which h:I~; priorilY o\'er thi:; ~erllrit}' Instrument Ilnlc:-,!; Borrower: (a) agree!: ill writ ill!; \0 lhe payment of the obli!;alion :;ecllrcd hy the liell in .1 manner :lcccptable to l.ender; (h) conlc:>t:; in ~{)od (aith the liell by, or Jdcmb al:;lin:,( (~nrt)rrCl1lellt of the liell in, legal proceeding.'i which in the Lcnder':; opinioll operale to pre\'ent the l:llforeernelltof the lieu; or (c) ::cl.:ure.'i from the holder of the lien an :lgrecmelll .'iati.'ifactnry tn I.ender :;uhllrd;llatill~ the liell to thi:: Secmity In:;trument. If Lender determine:; that an)' part or the Propeny i~; :;\Jbjcct tl} a lien wbich ma}' attain priorit)' over this Security In:>tl'lllllellt, l.ender mOlY give Borrower a 1lotice itlcntlfyill~ the lit~lI, I\ormwer .'ihall saldy the lien ur take aile or more nr the action:; :;ct forth abu\'e within 10 day:: of the r,ivinr, of notice. 5, lIal,aro ur Property Ills,lrallce. BlJrrower .'ihall kct'p Ihe improvement.'i now exi.'ilillg or hereafter r'fl~ctr'd 1m the PrIJI'Nh' inslHt'd :J1~.,ill';t llJ~;" hI' firt'. hazard.'; inrllltled within the term "c~tel\ded cO\'erageR and allY (II her ha!.:Inl:;, includillg flood... or flolldilll:, fm which .ender reqllirC!l ill.'iIJr:lllce. Tlti.'i in:,>ur.lllce .'ihall be FOAM 3011 V.,lIlln 1.0 (l1l911l31 l'.g.Jllrft~_ln;'I.I. maillt.,in,'d in the amnlll1l~ a, ror the [lcriodr: that Lcmlcr n~qllire~: ; in"llrancc carrier providing thf~ in~lJr.'nce ::l1all he eho;,cll br Borrower ~:lJhjt'ct In r.t'lldcr'~: ,lprroval \l'h;ch :;hall nnt he llllreamn.,bly withheld. lr Borrower hi!.,; 10 main lain c()verag~ dt;~;crlhcd above. l.cnder mar. at Lendcr'~ option, ohlain (.:overage to prolect Lender's right!; in the I'roperty in accordance wilh para~rapll 7. All int.urance policie" and renewal" :;hall be acceptable to Lender and !lhall include a stnntlard mortgagc c[all"e. Lemler shall have the right to hold the rolicic" and renewal!:. If lender requirc:!, Borrower shall prompllr give to Lender nil receipt~; of paid premium" anJ renewal notice,:, In the event of In:;:;, Borrower "hall give prompt notice 10 the insurance carrier and Lender. Lender may make proof of Im;s if not made promptly hI' Uorrower. Unle~,s I.ender afld Borrower flthcrwi:;e agree in wriling, insurance proceed~ rohall be applied t'l re;,loration or repair nf the Property damaged, if the rc:;toratioo or rep,1ir is economically fea!;ible and Lender'" security is not le"r.ened. Jr the rc"toralioll or rep:lir i~ not economically fcasible or Lender's r.ecurity IVould h~ ]e,,,';ened. the imaJram:e proceed~ r.hall be applied In the sum!; r.ecIJred bj' this Security Ill:.trllment, whether or nUl then dlle, with allY excer.s paid to !inrrower. If Borrower aballd(Jn~ the Property, or dner. not answer within JO da;'s a notice from I.ender that the inr.urance carrier has offered to !Oettle a claim, then Lender may collect t!l(; insurance proceed... Lender may lIse the proceed.. to repair or restore the Property or to pay sums secured by thi!; Security Instrument, whether or not then due. The JO'd"y period will begin when the notice is given. Unle<.s Lender and Borrower otherwi"e agree in writing, allY application of proceeds 10 principal ::hallll!>t extend or postpone the due dale of Ihe monthly payment!; referred to in paragraphs I aod 2 or change the nmount of the payments. If under paragraph 21 the Property is acqllired by Lender, Borrower'!; right to any insurance po]icie!l and proceeds resulting from damagt: In the Property prior to the llcquisition shall pass (IJ Lender to the extent of the !l\lms r.et;ured by thi~ Secmity In"trumenl immediately prior to the acquisition. 6, Occupancy, Preservalion, ~Iaintenance <:Ind Protection of the ProperlY; norrow.er's Loan Application: Le<:lsehnlds, Borrower shall m:t:l1py, e!;tahlish, and lIse the Property as Borrower's princip,d residence within :;ixty days after the execlltinn of this St:curity !n:;ltllmenl and shall continue to oCCIlPy thc Property a" norrower'" principal re::idem.:e f(lr at le:lst one yt:ar after the date of occupancy, IInless Lender otherwise agree;. in writing, which consent :;110111 not bc Ilnrea:.onahly withheld, or unless extenuating circumslance" exi!;t which are hcyond Borrower's control. Borrower shall not dc!;troy, damage or imp:J.ir th~ Property, allow the Property to deteriorate, or commit waste on the Property. norrower shall be;n default if an;' forfeiture action or prot;eeding, whether civil or criminal. i~ begun that in Lender's good Faith judgment could result in forfeiture of the Propcrty or otherwi~:e material]y impair the lien created by this Security Instrument or Lender's sec\J~it~' intere!>t. Borrower ma}' t;lIre SlIch a defalllt and reinstate, as providt.:d in paragraph IR, br causing the action or proceeding to he dismissed with a ruling that, in Lender's good faith determination, preclude;, forfeiture of the Borrower'r. interest in the Propt.:r1)' nr other material impairmellt of the lien created by this Security In:arument or Lender'!l .<;ccurity interc:ll. Borrower !:hall al:.o be in default if norrower, during the loan application proCt.:~.:;, gave materially f:l1r.c or inaccurate information or statements 10 Lender (or failed tll provide I.ender with any material informlltion) ill connection with the Inan e\'ident:t:d br tht: Note, including, hill not limited to, reprc.<;entatinns concerning Bnrrn\\'er'~; occupancy of the Property .15 a principal re:.idellt;e. If thi~; Security In!ltrument i~ on a leaseho]d, lI11rro\\'er l:h;11I comply with all tht: provi:.ion~ of the lease. If Ilorrnwt.;r acquirer. fee title to the Prnpeny, the lea~;eh(Jld and the rce tille "hall not merge UII]e!lr. Lender ;'lgrce~ tn the merger in writing. 7. Protection of Lender'... Rights ill the Property. If TInrr9\Ver fails to perform the covenants and agreement" contained in thi" Seellrity ]ll:;lrllmcnt,' or therc is a legal 'procceding th;rt may significantly aHccl Lender'!; rights in the Property (mll.:h a" ;'l proceeding in hankruptcy, probate, for condemnation nr forfeiture or to enforcc laws or regulation:.), tbcn Lcnder may do anti pa}' for wh,llever is nece~....arj' to protect the vallie of the Propertj' and Lender's rights in the Property. l.ender's actions m:lY include paying any slims f,ecured by a licll whieh has priority over thi~ Security lnr.trument, appearing in comt, paying reasonable ottornej's' fecs :Ill.! entering on the Property 10 make repairs. Although l.ender may 1.11:e ,1<:tion" under Ihis p,lragraph 7, I.cnder dot.::; not have to do so. Any amount:. dishursed hy Lender under this p:lragrnph 7 ::hall become adJitlonal deht of Borrower roecured by this Secllrity In:;trument. Un]e,.... Ilorro\\.'er alld LcnJer agree to other term" or payment. the!lc amollnts r.hal] bear interc:ot from tbe dale of tJi:.hllf~cment at the Note rale and shall be payahle, with illtere~l, upon notice from Lender to Borrower rcqlle"tillg pa}"inent. fI, Morlgage Insurance. Jr Lender r<.:quired rnortg,'gc in~,llrance a.:; a condition of making lhe loan secured by this Security In"trument, Borrower l:h:1l] pay the premiums required to maintain the morlr..'Ig~ insurance in erfect. Jr, for any rea:.nn, tbe morlg.1gc in~urance em'eragc required hy Lender lap.~e5 or cca~e:; 10 be in eHecI, Borrower :;hall pay the premium" required to nhtnill co\'erage suh"tantially equivalent 10 the mortgag~~ insurance previolls]y in erfect, at a co~t :Ollh"t:mti.1lly equivalent tn the t"O~t tn Borrower of lhe mOrlg,1ge in:.llrance previously ill effect, from an alternnte mnrq~:Jge in:;lIrer approved by Lender. Ir !luh!ltantially equivalent mnrtgage in5urance cover,'J;e i~ not available, Borrower r,h:lll pay to Jxndcr each month a sum eqll.,l to one"lwelfth of the ye.'lrly morq~aRe in~ur:\f\ce premillm being paid hy Borrower when the in!::\lrance coverage lap::cd or ee:t!Oed to h~ in errcct, I.ender will accept, IIse and retain thc::e payment!l as a 111s~ re"erve in lieu of mortgage immrance. 1.0:':; re~erve p~ymentl: may no longer he rt.:f!llired, nt the opti(lfl of the Lender, if mortgnge in"lIrnnce cnvr.rage (in the amollnt ,111d (or the period tllnt Lender req\1ire';) pro'/icled hy an int.llrer approved by Lender ag"in becomef; available :llld ir. obtaincJ, BurrolYer :;ball ray the premillln:; reljlJircd to maintain lIlortgage in:;lIrancc ill errect, or to rrovidc a lo:'m n::;erve, Ilnti' ': requirement for rnurlg:lg': ill:01lrallCC en :n accord:lllce with allY wrilten agreement netween Borrower ant. ~':lH.ler or arrlic:lble law, C), In.~pecli(JlI, Lemler I)r it:'; agent lI\ay make rca:;onahlt: cntrit,:; upon ant.! ill:;reclion:; of the ProperlY. I.ender :;hall give Burruwer Ilotice at tlJl: time uf Ilr rrior tll :1Il ilJ::pcctioll ::pecifring rca:;ol1;lhle cau:;e ror Ihe in"pectioll. 10, COIIJemllaliulI, The proceel.h of all,' award or d.1im for damage", dire!.;l or con:;cqllential, in cOllnc!.;tion with any l.:ondemnation or other takillJ.: uf any part of the I'roperty. or for conveyance ill lieu of conuemnation. are hereby a!,,signed and ::hall be paid to Lender, In the event of a total taking of the Property. the proce,:J:o :,;hall he applied to the f.llm" secured by this Seeurity In::trument, whether or not tln:n dlle, wilh any excc,,:; paid tu Borrower. III the event of a pJrtial taking of the I'roperty in which Ihe fair market \'~llJe of Ihe I'rnpcrl)' i lTlmcJialcly before the takill~ i:; cqllal to or greater Ihan thc :ImOllllt of the r.\lrn:; !;ecured br thi!; Se!.:\Jril}' f!l:;trlllnellt immediately before the takinJ.:. ullle~ Burrower and Lemler otherwi::e agree ill writing. tbe :;l1m!; !ie!.:llreu hr llli!; Se!.:\lrity Instrument !l1J.'l1l be reduced oy the amount of the proceed::; lllllltiplied by the followiJlg fraction: (a) the total ammlflt of the :;llmf. !;ecured immediately before Ihe taking. divided b)' (b) the fair market ...al\J1: of the Property immediately before the taking, All}' bJlance :;hal1 be paiu to Borrower. III the evenl or :l partial t;lking of the Property ill which the fair markel \':'llllc of the Property immedi,'tely before the taking i::: Ie:;!; thall thc amuunt of the "ums sec\Jred immediately before the taking, unle;,:; Borrower and Lenuer otllcrwi:;e agree in writing or unle:;:; applicable law otherwise pruvide:;. the proceed:; ::hall be .1pplied to the ~;tlln:: ::ecllred by this Security Instrument whether or not the sums are then due. If the Property is abanuoncd hy Burrower. or if. rlfter 1111til'e hI' Lender to Borrower that the condemnor urfers to makc an award or ::etlle a claim for damngc::. Borrower fail:; to retopond to Lender within 30 Jays after thc datc the notice i" given. Lcnder it. authorizcd to collect and apply Ihe procceds, at its option. either to rC!ltorntion or repair ur the I'n1perty f~r 10 the ~llm:; :;co.:\lred by thit. St'cllrit)' In::trumt'nt. whether or not then due. Unless Lender and Borrower other\\'i::e agree in .....riting. tiny application of proceeds to principal shall not extend or postpone the due date of the monthly paymellt~ referred to in paragraph:: I and 2 or changc the amount of such paymcnt:;, II. Borrower Not Rele:J~cd; Forbearance ny Leutler ~flt a Waiver. Extension of the time for payment or rnodiril.:ation of amortiz:ltilJl1 of the sum:; ::"cllL'ed by thi:: Securitj' Instrument !:ranted by Lender to any :;Ilcce:;:;or ill interc:;t or Borrower ::hall not oper:ltc to rc1ca~:c the li,lbililY of the original Borrowcr or Burrowcr'f. ::ucce":;or,, in intere.";t, I.ellder r.h:JlIuot be reljuired If} comnwnce prOl,;ceJillgs a!:ain:;t any Stlcce!'.5or in intcre:;t or refu:;e to extend time for f';lyment or otherwise /TlIJdify amortization of the sum5 secured by thb Security Instrument by reason of any demand m:ldc b,' the lJriJ.:in;11 Borrower or llorroIVer'r, sucCe!"',sorr. in intere5t, Any forberlrant:e by Lender in exerci:;ing any right or remedy "hall lIot he a waiver or or preclude the exercifie of allY right or remedy, , , 12. Successors and A!lsjgll.~ BCllllld; Jllinl :Jntl Several I,iallilil}'; Ctl.~igners. TlJe covennntr. and agreemellt5 or this Secmitj' In:;trumcnt fihall bind and hendit the ::\1cce,,::or:; allu a::sign!; of Lender and Borrower. ::\lbject to Ihe provi:'1ions or paragraph 17. Borrower':; covenants and agreemCl1L'> !ihall be joint ond flevera1. Any Borrower who co-signs thi:; :-ircurity Instrument Illlt d()e~ 1I0t execute the Note: (a) is w'si!:ning this Security lnstrument only to mortgage, ,:r:1I\1 and COIl\'ey Ihat BlJrrlJI',cr':: intcre~;t ill the Propcrt)' under the term:; of this Security Instrument; (b) is Ilot rersonally obligated III pay the :;1JIl1S ~;eclJn:d by this Securitj' Instrument: and (Cl agrcer. that Lender and :IIlY nther Borrower may agree to eXlcnd, modify, forbear or make any accommouations with recaru to the term:; of tliis Security 11I:,;trllmcnt or the Nule lI'ithout that Borrower's con!lent, 13. Luan Charges. If the lmn secured hy thi:; Security In::trllrnellt ir. :;\lbjeet to a law which set:; . maximum loan chaq:e~;. and that law i:: final1}' interpreted ,,0 tll;ll the illlere::t or other IOrln charges collected or to be collected in connection with the loan exceed Ihe rermiucu limitf-, then (a) ,1ny r,llch lo...n charge :;hall be redm:eu by the amollnt neccf,:::lry III redllce Ihe eharge tn the pcrmilted limil; and (bl "'1Ii' ::um:; alread}' collect cd from Borruwer which exceeded permitted limits will he refunded to Borroll'er. Lemler may choof.e to make this refund by redlldll~ the principal o\\'ed onder Ihe i\'CJtc or by making a direct paymenl to Borro\\'cr. If a refunu redllcef. principal. the reduction will be trealed a:: a partial prepaYlllent without any prep:lyment charge under the Note. 14. Notices. AllY nolice to Borroll'er provided for in Ihi:; Sccurity In::trllltlent shall be given by delivering it or by m:liling it bj' fir!;t cla:;,.; mail llnle:;r, .1pplicable law reqllirer, \l::e of another method, The notice ::hall be directcd to the Propert}. Addrcr,r, or an}' other .,ddre::<; Borrower de~;ignate... br notice tn Lender. Any notice to Lender "hall be ~ivel\ b)' fir:a d.w; mail to Lelluer':'1 aJdrc::r. :;t.1ted herein or .11l)' other adurc:-.:; Lender design.1tes hy notice to Borrower. Any noticc provided for in thi~; SecurilY lnstrumcllt ::hall be deemed to havc been given to Borrower or Lender when gi\'ell a:; provideu in thi" p.Hagraph, 15. Governing Law; Severahility, This Security ll\~lrurnellt ~hall be :;o\'erned hr federall:iIV Ilnd the law of the juri:'1diction in whieh the Propertr i" located. In the e\'ent that till}' provision or c1aw;e of this Sccurit~' Instrument or the Note conflicts with applicable law. such conflict ...hall not affect other pro....i:;ion:; of thi:: Security In:;trumcnt or the Note which C.111 be givcn effect wilhollt tbe conflicting provit.ion. To this end the provision:; of thi:; Security In::tr\fITH'nt and the Notc :Irl: tlcd.Hed 10 h. ::e\'crable. I r~a.""18~IfIAl. " I G. IJfJrr(Jwcr'.~ Copy. ln~;!rlJmt'llf. 17. Tran.~fcr fir thc I'ropt'rt\. Of a Bcndici:lI Inlt:l'c!'l in Uorro\\Cr. If :dl or any p.ut or the l'roI'Nt)' or :'IllY intere:;t in it i~ ~old or tral\:;fcrred (or if a ht'IWrir:i:d illtcre~;t In UOrr\lWer I.., :;old or tran5ferred ami Borrower I:> nut a ll:!tIlral pc("o!ll wirtu!!lt l.cnuer'!; prior written LOII~cnt, Lender m:!}', at it opllon, require immediate {layment ill full or all :>\Jm:; !;et'llred by lhi" Sel:lIritJ' lll:;tnllnent. Ilowever, lhi" option r.hall not be ,~xerr:ir.eJ hy Lender if excrej~e j~: prohibited hy feder:d law ,,~; of lllc O:ile of thi.'lSeclJrity IIl:>trllmellt. If Lender cxerci::cr. thi" ofllion. 1.cllder "hall gi\'e I\lJrro\\'tr rllJtit'e of acceleration. The notice shan pmvidc a period uf Ilot Ie!;" lb.1n 30 Ja}!; from the Jate tile notice i:; delivered or mailed within which Borrower m\J~t pay all .'lllmr. ::cl.:llrl"d by thi:; Ser:uril}' In::trUIl\l'Ilt. If 1l1lrf(Jln:r r:Jil~ to pay the:;e "urns prior to the e.~piratiol1 (If thi5 period, I.ender 111 a)' i1l':oKe any remedie:; p','rl1litted by thi::; Sel.:urity Instrumenl without further notice ur demand on llorro\\er. IH, Borrower's Ril:ht to Reill~I::Ilc, lr Borrow!'r rneet~; rer1aln l:onditiol1", Borrower r,hall have the right 10 ha\'e enrorl.:ernellt or thi~ Sel:uril}' 11l~;lrtlmelll di~,Grllltil\\JL'u;1I :lllY time prior to tlLe earlier of: (a) 5 days (or "ncb olher period a~ applicable law lll:lY "pccify fllr reill:.tatcflIellt) hcrnr~ ::ale of the Property pUf5\lant to allY pOIVer of "ale (,;olllailled in thi:: Serurit)' IIl~:trllmellt: or (Il) elltr)' of a judgment ellfon.:ing this Security In.o;trllmcnl. Those condition;; Me that 1IIJrro\\'er: (a) paF; l.cnuer all :,lllllS whkh then wOllld be due under this Sccurity IlI"trumcllt and the Note ao; if IlIJ at't'cleratioll h:IU ol.:cllrrt'u: (11) 1..:1Irc..'l any default uf allY other covenant" or agn:emcllt,,; (c) pay!: all cxpen;.r:~ inclJrreu in cllfortinj:: lhi~ Security lw,tnunent, including, but not limited to, rea';ollahle attorne)'s' fee,,; :H\U (d) takt'!i !;\Kh :1I.:tion :1:; Lender molY rea$unabl~' require to as.surc that the lien of this Security Iw;trumcnt, I.ender':; ri~ht:; ill the Property ano Borrower'" obligation 10 pay the slims flecured by this Security Ill"trllment shall l'Ontinlle llllch:lllged. Upon reillr.tatement by Burrower. this Security lnstflJmcnt :1nd the obligation~ r.ecured hereby r.hnll remain fully crfcl.:tive :1~ if no acceleration had occurred. llowever. thi" right to reill~tateshalll\lH :Jpply ;n the I.:a:;e or at'r:cleratioll IIllUer par:Jgraph 17. II). Sale or NlIte; Change of Loan Scnicer. The Nole or ,1 PMlial intere!il in the Note (together With lhi" Security Instrument) may be wlu {Jlle or more limer. wilhout prillr notice to Borrower, A nale may re:mlt ill:1 chall~e ill the cntity (known ar. the "1.!J:lIl Sl"f\'il.:er~) 11l,1{ cIJller:t" monthly payment" due under the Note anu thi" SeGllrity In~trllrnellt. There 011:;0 may hc olle or more chanl:er. of thC'1.0:!1l Scrvicer unrelated to a sale of the Note. If there i~: a eh.lnge of the Loa II Servieer, Borrower will he gi\'cn written notice of the change in accordance with par3gr:!ph 1.\ 3bo\'c :llld applic3ble law. The notice will ~tate the flame and addrC['.!i of the new Loan Ser\'icer and the adure:;:; to which paymenl:; should he made. The l10tice will al~{) cOl1tain any other information required by applicable !;IW. 20, IhzardlJlI.~ Sululance!'. Borrower shall not !;all"e or permit the prer:ellce, \Jse, disposal, :;torage, or rele3r.e uf any 113zardollr. Subr.tallces on ur in the Property. Burrower :;hall nol do, nor allow all~'one else to un, anything aHecting thc Property lhat is ill violatioll of .1ny Environrnent.l11.aw. Thc prcr:eding two !ientence.'l rohall not apply to the prer.ence, use, or sloragc UIl the Property of small tPlanlities of I la7.aru(Ju~ Sub~tallcc:l that arc gcnerally rccognlzed to be appropriate to norm:!l rc::idential WiC" allu to m"inlenallce of the Property. Burrower "h.111 promptly I;ive LenJer written nuliee of any illvc..o;tig3tloll, daim. demand, laWSUit or other ;lctioll by any govcrnflltntal or regulatory agenc)' cr pri\'llte par:y in\'olvillg lhe Property and any Ila..o:ardOl15 Sub!'talll..:e or Environmelll:!l Law IIf which Borrowcr ha~ actual knnwlcuge, If Borrower Icarll5, or is notified I'll' 3ny governmenlal or regulatory authority, that ao:. reml1\,,,1 or other remediatioll or any IInzardous Substance affecting the I'roperty i:; llel.:c:;:;ary. Borrower !,hall promplly take all necc:;:;ary remedial actiolis in al,;!;Ord3nCe with Environmental Law. Ar. u"cd in this paragraph 20, ~11:m1fdoll:; Sub:;talll:e:j" arc Ilm:;e ~ubr.tance::; defineo .13 to~ic or hazardous suh"taor:cS by Environmental Law and the following r.uhsl:lllCC:;: I:a::oline, kero"ene, other flammable or toxic .petroleum prod\:..:t.o;, toxic pe:iticide" and herbit'ioe~., volatile .';ol\'l"llt!;, material" wntaining a~be:;tos or formaldehyde, and rauioactivc m:!terial:;, A.'i used ill thi:; paral;raph 20, ~ElIvironl1lental Law~ means federal law/1 i'lnd lawl! nf lhe jurir.diction where the Property j:; IOI.::lled that relate to hcalth, ~arety or environmental pflltectillll. NON-UNIFORt<.1 COVE~J\NTS. Borrowcr aud I.cllucr further t'O\'cnant and ngree 3:; followr.: 21. Acceleration: Remedier.. Lender .~hall j:;i\'c n~llkc III IJorflJ\\'cr prior III a(,;celeration fllllnwinr, Borrower's hrcach or allY ell\'Cllant or ar,reel1lelll in this Security Instrurn~nt (but not prior tn nccelcralion lJlldr.r parnr,raph 17 Ilnl("s.~ applicahle lal\' prndtlcs illhcrwise). I.ender .~hall notify lI11rro\\'er or. amnll\: nther thiller.: (a) Ihe ddallll; (11) lhe action re'1"ired to cllfe the default: (c) when the default m\lst be curet!; and (d) that failure to cure Ihe ddault tiS specified may result in ncccler:ltiol1 or the r.UtnS secured by llli,~ Security In!'lrlllllcnl, fnreclmure by judicial prncceding and sale of IIII' I'roperty, Lentler ,~hall rurther inform Borrnll'f:r lIr the rir,ht 10 reinstate nrter a(,;ecleraliol\ and lhe ril:ht to a,~sert in tile rnrec!llsure proceed in I: the llon.r.\islcllce or a default or any olher "cfelt.~e of Bnrrower tn acceleration :11\11 rorcclmure, H the ddnlllt ir. 1I0t cured ar. ,~pcciried, Lendcr at its optillll may require immediale papncllt ill filiI of all r.1l11l.~ r.ecured hy thi.~ Securily Instrument \\'ilhollt furthcr demand and mar flHec!(),~e lhi,~ Security IJutrlJlllenl b}' judicial proceeding, Lender r.hnll be I:nlitleu In colJr.ct all C\pcl.Her. incurred in (llluuinr, Ihe rCflledier. IHO\'ided in this paragraph 21. incluJinc, but 11111 limited 10, 3111lr11CYr.' fc(',~ :inJ (,;o,~t,~ of title evidence to the ek1ellt permitted by i'lpplir:nble la\\'. rower ~;haIJ be gl\'ell Ollt: t'llllflJrrned cu l( thc Note anJ or this Ser:urity : 1 ~ i. ' , CA:-;~: Hi I: ! -.~'.it. - '.~ ;1 'l"<. I:IJMMIINW,:AI,TII 11(' ,"'f',' 1:IJl1NTY IIF 1_:U~1HI' r'{LA~'iIJ '.' .\ ~j : f\ : L,f.o: I.;A!" f'j'ft..L MIJh'l";f",',I' : -, ~~, ',o : I 'I'::. RALlIC l..1i;:f-T;uRI i-:r {,l. ST,:V,: '1i1l1,,;i'U:R CUMBERLANli County. f'€-'nnE.;yl"';.lfll,"'), '.Ir: to law. ::::;~JYs. the t,,'lt.n1.rl ~:~I_~t1L!,ti':r;:- upon _ RAe) (C G!H<GOEL____.____.___.u-.- defend<Jnt. at J 7<2: 'i~t'1 HOUE:::. ':~:_ : ;!',' l';:}::!f:,. a-+~ G'5! ''';ILI.U'..J [.JF::JV1-~ ;:;ij,\L; CAI1I,[~';U:. f'A 1'/'lll J County. l:'enns'/l....o:-I::..a. :J", h~,r;;j:.:,_, I',' [,.r it 1 :-'j ;-'.:'..,'~:~_'.. :~Li~~rl_~f ,:<f ~ '-,' :. ;" ,_~ . ), 1 ',' '''c- r rl ;.1(:,:':::: c;.;. fl':'"] "',,;-. ,r..i- ',.{,;j~ :c~...rvi::-'j t hiO' ,'j ~'J:: (.: ['-~~ G _"L;:~~ , r"l; t-l !_~l:...;:;:L;,tl:, ,Ji 'r" ~~A~ITI= t(Jq~ttler with ~IU'rI~:~ .:1 truE' 3nd atr.est.c.:j c:c~)r"/ e,.:!' I ;,':. f:'):~: :_/', ~::-:-- '.', :r::; II;;>: and at the sanh':" tl,'li~ ,jlrec~_lrl:J ~.!l~'" " 1.,,:,..--:, :.;~I:-. t,- t_:--V? crJnt~~'nl--_s t.h.;:';-,;::'c;=:, :~tll"'riii' s Cost_,,-': [I(tl:-:ket l no ~;er'}ic(? - Aiflda'Jit ::iurch.] 1yf.:.' :'-',,1.:,'7) J. =>"1 ','".', ::, ('i<J :.' ' '," ,.': ~ // /./d "" r/ ~~. ~ f""1,,~S~;':~~~1~._ _~____ _' _~ ".~. I...r:~ ,:'1''::: ... 11 r:', --7:' .~:T.-:-::r7I' j~ATl'LE':;~,,\~;, .;~.:~l:;:i~~L!.;C:, Sll!'lL!':: I.. ,j;':1 t (:1 -j I 1 ;~~ '? 1''-. :-;wnrn and sub:;::I~rj [,:,';:":1 i:, .;;' :f ;~, 1 .: th~s /,' " '..):fl, d,. day ("Ii l'J_S_I.:_~ A,[', '- 1.'1" C ') kU. ",),JJ"/ 1 Proth-:'L~"~.lr 8/ ~2\L,-,,_dc-'1~~ ~._ ~.' ,,' r: 'J '. :,' ::' ,',,:. r :. 1. .: . ,~. "1 i;' i ~. ~. '-' :; ~;,y:' I.':i > CASE NU: 1~~b-0'1~-,0= I' CIJMMIJNW>:AI,TH UF I'HIW:YLV 1,11 I A: CI.J1INTY LW CUMHI',fd.ANL' IOF: I:ArrrAI. MUHHjAI,F: :.::<1,:'1 !.'.X',---. v'.:.~. RADIC GIlI':IOiJRY ET AL R. Thomas Kll.ne Sherlif. ""ho b.21ng rj,;ly slio.orn ac:ce,rding to law, says. t.hat hi? m::Jct:;> ,"3 d~li.~'?nt ::;.?;:Jt-r:h ;:J;-j,::! ~nQlJi!-y flJr the loI~thin named defendant, to Wlt: MAI;',~"GA JIII.IA bur, was unable to loc03tE' liE.'r 10 ~llS b~lllWj(:k. l'/8 ttlerefr)re returns the GUM!'I.A (NT. MIJHT FUll>: NIJTI.CF: NUT 1"UIJND . tiS to + he wi "_hl;": n~pr.ed .:!~ier:d;oli.J~ MAC/.1JGA JilL! A -' DI':FT. NU I.lJNI;I-:H rn~SI[II':S AT ABUVf.: AnPE!-:J~. !'lAY I. (V~Jllli...SI:Ii8J!I.'lJL.!!B.t.6.'-_m____~"_'__'_____"_"___'__~___'---.~ Sheriff's Costs: Docv.etinq Service - Affidavit Surcharge -:;':'0 arl='..~,e:s;~ t..1/:0 . rj)lL) . (~r;:,1 =:.00 ./ ,/(~..>__c/> ~.r';-r',:;" ..j f\7~ i t:or;ld;::' r.T.irl0:"-:;rlerrri-------~~.-- "Y8:-TFli l'jATTLE1'lf~?j. C.;S:CLlibr:RC" :=~![~lLht:L eJ~J/o~~:/: '3'::)c. SWllrn and subsc:rib.;..:i ,t.o heforo:::- ill;::' .~ J this ~_ day "f ."1' I. l'-9_~h.[J. --~-ll L<--;~r'~:l~(~~f: ' UJff ~ - ~. .- r/qh 9(; elL (iUl: L NOTICE 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. COURT ADMINISTRATOR - CUMBERLAND COUNTY CARLISLE, PA 17013- 717-240-6200 ) 001: n~tiul\~( lJ~e and non'uniform cllrll)' inr.trurncnt covering real TillS SECUHIlY IN~;T"'I:-.tm'JT o.;nrnbim':; \lI1i!Ofm t'(/v{'llalll~ r covcll:lnlr. with limited variatlo, hI' j\lri~uit,:ti(J1I to o.;oll:;litule a uniform property. UNIFOI~M COVENANTS. llurrowcr':lllu l.cnucr L'O\lI:n:Jnt aile! ;q:rec as fol1owr.: I Payment of I'rincil';d ami IllIClc.st: I'rcl'aymcl1t nllll L:llc Charge.~. Borrower r.hall promptly pay 11'11('11 due the principal of and intcrc:;t on the lId,! cvidello.;cd hI' the Note and allY prepayment and latc ch,uge:; ulle under the NOlI:. 2, Funds fOf Taxc.~ and ltl.~IHall(e. Sllbjf.:t.:t to :IppJicablc [;\"V Of to a written waiver hy Lender, Borrower :;lIall pay to lcnuer 011 the J.l}' monthly payment:; .He uuc \1I\(.Icr the Nule, \Jlltil the Note i!l paid III full. a r.um ("F\Jnd!:~) for: (a) YCMly \a~C3 al\d a....::t';,!:!nC'tlt!: wllidl may' auain priority over this Security In5trumcllt a5 a lit'lI on the Property; (b) ~'e.lrly kl';dll)ld pa/'ment!: or r.ruund rent" 011 tile Property, if any; (c) yearly ha/.ard or property in:;uroll\l;e premium!:; (d} ycarl~' fluod il1!:\IralH;t~ premiulll!:, if an}'; (e) }'early mortg:,gc in!:\lfall\:e premium!:, if :lny; anJ {f) nny ,,\Jill!: papb1e by Borrowcr to Lenuer, in :lccordallee with the provision!: of rara~r:lph B. in liell of the p:lymcnt of mortr.:l~e ir-,.;llfallcc premium!:. These item!: are c:llled "Escrow Item!:." Lender may, at :l11)' lime, cullc!;t and huld hHld:o ill all amuunt lIot to cxceed the m:uimum amount .1 lendcr for a fcuerally rel.,tcd mortGa~c 10:111 may require for BllfrtJl','(.'r'!: e~;\:rnw account under the federal Real Estate Scltlement Procedure:; Act of 1974 a!: :1melldcd from timc to time, 12 U.S,C, 52601 rf Hq, '''RESPA''}. unlc.<;<. another law thai applie" to the Fllnd;; roct" a le~.~cr, amollnt. H 50, Lender may, at any time, collect nnd hold Film.!!; in an :!mount not tll e.n:eeu the le5~er amount. l.em.ler m,'y ('"timate the amount or Funds uue on the ~l:d!l of currcnt dOl!.' and reasonable e.o;tim~te!: of e~reIlJit\Jre:; of future E.--:erow ltem~ or otherwise in nCCOf(.hm:e with applicable l:lw. The F\Jod~ "hall be helu ill ~n in.o;titlltinll wIHj!;e uepo!:it.o; nre im;ureu by a feoernl a~ency, in!ltrurncnt:llit)', or entit}' Oncl\Jt.linl; Lenuer, if Lender i" !:\Jch an il1!ltitlltion} or in any Peuer:!1 Itome Loan Bnnk. Lenuer :;]1:111 apply the Fund" tolpay the I:.:.crow Item!:. Leuder may not chnq~e Borrower ror holding ami applying the Fundg, :llIllu:llly :lll:ll}'~ing the e~crpw "ccount, or verifyin~ the r'.[;crow Items, unlc:".!l Lender P:lYS Borrower intere:;t on the Fund!: and applic:lble l:lw rcm1it.r. Lender to m:ike sllch a charge. However, Lender may re'Jllire Burrower to P:lY :l one-time chnrge ror an independent.renl e"tate tax reporting service used by Lender in connection wilh thi" lo.,n. unle,,!: npplic:lhlc b\~ provide:. olherwi.~c, Borrower and Lender may :lgree in writing, however, th~t intere"t "b.,1I be paiJ on the Fum.!!:. Lender "h~lI Give to Borrower, without charge, an allllu"l :lccOIlIlting of the Fund!:, showing credits anu debit5 to the Fund;; and tbe p\lrp05e for which each debit to the FllllC.J" (\'a" marJe. The Fund:; life pled~cd a;; additional "ecurit)' for :Ill sum!: !lccllred by this Security Instrument. ' If the Fund" held by Lemler e~ceed the amount:; permitted to hy 1l('ld by applic"ble law, Lender shall :lccount tn Borrower ror Ihe eXce!:s Fund!: in al:cofl.l.1nce with the requirement:: of applic:lble Inw. If the amount of the Fund;; held hy l.ender at :lny time i;; not sufficient tn pay the ES!;f{)w Itemr; '....hen due, Lender may foO notify Borrower in writin~, :11\0. in rollCh l:a!:c Borrower shall r:1Y In Lender the amount neccr..:;:lry to make up the ddicicney. Borrower $h.,11 make Ill' the deficiency in no more tll:ln twelve monthly paymeots, at Lender's sole di.o;cretion. ' Upon payment in filiI of nil Sllrnt. st:\:ured by thi:; Secllrity Ill!ltfllment, Lender shall promptly rdund to Borroll'er :In)' Fund!: held by Lender. l[, under r:lrar.raph21. L....nder :;hal1 :ll:quire or rocll the Property, Lender, prior to the :lcquir,ition or "ale of the, Propenr, sll.,ll :lpply all}' Fund" held hy Lender at the time of ncqlli$ition or SOlIe a" a l:redil :lJ:aio;;t the !:\1m!: ~ecllred by thi:; Security In~tflllnent. J. Application of P3}'lTlelll~. Unlet.... arrlic.,ble law proviuC!'l otherwise. fill pnymellts received by' Lender under p:lr:lgraphr; I anu 2 shall h :lpplicd: (irst, to :Ill)' prepnj'ment charge:; due IJnJer the Note; second, . to amounts p:lpble under p~lragraph ?:: third, 10 intere:.t due; forth, \0 principal due: and la:;t, to :lllj' Inle charges due under the Note. 4. Ch3rge~; Liens. Borrower sldl [la}' all t~Xe!:, "s~e;.;;mellt5. charr.e::, fine:; and irnpo!litions attributnble to the Property whieh Inay :1\\aio priority ewer thi~ Sccurit~. II\;;trulllcnt, and lea!:ehuld payment:; or ground rents, ir any. Borrower ~;ll~ll pay th~"e obli!;atilJl1:; ill the manner provided in paragr~ph 2, or if not paid in that m:ll1ncr, Ihirroil'er "hall pay them on time tlirectlr to the f1cr.o;oll owed p,'yment. Borrower shall promptly [llrni5h to Lender all notiCe!: of amount" to be p.,id unuer tlli;; paragraph. If 130rroll'er mnkC5 these paymcnt" directly, Horrower rohal\ promptly f\lrni!:h to Lender rel:cipt" evidencing the payments. Borrower !;h~1l promptly djr.cbaq;e "nr lien which ha5 priority over thi!: Security In5trument unle:'o$ Borrowcr: (,,) :lgrec" in writing 10 the p~yrneot or thc obligatioll 5ccured by the lien ill a manner :lccept3bl.: to Lender; (b) contests ill good faith Ihe liell by, or defcnd" ag:liw;t cnforcement of thc lien in, leg:ll proceedings which in the Lender's opinion operate to prevent Ihe enforcemellt of the lien; or (c) secures from the holder of the lien an agreement sati:-;factory to Lender ~tlb()rdinatin~ the lien to this Seeurilr Instrument. If Lender determines tbat any part of Ihe Property i!: r.\Jbjeet to a lien which may attain priority over this Security Inslrument, Lender may gi'{e llarrower :I noticeidcntiryifl~ the lien. llorrower ::;h,,1I s:lti,,[y the lien or take one or more of the ac~ions set forth ahove within 10 d~ys of the giving of notice, 5, Halard or Property Il1s~lfal\ce. Dorm.....er !;h:lll keep the improvements now existing or hereaher erectcd on the Property in"ured ag"ill:-;l lo:;s by lire. hanird.o; included within the term "extended covera~e" and aoy (1ther hazards, iocluding flood:; or noO/Jinn. for \Vh~~~encler require:; in.o;urance. Thi!l :insurl\nce sball be FORM JOH V."len 1.0 (1Il"'Jl r.g. J~' 8~':::::lnl1l.1. \'(\~ rn"int~ined in the ~rnO\llll'" a, fllr the l't'rirJd"i tll.lt I.ender 1"'!llir"::. ; in"'lIranCt~ c,'rrier providing tIle in...urance ~,hall he c!lo"ief! or lIorrow,.r .';llhj"ct 10 J.':rlder'.'; ,'['rrovaJ \\hich :;!i.,llnot he llllrea.';ol\.,hly withheld. If Borrower f.,il... to rn:linlain co','eraJ;c (k~,cribed Jh(lvr. Lender may. ;\1 Lender'" option, oht.,ill CO','l::r.lj;C 10 prntl::d Lender'" right:. in the Property in accmdarlo.;t~ with f1:Haw,'ph 7. All ill:.\HanCe polidc.'; and rCI\l::wal" :.hail k acr:cpt;lb:c to Lel\der ami :.hall include a :.landard rnortgnge cla\l:;e. Lender :.hall h;we tile right to hl)ld th~ f'olir:it::. :lnd rCllew:lI:; If lender relllJire:;. Borrower ...h<lll prompll}" give 10 Lender all receipt:; of paid prcrnjul1~~; anJ rCllew.,1 nntke~:. [1\ the event or 10:;:;, Borrower r.hall r.il'e prompt notice to tbe ill:.ur:lIlce carrier ami Lcmkr. Leuder mOl)! make pl"Oof of 10:;:' ir llot made promptly hr Borrower. I Unlc:",:'; Lender and Borrower Ilther\\'i"ic agree ill writing, i[l:;\Jranc~ proceed:; :;hall he 'lpplied tfl re:;tnration Of rC"pair or the- Property dall'lal:,;d. if the le:;loralion or rep.lir i:; eCfl[wmic:Jlly fe.l':ible nnd Lender',; r;ecllfity is not k:.<;cned. Ir the rc:.toration or rep"ir i... [lot ccnnnmic.,lly f!",15ible or Lender'... !Ocwrity wO\lld ht: Ic,.:;ened, tho: in....ur,lnce prOl.:eedr; !Ohall be arpli-:d In tllc :;1I1l\:; :.ecllred by thi:; Secmit}, IWJlrllrnent. whelher or nllt then dlIC. wilh all)' e~cet.:. paid to Borrower. lr Borrower abandon:; the Property. or Joer; flot nn:;wcr within 30 day:; " notice from Lel\der t1lat the in:;m.1nce carrier lia:; orfered to r;cule a cLlim, then l.emler may coIled lb,: ill.'lUfllnCc proceed:;. Lcndt'r m.1Y IJ';C tLe proceed,; 10 rep:'Jir or re:1IOfC the I'rnrcrlr or to pay !OUIn:1 r;ec!lred by thi:. Securit,' Iwitrllmcnt. w1\o:thcr or nnt then dll':.'[ !It: 30-d,,}' p...riod willlwgin when the noli(.'e i.'; given. Unlc!:!': Lender :Jnd Borrower ot1\erwir;c ;1I::rt'C' in writinr" allY Jpplicati(Jr! or proceed:; tn rrincipal "halll1lf( extend or po:.tponc the dlJe date or the mllllthly p:lyment:; referred 10 in p:'Jr.lgraphr; I .1rlJ 2 or chan~e the amount or the rayment.... If under p.lr:Jr,r,lph 21 the Property i" acquired by Lender. Borrower'... right to any insurance policie:; alld proceed... re:1uitinr, from d;lI11,lge to the Property prior to the :lC{lui"ition r.h:JII p:l~:!': to Lender to thl:' extent or the :;urn...r.ecured hy thi:. ~;ec\Jriti' In:>tr\Jlllcnt immediate!}! prior to the acqui.'.itioJl. 6. Occupancy, Preservation. :-'hintell:lIlCe aOlI Protection or the Property; Borro\\',er,'5 1.0311 Application; Lea.o;elwld<;. Borrower ~!lall Oo.;GllPY. c:;tahli:.h. :llld lI:;e the !'roperty :I:; Borrower.... princip.d rer.idence within sixty day... after the e,cclItioi\ or thir. SCCllrit}' Inr.lnllnent :lnd .o;hnll continue to occllpy the Property :1:1 Borrower':. principal rct.idenl'e ror al lca!Ot olle }"r:ar :lrtr:r the dale of occupancy. unle...:; !'/:nder othef\\'i:oe <lgreC!: in writinj;. which con~('nt :;lInll nut I~c unren:;ollahly withheld, or unl~ exten\latin~ circumr;t:uwe... e~if,t which .1fe heyond BorrowN'~ clJntrol. Borroll'er :;11<111 not de:1troy. damage or imp,lir th~ Property, allow the Propertj! to dcterior.'te, nr cOlllmit \\"~:;te nn lhe Prop~rty. Borrower ~;h<l[l be in deralllt ir an)" fodeitllre action or pruceeding, whether civil or niminal, i:; be.c:1Jl\ Ihat in Lender'r. good fnith judgment coult! re:;ll!t in forfeiture of the Properly or ntl:erwir;e rn;}tl'ri:lIly impair tbe licn createJ by thi:; Set:\lrity In5trurnent or Lender':. :;ecmity intere;.t. Borrower Inn}' Cllre ~lIch a ddn\llt alld r('in:.l:lte, 01<; provided in p.1ragraph IB, hr c:\lIt,ing the action or proceedinr. tn be di.';mir;r;.~d wi:h ,1 rllling that, in Lender'.'; good faith dctermillalioll, preclude.:; fnrreiture of the Borrower'~ interr:r;t in the I'rnrellj' fir other fT\:Jleri.11 impairment of the lien created hy thi~ Secllrity In"trulncnt or Lender':1 ...cclIril}" intere:.t. Borrowt'r :,11.111 al:.o he in default if Borrower. durinJ.; the loan application proco:,.:.: g.1\'l: materially r.1\~,e or inaccurate il\fntll1ntiol\ nr ~tatement~ to Lender (or failcd III provide Lellder with allY rn:ltcri:Jl illfnrl11:ililll1) in lflllllt'clillll witll II,,: Ilran e\"idcm;ed h)' the Note. indlldinl:, hilt not limited to, repr(,~clltatif)nt. cor:eerniI11: Bnrrlll\er':; O("C111':lIlCY or Ill!' I'rrlpertr a:; ,1 pril\cipal tct.idcllce. If thi~: :)ecmity ln~trument i~ on il le.1:;e!fo\d, l\1,rrll'\'l"r .':IJ:dl cOlnply with ail tIlt' rrovi:.ioll.'; of lhe Ica!;e. H lIo((O\\',;r acquire.'l fee litle to Ihe I'rop!'rtj", tl.e leil',chntd :1[;<1 tiLe fe(' til!t~ :;h~dl ont Illc'rge w\le!::. l.ender ar.rce:. to the merger in writinl:. 7. Prolection or Lender'~ Rir:hl~ ill th~ !'roperty. If Borroll'er faih to r('dorm the covenant:; and af:reemcnl!: contained in thi:. Secmity rl1~,:nlrne[\t"llr tl10::r(' ir; a 1('li.,l \prllCeeJirll: that may "il:nific,lntly affect I.ender'" right.:. in the Prorerty ("i\Jch .,r; .1 prnrccdirlr. in h111\:rllrtcr, prnbale, for cnndcmnation or fodeiture or to enrorce 1.1W:. or reglll:Jtinllt.). then l.ender 01;1i' do aod p.,)' fur Wh,ltC\'er i:; nece!~,;arr to protect the vallie of the Property and Lender'r. ri~ht" ill the I'ropen)' Lender'!: aclioll.'; may indudc paying allY "um... ::ecured hy a lien which hn:1 priority OV{'f thir; Se(;Urilr IIlr;tnunenl, .1pr~arilll: ill C(llIrt, p.,ying re:'J.';onahle <It!orner,'l' kef. allJ enterinr. nn the Property 10 make rel'.1ir~, AI:lHlII!:h I.ender mar t.1ke :lcljOll:; lInder thi.'; p:lr:lr,raph 7, Lcnder doe:. not have to do r.o. Any amountr; di~;h\Jr~bl by Lt'nda 1I:1der tLi~; rar.1r:r~rh 7 ::11.111 h{'come addilional deht of Borrower ::ecurd by thi:; Se';llrity lw;tr\J:1'l:llt, Unk~.:: IloHn'ser .111J l.ender :q~ree to other lerrnf1 of p.1}'ment, the~e amollnt:: r;1l:l11 be.lr intere~.: from the dat': nr di:;hllr:;ement ,11 thl: t\ldl: rate alld :.h,111 be p.lynhle, with intere:.I, \lpon f1(1ti('C' from Lcnd<:r In IILIHo'S,.r n''1W'~tillr. r:1j'ln('1\1. 8, :-'fnrtJ;:lI:c IIl~ural1cr. If Lem!er p'IPliled 1ll<)ftl:.1t:e iW;\lrance <I!: a cl111Jitio!l of making the lnall :;ecllreJ by thi:; Security Iw:tr\Jrnent, jJll(fOWf;r !:hall 1'.11' the premillm:. required to maintain the mortgaJ:'': inr.urance in erfect. H. ror an}' rea:;on. the fllortr,,'l:(' in:;IJfal\cc cllver:lgc reqllired hy Lender lapr;C!; or ce,l~e:; to he in errect, Borrower :',!1.111 par ILe premium:; rt:'qllired to nht.lin w';rr:ir.e ~:lJh';t"llti:lll}' equivalent to the mortr,:l~e in:Jllrance pre\'iolJ.'~[Y in effecl. at .1 Cllst f,\lh.;t.1ntially eqlli....1lcnt to the l'O'lt In Borrower or the mOrlg.lgc il\r;Urancl: rreviou...ly in eHect. rrom an altern.,te rnnrt~.lge in~lIrer .1pprn\"cd b)' Lender. If f.llb:;tantinllr equivnlent mortr..lg~ inr;\lrance co\'ernge i!O not .'J\'.lil<'lble. llnrrlJlI'er shall pal' tn LendN each month a f1\J1T\ equ.l1 to one-twelfth of the yearly mortgar:e in!:\Jr,lnCe premium l1einr. r.1id 11,. l\orro.....er wh=n lilt' iw.llrance coverar,e lapt.ed or ce:l~ed to he in efrecl. Lender will accept. \J~e <IIld rel.,in th('~e p.1}'rneilt:. .1~ a 10'::; re,;ervc in lieo or mortgage in!:lIrance. I.(lS~ re5erve payment;, ma,' no lonr.~r be required. 011 the op~jor! of the Lender. ir mort~.1r.e in~,\lr,lnCe covr:r,lge (in th~ amollnt and for the period th.lt Lender rer'j\lire:;) provided hy an in:;lIrer <lrrroved hy Lender ac"in becomer. /1 /' / ,/ ..- available nnd i~ IJbtained. Borrower ~hall [1.1)' the rrcrnilll1l~; rC'jllircd to lllaintain nlorlgal:e iw;uc.lnce in errect, or to proviJe n lu~:; rC5ervc, \luti' '; fequirt'n,enl for m(Jrlgag~ ill";Uf.1IlQ: ell '1\ accorJam:e with allY written agreement between Borrower :lll<. _,":IlJcr or ,'rr1i<::,hle /'11\', ", I). 11I~pectioll. Lender or it:; agr:nt may make r(:a~.llIlahle cIIlric!. upon and in:;pcdion:; of the Property. Lender r,hall llive Borrower Ilolkc al tbe time, of or prior III all ill!;pct;tiol\ !;peo..:if}'illl: rC;Jf,onable C,lUr,C for tbe ill"pe..;tioll. 10. COI1Je/llll;)tioll~ Tht: prucced!; of .111Y award Uf ,jaim fur Jam:ll;c::, direct or COIlf.cq\Jcntinl, in wnncction with :H\Y condemnation Of other takillg of any pal t uf the l'roperty, or for CUllVCY;IIICC ill lieu of condcmllation, are herehy a~",il:ncd and r.h:1I1 be raid to Lender, In the event of a total t:lkin~ or the l'roperty, the rr()(.:er~u~ ~;h;llJ be :lrrlied to the ~um!! :;ccIJrcu hy thin Security !n:;trumcnt, whether ur !Jot thcll dllC, with :'lilY e.~C('fo:O paid to Borrower. In the event (If a p:'lnial t:'lking of the )lropr:rty ill which the f:'lir rnarht \'.11\JC ilf tile I'rnperty inHneJi:'ltcly hefore the takinp, i:o c(jllal to or greater tllnn the amollnt of the :ourn:o ~;e.:ured hr ihi:o SeclIrity In:;trulHcllt immediately before the takinJ:, llllle~;:; Borruwcr and LenJer Olherwi:;e ,'r.rcc in writirlr" thc ::lJm:: :;ecllrcr) by thi:o Security lll!;trument :oll:lll be reduced hy the amount of the proceed!; ll\u1tirlicrl b}' ttn:1 fotlowiR[: fractil)ll: (a) the total amollnt of the sllm:o r.ecured immediately before the taUnp., divided by (1)) dIe f.lir Il\:'lrket ','.1~lJe of the Propeny immediatel}' before the t<lUng. AllY balance r.hall be paid to Borrower: III tll(: evenl or a partial lOlking of the Property in which the fair market vlllue of the Propeny immediatel)' l~crore the taking i:; It':;s'than the alllUllllt of the sums r.ecllred immedi3tel~' before the tnkinJ:"ulller.~ llorHJII'I:r "nd I.emler otberwir.e Hgree in writinJ: or unlc:;f, applil.:able law otherwifoc provider., the pruceed:; r.hall bc applied to the '!;1I1ll~ :;eeurcd by this SeclIrit}' Iii:;lrllment whether or nol the S\Jmr. are then dlle. I[ the Property i~; abandoned by llorroivcr, or if. atter nuti!.:e b}' Lender to Borrower that the condemnor oUerr. to make:lll award or ::enle a claim for d;'\m:lger., llorro\\'er fail" to rer.pond to Lender wilhin 30 days after the date the notice i:; r.iven, Lender i:'i 1l\Jlhori1.cd to wlleet and appl}' the proceedr., at itr. option, either to reslorati,oll or repair of the Propert}' I\r to the r.ll,m:; f,eclJred hy tbi:; Security Inr.trulllcnt, whether or I\ot then due. ; , UnlC!'.!; Lender and Bnrro\Vcr otherwi~e~agree ill writing, an}' application of procced:o to principal shall not extend or po:otpOl\C the due date of t,he monthl}' p;'\yment:; referred to in parai:rnphs I and 2 or change the amOl/llt or :;\Jcll pa}'menl5. i II. Borrower Not Relea.-;ctl: Foruearance By I.elltler Not a Waiver. Exteilr.ion or thc time for p;lymellt or mr)diricntion of amortization or the r.llms r.ee\Jrcd by thi" Scellrit}' Imtrllment granted by Lender to any :;ucccr.:;or ill 1nter(':,t of Borrowl'r r.lwll ootoperale, to n:lea:;c the linbility of the ori(;inal Borrower or Borrower':; r.m:ce":;or,, ill intere.-;t, Lelldcr :;hidl Ilot be reqllired to commcnce pr(JI,;eeuings 3gnin:;t ony succe....sor in illtcrer.l or rduroe to extcnd time for rqyrncnt or olherwiroe motlify amurtization of the :;\lms r.ecllrcd by this ~ee\Jrity lll"trurnent b}'. rea:;OIl of illlj' dern"nd m:lde b~' the origillOll Borrower or Borrower's r.uccC<....ors ill interest. AllY forbear:tllce hy Lender in exercir.inJ: :lny right or remedy r.hallllol be a w:liver or or preclude the exerciGe of any right or remeuy. 12. Succes..mu 3nd A.~,~ir.llS BilllllU; Joint :Il\d Se\'eral I.i:tbilitr: Cn..~igller;'. The covc~nilt:l'and anreemellls or thir. Securit}' lll~tr\lrnent :;I\all hinu MId l1t~ncrit the r.\ICCC:;~or" :Illd llr.Sil:ll~ nf Lender and Borrower, r.\Ibject to the provi:;iOll!:: of p,1rOlgraph 17. Borrower'" covcnantr. alld agreernents r.hall be joint :tod r.evcral. Any Borrower who !:(rr.ir,ns thi:> Security 11\~lrllmcllt lHlt doer. Illlt execute the Note: (n) is co.signing this Security Illr.tr\llllent only to 11lort/:age, grant ;l1\t! t:IHlI'Cj' that Illlrro\\'er':! illtere~;t in the Property under the term:! of this Sl:curity Inr.trurncnt; (b) is llot pcwlJ\all~' ubligated to pay the !lIIIIlS ~;c(;\Jred by thi!! Security In:otrumellt; and (c) ar.rcc~ Illllt Lcader and :lIiy other lJorrnwl'r Illay al:rce 10 extelld, modify. forbcllf or mnkc any lIcCfll11fnod:ltioll'l with rel:ard to the lerm~; of tliin Security 111~;trllrnellt or the Nutc without tllnt Borrower's cllnr.ent. 13, 1.031\ Charr.e.~. If the 10;111 r,eCIJrcl/ br thir. Security In::trlllllent is r.ubject to a Ill\'( which set!! . 1Tl:lxi mllll\ loan chargr~s, nnd that law iro finall}' interpreted, r.o that the illterc:ot or other loall charJ:cr. collected or to be wllccted in cOlll\ection with the 10010 e~ceed the rermitted limils, thell (al any r.llch loan clinq~e fihall be reduced by the amount ncce~;roar~' to reduce the charr.e to tho:: permitted limit: nnd (Il) allY r.\lm~ alreauy collected from Borrower which exceeded permitted limits will he refunded to Borrower. Lender may choose to make thi:; rchll1d b}' rcdlldnl: the princip;ll oli.eu l'llder the Nolc ur by making a direct payment to Borrower, Jr a rdund redllce:; princip:ll. the reduction will 1)(~ tl'('.1Ied n~~ a p.'Htbl [lrep:Jyment without an}' prepaymellt eharr.e under the Note,' i' " I.f. Notice~. I\ny notice 10 Borrower rrol'ided for ill tlli:; Security In:ltrument r.h"lI be given hy delivering it or by mnilillJ: it hy firr,t cla:;s mail IJIlIe..;;, applic.1blt.' law r('!IIJires \lr,e of "nother mcthod, The notice r.hall be directed to the i'ropr.'1 ty t\ddrc~", or :lIlY olher addre:;~ Borro\\'er UC!;igI1,1tC" by notice tn Lender. Any notice to Lender r.ll"l! be r,ivw by firr.t c1a~,,, nlOlil tn l.ender'!; addrc:;~ :ltated herein or allY other llddret.s Lender dc:;ignatcs by notice 10 Borrower. An}' notice: pwvidcu for in thi~l Sr.curity lllr,trllmellt roh,111 he deemed to have been given to Borrower f)r Lender when ~i\'Cl; n~prnviJcd ill thi:; parar,raph. 15, Governing I.aw: Severability. 'lhir. Security 11I~trlJmr'nt ::11"U be f,ovcrned by federall:l\\' and the law of the jmir.diction in I'Ihich the Prflrert~' Is It}cated, Iri the r:\'ent th.1t "ny prO\'j:;inn or clau!le of thi:; Securit}, In,,trllmcllt or the Note conflict" with applicable 1.,w. r.\Jch clll1r1it:t roll"ll lIot affect other proviroiollr. of Ihis Security In:;trument or the Nute which C,'II bc l:iven r.frcct without thc conflicting prnvir.ioo, To thir. end the provi!li{Jn~ or thiro Ser:\lfity II1r.trulllr'llt and the NlHr. arc dr.dilred 10 bl;'. r,r.v('rahle. , r"~.(,O'eWIII.I'~ .~ 16. Burrower's Co!'}'. ([)Wer ,<:haJJ be p,iven (Jill'.: l,:onformed co .,r the Note and of this Security Imitrumcnt. 11, Transfer of the Property or. a n~llcfici;d Inlere!>t ill Borrower. H all or any part of the Property or allY interest in it is sold or tr<lrderreJ (or if a beneficial intcrc.:;l in 130rrllwer is sr)ld or transferred and Borrower i5 not a natural person) withoul Lender'r. prior written I.:onsent"Lemler may, at it option, require immediute p.,ymcnt in full of all sums .secured by this Security Instrument. lIowever, this option shall not be exercised hy Lender if exercise is prohibited by federal law as of the date of this Security In"trument. If Lender excrcir.cs thi!> option, Lender I1hall give Borrower notice of acceleration, The notice shall provide a pe(iod'of nut Ic:;s than 30 days from thei d<lte the notice is delivered or mailed within which narrower mur.t P;,y all r.\Jms secured by thii: Sel.:urity In:;truffient. H Borrower failG to pay thc:;e Gums prior to the expiration of this period, Lender may invoke any remediC!: permitted by this Security Instrument without further notice or demand on Borrower, 18, Borrower's Ril':ht to Rein...tale,:1f Borrower meet:; certain conditions, norrower shall have the right to have enforcement or thi!! Security II1!itrument di::cl'Jntinlled lIt an}' time prior to the earlier of: (3) 5 days (or !luch other period a:; applicahle law ma,' !lredfy for rcinstatement) before sale of the Propert}' pursuant to <1n}' power of sale c0l11llined iit thi" Sct:\lrit}' In!;trtlment: or (b) entry of a judgment enforcing this Security In!ltrument. Those conditiolls are that Borrower: {ill pay!! Lender all sums which then would be due under this Security Instrument and the Note a:; if no <Ict:elcr<ltilln had occurred: (b) curc..'l any default of any other covenants or agreements; (c) p.,ys all ellpenses int:\Jrri:J in enforcind th1.<; Security Instrument, including, but not limited to, rensonable attorneys' fees; and (d) takes slJch action as Lender may reasonably require to ar.sure that the lien of this Security Im;trument, Lender':,; right.'l in ,the Property llml Borrower's obligation to pay the sums secured hy thi.:; Security Inlltrllment shall continue' \lI\changed~ Upon reinstatement by Borrower, this Security Instrument "nd the obligations ;,ecured hereby shllll remain fully effective :JI:1 if nfJ acceleration had occurred. I-Iowever, thill right to rcinstateshalllllH apply in the case of acceleration under par<1r,r3ph 17. 19, S<1le of Note: Change of Loan $crvicer, The Note or a partial interc:;t in the Note (together with this Security Instrument) may be sold nile or more timc:i without prior notice to Borrower. A sale may result in a change in the entity (known a:; the "Loan Servicer~)', that t:Ollects month!)' payment" due under the Note and this Security In:;trllment. There aIm may he one or more changer. of the. Loan Servicer unrelated to a sale of the Note. U there it; a change tlf the Loap S~r\'icer, Borrower will be given written Ilotice of the change in accordance with parllgraph 14 llbove ,and applicable law. The notice will state the n:line and addrC5:J of the new Lo"n Servicer and the addres:; to which p"ymeiltll should be m:Jde, The notice will 011:;0 contain any other inrormation required by applicable law" .. : I , ;'i . 20. lIazardous SutMtances: llorrowe.r, shall not c:Jllse or permi~ the presence, u::e, disposal, storage, or re1e3se or any lIazardous Substance;, on or in the Property, Borrower shall not do, nor allow anyone else to do, anything aUecting the Property that is in, violation, of any Environmental Law, The preceding two sentences fihall not npply to the prescnce, u:;e, or stor:lge on the property of :;rn:JlI qllantitie:; of IIa7.ardou" Substance:. that lire generally recognized to be appropriate to normal rc:;idential uses <Int! to. maintenancc of the Property, Borrower shill! promptly r,ive Lender. written notice of allY illvcstigation, claim, demllnd, lawlluit or other action by all)' govcrnmental or reglllatory agcne}' or privnte party involving the Property IInd llny I bzardolls Sllbstanee or Environment"l bw of which Borrower h::!s actlinl knowledge. If Borrower leam,;, or is notified by any governmental or regulatory authority, that any temov,11 or other remediation of any Ila7.lIrdo\Js Suhstnllce arfccting thc Property is necC:<,f,:Iry: Uarrower shall promptly t"ke all Ileccs:;ar}' remedial actions in accordance with Environmental Law, ., - As w;cd in this paragr"ph 20, ~ll"lardotJ:: Substances" 3re those .'l\JU:lt3IlCCS ddined as loxic or bzardour. sub:;tance:; by En\'ironmental L"w and the rollo\~inr, S\Jb:;t,111t:e...: &:l:;oline, kerosene, other rl:lmmable or tOlie _petroleum product:;, toxic pesticidc:: and herbicidc:'>, ....olntile r.olvent!l, material:; containing :lsbe:;tos or formaldehyde, :lnd r:ldibactive m:\teri.1l:7, As \J~cd in lhis p:\r:\r,r:\ph 20, ~Environmelltal Law" menns federal 13wn and lal\'n of the jurir.dictioll wllere the Property is localed th:tt relate to health, s:\{ety or environmental protection, NON-UNIFORM COVENANT$. Borrower and L~nder further covenant 3nd agree :\s followa: 21. Acceleration: Remcdie~., Lender ~hall gi\'e l1~llice 10 Borro\l'cr prior tn nccelerotion rollowing Borrower!> breach of 31lY co\'eli:\llt or :\r,reement in thi... Securit}' Instrumcnt (but not prior 10 acceleration under paragraph 17 Illlle~~ :\l'plicahlc 1:\\\, prn\'iJe.~ nther\\'i~e), Lender .'>h311 notHy Borro\\'er of, a010nr, other thing:;: (a) Ihe tlcf3\Jlt; (bl Ihe 3clioll required to curt" the debult; (cl when the default mllst be cllred; nnd (Il) that failure 10 cure the default a.~ :>flet:ified may resull ill lIcceleration of the sllms,.'>ecuret!,b}' lid... Sccurity Instrumcnt, foreclosure by judicial proceeding and .'>31e of Ihl'; Property, Lellller shall further Inform Borrowcr or the right 10 rcill.~late Bfler acceleration and the right to a~...ert in the rorct:losllre proceeding the !lon-cxistence of a default or 1I1IY other dcfeiue of Borroll'er to acceleration nlll! r(}reclo.Hlre, If the default i.'> lIot cured 3.'> specified, Lemler <11 il.~ option may I'cquire immediate Jla~'l1lclit in filII i)f all .'>II01S ~ecured by lhi... Security lIutru01ent without further demand allLl may fnreclo;~e ,thi.'> Security IlI:;trultlcnt by judicial proceeding, Lender ...hall be entitled to collect" all expe~lscs inchrreJ in pursuing the remedie.~ prnvided in this raugrnph 21. including, but not limitcd to, attorneys' rce~ anJ CtHtS of title evidence to the extent permitted by applicable 1;J\v. ': 22. Relc3$C. Upon payment II "tun:: 5CClJfeU by Ihi~ Security In:;trur, , thi:; Security Illfotrument and the C!;I:lte conveyed r.hnll terminate and become void, Arter f,\JI;!l OCl.:urrcnce, Lenuer shall dir.charge and sallnfy this Security Instrument wilhoUlchnrJ:c 10 Borrower. Burrower r.h;lll pay nny recordatiun costs. 23. Waivers. Borrower. tu the extent permitted by applicnblc law, waiv~ :llId relear.c:; any error or derects in I'rut.:cetlingr. to enlaree thin Security Instrument. and hereby waive" the benefit of :lny prer.clIl or ruture lawn providing r;,r rotay of e~ecution, cxlellr.iun of time. c~clllptiun from :ltladllncnt, ICilY and "ale, and homc5teau exemption. 24. Rcill$talcmcnt Periul!. Borrower'r, time to rcil1r.tatc provided in parngraph 18 r.hnll extend to une hour prior to the commem:ernent of biJdinR at a .<:herlrt'::; .<:ale or other :;ale pllr,,\l.lnt to this Security Instrllment. 25. I'urchase MOlle}' Mor1gar,c, If any o\b::r debt secured b}' this Security Instrument is lent tn norrr1wer tn aC4llire title to the Property, tbi::;Sccllrity Instrumentfohall be a pun:har,e money mortr,3Re. 26. llllere.~t Ibtc Arter JUllgfllenl. Burruwer agrees Ihat the intere"l nte payahle lifter a judgment is enlered un the Nute or in an action of m(Jrq~a&e fmedo5ure Sh,ll! be the rate payahle rrom time \0 time UlIder the Note. 27. Ritlers to thi." Security Inr.trumcnt. H one or more riders arc eKecuted by Borrower and recordeJ together with this Security Instrument, the covenant" ant! agreement:; of each r.uch rider shall be incorporaled into and shall amend and "upplemenl the coven:lnt:l :lnt! a&r~eillClIt::; of thi::; Sccurit,' Instrument as it the rided::;) were ::I. part of thi" Security Instrument. [Check npplicahle hox(e::;)] o Adjw;tahle Rate (tider 0 Comlominium Rider o Gr:ll..IL:lted Paymenl IUder 0 PlanneJ Unit Development Hider B Dalloon Rider 0 Rate Improvemenl I~ider Otheds) (specify] o 1'4 Family Rider D UiwceklyPaymellt Rider o Second Ilome Rider DY SIGNING I3ELOW, Borrower:.lCCepl5 :lnd a~rec:; to the term:': and covenant:,: contained in this Security Instrument and in any rideds) executed hy Borrower,and rccorded with it. Witne<.s: g:2'L-'-'~ '" 0:2:~ '7 A MACZUGA < '-C<.c~(' . (Se.1) -llorrOlYer OL2L~r;~~:;~ , (Se,i) -ilorrower (Se,1) J) -Borrower f ~ I\/U--^K- COllllty r.:; Jar of (JLc-~~:(';';j,-" 199/..(, berore me, J) tlie \Indef'jll:llcJ officer, per;,flll:llly nppeared --1.1-I.n"){)......~_ FA<R.'e- known In me (or r.:ltbrnetorily COMMONWEALTH OF I'ENNSYLVANIA On thi:;, the c2. & tlJ_ ~~ 'rt'-o"'d~lr<J pruvenl to be the per;,Ol(".:> who:':c namc) (L'UL_ ;,uh$cribed lu the withlll in$IOllllent lint! acknowled~ed that . . -tt::r"~ executed the r.ame for the purpo:,e,o; herein cOlllaim:J. IN WITNESS WlIEREOF, ( herellnto net Ill}' hand and oUicial foC:l1. _~.LJr",,_~ . Nt.1;i//2 Y PrJj]LlG -------"n""ileoIlJJrlcer !\ly Commi$~' III expire,r,: r:ol:lflnJ !in,,1 LJu.J. O/>,mlnr. t~Oli1ryrubIlC M r.U,I:'fTVlfl..('cllyCOUnl y C"mrn~:;:;lon EJplfO~ Sop!. ~" 199'0 . t.1:nUlf,rt'f'~<W'laA.'MO"J~' _ h_'__,' ..._,..__. _.,~.o~~~ fJ J,'w,,1c..(. I c'c't1irr that the pre::ci:le plllrl;:p~bll~j~~o; of the:: within llallled !\Iortr"lr,ee in -' .-. -.: ~"":' -, &.c, . . '..,:;....,'....--.... . -;?;. "'''-,'' .... -' " '- ~ ......::.~,~...... t..;rH .- '7Ir~-:~ oil:: --""'{ ]ljl)!jOI-on!i NOTE aCT'JE!En 76 .I'J 'J.1 n[w ClJf,HlEnLAlm (r:it,.) PEflWi'(l'/AlIIA (~;tald 651 WILLOW GROVE ROAD, CARLISLE, PA 17013 (1'1"1"'111' ,\,],If..'.",) 1 nOltlW\\'EIC; I'IWMISE TO 1':\ \' 11\ return for a IU;lfl thill I hall' r~':ell,'d. I ['r'III1I';(' ,,, rn r I ~; "prln":I[1IlI"l, plll~ interr.~t.;o 1101' nrlier ,,[ II.,. 1":Il(J~r., IJ,~ 1.\'lldr.r I', 114,500,00 (lhi~ Ilm<lIll\l l~ ,;..llI'd [mil T'I onE InCORPORATED I IIIIJer~tllfl'J thlll the Lenuer rni'lY tri'lJl~fer thi~ Noll!, rile LClltkr <Jr aIlY<1I1': Ilh'! tllke~ thj.~ j-':ute hi' Irllmf,.r find who i~ calitlr.u 1<J receive pllyment~ lInder thi~ Note i~ cnlleuthe "tlc,tl: JI,)lder," 2.INTEIlEST ]Iltere~t will be char;~ed on unpaid prilll':ll'al \llltll \lll! flllllllll'J\jllt of prlll<.:ipaJ IHI~ kcn 1';lid I will pay Inlere~t lit 11 yellrl)' rllte of 9,250 'Yo. 1'he i/Jler/.".~l ("Ie rl'l/lJiretl by thi:; S':.;!lfJ!\ 1 i.. th.. rat,. r wdl 1';1}' b<lth hdNe ;\flU aft..r nny uefault ue"crlheu in Section ti(lJ) of thi5 Note. J.I'A\'~IENTS (A) Time nntll'lncc of I','ymenl~ I will pill' principalllntl illlcre:;1 br making P;:YI~t:'l\t" ererr month I will make my monthJ)' p,,)'ment5 on Ille F lAST da)' of eilch month bcgil1nin~ Oil DECEMBER ,1994 I will make lhe5e payments el'er}' month until I ha~'e paid oil of tbe principill nnd intere"t ami HflY other chnrge" de~cribed helow that lmay owe unuer this Note. 1\1'/ monthly pa)'mefll~, I\ill be applied to intere..t before prmcipal. If. on NOVEMBER 01, 2024 , I stlll owe am(J\lnl~ lllld-:t thi.. Note..l will pilY tho..e affiOll111S in fnll 011 that uale, which is called tbe "mnturit}' date." I will make my [1arments al 3<10 EAST MAPLE AVENUE, SUI TE 3, LANGHORtIE, PA 19041 I)r lit a different plnce if re'l'"reu hr the Note Holder. (Ul Amullnt or Monthl)' I'a)'menl~ i'vly monthly [1::!'jment will he in the IImOllnt of V.OS. 4 nORROWER'S RIGHT TO l'REPA \' f hllve the right to mllke payment... of principul III tiny lime hdore ther ore due. A payment of principlll only i,., known 05 11 "prepayment." When I mBke II prepayment. I will lell the Nute Ilolder in wriling that [11m doing so. I mil)' make II full rreprl):ment or p;lrli::!1 pre[1:lyment" without pa)'ing llll}' prepayment chnrw:. The Note will U5e Illl or my prepllrment~ to rednce the amollnt of prinei[1;}1 th;}t I owe Hnder this Note. If I make Q prepayment. therl: will he no elwnhe~ in the dlle date or in the llmount or my monthly fHl)'menl \lnleS5 the Note agree5 in writing 10 Ihllse changc~. ' S. LOAN CHARGES If 11 lillY, which applies to this lonrl IInd which 5et~ Illiuimum loan l:harge5, is fio,,11 y interpreted 50 that the interest or other loan cn::!rge5 collected or 10 he collected in con~ection with thi~ loan e.~ceed the permitted limits, lhen: (ilany 'ouch loan charge shall be reduced hy the nmollnt neces~llr)' to reduce the char~e to the permitted limit: Ilnd (ill rmy sums olrelld)' collectcd horn me which exceeded permitted Iimils will be rcfunded to me. The Note Ilolder mll~' choo~e 10 mllke this refund by rcullcinfi the princip::!1 I owe Illlder thi.~ Nule or hy mnkin~ n direct payment to me, IF 11 refund reduces principnl, the reduction will be Ireateulls n p::!rtinl prepa)'ment. U. ilvRii.G~I;'L~'::: i-',\i:Xj:;; TG 7;\ ':' :.::: ::EG::~F.Et: (1\) I.nte Charge for {herdue P;}rment.., If the Note Holder hl1~ not receil'cd the full ~mollot of an}' monlh[)' pa)'ment h)' lhe end of 15 ClIlendnr uoys nfter the dote it is due, 1 will pny alate chl1rge tt) the Nflle Ilohler. The alllollnt of the ..:hnrge will he 5,0 % of my overdue payment of principal nfld intere5t. I will p~y Ihi~ laIc chaq,:e promptl)' hut only ooce on ench lllte pn)'ment. (11) Derallll If I do not pi'lY the full ;}mounl of cnch monlhl r 'pa)"mcnt nil the date it is uue, r will be in ddll\llt. (Cl Notice flf Ocf:alllt . If I nm in defllllll, the Nole llolder mllY .'.end me 1\ written !lIJlice telling me that if I U" lIot par the lll'erdue lunnlinl by a certain dale, Ihe Note Ilolder ma}' require me I~ pay immediolely the fulllllllOlll1t of principal which hns not been rnh.! nnd all the inlere5t tnnt I owe on th::!t amount. Tklt dnte m1Jst be lit Ienst Jll dnys lifter Ihe drlte un which the notice is delivered or mniled to me, (Dl No Wllin!r II}' Nole lIoltler Even if, at II time when I nm ill .Ieflllllt, the Nole I [<,Iller uoe~ Jlllt reqllire me to par immetlintel~' in rull ns de~erihed uhove. the Note Iloltler will 5til1llo~'e the rif:ht to 01) 50 if [ ;lIn in defnult lit II Inter time. (ElI':J}'ment of Nole 1I0Ider'.~ Co~l... :lIld E~pl'n~l's If Ihe Note llolder hn5 rl'<plired me 10 p,'y imrnetliatel)' in Full 1'15 descriheu IIhove, the Nnte Ilolder will hllve the right to be puid b"ck by me fnr nil of it'. cn~l~ nll;l exp;:n~e5 in enForcing thi5 Noll' to the extenl not prohibited br arplicnble lnw. Those e~~n~e5 il\dmle. for 1'\::!fIIple, rca..onllhle Ilttl'H/le)"5' fee~. 7. GIVING 01' NOTICES: : i' Unle.~5 npplicnble In\\' require.. a Jirrerent method, nnr notice that mllst he ~i\'ellto me under thi~ Nole \I'ill he Bl\en by deli\'erill~ it or by lnllilinf: it b~' fir~t cln..s Inll1l1o 1111' :It tIle I'r()[Y!rt i' :\dure55 above or al a different ntldress ir I f:il'e the Noll' 1I0lder n notice of my t1iHerenl nddre~.. /\ny lIotice thnt rnlJ~t he l:il'(,IlIO the Noll' llolder under lhj~ N'lte will be i:ilen b)' mili'ill~ il hr rirst clns~ mnilto the Nule Ilolder nt the /Itldles5 ~t/lled il\ Section J( A) 111,01'e Il' al n different i1~Ure~5 if I nm r.ilen n nllliee of lhnt dirferent nddre~~. ' 595.17 Ilolder portial Iloloer MUlTl5T^TE rlX(D n^T( tlOTF.-.r;'llqlfl r,llll,ty -frlM^'rtH.MC tJrllrOllM INSTntJMHH , rn.m HOO lJ!Rl / / _.//' ........ - J ( GE Ca/lital GE C'lJlifn!I\fClrtg.l!!C Services. II/c. Ill/fljl/JIGI r::l{HI.lIMIIII!j"!J1!CIJI/III/0i1Iflll 201m Wf~~llr)l)/I SOl/ill. Sill/!? /300 fl (] litH ,IJ(ll/5. /lfII/.~lr)ll. lX //01/ 0715 /13 (i/343J2 DATE: May '10, 1996 NOTICE OF INTENTION TO FORECLOSE MORTGAGE UNDER SECTION ~03 Of PA ACT NO. 6 OF 197/,. (READ BOTlI rAGES OF TIllS NOTICE CAREFUllY.) GREGORY RADle 651 ~ILLO~ GROVE ROAD CARLISLE, PA 17013 RE: GE LOAN # 0016300295 PROPERTY 651 YlllOY GROVE ROAD CARLISLE, PA 17013 MORTGAGEE: G.E. CAPITAL MORTGAGE SERV:CES The Mortgage held by the above named Mortgagee (hereinafter we, us, or ours) on your property noted above is in serious default because you have not mode' the monthly payments as noted below under (a), nnd/or because you have failed to comply with or perform th~ other provisions of the mortgage obligation, if any, as noted below under (d). Previous late charges under (b) and other charges, if any, under (c) noted betow, have also accrued to thIS date. The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of ,this letter, is noted below under (e). (a) 030196 thru 050196 @ $8~3.80/mo plus late chg @ $27.80 " $2,587.00 (b) Previous late charge(s): (c) NSF check charge(s): (d) Other provisions of the mortgage obligation if any: (e) Total amount ~cquired os of this date: $69.51 , .00 108.36 $2,709.27 You may cure this default within THIRTY (30) days of this tetter by paying to us the amount under (e) above, plus any addition~l monthly payments and la~e charges (and other charges) which may fall due during this period. Such payment must be either by,cash, cashier'S check, certified check, or money order made payable to G.E. Mortgage S~rvices, 625 M<lryvill'e Cent~e, St. louis, MO 631'." Attention: cashiering Department. If you do not cure the def<lult within THIRTY. (30) days, we intend to exercise our right to acceler<lte the mortgage payments. This m~ans that whatever is owing on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance t? payoff the original mortgage in monthly installments. If full payment of the amount of 'dcfoult' is not made within Tll1RTY (30) days, we also intend to instru~t our at~orncys to start:a lawsuit to foreclose your mortgage property. If the mortgage is foreclosed, your mortgage property will be sotd by the Sheriff to pay ~ff th~ mortgage debt. If we refer your case to our attorneys, but you cure t~e defau~t before they begin legal proceedings against you, you witl have to pay the reasonabte attorney's fees actually incurred up to'$50.00. Ilowever, if legal proceedings are started against you, you'.will have to pay the reasonable attorney's fees even if they are over $50.00. .Any attorney's fees will be added to' whatever you owe us, which may also include our reasonable cost~. If you cure the default within the THIRTY(30) day period, you will not be required to pay attor~cyls fees. : ' . - ) I ACT 91 NOIICE GE Capital TAKE ACTION TO SAVE YOUR 1I01~E fROM FORECLOSURE GE e"/filill MOftgnfle Sc/vices, Inc. A I/I!Jfof (iI.Ca/III"Ir..:llflf",,/f' (:(II/IIII,lfulI! The Comnonwelll th of pennsyt viJni.. I s Itomeowllcrs I Ernerger,lf~'rl-lI;'l"'idll\jc'<;lIflrll. ....1II1l~ I]U(! 'I I' 1111". ,lJJJ.~/'i 1I11I1If/'(1 IX 111I')1 ri//.'. AssIstance Program moy be able to help you. Rend t ~c foltorl,I1?;p.?t);F-c to, lhd out how the program wor\o:r.. If you need more information, call the Penrlr.ylvnnio flou<:>ing Finance Agency at 1.800.3~2.2397. ; la Notification en adjunto cs de suna importancia, pues ..fecta su dcrccho a contlnunr vivlendo en su casa. si no comprende cl ~ontcnido de csta notiffcac!cn obtc~ga una traduccion inmcdiatnmcntc 'tlomnndo esta ogencio (Pennsylvania Housing Finance Agency) sin cargos ol:,numero mencionado arriba. puedcs scr elcglble para un prestarno por el progromc llnmado "Homeowners. Emergency Mortgogc Assistance Programll al cual puede'salvar su cnsa de la pcrdido del derecho D redimir su hipoteca. ACT 91 NOT ICE IMPORTANT: NOtiCE OF HOMEO'"lNERS' EMERGENCY MORTGAGE ASSISTANCE P~OGR^M PLEASE READ TIll S NOT I CE- YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE IJlllCIl CM SAVe YOUR 'HOME FROM fORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS May 10, 1996 RE: G.E. CAPITAL HORTGAGE SERVICES, INC. Property Address: 651 ~llLOY GROVE ROAD, loan" 16300295 CARLISLE PA 17013 , TO: GREGORY RAOle 651 ~ILL~ GROVE ROAD CARLISLE, PA 17013 FROM: G.E. capi ta 1 Mortgage Servi ce!i You may be cligible for financiat a!isi!itance. that will prevcnt foreclosure on your mortgage if you,comply with the provisions of the Ilomeowners' Emergcncy Mortgage Assistance Act of 1983 (the "ACTl1). You may be et igibte for emergency temporary assistance if you dcfault has been caused by circum!itanccs beyond your control, you have a reasonable prospect of'rc!iuming your mortgoge payments, and if you meet other eligibility req\Jirement5 established by the Pennsylvania Housing Finance ^gency~ ~lcase rcad all of this Notice. It contains nn explanation of your rights. Under thc Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (0) days from the date of this Notice. During that, titTle you must arrange ond attend a "face-to-.face" meeti~g ~ith a representative of this lcnder, or with Il de~lgnnted consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwisc settle your delinquency. ,This meeting mU!it occur in the next thirty (30) days. 8 ( , IJ IIUD APPROVED COUNSELING AGENCIES GE C"llit.,1 PENN~~~Y~~!~~~on_tl ~__ _.___ NEIGtIBORlIOOO DEVELOPMENT ALLIANCE 3935 OGONTZ AVE. PHILADELPHIA, PA 19141 (215) 421, 1111 HORTHl,JEST COW~SEl.ING SIERVICE, INC. 5601 N. BROAD STREET', 'SUITE 209 PHILADELPHIA, PA 19141 (215) 549 2334 ' I PHilADELPHIA COUNCIL fOR COMMUNITY ADVANCEMENT 100 N. 171H STREET, SUITE 600 PHILADELPIIIA, PA 19102 (215) 567 7803 PHllAOElPHIA,HOUSING DEVELOPMENT CORPORATION 1234 MARKEr STREET. 10TH FLOOR PHILADELPHIA, PA 19107 (215) 448 3137 SOUTIl\.lEST GERMMHOUN COMMUNITY , DEVELOPMENT CORPORATlpn 5002 \.JAYNE Ave. PHILADELPHIA, PA 19144 (215) 843 2000 URBAN LEAGUE OF PHILADELPHIA' EDUCATION FOUNDATION, HOUSING INFORMATION CENTER 4601 MARKET STREET, SUITE 2 SOUTH PHllADElPttlA, PA 19139 (215) 476 4040 YASHINGTON~GREENE COMMUNITY AerlON CORPORATION 2198 NORTH MAIN STREET ~ASHINGTON, PA 15301 (412) 255 9550 SERVICE AREA: BLAIR COUNTY AlTOONA/BlAIR COUNTY COMMUNITY HOUSING RESOURCE BOARD ',22 6TH AVE. P.O. BO':C 1485 AlTOONA, PA 16603 (814) 944 7286 SATElll TE OFF I CE: .J GE C/lllir/11 Motlg(lgu Services. file, !' 1\ fit/It /)/ G( C<?{lllill ^,!II'!1,J~}I~ CO/POW/ifill COnSUMER CREDI T . colmsElI N?t!r~tUivt~e(l/J South. SWII! IJOrJ Of ~ESTERN P NSYL1', A ';'(I.JJfI,',"J(})J5, IIlJll.ltrJ/l. lX 7/01107/5 I EN rANI, r.h')] ".11J 500-02 TltlRD AVE. I; ~~ST OFFICE BOX,278 OUNCANSVILlE, PA 116635-0270 (614) 6963546 ;1 I SERVICE AREA: CAMBRIA COUNTY CAMBRIA COUNTY ftOlJSING CoRPORAflON SYANN BUilDING, ROOM 304 616 MAIN STREET JoUNSTON, rA 15901 (81ft) 535 8300 SERVICE AREA: ERIE COUNTY, PA BAYFRONT NATO, INC. " MARTIN lUTIIER KINO CENTER 312 CHESTNUT STREET ERIE, PA' 16507 !i (814) 453 571,4 :! BOOKER T.' \JASIII NGToN, 1 NC. 1720 HOLLAND ST. , ERIE,PA 16503 (814) 453,57/,4' ;'/1 H.A.N.D.S., INC.;, 139 EAST 12TH STREET ERIE, PA' 16501 i' (314) 459 1047 I, JOHN F. KENNEDY CENTER 2021 EAST 20TH STREET ERIE, PA 16501 (814) 898 0400 FAMilY SERVICE OF. ERIE 110 ~EST 10TH STREET ERIE,PA,16501I' (814) 454 6/,78 I , I' I I 'I , , " , , - / ~ '~ GE CiJ/,jtilll\1orty.lge Sc/vices. I/le, 11 (inti {II (i[ [;lfJllill Mmlgilaf~ Cf)/{Ir)/,11I1!11 7000 \flk~llnrr{J Suulh. Sllllf! /300 f'O [J11,l42027!i,IIrJI',,{lJIr, TX 11077 021~ 113 (j23.,fJll Also, we may sue you personatly for the unpaid princIpal balance, and all other sums clue under the Mortgage. If you have not cured the default within the thirty day period, and foreclosure proceedings have begun, you will still hove the right to cure the defautt and prevent the sale at any time up to one hour before the sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late Chllr9C!l, charges then due, as wetl as. the reasonable attorney's fees and costs co~ncctcd with the foreclosure sate (and perform any other requirements under the! mortg<lge). It is cs~imated t~at the earliest date that such sheriff's sale could be held would be approx'imotely FIVE MOIlTilS FROM TIlE DATE OF THIS lETTER. A notice of the date of the sheriff's sale will be sent to you before the' sate. of course, the amount nceded to cure the default will increase the longer you wait. You may find out at 'any time exactly ....hat the. required payment will be by calling us at he following number:1 (800) 317.4322 :. Th,is paym~nt must be in cash, cashier's check, certified check, or money order and made payabte to us at the address stated above. You should realize that a sheriff's sate will en~ you~ ownership of the mortgaged property and your right in it. If you con~inue to live in the property after the sheriff's sate, a lawsuit could be started to evict you. [, You have add it i onal rights to hel p protec t your i ntercis tin the property'. You have the right to sell the property to ,obtain money ~~ payoff the mortgage debt, or borrow money from another lending institution to payoff this debt (you may have the righ.t to sell or transfer the property' s~bject to the m?rtgage to a buyer or transferee who, wilt assume the mortgage debt; provided that all the outstanding payments, charges, attorney's fee~ and costs are paid prior to, or at the sale and that other requirements under the Mortgage are satisfied). Contact us to determine under what circumstances this right might exist. You have the right to hove this defautt cured by any third party acting on your .behotf. If you cure the default, the mortgage will be restored to if no default had, occurred. However, you are not entitled than three times.in a calendar year. the same position as to this right more Very Truly Yours, 16300295 KIRK WIER, loon Counselor 1 (600) 317-4322 GE C"fJitat 'fj) ACT 91 NO! ICE TAKE ACT 1011 TO SAVE YOUR 1l0HE fROM FORECLOSURE GE C;I/';t,ll Mortgn{/c Services, flIC. The COllrnonwcal th of Pcnn5yt van i a'!:. Ho~co'rlner~' Emergcrll:VIIJ:lQrll!Ulgol,ll fdl!rrrld'I'~ C()I/Hlldl,111I Assistance Program may be able to help you. Re.ld the '0\ lo;;nh\d\'t1oifO'b,~'t'tV'.fl~ I.IIJIJ . h f'(} i111(4}fli'h.III1I!';I!lII, IXI/Oj/OJI!, out ow the progrnm work5. /I1f,).I,I./}) If you need more information, call HIe Pcnn~ylvania ltou5ing Finance Agency at 1-800-342-2397. La Notification en odjunto e!O de sumO! importancia, p_H.":. "recta !ou dcrccho n continuilr vivicndo en su caSil. Sf no comprcnde el contcnldo de estn notificaclon obteng<l una trnduccion irnncdiatamentc Ilarll.3ndo c!Ota a9cncin (Pennsylvania Housing FiniJnce Agency) sin cargos ill numero lIll:"ncionado orriba. Puedes ser etcgibte porn un prestamo por el programoi I iarnildo IIll0meowncrs' Emergency HortgDge /lssistcmcc Progrnm" 0'11 cual pued€! s;llvM ~V eelS,) de III pcrdida del derecho n redimir su hipoteca. ACT 91 NOTICE IMPORTANT: NOTICE OF 11OMEmmERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU HAY DE ELIGIBLE FOR FltlAtICIAL ASSISTANCE \.JllICIl CAN .SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS May 10, 1996 RE: G.E. CAPITAL MORTGAGE SERVrCES, UlC. Property Address: 651,WILLOW GROVE ROAD, CARLISLE PA 17013 Loan II 16300295 TO: JULIA MACZUGA 651 WIllOW GROVE ROAD CARLISLE, PA 17013 ' FROM: G.E. eapital Mortgag~ Service5 You may be et igibte for financial assistance that wi II prevent foreclosurc on your mortgage if you compty with thc provision~ of the flomcowncrs' Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be et igible for (!mcrg~ncy t~mporory assistnnce if you defnult has be~n cnused by circumstances beyond your controt, you have a reasonable prospect of resuning your mortgage pa~ncnts, and If you me~t othcr eligibility requir(!ments estnblished by the Pennsy(vil'1ia Ilousing Financ~ Agency. Plcase rend all of this lIotice. It contnins an explanation of your rights. Under th~ Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from th~ date of this Noticc. During that timc you must arrange and attcnd a I1tDce-to'face" meeting with a reprcsentot~ve of this lender, or with a designnted consuncr credit count.et ing ngcncy. The purpose of this meeting is to attempt to work ?ut a repayment plan, or to otherwis~ scttle your delinquency. This meeting IllIJSt occur in the next thirty (30) d,y'. ) GECo1fJit.11 . If'you:.a foec.to.focc mectlng witt, thl, l,nd:t, 0' with a co,m".' teCdlt) counseling agency Identified in thi~ neticf', no further proceeding ;n mortgngc foreclosure may take p~~~~.!..?~t.~~~_ .(.J~.~ .~~y~__~~~+!:-_!~~. ~<1_~?,. of thi,....,.~~~t ina. The nome, odd~es51 ond telephone /lumber of our rr.pr;"scntiltltfl!d,fli'{IIMO'fU.lgoSctvic/!,~.II/(: G.E. Capi till Mortgage Servlcc~ 1\/111I101(;( C'I!lr,IIM/If/lj,H/f' CrJlII'U,lllrtll 625 Milryville Centre Orive ;m()I)WI',/IIJII/lSllIIrh, SIIIII! 1.71111 I 6.3111 /' () IInl 'l.'I)I/~, I/IIW./IIII, lX /lilll OJ/', SL Lou .., MO. 113(;/1,13;) 1 (BOO) 317-~322 The names and addresses of dcsi9nntcd con<;ulner credit coutl5cllng ngt'ncle5 arc shown on the attached sheet. It is only ncce....ol'y to schedule one face-to-face meeting. You shoutd advise this lender In.nediately of your Intentions. GE C<1/,ilal Your mortgage i:; in defoult because you have foiled to pay promptly lmtilllmcnts of principal and Intcre5t, as req'ulrcd for ot least, sixty (60) days. The total omount of the dclinqucncyls $2,709.27. That sum inCludes the following: payments due 03/01/96 through the first of this month and late charge!>. Your mortgage is olso in defaul t for UH! fol toLing rElat.on: Unable to Contact. If you have tried :Jnd are unable to 'resolve this problem nt or after our face-to-fac~ mec~ing, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund., In order to do this, you must fill out, sign and file n completed Homeowners I Emergency flssi!>tnnce Application with one of the designuted consuncr credit counseting ngencic!> listed on the att~chment. An application for assistcmce rnay onty be obtained from a consumer credit counseling agency. The condumer credit counseling agency will assist you in filling out your applicntion and wilt submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked" within thirty (30) days of yo~r foce-to-face m(!(!ting. It is extremcly important that you file your applica~ion promptly. not do so, or if you do. not foltow other time periods set forth in foreclosure may proceed against your home irnnediotety, If you do this letter, Avoi lable funds for emergency mortgage assistance ill:e very 1 lmi ted. They wi t 1 be disbursed by the Agency under the eligibilityc~it(!ria established by the ACT. It is extremely important that yournppllcat'ion Is'accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receivcs your application! During that additional time, no foreclosure proceedings witl be pursued against:you if you have met the time requirements set forth above. You will be notified,directly by the Agency of its decision on your application. The Pennsylvania !lousing Finnnce Agency is' located' at 2101 North Front Street, Post Office Box 8029, Itnrrisburg, pennsylvnnia 17105. Telephone No. (717) 760-3800 or 1-800-342-2397 (totl free number). Perso~s with impnired hearing can call 1-BOO-3~2-2397. In addition, you may receive .lnother notice from this tender under Act 6 of 1974. That notice Is cnlled n "Notice of Intention to Foreclose." You must read both notices, since they bo~h exploi'n rights thnt you now have under Pennsylvania low. Ilowever, if you choose to exer~ihe your rights described in this notice, you connot foreclosed upon while ,you Dre receiving that assistance. Sincerely, lfl300295 KIRK ~IER,1 (BOO) 317.~322 , Collection Dcpartmen HOUSING ASSoCIAT IO'N OF DELA\JARE VAllEY , , HOUSING ASSOCIATION ~NFORMATION PROGRAM 1314 CHESTNUT STR~ET~ SUITE 900 , , PHILADELPHIA, Pf. U9107 (215) 545 6010 , :e I:' \, HUO APPROVED COUNSELING AGENCIES PENNSYLVANIA SERVICE AREA: DELA~ARE COUNTY (PENN SITE OFFICE) 1I0USING ASSOCIATION AND , DEVELOPMENT I, 411 \.JALNUT STREET\: P.O'. BOX 1505 ,., ALlENTO~N, PA 18105 (215) 1,32 6336 (: DElA\.IARE COUNTY H.O.P.E. PIIILADELPHIA COUHCIL FOR ADVANCEMENT 511 YElSIt STREET CH"TER, PA 19013 (215) 872 3500 COM~~UN I T Y SERVJCE AREA: HARRJSBURG URBAN lEAGUE OF METROPOLITAN HARR I SaURG, I NC. 28 HORTH SECOND STREET HARRISBURG, PA 17101 (717) 397 5182 ) GE C,lllirllf Mortgnye Sorviccs. Iflc, A 1111I1 of Gl C.1/1II"/ ""ru(q.1ge CIJf(IOI.1111111 2()OOWr.,\//OOpSIIIIIII. SUlle /300 r a (fox 420JJ5. I/IHHIIJII, rx 7l0Jl.oll~ 713 G2J <J22 SERVICE AREA: READING AND BERKS COUNTlE~ IlOUSING COUNCil Of, YORK 116 NORTIl GEORGE 'STREET YORK, PA 17/.01 \~, (717) 854 1541: i; :: COUNCil OF TlIREERIVERS AMERICAN INDIAN CENTER, ,I~~; 200 CIlARlES STREET PI TTSBURGfl, PA: 15238 (412) 782 (,457: I I HOUSING ASSOCIATION ,OF DELA\./ARE VALLEY , HOUSING AssociATION I iNFORMATION PROGRAM :658-60 NOR TIt YATtS .ST. IPHILADELPfHA, PAl, 19123 : (215) 978 022/,: j1 ,. I (COUNSELING OFIi~,E), " ; : I: i , ~ ' j' SERVICE AREA: LANCASTER COUNTY THE BUDGET COUNSEllNG CENTER 2/.7 NORTH 5T11 STREET READING, PA 19601 (215) 375 7866' :;', i ~ ~ ! TABOR COMMUNITY SERVICES, INC. 320 SOUTH DUKE STREET LANCASTER, PA 17602 (717) 397 5182 SERVICE AREA: YORk COUNTY SERVleE AREA: LEHIGU VAllEY CONSUMER CREDIT COUNSELING SERVICE OF lEIlIGIl VAllEY, INC. 1031 LINDEN STREET AllENTO\.JN, PA 18102: (215) 821 4011, SERVICE AREA: lUZERNE COUNTY COMMISSION OF ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 2'1.213 SOUTH MAIN STREET ~ILKES-8ARRE, PA 18701 (717) 826 0510 " , I, I,,: GE Catli/at . " CAROl ROMAN CHIEF DEPUTY ADMINISTRATION REAL ESTATE DIVISION LT. BARBARA JAVICK SGT. HEATHER ZAWATSKI CIVIL DIVISION LAURA CHOPICK SGT. CAROl BENFANTE TINA McMINN Office of tbe sberiff . . ~ : ..... ",. '0aU'" ALFRED FENIMORE CHIEF DEPUTY OPERATIONS CIVIL& CRIMINAL DIVISION CAPT. DON GODEK LT. FELIX WAWER JOHN WASSIL SAM SALVO CAS KIZIS lUll'mc County, Pcnnsylyani.l I U711 9o\.1A"'''''g C"" "",IRI.o'... Ifl FAX (717) 825-1849 CARL ZAWATSKI, SHERIFF \\ II U ">tI'\RKf 1'1 .....~'-,Yl\',\,'I;\ i71!i H2;.!(,;1 IDENTIFICATION DIVISION SGT, GARY LOUGHNEY SGT. ERIN JOYCE SOLICITOR JOSEPH F. SKLAROSKY TDD (717) 825-1860 CUMBERLAND 96-4602 G.E. CAPITAL MORTGAGE SERVICES, VS. INC. GREGORY RADIC AND JULIA MACZUGA STATE OF PENNSYLVANIA LUZERNE COUNTY, SS: JOHN WASSIL , DEPUTY SHERIFF, for SHERIFF of said county, being duly sworn according to law, deposes and says, that on _. TUESDAY _.__. th e __..liT day of OCTOBER 19 _29_ at _.~CJ.:..!J____,.._,_____A, M" prevailing time, he served the wilhin NOTICE AND REINSTATED COMPLAlpT upon JULIA MACZUG.A the within named, by handing to LORETTA FISHER an adult member of the household, whose relationship to the within named is that of at HER PLACE OF R!':JUJ)j:;NCE....Il.OX.Jl88J._RlU...sJ.1.GARLOAF_______ MOTHER in the County of Luzerne, State of Pennsylvania, a true and attested copy and making known the contents thereof. Sworn to and subscribed before me ~~d;L. Sheriff of Luzerne County ~C,. (\ by ,>-'-- ~..,~ ._ Dep'uiyiheriff of Luzerne County, Pennsylvania this 2ND day of, OCTOBER 19 ---2.L .,,'::; fl '- . .,~(.,.~- <:;;1 I...)~A..~ CO.., -;; ~"~ t../-.~ " Prothonotary' i MATTLEMAN, GREENBERG, SHMERELSON, WEINROTH & MILLER SUITE 2226 - LAND TITLE BUILDING BROAD AND CHESTNUT STREETS PHILADELPHIA, PA 19110 215-923-2225 ATTORNEYS FOR PLAINTIFF By: MICHAEL R. NESTOR Attorney I.D. Number: 76429 ======================================================================== GE CAPITAL MORTGAGE SERVICES, INC. 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NUMBER: 1996-04602 AFFIDAVIT OF ADDRESSES GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA RR 1 P.O. BOX 988 SUGARLOAF, PA 18249- Defendant(s) ======================================================================== COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: ss I, MICHAEL R. NESTOR, Esquire, being duly sworn according to law, upon my oath, depose and say: 1. I certify that the Plaintiff's address is: GE CAPITAL MORTGAGE SERVICES, INC. 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834. 2. That the Defendant(s) is/are at least 21 years of age and reside at the following address(es): GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA RR 1 P.O. BOX 988 SUGARLOAF, PA 18249- 3. The affiant has ascertained the foregoing information by personal inquiry and knowledge and makes this Affidavit with due authority. Sworn to and Subscribed . flu day , jqc;~): MATTLEMAN, GREENBERG, SHMERELSON, WEINROTH & MILLER , ~)J ~),-i( ,/ ( '----. ByL/ MICHAEL R. NESTOR 76429 AN , GR I.. NOTARY PUBLIC OF N[W JfAS(y m,Comml!.S/Qn~),,"" k f<1,~~~h,,,-..,",, l~ .. ,"', ",7 Our File No. 291/45987 MATTLEMAN, GREENBERG, SHMERELSON, WEINROTH & MILLER SUITE 2226 - LAND TITLE BUILDING BROAD AND CHESTNUT STREETS PHILADELPHIA, PA 19110 215-923-2225 ATTORNEYS FOR PLAINTIFF By: MICHAEL R. NESTOR Attorr.ey I.D. Number: 76429 ======================================================================== GE CAPITAL MORTGAGE SERVICES, INC. 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834 Plaintiff vs. GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA RR 1 P.O. BOX 988 SUGARLOAF, PA 18249- Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY : NUMBER: 1996-04602 CERTIFICATION OF MAILING ------------------------------------------------------------------------ ------------------------------------------------------------------------ I, MICHAEL R. NESTOR, Attorney-at-Law, do certify that: 1. I am a member of the Firm of Mattleman, Greenberg, Shmerelson, Weinroth & Miller, attorneys for plaintiff in the above entitled cause of action. I I I, I I if ~ f ii' 'f \ , /, . " il. ~! 'r :~ 'II I', II jl , 'I 'I, it :1 " I 2. I forwarded to the following defendant(s) on the date(s) listed, by regular mail, a copy of the Notice, Rule 237.1: GREGORY RADIC - 10/22/96 - 10/22/96 JULIA MACZUGA A copy of the Notice is attached hereto. 3. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are wilfully false, I am subject to punishment. MATTLEMAN, MILLER -- /; GREENBERG, SHMERELSON, WEINROTH & ttorneys for Plaintiff By Dated: 11/04/96 R. NESTOR, Esquire Our File No. 291/45987 (RULE OF CIVIL PROCEDURE NO. 236) - REVISED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ======================================================================== GE CAPITAL MORTGAGE SERVICES, INC. 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NUMBER: 1996-04602 GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA RR 1 P.O. BOX 988 SUGARLOAF, PA 18249- Defendant(s) NOTICE PURSUANT TO RULE 236 ------------------------------------------------------------------------ ------------------------------------------------------------------------ NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. PROTHONOTARY - CUMBERLAND COUNTY If you have any questions concerning the above, please contact: MICHAEL R. NESTOR Attorney I.D. Number: 76429 MATTLEMAN, GREENBERG, SHMERELSON, WEINROTH & MILLER Suite 2226 - Land Title Building Broad & Chestnut Streets Philadelphia, PA 19110 215-923-2225 Attorneys for Plaintiff "~' , , ' ~g!; ::.J: ". ThIS is 11' obtained ' ' ,,''I'nFall'~e~Aq ~mdanylnforu._,,()n ,....._ ., .hat. ..IT '''",1; "S. ;,;,;:;.q. "1'''\ ," w'~ .' ~- i"'OI../., . ., '0 -' 1..>.- <'", III ;,:~ h- L) fl: ~ I'. C)~ '-- Cl (<'J '" , ["!," c.' , 1', '..J .' ". ,r> .. 0 u' ~ , ....--, \>-- ... " '-0 \ ~" " " '-.!J '- , - " ) <:::. .;...... -<1- :;---........ " ~ oJ '/ I.. --, " " .-' [ ", ' , ..... '<.'0.'- r-- <::.>J \....:...)'< .'"'":,' --.: AJ~L THAT CERTAIN tract of lund situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on 1:he aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling ~- /": i "-'( .: \ L'_ . " () . C', . , lL ~ . <\ .. v. ,-: ;J (j .~ "'\ ..?\ f - l,r) ':''' "" ~ '":'- (,,'- "1\ I (, Ci\ "'= .'- ~ "1\ '" ' " ~ .., .J o "x" I ' -....j... ~ -0 '-~ ~- "- G .....Sl -:> .-.J ~ ...J ~ --- -..;., C::J ~' , MATTLEMAN, GREENBERG, SHMERELSON, WEINROTH & MILLER BY: MICHAEL R. NESTOR, ESQUIRE ATTORNEY ID NO. 76429 SUITE 2226 LAND TITLE BUILDING BROAD & CHESTNUT STREETS PHILADELPHIA, PA 19110 215/923-2225 Attorney for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff NO. 1996-04602 vs. GREGORY RADIC AND JULIA MACZUGA Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at 65'1 willow Grove Road, Carlisle, PA 17013: 1. Name and address of Owner(s) or Reputed Owner(s): Gregory Radic 651 willow Grove Road Carlisle, PA 17013 Julia Maczuga RR 1 P.O. Box 988 Sugarloaf, PA 18249 2. Name and address of Defendant(s) in the Judgment: Gregory Radic 651 willow Grove Road Carlisle, PA 17013 Julia Maczuga RR 1 Box 988 Sugarloaf, PA 18249 ~ 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Merryville Centre Drive St. Louis, MO 63141-5834 4. Name and address of the last recorded holder of every mortgage of record: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Merryville Centre Drive St. Louis, MO 63141-5834 5. Name and address of every other person who has any record lien on the property: None known. 6. Name and address of every other person who has any record interest in the property and whose interest amy be affected by the sale: Occupant, 651 Willow Grove Road Carlisle, PA 17013 7. Name and address of every plaintiff has knowledge who has any interest may be affected by the sale: Occupant, 651 Willow Grove Road Carlisle, PA 17013 person of whom the in the property which I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 ,1> : C.S. Section 4904 <01"'"9 Co u"m<" ,"'.'fiooHo" :~7 9L .' Michael R. Nestor, Esquire before me this day of , 1996. I/OTAi;~_NrGrfOIl ( M,-c . U(;or N['" J omml:;:'icnrt j, 'tJFR,~IY P'~.J,lnl""""1 . , I.'~=t NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S) : GREGORY RADIC AND JULIA MACZUGA PLAINTIFF/SELLER: GE CAPITAL MORTGAGE SERVICES, INC. DEFENDANT (S ) : GREGORY RADle AND JULIA MACZUGA //"1 ;; ,I Michael R. Nestor, Esquire MATTLEMAN, GREENBERG, SHMERELSON, WEINROTH & MILLER Suite 2226 Land Title Building 100 South Broad Streets Philadelphia, PA 19110 215-923-2225 NO.: 1996-04602 PROPERTY: 651 willow Grove Road Carlisle, PA 17013 The above captioned property is scheduled to be sold at Sheriff's Sale on March 5, 1997, at 10:00 am in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013. You may hold or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 291/45987 MATTLEMAN, GREENBERG, SHMERELSON, BY: MICHAEL R. NESTOR, ESQUIRE Attorney ID #76429 Suite 2226 Land Title Building Broad and Chestnut Streets Philadelphia, PA 19110 Attorneys for Plaintiff WEINROTH & MILLER GE CAPITAL MORTGAGE SERVICES, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.: 1996-04602 GREGORY RADIC AND JULIA MACZUGA Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at 651 willow Grove Road, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on March 5, 1997, at 10: OOam in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the Court Judgment of $95,000.95 obtained by GE Capital Mortgage Services, Inc. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Michael R. Nestor, Attorney for GE Capital Mortgage Services, Inc, back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call Michael R. Nestor at 215-923-2225. 2. You may be able to stop the Sale by filing a petition asking the court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the Sale. (See Notice on page two and how to obtain an attorney). . -... YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder. You may find out the bid price by Michael R. Nestor at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Michael R. Nestor at 215-923-2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on April 5, 1997. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways ot getting your house back, if you act immediately after the Sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse 717/240-6200 291/45987 ALL TIlAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and 'fhelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by Virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling ~ GE Capital Mortgage Services Inc. vs Gregory Radic, Julia Maczuga In the Court of Common Pleas Cumberland County, Pennsylvania Writ No. 96-4602 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Letter is hereto attached fran attorney. Sheriff's Costs: [J(Jcketing Poundage Pos ting Bills IIdvert is ing Law Library County Mileage Cert Mail Levy postpone Sale Surcharge Law Journal Patriot Pas ter Advance Costs Sheriff Costs Refund to Atty 30.00 15.65 15.00 15.00 .50 1.00 6.20 18.17 15.00 25.00 6.00 316.25 293.95 40.64 5798.16 $1,000.00 798.36 $ 201.64 Pd. by Atty. 3-4-97 THIS WRIT IS RETURNED STAYED 3-5-97 sO?J.nsw B::;"',,-. //,--:;"'.1-"..--". . R. Thomas Kline, Sheriff Sworn and subscribed to before me ...... J lhis v - day of )l<,-~ 1997 ~ Q. ~i<- ~,A5 Prothonotary by (;\'<.l,ll0.'", {/LC,- 1}'-V DeputyO Sheriff .$l r:- .!. .- " ~ I. ",'0 YOU MAY S1'ILL BB l\BLE 'fO SAVE YOUR PROPER1'Y AND YOU HAVE OTHER RIGHTS EVEN IF TilE SHERIFF'S Sl\LE DOES 1'ME PL1\CE. 1- be sold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder. You may find out the bid price by Michael R. Nestor at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Michael R. Nestor at 215-923-2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the. owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on April 5, 1997. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse 717/240-6200 291/45987 .0_. ALL THAT CERTAIN tract of lalld situate in North Middleton Township, Cumberland County, Penllsy Ivallia, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded ill the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling MATTLEMAN, GREENBERG, SHMERELSON, BY: MICHAEL R. NESTOR, ESQUIRE ATTORNEY ID NO. 76429 SUITE 2226 LAND TITLE BUILDING BROAD & CHESTNUT STREETS PHILADELPHIA, PA 19110 215/923-2225 Attorney for Plaintiff WEINROTH & MILLER GE CAPITAL MORTGAGE SERVICES, INC. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 1996-04602 VB. GREGORY RADIC AND JULIA MACZUGA Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at 651 willow Grove Road, Carlisle, PA 17013: 1. Name and address of Owner(s) or Reputed Owner(s): Gregory Radic 651 willow Grove Road Carlisle, PA 17013 Julia Maczuga RR 1 P.O. Box 988 Sugarloaf, PA 18249 2. Name and address of Defendant(s) in the Judgment: Gregory Radic 651 willow Grove Road Carlisle, PA 17013 Julia Maczuga RR 1 Box 988 Sugarloaf, PA 18249 3. judgment is a Name and address of every judgment creditor whose record lien on the real property to be sold: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Merryville Centre Drive St. Louis, MO 63141-5834 4. Name and address of the last recorded holder of every mortgage of record: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Merryville Centre Drive St. Louis, MO 63141-5834 5. Name and address of every other person who has any record lien on the property:. None known. 6. Name and address of every other person who has any record interest in the property and whose interest amy be affected by the sale: Occupant, 651 willow Grove Road Carlisle, PA 17013 7. Name and address of every plaintiff has knowledge who has any interest may be affected by the sale: person of whom the in the property which Occupant, 651 willow Grove Road Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 . C.S. Section 4904 relating to unsworn falsification to a~7 ~ Michael R. Nestor, Esquire Sworn and Subscribed to before . ~ /)~ day of , 1996. NO ANA 0, NEarrCl/I M Y-f>U1l[/cOF rcommiss' ,NEWJr:n~~" lanfrp"",., 1 " '''1, "/limy", Hl~, . j" .' , " (', ' ,'-... J..... ...., ~,-...- -r uO. I I ..".....J fill r~:2 '11'~'ls \~J \S ~f t, ~~ I.t1 On !L('l.'€.1,cb..~ .,~7 /7r4 the 2imifi IlJviod upcn U;o CCiSil: r- \-. , ' .........-. //-,)7-'1{, ;-... t2 .1" 9, /}(7 :~, . LC(.;,[ ~ _.~~.,)..:.. (.t~~, <.1.-):7:'-<- , 0.' !t?L.{ l-<.tXL Ll1M inl~rcst In the real property situilted in ]j~,t. ,~ Tn <t,((.f:,o~_-lr,L=f' Cum bar land Count)', Pa., knr.vIn 8::'J r.wnb:;;.::;:J ,,5: b5-L62,JOJ.~,J../,J( M'- (;1 (('tttt:"'c~ ~n.ll -1"f"f? J'\:!'II .~'.\.....,.,:.:'..... "!"'11 t:.,':..,:..,.:~ II "." .... -: ," c.. U IL.J'\:, l~,:,;, '. ,u~". ..'.. 1.:.. I~J.....,., J\ I,........, t";' ,'t nd by t':~ "-'f'il "\ :,'... ..'.c',.,.,.1 '",-.,:~ It;\) \vn a 'd;0 r~h.. vi Cv :".._'1 ",:.:..:......d !:vli."il. "'1' rr 1'1' ell I' .JU: , I 17, 1,1:;1 ~.;! .d, j ._ ,.:.:!.10 Caption: IN '!lIE <XXJRl' OF co-MlN PLFAS OF aMlER!.J\ND CCXJroIT'f, PENNSYLVANIA CML DIVISION rlIe No. 1996-04602 GE Capital MortKaKc Scrviccs. Inc. Moun t Due $95.000.. 95 Interest 11/9/96 to 3/4/98 $7,497.60 Atty's Comn Costs VS. Gregory Radic and Julia Maczuga TO THE PRCl'IHOl'mARY OF THE SAID COURT: The undersigned hereby certifies that the below doe.; not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as arrended; and for real property pursuant to Act 6 of 1974 as arrended. PRAEX::IPE FUR EXEClJI'ION Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs up:m the following described propeny of the defendant(s) 651 Willow Grove Road, Carlisle. PA ]7013 (See attached legal description) PRAECIPE FOR ATrl>Of-lENr EXEnJ'l'ION ~ Issue writ of attachment to the Sheriff of interest and costs, as above, directing attachment the following property (if real estate, supply six copies of lengthy personalty list) County, for debt, against the above-named garnishee(s) for copies of the description; supply four and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). a lis pendens agains t c ,./ )/ '/ .// -' .. I '-v; // , (Indicate) Index this writ against the garnishee!s) as real estate of the defendant(s) described in the attached exhibit. ;" DATE: 10/28/97 )/'; , l-' ..)j Signature: Print Name: Marissa M. O'Connell "..i..;:W',," .)~.t\'.,,'40':.c...~ .~... / Address: ]00 S. Broad Street, Suite 2226 .- ~ Philadelphia, FA 191]0 Attorney for: GF. Caoital Mortgage Services. Inc. Telephone: (215) 923-2225 Suprerre Court ID No. : 66629 >:: r:: c.. <'- t..:':: ,,:~ '.; 1\ J ~~. , , (); , --. G'::. ...- ~ I _ C' (:: C," c..; '-'-! i:i c_ , '- , -~ " -, 1.1. ,-. 'j U c:- {-} (' 'G (\ IV)IY) \ "'- V'J~ (V) ." 'v) ~\ ~', ~ . ~ , , "\" ~~ ~ \ ' 'Q ~N~~ , ) V] VI I::::, ~ ~~\ ~':::( ~ f". ~ <::Q '-...) . ...... . ~ . : ~ '~ ~ ~ '--" n, '\I<> ~ I. ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the cornmon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the conunon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling >- r~ \:".' \ ..~ ,. , !.l ,< (', " , ",: " c' r', ('...: ~:::: , , - , --- ~ " ,- c.) G", U \" MATTLEMAN, WEINROTH & MILLER BY: MARISSA M. O'CONNELL, ESQUIRE Attorney ID #66629 Suite 2226 Land Title Building Broad and Chestnut Streets Philadelphia, PA 19110 Attorneys for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.: 1996-04602 GREGORY RADIC AND JULIA MACZUGA Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at 651 WILLOW GROVE ROAD, CARLISLE, PA 17013 is scheduled to be sold at Sheriff's Sale on March 4, 1998 at 10: OOam in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the Court Judgment of $95,000.95 obtained by GE Capital Mortgage Services, Inc. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Marissa M. O'Connell, Attorney for GE Capital Mortgage Services, Inc., back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call Marissa M. O'Connell, Esquire at 215-923-2225. 2. You may be able to stop the Sale by filing a petition asking the court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the Sale. (See Notice on page two and how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder. You may find out the bid price by Marissa M. O'Connell, Esquire at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Marissa M. O'Connell, Esquire at 215-923- 2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on April 4, 1998. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse 1/717/240-6200 291/47178 ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, pennsyl vania, bounded and described in accordance with a plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by Virtue of Deed dated october 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling '- ~: l'. i II'\. c::. I!': -, j,:". , - , ..~ i r:.. l....". u_; G..--: -:.::' ,- ... " h, L.' G" ;-) . HATTLEMAN, WEINROTH & MILLER BY: MARISSA M. O'CONNELL , ESQUIRE ATTORNEY ID NO. 66629 SUITE 2226 LAND TITLE BUILDING BROAD & CHESTNUT STREETS PHILADELPHIA, PA 19110 215/923-2225 Attorney for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY VB. NO. 1996-04602 GREGORY RADIC AND JULIA MACZUGA Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA AFFIDAVIT PURSUANT TO RULE 3129.1 GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for the writ of execution was filed the fci.lowing information concerning the real property located at 6',1 Willow Grove Road, Carlisle, PA 17013: 1. Name and address of Owner(s) or Reputed Owner(s): Gregory Radic 651 Willow Grove Road Carlisle, PA 17013 Julia Maczuga 361 Twentieth Street Naples, FL 33964 2. Name and address of Defendant(s) in the Judgment: Gergory Radic 651 Willow Grove Road Carlisle, PA 17013 Julia Maczuga 361 Twentieth Street Naples, FL 33964 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Maryville Centre Drive St. Louis, MO 63141 4. Name and address of the last recorded holder of every mortgage of record: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Maryville Centre Drive St. Louis, MO 63141 5. Name and address of every other person who has any record lien on the property: None known. 6. Name and address of every other person who has any record interest in the property and whose interest amy be affected by the sale: Occupant, 651 willow Grove Road Carlisle, PA 17013 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant, 651 willow Grove Road Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~ . / ~--)~ ~arissa ~O'Connell, Sworn and Subscribed to before tA- me this I" l-q"~1-1-_/._~-JJ (~? ' ,j/L c.,c< ...~ ti, day of , 1997. I.- lj/'.L~ 291/459 Bc'ATR!CIA A, GOTTA r:oL:-,:'/ Public of NewJerse~' My Corr.;r,i;,.~;o(1 E.:.xpircs November 4,1999 >- ~~; '" , I.. lJ.1 , (,~ C) , ,- ; , ,- _0.- C~ " C' c'.' u-:. L' , - " c , I r-. ~ U C..."" l_') . , NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S) : GREGORY RADIC AND JULIA MACZUGA PLAINTIFF/SELLER: GE CAPITAL MORTGAGE SERVICES, INC. GREGORY RADIC AND JULIZ MACZUGA DEFENDANT ( S) : PROPERTY: 651 willow Grove Road Carlisle, PA 17013 NO.: 1996-04602 The above captioned property is scheduled to be sold at Sheriff's Sale on March 4, 1998, at 10:00am in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013. You may hold interest or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Sincerely, -"'-~&-1 / .- v:/ Z ",I:-' - 2/~-t--?-7/ -,' ~t/r1A "" y. / . ,Mar~ssa M. O"Connell, Esqu~re / MATTLEMAl!/WEINROTH & MILLER Suite 2226 Land Title Building 100 South Broad Streets Philadelphia, PA 19110 215-923-2225 291/45987 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the Sheriff's Sale is not stopped, your property will tD the highest bidder. You may find out the bid price by Marissa M. O'Connell, Esquire at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Marissa M. O'Connell, Esquire at 215-923- 2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on April J 1998. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAll GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse 1/717/240-6200 291/47178 ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the cornmon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the cornmon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded october 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling WRIT OF EXECUTION and/or ATrACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, %-4602 CIVIL 111x TCml CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland COUNTY To satisfy the debt, inlerest and costs due~_qLC:i'!pi~LlJ.~ MOItqage Serv ices, I nc . ---~-_.-.._..,._-'---_..__._----- PLAINTlFF(S) from Gregory Radic Llnd~':',U~_~l-!Clczu'1~~_~_~______ 651 Willow Grove ROLld -~---_.--~_._._~...._-_._-~._--_._---- Carlisle, PA 17013 DEFENDANT(S) ----_._--~-~---,~.__..- ---. (1) You are directed 10 levy upon the property ollhe delendant(s) and to sell See l_<;!ilil,L de'i<;:dpJJon~__,_____~__ AmountDue~95,OOO.95 Interest 11/9/96 to 3/4/98_~,497.60 (2) You are also direcled 10 attach the property of the delendant(s) not levied upon in the possession of _ GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued: (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof: (3) If property olthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, % L.L. Due Prolhy Olher Costs $1.00 Atty's Comm Atty Paid Plaintiff Paid $882.86 Date: November 21, 1997 Lawrence E. Welker, Prothonotary Prothonotary. Civil Division by -7;'m K X/t; fJj Deputy REQUESTING PARTY: Name Marissa M. O'Connell, ESq. Address: 100 S. Broad St. Suite 2226 Philadelphia, PA 19110 AUorney for: GE Capital Mortqaqe Services, Inc. Telephone: ( 215 t 923-2225 __~~_ Supreme Court 10 No, 66622.__~_____ R!:'I1J C('Tr,-:--",'lr l..{.' , I ",. ". . t 1\10 l1.... ,_ ,-' . . .. '- '-"'.~:"" 1 It , ~, ,,.-,' I" t,.. ' .......~ :.~) GIl /1.'1" ",(,11 ! ;,') the sheriH levied upvn lhe delEi,1::,. !nleff3$1 ill the real ~Jr,;:,>('n'! si,I::::tc1 in l.L..::J. !} /, I ,,' Ii, ,,-,-JL'f' t\l'(r:~' --Irl":'~ C~'l''''~',' '")., , . .,lo , L ; :, .~ oJ ...1 \ " ". ~ I \ .' ' " _ .e') 'I ~,' '1-' I" (I I't' I. Ji , (",., {j, Q .'. .,'..;1.\1.. _.,'J ~,.:;. J;...~__!-'-'..l- {tl. ,"J t n'):" 1" " -D-~\-i~'--- 2,'j','; , .' ,:> ",: ;. ~i ~:...i:i~lit H A' I !t:e;'; \' :'.. . ,~:.. "'[I" "lId \," l"'~ ." ,,' .: ,:.)." ~ {\ . u'j l;i:~: .,'..., ~ i . "i''j'~ ......,,~;:.rl I'ere.ln """"'".,II...l,"'" I I . ",'",,: ,. _jj..'.:l..1-iL-.-----.--.. t",.' 1.'(.1 ~i' ._-:':/I..../~..~,'t...'( II~.~ ',' .~ ~. -~~'~.;.~t. rl /:.', ( ".,' i" 1-'F.5, V,,, "'" -],; 1.5, ~V [0 9 \17, ^ON . '.1;', .: " ,,1-.1 :i (... ,I, "..J'... ~ -1.::]0 MATTLEMAN, WEINROTH & MILLER BY: MARISSA M. O'CONNELL, ESQUIRE ATTORNEY ID# 66629 Suite 2226 Land Title Building Broad and Chestnut Streets Philadelphia, PA 19110 215/923-2225 Attorneys for Plaintiff Our File #291/45987a GE CAPITAL MORTGAGE SERVICES, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff NUMBER: 1996-04602 vs. GREGORY RADIC JULIA MACZUGA Defendant AFFIDAVIT OF SERVICE 3129.2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Marissa M. 0' Connell, Esquire, of full age, being duly sworn according to law, upon my oath, depose and say: 1. I am a member of the firm of Mattleman, Weinroth & Miller, attorneys for the Plaintiff in the above entitled cause of action. 2. On January 8, 1998, a copy of the Notice of Sheriff's Sale of Real Property was personally served upon the Defendant, Gregory Radic, by the Sheriff of Dauphin County. 3. On April 28, 1998, the property located at 651 Willow Grove Road, Carlisle, Cumberland county, Pennsylvania, was posted with a copy of the Notice of Sheriff's Sale of Real Property, per Order of Court dated April 9, 1998. 4. On April 28, 1998, a copy of the Notice of Sheriff's Sale of Real Property was sent to the Defendant, Julia Maczuga, by certified and regular mail, return receipt requested, per Order of Court dated April 9, 1998. 5. On November 17, 1997, a copy of the Notice of Sheriff's APR 0 7 1995oP MATTLEMAN, WEINROTH AND MILLER BY: MARISSA M. O'CONNELL, ESQUIRE ATTORNEY ID NO.: 66629 2226 Land Title Building 100 South Broad Street Philadelphia, PA 19110 (215) 923-2225 Attorney for P1aintiff(s) Our file no.: 291/45987a GE CAPITAL MORTGAGE SERVICES, INC. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO. 1996-04602 GREGORY RADIC JULIA MACZUGA Defendants ORDER GRANTING ALTERNATIVE SERVICE PURSUANT TO PENNSYLVANIA R.C.P. 430 This matter being opened to the court by Marissa M. O'Connell Esquire, attorney for GE Capital Mortgage Services, Inc. upon Motion for Order Granting Alternative Service, pursuant to Pennsylvania R.C.P. 430, and the Court having reviewed and considered the pleadings submitted in connection with this matter, and for good cause shown: IT IS on this q-Ji. day of 1998, rwA..:.c ORDERED that the Motion for Alternative Service by service of the Notice of Sheriff Sale of Real Property by posting and tacking the Notice of Sheriff Sale of Real Property on the premises and by regular and certified mail, to the Defendant's last known address, is hereby GRANTED. BY THE COURT: J~/~ r<' ~ J. lct I H<jl.fD )M GE Capital Mortgage Services Inc, -vs- Gregory Radic and Julia Maczuga In the Court of Common Pleas of Cumberland County, Pennsylvania No. 96-4602 Civil Term Michael E. Barrick, Deputy Sheriff who being duly sworn according to law, says on January 6, 1998 he posted a copy of Real Estate Writ Notice Poster and Description at 65 I Willow Grove Road, Carlisle, Cumberland County, Pennsylvania according to law, R. Thomas Kline, Sheriff who being duly sworn according to law, says he made diligent search and inquiry for one of the within named defendants to wit: Gregory Radic, but was unable to locate him in his bailiwick. He therefore deputized the sheriff of Dauphin County, to serve the within Real Estate Writ Notice, Poster and Description according to law. Dauphin county return: And now January 8, 1998 at3:10 P.M. served the within Real Estate Writ Notice Poster and Description upon Gregory Radic by personally handing to Gregory Radic I true and attested copy of the original Real Estate Writ Notice Poster and Description and making known unto him the contents thereof at 80 Suffolk Road, Harrisburg, PASo answers: J .R. Lotwick, Sheriff. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a one of the within named defendants, to wit: Julia Maczuga a notice of the pendency of the action by certified mail return receipt request deliver to address only to her last known address 361 Twentieth Street, Naples, FL on January 6, 1998. The letter was returned to the Sheriff's Office eon January 26, 1998 within reason checked ATTEMPTED UNKNOWN. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the within Real Estate Writ Notice Poster and description in the following manner: The sheriff mailed one of the within named defendants to wit: Gregory Radic a notice of the pendency of the action by certified mail return receipt requested deliver to addressee only to his last known address 80 Suffolk Road, Harrisburg, Pennsylvania. The letter was mailed under the date of January 6, 1998. The return receipt card was returned to the Sheriff's Office on January 8, 1998 the return receipt card signed by Gregory Radic. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed one of the within named defendants to wit" Gregory Radic a notice of the pendency of the action by regular mail to his last known address 80 Suffolk Road, Harrisburg, Pennsylvania. The letter was mailed under the date of February 5, 1998 and never returned to the Sheriff's Office, R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: the Sheriff mailed a notice of the pendency of the action by regular mail to one of the within named defendants to wit: Julia Maczuga to her last known address 361 Twentieth Street, Naples Florida. The letter was mailed under the date of January 30, 1998 and returned to the Sheriff Office on February 9, 1998 with reason checked return to sender insufficient address, R. Thomas Kline, Who being duly sworn according to law, says he made diligent search and inquiry for one of the within named defendants to wit: Julia Maczuga but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ Notice Poster and Description according to law, Dauphin County Return: I Jack Lotwick, Sheriff of Dauphin County, State of Pennsylvania. do hereby certify and return, that I made diligent search and inquiry for Julia MacZllga defendant named in the within notice of Sheriffs Sale and that I am unable to locate her in the County of Dauphin, and therefore return same NOT FOUND, February 27, 1998, Ex boyfriend states last time he saw her was in 1996. As far as he knows she is living with mother in Florida. So answers: J.R. Lotwick, Sheriff Dauphin County. R. Thomas Kline, Sheriff who being duly sworn according to law, say he served the within Real Estate Writ Notice Poster and Description in the following manner: Thc Sheriff mailed one of the within named defendants to wit: Julia Maczuga a notice of the pendency of the action by certified mail return receipt requested deliver to addressee only to her last known address 80 Suffolk Road, Harrisburg, Pennsylvania. The letter was mailed under the date of February 17, 1998 and was returned to the Sheriff Office on March 5, 1998 with reason checked UNCLAIMED. Timothy Reitz Deputy Sheriff, who being duly sworn according to law, says he posted a copy of a Sheriff s Sale notice on the property of Gregory Radic and Julia MacZllga located at 651 Willow Grove Road, Carlisle, Cumberland County, Pennsylvania per Court Order. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the within Sheriffs Sale Notice in thc above entitled action in the following Manner: The Sheriff mailed one of the within named defendants to wit: Julia MacZllga a notice of the pendency ofthe action by CERTIFIED MAIL RETURN RECEIPT REQUESTED RESTRICTED DELIVERY DELIVER TO ADDRESSEE ONLY TO THE ADDRESS OF 651 Willow Grove Road, Carlisle, Pennsylvania per Court Order. This letter was mailed under the date of April 28, 1998 and returned to the Sheriffs Office on April 30, 1998 with the reason checked Return to Sender Authorized time for forwarding has expired. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the within Sheriffs Sale Notice in the above entitled action in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Julia MacZllga by regular mail to her at 651 Willow Grove Road, Carlisle, Pennsylvania per Court Order. This letter was mailed under the date of April 28, 1998 and never returned to the Sheriffs Office. So Answers: /.:"<~.z.!.~-~-:_,<~ 4~.-:? , R. Thomas Kline, Sheriff By ,4K./.~ ..JLtr Real Estate Deputy SENDER: . ComPk.'le Il!#ffi".' Orll/Of '2 for fllX!,!londl SCfYIl;:CS .Prt~r your I1.1mo and OOd/oss on thll revur,o 01 Ih" form 50 thaI WI) Col" Hllurn thIS Colrd 10"," . A".ICh th.s lotm to Ire lrOllI of the ma"ptllctI, Of OIl rho! b;1Ck If 5opaco dOlls not ptIfm't . ThQ Rct,!," Rucolpt will $how to whom thQ ,lflJ(;~ W,"1.1 do!I.....!llod and the d,lhl (X!hv!!fod 3, Arl..-r.. AI'trlro..,....t In ... GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013 5, Received By: (Print Name) I also wish to receive the following services (lor an extra fde): 1. 0 Addressee's Address 2. 0 Restricted Delivery Consul! postmaster for fee. 4<1. Article Number P 965 140 580 4b, Service Type . rJ:;",," :"f-';':: , ~ CERTIFIED , ~ I ,: I I . I I" 1 , Domestic Return Receipt 0X1 iJ45q~ 7 'to ,,'. ''I'' ;, SENDER: .~leitemo1ard/or2lor&cXjltionalserviCe!l. ., IPri"; rod' name and address on tho reverse of this larm $0 that wo can relurn this card 10",", . Mach thiS lorm to IhI front oltha mailpiece, or OI'J tho back if space does rot permit . The Return Receipt will &how to whom the articlO was oolivarcd and lhe elate delivercd ) 3. Article Addr:essed lo~ GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013 5. Hecelved By: (Print Name) 291/4S9e,'1 I also wish to recei"e the following services (for eel extra tee): 1. 0 Addressee's Address 2. 0 Restricted Delivery Consult postmaster tor fee. 43. 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IN THE mJRT OF CCM1:X'I PLEAS OF CLWlERlJIND CXJJNI'Y, PENNSYLVANIA CIVIL DIVISION Caption: Gt: Capital Mortgal\e Services, Inc. file No.1996-04602 ilJroun t Due $95,000.96" vs. rnterest $14,729.66 from 11/8/96 to 6/9/99 Gregory Radlc and Julia Haczul\a Atty's Comn Costs TO THE PROIHONJTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as arrended: and for real property pursuant to Act 6 of 1974 as amended. PRA.El:IPE FOR EXECUTION Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 651 Willow Grove Road, Carlisle, PA 17013 (See attached legal description) PRAECIPE FOR A'ITJ\Clf-lENT EXEU1l'ION Issue writ of attachment to the Sheriff of interest and costs, as above, directing attachment the following property (if real estate, supply six copies of lengthy personalty list) County, for debt, against the above-named garnishee(s) for copies of the description: supply four and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibir~ " I ;{ \/ /;' DATE: 3/5/99 Slgnature: " L/ ,t" , / Print Name: Sharon Oras Morgan , 2i.~~;-\f~~1~'~'- Address: 100 S. Broad Street. Suite 2226 Philadelphia, PA 19110 Attorney for: Gt: Capital Mortgage Services. Inc. Telephone: (215) 923-2225 Supreme Court 10 No.: 60068 \~\ ~ " ~ ~ t.~ ~, '\.... ~~ ~, < ' "" " "J " q ...~ '-.; ~ \.'\1"\ \ ~ \' ~ B,<:J~ao l::-" r' r, ~ , (~ \.: ;/\ '.j ~ fY', \)1 "" z: rr\'~ . If'! \ 0j c;~' .~ ~rt " r'. '" ~ " '" " ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by Virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling , . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder. You may find out the bid price by Sharon Oras Morgan, Esquire at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Sharon Oras Morgan, Esquire at 215-923-2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid tc the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on July 9, 1999. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse 1/71 7 /240-6200 291/459B7a ALL THAT CERTAIN tract of land situate in North Middleton Townshi.p, Cumberland County, Pennsylvania, bounded and described in accordance with a plan prepared by Stephen G. Fisher, P.L.S., dated March 1Bth, 19BB and recorded in the Office of the Recorder of Deeds for Cumberland County in plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South OB degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 6BB.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 59B.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No.2 on plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated october 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S) : GREGORY RADIC JULIA MACZUGA GE CAPITAL MORTGAGE SERVICES, INC. PLAINTIFF/SELLER: DEFENDANT(S) : PROPERTY: DOCKET NUMBER: GREGORY RADIC JULIA MACZUGA 651 WILLOW GROVE ROAD, CARLISLE, PA. 17013 1996-04602 The above captioned property is scheduled to be sold at Sheriff's Sale as follows: Sale Date: June 9, 1999 Sale Time: 10:00AM Sale Location: Cumberland County Courthouse s. Hanover Street Carlisle, PA 17013 You may hold a mortgage or judgment on the property which will be extin~uished by the sale. You may wish to attend the sale to protect your ~nterest. A schedule of distribution will be filed by the Sheriff on a date s~ecified by the Sheriff not later than 30 days after sale. Distribution w~ll be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. . Sincerft.l..y, "" f ,., '/7 J r. , / /.; i. ./\>v'IC//,~~/j; Sharon O. Mo gan MATTLEMAN, EINROTH & MILLER Suite 2226-Land Title Building 100 South Broad Street Philadelphia, PA 19110 215-923-2225 Our File Number: 291/45987a , MATTLEMAN, WEINROTH & MILLER SUITE 2226 - LAND TITLE BUILDING BROAD AND CHESTNUT STREETS PHILADELPHIA, PA 19110 215-923-2225 ATTORNEYS FOR PLAINTIFF By: Sharon o. Morgan Attorney I.D. Number: 60068 ======================================================================== GE CAPITAL MORTGAGE SERVICES, INC. 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY NUMBER: 1996-04602 vs. GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA 361 TWENTIETH STREET NAPLES, FL 33964- Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 ------------------------------------------------------------------------ ------------------------------------------------------------------------ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 651 WILLOW GROVE ROAD, CARLISLE, PA. 17013: . , EXHIBIT 'B' - MORTGAGE HOLDERS GE CAPITAL MORTGAGE SERVICES, INC. (Plaintiff Herein) 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834 MATTLEMAN, WEINROTH & MILLER SUITE 2226 - LAND TITLE BUILDING BROAD AND CHESTNUT STREETS PHILADELPHIA, PA 19110 215-923-2225 ATTORNEYS FOR PLAINTIFF By: Sharon o. Morgan Attorney I.D. Number: 60068 ======================================================================== GE CAPITAL MORTGAGE SERVICES, INC. 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY NUMBER: 1996-04602 vs. GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA 361 TWENTIETH STREET NAPLES, FL 33964- Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 ------------------------------------------------------------------------ ------------------------------------------------------------------------ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 651 WILLOW GROVE ROAD, CARLISLE, PA. 17013: , 5. Name and address of every other person who has any record lien on the property: None known. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Occupant{s) - 651 WILLOW GROVE ROAD, CARLISLE, PA. 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant{s) - 651 WILLOW GROVE ROAD, CARLISLE, PA. 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Sworn to and Subscribed before me this q tn day of1'Y'\ (\\~ \l ~~" d l c.. l~'L.l '~~\\llt~_ TERRI L. SMITH Not"z-: ;Ublic of New Jersey My Cc".::I~ssion Expires Jan. 28, , : By 2002 291/45987a MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID #60068 Suite 2226 Land Title Building Broad and Chestnut Streets Philadelphia, PA 19110 Attorneys for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.: 1996-04602 GREGORY RADIC AND JULIA MACZUGA Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at 651 willow Grove Road, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on June 9, 1999 at 10: OOam in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the Court Judgment of $95,000.95 obtained by GE Capital Mortgage Services, Inc. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Sharon Oras Morgan, Attorney for GE capital Mortgage Services, Inc., back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call Sharon Oras Morgan, Esquire at 215-923-2225. 2. You may be able to stop the Sale by filing a petition asking the court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the Sale. (See Notice on page two and how to obtain an attorney) . .' YOU MAY STILL BB ABLB TO SAVE YOUR PROPERTY AND YOU HAVE OTHBR RIGHTS BVBN IF THB SHBRIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder. You may find out the bid price by Sharon Oras Morgan, Esquire at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Sharon Oras Morgan, Esquire at 215-923-2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on July 9, 1999. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAItE THIS PAPER TO YOUR LAWYER AT ONCE. Ii> YOU DO NOT HAVE A LAWYBR OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse 1/717/240-6200 291/45987a I :1 I 1 I I , 'I ,I I I I i i ! i .. ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. I as shown on the aforementioned subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the conunon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. I as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling " WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 96-4602 CIVIL 19< Term CIVIL ACTION. LAW TO THE SHERIFF OF COUNTY: ClmhP.rlAnn To satisfy the debt, interest and costs due GE Capital Mortqaqe Services, Inc. PLAINTIFF(S) from Gregory Radic and Julia Maczuga 651 Willow Grove Rd. Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant(s) and to sell ..,.,__.Bf:fLatti'lched legi'll description DEFENDANT(S) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of _ GARNISHEE(S) as follows: and to notify the garnlshee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of fhe defendant(s) or otherwise disposing thereof; (3) If property olthe defendant(s) not levied upon an subject to attachrnent is found in the possession of anyone other than a named garnishee, you are directed to notify him/herfhat he/she has been added as agarnishee and is enjoined as above stated, Amount Due $95,000.95 Interest $l4, 729.66 from 11/8/96 to 6/9/99 Atty's Comm Atty Paid Plaintiff Paid % LL Due Prothy Other Costs $1. 00 ~1. 725.94 Date: Curtis R. Lona Prothonotary, Civil Division Mrlrrh lOr ,qqq by: "../11<'<- K x;1? iJl j/ Depuly REQUESTING PARTY: Sharon Oras Morqan. Esq. 100 S. Broad St., Suite 2226 Philadelphia. PA 19l10 Attorney for: C;E Capiti'll Mortgage Services. Inc. Telephone: (? 1 'i-Q?1-?225 Supreme Court ID No, fiOOfiR Name Address: f"''''' ro. e . sl /" i r "., , ,.~,. . r..-..,-....... ...~_... '""". - ...-..' J..... ~a,/J'l1~ /J../r'i 9 t~I") c.hO\"U in '~rl'.J ll-"'n 'l'lt:, ..J~ir> ..,.:,.,...., Il'"" ~'':'" dl lli~nr~~:" :'~f...,...1 ~.L' Ij:.,,;.tH..I.,,;;j'~ b.....~-""l'n 'h_ "Mll'.~'"'''' -""-1-" '''/4 ././. A 'JJtt. /J // ~""'" IJ t:it IQU '!'Jr-:t,,:tl.Y ';".U';':".1,.':"d i.l 1'/1 ~ -.~ .. "..i. 5'D C l. '. -,' ,'". ,'. uf";1,..."loJ"j.,",.'l.,,'t,I;,.'.. a:lllJ .1, .... .., '. .~..~" '.~ I F:~~. .. h'y:~ ~.;,': :'...:,':.:';',~~ "": /!:L/ I~ . . ..... .., _.,....J ,. ._Id.. ,,' ..... .R..... fe'_.. ..'='t.:, ..... , . ~__.;..;n,~ ".<';;.,r:;"y(:; ....,.-. "." ._." r.,,'....I.~ II A I' '.;..; 0:1 ~:...Il\:J t h "'i;:..~' '.~. ~'.~;. i.,......_ Pi. 't. " " , '. ' . "I ' -l'~ "''''I'' '~f''''' -..,\. t,,,.. "'~""''''''~'''''';:> 1'~'''r.'rIJ,r'',.'r..r; ......r~'" 1 .....' 'dll\" U:;t~; 1".1 ~I:'J :.;;:~~,n::I;...... ,!i<....~I;-;\.Jl.~~-...\.: l~ .....':i.. ~,'~< ,,1.. JJ, l?'i) By~-;t;~u, -e/L;g- , C-l CUil CUil = @ 1iV", J (l\ rT) (,\, -r :.l 1."-) c- ('y fJ0 '" -:tI i CL U ;- i ~ -- ;r 1) It,~ -- { '/ .~ u f- .;: N ~5.c 1- q , . (-I ~-:_~ - - - .. - u t~/, ,-)~r.. - - - - ,'!JJ :r.:. - -.. -a V C_', <.>- :::;?- -r 0 '~r' r'J- 'I- V (;[ ':.: ~-~ i) 0 8 J 0 J 0 0-" 0 tJ 0 2,.... . , ' 2 [~ . (i',1 N ;1.::1 (Q 0 0 0 rf) 0 rf) 0 If) 0c:1 ~: } , : \-' tl!UJ - '" - L~ . :JO- [{) l{) r{) cO r-- cr I[) &:> I{) -:t If)rI) () ~.. 0 ", (1'> :,':) -:r CO '" - () ~-cO t- I.~. ~, 0 C1' u 7fJ C- 1)0 ()O 0 " tt U, rO ,0 '. -t 01 () U " ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown'.on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, Sputh 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at Lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the conunon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, N0rth 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the conunon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. I as shown on the aforementioned Subdivision Plan; thence by Lot Number I, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. . IMPROVEMENTS THEREON: Residential Dwelling ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. I as shown'.on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, Sputh 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the conunOIl corner "ith Lot Number 3 as shown on the aforementioned Subd~vision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the conunon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number I, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by Virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling ~ ',. ,- u ,c.~ ~~ttJ (?~::; (-;.::: IT! ~~ F: ." U C'l ~. '" .- .~ a.. ;0- t-- -7 <- '7~~ C - C)~ (::l~i :;:i0 '17'"-:": ::~JW ::.4a.. :5 o N ~- '-' Cl a'. 0"' J'o YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder, You may find out the bid price by Sharon Oras Morgan, Esquire at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Sharon Oras Morgan, Esquire at 215-923-2225, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened, 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you, 6, You may be entitled to a share of the money which was paid for your house, A Schedule of distribution of the money bid for your house will be filed by the Sheriff on March 1, 2000. This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after, 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. cumberland County Court Administrator 4th Floor Cumberland County Courthouse 1/717/240-6200 291/45987 , ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. I as shown-on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, Sputh 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the conunon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision P::'an; thence by Lot Number I, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Juli.a Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling ," . ~ "" ;>- t;: j'~; N jt: U-l';.; 0"'- - c.:~;- i;: --::?:j '... t-.: (")' .,~\0 ' ( c::.,:. N "I..... ...c2 ~-d" ,..., llittJ l1-~i-: ,-, }?LJ- F..' c:; u. 0' '5 0 Cf' <.:; , 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold, GE Capital Mortgage Services, Inc, (Plaintiff herein) 625 Maryville Centre Drive St, Louis, MO 63141-5834 Child Support Enforcement Agency P.O, Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Maryville Centre Drive St. Louis, MO 63141-5834 5. Name and address of every other person who has any record lien on the property: None known, 6. Name and address of every other person who has any record interest in the property and whose interest amy be affected by the sale: Occupant, 651 willow Grove Road Carlisle, PA 17013 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant, 651 Willow Grove Road Carlisle, PA 17013 , MATTLEMAN, WEINROTH << MILLER BY: SHARON ORAS MORGAN, ESQUIRE ATTORNEY ID NO. 60068 SUITE 2226 LAND TITLE BUILDING BROAD << CHESTNUT STREETS PHILADELPHIA, PA 19110 215/923-2225 Attorney for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC. eOURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO. 1996-04602 GREGORY RADIC AND JULIA MACZUGA Defendants AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at 651 willow Grove Road, Carlisle, PA 17013: 1. Name and address of Owner(s) or Reputed Owner(s) : Gregory Radic 80 Suffolk Road Harrisburg, PA 17112-2952 Julia Maczuga 651 willow Grove Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the Judgment: Gregory Radic 80 Suffolk Road Harrisburg, PA 17112-2952 Julia Maczuga 651 Willow Grove Road Carlisle, PA 17013 \ . -, '- . I 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Maryville Centre Drive St. Louis, MO 63141-5834 Child Support Enforcement Agency P.O. Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: GE Capital Mortgage Services, Inc. (Plaintiff herein) 625 Maryville Centre Drive St. Louis, MO 631'1-5834 5. Name and address nf every otL~r person W;lO has any record lien on the pro~_rty: None kn,":\pn. 6. Name ann address ~!' every othE._" person '..:,() has any record interest in the rroperty QUO whose int~rest amy be affected by the sale: Occupan:., 651 Willow Grove 11.0<:.1 Carlisl~, PA 17013 7. Name and address of every ,erson of whom the plaintiff has knowledge who has aay interest in the prcperty which may be affected by the sale: Occupant, 651 Willow Grove Road carlisle, PA 17013 ,. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder, You may find out the bid price by Sharon Oras Morgan, Esquire at 215-923-2225. 2, You may be able to petition tJ:1e Court to set aside the Sale if the bid price was grossly inadequate compared to the market vallJe of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale, To find out if this has happened you may call Sharon Oras Morgan, Esquire at 215-923-2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened, 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for YOll'- house will be filed by the Sheriff on March 1, 2000. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheliff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse 1/717/240-6200 291/45987 ALLTRAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shownNon the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, Sputh 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and wi'~h line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. I as shown on the aforementioned Subdivision Plan; thence by Lot NUm0er I, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on ~lan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by Virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia M~czuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling .' REAL ESTATE SALE No. uil tf~ ;).", tit')'! the s:i::;r:;'; ;~:~;ir.~d ~.lr;,n :he (:-:.!.2nd~i:'i .:1 , interest in the real property si\';~~,d in /r},.,.,ZL MI;'//tf,~~ ,'/ l > ,,-,' ;' <9" Cum"""and C'lj"" P'l '"'~''' '. "~" ."..,...'....r(l "S' /51 /./. tl1. J (li D. ,;..,;. v\.'11 0 tit) I c: " 1,,1,.-,,".1. t. i.d il,;~~'_;I.:-;:,.. (.i. . /I. I J ....1 ~J~i. ~ ,........ ,)I',~,< Ivt:" :1"'1 ((10"'.) f ~!,: ,<:~,~::'''i~p.,,,, (:'" ;':vbil"it 11/1," j;l'~ri \,/,'jl _0 ~lll" ",',v """'j ,_..'.1..,\.".".'-.1 ,,1.-'" J'~ r\ 1,\_,1 .It. (1 AaA- this writ and b'J Ihis lef3'Lfise incorparatcd herein, "1te:d2../~)2" ).t. /<;99 Byd7~~~ ,}d..bf ~CJ.k~ VI'l'<'\" :':H::Jd 66. Hd zo p IZ 130 .'.. I (j,IJ .:Idib:;hS ;111.. JL 3:i:;L:lO ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberiand County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. I as shown"on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, Sputh 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the conunon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the conunon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. I as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subj ect to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by Virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory. Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE SUITE 2226 - LAND TITLE BUILDING BROAD & CHESTNUT STREHS PHILADELPHIA, PA 19110 215/923-2225 Attorneys for Plaintiff - GE CAPITAL MORTGAGE SERVICES,INC. Plainti ff vs, GREGORY RADlC AND JULIA MACZUGA Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO,: 1996-04602 AFFIDAVIT PURSUANT TO RULE 3129,1 GE Capital Mortgage Services, Inc., Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following infonnation concerning the real property located at 651 Willow Grove Road, Carlisle, P A 17013: 1. Name and address of Owner(s) or Reputed Owner(s): Gregory Radic 80 Suffolk Road Harrisburg, PA 17112-2952 Julia Maczuga 651 Willow Grove Road Carlisle, PA 17013 2, Name and address of Defendant(s) in the Judgment: Gregory Radic 80 Suffolk Road Harrisburg, PA 17112-2952 Julia Maczuga 651 Willow Grove Road Carlisle, P A 17013 GE Capital Mortgage Services, Inc, (Plaintiff herein) 625 Maryville Centre Drive SI. Louis, MO 63141-5834 3, Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Child Support Enforcement Agency I Courthouse Square Carlisle, PA 17013-3387 4, Name and address of the last recorded holder of every mortgage of record: GE Capital Mortgage Services, Inc. {Plaintiff herein} 625 MaryvilJe Centre Drive SI. Louis, MO 83 14 I -5834 5, Name and address of every other person who has any record lien on the property: None known, 6, Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Occupant, 651 Willow Grove Road Carlisle, PAl 70 I 3 7, Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant, 651 Willow Grove Road Carlisle, PAl 70 I 3 chance you \~ill have of stopping the Sale, (See Notice below and how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Sharon Oras Morgan at 215-923-2225, 2, You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property, 3, The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale, To find out if this has happened you may call Sharon Oras Morgan at 215-923-2225, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened, 5, You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer, At that time, the Buyer may bring legal proceedings to evict you, 6, You may be entitled to a share of the money which was paid for your house, A Schedule of distribution of the money bid for your house will be filed by the Sheriff on January 3, 200 I, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 1-717-240-6200 291/45987a MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE SUITE 2226 - LAND TITLE BUILDING BROAD & CHESTNUT STREETS PHILADELPHIA, PAl 911 0 215/923-2225 Attorneys for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs, NO,: 1996-04602 GREGORY RADlC AND JULIA MACZUGA Defendant AFFIDAVIT PURSUANT TO RULE 3129,1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA GE Capital Mortgage Services, Inc., Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 651 Willow Grove Road, Carlisle, P A 17013: 1. Name and address of Owner(s) or Reputed Owner(s): Gregory Radic 80 Suffolk Road Harrisburg, PA 17112-2952 Julia Maczuga 651 Willow Grove Road Carlisle, PA 17013 2, Name and address of Defendani(s) in the Judgment: Gregory Radic 80 Suffolk Road Harrisburg, PA 17112-2952 Julia Maczuga 651 Willow Grove Road Carlisle, P A 17013 chance you \~ill have of stopping the Sale, (See Notice below and how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. Cumberland County Court Administrator 4"' Floor Cumberland County Courthouse Carlisle, PA 17013 1-717-240-6200 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, You may find out the bid price by calling Sharon Oras Morgan at 215-923-2225, 2, You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3, The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale, To find out if this has happened you may call Sharon Oras Morgan at 215-923-2225, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5 , You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer, At that time, the Buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your house, A Schedule of distribution of the money bid for your house will be filed by the Sheriff on January 3,2001, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7 , You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale, YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 291/45987a ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumbe.cland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P. L. S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot. No. 1 as shown"on the aforementioned subdivision Plan; thence by land of the aforementioned Gardner, Sputh 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the conunon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. I as shown on the aforementioned Subdivision Plan; thence by Lot Number I, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded october 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at gr~nted and conveyed unto Gregory, Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling On ~ :/p, ~ the snerifllevieQ upon the de(6noam~ Interest In the real property situated In -4,'J /.1- /lY/.;...uIJ;...... --;:~ Cumberland County, Pa" known ~nd number~~M~:t'S; IJ. r1~ and more fu!' . p'bed o~I~~lt':~:'f~~lfh this wn' la~~l}Wy tm~~ r~Jr~~~,r~e I ~S,?SP9tJ;~,\OO:1 twellMh. ~~e~1a-d..,~,d.nro BJyjlZh_'~_'__ ~UA:R~ REAL ESTATE SALE No. 1,,1 (, i' ::' II L d:S J, .:J~', , " , '--.".' MATTLEMAN, WEINROTH & MILLER By: Sharon Oras Morgan, Esquire Attorney 10# 60068 Suite 2226, Land Title Building Broad & Chestnut Streets Philadelphia, P A 19110 (215) 923-2225 Attorneys for Plainti ff GE CAPITAL MORTGAGE SERVICES, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs, No,: 1996-04602 GREGORY RADlC AND JULIA MACZUGA Defendants AFFIDAVIT PURSUANT TO RULE 3129,2 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF PHILADELPHIA ) I Sharon Oras Morgan, Esquire, of full age, being duly sworn according to law, upon my oath, depose and say: 1. I am a member of the finn of Mattleman, Weinroth & Miller, attorneys for the Plaintiff in the above entitled cause of action, 2, On October 9, 2000, a copy of the Notice of Sheriffs Sale of Real Property was served on the defendant, Gregory Radic, On October 9,2000, a copy of the Notice of Sheriffs Sale of Real Property was served on the defendant, Julia Maczuga by posting of the property per Order of Court, On October 4,2000, a copy of the Notice of Sheriff's Sale of Real Property was served on the defendant by certified mail per Order of Court, On October 10, 2000, a copy of the Notice of Sheriffs Sale of Real Property was served on the defendant by regular mail per Order of Court, A copy of the Sheriffs Return of Service is attached hereto and made a part hereof as -let I c{7%1LL- GE Capital Mortgage Services, [nc, -vs- Gregory Radic and Julia Maczuga In the Court of Common Pleas of Cumberland County, Pennsylvania No, 1996-4602 Civil Richard E. Smith Deputy Sheriff who being duly sworn according to law, says on October 9, 2000 at 1:16 o'clock P,M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Gregory Radic by making known unto Margaret Radic wife at 65 I Willow Grove Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said t rue and attested copies of the same. Richard E, Smith Deputy Sheriff, who being duly sworn according to law. says on October 9, 2000 at I: 16 0 'clock P,M, He posted a copy of Real Estate Writ Notice Poster and Description on the property of Gregory Radic and Julia Maczuga located at 651 Willow Grove Road, Carlisle, Cumberland County, Pennsylvania according to law, R, Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheirff mailed a notice of the pendency of the action to one of the within named defendants to wit: Julia Maczuga by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to her last known address 651 Willow Grove Road, Carlisle, Pennsylvania, This letter was mailed under the date of October 4, 2000 and returned to the Sheriffs Office on October 23, 2000 with reason checked Unclaimed, R, Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Gregory Radic by regular mail to his last known address 651 Willow Grove Road, Carlisle, P A, This letter was mailed under the date of October 10,2000 and never returned to the Sheriffs Office, R, Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Julia Maczuga by regular mail to her last known address 651 Willow Grove Road, Carlisle, P A, This letter was mailed under the date of October 24, 2000 and never returned to the Sheriffs Office, J/J../ ./;}?,:;-', ,s~~~<< 'f~~"""': R~as Kline, Sheriff B 'i;::;.... J/--ff Real Estate Deputy iN '\lIE CDJRT OF cnMJN PLEI\S OF CLfoIflERLIIND CCl.JNrY, PENNSYLVANIA CIVIL DIVISION Caption: GE CapitaJ Mortgage Services, Inc. File No, 1996-04602 AImunt Due $95,000.95 Interest $29,955.84 from 11/8/96 to 9/7/01 V:3. Gregory Radle and .Julia Hnczuga !,tty's Comn Costs TO THE PRaIHOrmARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of Judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECt1I'ION Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 651 Willow Grove Road, CarlIsle, PA 17103 (See attached legal descriptio,") PR!\ECIPE FOR ATTJlDfo1ENI' EXEOJl'ION Issue writ of attachment to the Sheriff of interest and costs, as above, directing attachment the following property (if real estate, supply six copies of lengthy personalty list) County, for debt, against the above-named garnishee(s) for copies of the description; supply four .. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: Seotember 7, 2001 Signature: '&'UJ,. (9JA"A~L1' Print Name: Sharon Dras Morga~ Esquire Address: Land Title Building, Suite 2226 Philadelohia. PA 19110 Attorney for: r.F r~p;~~l Mnr~g~gp ~PTV-I,..iPC , TnI'. Telephone: (215) 923-2225 Suprerre Court ID No.: 6006R " ALL TllAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Penr:sylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in plan Book 55, page 63. BEGINNING at a point on a 50 f00t private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the corronon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the corronon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number I, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No.2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling t=; ~ \-.("l ~l ........ '.-. z ~ ~ ~ I - \ ' ..J") '" "<'> .......'....;:J- ~ 8 , <:'- tol '..0 ~,~ '" t::=;'~~ ....., . ,,-=- 'n '~ \.0-.,;.. \ .n "r. \0 ~ '..n ~ .........\l-"- --~'- -;:::) :-- j, ~ ;.. \:on . , ffJ I' \ 1'- '" """ " '-' "2 ~ -' ........ I>., ---\ - \-,d ........ ~ - ~ "'< '\ I::)~ -. J MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE SUITE 2226 - LAND TITLE BUILDING BROAD & CHESTNUT STREETS PHILADELPHIA, PA 19110 215/923-2225 Attorneys for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC. Plaintiff vs, GREGORY RADlC AND JULIE MACZUGA Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS CUMBERLAND COUNTY NO,: 1996-04602 AFFIDAVIT PURSUANT TO RULE 3129, I GE Capital Mortgage Services, Inc., Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following infonnation concerning the real property located at 651 Willow Grove Road, Carlisle, P A 17 I 03: ), Name and address of Owner(s) or Reputed Owner(s): Gregory Radic 651 Willow Grove Road Carlisle, PAl 71 03 Julie Maczuga 65 I Willow Grove Road Carlisle, PAl 71 03 2, Name and address of Defendant(s) in the Judgment: Gregory Radic 65 I Willow Grove Road Carlisle, PAl 71 03 Julie Maczuga 65 I Willow Grove Road Carlisle, P A 17103 " r . , t, ", - , IlIA COI'iI'lIZllIOtl Ellbwr:a 11'.1 aw,? :~) V MO.l.VijA btlllf1/;l 0.. r.:::'<I 'Llli:U Willie tlClI'lU.-A MAITLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID #60068 Suite 2226 - Land Title Building Broad & Chestnut Streets Philadelphia, PA 19110 (215) 923.2225 Attorneys for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs, NO,: 1996-04602 GREGORY RADlC AND JULIE MACZUGA Defendant :NOTlCE OF SHERIFF'S SALE OF :REAL PROPERTY :PURSUANT :TO PENNSYLVANIA RULE OF :CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at 651 Willow Grove Road, Carlisle, P A 17103 is scheduled to be sold at Sheriff's Sale on March 6, 2002 at 10:00 am in Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013 to enforce the Court Judgment of $95,000.95 obtained by GE Capital Mortgage Services, Inc, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Sharon Oras Morgan, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorneys fecs due, To tind out how much you must pay, you may call Sharon Oras Morgan at 215-923-2225, 2. You may be able to stop the Salc by filing a petition asking the court to strike or open the Judgment, ifthe Judgment was improperly entered, You may also ask the Court to postpone the Sale for good cause, 3, You may also be able to stop the Sale through other legal proceedings, You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the Sale, (See Notice below and how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, You may find out the bid priee by calling Sharon Gras Morgan at 215-923-2225, 2, You may be able to petition the Court to set aside the Sale if the bid price was b'l'ossly inadequate compared to the market value of your property, 3, The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale, To find out if this has happened you may call Sharon Gras Morgan at 215-923-2225, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened, 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you, 6, You may be entitled to a share ofthe money which was paid for your house, A Schedule of distribution of the money bid for your house will be filed by the Sheriff on April 6, 2002, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after, 7 , You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale, YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse Carlisle, P A 17013 1-717-240-6200 291/45987a ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in plan Book 55, page 63. BEGINNING at a point on a 50 f00t private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling MATILEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE SUITE 2226 - LAND TITLE BUILDING BROAD & CHESTNUT STREETS PHILADELPHIA, PA 19110 215/923-2225 Attorneys for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.: 1996-04602 GREGORY RADIC AND JULIE MACZUGA Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GE Capital Mortgage Services, Inc., Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 651 Willow Grove Road, Carlisle, P A 17103: I. Name and address of Owner(s) or Reputed Owner(s): Gregory Radic 651 Willow Grove Road Carlisle, PA 17103 Julie Maczuga 651 Willow Grove Road Carlisle, P A 17103 2, Name and address ofDefendant(s) in the Judgment: Gregory Radic 651 Willow Grove Road Carlisle, PAm 03 Julie Maczuga 651 Willow Grove Road Carlisle, P A 17103 ALL TllAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 fvot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. I as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the common corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number I, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No.2 on plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID #60068 Suite 2226 - Land Title Building Broad & Chestnut Streets Philadelphia, PA 19110 (2 I 5) 923-2225 Attorneys for Plaintiff GE CAPITAL MORTGAGE SERVICES, INC, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs, NO,: 1996-04602 GREGORY RADIC AND JULIE MACZUGA Defendant :NOTICE OF SHERIFF'S SALE OF :REAL PROPERTY :PURSUANT :TO PENNSYLVANIA RULE OF :CIVIL PROCEDURE 3 I 29 TAKE NOTICE: Your house (real estate) at 651 Willow Grove Road, Carlisle, PAl 7 I 03 is scheduled to be sold at Sheriff's Sale on March 6, 2002 at 10:00 am in Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013 to enforce the Court Judgment of $95,000.95 obtained by GE Capital Mortgage Services, Inc, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE 'TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1, The Sale will be cancelled if you pay to Sharon Oras Morgan, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call Sharon Oras Morgan at 215-923-2225, 2, You may be able to stop the Sale by filing a petition asking the court to strike or open the Judgment, if the Judgment was improperly entered, You may also ask the Court to postpone the Sale for good cause, 3, You may also be able to stop the Sale through other legal proceedings, You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the Sale, (See Notice below and how to obtain an attorney), Cumberland County Court Administrator 4'h Floor Cumberland County Courthouse Carlisle, P A 17013 1-717-240-6200 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Sharon Oras Morgan at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property, 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale, To tind out if this has happened you may call Sharon Oras Morgan at 215-923-2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened, 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer, At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on April 6,2002, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7 . You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale, YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 291/45987a ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, pennsyl vania, bounded and described in accordance with a plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in plan Book 55, page 63. BEGINNING at a point on a 50 f00t private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the conunon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number I, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No.2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as ,shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling REAL ESTATE SALE No, 10 On October 30, 200 I , the sheri ff levied upon the defendant's interest in the real propel1y situated in North Middleton Township, Cumberland County, PA, known and numbered as 651 Willow Grove Rd" Carlisle and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. @] ~ ~ ~ Date: October 30,2001 By: qodc/ I Sfvti.tC\ Real Estate Deputy i:., 'i r CZ dJS AJ :lJii' c . ..;l.i(J 11& THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Undor Act No. 587, Approved May 16,1929 Commonwoalth of Ponnsylvania, County of Dauphin} S5 Michael Morrow being duly sworn according 10 law, deposes and says: That he is the Assl. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonweallh of Pennsylvania, with its principal office and place of business at 812 to B18 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and.Il:1ll Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, lB54, and September lBth, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely allached hereto is exaclly as printed and published in their regular daity and/or Sunday/ Metro editions which appeared on the 29th day(s) January and the 5th and 12th day(s) of February 2002, That neither he nor said Company is interested in the subject mailer of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of \ Dr/hin 1 Miscellaneous Book "M", ':~:~g;~:~: '~'~~.'~"~'~'~'''''F:~;~'''''~~;~''A.D' SA L E #10 Not.rlaIS..,.' / 't / TorryLRus'~Il.NotaryPubllc ;j. "./ /~: ,/ ~ .~..., ~O~ Harrisburg, Dauphin County '" ' -- . :-<::::- My Commlsslon Explros June 6, 2002 NOTARY PUBLIC -. Momber, Penn!\yrvanla Assodatlon 01 Notaries My commission expires June 6, 2002 REAL UTAlE SALE No, 10 Writ No, 1 Q9&<I602 Ci'lIITenn GE Capital MorlQl9O Sor/ICOI, Inc, VI Gregori Radle ~I czuga -n . Ally: ShI omllo,... DESCRIPTION tr.J,tt of land situate in ALL TllAT . bcrl>nd County, , North Middleton nshtP.;U; described in PonlUylvan.., bon~p<q>artd by Soplten Q, accordaJltCWltha : hl81988andrecoroed ftsber,p,L.S.,dated !he fCReco;Uer of {)ccds fOT in me Office of . Plan Book 55. page 63: Cumbcrland county m 5O-footprlvatenght. BOOINNlNGatapointo'f:'nnrrtv of Dr-mum I.. of.wa... at Illnd~ now or 0 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA, 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr, For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 326.40 1.50 327,90 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sundav Patriot,News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid, By""..,."""""""".""""""""""""""".."",.".., PROOF OF PU8L1CATION OF NOTICE IN CUI\IHERLAND I.AW .IOURNAI. (Under Acl No, 587, approved May I(,. 1')29). p, L.1784 STATE OF PENNSYLVANIA: 55. COUNTY OF CUM8ERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the officiallcgal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached herelo is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dales. viz: JANUARY 25, FEBRUARY 1.8,2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is nol interested in the subject matter of the aforesaid notice or advertisement, and that all allegations inlhe foregoing statements as to time, place and character of publication arc true, REAL ESTATE SALE NO, 10 P)f&~ Rdger M, Morgenthal, Editor Writ No. HJ~W-<1(j02 Ch'U ag Cnpltal Mort~al-t(' Sc'rvkc's. In<" vs. Gr('~OIY HH<llc: mill .Jull(' MIH'ZIl/-{n Ally.: Sharon Oms Mor.L:an AIL 'n fAT r.EHTAIN tnll:l of ]<111(1 sltuah' III North Mlddl{'ton Towll ship. Cllllllx'rlnnd C01l1J1y. Pl'rlllsyl vania. hOllnded awl f!cs('rlhcd III 1lC'C':onlaJl('c wllh a Plall prepared hv Stephen G. Fisher, 1'. I.. S" dah';1 March lHlh. !wm mill n'{'or-ded III the ornee of llw Ik('orcln of J)C('ds (orClIlIlherland COllllly hi Plan/Jook !jS, Jl"W~ n:t BEGINNING at 11 poinl 011 :J fi() fnol privnll- ri~hl llfwav al lands SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY, 2002 it"~. . . .' 'j,' ~~\.:;}f:G " '." '::11 I '~~". ..,~',;~_:.~:,~,:::;:~:~:) ;' <:~l~~T~~~'~::.~~'.; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: GE CAPITAL MORTGAGE SERVICES, INC. ) CIVIL ACTION ) vs. GREGORY RADIC JULIA MACZUGA ) ) CIVIL DIVISION NO. 1996-04602 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, FRANK FEDERMAN, ESQUIRE attorney for GE CAPITAL MORTGAGE SERVICES, INC. hereby verify that on 7/31/02 & 8/6102 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 7/31/02 by certified mail return receipt requested see Exhibit "B" attached hereto. /'/ DATE: November 11 ,2002 ) FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff SS: /' --~---- t ~ I' \ I \1': ~'l . ~'I' HI . :lU' <-),IL . 6:00 $ 00 ".,,,, .""',"", ~ 'i ~ M 0 ,,", ~ ;:; <<: ~ p., <<: '" 0- p., .,. -' '" N Ul ~ ~ -' Ul <<: u ~ p., ~ <<: :i u 0 Cl ~ Q .,: <<: 0- UJ 0 0 " > .,: " - ~ :::> 0 "- UJ .". " Ul - Q " > 00 lJ :::. ::: ~ '" 'S " 0- cr/] .g E 0 x -' ::: 0 p., 0 ~ ~ == -,'J:' '._ ~ 0 Cl -l1S]~ ~ ::: -' 0 . .</l ;> E :;; == 0.; ~a~:! 0 '" ::: .0::>00 . :;1 -'90- .. ~ '" w co~ .. '" :r:.g ~o . <<: r.J ..,: 0-.(/)"2;; J . 5 15 " ~<l2- :::> ~ u ;2 N ~ 0) <r: i u u -~p., E 0 ;;; :;; ~ E . d f:; @i~ ~ 0 '" ~ ;z ;S ~ <<: " . z ~ -' ,,~-o e <=: wp,...r-~ UJ " ClIlJ.....:-::: Z f- wt::...o..s: w..O-o... "" 1;; c ~ ~ C2 Cot 5 e.ar.n ,,"".... z->:o 0- " .0 E ::> z " '0 1:: ->: v c :::; ~l ,'l' '. ~. . .... .... .",j =t ., ~ . '" 5' :":'!'" .' .:, -..), ~~ ~)>-.tSO~1 ~,.. M '" r-- '" 0- o ~l .-, :! Cl ~ S2 ':'.. -j ~h~ ~~1.a E e ~ ,t ~ t! ~ ~ .. ~.: '<.! ~ 5 ~ ~ ~ g ::l S -:: ~ ~ ~ ~ ~ uJ ~ HB -3 9 ~ ~ tin ~ ~ ~-2 ~ ~ l! ~ .. ~~~~:B ~ ~ ~ ~ c; ~~~~~ ~ ~ ~~. ~ <7::0 ....g".g ~.;:! g,;,.., ~ .~ ~. ~ .~ ] 1! g g~.2 l'j ] "I E ~ ;: ::: ... ::: f:! ~ ~ g ~ ~;11.9J,!;:: ::::: 81:; i= CIl ...:! l::,~g 8 ~.s~~~ -. ~ > .~ " :s . g " 'r, 0- N o o M "" o o It: U o ~ ~ t: a is' ~Q. ;i:J:i >- .,: o " ~ l:J .. " ~~ . " . "~ ~;; ~] :i ~ "" 'r, 1: ~ - _. 'c "~ .fj ~ l:::: :a ,~ ~ ~ ::l .~ ~J: o o .., .., .,. - '" . f- " S :8 VJ'"'1'< . - " < oo,~ N'i'e: <a~ iZ;i;;ce < -~ ,..J~<g ~~Q.."': == f-I w ~ ~z<~ ~[.IJ;:1J zUQ..~ <z,.J~ :;z~:g ~.~~:.': '" ....0 Q~:;:E ~O~Z t '" 0- ; ~ ~ ~ ~ ~ c ,- S "" C1I...l ~:gVJ Z-'t'O \ _nr \ ~~' ~ ~ ~ ~3_??? dl/ Ll. 'd J UIII':.'j 068:~O$ , ~',\, ,ll . I'''.' ~"." ..".:~-:;,SZ!M~Yl~~/~;i! ~. '_.,'/;,j .# "'. D \:. c, ,~, 1"';:1,15~\.~ " ~ ~ ,<: ;;. f- Z ;;::> o U Q <<: ~ Z ~ < '" ~ ~ Ul ;;::>f- Z'" U'" Z~ ~i:'2 ~~ VJ~ ~,.J :gZCF.l O~ t:9f5~ ::c r.. - ,-," - E-o- -t.......O ....0 ..j::'~ ~t;""c.:i"'~< . '_r-N":_p., ~ ~...or'" U.... . Z-N;:l_::CW -"'XCCf- .... 8~OUl"'~:!l ::;-tCC~!;:lO"" .....0. ....zQ: 0'" . .0"; < UQ..:I:Q_U ---------- ~]: S! e . c , . <z. . . . . c. ", ., ". '" \ I \ \ I ," \ \ ., o Cl -.. .. :.c: ,", ~ ~ " '" '" 0 E " ;.: \; 'r, 0. '" Ii - ..., " ~ Q g " "" ." .~ c~ ....., :s E '0 0.'" .... "" "" 'I. ;... c.:: C \.:l t<.l c.:: . \.:l " ij r...i ~l:S ;:0 .... '- o ^ Cl ." 0- ~ ~ EO ,~ til z ~ '9 'E c.:: c " .-", o ~ c o ~ rl r". c " _~....c ~"'il E" Z~ - " ~~ :! ", __.__ __ __H_ ___.. ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the conunon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the conunon corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet , to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded october 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling TAX PARCEL' 29-07-0473-004A PROPERTY BEING KNOWN AS: 651 WII.\.OW GROVE ROAO, GARISLE, PA 17013 , " '. , , i~' , ',' ...~; ~ ~ "..... :.." ..... ;}' ~ ~ N ~ ....... 11 J ~ 01 Jl . ~ :; I ,'.1 I C_'. J-, ~~ ~ '- ~ ~ : : ~ ~ - ~ ~ - " : --J~~'-~;' ~::~-~ (1- ,I I , I I I I I \ I I I I J () J :) "0... cr- .J ,,- J 'J :) :) :l 'J J ~ q) Cl ~ ;) () "? "'~~ 0 ~ ~ () J.J \l V J () C? l.Jj ~ ~ ~ ..:. ::i-"ji i- t("{ ~ 0- l" ,.:, '~ ,;, .:, v; j '- f)I V) 0- ~_ a " "...." .... .... .... b?- ~ 0,;<.0- ~ 'i;? , . '11+.1 .Ill... '-"'-' ~ J CJ (.J Ij -.l U v.J c:iJ ob \.J--j- J 'J ::- tn ?' c; ~n; .'f. i , " ':.: I ~J , . , " ; i_, '" ! c. I , " .... , !- - 1 , '.' :.1 ,,- 0::,;.. I C" J :j U 0 CJ GE CAPITAL MORTGAGE SERVICES, INC'. Plaintiff, ClJ:\llIERLANI> COUNTY v. No. 1996-0-1602 GREGORY RADlC JULIA MACZUGA Dcfendant(s). July 30.2002 TO: GREGORY RADIC 65t WILLOW GROVE ROAD CARLISLE. PA 17013 .IU.!A i\L\CZUGA RR 1 P.O. BOX 988 SUGARLOAF. PA 18249 "THIS FIRM IS A DEB T CGL!.ECl'01I A 7TE.lIPn,vC 7'0 CGLLECT A DEBTA,VD ANY INFOIW.mON 'OBTAINED WILL BE USED 1''011 7'/1,.1 T PURPDSE. IF )'OU /1..1 I 'E PIIEVIDUSL Y IIECEIVED A DISCHAIIGE IN BANKIIUPTCY AND THIS DEBT WAS NGT REAf'FlRMED. THIS IS NOTAND SHOULD NDT BE CONSTRUED TO BE AN ATTEMPT I'D CDLLECT A DEB7: BUT 'ONLY ENFORCEMENT 'OF A LIEN AC.1 INST PRDPERTY." Your house (real estate) at. 651 WILLOW GROVE ROAD. CARISLE. PA 17013. is scheduled to be sold at the Sheriffs Sale on 12/04/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment 01'$95.000.95 obtained by GE CAPITAL MORTGAGE SERVICES. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (2 t 5) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILI. BF: ABLE TO SAVE YOUR PROPERTY AND YOt' HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sherif!'s Sale is not stopped. your property will be sold to the highest bidder. You may lind out the price bid by calling (215) 5(,J-7i)I)I). 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. J. The sale will go through only if the buyer pays the SherilTthe full amount due in the sale. To find out if this has happened. you may call (717) 240-6J<)(). 4. If the amount due from the Buyer is not paid to the Sheriff. you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) arc filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defcnses. or ways of getting your homc back, if you aet immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IFYOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORl'lEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)2-19-3 t 66 (800) 990-9108 ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the cormnon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet , to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as.shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded october 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling ~AX PARCEL , 29-07-0473-004A PROPERTY BEING KNOWN AS: 651 WILLOW GROVE ROAD, CARISLE, PA 17013 >- , () ; 0: I - It I I'...:) (.~ ; I; .- - " '-' C\ ('J , , , II , ;::;::' , U' I '10 c: ,J.. I' <', ~-j 0 0 CJ IN '!HE c:aJW' Of' .-MJN PIE/IS Of' Cl.MBERlJlND CU1Nl1' 'ENNSYLVf\NIA ------ --'- CIVIL DIVISION C{'ption: fl1.e N'J. \996-01.602 GE CAPITAL MORTGAm: S~;RVICI':S, ING. Nrollnt Due $95,000.95 Interest 11/8/96-3/5/97 $1,8/.3.16 V5. GREGORY RADIC 8~d JULIA HACZUGA r\tty's (onm Costs TO THE PRCYIlIONJTARY OF THE SAID COURT: The undersigned hereby cert1fies that the below does not arise out of a retail installment sale, contract, or account based on a confession of Judgment, but if it does, it is based on the appropriate original proceed1ng filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 oE 1974 as illnended. PMECIPE FUR EXEClTI'ION Issue writ oE execution in the above motter to the Sheriff of CUMRERLAND County, for debt, interest and costs uPon the following described property of the defendant(s) 651 Wll.LOW GROVE ROAD, CARLISLE, I'll. l70n (SEE ATTAGHED COPY OF LEGAL DESCRIPTION) PMECIPE FUR A1"1'ACIM1'Nl' EXIDJI"ION Issue writ of attachrrcnt to the Sheriff of interest and costs, as aoove, directing attachrrcnt the following property (if real estate, supply six copies of lengthy personalty list) County, for debt, against the above-named garnishee(s) for cop1es of the description; supply four and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this ~Tit against the garnishe real estate of the defendant( s) described . lis pendens against DATE: 11119/% ""7// /' L------ Print Nam8: MICHAEL R. NESTOR, ESQUIRE Address: lOa S. BROAD STREET, STE 2226 ";0;: cr) c., (r. . . <'- ~~3;;; ,... cr. c' u.I-- .., ~(: _.J.:- -. Ll-OJ ':l... '.:.i::..J ~~: .'" ~~:.~ c"..' ...J~; L.:":'..' '. ")(D rr.:\-t' c. .;'.1L\- f'- -. ~) u. \.") () c> Co' PHU,ADELPRT A. PA 1911 0 Attorney for: GE CAPITAL MORTGAGE SERVICES, INC. Telephone: 215/923-2225 Supreme Court ID No.: 76429 ALL THAT CERTAIN tract of land situate in North Middleton 'l'ownship, Cumberland County, Pennsylvania / bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55/ page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the conunon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No.2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling I' --- ( C5' '- J-. '0':' <:'"'<, <2 ~ > -~-;:::::-- '7-- .... '" IS) CJ ::r .... IS) ..0 lJ'" I.;;,:"!. :1"/;" :).. , .' I ',' 'i'L ,,'1-"~o .'- _ ..; ,,0 '!)~~ 1'-' ' "'" .0-' I . W.," VVn:! ~ ".W.'. . "f U f:<...~'\.<...:~~/i:P:= J. . . . ~~/11(Jl"""- ..-..,1.., J~ A:/' -" 'oJJ q,,"f)' ..-#~ .. en ,~l' ~i~.~,'~> ~-><:g. $.::j:. ....t-~ .~~ <' " .,;;l' ..Wi"'~_ ' ~ .(..." ,':,.' ...../_~.~.~.J ~ ~,"'J~ ....l~ ...~\~ J~ ~!J.;' . ,~~ v' ~\"-_:J>~..... z . ~' ~t:.'i' ",o;).r ,E W ..... "".,...' r:3 (J) .' ... .a: ~!J.l - #/JP iH -I"', ,:-I,...-l C1. .' ~ !o~t a. .,: t.tl ...l ...l ~ o(j .,. '" o 00 o :I:. ,. fo' :i ~ ~ o I- .0: ll:: ~ < lJ.l.!!; Z ~ g !;r Uij~z ::::. ~.,: . ~ z _:l " 0 - i 8 ~::r: <<: ,. :E ~ t.tl ~ ...l U f-- f-- ~ ~ (ll rJ'I " ~ o ... ~ 1" .' ~~'~~~~~+*~,~~~~~~~,~~~.:~ ... . ~~'~~'~~~~~~~'~~~~~*~~~~~~,~~~~~~~~'::=,~~:= :]l~TE : ():~--:::5'-'19::;:!j I l1~-IC. ~'ur.3{;l ~ J Lit. l (.1., ~ 651 ,WIt.LOW GROVE,RD.CARl.r~:i_f~~PA. f - ..- -... - ._. u,..' C'" " . ~-'. .-~i :\)::.:' !...il'J ,I fJ (.) , 1'" t .. r:UH .," <.'~.:U8 f'~(l!.IE , r',iJ\'~I(:O(i:,I).~, Cf:LLi'.Ic-.[7~H,c-., :::i:' :.:.:UD)ECT':. ..~:'....." 71 :r;'.", ..-..... ....... -: 1 :: : r~ CUr-U-?.ENT ~1D['R.E.ss:,:.-111- NL 80 5UFFOLt( RD. ~ CARLISLE PA. 17\)13 ,FOr:U1EH ~IDDPF;SS., HFi WILLOW GPOVE PD.. [:;~~LISLE 1 FOB q88~ SLIG~RL(JAF p~, P,"I. ;:: R c: ,'H,'" 1 D I T ceiL ;~(l S U ;-1 r"l p.., n NEG::~ I~STrJF(;-:~,-. (I HIU::-l CFED Cf~.l.:=I." L j r.; 1', j .:::{,(l . . :iE\.JOL\}INE,~ iNSH\LLl1EIH: :"LOSED IAI/E;l:iL. TOT;iL~3 : ~:i./'7:~::? ";11.:.',1' " U B L J C RECDFI['S ...............,. ... .. ..~. - .- ..,-. ._- I.':' :-:r) .-... "j.' " ' r- . I:~.- I;~ ':.-:'I'l.:,)ll j j ... ::.\~.fi . T \! T l. J L.JDhf"i[~t.rr CUI_iF: ~( ..1:'1 P. ~'.\ n E ::; ... .. . ~ . .." .............. .. ....-.. .. .. .... .. ...._~--. .. '-'.. . 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".., .. j :'~/C;:'7 ~I ~'::--1 i i.E;:r ," 1 ., 1-1,,":"1'::',1' CIPf'J;.:() I.IJr):::? ,.1'-,: ;:::1::'/ ~';\./::-:l:rL;.;r:L[: 1."_." :-::',:':--:1, ~ ,I, ' '11 1:>'00"; :".(1 : 1".f':1 :::<~iii 'E;~; t-,:..1 i ~:> I';IC::: CT I! . , (:1hl"1 ::Fi'" ';":Tr,> ',.. ,,".', I~~i- 'i.t: C'H;-';L , I i','FI'-I-! "i:"t i-~ ;~': ..... : 1'liJ "_..::':.;(. :!.:r:; I IF' .'" " i i r i . -,I if r: j!.; T'~ :" ,1C;' (," J i I . j (RULE OF CIVIL PROCEDURE NO. 236) - REVISED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW =======================================================~=============~ GE CAPITAL MORTGAGE SERVICES, INC. 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NUMBER: 1996-04602 GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA RR 1 P.o. BOX 988 SUGARLOAF, PA 18249- Defendant(s) NOTICE PURSUANT TO RULE 236 ======================================================================== NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER BEEN ENTERED AGAINST YO~ ~ ~~ hLL'1..~~ C ~)Jh-'L 'Y.,,1 PROTHONOTARY - CUMBERLAND COUNTY/J- If you have any questions concerning the above, please contactn c:: ;;- "l:lC: fnr' z:-- ;;'.:.fL' en " ;:s ;'. ~c.; ~...... -0 5C:' ::.: c:..: S'l' ~ :...> .::- HAS MICHAEL R. NESTOR Attorney 1.0. Number: 76429 MATTLEMAN, GREENBERG, SHMERELSON, Suite 2226 - Land Title Building Broad & Chestnut Streets Philadelphia, PA 19110 215-923-2225 Attorneys for Plaintiff v:> C'l. ,... is ~ , co q ::;1 .7: ::n r-- ;;;6"'" .:-> :i! :tl C):!l '~(") 0"" ""' $ -<: WEINROTH & MILLER ....~~. ':. I . Not;.," p..".",.,~t '1'0 ,Fail' Debt CoIIec:tIGft ~ctices..~j:.! Th~ '1e:t. dIIIt and any infonr...uon obtained "... _ - ~"..- .... .hat 1JIII1IC*o MATTLEMAN, GREENBERG, SHMERELSON, WEINROTH & MILLER SUITE 2226 - LAND TITLE BUILDING BROAD AND CHESTNUT STREETS PHILADELPHIA, PA 19110 215-923-2225 ATTORNEYS FOR PLAINTIFF By: MICHAEL R. NESTOR Attorney 1.0. Number: 76429 ========================================================================= GE CAPITAL MORTGAGE SERVICES, INC. 625 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5834 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NUMBER: 1996-04602 PRAECIPE TO ENTER DEFAULT JUDGMENT GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013- JULIA MACZUGA RR 1 P.O. BOX 988 SUGARLOAF, PA 18249- Defendant(s) ------------------------------------------------------------------------- ------------------------------------------------------------------------- TO THE PROTHONOTARY Kindly enter Default Judgment in favor of the plaintiff and against the Defendant(s) for failure to Answer the Complaint in civil Action - Mortgage Foreclosure. Service was made on the Defendant(s) by the Sheriff of CUMBERLAND County as follows: GREGORY RADIC JULIA MACZUGA Assess Damages as follows: Principal and Interest Interest from 08/08/96 to 11/06/96 Costs Incurred TOTAL 291/45987 - 08/.28/96 - 10/01/96 $ 92714.65 $ 1936.80 $ 349.50 $ 95000.95 MATTLEMAN, GREENBERG, SHMERELSON WEINROTH & M LER By: tJ /f~ MICHAEL R. NESTOR ~ Attorney I.D. Number: 76429 :.,.. ;"!r "l' ill'.1 :j ! ~ " ..,.. .. .. .. I! -:; :'iY:i/::;B 'y'r.JJ(:(I(I(! 1 (),:;.. (['(":~, 'I (:; ." 1 '::':(j/:,),/ Uf-'H(,n :~:"'l j (,,'::, It-:-(+:: I '-:'NJO(ii":::i 1. n.~,! 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I " ., , I'" ~ 1 C:''''- '-ITI ,"d'.:I'~I, l'li:llfY:1 ,~i. i.: <: !::i 'ut,!", 'i ":' 1 I": GE Capital Mortgage Services Inc. -vs- Gregory Radic and Julia Maczuga In the Court of Common Pleas of Cumberland County,Pennsylvania No. 96-4602 Civil Term Michael E. Barrick, Deputy SheritTwho being duly sworn according to law, says on January 6, 1998 he posted a copy of Real Estate Writ Notice Poster and Description at 651 Willow Grove Road, Carlisle, Cumberland County, Pennsylvania according to law, R. Thomas Kline, Sheriff who being duly sworn aeeording to law, says he made diligent search and inquiry for one of the within named defendants to wit: Gregory Radic, but was unable to locate him in his bailiwick. He therefore deputized the sheriff of Dauphin County, to serve the within Real Estate Writ Notice, Poster and Description according to Jaw. Dauphin county return: And now January 8, 1998 at 3: 10 P.M. served the within Real Estate Writ Notice Poster and Description upon Gregory Radic by personally handing to Grcgory Radic I true and attested copy of the original Real Estate Writ Notice Poster and Description and making known unto him the contents thereof at 80 Suffolk Road, Harrisburg, PASo answers: lR. Lotwick, Sheriff. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a one of the within named defendants, to wit: Julia Maczuga a notice of the pendency of the action by certified mail return receipt request deliver to address only to her last known address 361 Twentieth Street, Naples, FL on January 6, 1998. The letter was returned to the Sheriffs Office eon January 26, 1998 within reason checked ATTEMPTED UNKNOWN. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the within Real Estate Writ Notice Poster and description in the following manner: The sheriff mailed one of the within named defendants to wit: Gregory Radic a notice of the pendency of the action by certified mail return receipt requested deliver to addrcssec only to his last known address 80 Suffolk Road, Harrisburg, Pcnnsylvania. The lettcr was mailed under the date of January 6, 1998. The return receipt card was returned to the Sheriffs Office on January 8, 1998 the return receipt card signed by Gregory Radic. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed one of the within named defendants to wit" Gregory Radic a noticc of the pendency of the action by regular mail to his last known address 80 Suffolk Road, Harrisburg, Pcnnsylvania. The letter was mailed under the date of February 5, 1998 and nevcr returned to the Sheriffs Office. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: the Sheriff mailed a notice of the pendency of the action by regular mail to onc of the within named defendants to wit: Julia Maezuga to her last known address 361 Twentieth Street, Naples Florida. The letter was mailed under the date of January 30,1998 and returned tn the ShcriffOflice on February 9, 1998 with reason checked return to sender insufficient address. R. Thomas Kline, Who being duly sworn according to law, says he made diligent search and inquiry for one of the within named defendants to wit: Julia Maczuga but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ Notice Poster and Description according to law. lATTLEMAN, WEINROTlI & HILL_ , A Professional Corporation Counsellors at Law PENNSYLVANIA NEW JERSEY DELAW:IRC: suite 2226-Land Title Bldg. Broad & Chestnut Sts. philadelphia, PA 19110 Phone: 215-923-2225 Fax: 215-567-4151 401 Route 70 East Suite 101 Cherry Hill, NJ 08034 Rockland Center II 1801 Rockland-Suite 302 Wilmington, DE 19803 Phone: 609-429-5507 Fax: 609-429-9036 phone: 302-658-6835 Fax: 302-658-6838 Postmaster Post Office CARLISLE PA 17013- 02/03/98 OUR FILE NO. 291/45987a REPLY TO PENNSYLVANIA REQUEST FOR CHANGE OF ADDRESS OR BOXHOLOC:H INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or name and street address (if a boxholder) for the following: JULIA MACZUGA 651 WILLOW GROVE ROAD CARLISLE, PA, 17013- The following information is provided in accordance with 39 CFR 265.6 (d) (6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d) (1) and (2) and corresponding Administrative Support Manual 352.44 a and b. Capacity of Requester: MARISSA M. OCONNELL ATTORNEY FOR PLAINTIFF The Names of all known parties to litigation: GE CAPITAL MORTGAGE CORP vs. JULIA MACZUGA The Court in which the Case has been or will be heard: PENNSYLVANIA COURT OF COMMON PLEAS The docket or other identifying number if one has been issued: 1996-04602 The capacity in which this individual is to be served: DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000.00 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH TITLE 18 U.S.C. SECTION 1001). .....continued ..; ().., '" ....... '" ") -s:.. ~ ~ J ~ ~ g ~ .... '- The same is incorporated by reference as if fully set forth at length. 2. The Defendants, Gregory Radic and Julia Maczuga are the real owners of the property known as 651 willow Grove Road, Carlisle, PA 17013. 3. Plaintiff, GE Capital Mortgage Services, Inc. is Mortgagee by assignment on said property. 4. Plaintiff has filed a praecipe for writ of Execution- (Mortgage Foreclosure), on or about November 21, 1997. A copy is attached hereto and made apart hereof and marked as Exhibit "B". 5. Plaintiff has made repeated attempts to effectuate service of the process of the Notice of Sheriff's Sale of Real Property pursuant to Pennsylvania Rule of civil Procedure 3129 upon the Defendant, Julia Maczuga, but has been unable to do so. Plaintiff attempted service on Julia Maczuga out of state by certified mail. The certified mail returned marked unclaimed. A copy of the envelope is attached hereto and made a part hereof as Exhibit "C". 6. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendanta including the following: A. On February 5, 1998 support staff for Mattelman, Weinroth and Miller ran a Trans Union Consumer Credit Report for the defendant, Julia Maczuga, which indicated her current address as 80 Suffolk Road, Carlisle, PA 17013. A copy of the Trans Union Consumer Credit Report is attached hereto and made a part hereof as Exhibit "0". Plaintiff attempted service on the defendant, Julia Maczuga at the new address by the Sheriff. A copy of the Sheriff's return is attached hereto and made a part hereof as Exhibit "E", which indicates that the Sheriff was unable to locate Julia Maczuga. B. On February 3, 1998, support staff for Mattleman, Weinroth and Miller requested a Postal Inquiry from the Postmaster to obtain a current address for the Defendant, Julia Maczuga. The Postal Inquiry returned indicating that the defendant moved and loeft no forwarding address. A copy of the Postal Inquiry is attached hereto and made a part hereof as Exhibit "F". C. On February 6, 1998, support staff for Mattleman, Weinroth & Miller verified through the Telephone Operator and the Coles Directory that there is no listing for the Defendant, Julia Maczuga. 7. Plaintiff has attempted to ascertain the present address of the Defendants, Julia Maczuga, but has been unable to do so. 8. Pennsylvania Rule of Civil Procedures 430 permits service of process in Mortgage Foreclosure Actions by regular and certified mail to Defendant's last known address. NOTE '~lr' ") '1(' .. ," 358507-8115 l..;rlT OCTOBER 26 ,1'1 ')4 NEW CUMBERlArIO (CltVJ PENNSYLVANIA ( ~; I a Ie) 651 WILLOW GROVE ROAD. CARLISLE, PA 1701J (l'r"IX'rl \' \.JJrc';~i I nORIWWER'S I'IW;-.lISE TO I'A Y In return 1M a ["an that 1 ha\'c n:<':l.:ln~d. I rr()ml:a~ I" par L'~; "rrmcipui"), pills lulere51. to the order flf the I.ender. TI-,'~ !.cwJcr 15 5 84,500,00 IIhis nrno\Jl\t is callcu (aUI T'( OtIE ltJCQRPORATEO I understnnd IhM Ihe Lender may trllnsfcr this N0te. rhe Lender 'l( anyone wh'! \i1ke~ this ;":ole hI' Irlln~fcr Jlm.l who is entitled to recei\'e pllyments IInder Ihis Nute is called Ihe ":\n!c lI'll11er," 2. INTEREST Interest will be charged on IlnpniJ prinCIpal ulltll the full mnO\lllt uf principal has heen paid. I will puy interest lit II yearl~' rale of 9.250 %. The interest rate rctjuireu h~' thl:: Sc..;tinn 2 i~ the rale I '.\"ill pay hrllh hcfore anuafter anlo' dcfllult described in Section 6(13) (Jf Ihis Nole. 3, PA\'~IENTS {A) Time and Place or Payments I will pay principal nnu intere51 hr making payments el'er)' month. I will mllke my monthly payments on the FIRST Jay (,f each month beginning on DECEMBER ,1994 I will make these palo'ments e\'cry month unllll ha\'e paiu ullof thc principalllnJ Interest and /Jny nlncr c1l1lrgcs described bell)w lhat! may owe under thiS l\ote.1\ly monthl}' p;lyments will be applied 10 Interest hefore prmcipal.lf. on NOVEMBER 01, 2024 I still owe amounts \lnder this i\ote. I will pay those amounts in f\lll on that date. which is called the Mmlltl1tll}' date." I will miJke m}' payments at 340 EAST MAPLE AVENUE. SUI TE 3. LANGHORNE,?A 19047 or at a different place If reqlllred hr the Note Holdcr. .-/. (lJ) Amount of ;-.fonthly I';'\ymenl.~ My monthl}' payment will hc in thc f1mount of U.S. 695.17 4. nORROWER'S RIGHT TO PREP A\' i have the right to make pllyment5 of principal at nnlo' time bdore they Ilre dlle. A payment of principal only is known IlS a "prepayment." When I make a prepayment, I will tell the Note Holder in writing thllt [am doing so, I mny make II full prepayment or partial prepnyrnents withoul palo'ing an)' prepayment charge. The Note Holder will u~e ull of m;' prepllyments to reduce Ihe amouot of principal that I owe llnder this Nole. If 1 make a partinl prepllyment. there will h': no chnnhes in the due date or in the f1rnOllnt of my monthl r payment unless the Note Holder agrees in writing to those changes. 5. tOAN CHARGES If a low, .....hich llPplies to this loan llnd which sets ma,~imum 101ln charges, is finnll y inlerpreteu so thot the interest or other lonn charges collected or to be collected in connection with this 10<10 exceed the permitted limits, then: (D any such lOlln chnrge shnll be redllced by the amount necessar)' to reuuce the chnrge to the permilled limit: and (iil any sums nlrelld}' collected from me which exceeded permitted limits will be refunded tn me. The Note !-Iolder mny choose to mnke this refund h~' reducing the principill I owe uoder this Note or hj' making a direct payment to me. If a rcruod reduces principal. the reduction will be treated 1IS a pllrtilll prepayment. Ii. n0Ri\.O'I;'r::~:::: ;:.\i:.i..:::~ TG- 7..... .~. :.:: ::::::;:::R2r.. {All-llte Charge for {herdue I'3yments If Ihe Note Holder hlls flot recei\'cd the full amollnt of any monthly payment or the end of 15 calendar da}'s after the date it is due, I will pa~' II late chllrge 10 thc Note (folder. The amount of the chnrge will be 5,0 % of m;' ol'erdne payment of principal rmd interes!.l will pay this late char/-:e promptly hut only once on clJl.:h lllte payment. (IJ) ner3ult If I do not palo' the full nmollnt of eOlch month I r p;j~'ment nn the date it i~ dllc. I lI"ill be in defnult. {Cl Notice uf nef3ult If I am in dcfnlllt. the Note lIo1der mar senu me a written notice telling me thnt if I un not pay thc ovcrdue amount by a certllin dule. the Nole Ilolder mar re4uire me to pa~' immediatel;, the ftllllllTIOUnl of principal which has not been paid and nIl the intercsl that I owe on thnt amuunt. Thnt oate must he lit Jeasl J(l un p after the dnte on which the notice is delivered or mailed to me, (D) No Wah'er Hlo' Note Holder Even if, lit n time when I am in deflllllt. the Note I {(Jlder uocs nnt require me to pol' immediatel y in fullns described llbo\'e, the Note Holder will still have the right to do so if I IIIn ill ueflllllt al a later time. (fi) Payment of Note Holder'.~ C(),~IS and E~pen.~es If the Note lIolder has req\1ired me to P,1}' immediatel j' in full as de~eribed llhove, the Note Holder will h:lve the right to be paid back hr me for all of its CMts and expenses in enforcing Ihis Note to the extent not prohibited O}' applicable laW, Those expel15es indllde. for e\ample. reasonable n!lorneys' fees, 7, GIVING 0(1 NOTICES Unless applicahle law requires 11 different melhou. mlj" notice Ihal must ne gllen In me under this Nole will be gi\en hy delil'ering it ()f by mailing it br first clnss mail In me at the I'ropetl y Address ahove or at a different addrcss if I gil'e the Note Iloloer n notice of m;, different nddress. Any notice tlmt must he given to the Nolc Illlluer under this Note will he gil'en hr mllding It hy firsl elllSs mnil to the NolC Holder at the nddress stilted in Section J(A) IIbol'e or nt II different nddress if lam /-:I\'en n notice of Ihat different address, a. ..n~ NOTE-S,nqlc Fo1Tn,lv -FNMAIHtLMC UNIFORM INSTRUMENT l'<Ige I or 2 !'l!- ~ Fa.m 3200 !2IU MULTI STATE FIXED RATE NOTE500 REV' 1181 8 ..,J GE Capital Gf C..'piroJ Mortg.1ge Service!, Ine. 11rJIII/liI(i! r:'-l/llr"I~.r(:ltll.uJ!.'(:rlrjllll.!II.'J1I /uuu Wt~,';r /1111/1 SlIull1, .'il!llr~ IJUU "() {!IJ~ ,1}()l/~. 1I1J1J...t(JlI. IX //O?!I))/!j 1/31,'/J,U?! DATE: May la, 1996 NOTICE OF INTENTION TO FORECLOSE MORTGAGE UNDER SECTION 403 OF PA ACT No.6 OF 1974. (READ BOlli PAGES OF THIS NOTICE CAREFULLY.) GREGORY RADle 651 WILLOY GROVE ROAD CARLISLE, PA 17013 RE: GE LOAN # 0016300295 PROPERTY 651 ~ILLOW GROVE ROAD CARLISLE, PA 17013 MORTGAGEE: G.E. CAPITAL MORTGAGE SERVICES The Mortgoge held by the above named Mortgagee (hereinafter we, us, or ours) on your property noted above is in serious default because you have not made the monthly payments as noted below under (a), and/or because you have failed to comply with or perform the other provisions of the mortgage obligation, if any, as noted below under (d). Previous late charges under (b) and other charges, if any, under (c) noted below, have also accrued to this date. The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter, is noted below under (e). Ca) 030196 thru 050196 @ S843.80/mo plus late chg @ $27.80 $2,587.00 (b) Previous late charge(s): (c) NSF check charge(s): (d) Other provisions of the mortgage obligation if any: (e) Total amount required as of this date: $69.51 .00 108.36 $2,709.27 You may cure this default within THIRTY (30) days of this letter by paying to us the amount under (e) above, plus any additional monthly payments and late charges (and other charges) which may fall due during this period. Such payment must be either by cash, cashier's check, certified check, or money order made payable to G.E. Mortgage Services, 625 Maryv;lte Centre, St. Louis, MO 63141, Attention: Cashiering Department. If you do not cure the default within THIRTY (30) days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever ;s owing on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgage property. If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to payoff the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will have to pay the reasonable attorneyls fees actually incurred up to S50.00. However, if legal proceedings ore started against you, you will have to pay the reasonable attorney's fees even if they are over S50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the THIRTY(30) day period, you will not be required to pay attorney's fees. . - ACT 91 NOTICE GE Capital ) TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE GE Capitnl Morrgngc Servicl1s,/IIC. Ill!Ii,III/(it r"I'ildlr,rmlll'/!/" CIII{J'If,If'flll The COfTTT1onwcalth of Pennsylvania's Homeowners' Emergcn't!\ilit.lod~ti~'o';!ll!r!J, .';11'11' f3()O "'/11... ,1,'!).'/'I. lI..u' 'I"~ IX I /lJ11 IJ,"/~I Asshtance Program may be able to help you. Read the follo;"I.n~Jr.?!/,ce to lnd out how the program works. If you need more information, calt the Pennsylvania Housing Financ~ Agency at 1'800-342-2397. La Notification en adjunto os de sumo importnncia, pues afecta su derccho a continuar viviendo en su caso. Si no co"~rendc el contcnido de csts notificacion obtcnga una traduccion immcdiatamcntc llamando esta agcncia (Pennsylvania Housing Finance Agency) ~ln cargo~ al numero mcncionado arriba. Pucdes ser e(egib(e para un prestilma par ct pragrama tlarllado Illlomeowne!rs' Emergency Mortgage Assistance Program" al cuol puede 5alvar su casa de! la perdida del derecho a rcdimir su hipateca. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS I EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS May 10, 1996 RE: G.E. CAPITAL MORTGAGE SERVICES, INC. Property Address: 651 ~ILLOW GROVE ROAD, CARLISLE PA 17013 Loon # 16300295 TO: GREGORY RADIC 651 WILLOW GROVE ROAD CARLISLE, PA 17013 FROM: G.E. Capitol Mortgage Services You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeownersl Emergency Mortgage Assistance Act of 1983 (the llACTll). You may be eligible for emergency temporary assistance if you default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains on explanation of your rights. Under the Act, you arc entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the datc of this Notice. During that time you must arrange and attend a IIface-to-facell meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwisc settle your delinquency. This meeting must occur in the next thirty (30) days. e ..J HUD APPROVEC COU~SEllNG AG[NCIES GE Cnlli/al PEtlNSYL VAN I At Cont ) SERVICE AREA: GREENE COUNTY SERVICE AREA: Gt e"/IIrill Mortgnge SCfVlCCS. Iflc. \.jE 5 TMORElA1fOCOU,.T'l' II": II J. f(,.~ II','" ( "'I",,'.jr /j', /'J/).) ~\,' .1/1'''1' ','J'''.'!: '".. :1' I,f.,'d [.','/iI/:!!,'/" SATELLITE OFfiCE: co",uMEN CREOIT COUNSElIJr."d~~v't~r' /I",,"'" [1J/"I.,f" OF \.lESTERN PENNSYLVANIA. INC. CHAMBER OF COMMERCE BUILDING 662 HQRJIl MAIN STREET GREENSBURGIl, PA 15601 (/.12) 838 1290 ~^SHINGTON/GREEN COMMUNITY ACTION CORPORATION 202 OLD COUNTY OFFICE BUILDING ~AYNESBURG, P^ 15370 (412) 852 2893 CONSUMER CREDIT COUNSEL DIG SERVICE OF \,jESTERN PENNSYLVANIA. INC. 309 SMITHFIELD STREET PITTSBURGH, PA 15222 (412) 471 758f, SERVICE AREA: lA~RENCE COUNTY SATELLITE OFFI~E: CONSUMER CREDIT COUNSELING SERVICE OF ~ESTERN PENNSYLVANIA, INC. 309 SMITHFIELD STREET HANEY OFFICE BUILDING, SUITE 304 NE~ CASTLE, PA 16101 (412) 652 8074 ELDER-ADO, INC. 320 BROYNSVllLE ROAD PITTBURGH, PA 15210 (412) 381 6900 SERVICE AREA: MERCER COUNTY GARFIELD JUBilEE, ASSOCIATION 5138 PENN AVE. PITTBURGH, PA 15224 ((.12> 665 5200 SHENAGO VALLEY URBAN LEAGUE 39 CHESTNUT STREET SHARON, PA 16146 (412) 981 5310 HOUSING OPPORTUNITIES, INC. 133 7TH STREET POST OFFICE BOX 9 MCKEESPORT, PA 15;34 (412) 664 1590 SERVtCE AREA: YASHINGTON COUNTY YASHINGTON/GREENE COMMUNITY ACTION CORPORATION 2198 NORTH MAIN STREET ~ASHINTON, PA 15301 (412) 225 9550 URBAN LEAGUE HOUSING COUNSELING SERVICE, INC. 304 ROSS STREET PITTSBURGH, PA 15219 (412) 261 0932 .' 8 GE Capital ) GC C"I/ilill M01tgnge Services. I/lc. ,1 ". ~ r./I./ LII'.'/.I/'.1""'/-I'I" 1.1II1"""fI/JI' .:'.'; ,I; ~ ~', ",/ I ""I-' ':I}IIII; '.; ;'.' I.:' ,Iii "I! 11"".I'(},iI', l/u'I',I"1I h//IV/n,'/', /1'1,//,11// ~OTICE OF IN'~N'ION TO FORECLOSE MORTGAGE UNDER SECTION 403 OF PA Acr NO.6 OF 1974. (READ eOlIl PAGES OF THIS NOtiCE CAREFULLY.) DATE: Hay 10, 1996 JULIA MACZUGA 651 "Ill~ GROVE ROAD CARLISLE, PA 17013 RE: GE lOAN # 0016300295 PROPERTY 651 WllLOY GROVE ROAD CARLISLE, PA 17013 MORTGAGEE: G.E. CAPITAL MORTGAGE SERVICES The Mortgage held by the above named Mortgagee (hereinafter we, us, or ours) on your property noted above is in serious default because you have not made the monthly payments as noted below under (a), and/or because you have failed to comply with or perform the other provisions of the mortgage obligation, if any, as noted below under (d). Previous tate charges under (b) and other charges, if any, under (c) noted below, have also accrued to this date. The totaL amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter, is noted below under (e). Ca) 030196 thru 050196 @ $843.80/mo plus late chg @ $27.80 $2,567.00 (b) Previous late charge(s): (c) NSF check charge(s): (d) Other provisions of the mortgage obligation if any: (e) Total amount required as of this date: $69.51 .00 108.36 $2,709.27 You may cure this default within THIRTY (30) days of this letter by paying to us the amount 'under (e) above, plus any additional monthly payments and late charges (and other charges) which may faLL due during this period. Such payment must be either by cash, cashier's check, certified check, or money order made payable to G.E. Mortgage Services, 625 Maryvi l te Centre, St. Louis, MO 63141, Attention: Cashiering Department. If you do not cure the default within THIRTY (30) days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgage property. If the mortgage is foreclosed, your mortgage property will be sold by the Sheriff to payoff the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings Dgainst you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started Dgainst you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees wilt be added to whatever you owe us, which may also include our reasonable cost~. If you cure the default within the THIRTY(30) day period, you will not be required to pay attorney's fees. 'G ACT 91 NOTICE GECnflil.1/ TAKE ACTION TO SAVE YOUR ItOME fROM FORECLOSURE GE CIII/it,ll MOtlg.lfJl! Sc/vices, IlIc The COflJl1onwcal th of Pennsylvuni a' s Homeowners I Emcr9cneY:,~OM:.9a!JO,' J,' ',!'! I J'I" 1'1,'; -,I!,J,' Assistance Program may be able to help you. Read the foll~~nW;'ndthic':td' Hn(1 i}!{} I) 1/ /1", .J.'I i'/ I.', /I",,' t, ,: I ,.~ III!,' / U/":', out how the progrem works. IIII,/i./i..... If you need more information, call the Pcnn5yLvnnia Hou~in9 Finance Agency at '-800-342-2397_ La Notification en Ddjunto cs de sumo importnncia, pues ~fccta su derccho D continuaf vivicndo en su coso. Si no comprcndc cl contcnido de csta notificacion obtcnga una traduccion immcdiatamcntc llamando csta agcncia (Pennsylvania Housing Finance Agency) sin cargos at numcro mcncionado arrib~. Pucdes ser e(egible para un prestamo por cd program,} t !amado "lIomcowncrs' Emergency Mortgage Assistance ProgromU 01 cual puede salvor su C<lsa de lo perdida del derccho a rcdimir su hipoteca. ACT 91 NOT I CE IMPORTANT: NOTICE OF HOMEO~NERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS May 10, 1996 RE: G.E. CAPITAL MORTGAGE SERVICES, INC. Property Address: 651 WilLOW GROVE ROAD, CARLISLE PA 17013 loan # 16300295 TO: JULIA MACZUGA 651 WILLOW GROVE ROAD CARLISLE, PA 17013 FROM: G.E. Capital Mortgage Services You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be el ;gible for emergency temporary assistance if you defoult has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you arc entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "facc-to-f<lce" meeting ",ith a representative of this lender, or with <l designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) day'_ II yo:go /oco-to-Ioco ""oting with thi, l.nder, or with 0 con'''''''' cr.dit) counseling agency Identified in this notice, no further proceeding in mortgage _,.___.._._.~~~~~~~_~'Lt_~~~-~~.!l.~~..f_~!_~h_!!t.'( nO! day.s__~!t~!'_ ~h~ da~~ of this meeting. The nome, address, and telephone nLtllber of our rcprescntiltilf'd~hnIMorlg.1gflSelvicc,,'llc. G.E. Capital Mortgage Services 11111111,,1111 (",p'!JI,\',',/rJ."I"r'Il/IlIf,)''''1I 625 Mary..-i lIe Centre Drive /II{}I)~V."II(H'J' ";"Ii't. ',,1."" I,/(}() . I'I! n".Il!!),''., IIIP'I""'J IX //11// (!II', st. lOuu, MO 63141 1 (800) 317-4522 The nomes and addresses of designated consumer credit counseling agencies arc shown on the attached sheet. It is only necessary to schedule one face-to' face meeting. You should advise thi~ lender immediately of your intentions.. 1111,}1.11,',' Your mortgage Is in default becnuse you hnve failed to pny promptly in~tallmcnts of principal and interest, as required for at least sixty (60) days. The total amount of the delinquency Is $2,709.27. That sum includes the following: payments due 03J01J96 through the first of this month and late charges. Your mortgage is also in default for the following reason: Unable to Contact. If you have tried and are unable to resolve this problem ot or after our face-to-face meeting, you have the right to apply for financial assistance from the Homeowner~' Emergency Mortgage Assistance Fund. tn order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to. face meeting. It is extremely important that you file your applica~ion promptly. If you do not do so, or if you do. not follow other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criterin established by the ACT. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application; During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1-800-342'2397 (toll free number). Persons with impaired hearing can call 1-800-342-2397. In addition, you may receive another notice from this lender under Act 6 of 1974. That notice is called a IINotice of Intention to Foreclose.1I You mU5t read both notices, since they both explain rights that you now have under Pennsylvania low. However, if you choose to exercise your rights described in this notice, you cannot foreclosed upon while you ore receiving that assistance. Sincerely, 16300295 KIRK "HER,l (800) 317-4322 . Collection Department Gf Capital '8 HUD APPROVED COU~SElING AGENCIES SERVICE AREA: G~EENE COUNTY PENNSYlVANIA(Cont) GE CIIJlit/J1 Morlg,lll" Serlllces, Ille SERVICE AREA: UESIMORElAAC"COutLTfl/"!)'" '!,:';.. ,,; I' ~ATElll'E Of riCE: WASHINGTON/GREEN COMMU~IIY ACTION CORPORATION 202 OLD COUNTY OFFICE BUilDING WAYHESBURG, PA 15370 (412) 852 2893 SERVICE AREA: LAWRENCE COUNTY SATELLITE OFFICE: CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC. 309 SHITHFIElD STREET HANEY OFFICE BUILDING, SUITE 304 NEW CASTLE, PA 16101 (412) 652 8074 SERVICE AREA: MERCER COUNTY SHENAGO VALLEY URBAN LEAGUE 39 CHESTNUT STREET SHARON, PA 16146 (412) 981 5310 SERVICE AREA: WASHINGTON COUNTY WASHINGTON/GREENE COMMUNITY ACTION CORPORATION 2198 NORTH MAIN STREET UASHINTON, PA 15301 (412) 225 9550 ;'(lI),') ',V,"".rl,,'-/, '''''.'' CONSUMER CREOII CO\JNSElI~G:}stft'v\h','" II., ",11,,1-'1';', OF ~ESTERN PENNS1LVftNIA, INC. CHAMBER OF COMMERCE BUILDING 662 NORTH MAIN STREET GREENSBURGH, PA Ei601 (412) 838 1290 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNsnVANIA, INC. 309 SMITHFIELD STREET PITTSBURGH, PA 15222 (412) 471 758f, ELDER-ADO, INC. 320 BROWNSVILLE ROAD PITTBURGIl, PA 15210 (412) 381 6900 GARFIELD JUBILEE, ASSOCIATION 5138 PENN AVE. PITTBURGH, PA 15224 (412) 665 5200 HOUSING OPPORTUNITIES, INC. 133 7TH STREET POST OFFICE BOX 9 MCKEESPORT, PA 15134 (412) 664 1590 URBAN LEAGUE HOUSING COUNSELING SERVICE, INC. 304 ROSS STREET PITTSBURGH, PA 15219 (412) 261 0932 Gf Capital "-' , . )cp!e'Yo,I) , I )(', f'7't~ (j'~~7>rJ I~:J~",,".I'" l I lJ' , " / , \"., '1 (: \ ~) (. I i:: L' C) , [0' , ,J I .- C' ') : c I C' " "j , (_.. C. - -- ,. -, :::.l l' V') 0 '-" :.J .~ I'~ "-' '~'J .......;.....J ~-- ~ : ~ ~ n~ - (:;- - '" .:::: rn - <" N ~ .". ~ '1')""'" :v \,- ~ '00 GE Capital Mortgage Services, Inc. YS Gregory Radie and Julia Maezuga In The Court of Co III III on Picas of Cumberland County, Pennsylvania Writ No. 19'J(,-4W2 Civil Terlll Steve Whistler, Deputy Sheriff, who being duly sworn according to law, states that on August 19,2002 at 5:50 o'clock PM, he served a true copy of the wilhin Real Estate Writ, Notice and Description, inlhe above entitled action, upon the within named defendant, to wit: Gregory Radie, by making known unto Margaret Radie, wife of defendant, at 651 Willow Grove Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. R. Thomas Kline, Sheri 1'1', who being duly sworn according to law, stales that he made a diligent search and inquiry lor the wilhinnamed defendant, to wit: Julia MaeZllga, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Luzerne County, Pennsylvania to serve the within Real Estate Writ, NOliee and Description according to law. LUZERNE COUNTY RETURN: Now, Wednesday, August 28, 2002 at 7:25 o'clock P.M., served the wilhin Notice of Sale, Notice of Rights, Description and Execution upon Julia Maczuga at her residence, RR #1, Box 988, Sugarloaf, by handing to Juanita Maczuga, her sister, and made known to her the contents thereof. So answers: Barry L. Stankus, Sberiff of Luzerne County, Pennsylvania. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2002 at 11:060 'clock A.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Gregory Radie and Julia Maezuga located at 651 Willow Grove Road, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served thc above Real Estate Writ, Notice, Postcr and Description in the following manner: Thc Sheriffmailed a notice of the pendency of the action to one of the within named defendants to wit: Gregory Radie, by regular mail to his last known address of 651 Willow Grove Road, Carlisle, PA 17013. This letter was mailed under the date of October 1,2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Eslate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to one of the within named defendants to wit: Julia Maezuga, by regular mail to her last known address of RR I P.O. Box 988, Sugarload, I' A 18249. This letter was mailed under the date of October I, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on Dccember 4,2002 at 10:00 o'clock A.M. He sold the same for the sum 01'$1.00 to Attorney Frank Fedenmlll for GE Mortgage Services, LLC flk/a GE Capital Mortgage Services, Inc. It being the highest bid and best price received for the same, GE Mortgage Services, LLC f/k/a GE Capital Mortgage Services, Inc. of 5024 Parkway Plaza Blvd., Bid. 7/F/C, Charlotte, NC 28217, being the buyer in this execution paid SheriffR. Thomas Kline the sum ofSIO,500.00. Sheriffs Costs: Docketing 30.00 Poundage 1800.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 1.00 6.90 14.40 15.00 30.00 428.15 308.95 25.20 25.00 39.50 S2794.10 Sworn and Subscribed to Before Me SO!;'SW;jr This ,~ Dayof jLt.~ .~~~~"" C I R. Thomas Kline, Sheriff 2009, A.D. /'1'-'- () /k.;J~IJ7-i ).J \' . . II Prothonotary BY' CclLl.5YVlLt~ Real Estat;;Beputy )u J.JJtL 1JIY ;() ~ (",,,,;it " r. '" (:k-- .1/'1" ftu/. 131 32 '1 Disbursements: To Sherifrs Costs To Legal Search To Allomey Frank Federman Credit Writ Total Disbursement: Balance for Distribution: So Answers: r~~ R, Thomas Kline Sheriff $2,834.10 200.00 7,465.90 79500.00 ($90.000.00) 0.00 i 1 I I I , I .1 I TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOV AL IS PRODUCED. SHERIFF SALE NO. 11 Held Wednesday, Deccmber 4, 20()2 Date: December 4,2002 TAXES: Rcceipts for all taxes for the ycars 1999 to 200 I inclusive. Taxes for the current year 2002. WATER RENT: SEWER RENT Company assumcs no liability for private supply of water or sewer Receipts to be produced if services are lienable. MECHANICS' AND Possible unliled Mcchanics Liens and Municipal Claims. MUNICIPAL CLAIMS :1 MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Dced from Cumberland County Sheriff to dated . 2002, and recorded ,2002, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Julie D. Morton, formerly known as Julie D. Moyer by deed dated October 20, 1994 and recorded October 31, 1994 in the Office of the Recorder of Deeds in and for Cumberland County. Carlisle. Pennsylvania. in Deed Book 114. Page 213. granted and conveyed to Gregory Radic and Julia Maczuga, single persons. I I I I I I i I I I I I I I I I ! i , I I i i OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded casements. discrepancies or conOicts in boundary lines, shortage in area and encroachments which an accurute and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in 50 foot wide private right-of-way as shown on the Preliminary/Final Subdivision Plan for Cathryn Brewbaker. Recorded in Plan Book 55. Page 63. 6. Subject to responsibilities for maintenance of the 50 foot wide right-of-way as imposed by conditions recorded 00 Preliminary/Final Subdivision Plan for Kathryn Brewbaker recorded in Plan Book 55. Page 63. 7. Building setback lines and eonditions as shown on the Preliminary/Final Subdivision Plan for Cathryn Brewbaker recorded in Plan Book 55, Page 63. 8. Mortgage in the amount of $84.500.00 given by Gregory Radie. and Julia Maczuga, to Equity One. Inc. dated October 26, 1994 recorded October 31, 1994 in Mortgage Book 1239 Page 594. Assigned to North Ameriean Mortgage Company by instrument recorded November 16, 1994 in Miscellaneous Reeord Book 486, Page 108. Further assigned to GE Capital Mortgage Services, Inc. by instrument recorded November 13, 1995 in Miscellaneous Record Book 508, Page 8. Complaint in mortgage foreclosure filed by GE Capital Mortgage Services, Inc. as Plaintiff. against Gregory Radic and Julia Maczuga as Defendants on August IS, 1996 in the Office of the Prothonotary of Cumberland County to file number 96-4602. Judgment in the amount of $95,000.95 entered November 8, 1996. 9. Rights granted to United Telephone Company of Pennsylvania by instrument recorded July 27, 1988 in Miscellaneous Record Book 352 Page 727. 10. Rights granted to the Pennsylvania Power and Light Company by instrument recorded August 26, 1988 in Miscellaneous Record Book 353 Page 1085. 11. Rights granted to United Telephone Company of Pennsylvania by instrument recorded July 27,1988 in Mbcellaneous Record Book 352 Page 729. 12 Rights granted to the Pennsylvania Electric Company Company by instrument recorded June 22, 1950 in Miscellaneous Record Book 93, Page 397. 13 Rights granted to United Telephone Company of Pennsylvania by instrument recorded February 28.1974 in Miscellaneous Record Book 208 Page 120. 14 Rights granted to United Telephone Company of Pennsylvania by instrument recorded September 30.1975 in Miscellaneous Record Book 217 Page 508. 15 Under and subject to right-of-way granted to Glenn Tolbert and Norman E. Markley as recited in deed recorded in Deed Book "T," Volume 13, Page 267. 16. Satisfactory evidence to be produced that service of the Writ of Execution and Complaint was sufficient on Julia Maczuga. 17. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 18. Real estate taxes accruing on and after January 1.2003 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill t412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. <~~~. RobcI1 G. Frey, Agent Noll:: This Title Report shall not he valid (l .lding until \:otll1tcrsigl\cd hy an authorized sigl1utory. REAL ESTATE SALE NO. 11 Writ No. 1996.-l602 Civil GE Capital Mortga~t: Scr....\ces. Inc. vs. Gregory Radle and Julia Maczuga Atty.; Frank Federnmn ALL TIiAT CERTAIN tract of land situate In North Middleton Town- ship. Cumberland County. Pennsyl- vania, bounded and described In accordance wtth a Plan prepared by Stephen G. Fisher. P.L.S" dated March 18th, 1988 and recorded In the Office of the Recorder of Deeds for Cumberland County tn Plan Book 55. page 63. BEGINNING at a point on a 50 foot private right-or-way at lands now oc formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the afore- mentioned Subdlv1slon Plan: thence by land of the aforementioned Gardner. SOl1th 35 degrees 31 min- utes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly. Sr. and Thelma L. Kelly: thence by lands of the afore- mentioned Kelly. South 08 degrees 23 minutes 49 seconds East 363- .26 feet to a pOint on the line with the aforementioned Kelly and at the common comer with Lot Number 3 as shown on the aforementioned Subdivision Plan: thence by Lot Number 3. North 79 degrees 44 minutes 22 seconds West 68B.55 feet to a point on the common cor- ner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbal<er: thence by lands of CathrYn J. Brewbaker. North 05 de~re~s 14 minutes 47 seconds West 132.14 feet to a poInt In line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. t as shown on the aforementioned SubdivisIon Plan: thence by Lot Number I. North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of begin- ning. CONTAINING 4.5716 acres and desIgnated as Lot No.2 on Plan for Cathryn Brewbaker. Subject to the fifty foot right-of-way for Ingress. egress and regress for the owners of Lot Numbers 1. 2 and 3 as shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer. a single' per- son, by Vlrtue of Deed dated Octo- ber 26. 1994 and recorded October 31. 1994 and recorded (n the Office of the Recorder of Deeds in and for Cumberland County. PennsylvanIa. In Deed Book 114, Volume 213. at granted and conveyed unto Gregory Radle and Julia Maczuga. Mortgag- ors, herein. IMPROVEMENTS THEREON: Residential Dwelling. TAX PARCEL #29-07-0473-004A. PROPERlY BEING KNOWN AS: 651 WTLLOW GROVE ROAD. CAR. LISLE. PA 17013. .., GE'CAPITAL MORTGAGE SERVICES, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COM;\ION PLEAS GREGORY RAI>lC Jl'L1A :\IACZl'GA CIVIL DIVISIO.... NO. 19%-04602 Dcfcndanl(s). AFFIDAVIT PURSUANT TO RULE 3129 (Aflidavil No. I) GE CAPIT'AL MORTGAGE SERVICES, 1:"1 C. , Plaintiff in th~ above action, by its attorncy. FRANK FEDERMAN, ESQUIRE, scts forth as ofthc datc the Praccipe for thc Writ ofExccution was fil~d the following information concerning th~ real prop~rty locat~d at, 651 WILLOW GROVE ROAD, CARISl.E, PA t 7013. 1. Namc and address ofOwncr(s) or rcputcd Owner(s): Name Last Known Addrcss (if address cannot bc reasonably asecrtaincd, please indicatc) GREGORY RADlC 651 WILLOW GROVE ROAD CARLISLE, PA 17013 JULIA MACZUGA RR 1 P.O. BOX 988 SUGARLOAF, PA 18249 2. Name and address of Dcfcndanl(s) in thc judgmcnl: Same as above 3. Name and last known addr~ss of every judgment credilor whose judgment is a record lien on the real property lo be sold: Nam~ Last Known Address (ifaddress cannot be reasonably ascertained, please indicate) None . GE' CAPITAL MORTGAGE SERVICES, INC. Plaintiff, CUMBERLAND COUNTY v. No. 1996-04602 GREGORY RADlC ,JULIA MACZIIGA Ilcfcndant(s). July 3D, 2DD2 TO: GREGORY R-\D1C 651 WILLOW GROVE ROAD CARLISLE, PA t7013 .Il!LJ..\ MACZUGA. RR 1 P.O. BOX 988 SUGARLOAF, PA 18249 "THIS FIRM IS A DEBTCOLLEC7'OR ATTE.lIPTlNG 7'0 COLLECT ..I DEBTAND ANY INf'OR,I/..1TI0N OBTAINED WILL BE USED FOR THA T PURPOSE IF rou 11..If'E PREVIOUSLY RECEIVED A DISC/lARGE IN BANKRUPTCY AND THIS DEBT /VAS NOT RE..IFFIRMED. THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPTTO COLLECT A DEBT. BUTONLY ENFORCEMENTOFA LIEN AGAINST PROPERTY." Your house (real estate) at. 651 WILLOW GROVE ROAD. CARISLE. PA t7013. is schedulcd to be sold at the Sheriffs Sale on 12104/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment 01'$95.000.95 obtained by GE CAPITAL MORTGAGE SERVICES. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, youl11ust take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (2 t 5) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACF.. I. If the Sheriffs Sale is not stopped. your propeny will he sold to the highest hidder. You may find out the price bid by calling (215) 563- 7(J()(). 2. You may be able to petition the Coun to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. lfthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IFYOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTOR.l"iEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (7t 7) 249-3166 (800) 990-9 t 08 ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Stephen G. Fisher, P.L.S., dated March 18th, 1988 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 55, page 63. BEGINNING at a point on a 50 foot private right-of-way at lands now or formerly of Branson L. and Ruth A. Gardner and at the corner of Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by land of the aforementioned Gardner, South 35 degrees 31 minutes 07 seconds East 131.67 feet to a point at lands now or formerly of Melvin E. Kelly, Sr. and Thelma L. Kelly; thence by lands of the aforementioned Kelly, South 08 degrees 23 minutes 49 seconds East 363.26 feet to a point on the line with the aforementioned Kelly and at the conunon corner with Lot Number 3 as shown on the aforementioned Subdivision Plan; thence by Lot Number 3, North 79 degrees 44 minutes 22 seconds West 688.55 feet to a point on the common corner of Lot Number 3 and with line of lands now or formerly of Cathryn J. Brewbaker; thence by lands of Cathryn J. Brewbaker, North 05 degrees 14 minutes 47 seconds West 132.14 feet , to a point in line with lands of the aforementioned Cathryn J. Brewbaker and Lot No. 1 as shown on the aforementioned Subdivision Plan; thence by Lot Number 1, North 69 degrees 14 minutes 26 seconds East 598.97 feet to a point, the place of beginning. CONTAINING 4.5716 acres and designated as Lot No. 2 on Plan for Cathryn Brewbaker. Subject to the Fifty foot right-of-way for ingress, egress and regress for the owners of Lot Numbers 1,2 and 3 as.shown on the aforementioned Subdivision Plan. BEING THE SAME PREMISES which Julia D. Moyer, a single person, by virtue of Deed dated October 26, 1994 and recorded October 31, 1994 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, pennsylvania, in Deed Book 114, Volume 213, at granted and conveyed unto Gregory Radic and Julia Maczuga, Mortgagors, herein. IMPROVEMENTS THEREON: Residential Dwelling ~AX PARCEL I 29-07-0473-004A PROPERTY BEING KNOWN AS: 651 WILLOW GROV~: ROAD, CARISLE, PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonweallh 01 Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the iaws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsyivania, owner and publisher of The Patriot-News and~ Sundav Patriot-News newspapers 01 general circulation, printed and pubiished at 812 to 818 Market Street, in the City, County and State aforesaid: that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and ail have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daity and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of October and the 5th day(s) of November 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockhoiders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317'J'- , r PUBLICATION - ..,..:<,......~:.;;.~...~..:......................,...........,........... COpy l, Sworn to and subscribed before.t)is 14th day f ~ove ber 2002 A.D. S ALE #11 NolanalSeaJ /, ' Terryl.RusSell,NotaryPublic '! .....2: /. ory Of Harnsoorg. Dauphin County My Commossoon EXplresJune 6.2006 NOTARY PUBLIC Member. Pcnnsy1YJma AsS0Ci3llon Of Notal1es My commission expires June 6, 2006 o. Writ No.l996-4e02 Civil T.rm GE Capital Morlg.g. Slrvlc.., Inc. v. Gregory R.dle and JU~I Maczuga AUy: Fr nk Fad.rman DESCRIPnON ' ALL ~T CE IN tr3ct of land situate in North Mllj<!lelon ~hip, Cumberland County, Pcnnsylnma, bounded Bnd described in ammLmcc with :l Plan p~pan-d by' Stephen G. Fisher, P;L.S., dated Mmh 18th. 1988 and recorded In the Office of the Recorder of Deeds ror Cumberland COU~IY in Phn Book 55. page 63. BEGINNING at a ~tnt on a SO fool private right- or-way al [and~ now or formerly or Rran\On L CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT.NEWS CO., Dr, For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 307.20 1.75 308,95 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of IhJLEgtriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By......................................................,............. REAL ESTATE SALE NO. 11 Writ No, l!I!JIi -Hill:.! Civil (iE Call1lal M()rI~d~C' St'r...kl'''. ill!' \".. (in'gory Hildh' .lllll ,h,lid ;\1.l('ZIl~~.t t\tt\',' Fr,lIlk Fc.(j,-rllldll AI.I. TIIAT (:Elfl",\Ir\ Ir.WI 1>11;11111 ,1111;11(' III Norlll :-'11rldkloll Towll ...hip. Clllllll1'rLuull:01l111\'. 1'1'1111',\'1 \';t I 11.. , hOlllllkd "ILd dt'''l'l'ilH'd ill ;If"f'llnldll('c willi ;L l'l,lIlI'ITPdrt'd II.\' S1c'ptll'1l Ci. Fhlwr. I'. r. s d.t1l'c1 i\1.lft'1L P'irll. I!II1.''i dlld r",onhl ill rll!" Ollk\' 01 Ill(" lkl'l!l'dc'r of [ked... lOl" (:llllllll'rl.llUI 1:"1I111\, irl 1'1.111 Il<lok :,....... J1dgl' li;\ IlE<iINNINCi 011 d I",jlll !Ill d :Ill loul prh';J[t' ri~lil "I W,l\' ,II [,I/Ill... now OJ' J<Jl"lIU'rl\' (II' Ilr,l/t"O[1 l.. dlltl I~fllll r\. (j,trdrwr drill .II c1ll' ('()l'lll'l' or l.or No. I a.... ..!trlWIl Oil lht' ;dnl"!' lllt'llthlllc'cl Slll)(li\'i"I'1l11'l;UI: Illt,tH'!' IJV l<lud 01 Iht. "ron'lllt'llt iOlled (i.lnlllt'r. SOlllll :\!'"> dq.!ln.... :\1 luill lIlt.... ()7 ...t'('lllltL.. 1';.1:->1 1:\I.li7 It.,.t It I .L 1"'lIlt .11 1.11"l., 11<)\" "r t',rllwrl\" Id Mdvill E. 1{l'lIv. ~;r dud'l ilt'llUd I. I\d].v; 11lt'1ll"l' hy l,ll11l... of till' ,lIlll't. IlU'llliollt'd Kd].v. SOlltll (),"I dt.j.t]"('t.... :.!:I IIlIIlII!CS 'HJ "'1't'otHls ]-;,\...' :lIi:1 .:lli fn'l 10;j poillt Oil lilt' 1I1H' with Ill<' afol"t'IlI('I]tiOlll'd Kdl.\' ,1I1l] al lILt' l'Olllllloll ('Ol'lH'1' with Lot Nllllllwl' :\ ;I... ...llOwn Oil lilt' at"Ol'l'lllt'lLliotll'd Slllldivi...loll 1'1;111: tll('llI'(' h.v 1.01 NlIllll)('r :\. Norlh 7~J dt'J.!J"I'(.... ']'1 IIdlllllt.... 2:l ""'('t>lltl... \Vt....l (iH.'i.:,:. J('('1 10 i\ pollll Oil rill' ('1l1111111l/] 1'01' IltT of 1.01 Nlllllht'J" :1 alld willi [lilt. of lands now or bnllt'J"I_\' or C:,llll]~'1l .J. Bn'whak!'l': 111('11('(' II,\' LUld... (II Calhr,\'l] .1. Ilrt'wlJ;\kn. Nflrlll (j:, dt./.!l"I.t.... 1.1 1Il1111l1t.s ,17 ...,.t'olltl... We...! ]:12. H k('1 10 ;1 poilll ill iiiit' wilh ];md... of IIII' OlrOn.tll"llllolll'd C;Il!l];.'1\ .J. Ill'l'wh;rktT ;!lul I.ot No. 1 01... ...!lO\\'11 Oil lilt' afort.ltU'llliolll'd Sllbdivbioll 1'1;1l1: tllt'IIt'(' b.v I.ot Nllllilwr I. North fi!J dt./.!l't't'S ] ,\ Illillllll.... 20 ...I'{"(lIl(!... 1':"...1 :.!JH. ll7 kl'l 10 a pollll. llll' platT of ]wglll nlllg, CONTAININCi '!.!i7 J{j ,wrl'S ,UIIJ dl'...il.!ll:llt'd ;IS Lot No, 2 011 1'1;1/1 Jill' C;lllllyrl Ill'l'wtJ;rkl'l', SlJhjt'c.t 10 llll' Fifr.\' fool I'l/.!ltlufwa.\' for itlgl't'ss. t'.cn'ss ;J1lt1 l't'grc...s for III(' O\\'IIt'l's of Lol NliIlIllt'l"s I. 2 awl:1 ;IS showlI 011 lilt, ,lfon'lll('lllioIWd SlltJllivlsllllr Plau. IlEI;".J(i TilE SM\.lE I'HEMISES whkh .lull;! D. Moyer. a ...lll!.!]1' pt'l' "'011, h.\' Vil"ll]{' of D('l'(1 dOlled (kIn ]Wl' :In. ]~J!J'I ;Jill I I'l't'OI'I/(.tJ <kloJll'r :1]. ]~J!J'l :tIIC! 1"t'l'Onlt'd II] 111(' ()mn' of lILt' Ikl'ord!'r of Deed... ill <lIld for (:llllllwrl,uld (:01 II 1l,V. 1'('llllsvJv,IIIJa. ill Iked Book 11.1. VObUII{' '2]:t <II J.!]':\llled ;lflll COll\'(',Vt'd 111110 Cil't'/.!oI'Y I~:\dll' .allll.lulia M,lt'ZII/.!:1, MlIl'l~;L~ ol'!';,Ilt'l'clll. I~II'I~OVEMENTS TIIEI~E()N: HniltkIIIIOlII)wdlillJ.!. TA'i: PAIWEI. 112!J 07 (}.J7:1 (JIHA. I'I~OPEHTY HEINCi KNOWN AS: (j!i I WILI.OW (iIH>VI~ HOAD, CAH I.ISI.E. P^ J 70 I:!. . . . . '-"",:- ... ': . - _. -.