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HomeMy WebLinkAbout96-05106 ..... - ~ . .0 .. 1:::: ~ .~ ,.... Ii! <<. ~~ ~ i 'I ~ ~... " ~ ~ c .3 II) '> . ~. ~ ~ THE FIRST NATIONAL BANK OF MARYSVILLE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PA Plaintiff vs. NO. 9c. ,>,/t(, C~. ~t r;........- STEPHEN J WARREN AMBER J WARREN Defendant/s CIVIL ACTION - LAW MORTGAGE FORECLOSURE COMPLAINT 1. Plaintiff is The First National Bank of Marysville. a Pennsylvania corporation with an address at 101 Lincoln Street. PO Box B, Marysville, PA 17053. 2. Stephen J. Warren, a Defendant and Mortgagor. is an adult individual with an address of 426 Water Street. New Cumberland, Cumberland County, Pennsylvania 17070. 3. Amber J. Warren. a Defendant and Mortgagor. is an adult individual with an address of 2630 Valley Road. Marysville. Perry County, Pennsylvania 17053-9749. 4. On or about September 5, 1995. Mortgagors executed and delivered a Note in the sum of $52.000.00, payable to The First National Bank of Marysville. a copy of which is attached hereto. marked Exhibit "A" and made a part hereof. 5. Contemporaneously with and at the time of the execution of the aforesaid Note, in order to secure payment of the same, Defendants made, executed and delivered to The First National Bank of Marysville, a certain real estate Mortgage which is recorded in the office of the Recorder of Deeds of Cumberland County. Pennsylvania in Mortgage Book ,16(' Page 1"t>, conveying the subject premises to plaintiff. which mortgage is incorporated herein by reference. 6. The land subject to the Mortgage is situated in the Borough of New C'..Imberland . Cumberland County. Pennsylvania and i8 more particularly described in Exhibit .B" attached hereto and made a part hereof. 7. Mortgagors are the real owners of the land subject to the Mortgage. 8. The mortgage is in default due to the fact that the Mortgagors have failed to pay monthly installments of $361.82 for the months of May, 1996, and all subsequent monthly installments thereafter and the following amounts are due on the Mortgage: (al Unpaid principal balance (b) Interest to September 29, 1996 (c) Late Charges (dl Attorney's Commiss~on lOt Total Amount Due $ 51,721.96 1,859.18 86.82 5.366.80 $59,034.66 together with interest at the per diem rate of $10.33 per day after September 29, 1996, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 10. Mortgagors are not members of the Armed Forces of the United States of America. nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Notice of intention to foreclose and to accelerate the loan balance has been given to the Mortgagors in accordance with Section 403 of Pennsylvania Act No. 6 of 1974, but the Mortgagors have failed to reinstate the Hortgage in accordance with the provisions thereof. A copy of the notice is attached hereto. marked Exhibit "C" and made a ~art h~reof. 12. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program I and Defendant has either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. 13. This complaint is an attempt to collect a debt and any information obtained will be used for that purpose. -- FIXED RATE NOTE (Daily Simple Interest) S52,OOO.00 September 5, 1995 New Cumberland, Pennsylvania FOR VALUE RECEIVED. the undersicned (jointly and leverally) promise to pay The First National Bank of Marysville. a Pennsylvania Corporation. ("Note Holder"), or order. the principal sum of Fitty Two Thousand and 00/100 Dollars (S52.000.00) with interest on the unpaid principal balance trom the date ot this Note, until paid, at tbe rate of Seven and Forty Five Hundredths (7.451) per cent. per annum. The principal and interest shall be paid on demand, in the absence of demand. payments sball be made in 59 (tifty nine) consecutive monthly installments of principal and interest in the amount of Three Hundred Sixty One Dollars and 82/100 (S~61.82) and 1 (one) final payment in the amount of Forty Nine Thousand Five Hundred Thirty Seven Dollars and 90/100 (S49.537.90). Tbe payment is due on the 5th day of each .onth. beeinnine October 5. 1995.. Principal and interest shall be payable in lawful money of the United States of America. at the offices of the holder in MarYlville. Pennlylvania (or at sucb other place al the Note Holder .ay desienate in writine). In applyine iOltallments under this Note. Note Holder will apply all amouots received first to all interest accrued on the date the payment is credited and then to the unpaid principal balance until the entire indebtedness. evidenced by this Note. il tully paid. except that any remainine indebtedness. if not loaner paid. Ihall be due and payable on September S. 2000. In the event of a default in the payment of any installment due on this Note. a default in the performance of any covenant or condition in the Morteae. securine thil Note or a default in the performance of the oblieationl impoled by any Morteaee constitutine a lien luperior to the Morteaee lecurine thil Note. the Note Holder upon providine the undersiened with such notice as required by law. Ihall have the rieht and option to declare the entire unpaid balance or this within indebtedness due and payable at once and to toreclose any Morteaee securine this Note. Failur. to exercise this option shall not constitute a waiver at the rieht to exercise tbe sa.e in tbe event of a subsequent deraul t. The ~ot. Holder .ay require tbe und.rslened to reimburse Note Holder tor any charee the Note Holder bas been reqUired to pay upun tbe dishonor or the undersiene.', check. Tbe undersiened .af prepay wilbout penalty Ihe tnde~I..ne$s eVidenced her.by .n wbnl. ur tn part at anr r:-;Hlp.tr u\'. time. Any prepayment will be applied to the outstanding principal balance atter payment at all late charles and interest throulh the date at such prepayment. Any prepayment will not postpone the due date at any subsequent monthly installment unless Note Holder otherwise alrees in writinl. In the event it becomes necessary to reter this Note to an attorney at law tor collection, or it this debt at any part hereof be collected by any attorney in lelal proceedinls at any kind, the undersigned shall reimburse Note Holder ror such reasonable attorney's rees, court costs and rees as are actually incurred by Note Holder in the collection or any part at the debt evidenced by this Note. Tbe undersilned bas been inrormed and understands that credit lire insurance is not required to obtain credit. Property insurance on the real property described in the Mortlsce may be obtained rrom anyone you want that is acceptable to the Lender. The undersilned and all endorsers, sureties and luarantors rurther consent to any and all extensions or tiae, reDewals, waivers or aodirications which aay be granted or consented to by the Note Holder hereor as to the time or payaent or aDY other provision or this 1Iote. Presentment. notice or dishonor, and protest are hereby waived by all aakers, sureties, luarantors, and endorsers hereor. This Note Is the joint and several Obligation or each aaker and shall be binding upon them and their heirs, successors and assigDs. The parties alree that they have engaged in this transaction evidenced by tbis Note and the Mortgage securing this Note pursuant to applicable rederal, as well as state law, IDCluding the Secondary Kortgage Loan Act. al have been preeapted by applicable rederal law. This Note is secured by a Kortgage or even date herewith executed by Stepben Y. Warren and Aaher J. Warren, to The First National aank or Yarysville, conltltuting a rirlt lien on real property located in Cuaberland County, and duly rlled ror record in the Otrice or the lecorder or Deeds ror lald Countf. 1M WITlESS WHEREOF. the date rirst .ritten i l~'~ ..., has set bil band on Stepben .. \ \}.rm \\ 'i. I. Aab.r J. Warren \ \ \_ '\ ~'f't "- "arren NOTICE OF INTENTION TO fORECLOSE MORTGAGE . - 7-11-96 .-' TO ~~eohen J. Warren Dolle 01 NO(ICe 426 Water St.. t..'91.1 o~..1111nn, 0& Loan No __Z21296 The MOR TGAGE held by The !'irst Nationall3aM of /'arysville - - - ---- Ihere,,,alte' we usor ourSI on your properly located at _ 426 water St....New CUmberland. .1'/1 -.----' IS IN SE R IOUS DEFAUL T because 'lot/ have 1101 made the moml1lv pdymerrrs of S .361.82 for the mOllths of /1ay __ ___ _. __ _June _._ ...-. and ~1y' ~J996 andlorbecause ___' -- --- Late charges and 01 her charges have also accrued to Ihis dale in Ihe amounl of $72.35 -' The 10lal amounl now relluired 10 cure Ih,s defaull. or In olher words. gel caughl up in your paymenls. as of Ihe date of Ihis leller, 's S l...l51 81 'lOll "'dV mre rhls defat/It with", THIRTY (3DI DAYS o( tho ctdto or Ihls le:ter. by paY'llg 10 uS thf' above amount o( 5.1.157.81. _. _. plus any addItIonal monthly payments and late charge which may fa(/ ,/"e aurlng rhls pe(lod Such paymenl musl be made ellher by cash, cash,er's check, cert",ed check or money order, and made al The FirJ?t N.!t.iQML~kQf !'tU:Y5'lille._- _ .lll1 Llnmln .St... M:4rySl'! IIp PA 17053 II you do nOI cure Ihe defaull wlth,n THIRTY (30) DAYS. we "'lend 10 exerCIse our right to Kcelerate rhe morlgage payments, This means that whatever is owing on Ihe anginal amount borrowed will be cOnsidered due ImmedIately and you may lose the chance to payoff the original mortgage in monthly installments. " full payment of Ihe amounl of default is not made within THIRTY (301 DAYS, we also intend to instruct our attontevs to start a lawsUl t to (oreclose your mortgaged property. If the mortgage is forectosed your mortgaged property wi/1 be sold by Ihe Sher"f to payoff the mortgage debt. 11_ refer your case to our attorneys, but you cure the default before they begin legal proceedings a~inst you. you will still have to pay the reasonable attorney's fees. actually incurred, up to S50.00. However, if legal proceedings are started against you, you w,lI have 10 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 defllult Within the thirty day period. you will not be required to Pilyatrorney's fees. We may also sue you personally for the unpaId princ,pal balance and all other sums due under the morl~ge. If you ha.e nol cured the default w,th.n the thlfty day perIOd and foreclosure proceedings have lM.gun. you st"l hd,'e the (lgM 10 cure the defautt and prevent the Sill. lit any time up to one hour before the Sheriff's fureclosur. sale You mav do so by paying the total amount of Ih. unpaId monthiy Pilyments plus IIny late or other ~'f/I!s then due. as well al the reasonable attor".y's fees IInd costs connectrtd WIth the foreclosure Slllet dnd perform IIny athe' rrqUlre ments under the mortgilge. I I 's estimated th.t the earhest dal. Ihal such a She"ff's sale could be held would be appro..mately 10-13-96 . A nOI.ce of the dale of the She"" sale w.1I be sent to yOU before the 5'.le. Of course. the amount needed 10 cure Ihe default WIll ,"crease Ihe longer you wa.1 You may find out at any I,m" uactly wha, 'he 'eou".d "a,ment w,lI be by callong uS at the fOllOWing "umbe' 957-..2~~_. ThIS pay......"1 ,nllSI be In cash 3"11;1:" 'Lt"t!'C~ ~:e"t1flE'd Cnetk Of 'nvney order and made payab!e to uS at the address natf'd .00\11:1 V Oll ,t'ouoc1 rulole that a SheroWs sale w.lI end your O\'<Mrsh'o of Ih., mortgaqed property and VOU' . t<jht 10 rem a,,, ".t rf 'a.. cont,nue 10 love ,n the pro~nv alter Ihe Sher'Ws sale J laWSUIt could be slillted 10 eVlCI V'" 'uu "d" ll!<l'honal ri<JhlS to he,p p'otKI your ,merest.~ the proller" you HAVE tHE ~IGHT tll SELL tHE ,'",'P(,,~, TO 08TAIN 11.10',(, TO PAY OFF THE \IC"'TG....Cf DEBT, OR TO IW!''IOW \HINEY FRO\' .";O~"f" !. f'jO!r-,:G INSTln T,ON T,) ~AY OF' T''''; nf "I '1'1' MAY HA\f THE 'l'GHT 1\) "ELL C" y;: \'.'Jf:;, ~ti~ pq()p(qr\- .~i 9~F-~~ .\) THE \~\~~.. .... ..\ ~HJ'VEn OH rH~\~..,o;';'>-H; WHO '\\\ .\.>_~, '.,\t :oj~ \'l''!J~rG~Gf ~)t8r P~UVil)fO TH..\T ..\t. :ltf~ ',1 ~'~rANO'NG p.\"\H-'.r'') i..:H^,llilS ..\'\ ., ;~ESA,ND(O~.~l~,~Ht .,.,....l;)P'Rtt'.~~, \ ~:--.~ r,., .\tl ...'''...orl...\T ~.H '''HlHf1t:n\\q. rH( \'O>.:~._>L',: ,H~F ~~\TiS"H) p,..\(' .\' JE.TE~M!"'t~ l' ~ _\\1", \:I~\~\"- " ,..I\~~..T \ll,,~i'~ ,,.. ... ,,'\1 HA\t ". ,'I' '.\vE- T,,,l~; ,)~;,:~ 'i t}"' \ \..~~_ '\ \~ " \ .~.:;' 't ~\" \\';~ i: . r't \)~., , ., . . \ "'. . t . .. ' , i ~ t" ) ~ - f ,\ , ", ~ \' , : h~ '-"\ ;, .....' i NOrtCE OF INTENrtON ro rORECLOSE MOIITGAGE Loan No. 7-11-..96 221296 Arri'"lP[' J & WArTpn _lBO.l VAlley..Rcl ~ry~vi11e, PA 17053-9749 Date of Notice The MORTGAGE held by.~ Firs.t,~1;J.Qnal lhereHlatter \"lIt! il'i or our~l on your property located III Bank of M..1n'svi.lle 426 Water St., New CUntlerland. PA .- +.- -- _.-- -.-.---- IS IN SERIOUS DEFAULT because you have not made 'he monthly payor"'"rs 01 S Ji1.8~ lor the months 01 May __, June ..- - -.. a",/ ..July 5. 1996 and/or because Lale charges and olher charges have also accrued 10 Ihls date In the amount of $71.15 . The total amount now reqUired to cure Ihis default. or ,n olher words, gel caught up In your payments. as of the dale of th.s letter. IS 5 1. 157 .8~.... You may ClI'. rh.s delault within THIR TY '301 OA YS 0/ rhe elate of rh,s let:er. by paying to us the above amOLJ"t 01 S .-L.l57 .81 _, plus any addItIonal monthl, payments ,md fare charge which may fall due dur"'g rhls /JeT/ad Such payment must be made ellher by cash. cash.er's check, certlfoed check or money order, and made at 'the First .National Bank nf ~'"Y""ill.. .1Q.l !.lntTllnS'!. ..M..'Y'""itlA PA I7n<;1 If you do not cure the default Within THIRTY (30) DAYS, we Intend ro exercise our right to accelerate the morrgage paymenrs ThiS means that whatever is OWIng on the original amount borrowed will be considered due ,mmedlately and you may lose the chance to payoff the orogtnal mortgage .n monthly installments. If full payment of Ihe amount of default IS not made within THIRTY (30) DAYS, we also mtend to instruct our attorneys to starr a laWSUit to foreclose your mongaged oroperIY. If the mortgage IS foreclosed your mortgaged property will be sold by rhe She"ff to payoff the mortgage debt. If we refer your case to our attorneys, but you cure the default before they be9,n legal proceedIngs against you. you Will still have to pay the reasonable attorney's fees. actually incurred, up 10 550.00. However, ,f legal proceedings are started against yOU, you will have to pay the reasonable attorney's fees even .f Ihey are over 550.00. Any attorney's fees will be added to whatever you owe us. which may also include our reasonable costs. " you cure tM ~'ault within the thirry day period. you WIll not ~ required to pay attorney's 'ees. We may also sue yOU penonally for the unpaid prinCipal balance and all other sums due under the mortgage. If you have not cured the default wlthon the Ihlrty day perIOd and foreclosure proceedings have begun, you stIli have the right to cure the default and fJ"Vtlnt the ule at any time up to one hou' before the Sheriff's foreclosure sale You may do so by pay"'g thtl rot" Mnount of tM unpaid monthly payments DIllS any lar. or other charges then due. 4S well as the reasonable attonwy'. feu and co.ts connected WIth the foreclosure sale and ptlrform any other reqUIre menu under the mortgage. It is estimated that the e.rltnt date that such a Sheroff's sale could be held would be appro. ,mately 1.Q,.lJ~_, A notice of Ihe date 01 the Shelllf sate Will be Sl!nt to you before the sale. Of course. I'"~ amount net'ded 10 cure the default Will Increase the longer yOU wall You may find out at any time exactly what .t"<,' rPUlJ,r(ll(j p.vm~.,t \'\lIP be by call1f1g u,.1 the followff~q flumber-95.h1l.96.-. __ This paymt!nt "ust be In casr. '''''''e. s ch"ck (e.,"'O'(I e"Kk or money Old., .nd mad. paobl" 10 us at Ih" add.ess stated above "c>" ,hauld "a!.,e '''AI a Sher,lf"s sale "",II ,0<1 your 0"'""''''''0 of the mOllgaqed proplll'ty and your fight to r"""A'" ".\ It ,Ou con,,,,,,,, to '"e .n the PfllP"rtv Afler lhe She..lt's sale. A lawsu.t cou'd he started to ev,CI vou 'ou ha." add.t.""a! .'gt>a to help p'otl'tl v.}\Jr "\t~.',, .., Ihe P'Oll""V vOU HAVE THE RIGHT ro SELL Tf-'t ""l'PE'1TY TO 0BL\I'I, \tONEv TO p>>, \)H T"" \'ORTGAGf Df8T \lR TO BORROW "'ONEY ~RO'.' \""THER Lt....D:'.."~ .l\jSTlTUTlON ~n ,'on (]f; '.,.~ DEBT ~Ou \'A' .IAVE THE RI(j~r TO SEl.l :., ..~.\'..(~rfn '".H ."lA,. :)f;::TY SU8jf,-_~r" "..t:" '~,' .:f\-~.J.~;r !(! :;, Mt,~f4 ,q TRANstr ,'..;: '.\-....l\ ,\- ",c';: \~f rH~ \'~';~.,-~.\L~( DEBT i-1H' ',it ; r~~.. ~. \ "'ht OtJr{,T.\"i~\ ',\":j PA'Y'ME'\JT' >u.\HLf.'J, ,~~. .!!\'~I'lf-,..'.~~-f(-.'.~':'l:OST~~flt,):. ..1i.;:\lt~ H~_\TtH~;';,\'f .\>'orHATTB[ ,. .!!1nr,~,_,'~ ".-, '\~'~t\' 'ql I '.~rGAGE .\i,\ \~- I '\Cf ;!\~ ~'.. ,", 'i\'!~f. Uf\fnf' h~' (.~i .\',\ ~ , ." . "~j,.r to: \.i':- >,,,\',' .;"t ',' '\," ..,~ nEJ:~l'l' .:.r, j,t\. "\'... .i,..t~: ~\ I "', '1 .;;T !~ ... ~ ,j..;,... . !\'J~t . ,\, . .~ ,\ . ,,,' \ ~ t, ,,: It- .\"..' '.,"- ..... 'l'~'" / ACT 91 NOTICE TAKE ACTION TO SAVE YOUA t'iJME FRO:4 fORECLOSURE ..1*8oJllh 01 Pennsylvlfll.'S HOITleownllt' Eme'Olney MGnO.aoeAUls,.nce PfOQlam may oe .bt.lo hltlp you Utt;W lh. 'OlIo.lug IIf)II& ftIII I,od ou' hOw Ihlltff)QI.m ."no more ml()t'mallon taU Ih. Pennsylv..,.. HOUJlnq FlnanceAQency all (800) 341.2.391 ~ notlhCIClon en acI,unlO" de sum. ImpoNlnc... pull ,lee'. su ""IChO. cont'"u.' ,,'v'lndo en su tin. ::;, no cO!TlJMende II f;ontenMk) de ''''1 "nl.h'.luon ob.II\Cj' un" lIadUCClon ,mmeCSlllamen1enam.nO.1t11 IOencl' (PtnnSyl....f\l. HOU1'"V f.n.nce -'Oentlllln tarlJo, al f\u'"fHO mft..,CfonacJO ,,,''" Puedl' .., "8Q1bl1 pa" un pr.,t'l11l1 pol el ploo,am.n,m.dO "Homeownttt" Em...olftCy M011q'Qe .nlltancl Pn>Ql.m" elcual pueOe sa'"a' \u c... del" pe'dMJ' del dl.tKhO.. '....rtm IU h,,)(ilk. AE ~I No ACT 91 NOTICE IMPORTANT: NOnCE OF HOMEOWNERS' IME"GrNC' MORTGAGE AISISUNCE PROGRAM PLEASE REAO fHIS NOflCE. YOU MAY 81111G18LE '011 "NANCIAL ASSlITANCE WtllCtl CAN 8AVI YOUII tlOMI '"0M 'OIlICLOIUIIE AND tlELP YOU MAKE 'UTUIIEIIOIITGAGE PAYMENfI "1296 D.. 1_1'_QF. 10 <"OM An'hAr .1. WArt""tl!'n '1lle First tb.tional Bank of Ma,,"v!NlIle You ml, o. elltib.. 'or flftMClAI .....unCl tlta..... pre..... 'orl':IOI..,. Oft ,OUI' nlCM1t-e' at JOY cOlllt'l.. ..'" 1"- IN......... of th, H.......,..'. a",.".,.c, Mortgag. AISlIgnCI Act Of '113 (Ut, "'Act' YoIoIN'" .."..... fOf ,M"flMY IlltfftPOfllf'Y ....".,.c,d 'OU, IM'_II ..... ItNft cauHCIII, UfCU",,,,MtI ..,ond your contrOl, yOU "ft" ".,onaIIt. prolpec1 01 ,u""'"" ,WI' 1lftCN1.... ..yfMftta, aft..f Jou "'..._.. ........"y ,....,....... ,.t.IItItlftd", lhe hn"I,...ftt. "0..&1"9 'InIM. Apt'CY. ....... 'Iltdlll Of tN' Hotte.. II cOM"'" .....planeuon of your flI"ll. UndIt thl "CI, yOU 'f' antd1e4 to I 1"""'" ...,01 tOftM:tot."" Oft your mono. tor Ihttt, tlOl dIY' 110m me daI. at tnt. HotCI OUftnQ lhall"'" yeN ""'tt '''ano' .nt1 ,ttend I -tac,.to.'ac,- ~ trtltll reor"ent.~ 0I~' tenOtt. Of wdt\ I OItq\ated tOf\""'* c;l1dd cOWl.....~" The puJpoH ..,. tfttl~.nt II to '<<-"PI lO..uta out ;I Ie().IV"'*" QIaft. or to ~ tMM ~~, !'hit rnB't"O mtAt ou'" aft tN ne.t tfWf1w 1)0, ayt II yOU ,tlend aIKI.lo-fK. fftMt'"9"" thtI~. 01 wttflacon'lU'hl' crMtt c~ al)lAC' ~Ihed '" tn., ftOtl(;l. no ~ p'oceedolliQ '" ~ 1Of..-.tutl ml, Ilkl Dlacl 101 tlWty ()OJ cayS an. I.... CSMt 01'" JftMWlQ T.... narr>e. iOdt." and t~ numtlief 01 0411 representatlv. IS LanY 0 Reich at 'nle first National Bank of KllV!:Ville 101 t,inooln St '~ille ~ 17053 717 957-2196 T~~~ 'he ....meisl...."..1l..1, endP"ON""""*' Of 1.1..,..-I'r..t)..,..,..,Cf....~ ..-ncy,,,"~ ~'''I Urban fpJlQJiP. nf ......."V"lttAl't Ib:rri.....1rq 28 Ihrth ~ St ~rri~'rq ~ 17tO\ 1\1 "4-C;Q,,, ...............-~,-~-.-._. 'I ft 0I'il "4CetMIJ lO .,.,..,.. .. t....'.ke....... """............ --......, J ~ qt y.. ~ 'l't)ut "'O"';a94t .. 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THE FIRST NATIONAL BANK OF MARYSVILLE : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PA Plaintiff vs. NO. 1996-5106 CIVIL MORTGAGE FORECLOSURE STEPHEN J WARREN AMBER J WARREN CIVIL ACTION - LAW Defendant/s NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE That the Sheriff's Sale of Real Property (Real Estate) will be held on March 5, 1997 in the CUmberland County Courthouse, Carlisle, Pennsylvania at 10:00 A.M. prevailing local time. THE PROPERTY TO BE SOLD IS delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (See description attached) The location of your property to be sold is: 426 Water Street New CUmberland, PA 17070 The judgment under or pursuant to which your property is being sold is docketed to: 9€ ~::::~ :~~.'!!.. CUmberland County, PA The name(s) of the owner(s) or reputed owner(s) of this property is: Stephen J. and Amber J. Warren A Schedule of Distribution, being a list of the persons being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff will be filed by the Sheriff thirty (30) day. after the sale and di.tribution of the proceeds if someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of CUmberland County, Carlisle, PA (717) 240-6390. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held to be sold or taken to pay the Judgment: You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET FREE LEGAL ADVICE. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association P.O. Box 186 Harrisburg. PA 17108 (800) 692-7375 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of CUmberland County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's sale you may file a petition with the Court of Common Pleas of CUmberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. 3. A petition or petitions raising the legal issues or ~~~~~~ -~~~:~~~~ :~ ~he ~~~~~1i~~ ~~~~or~Fhs must be prese~~Q~ -~ the Court of Common Plea~ of Cumberland County. The petition ~~3t be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, 8uch date must be obtained from the Court Administrator's Office, CUmberland County Courthouse, Carlisle. PA, before presentation of the petition to the Court. Arthur M. Feld Attorney for Plaintiff ALL THAT CERTAIN piece or parcel of land situate in the Borough of New CUmberland, Cumberland County, Pennsylvania, being bounded and described according to a survey made by Gerrit J. Betz. Registered Surveyor, dated November 11, 1978 as follows to wit: BEGINNING a nail on the West side of Water Street at the corner of lands now or formerly of Mary B. Hiller, being house number 424: said point being measured 31.67 feet to the Southwest corner of Water Street and Fourth Avenue; thence along lands now or late of Mary B. Miller South 44 degrees 45 minutes West the distance of 150 feet to a hub on the East side of Walnut Avenue: thence along the said side of Walnut Avenue North 45 degrees 15 minutes West the distance of 17 feet to a hub at the corner of house number 426 and number 428 Water Street: thence through the center line of partition wall between house number 426 and house number 428 Water Street North 44 degrees 45 minutes East the distance of 150 feet to a point on the West side of Water Street; thence along said street South 45 degrees 15 minutes East the distance of 17 feet to a point; the point and place of BEGINNING. BEING known and numbered as No. 426 Water Street. BEING the same premises which the David A. Krulac. single person, by his deed dated June 6, 1991, and recorded in the CUmberland County Recorder of Deeds office, in Deed Book D 35. Page 762, granted and conveyed to Stephen J. Warren and Amber J. Warren, his wife. mortgagors herein. HAVIKG thereon erected a two story fr..e dwelling known as 426 Water Street. New Cuaberland. PA. Tax Parcel No. 2S-24-G813-G56A SE1%tD. taken in execution to be sold ae the property of Stephen J. and ~ber J. Warren. Kortlacors herein under Jude-ent No. 1996-5106. NOTICE Is further liven to all partie. In interest and claiaants. A proposed schedule of distribution of the proceeds of tbe above sale will be filed by the Sheriff of Cuaberland County. 'enn.ylvanla. on June 24. 1997. and that distribution of said proceeds will be aade In accordance with said proposed Ichedula thirty (30) day. after tha date of a.la unless sxcaptions ara (iled thareto within ten (IO) days thereaftar. J SHERIFF'S RETURH - REGULAR CA!:;~: HIJ: t "1;-05106 P CU/I/lOHW~:^,.TH m' PENNSYLVANIA: CUUNTY at' CU/lIU:RLAND FlRS~T NATtUNA'. !lANK /lARYSVILU: VS. WARR~~ _STEPI!J':N~ .1 ET AL , ROBF.IlI 1.. ~ fINK J Sh~riff or D~puty Sh.riff of CU/l8ERLAND County, Pennsylvani., who being duly sworn according to law. .ays, th. within COIIPf.AINT - /lORT FORE was serv.d upon WARREN STEPHEN .1 the defendant, at 1100100 HOURS, on the ~ d.y of Nove~ber 1922 at 426 WATER STREET NEW CU/lBERLAND. PA 17070 . CUll BERLAND . County, P.nnsylv.nia, by handing to HOPE PARKER FRIF.ND a true .nd .ttested copy of the CO/lPLAINT - /lORT fORE . .nd at the .... ti.. dir.cting ~ att.ntion to th. contents th.reof. Sh~riff'e Costel So .new.rsl - ~. .",!,-, Dock.ting 18.00 ~;. ~.,.. ,..' ,- .~.~#! .w "'_..4!.7...-~.." S.rvle. 21.08 .. ,- ..~ ... " Affidavit .00 Surch.rg. 2.00 R. Tho..s 1\11nw. ~h.r111 .~1.~8 ARTHUR FELD 11/08/19% by /.,~~ /I~ 1 '/ - - -- "" ... f') r f~';;/ ,.~q4-..i51J , pu y 5h.rlf{ Sworn .nd eubeeribwd to b~for. .. thls ) t' '" d.y of 'iJ.cw.. L. J 19 t1(.. A.D. ~ . , l. .- Ii ..i(.. '1 ""'(tnono~ary ~. . . .. THE FIRST NATIONAL BANK OF MARYSVILLE : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PA Plaintiff NO. 1996-5106 CIVIL vs. STEPHEN J WARREN AMBER J WARREN MORTGAGE FORECLOSURE CIVIL ACTION - LAW Defendant/s Co ( (f'e I,.."l NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE That the Sheriff's Sale of Real Property (Real Estate) will be held on June 4, 1997 in the Cumberland County Courthouse, Carlisle, Pennsylvania at 10:00 A.M. prevailing local time. THE PROPERTY TO BE SOLD IS delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (See description attached) The location of your property to be sold is: 426 Water Street New CUmberland, PA 17070 The judgment under or pursuant to which your property is being sold is docketed to: 96-S106 CIVIL Cumberland County, PA The name(s) of the owner(s) or reputed OWDer(s) of this property is: Stephen J. and Amber J. Warren A Schedule of Distribution, being a list of the persons being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff will be filed by the Sheriff thirty (30) days after the sale and distribution of the proceeds if someone objects by filing exception. to it within ten (101 day. of the date it i. filed. Information about the Schedule of Distribution MaY be obtained from the Sheriff of the Court of Common Pleas of Cumberland County. Carlisle, PA 1'171 ~.O-')90. '" ~ THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET FREE LEGAL ADVICE. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association P.O. Box 186 Harrisburg, PA 17108 (800) 692-7375 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of CUmberland County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's sale you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of CUmberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, CUmberland County Courthouse, Carlisle, PA, before presentation of the petition to the Court. Arthur M. Feld Attorney for Plaintiff " ~ ALL THAT CERTAIN piece or parcel of land situate in the Borough of New CUmberland, Cumberland County, Pennsylvania, being bounded and described according to a survey made by Gerrit J. Betz, Registered Surveyor, dated November 11, 1978 as follows to wit: BEGINNING a nail on the West side of Water Street at the corner of lands now or formerly of Mary B. Miller, being house number 424: said point being measured 31.67 feet to the Southwest corner of Water Street and Fourth Avenue; thence along lands now or late of Mary B. Miller South 44 degrees 45 minutes West the distance of 150 feet to a hub on the East side of Walnut Avenue; thence along the said side of Walnut Avenue North 45 degrees 15 minutes West the distance of 17 feet to a hub at the corner of house number 426 and number 428 Water Street; thence through the center line of partition wall between house number 426 and house number 428 Water Street North 44 degrees 45 minutes East the distance of 150 feet to a point on the West side of Water Street; thence along said street South 45 degrees 15 minutes East the distance of 17 feet to a point; the point and place of BEGINNING. BEING known and numbered as No. 426 Water Street. BEING the same premises which the David A. Krulac, single person, by his deed dated June 6, 1991, and recorded in the CUmberland County Recorder of Deeds office. in Deed Book D 35, Page 762, granted and conveyed to Stephen J. Warren and Amber J. Warren, his wife, mortgagors herein. HAVIXG thereon erected a two story frame dwelling ~nown aa 426 Water Street. New Cumberland. PA. Tax Parcel No. 25-24-08IJ-Q56A SEIZED. ta~en in execution to be sold aa the property of Stephen J. and Amber J. Warren. Mortgagora herein under Judgment No. 1996-5106. NOTICE is further given to all parties in Interest and clai..nta. A proposed schedule of distribution of the proceeds of the above aale viii be filed by the Sheriff of Cumberland County. Pennsylvania. on June 24. 1997. and that diatribution of aaid proceeds viii be ..de In accordance vlth said propoaed achedule thirty (JO) day. after the date of sale unlesa exceptions are flIed thereto within ten (\0) daya therufter. Plaintiff : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PA NO. 1996-5106 CIVIL THE FIRST NATIONAL BANK OF MARYSVILLE vs. MORTGAGE FORECLOSURE STEPHEN J WARREN AMBER J WARREN CIVIL ACTION - LAW Defendant/s NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO P~iNSYLVAl.lh RL~ OF CIVIL ~ROCEDL~~ 3129.1 TAKE NOTICE That the Sheriff's Sale of Real Property (Real Estate) will be held on June 4, 1997 in the CUmberland County Courthouse. Carlisle, Pennsylvania at 10:00 A.M. prevailing local time. THE PROPERTY TO BE SOLD IS delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property. together with a brief mention of the buildings and any other major improvements erected on the land. (See description attached) The location of your property to be sold is: 426 Water Street New CUmberland, PA 17070 The judgment under or pursuant to which your property is being sold is docketed to: 96-5106 CIVIL CUmberland County. PA The name(s) of the owner(s) or reputed owner(s) of this property is: Stephen J. and Amber J. Warren A Schedule of Distribution, being a list of the persons being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff will be filed br the Sheriff thirty (301 days after the sale and distribution 0 the proceed. if someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the COurt of Common Pleas of CUmberland County, Carlisle, PA (7171 240-6390. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held to be sold or taken to pay the Judgment: You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET FREE LEGAL ADVICE. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association P.O. Box 186 Harrisburg, PA 17108 (800) 692-7375 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's sale you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. 3. A petition or petitions raising the legal issues or ~:?~~= ~~~t:c~~d i~ ~~~ r~~~~~i~g paragraphs ~ust ba ~~a~~~.~~ -~ the Court of Ccmre~n pleas of CUT~rlarn Ccunty. Th~ petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office. Cumberland County Courthouse, Carlisle, PA, before presentation of the petition to the Court. Arthur H. F'eld Attorney for Plaintiff ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, being bounded and described according to a survey made by Gerrit J. Betz, Registered Surveyor, dated November 11, 1978 as follows to wit: BEGINNING a nail on the West side of Water Street at the corner of lands now or formerly of Mary B. Miller, being house number 424: said point being measured 31.67 feet to the Southwest corner of Water Street and Fourth Avenue; thence along lands now or late of Mary B. Miller South 44 degrees 45 minutes West the distance of 150 feet tc a hub on the East side of Walnut Avenue; thence along the said side of Walnut Avenue North 45 degrees 15 minutes West the distance of 17 feet to a hub at the corner of house number 426 and number 428 Water Street; thence through the center line of partition wall between house number 426 and house number 428 Water Street North 44 degrees 45 minutes East the distance of 150 feet to a point on the West side of Water Street; thence along said street South 45 degrees 15 minutes East the distance of 17 feet to a point; the point and place of BEGINNING. BEING known and numbered as No. 426 Water Street. BEING the same premises which the David A. Krulac. single person, by his deed dated June 6, 1991, and recorded in the CUmberland County Recorder of Deeds office. in Deed Book 0 35, Page 762, granted and conveyed to Stephen J. Warren and Amber J. Warren, his wife, mortgagors herein. HAVI~G thereon erected a two story frame dwelling known as 426 Water Street. New Cumberland. PA, Tax Parcel No. 2S-24-0813-oS6A SEIZED. taken in execution to be sold as the property of Stephen J. and Aaber J. Warren. Mortgagors herein under Judgasnt Mo. 1996-5106. NOTICE Is further given t~ all parties In Interest and clalaants. A proposed schedule of distribution of the proceeds of the above sale viII be filed by the Sheriff of Cumberland County. Pennsylvania. on Ju1v "I. 1991, and that distribution of said proceeds viII be aade in accordance with said proposed schedule thirty (30) days after the date of sa 1. unl.ss exceptions are filed ther.to within ten (10) days thereafter. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION vs ( ) CONFESSED JUDGMENT (X) OTHER DEFAULT JUDGMENT MORTGAGE FORECLOSURE No. 96-5106 CIVIL Amount Due S51.721.96 Interest Through March 4, 1998 S 7.471.09 Atty's Comm S5.366.80 Late Charges $ 289.40 Costs Total S64.849.65 THE FIRST NATIONAL BANK OF MARYSVILLE STEPHEN J. WARREN 426 WATER STREET NEW CUMBERLAND PA 17070 AMBER J WARREN 2630 VALLEY ROAD MARYSVILLE, PA 17053-9749 TO THE PROTHONOTARY 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. 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) 426 WATER STREET. NEW CUMBERLAND. PENNSYLVANIA 17070. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the sheriff of County. for debt. interest and costs. as above. directing attachment against the above-named qarnishee(sl for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) 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: iIL,I, ; By' C. \ I.~ ,',,- Arthur M. reId, 1\ttomey for Plaintiff Attorney 1.0. No, 07172 1309 Bridge Street New CUmberl.md. 1'1\ 17070-1116 ('1111 Tl'a. o:Jn ;- C'" .-: - , (:Jr t1" t," 0 , ..,.. '.._1 .. ::..:J ,~ .... .,:- ::1 .. ,....; l:-. . . ~. . - , ;.>.. , t- o '-' C U ob1 -::t 0 ~o- ("'(, In ~l o i "B 8 to - ~ t i -g i t il-g ~ 1l. >L ~ "& ~ 1l.\ -p~ 3 gg8l/3 8~ a- ~ !.Du'w . (t r0 ~ - -.:t _ 7" tn l,.'1 \ 0_ .. ()O - ~ Ql ~ . '4J o tF (0) :- - t-,: a.. c=-; ~~f ~...\.., :r: u.. C-: "1{ ,- 0 C \::J at C",t o. .,.... .. .~- ~~->o f-- ~: :l~ -- "'- ,.... :.) <,;I 0" <.) '- (". ....." tt c ...,~ -- "-+ t__ (,i' \,.;.Jr;;., ". .- .., \._0, <t...: o!C i:, Ct u..; N Ci:' , ~U ..-., .;_l~ t'"' .. ~'-; ... :5 I'. r- U CJ' .;".,,' .... C"o i.~ r ~; ...:1 . ., . ll.'~ C,\ (.,. ;.~~ . l.-' (': . r:- ,_:t ,..... , "oj 1.... .. ").;. ,- :. . .. r- ...:' U cr f) . . ...- . . .- . ,- . THE FIRST NATIONAL BANK OF MARYSVILLE : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PA Plaintiff NO. 1996-5106 CIVIL vs. MORTGAGE FORECLOSURE STEPHEN J WARREN AMBER J WARREN Defendant/s NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 CIVIL ACTION - LAW TAKE NOTICE That t~ Sheriff's Sale of Real property (Real Estate) will be held on HAllCH 4, 1998 in the cumberland County Courthouse. Carlisle, Pennsylvania at 10:00 A.M. prevailing local time. THE PROPERTY TO BE SOLD IS delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (See description attached) The location of your property to be aold is: 426 Water Street New CUmberland, PA 17070 The judgment under or pursuant to which your property is being sold is docketed to: 96-5106 CIVIL CUmberland County, PA The name(s) of the owner (a) or reputed owner (a) of this property is: Stephen J. and Amber J. Warren A Schedule of Distribution. being a list of the persona being cUtled to receive part of the proceeds of the sale r.eeived and to be d1aburaed by the Sheriff will be fUed by the Sheriff thirty (lO) days after the eale and distribution of the proceeds 1f 8QftIeone objecU by filing exeeptiona to it within ten (10) days of the date it ia filed. Infot'SAt1on about the Schedule of Oiatdbution may be obtained frt:llll the Sheriff of the COUrt of ex ~ Ple.s of cumberland County. Carlisle, PA (717) 240-')90. -~_.. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET FREE LEGAL ADVICE. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association P.O. Box 186 Harrisburg, PA 17108 (800) 692-7375 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of CUmberland County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's sale you may file a petition with the Court of Common Pleas of CUmberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of CUmberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired. such date must be obtained from the Court Administrator's Office, CUmberland County Courthouse, Carlisle, PA, before presentation of the petition to the Court. Arthur M. F'eld Attorney for Plaintiff -- (0' ;>: (- ..;J , . ~~"" ;}. . , , It!~ .: ; ...... >' . "-- (' ,:'1 L- C-" '-1 ~.-I l ;. i . ~ .. .... _J C' (1'1 i"";'l .- ,... tt M >, ..:2 ,- ~ C", ~, u' -. C'P ''':''; '';'''l - 1.-\~ - ~\_' , ,- ;'.1 (-" . -" .::) rY ,",' .... fl:' .....,. ;) t." ."...~..- F :t~ . 15 r; '-) 0 ">- r. -.#'~ rr -'l ~*_. "'. \', c..... , . .' . .. , 0'.-. ~ c:: " 0 " ~ .' ( . - .; 1 ~ , - ,- ~ r- , ",' ,) .. I I , , ~ The First National Bank of Marysville -vs- Stephen J. Warren and Amber J. Warren In the Coun of Common Pleas of Cumberland County. Pennsylvania No. 96-5106 Civil Term Michael E. Barrick. Deputy Sherill'who being duly sworn according to law. says on January 9. 1998 at II :34 A.M.E.S:r,. he postcd a copy of Rcal Estate Writ Notice Poster and Description on the property of Stephen J. Warren and Amber J. Warren at 426 Water Street. New Cumberland. Cumberland County. Pennsylvania according to law. Kathy J. Clark. Deputy Sheri IT. who being duly sworn according to law. says on November 24. 1997 at 6:33 o'clock A.M,E.S.T.. she served a copy Real Estate Writ Notice and Description upon one of the within named defendants to wit: Stephen J. Warren by handing to Stephen J, Warren at 426 Water Street. New Cumberland. Cumberland County. Pennsylvania. its contents and at the same time handing to her personally the said true and attested copies of the same. R. Thomas Kline. SherilTwho being duly sworn according to law. says he made diligent search and inquiry lor one of the within nam~-d defendants to wit: Amber J. Warren. but was unable to locate her in his bailiwick. lie therefore deputized the Sheri IT of PeO')' County to serve the within Real Estate Writ Notice Poster and description according to law. Perry County Return: and now JanuaJ'}' 13.1998 ser..ed the within named Amber J. Warren the defendant named he:rein personally at her place of residence in Rye Twp.. Perry County. PA on January 13. 1998 at 6:40 I'!\I, by handing to Amber J. Warren personally I true and attested copy of the: within Writ Notice & IX-scription and made known to her the contents thereor. So answers Ilonald Smith Deputy. R. Thomas Kline. She:riIT. Wh<,l b.:ing duly sworn :K.'Cording to law. says he served the above Real Estate Wril Notice I'oster and l>escription in the following manner: The sheri IT mailed one of the within named defendants Amber J. Warren a notice of the pendency of the action by Certified Mail Return Receipt Reqll\."Sted Deliwr To AddresS<.'C Only to her last known address 2630 Valle}' Road. Marys\iIIe. I'A 17053. The h:ner was maik-d under the date of January 6. 1998 and the return receipt card was returned to the Olliee of the: Sheri IT on January 8. 1998 the return l'e\.'Cipt card signed by Amber J. Warren, R. Thomas Kline. SheriITwh<,. being duly sworn according to law. say's he sen'ed the abow Real Estate Writ Notice I'~er an..! Description in the following manner: The SherilTrnailed a notice of the pen<kncy of the iKtion to (lflI: of the w ithin nam~-d delendants to wit: Stephen J. Warren to his last Imown ildJn:ss 426 Watcr SIm:t. New Cumb.:rland. Pennsylvania. The letter wa.s mailed under the date of January I~. 1998 an..! never relul1l<.-d to Ib.: Sherilrs Office. R, Thomas Kline. Sherilh,h<,. b.:inl: duly sworn OII:cording h' la\\'. says he scn~-d the ah<,.w Real btale Writ NotK'C l\lSt~"r alld 1lv."S\:ripli,," in ~ fllllow ing manner: The: sherill' mailed it Il\>tice 'If~ po:n.k"ll\:) oflhe a.:ti.m hI une or the within nam~-d defendants t.1 "il: Amber J, Warren tu her last lll\l\\tl.lIlJn-ss 2630 V:llk.'} Road. !\Iarysvill...I'ennsyhania. Th.-Ietter \\as mailed ImJer the dat.. ofJ.muary I~. 19911 and ne'~'r n"turned to the Sherin's Olliee R n""lla~ KhlliC. Sherill. "h<,I b.:1~ Jul~ \wom iI\.'Cofllm~ I" IJ". say\. that alkr due and ",;.alll\>tl\'~ h;aJ......"l1 ~I\t:n <I\,'("I'\lInl: h' IJ\\< nl"''>cl the \\'!Ihlll J..-SCrlh..-d J'f\'fl\iso.-s OIl puNIV: \CIlUI: ofl'Uh:n al the l\>ul1lh>u...:. CoIrhsk Cumt,,:rl.anJ l','untv.I\'\\I\"han!a.'>n MiU\:h 4 . . w . lqqll ill :OOl.l.,\h"l " MIS I.;and....w tho: \JIIle tl>r lhv: sum ,'fS I O() ", Alh,"",y Anhur Iddl,>r 1 hv: fiN "'Jtlt>nJll\.lnl.. "t' \tar~", Ilk. It. Slll.'\:~",...'I's and a"i~n, It h..'ln~ the hi~h..-st t>4J and thv: ~ pc,,~ n.-':\,I\\.'\lli'f."'-' ....~ I hi.' IIN ....II1\'llJl nJIII. .... \tm" till.' it' \uv:..s...>r<