HomeMy WebLinkAbout00-00176
I
.. ---
-"".,
I
. ,
.~'
,. ,
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CIVIL DIVISION - LAW
ALTEGRA CREDIT COMPANY,
Plaintiff
)
)
)
) NO. j1'LXO - /70
)
)
)
)
)
~
vs.
ARTHUR L. FRITZ, JR.
Defendant
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 MAYBE ENTERED AGAINST YOU
BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE
COMPLAINT OR FOR ANY OTHER CLAIMS 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.
LAWYER REFERENCE SERVICE
Court Administrator, 4th Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(717)240-6200
Douglas M. mos, Esquire
Attorney for Plaintiff
c
-.,
. ':"--.--~~.--I
..
r
,.
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION - LAW
ALTEGRA CREDIT COMPANY,
Plaintiff
)
)
)
) NO.
)
)
)
)
)
c2 0-00 _;7't G.;,J".et-..
vs.
ARTHUR L. FRITZ, JR.
Defendant
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff AItegra Credit Company ("AItegra") states the following complaint against
Defendant, Arthur L. Fritz, Jr.
I. AItegra is a corporation organized under Pennsylvania law with offices at 116
Allegheny Center, !DC 23-521, First Floor, Pittsburgh, Pennsylvania 15212.
2. Defendant is an adult individual with a residence at 1701 Hummel Avenue, Camp
Hill, Cumberland County, Pennsylvania 17011.
3. On or aboutJanuary 20, 1999, Defendant made, executed and delivered to American
Mortgage Reduction, Inc. (Hereinafter "American") a Balloon Note to pay American EIGHTY-FIVE
THOUSAND AND 00/100 DOLLARS ($85,000.00) together with interest at the rate set forth
therein (the "Note"). A true and correct copy of the Note is attached hereto, made a part hereof, and
marked as Exhibit A.
4. On or about January 20, 1999, Defendant made, executed and delivered to American
a mortgage upon the real property located at 1701 Hummel A venue, Camp Hill, Cumberland County,
J
,
, ~
^ "
.,~
< '.
Pennsylvania, 11011 (tlte "Mortgage") as security for payment of all sums due under the Note. The
Mortgage is recorded in the Office of the Recorder of Deeds in and for Cumberland County
Pennsylvania in mortgage book volume 1523, page 892 etc. A true and correct copy of the Mortgage
is attached hereto, made a part hereof, and marked as Exhibit B.
5. The Mortgage covers the property more fully described and attached as Exhibit A on
page 901 of the Mortgage.
6. On or about January 20, 1999, American assigned the Mortgage together with the
Note and all its right, title and monies due and to grow due thereon to Altegra pursuant to an
Assignment of Mortgage (the "Assignment"). A true and correct copy of the Assignment is attached
hereto, made a part hereof, and marked as Exhibit C.
7. Pursuant to the Note, Defendant is required to make mortgage payments of principal
and interest in the amount of SEVEN HUNDRED THIRTY AND 281100 DOLLARS ($730.28) on
the 25th day of each month, beginning on February 25, 1999 and continuing each successive month
thereafter until January 25, 2014, the Maturity Date, upon which the final amount of SIXTY-NINE
THOUSAND SIX HUNDRED SIXTY-SIX AND 63/100 DOLLARS ($69,666.63).
8. Defendant has defaulted on his obligation to make timely mortgage payments to
Altegra by failing to make mortgage payments due for May of 1999 through October of 1999.
9. Under the Note and Mortgage, upon Defendant's failure to make mortgage payments
when due, Altegra is entitled to declare all the sums secured by the Note and Mortgage due and
payable and foreclose upon the Mortgage.
10. Altegrahas complied with the notice provisions Act 6, 41 P.S. ~ 101 et. seq. and Act
91,35 P.S. ~ 1680.401(c) et seq. A true and correct copy of the notice sent to Defendant pursuant
2
,
,
--"-"
.~i
t <.
to Act 6 and Acf9I is a'ltached hereto, made a part hereof, and marked, collectively, as Exhibit D.
11. Altegra has declared all sums secured by the Note and Mortgage due and payable.
12. As of May 13, 1999, Defendant is indebted to Altegra under the Note and Mortgage
in the amount of NINETY-FOUR THOUSAND TWO HUNDRED NINETY -EIGHT AND 26/100
DOLLARS ($94,298.26) which is comprised of the following amounts:
Principal
$ 84,880.07
Accrued Interest as of
November 15, 1999
$ 4,381.68
Late Charges
$
36.51
Attorney's Fees & Costs
$ 4.500.00
REAL DEBT
$ 94,298.26
plus interest accruing from and after November 15, 1999 at the per diem rate of $22.98.
13. Under the Note and Mortgage, Defendant is required to pay all the costs and
expenses, including reasonable attorneys fees, that Altegra incurs in exercising its right to
foreclosure, which Altegra anticipates in the amount of FOUR THOUSAND FIVE HUNDRED
AND 00/100 Dollars ($4,500.00).
WHEREOF, Altegra demands judgment in mortgage foreclosure against Defendant in the
amount of NINETY-FOUR THOUSAND TWO HUNDRED NINETY-EIGHT AND 26/100
DOLLARS ($94,298.26) (comprised ofreal debt in the amount of EIGHTY-NINE THOUSAND
TWO HUNDRED NINETY -EIGHT AND 26/1 00 ($89,298.26) and anticipated forecIosure expenses
in the amount of FOUR THOUSAND FIVE HUNDRED AND 00/1 00 Dollars ($4,500.00)), plus
interest from and after November 15, 1999 at the per diem rate of$22.98 and costs of suit, together
3
" ~',I
with foreclosure'and sale ofthe mortgaged property.
Date:
,,--,'
,,' -I "",_~
.
DOUGLAS M. MARINOS & ASSOCIATES P.C.
I~ /?x) Aer
;t
BY:
Doug as M. Mari , Esquire
Attorney J.D. 53 04
101 N. Cedar Crest Blvd.
Allentown, PA 18104
(610) 434-0504
4
<
~- ~,,-
~,'":'<r ,--
.
Verification
CRYSTAL ZINK states that she is a foreclosure specialist employed by AItegra Credit
t
Company, Plaintiff herein, that she is authorized to make this Verification on behalf of Plaintiff,
and that the facts set forth in the foregoing pleading are true and correct to the best of her
knowledge, information and belief. The undersigned acknowledges and understands that the
statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn
falsifications to authorities.
~ipt
CRY: TAL ZIN
-
L
.;.
(
-'....'
BALLOON NOTE
(Fixed Rate)
THIS LOAN IS PAYABLE IN FULL AT MATURITY. YOU MUST R!'PAY THE \!:NTIRE
PRINCiPAL BALANCE OF THE LOAN ANO UNPAIO INTEREST THEN DUE. THE
LENDER IS UNDER NO OBLIGATION TO REFINANCE THE LOAN AT THAT TIME. YOU
WILL, THEREFORE, BE REQUIREO TO MAKE PAYMENT OUT OF OTHER ASSETS
THAT YOU MAY OWN, OR YOU WILL HAVE TO FIND A LENDER, WHICH MAY BE THE
LENOER THAT YOU HAVE THIS LOAN WITH, WILLING TO LEND YOU THE MONEY. IF
YOU REFINANCE THIS LOAN AT MATURITY, YOU MAY HAVE TO PAY SOME OR ALL
OF THE CLOSING COSTS NORMALLY ASSOCIATED WITH A NEW LOAN EVEN IF YOU
OBTAIN REFINANCING FROM THE SAME LENDER.
Januarv 20th. 1999
CAMPHILL. PI'. 17011
1701 HUMMEL AVENUE. CAMPHILL. PI'. 17011
IPrQpalty Addranl
1. BORROWER'S PROMISE TO PAY
In return for a loan thai I have received, I promise to pay U.S. $85,000.00 (this amount is called
"prine,lpal"), plus Interest, 10 the order of the Lender. The lender Is AMERICAN MORTGAGE
REDUCTION. INC.. t understand that the Lender may transfer this Note. The Lender or anyone who takes
this Nola by transfer and who Is entitled 10 receive payments under this NOla is called the "Nole Holder".
2. INTEREST
Interest will be charged on unpaid principal unlil the luU amount of principal has been paid. I will pay
interest at a yearly rate of 9.75%.
The interest fale required by this Section 2 is the rale r will pay both before and after any defeult described
In Section 6(8) of this Note.
3. PAYMENTS
(A) Time and Place 01 Payments
I will pay principal and interest by making payments every month.
I will make my monthly payments on the 25th day 01 each month beginning on February 25th, 1999.
I will make these payments every month until I have paid all 01 the principal and interest and any other charges
described below that I may owe under this Note. My monthly payments will be applied to Interest before
prlncipal. It, on Januarv 25th. 2014, I still owe amounts under this Note, l will pay those amounts 'In lull
on that date. which is celled the "maturity dale."
I will make my monthly payments at 100 PAINTERS MILL ROAD, SUITE 800, OWINGS
MILLS. Me 21117 or at a different place II reqUired" by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment, exccept lor the final payment, will be in the amount 01 U.S. $730,28. Assuming
all scheduled payments of principal and interest are made on their due dates, the
final payment will be U.S. $69.666.63.
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of princIpal at any time before they are dU,e. A payment of principal only
Is known as a "prepayment". When I meke a prepayment, I will tell the Nole Holder In writing that I am doing
'0.
I may make a full prepayment or partial prepayments without paying any prepayment charge. The Note
Holdef w\ll use allot m,/ prepayments to reduce the amount of principal that I owe under ttlis Note. II I make a
partial prepayment, there will be no changes In the due dates or amounts of my monthly payments unless the
Note Holder agrees in writing to thOSe changes.
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, Is Ilnally interpreted so that the
Interest or other loan charges collected or to be collected In connecllon with this loan exceed the permitted
limits, then: (I) any such loan charge shall be reduced by the amount necessary to reduce the charge to the
permitted Iimll; and (ii) any sums already collected from me which exceeded permitted limits will be rellJnded to
me. The Note Holder may choose 10 make this refund by reducing the principal I owe under this Note or by
making a direct payment to me. If a refund reduces princIpal, the reduction will be treated as a partial
prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
U a Note Hatdee nas 1\01 ~eceived the lull amount 01 any monthly payment by the end 01 Fifteen calendar
days after Ihe date it is due, I will pay a lale charge to the Nole Holder. The amount 01 the charge will be 5%
of my overdue payment 01 principal and interest. I will pay this late charge pfomptly but only once on each late
paymenl.
(B) Default
If I do not pay the lull amount of each monthly payment on the date it Is due. I will be in default.
(C) Notice of Default
If I am In defaull, the Note Holder may send me a written notice telling me that If I do not pay the overdue
amount by a certain date, the Nole Holder may require me to pay Immediately the lull amount of principal which
has not been paid and all the interest that I owe on that amount. That date must be at least 30 days aller the
date on which the notice Is delivered or mailed 10 me.
(D) No Waiver By Note Holder
Even If, at a time when I am In delault, the Nole Holder does not require me 10 pay Immediately In full as
described above, the Note Holder will still have the right to do sO II t am in default at a later time.
MULTISTATE BALLOON FIXED RATE NOTE.Slngl.. Farnlly"FNMA UNIFORM INSTRUMENT (REV.) Form 3260 3/87
'f-f1-LF
_c "
,-,
~.
.t
..' ':
,
'-'
(E) Payment of Note Holder's Costs and Expenses
If the Nole Holder has required me to pey immediately in full as descrlbad above, Iha Note Holder will have
the right to be paid back by me lor all 01 Its costs and expenses in enforcing this Note to the extent not
prohibited by applicable law. These expenses Include, lor example, reasonable allorneys' lees. ~
t. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note wlll
be given by delivering .it or by mailing II by lirst class mail to me at the Property Address above or at a dillerent
address il I give the Note Holder a notice 01 my dlflerent address.
My nolice that must be given to the Note Holder under this Nole will be given by mailing it by first class mail
10 the Note Holder at the address staled In Section 3(A) above or at a different address if I am given a notice of
that different address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally Obligated to keep all of the
promises made In the Note, Including the promise 10 pay the lull amount owed. Any person who Is a guarantor,
sur9ty or endorser 01 this Note Is also obligated to do these things. Any person who lakes over these
obligations, Including the obligations of a guarantor surety or endorser of this Note, Is also obligated 10 keep all
01 the promises made in this Note. The Note Holder may enlorce Its rights under this Note against each person
individually or against all of us together. This means thai anyone of us may be required to pay all of the
amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Nole waive the rights of presentment and notice of
dishonor. ~Presentment" means the right to require the Note Holder to demand payment 01 amounts due.
~Notice of dishonor~ means the right to require the Note Holder 10 give notice to other persons that amounts
due ha....a not been paId.
10. UNIFORM SECURED NOTE
This Note Is a uniform Instrument with limited variations in soma jurisdictions. In addilion 10 the protections
given to the Nole Holder under Ihis Note, a Mortgage, Deed of Trust or Security Deed ("the Security
InstrUment"), dated the same date as this Note, protects the Note Holdel' from possible losses which mlgh\
result il I do not keep the promises which I make in this Note. That Security Instrument described how and
under what conditions I may be required to make immediate payment in lull of all amounts I owe under this Nole.
Some of those conditions are described as lollows:
Transfer of the Property or a Beneficlal tnterest in Borrower. II all Of any part of the
Property or any Interest in II Is sold or transferred (or il a beneficial interest in Borrower is sold or transferred
and Borrower Is not a natural person) without Lender's prior written consent, Lender may, at its option, require
Immediate payment In full 01 all sums secured by this Security Instrument. However, this option shall not be
exercised by Lender Is exercise is prohibited by federal law as 01 the date of tnis Security Instrument.
II Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a
period 01 not less Ihan 30 days Irom the date the notice is delivered or mailed within which Borrower must pay
all sums secured by this Security Instrument. II Borrower fal!s ~o pay these sums prior to the expiration of this
period. Lender may Invoke any remedies permitted by the Secudty Instrument witttout lurther notice or demand on
the Borrower.
WITNESS THE HAND(S) AND SEAl(S) OF THE UNDERSIGNED.
sal)
OF:
A CREDIT COMPANY
HAR Y KOROTKr
PRESIDENT
AMERICAN MORTGAGE REDUCTION, INC.
(Seal)
.Borrower
:'..,,:w.._:.:.:
(Seal)
-Borrower
(Seal)
-Borrower
[Sign Original Only)
MULTlSTATE BALLOON FIXEO RATE NOTe'Sl~olo' Famlly.FNMA UNIFORM INSTRUMENT (fIEV.) Fotm 3260 3/$7
~.
(
(
,/,
l~ .
Mail to:
VALLEY TITLE COMPANY
66 PAINTERS MILL ROAD, STE. 200
OWINGS MILLS, MARYLANO 21117
Parcel 1.0.
Tille Insurer:
File No.:
LAWYERS TITLE INSURANCE
VT-58812
[Space Above This Line for Recording Information]
MORTGAGE
WORDS USED OFTEN IN THIS DOCUMENT
(A) "Security Instrument." This Mortgage, which Is dated January 20th, 1999 will be called the "Security
Agreement."
(B) "Bo"owerts)," ARTHUR L. FRITZ, JR.. ros;d;'9 0' 1701 HUMMEL AVENUE, CAMPHILL, PA
17011 sometimes will be called "Borrower" and sometimes simply "I" or "me.W
(C) "Lender." AMERICAN MORTGAGE REDUCTION, INC. will be called "Lender." Lender is a
corporatlon or association which exists under the laws 01 the State of MARYLAND. Lender's address is 100
PAINTERS MILL ROAD, SUITE 800, OWINGS MILLS, MD 21117.
J
(D) "Note: The Note signed by Borrower and dated January 20th, 1999 wlU be called ihe "Note." The
N~lfl shows thai t owe Lender Eighty-Five Thousand and PO/l00 Dollars (U.S." $85,000.00) plus interest.
I have promised 10 pay this debt In monthly payments and to pay the debt In lull by January 25th, 2014.
(E) "Property." The properly thai Is described below In the secllon IItled "Description 01 the Property" wl1l be
calle.d the Property, which is Iocaled In CUMBERLAND COUNTY, PENNSYLVANIA.
(F) "Sums secured." The amounts described below in the section tilled "Borrowers Transfer to Lender of Rights
In the Property" sometimes will ,pe called the "sums secured."
BORROWERS TRANSFER TO LENDER OF RIGHTS IN THE PROPERTY
I mortgaQ;e, grant end convey with the Property described below to Lender, subject to the terms of this Security Instrument. This
Securityfi'nstrument secures to Lender those rights that are stated In this Security Instrument, and also those rights that the law
gives to lenders who hold mortgages on real property. I am giving Lender these rights 10 protect Lender from possible losses that
might result if I fall to:
(lA) Pay all the amounts that I owe Lender as stated in the Nole. with interest, and aU renewals, extensions and
modiricatlons to the Nole;
(B) Pay with interest, any amounts that Lender spends under Paragraphs 2 and 7 of this Security Instrument 10 protect the
value of the Property and Lender's rights In the Property; and
(C) Keep all of my other promises and agreements under this Security Instrument, and the Note.
DESCRIPTION OF THE PROPERTY
I give Lender rights in the Property described In (A) through (J) below: '
(A) The Property located at 1701 HUMMEL AVENUE. CAMPHILL. PA 17011. The legal description of the
Property Is more fully described In the Schedule -A" Legal Description attached hereto and made a part hereof;
(B) All buildings and other improvements that are located on the Property described In subparagraph (A) Ollhis section;
(C) All rights In other property Ihat t have as owner of the Property described In subparagraph (A) of this section. These
righls are known as "easements, rights and appurtenances attached 10 the property;"
(0) All rents or royallles from the Property described in subparagraph (AJ 01 this section;
(E) All minerai, oil, and gas rights and profits, water rights and stock that are part
RLr
~C~~
".
,
1:<0
~
0;
,,:.,'
,(
\- '
subparagraph (A) of Ihls section;
,
"'(F) All rights"thal I have In Ille land which lies In the streets or'roads in Ironl 01, or next to, the Properly described In
"
subpanlgraph (A) 01 this section;
(G) All fixtures that are now 0(' in the luIure will be on the Property described in subparagraphs (AI and (B) of this
section; along with but not limited 10 stoves, refrigerators, washers, dryers, dishWater, ovens, air conditioning units:
(H) All of the rights and property described in subparagraphs (B) through (G) 01 Ihls section thai I acquire in the future;
(I) All replacements 01, or addlUons to, Ihe Properly described In subparagraphs (8) through (H) 01 this section; and
(J) All 01 the amounts Ihal I pay 10 lender under Paragraph 2 below.
BORROWER'S RIGHT TO MORTGAGE THE PROPERTY AND BORROWER'S
OBLIGATION TO DEFEND OWNERSHIP OF THE PROPERTY
I promis~ that: (A) \ lawfully own the PfOpertYj (6) \ have the fight to mortgage, gfant and convey the PropeTty to lender; and Ie)
Ihere are no outstanding claims or charges against the Property.
I give a general warranty of litle to Lender, This means that I will be fully respanslble for any lasses which Lender sullers because
someone other than mysell has some '01 the rights In the Property which I premise that I have. 'promise that , will defend my
'Ownership '01 Ihe Property against any claims of such rights.
PLAIN LANGUAGE SECURITY INSTRUMENT
This security inslrument conlains uniform pramlses and agreements that are used In real praperty security agreements all aver the
cauntry. It cantalns nan-uniform pramises and agreemenls that vary ta a Umited extent, In differsnt parts 'Of the country. My
pramises and agreemenls are slated in "plain Ianguaga."
I pramls'e and agree with Lender as lollows:
I
1. BORROWER'S PROMISE TO PAY
I will pn ta lender, 'On time, principal and Interest due 'under the Note and any prepayment and late charges due under the Note.
2. MONTHLY PAYMENTS FOR TAXES AND INSURANCE
t . .
(A) Barrawer's Obllgatlans
] will pay to lender all amaunts necessary ta pay lar taxes, assessments, leasehald payments 'Or graund rents (If any), and hazard
insurance an Ihe Praperty and martgage Insurance (If any). I will pay thase .amaunts 1'0 Lender unless Lender tells me, In writing,
that I da nat have ta da sa, Dr unless the law requires 'Otherwise. I will make thase payments an the same day that my monthly
paymen,ts 'Of principal and interest are due under Ihe Note. Each of my payments under this Paragraph 2 will be the sum 'Of the
following:.
Ii
(i) One-twelfth 'Of the esllmated yearly laxes and assessments an the Praperty which under the law may be
superlar to this Securlly Instrument; plus
)iI) One.twelfth allhe estimated yearlY leasehold payments or ground rents on the Praperty, if any; plus
,PIIt One-twelfth 'Of the estimated yearly premium lar hazard insurance cavering the Property (If required): plus
J.l") One-lweUth 'Of the esUmated yearlY premIum for martgage Insurance (if any); plus
j:4 One-twellth 'Of the estimated yearly premium for flaod Insurance (if required),
In accardance with applicable Jaw, lender will estimate fram time ta time my yearly taxes, assessments, leasehold payments 'Or
graund rents and insurance premiums. Lender will use existing assessmenls and bills and reasonable estimates of future
assessments and bills. lender may, al any time, collect and hald Ilems under Paragraph 2 in an aggregate amaunt not t'O exceed
the maximum amaunlthal may be required f'Or Barrawer's Account under the Real Estate Seltlement Procedures Act 01 1974, 12
use 2601 et seq., and implementing regulatfans, 24 CFR Part 3500, as they may be amended from time ta time. ("RESPA"l, except
thai I wlll pay Lender an additional sum equal 1'0 .one.sixth 'Of the aggregate amount 'Of yearly payments under this Paragraph 2 'Or a
losser amauntll required by applicable law. This sum Is known as the "reserve" or "cushlan," and Is permitted by AESPA f'Or
unanticipated disbursements Dr disbursements befare my payments are available In the accounl. These amounts that I pay ta
Lender far lhose items under Paragraph 2 will be called the "funds." These funds may be commingled with the funds of the lender
unless the law requires 'Otherwise. Unless an agreement Is made 'Or applicable law requires interest ta be paid, Lender shall not be
required ta PIlY Barrawer any interest 'Or earnings on the Funds. lender may require Borrower 10 pay a one-lime charge lar an
Independent real estale tax reparting service used by Lender in connection with the Jaan, unless applicable law pravldes 'Otherwise.
,'I'
(B) Lender's Obligations
Lender will use the funds ta pay Ihe above listed items. lender wlll give 10 me, wlthaut charge, an annual accounting 'Of the funds.
The accaunting must shaw all additions ta and deductians fram the Funds and the reasan lor each deduction.
i{i /\ L F
(e) Adjustments .n -
~~
'"
-
l
,;"
,-
\
II Lende(r; estimales ~re 100 high or If taxes and insurance rates go dowl'\, the amounts that 1 pay under this ~aragraph !z will be
too Iatgl II this happens at a time when I am keeping all of my promises and agreements made in this Security Insttument, I will
have trie right to have the excess amount either promptly repaid to me as a direct refund or credited to my future monthly
payments of funds. There will be excess amounts 11, at any time, the sum of (i) the amounts 01 funds which Lender is holding or
keeping, plus (il) the amount of' the monthly payments of lunds which I stili must pay between that time and the due dates 01 these
items is greater than the amount necassary to pay the above listed Items when they are due. If the Funds exceed the amounts
permilled to be held by RESPA, Lender shall deal with excess funds as required by AESPA.
II, when payments of these Items is due, lender has not received enough Funds to make those payments, I wilt pay to Lender
whatever addlllonal. amount is necessary to pay these Items In full, I must pay that additional amount in one or more payments as
Lender may require, and permitted by AESPA,
3. APPLICATION OF BORROWER'S PAYMENTS
Unless the Jaw requires otherwise, Lender will apply each of my payments under the Note and under Paragraphs 1 and 2 above in
the following order and lor the lollowlng purposes:
First, 10 pay any prepayment charges due under the Note:
Next, to pay la,e charges under the Note;
Next, to pay the amounts due to Lender under Paragraph 2 above or other advances;
Naxt, to pay Interesl due; and
Last, 10 pay principal due.
4. BORROWER'S OBLIGATION TO PAY CHARGES, ASSESSMENTS AND CLAIMS
I will pay all taxes, assessments, charges, flnes and impositions allrlbutable to the Property and that may be superior to this
Securlly Agreement. I will also make payments due under any lease il I am a tenant on the Property and I will pay ground rents (if
any) due on the Property. I will do this either by making the payments to Lender that are described in Paragraph 2 above or, il I
am not ~equired to make payments under Paragraph 2, by making the payments on time to the person owed them. (In this Security
Instrument, the word "person" means any person, organlzallon, governmental authority or other party.) If I make direct payments,
then pr~mptly alter making any of those payments, I will give Lender a receipt which shows that I have'done so. If I make
paymen(s to Lender under Paragraph 2, I will give Lender all notices or bllls that I receive lor the amounts due' under this Paragraph
4.
f":
Any claim, demand or charge that is made against the Property because an obligation has not been fulfilled is known as a "lien.~ I
will promptlv payor satisfy aU liens against the Property lhat may be superior to this Sacurity Instrument However, tt\is Security
Instrumant does not require me to satisfy a superior lien if: (A) I agree, in wriling, 10 pay the obligation which gave rise to the
superior lien, and Lendar approves the way In which I agree to pay that obligation; or (B) In good faith, I argue or defend against
lhe superior lien in a lawsuit so that, during the lawsuit, the superior lien may not be enlorced and no part of the Property must be
given up; or (C) I secure from the holder of that other lien an agreement, approved in writing by Lender, that the lien of this
Security Instrument Is superior to the lien held by that person. If Lender determines that any part of the Property Is subject to a
superior lien, Lender may give Borrower a notice identifying the superior lien. Borrower shall payor satisfy the superior lien or take
one or fIlore 01 the actions set forth above within 10 days from the giving 01 notice.
5. BORROWER'S OBLIGATION TO MAINTAIN HAZARD INSURANCE
I will obtain hazard Insurance to cover all buildings and other improvements that are now, or in the future will be localed on the
Property, The Insurance must cover loss or damage caused by fire, hazards normally covered by Mextended coverage" hazard
Insurance policies, and other hazards, including floods or flooding, lor which lend!''' or slate or federal government requires
coverage. The Insurance must be In the amounts and for the periods 01 Ume required by LendElr or government agency. I may
choose the Insurance company, but my choice is subject to Lender's approval. Lender may nol refuse to approve my choice
unless the refusal is reasonable. If I do not maintain coverage as described above, Lender may, at Lender's option, obtain
coverage to protect Lender's rights in accordance with this paragraph and paragraph 7. If the property is determined to be located
in a flood ione that requires flood Insurance, as designated by the Federal Emergency Management Agency or another agency that
has the authority to make such determination, I will obtain flood insurance coverage for the property.
All 01 the insurance policies and renewals of those policies must Include what is known as a "Standard Mortgagee" clause to
protect Lender. The form of all policies and renewals must be acceptable to Lender. Lender will have the right to hold the policies
and renewals. II Lender requires, I will promptly give Lender all receipts .of paid premiums and renewal notices that I receive. If
there Is a loss or damage to the Property, I will promptly notify the insurance company and Lender. If I do not promptly prove to
the insurance company that the loss or damage occurred, then Lender may do so.
The amount paid by the Insurance company Is called "proceeds,M I authori:z;e the Lender to sellle any claims and collect the
proceeds on my behalf and use them to reduce the amount I owe to Lender under the Note and under this Security Instrument
(whether or nol repaIrs have been made by me), or lender may release the proceeds to me for use In the repair or restoration 01
the damaged Property.
If I abandon the Properly, or if, I do not answer, within 30 days, a notice from Lender staling that the insurance company has
of/ered to settle a claim, Lender may collecl lhe prq~et;!ds. Lender may us~ the proceeds to repair or restore the Property or to
pay the sums secured. The SO.day period will begin when the notice Is given.
Rlf
f 0/,'-//
J"
L
-;,-
"
r'
\~
II any proceeds are used to replace the amount of principal which I owe to Lender under the NOle, that use will not delay the due
date or ;change the 'amount 01 any 01 my monthly payments under the. Note and under Paragraphs 1 and! above. l'iowever,
Lender :~nd I may agree in writing to those delays or changes.
I'
If Lender acquires the Property under Paragraph 25 below, all 01 my rights in Ihe Insurance pOlicies will belong to Lender. Also. all
01 my rights In any proceeds which are paid because 01 damage thai occurred before the Property is acquired by Lender or sold
will belong to Lender. However, Lender's-rights in those proceeds will not be greater than the sums secured Immediately belore the
Property is acquired by Lender or sold.
In the event that Borrower fails to maintain hazard insurance or flood insurance as outlined in this Paragraph 5, or has the policy
cancelled, t~en and in that event, Lender may obtain the necessary insurance. Borrower will pay to Lender a service fee no less
than filly dollars ($50.00) to cover the costs and administration 01 said insurance, and wlll be responsible for the payment 01 these
fees and all premiums on said insurance.
6. BORROWER'S OBLIGATION TO MAINTAIN THE PROPERTY AND TO FULFILL ANY LEASE
OBLIGATIONS
I will keep the Property in good repair. I will not destroy, damage or substantially change the Property, and I will not allow the
Property 10 deteriorate. If I do not own but am a tenant on the property, I willlulfill my obllgallons under any lease. I also agree
that, II I acquire the fee IiUe to the Property, my lease Interest and the ree IiIIe will not merger unless Lender agrees to the merger
in writing.
7. LENDER'S RIGHT TO PROTECT ITS RIGHTS IN THE ~ROPERTY: MORTGAGE INSURANCE
If: (A) I do not keep my promises and agreements made In this Security Instrument, or (B) someone, including me, begins a legal
proceeding that'may significantly aUect Lender's rights In the Property (such as a legal proceedIng In bankruptcy, In probate, for
condemnation or 10 enforce Jaws or regulations), Lender may do and pay for whatever is necessary to protect the value of the
Property and Lender's righls In the Property. Lender's actions may Include appearing in court, paying reasonable attorney's fees
and entering on the Property to make repairs. Lender must give me notice before Lender may take any of these actions. Although
Lender may take action under this Paragraph 7, Lender does not have to do so.
I will p~y to Lender any amounts, with interest, which Lender spends under this Paragraph 7. I will pay those amounts to Lender
when Lender sends me a notice requesl!ng that I do so. I will also pay interest on those amounts at the Note rate. Interest on
each aVlount wlll begin on the date that the amounl Is spent by Lender. However, Lender and I may agree In writing 10 terms of
payment thai are different Irom those In this paragraph. This Security Instrument will protect Lender in case I do not keep this
promise to pay those amounts with Interest.
If Lender required mOrtgage insurance as a condition or making the loan that I promise to pay under the Note, I will pay the
premiums for that mortgage insurance. I will pay the premiums until the requirement for mOrtgage insurance ends according to my
wrlnen agreement with Lender or according to law. Lender may require me to pay the premiums in the manner described in
Paragraph 2 above.
B. LENDER'S RIGHT TO INSPECT THE PROPERTY
I
Lender, -~nd others authorized by Lender, may enter on and Inspect the Property. They must do so in a reasonable manner and at
reasonabie times, Berore or al the time an inspection Is made, Lender must give me notice slating a reasonable purpose for the
Inspection.
9. AGREEMENTS ABOUT CONDEMNATION OF THE PROPERTY
A taking of property by any governmental authority by eminent domain is known as "condemnaUon,ft I give to Lender my right: (A)
10 proceeds of aU awards or claims lor damages resulting from condemnation or other governmental taking of the property; and (B)
to proceeds from a sale 01 the Property that is made to avoid condemnation. All of those proceeds will be paid to Lender.
If all of the Property is taken, the proceeds will be used to reduce the sums secured. If any 01 the proceeds remain after the
amount that I owe. to Lender has been paid In full, the remaining proceeds will be paid to me. Unless Lender and I agree otherwise
in writing, iI-only a part of the Property is taken" the amount that I owe to Lender will be r~duced only by the amOllnt of proceeds
multiplied by the following fracUon: (A) the total amount of the sums secured immedlalely belore the taking, divided by (B) the fair
market value 01 the Property immediately belore the taking. The remainder Qf the proceeds will be paid to me.
If I abandon the Property. or ir I do not answer, within 30 days, a notice from the Lender stating that a governmental authority has
offered to make a payment or to settle a claim fOr damages, Lender has the authority to collect the proceeds. Lender may then
use the proceeds to repair or restOre the Property or 10 reduce the sums secured. The 3D-day period will begin when the notice is
given.
11 any proceeds are used (0 reduce Ihe amount of principal which I owe the Lender under the Note. that use will not delay the due
date or change the amount of any of my monthly payments under the Nole and under Paragraphs 1 and 2 above. However, the
Lender and I may agree in writing to those delays or changes.
10. CONTINUATION OF BORROWER'S OBLIGATIONS AND OF LENDER'S RIGHTS
(A) Borrower's Obligations
(I{l~
(1
.
I
.&.l ~,
L
/'
\
Lender i)lay allow a person who lakes over my rights and obligations to dt!lay or to change the amount of the monthly.payments of
.<" .
principa,~and Interest due under the Nola or under this Security Insfrumen!. Even II Lender does this, however, thai person and I
will bolo' still be fully obligated under the Nole and under this Security Instrument. Lender may allow those delays or changes lor a
person who takes over my rights and obligations, even il Lender is requested not to do so. Lender will not be required 10 bring a
lawsuit against such a person for nol lulliJli~g the obllgaUon' 01 the NOla or the Security Instrument.
(Bl Lender's R;ights
Even if Lender ~oes not exercise or enforce any right 01 Lender under this Security Instrument or under the law, Lender will slill
have all of. those rights and may exercise and enforce them in the future. Extension of time for payment or modification of
am~it~Uo,n of the sums secured by this Security Instrument granted by Lender to any successor In Inter~st 01 Borrower shall nol
operate to release the liability of the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exerCising
any right or remedy shall nol be a waiver of or preclude the exercise 01 any right or remedy. Even" Lender obtains insurance,
pays taxes, or pays other claims, charges or liens against the Property, Lender will have the right under Paragraph 19.below to
demand that I make Immediate payment In full 01 the amounl that I owe to Lender under the Note and this Security Instrument.
11. OBLIGATIONS OF BORROWER AND OF PERSONS TAKING OVER BORROWER'S RIGHTS OF
OBLIGATIONS
,
My person who takes over my rights or obligations under this Security Instrument will have all of my rights and will be o6ligated to
keep all 01 my promises and agreements made In this Security Instrument. Similarly, any person who takes over Lender's rights or
obligations under this Security Instrument will have all of Lender's rights and will be obligated to keep all of Lender's agreements
made in this Security Instrument.
II more than one person signs this Security Instrument as Borrower, each of us Is lully obligated to keep all 01 Borrower's promises
and obligations contained In this Security Instrument. Lender may enforce Lender's rights under this Security Instrument against
each of us individually or agarnst all of us together. m This means that anyone of us may be required to pay all sums ~ecured.
However, if one of us does not sign the Note: (A) that person is signing this Instrument only to gllle that person's rights In the
Property. to Lender under tbe terms 01 this Security Instrument: and (8) that person Is not personally obligated to pay the sums
secured: and (C) that person agrees that Lender may agree with the other Borrowers to delay enforcing any of Lender's rights or
so mod~y or make any accommodation's with regard to the terms 01 this Security Instrument or the Note 'without the person's
consent;
12. ~OAN CHARGES
II the loan secured by this Securlly Instrument Is subject to a law which sets maximum loan charges, and that law is finally
lnterpret~d so that the Interest or other loan charges collected or to be collected in connection with the loan exceed permitted
limits: (A) any such loan- charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (B)
any sums already collected from Borrower which exceeded permilted limlls will be relunded to Borrower. Lender may choose to
make this refund by reducing the principal owed under the Note or by making a direcl payment to Borrower. If a relund reduces
principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Note.
13. 4EGISLATION AFFECTING LENDER'S RIGHTS
II a chah~e In applicable law would make any provision of the Note or this Security Instrument unenforceable. Lender may require
immediate paymenl in lull of an sums secured by this Security Instrum.ent as that phrase is defined In Paragraph 19 below. Jf
Lender requireS immediate payment in full under this Paragraph 13, Lender will take the steps and may act as specified in Paragraph
19 below.
14. NOTICES REQUIRED UNDER THIS SECURITY INSTRUMENT
Any notice that must be giVen to me under this Security Instrument will ~e given by delivering it or by mailing it by first class f!lail
unless applicable law requires use of another method. The notice will be addressed to me at the address stated in the section
above titled -Description 01 the Property.ft A Notice wlll be given to me at a dillerent address ill give Lender a notice of my
aifl~rent address. Any'notice that must be given to Lender under this Security Instrument will be given by mailing it to lender's
address stated In paragraph (Cl of the section above titled "Words Used Often In This Document. 0 A notice will be mailed to
Lender at a dillerent address if Lender gives me ~ notice of the different address. A notice required by this Security Instrument is
given when it is mailed or when it is delivered according to ttie requirements of this Paragraph 14 or of applicable law.
15. LAW THAT GOVERNS THIS SECURITY INSTRU~ENT
This Security Instrument is gOllerned by Federal law and the laws of the JuriSdicl.iofl \"r,,'~r,
,
The borrower hereby consents and a9rilas III..! i:a,> a~m( r'''''''!':'j )',;J, ,.; ol"lY V'\,lt llH:lli..:o/, illay li;1il wna.....!:llJ Of ext&floed beyono
maturity as olten as may be desir<,'1d h~1 "Iqrep-ftl.'m! h",t"!A~1"1 the r.rA(1itor 8f'ld 1:',1"" ~ub~ec!,.IAf" "".''',C:- :,' ~:-"" :::~"':::'Oc'~
renewal or extension shall in any way alleet the borrowe{'s responsiOiluy, wnelner as surety or otherwise. The borrow,er and any
other party assuming liability hereunder hereby consent and ,agree that if the property conveyed hereby or a substantial portion
thereof is transferred 10 any subsequent ov.:ner, and Ihe creditor exercises ~he right to accelerate debts secured ,hereby, the creditor
may accept any d'iltinquent payments qr otl1~ cure 01 defauR givirul!l~to such. acceleration from the then owner 01 the property or
any other person and ,reinstate l~ .indebted-ness in accordance wit~,:.the sche!:fUIe of maturity as 01 the time-of acceleration or upon
such new_schedula as may be agreed. if. renewal_ or extensiqn are' otherwise perm"ted and no such reinstatement shall in any way
1" 'ff! J-- F
.,-,'
""
'-,~'
'-
affect the liability of such, prior parties, whether as surety or otherwise,
\'-,l' . , .
IF aity~wm of Ihis, Security Instrument or of the Note conflicts with the law, all other terms of this Security Instrument and of the
N9te will still remain In effect If they can btil given allect without the conWctlng term. Tllls means th,at nay terms ,of this Security
Instrument, and 01 the Note: whIcH l?onfllcts with the law can be separated from the remaining terms and the remaining terms win still
be enlorced" , . _.l.'
16. BORROWEfl'SCOP~
" -. :,' , .!.
I will be ~~en 'bne COnfQrm9~" copy oiithe, Note and of this Security Instrument \nd ,hereby 'acliriow~dge' rebeipt, thereof..
, ,,- ," ,\' --"
,~jO
""
" ',-_ ,J ,_,_,':
17~ l'RANSI;ER OF. THE. PROPERTY OR A BENEFICIAL INTEREST INBORRi:>W~~:'
'..---c_, '
If al,1 or any part of the Property or an interest therein is sold or transferred by Borrower (or il a beneficial ifii-eresi in~&;'!ower IS
sol~ or transferred and Borrower is not a natural person or persons but is a corporation, partnership, trust or other legal entity)
without Lender's prior written consent, excluding (A) the creation or a lien or encumbrance subordinate to this Security Instrument
whlQh dOlilij nol rUli'lta 10 a lranaler of r~hli of OQQup,noy in the property; (B) the Cll1utlon 01 , puranusi money leoyrily inlilr6tll lor
hOUlehold IppllanOel; (01 a !fanDlar Il, ue,I", deaeMI ar by lhe aparallan 01 .w ~pon Ih. dealh of a lolnl tenanu or (0) Ihe
orant .1 I.V ~11~hald i11111111.1 thru V'"I OII.u not ...tailll.o 1ft .~II.. I. ~U"hsl'; L~dll "IV; .t Lond"'. .ptlon; d..I.I.
aU the sums secured by this Security Instrumenl to be immediately due and payable.
If Lender exercises such option 10 accelerate, Lender shall mail Borrower notice of acceleration in accordance with Paragraph 14
hereof, and Lender may, In accordance with Pennsylvania law, invoke any remedies permitted by Paragraph 24 herein.
Lender may consent to a sale or transfer if (1) Borrower causes to be submilled to Lender Information required by Lander to
evaluate the transferee as if a new loan were being made ,to the transferee; (2) Lender reasonably determines that lender's security
will not be impaired and thai the risk of a breach of any c'ovenanl or agreement in lhls Security Instrument is acceptable; (3) Interest
wlll be payable on the sumlj secured by this Security Instrument at a rate acceptable to Lender; (4) changes in the terms of the
Note and, this &!curity Instrument required by Lender are made, including, for example, periodic adjustment In the Interest rate, a
different,llnel payment date lor the loan, and addition 01 unpaid Interest 10 principal; and (5) the trans lares signs an assumption
agreement that is acceptable to Lender and that Obligates the translares to keep all the promises and agreements made in the Note
and in this Security Instrument, as modified II required by Lender. To the extent permitted by applicable Ia'ws, lender also may
charge ~ reasonable lee as a condition to Lendets l;:9f!~~l1t to any s~le or lransfer.
80rrow~~s will continua to ba o~llgated under the Note and this Security Instrument unless Lender releases Borrower in writing.
18. BORROWER'S WARRANTIES REGARDING FORFEITURE
Borrower states that he will nol 'bse. and will not permit any third party to use the Property or any portion thereof or Interest therein
(or any purpose that would caus\ the property to be subject to forfeiture, Borrower further states that the Property has not been
acquired with the proceeds from any transaction or activity that would thereby cause the Property 10 be subject to forleiture,
19. LENDER'S RIGHT TO REQUIRE IMMEDIATE PAYMENT IN FULL
III fail to. keep any promises or agreements made in the Note or in this Security Instrument, including the promises to pay when
the due! tlmounts I owe to Lender, I will be in default. If this occurs, the Lender may require that I pay immediately the entire
amount Ihen remaining unpaid under the Note and under this Security Instrument. Lender may do this without making any further
demand lor payment. This rf;!quiremenl will be catled ~Immediate Payment in Full,. If I am In delault lor any reason, you have the
right 10 demand payment of the entire amount I owe you, If Lender requires payment in full or In the event of a foreclosure action,
I agree to pay reasonable and permiS$lble legal fees, costs and disbursements, allowances and additional allowances as may be
awarded by any judgment of loreclosure and sale added thereto, and that such total amount shall be paid by me with interest, as
speCified In paragraph 25, up to the date you actually receive such payment, even aller foreclosure occurs.
In any lawsuit for sale, Lender will have the rlghlto (i) collect all costs allowed by law; (Ii) have the Property sold as one parcel;
and (Iii) have a Receiver appointed by the Court without first giving notice to me and without regard to the value 01 the Property.
Upon acceleration, Borrower shall have no right to reinstate, All rights and remedies provided In tl')ls Security Instrument are distlnct
and cumulative to ~ny other right or remedy under this Security Instrument or allorded by law or equity, and may be exercised
concurrently, Independently or successively.
20. LENDER'S RIGHTS TO RENTAL PAYMENTS AND TO TAKE POSSESSION OF THE PROPERTY
II lender requires Immediate Payment in Full, or ill abandon the Property, then Lender, persons authorized by Lender, or a receiver
appointed by the court at Lender's request may; (A) collect the rental payments, including overdue rental payments, directly from the
tenants: (8) enter on and take possession of the Property: (C) manage the Property: and (0) sign, cancel and change leases. 1I
Lender notilies the tenants, Lender has the right to collect rental payments 10 Lender without having to ask whether I failed 10 keep
my promisees and agreements under this Security Instrument. 11 there is a judgment for lender in a lawsuit for foreclosure and
sale, I will pay to Lender reasonable rentlrom the date the judgment is entered for as tong as I occupy the Property, However,
this does not give me the right to occupy the Property.
All reotal payments collected by Lender or by a receiver, other than the rent paid by me under this Paragraph 20, will be used first
10 pay the costs of collecting rental payments and/or managing the Property. If any part 01 the rental payments remains alter those
iftF
K
_11.
,',
c
':
,(
\:.-
I
,
costs have been paId In lull, Ihe remainIng pari will be used 10 reduce the amounl Ihal I owe 10 Lender under the Note and 'under
this Sec!Jtity Instrumen,l. The costs 01 managing Ihe Property may include, the receiver's lees, reasonable Q.ttorney's lees, and the
cost oli/any necessary, bonds. Lender and the receiver will be obligated to: account only for those renlal payments that they actually
. ., .
receive;,
If I fait to make',any paymenls or keep promises under this Sec\JritY,lnstrumeni or the Nole, then I _shall pay monthly if) advance to
you or to any rec~~er a lair charge lor Ihe lJse 01 the P~operty thllt I occupy. II I do not pay this lair charg~, yo'y)or .the fec,eiver
may sue to coltectlf:.9r to remove me, or both, ,I will not collecl more than one (1) monl~:S r",ol in ~vallce .Irp'm ,any tel\aot. o.r
occupant- without youf:'-wriUen consent. '. ". . ,
21. l.ENDER'S OtUGATIONTODlSCHARGE THIS SECURITY INSTRUM~N'1:' ,e,;' .<;i ,'i'
., - , ,,OJ,,,,-,,, .,_-:_:'.,~~<,:;-,.J,-:;:_>~~t~!;,~,~.':,_:,.,:.':_,<\.
When Lender has been paid aUtamounts due under the Note and under this SecurilY Instrtl~_eht,~i;'6.;L1i~d~l:Wjll;,re:!~~~J~,'itj~~s~b.J"r_iiY/-
Instrument, and deliver a certificate stating this Security Instrument has been paId In lull. Lender will then deliver a certificate siating'
Ihat this SecurllV Inslrument has been satisfied. I will pay all costs 01 recording the Release in the proper official records,
22. ADDITIONAL CHARGES
I iUfii 18 piy III "mAioll IlIiflll In 6111n1111811 willi 1110 181\11emO 811111! le.1I1 IAelWglAU ~WI Allllmllsllll elllllnlnl I~,
seatci'lEi~ ilfId bliis and in s)rocesslno insul'til1ce loss "ayments, ownership transfers, releases, E1asomsfihll BotH.bnlsl l'fIlIGh,lii.-/r'I,\,
modifications, special agreements, assignments, reductJon certificates and salislacllon 01 mortgage.
In Ihe event Borrower directs Lender to order any reports, appraisals, searches, examinations and/or the like, I agreB thai thd
expense lOT the same Is \0 be added to the balance 01 'he existing mortgage, 11 'Same It. not paid within 30 days 01 written
notification.
23. HAZARDOUS SUBSTANCES
Borrower shall not create or sulfer to axist, or permit any of Its agents, employees, contractors, tenants, or irwitees to creale or
suller to exist any lien, securUy Interest charge or encumbrance against the Property or any portion thereof, relating 10 any physical
or environmental, C,ondition, including, but not limited to, any lien Imposed pursuant to section 107(f) 01 the Superfund Amendments
and Requlhorlzatlon Act of 1986 (42 U.S.C. 9607(1)) or any similar federal, state or local statute, regulation, rule,' order or ordinance.
80f(Ow~r shall not cause or permil any other party 10 cause or permit the presence, use, disposal, storage or release of any
Hazard~us Substances on or in the ProperlY. Borrower shall not do, nor allow anyone else to do. anything affecting the Property
that is In violallon of any environmental law.
Borrowsr shall prompUy give the Lender written notice of any investigallon, claim, demand, lawsuit or other action by any
governmental or regulatory- agency or private party Involving the PrOperlY and any Hazardous Substance or environmental law, of
which the Borrower has actual knowledge or should have actual knowledge. If Borrower learns or is notified by any governmental
or regulatory authority Ihat any remol'al or remediation 01 any Hazardous Substance allectlng the Property is necessary, Borrower
shall promptly take necessary remedial, removal and other actions necessary 10 clean up and remove all Hazardous Substances,
solid wastes, or contaminates on, in, Irom, or allecUng the property or any portion thereof, In accordance with environmenlal law, to
the sat~faclion of the lender and In accordance with all orders and directives of governmental authorities having iurisdlction over the
Property .andlor such substances or materials. II Borrower fails 10 take remedial action, and upo" receipt 01 notice Irom any party
asserting' the existence of any Hazardous Substances altecting the property thai It true may resull. In an ordeJ, suit imposition 01 a
lien on Ihe property, or other action, or if the lender in good laith believes would jeopardize lis security interest, the Lender at ils
option shall take whatever acUon necessary In accordance with environmental law, to clean up, remove. resolve or olherwise
remedlate the situatIon. All reasonable costs and expenses paid or Incurred bV Lender in the exercise of such rights shall be
secured by the liens
Borrower Shalllndemnlly, exonerate, defend and hold harmless Lender, ils officers, directors, shareholders, agents and employees,
from and against any and aU clarms, demands, obligallons, penalties, fin6s, suils, llabllities, setllemeflts, damages, losses, costs and
expenses (inCluding but not Ilmlledto, attorney and consultant lees and expenses, Investigation fees, laboratory expenses, cleanup
costs and other expenses ot lUlgallon or arbitration), as well as any such lees and expenses Incurred in enforcing this indemnity,
and any, violation 01 any applicable environmenlallaws In effect on or belore Ihe date hereof or hereafter made effective.
As used In this document, 6tia:z:ardous Substances6 are those substances defined as toxic or hazardous substances by
El\Vironmenta.\ Law, and the loUowing substances: gasoline, kerosene, other flammable or toxic petroleum products or by-products,
toxic pesticides, herbicides and fungicides, volatile solvents, materials containing asbestos or formaldehyde and radioactive materials.
As used In this document, ~environmental Law" means lederal, state, and locallaw$, statutes, rules, regulations, judicial orders and
decisions Ihat relate to health, safety or environmental protection and maintenance in the jurisdiction where the property is located.
24. MISCEl.LANEOUS PROVISIONS
(A) In the evei'll that the holder of this Security Instrument be required to retain legal counsel lor the purpose of commencing
loreclosure proceeding
(C) In the event that Borrower declares Bankrupt~y and Lender has petition dismissed then Borrower shall be responsible for
Lender's legal lees.
pH t-J~
-
/
,
:'~\'; ,: :
?;';~";'~
-",
:?ft:;
'\lit{;.f~~; .
-,...-.
~..;L ~" C"
\...../
.,....-.
(OJ In the event that lender shall advance any money in order to pay Borrower's insurance, taxes and/or hazard Insurance and/or
any ol~~riJUdgments,:1iens, violations or actions under Paragraph 23, then.Borrower will pay Interest on the sums advanced at the
rate sp~cified in Borrower's Note,
,.
(E) In the event thai the premises sullers damage or Borrower's statements and/or representations have been found to be false
prior to the disbursemenl of funds. Lender, In its sole discrellon, may cancel this Note and Lender shall have no lurther obligations
to the Borrower. Lender agrees that Lender wllJ file a Salislacllon 01 Mortgage in the county this Security Instrument is filed with
the Ollice 01 the County Clerk prior to cancellation by Lender.
(F) In the event that a~y check paid by Borrower to lender is returned unpaid then and III that event Lender may, at Lender's
option, require bank or tertilled f.unds lor each payment made therealler.
(G) In the event the Borrower(s) herein cause or bring any action. proceeding or petition for the assignment, liquidation or
rearrangement of their total indebtedness under any federal, state or local stalue, and In such event there is an improper impairment
of the lien 01 this 'Security Instrument within the meaning of any Title, Code or local statute therein relevant, there shall be -allowed,
awarded and granted to the holder 01 this Security Instrument by the court or tribunal having Jurisdiction thereol, reasonable legal
fees Incurred to protect the lien of this Security Instrument against such Improper impairment, or In the event the holder of this
Security Instrument is required to bring on any motion or proceeding to vacate any stay or compel rejection 01 any proposed plan.
Such award of reasonable counsel fees shall be based upon the reasonable hourly billing rate of an experienced real
est8teJbankruptcy practitioner within the jurisdIctIon of the court of tribunal, and without any reference or regard direct or indirect to
the now disused theory 01 Neconomy 01 administration."
(H) In addition. Lender shall be entllled to charge Interest on all accrued Interest. foreclosure costs, allomey fees whether incurred
as a result 01 the foreclosure or the bankruptcy proceeding, or other pre,p9liUon arrearage payable pursuant to or through any plan
in the bankruptcy proceeding. The Interest rate shall be the same rate Charged under the Note secured by this Security Instrument.
25. ACCELERATION; .REMEDIES
In the event 01 a delault by Borrower, In any 01 its covenants and agreements hereunder or in the event of a breach of any of
6Qrrowets represerltalKmS and waffanties l\efein, lender, at its option, may require Immediate payment in lull 01 all sums secured by
lhis Security Instrument without further demand or notlee 01 Borrower and may invoke any remedy permitted by applicable law.
J .
If the ~hder requires payment in lull, or In the event of a foreclosure acllon, I agree to pay reasonable legal fees, principal and
interes~1costs and disbursements, allowances and additional allowances as may be awarded by any judgment 01 foreclosure and
sale added thereto. Aller acceleration and until a Judgment has been entered, I shall pay this total amount with interest. up to the
day you actually receive such payment, at the following Interest rate: a) 24% if this Is a mortgage in excess 01 $50,000.00; or b) the
Note rale If this is a mortgage bearing an original principal amount between $5,000.00 and $50,000.00. After a judgment has been
rendered, the Interest rate will be the highest permitted by the State 01 Pennsylvania.
In addition, Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided In this paragraph 25, InCluding
but not limited to, reasonable allarney's lees and costs 01 Iitle evldenoe. Upon accelerallon, Borrower shall have no right to
reinstate. All rights and remedies provided in this Security Instrument are distinct and cumulative to any other right or remedy under
this Security Instrument or afforded by law or equity, and may be exercised concurrently, independently or successively.
i
26. RIDERS TO THIS SECURITY INSTRUMENT
.'
If one or more riders are signed by Borrower and recorded together wllh this Security Instrument, the promises and agreements 01
each afe incorporated as a part of this Security Instrument. (Check applicable box(es))
AdJLlstable Rate Aider
- Condo;"lnlum Aider
_ Biweekly Payment Alder
_ Graduated Payment Alder
_ 1-4 Family Alder
_ Planned Unit Development Rider
_ Rate Improvement Alder
Second Home Rider
lL Schedule NAN Legal t
VA Alder
_ Other(s) (specify]
BY SIGNING BELOW, Borrowers accept and agree to the promises and agreements contained in this Security Instrument and in
any rider(s) signed b}l me and recorded with it.
/JC
--
.')
Borrower
(Seal)
Borrower
'1
,-I
c
',:.
,-
,
'-
.J. .~\\ Je
STATE pF MARYLAND, (A . MO COUNTY, 10 wit ss:
I Hereby Certify, That on this 20th day 01 January, 1999, before me, the undersigned. a Notary Public in and lor said
County, personally appeared ARTHUR L. FRITZ, JR. and. and acknowledged that they executed the same lor the purpose
hare thoreln contained,
WITNESS my hand and official seal.
~
Notary Public
r.4v Commlssiun Expires:
I CERTIFY THAT THE PRECISE PLACE OF BUSINESS OF THE WITHIN NAMED MORTGAGEE IS.
100 PAINTERS MILL ROAD, SUITE 800
OWINGS MILLS, MD 21117
1;1
rf
~f!Lr
_,."__,~,,,,'O
~ :."
c
t'
,
58812
i ~
EXHIBIT "A;'
BEING KNOWN AND DESIGNATED AS A~~ THAT CERTAIN ~OT OF LAND, SITUATE IN LOWER A~~EN
TOWNSHIP, CUMBERLAND COUNTY, PENNSY~VANIA, MORE PARTlCU~AR~ Y BOUNOEO AND
DESCRIBEO AS FO~~OWS, TO WIT:
ON THE EAST BY PROPERTY, NOW OR FORMER~Y, OF J. C. BUCHER; ON. THE SOUTH BYLANDS,
NOW OR FORMER~Y, OF PHILADELPHIA, HARRISBURG AND PITTSBURGH RAILROAD; ON THE
WEST BY. LANDS, NOW OR FORMERLY, OF MARY E.COLEMAN; AND ON THE'.NbRTH,fjY'HUMMEL
AVENUE; CONTAINING IN FRONT OF HUMMEL AVENUE 35 FEET, AND EXTENDINGSOUTHWARDL Y
AT AN EVEN WIDTH 85 FEET, MORE OR LESS, TO LANDS, OF THE PHILADELPHIA, HARRISBURG
AND PITTSBURGH RAILROAD;
HAVING THEREON ERECTED A SINGLE TWO-STORY FRAME BUNGALOW HOUSE.
THE IMPROVEMENTS THEREON BEING COMMONLY KNOWN AS 1701 HUMME~ AVENUE, ~OWER
AL~EN TOWNSHIP, CUMBERLANO COUNTY, PENNSYLVANIA.
BEING THE SAME ~OT OR PARCEL OF GROUND WHICH BY DE EO DATED NOVEMBER 10, 1995
AND RECORDED AMONG THE LAND RECORDS OF CUMBERLAND COUNTY IN BOOK 131, PAGE 690
WAS GRANTED ANO CONVEYED BY GEORGE G. STRADTMAN AND JEAN R. STRAOTMAN, HIS
WIFE, UNTO ARTHUR L. FRITZ, JR.
1'1
"i
,I
\....-
":,,
c
THIS ASSIGNMENT OF' DEED OF TRUST, Made this 20th day 01 January in the year 1999. bl" AMERICAN
MORTGAGE REDUCTION, ING. of OWINGS" MillS, MARYLAND.
W1TNESSETH, that in consideration of the sum of
FIVE DOllARS ($ S.D01. the SAid AMERICAN MORTGAGE REDUCTION, INC. doth heroby grant and assign unto;
. AL~'F::-q" cr.=c:')n C:"'~;~tl\;'Y
all of ils right, title and interest In a carlaln Deed 01 Trust made 10 AMERICAN MORTGAGE AEOuC'nON. INC. by
ARTHUR L. FRITZ, JR. and dated the 20th day of January, 1999 and recorded among the Land Records of
CUMBERLAND COUNTY In 1,.Iber
_IorIO
on the propen" known u HO\ HUMMEL AVENUE.
CAMPHJLl, PA 17011.
AS WITNESS the hand and seal the day and year first above written.
WITNESS: AMERICAN MORTGAGE REOUCTION. iN~
,~~~~tok B" .
I HARRY S. KOROTKI
"
~*~::
STATE OF MARY'LAND. COUNTY OF BAlTIMoRE, to wit:
I HEREBY CEATIF't, thai on this -20th-day of January, 1999 bafore me. the subscriber, a Notary Public, 01 the State of
Maryland, in and tor thQ County 01 Balllmore aloresald, personally appeared HARRY S. KOROTKI, ,Trustee(s) lor
AMERICAN MORTGAGE REDUCTION, INC. and acknowledged the aforagoing to ba his act.
As witness my hand and Notarial Seal
My c;~mlsslon Explru: rlr~
MULTlaT....TE a....LlOON FlXEO RATE NOTE'Singl. F~mUy'FNMA UNIFOfIM INSTRUMENT (REV.) FO/ln 321111 3/11
F\LLTEGRF\ Fdx:1\12~1\1\2-5381\
Dee 29 '99 9:00 P.02
r ~ III .q 1.,lj-U0 :)Y
Natioo..J1 City Bdnk of Penn'Sylv.:Jni."'l
Con-:;;omct" l031'\ Scrvice~
P.O, Box 53$400
Piusbt.u.gh, PA I6253-S400
.
. Na\."4onalCity..
APPENDIX A
(COMlHNED AT 91/ACT 6 NOTIr.E)
"DATE: December 23.1999
HOMEOWNER'S NAME(S): Arthur L. Fritz. Jr.
PROPERTY ADDRESS: 1701 Hummel Avenue
Camp Hill. PA 17011
CREDrrOR:
National Citv 8ank
LOAN ACCT. NO.:
8669142
YOUR MORTGAGE IS IN DEFAULT
FOR REASONS SET FORTH IN TfilS NOTICE
VOUR. LENDER MA V FORECLOSE AND YOU MA V LOSE YOUR HOME.
IF YOU WANT TO SAVE YOUR HOME FROM FORECLOSURE. YOU MUST TAKE
ACTION NOW BY EITHER:
l. CURING TItE DEFAULT - This notice explains the nature orlhc default and your
rights to protect your interest in your home (s"ee Section 403 of the Act of January 30, 1974
(p.L. 13, No.6), 41 P.5, Section 403); OR
2. APPl.YING TO TIlE HOMEOWNER'S EMERGENCYMORTGAGE ASSISTANCE
PROGRAM FOR FINANCIAL ASSIST ANCF. WHICH CAN SAVE YOUR. HOME
FROM FORECLOSURE AND HELP-YOU MAKE Ftrrotu; MORTGAGE PAYMENTS
- Read this notice to find out how the program \Yorks. Your must meet with a Consumer
Credit ClIunsc1inl! Al1encv within 30 davs of the date of this notice in order to apolv. See
^~t of De~ember 23,1983 (p.L. 385, No.91), 35 P.S. Section 1680.201c-1680.409c. If you
neM more information, call the Pennsylvania Housing Finance Agency at 1-(800) 342-2397.
LA NOTIFICATION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVlENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCClON
IMMEDlTAMENTE LLAMANDO EST A AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA.
PUEDES SER ELEGrBLE PAR UN PREST AMO POR EL PROGnAMA LLAMA DO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIl"OTECA.
. . .".. . \'. ~ -' ''',
RLLfCGRn
rdx:~1?-~~?-5384
Df~c 29 '99
9:00
P.03
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MA Y Ill; ELlCInLF. FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR
:aCME FlWM FO~F:CLOS1JRE AND HELP YOU MAKE FUTURE MOltTGAGF.
, , . 1>A YMEl\'TS '.
IF YOU COMPLY WITH THE l?novrsION'S OF T:aE HOMEOWNER'S :eMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELlGIBLE
.. FOR EMERGENCY MORTGAGE ASSISTANCE rFYOUR DEFAULT HAS BEEN
CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HA VE A
REASONABLE PROSPECT OF RESuMING YOUR MORTGAGE PAYMENTS AND IF
YOU MEET OTHER ELIGlBILITY REQUIREMENiS ESTABLISHED BY HIE
PENNSYLVANIA HOUSING FINANCE AGENCY. PLEASE READ ALL OF Tms
NOTICE. IT CONTAINS AN EX?LANA TION OF YOUR RiGHTS.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are 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 allend a "face-to-face" meeting with a representative of the
creditor or with a 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. TIDS
MEETING MUST OCCUR WITHIN THE NEXT (30) DA YS.
HOW TO CONTACT THE CREDITOR:
Name of Creditor: N2tional Citv /lank
Address:
150 Allel!'henv Ceuter. PittsbuTl!h PA 15212
Phone Number: 1-800-745-1787. exL 3958
Contact Person: .Crvstal Zin k
CONSUMER CREDIT COUNSELING AGENCY - If you meet with your creditor or with a
consumer credit counseling agency identified in this notice, the creditor may NOT take action
against you for thirty (30) days afler the date of this meeting. The names and addresses of
desil!llated consumer credit counseling agencies for the county ill which the orooerty is located
are .hown on the attJtched sheet. It is only necessaiy to schedule one face-lo-face meeting.
Advise your creditor immediately of your intentions.
APPUCATION FOR MORTGACE ASSISTANCE -- Your mortgage is in default for the
reasons set forth in this Notice. If you have tried and are unable to resolve this problem with the
creditor, you have the right to apply for financial assistance from the Homeowner's Emergem:y
Mortgage Assistance Program Application with one of the designated consumer credit
counseling agencies listed on the attachment, Only consumer credit counseling agencies have
applications for the program and they will assist you in submitting a complete application to the
Pennsylyania Housing Finance Agency.
2
f1LLT[GRf1
Fax:412-442-S384
Dee 29 '99
9:01
P.04
Your applieatiorl MUST be filed or postmarked within thirty (30) days of your face-to.face
meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR
IF YOU DO NOT FOLLOW TIlE OTHER TIME PERIODS SET FORnI IN THIS
LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y
AND YOUR APPLlCA TlON FOR MORTGAGE ASSISTANCE WILL BE Dl!:NIED.
'. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibihty criteria established by the Act. It is
ex!temely 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 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
Pennsylvania Housing Finance Agency of il s decision on you application.
TUE PENNSYLVANIA UOUSING FINANCE AGENCY IS LOCATED AT 2101 NORTH
FRONT STREET, POST OFFICE BOX 8029, HARRISBURG, PENNSYLVANIA 17105.
TELJi:PHONE NO. (717) 780-3800 OR 1-800-342-2397 (TOLL FREE NUMBER).
PERSONS WITH IMpAIRED HEARING CAN CALL (717) 780-1869.
HOW YOUR MORTGAGF. IS IN f)EF AUL T
NATURE OF THE DEFAULT -- TI\~ MORTGAGE debt held by the above ereditor on your
property located at: 1701 fl'ummel Avenue
Carn" Hill. PA 17011
IS SERlOUSL Y IN DEF AUL T because:
YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS. The
following amounts are past due:
l'a.yments of Principa.l and interest: $5.111.96
Escrow cbarges:
Late charges:
$36.5 I
Attorney Fees/cost.:
Other eltarges:
Total Amount Past Due: S 5.148.47
B. YOU UA VE FAILED TO TAKE THE FOLLOWING ACTION (EXPLAIN):
Pay monthlY payments 0($730.28 from 5/25/99 to 11/25/99.
3
_L__,.
RLLTEGRR
Fax:412-442-S384
Dee 29 '99
9:01
P.OS
HOW TO CURE THE OEFAULT -- You may cure the default within THIRTY (30) DAYS of
the date of this nolice BY PA )tING THE TOTAL AMOUNT PAST DUE to the creditor pIlls
any additional monthly payments and late charges which may fill due after the date of Ihis notice
and the date you make your payment. Payments must be made either by cash, caShier's check,
certified check or money order made payable and sent to:
National City Bank
150 Allegheny Center 23-521
:Pittsburgh, PA 15212
You can cure any other dcfault by taking the following action within thirty (30) days of the date
of this letter.
N/A (Monetary default only)
IF YOU DO NOT CURl!: THE DEF AUL T -- If you do not cure the default within lHIRTY
(30) DAYS of the date of this Notice, the creditor intends to exercise its ri!!:!1ts to accelerate
the mort!!'a!!:e debt. This means that the entire oulslanding balance of this debt will be
considered due immediately and you may lose the chance 10 pay Ihe mortgage in monthly
installments. If full payment of Ihe lotal amount pasl due is not made within TIIIRTY (30)
DAYS, Ihe creditor also intends 10 instmct ils attom!;YS to start a lawsuit to foreclose UDon your
mortl!'ll!!ed DrODertv.
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by
the Sheriff to pay off the mortgage debt. If the creditor refers your case to it s attorneys, but you
cure the delinquency before the creditor begins legal proceedings against you, you will still be
required to pay the reasonable attorney's fees Ihat were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by !he creditor even if they exceed $50.00. Arty attorney's fees
will be added to the amounl you owe the creditor, which may also include other reasonable costs_
IF YOU CURE THE DEFAULT WITHIN mE Ihirty (30) DAY Denod you will not be reauired
to Day attorney'S fees.
OTHER CREDITOR REMEDIES -- The credito,r may also sue you personally for the unpaid
principal balance and all other sums due under the mortgage.
_,!1ilP
RIGHT TO CURE THE Dl!:FAUL T PRIOR TO SHERIFF'S SALE -- If you have not cured
the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you
still have the rie:hl to cure the default and prevenllhe sale at any lime UD to one hour before the
Sheriffs Sale. You may do so bv pavin!! the total amount Dlus any late or other costs connecled
with Ihe Shenfrs Sate and bv Derforming: anY other reouirements under the mort!!'a2e.
4
-
tiiIij.liii
.~
~i:lilfMlf",,","-.~-'.
~~
~.
.
"
b
"
" I
~.
RLLTEGRR
Fax:412-442-5384
Dee 29 '99
9:02
P.06
EARLIF:ST POSSJRLE SHERIFF'S SAl,E DA n: -- It is estimated that tile earliest date that
such a Sheriffs Sale of the mortgage property could be held would be approximately six (6)
months from the date of this Notice. A notice of the actual date of Ihe Sheriffs Sale will be sent
to you before the sale. Of course, the amount needed to cure the default will increase the longer
you wait. You may find out at any time exactly what the required payment or action will be by
contacting the creditor. If money is due, such payment must be in cash, cashier's check, certified
check or money order made payable to the creditor at the address set forth above.
EFFF.:CT OF SHERIFF'S SALE -- You should realize that Sheriffs Sale will end your
ownership of the mortgaged properly and your right to occupy it. [fyou continue to live in the
property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the creditor at any time,
OTHER RIGHTS THAT YOU HA VE -- You have additional rights to help protect your
interest in the property:
YOU ALSO HAVE TIlE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO
PAYOFF THIS DEBT.
TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A
BUYER OR TRANSFEREE WHO WlLL A$SUME THE MORTGAGE DEBT,
PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR 0 OR AT THE SALE AND THAT
THE OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED. CONTACT
THE CREDITOR TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT
MIGHT EXIST.
TO HAVE TIDS DEFAULT CURED BY ANY TIDRD PARTY ACTING ON YOU
BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED,lF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RlGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES
IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LA WSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH
ACTION BY THE CREDITOR.
s
, ,
...~
ALLTEGRA
.1
Fax:412-442-S384
P.O?
Dee 29 '99
9:02
.
The n,mes, addresses and l,hone numbers of designated consumer credit counseling
agencies are:
I, ACTION HOUSING, INC.
TWO GA TEW A Y CENrER
PIITSBURGH, PA 15122
(412) 281-2102
2. CONSUMER CREDIT COUNSELING SERVICE OF WESTERN
PENNSYLVANIA INC.
SUITE 500, 309 SMITHFIELD STREET
PITISBURGH.PA 15222
(412) 47\-7584
662 NORm MAIN STREET
GREENSBURG, PA 15601
(724) 838-1290
3. HOUSING ACTION COALmON, INe.
WESTMORELAND COUNTY ONLY
714 PHILADELPHIA STREET
INDIANA, PA 15701
4. HOUSING OPPORTUNITIES, INC.
623 VERSAILLES AVENUE
McKEE$PORT, PA 15U4
P. O. BOX 278
500-021RIRD AVE.
DUNCANSVILLE. PA 16635
(814) 696-3546
125 NORTH JEFFERSON STREET
NEW CASTLE, PA 16101
(412) 652-8074
5, MON.VALLEY UNEMPLOYED COMMIITEE
600 W ALNUf STREET
McKEESPORT. PA 15134
URBAN LEAGUE
OF HARRISBURG, INC.
28 NORTH SECOND STREET
HARRISBURG, PA 11101
(717) 234-5925
6. URBAN LEAGUE
OF PITTSBURGH, INC.
AlLEGHENY COUNTY ONLY
200 ROSS STREET
PITISBURGH, PA 15219
(412) 261-1130
7. CONSUMER CREDIT COUNSEUNO SERVICE OF DELAWARE V ALLEY
Ill! CHESTNUT STREET - SUITE 411 '
PHILADELPHIA. PA 19101
(215) 563-5665
8. CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY
P.O. BOX A
WHITEHALL, PA 18052
(610)821-4010
6
,
I
!
I
,
,
.
ALLTEGRA
Fax:412-442-5384
"
:l
:'1
,
-----
:---.0,_
l'-
~
~
RETU1'lN
REceIPT
seRVICE
-
~tEuveRV
Q;Jn'Aa) Rt ... Rr;T\JRN AecePT
~flOS'rABENoIDf!fES
SENT
.D
.JJ
c
i\"IHvR L. flU IZ. .JR.
1701 IlUMMEL AVENUE
(,\!-:1' lULL. Pi' li'On
cr
.Jl
II'"
OL
P$ FORM 3800
US Postal Service
,_.
~._~~_____.______A__'_____
Dee 29 '99
::"",
POmtARK OR BAil
Receipt for
Certified Mail
:
~ j
'" .
... .
o :
.J uS:
.~~~
%""
w~1
"'".
0<:.,
0.%'
~a:'
!:i~.
",0:
~[!;.
~i;
",-.
(,l""
:1....
...i!"
~
~
o
...
;!1
. - -. ~-I
I
1--".--- -""!,,.--o.. __ _ ~ _ _ ----. ----. _'~ _'_ -.-:..~ _ ---. ~ __ _ _____'-:--.'
.
.
. ".,,<f~' ,.
.~;
,; ".:'-'''.-
....:::~: '
.'-."..-, "'" c-..'......-.,..
'. .:;:~.::t.':i~~~.-,~'~~~:;~;::.:-;'.-
,..i~d~~~L~_,: h.-'
9:02
P.08
f
i:
:1
k
'::!"
)~j ,"
"
, .
. ,',.., "",
.",.....-..
;.,<k;;l..~i::.;.4;:~~~~~..>;~,. .
....'.., ,
~.:_; .~;.~~;).;~~;0;~~~,,:;
o
c
RLLTEGRR
Fax:412-442-5384
Dee 29 '99
9:03
~ ,--.~--. ----- -- -.,- ---- -- --- ~- _.-...... '-- .-.-
l"-
on
=r
~ """"" POSTMARK DR DATE
FlETURN
RESTRIGTEO OELIVEFt
R~Ct;:lIlT
CERTIFIED FEE .. flETUAN RECEIPT
SERVICE
TOllU. POSTAGE ANa FEES
SENT 10: .....' tlCT FO~~~~~~I'm"L "'AIL -
. ..'..r..... r . " ,., .;.(.
, '::':t:.<!. " H ,.;".'
~~L .. .'
. ':,..! . .. . ...... ,
Jl
Jl
c:J
g
W
0.
o
....
wO)
,.'"
zw
wOO
,,-e
o:l
o.z
8",
ti~
a: a:
w,,-
"'0
~....
~:z:
<A!:!
w",
~w
a
0-
-n
Ir'
EL
PS FORM 3800
US Postal Service
s;
~
~
;;;
Receipt for
Certified Mail
,<II
._ _""""_ _ _ _ - _ _ __ ~ -~ _ ----. -, ___. __.... ......-.r--.-:- __. _ _ __,
P.09
.
--
.I!IIIlliiI1IIIilM_' ,
" IIiiiiii!I
'-tfT"'-- ,
~. ~
<>{\ ~
~ ~
-.(\. Qj
~ ~
~. -',
o C)
~ 0
~m ~
""",C-
(1).,}':> C)-
;:::z
~O -0
:z0 :::z;
)>:0
~ ;
~
o
-n
:,~j
(;~ :TI
;~~
::':;0.
;t~B
~;)t)
OrT1
-i
~
'-,
1
-
~
~'^
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-00176 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ALTEGRA CREDIT CO
VS
FRITZ ARTHUR L JR
KATHY CLARKE
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
FRITZ ARTHUR L JR
the
DEFENDANT
, at 0013:44 HOURS, on the 12th day of January ,2000
at 82 LINDA DRIVE
LOT 52
MECHANICSBURG, PA 17055
by handing to
JEAN FRITZ (WIFE)
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
5.58
.00
10.00
.00
33.58
So Answers:
r-~~~~t
R. Thomas Kline
01/14/2000
DOUGLAS M.
Sworn and Subscribed to before
By:
MARINOS
t::,~he~
me this ,) /It..oI day of
,1..d.,,, .) 0L0-0-0 A . D .
~(J.~~
Prothonotary
-" c_ ,"~
<..~ ..,";,
.- "-.,,,.--- ,-.
.-1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION - LAW
AL TEGRA CREDIT COMPANY,
Defendant
)
)
)
) NO. 2000-176 Civil
)
)
)
)
)
Plaintiff
vs.
ARTHUR L. FRITZ, JR.
PRAECIPE TO ENTER DEF AUL T JUDGMENT
TO THE PROTHONOTARY:
Kindly enter default judgment in favor of Plaintiff, Altegra Credit Company, and against
Defendant, Mark Barger, for failure to answer Plaintiffs Complaint In Mortgage Foreclosure.
1. Pursuant to Pa.R.C.P. 237.1(2)(ii), I hereby certify that I mailed written notice of
Plaintiffs intention to file this Praecipe to the Defendant at least ten (10) days prior to the date of
filing. A true and correct copy of the Notice sent to the Defendant is attached hereto, made a part
hereof, and marked, collectively, as Exhibit "A".
2. A true and correct copy of the Cumberland County Sheriff s Return of Service of
Plaintiffs Complaint In Mortgage Foreclosure upon Defendant, Arthur L. Fritz, Jr., on January
12, 2000 is attached hereto, made a part hereof and marked, as Exhibit "B".
3. Pursuant to Pa.R.C.P. 1026, Defendant's answer or any other pleading responsive
to Plaintiffs Complaint should have been filed by February 1,2000.
.~.,_ .~ C.' . . :
"n
, ",. " -.) ~~ - ",-
-,-
'"" _~_l
4. Defendant has not filed, or served Plaintiff with, an answer or other pleading
responsive to Plaintiffs Complaint In Mortgage Foreclosure by February 1,2000.
5. An Affidavit Of Non-Military Service for Defendant is attached hereto, made a
part hereof, and marked as Exhibit "C".
6. Kindly assess damages as of April II, 2000, Defendant is indebted to Altegra
under the Note and Mortgage in the amount of NINETY -SEVEN THOUSAND TWO
HUNDRED TWENTY-TWO AND 28/100 DOLLARS ($97,222.28), which is comprised of the
following amounts:
Principal $ 84,880.07
Accrued Interest as of
November 15, 1999 $ 4,381.68
Interest accrued from and
after November 15, 1999 to
April 11, 2000 at $22.98
Per diem $ 3,424.02
Late Charges
$
36.51
Attorney's Fees & Costs
$ 4,500.00
REAL DEBT
$ 97,222.28
plus interest accruing from and after April 11, 2000, at the per diem rate of$22.98.
"' 'c' _~ . ',-,
,.._-~
,'.-'-, -
DOUGLAS M. MARINOS & ASSOCIATES, P.C.
Aoril12. 2000
BY M--?~
D~S M. ARINOS, ESQUIRE
101 North Cedar Crest Blvd.
Allentown, P A 18104
(610) 434-5441
Attorney I.D. No. 53104
DATE
.
...._1
. ~",',
DOUGLAS M. MARINOS & ASSOCIATES, P.e.
ATTORNEYS AT LAW
101 NORTH CEDAR CREST BOULEVARD, ALLENTOWN, PA 18104
TEL: (610) 434-0504 FAX: (610) 434-0538
February 9, 2000
Arthur L. Fritz, Jr.
170 I Hummel Avenue
Camp Hill, PA 17011
Re: AItel!ra Credit ComDanv vs. Arthur L. Fritz. Jr.
Complaint In Mortgage Foreclosure
Cumberland County CCP No: 2000-176 Civil
Dear Mr. Fritz:
Enclosed herewith is written notice of the intention of Altegra Credit Company, Plaintiff
in the above-captioned action to enter judgment by default against you in the above-captioned
action within ten (10) days from the date of the notice enclosed.-
Sincerely,
:?~
os
DMMleag
U.S. POSTAL SERV' E CERTIFICATE OF MAILING
MAYBE USED FOR DOMESTIC AND INTERNA naNAl MAIL DOES NOT
PROVIDE FOR INSURANCE POSTMASTER .
Allentown. PA 18104
~",",'~lt-lI."''iO.';'''\::\.t~i~
~!;i .:'~.~ 1 ~ ;
,1,1 ~-.
"!: ...;.." 2.
il",i ,'-. ::~
;d! ::i.
~ ~ \.~r~~
..," 1 ~ N ..\
~ eJ i}l~ <!
...1. \:~, .~l .c..,
'I ," -1.>"''). U-l I
.U.S.Q,P.O.: 1912.329-lI23I882:t? -.-" ~'-, <~_.~
Received From:
Douglas M. Marinos, Esquire
LAS M. MARINOS &
ASSOCIATES, p.e.
One piece of ordinarY mail addressed to:
Arthur L. Fritz, Jr.
1701 Hummel Avenue
Camp Hill, PA 17011
PS Form 3817. Mar. 1989
,
,,J;
.... ~~..-.JlV
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION - LAW
ALTEGRA CREDIT COMPANY,
Plaintiff
)
)
)
) NO. 2000-176 Civil
)
)
)
)
)
vs.
ARTHUR L. FRITZ, JR.
Defendant
IMPORTANT NOTICE
TO: ARTHUR L. FRITZ, JR.
1701 Hummel Avenue
Camp Hill, PA 17011
DATE OF NOTICE: February 9, 2000
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIiER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA VEA
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
4th FLOOR
CARLISLE, PA 17013
(717) 240-6200
Douglas M. Marinos & Associates, P.C.
....~,--"~""""
SHERIFF'S RETURN - REGULAR
'~E NO: 2000~00176 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ALTEGRA CREDIT CO
VS
FRITZ ARTHUR L JR
KATHY CLARKE
, Sheriff or Deputy Sheriff of
Cumberland county, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
FRITZ ARTHUR L JR
the
DEFENDANT
, at 0013:44 HOURS, on the 12th day of January , 2000
at 82 LINDA DRIVE
LOT 52
MECHANICSBURG, PA 17055
by handing to
JEAN FRITZ (WIFE)
a true and attested copy of COMPLAINT - MORT FORE
, NOTICE
together with
and at the same time direc.ting Her, attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
. 18.00
5.58
. .00
10.00
.00
33.58
So Answers: .
~~~.t
R.~ Thomas Kline
01/14/2000
DOUGLAS M.
Sworn and Subscribed to before
By:
MARINOS
;(.~he~
me this
day of
A.D.
Prothonotary
,.-
'1-,
" ,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION - LAW
AL TEGRA CREDIT COMPANY,
Plaintiff
)
)
)
) NO. 2000-176 Civil
)
)
)
)
)
vs.
ARTHUR L. FRITZ, JR.
Defendant
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF LEHIGH
DOUGLAS M. MARINOS, ESQUIRE, being first duly sworn according to law, hereby
deposes and says:
1. I am the attorney responsible for representing Plaintiff, Altegra Credit Company
in the above-captioned action, and I am authorized to make this Affidavit on behalf of Plaintiff.
2. Plaintiffs address is 116 Allegheny Center, !DC 23-521, First Floor, Pittsburgh,
Pennsylvania 15212.
3. The last known address of Defendant, Arthur L Fritz, Jr., is 1701 Hummel
Avenue, Camp Hill, P A, 17011.
4. Defendant is not in the military service of the United States or any State or
Territory thereof or its allies, as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and
the amendments thereto.
~L~i:~
-,'-
Sworn to and subscribed
before me this /:<'f..- day
of --Of(d . ,2000.
~A~
Notary ublic
Notarial Seal
Elizabeth A. Gschrey. Notary Public
Allentown. Lehigh County
My Commission Expires Sept. f 1, 2000
, ;.
>,-,
",,-=,-l,~_
.
.- -~_k_ - "r f';
" -.....,~"
" "
. '-'~ 4id1lli
-.
- o. '.
~R~~
--
~
f
~
*'
-
(jv
0v
*'--
\
..........
~
~
~
~,
"-",
,- c:._"C c'- "~ -
C)
. (7~
:";...;
'.' ,.~;
:=-:.\
=
__on
---;-,
.' n
,",
'-,--
_.C)
, "
g~~
c-l
~
-<
':c?
.-.1
.
:
"'.-
1-_
.-
--
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION - LAW
ALTEGRA CREDIT COMPANY,
Defendant
)
)
)
) NO. 2000-176 Civil
)
)
)
)
)
Plaintiff
vs.
ARTHUR 1. FRITZ, JR.
NOTICE OF ENTRY OF JUDGMENT
PURSUANT TO P ARC.P. 236
TO: ARTHUR L. FRITZ, JR.
1701 Hummel Avenue
Camp Hill, P A 17011 /I . (" I
PLEASE TAKE NOTICE that on the A day Of~, 2000, default
judgment in the above-captioned matter was entered against you in the amount of $97,222.28.
We are required pursuant to Rule 236 ofthe Pennsylvania Rules of Civil Procedure to
notify you of the entry of said Judgment and this shall constitute such notice.
c~~ K L~~
Prothonotary U
;,;~
,,_".~-_ ~ -~i ~~ _ ,-:, ~,,:--'-;_A~
~ """~ .~~--
- iv.. '-~~
__"_ --10"-' "","
'-
- - "-"~,~ ."--,
~CC"~ "
-
"C"',
":..,,,'
I
I
I
() c."? 0
C C,.::; un
-, J:::,,. "
e, nj -0
nl (~:
Z
~:.. C. , C I-'~
(.r) '." C'
-< c'";- (.!..,
-
r:;:U .:..::;'
.,~ "'D ,
p-- '-~ :~~!
~7L ) C)
::'::~C__, ~") ;--'1
.-'-""c.--::: '~J
Z ~~~
=< " ~::J
-:,:
"
.,
.".,--".
,
I
I
I
I
I
, .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION - LAW
ALTEGRA CREDIT COMPANY,
Plaintiff
)
)
)
) NO. 2000-176 Civil
)
)
)
)
)
vs.
ARTHUR L. FRITZ, JR.
Defendant
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$97,222.28
Interest from 4/11/00
to 12/6/00 at
$22.98 per diem
$ 5,492.22
Costs (to be added)
$
TOTAL DUE:
$
Date:
7 I~ /00
.
A~
Douglas . arinos, Esquire
Attorney for Plaintiff
101 North Cedar Crest Boulevard
Allentown, PA 18104
610-434-0504
I.D. No. 53104
"",',.",\,'" .. '.
".:,. ;''''-'<"-''';is,;.(~.,,,"
~Q
l~ r;.
~
~
tr'
---
w
--.)
.....p
~
~
?':-
;--
~
c-
o
Q0
()
~
~
-..
~
- .:.;. . ~ '
*w~
"-> ;C V) Lv .~
B8&~g
~ I I
p~
, '!J
::- '"
"~ ~
'Jf---c.,
,
,
,
,
-
. .
o
c-
~";;.
-CJ[{;
QJr:'
..::::.. 'i',
Z",
G-5t:;.
r;;;i:~:
-~-'
."
~Q
--c!
Pc:
:z;
=<
,.' _ u~
f.:)
C-'
"-
C-
(-..,
.'t-:
v
;.2);
"
:'i::
':::1 ~;~,
---i-.;
--'-!
:..::.~ (-)
,'.:-."':;rn
~
-<
f\.)
;-,)
<.0
~
""-,.-'-
L;s ~_ -~'<
_,",r__'
,",
,I
~
Ii
...
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION - LAW
ALTEGRA CREDIT COMPANY,
Plaintiff
)
)
)
) NO. 2000-176 Civil
)
)
)
)
)
i;
,:
vs.
ARTHUR L. FRITZ, JR.
Defendant
AFFIDAVIT PURSUANT TO RULE 3129.1
AItegra Credit Company, Plaintiff in the above-captioned action, sets forth as of the date
the praecipe for the writ of execution was filed the following infonnation concerning the real
property located at 1701 Hummel Avenue, Camphill, Lower Allen Township, Pennsylvania,
17011, more fully described in Exhibit "A" attached hereto.
1. Name and address of owners or reputed owners:
Arthur L. Fritz, Jr.
1701 Hummel Avenue
Camphill, P A 17011
2. Name and address of Defendants in the judgment:
Arthur L. Fritz, Jr.
170 I Hummel Avenue
Camphill,PA 17011
3. Name and address of every judgment creditor whose judgement is a record lien on
the real property to be sold:
AItegra Credit Company
116 Allegheny Center, IDC 23-521
First Floor
Pittsburgh, PA 15212
,-
,- ,". '~".-' - ~
-",.
J
"
The Patriot New Company
812 Market Street
P.O. Box 2265
Harrisburg, P A 17105
4.
Name and address of the last recorded holder of every mortgage of record:
Altegra Credit Company
116 Allegheny Center, IDC 23-521
First Floor
Pittsburgh, PA 15212
5. Name and address of every other person who has any record lien on the property:
Cumberland County Tax Claim
CUMBERLAND COUNTY COURTHOUSE
1 Courthouse Square
Carlisle, P A 17013-3387
Mary Ann Prior, Tax Collector
Lower Allen Township
1993 Hununel Avenue
Camphill, PA 17011
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:
N/A
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:
N/A
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. 94904 relating to unsworn falsification to authorities.
q
,
ii
I
I'
i,
::
:';
i
i'
i
1
I'
I
i,
I,
~ 'I
i
(,
I
I
I
;"
,
,
1
,
!
I
1,:
I:!
.""
I
July 5. 2000
DATE
BY:
, ~,_ ~ '" :'J' ",' ',. ". ___ ,.'." ~ . >,', ' '. '
'Ii
"
!
I
I
I
,
DOUGLAS M. MARINOS & ASSOCIATES, P.C.
OUGLAS M. M
Attorney for Pia. tiff
101 North Cedar Crest Blvd.
Allentown, P A 18104
(610) 434-0504
Attorney I.D. 53104
~ ~
-
'""" ~I
, '
Exhibit A
ALL TImT CERTAIN lot of land, eicu~te in Lower Allen Township, CumbRrland
County, Pennsylvania, more particularly bounded and doscribed as follows, to
wit.:
ON THE EAST by property, now or formerly, of J. C. Bucher; on the South by
lands. now or formerly, of Philadelphia. Harrisburg and Pittsburgh Railroad;
on the West by lands, now or formerl.y, of Mary E. Coleman; and on the North
by HUlllmel Avenue; containing in front of Hummel Avenue 35 feet, and extending
southwardly at an even width 65 feet, more or .Less, to lands, or r:he
Phildalphia. Harrisburg and Pittsburgh Railro~d;
1l1\V~NC: THEREON ERECTED a aingle two-story frame bungalow htJusc known and
numbered as 1701 Hummel Avenue, Lower Allen Townl:lhi.p, C1.\mberland County,
Pennsylvania.
DEING the same premi!les which Dorothy S. Nugent and Allen 1<:. Nugent, her
hllf.lband, by their deed dated April 10, 198'1 and recorded in the Cumbelrand
County Recorder of Deeds Office in Book P-32, Page 276, granted and conveyed
unto Garoge C. Stradtman and Jean R. Stradtman, his wife, Grantors her.ein.
I!IIIIilDi1-
Ii >Jiii;j'lW~
~~
~,*~");1Ii:il1>i~->l~~j;jiUo.'"",,,,-'lh!?"J!.t;"~ ...... -
()
C
;;::-~.
"1:Jf{
n1r-.-l
.z :T.,~
0~:~
rri
::-..::: -"
~()
,.-( -
Pc
~
:<:
-
\,
C)
C':)
S=
>~::
"'t
"'u
,"--,
,..;.(
:-'~'i()
-,--1',
~~~
~"::': [11
~~
N
r""
'D
. ,---'"0 -,' ,;;,., .' ~-
..
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION - LAW
ALTEGRA CREDIT COMPANY, )
)
Plaintiff )
) NO. 2000-176 Civil
vs. )
)
ARTHUR L. FRITZ, JR. )
)
Defendant )
NOTICE OF SHERIFF'S SALE OF REAL EST A TE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2
TO DEFENDANT: ARTHUR L. FRITZ, JR.
1701 Hummel Avenue
Camphill,PA 17011
TAKE NOTICE:
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: December 6, 2000
TIME: 10:00 a.m.
LOCATION: Cumberland County Courthouse
1 Courthouse Square
Media, PA 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
primarily 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 EXHIBIT "A"
ATTACHED)
. , "~~.;, c , "
"^
THE LOCATION of the property to be sold is:
1701 Hununel Avenue
Camphill, Cumberland County
Pennsylvania
THE JUDGMENT under or pursuant to which the property is being sold is docketed in the
within Commonwealth and County to:
No. 2000-176 Civil
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of the property are:
Arthur L. Fritz, Jr.
1701 Hununel Avenue
Camphill,PA 17011
A SCHEDULE OF DISTRIBUTION, being a list ofthe persons and/or governmental or
corporate entities or agencies being entitled to receive part ofthe proceeds of the sale received
and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities
that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless
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 the within County.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF THE
PROPERTY.
IT HAS BEEN ISSUED BECAUSE YOU HAVE AN INTEREST IN THE PROPERTY
WHICH MAY BE AFFECTED BY THE SALE.
Your may wish to attend the sale to protect your interest in the property. A lawyer can
advise you more specifically of these rights.
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
2
I 0 .~ "
,.," -,"'>'"'" ;,- , .~, '. . '
",
- I.
~- '..
'I;'
,
i.;
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL
ADVICE.
LAWYER REFERENCE SERVICE
Court Administrator, 4th Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(717)240-6200
THE LEGAL RIGHTS YOU MA Y HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to
open judgment if your 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 Sheriffs Sale you may file a petition with the Court of Common Pleas of
the within 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 the within 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 form the Court
Administrator's Office - Civil Division, of the within County Courthouse, before a presentation
of the petition to the Court.
DOUGLAS M. MARINOS & ASSOCIATES, P.C.
BY:
Douglas M inos, Esquire
Attorney for Plaintiff
3
. -~-
1.-.
,. . , "-
Exhibit A
ALL THAT CERTAIN lot ot: land, Elicu~te in Lower Allen Township, Cumbttrland
County, Pennsylvania, more particularly bounded and dascribed as follows, to
wir.:
ON THE EAST by property, now or formerly, of J. C. Bucher; on the South by
lands, now or formerly, of Philadelphia, Harrisburg and Pittsburgh Railroad;
on the West by lands, now or formerJ.y, of Mary E. Coleman; and on the North
by Hummel Avenue; containing in front of Hummel Avenue )5 feet, and extending
souchwardly at an even width 85 feet, more or .Less, to lands, r.>f r.he
Phildalphia. Harrieburg and Pittsburgh Railroad;
IlJ\VING THEREON ERECTED a aingle two-scary frame bungalow house known and
numbered as 1701 Hummel Avenue, Lower Allen Townl:lhi.p, Cumberland County,
Pennsylvania.
DEING the same premises which Dorothy S. Nugent and Allen 1<' Nugent, her
husb;:md, by cheir deed dated April 10, 198'/ and recorded in the Cumbelrand
County Recorder of Deeds Offiee in Book P-32, Page 276, granted and conveyed
unto Garege C. Stradtman and Jean R. Stradtman, his wife, Grantors her.ein.
~~""""~_Jijll*_U
'&Li/lII!liIlhli!,~"'"'''''dd"j~)I!J'''Ii!!!;,,~r;;;~,J..''''''' ,~.....
.lllllllllli
o
~;
:~I
~e"
=2: C)
5>8
2:
~
-<
"" ~'.
'Hi
"
',,",
c5
()
,
,
,::::::
'::!
~"'O
:"""::::
"
c-., r-
~"~i()
~ -r,
,~~;i~
~
p,~
:0
-<;
~~~
::.v
<:;)
.- , ..~. ,~~ ~ ^ , '
- ~~
. -<.;;-,
, _~_" " ,,:I
- - '>'." ... '.~-.
~-,
I
L,
.L
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION - LAW
ALTEGRA CREDIT COMPANY,
Plaintiff
)
)
)
) NO. 2000-176 Civil
)
)
)
)
)
vs.
ARTHUR L. FRITZ, JR.
Defendant
AFFIDAVIT OF SERVICE
I, Douglas M. Marinos, Esquire, state that I am the attorney responsible for representing
Plaintiff, AItegra Credit Company ("Altegra"), and that I am authorized to make this affidavit on
Plaintiffs behalf.
1. On August 31, 2000, the Cumberland County Sheriff served the Defendant,
Arthur L. Fritz, Jr., with written notice of the Sheriffs sale ofreal property scheduled for
December 6, 2000 in the above-captioned action by first-class mail, postage prepaid, to his
addresses set forth in Plaintiffs affidavit pursuant to Pa.R.C.P. 3129.1. Service was complete
upon receipt of the notice on August 31, 2000. A true and correct copy of the notice and the
Cumberland County Sheriffs Certificate of Service thereof are attached hereto, made a part
hereof, and marked, collectively, as Exhibit "A".
2. On July 6, 2000, I served AItegra Credit Company with written notice ofthe
Sheriffs sale ofreal property scheduled for December 6, 2000 in the above-captioned action by
<,
p
ordinary mail, postage prepaid, to the address set forth in Plaintiffs affidavit pursuant to
Pa.R.C.P.3129.1. Service was complete upon the mailing of the notice on July 6, 2000 as set
forth in the United States Postal Service Certificate Of Mailing attached hereto. A true and
correct copy of the notice and the United States Postal Service Certificate of Mailing thereof are
attached hereto, made a part hereof, and marked, collectively, as Exhibit "B".
3. On July 6, 2000, I served The Patriot New Company with written notice of the
Sheriffs sale of real property scheduled for December 6, 2000 in the above-captioned action by
ordinary mail, postage prepaid, to the address set forth in Plaintiffs affidavit pursuant to
Pa.R.C.P. 3129.1. Service was complete upon the mailing ofthe notice on July 6, 2000 as set
forth in the United States Postal Service Certificate Of Mailing attached hereto. A true and
correct copy of the notice and the United States Postal Service Certificate of Mailing thereof are
attached hereto, made a part hereof, and marked, collectively, as Exhibit "C".
4. On July 6, 2000, I served Cumberland County Tax Claim Bureau with written
notice of the Sheriffs sale ofreal property scheduled for December 6, 2000 in the above-
captioned action by ordinary mail, postage prepaid, to the address set forth in Plaintiffs affidavit
pursuant to Pa.R.C.P. 3129.1. Service was complete upon the mailing of the notice on July 6,
2000 as set forth in the United States Postal Service Certificate Of Mailing attached hereto. A
true and correct copy of the notice and the United States Postal Service Certificate of Mailing
thereof are attached hereto, made a part hereof, and marked, collectively, as Exhibit "D".
,",."
". "" ,,;,,;,~ ~,~_, --, . c." "
C''''-',
0.',..
,t" "',"",_'
.
I
.'
5. On July 6, 2000, I served Mary Ann Prior, Tax Collector with written notice of
the Sheriff's sale ofreal property scheduled for December 6, 2000 in the above-captioned action
by ordinary mail, postage prepaid, to the address set forth in Plaintiff's affidavit pursuant to
Pa.R.C.P. 3129.1. Service was complete upon the mailing ofthe notice on July 6, 2000 as set
forth in the United States Postal Service Certificate Of Mailing attached hereto. A true and
correct copy of the notice and the United States Postal Service Certificate of Mailing thereof are
attached hereto, made a part hereof, and marked, collectively, as Exhibit "E".
I verify that the statements made in this Affidavit of Service are true and correct to the
best of my knowledge, information and belief. I understand that false statements made herein are
subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities.
Dated: December 4, 2000
L!:d:.,f! ~
I.D. No. 53104
101 N. Cedar Crest Blvd.
Allentown, PA 18104
(610) 434-0504
-
- .~
.... '''''''"''""
"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW
AL TEGRA CREDIT COMPANY, )
)
Plaintiff )
) NO. 2000-176 Civil
vs. )
)
ARTHUR L. FRITZ, JR. )
)
Defundant )
NOTICE OF SHERIFF'S SALE OF REAL EST ATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2
TO DEFENDANT: ARTHUR L. FRITZ, JR.
1701 Hummel Avenue
Carnphill, P A 170 II
TAKE NOTICE:
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: December 6, 2000
TIME: 10:00 a.m.
LOCATION: Cumberland County Courthouse
I Courthouse Square
Media, PA 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
primarily ofa 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 EXHIBIT lOA"
ATTACHED)
,
.k,
_\ t _" f'".
THE LOCATION of the property to be sold is:
1701 Hummel Avenue
Camphill, Cumberland County
Pennsylvania
THE JUDGMENT under or pursuant to which the property is being sold is docketed in the
within Commonwealth and County to:
No. 2000-176 Civil
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of the property are:
Arthur L. Fritz, Jr.
1701 Hummel Avenue
Camphill, PA 17011
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities
that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless
someone objects by filing exceptions to it within ten (l0) 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 the within County.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF THE
PROPERTY.
IT HAS BEEN ISSUED BECAUSE YOU HAVE AN INTEREST IN THE PROPERTY
WHICH MAY BE AFFECTED BY THE SALE.
Your may wish to attend the sale to protect your interest in the property. A lawyer can
advise you more specifically of these rights.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
2
rll'
.'
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL
ADVICE.
LAWYER REFERENCE SERVICE
Court Administrator, 4'" Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(717)240-6200
THE LEGAL RIGHTS YOU MA Y HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to
open judgment if your 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 Sheriffs Sale you may file a petition with the Court of Common Pleas of
the within 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 the within 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 form the Court
Administrator's Office - Civil Division, of the within County Courthouse. before a presentation
of the petition to the Court.
DOUGLAS M. MARINOS & ASSOCIATES, P.C.
BY:
Douglas M inos, Esquire
Attorney for Plaintiff
3
,,~
""
-,,"--",
Exhibit A
Al.L 'THAT CERTAIN lot of land. aicu:lte in Lower Allen Township, Cumbarland
COUIlty, Pennsylvania. more parcicularly bounded and described as follows. co
wit::
ON THE EAST by property, now or formerly, of J. C. Bucher; on the Souch by
lands. now or formerly. of Philadelphia. Harrisburg and ~ittsburgh Railroad;
on the West by lands. now or formerly. of Mary E. Coleman; and on the North
by Hummel Avenue; containing in front of Hummel Avenue 35 feet. and extending
Bouchwardly at an even width 85 feet. more or .less. to lands. r"r r.he
Phildalphia. Harrisburg and PittRhurgh Railroad;
ll1\vnm THEREON ERECTED a sIngle two-scory frame bungalow house known and
nl\mbered as 1701 Hummel Avenue, Lower Allen TownshIp, Cumberland County,
L>Qnnsylvania.
DE:ING the same premi!les which Dorothy S. Nugent and Allen K. Nugent. her
huab;:md. by chair deed dated April 10, 199'1 and recorded in the Cumbelrand
County Recorder of Deeds office in Book P-32, Page 276, granted and conveyed
unto Garoge C. Scradtman and Jean R. Stradtman. his wife. Grantors her.ein.
.
j
~....,,,-"'
~< ~
---------
.......
')
AItegra Credit Company In the Court of Common Pleas of
-vs- Cumberland County, Pennsylvania
Arthur L. Frit::3>'/ No. 2000-176 Civil
awn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on August 31, 2000 at
5:28 o'clock P.M. EDST she served a true copy ofreal Estate Writ Notice and Description in the above
entitled action upon the wihtin named defendant to wit: Arthur L. Fritz Jr. by making known unto Arthur
Fritz Jr at 82 Linda Drive # 52, Mechanicsburg, Cumberland County, Pennsylvania its contents and at
the same time handing to him personally the said true and attested copies of the same.
Brian M. Barrick, Deputy Sheriff, who being duly sworn according to law, says on October 12,2000
at 7:31 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the
property of Arthur L. Fritz Jr. located at 1701 Hummel Avenue, Lemoyne 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 Sheriff mailed a notice of the
pendency of the action to the defendant Arthur L. Fritz Jr. by regular mail to his last known address 82
Linda Drive # 52, Mechanicsburg, P A. This letter was mailed under the date of October 13, 2000 and
never returned to the Sheriff's Office.
S~ _tfP~
R. Thomas Kline, Shen~
By f2j;;..~~ 9j_~
Real Estate Deputy
. "
;/. .
-- -\--,
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Altegra Credit Company
116 Allegheny Center, IDC 23-521
First Floor
Pittsburgh, PA 15212
FROM: Douglas M. Marinos & Associates, P.C.
101 North Cedar Crest Blvd.
Allentown, PA 18104
OWNER: ARTHUR L. FRITZ, JR.
PROPERTY: 1701 Hummel Avenue, Camphill,
Cumberland County, Pennsylvania
2000-176 Civil
The above-captioned property is scheduled to be sold at the Cumberland County Sheriffs
Sale on December 6, 2000, at 10:00 a.m. at the Cumberland County Courthouse, I Courthouse
Square. Media, PA 17013. Our records indicate that you may hold a mortgage or judgment on
the property which will be extinguished by the sale. You may wish to attend the sale to protect
your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff
not later than thirty (30) days after sale. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule.
l#-"!l: 1: '. ,_..'~ '.\ i< "
p-"p--~-~ --
;"~~ ~
, ,j.'....../\f
,
~'
<: -- ~
C-/
/
686 L . JOW . LL 8t WJO~ Sd
ZIZSI Yd '~qsP!d
mOH lO'!..I
IZS-(Z;)ill 'l:llU:l;) AU:lqB:l!IY 9[ [
4 ANY dWO;) HQffi!;) VdDanV
~\<>-:. :01. peSSEuppe 1I8W A18U!pJO II) eOBld euo
VO ISI V d 'UM.OlUIl\lY
pJllAIl[nog lSIlJ:) Jllpll:) l{lloN 101
~ ")'<1 '')qrVDOSSV
~SONrnVW'WSVIDnOa
<:JJ~nbs3: 'SOU!Jt?W .W S'RI~noawOJ::l peA!&OBij
ij31S'tfVIIJ.SOd ~ON'tfynSNI YO::! 3Q,^OYd
J.ON 8300 'l1VW lVNOll VNij31NI ONV ~US3woa ),:10.::1 Q3sn 39 ~ ~V11
DNI1I'lf1l\l :10 3.L'lfOI:lI.LH30 .OIA.'S 1'o'lS0d S n
~~ """~=, ~,-
Exhibit A
ALL 'tHAT CERTA.IN lot of land, eituJ.te in Lower A.llen Township, Cumbarland
County, Pennsylvan.ia, more particularly bounded and dascribed as follo....s. to
wir. :
ON THE EAST by property. now or formerly, of J. C. Bucher; on the South by
lands. now or formerly, of Philadelphia, Harrisburg and Pittsburgh Railroad;
on the West by lands. now or formerly, of Mary E. Coleman; and on the North
by Hummel Avenue; containing in front of Hummel Avenue 35 feet, and extending
southwardly at an even width as feet, more or less. to lands, ,~r r.he
Phildalphia. Harrisburg and Pit~shurgh Railroad;
!lAVING THEREON ERECTED a alngle
numbered as 1701 Hummal lI.venue.
pennsylvania.
two-story frame bungalow house known and
Lower Allen Townahi.p. Cumberland County.
DEING the same premises which Dorothy S. Nugent and Allen K. Nugent. her
hUllbJ.nd. by cheir deed dated April 10, 198'1 and recorded in the Cumbelrand
County Recorder of Oeeds Office in Book P-32, Page 276. granted and conveyed
unto GAroge C. Stradtman and Jean R, Stradtman, his wife, Grantors he1.'e1n.
",
,-- -
,[
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: The Patriot New Company
812 Market Street
P.O. Box 2265
Harrisburg, P A 17105
FROM: Douglas M. Marinos & Associates, P.C.
101 North Cedar Crest Blvd.
Allentown, P A 18104
OWNER: ARTHUR L. FRITZ, JR.
PROPERTY: 1701 Hummel Avenue, Camphill,
Cumberland County, Pennsylvania
2000-176 Civil
The above-captioned property is scheduled to be sold at the Cumberland County Sheriffs
Sale on December 6, 2000, at 10:00 a.m. at the Cumberland County Courthouse, 1 Courthouse
Square. Media. PA 17013. Our records indicate that you may hold a mortgage or judgment on
the property which will be extinguished by the sale. You may wish to attend the sale to protect
your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff
not later than thirty (30) days after sale. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule.
686\ 'JOW 'Ll8e WJO~ Sd
-: ,'{:,;~ -'l ~'. -Ot .
~o I L I V d 'JJlnqslll1!H
S~ll JIBe 0 d
1~~lIS 1~)jl1!W c: I S
,(~<J~vJ M."N IO!.Il1!d ~4.l
.~, :~:
-.,,::.: i?:" /"1
.,! ~ :,,-(.,}:,.,"
,.i:Jl \--" i,.' ',,+'
::'~.~..'.'!_i~~~~: ~/.-..
..,..,.. .. ') (~'<-
.:,?::~~~~~:~{lm:, ,~~\~,
, !t."h .~..." '- ,~.]::-' \ '"
.', I,) I-:~,.;>-~;.~\j,.nr::: ~\"
'.:'~,):~:_~~~~~~a..~. "~.!
,'" /...~\'" ~\
.'); ..
""',
-.. /
" .
;O~ pSSS6Jppll l!ew AJBU!PJO jO 8~!d e
..}
" ).
,
."
\79[81 Vd 'tI~o~"I';?nv
pJllA~tnOa IS~l:) 11!p~:) 4jloN [0 I
':)'d 'S~.l\;'J:)055v
~ SONnIVW 'W SV'1DflOa 'M'"
~J!nbS3 'SOU!JllW 'W Sll[llnoa oWO'; p . "
1:I3J.SVW.1S0d 3:)NVl:InSNI 1:I0~ 3QIAOl:ld
.10N S300 '1IVW 1VN0I.1'fNl:I3J.NI ONV 01.1S31/1100 1:I0~ 03sn 38 ~~V\l
FlNI1.'O'1/II :10 3l. 'O':lI:lIl.H3:l 30'^"3S 1nSOd S n
}
41
~l
_." J
E:<hibilA
ALL THAT CER1'AIN lot of land, aitu.:lte in Lower Allen Township, Cumbtlrland
COUIl~Y. Pennsylvan:ia, more particularly bounded and described as follows, [;0
wir. :
ON TH8 EAST by property, now or formerly, of J. C. Bucher; on the South by
lands, now or formerly, of Philadelphia, Harrisburg and Pittsburgh Railroad;
on the West by lands. now or formerly, of Mary E. Coleman; and on the North
by Hummel Avenue; containing in front of Hummel Avenue 35 feet, and extending
southwardly at an even width 85 feet, more or .Less, t(~ lands, (~C r.he
Phildalphia. Harrisburg and Pit~5hurgh Railroad;
Ill\VING THEREON ERECTED a sIngle two-story frame bungalow house known and
numbered as 1701 Hummal 1\venue, Lower Allen Townahi.p, Cumberland Counl:y,
pennsylvania.
DEING the same premises which Dorothy S, Nugent and Allen K. Nugenl:, her
husb;md, by their deed dated April 10, 198'1 and recorded in the Cumbelrand
County Recorder of Deeds Office in Book P-32, Page 276. granted and conveyed
un~o Garoge C. Stradtman and Jean R, Stradtman, his wife, Grantors her.ein.
"
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Cumberland County Tax Claim
CUMBERLAND COUNTY COURTHOUSE
I Courthouse Square
Carlisle, PA 17013-3387
FROM: Douglas M. Marinos & Associates, P.c.
101 North Cedar Crest Blvd.
Allentown, P A 18104
OWNER: ARTHUR L. FRITZ, JR.
PROPERTY: 1701 Hummel Avenue, Carnphill,
Cumberland County, Pennsylvania
2000-176 Civil
The above-captioned property is scheduled to be sold at the Cumberland County Sheriffs
Sale on December 6, 2000, at 10:00 a.m. at the Cumberland County Courthouse, 1 Courthouse
Square, Media, PA 17013. Our records indicate that you may hold a mortgage or judgment on
the property which will be extinguished by the sale. You may wish to attend the sale to protect
your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff
not later than thirty (30) days after sale. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule.
686L 'J8W 'LL8E WJO~ Sd
L.8EE-HOL.I Vd ':l\S!(Jll;)
a:HJRhg e~Re~RgJ 1
:lSnOl{l.1no;) Aluno;) PUll(J:lqwn;)
W!t:IJ A~..1 tC.,.UlIVJ pU~P"'''IWIIJ
:Ol peSS8Jppe IIBW AlBU!PJO jO 8::l8!d suo
~ ~',
" ~ .~} c..)
> - ,
'] ~'-.../
'UM.OlU;J
pJllA;llnog )S:lJ;) Jllp:l;) ljlloN [0 I
';).a '~:U.VDO~~V
?,? SONnIVW .W SV,DflOa
~IJ!nbs'3 'SOU!J'BW .W Sel13noa :WOJ.::l p8A!8:Jey
lB.LSVWl.SOd 30N'lflmSNI YO:::! 301^OYd
LON 8300 "I'o'W 1VNOLLVNI:I31.NI aNY Oll.S3WQa 1:10::1 Q3Sn 38 AVW
DN.,IY :10 3.LYOI:lI.LH30 331A"3S W1S0d 's'n
, ,
, .t
..
-.....""'''-
"
Exhibit A
ALL THAT CERTAIN lot of' land, eiCU.:Ite in Lower Allen Township, Cumbarland
County, Pennsylvania, more parcicularly bounded and described as follows. co
wir. :
ON THE EAST by property, now or formerly, of J. C. Bucher; on the Souch by
lands. now or formerly, of Philadelphia, Harrisburg and Pittsburgh Railroad;
on the Weet by lands, now or formerly, of Mary E. Coleman; and on the North
by Hummel Avenue; containing in front of Hummel Avenue 35 feet, and extending
eouchwardly at an even width 65 feet. more or less, tr" lands, Q[ the
Phildalphia. Harrisburg and Pit~sburgh Railro.:ld;
.
HAVING THEREON ERECTED a alngle two-story frame bungalow house known and
numbered as 1701 Hummel Avenue, Lower Allen TownshIp, Cumberland County,
I!ennsylvania.
DEING thE! same premises which Dorothy S. Nugent and Allen K. Nugent. her
hUflb<lnd, by cheir deed dated April 10, 198'/ and recorded in the Cumbelrand
County Recorder of Deeds office in Book P-32. Page 276, granted and conveyed
unto Garoge C, Scradtman and Jean R. Stradtman, his wife. Grantors her.ein.
, .
,-~
ill!"_
'.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Mary Ann Prior. Tax Collector
Lower Allen Township
1993 Hummel Avenue
Camphill, PA 17011
FROM: Douglas M. Marinos & Associates, P.c.
101 North Cedar Crest Blvd.
Allentown, P A 18104
OWNER: ARTHUR L. FRITZ, JR.
PROPERTY: 1701 Hummel Avenue, Camphill,
Cumberland County, Pennsylvania
2000-176 Civil
The above-captioned property is scheduled to be sold at the Cumberland County Sheriffs
Sale on December 6, 2000, at 10:00 a.m. at the Cumberland County Courthouse, I Courthouse
Square, Media, PA 17013, Our records indicate that you may hold a mortgage or judgment on
the property which will be extinguished by the sale. You may wish to attend the sale to protect
your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff
not later than thirty (30) days after sale. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule.
686 L . Jew . LL 8& WJO~ Sd
'_,.;1..,..\....;.,'.(...,
[lOLl Yd'll!l(dwll:)
~lIU~^V [~wwnH (661
d!l(SUMO.l U::lllY J::lMO,
lOP::lllo:) Xll.l 'lO!ld uuY ,\,I1lW
,;
:01 peSB9Jpp8 lIew AlIIUIPJo JO 6:19!d suo
<:':':
tOl8[ Yd 'UMOlU::lllV
plM"[nog lS::ll:) Jllp::l:) l(UON [0 I
":)',.:( 'c;;:q T \7T)OS~V
?,? SONnlYW 'W SY'lDflOa
;'1~nbs3 'SOU~JHW 'W S'e13noQ :WOJ;:I pa^!9:19l::1
l::I31S~lSOd 30NVI:mSNll::IO=' 3QI^Ol:ld
.ON S300 '1IVW lVNOIlVNI::I31.NI ONV OUS3WOO 1::10:1 03sn 38 Am
9NI11'O'W :10 3.1'0'01:111.1:130 301^"3S 1'o'~SOd 's'n
~~.} ::::; ......i
.>..,-. ,
",[;1.//
~ ~ L. ~'~~"'"
"
'.
Exhibit A
ALL THAT CERTA.IN lot of land, slcu~te in Lower Allen Township, Cumbnrland
Coun~y, Pennsylvania, more parcicularly bounded and doscribed as follows. to
wir.:
ON THE EAST by property, now or formerly, of J. C. Bucher; on the Souch by
lands. now or formerly, of Philadelphia. Harrisburg and Pittsburgh Railroad;
on the West by lands, now or formerly, of Mary E. Coleman; and on the North
by Hummel Avenue; containing in front of Hummel A.venue 35 feet, and extending
souchwardly at an even width as feet, more or less, t(~ lands, r~C rohe
Phildalphia, Harrisburg and Pit~ahurgh Railroad;
IlI\VING THEREON ERECTED a alngle two-scory frame bungalow house known and
numbered as 1701 Hummel lI.venue, Lower Allen Townahi.p, Cumberland Coun~y,
LJcnnsylvania.
DE:ING che same premi!les which Dorothy S. Nugent and Allen K. Nugen~, her
husb.md. by cheir deed dated April 10, 198'1 and recorded in the Cumbelrand
County Recorder of Deeds Office in Book P-32, Page 276. granted and conveyed
unto Garoge c. Scradtman and Jean R. Stradtman, his wife, Grantors her.ein.
_~iI:l&i"" ~- ~"'IlIIfil.ll!_~~;Wr<ili,;,e~"ia.5l""",,~IWl;!~~L,~ ~1lliiill.l:I.A
~ ^ ~
.-
_l
L__
~- .
.h,
~,
.,
"""~" ~-~,-,-. -.....
0 0 -,
C C~) ~'-1
$: ;::::;t
-rJ(TJ 1";:'1 "
rn~.::J (-) ~:
2".>-1
~)~ I -", ,--"
_:"~ ::,j
<J'; ;;.~";, ,
-<..+~ '---~(")
~[~) "T.I ~t~~
~O .3:
>,0 N
c ~i
z c:- 5i
=< Ul -<
.
M'- .,
"" ,. ~~
.-,1 ~
,,- ,-.,- - " "'"k" _,., ;~" -1_"
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} SS.
Robwer P Ziegler
~ ______________________________________________________________________________Flecorderof
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ________________
Altegra Credit Co
________________________________________________ ____________________________________ is the grantee
the same having been sold to said grantee on the _____~_:~______________________________________ day of
December 2000
________________________________________ A. D., l~_____, under and by virtue of a writ______________
Execution 14th
________________ _____ _______________ __ ___ ___ ___ _ issued on the __________ ___ ___________ __ __ _________
July , =2000 .
day of ______________u__________ A. D., l~______, out of the Court of Cornman Pleas of saId County as of
Civil 2000
____________________________ __.'__ ___ __ ___ _____ __ __ _______ ___ _______n_ __ ________ _ Term, nt______
t76 ,Altegra Credit Co
Nwnber ______________, at the SUit of ______________________________________________________________-
___________ _____ _______ ________ ____ againsL_ ___ _~!?:'!:._~_~r:~!::__~~_ __ __________ __ __ ____ ___ is
duly recorded in Sheriff's Deed Book No. _~_~~_______, Page __~:_~______.
IN TESTIMONY WHEFlEOF, I have hereunto
set my hand and seal of said office this _.l~~__ day
of --4~-;j~---}t"~~q-=
---------------~~~~
Recorder of Deeds. Cumberland County, Canisle. PA
My Commission Expires the Fil1l Monda, of Jan. 2002
I I
'~'""
Altegra Credit Company
-vs-
Arthur L. Fritz, Jr.
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 2000-176 Civil
Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on August 31, 2000 at
5:28 o'clock P.M. EDST she served a true copy ofreal Estate Writ Notice and Description in the above
entitled action upon the wihtin named defendant to wit: Arthur L. Fritz Jr. by making known unto Arthur
Fritz Jr at 82 Linda Drive # 52, Mechanicsburg, Cumberland County, Pennsylvania its contents and at
the same time handing to him personally the said true and attested copies of the same.
Brian M. Barrick, Deputy Sheriff, who being duly sworn according to law, says on October 12,2000
at 7:31 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the
property of Arthur L. Fritz Jr. located at 1701 Hummel Avenue, Lemoyne 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 Sheriff mailed a notice of the
pendency of the action to the defendant Arthur L. Fritz Jr. by regular mail to his last known address 82
Linda Drive # 52, Mechanicsburg, P A. This letter was mailed under the date of October 13, 2000 and
never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice
had been given according to law, exposed the above described premises at public venue or outcry at
Court House, Carlisle Cumberland County, Pennsylvania on December 6, 2000 at 10:00 o'clock A.M.
EDST and sold the same for the sum of $ 1.00 to Attorney Douglas M. Marinos for Altegra Credit
Company. It being the highest bid and best price quoted for the same Altegra Credit Company of 116
Allegheny Center, !DC 23-521 First Floor, Pittsburgh, Pa being the buyer in this execution paid to
SheriffR. Thomas Kline the sum of$ 690.92 it being costs.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
County
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff s Deed
30.00
13.84
15.00
15.00
30.00
10.00
.50
1.00
14.88
1.60
15.00
20.00
232.85
216.60
23.15
25.00
26.50
$690.92 Pd By Atty
12/08/00
I J
I ~""""",,"".i
Sworn and Subscribed To Before Me
This-u> ~ Day of ~
2000,A.D.(lL..JlInJjl,,~~
"Pfottnotary
soan~~
-Qomas Kline, Shenff
BY~'~-(ltt;
Real~state Deputy
~-u -1 (..
I. Jb'1 ':Jot.,
cJv JIJ5
~
,'"" -
,1-'
.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing
under the laws 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 Pennsylvania, owner and publisher of The
Patriot-News and The Sunday 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, 1854, and September 18th, 1949, respectively, and all 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 daily and/or Sunday/ Metro editions which appeared on the 31 st day of October and the 7th and 14th
day(s) of November 2000. 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 unanimousiy passed and
adopted severally by the stockholders and board of di,rectors of the said" co:~y and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Me ellaneous Book "M",
V;I;;~I~:~~~~' ..............................c;..........................................................
COpy Sworn to and subscribed before me this 1st day of ece er 2000 A.D.
S ALE #5
Nota~.1 Seal
Tarry L. Aussell, Notary Public
Harrisburg, Dauphin County
My Commission Expires June 6, 2002
Member, Pennsylvania Association ot Notaries
NOTARY PUBLIC
My commission expires June 6, 2002
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) $
~~ $
215.10
1.50
216.60
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sunday 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....................................................................
,t~
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL'
(Under Act No. 587, approved May 16,1929), P. L.1784
STATE OF PENNSYLVANIA :
SS.
COUNTY OF CUMBERLAND :
Roger M. MorgenthaI, Esquire, Editor ofthe 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 official legal
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 hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
OCTOBER 27, NOVEMBER 3,10,2000
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 not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place ang character of publication are true.
REAL ESTATE SALE NO. 5
~ditor .......
Wrtt No. 2000-176 Civil
Altegra Credit Company
vs.
Arthur L. Fritz, Jr.
Atty.: Douglas M. Martnos
Exhibit A
ALL THAT CERTAIN lot of land.
situate in Lower Allen Township,
Cumberland County, Pennsylvania.
more particularly bounded and de-
serthed as follows. to wit:
ON TIlE EAST by property. now
, or formerly I of J. C. Bucher; on the
South by lands. now or formerly, of
Pw1a.de1pbia. Harrisburg and Pitts-
burgh Railroad; on the West by
lands. now or formerly. of Mary E.
Coleman; and ou the North by Hum-
mel Avenue: containing in front of
-- -'.- ----'".~................_-.--.--.--_.-,..,..------
SWORN TO AND SUBSCRIBED before me this
10 day of NOVEMBER. 2000
NOTARIAL SEAL
LOIS E. SNYDER. Notofy PubIc
Carlitl. Bore, Cumberland Counly, 'A
My Commiuion Expires March .5. 2001
"'.
,-,
k ~
'J!
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CIVIL DIVISION - LAW
AL TEGRA CREDIT COMPANY,
Plaintiff
)
)
)
) NO. 2000-176 Civil
)
)
)
)
)
vs.
ARTHUR L. FRITZ, JR.
Defendant
AFFIDAVIT PURSUANT TO RULE 3129.1
AItegra Credit Company, Plaintiff in the above-captioned action, sets forth as of the date
the praecipe for the writ of execution was filed the following infonnation concerning the real
property located at 1701 Hummel Avenue, Camphill, Lower Allen Township, Pennsylvania,
17011, more fully described in Exhibit lOAn attached hereto.
1. Name and address of owners or reputed owners:
Arthur L. Fritz, Jr.
1701 Hummel Avenue
Camphill, P A 17011
2. Name and address of Defendants in the judgment:
Arthur L. Fritz, Jr.
1701 Hummel Avenue
Camphill, PA 17011
3. Name and address of every judgment creditor whose judgement is a record lien on
the real property to be sold:
. Altegra Credit Company
116 Allegheny Center, !DC 23-521
First Floor
Pittsburgh, P A 15212
.,
, ,~
.
The Patriot New Company
812 Market Street
P.O. Box 2265
Harrisburg, PA 17105
4. Name and address of the last recorded holder of every mortgage ofrecord:
Altegra Credit Company
116 Allegheny Center, !DC 23-521
First Floor
Pittsburgh, PA 15212
5. Name and address of every other person who has any record lien on the property:
Cumberland County Tax Claim
CUMBERLAND COUNTY COURTHOUSE
1 Courthouse Square
Carlisle, PA 17013-3387
Mary Ann Prior, Tax Collector
Lower Allen Township
1993 Hummel Avenue
Camphill, PAl 70 11
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:
N/A
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:
N/A
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge or infonnation and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities.
Julv 5. 2000
DATE
BY:
. ~
-~.,
DOUGLAS M. MARINOS & ASSOCIATES, r.c.
UGLAS M. M
Attorney for Pia' tiff
101 North Cedar Crest Blvd.
Allentown, P A 18104
(610) 434-0504
Attorney J.D. 53104
'~_k.'
-'
Exhibit A
ALL 'THAT CERTA.IN lot of land, alcu(lte in Lower Allen Township, Cumbllrland
County, Pennsylvan~a, more particularly bounded and doscribed as follows, to
wit::
ON THE EAST by property, now or formerly, of J. C. Bucher; on the South by
lands, now or formerly, of Philadelphia, Harrisburg and Pittsburgh Railroad;
on the West by lands, now or formerly, of Mary E, Coleman; and on the North
by Ilumn\el Avenue; containing in front of Hummel Avenue 35 feet, and extending
southwardly at an even width Bs feet, more or .less, to lands, ,,,{ r:he
Phildalphia, Harrisburg and Pittsburgh Railroad;
!lAVING THEREON ERECTED a alngle two-story frame bungalow house known and
numbered as 1701 Hummel I\venuE!, Lower Allen Townahi.p, Cumberland County,
Pennsylvania.
DEING the same premises which Dorothy S, Nugent and Allen K. Nugent, her
hlJRb(lnd, by their deed dated April 10, 19B'1 and recorded in the Cumbelrand
County Recorder of Deeds office in Book P-32, Page 276, granted and conveyed
unto Geroge C. Stradtman and Jean R. Stradtman, his wife, Grantors heT.sin.
,
~ ~
.
""""...L__..,j~_
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION - LAW
AL TEGRA CREDIT COMPANY, )
)
Plaintiff )
) NO. 2000-176 Civil
vs. )
)
ARTHUR L. FRITZ, JR. )
)
Defendant )
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2
TO DEFENDANT: ARTHUR L. FRITZ, JR.
1701 Hummel Avenue
Carnphill, PA 17011
TAKE NOTICE:
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: December 6, 2000
TIME: 10:00 a.m.
LOCATION: Cumberland County Courthouse
1 Courthouse Square
Media, PA 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
primarily 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 EXHIB1T "^"
ATTACHED)
'.
.-.
._.._1
~~
.
THE LOCATION of the property to be sold is:
1701 Hwnmel Avenue
Camphill, Cumberland County
Pennsylvania
THE JUDGMENT under or pursuant to which the property is being sold is docketed in the
within Commonwealth and County to:
No. 2000-176 Civil
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of the property are:
Arthur L. Fritz, Jr.
170 I Hummel Avenue
Camphill, P A 17011
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or govemmental or
corporate entities or agencies being entitled to receive part of the proceeds ofthe sale received
and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities
that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless
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 the within County.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF THE
PROPERTY.
IT HAS BEEN ISSUED BECAUSE YOU HAVE AN INTEREST IN THE PROPERTY
WHICH MAYBE AFFECTED BY THE SALE.
Your may wish to attend the sale to protect your interest in the property. A lawyer can
advise YOLl more specifically of these rights.
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
2
,
~ ~=L~,""",,,,:v
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL
ADVICE.
LA WYER REFERENCE SERVICE
Court Administrator, 4'h Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(7 I 7)240-6200
THE LEGAL RIGHTS YOU MA Y HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within COWIty to
open judgment if your 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 Sheriffs Sale you may file a petition with the Court of Common Pleas of
the within 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 the within 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 form the Court
Administrator's Office - Civil Division, of the within County Courthouse. before a presentation
of the petition to the Court.
DOUGLAS M. MARINOS & ASSOCIATES. P.c.
BY:
Douglas M inos, Esquire
Attorney for Plaintiff
3
.
-~_e,
. .
Exhibit A
ALL THAT CERTAIN lot of land, a1cu.:!te in Lower Allen Township, Cumbnrland
County, Pennsylvania, more particularly bounded and dascribed as follows. to
wir.:
ON THE EAST by property, now or formerly, of J. C. Bucher; on the South by
lande. now or formerly, of Philadelphia. Harrisburg and Pittsburgh Railroad;
on the West by lands, now or formerJ,y, of Mary E. Coleman; and on the North
by Hummel .Avenue; containing in front of Hummel Avenue 35 feet, and extending
souChwardly at an even width 85 feet, more or .Less, t.o lands, r.>r r.he
Phildalphia, Harrisburg and Pittsburgh Railroud:
!lAVING THSREON ERECTED a single two-scary frame bungalow house known and
numbered as 1701 Hummel Avenue, Lower Al.len Town6hi.p, Cumberland County,
Pennsylvania.
OEING the same premises which Dorothy S. Nugent and Allen K. Nugent, her
husb,md, by cheir deed dated April 10, 198'7 and recorded in the Cumbelrand
County Recorder of Deeds Office in Book P-32, Page 276. granted and conveyed
unto Caroge C. Stradtman and Jean R. Stradtman, his wife, Grantors her.ein.
,.
-
~
,
"
"
.~,"I"=""'~'^i
.
Ii
I
ii
I:.
i,
I:
!I
WRITGF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO.
00-176 civil Term
CIVIL ACTION - LAW
TO THE SHERIFF OF
Cwnberland
COUNTY:
A1 teqra Crecli t Corrpany
10 satisfy the debt, interest and costs due
PLAINTIFF(S)
\',
~ i
Ii
I:
,
I'
Ii
from Arthur L. Fritz, Jr., 1701 Hummel, j\venue, Camp Hill, PA 17011
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description
(2)
. ,,~ .':: ",";;. "~ ":',, !- ,-j-' ;i .
You are also directed to attach the prop'erty of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
il
"
i:
II
I
!
"f'
and to iIomy the garnishee(s) that: (a) an atla<;hment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s), imd from delivering any property of the defendariWs) or otherwise disposing
thereof;
(3) If property. of the defendant(s) not levied upon an subjectto attachment is found inth13 possession of anyone other
than a named garnishee ,you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated,
Amount Due $97,222.28
from 4/11/00 to 12/6/0U at
Interest $?? 9R p"r ni"m
Atly's Cornm %
L.L.
$.50
Due Prothy
Other Costs
$1.00
Atty Paid
Plaintiff Paid
$105.58
Date:
July 14, 2000
Curtis R. Long
Prothonotary, Civil Division
b\t-:- 40/?o1 U , P '7l(07/? ~r
Deputy
REQUESTING PARTY:
Name Douq1as M. Marinos, Esq.
Address: 101 North Cedar Crest Boulevard
Allentown, PA 18104
Attorney tor: Plaintiff
Telephone: 610-434-0504
Supreme Court 10 No. 53104
TRUE COpy FROM RECORD
In T 8Stlmony whereof ,Ilwrs unto set my hand
and the of said. a Carlisle. Pa.
Thi day 0
~
_~*II!!m'~I,.~iillIlIiiIllfdiwno!!iljH'mjJ<U'",<':!>il<<l"b.:.a-..'~';.;""~' .-,. tV"'"---
~ ~ ".~....._~-"" =-"--~ ~ ~... ~
.
~- A -'....
,
"REAL E~:TATE SALi I~O?
~"-
;:_ ,_Un ~ rI.- '}I. ;)-rrl> the sheriff levied upon the defendants
;:::"lnterest In the fEtal property situated In.L.I-l'A.. AfJtZ_ ;:t-.M"\h'''~~
:-~ Cumberland COIJlnty, Pa., known and numbered as:/701 i./..dW11.1 ~
_~ and more fullj ,:ascribed on Exhibit "A" filed with
this writ and by this reference incorporated herein.
')ate0, d. ,:27 .:J.nm BY:j~;/;N_..Rt;tt
'rr-r, ~
c:;~
IlViJ
r:::viJ
&e::::2
r.lC\. ',"
10;....
~,
.' .
c <_