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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO, 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563.7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
BANK ONE COLUMBUS, NA, AS TRUSTEE
UNDER POOLING AND SERVICING AGREEMENT
DATED 10/1/94 ON BEHALF OF HOLDERS OF
MORTGAGE PASS THUR CERTIFICATE
(MERIDAN CAPITOL MARKETS A DIVISION
OF MERmAN BANK SERIES 1994-3M)
AND VARIOUS MORTGAGORS
725 NORTH REGIONAL ROAD
GREENSBORO, NC 27409
TERM
NO. , CO - ..2.:2S'.3 du.{~
Plaintiff
v.
CUMBERLAND COUNTY
ROBERT L. MAIER, JR.
KATHLEEN M. MAIER
8 IAN DRIVE
MOUNT HOLLY SPRlNGS, P A 17065
Defendant(s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you, You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VENUE
CARLISLE, P A 17013
(717) 249-3166
Loan #: 3658127
I. Plaintiff is
BANK ONE COLUMBUS, N.A., AS TRUSTEE
UNDER POOLING AND SERVICING AGREEMENT
DATED 10/1/94 ON BEHALF OF HOLDERS OF
MORTGAGE PASS THUR CERTIFICATE
(MERIDAN CAPITOL MARKETS A DIVISION
OF MERIDAN BANK SERIES 1994-3M)
AND VARIOUS MORTGAGORS
725 NORTH REGIONAL ROAD
GREENSBORO, NC 27409
2. The name(s) and last known address (es) of the Defendant(s) are:
ROBERT L. MAIER, JR.
KATHLEEN M. MAIER
8 IAN DRIVE
MOUNT HOLLY SPRINGS, P A 17065
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3, On 3/31/89 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to HILL FINANCIAL SAVINGS ASSOCIATION which mortgage
is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 934, Page 55, By Assignment of Mortgage recorded 11/25/91 the mortgage was
assigned to MERIDIAN BANK which Assignment is recorded in Assignment of
Mortgage Book No. 407, Page 892, By Assignment of Mortgage recorded 1/24/94 the
mortgage was assigned to MIDWEST MORTGAGE INVESTMENT FUND LP IT which
Assignment is recorded in Assignment of Mortgage Book No. 464, Page 921. By
Assignment of Mortgage recorded 12/04/95 the mortgage was assigned to PLAINTIFF
which Assignment is recorded in Assignment of Mortgage Book No. 509, Page 699.
4. The premises subject to said mortgage is described as attached.
5, The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 11/1/99 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
. ,
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6. The following amounts are due on the mortgage:
Principal Balance
Interest
10/1/99 through 311I00
(Per Diem $13.04)
Attorney's Fees
Cumulative Late Charges
3/31/89 to 311100
Cost of Suit and Title Search
Subtotal
$53,089.84
1,982.08
2,654.00
48.08
550.00
58,324.00
Escrow
Credit
Deficit
Subtotal
TOTAL
0.00
310,51
310.51
$ 58,634.51
7. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. gl680A03c on the date(s) set forth in the true and correct copy of
Stich notice(s) attached hereto as Exhibit "A."
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiffs written Notice to Defendants,
a true and correct copy of which is attached hereto as Exhibit "A"; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$ 58,634.51 together with interest from 311100 at the rate of$13.04 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property,
}~1-~
Isl Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
.~"
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:lx' 41 " 9128~36581271/2CA01-05-00 ,
,l~ aJ.er Jr 8 Ian Dr Mt Holly springs PA
. THIS NOTICE IS SENT IN AN ATTEMPT TO
. COLLECT A DEBT. INFORMATION OBTAINED
'X7endover WILL BE USED FOR THAT PURPOSE.
FifrlM'~!tf9'er~~!::s 2000
CORPORATION
Robert L Maier Jr
Kathleen M Maier
B Ian Dr,
l'It Holly springs
** ACT 9 1 N
** T A K E A C
** T 0 S A V E
** H 0 M E F
** FOR E C L 0
o TIC E **
T ION **
YOU R **
ROM **
SUR E **
PA 17065
Loan Service Number: 3658127
Borrower(s): Robert L Maier Jr, Kathleen M Maier,
Premises: 8 Ian Dr" Mt Holly Springs PA17065
~rhis is an official notice that the mortgage on your home is in default,
i!nd the lender intends to foreclose. Specific information about the
nature of the default is provided in the attached pages.
NATURE OF THE DEFAULT: The mortgage debt we service for your lender for
the property listed above IS SERIOUSLY IN DEFAULT. The total amount due
is as follows:
Monthly payments due from 11-01-99 to the present:
Accumulated late payment charges:
Non-Sufficient funds charges:
Advances for taxes, insurance or legal fees:
Credit for funds in suspense:
TOTAL AMOUNT DUE:
$
1,852.59
216.36
.00
90.00
308.77
1,850.18
HOW TO CURE THE DEFAULT: You may cure the default before 02-04-00 by
Iby paying the total amount past due which is currently $ 1,850.18
]~LUS any additional mortgage payments, late charges, or other fees which
become due between 01-05-00 and 02-04-00. Although you will continue
'co receive monthly billing statements, DO NOT RELY on the amount
Istated as due or the due date. This acceleration supercedes any
;and all c<:ll!tl!1tmiceticns. You should call our office at
1-800-436-1022 prior to sending funds to verify the total amount due.
:Payment must be made by cashier's check, certified check, or money
lorder and should be sent to:
Wendover; P,O. Box 70808; Charlotte, NC 28272-0808
lBe sure to write your service/loan number on your check.
...................................................................... .
AVISO IMPORTANTE PARA LAS PERSONAS QUE HABLAN ESPANOL
(Important notice for Spanish speaking persons)
:~ NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
IDERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO
DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
,~GENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
l'lENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
:LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
]~UEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0 . . . . . . . . . . . . . . . . . . . . . . . . . .
C0091/WF288
EXHIBIT A
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'D,.l.TEP: { {
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** ACT 91 NOTICE **
TAKE ACTION TO SAVE
YOUR HOME FROM
,
FORECLOSURE
This is an (.rodal notice that the mart;!a!!e an vaur home Is In derault. an4 the ten4er inten4. to rareclase. SDecine
infarmatia" abaullhe natura of the 4erault is DroYided In tbe attae~ed Da!!...
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM IHEMAPlmav be able to belD to save Your home.
'This Notice. eX15hdns hOVl the arq_rara wo.rks. .
To see if HEMAP...n helD. Yon IDU_t MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30
DAYS O.tHE DATE OF THIS NOnCE. Take this Nodeewlth YOU when vau meet with the CannseUn\! Al!eneY.
The name. llddress and Dbane number at Cal1.!umer Credit CaunselinlZ Allend.. servinll' your Countv are listed at the
end or this .Nodce. If vau hay. any nu~on_, vou mav call the P.~nsvlvania Hausln!! Finance Alteney loll (ree at
1-800.i42.zi97. !Penon_ with Imnalre4 he:ariu can ealll.71'-78o.18691
This Nallee .oDcain. ImportaDt legallDtormadon. If YOIlIta"e allY qllcstiallS, represelltatives at the Consumer Credit
Caunsclill!: Afi:CIlCY ma)' be able to help uplalll it. Yall may also \IVallt to COlltact 811 aRomey ill your area. TIle local
bar assaciat;aD may be able to help YOlllind a lawyer.
NOTE: IF YOU ARE CUlUlENTLY I'ROTECTED BY THE mING OF A PETITION IN BANKRUPTCY. THE
DELINQUi:NCY INFORMATION AT THE BEGINNING OF nns NOnCE IS FOR INFOR.~nON
PURPOSES ONLY AND SHOULD NOT BE CONsmERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have file4 ballkruptcy you call .tW apply tor ElIlcrfi:ency Mongaee Assistan....)
A VlSO IMPORT ANTE PARA LAS PERSONAS QVE HABLAN ltSI' ANOL
(llZlportallt lIolice tor Spanish speaking penons)
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUES AFECTA SU DERECHO A
CONnNUA>R VMENDO EN SU CASA. 51 NO COMPRENDE It CONTENIDO DE ESTA NOTIFICACION
OSTENCA UNA TRADtlCCION INMEDITAMENTE LLAMANDOESTA AGENClA (!'El'INSYLV^,"fIA
HOUSING FINANCE AGENCY) SIN CARGOS AI. NUMERO MENCIONADO ARRIBA. PtlEDES SER
ELEGIBI..E PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
:'oIORTGAGE ASSISTANCE PROGRAM" EL CUAL I'VEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
i]
'I I'OU MAY BE EUClBLE FOR lilNANCIAL ASSISTANCE WHICH CAN SAVE YOUR. HOME FROM
!!"ORECLOSURE ANI) HELP YOU MAKE FUTtJRE MOR~GAGE PAYMENTS
F YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGACE
'SSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
..sSIST ANCE,
,
IF YOUR DEFAULT lIAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS. AND
EXHIBIT r\
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,!~
. IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLV Al"IA HOUSING FINANCE AGENCY. (~PHF A R).
TEMPOR..JIRY STAY OF FORECLOSURE - Under the Act. you are entided to a temporary SlaY offoreelosure on your
mortgO$e fcor thirty (30) days from the date of this Notice. During that time you must arrange and attend a "faee-lo.faee"
meeting witb one of the consumer credit counseli!!!: agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR \!I1THTN THE NEXT (30) DAYS. fF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE
ASSISTANCE. YOU MUST BRING YOUll MORTGAGE UP TO DATE. THE PART OF THTSNOnCE CALLED"HOW
TO cURE YOlJR. MORTGAGE DEF AUL 1'". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. .
CONS~mR CREDIT COUNSELING AGENCIES -lfyou meet ....ith one of the eoa.sumer credit counseling agency
listed 3t the end of this notice, the lender may l'IOi take action agllinSt you for thirty (30) days after the date of this m""ting.
The names. addresses and teleohone numbers of desi!!t1ated consumer credit eounselinst astendes for the counlY in which the
oroDel'1" is located are set fortlt at the end of this Notice. It is only necessary to schedule one face-to. face meeting. Advise
your. lender immediatelv of your intentions.
APPLICA 1:TON FOR' MORTGAGE ASSISTANCE - Your mortgage is in default for the reasoa.s Set forth later in this
Notice (see following pages for speeific infonnalion about the nature of your default.) If you have tried and are unable to
resolve this problem with the lender, you ltave the right to apply for financial assistance from the Homeowner's Emergency
Mortgage A,ssisWlce Program. To do so, you must fill out, sign and.file a comple~d HO/l1eowuer's Emertency Assistance
Progra<ll A~lplieation with one of the desisnated consumer credit eounselizlg agencies listecl at the end of this Notice. Only
consumer CI:edit counseling agencies b.ave applications for the program and they will assist you in submitting a complete
application 1:0 the Pennsylvania Housing Finance Agency. Your application MUST be tiled or pOSllllarked within thirty (30)
days of you\' !ace.lo-face meeting.
NelTE: YOU ~ FILE YOUR APPLICATION PROMPTLY. IF yOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIMi PERIODS SET FORTH IN THIS LETTER. FORECLOSURE
MAY PROCEED AGAINST YOUR HOME IMMEDIATELY Al'lD YOUR APPLICATION FOR
MORTGAGE ASSISTANCE \VU..L BE DENIED.
AGENCY ACTION - Available timcls for emergeacy mol1gage assistance are vel)' limited. They will be disbursecl by the
Agency under lhe eligibility criteria established by the AI;!. The Pennsylvania Housing Finsnce Agellc)' bas sixty (60) days to
make a deci~ion after it receives )'our appUeatioll. During that lime, no foreelosure proceecliags will be pursued aga.iDSt you if
you bave met the time requirellll!llts set fottb above. You will be 1I0tifiecl cIir:Clly by the PellllSylvania Housing finsnce
Ag=.ccy of its c1ecision on your application.
NATUltE OF THE DEFAULT -The MOR.TGAGE debt we seNice on behalf of your lender IS SERIOUSLY IN
DEFAULT. The total amount due and the propmyacldress are listed on thelirstpage of this notice. .
HOW TO CURE THE DEFAULT -You mall cure the default within THIRTY (30) DAYS of the date oftbls notice BY
PAYING THE TOTAL AMOUNT PAST D.UE TO TIm LENDER. PLUS ANY MORTGAGE PAYM:EN1'S AND
LATE CHARGES WHICH BeCOME DUE DURING THE THIRTY (30) DAY PERIOD. The eumllttotal due is listed on
page one of this notice. Pa_enrs mUSt be made in CERTIFIED FUNDS (either bv cashier's cheek. certified check or
monev order) made navable and sent 10:
Welldover; P.O. Box 70808; Charlotte, NC 28272-0808.
8e sure to wdte your loan service number an your check or moneyorcler.
IF YOU DC NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this
Notice. the I,ender intends to exercise its nl!hts to accelerate lIle martstal!e debt. This means that the entire outstandin~
oaJ""ec of this debt will be considered due immediately and you mOl)' lose the cbance to pay the moltgage in monthly
installments. If full payment of the total amount past clue is not macle within THIRTY (30) DAYS, the lender also intends to
instruct its a['1:omeys to sta.rt legal action co torec:lose ocon VOQr mort!!'Bt!:cd Drooertv.
[F THE MCIRTGAGE IS FORECLOSED UP~N - The mortgaged Propelt)' will be sold by the Sheriff to payoff the
mortg'g.e debt. ~f the lender tef~rs y.our case t~ Its .ttorneys, but you Clll'e the delinquency before rl1e lender begins legal
:~oceedlllgs "galns~ you, you will :nll be reqUired ro pay the reasonable attorney's fees that were aCNally incUll'ecl. up lo
,)0.00. Howl,ver, If leg.1 proceedings are SWled against you, you will have to pay all reasonable attorney's fees actually
nculTed by [he lender even if they exceed 5S0.00. Ally attorney's fees will be added to the amount )'ou owe the lender. ...Mcb.
nay also Include ather reasonable casts_ If 'IOU cure the default within the THIRTY (30) DAY neriod. vou will nor be
:""e:auired to C1IQV :ltfonley'S fees.
EXHIBIT A
i')/ jU+.....,..." "' ~ ". _11
L
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OTTiER LEJI/1)ER REMEDIES - The lender may also Sue you personally for the unpaid principal balance and all other
sums due ~der the mOl'lgage. .
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not =ed the default within the
TIURTY (30) DAY period ana foreclosilrc proceedings have begun. vou still have the rillh! to """" the default and D'event
the sale :It art" time OD to one bour before thtt Sheriff's Sale. You mav do so bv n8vmR the total amount then nast due. nlus
an" late or other c!tat1[os then due. reasoftllble attOrneY's fees and costs conncc:ted willllhe foreclosure sale and an" other
costs conne",:ed with the Sheriffs Sale as meclfied in \\Tidnl! bv the lender and b", Derforminll anv other reauirements under
the mort~lIl!',. Cllrillg your deCault III the lIIallner set forth III Ihis notice ",ill restore your lIIorteage to the same
position ;IS il, you bad oever deCaulted.
EARLIESt-POSSIBLE SHERIFF'S SALE DATE - It is estimated that the ea.rliest date that such a Sheriffs Sale of the
mortgaged property could be beld would be approximately six (6) months Cmlll the date DC this Nolice. A Ilotice of the
actual dale of the Sheriffs Sale will be sent to you before the sale. Of course, the amolUlt ",eeded to cure the default will
increase the longer you wait. You lIIay find out at any lime exac:tly wbat the required pa)lUlCtlt or action will bc by COntllcting
me le",der. .
HOW TO CIONTACT WENDOVER
Mailin..tl.ddress: P.O. Box 26954; Greensboro.]IIC 27419-6954 .
Over1l1E,ht Mail Addr...: 725 ]IIorthRegionaI Road: GreensborO'.)le 27409
Addtoss Cor IItr1",,,,,ts 1I"lTr. P.O. BOle 70808; Charlotte, NC 28272-0808
Phone Niumber: 1-800-436.\022
Fu l'l'um~ 1-336-668-2943
EFFECT OF SHERIFF'S SALE - You should n::aIb:e that a Sheriffs Sale will end your ownership of the I%lortgaged
pl'Operty IlIId your right to occupy It. If you continue to Ii",e in tIlc property after the Sheriffs Sale, a lawsuit to remove you
and your lUrnishiAgs and othct belongings could be started by the lender at any time.
ASstlMl"IION OF MORTGAGE - Your 10811 doeumcnts may give ~u the ability to sell or lnllSfer your bome to a buyer
or tranSferee 'Who will assume tIle mortgage debt, provided thaI all the oulStlildi:og pa)lUlelllS, charges and iIItOlIley'S fees and
COsts arc paid prior to or at the sale lIIld that the other noquirements of the moltPlle an: satisfied. Call our CIlStam.er Service
DcpanmCllt a.t 1-800-4364008 if you have someo",c i:oterested in asswning your loan. They will verify if you have mat
ability.
YOU MAY ALSO HAVE THE RIGHT:
TO SEU. THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORR,OW
MONEY FROM ANOTHER LENDING INSnTlJ110N TO PAYOFF lHIS DEBT.
TO HAVE nus DEFAUl. T CtJR.ED BY ANY THIRD PARTY ACTING 0]11 YOUR BEHAlF.
TO HAVE THE MORTGAGE RESTOREO TO THE SA."tE POSInON AS J:F ]110 DEFAUl.T HAD
OCCURRED, J:F YOU CURE TIlE DEFAUl.T, (HOWEVER, YOU 00 NOT HAVE nus lUGK!' TO CURE
YOUR DEF AUl. T MORE tHAN THREE TIMES IN A:Nr CALENDAR YEAR)
TO ASS!:RT THE NONEXlSTrENCE OF A DEFAUl.T IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER I.A WSUIT INsnnrn::D l.JJIIDER THE MOR.TGAGE DOCUMENTS, .
TO ASSERT ANY OTHER. DEFENSE YOU. BELlEVE YOU MA Y HAVE TO SUCH ACTION BY TIlE
LENDER. '
TO SeEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LA W.
eXHIBiT A
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APR 05 2000 16:0
YMCA Buil'"III
JJ':I1'Iord1. Washl"Fn SL
Butler. p" 115001
. (412) 2tq-71l2
CLEAiU"LELD <:;O\ll'lfTT
~n. E"'''''... o..dop.a"C~o.
1954 "''''' Gr-l.oo.
Io/lnstl:rwll, P'A 15901
(814) 535",,~6
FAX (814) 5:19-1688
FAX (4121465-5111
cees or",=- PA, Inc.
217 E.lIIok lid
,ulDOaa '" 16601
(BI4) 944-8100
FAX (114) _5747
cces o(!lo_ PA
1631 S ~St.Sulre 100
s.... ColIOF, PA 16801
(814) 238-3668
FAX (114) 238.3669
cces .rwlStOl'll PA
21M C.Il..., I';ut PIEI
Jo_ PA 15904
(814) 53~35
lndillll& Co. C:QIMlllllity A<:Zl.. PlOanm
827 "'_S'_80'187
Incllmo. PA 15701
mol) 465.26.;7
cu....,ol'll (;OUl'lll 'f
LYCCl~inll>n Co...d..
Collllfti$si... .l'<< C:.mmun;ty AGio. (Sl.l!P)
2131 UDooln S.
P.O. 80. 1328
"'lIIlarosport. PA m03
(570) 3~a7
FAX (570) 3.2-2197
. ccCSonr.""""""PA
1631 S........ St, Sui", 100
SlUIo C.I...... PA 168111
(114) 231.3661
FAX (814) 231.3669
cees ot1'l0nilalom PA
201 Basin S.
WU1da1sPolt, PA 17703
(510)323~7
FAX(570)323~6
COJ,.U~~U, COfJ~
cces .010.__ PA
3IW._.$t.
P.O. Booc 112.7
Wllizl-B..... PA 11702
(S7O) I2I-4U7 01l.1..&Q0.922.g537
FAX (570) 821-17115
1400 All...... E=ud>e Part. Sill'" I
ctd SununiC. PA 18411
(570) 5i1-4163 or 8GQ.m.9531
FAX1S7ll) 587-913<W1J5
-163 AmbcrLon.
W11Jo:s..8ono, PA 11702
(570) 1U-4S10 Oll, l-aoo-m.lJ3S9
FAX (570) ll2901665-<ALL BEFORE FAXlNO
(510) '554994llJ1ZEI.!C!I
FAX(570)45S-S63I~BEl'OREFAXlNO .
(570) 836-4090 'l1.I1'IKHAN1'IOCK
c.1IIII\isoiGn on E..""mlcr Ollp'rmnlty
o(x.-m. COlll\l)'
eRA WFOJU:J C:OUl'ffY
Booker T. W....in.... CCllf<l'
1720 Hall..d S.
Erie. PA 16503
(814) 453-5144
FAX (114) 45:3.5749
0.....' Erio Community A...on Comm;...
II W... 51b SIC
Eri..PAI6S01
(114) 45904511
FAX (114) 4554161
J.hn F.1CcluIaIy Calor. I...
2021 Ec2/Jlll S.
Eri.. PA "SID
(114) ua.4440
FAX (814) 891-U43
Sh....... VallO)' Urb.. Leap:, In..
601 IDQIlIIl&A""
'"",,11, PA 16121
(412)911.5310
. C:lJMBEJU...t\ND t:aUNTY
CCCS.fW_rA..liI..
2000 tinsl__1U
IWrisbww. PA. 17102
(711) 54f-17H
FA.'l: (711) 541.-4670
r.."""liIl Co",odinl SorlIiA:u ofFnIftldin
31 W..,3rdS,.
W.,....t>otu. FA 17268
(717) 762.nU
Urban l.<qIlC.r M_p'lil= Hmlsburl
!II. 6th S.
COllllnilllRy AGion' C.mm orll1. Cilpil3lltoglon
1514!lmy S.
HaIrisb"'1. PA 17104
(717) m-9757
PAX (717) 234-m7
Hmlsbuq,PA mOl
(717) 234-5925
FAX (717) 234-HS9
'YWCA .fCat!isl.
301 OS.
Corfisl.. PA 17013
(717)243-38lB
FAX(717)731~519
AcWo! Coun\Y' Hall5ins AutIlarity
139.143 C>tIIaI. S.
Oea:)o>b"'l. PA 1732S .
(711)J3~1S11
FAX (711) 334-ilJ26
D"IJ.fHli~ CCIUNl Y
cees .fW....:m PA.. mo:.
zooo t.inslcslC'w Rd
Hnrri:obUl'Jl, p" 17102
(711)54/.1757
FAX (711) ~41'''670
Urb..l,._ .rMo""p'Ii... H;rrisboq
21071'1.6thS.
1lorrIab"'l- PA 17101
(7I7) 234-l92S
FA.'C (717)434-9459 .
Communi')' Acticn Commisa:ioft
of tIl. Copicnlllcgi.n
15141lcny S.
Hllni:ibur;PA l7l04
(717) 232-9757
FAX (7I 7) 234-%227
o EU,W"'.RE (..OlJrllTY
ACl:lm Houslnl c.o~rw.iOI'l
14<\ N.m BU S.
?hilodelphi.. PA 19130
!11l16S.llll
'AX (21;) 165-1427
.....QRh~,st COWl$CIin, Scr'Yi=-
5001 N.m BRd S~
Philadolphi4. PA 19141
(215) 32...7S00
FAX (215) Jl4-B75J
cces .rDola..... VallO)'
IS IS MId<J:, S<-S.i.. 1325
Philaddphi.. PA 19107
(2ISl 563..s665
FAX (215) 864-2li66
IlACE
1 67'W. A1lq/1..,y AVe.. 2ftd A<Xlr
Philadelphia. p" 191-lO
EXHIBIT A
:;{'j.:
. to t4e 30icl groRtee S .
" AlL.that certain tract of land, situate in South Middreton Township, OJmberland
Colin,ty, Pennsylvania, more particulary bounded and described as follows to wit:
..
..
....
BEG:INN~ "at _ 'aIL iron pin on the West side of Ian Drive. a 50 foot
wid.e riilit-of-'wa;r. at Lo~ No, 24. Section A of the hereinafter Plan of
Lot.s; thence by the said Lot No. 24. South 71 degrees 35 minutes 50
seconds West for a distance of 136.42 feet to an iron pin; thence
alc,ng the land. now or formerly of William Otto, South 18 degrees 26
minutes East for a distance of 110.00 feet to an iron pin; thence
alc~g the boundary of Lot No. 22, North 71 degrees 35 minutes 50
seconds East for a distance of 136.36 feet to an iron pin; thence
alc,ng the aforementioned right-of-way, North 18 degrees 24 minutes 10
seconds West for a distance of 110 feet to an iron pin which is the
plB,ce of BEGINNING.
BEING Lot No. 23. Section A of the Final Plan of Stephan O. Smith and
Larry V. Neidlinger, recorded in the Office of the Recorder of Deeds
in and for Cumberland County. Pennsylvania, in Plan Book 44, Page 38.
SUEIJECT to easements, rights,:-of-way and restrictions of record.
\
.
Jl'REMISES: 8 lAN DRIVE
'';i!..
.~"','-. .
"..-...
VERlFlCA nON
MICHAEL V. CAPPS hereby states that he is VICE PRESIDENT of WENDOVER
FINANCIAL SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to
take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure
are true and correct to the best of his knowledge, information and belief. The undersigned understands that
this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to
authorities.
~kw\\~("
\ 1
DATE;
L\-l-~D
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-02253 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK ONE COLUMBUS NA ET AL
VS
~~IER ROBET L JR ET AL
CPL. TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
~~IER ROBERT L JR
the
DEFENDANT
, at 0012:39 HOURS, on the 3rd day of May
2000
at 8 IAN DRIVE
MOUNT HOLLY SPRINGS, PA 17065
by handing to
KATHLEEN MAIER
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
3.72
.00
10.00
.00
31.72
So Answers:
r~d,~~l
R. Thomas Kline
me thi'~ J.S'~
day of
05/04/2000
FEDE~ j~f< l#E
De ty Sheriff
Sworn a~d Subscribed to before
~ c2-c-vv A.D.
0.<}'-- a Iu.t#/. ~ I\~,,~
. Prothonotary I
""""0"
,
. .
l
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-02253 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK ONE COLUMBUS NA ET AL
VS
~~IER ROBET L JR ET AL
CPL. TIMOTY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
~~IER KATHLEEN M
the
DEFENDANT
, at 0012:39 HOURS, on the 3rd day of May
, 2000
at 8 IAN DRIVE
by handing to
MOUNT HOLLY SPRINGS, PA 17065
KATHLEEN MAIER
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
j~ffidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
sO;:~~t
R. Thomas Kline
05/04/2000
FEDERMAN & PHELAN
Sworn and subscribed to before By:
",
me this" /~!'Y day cif
~~... ,;/...<>vV A.: D .
q.--. r; ~ #
I Prothonotary , :
""1,
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m.
,,.
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, P A 19102
(215) 563-7000
Attorney for Plaintiff
Bank One Columbus, N.A. as Trustee
Under Pooling and Servicing Agreement
dated 10/1/94 on Behalf of Holders of
Mortgage Pass Thur Certificate (Meridan
Bank Series 1994-3M) and Various
Mortgagors
725 North Regional Road
Greensboro, P A 27409
: Cumberland COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: NO. 00-2253-Civil
Plaintiff
vs.
Robert 1. Maier, Jr.
Kathleen M. Maier
8 Ian Drive
Mount Holly Springs, P A 17065
Defendant(s)
PRAECIPE FOR JlJDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment, in rem, in favor of the Plaintiff and against Robert 1. Maier, Jr.
and Kathleen M. Maier, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within
20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess
Plaintiffs damages as follows:
As set forth in Complaint
Interest 3/1/00 to 6/6/00
TOTAL
$58,634.51
$1.277.92
$59,912.43
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rule 237.1, c~~ed~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: (juu,_ 1. ~(FO{)
~'12~'
PROP 0 HY
"TIIIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED Wll.L BE
USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS
NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOUW NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECf
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .,
"",. - , , , ~
,..
FEDERMAN AND PHELAN
Frank Federman, Esquire
1dentification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
BANK ONE COLUMBUS, N.A., AS
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT, DATED
10/1/94 ON BEHALF OF HOLDERS
OF MORTGAGE PASS THROUGH
CERTIFICATE (MERIDAN CAPITOL
MARKETS, A DIVISION OF MERIDAN
BANK SERIES 1994-3M) AND
VARIOUS MORTGAGORS
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 00-2253-CIVIL
vs.
ROBERT L. MAIER, JR.
KATHLEEN M. MAIER
Defendant(s)
TO: ROBERT L. MAIER, JR.
8 IAN DRIVE
MOUNT HOLLY SPRINGS, PA 17605
F\LE COP~
DATE OF NOTICE: MAY 24, 2000
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. 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 other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNfY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
. T<!Ii
-
", -
-
,,,"
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
BANK ONE COLUMBUS, N. A., AS
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT, DATED
10/1/94 ON BEHALF OF HOLDERS
OF MORTGAGE PASS THROUGH
CERTIFICATE (MERIDAN CAPITOL
MARKETS, A DIVISION OF MERIDAN
BANK SERIES 1994-3M) AND
VARIOUS MORTGAGORS
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
,
NO. 00-2253-CIVIL
vs.
ROBERT L. MAIER, JR.
KATHLEEN M. MAIER
Defendant
FILE COpy
TO: KATHLEEN M. MAIER
8 IAN DRIVE
MOUNT HOLLY SPRINGS, PA PA
DATE OF WOTICE: MAY 24. 2000
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS
NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A
DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. 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 other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
-,,"-.
-,
- ~ ,
,
~nn~l~r ~ K~~U~~ - ~~~u~~
.
CASE NO: 2000-02253 P
cor;IMONWEALTH OF PENNSYLVANIA:
COlWTY OF CUMBERLAND
BANK ONE COLUMBUS NA ET AL
VS
MAIER ROBET L JR ET AL
CPl,. TIMOTY REITZ
, Sheriff or Deputy Sheriff of
CUIT~erland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
MAIER KATHLEEN M
the
DEFENDANT
, at 0012:39 HOURS, on the 3rd day of May
, 2000
at 8 IAN DRIVE
MOlWT HOLLY SPRINGS, PA 17065
by handing to
KATHLEEN MAIER
a t.rue and attested copy of COMPLAINT - MORT FORE
together with
NOTI CE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers:
r~~~<~t
R. Thomas Kline
05/04/2000
FEDERMAN & PHELAN
Sworn and Subscribed to before
By:
---
.if-
me this
day of
A.D.
Prothonotary
, ~..
0"
SHERIFF'S RETlliL~ - REGULAR
.
'CASE NO: 2000-02253 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK ONE COLUMBUS NA ET AL
VS
~~IER ROBET L JR ET AL
CPL. TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
~~IER ROBERT L JR
the
, at 0012:39 HOURS, on the 3rd day of May
2000
DEFENDANT
at 8 Dill DRIVE
MOUNT HOLLY SPRINGS, PA 17065
by handing to
KATHLEEN MAIER
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
l',ffidavit
Surcharge
18.00
3.72
.00
10.00
.00
31.72
So Answers:
r~~~~~t
R. Thomas Kline
day of
05/04/2000
FEDERMAN &~~~2>-1,~r-/
By : f,../' //'
...--C4-U-A, L.- '
De ty Sheriff
Sworn and Subscribed to before
me this
A.D.
Prothonotary
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(Rule of Civil Procedure No. 236 - Revised)
Bank One Columbus, N.A. as Trustee
Under Pooling and Servicing Agreement
dated 10/1/94 on Behalf of Holders of
Mortgage Pass Thur Certificate (Meridan
Bank Series 1994-3M) and Various
Mortgagors
: Cumberland COUNTY
: Court of Common Pleas
: CML DIVISION
: NO. 00-2253-Civil
Plaintiff
vs.
Robert L. Maier, Jr.
Kathleen M. Maier
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on June
1 , 2000.
By Y'j,u 0. ~
DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESOUIRE
Attorney for Filing Party
SUITE 900
TWO PENN CENTER PLAZA
PHILADELPHIA. PA 19102
(2151563-7000
**TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, TillS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, P A 19102
(215) 563-7000
Attorney for Plaintiff
Bank One Columbus, N.A. as Trustee
Under Pooling and Servicing Agreement
dated 10/1/94 on Behalf of Holders of
Mortgage Pass Thur Certificate (Meridan
Bank Series 1994-3M) and Various
Mortgagors
: Cumberland COUNTY
: Court of Common Pleas
: CIVIL DIVISION
: NO. 00-2253-Civil
Plaintiff
vs.
Robert L. Maier, Jr.
Kathleen M. Maier
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act
of Congress of 1940, as amended
(b) that defendant Robert L. Maier, Jr. is over 18 years of age and resides at 8 Ian
Drive, Mount Holly Springs, P A 17065.
(c) that defendant Kathleen M. Maier is over 18 years of age, and resides at 8 Ian
Drive, Mount Holly Springs, P A 17065.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
L9dL
FRANK FEDERMAN
Attorney for Plaintiff
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