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Home My WebLink About00-02637 ~ I . , ~" FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PNC MORTGAGE CORP, OF AMERICA 539 SOUTH 4TH AVENUE LOUISVILLE, KY 40202 ATTORNEY FORPLAlNTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff v, NO, 00 - .:11031 GlJ,-tT~ PIKE COUNTY JASON L. LEININGER 62 BALL PARK ROAD GARDNERS, P A 17324 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, IlUT 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 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, CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 0430004519 , ., "~ ~ ilil:&." , 1. Plaintiff is PNC MORTGAGE CORP. OF AMERICA 539 SOUTH 4TH AVENUE LOUISVILLE, KY 40202 2. The name(s) and last known addressees) of the Defendant(s) are: JASON L. LEININGER 62 BALL PARK ROAD GARDNERS, PA 17324 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On 9/10/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of PIKE County, in Mortgage Book No. 1570, Page 584. 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 1111199 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." ~" ~~~.~ - '-"""', 6. The following amounts are due on the mortgage: Principal Balance Interest I 011/99 through 3/1/00 (Per Diem $22.59) Attorney's Fees Cumulative Late Charges 9/10/99 to 3/1/00 Cost of Suit and Title Search Subtotal $106,400,00 3,433,68 4,000.00 152.44 550.00 114,536.12 Escrow Credit Deficit Subtotal TOTAL 0.00 335.49 335.49 $114,871,61 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. 8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A," 9, 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 $ 114,871.61, together with interest from 3/1/00 at the rate of $22.59 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale ofthe mortgaged property. ~ ;;--~ /s/ Frahk Federman FRANK FEDERMAN, ESQUIRE Attomeyfor Plaintiff ''-~~~;;%, ;;::.r-- :'.::J-~ ;:""'::1 ;:;l(J 1'(: 3~31~ "'---- F..:!4/23 Record and Rerum To: PHC Mortgage corp. of America DOcument OperatiQ~ 15 North r_irwoy D~i~e Vernon Hill., IL 60061 Parccl Number: 8.;1.6-210-046 ... -". " ..~~'~..'-r\ -/8 -00 -045/9 ~~ - '-/h l" - ~ - . .L=~ ;:,)5 '99 S:r 15 rn 2 05 [Spilt:t Abovt Tb1s Lin~ Fir Recurd1a& DlalaJ Prepared By: Deborah A Andreen Beth.l rark. PA lS10~ MORTGAGE Lender //~ 430004519 THIS MORTGAGE (-Security Inmumenl") is given on September 10, 1999 JABon L Leininger unmarried &S Individual . The mongagor is rBorrower-). This Security Instrument is given to liNe Mortgage Corp. of America, an Ohio Corporation. which is organized and existing under the laws of OhiQ . and whose address is 75 North ..airway Drive. Verllon Hills, IL '0061 ("Lcnder'), Borrower owes Lender the principe! sum of On. Hundred Six ~housand four Hundred and OO/lOO~._.~._._..._-_.~---_.-._._----~-_..--- ._____. .___. .__..____ ..--... ...--.... -----. -------.. --. Dollan (U,S, $106,400.00------- --). This debt j, evidenced by B01TQwer', note dated the same date as this Security Instrument ("Notc-), which provides for monthly payment.. with the full debt, if not paid earlier, due and payable 00 Octobo. 1, 202' This Security Instrument secures to Lender: (8) the repayment of the: debt evidenced by me Note, with interest. and all renewals. ex.tensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the "ecurity of this Security Instrument; and (c) th(: p:rfonnanu of Bomwer's coyenanrs and agItements under thi3 Security InstrlJ,mtnl and the Note. For this purpose. Borrower does hereby mongagc. grant and convey to Lemkr the following describedprapcny located. in C\UDbe:cland County, Pennsylvania: See Exhibit "Aa att.ached hereto amI. made a pat't hB:t80f. ---... which has the address of 62 8.11 park R.oad, Gardn.rs Pennsylvania 17324 (Zip Codel (-Property Address"); {Stn:el,Cityj. PENNSYLVANIA-Single Family.CONVENTlONAL UNIFORM INSTRUMENT PA00001119l!IZl I"Iil1 ~Ili Inlll.II:~LL..- ffoad570rlGf. .584 ~~ ......~ ~""""'~ .~ ....~~. -"",""" 5EC-10-1S99 11:S~ ?05/23 . TOGEiHER WITH .all the improvcroenu now' or hereafter erected on the properry, and all easements. appllrtc.nances. and tb:.tuIes now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. AU of the foregoing is referred to in this Security llUtrUIIlet1l as the "Ptoperty. . BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Pfopert)' and that the Property is unencumbered, cxcept for encumbrances of record. Borrower warrants and will defend genc:raIly me title to the Property agaiDst all claims and demands. subject to any cncumbranccs of recQrd. THIS SECURITY INSTRUMENT combines unifonn covenants for nalionaJ we lJDd non-uniform covenants with limited variatiom by jurisdiction to comritutc a uniform security in,rrurnent covering real property. UNIfORM COVENANTS. Borrower and Lender covenant and agree as follows: L Payment or Principal and Interesli Prepayment and Late Charges. Borrower shall promptly pay when due the principaJ of and interest on the debt e\lidcnced by the Note and any prepayment and late charges due under the Note. 2. Funds rOT Taxes and Insurance, Subject to applicable law or to a written waiver by Lender, Borrowcr shall pay [0 Lender on the day monthly payroents an:: due W'lder me Notd, W'ltil the NOle is paid in full. a sum rfunds.) for: (a) yearly taxes and assessments which ma.y auain priority over this Security Instrumenl as a lien on tbe Property: (b) yearly leasehold payments or ground rents on the Property, if any: (c) yearly hazard or property insurance premiul11$: (d) yearly fiood insurance pIemiums. if any; (e) yearly mongage insurance premiums, it any; and (0 any sums payable by Borrower to Leader, i.a accordance with the proyjsicms of paragraph 8. in Jieu of the paymenr of mortgage insur.am:e pn:miums. These items are called -Escrow Iltmli. ~ Lender may, at any time. collect and hold Funds in an amOUDt nor [0 exceed the t'I'l.3.Ximum amount a lender for a federally related mongage loan may require for Borrower's escrow account under me federal Real Estate Sertlemtnt Procedures Act of 1974 as amended from time to time, 12 V.S.C. Section 2601 et seq. (~RESPJ\~), UDless another law that applies to the Funds sets a lesser amount. If so, Lender may, al my lime, collect and hold FWlds in an amount not to exceed me lesser amount. Lender ruay estimatc the amount of Funds due on the basis of currcnt data and reasonable c:stinwes of expenditures of future Escrow Items or otherwise in ittordance with applicable law. 'The Fund$ !ball be held iD an institution whose depOsiu are insured by a federAl ageDC)'. instrumelK.1Ury. or calif)' (including Lender. it Lender is such an institution) or in any Federal Home Loan Bank. l.e.ader ,hall ilpply the _Funds -to pay the Escrow Items. Lender lJ]a.y not chugc Borrower for holding and applying me Funds, annuaUy analyzing the escrow accoUlll, or verifying the Escrow Items. unless Lender pays Borrower interest on the funds and applicablo law permits Lender to make sl1Ch II charge. However, Lender may require: Borrower 10 pay a one.thne cbarge for an independent real estate tax reponing service used by Lender in coJUttction with this loan. unless applicable law provides otherwise. Unless an agreement is made or applicable law requires interest to be paid. Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower illId Lender may agree in Wriliog, however, lilac inte"," shall be paid on chc FWIdI. Leader Ihall give 10 Borrower, without cbllfgc, an annual accounting of che Fwuu, &howing credits and debits to lhe Funds and the purpose for wbich each dobi. to tl1e FllIIds was made. The FWIdI Me ple<lged as addilional.ecurity for all sums secured by this Security iIlsll"Ulllellt. If the Funds held by Lender exceed the amoUtlta permitted to be held by applicable law. Lender shalt account to Borrower for Ihe excm FllIIds in accordance willlllle requirements of applicable law. If Ille amOllllt of chc FWIdI held by Lender" any time is not sufficient to pay the Escrow Items wben due. Lender may so ntllify Borrower in writing, and. in such case BOllowcr shall pay to Lender me amount necessary to make up the deficiency. Borrower shall make: up the deficiency in no more than twelve monthJy payments, at Lender's sole discretion. Upon paYlIle.1 in lull of all sums secured by this Security Insc1'UlIll:nl, Lender shall promplly relund 10 Borrower any Funds beld by Lender. It, UDder paragraph 21, Leeder shall acquire or sell the PropertY. under, prior 10 the acquisition or sale of the Property. shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the sums scalled by this Security Instrument. 3. Application of Paymeuts. Unless applicable law provides otherwise. all payments received by Lender under paragraphs 1 and 2 shall be applied; first, [0 any prepayment charges due under the Note; second. to amQunts payable under paragraph 2; third, [0 interest due; fourth, to principal due; and last, IO any late cl1argc$ due under the Note, 4. Charges; Liens. Borrower shall pay all ta.xes. as5C5SIDenLS, tlwges. fiaes and impositions llrtributable 10 the Property whicb may strain priority over this Security InsUluuent, and leasehold, payments or ground rentS, if any. Borrower shall pay these obligations in the manner provided in paragraph 2. or if nol paid in thai manner, Borrower shall pay them on time directly to the person owed payment Borrower shall promptly furnish 10 Lender all nolices of amounts (0 be paid under lbiJ paragraph. If Borrower maltcs these payments dil't'ttly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to l..crtder; (b) oo.alests in good faith the lien by. ,or defends agaimt enforcement of the lien in, legal prOCeedings whicb in the Lender's opinion operate [Q prevent lhe cnforcement of the lien: or (c) secures from the holder of the lien an agreement satisfacIOry to LendeJ; subordinating the lien [D this Securiry w!nunent. If Lender detennines that an)' pan of the Property is subject to a lien which may attain priority over this Security InsU'ument, Lender may give BotTower a Jlotice identifying the lien. Borrower sh;tll satisfy the lien or take ace or more of the actions set forth above within 10 days of the giving of nOlice. PA000012 U..12, 430004519 Pogo2a/6 ,n'\I.,s:)LL Bood570rlGf: .585 ,.' ~~.. ~ .~"....-"'-'"~ ,,,-- -~. ~,""', ,. ~~I -- Sc?-:a-1559 11:51 P.26/23 5. Hazan! or Property Insu["Bne~. Borrower ~hall.keep the improvements now 'c;tiSling or hereafter CfcClcQ on me Property insured against loss by fire, hazarc1! includcd within the term Mex1end'ed coverage" and any other hazards. includin&: floods or flooding, for which Leeder requires insurance. This insurance shall be maintained in the amounts and for the periods lh.<.Lt Lender requires. The insuranc'e carrier providing the 1ns\U'ance sh.aJ1 be chosen by Borrower subject to Lender's approvaJ which 9ha.ll not be unreasonably Withheld. If Borrower fails to maintain coverage described above, Lender may, iU Lender's option, obtain coverage to protect Lender's rights in the Property in accordance with paragraph 7. All iwurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender sholl! have flll: right to hold the poheies md renewals. If Lender requires, Borrower sball promptly give ~o Lender all receipts of paid prt:miums and renewal notices. In the event of loss, Borrower shall give prompt notice to tbe insurance camer and Lender. Lender may make proof of lou if nor made promp!ly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of lbe Propert)' damaged, if the restoration or repajr js eamomically feasible and Lender', security is Dot leneoed. If the restoration or repair is not economically feasible or Lender's securilY wquld be lessened, the insurance proceeds shall be: applied to the sums setured by this Seculi[y Instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons the Propeny, or does not answer within 30 days a notice from Lender that the insurance carrier lw offered to settle a claim, thea Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restOrt the Property or to pay sums secured by this Security Instrument, whether or nOI then due. The 30-day period will begin when me notice is given, Unle~s Lender and Borrower otherwise agree in writing. any application of proceeds to principal shall not exteDd or po:srpone the due date of the monthly payments rcfcrred to in paragraphs 1 and 2 or change the amount of thc payments. If Wlder paragraph 21 the Propeny is acquired by Lender. Borrower's right to any insurance policies and proceeds resulting from dMtage to the Property prior (0 me acquisition sb~f pas! to lender to the exten~ of tbe swm ~eeurcd by this Security Instrument immediately prior to the acquisition. ~ 6. Occllpanc:y, Preservation, Maintenance and ProtectIon of the Progeny; Bo(TOwer', Loaa Application; Leasebolds. Borrower shall occupy, establi5h. and USe the Property as Borrower's principal ~s.idem:e within sixty days after the execution of this Sec~rit)' Insuumenl ancl shall continue to cecupy' the Property as Borrower', principal residence for at Ic.ut, one yeas after the date of occupancy. unless Lender otbCIW~sc agrcQ iD Writing, which consent shall not be umeasocably withheld, Or unIt$$. e~tcnuati.ng circumstances exi$t Which are beyond Borrower's control. Borrower 5hall not c!es[roy, damage or impair the PropertY. allow the Propeny to de~eriorate. or commit waste on the Property. Borrower shaH be in default if any forfeiture action or proceeding, whether civil or criminal, is begun that in lender', good faith judgment could rcswt in forfei~ure of the PropertY or othet\llise malerially impair the lien creat~ by this Securiry lnstNmCnl or Lender's $ecurity interest. Borrower may cure such a default and reinsta~e, as provided in paragraph 18. by causing the action or proceeding to be dismissed with a ruling that, in Lender's good faith determination, precludea forfeiture of the Borrower's in~es~ in che PropertY or otber material impairmenl or the lien created by this Security lnstromcnl or Lender's security interest. Borrower shall also be in default if Borrower. during the Loan application process. gave materially false or inaccurate informacion or statements to Lender (or (ailed to provide Lender with any material information) in coDl1ection with the loan evidenced by the Note, including. buc nOllimited fO, represenfadons coacerning Borrowerls occupancy of the Propeny as a principal residence. If this Sccuriry lnstnunem is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee tide to the PropertY, the leasehold and the fee lide shall nor ale-rge unlcss Lender agrees 10 tJJe merger in wridng. 7, Prottfrtion of Lender's Rigbb in tbe Property. If Borrower fail! 10 perfoon the coven.1Jlts and agreements comained in this Security Instrument, or there is a legal proceeding that may significantly affect Lendcr~s rights in the Property (such as a proceeding in bankrup!cy, probate, for condemnation or forfeiture or 10 enforce laws or regulations), then Lender may do ilDd pay for whatever is necessary 10 protect the value of the Property and Leader's rights in the Property. Lender', actions may include paying any sums secured by a tien which has priority over this Securi~y Instrument, appearin~ in court, paying reasonable auorney3' fccs and entering on the Property to make repairs. Ahhoq.gh Lender may take aclion under this paragraph 7, Lender does no! have to do so. Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Insrrument Unless Borrower ilIld Lender agree to ollIer tenns of payment, thesc mount:; shalJ bear interest from the date of disbursement at the Note rale and shall be payable, with Lnterest, upon notice from Lenc1cr to Borrower requesting payment. 8. Mortgage Jnsllranee. If Lender required Q\Ortgage insurance as a condi~ion of making the loan secured by this Security Instrument, Bonower slWl pay the premiums required to maintain the monsage insurance in effect. If, for any reasoD, lhe mongage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the premi\lnlS requited to obtai1'l. cove~age substantially equivalent to the mongage insurance previously iD effect, at a cost substantially equivalent to the cost to BOITower of tbe mortgage insurance previously in effect, from an altemate mortgage insurer approved by Leeder. If substantially equivnlern mortgage insurance coverage is Dot available. Borrower sball pay to Lender each month a swn equal to one-twelfth of the yearly mortgage i.csurance premium being paid by Borrower when the insuraocc coverage lapsed or ceased to be iD effect. Lender will accept, use and retain these payments as a loss reserve in lieu of mongage insurance. Luss reserve PAOOO013 CUll) 4300Q~S1.g 'oat3o'S :lL- In.I<IJI"_ Bood570PAGt .586 ~ -. ,", '~_<-i""", . "~~~-"lilldillilll.l~l!!'li SEP-10-1999 11:51 ?37/23 payments may no long.er be required, at the option of lender.. if mortgage insurance coverage (in the amount and for the perlOQ that Lendcr requires) provided by an insurer approved by Lender again becomC$ available iIlod is obtainca, Borrower shall pay the premiums required to maintain lIlongagc insurance in cffect. or to provide 11105$ rc$erve, until the rcquiRmeDt for rnongatc ilJ,~UIa.nce ends in accordiltcc wi!h any wlitten agreement belw~~n Borrower and Lender or applicable law. 9. Impealon. Lender or its agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying R:ilSonable cause for the inspection. 10. Cond.emnation. The proceeds of any award or claim for damages. direct or consequential. in cocnectioD with any condemnation or other taking of any part of the Propcny, or for conveyance in lieu of conaemD:ation. are hereby assigned a."U1 .hall be paid 10 Ltnder. In the event of a totOlllaking of the Propeny, the proceeds sban be applied to the $UDlS secured by this Security loslrumeDt. whether or not then due. with any excess paid 10 Borrower. tn the event of a partial taking of the Property in wbich the fair market value of the Property immediately before the laking is equal to or greater than the amount of !be sums secured by this Security Instrument immediately before the taking, W11ell' Borrower and Lender Qttlerwise agre= in wrido;. the sums secured by this Security Instrument sbaH be reduced by the amowlt of the proceeds multiplied by the following ftacrion: (a) me lotaJ amount of the sums secured immediately before the takingl. divided by (b) the fair market value Qf the Propeny iDlII1ediately before the taking. Any balance shall be paid to Borrower. lD the event of a partial taking Qf the Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking. unless BOlTower and Lender othclWise agn:e in writing or unlC1S applicable law otherwise provides. the proceeds shall be applied to the sums secured by this Security Inmument whether or nOl the surm are then due. If the Property is abandoned by BOlTower. or if, after Dotice by Lender to Borrower that me copdemnor offers to make an award or settle' a claim for damages, Borrower fails to re$poud to Lender wi[b.in 3() days after the date the notice is giveD, Leoder is authorized to collect and apply the proceeds, at its option, either to reS{oratiQU or repair of the Property or to the sums securecl by this Security Instrument, whether ar not then due. UDless Lender and Borrower othenvise agree in wrJring. any applkariQn of proceeds fO principal shaJJ not' eJ!:!CfId or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or changc the amoWlt of such payments. 11. Borrower Not Released; Forbearance By Lender Not Il Wainr. E.xteIlSion of the time for paymeut or modification of amortization of the swns sccured by this Security Instrument granted by Lender to any SuCtcssor in interest of Borrower shall nOt operate to release the liability of the original Borrower or Borrower's Juccessor'$ in interest. Lender shall not be required to commence pr<<eedings agaimr allY SIJC(CSSOl in iureresl or refuse 10 t.1lcnd rimt for payment or oJbelWi~ modify amortjzari012 . of the sums secur~ by this Security Instroment by reason of an)' demand made by the original Borrower or Borrower's slIccesSOrs in interest, Any forbearance by Lender in exercising any right or remedy sban not be a waiver of or preclude the exercise of any right or remedy. 12. Suceessors and Assigns Bouad; Joint and Sevenl Liability; Co-signetS. The covenants and agreements of this SecuritY Imrrumenr ,haJJ bind and benefir !he SUCCCS30TS and .wigns of Lender and Bor.rowet, .subjet! !O the proVisions of paragraph p. Borrower's covenants and agreemcuts shall be joint and several. Any Borrower who co..-signs this Security In.ununent but does not execute the Note: (a) is co-sigoin&; this SecuritY Instrument only to mortgage. granl and convey thai Borrowlllr's intere:st in the Propeny under the termS of lhis Security Insln1meIlt; (b) i:s Dot personally obligated 10 pay the sums secured by this Security Itl.'ittument; and (c) agrees that Lender and any other Borrower may agree to elllend, modify. forbear or make any accommodations with regard to the lerms of this Security Instnunem or rhe Nare withoul mat Borrower'S COl2SeDt. 13. Loan Charges. Lender may charge Borrower fees for smices performed in coDbectioQ with Borrower's default. for the purposc of protecting lender's interest in the Property and rights under this Security Insuument, including, but not limhed to. attorneys fees and property inspection fees. The absence of express authority in this SecuritY Instrument to charge a specific fee to Borrower shall not be construed as a prohibilion on the charging of such fee. Lender may not charge fees that are expressly prohibired by thi.s Security lZlflrument or by ApplicabJe Law. If the loan secured by this Security InstrUment is subject to a law which sets maximum loan charges. and thai law is finally interprelcd. so that the inltrest or other loan charges collected or to be collected in c:onnection with the loan e~ me permitted limits, then: (a) any such loan charge shall be reduced by thc amount necessary to reduce lbe charge to the permined limit; and (b) any $l,UUS already collectco4 (rom Borrower which ucecded permitted limils will be refunded 10 Bonower. Lender may choose to malee thi" refund by reducing the principal owed UDder tbe Note or by making a direct payment to Borrower. If .a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge puder the Note. 14. Notices. AJJy notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law require~ IUC of another method. 1be notice shall be direcled to lhe Property Address or any other address Borrower designates by Ilotice to Leeder, Ally notice to Lender shall be given by first class mail to Lemler's addreas stated herein or any other address Lender Iksignalcs by notice to Borrower. Aay notice provided for in tbi5 Security Instnunent shall be deemed to have been given to Borrower or i,.ender when given as provided in this paragraph. 15. GO..miDG. Law; Severability. Thi. Security Instrument .hall be governed by lederal law and the law olthe jurisdiction in which the Property is located. tn the event thai any provision or clause of dtis Security Instrument or the Note conflicts with applicable law, such conflict shall noC affect omer provisions of tbis Security Instrument or the Note which can be given effect without Che confliccing provision. To chis eod the provisioo.s of this Security lnsnumcnt and the Note are de-elated to be severable. 16. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument, 17~ Tnaosfer or the Property or a Beneficiallnteresc in 8orrower~ If all or any pan of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural persOD) witbout Lender's prior writccn consent, Lender may. at its option. require inuncdiace paymtl1t in fuU oC all SUIJIS secured by tbis Security Instrument, However, this op!ion shall no! be exercised by Lender if exercilJe is prohibited by federaJ law as of Ihe date of this Security Instrument. PAOOOO," 1"'11 430004519 1'1""ota .,,,,,~\LL BOOK1570 PAGE .587 _.......'"~, - ,~iIlJi~ilI11l!..lt'l~llih'_~j;l:<.l" 5EP-10-1999 11:52 . ;.2E/23 IfL.ender exercises mis opcion. Lender shaJl give Borrower notice of aCceleration. The notice sball provide a period of OO( less lhan 30 days from the date the nolice is delivered Of mailed within which Borrower must pay all sums sCI:UIed by thi$ Security Instrument. If Borrower fails to pay Ihese sums prior to the expiration of this period. Lender may invoke any remedies pc'emitted by this SCQuritY Instrument wimout further notice or demand on Bonower. 18. Sorrower's IUght tu Reinstate. If Borrower meets cmaio conditions. Borrower shall bave lhe right to have en(or~ement of this Security Instrument discontinued at any time prior to tbe cartier of: (a) S days (or sucb other period as appliCable law may specify (or reinstatement) before:: sale of the Property pu~u.ant to any power of sale contained in thiS Securil}' Instrumezn; ot {b) miry of a judgment eDforcing this Security InslnlDttUI. Dose condjdon.s are Ibat Borrower: (a) pays Lender all 'sums which then would be due under this ,Security InstrumeGt and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security'Imtrumeot1 intluding, but not limited to, reasonable anomeys' fees; and ((1) t.uces such action as Lender may reasonably require to assure that the lien of this Security Instrument. Lender's rights in the Property and Borrower's obligation to pay the sums secured by this ,Seeurity fnstnunent shall continue unchanged. Upon re:insCatement by Borrower, this Security fnsrrumenc and Ute obligations secured hereby shall remain fully effective as if no IICccleralion had occurred. However, tm! right to reimtate shall 001 apply in the cue of acceleration under p.1J',sgraph 17, I 19. Sale of Note; Cbange of LOin' Servicerj Notice of Grievance. The Note or a partial interest in the Note {together with this Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the CDtity (kn()wn I\S the .Loan ServicerW) thaI collects monthly paymenls due under the: Note and. this Security Instrument. There also may be one or more chiIDRcS of the Loan SerYicer wuelated to a sale of the Notc. If mere is a change, of the Loan Serviccr, Borrower wi!! be siven wriuen OOlite of tha change i.o accordance with paragraph 14' above and applicable law. The notice will state the name and address of the new Loan Servicer and the address to which payments should be made. The notice will also contain any other information required by applic.able law. Neither BOITower nor t.eader may commenCe. join. or be jomed to my judicial aclion (as either aD individualliligant or me member of iI class) that alleges that the other pasty bas bteached any provision of, or any duty owed by reasOD of. this Security lnstrumenr. Wltli such Borrower or Lender iw notified. the other partY (with such notice given in compJiaacc with the requirementS of Scc;lion 14) of soch alleged breach and afforded 1M other party heccto a reasonable: period after the giving of such notice to take corrective action. If Applicable Law provides a time period which must elapse before certain action can be laken, rhal time period will be deemed to.be reasonable for purposes ~f this pangraph. 20. Hazaidous Substanees. Borrower shall not cause or permillhc presence; lUe, disposal, storage. or release of any Hazardous Substances on or in me Property. Borrower shall not do, nor allow anyone else to do. anything a((ecdng the Property that is in violation of any Environmental Law. The preceding two senlences shall qol apply to the presence, use, or storage: OJ) the Property of smJll qu.antitieJ of Hazardous Sub,nances that arc generally recognized to be: appropriate to noJ'lIlal residential uses and 10 mainlenance of the Property. Borrower sball promptly give lender wriUtD nolice of any invesligati011, claim, demand, lawsuit or omer action by any governmental or regulatory ageney or priVale party involving the Property and any Huardous Subsram:. or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any gove~ntal or regulalory authority. that any removal Qr other remediadoD of any Hazardous Substance affecting che Propeny u necessary, Borrower shall promptly rake all necessary remedial actions in accordance with Environmental Law. A3 used in this paragraph 20, -HazardoUS Substancesw are those substances defined as toxic or bazardou$ substances by Environmental Law and the following substances: ga.soline. kerosene, olber flammable or toxic peuol~ products. lollic pesticides. and herbicides, volatile solvents. materials containing asbestoS or fonnaldebyde, and radioactive malerials. As used in this pafJgraph 20. -Environmental Law" means federal laws and laws of !.he jurisdicdon where the Property is. located mat relale to health. safety or environmeJllal protcction. NON-tJNIli'OlIM COVENANTS. B......"er...d LODder lUJ1ber "'.._ and ".reo as 10110"" 21. Acceleration; Remedies. Lender shall give 'notice to BolTOwer prior to acceleration following Borrower's breach of an)' covenant or agreement in this Security Instrument (but not prior to atclC~ioD UDder paragraph 17 unless applicable law provides otherwise). Lender shall 'Ratify Borrower of, among other thinI': (a) the default; (b) the actiOD required to cure the default: (c) when the default must be eurcdj and (d) that failure to cure the default as ,speciified may result In acceleratioD or the SWD5 secul'ed by thk, Security lasrrument, foreelD5W'e by judicial proceediDg ildd sale ot the Property. Lender shall further infonn Borrower :of the right to reinstAle after aceelU1ltion and tbe ricbt to assert in the foredOliure proceeding the non-exlstence of a default or any other deleuse ot BOlTOWer to aa:eleratI'on aDd foreclosure. U the default 15 not cured as spec1ned, Lender, at its option. may require immediate payment In full of all sums secured by this Security Instrulllent without further demand and may roreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collett aU expenses ineUITtd in punuing tbe remedies provided in th& paragraph ZI, Including, but DOt limited to, attorneys' fees IJnd costs or tide evidence to tbe extent permitted by applicable law. 22. Release, Upon payment of all sums .$t'cured by this Security Jns.IlU%Dt!Dt, this SecuriIy lmtrumt.DI and the eslate ~nveyed shall terminate and become void. After such. occurrence, Lender shall discharge and salisfy this Security Insuument without charge to Borrower. Borrower shall pay any recordation cous. D. Waivers. Borrower, to the extent permitted by applicable l:lw. waives ttnd releases any error or defects in proceedings to enforce this Security lnstrumem, and hereby waives the benefit of any present or fuNre laws providing for stay of execulion, extension of time, exemption from attachment, levy arId sale. and homestead cxemprion. 24. R'elDSlatement Period, Borrower's time to reinstale provided in paragraph 18 shaU extend to one hour prior to the commeno.:ment of bidding at 1 sheriff' J sale' or other sale pursuant 10 this. Sccuril1lnstlUJDtDt 25. Purchase Money Mongage. If any of the deb~ secured by this Security Instrument is 11m! to Borrower to acquire title to the Property, Ibis Se<:u.riry Instrument shall be a purchase money monzage. 26. Interest Rate After Judgment. Borrtlwtr agrees that the interest rate payable after a judgment is mtered 00 the Note or in an aClion of mongage foreclosure shall be the rall! payable from time to lime under 1he Note. \ { j PAOOOO'S""" 430004519 ,Biiu.K1570fAGl .588 '""'~ - 1:1. Riders to this Security Instrument. If OD~ or more riders arc executed by Borrower and rel:orded together W\th lhis Security !nstnunent, the covenants and agreements of each. such rider shall be incorporated into and shall amend and suppLement the covenants 8J1d agrtement5 of this Secu.riry lnslrument as if the rider{s.) wefe a part of this Security lnslJUU1enl. (Check applicahle box(es)} o Adjustable Rale Rider 8 Graduated Payment Rider Balloon Rider o VA Rider o Condominium Rider 8 Planned U. nit Development Rider Rate Improvement Rider O<he<(,) (specify] o 1-4 Family Rider o Biweekly Payment Rider D Second Hame Rider BY SCGNlNO BELOW. Borrower accc;pts and igRes to the cemlS in any rider(:;) executed by BoJTOwtt and rccotded with if. Witnesses; ;L /'J 7 ----> , / .~ ~ (Seal) -Botrower (Seal) -Bonowtr (Seal) -BoI'lO'Ncr (Seal) .Bomlwer Cer1ificafe of Raidence I, Micl-PeJUl. IJ)stt'act the within-named Mortgagee is 75 WilneR my band this . do hereby certify that the comet il.ddress of North Fairway Drive, Vernon Hills, XL 60061 r .1. - / ) o/"'f day of .;. /,-1"11,),,~/ /.. :' / , ~'- Nid.Pe Ab.~r~ct. Agtl\lof M0Tt811U /" fl, On this, <he \ 0 Vc, porsooally appoored .-sa..> ""- L COMMONWEALTH OF PENNSYLVANIA. '0"-~~?~ '- ~ dayo! ~\"~- L.:..-\\--., \r--.s~ COUDty .ss; , \'\.'\.1 . before me, the undersigned officer. known to me {or &atisfactorily proven} to be the penon whose name '-So subscribed to the within. instrument and acknowledged that ~ executed the same for the p\lIPOses herein CODtained. IN WITNESS WHEREOF, I hereun'o se, my lLmd and official "'al.~ My Commission Expi,es: . .'" ~ \ \ NOTARIAL SEAL ' JOO.,. GOLDRING. NoliH~ Pu'ohc HaniSburg, Oa\lJlhin Counly P,A . MV Commissicn Expire) !l';'J .?~_:?lj1 ~~ ~- . '\ t"~~. NC<)(~ Tldco/Officct '- \ ,_Jo\~<- PAOOOO16l9ol121 U0004519 1"11.1 a' II BoodS70'AGE .589 =- > . ~, 1!lW'':." Description All THAT CERTAIN lot of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a mag nail set 6 feet south of the centerline of Ball Park Road (T-525), which point is on the line of lot No.2, as shown on the hereinafter mentioned Plan of lots; thence along the latter and through a concrete monument located 29.81 feet from the point of beginning, North 35 degrees 50 minutes 48 seconds West, a distance of 290.63 feet to rebar set in the base of a maple tree on the line of land now or formerly of Brian Starner; thence along the latter, North 48 degrees 58 minutes 59 seconds East, a distance of 150.24 feet to an existing reba, on the line of land now or formerly of Bryon Stamer; thence along the latter and through a reference rebar set 25.06 feet from the centerline of said public road, South 3S degrees 50 minutes 4B seconds East, a distance of 314.76 feet to an existing railroad spike in the centerline of said public road; thence along the latter, South 58 degrees 12 minutes 07 seconds West, a distance of 150.00 feet to a mag nail set 6 feet south of the centerline of said public road, the Place of Beginning. CONTAINING 1.040 acres according to a subdivision plan for Paul J. and Martha E. Smith by Mark A. Kuntz, R.5., dated June 14, 1996, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 73, Page 89 and being designated as lot No. 3 thereon. BEING THE SAME premises which Donald E. Hawbaker and Sandra S. Smith, single persons, by their deed dated April 15, 1999 and recorded June 18, 1999 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 198, Page 31, granted and conveyed unto Jason L. leininger, MORTGAGOR herein. '-\:1 -' . ,~- . .- , .",. .:::] .~" .4 ..,.~-;... ",. ._~-:-. Bood570 PAGE .590 ~ th!~ki:" -.. BS706-R1st January 09, 2000 Jason L Leininger 62 Ball Park Road Gardners RE: LOAN NUMBER: PROPERTY ADDRESS: 17324 Current Servicer: 0430004519 62 Ball Park Road , PA PNC Mortage 539 S 4th Avenue Louisville, KY 40202 AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. 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 its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance. ) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) . NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 62 Ball Park Road Gardners PA 17324 IS SERIOUSLY IN DEFAULT because: As of 01-05-00 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are past due: Payments from 11-01-99 through 01-05-00 * PAYMENT AMOUNT 952.20 * PAYMENTS NOW DUE 3 * LATE CHARGES 76.22 * RETURN CHECK CHARGE .00 * OTHER FEES .00 * LESS UNAPPLIED FUNDS .00 TOTAL AMOUNT PAST DUE: 2,932.82 HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 2,932.82, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: PNC Mortqage Corp of America, ATTN: Cash Services Dept, 75 N Fairway Drive, Vernon Hills, IL 60061. EXr\\B\1' ,,~ ~- . I~~, -.. APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE is is ~n official notice that the mort a e on our home is in default and the lender intends to foreclose. ecific information about the nature of the default is rovided in the attached a es. be o see if I-1~MAP can- bei -- ou must ~iEET V,1TH--A-,-CONSUl'.,1ER -CHEDIT -CO{JN~EL!NG A~ENCY I HIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with the Counselin2 Al!encv. This Notice contains important legal information. If you have any questions, representatives at the Cllnsumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. ,A NOTIFICACION EN ADJUNTO ES DE SUMA IMPORT ANCIA, PUES AFECT A SU DERECHO . CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A IOTlFlCACION OBTENGA . UNA TRADUCCION INMEDIT AMENTE LLAMANDO . EST A .GENCIA . (PENNSYLVANIA . HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO 1ENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA ,LAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL 'UEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS F YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE .CT OF 1983 (THE "ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PA YMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. EXHIBIT "Ad :.=: :".., ;; . 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Swte 100 St:J.te College, FA 16801 (8H) 238-3668 FAX (814) 238-3669 COLUMBIA COU!'<"I'Y CCCS ofNort.'leastem Pennsvlvania 1400 Abington E.:<e<:'~tive Park Suite 1 Clarks Summit: PA 18411 (570) 587-9163 or (800) 922.9537 F A.1: (570) 587.913419135 31 W. Market S"",et FOB 1127 W~~B~.PAI8702 (570) 821-0837 or (800) 922.9537 F_~1: (570) 821.1785 Commission an EconomitS Opportunity of Luzerne Count:1 163 Amber Lane W~-B=, PA 18702 (570) 826-0510 or (800) 822-0359 F.~"{ (570) 82S-1665-CALL BEFORE FAXING (570) 455-4994 H..>.ZELTON F.~1: (570) 455-5631~ALL BEFORE FA.'IDlG (570) 836-4090 TUNKH.-\.J.'<"'NOCK Booker T. Washington Center 1720 Holland St:'eet Erie, PA 16503 (814) 453-5744 FA.1: (814) 453-5749 John F. K..nnedy Center, Inc. 2021 East 20th St~t Erie, PA 16510 (814) 898-0400 F.-\X (814) 8S8-1243 CCCS of Western Pennsvlvania, Inc. 2000 Linglestown Road . Harr'.sburg. FA 17102 (717) 541.1757 Urban League of :.tetropolitan Harrisburg N. 6th St:'eet Harrisburg. PA 17101 (717) 234-5925 F_~1: (717) 234.9459 Co=unit"J .......:::on Co= of the Capital Region 1514 Derrv Street Harr'.sburi. PA 17104 (717) 2:32.9757 F.~1:(717) 234-2227 CRAWFORD COL?-<"I'Y Greater Erie Co=unit"J .......:::on Co=it'"..ee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban teague. Ine 601 Indiana Avenue Farrell, FA 16121 (412) 981-5310 CUMBE1U..AND Cm.rN'1'Y Fif"t:2 "";!:ll1 COWlSeling Serrices of Fr..mklin 31 West 3ni Street Waynesbaro. FA 17268 (717) 762-3285 YWCA of Carlisle 301 G StIftt Carlisle. PA 17013 (717) 243-3818 F.~1: (717) 731-9589 Adams Count'j Housing Aut.'lorit"J 139-143 Carlisle St c"ttysbUI'6. PA 17325 (717) 334-1518 F.~X(717) 334-8325 PEHNSY1.VANIA BUu.rnN, VOL 29, NO. 2:l, JUNE $, 1999 EXHIBIT "An "ti!- l.>i.*"; . Description All THAT CERTAIN lot of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEI:;INNINI:; at a mag nail set 6 feet south of the centerline of Ball Park Road (T-525), which point is on the line of Lot No.2, as shown on the hereinafter mentioned Plan of Lots; thence along the latter and through a concrete monument located 29.81 feet from the point of beginning, North 35 degrees 50 minutes 48 seconds West, a distance of 290.63 feet to rebar set in the base of a maple tree on the line of land now or formerly of Brian Starner; thence along the latter, North 48 degrees 58 minutes 59 seconds East, a distance of 150.24 feet to an existing rebar on the line of land now or formerly of Bryon Starner; thence along the latter and through a reference rebar set 25.06 feet from the centerline of said public road, South 35 degrees 50 minutes 48 seconds East, a distance of 314.76 feet to an existing railroad spike in the centerline of said public road; thence along the latter, South 58 degrees 12 minutes 07 seconds West, a distance of 150.00 feet to a mag nail set 6 feet south of the centerline of said public road, the Place of Beginning. CONT AININI:; 1.040 acres according to a subdivision plan for Paul J. and MarthaE. Smith by Mark A. Kuntz, R.S., dated June 14, 1996, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 73, Page 89 and being designated as Lot No. 3 thereon. REINI:; THE SAME premises which Donald E. Hawbaker and Sandra S. Smith, single persons, by their deed dated April 15, 1999 and recorded June 18, 1999 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 198, Page 31, granted and conveyed unto Jason L. Leininger, MORTGAGOR herein. PREMISES: 62 BALL PARK ROAD , , ~ ~.' it; . VERIFICATION TERESA SWITZER hereby states that she is SECOND VICE PRESIDENT ofPNC MORTGAGE CORPORATION OF AMERICA mortgage servicing agent for Plaintiff in this matter, that she 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 her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 1& Pa. C,S, Sec. 4904 relating to unsworn falsification to authorities, . d:,IL- r:I~, p , (j ~'SWITl.EA ...2nd\IICIPRlSlO6NT DATE: L//~ '3/tYD ,- ~_Iid~M!ti~~iifIjj~Ujlliilllli'llltllMi-~':!,llillM;~",",,<<,","~f!.~~liIflJ ~"~IIii~- ""iii: ., :-~~~r ,,_~_-i., l'liiliIiI "..:.c:" ,',. ":,..,,.1..:.1'. ___'_""v~!I"t~! '''',t:~~:~~-''"t~'; .r ~'.".~..~ - ~L",_ - =-1 . "P () <: iQ. It t h .t: c' .~ () .; ~ c: G ...:: ~ -, :& () -r:: i--:'~ . 0 GOo';" , ~ ~ -,. I L.. -<l" ~" C; f"'- .~ -', '0'- ~ r-- - ....:' .""'"> --- ~- ....... .....-'. ~ ?': , : ....--::: -- .. t -'-j :;-j -< - ~ ~ ;. _c, ~- - :I". ~j b > ~.t I. ~ : I,; , I Ii f, II ~': ~'! 1:'] ,. 1: '; 1-' , )'1 ii " ;] 1.1 !"l !' fJ Ii r! H ij 11 i~ f: rl iJ ii " i! f~ I: i :1 i [: u .. SHERIFF'S RETURN OUT OF COUNTY CASE NO: 2000-02637 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC MORTGAGE CORP OF AMERICA VS LEININGER JASON L R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: LEININGER JASON L but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT - MORT FORE/NOT On May 18th , 2000 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep. York Co. 51.20 .00 88.20 05/18/2000 FEDERMAN & PHELAN ~~ .' Thomas K e Sheriff of Cumberland County Sworn and subscribed to before me this ,2-1 '5:: day o~ h'J ;;L0ll""0 A . D . ~ Q Iltdi.--'f~" Prothonotary - ."' 0; . lli:ifj~ , , SHERIFF'S RETURN - REGULAR CASE NO: 2000-02637 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC MORTGAGE CORP OF AMERICA VS LEININGER JASON L 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 LEININGER JASON L the DEFENDANT , at 0013:28 HOURS, on the 3rd day of May , 2000 at 62 BALL PARK DRIVE GARDNERS, PA 17324 by handing to JASON L. . LEININGER a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 6.82 .00 10.00 .00 22.82 So Answers: e"~-~t:~t R. Thomas Kline . . Sworn and Subscribed to before 05/18/2000 FEDERMAN & PHELAN ~ By:. ,- .~ .- .. ~~ Sheri me this 01,<(' ~ day of ~ ~ A.D. C~. Q -n"OU.. '.'~ P othonotary COUNTY OF YOFIK OFFICE OFTHE SHERIFF 26 EAST MARKET ST., YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINE 1 TO 12 DO NOT DETACH ANY COPIES 1. PLAINTIFF/SI PNC MORTGAGE CORP. OF AMERICA 2. CQURT NUMBER ~0-2637 Civil 4..lYPE OF WRIT OR COMPLAINT 3. DEFENDANT ISI JASON L. LEININGER - ---- ------ -- SERVE { 5. NAM~ OF INOlVIDUAL COMPANY, CORPORATION, ETC.JO S.ERlIE_OR_OE$CRIPIIQN OLPilOPEBTY TO.!!E L_E\iIEO. ATTACHEO" OR SOLO.. _ ~ JASON L. LEININGER ~ 6. ADDRESS (STREET-OR RFQ WITH RaX NUMBER, APT. NO.,.cITY, BORD, TWP., STATE A~D.ZIP CODE.. AT DAVE LEININGER PAVING, 119 TUCKAHOE ROAD, DILLSBURG, PA 17019 7. INDICATE SERVICE: 0 PERSONbL 0 PERSON IN CHARGE DEe.UTIZEC:UJ11~a.mId ___ _ _O_lST ClASS MAlL_ _ _ 0 POSTED 0 OTHER NOW 5 / 1 /0 0, 2~__~BI:IERIFF OF ..._ COUNTY, PA do hereby deputize the sheriff of York COUNTY to exec - (j make retur f according to law. This deputation being made aUhe request and risk of ffie plaintiff. . MORTGAGE FORECLOSURE 8. SPECIAL IN8.TRUCTIONS OR OTHER INFORMATlON THAT WILL ASSIST IN EXPEDITING SERVICE: SHERIFF 0 0 N Cumberland OUT- OF COUNTY CUMBERLAND ADVANCE FEE PAID BY ATTY NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watcbroan, in custody of whomever is.founcLJn possession, after notifying person of levy or attachment, without liability on the part of. sucb .deputy or the' sheriff to_ any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. lYPE NAME AND ADDRESS of ATTORNEY J ORIGINAT and SIGNATU/L ';. .. ,: FRANK FEDERMAN, ESQUIRE /14~ f d~' t 2. SEND NOTICE OF .SERVICE COpy NAME AND ADDRESS BElOW:_ (Jbis..are_a must.be__c.omRlete_<t if notice iHo be maUad).._ 10. TELEPHONE NUMBER 11. DATE FILED (215) 563-7000- 4/28/00 TWO PENN CENTER PLAZA, XMXE SUITE 900, PHILADELPHIA, PA 19102 ~ ~$PACE BELOW FOR USE OF TH\;SHERIFF. DO NOt WRITE BELOW THIS LINE 13.1 acknowledge.receipt otthe writ 14. DATE RECEIYED 15. Expiration/Hearing Date orcompla;ntas;nd;catedabove._ J. LUDWIG 5/2700 5/30/00 16. HOW SERVED: PERSONAL RESIDENCE ( POSTED ( ) POE SHERIFF'S OFF ( ) OTHER ( SEE REMARKS . 17.0 I herebY3,erlify and return a NQT FOUND because I am_u.Q!'lb!e_to lo.cate tbe in.d-!}'Jgllal.,. c.Olppany, ~tc. _n~med above..jS~e remarks below.) _ 18. N E AND TIT OF ID l SERVED / LIST ADDRESS HERE IFNOT~SHOWN AElOVE (RelatlQnsblp to Defendant) 19. Date of Service < -//-00 ('\" 41. AF IRMED and ::j'\J~arjftfUAI.P~e this MELISSA J. SHAFFER. Holary Public 42. da of C".~Y"k. Yq~'l<l. My c.~v-:-:jT_!,?~!'~:'"l \':'''u:,q;:; APi1f2Q.. H 6th 44. Signature of Dep. Sheriff 45. Signature of York County Sheriff William M. Hose 46. Signature of Foreign County Sheriff NATURE. ~ /t 47. DATE S-//-oo 48. DATE 50. I CK WlED RECEIPT'OF THE SHER[FF' _ R OF AU HOR/ZED ISSUING AUTHQRIIY AND nTl - Issuing Authority 2. PINK. Attorney 5/16/00 49. DATE 51. DATE RECEIVED. _ 4. BLUE. Sheriffs Office , " "RECEIVED" OFFICE OF SHERIFF YORK. PA '00 (~RV 2 PrI 1 17 . , . ",,_Ill_If _ V~K~~\I.~~;lfh%;t,'!.-~ Gj-ti-W rTl!.~,v~~~Jij$lIi!'!if,:r~~l~..",!(qW~' Mi)~,'''-'~!i+~l1mr~l'lW!~il!~\~\~l~H~b#i:~l'""",~ ~ "~"_"""''''',:;,'i''' .' ~~~''''!'';'''''~~J";'~ ,,",",.,~>\.,..},,,,""t.:,,>, ~, "',!,~" - !:f,,,,,;~';'i "",- .- ".,., ""';'';1''~iH,]~~''F:'f~:"j~',41'ii"Bf'.'1 , ~: ._~~""'~'._.4'_-' \ .':-C'. . ' .. '" COUNTY ?i10RK . . OFFICEOFTHE SHERIFF ,~~z.,xeJi!<.IiW;'~l, . SERVICE CALL (717) 771-9601 ~" 26. ..''''''''''''''~''. ~"'- -'. "'... t. eLAINllFF ,_. ,< . --,'; --- PNC ~GAGE CORP._ OF AMERICA 3. DEFENqAfo!;m>/ JASON.:.t. +VE_...{....' AT :.:.. LEININGER 5. NAME dE INDWlbUAL COMPANy, cbRPQRAnQN.J::m~to'_SEaVJ;; ORDESCalEJI JASON L. L~lNINGRR INSTRUCTIONS PLEASE TYPE ONLY LINE 1 TO 12 DO NOT DETACH ANY COPIES 2, COjU.ElT NlJMBffi , . ....U-~bTl ClVll -4.' TYPE OF WRIT OR COMPLAINT - MORTGAGE FORECLOSURE .. J..r~. . '.. .... $H.ERIFF. SERVICE ....'. PJl'OCESS RECEIPT, and AFFIDAVIT OF RE"'URN .;;,."'f. ,......;: ..'__J.' . . N Qf P-'LQl'EfiD'TO_E."EI'IIOD.ATTACHED.l:lBSQ\.D, 6. ADDRESS .(STREET ORRFO W1T.H .sox N_UMBffi.P.flT~MQ,.. C'LTY":.eo.8Q,. "IYiR, STATE AND Z!E.'.C.o.~. . DAVE LEININGER PAVING, 119 TUCKAROE ROAD, DILLSBURG, PA 17019 1,INDICATEs..i$VICE' . 'OPERSOHAL . a PERSON IN.CHIIRGE. XLDoeurieI:U).no.'t.~.~i;l['l ,Q l.ST~,MA!L J:,-P.oSTJ;P" a OTHER NOW 5 / 1/00 _,~, ... .~. SHERlFEPf'/t~~QODI'-ln;-P~, d611elee.'U1i!lJ?u!i?~tb~s:n:.erl1[0r. . ,aoGEK,"" ,. .cC:;,.i;."",c.. .,"-~'::'\ "_~; -<-""--CQ\,Jm'Y[qexecute tn!~WJiL~fld fT@KEl.!e\lfrniliereCl.f.acc.ordin..9.. , to law,' Th~._.q.eput~liO!1 bei'l9 ma:de at the. r..e.q.\J.~;ta:.[ld riSK. ?fthePI.airitiff'.' ..... ~u.__. - .,-.- .. . ....~u ,.... .,' . - SHe~lFF OF2[IEl!:J:OUNTY 8, SpECIAL <N!;TRucnONS OR OT;lER iNfORMAnON TKAT WILL I\SSlSTJNEOl(pOQilli'&.SoBYlCo: ____ _.,. C Umb e r.l and i .. OOT OF COUNTY ,'",_ ~. ;~+'~~4~:~~'.;;-;.;; ~)- r.')' "~i'~"(~ r -~, ADVID FEE PAID BY' KJ:TY NOTE ONLY ~UCABLE ON WRIT OF EXE;cunON: N.S. WAIVER..OF WATCHMAN ~ lWy deputy sheriff I~vying upon o-r attaching,any'prop!;}fty under within writ may leave same without a wat~an, in cus.tody of whomever i$ found if) possession, after notifying person of revy or attachment. witho.ut l1ahJfffy on th(;t --p~rfOf' such deputy or the.. sheriff Ie any plaintiff herem fgr anyl9is, destruction, or removal of any prqpE:lrty before sher!tt:s sa!(;llhElreof. '~.' '.. ' ~' - ~ .' R TYPE~~.P.~., DADDRE.?~:o~~n9R. N'P'lO.RIG1N,AT ,a.i1d sr~"~.AJY~y:j t"_.... - .~ :~> _ . L'~ Hi. TElEPHO~.NWivU3ER-- 11. DATE FILED FflANKu!!IJERMAN, ESQUIRE_' . /Ut1t.h;;.:/~t:-,~,"<,~u . - (215) 563-7000 4/28/00 . 12.. SEND NO_I)~EOF SERVICE COPY NAM~ AND .;PpRE.SS SE:LQ'(V: {Thl~..at~a..(QY$.l;le .c.9ffiPlel~JLn.QtiC.l;! .is !o .b.e: J'naJI,fil91. -, __. . _____ TWO PdN CENTER PLAZA. xm SUITE 900,TIn:LAn'Et.PRIA. FA 19102' '. .~' .. '.. . -- . '. - .,' ~.,..' " ,"i,,,~~..}i-,,($'BJ;J::'O. Oft SEF THlfSHERIFF.I)ON'O....W .'BEL Vi THIS LINE 1'3. I acknowfei&e receipt of the wtit ._ 14. DATE RECENED 15. Expiration/Hearing Date orcoinPla:n~i;ndicatedabove, -J_.LlJJ:WlG 5/2/00 5/30/00 j6.H6w~, PERSONAt " RESIDENce () ...... :...PQ,\lTED ()L- eOE SHgRIFF'SO(f'(.). ()r~gR( 1. SE:"-HEMABKS, fr. Q I hereby"certify and re ~ n.a..,NOTFbUND because I. am~unabl~lo (ocafe: th~ rror0.~yar" CQrn~ny-,. alt:. nar:ri~<fa1:l~ve.~tse~ r~rn~:fi?~l~:r 18'. E AND 11 OF NDlVIDUAL SERVED lUST ADORESS HEREJF NOr SHbw.rfAeOVt:" .(ReJation~hlp to Detendan.O 19. Date of Service ,~, " .. .., " ...- S-./'.OO Time Miles Int. 22. REMARK - ...~)".: 1 ,..! r ),~ ..-1 I. .;;~(:: ltr..- t I$;d ___.' I , 4,.0..; 1. '. ,. . ~ ' .l;,(.u",<i' ~/ ,/,' t. ..... .... '>-- 26. Milage 40. Cost Due Of Refund .,~~ . ',' .--~', ...~. .,. " ' 41, AFF1BME6~/~~s'~;~~~\p~~efO!~ ,:~~\~: 42. day or ~::: May " -; ~ ...... 47.f~~E/_ ';'.." 48. DATE 5/16/00 49. DATE 51. DATE RECEIVED "",,.'.-,,--,-,,' . -..~~.BLl;E'". :.sherin S"t;"l'l.~~' .' " ,,:'~ ~.. .:'''' _.' .~~>{".I. '< , 1. WHITE . Jss~tQ~ Authority ,.~- _ ______ ~r,!. .'~< -,.."..,--,..,..~;,,'~!; '-'_."'~"'-'-."."":':_. ~ I "' .' ~,.: .. FEDERMAN AND PHELAN By: F~FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, P A 19102 (215) 563-7000 Attorney for Plaintiff PNC Mortgage Corporation of America 539 South 4th Avenue Louisville, KY 40202 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. : NO. 00-2637 Jason L. Leininger. c/o Dave Leininger Paving, 119 Tuckahoe Road Dillsburg, P A 17019 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAll.,URE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against Jason L. Leininl!er, Defendant(s), for failure to file an Answerto 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 3/1100 to 6/13/00 $114,871.61 $2,371.95 TOTAL $117,243.56 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, copy attached. i(*~ F~ FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ...L..ue.... I~ '::l.noc> /.s/ (l.b1"i/i ~ ))-~ I ( PRO PROT **TIllS FIRM IS A DEBT COLLECfOR ATIEMPTING TO COLLECf A DEBT AND ANY INFORMATION OBTAlNED 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 ATIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAlNST PROPERTY. ** . .~-- ~ " ,........""'..- I ,~ FEDERMAN AND PHELAN Frank Federman, Esquire rdentification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PNC MORTGAGE CORP. OF AMERICA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY JASON L. LEININGER NO. 00-2637 i1 , Defendant(s) ii TO: JASON L. LEININGER C/O DAVE LEININGER PAVING 119 TUCKAHOE ROAD DILLSBURG, PA 17019 DATE OF NOTICE: JUNE 1, 2000 FILE COpy 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 DI,SCHARGE 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. IMI?ORTANT 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 Judgmeht 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,PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff .- ~, FEDERMAN and PHELAN By: FRAJ{KFEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff PNC Mortgage Corporation of America : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Jason L. Leininger : NO. 00-2637 Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRAJ{K 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 Jason L. Leininger is over 18 years of age and resides at 62 Ball Park Road, Gardners, P A 17324. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. t(17~ FRAJ{K FEDERMAN Attorney for Plaintiff ~ - ~ ~1c. , , (Rule of Civil Procedure No. 236 - Revised) PNC Mortgage Corporation of America : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Jason L. Leininger : NO. 00-2637 Defendant(s) Notice is given that a Judgment in: the above captiOIled matter has been entered against you on June //..{ .2000. . ... . .. .IBJ: )Jar- ~ .97pm/Y~ r- DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWQ PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 "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 THIS 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. .. r~IDilIli!M~iii;Jlih;!';iil4l"",i"'"tl,U&l\!,i>""".ili!l:li-",,--,,,,-"",;~~~I!,,~",~,, """,:..,~,,,,,-""'W;)ms!m-.Jiitj~tN '.. .. [jl:&l;i ~~ ~ P)~~ ~.~ ::;:. .,. 6'- ~ -~ ~ K ~ -.0 o o ft! ) . ~" ",' I. ~~"lflllailil~lll" =l ~ ~. (':) C <- We';; [nrT~ ~?,: w> ~f!.~ 27G ~-= () -c z ::;! ~---"'" ~""""'~t,' , , . o CO (:') -n :... '- ::;;:;: .1::- , ''''1::'::: .'j L -- "J !".:.; =!j ,~~iC,~ ~ :rJ -< -0 :1\': :::> (r, I !'i ..... !\ i" i ., , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 PNC MORTGAGE CORPORATION OF AMERICA Plaintiff, CUMBERLAND COUNTY v. No. 00-2637 JASON L. LEININGER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $117.243.56 " Interest from 6/13/00-12/6/00 $3391.52 and Costs (per diem - $19.27) $120.635.08 TOTAL Note: Please attach description of property.No. _~'tiiUi~iiMiItiI- "1'~l€llllm~~Ij;'jYj!irn3l!I"do:lMl~""""*"'" 0" ,,- ~.,... ~ 4.~ ~'lii!~-- ~=n~ ~~~.... oJ .~ ~ ~b .= -;'-;1 ",.. ~"'" <M o~ ~.... ~~ ~ga ...:l~ ...;:$ Z ~~ o~ ... 0 ~" '11;;;- 0 .... <...:l Z Eo< f;l;l>o ~ ...:l'l1 0 U ~~"'" -d .... ~~ Eo< ~ f:J'F f;l;l<M " ~ f;l;l "o~ ~ 0 Of;l;l " f;l;l = ~~.... '" z '" ::?j~ 0 ... <:> z~< " < .... 0<> ..c ::?j;;.; ~< z .... ~ ... f;l;l<oo ~ 0 8~ oU .... Eo< .. 0 .; f;l;l ;~ ...:l~~ S 0 U; ...:l N .. ..J...:lf;l;l '" "'0 f;l;lf;l;l ..J ~~ .... SO Z...:lZ " ~U ,,~ Z ~.:n O<~ @' " <- 0 Ot: 0- f-< ~~ ,,' '11=< " ~~ '11 ... <:> ;:;~" .... ~ -< f;l;l6 jj 8; ..., ~ ~ 0 .... '" ::?j U '" f;l;lf;l;l f;l;l ..c; " == U ~ ~ Eo<::?j " Z - .~ z~ ~ ~ ... ....u J " ~,. b.,," . DESCRIPTION ALL THAT CERTAIN lot of land situate in Dic~on Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a mag nail set 6 feet south of the centerline of Ball Park Road (T-525), which point is on the line of Lot No.2, as shown on the hereinafter m~tioned Plan of Lots; thence along the latter and through a concrete lJ?onumtmt located 29.81 feet from the point of beginning, North 35 degrees 50 minutes 48 seconds West; a distaiiee of 299.63 feet to rebar set in the base of a maple , "" ' tree on the line of land now or formerly of Brian. Stanier; thence along the latter, North 48 degrees ' 58 minutes 59 seconds East, a distaDce of 150.24 feet to an eXisting rebar on the line of ian.dn.ow formerly of Byron Starner; thence aJong the latter and through a reference rebar set 25.06 feet from the centerline of said public road, South 35 degrees 50 minutes 48 seconds East, a distance of 314.76 feet to an existing railroad $pike in the centerline of said public road; thence along the latter, South 58 degrees 12 minutes 07 seconds West, adista,nce of 150.00 feet to a mag nail set 6 feet south of the centerline of said public'road, the place of beginning. CONTAINING 1.040 acres accorlting to a subdivision plan' for Paul J. and Martha E. Smith by Mark A. Kuntz, R.S., dated June 14. 1996, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 73, page 89, and being designated as Lot No.3 thereon. BEING Parcel Number 08-16-0210-147. TITLE TO SAID PREMISES IS VESTED IN Jason L. Leininger by Deed from Donald E. Hawbaker and Sandra S. Smith, single persons, elated 4/15/1999 and recorded 4/26/1999 in Record Book 198 page 31. _N~_~IiilD!lIbIlJi~~-ii'j;!<lll4lii>lk",",~~""'\;.""'~ '~~." ~.- ~1IlIi~- ,-.''" .'.... . ~ ~ ...... ./q l l Gl. "<l. ~ ~ .~ 11 ~ . - ..p j;:; d . ~ b ~ 0 '1 d p b ....0 C C' C ,.. r- i J \ J , 0 0, I I ~ t &' K (") a ~ c a " '_.J s: -.'"I :"Dw ~ , , .. , EPr,fi ,- , ... , .. - t-~ -- , G? :::1' -t 2:(~ i\,) ,.., ~ - ~ ~2~:' Cn ;._. - .... ... ~G ' " ._'..... ):>: "'~ ,--I'....; Y-I ~Q '-:!-,. t " _t:o ,:- .-;~ :-.r: ..,t.~C, - .;~~~ c - ~ .. "'" -, :p: '::0 '< t ., Ce, 0, '1," 'Ii 'i 'i ~j PNC MORTGAGE CORPORATION OF AMERICA CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JASON L. LEININGER CIVIL DIVISION Defendant(.). NO. 00-2637 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) , I PNC MORTGAGE CORPORATION OF AMERICA, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 62 BALL PARK ROAD. GARDNERS. P A 17324. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JASON L. LEININGER 62 BALL PARK ROAD GARDNERS, P A 17324 , I, f' I':: H I,: ". n u ,i I;,' ~ " 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) b! I, ii! iii I:: fii "I Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None .- ' , ' ~ ... 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) PNC Mortgage Corporation of America 75 North Fairway Drive Vernon Hills, IL 60061 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) , , None i II ,. I: , t.: i': 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: I::i 1.1 1,1 i.1 IJ , ":i !,,: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant ,.i 'I i:i :1 II' I fl 1:] Ii] il'.. I, ~I 62 BALL PARK ROAD GARDNERS, P A 17324 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. August 23. 2000 DATE ~~~ F K FEDE , ESQUIRE Attorney for Plaintiff FEDE~NandPHELAN By: FRANK FEDE~N Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEYFORPLAmT~F PNC MORTGAGE CORPORATION OF AMERICA Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DMSION JASON L. LEININGER NO. 00-2637 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant ( X ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FJK~~E~;~ ~ Attorney for Plaintiff --..I.v" I I' i, f;' " f. ;, ;1 i:i ~ilivm_-r",",iJLuio_ilMBiI!lI1ifHljlllii~~~~~=~ ~ ........,IIM-~ ~ iII..............."""-'. '-fl.~JIiIlBj."'" ~o )>C -':::" Z J -r~~ )>.......; C si Z r. =< =0 --< ~ - . , . . . PNC MORTGAGE CORPORATION OF AMERICA Plaintiff, CUMBERLAND COUNTY v. No. 00-2637 JASON L. LEININGER Defendant(.). August 23, 2000 TO: JASON L. LEININGER 62 BALL PARK ROAD GARDNERS, P A 17324 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY," Fj Ii I: I " I' I' Your house (real estate) at 62 BALL PARK ROAD. GARDNERS. P A 17324, is scheduled to be sold at the Sheriffs Sale on DECEMBER 6. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by PNC MORTGAGE CORPORATION OF AMERICA(the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the _March 7, 2001_ Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE r! . i'; H To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings. " You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3, The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ~-~"" , Ii 1:1 i.:1 I[.i :'1 II j'; ::i i;j i'l h: i'l H " H n f:! i;j II I; I; " r,: U I:! !j :'i , :,j I'i ',j [ 1:1 1'1 :! il .[ \1 ~.l ~ 'I 11 ;1 I[ Ii II I' i [I II J I I -J..,., DESCRIPTION ALL THAT CERTAIN lot of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNlNG at a mag nail set 6 feet south of the centerline of Ball Park Road (T-525), which point is on the line of Lot No.2. as shown on the hereinafter mentioned Plan of Lots; thence along the latter and through a concrete monument located 29.81 feet from the point of beginning, North 35 degrees 50 minutes 48 seconds West, a distance of 290.63 feet to rebar set in the base of a maple tree on the line of land now or formerly of Brian Swner; thence along the latter, North 48 degrees 58 minutes 59 seconds East, a distance of 150.24 feet to an eXisting rebar on the line of land now formerly of Byron Starner; thence along the latter and through a reference rebar set 25.06 feet from the centerline of said public road, South 35 degrees SO minutes 48 seconds East, a distance of 314.76 feet to an existing railroad spike in the centerline of said public road; thence along the latter, South 58 degrees 12 minutes 07 seconds West, a distance of 150.00 feet to a mag nail set 6 feet . south of the centerline of said public road, the place of beginning. CONTAINING 1.040 acres according to a subdivision plan for Paul I. and Martha E. Smith by Mark A. Kuntz, RS., dared June 14, 1996, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 73, page 89, and being designated as Lot No.3 thereon. BEING Pucel Number 08-16-0210-147. TITLE TO SAID PREMISES IS VESTED IN Jason L. Leininger by Deed from Donald E. Hawbaker and Sandra S. Smith, single persons, dated 4/15/1999 and recorded 4/26/1999 in Record Book 198 page 31. . . . , .- ._---'---:.~.._->.'''''-''',,'., .... ' , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , PNC MORTGAGE CORP. OF AMERICA. Plaintiff CIVIL DIVISION vs. No. 00-2637 CIVIL JASON L. LEININGER Defendant AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for PNC MORTGAGE CORP. OF AMERICA, hereby verify that on AUGUST 28. 2000, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded Iienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on AUGUST 28. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ~~ ~'=- RANK FEDERM , ESQUIRE Attorney for Plaintiff Date: November 2. 2000 ~ ~.k,,^ 1,,1 i] :'1 , I , i I i ;:: , , I :',1 Ii Ii I';! II 1 !'1 'I n " ,. ,"I !'i ",1 !'j I;': :. I,j :1 !1 ., 1'1 "'I " '''; ;,] 1 ;,j !J :'1 :'i ,. i f:1 1,,1 :,:1 i iJ -~-, -,. ~;;i R Pi. ~z _.0 !'.3 nC" ""~ ~o en'" n " "" ~ t--> i~ i= ~.Z .. ,,"0 ..... ~ 3 t.tl li ~ (~ ~ r-:\ ~ ~)~ m~ ..S2 .g i. t~1 -3 l"'< ~ffi eli :"'.'" .~ .. n ~ N o ... f :or ~. . - - - v. ." - tv - - - '" <:;; '" co , !Mil!! kl \~\ ~~ ~~ " jii: ~~ ~ >: - ~.- . : _ 109(8909, : :::: 0 2' , ::: L..!"HW~';.;' '<ic:{ - - .. i.if,... ; gt...l9VlSDd"S"n IJ/- ~ ~ owtiiiit ~ ~E ~ ~O' ~~ . "",:_",,"~...," '},,"~^ ...f l" !::ioIIIo-___....v_ ., --=" . .... . '" v. "" ." w tv . "'..."'''' Z N/:!!jf"J...... =220 ~ ~~o~ S, 1:"'... ~'" > "'o=::l J"" >n=n ~n>:= o 2lol en ~::o~ 11 >~ -<... r .!? ~o g, Cl '" 2 ? > .., en ~ := ~~ 0 t::l I:'l 2l 2 ...n II I:'l .. 0 1;: 1;; n~ "" .. > = i '" ~I:'l > ...2: _ 00> ;;l f;;2 ~ . t::l "'n ::0 ....0 02 ...... "'><: ~-,""""",,~ ~~"""< I~ n 2,>2 "'..... '" ... a = .. '" i"B= .. = ... ~ ;;" n z o 3 C" ~ l "'..."" !:.:l!1:'l ;roc J~I ",= >ltRo .....'" ",,,,= I-';-~ S!lll:'" "'~ = i '" o o -g ,i n ;;' n .'~ -.. ..-.... .,p. ~;.. l.";", ~', ,. i 'C" TO: , P 9b9 D5b DLD "'.'.'-.C"',' ,JASON ~. LEfNINGER 62 BALL PARK ROAD GARDNERS, PA 17324 SENDER: REFERENCE: DMK SALES PS FORM 3800 SEPTEMBER 1 95 -.. CertilledFee RETURN RECEIPT SERVICE AetumAeeeiplFee _Dol""" Total Postage and Feee US Postal Service ,',,'- Receipt for Certified Mail No Insurance Coverage Provided Do not use for International Mail _lI~waiMMi.l!I~y,.i'ltJi~IiiIIi41iIJo~I~~"""i;t<niK><lf""'"",,,~;'(~I'ill'l!'''''>1.ii'"""'''''.....~_'""_,~~''='=o~="IIO,~!lmliill!iimlitll!ldf......,j-~ ~. - r '> - 0 a ,._1 C 0 " s:: z -oeD c:> nlrn <~.::: ZX, \, .' , Z,' , 63'"'> 0' ~';--~-' ~.~~~ ~ 1c w Z --j i'V e: =< :xl U"I -< ] <~ k,> . 4 STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. I, I , i' f I I ,. I i: f: !:. Robert P Ziegler I, ________________________________________________.__________________.__._______Ilecorderof Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which ------c--------- Federal Home Loan Mtg Corp ____________________________________________________________________________________ d thegr.antee ;; r, 7th the same having been sold to said grantee on the _________________________n______h____________ day of ___~~E~~__.___________h_____________ A. D., r ~~_~~, under and by virtue of a wriL____n_______ Execution . 28th _____________._________________ __ ___n _____ h_ _. ISSued on the _ n_________ _ ___ n__ __ _______________ Aug 2000 day of __________________________ A. D., _nn' out of the Court of Cornman Pleas of said County as of Civil 2000 ______________-______ _________. 0-- ___ ____________ __ _______ _________ __ __ __ _____ ____ Term, : -"2637. PNC Mtg Corp of America _0____' at the SUit of _______________________________________________________________ I:: Number _ . Jason L Leininger ___________________________________agaJnst____________________________________________________ 6 241 156 duly recorded in Sheriffs Deed Book No. ____h______' Page' ___n_______. .~ IN TESTIMONY WHEIlEOF, I have hereunto . -:-ti.. set my hand and seal of said office this _~_O_.____ day Of__)+:______. - -----il1----- .- ~"~~"'-- -- _tJ_f.t1~___ -. -_ __________ Il mer of Deeds He.GIller of ds. Cumbe~lnd County, Ca~isle. PA My CommisSion Expires ll1e fil$\ Monday 01 JaR. 2002 t. '. I PNC Mortgage Corporation of America -vs- Jason L. Leininger In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-2637 Civil Trevor Kent, Deputy Sheriff, who being duly sworn according to law, says on October 10, 2000 at 5:45 o'clock P,M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Jason L.Leininger by making known unto Stephanie Leininger wife at 62 Ball Park Road, Gardners, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Trevor Kent, Deputy Sheriff who being duly sworn according to law, says on 10/10/00 at 5:45 o'clock r:M.EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Jason L.Leininger located at 62 Ball Park Road, Gardners, Cumberland County, Pennsylvania according to law. R, Thomas Kline, Sheirff, 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 to wit: Jason Leininger by regular mail to his last known address 62 Ball Park Road, Gardners, P A. This letter was mailed under the date of October 11, 2000 and never returneq'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 within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 7,2001 at 10:00 o'clock A.M., E.S.T. and sold the same for the sum of $1.00 to Attorney Robert Liberman for Federal Home Loan Mortgage Corporation. It being the highest bid and the best price received for the same Federal Home Loan Mortgage Corporation, Foreclosure Unit, of Mail Stop 61, P.O. Box 5000, Vienna, VA, being the buyer in this execution paid Sheriff R. Thomas Kline, The sum of $838.87 it being costs. Sheriffs Costs Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 30,00 16.45 15.00 15.00 30.00 10.00 .50 1.00 6.82 .80 15.00 30.00 20.00 321.20 252.45 23.15 25.00 26.50 838.87paid by attorney 3-14-01 .~ . ~p~ R. Thomas Kline, Sheriff By",,!;;:., J~~ Real Estate Deputy Ii I I I, I; !J c 11 Sworn and subscribed to before me This ~ l)i.. day of ~-;.P 2001 A.D. Si"'-'r..L~O ~,~ Pro onotary I} ii ~ ,pJ'- -30,rri) 1.'01 Ue. 3J~J3 t2u--. I/)'tjp f., ., , . PNC MORTGAGE CORPORATION OF AMERICA CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JASON L. LEININGER r CIVIL DIVISION Defendant(s). NO. 00-2637 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) PNC MORTGAGE CORPORATION OF AMERICA, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 62 BALL PARK ROAD. GARDNERS. P A 17324. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JASON L. LEININGER 62 BALL PARK ROAD GARDNERS, PA 17324 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ;..... } " 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) PNC Mortgage Corporation of America 75 North Fairway Drive ' Vernon Hills, IL 60061 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 62 BALL PARK ROAD GARDNERS, PA 17324 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. August 23. 2000 DATE ~~~ F K FEDE , ESQUIRE Attorney for Plaintiff ~. , "<, "i" ...... PNC MORTGAGE CORPORA nON OF AMERICA Plaintiff, CUMBERLAND COUNTY v. No. 00-2637 JASON L. LEININGER Defendant(s). August 23, 2000 TO: JASON 1. LEININGER 62 BALL PARK ROAD GARDNERS, PA 17324 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS PEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TrEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 62 BALL PARK ROAD. GARDNERS. PA 17324, is scneau1edto be sold at the Sheriffs Sale on DECEMBER 6. 2000 at 10:00 a.m. in the Cumberland COWlty Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by PNC MORTGAGE CORPORATION OF AMERICA (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the _March 7,2001_ Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you m)lSt take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. !i ", \..].... You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney,) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to. the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the bllyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD.oNE, GO TQ OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE,.P A 17013 (711) 249-3166 (800) 990-9108 """,,"'" "'" " - :. ,~'" --- ,--, i.J..,.,,~' i,.l ,,~ DESCRIPTION ALL THAT CERTAIN lot of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a mag nail set 6 feet south of the centerline of Ball Park Road (T-525), which point is on the line of Lot No.2. as shown an tl1e l1ereixlafter mentioned Plan of Lots; thence along the latter and through a concrete monument located 29.81 feet from the point of oegin:ning, North 35 degrees 50 minutes 48 seconds West, a distance of 290.63 feet to rebar set in the base of a maple tree on the line of land now or formerly of Brian Starner; thence along the latter, North 48 degrees 58 minutes 59 seconds East, a distance of 150.24 feet to an existing rebar on the line of land now formerly of Byron Starner; thence along the latter and through a reference rebar set 25.06 feet from " the centerline of said public road, South 35 degrees SO mblutes 48 seconds East, a distanee of 314.76 feet to an existing railroad spike in the centerline of said public road; thence along the latter, South 58 degrees 12 minutes 07 seconds West, a distance of 150.00 feet to a mag nail set 6 feet . south of the centerline of said public road. the place of beginning. CONTAINING 1.040 acres according to a subdivision plan for Paul J. and Martha E. Smith by Mark A. Kuntz. R.S., dared June 14. 1996, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 73. page 89, and being designated as Lot No.3 thereon. BEING Parcel Number 08-16-021Q..147. TITLE TO SAID PREMISES IS VESTED 1.N Jason L. Leininger by Deed from Donald E. Hawbaker and Sandra S. Smith, single persons, dated 4/15/1999 and recorded 4/26/1999 in Record Book 198 page 31. -;--. '';:' '-:";~/::~~ . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-2637 Civil Term_ CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland COUNTY: PNC Mortqaqe Corporation of America To satisfy the debt, interest and costs due PLAINTIFF(S) from Jason L. Leininger, 62 B3.11 Park Road, Gardners, PA 17324 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description (2) You are alsodirectedtoall<lC!1ttJflprOP~rty of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otheWise disposing thereof; .. (3) If property of the defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee. yoLiare directedto notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $117,243.56 per ellem - :;'19.2/ Interest fr.om 6/1,/011-1 ?/h/OO - $"gl S? Atty's Comm % Atty Paid $183.02 L.L. $.50 Due Prothy Other Costs $1. 00 Plaintiff Paid Date: Auqust 28, 2000 Curtis R. long Prothonotary. Civil Division '-- bv: An....,. (1 2 /7(cJ2a~f./ Deputy REQUESTING PARTY: Name Frank Federman, Esq. Address: Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No, 12248 _-- iIlIUiillllillidliilllldllllliiililiillllllUMtilll iliilllllllli . REAL ESTATE SALE NOli' (;" ~ 31. d-PV the sheriff' levied upon the defendants inter>>,,1 in the real property c;ituated in/?7/~i A._:......... ~nfAo/ Currierland County, Pa, >ii' ': numbered as: i92 tfLtll/!,Jt..e. ~ and more 1ll< ~;c r'J bed on Exhibit "A" flied with this writ and oy this reference incorporated herein. rate: C(~J 31. d-,rrt> By:f1iE!ffL .~ ~ \11 ,_J::',1\'.]), ~ !.,'~: Jd "~I 1"L-;'. DO, Ii 2S Q! OS 3tiV AJJirc( ,- . JJiMiii,j c J(i"xf~~1l '",'--. ~,'~". "~., . > . - h<< ~! ~~~ESTmA1:E"NO:-ltj-' -.--.~ ~ . Writ No. 2000.2637 Ii~ "'- .-~' Civil Term _:0- ~NcMoitgai;le COTporatrorrol America _._~~~ - -- VS ~! . ifFJaSOi'lL:Lelni'riger~~' ~~~-;--- Atty: Frank F.ederman !""'~. , .. DESCRIPTION . ~ALI1HAT .CERTAIN' lot, of land situate 1n . Dickinson - Town5hip~ Cmnberland Count}; ~Il:nsylvJ.~~~, bou,nded and described as 'S: . 'NING at ,1Jpag nail set 6 feet 'soulh:6r .,- h:irlioQof1rn:JfPark Road (T-525);wni(h- ' l1_J,onthc fine ofLat No. 2'0 as slt';II';n..w . cntion~d Plan rifLots; thence' i~i.-~tiQ. Ihr9ugn"~a, 'conctffe". "bm 29][ fel'! from '-lliejoiiilj)'f It''M~~'5'''ifegn.'Cs 50 -minutes~'4S' l~t, a aislance of 290.6':rfed 10 rl'U5r ~(fUtUqS,f:.;.ciC<1JX@rle tree on lhe 1ine Of _an. !l..o~ or formerlY a. Brian Starner; .lheQI:.e BJnJiDlfe l1Het N"ofth-:-48'dl'gree~ 58 minures c,secon-ds "fast, a distance of 15Q:2-1 feet to an . J'.Ctlar .onOOrlirfc....cif.land .Doi.... or ~ y of13yron'Stam~?r;' thence. along the attcLJ,lJ,d.lbr9-ugh..aj'~feren'.c. rebar set 25.06 Ir""'l!i":{Rn:!'t\(~F of said public ,oad, -. . "'".5). ...5.". ee'.50-m..m.utes 48 seconds Easf, a ,l~~,' .. .14)6 feet'to an ~xisting railri)ad lke in t c centeJline of" said public road; .' .' ~c.~~[nKthe latter, Sout~ 58 def;!ecs 12 m~Qi. '::ocean-ds. \'\\S~ a dl5!anCe of 150,QO f(LQ,.a' m1-rn~n'set 6 feet south of the n rlinf. of sai~ 'public road,-lhc place .of ~~~ING'-;Q.W ~cre&' ac~ordjng t~ ''-'a ~ . n p,lan for Paul J. and Martha 'E. M:arlj,' A.-KUtitz, RS., dated June 14, iccoraet,in tlie Cumberland County 9rDecart:Jtfic~ in Plan Book i3, page k~'g.d.esiSn)J~d as Lot N.o. 3 thereon7 J'ar,cE:(Nurll'i;lediS-16-0210w147. - ..., ~.. JLSAJ]). fRtMISES ts VESTED IN !OEso.nn t..,--.Lcinin-S. St by ~eed .!~o.ni~D6n~~~~. ~aKer ana Sandra 5, SO'lI(h, smgle fp~<;ons, 'dated -:t7!S?1999' and recordea 41261 ~~~lXord:a2.9~ 198 .2.J.~:2!:__ .::..~_ _ ~_ __ '''''''.'''':! ;< , ... '\ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth ot Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That h,e 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 Th e Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot,News were established March 4th, 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 exactiy 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 unanimously passed and adopted severaliy by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of DaUPhin!' Miscellaneous Book "M", Volume 14, Page 317. (, PU B LICA TION . ""..,.".".".".".,..,. ,.<<."",.."."...".", ,., .., ..... ..... ............,... ... ... ... COpy efore m.e ' 1st day of~emb S ALE #16 NOlana'soa' [. Terry L. Russell, Notary Public ' Harrisburg, Dauphin County MyCommiss'DrlExpiraSJuna6,2002 NOT RY PUBLIC Member, Pannsylvania Association ot Notaries My commission expire~ 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) $ Total $ 250.95 1,50 252.45 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.............,.,.,..,.,...,....................."".,.",...,...... I l;.~~, " , 'I 'r ~".~.'. ~. ,"" -. ES'l'ATE ~ NO. 16 Writ No. 2000,2637 Civil PNC Mortgage Corporation of America vs. Jason L. Leininger Arty,: Frank Federman DESCRIPTION ALL TIiAT CERTAIN lot of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a mag nail set 6 feet south of the centerline of Ball Park Road rr -525). which pOint is (j);11 the line of Lot No.2. as shown on the hereinafter mentioned Plan of Lots; thence along the latter and through a concrete monument lo- cated 29.81 feet from the point of beginning, North 35 degrees 50 minutes 48 seconds West. a dis- tance of 290,63 feet to rebar set 1I1 the base of a maple tree on the line of land now or formerly of Brian Starner; thence along the latter, North 48 degrees 58 minutes 59 seconds East, a distance of 150.24 feet to an existing rebar on the llI1e of land now formerly of Byron Starner; thence along the latter and through a reference rebar set 25.06 feet from the centerline of said pub- lic road, South 35 degrees 50 min- utes 48 seconds East, a distance of 3 I 4. 76 feet to an existing railroad spike in the centerline of said pub~ lic road; thence along the latter, South 58 degrees 12 minutes 07 seconds West. a distance of 150.00 feet to a mag nail set 6 feet south of the centerline of said public road. the place of begtnntng. CONTAINING 1.040 acres ac- cordlI1g to a subdivision plan for Paul J. and Martha E. Smith by Mark A. Kuntz. R.S., dated June 14, 1996, and recorded in the Cumberland County Recorder of Deeds Office 1I1 Plan Book 73, page 89, and belI1g designated as Lot No. 3 thereon. BEING Parcel Number 08- 16- 0210-147, TITLE TO SAID PREMISES IS VESTED IN Jason L. Lelninger by Deed from Donald E, Hawbaker and Sandra S. Smith. single persons, dated 4/15/1999 and recorded 4/ 26/1999 1I1 Record Book 198 page 31. , .=- ~l - .-. --" w~~ " J, ~ , 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. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the 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 ofthe 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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. / cJ/J;l/l Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 10 day of NOVEMBER. 2000 ~' SEAL LOtS E. SNYDER, NotoryPubllc CarMI. Bore, Cumberland C9unly,PA MX Commistion Expi....March 5, 2001