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Home My WebLink About00-03186 I " , ~ SAlOIS, SHUFF & MASLAND ATI'ORNB"lS-AT.uW 26 W, High Street Carlisle, P A , ~ 'r_""";;;' ";. ." HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, ARDELLA M.. SOUDERS, a/kla ARDELLA F, SOUDERS, CARL E, SOUDERS MCBRIDE, MICHAEL Land FICKEL, MARIETTA B. NO. 00' ..5/I'f.. CIVIL ACTION - LAW Defendanl(s) MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are wamed 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 Bar Association 2 Liberty Avenue Carlisle, I'A 17013 717 - 249 - 3166 NOTICIA Le han demandado a usted a la corte. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tien veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion, Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra suya. Se ha avisado que si usted no se defienda, la corte tomara medldas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda, USTED PUEDE PERDER DINERO 0 PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED, LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 CONOCES UN ABOGADO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717 - 249 - 3166 1 SAID IS, SHUFF & MASLAND ATIORNEYS-AT-LAW 26 W, High Street Carlisle. P A HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. iHJ..JI Pc' Ci..;J ~ CIVIL ACTION - LAW Plaintiff v. ARDELLA M.. SOUDERS, a/k/a ARDELLA F, SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL Land FICKEL, MARIETTA B. Defendant(s) MORTGAGE FORECLOSURE COMPLAINT AND NOW, comes Plaintiff, Harris Savings Bank ("Bank"), by and through its attorneys, Saidis, Shuff & Masland, and files this Complaint, alleging in support thereof the following: 1. Plaintiff, Harris Savings Bank, is a national banking association organized and existing under the banking laws of the United States of America with a principal regional office located at 235 North Second Street, P,O. Box 1711, Harrisburg, Pennsylvania, 17105-1711. 2, The Defendant(s), Ardella M, souders, a1k/a Ardella F. Souders, Carl E. Souders, Michael L McBride and Marietta B, Fickel is/are adult individual(s) whose last known address is 18 valley street, Carlisle, PA 17013. 3. On or about April 9th, 1999, Defendant(s) borrowed from and agreed to repay to Bank the sum of fifty-eight thousand six hundred ten and 44/100 dollars ($58,610.44) ("Loan"), As security for the Loan, Defendant executed and delivered to Bank a mortgage ("Mortgage") on that tract of land together with the buildings and improvements erected thereon located in Cumberland County, Pennsylvania known as 18 Valley Street, Carlisle, PA 17013, At all times relevant hereto, Defendant(s) is/are and remains the record and sole owner of the Property, A description of the Property is attached hereto, made a part hereof and marked Exhibit "A", 4. On April 9th, 1999, the Mortgage was recorded in the Office of the Recorder of Deeds of Cumberland County in Book 1533, Page number 98. A copy of the Mortgage is attached hereto, made a part hereof and marked Exhibit "B". 5, The Mortgage was never assigned by Bank and is still held by it as a valid and subsisting obligation of Defendant. 6, Under the terms and conditions of the Note ("Note"), Defendant agreed to make monthly payments to Bank in the amount of five hundred sixty and 51/100 ($560,51) beginning on fifteenth day of I May, 1999 and continuing on the fifteenth day of each month thereafter. A copy of the Note, evidencing the I Loan is attached hereto, made a part hereof and marked Exhibit "C". 7. Defendant has breached the terms and conditions of the Mortgage and Note and is in default under such terms and conditions because he has failed to make the payments required in accordance with the terms thereof. 2 II II SAID IS, SHUFF & MASLAND A'ITORNHYS.AT-LAW 26 W. High Street Carlisle, PA , ~ .>'" .~. ,,~., ~"~'-~,",-~",~'" '-'j,-, -'=><"''"'''''"'_;'$'_d~',>,;,.,_,_<~,;_ ~,_.. _,__~ ,__ ,:11 9, Defendant also agreed under the terms of the Mortgage that in the event of default thereunder he would pay costs incurred by Bank as a result of the institution of these legal proceedings, 10. The obligation owed by Defendant to Bank continues to accrue interest thereon at the rate of twelve and 66/100 dollars ($12,66) per day, through the date of payment, including on and after the entry of judgment on this Complaint, and continues to accrue late charges, and attorneys' fees, 11. The combined Act Notices were forwarded to Defendant on February 01 and 02, 2000, by First Class Mail and Certified Mail, return receipt requested, addressed to Defendant. A copy of said Notice is attached hereto and marked Exhibit "D", 12. Copies of the postal forms, evidencing the mailing of said Notices are attached hereto and marked Exhibit "E". 13. Bank believes, and therefore avers, that Defendant has not applied for assistance under the Act. 14. As set forth above, Bank has made demand upon Defendant herein to cure the default under the aforesaid Mortgage and Note. However, Defendant has refused and failed and continues to refuse and fail to cure this default. 15, Defendant is presently indebted to Bank, as of May 11, 2000, in the amount of sixty-three thousand eight hundred eighty-five and 42/100 Dollars ($56,885.42) itemized as follows: Principal Balance $57,997,13 Interest to and including May 11, 2000 $ 2,483.84 Late Charges $ 504.45 $ 2,900.00 Attorney Fees TOTAL DUE $63,885.42 3 Ii , SAIDlS, SHUFF & MASLAND ATI'QRNEYSeAT.LAW 26 W. High Street Carlisle, P A _ .~ _ ~,^,'-'-.,-,,"-," ..'- .">''-'-- ~,~~, ,~,-,--- ',-,'-' -",1' WHEREFORE, Plaintiff, Harris Savings Bank, demands judgment against Ardella M. souders, a/kla Ardella F. Souders, Carl E, Souders, Michael L McBride and Marietta B, Fickel, Defendant(s), in the amount of sixty-three thousand eight hundred eighty-five and 42/100 Dollars ($56,885.42) plus interest at the rate of twelve and 66/100 Dollars ($12,66) per day, through the date of payment, including on and after the date of entry of judgment on this Complaint, and costs, and for foreclosure and sale of the mortgaged property. SAlOIS, SHUFF & MASLANO Dated: 5-1 =1-00 By: 4 . SAlOIS, SHUFF & MASLAND ATTORNEYS-AT-LAW 26 W. High Streel Carlisle, PA HARRIS SAVINGS BANK v. ARDELLA M.. SOUDERS, a/k/a ARDELLA F. SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL Land FICKEL, MARIETTA B, Plaintiff Defendant( s) '" r_' .. "C ~ "._ , ",..': _'" _'_," ' "r.-' ~~. ~...,";",_, ,'.'-'"" ;:-;,,~ii,"" ',:,-" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, CIVIL ACTION - LAW MORTGAGE FORECLOSURE VERIFICATION I verify that statements made in this Complaint are true and correct. I understand that false statements _~ _J '" _ h., I I I I , I I i I I herein are made subject to the penalties of 18 Pa,C,S, ~ 4904, relating to unsworn falsification to authorities. Date: :5 J n / I/IJ II Harris Savings Bank BY:,~~~, Stacy L trang . Loan Default Coordinator/Officer 5 .1 ~~ ". , 201 AT II lr' 11"\ I'""... 1-' 'l', I. I . ' lI~nl r 11,,11, 11l~., Indllln'l. I'a. bJlI,1fj r CI:L; .1SU m:b i!i 1!leeb, r-ct. .It,lln: UII-: ;) ""!I'" February fir P/11' /./In/ (llle tJ"ul;.:r/llrf Ililll' }I/I}dO'I/ and fifty-five (1955). /111111' .'/1'//1' m:TIIEf.',\' ARDELLA ~~. FICKEL, now inter,;;arried wi th Carl ,,;. Souders, and CARL ;,;. SOUDERS, her husband, of South Middleton Township ,. Cumberland County, Pennsylvania, GranflJ/' s. (/,,1 CA~L E. SOUDERS and ARDELLA F. SOUDERS, his wife, of South :ciddleton Township, Cumberland County, Pennsylvania, (;n1I1/I'( S : II'lT.\'/-,'SSFTFl. /hul ;11 c"(/,,;1,'/,(l1;0,, of One (~l. 00) , jJr.ll'/rl /trl'r!J!1 ,1I/'11/lt ill h(/lld JJ(li'/, Ih(' I'd'! ipt 1/'1/1 r('ol i.~ hereby acknoll'll'r/!Jed, tltC' ......(lid !fraU/fit' 5 rlf. owl ('fl/I,.!'!I to flu' sail/ [f1'(lJIf('fS ,their heirs and assigns, ALL, those certain two lots of ground situate in South r:iddle- ton Townshio, Cumberland County, Pennsylvania, more particularly described as follows: Being Lots Nos. 19 and 20, Block "L", of that certain Plan of Lots known as Carlisle "~nor Extention, which Plan is recorded in the Ofiice of the Recorder of Deeds in and for Cumberland County, rennsylvania, in Plan Book 3, Page 99. Said Lots having a frontage on Valley Street of 100 feet and extending in depth 150 feet to line of Lot No. 16, Block "L", in the reAr. It bein~ the same two lots of ground which Pierson K. Miller and ~argaret S. giller, his wife, by deed dated April 7, 1954 and recorded in the Office of the Recorder of Deeds in and for Cumber- land County, Pennsylvania, in Deed Book "R", Vol. 15, Page 355, granted and conveyd to Ardella M. Fickel, now intermarried with Carl E. Souders, one of the Gl1ntors herein. EXHIBIT A j,/6i/ C- "1 . ~~ - ~ 'v Ir ~ , ',.\ Harris Savings nank 2nd and Pine Streets Uarrisburg, Pennsylvania 17101 ,. I 17-51007388 , ,',.. MORTGAGE THIS MORTGAGE made this 9 day of April , , ' i ,19 qq belween Ardella M Soudel!'B AI(A Ardella F Souders '>c" Manetta /j hcl<e'l ''" '_,.,,,.........,' of, 18 Valley Street, Carlisle, Pa 17013 HARRIS SAVINGS BANK of Harrisbur9, Pennsylvania as Mortgagee. and Carl E SouderBt;!nd Michael !.McBt;i.!:le am! , as Mortgagor, and WI1~ESSETH t~~,_the Mortgagorhas executed and delivered to the Mortgagee a Note/Agreement on this date in the face amount of $ ,6~~.44..... . with interest thereon at the rate specified therein requiring the performance of all the terms, covenants and condItions therein contained: all of which are made an integral part hereof and incorporated here,n by reference. As evidence of said Indebtedness of Mortgagor to Mortgagee, and as security for payment of said Note/Agreement with Interest and in consldera- lion of $1 ,qQJP,a!f!, b\', Mortgagee, the Morlgagor does hereby bargain, sell, grant and convey unlo Mertgagee: ALL THAT CERTAIN piece'oHan'it'together with all improvements thereon erected situate in: 1 South Middleton Twp C be 1 d . , County of _ 'um r an (City. aora, or Twp.) (City~oro. or Twp.) , County of J (C' to (') c- , 3: ;0 0] r~l ;;:J r:, (Jl (.:'1 0[.; ~:u iT1 f. ';' ;';; - , .~._ r;l 2. 3. .',' -r\ --0 = , County of _ (City, Bora. or Twp.) CD 2 3 (Joentifkalion of Mortgaged premises) r;J -0 0 ~ c..> c: N -,- --j M _...:: ,N . -0 1'- C') G~; 1'\"1 r- III rn 0:;0 (J) .., ~ and Pa (State/Commonwealth) . known as: 1 18 Valley nStreet, Carlisle Pa 17013 c> ',< " r=or title into the Mortgagor see Deed recorded in the County of Cumber land, 1 in: Deed Book 16F ..~. , Vol ume , Page, 489 2 in: Deed Book , Voiume , Page, 3 in: Deed Book , Volume ,Page TOGETHER with all buildings, improvements, rights of way, rights and privileges, hereditaments End appurtenances, and the rever- sions, remainders, rents, issues and profits thereof. Mortgagor covenants and warrants that Mortgagor has full fee simple title to premises above de..cribed;. thar'the. buildi~gs on the premises shall be kept insured against loss by fire and other casulty for benefit of Mortgagee in alnoun~~- satisfactory to Mortgagee, with standard Mortgagee clause; and Mortgagor will pay any tax, assessment, municipal or other gove:rnmental charge, including water and sewer rents charged to said premises, and will deliver to Mortgagee receipts therefor imme(liately upon ~emand. Provided that if said Note is paid in accordance with its terms and if all other terms, conditions, "nd coven.~nts ~f this mortgage and the aforesaid Note are performed, the estate hereby granted shall cease and this mortgage shall be va d and of no.e'ffeel.. The transfer of any interest in the property mortgaged herein without the prior written consent 0; Mortgagee, except for a leasehold interest for three years or less, not containing an option to purchase, is a dp.fault hereunder. In the event of default hereunder or under the terms of the note, the entire balance of the debl shall fall due and Mortgagee may institute an action ot'mortgage foreclosure hereon. If Mortgagee retains an attorney to institute c ction on said Note or an action of foreclosure on this mortgage, Mortgagor shall pay, in addition to the principal, interest and costs, an attorney's collection fee of 15% of the principal balance then due; and if a judgment is entered in favor of Mortgagee against Mcrtgagor in said suit and Mortgagee thereafter secures a Writ of Execution or other appropriate writ, Mortgagor waives all rights and benefits under any and all laws or rules of the court now or hereafter in effect, granting or permitting any exemption or stay of exe :ution against the mortgaged prem- ises or any other property whatsoever, and such judgment shall bear interest at the applicable race until the full amount due Mort- gagee is actually paid, The word "Mortgagee" shall be construed to include successors and assigns of Mortgagee, and t 1e word "Mortgagor" shall be con. strued to include the respective heirs, executors, administrators, successors and assigns of Mortgalor. ,If there is more than one party named herein as a Mortgagor, the word "Mortgagor". whenever occurring, shall be deemed and taken to be the plural; and all cove- nants, waivers, warrants, promises, and releases by, and the obligations or liabilities imposed ur on, Mortgagor under this mortgage shall bind them jointly and severally, together with each of their respective heirs, executors, admin strators. successors and assigns. Any forbearances by Mortgagee in exercising any right or remedy hereunder, or otherwise pernitted by Jaw, shall not be a waiver of or preclude the exercise of any such right or remedy. IN WITNESS WHER EO F, and intending to be legally bound hereby, Mortgagor has hereunto sel hand and seal the day and year first above written. and lelivered in the presence of: J1JJ-t>u..e;.4... ~~~ r .-fll-~.A~>-(SEAL) ~4~CYtf/~ ;;l;lh- nurl~ 98 ':]y!(J()/#--- ii 1,:/"/ (SEAL) " (SEAL) (SEAL) ('j n " T 9-9~ ~Illln: _ r.nr:nITOI1 CANAI1Y - CRFD1TOfl PINI< - nORROWER GOLDENR)O. BORROWER EXHIBIT B '-" 'I,) ,', t GOVERNING L~W: Terms following a 0 apply when checked. o If the Mortgaged Property is located within the Commonwealth of Pennsylvania, then this agreement 'hall be governed by the laws of the Commonwealth of Pennsylvania, except to the extent that such laws have been preempted or superseded by Federal Law. o If the ~Iortgaged Property Is located within the State of Mar;land, then this agreement shall be governed by the laws of the State of Maryland, except to the extenlthat such laws have been preempted or superseded by Federal Law. If this Agreement is governed by the laws of the State of Maryland, then the Lender elects to have this Agreement governed by Title 12 of the Commercial Law Article of the Annotated Code of Maryland, o Subtitle 9, Credit Grantors Open - End Provisions o SubtitlH 10, Credit Grantors Closed, End Provisions ",-,;:~ '. ,...--:~", ," STATE OF Pennsylvania l'J- SS: COUNTY,OF Cumberland ,. ' On this, 'the 9th day of April 19 99 ,before me the undersigned officer, personally . app'eare~';. lArdella M. Souders AKA Ardella F. Souders and Michael L. MeBride and Marietta' B. Fickel and Carl E., Souders Mm'9'9ml'l known to me (or satisfactorily proven) to be the person(s) whose name(s) is (are) subscribed to the with n instrument, and acknowledged that , (he, she, or they) executed the same for the purpose therein contained. IN WITNESS WH'EREOF, I have hereto set my hand and notarial seal. ,"'IJI"'II~~::~>;'lij"."-" ',. .. i'._.~.~'( \~E- t'1 1;,1. ~r " ", ,..,.,;'.;~':.\," \I r.J~, ';r.'," ._'::"'....'~':t- ,.0"... ,i6t_-:j..-1 '" ,:"u.~::,.-!,::'..,:. ~;V:c ..... <;::-0:-. , ..,.;itV;A~!.fJ!:~~,',. ,,/~ ,~/t~\A~'-~', . '..-:...".. .~lt;li.iit-'I'.~'.l;:." '/.":/. ~ '" ,._.-. "':, ..,~. ,,""i'" ~l1"":~;I_>I "'l." ,"I', ,,- ';':ii' '0 ,- "', ,'"j-' l!/.J',:,; ,<!~2~1~.ii~E! I, P '(~J~-r~I:.~." E. '~;'(.;' ....,: """,," ~,~.,..., <q/ . ., " . . "'\ii'=tA"'-" '. .....' _ ;,_..//.......~: ../,"~,G'..:~ ." ',.~,.'-,. i,_ ""l':"",,".oil~ " :.. 1/ ':.'r ". \~:;;:,:.~';<,/l..,. ~,'i'tf,,' l/ No'arial Saal ~'.c::~'. 't.. .:'u' ";.... i:;,",.;:-"'.' ~,~." Jay A, Cha'lnut. Notary Public .> . }'. ....;. \).'. 11'.'.'\ ' Cmnsle Boro, Cumberland Coun!y .."'..,A~V,,.'.:,9 ,...":~:(>. '. My eomrnisalon Explroo May 13. 2000 ,Iht ,'rf:" I HERE1~:. ., 'hat the precise reslderice of the Mortgagee(s) and person entititManll!M9f\llVll'~~~lrill!illlJiariNdttrfuSs Savings Bank, .. 't _..,L, ".-..,,:...-':(".-.... /') (J /Z--_'_-- -/ .... ~~ Lib", (/, ltf&-'/Ua-;f , 2nd and Pine"Street~l Harrisburg: PQnnsylv~l1ia 17101. J / /JOoK:t53J Met .. 99 . \;'(1:: 'i ' . 1'" ~-" "~ ~"""---"'~- I --....J_,,~~"'~W-, ~,fJ , APR ? '99 13:27 FROM FINANCIAL DIMENSIONS TO 9171723129 PAGE.l'l27 , , ..~ " ' , ' ,', " .', ;. .. L~GAL' PESCKIFiIO<< rOR' 16 VALLBY Stl&&i, CARLISL&. PA ~ H~D/l' 1'11" {- al ".,r '.nnl 0,,, ,J,ftl,""',,11 .tHHI h""""rt and ff'" II' . F,'brYafY fifl!y.t1V<l (19S~ I. ;w ,/",. ""'~ RETlrS~X AIl!lllUA I!. nCK,,1., noli tllt'l'I!II.I'ri~ Ill. tll ~iil'1 ~. So\l4.';,. .nd CARL L, .$OUIllal!, h... ",,",~0n4. of Sou~h K1.CdloWll To1OIIthip" c...\.~l...d Co\lntl'. FoM.ylv...1a, , I' , " ,001 CARl. E, 50UDIlIIS ond ARIlWA Y. lIOUOZllS, U. \tl~. at ~~,ue~on tOWliah1P. cllllllerl....d CGlmo;r, '......~iv*n1a. " <1....,..:,& So.ob C",w'I"',: ,rrt.,'BIlIF.111. ,,",' i. .....:i4.."'II.. oJ QQ. \ Ul,OO! , h. ...... ,,..;.l.th rmlM Irfu;rr?/ f$l!:'l'Ih:",*wl,,,,ri. tAt IffIIIJ p,..,.lfI;. "t, n",f tfrlt"f'" t~ tAt' ;:ti,f ~rl:ldte . ""'.11' ".11'. knd acsiPi3,' ' ".,''''''" Mrt'lJtIllt'flftl AU: ~bO" ovuin tWO loto ~f ~Und ;it;..\~ lis Seuob ~,i~Ill.... . , . ~~ 'Coon. TDWft.hlPt C_lJ'l:~latl4 COUftty, p.nn.y1,-ian:S.1l, 1OO~Q })~r~U'UlarlY ~ '.,; . ri,~l'i.~ ... tallowa: 'If L:"- BeUl5 Lots Has. 19 ~<! ZO'.,iIuOll. '!l.~. .o1'o1ihoO 'Q"",,in Pl.... ot 1.ot_ I<no~ .', e~rli5b JoQno~ ~...il.lI. whi~h' 'phI> h ,r..~r4.4 !.ft. <ho 01::10'.- of t.h~ Jte.~ri.r..;t ~. ,.1n ~~. tor cu..~'r1and e<,un~)' I , ,.' -,,-. p....n.yl.v...U, \n-l'~';ilo.ll'3)'PaCo.,99.,Sti4 Lots hlotnc . rro""'.' ',(' :; ';, ~~':. --;,: ,(, ~. .'" " ,_:: " . on V&1:l.~" s"r.oo\ ot '1OQ.i~;.~)~.f...jl)llo<ll\cilnlJ 1.. ci&p\1\ ~50 r..~ ~o '-: . -----...- ' . , ' Un. otlA' H'o. l!t->>SQ5-!!L..!..."',.:.th9-n..... . tt'b;1~~. ..m~;;!~o\. or .ro.n4 wbicb Pi.~amo K. ~'ll.r and ~,,"rot S. Rtl.10', bl. wit., by d..4 4..~d April 7, 19S~ 5nQ r.aor4.4 ln tho OrriCo or t~. 1.~.r4tr Of n..~. 10 .n~ tor Cumb.', lan" Caun"l". P'J'HU71va,..u, in n..,d, Bock ,IlIRfI' I V~l,' 1~; Pti- )In. I,.n".' .n~ oonv.;rd to Ard.].l.. ~. rlck.l, nOW ~~~~~1'4 with C4'E'1 11:. ~\lGer., on- cr '-he ~J. 1n\oroS htlt'tin I ':;;.::- /. .' . I ',- :,..'~~ ',,"" .:;-'. .: J , . r . . .. .8ood~'MGf ~lCO OL6c\EcL1L 'ON X~d ~Ol H3WnSN00 L03HIG Wd L\:\O nHL 66-80-Hd~ EO 'd .-,- -"""'" ~ , ~-" ,-~ . J I~ '~..~,--"..,c ~, .~ , State of pennSYlvania} 86 County af Cumberland ~card 'n the office. for the recording of Deeds ee. dfar1.~rlaIlll.COUntY'~f I ook~301. -Page Wilne my hand and '1" of offl 't. j t:1 Carlisle, PA this day of 9...L/ . ... , ......._" '".. "-~" -:<\~" I ~) ~" J . ','., " - , , ;~~"., . Inslilllment Note and Security Agreement No. HARRIS SAVINGS BANK 17-51007388 $ 58,610.44 4-9 .19 99 For \/a1ue received. the undersigned, I$OJ58 an6W8f8f!Y. (~~;ower") promises to pay to the order of HARRIS SAVINGS BANK("Hanls1 at 235 North Second Street, Harrisburg, PA 17101, or any branch office, the principal sum at , .44- y,llthlnlerestatlherateot 7 qq "hptlC&Mumonthe\lnpeldbale.rn::eln 180 succBulvemonthlylnstallmentsot$ C)(;O _ c)1 each, Ille first Installmenllo bedue ~nd payable on the 11) day of M,q y 19 --9.9...IUtCeSSIV8 installments to bedu(tand payable on Ihe like day of Bach month thereafter until the enllre Indebtedness evidenced hereby is paid in full, except that any remaining indebtedness, if nol sooner paid, shall be due and payable on 4-11)-2014 II "yin III II J t B Ih' . not Harris eleels to accelerate the dUB dat~ a: prOV~d~d~~~ u~d~reDE~~~~~ ~::::~ at additional chargas lor Inlerastwlll badue attha 51atad rateduato thenon-reducllon of principal whelheror LATE CHARGES 15 20 00 10 It any installment Is ~ale, by more than days Bo~roweragreesto pay a late charge of $ . OR %oftha lale paymentwhlch.veris [jC ,,..'.r D lnMr what her or not H.rtls elact8to ,,"ccaleral.the due dale as prOVided 'or under Default !>(tlow. In addition, if collection requires relerral to an atlorney 'or collecllon, Borrower agrees In Ihe evenl of oefaultto pay re.sonable allorney's 'ees and 10 pay all legally recoverable charges. SECURITY INTEREST AND COLLATERAL AS security for ll1e payment of all sums under Ihis note and aU other existing indebtedness to Harris, The Borrower hereby grants a security Interesl In any Insurance required or purchased hBreunder, and In the following as indicated. [J Under the Uniform Commercial Code to Harris in the property described below together with all additions, attachm.nts, repairs and extra paris now or hereafter installed In or aflixedthereto Granted tilt the Collateral Mortgage dated Ijl 4-9 ,19 2L for the following real estate 18 Vflllf'Y r.::l'rl;~lp, Strf'f't p" 1 701 , [] in B<mow~r she.lI not p0fmit an'l othe.r lien or ~ru:.umbrance 01 an'l nature to be placed upon the CoUaleral withoul 1tle consent 01 HARRIS. INSURANCE Tile Borrower agfees to keep the Collateral insured against loss or damage by lire, theil, or other casualty, in an amount agreeable to Harris with a loss-payee clause In favor of Harris, and the Borrower assigns to Harris all tights 10 receive proceeds of ally such Insurance, and directs any insurer to pay all such proceeds 10 Harris, and authori!:es Harris 10 endorse any draft lor such proceeds. The Borrower agrees 10 pay aU taxes on the Collateral. The Collateral shall nol be s61d or removed Irom the above location without thewrillen consent of Harris. This insurance, If required by this loan, may be obtained by the Borrower from any insurer of his choice acceptable to Harris. Such insurance is I\Ot available th~ough Harris. CREDIT INSURANCE CREDIT INSURANCE IS NOT REQUIRED: Sufllect to acceptance by Ihe Insurer named below, creditlnsufance is available through us for the term 01 this Note atthe cost{s) shown below: Single Ciedit Lile and Single Credit Accident & Health Insurance are available to anyone Borrower signing for insurance below. Joint Credit Llle Insurance is available to both Borrowers signing for insurance below. No credll insurance will be provided unless the approptlale statement(slls signed by the Borrower(s) to be insured and the cosls shown below are included in the'Amount Fif'tanced. (See the NOTICE OF PAOPOSED CAEDIT INSURANCE. I NOTICE OF PROPOSED CREDIT INSURANCE Tl1e Borrower hereby takes notice Ihat group credit life insurance coverage andlor group credit accident and health insurance coverage will be applicable to this nole If so marked, and each such type 01 coverage will be written by the insurance company named. This Insurance, subject to acceptance by Ifle insurer, covarsonly the person signing the request lor such Insurance, Theamounl of charge Is Indicaled for each type of credillnsurance to be purchased. The term of Insurance will commence as of Ihe date the indebtedness is incurted and will expire on the original scheduled m<lturity date 01 the Indebtedness. Subject to <<cceptance by the insurer and within 30 days, there will be delivered to the insured Borrower a certlflcate of lnsuranc& more fully describing the in~urance. In the event 01 prepayment of the indebtedness, a relund 01 Insurance charges will be made when due. .12i By signing, you want Single Credit Life-Insurance, D By signing, you wanl Single Cf"8dit Accident & Heallh 0 8ysignlng,youbothwantJolntCredltUlelnsurance, lnsurance,whichcosls: $ which costs: $ Whatsre your ages? 519 alure of Borrower 10 be insured for Single Credit Ule lIlsurance. Signature 01 BOHower to be insured lor Single Credit Accident & Health Insurance. " Years What is your age?_Years. What is yourage?_ Years. UNION FIDELITY Nllme of Insurer: SECURlTT"'l:J'F~'t11"E"1I'il'SOFf~COMPA"N"I'7"Reading, Pa. 2, _Years Signatures of both Botrowers to be insured lor Joinl Credil Ufe Insurance. I/We do not deSire any Credit Life or Acctdent & Health Insurance 1<' ~--d"4:- "Jv4 cr-~"'-.-' y f~ ~ ~/P4/ y )YJ~-;tf~ 7<<-L/ Signatufe(s) 01 Borrower(s) relectlng Insurance. PREPAYMENT If (his nole, Including accrued finance charges, Is prepaid in lull by cash, a naw loan, refinancing at otherwise, there Is no penally and inleresl charges will stop on lhe date prepayment Is made. WAIVERS The Borrowef, and all endorsers and guarantors, hftrebylolnlly and severally waive notice 01 default, demand presenlment for payment, nOliceol non-payment, pfolest, notice 01 protest, diligence In bringing suil hereunder, and all defenses on the grounds of any extension of time 01 paymentlhat may be given by Harris to any maker hereof. DEFAULT The occutence of any of the lollowlng events shall constltule a default heteunder, and shall, althe option of Harris. render the entire unpaid balance ofthls note and all other liabilities 01 the BOHower 10 Harris immediately due and payable without nolice or demand to the Borrower or any endorser or guarantor: (8) non-paymenl hereunderol any pa'lment when due and payable: (b) failure 01 the Borrower or any endorser or guatantor, to perform any agreement herein or In any other instrument, agreement ~r writing given to Harris: (c) death otthe Borrower, or any endorser.orgua~antor: (d) inSolvency, bankruptcy, assignment lor the benefit of creditors, or any other act 01 Insolvency under slate or lederallaw, by lhe Borrower or any endorser or guarantor, or the Instllutlon of any bankruplCY, Insolvency, arrangemenl, debt adjustmenl, 0 r receivership proceedings in which the Borrower, or any endorser Of guarantor, is alleged to be insolvent or unilbl~ to pay his debts as they become due: (e) Harrls,ln good leith, believes thet the prospect of payment heteunderhas been impaired: (') entry 01 any judgment in anycourtofcompetenljurlsdlctlon against the Borroweror any endorser Of guarantor: (g) transler or attempted transferol anylnlerest of Borrowef in the security pledged therelor: (h)lailure 01 borrower to maintain or preventlhe delerloratlon and degradation 01 the value of the securlly or abandonment ollhe security, ASSUMPTION AND PROVISIONS AFFECTING REAL ESTATE , , II fhls loan 'is secured by real estale, Ihetransler, without Harris' prior wrillen consent, 01 any Interesl in Ihe real eslate except the grant of a leasehold Interest lor three years Of less not contelnlng an option to purchase, is a default hereundef. A purchaser 01 real estate plej:lged as security lor this loan caMot assume the remainder 01 t'nis loan on Ihe orlginallerms, REMEDIES upon the occurrence 01 anydelault hereunder, Harris shall have all rights and remedies with reapect to Ihis /'lole and tha collateral as provided herein and as provided lor by law,lncluding, w.llhout IIrflltallon, the Pennsylvania Uniform Commercial Code, and all such flghla and remedies shall be cumulative. To the exlent permitled by faw, upon defaoll, Harris shall have Ihe Immedlale fight of set-olf against air mo :2owed by H tis to the Borrower or any endorser or guarantor. , "'" T.,a undarslgna ackno fadga. r Ipl cop of thl, hota and Collataral Mortgaga, If .ppllcabla, al tha tlma ola.acullon hareof. y ~~_hor~-- Carlisle Pa 17013 (SEAL) 18 Valley Street, Address (iOVERNING LAW: li ms following..l&apply when checked, o If the Collateral Property is located within the Commonwealth of Pennsylvania, then this agreement shall be governed by the laws of the Commonwealth of Pennsylvania, except to the extent that such taws have been preempted or superseded by Federal Law, o If the Collateral Property Is located withIn the State of Maryland, then this agreement $hall be governed by the laws of the State of Maryland, except to the extent that such laws l1ave bean preempted or superseded by Federall.aw. The lender elects to have this agree- ment governed by Subtitle 10, Credit Grantors Closed End Provisions of Title 12 of the Commercial Law ArtIcle of the Annotated Code of Maryland. -(~ h._~A{/~ (SEAL) 18 Velley Street, Carlisle Pa 17013 Addreu _( (illH' ,:1t_ B 7-uY P I;~lisle Pa 17013_~:::~: 18 Valley Street, Carlisle Pa 17013 {SEAL) Address Cl-D10312195 WHITE ~ CREDITOR CANARY - CREDITOR PINK _ BORROWER EXHlBIT ,. V ~--... ..~ - J...";= ~ """", L, N S BANKERS ,l _ ':' . "... J. "" , ,- , ~"'~';. _co, .. ~...'_ ., ,i~.. Leaving Our Mark~ ; ,';.,',' pi#~Vity ," February I, 2000 " , ..,.- ~ ,~. .'-',.. -,.) __ ,'-.;; t'., .. "," ,., ~"'. c; ;. .;', ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE :.;. This is an official notice that the mortgage on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to help to save vour home. This notice explains how the program works. To see if REMAP can help, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITIllN 30 DAYS OF THE DATE OF TIllS NOTICE. Take this Notice with vou when vou meet with the Counseline: Ae:encv. The name, address and phone number of Consumer Credit Counseline: Ae:encies servine: your County are listed at the end of this Notice. If you have any Questions. YOU may call the Pennsvlvania ROllSine: FiIiance Ae:encv toll free at 1-800-342-2397. (Persons with impaired hearine: can call (71'7) 780-1869). . This Notice contains important legal information. If you have any questions, representatives at the Consumer 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, LA NOTIFICACION EN ADJUNTO ES DE SUMAIMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO ]'yIENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOl\oIEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU IDPOTECA. Harris Savings Bank 235 North Second Street, P.O. Box 1711, Harrisburg, Pennsylvania 17105-1711 717/236-4041 . www.hatrissavingsbank.com EXHIBIT 0 1 . ~.. ~ . . . ,...,,,"~ ,,'~""'~'''''''' ~..,.. 'HOMEOWNER.'SNAME(S): . ,,,,Ardella M. Souders AKA Ardella F. Souders~,..,,,,,:,,;,:. PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS: _18 Valley Street, Carlisle, PA 17013 LOAN ACCT. NO.: _1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDER/SERVICER: Harris SaviIll!:s Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WInCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TIDS MEETING MUST OCCUR WITHIN THE NEXT TIllRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES---If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and teleohone numbers of designated consumer credit counseling agencies for the countv in which the oropertY is located are set forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCEmYour mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you h~ve the right to apply for financial assistance from the Homeowner's Emergency Mortgage ASSistance , , , .0" - , ~~~ - ~"' . . ,','( ~:: _, ,.. Program, To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance ',....., ,e .. Pragran!' Applicationowithone of the designated consumer credit- counsel.ing,agencieslis\ed .at ,the, end '.... -v. ,,' . of this Notice. Only consumer credit counseling agencies have applications for the prograrn- and they. will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN TInS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED, 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 A enc of its decision on our a lication. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TillS 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 !Brin!! it UP to date). NATURE OF THE DEFAULT-..The MORTGAGE debt held by the above lender on your property located at:_18 Valley Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A, YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ a partial payment of $168.06 for October 1999, and payments of $560.51 for November and December 1999, and January 2000 Other charges : _Late charges $280.25 TOTAL AMOUNT PAST DUE:_$2,129.84 B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $2,129.84 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or money order made payable and sent to: Harris Sayings Bank 234 North Second Street Harrisburg. PA 17101 ~ - ~ --.. ~ ~,- ~....;~- ~ >~.' .,. . I j 1lW.....lIlJa.oll*", IF YOU DO NOT CURE THE DEFAULT-nIf you do not cure the default within THIRTY (30) ""~',." 'DA YSof the date of this Notice, the lender intends to exercise its ril!hts to ' accelerate the mortl!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortl!al!ed propertv. IF THE MORTGAGE IS FORECLOSED UPON---The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs, If vou cure the default within the TIllRTY (30) DAY period. vou will not be required to pav attorney's fees. OTHER LENDER REMEDIES--- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage, RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yOU still have the right to cure the default and prevent the sale at any time UP to one hour before the Sheriffs sale. You mav do so bv paving the total amount then past due. plus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing bv the lender and bv performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSffiLE SHERIFF'S SALE DATE---It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cur~ the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contracting the lender. HOW TO CONTACT THE LENDER: . Name of Lender: Harris Savings Bank Address: 234 North Second Street Phone Number: (717) 909-6296 or 1-800-554-4572 ext. 6296 Fax Number: (7! 7) 909-2780 Contact Person: Taunia Ouercia EFFECT OF SHERIFF'S SALE---You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time, ASSUMPTION OF MORTGAGE---You X mayor may not (CHECK ONE) sell or transfer your home to a buyer or transferee whc; will assumethe mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. " . ~" " \ ~. .-:,'-:, ! ~. , TQ/ipp , ."~~ ~~ ~. - ''"--0> -~~, YOU MAY ALSO HAVE THE RIGHT: < ~,' , ~-' --.', ,- ... , · TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BOROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE " PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Taunia Quercia Collection Counselor - ,~..,,-, ~,- '-"~"". ~-"-'-'-." '-'" ~ ,-".', .~ I'? If fUllds are received and negotiated in less them the total amount due including legal fees and costs. Harris Savings Bank reserves the right to return the funds to you and continue with legal proceedings pending receipt of the total amount due. " ,...."..-" ~"" _. ,~, .._~, '" --::."'"::' ....- '~'-'<~"'_"Vl '~~~l~~ 235 North Second Street P.O. Box 1711 Harrisburg, Pennsylvania 17105-1711 717/236-4041 CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2()()(J Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited Il7 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 232-4985 .' YWCA of Carlisle 301 G. Street Carlisle, PA' 17013 (717) 243-3818 Fax (717) 243-3948 . .--~' - . ."'~~. - '''"' _l . ~ ",. ..f, II S ,BANKERS " .', _ . .'-.~..::,.:., '. ._c..,.: .-...~:;.,:__-r';:,'.,'""~'>>:...~".:... Leaving Our Mark. i' ,. ",. ..,.,..~vity ~Vcw February 1, 2000 u';:_\.~: .--";"""''' ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM mEMAPl mav be able to help to save vour home. This notice explains how the prOl!l'am works. To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TffiS NOTICE. Take this Notice with vou when vou meet with the Counselinl! Al!encv. The name. address and ohone number of Consumer Credit Counselinl! Al!encies servinl! vourCountv are listed at the end of this Notice. If you have anv Questions. YOU mav caIl the Pennsvlvania Housinl! Finance Al!encv toIl free at 1-800-342-2397. (Persons with imoaired hearinl! can caIl (717) 780-1869). . This Notice contains important legal information. If you have any questions, representatives at the Consumer 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. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGmLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU ffiPOTECA. Harris Savings Bank 235 North Second Street, P.O. Box 1711, Harrisburg, Pennsylvania 17105-1711 717/236-4041 . www.harrissavingsbank.com : ~~ "'.._'" .."', HOMEOWNER'S NAME(S): ,~ Carl E, Souders' "",-,,:., " ,- PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS: _18 Valley Street, Carlisle, PA 17013 LOAN ACCT. NO.: _1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDERISERVICER: Harris Savilll!s Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE wmCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE, CONSUMER CREDIT COUNSELING AGENCIES---If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of desi2nated consumer credit counselin2 a2encies for the countv in which the orooertv is located are set ' forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonnation about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's. Emergency Mortgage Assistance -,~~-~ .~ ,~ ~'N":"; " HOMEOWNER'S NAME(S): ~ Carl Eo' Souders ,-,..., '. ,. ",' ~'. '" .' PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS:, _18 Valley Street, Carlisle, PA 17013 LOAN ACCT. NO.: _1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDERISERVICER: Harris Savinl!s Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FI1'lANCIAL ASSISTANCE WInCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TIllS MEETING MUST OCCUR WITmN THE NEXT TIllRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. , YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT'. EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES---If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the propertY is located are set forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonnation about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's. Emergency Mortgage Assistance , , '~ . -- ~ - ~~ ,~""""~ '''--,'',1'''';_... ''-" Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance "PiogiairlApplicati6n with one 'of the designated consumer credit .counseling agenciesJisted at the.end ,,"",. ,0".'.'.. , ' of this Notice. Only consumer credit counseling agencies have applications for the progr~ and th~y . .' .-. will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face.to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 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 A enc of its decision on our a Iication. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TIllS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If yon have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brinll it uo to date). NATURE OF THE DEFAULT ---The MORTGAGE debt held by the above lender on your property located at: 18 Valley Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ a partial payment of $168.06 for October 1999, and payments of $560.51 for November and December 1999, and January 2000 . Other charges: Late charges $280.25 TOTAL AMOUNT PAST DUE:_$2,129.84 B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $2129.84 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME , , . , DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier s check. certified check or monev order made pavable and sent to: Harris Savings Bank 234 North Second Street Harrisburg. PA 17101 I ;::;'-~-,---- ~.............. *'.......~" " ., ,,~ ..-. .~ ~~" ~~ IF YOU DO NOT CURE THE DEFAULT---If you do not cure the default within THIRTY (30) ,":32'. '-~:.' - DA YSof the date of this Notice, the lender intends to exercise. its ri!!hts-to .accelerate. the mort!!a!!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mort!!a!!ed property. IF THE MORTGAGE IS FORECLOSED UPON---The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the TIllRTY (30) DAY period. vou will not be required to pav attornev's fees. OTHER LENDER REMEDlES--- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-nIf you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's sale. You mav do so bv paving the total amount then past due. plus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff s Sale as specified in writing bv the lender and bv performing anv other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLffiST POSSIBLE SHERIFF'S SALE DATE---It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately four months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cur~ the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contracting the lender. HOW TO CONTACT THE LENDER: . Name of Lender: Harris Savings Bank Address: 234 North Second Street Phone Number: (717) 909-6296 or 1-800-554-4572 ex!. 6296 Fax Number: (717) 909-2780 Contact Person: Taunia Ouercia EFFECT OF SHERIFF'S SALE---You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE---You X mayor may not (CHECK ONE) sell or transfer your home to a buyer or transferee who'" will assume""the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. ." . TQ/ipp ~ < ~ ~ - . - YOU MAY ALSO HAVE THE RIGHT: - ... . · TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BOROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE . PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Taunia Quercia Collection Counselor . ~ .~ ~ ~...... -' "-~_....'_..- -.- ~""'-"',-:-".~,~ .',.'.-.' :>-~- If funds Clre received Clnd negotiClted in less thCln the totClI amoullt due including legClI fees alld costs. Harris Savings BClnk reserves the right to retu/'ll the funds to )/OU Clnd cOlltinue with legal proceedings pending receipt of the total amount due. . ""- ,~ ~~. "-.' -;.~~~~ R~~~1~. 235 North Second Street P.O. Box 1711 Harrisburg, Pennsylvania 17105-1711 717/236-4041 CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 232-4985 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 Fax (717) 243-3948 . , = .l_~ ",",,"'I ',-.~ .,. .. "_,'., ; ,~'<'L """,. ...':" ,~ - ,~ ., 10" DI . ~,~.,. -,. -. ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!a!!e on vour home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pa!!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to help to save vonr home. This notice explains how the pro!!I'lllI1 works. To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITffiN 30 DAYS OF THE DATE OF TInS NOTICE. Take this Notice with vou when vou meet with the CoUnSelilll! A!!encv. The name. address and phone number of Consumer Credit Counselin!! A!!encies servin!! vour Countv are listed at the end of this Notice. If vou have anv Questions. vou mav call the Pennsvlvania Housin!! Finance A!!encv toll free at 1-800-342-2397. (Persons with impaired hearin!! can call (717) 780-1869). . This Notice contains important legal information. If you have any questions, representatives at the Consumer 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. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SUCASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU ffiPOTECA. Harris Savings Bank 235 North Second Street, P.O. Box 1711, Harrisbutg, Pennsylvania 17105.1711 717/236-4041 . www.hatrissavingsbank.com .,;;t HOMEOWNER'S NAME(S): ," _Michael L. McBride . PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS: _18 Valley Street, Carlisle, PA 17013 LOAN ACCT. NO.: _1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDER/SERVICER: Harris Savin!!s Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE . TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TIllS MEETING MUST OCCUR WITHIN THE NEXT TIllRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCmS---If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the prooerty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are Unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance -~"~ ~ "-- I. Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Prograrn Application with one of the designated consumer credit counseling agencies listed ,at the ,end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENmD. 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 A enc of its decision on our a lication. NOTE: IF YOU ARE CURREl'.'TLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TIllS 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: 18 Valley Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ a partial payment of $168.06 for October 1999, and payments of $560.51 for November and December 1999, and January 2000 . Other charges: Late charges $280.25 TOTAL AMOUNT PAST DUE:_$2,129.84 B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $2129.84 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE 'DURING' THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made pavable and sent to: Harris Savings Bank 234 North Second Street Harrisburg, PA 17101 -. - ~' l = --~ -- ~~~ ,~~ "~~.""~ -~ ~lll' - < "" ",~",l ...- -'-~, ','''' IF YOU DO NOT CURE THE DEFAULT.--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender ilIltends to exercise its ri!!hts to accelerate the mort!!age debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose noon vour mort!!a!!ed properlY. IF THE MORTGAGE IS FORECLOSED UPON---The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender eyen if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the TIDRTY (30) DAY period. vou will not be required to pav attorney's fees. OTHER LENDER REMEDIES---The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---If you haye not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's sale. You mav do so bv paving the total amount then past due. plus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff s Sale as specified in writing by the lender and bv performing anv other requirements under the mortga!!e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE---It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately four months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contracting the lender. HOW TO CONTACT THE LENDER: . Name of Lender: Harris Savings Bank Address: 234 North Second Street Phone Number: (717) 909-6296 or 1-800-554-4572 ext. 6296 Fax Number: (717) 909-2780 Contact Person: Taunia Ouercia EFFECT OF SHERIFF'S SALEmYou should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE---You _X_mayor _may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. " .~= TQ/ipp . - ,~ ..... c '-"""'-" YOU MAY ALSO HAVE THE RIGHT: . . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BOROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE ' PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Taunia Quercia Collection Counselor -~ If fimds are received and negotiClted in less than the total amount due ineluding legCll fees and costs. Harris Savings Bank reserves the right to retu1'll thefimds to you and continue with legal proceedings pending receipt of the total amount due. .' . .~~ ",. -". IUHARRIS@' D.. SAVINGS BANK " 235 North Second Street P.O. Box 1711 Harrisburg. Pennsylvania 17105-1711 717/236-4041 CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of West em Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 Nonh Front Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 232-4985 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 Fax (717) 243-3948 . > .' ~ ~ '~lIw>>l...~~; .. : ~, -"",,~.' ~ r_ . . ,,', "':,".i ___L~. ro OJ S BANKERS, "~a~g' 6~~ MaI'IZ ;Wf";:~:Y ~~~vity February 1, 2000 ";: . -';;.1"-,,., ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!a!!e on vour home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached Da!!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to help to save vour home. This notice explains how the pro!!ram works. To see if HEMAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TillS NOTICE. Take this Notice with vou when vou meet with the Counselin!!: A!!:encv. The name. address and nhone number of Consumer Credit Counselin!!: A!!:encies servin!!: vour County are listed at the end of this Notice. If vou have any ouestions. vou mav call the Pennsvlvania Housin!!: Finance A!!:encv toll free at 1-800-342-2397. (Persons with imnaired hearin!!: can call (7171780-1869). ' . This Notice contains important legal infonnation. If you have any questions, representatives at the Consumer 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 fmd a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU illPOTECA. Harris Savings Bank 235 North Second Screet, P.O, Box 1711, Harrisburg. Pennsylvania 17105-1711 717/236-4041 . www.harrissavingsbank.com -,~ ". ..a. '~ ':.;'.0 :. ,', '. _~"'. HOMEOWNER'SNAME(S):, '~M:u.ietta B. Fickel."".. PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS: _18 Valley Street, Carlisle, PA 17013 ~~~' -.. ._''''o'.,.:.--;;;..t:;:~...~. LOAN ACCT. NO.: _1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDER/SERVICER: Harris Savin!!s Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE . TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCmS---If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of designated consumer credit counseling agencies for the county in which the prooertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCEmYour mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance ,~ ~.. L, ',' \. ,~" ,'.:. ..j "e' . Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance PrograIhApplication with oneofthe designated' consumer 'credit counseling agencies listed, ~t the end .- of this Notice. Only consumer credit counseling agencies have applications for the program and they" will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIi'vIE PERIODS SET FORTH IN TmS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. ' 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 A enc of its decision on our a lication, NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TmS 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 (Erin!! it UP to date). NATURE OF THE DEFAULTmThe MORTGAGE debt held by the above lender on your property located at_18 Valley Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: . A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ a partial payment of $168.06 for October 1999, and payments of $560.51 for November and December 1999, and January 2000 Other charges:_Late charges $280.25 TOTAL AMOUNT PAST DUE:_$2,129.84 B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $2129.84 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME , , . , DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier s check. certified check or monev order made pavable and sent to: Harris Savings Bank 234 North Second Street Harrisburg. PA 17101 . ~ .- I ~ , ..~"" ~....., ,;~... ~-.. ,,'y-,:',. IF YOU DO NOT CURE THE DEFAULTmIf you do not cure the default within THIRTY (30) 'DA YSof the'da:te of this Notice, the lender intends to exercise its ri!!hts to accelerate the mort!!a!!e' debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to fOl'eclose upon vour mort!!a!!ed property. IF THE MORTGAGE IS FORECLOSED UPON---The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the TIllRTY (30) DAY period. vou will not be reQuil'ed to pav attornev's fees. OTHER LENbER REMEDIES---The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at anv time UP to one hour before the Sheriffs sale. You mav do so bv paving the total amount then past due. plus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writing bv the lender and bv performing anv other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had nevel' defaulted. EARLmST POSSIBLE SHERIFF'S SALE DATE---It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately four months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contracting the lender. HOW TO CONTACT THE LENDER: . Name of Lendel': Harris Savings Bank Addl'ess: 234 North Second Street Phone Number: (717) 909-6296 or 1-800-554-4572 ext. 6296 Fax Number: (717) 909-2780 Contac:t Pel'son: Taunia Ouercia EFFECT OF SHERIFF'S SALEmYou should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE---You X mayor may not (CHECK ONE) sell or transfer your home to a buyer or transferee wh-;- will assume""the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. i. ~,-- 'r ' TQ/ipp . - ,~ ~ "';,j YOU MAY ALSO HAVE THE RIGHT: " . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BOROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE' PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Taunia Quercia Collection Counselor - i, "~~ "" "~'~,:". - ': o.~:, .~, . _,. " ,<;",-~,.,~t::-. .- '-""-'. If fund~ (Ire received Ctnd lIegotiClted in less them the total Ctmount due including legal fees Ctnd costs. Harris SCtvings Bank reserves the right to retum the funds to )/OU Clnd continue with legClI proceedings pending receipt of the total amount due. , <.~~ ; ." ;.:; ,.~ ""'" -~* ~ - ~ N~~1~. . -'. ~ - ,',' ..' _ -. _ -"' ",' '"' " ".. ,~"..", ..'lo. . 235 North Second Street P.O. Box 1711 Harrisburg, Pennsylvania 17105-1711 717/236-4041 CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 Nonh Front Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 232-4985 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 Fax (717) 243-3948 . ......_,<,. r, ~l ',..",1_.",; , - ........-_~~" ._~- "",~..._~ " ~ - -~''''''O=''';'h-'<"' ID...,.,. OJ ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!a!!e on vour home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached oal!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to help to save vour home. This notice explains how the oro!!ram works. To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TmS NOTICE. Take this Notice with vou when vou meet with the Counselin!! A!!encv. The name. address and phone number of Consumer Credit CounseIin!! A!!encies servin!! vour County are listed at the end of this Notice. If vou have anv Questions. vou may call the Pennsvlyania Housin!! Finance A!!encv toll free at 1-800-342-2397. (Persons with impaired hearin!! can call (717) 780-1869). . This Notice contains important legal information. If you have any questions, representatives at the Consumer 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 f'rod a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU mpOTECA. Harris Savings Bank 235 North Second Screet. P.O. Box 1711, Harrisburg, Pennsylvania 17105-1711 717/236-4041 . www.harrissavingsbank.com "" ~~ " HOMEOWNER'S NAME(S): ,_Ardella M. Souders AKA Ardella F. Souders PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS: _18 Valley Street, Carlisle, PA 17013 LOAN ACCT. NO.: _1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDER/SERVICER: Harris Savin!!s Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WmCH CAN SAVE YOUR HOME ' FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE . TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITIllN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIESmIf you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the prooertY is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your defaul~.) If j'cu h~~:e tried and. a!'~ un~bl~ to resolve this problem with the lender, you h~ve the right to apply for financial assistance from the Homeowner's Emergency Mortgage ASSIstance , L_c_ ,Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENmD. 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 A enc of its decision on our a lication. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TIDS 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 (Brilll! it un to date). NATURE OF THE DEFAULT---The MORTGAGE debt held by the above lender on your property located at: 18 Valley Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: . A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ a partial payment of $168.06 for October 1999, and payments of $560.51 for November and December 1999, and January 2000 Other charges:_Late charges $280.25 TOTAL AMOUNT PAST DUE:_$2,129.84 B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $2,129.84 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made pavable and sent to: Harris Savings Bank 234 North Second Street }hrri,hllrQ, PA 17101 ,..,.. -- - .~" ~ . . .. .,",1 IF YOU DO NOT CURE THE DEFAULTmIf you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri!!hts to accelerate the mort!!a!!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mort!!a!!ed property. IF THE MORTGAGE IS FORECLOSED UPONmThe mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually' incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the TIllRTY (30) DAY oeriod. vou will not be required to nav attornev's fees. OTHER LENDER REMEDIES---The lender may also sue you personally for the unpaid principal' balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at any time UP to one hour before the Sheriff's sale. You may do so bv paying the total amount then past due. plus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writing bv the lender and bv performing anv other requirements under the mort!!a!!e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLmST POSSIBLE SHERIFF'S SALE DATEmIt is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contracting the lender. HOW TO CONTACT THE LENDER: . Name of Lender: Harris Savings Bank Address: 234 North Second Street Phone Number: (717) 909-6296 or 1-800-554-4572 ext. 6296 Fax Number: (717) 909-2780 Contact Person: Taunia Ouercia EFFECT OF SHERIFF'S SALE---You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE---You X mayor may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assum~ mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satistied. -'~~ TQ/ipp . ""~M"',jl'!'I".,,"k YOU MAY ALSO HAVE THE RIGHT: · TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BOROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ' . . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, TauniaQuercia Collection Counselor " ~- If fimds are received and negotiated in less than the total amollnt due including legal fees and costs. Harris Savings Bank reserves the right to retul'll the fimdr to YOII and continue with legal proceedings pending receipt of the total amount dlle. . ~- --_.-~~,' ~.",,-. lDHARRIS$ .D SAVINGS BANK., 235 North Second Street P.O. Box 1711 Harrisburg, Pennsylvania 17105-1711 717/236-4041 CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 232-4985 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 Fax (717) 243-3948 , ~.- " ~~ ~ II ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortl!lll!"e on your home is in defanlt. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pa!!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to help to save vour home. This notice explains how the pro!!1'lllI1 works. To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TIDS NOTICE. Take this Notice with vou when vou meet with the Counselim! Agencv. The name. address and phone number of Consumer Credit Counselim! Al!encies serving vour Countv are listed at the end of this Notice. If vou have anv Questions. you mav call the PennsvIvania Housing Finance Al!ency toll free at 1-800-342-2397. (Persons with iml)aired hearing can call (717)780-1869). . This Notice contains important legal information. If you have any questions, representatives at the Consumer 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. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU , DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU HIPOTECA. Harris Savings Bank 235 North Second Street, P.O. I}ox 1711, Harrisburg, Pennsylvania 17105.1711 717/236-4041' www.harrissavingsbank.com ,~ " -" ......., HOMEOWNER'SNAME(S): _CarlE. Souders PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS: _18 Valley Street, Carlisle, PA 17013 LOAN ACCT. NO.: 1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDERISERVICER: Harris Savin!!s Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WmCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE . TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCmS---If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set ' forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance - Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN TInS LETTER , FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 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 A enc of its decision on our a lication. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TInS 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 (Brin!!' it uo to date). NATURE OF THE DEFAULT---The MORTGAGE debt held by the above lender on your property located at:_18 Valley Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: . A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ a partial payment of $168.06 for October 1999, and payments of $560.51 for November and December 1999, and January 2000 Other charges:_Late charges $280.25 TOTAL AMOUNT PAST DUE:_$2,129.84 B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $2,129.84 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made pavable and sent to: Harris Savings Bank 234 North Second Street Harrisburg. P,A. 17101 .. ,~ . - ,- ~. ~~ . ~~ '., ,,~ IF YOU DO NOT CURE THE DEFAULT---If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri!!hts to accelerate the mort!!a!!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mort!!a!!ed pronerlY. IF THE MORTGAGE IS FORECLOSED UPONmThe mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the TIllRTY (30) DAY period. vou will not be required to pav attornev's fees. OTHER LENDER REMEDIES--- The lender may also sue you personally for the unpaid principal ' balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALEmIf you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at any time UP to one hour before the Sheriff's sale. You mav do so by paving the total amount then past due. plus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing bv the lender and by perfonning anv other requirements under the mortgage. Cnring your default in the manner set forth in this notice will restore your mortgage to the same position as if yon had never defaulted. EARLIEST POSSffiLE SHERIFF'S SALE DATE---It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately four months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contracting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Harris Savings Bank Address: 234 North Second Street Phone Number: (717) 909-6296 or 1-800-554-4572 ext. 6296 Fax Number: (717) 909-2780 Contact Person: Taunia Ouercia EFFECT OF SHERIFF'S SALE---You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE---You _X_mayor _may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt. provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. - TQ/ipp . .. -, YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BOROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE . PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Taunia Quercia Collection Counselor , . ~~-- If funds are received and negotiated in less them (he total amount due including legal fees emd costs. HClrris Savings Bank reserves the right to returll the funds to )/OU Clnd continue with legal proceedings pending receipt of the total amount due. . "~ -:-:..~'"~- IDHARRIS~ IliI SAVINGS BANK 235 North Second Street P.O. Box 1711 Harrisburg. Pennsylvania 17105-1711 717/236-4041 CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 1 17 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 Nonh Front Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 232-4985 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 Fax (717) 243-3948 . ............. '., ~ ~, '. ~ L '...~~,..- B S BANKERS Leaving Our Mark. ,., ..',. , t;tt~vity February 2, 2000 ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!a!!e on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is nrovided in the attached Pa!!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to heln to save vour home. This notice exnlains how the nro!!ram works. To see if HEMAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the CounseIin!!: A!!:encv. The name. address and nhone number of Consumer Credit Counseling A!!:encies servin!!: vour County are listed at the end of this Notice. If vou have anv Questions. vou mav call the Pennsvlvania Housin!!: Finance A!!:encv toll free at 1-800-342-2397. (Persons with imDaired heann!!: can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer 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. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIYmNDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU IDPOTECA. Harris Savings Bank 235 North Second Street, P.O. J?ox 1711, Hatrisbutg, Pennsylvania 17105-1711 717/236-4041 . www.hamssavingsbank.com -"~ ,~ "~ 1-.-. ,< '-"" HOMEOWNER'S NAME(S): _Michael L. McBride PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS: _18 Valley Street, Carlisle, PA 17013 LOAN ACCT. NO.: _1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDERISERVICER: Harris Savings Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WInCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR El\'ffiRGENCY 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TIllS MEETING MUST OCCUR WITmN THE NEXT TIllRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. , YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES---If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you h~ve the right to apply for financial assistance from the Homeowner's Emergency Mortgage ASSistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they , will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN TInS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENmD. 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 A enc of its decision on our a lication. ' NOTE: IF YOU ARE CtJRRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TIDS 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 (Erin!! it np to date). NATURE OF THE DEFAULT---The MORTGAGE debt held by the above lender on your property located at_IS Valley Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ a partial payment of $168.06 for October 1999, and payments of $560.51 for November and December 1999, and January 2000 . Other charges:_Late charges $280.25 TOTAL AMOUNT PAST DUE:_$2,129.84 B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $2,129.84 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made oavable and sent to: Harris Savings Bank 234 North Second Street Harrisburg. PA 17101 1Iij""~''''o~,_.''''''-''-_,,,,,,''-...~ - ~~~. .~ ~~ ~~ I 1.--,__ --..i""""",.-.;,, IF YOU DO NOT CURE THE DEFAULT---If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri!!hts to accelerate the morte:a!!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mort!!a!!ed properlY. IF THE MORTGAGE IS FORECLOSED UPON---The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees acmally incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the THrRTY (30) DAY period. vou will not be required to pav attornev's fees. OTHER LENDER REMEDIES---The lender may also sue you personally for the unpaid principal' balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU still have the ri!!ht to cure the default and prevent the sale at anv time UP to one hour before the Sheriffs sale. You mav do so bv paying the total amount then past due. plus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as specified in writing bv the lender and bv perfonning anv other requirements under the mort!!age. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE---It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately four months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may [md out at any time exactly what the required payment or action will be by contracting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Harris Savings Bank Address: 234 North Second Street Phone Number: (717) 909-6296 or 1-800-554-4572 ex!. 6296 Fax Number: (717) 909-2780 Contact Person: Taunia Ouercia EFFECT OF SHERIFF'S SALE---You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE---You X mayor may not (CHECK ONE) sell or transfer your home to a buyer or transferee who'" will assume""the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. TQ/ipp . YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BOROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, TauniaQuercia Collection Counselor - " If funds are received and negotiClted in less than the total amount due including legClI fees Cllld costs. Harris SClvings BClnk rese/1'es the right to retul'll the fund~ to you Clnd continue with legct! proceedings pending receipt of the total amollnt due. -'-"1 , K.lHARRIS@ n SAVINGS BANK ' 235 North Second Street P.O. Box 1711 Harrisburg, Pennsylvania 17105-1711 717/236-4041 CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of West em Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 232-4985 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 Fax (717) 243-3948 . R S BANKERS Leaving Our Mark. ' ~~~rity February 2,2000 ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!a!!e on vonr home is in default. and the lender intends to foreclose. Specific information about the nature of the default is Drovided in the attached Da!!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to helD to save vour home. This notice explains how the pro!!ram works. To see if HEMAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TillS NOTICE. Take this Notice with vou when vou meet with the CoUnSelilll! A!!encv. The name. address and phone number of Consumer Credit Counselin!! A!!encies servin!! vour Countv are listed at the end of this Notice. If vou have any auestions. vou mav call the PennSYlvania Housin!! Finance A!!encv toll free at 1-800-342-2397. (Persons with impaired hearin!! can call (717) 780-1869). . This Notice contains important legal infonnation. If you have any questions, representatives at the Consumer 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. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDlTAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU lllPOTECA. Harris Savings Bank 235 North Second Street, P.O. !lox 1711, Harrisburg. Pennsylvania 17105-1711 717/236-4041, www.harrissavingsbank.com ~~ - ,..1,( HOMEOWNER'S NAME(S): _Marietta B. Fickel PROPERTY ADDRESS: _18 Valley Street, Carlisle, PA 17013 MAILING ADDRESS: _18 Valley Street, Carlisle, FA 17013 LOAN ACCT. NO.: _1751007388 ORIGINAL LENDER: _Harris Savings Bank of Harrisburg CURRENT LENDER/SERVICER: Harris Savin!!s Bank 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 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE TEMPORARY STAY OF FORECLOSURE---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TInS MEETING MUST OCCUR WITInN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. . YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE, CONSUMER CREDIT COUNSELING AGENCmS---If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set ' forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and we unable to resolve this problem with the lender, you have the right to apply for fmancial assistance from the Homeowner's Emergency Mortgage Assistance --. LH ~- .' Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY, IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN TIllS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENmD. 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 A enc of its decision on our a lication. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TillS 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 (Brill!! it UP to date). NATURE OF THE DEFAULT---The MORTGAGE debt held by the above lender on your property located at: 18 Valley Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ a partial payment of $168.06 for October 1999, and payments of $560.51 for November and December 1999, and January 2000 Other charges:_Late charges $280.25 TOTAL AMOUNT PAST DUE:_$2,129.84 B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $2,129.84 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash. cashier's check. certified check or monev order made payable and sent to: Harris Savings Bank 234 North Second Street Harrisburg. PA 17101 ~._~~. ".~~" < ~...~< IF YOU DO NOT CURE THE DEF1-ULT---If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri!!hts to accelerate the mort!!lU!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mort!!lU!ed properlY. IF THE MORTGAGE IS FORECLOSED UPONmThe mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the TIllRTY (30) DAY oeriod. vou will not be required to pav attornev's fees. OTHER LENDER REMEDlES--- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE 'rHE DEFAULT PRIOR TO SHERIFF'S SALE---If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's sale. You mav do so bv paving the total amount then past due. plus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as specified in writing bv the lender and bv perfortning anv other requirements under the mort!!age, Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLmST POSSIBLE SHERIFF'S SALE DATE---It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action will be by contracting the lender. HOW TO CONTACT THE LENDER: . Name of Lender: Harris Savings Bank Address: 234 North Second Street Phone Number: (717) 909-6296 or 1-800-554-4572 ext. 6296 Fax Number: (717) 909-2780 Contact Person: Taunia Ouercia EFFECT OF SHERIFF'S SALE---You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE---You X mayor may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume ""the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. TQ/ipp . .~~- ~c,~_. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BOROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE ' PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Taunia Quercia Collection Counselor If filllds are received and negotiated in less than the total amount due ineluding legCll fees alld costs. Harris Savings BClnk reserves the right to retuJ'll thefilllds to you and cOlltillue with legal proceedings pending receipt of the totClI ((mOl/nt due. . .._~. . . '. IUHARRIS~ n SAVINGS BANK, 235 North Second Street P.O. Box 1711 Harrisburg. Pennsylvania 17105-1711 717/236-4041 CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 232-4985 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 Fax (717) 243-3948 . '. ..> ~ .=.,"-,~~, ',;. "0'.-. ~ o I ,Ii :1 __________. 1'.1 1,1, .., ,,' -, j,',I' I': ~ o .(""t ~ '~J iii d . Q) ~ l!! ~ ~ :9- E ti e :5'ca o ~ Q) 0 E u'iii-E >-cu g~ t:.s~ . 4:.!!2 ~-eO~ M~tI]rsTIE "O'Q.l~<1ltl:lQ) c.'2:::g..c..o a. ct! 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Post Office located at the Federal Building, 228 Walnut Street, Harrisburg, PA, does hereby certify that an envelope was mailed with postage repaid by First Class Mail from the Harris Savings Bank addressed to Ardella M. Souders AR:4 Ardelia f Souders, 18 Valley Street, Carlisle, PA 17013 properly deposited U. S. Mail for delivery this r day of February, 2000. U. S. Post Office By: Federal Building Harrisburg, PA . Harris Savings Bank 235 North Second Street, P.O. Bo~ 1711, Harrisburg, Pennsylvania 17105-1711 717/236-4041 . www.harrissavingsbank.com ,~.-= , , ~~ ~ .- ~- - "'J~~ Ii S', BANKERS ,f~1" . o~ ~:ij:iW~:~:~; ,,;: ,'0;' Leaving Our Mark ,'*', ".;,'"'''' , \::f.ity", . :Jv -"./':-J,." r' vV"' " February 2, 2000 The subscriber below of the U. S. Post Office located at the Federal Building, 228 Walnut Street, Harrisburg, PA, does hereby certify that an envelope was mailed with postage repaid by First Class Mail from the Harris Savings Bank addressed to Carl E. Souders, 18 Valley Street, Carlisle, PA 17013 properly deposited U. S. Mailfor delivery this zv1 day of February, 2000. U. S. Post Office By: Harrisburg, P. Harris Savings Bank 235 North Second Street, P.O. Box 1711, Harrisburg, Pennsylvania 17105-1711 717/236-4041 . www.harrissavingsbank.com ""~=~. .~ -- - ~- I ! , . Ii BANKERS' ;f}':f:,> ". . { .~it~;:~<:':~_~~ Leaving Our Mark' p,i{!; ,",;,', '%~ity,,,.i'.'; . ,';~.dV' ,,' , l)Ivv-J,.,....,.' February 2, 2000 The subscriber below of the U. S. Post Office located at the Federal Building, 228 Walnut Street, Harrisburg, PA, does hereby certify that an envelope was mailed with postage repaid by First Class Mail from the Harris Savings Bank addressed to Michael L. McBride, 18 Valley Street, Carlisle, PA 17013 properly deposited U. S. Mail for delivery this zv1 day of February, 2000. U. S. Post Office By: Federal . Harris Savings Bank 235 North Second Street, P.O. B9x 1711, Harrisburg, Pennsylvania 17105-1711 717/2364041 . www.harrissavingsbank.com .m~_'~. """""-"- ~. . . ~. ~~;, . . R February 2, 2000 The subscriber below of the U. S. Post Office located at the Federal Building, 228 Walnut Street, Harrisburg, PA, does hereby certify that an envelope was mailed with postage repaid by First Class Mailfrom the Harris Savings Bank addressed to Marietta B. Fickel, 18 Valley Street, Carlisle, PA 17013 properly deposited U. S. Mail for delivery this r day of February, 2000. U. S. Post Office Federal Buildin By; Harrisburg, PA . Harris Savings Bank 235 North Second Street, P.O. Box 1711, Harrisburg, Pennsylvania 17105.1711 717/236-4041 . www.barrissavingsbank.com liilM ~""''''''''''''''~~~~~rj@!tliSiliI!o'~>:illlJ01lj!~h~~~,,'-,ti(,j'h'_>J:.-I'o., ","'>i1'd:.,_~",~",-,,,,,;-.;ill,r,!l1~iili!lli1!~~~""ld:I'",,,;""'~fi".~~l!!~t~!iI~~~1!;;i!>!o. l:J r;.J:: 'fls1 It.~~h~ ~~C1~6 t ~ r~ J - . n (':) 9 ~i 0 n n :1: ---I , , ~ ~~~ , ,..~ '8 r\J C$',) -CO? (SC) -_:'J" :_j "'Tl -- ;;'5 , - ~rTI , .'~.) / :n ---, :::a -<. OJ -< I SHERIFF'S RETURN - REGULAR .... CASE NO: 2000-03186 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HARRIS SAVINGS BANK VS SOUDERS ARDELLA M ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SOUDERS ARDELLA M A/K/A SOUDERS ARDELLA F the DEFENDANT , at 0014:07 HOURS, on the 25th day of May , 2000 at 18 VALLEY ST CARLISLE, PA 17013 by handing to ARDELLA M. SOUDERS a true and attested copy of COMPLAINT - MORT FORE together with FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So Answ;~/ // ~~A~~f'~< R. Thomas Kline Sworn and Subscribed to before OS/26/2000 SA'D':~,SHUFF & MASLAND ,J \Jw;n ~. ~ Deputy Sneriff me this ~~ day of 9:.., o2.-b-v-o A. D . ~f27hJ~.~v rothonotary , ' , SHERIFF'S RETURN - REGULAR CASE NO: 2000-03186 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HARRIS SAVINGS BANK VS SOUDERS ARDELLA M ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SOUDERS CARL E the DEFENDANT , at 0014:07 HOURS, on the 25th day of May , 2000 at 18 VALLEY ST CARLISLE, PA 17013 by handing to ARDELLA M. SOUDERS a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: f!'~r4-t:~( R. Thomas Kline Sworn and Subscribed to before OS/26/2000 SAIDIS, SHUFF & MASLAND By: ~QU)h ~. \LR Deputy Sheriff me this ;l ~ day of q,... p. chnnJ . " A.D. qT,"tt ,,",,111/; ).(~ rothonotary " , SHERIFF'S RETURN - REGULAR -" CASE NO: 2000-03186 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HARRIS SAVINGS BANK VS SOUDERS ARDELLA M ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MCBRIDE MICHAEL L the DEFENDANT , at 0014:07 HOURS, on the 25th day of May , 2000 at 18 VALLEY ST CARLISLE, PA 17013 by handing to ARDELLA M. SOUDERS a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ~~<v.e~~ R. Thomas Kline Sworn and Subscribed to before OS/26/2000 SAIDIS, SHUFF & MASLAND By: (\ ~ J.l ~t\ \ I ri\ . 'l.tll Deputy eriff me this ,)~ day of 0A""'~. ~tr7rO A.D. ~t2 "hui, :~ r thonotary -,-~ .~ , j' ...... CASE NO: 2000-03186 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HARRIS SAVINGS BANK VS SOUDERS ARDELLA M ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FICKEL MARRIETTA B the DEFENDANT , at 0014:07 HOURS, on the 25th day of May , 2000 at 18 VALLEY ST CARLISLE, PA 17013 by handing to ARDELLA M. SOUDERS a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ~g~1-~~~ R. Thomas Kline Sworn and Subscribed to before OS/26/2000 SAIDIS, SHUFF & MASLAND By: (\ ~ \ / . '\-J 0.3 lYV'I . M Deputy heriff me thi s .1,.....,L day of ~ d...n-o _ A.D. ~Q~~. P othonotary . SAlOIS. SHUFF & MASLAND ATIURNEYSeAT.LAW 26 W. High Street Carlisle. PA ~ HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO. 00-3186 Civil ARDELLA M.. SOUDERS, CIVIL ACTION - LAW a/kla ARDELLA F. SOUDERS. CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. Defendant(s) MORTGAGE FORECLOSURE PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a judgment by default in favor of the Plaintiff and against the Defendant(s) for failure to Answer the Complaint in the amount of sixty-three thousand eight hundred eighty-five and 42/100 ($63,885.42) Dollars, plus interest at $12,66 per diem and costs and for foreclosure and sale of the mortgaged premises, I certify the Ten (10) Day Notice of Entry of Default pursuant to Rule 237,1 was mailed U. S. First Class Mail postage prepaid and is attached as Exhibit "A". Respectfully submitted, SAlOIS, SHUFF & MASLAND Dated June 28, 2000 Prothonotary AND NOW, thiS~ay of J1.'rYl. , 2000, a default judgment has been entered in the amount of sixty-three thousand eight hundred eighty-five and 42/100 ($63,885.42) Dollars, plus interest at $12.66 per diem and costs and for foreclosure and sale of the mortgaged premises, 1.5/ (2u.J;;, --R..-f ~ Prothonotary /<.,...8 ,I i II ~ " ~ ~-~i HARRIS SAVINGS BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. ARDELLA M.. SOUDERS. aJk!a ARDELLA F. SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. NO. 00-3186 Civil CIVIL ACTION - LAW Defendant(s) MORTGAGE FORECLOSURE TO: Marrietta B. Fickel 18 Valley Street Carlisle, PA 17013 DATE OF NOTICE: June 15, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE. A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR 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 Bar Association 2 Liberty Avenue Carlisle, P A 17013 717 - 249 - 3166 / , Johnna J.. \ U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTjC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE_POSTMASTER Receiv f SAlOIS, SHUFF & MASLAND . - 26 West High Street - . . Carlisle PA 17013-2956 ,. , . >:;-, '~\~.. ' , - - - f-::: \) "i)S j" One piece of ordinary mail <:1ddressed to: '-.... ,; k-~ " - Marrietta B Fickel ~ - 18 Valley Street - ".- Carlisle PA 17013 - - _'i,.:_.':.,;\,: '.-'-' '--'-""-:1~ . r. .'." ,-, J; J_.; -' / j/: EXH'E~lf A I ;--..--,- PS Form 3817, Mar. 1989 - HARRIS SAVINGS BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v, ARDELLA M.. SOUDERS. aMa ARDELLA F. SOUDERS. CARL E. SOUDERS MCBRIDE. MICHAEL L. and FICKEL. MARIETTA B, NO, 00-3186 Civil CIVIL ACTION - LAW Defendant(s) MORTGAGE FORECLOSURE TO: Michael L McBride 18 Valley Street Carlisle, PA 17013 DATE OF NOTICE: June 15, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE. A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR 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 FINO OUT WHERE YOU CAN GET LEGAL HELP: , II I I I ! II II ,r " Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717.249.3166 Johnna J, ily, E uire Attorney t r the Plaintiff ~. ,~,~ ,HUFF & MASLAND Affix fee here in stamps -ligh Stre<=>t or meter postage and .... postmark, Inquire of 'A 17013 Postmaster fot current ~6222 fee. --- "'. ._" :-'! One piece of ordinary mail addressed to; ~ Michael L McBride - 18 Valley Street Carlisle PA 17013 ,,:., _, ~.._ ~,~ ~i-'~ PS Form 3817, Mar. 1989 ""~- ~ HARRIS SAVINGS BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, ARDELLA M.. SOUDERS, a/k/a ARDELLA F, SOUDERS, CARL e:. SOUDERS MCBRIDE, MICHAEL L. and FiCKEL, MARIETTA B. NO. 00-3186 Civil CIVIL ACTION - LAW Defendant(s) MORTGAGE FORECLOSURE TO: Carl E. Souders 18 Valley Street Carlisle, PA 17013 DATE OF NOTICE: June 15. 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTiCe:, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 717.249.3166 U,S, POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT I P::::~v: FOR INSURANCE-POSTMASTER ~/:--:,:;_" SAlOIS, SHUFF & MAS LAND' ,>< . -......... 26 West High Street 1.:::.:;-/ ~ " Carlisle PA 17013-2956 , .,' 'S, ~ . 1'; ~ ...:.... ~ .t.' ~ ",' ~ \. '=\~ \~-- .--. "i',': ,~ 'V. <..!- ".: '.,--3 /~ ' , '-. Johnna ,l1Oeily, Eire Attorne0or the Plaintiff "',^"'"'' "',HUFF & MASLAND Affix fee here. in~stamps iigh Street or meter postage and .post mark. :lnquire of 'A 17013 . ' Postrrlllster. for, ~urrent -6222 fee. - .", . ::.~: '-, <~; One piece of ordinary mail addres$e~ to: . :.~ . , Carl E Souders 18 Valley Street Carlisle PA 17013 '.-..' , ..~. ::;-i:';'7.:'.j~:;.~i-:~.~",., PS Form 3817, Mar. 1989 ~ ~', HARRIS SAVINGS BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. ARDELLA M.. SOUDERS, alkJs ARDELLA F. SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. NO. 00-3186 Civil CIVIL ACTION - LAW Defendant(s) MORTGAGE FORECLOSURE TO: Ardella M. Souders alkJa Ardella F. Souders 18 Valley Street Carlisle. PA 17013 DATE OF NOTICE: June 15. 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR 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''l''rlE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717 - 249 - 3166 John " Affix fee here in stamps U,S, POSTAL SERVICE CERTIFICATE OF MAlLIN ' or meter postage and MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT - -. post '-mark<lnquire of \ PROVIDE FOA INS~_RANCE-POSTMASTEA Postmaster, for .current fee. . Received Fr, , , SAlOIS, SHUFF & MASLAN,9<e.-~ . ';':\1. 26 West High Street I. ,>"--.----.... ' . " , Carlisle PA 17013-2956 (/f( ~~ : ".' v \~ !: ..-' l\~ ;,-.) One piece of ordinary mail addr6ssed to: \ '-.~~ ~t:";/ ",-..::;Y - Ardella M Souders alkJa Ardella F Souders - 18 Valley Street I Carlisle PA 1703 " PS Form 3817, Mar. 1989 iWilliiiliL "" ~'''''''-''~~~\Iijl,i;,"~H~gY&''''~;Mllilim!.it1tJiill<Ui=>1,~,l-~,.,t' '-"",-" -, ii" 'oW!Wt!~;\>,;iItiJB'~i~~lllii!H~:i~~,Ii'lk"d~!'J;'<~,",",",'"",,'i>_~!f:,Q~E!i!illmlili'.li'J1!j~ili~i!lllllli:,-'rI:t".w~" -.." ~,"~ () 0 ~ ....,.. C 0 5:: ~ --, <:. () -;-!::> elCU ,~ c';:!'J C ~ ~ t11F'1 Z "'r'- 0 Z,:JJ --CJ,ttl * tl= ZC- ", 0 '''::J n (.?:.t;: .0 ()6 ~ -.!U -<~ lU !<O ",. ~~r! -'l"'i ~ '4: :b """tJ ~;0 :x ';:h ~ ...J $L ji'O '? Om VJ 'c: -< ~ ::1 f(J Z '0 "'0 =< VI "< - l;t. '" II SAlOIS, SHUFF & MASLAND ATrORNEYS.AT.UW 26 W. High Street Carlisle. PA '", .0"_,--.,,,<:_-. HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 00-3186 Civil ARDELLA M.. SOUDERS, CIVIL ACTION - LAW a/kla ARDELLA F. SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. Defendant(s) MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE I, Johnna J, Deily, Esquire, do hereby certify that I served the below-named parties by first class mail, postage prepaid, the Affidavit Pursuant to Rule 3129,1; Notice to Lien Holders Pursuant to Pa, R.C.!". 3129.2; Notice of Sheriff's Sale of Real Estate Pursuant to Rule 3129 and a copy of the Legal description on the date and time reflected on the Certificate of Mailing: Ardella M.. Souders. atkla Ardella F, Souders 18 Valley Street Carlisle, PA 17013 Carl E. Souders 18 Valley Street Carlisle, PA 17013 Michael L. Mc Bride 18 Valley Street Carlisle, PA 17013 Marietta B, Fickel 18 Valley Street Carlisle, PA 17013 Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Dated: August 17, :2000 By: II ,-~ h~' --,'" HARRIS SAVINGS BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. ARDELLA M.. SOUDERS, alk/a ARDELLA F, SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL. MARIETTAB. NO. 00-3186 Civil CIVIL ACTION - LAW Defendant(s) MORTGAGE FORECLOSURE III -,,:: i-'I \K'ffix fey,ere ~6mps Or meter JI,"land p~~mar~!...~.f: e of co~~1\",11iI1 rent ::!i:M....,.:.-"<l3"i~ I<J 2iCl",'~'1 '\~ =m'(;"~~~ ,,-. ~~ :lJt;Z~~~~"\\l ~",<.v.dA"~ .,Jj~, !=I 1/1 ~'I ~! 0 I~~ ~I 0-- Il'l 1>1 0 I lG'Jj ... i. E:.....~ ij ~"**.~"'lt"':Jo*** I U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received Frorr Law Offices Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle PA 17013-2956 . , . One piece of ordinary mail addressed to: ,~---. , !t!.:'/" c.:J...... ~. -_," Ardella M Souders , 1.~t;;::)--&=-,- '~'~,....-=:; ~,~ a/kla Ardella F Souders \~~~~~: --...//~,:, 18 Valley Street Carlisle PA 17013 ...."':.:~:?_-,,"'> - .-.. ,,,,"' "- , \ PS Form 3817. Mar. 1989_ MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Carl E Souders - 18 Valley Street Carlisle PA 17013 r_:-:. ,,> ':;:"}. -' -'-'- '~I, "":""5 ...~;:n~g~ ClIlU ""S,t mark',:, li\qwle of ~._;;.jt~~~,rent t~ ~,?:g'i_~:l~ '_.,.y.......~~ i ~ j- iil li~i 1 "';;:1 '-- i ,\! !C! C:7'" dll i';!li 'ill j>~ ,= ;L ;:). ll' I m I ;;: ; ,l . ._a..-.! t. ~rt-'t.,.'"."..~:40.~)..:6- Received From: Law Offices Said is, Shuff, Flower & Lindsay 26 West High Street Carlisle PA 17013-2956 " " One piece of ordinary mail addressed to: ~,;..- , ;T- ...,-...... . . '-'"-;''-j() ./0" ....,--~ , PS Form 3817. Mar. 1989 I U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC ANO INTERNATIONAL MAil. OOES NOT PROVIDE FOR INSURANCE-POSTMASTER - Received FrOl .3' Law Offices ",; Said is, Shuff, Flower & Lindsay c~' -- 26 West High Street L Carlisle PA 17013-2956 "~. \: One piece of ordinary mail addressed to: --....-... "S_~ ~""~7: Michael L McBride ~::- ' .i * 18 Valley Street .-/ - Carlisle PA 17013 ' V' '. "~ ' , , -' - , -;.Affix f~ her&..io:*amps or meter ~_. and p~st ~ark'o)ri ore of Pq.~~~ rrent 'f40""'" 't'" '!tJ ~~~1:~}~~~, ~::::::_,,~"'-,'-l-l'i-:! >l c: I ill III ~ ! -. lall -j' ,....; l!l( 01. llij U) ! t:J' -; 1 ., :0>1 f'". ' \;;;1 171 }. I *+~1{"*"",,?+"''''''' PS Form 3817, Mar, 1989 - ~~ ..~ HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3186 Civil CIVIL ACTION - LAW Plaintiff v. ARDELLA M.. SOUDERS. aJk/a ARDELLA F, SOUDERS. CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. Dafendant(s) MORTGAGE FORECLOSURE I "'Y \'1 I::: here~\s amps "" po...~ and r~~,,~q re of -'y~.l~, rrent ~~~~~ ',,,~.- ~ ~:~I c:: r;\I ~ HII till _..--J ~l..: li"::t;t-;.Io*lif' U.$, POSTAL SERVICE CERTIFICATE OF MAILING /ltffixfe,i :''3GT me MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT \post nii PROVIDE FOR INSURANCE-POSTMASTER - P~mas Received f f,~.~ cn;l~~~'u'>,: Law Offices ~.. ..,--;--~~. ~J~~.i:I.:;..... Saidis, Shuff, Flower & Lindsay ~;~~~; 26 West High Street Carlisle PA 17013-2956 "'""~--"., ICI II ft..,l . ," ! 1-" One piece of ordinary mail addressed to: .'~~.... 0; I~i - / ~!.,- /? \- , lEi -1""<'"'1 ~~ Marrietta B Fickel . """" ,",,0 t-... ~ -' " '~,----,'~~~- " '~.:40-'''''1It''* 18 Valley Street ,.I Carlisle PA 17013 ,~:~~-/ ~~.... '" -- I IpS Form 3B17. Mar. 19B9 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FDA DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received Fro , Law Offices , Said is, Shuff, Flower & Lindsay i 26 West High Street Carlisle PA 17013-2956 "-. One piece of ordinary mail addressed to: ,~~-- ,<~::y"'~3 ~---....., - i';---~ . '. . Harris Savings Bank f ;;': (' C!3;:;.' = . - 449 Eisenhower Boulevard 1 ..'=.....~ Harrisburg PA 17105-1711 ~~ " .<t; ~ ; , <b\~--/ i - '\.' '>'." ~ x~ :::l1tO ; . ,....Affix fej he!~it1frmps 'or meter'1)o~. and 'J~~:'a~: c,~tr:;~~ ~ .....:::;.~lf$~;~"l.. :';'.' ':;Jh'6"i'!,~.~ _ -.::, III li,,~"' ~~; q ~-' , '''''! ~ >61 ~ ql; "; ::::; ~ PI \ E: --- jq, ; ,,' " ~~;! ,~;..:-;:~ :}~;;;*:; PS Form 3817, Mar. 19B9 U..;>, rUQ I....L. QcnVIl..C "",..n I.r.,-,,,,. C VI"' IYI"'IL.II.,U MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER . '7 -. ._--,-,---,..-- ,or met~ posta, "gtft.and PQ$t m8tk,\~~ of P~.!~~l:~ rent d!!!lh~,,,,,,,.tl"11 (-!:;~-;-:;f:,\,fj" r::J C""''''~'' .,,, '~, 'o~k~,_J ..~ ',..~ S:~1R;~.\~~:~~' :~.,~w!"~_,. ;~l ~ :nl ..vi !~\! ~~\ ~ 1111 - !1'-i' i~' th ~ I :_":"::.-J 'I.: _/*i.>r.>:A->i'.i'~::jo"'","** Received F Law Offices Said is, Shuff, Flower & Lindsay 26 West High Street Carlisle PA 17013-2956 i One piece of ordinery mail eddressed to: ./ '("" 1~ _..., ~ ~o..~ ~.~ , \ .\ =- Cumberland County Tax ClaimBLI~\I Cumberland County Courthouse "",,;:;:-_~, One Courthouse Square ~, ' Carlisle PA 17013 '. PS Form 3B17, Mar. 1989 - -- '~ h SAlOIS, ~HUFF & MASLAND A'I'TOItNP.VS-AT-IAW Z6 W. High Street Carlisle. PA ~ = . " HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff v. NO. 00-3186 Civil ARDELLA Moo SOUDERS. CIVIL ACTION - LAW alk/a ARDELLA F. SOUDERS. CARL E. SOUDERS MC8RIDE. MICHAEL L. and FICKEL, MARIETTA 8. Defendant(s) MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Harris Savings Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of execution was filed the following information concerning the real property consisting of one tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013. 1. Name and address of owners or reputed owners: Carl E. Souders and Adrella F. Souders, alkJa Adrella M. Souders 18 Valley Street Carlisle, PA 17013 2. Name and address of defendants in the judgment Ardella M. Souders, alkfa Ardella F. Souders, Carl E. Souders McBride, Michael!. and Fickel, Marietta B. 18 Valley Street, Carlisle, PA 17013 3. Name and address of every judgment creditor (other than the Plaintiff herein) whose judgment is a record lien on the real property to be sold: Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 4. Name and address of the last recorded holder (other than the Plaintiff herein) of every mortgage of record: Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 1 SAIDIS, HUFF & MASLAND ,4,TmltNEYSeAT-LAW 26 W. High Street Carlisle, PA ;: 5. Name and address of every other person who has any record lien on the property: 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: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None. 'I, Johnna J. Deily, Esquire, attomey for the Plaintiff, Harris Savings Bank, verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unswom falsification to authorities. SAlOIS, SHUFF, FLOWER & LINDSAY Dated: 6" is, 00 By' Jo S reme Court ID #53147 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorneys for Plaintiff 2 SAIDIS, iHUFF & MASLAND "Tm~AT.LAW 26 W. High Street Carllste. PA HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO. 00-3186 Civil ARDELLA Moo SOUDERS, CIVIL ACTION - LAW a1k/a ARDELLA F. SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL. MARIETTA B. Defendant(s) MORTGAGE FORECLOSURE NOTICE TO LIEN HOLDERS PURSUANT TO PA. R.C.P. 3129 NOTICE IS HEREBY GIVEN TO the following parties who hold one or more mortgages, judgment or tax liens against the real estate of Carl E. Souders and Ardena F. Souders,h/w. Ardella Moo Souders, alk/a Ardella F. Souders 18 Valley Street Carlisle, PA 17013 Carl E. Souders 18 Valley Street Carlisle, PA 17013 Michael L. Mc Bride 18 Valley Street Carlisle, PA 17013 Marietta B. Fickel 18 Valley Street Carlisle, PA 17013 Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 You are hereby notified that on December 06,2000, at 10:00 a .m. prevailing time, by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, on the judgment of Harris Savings Bank v. Ardella M. Souders, 1 II " Ii SAlDIS, HUFF & MASLAND A1TO~Ar-LAW 26 W. High Slreet c.uU.le. PA - ,~ alk/a Ardella F. Souders, Carl E. Souders, Michael L. Mc Bride, Marietta B. Fickel, No.OO- 3186 Civil in the amount of $63,885.42 plus interest from May 11, 2000 $12.66 per diem, costs, attomeys' fees and for foreclosure of the mortgaged premises, the Sheriff of Cumberland County, Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, Commonwealth of Pennsylvania, real estate of Carl E Souders and Adrella F. Souders, alkla Adrella M. Souders, known as that tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013. A description of said real estate is attached hereto. You are further notified that a Schedule of Proposed Distribution will be filed by the Sheriff of Cumberland County within thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless exceptions are filed thereto within ten (10) days thereafter. You are further notified that the lien you hold against said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriff Sale. Dated: 8 -IS, Dc:.:> By: Joh SAI IS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attomey for Plaintiff Attorney 1.0.53147 2 SAID IS, HUFF & MASLAND A: -LAW 26 W. Hlgb Slreet Carlisle, PA ~~~ HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 00-3186 Civil ARDELLA M.. SOUDERS, CIVIL ACTION - LAW a/kla ARDELLA F. SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. Defendant(s) MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: December 06, 2000 TIME: 10:00 A. M. Prevailing time LOCATION: Cumberland County Courthouse 1 Courthouse Square Carlisle PA 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal deSCription mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: all that certain improved tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley street, Carlisle, PA 17013. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to Harris Savings Bank v. Adrella M. Souders, alkJa Adrella F. Souders, Carl E. Souders, Michael McBride and Marietta B. Fickel, No. 00-3186 Civil for $63,885.42, plus interest from May 11,2000 at $12.66 per diem, costs, attorneys' fees and for foreclosure of the mortgaged premises until the Sheriff Sale. 1 SAlDlS, SHUFF & MASLAND "TmR~^r-LAW 26 W. High Slreet Carlisle, PA THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property are: Carl E. Souders and Adrella F. Souders, h/w A SCHEDULE DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this , schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. . THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights. YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2 SAID IS, HUFF & MASLAND ATmRNEYS-AT-tAW 26 W, High Street earli,l., PA I~""" 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the, petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation to the Court. A copy of the Writ of Execution is attached hereto. SAlOIS, SHUFF, FLOWER & LINDSAY Dated: 8 -IS-~DD By: J S preme Court 10#53147 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorneys for Plaintiff 3 :i 'I I, II LEGAL DESCRIPTION ALL those certain two lots of ground situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEING Lots No. 19 and 20, block "L", of that certain Plan of Lots known as Carlisle Manor Extension, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page 99. Said Lots having a frontage on Valley Street of 1 00 feet and extending in depth 150 feet to line of Lot No. 16, Block "L", in the rear. It being the same two lots of ground which Pierson K. Miller and Margaret S. Miller, his wife, by deed dated April 7,1954 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book "R", Vol. 15, Page 355, granted and conveyed to Adrella M. Fickel, now intermarried with Carl E. Souders, one of the Grantors herein. BEING SOLD AS THE PROPERTY OF CARL E. SOUDERS AND ADRELLA F. SOUDERS a/kJa ARDELLA M. SOUDERS 1ti'.ll;;i;!adinlli~~ieill!'M~,;"",.,->,~"~"""'10\jb,,",,,,,-,,~_.o 1tGIl!B' .II.' 1II!IIIIL ... ~"~~~<"O"~.~., ,.",g. ~ ~>, '"~-" . ,~.... -" b~l-, ." tiI~~~~~~fIIIlIilIIil (") C:, ,- c: C:' " ~~, .. "'1J r'-j "'" ;=! .'-"' r!l r:- ~:;.) 2:: " C ,-- 2:: -- rn (j) ::~: co C::i -< c~) r' C' 5~ )3: ~-~ S2 ""T\ €~E; ~.. C) ~, C) rn ~ c--= ';;-;J Z ---j =<! ~:"'j );0. ...J ::D -< ~ < ~I '. ~-, PRAECIPE FOR WRIT OF EXECUTION P.R.C.P. 3101 TO 3149 HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. Plaintiff NO. 00-3186 Civil v. AD RELLA M. SOUDERS alkla AD RELLA F. SOUDERS CARL E. SOUDERS MCBRIDE, MICHAEL and FICKEL, MARIETTA B. AMOUNT DUE: $63,885.42 INTEREST AT $12.66 per diem FROM May 11lh, 2000 thru Date of Sale ATTY, COMM.: $2,900.00 COSTS: TO BE ADDED Defendant( s) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Adrella M. Souders, a/kla Adrella F. Souders, Carl E. Souders, Michael McBride and Marietta B. Fickel, 18 Valley Street, Carlisle, PA 17013. (3) and against the following Gamishees: N/A (4) and index this writ (a) Adrella M. Souders, alkla Adrella F. Souders, carl E. Souders, Michael McBride and Marietta B. Fickel, 18 Valley Street, Carlisle, PA 17013. (b) against N/A Garnishee(s), as a lis pendens against the real property of the Defendant(s) in the name of the Garnishees as follows: all that certain tract of land situate in South Middleton Township, Cumberland County, Commonwealth of Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013. (5) Exemption has (not) been waived, SAlOIS, SHUFF, FLOWER & LINDSAY g.lr.oo Dated: By; J na J, D ,Es ire S reme Court 10 #53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorneys for Plaintiff J.lI 1illWlS:!W~'WI~",,",___"'''\<'-'~~_~;W5I~~,,"~Y ';,;,~"",J.c;l",;;,!;,,,'''';I!OI*~i~'!i~"~~&~JlWlMlli.til~Jill.iJJ.ill!ilitW~lbIi!~~'ll~ll!li,jjl\Ii..lliJi!llilllMlJI~lill~i!I-"'~"""'""'''' ~"~~ -~"~ (') 0 n c: c..""> .:::r1 s: ",. -' "'OeD c::: mrn G") .. Z-'J) ,:;-~r5 z' -' cn"T:-, ---';. I ~7: ~{~~ ,<0 ="" ~o ...:!:o. -0 s:? (srn ):>c ---\ ~ ;:? ~ (J:) -< ,:DJn.(!!!L,JIJUr J. ..ltif"".!J:t;,~~(~",_;~ t~A"''''''''.) L ,",0':' -~ -.,jlUk_, ,_ J.._ ._ ',~ ~~,." c ,,(~,,"='-~;:'_~("~'_~~ ~.~< .. 'I! SAlOIS, SHUFF & MASLAND AlTORNEYSIAT-LAW 26 W. High Sir... Carlisle. PA i:: 1: " I HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~I ;t Plaintiff t, Ii Ii v, NO, 00-3186 Civil ARDELLA M.. SOUDERS, CIVIL ACTION - LAW a/k/a ARDELLA F. SOUDERS. CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. ~! f' i r-i H I.! r~ 1'1 I", il I: '" Defendant(s) MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Harris Savings Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of execution was filed the following information concerning the real property consisting of one tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013. 1. Name and address of owners or reputed owners: Carl E. Souders and Adrella F. Souders, alkla Adrella M. Souders 18 Valley Street Carlisle, PA 17013 2. Name and address of defendants in the judgment: Ardella M. Souders, alkla Ardella F. Souders, Carl E. Souders McBride, Michael!. and Fickel, Marietta B. 18 Valley Street, Carlisle, PA 17013 3. Name and address of every judgment creditor (other than the Plaintiff herein) whose judgment is a record lien on the real property to be sold: Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 4. Name and address of the last recorded holder (other than the Plaintiff herein) of every mortgage of record: Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 1 ~' ----", -li;jjllli' Ii nlll t~"~~''''''"l*ill.llllilll~~",mlitll;i.6_-.l11jj;-iii~M' .--." [jJ~l]';ii.ldlll-~"""~~- -" ".~-~'~illililllilii ,II .. -~~-' " ~iIMiilII (') c $~ "0("" ,...... '_e "lfr 2," -2": J-::':~ 0].1:;-: ",-". r- r- , --:-' -' ~-. 2\:) j;: (" c: 2: =< Q:) '. ~ '.' <" "'~ o C> b c::: ~-:> (J. ... ~-:;-:r 1-'.' "-! --}:-'q --;__:"(~J ':>~(~ ':~~J :i~' ,~~ ?~? . );, ~u --< .:b.. '~ 9 111 SAlOIS, SHUFF & MASLAND AlTORNEYS-AT.LAW 26 W. High Street Carlisle. PA \'! 5. Name and address of every other person who has any record lien on the property: I f, (1 I; [, I [, " I 1-' n , I (' i II ti ~; I Ii II i~ If ';; None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None. I, Johnna J. Deily, Esquire. attorney for the Plaintiff, Harris Savings Bank, verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unswom falsification to authorities. SAlOIS, SHUFF, FLOWER & LINDSAY Dated: 'B' rs ,00 By' Jo S reme Court ID #53147 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorneys for Plaintiff 2 ~".-'-""""'illIlI""""-=""'-~.Iilillllill!r' L L rnfl 11m ~J"n.L]:-, o'__<.<~"'<~".l ,_~_" zm,jil;iilfiIIy~~~lIW/IjI;illhiIMMi.-1 , ,., " "~--,, . -.,,~ -+ '~l> . '~~_lIlI'""~ 'WlllltlllOllliBiN ,< .-, "~- () c;. c: CJ Q ~ :-0;:;':': :Do ., IIJ''''''; -"-; rr-. '- z..' GJ , iJ3 ~~. ~:"~~; i:l3 ;:$ :<':' -.! :s:CJ ~3c~) ,;b:(> '::'::.!>J ? " ~-,. ~~J ~~ '-==:-c5 .l>c S3 Z orfl :< -.j J>' co ::.0 -< " SAIDIS, SHUFF & MASLAND ATfORNE\Js-AT-LAW 26 W. High Street Carlisle, PA HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA i ! i , ~ , ~, II; , ~, v. NO. 00-3186 Civil ARDELLA M.. SOUDERS, CIVIL ACTION - LAW alkJa ARDELLA F, SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B, Ii I, f! I" Defendant(s) MORTGAGE FORECLOSURE NOTICE TO LIEN HOLDERS PURSUANT TO PA. R.C.P. 3129 NOTICE IS HEREBY GIVEN TO the following parties who hold one or more mortgages, judgment or tax liens against the real estate of Carl E. Souders and Ardella F. Souders,h/w. Ardella Moo Souders, a/kla Ardella F. Souders 18 Valley Street Carlisle, PA 17013 Carl E. Souders 18 Valley Street Carlisle, PA 17013 Michael L. Mc Bride 18 Valley Street Carlisle, PA 17013 Marietta B. Fickel 18 Valley Street Carlisle, PA 17013 Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 You are hereby notified that on December 06, 2000, at 10:00 a .m. prevailing time, by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, on the judgment of Harris Savings Bank v. Ardella M. Souders, 1 ,[ II \lIIIIl___~~ ~iFtilill' \i!a 'li'~!IlJ4.Ii!ilmau"m~""'~ ,-~'~ ",J L,l:"Q.."I,ll~,L_,.1JfJILrtL "e- J """~~~,.~~" ,~~,,~~ " N<_ :llAlIlIlI.........IiwiiI"'"""...~ , ~ ,~'".- i.rilJilldiliilllilii. ".~.~ . .'~ ~.""'""" (") c::: ;;=- "'1~" rnCf-7 <!SZJ ;:: f-.~l CO2 rs.':::~ .-s:;C; ;]::;> ..,2:'() ji:C) c: ~ ():) - C1 C:l :z:" - c:; (") -q -'--I - ---l '-"\J_~ .{;:~ ,,' -~-,' ,~~ :...5r-:1 5;! :J...'J --<; 5~~ S? - ~i SAlOIS, SHUFF & MASLAND A'ITORNBYS-AT.LAW 26 W. High Slreel Carlisle, PA alkfa Ardella F. Souders, Carl E. Souders, Michael L. Mc Bride, Marietta B. Fickel, No.OO- 3186 Civil in the amount of $63,885.42 plus interest from May 11, 2000 $12.66 per diem, costs, attorneys' fees and for foreclosure of the mortgaged premises, the Sheriff of Cumberland County, Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, Commonwealth of Pennsylvania, real estate of Carl E Souders and Adrella F. Souders, alkfa Adrella M. Souders, known as that tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013. A description of said real estate is attached hereto. You are further notified that a Schedule of Proposed Distribution will be filed by the Sheriff of Cumberland County within thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless exceptions are filed thereto within ten (10) days thereafter. You are further notified that the lien you hold against said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriff Sale. Dated: 8 ~ (S" ,aU By: Joh SAI IS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorney for Plaintiff Attorney 1.0. 53147 2 :1 II - !II .. "~~"".-illlllllIii~liS ~,...,- . """"IlIIiIW"~,fi,,;mI"""';:l~rui~,,,~lIIiMIl~_-- T ,I, J "L -v _ "'_ ,_', _~ ~ c,. ", ' ,'C' ~, <" - ^ ~" ...... .-- . ~di .....----iIiIIiIIiIli""'"""'"' 0 a c- o () >-:;, '"" mfj; b ~ :;-:f 7,ql G') 2t~"' .. Co ,> ',rn ;;"co' ~....J ,;~;l,? ...:., _:;::: c:: .:t:m. ~::{C) ~() -r,.. ~~~ J>o 5 c: 6'ft :;;:: =;! ~ co :0 -< ,~; ~ SAlOIS, SHUFF & MASLAND AlTORNB\'sI;AT'LAW 26 W. HIgh Street Carlisle, PA HARRIS SAVINGS BANK v, ~!' I~I ~: Ii , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 00-3186 Civil ARDELLA M.. SOUDERS, CIVIL ACTION - LAW a/kla ARDELLA F. SOUDERS. CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. Defendant(s) MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: TIME: LOCATION: December 06, 2000 10:00 A. M. Prevailing time Cumberland County Courthouse 1 Courthouse Square Carlisle PA 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: all that certain improved tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley street, Carlisle, PA 17013. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to Harris Savings Bank v. Adrella M. Souders, a/kla Adrella F. Souders, Carl E. Souders, Michael McBride and Marietta B. Fickel, No. 00-3186 Civil for $63,885.42, plus interest from May 11, 2000 at $12.66 per diem, costs, attorneys' fees and for foreclosure of the mortgaged premises until the Sheriff Sale. ,I II 1 - .1/!lIiIi_1\! ""'_~~~ilW~,,' =''''- ".L,ll 1 "nMlIh,:m:.:' ,-~ H___,,!:i- ,,,'- "f ,c. ,~,~~ ,,",,", , '.'''''---'" - iU!~" ,~. "'~ -~I---- ._"_.~-- o c: s: ::Q. ~ O::J "'lfn 2:~, 2:P ~;~?; -...::....." 2:"'('........ ..2:..1 ~() ""C 2: -j -, (,"J o J:>o c:: I:;J o '1 ."'j'j fJ1 'C!fTl 2j;~ ZSiT] ~, .> ::0 -< -..) """ =':: "'" (Xl ~, SAlOIS, SHUFF & MASLAND ATI'ORNEYS-A.TlLAW 26 W. High Street Carlisle, PA "" THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property are: Carl E. Souders and Adrella F. Souders, h/w A SCHEDULE DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. ~ 11 R " Ii II " Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY 1'0 BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717.249 - 3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2 ,I Ii II -- ~""'llIilII ll>liiiI-.", ",,'~ 'iIiI~,,!~'\l:i!>;.';;,~.'_."""""'~"'" ~~'liiil J! l1!i' ,IIlIJ_ . ," TJf. ~. ;Z,"." '.,~"~- ...~-~-~ >-iIlIiaIIIii~~1lI!IIi!lMl ~=. ""'~ IiIlIIIII . 0 C) 0 C 0 'n <- no -otI: c mnj GJ "1-1 Z::CI 1':-: 2;1:,:: :"-n (JJ,_~,. -.) .\:;(~) -<2: / ~~~ r::~ .<,-j :1::"" )>f---" :;;?2~ L"''''- .=0 C5 Pc CitTI Z -" :r> -I :n -< ():) -< ~, SAlOIS, SHUFF & MASLAND ATIURNEYS.AT-LAW 26 W. High Street Carlisle, PA 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation to the Court. A copy of the Writ of Execution is attached hereto. SAIDIS, SHUFF, FLOWER & LINDSAY Dated: 8- (S'"oD By: J na J. ily, squire S preme Court 10#53147 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorneys for Plaintiff 3 ~ ~ , " '1<.=, LEGAL DESCRIPTION ALL those certain two lots of ground situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEING Lots No. 19 and 20, block "L", of that certain Plan of Lots known as Carlisle Manor Extension, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page 99. Said Lots having a frontage on Valley Street of 100 feet and extending in depth 150 feet to line of Lot No. 16, Block "L", in the rear. It being the same two lots of ground which Pierson K. Miller and Margaret S. Miller, his wife, by deed dated April 7, 1954 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book "R", Vol. 15, Page 355, granted and conveyed to Adrella M. Fickel, now intermarried with Carl E. Souders, one of the Grantors herein. BEING SOLD AS THE PROPERTY OF CARL E. SOUDERS AND ADRELLA F. SOUDERS a/kla ARDELLA M. SOUDERS ""., .""'" '._*\iL~~..M.".~_~ii-~'iil1l""~""''';' :"~_;"'_>H"hl'-'J.",*,"$,.~~_llI:IiI~~iil!"Illll-~",,~~~"-" fu~ ... :::0 :q:. ..-C) ~ -...Q "-J' ~ ':.r ; c-~ ~~ \\J ......J -- Jl) - ~., , III II mlJ[, I .. ," ,_ _,'''._, "", .. \J) ~J =- ' 0\)'0 L""'I':::, . C> I --Gvr,& ~?"::-:1Vr C>oC>_ ~'()- DOO>CJOO ~ ~. ~ :n t7 % , 0 0 (:) c: 0 " s: :po u(Il r- ;~l rnrn 0 Z:U , : , ~ ~~~: ...... "i\"CJ ;~(:) ~::C::' ~ -T, ," ~C.' -';'" '.'.~J t5 ~C> 6 ~:.;r-n c: ::i 2: ?D =< 0:> -< - ~ ~ ,.. - =' ~ ,-:- JAMES D. FLOWER JOHN E. SLIKE ROBERT C. SAIDIS GEOFFREY S, SHUFF JAMES D. FLOWER, JR, CAROL J. LINDSAY JOHNNAJ. KOPECKY KARL M. LEDEBOHM JOSEPH L. HITCHINGS THOMAS E. FLOWER LAW OFFICES SAIDIS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attomey@ssfI-law.com OF COUNSEL ALBERT H. MASLAND WEST SHORE OFFICE: 2109 MARKET STREET CAMPHILL,PA 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE August25,2000 Sheriff of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle PA 17013 INRE: Harris Savings Bank v. Souders, et. al. Docket No. 2000-03186 Civil Dear Sir or Madam: Please cancel the Sheriff Sale currently scheduled on the property of the above-captioned debtor for December 06, 2000. These debtors have applied for and received assistants from the Pennsylvania Housing Finance Agency (pHF A) and they (pHF A) have paid the default current. If you have any questions please do not hesitate to contact my office or myself at 717-243-6222. Thank you for your help and cooperation in this matter. Very truly yours, JJD/ler Cc: OWER & LINDSAY "x~/ , Esquir? r Johnna . Stacy L. Armstrong Harris Savings Bank ATTN: Default Management 449 Eisenhower Boulevard Harrisburg P A 171 05-1711 .', . ~ ~, , ,', "" , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~rm CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Harris Savings Bank PLAINTIFF(S) from A(rr~11r1-'M6:Hr)1'lnprq, .=I/k/.=I nn-r,o.ll.=l F ~ntln~l""C:r r.=ll""l F. Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 ~nllnArc:. M;~h.=lpl M~Rr;np .=IMn DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof: (3) If property ofthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above stated. AmountDue $63,885.42 I t t $12.66 per diem FROM May 11th, n eres thrn !1at.. of Sill" Atty'sComm $2,900.00 % Ally Paid $151.10 Plaintiff Paid 2000 L.L. .50C;: Due Prothy $1. 00 Other Costs Date: August 17, 2000 Curtis R. Lonq c' Prothonotary. Civil Division by: Ll+J lA)~OL)~ ~. foep ~. REQUESTING PARTY: Name Johnna J. Dei! y Address: 18 Vally Street Carlisle, Pa 17013 Attorney for: PHff Harris Savinqs Bank Telephone: (717) 243-6222 Supreme Court lD No. 53147 , n_- ~_, I or", j~i AUG 3D P[ {.' 'i I"l: IU ", ~.1 , ".: '1.,' C. 'f I ' " ,1, _ V/ 'I '\ "" ).. { 'lUfF "vvllfY " , ,.-, "".~ ."~ <<, ,. "'n II 'n] ,.;.~- ,..,-, J~~~~~~I~l~w ,,~_"III!I',_'t"""'""fI!t...fWl~~"''''''''''''''!''l~'''''''''''-'~''\''''''''';-''!<~~-~''''"''~,~~"""=~IIi!ffiMIBJr~,,,,,~ ~ '" ,--= ........ -,~ , , ....-..' , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~ CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt. i,,-terest and costs due Harris Savings Bank PLAINTIFF(S) from Adrelln M~ SOl1c1prc:: rt/k/rt l\nrAllrt F' ~()tlnprc::. ('.:::Irl F. ~()llnprC:::r MirhrtAl Mr'Rrinp r:tnn Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to nomy the garnishee(s) that: (a) an allachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee. you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated, Amount Due $63,885.42 $12.66 per diem FROM May 11th, Interest tlw' naw of $al", Atty'sComm $2,900.00 % Atty Paid $151.10 2000 LL .50<: Due Prothy $1. 00 Other Costs Plaintiff Paid Date: Auqust 17, 2000 Curtis R. Long " O/f>i;;;;J"~jTJ~~ REQUESTING PARTY: Name johnna J. ceilv Address: 18 Vally Street Carlisle, Pa 17013 Attorney for: pUfl Harris Savings Bank Telephone: (7171 243-li227. Supreme Court ID No, 53147 TRUE COpy FROMRECORO In JuttmcJny Whereof. I,*, unto. my hand _'.,.II"of, sa. Id,~.. at.,Ca,.'..~ T"I~ ~~y of ~' ' , . ' ", .' ~~121 , PtotllOnotalY -. I, OFc" tUG 3u PEi:. /0 51 , ~'I I I ,~ L. Ii,; /i I,:l r, ., l'\iIIIiIl",~~_., _ ,,~liffl'ffl~ff~~~,iJj!I1f-~ ~-=,...~ 'H 1 ,o~ .~ ~- , ',j>,,' :!r,'illf" :.vt( 1I::~, UU ,:i ""l"';~:mJl!'ll]l'2!~'~'_":"'t",I'r,~,,"- ","'.;r-""-,,c~"~P"%~~~~Q~,m!~I!'_'iIIl~~~I'MR" C,,_"_I!ll~ "- ."., ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~nn CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, iQlerest and costs due Harris Savings Bank PLAINTIFF(S) from Adre11;g M. S()11npr!=:. Pl/k/r1 anrpll;::a F' ~nl1np.rc::.r (';::aTl F. ~nl1n~rc::.r M;rh;::ap.l M(""Rr;np ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above stated. Amount Due $63,885.42 $12.66 per diem FROM May 11th, Interest tb""l naw of Sal@ Atty'sComm $2,900.00 % Atty Paid .s151.10 Plaintiff Paid 2000 LL .50<:: Due Prothy $1. 00 Other Costs Date: Auaust 17, 2000 Curtis R. Lonq Oy am be~~;;:. I:' O~(l~ v ~............. t . Y --- REQUESTING PARTY: Name JohnnaJ. Deilv Address; 18 Vally Street Carlisle, Pa 17013 Attorney for; PHfl Harris Savinqs Bank Telephone:. (717) 243-627.7. Supreme Court ID No. 53147 - ~f1 ,~j",;,,,,.' ,",' ., ,.- ">. ~~;~' n.....'.. I:~.'T O!'...-, hUG 30 10.';1 <'I/IP" ....c'li.,""" "r,' '.....J ,'I' UJ ~. ~ PC__'-,:','i' " , .) \~> I '- .' ).~ .: ' " ! i I 1/1 - _ ~"""'r'~", ^. .1-~~~ftm~!l!'~~WllI\"Ji!MJl'~"~ _'".........~""~,~~ft~IIi"i,rp;'-f'1~o' ;""1;"WN"j~.:,~ --";1)~1W"~'''"1~~f!''~~!!;IlIIO. ,.l'r!lli1!~ ~. . "'-'-' WRIT OF EXECUTION and/or ATTACHMENT ". COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~ CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, i~erest and costs due Harris Savings Bank PLAINTIFF(S) from adrel1;g M. Snnnpr!=:. r1/k/;::a anrp..ll;::a Ji' ~()nnp..rc::.r (';::ar1 R ~nllnp.rC:f M;(""h;::aAl M,..Rr;np. ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or lor the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) II property of the defendant(s) not levied upon an subject to attachment is found in the po~session of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as agarnishee and is enjoined as above stated. Amount Due $63,885.42 $12.66 per diem FROM May 11th, Interest thm nabs of S..l@ Atty'sComm $2,900.00 % Atty Paid S151.10 Plaintiff Paid___~ 2000 LL. .50<:: Due Prothy $1. 00 Other Costs Date mAuqUst 17,--2000 ._ Curtis R_ Lonq OyWmte~"i~O~ - REQUESTING PARTY: Name Johnna J. Deily Address: 18 \1a~:i;y St:t.ceet Carlisle, Pa 17013 Attorney for: pUff Harris · ~iivinqs Bank Telephone (717) 243-6777 Supreme Court 10 No. 53147 ~~ W~ ~~H_ .i~ Or(- J'" dUG JO Pi- " 1.,,' ",' -" I -'~ :: 'U. f;' '"' W"F""^: ~ ."< ",~{?iF'F' '"!try, r; '~ ,,_'I ,d, ' i I"j . """",,,'!!!l'fiilIlJII~~""'%I~IW~~~~~I~~'W''''W'H!~'1r'""''':'''"'''''"'''-l'"''' ;,,., """''''''''''''l'''''L~'l!n'~~Ii!lflfl~!<i~~'ffl!~~~""""""..~~ WRIT OF EXECUTION and/or ATTACHMENT ". COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL 1!k~nn CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisly the debt, iil-terest and costs due Harris Savings Bank PLAINTIFF(S) from acin==-ll;g M. S011npr!=:. ;::a/k/;::a anrp..ll;::a F ~nl1('1ArC:r r;::arl F. ~nl1nAr!=:.r M;(""h;::aAl MroRrinp r1nn Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of Ihe defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or lor the account of Ihe defendanl(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject 10 attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlherthat he/she has been added as agarnishee and is enjoined as above stated AmountDue $63,885.42 $12.66 per diem FROM May 11th, Interest thr" nate of Sal@ Atty's Comm $2,900.00 % Atty Paid $151.10 Plaintiff Paid 2000 L.L. .50<:: Due Prothy $1. 00 Other Costs Date: )l.Uqust 17 , 2000 Curtis R. Lonq prothonO.,t,~. C'"'O~~~ byan~~~?J Ct-.J~ " ty - liEQUESTING PARTY: Name Johnna J'. Den y Address: 18 Vally Street Carlisle, Pa 17013 Attorney for: PHfl Harris, Savinqs Bank Telephone: -.ill?) 243 6?n Supreme Court ID No, 53147 ~ ~ I " I \1 I " - -.- - - .." 0"., I" I;" . AUG 30 " " ' ),,'! I Q ":"11\; J f:" ~J ",1 (~. .'. '-I ii0; ID 5.1 .~ ''''HI'/' ,:,),ltTr iil ':,r} oJ!.,. ,< ",'. ",",.W""'''" - ~.. """","""__=o..A,^~flm"~q~ffi!I!.~",,,,,-,..";"'" "".lJ~~_~~r'''!!Hf-W~;,.r.*":;,,,,,;.'''''''~\~.'''r'~''\1f,,*J1Jr.~~~Hll'~!~IlIJIBJl~_""'''''''~ 1\, . I~ 1-'/"{'i //\ - ~ ," WRIT OF EXECUTION and/or ATTACHMENT ". COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~rm CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, i~erest and costs due Harris Savings Bank PLAINTIFF(S) from 'Anrpll;g M. S011npr,q ;::a/k/;::a Anrpll;::a P' ~nl1np..rC:r r.;::arl F. ~nl1np.rC:r M;(""hrlpl M,..Rrinp. :=Inn Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENOANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the posseSSion of anyone other than a named garnishee, you are directed to notity him/he r that he/she has been added as agarnishee and is enjoined as above stated Amount Due $63,885.42 $12.66 per diem FROM May 11th, Interesf tl1r1' naw of Sa1", Atty'sComm $2,900.00 % Atty Paid S151.10 Plainfiff Paid__~__-,----____ 2000 L.L. .50<:: Due Prothy $1. 00 Other Costs Date AUqilst lL. 2000 _ Curtis R. Lonq 'y (k, be~~~" Z' "~.~~ V"' '---0- ....---- ty - REQUESTING PARTY: Name Johnna J. Deily Address: 18 Vally Street Carlisle, Pa 17013 Attorney for: pHfl HarrisSaVinqs Bank Telephone: (717) 24:l-6227. Supreme Court ID No. 53147 TsDE QOPY FROM a~CORO ,,, TlI,~~Y<Wb~~I_,II,,!li~f\lY,1IarId and ~ '.. ,'.. 'i>fsal(f' ........ -at~CiflISle. Thl _~!-1"f 11, '", - ~ IJ(I?N.~. (Wi:-'. AUG 30 " iU 51 ....'-,' .1... PCN;i'J ~1tl~!il'~""'~~~lln,,,~~,,_ ., 1,-1','-'0 iEiliff !~,::4TY ;0 ,J:_ [,'.1, ,"'~;>'jI,'j1!l1IDJ'~JI>?$,"'''''"'''1F'~' - .,.~", I:I-l'~j{qJ:K%;~Q$iit;I'l!!~~"'l'~": ~~ ~ ~--_.....- - ."Ilil" WRIT OF EXECUTION and/or ATTACHMENT ". COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~nn CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland To satisfy the debt, i~terest and costs due COUNTY: Harris Savinqs Bank PLAINTIFF(S) from Adrpll;g M. SOllnprq ;::a/k/;::a anrp..ll:::! F' ~nllnprC:r r;::arl R ~nllrlp.r<:::'r M;,..h~pl M,..Rr;np. ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the detendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s} not levied upon in the possession of GARNISHEE(S) as follows: and to notify the 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 ot the defendant(s) and trom delivering any property ot the detendant(s) or otherwise disposing thereof; (3) If property ot the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlherthat he/she has been added as a garnishee and is enjoined as above stated AmountDue $63,885.42 $12.66 per diem FROM May 11th, Interest thv' naw of Sal@ Atty'sComm $2,900.00 % Atty Paid $151.10 Plaintiff Paid _~----'---___ 2000 LL. .50<:: Due Prothy $1. 00 Other Costs Date: --1'lli91!st 17, 2000 Curtis R_ IDnq Or. (h be~'O::Z_~':"~:~ V"' \...7~ V~_/ ty ~ REQUESTING PARTY: Name Johnna iJ. Deily Address; 18 Vally Street Carlisle, Pa 17013 Attorney for: PHil HarrisSavirlc(s sank Telephone _J.n 7) 243-6? n Supreme Court ID No. 53147 TtqlJE C;.O~.,Ffl9l!1ft~CORO In T"""mOn'Wh ....... lllilreunmiS8t hand, . "~"", .Y.,,,.et~J,', "..co...... ,mv and~.' 'ofsalliCCl "afeiftlSlil. Th day. ..;/, I ~ I !"t'lftl " . ~ '- "''',- ~,~ 'r. <'-~'''"r ,~. [0,:"::'1 J: "",,_ Me jU ; ,'-', , ,'\..,. ;',: DC'J 'c, j L,' i'~;) ".'-'.' l_,...~~ ~1,~/I>'.~JI\'I'1'?~~"'ftl!lWlML i 10 -',.r. ,,,"<""~ ." ..;, -""',,, "'''',~,~, " _.,."c. 'c '.'-- c, . ""'.~"'".""T-'''"''''l '. :- -~';,t~V~F '1 ":11 ,JU ~ ,., '" ':_ -j' <'-1;',,' [,.r~ .1J]_ItIlIIJllf~ili~~'~Hl""-!<" . "-""""".,,," ""'-"""'--"""l'F~~~l\Ii~I3~~.....,," [I lli[Ui!'fn' u~ .-. ~~. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~rm CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, illterest and costs due Harris Savinqs Bank PLAINTIFF(S) from A(lr~llr:l M. ~nllnp,rc::: ;::a/k/~ anrp.ll;::a F ~nllnprc: (';::arl R g()l1nArC:r M;(""h;::ap,l MroRr;r1p ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlherthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $63,885.42 $12.66 per diem FROM May 11th, Interest thrn naw of Sal.. Atty'sComm $2,900.00 % Atty Paid S151.10 Plaintiff Paid 2000 L.L. .50<:: Due Prothy $1. 00 Other Costs Date: Auqust 17, 2000 Curtis R. Lonq Oy c1rn~0"t)O;L ~ REQUESTING PARTY: Name Johnna_ J. Deil y AddreSS; 18 Vally Street Carlisle, Pa 17013 Attorney for; Plffl Harris Savinqs Bank Telephone: (717) 243-6;>22 Supreme Court ID No. 53147 TRUE COPY FROM RECORD In Testimony whereof;rhereunto setmy ~ an, d the trlf said c~ at. ~.~.. . TV~ ?A(ff t~ _ .~ 9rothonotary . ,. -- ~I' ,','" ~ '")" AUG jU !:::I{!FF :;:,::'JTY d '" .,] 1'....~ " I....., L \r' ;',.\ i ,:~ Il, ',1._1._ ,~.- .~~,.."..~ ~ . ~~.l~'M"lm;,;~'~J;~~W~ 'i.~:l ,_\,;l" ",:" ~, j.'; '. '---- I?,!;.' "'~'I-"'- ~ '., 1"",~~"*,,,-j"~F""--"!';";--,q"Cr~""'" -T,->"}";,,,,'*l!"1''',,,"$'1''PiR'!ii~~~~jmll~I'T'' "'11' '.'nll! ..,,.,.,_!- ~-' ~u" ' WRIT OF EXECUTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00- 3186 CIVIL ~~DTl CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt. u,terest and costs due Harris Savinqs Bank PLAINTIFF(S) from AdrF.:llrJ M. S()llnpr~ A/k/r1 anrpll.'=l l<' ROl1nprc:, r;::arl Po Q()11ilArC:r M;(""n;::ap,l M(""Rr;np ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows and to notify the garnishee(s) that: (al an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or tor the account of the defendant(s) and from delivering any property of the detendant(s) or otherwise disposing thereof. (3) If property of the defendant(s) notlevied upon an subjectto attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify himlherthat helshe has been added as a garnishee and is enjoined as above stated. 2000 L.L. . 50~ Oue Prothy $1.00 Other Costs AmountOue $63,885.42 $12.66 per diem fROM May 11th, Interest thrn naw of '3a.lG' Atty'sComm $2,900.00 % Atty Paid $151.10 n ____n Plaintiff Paid___~~__________ Oat e: _--1iuCI>L,,-t__~7-,---~.Q.QCL___________.__ Curtis R_ Lonq - "' am ~~~~J(4')O;L fk.~. (/ ep y REQUESTING PARTY: Name Johnna_ J. Deny Address: 18 Vally Street Carlisle, Pa 17013 Attorney for: PHfl Harris Savinqs Bank Telephone _ULu 241-67n________________ Supreme Court 10 No. 53147 _______________ TRue CQPVFROM REOORD In Testl~l1y,w'*8\Jfjfher:o,:O~ _-my hanc1 ~~d theJ,.~ta.y idp~ .. at, r.~. L <...../i '/./ ),;/Jd1 - Prothonotary :. - ~" ~. '- , WRIT OF EXECUTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00- 3186 CIVIL 1&~rm CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY To satisfy the debt. i"terest and costs due Harris Savings Bank PLAINTIFF(S) from Ann=: 11 A M. S()llnpr~ ;::a /k /?1 Anrp..ll ~ F ~ol'nArC:r (';::arl R ~(")llr1p.rc: Mi (""n.:::'lP 1 M(""Rri np ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows and to nofify 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 accounl of the defendanf(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject fo attachment is found inthe po~session of anyone other fhan a named garnishee, you are directed to notify him/herthat helshe has been added as a garnishee and is enjoined as above stated. Amount Due3Q3,885.42 $12.66 per diem FROM May Interest tnt''' f)~te of S"l@ Atty's Comm $2,900.00 % Atty Paid ~.-ln_____ Plaintiff Paid 11th, 2000 LL .50(; Due Prothy $1.00 Other Costs Date __Auqu'i.t_.1JL 2000 ______n._____u_____ c:urtis R. IDnq " C1n}/fJ"2;;rISL ~h v ~ REQUESTiNG PARTY Name Johnna S. Deily Address: 18 Vally Street Carlisle, Pa 17013 Attorney for: pHfl Harris Savinqs Bank Telephone _J.112L-241-6);>7. ____ ___ .______.. Supreme Court ID No. 53147__ __ ______________ TRU~OOPY' :~-ROM RECORD In Testlii1!J~W~~f;bei:8iJll!q $t(my hal10 a~z!. :;...'... sa. III '-- . at'l')"tllSle "_' .~JlJ , :~. ~" , Th . . day I L/ II 'l ,~-,- """""~' . ~-- ~.. , i , IiUG JU p""" 1-i.; id I'..; r :~H".i!IFF "):.f;,ITY .'1 ,;u L ;' ',:i ,I,q ,-~"~ '""'"~< o.,'J "_". ' ,>,,-,',," ",'': =,_ "'"'' ~li~~~'~:'!lIIII:, ~r~"~,,"'1"",!,IJ,~r ,."_,,,'~TIf~AW'''''''''];H'[1f'iF,'.'''''~'i'--n>'--'''''''I~~~~~n..,~ '''Hi ....,.,..~~ ~~ '. . WRIT OF EXECUTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL 1&~nn CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt.. iQ.terest and costs due Harris Savings Bank PLAINTIFF(S) from Aon~llA M. SOl1npr!'=: r1/k/;::a Ailrp.1L~ F' ~nl1i1prC:r (';::arl F. ~nl1nArc: M;(""hrl,ol M,..Rriilp. ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) thai: (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 Irom delivering any property of the detendant(s) or otherwise disposing thereof: (3) 11 property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as a garnishee and is enjoined as above stated. Amount Due~885.42 __._______ $12.66 per diem FROM May 11th, 2000 Interest thp' 1'\~w of 5,,1@ Atty'sComm $2,900.00 % Atty Paid $15LUl.,____ L.L. .50c Due Prothy $1.00 Other Costs Plalntlft Paid Date .l\~g:2.",Ll 7, 200()._ Curtis R. IDnq a Prothonotary, Civil Division by _ ) rnLf/LcJlJ;~ ~~~ REQUESTING PARTY Name Johnna. J. Deily_ Address: 18 vally Street Carlisle, Pa 17013 Attorney for' plfff Harris Savinqs Bank Telephone _.Clul...243-67?? .._.____'__u_. . Supreme Court ID No. 53147_____.~____ ~~ ;-1'_ -,. "~ " G ~''- AUG 3u PL.C ,Ii !,'i III 50 ! <i '- , " :; ",,\ ,"""""".,",,, ,.,.",fc~~~~'.n'ffl~j_W~'I'lIl'~!l!t~ir~~.,,~ "'" ~ ! r: r: 'r "~'r~ ^ .1f;~iI!~~'"~~'''o''''---,''''''!I'''~''' -""'T'('l,'::"!j'Pf;'~>\"I!,!i!i'~~N~~_""""I'1I! ,..1RIIl!lI~ ~- WRIT OF EXECUTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~nn CIVIL ACTION - LAW TO THE SHERIFF OF Cumber] and COUNTY: To satisfy the deb!.. i"teresl and costs due Harris Savings Bank PLAINTIFF(S) from Ann;:~11Fl M. S()nnp7'~ ;::a/k/;::a Ann:>ll;::a F ~()l1nP.rc.::r r;::arl Po qnnnprc: M;(""h;::apl M(""Rr;np. ;:mn Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof: (3) If property of the defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee. you <lre directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $63,885.42 $12.66 per diem FROM May Interest thr" flaw of Sal@ Atty'sComm $2,900.00 % Atty Paid $151.10 _~_ 11th, 2000 L.L ~__~___ Due Prothy $1. 00 Other Costs Plaintiff Paid _______._~_______ Date __Au<r4..'~t.lZ1 2001L_____d c:urtis R. Lonq "' ~}~~J~"lJ'L ~~ REQUESTII~G PARTY Name Johnna J. Peily_ Address: 18 VallyStreet Carlisle, Pa 17013 Attorney for: PHf! Harris Savinqs Telephone: -.--UlIL24J.=62?7 Suprerne Court 10 No 53147 Bank T8UEOOpy:FROM RECORD In Testlilip~Y..Wh6!~~~;lJ~~iny hano ~l~~~r'~_ ~ Prothonotary " ~I Ii AUG Pt!'. ~;i .JU !i Ii} 50 ~- ~ -,- ~ , "'~jFF :-y ':1 l;-~ :.:.: '". , .i , , I ,~"- ",,", "]"W ~~ 'l8I! ._~_,~,!\\ftJ~""""o~_....~~~I$11iffli!i!"'~ ...~~f~~',"+,""'''f'i''','''~';'',-''., .,'-~j":TF4"j;w,1lJ'9tIIA~I~"I~'~" i', '-', I J L. "== ",~~^h "C' - WRIT OF EXECUTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~nn CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt.. i,.terest and costs due Harris Savings Bank PLAINTIFF(S) from Anr0-11Fl M. Snnnpr!=:. ;::a/k/rl Anrp.ll;::a F' ~(,)l1nprc:. (';::arl R ~nllnArc:. M;(""n;::ap,l MroRr-;np ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notrty 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 detendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereot: (3) It property of thedefendant(s) not levied upon an subject to attachment is found in the possession of anyone other thana named garnishee, you are directed to nolify himlherthat he/she has been added as agarnishee and is enjoined as above stated. Amount Due $63,885.42 $12.66 per diem FROM May 11th, Interest tWI l}ate of S...l@ Atty'sComm $2,900.00 % Atty Paid 251.lO---__ Plaintiff Paid 2000 L.L .50<:: Due Prothy $1.00 Other Costs Date. Aqg:Clst__l~OOO______~_______ Curtis J.L Lonq ", ~~:':fG~ ~~ U e y REQUESTING PARTY: Name Johnna_ J. Deily Address; 18 Vally Street Carlisle, Pa 17013 Attorney for: pHf! Harris Savinqs Bank Telephone: .J.1.12L.24:J-677L________ Supreme Court 10 No. 53147 _____________ II 1" r,lI,~" illJG' .Ju pc. .~~_~~'I!'~~"B iJ " '-';:iUF;: .' ,.:-iTy ...J<.., 1 c.,J i '(i l J ",,!,'~n_ ' ~!l!!lIlJ~"''''I)'..''~'-'''';::''Tf'W'''''; i. "",f-,~,.,,-,~,,'qjjl~;_;!J1;~liI1!'I'i[llIir;","''''''''''r~~'!'''''''' .-....MIIl - -< - ~. WRIT OF EXECUTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3186 CIVIL ~rm CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt.. iQ.terest and costs due Harris Savinqs Bank PLAINTIFF(S) from Adre11r:i M. S()11r1pri=:. r1/k/;::a Anrp..ll;::a F' ~()l1npr!=:.r (';::arl R ~nl1nArC:r Mi,..h~Al M(""Rr;n;;:.. ;::ann Marietta B. Fickel; 18 Valley Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed 10 attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and trom delivering any property of the defendant(s) or otherwise disposing thereof: (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlherthat helshe has been added as a garnishee and is enjoined as above stated. AmountDue $63,885.42 $12.66 per diem FROM May 11th, Interest ...thJ;u naw of Sal€l Atty's Comm $2,900.00 % Atty Paid ~LU___ 2000 LL. .50<:: Due Prothy $1.00 Other Costs Plaintiff Paid Date: Au(mo'iL1L--1000 _______ Curtis R. Lonq 0' Urn~~'0"G;L ~~j, REOUESTiNG PARTY Name Johnna J. Den y Address: 18 Vally Street Carlisle, Pa 17013 Attorney for: plffl Harris Savinqs Bank Telephone: ~717J_243-6/.n _________ Supreme Court 10 No 53147 ________ TRUIH~OPYt=RQM ij(tOORD In Testlii\on~Wh8rfOfr.theit1In{O ~iny hali() ~U;""~tZ'.~ . ~rotfionotary , ., - ~ ~ ~~~, ~ ~..~ Ci ~. (::- , ("., H:.:;; PC;,':' i, :~" , Ii I " I I , i , !I I, il " II II ;'''ll , ~ I,) ~D - .~-~ ',~ .~.~ IfF"F , ,y '!} " !, ~ ~ ~""""""" -q1f"I~l\-~~j~~ ,~."~ '. "~,. ,ll!'i~~"""~"'I.""-<Tf"'-'''"''" "'~T"""'.",__~,,~~,!~~nii!!~ "">"" ,~ ,~ . JAMES D, FLOWER JOHNE. SLIKE ROBERT C. SAlOIS GEOFFREY S, SHUFF JAMES D, FLOWER, JR. CAROLJ, LINDSAY JOHNNAJ, DEILY KARL M, LEDEBOHM JOSEPH L. lllTCHlNGS THOMAS E, FLOWER LAW OFFICES SAIDIS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attomey@ssfl-Iaw.com OF COUNSEL ALBERT H. MASLAND WEST SHORE OFFICE: 2109 MARKET STREET CAMP HILL, P A 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE August 16,2000 Prothonotary of Cumberland County Cumberland County Courthouse One Court House Square Carlisle PA 17013 IN RE: Harris Savings Bank v, Souders, et al Docket No,: 00-3186 Civil Dear Sir or Madam: Enclosed please find the following documents for filing of Writ of Execution in Mortgage Foreclosure on the above-captioned matter: 1, Praecipe for Writ of Execution; 2, Affid@vit Pursuant to Rule 3129,1; 3, Notice to Lien Holder Pursuant to PA. R. C, P. 3129; 4, Notice of Sheriff's Sale of Real Estate Pursuant to PA Rule of C. p, 3129,2; 5, A copy of the Legal Description; and our checks made payable to the Prothonotary in the amount of $15,00 to cover the filing fee and our check in the amount of $1,000,00 made payable to the Sheriff of Cumberland County to execute the Writ of Execution on the above matter. Please date /time stamp the extra copy included and return it to me, Please forward the necessary documents along with our check to the Sheriff so he may serve the Writ of Execution on the defendants at 18 Valley Street, Carlisle, PA 17013 as well as Post the Property with a copy of the Writ of Execution, Notice of Sheriff Sale of Real Estate and the Sheriff's Handbill. Thank you for your help and cooperation in this matter. Very truly yours, JJD/ler Enclosures Cc: Loan No,; 1751007388 Stacy L. Armstrong Harris Savings Bank ATTN: Default Management 449 Eisenhower Boulevard Harrisburg PA 17105-1711 .~ SAlOIS, HUFF & MASLAND A1TflR~AT.LAW 26 W, Hlgb Stretlt Carll.le, PA ~ HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA o (::: C Co::; 7 ~ IJ';T'; rnl", \ <:.i1 Z:J:' ~ ?:J'~ ~-l ~,C"J :,e-;" j;; z.--' 60 __~ MORTGAGE FORECLOSURE y c: --:: ~ .~ Plaintiff v, ARDELLA M.. SOUDERS, a1kJa ARDELLA F. SOUDERS, CARL E, SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B. NO. 00-3186 Civil CIVIL ACTION - LAW Defendant< s) AFFIDAVIT PURSUANT TO RULE 3129.1 ~~~, 1iIliiIl~ >liillliiW;Otlillli$>-' , :=i~ " "I ~.':.,;, ~:1~') ~l"" -i~ 'cc.;CJ (~)r'n ., :Jc. ~ Harris Savings Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of execution was filed the following information concerning the real property consisting of one tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013. 1, Name and address of owners or reputed owners: Carl E. Souders and Adrella F, Souders, alkJa Adrella M. Souders 18 Valley Street Carlisle, PA 17013 2, Name and address of defendants in the judgment: Ardella M, Souders, a/kJa Ardella F, Souders, Carl E, Souders McBride, Michael!. and Fickel, Marietta B. 18 Valley Street, Carlisle, PA 17013 3, Name and address of every judgment creditor (other than the Plaintiff herein) whose judgment is a record lien on the real property to be sold: Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 4. Name and address of the last recorded holder (other than the Plaintiff herein) of every mortgage of record: Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 1 -.. SAlOIS, HUFF & MASLAND A~VS-AT'LAW 26 W, High Street Carll,le, PA - . - '~__~~kL' 5, Name and address of every other person who has any record lien on the property: 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: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None, . I, Johnna J. Deily, Esquire, attorney for the Plaintiff, Harris Savings Bank, verify that the statements made in this affidavit are true and correct to the best of my personal knowledge; information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. section 4904 relating to unsworn falsification to authorities. SAlOIS, SHUFF, FLOWER & LINDSAY Dated: 6'. is' 00 By' Jo S reme Court 10 #53147 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorneys for Plaintiff 2 ~. .~. SAID IS, SHUFF & MASLAND ATrORNEYS'A,..1.AW 26 W, High Street CarUsle. PA ,I~ ~~,,~ HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff v. NO, 00-3186 Civil ARDELLA M.. SOUDERS, CIVIL ACTION - LAW a1k1a ARDELLA F, SOUDERS, CARL E, SOUDERS MCBRIDE, MICHAEL L, and FICKEL, MARIETTA B. Defendant(s) MORTGAGE FORECLOSURE NOTICE TO LIEN HOLDERS PURSUANT TO PA. R.C.P. 3129 NOTICE IS HEREBY GIVEN TO the following parties who hold one or more mortgages, judgment or tax liens against the real estate of Carl E. Souders and Ardella F. Souders,hlw. Ardella Moo Souders, a/kfa Ardella F. Souders 18 Valley Street Carlisle, PA 17013 Carl E. Souders 18 Valley Street Carlisle, PA 17013 Michael L. Mc Bride 18 Valley Street Carlisle, PA 17013 Marietta B. Fickel 18 Valley Street Carlisle, PA 17013 Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 You are hereby notified that on December 06, 2000, at 10:00 a ,m, prevailing time, by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, on the judgment of Harris Savings Bank v. Ardella M, Souders, 1 _....-,.~ ~ "~~ -6 SAlOIS, HUFF & MASLAND ATrOR~AT'LAW 26W,I1lghStrftt Carlisle, PA . . ~,; . a/kJa Ardella F, Souders, Carl E, Souders, Michael L. Mc Bride, Marietta B. Fickel, No.OO- 3186 Civil in the amount of $63,885.42 plus interest from May 11, 2000 $12,66 per diem, costs, attorneys' fees and for foreclosure of the rnortgaged premises, the Sheriff of Cumberland County, Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, Commonwealth of Pennsylvania, real estate of Carl E Souders and Adrella F, Souders, a/kJa Adrella M. Souders, known as that tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013, A description of said real estate is attached hereto, You are further notified that a Schedule of Proposed Distribution will be filed by the. Sheriff of Cumberland County within thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless exceptions are filed thereto within ten (10) days thereafter. You are further notified that the lien you hold against said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriff Sale. Dated: 8. is'. DU By: Joh SAI IS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorney for Plaintiff Attorney I.D, 53147 2 ~""""""",. SAlOIS, HUFF & MASLAND ATIURNF.1S.A"'LAW 26 W, HIgh Street Carll,le, PA -~~.-.I , ~~ " , , .~.'.'-'-- ._, ...........,.~t,' HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO, 00-3186 Civil ARDELLA M., SOUDERS, CIVIL ACTION - LAW a1kJa ARDELLA F, SOUDERS, CARL E, SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B, Defendant(s) MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: December 06, 2000 TIME: 10:00 A. M, Prevailing time LOCATION: Cumberland County Courthouse 1 Courthouse Square Carlisle PA 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: all that certain improved tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley street, Carlisle, PA 17013. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to Harris Savings Bank v. Adrella M. Souders, a/kla Adrella F, Souders, Carl E, Souders, Michael McBride and Marietta B, Fickel, No. 00-3186 Civil for $63,885.42, plus interest from May 11, 2000 at $12.66 per diem, costs, attorneys' fees and for foreclosure of the mortgaged premises until the Sheriff Sale, 1 '''.'''.:.,,-._, I... ~~ ~.,'^'~ >.. SAID IS, OIHUFF & MASLAND A'ITORNEYS'A,..LAW Z6 W, High Street Carlisle. PA ~t."" r THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property are: Carl E. Souders and Adrella F, Souders, h/w A SCHEDULE DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entjtled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact. be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed, . Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address speCified herein, THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A' lawyer can adlfise you more speCifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN . GET FREE LEGAL ADVICE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717.249 -3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County , to open the judgment if you have a meritorious defense against the person or company . that has entered judgment against you. You may also file a petition with the same Court ' if you are aware of a legal defect in the obligation or the procedure used against you. 2 ~~ SAIDIS, HUFF & MASLAND A~ATaLAW 26 W, Utgh Street earllsle, PA ,~" . --_.".._---~-- !lW'I~ 2, After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause, This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3, A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County, The petition must be selVed on the attomey for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the. petition, If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation to the Court, A copy of the Writ of Execution is attached hereto, SAIDIS, SHUFF, FLOWER & LINDSAY Dated: 8 - f5:v uu By: J na J. i1y, squire S preme Court 10#53147 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorneys for Plaintiff 3 """'~""~- --~ ~' -" """;,i-I',^ -jl!i;;:..i LEGAL DESCRIPTION ALL those certain two lots of ground situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEING Lots No. 19 and 20, block "L", of that certain Plan of Lots known as Carlisle Manor Extension, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page 99, Said Lots having a frontage on Valley Street of 100 feet and extending in depth 150 feet to line of Lot No. 16, Block "L", in the rear. It being the same two lots of ground which Pierson K. Miller and Margaret S. Miller, his wife, by deed dated April?, 1954 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book "R", Vol. 15, Page 355, granted and conveyed to Adrella M. Fickel, now intermarried with Carl E. Souders, one of the Grantors herein. BEING SOLD AS THE PROPERTY OF CARL E. SOUDERS AND AD RELLA F. SOUDERS a/k/a ARDELLA M. SOUDERS i'~ ~~ SAIDIS, HUFF & MASLAND A'M'ORNIMl'AT'LAW 26 W, Hlsh Street Carlisle, PA . ~l ~~, .._~ '~~'" . HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff v, NO, 00-3186 Civil ARDELLA M.. SOUDERS. CIVIL ACTION - LAW aikJa ARDELLA F. SOUDERS, CARL E, SOUDERS MCBRIDE. MICHAEL L. and FICKEL, MARIETTA B, 0 Q ~:; c- o ,1 s: "'" -~.-, -r,lrD ,--- m n- , G') =.~!~ ~ ~;J . , ;=~ ~ --, (f) ,':..,- .--.J -( ",:: C) !;::C:' ~o J::;:'>> "r"-", :ij ~::: -"0 -,,- :l>c ~ ;-';;;;-,rn; ~, Z '''-' :~ -' ::0 -< (::::l ~' ~ Defendant(s) MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Harris'Savings Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of execution was filed the following information concerning the real property consisting of one tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013, 1, Name and address of owners or reputed owners: Carl E. Souders and Adrella F, Souders, a/kJa Adrella M. Souders 18 Valley Street Carlisle, PA 17013 2. Name and address of defendants in the judgment: Ardella M. Souders, a/kJa Ardella F, Souders, Carl E. Souders McBride, Michael!. and Fickel, Marietta B. 18 Valley Street, Carlisle, PA 17013 3. Name and address of every judgment creditor(other than the Plaintiff herein) whose judgment is a record lien on the real property to be sold: Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 4, Name and address of the last recorded holder (other than the Plaintiff herejn) of every mortgage of record: Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 1 - SAIDIS. HUFF & MASLAND A'ITORJIIEYS.AT.LAW 26 W, High Street Carllsie, PA "~ , ~~' ~. 5. Name and address of every other person who has any record lien on the property: 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: None 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None, .1, Johnna J. Deily, Esquire, attorney for the Plaintiff, Harris Savings Bank, verify that the statements made in this affidavit are true and correct to the best of my personal knowledge; information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S, section 4904 relating to unsworn falsification to authorities. SAlOIS, SHUFF, FLOWER & LINDSAY Dated: 8' fS ,00 By' Jo S reme Court 10 #53147 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorneys for Plaintiff 2 "," ~~ SAlOIS, HUFF & MASLAND ATfORNBf5-ATlLAW 26 W, High Street Carll_Ie. PA ~_... ~. ~ , '~, ..,. w_ lIIlIi_j<l~_,,1 ~~~-'.- ---~_._---,-<~,_. HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff v, NO, 00-3186 Civil ARDELLA M.. SOUDERS. CIVIL ACTION - LAW aikla ARDELLA F, SOUDERS. CARL E, SOUDERS MCBRIDE. MICHAEL L. and FICKEL. MARIETTA B, Defendant(s) MORTGAGE FORECLOSURE NOTICE TO LIEN HOLDERS PURSUANT TO PA. R.C.P. 3129 NOTICE IS HEREBY GIVEN TO the following parties who hold one or more mortgages. judgment or tax liens against the real estate of Carl E. Souders and Ardella F. Souders,h/w. Ardella M.. Souders, a/kJa Ardella F. Souders 18 Valley Street Carlisle, PA 17013 Carl E. Souders 18 Valley Street Carlisle, PA 17013 Michael L. Mc Bride 18 Valley Street Carlisle. PA 17013 Marietta B, Fickel 18 Valley Street Carlisle, PA 17013 Harris Savings Bank 449 Eisenhower Boulevard Harrisburg PA 17105-1711 Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 You are hereby notified that on December 06, 2000, at 10:00 a ,m. prevailing time. by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania. on the judgment of Harris Savings Bank v. Ardella M. Souders, 1 '" ~ SAIDIS, HUFF & MASLAND ATIYUtNBYS.AT-LAW 26 W, High Street C,1rlisle,PA " ~~'(iI:l.illlI;li~;$!J;; , . ~ ,. a/k/a Ardella F, Souders, Carl E. Souders, Michael L. Mc Bride, Marietta B. Fickel, No,QQ- 3186 Civil in the amount of $63,885,42 plus interest from May 11, 2000 $12.66 per diem, costs, attorneys' fees and for foreclosure of the mortgaged premises, the Sheriff of Cumberland County, Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, Commonwealth of Pennsylvania, real estate of Carl E Souders and Adrella F. Souders, a/k/a Adrella M. Souders, known as that tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley Street, Carlisle, PA 17013. A description of said real estate is attached hereto, You are further notified that a Schedule of Proposed Distribution will be filed by the, Sheriff of Cumberland County within thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless exceptions are filed thereto within ten (10) days thereafter, You are further notified that the lien you hold against said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of sajd Sheriff Sale, Dated: 8. is' ,ou By: Joh SAI IS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorney for Plaintiff Attorney I.D, 53147 2 . ~~ -- .., "..----,.- SAID IS, HUFF & MASLAND ATmRNEYS.AT.LA.W 26 W. 81gb Street Carlisle, PA "" L._~~ - ~,~, HARRIS SAVINGS BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO, 00-3186 Civil ARDELLA M.. SOUDERS, CIVIL ACTION - LAW . aIkIa ARDELLA F, SOUDERS, CARL E, SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B, Defendant(s) MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2 . TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: TIME: December 06, 2000 10:00 A. M. Prevailing time LOCATION: Cumberland County Courthouse 1 Courthouse Square Carlisle PA 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land, (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: all that certain improved tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 18 Valley street, Carlisle, PA 17013. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to Harris Savings Bank v. Adrella M. Souders, a1kfa Adrella F, Souders, Carl E. Souders, Michael McBride and Marietta 8. Fickel, No, 00-3186 Civil for $63,885.42, plus interest from May 11, 2000 at $12.66 per diem, costs, attorneys' fees and for foreclosure of the mortgaged premises until the Sheriff Sale. 1 , "~ " SAlOIS, i:)HUFF & MASLAND ATrORNRfS.ATtLAW 26 W, High Stroel Carli,le, PA ....' ~ "-~~i' THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property are: Carl E. Souders and Adrella F, Souders, h/w A SCHEDULE DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of thjs County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (1 0) days of the date it is filed. . Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein, THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away, A lawyer can advise you more specifically of these rights. If you wish to exercise your . rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717.249 - 3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1, You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2 ""- SAIDIS, HUFF & MASLAND "T1YlItNEYStIAT.LAW 26 W, High Street carlisle, PA ~ - ~~~'" 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3, A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the. petition, If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation to the Court. A copy of the Writ of Execution is attached hereto, SAlOIS, SHUFF, FLOWER & LINDSAY Dated: $ - {S'~ 'Ou By: J na J, i1y, squire S preme Court ID#53147 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Attorneys for Plaintiff 3 ~.,~ ~~ -.Mi"", LEGAL DESCRIPTION ALL those certain two lots of ground situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEING Lots No, 19 and 20, block "L", of that certain Plan of Lots known as Carlisle Manor Extension, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page 99. Said Lots having a frontage on Valley Street of 100 feet and extending in depth 150 feet to line of Lot No, 16, Block "L", in the rear. It being the same two lots of ground which Pierson K, Miller and Margaret S. Miller, his wife, by deed dated April 7, 1954 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book "R", Vol. 15, Page 355, granted and conveyed to Adrella M. Fickel, now intermarried with Carl E. Souders, one of the Grantors herein. BEING SOLD AS THE PROPERTY OF CARL E. SOUDERS AND ADRELLA F. SOUDERS alkla ARDELLA M. SOUDERS SAIDlS S~~WER &.~uSAY ATIOIlNI!\'SoAT-1AW Uw.mghStreet Carlisle, PA HARRIS SAVINGS BANK Plaintiff v. ARDELLA M.. SOUDERS, a/k1a ARDELLA F, SOUDERS, CARL E. SOUDERS MCBRIDE, MICHAEL L. and FICKEL, MARIETTA B, Defendant(s) , "".' .-";' "',;'->"^,L--_, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 00c3186 Civil CIVIL ACTION - LAW MORTGAGE FORECLOSURE PRAECIPF TO SATISFY AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned case Satisfied and Discontinued. Dated: December 7,2000 II Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY By: Jo I 53147 26 W, High Street Carlisle, PA 17013 (717) 243-6222 Attorney for the Plaintiff It; "".",,-'" '~ '. '"' - ,.,,' ,~.. ,,0 '-"""'~""""'"'' 'J ~,' -;.., ., I' ~ II ~ 0 c::> ~ ~ <:::> c::1 -OC~ ,-., " lTIr<' n p z.......', -"'J - ,,:~0 ZC~ -~::jC7 Cf.!<' - , ;~ L -(;..:~ (j ! ' r.;:.G -oi ~~ ~ ;;>0 ::J;: ~b - ;t>c ..; -~ ~' ..- ~ (1'\. "< I.