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Home My WebLink About00-03742 ~~~~ -: . , FEDERMAN AND PHELAN By: Dave Hobson, Esquire Atty. I.D. No. 76060 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 INDYMAC MORTGAGE HOLDINGS, INC. 15050 AVENUE OF SCIENCE, SUITE 101 SAN DIEGO, CA 92138 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Plaintiff NO. CO - .J74^,-- Cu JT~ vs. DAVID W. SNOW ROXANN SNOW AND/OR OCCUPANTS 29 VICTOR DRIVE MECHANICSBURG, PA 17055-2914 Defendants CIVIL ACTION/COMPLAINT RETAIL INSTALLMENT CONTRACT AND SECURITY AGREEMENT FOR MOBILE HOME YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or 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 PA 17013 (717) 249 3166 or 1 800 990 9108 DEBT Al\JU Al\lI 1.1\l.l?V!'..L"'1.M..L..1..Vl'l "-"..u..L.....>....L..>.~.............. WILL BE USED FOR THAT PURPOSE " TRU OPY FROM In Tastlillonyw . and ttle of AVISO '-'" Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, demanda y la notificacion. Hace fal ta asentar una comparencia escri ta 0 en persona 0 con un abogado y entregar a la corte en forme escrita sus defensas 0 sus objeciones alas demanandas on contra de su persona. Sea avisado que si usted no se dafienda, la corte tomara medidas y puede continuer la domanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandanto y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perdar dinero 0 sus propiedadas u 0 tros derachos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO 1NMED1ATAMENTE, S1 ABOGADO 0 S1 NO T1ENE EL DINERO SUFICIENTE DE PAGAR TAL VAY A EN PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA CONSEGUIR ASISTENCIA LEGAL. COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)240-6200 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NO T1ENE SERVICIO, DIRECCION l'4i 'FEDERMAN AND PHELAN By,' Dave Hobson, Esquire Atty. I.D. No. 76060 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF INDYMAC MORTGAGE HOLDINGS, INC. 15050 AVENUE OF SCIENCE, SUITE 101 SAN DIEGO, CA 92138 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Plaintiff vs. NO. DAVID W. SNOW ROXANN SNOW AND/OR OCCUPANTS 29 VICTOR DRIVE MECHANICSBURG, PA 17055-2914 Defendants CIVIL ACTION/COMPLAINT RETAIL INSTALLMENT CONTRACT AND SECURITY AGREEMENT FOR MOBILE HOME COUNT I: ASSUMPSIT 1. Plaintiff is INDYMAC MORTGAGE HOLDINGS, INC. 15050 AVENUE OF SCIENCE, SUITE 101 SAN DIEGO, CA 92138 who is the Seller and Owner of the property, one used 1983 70' X 14' Nashua Mobile Home, Serial #NZOHCNX3700143Tl12416, Title #35268328103-HA, Vehicle Identification #NZOHCNX370143T112416, which is located at 29 Victor Drive, Mechanicsburg, Pennsylvania 17055-2914. 2. The name and last known address of Defendants are DAVID W. SNOW ROXANN SNOW AND/OR OCCUPANTS 29 VICTOR DRIVE MECHANICSBURG, PA 17055-2914 who are the Buyers or Occupants of the mobile home as described in ,;._. .~, --, '-" f~; 'paragraph 1 above. , 3. On or about December 16, 1998, Plaintiff's predecessor in interest, Independent National Mortgage Corporation, and Defendants entered into a Retail Installment Contract and Security Agreement for Sale of a Mobile Home at 135 Castle Drive, Mechanicsburg, PA 17055. A true and correct copy of said contract is attached hereto, incorporated herein by reference, and marked as Exhibit "An. Said Installment Contract has since been assigned to Plaintiff. 4. Defendant is in default under the Installment Contract because monthly payments under the contract due September 14, 1999 and each month thereafter are due and unpaid, and by the terms of said contract, upon failure of Defendant Buyers to make such payments after a date specified by written notice sent to Buyer, the entire principal balance and all interest due thereon are collectible forthwith. A copy of said notice is attached hereto, incorporated herein by reference, and marked as Exhibit "Bn. 5. The aforesaid contract also provides for the addition of a reasonable attorney's fee upon default by Defendant(s). It is averred that five (5%) percent of the unpaid principal balance is a reasonable attorney's fee. 6. The following amounts are due on the Installment Contract: Principal Balance $15,507.78 Interest from 08-14-99 to 05-01-00 At $5.09 per Diem Late Charges/NSF fees Credits 1,323.40 Total Indebtedness 15.00 0.00 $16,846.18 8. Notice of Default and Right to Cure Default was sent to -" ""'&-1 'Defendant(s) by certified mail on the date set forth in the true . . and correct copy of such notice attached hereto as Exhibit "B". WHEREFORE, Plaintiff demands judgment against Defendant for the total amount due, plus interest at the rate of $5.09 per diem from May 1, 2000, plus costs and charges collectible under the Installment Contract. COURT II: REPLEVIN 10. The paragraphs in Court I are incorporated herein by reference as if set forth herein at length. 11. Plaintiff is entitled to possession of the mobile home. 12. Plaintiff is the perfected, secured lien holder of the subject mobile home. 13. Plaintiff has demanded return of mobile home, but Defendants have refused to return the same to Plaintiff. 14. It is believed and therefore averred that the mobile home is uninsured, due to Defendants' default. 15. It is asserted the Plaintiff will be greatly prejudiced if the mobile home is not given into its possession. WHEREFORE, Plaintiff demands judgment for immediate possession of property and issuance of an Order for possession of the mobile home. FEDERMAN AND PHELAN Date: >0 By: ~~____ . David obson, Esq. Attorney for Plaintiff . " , j , ?ENNSYL VANIA ,A''''''' RETAIL INSTALLMENT CONTRACT AND SECURITY AGREEMEr:n BUYER(S): DAVID W SNOW AND ROXANN SNOW FUll ADDRESS: 135 CASTLE DRIVE MECHA~ICSBURG PA 17055 lOCATION OF MANUFACTURED HOME: 29 VlCTORDRIVE MECHANICSBURG PA 17055 (TWIGGS MOBilE HOME PARK) "I," "me" or 'us. means the buyers listed above. and "you. or "your" means the seller and any assignee. On the date of this contract, I buy from you on a credit sales basis the manufactured home described below, together with furnishings, equipment, appliances and accessories included in the manufactured home at the time of purchase (called "Manufactured Home;. Description of TRADE NAME: NASHUA MODEL: NASHUA Manufactured YEAR:1983 NEW: 0 USED: 181 lENGTH: 70 ft. WIDTH: 14ft. Home: SERIAL NUMBERS NZOHCNX3700143T112416 ITEM SERIAL # ITEM SERIAL # ADDITIONAL ACCESSORIES AND FURNISHINGS: PROMISE TO PAY: I promise to pay you the Unpaid Balance shown on the next page (Item 5) with interest at the rate of: 12.00'10 per year until the debt is fully paid. I'll pay this amount in installments as shown in the payment schedule. Each monthly payment will be applied as of its scheduled due date. If no interest rate is disclosed above. the interest rate is the Annual Percentage Rate shown below. ANNUAL FINANCE CHARGE 'Amount Financed Total of Payments Total Sale Price PERCENTAGE RATE The lotal cost of my purchase on credit The cost of my credit as The dollar amount the The amount of credit The amount I will have including my down a yearly rate: 'Credit will cost me: iprovided to me or on paid after I have made all payment of my beha/l: payments as scheduled: $ 1,000.00 12.00'10 $ 1 1l,258.00 $ 15,735.00 $ 33,993.00 $ 34,993.00 See contract terms on the following pages for additional information about nonpayment. default, required repayment in full before the scheduled date and prepayment refunds and penalties. Number of Amount of When Payments are Due Payments Payment My 180 $ 188.85 Monthly, beginning payment $ Monthly, beginning schedule Monthly, beginning will be: Monthly. beginning Prepayment: If I payoff early, I will not have to pay a penalty, but I will not be entitled to a refund of the Prepaid Finance Charge, if any. Security : I give you a security interest in the goods or property being purchased, and if checked: 0 real property located at: Late Charge: If a payment is more than 15 days late, I will be charged 2% of the unpaid amount of such payment. not to exceed $5.00~ Assumption: Someone buying my Manufactured Home may. under certain circumstances, be allowed to assume the remainder of the contract on the original terms. Retail Installment Contract and Security Agreement - Page 1 of 4 DL-539PA (4/97) ~ "" '""'~"~"I ~~ ~ ... lW. ....~ INSURANCE PROPERTY INSURANCE: Property Insurance on the Manufactured Home is required for the tenn of this contract. I have the right to choose the person through whom it is obtained. By marking the appropriate line below, I elect to buy the coverage indicated from you for the term and premium shown: Tvoe of Insurance o Broad Form Compo o Mobile Home Owners Tenn Premium Mos $ N1A Mos $ N1A LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS IS NOT INCLUDED UNLESS MOBILE HOME OWNERS INSURANCE IS INDICATED IN THE PROPERTY INSURANCE SECTION ABOVE. CREDIT LIFE INSURANCE: Credit Ufe Insurance is not required for this contract or a factor in its approval. If I elect Credit Life Insurance, the name(s) of the proposed insured(s) are: Proposed Insured: N1A Proposed Insured: N/A (Only spouse can be insured jointly.) This insurance may not payoff all of my debt, and the exact amount of coverage is shown on my policy or certificate. My signature indicates my election to obtain Credit Life Insurance coverage for the term and premium shown: Tvoe of Insurance o Single o Joint Term Mos Mos Premium $N/A $N1A Date N1A Date N/A (If Joint coverage desired, both proposed insureds must sign.) ADDITIONAL TERMS AND CONDITIONS SECURITY INTEREST: I grant you a security interest under the Uniform Commercial Code and any applicable certificate of title law in (1) the Manufactured Home and in all goods that are or may hereafter by operation of law become accessions to it, (2) any refunds of unearned insurance premiums financed in this contract, and (3) all proceeds of such Manufactured Home and accessions. This security interest secures payment and performance of my obligations under this contract, including any additional debt arising because of my failure to perfonn my obligations under this contract, and includes any contractual extensions, renewals or modifications. If this contract is secured by a mortgage or deed of trust on my real estate, then this security agreement is not exclusive. Your rights and remedies under this contract and any mortgage or deed of trust executed herewith are cumulative, but my right to a Notice of Default and Right to Cure Default shall not be affected by any inconsistent provision of any mortgage or deed of trust. My execution of this contract constitutes a waiver of my personal property and homestead exemption rights to the personal and real property herein described. PREPAYMENT: I MAY PREPAY THIS CONTRACT IN FULL OR IN PART AT ANY TIME WITHOUT PENALTY, BUT I WILL NOT BE ENTITLED TO A REFUND OF THE PREPAID FINANCE CHARGE, IF ANY. PROPERTY INSURANCE: I am required to insure the Manufactured Home against physical damage for the term of the contract at my expense. The minimum coverage will be broad fonn comprehensive and flood coverage, if applicable, in an amount equal to the lesser of the actual cash value of the Manufactured Home or the remaining unpaid balance I owe from time to time on this contract. The insurance policy will contain a loss payable clause protecting you (as your interest may appear), and pwvide for 10 day notice of cancellation to you. I have the right to choose the person through whom the property insurance policy is obtained. If my insurance Retail Installment Contract and Security Agreement. DL.539PA (11/97) . Page 2 of 4 ~~~ --=~ . . ",~j coverage expires or is canceled pric .......""j'payment in full of this contract, I must obt:-1Io less than the minimum coverage at my ~xpense f.::r the rem&ining term of the contract. Should I fail to maintain insurance coverage, you may, but are not obligated to. obtain In,,-urance coverage. I agree that any Insurance you purchase may be for the protection of only your interest in the Manufactured Home: ',nay inciude coverage beyond those you require me to maintain if I purchase my own insurance policy, may be in the amount of the onglnal contract balance, and .may be for such reasonable period as you determine. If you do obtain insurance, you will notify me of that.fact and that the cost, plus Interest at the contract rate, will be added to my debt. I will repay such amount during the term of the policy 'n the manner requested by you. I understand that the insurance premiums may be higher if you purchase the insurance than mIght be the case if I had purchased the insurance, and that you may purchase the insurance from an affiliated company who may receive a profil.for this service. LATE CHARGE AND DISHONORED CHECK CHARGE: I agree to pay a late charge for late payment as set forth on the first page of this contract. Only one late charge will be made on any delinquent installment regardless of the period for which that installment remains in default. After this contract matures, whether by acceleration or othelWise, I will not be charged a late charge. If a check, draft or similar instrument I give you for payment on my account is not paid or is dishonored by my financial institution, I will pay you a dishonored check charge in the maximurrramount allowed by applicable law. EVENTS OF DEFAULT: I will be in default under this contract if: (a) I fail to make any payment when due; (b) I fail to timely make rental payments, or to pay other charges and assessments, relating to the real property andlor facility on which the Manufactured Home is located; (c) I violate rules or regulations relating to the facility where the Manufactured Home is located; (d) I fail to keep the Manufactured Home in good repair and condition, as you may reasonably determine; (e) I remove the Manufactured Home from the address shown on this contract unless I notify you in advance and receive your written consent; (f) I sell or attempt to sell the Manufactured Home without first obtaining your written consent; (g) I allow the Manufactured Home, if is personal property, to become part of any real estate; (It) I encumber or abandon the Manufactured Home or use it for hire or illegally; (i) I fail to promptly pay any taxes and other liens and encumbrances on the Manufactured Home: andlor G) I'fail to do anylhing else which I have promised to do under this contract. NOTICE OF DEFAULT: II any of the above specified Events of Default have occurred, you may do whatever is necessary to correct my default. You will, except as set forth below, first give me a Notice of Defauit and Right to Cure Default before you accelerate payment of the remaining unpaid balance I owe you or repossess or foreclose on any property which secures this contract. The Notice will tell me what my default is and how I can cure it. You are not required to send me this Notice when (1) you have already sent a Notice twice within the preceding one-year period, (2) I have abandoned or voluntarily surrendered the Manufactured Home, or (3) other extreme circumstances exist. CURE OF DEFAULT: I may cure a default at any time before title to the Manufactured Home is transferred from me, which will be at least 45 days after receipt of the notice of default. To cure a default, I must pay: (a) all amounts which would have been due in the absence of default and acceleration; (b) the attomey's fees set forth below; (c) any late charges that are due; and (d) reasonable costs which are ,actually incurred for detaching and transporting the Manufactured Home to the site of sale. I must also perform any olher obligation I would have had to perform in the absence of default. REMEDIES UPON DEFAULT: II I do not cure the default, you can require me to pay you the enire remaining unpaid balance of the contract plus accrued interest, and you can repossess the Manufactured Home. II you are not required to send me the Notice of Default and Right to Cure Default, you will have these rights immediately upon my default. Once you get possession of the Manufactured Home, you will sell it. If the amount from the sale, after expenses, is less than what I owe you, I will pay you the difference except as othelWise provided by law. ATTORNEY FEES: If you hire an attorney who is not your salaried employee to collect what I owe under this contract or to get possession of the Manufactured Home, I will pay your reasonable attorney's fees, provided that prior to commencement of legal action such fees may not exceed $50 and further provided that no attorney's fees may be charged prior to my receipt of the notice of defauit.. OTHER TERMS AND CONDITIONS: I agree: (a) to pay with my monthly installments, if requested by you to do so, the estimated amount necessary to pay yearly taxes, assessments and insurance premiums that will become due within the next twelve month period; (b) to pay you a transfer fee, if I sell the Manufactured Home, unless such fee is prohibited by law; (c) to pay interest at the contract rate on the remaining unpaid balance plus accrued interest, from the date of maturity until paid in full; (d) to reimburse you, immediately upon your demand, with interest at the contract rate, the amount of funds you actually advance on my behall to correct my default; and (e) that if I am married, and residing in a community property state, both my community property and separate property will be liable for all payments due underthis contract. CREDIT INFORMATION: You may investigate my credit history and credit capacity in connection with opening and collecting my account and share information about me and my account with credit reporting agencies, You may sell or otherwise furnish informatIon about me, inciuding insurance information. to others who may lawfully receive such informalion. You may furnish specific informalion about the Manufactured Home and any insurance policies on the Manufactured Home to any insurance agent to enable such agent to quote premiums to me al1d solicit my insurance business. ASSIGNMENT: You may assign this contract to any person or entity. All rights granted to you under this contract shall apply to any assignee of this contract WAIVER: Waiver of any default shall not constitute a waiver of any other default. No term of this contract shall be changed unless in writing and signed by one of your officers, This contract, and any mortgage or deed of trust executed by me .n connecl,on w,th thiS contract, is the entire agreement between us and I agree that no oral or implied represenlations have been made to induce me to enter into this contract. Retail Installment Contract and Security Agreemenl- DL-539PA (11/97) - Page 3 of 4 VALIDITY: Wherever possible each provision of this contract shall be interpreted in such manner as to be effective and valid under applicable law, but if any provision of this contract shall be prohibited by or Invalid under applicable law, such prOVISion shall be ~" ~. < JJ:<j ,iI ineff~ctive. only to the extent ~f such, . ,ibition or invalidity, without invalidating the ,ainder of such provision or the remaining provIsions of this contract. ThiS ?ontract shall be of no effect until and unless signed by me and you. In no event shall any charge under thiS contcact exceed the highest amount allowed by applicable law. If any excess charge is received such excess shall be refunded or applied to the amount due. ARBITRA T!ON: All disputes, .claims or controversies arising from or relating to this contract or the parties thereto shall be resolved by blndmg arbitration by one arbitrator selected by you with my consent. This agreement is made pursuant to a transaction in interstate commerce and shall be governed by the Federal Arbitration Act at 9 U.S.C. Section 1. Judgment upon the arbitration award may be entered in any court having jurisdiction. I agree and understand that I choose arbitration instead of litigation to resolve disputes. I understand that I have a right to litigate disputes in court, but I prefer to resolve disputes through arbitration, except as provided in this section. I VOLUNTARILY AND KNOWINGLY WAIVE ANY RIGHT I HAVE TO A JURY TRIAL EITHER PURSUANT TO ARBITRATION UNDER THIS CLAUSE OR PURSUANT TO A COURT ACTION BY YOU (AS PROVIDED HEREIN). I agree and understand that all disputes arising under case law, statutory law and all other laws including, but not limited to, contract, tort and property disputes will be subject to binding arbitration in accord with this contract. These powers shall include all legal and equitable .remedies including, but not limited to, money damages, declaratory relief and injunctive relief. Notwithstanding anything herein to the contrary, you retain an option to use jUdicial (bring a lawsuit) or non-judicial relief to enforce the monetary obligation secured by the Manufactured Home or to foreclose on the Manufactured Home. The institution and maintenance of a lawsuit to foreclose upon the ~anufactured Home or to obtain a money judgment shall not constitute a waiver of the right to compel arbitration regarding any other dispute or remedy subject to arbitration in this contract, including the filing of a counterclaim in a suit brought by you pursuant to this provision. a David W'Snow A~ l/X.t NOTice. ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR. COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. IF YOU DO NOT MEET YOUR CONTRACT OBLIGATIONS, YOU MAY LOSE YOUR MANUFACTURED HOME. NOTICE TO THE BUYER: 1. DO NOT SIGN THIS CONTRACT BEFORE YOU READ IT OR IF IT CONTAINS ANY BLANK.SPACES. 2. YOl!.A.R.E.~N:rI'fI,.ED TO AN EXACT COPY OF THE CONTRACT Y 51 EEP TTO PROTECT YOUR l~~A~:~I~!'lr.~. =cn ~""""""""'- t~i..."'-- :. ......:- '"0 .. ...... ':;:I .......... - .~-~-~-~<-~<.~-~.~. m rail'. .......................................: la :::;t:i:i:i:t: ='-" . . . . , . '.' '" :.... . ATE'Of:tHISIt RACT: ......... . ........ . I AGREE TO ALL THE TERMS OF THIS'Rl;TAII;'JI\l6l'ALL ENT CONTRACT AND ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS COriltFiAcT. ~ ~"""'X^ ./ Roxann Snow rJ--/6-7~ ASSIGNMENT BY SELLER TO IndyMac Mortgage Holdings, Inc. ("Creditor") With respect to this retail Installment contract ("contract") signed by one or more buyers ("Buyer"), Seller represents and warrants that (1) Buyer's credit statement submitted herewith Is COn1pletely accurate unless otherwise specified; (2) Buyer was legally competent to contract at the time of Buyer's execution ot this contract: (3) this contract arose from the bona fide saie of the merchandise described In this contract; (4) the downpayment was made by Buyer In cash unless otherwise specified and no part thereof was loaned directly or Indirectly by Seller to Buyer; (5) any trade-In, or other consideration. received as any part of the down payment, Is accurately described on the second page of this contract, and has been valued at Its bona fide value, and any amount owed on such trade-In or other property Is accurately described on the second page of this contract, and has been paid off by Seller prior to or contemporaneously with the assignment of this contract to Creditor; (6) there is now owing on this contract the amount set forth herein; (7) this contract and any guaranty submitted In connection herewith is In all respects legally enf.orceable against each purported signatory thereof; (8) Seller has the right to assign this contract and thereby to convey good title to it; (9) In the event of any claim or defense asserted by any Buyer, or any heirs or assigns of Buyer, with respect to the Manufact~red Home or other property or consideration transferred pursuant to this retail Installment contract, Seller agrees that it will Indemnify and hold Creditor harmless from all such claims and defenses as well as from all costs reasonably incurred by Creditor In connection therewith, Including but not limited to reasonable attorney fees and court costs; and (10) in accordance with the Fair Credit Reporting Act, Seller has notified Buyer that this contract Is to be submitted to Creditor. For value received. Seller hereby assigns to Creditor all Its rights, title and Interest in this contract and the property which is the subject matter hereof and authorizes Creditor to do everything necessary to collect and discharge same. All the terms of any existing written agreements between Seller and Creditor governing the purchase of contracts are made a part hereof by reference, it being underst that Creditor relies upon the above warranties and upon said a reements In urchasln Ihls contract. ASSIGNMENT: The foregoing contract is hereby assigned to IndyMac MO,rtga i i , Signature ; ! L(.. :5-k..'il/ SELLER FULL ADORES 1D Retail Installment Contract and Security Agreement. DL.539PA (11/97). Page 4 of 4 . Inc. under the terms of the above Assignment. ii,OV--- Title f11.Ci;-- " j ;:l. If SELLER NAME: , ".;' .--,,, -.:-- 1IfIIllIll1/1'll1lflTJ:J"...:IIJ::lil, i11l1 t;\...."'U11J.' . DEPARTMENT OF TRA~SPORTATlON , . ,', n. CERTIFICATE OF TITLE FOR A VEHICLE~o i '~~~': t'} :~.~ 97~7?n0530029~8-00~' ~ {,~;. . ,,';"..." -" BY #_;~- ._;,.",-," ,," ,-i.~&;' ~ "". . ,..', , .~~:.~~~ !>~ ~;; ,"'<"~','.' .,/;. ','':' :::'~;';,{: - ," AuntORIZED REPRESEmATlYE. . ' 03~007 INDEPENDENT NATl. MORTGAGE CORP J~5050 AVE OF SCIENCE / STE ~01 SAN DIEGO CA 92~2a "''',,' ',,';,' ~ .,., "'0.::'. ~)1;:r"' , . 'A; ',i';' ~<._~ ,-:" -/:':'~ "~~.~;.:~:~+44\ ):~u>~1~:J<)& ',- "-" -,,1; - ';q, . ,]\-.iga J.l;, ,. ~:Y;~;~~~~\,~?.Jj~:~l:'\~ "" "BR"'DLEY-~_i]:lA(;(t:lRY , Icortitya&ortho~of!$suo.thooHic!alf{l<X><tkotthloPonnsylYania~ of Transportation reflect that the person(s) C1t comPIl(l)' I\3med Men Is 1M tawiul owner "ot the said veMieI&. Whllnll;lptylnglottitlowflhaco-<lWl'l6l'_olhOl'thanyour:opouse.<lhed;:OMot-: lI>oS&bIod<& II no blockisdwekod.lillowilrbe~ILS"'_ ioCommo<'l~." A D JointT_...;u.R,,"htol~(on<ktaltlol""""!"'*.lIIlogool._< 8h ~":n~z.m~?~ndelUhd';;;QW!'4r.irtta~'~'~~~r':; ~ goe;IDh<:lcrhorheOrsoroSl.atel. MaBA D. MEANS @ commission #1171852 ;; ~, _ Nota)' public - Col!f~ __ ~ z - San Diego County' ( i Mf~~~~3~~ / - - - - g~~ei /;:),-lb-Q0 F1RST<UENHQLDEA: ~'~:rND'I(}').4c.\''lJcl.'''I16E. ltowIfJC,,,> smm,', :p.O. ~ /500%0, CITY, ~ OlE;. 0 , "" IF NO UEN CHecKeox o ,:t..0C . D o STATE! UEN':: DATE!" SE~O t.lI::NHOL.OeA: NAM~ smE~ Tho undOlSignQd ho"'by rrIIlKas ap~lc:l!.1JQn for Certificato of T(Ie to lhfJ wohicloo dascriOOd 4bovtI,$UbJectlOl/WlenclJ~andol/WlfJooaldaimo~tfc!tll/lo<'a. '~GN"11JAEOFM>P~C TOFl":;&:!! fi) j .$/1 tr-(3Y \I~OFCO-"~rrr.xOF/I, ,. . - CITY i - < . .""- . ;"\ co '-~" ,=-.,. ~ _ (I ACT 91 NOTICE (INSTALLMENT CONTRACT) TAKE ACTION YOUR HOME FROM EVICTION TO SAVE DATE: April 18, 2000 TO: David W. Snow 135 Castle Drive Mechanicsburg, P A 17055 Roxann Snow 13 5 Castle Drive Mechanicsburg, P A 17055 TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TIIA T PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. , ' This is an official notice that the Installment Contract on your home is in default and the lender intends to start eviction proceedings. Specific infonnation about the nature of the default is provided in the attached ~ The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet the Counseling Agency_ The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, yon may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired 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 ~bl~ to help explain it. You may also want to contact an attorney in your area. The local bar associ~tio~ 11;1ay be able to help you fmd a lawyer. LA NOTIFICACION EN ADJUNTO ES,DESUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA."StNO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCcioN INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA. " ',~ "",,'"" - i-'~ " ijl 'I .), STATEMENTS OF POLICY HOMEOWNER'S NAME(S): David W. Snow and Roxann Snow PROPERTY ADDRESS: 135 Castle Drive - Mechanicsburg, PA 17055 LOAN ACCT. NO.: 3000537328 ORIGINAL LENDER: National Asset Management Group CURRENT LENDER/SERVICER: National Asset Managemeut Group HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE THAT WILL PREVENT TERMINATION OF YOUR CONTRACT FOR THE SALE OF REAL ESTATE PENNSYLVANIA (HEREINAFTER CALLED "CONTRACT") FROM EVICTION AND HELP YOU MAKE FUTURE INSTALLMENT PAYMENTS IF YOU COMPLY WIlli THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PRO~PECT OF BEING ABLE TO PAY YOUR CONTRACT PAYMENTS, AND ' - " '. . IF YOU MEET OTHER EL.JQIBILITY REQUIREMENTS ESTABLISHED BY 1HE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF TERMINATION OF YOUR CONTRACT-Under the Act, you are entitled to a temporary stay of eviction on your contract 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 WI1HIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR CONTRACT UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR CONTRACT DEF AUL T" EXPLAINS HOW TO BRING YOUR CONTRACT 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. '...,1 : APPLICATION FOR CONTRACT ASSISTANCE-Your contract is in a 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 pr9bl~mwith 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 TlliS LETTER, EVICTION MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR CONTRACT ASSISTANCE WILL BE DENIED. . >' . ~ '.o;-A _,', ,'~_'" _ _ ~~_~ -K; 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 eviction proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE 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 CONTRACT DEFAULT (Bring it UP to date). NATURE OF THE DEF AUL T- The CONTRACT debt held by the above lender on your property located at: 135 Castle Drive - Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHL YCONTRACT PAYMENTS for the following months and the following amounts are now past due: Start/End: 9114199 thru 4114100 at $188.85 per month. Monthly Payments Plus Late Charges Accrued $1,530.80 NSF: $0.00 Inspections: $0.00 Other: $0.00 (Suspense): $0.00 Total amount to cure default $1,530.80 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use ifnot applicable): NIA 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 $1,530.80, PLUS ANY CONTRACT PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING TIIE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check, certified check or money order made payable and sent to: FEDERMAN AND PHELAN, Suite 900,Two Penn Center Plaza, Philadelphia, PA 19102, attention: Reinstatement Department. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable.) N/~.'. IF YOU DO NOT CURE TIIE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to' exercise its rights to accelerate the contract debt. The means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the contract 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 attorney to start legal action to start eviction proceedings upon your contract propertv. IF THE CONTRACT IS TERMINATED-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, iflegal 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 to the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay 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 contract. , ,I - " .- 'I RIGHT TO CURE TIlE DEFAULT PRIOR TO EVICTION-If you have not cured the default within the THIRTY (30) DAY period and eviction proceedings have begun, you still have the right to cure the default and prevent the eviction at any time UP to one hour before the eviction. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the eviction and any other costs connected with the eviction as specified in writing by the lender and by performing any other requirements under the contract. Curing your default in the manner set forth in this notice will restore your contract to the same position as if you had never defaulted. EARLIEST POSSIBLE EVICTION DATE-It is estimated that the earliest date that such eviction from the property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the eviction will be seni to you. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Attorney Representing Lender: FEDERMAN AND PHELAN Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102 Phone: (215)241-1711 Fax Number: (215) 568-7617 Contact Person: Phyllis Levin, Reinstatement Department EFFECT OF EVICTION-You should realize that an eviction will end your interest in the property and your right to occupy it. YOU MAY ALSO HAVE THE RIGHT: . TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE CONTRACT RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEF AUL T. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) . TO ASSERT THE NONEXISTENCE OF;\. DEFAULT IN ANY EVICTION PROCEEDING OR ANY OTIlER LAWSUIT INSTITUTED UNDER THE CONTRACT DOCUMENTS. . TO ASSERT ANY OTIlER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED Very truly yours, FEDERMAN AND PHELAN Cc: National Asset Management Group Attn: Mary Hanson Account No.: 3000537328 Mailed by 1" Class mail and by certified Mail No: 7099-3220-0003-6385-4001,4018 Pennsylvania Housing Finance Agency Hom.eowner's Em.ergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) LCYCOlIling'~linto:ln Counties Omm.LSS1on For Co '.\ _ . 2138 Lincoln Street mmWllty .-=t:ion (STEP) P.O. Box 1328 W~linmsport. PA 17703 (5,0) 326-0587 FA.X (570) 322.2197 CCCS of Northeastern Pi\. 201 Basin Street . W;.lIiamsport. PA 17703 (5 10) 323-6627 FA..X (570) 323-6626 CI.lNTON COUNTY CCCS of Northeastern Pi\. 1631 S AthertOn St . Suite 100 Sl::1te College, PA 16801 (814) 238-3668 F~(814) 238-3669 COLUMBIA com.n CCCS of Northeastern Pennsvlvania 1400 Abington Executive Park Suite 1 Clarks Suznmitt PA 18411 (570) 587.9163 or (800) 922-9537 FA..X (570) 587-9134/9135 31 W. Market Street POB 1127 Wllkes-Barre, PA 18702 (570) 821-0837 or (800) 922.9537 FA.X (570) 821-1785 Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 or(800) 822-0359 F......X (570) 829-1665-CALL BEFORE FA..'IDlG (570) 455-4994 HAZELTON FAX (570) 455-5631-CALL BEFORE FA..'IDlG (570) 836-4090 TUNKHANNOCK Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 F......X (814) 453-5749 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglesto:lwn Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 F_.....X (717) 234-9459 Community A"cion Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232.9757 FA.,,((717) 234-2227 CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban League, Inc 601 Indiana Avenue Farrell. PA 16121 (412) 981.5310 CUMBElU..Al'lD COUNTY Financial counseling Services of Franklin 31 West 3rd Street Waynesbortl, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Smet Carlisle, PA 17013 (717) 243-3818 FA..,,( (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St ~ttysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 PENNSYLVANIA BULLETIN, VOL 29, NO. 23, JUNE 5, 1999 '. 'or ~. - . ' , . VERIFICATION Karen M. Mastro Hereby states that he/she is the First Vice President of IndyJllac Mortgage Holdings, Inc. , Mortgage servicing agent for the Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action Ejectment are true and correct to the best of his/her knowledge, information and belief. I understand that this statement is made subject to the penalties of 18 pa. C.S. S. 4904 relating to unsworn falsification to authorities. Date: 0UNe: ';'J,CJooo HOLDINGS INC. As Attorney In Fact Indymac Mortgage Holdings, Inc. vs. David and Roxann Snow Account No.: 3000537328 ~"'~IlF"""~ ~ ~ """ <<o''''Ib,' : . THE STATE OF CALIFORNIA ~ ~ COUNTY OF Los Angeles ~ BEFORE ME, the undersigned authority, on this day personally appeared K"T"pn lot. M"Rtro , known to me to be the First Vice President of INDYMAC MORTGAGE HOLDINGS, INC., and whose name is subscribed to the foregoing instrument, and acknowledged to me that he executed the same for the pUIposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE on this S _ \,-;-. .r- CJ.~ ~c:. ,~ day of r;2j~k NOTARY LlC in and for the State ofCalifomia My Commission Expires: (/1 at; I ~ /;J[f[ ~ J@, ,- -,::=~4-f ~ HolaIy Public - Cafifania ~ i' , Los Angeles Counly f _ _ _ _My~~~~l~~ ___~~I::if~~i[Jl/;.,~;_"~Mi:iW;"i{~bII~I~M~&i\f'M"",,,d,lli%!,)._;,,'W-Mj,,,milli!!!ll:0>!I~~"1!i! , ", 'I.':~~~" ,,~.. ..": '. ~) " ~ ". +~, . ...' ~. - . , ~ _ ",c,"';';' ,,<I.:, 'd"~'"'~~~~'": J" ,/,'\!,. ,'< ' "iMli,., ",." . "" ~.,,,~.. p f~~8 ":.t) ~ I ", Sj;-l) I ~ o ;p ~ .....: r--- r "'.t J- ..L~ ",",~' ,."~ .~ ___. -.... '" ,. -. ,~. .. ,~~ : . () 0 0 r~ C) ~ -" , ~ -r.Jf{i ." 0....111,'1 L_',,\ r 2..: -c ~'~1 9 0 if) -. 'LJ :::LJ 0 -< ~2(j 8 r:::::c.; " -,-' 'I ;?e, ;-,'.::: ~,n ::;:.: ~:i:r) L. ,:.-.~ >c ;--M ::i' (":" " ..:::~ Z .:..:> > :<! :1., -< ~ .. ~ ,... :"'. -'i\ ~t. CASE NO: 2000-037~2 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INDYMAC MORTGAGE HOLDINGS INC VS SNOW DAVID W ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SNOW DAVID W the DEFENDANT , at 0014:32 HOURS, on the 21st day of June , 2000 at 29 VICTOR DRIVE MECHANICSBURG, PA 17055 by handing to ,,' WILLIAM J. MIXELL (NEPHEW) a true and attested copy of COMPLAINT & NOTICE together with and ~t the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 7.44 .00 10.00 .00 35.44 So Answers: r-~~~ R. Thomas Kline 06/22/2000 FEDERMAN & PHELAN Sworn and Subscribed to before I:L- me this 7 day of 11 ~ A.D. ~' 7hd~ ~ prothonotary' By: \joJAl1'l ~ \Mt Deputy Sheriff ""3":k'~'"i.'h~~-:g - ~ . ~"-" -- ''''''I 1-, '-. SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-03742 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INDYMAC MORTGAGE HOLDINGS INC VS SNOW DAVID W ET AL R. THOMAS KLINE ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT SNOW ROXANN but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , SNOW ROXANN DEFENDANT NO LONGER RESIDES AT ADDRESS STATED LEFT NO FORWARDING WITH P.O. MAY BE OUT OF STATE. Sheriff's Costs: Docketing NOT FOUND RETURN Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21.00 -----......, County FEDERMAN & PHELAN 06/22/2000 Sworn and subscribed to before me this 1'= day of Q~ .24rvo A. D. ~ 12 ?nJJ?~.,,-~ Pro nonotary " 'FJ,,;;~~j~!~~~ FEDERMAN AND PHELAN By: Frank Fedennan, Esquire Atty. 1.0. No, 12248 Two Penn Center Plaza, Suite 900 Philadelphia, P A 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF INDYMAC MORTGAGE HOLDINGS, INe. COURT OF COMMON PLEAS CIVIL DMSI0N v. DAVID W. SNOW ROXANN SNOW AND/OR OCCUPANTS CUMBERLAND COUNTY No. 00-3742 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Plaintiff hereby Settle, Discontinue and Ends the action filed in the above matter. ~/I/ /00 Date I ~~i2. _ Fr Fed , uire Attorney for Plaintiff "-- ;_" _ _"~<-;~,c,~_;,~-_._'_ '_~,""__; ~_" Illfl:~.' 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