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Home My WebLink About97-02164 ~ o o I -i\ r ! , . -(' j i Jl u.J <.!) " .' .,if~ Al'~"'1'" " .' I .\, I) '. E L ~ J ::r ~ - (Q , G) . 1( GE CAPITAL MORTGAGE SERVICES, INC. I Suooessor in Interest to TRAVELERS I MORTGAGE SERVICES, INC., I Plaintiff I I vs. I I RICHARD LEE CLOUSER, I Defendant I IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. e(7 - v<. ( r., 4- (1' l-~_{L, , i " \ ). CIVIL ACTION - LAW 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 have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you/ the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the court without further notice. You may lose money, 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 Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 NOTICIA Le han demandado a usted en la corte. si usted quiere defenderse de estas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted de be 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 de su persona, Sea avisado que si usted no se defiende, la corte tomara medidas 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 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABOGAD 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA DIRECCION SE ENCUENTRA ~SCRIDA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL: CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa, 17013 u (717) 240-6200 GE CAPITAL MORTGAGE SERVICES, INC. I Succe.sor in Interest to TRAVELERS I MORTGAGE SERVICES, INC., I Plaintiff I I VB. I I RICHARD LEE CLOUSER, , Defendant I IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. CIVIL ACTION - LAW MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C, ~1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint, Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor, Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff GE CAPIT.AL MORTGAGE SERVICES, INC. Successor in Interest to TRAVELERS MORTGAGE SERVICES, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. RICHARD LEE CLOUSER, Defendant CIVIL ACTION - LAW MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, GE CAPITAL MORTGAGE SERVICES, INC., Successor in Interest to TRAVELERS MORTGAGE SERVICES, INC., with a servicing agent of On-Line Solutions, which has an office at 4690 Hallmark Parkway, San Bernardino, California 92407. 2. Defendant, RICHARD LEE CLOUSER, is an adult individual whose last known residence is 1075 Oyster Mill Road, Camp Hill, Pennsylvania 17011. 3. On or about March 30, 1990, Defendant executed and delivered a Mortgage Note in the sum of $52,989,00 payable to TRAVELERS MORTGAGE SERVICES, INC. (original mortgagee), a copy of said Note is attached hereto and marked Exhibit "A", 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed and delivered to the original Mortgagee, a certain real estate Mortgage which is recorded in the within Commonwealth and County in the Office of the Recorder of Deeds in Book 971, page 1004, conveying to the vriginal Mortgagee the real estate described therein. GE Capital Mortgage Services, Inc. is the Successor in Interest to Travelers Mortgage Services, Inc, Said Mortgage is incorporated herein by reference, 5. The land subject to the Mortgage is: 96 Front Street, Borough of West Fairview, Pennsylvania 17011/ and is more particularly described in Exhibit "B" attached hereto. 6, Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on February 1/ 1996, and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance (b) Interest at $14.10 per day From 1/1/96 to AC (based on contract rate of 10\) $50,766.48 (c) Accumulated Late Charges and Late Charges at $22.99 per month for AC months 321.88 (e) 5\ Attorney's commission 1,227.15 $ 2.538.32 (d) Escrow deficit TOTAL $AC * *Together with interest at the per diem rate noted in (b) above after AC/ and other charges and costs to date of Sheriff's Sale. The attorney/s fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff/s Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8, No Judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance has been given to the Mortgagor, but the Mortgagor has failed to reinstate the Mortgage in accordance with the provisions thereof. A copy of the Notice is attached hereto and made a part hereof as Exhibit "C". 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The subject Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A, Section 707 - 1715z11) and therefore does not fall within the provisions of Pa, Act 91 of 1993 (Homeowners' Emergency Assistance Act of 1983). WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in rem for the aforementioned total amount due together with interest at the rate of 10% ($14.10 per diem), together with other charges and costs, including escrow advances incidental thereto, to the date of sheriff's Sale, and for foreclosure and sale of the property within described, PURCELL, KRUG & HALLER By ~ -D I J. ,! LVI 1 {. ~ Leo P. Haller Attorney for Plaintiff I. D. #15700 1719 N. Front St. Harrisburg, Pa. 17102 (717) 234-4179 ~Iulll",ol' _ \....11,'1 ORIGIf \L NOTE' RETURi'1 TO TRA~r.Llin~ r~QQT~Ar.F ~FR\11CES, INC. IU\l.A.. '" ~ I .398J434 IWlCH 30 ,19 90 96 FRONT STREET 80ROUGH OF WEST rAIRVIEW ,P,opnIY AdtJlnll I. PARTIES RICIWUl LEE CLOUSER "Borrower" mean. tach person .llnlna.lthe cnd or Ihll NOli. and lhe penon', ,ucccuor. and 1I111nl. "Lender" melnl TRAVELERS HORTGAGE SERVICES. IHC. and hllu~ellor. Ind wlIRl. I. BORROWER'S PROMISE TO PAy,INTEREST In return rOt. loan received from lender, Borrower promilCllo PlY Ihlll principal sum or rIFTY TWO THOUSAND HINE HUNDRED EIGHTY NINE 00/100 0011111 (U.S. S 52.989.00 ), plus inleresl, 10 tho order or lender. Interal will be chlt,cd on unpaid principal. trom the dill of dllburscmcnl or th.loan proceeds by Lendel. lithe rile or per cent ( 10 ") per )'eu unlU Ihl rull amount or principal hu been paid. ., PROMISE TO PAY SECURED Bonowcr', promlH 10 pay b ICCUrcd by. mon,.,I, deed or lrull or similar .cc:urily Instrumentlhat iI'dated the aaml dltl u lid. NOI. and called Ih. IISccurit)' Irulrument.1f Thlt Securit)' lruuument pratccu th. Lender from Ioua which ml,h& ,"ull I' Borrower de'lullI under Ihl. No... 4, MANNER OF PAYMENT (A'TI.. Borrower .hln mlkl I paymen' 0' principal and Inllm' 10 Lander on Ih. finl day 0' each monlh bq!Mln. on HAY 01 , 1990 ' Any principal .nd Inl....' remalnln. on ,h. fin! dlY 0' APRIL 01 ' . 20 20 ,will be due on thll dati. whkh II called Ihe mlturh)' date. (I) PI... Plrreen, .hln be mad,.' TRAVELERS HORTGAGE SERVICES. INC. hURXA5YEC98'SHIE PbOlARy HILL NEW Jii~:luch olher pll" U lAnder mlY dlll,DI.. In wrllln., (C) A_o..1 ' , l!ach monlhly P"ymen' 0' principal Ind Inllml will be In Ih. .mounl 0' S 465,02 . ThII Imoun' wUl be pan 0' llar.er monlhly paymenl required by Ih. SecurllY 100"umenl, 'hit .haIl be Ipplled 10 principal, Inl....' and OIber II.... In lho order dacrtbtd I. the Securlly 100trumenl. lD) All.... .. tIola .... lor 'IJ_' .dJ........ , . , ' Ir an allonl' pravldlnl for paymenl adjuttment. I. executed by Borrower toaether with thll Not.. Ih. COymutll or the allan" ahall be IncoflKJrated Inlo and ahall amend Ind aupplement the covenanll of IhiI NOle u lllh. IUan,. wen . pan ., Ibb NOli, (Check Ippllcabl. box) 8 AdjUlllbl. R." Allon,. Orowln, EqullY Allan,. 8 OradUlled Plymen' Allan.. Olber S. BORROWER'S RIGHT TO PREPAY Bonower hu Ihe rtlht 10 pa)' Ihe debt evidenced b)' thl. NOI.. In whol. or In plrt. Wllhoul challl or penall)', on Ih," fint da)' or In)' month. a. BORROWER'S FAILURE TO PAY (AI Lal. 0.... 'or P"n1.. PIJIM'II Jr Lender .... DOl rccdved Iho full monthly paymen' required by lhe Sc<url1y 1000rumau, U _bed In p......ph 4(C) ollhb NOIe by 1110 end 0' nncen caIcndar dayo .ner lhe paymcnl b due. Lender moy coDece I IIlo cborp In tho IIllOWlI 0' rIVE ,.,_ ( 5 "') 0' Iho overdue amount 0'.... JlIymcnl, (B) Oel..I. If Borrawer derlUl1l b)' IlilInato pi)' In full In)' monlhl)' plyment, then Lender ml)', except u IImlled b)' re,ulatloru 01 Ih, Scaetary in th. cue of lNyment delaulU, requlr. Immediate paymentln luU or tb. principal balao" mnalnlnl due and a1llcctUed Inlernt. Lender ma)' choou not 10 ucrclJ"tbll option wilhout walvlnliu nahu In th. event 01 an)' aubacqulnt dcllUlt. In man)' clrcumllanca rqulatlona Ilium b)' the Sccrttlry will 11mb Lender'a riabllto require Immedlal' paymenl In full In Ih, cue of payment delaultl. Thla NolO don not autharill lCCC1erallon when DOC pmnlucd by HUD rqulallon'. AI wed In Ibil Note. uSecretary" meaRl Ibe Secretary of Howlnl and Urban DtYtlopmeRt or hb or her dalanet. (C) P'Jm... ., Cotll lid Ex_ ' If Lender hu nqulrcd Immfdlal' payment In full, u dCKrlbcd above. Lender ma)' requlr. Borrower 10 ply COllI and exptftlCllncludlnl reuonable and CUllomII)' anome)'I' fea lor .nrordnl thl. Note. Such rea and (QIIJ lnall belr lnlerat trom Ih, dal' 01 dl.bunement at lb. same rate u Ihe principal 01 Ihb Note. , '... ," .',':' '.', , '. u...' , , , , h' _/0/1 ntA M......... ,..... .... ..... . "" <.}!J> 3913434 " WAIVER! Borrower and any oth..r I'Cnon "'ho hat abUIII!""' Undtf Ihi. NOI' WII"1: Ih, rl,hl' or prtltnlmcnl and nodcl 01 dhhonor. "Prmnlmrnl" mean'lhe rl,hllo require Lndcr 10 demand plymcnl or amuunt, due. "NOllu or dllhono," meanllh, filM 10 rcq~lr. Lender lOlly. nollcclo Dlher ptnon. ihAI amounll due h..... nOI been paid. I, CIVINC or NOTICES Unltu 'PPUclbl. Ilw rrqulra I dIHcrcnl mClhod. In)' nOlle. Ihl' mUll b. ahen to Borrower under Ihit NOli will be .i....n by dclivmn. II or by millin, it by fiut clUJ mall 10 Borrower Illh. property addrtll above or all dlrl.,ent addrtu lr Bonowcr bu 11'1'" Lender I noli" 01 Borrow"'. dlrr.,.nl addreu. Any nOllel lhll mUll be Ilycn 10 Lender under Ihl. NOI. will be .Ivcn by nnl cia.. maUlo Lender I' the addre.. .laltd in Parlar.ph 4(8) or It . dlrrertnl add".. II Borrow.r II ,lYen a nolle. of lhll differcnl addrlU, ,. OIUGAnONS or PERSONS UNDER THIS NOTE U mort lhan on. penon Illnllhi. NOli, each penon il fully Ind penonllly abU.lled 10 kttp In of Ih. promlltl mid. In Ihl. NOI., lncludln, Ih. prumbt 10 pay Iht full Imounl owed. Any penon who II I ,ulrlnlor. lurelY or tndorKr of Ihta NOltta 1110 obllalled 10 do thnt Ibln.., Any ptrleR wbo Ilk" oYer Ih"t obllaldonl, IncludlnllM abU,lllonl of Iluarlnlor, .urtty or .ndOrlff of Ihta NOli, 1I a1ao abllllll'd 10 Ir.Hp aU of Ih. promlan mid. In Ihll NOI., Lender mlY .nforCl hi rl,hu under Ihll Not. ..IIMI .ach plrlOR Indlvldullly or .,llnll 11I11.nl'orln 10lelher, Anyon. penon Il,nln, Iblt NOli may " required 10 ply aU of Iha amountl under ehb NOli, f I . ;1' , . .: I . , ~ j' , .. J' " \ ' I, .,', , "'fllILII1"JflJt; I".' ". "!. t1,( 'n " . II' ,t"Jlq !IIIJ" 'I d:' "I. 1 ":1 ",1,1 ,; il ~., . ,i. . . fL.r 1"1 ,-, .::" !t' P':' .."11.... . ""., .' ,. . BY SIONINO BELOW, Bonowlt IcctplllllCl Ilrm 10 Ihl term. Ind covenanll contained In thl. NOli, t~/J.X~, ":', j1JJ~~ _ ,)),)..U/ltL fJ Q) RlCUAIlD LEE CLOUSER i (ScaI) i ,- t (SuI) f ,- I , (SuI) ~ ,- (SuI) .- , '." '. f" -:'~ . .,. q"" 'j 114' '''1'' ~ ,.,~:. . "I' 'I' ""'.j i", " - I ~\ I ' q iJU ' \.IU~ L I:l.-Il'~l.!l I I II t.":I:'''<;1 ""II 'l"rC t !l-'WUl;'1I" tJqili( 111~": illr ," I" I 'J" .! !'_i~ '.' . 01 . If ~!., .' ,j \ I ,'1.~'lnfl j 1 fl' ';' PAV TO THE ORDER OF "TRA~OlITRECOURSE CES, INC, BV: EllllDoIam PRESIDENT I.lft,I' IlU';:l 11'" : 1':1 ~ 1 , '11.ft ;p~ ,,;'''''*!'', p.rl.. ''''l'::,'jl'<fJ:.''ff. ',",0, ','If ','l.P f:' . nl . ' .;";-1 " ",'-ll! ','11 t, ; I'd;:.: ".,. 'IT., 1:.1\.'.-.1.'.010'11'1":1, . 'j ,. ~ ',- :' ::.'f ,. \ "f.~' I:' I'" "1/1 I ~ ',- , r', f T.I,j:P'U I; l"i"'):;' .. :1 ;h'ir';',ll ",: ',J -it ': '~';l~:q ..,. I.. II' -- . '11,'..'..... .u._......_ _~. "'~_..'" 8EGIIl~IIlG It I point on the WlSt lid. of Front Strltt, laid point bel.ng'S8.31:< ' . f..t South of the louthwolt corn.r of Front .nd H.rkotl Stre.tll thonc.' ..tend- lng .10nO Front Stre.t South I d'grle 30 mlnut.\ West 23.67 feet to . point 'oppollt. th_ cenler of tht partition w.ll dhldlng properties known IS 110. 94 Ind 110;'96' Front Strut; Ihenco Ilorth 8S degrees 30 1.lnulel WlSt, paning through the. .. c.nttr o( 1.10 partition will and boyond 130 ftot to I point on tht Elst'sld. of .,5 foot IlleYI thence along laid al1.y North 1 degr.. 30 minutes E.st 23.67' fout to a point on the louthern line o( Lot Ho. 8 on tho heretnaftor ~tntlon.d plan of Lots; thence .long the sou thorn line of Slid Lot South 80 degrees 30 minutes Elst 139 foot to I point. the place of beginning. BEIIlG the northern port o( Lot No.7 on the Town Plan of West Falrvlow .5' ftcordod In Curnberhnd County Recorder's Offlco In Ottd Book 2H. Page 205. . ,0,'. , HAVIfIG thereon erected the northern one'h.H o( I (rame dwelling known' .s 110. 96 Front Slr'tt. . 0I10ER MID SUBJECT nevertheless to easements. restrictions. reservations. conditions .nd rights of wlY of record. . BEUIG THE StJotE PREI41SES which Dennis E. Biker Ind Bonnie J. Boker, his wlf., by deld d.ttd April 23, 1981. Ind rlcorded In Doed Book J. Volume 29, Plgt 611, Cumberllnd County Rlcords. granted Ind conveyed unto D.nltl L. Sllnlll .nd L.hr.oen H. Shntts. his wHI, thl Grantors herein. _~.,4. I i ."" , . . " 1 ,I .~ , . (~ I . ( '8 'I " I1E Capital DATB, January 27, 1997 11 C,.IIII MOI/q.,. $ml.... Ine. ; UtIli 01 ~"'lf'" E/~crn~ L'X/III Mr.f1gJ~' .; ,r:orauon "?/JO /IaILTIJIIl P>iJIwI~ :lJn .'11'''''",0. (;. !;IO~ :oo.3~H'23 NOTICB PV INTBNTION TO PORBCLOSB MORTOAOB UNDBR SBCTIOH 403 OV PA ACT NO.6 OV 1974. (RBAD BOTH PADBS or THIS NOTICB CARBPULLY.I RICHARD LBB CLOUSBR 1075 OYSTBR MILL ROAD CAMP HILL, PA 17011 RB, GB LOAN * 0003983434 PROPBRTY 96 FRONT STRBBT WBST VAIRVI, PA 17025 MORTOAOBB, G. B. CAPITAL MORTOAOB SBRVICBS The Mortgage held by the above named Mortgagee (hereinafter we, us, or oure) on your property noted above is in eerious default becausa you have not made the monthly payments as noted below under (a). Late chargee under (b) and other charges, if any, under (c) noted below, have also accrued to this date. The total amount now required to cure this default as of the date of this letter, is noted below under (e). (al 020196 thru 040196 . $574.91/month $1,724.73 (al 050196 thru 010197 . $571. 81/montl1 $5,146.29 (b) Late charge (a) , $275.90 (cl NSV check charge(s)' .00 (d) Less I Credit Balance .00 (e) Total amount required as of this datel $7,146.9~ You may cure this default within THIRTY (30) days of this letter by paying to us the amount under (e) above, plus any additional monthly payments and late charges (and other charges) which may fall due during this period. Such payment must be either by cash, cashier's check, certified check, or money order made payable to G.B. Mortgage Services, 625 Maryvi11e Centre, St. Louis, MO 63141, Attention: Cashiering Department. If you do not cure the default within THIRTY (30) days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original mortgage amount borrowed will bs considered due immediately, and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgage property. If the mortgage is foreclosed, your mortgage property will be sold by the Sheriff to payoff the mortgage deht. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings ({J/gWJVf ,.-".'I'I'.'I'~- tiC" LJ,., U I ~_. ( GE Cap/t./ 11 CJDIUI,lI.t1g,q, ~''''''J, 1.1.. ..: Jlllt 01 tj Jr.f!'~' :,e:ill: ::'=';,tJJ MCnQlir;' t,;';fOorat:OIl .;,'}dO Hjll.rw",''; Jr~w,jv' $J.'1 C4fnd/~I;'O. CA 32401 against you, you will hava to pay tha ra..anabla attorney's fees actually incurrad up to $50.00, Howavar, if legal proceedinga are atarted againat you, you will hava to pay the reaaonable Attorney's feea even if theyare over $50.00. Any attorney'a fea. will be added to whatever you owa us, which may alao include our reaaonable coata. If you cure the default within the THIRTY(30) day pariod, you will not be required to pay attorney' a fees. A),so, we may aue you personally for the unpaid principal balance, and all other auma due under the Mortgage. If you have not cured the default within the thirty day period, and foreclosure proceedinga have begun, you will still have the right to cure the default and prevent the sale at any t.ime up to one hour before tha sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, .s well aa the reasonable attorney's fees and costs connected with ths foreclosure aale (and perform any other requirements under the mortgage). It ia eatimated that the earliest date that such sheriff's sale could be held would be approximately FIVE MONTHS FROM THE DATE OF THIS LETTER, A notice of the date of the sheriff's sale will be sent to you before the sale. Of courae, 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 will be by calling us at he following number,l (800) 344.6723 . This payment must be in cash, cashier's check, certified check, or money order and made payable to ua at the address stated above. You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right in it, If you continue to live in the propert.y after the aheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to payoff the mortgage debt, or borrow money from another lending institution to payoff this debt (you may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will asaurne the mortgage debt, provided that all the outstanding payments, charges, attorney's fees and costs are paid prior to, or at the sale and that other requirements under the Mortgage are satisfied), Contact us to determine under what circumstances thia right might exist. You have the right to have thie default cured by any third party acting on your behalf. If you cure the default, the mortgage will be restored to the same position as if no default had occurred, However, you are not entitled to this right more than three times in a calendar year. Very Truly Yours, 39S3434 Tina Richardson, Loan Counselor 1 (800) 344-6723 .....'-,, "", J '_. " :1 ~;~:. .' HALLER ..., ' TEL:717-234-1206 Ju 1 17 96 12:54 No.007 P.06 COMPANY NAME ION-LINE SOLUTIONS, SERVICING AGENl' FOR GE CAPITAL /oORl'GI\GE SERVICES, INC. Successor in interet to TRAVELERS /oDRl'GI\GE SERVICES, INC. VERIFICATION I verify that the statements made in the foregoing Complaint ~re true and correct. 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. Datedl By r\;f f).-H[L (rJ)/1 0 ~ ~CApr ~ Title ASST. VICE-PRESIDENT :'1 'if; \,,! , , I. I [,' ')1/\1 1 -, fc. ~ ; ! I : ;' ) '. I.' l _. 11:, t J I Ii; :<1 jU "it: ;\i. !'ll I W f i':fHJ~-) YL'I.\tll l\: 'll:lj'Y iii' CU!'\tiiT,L!\tUi I;'. 1';\, I i,\. !'jt)HT/,lj.'; :^)J.;nv rr;l-: J..!.!!_~. V!.: ..'. l~f,!ill:;1.I;; rn\ lItd;:1J lJ+:r: l' "11.\'.1. DArili leli ShC"riJt or lJC'put.y SherLtJ 01 ""Mtll'.' MIl> Count.y. Pp.nns,Ivanla. who being duly "worn according '0 j,)W, says, the wittlln CUMPI,AINT - 11URT FUIII': "pon ,'I.IIUSI':II HICflMID LEE was :tH~)l'ved Lho: dr:-ti".'nddnt. dt 1'1';:.1:(,1\1 HDUHS. on U'le ~ day oJ lIr>ri I t'y:I':'. ;]t Ill?:', UY:'in:R M Il.L RUAD eMil' IIILI." I-',~ 171/)11 .CUMBERI.IIND --_..' CDllllty. I'c'nr13ylvanii'\, by hand1.ng Lo rlllLL.lr RFI'LOYLE, ROG:IMATt: M1!::....."..Tlj:;Il!! IN CHARm: a 'JIlt' .:lnct at t..,otE'd copy ui the CIJMPLII UIT - f11lHT Furn:: t.fJ<]ethpl' wit.h NUTIC~: dnd at l.tll? Gamr;,~ time directing HiE atlentl.on to the cCJfltenlG thE.~reof. " t-~hpr_i.tJ'[J C(J:.;.t',s: LJ(lI.~i'.r:'( tng ':(:'C'l lct? t,t( 1.1.]'/1\ ~.UJ-f'h;Jrge ~;:~Tnl~~~J_'_'_.'.~~~~r~ I;. iliI1lJ~;, .. .1.11'.'. __'ll'.'J _1. J lH,00 '1.1)2 .00 2, (;)0 /~), ':,J2 'l'UHCCI t. I-\flULI Ani' 04 F.'1\}./ 1 ~Y)7 Ijl'~- el. 1 it ....I.;f jJ ::dld ll!J;:,r:r 1 hed to lH:lI-Jf'C' UI(-> \1"" JtJ~ t')~ ff;]y 'J.f v~-- 1'1 Q1.,_;', f', l\. Q. ~ ^t'-. ---".,1.4.. J--'i-,)1,tj('I,,:.t.]IJy ~ i:i;, il'l . I. i " i ' ~ i ii;!i j,'Jll) , ~ I I: l' J l l !I' I . In:! i'i'''';I" )';1 flt- j'FtlfL;'ll VldUA: ";1'1 :\j iunl\~r,L:dll; :,- 1 \t'11;,1 !111hiAl.:I.: :d-:F:VII~I': IrH~ \/, . ',' i 'j _~ 1l1~_;!':I,; lLLLLUU,-~'~~_~Ji": .J\. Th,'l1l1;.1;:; r:l int:' Sheriff. who being duly sworn accord1ng tll l-Jw, 8.JY3, that he rlli;Jds.' a dil~gE'nt search ilnd inquicy for the within rh~rncd dC'lfenrlilnt.. .pQ wit.: CLlJlJSI::R RICI1AIW U:": but ""-.1':3 t1n-:tbli:' to lor::ate Him 1n h1s b~i11w1c~. l1e therefore returns tl.... Ci.iMI'i..\ltlr - HUrn FUR": ~~XLLL~_____. 11111' 1'\.>111111 -' ;'1,;-3 to th~' \l1th.in n<.1rm~rJ def...:?ndant 1;1.lllI,,;,'I.; "jl,IIMW LlOl': i\HIJ\'I': ;\I,prd~:::;i:.; I'..; VACAUT. :;lll'l]ff'~ Cr;~-lt.8: 111-,,'1.,-,1 i fig :;"'f '/11"(' t, t t. 1.,_1.)',-' _L t ~,ul-'.:haI ':Je :';0 ,"In[i\lt'-rs: b. It'~" ,1)1) . vWI ~;, 1210 ll. 1 hl,:lnHJs ";1iol;.', Sher iff '."<1. ,-ll! ,'LlT,CLlI. !';IWG AlII) IIALLt:H iii.}.' JO/ 13\j? I ill 'H~ -.rl.l ::,i'IL<,.:criljed t(1 Ilc"lnn,' rilE' .30_~_ .ill'! ~~ 'II. :J~ J~C' (J"_ tv....' f~ ' ~. I "rl I 1 r Il 1'1 ql /\. [I. C~.-J'-L-llqth~C.~. I "+~" GE CAPITAL MORTGAGE SERVICES, INC. I IN THE COURT OF COMMON PLEAS Suocessor in Interest to TRAVELERS I CUMBERLAND CO., PENNSYLVANIA MORTGAGE SERVICES, INC., I Plaintiff , , NO. VB. I I RICHARD LEE CLOUSER, I CIVIL ACTION - LAW Defendant I MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C, ~1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint, Plaintiff is the creditor to whom the debt is owed, Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor, Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon p, Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4179 Attorney ID #15700 Attorney for Plaintiff . GE CAPITAL MORTGAGE SERVICES, INC. Successor in Interest to TRAVELERS I MORTGAGE SERVICES, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs, RICHARD LEE CLOUSER, Defendant CIVIL ACTION - LAW MORTGAGE FORECLOSURE C 0 M P L A I N T 1, Plaintiff, GE CAPITAL MORTGAGE SERVICES, INC" Successor in Interest to TRAVELERS MORTGAGE SERVICES, INC., with a servicing agent of On-Line Solutions, which has an office at 4680 Hallmark Parkway, San Bernardino, California 92407, 2, Defendant, RICHARD LEE CLOUSER, is an adult individual whose last known residence is 1075 Oyster Mill Road, Camp Hill, Pennsylvania 17011, 3, On or about March 30, 1990, Defendant executed and delivered a Mortgage Note in the sum of $52,989.00 payable to TRAVELERS MORTGAGE SERVICES, INC. (original mortgagee), a copy or said Note is attached hereto and marked Exhibit "A", 4, Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed and delivered to the original Mortgagee, a certain real estate Mortgage which is recorded in the within Commonwealth and County in the Office of the Recorder of Deeds in Book 971, page 1004, conveying to the original Mortgagee the real estate described therein, GE Capital Mortgage Services, Inc. is the Successor in Interest to Travelers Mortgage Services, Inc. Said Mortgage is incorporated herein by reference, 5. The land subject to the Mortgage is: 96 Front Street, Borough of West Fairview, Pennsylvania 17011, and is more particularly described in Exhibit "B" attached hereto, 6. Defendant is the real owner of the land subject to the Mortgage. 7, The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on February 1, 1996, and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance (b) Interest at $14.10 per day From 1/1/96 to ^C (based on contract rate of 10%) $50,766.48 (c) Accumulated Late Charges and Late Charges at $22.99 per month for ^c months 321.88 (d) Escrow deficit 1,227.15 (e) 5% Attorney's commission TOTAL S 2.539.32 $AC * *Together with interest at the per diem rate noted in (b) above after ^C, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale, If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8, No Judgment has been enteren llpon said Mortgage in any . jurisdiction. 9. Notice of intention to foreclose and to accelerate the t loan balancA has been given to the Mortgagor, but the Mortgagor has failed to reinstate the Mortgage in accordance with the provisions thereof, A copy of the Notice is attached hereto and made a part hereof as Exhibit "C". 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11, The subject Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 - 1715z11) and therefore does not fall within the provisions of Pa. Act 91 of 1983 (Homeowners' Emergency Assistance Act of 1983) , WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in rem for the aforementioned total amount due together with interest at the rate of 10% ($14.10 per diem), together with other charges and costs, including escrow advances incidental thereto, to the date of Sheriff's ~ale, and for foreclosure and sale of the property within described. PURCELL, KRUG & HALLER By ~W71 P. f-k~ Leo . P. Haller Attorney for Plaintiff I. D. 1115700 1719 N. Front St. Harrisburg, Pa. 17102 (717) 234-4179 . .I ,398J434 ~-\". - 1-, ~lullisl,'I' 0 RIG It' \ L NOTE' REiURii TO , Tll/\'![LtR5 !!onTr.Ir.~ ~fll'llCES, INC. IWlCII 30 ,19 90 -. 11t'..:....s... I~ ~6 fRONT STREET BOROUCII OF WEST rAlIVIEII IPtope", ArJdlrtll I. PARTIES R1CIlARD LEE CLOUSER "Borrowe," munl IIch penon II,nin,.llh. end orlhi, NOle, and Ihe pcnon'lluccenon and ullaRI. "Lender" meanl TRAVELERS HORTCACE SERVICES, INC. and III luc,ccllon and lullnl. J. BORROWER'S PROMISE TO PAY; INTEREST In return rOf . lOin received (rom Lende" Dorrower promilcllo PlY Ihe prlncipallurn or FIFTY TWO TIIOUSAND NINE HUNDRED EICiTY NINE 00/100 Oollan (U.S. S 52,989.00 " plUllnlerest,lO Ihe order or lender. Inlcfnl will be char,cd on unpald principal. (rom lhe dlle or dbbuuemcnl or Ihe lOin proems by Lender. II Ihe rata of pcr ccnl ( 10 ") per )'elr unlll 'he (ulllmounl or principal hu betn paid. 3. PROMISE TO PAY SECURED Dorrower'. promise 10 pay il KCurcd by. mortall', deed ur nUll or Ilmita, Iec:urilylnstrument Ihlt la.dlled Ih, slme dill U Ihls Nolc Ind called the "Security Instrument." Thlt SMull)' Inslnlmcnt protccu the Lender rrom loua which mllhl rauh Ir Borrower ddlulu under thta Nole. 4. MANNER OF PAYMENT (AlTlm. Borrower shill mlk, I paymenl or principII and lnlerest ~o Lender on Ih, "n' dlY or each month bellnnlna on HAY 01 , 1990 ' Any principal .nd In'''es. ..malnlnl on th. finl day 01 APUL 01 ' , 20 20 ,will be duo on thlt date, which b ClUed the maturity dill. (B) PI... Parn'''" shall be mad. II TRAVELERS HORTGACE SERVICES, 'INC. hJ6RX~filIEC98PBIUE pea~QRY HILL NEIl Jfi./i/"eh o'her place u L.nder may desllna.. In wrldnl. (C) Amounl ' , Each monlhl)' plyment or principal and Inlerest will be In the amount or S 465.02 . ThlIamount will be p.n or alul" monthly pa""en' required by th. S<<uri'y Instrumen', 'hal shall be applied '0 prlndpal, In,eml and other Iteml In the order described In th. Rccurhy Instrument. (0) Allonl' 10 lid. aol. for ,.)'nanl IdJYllratnll . If an allonlo proYidlna ror payment adJualmentl It executed by Borrower loaether with tbiJ Not., tht covcnanu at Ihe aUonlc Ihall bo Incorporated Inlo and Ihllllmend Ind supplement the covcnanU of IbtJ Not. u If the allonl' wm I pan 01 'hls Note, (Check appllcabl. boxl 8 Adjlll.abl. Rato AllonlO Orowlnl Equit)' Allona' 80radUlled Payment AlIonll O.her S. BORROWER'S RICIIT TO PREPAY Borrower bu Ih, rlahlto pay the debt evidenced by Ihls Note, In whole or In pan, wllhout charI' or penally, on Ih,.' nr.. day of any month. 6. BORROWER'S FAILURE TO PAY (A) Litt Cbar., for ~htrd... 'a,.,nu II Lender hu nol rccdvcd lhe luU monthly paymenl Rqulred by .he S<<urlly 100"\lmen', U ~bcd In parqraph <l(C) 01 'his NolO by .he end 01 nRem calendar days aller lb. paJll1Clll Is due, Lender may _ a Iale dwp In Iho omounl of lIVE per cent ( 5 ") 01 lhc ovmlue omounl or ooch "'_. (B) Oolaul. If Borrower der.ulu by r.l1Inl to pi)' In tullany monchly ",,)'menttlhen Lender may, ClCqK U IImhcd by r'lulatioM of Iha Secretary In Ihe cue of payment deeaulu, requlr. Immediate paymenlln fun or Ihe principal b.laoc:e rtmIinln. due and all accrued Inlerest. Lender mlY chOOla not 10 cxerd.. Ihls option whhout walvln.lu riahllln the evenl or In)' subJcqu.nt derlull. In many c1rcumltlnca rClutlllonl bsued by Ih. Secretlry will limit Lender'. rilhll 10 rcquln lmmcclla.. payment In lull In Ih. euo or paymen. delaulll, This No" doa nol au'horiu acceleration wh.n 110I pcrmlUed by HUO ,qulalIon" AI used In IhlJ Not., f1Sccr:t1r,." :neanl Ihl Secretary of Hou.ln. and Urban [\CVClopment or hll or her dallnet. , (C) ,.,.m.at 01 eo... and Elpcua " If Lend" hu required Immediate payment In rull, II dcsc:ribcd above. Lender may require Borrower 10 pa, cow and expenscllncludln. reuonlble and customlll' InomeYl' fea ror cnrordnl thil Notl. Such rm and COltllhaU IMar lnleral trom tb. da.. of dlsburlCment Itlhe urn. ntl U Iho principal or thll,Note..I,~,. ". t . .,,, IO.,.,!. ....:.. 'd,' '" :l.,..:r. .'''..,", ,",. . .,j.l, .. """ 1./1 filA "''''11&.'' ra-.. .... H... . "" ~J> I I ! , ! I i I I i f i r .. I i 398]434 ,,,, 1. WAIVERS Borrower and any olhrr rcnon .'ho hat ablla.aieln, under Ihlt Nole walH'lh. ,I,hll of prcunlmcnl and nolke or dl,honor. "P,.Holmenl" meanllh. ,I,hllO rtqulr. Lende, 10 demand paymeRI of .mounn due. "NodCl of dishono," mcan.lh.,I.hl 10 requlrl Lender 10 11'1' node. 10 olhtf pellona thAI amounlt du. havt nOI been paid. .. CIVING OF NO.TleD Unlea. Ippllclblc II. tequila I durcrtnl method, In)' 0011r.. Iha' mUll be liven 10 Borrower under IhiJ Nolf will be ,Inn by d.II\'1llo, II or by mamn, It by nUl el.... maUIO Borrow" Illhe properly addle... above or II . dIU"enladdr"l If Horrower hu liven Lender I notlcl or Borrowc,', dllrCfcnllddrcu. Any nOllce thl' mUll be liven 10 Linder under Ihl. NOli will be alun by finl c1... m.1l1o Lender II Ihe addle.. lilted in Par.al.ph "(8) or It I dlrrcrcnllddrul I( Borrower II ,I\'en I nOlle. of Ih.t dUferent addre... ,. OBLIGATIONS OF PERSONS UNDER TillS NOTE If more Ihln one penon lilnt Ihll NOI., each penon IIlulty Ind pcnonaUy oblllllcd to kClp 111 ollh. proml... mid. In ,hit NOI., Includinllh. proml.. 10 pi' Ih. lull amounl owed. An, pinon who II . IUlrlnlor. IUUI, or .ndouct or thll Nolell 1110 obllalled 10 do Ihm thin... An, penon who Ilk" over IheM obllaallonl,lncJudlna th. obllalllont or laUlrlftlt~'. lurety or .ndorler or Ihl. NOlI, It abo obUpled 10 knp In or Ihl pI'ombo mad. In Ihil Notl. LInder may .nforcelu .lahu under Ihll Not. 1,llnll lIeh perlGn IndlvldullIy or I'll nil III IlanllollettOlclher . Anyon. penon lianlna thi. NOI. may be required 10 pa, In 01 the amounll under Ihll Nolt. ..:1 "I' '1. J' ... ;Ilt'''~~'(lll, f' "j . '." '. I!t. \'I'q IUI) I II" "1 : "; I n",l . '. I ~ .. I I.... ".. i':'" . , .., I . '. .. ' BY SIONINO BeLOW. Borrower .CC'PIl and .,r... 10 Ih. tonn. .nd .......nll ..nlllncd In Ihl. NOl.. l~/a~, :'. JU..J~ ~ - .J,().J},1U.. tJ Q) RICIWUl LEE CLOUSER (ScaI) ,- '.' (Scal) '........ (ScaI) ,- '1,'" 'iIN' '11. '." : III I.,!I "1I: ',1;"1"11" 'j 'I"'~'r. " h .;",:,~ '1. ill',i. "," .' ,0' " (ScaI) ,- '.~" ';'. PAY TO THE ORDER OF . TRA~ WITHOUT RECOURSE '" 8y,,~.9.?/~CES,INC, EIIIIID.1alo ~RfSlOENT ,'1;:'.111' .:r .," ..:' " .': I. i' "","l' r,',. " , " ." f'l~,," ,. ,..:., " ,'.....1....,11'11 "\',', " ., .,: It ~.' '.' r:' I' '." '. t'" I. ',;II"~ . I: ;".". .. "1 . ['-;-'-".11,': ., " ." "" '.1 ',I.: '"'''' .','" ""1 I. " , . r~, ,:.",: . \ P l ,.~ ... 'I ~"'I)1,n~ ~ "~?P:..t'i'~' ,.... ;<\..;,,~. ~ "~.,,. ..;~j'Y.":!'.~t':jl*~f,~/' ....'; ."; .y,.;,t.;,'l.l~'}:{' ',. ,'-\"'~.li.W~)k~~;::, ,( '..';";~;; ,...~:Jl~l:i\':'; :- ';....;It/r~: '.~ <~. . '. ~'L.~~ , ~. ..... ...~ r "I' :.,~," 'f 1'- - BE Capital OATB: January 27, 1997 11 C.O/tol Mm,.,. ~,"'I.... ,.e. . UnIt ot titlllelill il:ctnc L.'J~/tlJ Mr.rtY~1' 1J;r:oratlon .J?80JWJ.'71JIt~ay. :iJnd'fflJrou:o. (:..t g;~O;' Joo.34HI23 NOTICB pF INTENTION TO FORECLOSE MORTGAOB UHIlER SECTION 403 OV PA ACT NO.6 OV 1974. (READ BOTH PAGES OV THIS NOTICB CARBFULLY.I RICHARD LBB CLOOSER 1075 OYSTBR MILL ROAD CAMP HILL, PA 17011 RB, GE LOAN . 0003983434 PROPERTY 96 PRONT STREET WEST FAIRVI, PA 17025 MORTGAGEE: G. E. CAPITAL MORTGAGE SBRVICES The Mortgage held by the above named Mortgagee (hereinafter we, us, or ours) on your property noted above is in serious default because you have not made the monthly payments as noted below under (a). Late charges under (b) and other charges, if any, under (c) noted below, have also accrued to this date. The total amount now required to cure this default as of the date of this letter, is noted below under (e). (a) 020196 thru 040196 . $574. 91/month $1,724.73 (a) 050196 thru 010197 iii $571. 81/month $5,146.29 (b) Late charge (s) : $275.90 (c) NSF check charge(s), .00 (d) Less. Credit Balance .00 (e) Total amount required as of this date, $7,146,92 You may cure this default within THIRTY (30) days of this letter by paying to us the amount under (e) above, plus any additional monthly payments and late charges (and other charges) which may fall due during this period. Such payment must be either by cash, cashier's check, certified check, or money order made payable to G,B. Mortgage Services, 625 Maryvi11e C~ntre, St. Louis, MO 63141, Attention: Cashiering Department, , If you do not cure the default within THIRTY (30) days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgage property. If the mortgage is foreclosed, your mortgage property will be sold by the Sheriff to payoff the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings . rg@W>~ I'C'\ ~"'.z: '.llJI1 I. , . '.,,: ~h".; t",., ,..:-,1Ji ..... '.J", ..'-'.f', ( '. . (- .~ tWA ., .. . . "~'I ,,.. . -;'~r GE Capli.,.1\'" ,:, '. " 11 '~Q'III,lr.rt9.q, ~.n"'1, "'... ... ~.t 'JI Ot::rt{l' t,t::r,: :';;.;,tJl :"crrgfi" ~':'I:JoratlOi' ';/jSO Hl/l,nJrA t' m\I'~V SJ,'; ';i'n.u~,,'o. (..'A 1240/ against you, you will have to pay the re..anab~ attorney's fees ectually incurred up to $50,00. However, if lesal proceedings are .tarted again.t you, you will have to pay the reaaonable attorney's ree. even if theyare over $50.00. Any attorney's fees will bs added to whatever you owe us, which may also include our reaeonable costs, If you cure the default within the THIRTY(30) day period, you will not be required to pay attorney's fee.. Also, we may eue you personally for the unpaid principal balance, and all other sums due under the Mortgage. If you have not cured the default within the thirty day period, and foreclosure proceedings have begun, you will still have the right to cure the default and prevsnt the sale at any time up to one hour before the sheriff's foreclosure sale. You may do .0 by paying the total amount of the unpaid monthly payments plus any late chargss, charges then due, a. well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimatsd that the eal.1iest date that such sheriff's sale could be held would be approximatsly FIVE MONTHS FROM THE DATE OF THIS LETTER. A notice of the 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 requirsd payment will be by calling us at he following number:l (800) 344-6723 . Thi. payment must be in cash, cashier's check, certified check, or money order and made payable to us at the addres. atated above. You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right in it. If you continue to live in the ~roperty after the sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to payoff the mortgage debt, or borrow money from another lending institution to payoff this debt (you may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, providsd that all the outstanding payments, charges, attorney'a fe.. and costs are paid prior to, or at the sale and that other requirement. under the Mortgage are satisfied), Contact us to determine under what circumstances this right might exist, You have the right to have this default cured by any third party acting on your behalf. If you cure the default, the mortgage will be restored to the same position as if no default had occurred, However, you are not entitled to this right more than three times in a calendar year, Very Truly Yours, 3983434 Tina Richardson, Loan Counselor i (800) 344-6723 MHL.L.t.1< ~. ' , TEL:717-234-1206 Jul 17 96 12:54 No.007 P.06 , COMPANY NAME, ON-LINE SOLUTIONS, SERVICING AGENl' FOR GE CAPITAL foORTOAGE SERVICES, IfIC. Successor in interst to TRAVELERS ~ SERVICES, IfIC. VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsificat.ion to authorities. Datedl 4/'J..4 J q 7 , By..QiU(:fO-l ~ Title ASST. VICE-PRESIDENT . " C.. -'. - ,". -., - ~ "f'l!,-P APR 2;; 813 l:1'97 r ,-, , ' "L.I,j; " i i. \'}\},IA G,E. CAPITAL MORTGAGE SERVICES, INC. SUCCESSOR IN INTEREST TO TRAVF.LERS MORTGAGE SERVICES, INC., PLAINTIFF VS. RICHARD LEE CLOUSER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE APPIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 96 PRONT STREET, WEST PAIRVIBW, PA 170251 1. Name and address of the Owner(s) or Reputed Owner(s): Richard Lee Clouser 1075 Oyster Mill Road Camp Hill, PA 17011 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : 5, Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 7 . Name and address of every other person of whom the Plaintiff has knowledge who has any inter..t in the property which may be affected by the sale: TENANTS I F ANY ... DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Bonnie M. Clouser 96 Front Street West Fairview, PA 17025 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, info ation and belief. I understand that false statements herein are ade subject to the penalties of 19 PA C.S. Section 4904 rela ng to unsworn falsification to authorities. ~ Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234.4178 DATE: September 4, 1997 Ii :i i i' , r , I l r f I .... 1'"" '. i:-; -I r ., I.:. N lll~ n" ." i::';'( ....' I:. I'.... I ~. , , --1 ~ : 0::' I rEf' t1 :;";", f" 'LJ ~ l'_ ,,, , Il, r- :~) u C' U G,E. CAPITAL MORTGAGE SERVICES, INC. SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC., PLAINTIFF VS. RICHARD LEE CLOUSER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION . LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE NOTICE OP SHBRIPP'S SALE or REAL BSTATB PURSUANT TO PBNNSYLVANIA RULB OP CIVIL PROCEDURB 3129 TAltB NOTICB, That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 10, 1997 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, PelIDsylvania 17013 THB PROPERTY TO BE SOLO 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 DESCRIFTION ATTACHED) THE LOCATION of your property to be sold is: 96 FRONT STREET WEST PAIRVIEW CUMBBRLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 97 2164 CIVIL THB NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: RICHARD LBB CLOUSBR - RIAL OWNER A SCHBDOLB: 01' DISTRIBtrl'ION, 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 bank. that hold mortgage. and municipalitie. that are owed tax..) 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 PAPBR IS A NOTICE OF THE TIME AND PLACB OF THB SALB 01' YOUR PROPBRTY. IT HAS BBBN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HBLD. TO BE SOLD OR TAKEN TO PAY THB 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 OFFICB SBT FORTH BELOW TO FIND Otrl' WH~RE YOU CAN GBT FRBB LEGAL ADVICe, Court Administrator Court Administrator's office Cumberland County Courthouse Carlisle, Pennsylvania 17013 phone (717) 249-1133 THB LBGAL RIGHTS YOU MAY HAVE ARB' 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 an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. ALL THAT CERTAIN parcel of ground situate in West Fairview Township, Cumberland County, Pennsylvania, bounded and described as follows I 'EGJll~IIlG It I point on the WlSt std. 0' 'rant Strltt. Slid point bol,ng' 5'!31 :,- . ,..t South of the louthwost carn.r 0' 'rant Ind H.rkots Str..tll thonc. ..t.nd-' Ing .lono 'rant Strltt South I d.gree 30 _Inutt\ Wast 23.67 '1ft to . jlCililt'oppollU th. ccnter of the pertltlon w.1I elhl41n9 propertlos known U 110. 94 .nd 110;'96' . FroM Strltt, th,nco 1I0rth 88 4.grats 30 11I1nutOl west, PUlln9 through tho: ",:,- c,ntur 0' 1.ld p.rtltlon will .n4 bayond 130 'lot to I poInt on the (.It'llel. of I IS foot 11"1. thence .lon9 I.Id 111.y North 1 d.gre. 30 .Inut.s E.lt 23.67' 'oat to , pOint on th, louthern line 0' Lot No.8 on tho h.re'n"tor ~ntlan.d, Pl,n of Lots; th.ne. .Iong the southorn Itn. 0' ,.Id Lot South 84 dlgr..\ 30 _Inutol tlst 139 foot to . Dolnt. the pl.c. 0' b.glnnlng. BEING the northern part of Lot No. 7 on the Town plan of West Fairview as recorded in Cumberland County Deed Book 2H, Page 205. HAVING THEREON ERECTED the northern 1/2 of a frame dwelling known as 96 Front Street. UNDER AND SUBJECT nevertheless to easements, restrictiona, reservations, conditions and rights of way of record. BEING THE SAME PREMISES WHICH Daniel L. Slantis and Lahneen M. Slantis by deed dated March 30, 1990 and recorded in Cumberland County Deed Book M34, Page 529 granted and conveyed unto Richard Lee Clouser. TO BE SOLD AS THE PROPERTY OF RICHARD LEE CLOUSER UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 2164 CIVIL. Parcel: 45-17-1044-282 . ~ ,I '- r-. ~:'-- t-: -:J r', ~ ,. III ~.: <.1- '''' ,~ .; L_ ,," ,:1 " {,',; e::. , I ; ,j , Q:' r:.. ";J L, , .-.~ , c.., II, ,.... U ~ (j G,E, CAPITAL MORTGAGE SERVICES, INC, SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC., PLAINTIFF VS. RICHARD LEE CLOUSER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) P,R.C.P, 3180-3183 TO THE PROTHONOTARY. Issue Writ of Execution in the above matter on the real estate located at 96 Front Street, West Fairview, PA as follows, Amount due pursuant to Judgment Interest (Per diem of $14,10 from 3/1/97 to 12/10/97) Late Charges at $22,99 (3/97 to 12/97) Escrow deficit TOTAL WRIT ** Together with any additional interest, charges and costs to the date of Sheriff's Sale. By LEON P. HALLER I.D. #15700 ATTORNEY FOR PLAINTIFF 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Dated: September 5, 1997 Attached is a description of the real estate. ALL THAT CERTAIN parcel of ground situate in West Fairview Township, Cumberland County, Pennsylvania, bounded and described as follows: 'EGJiI~IHG st . poInt on the West sId. of front Streit. uld point bol,n9'5~.31 :'. r..t South o( the southwo't corn.' of front Ind Hlrkot' Str..tSl thon~. ..~.~~. ' Ing Ilon~ front Slr,'t South I d'gr., 30 mlnut., WIst 23,67 feet to I poInt oppo,lt. thlt clnler o( th' plrtttlon Will dhioln9 propertIes known U 110.9' Ind "0;'96" front Strtltl thenco Horth !8 d.grOll 30 ,"'nutes WlSt, puslng through tho, ',:' c.nlvr of ,.10 plrtitlon Will InO ooyond 130 f.ot to . point on the E.st 11d. 0' .15 foot 11"11 thene. 110ng s.ld 111.y North 1 d.gr'. 30 mInute, E.st 23.67' foot to . point on the louthern lIn. or Lot Ho. 8 on tho hereln.fter II.nt\on,d Pl.n o( LotSl th.ne. ,'on9 the 'outhorn ltne of 1.ld Lot South 88 d.gr,.' 30 .tnutes tlSt 139 foot to . poInt. the pl.e. o( O'9innlng. BEING the northern part of Lot No. 7 on the Town Plan of West Fairview as recorded in Cumberland County Deed Book 2H, Page 205. HAVING THEREON ERECTED the northern 1/2 of a frame dwelling known as 96 Front Street, UNDER AND SUBJECT never.theless to easements, restrictions, reservations, conditions and rights of way of record. BEING THE SAME PREMISES WHICH Daniel L. Slantis and Lahneen M. Slantis by deed dated March 30, 1990 and recorded in Cumberland County Deed Book M34, Page 528 granted and conveyed unto Richard Lee Clouser. TO BE SOLD AS THE PROPERTY OF RICHARD LEE CLOUSER UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 2164 CIVIL, Parcel: 45-17-1044-292 'r .. G.E, CAPITAL MORTGAGE SERVICES, INC. SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC" PLAINTIFF VS. RICHARD LEE CLOUSER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE 1 . P R ABC I P B TO THB PROTHONOTARY OF THB WITHIN COUNTy, Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant RICHARD LBB CLOUSBR for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $14,10 from 1/1/96 to 3/1/97) Accumulated late charges and Late charges ($22.99 per month to 3/97) Escrow Deficit 5% Attorney's Commission $50,766.48 $ 5,978.40 TOTAL $ 321.88 $ 1,227.15 S 2.538,32 $60,832.23** ** TogAthAr with ~drlitional interest at the per diem above from 3/1/97, based on the contract rate, and costs to the date of Sheriff's Sale. rate indicated other charges By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 .. G.E. CAPITAL MORTGAGE SERVICES, INC. SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC., PLAINTIFF VS. RICHARD LEE CLOUSER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE CBRTIPICATE OP SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on JUNE 27, 1997 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. y Leon P. aller PA 1.0. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 August 8, 1997 J.. G E CAPITAL MORTGAGE SERVICES, INC., SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC. , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. RICHARD LEE CLOUSER, CIVIL ACTION - LAW NO. 97-2164 CIVIL Defendant IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: RICHARD LEE CLOUSER 1075 OYSTER MILL ROAD CAMP HILL, PA 17011 DATE OF NOTICE: JUNE 27, 1997 THIS FIRM IS A DEBT COL1,ECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU I~ AN ATTEMPT TO COLLECT tHE INDEBTEDNESS REFERRED TO HEREIN, AN ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 PURCELL, KRUG & HALL ~ BY Leon P. Haller PURCELL, KRUG & HAL ER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney 10 # 15700 . a.E. CAPITAL MORTGAGE SERVICES, INC. SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC., PLAINTIFF VS. ' RICHARD LEE CLOUSER, OEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE NOTICB OP BNTRY OP JUDGMENT TO THE ABOVE-NAMEO DEFENDANTS: You are hereby notified that on following judgment has been entered aga captioned matter: $60,832.23 and for the sale and foreclosure of your property at 96 pront Street, West pairview, PA Dated: S - I).. -(7 , Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA l7l02 Phone: (717) 234 -4l 78 , I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: - , - . .' " ~. : . J . ; .' Richard Lee Clouser 1075 Oyster Mill Road Camp Hill, PA 17011 --- ~~ I lI'C) ~ ~ i . \.,' \:-, '1' h~; -' <.,' \'- t' U .1'.... ~ ...,\ '" I \).", ~ ~~ C'ol '" ~ ~ ~ ~ l{y~ ~ ~ ~ j~~ '-- f' ~ .- \ I ~ - l'-~ ", '.'1 (,. " .... ,- U' () , ' , . . I ~ I , ,''''' G.E. CAPITAL MORTGAGE SERVICES, INC. SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC., PLAINTIFF VS. RICHARD LEE CLOUSER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE R.TURN or SBRVICll I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on Q/9.?llql , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: Richard Lee Clouser 1075 Oyster Mill Road Camp Hill, PA 17011 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Bonnie M. Clouser 96 'Front Street West Fairview, PA 17025 ~ By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW Or'ICBS PURCBLL, KRUG . HALLBR 1719 NORTH PRONT STRBBT HARRISBURG, PBNNSYLVANIA 17102 (717) 234-4178 Richard Lee Clouser 1075 Oyster Mill Road Camp Hill, PA 17011 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COlrnTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Bonnie M. Clouser 96 Front Street West Fairview, PA 17025 NOTICB IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIPIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. By: the said ave an notified of YOU ARE FURTHER NOTIPIED that the lien real estate will be divested by the sale opportunity to protect your interest, if said Sheriff's Sale. ! Leon P. Hal er PA 1.0.15700 Attorney for Plaintiff G.E. CAPITAL MORTGAGE SERVICES, INC. SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC., PLAINTIFF VS. RICHARD LEE CLOUSER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE NOTICE or SHERIFP'S SALB or REAL BSTATE fURSUANT TO PBNNSYLVANIA RULB OP CIVIL PROCBDURB 3129 TAXB NOTICB I That the sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 10, 1997 10:00 O'clock A.M. TIME: LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania l70l3 I I t ! ! THB PROPBRTY 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: 9 Ii PRc:rr STREET WBST PAIRVIBW CUMBBRLAND COUNTY PENNSYLVANIA THE JUDGMEnT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 97 2164 CIVIL THE NAME (S) OP THE OWNER (S) OR REPUTBD OWNERS of this property is: RICHARD LEI CLOUSIR - REAL OWNER A SCHEDULB or 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 bank. that hold mortgage. and municipalities that are owed taxes) will be filed by the Sher.iff 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 (lO) 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. j, THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OP YOUR PROPERTY. IT HAS BBEN 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 OFPICE SET PORTH BELOW TO PIND OUT WHERE YOU CAN GET FRIE LEGAL ADVICE, Court Administrator Court Administrator's Office Cumberland County Courthouse Carlisle, Pennsylvania l70l3 Phone (7l7) 249-ll33 THE LEGAL RIGHTS YOU MAY HAVE ARE, l. 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 per~on or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. /' . ,I l" \ ,I l '. . L I \ ' 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 PILED BKPORB THB SHBRIPP'S OKlO IS DBLIVERID. 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 m~st 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 of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~ . ALL THAT Township, follows: CERTAIN parcel of ground situate in West Fairview Cumberland County, Pennsylvania, bounded and described as l{ :~ II ~ IEGIU'IING It I point on the Wilt side 0' 'rant StreU, uld point bol,n,'58.31 :.- ' 'let South 0' the ,outhwost corn.r 0' 'rant Ind H.rkolS Str..tSI thonc. ,atend- ' In, .Iono 'rant Street South 1 d.gree 30 _tnute' wost 23.67 'eet to . point 'opposite "" conter 0' the plrtltlon will dlv141ng properties known IS 110. 9. Ind No;'96 , 'rant Strut, thenco North ea dlgroes 30 ,nlnutaS Wilt, pus'ng through thO' ",:' centu' or sl14 pl,titlon Will .nd boyond 130 tlOt to . point on the E.stsld. 0' . IS foot .11'/1 thence .long ,.Id .111Y North 1 4eg,.e 30 .tnutes Elst 23.67' foot to . point on the southern line at Lot No.8 on tho h.relnlttor ~ntloned ,I.n at LotS; th.nce .Iong the loutharn ltn. 0' s.ld Lot South ao degr"l 30 .lnutas tlst 139 taat to . point. the pl.ce at b.glnnln,. ~ BEING the northern part of Lot No. 7 on the Town plan of West Fairview as recorded in Cumberland County Oeed Book 2H, Page 205. HAVING THEREON ERECTED the northern 1/2 of a frame dwelling known as 96 Front Street. UNDER AND SUBJECT nevertheless to easements, restrictions, reservations, conditions and rights of way of record. BEING THE SAME PREMISES WHICH Daniel L. Slantie and Lahneen M. Slantis by deed dated March 30, 1990 and recorded in Cumberland County Deed Book M34, Page 528 granted and conveyed unto Richard Lee Clouser. TO BE SOLO AS THE PROPERTY OF RICHARD LEE CLOUSER UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 2164 CIVIL. Parcel: 45-17-1044-282 . . JL..Jl.. POSTAL SERVICE CERTIPICATE OP MAILING (In comcliance with po.ta1 Service Porm 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Bonnie M. Clouser 96 Front Street West Fairview, PA 17025 Postage: Postmark: , , " '>, co " '- ~ , , -- .. u - , -,., , ", - , " t.., l.J..... U c_ , L l" I , '-' C. U STATE OF PENNSYLVANIA, COUNTY OF CUMBERI.ANI> } 55. Robert P Ziegler I. _____h_____n__ __ h_h__h____ _________ _________u__u__nn______n_________ aeeorder 01 Deed. in and for .aid County and Slate do hereby certify that Ihe Sherilr. Deed in which ____n__________ _n___ _________n________n ;~~~lir-"-~~:.L~!--'!.~~! :.?l!._~!'_d__~:~_~~_~_e_~~}.?_~~~!'.t..~!__ is Ihe gnolee was ington D C Ihe same having been .old 10 ,aid granlee on Ihe _______..l.Qtb.hh______n___h___h__h________ day of ___ 'hm_P:-':.~!!'.!>_"_~_____'____n..n'__n A. D.. 19.._?.7__n' under and by virtue of a wril____h________ Execution . 8th _u___ __h__U_ ____ h__ _h__" __h _n __ _ __ _ _ ___h 115ued OIl Ihe _ u__ __hh _ _ _ __ h_h_ __ __ ,_______ ___ September 91 . day 01 n_n__________hnh_____ A. D., 19hn__. oul 01 the Court of Cornman Pleas 01 saId County as of ___________~!J!jJ_h______n___ 00_______________ __n______h_n_n____ ____00_____ Tenn, 19__~~___ 2lb4 . G E CApital Mtg Services Inc Successor in interest Number _____n__n___' allhe .ull of ______h_hu___n_n________h____________h______h____n____ to Travelers Ktg Servi~es Inc Richard Lee Clouser ----..--~---------..--- ------ - -- --- -_ agalnst_ __ _____ __ ___ __ ___ ___ ________________ ____________.. __ is duly ..,<orded in Sherifr. Deed Book No. ~?_l_____h__, Page h~~!___nn. IN TESTIMONY WHEREOF, I have hereunto 'el my hand and seal of said office this -2-'t.___ day 01 --n1~X,g,(l---m--m- A. D., 19_~n_ ~~-------------------- ;;,r- 2/'---- Record... 01 Deeds llIeonfer of 0Ieds. Cumberlind Count,. Catlialt, PA My Canomialall Explm tilt fInt Monelly 01 JIn. ... :UO"" G.E. Capital Mortgage Services Inc. successor in interest to Travelers Mortgage Services Inc vs Richard Lee Clouser In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 97-2164 Civil Term Timothy ReilZ, Deputy Sheriff, who being duly swom according to law. says on October I, 1997 at 4:10 o'clock P.M" E.D.S.T., he posted the property of Richard Lee Clouser at 96 Front Street, West Fairview, Cumberland County, Pennsylvania with a copy of Real Estate Writ, Notice, Poster and Description according to law. Kristen Mertz, Depuly Sheriff, who being duly swom according to law, says on October 8. 1997 at 7:09 o'clock P.M., E.D.S.T., she served true copies of Real Estate Writ. Notice, Poster and Description ill the above entitled action upon the wilhin named defendant, 10 wit: Richard Lee Clouser by making known unto Richard Clouser at 1075 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and attested copies of the same. R. Thomas Kline. Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ, Notice, Posler and description in the following manner: The Sheriff mailed the within named defendanl. to wit: Richard Lee Clouser a notice of the pendency of the action by regular mail to his last known address at 1075 Oyster Mill Road, Camp Hill, Pennsylvania 17011, This letter was mailed under the dale of Oclober 9, 1997 and was never returned to the Sheriff s Office. R. Thomas Kline, Sheriff who being duly sworn according 10 law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on December 10, 1997 at 10:00 o'clock A.M. and sold the same for the sum of$ 1.0010 Attorney Leon P. Haller for The Secretary of Housing and Urban Development of Washington, D.C. his successor and assigns, The Wanamaker Building, 100 Penn Square East, Philadelphia. PA 19107-3380. It being the highest bid and best price received for the same, The Secretary of Housing and Urban Development of Washington D.C., his successor and assigns, The Wanamaker Building, 100 Penn Square East, Philadelphia, PA 19107-3380 being the buyer in this Execution paid SheriffR. Thomas Kline the sum of $ 706.25, it being poundage elc. Sheriffs Costs listed below. See attached distribution sheet for addilional costs. SHERIFF'S COSTS: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County MILEAGE Cert Mail Levy 30.00 13.85 15.00 15.00 30.00 10.00 .50 1.00 18.60 .50 15.00 Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deeds 4.00 263.75 212.58 26.97 25.00 lUO 706.25 , ii' ! , " '" I 1 'I Sworn and Subscribed To Before Me . "'" /l. This JJ(l - Dayo,y-......., 199'K ~~~:?~~m$ )U, 41.. , ,~ So~./ ~ r ~.;?.J -: -~ .~ R. Thomas Kline. Sheri By ~j;,_u,1L~ Deputy Sheriff ~ ~/ 30.",,,, CJc../q(,J/ \. / ~, (,1/.1' . '. sale: UNXNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any intereat in the property which may be affected by the sale: TENANTS IF ANY ... DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Bonnie M. Clouser 96 Front Street West Fairview, PA 17025 (In the preceding informQtion, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, info ation and belief. I understand that false statements herein are ade subject to the penalties of 18 PA C.S. Section 4904 rela ng to unsworn falsification to authorities. ~ Leon P. Haller PA 1.0. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 4, 1997 G.E. CAPITAL MORTGAGE SERVICES, INC. SUCCESSOR IN INTEREST TO TRAVELERS MORTGAGE SERVICES, INC., PLAINTIFF VS. RICHARD LEE CLOUSER, OEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 2164 CIVIL IN MORTGAGE FORECLOSURE NOTICE OP SHERIFP'S SALE OP RIAL BSTATE PURSUANT TO PINNSYLVANIA RUL~ OP CIVIL PROCEDURB 3129 TAXI NOTICBI That the Sheriff's Sale of Real Property (real estate) will be held: OATE: WEDNESDAY, DECEMBER 10, 1997 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania l70l3 THB PROPERTY TO BE SOLD is delineated in detail ~n 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 OESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 96 PRONT STREET WEST I1AIRVIEW CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 97 2164 CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: RICHARD LEE CLOUSIR - RBAL OWNER A SCHBDULB OP 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 (tor example, to banks that hold JIIOrtgage. 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 (lO) 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 PAPSR IS A NOTICE OP THE TIME AND PLACE OP THE SALB OP YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROP~RTY 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. I f you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YO~ LAWYER AT ONCE. GO TO OR TELEPHONE THE OPFICE SET FORTH BELOW TO PIND OUT WHERE YOU CAN GET PREB LEGAL ADVICe. Court Administrator Court Administrator's Office Cumberland County Courthouse Carlisle, Pennsylvania l70l3 phone (7l7) 249-ll33 THE LEGAL RIGHTS YOU MAY HAVE ARE. l. 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 an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. " 2. After the 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 PILBD BEPORB THE SHERIPP'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' 6 Office - Civil Oivision, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 " ,/ ,. ALL THAT CERTAIN parcel of ground situate in West Fairview Township, Cumberland County, Pennsylvania, bounded and described as follows I .EGlil~I/lG It . poInt on the WISt std. of 'rant Strltt. SlId poInt bol.ng'SJ.)\ ;.- ' f..L South of the southwost eorn.r of Front .nd H..kots Streetll thane. e.t.nd-' lng .lon9 'rant Str..t South 1 d.gr.e 30 _tnutes Wost 23.67 f..t to a point ~pposlt. thlr conter or tn. partItIon will dhl41ng propertlos known IS 110. 94 Ind lIo;'96' Front Strltt; thence /lorth sa d.gralS 30 fftlnutOl WlSt, puslng through tho' ",:,- c.ntur 0' s.14 plrtltlon w.ll .nd boyond 130 t.ot to. poInt on tn. East sId. of , IS foot ,Il'l: thonee .10ng s.ld .11ey Harth 1 degrtt 30 _tnutts Ellt 2J.67- foot to . point on the southern line of lot No.8 on tho her.ln,ftor gentloned ,lln of lots; th.nct ,long the sou thorn ltn. 0' Slid lot South 80 d.grt., 30 _tnutos (1st 139 toot to , poInt. the pllee 0' b.glnnlng. BEING the northern part of Lot No. 7 on the Town Plan of West Fairview as recorded in Cumberland County Deed Book 2H, Page 205. HAVING THEREON ERECT EO the northern 1/2 of a frame dwelling known as 96 Front Street. UNDER AND SUBJECT nevertheless to easements, restrictions, reservations, conditions and rights of way of record. BEING THE SAME PREMISES WHICH Daniel L. Slantis and Lahneen M. Slantis by deed dated March 30, 1990 and recorded in cumberland County Oeed Book M34, Page 528 granted and conveyed unto Richard Lee Clouser. TO BE SOLO AS THE PROPERTY OF RICHARD LEE CLOUSER UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 2164 CIVIL. Parcel: 45-17-1044-282 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 97-2164 CIVIL lGC~rm CIVIL ACTION. LAW TO THE SHERIFF OF ___~land COUNTY: To satisfy the debt, interest and costs due Q!~. Capital Mortgagfl Services, Inc. Successor in Interest to Travelers /obrtgage Services, Inc. PLAINTIFF(S) from Richard Lee Clouser, 96 Fr\)nt Street, West Fairview, PA 17025 DEFENDANT(S) (1) You are direc1ed to levy upon the property o. the de'endant(s) and to sell Real Estate located at 96 Front Street. West Fairvielll. PA 17025 (see attached description) (2) You are also directed to anach the property 0' the delendant(s) not levied upon In the possession 01 GARNISHEE(S) aslollows: and to not~y 100 gamlshee(s) that: (a) an attachmenl has been Issued; (b) the garnlshee(s) Is/are enjoined 'rom paying any debIto or 'or the account o' the de'endant(s) and from delivering any property o. the de'endant(s) or otherwise disposing thereot; (3) II property o'the de'endant(s) not levied upon an subject to anachment Is.ound In the possession 01 anyone other .han a named garnishee, you are direc1edto notify him/her that he/she has been added as a garnishee and is enjoined as above stated, AmountOue 560,832.23 _ Per deim of $14.10 from 3/1/97 Interes\ ---to-lrflO/97 $~.o04.~0 Any'sComm___ % $.50 u.. Any Paid Plaint if. Paid !'; 10'1..22- Due Pro thy $1 00 Other Costs tAt.. Charg.." at 522.99 (3/97 to 12/97) 5206.91 Escrow deficit $1,000.00 Date: ~ent>er 8. 1997 Lawrence E. Welker Prolhanolary. Civil Division tly;... a~. [J /?1n/M,i 0~ ( '0. . REQUESTING PARTY: Name [,f>On P. H;oller. Eso. Address: 1719 North Front Street H;orrjl'lhllrg. PA 17102 Anorney for: P1;oj nti ff Telephone: 717-::>14-4 J7R Supreme Court 10 No --1510D...______________ OCT. I I - "kun. l'\\.K1IJ(j '''C'-CI M~l~ll Ot'ru. ~hr patriot , , I ~'C14 u.. Auuunltn.c [A-pI. l\\,~ll1 O.'L' ..~ I, , I 'the l:\Jtning RrlUs 2, I ,5undau f3atriot'RclUS 3 i I ~ , I 110 III " ':::',.", II \IWI~II'- Hf~ I' \ 1-I'Jll'llI)\E ':"1:", :':.ii-~II.I ..; /" , I Compl.lu Cll"ura~u Ilf Punnsyl"anla'~ Third Large~t to,'", , " ! I and ~l,,~t Pro Ii table ~Iarket j , I e I I I CU11BO 20 OCT & NOV 1997 _ , I 71 , I '-- ' CUMBERLAND CO SHERIFfS OFFICE I 81 I I COURT HOUSE 81 I I CARLISLE, PA 17013 1,0 I , , t 11 i I I 121 I I / '/ :::z 10 OAll."It."'. ..11/ S/ 13/ I I IheM,. . ~ C; Plltlf'rtCH '14 : I NOTARY L.ESS ,po OAIL" 1 00 , , ! > ----_.~.._.. t--::- ';' i ,,/ I f\lIETOA1L.Y ...?J2 ,~J i 1 Ie I , I ~c..u.. "AtC 'hCHI, , ...ltl/'tCH, . 17' I i ' , , Ie' i '~""'TI 'he"" , "'ltINCH , 19 ; I , i LISS ,,.0 SUNO...., , 20, I I NCT IPl\oi > 2 I I i.,-!-i , I SALE NO. .2.1.. : 22\ : I i 23 I , i METRO WEST I ! 241 : I -. I i ' .. , DUPLICATE 12e; , i I TOTAl. Due > '27 ! I i 28 I J,-7, , I I 29t I I : 30 I ! I '3' I ! ! . , . I , ! , ~ /'l:i.. , . I , , , i I NOV. OCT. ~1.Jklf th<<k payabl~ to The Patrlul,XlfWI Co, All ad"erti.ing recei,'ed $ubject to appro,'aJ by Publi$her, THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No 587 AMmvlld loll. 18 Ig211 Commonweelth of Penneylvenle, County of Deuphln) II FrankJ. Epl., being duly sworn according to \Qll/, deposes and says: That he II the Controller 01 THE PATRIOT.NEWS CO,. I corporal/on orgenlzed and exlatlng under the IIWI of the Commonwedh of Penneylvlnll. with Ite principII Oltlcll Ind place of bUllne.. It 812 to 818 Mlrket StrMt, In thl Clt/ of Hlrrilburg, County 01 Dluphln, Stltl 01 Pennaylvanla, owner Ind publlah.r 01 THE PATRIOT.NEWS Ind THE SUNDAY PATRIOT.NEWS newapapera of gen.r.1 circulation, print ad .nd publlahed at 812 to 818 M.rkat Strllt, In tha City, County and State .foreaald; th.t THE PATRIOT.NEWS .nd THE SUNDAY PATRIOT.NEWS were ealabllahed Maroh 4th, 1854, and September 18th, lQ411, reapecl/vely, and .11 have been oontlnuoualy publllhed Iver Ilnol; Thll the printed notice or publlc.tion which I. lecurely Ill.ched h.reto I. exaclly ae printed and publl.hed In their ragular dally Indlor Sunday Ind Metro editlonallaauea which appllr.d on the 21., and 28th day(.) 01 October Ind tha 4th dlY of November lllll7. Th.t n.lth.r h. nor ..Id Company I. Inlaraaled In the .ubJacl mailer 01 aald prlntad notice or advertl.lng, and that III of Ih. alleg.llona of thla .tatemant a. to Ihl time, pllce Ind chlr.cter of publlcal/on arl truI; and Thll he h.. per.onal knowledge 01 the lacta ,'orl8ald Ind I. duly lulhorlzed Ind empowered to verily thla .lltemant on behall 01 Thl P.trlot-News Co. alore..ld by virtue .nd pur.u.nl to . re.olullon un.nlmoualy p....d and adopled IIvar.11y by the Itockhold.ra and board of dlr.ctora 01 the laid Company and lub..quently duly recordld In thl olflce for the Racl)rdlng 01 Deeda In and lor ..Id County 01 Dauphin In Mlacellaneoua Book "1.1", Volume 14, P.ge 317. , ---7~ ~ PUBLICATION I /' -.,~..-- -~ ------ COpy L~worn lov.nd subacrl~ balor;;' m'),hlI)241h d'y~ ar 11197 AD. 8AlE .22 - / Nollllie' 5eo1 /, I>~~ NIt. II I T""Y l, /1u"oll, Nol..... P. ' . ..~ Hat,,!IlUfg, Dauphin CouOIr N A PUBLIC MyCommlS..o..E.poresJun ,199 I I I J 61MB lion exp rell une , "" , UontIiot.PIo...,_~..-\ No'~ aJMBERlAND COUNTY SHERIFFS OFACE <XUlT to.JSE CARLlSL E, P A. 17013 statement or Advertlllng Costs To THE PATRIOT.NEWS CO., Dr. For publishing th. nollc. or publication attach ad harelo on the abova statad dataa S Prob.tlng aama (1) Notary Faa(s) S Tolal S 211.58 1.00 212.58 By.................................................................... ~ G.E. CAPITAL MORTGAGE SERVICES, IN THE COURT OF COMMON PLEAS INC., SUCCESSOR IN INTEREST TO CUMBERLAND COUNTY, PENNSYLVANIA TRAVELERS MORTGAGE SERVICES, INC.: Plaintiff NO. 97 2164 CIVIL vs. CIVIL ACTION - LAW RICHARD LEE CLOUSER, Oefendant IN MORTGAGE FORECLOSURE PRAECIPE TO SATISPY To the Prothonotary: Please mark the judgment in the above-captioned Action in Mortgage Foreclosure satisfied. PURCELL, KRUG & HALLER J 1/'1 By 7l fJ liu< ~(. Leon P. Haller, Esquire ID #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 (Attorneys for plaintiff) DATED: September 2, 1999 "