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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Uegler
I, _ _ _ ___ __ ___ n__ _ __ ____ _ _ __ __ _ __ _ _ _______ _ _n_ ____u____ __ u__ __ uu__ __ __n_ _ _ Recorder 01
Deed. In and fur .aid Cuunty and Slale do hereby certify Ihallhe Sherlfr. Deed In which ___uu____u___
_!.!~}_l_~':!_~_~':!~_!l__~_______ .____nm____u_____ ______u______u__m__________u___ Is Ihe granlee
lhe .ame having been .old 10 .ald grantee on Ihe ___________lO.th_nu____u_u_u_u____u_____ day of
p.<t~~P.!>_'~L_____________.__.___n__u_n A. n., 19_2]_00__' under and by virtue of a wrilu____________
.!!_~~=~_t_~~~___u__ n_______. _ _ _ __ _n _ _ _ __ u __ _n i...ued on ,he - - - - __ __ ___ _~ ~!>_ _n_ __ ____ ___u______
day of ___~~p~_e_"!~!_r____u_______ A. n., 19_~_~__, oul of Ihe Court of Comman Pleu of said Counly a. of
_u___~ivll____u_______ __00' ___u____________ __n____u__ u_unuuu_n_____ Term, 19_?_~___
Number ___n~_J..'l2u__, allhe .uil of u.Md_tQ.lJ_!I-'!!]~_R.A__n_u__n____un_u_______________n___
_________m___m___m____ _ __ n __ agaiml_~! !.'~_~: ~_.!'_'!'!~ _t_"- ,,_~_~~'!.!'~_'!_~!<_~_~..i .!!.~~_.!'_'!'!~E_t_':_ Csl.man
Taylor & Walter Johnson
171 83
duly recurded In Sherifr. Deed Book No. u_nn___n' Page ____n_UU_.
IN TESTIMONY WHEREOF, I have hereunlo
",)....e
10' mgand and ..01 of said office IhiJ .,a___u___ day
ol/~~~~Z~l!~c~-m )~.~_ J.rm
1'fI of Deed..
~e'Drder of DesdJ, Cumbel1ll11l CGanty, ClrtIsls, PA
My Commil$ion upirss tht AI1IIIonday of Jan. 1998
,UlIlc...
Mellon BlIIlk N.A.
vs
Lindora Annette Johnson aIkIa Linda Annette
Colemllll-Tyler lIIld Walter Johnson
'f ';') 1'1 'i <i..J r.....-.
[n the Court of Common Pleas of
Cumberland County, Pennsylvania
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Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on October 9,
1997 he posted one of the properties of Lindora Annette Johnson aIkIa Linda Annette Coleman-
Tyler lIIld Walter Johnson at 146 West North Street, Carlisle, Cumberland County, Pennsylvllllia
with copy of Real Estate Writ Notice Poster and Description according to law. On October 9,
1997 at 2:40 o'clock P.M., E.D.S.T., he posted the second property of Lindora Annette Johnson
aIkIa Linda Annette Coleman-Tyler lIIld Walter Johnson at 55 Baltimore Street, Carlisle,
Cumberllllld County, Pennsylvania. He posted the third property of Lindora Annette Johnson
aIkIa Linda Annette Coleman Tyler and Walter Johnson at 333 North West Street, Carlisle,
Cumberland County, Pennsylvania with a copy of Real Estate Writ Notice Poster lIIld
Description according to law.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on Oetober 9,
[997 at 8:38 o'clock P.M., E.D.S.T., he served true copies of Real Estate Writ Notice, Poster and
Description in the above entitled action upon one of the within named defo::ndants, to wit:
Lindora Annette Johnson alkla Linda Annette Coleman-Tyler by making known unto her room
mate (who would not give her name) for Lindora Annette Johnson aIkIa Linda Annette Colemllll-
Tyler at 1416 Bradley Drive Apt. 212, Carlisle, Cumberland County, Pennsylvania ils contents
lIIld at the same time handing to her personally the said true and attested copies of the same.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on October 9,
1997 at 1:53 o'clock P.M., E.D.S.T., he served true copies of Real Estate Writ, Notice, Poster lIIld
Description in the above entitled action upon one of the within named defendants, to wit: Walter
Johnson by making known unto Walter Johnson at 333 N, West Street, Carlisle, Cumberllllld
County, Pennsylvania its contents and atthc same time handing to him personally the said true
lIIld attested copies oflhe same.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the
above Real Estate Wril, Notice Poster and description in the following mllllner: The Sheriff
mailed one of the within named defendants, to wit: Lindora Annette Johnson aIkIa Linda Annette
Colemllll-Tyler a notice oflhe pendency of the action by regular mail to her last known address
at 1416 Bradley Drive Apt. 212, Carlisle, Pennsylvania 17013. This letter was mailed under the
date of October 120, 1997 and was never returncd to the Sheriffs Officc.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says lhat he served the
above Real Estate Wril, Notice, Poster and Description in the following manner: The Sheriff
mailed one oflhe wilhin named defendanls, to wit: Walter Johnson a nolice of the pendency of
the action by regular mail to his last known address at 1416 Bradley Drive Apt. 212, Carlisle,
Pennsylvllllia 17013. This letter was mailed under thc date of October 10, 1997 and was never
returned to thc Sheriffs Office.
R. Thomas Kline, Sheriff who being duly sworn according to law, says that after due lIIld
Icgal notice had been given according to law, cxposed the within described premises at public
venue or outcry at thc Court Housc, Cumberland Counly, Pennsylvania on December 10, 1997 at
10:00 A.M. E.S.T. and sold the same for the sum of 1.00 10 Attorney Craig J. Staudenmaier for
Mellon Bank, N.A.,lts successors and assigns at Two Mellon Bank Center, Pittsburgh, PA 15259.
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It being the highest bid and best price received for same Mellon Bank. N.A.. Its successors and
assigns at Two Mellon Bank Center. Pittsburgh. PA 15259 being the buyer on this Execution
paid SheriffR. Thomas Kline the sum of$ 880.33 it being poundage etc. Sheriffs Costs listed
below.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging deed
Auctioneer
Law Library
County
Mileage
Cert Mail
Levy
S urchurge
Law Journal
Patriot News
Distribution of Proceeds
Shure of bills
Sheriffs Deed
30.00
17.26
45.00
45.00
30.00
10.00
.50
1.00
6.20
.50
45.00
6.00
305.00
261.40
25.00
26.97
~
880.33 pd by atty 12-\0-97
Sworn and subscribed to before me
;~~,~~~,
R. Thomas Kline. Sheriff
By -t~~ 1.f!.dt;-
Deputy Sheriff
'I,"
This ..1 ~' ~ day of 199'1-.)""'~r
U,!-" Q. )"\.1.J.e,,-- o.J.pfi I
Prilthbnotary .
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WRIT OF EXECUTION and/or ATIACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 97-2199 CIVIL we Term
CIVIL ACTION. LAW
TO THE SHERIFF OF
CuttJer1and
COUNTY:
To satisfy the debt, Inlerest and cosls due Mellon Bank, N.A.
PLAINTIFF(S)
lrom Lindora Annette Johnson a/k/a Linda Annette Coleman-Tyler and Walter Johnson
DEFENDANT(S)
(1) You are directed to lavy upon the properly 01 the defendant(s) and to sell Arltlress of Mortaaaed
~rties: 146 West NOrth Street. 55 Baltimore Street and 333 North West Street.
Carlisle. Cumberland Countv. Pennsylvania 17013
(2) You are also directed to attach the properly 01 the delendant(s) not levied upon In the possession 01
GARNISHEE(S) as lollows:
and to notlly the garnlshee(s) that: (a) an attachment has been Issued; (b) the garnlshee(s) ISfare enjoined lrom paying any
debt to or lor the account 01 the delendant(s) and Irom delivering any properly of the defendant(s) or otherwise disposing
thereol;
(3) II properly 01 the delendant(s) not levied upon an subject to attachment Is found Inthe possession 01 anyone other
than a named garnlshae, you are directed to notlly him/her that he/she has been added as a garnishee and Is enjoined as above
stated.
AmountOue $16,778.97
Interest through 12-10-97
Atty's 00lJIlI0 Fee
Any Paid
Plaint III Paid
$2,946.16
$8.500.00
$106.20
L.L. $.50
Due Prolhy $1.00
Other Costs
Date:
September 5, 1997
Lawrence E. Welker, Prothonotary
Prothonotary, Civil Division
by:
'1"~1L~ ~ ~~ ifl
D.puly
.
REQUESTING PARTY:
NAUMAN, SMITH, SHISSLER & HALL
Name ("r~i~.l C:r;t"n,::anl'1'\Ripr, F.R'1
Addrass: lllO.. North Third St. P.O. Box 840
Harrisburg. PA 17108
Attorney lor: Plilintiff
Telephone: (7171 236-3010
Supreme Court 10 No. 34996
REAL (vr,~TE S,f. I"~"~ .
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lIJIF/FOft
On ...g'Ft 't. I )l\'"J
the sheriff levied upon the defendani~
Interest In the real property situated In (~,. ~,t'. 4:l"1< J ..J
1"1 {,J 'YI. t' j.. ,...,. k (J.,U~~ L..
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Cumberland County, Pa.. known and numbered as: 3 .~..;- '/1 li)Y~;"..!L.
(I(\J.', c.
and more fully described on Exhibit "A' I flied wl:!1
this writ and by this reference incorporated herein.
Oifte: 9 -6- 17
By: Cr1l('[" A
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MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97.2199
LlNDORA ANNETTE JOHNSON alkla
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON, : CIVIL ACTION - LAW
Defendants : MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1
Mellon Bank, N.A., Plaintiff in the above captioned proceeding, sets forth as of the date the
Praecipe for Writ of Execution was filed, the following information concerning the real properties
located at 146 West North Street, 55 Baltimore Street and 333 North West Street, Carlisle,
Cumberland County, Pennsylvania 17013.
1. Name and last known address of Owner(s) or Reputed Owner(s):
Walter Johnson
333 North West Street
Carlisle, PA 17013
Lindora Annette Johnson a/k1a
Linda Annette Coleman-Tyler
1416 Bradley Drive, Apt 212
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment Is a record
lien on the real property to be sold:
Orlean S. Elliot
2014 Franklin Ayenue
Harrisburg, PA 17109
Commonwealth of Pennsylyania
c/o Dale F. Shughart, Jr.
28 South Pitt Street
Carlisle, PA 17013
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James Costopoulos
860 Easy Road
Carlisle, PA 170n
James Costopoulos
13 S. HanoYer Street
Carlisle, PA 17013
"
Borough of Carlisle
53 West South Street
Carlisle, PA 17013
j.'-
4. Name and address of the last recorded holder of every mortgage of record:
Mellon Bank, N,A.
(executing creditor)
c/o Nauman, Smith, Shissler & Hall
200 North Third Street
Post Office Box 840
Harrisburg, PA 17108
Attention: Craig J. Slaudenmaler, EsquIre
5. Name and address of every other person who has any record lien on the property:
None.
6. Name and address of every other person who has any record interest in the property
and whose interest may be affected by the sale:
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Cumberland County Tax Assessment Office
One Courthouse Square
Carlisle, PA 17013
I, Craig J. Staudenrnaier, Esquire, allorney for Mellon Bank, N.A. hereby slate that the
statements made in this affidavit are true and correct to the best of my personal knowledge or
infonnation and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. 14904 relating to unsworn falsific~tion to authorities.
NAUMAN, SMITH, SHISSLER & HALL
Craig J. S
Date: September 4, 1997
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L"w O~"CES
N.A~. .s'IJ~II. 811....1.11I11 lit U.ALL
200 NORTH THIRD STR!n-
P. O. Bo. 840
H"RRf.aURa, PENNSYLV"N'" 17'08-08040
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MELLON OANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMOERLAND COUNTY, PENNSYLVANIA
Y.
: NO. 97.2199
L1NDORA ANNETfE JOHNSON elk/a
LINDA ANNETfE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 3129.21cH21
AND NOW, this ~ day of September, 1997, Craig J. Staudenmaler, Esqulre, of the
fino of NAUMAN, SMITH, SlDSSLER & HALL, attorneys for Mellon Bank, N.A., Plaintiff,
hereby certifies that he served the person(s) listed below whose name appears in the Affidavit filed
in this proceeding pursuant to Pa. R.C.P. 3129.1 attached hereto as Exhibit "A", with the Notice
of Sale and legal description of the property to be sold also filed in this maller, attached hereto as
Exhibit "0", by depositing the same in the United States Mail at the Post Office in Harrisburg,
Pennsylvania, first class, with certificates of mailing (postal forms 3817) and contained within
envelopes bearing his return address. A copy of the certificate of mailing is attached hereto and
marked Exhibit .C..
Orlean S. Elliot
2014 Franklin Avenue
Harrisburg, PA 17109
Commonwealth of Pennsylvania
c/o Dale F. Shughart, Jr., Esquire
28 South Pitt Street
Carlisle, PA 17013
James Costopoulos
860 East Road
Carlisle. PA 17013
James Costopoulos
13 South Hanover Street
Carlisle, PA 17013
Cumberland County Tax Assessment Office
One Courthouse Square
Carlisle, PA 17013
Borough of Carlisle
S3 West South Street
Carlisle, PA 17013
NAUMAN, SMITH, SHISSLER & HALL
Craig J. Sta aler, EsquIre
Supreme Court D #34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
(717) 236-30 \0
Counsel for: Mellon Bank. N .A.. Plaintiff
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MELLON BANK. N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
f
: NO. 97-2199
UNDORA ANNETTE JOHNSON a/kla
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1
Mellon Bank, N.A., Plaintiff in the above captioned proceeding, sets forth as of the date the
Praecipe for Writ of Execution was filed, the following lnfonnation concerning the real properties
located at 146 West North Street, 55 Baltimore Street and 333 North West Street, Carlisle.
Cumberland County, Pennsylvania 17013.
1. Name and last known address of Owner(s) or Reputed Owner(s):
Wal'.er Johnson
333 North West Street
Carlisle, PA 17013
Lindora Annelle Johnson a/kla
Linda Annette Coleman-Tyler
1416 Bradley Drive, Apt 212
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Same as No.1 above.
3. Name and last known address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Orlean S. Elliot
2014 Franklin Avenue
Harrisburg, PA 17109
Commonwealth of Pennsylvania
c/o Dale F. Shughart, Jr.
28 South Pill Street
Carlisle. PA 17013
EXHIBIT
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James Coslopoulos
860 Easy Road
Carlisle, PA 17013
James Costopoulos
13 S. Hanover Street
Carlisle, PA 17013
Borough of Carlisle
53 West South Street
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
Mellon Bank, N .A.
(executing creditor)
c/o Nauman, Smith, Shissler & Hall
200 North Third Street
Post Office Box 840
Harrisburg, PA 17108
Attentlon: Craig J. Staudenmaler, Esquire
S. Name and address of every other person who has any record lien on the property:
None.
6. Name and address of every other person who has any record Interest in the property
and whose interest may be affected by the sale:
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Cumberland County Tax Assessment Office
One Counhouse Square
Carlisle, PA 17013
'.
I, Craig J. Staudenmaier, Esquire, attorney for Mellon Bank, N.A. hereby state that the
statements made In this affidavit are true and correct to the best of my personal knowledge or
Infonnation and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. fi4904 relating to unsworn falsification to authorities.
NAUMAN, SMITH, SHISSLER & HALL
Date: September 4, 1997
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MELLON BANK, N.A.,
Plaintiff
: iN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-2199
l.INDORA ANNETTE JOHNSON elk/a
UNDA ANNETTE COLEMAN-TYLER
and W ALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
NOTICE OF SALE PURSUANT TO PA. R.C.P. 3129.1
TO: Waller Johnson and Lindora Annette Jolmson elk/a Linda Annette Coleman-Tyler,
Mortgagors and real owners and all lienholders and other parties in inlerest
PROPERTY TO BE SOLD:
146 West North Street,
Tax Parcel No.5 (201798) 326; and
55 Baltimore Street,
Tax Parcel No.4 (210320) 612; and
333 North West Street,
Tax Parcel No.5 (201798) 56,
Carlisle, PA 17013, Cumberland County
YOU ARE HEREBY notified that Mellon Bank, N.A. has issued an execution against
your properties with structures erected thereon situated at 146 West North Street, 55 Baltimore
Street and 333 North West Street, Carlisle, Cumberland County, Pennsylvania 17013. This
execution is being issued pursuant to the judgment of the Court of Common Pleas of Cumberland
County entered against you by Mellon Bank, N.A. on June 12, 1997, to No. 97-2199 Civil Tenn.
Unless the debt, interest, and costs are paid in full prior to the date of sale, said property will be
sold at public sale by the Sheriff of Cumberland County at the Courthouse in Carlisle,
Pennsylvania on December 10, 1997, at \0:00 a.m.
The property to be sold is described in detail in a legal description attached hereto which
sets forth the boundaries of the property to be sold, together with a brief mention of the buildings
and any other major improvements upon the land. (SEE ATTACHED DESCRIPTION)
NOTICE is further given to all parties in inlerest and claimants. A proposed schedule of
distribution of the proceeds of the above sale will be filed by the Sheriff of Cumberland County,
Pennsylvania on January 8, 1997 and distribution will be made in accordance with said proposed
schedule of distribution unless exceptions are filed thereto within ten (10) days thereafter.
EXHIBIT
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THIS NOTICE IS GIVEN PURSUANT TO RULE 3129.1 OF THE PENNSYLVANIA
RUL.E OF CIVIL PROCEDURE. THIS PAPER IS A NOTICE OF THE TIME AND PLACE
OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE MELLON BANK,
N.A. HAS ENTERED A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY
TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS
TO PREVENT YOUR PROPERTY FROM BEING TAKEN. A LAWYER CAN ADVISE YOU
MORE SPECIFICALLY OF THE RIGHTS YOU MAY HAVE. IF YOU WISH TO EXERCISE
YOUR RIGHTS, YOU SHOULD DO SO IMMEDIATELY. IF YOU HA VB ANY QUESTIONS
CONCERNING THIS NOTICE OR YOUR RIGHTS REGARDING THE SALE OF YOUR
PROPERTY, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, YOU SHOULD GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
OBTAIN LEGAL HELP.
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Cumberland County Lawyer Referral Service
Court AdmInistrator
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone No: (717) 240-6200
YOU MA Y HAVE THE FOLLOWING LEGAL RIGHTS IN THIS PROCEEDING:
1. You may file a petition with the Court of Common Pleas of Cumberland County to open
the judgment if you have a meritorious defense against the person or company that has entered
judgment against you. You may also file a petition with the same Court if you are aware of a legal
defect in the obligation or the procedure used against you.
2. After the Sheriffs sale you may file a petition with the Court of Common Pleas of
Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause.
This petition must be filed before the Sheriffs Deed is delivered.
3. These rights must be asserted by filing a petition or petitions raising the legal issues or
rights mentioned above with the Court of Common Pleas of Cumberland County located In
Carlisle, Pennsylvania. If you have any questions concerning these 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 above.
.
REAL ESTATE SALE NO 20
$1,000.00 Advance Costs Paid 9-09-97 Ally.Craig 1. Staudenmaier
Assessed Valuation $ $2,400.00 tract I
$1,810.00 tract 2 $2,080.00 Tract 3
W;it No. 97-2199 Civil
Mellon Bank, N,A.
Vs
Lindora Annell Johnson a.k.a Linda Coleman Tyler and
Walter Johnson
146 W. North St., 55 Baltimore St., 333 N. West St.,
Carlisle, Pa. 17013
I'
REAL DEBT
INTEREST
ATTY'S FEES
WRIT COSTS A TTY
16,778.97
2,946.17
8,500.00
106.20
ESCROW
LATE CHARGE
SHERIFF'S COSTS
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
County
Mileage
Cert Mail
Levy
Postpone Sale
Surcharge
30.00
45.00
45.00
30.00
10.00
.50
1.00
6.20
.50
45.00 it
6.00
Legal Seurch
ADVERTISING:
Law Journal
Patriot
Share of Bills
Distribution of Proceeds
Sheriffs Deeds
STAMPS
Pa. Transfer Ta.'(
Twp or Boro Transfer Tax
TAXES
1997 Co Twp & School 146 W. North
305.00
2~k4f
25.00
25.50
470.64
. ,,0
3 o~
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LA W JOURNAL
(Under Act No. 5H7, upproved Muy Hi, 1929), P. L.17H4
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
---- ....
'Jal, Esquire, Editor of the Cumberlund Law Journul. of the County
ly sworn, uccording toluw, deposes and suys thutthe Cumberlund
al published in the Borough of Curlisle in the County and State
lUary 2, 1952, und designated by the local courts as the officiul
alion of all legal notices, and has. since January 2, 1952, been
, said County, and that the printed notice or publication attached
vas printed in the regular editions and issues of the said
he following dates,
RIO. 17.24.1997
that he is authorized to verify this stutement by the Cumberlund
of geneml circulution, und that he is not interested in the subject
. advertisement, und that all allegations in the foregoing
character of publication are true.
SWORN TO AND SUBSCRIBED before me this
24 day of OCTOBER. 1997
HOT AllIAl S AI.
LOIS E SNYOER. Notary ""bile
Cortld. Ioro, Cumberlal"d County, PA
My CO",l1'IiMion bpi'" Marth~. 2001
NOV.
OCT.
OCT.
,
: I INC:I'IIS "l.'I'";..IOqu. '[he :@atriot Phlln" H'."ll.lfl
I ,.. I ~'C",-u~ A\CIJUnllnlC (Xrl. 1\\,HI17
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I; , I '[he 3:\Jcning Re\\1S
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4, I Compl.t" Cl)v.ra~e of Pennsylvania's Third Largest
I sl ! 1 and ~I05t ProO table Market
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: el 1 CUMB020 OCT [, NOV 1997, _
121 ,
, CUMBERLAND CO SHERIFFS OFFICE
81 I COURT HOUSE
,
9! I CARLISLE, PA 17013
,101 1 I
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121 1 1 jJf DAIl.Y"ATII: ~ttJ 40
131 I I INCHIJ . 1 n R c; Jill" INCH
i 14: I I NOTARY I.ESS ,po DAILY 1 00
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i Isl I NET DAILY ...26 I
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i 121 , I SALE NO. "ztJ
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All Old\'ertising recei,'ed subject to appro\'al by Publisher.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publlciltlon
Undtf Act No 587 Aootovtd May Ie tD211
Commonwulth 01 PennaylVlnla, County of Dauphin) u
FnlnkJ. Epl.r being duly sworn according to law, depos.. and says:
That ha la the Controllar 01 THE PATRIOT.NEWS CO., a corporation organl.lld and ul.tlng und.r tha lawa 01 the
Commonwaallh 01 Pannsylvanla, wllh lis principal olllce and plac. 01 bu.ln... at BI2 to BIB Mark.t Strut, In the
City of Harrisburg, Counly 01 Oauphln, Stat. 01 P.nnsylvanla, own.r and publlshar 01 THE PATRIOT.NEWS and THE
BUNDAY PATRIOT.NEWS newspap.rs 01 general circulation, prlntad and publlsh.d at 812 to BIB Market Street, In
the Clly, County and State aloresald; that THE PATRIOT.NEWS and THE SUNOAY PATRIOT.NEWS w.re IItabllahed
March 4th, 1 Bll4, and September lBth, 111411, rllp.cUv.ly, and all have blln contlnuoualy publl.h.d .ver .Ince;
That the printed notice or publlcetlon which la ..cur.1y altach.d h.r.to la .xactly II prlnt.d and publlahed In
thalr regular dally and/or Sunday and Metro .dltlontllllu.a which app.ar.d on lh. 21at and 2Bth day(a) 01 October
and th. 4th day of Novamber 111117. That nallher he nor aald Company la Int.rlltad In the aUbJ.ct matter 01 aald
printed notice or advertlalng, and that all 01 the allegatlona 01 Ihla stst.m.nt II to th. tlm., place and character of
publication ar. true; and
That he hae p.raonal knowledge 01 the facta alorllald and I. duly authorlz.d and .mpow.red to verily this
atatement on behalf of The Patrlot.News Co. aforllald by virtu. and purauant to a rllolutlon unanimously passed and
adopted aeverally by the stockholders and board of dlr.ctors 01 Ih. tlld Company and ,ubl8quently duly recorded In
the ottlce for the Recording 01 Daeds In end lor said Ccunty 01 Oauphln In Mlsc.llan.ous Book "M",
Volume 14, Page 317. _ -" ..L' E:....~
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PUBLICATION
COpy
SALE 120
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CUMBERLAND COUNTY SHERIFFS OFACE
COJRT I-OJSE
CARLISLE, PA. 170t3
~t.t.m.nt Or Advertlllng COltl
To THE PATRIOT.NEWS CO" Or.
For publishing th. notlca or publication attached hereto
on tha above .'at.d datil S
Probating aam. (1) Notary Fee(s) S
Total S
2BO.40
1.00
281.40
IN TIlE COURT OF COMMON PI.F:AS OF 'I'm: ClJI\IIII':IU.ANU l:OUNTY, I'F:NNSYI.V ANIA
v.
LlNDORA ANNETTE JOHNSON a/kill
LINDA ANNETTE COLEMAN.TYU:R
and WALTER JOHNSON,
Defendanls
Writ Nn. Term 19
Nn, -21!llJ Civil Term Term 19...2L
l'IiruJDlIL S 16,778.97 Y
lntI:I~UluuuWh 12/10/97 2.946 16
AllilUll:)'lil:1:~ 8.500.00
MELLON BANK, N.A.,
Plaintiff
TOTAl.
$28,225.13
PRAECIPE I'OR WRIT m' EXECUTION. (MORTGAGE Jo'ORECLOSURE)
1',R,C,I'.3180-3183
TO THE PROTHONOTARY OF l:UMIIJo:RLANJ) COUNTY
Please issue writ nf e~ecullnn in Ihe uhnvc cupllnned cuse,
Address or MortllBlled l'rllJK'rlles: 146 Wesl Nurlh Slreet, 55 lIaltimore Street and 333 North West
Street, Carlisle, Cumberland CnulUy. I'ennsylvllnhl 17013.
Date:
'\\"\\C\~
, \
CrlllllJ,
Supreme ,nurt 10# 34996
NAUMAN, SMITII, SHISSLER & HALl.
20() Nurlh Third Street
1',0, J1n~ K40
IIl1rrlshurll.I'A 17108
'I'elephnne: (717) 236-3010
WHIT 010' EXECUTION
COMMONWEALTII OF JlJiNNSYl.VANIA )
) ss:
COUNTY OF ClJMIlJiRLANU )
TO TIlE CUMDJo:RI.ANJ) COUNTY Sm:RIJo'Io'
'I'll slllisfy Ihe judwmelll. interest and ClIsts in the above-captioned case, you are directed to levy
uplln and selllhe prll(lCrty descrihed In the llllllChcd description.
Dutc:
Prothonolary
by:
Deputy
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200 NORTH THIRD STRUT
POBox 840
HARRISBURG, PENNSYLVANIA 1710a.0840
,
-,
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, 97-2199
LlNDORA ANNETTE JOHNSON a/kla
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
I, Craig J. Staudenmaier, Esquire, allorncy for Mellon Bank, N.A., Plaintiff, hereby state
that, to the best of my knowledge, information and belief, Lindora Annelle Johnson a/kla Linda
Annette Coleman-Tyler and Walter Johnson, Defendants, are currently not in the military or naval
service, based upon the following facts: Last known place of Residence:
Lindora Annelle Johnson a/kla
Linda Annette Coleman-Tyler
1416 Bradley Drive, Apt 212
Carlisle, PA 17013
Walter Johnson
333 North West Street
Carlisle, PA 17013
I verify that the statements made in this Affidavit are true and correct. I understand that
false statement herein are made subject to the penalties of 18 Pa.C.S. fi4904, relating to unsworn
falsification to authorities.
NAUMAN, SMITH, SHISSLER & HALL
Date: September 4, 1997
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-2199
LlNDORA ANNETTE JOHNSON a/k/a
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION . LAW
: MORTGAGE FORECLOSURE
NOTICE OF SAI.E PURSUANT TO PA. R.C.P. 3129.1
TO: Walter Johnson and Lindora Annette Johnson alkla Linda Annette Coleman-Tyler,
Mortgagors and real owners and all lienholders and other parties in interest
PROPERTY TO BE SOLD:
146 West North Street,
Tax Parcel No.5 (201798) 326; and
55 Baltimore Street,
Tax Parcel No.4 (210320) 612; and
333 North West Street,
Tax Parcel No.5 (201798) 56,
Carlisle, PA 17013, Cumberland County
YOU ARE HEREBY notified that Mellon Bank, N.A. has issued an execution against
your properties with structures erected thereon situated at 146 West North Street, 55 Baltimore
Street and 333 North West Street, Carlisle, Cumberland County, Pennsylvania 17013. This
execution is being issued pursuant to the judgment of the Court of Common Pleas of Cumberland
County entered against you by Mellon Bank, N.A. on June 12, 1997, to No. 97-2199 Civil Term.
Unless the debt, interest, and costs are paid in full prior to the date of sale, said property will be
sold at public sale by the Sheriff of Cumberland County at the Courthouse in Carlisle,
Pennsylvania on December 10, 1997, at 10:00 a.m.
The property to be sold is described in detail in a legal description allached hereto which
sets forth the boundaries of the propeny to be sold, together with a brief mention of the buildings
and any other major improvements upon the land. (SEE ATTACHED DESCRIPTION)
NOTICE is further given to all panies in interest and claimants. A proposed schedule of
distribution of the proceeds of the above sale will be filed by the Sheriff of Cumberland County,
Pennsylvania on January 8, 1997 and distribution will be made in accordance with said proposed
schedule of distribution unless exceptions are filed thereto within ten (10) days thereafter.
THIS NOTICE IS GIVEN PURSUANT TO RULE 3129.1 OF THE PENNSYLVANIA
RULE OF CIVIL PROCEDURE. THIS PAPER IS A NOTICE OF THE TIME AND PLACE
OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE MELLON BANK,
N.A. HAS ENTERED A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY
TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS
TO PREVENT YOUR PROPERTY FROM BEING TAKEN. A LAWYER CAN ADVISE YOU
MORE SPECIFICALLY OF THE RIGHTS YOU MAY HAVE. IF YOU WISH TO EXERCISE
YOUR RIGHTS, YOU SHOULD DO SO IMMEDIATELY. IF YOU HAVE ANY QUESTIONS
CONCERNING THIS NOTICE OR YOUR RIGHTS REGARDING THE SALE OF YOUR
PROPERTY, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, YOU SHOULD GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
OBTAIN LEGAL HELP.
Cumberland County Lawyer Referral Service
Court AdmInIstrator
Cumberland County Courthouse
Carlisle, PennsylvanIa 17013
Telephone No: (717) 240-6200
YOU MAY HAVE THE FOLLOWING LEGAL RIGHTS IN THIS PROCEEDING:
1. You may file a petition with the Court of Common Pleas of Cumberland County to open
the judgment if you have a meritorious defense against the person or company that has entered
judgment against you. You may also file a petition with the same Court if you are aware of a legal
defect in the obligation or the procedure used against you.
2. After the Sheriff's sale you may file a petition with the Court of Common Pleas of
Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause.
This petition must be filed before the Sheriff's Deed is delivered.
3. These rights must be asserted by filing a petition or petitions raising the legal issues or
rights mentioned above with the Court of Common Pleas of Cumberland County located in
Carlisle, Pennsylvania. If you have any questions concerning these 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 above.
A copy of the Writ of Execution for your property is attached hereto.
i
NAUMAN, SMITH, SHISSLER & HALL
udenmaier, Esquire
urt ID #34996
200 North Third Street
Post Office Box 840
Harrisburg, PA 17108
Telephone: (717) 236-3010
Counsel for: Mellon Bank, N.A., Plaintiff
cc: Al1lienholders of record
ALL those certain tracts with dwellings erected thereon situate in the Borough of
Carlisle, Cumberland County. Pennsylvania as bounded and described as follows:
TRACT I: On the South side by Baltimore Street; and the East by property of heirs of
Rachael Whiting; on the North by property now or late of C. Shapley's heirs and on the West
by property of John R. Hunter. having a frontage of seventeen (17) feet and six (6) inches on
said Baltimore Street and extending at an even width one hundred fifteen (115) feet. Being
known and numbered as 55 Baltimore Street, Carlisle, Pennsylvania.
BEING known as Parcel No.4 (210320) 612.
TRACT 2: On the West by North West Street; on the North by lot now or late of the heirs
of Charles Shapley, deceased; on the South by lot now or late of Calvin H. Garlick.
Containing in front on said West Street 14 feet and in depth 100 feet, more or less and being
improved with a two story frame dwelling house known and numbered as 333 North West
Street, Carlisle, Pennsylvania.
BEING known as Parcel No.5 (201798) 56.
TRACT 3: On the North by West North Street. on the East by an alley, on the South by an
alley, and on the West by land now or formerly of Lawton C. Rovegno and Evelyn B.
Rovegno, his wife, CONTAINING 20 feel in front on West North Street and extending in
depth 120 feet, more or less, to the alley on the South. Having thereon erected a 2 story frame
dwelling, known as 146 West North Street.
BEING known as Parcel No.5 (201798) 326.
SEIZED and taken in execution by the Sheriff of Cumberland County to be sold as the
property of Lindora Annette Johnson a/kla Linda Annette Coleman-Tyler and Walter Johnson,
mortgagors and real owners, under judgment No. 97-2199 in the Court of Common Pleas of
Cumberland County, Carlisle, Pennsylvania.
NOTICE is further given to all parties in interest and claimants. A proposed schedule
of distribution of the proceeds of the above sale will be filed by the Sheriff of Cumberland
County, Pennsylvania on January 8, 1997 and distribution of said proceeds will be made in
accordance with said proposed schedule of distribution unless exception.~ are filed thereto
within ten (10) days thereafter
James Costopoulos
860 Easy Road
Carlisle, PA 17013
James Costopoulos
13 S. Hanover Street
Carlisle, PA 17013
Borough of Carlisle
.53 West South Street
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
Mellon Bank, N.A.
(executing creditor)
c/o Nauman, Smith, Shissler & Hall
200 North Third Street
Post Office Box 840
Harrisburg, PA 17108
Attention: CraIg J. Staudenmaler, EsquIre
.5. Name and address of every other person who has any record lien on the property:
None.
6. Name and address of every other person who has any record Interest in the property
and whose Interest may be affected by the sale:
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest In the property which may be affected by the sale:
Cumberland County Tax Assessment Office
One Courthouse Square
Carlisle, PA 17013
I, Craig 1. Staudenmaier, Esquire, allomcy for Mellon Bank, N.A. hereby state that the
statements made in this affidavit are true and correct to the b:st of my personal knowledge or
infonnation and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. 14904 relating to unsworn falsification to authorities.
NAUMAN, SMITH, SHISSLER & HALL
Craig J. St udenmaler, Esquire
Date: September 4, 1997
'i
<,
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY , PENNSYLVANIA
v.
: NO. 97-2199
L1NDORA ANNETTE JOHNSON a/k/a
LINDA ANNETTE COLEMAN-TYLER
and W ALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. JI29.2(cH2)
AND NOW, this ~ day of September, 1997, CraIg J, Staudenrnaler, EsquIre, of the
firm of NAUMAN, SMITH, SHISSLER & HALL, allorneys for Mellon Bank, N .A., Plaintiff,
hereby certifies that he served the person(s) listed below whose name appears in the Affidavit filed
in this proceeding pursuant to Pa. R.C.P. 3129.1 allached hereto as Exhibit "A", with the Notice
of Sale and legal description of the property to be sold also filed in this maller, attached hereto as
Exhibit "B", by depositing the same in the United States Mail at the Post Office in Harrisburg,
Pennsylvania, first class, with certificates of mailing (postal forms 3817) and contained within
envelopes bearing his return address. A copy of the certificate of mailing is attached hereto and
marked Exhibit "C".
Orlean S. Elliot
2014 Franklin Avenue
Harrisburg, PA 17109
Commonwealth of Pennsylvania
c/o Dale F. Shughart, Jr., Esquire
28 South Pitt Street
Carlisle, PA 17013
James Costopoulos
860 East Road
Carlisle, PA 17013
James Costopoulos
13 South Hanover Street
Carlisle, PA 17013
Cumberland County Tax Assessment Office
One Courthouse Square
Carlisle, PA 17013
Borough of Carlisle
53 West South Street
Carlisle, PA 17013
j'
NAUMAN, SMITH, SHISSLER & HALL
,--
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
(717) 236-30\0
Counsel for: Mellon Bank, N.A., Plaintiff
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-2199
UN DORA ANNETTE JOHNSON a/k1a
LlND~ Ar-'i'lETTE COLEMAN-TYLER
and WALTER JOHNSON,
Ii:, Defendants
"
,
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1
Mellon Bank. N.A., Plaintiff in the above captioned proceeding, sets forth as of the date the
Praecipe for Writ of Execution was filed, the following information concerning the real properties
located at 146 West North Street, 55 Baltimore Street and 333 North West Street, Carlisle,
Cumberland County, Pennsylvania 17013.
1. Name and last known address of Owner(s) or Reputed Owner(s):
Walter Johnson
333 North West Street
Carlisle, PA 17013
Lindora Annette Johnson a/k1a
Linda Annette Coleman-Tyler
1416 Bradley Drive, Apt 212
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Same as No. I above.
3 Name and last known address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Orlean S. Elliot
2014 Franklin Avenue
Harrisburg, PA 17109
Commonwealth of Pennsylyania
c/o Dale F. Shughart, Jr.
28 South Pitt Street
Carlisle, PA 17013
EXHIBIT
I~"
James Costopoulos
860 Easy Road
Carlisle, PA 17013
James Costopoulos
13 S. Hanover Street
Carlisle, PA 17013
Borough of Carlisle
S3 West South Street
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
Mellon Bank, N.A.
(executing creditor)
c/o Nauman, Smith, Shissler & Hall
200 North Third Street
Post Office Box 840
Harrisburg, PA 17108
Attention: Craig J. Staudenmaler, Esquire
S. Name and address of every other person who has any record lien on the property:
None.
6. Name and address of every other person who has any record interest in the property
and whose interest may be affected by the sale:
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Cumberland County Tax Assessment Office
One Courthouse Square
Carlisle, PA 17013
t:
p
I, Craig J. Staudenmaier, Esquire, a,torney for Mellon Bank, N.A. hereby state that the
statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. 14904 relating to unsworn falsification to authorities.
""
NAUMAN, SMITH, SHISSLER & HALL
Crnlg J. 81 udenmnler, Esquire
Date: September 4, 1997
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-2199
UNDORA ANNETIE JOHNSON alk/a
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
NOTICE OF SAI,E PURSUANT TO PA. R.C.P. 3129.1
TO: Walter Johnson and Lindora Annette Johnson aIkIa Linda Annette Coleman-Tyler,
Mortgagors and real owners and all lienholders and other parties in interest
PROPERTY TO BE SOLD:
146 West North Street,
Tax Parcel No.5 (201798) 326; and
55 Baltimore Street,
Tax Parcel No.4 (210320) 612; and
333 North West Strer.t,
Tax Parcel No.5 (201798) 56,
Carlisle, PA 17013, Cumberland County
YOU AU HEREBY notified that Mellon Bank, N.A. has issued an execution against
your properties with structures erected thereon situated at !46 West North Street, 53 Baltimore
Street and 333 North West Street, Carlisle, Cumberland County, Pennsylvania 17013. This
execution is being issued pursuant to the judgment of the Court of Common Pleas of Cumberland
County entered against you by Mellon Bank, N.A. on June 12, 1997, to No. 97-2199 Civil Term.
Unless the debt, interest, and costs are paid in full prior to the date of sale, said property will be
sold at public sale by the Sheriff of Cumberland County at the Courthouse in Carlisle,
Pennsylvania on December 10, 1997, at 10:00 a.m.
The property to be sold is described in detail in a legal description attached hereto which
sets forth the boundaries of the property to be sold, together with a brief mention of the buildings
and any other major improvements upon the land. (SEE ATTACHED DESCRIPTION)
NOTICE is further given to all parties in interest and claimants. A proposed schedule of
distribution of the proceeds of the above sale will be filed by the Sheriff of Cumberland County,
Pennsylvania on January 8, 1997 and distribution will be made in accordance with said proposed
schedule of distribution unless exceptions are filed thereto within ten (10) days thereafter.
EXHIBIT
I \1.B"
THIS NOTICE IS GIVEN PURSUANT TO RULE 3129,1 OF THE PENNSYLVANIA
RULE OF CIVIL PROCEDURE. THIS PAPER IS A NOTICE OF THE TIME AND PLACE
OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE MELLON BANK,
N.A. HAS ENTERED A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY
TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS
TO PREVENT YOUR PROPERTY FROM BEING TAKEN. A LAWYER CAN ADVISE YOU
MORE SPECIFICALLY OF THE RIGHTS YOU MA Y HAVE. IF YOU WISH TO EXERCISE
YOUR RIGHTS, YOU SHOULD DO SO IMMEDIATELY. IF YOU HAVE ANY QUESTIONS
CONCERNING THIS NOTICE OR YOUR RIGHTS REGARDING THE SALE OF YOUR
PROPERTY, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, YOU SHOULD GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
OBTAIN LEGAL HELP.
Cumberland County Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone No: (717) 240-6200
YOU MAY HAVE THE FOLLOWING LEGAL RIGHTS IN THIS PROCEEDING:
1. You may file a petition with the Court of Common Pleas of Cumberland County to open
the judgment if you have a meritorious defense against the person or company that has entered
judgment against you. You may also file a petition with the same Court if you are aware ofa 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
Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause.
This petition must be filed before the Sheriffs Deed is delivered.
3. These rights must be asserted by filing a petition or petitions raising the legal issues or
rights mentioned above with the Court of Common Pleas of Cumberland County located In
Carlisle, Pennsylyania. If you have any questions concerning these 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 above.
A copy of the Writ of Execution for your property is attached hereto.
I,
,
,
j,
NAUMAN, SMITH, SHISSLER & HALL
~
i
i
~
udenmaler, EsquIre
urt ID #34996
200 North Third Street
Post Office Box 840
Harrisburg, PA 17108
Telephone: (717) 236.30\0
I
I
l
t
I
Counsel for: Mellon Bank, N.A., Plaintiff
cc: All lienholders of record
ALL those certain tracts with dwellings erected thereon situate in the Borough of
Carlisle, Cumberland County, Penn~ylvania as bounded and described as follows:
TRACT I: On the South side by Baltimore Street; and the East by property of heirs of
Rachael Whiting; on the North by property now or late of C. Shapley's heirs and on the West
by property of John R. Hunter. having a frontage of seventeen (\ 7) feet and six (6) Inches on
said Baltimore Street and extending at an even width one hundred fifteen (II S) feet. Being
known and numbered as S5 Baltimore Street, Carlisle, Pennsylvania.
BEING known as Parcel No.4 (210320) 612.
TRACT 2: On the West by North West Street; on the North by lot now or late of the heirs
of Charles Shapley, deceased; on the South by lot now or late of Calvin H. Garlick.
Containing in front on said West Street 14 feet and in depth 100 feet, more or less and being
~proved with a two story frame dwelling house known and numbered as 333 North West
Street, Carlisi::, Pennsylvania.
BEING known as Parcel No. S (201798) 56.
TRACT 3: On the North by West North Street, on the East by an alley, on the South by an
alley, and on the West by land now or formerly of Lawton C. Rovegno and Evelyn B.
Rovegno, his wife. CONTAINING 20 feet in front on West North Street and extending in
depth 120 feet, more or less, to the alley on the South. Having thereon erected a 2 story frame
dwelling, known as 146 West North Street.
BEING known as Parcel No.5 (201798) 326.
SEIZED and taken in execution by the Sheriff of Cumberland County to be sold as the
property of Lindora AMetle Johnson a/kla Linda AMette Coleman-Tyler and Walter Johnson,
mortgagors and real owners, under judgment No. 97-2199 in the Court of Common Pleas of
Cumberland County, Carlisle, Pennsylvania.
NOTICE is further given to all parties in interest and claimants. A proposed schedule
of distribution of the proceeds of the above sale will be filed by the Sheriff of Cumberland
County, Pennsylvania on January 8, 1997 and distribution of said proceeds will be made in
accordance with said proposed schedule of distribution unless exceptions are filed thereto
within ten (\ 0) days thereafter
ALL those certain tracts with dwellings erected thereon situate in the Borough of
Carlisle, Cumberland County, Pennsylvania as bounded and described as follows:
TRACT I: On the South side by Baltimore Street; and the East by property of heirs of
Rachael Whiting; on the North by property now or late of C. Shapley's heirs and on the West
by property of John R. Hunter, having a frontage of seventeen (17) feet and six (6) inches on
said Baltimore Street and extending at an even width one hundred fifteen (11S) feet. Being
known and numbered as 55 Baltimore Street, Carlisle, Pennsylvania.
BEING known as Parcel No.4 (210320) 612.
TRACT 2: On the West by North West Street; on the North by lot now or late of the heirs
of Charles Shapley, deceased; on the South by lot now or late of Calvin H. Garlick.
Containing in front on said West Street 14 feet and in depth 100 feet, more or less and being
irnproYed with a two story frame dwelling house known and numbered as 333 North West
Street, Carlisle, Pennsylvania.
BEING known as Parcel No.5 (201798) 56.
TRACT 3: On the North by West North Street, on the East by an alley, on the South by an
alley, and on the West by land now or formerly of Lawton C. Rovegno and Evelyn B.
Rovegno, his wife, CONTAINING 20 feet in front on West North Street and extending in
depth 120 feet, more or less, to the alley on the South. Having thereon erected a 2 story frame
dwelling, known as 146 West North Street.
BEING known as Parcel No.5 (201798) 326.
SEIZED and taken in execution by the Sheriff of Cumberland County to be sold as the
property of Lindora Annette Johnson a1k1a Linda Annette Coleman-Tyler and Walter Johnson,
mortgagors and real owners, under judgment No. 97-2199 in the Court of Common Pleas of
Cumberland County, Carlisle, Pennsylvania.
NOTICE is further given to all parties in interest and claimants. A proposed schedule
of distribution of the proceeds of the above sale will be filed by the Sheriff of Cumberland
County, Pennsylvania on January 8, 1997 and distribution of said proceeds will be made in
accordance with said proposed schedule of distribution unless exceptions are filed thereto
within ten (10) days thereafter
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
I
I.
,
! ;
I
f 1
i
I
!
l
\t.
: NO. 97-2199
LlNDORA ANNETTE JOHNSON alkla
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY:
Please enter judgment in the above-captioned proceeding in favor of Mellon Bank, N.A.,
Plaintiff, and against Lindora Annette Johnson a/kla Linda Annelle Coleman-Tyler and Walter
Johnson, Defendants in the above captioned proceeding, in the amount of $18,102.25 plus interest
in the amount of $6.44 per day from April 4, 1997, plus costs, attorneys fees and for forecl03ure
and sale of the mortgaged properties known as; 146 West North Street, 55 Baltimore Street and
333 North West Street, Cumberland County, Carlisle, Pennsylvania 17013. Judgment is entered
pursuant to Pa. R.C.P. 1037 for failure of Defendants to file an Answer to Plaintiff's Complaint
within twenty (20) days of service thereof.
NAUMAN, SMITH, SHISSLER & HALL
nmaler, Esquire
ID #34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
Telephone: (717) 236-3010
Counsel for: Mellon Bank, N .A., Plaintiff
I hereby certify that a Notice of Intent to take a default judgment was forwarded to
Defendants, Lindora Annette Johnson a/k/a Linda Annette Coleman-Tyler and Walter Johnson,
by United States Mail, First Class with certificate of mailing, postage prepaid on May 29, 1997
addressed to Lindora Annette Johnson alkla Linda Annette Coleman-Tyler, 1416 Bradley Driye,
Apt 212, Carlisle, Pennsylvania 17013. 100 West Penn Street, Carlisle, Pennsylyania 17013 and
Walter Johnson 333 North West Street, Carlisle, Pennsylvania 17013. The aforesaid Notices were
contained within an envelope bearing the return address of the undersigned. The Notices haYe not
been returned to the undersigned as undeliverable or otherwise. A copy of the Notices and Postal
Forms 3817 are attached hereto and marked Exhibits "A" and "B" respectively.
u
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-2199
UNDORA ANNETTE JOHNSON a/k/a
UNDA ANNETIE COLEMAN-TYLER
and WALTER JOHNSON, : CIVIL ACTION - LAW
Defendants : MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO: WALTER JOHNSON
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRlTIEN
APPEARANCE PERSONALLY OR BY AN A TIORNEY ANi) FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAISNT
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS PAPER TO YOUR U\WYER 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
I Courthouse Square
4th Floor
Carlisle, PA 17013
Telephone No.: (717) 240-6200
EXHIBIT
J \ , I'
A
--.
NOTICIA IMPORTANTE
TO: WALTER JOHNSON
USTED NO HA CUMPLlDO CON EL A VISO ANTERIOR PORQUE HA PALTADO
EN TOMAR MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA
DENTRO DE DIEZ (10) DIAS DES DE LA FECHA DE ESTA NOTICIA, ES POSffiLE QUE
UN PALLO SEA REGlSTRADO CONTRA USTED SIN UNA AUDIENCIA Y USTED
PODRIA PERDER SU PROPffiDAD U OTROS DERECHOS IMPORT ANTES. USTED DEBE
LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TIENE
ABOGADO, VAYA 0 LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR EN
DONDE USTED PUEDE OBTENNER LA A YUDA LEGAL.
COURT ADMINISTRATOR
Cumberland County Courthouse
1 Courthouse Square
4th Ploor
Curlisle, PA 17013
Telephone No.: (717) 240-6200
NAUMAN, SMITH, SHISSLER & HALL
Cralg J. S enmaler, Esquire
Supreme Co rt ID #34996
.
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
(717) 236-3010
Counsel for: Mellon Bank, N.A., Plaintiff
A
--
MELLON BANK, N.A..
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-2199
LINDORA ANNETIE JOHNSON a/kla
LINDA ANNETIE COLEMAN-TYLER
and W ALTER JOHNSON, : CIVIL ACTION - LAW
Defendants : MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO: LINDORA ANNETrE JOHNSON a/kIa
LINDA ANNETIE COLEMAN ,TYLER
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRfITEN
APPEARANCE PERSONALLY OR BY AN ATIORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAISNT
YOU. UNLESS YOU ACf WITHIN TEN (10) DAYS FROM THE DATE OF TInS NOTICE,
A JUDGMENT MAYBE 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 Coun!y Courthouse
I Courthouse Square
4th Floor
Carlisle, PA 17013
Telephone No.: (717) 240-6200
.
.-
...
NOTICIA IMPORTANTE
TO: LINDORA ANNETTE JOHNSON alkla
LINDA ANNETTE COLEMAN-TYLER
USTED NO HA CUMPLlDO CON EL AVISO ANTERIOR PORQUE HA PALTADO
EN TOMAR MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA
DENTRO DE DlEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIA. ES POSmLE QUE
UN PALLO SEA REGlSTRADO CONTRA USTED SIN UNA AUDIENCIA Y USTED
PODRIA PERDER SU PROPIEDAD U OTROS DERECHOS IMPORT ANTES. USTED DEBE
LLEV AR EST A NOTICIA A SU ABOOAOO EN SEGUlDA. SI USTED NO TIENE
ABOGADO, VAYA 0 LLAME A LA OFlCINA ESCRITA ABAJO PARA AVERIGUAR EN
DONDE USTED PUEDE OBTENNER LA A YUDA LEGAL.
COURT ADMINISTRATOR
Cumberland County Courthouse
1 Courthouse Square
4th Floor
Carlisle, PA 17013
Telephone No.: (717) 240-6200
NAUMAN, SMITH, SmSSLER & HALL
nmaler, Esquire
ID #34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
(717) 236-3010
Counsel for: Mellon Bank, N.A., Plaintiff
. ~ ,:.... :
MA'" II U~~D FOR OOMESTIC AND INTERNA TlONAL MAIL. DO~' NOT
",OVIDI FOA INSU""...cl-POSTMASTER
".c:......d'rom
N&I"~.&N. S-.ll1( SWISILiA , MAU..
P.O, BOX &40 n
HARRISRlIRn PA 171nA.1\JU
~,
PS Form 3817. Mar. 19S9
GPO I 199J 0 - lS1-0S1
MAY II uno FOR DOMESTle AND INUANATIONAL MAil. Don NOT
....OVIDI'OR INSURANCE-POSTMASUA
Recetnd "om:
"&IIU&U Aurn..t JU.nHt CD . ......t,
, P.O. BOX 840
HARRISBURG, PA 17108-0840
......
PS Form 3a17. Mar. 1989
GPO I 1993 0 - 151-051
1
MAY I. USED 'DA DOMESTIC AND INTERNATIONAL MAll, DOES NOT
....OVIDI'OR INSURANCE-POSTMASTER
R~'rom:
NAlJl4.I.l.I alAm~ 1:u.1I~~1 CR I. HALL.
P.O. BOX lI40
HARRISBURG.
PS Form 3a17. Mlr, 1989
GPO I 1993 0 - 151-051
EXHIBIT
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MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
~
f
I
i
I
I,
t,
v.
: NO. 97-2199
L1NDORA ANNETTE JOHNSON alkla
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
NOTICE OF JUDGMENT
TO: WALTER JOHNSON.
You are hereby notified that on /" to .. .' I, )
has been entered against you in the abov~aptioned case:
. 1997, the following judgment
Judgment in favor of Plaintiff, Mellon Bank, N .A., and against Defendants, Linda Annette
Johnson a/kla Linda Annette Coleman-Tyler and Walter Johnson, in the amount of $18,102.2S
plus interest in the amount of $6.44 per day from April 4, 1997, plus costs, attorneys fees and for
foreclosure and sale of the mortgaged properties known as; 146 West North Street, 55 Baltimore
Street and 333 North West Street, Cumberland County, Carlisle, Pennsylvania 17013. Judgment
was entered pursuant to Pa. R.C.P. 1037 for failure of Defendants to file an Answer to Plaintiff's
Complaint within twenty (20) days of service thereof.
Dated:
(,;f:J In
,
p ,) /"/
,.~<?,;.:.IA. 't*'-~!/'/ ( . /c-:<.,;'t:/':t;,,/
Prothonota~/.... .::
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 is:
Lindora Annelle Johnson alkla
Linda Annette Coleman-Tyler
100 West Penn Street
Carlisle, PA 17013
Lindora Annette Johnson a/kla
Linda Annelle Coleman-Tyler
1416 Bradley Drive, Apt 212
Carlisle, PA 17013
Walter Johnson
333 North West Street
Carlisle, PA 17013
A WALTER JOHNSON, Defendido/a Defendidos/as
Por este rnedio se Ie esla notificando que el de del 1997, ellla
siguiente Fallo ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado
de residencia:
Lindora Annette Johnson a/k/a
Linda Annelle Coleman-Tyler
100 West Penn Street
Carlisle, PA 17013
Lindora Annelle Johnson a/k/a
Linda Annette Coleman-Tyler
1416 Bradley Drive, Apt 212
Carlisle, PA 17013
Walter Johnson
333 North West Street
Carlisle, PA 17013
Abogado del Dernandante
NAUMAN. SMITH. SmSSLER & HALL
()
Craig J.
Supreme rt ID #34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17\08
Telephone: (717) 236-3010
Counsel for Mellon Bank, N.A.
I
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-2199
LINDORA ANNETTE JOHNSON a/kla
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
~
I
I
NOTICE OF JUDGMENT
TO: LINDORA ANNETTE JOHNSON a/kla
LINDA ANNETTE COLEMAN-TYLER.
You are hereby notified that on i }u,,,,, /~:<
has been entered against you in the above'l:aptioned case:
,1997, the following judgment
"
...
.
,.
Judgment in favor of Plaintiff, Mellon Bank, N .A., and against Defendants, Linda Annette
Johnson alkJa Linda Annette Coleman-Tyler and Walter Johnson, in the amount of $18,102.25
plus interest in the amount of $6.44 per day from April 4, 1997, plus costs, attorneys fees and for
foreclosure and sale of the mortgaged properties known as; 146 West North Street, 55 Baltimore
Street and 333 North West Street, Cumberland County, Carlisle, Pennsylvania 17013. Judgment
was entered pursuant to Pa. R.C.P. \037 for failure of Defendants to file an Answer to Plaintiffs
Complaint within twenty (20) days of service thereof.
Dated; l' /.J''''''
". ", / I //"t'
/'f / -7';.)'" t,,:,.,yr' > . /,~ / ,/J!-/',
,,~ ,t.: _ ,,(. ( (. .....'<;-..-,.,r:V'
Prothonotary //)~
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 is:
Lindora Annette Johnson alkla
Linda Annette Coleman-Tyler
100 West Penn Street
Carlisle, PA 17013
Lindora Annette Johnson a/kla
Linda Annette Coleman-Tyler
1416 Bradley Drive, Apt 212
Carlisle, PA 17013
Walter Johnson
333 North West Street
Carlisle, PA 17013
A LlNDORA ANNETTE JOHNSON a/kla,
LINDA ANNETTE COLEMAN-TYLER, Defendido/a Defendidos/as
Por este medio se Ie esta notificando que el de del 1997, el/la
siguiente Fallo ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certifico que la siguiente direccion es 1a del defendido/a segun indicada en el certificado
de residencia:
Lindora Annette Johnson a/kla
Linda Annette Coleman-Tyler
100 West Penn Street
Carlisle, PA 17013
Lindora Annette Johnson a/kla
Linda Annette Coleman-Tyler
1416 Bradley Drive, Apt 212
Carlisle, PA 17013
Walter Johnson
333 North West Street
Carlisle, PA 17013
Abogado del Demandante
NAUMAN, SMITH, SHISSLER & HALL
CraIg J. Sta enmaler, EsquIre
Supreme Co t ID #34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
Telephone: (717) 236-3010
Counsel for Mellon Bank, N.A.
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MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
~ 111
r<tL'tL,
(/" 7
: NO.
LINDORA ANNETTE JOHNSON a/k/a
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: 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 are seryed, by
entering a written appearance personally or by attorney and filing in writing with the Court you 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 for any money claimed in the Complaint or for any 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:
Court Administrator
Cumberland County Courthouse
1 Courthouse Square, 4th Floor
Carlisle, PA 17013
Telephone (717) 240-6200
NAUMAN, SMITH, SHISSLER AND HALL
Craig J. Staudenmaier, Esquire
Supreme Court 10#34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
(717) 236-3010
Counsel for: Mellon Bank, N.A., Plaintiff
.
,
!
I
f
MELLON BANK, N.A..
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
:NO.
LlNDORA ANNETTE JOHNSON a/kla
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas
en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la dernanda y la
notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 par 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 previa
aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demando. Usted puede
perder dinero 0 sus propiedades 0 otros derechos importantes para usted.
LLEVE EST A DEMANDA A UN ABODAGO INMEDlA T AMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VA Y A EN
PERSONA 0 LLMIE POR TELEFONO A LA OFICINA CUY A DlRECCION SE ENCUENTRA
ESCRlT A ABAJO PARA A VERlGUAR DONDE SE PUEDE CONSEGUlR ASISTENCIA LEGAL.
Court Administrator
Cumberland County Courthouse
1 Courthouse Square, 4th Floor
Carlisle, PA 17013
Telephone (717) 240-6200
NAUMAN. SMITH, SHISSLER & HALL
Craig J. Staudenmaier, Esquire
Supreme Court 10 #34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
(717) 236-3010
Counsel for: Mellon Bank, N.A., Plaintiff
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. q'l,.J1 t)(; ~,...I /..-
L1NDORA ANNETTE JOHNSON a/kla
LINDA ANNETTE COLEMAN-TYLER
and W ALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
~
COMPLAINT
AND NOW, comes Plaintiff, Mellon Bank, N.A., by its attorneys, NAUMAN. SMITH,
SHISSLER & HALL, and files the within Complaint, representing in suppon thereof the
following:
.-
.
1. Plaintiff, Mellon Bank, N.A. (hereinafter "Mellon"), is a national banking
association organized and existing under the banking laws of the United States of America with
principal offices at to South Market Square, Harrisburg, Dauphin County, Pennsylvania 17101.
2. The Defendants, Lindora Annette Johnson alkla Linda Anelle Coleman-Tyler and
Walter Johnson (hereinafter "Defendants") are adult individuals and husband and wife whose last
known addresses are, 110 West Penn Street, Carlisle, Pennsylvania 17013 and 333 North West
Street, Carlisle, Pennsylvania 17013, respectively.
3. On or about June 10, 1985, Defendants entered into an agreement whereby they
borrowed from Mellon and agreed to repay to it the sum of Fifty Thousand Six Hundred Forty
Dollars and Zero Cents ($50,640.00), plus interest, and as security for the loan executed and
delivered to Mellon their mortgage dated June 10, 1985, in the amount of Fifty Thousand Silt
Hundred forty Dollars and Zero Cents ($50,640.00) mortgaging tracts of land with dwellings
erected thereon located in Cumberland County, Pennsylvania known as 146 West North Street,
55 Baltimore Street and 333 North West Street, Cumberland County, Carlisle, Pennsylvania
17013. At all times relevant hereto, Defendants were and remain the sole owners of the
mortgaged property as tenants by the entireties. A description of the properties is attached hereto,
made a part hereof and marked Exhibit "A".
4. On June 11, 1985, said mortgage was recorded in the Office of the Recorder of
Deeds of Cumberland County in Mortgage Book 780, Page 430 and this mortgage in the public
records is incorporated herein by reference.
5. The said mortgage was never assigned by Mellon and is still held by it as a valid
and subsisting obligation of Defendants.
6. Mellon believes and, therefore avers, that Defendants herein, are the only parties
in interest in the land described herein as Exhibit" A".
7. Under the terms and conditions of the mortgage and promissory note, Defendants
agreed to make monthly payments to Mellon in the amount of Seven Hundred Eighty Seven
Dollars and Forty-seven Cents ($787.47), beginning July IS, 1985 and payable on the 15th day
of each successive month thereafter.
8. Defendants have breached the terms and conditions of the mortgage and promissory
note and have defaulted under their terms and conditions in that they have failed to make the
required monthly payment in accordance with the terms thereof.
9. Defendants are presently indebted to Mellon in the amount of Eighteen Thousand
One Hundred Two Dollars and Twenty-Five Cents ($18,\02.25) itemized as follows:
Principal Balance
$ 16,778.97
$ 1,323.28
Interest to April 3, 1997
(per diem $6.44)
TOTAL DUE
$ 18,102,25
10. Defendalits also agreed under the terms of the mortgage and note that in the event
of default thereunder they would pay, in addition to the charges listed in paragraph 9 aboye,
attorneys' fees and costs incurred by Mellon as a result of the institution of these legal
proceedings.
II. The obligation owed by Defendants to Mellon continues to accrue interest thereon
at the rate of $6.44 per day beginning April 4, 1997.
12. In accordance with the Homeowners' Emergency Mortgage Assistance Act, of
December 23,1983, P.L. 385 No. 91, 35 P.S, ~1680.401c.l:J~., Notices oflntent to Foreclose
and of Defendants' rights under said Act were forwarded to Lindora Annelle Johnson alkla Linda
Anette Coleman-Tyler and Walter Johnson by letters dated September 14, 1995, first class mail,
addressed to Lindora Annelle Johnson a/kla Linda Anette Coleman-Tyler, 110 West Penn Street,
Carlisle, Pennsylvania 17013 and Walter Johnson, 333 North West Street, Carlisle, Pennsylvania
17013. Copies of the aforesaid Notices are attached hereto and marked Exhibits "B" and "C".
Copies of the mailing receipts, postal forms 3817, evidencing the mailing of said Notices are
attached hereto and marked Exhibit "D". Defendants received delivery of said Notices on
September 17, 1995. See 35 P.S. g 1680.404c(e). Mellon believes, and therefore aYers, that
Defendants have not applied for assistance under the Act.
13. Pursuant to the Act of January 30, 1974, P.L. 13, No.6, 41 P.S. glol ~..KlI., and
in particular g403 thereof, Mellon gave written notice to Defendants of its intent to foreclose by
letters dated September 14, 1995, addressed to Lindora Annette Johnson a/k/a Linda Anette
Coleman-Tyler and Walter Johnson, certified mail, return receipt requested Nos, Z 232 035 179
and Z 232 035 180 respectively. Copies of said notices are attached heretlJ, made a part hereof
and marked Exhibits "E" and "F".
14. Defendant, Walter Johnson received delivery of the aforesaid notice on
September IS, 1995 as evidenced by the signed certified mail receipt attached hereto, made a part
hereof and marked Exhibit "G".
IS. Defendant, Lindora Annette Johnson a/k/a Linda Annette Coleman-Tyler, did not
claim delivery of the aforesaid Notice despite the postal ~uthorilies three attempted deliveries as
evidenced by the unclaimed envelope a copy of which is attached hereto, made a part hereof, and
marked Exhibit "H".
16. Plaintiff then forwarded said Notice set forth herein as Exhibit "I" to Defendant by
first class mail, certificate of mailing, to her last known address in an envelope bearing the return
address of counsel for Plaintiff. To date said Notice forwarded in this manner has not been
returned as undeliverable or otherwise. A copy of the mailing receipt, postal form 3817,
evidencing the mailing of said Notice is attached hereto and marked Exhibit "J".
17. As set forth above, Mellon has made repeated demands upon Lindora Annette
Johnson alkla Linda Annette Coleman-Tyler and Walter Johnson, Defendants herein, to cure the
default under the aforesaid mortgage and promissory nOle, however, Defendants have refused and
failed and continue to refuse and to fail to cure this default,
WHEREFORE. Plaintiff. Mellon Bank, N .A. demands judgment against Lindora Annette
Johnson a/kla Linda Annette Coleman-Tyler and Walter Johnson. Defendants, in the amount of
Eighteen Thousand One Hundred Two Dollars and Twenty-Five Cents ($18,102.25), plus costs,
attorneys' fees and interest in the amount of $6.44 per day beginning April 4, 1997, and for
foreclosure and sale of the mortgaged properties known as; 146 West North Street, S5 Baltimore
Street and 333 North West Street, Cumberland County, Carlisle, Pennsylvania 17013.
N0' SMITH, SHISSLER & HALL
,J ' .',
CraIg J. S
Supreme rt ID# 34996
200 North Third Street
P.O. Box 840
Harrisburg. PA 17108
(717) 236-3010
Counsel for: Mellon Bank, N.A.
MELLON BANK, N.A.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.
LlNDORA ANNETTE JOHNSON a/kla
LINDA ANNETTE COLEMAN-TYLER
and W ALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
NOTICE
You have been sued in Court. If you wish to defend againstth~ claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are serYed, by
entering a wrillen appearance personally or by allorney and filing in writing with the Court you 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 for any money claimed in the Complaint or for any 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 TELEPHOJl,'E THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Court Administrator
Cumberland County Courthouse
1 Courthouse Square, 4th Floor
Carlisle, PA 17013
Telephone (717) 240-6200
NAUMAN, SMITH, SHISSLER AND HALL
Craig J. Staudenmaier, Esquire
Supreme Court 10#34996
200 North Third Street
P.O. Box 840
Harrisburg, P A 17\08
(717) 236-3010
Counsel for: Mellon Bank, N.A., Plaintiff
",
,
MELLON BANK, N.A..
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.
LlNDORA ANNETTE JOHNSON a/k/a
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
AVISO
Le han demandado a usted en la corte. Si usled quiere defenderse de estas dernandas expuestas
en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la
notlficacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la
corte en fonna escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea ayisado
que si usted no se defiende, la corte tomara rnedidas 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 demando. Usted puede
perder dinero 0 sus propiedades 0 otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, V A Y A EN
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA
ESCRlTA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Court Administrator
Cumberland County Courthouse
1 Courthouse Square, 4th Floor
Carlisle, PA 17013
Telephone (717) 240-6200
NAUMAN, SMITH, SHISSLER & HALL
Craig J. Staudenmaier, Esquire
Supreme Court ID #34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
(717) 236-3010
Counsel for: Mellon Bank, N.A., Plaintiff
MELLON BANK, N.A..
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY , PENNSYLVANIA
v.
: NO.
LlNDORA ANNETTE JOHNSON a/kla
LINDA ANNETTE COLEMAN-TYLER
and WALTER JOHNSON,
Defendants
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
COMPLAINT
AND NOW, comes Plaintiff, Mellon Bank, N.A., by its allorneys, NAUMAN, SMITH,
SHISSLER & HALL, and files the within Complaint, representing in support thereof the
following:
1. Plaintiff, Mellon Bank, N.A. (hereinafter "Mellon"), is a national banking
association organized and existing under the banking laws of the United States of America with
principal offices at 10 South Market Square, Harrisburg, Dauphin County, Pennsylvania 17101.
2. The Defendants, Lindora Annelle Johnson a/k/a Linda Anette Coleman-Tyler and
Walter Johnson (hereinafter "Defendants") are adult individuals and husband and wife whose last
known addresses are, 110 West Penn Street, Carlisle, Pennsylvania 17013 and 333 North West
Street, Carlisle, Pennsylvania 17013, respectively.
3. On or about June 10, 1985, Defendants entered into an agreement whereby they
borrowed from Mellon and agreed to repay to it the sum of Fifty Thousand Six Hundred Forty
Dollars and Zero Cents ($50,640.00), plus interest, and as security for the loan executed and
delivered to Mellon their mortgage dated June 10, 1985, in the amount of Fifty Thousand Six
Hundred forty Dollars and Zero Cents ($50,640.00) mortgaging tracts of land with dwellings
erected thereon located in Cumberland County, Pennsylvania known as 146 West North Street,
55 Baltimore Street and 333 North West Street, Cumberland County, Carlisle, Pennsylvania
17013. At all times relevant hereto, Defendants were and remain the sole owners of the
mortgaged property as tenants by the entireties. A description of the properties is attached hereto,
made a part hereof and marked Exhibit" A".
4. On June II, 1985, said mortgage was recorded in the Office of the Recorder of
Deeds of Cumberland County in Mortgage Book 780, Page 430 and this mortgage in the public
recl'rds is incorporated herein by reference.
5. The said mortgage was never assigned by Mellon and is still held by it as a valid
and subsisting obligation of Defendants.
6. Mellon believes and, therefore avers, that Defendants herein, are the only parties
in interest in the land described herein as Exhibit" A".
7. Under the terms and conditions of the mortgage and promissory note, Defendants
agreed to make monthly payments to Mellon in the amount of Seven Hundred Eighty Seven
Dollars and Forty-seven Cents ($787.47), beginning July IS, 1985 and payable on the 15th day
of each successive month thereafter.
8. Defendants have breached the terms and conditions of the mortgage and promissory
note and have defaulted under their terms and conditions in that they have failed to make the
required monthly payment in accordance with the terms thereof.
9. Defendants are presently indebted to Mellon in the amount of Eighteen Thousand
One Hundred Two Dollars and Twenty-Five Cents ($18,102.25) Itemized as follows:
Principal Balance
$ 16,778.97
$ 1,323.28
Interest to April 3, 1997
(per diem $6.44)
TOTAL DUE
$ 18,102.25
10. Defendants also agreed under the terms of the mortgage and note that In the event
of default thereunder they would pay, in addition to the charges listed in paragraph 9 above,
attorneys' fees and costs incurred by Mellon as a result of the institution of these legal
proceedings.
11. The obligation owed by Defendants to Mellon continues to accrue interest thereon
at the rate of $6.44 per day beginning April 4, 1997.
12. In accordance with the Homeowner~' Emergency Mortgage Assistance Act, of
December 23, 1983, P.L. 385 No. 91, 35 P.S. ~1680.40Ic.eJ.wj., Notices of Intent to Foreclose
and of Defendants' rights under said Act were forwarded to Lindora Annette Johnson alkla Linda
Anette Coleman-Tyler and Walter Johnson by letters dated September 14, 1995, first class mail,
addressed to Lindora Annette Johnson a/kla Linda Anette Coleman-Tyler, 110 West Penn Street,
Carlisle, Pennsylvania 17013 and Walter Johnson, 333 North West Street, Carlisle, Pennsylvania
17013. Copies of the aforesaid Notices are attached hereto and rnarked Exhibits "B" and "C".
Copies of the mailing receipts, postal forms 3817, evidencing the mailing of said Notices are
attached hereto and marked Exhibit "D". Defendants received delivery of said Notices on
September 17, 1995. See 35 P.S. 0 1 680.404c(e). Mellon believes, and therefore avers, that
Defendants haye not applied for assislance under the Act.
13. Pursuant to the Act of January 30, 1974, P.L. 13, No. 6,41 P.S. O\oI-'l.KQ., and
in particular ~3 thereof, Mellon gave wrillen notice 10 Defendants of ils inlentto foreclose by
letters dated September 14, 1995, addressed to Lindora Annette Johnson a/k/a Linda Anelle
Coleman-Tyler and Walter Johnson, certitied mail, return receipt requested Nos. Z 232 035 179
and Z 232 035 180 respectively. Copies of said notices are attached hereto, made a part hereof
and marked Exhibits "E" and "F".
14. Defendanl, Walter Johnson received delivery of the aforesaid notice on
September IS, 1995 as evidenced by the signed certified mail receipt attached hereto, made a part
hereof and marked Exhibit "G".
15. Defendant, Undora Annette Johnson alkla Linda Annette Coleman-Tyler, did not
claim delivery of the aforesaid Notice despite the postal authorities three attempted deliveries as
evidenced by the unclaimed envelope a copy of which is attached hereto, made a part hereof, and
marked Exhibit "H".
16. Plainliff Ihen forwarded said Notice set forth herein as Exhibit "I" to Defendant by
first class mail, certificate of mailing, to her last known address in an envelope bearing the return
address of counsel for Plaintiff. To date said Notice forwarded in this manner has not been
returned as undeliverable or otherwise. A copy of the mailing receipt, postal form 3817,
evidencing the mailing of said Notice is attached hereto and marked Exhibit "J".
17. As set forth above, Mellon has made n:peated demands upon Lindora Annette
Johnson elk/a Linda Annette Coleman-Tyler and Walter Johnson, Defendants herein, to cure the
default under the aforesaid mortgage and promissory note, however, Defendants have refused and
failed and continue to refuse and to fail to cure this default.
WHEREFORE, Plaintiff, Mellon Bank, N.A. demands judgment against Lindora Annette
Johnson a/k/a Linda Annette Coleman-Tyler and Walter Johnson, Defendants, in the amount of
Eighteen Thousand One Hundred Two Dollars and Twenty-Five Cents ($18,102.25), plus costs,
attorneys' fees and interest in the amount of $6.44 per day beginning April 4, 1997, and for
foreclosure and sale of the mortgaged properties known as; 146 West North Street, 55 Baltimore
Street and 333 North West Street, Cumberland County, Carlisle, Pennsylvania 17013.
Nn' SMITH, SHISSLER & HALL
V .
Craig J. S
Supreme rt 10# 34996
200 North Third Street
P.O. Box 840
Harrisburg, PA 17108
(717) 236-3010
Counsel for: Mellon Bank, N.A.
, ,
. ..
~~/~~:: J,',,:',t"IHlf Ihu,a:li tli~' IuinJrrJ . i Shl. y-t 'IJU ~ & 'JO J,
,
l
;
f
. . Hurled of the 8orollHh of Carli.lu.
DETIVI.'EN UALTER JOtlNOIUN. d CONNIE L JOIlNSON Single Wom.m.
Cumberland County, penn.ylv.~hb.nhnd Courty Penn.ylvpniil, herelnolCter
ot the Boroulh ot C.rlhh. um If ,
LIndo<. AmatU Jomaoo, hi. wife
tin" \lALTU JOUHSON,I . ot C.rU.h. Cumberland
p.nn.yl~Gnl., h.r~ln.tt.r
('j'lIn/"" .
County.
';1111I11'1' :
lVITNESSETU. ,A;a' ill tOlllill,raHoll uf On. .............--..................---...-------
......____.._......._.............u.._OO/IOO ($1 _ 00)11"11,,,"_
~..,...d:~-;;d:~;;;,:;,;;~;;r::'..~.It.'rlJ~ OdUlOII",Jurfl. ,.Ii: r'{~t1l1lIljr I .,.. 11m "lIllItl/ll
."d C\JAller '0 IAI "Id 811111'" , th,ir he I U Ind " R ,
. i t 1 the BorouRh of Carlillo.
ALL thole certain trp'ctl II tu.l....nbounded and dc.crihcd al
CUllberland County. ennlY vln
fol1?w'l
TRACT liOn the North by Wa.t Penn Stree~iofnA~~oh~:'~.b~nd
property tor.erly of Herm.n alrl. Jr" no w o~ formerly of W.
SlvlHn p, Barnll, hn ~h't8~ut~r:~I~~~Pf~:~e~lY of William I.lno.
Frink W.lter.; oln I .c e: I InB 16 f..t 4 Inches, more or le..,
now ot Walter L ne. on I n din in de~th 81 feet 6
in tront on WII" Plenn stdruelthn: ::~e~tor~ dwellIng ,kno\1O II No.
inchl' .n4 b, PI mprov. w
110 W.tt ',nn Sere.t. C.rll.le.
1001# 31 fAct 598
(CONTINUED ON REV~RSE)
"
I
\.
1I1':INC: tllp. 1':11"(.' 'JrcllliHs whlch Slvilln P. BArllel, Admlnluratrix
of l~e E'tulo of Adolphu, S. Bnrnel, ~rant.d .nd conveyed unto
nr:111t(lr't hrrt'ln "y dl'ed dlJted Octobn 7, 1976 "nd recorded In
Or.C'tl U'lIlk Y, Volume 2". Patte '.57.
TRAcr 2: On the ,0ull, hy BaltImore Street; and the EDit by
pi"ii'jie'"ity of h,!irs of Jl3ch'!l WhitinRi on the North by property now
or '.1l(' uf C. Shapley', helu .nd on the Weu by property of John
It, Hunlcr, h.1Yinn Cl rrontlJRe or .eventeen (17) fel!t and .h (6)
inchl'."i on 1",11 8illtimore Street anrl extendinR at an even width
11n(' hundred riller" (l15) feet. Being known .nd numbered.. "
Illlllbnnrr St" C.:arli!lle, Penna.
UP-tNG lhe .umr prernlloll which Charlea R. Mitchell nranted .nd
CClIl\lI!Yl"d Ulllo r,r:1nlora herein by deed dated Novembor 2, 1977 and
r('c(lrtlc,1 in Oiled Dook tI, Volume 27, Pege 750,
l.!!..^.f!:..1: On lhe W(''I.l by North West Street; on the North by lot
now (If l.:al~ of tllr. IIr.ir. DC Char Ie. Sh.pley, dec...ed; on the
E:lIq hy !1rn!1f" ty nou or Cormerly of Sidney Spualin; and on the
South hv Ifll nn" or lnte of Calvin II. Carlick. Cont.inina in
front Ofl ."id Wellt Street t4 feet and in depth 100 feet, more or lell
Mill hf'illr, Improved with a tuo Itory Creme dwelling hou.e known
o1nrl nUl'lbl'fed .19 ))) Harth W~lt Strut. Carlht., Penn.ylvania,
DEING lhe J~mc premi,es which Daniel W, Jone. and Detore. 1.
Jane.. hi. wife, r,rnllted and conveyed unto grantor. herein by
dcord d;nl'd Nnv('lfthcr 10, 1918 and recorded in Deed Book E, Volume
2A, 1'''J.!c 25'1.
"
IIMg~: 1)11 lhe North by We.t North Stnet, on the Ealt by an
n nrV, Oil lhl' !;ollth by an alley, and on the West by hnd now or
rnnnl."rly of 1..1,,IlOII C. Rovep,no and Evelyn 8. Rovegno, hit ,,,Ue,
CONTAINING 211 ft"et in front on Weu North Street Ind extending in
11t'IIlh 120 fl."rt. more or lell. to the .lley on the South. Ulving
th~'rrOll I"rl'clrcl :1 2 Itory rrar.re dwell1nR, knolln a. 14ft Weu North
5l rrt'l.
I1I;IN(: tile .:rmt.' premise. whtch Commonwulth N.tlon.l lJank
CU01rlli.11l of the EstnU of tlarion Lout.e Middleton. elk,.; Harion
Anderson, 0'\11 incompctl!ntj Runted and convered to lunton herein
hv (h'ed d,1trll .Iune 25, 1'180 and recorded in Deed Book Z, Volume
1f\. 1'.1~1' 112.
/,'
I?,.,.../f... Ie-
I
,
,...
,
......
-
~
LAW OFFICES
NAlTHAN. HJ>UTU, HIIIHHLJlIR ,. JlALL
le'~ FLOOR
200 NOATH THIRD Sl'Rf:E:T
0.....10 C. .ATOH
."CNI:II:I' Q. ",AUNAN, "R.
.JOHN C. .ULLIYA"
oJ. .T."HIN ,.CINO..,"
C".IO oJ. .T...VO.......,...
A O. 601C 840
HARRISBUFtO, Pt::NNSYLVANIA 17108-0840
T&'-1I'110"'.
f7171130.3010
TIL.,.....
f7171 .34-18'5
Coutt.I'"
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.............IN C. DUNL,."''' ......
.TIl~HIN .... "IlIlHIl
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ TmS NOTICE. YOU MAYBE ELlGmLE FOR
FINANCIAL ASSISTANCE WmCH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
September 14, 1995
CERTIFICATE OF MAILING
Lindora Johnson
1\0 West Penn Street
Carlisle, PA 17013
RE: Account No: 418-0525436
Mellon Bank, N.A.
Dear Ms. Johnson:
You may be eligible for financial assistance that will prevent foreclosure on your mortgage
If you comply with the provisions ofthe Homeowners' Emergency Mortgage Assistance Act of 1983
(the "Act"). You may be eligible for emergency temporary assistance If your default has been
caused by circumstance beyond your control, you have a reasona'ble prospect of resuming your
mortgage paymenl.~, and If you meet other eligibility requirements established by the Pennsylvania
Housing FInance A.:ency. Please read all of this Notice. It contains an explanation of your rIghts.
Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty
(30) days from the date of this notice. During that time you must arrange and attend a "face-to-face"
meeting with a representative of this lender, or with a designated consumer credit counseling agency.
The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your
delinquency. This meeting rnust occur in the next thirty (30) days.
--
If you auend a face-to-face meeting with this lender, or with a consumer credit counseling
agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty
(30) days after the date of that meeting.
The name, address and telephone number of the Bank's representative is:
Craig J. Staudenmaier, Esquire
NAUMAN, SMITH, SHISSLER & HALL
200 North Third Street
Harrisburg, Pennsylvania 17108
Telephone: (717) 236-30\0
The names and addresses of designated consumer credit counseling agencies are shown on the
attached sheet. It is only necessary to schedule one face-to-face meeting. You should adyise this lender
immediately of your intentions.
Your mortgage Is In default because you have failed to pay promptly installments of principal
and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency
as of the above date is $12,599.52. That sum includes the following: principal, interest, escrow and
late charges.
If you have tried and are unable to resolve this problem at or after your face-to-face meeting,
you haye the right to apply for financial assistance from the Homeowners' Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners'
Emergency Assistance Application with one of the designated consumer credit counseling agencies listed
on the attachment. An application for assistance may only be obtained from a consumer credit
counseling agency. The consumer counseling agency will assist your completed application to the
Pennsylvania Housing Finance Agency. Your application must be filed or postrnarked, within thirty
(30) days of your face-to-face meeting.
It Is extremely Irnnortant that vou file an application nromptly. If YOU do not do so. or If
you do not follow the other time periods set forth in this letter. foreclosure may nroceed al!ainst
your home Immediately.
Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act.
It is extremely important that your application is accurate and complete in every respect. The
counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency
has sixty (60) days to make a decision after it receives your application. During that additional time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by that agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P.O. Box
8029, Harrisburg, Pennsylvania 17105. Telephone No: (717) 780-3800 or 1-800-342-2397 (toll free
number). Persons with impaired hearing can call 1-800-342-2397.
In addition you may receive another notice from this lender under Act 6 of 1974. That notice
is called a 'Notice of Intention to Foreclose'. You must read both notices, since they both explain
right!l that you now have under Pennsylvania law. However, if you choose to exercise your right!l
described in this notice, the Bank cannot foreclosure upon while you are receiving that assistance.
MELLON BANK, N.A.
enmaler, Esquire
ellon Bank, N.A.
CJS/mlc
Enclosure
!\
,
,
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The Commonwealth of Pennsylvania's
Homeowner's Emergency Mortgage Assistance
Program
may be able to help you.
Read the attached notice to find out how the
program works.
If you need more information call the Pennsylvania
Housing Finance Agency at 1(800) 342-2397
LANOTIFICACION EN ADJUNTO ES DE SUMA 1\IPORTANCIA. PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU C\SA. Sl NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTE:\GA UNA TRADUCCIOl'
INMEDIATAMENTE LLAMANDO ESTA ,-\G E:\C 1.,\ IPEt'<'NSYL\'ANlA HOUSING
FINANCE AGENCY) SIN CARGOS AL NU~IERO \lE\'CIONADO ARRIBA, PUEDES SER
ELEGIBLE PARA l.~ PREST AMO POR EL PROGR.-\\IA LLAMAlJO "HOMEOWNER'S
EMERGENCY \-IORTGAGE ASSISTANCE PROGRA\I" EL CUAL PL'EDE SAL V.-\R SL'
CASA DE LA PERDlDA DEL DERECIIO A REDIMIR SU HIPOTEC.-\. .
"
...
3238
STATEMENTS OF POLICY
l:llUIMDlA COUNI Y
CUMBERLAND COUNTY
Consumer Credit Counseling Service 01 W.etem
Pennsylvania. Inc.
2000 Linglestown Roed
Harrisburg, PA 17102
(7171541.1757
Financial Services Unlimited
117 West 3rd Street
Waynesboro. PA 17268
(7171 762,3285
Urban League 01 Matropolitan Harrisburg
25 N, Front Street
Hsrrisburg, I'A 17101
1717) 234-5925
FAX , (7171 232,4985
YWCA or Cllrlisla
301 G Street
Carlisle. I'A 17013
(7171243,3818
FAX' (7171 243,3948
PENNSYLVANIA BULLETIN. VOL, 24. NO. 27. JULV 2, 1994
Hiapanic Association of Contractore & Enterprises
2921.27 North 5th Strl.'Clt
Philadelphia, P A 19133
(2151426,8025
FAX , (215) 426.8027
L. Ca.. Del Pueblo
815 W. Baltimore Pike
K.nnett Square, PA 19348
(2151 444-3731
FAX' (2151 444.3178
MtdJ. Ftllowshlp House
802 S. J.ckeon Street
MtdJa, P A 19063
(2151 565-0848
Philadelphia Council lor Community Advancement
100 North 17th Street
Sulle 600
Philadelphia, P A 19t 03
(2151 567-7803
FAX' (215)963.9941
Tabor Community Servlcee, Inc.
439 E. KIng Stroot
Lancaetar, PA 17802
(717)397-5182 or 1(800)788.5082 (Homeowners only)
FAX' (717) 399-4127
CLARION COUNTY
Consumer Credit Counse1lng Service 01 Western
Pennsylvanls. Inc.
YMCA Building
339 North Washington Street
'Butler, PA 1600t
(412) 282.7812
CLEARFIHD COUNTY
Keystone Economic Development Corporation
1954 Mary Grace Lane
Johnstown. PA 15901
(814) 535-6556
FAX , (814) 539-1688
Indiana County Community Action Program
827 Water Street. Boa 187
Indians. PA 15701
(412) 465,2857
FAX , (4121 466,5118
Consumer Credit Counseling Service 01 Wsstern
Pennsylvania, Inc.
500-02 3rd Avenue
Poat Ollice BOl< 278
uUDcansvllle. P A
(8141 698.3548
CLINTON COUNTY
Lycom!nIl,Clinton Counties Commission For Community
Action (STEP)
2138 Lincoln Street
P. O. Boa 1328
WUllamsport. P A 17703
(717) 326.0587
FAX , (7171 322.2197
Consumer Credit Counseling Service of NOrlheut.em
Pcnnliylvunill
Human Services Building
541 WyominH' Avenue
Box 16B
Scranton. I'A 18501
(7171342.1072 or 1,800,922,9537
FAX' t7171342'8040
31 W. Markat Street
WUk...Barre, PA 18702
(7171 82t-0837 or 1(8001922.9537
FAX' (7171 82l-1785
Commission on Economics Opportunity 01 Luunle
County
211.213 South Main Street
Wilkes.Barre. PA 18701
(7171826.0510 or 1(800) 822-0359 .
FAX' (7t71 829.1865-Ctll belore lulng
(7171455.4994 Huelton
FAX' t7171455'5831-Ctll belore lulng
(7171 836.4090 Tunkhannock
CRAWFORD COUNTY
Booker T. Weshington Cen~r
1720 Holland Street
Erie. PA 18503
(8141 453,5744
FAX' (8141453,5749
Greater Erie Community Action Commlttee
18 West 9th Street
Erie. PA 16501
(8141459.4581
FAX , (8141 456,Ol6t
John F. Kennedy Center, Inc.
2021 East 20th Street
Erie, PA 16510
(8141898.0400
FAX' (8141 898,1243
Shenanllo Valley Urhan League, Inc.
601 Indiane Avenue
FarreU, PA 16121
14121981.5310
l
r
~
,
.,
..
.-
,
-,
LAW OFFICES
NAU:&IAN. S:&IITII, SIIISHLIDII a: JlALL
OA.".O C. ':IoTO,.,
.,.CHee,. Q, "'.UMAN, .JR.
.lOHN c_ aUL.l.IYAN
.... STePHEN ,.CIHOUR
CRAIO oJ. STAUDeN"'AIC"
18TH FLOOR
ZOO NORTH THIRD STREET
P O. BOM: 840
HARRISBURG, PENNSYLVANIA 17108-0840
TELePHONe
(?I?I 138-3010
TILe,.....
(7,7\ 2304-1015
BCNJAfr04IH C. DUHL"'''' .JR.
arcp...eN oJ. KeENE
cou...aCL
"ALPH w. eOYLe., ......
ACT 91 NOTICE
IMPORTANT: NOTICE OF HO!'.IEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ TIDS NOTICE. YOU MAYBE ELIGIDLE FOR
FINANCIAL ASSISTANCE WmCH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
September 14, 1995
CERTIFICATE OF MAILING
WaIter Johnson
333 North West Street
Curlisle, PA 17013
RE: Account No: 418-0525436
Mellon Bank, N.A.
Dear Mr. Johnson:
You may be eligible for financial assistance that will prevent foreclosure on your mortgage
Iryou comply with the provisIons of the Horneowncrs' Emergency Mortgage Assistance Act of 1983
(the "Act"). You may be eligible for emergency temporary assistance If your default has been
calL.ed by circumstance beyond your control, you have a reasonable prospect of resuming your
mortgage payments, and if you meet other eliglblllty requirements established by the Pennsylvaula
HOllsing Finance Agency. Plcase read all of this Notice. It contains an explanation of your rights.
Under the Act, you are entitled to a temporury stay of foreclosure on your mortgage for thirty
(30) davs from the date of this notice. During that time you must arrange and attend a "face-to-face"
meeting with a representative of this lender, or with a designated consumer credit counseling agency.
The purpose of this meeting is to allernpt to work out a repayment plan, or to otherwise settle your
delinquency. This meeting must occur in thc ncxt thirty (30) days.
,
If you attend a face-to-face meeting with this lender. or Wilh a consumer credit counseling
agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty
(30) days after the dale of that meeting.
The name, address and telephone number of the Bank's representative is:
Craig J. Staudenmaier, Esquire
NAUMAN, SMITH, SHISSLER & HALL
200 North Third Street
Harrisburg, Pennsylvania 17108
Telephone: (717) 236-3010
The names and addresses of designaled consumer credit counseling agencies are shown on the
attached sheet. It is only necessary to schedule one face-to-face meeting. You should adyise this lender
immediately of your intentions.
Your mortgage Is In default because you have flliled to pay promptly installments of principal
and interest. as required, for a period of at least sixty (60) days. The total amount of the delinquency
as of the above date is $12,599.52. That sum includes the following: principal, interest, escrow and
late charges.
If you have tried and are unable to resolve this problem at or after your face-to-face meeting.
you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners'
Emergency Assistance Application with one of the designated consumer credit counseling agencies listed
on the attachment. An application for assistance may only be obtained from a consumer credit
counseling agency. The consumer counseling agency will assist your completed application to the
Penn5ylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty
(30) days of your face-to-face meeting.
It Is extrernelv irnDortant that you file an aDDllcatlon DrornDtlv. If yOU do not do so. or If
YOU do not follow the other time Derlods set forth In this letter. foreclosure rnav 'Proceed a~alnst
your home Imrnedlatelv.
Available funds for emergency mortgage assistance ure very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act.
It is extremely imporlant that your application is accurate and complete in every respect. The
counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency
has sixty (60) days to make a decision after it receives your application. During that additional time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by that agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street. P.O. Box
8029, Harrisburg, Pennsylvania 17105. Telephone No: (717) 780-3800 or 1-800-342-2397 (toll free
number). Persons with impaired hearing can call 1-800-342-2397.
,
In addition you may receive another notice from this lender under Act 6 of 1974. That notice
is called a 'Notice of Intention to Foreclose". You must read both notices, since they both explain
rights that you now have under Pennsylvania law. However, if you choose to exercise your rights J
described in this notice, the Bank cannot foreclosure upon while you are receiving that assistance. r
{"
MELLON BANK, N.A. ,
e aler, Esquire
ellon Bank, N.A.
CJS/mlc
Enclosure
'....
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The Commonwealth of Pennsylvania's
Homeowner's Emergency Mortgage Assistance
Program
may be able to help you.
Read the attached notice to find out how the
program works,
If you need more information call the Pennsylvania
Housing Finance Agency at 1(800) 342-2397
LANOTIFICACION E~l ADJUNTO ES DE SUMA IMPORTANCIA. PUES AFECTA SU
DERECHO A CONTNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTlFlCACION OBTE"GA UNA TRADUCCIO!\'
INMEDlATAMENTE LLAMANDO ESTA ,-\GE"CJ..\ tPENNSYL\'ANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO ~IENCIONADO ARRlBA. PUEDES SER
ELEGIBLE PARA l!;-': PRESTAMO POR EL PROGRA:>.IA LLAMADO "HOMEOWNER'S
EMERGENCY ~IORTGAGE ASSISTANCE PROGRA~t" EL CU.-\L Pl'EDE SAL V AR SL'
CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA, ,
, . . I
, .. . ., tI,
. .
-
...
-
3236
STATEMENTS OF POLICY
CUMBERLAND COUNTY
Consumer Credit Counseling Service 01 Weotem
Pennsylvania, Inc.
2000 Llnglestown Roed
Herrlsburg. PA 17102
(717) 54J.\757
Flnancll11 Sarvlces UnUmlted
117 West 3rd Street
Waynesboro, PA 17268
(717) 762,3285
Urban League 01 Metropolitan Harrisburg
25 N. Front Strcet
Herrlsburg, PA 17101
17171234,5925
FAX I 17171 23204985
YWCA 01 Carli.le
301 0 Street
Carlisle. PA 17013
17171243,3818
t'AX , 17171 243,3948
PENNSYLVANIA BULLETIN, VOL, 24, NO, 27, JULY 2, 1994
Hilpanic Association of Contractors & Enlerpriscs
2921.27 North 5th Street
PhUadelphla. PA 19133
(215) 426,8026
FAX I (2161426,8027
La Casa Del Pueblo
815 W, Beltlmore Pike
Kennett Square, PA t9348
(215) 444.3731
FAX' (215) 444-3178
Media FeUow.hlp House
802 S. Jackson Street
Media, PA 19063
(2151 565'()846
PhUadelphla CouncU lor Community Advancement
100 North 17th Street '
Suite 600
PhUadelphla, PA 19t03
(215) 567-1803
FAX' (2151 963.994t
Tabor Community Services, Inc.
439 E. KIng Street
Lancaster, PA 17602 ,
(7171397.&182 or 1(800) 788.&062 (Homeowne" only)
FAX' (7171399-4127
CLARION COUNTY
Con.umer Credit Counseling Service 01 Western
Penn.ylvanla, Inc.
YMCA Building
339 North Washington Street
'Butler, PA 16001
(412) 282.7812
CI.EARt'lELD COUNTY
Key.tono Economic Dovelopment Corporotlon
1964 Mary Oreco Lane
Johnstown, PA 15901
(814) 535-6556
FAX' 18141 539-1688
Indiana County Community Action Program
827 Water Street. Box 187
Indiana. PA 15701
(412) 465.2657
FAX 1(412) 466.6116
Con.umor Credit Counseling Service 01 Western
Pennsylvania, Inc.
500.()2 3rd Avenu.
Po.t Olllce Box 278
Duncansvllle, PA
(814) 696,3546
CI.INTON COUNTY
Lycomlng.Clinton Counties Commission For Community
Action (STEPI
2138 Lincoln Street
P. O. Box 1328
Wllliam.port, P A 17703
(717) 326.0687
FAX I 17171 322.2197
COLUMBIA COUNH'
Consumer Credit Counseling Service 01 Northeastern
Ponnsylvania
Human Services Building
541 Wyoming Avenue
Box t68
Scranton, PA 18501
(7171342.1072 or 1.800,922.9537
FAX' (717)342'8040
3t W. Market Street
WUkos.Berre. PA 18702
(717) 821'()837 or 1(800) 922.9537
FAX' (717) 82J.\785
Commi.slon on Economic. Opportunity 01 Luzorn.
County
211.213 South Meln Street
WUkos.Berre, PA 18701
17171826.0510 or 1(8001 822'()359 .
FAX I (7171 829.t665-CeIl bolor. fulng
(717) 455,4994 Hllelton
FAX , 17171 455'5631-CeIl belor. fulng'
(717) 836,4090 Tunkhannock
CRAWFORD COUNTY
Booker T. Washington Cen~r
1720 Holland Street
Erie, PA 16503
18141 453.5744
FAX 1(8141453.5749
Oreater Erie Community Action Committee
18 West 9th Street
Erie, PA 16501
(8141469,4581
FAX 118141 456.0t61
John F. Kennedy Center, Inc.
2021 East 20th Street
Erie, PA 16510
(8141 898,0400
FAX I 16141 898.1243
Shenango Valley Urban Leegue, Inc.
601 tndiana Avenue
Ferrell, PA 16121
(4t21981.5310
CERTIFICATE OF MAILlNO
MAY I. UIID '0fIl DOMEsne AND INTlItHA no""" MAIL. 0011 HOT
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LAW Of"nct:~
NAUMAN. Sl'UTII. S...HHLJaIl a JlALL
DA....ID C IE",-ON
.....NeE" o. HAUM"'H, .I".
,",OHN C. .ULLI....AN
oJ_ ."ClII'MCN 'IINOU"
C"AID " ..,ALoID.If.......I..
.CN.....MI,.. C. DUNLA" '"'ft.
.TI.....U:H oJ. "IEH&
UP" '-1..00"
200 NOATH THIRD STRI!:!.T
P. Q. Box 8<40
HARRISBURG, PENNSYLVANIA 17108-0840
T.I..&PIiQHC
C1ln 23&.3010
T.I.C......
Ill?} 23"-IliUlt
COUNaCL
.....L...H W. .o.,...a, oJ".
September 14, 1995
tERTlFlED MAIL
RETURN RECEIPT REOUESTED
Walter Johnson
333 North West Street
Carlisle, PA 17013
IMPORT ANT NOTICE
Re: Mellon Bank, N.A.
Loan Account Number: 418-0525436
Dear Mr. Johnson:
I urn enclosing a Notice of Default and Intent to Foreclose as required by and in compliance with
the provisions of Pennsylvania law, more particularly, Act No.6 of 1974, Act of January 30, 1974,
P.L. 13, No.6, AlOl et ~.. as amended, 41 P.S. AlOl!tl~.
THIS NOTICE OF DEFAULT AND INTENT TO EXECUTE IS EXTREMELY
IMPORTANT AND REQUIRES YOUR IMMEDIATE ATTENTION. DEFERRING ACTION ON
THIS NOTICE WILL FORCE THE BANK TO SELL YOUR HOME AT SHERIFF'S SALE.
Should you have any questions regarding this action, please contact the undersigned at the above
address and telephone number or an attorney or other advisor of your choice immediately.
"[1'
Craig J
Attorne
denmaier
or Mellon Bank, N.A.
CJS/rnlc
Enclosure
cc: Rebecca Blazina
LAW OfFICE~'>
NAUMAN, liMITlI, HUIHHLRII .II: JlALL
0"'''10 C ~.TON
...INCC" O. NAUMAN, "".
JOHN C. aUI..LIVAN
oJ. eTC"HIN "CIHOU"
C....IO ..I. aTAUOCNMAll:A
16'M fLOOR
200 NOATH THIRO STRCI:T
P O. Bo_ 840
HARRISBURO. PltNN9YLVANIA 17108-0840
TIlL'''HONIl
f1l71 13<<h~OIO
TtL.Ilr.._
17111 i13..lgl~
;
..H,JAMIN C. DUNI..A" ,JR.
aTC"HCN ..I. KCCNI:
C:OUJIII.CI.
"'...1........ W, .OYL." JR.
IMPORTANT: NOTICE OF DEFAULT AND INTENT TO FORECLOSE UNDER ACT 6
September 14, 1995
In Re:
Mellon Bank, N.A.
Account No. 418-0525436
Addresses
of
Mortgaged
Properties
110 West Penn Street, Carlisle, PA 17013
146 West North Street, Curlisle, PA 17013
55 Baltimore Street, Carlisle, PA 17013
333 North West Street, Carlisle, PA 17013
TO: Walter Johnson
.
FROM: Mellon Bank, N.A. (fonnerly The Commonwealth National Bank)
TIllS IS A NOTICE OF DEFAULT AND OF THE INTENT OF MELLON BANK, N.A.
TO FORECLOSE ON YOUR MORTGAGE. PLEASE READ ALL OF THIS NOTICE.
The Bank holds a Note which is signed by Walter Johnson and Lindora Johnson dated June 10,
1985 in the original amount of $50,640.00. The Bank also holds a mortgage on a residence at the
above address, securing the agreement.
The mortgage and your Note are in serious default because vou have failed to Dav when due
monthly Installments of principal and interest and escrow in the amount of $787.47 each for the
months of June, July, August, September, October, November and December of 1994 and January,
February, March, April, May, June, July, August and September of 1995. THE TOTAL AMOUNT
YOU NOW OWE IS $12,599.52.
If the Bank does not receive full payment from you by October 14, 1995, you must add an
additional $787.47 for the monthly installment due,on the following day.
You may CURE THE DEFAULT and restore the morlj1aj1e and aj1reement to the same positioll
as if the default had not occurred by payini to us in full the amount of $13.386.99 WITHIN THIRTY
1301 DAYS after the date of the notice.
Payment of the amount of oyerdue monthly installments, now totaling $12,599.52 (plus any
installment becomes due before the Bank receiyes payment, as provided aboYe) must be made by wl4
cashIer's check. or certified check.
Payment must be made at the offices of Nauman, Smith, Shissler & Hall, 200 North Third
Street, Harrisburg, Pennsylyania between the hours of 8:30 am and 5:00 prn, Monday through Friday,
or by mail addressed to Cralg J. Staudenmaler, Esquire, Nauman, Smith, Shissler & Hall, P.O. Box
840, Harrisburg, PA 17108.
If payment is not receiyed within THIRTY (30) DAYS AFTER THE DATE OF THIS
NOTICE, THE BANK MAY, WITHOUT ANY FURTHER NOTICE TO YOU, DO ANY OF THE
FOLLOWING:
(I) ACCELERATE THE MATURITY DATE OF THE MORTGAGE AND DECLARE
THE ErfiJRE AMOUNT OF THE UNPAID PRINCIPAL BALANCE of the mortgage, which is
now $16,920.05 and all other sums due under the mortgage TO BE IMMEDIATELY DUE AND
PAYABLE. This means that, unless you cure the default in accordance with this notice, you could
immediately owe to us this full sum, plus other sums that may then be due.
(2) BEGIN LEGAL PROCEEDINGS TO FORECLOSURE UPON THE MORTGAGE IN
WmCH PROCEEDINGS THE SHERIFF MAY SELL THE HOUSE SUBJECT TO ITS
MORTGAGE,
(3) TAKE POSSESSION OF THE PROPERTY, and proceed to have vou ejected from the
property.
(4) SUE YOU PERSONALLY FOR THE SAID UNPAID PRINCIPAL BALANCE and other
sums due under the Mortgage and/or Agreement.
WARNING: If you pay the amount more than thirty (30) days after the date of this
notice, and the Bank has referred this matter to its lawyers for legal action, you may
haye to pay an attorney's fee of up to $50.00 and the cost of the title search and report,
in addition to the oUler amounts due, in ordcr to cure the default. Furthermore, if you
pay the amounts due more than thirty (30) days after the date of this letter and the Bank's
lawyers have started legal proceedings, you may haye to pay additional legal expenses,
including court costs and attorney's fees that may exceed $50.00, in order to cure the
default.
If you pay the amounts due more than thirty (30) days after the date of this notice, you must
contact Craig J. Staudenmaler, Esquire, Nauman, Smith, Shissler & Hall at 200 North Third Street,
Harrisburg, Pennsylvania, telephone number (717) 236-3010 to find out the exact amount you must pay
in order to cure the default..
LAW O,..ncr;s
NAU.,AN. HMITII, HIIIKHLIlIR ,. JlALL
OAVID C. IATOH
."IlNCllA O. HAUMAN, .Ut.
JOHN C. .UL",IVAN
.I. .T....H.N ",IHOU"
C"AIO .J. aTAUO.H...AII"
181M FLOOR
ZOO NORTH THIRD STRItET
R O. BOl( 8"0
HARRIBBURO, P~NN5YLVANIA 17108..0840
.'
i
..NJAWIN Co OUHL.A" .I".
eTI..HIN .I. 1I..IHI
T"L.JlHONI:
(7171 230.3010
TIL.''''.
(717) 13"'UUD
COUNel..
"ALJltH W. .0'1''''1_, "'It.
September 14, 1995
CERTIFffiD MAIL
RETURN RECEIPT REOUESTED
Lindora Johnson
110 West Penn Street
Carlisle, PA 17013
IMPORTANT NOTICE
Re: Mellon Bank, N.A.
Loan Account Number: 418-0525436
Dear Ms. Johnson:
1 am enclosing a Notice of Default and Intent to Foreclose as required by and in compliance with
the provisions of Pennsylyania law, more particularly, Act No.6 of 1974, Act of January 30, 1974,
P.L. 13, No.6, ti101 et seq., as amended, 41 P.S. til01 ~ g;g.
THIS NOTICE OF DEFAULT AND INTENT TO EXECUTE IS EXTREMELY
IMPORTANT AND REQUIRES YOUR IMMEDIATE ATIENTION. DEFERRING ACTION ON
THIS NOTICE WILL FORCE THE BANK TO SELL YOUR HOME AT SHERIFF'S SALE.
Should you have any questions regarding this action, please contact the undersigned at the above
address and telephone number or an attorney or other advisor of your choice immediately.
Sincerely yours,
CJS/rnlc
Enclosure
cc: Rebecca Blazina
enmaier
Mellon Bank, N.A.
.....
LAW O"''-.CES
NAUMAN, SMIT.., SI1I88LIlIII a. HALL
DAVIQ C. I.TON
."CHCIU' Q. NAUM..... "'...
.I0HN c. aULl..IV"'H
.I. ITe"...I:N "I.INOU"
C"AIO oJ. .TAUO&N"'.III"
leT" FLOOR
zoo ttORTH THIRD STAr;ET
F! O. BOle 840
HARAISUURO, PENNSY'-VANIA 17108-0840
.I:.."'.....IH C. OUH"'." ......
aTI"HIlH .I. "CliNe
TCL.C"WOHC
'7171 .1311'3010
T."'......
{'717, a34-IQZ15
COUNa.1.
"..."... 'II, .OYI.."., ."..
IMPORTANT: NOTICE OF DEFAULT AND INTENT TO FORECLOSE UNDER ACT 6
September 14, 1995
In Re:
Mellon Bank, N.A.
Account No. 418-0525436
Addresses
of
Mortgaged
Properties
110 West Penn Street, Carlisle, PA 17013
146 West North Street, Carlisle, PA 17013
55 Baltimore Street, Carlisle, PA 17013
333 North West Street, Carlisle, PA 17013
TO: Lindora Johnson
FROM: Mellon Bank, N.A. (formerly The Commonwealth National Bank)
THIS IS A NOTICE OF DEFAULT AND OF THE INTENT OF MELLON BANK, N.A.
TO FORECLOSE ON YOUR MORTGAGE. PLEASE READ ALL OF TillS NOTICE.
The Bank holds a Note which is signed by Walter Johnson and Lindora Johnson dated June 10,
1985 in the original amount of $50,640.00. The Bank also holds a mortgage on a residence at the
above address. securing the agreement.
The mortgage and your Note are in serious default because vou have failed to pav when due
monthlv Installments of principal and interest and escrow in the amount of $787.47 each for the
months of June. July, August. September, October, November and December of 1994 and January.
February, March, April, May. June, July, August and September of 1995. THE TOTAL AMOUNT
YOU NOW OWE IS $12,599.52.
If the Bank does not receive full payment from you by October 14, 1995, you must add an
additional $787.47 for the monthly installment due on the following day.
-
You may CURE THE DEFAULT and restore the mort2a2e and aireement to the same position
as if the default had not occurred by pavinllto us in full the amoun! of $13.386.99 WITHIN TmRTY
/30\ DAYS after the date of the notice.
Payment of the amount of overdue monthly installmenlS, now totaling $12,599.52 (plus any
installment bec.omes due before the Bank receives payment, as provided above) must be made by wh.
cashier's check. or certified check.
Payment must be made at the offices of Nauman, Smith, Shl.s!ller & Hall. 200 North Third
Street, Harrisburg, Pennsylvania between the hours of 8:30 am and 5:00 pm, Monday through Priday,
or by mail addressed to CralgJ. Staudenmaler, Esquire, Naumau, Smith, Shissler & Hall. P.O. Box
840, Harrisburg, PA 17108.
If payment is not received within THIRTY (30) DAYS AFTER THE DATE OF THIS
NOTICE, THE BANK MAY, WITHOUT ANY FURTHER NOTICE TO YOU, DO ANY OF THE
FOLLOWING:
(I) ACCELERATE THE MATURITY DATE OF THE MORTGAGE AND DECLARE
THE ENTIRE AMOUNT OF THE UNPAID PRINCIPAL BALANCE of the mortgage, which is
now $16,920.05 and all other sums due under the mortgage TO BE IMMEDIATELY DUE AND
PAYABLE. This means that, unless you cure the default in accordance with this notice, you could
immediately owe to us this full sum, plus other sums that may then be due.
(2) BEGIN LEGAL PROCEEDINGS TO FORECLOSURE UPON THE MORTGAGE IN
WillCII PROCEEDINGS THE SHERIFF MAY SELL THE HOUSE SUBJECT TO ITS
MORTGAGE.
(3) TAKE POSSESSION OF THE PROPERTY, and proceed to have vou ejected from the
property.
(4) SUE YOU PERSONALLY FOR THE SAID UNPAID PRINCIPAL BALANCE and other
sums due under the Mortgage and/or Agreement.
WARNING: If you pay the amount more than thirty (30) days after the date of this
notice, and the Bank has referred this matter to ilS lawyers for legal action, you may
have to pay an attorney's fee of up to $50.00 and the cost of the title search and report.
in addition to the other amounlS due, in order to cure the default. Furthermore, if you
pay the amounts due more than thirty (30) days after the date of this letter and the Bank's
lawyers have started legal proceedings, you may have to pay additional legal expenses,
including court coslS and attorney's fees that may exceed $50.00, in order to cure the
default.
If you pay the amounts due more than thirty (30) days after the date of this notice, you must
contact Craig J. Staudenmaler, Esquire, Nauman, Smith, Shissler & Hall at 200 North Third Street,
Harrisburg, Pennsylvania, telephone number (717) 236-3010 to find out the exar,t amount you must pay
in order to cure the default.
..
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.
You have thc rll!ht to curc thc default at any tlmc until one hour before the Sale on the day
vour nrooertv Is scheduled for Sheriff Sale. A notice of the date of the Sheriff Sale will be sent to
you before the sale. Please remember, however that the amounts due will increase the longer you wait
to cure the default.
You also bave the rlllht to sell or transfer vour propertv sublect to the Mortl!al!e with the
Bank's Dermlsslon: and the buyer or transferee will have the same r12ht as you do to cure the
default. You also have the rlllht to refinance the Morteaf,le with. or obtain a new mortllal!e from.
another bank or lender.
Any sale, transfer or refinance must be completed by, and notice thereof must be given on or
before one (1) hour before the time set for the Sheriffs Sale.
You have the right to cure a default, after notice of default from the Bank, on1v three (3) times
in any calendar year.
SPECIAL NOTICE
Your payment to the bank of less than the total amount you NOW owe will not cure your
default, and while the bank, in ilS sole discretion may accept a partial payment, such acceptance l!lll
Illl.l waive ilS right to proceed with any of the remedies described herein, but will only reduce your 1lItJ\J
balance owing on the Mortgage and/or Agreement.
MELLON BANK, N,A.
denmaler, Esquire
r Mellon Bank; N.A.
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i J, t 1 .,.uor 2 for IddItIonIiI HMctI.
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I return thiI ani to you. ,
, AttIoh ~ 'ann to the front of tht IMilpNce. Of on !he bKk If IPllctI
float lip' _.
I , Wrim ""ttum Atct!pt AtqultltH" on the mIII~ below the artidt number
'0 . The Return R.ctIpt wll ahaw to whom tht ItUcIt w...~ Ind the dati
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zoo NORTH THlno STRl;E T
P. 0 Box 840
HARRISBURG, PENNSYLVANIA 17108-0840
rll.l"HOHI
(717) 230-3010
Tcu:r.u
17171 .I34.'VIS
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CQUNa.",
""I._H W. aCT".., .JR.
September 14, 1995
CERTIF1J!:T.i' MAIL
RETURN RECEIPT REOUESTED
Llndora Johnson
110 West PeM Street
Carlisle, PA 17013
IMPORTANT NOTICE
Re: Mellon Bank, N.A.
Loan Account Number: 418-0525436
Dear Ms. Johnson:
I am enclosing a Notice of Default and Intent to Foreclose as required by and in compliance with
the provisions of Pennsylvania law, more panicularly, Act No.6 of 1974, Act of January 30, 1974,
P.L. 13, No.6, UOI et ~., as amended, 41 P.S. ~101 ~ sea.
THIS NOTICE OF DEFAULT AND INTENT TO EXECUTE IS EXTREMELY
IMPORTANT AND REQUIRES YOUR IMMEDIATE ATTENTION. DEFERRING ACTION ON
THIS NOTICE WILL FORCE THE BANK TO SELL YOUR HOME AT SHERIFF'S SALE.
Should you have any questions regarding this action, please contact the undersigned at the above
address and telephone number or an attorney or other advisor of your choice immediately.
CJS/mlc
Enclosure
cc: Rebecca Blazina
enmaier
Mellon Bank, N.A.
LAW O~'FICE5
NAUMAN, 8MITII, 811188...11I.. a. HALL
0.....'0 c_ EATOH
....Nce.. 0. NAUMAN, "...
""OHN c. aULLWAN
,J. aTe_HCN '1 tHOU..
C""tQ oJ, .TAUOEN.....'C"
18TH fl.OOR
ZOO NOATH THIRD STREET
P. Q. BoJIC B4Q
HARRlseUAO, PENNSyL......NIA 17108-0840
T.I....HQHIl
('717)13115.3010
TIlI.Il.....
(717) a3~-I~.D
."N""A"'IN r.. DUNL"'" "R,
.TC.....IN "", ".CHI:
eOUNaCL
....L...H W. BOYLC" JR,
IMPORTANT: NOTICE OF DEFAULT AND INTENT TO FORECLOSE UNDER ACT 6
September 14, 1995
In Re:
Mellon Bank, N.A.
Account No. 418-0525436
Addresses
of
Mortgaged
Properties
110 West Penn Street, Carlisle, PA 17013
146 West North Street. Carlisle, PA 17013
55 Baltimore Street, Carlisle, PA 17013
333 North West Street, Carlisle, PA 17013
TO: Lindora Johnson
FROM: Mellon Bank, N.A. (formerly The Commonwealth National Bank)
THIS IS A NOTICE OF DEFAULT AND OF THE INTENT OF MELLON BANK, N.A.
TO FORECLOSE ON YOUR MORTGAGE. PLEASE READ ALL OF THIS NOTICE.
The Bank holds a Note which is signed by Walter Johnson and Undora Johnson dated June 10,
1985 in the original amount of $50,640.00. The Bank also holds a mortgage on a residence at the
above address, securing the agreement.
The mortgage and your Note are in serious default because YOI1 have failed to Dav when due
monthlv installments of principal and interest and escrow in the amount of $787.47 each for the
months of June, July, August, September. October. November and December of 1994 and January,
February, March, April, May, June, July, August and September of 1995. THE TOTAL AMOUNT
YOU NOW OWE IS $12,599.52.
If the Bank does not receive full payment from you by October 14, 1995. you must add an
additional $787.47 for the monthly installment due on the following day.
.Ylllunay CURE TilE IlEFAUI,'1' and rcstorc thc lIlur1llallc and llllrcclIlclIlto the same positlolj
as if the default had not occurred by paylnllto us ill fullthc.JUll1lUIlLuUU.:ul.fi..2llilTIllN THIRTY
(30) IlA YS aftcr the date of the notlcc.
Payment of the amount of ovcrdue lIlollthly InsllIllmcnls, now tolllling $12,599.52 (plus any
installment becomes due before Ihe Bank receives payment, as provided above) lIlust be made by ~
cashier's check. or certified check.
Payment must be made at tile offices of Naumllll, Smllh, ShL'Ilder & 11011, 200 North Third
Street, Harrisburg, Pennsylvania between the hours of 8:30 alll and 5:00 Pill, Monday through Friday,
or by mall addressed to Crlllg J, Slaudcnmaler, Esquire, Nlluman, Smllh, Shbi..lcr & 11011, P.O. Box
840, Harrisburg, PA 17108.
If payment is not received within TIIIRTY (30) nAVS A"'I'I~R Tm~ DATE OF THIS
NOTICE, TIlE BANK MA Y, WITIIOUT ANY FUR1'III~R NOTICE TO YOU, DO ANY OF THE
FOLLOWING:
(I) ACCELERATE TilE MATURITY DATE (W TIII~ MORTGAGE AND DECLARE
THE ENTIRE AMOUNT OF TIlE UNPAID PRINCIPAL BALANCE of tile mortgage, which is
now $16,920.05 and all other sums due under llle mortgage 1'0 liE IMMEI>IATELY DUE AND
PAY ABI,E. This means tllat, unless you cure \Jle default In accordance with this notice, you could
Immediately owe to us tills full sum, plus othcr sums that may then be due.
(2) IIEGlN LEGAL I'ROClllmlNGS '1'0 I"ORI~CLOSURE UI'ON TilE MORTGAGE IN
WHICII PROCEEDINGS TIII~ SIIEltWI" MAY sm.L TIII~ 1I0USE SUBJECT TO ITS
MORTGAGE,
(3) TAKE I'OSSESSION OF Tim 1'I{()l~UIT, and procecd to havc you ejected from the
property.
(4) SUE YOU PERSONALL V !I()({ '1'1 m SA II) UNI'AIU I'RINCIPAL BALANCE and other
sums due under the Mortgage and/or ^grcclIlellt.
WARNING: If you pay the alllount lIlorc Ihlln Ihlrty (30) days after the date of this
notice, and the Bank hilS referred this IIUlller 10 lu 11Iwycrs for legal actloll, you may
have to pay an attorney's fee Ill' up to $50.()() allllthc cost of the title search and report,
in additiollto the othcr lImOllnts due, In nrdcr to curc the default, Furthermore, if you
pay tile amounlB due more tlmn thirty (30) dllYs aftcr the dllte of this leUer and the Bank's
lawyers have started legal procccdings, you lIlay hllve tll PllY lldditionallegal expenses,
including court costs llnd attorney's fces Ihat 1Il1lY cxcccd $50.00, in order to cure the
default
If you pay the lImounts due lII11rc thlln thirty (30) dllYs IIftcr the date of this notice, you must
contact Craig J. Staudenmalcr, 1~.(IUll'c, NllUlllIlll, Smith, ShL.slcr & 11011 at 200 North Third Street,
Harrisburg, I'cnn,'ylvllnla, tclcphonc numhcr (717) 236.30 I 0 to find out the exact amount you must pay
in ordcr tll cure thc defllult.
"
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MAY II USlO FOR DOMEsne AND INTlRNAnOHAL MAIL. DOES NOT
,"OVID. fOR INSURANCI-POSTMASTER
R".,,"',om: CraIg-X Shuder\mQI eJr
h.ln 11t1'Y1V1 .~,th,ChissJf'V.. ~ &..11
7 () -pn}( 7?fkJ
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On. IN.el of ordln.1V m.1I .ddr....d 10:
Lirdcwa - hnson
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Aftlll I.. hll.1n Itamp'
or mlllr polt.g. and
POI' milk. Inqulr. 01
po,tm"11f fa, curt,nl
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PS Form 3817. Mar. 1989
GPO I 1993 0 - 151-051
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"
VERIFICATION
I, Margllret Campfield, Senior Foreclosure Specialistof Mellon Bank, N.A., Plaintiff
in the foregoing proceeding, make the following statement subject to the penalties of 18 Pa.C.S.
~4909, relating to unsworn falsifications to authorities, and do state that as Senior Foreclosure
Specialist of Mellon Bank, N.A.. I am authorized to make this verification on its behalf, and do
state that the facts set forth in the foregoing Complaint are true and correct to the best of my
knowledge, information and belief.
r ~_~lD..aX'
Witness
Date: 4-2.5-Q7
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