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HomeMy WebLinkAbout98-01507 3. Defendants Duane E. Kress and Michelle R. Kress have held themselves out to be the current registered owners ora 1970 Hillcrest mobile home, having a serial number ofHDI12D. 4. Approximately four (4) years ago, Defendants Duane E. Kress and Michelle R. Kress vacated the mobile home in which they were living, abandoning said mobile home on the Lot # II of Weaver's Mobile Home Park which Defendants Duane and Michelle Kress had rented from the Plaintiff, Arthur E. Weaver. 5. Since the time that Defendants Duane and Michelle Kress abandoned their 1970 Hillcrest mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the roof and awning have collapsed, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 6. Since 1994, Defendants Duane and Michelle Kress have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Duane E Kress and Michelle R. Kress's abandonment of the 1970 Hillcrest mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, " the Plaintiff respeetfully requests that this Honorable Court extinguish all right, title and interest of Defendants Duane E. Kress and Michelle R. Kress, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 7. Defendants Paul L. Annolt and Cynthia F. Annolt are both adult individuals whose last known address was located at 52 South High Street, Newville, Cumberland County, Pennsylvania 17241. 8. Defendants PaulL. Annolt and Cynthia F. Annolt have held themselves out to be the current registered owners of a 1963 Marlette mobile home, having a serial number of M255FDCA3119. 9. Approximately four (4) years ago, Defendants Paul L. Annolt and Cynthia F. Annolt vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 5 of Weaver's Mobile Home Park which Defendants Paul L. Armolt and Cynthia F. Annolt had rented from the Plaintiff, Arthur E. Weaver. 10. Since the time that Defendants PaulL. Annolt and Cynthia F. Annolt abandoned their 1963 Marlette mobile home, no lot rent has been paid and the condition of the mobile home has -,-.' " deteriomted and been vandalized to the extent that the windows of the mobile are broken, making the mobile home inappropriate and unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. II. Since 1994, Defendants Paul L. Annolt and Cynthia F. Annolt have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Paul L. Annolt and Cynthia F. Annolt abandonment of the 1963 Marlette mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for stomge or lot rent, the Plaintiff respectfully requests that this Honomble Court extinguish all right, title and interest of Defendants Paul L. Annolt and Cynthia F. Annolt, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 12. Defendant Angela M. Vanlaere is an adult individual whose last known address was located at 245 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 13. '. Defendant Angela M. Vanlaere has held herself out to be the current registered owner of a 1964 Parkway mobile homc, having a serial number of 250FKRA 1255. 14. Approximately four (4) years ago, Defendant Angela M. Vanlaere vacated the mobile home in which she was living, abandoning said mobile home on the Lot # 10 of Weaver's Mobile Home Park which Defendant Angela M. Vanlaere had rented from the Plaintiff, Arthur E. Weaver. IS. Since the time that Defendant Angela M. Vanlaere abandoned her 1964 Parkway mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the central beam is cracked, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 16, Since 1994, Defendant Angela M. Vanlaere has made no attempt to reclaim her mobile home, and has failed to respond to Plaintiff's attempts to contact said defendant for removal of the mobile home from his property. WHEREFORE, based upon Defendant Angela M. Vanlaere's abandonment of the 1964 Parkway mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendant Angela M.Vanlaere, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 17. Defendant James E. Lewis is an adult individual whose Inst known nddre3s wns located at 650 North College Street, Carlisle, Cumberland County, Pennsylvania 17013. 18. Defendant James E. Lewis hns held himself out to be the current registered owner of a 1965 Crestwood mobile home, having a serial number of 9945E. 19. Approximately four (4) years ago, Defendant James E. Lewis vacated the mobile home in which he wns living, abandoning said mobile home on the Lot # 13 of Weaver's Mobile Home Park which Defendant James E. Lewis had rented from the Plaintiff, Arthur E. Weaver. 20. Since the time that Defendant James E. Lewis abandoned his 1965 Crestwood mobile home, no lot rent or other storage fee hns been paid and the condition of the mobile home hns deteriorated. "'-. .' 3. Defendants Duane E. Kress and Michelle R. Kress have held themselves out to be the current registered owners ofa 1970 Hillcrest mobile home, having a serial number ofHD112D. 4. Approximately four (4) years ago, Defendants Duane E. Kress and Michelle R. Kress vacated the mobile home in which they were living, abandoning said mobile home on the Lot # II of Weaver's Mobile Home Park which Defendants Duane and Michelle Kress had rented from the Plaintiff, Arthur E. Weaver. S. Since the time that Defendants Duane and Michelle Kress abandoned their 1970 Hillcrest mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the roof and awning have collapsed, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 6. Since 1994, Defendants Duane and Michelle Kress have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Duane E Kress and Michelle R. Kress's abandonment of the 1970 Hillcrest mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, .. the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendant~ Duane E. Kress and Michelle R. Kress, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 7. Defendants Paul L. Annolt and Cynthia F. Annolt are both adult individuals whose last known address was located at 52 South High Street, Newville, Cumberland County, Pennsylvania 17241. 8. Defendants Paul L. Annolt and Cynthia F. Annolt have held themselves out to be the current registered owners of a 1963 Marlette mobile home, having a serial number of M255FDCA3119. 9. Approximately four (4) years ago, Defendants Paul L. Annolt and Cynthia F. Armolt vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 5 of Weaver's Mobile Home Park which Defendants PaulL. Annolt and Cynthia F. Annolt had rented from the Plaintiff, Arthur E. Weaver. 10. Since the time that Defendants Paul L. Annolt and Cynthia F. Annolt abandoned their 1963 Marlette mobile home, no lot rent has been paid and the conditiDn of the mobile home has deteriorated and been vandalized to the extent that the windows of the mobile are broken, making the mobile home inappropriate and unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. II. Since 1994, Defendants Paul L. Annolt and Cynthia F. Annolt have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Paul L. Annolt and Cynthia F. Annolt abandonment of the 1963 Marlette mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honomble Court extinguish all right, title and interest of Defendants Paul L. Annolt and Cynthia F. Annolt, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 12. Defendant Angela M. Vanlaere is an adult individual whose last known address was located at 245 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 13. .' Defendant Angela M. Vanlaere has held herself out to be the current registered owner of a 1964 Parkway mobile home, having a serial number of2S0FKRAI2SS. 14. Approximately four (4) years ago, Defendant Angela M. Vanlaere vacated the mobile home in which she was living, abandoning said mobile home on the Lot # 10 of Weaver's Mobile Home Park which Defendant Angela M. Vanlaere had rented from the Plaintiff, Arthur E. Weaver. 15. Since the time that Defendant Angela M. Vanlaere abandoned her 1964 Parkway mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the central beam is cracked, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 16. Since 1994, Defendant Angela M. Vanlaere has made no attempt to reclaim her mobile home, and has failed to respond to Plaintiff's attempts to contact said defendant for removal of the mobile home from his property. WHEREFORE, based upon Defendant Angela M. Vanlaere's abandonment of the 1964 Parkway mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish al1 right, title and interest of Defendant Angela 3. Defendants Duane E. Kress and Michelle R. Kress have held themselves out to be the current registered owners ofa 1970 Hillcrest mobile home, having a serial numberofHDl12D. 4. Approximately four (4) years ago, Defendants Duane E. Kress and Michelle R. Kress vacated the mobile home in which they were living, abandoning said mobile home on the Lot # II of Weaver's Mobile Home Park which Defendants Duane and Michelle Kress had rented from the Plaintiff, Arthur E. Weaver. 5. Since the time that Defendants Duane and Michelle Kress abandoned their 1970 Hillcrest mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the roof and awning have collapsed, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 6. Since 1994, Defendants Duane and Michelle Kress have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Duane E Kress and Michelle R. Kress's abandonment of the 1970 Hillcrest mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the PlaintilTrespectfully requests that this Honorable Court extinguish all right, title and interest of Defendants Duane E. Kress and Michelle R. Kress, to:~ether with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the PlaintilT, Arthur E. Weaver. 7. Defendants Paul L. Armolt and Cynthia F. Armolt are both adult individuals whose last known address was located at 52 South High Street, Newville, Cumberland County, Pennsylvania 17241. 8. Defendants Paul L. Armolt and Cynthia F. Armolt have held themselves out to be the current registered owners of a 1963 Marlette mobile home, having a serial number of M255FDCA3119. 9. Approximately four (4) years afo, Defendants Paul L. Armolt and Cynthia F. Armolt vacated the mobile home in which the) were living, abandoning said mobile home on the Lot # 5 of Weaver's Mobile Home Park which Defendants Paul L. Armolt and Cynthia F. Armolt had rented from the Plaintiff, Arthur E. w.~aver. 10. Since the time that Defendantl Paul L. Armolt and Cynthia F. Armolt abandoned their 1963 Marlette mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated and been vandalized to the extent that the windows of the mobile are broken, making the mobile home inappropriate and unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 11. Since 1994, Defendants Paul L. Armolt and Cynthia F. Armolt have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Paul L. Armolt and Cynthia F. Armolt abandonment of the 1963 Marlette mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendants Paul L. Armolt and Cynthia F. Armolt, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 12. Defendant Angela M. Vanlaere is an adult individual whose last known address was located at 245 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 13. Defendant Angela M. Vanlaere has held herself out to be the current registered owner of a 1964 Parkway mobile home, having a serial number of250FKRA1255. 14. Approximately four (4) years ago, Defendant Angela M. Vanlaere vacated the mobile home in which she was living, ablUldoning said mobile home on the Lot # 10 of Weaver's Mobile Home Park which Defendant Angela M. Vanlaere had rented from the Plaintiff, Arthur E. Weaver. 15. Since the time that Defendant Angela M. Vanlaere abandoned her 1964 Parkway mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the central beam is cracked, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 16. Since 1994, Defendant Angela M. Vanlaere has made no attempt to reclaim her mobile home, and has failed to respond to Plaintiff's attempts to contact said defendant for removal of the mobile home from his property. WHEREFORE, based upon Defendant Angela M. Vanlaere's abandonment of the 1964 Parkway mobile home on the Piaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendant Angela .. 3. Defendants Duane E. Kress and Michelle R. Kress have held themselves out to be the current registered owners of a 1970 Hillcrest mobile home, having a serial number ofHD l12D. 4. Approximately four (4) years ago, Defendants Duane E. Kress and Michelle R. Kress vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 11 of Weaver's Mobile Home Park which Defendants Duane and Michelle Kress had rented from the Plaintiff, Arthur E. Weaver. 5. Since the time that Defendants Duane and Michelle Kress abandoned their 1970 Hillcrest mobile home, no lot rent has been paid a.,d the condition of the mobile home has deteriorated to such an extent that the roof and awning have collapsed, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 6. Since 1994, Defendants Duane and Michelle Kress have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Duane E Kress and Michelle R. Kress's abandonment of the 1970 Hillcrest mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, . ' ., ,. deteriorated and been vandalized to the extent that the windows of the mobile are broken, making the mobile home inappropriate and unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 11. Since 1994, Defendants Paul L. Armolt and Cynthia F. Armolt have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Paul L. Armolt and Cynthia F. Armolt abandonment of the 1963 Marlette mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendants Paul L. Armolt and Cynthia F. Armolt, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 12. Defendant Angela M. Vanlaere is an adult individual whose last known address was located at 245 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 13. , I 01 o. Defendant Angela M. Vanlaere has held hernelf out to be the current registered owner of a 1964 Parkway mobile home, having a serial number of250FKRA1255. 14. Approximately four (4) years ago, Defendant Angela M. Vanlaere vacated the mobile home in which she was living, abandoning said mobile home on the Lot # 10 of Weaver's Mobile Home Park which Defendant Angela M. Vanlaere had rented from the Plaintiff, Arthur E. Weaver. IS. Since the time that Defendant Angela M. Vanlaere abandoned her 1964 Parkway mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the central beam is cracked, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 16. Since 1994, Defendant Angela M. Vanlaere has made no attempt to reclaim her mobile home, and has failed to respond to Plaintiff's attempts to contact said defendant for removal of the mobile home from his property. WHEREFORE, based upon Defendant Angela M. Vanlaere's abandonment of the 1964 Parkway mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiffrespectfully requests that this Honorable Court extinguish all right, title and interest of Defendant Angela , I .' M.Vanlaere, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 17. Defendant James E. Lewis is an adult individual whose last known address was located at 650 North College Street, Carlisle, Cumberland County, Pennsylvania 17013. 18. Defendant James E. Lewis has held himself out to be the current registered owner of a 1965 Crestwood mobile home, having a serial number of 9945E. 19. Approximately four (4) years ago, Defendant James E. Lewis vacated the mobile home in which he was living, abandoning said mobile home on the Lot # 13 of Weaver's Mobile Home Park which Defendant James E. Lewis had rented from the Plaintiff, Arthur E. Weaver. 20. Since the time that Defendant James E. Lewis abandoned his 1965 Crestwood mobile home, no lot rent or other storage fee has been paid and the condition of the mobile home has deteriorated. .. 3. Defendants Duane E. Kress and Michelle R. Kress have held themselves out to be the current registered owners ofa 1970 Hillcrest mobile home, having a serial number ofHD112D. 4. Approximately four (4) years ago, Defendants Duane E. Kress and Michelle R. Kress vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 11 of Weaver's Mobile Home Park which Defendants Duane and Michelle Kress had rented from the Plaintiff, Arthur E. Weaver. 5. Since the time that Defendants Duane and Michelle Kress abandoned their 1970 Hillcrest mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the roof and awning have collapsed, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 6. Since 1994, Defendants Duane and Michelle Kress have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Duane E Kress and Michelle R. Kress's abandonment of the 1970 Hillcrest mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, .. .. the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendants Duane E. Kress and Michelle R. Kress, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 7. Defendants Paul L. Armolt and Cynthia F. Armolt are both adult individuals whose last known address was located at 52 South High Street, Newville, Cumberland County, Pennsylvania 17241. 8. Defendants Paul L. Armolt and Cynthia F. Armolt have held themselves out to be the current registered owners of a 1963 Marlette mobile home, having a serial number of M255FDCA3119. 9. Approximately four (4) years ago, Defendants Paul L. Armolt and Cynthia F. Armolt vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 5 of Weaver's Mobile Home Park which Defendants Paul L. Arrnolt and Cynthia F. Armolt had rented from the Plaintiff, Arthur E. Weaver. 10. Since the time that Defendants Paul L. Armolt and Cynthia F. Armolt abandoned their 1963 Marlette mobile home, no lot rent has been paid and the condition of the mobile home has " " deteriorated and been vandalized to the extent that the windows of the mobile are broken, making the mobile home inappropriate and unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 11. Since 1994, Defendants Paul L. Armolt and Cynthia F. Armolt have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Paul L. Arrnolt and Cynthia F. Annolt abandonment of the 1963 Marlette mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendants Paul L. Annolt and Cynthia F. Armolt, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 12. Defendant Angela M. Vanlaere is an adult individual whose last known address was located at 245 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 13. " Defendant Angela M. Vanlaere has held herself out to be the current registered owner of a 1964 Parkway mobile home, having a serial number of250FKRA125S. 14. Approximately four (4) years ago, Defendant Angela M. Vanlaere vacated the mobile home in which she was living, abandoning said mobile home on the Lot # 10 of Weaver's Mobile Home Park which Defendant Angela M. Vanlaere had rented from the Plaintiff, Arthur E. Weaver. 15. Since the time that Defendant Angela M. Vanlaere abandoned her 1964 Parkway mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the central beam is cracked, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 16. Since 1994, Defendant Angela M. Vanlaere has made no attempt to reclaim her mobile home, and has failed to respond to Plaintiff's attempts to contact said defendant for removal of the mobile home from his property. WHEREFORE, based upon Defendant Angela M. Vanlaere's abandonment of the 1964 Parkway mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendant Angela " .0 M.Vanlaere,together w,th any and all other persons who may have an interest in said mobile home, anll award title alld ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 17. Defendant Jamel: E. Lewis is an adult individual whose last known address was located at 650 North College Street, Carlisle, Cumberland County, Pennsylvania 17013. 18. Defendant Jame:l E. Lewis has held himself out to be the current registered owner of a 1965 Crestwood mobile hom,:, having a serial number of9945E. 19. Approximately four (4) years ago, Defendant James E. Lewis vacated the mobile home in which he was living, at-andoning said mobile home on the Lot # 13 of Weaver's Mobile Home Park which Defendant James E. Lewis had rented from the Plaintiff, Arthur E. Weaver. 20. Since the time that Defendant James E. Lewis abandoned his 1965 Crestwood mobile home, no lot rent or other storage fee has been paid and the condition of the mobile home has deteriorated. ,,' '-' 3. Defendants Duane E. Kress and Michelle R. Kress have held themselves out to be the current registered owners ofa 1970 Hillcrest mobile home, having a serial numberofHDll2D. 4. Approximately four (4) years ago, Defendants Dunne E. Kress and Michelle R. Kress vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 11 of Weaver's Mobile Home Park which Defendants Duane and Michelle Kress had rented from the Plaintiff, Arthur E. Weaver. 5. Since the time that Defendants Duane and Michelle Kress abandoned their 1970 Hillcrest mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the roof and awning have collapsed, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 6. Since 1994, Defendants Duane and Michelle Kress have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Duane E Kress and Michelle R. Kress's abandonment of the 1970 Hillcrest mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendants Duane E. Kress and Michelle R. Kress, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 7. Defendants Paul L. Armolt and Cynthia F. Armolt are both adult individuals whose last known address was located at 52 South High Street, Newville, Cumberland County, Pennsylvania 17241. 8. Defendants Paul L. Armolt and Cynthia F. Armolt have held themselves out to be the current registered owners of a 1963 Marlette mobile home, having a serial number of M255FDCA3119. 9. Approximately four (4) years ago, Defendants Paul L. Armolt and Cynthia F. Armolt vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 5 of Weaver's Mobile Home Park which Defendants Paul L. Armolt and Cynthia F. Armolt had rented from the Plaintiff, Arthur E. Weaver. 10. Since the time that Defendants Paul L. Arrnolt and Cynthia F. Armolt abandoned their 1963 Marlette mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated and becn vandalizcd to the extent that the windows of the mobile are broken, making the mobile home inappropriate and unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. I!. Since 1994, Defendants Paul L. Armolt and Cynthia F. Armolt have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Paul L. Armolt and Cynthia F. Armolt abandonment of the 1963 Marlette mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for stomge or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendants Paul L. Armolt and Cynthia F. Armolt, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 12. Defendant Angela M. Vanlaere is an adult individual whose last known address was located at 245 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 13. Defendant Angela M. Vanlaere has hcld hersclf out to be the current registered owner of a 1964 Parkway mobile home, having a serial numbcr of250FKRA1255. 14. Approximately four (4) years ago, Dcfendant Angela M. Vanlaere vacated the mobile home in which she was living, abandoning said mobile home on the Lot # 10 of Weaver's Mobile Home Park which Defendant Angela M. Vanlaere had rented from the Plaintiff, Arthur E. Weaver. IS. Since the time that Defendant Angela M. Vanlaere abandoned her 1964 Parkway mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such all extent that the central beam is cracked, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 16. Since 1994, Defendant Angela M. Vanlaere has made no attempt to reclaim her mobile home, and has failed to respond to Plaintifi's attempts to contact said defendant for removal of the mobile home from his property. WHEREFORE, based upon Defendant Angela M. Vanlaere's abandonment of the 1964 Parkway mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or pa:iment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendant Angela M.Vanlaere, together with any and all other persons who may have an interest In said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 17. Defendant James E. Lewis is an adult individual whose last known address was located at 650 North College Street, Carlisle, Cumberland County, Pennsylvania 17013. 18. Defendant James E. Lewis has held himself out to be the current registered ownerofa 1965 Crestwood mobile home, having a serial number of9945E. 19. Approximately four (4) years ago, Defendant James E. Lewis vacated the mobile home in which he was living, abandoning said mobile home on the Lot # 13 of Weaver's Mobile Home Park which Defendant James E. Lewis had rented from the Plaintiff, Arthur E. Weaver. 20. Since the time that Defendant James E. Lewis abandoned his 1965 Crestwood mobile home, no lot rent or other storage fee has been paid and the condition of the mobile home has deteriorated. 3. Defendants Duane E. Kress and Michelle R. Kress have: held themselves out to be the current registered owners ofa 1970 Hillcrest mobile home, ha\ing a serial number ofHD112D. 4. Approximately four (4) years ago, Defendants Duane E. Kress and Michelle R. Kress vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 11 of Weaver's Mobile Home Park which Defendants Duane and Michelle Kress had rented from the Plaintiff, Arthur E. Weaver. 5. Since the time that Defendants Duane and Michelle Kress abandoned their 1970 Hillcrest mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the roof and awning have collapsed, mak ing the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 6. Since 1994, Defendants Duane and Michelle Kress have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Duane E Kress and Michelle R.Kress's abandonment of the 1970 Hillcrest mobile home on the PIJintiff's property for a period of approximately four (4) years without authorization from F laintiff or payment for storage or lot rent, the Plaintiff rcspectfully requests that this Honorable Court cxtinguish all right, title and intercst of Defendants Duane E. Kress and Michcllc R. Kress, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 7. Defendants Paul L. Almolt and Cynthia F. Armolt are both adult individuals whose last known address was located at 52 South High Street, Newville, Cumberland County, Pennsylvania 17241. 8. Defendants Paul L. Armolt and Cynthia F. Armolt have held themselves out to be the current registered owners of a 1963 Marlette mobile home, having a serial number of M255FDCA3119. 9. Approximately four (4) years ago, Defendants Paul L. Armolt and Cynthia F. Armolt vacated the mobile home in which they were living, abandoning said mobile home on the Lot # 5 of Weaver's Mobile Home Park which Defendants Paul L. Armolt and Cynthia F. Arrnolt had rented from the Plaintiff, Arthur E. Weaver. 10. Since the time that Defendants Paul L. Armolt and Cynthia F. Armolt abandoned their 1963 Marlette mobile home, no lot rent has been paid and the condition of the mobile home has '. deteriorated and been vandalized to the extent that the windows of the mobile are broken, making the mobile home inappropriate and unsafe for habitation or for continued presence within the limits of the Borough ofCwlisle. 11. Since 1994, Defendants Paul L. Annolt and Cynthia F. Annolt have made no attempt to reclaim their mobile home, and have failed to respond to Plaintiff's attempts to contact said defendants for removal of the mobile home from his property. WHEREFORE, based upon Defendants Paul L. Armolt and Cynthia F. Armolt abandonment of the 1963 Marlette mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendants Paul L. Armolt and Cynthia F. Armolt, together with any and all other persons who may have an interest in said mobile home, and award title and ownership of said mobile home to the Plaintiff, Arthur E. Weaver. 12. Defendant Angela M. Vanlaere is an adult individual whose last known address was located at 245 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 13. '. , . Defendant Angela M. Vanlaere has held herself out to be the current rcgistered owner of a 1964 Parkway mobile home, having a serial number of250FKRA1255. 14. Approximately four (4) years ago, Defendant Angela M. Vanlaere vacated the mobile home in which she was living, abandoning said mobile home on the Lot # 10 of Weaver's Mobile Home Park which Defendant Angela M. Vanlaere had rented from the Plaintiff, Arthur E. Weaver. 15. Since the time that Defendant Angela M. Vanlaere abandoned her 1964 Parkway mobile home, no lot rent has been paid and the condition of the mobile home has deteriorated to such an extent that the central beam is cracked, making the mobile home unsafe for habitation or for continued presence within the limits of the Borough of Carlisle. 16. Since 1994, Defendant Angela M. Vanlaere has made no attempt to reclaim her mobile home, and has failed to respond to Plaintiff's attempts to contact said defendant for removal of the mobile home from his property. WHEREFORE, based upon Defendant Angela M. Vanlaere's abandonment of the 1964 Parkway mobile home on the Plaintiff's property for a period of approximately four (4) years without authorization from Plaintiff or payment for storage or lot rent, the Plaintiff respectfully requests that this Honorable Court extinguish all right, title and interest of Defendant Angela 4. By its terms, the Contract provided for the simultaneous assignment of the Contract to the Bank. 5. Under the terms of the Contract, the Bank maintains a security interest in the subject 1995 Fleetwood Mobile Home, VIN PAFLR22A073360L (the "Mobile Home"). Said security interest is duly noted on the Certificate of Title (hereinafter the "Title") as required by law. A true and correet eopy of said Title is attached hereto at Exhibit "B" and ineorporated herein by reference. 6. The Contract is now in default because Defendant has failed to make timely monthly payments that are due and owing for the months of November, 1997 through March, 1998. 7. Such defaults are eontinuing. 8. The Bank believes and therefore avers that the Defendant has possession of the Mobile Home. 9. The Bank sent Defendant a Notice of Default by letter dated January 2, 1998, in accordance with 69 P.S. ~623(G). A true and correct eopy of the Notice of Default is attached hereto at Exhibit "C" and ineorporated herein by reference. 11. As of this date, Defendant has failed to cure the default or deliver possession of the Mobile Home to the Bank. 12. The Bank is entitled to possession of the Mobile Home. - 2 - exhibit A . Addrw.. MIWII ~ ItD -........ D....... It... '7DM "W." .nd "Ut" m..n the SeI/. .bov., "You" .nd "vour" mean .e.:h Buve, lboy. 'II IUCCI..o... lIId I../gno.' .nd _. 01 lIId IndiYlduelly. Q/ 'ALE: You "- 10 pur",,". fr'm .., lub/IClIO lhe Ilrml end condll/otlI of 11I10 Cant'ICI onct Security AD"'......"I, lhe Vlhlclo In III Ic.J 10m c~on dHCltIlod bolo... \tl '1'.., Mlkl MOdel MlnuflCluto"l S""", Numbo,. UOOIIIO No.IVII' ?> I.,.. :to ~ ~ O~/~/" WED 1.:lS FAl ~~O 2S. ~'71 " llriTAlllIlTAUIIEIIT COlm"'CT SIUI' __ .........1ICI...1II1 AIIO IECtJIlITY AIIllHMEW" No. Dati FIRST nDmw. ~.... tEQALS 1iII022 .....L lIuyr .\u~ ..., ,qqtQ: , MY.... JUMI ... LM.. AddNs. IUWUIIll. itA .nel -r nc:.. l<:des :4 S+C::RS c..~,""k.1 1~'r / SECURITY: You 01.1 III · lOCurtly In"'"I In tho Vlhlclo dllcrlbod .bo... Th. Vlhlcll .hell bo complel. with oil lec.,,/ono. .llIc","."". lce..IIleI, .qulp,.,.n. end PtOCIIda of tho Vlhlcll. Tho dlN..ry end .cc~nc. of tho Vlhlcl. f. .oknow/ldo.d by you. Ou, 'lCuritv lntoNat will"", lIlCllnd 10 OotllWllI' lIoodl lhot 11'1 nollnltallocl In or Iffillld to thl Vlhlcl. 1'1I0", thon 10 d.ve 1"", WI _, Into lhll Contrlcl with I 00. PROMISE TO PAY AND PAYftII!NT TERMS: You !Hornllo to P'V IlIthl princlpel .mount of. 22115.00 . plul fin.n.I Chlttlll .oorulnll at 1110 ,at. of - J . 75 "PI' VII' unlll mllu,hv. You IlIrel to plV Ihl. Contrlcl .ocording 10 lho p,vmlm lohedul. lIId 1111 ohe'le Ptovlllona Ihown In 11I1 TRUTH IN LENDING DISCLOSURES. Ind pev Iny eddltlol\l' Imounll Iccordlng 10 tho Ilrml .IId .one ftJonl of thI1 ContrICI. AlII' mlturlly, 0' .Ito, WI hi.. dlmanded perm.nl of ......d bUI unplld lmounll. w. will, I...told, "I'll Irlt.ren II ..75 pe,..nt per V... DOWN PAYMINTI You 1100 ., roe to PlY on 0, bofotl lodly'l dll' rho down PlYlllont of .nv c..h. reblll Ind nit ttldl~n VII.. dacrlbod on PIOI 2. a MINIMUM FINANCE CHARIJE: W. mly retain. minimum finln.. cherge ot . it you PIV off thil Conltlol bofo.. w. hIv. '_d IIIIt much Intwlll. TRUTH IN LENDINQ DISCLOSURES F1NAI/CECHAROE AMOUNT TOTAL OF PAYMENTS Tho do/.., 1Il10000t the FINANCED TIlIlI'Iloum you will hevo ct'Idit NIII COlt you. Tho ImOUnt of ctldh p.1d when yoU hive I'll" PftlYldod to you 0, .11 .chedulId p'rmanb. on your bohlll. , 11 . 22111.00 P lilt Sohedul.: '1'...... "nIIOh.dull will be . I Number of Plvriiintl Amoun: of Plymlnll . . . SICU : You III giving. Mcur tv Inl.rllt In tho Vlhiclo bolng purchlled. AMIUAL PEIICEITAOE IlATE Tho Olllt 01 VOW Ct'Idit .. I ....1IIy tII.. . Unl.40 q Whon P'YIllIml Are D.... I T ALE PRICE Tho tOtlI COlt of ...ou, purch... on c,ldlc, Including your dOWn P.ymenlo,. 1000.00 . 59131..0 ,...., ::. r.... DlI Lote Chlt9.: You will be ol>lllIId 2" por month on tholmoum of the plymlm In ''''"'' by motlthen 10 d.V.. AI.umpt/onl Som.on. buying y"ur homo Clnnot ""umlthoobll~tionon tho orill"'" IlIrml. Prep.yrnont: ., YOU pey oft lhil COntrlOI.."..., you 0 mlV IllI wm not hI.lto pev. ponllty. FIl""..... 20.00 Contt.ct Pro./.lo".: You CIIl nl ...our Contr.cl documlnll for .nv ldelltlonl/lnform.tlon .bout nonptymont. dot.ult, .nv "qui,ed ,ape menl bot_ thl ,choduiod ""to. .nd pro Iymom refundo Illd PIMftJ... " you do no'l 1'1I_ vour Co,",-, obllptlclno. you m.y 10.. YOUI' hou... tho PfOPIrty ""'I You bouclht W/lh thJa '..... or hounhold gaodo .nd fUrMuno. yOIll' motor vlhloIe.,~ m_y In VOUl' _ wIth ua. CREDIT INSURANCE: Credit iiI, InoUl'lllc:' end Cl'ltllt dlublllly PROPI!RTY INSURANCE: You ... ,...,,.d by III to Inourl tho ineutlna. .,. not I'lllUlred co ollt"n orld/I. Ctldlt "f. Inlur.nel VINoIo.~ thJa CoIlttlCt. You .heII hi.. tho opdon of Ind cl'ldlt dJllbll/ty InoUl'lllc:. will lOt be providocl unlo.. you Ilgn ~ tile IIQ1ftd '_110I 11,,* thrOUOh IlIIItIno 1lOlloI.. .f .nd Ig,.. to PIV tho .ddltlOl1lI 001 t. 1__ Owned or oontroIlod by YOU or ~ end """hlng tho equJYIIInl ,nour..... co....,. ~ '"V Inoiitanoe compeny .uthoifzocl to lrMIIot IluolnMe In "-iIvtvonII. !nItnanoi 00VIflna Ill.. of: , I '- or IlIIIII/ty I'IIIIId to till Vohlcfe. ZI lhe u.. of the Vlhlof., ., 000d0 or ....... relItId to tho Vlhl.... 4) mlChenk:lll ......IuIoW... or . MnIIce 0011I...( or w.r:remv '" optionot.IId nollncludoii ....... ........d '"" 'ndlcatod below. Premium: . _ For Fi,.t 8uve, - Per Secolld IllY. Fo, Both BUYInI CRIDIT UFE, CREDIT DfSABlLITY: Premium: . _ Fo, Fitot Buve, _ For SIcond BlIYer _ Fo, Both BWn LIABILITY INSURANCE; UobIlty ~ _...,. for bocIiIy l/1ury ond .......rty dImogo _ocI to othere 10 no'l InclucIod In tNt ContrlOt unIe.. ohoclced .rid IndlcltId bolow. Promlum: , Inlur.ne. Comp.nv Nlml Ind Ho". 0111.. Add,e..: For Flrsl Buy., _ For SIeond Bwer _ Fo, Both Buy.,1 If you got tho I",u..n.. from or throullh UI. yOU will p'v · 2'1. DO for 12 mmtt:.h. of cov.,.g.. Th. VlhI.1e II1IUtlnc. premium II c.leu'"ed e. followo: o FI....Thert and Combined Add'l. Cov""II' . o . , D.duotfbl. Compreh""l.. Cov. . o . DocIuctlbla Colllo/on Cov...g. . o . o . o A charge for In Extendocl Servlc. Conuoot II ldelld to thll COIllnlCl. Th. Elllended Slrvlc. ContrlICl .00d 0' p'ovId.d by Ut 10: COVOflga: for T.rm: I Wlntlh. Ct1ldlt Inouronel Speclflld Abovo: FE,.., Bu .r SIOond Bu " MODEJlN CREDIT PROTECT/ON POUCY: Promlum , for .INI.1'M~"rutrfI..lftf,,'LCM..... ...oa.JI1.JM1, ftmtNu.rvuz,.,." 11III4 ORIGiNAl. ~ 01 .o....g.. MOTOR IlEHICLli ,.... , 01 ~I B. W.. In goOd f.1lh '''ve thtt !he p,o'pect .1 Plvm.nl Or tht _peel 01 _I. .' performlnee 01 .nv oth.. of v.ur ollIIaatf.... undtr me ContnIct I. ''''''tired. "VOll dtltult. you _. to P,y c.un coau w. Incur to ooll.cl !hI. Comr.ct .. w.1I .. lIttOInlV" fHa II W. ..,., thl. C.nll.cl lor c.lltetl<<lto en -V. " en "'.nl of deltuIt occur. .. t. '!IV ..,. 01 YOU, W. m.v ...relu our ,.",tdlll eallnet .nv or .11 of YOU. REMEIlIESr "VOll ... In del.ufl .n W. Comr.ct, wa hev. .11 01 the rtmtdl.. provided by I.w .nd thI1 Contr.Cl. A. WI m.V 'tqUlre yOU to 'mmedl.t.1y p,y III the _Ining !lnPIld IlIlence 01 the .mourn "nencld. n_ chtrgtl I... II1V "'und ..q\ll"d by Ilw, .nd III .thtt '11/11;1 cherg... B. W. mlV PlY t....1 ......m.m.. 0' other ft... 0, mlk. '.palll to lht VohlCl. " yOU h.v. not doll. ... W. ... not "qullld t. d. ... Any .mOUllI We p,y will be .dd.d 10 lhe .mounl vou .w. Uf. will be Imm.dltl.,v dill, .nd will ..rn · o. .0 Intll..1 I,,,", the dn. pilei n the hlghetl Ilwful COnt'lOl I I ,et. Plrmltt.d by r.w llntil p.ld In full. Dawn ....,....nl . 1000.00 C. W. ml., Immldllt.1y IIka po.....lan ollhe Vlhlcll bv lea., . . prace.. Of .tff-htlp, but In dOing '0 w. mlV not brllch l'he UIlJIIId ........ 01 c.lh Pttc. I I PI'" or unltwfufly .nt.r onto VOUt prernltH. W. m.y then ICtlh ""ce',,, DOwn !'.ym.m, . 21100.00 "" the VthlcIt tnd ,pllly whet w. rec.1v1I II provided by !'lId to I'ubIIc Offld"I' SII.. Till I Tire Till . 0.00 ~~~~ =1G~:'~b1' .IlptMn tnd then town VOll, Plld '0 Pnlptny IlIIutlnca Camp., v / MCPP . ~n. 00 0.00 O. W. mlY be .nUtled 10 . deflcl.ncv JUdgment 1II.lntt you II Pold to Cttdh Uf.IntUtIllCl Camp.ny . 0.00 tht praCltdl of the.tIe do net p.y.1I 01 the .Ilpt.... .nd wht1 you ow. UllllCcept when prohlbll.d by'lwl. Plld to C"dIt DI..b1l1ty INIlrInC. I :omPlnv · o. a a BV choo"ng eny one or mort of lIltla "media., w. do not "'lIng'H / UCC . '0.00 o. oow.lve our right to 1.1t, ut. .nothe, romally. BV d.cldlng not to TOI Not_ '~-I_- . 10.0. '1 oow, env rtmtdv, W. do not glv. up our right to co",ld.r the av.nt I . deflllllllt hiPPtIll .glin. To: . You ... IlIn If IIIV noU.. bo reqund 10 be glVln to YOU of c thtr Chtrvu I I the inl.ncItd Al. or dltPcehlon 01 1M Vehlcl.. thli notlc. wm be Ilnclucllng AmOUlllt PIlei III Dtht" 011 Your """11 . 315 .00 oonaldtncl re......... II lint !IV mtllto YU lut known addr.... I' -, -"u "'-.,- ....--. . ~.oo II mitotIC! In our recorda,.t Iti.lt 10 cliVI bllore the dlte of Ih. -- "---,,.,. .-. --- -.-- Intlndtd d1'llOIldon 10"lIOh .Iher Ptrlad of time II ,. required by Amllln1 F1nenoed r ] lew,. {Unpaid "'.nc. 01 Ct.h Price pllla etlt" Chtl'll'" ,. aJlll.oa RIINSTATEMENT: "the Vthlclt h.e "In "pO.....ed Dr "'kin You earee to the torml on JIIGU I 2, ItId 3 of thla Contr.ct. throUGh '1lI111Ctl.n. w. ml'( "'_e the Conlraet .nd return the ADDmONAL T!RMs 0 II TH! CONTRACT V.hlcl. '0 you. The ConvICt wID " ,wltltd II you PIV .11 PI.t AND SEeUR.... IIO--'-ENT dllllnnt/lmenu, '..rued dt1tUh. pI...ny other .moUllt lawlullv ,. . ......... dut under the Contrl.,. In .ddltlon. YOU iIlI- 10 PI'( f.r the _ GENERAL TEJlMS: AI Uled In th a docum.nt. Conu.ct lnollld.. of .uft If We mtke the V.hlcl. throllOh 1"",lletl.n. " dtl.ull h.. the ttnn. .f lilt Convect IncI hcurfW "'lFIIm.m. You hev. exlttld for mort thin 16 d.y. It the IIrilt 01 repo....llon. tltl been alv.n III oPPDrtuMy to purch... the V.hiel. 'nd/or ..IVlcel Illp.llI.. fa, FIlIIklng, rtPlirfnvl .nd ICDrIng the V.hicl. u de..,rbtd on PIIIt 1 lorth. cuh pica Of the totll Ill. prle.. The ,ulheri"d by lew mUlt lito be plJd by you, I.tll III. PlIo. I. the tottl price 0' the V.hlcl. .nd/or "IVlc.. II rOU buy It OYIr tlm.. The tot.,..II price .h.wn In the TRUTH IN NOTICE OF PROPOSED INSURANCE: You t.k. notic. Ihlt ENDING DISCLOSUIlES bo bI..c .n Ih. "'umptlon thlt all group credit II1e In.ur.ne. cov""" end/er g,OUjl credit .edd'n! p'vmen'" will" mtdt la Ichelluled. YOII eg". to buy thll .nd httl1h IruWIIlCl cov."g. will be .pplloabl. I. this Conll.ct If property end/Ol a..vic.. lrom .. at tht .Clllal tot., nl. prlca 10 marked on P''''' 1. Group cnodl1l11e Inaurence oover."" Ind/or ICconling t.the lIrm. of thl. Coni' .ct. group crldl1 ...ld.nt III1d he.1lh lneur.nc. cova.."" will be Y.u 1;TIt W. ContraCI will IH, gov.rned by the I.w 01 the written by ",. lruurll1C1 eempeny lIIm.d. TN. lnturence, .ubJect Stet. 01 Panntvlv.nl.. You .g,. dllt Wa hav. not mid. II1V orel to .ectptlnca by ,he Insurer. COy.,. only the pereon 1111I11119 the wlmontln or prarrn." regarding the prOperty. Thl. Com,.ct roqueet for .uch InaUI'tIICII (Of a.ch pert.., "gnln; the requett to, tak.. eH.et when .lan.d by you ".ny p.n of thl. Contrect jOint Cltdil UII IlIIlIrtnee'. Tho amount .f chlIrgoi bo lnelicltad fa, ..nnot be .n'o,oed, IliII f.ct will nlot IfI.ct the rem.lning term.. ttch type 01 Cltdlt Intuit... I. " purchU.d. The 1Irm 0' Inlur.nc. win camm.nce II 01 the d.u the Ind.b1ldnall I. WARRANTY: Vehlcla w.rr.ntv 11I.rmnlon I. .upplltd to y.u InClUTtd and wm a"plr. on tht origlntllv alchtdul.d m.turftv d.ta IIP.lttltv. of th. Incftbtldnn.. Subject to .ccept.... by the I........' .nd within 30 dava, there Will be dtllvtrtd to UI . c.nillclC. 01 PREPAYMENT: Y.u m.v prep.v I1It Contract In part or In lull .t I",ullllOl mort Iully dllcriblng the 111I""01. In the aVlnt 01 anv IlnI.. Anv p.tti.1 p.ym..,t will lOt ..cw. .nv Iller Ichedul.d pllPlvrnent 01 the lndtbtodntl.. . r.fund of '''Ul'Inco chlrva plvm.ntt unlll y.u p.v In lull. will" mtde when due. OWNEII8HIP AND DUTIES TOWARD PROPERTY: By giving INSURANCE: Y.u Ill'" to buy '''UI'Inoe on the Vahlcle .golon LIS a Itcurity Imlrut In ml V.hlcll, you rept...nt .nd .g,... to tha ~.Ict .nd lor the ....Ounlt w. require. YOII will n.me UI II the following. I... Ply", on .nV auch policy. W. m.y requlra tddtd aeCUrity en A. Y.u will daflnd thl. proper\" IIgtlnlt ..V cl.im mtda by lhlw CoMract " you Igrw Utlt I..urlnea proottde may be unci to .nYOM II... You will do wh.:a"" I. ""N'ry to keep our 'lPIlr or IIpllol thi Vehicle. You '"tH thtit II the lnIuranc. olllm 10 the Vehlclt .httd of' he alllm 01 .!\YOI1t "11. praoHdl do nat cov.r tlta Imounla you atIl1 OWl us, you will p.y B. Thl ..curlty IntlfNt yoU IrIJllvlng III In thlt Vthld. comaa the d1fftnHIo.. You will buy the IlIIurance from . IlmI .utho,1zed .httd of ttie clllm 01 .ny 0 It' 01 you, g'lltll' 01 "OUl'1td to do bUt.... In P.nnaylv.n1.. You will kltP thl I..urene. until crtdltOtl. y.u htvo .Igned ., Immedl.t.lv will ./an.ny thI. Contnct It paid In full. tddltfon.1 d.cum.nt. or ",cvld. III Wl1h eny .ddJtlonel II VOU 1111 to obaIln or mt/nt.ln thI. Intureno., w. m!IV obltln Inlorm.lf.n WI ml'( requlnj tl k........ el"m ,. the v.h1el. Intlllt_ to pro_ our Inttreat In the VllIIol.. " YOU 111110 noml .h..d 01 tilt el"m of .nv.... .It.. You will n., do .nytt,lng us u I... ~yee, WI m.v Obtlln ''''...n.. I<> proled _ Inlt'Ht to ching. .ur llltl.....lln the V.hlcl.. In the Vehicle. W. will nqllly you " Wa d. .e. The con 01 .uch C, You will k.ep Iha V.hlcle In your p......lon In goOd Insurano. will be Iddod to the .mount V.u ow. ... The COIl will condl1lon Ind replIl. Yeu will ut. \h. V.hlcI. .nly lor the be Immedlntly due. The cost will .ceru. Int"..t at the hlgh..t I.wIulPUIllOH. lor which It .... Inltndtd. UnI.I. othorwi.e '.wlul contrect II... until pelel In IuI/. 'sreed In writing, the Vehicle ..III be loclltad It your addtua Iltltd on peg. t. WAIVER: You lIIv. up ..- rlghll (Ia the ..1Im PtrmIttId by D. You will not .lbImpt to 10,11 the V.h1el. (unI... It bo Itwl to"",*, US to do OIf1t/n Wngo. You wllI not requlr. Ullll: Inv.rnory end Id.ndr"d .. .uch) 0, othtrwlt. tral1lftr Ill\' 111 demend III)'mlnt of ""oun" due; ta, IIIvt notlct thet rights in \hI. PI'OPlrtv t. Infone ebo.. without nUr prior .mounts due htive not be.n ptkf: 131 Dive noiIo. thel we tit wrlntn C....nl. m.1dng \he CoMrtot Imm.d1.ttIy eIlI.. E. YOII will PIV .11 tlllU end 1.l....IlWolU on the V.hlcle II thev beeom. du.. OBUGAnDNS INDEPENDENTI Elch Plreen who II_ this F. You will n.tffy us 01 .nv lOll IIr dlmag.l. the V.hloJ.. You Contract ...... t. PlY !hi. Coou.., ,ccording co Ita t."",. Thi. will provide ut rellentbl. II ena 10 the Vthlcl. f.r the mtl.. the 10llowfng. PUIll'" el INp.ctlon. Our · tI1y Ind In.pectlon must bt III, You mu" P'V w. Contr.ct 'v.n II lomeon. 11I11 hll "gn.d .coompll.htd In . Itwlul m.",..,.nd wllhout "lIchlng the It. pe'ot. B. Wo ",.v ,eI.... .nv c..al.ner Of gu.rtmor .nd V.U will nUl e. You will .nd.... 111. cenll/ooll .1 title 10 thl. V.NcI.. " be """lIIted Ie P'V the Conlr..I. .nv, to Ih.w tha ..curltv Int....t wo h.v. In thI. V.htcle. C. W. m.v ,el.... anv ".Ut/ty IIIld you will .tllI be obllaalaa to PlY tho Comr..,. DEFAULT: y.u wUl be In aal.ult cn lhi. C.ntr.ct " .ny one or 0.11 w. glv. up .nv 0' eur ~.hlt. II will not "",ct vour dutv t. mare ., lhe foll.wlng OCCUII (..cepl I' prohlblltd by Ilw,. PlY mJa Conlr.ct. A. Yeu 1.11 I. perform .nv IIb1lsttlan which VOU hlv, E. If w. .lCttnd new credit or renew thI. Centr.d, II will not l.I1d.rttkan In thl. C.ntrect. .IIeet your dlaHPlv thlt C.ntract. ..,. 2/11:1/ .'Ma, tl.. '-"n .'11...., Ni.. 'f. ClIwf: IAN 11400-...,.21'11 ......1tI1lMVlAZ.,." en,.. ORIOINAl 03/11/.. WED 18:1. FAl 330 Z8. 3S11 . ." n:!MIZAT/ON OF AJ.'OUNT Fl. CED Vehicle . JOKDD. DD (including le_orltt, d......,. IIrvtot., .nd .... IIll of . O. eq I Extended ServIce ContrIet FIRST I'1lDERAL ...... LEGALS IiIOZ3 N Cllh Down Ptvrntnt ~lnullCturII,.. "'bat. ~ Dtlerlpllan 01 Tr..ln Il> ~ TfICIt.In .:l L.... Amounl Owing ") (".Id by Siller) N.t Tr.dt-ln Cuh Prfat , --UJ'O,OO ._G.OD I I. 30100.00 O.GO ._1.00 '_D.OD , 03/~1/" WED 1':17 FAX 330 2.4 3.71 FTC NI)TICES ANY HOLDER OF TH~S CONSUMER CREDIT CONTRACT IS SUBJEC1' TO ALL CLAIMS AND DEFENSES WHICH THE I)ESTOR COULD ASSERT AGAINST THE SELLER C'F GOODS OR SERVICES OBTAINED PURSUANT "ERETO OR WITH THE PROCEEDS HEREOF. RI!(:OVERY HEREUNDER BV THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DIBTOR HEREUNDER. F YOU ARE BUYiNG ., useD VEHICLE. THE INFORMATION YOU SEE ON THE WINDOW FORM ~ FOR THIS VEHICLE IS PART OF THIS CONTRACT. ~ ~:3::CE"~O:NY g~NTII~~:Y p~~'~?O~S I:~':.~ I JI CONTRACT 01' SALE. +++ LEGALS THIRL .RTY AlJREEMENT By .I,nlng below you .gr," to gi... UI . lecu.1ty Inte,ollln thl Vthlcle IItlcrlbtd on Pille 1. You Ir,O .g,," 10 bt bound by the terml ollhll Conl,.ct. Inclulllng Ih. WAIVER IIcllon on P.... 2. EXCEPT thet you W'" not bt lI.bl. for tilt plymtnlllt rlqult... .VOU late. that we mlV flntW. I_tlnd, nr ching. thl, ContrAct. You .'Ia .".... thlt WI mlY ,.1.... Iny plnV or Vthlclt wIthout ..rttllno you from thll Comr.cl. WI mlY t.ke the.. otlp' without notlcl or IItmlnd upon you. Yav IcknDWIIll.. rtCIlPt of I complt<<ed CO" af thll Contrlet Ind Security A..-nL X o.to N.ml NOTICE TO BUYER: Del NOT SIGN THIS CONTRACT IN BLANK. YOU ARE ENnTL!D TO AN EXACT COpy OF THE I:ONTRACT YOU SIGN. KEEP IT TO PROTECT YOUR LEGAL RIGHTS. Buy.,: Buy.r: a. I.Lov Signa .: Dill 5lgnltunr: 0.10 SignltlJrli Dlta Slgn.luro: O.tl BUYER ACKNOWLEDGi:S RECEIPT OF A COpy OF THIS RETAIL INSTALLMENT CONTRACT Buyo" L ~ 0.. (c1'1"d Q..u Slgrnnurif Date SlgnltUl'll: Data ASSIGNMENT: this Contracl ,nil Soc..;ty Agroomont Is IlIlgnod to PlAIT FED!lUL SA VlI!U " . LOA" AISOC ('lime .nd "dd","), the Alllgnlt. Sy, un"", tho torml of tho ASSI'3NMllNT BY SELLER belaw. Buyor: Slglllturl: Olto Siglllture: Ollte ASSIGNMENT BY SELLER \ nO Stll..lollo .nd IlIlgna thll Rltallnsltllmo"1 Comrlct Inll Security Ag.temonl onJ \III€!- 1 ,19 ~ to flltIT IIIDUlAL SAVINO. & LQAN Aaoc. 1J11! uaRTY aT. WQOSTIA. OM ual the AI,lgnee, Its BUCCUIDrI .nd ...ignl, 111 It 1 rlghll, titlo .nll Inlortot In tNl Conuoct Inll Slcurlty Agreement. one! .ny guartntoe IXICUlld In connlclion with thlo Convlot and 6tcurIty Agrtem, nl. THIS ASSIGNMENT IS MADE: (J UNDER THE TEllMS OF A SEPARATE AGREEMENT. (ill PURSUANT TO THE FOLLOWING TERMS, Sailor givos AIIIgn.. full powor, lither In lis own ""mo or in Sailor's nom.. to teko IlIlogol or ochor Ictlol1l which Stller could hlvo' tlken under thia Contrlct. Sell., WI "ants: A. This Cantr.at reproaentl 8 III. by Sener to Buye, on _ time price ba.ls and not on . ceth b.. I.; B. The om""'"nt. conl.inad In :hi. Contrtct art true one! corrocl: C, The IIown POYmtM .... m.,lo by the Buy.r In Iht manno' .lltod on plgl 1 and no port of Ihe down p.ymom Wit loollld or paid to thl Buye. bV StIle. a, Stller'o ..p..l.nt.llvo., o. Thll ..I. WOI complotod In. :car1lnco wllh III Ipplicable lodorlltnd ototll.WI lne! ..gulllloOl: E. Thll ConUlct io velld ."" onh.a.abl. In tccordence with III torms; F. Tho nlm.. end .Ignlwr.. on thil Contr.ct... not forgoll. fiallllous or ,,"umod. end 1'0 rru. one! correct: G. Thi. Contllcrt I. not oubloct t , .ny cllim. o. dtftlllO. on tho port of the Buye,: H. A compl.tory fillecHn copy of thll Contr.ct WII delivered to tht Buyer It tho tlm. of oxocution: .nd I. The VlhloIo he. blln IIollvored to tho Buyo, In good condition lne! hll bean ICCIIPt.d ~y Buyer. If Iny 01 tlltll wenonUes 10 b...chod or uMruo. Soller will, upon AIIlg..o'. d.mand, purch..e thil Contrect from AlIlgn.e. The purch... ohell be In aosh In the on'aunl of the unpllll blloncl (inclUding Intlrul) plut tho coot tn<l expenoo. of AlIlglll., Inclulling attorney.' fell. S.Uo, wllllnlllmnlfy As.llln.1 fer any 1011 lultlllnod bV It blclu.e of judlcl.1 011'011 or '" tho ...ult of I ,ocovory mado Ig.lnst AIIlg.... "' I reault of I claim 0' ""onll Buy., has Illllnst Salllr. Sella, wlivo. nOlico of tho occ"Ptonco 01 thll ''''gnmlnt. notlca of nan-paymlnt or noll1lOrfo'mlnce and notlct of Iny athor romolllo. Ivoilohlt to AIIlg""". A..lgnee may. without notice to Sellar, and without affecting theUabllhy of Sellor undar this uaJgnment, compound or releale any .Ightl ogllnlt, .nd gront eXlenllons .1 tlmo for Ptymo"t to be mado. 10 Buyo, ane!lnv othe, po,.on obllglttd undor thlo Contrlct. UNLESS INDICATED BY CHECKING THE BOX BELOW. THIS ASSIGNMENT IS WITHOUT RECOURSE. o WITH RECOURSE: SeUor .gr.... thlt if tho Buve. dlllull. on Iny obligation of p.ymtnt or performance undo. thi. Controct one! S,curlty Agr.tmonr. StU.. will. uo"" """"ne!. ,"ourchl" Ihl. COtltract ond Socurity Allrtlmont for the Imount of the unotid bllllnc.. Inclulling IIn.nc. argo due It thet tlml. ~ SoUor: aD By: TIUI: _ 'C~ 111111, "'4 ..1\Uta Iy.."",, 1M.. It. Ctow. MN n.loo.Jl7.n4,. JtmI ItUNVI.AI:"" '''114 ORIGINAL /Hff .t 01 JJ 611""'.II.....'.".u.".f.n.'"'C'",II.0 exhibit c FRI 11:31 FAX 330 284 3811 FIRST FEDERAL ~~~ MCI COLLECTIONS III 004 r:oc j~ -- "^ t\ ~ I'-~~?() .,.... KOTICE OF INTENT TO REPOSSES AND/OR TARE LIDAL ACTION ('ROTICE') 6"5 r )~'" .::.nu....y 2, lUB .....::uneA:'llr.er . Lot l11S B 9 Sprin!l Terraae Newville, PA 17~, 1 Dear MI. HYIJerr Tlte Hobih :Io",e InotaUm.nt Sal. Contract ('contract') eXClcuted by you on Jun"" , .....: in tl.vor of wi 9"." ~.deral Rav( "'g_ LLDAn nr ..n^....... (nka Signal Dank, N.A..) for the: purf'h... of the lqql; .'.IIIt'wood. Mobile Home, aerial nO.PAPLR22A07 located at Lot 101 B19 Spring Torrace, i. in aeriou. default becau.e monthly paymencs of $~~ have Dot been made for the month. of Hn~mh.~ n.cefth_~ a...A Ja~. Late clarga. Itav. aloo accru.d to thi.,dat. in tit. amount of $12-2B. The amount now re(uired to cure this defaUlt, or in other worda, get caught-up in tlte paym.nt. a. oj tlte date of tlti. lotter, i. $0.. 1.. You may cur, tltio default within thirty (30) doy~ of tlte date of tlti. notice by p.yl~g ~i~rl~Pftl A.v~"gs_'-Ln~n n(. W"nWpe~ln~A ~~gn.' D.n~ N. , the abov~ amoune ot a&~2,,~. plUG any additional monthly payment and lat. charga. will fall due during tlti. periOd. Such payment a mu.t b. mad. eitlter by ca.h. caaltlere ch.ck. money order or aaltified check, and made at the Ollie. ofSignft1 RAn~ W A ,__,~~ ~ Lib~~~y ~~ ~oo~t~~ nhin ..~Q', It you cure the default within the thirty (30) day period, you will not be r.quired to pay attornay'o fee.. It the defa,lt is not cured within thirty ~dayS, .i~D~ V.de~al ~nving~ ~ r.n.n n~ Wno~t.~~. ~ign.' uan~~ intende to ex.rei.. its right to accelerat. the Contreet payments. Th1. m.ane that what8ver 11 OWing on the origlnal loan amount borrowed wl11 ba conaid.red due imm.diaeely and you may 10.. tlte cltance to pay-oft the original Contract in monthly InGtallmence. rt~.~ ~-~.r.' ~AV~"Q. ~ Y.n..n ...t1 'lQna~o,. n~gu.' Ran'" N A may repoI"." the Mobile Hcme or insu:.itute legal .ctlon to r.gain po.....ion of tlte Hobile Home. If the Hobile Hom. i. .epolse'D8d, ~-Eed~"~' ~Avi"g. ~ ~Q.n n~ Unn.~."I-D~A ~ian.' ~a~~ N a will ..11 the Hobil. Ho.. at pUblic or prlvate aale on o~ after NO SOONBR THAN 45 DAYS FROM DATE OF LETTBR to payoff tlte Contract Obligation. It the Mobil. Home i. eold at public aale. a ,otica of the date of the .al. will b. .ent to you before tlte aale, You ahould <eali:e tltat 0 public or privot. ..le of the Hobile Home will end your own.r.ltip intar..t in tlte Hobile Home. ~Dr: J:'conDt-nL.s.a3ting.s " T,~l'ln ,.,F w"'aat.al" nl.oa ~~g".' Dan}f. tJ " may alSlo .U. you p.roonally for tlte unpaid principal balanc. and all other .um. duo und.r tlte Contract following the sa10 of the MQ~11e Homl. If you do no: cure tit. defeult witltln thirty 1301 day. of tit. data of this notice, yoU may stll1 avoidd acceleration of the indebtedness under under_the Contract an~ p~'V"t sale of the Hobile Homo at any eime betar. legal~it~ to tlte Mobile Nome ~. oct.ally tran.ferrod by tendering $662.19. plug tit. fol~owtn9 additional chargeR, 1. All montl1y payment. of $216.11 due a~ter January 2, 199B up to the dote ot cur!, and. . 2. All lace char;.. accuring after January 2, 1997 up to the data of cure, ond 3. Attorney 8 fees of up ~o $50.00 or, it legal action hae been commQnced, all relsonable attorneY'G tees actually incurr.d by Firat F.d.~.l Savin9G & LOin of WOoBter, nk~ Signal Bank, M.A.; and 4. All COBtl actuDlly incurred by Firat Pederal 9av!ng8 & LOAn o~ WocBcer, nka Slrnal Bank, N.A. in commening legal .~tion: and G:t lm""lli Sl.....B...N.A. 'Jl P..,l Uberly 5L. P.O, Do:c Ja, WIIO.tcl!OH 4#91-.Ja$ "n-zltc-8001 www.lipalbanlc.com ..~~IIII: ~ ,I , LL, co -< ...:>- en -..... - ffi!!; - = tll ...... :rE. 0... ..J-< 11)(.;. IJ"I CJ:'> \.1.1., r-l "'::-1 -- .'. _.~ ;- j:. :.~~ -::r lL. _J c.::cn orr. ~L.'tZ "J~u ro") c.:>::r: ~:.. r--J W u,:.> r:r: a.. ....U ~ 0 ~r \;'. ,- """ .....'