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IN TilE CO! JRT <)!! COMMON PLI':M;
CIIMIlERI.AND COIINTY, PI~NNSYI,V ANI A
ELI M, DOIlRINOFF, .IR.. NO, 9 J- ,} Yl> 'I (.!.t~;~ TJ.....
!,Iuintiff
4 v,
5 LISA IIARDEN SMITI (
Defcndant
Notice to Defcnd
Mortguge Foreclosure
COMI'LAINT
AND NOW, comes the Plaintiff: Eli M, DobrinofI Jr., by and through his attorney. KUI't A,
Blake, Esquire, and in support of this (:omplnint uvers thc fhllowing:
I, Plaintiff: Eli M, Dobrinoff: .II'.. is an individual with an addrcss of 169 Stoney Run
Road, Dillsblll'g, Pennsylvania 17019,
2, On inlhrmation and belief: Detendant, Lisn Hardcn Smith, is a Pcnnsylvania rcsident
with a previous addrcss of 167 Bectclll IIollow Road, Ncwville, Pcnnsylvania.and
is now believed to bc living on Warrington Roud, Carroll Township,
3. On or about Septcmbcr I, 1996, Plaintiff, Eli M, DobrinoJ'I: .II', cntercd into a Rcul
Estate Installmcnt Sales Agrecment with Defendant, Lisa Hardcn Smith in
consideration of and as sccurity on the propcrty known as ]67 Beetem Hollow Road,
Attachcd hereto and incorporated hcrein is a truc and cone\1t copy marked as Exhibit
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Defendant exccuted the agreement lor atolal purchase price 01'$128,000,00 dollars
with thc Buyer (Delcndant) paying monthfy installments of $1200,00 per month
beginning October 1996 and thereafter on the 1;1 dllY of each month for a period not
to exceed 24 month,
5,
Defendant is in delaull of the terms of the agreement in that she failed to make
payments pursuant to the agreement, specifically paragraphs 2(d) payment of taxes,
paragraph 3( d) payment of insurance (cancellation notice was received) and monthly
installments (If principalllnd interest for September, October, November, December
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)997 und JUllunry, Fd1l'uary. M,a'ch nlld April 1998,
Defendant wns giwnlhnllalllotlce (lfthe ddilult. 011 or uhout (letohel' '27.1997. hy
cel'titicd ulld rcgulnr mail. AlIached hereto is a true allll wnwl copy mnl'ked us
Exhihit "B",
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On or ahoul Janulll'Y 21. I (Nil, Dct~'ndallt was sent hy eertitied and regular mail a
Notice of the I!olllcowllers' ":mcrgcncy Mnrtgagc Assistance Act of 1(8), A true
and correct copy of whkh is attachcd hereto and marked as Exhibit "C",
As the certiticd k'lIer of the nolice was l'elul'l1ed, Allol'Ill'Y Kurl A, Blake. Counsel
to Plaintiff. hand delivcrcd and served a copy oflhe nolice oflllortgage ((lreelosure
personally 10 Terry and Lisa Hardcn Smith Oil March 17. 1998 nt 7:05 p,m,
Pursuant 10 the ngreernent Eli M, Dohrinofl~ .II'.. is allowed to invoke any remcdies
permillcd undcr paragraph 8(h) to include ejcetion of premises, seck judgment
against Buyer (Defendant) to include laIc fees and reasonahle nllorncys' fees,
The following amounts arc due and payable under the terms of the agreement:
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Monthly installment paymenls past due:
Septembcr 1997
Oeloher 1997
November 1997
Dccemher 1997
January 1998
Fehruary 1998
March 1998
April 1998
$1,000
$1,200
$1,200
$1,200
$1,200
$1,200
$1,200
$1,200
$9,400
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Lute fees on all thc above listcd months $100/month total: $800.00
Taxes due: $1,489,24
Sublolal - $11,689,24
OUlstanding principal. $11 ),559.51
Collection fcc of 5% on unpaid balunee . $584.46
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Altol'l1cys' Icc 10'\'1, ofhuluncc duc undcr thc Agrccmcnt.. $1,16K.92
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10, Thc totUIUI11111ll1t of thc dclinqucncy, including tuxcs, principnlund intcrcst IiII'
January, Fclmwry, Murch. Arrill99K, Novcmbcr, Dcccmbcr and purlial Octobcr
1997und rcasonublc ultol'l1cys; fees is: $127,OOI.K6
wnER~:FORF,. I'laintin: Eli M, Dobrinoff, .Ir" dcmunds judgmcnt in
mortgagc IbrcclosUl'c in its Ihvor and ugninst Defendant, in thc amount 01'$127,001.86
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y submilted,
Attorney lor Plaintiff
Eli M, Dobrinoff
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IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ELI M, DOBRINOFF, JR"
3 PllIintiff
NO, 98.SLJ-
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Notice to Defend
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5 LISA HARDEN SMITH
Defendant
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VERIFICATION
l,the undersigned, do hereby verify that the statements contained in this Complaint are true
and correct to the best of my knowledge, information and belief, I understand that false statements
herein aro made subject to the penalties of 18 Pa,C,S, Scetion4904, relating to unsworn falsification
to authorities,
13 Date: (l-J(.V
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b. The balance of the purchase price, One hundred eightccn thousand ($118,000)
"D011ars, shall be paid by the Buyer to the Seller in equal monthly lnstallmenlS (If Twelve
( bundred per month ($1.200) per month, beginning 0IH!Ie OC:r. and on the I day of eacb
monththereafter for a period not to exceed 24 months, applying each month's paYl\1ent first to
interest at the rate of 10 percent per annwn on the unpaid principal balance and then to the
reduction of the principal amount due.
c. Not lateI than 24 months from the dale of the first payment as called for
berein, the Buyer agrees that the emil'e balance then due and owing shall become due and
payable. It is expressly agreed and stipulated that the Inability of the Buyer to obtain
. "conventional financing shall not excuse their inability to pay the principal balance within tile time
period specified berein and such failure shall constitute a default bereunder.
Buyer is required to pay balance due within 30 days after the 24th payment,
which is on or before 1- SEpT-,1998. Buyer must obtain fmancing from a source other than
seller for the balance and close on or before /- OC T". .1998. In the event [bat buyer cannot
obtain financing, then an extension until/-;t!ov'/q~iIl be provided, and closing must occur on
or before /- /~C ,/9'Ie . In the event that buyer cannot obtain fmancing, then the $1.200.00
monthly payments will be cOllsidered rent for the premises and there will be no reimbursemenlS
. for payments, improvements, or additions to the pIOperty.
d, If Buyer should fail to pay any real estate !axes or assessments within either
the discount period or flat or face rate period, thereafter the Seller sball then have the rigbt to
demand, either orally 01' in writing, that Buyer must pay, with eacb monthly payment, an amount
equal to one-twelfth (1/12) of the annual combined real estate !axes, and other lienable municipal
charges which amount shall be placed by the Seller in an interest bearing account in a banking
or savings institution (the interest earned thereon to inure to the benefit of the Buyers). As any
real estate tax bills become due and [layable, the Seller may satisfy same from said account,
rendering an annual accounting [0 the Buyer.
e, Buyer agrees to reimburse Seller for the amount of any personal property tax
paid by Seller as a result of the execution and delivery of this Agreement.
3. EXECUTION OF THIS AGREEMENT.
As of tIle date of the execution of this Agreement:
a, Possession sball be delivered by the Seller to the Buyer at the lime of the
execution of this Agreemefll.
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d. At settlement, Buyer shall pay for title insurance, If necessary, and for the
costs of recording all deeds or other documents granling title. Seller sllall be responsible, with
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respect to real estate transfer taxes, for either one-half of all real :~state transfer taxes imposed
by any govemmenlal authority or one percent (1 %) of the purch8llCl price whichever Is less.
The balance of such taxes in excess of Sellers' share shall be borne by Buyer, In the event of
sale by Buyer to a lhlId party purchaser, Sellers' obligation to pay transfer taxes shall be limited
to that amount respective to the purchase price herein, Seller shall pay for the costs of the
pIeparation of the deed and any other docwnenls gl"dIIting title to Buyer as herein stated,
Nothing herein contained shall require Seller to Join in any conveyance to a third party.
e, Buyer agIee to pay, in addition to the foregoing. all real estale taxes and any
and all personal propeny taxes and assessment~ by their due date that may be levied upon the
Seller by vinue of lhls agreement of sale, The same to be paid either directly to the appropriate
lax collector by the Buyer when presented with the appropriate bills representing said taxes or
to be paid by Seller who shall be reimbursed by Buyer upon demand,
5. PREPAYMENT,
It is agreed by and between the panies that should the Buyer al any lime settle and
pay the full purchase price of the premises plus any accrued interest to dale, and other charges
called for herein in full satisfaction of any obligation to the Seller, no prepayment penalty 01
excess interest charges of any kind whatsoever shall be levied or assessed,
6, SELLERS' COVENANTS,
The S"lIer covenants with the Buyer that the Sellers' title shall remain as good and
marketable dUling the entire lenn of this Agreement, as it is upon the execution of this
Agreement. The parties agree that lhls propeny is sold in an as is condition.
7. ASSIGNMENT.
Although this Agreement is subject to unlimited assignment by Seller, it is not to
be assigned by Buyer without the prior written consent of Seller. Further, absent any agreement
to the contrary, it is agreed by and between the parties that regardless of whether any such
assignment is consented to, the Buyer will still remain liable to the Seller for all payments and
all perfonnances called for within this agreement. Buyer shall not rent or sublet the premises
without the prior written consent of Seller. Breach of these tenns constitutes a default under the
terms hereof by Buyer.
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8, DEFAULT.
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a, Default shall be defmed, where applicable, either as the fallure of the Buyers
to make any payment called for herein within six (6) days after its due date, or for any pany to
thls Agreement to perf'onn any act as called for hereul within six (6) days after a fonnal written
demand is made for said perfonnance,
b. lt is mutually agreed that should either party hereto fail or neglect to perfonn
according to the tenns of this Agreement, the other pany may, at Ws/her option, elect either to
pursue his/her remedy for specific perfonnance of this contract, or to accept a sum equal to the
down payment provided for hereL'1 as liquidated damages, and the other parties hereby agreed
to pay said sum, Fonnal tender of a deed and all monies called for herein is waived and shall
not be required. If the Buyer default and the Seller elects to retain an amoWlt equal 10 the down
payment paid herein as liquidated damages, it is then agreed between the panies that all monthly
payments made shall funher be forfeited and retained as an equivalent rental value of the
premises, and Buyer funher acknowledges that they will lose all rights In the propeny which Is
the subject of this Agreement, as well as all right to any Improvements made thereon.
c, It is funher understood and agreed that any sum of principal and interest, or
taxes or assessments herein agreed to be paid, or premiums on insurance herein agreed 10 be
paid. which are not paid for lhe space of six (6) days after the same shall become due and
payable by the tenns hereof. then in such case the whole of said principal sum shall, at the
option of the Seller, fonhwith become dne and payable, anything herein before contained to the
contrary notwithstanding. Funher, the failure to comply with any provision of this Agreement
shall be deemed a default. A five percent (5%) attorneys' commission or collection fee shall
be assessed, and rhe Buyer, in case of default, funher authorize and empower any attorney of
any COUrt. either in addition 10 or without such judgment for the amount due according to the
tenus of this Agreement, to appear and confess judgment against the Buyer In an amJcable action
of ejectment for said premises, and auth0l1ze the Inunediate issuance (without leave of coun)
of a writ of possession, together with a clause for the amount of said Judgment plus costs,
together with a minimum attorneys' commission of either five hWldred and 00/100 ($500,00)
dollars, or ten (10%) percent of the balance dur. Wider this AgIeement. In each case, Buyer
waive the benefit of any law exempting fmm levy and sale, waiving tile right of inquisition if
levy is made on land and consenting to condemnation thereof with liberty to sell same, without
stay of execution, and with release of all errors. A late fee of $100,00 will be charged In the
event of late payment. Each individual late payment will incur a charge of $100.00. Checks
returned to Seller for in~ufficient funds will be charged a fee of $35,00 for each individual
occurrence,
" d. If Buyer does not pay taxes, assessments or Insurance, Seller may, in addition
to any other remedy herein contained, and not In limitation of remedies, then pay the same.
Such amount shall be paid by Buyers to Seller in addition 10 any other amounts due hereWlder
with Interest at TEN percent (10 %) per year.
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9. MAINTENANCE AND REPAIRS.
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From and after the 'date-of execution of this Agreement, the Buyer sha1J assume and
be responsible for the mainten8hce of the premises, inclUding, but not Ilmlted 10, maintenance
and repairs to the roof, heating and plumbing systems, exterior walls and shall keep the same
in good order and repair, such order and repair always to be at least cqualto the condidon of
the premises when delivered by the Seller to the Buyer. Funher, Buyer shall indemnify and
save Seller hannless of and f!'Om any and all claims for work and labor done or materials
furplshed in Connection with the maintenance and repair of said premises. No major
Improvements or alterations shall be made to the premJses without the wrinen consent of the
Seller.
10. PUBLIC IMPROVEMENTS,
Buyer shall bear the costs of all improvements made pursuant to the authority of
any govenunent or governmental agency for work done or ordered to be done in and about the
premises by any such governnient agency from and after the date of this Agreement, and shall
not allow the property to be or become subject to any lien or encumbrance resulting from the
aforesaid,
II. NON-WAIVER.
The fallure of either pany to insist upon strict perfonnance by the other pany in
one or more instances shall not be construed as a waiveI', release, or relinquishment of any term,
covenant or condition of this Agreement, but on the contrary, each term, covenant or condidon
of this Agreement shall continue in full force and effect,
12. RIGHT-Of-WAY.
Seller granted a right-of-way to Lot #2 of minor subdivision in Penn Township,
Cumberland COWlly, PennsylvanJa for ingress, egress, and transgress on the Easlern boundary
of Lot #1, 167 Beetem Hollow Road. Newville, PA 17241. The right-of-way is fifty-feel (50)
wide and one thousand seventy-two and one one hundredths (1,072.01) fcctlong and runs along
the Eastern boundary of the above described Lot #1. (See Exhibit "B")
13, ENTIRE AGREEMENT.
This Agreement contains the whole agreementb-:tween the parties, No other tenns,
obligadons, warranties, covenants, representations, statements or conditions, oral or otherwise,
of any kind whatsoever are implied. ~s Agreement may not be altered, amended, or modified
other than in writing execuled by the partlt:s hereto. The terms, covenants and conditions of this
Agreement shall extend to and be legally binding upon the parties hereto, their respective heirs,
personal representatives, execulors, administrators, successors, and assigns,
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EXHIBIT "A,"
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IT BEING a portion of the parcel of land located in Penn Township, Cumberland
County, Pennsylvania. Containing 10.249 acres,
BEGINNING at a point in the centerline of Beetem Hollow Road, T-350, thence South
twenty-three (23) degrees eighteen (18) minutes ten (10) seconds West to a point in the
centerline of Beetem Hollow Road, T-350, thence North eighty-two (82) degrees fifty-two (52)
minutes fifteen (15) seconds East to a point along lands now or fonnerly of David L. McGowan
thence South five (5) degrees forty-five (45) minutes zero (0) seconds East Four hundred ninety-
five and forty-six hundredths (495,46) feet South fifteen (15) degrees forty-eight (48) minutes
and fifty (50) seconds East One hundred twenty-four and eighty-thIee hundredths (124.83) feet
to a point thence South twelve (12) degrees fifty-six (56) minutes fifty-five (55) seconds East
Five hundred thirty-five and forty-one hundredths (535.41) feet to a point along lands now or
fomlerly of Gary E. Galbraith thence North eighty-two (82) degrees zero (0) minutes forty-five
(45) seconds East Three hundred forty-eight and eighty-six hundredths (348.86) fcetto a point
land known as Lot #2 of said subdivision thence North eight (8) degrees thirty-five (35) minutes
zero (0) seconds West One thousand seventy-two and one one hundredths (1072.01) feet to a
point thence North seventy-eight (78) degrees forty-five (45) minutes fifteen (15) seconds West
Three hundred ninety-four and eighty-seven hundredths (394,87) feet to a point thence South
eighty-two (82) degrees fifty-two (52) minules fifteen (15) seconds West Two hundred eleven
and eighty-one hundredths (211. 81) feet to the point and place of BEGINNING
IT BEING part of the final plan of minor subdivision for Eli M. Dobrinoff, Jr., pIepared
by registered land surveyor, Rodney Lee Decker, and recorded Recorder of Deeds
. in and for Cumbel.land County, Pennsylvania, in Plan Book 5'3> ',Page 5" {:, .
IT BEING part of the parcel conveyed Roy W. Kelso and Mary M. Kelso, husband and
wife unto Ell M. Dobrinoff, k, on May I, 1986 and Recorded in the Office of the Recorder
of Deeds in and for Cumberland County on May 2, 1986. Recorded in Book W31, Page 180.
Subject to all R!3STRICTIONS and CONDITIONS previously recorded.
Subject to a Right-of-way along the EASTERN BORDER of Lot No. I, above described,
for ingress, egress, and transgress for Lot No, 2 along the EASTERN BORDER, a width of 50
feet and a length of 1,072.01 feet,
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October 27, 1997
Lisa Harden Smith
167 Beetem Hollow Road
Newville, PA 17241
Re: Sales Agreement with Eli M, Dobrinolf
Dear MI'S, Smith:
Please be advised that this office represents the interests of Eli M, Dobrinoff, Jr., relatlve to
your September I, 1996, Real Estate Installment Sales Agreement.
At this point be advised that you are in DEFAULT of the terms and provisions of the
agreement as follows:
1. Paragraph 2(d) re: Payment of Taxes, amount due: $1,489,24
2, Paragraph 3(d) re: Insuranee (Cancellation notice reteived),
3, Paragraph 2(b) fe: Payment of monthly installments
a, September 1997 amoUnt due and owing: $1,000,00
b, October 1997 amount due and owing: $1,200,00
c, As of November 1997, amount due: $1,200,00
Additionally, in that you have failed to make timely payment of such, you are responsible
for a $100.00 late fee for the months of September and October.
There also appears that there is a point of misunderstanding on your part regarding Mr.
Dobrinoff's offer of June 9, 1997, Such offer provided for a credit of $5,000,00, IF you settled on
01 before August 8, 1997, Obviously, this credit no longer is available or applicable,
Be advised that this is fOl111al notice of your default and that you must cure such default
ill1l11ediately, Your failure to take these steps will result in legal action being commenced to have
Mr, Dobrinoffregain possession of the property,
Very tl'llly YOUrs,
Kurt A. Blake
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Eli M. Dobrinoff, Jr.
VS,
Lisa Harden Smit h
"'0, 98-2407 Civil
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"'ow, 4/29/98
York
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19_, I SHERIff OF CUMBERlMI")) COUNTY, PA do bereb~' deputize tbe SberlfT of
Coun!)' to e~ecute Ihls Writ, this depulntlon beIng mode ot the request ond risk oflbe Plaintiff.
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3 ELI M, DOBRlNOFF, JR"
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 98-2407 CIVIL
4
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Notice to Defend
Mortgage Foreclosure
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LISA HARDEN SMITH
6 Defendant
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8 To: Lisa Harden Smith
103 Warrington Road
9 Dillsburg, Pennsylvania 17019
Date: ,lu,ne 3. 1998
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IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
12 REQUIRED OF YOU IN THIS CASE, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU
13 WITHOUT A HEARING AND YOU MA Y LOSE IMPORT ANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO A LA WYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT
14 AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP. .
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LA WYER REFERRAL SERVICE
YORK COUNTY BAR ASSOCIATION
137 EAST MARKET S' EET
YORK,PENNSYLV ~ 17401
(717) 854-8
Kurt A. BI e, EsqUIre
1.0, No. 68791
Attorney for Plaintiff