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JOliN \\'.1'111(('1'1.1.
HOWARD II. KIUI(i
I.EON 1',IIAI.I.1:Il
JOliN W. I'II/lCl'I.I. JR.
Ill1lAN J, TYLER
JILL M. WINEKA
1,A\1 orrrCES
PURCELL, KRUG AND HALLER
171') NORTII FRONT STREET
IIARRISllllIHi, I'ENNSYL VANIA 17102-2392
TEI.EI'1I0NE17I7i2J,I..il7X
FORECI.OSURE DEI'\'. FAX (717) 2J4-12()('
JOS[1'1l fllSSlEY (1910-1982)
AN THONY DiSANTO
OF COUNSEL
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HERSHEY
1099 GOVERNOR ROAD
(711)533.3636
NOTICE TO:
Eric R. Smith, Sr.
222 Marion Avenue
Carlisle, PA 17013
J~mes c. C~Gt.~p~u!os
}.3 Sou th Han'.':,~,i'e:- S t::.:-ee;:
C.~:~l.~.s:.e, Ph l"'O~.:::
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By:
Donna V. Smith
180 Youngs Church Road
Shermansdale, PA 17090
Jimmy Nesmith
655 North East Street
Carlisle, PA 17013
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
NOTICE IS HEREBY GIVEN to the Defendants in the within action and
those parties who hold one or more mortgages, judgments or tax liens
against the real estate which is the subject of the Notice of Sale
pursuant to Pennsylvania Rule of civil Procedure 3129.1 attached
hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution
issued out of the Court of Common Pleas of the within county on the
judgment of the Plaintiff named herein the said real e::~ will be
exposed to public sale as set forth on the attached NO;7~of Sale.
YOU ARE FURTHER NOTIFIED that the lien you hold a 'st the said
real estate will be divested by the sale and that have an
opportunity to protect your interest, if any, b g notified of
said Sheriff's Sale.
Leon P. Hall r PA I.D.15700
Attorney for Plaintiff
ERIC R. SMITH SR. AND DONNA V. SMITH
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
ALL THOSE TWO CERTAIN pieces or parcels of land situate in the
First Ward of the Borough of Carlisle, Cumberland County,
pennsylvania, bounded and described as follows:
TRACT 1:
ALL that certain house and lot of ground situated in
the First Ward of the Borough of Carlisle, Cumberland
County, Pennsylvania, hounded and described as follows:
BEGINNING at a stake at the Northeastern corner of
Henderson Avenue and North East Street: thence
extending along Henderson Avenue in an Easterly
direction 110 feet to a stake: thence at right angles
to Henderson Avenue in a Northerly direction 100 feet
to a stake: thence by a line at right angles tO,North
East Street in a Westerly direction 110 feet to a stake
at the Eastern side of North East Street; thence along
the Eastern side of North East Street in a Southerly
direction, 100 feet to a stake, the place of BEGINNING.
TRACT 2:
ALL that certain tract of land situate in the Borough
of Carlisle, Cumberland County, Pennsylvania, more
particularlY bounded and described according to a
survey prepared by Stephen G. Fisher, R.S., dated Hay
13, 1982, as follows, to wit:
BEGINNING at an existing reinforcing bar at the
northeast corner of Henderson Street and a 40 foot
private right-of-way; thence .along the northern right-
of-way line of Henderson Street North 75 degrees 43
minutes West 50.20 feet to 'an existing steel pin;
thence along lands now or formerly of Nicholas and
Delores J. Haravic North 14 degrees 38 minutes East
99.27 feet to an existing steel pin; thence by lands of
said Nicholas and Delores J. Haravic South 74 degrees
53 minutes East 49.34 feet to an i~on pin; thence ulcng
a 40 foot private right-of-way South 14 degrees 8
minutes West 98.55 feet to an existing reinforcing bar
at the northeast corner of Henderson Street, the place
of BEGINNING. CONTAINING 4922,,5 square feet.
THE DWELLING THEREON KNOWN AS 655 NORTH EAST STREET, CARLISLE, PA
BEING THE SAME PREMISES WHICH Patrick K. Walker and Terry E. Walker
by deed dated October 26, 1994 and recorded in Cumberland County
Record Book 114 Page 9 granted and conveyed unto Eric R. Smith, Sr.
and Donna V. Smith.
TO BE SOLD AS THE PROPERTY OF ERIC R. SMITH, SR. AND DONNA V. SMITH
UNDER CUMBERLAND COUNTY JUDGMENT NO. 98 - 3389 CIVIL.
ASSESSMENT:
02-20-1800-111
Re: GE Capital vs. Eric Smith, Sr.
Cumberland County Sale 03/03/99
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage
One piece of ordinary mail addressed to:
Postmark:
James C. Costopoulos
13 South Hanover Street
Carlisle, PA 17013
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GE Capital Mortgage Services
-vs-
Eric R. Smith Sr. and Donna Smith
In the Court of Common Pleas of
Cumberland County. Pennsylvania
No. 98-3389 Civil Term
Timothy Reitz, Deputy Sheriff who being duly sworn according to law, says on January 8,
1999 at II :34 o'clock A.M. E. S. '1'., he posted a copy ufreal Estate Writ Notice Poster and
Description in the above entitled action on the property of Eric R. Smith Sr. and Donna Smith
located at655 North East Street, Carlisle, Cumberland County. Pennsylvania according to law.
Kenneth Gestured, Deputy Sheriff~ who being duly sworn according to law, says on January
13, 1999 at 8:35 0 'clock A. M. E. S. T, he served a true copy of Real Estate Writ Notice Poster
and Description in the above entitled action upon one of the within named defendants to wit: Eric
R. Smith Sr., by making known unto Eric Smith Sr. at 222 Marion Avenue, Carlisle Cumberland
County, Pennsylvania, its contents and at the same time handing to him personally the said true
and attested copies of the same.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above
Real Estate Writ Notice Postcr and Description in the following manner: The Sheriff mailed a
notice ofthc pendency of the action to one of the within named defcndants to wit: Eric R. Smith
Sr., by regular mail to his last known address 222 Marion Avenue, Carlisle, Pennsylvania. This
letter was mailed under thc date of January 14, 1999 and nevcr returned to the Sheriffs Office.
R. Thomas Kline, Sheriff who being duly sworn according to law, says he made diligent and
search for one of the within named defendant to wit: Donna v; Smith, but was unable to locate
her in his bailiwick. He therefore deputized the Sheriff of Perry County to serve the within Real
Estate Writ Notice Poster and Description according to law.
PERRY COUNTY RETURN: Now January 9, 1999 at 9;30 o'clock a.m. served the within writ
Notice & Description upon Donna V. Smith at 180 Young's Church Road, Shermansdale, PA by
handing to Donna V. Smith a true and attested copy of the original Writ Notice & Description
and made known unto her the contents thereof.
So answers; Carl E. Nace Deputy Sheriff Perry County.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above
entitled Real Estate Writ Notice Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to one of the within namcd defendants to wit:
Donna V. Smith by Certified Mail Return Receipt Requested, Restricted Delivery Deliver to
\ .
Addressee Only to 180 Young's Church Road, Shermansdale. The letter was mailed under the
date of January 6, 1999 and received by Donna V. Smith on January 8, 1999 the return receipt
card signcd by Donna V. Smith.
R. Thomas Kline ,Sheriff who being duly sworn according to law says he served the above
Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a
notice ofthe pendency of the action to one of the within named defendants to wit: Donna V.
Smith by regular mail to her last known address 180 Young's Church Road, Shermansdale, PA.
This letter was mailed under the date of January 14, 1999 and never returned to the Sheriffs
Office.
R. Thomas Kline, Sheriff who being duly sworn according to law, says that after due and
legal notice had been given according to law, exposed the within described premises at public
venue or outcry at the Court House, Carlisle, Cumberland County, Pennsv~val11~'a on March 3,
. 1I!1-"" I'.$'
1999 at 10:00 A.M.EST and sold the samc to Attorney Leon P. Haller 10rllle ecretaryof
I
, .
. I
Veterans Aflhirs. Its successor and assigns. Wissahickon A vcnuc and Manhcim Slrcct.
Philadelphia. Pcnnsylvania. It bcing thc highcsl bid and bcst pricc rcccivcd for thc samc Thc
Sccrctary of Vctcrans AfIllirs bcing thc buycr in this EXcculion paid to R. Thomas Klinc. thc
sum of
$ 984.86 it bcing Shcrilfs Costs.
Sheri tr s Costs:
Dockeling
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
County
Mileage
Certified Mail
Levy
Surcharge
Out of County
Perry County
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
Poundage
30.00
15.00
15.00
30.00
10.00
.50
1.00
3.10
6.79
15.00
18.00
9.00
27.80
353.75
355.50
24.25
25.00
26.50
18.67
$ 984.86 I'd by ally 3.15.99
Sworn and Subscribed To Before Mc
This /1,PDay of (};uY
1999,A.D.~\, f?)-v"IlJ!U,<>>r;'
rothonotary
So~ ~~~
r.~;;"'d< ~
R. 1110mas Kline, Sheri f
ByAt:...~. .Jtdt:-
Real Estate Deputy
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GE CAPITAL MORTGAGE
SERVICES, INC.,
PLAINTIFP
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
ERIC R. SMITH, SR. AND
DONNA V. SMITH,
DEPENDANTS
NO. 98 3389 CIVIL
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 655 North East Street, Carlisle, PA:
1. Name and address of the Owner(s) or Reputed Owner(s):
Eric R. Smith, Sr.
222 Marion Avenue
Carlisle, PA 17013
Donna V. Smith
180 Youngs Church
Shermansdale, PA
Road
17090
2. Name and address of Defendant(s) in t.he Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record ..on the real property to be sold:
4. . Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
5. Name and address of every other person who has any record
lien on the property:
UNKNOWN
I:\HOMEWKF\DOCS\CUMBERLAISMITH,PTF
. '
ALL THOSE TWO CERTAIN pieces or parcels of land situate in the
First Ward of the Borough of Carlisle, Cumberland County,
Pennsylvania, bounded and described as follows:
TRACT 1:
ALL that certain house and lot of ground situated in
the First Ward of the Borough of Carlisle, Cumberland
County, Pennsylvania, hounded and described as follows:
BEGINNING at a stake at the Northeastern corner of
Henderson Avenue and North East Street: thence
extending along Henderson Avenue in an Easterly
direction 110 feet to a stake: thence at right angles
to Henderson Avenue in a Northerly direction 100 feet
to a stake: thence by a line at right angles tO,North
East street in ~ westerly direction l10 feet to a stake
at the Eastern side of North East street: thence along
the Eastern side of North East Street in a Southerly
direction, 100 feet to a stake, the place of BEGINNING.
TRACT 2:
ALL t.hat certain tract of land situate in the Borough
of Carlisle, Cumberland County, Pennsylvania, more
particularlY bounded and described according to a
survey prepared by Stephen G. Fisher, R.S., dated Hay
13, 1982, as follows, to wit:
BEGINNING at an existing reinforcing bar at the
northeast corner of Henderson Street and a 40 foot
private right-of-way; thence .along the northern right-
of-way line of Henderson Street North 75 degrees 43
minutes West 50.20 feet to 'an existing steel pin;
thence along lands now or formerly of Nicholas and
Delores J. Haravic North 14 degrees 38 minutes East
99.27 feet to an existing steel pin: theoce by lands of
said Nicholas and Delores J. Maravlc South 74 degrees
53 minutes East 49.34 feet to an iron pinj th~nce along
a 40 foot private right-of-way South 14 degrees 8
minutes West 98.55 feet to an existing reinforcing bar
at the northeast corner of Henderson Street, the place
of BEGINNING. CONTAINING 4922,,5 square feet.
THE DWELLING THEREON KNOWN AS 655 NORTH EAST STREET, CARLISLE, PA
BEING THE SAME PREMISES WHICH Patrick K. Walker and Terry E. Walker
by deed dated October 26, 1994 and recorded in Cumberland County
Record Book 114 Page 9 granted and conveyed unto Eric R. Smith, Sr.
and Donna V. Smith.
TO BE SOLD AS THE PROPERTY OF ERIC R. SMITH, SR. AND DONNA V. SMITH
UNDER CUMBERLAND COUNTY JUDGMENT NO. 98 - 3389 CIVIL.
ASSESSMENT:
02-20-1800-111
ERIC R. SMITH SR. AND DONNA V. SMITH
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common pleas of the within County to set aside the sale
ALL THOSE TWO CERTAIN pieces or parcels of land situate in the
First Ward of the Borough of Carlisle, Cumberland County,
Pennsylvania, bounded and described as follows:
TRACT 1:
ALL that certain house and lot of,ground situated in
the First Ward of the Borough of Carlisle, Cumberland
County, Pennsylvania, hounded and described as follows:
BEGINNING at a stake at the Northeastern corner of
Henderson Avenue and North East Street; thenge
extending along Henderson Avenue in an Easterly
direction 110 feet to a stake; thence at right angles
to Henderson Avenue in a Northerly directi~n 100 feet
to a stake: thence by a line at right angles to. North
East Street in a Westerly direction 110 feet to a stake
at the Eastern side of North East street; thence along
the Eastern side of North East Street in a Southerly
direction, 100 feet to a stake, the place of BEGINNING.
TRACT 2:
ALL that certain tract of land situate in the Borough
of Carlisle, Cumberland County, Pennsylvania, more
particularly bounded and described according to a
survey prepared by Stephen G. Fisher, R.S., dated Hay
l3, 1982, as follows. to wit:
BEGINNING at an existing reinforcing bar at the
northeast corner of Henderson Street and a 40 foot
private right-of-way; thence .along the northern right-
of-way line of Henderson Street North 75 degrees 43
minutes West 50.20 feet to 'an existing steel pin;
thence along lands now or formerly of Nicholas and
Delores J. Haravic North 14 degrees 38 minutes East
99.27 feet to an existing steel pin: thence by lands of
said Nicholas and Delores J. Maravic South 74 degrees
53 minutes East 49.34 feet to an iron pin; thence along
a 40 foot private right-of-way South 14 degrees 8
minutes West 98.55 feet to an existing reinforcing bar
at the northeast corner of Henderson Street, the place
of BEGINNING. CONTAINING 4922,,5 square feet.
THE DWELLING THEREON KNOWN AS 6?5 NORTH EAST STREET, CARLISLE, PA
BEING THE SAME PREMISES WHICH Patrick K. Walker and Terry E. Walker
by deed dated October 26, 1994 and recorded in Cumberland County
Record Book 114 Page 9 granted and conveyed unto Eric R. Smith, Sr.
and Donna V. Smith.
TO BE SOLD AS THE PROPERTY OF ERIC R. SMITH, SR. AND DONNA V. SMITH
UNDER CUMBERLAND COUNTY JUDGMENT NO. 98 - 3389 CIVIL.
ASSESSMENT: 02-20-1800-111
..
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 98-3389 CIVIL1~X TE~
. - -
CIVIL ACTION. LAW
TO THE SHERIFF OF Ctrnoc,rland
COUNTY:
To satisfy the debt, interest and costs due GE Capi tal Mortqaqe Services. T nc.
from Eric R. Smith. Sr. 222 Marion Avenue Carlisle Pa. 17013
Donna V. Smith l80 Youn s Church Road Shermansdlae. Pa. 17090
PLAINTlFF(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
Real Pro r located at 655 North East Street, Carlisle. Pa.
DEFENDANT(S)
~
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notify the garniShee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) It property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other
than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due
(Per Diem
Interest
Atty's Comm
Ally Paid
Plaintilt Paid
S97 n9.57
of $21.95 from (7/l/98
~. 1.77 7l:j
l.l.
Due Prothy
$0.50
1.00
to 3/3/99)
%
Other Costs
(7/98 to JI':!':!)
Late Charqes at $28.93
714.60
$ 231. 44
82.000.00
Date:
-Escrow DPfi"H
December 16, 1998
Curtis R. Long
Prothonotary, Civii Division
REQUESTING PARTY:
Name Leon P. Haller. Esq.
Address: 17] 9 North Front Street
HarrisburG, Pa. 17102
Attorney for: Plainti ff
Telephone: ( 717) 234 -4178
Supreme Court ID No. 15700
by: y", _ 0.. /11.J pc,',.-'
Deputy
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THE PATRIOT NEWS
THE SUNDAY PATmOT NEWS
Proof of Publication
Under Ret No.587. Rooroued MaV 16. 1929
Commonwealth of Pennsylvsnla, County of Dsuphln} 88
hUchaelAforroMl being duly sworn according to law, deposes and says:
That he Is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 818 Market Street, In
the Clly 01 Harrisburg, County 01 Dauphin, Slale 01 Pennsylvania, owner and publisher 01 THE PATRIOT.NEWS and
THE SUNDAY PATRIOT.NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street,
in the City, County and State aloresald; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto Is exactly as printed and published in
their regular dally and/or Sunday and Metro editions/Issues which appeared on the 26th day of January and the 2nd
and 9th day(s) 01 February 1999. That neither he nor said Company Is Interested In the subject mailer 01 said
printed notice or advertising, and that all 01 the allegations of this statement as to the time, place and character 01
publication are true; and
That he has personal knowledge 01 the facts aloresald and Is duly authorized and empowered to verily this
statement on behalf of The Patriot-News Co. aloresald by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board 01 directors 01 he said Company and subsequently duly recorded in
the of lice lor the Recording of Deeds In and lor said County 01 a hln in Miscellaneous Book "M',
Volume 14, Page 317.
PUBLICATION
COpy
S ALE #38
I
,
,
CUMBERLAND COUNTY SHERIFFS OFACE
COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertisina Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication allached
hereto on the above stated dates $
Proballng same Notary Fee(s) $
Total $
354.00
1.50
355.50
Publisher's Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher 01 THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers 01 general
circulation, hereby acknowledge receipt of the aloresaid nollce and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
By..............................;,..........................,.....:...
GE CAPITAL MORTGAGE
SERVICES, INC.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
NO. q S'-3:; S' 7 Cu-:.J -ri.v~
ERIC R. SMITH, SR. AND
DONNA V. SMITH
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOT ICE
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 the
Complaint and notice are served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the Court without
further notice for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
a Irvine Row, Carlisle, PA 17013
717-243-9400
A V ISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
US TED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
5. The land subject to the Mortgage is: 655 NORTH EAST
STREET, CARLISLE, PENNSYLVANIA 17013 and is more particularly
described in Exhibit "B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on January 1,
1998 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $
(b) Interest at $21.95 per day
from 12/1/97 to 7/1/98
(based on contract rate of 9.000%)
87,809.58
4,653.40
(c) Accumulated Late Charges
115.72
(d) Late charges at $28.93
per month for 7 months
(e) Escrow Deficit
202.51
57.88
(f) 5% Attorney's Commission
4,390.48
$ 97,229.57
*Together with interest at the per diem rate noted in (b) above
after July 1, 1998 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
INIT1~L
g
, ~':;Oi"~""
. -' ....
NOTE
VA
:=H N-:.l,~:'5(1- t
C;1~C Nil.
i\Iullislalc
.1,-:.O'~6~t
,JCT88E~ :6TH. l?q~
Illalcl
6Z;~ NORTH EAST S'fREET. CARt_ISLE. PA :7013
Il'rnrCIl~' "dtllc~"1
I. PARTIES
U[]orrO\\lcr" means each person signing at lite end or lhis Note. <lilt! the person's successors tlnd :1ssigns. "Lender" menlls
NORWEST MORTGAGE. INC.
and its successors and assigns.
2. nOR[WWER'S PROMISE TO I'A Y; [NTEREST
[n relurn for a loan received frum Lendcr, BOITower promises to pay the principal sum of
THOUSAND NINE HUNDRED AND OO/10U
EIGHTY i'IINE
Dollars (U.S. .$ *****89.900.(0), plus interest, 10 the ordcr of Lcmler. Inlerest will be chargeu onltnpaiu principal,
from the date of disbursement of the loan proceeus by Lenuer, atlhe rate of NINE
per cent ( 9.000 %) per year lInlilthe full amount of principal has been paiu.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secureu by a mortgage, ueeu of trust or similar seeurily instrument that is ualed the same uale
as this Note anu called the "Security Instrument." That Security Instrument protects the Lcnder from losses which might result
if Borrower defaults under this Note.
4. MA.NNER OF PAYMENT
(A) Time
DECE~\lfE.'Wer shall mak'i ~dJ~ment of pri~,ci~al anu !nterest 10 L~I~uer on Ihe first uay of ea'j\\\jJ'E!14B~inning on
'?n?4 ' . Any principal anu Interest remanllng on the first day of ,
- - - . will be uue on that date, which is called the "Maturity Date."
(B) Place E~ 0 I NEe;
'NORWEST MORTGAGE INC. II P.O. BOX 5137, D.~ M _,
I A ~!tW.!\~~l~J}le made at
or at such other place as Lenuer may designate in writiitg
by notice to Borrower.
(C) Amount ********723,36
Each monthly payment of principal anu interest will be in the amounl 01'.$ . This alllount
will be part of a larger monthly payment required by the Security Instrument. that shall be applied to principal, interest anu
other items in Ihe order described in the Security [nstrument.
(D) Allonge to this Note for payment odjustments
If an allonge providing for payment adjustments is executed by Borrower together with Ihis Nole. Ihe covenanls of
the allonge shall be incorporated into and shall amend alld supple1l1enttl1e covenants of Ihis Note as if Ihe allonge were a part of
this Note. [Check applicable boxl
DOraduUled Payment Allonge DGmwiog Equily Allonge DOther [specifYI
5. BORROWER'S RIGIIT TO I'REI'A Y
Borrower has the right 10 pay Ihe uebl eviuenced by Ihis Note, in whole or in parI, wilhout charge 01' penalty. on Ihe fir;t
day of any month.
O.,,~lRI910JI
L 'L . i ,'fl!j'/P
1i!if.~JtTr(!JJ.,'-rpnMS/i11JI7~3.A 100. mOOI5".n91
VA :oll'i Mull latc 1';",
---'
6. BOIUWWER'S FAILURE TO I'A Y
(i\) Lute CllDrge for Ol'erdue I'n)'lIleuls
If Lender hus not received Ihe fullmonlhl)' pa)'menl required b)' Ihe Securil)' In,lrumcnl. a, described in l'aragrnph
4(C) of this Nole b)' the end of fifteen calellllar days after Ihe pa)'menl is due. Lender ma)' collect a laic charge in Ihe amnunt of
FOUR per ecnt ( 4. (H)(> %) of Ihe overdue an.ounl of each payment.
(Il) Dcfllull . " FHA2-(>35(l-2, , .
If Borrower defllulls by f,"hng III pa)' "' full 'm)' monlhly pa)'menl. Ihen Lender ma)', execI'I 'IS hnlltcd by regulations
of the Sccretllry in Ihe cuse of paymCl1t de f'lIIlls , rcquire imlllcdiale paymcnt in full of the principal balance rcmaining due IInd
ull accrued interest. Lender may choose not to exercise Ihis 01'1 ion without waiving its righls in the evenl of any subsequent
defaull. lu many circumslances regulalions issued by Ihe Sccrelary will limil Lellder's righls to require immediale p,.)'menl in
full in Ihe case of pay men I defaulls. This Nole does nol authori,e acceleralion when not perlllittcd by IIUD regulations. As used
inlhis Nole. "Secretary" mc:lns the Secrelary of Housing and Urban Development or his or her designee.
(C) PaJmenl of Costs and Expenses
If Lender has required inunediate pa)'melll in full, as described above, Lender may require Ilorrower 10 pay costs and
expenses including reasonable and cusIOlllDry attorneys' fees for enforcillg this Note. Soch fee, and costs shall bear inleresl from
the dale of disbursement al the same rale us Ihe principal of Ihis Nole,
7. WAIVERS
Borrower and any olher person who has obligations under this Note waive Ihe rights or presentmenl and nolice of
dishonor. "Presentmenl" IIlc:lns the righl 10 require Lender 10 demand pa)'lIlent of ",nounls due, "Nolice of dishonor" means
Ihe right to require Lender to give notice 10 olhcr persons that amounts due have nol been paid.
8. GIVING OF NOTICES
Unless applicable law requires a dirrerelll method. any notice that must be given to Dorrower under Ihis Nole will be given
by delivering it or by mailing it by first class nmil to Borrower at the properly address above or al a different address if
Borrower has given Lender a notice of Borrower's dirferenl address.
Any notice tbalmusl be given to Lender under this Nole will be given by firsl class mail In Lender at the address slaled in
Paragrnpb 4(B) or at a different address if Borrower is given a nolice of Ihal dirrerenl address.
9. OBLIGATIONS OF PERSONS UNDER TillS NOTE
Ir more than one person signs this Note. each person is full)' and personally obligaled to keep all of Ihe promises made in
Ihis Nole, including the promise 10 pay the full amount owed. Any person who is a guarantor. surety or endorser of this Note is
also obligated to do these Ihings. Any person who lakes over these obligations, including Ihe obligations of a guaranlor, surely
or endorser of Ihis Note, is also obligated 10 keep all of Ihe promises made in this Nole. Lender may enforce ils rights under this
Note against each person individually or against all signatories together. Anyone person signing Ihis Nole ma)' be required to
nav att nLthc..nnlolllllS..!lru:d..uudct.lhis Note,
NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUt THEAPPROV AL OF
THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT,
~?~-?
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
(Seal) L V_~
-Oorruwcr
DONNA \; sr'l I TH
(Seal)
-narrower
WITHOUT RECOURSE
eAY IU IHE ORDER Of
(Seal)
(Seal)
-nllrrower
WITHOUT RECOURSE
PAnO THE ORDER OF
-Bcurnwcr
GE Capital Mortgage Services, Inc,
NOPM~R~E, INC,
By . '\ / Ar
Eileen R. Slelzne
Assislant Secfl\lary
~;CA~~V~NC.
O~lp Sr:hneidmiller
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GE CAPITAL MORTGAGE
SERVICES, INC.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
NO. ti S' 3 OJ.I '7 C ,~,:(,i' '-r.:..
ERIC R. SMITH, SR. AND
DONNA V. SMITH
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOT ICE
You have been sued in court. It you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after the
Complaint and notice are served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the Court without
further notice for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REG ISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES' POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
TRUE COpy FROM RECORD
In Tostimony whereof, I here unto set my hand
and the seal of said Court at Carlisle, s.~
fhls lii\:!::",- day ~'-<-<~ ,.19 _
qlw ( '- " 'A-t., el'l~ ,'l~
. , , Prothonotary
GE CAPITAL MORTGAGE
SERVICES, INC.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VB.
NO.
ERIC R. SMITH, SR. AND
DONNA V. SMITH
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
COM P L A I N T
1. plaintiff, GE CAPITAL MORTGAGE SERVICES, INC., is a
corporation, with an address of 4680 Hallmark Parkway, San
Bernardino, California, 92407.
2. Defendant, ERIC R. SMITH, SR., is an adult individual
whose last known address is 655 NORTH EAST STREET, CARLISLE,
PENNSYLVANIA 17013. Defendant, DONNA V. SMITH, is an adult
individual whose last known address is 655 NORTH EAST STREET,
CARLISLE, PENNSYLVANIA 17013.
3. On or about October 26, 1994, the said Defendants
executed and delivered a Mortgage Note in the sum of $89,900.00
payable to NORWEST MORTGAGE, INC., which Note is attached hereto
and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 1239, Page 32 on October 28, 1994
conveying to original Mortgagee the subject premises. The
Mortgage was subsequently assigned to GE CAPITAL MORTGAGE
SERVICES, INC. and recorded in the aforesaid County in Mortgage
Book 517, Page 315 on April 8, 1996. Said Mortgage and
Assignment are incorporated herein by reference.
5. The land subject to the Mortgage is: 655 NORTH EAST
STREET, CARLISLE, PENNSYLVANIA 17013 and is more particularly
described in Exhibit "B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on January 1,
1998 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 87,809.58
(b) Interest at $21.95 per day
from 12/1/97 to 7/1/98
(based on contract rate of 9.000%) 4,653.40
(c) Accumulated Late Charges
115.72
(d) Late charges at $28.93
per month for 7 months
(e) Escrow Deficit
202.51
57.88
(f) 5% Attorney's Commission
4,390.48
$ 97,229.57
*Together with interest at the per diem rate noted in (b) above
after July 1, 1998 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
1
I,
P
.'
,~.
"
.
'~Q'7f r::""'l
4 _'. . '._
i\lullistnlc
NOTE
VA
r.!-t),35(l-1
':,SO.~6..t
~
]CTJ8E~ :6TH. 199~
Ill,'cl
65~ ~iOI~TH EAST S'fREET. CARL!SLE. PA 17()13
(l'roperly "t111,c.~~J
I. PAIlTIES
"Oorrowcr" mcans each persoll signing at the el1<J ofth;s Nole, and the persoll's successors and assigns. "Lender" means
NOR~JEST 1'10RTGAGE, me.
and its succcssors and assigns.
2. OOllllOWEll'S PROMISE TO PA Y; INTEIlEST
In rcturn for a loan received from Lcndcr. Borrower promisc., to pay the principal sum of
THOUSAND NINE HUNDRED AND 00/10U
EIGHTY I'Hi'JE
Dollars (U.S. $ *****89,900.00), plus interest, to the order of Lender. Inlerest will be charged on unpaid principal,
from Ihe date of dis9l!~emenl of the loan proceeds by Lender. at the rale of NINE
per cent ( 9, l.ll}(.. % ) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage. deed of trust or similar security instrument Ihat is dated the same dale
as this Nole and called the "Security Inslrumen!." That Security Inslrument prolecls the Lender from losses which mighl resuh
if Borrower defaults under this Note.
4. ~IA.NNER OF PAYMENT
(A) Time
DE'rE~llfE.W'er shall mak, ii>~~ment of principal and interest to Lender on the first day of eaj\\IjI~14JB~inning on
?0;4 .' . Any principal and inlerest remaining on the first day of .
- - . will be due on thaI dale, which is called the "Maturity Date."
(il) Place
I A ~!!.\':I.!\~llliJ;be made at
'NORWEST MORTGAGE INC." P.O. BOX 5137, DES MOINES,
by notice to Borrower.
(C) Amount ********723,36
Each monthly payment of principal and inlerest will be in the amount of $ . This OIuount
will be part of a larger monthly payment required by the Security Instrument. that shall be applied to principal, inlerest OIld
other ilems in the order described in the Security Instrumen!.
(0) Allonge to lhis Note for payment adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Nole. the eovenanls of
the allonge shall be incorporated into and shall amend and supplemcntthe covenant., of this Note as if the allonge were a part of
this NOle. [Check applicable box]
OOraduatcd Payment Allonge DOrowing Equity Allonge DOlher [specify]
or al such other place us Lender may designale in writihg
5. nOIlROWEll'S RIGIITTO I'IlEI'AY .
Borrower has the righllo pay Ihe debt evidenced by this Nole, in whole or in pari, withnul charge or penally, on Ihe first
day of any monlh.
.~.1AI910JI
-.c.,,/L'L.j ,'f~o/I'
C7'1"PJlT~'TJ1"Ms/'1'J'2~'J'Rloo. tnooIS:11.n91
VA m4X ';,1ull laic Fhc II c" 2/91
P6-
'.
6. BORROWER'S FAILURE TO I'A Y
(A) Lnte Chnrge for Ol'enJue I'n,'lIIenls
If Lender has nol receivcd the fullmonlhly pnymenl required by the Security Instrument. as described in Pnragrnph
4(C) of Ihis Note by the end of rorleen calendar days aner Ihe paYlllenl is due, Lender may collect a lale charge in the amounl of
FOUR per cclll ( 4. (1l)(J %) of Ihe overdue alllonnl of ench payment.
(0) Default FHA"'-(I35n-'"
If Borrower defaults by failing 10 pay in full any monlhly paymenl, then tender niay,-except as limited by regulalions
of Ihe Secrelnry in Ihe case of payment defaulls, rcquirc immcdiate paymcnl in full of the principal balance remaining due nnd
nil accrucd inlerest. Lender may choose not 10 exercise this 01'1 ion withoul wniving ils righls in Ihe evenl nf nny slIbseqllenl
defnult. III many circumstances regulations issued by the Secrelnry will limit Lellder's righls to require immediate paymellt ill
full in Ihe case of payment defaults. This Note docs not authorize acceleration when nol permitted by BUD regulations. As used
in this Note, "Seerelary" m""ns the Seerelnry of Housing and Urban Development or his or her designee.
(C) I'nrlllell( of Costs nnd Expeuses
If Lender has required immediate paymellt in full, as described above, Lender may require Borrower to pay costs and
expenscs including reasonable and customary aitomeys' fces for enforcing this Nole. Such fees and COSls shnll b""r inlerest from
Ihe dole of disbursement at the same role ns the principal of this Nole.
7. WAIVERS .
Borrower and any otber person who has obligations under this Nole waive Ihe rights of presenlment and notice of
dishonor. "Preselllment" llI""ns Ihe right to require Lender 10 demand payment of mnounts ~ue. "Nolice of dishonor" means
Ihe right to require Lender to give nOlice 10 other persons Ihat amounls due have nol been paid.
8. GIVING OF NOTICES
Unless applicable low requires a differentmelhod, any notice that must be given to Borrower under this Note will be given
by delivering it or by mailing it by nrst class moil 10 Borrower at the property address above or at a different address if
Borrower has given Lender a notice of Borrower's different nddress.
Any notice that must be given to Lender under Ihis Nole will be given by nrst class mail to Lender at the address staled in
Paragrnph 4(B) or nt a different address if Borrower is given a notice of that different nddress.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of lhe promises made in
Ihis Note, including the promise to pay the full amount owed. Any person who is a guarnntor, surety or endorser nf this Nole is
also obligated to do these things. Any person who tokes over these obligations. including Ihe obligations of n guarnntor, surety
or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender lIIay enforce its rights under Ihis
Note agninst each person individually or against all signalories togelher. Anyone person signing this Nole may be required 10
nnv ~II nL.1.he...amollnIC: nwp.clund.eL'hic:: Notp.
NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUt THEAPPROV AL OF
THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT,
~?~~
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenanls contained in Ihis Nole.
~
(Seal)
v~
(Seal)
-norrower
-
-Dorruwer
DONNA II S~I I TH
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PAY TO THE OROER OF
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Assistant Secr!l'~ry
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GE CAPITAL MORTGAGE
SERVI CES, I NC .
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaint if f
VS.
('I.' j J S., (i . - 1 ~J .
NO. / J. . ) I ., "...c.t .....,
ERIC R. S~IITH, SR. AND
DONNA V. SMITH
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOT ICE
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 the
Complaint and notice are served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the Court without
further notice for any money claimed in the Complaint or for 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 C}~ GET LEGAL HELP.
cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-2';3-9400
A V ISO
LE illL~ DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERV1DO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: S1 USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
TRUE COpy FROM REeOHO
In Testimony whereof, I here unto ~et rWi hand
and the seal of said cO~J~ at Carlisle, Pa.
This J ~ 0::::: day of L I <C~ _' 19 q 9
(1'~'" Q /M...JlP'd,~~"
. ' I Prothonotary
::97:'::
NOTE
VA
FH r.!-I:l,:::S(l-l
Cue No.
i\lullislale
.1 ':.'=?'S6.t
JCTJ8E~ 26TH. t99~
IIl'Ie'
65j NORTH EAST STREET, CARLISLE. PA :71)13
I Property "lhJrc~!'i1
1. PARTIES
"llorrower" means each person signing atlhe end of lhis Nole, and the persnn's successors and assigns. "Lender" llIeans
NORWEST NGRTGAGE, mG.
and its successors and assigns.
2. llORROWER'S PROMISE TO I'A Y; INTEREST
In relurn for a loan received from Lender. Borrower prolllise.' 10 pay lhe principal SUIll of
THOUSAND NINE HUNDRED AND (~/10U
EIGHTY ~HNE
Dollars (U.S. $ *****89.900.(0). plus interest, 10 the order of Lender. Interest will be charged on unpaid principal.
frollllhe dale of disbursement of lhe loan proceeds by Lender, allhe rule of NINE
per cenl ( 9.000 %) per year unlilthe full alllount of principal has been paid.
3. PROMISE TO PA Y SECURED
Borrower's promir,e to pay is secured by a mortgage, deed of lrust or similar securily inslrulllenllhal is ~aled the sallie dale
as lhis Nole on~ called lhe "Security lnstrulllen!." That Security lnslrulllent prolecls lhe Lender from losses which llIighl result
if Borrower defaults under this Nole.
4.l\IA.NNER OF PAYMENT
(A) Time
DECE~grgwer shall mak" ~cIJ~menl of pri~cipol and ~nlerest 10 L~l~der on lhe first day of eO'f.\\j~~18~inning on
"n"4 . . Any pClnclpal an~ Interest remoll1lng onlhe first day of ,
- - - . will be due onlhat dole, which is called lhe "Maturity Dote."
(B) Place
I A ~'3'IJ.!l~l.oIJ,e mode al
'NORWEST NORTGAGE INC." P.O. BOX 5137, DES MOINES,
or at such 01 her place os Lender llIay ~esignale in writihg
by notice 10 Borrower.
(C) Amount ********723,36
Each monthly payment of principal and interest will be in lhe omounl of $ . This ol11ounl
will be port of a larger monlhly payment required by lhe Securily Inslrumenl. lhot shall be :.pplied 10 principal, inlerest and
olher items in lhe order described in the Security [nslrumenl.
(D) Allonge to this Note for payment adjustments
If on allonge providing for payment adjustments is execule~ by Borrower logelher with lhis Note, the covenants of
the allonge sholl be incorporaled illlo and shall olllend and supplelllenllhe covenanls of this Nole as if lhe allonge were 0 part of
lhis Nole. [Check applicable box]
DGruduated Payment Allonge DGrowing Equily Allonge DOther [specify]
5. naRROWER'S RIGHT TO I'REI'A Y
Borrower has lhe righllo pay the debl evidenced by lhis Nole, in whole or in parI. wiLhnul chargc llr penalty, on Ihe firsl
day of any monlh.
<<D~ .1R 1910:11
-t.:::.,,;'- 'L. / I'i'.!'Jo/l'
cMrJO'T~,.rpnMS/lt:Jl29J.A'OO .U\0015'I.n91
VA JrnJ'i Mull
II e. 2/91
'.
6. BORHOWER'S FAILURE TO PA \'
(AI LaIc Charge for O\'Crdue Pa)'nlents
If Lender has not received the full 1I10nthly paymenl required by Ihe Securily In,lrull1ent. u,i described in Paragraph
4(C) of Ihis Nole by Ihe end of fifteen calendar days afler Ihe paYll1enl is due. Lender lI1ay collecl a laic charge ill the all10unl of
FOUR per celli ( 4. (1(10 %) of the overdue all10unl of each l'aYll1enl.
(U) Default FHA"'-035l',-'"
If Borrower defaulls by failing to pay in full any lI1ontl11y paYll1enl, Ihen tender niay,-exeepI as lill1iled by regulalions
of Ihe Secretary illlhe case of paYll1ent defaults, require inllllediale paYll1enl in full of the principal balance rCll1aining due and
all accrued interest. Lender lI1ay choose not 10 exercise Ihis opliun wilhout waiving ils righls in lhe evenl of tll1Y subseljuenl
default. In many circumstances regulations issued by Ihe Secrelary will limil Lender's righls 10 require ill1mediate paYll1ent in
full in the Case of payment defaults. This Note does not aulhorizc acceleration when not permilled by H UD regulalions. As used
in this Nole, "Secretary" means the Secrelary of Housing and Urban Developmenl or his or her designee.
(C) I'a)'menl of Costs and Expenses
If LendO' has required immediale payment in full, as described above, Lender lI1ay r~quire Borrower to pay cosls and
expenses including reasonable and cuslomary allorneys' fees for enforcing Ihis Nole. Such fees and costs shall benr inlcresl from
the dale of disbursemel1l at the s~me rale as Ihe principal of this Note.
7. WAIVERS
Borrower and any other person who has obligalions under Ihis Nole waiye the righls of presentmenl and notice of
dishonor. "Presenlment" lI1eans lhe righlto require Lender to demand payment of amounls due. "NOlice of dishonor" means
the righllo require Lender to give notice to olher persons Ihat amounls due have nol been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different melhod, any notice thalmusl be given to Borrower under Ihis Note will be given
by delivering it or by mailing it by firsl class mail 10 Borrower at Ihe property address above or al a different address if
Borrower has given Lender a notice of Borrower's differenl address.
Any nOlice Ihal must be given to Lender under this Nole will be given by first class lI1aillu Lender althe address staled in
Paragraph 4(B) or at a different address if BOlrower is given a notice of Ihal differenl address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs Ihis Nole, each person is fully and personally obligated 10 keep all of Ihe proll1ises made in
Ihis Note, including the promise 10 pay the full all10unt owed, Any person who is a guarantor. surely or endorser of this Nole is
also obligated to do these things. Any person who takes ovcr lhese obligalions. including the obligations of a guarantor. surety
or endorser of Ihis Note, is also obligated 10 keep all of Ihe promises made in this Note. Lender lI1ay enforce its righls under Ihis
Note againsl each person individually or against all signalories together. Anyone person signing Ihis Nole may be required to
n~v ~1I nf...1.he..anl0UllJ.S....mllCclundct..thic:: Nnle
NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUtTHEAPPROV AL OF
THE DEPARTMENT OFYEfERANS AFFAIRS OR ITS AUTHORIZED AGENT.
~g~-?
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenanls contained in this Nole.
.~
(Seal)
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(Seal)
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DONNA '! S~I r TH
WITHOUT RECOURSE
~AY IU IHI: OADEROF
(Seal)
(Seal)
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WITHOUT RECOURSE
PAYTO THE ORDER OF
-Unrrowcr
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O"lp Sr.hneidmilier
',Atlc..\rn~v j1 ~acl
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GE CAPITAL MORTGAGE SERVICES, INC.
IN THE COURT OF COMMON PLEAS
CUMBERLfu~D COUNTY, PENNSYLVANIA
PLAINTI FF ,
VS.
NO. 98-3389 Civil Term
ERIC R. SMITH, SR. AND
DONNA V. SMITH,
DEFENDANTS
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the complaint on the above captioned matter.
DATE: AUGUST 10, 1998
PURCELL, KRUG, & HALLER
BY ~ )#i~
Leon" P. Haller '---..
1719 North Front Street
Harrisburg, Pa. 17101
Attorney for Plaintiff
Attorney ID# 15700
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ALL THOSE TWO CERTAIN pieces or parcels of land situate in the
First Ward of the Borough of Carlisle, Cumberland County,
Pennsylvania, bounded and described as follows:
TRACT 1:
ALL that certain house and lot of ground situated in
the First Ward of the Borough of Carlisle, Cumberland
County, Pennsylvania, hounded and described as follows:
BEGINNING at a stake at the Northeastern corner of
Henderson Avenue and North East Street; thence
extending along Henderson Avenue in an Easterly
direction 110 feet to a stake: thence at right angles
to Henderson Avenue in a Northerly direction 100 feet
to a stake; thence by a line at right angles tO,North
East Street in a Westerly direction 110 feet to a stake
at the Eastern side of North East street; thence along
the Eastern side of North East Street in a Southerly
direction, 100 feet to a stake, the place of BEGINNING.
TRACT 2:
ALL that certain tract of land situate in the Borough
of Carlisle, Cumberland County, Pennsylvania, more
particularly bounded and described according to a
survey prepared by Stephen G. Fisher, R.S., dated Hay
13, 1982, as follows, to wit:
BEGINNING at an existing reinforcing bar at the
northeast corner of Henderson Street and a 40 foot
private right-of-way; thence ,along the northern right-
of-way line of Henderson Street North 75 degrees 43
minutes West 50.20 feet to 'an existing steel pin;
thence along lands now or formerly of Nicholas and
Delores J. Haravic North 14 degrees 38 minutes East
99.27 feet to an existing steel pin: thence by lands of
said Nicholas and Delores J. Haravic South 74 degrees
53 minutes East 49.34 f~ct to an iron pinj thence along
a 40 foot private right-of-way South 14 degrees 8
minutes West 98.55 feet to an existing reinforcing bar
at the northeast corner of Henderson Street, the place
of BEGINNING. CONTAINING 4922,,5 square feet.
THE DWELLING THEREON KNOWN AS 6?5 NORTH EAST STREET, CARLISLE, PA
BEING THE SAME PREMISES WHICH Patrick K. Walker and Terry E. Walker
by deed dated October 26, 1994 and recorded in Cumberland County
Record Book 114 Page 9 granted and conveyed unto Eric R. Smith, Sr.
and Donna V. Smith.
TO BE SOLD AS THE PROPERTY OF ERIC R. SMITH, SR. AND DONNA V. SMITH
UNDER CUMBERLAND COUNTY JUDGMENT NO. 98 - 3389 CIVIL.
ASSESSMENT:
02-20-1800-111
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GE CAPITAL MORTGAGE
SERVICES, INC.,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
ERIC R. SMITH, SR. AND
DONNA V. SMITH,
DEFENDANTS
NO. 98 3389 CIVIL
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on NOVEMBER 24, 1998 I served the Ten
Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this
matter by regular first class mail, postage prepaid, as indicated
on the attached Notice.
By ~
Leon P. Hall r PA I.D. #15700
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front St.
Harrisburg, PA 17102
6.
interest
sale:
Name and address of every other person who has any record
in the property and whose interest may be affected by the
UNKNOWN
7. Name and address of every other person of whom the
Plairrtiff has knowledge who has any interest in the property which
may be affected by the sale:
TENANTS I F ANY
Jimmy Nesmith
655 North East Street
Carlisle, PA 17013
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit
and correct to the best of my personal knowledge, infor
belief. I understand that false statements herein are
to the penalties of 18 PA C.S. Section 4904 relati
falsification to authorities.
are true
~ on and
subject
o unsworn
Leon P. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: December 14, 1998
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ERIC R. SMITH SR. AND DONNA V. SMITH
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone (7l7) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
j'.
2. After the Sheriff's Sale you may file a petition with the
Court of Common pleas of the within County to set aside the sale
ALL THOSE TWO CERTAIN pieces or parcels of land situate
First Ward of the Borough of Carlisle, Cumberland
Pennsylvania, bounded and described as follows:
TRACT 1:
ALL that certain house and lot of ground situated in
the First Ward of the Borough of Carlisle, Cumberland
County, Pennsylvania, hounded and described as follows:
BEGINNING at a stake at the Northeastern corner of
Henderson Avenue and North East Street; then~e
extending along Henderson Avenue in an Easterly
direction 110 feet to a stake: thence at right angles
to Henderson Avenue in a Northerly direction 100 feet
to a stake; thence by a line at right angles tO,North
East Street in a westerly direction 110 feet to a stake
at the Eastern side of North East Street; thence along
the Eastern side of North East Street in a Southerly
direction, 100 feet to a stake, the place of BEGINNING.
in the
County,
TRACT 2:
ALL that certain tract of land situate in the Borough
of Carlisle, Cumberland county, Pennsylvania, more
particularlY bounded and described according to a
survey prepared by Stephen G. Fisher, R.S., dated Hay
13, 1982, as follows, to wit:
BEGINNING at an existing reinforcing bar at the
no~theast corner of Henderson Street and a 40 foot
private right-of-way; thence.along the northern right-
of-way line of Henderson Street North 75 degrees 43
minutes West 50.20 feet to 'an existing steel pin;
thence along lands now or formerly of Nicholas and
Delores J. Haravic North 14 degrees 38 minutes East
99.27 feet to an existing steel pin; thence by lands of
said Nicholas and Delores J. Haravic South 74 degrees
53 minutes East 49.34 feet to an iron pin: .hence alung
a 40 foot private right-of-way South l4 degrees 8
minutes West 98.55 feet to an existing reinforcing bar
at the northeast corner of Henderson Street, the place
of BEGINNING. CONTAINING 4922,,5 square feet.
THE DWELLING THEREON KNOWN AS 655 NORTH EAST STREET, CARLISLE, PA
BEING THE SAME PREMISES WHICH Patrick K. Walker and Terry E. Walker
by deed dated October 26, 1994 and recorded in Cumberland County
Record Book 114 Page 9 granted and conveyed unto Eric R. Smith, Sr.
and Donna V. Smith.
TO BE SOLD AS THE PROPERTY OF ERIC R. SMITH, SR. AND DONNA V. SMITH
UNDER CUMBERLAND COUNTY JUDGMENT NO. 98 - 3389 CIVIL.
ASSESSMENT:
02-20-1800-111
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