HomeMy WebLinkAbout98-03561
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I SOVEREIGN BANK, F.S.B. as assignee or
I Amnit)' National Mortgage.
, Plaintiff
IN THE COUHT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL I>IVISION - LAW
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MORTGAGE FORECLOSURE
NO. ~'ir - J 5'10 I
C-~
vs.
ROGER L. KUMLER JR. and TAMMY L.
KUMLER, Husband and Wire.
Derendants
NOTICE TO DEFEND
YOU HA VE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS
SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY
(20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE 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 FORTI.I
AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY
PROCEED WITHOUT YOU AND A JUDGMENT MAYBE ENTERED AGAINST YOU BY
THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN TI-IE
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 LA WYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, 4'1'11 FLOOR
CARLISLE,pA 17013
(717)240-6200
pIOSA HIXSON & REILLY, p.c.
LAwOmCES
PIOSA HIXSON & REILLY P.C
ONE WINCSO" PlAZ~. SUITE 101
7535WINOSOF! DRIVE
ALLENTOWN, PA 18195-1014
1610! 530-7500
4.
On May 20, 1994, Defendants executed and delivcred a Mortgage to Plaintiff
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upon the Premises, which Mortgage was recorded on AugustS, 1994 in the Office of the
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Recorder of Deeds, Cumberland County, Pennsylvania, in Mortgage Book 1227, Page 150, el.
seq, (the "Mortgage"). A true and correct copy of the Mortgage is attached hereto, marked as
Exhibit "13", and incorporated hcrein,
5. On or about May 20. 1994, the Mortgage was assigned by Affinity National
Mortgage, to Plaintiff, Sovereign Bank, F,S,I3. (the "Assignment"), A true and correct copy of
the Assignment is attached hereto, marked as Exhibit "c" and incorporated herein.
6. The Mortgage has not been further assigned by the Plaintiff.
7. The Mortgage was given as collateral security for a loan to the Defendants as
evidenced by a Note executed by the Defendants on May 20, 1994 in the principal amount of
Forty-one Thousand One Hundred Dollars ($41,100.00) (the "Note"). A true and correct copy of
the Note is attached hereto, marked as Exhibit "0", and incorporated herein.
8. The Mortgage is in default because the Defendants have failed to make monthly
payments of principal and interest due under the terms of the Note and the Mortgage since March
1,1998,
9, Because of the aforesaid default, on or about May 5, 1998, a Notice of Default
and Intention to Foreclose Mortgage was mailed to the Defendants by certified mail, return
receipt requested, wherein Plaintiff demanded that the Defendants make a payment of$I,287,93
LAW OFFICES
PID5A HiXSON 8: REILLY P.C.
ONE WINDSOR P~AZA, SUITE 101
as required by the Mortgage in order to cure the aforesaid default. A true and correct copy of the
7535Wn~050R DRIVE
said Notice of Intention to Foreclose Mortgage is attached hereto and marked as Exhibit "E",and
ALLENTOWN, PA 18195.1014
(610) 530-750"
incorporated herein,
LOAN NO. !) 4 0 0 9 ~ q
THIS SECURITY INSTRUMENT combInes unllorm COVor;iHlIS lor nalional use find non-uniform covenants with
limited vdrlallons by Jurlsdlclion to c.on5t1tutc a uniform security lnslrumcnl covering real property
UNIFORM COVENANTS. Borrower and Lendor covonant {lnd agree as follows:
1. Payment ot Principal and Interest; Prepayment and Late Charges. Borrower shall promplly pay when duo
tho principal of nnd Inlorest on Iho dobl ovldenced by tho Nolo and llny prepayment anc.llalo chmlJcs duo undor tho
Nolo.
2. Funds for T8KOS and Insurance. Subjocllo llppllcnhlo law or 10 a wrlllon waiver by Londor, Borrowor 511(111 pay
to Londor on tho day monthly payments arc duo unclor Iho NOlo. Ilnllllho NolO Is puid in full, a sum ("Funds") lor: (El)
yearly laxos and assessments whIch may attaIn priority over thIs Securtly Instrumunt as n 11011 011 the Property; (I>) yearly
leasehold payments or ground rents on tho Property, II any; (c) yearly haznrd or property Insurance premiums; (dJ
yearly flood Insuranco promlul11s. II any; (0) yearly mor1gago inSlJrHnce premlullls, if any; and (I) any sums payablo by
Borrower to Londor. In accordanco with tho provisions 01 pmaoraph O. in lieu of the payment 01 mortgage Insurnnco
premiums. Thoso Itoms are called -Escrow Items: Lender may, at AllY limo. collocl and hold Funds In an mnount not
to exceed the maximum amount a lelldor for a fnclmnlly mlntml mor1gago loan mny ruqtllre lor Borrower's oscrow
account under Ihe fodoral Real Estale Settlomonl Procedures Act 011974 as amended from limo 10 tlmu. 12 V.S.C. !i
2601 et seq. (-RESPA"), unless another law that applltls to the Funds sets a lessor amount. II so, Lender may, al any
time, collect and hold Funds In an amollntnot to exceed tho lessor amount. Lender may estlmate the amount 01 Funds
due on the basis of currenl dala and reasonable estlmales 01 expendlluros of llltum Escrow Items or otherwIse In
accordanco with appllcablo law.
The Funds shall be held In an Instilution whose deposits are Insured by a ledora! agency, Instrumentality, or enllty
(includIng Lender, If Lender Is such an Instltutlon) or In any Federal Home Loan Bank. lendor shall apply Ihe Funds to
pay the Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing tho
escrow account, or verifying the Escrow ICems, unless lender pays Borrower Interest on tho Funds and applicable law
permits lender to make: such a charge. However, Lender may requIre Borrower to pay a one.llme charge lor an
independent real estate tax reporting service used by Lender In connecllon wIth this loan, unless applicable law
provides otherwise. Unless an agreement Is made or applicable law requires Interest to be paid, Lender shall not be
required to pay Borrower any/nterest or earnings on the Funds. Borrower and Lender may agree In writing, however,
that Interest shall be paId on t 1e Funds. Lender shall give to Borrower, without charge, an annual accounting 01 the
Funds, showing credits and deblls to the Funds and the purpose lor whIch each debit to tho Funds was made. The
Funds are pledged as additional security lor all sums secured by this Security Instrument.
If the Funds held by Lender exceed the amounts perlllilled to be held by applicable law, Lender shall account to
Borrower for the excess Funds In accordance with the requirements of applicable law. If the amount of the Funds held
by Lender at any lime Is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower In writing. and,
In such case Borrower shall pay to Lender the amollnt necessary to make up the deficiency. Borrower shall make up
the deficIency In no more than twelve monthly payments, at Lender's sole dlscrellon.
Upon payment In full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any
Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender, prior to the acquisition
or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the
sums secured by this Security Instrument.
3. Application of Payments. Unless applicable law provides otherwise. all payments received by Lender under
paragraphs 1 and 2 shall be applied: first, to any prepaymenl charges due under the Note; second, to amounts payable
under paragraph 2; third, to Interest due; fourth, to principal due; and last, to any late charges due under the Note.
4. Chargesj Liens. Borrower shall pay all taxes, assessments. charges. fines and impositions attributable to the
Property which may attain priority over this Securily Instrument, and leasehold payments or ground rents, If any.
Borrower shall pay these obligations in the manner provided In paragraph 2, or If not paid in that manner. Borrower
shall pay them on tIme directly to the person owed payment. Borrower shall promptly furnish to Lender all notices of
amounts to be paid under this paragraph. II Borrower makes these payments directly, Borrower shall promptly furnish
to Lender receipts evIdencing the payments.
Borrower shall promptly dIscharge any lien which has prIority over thIs Security Instrument unless Borrower: (a)
agrees in writing to the paymenl of the obligation secured by the lien In a manner acceptable to Lender; (b) contests In
good faith the lien by. or defends against enforcement of the lien In, legal proceedings which In the lender's opinion
operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to
lender SUbordinating the Hen to this Security Instrument. If lender determines that any part of the Property Is subject
to a lien whIch may attain priorIty over this Security Instrument, Lender may give Borrower a notice Identifying the lien.
Borrower shall sallsfy the lien or take one or more 01 the actions set forth above within 10 days 01 the giving of notice.
5. Hazard or Property Insurance. Borrower shall keep the Improvements now existing or herealler erected on the
Property Insured agaInst loss by fire, hazards included withIn the term "extended coverage- and any other hazards,
includIng floods or flooding, lor whIch Lender requIres Insurance. This insurance shall be maintained In the amounts
and for the periods that lender requires. The Insurance carrier provIding the Insurance shall be chosen by Borrower
subject to lender's approval which shall not be unreasonably withheld. If Borrower falls to maintain coverage descrIbed
above, lender may, at Lender's option, obtain coverage to protect Lender's rights In the Property In accordance with
paragraph 7,
PENNSVLVANIA..SIUGLE FAMILY..FUMA/FHLMC UNIFORM INSTRUMENT
ISC/CMDTPA//0391/3039(9.gOl.L PAGE 2 OF 6
FORM 3039 9/90
800'K1227 PIGE 151
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LOAN NO (j 4 0 0 'I t, 'I
AlIlnsurLlncO potlclcs and renewals shalllw nccun1nhlo to londor and shnlllncludo n standard mortgage c1nuso.
Londor ~hall havo Iho rlohlla hold 1110 policies and renowals. II Londor requires. Borrower shall promptly glvo 10 londor
all recelpls 01 paid promlums and renowal notlcos. In Iho olJont of loss. Borrower shall 011/0 prompt notice 10 tho
Insurance carrier und lender. lendor may make rHool ollossll not made promptly hy Borrower.
Unloss Londor and Borrower otherwise ooroo In wrllln{J, Insurance proceeds shall ho applied to rostornllon or ropnlr
01 tho Property damaged, 1I1ho restomtlon or ropnlr Is oconomlcally feaslhlo anu Lomler's security Is nOllossonod. II
tho restoration or fopnlr Is nol oconomlcally feasible or lend or's securlty would be IOS50110d, tho Insurance proceeds
sholl ue applied 10 tho sums secured by this Securlly Instrument, wholher or not then duo, wllh any excess paid 10
Borrower. II Borrower almndons tho Ptoperty, or doos not answer within 30 days rt nolleo from lendor thot the
Insurance carrlor has ollorcd 10 scllle a claim, then lemler mny collect Iho Insurance proceeds, lender may llse tho
proceeds to repaIr or restore tho Proporty or to pay sums secured by thIs Security Illslrllmenl, whelhor or nol thon duc.
The 3D.day porlod will boaln whon tho notice Is alven.
Unless Lender end Borrower othorwlso aareo In writing, any application of I1roceods to prlncll1al shall not oxtend or
postl1one tho due dato olll1e monthly paymonls relerred 10 In paragraphs 1 and 2 or chanao Iho amounl 01 the
paymenls. II under paraoroph 21 tho Property Is acquired by Lendor, Borrower's rlghlla any insurance policies and
proceedS resulting from damage to tho Property prIor to lho acquIsition shall pass 10 lender 10 the Qx1ent of the Slims
socured by this Socurlty Instrument Immediately prior to Iho acqulslllon.
6, Occupancy, PrescfVoUon, Maintenance and Protection of the Property; Borrower's Loan Application;
leaseholds. BOlTOWB! shl1/J occupy, establish, and use the Property as Borrower's principal resIdence within sixty
days alter Iho execution 01 this Security Instrument and shall continue to occupy the Property as Borrower's principal
residence lor at leasl one year aller the date 01 occupancy, unless lendo! otherwise agrees In writing, which consent
shall not be unreasonably withheld, or unless extenuallng circumstances exist which are beyond Borrower's control.
Borrower shall not destroy, damage or Impair the Property. allow the Property to deteriorate, or commit waste on the
Property. Borrower shall be In default II any forfeiture action or proceeding, whether clvll or criminal, Is begun that In
lender's good faith Judgment could result In forfeiture of the Property or otherwIse materially Impair the lien created by
thIs Security Instrument or lender's securIty Interest. Borrower may curo such a default and reinstate, as provIded In
paragraph 18, by causing Ihe acllon or proceeding to be dIsmissed with a ruling that, In lender's good faith
determInation, precludes forfeiture 01 the Borrower's Interest In the Property or other material Impairment of the llen
created by this Security Instrument or Lender's security Inlerest. Borrower shall also be in default If Borrower, during the
loan application process, gave materially false or lna~curate Informatlon or statements 10 lender (or failed to provide
lender wllh any materIal Information) In connection with the loan evidenced by the Note, Including, but not limited to,
representations concerning Borrower's occupancy 01 the Property as a principal resIdence. If this Security Instrument
Is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquIres fee title to tho
Property, the leasehold and the fee title shall not merge unless lender agrees to the merger in writing.
7. protecllon of Lender's Rights In the Property. If Borrower falls to perform the covenants and agreements
contained In thIs Security Instrument, or there Is a legal proceedIng that may significantly affect lender's rights In the
Property (such as a proceeding In bankruptcy, probate, lor condemnation or forfeiture or to enforce laws or
regulations), Ihen lender may do and pay for whatever Is necessary to protect the value 01 the Property and lender's
rights In the Property. lender's actions may Include paying any sums secured by a lien which has priority over this
Security Instrument, appearing In court, payIng reasonable attorneys' fees and entering on the Property to make repairs.
Although lender may take action under this paragraph 7, Lender does not have to do so.
Any amounts disbursed by lender under thIs paragraph 7 shall become addillonal debt of Borrower secured by
Ihls SecurilY Instrument. Unless Borrower and lender agree to other terms of payment, these amounts shall bear
Interest from the date of disbursement at the Note rate and shaH be payable, with Interest, upon notice from lender to
Borrower requestIng payment.
8. Mortgage Insurance. If lender required mortgage Insurance as a condllion of making the loan secured by this
Security Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in effect. If, for any
reason, the mortgage Insurance coverage required by lender lapses or ceases to be In effect, Borrower shall pay the
premiums required to obtain coverage substantially equivalent to the mortgage Insurance previously In effect, at a cost
substanlfally equivalent to the cost to Borrower of the mortgage Insurance previously In effect, from an alternate
mortgage Insurer approved by lender. If substantially equivalent mortgage Insurance coverage Is not available,
Borrower shall pay to lender each month a sum equal to one.twelfth of the yearly mortgage Insurance premium beIng
paId by Borrower when the insurance coverage lapsed or ceased to be In effect. lender will accept, use and retain
these payments as a loss reserve In lieu of mortgage Insurance. loss reserve payments may no longer be required, at
the option of Lender, If mortgage Insurance coverage (In the amount and for the period that lender requires) provIded
by an Insure! approved by lender agaIn becomes available and Is obtained. Borrower shall pay the premiums requIred
to maIntain mortgage insurance In effect, or to provide a loss reserve, untillhe requirement lor mortgage insurance ends
In accordance with any written agreement between Borrower and lender or appllcable law.
9. Inspection, lender or Its agent may make reasonable entries upon and Inspections of the Property. lender
shall gIve Borrower noUce at the time of or prior to an Inspecllon speclfying reasonable cause for the Inspection.
10. Condemnation. The proceeds 01 any award or claim for damages, direct or consequential, in connecllon wIth
any condemnation or other taking of any part of the Property, or lor conveyance In lieu 01 condemnation, are hereby
assIgned and shall be paid to lender_
PEtlUSVLVANIA..SlflGLE FAMILV..FtlMA/FHLMC UNIFORM.NSTRUMENT
ISC/CMDTPAI/0391/3039(9-90j-L PAGE 3 OF 6
fORM 3039 9/90
eooK1227 PAGE 152
LOAN NO, !l 4 0 0 ~ ~ 9
In tho evont of (] lOllll taking of tho Property, tho'procccds 511[111 be applied 10 tho sums soclJrod by tills Security
Instrument, whelhor or not then dU€l, wllh any OXCQSS paid to Borrowur. 1111110 ovont of i:I parllal laking of 1110 Property In
which Ihe fal, market value DIllie Property irnmedllllcly boloro tile laking is aqualla or grcalor limn tho i'Imounl of Iho
slims secured by Ihis Security InSlrurnont Immodl,lloly before tho Inking, unloss Borrower and Londor Olhorwl50 agree
In wrlllng, tho sums socured by Ihls SoclJrlly Instrumenl stulll bo reducod by ltlO nnlounl of tho procoods mulllplled by
Iho following lraclle": (a) tho lalal amount of tho sums securod lnunodlaloly boloro 1110 Inking, dlvldod by (bltho fair
markot valuo of tho Properly Immediately boloro lho laking. Any balal1co shall ho paId 10 Borrower. In Iho ovont of n
par1lallaklllO of Ihe Property In whIch Ihe lair markot valuo ollhn Proporty ImlT1edlatoly boloro 1110 laking Is loss limn lho
amounl of Ihe sums secured hnrnedlalcly bofore Ihe laking, unloss Borrower llnd Lmlcler olherwlse fluree III wrlllng or
unless appllcablo law OlherNlso provides, tho proceeds shall bo applied 10 Iho slims securO(J by this Socurlly Instrurnonl
wl10lher or not 1110 sums are then duo.
IIlho Property Is abandoned by Borrowor. or II, allor notice by Londor 10 Borrower Ihatlho concJernnor offors 10
make nn aW:Hd or sottle a claim lor darn.1Uos, Borrowor lall~ 10 rosponeJ to Lender within 30 days niter the dala tho
noUce Is given, Lender Is authorized to collecl and apply the proceeds, at ils opllon, ellher to roslorallon or repair of tho
Proper1y or 10 Iho sums secured by Ihls Security Inslrument, wllOther or notlllOn duo.
Unless lender and Borrower OlhoMlse agreo In wrillng, any appllcallon of proceeds 10 principal shall nol extend or
postpone the due date ollhe monthly payments relerred to In paragraphs 1 and 2 or Chango 1I1e mnount of such
payments.
11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of Il1e time for payment or
modlllcallon of amOr1lzalJon of the sums sccured by this Security Instrument granted by Londer to any SUCCCSSor In
Interest 01 Borrower shall nol operate 10 releaso fhe JlabiJIfy of the original Borrower or Borrrowcr's successors tn
Interest. Lender shall not be required to commence proceedings against any successor In Interest or refuse to exlend
lime for payment or olherwlse modify amor1/zallon of the sums secured by thIs Security Instrument by reason of any
demand made by Ihe origInal Borrower or Borrower's successors In Interest. Any forbearance by Lender In exercising
any right or remedy shall nol be a waiver of or preclude the exercise of any right or remedy.
12. Successors and ASSigns Bound; Joint and Several Liability; Co-signers, The covenants and agreements
of this Security Instrument shall bind and benellt the successors and assigns 01 Lender and Borrower, subject 10 the
provisions 01 paragraph 17. Bdrrower's covenants and agreements shall be Joint and several. Any Borrower who
co-signs this Security Instrument but does not execute Ihe Note: (a) Is co-signIng thIs Security Instrumenl only 10
mortgage, grant and convey that Borrower's Interest In Ihe Property under the terms of this Security Instrument; (b) Is
not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees thai Lender and any other
Borrower may agree to extend, modify, forbear or make any accommodallons wllh regard 10 the terms of Ihls Security
Inslrument or the Note without thai Borrower's consen!.
13. Loan Charges. If the loan secured by this Security Instrument Is subjecl to a law which sets maximum loan
charges, and that law Is flnally Interpreted so thallhe Interest or other loan charges collected or to be collected In
connecllon with the loan exceed the permitted limIts, lhen: (a) any such loan Charge shall be reduced by the amount
necessary to reduce Ihe charge to the permitted limIt; and (b) any sums already collected from Borrower which
exceeded permItted limits will be refunded to Borrower. Lender may choose to make Ihls refund by reducing the
principal owed under the Note or by makIng a direct payment to Borrower. If a refund reduces prIncipal, the reduction
witl be trealed as a partIal prepayment withoul any prepayment charge under the Note.
14, Notices. Any nollce to Borrower provided for In Ihls SecurIty Instrument shall be given by delivering It or by
mailing it by first class mail unless applicable law requires use of another melhod. The nollce shaH be dlrecled to the
Proper1y Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given
by first class mall to Lender's address stated herein or any other address Lender designates by nolice to Borrower.
Any nollce provided for In thIs Security Instrument shall be deemed to have been given to Borrower or Lender when
given as provided In this paragraph.
15. Governing lawj Severability. ThIs Securily Instrument shall be governed by federal law and the law of the
jurisdIction In whIch the Property Is localed. In the event that any provisIon or clause of Ihis Security Instrument or the
Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Inslrument or the Note
which can be given effect without the conflicting provision. To this end Ihe provisions of this Security Instrument and
the Note are declared to be severable.
16. Borrower's Copy. Borrower shall be gIven one conformed copy of the Note and of Ihls Security Instrument.
17. Transfer of the Property or a Beneficial Inlerest In Borrower, If all or any part of the Property or any Interest
In It Is sold or transferred (or If a benellclallnterest In Borrower Is sold or transferred and Borrower Is not a nalural
person) without Lender's prior wrinen consent, Lender may, at its opllon, require Immediate payment In full of all sums
secured by this Security Instrument. However, thIs opllon shall not be exercised by Lender If exercise Is prohibited by
federal law as of the date of tills SecLlrlly Instrument.
If Lender exercises this opt/on, Lender shall give Borrower notice of acceleration. The noUce shall provIde a period
of not less than 30 days from Ihe date the notice is delivered or mailed within which Borrower must pay all sums secured
by Ihls Security Instrument. If Borrower falls to pay these sums prior to the expiration of thIs period, Lender may Invoke
any remedies permitted by this Securily Instrument without further notice or demand on Borrower.
PENNSYLVANIA_SINGLE FAMILY..FUMA/FHLMC UNIFORM INSTRUMENT
ISC/CMDTPA//0391/3039/9.90j.L PAGE 4 OF6
FORM 3039 9/90
eooi1227 PACE 153
I.OAN NO. ~ ~ 0 0 9 ~ ~I
lB. BorroNor'o RighI to Rolnototo. 1/ Borrowor mools cortaln comlilions, Borrowor shal/ havo Iho rlghllo havo
onlorcomonl ollhls Socu"ly Inslrumonl disconllnuod 01 anV I/mo prior 10 Iho oarl/er 01: (a) 5 days (or such ollwr porlod
as npplicablo law may spocl/y lor rolnSf<1l0mOnl) boloro solo ollho Proporty PUlSuonllo nny powor 01 solo conlalnod In
1I,'s SocurllV InSfrumonli or (b) onlry 01 0 ludgmonl onlorclng Ihls Socu'liy InSfrumon!. Thoso condll/ons oro 111<11
Borrowor: (a) pavs Londo, ali sums which Ihon WOUld ho duo undor Ihls Sncurlly In5l,umonl nnd Iho Nolo as 1/ no
occolomllon had occurrod; (b) curos nny doloull 01 anV olhor cOVonanls or auroomonls; (c) pays nli oxponsos Incurrod
In onlorclng Ihls SocurllV InSfrumonl, Including, hUI nOllimllod 10, roosonoblo Ollomeys'loos: nnd (d) lokos such acl/on
ns Londnr mny roasonahly roqulro 10 nssu,o Ihol Iho I/on of Ihls Securily InSfrUlnonl, Londor's rlghls In 1110 Proporty and
Borrower's ohligallon 10 poV Iho ""'IS Socured hy Ihls SocU'"V InSfrl/monl slmli conllnuo unchangnd. Upon
rolnslnlomonl hy Borrowor, Ihls Socu,"y Inslrumonl and Ihn obllgallons Socur",1 horeby sholl romoln lully oll.cllvo os /I
no nccolorallon hml occurrcd, Howover, Ihls rlOhlto rulnslllln shall not applV 10 Iho coso 01 accolo'allonl/ndor
p.1ragfaph 17.
19. Salo of NOlo; Cbango of Loan Sorvleor. Tho Nolo or 0 portlallnler05lln Iha Nato (Iogolho, wl!h Ihls Socurlly
InSfrUmOnl) may bo sold ono or mo,o limos wllhoUI p,'or nollco 10 Borrowor, A solo may rosull In 0 chango In Ibe emlly
(known os Iho "Loon SelVlcar') Ihal collecls monthly pavmanls duo I/ndor Iho NOle and Ihls Socurlly 10Sf,umenl. The,o
also maV bo ono or more changos of Iho Loon SOlVlcor un'olalo,1 to 0 sole ollhe Note, Illhere Is 0 change ollhe Loao
SelVlcer, Borrower will be given wrluon nollco 01 the chango In aceo'daoce wllh parag'aph 14 ahove and applicable
low, The nollco will slate Ihe nome and address olthe now Loon SOlVlcor anel 1110 addross to which paymoms shol/ld be
made. The nolleo will also contain any other jnformalfon required by applicable law.
20. Hazardous Substaneos. Borrowor sholl nol COUse or perml! Ihe prosonce, use, disposal, Sforage, or roloase
01 any Hazardous Sub5lancos on or In Ihe Property, Borrower shall nol do, nor allow anyone else 10 do, anVlhlng
a/lecllng Ihe Proporty Ihalls In viola lion of anV Envlronmo"'al Law, The preceding two semences sholl nol apply 10 Ihe
presence, use, or Sforage on Ihe Property of small quanlllles 01 Hazardous SUbstances Ihal are generally recognized to
be appropriate to nO'mal resld!,nllal Uses and 10 malmenanco ollhe PropertV,
Borrowor shall promplly give Lendor w,luon nollce 01 any Invosllgallon, claim, demand, lawsuil or olher acllon by
any govommenlal or regula lory agency or prlvale perty Involvlno Ihe PropertV and any Hazardous Subslance or
Envlronmenlal Law 01 which Borrower has actual knowledge, /I Borrower learns, or Is notified by any governmental or
regulatory aUlho,IIV, that any removal or Olhor ,"mediation 01 any Hazardous Subslance aftectlng Ihe Property Is
necessary, Borrower sholl promptly lake all necessary remedial actions In acco,dance wilh EnvlronmeOlal Low,
As used In Ihls paragraph 20, 'Haza,dous SubS/ances" ore Ihose subslances dolloed as loxlc or hazardous
subS/ances by Envlronmenlal Law and the follOWing subS/ances: gasoline, ke,osene, other lIarnmable or loxlc
pelroleum products, loxlc peslleldes and herbicides, volallle solvenls, malerlals conlalnlng asbeslos or formaldehyde,
and radioactive malerlals, As Used In Ihls paragraph 20, 'EnvlronmeOlal Law' means tederallaws and lows Ollhe
Jurisdiction where Ihe Property Is located Ihal relale 10 heallh, solely or envlronmeOlal prolectlon,
NON. UNiFORM COVENANTS, Borrower and Lender lurther covenaOl and agree as lollows:
21. Acceleration; Remedtes. lender shall give notice to Borrower prtor 10 acceleration fOllOWing Borrower's
breach 01 any covenanl or agreemenlln this Security Inslrumenl (but not prior to acceleration under paragraph
17 unless applicable law provides olberwlse), Lender sholl nollly Borrower of, among otber Iblngs: (a) the
delault; (b) the action required to Cure the detault; (c) wben Ihe delault mUsI bo cured; and (d) Ihal tallure 10 CUre
the default as speclllod may result In acceleration of tbe SUms secured by this Security Inslrument, foreclosure
by JudIcial proceeding and 3ale of the Property, lender sholl furtber Inform Borrower of Ihe right to relnstale
Oller acceleration and the rIght 10 assert in the foroclosure prOCeeding lhe non.exlstence of a default or any olher
delense of Borrower to acceleration and foreClosure. If the defaull Is not cured as specified, lender at Its option
may require Immedlale payment In full of all sums secured by this Security Instrument wltbout further demand
and may toreciose Ihls Security Instrument bV Judicial proceeding. Lender shall be entitled to collecl all
expenses Incurred In pursuIng tbe remedIes provfded In this paragraph 21,Includlng, bUI not limited la,
allorneys' fees and costs 01 title evidence to Ihe extent permitted by applicable law.
22, Release. Upon payment 01 ali SUms secured by Ihls Securlly InS/rumenl, this Securily InS/rumeOl and Ihe
eS/ale conveyed shalllermlnate and become void, After such occurrence, Lender sholl discharge and sallsfy 1I1ls
Securily Instrumenl wilhoul charge to Borrower, Borrower sholl pay any recordation cosls,
23. Waivers, Borrower, to the extenl permlUed bV applicable low, wolves and releases any error or delecls in
proceedings to eniorce Ihis Securily InstrumeOl, and hereby wolves Ihe benefit 01 any presenl or IUlure lows providing
lor stay 01 execullon, eXlensloo 01 time, exempllon trom allachmenl, levy and sale, and home5lead exempllon,
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PENfISVlVANIA_SItlGlE FAMIlY..FNMA/FHlMC UNIFOAM INSTRUMENT
ISC/CMDTPAfIOJ91/3039(9.90J.l PAGe 5 OF 6
FORM 3039 9/90
eoo! 1227 fAG! 154
LOAN NO, 9 4 00 , \ ,
Transfer 0' tho Properly or a Boncllclnllnlerost In Borrower. If all or any part ollho Properly or any
Inlcrosl In It Is sold or Imnsforrod (or II n bonoliclallrUoreslln Borrowor Is sold or transferred and Borrowor Is
not n natural person) Wlltl0UI Lendor's prIor writlon consonl, Londor may, at lis option. roqulro Immodlato
paymentl" full 01 nil slims socured by this Securlly InslrlJOlOIlI. However, Ihls apllen shall nol be oxorclsed
by Londor If oxorclso Is prohlbllod by loci oral law liS 011110 dalo ollllls Socurlty Inslrumon!. londor also shall
not exorclso Ihls option II: (0) Borrowor causos to bo submlllod 10 Londor Information required by Londor 10
ovaluate tho Inlendod Irnnsloroo us If n now lonn wore being mado 10 Iho transferoe: and (Ill lendor
reasonably dotermlnes IhalloncJor'~ socurlty will nol bo Impaired by tho loall assumpllon and that 1110 risk 01
n breach 01 any covenant or agreement In 11115 Sectlrlly Inslrumenlls acceptable to Lender.
To tho oxtonl permllled by applicable law, lendor may chargo a reasonable leo as a condlrloll 10
lendor's consenl fa the loan assumption. Londer nlso may require the Iransferee to sIgn an assumption
noroemenlthatls accepfablo to londer and Ihat obllgatos the transferee to keep all the promIses and
agreements made In tho Nolo and In thIs Security Inslrument. Borrower will conl/nue to be obllgaled under
tho Note and this Security Inslrument unless Londer releases Borrower In writing.
II lender exercises Iho option 10 require Immediate paymenlln full, Lender shall give Borrower notlce of
acceleration. The nollee shall provide a porlod of not less Ihan 30 days from the dale 1110 notice Is delivered
or mailed within which Borrower mus' pay all sums secured by thIs Security Inslrument. II Borrower falls 10
pay these sums prIor to the Qxplrallon of Ihls perIod, Lender may Invoke any remedies permifled by thIs
SecurIty Instrument without further nol/ce or demand on Borrower.
2. If Borrower exercises the Conversion Opt/on under the condilions stated In Sectlon B of Ihis
Adjustable nale R/der, tho amendment to Uniform Covenant 17 of Ihe Securlly Instrument conlalned In
Section C 1 above shall then cease to be In effect, and the provisions 01 UnIform Covenant 17 of the Security
Instrument shall Instead be In eUect, as follows:
Transfer of the Property or a Beneficial Interest In Borrower. If all or any part of the Property or any
Interest It In Is sold or transferred (or II a boneflclalInlereslIn Borrower Is sold or transferred and Borrower Is
not a nalural person) without lender's prior written consenl, Lender may, at Its option, require Immediate
payment In full of all sums secured by Illls Securlly Inslrument. However, this option shall not be exercised
by lender If exercise Is prohlblled by federal/aw as of Ihe date of this Securlly Inslrument.
If Lender exercises this option, Lender shall gIve Borrownr notice of acceleration. The notIce shall
provide a period of not less than 30 days from the date the nollce Is delivered or mailed within whIch
Borrower must pay all sums secured by this Security Inslrument. If Borrower falls to pay Ihese slims prior
to the expiration of thIs period, lender may Invoke any remedies permitted by thIs Security Instrument
without further nollce or demand on Borrower.
BY SIGNING BELOW, Borrower accepts and agrees (0 Ihe terms and covenants conlalned in this
Adjustable Rate Rider.
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R 0 G [R l. K IJ M l [ R, J .
(Seal)
SOHower
-----~afM~ ::R.'1{h.NhOPA
TAMMY l. KUHl R
(Sear)
Borrower
(Seal)
Borrower
(Seal)
Borrower
MULTISTATE ADJUSTABLE RATE RlDER-SINGLE FAMILY-FNMA UNIFORM INSTRUMENT
ISC/CAID..//0392/311B(Ol.B9).l PAGE 3 OF3
FORM31181/89
~OOK t.':!27 fAGE 159
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kFFINITY NATIONAL ",oRTGAGE
10 GREAT VALLEY PARKWAY
MALVERN, PA 19355
ASSIGNMENT OF MORTGAGE
KNOW ALL MEN BY THESE PRESENTS, THAT AFFINITY NATIONAL MORTGAGE ,n rally ollho lirsl part,
In cOllskJoratlon 011110 surn of TEN ($1000) DOLLARS and Olhur good nnd vahmblo cOflsfcJcratJon Jnlawful money ollho
United Sriltes 10 hill hand pnld by:
SOVEREIGN BANK, ^ FEDERAL SAVINGS BANK
1130 BERKSHIRE BOULEVARD, WYOMISSING. PA 19610
, party at the socond pmt, al or bofore tho onscallng ond delivery at Ih050 presonts. tho receipt whereof Is hereby
ilcknowlecJgod. lms oranled, bargained, sold. l1SSI{JIll!cJ. transferred llnd set over and by 111050 presents docs Iwmby oranl,
bargaIn, sell, assign. transfer and .sol over UlltO Iho said pmly ollho socond part Ihat certaIn Mortgage by;
ROGER L, KUMLER, JR, and TAMMY L, KUMLER
Intheamounlol $41,100,00
doled OS/20/94 ' and lilod
111.'!-etPaoe 15D
In Official Accords Book
MGQl'ItI(OO"lCt Of 'Hi
MGOfUllOf Ot:1Ol.
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I Cll*lUHO COtJJiITY J
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undor Clerk's FHa Number
on tile lollowlno doscribed property: 242 SUSQUEHANNA AVENUE
ENOLA,PA 17025
SEE LEGAL DESCRIPTION AlTACHED HERETO AND MADE A PART HEREOF
PREPARED BY: CAROL RoNDOLONE
together with the Note or obllgaflon described in saId Mortgage, and the money due and to become due thereon, wllh
Inlerest accrued and owing thereon.
TO HAVE AND TO HOLD the same unlo the said party of the second part, its successors and assigns forever, the said
party of the first part has caused these presenrs 10 be signed In lis Ilame by Its officer, and fls corporate seai 10 be affixed,
lilis 20lh
deyof May
1994
WITNESS:
AFFINITY NATIONAL MORTGAGE
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I, an Officer duly authorized to lake acknowledgements of deeds according to the laws of the Sla,; o~~v~nla, duly
qualllied and acting, hereby certily that KATE BECK "'\f'''''''
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STATE OF Pennsylvania
SS
to me personally known, this day acknowledged before me Ihat saId person executed the foregoing Assignment of
Mortgage as such Officer of said organlzallon, and Ihat said person affixed thereto the Official Seal of Ihe sald'9rg{!nlzallon
and Ilurther certily Ihall know the said rerson making said acknowiedomenllo be the Individual descpb~'f''lliJntlWho
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Public Stale of
ommlsslon Expires
IN WITNESS WHEREOF, I hereunto set my hand end Olflclel Soalln sold county
and Slate, Ihls 201h day 01 Ma
This Jnsllumenl was prepared by:
AFFINITY NATIONAL MORTGAGE
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PLAINTIFF'S
EXHIBIT
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ALL ~HA~ CER~AIN lot or parcol ot land oituato in Enola, East ponnsboro
Township, cumborland County, pennsylvania, boundod and doscribod, as follows,
to wit I .
BEGIIINING at a point in the Nort,horly 11no of suaquohanna Avenue at the
distance ot 161. 119 feet measurod Il0rthwestwardlY along .aid susquehanna
Avenus trom the NorthwesterlY extremity of the arc or curvo having a radius
ot ten (10) teot connocting tho Northorly lino of Juniata stroot with tho
said 11n of susquehanna Avenue, extending THE/ICE in 0 genoral Northwesterly
direction along the said lone at susquehanno Avenue, curving toward the left
with a radius at 275 teet, a diotance at fifty (50) teoti THENCE North 26
degreoS, 16 minutos, 13 seconds East, 119.719 toot; THENCE South 62 degreos,
20 minutes, 10 seconds Eest, 72.267 toot; ~HENCE South 36 dogroeS, 41
minutes, 16 seconds West (passing through the middle of tho partition wall
botwoon the house on this lot and tho houso on tho adjoining lot on the
southeast), 142.548 feot to tho place of BEGINNING.
HAVING THEREON ERECTED a two and one-half story semi-detached dwelling
house, known and nu~ered as 242 susquehanna Avenue, Enola, Pennsylvania.
BEING parcel No. 9-14-832-103A.
BEING THE SAM,E PREMISES WIIICH EVELYN MARIE FERRANTI, also known as
EVELYN M. FERRANTI, by Deod dated 1{7/91 and recorded 1/8/94 in the orfice
for the Recorder of Deeds in and tor the County ot CUMBERLAND, and
commonwealth at pennsylvania in ,Deed Book Volume X-34, page 1122, granted and
convoyed unto JOSEPH A. F~TI JR. AND ROSE ANN FERRANTI, in tee.
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Wltnc!:.' my hand an~eal of offico c C),/)'~'
Corli.lo, PA this ~ day 01 !lL,Z.
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AN NO. 9 4 0 0 !I OJ ~I
ADJUSTABLE RATE NOTE
(1 Ye.r Tre.sury Ind.x--R.I. C.ps-Flxed R.le Canv.rslan Opllan)
TIllS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE
AND MY MOIHlfLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY ADJUSTABLE
INTEREST RATE CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE I MUST PAY.
TIllS NOTF. ALSO CONTAINS TIlE OPTION TO CONVERT MY ADJUSTABLE RATE TO A
FIXED RATE.
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(Idle A S It II
ICily I
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ISllIlej
241 SUSQtl[ltANNA AV[NIJ[ .fnOlA,I'A lJ02S
IPfOplHlyAddfP,SSJ
1. BORROWER'S PROMISE TO PAY
In return for n loan thai I havo received, I proml5o 10 pay U.S. $ 4 I . I 00 . 0 0 (Ihls amounlls called
"prlnelpol"), plus Intoresl, 10 lho ardor of Iho Lendor, Tilo Londor 15 A r r ] n I r Y II A , loti A l H 0 R J v A r; [
I undorsland Ihat tho Lendor may Iransfer Ihls Nato. Tho Lemler or nnyone who lakos this Nato by lransfer and who Is'
enlll/od 10 receive paymenls undor Ihls Nolo Is called tho "Nole Holder."
2. INTEREST
Interesl will be charged on1unpnld principal unllllho fLJII amount of principal has boon paid. I will pay Inlerest at a
yearly ralo of 5 . B 7 5 0 %. Tho Interosl rate I will pay may chango In accordance with Sections 4 or 5 of this Note.
Tho Inlerost role required by this Socllon 2 anel Socllons 4 or 5 of Ihls Nato Is tho rala I will pay both before and afler
any defaull described In Socllon 8(B) of Ihls Nota. .
3, PAYMENTS
(A) Tim. end Plac. 01 Paym.nls
I will pay principal and Interest by making payments every month.
I will make my monlhly payments on tile IIrst day of each month beginning on J u 1 Y I. I 9 9 4 .
I will make these payments every month until I have paid all of the principal and Interest and any other charges described
below thaI I may owe undor thIs NOle, My monlhly payments wUl be applied to Interest before principal. If, on
J u n e 1. 2 0 Z 4 , I sUIl owe amounts under Ihls Note, I wlU pay those amounts In full 011 that date, which Is
called Ihe "Maturity Data."
I wlll make my monthly payments at I 0 {j REA T V A II [Y PAR K 'oJ A Y ,
HAL V [ R tI, P A I 9 3 5 S , or at a different
place II requlr.d by the Nale Haleler,
(B) Amounl 01 My Inlllal Monthly paym.nts
Each of my Initial monthly payments will be In the amount of U.S. $ 2 4 3 , 1 2 . This amount may change.
(C) Monthly paym.nl Chang..
Changes In my monthly paymenl will r.ll.cl changes In Ih. unpaid principal of my loan and In the Inl.resl rale lhall
must pay. The Note Holder will determine my new Interest rate and the changed amount of my monthly payment In
accordance with SecUons 4 or 5 of thIs Note.
4, ADJUSTABLE INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change 001.0
The adjuslable Interest rate I will pay may change on the first day of J l/ n e. I 9 9 5 , and on that day
every 12th month thereafter. Each date on which my adluslable Interest rate could change Is called a .Change Date..
(B) Th. Ind.x
Beginning wllh the first Change Date, my adjustable Inlerest rate will be based on an Index. The "Index" Is the weekly
average yield on United Stales Treasury securUles adjusted to a constanl matLJrlty of 1 year, as made available by the
Federal Reserve Board. The mosl recent Index figure available as of the date 45 days before each Change Dale Is called
the "Current Index,.
MULTI STATE ADJUSTABLE RATE NOTE..smGlE FAM1LY..FtlMA UNIFORM INSTRUMENT
lSC/CNOT""/D592/350S(01.S9j.L PAGE 1 OF 4
FORM 3508 f/89
I
PLAINTIFF'S
EXHIBIT
11011
)AN NO, "0 09 \ 9
If tho Indox Is no Ion nor lI'IaHHlJlo, 1110 Noto Holder will chooso n now Indox wIllet! Is based upon com para hIe
Information. Tho Nolo Holder wUl U1vo mo notice 01 thIs cholco.
(C) Colculollon 01 Chongeo
Boloro each Chango Onlo, tho Nolo Holdor wl1l calculato my rww InlcroM raiD by mJdlngT", &ml 'nnl!teen I '",cnt Il'th~
perconlago pOlnt(s) ( l.!l 500 %) 10 tho Cllrronllllde.... Tho
Nolo Holdur wllllhon round tho result althls nddlllon 10 tho nomosl ono.olghlh of one rmrconlago poInt (0.125%). SuhJect
to tho limits stillod In Soctlon 4(0) hulow, Ihis rOUl1ded moollnl will bo my now l/llmosl mlo untlllho noxt Chango Dale.
Tho Nolo Holder wlllll1f)fl dotorminu 1110 amount ollho monthly paYlllonllhal would ho sulllclonl to rupay 1t1O unpnJd
princ:lpal1hall am expectod 10 owo nl tho Cllllngll Dale In full on 1110 Mnlurlly Oalo nt my flOW Irllorost ralu In SlIhSlilflllally
oqual paYll1llnls. Tho rosull 0111115 calclllallon will bo tho now nmOU1\1 01 my monthly pLlymonl.
(D) Limit. on Inlere.1 Rolo Chonge.
Tho Inlerost rata I am requlrod to pay nllllo first Chnngo Onto will nol bo grontor than , . 8 1 !I 0 % or loss Ihan
J . 8' so %. Thoreafler, my ndj1l5tuhro Inlerust rate will never be Increased or decreased on any slnglo Chango
Onlo by mora Ihnn 1 OJ 0 porcenlago polnl(s) ( 2. 0 0 0 0 %) from Ihe rote ollnlorost
I havo boon payIng for tho preceding 12 months. My Inlerost mle will novor bo tlranlor Ihan 1 I . I) , 50 %. which Is
called tho "Maxlrmlm Ralo."
(E) Elfecllve Dote of Chonge.
My now Interesl rate will become cffocllve on oach Change Oato. I will pay tho amount of my now monthly payment
beginning on the lIrst monthly payment dale altor the Change Date Ilntilthe amount of my monthly payment chanuos
again,
(F) Nollce of Chonge.
The Note Holder will deliver or mail to me a notice of any changes In my adjustable Interest rille and the amount of my
monlhly payment before Ihe effecllve date of any change. The notice wiJllncluclo Informatlon required by law 10 be given
me and also the title and lelephono number of a person who will answer any question I may have regarding the notice.
5. FIXED INTEREST RATE CONVERSION OPTION
(A) Opllon 10 Convert to Fixed Role '
I have a ConversIon Opllon Ihat I can exercise unless I am In default or this Section 5(A) will not permit me to do so.
The .Conversion Opllon" Is my opllon 10 convert tt18 interest rate I am required 10 pay by this Note from an adjustable rale
with Interest rate IImlls to the fixed rate calculated under Section 5(8) below.
The conversion can only take place on a date(s) specified by the Nole Holder during the perIod beginning on the first
Change Dale and ending on tho fifth Change Date. Each date on which my adjustable Interest rate can convert 10 Ihe new
fixed rate Is called the "Conversion Dale,"
If I want to exercise the Conversion Opllon, I must first meet certain conditions. Those conditions are that: (I) I must
give the Note Holder notlee that I want to do so; (Ii) on the ConversIon Date, I must not be In default under Ihe Nole or the
Security Instrument; (iIi) bye dole specified by the Nota Holder, I must poy the Note Holder 0 conversion fee of
U.S. $2 5 0 . 00 ;and (Iv) J mllst sign and give the Nole Holder any documents the Note Holder requires to
ellect the conversIon.
(8) Colculsllon of Fixed Role
My new, fixed Interest rate will be equal to the Federal NatIonal Mortgage Association's required net yIeld as of a date
ond lime of doy specified by the Note Holder for (II if the orlglnallerm of Ihls NOle is greoterthon 15 yeors, 30.yeor fixed
rate mortgsge. covered by oppllcable 60.doy mandatory delivery commitments, plu. five.elghth. of one percenloge point
(0,625%), rounded to the neorest one.eighth of one percenlage point (0,125%1, or (ii) If Ihe orlglnolterm of thl. Note Is 15
years or less, 1S-year fixed rate mortgages covered by applicable 50.day mandatory delivery commitments, plus
five.eighths of one percentage point (0,625%), rounded 10 Ihe neorest one. eighth 01 one percentoge point (0,125%), IIthl.
required net yIeld cannot be determIned because the applicable commitments are not available. the Note Holder will
determIne my Interest rate by usIng comparable information. My new rate calculated under this Section 5(B) will not be
greater than the Maximum Rale stated In Section 4(0) above.
(C) New poyment Amounlond Effecllve Dote
If I choose to exercise the ConversIon Option, the Note Holder will determIne the amount of the monthly payment that
would be sufficient to repay the unpaid principal I am expected to owe on the ConversIon Date In full on the Maturity Date
at my new fixecllnlerest rate In sUbstantlally equal payments. The result of thIs calculatlon will be Ihe new amounl of my
monthly payment. BegInning with my first monthly payment after the Conversion Date. I will pay the new amounl as my
monthly payment until the Maturity Date.
MULTISTATE ADJUSTABLE RATE IIOTE..SINGLE FAMIlY..FNMA UNIFORM INSTRUMENT
JSC/CNor"/0592/3508(01.89).l PAGE 2 OF 4
FORM3508 1/89
ANNO. 94009 S9
6. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of principal at any time before they are due. A payment of principal only Is known
as a .prepayment." When I make a prepayment. I will tell the Nole Holder in writing that I am doing so.
I may make a full prepayment or partial prepayments without paying any prepaymenl charge, The Note Holder will
use all of my prepayments to reduce the amount of principal that I owe under this Note. III make a partial prepayment,
there will be no changes In the due dates of my monthly payments unless the Note Holder agrees In wriling to lhose
changes. My partial prepayment may reduce the amount of my monthly payments after the first Change Date following my
partial prepayment. However, any reduction due to my partIal prepayment may be offset by an Interest ralo Increase.
7. LOAN CHARGES
If a law, which applies 10 this loan and which sets maximum loan charges. Is finally interpreted so that the Interest or
other loan charges collected or to be collected In connectlon with this loan exceed the permitted limits. then: (I) any such
loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (i1) any sums
already collected from me which exceeded permitted limits will be refunded to me. The Nole Holder may choose 10 make
this refund by reducing the principal I owe under Ihls Note or by making a direct payment to me. If a refund reduces
principal, the reduction wHl be treated as a partial prepayment.
8. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charges for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end 01 I 5 calendar days
alter the date It Is due, I will pay a lale charge to the Nato Holder. The amount of the charge will be I 0 . 0 0 0 fro 01 my
overdue payment of principal and Interest. I will pay this late charge promptly but only once on each late payment
(B) Default
If I do not pay the full amount of each monlhly payment on the date It Is due, I will be In default,
(C) Notice of Default
If I am In default, the Note Holder may send me a written notice telling me that If I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay Immediately the full amount of principal which has not been paId find
all the Interest that I owe on Ihat amount. That dale must be a least 30 days alter the dale on which the nollce Is delivered
or mailed to me,
(D) No Waiver By Note Holder
Even If, at a time when I am In default. the Note Holder does not require me to pay Immediately In full as doscrlbod
above, the Nole Holder will still have the right to do so III am In default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay Immediately In full as described above. Ihe Note Holder will have Ihe right 10
be paid back by me for all of ilS cosls and expenses In enforcing Ihls Nole to the extenl not prohlblled byappllcablelew,
Those expenses include, for example, reasonable attorneys' fees.
9. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note w1l1 be glvon
by delivering It or by mailing it by first class mail to me al the Property Address above or at a different address If I givo tho
Note Holder a notice of my differenl address,
Unless the Note Holder requires a different method. any notice that must be given to the Note Holder under this Noto
will be given by mailing II by first class mall to the Note Holder at Ihe address stated in Section 3(A) above or at n dlfforont
address If I am given a notice of that different address.
10. 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 the promises
.. made In this Note, including the promise to pay the full amount owed. Any person who Is a guarantor, surety or endorser
of Ihls Nole Is aiso obligated to do these things, Any person who takes over these obligations, Including Ihe obligations of
a guaranlor, surety or endorser of this Note, is also obligated to keep all of the promises made In this Note, The Note
Holder may enforce its rights under this Note against each person Individually or against all of us together. This means
that anyone of us may be required to pay all of the amounts owed under this Note.
11. WAIVERS
I and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor.
"Presentment" means the right to require the Note Holder to demand payment of amounts due, "Notice of dishonor"
means the right to require the Note Holder to give notice to olher persons that amounts due have not been paid.
MULTISTATE ADJUSTABLE RATE NOTE-SINGLE FAMILY-FNMA UNIFORM INSTRUMENT
ISC/CNOP-/0592/3508(Ol.89j.L PAGE 3 OF <I
FORM 3508 1{89
to cure the default and prevent the sale at any time up to one
. hour before the Sheriff's foreclosure sale. You may do so by
paying the total amount of the monthly payments plus any late or
other charges then due, as well as the reasonable attorney's fees
and costs connected with the foreclosure sale and perform any
other requirements under the mortgage. It is estimated that the
earliest date that such a Sheriff's sale could be held would be
approximately six months from the date of this letter. A notice
of the date of the Sheriff's sale will be sent to you before the
sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time
exactl~ what the required payment will be by calling us at the
follow~ng number: 1-800-753-7366. This payment must be in cash,
cashier's check, certified check, or money order made payable to
Sovereign Bank at the above address.
You should realize that a Sheriff's sale will end your ownership
of the mortgaged property and your right to remain in it. If you
continue to live in the property after the Sheriff's sale, a
lawsuit could be started to evict you.
You have additional rights to help protect your interest in the
property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN
MONEY TO PAY OFF THE MORTGAGE/DEBT, OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE
THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE
MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE
DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES, AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND
THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED) .
CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT
EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY
THIRD PARTY ACTING ON YOUR BEHALF. YOU HAVE THE RIGHT TO ASSERT
IN THE FORECLOSURE PROCEEDINGS THE NON-EXISTENCE OF A DEFAULT OR
ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION OR FORECLOSURE.
If you cure the default, the mortgage will be restored to the
same position as if no default had occurred. However, you are
not entitled to this right to cure your default more than three
times in any calendar year.
THIS BANK IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.
Constance M. Cocroft
Vice President
, .
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Date of Notice: 05/05/98
Loan #0176132635
To: ROGER L KUMLER JR
242 SUSQUEHANNA AVE
ENOLA
PA 17025
The MORTGAGE held by Sovereign Bank (hereinafter we, us, or ours)
on your property located at 242 SUSQUEHANNA AVE
ENOLA PA 17025
IS IN SERIOUS DEFAULT because you have not made the monthly
payment of $ 407.45 since 03/01/98 to the present. The
total amount now required to cure this default, or in other
words, get caught up in your payments, as of the date of this
letter, is $1287.93 . The total amount includes late
charges and any other charges:that have accrued to this date. If
you disagree with the assertion that a default has occurred or
the correctness of the calculated amount required to cure the
default, contact:
SOVEREIGN BANK
CREDIT COUNSELING DEPARTMENT
PO BOX 876
SHILLINGTON PA 19607
1-800-753-7366 OR 610-208-6197
You may cure this default within THIRTY (30) DAYS of the date of
this letter by paying to us the above amount of $1287.93
plus any additional monthly payments and late charges which may
fall due during this period. Such payment must be made either by
cash, cashier's check, or money order made payable to Sovereign
Bank at the above address.
If you do not cure the default within THIRTY (30) DAYS, we intend
to exercise our right to accelerate the mortgage payments. This
means that whatever is owing on the original amount borrowed will
be considered due immediately and you may lose the chance to pay
off the original mortgage in monthly installments. If full
payment of the amount of default is not made within THIRTY (30)
DAYS, we also intend to instruct our attorneys to start a lawsuit
to foreclose your mortgaged property. If the mortgage is
foreclosed, your mortgaged property will be sold by the Sheriff
to payoff the mortgage debt. If we refer your case to our
attorneys, but you cure the default before they begin legal
proceeding against you, you will still have to pay the
reasonable attorney's fees actually incurred, up to $50.00,
However, if legal proceedings are started against you, you will
still have to pay the reasonable attorney's fees even if they are
over $50.00. Any attorney's fees will be added to whatever you
owe us, which may also include our reasonable costs. If you cure
the ?efault within the thirty day period, you will not be
requlred to pay attorney's fees.
We may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
If you have not cured
and foreclosure proce
EXHIBIT
in the thirty day period
, you still have the right
I
liEU
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Date of Notice: 05/05/98
Loan #0176132635
To: TAMMY L KUMLER
242 SUSQUEHANNA AVE
ENOLA
PA 17025
The MORTGAGE held by Sovereign Bank (hereinafter we, us, or ours)
on your property located at 242 SUSQUEHANNA AVE
ENOLA PA 17025
IS IN SERIOUS DEFAULT because you have not made the monthly
payment of $ 407.45 since 03/01/98 to the present. The
total amount now required to cure this default, or in other
words, get caught up in your payments, as of the date of this
letter, is $1287.93 . :The total amount includes late
charges and any other charges that have accrued to this date. If
you disagree with the assertion that a default has occurred or
the correctness of the calculated amount required to cure the
default, contact:
SOVEREIGN BANK
CREDIT COUNSELING DEPARTMENT
PO BOX 876
SHILLINGTON PA 19607
1-800-753-7366 OR 610-208-6197
You may cure this default within THIRTY (30) DAYS of the date of
this letter by paying to us the above amount of $1287.93
plus any additional monthly payments and late charges which may
fall due during this period. Such payment must be made either by
cash, cashier's check, or money order made payable to Sovereign
Bank at the above address.
If you do not cure the default within THIRTY (30) DAYS, we intend
to exercise our right to accelerate the mortgage payments. This
means that whatever is owing on the original amount borrowed will
be considered due immediately and you may lose the chance to pay
off the original mortgage in monthly installments. If full
payment of the amount of default is not made within THIRTY (30)
DAYS, we also intend to instruct our attorneys to start a lawsuit
to foreclose your mortgaged property. If the mortgage is
foreclosed, your mortgaged property will be sold by the Sheriff
to payoff the mortgage debt. If we refer your case to our
attorneys, but you cure the default before they begin legal
proceeding against you, you will still have to pay the
reasonable attorney's fees actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will
still have to pay the reasonable attorney's fees even if they are
over $50.00. Any attorney's fees will be added to whatever you
owe us, which ma~ also include our reasonable costs. If you cure
the default with~n the thirty day period, you will not be
required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
If you have not cured the default within the thirty day period
and foreclosure proceedings have begun, you still have the right
. ',.-::'.
..........
..'.--.-.....
to cure the default and prevent the sale at any time up to one
hour before the Sheriff's foreclosure sale. You may do so by
paying the total amount of the monthly payments plus any late or
other charges then due, as well as the reasonable attorney's fees
and costs connected with the foreclosure sale and perform any
other requirements under the mortgage. It is estimated that the
earliest date that such a Sheriff's sale could be held would be
approximately six months from the date of this letter. A notice
of the date of the Sheriff's sale will be sent to you before the
sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time
exactl~ what the required payment will be by calling us at the
follow~ng number: 1-800-753-7366. This payment must be in cash,
cashier's check, certified check, or money order made payable to
Sovereign Bank at the above address.
You should realize that a Sheriff's sale will end your ownership
of the mortgaged property and your right to remain in it. If you
continue to live in the property after the Sheriff's sale, a
lawsuit could be started to evict you.
You have additional rights to help protect your interest in the
property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN
MONEY TO PAY OFF THE MORTGAGE{DEBT, OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE
THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE
MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE
DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES, AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND
THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED).
CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT
EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY
THIRD PARTY ACTING ON YOUR BEHALF. YOU HAVE THE RIGHT TO ASSERT
IN THE FORECLOSURE PROCEEDINGS THE NON-EXISTENCE OF A DEFAULT OR
ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION OR FORECLOSURE.
Constance M. Cocroft
Vice President
If you cure the default, the mortgage will be restored to the
same position as if no default had occurred. However, you are
not entitled to this right to cure your default more than three
times in any calendar year.
THIS BANK IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM. PLEASE READ THIS NOTICE: YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
Date: 05/05/98
Loan #0176132635
To: ROGER L KUMLER JR
242 SUSQUEHANNA AVE
ENOLA
PA 17025
You may be eligible for financial assistance that will prevent
foreclosure on your mortgage if you comply with the provisions of
the Homeowners' Emergency Mortgage Assistance Act of 1983 (the
"Act"). You may be eligible for emergency assistance if your
default has been caused by circumstances beyond your control, you
have a reasonable prosl?ect of/resuming your mortgage payments,
and if you meet the el~gibility requirements of the Act as
determined by the Pennsylvania Housing Finance Agency. Please
read all of this Notice. It contains an explanation of your
rights.
Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for THIRTY (30) DAYS from the date
of this Notice. During that time you must arrange and attend a
"face-to-face" meeting with a representative of this lender, or
with a designated consumer credit counseling agency. The purpose
of this meeting is to attempt to work out a repayment plan, or to
otherwise settle your delinquency. This meeting must occur in
the next THIRTY (30) DAYS.
If you attend a face-to-face meeting with this lender, or with a
consumer credit counseling agency from the enclosure, no further
proceedings in mortgage foreclosure may take place for thirty
(30) days after the date of this meeting.
The name, address, and telephone number of our representative is:
SOVEREIGN BANK, CREDIT COUNSELING DEPARTMENT
PO BOX 876
SHILLINGTON PA 19607
1-800-753-7366 or 610-208-6197
The names and addresses of designated consumer credit counseling
agencies are shown on the enclosed sheet. Please contact the
agency nearest to you. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately
of your intentions.
Your mortgage is in serious default because you have failed to
pay promptly installments of principal and interest, as required,
for a period of at least sixty (60) days. The total amount of
the delinquency is $1287.93 . That sum includes all
principal, interest, escrow (if applicable), late charges, and
any other charges from the month of 03/01/98 to the present.
If you have tried and a
after your face-to-fac
financial assistance f
EXHIBIT
solve this problem at or
ve the right to apply for
s' Emergency Mortgage
I
IIFll
Assistance Fund. In order to do ehis, you must fill out, sign,
and file a completed Homeowners' Emergency Assistance Application
with one of the designated consumer credit counseling agencies
from the enclosure. An application for assistance may only be
obtained from a consumer credit counselin~ agenc~. The consumer
credit counseling agency will assist you ~n fill~ng out your
application and will submit your completed application to the
Pennsylvania Housing Finance Agency. Your application must be
filed or postmarked within thirty (30) days of your face-to-face
meeting.
It is extremely important that you file your application
promptly. If you do not do so, or if you do not follow the other
time periods set forth in this letter, foreclosure may proceed
against your home immediately.
Available funds for emer~ency mort age assistance are very
limited. They will be d~sbursed by the Agency under the
eligibility criteria established by the Act.
It is extremely important that your application is accurate and
complete in every respect. The Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives
your ap~lication. During that additional time, no foreclosure
proceed~ngs will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by
that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at:
2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105.
Telephone number (717) 780-3800 or 1-800-342-2397 (toll free
number). Persons with impaired hearing can call (717) 780-1869
or 1-800-342-2397.
In addition, you may receive another notice from this lender
under Act 6 of 1974. This notice is called a "Notice of
Intention to Foreclose". You must read both notices since both
explain rights that you now have under Pennsylvania law.
However, if you choose to exercise your rights described in this
notice, you cannot be foreclosed upon while you are receiving
that assistance..
THIS BANK IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.
Constance M. Cocroft
Vice President
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM. PLEASE READ THIS NOTICE: YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
To: TAMMY L KUMLER
242 SUSQUEHANNA AVE
ENOLA
Date: 05/05/98
Loan #0176132635
PA 17025
You may be eligible for financial assistance that will prevent
foreclosure on your mortgage if you comply with the provisions of
the Homeowners' Emergency Mortgage Assistance Act of 1983 (the
"Act"). You may be eligible for emergency assistance if your
default has been caused by circumstances beyond your control, you
have a reasonable pros~ect of'resuming your mortgage payments,
and if you meet the e1~gibility requirements of the Act as
determined by the Pennsylvania Housing Finance Agency. Please
read all of this Notice. It contains an explanation of your
rights.
Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for THIRTY (30) DAYS from the date
of this Notice. During that time you must arrange and attend a
"face-to-face" meeting with a representative of this lender, or
with a designated consumer credit counseling agency. The purpose
of this meeting is to attempt to work out a repayment plan, or to
otherwise settle your delinquency. This meeting must OCcur in
the next THIRTY (30) DAYS.
If you attend a face-to-face meeting with this lender, or with a
consumer credit counseling agency from the enclosure, no further
proceedings in mortgage foreclosure may take place for thirty
(30) days after the date of this meeting.
The name, address, and telephone number of our representative is:
SOVEREIGN BANK, CREDIT COUNSELING DEPARTMENT
PO BOX 876
SHILLINGTON PA 19607
1-800-753-7366 or 610-208-6197
The names and addresses of designated consumer credit counseling
agencies are shown on the enclosed sheet. Please contact the
agency nearest to you. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately
of your intentions.
Your mortgage is in serious default because you have failed to
pay promptly installments of principal and interest, as required,
for a period of at least sixty (60) days. The total amount of
the delinquency is $1287.93 . That sum includes all
principal, interest, escrow (if applicable), late charges, and
any other charges from the month of 03/01/98 to the present.
If you have tried and are unable to resolve this problem at or
after your face-to-face meeting, you have the right to apply for
financial assistance from the Homeowners' Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign,
and file a completed Homeowners' Emergency Assistance Application
with one of the designated consumer credit counseling agencies
from the enclosure. An application for assistance may only be
obtained from a consumer credit counselin$ agenc~. The consumer
credit counseling agency will assist you ~n fill~ng out your
application and will submit your completed application to the
Pennsylvania Housing Finance Agency. Your appl.ication must be
filed or postmarked within thirty (30) days of your face-to-face
meeting.
It is extremely important that you file your application
promptly. If you do not do so, or if you do not follow the other
time periods set forth in this letter, foreclosure may proceed
against your home immediately.
Available funds for emergency mort age assistance are very
limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act.
It is extremely important that your application is accurate and
complete in every respect. The Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives
your ap~lication. During that additional time, no foreclosure
proceed~ngs will be pursued against ~ou if you have met the time
requirements set forth above. You w~ll be notified directly by
that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at:
2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105.
Telephone number (717) 780-3800 or 1-800-342-2397 (toll free
number). Persons with impaired hearing can call (717) 780-1869
or 1-800-342-2397.
In addition, you may receive another notice from this lender
under Act 6 of 1974. This notice is called a "Notice of
Intention to Foreclose". You must read both notices since both
explain rights that you now have under Pennsylvania law.
However, if you choose to exercise your rights described in this
notice, you cannot be foreclosed upon while you are receiving
that assistance.
THIS BANK IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.
Constance M. Cocroft
Vice President
CONSUMER CREDIT COUNSELING AGEt':ClES FOR PENNSYLVANIA
BUDGET COUNSELING CENTER
247 NORTH 5TH STREET
READING PA 19601
(610) 375-7866
TABOR COMMUNITY SERVICES INC
439 EAST KING STREET
LANCASTER PA 17602
(717) 397-5182 or 1-800-788-5062
CONSUMER CREDlT COUNSELING SERVICE OF
LEHIGH VALLEY
3671 CRESCENT COURT
EAST WHITEHALL PA 18052
(610) 821-4011 or 1-800-220-2733
(717) & (814) ONLY
AM CREDlT COUNSELING L'ISTITUTE
144 EAST DEKALB PIKE SUITE 100
KING OF PRUSSIA PA 19406
(610) 354-9922 CONSUMER CREDIT
COMMUl'iITY ACTION DEVELOPMENT
COMMISSION
113 EAST MAIN STREET
NORRlSTOWN PA 19401
(610) 277-6363
MEDIA FELLOWSIDP HOUSE
302 SOUTH JACKSON STREET
MEDIA PA 19063
(610) 545-0846
LA CASA DEL PUEBLO
815 WEST BALTIMORE PIKE
KENNETT SQUARE PA 19348
(610) 444-3731
CONSUMER CREDIT COUNSELING SERVICE OF
DELAWARE VALLEY
1211 CHESTNUT STREET SUITE 400
PHILADELPHIA PA 19107
(215) 563-5665
ACORN HOUSING CORPORUION
846 NORTH BROAD STREET
PHILADELPHIAPA 19130
(215) 765-1211
BUCKS COUNTY HOUSING GROUP INC
140 E RICHARDSON A VENUE
LANGHORNE PA 19047
(215) 750-4310
mSPANlC ASSOCIATION OF CONTRACTORS
AND ENTERPRISES
2921-27 NORTH 5TH STREET
PHILADELPHIA PA 19133
(215) 426-8027
CONSUMER CREDlT COUNSELL'IG SERVICE OF
NORTHEASTERN PENNSYL V ANlA
HUMAN SERVICES BUILDING
541 WYOMING AVENUE BOX 168
.' SCRANTONPA 18501
(717) 342-1072 or 1-800-922-9537
HOUSING COUNCIL OF YORK
116 NORTH GEORGE STREET
YORKPA 17401
(717) 854-1541
CONSUMER CREDIT COUNSELING SERVICE OF
NORTHEASTERNPENNSYLV~'~
31 WEST MARKET STREET
WILKES-BARRE PA 18702
(717) 821-0837 or 1-800-922-9537
ECONOl\;I1C OPPORTUNlTY OF LUZERNE COUNTY
211-213 SOUTH MAIN STREET
WILKES-BARRE PA 18701
(717) 826-0510 or 1-800-822-0359
L YCOMlNG-CLINTON COUNTIES COMl\;I1SSION
FOR COMl'<[UNlTY ACTION
2138 LINCOLN STREET
WILLlAMSPORT PA 17703
(717) 326-0587
ECONOl\;I1C OPPORTUNITY CABL'lET OF
SCHUYLKILL COUNTY
118 NORWEIGIAN STREET
POTTSVILLE PA 17901
(717) 622-1995
URB~'i LEAGUE OF METROPOLITAN
HARRISBURG INC
25 NORTH FRONT STREET
HARRlSBURGPA 17101
(717) 234-5925
AMEIUCA RED CROSS. HAJ"IOVER CHAPTER
529 CARLISLE STREET
HANOVERPA 17331
(7\7) 637.3768
CONSUMER CREDIT COUNSELING SERVICE OF
WESTERN PENNSYLVANIA INC
2000 LINGLESTOWN ROAD
HARRlSBURGPA 17102
(717) 541.1757
CONSUMER CREDIT COUNSELING SERVICE OF
WESTERN PENNSYLVANIA INC
YMCA
339 NORTH WASHINGTON STREET
BUTLER PA 16001
(412) 282-7812
HOUSING OPPORTUNITIES OF BEAVER
COUNTY INC
334 INSURANCE STREET
BEAVERPA 15009
(412) 728.7511
ACTION HOUSING INC
NUMBER TWO GATEWAY CENTER
9TIi FLOOR
PITTSBURGH PA 15222
(4\2) 391.1956
INDIANA COUNTY COMl'vfUNITY ACTION
PROGRA1\1
827 WATER STREET BOX 187
INDIANA PA 15701
(412) 456.2657
MONN ALLEY UNEMPLOYED COMl'vOTTEE
120 EAST 9TH AVENUE
HOMESTEAD PA 15120
(412) 462.9962
CONSUMER CREDIT COUNSELING SERVICE OF
WESTERN PENNSYLVANIA INC
500-02 3RD AVENUE
PO BOX 278
DUNCANSVILLE PA 16635
(814) 696.3546
JOHN F h."ENNEDY CENTER INC
202 \ EAST 2011-1 STREET
ERIEPA 16510
(814) 898.0400
NORTHERN TIER COMMUNITY ACTION COR1'
135 WEST FOURTH STREET
EMPORIUM PA 15834
(814) 486.1161
WARREN-FORREST COUNTIES ECONOMIC
OPPORTUl'<"lTY COUNCIL
204 LIBERTY STREET
PO BOX 547
WARRENPA 16365
(814) 726-2400
BEDFORD-FULTON HOUSING SERVICES
RD #1 BOX 384
EVERETTE PA 15537
(814) 623.9129
TALBELAJ~SERVICES INC
131 NORTH CENTER AVENUE
SOMERSETPA 15501
(814) 445.9628
KEYSTONE ECONOMIC DEVELOPMENT
CORPORATION
1954 MARY GRACE LANE
JOHNSTOWNPA 15901
(814) 535-6556
GREATER ERIE COMMUNITY ACTION
COMl\1lTTEE
18 WEST 9TH STREET
ERIE PA 16501
(814) 459-4581
BLAIR COUNTY ECONOMIC OPPORTUNITY
COUNCIL
5433 INDUSTRIAL AVENUE
ALTOONAPA 16601
(814) 946-3651
CONSUMER CREDIT COUNSELING SERVICE OF
WESTERN PENNSYL V A.l'lIA INC
1ST FEDERAL PLAZA SUITE 406
NORTH MILL STREET
NEW CASTLE PA 16101
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IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL IlIVISION - LAW
SOVEREIGN BANK, F.S,B. as assignee of
Aflinity National Mortgage.
)
)
)
)
)
)
)
)
)
MORTGAGE FORECLOSURE
PlaintilT
NO. 98-3561-Civil
vs.
ROGER L. KUMLER JR. and TAMMY L.
KUMLER, Husband and Wife.
Defendants
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in Mortgage Foreclosure in the above-captioned matter.
PIOSA HIXSON & REILLY, P.C.
Date:
~;/I'O At
/
By: V\.V;\
Thomas E. Reilly, Jr., Es
Attorney for Plaintiff
Attorney I. D. No. 41668
One Windsor Plaza, Suite 101
7535 Windsor Drive
Allentown, PA 18195-1014
(610) 530-7500
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1n 1l1tllourr Ollollllllon IJIc:JS OllumberJ:Jl1d lounry, renl1syl\':J111:J
Sovereighn Bank, et. al.
VS.
Roger L. Kumler. Jr.. et. al.
Serve: Roger L. Kumler, Jr.
;-io. 98-3561 Civil
19_
;-iOIY, 8114/98
Pern'
19_, I SHERIFF OF CDlBERL.'\';'Il) COU;-iTY, PA do hereh:' deputize the Sheriff of
Couory to execute this Writ, this deputatioo beiog made at the request aud risk of the Plaintiff.
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SheriffofCumberlnnd Count)', Pn.
Affid:J.vir of Service
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nttested copy of the origioal I!..,",{,.I ....
/':~ the cootents thereof.
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So :Jnswers!
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Sheriff of '?r:.'.'l
County. Pa,
COSTS
SER VICE
:IIILEAGE
AHIDA \'IT
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NOW,
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, 19911, ,JUDGMENT IS ENTERED AS AIlOVE.
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Prothonotary/Clcrk, Civil Division
By Ci)-",,:J ;JI'MU-^ff
Deputy (J
IN THE COURT OF COMMON PLEAS OF CUMIlERLANIl COUNTY, PENNSYLVANIA
CIVIL DIVISION - LA W
SOVEREIGN BANK. F.S,ll as assignee of
Affinity National Mortgage,
)
)
)
)
)
)
)
)
:1
Plai nti rr
NO. 98-3561-CrVIL
vs.
ROGER L. KUMLER JR. and TAMMY L.
KUMLER, Husband and Wife,
Defendants
MORTGAGE FORECLOSURE
( X )
Notice is hereby given that a Default Judgment in the above-captioned matter has
been entered against you in the amount o~$42,823.59 plus interest from ,.
September 22, 1998 and costs, on ,Utll L. ,,) if , 19 C;f
/ I ( ----j-fJ-
( X )
A copy of all documents filed with the Prothonotary in support of the within
judgment are enclosed.
(1/ Vt:'(-<.A-) K rj;",--~)
Protnonotary/Clerk, Civil Div. (j
by ~M-l r:LJ1l~L"7i
~r7J (j
If you have any questions regarding this Notice, please contact the filing party:
Thomas E. Reilly, Jr. Esquire
One Windsor Plaza, Suite 101
7535 Windsor Drive
Allentown, PA 18195-1014
(610) 530-7500
(This Notice is given in accordance with Pa,R,C.P. 236).
CERTIFICATION OF ADDRF.SSF.S
!, THOMAS E. REILLY. JR., ESQUIRE, hereby certify that the precise address of the within-named
Plaintiff, Sovereign Bank, is 525 Lancaster Avenue, Reading, PA 19611 and the precise address of the within-
named Defendants, Roger L. Kumler Jr. is RD #4, Box 4753. Duncannon, PA 17020 and Tammy L. Kumler is
4 Dullcs Drive, 3G, Camp Hill, PA 17011.
Thomas E. Reilly, Jr., Esquir
LAW Of"f"ICES
PIOSA HIXSON B: REILLY P,C.
ONE WINOSO~ PLAZA, SUITE 101
7535 WIN050~ DRIVE
ALLENTOWN, PA 18195-1014
(610) 530,7500
:1
,I
:1
ill IN TilE COURT OF COMMON PLEAS OF CUMHEI{LANU COUNTY,PENNSYLVANIA
CIVIL (lIVISION - LAW
1
I
,
I SOVEREIGN BANK, F.S.B. as assignee of
il
II Affinity National Mortgage,
rl
11
II
vs.
)
)
)
)
)
)
)
)
PlaintilT
NO. 9S-3561-CIVIL
ROGER L. KUMLER JR. and TAMMY L.
KUMLER, Husband and Wile,
Defendants
MORTGAGE FORECLOSURE
AFFII)AVIT PURSUANT TO RULE 3129,1
Thomas E. Reilly, Jr., Esquire, attorney for Plaintiff in the above action, sets forth, as of
the date the Praecipe for Writ of Execution was tiled, the following information concerning the
real property located at 242 Susquchana Avenue, Enola, Cumberland County, Pennsylvania and
more particularly described in Exhibit "A" attached hereto:
I. The names and last known address uf the Owners or Reputed Owners of the
Property are: Roger L. Kumler Jr., RD #4, Box 4753, Duncannon, Pennsylvania 17020 and
Tammy L. Kumler, 4 Dulles Drive, 3G, Camp Hill, Pennsylvania 17011.
2. The names and last known address of the Defendants in the judgment are: Roger
L. Kumler Jr., RD #4, Box 4753, Duncannon, Pennsylvania 17020 and Tammy L. Kumler, 4
Dulles Drive, 3G, Camp Hill, Pennsylvania 1701t.
3. The name and last known address of every judgment creditor whose judgment is
a record lien on the real property to be sold is:
a) Sovereign Bank, F.S.B., assignee of Affinity National Mortgage, 525
Lancaster Avenue, Reading, Pennsylvania 19611; $42,823.59; dated 09/23/98; No. 98-3561-
Civil, Cumberland County records.
4. The names and last known addresses of the last recorded holders of every
mortgage of record are:
a) Sovereign Bank, F.S.B" assignee of Affinity National Mortgage, 525
Lancaster Avenue, Reading, Berks County, Pennsylvania] 9611; $41,100.00; recorded
08/05/94; Mortgage Book Volume 1227, Page 150.
b) PNC Bank; 2730 Liberty Avenue, Pittsburgh, Pennsylvania 15222;
$9,010,00; recorded 09/15/95; Mortgage Book Volume 1282, Page 43.
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Sovereign Bank F.S.B. as Assignee
of Affinity National Mortgage
-vs-
Roger L. Kumler, Jr. and
Tammy L. Kumler
[n the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 98-3561 Civil Term
Wesley Cook, Deputy Shcrin~ who being duly sworn according to law, says on January 19,
1999 at 7:33 o'clock P.M. E. S. T., he posted a eopy of Real estate Writ Notice Poster and
Description in the above entitled action upon the property of Roger L. Kumler, Jr. and Tammy L.
Kumler located at 242 Susquehanna Avenue, Enola Cumberland County, Pennsylvania according
to law.
Wesley Cook, Deputy Sheriff, who being duly sworn according to law says on November 16,
1998 at 6: 19 o'clock P.M. E. S. T., he served a true copy of real Estate Writ Notice and
Description in the above entitled action upon one of the within named defendants to wit: Tammy
L. Kumler by making known unto Tammy L. Kumler at 4 Dulles Drive, Camp Hill, Cumberland
County, Pennsylvania, its contents and at the same time handing to her personally the said true
and attested copies of the same.
Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on
November 30, 1998 at 6: 19 o'clock P.M. E. S. T., he served a true copy of Real Estate Writ
Notice and Description, in the above entitled action upon one of the within named defendants to
wit: Roger L. Kumler, Jr. by making known unto Roger L. Kumler, Jr. at 225 Bella Vista Drive,
Marysvillc, Cumberland County, Pennsylvania, its contents and at the same time handing to him
personally the said true and attested copies of the same.
David McKinney, Deputy Sheriff who being duly sworn according to law, says on January
19, 1999 at 4:45 o'clock P.M. E. S. T., he posted a copy of real Estate Poster, in the above
entitled action upon one of the within named defendants to wit: Tammy L. Kumler by making
known unto Tammy L. Kumler at 4 Dulles Drive, Camp Hill, Cumberland County,
Pennsylvania, its contents and at the same time handing to her personally the said true and
attested copy of the same.
Wesley Cook, Deputy Sheriff, who being duly sworn according to law, says on January 19,
199 at 6:10 o'clock P.M. E. S. T.,he served as copy of Real Estate Poster, in the above entitled
action upon one of the within named defendants to wit: Roger L. Kumler, Jr., by handing to
Roger 1. 'Kumler, Jr. at 225 Bella Vista Drive, Marysville, 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 within
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 named defendants to wit: Roger 1.
Kumler, Jr., by regular mail to his last known address 225 Bella Vista Drive, Marysville,
Pennsylvania. This letter was mailed under the date of January 20, 1999 and never returned to tile
Sheriffs Office.
R. Thomas Kline, Sherin~ 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 of the pendency of the aetion to one of the within named defendants to wit: Tammy 1.
KUMLER, by regular mail to her last known address 4 Dulles Drive, Camp Hill, Pennsylvania,
YOU SIIOULD TAKE TillS PAPER TO YOUR I.A WYER AT ONCE. IF YOU DO NOT
HA VE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPIIONE THE OFFICE
LISTED BELOW TO FIND OUT WI [ERE YOU CAN GET LEGAL IIELI'.
couln ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, 4TIl FLOOR
CARLlSLE,I'A 17013
(717)240-6200
P[OSA H[XSON & REILLY, P.C.
Dated: ncT1>Bfl 10 IQ'l8
.
By: rt2-c
Thomas E. Reilly, Jr., Esqui e
Attorney for Plaintiff
1. D. No. 4\668
One Windsor Plaza, Suite 101
7535 Windsor Drive
Allentown, PA 18195-1014
...',
IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL I>IVISION. LA W
SOVERE[GN BANK, F.S.B. as assignee of
Affinity National Mortgage,
)
)
)
)
)
)
)
)
MORTGAGE FORECLOSURE
PlaintilT
NO. 98-3561-CIVIL
vs.
ROGER L. KUMLER JR. and TAMMY L.
KUMLER, Husband and Wile,
Defendants
AFFmA VIT PURSUANT TO RULE 3129.1
Thomas E. Reilly, Jr., Esquire, attorney for Plaintiff in the above action, sets forth, as of
the date the Praecipe for Writ of Execution was filed, the following information concerning the
real property located at 242 Susquchana Avenue, Enola, Cumberland County, Pennsylvania and
more particularly described in Exhibit "A" attached hereto:
1. The names and last known address of the Owners or Reputed Owners of the
Property are: Roger L. Kumler Jr., RD #4, Box 4753, Duncannon, Pennsylvania 17020 and
Tammy L. Kumler, 4 Dulles Drive, 3G, Camp Hill, Pennsylvania 17011.
2. The names and last known address of the Defendants in the judgment are: Roger
L. Kumler Jr., RD #4, Box 4753, Duncannon, Pennsylvania 17020 and Tammy L. Kumler, 4
Dulles Drive, 30, Camp Hill, Pennsylvania 17011.
3. The name and last known address of every judgment creditor whose judgment is
a record lien on the real property to be sold is:
a) Sovereign Bank, F.S.B., assignee of Affinity National Mortgage, 525
Lancaster Avenue, Reading, Pennsylvania 19611; $42,823.59; dated 09/23/98; No. 98-3561-
Civil, Cumberland County records.
4. The names and last known addresses of the last recorded holders of every
mortgage of record are:
L.,I,WOFF'ICES
-\ HIXSON 8: REILLY P,C.
'vINDSCR PLAZA, SUITE 101
7535 WINDSOR DRIVE
~NTOWN, PA 18195'1014
16101530.7500
a) Sovereign Bank, F.S.B., assignee of Affinity National Mortgage, 525
Lancaster Avenue, Reading, Berks County, Pennsylvania 19611; $41,100.00; recorded
08/05/94; MOligage Book Volume 1227, Page 150.
b) PNC Bank; 2730 Liberty Avenue, Pittsburgh, Pennsylvania 15222;
$9,010.00; recorded 09/15/95; Mortgage Book Volume 1282, Page 43.
....1
,
5. There are no other known persons who have any record lien on the properly.
6. There are no other persons who have a record interest in the property and whose
interest may be affected by the sale.
,
1
7. There arc no other persons who has any interest in the property which may be
affcctcd by the sale.
I verify that the statements made in this Affidavit arc true and correct to the best of my
personal knowledge, information and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
PIOSA, HIXSON & REILLY, P.c.
Date: OC"i08E'l,D11'lq,l\
By: rfLL-..
Thomas E. Reilly, Jr., Esquire
Attorney for Plaintiff
Attorney 1. D. No. 41668
One Windsor Plaza, Suite 101
7535 Windsor Drive
Allentown, PA 18195-1014
, .
WRIT OF EXECUTION and/o~ ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
98-3561 CIVIL 19
CIVIL ACTION. LAW
NO,
TO THE SHERIFF OF CUMBERLAND
COUNTY:
Tosalislythedobl,lntorestandcostsdue Sovereign Bank, F.S.B. as assignee of
Affinity National Mortgage
from Roger L. Kumler, Jr., RD ff4, Box 4573, Duncannon PA
L. Kumler, 4 Dulles Dr., 3G, Camp Hill PA 17011.
PLAINTIFF(S)
17020 and Tammy
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located
at 242 Susquehanna Ave., Enola PA 17025. (See attached legal description)
(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) If 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,
$42,823.59
L.L.
$.50
$1.00
Amount Due
Interest 9/22/98 to Sale @ $8.92/day $1,445.04
Due Prothy
'lher Costs
Atty's Co.....,
Atty Paid
Plaintiff Paid
$152.32
Date:
November 5,1998
CURTIS R. LONG
by:
Deputy
REQUESTING PARTY:
N Thomas E. Reilly, Jr., Esq.
ame
Address:One Windsor Plaza, Ste 101, 7535 Windsor Dr.,
Allentown PA 18195-1014
Plaintiff
Attorney for:
Telephone:
Supreme Court ID No.
(610) 530-7500
41668
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On d/ ~ !(J/,99 Y the sherIff levied upon the defern:Wlls
mlefeslln the real property situated in E~ ~ ~~
Cumborland County I Pa" known and numberoo as: jJlJ ~jW..e..<,.
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f~ _. and mora fully described on Exhibit "A" Wad Wi~l ~
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Ret No. 587. Rooroued May 1!.J.W
Commonwealth of PennsylvanIa, County of Dauphin) aa
MIchael Morrow being duly sworn according to law, deposes and says:
That ha 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 10 818 Markel Street, In
Ihe City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of 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 aforesaid; 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 secureiy altached 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 dayes) of February 1999. That neither he nor said Company is interested In the subject matter of said
printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and Is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockhoiders and board of directors of the said Company and subsequently duly recorded In
the office for the Recording of Deeds in and for said County of D~, a phin.in Miscellaneous Book "M",
Volume 14, Page 317. (tl !:tOJ-
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PUBLICATION / {....... .6 zt72'l ,~
. COpy Sworn to 'an su scnb'r,~tn~mif~['?' meIm h day-,of~~~a'1'~~:k.6.
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-'-REALESrArE'SALE No. 7 My Co"miSoio,'*-'xpirc" Jut'" 6. 2002 '.. J / -
Writ No. 98-356JClvIITerm
, ""SoverelgnBank;F,S.B,
'as Assignee of Affinity
, , ' National Mortgage
"..vs.. ,,'
:':Roger L Kumleri'Jr, and
'i,:, iammyL,Kumler
..: ':i'i\tIy: ThomClsE., Reilly, Jr,
.. ,,",.;.. 'DESCRIPTION..
";..(ALL THAT CERTAIN lot or porcel of
,Iand",sltuate In Enolo. East Pennsboro
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'.,SY..lvanla. .boundSd..on. d,descrlbsd as
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,,:'. BEGINNING ab point In the North.
,'erly line of Susquer nna Avenue ot the
dlstonce of 161. 19. feet' measured
,Nqrthwestwardly along scld Susque-
hanna Avenue' from the Northwest-I' Total
wardly extremity of the arc or curve
,having a rodlus of ten (10) feet con-
~:~gJ~ t~~rt~~I~ IJ~': g/ d~s~~~~ It' sher I s Receipt for Advertising Cost
'hanna Avenue, extending THENCE In aYE
general Northwestwordly direction her of THE PATRIOT.NEWS and THE SUNDA PATRIOT-N WS, newspapers of general
'l~?!'.!Uh~..~9l~ 1!!.'.~~~ ,E~s~.;~9,'),n~ ,receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
Mumo"r, P'"Il'ylvorHa ft.ssoCJ'lJlpn QI No.''''''''' . J 6 20 2
My commiSSion expires une, 0
CUMBERLAND COUNTY SHERiFFS OFRCE
COURT HOUSE
CARLISLE, PA. 17013
Statement of Advertisina Costll
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Probating same Notary Fee(s)
$
$
$
398.25
1.50
399.75
By..................................................,.................
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
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Proof of Publication
UnderAct Ho,S81, Aoomued MaV 16.1929
Commonwealth 01 Pennaylvanla, County of Dauphin} 88
MIchael Morrow bei.ng duly sworn according to law, deposes and soys:
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 City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and
THE SUNDAY PATRIOT.NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street,
In tho City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT.NEWS were established
March 4th, 1854, and Septomber 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 publlehed 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(e) of February 1999, That neither he nor said Company Is Interested in the subject matter of said
printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and Is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of t~hid Company and subsequently duly recorded In
the office for the Recording of Deeds In and for said County of Dau i in Mis elianeous Book "M",
Volume 14, Page 317.
PUBLICATION ~/
COpy
S ALE #18
Sworn to and subscribed before me this 1 Olh da~ Febr
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NOIAnal Se<1! i ' '<
Tcmy L. Russell, Notnr/Pub!:c NOTA
Harfl5bllrg, Oaurhin CO+frlty
My Commission bp:rc$ June 6. 2002
com ission expires June 6, 2002
r~18Il1bcr, PonnsYNanii\ P.~;;:Jci"lion ,Notaries
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,'..at. e"ln..the".Boro. UQh:Ot., NeWVllle.>cU.."",. "
f berlo ndFCounly ;;": Pennsylyanla, ~
:,boundEld and,cescrlbEld os.foIIoWS: >>;<
1,,,t1BE~INNING ata.'polnloJ'lBIQ SOOng
>,\Avenue;';;:formetly ,; DePOt ",or.. RallroOc
fStreel;;thence.bysald,StreetNorth:17:V<',
idegt~EosI@.f8E!I,lo,a:polnt:ttj9nc'e'; . .
';by."lo!"Numbilr,!B:of..!,an::unrecorcled'iaher' a Receipt for Advert~ a ~ng Coat
':',Plohi',lmorovedW~h.adwelllnQ known, '
",' THE PATRIOT-NEWS CO., publisher of THE PATRIOT,NEWS and THE SUNDAY PATRIOT-NEWS, newspapors of general
olrculatlon, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies thai the same have
been duly paid. THE PATRIOT.NEWS CO,
CUMBERLAND COUNTY SHERIFFS OFRCE
COURTHOUSE
CARLISLE, PA. 17013
Statement of-AIlvertislna Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Probating same Notary Fee(s)
Total
$
$
$
276.57
1,50
278.07
By..............................,.....................................