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HomeMy WebLinkAbout00-08276 ! -'" , < IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC BANK, N.A. CIVIL DIVISION Plaintiff, NO.: 00 -?~?L d(.Jl-r~ YS. TYPE OF PLEADING KEITH L. KIEFFER and STEPHANIE C. KIEFFER, CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE Defendants. FILED ON BEHALF OF PLAINTIFF: TO DEFEN DANTS You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN J TWENTY (20) DAYS FROM SERVICE HEREOF P;Lf~ PNC BANK, N.A. ATTORNEY FOR PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: Brian B. Dutton, Esquire Pa.I.D.#81953 I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS, 539 SOUTH FOURTH AVENUE LOUISVILLE KY 40202 GRENEN & BIRSIC, P.c. AND THE DEFENDANTS IS, 531 HERMAN AVENUE LEMOYNE. PA 17043 ~J~ One Gateway Center, Nine West Pittsburgh, P A 15222 (412) 281-7650 ATTORNEY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS BOROUGH OF LEMOYNE (C~6~ ATTORNEY FOR PLAINTIFF . 1.< -~~, -CO",>, .,..~,,- .~<'""'C, ' " ~~, - ,,' 'r"=,~.,'" . <" ,~ ,,~ f",!" ',.'1' ~, A ;-'. '")"'1 r, ,? 1 .,.~,"","""", ,"""""-'-",""",-',,w'T,iif']IIif" ~1I I ill, r"T'~"""'n ""}I:~!,;:W ,-,:- / " " ."" , ._, ~, __I r,!l' f~~~~lIlfS.]!j, " ,11!]r-;,~ "!I'15!~~~~~!'ff;:~~1'!l!ll'!j~jwm~Ii1ifI\~.~nllf:,L,,,,, ,,/ ., , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC BANK, N.A., CIVIL DIVISION NO.: Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend agai nst the claim set forth in the followi ng pages, you musttake action within twenty (20) days afterthis complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered agai nst you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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 4th Floor 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 _.' ',-1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC BANK, N.A. CIVIL DIVISION /l't1~ NO.: tJD ' ~2 7G L.Mr<-X Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE PNC Bank, N.A., by its attorneys, Grenen & Birsic, P.c., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is PNC Bank, N.A., which has a principal place of business at 539 South 4th Avenue, Louisville, Kentucky 40202 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendants, Keith L. Kieffer and Stephanie C. Kieffer, are individuals residing in the Commonwealth of Pennsylvania whose last known address is 531 Herman Avenue, Lemoyne, PA 17043. 3. On or about November 28, 1997, Defendants executed a Note in favor of PNC Mortgage Corp. of America in the original principal amount of $62,950.00. A true and correct , , ,,' "' ' '~ copy of said Note is marked Exhibit "N, attached hereto and made a part hereof. 4. On or about November 28, 1997, as security for payment of the aforesaid Note, Defendants made, executed and delivered to PNC Mortgage Corp. of America a Mortgage in the original principal amount of $62,950.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on December 1, 1997 in Mortgage Book Volume 1419 Page 464. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto and made a part hereof. 5. PNC Mortgage Corp. of America, assigned all of its right, title and interest in and to the aforesaid Mortgage and Note to Plaintiff pursuant to certain Assignment of Mortgage. 6. Defendants are the record and real owners of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. Defendants are due for the February, 2000 payment. 8. On or about April 9, 2000, Defendants were mailed combined Act 91 and Act 6 Notices, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. 9101, et seq. 9. The amount due and owing Plaintiff by Defendants are as follows: Principal Interest through 11/05/00 Late Charges through 11/05/00 Escrow Deficiency through 11/05/00 Attorney's fees Title Search, Foreclosure and Execution Costs $ 61,430.81 $ 3,371.26 $ 179.01 $ 747.83 $ 800.00 $ 2.500.00 TOTAL $69,028.91 ,',I, WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $69,028.91 with interest thereon at the rate of $10.94 per diem from November 5,2000, and additional late charges, additional reasonable and actually incurred attorney's fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.c. BY: Brian B. Dutton, Esquire PAID# 81953 Attorneys for Plaintiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 THIS ISAN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. '"', ,-I I -''''''1,' NOTE ,-E"'LE~ S ~ ~;-:":-:S.;~: ,~MEM8EP 28 1987 [Datel C'&'Il,P HIll {Cityl PEtillSn.\IMii>\ rSIa.!el j3i HERMAN .VENUE, LEMOYNE~ PENNSYLVANIA 17043 (Propdt'ty Addr<:lS&J I. BORROII'ER'S PROMISE TO PAY In retu(O for a [olin that [have received. I promise to pa). e.s. $62.95o.o0--------------------(this amount is .:alled "principal ~}. plu.c; interest. to the order of the Lender. The Lender is PNC MOATGAGE CORP. OF AMERICA. AN ~HIC CCRPORAT iON [ understand thac the l.ender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive pll!"mentS ur1der this ~ote is called the "Note Holder." 2. I!\TEREST Interest will be charged on unpaid principal until the full amount of prinCipal has been paid. I will par interest at a }'carly rate of ----h----.-----6.5000%. The [merest rate required by this Section 2 is the rate 1 will pay both before and after any default described in Set:tiun 6(B) ()f this :\ote. 3. (',\ Y~IE:'iTS (A) Timeand Place of Payments [ will p8}" principal and interest b)' making payments every month. I will make my monthly payments on the FIRST day of each month beginning on JANUARY I . : 998 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. My monthly payments will be applied to interest before tncipal. If. on DECEMBER 1. 2027 , I still owe amounts under this Note, I will pay those amounts in full on that date. which is called the "Maturity Date." 1 will m.ke my monthly payments.. 75 NORTH FAIRWAY DRIVE. VERNON HILLS. ILLINOIS 60061 (8) AmOunt of Monthly Payments ).,l}- mOilthly payment will be in the amount of e.S. S 397 .Bg~--~--4~.___h__. 4. BORROWER'S RIGIITTO PREP.\ Y r have tlleri~ht to make paymeotsof principat at any time before they are due. A payment of principal unl)' is knownasa Q prepayment." \\' hen I make a prepayment, I wilt teU the Note Holder in writing that I am doing so. l may make a full prepayment or partial prepayments without paying any prepayment charge. The Note Holder will use all of my prepayments to reduce the amount of principal that I owe under this Note. If I make a partial prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5. LOAN ClIARGES If a law, ,which applies to this loan and which sets maximum loan charges, is rinalty inte'l"'eted so that the interest or other loan charges collected or to be collected in connection with this loan exceed. the permitted bmits, then: (i) an!" such loan charge shall be reduced. by the amount necessary to reduce the charge to the permitted limit; and (ii) an}' sums already c()llected from me which exceeded pc:rmitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this Note or by making a direct payment to me. If a refund reduces principal. the reduction will be treated as a partial prepayment. , 6. BORROWER'S FAILURE TO PA Y AS REQI.."IRED (A) Late Charge Cor Overdue Payments If the>:ote Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I win pay a tate charge to the Note Holder. The amount of the charge witllJe.-------~-~------5.0000% of my overdue payment of principal and interest. I will pay this late charge.promptly but only once on each late payment. (8) DeI..I. If I do not pay the futl amount of each monthly payment on the date it is due, I will be in default. (Cl Nolice or Der..1t , If I am in default, the Sote Holder may send me a written notice !elting me that if I do not pay the overdue amount bl' a certain date. the !\late Holder may ~uire me to pay immediately the full amount of principal which has not been paid and or at a different place if required by the \"ote ([older. MUlTlSTATE FIXED RATE NOrE... Sill9le Family -FM/li. Ullt/Freddi.... Uniform lDstrUlNllt .....10Il q-SAlgl05~02 XC3IOOt)AAA.01 VMP MORTGAGE FORMS -1313)2'3.1100. 1800l511-1291 Fill"'" 3208 121&3 Amended 5/91 In;I..'S:,ft ~ , I' ~ , ;...- illl dlr:: Interest [liar I o\\"e on that amount. That date mw>t he: at lea,>t 30 days after the date on \\'hich the 1l0til;t:;~ Jdi, en~d or malkd to me:. . (l)) \0 Wain;l' By \ote Holder . Even i~. at a time whettl am in default. the \'ote Holder does not require me to pay immediately in full as dt:."lCribed abo\'e. the :\ote Holder !Iii! still have the right to do so if I am in defaultata later time. (E) Pa)"ment or \otc Holder's Cosuand Expenses ((the \ote Holder has required meta pay immediately in full as described above the \"ore Holder willl1a'..e the right to be paid back: by me for all of its costs and expenses in enforcing this ~ote to the extent ~O[ prohibited by applicable law. Those expenses include, for example. reasonable attorneys' fces. 7. G1VI:liG OF :liOTICES Cnless applicable law requires a diffcl'cnt method, any notic-ethat must be given to me under this Note will be given by deli\.ering i.tor by mailing it by flrstclass mail tome at the Property Address above Of at a different address if t give the Sote Holder a notice of my differentaddress. . .-\n)' notice that must be given to the ~ote Holder under this Note will be given by mailing it by first class mail to the \ote Holder at the address statCd in Section 3(A) abm'eor at a different address if [am given a Roticeof that different addres.... 8. 0IILlG.H10~S OF PERSO:\S l::liDER THIS :liOTE . ~f morc tha~ one person signs this Notc, each person is fully and personally obligated to keep aU of the promises made in ~hls \ote. !RctudlOg the promise to pay the full amoumowed. Any person who is a guarantor, surety or endorser of this ~ote IS also obhgated to do_ ~h~ thj~gs. Any person who takes over these l?bligation~, inc.iud.jng the ob~igations of a guarantor, !;uret). or endorser of dus ~ote, IS also obhgated to keep all of the promises made In thiS ~ote. The >';ote Holder may enforce its rights \lnder this xote against each person individuaUy or against aU of US together. 'This means that anyone of us may be required to pay all or the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this :-.iote waive the rights of presentment and notice of dishonor. "Presentment" means the rig~t to require the Note Holder to demand payment of amounts due. "Notice of dishonor" means the riJ.ht to require the :\rote Holder to give notice to other persons that amounts due have not been paid. 10. L ~IFOR\I SECURED NOTE :rhis ~ote is a uniform instrument with limited variations in some jurisdictions. In addition to the prot~tions given to the ~ote Holder under this Note. a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same date as this Note. protects the Note Holder from possible losses which might result if {do not keep the promi.see. whicb.,{ make in this Note. That Security Instrumentdescribes how and under what conditions I may be required to make intmediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: . Transfer of the Property or a Beneficial Interest in Borrower. If all or any part or the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is nOt a natural person) without Lender's prior written consent, Lender may, at its option. require immediate payment in full of aU sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not tess than 30 days from the date the notice is delivered or mailed within which Borrower must pay aU sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period. Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. il i il II II II II !1 II , I , I II II ,'I ;1 I , I W1T~ESS THE HA:liD(S) ANO SEAL(S) OF THE UNDERSIGNED. I~,;L 1- "f KEITH l. KIEFFER SSN: (Seal) (Seal) .BortOWltt .8orrower SSN: (Seal) PAVTO THE ORD~\!.e"ilMIlI:''N.A. W1TPOU1 RECOURSE PNC 'frtgage Corp. 0\ Am9l\al ~,f. f6/~ - AfoL_ GoI E. w_ _ -5R(tIO~t02 XClIOODAAB.O% (Seal) .Borrowor SSN: (Sill" OrIgin.. Qltly] _".2.'2 Form 3200 1%113 " ,- ,-' 7ft j ) jd,1S..~'5 qtJ J.-.. C) .. ::-.:::.,_. p~c Mo~eage Corp. or America 75 North fal"'ay Drive . DocurDCftt Operationl_ St.sG7.5..0J-A Vernon Hilts, IL 60061 . . :,', ~ .::: ~ 'I T' .: .~ '9'1 DE~ 1 PP112 'i~ Pared ~Urt1 ber: 12-22.0822-014 );.)IlO ?/A ..r ,P t) pp~ [S"..<< Abo"'lIl: This LiRe For R.ccGl'4ing 0.,.1 "EP'RED BY' DEBRA J LASHLEY BETHEL PIRl. PA 15102 MORTGAGE LENDER.S . 09-24-65446 THIS ~{ORTGAGE ("Security Instrument") is given on NOVEMBER ZB . \997 KEITH L. KIEFFER AND STEPHANIE C. KIEFFER . The mortgagor is '''Borrower")_ This Security Instrument is given to PNC MORTGAGE CORP. OF AMERICA . "-hich is organized and existing under the laws of THE STATE OF OHIO , and "-nose address is 15 NORTH 'AIRWAY DRIVE. VERNON HILLS. ILLINOIS 60061 ("Lender"). Borrower owes Lender the principal sum of SIXTY-T,O 1HOUSANO NINE HUNDRED FIFTY DOLLARS AND IERD CENTS------------------------------------------------- _________.J______________________________________________________________________________________.__.________ Dollars (l~.S. $62.950.00------------- ). This debt is evidenced by Borrower's note dated the same date as this Sectlrit). Im;trument ("~ote"). which provides for monthly payments. with the full debt, if not paid earlier, due and payable on DECEMBER I, 2027 . This Security Instrument secures to Lender: (a) the repayment of the debt evident.-ed, by the :\ote, with interest. and all renewals, extensions and modifications of the Note; (b) the pa)'ment of all other sums. with interest, advanced under paragraph 7 to protect the scc:urity of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the following described property located in - CUMBERLAND County. Pennsylvania: which has the addr... of 531 HERMA/l AVENUE, LEMDYNE Pennsylvania. 17043 (-Property Address"); rZipCodol PEMtSYlVANlA-Single Plmily. PNMAlAlLMC UNIFORM INSTRUMENr Form 3D39 1198 <<S:I\ -6RIPA) C.-la, Am"'~ 5/91 VMP ~~II';~ f.lll'~1 ;,I4OO152""'l_,/, .BOOK1419"- ,IrA 1'.,. 1 .., e Inlll.le IC. I nul: nQ't ss::- tS"ft\.Ci'Yl. 111111~lllllllllllli III 11m ,. , , ',.;..,,'~,; , ~ c"d ( , I roc;r:TIIER ~\"rnr all the improvem~nls nOI\" or hereafter erC(;ted on the prn~rtr. am! ,Ill c::a::;cnc::nt:;. arpurTenam:l:S, and fl'l:turc:'i no\\" or hereafter a part of the property, All replat:cments and additiuns sha.lI a.]<;o 'r>t: l;tlt"c::rc::J by chi~St:t;urity lmnrumcnt, .-\11 of the rorcgoing is referred to in this Security lnstrumentas the "Propert)"." , BORROWER CQVE:,'\A!STS that Borrower is lawfully ~sed of the estate hereby conveyed and has the right to mortgage, grant and convey the ProperlY and chat the Propert)' is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demandlj, subject tn any ent:umbrances of record. - THIS SECL'RITY I~STRUME.\IT combines uniform covenants for nationaruse and non~un\form l,:o...enant.~\\"ith limited variations by jurisdiction to constitute a uniform Security instrument covering real property, lSIPORM COVENANTS. Borrower and Lender covenant and agree as follows: I. Payment of Principal and Interest: Prcpayment and Late Charges. Borrower shall promptlr pay when due the principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the ~ote. 2. Funds for Taxes and Insurance, Subject to applicable law Or to a written waiver by Lender, Borrower shall pay to Lender on the day monthly payments are due under the S'ote, until the Note is paid in full, a sum (~Funds") ror: (a) yearly taxes and assessments which may attain priority over this Security Instrument as a lien on the Properq'; (b) rearly leasehold payments or ground rents on the Property. if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums, if any; (e) yearly mortgage insurance premiums. if an}.; and m any sums pa}"able h}' Borrower to Lender, in accordance with the provisions of paragraph 8, in lieu of the payment of mortgage insuram:e premiums. These items are called "Escrow [terns," Lender may, at any time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan may require for Borrower's escrol\' ac(."Ount under the federal Real Estate Settlement Procedures Act of 1974 as amended from time to time. 12 CS.C. Section 2601 fit seq, ("RESPA "), unless another law that applies to the Funds sets a lesser amount, [f so, Lender may, at any time, collect and hold Funds in an amount not to exceed the lesser amount, Lender may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escro..... Items or otherwise in aCl.-"01'dance ,,'ith applicable law. The Punds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items, Lender may not charge Borrower for holding and applying the Funds. annually analyzing the escrow account, or verifying the Escrow hems, unless Lender pays Borrower \nterest on the Funds and 3pplicatlle taw. permits lender to make such a charge. However, lender may require Borrower to pay a one-time charge!for an independent real estate tax reponing service used by Lender in connection with this loan, unless applicable law pro\'ides otherwise, L. nless an agreement is made or applicable law requires interest to be paid. Lender shall not be requited to pay Borrowcr any i.nterest or earnings on the Funds. Borrower and Lender may agree in writing, however. that interest shall be paid on the Funds, Lender shall give to Borrower, without charge, an annual accounting of the Funds, showing credits and debits to the Funds and the purpose for which each debit to the funds was made. The Punds are pledged as additional security for aU sums secured by this Security Instrument. If the Punds held by Lender exceed the amounts permitted to be held by applicable (aw, Lender shall account to Borrower for the excess Funds in accordance with the requirements of applicable taw. If the amount of the Funds held by Lender at an). time 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 amount necessary to make up the deficiency, Borrower shall make up the deficiency in no more than twelve monthly payments, at Lender's sole discretion, Upon payment in fuU 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 nr sell the Property, Lender, prior to 'he acquisition or sale of the Property, shaU 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 P.yments. Unless applicable law provides otherwise. all payments received b)' Lender under paragraphs I and 2 shall be applied: first, to any ptepayment charges due under the Note; second. to amount.lj pa}"able under paragraph 2; third, to interest due: fourth, to principal due: and last. to any late charges due under the ~ote, 4, Charges; Liens, Borrower shall pay all taxes, a.'iSCSSrttents, charges. fines and impositions attributable to the Property ....hich may attain priority over this Securit} lnstfument. and leasehold payments or ground rent.';, i.f any. Borrower shall pay these obligations in the manner provided in paragraph 2. or if not paid in that manner, Borrower shalt pay them on time directly to the ~n owed payment. Borrowcr shall promptly furnish to Lender all notices of amounts to be paid under this paragraph. If Borrower makes tbese payments directly, Borrowef shall promptly furnish to Lender receipta evidencing the payments. Borrower shall promptly discharge any lien which has priority Over this Security (nstrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good Caith the lien by. or derends against enforcement or 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 satisfactor). to Lender subordinatlng the lien 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 satisfy the lien or take one or more or the actions set Forth above within 10 days of the giving of notice, ii Ii I; I' I' 1 " " , I: ,. I; :i !: ,: I' I' ~: lIOid419PAIl'E 465 Form 3039 9/90 Ini'I.I':~ lIC18070....8l"A1.4I1".5 tQ. -SRfPA) 111_ 101 "...l.rll ,. . """-',.:] ( .'~-- 5. "ala~d ur Prupert~. Insurance. Borrol\'cr shall keep the impro\.ement~ nflI\' e-,j~ling or hereafter CrCI:rt"ti rill ~111: Pr~lf'lert} IllSlIreu ;Jgai:IS[ loss or Fire, hazards lnduded within the term ~exlt:ndd l.."U\cra:.:e~ and an! other ha/,arJs. 11IdtlulI1g floods lIt f1uncJrng. fur whil,:h Lender requires insurance. This insurance shall he maintained in the amounts antl for tne! periods that I..ender requires, The insurant:e c;arrier providing the insurance shalt be chosen hr Bnrrol\'er 5\lhje-.:t to l.~nder'5 approval which shall not be unreasonably withheld. if Borrower rails to maintain em"erage descrihed ahll\'C, I.ender mal'. at Lender's option, obtain coverage to protect Lender's rights in the Property in accordam:e with paragraph 1. _ All insurance policies and renewals shall be acceptable to Lender and shall'include a standard mortgage clause, Lender shall ~ve the right to. hold tho poHcies and renewals. If Lender requires, Borrower shall promptly gin:: to Lender all receiptS or paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. l'nless I ,cnder and Bor.rower otherwise agree in \writing, insurance proceeds shall be applied to restoration or repl:Iir of tht: Propert). damaged., if the re.o;toration or repair is economically feasible and Lender's securit)' is not h:s.<;ened. If [he: rest.oration or repair is not. etonf>mi.call:; reasible Of l.ender's security \vould be les....ened. the insurance proceeds shall \'lI;:. applied to the sums secured by this Security Instrument, whether or not then due, with any e:<cess'paid to Oorrow~r. If Borrower abandons the Propertr, or does not answer within 30 days a notice from L~nder that the insurance carrier has offered to settle a claim, then I.ender may collect the insurance proceeds, Lender may USe the proceeds [0 repair or restore the Propert}. or to pay sums secured by this Securi ty Instrument. whether or not then due. The 3<rda)' period will begin when the notice is given. C nless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of the payments. If under paragraph 2) the Property is acquired by lender, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender to the ettenlof the SU(tlS secured by this Security Instrument immediately prior to the acquisition. 6. Occupancy, Preservation. Maintenance and Protection of the Property; Borrow.er's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sin)> days after the esecution of this Security Instrument and shalt continue to occupy the Propert)" as Borrower's principal ~idence for at least one year after the date of occupancy. unless lender otherwise agrees in wri ting, which consent shal\ nm be unrea.c;onabl}. withheld, or unless extenuating circumstances exist which are be}'ond Borrower's control. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate. or commit waste on the P~perty. Borrower shall be in default if any forfeiture action or proceeding, whether civil or criminal. is begun that in lender's good faith judgment could result in forfeiture or the Property or otherwise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower may cure such a default and reinstate, as pro\'ided in paragraph 18, by causing the action or proceeding to be dismissed with a ruling that, in lender's good faith determination, precludes forfeiture of tho Borrower's interest in the Property or otber material impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default if Borrower. during the loan application process, gave materially !alse Of inaccurate information 01' statements to Lender {or (ailed to rrO\'ide l.ender with an)' material information) in connection with the loan evidenced by the ~Ote. including. but not limited to, rt:present8tions concerning Borrower's occupancy of 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 [0 the Propert}.. the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 1. Protection or Lender's Rights in the Property. If Borrower lails 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, for condemnation or forfeiture or to enForce laws or regUlations}, then Lender may do and pay for whatever is necessary to protect the \.alue of 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. .-\1 though 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 additional debt or Borrower secured by this Security 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. ~fortgage Insurance. If Lender required mortgage insurance as a condition of making the Loan secured by this Security Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in effett. 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 10 the mortgage insurance pre"iously in effect, at a cOSt substantially 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-t;welfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or eeased. to be in effect, Lender wit\ accept. use and retain these payments as a loss reserve in Lieu of mortgage insurance. Loss reserve payments may no longer be required, .lICl8Q7OA.,.ClPll).0."O& _-SRIPAt 10"1101 PapJofS .Bood419riGE .466 fUI1l 3031 1/90 l"lti.l:tr ^' ~. ,j ( ;l[ I,he option of I.endt=r. it morrgage in~tlraOl:e t:on~rage {in the amount and rnr (he period that r.~ndt:r reqtlire~) pNJ\.id~d by an insurer appro\.cd hr Lender again becomes a\.ailable and is obtained. Borrower shall par the premiums required to maintain mortgage insurance in effect, or to pro".ide a loss reserve, until the requiremem for mortgag~ ins(lrance ehds in accordaflce 'li'ith any written agreement between Borrower and Lender or applicable law. 9. rnspection. Lender or its agent may make reasonable entries upon and inspections of the Propert)'. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable calIse for the inspection. 10, Condemnation, l11e proceeds of any award or claim for damages, direct or consequential, in connection \\'ith an)' condemnation or other taking 01 any part of the Property, or for conveyance' in lieu of condemnation, are herebr a~igned and shan be paid to Lender_ . In the event of a total taking of the Property, the proceeds shall be applied to thc sums secured by this Securit)' (marumem, \\.h.ether or not then due. with any excess paid to Borrower. In the eVent of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secur~ by this Security instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the Sums secured by this Security rnstrument shall be reduced by the amount of the proceeds multiplied b~' the following fraction: (a) the total amount of the sums secured immediately before the taking, divided b). (b) the fair market \'alue of the Property immediately before the taking, Any balance shall be paid to Borrower, In the event of a partial taking of the Property in which the fair mark.et 1,.alue or the Property immediately before tbe taking is less than the amount of the sums secured immediatcly before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums socul'ed by this Security Instrument whether or not the sums are then due, If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor off~rs to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given. Lender is authorized to collect and apply the proceeds. at its option, eithcr to restoration or repair of the !)mpertyor to the sums secured b)' this Security Instrument. whether or not then due. L:nless lender a.nd Borrower otherwise agree in writing, any application of proceeds to principal shall not e:.."tend or postpone the due date of the monthly pByments referred to in paragraphs 1 and 2 or change the amount of such paymentS. (I. Borrower Not Relcased; forbearance By Lendcr Not a Waivcr. Extension of the time for paYn:!ent or modification of amortization of the sums secured by this Security Instrument granted by Lender to any succ~r in interest of Bono'Het shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortiuation of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exerl".;sing an}' right or remedy shaH not 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 (",'Ovenants and agreements of this Security Instrument shall bind and benefit tht successors and assigns of Lender and Borrower, subjeCt to the provisions of paragl'llph 17, Borrower's covenants and agreements shall be joint and several. Any Borrower whoco-signs this Security rnstrument but does not execute the Note: {a} is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the 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 that Lender and any other Borrower may agree to extend. modify, forbear or make any accommodations with regard to the terms of this Securit)' Instrument or the Note without that Borrower's consent, \3. loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges, and that law is finally in'terprcted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to.the permitted limit: and (b) any sums alread)' collec:ted from Borrower. \l,.hich exceeded permitted limits wlll be relunded to Borrower. Lender may choose to make this refund by redUClfig the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under the ~ote. 14. Sot ices, Any notice to Borrower provided for in this Sec::urity Instrument shall be given by delivering; it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to lender shalt be given b}' first class mail to Lender's address stated herein or any other address Lender designateS by notice to Borrower. Any notice provided ror in this Sec:urity Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph, 15. Governing: Law; Severability. This Security Instrument shaH be governed by fcderallaw and the law of the jurisdiction in which the Property is located, In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law. such conflict shall not affect other provisions of this Security InstrUment or the Note which Catl be given effect without the conflicting provision. To this end the provisions of this Sec:urity Instrument and the SOle are declared to be severable, llCI8010"AO (1'1IJ,Cl61/.' ,,,.. 303'i!1: lnitlal~ C::' o.-SR(PAI '~1C11 Po,...f8 .BOOk1419 PAGE. 4fjl l" u, ,_ .....w.. , ", ,[ ( r Ifl. ~'.flrl'"fl\rer's Curr. Burrower shall he ginm nnet,;nnformed copr of the 'ote and of chi!' Set:urirr In~[rt1m,-.l1~. 17. I ~al.lder or the Property or a IIeneticiallllterest in Uorrower. [f all or any part of the I'ropc:rT} or ,lll~ intert:sl in It IS sulrl or tninsferred (or it a beneficial intel'c:5t in Borl'Ot\.er is sold or transferred and Burruwer is nut:l nati.ral pe(!;on)lVithout I.ender's prior written l.'Onl'lCnt, Lender mar. at its option, require immediate p3)'ntent in full nf aU sums secured '0)' this Security Instrument. However, this option sl\aU not be e~ercised b)" Lender if exel"\:ise is prohibited by federal law as of the date of this Sccurit).lnstrument. If Lender exercises this-option, Lender shan gi ve Borrower notice of acceleration, The notice shall provide a periud of not less than 30 days from the date the notice is delivered or mailed within whicn Borrower must pa}' all sums !'it:Cured by this Security Instrument. If Borrower fails to pay these sums prior to the-elpintion of this period, Lender ma). i nmke any remedies permitted by this Security InstrumCDt without further notice or demand on Borrower, 18, RorrO\ver'$ Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security {nstrument discontinued at al'lY time prior to the earlier of: (a) 5 days (or such other period as applicable laW' may specify for reinstatement) before sale of the Property pursuant to any power or sale contained in this Securit)' In.c;trument: or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the ~me as if no acceleration had occurred; (b) cures any default of any other COVCDants or agreements; (c) pays aU expenses incurred in enforcing this Security I~.rumenc, including, but not limited to, reasonable attorneys' fees: and (d) takes such action as Lender may reasonably. require to assure that the lien of this Security Instrument, Lender's rights in the Propert}' and Borrower's; obligation to pay the sums secured by this Security fnstrumentshall continue unchanged, t:pon reinstatement by Borrow~, this Security Instrumentand the obligations secured hereby shall remain fully effective as if no accel~tation had occurrtd, However, this right to reinstateshall not applY in the case of acceleration under paragraph t7, 19. Sale of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this Security Instrumen't) may be sold one or more times without prior notice to Borrower, A sale may result in a change in theentit). (known as the "Loan Servicer") that collects monthly payments due under the Note and this Security Instrument. There also may be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of th.e Loan Servicer, Borrower will be gi ven written notice of the change in accordance wi th paragraph 14 abo\'e and applicable Jaw, The noti.ce will state the name and address otthe new Loan Servicer and the address to which paymentsshoutd be made, The notice will also contain any other information required by applicable law. 20. Huardous S ubstanccs. Borrower shall not cause or permit the presence, use, disposal, storage, or rehse of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, an)'thing affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generatl}' recognized to be appropriat~ to normal residential uses and to maintenance of the Property, Borrower shalt promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or En,.ironm~ntal Law of which Borrower has actual knowledge, If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substance affecting the Propertr is necessary, :Borrower shall promptly talce all necessary remedial actions in accordance with Environmental Law, As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene. other flammable or toxic petroleum products, toxic pesti.::ides and herbicLdes. volatile solvents, materials containing asbestos or rormaldehyde, and radioactive materials, As used in this paragraph 20. "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection, NON-UNIFORM COVENANTS. Borrower and Lender further COvenant and agree as follows: 21. Acceleration;, Rem'odic.. Lender shall give notice to Borrower pdor to acccleratioo following Borro"er's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under parseraph 17 unless applicable taw provides otherwise). lender sball ootify Borrower of. among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceLeration of the sums secured by this Security Instrument, foreclosure by judicial ,proceeding and sale of the Property. Lender sball further inform Borrower or tbe right to reinstate after acceleration and the right to assert in tbe foreclosure proceeding tbe non--existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender, at its option, may require immediate payment in full of aU sums secured by this Security Instrument without further deMand and may foreclose tbis Security Instrument by judicial proceedin,. Lender sball be entitled 10 collect aU elpenscs incurred in pursuine the remedies provided in this paragraph 21, including. but not limited to. attorneys' fees and costs of title evidence to the eltent permitted by applicable law. 22, Release. Upon paym.ent of all sums secured by this Security Instrument, this So::urity lnscrumentand the estate conveyed shall terminate and become void, After such occurrence, Lender shall discharge and satisfy this Securit)" Instrument without charge to Borrower. Borrower shall pay any recordation costs, .ClI01QAAff....I.O.'J1I5 c:q. -6RIPA) 111.10) .8ood419rAGE 468 Fwm 3G39 ~~90. Inlti.l~ "...5.'6 - I (r-- r 23. Wal\"er",. nnrf'nwer, to the estem permitted t'tr applicahle law, \vai\'es and rdeaSl:5 an!. c::rrllr III' dt'rc:~t!'l in ("lrol,..<<,rJing.'l to cnfurc;c (hill St:Curitr In.<nrumcrn, and hereh). wai...es the benefit of an)" present nr future law.. {'rmiding rfJr.~t.ar ()( 1;"~Cl.:ution. extension of time, exemption from attachment,lcvy and sale, and homestead e!o:cmption. 24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the commencement of bidding at a sheriff'5511c or other sale pursuant to tnis Security Instrument. 25. Purchase ~Ioncy_~,tortgage. It any of the debt secured by this Security Instrument is lent to Borrower to acquire ti tie to the Property. this Security lnstrumentshall be a purchase money mgrtgage, 26. Intcre.,t Rate Alter J~dcmcnt. Borrower agrees that the interest rate payable after a judgment is entered on the :\ote or in an action of mortgage foreclosure shall be the rate payable from time to time under tbe Note, 27. Riders to this Security Instrument, If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend aOd supplement the covenants and agreements of this Security Instrument as i( the rider(s) were a part of thi$ Securitl (ostrumc.nt, [Chec:kapplicable box(es)] ~:--' Adjustable Rate Rider ~ Condominium Rider B 1.4 Family Rider : Graduated Pa)'ment Rider Planned t.:'nit Development Rider Biweekly Payment Rider Balloon Rider Rate Improvement Rider Second Home Rider I'.A. Rider Other(s) [specify] BY SIGNI~G BELOW. Borrower accepts and agrees to the terms and covenants contained in this Securit}' Instrument and in any rider(s) executed by Borrower "nd recorded with it. Wim.....:. LII- ~ -?~ KEITH L: KIEFF ~ t!\ ..."'t dt~~ rAV~ ~/I (Seal) -~rrower. . ~'''''D (J '6;'" E HA IE C. KIEFFER (Seal) -BOtMwor (Seal) (Setl) ~Borr()w.t -Borrower Certific:atg,pf Residence. """;"') L I. ..J~nc.\.lc. \- 1'<!Y'\nlY'q TUn . do hereby certify thatthe correct audressol the within-named Mortgageei. 20bo OXFORD DRIVE. 3RD FLOOR, BETHEL PARK. PI 15102 dayof Nl)jefY\~Y" . lqq~ A d OIlA..liJ '" ~ ".,...... CmlMOSWEALTH OF PENNSYLVANIA. CIA'f'\'\loefl Cl.Y\J. County ss: Ontl1is.the ~rh day of t\Jo,,~mbe,.... \'1'17 . beroreme. the undersigned oWcer. personally appeared :'J... ~ . C. IoC. rr _ -( Vl~\fh L. ~lc.ff(.Y' c.nd .......,.. ,a.n \.Q . I' ,c.~ known to me (or satisfactorily, proven) to be the person. ~ whose name;~ CJ.;{'I! subscribed to the within instrument and acknowledged that 111a.a- executed thesamc for the purposes heroin contained, ~ r"\~ INW1TNESSWHEREOP.fhereuntosetmYhand.and~Of. I. J.. I...! My Com.-i" ,...IIt'..~~"'1 ~rJ fll NO'FIJULSIAL .,...ot14~,Jtcl"""'" . -~-- ~',... ..........., ... ~ JIAtIff1IL~._ I-~ ,"itl1\ffc, '. ~ ~'$.' J . c.tP.......OJ.... ....c...M ~"'V"~"~~i: 0 I~ -~~Soptlo._ 1"r;~,g'~~~'<'- .,' " Mt--..-. ' : .~~:~ . 0. -SRIP>J ...." 'e'."",.~." '''' \~\(~;~t~~f Officer '<:...~\V BooK1419rACE 469 -~t"l'""~ Witness my hand this ;)."(,'"' For",3039 tl118 , , ~ 0"; i, "'.:1 r. c EXH.tBI't' A ALL 'tHAT CERTAIN piece or parael of land eituate in the Borough ot t..moyn., count.y of cumberland. and state ~t Pennlylvania, ~r. putiaularly bOunded and deacribed u followe, to wita BEGIHHING at II point on the northerly line of Berman Avenue on the dividing line between Lot. Noa. 36 and 31, section Dr on the hereinafter mentioned Plan of Lot.; 'thence North 31 degre.. w..t along ..id dividing Un., 4 eli.tanGe of one hundred fifty (150) feet to tbe loutherly lin. of PHcb Alley; thence aloDg en. southerly line of Peach Alley North fifty-nine degree. Ba8t, a diatance ot ..venteen and five tenths (17.S I f..t to I. point, thence South thirty-on. d8grHI But throuqh a partition wall between the premia.. herein described and the hou.. to the But . distance of one hundred fifty (150) feet to the northerly line of Berman Avenue, thence along the nortberly line of BeJ:maJl Avenue South fifty-aine clagr.e. wa.t, a dia1:anc:e of a.venueD. and. five 'tentbs e17.5) f..t 1:0 1:he clividing line betw.8n Lot. No.. 36 and. 37, sectiao D, 011 the hereia.after mentioned plan of Lota, at. the point or place of BEGINNING. BEItto the w..t:erly half of Lot 110. 37, Section 0 on. plan No.1 of Rivert.on .a recorded. in the CUmberland. county :Recorder's Offic:e in Dead Book -J-, volume 4, page 40. ltI10wn .a NO. 531 Bermaa. Avenue, Lemoyne, .eDlUlylvaaia.. " aBXHG the same premises which walter J. Buck end Harian A. Buck, hie wife, by Deed bllllarinq date the 15th day of March, 1965, and recorded in the of:U,ce of 'the Recorclar of Deeds in and. for cumberland. count.y, .eDD8ylvania, on the 15th. day ot Harch, 1965, io Deed Book .-,21, pag'41 125, granted and coa.veyecJ. ua:to VerDOn hgene J'J:anJc1in and. Haxy s. Franklin, hi. wit.. Bo0K1419 FAGE 470 u:N~:;r,\t: 1-,-- , 'c" . VERIFICATION The undersigned, and duly authorized representative of Plaintiff, deposes and says subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to her information and belief. TERESA SWtrzeA 2nd VICE PRESIDENT y..J::':;~:? ,~;;b.;k'H'1';[,~i.6.[;""I!I0"'1'"'Ji'ifl!i.'liJ"j~LAb1 ' '-'-.i/iI.-!l:;iU'iii~i~m>MIa:; . " .-'--'-Ili!l_""'~~!f!,. ~'.:ii;.w>.;,,,,,~~ Ii!im~.Hllc. IIJLJlM! ~U!.~.IV"~...w ~,. - ,;.....,.~"" '~llnlI" < . ..,.,. .. !~U _ ,l,~,-,>~,--.-"c;," . ... i lItllll!!.ll. ..",. .,_;, ~JJ'~' ,:,~",,'l)~"l< L" AJ"0'",,, __. ."- lilll&ilr ~.c_ ,,,,-,-."-__'<'-,,. . ~ ,. -~~".~,_ ,_m= I__~ J - L.~^ .~ .. -' ~ , I l_.~ ~.L l~ ---"~lLJ_ SHERIFF'S RETURN - REGULAR , , CASE NO: 2000-08276 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC BANK N A VS KIEFFER KEITH L ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KIEFFER KEITH L the DEFENDANT , at 0018:50 HOURS, on the 29th day of November, 2000 at 531 HERMAN AVENUE LEMOYNE, PA 17043 by handing to KEITH KIEFFER a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.92 .00 10.00 .00 37.92 So An~swers. ~. r"J. ....~~ -! W;- . R. Thomas Kline 12/07/2000 GRENEN & BIRSI Sworn and Subscribed to before By: me this J'F;t[::... day of ~ J.o-vo A.D. G;---() ~.-:~I . P othonotary ,.c-",,~;.j I ~ " . < ~~ -,'11 SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-08276 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PNC BANK N A VS KIEFFER KEITH L ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT KIEFFER STEPHANIE C but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE NOT FOUND , as to the within named DEFENDANT , KIEFFER STEPHANIE C DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FORWARDING, RETURN NOT FOUND AS PER ATTY. Sheriff's Costs: Docketing Not Found Return Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21. 00 S~ ~. Thomas :;~ne . .... Sheriff of Cumberland County GRENEN & BIRSIC 12/07/2000 Sworn and subscribed to before me this Ire day ofA.Pue~ ;2rmJ A.D. C \r-<-- 0 'flv~v ~ pr&t onotary f ., ~. I ~ ~_.i. R. THOMAS KLINE Sheriff \." of Q[.Ul11.fj" .,"{\ .~. <orZ tSY\)....- 4'"-'l: ..'.,., =' "~. :0- ~:=: -._.....;:..,~- ,.;.--: . ,. ." ,.~~~~.jJ[~:~~C~2. 4 J_:""" '. .;:-. jji'l -'<:-. .C' i EDWARD L. SCHORPP Solicitor -,' . :z:.~" -'f:;.' ,,:,;.., RONNY Fl. ANDERS( Chief Deputy ~",i ''ill! :l~4" OFFICE OF THE SHERIFF ?ATR1CIA A. 3HATT Real Estate D-eputy One Courthouse Square Carlisle, Pennsylvania 17013 To: po~~ Agency Comrol No. J.O - If). 7 h Date: Address Information Request Please furnish this agency with the new address, if available, for the following individual or verify whether the address given below is one at which mail for this individual is currently being delivered. If the following address is a post office box, please furnish the street address as recorded on the boxholder's application form. . Name ~t~.~ c... t.'e~ Last Known Address: nee of this agency's . I certify the address information for this indivldual is required f ~ lif:f oA;- 1f5 ()CL eO ~ FOR POST OFFICE USE ONL Y ~MAIL IS DELIVERED TO ADDRESS GIVEN ( ) NOT KNOWN AT ADDRESS GiVEN ~VED, LEFT NO FOR W ARDfNG ADDRESS () NO SUCH ADDRESS () OTHER (SPECIFY): NEW ADDRESS t.f i-IQl2shc&Q lW ' LOJn.f ~ elD II BOXHOLDER'S STREET ADDRESS Agency Return Address PostmarkIDate Stamp Address lnfor-mation Request (Required Format). Exhibit 352.44b ?A"l';:--h '., '.-..',",-",,"" "(,{ ,. ~<l ".' J? ./.~'/ ~~ '. \.~.o ", ,\\'(0 . "-I '.' . I r?, . '\}.. l . \.;;> \ c~:" I \~\\".'.:~~i)/ .',.; ll,__ ,-I, -1 ,. "', :i 'I !i I' I I I i I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC BANK, N.A. CIVIL DIVISION Plaintiff, NO.: 60 - f:2.'7 L C'o~[ T~ VS. TYPE OF PLEADI NG KEITH L. KIEFFER and STEPHANIE C. KIEFFER, CIVil ACTION - COMPLAINT IN MORTGAGE FOREClOSURE Defendants. FILED ON BEHALF OF PLAINTIFF: .J TO DEFENDANTS You are hereby nOlified to plead to the ENCLOSED COMPLAINT WITHIN TWZ2~HEREOF PNC BANK, N.A. ATTORNEY FOR PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: Brian B. Dutton, Esquire Pa. I.D. # 81953 I HEREBY CERTIFY THAT THE AODRESS OF THE PLAINTIFF IS, 539 SOUTH FOURTH AVENUE LOUISVILLE KY 40202 GRENEN & BIRSIC, P.c. AND THE DEFENDANTS IS, 531 HERMAN AVENUE LEMOYNE, PA 17043 $;J~ One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 ATTORNEY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL EST ATE AFFECTED BY THIS LIEN IS BOROUGH OF LEMOYNE (C1~T6~ AtTORNEY FOR PLAINTIFF TRUE COpy FROM RECORD In Testimony wherilof, I here unto set my hand . al'Id tOO g; said COOrt at Carlisle. ~ '--- Th~. ~da: ~;~~~~ . ,-~ J j oJ. " ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC BANK, N.A., CIVIL DIVISION NO.: Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you musttake 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 forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered agai nst you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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 4th Floor 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 I",. "'"'-"~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC BANK, N.A. CIVIL DIVISION NO.: Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE PNC Bank, N.A., by its attorneys, Grenen & Birsic, P.c., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is PNC Bank, N.A., which has a principal place of business at 539 South 4th Avenue, Louisville, Kentucky 40202 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendants, Keith L. Kieffer and Stephanie C. Kieffer, are individuals residing in the Commonwealth of Pennsylvania whose last known address is 531 Herman Avenue, Lemoyne, PA 17043. 3. On or about November 28, 1997, Defendants executed a Note in favor of PNC Mortgage Corp. of America in the original principal amount of $62,950.00. A true and correct ~ '-, j. > -~I L. i . ,. ,; ~-, , ~ - ~,i. copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about November 28, 1997, as security for payment of the aforesaid Note, Defendants made, executed and delivered to PNC Mortgage Corp. of America a Mortgage in the original principal amount of $62,950.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on December 1, 1997 in Mortgage Book Volume 1419 Page 464. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto and made a part hereof. 5. PNC Mortgage Corp. of America, assigned all of its right, title and interest in and to the aforesaid Mortgage and Note to Plaintiff pursuant to certain Assignment of Mortgage. 6. Defendants are the record and real owners of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. Defendants are due for the February, 2000 payment. 8. On or about April 9, 2000, Defendants were mailed combined Act 91 and Act 6 Notices, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.5. ~101, et seq. 9. The amount due and owing Plaintiff by Defendants are as follows: Principal Interest through 11/05/00 Late Charges through 11/05/00 Escrow Deficiency through 11/05/00 Attorney's fees Title Search, Foreclosure and Execution Costs $ 61,430.81 $ 3,371.26 $ 179.01 $ 747.83 $ 800.00 $ 2.500.00 tOTAL $69,028.91 ~ . , "I,! WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $69,028.91 with interest thereon at the rate of $10.94 per diem from November 5,2000, and additional late charges, additional reasonable and actually incurred attorney's fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.c. ~d; // BY: Brian B. Dutton, Esquire PAID# 81953 Attorneys for Plaintiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 THIS ISAN ATTEMPT TO COllECT A DEBT, AND ANY INFORMATION OBTAINED Will BE USED FOR THAT PURPOSE. ,-1'< ." ,-, '......:1-,; NOTE ,~:,.;;:~: '.i: :; - :.; .::::.:.~; ~C~:M8E~ 29 1967 :O..tt:! CAMP H[Ll leilfl ?ENNsn.'/~:tI~ l$t:lI.i jJ; ~e~MAN 4V€NUE LEMOYNe~ PENNSYLVAH[A 17043 lPfQplIftJ Addrus.1 I.IIORROWER'S PRO.\IlSETO PAY III return for it IUlIn that [ have received, I promise to pay C,S. $62. 950. OO-~--_._.---_u n_--~(this amount IS ~allcc.\ - rrlncipal-), plu.'1 intere.~il, to the order of the Lender, The Lender is PNC MORTGAGE- CORP. OF AMEf1ICA. AN :JH[C CCAPORAT ION r understand that the l,ender may transfer this ~ote, The Lender or anyone: Ivho takes this Note by transfer and \1,.00 is entitled to rcceive pll}'ments under this \'"ote is called the .Sate Holder, ~ 2. I~TEREST int1:fest wi.l\ be charged on unpaid principal llntil tbo fuU amount of principal has been paid. 1 will pay intcrl:St at a p:arl)" rate of ---------~---.-.6. 5000~, The interest rate required by this Section 2 is the rate I witt pay both before and after any default described in So.:tion 6(B) uf this XOte. J. 1'.H\IE)iTS (.-\) Timeand Place or Payments I will pal. principal and interest b}' making payments every month, [ \Viii make my monthly payments on the FIRST day or each month bt=ginning on JANUARY I , :998 . I will make ~hese payments every month until I have paid aU of ~he principal and interest ,nd an}' other charges described below that I may owe under this Note. My monthly payments wiU bd applied to interest berore tincipal. tr, on OECEH8EfI I, 2027 , I stilt owe amounts under this Note, I will pay those amounts in fulJ on that date, which is called the -Maturity Otcc,. I will malo my monthly pal'mentsat 7~ NORTH FAIRWAY DRI'E. 'lEANON HILLS. ILLINOIS 60061 or It a different place if required by the SOte llolder. (0) Amount of Monthly Payments )'l~. monthly payment will be in tbe Imountof C.s. S 397 ,89"---.-_.'-_____. 4. BORROWeR"S RIGIITTO PREPA Y I have theri~ht to make payments of pri",:ipal at an)' time befOte they are due, A payment or principal onl). is known L"O. -prepayment." When I make a prepaymenc:1 will tell theNo~Holdeti~ writingthatI am doing so. . . 1 may make a full prepayment or partial prepeyments Without plYing any:prepayment chirge. The Note Holder Will use all of my prepaymenrs to reduce the amount of principal that 1 owe under this Note. If I make a pattial prepayment. there will be no changes in the due date or in the amount of my monthly payment unless the ~ote Haidet agrees in writine to those changes. S. LOAN CH.\RGES If a law, which applies to this loan and which sets mwmum loan charges, is finally in~ted SO that the interest or nther loan charges collected or to be colJeeted in connection with this loan elCeed the permitted lunits, then: (i) an)' $UCh loan charge shall be r<cIucod by lho amount nocoaaatl' to r<cIuco the charge to the pennittod Iimi~ and (ii) any suma already l.:ullcctcd trom me which exceeded permitted limitl will be refunded to me, The Noto Holder may cltoose to malee this refund b}. reducing the principal I owo under this Note or by mating a direct: payment: to rr.e. It a refund reduces principal. the reduction will be treatedasa partial ~yment, 6. BORROWER'S FAILURE TO PA Y .U REQt:IRED (A) Late Charee tor Overdue Payments II lho :\010 Holder has not received the luUamount 01 any monthly payment by the end 01 15 calendar days alter tbe date i.t is due, I will pay a late chatp 'to the Note Hohler. The amount of 1he charge "'ill _-.------------5, ??oo1$ of my overdue payment or principal and intereSt. I will pay this late: charge promptly but only once on each late payment, (B) Delaolt II I do not pay the lull amount oleaeh monthly payment on tho date it is due. I will be in delaull. (C) !'Ioti.e 01 Delault If I am in default, the SOte Holdet may send me I wriuen notice telling me that if I do not pay the overdue amount by I certain date, the ~Ote Holder may require me to pay immediately the full amount of principal which has not been paid and UULnSTATE FIXED "ATE fCJfE- Single F....ily -F_i. u./Fr.wJ. II. lWfullt Ittstr... ....I.ll q -5AI.'OSL02 )(CJIOl)DMA.01 VM' MOIITQAClllIORMS - 013.213--1100 . lItIOIS:u-n" F"'L.'~'lm Illlll.ICft " i ,_. J' " +-i i I , - .111 lhe 1111l:"ro::~L 'lliH 10\\<: on lnu' Jmutlllt. {hat date mll!tt!":::.It lea.cH;o da\'s J.(tcr ~t\e <.!;ale: no 1\ At..:h (he \lOll":O:: \"<.ldt' ere,J Hr ~Tudcd tu :no::. (1)) \0 Wai\'cr By \ole Holder 'Even i(, at a time when 1 am in default, the Sate Holder does not require me 10 pay immediatelr in filII as d~rlbed alxIVI:, the \O(C Holder ~ill stilt I:u."e tt\o r;lht moo so it I ilom indefaultal" iater time. (F.) ra~.ment of \ote Holder's Costs and EJ:pensc, If the \ute Holder has required me co pay immediatcl)' in tull as described above, the ~Ote Holder will ha'..e theriit\t to be paid back by me for aU of its costs and expenses in enforcing this ~ote to the extent not prohibited by applicable law._.rhose c:\penSes inch)Qc. for e:tample. reasonaole anorneys' fees. 7. GIVI:-iG OF SOTICES L.nlesR applicable law requires a different method. any notice that must be given to me under this ~ote will be gio.'en by deli\'cring it or by mailing it by first class mail to me at the Property .-\ddress above or at a ditrerentaddress if I gi...e the \'ote llcllder, notice or my di"erent,ddress, ,-\n)" nmice Chat must be given to tho ~ote Holder under this Note will bofiven by mailing it by rirst crass mail to the 'lIte HolLIer at the address stated in Section J(A) abO\ieor aI a different address i l am given a noliceot thatdifterentaddress, H. OIILIG.\TIO:O;S OF PERSOSS I.:SDER THIS SOTE It more than one person signs this Xotc, each person is tully and personally obligated to keep aU of the promises made in thi:; \"ote, including the promisc to pay the tullamountowed. Any person who is a ~uarantor, surety or endorser or this ~ote is al1'io obligated. to do these things, Any person who talces over these obligations, Including the obligations of a guarantor, MJret~ or endorser of this ~Ote, is also obhgated to k.eep aU of the promises made in this Sote, The Sote Hoider may enforce its righrs under this :'orate against each person individually or alainst all of us tOgether, This means that anyone of us ma)' be required to pay all of the amounts owed under this Note. 9. WAIVERS { and any other person who has obligations under this ~ote waive the rights of presentment and notice of dishonor, "Presentment" means the right to require the Note Holder IO demand payment of amounts due. .~oticeof dishonor- means the right to require the ,"ate Holder to Jive Rotice to other persons that amounts due have not been paid. 10. I.::O;IFOR~I SECJ:RED :>IOTE Thi,; :--;utC is II uniform instrument with limited variations in some jurisdictions, [n addition to tho ~tections civen. to the ~ote Holder under this NotO. a Mortpp, Deed or Trust or Security Deed (the -Security (nstrument'"), dalCd the samo date as this Note. ~rotects the Note Holder from possible losses which might result it I do not keep the promisn which. ( make in this Note. That Security Instrumentdeecribes how and under what conditions I may be roquired to make irllmedialO payment in full of all amounts I owe under this Noto. Some of those conditions are described as follows: ' Transfer of the Property or. Benefi.,::i.1 Interest io Borrower, If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial intorCSt in Borrower is sold or transferred and Borrower is not a natunl person) without Lenaer'a prior written c:onsent, Lender may. at its option. require immedia10 payment in lull or ,II sums -..red by this Security lnsIrume.u. However. .his option shall no' be ..ereised by Lender it exercise is prohibited by federall.w AS or the date of this Security lnstrument. It Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period. of not less than JO deys from the date the notice is delivered or mailed within which Borrower must pay all 5ums secured b)' this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period. l..ender may invoke any remedies permitted by this Security Instrument without further notice or demand on UarralXet' . WIT:O;ESS THE HASD(S} AND SEAL(S) OF THE tiNDERSIGNED. ~.c~ "" E ~-:- K1EF;ER N: i~.A:L I- ~ 'E \l~ l. (IEFFER SSN: (Sesll (SoIl) -Botrow., .Botrow.t (Sesl) PAYTO THE OROE" qt'.IIo...._ . l'l'lv DlIIl'" ~1V'o SSN: Wffi'OUT ReCOURSe PNC~age corp. 01 A-'<<:a . F.i/~ - ... ClIIE._ q -SA II IOU02 XClIOOD""..OI (Sesll ..Borrowe, SSN: ($i... Or"llt.' 0111,1 ..,.1.12 Fw. 1200 lVI3 ~;~ 5q~ Cib J.-.. / C) ':. :... p~c Mo~pce Co.,.. 01 Alllerica 75 North Fal"'.y Drive . Docu_, Open'lon. - 51-5075-03-" Vemo. Rllb, IL _I _:.',:. ";':w'\i' .::. '9"1 DE~ 1 PP112 'i~ l)lIn:el \"umbcr: 12-22-0822-014 );JIlO?/A ..r ,P t) P/.J~ rSpace "boye This Line For RlICordinl D.t.l "'EP'RED By, DE8RA J LASHLEY 8ETHEL PAR'. P. 15102 MORTGAGE LENDER'S' 09-24-65446 THIS ~IORTGAGE ("Security Instrument") is given on NOVEM8ER 28 . 1991 'E!'" L. XIEFFER AND STEPHANIE C. 'IEffER . The mortgagor is C" Borro\ycr"), This Security InIlrumcnt is &i ven to PNC MOATGA6E COAP, OF AMERICA . lA'hic.:h isorpnized and existinCunder tho laws or THE SlUE OF OHlO . and wnosc address i. 75 NORTH F.IRWAT DRIVE, VERNON HILLS, ILLINOIS 8006\ ("Londcr"), Borrower owes Lender the principol sum or Slxr'-r'D THOUSAND NINE HUHoRED FIFTY DOLLARS AND 2ERO CENTS-----"------------------------------------------- ---_.._..__.....--------..--.._----~-.._----_......_.._._----_._-----...--------------.---..---....-------------------..----- Dollars (l..S. 562.950. OO-------m--- ). Tbi. debt i. ovideneed by Borrower's note dated the same date as this Securi'f Instrumen, (":'iote"), wbieh provides ror monthly poymenlS, with the rull deb~ il no' poid earlier, due and porable on oECENBER t. 2027 . This Security Ioatrument secures to Lender: (a) the repoymen, 01 the debt c\.idem:od by the ~ote. with interest. and all renewals. extenSions and modifications of the Note: (b) the: pa)'meat of all o'her sums. with in-. edvanood under JlItI#l'Illh 7 to protect the security orthi. Security Instrumenr. and (c) the performance of Borrower's covenants and asreementa under this Security Instrument and the ~ole. for this purpose. Borrower does here~ mort.... grant and convoy to Lender the following described property located in .. . CUM8EIIl.ANIl County. PennayIVllnia: whi<h has the add..... or 531 HEIlMAN AVEMIE, LEMOYNE Pennsylvania. 11043 ("Property Addresa"); [Zip Code) PErftSYlVAMA.SiIlgl. FIlftiIy-fNIINFtIUIC UMFOfIM INSTRUMEN1' "'11I 303' t/!lD fCt.-IRlPA) 1"101 ..... Sill v.... ~el'oT.'lt.lll. folll'!1l1 :..f""21""'.,/< .80011419.... AI!'A ,",. I ., . l"'tl.11: /Cia r MIle nO'I ~. ts,..1. CiI,I. 1IIIIIIIIml , .l "il , , , , rO(;(:lIII:R \lTn I 311 (he Improvements nOli. or hereaf:er erected on :hc rrnrer~~ ltuJ ,III <:a_~e~e"l~. ,lrflllrICnll.m.:~. oIntl ';\tur~ nil'" or hereaCter II patt III [he prnpt:rt)". .\11 repl"..:~ments and ilddltiUllS ih,,11 .1.1<;(1 ~ \.1.q:rcJ I'll' chi~ St:Curity Instrument. .\11 of the foreloing is referred to in this Security Instrument as the ~Prorcrt}"_ ~ , BORROWER COVI;::\.-\;..l.S that Borrower is lawfully seised of the estate hereby c.:on\'ered and has che right tCI mortgage, grant and convey the Property ,nd that the Propert}' is unencumbered, elCept tor encumhratll.:e5"r recnrd. Borrower warrants and will defend generally ~he title to the Property against all claims and demal1d't, sub~t tn "nr c:n..:umbrances of record. - nns SEClRITY I:\STRUYlENT combines uniform covenants for nationaruse and non.uniform l.:o\'cnanl.'i with limit~ ~ariations by jurisdicrion co constirute a uniform security instfumenrcoverin, real propcrt)'. L \IEORM COVENA~iS, Borrower and Lender covenant and agree as follows: 1: P~)'meRt 01 Principal and Inrerest; Prepayment and lato Charles. Borrower Shill prompt1r par l\.hen dUe the prIncipal of and interest on the debt evidenced by the :-.'ote and any prepayment and late charges due under the ~ote. 2, FundI (or Taxes and Insurlnee. Subject to 3pplicable law or to a writtcn waiver by Lender, Borrower !lhall pi)' to Lender on the day monrhly paymeRts are due under the ~ote. until the SotCl is paid in full, a sum ("Funds") for: (iI) yearly taxes and assessments which may artain priority over this Security Instrument as a lien on the Propert).; (b) rearly lelaSChold payments or ground rtnts on the Property, if any; (c) yearly hazard or proper1Y insurance premiums: (d) yearly flood insurance premiums, it any; (e) yearly mortpga insurance premiums. if any; and (r) any sums parable 0)' Borrower EO Lender, in accordance .,ith the provisions of peragraph 8, in lieu of the payment of mortgage insurance premiums, These items arc called "Escrow Items." Lender may, at any time, collect and hold Punds in an amount not to exceed the maximum amount a lender tor a federally related mortgage loan may require tor Borrower's e.'lCroft' llt.:count under the Cederal Real Estate Settlement Procedures .\ct of 1974 as amended from time to time, 12 LS.C, Section 2601 st seq. ("RESPA "), unless another law that applies to the Punds sots a lcsscr amount, If so, Lender ma~., at any time, collect and hold Funds in an amount not to exceed the lesser amount. Lender may estimate the "mount or funds due un the basis of current data and reasonable estimates of expenditures ot (uture Escrow Items or otheru:ise in ac."Cordanee \Vith applicable la\v. The runds shall be neld in an institution whose deposits are insured by a tederal agency. instrumentality, or entity {including Lender, it Lender is such an institution) or in any Federal Home Loan Bant.-LendClrshall apply the Funds to pay the Escrow hems. Lender may not charge Borrower for holding and applyinS the Funds, annually analyzins the ...-row account, or veritrins the Escrow (tems, unless Lender pays Borrower interest: on the Punds and applimlo law permits Lender to make such a charge. However, Lender may require Borrower to pay a one-time Charge!l'or ,n independent real estate w: reportina: service used by Leoder in GOMecUon with this lOin, unless applicable law pro\'ides otherwise. t;nJess an agreement; is made or applicable law requires interest to be paid, Londer shall (lot be required to ray Borrower any interest 01' earnings on ch. Funds, Borrower and Lender may agree in writing, howe\'er, that interest shall be paid on the Funds. Lender shall livo to Borrower, wirhout ch".ge, an aMual accounting or the Funds. showing credits and debics to the Punds and the purpose for which each debit to rhe Punds was made. The Funds are pledged as additional security for all sums secured by rhis Security Instrument. If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Bnrrower for the excess Funds in accordance with the requirements of applicable law. If Ute amount of rhe Funds held b)' Lender at an)' time is not sufficient to pay the Escrow [eems when due, Lender may so notify Borrower in ~\"titing, and, in suc;h case: Borrower shall pey to Lender the amount necessary to mako up the defiCleRCY. Borrower shall make up the deficiency in no more than twelve monthly peyments, at Lender's sole discretion. l.:pon payment ;n full of aU sum. secured by this Security Instrumen., Lender shall promptly refund to Borro..... any Funds hold by Lender. If, under poracrsph 21, I..ender shall acq~ire or seU tho Property, Lender, prior to the acquisition or salo of the Property, shan apply any Funda held by Lender at the time or acquisirion or sale as a credit apinst the sums Sl:lCUred by this Security Instrument. J. ."-pplication of Payment., Unless applicable law provides otherwise. all payments received. b)' Lender undo!' paragraphs I and 2 shall be applied: first. 10 any prepayment charges due under the Note: second. to amoun1& payable under paragraph 2; third, to interest due: rounh, to principal due: and last. to any late charCCS due under the Sou:, 4, Chuges: f..iens. Borrower shall ply all taxes, assessments, charges. fiRes and impositions attributable to the I'ruperty which may attain priority over this Security Instrument, and leasehold paymenrs or ground renrs, if any. Borrower shall pa)' these obligations in the manner provided in pangraph 2. 01' 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 or amounts to be paid under this paragraph, (f Bon'Ower makes these payments directl)', Borrower shall promptly Curnish to Lender receipts evidencina tile paYments. Borrower shall promptly discharge any liCtl which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender: (b) conteStS in good 'aith the lien by. or defeads apinst enrorcement or the lien in. logal proceedings which in rhe Lender's opinion operate to pravent the enforcement of the lien: or (c) secures rrom the bolder of tho lien an agreement satisfactOry to Lender subordinating the lien to this Security Instrument-If Lender determines that Iny part of the Propcny is subject to a lien which may attain priority over this Security Insrrument, Lender may give Borrower a notice identifying the lien, Borrower shall satisfy the lien or talce one or more of the actions sot ronh above within 10 days of the Civinc or notice. lIC11O'DA.oe"'iU.O.JIU ao0k1419 rAG'i 465 F.,... 1'39 !l9'D ,nlti..,.;e _-SAIPAJ 1"101 ....z... ~ , ~" 5. If."ud IIr IlrlJperc} In'lurance, l\nrrn\\"er ..hall (eep the lmprfl\emen[~ Illl\\ ~\I..llne nr ne~eah:r o:re.,:~~ "fl ;h~ Prllrcrl~ Irl!'illreu J"aHl!illu:<;.o; I'o! rire:, !ulI.artls luducJcO l\"tlhi(\ the: ~o:tm ~<:~t>:.n<.k.J. ":(l\er;t~o:~ MId .\\~ lither ll~f,,,rcJ.~" nll.1uuing (lllflcJ"..r (lundin&:, fur whil:h I.ender requitefi in.';urance:. nus in,uranc.:e ..hall he malntainet.l in the 4rT'H1lI!1fS JI1lJ' for the:' permd... that J..ender requires, The insurillnt:c -=arricr prm"iding the in!\.urance ..hall he chc)!I;Cn hr Borro".er iut'lJQ;t to r.cmcJe:r'~ appro\'al whi~h shall not bt: unrea50nablr withheld, If Bnrmwer fails 10 maintain cmeracc: d~ri\"occJ ,d1CI\'e, 1.ender mar, at Lender'1 option, obtain Go\'erage to protect Lender's rightS in (he t>ropcrt~" in al.:cordance with f'1"ragraph 7. _ .\(1 insurance policies and ronewals shall be acceptable to Lender and shall. include a standard mortglge clause. lender !I~all have the richt to. hold the policies and renewals, If Lender requires, Borrower shaU promptl)' gi\'C tn Lender all receipts or paid premiums and renewal notices. In the event of 108S, Borrower shall give prompt notice to the inl'lurance carrier and Lender. Lender may make proof or loss if nOI made promptly by Borrower. L'nless 1.ender and Rarmwer ott\erwise agr~ in writing, insurance proceeds shall be applied to restoration or repair uf che Prupcrtr damaged, if Ihe restoration or repair is economically feasible and Lender's security is not Ic:s..o;ened. tr the rc:sturatiun ur repair is nm economiclIlI)' f~lIsible or I.ender's security would be les.o;ened, the insuranc.:e prncc:ed., :;hall be applied to the 5ums 5eCUred by this Security Instrument. whether or nOl then due, with any e~ess.p.llid to Ilnrrot'cr. (f Borrower "bandon... the Propert)., or does not ansW~r within 30 days a notice from Lender that the insurance carrier ha.o; uffered to ~ttle a claim. then I.ender may collect the insurance proceeds. Lender ma). use the proceeds to repair or r~tore the Propert)' or to pay sums secured by this Security Instrument, whether or not then due. The JD-dar pcriod will begin \\'hen the notice is given. L.nless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or pmnpone the due date ol the monthly payments metred to in paragraphs I and 2 or change the amount of the paymentS. if \lndcr paragraph II the Property is Icquired by Lender. Borrower's right to lny insurance po\icies and proceeds resuhing from damage to the Property prior to the acquisition shall pass to Lender to the eltent of the sums secumi b)' this Security [nstrument immediately prior to the acquisition, 6. Occupancy, Preservation, Maintenance and ProtectioR of the Property: Boftowcr's Loan AppHcation: I.easeholds. Borrower shall occupy, establish, and U$C the Property as Borrower's principal residence within sin>. days aftc-r the execution or this Security Instrument and shall continue to occupy the Propert). as Borrower's principal residence for at lC88t one year alter the date of occupancy, unless Lender otherwise agrees in writing, which consent shall nut be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower ~hall not dtstroy, damage or impair the Propeny, allow the Property to deteriorate. or commit waste on ~ P~peny, Borrower shall be in default if any forfeiture action or proceeding, whether civil or crimiDlI. is beCUn that IR Lender's good faith iudlmenl could result in forfeiture of the PropertY or otherwise materially impalr the Hen created by this Sccurhy InstrUment. or Leader's security interest, Borrower may cure such a default and reinstate. as provided in paragraph 18, by causing tho action or proc:eodins to be dismissod with. ruling thaI, in Lender', good 'ailb determination, precludes. forfeiture of the. Borrower's intefst in the Propert, or otber l'uterial impairment of the ~'en created by this Security Instrument or Lender's security intereSt. Borrower shall also be in default ir Borrower, during the loan application process. gave materially ralso or inaccurate inrormation or statements to Lender (or failed to rro\'ide J.ender with an)' material inrormation) in connection with the loan evidenced by the ~Ote. includinc. but not limited to, representations c.."Oncerning Borrower's occupancy or the Property as a principal residence, If this Scl:urit)' lnatrumcnt is on a leasehold. Borrower shall comply with all the provisions of the lease, If Borrower acquires fee tide to the Propen:)', the leasehold Iftd the ree title shall not merge unless lender agrees to the merger in writing. 7. Protection of Lender'.s RiCh" in the Property, Ir Borrower fails to perform the co,",cnants and agreemenTS ..:ontained in this Security Instrument. or there is a legal proceeding that may significantly affect Lender's rightS in the I)roperty (such 18 a proceeding in bankruptcy. probate. ror condemnation or forfeiture or to enforce la\YS or regulations), then Lender may do and pay ror whatever is necessary to protect the \'alue 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 anomeys' fees and entering on the Propel17 to make repairs. Allbough Lender may like action uadet thia paragraph 7, Lender does ao' have lD do so. Any amounts disbursed by Lender under this paracraph 7 shall become additional debt or Borrower secured by this So.:urity Instrument, Unless Borrowor and Lender agree co other terms of payment. these amounts shall bear interest from the date: of disbursement at the Note raw and shall be payable, with interest, upon notice from Lender to Borrower requesting pa)'ment, 8, ~(ortl.ce Insurlnce. It Lender required mortgage insurance as a condition or making the lOin secured by this Security Inst.rumen~, Borrower shall pay the premiums required to maintain the mongap insurance in effect-If. lor any reason, the mortgage insurance coverace required by Lender lapses or ceases to be in effect, Borrower shall pay the premiums required to obain coverage substantially equi valent to the monpse lnsuran'ce previously in effect. at a cost: substantially equivalent to the cost to Borrower of the mottpge insurance previously in effect. rrom an alternate mortpf,a ittSU-r<< approved by Lender, if substantially flq,mvalcnt mortgage insunncc covon.p is not available, Borrower shall pay to Lender each month a sum equal to onrtweltth of the yearly mortgage insurance premium being paid by Borrower when the insurance covenge lapsed or ceased to be in cfrect, Lender VIm accept. use and retain these payments as a loss re&ervd in lieu or mottpcc insurance, Loss reserve payments may no loncer be required, "'C:'107~C:~.\I,O."" _-6RlPAJlM'OI ....)". .BDDK1419ricE .466 f.,,,, 3031 'ISO 1"1'1.1:t~ , , ,If rhe unrlOn of Lcnc.h:r. If mortlacc in:;uranc;e ~O\er"gr: (in the Imnunt 4nd rot' (he period th.H Lcnl.lcr ~c<.ltlire!ll) rl'l'l' lued b~ all insurer arpro\.t:d, h) Lc:nder alalA b<<um(:'l a,.ailable anl.l IS Obtalneu. liorroll cor ..hall (lUF the ;"Irerni\lm!l ret!ulred co maintain mortlago insurance in effect, or 10 provide I. loss reserve, until che requirement tor mortPle II1~Orancc chds in ac;cordafJce 11Iith any writtenagrcemcOt between Borrower and Lcndcr or applicable la"'. 9. (nspection. Lender or its &Ienl may make rca!k1nable entries upon and inspections of the Propertr. Lender shall gi...e Rnrrowe1' t\oticea.t tho timoof or prior to an inspection speci(ying reasonable calISe for tho inspection. 10. Condemn. lion. 'Fbe proceeds of .ny award or claim for damaGcs, direct or consequential, in connection with an)' ~ondemnation or ocher taking at any p.rt of the Prnpert)', or for conveyance. in lieu of condemnation, are hm:b}. illll'ligncd and ~hall be paid to Londer, In the ClVent of a tOtal talcing of the Property, the pl'txecds shall be applied to the sums secured by this Securit)' [murumcnt. "'hether or not then due. with any excess plid to Borrower. (n th.e event of a partial taking ot the Propert~' in which the fair market value of the Property immediately before the takinS is equal wor !P'eatcr than the amount of the sums secured by this Security Instrument immediately before the taking, unlCSll Borrower and Lender otherwise agree in IHiting, the sums secured by this Scc:urity Instrument shall be: reduced b~' the amount of tbe proceeds multiplied b)' the following fraction: (a) the total amount of the sums secured immediately before the taking, divided b~. (b) the fait market \'1.luc of the Pt'Qpetty \mmediatety bct~ the tak\ng. o\(\y balance shan be raid to Bol't'ower, tn tM: event or a partial taking of the Property in which the fair market value of the Property immedia~e(y before the taking is less than the amount of the sums secured immediately before the talcing, unless Borrower and Lender otherwise agree in ".ritine or unless applicable law otherwise provides. the proceeds shall be applied to the sums 5CCurcd by this Securitr Instrument whether or not the sums are then dUe. If the Property is abandoned by Borrower, or if, atter notice by Lender to Borrower that the condemnor offers to make an award or settle a claim for damaleg. Borrower fails to respond to Lender within 30 days alter the date the notice i.s I,...en, Lender ia authorh,ed to coUect and apply the proceeds, at its option, either to restoration or repair of the PnJpert)' or to the sums secured b)' this Security Instrument, whether or not then due. Cnless Lender and Borrower OEherwiso agree in writing, any application at proceeds to principal shall not e~end or postpone th., due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such paymentS. II. Borrower Sot Released; Porbearanee By Lender Not I Waiver, Extension of the time for paYlIJent or modification of amortization of the sums secured by this Security Instrument :ranted by Lender to any succCfSOr in interest of Borrower shall DOt opente to release the liability of the original Borrower or Borrower's successors in intereRt. Lender shall not be required to commence proceedings apinst any suc:cessor in interest: or refuse to cxtend time for payment or otherwise modify amortiZltion of thesoms secured by this Sec;urity Instrument by reason fJf any demand made by lhe oncinal Borrower or Borrower's successors in interest. Any furbearanot by Lender in eurcising an)' right or remedy shall not be I waiver of or preclude the exercise of any right or remedy. 12. Successors .nd Assipl' Bound: Joint and Several Liability; CO-Signers, The covenants and agreements or this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the ptO,.isions of paragraph 17, Borrower's covenanta and acreements shall be joint and several. Any Borrower ..ho co'"Signs this ~urit~' (nstrument but does not execute the :\lotI:: (a) is CO'"Signtng this Security Instrument only to mortgage. grant and convey that Borrower's intereSt in the Property undct' tho terms of this Security (nstrumcnt: (b) is not personally obligated to pay tile sums _ by this SecuritY Instrument;.nd (e) ..... tllst lender .nd any Othe. Borrower may agree to extend, modify, forbear or make any accommodations with regard (0 the terms of this Security Instrument or tho Sote without. that Borrower's consent. I J. LOin eblrces, If the lOin secured by this Security Instrument is subject to a law which sets muimum loan charges. and that law is finally interpreted SO that the interest or other loan charges collected or to be colleCted in connection with the loan exceed the permitted limits. then: (a) an)' such loan charp shall be reduced by the amount necessary to reduc:e the charge to.the permitted limit: and (b) any sums alread)' collected from Borrower ...hich C!cceded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal Qwed under the Note or by m.tinR a direct payment to Borrower, If a refund reduces principal, the n:duction I,'ill be treated as a partial prepayment without any prepayment charge under the Xote, 14, :-';oticcs. Any notice to Borrower provided for in this Security InstrumcntshaU be liven by delivering it or by mailing it b)' fim class mail unless applicable law requires use of another method, The notice shall be directed to the Property Address or any other _Bonow.. designates by no~c:e to Lender. Any no~e. to Lender sh.1I be given by first class mail to Lendcr's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security InstrUment shall be doomed to have been given to Borrower 01' lender when ci\'en as provided in this paragraph, IS. Governinc Law; Severability. This Security InstrUment shall be sovcmed by federalla. and the II. of the jurisdiction in whi.c:lt the Property \s \oc&ted. In tb.o event that any provision or clause of this Se:c:uritJ tastrumont ot' the SOte conDicts with applicable Jaw, such connict shall not affect other provisions of this Security (nsuumcnt or the SOle whic;h can be given effect without the connicting provision, To this end the provisions of this Security lnstrumau and the :\0[0: are declared to be severable. .ClI107000AllI.A1.0.J/H Bod419 PAG&. 4S7 "'.. 3"''-!//l: Iniflalt; U<: ~-6R(PAlt"IQI ".p4.' . (~ 1(" IJtlrrn".cr" C(lp~. I\urrower 'halt !-Ie gi\!;" flnc l.:f1nfnrmed <,;npr of the '"[~ .and o( tlll:"l ~ur;r~ In!lTrtlr-rh.n~. (7 t rau,Cer tiC the l)rHf'Cuy ur a l\enefiCIII !tuere" In nnrruwer. If <J\1 tit ..In~ rllnt uf tne: \'rllpcn~ ..r .1l1~ Intll:rl::'llln It I~ "flld or tnnsfcrrcd (or 1(, bcncriclallntcrcst In Borrower l!\ sold or transferred and l\um)\\'C1" I~ nut;l Jlstilral per~nnl without I.c:nder's prior written con.~nt, l.ender mar. at itS option, require Immediate pa}'mcnt in full nf all !'I~~S sa:urcd b)' thi.s Securi.ty Instrument, HQwc\.er, this. Option $haU not be esct'1:ised by Lender if eSef\.i!ie i~ prohibited by federal law IS of the date of thisSecurit}'lnstrument. If Lender eJefCises thiS-option. Lender shall Jive Borrower notice of acceleration. The notice shall prO\'ide . period of not leas than JO days from the date the notic.e is delivered or maill:d wttnin whi.ct\ Borrower must pt.)" aU !N.ms ~und by this Security Instrument. If Borrower rails to ply these sums prior to rhe expintion ot this period, LAnder ml}. inm" an)' remedies permitted by this Security Instrument without further notice or demand on Borrower. 18, Rorrou"er's Richt to Reinstlte. (f Borrower meets certain condttions, Borrower mall h..liC thc right to hal.e enforcement of this Security [nstrument discontinued. at any time prior to the earlier of: (a) S days: (or such olher pcriod aA.applicable la\\' may specity tor reinstatemend before sale of the Property pursuant to any power of sale contained in thIS Securit)' Instrument: or (b) enlry or . judament enforcing this Security (nsttUment. Th.ose conditions are that Borrower: (a) pt)'S Lender .11 sums Which then would be due under this Security [natrument and the \'ote as ir no acceleralion had oc:curred; (b) cures any detault of any other' covenants or agreements: (c) pays all expenses incurred in cnfon:ing this Security Instrument. including. but not limited to. reasonable attorneys' fees: and (d) takes such I(uon as I_cnder may reasonably require to assure that the lien or this Security Instrument, Lender's rightS in the Propcrt)' and Borrower', obligation to pay the sums secured by this Security Instrument shall continue unchanged, L" pon reinsuuemenl by Borrower, this Security lnsttumentand the obligations secured hereby shall remain fully efrective as if no acl%lcrariotJ had occurred. However, this right to reinstate shall not apply in the case or acccI.eration under paragraph \7, 19, S.le of Note; Chanco of LOin Servicer, The NOUl or a partial inUlrest in the Nota (together with thisSccurit)' Instrument) may be sold one or more times without prior notice to Borrower. .'\ sale may result in a change in theentit}' (known as the "Loan Servicer") thac collects monthly payments due under the ~ote and this Security Instrument. There also may be one or more changes 01 the Loan Servicer unrelated to a sale of the ~otc, If there is a change of the Loan Ser...il:cr. BorrowCf will be givcn written notice or thc change: in accordance with parasraph 14 abo,'c and applicable I.., The nOlice will state the name and address of the neVi Loan Serviccr anci the address co which paymenlS should be made, The notice will also contain any other information required b)' applicable law, 20, Huardoul 'S ublt.ncel. Borrower shin not cause or permic the presence, use, disposal. stonge. or i'dbse of any Hazardous Substancea on or in the Property. Borrower shaU not do. nor allow anyone clao to do. an)"thine aftec:tinl thc Propeny that is in violation 01 any Environm.encal Law. The preeec1inc two sentences shalt not apply to the presence. UBO. or storage on the ProPerty 01 small quantities or Hazardous Substances that are generally reaJ&nizcd to be appropriate to norma\ residential U&t6 and to maintenance of the Property, Borrower shall promptly give Lender ..ritten noticeol any investiption, claim, demand, lawsuit or other I~inn by an)' governmental or regulatory acency or privata pert)' involving the Propert)' and an)' Hazardous SubRanc:c or E.rwimnmental: Law of whKh Borrower baa actual knowlcc1p. rf Borrower learns, or is notified by any &O\"ernrneatal or regulacory authority, that any removal or other remediadon of any Hazardous Sl,IbscInce aerecting the Propert). is no:essary, BorrowlJrshall prompllytakeall ncces:saryremedial actions in accordanec with Environmental Law. As used in this paracraph. 20. -Hazardous Substances- ate those sub:nances<Winod as UlllC or huardous subsa:.aw;a by Environmental Law and the rollowing substances: psolinc. kerosene, other nlmft'lable or toric peuoleum proclucts. tosic pesticides and herbicides, volatile solvents, materials containing ubeslos or formaldehyde, and radioIcti,'o m...ri.ls. A. used in Ibis \lOTlCTlph 20. "Environmenlll La,," m.... federal 1a...1lld I.... ollhe jurisdiction .......lhe Property is located that relaUl to health. safety or environmental protection. NON-UNIFORM COVENANTS. Borro..er and Lender lurthereo.....t and.gree ..Iollows: 21. Acceleration; Rom"ediGl. Leader shall pve notice to Borrower prior to ICCClentioo rollo.ine Borrower's breach of Iny covenlDt or acroernOllt in tbis Security (utrume.t (but not prior to acceleration under plrarrapb 17 unless applic.ble IIW providOl otberwix). lender shill Dotify Borrower 01. .mone other lhines; (a) the default: (b) the action required 10 cure the derault; (c) wben the delault must be cured; aad (d) that railure to cure tbe default as specified may result in acceleration or the sums secured by this Security Instrument. foreclosure by judicial proceedi1lC and Slle or the Property. Lender shall further ialorm Borro"er or the riCht to reinstate after accelerltion and tho riCbt to assert in the foraclosure ptoceedinC tbe non-existence of I dcl.ult or Iny other defense of Borrower to acceleration aad foreclosure. If the default is not cured IS specified. Lcnder. at its option, may require immediate paymenl in full of all sums secured by this Security Instrument without funhor demand aDd may roreclose tbis Security Instrument by judicia. procecdinl- Lender .ball be entitled to collect 111 eJpcDscs incurred in punuinl tbe remedies provided: In tbis parlerlph 21, includin&. but: not limited to, attorney.' rees and cost:s of titlee\'idcacc to the edeut permitted by .pplicoblo I.". l:!. a.I..... Upon payment 01 all sum. soeurecl by this Security loatrumen~ this Security InstrUment and the.....o conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Seeurit). Instrument wilhout Charge to Borrower, Borrower shall pay any recordation costs. ...e'eG7DAAlIlillAl.a.1Ia1 Q-6AlPAJ (hlal BOOK 1419 rAGE 468 Fw.. J03t ~~'._ llllti'l~ .....s.,. (- (- 21 W'l\.et'!!. Hnrl"fll\'l:r. (n !hc extent permined tt). applicahle law. w.i\'es alld rtl'Ie=IdC!I ..n~ etnlr lit dC't"';fll in ['l"...:e'Ning.'l [I) c=nrnrt;l: ch~s ~uricr In...trumcnc, and herch}' u...i..:es ehe benefic 01 any ptdCnf ur rmurc 11I\\"1 rtlU idinl fnr."a) nf ~"sl;Cutinn, cS"tcn.,inn of time. exemption from attachment,le'.y and sale. and homeStead exemption. 24. Reinslltement Period, Borrower's time to reinstate provided in plncnPh 18 shall .luend to one hour prior cn the ..:nmmcnc;emcnt or biddinl at a sheriff'sSlle or other !laic pursuant to this Security Instrument. 2S. Purchase ~loney_~lortC'le. It In)' 01 the debt secured by this Security Instrument is lent to Borrower to lIcquire ti tIe to d\e Property. this Sec;urit)' [ostrumentsh.1l be I purchase monoy mort..p, 26, Interest R.te ..\'ter l~dlmOnt. Borrower 'I"ees thlt tho interest rite paYlble lIter I judcment is entered on the: ~ote or in an action of mortpco foreclosure shill be the rate payable from time to time under the ~Ote, 21. R;ders to this Security In.trument, tf one or mora riders are executed hy Borrower and recorded topCher with this Secunt). Instrument, the covenants and agreementS or each such rider shall be incorporated into and shall amend and supplement the covenants and alreements of this Security Instrument as it the rid.r(s) were a pen or this Scc;urit)O Instrument, [Check applicable box(es)] 8 Adjustahle Rate Rider ~condominium Rider ~ 1-4 Family Rider . Graduated Pa)'ment Rider Planned l:nit Development Rider Biweekly Payment Rider Balloon Rider Rate Improvement Rider Soc:ond Home Rider V.A. Rider Other(.) [specify] BY SIG:\I~G BELOW, Borrower accepts and agrees to the terms and covenants contained in this Sec:urit}. Instrument and in any rider(s) .xoaned by Borrower and recorded with it. Witnesses: . :ft.vM ./- ~ rn? A. ."'t .n" ,,~ ~~~ rIV.~ ~r":IEeER'6II~ ~(/ (SosI) .Btrro...... . (SosIl ..Borrow.t (SosII -80rro_.r (Sean -80rrn_.r Conifie.tsp'Residence 0 ""'7") L I. ....l~l"\c.\.Ic. \.. \'eY'\nINlTOO .dohetebycertilythstthec:orreo:t .ddressol the within-namod Mortppeia WOO OIFOIIO IIRIVE. JAG FlOOR. BETHEl P'RK. P, 15102 Wi_my hand thia ;J.~~ clayo! NOtICt"f\~'( . \'\~.7), A . . ejOflA.iJJ ~~"........ cml~IONWF..~L TH OF PENNSYLVANIA. Cl.A.Y'\'\ betl o..l'\~ CoualY'" Onthi..,he J.!il'h clayoII\)OVGmbc....- . \ttq7 .beforeme.theundersiplod Ollic:et.pe~~\.~~\c.~'(' 6.nd ~o.n~ c.. t\\cHeI" known to me (or ..lisl..tori~_l to be the person ~ whose nam.l~ ore. sutsribed to the W'i~n instrumeot and acknowledged that -." execu~ the samo for the putpOIeI hereia. contained. ("\ INWlTNESS WHBREOF'lhmuntoSOlmYhand,~. _ . . (...J.. ~ MyCo ".1::'_' ,.....,~,~""I r~ (J 1 ___ .,"011;,'"",,,,,,_0;.; -"ILPII'U__- h~,;,.'ri~~"""<"\.Ja ~I- -'''_(1' .....c...M ~-'~'.~' .. O~ " ",~"",,""1O.2IlII :~::;~""......... .- .... !~:I";; ~ : ~. .... of ottlcot :c::'- l/~." IIIClIeo7OAM'1P,u.oav.. t ~~ tai."':' C\-IAIPAl """ -:<..:~;?4";r~'" . ..,~~.. BOOK1419PlCE 469 ... 1031 tll, (- ." - ..;1 :1 i .I ! , ., [I II il II I r I EXHIBIT .\ ALL '1'1IM" CD'rAI. p1.o. H puo.l of lancl .11:".1:e ill 1:tMi BoJ:'ouCJh ot ~n.f COWIty ot CUllbeJ:'lud and SU'te of '.na.yl1'w., ...n. pU1;J.aulU'ly bOlIIIad aDd cHi,cJ:1JMd .. tollowl, 'to .itl ..lntH &t .. point oD t.h.e aarthel:'ly U.. of "~a. ""'.uue on th. d,1..,1cl1a.g U- bebN.a. Lat. Ko.. 36 aa4 37, ..otloD D, OIl ~ _eiA&ftlZ' _a.cJ.aDeCl 'lu of La'ttlJ t!leaal Rort.b 31 de9Z"'. w..t aloA9 .aid d1YicU.a, Une, .. dilcaAal of oa. huacked tifty (1501 f.." to tII. .""tIle~ly U... of .....b Alley, tb.no. alOllg tile .""tII.dy UII& of hllCb Alley __ fU.y-l1l.ne 48",... lIU., & cI1........ of ...."..." _ tift .."tII. (11.51 f... .0 . po1Dt, .Ileno. .outll tll.irty-one 48_. .... -..agb . partition "all betwela t:be ~... beraiD c1ellCr1blld and the houu to the But .. 41.'tua. 01' on. bUllUH t1ftJ' (150) t..'C 'to ~. ~ly line of Berman. Aveou., the=. aloaq 'the northerlY 11..- of lenwa AVlaue aou.'th tJ.t"ty-a1De degl:'" ...t, .. clJ..1:anae ot .eveuteln ancl t1" 't4tllt.b. e11.51 t..t. to the cU..,1cU.Dg U.. IMitw_ f.o1:. NO'. 3' ami 37, section D, aD tb. blre1nefter unti.oaed 'lu at locK., at the point or plac. of 8BGtHH11IG. _DIG the vI.'ter17 halt ot Lot .0. 37. S.crt.ioD. D OD. PIa .0. 1 of R1venoll .. ~eaorcled. La ~ CUIIb.rlud COWley ltec:o&'dez:.. Off1a. 111 DMCl BoOk -or, vol... ., page 40. KDCIVIl .. 110. 531 ..~ awe..., tAIDOfDe, ......ylvaa1a. . U'D1G tU I'" ~... vb.1ch walter 3. BUIck ad Ku1u. A.. auck, bJ.I wif., by Deed -l.ag cia.. tile 151:11"cIar of _. 1165. &114 ~lIClo_ 1D tile oU1c:. ot tile .._ of _cia 1D _ fo~ _1_ cout)'. .......ylv&lli&. 011 .... 15t11 48y of _b, lU5, 111 _c1 _ 8-21. I'&g& U5. "'....... _ _eel ...to _ ftgene ft&llkl1D _ IIaXY 8. ftADkl1D, hi. w1:1:.. .10011419 PAC! 470 ,~ ". VERI FICA TION The undersigned, and duly authorized representative of Plaintiff, deposes and says subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to her information and belief. TERESA SWtrzeR 2nd VICE PRESIDENT ~ ~~ ,,-,- '< I. 'lilltf.t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, N.A., Defendants. )CIVIL DIVISION ) ) NO.: 00-8276 ) ) ) ) )TYPE OF PLEADING: ) ) ) PRAECIPE TO REINSTATE CIVIL ACTlON- ) COMPLAINT IN MORTGAGE ) FORECLOSURE ) ) ) ) FILED ON BEHALF OF PLAINTIFF: ) ) PNC BANK, N.A., ) )COUNSEL OF RECORD FOR THIS PARTY: ) ) Brian B.Dutton, Esquire lPa.I.D.#81953 ) )GRENEN & BIRSIC, P.c. ) One Gateway Center ) Nine West ) Pittsburgh, PA 15222 )(412) 281-7650 1 ) ) Plaintiff, vs. KEITH L. KIEFFER, and STEPHANIE C. KIEFFER, -" ~ _'l . . I.. . ,'~""'i , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defendants. )C1VIL DIVISION ) ) NO.: 00-8276 ) ) ) ) ) ) ) ;i t I I i I I I I f PNC BANK, N.A., Plaintiff, vs. KEITH L. KIEFFER, and STEPHANIE C. KIEFFER, PRAECIPE TO REINSTATE CIVIL ACTION- COMPLAINT IN MORTGAGE FORECLOSURE , ~. , TO: PROTHONOTARY SIR/MADAM: Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.c. BY: ~If~ Brian B. Dutton, Esquire Attorney for Plaintiff ~ -" , . " " ."''''<,1") IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NA, Plaintiff, vs. KEITH L KIEFFER, and STEPHANIE C. KIEFFER, Defendants. I hereby certify that the address of the Plaintiff is: 539 South 4th Avenue Louisvile, KY 40202 the last known address of Defendant, Keith L Kieffer is: 531 Herman Avenue Lemoyne, PA 17043 GRENEN & BIRSIC, P.c. I!::tl!:~{ ) CIVIL DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) NO.: 00-8276 TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT against Defendant, Keith l. Kieffer, only (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: PNC BANK, NA, COUNSEL OF RECORD FOR THIS PARTY: Brian B. Dutton, Esquire Pa. I.D. #81953 GRENEN & BIRSIC, P.c. 1 Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 . >, I i , ~~_!;l:.g~l, . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , PNC BANK, N.A., CIVIL DIVISION Plaintiff, NO.: 00-8276 vs. KEITH L. KIEFFER, and STEPHANIE C. KIEFFER, Defendants. AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT IUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Brian B. Dutton, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant, Keith L. Kieffer is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copy. ~/~ Sworn to and subscribed before me this I~Of 2001. Not:;rl,~i'~;(~:j. ~ -1. Jo~l1tfe t1 \Ill 11 J" l',! if P, p,hf t\IT "-1_ /, 'I I 'II, "11:1 [ ~t ern ':Ii~:'i~ :.,~;)! .',,: :~:::L:'-~ :,','~' ;Ji)! ~~~ l_~)~~;~.,~~j ~mfltlm, I)I,inn- yl'/,j!!1iI t\'~~~(lc:':_'l'1O!1 rrl PQfltli1ilHi IT!': do - ~ . ~ ..._-"""""..",-~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , PNC BANK, N.A., CIVIL DIVISION Plaintiff, NO.: 00-8276 vs. KEITH L. KIEFFER, and STEPHANIE C. KIEFFER, Defendants. PRAECIPE FOR DEFAULT IUDGMENT against Defendant. Keith L. Kieffer. on Iv TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Keith L. Kieffer, onlv. in the amount of $69,833.30, which is itemized as follows: Principal $ 61,430.81 Interest to 1/09/01 $ 4,080.52 Late Charges to 1/09/00 $ 218.79 Escrow Deficiency to 1/09/01 $ 803.18 Attorney Fees $ 800.00 Title Search, Foreclosure and Execution Costs $ 2.500.00 TOTAL $ 69,833.30 with interest on the Principal sum at the rate of $10.94 per diem from January 9, 2001, and additional late charges, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. BY: GRENEN & BIRSIC, P.c. ~J~ Brian B. Dutton, Esquire P.A. ID# 81953 ;~- , IN THE COURT OF C \MON PLL>..S OF CUi',.\BERLAND c: . JNTY, PENNSYLVANIA PNC BANK, N.A., ) CIVIL DIVISION ) ) ) NO.: 00-8276 ) ) ) ) ) ) Plaintiff, vs KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. TO: Keith L. Kieffer 531 Herman Avenue Lemoyne, PA 17043 DATE OF NOTICE: DECEMBER 27, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OFTHIS NOTICE, AJUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEMING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOlLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 liberty Avenue Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 GRENEN & BIRSIC, P.c. By: 5)?o..; )f? r::,.{?~./> -f7,r Brian B. Dutton, Esquire Attorneys for PI ai nti ff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 FIRST CLASS MAIL POSTAGE PREPAID , , ''" "~''-;l'''_''L {rr'--r';~t:'~' "~'_~i!;I:ltim~"","M!!!I"'i!.....,t!I_;"""-.-.0;6;;;b"i.,,,L""'''''''''-''~'^'''''H';'",,-."~.-N~""'~Jt1.llll1M"'~ .' l""_..._~,,,,;_ ~~~ II""""" """ ...., UHI_ i I I . t ~ ~ -Iq ~ & - H "' 0 <:> 0 () t ft? ~ ." ... S- <- :~::i ;:gg:: l>" :"'7,::0 j r ~ :% ~~F.i - Z';G N ~ C> ) ~~ :06 N ...... ~ ~,.!::.~- ~~ ..i ( '20 --0 ~:r.:=tl ?28 ::::l1: C)~i .-7 . ca .,;......\1- ~C 9. ~ U1 ~ \D [I. Illil!llllflllll ,""'''' -, ,~ ,~-" ",",,- .,.,+,,,,,",,,,~ . _,,~. .,,,,,,,,",,,,,p<, ~-~<- ,,' , _ ,,-<, " .~ .. ~~ - I, iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, ) iNC., f!k/a PNC MORTGAGE, ATTORNEY- ) IN-FACT FOR PNC BANK, N.A., ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Plai ntiff, vs. KEITH L. KIEFFER and STEPHANiE C. KIEFFER, Defendants. CIViL DIViSION CASE NO.: 00-8276 TYPE OF PLEADING: Consent Judgment in Mortgage Foreclosure as to Stephanie C. Kieffer, ONLY FILED ON BEHALF OF PLAINTIFF: Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage, Attorney-in-Fact for PNC Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: Mary D. Grenen, Esquire Pa. I.D. #52698 GRENEN & BiRSIC, P.c. One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 I. ~ I __'!I, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, CIVIL DIVISION INC., f/k/a PNC MORTGAGE, ATTORNEY- IN-FACT FOR PNC BANK, N.A., CASE NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. CONSENT IUDGMENT IN M0RTGAGE FORECLOSURE AND NOW, this 16th, . .. 1:lay Of Mow , 2002, it is hereby stipulated and agreed that a judgment::"in mortgage foreclosure shall be entered in favor of Plaintiff, Washington Mutual Home LO(lrls, Inc:, f/k/a PNC Mortgage, Attorney-in-Fact . . for PNC Bank, N.A., and against Defe.ndant, StephanieC Kieffer, in the amount of $69,833.30, with interest on the principal sum at the rate of $10.94 per diem, and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) for foreclosure and sale of the mortgaged premises. It is also stipulated that Plaintiff, Washington Mutual Home loans, Inc., f/k/a PNC Mortgage, Attorney-In-Fact for PNC Bank, NA, will not seek a deficiency judgment against Defendant, Stephanie C. Kieffer. Dated: ~ \<i\D")r- 1 BY: Dated: 5 I b~ pha e C. Kieffer I . BY~MruID~~ 11> Washing:on Mutual U:Jans Inc.. .foDDer1y kOOwn as FNC Mlrtgage Co:!:p. of l\merica attorney in fact for FNC Bank National Association Jj' "~' , ~lIiIliii!.ft"l!illiJ::lll'@ll~~~r,~~#J~mnJH:!!'h,J..M!e"'-]b!>!,,,,,;';-'_V';'1F','-""j-'"''''~:''1#@iiiffuif~]-'~ li1lilrJi'-"'d-.'~~M~~~I!liil.it.~llo'r"-'''__R',...,;I ,..~O:,-~, iiIJj ~'~ 1::..- " illlllill/;liiJl ~ t ~ ~ 'l 8 D 0 'i3 \' C 1"0- r ~ :s - ,~ 0 -OCT :r'''' ~ fTjj";- -< "-l r ~-:::::- -- --r .... ,~.,.) - ~ ~ ~J CD~;:: , -,,''', ~ -, ~~-- , i;: .'G ~~) r (~:~~ ~ . , .J:.":>C: --:: Z -"-", --, :::> ,-> -< (',;'1 :JJ -< ~ , -'- ~ ~ . . ..1. , "~'" ........." '. ... ' . SHERIFF'S RETURN - REGULAR CASE NO: 2000-08276 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC BANK N A VS KIEFFER KEITH L ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KIEFFER STEPHANIE C the DEFENDANT , at 0013:26 HOURS, on the 29th day of January ,2001 at 717 16TH ST NEW CUMBERLAND, PA 17070 KIM PEELING (ADULT SISTER, by handing to CURRENT OCCUPANT) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE, REINSTATED and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 10.54 .00 10.00 .00 38.54 So Answers: ~V,~~~ R. Thomas Kline 01/30/2001 GRENEN & BIRSIC Sworn and Subscribed to before ~ me this IAJ- day of l,"""Q "'~ I A.D. .~ (2 ~~ r<!lthonotary Sheriff ,~,~ ". 1 R. THOMAS KLINE SheriN \.1? ot Q[U1l1be . \.\\"\ ,__ l' fer . ~'i:; c:r-;:; ;2 '!':".I1.o t;~t~4i\ EDWARD L. SCHOAPP Solicfiar OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 To: Agency Control No. ,20 -g;;J 71 Date: ,;) t/ -70-11 (7/ Postmaster (:c...D)/,'/1 1 Add,.ess Information Request Please furnish this agency with the new address. ifavailable, for the following individual or verify whether d1e address given below is one at which mail for this individual is cUITel1tly being delivered. tf the following address is a p06t office box, please furnish the street address as recoTded on the boxllOlder's application form, Name: s:.fell~ql\('" , Last Known Address: c. k Ie f2f~r <..; Me. rsL,.t/ f)r,'ll<. D,.yJ)./,/I/ P41)"'// r certify the address information for this individual is required for the performance of this agency's Off:ial duties. (jI-h.....JI- ?L4I':.' ) /7 (. (Signature of ency Official) N, t.ld. vrJ;, ffJ I~ ,. [)1'uI) <:!.jj I . (Title) . FOR POST OFFICE USE ONLY () MAlL IS DELIVERED TO ADDRESS GIVEN NEW ADDRESS () NOT KNOWN AT ADDRESS GIVEN X)(MOVED, LEFT NO FOR W ARDrNG ADDRESS () NO SUCH ADDRESS () OTHER (SPECIFY): BOXHOLDER'S STREET ADDRESS 1- 1;- -i,j;j;:;': RO NNY R, ANDERSON Chief Deputy PATRICIA A. SHATTO Real Estate Deputy. Agency Return Address Address Infonn2tion Request (Required Format) Exhibit 352.44b '"(,,.,' I" "." ,~,'I," - '~,,! PNC BANK, N.A., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. NO. 00-8276 CIVIL TERM KEITH 1. KIEFFER and STEPHANIE C. KIEFFER, Defendants CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE ANSWER OF DEFENDANT STEPHANIE C. KIEFFER Stephanie C. Kieffer, by her attorney, Robert P. Kline, Esquire, answers the above- captioned Complaint in Mortgage Foreclosure as follows: 1. Admitted. 2. Admitted in part, denied in part. By way of further answer, Stephanie C. Kieffer resides at 717 16th Street, New Cumberland, Cumberland County, Pennsylvania. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. Answering Defendant is without specific knowledge of the failure of her husband to pay the monthly installments of principal and interest. It is her belief, based upon representations from Defendant Keith 1. Kieffer, that he has, in fact, continued to make these payments. Proof of the alleged default is hereby demanded. 8. Denied. Answering Defendant is without specific knowledge as to the mailing of the notices alleged in this paragraph. If the notices were, in fact, forwarded to the defendants, Answering Defendant either did not receive them or they were concealed from her by her husband, Defendant Keith 1. Kieffer. .. 9. Denied. Answering Defendant is without specific knowledge as to the amount currently due and owing to Plaintiff by Defendants and proof is demanded. WHEREFORE, Answering Defendant, Stephanie C. Kieffer, respectfully requests that this Honorable Court enter judgment in her favor and against Plaintiff. Respectfully submitted, ,2- ~ 7001 DATE ~47~o ROBERT P. KLINE, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, P A 17070-0461 (717) 770-2540 Attorney for Stephanie C. Kieffer, Answering Defendant " ',; , ""........,1 I ~ l., '^~;j.,! VERIFICATION I verify that the statements made in the foregoing Answer of Defendant Stephanie C. Kieffer are true and correct. 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. S nm. ~~I I i' 'J ], CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Answer of Defendant Stephanie C. Kieffer upon the following persons by depositing same in the United States Mail, fIrst class, postage pre-paid on the 12&. day of February, 2001, from New Cumberland, Pennsylvania, addressed as follows: Brian P. Dutton, Esquire Grenen & Birsic, P.C. One Gateway Center, Nine West Pittsburgh, PA 15222 Keith 1. Kieffer 531 Herman Avenue Lemoyne, PA 17043 ROBERT PETER 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Defendant Stephanie C. Kieffer '=0...... f, J' J". 1- I '-"~"""",.l e JAN 15 2002~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, N.A., CIVIL DIVISION Plai ntiff, CASE NO.: 00-8276 vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. ORDER OF COURT AND NOW, this ~S"dayof 7'-""7 ,2002, upon consideration of the foregoing Voluntary Substitution of Washington Mutual Home Loans, Inc., f!k/a PNC Mortgage, attorney- in-fact for PNC Bank, N.A., it is hereby ORDERED, ADJUDGED and DECREED thatthe caption in the instant proceeding shall be amended from this date forward to read as follows: WASHINGTON MUTUAL HOME LOANS, INC., f/k/a PNC MORTGAGE, ATTORNEY- IN-FACT FOR PNC BANK, N.A., Plai ntiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. . ~ t!;tl~1\S ~ Gre~eJ ~ -e.. BY THE COURT: J. g , 1'!1IIIIIl!IIlJ1_~ ~-~",~~"l!!~~~~ ",,,., "' ~,~ ,,~ ~""",,,,,,,,~. ,._ , rtLm Ol~ ,;1 /-'~" ~-:")' 02 Jjl" 2'. ~ -1:\1 J ~,~."~",,, ,.,.",p- m '~'-~ij _Ur'.' q(t~-~:K ! ." 1.,;, (r'iRV ".'.'/r I. Pi'! 1.,,; 12 CU"I".. 11f;t1{-,~~'i i'" 1,-." PEN;VS:YL' v!.tl~}-'N.DUNTY , in 11\ "_ ~ c' _fj,"'lF[;;'f!ll"~'~I""~"'"\1""",,4"1'"~"',"~I,,,*lil:t_'1~~!!l'"~I~1Jj~'~_ljli~'WI'lFm~~., ^." ,_~ .~ ~~- - " , , "1- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, N.A., Plai ntiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. COUNSEL FOR DEFENDANTS: Robert P. Kline, Esquire 714 Bridge Street P.O. Box 461 New Cumberland, PA 17070-0461 ) ) ) ) ) TYPE OF PLEADING: ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CIVIL DIVISION CASE NO.: 00-8276 Voluntary Substitution of Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A. FILED ON BEHALF OF PLAINTIFF: Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: Mary D. Grenen, Esquire Pa. I.D. #52698 GRENEN & BIRSIC, P.c. One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 ~ > p 'f:, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, N.A., CIVIL DIVISION Plai ntiff, CASE NO.: 00-8276 vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. VOLUNTARY SUBSTITUTION OF WASHINGTON MUTUAL HOME LOANS. INC.. f/k/a PNC MORTGAGE. ATTORNEY-IN-FACT FOR PNC BANK. N.A. 1. Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A. is the successor in interest of PNC Bank, N.A., who is the Plaintiff herein, and desires to substitute itself for PNC Bank, N.A. as Plaintiff herein. 2. The material facts on which my right of succession and substitution is based are as follows: a. Washington Mutual Home Loans, Inc. maintains all rights, title and interest in and to the Mortgage which is the subject of the instant mortgage foreclosu re action. 2 I< I <~ " , >~, 3. Washington Mutual Home Loans, Inc., f!k/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A. hereby voluntarily substitutes itself as Plaintiff herein in the place and stead of PNC Bank, N.A. Respectfully submitted, GRENEN & BIRSIC, P.c. BY: .Jn~JI~ O. ~~ Mary D. renen, Esquire Pa. I.D. #52698 Attorneys for Plai ntiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 3 L, - ;$ .. , CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Voluntary Substitution of Washington Mutual Home Loans, Inc., f/kJa PNC Mortgage, attorney-in-fact for PNC Bank, N.A. was served via United States First Class Mai I, postage prepaid, th is q~ day of ~Q r\_ 2002, upon the following: Robert M. Kline, Esq. Kline Law Office 714 Bridge Street P.O. Box 461 New Cumberland, PA 17070 GRENEN & BIRSIC, P.c. By: nen, Esquire Pa. I.D. #5 698 Attorneys for Plaintiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 , J I . . \~~ ". . A HORNEY VERIFICATION I, Mary D. Grenen, Esquire, authorized legal counsel for Washington Mutual Home Loans, Inc., f!k/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A. deposes and says subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities that the facts set forth in the foregoing Voluntary Substitution are true and correct to my information and belief. -~~~ Name: D. Grenen Es uire Title: Counsel for Washington Mutual Home Loans. Inc.. f!k/a PNC Mort~a~e. attorney- in-fact for PNC Bank. N.A. i'!.JI"~ '1lil'>~~iiiillit!iiti~~WIi!llHliI~lj/;jI~~'IMl!~!&';e,1v,'~"'",.>i'''''''<1',,;,;mjf;>ili:\f~ -~iWAi '~ -~-._- - ,- ^ . ~ 0 r:::;; 0 c "-' -:-1 ~;.. '-- .. ~! -C' C[.' ,~:u m r-;-- :-~;: -7 - ..:_- r:;- 2'::: (J) ~r_: ~ - --<:' .- C::f.~:; -co ~1~? ~'"a :;;- ~ ~ ":D h,) -< 1},%;;t~ss,~~~;\l,~<U;.,uit;;~.;~;Ati:~-b,~~;J::~t,::Ay:,J,::iik.kL~T;,~,!~'ti(~~,;;;;~}"h!~c.L'~e.L;--",rw ,- 1. ~.." L !r" ,~,JJt_; ..lJ,: ,n [ lllL.~ J. l. if ,,~,J"1-~J,JL:;F~F' _=,^.t",_o;"Gr~'l~ l' ,-^",-, "",,,! ','c'"""," ."^ ,~,-" - _'~N . II ....... ,^I ., Jil;Oi-,_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, ) INC., f!k/a PNC MORTGAGE, ATTORNEY- ) IN-FACT FOR PNC BANK, N.A., ) ) ) ) ) ) ) ) ) ) ) ) ) ) . ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. COUNSEL OF RECORD FOR DEFENDANT: ROBERT P. KLINE, ESQ. 714 BRIDGE STREET POST OFFiCE BOX 461 NEW CUMBERLAND, PA 17070-0461 CIVIL DIVISION NO.: 00-8276 TYPE OF PLEADING: Motion for Summary Judgment Against Defendant, Stephanie C. Kieffer, ONLY (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: Washington Mutual Home Loans, Inc., f!k/a PNC Mortgage, Attorney-in-Fact for PNC Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: Mary D. Grenen, Esquire Pa. I.D. #52698 GRENEN & BIRSIC, P.c. One Gateway Center Nine West Pittsburgh, Pa 15222 (412) 281-7650 , " .~ ~I"": . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, CIVIL DIVISION INC., f/k/a PNC MORTGAGE, ATTORNEY- IN-FACT FOR PNC BANK, N.A., NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. MOTION FOR SUMMARY IUDGMENT AGAINST DEFENDANT. STEPHANIE C. KIEFFER. ONLY AND NOW, comes Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage, Attorney-In-Fact for PNC Bank, N.A. (hereinafter "Plaintiff'), by its attorneys, Grenen & Birsic, p,c., files the following Motion for Summary Judgmentas to Defendant STEPHANIE C. KIEFFER only: 1. Plaintiff commenced the above-captioned action byfiling reinstatinga Complaint in Mortgage Foreclosure on January 8, 2001. 2. In its Complaint, Plaintiff alleges that Defendants, KEITH L. KIEFFER and STEPHANIE C. KIEFFER (hereinafter "Defendants"), are in default under the terms of a Promissory Note dated November 28, 1997 in favor of Plaintiff's assignee in the original principal amount of $62,950.00 (hereinafter "Note") and a Mortgage securing said Note on real property and improvements thereon commonly known as 531 Herman Avenue, Lemoyne PA 17043 (hereinafter "Premises"). 2 ~ ~~- ~,~- ....J _ -~ :.a.. ".-,,/ . 3. A default judgement was subsequently entered against Defendant KEITH L. KIEFFER. However, an Answer was filed on behalf of STEPHANIE C. KIEFFER on February 12, 2001. In her Answer, the Defendant admits the following relevant material facts: a) Defendant executed the Note; b) Defendant executed the Mortgage which was recorded in the Office of the Recorder of Deeds of Cumberland County; and c) Defendant is the record and real owner of the Premises. 4. She denies having knowledge of the combined Notice of Intention to Foreclose Mortgage in compliance with Act 6 of 1974 and a Notice of Homeowners' Emergency Mortgage Assistance Act of 1983, in compliance with the Homeowners' Emergency Mortgage Assistance Act, Act 91 of 1983 as asserted by the Plaintiff. She claims that if they were mailed they were concealed by her husband. However, this claim is no defense to this mortgage foreclosure action as the Acts specify that actual receipt is not required, rather only that the Notices are sent to the last known address of the Defendant and the property address if different. Attached hereto and marked as Exhibit "A" is a true and correct copy of the combined Act 6 and Act 91 Notice mailed to Defendant's admitted last known address evidencing that the Acts were complied with in all respects as alleged by the Plaintiff. 5. The Defendant also claims that she has no specific knowledge as to whether the mortgage loan is in default stating that she believed her husband had been keeping the loan current. However, this is no defense as Defendant, Stephanie Kieffer, is a signatory on the Note (see Plaintiff's Complaint, Exb. "A") and remains liable on same. 3 - - " 1- _ I ~-~~< ....'.ok . 6. The Defendant also states that she is without sufficient knowledge to verify the truth of the averments regarding the amount due and owing. However, Plaintiff has filed a sworn Affidavit which is attached hereto as Exhibit "B". In the Affidavit, an authorized representative of Plaintiff certifies that Defendant is in default under the terms of the Note and Mortgage. The testimony is based on the Loan History Report which is a business record of Plaintiff maintained in the regular course of business. 7_ According to the Loan History Report, the amount due and owing by Defendant to Plaintiff is as follows: Principal Interest through 11/05/00 Late Charges through 11/05/00 Escrow Deficiency through 11/05/00 Attorney's Fees Title Search, Foreclosure and Execution Costs $ $ $ $ $ 61,430.81 3,371.26 179.01 747.83 1,600.00 $ 2.500.00 $ 69,828.91 TOTAL for a total of $69,828.91 plus interest at the daily rate of $10.94 plus additional late charges, attorneys' fees and costs. 8. The Defendant has failed to make payments when due under the terms of the Note and Mortgage, failed to cure the default after being placed on notice and lack any evidence to support her contentions. 4 - " ~I tlI""" I"" I 9. The Defendant has failed to raise a genuine issue of material fact in her Answer and has failed to offer any evidence to support her denials which are insufficient as a matter of law to defeat summary judgment. WH EREFORE, Plaintiff respectfully requests this Honorable Court grant its Motion for Summary Judgment and enter judgment in its favor and against Defendant, STEPHANIE C. KIEFFER, in the amount of $69,828.91 plus interest at the daily rate of $10.94, plus additional late charges, attorney's fees and costs and for foreclosure and sale of the Mortgaged Premises. Respectfully submitted, GRENEN & BIRSIC, P.c. By: Mary D. r nen, Esquire Pa. I.D. #52698 Attorneys for Plaintiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 5 'I ~ ~ i .; 05-06-00 I LOAN~ 0092465446 HTE~04-06 USER-CPI LINES PER PAGE-50 CONDITIONS=O . -I. '" ~J..JI.".", ,." " I,~ . ,.L' '_L_ MSP LETT'RWRlTER ACTI"I1; ~c:~~ <c," - KEY-BS705 IIS-003 TI TLE~ACT 91-PRCP+[j-" BS7(JS F<l s11~ Ap"il 09. 2000 Keith L Kieffer 531 Herman Avenue Lemoyne PA 17043 RE: LOAN NUMBER: 0092465446 PROPERTY ADDRESS: 531 Herman Avenue Lemoyne PA 17043 Current Servicer: PNC Mortage 539 S 4th Avenue Louisville, KY 40202 8aEUC1_8CII~ -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the A~ency under the eliqibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to maKe a decision after it receives your application. Durin~ that time, no foreclosure proceedinqs will be pursued against you if yOU have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance A~ency of its decision on your application. -- NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY. THE FOLLOWIHG PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed banKruptcy yOU can still apply for Emergency Mortgage Assist'lnce.) 8Q~_IQ_CUBE_~QUB_~QBIGBGE_nEE8ULI_1BL1Q3_1i_~~_iQ_dQia2.. NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender or> your property located at: 531 He~man Avenue Lemoyne PA 17043 IS SERIOUSLY IN DEFAULT because: As of 04-05-00 YOU HAUE NOT MADE MONTHLY MORTGAGE PAYMENTS following months and the following amounts are past due: Payments from 02-01-00 through 04-05-00 . PAYMENT AMOUNT . PAYMENTS NOW DUE . LATE CHARGES . RETURN CHECK CHARGE . OTHER FEES . LESS UNAPPLIED FUNDS for the 440.75 3 39.78 .00 .00 .00 IQIBL_8~QU~I_E8SI_DUE: 1,448.43 HOW TO CURE THE DEFAULT --You may cure. the default within THIRTY (:JO~__ .,'_ DAYS of ihe date of this notice BY P~YING THE TOTAL AMOUNT PAST DUE ,0 THE LENDER, WHICH IS $ 1,448.~~, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES ~jHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. _u'. ___ EQLrnaQi~_rn~~i_~e_mQda_alineL_~L_~Q~n~_~Q~nlaL~~_~ne~~~_~aLililaQ_~bec,LuQ= m~Q~L_~Ld~L_rn~d~_~Lab1~_~Qd_~~Qi_iQ~___e~C_~Qc13~3a_CQL~_~i_Brneci~a~ ATTN: Cash Services Dept. 7S N Fairway Drive. Uernon Hills. IL 50001. *** M 07 *** , - C": _I "n-'t . APPENDIX c\ . ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Ibis is an official notice tbat the mort~aee on your home is in default. and the lender intends to forecloac. SDecific information about the nature of the default is Drovided in the attached Dae:es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to helD to save your home" Tbis Notice explains how tbe proe:ram works. Jo see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take tbis Notice witb yOU wben yOU meet witb the Counselin!! Al;1ency. The name. address and pbone number of Consumer Credit Counseline: AI/encies servin!! your County are listed at tbe end of tbis Notice. If VOIl have any questions. you may call tbe Pennsvlvania HOllsin!! Finance Aeency toll free at 1-800-342-2397.(Persons.with impaired hearin!! can call (711\780-1869). This Notice contains important legal information. 1f)'OU have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. YOIl may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFlCACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A NOTIFICAClON OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENClONADO ARRIBA. PUlWES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMA DO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PA Y~ENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISHNCE ACT OF 1983 (THE "ACT"), YOU MA Y BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSEDBY CIRCUMSTANCES BEYOND YOllR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ^BLE TO PAY YOllR MORTG^GE PA YMENTS. 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"ir"f ~ 'a~ !Ii! 1- ~5r'." x .; ~ ~~. ~~f ~~~ . .Ci)! ~ ~ -. . ~11' ~~. . . . " :~ : . ~ ~~! ~~ 7 ~ i :l!; -;- '"'..Ii ~ ::.. > =!: ! ::; , !: , :: ~ ~.- - ~; ';' ~~ ~;: 'J . , f ~ ; ~ . .... . .., ,.... IJ. ~- . '-"'s: . 'c I k~' , 05-06-00 DAT~4-05 USER-CPI 11SP LETTEIIITER ACTIIJIT'I FOR 1101iH OF OC; LOAN- 0092455445 KEY-BS704 UERS=OOl TITLE=ACT 91 MAIL CERT 2ND LINES PER PAGE-50 CONDITIONS-O 22119 BS704 C2ndl1 Apr i l 09. 2000 Stephanie C Kieffer RE: LORN NUMBER: 0092465<146 531 Herman A"enue PROPERTY ADDRESS: 531 Herman A"enue Lemoyne . PA 170<13 0000 Lemoyne PA 170<13 Current ~ . . PNC Mortaqe .:>ervlcer. 539 S 4th Avenue Lou isvi lle, KY <10202 AGENCY ACllQN -- Available funds for emerqeney mortqaqe assistance are very limi ted. They will be disbursed by the Agency under the eligibility criteria estab l ished by the Act. The Pennsylvania Housing Finance Ag e n c y has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings wi II be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housinq Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION -- PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can sti II apply for Emergency Mortgage Assistance.) / , 8OM_ID-CUBE~QUB MORTGAGE DE[auLI-1BLln9_11_u~_lQ_d~~1~ ~aIUBE_Q[_~~E_DE[aULI --The MORTGAGE debt held by the above lender on your property located at: 531 Herman Avenue __LemoYJ)e PA 17043 IS SERIOUSLY IN DEFAULT because: As of 04-05-00 YOU HAUE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are past due: Payments from 02-01-00 throuqh 04-05-00 . PAYMENT AMOUNT 440.75 . PAYMENTS NOW DUE 3 . LATE CHARGES 3.9.78 . RETURN CHECK CHARGE .00 . OTHER FEES .00 . LESS UNAPPLIED FUNDS .00 .-..-.--.- IQlaL_B~QU~I_EeSI_ilUE: 1.<148.43 8o~~IQ~CU8E_I~E_ilE[aULI --You may cure THIRTY (30) .-------- .---.------ the default within DAYS of the date of this not ice BY PAYING THE TOTAL AMOUNT PAST DUE TO TULI ENlJERL l~HH,;H IS $ 1,'-1<18.<13, PLUS ANY MOI~T~AGE PtWI1tNTS " - AND LATC-CHARGE"S WHICH BECOME DUE DURING THE THIRTY ( 0) DAY ~ RIOD. E~~m~nl~_mu~l_~~_m~d~_~llUa~-Qy-~~~h~-~~~hl~c~~-~h~~t~-~~cl1iled_~be~L_QC money order made payable and sent to: PNC Mortqaqe Corp of America. ___._.~_________..__." ...__u alI~~_C~ab_S~~~l~ea_ile~l~_ZS_~_[~l~~~~_il~l~e~_Va~nQn_~llla~_IL_6QQQ1~ *** L 07 *** I. 1_,.1, , """~R: . APPENDIX t\ . ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort~a!:e on your home is in default. and the lender intends to foreclo~c. Specifil: information about the nature of the default is proYided in the attached Dae:es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to helD to save your borne. Tbis Notice explains bow the proe:ram works. To se.e ifHEMAP can belD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take tbis Notice witb you wben YOU meet witb the Counseline Ae:ency. The name. address and pboDe number of Consumer Credit Counseline: Ae:encies servine: your County are listed at the end oftMs Notice. lfyou have any questions. you may call the Pennsylvania Housine: Finance ^eency toll free at 1-800-342-2397.(Persons .with impaired beadne: can call (717) 780-1869). This Notice contains important legal information. lfyou have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENlDO DE ESTA NOTIFlCAClON OBTENGA UNA TRADUCClON INMEDlTAMENTE LLAMANDO ESTA AGENClA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUlWES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA tLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PlIEDE SAL V AR SU CASA DE LA PERDlDA DEL DERECHO A REDlMIR SU HlPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE P A Y~ENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MA Y BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEY AUL T HAS (JEEN CAUSEDBY CIRCUMST ANCES BEYOND YOUR CONTROL. IF YOU HAVE A REASONABLE PROSPECT OF BEINC ABLE TO PAY YOUR MORTGAGE. 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'\iIL:i , ,..~ .' ~ ~"~",d 5924654469 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME ) CIVIL DIVISION LOANS, INC., f/k/a PNC MORTGAGE, ) ATTORNEY-iN-FACT FOR PNC BANK, ) NO.: 00-8276 N.A., ) ) TYPE OF PLEADING: Plai ntiff, ) ) Affidavit in Support of Motion for vs. ) Summary Judgment Against Defendant, ) Stephanie C. Kieffer, ONLY KEITH L. KIEFFER and ) (Mortgage Foreclosure) STEPHANIE C. KIEFFER, ) ) FILED ON BEHALF OF PLAINTIFF: Defendants. ) ) Washington Mutual Home Loans, Inc., f/k/a ) PNC Mortgage, Attorney-In-Fact for PNC ) Bank, N.A. ) ) ) COUNSEL OF RECORD FOR THIS PARTY: ) ) Mary D. Grenen, Esquire ) Pa. 1.0. #52698 ) ) GRENEN & BIRSIC, P.c. ) ) One Gateway Center ) Nine West ) Pittsburgh, Pa 15222 ) (412) 281-7650 EXHIBIT "8" L. ~'"'.'-_I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, CIVIL DIVISION INC., f/k/a PNC MORTGAGE, ATTORNEY- IN-FACT FOR PNC BANK, N.A., NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. AFFIDAVIT IN SUPPORT OF MOTION FOR SUMMARY IUDGMENT AGAINST DEFENDANT, STEPHANIE C. KIEFFER. ONLY The undersigned, a duly authorized representative of Plaintiff, being first duly sworn, states of my own personal knowledge that: 1. I am a duly authorized representative of Plaintiff in the above-captioned matter. 2. This action was brought to foreclose on a Mortgage which secures a Promissory Note. 3. The Defendant is in default under the terms of the Note and Mortgage for, among other reasons, failure to pay the monthly installments of principal and interest when due. 4. The Loan History Report with respect to the loan upon which Plaintiff requests judgment in mortgage foreclosure against the Defendant is a business record of Plaintiff, maintained in the regular course of business. The Loan History Report reflects all of the payments made on the account, along with the corresponding balances, and accurately reflects the amounts due and owing by Defendants. Attached hereto as Exhibit "1" is a true and correct copy of the Loan History Report. - ,-,,~' Jan-IW:4Iam ~~.1 .. IL From- T-07S P.005/017 F-7!! 5. After allowing Defendant all proper deductions, credits and set-offs, the following is an itemization of the amount due and owing by Defendant to Plaintiff: Principal $ 61,430.81 Interest through 11/05/00 $ 3,371.26 Late Charges through 11/05/00 $ 179.01 Escrow Deficiency through 11/05/00 $ 747.83 Attorney's Fees $ 1,600.00 Title Search, Foreclosure and Execution Costs $ 2.500.00 TOTAL $ 69,828.91 for a total of $69,828.91 plus interest at the daily rate of $10.94 plus additional late charges, By: ~ Name: _ _ . ..- Title: _ _ ~.. President attorneys' fees and costs. SWORN TO AND SUBSCRIBED BEFORE ME ~ C,<,-> , 2002 bl.OJ 0'2-. ~ FlOR VALERIO ~. Commission fl. 1313920 = , Notary Public - California ~ Los Angele. County - My Comm. Expires Jul20, 2llOS , I. Page: 1 Document Name: untitled P309 LN 5924654469 MORTGAGE LOAN HISTORY NAME KL KIEFFER INV-LN Q34-995-0092465446 DUE 02-01-00 BR 00 MAN F P-TYPE 1 INT .0650000 FIRST PB 61,430.81 2ND PB HUD .00 NET 430.75 SF .00250000 SUSP .00 STOP D B REP .00 RES .00 0 0 APP 11-14 11-06 11-05 10-16 DUE 00-00 02-00 11-01 02-00 TYPE/TRAN 6 33 1 61 3 51 1 52 AMOUNT .00 281. 00 281. 00- .00 PRIN-PD .00 .00 .00 .00 PRIN-BAL 61,430.81 61,430.81 61,430.81 61,430.81 INT-PD .00 .00 .00 .00 ESC-PD .00 281.00 281.00- .00 ESC-BAL .00 .00 281.00- .00 A&H- INS .00 .00 .00 .00 LIFE-INS .00 .00 .00 .00 LC/FEES .00 .00 .00 1 19.89- MISC-PD .00 .00 .00 .00 ADV - BAL 1,193.69 1,193.69 912.69 912.69 SUSP .00 .00 .00 .00 SC/PAYEE APLENDERS 7184H PAGE 002 OF 005 TOTAL TRANS AVAILABLE 0024 OLDEST TRAN 02-16-01 / ~""""-~- -0_1 TY P o 1 Date: 02/15/2002 Time: 09:59:00 AM ,i Page: 1 Document Name: untitled P309 LN 5924654469 MORTGAGE LOAN HISTORY NAME KL KIEFFER INV-LN Q34-995-0092465446 DUE 02-01-00 TY BR 00 MAN F l?-TYPE 1 INT .0650000 FIRST PB 61,430.81 2ND PB HUn .00 NET 430.75 SF .00250000 SUSP .00 STOP D B P REP .00 RES .00 o 0 0 APP 08-24 08-16 07-16 06-18 DUE 00-00 02-00 02-00 02-00 TYPE/TRAN 6 30 1 52 1 52 1 52 AMOUNT .00 .00 .00 .00 PRIN-PD .00 .00 .00 .00 PRIN-BAL 61,430.81 61,430.81 61,430.81 61,430.81 INT-PD .00 .00 .00 .00 ESC-PD .00 .00 .00 .00 ESC-BAL .00 .00 .00 .00 A&H-INS .00 .00 .00 .00 LIFE-INS .00 .00 .00 .00 LC/FEES .00 1 19.89- 1 19.89- 1 19.89- 1 MISC-PD .00 .00 .00 .00 AnV -BAL 912.69 912.69 912.69 912.69 SUSP .00 .00 .00 .00 SC/PAYEE ATGREBI PAGE 003 OF 005 TOTAL TRANS AVAILABLE 0024 OLDEST TRAN 02-16-01 / Date: 02/15/2002 Time: 09:59:03 AM 1.1 "-J I t Page: 1 Document Name: untitled P309 LN 5924654469 MORTGAGE LOAN HISTORY NAME KL KIEFFER INV-LN Q34-995-0092465446 DUE 02-01-00 TY BR 00 MAN F P-TYPE 1 INT .0650000 FIRST PB 61,430.81 2NDPB HUD .00 NET 430.75 SF .00250000 SUSP .00 STOP D B P REP .00 RES .00 0 0 0 APP 04-16 04-10 04-09 03-16 DUE 02-00 02-00 04-01 02-00 TYPE/TRAN 1 52 1 61 3 13 1 52 AMOUNT .00 204.11 204.11- .00 PRIN-PD .00 .00 .00 .00 PRIN-BAL 61,430.81 61,430.81 61,430.81 61,430.81 INT-PD .00 .00 .00 .00 ESC-PD .00 204.11 204.11- .00 ESC-BAL .00 .00 204.11- .00 A&H-INS .00 .00 .00 .00 LIFE-INS .00 .00 .00 .00 LC/FEES 1 19.89- .00 .00 1 19.89- MISC-PD .00 .00 .00 .00 ADV-BAL 912.69 912.69 708.58 708.58 SUSP .00 .00 .00 .00 SC/PAYEE 370410446I A PAGE 004 OF 005 TOTAL TRANS AVAILABLE 0024 OLDEST TRAN 02-16-01 / Date: 02/15/2002 Time: 09:59:05 AM I. 1,1 I~ " ~".'~-L Page: 1 Document Name: untitled P309 LN 5924654469 MORTGAGE LOAN HISTORY NAME KL KIEFFER INV-LN Q34-995-0092465446 DUE 02-01-00 TY BR 00 MAN F P-TYPE 1 INT .0650000 FIRST PB 61,430.81 2ND PB HUD .00 NET 430.75 SF .00250000 SUSP .00 STOP D B P REP .00 RES .00 0 0 0 APP 03-09 03-09 03-09 02-16 DUE 00-00 00-00 00-00 02-00 TYPE/TRAN 6 32 6 32 6 30 1 52 AMOUNT .00 .00 .00 .00 PRIN-PD .00 _00 .00 .00 PRIN-BAL 61,430.81 61,430.81 61,430.81 61,430.81 INT-PD .00 .00 .00 .00 ESC-PD .00 .00 .00 .00 ESC-BAL .00 .00 .00 .00 A&H-INS .00 .00 .00 .00 LIFE-INS .00 .00 .00 .00 LC/FEES .00 .00 .00 1 19.89- MISC-PD .00 .00 .00 .00 ADV-BAL 708.58 708.58 708.58 708.58 SUSP .00 .00 .00 .00 SC/PAYEE ATTY15222 ATTY15222 ATTY15222 PAGE 005 OF 005 * * PRESS PF10 FOR 25 MONTHS * * OLDEST TRAN 02-16-01 / Date: 02/15/2002 Time: 09:59:06 AM .1 'I L~ . ~ "'[' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, CIVIL DIVISION INC., f!k/a PNC MORTGAGE, ATTORNEY- IN-FACT FOR PNC BANK, N.A., NO.: 00-8276 Plai ntiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the Motion for Summary judgmentfiled on behalf of Plaintiff, WASHINGTON MUTUAL HOME LOANS, iNC., f/k/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., it is hereby ORDERED, ADJUDGED and DECREED that the Motion is granted and judgment in mortgage foreclosure is entered in favor of Plaintiff, WASHINGTON MUTUAL HOME LOANS, INC., f/k/a PNC MORTGAGE, ATTORNEY-iN-FACT FOR PNC BANK, N.A., and against Defendant, STEPHANIE C. KIEFFER, in the amount of $69,828.91 plus interest at the daily rate of $1 0.94, plus additional late charges, attorney's fees and costs and for foreclosure and sale of the Mortgaged Premises commonly known as 531 Herman Avenue, Lemoyne PA 17043. BY THE COURT: j. ,.,"--' I, IL, ~"",I CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion for Summary Judgment was served via United States First Class Mail, postage prepaid, this ,tJRO day of ~~ , 2002, upon the following: ROBERT P. KLINE, ESQ. 714 BRIDGE STREET POST OFFICE BOX 461 NEW CUMBERLAND, PA 17070-0461 Respectfully submitted, GRENEN & BIRSIC, P.c. By: nen, Esquire Pa. I.D. # 698 Attorneys for Plaintiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and subnitted in dllpl ;cate) . TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next ArgImmt Court. ---------~----------------------------------------~----------------------------~-----~ CAPT10NOF CASE (entire caption,must be stated in full) WASHINGTON MUTUAL HOME LOANS, INC. f/k/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A. (Plaintiff) , . VS. KEITH L. KIEFFER and STEPHANIE C. KIEFFER (Defendant) No. 8276 Civ:U . 20 00 . . . . ,.. ..=1 o.::State:::matt-er::fu'be 'a:EgUed.c(i:e;-;- plaillntt-!S,,~tii ..:..... ,cnew,C....lcw..i"iIe~t 's denu1:rer to canplaint, etc.): Plaintiff's Motion for Summary Judgment 2. Identify counsel who will argue case: (a) for plaintiff: Address: ' Mary D. Grenen, Esquire Grenen & Birsic, P; C., One Gateway Center. Nine West Pittsburgh, PA 15222 . (b) for defendant: Robert P. Kline, Esquire Address: 714 Bridge Street, P.O. Box 461 New Cumberland, PA 17070-0461 3. I will notify all parties in writing within btio days that this case has been listed for argIIlBlt. 4. Argunent Court Dste: March 27, 2002 Dated: March 5, 2002 .~p~ ~~"~iI!lt~")lI~iiili~M.liill~*ilI!iIMJMill.,.l.l:I'rl",""; !In n If ~_ , ,~ ."_, ~_. =~ ".~! _, L '~d" ;,-~: ".,.,,,,",,;,;,-.q5!',;;!mki~'JlillJiiiii~' ~~...~ ~ll/iI:li.lli-'!~'l:i'" ~, ._-~ ,,_'", ,'c, " "ro-""""-tIlbliltli ~ '~'-iIilf~liH ~ -~~ .~,- ~ - :- (") 0 C) C r\J $: 'n -ort. ::J:: ---. m' ).~ r"'-: ~Fk._: "" .--- I ", (J~ ;;:~: 0\ ~r -.::......:- ,<=cJ :::0 ---..., c..) ...,.:::: ::::~ :'::8 ~. ;)(~ "l;"'c N (jrn -, ~ L.. f;"" ::;t .1:- ....0 -< ;Il'~~~-~I"~"'= - ,. "I, ;Ju.,: ~ .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage,' at,orney-in-fact for PNC Bank, N.A. ( ) Confessed Judgment ( ) Other File No. oO-8J lto ./ vs. Keith L. Kieffer and Stephanie C. Kieffer Amount Due $69.833.30 Interest 7,756.44 Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) County, See attached. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date ~//l6Y Signature: Print Name: Address: ~_/(y-4G~~ Kristine M. Faust, Esq. One Gateway Center, 9 West Attorney for: Telephone: Supreme Court ID No.: Pittsburgh,PA 15222 Plaintiff 412-281-7650 77991 (over) ~iihI~,~_lIif.~1li",ill:.1,kcJcl'n"lc<:'''~'1~1.'4~'''''iitilJl,"l,,*h';''\i\i.ud~-,:~,:Af_,U"",~,"..,,,,".g,,:,,)',=:jl,~,,,,-";",ih_,,"",";",{i.'_I"'1j'.all',;tlf~\ltIiH;ki""'IJ~~I;kBlj;'",_;@E"'dYlr,"iililWk';i. 11'.' t -,< .liillilll "1IilIiii1illlllllllillli ... \ Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, fiie separate praecipe with writ. 0 0 0 c: N ., ~ ~ :.:;:1 -ow ~ :1'1(3 rrlm z z:rJ -t-,m ZC N .:00 ~~~ . 1 CO qa '< --0 2~~ ~O :x )>~ ~ CSrn --I 3 w )> ::0 -~ -.J -< ,JJ~1!I1J,L..".._._~...._ ..."_.. ,. ...... ....,._ ..... .~, -,,- .. ~""~,,",,, .'.'" l'- J J ". .' .w: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYlVANIA) COUNTY OF CUMBERLAND) NO. 00 -8 d., I \Q CIVIL 19 CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland COUNTY: $69,833.30 To satisfy the debt, interest and costs due from Washington Mutual Home Loans, Inc., .et al Keith L. Kieffer and Stephanie C. Kieffer PLAINTIFF(S) DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell 531 ,Herman Avenue Lemoyne, PA 17043 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of - -- --:- GARNISHEE(S) as tollows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(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 ofthe 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 nomy him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due Interest Atty's Comm Ally Paid Plaintiff Paid $69,833.30 7,756.44 % L.L. Due Prothy Other Costs Date: Prothonotary, Civil Division by: Deputy REQUESTING PARTY: N Kristine M. Faust, ,Esq. ame . Address: One Gateway Center, 9 West Pittsburgh, PA 15~22 Allorney for: Plaintiff Telephone: 412-281-7650 Supreme Court 10 No. 77991 J "- ~ Ji IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A WASHINGTON MUTUAL HOME CIVIL DIVISION LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHAN1E C. KIEFFER, Defendants. LONG FORM DESCRIPTION All that certain piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the northerly line of Herman Avenue on the dividing line between Lots Nos. 36 and 37, Section D, on the hereinafter mentioned Plan of Lots; thence North 31 degrees West along said dividing line, a distance of one hundred fifty (150) feet to the southerly line of Peach Alley; thence along the southerly line of Peach Alley North fifty-nine degrees East, a distance of seventeen and five tenths (17.5) feet to a point; thence South thirty- one degrees East through a partition wall between the premises herein described and the house to the East a distance of one hundred fifth (150) feet to the northerly line of Herman Avenue; thence along the northerly line of Herman Avenue South fifty-nine degrees West, a distance of seventeen and five tenths (17.5) feet to the dividing line between Lots Nos. 36 and 37, Section D, on the hereinafter mentioned Plan of Lots, at the point or place of beginning. Being the westerly half of Lot No. 37, Section D on Plan No. I ofRiverton as recorded in the Cumberland County Recorder's Office in Deed Book "J", Volume 4, Page 40. Known as No. 531 Herman Avenue, Lemoyne, Pennsylvania. Being the same premises which Mary S. Franklin, a widow, by her attorney-in-fact, Joan A. Krasevic, by Deed dated November 28, 1997 and recorded in the Recorder of Deeds of Cumberland County on December I, 1997 in Deed Book Volume 168, page 791, granted and conveyed unto Keith L. Kieffer and Stephanie C. Kieffer, his wife. Parcel #12-22-0822-014 GRENEN & BIRSIC, P.C. By: ,11.~ctr(~~<----- Kristine M. Faust, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 J, ~-.J.." ~ ~ " ~ ";"~~'i>~~~"'ill!l"""&:~;i':C ~lJili~;;!\hil,.,ji~,,,,C,,,'t;;N-$h\r'$~j""''i'J:I';Milu,,, .J~"il1.,,"""~&'Jir:i;,",ciiih"'El:ll"'I"'''''''6~':';;'.!i''N,;;;.1~d~liI;4, ,.........- ~ <"'- 9-- c(""- D- p~\ I I .......)1 0' e- eL ~ ~~ ....... ~ }: o ." ~~" ,- . ,'= ~. lu -~,", ~__ ..,-"""',~~ --- --:J' ~ ...t:::- ~ ;J) r J ~ ~ ~ ~~~"'-f --.o~~~ ~~?I~ . U -tic! ~ )-- ""'"""""1MiIlllIIII ( It. ~ () 0 0 c "'" .1 s: c.... ,~, -ocu c:: ;~;;g ~rn :a::: ~:~ ~ tJj S;; N -":L: KCJ -,' ,.;::) c..... 2::0 -~ LPl ~3 ~ 0 --; :z .:..,) 1'; =< ...J -< i~.'~'r. ~ ._ I .,~-\ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A WASHINGTON MUTUAL HOME LOANS, INC., flkla PNC MORTGAGE, ATTORNEY~IN-F ACT FOR PNC BANK, N.A., CIVIL DIVISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY. ) Washington Mutual Home Loans, Inc., flkla PNC Mortgage, Attorney-in-fact for PNC Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Keith L. Kieffer and Stephanie C. Kieffer located at 531 Herman Avenue, Lernoyne, P A 17043 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KEITH L. KIEFFER AND STEPHANIE C. KIEFFER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 531 HERMAN AVENUE, LEMOYNE, P A 17043. DEED BOOK VOLUME 168, PAGE 791, PARCEL NO. 12-22-0822-014. - Ii I L 1. The name and address of the owner(s) or reputed owner(s): Keith L .Kieffer 531 Herman Avenue Lemoyne, P A 17043 Stephanie C. Kieffer 717 16th Street New Cumberland, P A 17070 2. The name and address ofthe defendants in the judgment: Keith L .Kieffer 531 Herman Avenue Lemoyne, P A 17043 Stephanie C. Kieffer 717 16th Street New Cumberland, PA 17070 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Washington Mutual Home Loans, Inc., f/kla PNC Mortgage, attorney- in-fact for PNC Bank, N.A. PLAINTIFF 4. The name and address of the last record holder of every mortgage of record: Washington Mutual Home Loans, Inc., fi'kla PNC Mortgage, attorney- in-fact for PNC Bank, N.A. PLAINTIFF Citifinancia1, Inc. 3401 Hartzda1e Drive, Suite 126 Camp Hill, PA 17011 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, P A 17013 P A Department of Revenue Bureau of Individual Taxes Inheritance Tax Division, Dept. 280601 Harrisburg, PA 17128-0601 Department of Welfare Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, P A 17105 ~~. , . ~ l"""l.-, , ~~ "~-~ "-; .' . 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants 531 Herman Avenue Lemoyne, P A 17043 I verifY that the statements made in the Affidavit are 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.A. g4904 relating to unsworn falsification to authorities. ~. Kris me M. Fa t, EsqUIre Attorney for Plaintiff SWORN to and subscribed before me this \ ~ day of ~ . ",,()---, , 2002. n.a.",~{'~~", e~ ."Th~ Not Public Notarial Seal Patricia A, Townsend, Notary Public City of Pitts~urgh, Allegheny County My CommissIOn Expires June 2, 2003 Member, pennsylvamal\SSOClallOn otNotanes h'~~,~W~;iBh1HJ,,;;l'"~"'!lllAilllf,.cli;j,;~!;ii!lt~"~,oiJlb>l;1"t-l;b, '_"I,_">,,;,,_"""""''''';,"--,~.:o'''''';''l~hit!11,,,;-,j;,l'"!;~il.~'li!illi,i,lW,,!O~l%lll!i>_1nJ"'wHii>lae~iffil;;~~d Uti ~ !llIIllm!L ill" UIIIJIJ L M ,~, ,,>,,>~> . ".m~,H",.., ." ~,. .'-".'~,~~ -", ~ ~ ~'""iIIIIlil r- --, lllliMljj.,1llliIIlIIilil .' ~... n 0 0 c:: N -n ;;:: c..... .--l .O(J;l c:: .~ mrn z ff1:!J Z:r:l ~ ,- zr. -um CD~ N ~IJ9 -<L. :_:), c-,. f20 -c ~~~~ ~8 :Jl:: ),.c '>i' orf1, Z ---l =<! W 3:; -.I ..< ~ . O~ " Ii " ., .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., flkla PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CIVIL DIVISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Keith L. Kieffer 531 Herman Avenue Lemoyne, PA 17043 TAKE NOTICE that by virtue ofthe above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISE, P A 17013-3387 on September 4, 2002, at 10:00 A.M., the following described real estate, of which Keith L. Kieffer and Stephanie C. Kieffer are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KEITH L. KIEFFER AND STEPHANIE C. KIEFFER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 531 HERMAN AVENUE, LEMOYNE, P A 17043. DEED BOOK VOLUME 168, PAGE 791, PARCEL NO. 12-22-0822-014. l J. ,~ ~r"t, ,." .. . The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Washington Mutual Home Loans, Inc., f'kIa PNC Mortgage, attorney-in-fact for PNC Bank, N.A., Plaintiff, vs. Keith L. Kieffer Defendants at Execution Number 00-8276 in the amount of $77,589.74. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriffbefore distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office ofthe Sheriff. This paper is a notice of the time and place of sale. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 800-990-9108 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriffhas not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. By: 4JL(~~~ Kristine M. Faust, Esquire Attorney for Plaintiff .... ~ ;.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME CIVIL DIVISION LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC NO.: 00-8276 BANK, N.A., Plaintiff, vs. KEITH 1. KIEFFER and STEPHANIE C. KIEFFER, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Stephanie C. Kieffer 717 16th Street New Cumberland, P A 17043 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland Connty, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISE, P A 17013-3387 on September 4, 2002, at 10:00 A.M., the following described real estate, of which Keith 1. Kieffer and Stephanie C. Kieffer are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KEITH 1. KIEFFER AND STEPHANIE C. KIEFFER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 531 HERMAN AVENUE, LEMOYNE, PA 17043. DEED BOOK VOLUME 168, PAGE 791, PARCEL NO. 12-22-0822-014. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure 1- -. ~.;, .. 0 action of Washington Mutual Home Loans, Inc., fi'kla PNC Mortgage, attorney-in-fact for PNC Bank, N.A., Plaintiff, vs. Keith L. Kieffer Defendants at Execution Number 00-8276 in the amount of $77,589.74. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriffno later than ten (10) days from the date when Schedule of Distribution is filed in the Office ofthe Sheriff. This paper is a notice of the time and place of sale. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 800-990-9108 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. ~~~ ,j L .,-, . ~ If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken ifthe Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. ..,,? ~ By:c./6c,.xi./~/'l"'<(_~'; :2-C-.. Kristine 1KFaust, Esquire Attorney for Plaintiff ',r4"jf~~m~~~I~~~~lii.wijll1lil!li!j;}mJ!Illi~jW;i!J-;i!J8;1lli;.,k;[! .'",'''; _""0,;) -,-"!.'U,-',',,,,, .j.".'j,k.'I~~"'_'fM;;j%jiliil!ii;!ili~W:!It1*WlWJ'-I.."fkii<'1I"*"""o,,,..~IiOl1'JMP"""'""...L'......~~gTifI!lIJW~. _4~" .~....,'~- I!ii!lIIIII ~~~ g ;;:: ~.o:: 'im z:e" (fl;J?;; -"..~ >.-, k'"' ZQ ~O "PC ~ =. ,~= ,_.~~, ~. ~ o tv 'c .,e. - tv .":, . --0 ~ ~ ~;;; .A -;- -i"\ r~1?:::: -Of" -0(:) D-b ~-rt ~,L11 '''-''0 2~ fil (") ::'" :l~ :2. "" ....l . ~..-- .1 ,;J ~;.., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , WASHINGTON MUTUAL HOME LOANS, INC., flkla PNC MORTGAGE, ATTORNEY-IN-FACT FORPNC BANK, N.A., CIVIL DIVISION NO.: 00-8276 Plaintiff, VS. KEITH L. KlEFFER and STEPHANIE C. KlEFFER, Defendants. AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.I01. ET. SEO. AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Faust, attorney for the Plaintiff, who being duly sworn according to law deposes and says that on April 9, 2000 Defendants were mailed Notices of Homeowner's Emergency Mortgage Assistance Act of 1983 and Act 6 Notices of Intention to Foreclose by certified mail, return receipt requested, and first class U.S. Mail. ~t2LC~~~ . SWORN TO AND SUBSCRIBED BEFORE ME THIS ~ DAY OF ~ ,,,,,ri, , 2002. ~~ ~0~ ('\\ A~ ",'n>.- ~ Notary Public Notarial Seal Publ\e P'<ltricia A. Townsend. Notary C t.y Cit~ of PittS~)ufgh, .l\He~~eny ? 0~~03 My C0l11ffilSS1on Expire:; . nne _. . Member, pennsylvanlaAsSOClatlOnof Notanes "'~- , " I' IJ "'1, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , WASHINGTON MUTUAL HOME LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CIVIL DIVISION NO.: 00-8276 Plaintiff, vs. KEITH 1. KIEFFER and STEPHANIE C. KIEFFER, Defendants. AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Faust, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owner of the property located at 531 Herman Avenue, Lemoyne, P A 17043 is, Defendant, Keith 1. Kieffer, who resides at 531 Herman Avenue, Lemoyne, P A 17043 and Defendant, Stephanie C. Kieffer, who resides at 717 16th Street, New Cumberland, P A 17070, to the best of her information, knowledge and belief. ~L~G~L- SWORN TO AND SUBSCRIBED BEFORE ME THIS ~DAY OF --s:t ,\'\\-C';" , 2002. CYd"'-~{';rof\~ LTh~ Notary Public Notarial Seal Patricia A, Townsend, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 2, 2003 Member, pennsylvama AsSOCIatIon ot Notaries Ii . I' 1_; "~ :. i. WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-8276 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, INC., FIK/A PNC MORTGAGE, A TTY -IN-FACT FOR PNC BANK, NA PLANTIFF(S) From KEITH L KIEFFER, 531 HERMAN A VB., LEMOYNE P A 17043 and STEPHANIE C. KIEFFER, 717 16TH ST., NEW CUMBERLAND PA 17070. (I) You are directed to levy upon the property of the defendant(s) and to sell REAL ESSTATE LOCATED AT 531 HERMAN AVE., LEMOYNE PA 17043 (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. Amount Due 69,833.30 Interest $7,756.44 Atty's Comm % Atty Paid $178.46 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs Date:. JUNE 12,2002 CURTIS R. LONG Prothonotary, Civil Divisio -~1J By: REQUESTING PARTY: Name KRISTINE M. FAUST, ESQ. Address: ONE GATEWAY CENTER, 9 WEST PITTSBURGH PA 15222 Attorney for: PLAINTIFF Telephone: (412) 281-7650 Supreme Court ill No. 77991 -' i1iT~-= "~ ,~ . '- ~ , ""Ii ~ llJls1 ~.. I .\ OCT 0 8 ZOOt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., fIkIa PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CNIL DIVISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. ORDER OF COURT , AND NOW, to wit, this 1/ day of Odl6-<<. , 2002, upon consideration of the within Motion for Service of the Notice of Sheriff s Sale Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that the Plaintiff is permitted to serve Defendant, Keith L. Kieffer, by first class mail, postage pre-paid at 531 Herman Avenue, Lemoyne, P A 17043 and 5 Nursery Road, # 1, Wellsville, P A 17365. Service on the Defendant shall be deemed complete and valid upon mailing by the Plaintiff. BY THE COURT: 44- J. 01 ~, ,,~' I,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., f/k/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., Plaintiff, vs. KEITH L. KlEFFER and STEPHANIE C. KlEFFER, Defendants. CIVIL DIVISION NO.: 00-8276 TYPE OF PLEADING: MOTION FOR SERVICE OF NOTICE OF SHERlFF SALE PURSUANT TO SPECIAL ORDER OF COURT CODE- FILED ON BEHALF OF PLAINTIFF: Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. LD.#77991 GRENEN & BIRSIC, P.C. One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 I, ~"-'. "".',,,-- _.~ " j I ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., flk/a PNC MORTGAGE, A TTORNEY-IN-F ACT FOR PNC BANK, N.A., CIVIL DIVISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. MOTION FOR SERVICE OF NOTICE OF SHERIFF SALE PURSUANT TO SPECIAL ORDER OF COURT AND NOW, comes the Plaintiff, Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, Attorney-In-Fact for PNC Bank, N.A., by and through its attorneys, GRENEN & BIRSIC, P.C., and files the within Motion for Service of Notice of Sheriffs Sale Pursuant to Special Order of Court under Pennsylvania Rule of Civil Procedure 430 as follows: I. On or about January 22,2001, Plaintiff entered DefaultJudgment against Defendant, Keith L. Kieffer in this action in the amonnt of $69,833.30 and for foreclosure and sale of the mortgaged premises 2. On or about June 12, 2002, Plaintiff filed with the Prothonotary a Praecipe for Writ of Execution on the judgment in this action. 3. In accordance with Pa. Rule of Civil Procedure 3129, Plaintiff mailed the Defendant, Keith L. Kieffer a true and correct copy of Plaintiffs Notice of SheriffS ale, by certified mail, return receipt requested at his last known address being 531 Herman Avenue, Lemoyne, PA 17043 and by directing the Sheriff of Cumberland County to serve the Defendant at the same address. " I ~ I~ -~, 4. As of July 1,2002, the certified mail regarding Defendant, Keith L. Kieffer was returned to Plaintiff, undelivered. 5. On or about July 8, 2002, Plaintiff received notice from the Cumberland County Sheriffindicating that they were unable to serve the Defendant with a copy of the Notice of Sheriffs Sale as the property at 531 Herman Avenue, Lemoyne, P A 17043 is vacant. 6. The Sheriff of Cumberland County also deputized the Sheriff ofY ork County to serve Defendant Keith L. Kieffer at 480 Mount Airy Road, Trailer #13, Lewisberry, P A 17339. The Sheriff ofY ork County was unable to serve Defendant, Keith L. Kieffer at this address. A true and correct copy ofthe Sheriff s return is marked as Exhibit" A", attached hereto and made a part hereof. 7. On or about August 20,2002 Plaintiff mailed Defendant, Keith L. Kieffer a true and correct copy of the Notice of Sheriffs Sale at 5 Nursery Road, #1, Wellsville, P A 17365 via certified mail, return receipt requested. 8. One or about September 16, 2002 the certified mail addressed to Keith L. Kieffer at 5 Nursery Road #1, Wellsville, PA 17365 was returned marked "Unclaimed." 9. The Sheriff of Cumberland County has posted the property located at 531 Herman Avenue, Lemoyne, PA 17043 with the Sheriffs Handbill of Sale pursuant to Pa. Rule of Civil Procedure 3129.2. 10. An Affidavit of the Plaintiff stating the nature and extent of the investigation which has been made to determine the whereabouts of Defendant, Keith L. Kieffer and the reasons why service of the Notice of Sheriff s Sale cannot be made, is marked Exhibit "B", attached hereto and made a part hereof. WHEREFORE, Plaintiff respectfully requests that this Honorable Court permit the Plaintiff to serve Defendant, Keith L. Kieffer by mailing a true and correct copy of the Notice of Sheriffs Sale by first class mail, postage pre-paid to 531 Herman Avenue, Lemoyne, P A 17043 and 5 .... ~"~,~ _'H'._ I, C" " "I, >~-4' Nursery Road #1, Wellsville, PA 17365. Service of the Notice of Sheriffs Sale shall be deemed complete and valid upon mailing by the Plaintiff. GRENEN & BIRSIC, P.C. BY: Kristine M. thou, Esquire Attorneys for Plaintiff One Gateway Center-Nine West Pittsburgh, PA 15222 (412) 281-7650 i' I, [ _I Washington Mutual Home Loans, Inc. flk/a PNC Mortgage, Attorney-In-Fact for PNC Bank, N.A. VS Keith L. Kieffer and Stephanie C. Kieffer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8276 Civil Term R. Thomas Kline, Sheriff, who being duIy sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Keith L. Kieffer and Stephanie C. Kieffer, but was unable to locate them in his bailiwick. He therefore deputized the Sheriffs of York and Dauphin County, Pennsylvania to serve the within Real Estate Writ, Notice and Descriptions, in the above entitled action, according to law. The house at 531 Herman Ave., Lemoyne, PA is vacant. The house at 717 16th St., New Cumberland, PA is occupied by persons named Ward and Johnson. Dauphin County Return: Served defendant, Stephanie C. Kieffer, on July 25, 2002 at 7:35 o'clock PM, by handing to her personally at 2914 Brookwood St., Harrisburg, P A 17111. So Answers: J.R. Lotwick, Sheriff of Dauphin County, Pennsylvania. York County Return: Writ returned Not Found, as to the defendant, Keith L. Kieffer. Defendant moved from 480 Mount Airy Road, Trailer #13, Lewisberry, P A and did not leave a forwarding address with the post office. , . 'Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, states that on July 8,2002 at 1:23 o'clock PM, she posted a true and correct copy of the within Real Estate Writ, Notice, Poster and Description upon the property of Keith L. Kieffer and Stephanie C.Kieffer located at 531 Herman Ave., Lemoyne, PA 17043, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Stephanie C. Kieffer, by regular mail to her last known address of 2914 Brookwood St., Harrisburg, PA 17111. This letter was mailed under the date of August 2, 2002 and never returned to the Sheriffs Office. Sworn and subscribed to before me This _ day of sOi? '~~~f' BY0l"\~ )'nQ-th Real Estate eputy 2002, A.D. Prothonotary Ii, L '" -,,,~ ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME CNIL DIVISION LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. AFFIDAVIT PURSUANT TO P A. R.C.P. 430 COUNTY OF ALLEGHENY ) ) SS COMMONWEALTH OF PENNSYLVANIA ) Before me, a notary public, in and for the foregoing county and commonwealth, personally appeared Kristine M. Faust, Esquire, of GRENEN & BIRSIC, P.C. attorneys for Plaintiff and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of the Defendant, Keith L. Kieffer, named in the above-captioned matter: A. On July 3, 2002, Plaintiff mailed to the United States Postmaster at Lemoyne, P A 17043, a request to be furnished with a forwarding address of Defendant, Keith L. Kieffer. B. On or about July 10, 2002, Plaintiff received a response from the United States Postmaster indicating that the Defendant, Keith L. Kieffer moved and left no forwarding address. A true and correct copy of that response is marked as Attachment "A", attached hereto and made a part hereof. C. On August 6, 2002, Plaintiff mailed to the Uuited States Postmaster at Lewisberry, P A 17339, a request to be furnished with a forwarding address of Defendant, Keith L. Kieffer. D. On or about August 14,2002, Plaintiff received a response from the Uuited States ~~ i' I., _J_ "".~~"""'. Postmaster indicating that the Defendant, Keith L. Kieffer moved to 5 Nursery Road, Wellsville, PA 17365. A true correct copy of that response is marked as Attachment "B", attached hereto and made a part hereof E. Examinations were made ofthe Lemoyne Area Telephone Directory and Wellsville Area Telephone Directory; said examinations failed to yield any useful information regarding the whereabouts of Defendant Keith L. Kieffer. F. Examinations were made of the Cumberland County Voter Registration Records; said examination indicated that Defendant, Keith L. Kieffer is not registered. G. A computer records search of a nationwide database indicates that the Defendant, Keith L. Kieffer, resides at 717 16th Street, New Cumberland, PA 17070-1515. H. According to the Sheriff s return dated August 2, 2002, the property at 717 16th Street, New Cumberland, PA 17070-1515 is occupied by persons other than Defendant Keith L. Kieffer. Finally, affiant deposes and says that after the foregoing investigation, the Plaintiff believes and avers that exact whereabouts of Defendant, Keith L. Kieffer are unknown to Plaintiff. GRENEN & BIRSIC, P.C. BY: ~L~f.;tC(}}L/ Kris me M. Anthou, Esqwre Attorneys for Plaintiff One Gateway Center-Nine West Pittsburgh, PA 15222 (412) 281-5197 Sworn to an subscribed before me this '3~ day of ~~ ,2002. ~,,-.{";....'\ACb ~ Notary Public Notarial Seal Palricia ~. Thwnsend, Notary Public City of Pittsbwgh. AUegheny Counly My ColIIDIission Expires June 2. 2003 Member,l'llnnsylvaniaAssociationor Notaries ~- I' _.: "I~, " """it Date July 3, 2002 @ Postmaster Lemoyue, P A 17043 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new, address or the name and street address (if a box holder) for the following: Name: Keith L. Kieffer Address: 531 Herman Avenue, Lemoyne, P A 17043 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following inform~tion is provided in accordance with 39 CFR 165.6(d)(8)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6( d)(I} and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing hiruselt}:Paralegal 2. Statute or regulation, tP..at empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a'corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: Washington Mutual Home Loans, Inc., f!k!a PNC Mortgage, Attorney-in-fact for ~NC Bank, N.A. V. Keith L. Kieffer and ' Stephanie C. Kieffer 4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County 5,. The docket or other identifying number if one has been issued:00-8276 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service oflegal process in connection with actual or prospective litigation. (\ Signature Christine A. Galvin Printed Name Grenen & Birsic, PoCo, One Gateway Center, Nine West, Pittsburgh, PA 15222 (412) 281-7650 FOR POST OFFICE USE ONLY _ No change of address order on file. _ No,known at address given. ~ved, left no forwarding address No such address. POS1MARK NEW ADDRESS OR BOXHOLDER'S NAME and STREET ADDRESS II , jj, .:i.",j;, 11."; Postmaster Lewisberry, P A 17339 City, State, ZIP Code Date August 6, 2002 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please fumish the new address or the name and street address (if a box holder) for the following; Name: Keith L. Kieffer Address; 480 Mount Airy Road, Trailer #13, Lewisberry, P A 17339 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR I65.6( d)(8)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(I) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing hiruselt):Paralegal 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: Washington Mutual Home Loans, Inc., flkla PNC Mortgage, Attorney-in-fact for PNC Bank, N.A. v, Keith L. Kieffer and'Stephanie C. Kieffer 4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County 5. The docket or other identifying number if one has been issued:00-8276 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant , WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATlON'FORANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENAL TIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for S~7~I.ice of legal pro~ess in connection with actual or prospective litigation. . - ij Signature Christine A. Galvin Printed Name Grenen & Birsic, PoCo, One Gateway Center, Nine West, Pittsburgh, PA 15222 (412) 281-7650 _ No change of address order on file. _ Not known at address given. POSTMARK NEW ADDRESS OR BOXHOLDER'S NAME and STREET ADDRESS S- /Vw5er~ \.Je'l rv! II e -' P ~. \1339 q'r: , 1:'- ,Cl: Cltl lffi , V: '<:Po . J" -""'>!/ FOR POST OFFICE USE ONLY _ Moved, left no forwarding address No such address. \" .z '#- I 11"1' 6~ j, II., CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Motion for Service of the Notice of Sheriffs Sale Pursuant to Special Order of Court and Order of Court was mailed to the following on this Lj~ day of ()~ . ,2002, by first class, U.S. Mail, postage pre-paid: Keith L. Kieffer 531 Herman Avenue Lemoyne, P A 17043 Keith L. Kieffer 5 Nursery Road, #1 Wellsville, P A 17365 GRENEN & BIRSIC, P.C. BY~/~tUl77CU7L- Kris me M. Anthou, EsqUIre Attorneys for Plaintiff One Gateway Center-Nine West Pittsburgh, PA 15222 (412) 281-7650 I. ~~.l, j~~!I$.i1ii~~~iill<&~!l$I!h;i~Hl,f;Ji';";",,,,,,,,,,,,,,,,,-,-;,O"-'""I'!'_1cdi'i:;I;1-",,*~~~lili-~~""'> -- ~~ C__~;W;;W;~ollI~B1.i:~'w.-,." ~~,iIilIIIllIIIlil ~:I 0 C"' 0 C i'J -'1 5~ C) " -0 ~:; C) -'r m !...:-' v~'1 ~'7: '.'}J -;.;- Z r-:--.'- r- I ;,'1 <n .,. -.I ~~3 ~~ ~ --.- ,~ ." ('j , .--, T._j~ Z Q --"- ('5 "~ onl ..s." '-H. :.,;) Z --, >' =< ::0 -< ~ ,.'''''_W. I> " i , I c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA WASHINGTON MUTUAL HOME LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. .." SALE DATE: December 4,2002 CIVIL DIVISION ISSUE NUMBER: NO.: 00-8276 TYPE OF PLEADING: Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS CODE- n 0 0 c: I'V ~''1 $: 0 ."",,1 7'00.J r.> {-;~ ~ ~T1 OJr11 -l _IJ !',~ :;:.i\~ ~~"" tn",,~ -<" -:::3,cJ kC1 -u -"T"" 2?: ~", :JJ:: g~ zt,., ,-,-0 W >c ::=j ~ => '> U1 ~ FILED ON BEHALF OF PLAINTIFF: Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center 9 West Pittsburgh, PA 15222 (412) 281-7650 !,'~-- <=><, , _ JJ ~ ~ , ol.ml",': ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., f/k/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CIVIL DIVISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS Kristine M. Anthou, Esquire, Attorney for Plaintiff, Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A., being duly sworn according to law deposes and makes the following Affidavit regarding service of Plaintiffs notice of the sale of real property in this matter on December 4, 2002 as follows: 1. Keith L. Kieffer and Stephanie C. Kieffer are the owners of the real property and have not entered an appearance of record. 2. On October 11,2002 this Court entered an Order authorizing Plaintiff to serve Defendant, Keith L. Kieffer by first class mail to addresses set forth in the Order, with service to be valid upon mailing. A true and correct copy of the Order is marked as Exhibit "A" attached hereto and made a part hereof. 3. Pursuant to the Order and Pa R.C.P. 3129.2 (C) on October 16,2002 the undersigned counsel served Defendant, Keith L. Kieffer, with a true and correct copy of ~,~ '_"W~ ~ I ~ . Plaintiff's notice ofthe sale of real property by regular U.S. mail postage prepaid, addressed to Keith L. Kieffer, 531 Herman Avenue, Lemoyne, P A 17043 and 5 Nursery Road, #1, Wellsville, PA 17365. True and correct copies of the Certificates of Mailing, evidencing service by certified mail and first class mail on the identified Defendants, are marked Exhibit "B", attached hereto and made a part hereof. 4. On July 8, 2002, Sheriff s Office of Cumberland County posted the property located at 531 Herman Avenue, Lemoyne, PA 17043. A true and correct copy of Sheriffs return of Service is marked Exhibit "C", attached hereto and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information, and belief. GRENEN & BIRSIC, P.C. BY: l/~UL-~M2U Kristine M. Anthou, Esquire Attorneys for Plaintiff Nine West, One Gateway Center Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS~AY OF ~hJt) ,2002. Qq,,)",(\'-, ",,", f\~ \')l\.~ Notary Public Notari.al Seal , . A 'Ii wnsend Notary Public ~~~i~f Piits~urgh, ~ileghJeny ~O~C2'3 M Commission Expires une , Y t . Member, pennsylvamaAssoclation otNo anas J , ~ " l, -j L " I , OCT 0 8 2Uu, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CIVIL DNISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, ~-^""" Defendants. ORDER OF COURT AND NOW, to wit, this I J ~ day of (Je:::r;.L. ,2002, upon consideration of the within Motion for Service of the Notice of Sheriffs Sale Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that the Plaintiff is permitted to serve Defendant, Keith L. Kieffer, by first class mail, postage pre-paid at 531 Herman Avenue, Lemoyne, P A 17043 and 5 Nursery Road, #1, Wellsville, P A 17365. Service on the Defendant shall be deemed complete and valid upon mailing by the Plaintiff. BY THE COURT: Is/ 1~~ r;. IL J. I 1 fRIJE.C..oPY FROM RECORD ~nT~w.:It.;:~ wh6r~"Jf, I herIHiIlio set my hand d'l? !!le ~l of $iill! Cmm il! Ca;1J~Je Pa. fillS Ii ~~~: J;f!J~~t.' ~oc.v I. J l .( qiJ'f _~~~_~__ P!oJ"~nl~~r" ...__ -- -- ~ <~---,~-:~ .1 I. J L ii.l.J.>~t . Received From: One Gateway Genter, Ni~e' West 1J o (f) g rn lIt U.S. POSTAL SERVICE, CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil DOES NOT PROVIDE FOR INSURANCE >.' ~'t: .~ ';(!,~ ,PSForm3817,January2~~~I.I"l/ "~ 1iJ_/ . (j{.f, c<,yp/hletf<< >!->tlff. >t:o-"'.."''''...... /V5()G " Received From: CERTIFICATE OF MAILING U.S. POSTAL SERVICE MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR lNSURANCE-POSTMASlER Grenen & Birsic, EG. o " o (f) c:::> :ti Cl In '" "'.,: ...'.,. .. *.... P$ Fonn 3817, January 2001 .. / /Lk. . (pl.f "J;3iJ'i h l.e~ ;1J05C;t5 \ I , I, , -<I' Washington Mutual Home Loans, Inc. flk/a PNC Mortgage, Attorney-In-Fact for PNC Bank, N.A. VS Keith L. Kieffer and Stephanie C. Kieffer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8276 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Keith L. Kieffer and Stephanie C. Kieffer, but was unable to locate them in his bailiwick. He therefore deputize4.. the Sheriffs of York and Dauphin County, Pennsylvauia to serve the within Real Estate 'Writ, Notice and Descriptions, in the above entitled action, according to law. The house at 531 Herman Ave., Lemoyne, PA is vacant. The house at 717 16th St., New Cumberland, PA is occupied by persons named Ward and Johnson. Dauphin County Return: Served defendant, Stephanie C. Kieffer, on July 25, 2002 at 7:35 o'clock PM, by handing to her personally at 2914 Brookwood St., Harrisburg, P A 17111, So Answers: J.R. Lotwick, Sheriff of Dauphin County, Pennsylvania. York County Return: Writ returned Not Found, as to the defendant, Keith L. Kieffer. Defendant moved from 480 Mount Airy Road, Trailer #13, Lewisberry, P A and did not leave a forwarding address with the post office. . "Dawn L. Kell, Deputy Sheriff, who being duly sworn according to la'Y, states that on JuIy 8, 2002 at 1 :23 o'clock PM, she posted a true and correct copy of the within Real Estate Writ, Notice, Poster and Description upon the property of Keith L. Kieffer and Stephanie C. Kieffer located at 531 Herman Ave., Lemoyne, PA 17043, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Stephanie C. Kieffer, by regular mail to her last known address of 2914 Brookwood St., Harrisburg, P A 17111. This letter was mailed under the date of August 2, 2002 and never returned to the Sheriffs Office. Sworn and subscribed to before me This _ day of so~ ~~~ BY0l"\~ )'nQ-th Real Estate eputy 2002, A.D. Prothonotary !l~~~~~il%~W~,i':!'""';"""'-~""4f;~"''',',L'''~''J'':'!,'<IiiI1iM'lIin~t .n ". ........ , " ~. ~~: i' ;.;, <:) C -:::;;- ~~t &;5; ~.. ~C' J':::~(.~ 'y . -G.... r'-c~ >c :z: =< .", ~ ----.:: i I I I o ,\.~~ :::> n ...... N ';;{ ..-< ?i :!J ,- --,-,1<1 <;10 :-!.-iJ.. '~f(J f;5~ C'srn --I '),,; S) -< " :J!: ~ ::> UJ ,~" "~ c..-. ,..J I: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., f/k/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. SALE DATE: December 4,2002 CIVIL DNISION ISSUE NUMBER: NO.: 00-8276 TYPE OF PLEADING: Pa. R.C.P. RULE 3129.2(c)(2) PURSUANT TO RULE 3129.1 LIENHOLDER AFFIDAVIT OF SERVICE CODE- FILED ON BEHALF OF PLAINTIFF: Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. LD. #77991 GRENEN & BIRSIC, P.C. One Gateway Center 9 West Pittsburgh, PA 15222 (412) 281-7650 I Oojl~J~ , - ."--~- _< ~"u ~-- :: I I ~~" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CIVIL DIVISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, Kristine M. Anthou, Attorney for Plaintiff, Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A., being duly sworn according to law, deposes and makes the following Affidavit regarding service ofthe notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows: 1. By letters dated June 13, 2002, undersigned counsel served all persons (other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 with a notice ofthe sale of real property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit "A", attached hereto, and made a part hereof. ~"-- "I, I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. BY: ~..!,vu.,~a/l.Z/LgV Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 Sworn to and subscribed before me thisJ7\~ay of ~I\ '"'),2002. ~C\,,~,,:"'\ f\~o~ Notary Public Notarial Seal Patricia A, Townsend, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 2, 2003 Member, Pennsylvania AsSOCiation at Notaries I. - - "~,,l ~ J , ! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CNIL DNISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER liiRl STEPHANIE C. KIEFFER, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, Attorney-in-fact for PNC Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Keith L. Kieffer and Stephanie C. Kieffer located at 531 Herman Avenue, Lemoyne, PA 17043 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KEITH L. KIEFFER AND STEPHANIE C. KIEFFER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 531 HERMAN AVENUE, LEMOYNE, P A 17043. DEED BOOK VOLUME 168, PAGE 791, PARCEL NO. 12-22-0822-014. - " . -b . ',_ L . I L '" 1. The name and address of the owner(s) or reputed owner(s): Keith L .Kieffer Stephanie C. Kieffer 531 Herman Avenue Lemoyne, P A 17043 717 16th Street New Cumberland, P A 17070 2. The name and address of the defendants in the judgment: Keith L .Kieffer ",~ 531 Herman Avenue Lemoyne, P A 17043 717 16th Street New Cumberland, P A 17070 Stephanie C. Kieffer 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attomey- in-fact for PNC Bank, N.A. PLAINTIFF 4. The name and address of the last record holder of every mortgage of record: Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney- in-fact for PNC Bank, N.A. PLAINTIFF Citifinancial, Inc. 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 5, The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 P A Department of Revenue Bureau of Individual Taxes Inheritance Tax Division, Dept. 280601 Harrisburg, PA 17128-0601 Department of Welfare Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants 531 Herman Avenue Lemoyne, P A 17043 r;""" I verify that the statements made in the Affidavit are 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.A. 94904 relating to unsworn falsification to authorities. ~~~ Kris me M. Fautt, Esqmre Attorney for Plaintiff SWORN to and subscribed before me this \ ~ day of ~ , """ -, , 2002. ~~l.l'~C"'b"-, fj.~ ."Th~ Notllf1 Public Notarial Seal Patricia A. Townsend, Notary Pablic City nf PitlSburgb, Allegbeny CouOll3 My Commission Expires June 2. 2 Member, pennsyivanJaAssOClatiOnof NotarieS ._<"-~" - ,-. i , I , "0 ! ~ \ ~ I ~ 1E;'.lii ~I~~ ~~ \AI 6' ,.::t' Itv ~ t G) en Cil 0" ::J c:: '" '" ~ '< ::J <g.C':)Qo '" co ~ ~ "'. '" en -4~""""'l C:;" CJ1z ~ 5":U 1'.>",0 ~. en\'.3il o , o 1l. il !l. o " 5' o " 3 ~ . o o ill ~ o ?r o ::J '" ""U~G) aar@ ~:E:::i c:: ~ ~ ~ =r0 '" ~a '" ~ ~ RjZ I'.> ::J 1'.>'" : 38'v'lSOd'S-n . . I ,~ : i : r L': r,,?). ., " _ ~ _ I~'/"A ~ 'l'l ;". "i ~ ..-'V' " .......... ~;-"::::;':;:.':"-';"';;:' -::.",~-"};(..., ',<> " ..-__.."O___.-=~~} r"~ ~ r-=====~~ ' ~~ c if Sm !:f.l s;l: om ""0 ~ mc 0 . "'O"'m '" a. ::tIO -1> a' R ~Cl r- c;o m ~g ~ ~~ 0 ~g m "1~ j;:! "'Z -l-l mm '":l! ~ ~ ~ j; F ~! c ~ s.. 9> om "0 1 ~~ ~ "T1 ::tIO i! ~ z~ r- ~::tI m ~g ~ t5~ 0 ~gj m 00 "1~ ,",0 /j;z ~ii1 (') '"<i/ m ~ ~ o ~ j; n i ~ r 0 g "II ~ ~ ~ C z Gl ,~ . ,.' ~ I ~ ". _:l<lIo.ol 1,.,,_... ~-;",' U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Grenen & Birsic, P.C. . une Gateway Genter, Nine West t'IUsourgh PA 15222 . Oci6hm~~M ' 3Lbr ltari~ f)fii/e. CalYJdhlljJ,4 /70// ' . ..~.. 'U o <" i] 10 1m, '5lde IJh U1 .11 *11-*........11-........... PS Form 3817, January 2001 /1/- &t-J..3~/ni~ A1S 010 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAll, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Grenen & Birsic, P.C. One Gateway Center, Nine e Pittsburgh PA 1522 ,'" One piece of ordinery mail addressed 10: ~ut};'ld/J1. ~17( l&/rdJdM IN), ~ 3){) . {tJrft5/~, f1A 17D/3 . 'c: in ]6 (f) LJ"l > III ::ril .... >l- 'l-" ... >l-,. >+ .. .. ~ PSForm3817,Jan7'll~jp}lhiw &os U1G U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: I~I :01 .5;1 :;; Cl 111 .1. ~ Ul .11 ",..*........>1-*.0-*-..* Ofr::, -.' r"~ I I I ! ! I r' ~ It: ~ . )Ii /'I 1'1 U r I I f":'" I;.'j "':'I~ tl-)' 1":) -'.;.s> ..... .., .... '!:1.1 l:tt \ '! I I 11-. ~i _ II: Ij~ il? ", I' Ii- I! Ii ; L:: '. \=- I r I L t' \c". I" ~i r-"'-">-J " w" S ......::> o ::r: ~ ;i " ..., " .... on - ::> ~ '0'" :J>::> ......:J> .....,< 0" ~::> we " DODO '22;1:10- C::CQ-IZ Z-Ic:n-lc:n =~~;~ J;;!:::!Ic:; """,<zm- o;=c~ 'TI'=- == Z.... ~~~~;IIo ;!mS!;IIl:g >=-c:nZ:a :ac:n....cm c=-:a::c:n cmzf'.n !il!!l lJl ~'; co ' m 0 CI -0 '" m '" '\ o (I":"' ;0. _I 1.\ ,n_,! ::l!OO ...,;:t ~ ~ ('D tl'1 ifot7;! a<l~Z ::r"""" - =<i ". ~~ ~ ......o~ ,-,," ...... NgO N" - N....I-f "1:1 'DO ~. " on ..., t:::1 ,-... ...,... a :_:_1 ,..- r~i ((I --001 ::C:' -001 ..,., ::i: ,-... ." .,;j (I) ...... Ul r.,':J ~~~,. "" c-'~ ~ ), ::;~ . .~~",1 Ii "":OB'~."F"";";-' ,-,1 ~~.~ .,.'''....1 1C I -~~_. J 11'''01' r'i', ' ..,;1 ..... . . ~l 101 ~ i' rwi '....t 1-"'11 [:r;:! ~ Idl !~I ".p,.!_M "" It * .. ,. -'l- * ". ". ~ .. . * ~ ~~ ~ , , ""';.,o-~~,! COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which EMC Mtg Corn is the grantee the same having been sold to said grantee on the 4th day of Dee A.D., 2002, under and by virtue of a writ Execution issued on the 12th day of June, A.D., 2002, out ofthe Court of Common Pleas of said County as of Civil Term, 2000 Number 8276. at the suit of Washington Mutual Home Leans Inc fka Pnc Mtg against Keith L Kieffer & Stephanie Cis duly recorded in Sheriffs Deed Book No. 255, Page 353. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ;l,31l J.. day of h..u..- , A.D. 2002 ~o!3. ~k-o ~,.~ f ecorder of Deeds CountY, CarlISle, PA l\eOOfdOl"oI~.,Cum~~oIJan.2llOlI My eommlSS1nn e<pilO5 1\1 ~~'~^"-. . - II J ., ~~~-lt; Washington Mutual Home Loans, Inc. flk/a PNC Mortgage, Attorney-In-Fact for PNC Bank, N.A. VS Keith L. Kieffer and Stephanie C. Kieffer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8276 Civil Term R. Thomas Kline, Sheriff, who being duIy sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Keith L. Kieffer and Stephanie C. Kieffer, but was unable to locate them in his bailiwick. He therefore deputized the Sheriffs of York and Dauphin County, Pennsylvauia to serve the within Real Estate Writ, Notice and Descriptions, in the above entitled action, according to law. The house at 531 Herman Ave., Lemoyne, PA is vacant. The house at 717 16th St., New Cumberland, PA is occupied by persons named Ward and Johnson. Dauphin County Return: Served defendant, Stephanie C. Kieffer, on July 25, 2002at 7:35 o'clock PM, by handing to her personally at 2914 Brookwood St., Harrisburg, PA 17111. So Answers: J.R. Lotwick, Sheriff of Dauphin County, Pennsylvauia. York County Return: Writ returned Not Found, as to the defendant, Keith L. Kieffer. Defendant moved from 480 Mourtt Airy Road, Trailer #13, Lewisberry, PA and did not leave a forwarding address with the post office. Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, states that on July 8, 2002 at 1 :23 0' clock PM, she posted a true and correct copy of the within Real Estate Writ, Notice, Poster and Description upon the property of Keith L. Kieffer and Stephanie C. Kieffer located at 531 Herman Ave., Lemoyne, P A 17043, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Stephanie C. Kieffer, by regular mail to her last known address of 2914 Brookwood St., Harrisburg, PA 17111. This letter was mailed under the date of August 2, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvauia, on December 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Attorney Kristine M. ~thou for EMC MortgageCorporation. It being the highest bid and best price received for the same, EMC Mortgage Corporation of 909 Hidden Ridge Drive, Suite 900, Irving, Texas 75038, being the buyer in this execution paid SheriffR. Thomas Kline the sum of$I,016.03, it being costs. ,1 ..'. ~.. ~ ~~-~ ~~ ~_. Sheriffs Costs: Docketing 30.00 Poundage 20.66 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1. 00 Mileage 33.81 Certified Mail 4.95 Levy 15.00 Surcharge 30.00 Out of County 18.00 York County 37.90 Dauphin County 29.25 Law Journal 344.45 Patriot News 270.55 Share of Bills 25.20 Distribution of Proceeds Sheriffs Deed 25.00 40.50 $1016.03 1_- dji s~orn and Subscribed to Before Me So ~ ~ ThIS 03 DaYO~""7 ~ . ~ R. Thomas Kline, Sheriff 20W,A.D. (2 ~,~ BU J. Ji.. \c At rothonotary NJJUY--I ~ Real Estate Joeputy ~~ ~<.O'oV/O ,,~ \ ,s \:..It.."'~ \ . 16.v' /yPJ.'( . . i I , "~ . .' " . , , . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., f/k/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CNIL DNISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) . Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage, Attorney-in-fact for PNC Bank, N.A., Plaintiffin the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information conceruing the real property of Keith L. Kieffer and Stephanie C. Kieffer located at 531 Herman Avenue, Lemoyne, PA 17043 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KEITH L. KIEFFER AND STEPHANIE C. KIEFFER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 531 HERMAN AVENUE, LEMOYNE, P A 17043. DEED BOOK VOLUME 168, PAGE 791, PARCEL NO. 12-22-0822-014. ~~ I, .' . Jo . 1. The name and address of the owner(s) or reputed owner(s): Keith L .Kieffer 531 Herman Avenue Lemoyne, P A 17043 Stephanie C. Kieffer 717 16th Street New Cumberland, P A 17070 2. The name and address ofthe defendants in the judgment: Keith L .Kieffer 531 Herman Avenue Lemoyne, P A 17043 Stephanie C. Kieffer 717 16th Street New Cumberland, PA 17070 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney- in-fact for PNC Bank, N.A. PLAINTIFF 4. The name and address of the last record holder of every mortgage of record: Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney- in-fact for PNC Bank, N.A. PLAINTIFF Citifinancial, Inc. 3401 Hartzdale Drive, Suite 126 Camp Hill, P A 17011 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 P A Department of Revenue Bureau of Individual Taxes Inheritance Tax Division, Dept. 280601 Harrisburg, P A 17128-0601 Department of Welfare Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 L~ J~ ~.....,,_, -~~ -" I; . . . . 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants 531 Herman Avenue Lemoyne, P A 17043 I verify that the statements made in the Affidavit are 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.A. 94904 relating to unsworn falsification to authorities. Kristme M. Fa t, EsqUire Attorney for Plaintiff SWORN to and subscribed before me this \ ~ day of ~ . ~,,--..., ,2002. n.c."'ir-~0b-""'" A~ Q"\t\~ Not3r Public Notarial Seal . Patricia A. Townsend, Notary PublIc City of Pitlsbwgb, Allegheny Cou~3 My Commission Expires June 2, 2 Member, PennsylvanlaAssOClatlonofNotartes l. .< *'- -,......-~. _.~ L; I. _J \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME CIVIL DNISION LOANS, INC., f/k/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC NO.: 00-8276 BANK, N.A., Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Stephanie C. Kieffer 717 16th Street New Cumberland, PA 17043 TAKE NOTICE that by virtue of the above Writ of Execution issued out ofthe Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISE, P A 17013-3387 on September 4, 2002, at 10:00 A.M., the following described real estate, of which Keith L. Kieffer and Stephanie C. Kieffer are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KEITH L. KIEFFER AND STEPHANIE C. KIEFFER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 531 HERMAN AVENUE, LEMOYNE, P A 17043. DEED BOOK VOLUME 168, PAGE 791, PARCEL NO. 12-22-0822-014. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure i I _,;""""'....;l,. , -~..'- . , " . , ~ll;W_,t; action of Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A., Plaintiff, vs. Keith L. Kieffer Defendants at Execution Number 00-8276 in the amount of $77,589.74. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriffno later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the time and place of sale. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. CUMBERLAND COUNl'Y BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 800-990-9108 You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. J ~""~ II ~ ~'" . . If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. Ifthe judgment is opened the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriffhas not made a valid return of service ofthe Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELNER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. ~ /~7 By:J~L ,x L/,:>C:J.u(p-i'; 2-c-_ Kristine M:"~ Faust, Esquire Attorney for Plaintiff " , I lI;~l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME CNIL DIVISION LOANS, INC., flk/a PNCMORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. LONG FORM DESCRIPTION All that certain piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the northerly line of Herman Avenue on the dividing line between Lots Nos. 36 and 37, Section D, on the hereinafter mentioned Plan of Lots; thence North 31 degrees West along said dividing line, a distance of one hundred fifty (150) feet to the southerly line of Peach Alley; thence along the southerly line of Peach Alley North fifty-nine degrees East, a distance of seventeen and five tenths (17.5) feet to a point; thence South thirty- one degrees East through a partition wall between the premises herein described and the house to the East a distance of one hundred fifth (150) feet to the northerly line of Herman Avenue; thence along the northerly line of Herman Avenue South fifty-nine degrees West, a distance of seventeen and five tenths (17.5) feet to the dividing line between Lots Nos. 36 and 37, Section D, on the hereinafter mentioned Plan of Lots, at the point or place of beginning. Being the westerly half of Lot No. 37, Section D on Plan No. I of Riverton as recorded in the Cumberland County Recorder's Office in Deed Book "J", Volume 4, Page 40. Known as No. 531 Herman Avenue, Lemoyne, Pennsylvania. Being the same premises which Mary S. Franklin, a widow, by her attorney-in-fact, Joan A. Krasevic, by Deed dated November 28, 1997 and recorded in the Recorder of Deeds of Cumberland County on December 1, 1997 in Deed Book Volume 168, page 791, granted and conveyed unto Keith L. Kieffer and Stephanie C. Kieffer, his wife. Parcel #12-22-0822-014 GRENEN & BIRSIC, P.C. ..' . aLP By: . ,r1>t.(..7r eLL- /\. y~L.- Kristine M. Faust, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 ,,,,,,,,,,,,,~ - _.1 l~i; ~. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., CNIL DNISION NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Keith L. Kieffer 531 Herman Avenue Lemoyne, P A 17043 TAKE NOTICE that by virtue of the above Writ of Execution issued out ofthe Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISE, P A 17013-3387 on September 4, 2002, at 10:00 A.M., the following described real estate, of which Keith L. Kieffer and Stephanie C. Kieffer are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KEITH L. KIEFFER AND STEPHANIE C. KIEFFER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 531 HERMAN AVENUE, LEMOYNE, PA 17043. DEED BOOK VOLUME 168, PAGE 791, PARCEL NO. 12-22-0822-014. '-,/c The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Washington Mutual Home Loans, Inc., flk/a PNC Mortgage, attorney-in-fact for PNC Bank, N.A., Plaintiff, vs, Keith L. Kieffer Defendants at Execution Number 00-8276 in the amount of $77,589.74. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriffno later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the time and place of sale. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically ofthese rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE TillS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 800-990-9108 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale ,'"~' ~ I~, ~ " I, .' occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. Ifthe judgment is opened the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HA VB THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. By: 4JL(~~ac-~ Kristine M. Faust, Esquire Attorney for Plaintiff , , ~, ~ '''' I'l:;.,a, - " I. . J. ~_ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME CML DNISION LOANS, INC., flk/a PNC MORTGAGE, ATTORNEY-IN-FACT FOR PNC BANK, N.A., NO.: 00-8276 Plaintiff, vs. KEITH L. KIEFFER and STEPHANIE C. KIEFFER, Defendants. LONG FORM DESCRIPTION All that certain piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the northerly line of Herman Avenue on the dividing line between Lots Nos. 36 and 37, Section D, on the hereinafter mentioned Plan of Lots; thence North 31 degrees West along said dividing line, a distance of one hundred fifty (150) feet to the southerly line of Peach Alley; thence along the southerly line of Peach Alley North fifty-nine degrees East, a distance of seventeen and five tenths (17.5) feet to a point; thence South thirty- one degrees East through a partition wall between the premises herein described and the house to the East a distance of one hundred fifth (150) feet to the northerly line of Herman Avenue; thence along the northerly line of Herman Avenue South fifty-nine degrees West, a distance of seventeen and five tenths (17.5) feet to the dividing line between Lots Nos. 36 and 37, Section D, on the hereinafter mentioned Plan of Lots, at the point or place of beginning. Being the westerly half of Lot No. 37, Section D on Plan No.1 of Riverton as recorded in the Cumberland County Recorder's Office in Deed Book "J", Volume 4, Page 40. Known as No. 53 I Herman Avenue, Lemoyne, Pennsylvania. Being the same premises which Mary S. Franklin, a widow, by her attorney-in-fact, Joan A. Krasevic, by Deed dated November 28, 1997 and recorded in the Recorder of Deeds of Cumberland County on December I, 1997 in Deed Book Volume 168, page 791, granted and conveyed unto Keith L. Kieffer and Stephanie C. Kieffer, his wife. GRENEN & BIRSIC, P.C. Parcel #12-22-0822-014 . ~ ." , . "" ,'.1 I. .' ~ ' . By: .r7/(v7rCK-.c.., ~L-- Kristine M. Faust, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 i. ~--~, , ~~ .....L - "-, WRIT OF EXECUTION and/or ATTACHMENT < COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-8276 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, INC., F/KJA PNC MORTGAGE, A TTY -IN-FACT FOR PNC BANK, NA PLANTIFF(S) From KEITH L KIEFFER, 531 HERMAN AVE., LEMOYNE P A 17043 and STEPHANIE C. KIEFFER, 71716THST.,NEWCUMBERLAND PA 17070. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESSTATE LOCATED AT 531 HERMAN AVE., LEMOYNE PA 17043 (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 gamishee(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 ofthe 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 Ii named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Arty's Comm % L.L. $.50 Due Prothy $1.00 Other Costs Amount Due 69,833.30 Interest $7,756.44 Artypaid $178.46 Plaintiff Paid Date: JUNE 12,2002 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name KRlSTINEM.FAUST,ESQ. Address: ONE GATEWAY CENTER, 9 WEST PITTSBURGH PA 15222 Attorney for: PLAINTIFF Telephone: (412) 281-7650 Supreme Court ill No. 77991 ~;Ci'-' c~~:Iii'i.w--"''''Ii:'~''''''iiItl!.i,;L~~l'I>'_Il.,-'lH',.j&<'>M.iUtlM\''lWir"ji,'~~~&H>lJ,"'';:lftll~;jlj~_1il > ,. ~.~,""'. -"'~OOlIliiIt1l..,.ml~ , Real Estate Sale # 55 On June 17, 2002 the sherifflevied upon the defendant's interest in the real property situated in the Borough of Lemoyne, Cumberland County, P A known and numbered as 531 Herman Avenue, Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 17,2002 By: JocU.f ~ Real Estate Deputy ". -! I. C' ',.!:1,d \' \.' - " I "-,' C' " :::~ liD (, \1llmr ^.~i';; \ ,; I <':-'~no ;!;!lH;W: ;j .J ..:0 j;;l.:l.iO ~I- '~, '...','....~....... -~, III REAL ESTATE SALE NO. 55 Writ No. 2000-8276 Civil Washington Mutual Home Loans, Inc. f/kJa PNC Mortgage. Attomey-ln-Fact for PNC Bank. N,A v.. Keith L. Kieffer and Stephanie C. Kieffer Att::r,: Kristine M. Faust LONG FORM DESCRIPTION All that certain piece or parcel of land situate in the Borough of Le~ moyne, County of Cumberland and State of Pennsylvania. more particu~ lady bounded and described as fol- lows. '" wit: Beginning at a paint on the north~ erly line of Herman Avenue on the dividing line between Lots Nos. 36 and 37. Section D. on the hereinaf~ ter mentioned- Plan of-~Lots; thence North 31 degrees West along said dividing line, a distance of one hun- dred fifty (150) feet to the southerly line of Peach Alley; thence along the: southerly line of Peach filley North fifty-nine degrees East. a ~Ustance of seventeen and five tenths (17.5j feet to a point: thence South thir1;y- one degrees East through a parti- tion wall between the premises ' herein described and the house to the East a distance of one hundred" ruth (150) feet to the northerly line ofHe:rman Avenue; thence along the northerly line of Herman Avenue South fifty-nine degrees West. a dis- tance of seventeen and five tenths (17.5) feet to the divtding line be- tween Lots Nos. 36 and 37. Section ' D. on the hereinafter mentioned Plan of Lots, a~ "tl1e _pqir!t or place o{ beginning. Being the westerly half of Lot No. 37. Section D on Plan No. 1 of Riv- erton as recorded in the, Cumberland County Recorder's Of- fice in Deed Book "J", Volume 4.' Page 40. . Known as No. 531 Herman Ave- nue, Lemoyne, Pennsylvania Being the same premises which Mazy S. Franklin. a widow, by her attorney-in-fact. Joan A Krasevic. by Deed dated November 28. 1997 and recorded in the Recorder of Deeds of Cumberland County on December 1. 1997 in Deed Book Volume 168. page 791. granted and conveyed unto Keith L. Kieffer and Stephanie C. Kieffer. his "'"ife. ~~~- , , je - : ~ , . _~_ _ . PROOF OF PUBLICATION OF NOTicE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JULY 26, AUGUST 2,9,2002 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subj ect matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~itor SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 LOIS E.SNYDER. Notary PublIc CaIlIsIe Boro, CUmber1anil County My COmmIBBIDII ExplM Ma1d15. 2005 -C--REAL EStATE SALE No. 55-- . .Will!io;200(F!j216 . ClvllTerm' . Washington Mutual . Home Loans,lnc. flkla PNC Mortgage, Att()1ney..In~Fact for Pfo/C Bani<, NA . vs , . . , , . . Keith L. Kieffer and StephanI' C.-Kieffer Atty: Kristine M. Faust DEsCRIPTION ALL THAI-CErp'AIN piece or parcel. of land situate in the Borough of Lemoyne. County of Cumberland and State: of Pennsylvania. .more : : pamcularly bounded and described as follows, to wit: . . BEG~1NG at a point on the northerly line of Herman Avenue on the dividing line between Lots Nos, 36 aud 37, Section 0, on the hereillafter mentioned Plan, of Lqts; thence North 31 degrees West along said dividing line, a distance of one hundred fifty (150) feet to the SQulhe:rly line of P-each.AIley; thenc;e .along the southerly line of ?~cll Alley North fifty-nine degrees Eas~ a {Ustaru:eot'.sevenleen and (Lve: tenths (17.5) feet to a point; thence South thirty-one degrees East through a pamtton wall between the premL~es nerein described and the house to the East a distance of one hundred fifty (150) feet to the northerly line of Herman Avenue; thence along the northerly l~e of Herman AI/enue Souili fifty" nine degrees W~t, a distance of seIIenteen and five-tenths (17,5) feet to the dividing line between Lols Nos. 36 and 37, Secnon D,on the hereinafter mentioned Plan of Lots, at the point or place of BEGINNING, BEING the weslSlrly balf of Lot no. 37, section D on Plan No. 1 of, Riverton as feC(lrded in the Cumberland Coun[y Recorder's Office in Deed Book "1", Valume4; Page 40. KNOWN as No> 531 [ierman Avenue, Lemayne, Pennsylvania. BEING the same premise!. which Mary S. FrankTIn, a widow, by her attomey-in-fact,Jaan A. KraSel/jc, by Deed dated November 28,1997-ll1ld recordcd ill the :Recorder of Deed, of Cumberland County on December t, 1997 in Deed Book Volume 168, page 791,,grnnted and conveyed unto Keith L Kieffe.t and Stephanie C, KIeffer, his Wife": _Par<cl#12c22,0822,o.IA,_ ~ ., '\ , " . I ~ "_ L~<; ~ , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the 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..I!!.e. !;undav 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 securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th day(s} of August 2002. 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 the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", V;I~:~I~:~:~~' ~..jz......................................................... COpy Sworn to and subscribed this 14th daY~f ugus 02 A.D. S ALE #55 Nolanal Seal Terry L Russell, Notaf\l Public City Of Hamsburg, Dauphin Coun My Commission Expires June 6, 2006 NOT RY PUBLIC Member,p.nn.y\V.nl.Associ.tionOfNota~y commission expires June 6, 2006 CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERLAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 , Statement of Advertising 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 $ 268.80 1.75 270.55 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By....................................................................