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HomeMy WebLinkAbout01-2994 FX !ill - ~~ j l j .1. - ~ --""<", ~ _ _ I ." _ : -:~ _-LI~ , FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 STANDARD FEDERAL BANK 4242 NORTH HARLEM AVENUE NORRIDGE, IL 60634-1283 COURT OF COMMON PLEAS CIVIL DIVISION ATTORNEY FOR PLAINTIFF Plaintiff TERM NO. 01 - ;l99'l Ctu~ tT'tI2..1[ v. CUMBERLAND COUNTY ROBERT THRUSH 1009 ROCKLEDGE DRNE CARLISLE, PA. 17013 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **TIDS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIDS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 060891588] ~ " I-I ,IJJ -, ,-- ,l~ ~";;;';;;-4:; 1. Plaintiff is STANDARD FEDERAL BANK 4242 NORTH HARLEM AVENUE NORRIDGE, IL 60634-1283 2. The name(s) and last !mown addressees) of the Defendant(s) are: ROBERT THRUSH 1009 ROCKLEDGE DRNE CARLISLE, PA. 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6i2i99 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAlNTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1548, Page 676 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 1/1/0 I and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit" A." ---., , , I~I ~""- ....1 i__. ''''';0,- 6. The following amounts are due on the mortgage: Principal Balance Interest 12/1/00 through 5/li01 (per Diem $22.05) Attorney's Fees Cumulative Late Charges 6/2/99 to 5/1/0 I Cost of Suit and Title Search Subtotal $123,807.36 3,351.60 4,000.00 229.12 550.00 $131,938.08 Escrow Credit Deficit Subtotal TOTAL 685.03 0.00 ($ 685.03) $131,253.05 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. gl680A03c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $131,253.05, together with interest from 5/1/01 at the rate of $22.05 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~p l4vv__- /s! Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ...... .." '8' ~ ~- . When recorded mail tOt S~AHDARD FBDBRAL IlAHX 2600 W. BIG &BAVER RD. TROY, JlICHlGAN 48084 LOAD ,. 608915881 Parcel Number: 10 ~,5Z.3 - D& ();).- tJ3J- [Space AbGwe This Une For Recordlnl Datal MORTGAGE THIS MORTGAGE ("Security Instrument") is given on Jll!IE 2, 1999. ROBERT THRUSH, AD UllMARRIBD MlIII The mongagor is ('"Borrower"). This Security Instrument is given to S~IIRDARD FEDERAL IlABK, A FEDERAL SAVIBGS IlABK existing under Ibe laws of THE ll!IITED STATES OF AMERICA and whose address is 2600 If. BIG BEAVER RD., ~ROY, MICHIGAN 48084 which is organized and (" Lender"). Borrower owes Lender the principal sum of ONE HUNDRED THIRTY ONE THOUSAHD FIVE Ull!IDRIlD IIRD BO/I00* *****.**-**************_..************..*******.......*.**.***....************** D~lan (U.S. $131,500.00 ). This debt is evidenced by Borrower' s note dated the same date as this Security InslIUment ("Note"), which provides for monthly paymenIS, with the full debt, if not paid eaIlier, due and payable on JULY I, 2014. This Security Instrument secures to Lender: (a) \he repayment of the debt evidenwl by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (0) the perfonnance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mongage, grant and convey to Lender the following described property located in CUMBERLAIlD County, Pennsylvania: . "See Legal Description" which has the address of 1009 ROCltLl!:DGE DR, CARLISLl!: {S\r<Ct,CilYI, Pennsylvania ("Property Address"); 17013 {ZipCadej 'Ze'1 PALOEED 'OJ PENNSYLVANlA. Single F...uly .FNMAlFHLMC UNIFORM INSTRUMENT F..... 303"190 Ammdod 511>1 Page I of 6 IniUals. PALDEED - ~,w,,,,-'-'-- .~ ..., - ,-, LOAN t. 608915881 TOGETIiER WITH alllhe improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereaftera pall of the property. All replacements and additions shall also he covered by this Security Instrument. All oflhe fo>egoing is referred to in lhis Security lnsllUment as the "Property." BORROWER COVENANTS that Borrower is lawfully seisedoCtheestate hereby conveyed and has the righlto mortgage, gIant and convey the Propertyandthatthe Propertyis unencumbered, =eptforencumlmmcesofrecord. Borrowerwammtsandwill defend generally the title 10 the Property against all claims and demands, subject to any enewnbfll1l<eS of n:cord. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-unifotm covenants wilb limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agRe as follows: 1. Payment of Principal and IDterest; Prepayment and Late Charges. Borrower shall promptly pay when due the principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Nole. 2. Funds for Taes and IIt...raltee. Subject to applicable law or 10 a written waiver by Lender, Bonower shall pay to Lender on the day motllhly payments are due under the Note. until the Note is paid in full, a sum ("Funds") for: (a) yearly taxes and assessments which mayaltain priority overthis Secarity Instrument as a lien on the Property; (b)yearly leasehold payments orground rents on the Property, if any; (c) yearly hazard orproperty insul8DCepremiums; (d)yearlyflood insurance premiums, ifany; (e) yearly mortgage insuranceptemiums, ifany; and(f) any sums payableby.Borrower loLender, inactardancewiththeprovisionsofparagraph 8, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow t.ems. " Lender may, at any lime. \:OIleet and hold Funds in an amauntllO\ 10 exceed the maximum alllGUnl a lender for a federally related mollgage loan may require for . Borrower'sescro\V aceount under the federal Real Estale Setllement Procedures Act of 1974 as amended from time to time, 12 U.S.C. Section 260 I el seq. ("RESPA "), unless another law that applies to the Funds selS a lesser amount. If50, Lender may, at any lime, collect and hold Funds in an amounl not 10 exceed the lesser amount. Lender may estimate the amount of Funds due on the basis of currenl data and reasonable estimates of expendilllres of future Escrow Items or otherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is such an inslitution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may nOl charge Bonowerfor holding and applying the Funds, annually analyzing theescrow aCtOUll\, or verifying lheEscrow Items, unless Lender pays Bonower inlerest on theFunds,md applicable Iawpennils Lender to make such a charge. However, Lender may require Bonowerto pay a one-lime charge for an independent real eslatetax repolling service used by Lender in connectionwith this loan. unless applicable law provides otherwise. Unless an agreement is madeorapplicablelaw requires interesllo be paid, Lender shall not be requiJed to pay Bonower any interest or earnings on the Funds, Borrower and Lender may agree in writing. however, that inteteSl shall be paid on Ihe Funds. Lender shall give 10 Borrower, without charge, an annual accounting of the Funds, showing credits and debits to the Funds and the purpose for which each debillo lhe Funds was made. The Funds are pledged as additional security for all sams secured by lhis Security Instrument. If the Funds held by Lender exceed the amounts permilled 10 be held by applicable law, Lender shall aecounllO Borrower for Ihe excess Funds in accordance with the requirements of applicable law. If the amount ofthe Funds .held by Lender at any time is nol sufficienl 10 pay the Escrow Items when due, Lender may so notify Bonower in writing, and, in such case Borrower shall pay 10 Lender the amount necessary to make up the deficiency. Borrower shall make up the deficiency in no more than lwelve monlhly payments, al Lender's sole discretion. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund 10 Bonower any Funds held by Lender. If, under paragraph 21, Lendershall acquire or se/llhe Property. Lender, prior to the acquisition or sale oflbe Property, shan apply any Funds held by Lender allhetime of acquisition or sale as a credilagainstlhesums secured by this Security Instrument. 3. Application of Payments. Unless applicable law provides olherwise, all payments received by Lender under paragraphs I and 2 shall be applied: first, 10 any prepaymenl charges due under the Nole; second, 10 amounts payable under paragraph 2; third. 10 interest due; fourth, 10 principal due; and Iasl, to any late charges due under Ihe Note. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property which may allain priority over lhis Security Inslrument, and leasehold payments or ground renls, ifany. Borrower shall pay Ihese obligalions in the manner provided in paragraph 2, or ifnol paid in Ihat manner, Borrower shall pay Ihem on time di~y to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraph. If Borrower makes these payments directly, Borrower shall promptly furnish 10 Lender receipts evidencing the payments. Borrowershall promptly discharge any lien which has priorilyover thisSccurity Instrument unless Borrower: (a) agrees in writing 10 the paymenl of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good failh the lien by, or defends against enforcement of the lien in. legal proceedings which in the Lender's opinion operate 10 preventlhe enforcemenl of the lien; or (c) secures from the holder of the lien an agRement satisfactory to Lender SUbordinating the lien to Ihis Security Inslrument If Lender determines lhat any pall of the Property is subject to a lien which may attain priority over this Securily Instrument, Lender may give Borrowera notice identifYing the lien. Borrower shall satisty the lien or take one or moreofthe actions set forth above within 10 days oflhe giving of notice. PENNsYI. V ANI,\- sinal. Family -FNMAlFIIILMC UNIFORM INSTRIlMENT F.... 303"190 Amended 5191 Page 2 of 6 Initials. _~L-1 PALDEED ~I;;;I!'~= ~ ~''IiiI LOAN II 608'15881 5, Huard or Property Insurance. Borrower shalllceep the improvements now existing or hereafter erected on the Property insured against lass by fire, hazards included within the term "extended coverage" and any other hazards, including /loads or flooding,ior which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's approval which shall DOl be unreasonably withheld. If Borrower fails to maintain coverage deseribed above, Lender may, at Lender's option, obtain coverage to protect Lender's rights in the Property in accordance with paragraph 7. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. In the event of/oss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lenderand Borrowerotherwise agree in writing, insuranceproceedsshaU beapplied toreslOrationorrepairoftheProperty damaged, iflhe restoration or repair is economically feasible and Lender's security is not lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whetherornotlhendue, withanyClCCCSs paid to Borrower. IfBorrowerabandonstheProperty, ordoesnotanswer within 30 days a notice from Lender that the insurance carrier has offered to sellle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not then due. The 30.ooy period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the moruhly payments referred to in paragraphs I and 2 or change the amount of the payments. lfunder paragraph 21 the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from damage to the,Property prior to theacquisition shall passtoLenderto theextentofthesumssecuredbythisSecurity InstrumentinunediatelypriorlOtheacquisition. 6. Ckcupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in defaull if any forfeiture action orproceeding, wbether eivil oreriminal, isbegun thatinLender's good faithjudgmentcouldresultin forfeiture of the Property or othClWisemateriallyimpair the lien created by this Security Instrument or Lender's security interest. Borrower may cure such adefault and reinstate, as provided in paragraph 18, bycausing the action orproceeding tobedismissed witharuling that, in Lender'sgoodfaithdetennination, precludes forfeiture oC the Borrower's interest in the Property or other material impairment of the lien ereated by this Securily Instrument or Lender's security interest. Borrower shall also be in default if Borrower, during the loan application process, gave lIIaterially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with all theptovisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the Cee title shall not merge unless Lender agrees to the merger in writing. 7. Protection of Lender's Rlgbts in the Property. If Borrower fails to perform the covenants and agreements contained in this Security Instrument, orthere 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 value 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, appearingincourr, paying reasenable allOmeys' fees and entering on the Property to make repairs. Although Lender may takeaclion under this paragraph 7, Lender does not have to do so. Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Securily Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the date of disbursement atlhe Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 8. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this Security Instrument, Borrower shall pay thepreruiums required to maintain the mortgage insurance in effect. If, forany reason, the mortgage insurance coverage required by Lender lapses or ceases to be in, effect, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the mortgage insurance previously in effeet, at a cost substantially equivalent to the cost to Borrower of the mongage insurance previously in effect, from an alternate mortgage insurer "Wraved by Lender. If substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Lender each month a sum equal to one-twelfth of the yearly mortgage insurancepreruium being paid by Borrowerwhen the insurance coverage lapsedorceasedto beineffect. Lenderwill ~ccept, use and retain these payments as" loss reserve in lieu of mortgage insurance. Loss reserve payments may no longer be reqUIred, at the option of Lender, if mortgage insurance coverage (in the amount and forthe period that Lender requires) provided by an insurer approved by Lender again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage IniHals. _gc -r PAlDEED PENNSYLV ANlA- Sind_ family .FNMA/lIllLMC UNIFORM INSTRUMENT Fono 303' '1')/) Am.......s 5191 Page 3 of 6 -" LOAN II 608'15881 insurance in effect, or to provide a loss reserve, unlillhe requirement for mortgage insurance ends in accordance with any wrillen agreement between Borrower and ]Lender or applicable law. 9. Inspection, Lender or its agent may make reasonable entries upon and inspections oflhe Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 10. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condentnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid 10 Lender. In theeventofa total taking of the Property, the proceeds shall beapplied to the sums secured by this Security Instrument, whether 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 grealer than the amount of Ihe sums secured by this Security Instrument immediately before the laking, unless Borrower andLender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amouru of the proceeds multiplied by the following fraction: <a) the total amouru of the sums secured immediately before the taking. divided by (b) the fair market value of the Property immediately before the taking. Any balanceshall be paid to Borrower. In the everu of a partial laking ofthe Property in which the fair market value of the Property immediiltelybefore the taking is less than the amount ofthc sums secured immediately before the laking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. Ifthc Property is abandoned by Borrower, or if, after notice by Lender 10 Borrower thatlhe condemnor offers to make an award or settlea claim for damages, Borrowerfails to respond toLenderwithin 30 days afterthedatethe notice is given, Lender is authori2ed to collect and apply the proceeds, at its option, either to restoration or repair of the Property orto the sums secured by this Security Instrument, whether or not then due. Unless 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 such payments. 11. Borrower Not Releascd; Forbearance Qy Lender Not a Waiver. Extension ofthe time for payment or modification of amortization of the sums secured by lhis Security Instrument granted by Lender 10 any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lendershall notbe required 10 commence proceedingsagainstanysuceessorininterest orrefusetoextend timeforpaymentorotherwisernodifyamoni2ationofthesumssecored 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 exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. U. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements ofthis Security Instrument shall bind and benefilthe successors and assigns of Lender and Borrower, subject to the provisioDs ofparagraphJ7. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does Dot execute the Note: <a) isco-signingthis Security Instrument only to mortgage, grantand convey that Borrower's interest in the Property under Ihe terms ofthis 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 10 extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that B.>rrower's consent. 13. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges, and that law is fmally iruerprcted so that the interest or other loan charges collected orto 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 already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing 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 plI!tial prepayment withoul any prepayment charge under the Note. 14. Notices. Any notice to Borrower provided for in this Security 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 Addressor any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 15. Governing Law; Severability. This Security Inslrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In Iheevent that any provision orclauseofthis Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of Ihis Security Instrumenl and the Note are !lecJared to be severable. 16. Borrower's Copy. Borrower shall be given ODe cooformed copy of the Note and of this Security Instrument. 17. Transfer oflhe Property or a Beneficial Interest in Borrower. !fall or any part of the Property or any interest in it is sold or uansferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior wcillen consent, Lender may, al its option. require immediate payment in full of all sums secured by this Security Instrument. ~ L. "1_ ?ALDID'D .. PENNSYl.V ANfA~ Single Family -FNMAlFULMC UNIFORM INSTRUMENT Form JOn 9190 Amended SIlII Page 4 of 6 -.,. Initials I -...- _III [-"1"-'1 ..~.... . " -"". . ""~~ ....,"..~~~~I LOAN ., 608915881 However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security InstnlIIIeru. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice sha1I provide a period ofllOlless than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security InSlrumellt. 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. 18. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security InstrumentdiscontinuedatanytimepriGflOtheearlierof: (a) 5 days (or such otherperiod asapplicablelawmayspecify ~or reinstatement) before sale oflhe Property pursuant to any power of sale contained in this Security Inslrument; or (b) entIY of a Judgment enforcing this Security Instrument. Those conditions are that Borrower: <a) pays Lender all sumswhieh then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other COvelW\lS or agreements; <c) pays all expenses incurred in enforcing this Security Instrument, including, but nOllimited to, reasonableallorncys' fees; and (d) takes such action as Lelllder may reasonably require to assure that the lien of this Security Instrument, Lender's righls in the Property and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully efl'ective as if no acceleration had occurred. Hllwever, this right to reinstate ,shall not apply in the case of acceleration under paragraph 17. 19, Sale of Note; Change of Loan SeM'icer. The Note or a partial interest in the Note (together with this Security InstrulJlCllt) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (kDOwn as the "Loan Servicer") that collects monthly payments due under the Note and this Security Instrument. Therealso may be one or more changes ofthe Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice ofthc change in accordance with paragraph 14 above and applicable law. The notice will state the name and address ofthe new Loan Servicerand the address to which paymentsshould be made. The notice will alsocontain any otherinforrnation required by applicable law. 10. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release ofany Hazardous SubS18nceson or in the Property. Borrower shall not do, norallow anyone else to do, anything alfectingthePropertythat 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 generally recognized to be appropriate to normal residentlaluses and to mailltenance of the Property. Borrower shall 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 Environruentai Law of which Borrowerhasactual knowledge. If Borrower learns, or isnotitied by anygovemmental or regulatory authority, thatanyremoval or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take 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 pesticides and herbicides, volatilesolvenls, materials containing asbestos or fonnaldehyde, 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 funher covenant and agccc as follows: 11. Acceleration; Remcdies. Lender shall give notice to Borrower prior to acceleration following Borrowcr's brcach of any co.cunt or agreemcnt in tbis Security In.trnmcnt (bllt not prior to acecleration IlRder parallraph 1711nlellS applicable law provides otherwillC), Lender shllll notify Borrower of, among other things: (a) the dcCault; (b) the aetion required to cure thc dcCault; (c) when the dcCault must be cured; and (d) that failure to cure the default as specified may result In acceleration of the sums secured by this Security Instl1lment, foreclosure by judicial proceeding and sale of the Property. Lender .ball further Inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-edstence of a default or any othcr dcCense 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 all sums secured by tbls Security Instl1lmentwithout further demand and may foredose this Security Instl1lment by judicial proceeding. Lender shall be entitled to collect all elJlCDSCS incurred In punlling the n:medles provided in this paragraph 11, including, but not limited to, attorucys' fees and costs of title evidence to the extent pcrmilted by applicable law, 11. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satislY this Security Instrument without charge to Borrower. Borrower shall pay any recordation COSIs. . . 23. Waivers. Borrower, to the extent permllled by applicable law, waives and releases any error or defects ID proceedlDgs to enforce this Security Instrument, and hereby waives the benefit ofanypresent or future laws providing for stayof execution, extension of time, exemption from allachment, levy and sale, and homestead exemption. PENNSYLVANIA. Single Family -FNMAlFHLMC UNIFonM INSTRUMENT Fo"" 3039 9/90 ........d... !1ft Page 5 of 6 ~P~'!D Initial. I ~ ~ . , I~' LeAH ., 608'15881 14. Reinstatement Period. Borrower's lime to reinstate provided in paragraph 18 shall extend to one honr prior 10 the commencement of bidding at a sherilrs sale or other sale pursuant to this Security Instrument. 25. Purchase Money Mortgage. If any of the debt secured by this Security Insuument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 26. Interest Rate After Judgment. Borrower agrees that the intelest rate payable after ajudgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable ~ time to time under the Note. 27. Ridcrs to this Security mlltrument.1f one ormore riders are executed by Borrower and recorded IOgetberwith this Security Instrument,thecovenantsandagreementsofeach such rider shallbe incorporated into and shall amend and suppJementthecovenanls and agreements of this Security Instrument as if the rider(s) were a pan of this Security Instrument. [Check applicable box(es)) c::l Adjustable Rate Rider c::l Graduated Paymeru Rider c::l Balloon Rider c::l VA Rider c::l Condominium Rider c::J I -4 Family Rider c::l Planned Unit Developmeru Rider c::J Biweekly Payment Rider c::l Rate Improvement Rider c::J Second Home Rider WJ Other(s) [specify] legal description BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any rider(s by Borrower and record Ylith it. Wit~ ~ ~tP '-.- ROBSll'r THRUSH Certificate of Residence r, of the within-named Mortgagee is 2600 W. BIG BEAVER 1lD., 'rROY, MICHIGAH 48084 Witness my hand this 2nd day of June, 1999 do hereby certify lhatlhe correct address Cornerstone Land Transfer, Inc. Agenl ofM""gap COMMONWEALTH OF PENNSYLVANIA, Cumberland County ss: On this, the 2nd day of ROBEll'r THRUSH June, 1999 before me, the undersigned officer, personally appeared known to me (or satisfactorily proven) to be the person instrument and acknowledged that he IN WITNESS WHEREOF, I hereunto set my hand and olIicial s My Commission Expires: OS/20/02 whose name is tlthe same for the subscribed to the within in contained. NotarfalSesJ SUzaMel.. Cramer, NoIaIy Pub!ic StQmanstNn SolO, Cun\bemmd Coonty My Commission Expires May 20. 2002 Member, Pennsytvanla _lien at Nolanes PENNSVLV ANlA- Single family .FNMAlFIrLMC UNifORM INSTRUMENT P..... 30399190 AlneDded 5191 Page 6 of 6 Notary Public Titlo ofOfficcr PAlDEEJ) ~ I," 'I _ , lliil ^ '- ~ . . . 'j r "-"f~ , DATE: March 2, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE* This is an official notice that the mortl!al!e on vour home is in default, and the lender intends to foreclose. Snecitic information about the nature of the default is provided in the attaclleapal!es. The HOMEOWNER'S MORTGAGE ASIST ANCE PROGRAM (REMAP) mav be able to help to save vour home. This Notice explains how the prOl!ram works. To see if HEMAP can help, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30.DA YS OF THIS NOTICE. Take this Notice with vou when vou meet with the Counseline: Al!encv. The name, address and telephone number of Consumer Credit Counselinl! Al!encies servinl! vour Countv are. listed at the end of this Notice, Ihou have anv Questions, vou mav call the Pennsvlvan,ia Housinl! Finance Al!encv toll free at 1-800-342-2397. (Persons with impaired headinl! call (717) 780-1869. This Notice contains important legal information. If you 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 ENSU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "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 NAME(S): Robert Thrush PROPERTY ADDRESS: 1009 Rockledge Dr Carlisle PA 17013 LOAN ACCT, NO.: 0608915881 GINAL LENDER: Standard Federal Mortgage Group CURRENT LENPEllISERVtCER: ABN AMRO Mortgage Group EXH\6\T A. ,~ ,~ < L ~ll_'1 .""" HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM . YOU MA Y BE ELIGIBLE FOR FINANCAL ASSISTANCE WHICH CAN SA VE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PA YMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSEURE-Under the Act. you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a .. face- to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED" HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for (30) days after the date of this meeting. The names. addresses and teleohone numbers of desienated consumer credit counseline aeencies for the countv in which the orooertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to.face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM. To do so. you must fill out, sign and file a completed HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM APPLICA nON with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer Credit Counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLACA nON PROMPL Y. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHE TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDlA TEL Y AND YOUR APPLICA nON FOR MORTGAGE ASSISTANCE c. .WILL BE DENIED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited, They will bc disbursed bv the A!!encv under the eli!!ibilitv criteria established bv the Act. Thc Pennsvlvania Housin!! Finance A!!encv has sixtv (60) davs to make a decision after it receives vour aoolication. Durin!! that time. no foreclosure oroceedin!!s will be oursueda!!ainst vou if vou have met the time requirements set forth ahove. You will be notified directlv bv the Pennsvlvania Housin!! Finance A!!encv of its decision on vour aoolication, EXH\B\\ ~ ~- "'.' (L..I......~ l"-'~' o.l.'''''-", NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPCY, 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 filed for bankruptcy you can still apply for Emergency Mortgage Assistancc.) HOW TO CURE YOUR MORTGAGE DEFALT (Brin!!: It UP To Date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 1009 Rockledge Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: January, February, March Other Charges Late Charge $114.56 TOTAL AMOUNT PAST $4,255.61 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not aOt;>licable ): HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS oflhe date of this notice BY I'A YING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,255.61 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made oavable and sent to: ABN AMRO Morteaee Grouo 4242 N. Harlem Ave.. Norridee. IL 60706 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE ][)EF AUL T-If you do not cure the default within THIRTY (30) DAYS of the date of this notice the lender intends to exercise its ril!hts to accelerate the mortl!Bl!e debt. This means that the entire outstanding balance of this debt will be considered due irnmediatelyand you may lose your chance to pay the mortgage in monthly installments. If full payment of the total amount is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose UDon vour mortl!Bl!ed DroDertv. IF THE MORTGAGE IS FORECLOSED UPON.. The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cllre the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you. you will have to pay ~ -all reasonable attorney's fees actually incurred by the lender even if the exceed $50.00. Any attorney's fees will be added to the amount you owe the lender. which may also include other reasonable costs. If vou cure the default within the THIRTY (30) DAY neriod. vou will not be required to Dav attornev's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE DEF AUL T PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAYS period and foreclosure proceedings have begun, you still have the ril!ht to cure the default E){H\Srr A . L 1 "1;;'1' , .~ i~ TC'<~ and Drevent the sale at anv time uo to one hour before the Sheriff's Sale. You may do so bv DayiniJ the total amount then oast due. Dlus any late or other chariJes then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as soecified in writiniJ by the lender and by Derforminl! any other reauirements under the mortl!aiJe. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHIERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: ABN AMRO MORTGAGE GROUP. INC 4242 N~ HARLEM A VENUE NORR.IDGE. IL 60706 1-800-544.8012 ORl-708-452-1330 Fax Number: 708;456.85-93 EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale. a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You _ mayor _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF TillS DEBT. TO HAVE TillS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TillS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDER YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ~ )"0 ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (See Attached) r;:j,-y..\ ~.xt j). I I ^ wl,,-I , -,do' "L ~~;llilt.::i~i' PENNSYL VANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV, 8/00) CLINTON COUNTY Lycoming-Clinton Counties Commision for Conununit}' Action (STEP) 2138 Lincoln Street P,O. Box 1328 Williamsport, P A 17703 (570) 326-0587 FAX (570) 322-2197 CCCS of Northeastern P A 1631 South Atherton St, Suite 100 State College, PA 16801 (814) 238-3668 FAX (814) 238-3669 CCCS of Northeastern PA 20 I Basin Street WiUiamsport, P A 17703 (570) 323-6627 FAX (570) 323-6626 COLUMBIA COUNTY 31 W. Market Street POIl1l27 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 1400 AbingtQn Executive Park Suite 1 ClarleS Summit P A 18411 (570) 587-9163 or (800) 922-9537 FA..'( (570) 587-9134-9135 Cml1.mission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre. P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665-(Call Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-5631-(Call Before Faxing) (570) 836-4090 Tunkhannock CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 9111 Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Booker T. Washington Center 1720 Holland Center Erie, PA 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 201b Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Shenango Valley Urban League, Inc, 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg. PA 17102 (717) 541-1757 CUMBERLAND COUNTY Financial Counseling Services of Franklin 31 West 3rd Street . Waynesboro, PA 17268 (717)762-3285 Urban League of Metropolitan Harrisburg N.6.Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 YWCA of Carlisle 301 "G" Street Carlisle, PA 17013 . (717)243-3818 FAX (717)731-9589 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 334-1518 FAX 334-8326 PENNSYLVANIA BULLETIN, VOL. 29, NO. 23, JUNE 5, 1999 EXH\B\T A - - '1....1 ALL ~AT CERTAZN ~oe of ground with ~m~rovements ehereon erected situated in the Township of south M~dd~eton, Curnber~and County, Pennsy~vania, more partiou~arly bounded and described as follows, to wit: BEGZNNrNG at a point in the center of the road leading from the Walnut Bottom Road to Mt. Holly Springs, locally known as "the back road to Mt. Holly,. which point is North 17 degrees 20 minutes East 440 feet from the intersection of the said center of the road known as the "back road to Mt. Holly. and the Northern line Of a proposed 50 foot street, which point is also the Northern line of properey now or formerly of Theodore s. Gr~ssinger and Rena V. Grissinger, his w~fe; thence along the center line of the said road North 17 degrees 20 minutes East 180 feet to the Southern line of land of Earl B. swarner and wife; thence along the line of the latter South 72 degrees 40 minuees Ease 250 faae to a point; thence South 17 degrees 20 minutes West 180 feet to a point on the Norehern line of land now Or formerly of Theodore S. Grissinger and wife aforesaid; thence along the line of the ~ateer North 72 degrees 40 minutes West 250 feet to a po~nt, t~e place of BEGINNING. SUBJECT to restric~ions and covenants contained in prior ~nstruments of -record. BEING the same premises which Eleanor C. Cogan, by Deed dated July 28, 1995, and recorded in ehe or~ice of the Recorder of Deeds of Cumber1and County, Pennsy1vanla, in Deed Book 125, Page 1127, granted and conveyed unto R~Qhard M, Brown and Linda J. RYan, now Linda J. Brown and husband and wife, Grantors herein. PREMISES ON; 1009 ROCKLEDGE DRIVE "'~.-.. , 1lIiI1-~--' -,.< "'. -, , . or "~.~ ._~ VERIFICATION PATRICIA SRAGA hereby statesi.l-,.,., ">,<is VICE PRESIDENT of ABN-AMRO MORTGAGE GROUP, INe. mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true aod correct to the best ofhis knowledge, information aod belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. , DATE: 6 ,.,&km>"j,\""Ol~Wk'~-;"~i~I1J;I~;m1lil!;-~-&~,~"""""'%;~",:~,,,,,,"-,"'-'''_:i._","',_'2l<";J_"j~<,,,,;,<Ii~,,,~,~M~,II!t,,'W:"~<1'~'iir--'1 c-S( /,>,...) <-dO '$'~~*_~!~,U_ ,~- ,~,L~::[1[ JU J [ _ .",_J[(,J~~,,-~" ""~,,,ffi! ~.Q,^ !_~"'~_"'_", .,__',''''''.~ ,~ )~ .......... - - ~ ~;'Illi::;.r''''"''' WH ....... W ~ & .r -€q ~ h~ ~8~ I I C).. (\d~ r't t '-Z ,n. ,C . <-.. .,,' ~ _~ o 5~ ;:g ~~:J Z:~I:,; ?} ~:..-- -'" -~., C;C~ ~~;: >~ --< -< ifIlJIIuI c::' -""" q1:: _. -'1 1'...1 :1'1 ...... n -_OJ , "C:' ;\h~: ':~"l . . ~ . ~~''"''''~. ',.. III!ld ='"'~j~=~< '~I~ .,. --. SHERIFF'S RETURN - REGULAR CASE NO: 2001-02994 P , COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STANDARD FEDERAL BANK VS THRUSH ROBERT DEP DAVE MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THRUSH ROBERT the DEFENDANT , at 1701:00 HOURS, on the 31st day of May at 1007 ROCKLEDGE DRIVE , 2001 CARLISLE, PA 17013 by handing to ROBERT THRUSH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 r~~-.,;~~ R. Thomas Kline 06/01/2001 FEDERMAN & PHELAN day of By: ,A;~~~ . Deputy Sher~ Sworn and Subscribed to before .... me this ZG. ~ ~ A.D. C) '1:1-<.' Q 7l.,tl/.... ~ rothonotary , - I J I , '" -, l..il"""" ,"",,- _:.~: f .- SHERIFF'S RETURN OF SERVICE Plaintiff(s) STANDARD FEDERAL BANK CIVIL ACTION NUMBER SHERIFF'S NUMBER Defendant(s) ROBERT THRUSH COST MILEAGE DISTRICT Serve At 1009 ROCKLEDGE DRNE CARLISLE, P A. 17013 Special Instrnctions _ Sununons .xJL Complaint _ Other TYPE OF ACTION Mortgage Foreclosure TO BE COMPLETED BY SHERIFF Served and made known to , Defendant, on the _ day of , 19_, at _ o'clock, _.m., at , County of , Commonwealth of Pennsylvania, in the manner described below: Defendant( s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant( s) reside( s). Agent or person in charge of Defendant's office or usual place of business. and officer of said Defendant company. Other: SHERIFF By: , Deputy Sheriff On the _ day of ,19_, at _ o'clock, _.m., Defendant not found because: Moved _ Unknown _ No Answer _Vacant _Other SHERIFF By: , Deputy Sheriff DEPUTIZED SERVICE Now, this _ day of , 19 _, I, Sheriff of County, Pennsylvania do hereby deputize the Sheriff of County to serve this Complaint and make return thereof and according to law. SHERIFF By: , Deputy Sheriff ATTORNEY FOR PLAINTIFF: TO BE COMPLETED BY ROTHONOT ARY Name Fr~nkFf':nf':rm~mJ P"-qnirf': Id. No. 1 ?74R Address Onf': PP.11n (\~ntf':r ::It ~llhl1rh::ln StRtton 11\17 John F K P.11nedy Ronlevard Snite 1400 Philadelphia Pa 11)101 ATTEST Pro Prothy Date ... _1".. , J ,I I IIlIJ.I -. -", "V ,. .. FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff STANDARD FEDERAL BANK 4242 NORTH HARLEM AVENUE NORRIDGE, IL 60634-1283 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DMSION VS. : NO. 01-2994 CIVIL TERM ROBERT THRUSH 1009 ROCKLEDGE DRIVE CARLISLE, PA 17013 Defendant PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWERAND.ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem. in favor of the Plaintiff and against ROBERT THRUSH , Defendant, for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 5/1101 TO 7/3/01 $131,253.05 $1.411.20 $132,664.25 TOTAL I hereby certify that (I) the addresses of the Plaintiff and Defendant are as shown above, and (2) notice has been given in accordance with Rille 237.1, copy attached. fYJtCUlK ct~dmYK1J1 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~ 1. ~f fhAUA' R ~~Ah' . PROPR. T "*THIS FIRM IS A DEBT COLLECTOR ATIEMl'I'ING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED Wll..L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPI' TO COLLECT A DEBT, BUT ONLY ENFORCEMEN1f OF ALIEN AGAINST PROPERTY. "" -, .,~" ," ,,-L__,j ., . - ,,1'1..1.1.1"'-', '-. '~~_. -"-' w SHERIFF'S R~TURN - REGULAR . .... ... CASE NO: 2001-02994 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STANDARD FEDERAL BANK VS THRUSH ROBERT DEP DAVE MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THRUSH ROBERT the DEFENDANT , at 1701:00 HOURS, on the 31st day of May 2001 at 1007 ROCKLEDGE DRIVE CARLISLE, PA 17013 by handing to ROBERT THRUSH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 ~~r~<~~ R. Thomas Kline 06/01/2001 FEDERMAN & PHELAN me this day of By: ,A~~::1.:r-,;~ Deputy Sheriff ~ Sworn and Subscribed to before A.D. Prothonotary ."~-.~ 1.1 'j ..1...1: I_:.,~\-. to' FEDERMAN AND PHELAN, L.L.P. .Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 -;,; , ATTORNEY FOR PLAINTIFF STANDARD FEDERAL BANK COURT OF COMMON PLEAS CIVIL DIVISION vs. ROBERT THRUSH CUMBERLAND COUNTY NO. 01-2994 CIVIL Defendant(s) TO: ROBERT THRUSH 1009 ROCKLEDGE DRIVE CARLISLE, PA 17013 FILE COpy DATE OF NOTICE: JUNE 21. 2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 (10) days from the date of this notice, a Judgment may be entered against you without a hearing 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: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff - - _ '_L_ I , 1-l.lIiI-'" ., \, . ,oj'. I.,. :.:.] ',', -"S1:! .. FEDERMAN and PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia,Pi\ 19103-1814 (215) 563-7000 STANDARD FEDERAL BANK Attorney for Plaintiff : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION ROBERT THRUSH : NO. 01-2994 CIVIL TERM Defendant VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant ROBERT THRUSH is over 18 years of age and resides at 1009 ROCKLEDGE DRIVE, CARLISLE, P A 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN Attorney for Plaintiff "..,.,.~" ~. ~=~= I I 11IlIiI~~~. . ~o ,- '-oiit.,; ~ . ~ (Rule of Civil Procedure No. 236 - Revised) STANDARD FEDERAlL BANK : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CML DMSION ROBERT THRUSH : NO. 01-2994 CML TERM Defendant Notice is given that a Judgment in the above captioned matter has been entered against you on JULY {,!:' .2000. By ~M' . - o I1ft,CiI"./ DEPUTY If you have any questions concerning this matter, please contact: FRANK. FEDERMAN. ESOUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 ""TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. "" '.b&~'i;"""&f!!li,;4hiWj,;i!J.illit:",,,,""Ub>f1!.:iJ<;;'ll!ifu,!;;':!b:6,,",-~-~~":i0~.C-,0_. r~ :::: {: , " \,. ~ "\ "'<:7, '. .cc (......., tp H L. ",'::;:;""", ";;;"":"'~W",_",,;4>ll'-S~~~~~.~1l&l~Iii!""'1'i-,,'_~~~rJ!jIi:]IKtlsL '" ~.," C'_~<~ ,~""_""',",~_ .-, ..". , - " 0 . , ~, Gl , (:;;;:; ,"- .._~ - / (j'.1 [:., CT' _n r~~ l i ,- ~,j --~ r:- ',-\ -< \ P --( ~. a. ~ ~~ ~ ~ -," - """"'"'~~ ~." I I_i ; J,I.J--' ~. -;-;, . . ..... , , , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P,R.C.P.3180-3183 STANDARD FEDERAL BANK Plaintiff, CUMBERLAND COUNTY v. No, 01-2994 CIVIL TERM ROBERT THRUSH Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $132,664.25 I Interest from 7/3/01 to 12/5/01 (per diem - $21.81) $3,380.55 and Costs TOTAL $136,044.80 RANK FEDE , ESQUIRE NE PENN CENTER at SUBURBAN STATION SUlTE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property. No. j~~~~iiIIlil;~~~i8<:~~'~\':;""_""":d"_'"""",_""a'i:":furft~i'iOll~[iJli1i1'-"'-~' . Iii~u '"lliItllit'i''^'-~:I'~' :IiI-iJ. -- . '. / ..., .... 0 r:-- .... < i:l< r.s "'" [JJ ... ....:s "'" z < O~ 0 u [JJ> ... ~ <"", E-< [;1;1;... ::.d ~ ~ ""'[JJ ~ u .,; i:l<Z ~-- Q Q) Zz ll:l ~ !: [;1;1 ~ Or-1 ~ r-1 = '" '" '" ~i:l< ; .... 0 Q Q) ~ . 0<3 r-1 ,D O~ == Q) ~ ~ r-1 ... lo UZ Q .; ... ~~ 13 [;1;1 .. ~ U ....~ ~ Q) '" 00 .... bll ~ [) ~ [;1;1 ~ '" go ...U ll:l bll ~-g a, Po ~Q ~ 0 Q) ~~ 0 ~ Q r-16 .... 8~ ~ i:l< ... ;; [;1;1[;1;1 E-< U '" ==ll:l [JJ ~ .0 ~ E-<~ Q) ~ - .~ z~ i:l< .... ...u 0 C) 0 c: -n ~ ",.. -00:1 ~ ,\ mrr; :;; i::;=: z::n I IfT\ Zc;-: "_;jd ~~~: ,.0 "-.~';J~~B ~CJ "'" :>;;C :I: -~.,,?() ~~ .,,~,- "'-n g' ' ~ "Y..--';' ~ "b (j1 "< J ~,,___'__h~ _, ,_'_."~ ~,___ M~ . I, -"iill- -~ ,: -, fi-""-t . . ..... " ALL THAT CERTAIN lot of ground with improvements thereon erected situated in the Township of South Middleton, Cumberland County, Pennsylvania, more particularly bounded and described ~ follows, to wit: BEGINNING at a point in the center of the road leading from the Walnut Bottom Road to Mt. Holly Springs, locaily known as "the back road to Mt. Holly", which point is North 17 degrees 2Y--- minutes East 440 feet from the intersection of the said center road known as the "back road to Mt. Holly" and the Northern line of a proposed 50 foot street, which point is also the Northern line of pfOperty now or formerly of Theodore S. Grissinger and Rena V. Grissinger, his wife; thence along the center line of the said road North 17 degrees 20 minutes East 180 feet to the Southern line of land of Earl B. Swarner and wife; thence along the line of the latter South 72 degrees 40 minute:.---- East 250 feet to a point; thence South 17 degrees 20 minutes West 180 feet to a point on the Northern line of land now or formerly of Theodore S. Grissinger and wife aforesaid; thence along the line of the latter North 72 degrees 40 minutes West 250 feet to a point, the place of BEGINNING. TAX PARCEL #40-23-0602-032 TITLE TO SAID PREMISES IS VESTED IN Robert 1. Thrust by Deed from Richard M. Brown and Linda J. Brown, fotmerly Linda J. Ryan, Husband and Wife dated 7/2/1997, recorded - 7/21/1997, in Record Book 161, Page 351. ,-, A;f.!ie1.:t<t1<'lEll~;illi\lli"","'~.;ili:4~"'V.:;WJ~~,~~)'Jll't"""~..ll';.10>l'b-.u.-"",-,,';,'~' ,..., ~",;,'of,.,.;"A'-'s!l"-,;.~rMi;il'i21~!~~iiIiiDlli~_~_ffifjht!ll'~"fI;;:,,,,,,,,,,-ij~~~--' . .". , , , "'- "'- }~~ (A , ~ ~ ~~ <) ~ <.v a \j c: ~ "'- ~ """" '/1 I:ll' ~ff:; ):>0 '" ~~ rn C'::. \) "- -c' (i") ;-;[} ~. ~ ~ Zp-- ~ (n)", I ",".liT! ;:$""'- \Ll :-)0 .-f-"'; t..){l. , '" '" ~~ l' f r'\. :<>- "'" ;~?i~ r Zl) ::!I: P " p() c:: ~ 1..._) , . :];! j:;- . (.11 :0 \ ~~ -< ~ ~ ~~ ~ ~ \) ~ ~ 3 &- Cp ~1._~Jl.J UJLJMJf U~_J ,",~,J(1LnL __ ,,' ,'"_l~~,_,~'_" ." ~_ ~~ ~_ .0'. ,,_'__' ~,">;~_~. . ".""""', .,_ ~_, ,__ ~___ .J>~ ,,- ~" ~~ ~ - ~,,~_._, -~ i-IJ.i i~.::~,", FEDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF STANDARD FEDERAL BANK Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT THRUSH NO. 01-2994 CIVIL TERM Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. B1:~urnE Attorney for Plaintiff """" ,., li~i.':',Wl",~;,,~IM"""'_'1i,;L,,",',.!!~'d:.,i"'-';,l"",~;l!Ml.~j,~,",k,);:tJ:',ilie<.'"",i,1 ,'"[>')"",,,id o>""'^,"ii<':.";",,,""~=c,"~,:;',~'~ic"1l....u,~~HIi;i~~';;;t#J'i;~J~o~1IiWJ'>"1 lEU 'In" s... --s I:-p ,i:r&ii,~~Jf LCJU,ILMJIW.L r ,I., J~L.""l, ~~_~ ,,~, ,~~-~-- -. -, ".,=--- ,".OW," ".", ~_, ,~,,~ ^ "~>~, "," ,_ ~~__,",~~." ~--"- "I 0 0 0 C -n .,.~ .".. ""- -om c: ~~ mn1 (;'") , z:r:; I - .::':~ ~.;..; Zc;. \.0 '-,;'-( ~2: ',-,:,!s;, 1.<0 "'" f~~~ 2';0 :,1'': 50 - ::z,rn 'C - ~ -- ~ r. ~ en ~l , --'" 1<_1 I~~I "'''''-''''''.~'i'' STANDARD FEDERAL BANK Plaintiff, CUMBERLAND COUNTY v. No. 01-2994 CIVIL TERM ROBERT THRUSH Defendant(s). August 7, 2001 TO: ROBERT THRUSH 1009 ROCKLEDGE DRIVE CALISLE, P A 17013 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBT AINEDWILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at 1009 ROCKLEDGE DRIVECALISLE, PA 17013is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by STANDARD FEDERAL BANK (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the MARCH 6, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, ifthe judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. Vou may also be able to stop the sale through other legal proceedings. iJj~'. .. --~..;. " - . ~ ~ .~ ~.~~, w" I I 1.1 '" ~ il!!drL: '. , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. . 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days ofthe sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ~~lli!!Mo.lilM!b:;"<t>d;$m,jli.'.';d,j~"!!k""'llk~M,l'~'m~1!i"',,*illd,tJ)bt.,b",,'1Jl~:o..';'----'o._,,"-,,_,,,,,~.,~-",'!i"d':iOO'j,,1;;''''I<i'':i!i,~~lillliiit~~#i,",ffi;i~'''~ID! '~JI'"rid~""""""-~" ~ ~J,::, j,..C 01 A)""~~~~lli ~jjW,,,,J.!~lll',L"+_::"'L-<B,,--,,,.}I<,));!ltij:,,~. "', _'~,^_ '.~_'r" _',m,', " ',fr;;(.'~."""_'" > ,.."",.;,,, ,,," "', ,..",. _P'$", __ -'.". , .,_,~" ~._" - ~ ~., ~ ">- n..~ ~tP, z"'r-.. z",'Y <!.t~:; 'LO 7-(") %0 -c;. :P-z.. :2. r' Ioo-~.. .- ~ -- ,,-' \ ,0 ~ ..- .- .- .' "1 I I ,-~} ~\ ..,., -"\f~ )..cJ :-~\t1, L --n ~40 >_,rI g '17 ?l. ""' tf\ r I' I 1..1 ..~ _~, ~r ~~"~ - -I ~_."'~,"",,, ~ (' STANDARD FEDERAL BANK CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS ROBERT THRUSH CIVIL DIVISION Defendant(s). NO. 01-2994 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) STANDARD FEDERAL BANK, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1009 ROCKLEDGE DRIVECALISLE. P A 17013 1. Name and address of Owner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT THRUSH 1009 ROCKLEDGE DRIVE CALISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME, LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None -. - ,. t - - ~. _i I - 1..1 ; ~ ' T" "_._~ .~l:'~I~ 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occnpant 1009 ROCKLEDGE DRIVE CALISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsificatio to au orities. August 7. 2001 DATE FEDE , ESQUIRE orney for Plaintiff -, 'i~{~brwi1ill!(;,,,,ili!t!'j"',L'Ii"'f!,:;C~';It\i~;I'"'~t!!~~h_~*{":""i!'_\J>:'.."m-t;. _,,;__j"':i;".>i,,~,''',''.ci'~^it'fi',gl;,~~~mM~!IiJ;}il;;i,*R;iP"~ii:r. ., .-~L --,~,~^ ,~"~,~,~"tt "~,,~,, " ,~~,.~,~_ " _~"",r _".- "lil1n~r""'" , ~ """I " 0 c; () c: ~rt g. ~ "-1""1 -orn t",_ ;-,'~~~ rnfil ;.j'") -? .~f' "- ~~ I :'IV ZC;:: ~:2:' \.,.0 :_':.~~>. ~CJ :0'" ~s~ ~Q ::1b1: - :::;.-C; - PC: ....., :z ~ ~ ~ (}1 --- . ,-- '1IitI - -, -^, ~ - .~'" -~ "'lidi -'-"";'ij JAM AFFIDAVIT OF SERVICE PLAINTIFF ST AND.<UID FEDERAL BANK CUMBERLAND COUNTY No.01-2994 CIVIL TERM DEFENDANT(S) ROBERT THRUSH SERVE ROBERT THRUSH AT 1009 ROCKLEDGE DRIVE CALISLE, P A 17013 Type of Action - Notice of Sheriff's Sale Sale Date: DECEMBER 5,2001 Served and made known to SERVED ~O \:>eX\. -\- ~ >$... v"':> It- , Defendant, on the I OO~~l:-\ 'C. ~~ \0 (1(. ) i If ~ day of A-U'j u~t-, 2001, n;1R\ 1":1 \~ , Commonwealth at B~ 5"~, o'clock~.m., at of Pennsylvania, in the manner described below: )< Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: I '/ Description: Age 1) S- Height.!S:..1./ Weight 1fJ...$'" Race ~ Sex -1i- Other I, d<il1Z ~\Jt~ L. C 'i)'(L ~ <;f'fcompetent adult, being duly sworn according to law, depose and state that 1 personally handed a true and correct copy of the No ce of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Notarial Seal Stacy L. Heefner. Notary Public ~4- Sworn to and sUb~ed Chambersburg BO",: Fra lin County . . I My Commission Expire g. 5 002 --/ befor me th s 2001~y l 1 Me~ber'l ennsylvama A 0 I No r' s I' ~. ~ By: NOT SERVED On the '~ day of ,200_, at o'clock _.m., Defendant NOT FOUND because: IV!oved Unknown No Answer Vacam Other: Sworn to and sub;cnbed before me this ___' day of ______. 20D _' Notar)': By: Allornev for Plaintiff Frank Federman, Esquire - J.D. No. 12248 One Penn Center Subnrban Station, Suitc 1400 Philadelphia, PA 19103 (215) 563-7000 ,OO~0~Jd,'lll~;M)1I1l'p.;wh..t>1iil;~~Milt~"'~~':f~'-4i!rti":""'"I,h'M".,,-,,,,,,.",,', "",t"",-",;,-,,,",~,,::",g~'i3&';K.!.;1'-"!~!;)~~lt'1i!i!4i.llil i~'N' "__'*':ttiil.Alb'l>:~lil!\;~"l~~~~[ .il&lIllll"""g!ili "11MiR_ m, 0 ,-", ~;; :'-;:'1!lI -0 I. ,~_ rn no, :'~"") r- :2 :T,i c \".~,} r:,U ""'," - '.,e' U]. c::) c c:= ) - " ~: ("~ -',,,,) () ",.-;:. CJ ;~~': 5> r:Y () [",1 ~ ~ L a -r-"': --' :0 -< .;.~ -< (r. ~ \1:~1\!>J,)Jn,:::LA~ - _ :J.nJb:.Jl)JJ~~j,~~"^~.lL.,,;,.l]l.;"JJn.,, _ "'c>__,,~.,,., ''C,', ,,,,,,,,",,,',, -~"~,,,,~c. .I..c".,,-., .. "".~~~ . ;< ~ " : J , I.,J,I ~ '""L.. ~,,' ".HO , ~' Standard Federal Bank VS Robert Thrush In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2994 Civil Term '-"-- 1B.Wi~1L R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriffs Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 20.00 15.00 .50 2.50 25.66 6.50 15.00 15.00 1.11 2747.15 265.40 206.94 $3350.76 paid by attorney Sworn and subscribed to before me ~;;Z~J~~ This 10 -g;. day of /.jw~ R. Thomas Kline, Sheriff 2001, A.D. 01AO - Q fh, fltJ,.)/'-K/ BY (}tJcU; J~ Prothonotary Real Estate Deputy \ .6\l Vk.2>yqXl ~ .~" I I IJ ".,~ "'~L, "'ihiriii- !. \ 1----' STANDARD FEDERAL BANK CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS ROBERT THRUSH CIVIL DIVISION Defendant(s). NO. 01-2994 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) STANDARD FEDERAL BANK, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1009 ROCKLEDGE DRIVECALISLE. P A 17013 1. Name and address of Owner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT THRUSH 1009 ROCKLEDGE DRIVE CALISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME. LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None I,., 1...1 " ~'" : ~I, '~~,:; c.... r ..,... 1 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiffhas knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 1009 ROCKLEDGE DRIVE CALISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commouwealth of Pennsylvauia Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsificatio to au orities. August 7. 2001 DATE " ~. ~~ i,1 .-~' ~ '"l l.,,-"~~. , STANDARD FEDERAL BANK Plaintiff, CUMBERLAND COUNTY v. No. 01-2994 CIVIL TERM ROBERT THRUSH Defendant(s). August 7, 2001 TO: ROBERT THRUSH 1009 ROCKLEDGE DRIVE CALISLE, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 1009 ROCKLEDGE DRIVECALISLE, PA l7013is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by STANDARD FEDERAL BANK (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the MARCH 6, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay. you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ," ~ ~ ........... -,".- ,'Iiil ->- ,no ~ 1^~,Mr-~-: You may need an attorney to assert your'rights. The sooner you contact one, the more chance )Iou will have of stopping the sale. (See notice on page two on how to obtain an attorney.) . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. lfthe Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. lfthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 -..:.a.dIi .~.~~ - ._."~ I I I. 1.,.,1, - - ~ "';"'-1f~-(: . ALL THAT CERTAIN lot of ground with improvements thereon erected situated in the Township . of South Middleton. Cumberland County, Pennsylvania, more particularly bounded and described ~ follows, to wit: BEGINNING at a point in the center of the road leading from the Walnut Bottom Road to Mt. Holly Springs, locally known as "the back road to Mt. Holly", which point is North 17 degrees 2~ minutes East 440 feet from the intersection of the said center road known as the "back road to Mt. Holly" and the Northern line of a proposed 50 foot street, which point is also the Northern line of property now or fowerly of Theodore S. Grissinger and Rena V. Grissinger, his wife; thence along the center line of the said road North 17 degrees 20 minutes East 180 feet to the Southern line of land of Earl B. Swarner and wife; thence along the line of the latter South 72 degrees 40 minute~ East 250 feet to a point; thence South 17 degrees 20 minutes West 180 feet to a point on the Northern line of land now or formerly of Theodore S. Grissinger and wife aforesaid; thence along the line of the latter North 72 degrees 40 minutes West 250 feet to a point, the place of BEGINNING. TAX PARCEL #40-23-0602-032 TITLE TO SAID PREMISES IS VESTED IN Robert L. Thrust by Deed from Richard M. Brown and Linda J. Brown, formerly Linda J. Ryan, Husband and Wife dated 7/2/1997, recorded - 7/21/1997, in Record Book 161, Page 351. ~"" ~- : I -j~I..;J- . .~ . ~ ,. ~= "J , WRIT O.R EXECUTION and/or ATTACHMENT C'OMMONWEALTH OFPE';JNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-2994 CIVIL 19 CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland COUNTY To satisfy the debt, interest and costs due standard Federal Bank PLAINTIFF(S) from Robert Thrush DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell see leqal description (2) You are also directed to atlach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows and to notffythe garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or tor 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 notify him/herthat he/she has been added as agarnishee and is enjoined as above stated Amount Due $132,664.25 from 7/3/01 to 12/5/01 (per Interest $"3. ~Rn ~~ ,mn CaRts diem - LL $21.81) Due Prothy Other Costs $.50 $2.50 Atty's Comm Atty Paid Plaintiff Paid % $103.10 Date: Auqust 9, 2001 Curtis R. Long Prothonotary, Civil Division by: *t~t<:- JC ,~~. 95 Deputy REOUESTING PARTY Narne Frank Federman, Esq. Address: One reaR CcnteF- at. 5~lQ'llrh;::l,T\ ~TMtion Suite 1400 l'h.aad",lpl.ia. PI>. 19103 Atlorney for: Plaintiff Telephone: 215-563-7000 Supreme Court 10 No. ^^,',!: ,-::,_,,,_,"c'-""-;"'"'''''(?"'')'.;i:rtc'';''lI:1;\j,~'1%f[~1ijjjW~.t:J''''''''';.......lil1j1'j' ~~- if--- ~ 'ill , .-r t1',-,-~, -,- ~!l&liIiI It. . . . REAL ESTATE SALE 'No.-I)" ,.Ii Sept. 10, 2001 the sheriff levied upon the Ollfendants Interest in the real property situated in SOllth Middleton_Township " Cumberland County, Pa., known qnd numbered as: 1009 Rockledge Dr. Carlisle and more flJl"scribed on Exb1bIt "Au flied with this writ and by this referenc€lncorporated herein. Date: sept"~~l,o,_._2001._ By~~ ~~ Real Estate Deputy If II.} 'I f '1 ' (' 1: ~'I-' J ,. ;' l' ,< _-','< ,..:J - '-j 10. lid ZE ZI 6 ~nv AlIiil~ " , ", J',:lO ~~IH3H~"h ,J,! 38:~jO .~,~o ~o "~ ~_ J >~ ~ ~ ~ " REAL ESTATE SALE No.12 Writ No, 2001-2994 CivilTerm Standard Federal Bank vs RobertThrush Atty: Frank Federman DESCRIPTION ALL THAT CERTAIN lot of ground with improvemelit~ tberoon er<:c~ siruateri in the "TQwnship of South MIddleton, cumberland . County, Pennsylvania, more particularly bounded an'ddescribedasfoUowI.,tci"i,'it BEGiNNING 'at a point in the center of the road .,leading from m<; Walnut,."BottomRoatl to. Mt Holly Springs, locally knQ'~u a:, "the bark road to , Ml. Holly,"which point it'North 17 degrec~ 20 "minutes East 44D fect from me interscl1ion of the Silm center road known as the "back road Ie ML :HollY"andtheNorthemliueofaproptiseLi5fl-foot ""'~trecl., which point is also the Northen! lme of . property now or formed.y of' Theodore S, . Grissinger and Rena V< GrThsinger; his wife; thence along the center lite of the road North 17 ~;:'::d~gre.es 20 minutes East 180 feet to. tbe Southern line of land of Earl B. S,wameI' and wife; then~e , mg" l~e line. of the l'atter South 72 degrees 40 . . minutes E'a~t 250 feet to a pOint; l1ien~c $(luth [7 ~rees 20 minutes West 1'80 feet to a point on the Northern line of land now or ronnerly of TheodoreS. Grissinger and wife afow.aid; thence along the line oi the latter North 72 degrees 40 minutes West 250 feci to a point, the place- of BEGINNlNG. TAXPARCEL #4IJ.21.0602.Q32, TnTS'TO SAID premb~~ is vested in Robert L Thrust by.. Deed from Richard M. Brown and , Linda J. Brown, fonnerly UJldll J. Ryan, Hushand and Wife, dated 7/211997, recorded 7/11/1997, in Record Book 161, Page351. ' '----_.- -------- --~----- - ----.--- . . I' . ..lJL ~-!~ I J-~ '_C-_',..+- "'_ [ :": 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 James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager 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 Th e Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is 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 October and the 6th day(s} of November 2001. 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 '~:::',~::::";~ " 0.00' '" ,00 fu'~":"='fo,"p~r=:'='~'"."'mm COpy Swo n to and su lW, . ~9th d of mber 2001 A.D. T "a1Seal S ALE #12 enyL RUSsell. NOIaryPub' HanlsbUlll. Dauphin eo. My Commissioi1 ElCpires June . 2 02 Member, Pennoylvanla Assoclation of . 0 ARY PUBLIC ~!&nmission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COUR1HOUSE 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 $ 205.44 1.50 206.94 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.................................................................... - REAL ESTA'l'E SALE NO. 12 Writ No. 2001-2994 Civil Standard Federal Bank vs. Robert Thrush Atty.: Frank Federman ALL 1HAT CERTAIN lot of ground with improvements thereon erected situated in the Township of South Middleton. Cumberland County. Pennsylvania. more particularly bounded and described as follows, to wit: BEGINNING at a point in the cen- ter of the road leading from the Walnut Bottom Road to Mt. Holly Springs. locally known as "the back road to Mt. Holly." which point is North 17 degrees 20 mlnutes East 440 feet from the intersection of the said center road known as the "back read to Mt. Holly" and the Northern l1ne of a proposed 50 foot street. which pOint 1s also the Northern line of property now or formerly of The- odore s. Grissinger and Rena V. Gris- singer, his wife: thence along the center line of the said road North 17 degrees 20 minutes East 180 feet to the Southern line of land of Earl B. Swarner and we: thence along the Une of the latter'South 72 degrees 40 minutes East 250 feet to a point; thence South 17 degrees 20 mlnutes West 180 feet to a point on the Northern line of land now or formerly of Theodore S. Grissinger and wife aforesaid: thence along the line of the latter North 72 degrees 40 mlnutes West 250 feet to a point. the place of BEGINNING. TAX PARCEL # 40-23-0602-032. TITLE TO SAID PREMISES IS VESTED IN Robert L. Thrust by Deed from Richard M. Brown and Linda J. Brown. formerly LInda J. Ryan. Husband and Wife dated 7/ 2/1997. recorded 7/21/1997. in Record Book 161. Page 351. _1",-,1."" , _>'~""-i" < "' J,-~ 1.'_L I L PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : 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: October 12, 19,26,2001 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 subject 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. ~Editrn SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 ~-(~)i~' q -,... NOTARIALS LOIS E. SNYDER, NoIaly Public Carlisle 80m, CumOOrial1ll County My CommissIon ExpiI'llS March 5, 2005 ~d~ -~ . I . .11.1. J ,-~ c-~~i FEDERMAN AND PHELAN By: FRANKFEDERMAN,ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION PHILADELPHIA, PA 19103 (215) 563-7000 STANDARD FEDERAL BANK 4242 NORTH HARLEM AVENUE NORRIDGE, IL 60634-1283 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DIVISION v. NO. 01-2994 CIVIL TERM ROBERT THRUSH CUMBERLAND COUNTY PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Kindly mark judgment in the above captioned matter "Satisfied" upon payment of your costs only. FRANK FEDE ESQUIRE December 3, 2001 {;I~~~$liw~J!mlHffil~..,Lri~H.-"d;ljj~'*ltt!>"3tlj ~~ ,,^ - ,,~~,o H~M" "~ "-",",':w_,,' ;'_,ld _,~*\",,>j,"!>j,'j'/"~;"l_j,Hi>I.~MiI'Ii!l!lt~~""""'~~=~"'~'_liIIilWi~'~~ _."~-.u o - c_ S. -rC: r~"'-' ~~.. -,-. --, :~ ~-:; /~ ~ :< ~~. ~ -~~~ , ~, -~. o ;-:J ;::;.1 ,-, ^---".Ijllil.~ ~~ -, '---' --0 (- -' .,k.' 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