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Home My WebLink About01-04124 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK MINNESOTA, N.A S/B/M/ TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INS. FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER THE POOLING AND SERVICING AGREEMENT DATED JUNE 1, 2000 PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 CIVIL DIVISION COMPLAINT IN EJECTMENT CODE MORTGAGE FORECLOSURE EVICTION FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: LESLIE J. CARSON, JR. 6378 LANCASTER AVENUE PHILADELPHIA, PA 19151 215-568-1980 DEFENDANT(S). * # # # i k * * 4t*##ti7~##~kkt##kkY#R7~#~k~k4##i~~k#~+E#+ki# * # ~I: R#*k~k~k##:kS:k:k~C~k~k#*:k##t&k#t~#~k#t+k-k##-k~k# NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT This is an attempt to collect a debt and any information obtained will be used for that purpose. II. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. III. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. LESLIE J. CARSON, JR., ESQUIRE ATTORNEY I.D. N0. 05111 6378 LANCASTER AVENUE PHILADELPHIA, PA 19151 ATTORNEY FOR PLAINTIFF TELEPHONE (215) 568-1980 WELLS FARGO BANK OF MINNESOTA, N.A. S/B/M TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2000 505 S. MAIN STREET, SUITE 600 ORANGE, CA 92868 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09- ~/ I2 ~ ~ ~i~.-- PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 DEFENDANT(S). COMPLAINT IN EJECTMENT 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 XOU 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 THE PAPER TO YOUR IAWYER 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. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 170.13 717-249-3166 LE HAN DEMANDADO A LISTED .EN LA CORTE. SI LISTED QUIERE DEFENDERSE DE SETAS DEMANDAS EXPUESTAS EN I,A5 PAGINAS SSGUSENTES, LISTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. LISTED DEBE PRESENTAR UFIA APARSENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS 0 5US OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI LISTED NO 5E DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA LISTED SIN PREVIO AVISO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALIVIO QUE ES PEDIDO AVI5O 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALIVIO QUE E5 PEDIDO EN LA PETICION DE DEMANDA. LISTED PUEDE PERDER DINERO 0 SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARR LISTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTS. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCTON SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR A5ISTENCIA LEGAL. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVEN[IE CARLISLE, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WELLS FARGO BANK OF MINNESOTA, N.A. S/B/M TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2000 505 S. MATN STREET, SUITE 600 ORANGE, CA 92868 COURT OF COMMON PLEAS CUMBERLAND COUNTY PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YOHE ROAD NEVdVILLE, PA 17241 DEFENDANT(s). COMPLAINT IN EJECTMENT. 1. The plaintiff is the corporation named above, having its principal office as stated on the preceding page. 2. The Defendants and all others who reside at the premises are those named above and they reside at the address stated thereon, which are, hereinafter referred to as the Premises. 3. The Premises which are described in Exhibit "A" attached hereto and incorporated herein by reference, were sold at Sheriff's Sale on June 6, 2001 by the Sheriff of the County in which they are located, after due advertisement according to law, under and by virtue of a Writ of Execution issued to satisfy a judgment entered in the Court of Common Pleas of said County at the suit of: Norwest Bank of Minnesota, N.A., et al. - vs.- John A. Ruby. The case number of said judgment is: 2000-8649. 4. The Premises were purchased by the plaintiff at the Sheriff's Sale pursuant to an assignment of bid. 5. The Plaintiff acquired title to the premises on the date of and by virtue of said Sheriff's Sale, pursuant to an assignment of the bid and is still the real owner of said premises. 6. The persons in possession of the premises are the defendants in this action and are occupying the premises without right and without claim to title. 7. Plaintiff has demanded possession of the Premises from the defendants who have refused to deliver up the possession thereof. WHEREFORE, the Plaintiff demands judgment for immediate possession of the premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. $Y: L lie J. Carson, Jr., Esquire ttorney for Plaintiff VERIFICATION The undersigned hereby verifies that he is the attorney for Plaintiff, a corporation; that he is authorized to make this verification and does so because Plaintiff corporation must verify through agents and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge, information, and belief and the source of his information is public records and reports of Plaintiff's agents. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. Dated: /.//~~~ ,~ ------- - ie J. Ca on, 3r., Esquire ttorney for Plaintiff ALL THAT CERTAIN TRACT OF LAND, TOGETHER WITH THE IMPROVEMENTS, THEREON ERECTED, SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POST IN A PUBLIC ROAD (FORMERLY THE STATE ROAD LEADING FROM NEWVILLE TO DOUBLING GAP); THENCE BY AN ABANDONED ROAD (FORMERLY LEADING TO GINTER'S MILL). SOUTH 71.75 DEGREES EAST 18.1 PERCHES TO A FENCE POST; THENCE BY THE SAME, SOUTH 65.75 DEGREES EAST 14 PERCHES TO A STONE AT CORNER OF LANDS FORMERLY OF K. JANE MCCREA; THENCE BY LAND NOW OR FORMERLY OF SAID K. JANE MCCREA, SOUTH 3 DEGREES WEST 26 PERCHES TO CORNER OF LAND NOW OR FORMERLY OF JOHN MCCREA AND W.H. MCCREA, JR.; THENCE BY THE LAST MENTIONED LAND, SOUTH 87 DEGREES WEST 11.5 PERCHES (INADVERTENTLY RECITED AS 115 PERCHES IN PRIOR DEED OF RECORD) TO A POST, THENCE BY THE SAME, NORTH 3.50 DEGREES EAST 15 PERCHES TO A CORNER TO MCCREA AND THIS TRACT; THENCE CONTINUING ON THIS SAME COURSE ALONG LANDS NOW OR FORMERLY OF MARLIN YORE (FORMERLY PART OF THIS TRACT}, 151.3 FEET TO A POST; THENCE BY THE SAME, NORTH 82.25 DEGREES WEST 188.6 FEET TO A POST; THENCE BY THE SAME, NORTH 65 DEGREES WEST 66 FEET. TO A POST; THENCE BY THE SAME, NORTH 80 DEGREES 15 MINUTES WEST 101 FEET TO A POINT IN THE AFORESAID PUBLIC ROAD; THENCE BY SAID ROAD, NORTH 3.50 DEGREES EAST 10.7 PERCHES TO A POINT, THE PLACE OF BEGINNING. PREMISES: 9 YORE ROAD, NEWVILLE, PA 17241 EXHIBIT "A" 1. .:.:. y ra~.#rrz~:,:.;rab J... _ac.,~;~ccc ~:eaei'.~~ ..., -s6rtaFfY ~ ;- ~~ O -~ R a SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-04124 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FARGO BANK MINNESOTA VS RUBY JOHN A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT RUBY JOHN A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , the within named DEFENDANT NOT FOUND as to RUBY JOHN A PER NEIGHBOR,. PROPERTY HAS BEEN VACANT FOR A MONTH. Sheriff's Costs: So answe a-: Docketing 18.00 ~~~ Service 7.80 ~~ Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 40.80 LESLIE CARSON JR 07/11/2001 Sworn and subscribed to before me this .2 3 ~f day of Protidofiotary SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-04124 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS RUBY JOHN A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT YOUNG THERESA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND as to the within named DEFENDANT YOUNG THERESA PER NEIGHBOR, PROPERTY HAS BEEN VACANT FOR A MONTH. Sheriff's Costs: So answ~ ~~~~~~ Docketing 6.00 Service .00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 21.00 LESLIE CARSON JR 07/11/2001 Sworn and subscribed to before me this a 3.cc[ day of -~UU ) A . D . Qlw„u, ~ /L~t~ ~or~otary SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-04124 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS RUBY JOHN A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT YOUNG JAMES but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND as to the within named DEFENDANT YOUNG JAMES PER NEIGHBOR, PROPERTY HAS BEEN VACANT FOR A MONTH. Sheriff's Costs: So answer s Docketing 6.00 Service .00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 21.00 LESLIE CARSON JR 07/11/2001 Sworn aild subscribed to before me this =?3~K day of ,Zyo f A . D . . CZ. ham.- Pro h notary y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK MINNESOTA, N.A S/B/M/ TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INS. FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER THE POOLING AND SERVICING AGREEMENT DATED JUNE 1, 2000 PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA I7241 DEFENDANT(S). CIVIL DIVISION C~LAINT IN EJECTMENT CODE MORTGAGE FORECLOSURE EVICTION FILED ON BEHALF OF PLATNTIFF COUNSEL OF RECORD FOR THIS PARTY: LESLIE J. CARSON, JR. 6378 LANCASTER AVENUE PHILADELPHL?A, PA 19151 215-568-1980 NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ~~##$###:###::#a$s*#:ssss**a*##:#s##sa###:*:*:#~~ss«~##sssa~ss###s# 1. This is an attempt to collect a debt and a~ information obtained will be used for that purpose. II. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. III. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. LESLIE J. CARSON, JR., ESQUIRE ATTORNEY I.D. NO. 05111 6378 LANCASTER AVENUE PHILADELPHIA, PA 19151 ATTORNEY FOR PLAINTIFF TELEPHONE (215) 568-1980 WELLS FARGO BANK OF MINNESOTA, N.A. S/B/M TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2000 505 S. MAIN STREET, SUITE 600 ORANGE, CA 92$68 COURT OF COMMON PLEAS CUMBERLAND COUNTY N0. PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 DEFENDANT(S). COMPLAINT IN EJECTMENT YOU HAVE BEEN SUED TN 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 THE 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. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE SETAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA. ESCRITA SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS EN CONTRA. DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO D NOTIFICACION Y POR CUALQUIER QUEJA Q ALIVIO QUE ES PEDIDO AVISO 0 NOTTFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTS. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFTCIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WELLS FARGO BANK OF MINNESOTA, N.A. S/B/M TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2000 505 S. MAIN STREET, SUITE 600 ORANGE, CA 92868 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 DEFENDANT(S). COMPLAINT IN EJECTMENT ],. The plaintiff is the corporation named above, having its principal office as stated on the preceding page. 2. The Defendants and all others who reside at the premises are those named above and they reside at the address stated thereon, which are, hereinafter referred to as the Premises. 3. The Premises which are described in Exhibit "A" attached hereto and incorporated herein by reference, were sold at Sheriff's Sale on June 6, 2001 by the Sheriff of the County in which they are located, after due advertisement according to law, under and by virtue of a Writ of Execution issued to satisfy a judgment entered in the Court of Common Pleas of said County at the suit of: Norwest Bank of Minnesota, N.A., et al. - vs.- John A. Ruby. The case number of said judgment is: 2000-8649. 4. The Premises were purchased by the plaintiff at the Sheriff's Sale pursuant to an assignment of bid. 5. The Plaintiff acquired title to the premises on the date of and by virtue of said Sheriff's Sale, pursuant to an assignment of the bid and is still the real owner of said premises. 6. The persons in possession of the premises are the defendants in this action and are occupying the premises without right and without claim to title. 7. Plaintiff has demanded possession of the Premises from the defendants who have refused to deliver up the possession thereof. WHEREFORE, the Plaintiff demands judgment for immediate possession of the premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. BY: !mod/~ lie J. son, Jr., Esquire ttornev for Plaintiff VERIFICATION The undersigned hereby verifies that he is the attorney for Plaintiff, a corporation; that he is authorized to make this verification and does so because Plaintiff corporation must verify through agents and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge, information, and belief and the source of his information is public records and reports of Plaintiff's agents. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. L i J. C on, r., qu re / / torney for Plaintiff Dated: ~~ r/// / ALL THAT CERTAIN TRACT OF LAND, TOGETHER WITH THE IMPROVEMENTS, THEREON ERECTED, SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POST IN A PUBLIC ROAD (FORMERLY THE STATE ROAD .LEADING FROM NEWVILLE TO DOUBLING GAP); THENCE BY AN ABANDONED ROAD (FORMERLY LEADING TO GINTER'S MILL). SOUTH 71,75 DEGREES EAST 18.1 PERCHES TO A FENCE POST; THENCE BY THE SAME, SOUTH 65.75 DEGREES EAST 14 PERCHES TO A STONE AT CORNER OF LANDS FORMERLY OF K. JANE MCCREA; THENCE BY LAND NOW OR FORMERLY OF SAzD K. JANE MCCREA, SOUTH 3 DEGREES WEST 26 PERCHES TO CORNER OF LAND NOW OR FORMERLY OF JOHN MCCREA AND W.H. MCCREA, JR.; THENCE BY THE LAST MENTIONED LAND, SOUTH 87 DEGREES WEST 11.5 PERCHES (INADVERTENTLY RECITED AS 115 PERCHES IN PRIOR DEED OF RECORD) TO A PO5T, THENCE BY THE SAME, NORTH 3.50 DEGREES EAST 15 PERCHES TO A CORNER TO MCCREA AND THIS TRACT; THENCE CONTINUING ON THIS SAME COURSE ALONG LANDS NOW OR FORMERLY OF MARLIN YOHE (FORMERLY PART OF THIS TRACT), 151.3 FEET TO A POST; THENCE BY THE SAME, NORTH 82.25 DEGREES WEST 188.6 FEET TO A POST; THENCE BY THE SAME, NORTH 65 DEGREES WEST 66 FEET TO A POST; THENCE BY THE SAME, NORTH 80 DEGREES 15 MINUTES WEST 101 FEET TO A POINT IN THE AFORESAID PUBLIC ROAD; THENCE BY SAID ROAD, NORTH 3.50 DEGREES EAST 10.7 PERCHES TO A POINT, THE PLACE OF BEGINNING. PREMISES: 9 YOHE ROAD, NEWVILLE, PA 17241 EXHIBIT "A" ~~ ~~ ~~S" O ~~ %4 ~ ~r- Ira ~t,~~. ~~ ~ E ~~~ rva,c.iv IN THE CO[}RT OF C(N PLEA3 OF CtRLAND CO~iTY, PENNSYLVANIA WELLS FARGO $ANK MINNESOTA, N.A. SJB/M/ TO NOR~iE3T BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERI¢UEST MORTGAGE SECURITIES, INS. FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER THE POOLING AND SERVICING AGREEMENT DATED JUNE 1, 2000 PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 DEFENDANT(S). CIVIL DIVISION COt4PLA.INT I1z BJSCTt~liT CODE MORTGAGE FORECLOSURE EVICTION FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PA1tTY: LESLIE J. CARSON, JR. 6378 LANCASTBR AVSNUS PHILADBLPHIA, PA 19151 215-568-1980 ######ii#i~i#i####M#####ti####i#i#i########4#~Fi###~F#i##q#i###i#####ii#########i### NOTICE PURSUANT TO FAIIt DEBT COLLECTION PRACTICES ACT :~~#s~s**~#s*s**ss##~**$*#*s*#s*s*ssssss:ss*#ss*#ssss*s®ses*s**##« This is an attempt to collect a debt and any information obtained will be used for that purpose. II. Unless you dispute the validity of this debt, or any portic+n thereof; within 30 days after receipt of this notice, the debt wdl be assumed to be valid by o~u offices. III. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof; is disputed, our offices will provide you with verification of the debtor copy of the Judgment against you, and a copy of such verifies or judgmem wrU be na~rled to you by our offices. LESLIE J. CARSON, JR., ESQUIRE ATTORNEY I.D. NO. 05111 6378 LANCASTER AVENUE PHILADELPHIA, PA 19151 ATTORNEY FOR PLAINTIFF TELEPHONE {215) 568-1980 WELLS FARGO BANK OF MINNESOTA, N.A. S/B/M TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERI¢UEST MORTGAGE SECURITIES, INC., FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2000 505 S. MAIN STREET, SUITE 600 ORANGE, CA 92868 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 DEFENDANT(S). COMPLAINT IN YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWIPTG 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 ANp 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 $E 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 THE PAPER TO YOUR LAWYER AT ONCE. IF YQU 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. LAWYER REFERENCE SERVICE CUMBERLAND COUNTX BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 1'7013 717-249-3166 LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE SETAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO 5E DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA LISTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. LISTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTS. SI NO TIENE ABOGAAO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE FUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WELLS FARGO BANK OF MINNESOTA, N.A. S/B/M TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUE5T MORTGAGE SECURITIES, INC., FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2000 S05 S. MAIN STREET, SUITE 600 ORANGE, CA 92868 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. PLAINTIFF, vs. JOHN A. RUHY and THERESA YOUNG and JAMES XOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 DEFENDANT(S). COMPLAINT IN EJECTMENT 1. The plaintiff is the corporation named above, having its principal office as stated on the preceding page. 2. The Defendants and all others who reside at the premises are those named above and they reside at the address stated thereon, which are, hereinafter referred to as the Premises. 3. The Premises which are described in Exhibit "A" attached hereto and incorporated herein by reference, were sold at Sheriff's Sale on June 6, 2001 by the Sheriff of the County in which they are located, after due advertisement according to law, under and by virtue of a Writ of Execution issued to satisfy a judgment entered in the Court of Common Pleas of said County at the suit of: Norwest Bank of Minnesota, N.A., et al. - vs.- John A. Ruby. The case number of said judgment is: 2000-8649. 4. The Premises were purchased by the plaintiff at the Sheriff's Sale pursuant to an assignment of bid. 5. The Plaintiff acquired title to the premises on the date of and by virtue of said Sheriff's Sale, pursuant to an assignment of the bid and is still the real owner of said premises. 6. The persons in possession of the premises are the defendants in this action and are occupying the premises without right and without claim to title. 7. Plaintiff has demanded possession of the Premises from the defendants who have refused to deliver up the possession thereof. WHEREFORE, the Plaintiff demands judgment for immediate possession of the premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. BY: ~~ s ie J. son, Jr., Esquire `Fttorney for Plaintiff VERIFICATION The undersigned hereby verifies that he is the attorney for Plaintiff, a corporation; that he is authorized to make this verification and does so because Plaintiff corporation must verify through agents and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge, information, and belief and the source of his information is public records and reports of Plaintiff's agents. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. Dated: /_/~ p~~ es J. C n, Jr., Esquire A orney for Plaintiff ALL THAT CERTAIN TRACT OF LAND, TOGETHER WITH THE IMPROVEMENTS, THEREON ERECTED, SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POST IN A PUBLIC ROAD (FORMERLY THE STATE ROAD LEADING FROM NEWVILLE TO DOUBLING GAP); THENCE BY AN ABANDONED ROAD (FORMERLY LEADING TO GINTER'S MILL). SOUTH 71.75 DEGREES EAST 18.1 PERCHES TO A FENCE POST; THENCE BY THE SAME, SOUTH F5.75 DEGREES EAST 14 PERCHES TO A STONE AT CORNER OF LANDS FORMERLY OF K. JANE MCCREA; THENCE BY LAND NOW OR FORMERLY OF SAID K. JA1dE MCCREA, SOUTH 3 DEGREES WEST 26 PERCHES TO CORNER OF LAND NOW OR FORMERLY OF JOHN MCCREA AND W.H. MCCREA, JR.; THENCE BY THE LAST MENTIONED LAND, SOUTH 87 DEGREES WEST 11.5 PERCHES (INADVERTENTLY RECITED AS 115 PERCHES IN PRIOR DEED OF RECORD) TO A POST, THENCE BY THE SAME, NORTH 3.50 DEGREES EAST 15 PERCHES TO A CORNER TO MCCREA AND THIS TRACT; THENCE CONTINUING ON THIS SAME COURSE ALONG LANDS NOW OR FORMERLY OF MARLIN YORE (FORMERLY PART OF THIS TRACT), 151.3 FEET TO A POST; THENCE BY THE SAME, NORTH 82.25 DEGREES WEST 188.6 FEET TO A POST; THENCE BY THE SAME, NORTH 65 DEGREES WEST 66 FEET TO A POST; THENCE BY THE SAME, NORTH 80 DEGREES 15 MINUTES WEST 101 FEET TO A POINT IN THE AFORESAID PUBLIC ROAD; THENCE BY SAID ROAD, NORTH 3.50 DEGREES EAST 10.7 PERCHES TO A POINT, THE PLACE OF BEGINNING. PREMISES: 9 YOHE ROAD, NEWVILLE, PA 17241 EXHIBIT "A" !: I ~J i ~ j (. :`, r `~~ v r r ~; `~ ~-;~ %.ti \, ~~~~ U (1 J~ ','r~~']tr„. ~s.ch.,,. ~ 2nr ~~, ~3frs .,a f,, .=r;~~ ;;j.~a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK MINNESOTA, N.A S/B/M/ TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INS. FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER THE POOLING AND SERVICING AGREEMENT DATED JUNE 1, 2000 PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 DEFENDAt3T (s) . CIVIL DIVISION N0. O~ ~- '~//~Y ~ttttl. /f/LJry~ COMPLAINT IN EJECTMENT CODE MORTGAGE FORECLOSURE EVICTION FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PARTX: LESLIE J. CARSON, JR. 6378 LANCASTER AVENUE PHILADELPHIA, PA 19151 215-568-1980 ###############################################i##################################### NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ~:$ass:#:#saaass:#*###as####~**a##~s~~s~ss##~#*####s#:###ssa#*#:## This is an attempt to collect a debt and any information obtained will be used for that purpose. II. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. III. If you notify our offices in writing within 30 days of receipt of tins notice that the debt, or any portion thereof; is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy off such verification or judgment will be mailed to you by our offices. LESLIE J. CARSON, JR., ESQUIRE ATTORNEY I.D. N0. 05111 6378 LANCASTER AVENUE PHILADELPHIA, PA 19151 ATTORNEY FOR PLAINTIFF TELEPHQNE (215) 568-1980 WELLS FARGO BANK OF MINNESOTA, N.A. S/B/M TO NORWEST BANK OF MINNESOTA, N.A. A5 TRUSTEE OF 1~MERIQUEST MORTGAGE SECURITIES, INC., FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2000 505 S. MAIN STREET, SUITE 600 ORANGE, CA 92868 COURT OF COMMON PLEA5 CUMBERLAND COUNTY NO. PLAINTIFF, vs. ,70HN A. RUBY and THERESA YOUNG and JAME5 YOUNG and ALL TENANTS/OCCUPANTS 9 YORE ROAD NEWVILLE, PA 17241 DEFENDANT(S). COMPLAINT IN EJECTMENT YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAIN5T THE CLAIMS 5ET 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 THE PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE pFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 LE HAN DEMANDADO A LISTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE SETAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS 0 SUS OBJECIONE5 A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO 5E DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA LISTED SIN PREVIO AVISO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALIVIO QUE ES PEDIDO AVISO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO 0 SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARR USTED. LLEVE E5TA DEPIAI3DA A UN ABOGADO INMEDIATAMENTS. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WELLS FARGO BANK OF MINNESOTA, N.A. S/B/M TO NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., FLOATING RATE PASS-THROUGH CERTIFICATES, SERIES 2000-2 UNDER POOLING AND SERVICING AGREEMENT DATED A5 OF JUNE 1, 2aoo 505 S. MAIN STREET, SUITE 600 ORANGE, CA 92868 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. PLAINTIFF, vs. JOHN A. RUBY and THERESA YOUNG and JAMES YOUNG and ALL TENANTS/OCCUPANTS 9 YOHE ROAD NEWVILLE, PA 17241 DEFENDANT(S), COMPLAINT IN EJECTMENT 1. The plaintiff is the corporation named above, having its principal office as stated on the preceding page. 2. The Defendants and all others who reside at the premises are those named above and they reside at the address stated thereon, which are, hereinafter referred to as the Premises. 3. The Premises which are described in Exhibit "A" attached hereto and incorporated herein by reference, were sold at Sheriff's Sale on June 6, 2001 by the Sheriff of the County in which they are located, after due advertisement according to law, under and by virtue of a Writ of Execution issued to satisfy a judgment entered in the Court of Common Pleas of said County at the suit of: Norwest Bank of Minnesota, N.A., et al. - vs.- John A. Ruby. The case number of said judgment is: 2000-8649. 4. The Premises were purchased by the plaintiff at the Sheriff's Sale pursuant to an assignment of bid. 5. The Plaintiff acquired title to the premises on the date of and by virtue of said Sheriff's Sale, pursuant to an assignment of the bid and is still the real owner of said premises. 6. The persons in possession of the premises are the defendants in this action and are occupying the premises without right and without claim to title. 7. Plaintiff has demanded possession of the Premises from the defendants who have refused to deliver up the possession thereof. the Plaintiff demands judgment for immediate possession of the premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. $Y: s ze J. son, Jr., Esquire ttorney for Plaintiff VERIFICATSON The undersigned hereby verifies that he is the attorney for Plaintiff, a corporation; that he is authorized to make this verification and does so because Plaintiff corporation must verify through agents and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge, information, and belief and the source of his information is public records and reports of Plaintiff's agents. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. Dated: /'~ v ~~i~/~ Y~`S9.ie J. CCU-r`§on, Jr., Esquire Attorney for Plaintiff ALL THAT CERTAIN TRACT OF LAND, TOGETHER WITH THE IMPROVEMENTS, THEREON ERECTED, SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POST IN A PUBLIC ROAD (FORMERLY THE STATE ROAD LEADING FROM NEWVILLE TO DOUBLING GAP); THENCE BY AN ABANDONED ROAD (FORMERLY LEADING TO GINTER'S MILL). SOUTH 71.75 DEGREES EAST 18.1 PERCHES TO A FENCE POST; THENCE BY THE SAME, SOUTH 65.75 DEGREES EAST 14 PERCHES TO A STONE AT CORNER OF LANDS FORMERLY OF K. JANE MCCREA; THENCE BY LAND NOW OR FORMERLY OF SAID K. JANE MCCREA, SOUTH 3 DEGREES WEST 26 PERCHES TO CORNER OF LAND NOW OR FORMERLY OF JOHN MCCREA AND W.H. MCCREA, JR.; THENCE BY THE LAST MENTIONED LAND, SOUTH 87 DEGREES WEST 11.5 PERCHES (INADVERTENTLY RECITED AS 115 PERCHES IN PRIOR DEED OF RECORD) TO A POST, THENCE BY THE SAME, NORTH 3.50 DEGREES EAST 15 PERCHES TO A CORNER TO MCCREA AND THIS TRACT; THENCE CONTINUING ON THIS SAME COURSE ALONG LANDS NOW OR FORMERLY OF MARLIN YORE (FORMERLY PART OF THIS TRACT), 151.3 FEET TO A POST; THENCE BX THE SAME, NORTH 82.25 DEGREES WEST 188.6 FEET TO A POST; THENCE BY THE SAME, NORTH 65 DEGREES WEST 66 FEET TO A POST; THENCE BY THE SAME, NORTH 80 DEGREES 15 MINUTES WEST 101 FEET TO A POINT IN THE AFORESAID PUBLIC ROAD; THENCE BY SAID ROAD, NORTH 3.50 DEGREES EAST 10.7 PERCHES TO A POINT, THE PLACE OF BEGINNING. PREMISES: 9 YOHE ROAD, NEWVILLE, PA 17241 EXHIBIT ~~A" (~~ ~o~ ~~~~~