HomeMy WebLinkAbout01-04552a~~ ~~~
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND ss.
Robert P Ziegler
h ----------------------------------------------------°------------------------ RecorderoE
Deeds in and for uid County and State do'hereby certify that the Sheriff's Deed in which ________________
Conseco Fin Con Disc Co
------------------°-------•--------------------------------------------------------isthe grantee
6th
the ume having been sold to said grantee on the _______________________________________________ day of
March 02
°------------------------°---------_-- A. D., ' __---, under and by virtue of a writ------------_-
Execution
Sept
day of ---------------
Civil
A. D.,
4552
Number ______________, atthe suit of ___
27th
-------issued on the -------------------------------------
_ O1 _, out of the Court of Comanan Pleas of said County'as of
Ol
---------------------------------------- Tenn,: ------
Conseco Fin Con Disc Co
Terry J Robinson & Sharon C
---------°------------------------ against---------------------------------------------------- as
251 1376
dulytroordediaSherifFsDeedBookNo.____________, Page____________.
IN TESTIMONY WHEREOF, I h//a/~vyye hereunto
set my hand and seal of said office this -1.(_~ day
of --~itu ~---------~:---- A+~. ~.,~
Deeds
Conseco Finance Consumer Discount
Company
VS
Terry J. Robinson and
Sharon C. Robinson
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-4552 Civil Term
Douglas Donsen, Deputy Sheriff, who being duly sworn according to law, states
that on November 7, 2001 at 3:41 o'clock pm, EST, he served a true copy of the within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Terry J. Robinson, by making known unto Sharon Robinson,
adult in charge, at 254 North Enola Drive, Enola, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Douglas Donsen, Deputy Sheriff, who being duly sworn according to law, states
that on November 7, 2001 at 3:41 0' clock pm, EST, he served a true copy of the within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Sharon C. Robinson, by making known unto Sharon Robinson
personally, at 254 North Enola Drive, Enola, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that
on January 03, 2002 at 1:01 o'clock P.M., E.S.T., he posted a true copy of the within
Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Terry J. Robinson and Sharon C. Robinson located at 2157 Ritner Highway,
Shippensburg, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Terry J. Robinson, by regular mail to his last known address of 254
North Enola Drive, Enola, PA 17025. This letter was mailed under the date of January
18, 2002 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Sharon C. Robinson, by regular mail to her last known address of 254
North Enola Drive, Enola, PA 17025. This letter was mailed under the date of January
18, 2002 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the
sum of $1.00 to Attorney Gregory Javardian for Conseco Finance Cnsumer Discount
Company. It being highest bid and best price received for the same Conseco Finance
Consumer Discount Company of 7360 So Kyrene, Tempe, AZ 85283, being the buyer in
this execution paid Sheriff R. Thomas Kline the sum of $2145.97 it being costs.
Sheriff s Costs:
Docketing 30.00
Poundage 800.00
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 18.85
Certified Mail 2.32
Levy 15.00
Surcharge 30.00
Legal Search 200.00
Law Journal 497.90
Patriot News 404.70
Share of Bills 24.20
Distribution of Proceeds 25.00
Sheriffls Deed 26.50
$2145.97
Sworn and subscribed to before me
This ~ day of ~°f'~'°
2002, A.D.
ro onotary
So ~~ ~~~
R. Thomas Kline, Sheriff
B~C~-~~iwi~~
Real Estate Deputy
~ ~ Ate'"'
301 3ro
c:42.. 3L3a't
~„ i.z yaYa-
SCHEDULE OF DISTRIBUTION
SALE NO. 11
Writ No. 2001-4552 Civil Term
Conseco Finance Consumer Discount Company
VS
Terry J. Robinson and Sharon C. Robinson
2157 Rimer Highway
Shippensburg, PA 17257
Sale Date: March 6, 2002
Buyer: Conseco Finance Consumer Discount Company
Bid Price: $40,000.00
Real Debt $88,958.03
Interest 2,426.92
Writ Costs 125.10
Total $91,510.05
DISTRIBUTION
Amount Collected $2,145.97
Sheriff s Costs 1,945.97
Legal Search 200.00
S s er ' ~~~
R. Thomas Kline
Sheriff
TITLE REPORT
THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING
TI'EMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY
EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED.
SHERIFF SALE NO. 11
Held Wednesday, March 6, 2002
Date: March 6, 2002
TAXES: Receipts for all taxes for the years 1999 to 2001 inclusive. Taxes for the current year
2002.
WATER RENT: Company assumes no liability for private supply of water or sewer.
SEWER RENT Receipts to be produced if services are lienable.
MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims.
MUNICIPAL CLAIMS
MORTGAGES: Listed Under Other Exceptions Below.
JUDGMENTS: Listed Under Other Exceptions Below.
INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to
dated , 2002, and recorded
2002, in Cumberland County Deed Book ,Page
RECITAL: Being the same premises which Barbara L. McMullen, wunairied„ by deed dated
April 19, 1996 and recorded April 19, 1996 in the Office of the Recorder of Deeds in and for
Cumberland County at Carlisle, Pennsylvania in Deed Book 137, Page 965 granted and conveyed
to Terry J. Robinson and Sharon C. Robinson, husband and wife.
OTHER EXCEPTIONS:
L The identity and legal competency of parties at the closing of this title should be
established to the satisfaction of the closing attorney acting for this Company.
Rights or claims of parties in possession, if any, other than the owner.
3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area
and encroachments which an accurate and complete survey would disclose.
4. Payment of State and local Real Estate Transfer Taxes, if required.
5. Public and private rights in the roadbed of US Route No. 11 known as the
RitnerHighway.
6. Private rights in a 50 foot wide private right-of--way located immediately adjacent to the
eastern boundary of the subject premises as imposed by deed recorded in Deed Book 109, Page
092..
7. Mortgage in the amount of $73,200.00 given by Terry J Robinson and Sharon C.
Robinson to Greentree Consumer Discount Company dated August 14,1996 and recorded August
15,1996 in Mortgage Book 1336, Page 572.
Complaint in mortgage foreclosure filed by Conseco Finance Consumer Discount
Company as Plaintiff against Terry J. Robinson and Shazon C. Robinson as Defendants on July
30, 2001 in the Office of the Prothonotary of Cumberland County on July 19, 2001 to file number
2001-4552. Judgment in the amount of $88,958.03 entered September 27, 2001.
8. Satisfactory evidence to be produced that complaint in foreclosure was properly
brought by Conseco Finance Consumer Discount Company where Mortgagor of record in
Greentree Consumer Discount Company.
10. Satisfactory evidence to be produced that proper notice was given to the holders of all
liens and encumbrances intended to be divested by subject Sheriff Sale.
11. Real estate taxes accruing on and after July 1, 2002 not yet due and payable.
It is to be noted that no search of Domestic Relations Records has been made to
determine support arrearages regarding House Bi111412, Act 58 of 1997, nor has any
search been made for environmental liens in Federal District Court.
~,
Ro ert G. Frey, Agent
Note: This Title Report shall n alid or binding
until countersigned by an authorized signatory.
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CONSECO FINANCE CONSUMER
DISCOUNT COMPANY
vs.
TERRY J. ROBINSON
SHARON C. ROBINSON
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 01-4552
AFFIDAVIT PURSUANT TO RULE 3129.1
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution
was filed the following information concerning the real property located at 2157 RITNER
HIGHWAY. SHIPPENSBU)ZG. PA 17257:
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
TERRY J. ROBINSON
SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
2. Nam and address of Defendant(s) in the judgment:
TERRY J. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
3. Name and last known 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 ascertain~l, Please indicate)
None.
~R
4, Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, Please indicate)
Plaintiff.
S. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address oannot be
reasonably ascertained, Please indicate)
None.
6. Name and address of every other person who has a~ record interest in the property and whose
interest maybe affected by the sale.
Name
Last Known Address (ff address cannot be
reasonably ascertained, Please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
Dept. of Public Assistance
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
33 Westminster Drive, P.O. Box S99
Carlisle, PA 17013-0599
7. Name and address of every other person of whom the plaintiff has knowledge who has a~
interest in the property which may be affected by the sale:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenaats/Occupants 2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief I understand that false statements herein are subject to the
penahies of 18 Pa. C.S.A. 4904 relating to tmsworn falsification to authorities.
c
G G Y J VARDIAN, ESQUIRE
orney f laintiff
September 21, 2001
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIltE
II?ENTIFICATION Nq.55669
44 SECOND STREET PII~, SUITE 101
SOLPI'HAMP1'ON, PA 18966
215) 942-9690
CONSECO FINANCE CONSUMER COURT OF COMMON PLEAS
DISCOUNT COMPANY
CUMBERLAND COUNTY
vs.
No.: 01-4552
TERRY 7. ROBINSON
SHARON C. ROBINSON
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TERRY J, ROBINSON
SHARON C. ROBINSON
2157 RITNER ffiGHWAY
SHIPPENSBURG, PA 17257
Your house (real estate) at 2157 RITNER HIGHWAY. SHQ'PENSBj.JI;G~,PA 17257. is
scheduled to be sold at Sheriff s Sale on MARCH 6. ~Q02 at 10:00 A.M , in the Cumberland County
Coutttmuse, 1 Courthou~ Square, Carlisle, PA 17013, to enforce the court judgment of $88,458.03,
obtained by CONSECO FINANCE CONSUMER BISCOUNT COMPANY, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS~SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale w~71 be cancelled ifyou pay to the nbrtgagee the tack payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 2L$2
942-9690.
2. You may be able to stop the sate h3' filing a petition asking the Court to stn7ce or open the
judgment, if the judgatent 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 pmoeedings.
You may need an attorney to avert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See tmtice on page two on how to obtain an attarneyJ
i. Ifthe Sheriil's Sale is not stopped, your property will be sold to the highest bidder. You
~y find out the price bid by calling j21 ~ 942-969Q.
2. Yau may be ab~ to petition the Court to set aside the sale id'the hid price was grossly
npadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the fiill amount due in the sale.
To find out if this bas happened, you may call Gregory Javardian, Esquire at (215) 942.9690.
4. If the amount due from the Buyer is not paid to the Sheriil; you will remain the owner of
the property as if the sak 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.
b. You maybe entitled to a share of the money which was paid for your house. A schedule
of distn'bution of the money bid for your house will be filed by the Sheriff. This schedule will'. state
who wilt be receiving that money. The money will be paid out in accordance with this schedule
unless excepiiOna (reams why the proposed distn'bution is wrong) are fi~ with the Sheriffwithin
ten (10) days.
7. You may also have other rights ami 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. H' YUTJ D~ NQT
HAVE A LAWYER OR CANNOT AI'FORD ONE, GO TO OR TELEPHOONE THE O FICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-316b
(800) 990A108
ALL that certain tract of land situate in the Village of Stoughstown, North Newton Township,
Cumberland County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point, a Parker kalon nail in the centerline of the Ritner Highway (U.S. Route
11), at corner of lands now or formerly of Sharp S. Jumper; thence along lands now or formerly
of Sharp S. Juniper, North eighteen (18) degrees twenty-eight (28) minutes forty-three (43)
ponds West, two hundredtwenty-six and sixty-five hundredths (226.25) feet (passing through
an iron pin on line twenty-five and eleven hundredths (25.11) feet from the aforesaid Parker
kalon nail) to an iron pin; thence akng lands now or formerly of Terry I. and Sharon C.
Robinson, South seventy (70) degrees fifty-three (S3) minutes thirty-two (32) seconds West, nine
arxi fifteen hundredths (9.15) feet to an iron pim; thence along lands of same South §eventy--one
(71) degrees thirty-two (32) minutesfifty-two (S2) seconds West, one hundred one and thirty-
seven hundredths (101.37) feet to an iron pin; thence along lands now or formerly of Allen R
Williams, South zero (00.00) degreesfifty-nine (S9) minutesforty-nine (49) seconds West,lnrty-
three attd seventy-nine hundredths (43.79) feet to an iron pin; thence along lands of same, South
sixteen (16) degrees fifty--nine (S9) minutesfifty-six (S6) seconds East, one hundred ninety-one
and seventy-one hundredths (191.71) feet to a Parker kalon nail in the centerline of the Rimer
Highway (U.S. -Route i i) (passing through an iron pin on line tweet}-five and eighteen
hundredths (25.18) feet from the aforesaid Parker kalon nab; thence over the centerline of
Rimer Highway (tT.S. Route 11) North sixty-six (66) minutesthirty-four (34) seconds East, one
hundred thirty and eighty-one hundredths (130.81) feet to a Parker kalon nail, the point and place
of BEGINNING.
Containing 29,272 square feet, more or less.
SUBJECT to a fifty (SO} feet wide private a~ight-of-way located immediately adjacenR to the
eastern boundary of the lot herein conveyed, for ingress, egress, and regress to a certain parcel of
land consisting of 5.570 sores, more or less, lying immediately to the North of the lot herein
conveyed and being owned by Terry J. and Sharon C. Robinson, husband and wife, through deed
from Tames W. Robinson dated July 8, 1994, and recorded in Cumberland County Deed Book
109, page 092.
The description of the lot herein conveyed was taken from a re-survey of said lot, by Carl D.
Bart, RS., dated March i, 1995.
BEING known as 2157 Rimer Highway, Shippensburg, PA 17257.
BEING THE SAME PREMISES which Bazbara L. McMullen, unmarried, by Deed dated
April 19, 1996 and recorded April 19, 1996 in Deed Book 137, page 965, in the Recorder of
Deeds Office in and for Cumberland County, granted and corrveyed unto Terry L. Robinson and
Sharon C. Robinson, husband and wife.
1NRIT OF EXECUTION and/or ATTACHBAENT
COMMONWEALTH OF PENNSYLVANIA) NO. 01-4552 CIVIL 1J~?'E~
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due Conseco Finance Consumer Discount Cartpany
PLAINTIFF(S)
from Terry J. Robinson and Sharon C. Robinson, 2157 Ritner Highway, Shippensburg,
PA 17257
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notrfy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property of thedefendant(s)notlevieduponansubjecttoattachmeniisfoundinthepossessionotanyoneother
than a named garnishee, you are directedtonotify hirNherthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $88,958.03
fran 9/21/01 to date of sale
Interest _~~~ 62~e~ d~~
Atty's Comm
Atty Paid
Plaintiff F
L.L. $.50
Due Prothy $1.00
Other Costs
Date: SPntember 27. 2001 ,_~ Curtis R. Long
Prothonotary, Qivil'Division
REQUESTING PARTY:
Name Gregory Javardian, Esq.
Address: 44 Second Street, Pike, Suite 101
Southampton, PA 18966
Attorney for: Plaintiff
Telephone: 215-942-9690
Supreme Court ID No. 55669
C- Deputy
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
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 Joumal, 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,
JANUARY 25, FEBRUARY 1, 8, 2002
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Joumal, 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.
l\
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
8 day of FEBRUARY. 2002_
L04S E. ER, ~ ~
w edis6e , ~ PAa~h 5,
REAL EsrnrE snt,E xo. 1a
Writ No. 2001-4552 Civil
Conseco. Finance Consumer
Discount Company
vs.
Terry J. Robinson and
Shazon C. Robinson
Atty.: Gregory Javaxdian
ALL that certain tract of land situ-
ate in the Village of Stoughstown.
North Newton Township. Cumber-
land Couny. Pennsylvania, more
particularly bounded and described
as follows:
BEGINNING at a point, a Pazker
kalon nail in the centerline of the
Rimer Highway (U.S. Route 11), at
comer of lands now or formerly of
Sharp S. Jumper: thence along lands
now or formerly of Sharp S. Jumper.
North eighteen (18) degrees twenty-
eight (281 minutes forty-three (43)
seconds West, two hundred twenty-
six and sixty-five hundredths (
(226.25) fee[ (passing through an
iron pin on line twenty-five and
eleven hundredths (25.11) feet from
the aforesaid Parker kalon nail) to
an iron pin: thence along lands now
or formerly of Terry J. and Sharon
C. Robinson, South seventy (70)
degrees Fifty-three (53) minutes
thirty-two (32) seconds West. nine
and fifteen hundredths (9.15) feet
m an iron pin: thence along lands
of same South seventy-one (71) de-
grees thirty-two (32) minutes fifty-
tvro (52) seconds West. one hvndied
one and thirty-seven hundredths
(101.37) feet to an iron pin: then ~,
along lands now or formerly of Allc.,
R William. South zero (00.00) de- _
grees fffty-nine (59) minutes forty- '
nine (49] seconds West, forty-three
and seventy-nine hundredths (43.79)
feet to an iron pin; thence along
lands of same, South sixteen (16)
degrees fdty-nine (59) minutes fifty-
six [56) secbnds East, one hundred
ninety-one and seventy-one hun-
dredths (191.71) feet to a Parker
kaion nail in the centerline of the
Rimer Highway (U.S. Route 11)
(Passing through anuon pin on line
twenty-five and eighteen hundredths
(25.18) feet from the aforesaid
Parker kalon nail): thence over the
centerline of Rimer Highway (U.S.
Route 11) North sixty-six (66) degrees
six I6) minutes thirty-four (34) sec-
onds East, oae hundred thirty and
eighty-one hundredths (130.81) feet
to a Parker kalon nail. the point and
place of BEGINNRVG
Conranung 29,'l92 squaze feet.
more or less.
SUBIECT to a fifty (50) feet wide
private right-of--way located imme-
diately adjacent to the eastern
boundary of the lot herein conveyed.
for ingress, egress. and regress to
a certain pazcel of land Consisting
of 5.570 acres. more or less, lying
Immedia[ely to [he No.-th cf the lot
herein conveyed and being owned
by Terry J. and Sharon C. Robin-
son, husband and wife. through
deed from James W. Robinson
dated July 8, 1994, and recorded
in Cumberland County Deed Book
109, page 092.
The description of the lot herein
conveyed was taken from a
re-survey of said lot, by Carl D.
Bert, ft.S., dated March 1. 1995.
BEING known as 2157 Ritner
Highway, Shippensburg. PA 17257.
BEING THE SAME PREMISES
which Barbara L. McMullen, unmar-
ried. by Deed dated April 19, 1996
and recorded April I9, 1996 in
Deed Book 137, page 965, in the
Recorder of Deeds Office in and for
Cumberland County, granted and
conveyed unto Terry L. Robinson
and Sharon C. Robinson, husbaad
and wife.
1
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Ac[ No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in 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 29th day(s) January and the 5th and 12th
day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant tc a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphi in Mi~~P Il^aneous Book "M",
Volume 14, Page 317. ~~ t( ! I1'~,( I ~~I
PUBLICATION
COPY
SALE#11
Sworn to and subscribed before thi 22nd d of F r ry 2002 A.D.
Notarial Seal
Tarty L. Rum@II, Notary Publk
Hanleburg. Dauphin County
My Commission Expires June 6, 2002 NO ARY PUBLIC
Member,PennsyNaniaASSOCiatlonotNOterie~y commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 403.20
Probating same Notary Fee(s) $ 1.50
Total $ 404.70
Publisher's Receipt for Advertising Cast
The Patriot News Co., publisher of The Patriot-News and The Sunday 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 ....................................................................
9~
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
44 SECOND STREET PIKE
SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
Attorney for Plaintiff
CONSECO FINANCE CONSUMER
DISCOUNT COMPANY
7360 SO. KYRENE
TEMPE, AZ 85283
PLAIlVTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
TERRY J. ROBINSON
SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
DEFENDANT(S)
COMPLAINT IN
MORTGAGE FORECLOSURE
COMPLAINT - C1VIL ACTION
NOTICE
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 defense or objections to the claims set forth against you. You
are warned that if you fail to do so the case may proceed without you and a judgment may
be entered against you by the Court without further notice for any money claimed in the
complaint or for any other claim or relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS NOTICE 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 FIIVD OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Cazlisle, PA 17013
717-249-3166
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
44 SECOND STREET PIKE
SUTfE 101
SOUTHAMPTON, PA 18966
(215)942-9690
Attorney for Plaintiff
CONSECO FINANCE CONSUMER
DISCOUNT COMPANY
7360 SO. KYRENE
TEMPS, AZ 85283
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
TERRY J. ROBINSON
SHARON C. ROBINSON
2157 RTi'NER HIGHWAY
SHIPPENSBURG, PA 17257
DEFENDANT(S)
NO.
COMPLAINT IN
MORTGAGE FORECLOSURE
CIVIL ACTION MORTGAGE FORECLOSURE
t. Conseco Finance Consumer Discount Company, (hereinafter referred to as
"Plaintiff') is an Insfitution, conducting business under the Laws of the
Commonwealth of Pennsylvania and brings this action to foreclosure the
mortgage between Terry J. Robinson and Sharon C. Robinson, Mortgagor(s)
(hereinafter referred to as "Defendant") and itself as Mortgagee. Said Mortgage
was dated August 14, 1996 and was recorded in the Office of the Recorder of
Deeds and Mortgages in Cumberland County in Mortgage Book 1336, page 572.
A copy of the Mortgage is attached and made a part hereof as Exhibit `A'.
2. The Mortgage is secured by Defendant(s) Note dated August 14, 1996 in the
amount of $73,200.00 payable to Plaintiff in monthly installments with an interest
rate of 12.15%.
3. The land subject to the mortgage is:
2157 Ritner Highway, Shippensburg, PA 17257.
4. The defendant(s), Terry J. Robinson and Sharon C. Robinson are the real owner(s)
of the land subject to the mortgage and the Defendants' address is :2157 Ritner
Highway, Shippensburg, PA 17257.
5. The Mortgage is now in default due to the failure of the Defendant(s) to make
payments as they become due and owing. The following amounts are due:
Principal Balance $71,041.98
Interest to 7/18/2001 11,629.63
Accumulated Late Charges 1,088.82
Attorney Fees/Costs 3,700.00
TOTAL $87,460.43
plus interest from 7/19/2001 at $23.40 per day, costs of suit and attorney fees.
6. In accordance with the provisions of the Act of January 30, 1974, P.L. 13 No.
6, Section 403 (41 P.S. 403), a Notice of Intention to Foreclose is required and
the Notice of Homeowners' Emergency Mortgage Assistance was sent to
defendants June 1, 2001. The Defendant(s) have not cured the default.
WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for
the sale of the mortgaged property in Plaintiff's favor and against the Defendant(s), in the
sum of $87,460.43 together with the interest from 7/19/2201 at $23.40 per day, costs of
suit and attorney fees.
Law offices of Gregory Javardian
BY:
JAVARDIAN
No. 55669
--
Receive: 8/23/99 t2e34PM; -> GREG JAVARpIAN LAW OFFICE; Page 2
AUG-23-1999•MON 09 16 AM FAX N0, P, 02/22
~. 'uc :',i~ ..,. ....:i ~~
_CfiCr~i' OF CC`-OC
'96 flUi1 A~ ~(~ 11 31
Cdninonwenlnt of Ikm~sylvsnix - - •- Spucv AAove ThLs 4Pne For RecordlnR Uatn
OPEN-ENY) MOKTGAGL,
This Mortgage sceutes CuWre advances
1. PATE ANLy PARI7FS. The dare of this lbCortgage (Security Instnimenr) is ........OQ~7+4I4~ ........................ and the
patties, their addtnsscs and tax idcntifieation domben, If required, are as follows:
MORTGAGOR: TERRX J RABTi,1SCS4
SI4+1~I C It17EIN9O[3
~ iC ducked, refer to the attached Addendum incorporated herein, [or additional Mortgagors, their signatures and
aetmowledgments:
LP.NDER: green Tree Aot7stader 17i.t3ewuit Qatparty
3901 gartzdale As.StE 132
Camp Ai11rPA 17011
2. CONVEYANC)t;. For good and valuable consideration, the receipt and sufficiency of which is acknowledged, and to secure
rho Scared Aebt (deeded below) and Mortgagor's performance under rids Security lnsttumcdt, Mortgagor grants, bargains,
,conveys and mortgages to Lender the fallowing described property:
HRIEF I,FJGE11, ~ YI'ICNe :- -. ". - • - -
ALL 'PRAT CF.StTAIIJ PROPEIrl"l, SIZ[]A'f.Ea TN 130RTkI 1Vf,WICRQ T01r7D7SiiIP, CTl!:H3II2UAND
Cf)L8J'1'Y AND CCM~,TH OF PkSIIJSXLVANIA ]3EING MARE FLI[d,Y DESCRiBID IN
REED ]aATEA 4-19-96,REOl'1~D 4-].9-96 AND APPFARB~ ANIt]NG THE I,AL•7D
Rk~ItI75 OF THE C70LIIJL'1t AND- STATE SEr kY~I AHOVE TN DEED HOOK 137, PAC;l;
965. - .. ._
PARCEL, 7.D 30-2.8-2040-4d2-N` -
The properly is located id :'A?`?4 .................................................... at .T....................,.........................
Together with all rights, sauments, appurtenances, royalCus, mineral rights, oil and gas rights, al! water and riparian rights,
ditches, and water stack and ali existing and Cuture improvements, structures, fixtures, and replacements that may now, or at
arty time in the future, be part of the red[ estate described above (all mferccd to as 'Properly°).
3. 1VIA)CIMUM OBLIGATION LIMIT. The tGW principal amount secured by this Security Instrutnant at any one tilno shall not
ext:ccd 5 .....7~~QR: ~9 .................................. •. This Iintitation of amount does not lndudc interest and other Tees and
charges validly Houle pnrsunnt tu this S~urity Insltuntunt. Also, lilts limitation dace not apply to advances made uadcr lire
'rums of this Security Instrument to protect Lender's security and to perform any o[ the covenants contained in this Security
Instrument. .
(county)
...................... ..................... :.................. ............::.... :Pennsylvania ...,. ....
(Addend (City) (ZIP Odle
A. SF.C[1ItED UCBT AND Fili'1)IaL AAVANCFS. The term °Secured Debt' is defined as folbws:
A. Debt incurtrxJ under the terms of sit promissory note(s), contract(s), guaranty(s) or other evidettx of debt described
,...below and all their extensions, renewals, modifications or substitutions. (R?,en referencing the debts below it is
' saggesred that you !nclNde irents such at borrower' nmaes, mote ornornus, iureresr rants, rttarariry dales, arc,)
• ~ B04Ki,3r~PAGE 572
t~IN9YLYAHIA . MOirTGAOE IN07 FOR FNMA, F/aA1C, PHA Oil VA USD
Or8a~8aJa.r enuw°. Inc., Sl.pwa. NlN n.900+t9748st1 Pam R6Mra-A lyt-IUs
fDa9e / o/ 6J
Received. B/23/99 12.34PM;
AUG-23-1999 .NON 09.16 AM
~ GfiEG JAVAROIAN LAW OFFICE;
FAX N0,
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P. 03/22
B. Alf future advance !mm Lettder to Mortgagor or other future obligariolm nC Mortgagor to Lender under any promissory
note, contract, guar..utry. or other evidence of debt ixocuted by Mongagix in favor of Lender exotttted afar this Security
lnstronlenl whether or not dies Security [nstrulnem is specifically rcfereltced. If more than one persttu signs these 5ewrity
instrument, each Mortgagot agrtvs tlraz this Security Instrument will''. securo all fuwre advances and future obligations
that are given to or incurred by any tmc or more Mortgagor, or aliy rntc or more Mortgagor atxi others. 1111 fuluro
advances .nd Mber future obligations are secured by this Security TiiStrument teen though all m part may not yet he
advanced.: Atl fuwrc advatttxs and other forme obligations are secured ae if made am the date of This Security Instrontcnt.
Nothing ]n this Security Instrument shall cettstimte a eommitroent to 'make additional or iulure loans ar advances in any
amount, Any such oonuninnclu tttust be agreal to in a separate writing.
C, All obligations MoR$agar owes to LendeY, which tray later arise, to the extant not prohibited by taw, irtchrding, but nat
limit«1 to, fiabilitiPS far overdrafts relating to any deposit account agreement between Mortgagor aztd Linder.
D. Atl additional Burns :ulvanccd amt expenses iuteurred by Leader for insuring, proetting or olluswise protecting the
Proporiy and its value and any other sums advanced and expanses incurral by Lender antler the terms of this Security
lnswmcnt.
This Steurlty Instrument will ant secure any other debt i[ Lender falls to 8ive ally required notice of the right of rcsiission.
5, PAYMENTS. Mortgagor agrees that all paytmmts under,du Secured Debt will be paid when due and in accordance with the
• firms of the Secured Debt and this Security Instrumrnl.
6. WARRANTY OF TITLE. Mortgagor warrants that Mortgagor is or will be lawfully seized of the estate conveyed by this
Security Insttutttemt and has the right to grain, bargain, wnvey, sell, and mortgage the Propetty. Mortgagor also warrants that
die Property is unettcumberod. except for entumbtances of recatd.
7. PRIOR SCCURITY 1NTI:RCSTS. Willi regard to any other mortgage, deed of trust, laxority agrocrncnl m other lien
dowment that created a prior security ituerest or ettcumbrana on fife Properly, Mortgagor agrees:
A. To make all paymcpts whom due and to perform or wmply with all covenants.
B. To promptly deliver to Lends any notkes that Mortgagor nxeives from the holder.
C. Not to allow any modification m extetuion of, nor to request any future advances under any note or agreement sicul'id
by the lice dowrrttxu without Lender's prior written roasent.
8. CLAIMS AGAINST TITLE. Mortgagor well pay all taxes. asaessmenls, liens, encumbraaocs, lease payments, ground rims.
utilities, and other charges relating [o the property when duo. Lender may require Mortgagor to provide to Lender copies of all
notices that such'. alnounla are due and' the receipts evitlcncing Mortgagor's payment. Mortgagor will d¢fend title to the
Property against any claims that would impair the lien of this Security Ituwrncnt. Mortgagor agrees to assign to Lender, as
rcquistcd by Lender, any rights, claims or defenses Mortgagor may have against pantos who supply labor or roaterinls to
maintain or improve the Ptolx:riy.
9. 1DUE ON SALE; OR ENCUMBRANCE. Lender may, at its option, declare fire entire balance of the Secured Debt to Ire
immediately dui and payable upon the creation of, or contlnct for the creation af, ally lien, erwumbtzlpcc, transfer or sale of dtc
Property, This right is subject to the restrialotts imposed by federal law (l2 C.F.It. 5g1), as applirablc. This wvcuant shall
Zlrtt with the Properly and shall remain in effect omit the Secured Debt is paid in full and this Security ]nstmment is released,
10. PROPERTY CONDITION, ALTERATIONS AND ]INSPECTION. Mortgagor will keep the Property in good wndition and
rooks all repairs drat are reasonably mtxessary. Mortgagor shall not commit oc allow any waste, impairment, or dctirforatiart of
the Properly. Mortgagor will keep ire Prgpeny fcce of tlgxious weeds and grasses. Mortgagor agrees that the nawre of the
occupancy and use will not subs[antially change without Lender's prior written consent. Mortgagor will toot permit any change
in airy license, restriaivc covenant or casement widtout Lender's prior writtar consent. Mortgagor will troti[y Leader of all
demands, proceedings, claims sad actions ttgafnst Mortgagor, and of any loss or damage to the Property.
adui;~336 PACI: 573 rpaya 2 G! GJ
01999 Butlun anMm,, I,,,,, a4 CNU1 MN IW~a911 Fun aGMTG•PA 13I191N •
ReceiVetl: 8/23/99 t2:35PM;
A11G-23-1999 ~MON 09:17 AM
> GREG JAVARpIAN LAW OFFICE;
FAX N0.
r^~. (~'i
Page 4
P, 04,
lender or Lender's agents may, at !center's option, enter tltc Property at any reasonable time for the purpose of inspecting rite
Properly. Lender shat! give Mortgagor notice at the tittle oC or before an ittspes[ioa specifying a reasonable purpose for the
Inspection. Any inspxtion o[ the Properly snail be entirely for Lender's beneCt and Mortgagor Witt in no way rely on
Lender's inspection.
11. AVl'11O121TY TO PEtZFOItM. If Mortgagor faits to perfonn any duty or any of the covenants comalnW In this Security
Instrument, !.ender may, without notice, perform or cause them to be performed. Mortgagor appoints Leader as attorney in
fact W sign Mortgagor's tiame or pay any amount netxssary for performance. Lend'er's right to perform for Mortgagor shall
not create ut abligmion Io;perfonn, and Lender's faihtre to perform will not prarludc Lender front exercising any of Lender's
other rights under the iaw or this SeSttrity Instrument. If any construction on the Property is discominucd or nut carried on in a
tt;asonablo tttattner, Lcndor may take ail steps tteeessary to protest Lender's security interest in the Properly, including
completion of the cotuttvction.
12. ASSIGNMCN'C OC LEAS$S AND RENTS. Mortgagor irrevocably grants, bargains, wnveys and modgagea to Lender as
adrlitiorwl security all the right, fide and intc[eat in and to any and all existing or Nlure lases, subleases, and any other written
or verbal agresmen[s .for the use and aexupaney of any portion of [hc Property, including any raeeten;;tons, renewals,
modifications or subsfitu[ions of such agratrtents (all rcferrul to as "Leases") and rents, issues and profits (alt referred to as
"Rents"). Mortgagor will prompfiy provide Lender with true and corrca rnpies. of all existing and futtue Leases. Mortgagor
may wllect, receive, enjoy and use the Rents ao long as Mortgagor is not in default under file terms of this Security
Instrument.
Morlgagor agrees that this assignment is itnmediatcly effective 6etwcen the parties to this Security lns[mtttcnl and cffectivc as
to third patties on the recording of this Security instmment, a~td this assigmttert[ wi-i remain effective until the ObHgatlons arc
satisfied. Mortgagor agrees drat Lender is entitled eo notify Mortgagor or Mortgagor's temnts to stake payments of licnts due
or to become due directly to lender aver such trrorrling, however Lender agrees not to notify Mortgagor's tenants until
Mortgagor dcfaulls and Lender noti[,tes Mortgagor of the default sad demands oral Mottgagor and Mortgagor°s tenants pay alt
Rents due or [o berme due directly to Letuler, Oo renelving notice of de[ault, Mortgagor will ondorse and deliver to Lander
any payment of Rents fn Mortgagor's possession and will receive any Ronts in !cost for [.ender and will not wmmingle the
(tents with eny other Funds. Any amounts eollceted wt11 be applial as provided in this Security instrument. Mortgagor warrants
Utat no detaulr exists under the Leases or any applicable laadlordltenant taw. Mortgagor also agrees to maintain turd require
any tenutt to comply with the terms of (Itc Leases..attd applicable law.
13. Li&ASEiIOLDS; CUNDOM1NlUMS; PLANNED UNIT DCbVELOPMiC,N'l5. Mortgagor agrees to comply with the
provisions o[ any lean if this Secuiily Instrument is on a' )easehold. If the Property includes a unit in a cottdominlum or a
plaoaed unit development, Mortgagor will perform all of Mortgagor's duties under the covenants, by-laws, or rcgulalions of
the condominium or planned unit development.
14. DEFAIJI,T. Mortgagor will 6n in default [f any party obligated on the Secured Dcbt fails to make payment when due.
Mortgagor will be to default if a breach occttis ender the terrtrs of this Scrwrity -nsttument or arty other document executed for
lha purpose of creating, securing ar goarantyfng rho Secured Debt. A goal faith belief by Lender that Lender at any time is
insecure with rospeet to any person or entity obligated on tin: Secured Debtor that the prospect of any payment or the value o[
the Properly is lmpaircd shall also constitute an event of default.
I5. itEMED1ES ON DEFAULT. In some instances, federal and sate law will require: Leader to provide Mortgagor with notice
of the right to cure or other notices and may tstablish time schodules for foreclosure actions. Subject to Ihnse limitations, i[
any, Lender may accelerate file Securod Debt and fottxlose this Security Inslmmcnt in a ruattner provided by law if Mortgagor
pis in default.
At the option of (ruder, alt or any part aC the agreed fees and charges, scented intc[esl amt principal shall became immediately
dtte and payable, after giving notice iF required fry iaw, upon rite oogtrtsnce of a default or anytime tltereaftor. In addition,
Lernlcr shall be notified to all fire rnnuxlitq provided by IoW, rho terms of the Secured Debt, this Security instrument slut say
related documents. Ail remedies arc distinct, cumulative and not exclusive, and the Lender is entitled to alt remedies provided
at law or equity, wheUter or not expressly set forth, The acceptance by Lender of any sum in payment or partial paymau on
the Seeurnd Debt alter the 6a[ance ig due or is aaelerated or attar foreclosure prsuxdings' are filed shall not constitute a waiver
of Lender's right to require complete wre of any existing default. 13y not exercising any remedy on Mortgagor's default,
Lender does not waive Lender's right to truer consider the event a defeat[ U it continues or happens again.
t /page 3 0/ BJ
oras~ttw"..sva.".,tiG.a.owa.uw u•eoo.ssr.:aett ea,aa~arr«o~ txnsrra gQnq~,~~SEiPAGE ~Mr`
,, ~.,,~
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AUG-23-1993 MON 09.17 AM
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f.,,, ~,._'".
16. EXPENSGS; AllVANCES C)N COVENAIVI'S; A'1'fORNTY5' Pf:PS; COI,LIxI'ION COSTS. Except whoo prohlhitea
by law, Mortgagor agrees to psy all of Lender's expenses if Mortgagor bec:tches airy covenant In this Security lnslNnteru.
Mortgagor will also ~'ty an demand any amour[ incurred by Lender for insuring. inspecting, preserving or odtetwise
protecting thc'Properly and', L.ender's security itttemat. These expanse; will bear imerest from the date of the ptrymevtt until paid
in full at the 1iigNcst interest talc in cffext as providal in the ternts of the Smtved De61. Mortgagor agrees to pay all costs and
expenses ;ncutree! 6y Lutdee in cARecting, eat[otcing ar pttexting Lender's rights and wmcdies under this Se:eutity Ittsttununt.
This aatount may, include, but is not limited to, anomeye' [ces, e:onrt costs, geld other legal expturses. This Security Inatruntatt
shall remain in et[ect until released. Mortgagor agrees to pay for any rtxotdalion coals of surly release.
t7. ENV1RONlV1ENTAL LAWS ANU HAZARI>Ot1S 9UIISTANCE5. As used in this scctiem, (l) Errvironmcntal Law tncans,
without limitation, the Comprehrnsiva Environmental Response, Canpensation mid Liability Aa (CEiRCLA, 42 ll.S.C, pGl1l
et seq.), nml all other federal, since and local laws, regulations, ordlnsuxce, crmrl orders, attorney general opinionfi ur
interpretive: leucrs concemiug dte public health, safety, wetfate, environmern or a haza[dents substance; and (2) liazardoufi
Substance means, any toxic, radioactive tx hazardous material, waste, pollalanl or conramiaattt which has characlcrist'tcs which
rextder llte stbs~ance dangerous or potentially dangerous to the public hazldr, safety, wdfaro or ettvirotuncnt. The term
includes, witbopt limitation, any substances defmcd as 'hazardous roazt:riU,` "lotus subsla»c~," `haysrdaus waste" or
"hazardous subsaancx' un~r any EnvironutcNal Isw.
Mortgagor represents, warrants and agroes draz:
A. Except as previously disclosed and acknowledged in writing to lender, no Hazazdous Substancx is of will be located,
stored or released on or in the Properly. This restriexion does not apply Io small gaantitiea of Hazardous Substattccs that
ace generally re:wgnired to be appropriate [ar the normal use and tnaintertance of the properly,
B. Except as previously disclosed and acknowledged in writing to Lender, Mortgagor sad every tenant have been, arc, and
shall remain in full cmnpliancc wiilt any applicable Environmeytlal Law,
C. Mortgagor shall immediately notify Lender if a release or threatened release oC a Hararclous Substancx Decors on, under
or ab'out'the Ptuperty or stele is a violation of spy Envirommental Law eaaexrrting the Property. In such an event,
Mortgagor shall take ell tucessary remedial action Ia awurdance with any F,nvironmental law.
D, Mortgagor shall immediately naGfy Lender In writing as soon as Mortgagor has reason to believe dtate is any pending or
WreateneQ htvestigation, claim, or proexeding rotating tp the release or threatened release of any Hauraous Substance or
the violation oFmry Envlrontncntal Law.
1S. CONDEMNATION. Mortgagor will give Lender prompt notice of arty patding or thrcatcrrcd action, by private or public
amities to purchase or take any or all of the Proptvty through condemnation, eminent dotrtain, or arty other moans. Mortgagor
aulhoitzes''Lender to intervene in M_otigagor's Hama fn spy of the above described actions or claims. Mortgagor assigns to
Lender the, proceeds of any award or claim [or damages connected with a condcumazion or other taking o[ all or any part of tits
Propcny. Such proceeds shall be cortsidcncd payments and will be applied as provided in this Sexueity htstrament. Tltis
assignment oC proceeds is subject to the terms of any prior nwngage, deed of frost, security agreement or other lien document,
E9. INSURANCE::. Mortgagor shall keep Property insured aga[nst loss by Ere, flood, theft sad colter hazards and risks reasonably
assetciazed'willi the property due to its type and lopiron. This instrance shall be maintained in the amoums and for the periods
that lender requires. 'fhe insurance carrier providing die insurance shall be chosen by Mortgagor subject to Larder's approval,
which s1a11 tun be unreasonably withheld, if Mortgagor falls to trtaintam rho twvetage described about, lettdcr may, at
~Lender'a option, oblaio coverage to protect Lender's rights in the property according to the terms of this Security ltesrrunten6
All insurance policies and renewals shall be aeseptable to Lender and shall include a standard "mortgage clause' and, where
applicable,' "Iws payee clause." Mortgagor shall irtunedialelY notify Lender of cancellation or temtlttalitm of the ittsuranex.
Lendtx shall have the right to hold the; policies and renewals. If Lender requires, Mortgagor Shall immediately give to. Lcudcr
all rcceipta of paid premiums and renewal notices. Upon loss, Mortgagor shall give immediate notice io the insurance carrier
and Lender. Lender may make proo[ of loss if not trade immediately by Mortgagor.
sgoK133(i eac~ J~7Jr lpsDs A o/6r
019a0. Se.drl"Eyrlune. Ineo SI. OOW, cal ry-ew~zselt Fam 11ENTG-PA 12a BJ9~. •-- _ -
Received: 8/23/99 12:36PM; -> GREG JAVARDIAN LAW OFFICE; Page 6
AUG-23-1999 •MON 09:18 AM FAX N0, P, 06/22
~ ~~
~~ ~ •
Unlcvs tdhawisc a;:rcctl in writing, all iasunnlx: proceeds shall be applied to rho restoratioa or repair of the Prola:rty ar to the
Severed Debl, wheUter or not then due, at Lender's option. Any application of proceeds to principal shalt not extend or
postpone the due dale of the scheduled payment riot dtangc the amount of any payment. Any excess will be paid to rile
Mortgagor. If the Property is acquired by Lendec,, Morigago~s right to any insurance policies and proceeds ettslthing from
damage to the Properly before the acquisition shell pass to Lender to the extent of the Secured Debi irmnedialely before the
acquisition.
2U. ESCROW NOR TASFS AND INSURANCE. Unless otherwise provided in a separate agreement, Mortgagor will not be
required to pay to Lender funds for taxes and in5trrattcc in escrow.
LI. I4NANCIAL REPORTS AND ADDCTIONAL DOCUMENTS. Mortgagor will provide to Lender upon [equest, any
fmanclal statement or infortnalion Lanier may deem reasonably necessary. Mortgagor agrees to sign, deliver, and file any
additional documents ar certifications that Lender may consider necessary to perfect, continue, and preserve Mortgagor's
obllgatiotu under this Security lnslrumem and Lrnder's lien status on Qte Properly.
2I:. ]OJN'C AND INDIVIDUAL LIABILITY; COSIGNERS; 5UCCESSOItS AND ASSIGNS ROUND. All duties under this
. Security Jttstrutnetu are Johu and individual. If Mortgagor signs this Security Instrument but does oot sign an evidence of debt,
.Morigagor does so only to mortgage Mortgagor's interest to the Property to sccuro payment of the Secured Debt and
Mortgagor does not agree to be personally liable on the Secured. Debt. If this Security Instrument secures a guaranty between
Leader ettd Mortgagor, Morigagor agrees to waive any rights that tray prevent Lender from bringing any action or claim
agalast Mortgagor or arty party lttdebted under the obllgalion. These rights may include, but are not limited to, any
anti•daficiency or one•aetion laws. Mortgagor egrets that Lender and any party to this Security [nstcutnent tray extend, tnodi(y
or make any chwtgc in the terms of this Severity Instrument or arty evidence of debt without Mortgagor's consent. Such a
change will not release Mortgagor from the terms of this Security lastntment. The duties and bcncCts of this 5ccurily
Instrument shalt bind and benefit the successors and assigns of Mortgagor and Lender.
Z3. APPLICAIILp. LA1V; SEVERARILITY; INTI;RPRLTAT[ON. This Scnviry instrument is governed by tiro laws of the
jurisdiction 9n which Lcndcr is located, i:)tocpt to die talent otherwise minircd by the laws of Utc jurisdiction where the
Property is lowted_ Tail Security ]nstrutnent Is complete and fully Inte6raced. This Security insttvmrnt may not be amended or
modified by oral agreement. Any section in this Security instrument, attachments, or any agramen[ related ro the Secured
Debt that wntlicts with applicable law will not be effective, unless that law expressly or imphcdly perntiW the vaziations by
written agreement. [f any section of this Security instrument cannot be enf<rtrcd according to its terms, that soction will be
several and will not affect the en[ortx:ability of the remainder of this Security Inattumau. Whenever used, the singular shall
lnelttde the plural and the plural the singular. 'the capt[oas and headings of the suctions of this Security Insttutnent are for
wavenicnce ody and aro not to be used to interpcel or delinn the terms of ibis Security Inst[urttetu, Time Is of the txsence In
this 5eatrity lnslrument.
24. NOTICE. Utiless otherwise required by law, any notice shall be given by delivering it Or by mailing it by first class mail to
the appropriate party's address on page l of this Security lnstrtuneut, or to any other address designated tR writing. Natlec to
otre mortgagor will be deerrtrxl to be nathx to aN mortgagors.
2S, WAIVERS. Gxcept to the cxlent prohibited by law, Mortgagor waives arty right to appratsement relating to flat Property.
saolcf336vac~ 576
O 1994 9en~v\ 57,Imm, Ina., 91• e+owd. MN 11.900.797.2761) Pww, Rr.MT0.PA 12/1986
(page b or 61
x,-mss
Receive'dc 8/23799 72:36PM;
AUG-23-1999•MON 09:18 AM
S[CNA'C[i1LE5: By slghlrrg bsiow, Mortgagor, inlettdisg to ix legally bound ltercby, agrors to the terms and wvenants eattained
in this',Sceutaty Insttumcm aad In any attachments. Mortgagor also acknowledges receipt of a copy of this Security Instrument on
the date stated on pSge i.
~, ~~~
2G. (YI'IIRIt TISRf11,S. If altcckcd, the (utlowing ara ttpplicablc to this SttvRt7ly htxlnancnt:
O Lbrc of Credit. Tlrc Sccural Debt includes a revolving 1'mc of credit provision, Although ilrc Secured Dcbt may laR
reduced to a 7rero balanx, ibis Security lnatrument will retnatn In effect until released.
^ Consdaction Loan. This Security instrument secures an obligarion incurred (or the porlsttUCtion of an improvenrrnt on
Ute Property.
^ Fixture )'ding. Mortgagor grams to Lender a security interest in all gaols that Mortgagor owns now or in tiro {afore
and that are or will become fixwres related to the Property. This Security Instrument suffices as a linaneing atatontent
and any carbon, photographic or other reproduction may 6~c filed of record for purposes o{ Article 9 of the Uniform
Commercial Cade.
^ Purchase: Mbney. Tills Security Instrument secures advances by l.cndar rased in whole or in part to acquire the
Properly, Accordingly, this Security lnsttvmenl, sad the lien heteutvJcr, is and shall be consttucd as a pnrohsse moacy
tnvrlg.~rge with ail of rite rights, priorities and benefits thereof under the laws of the Comrnoowcallh of Putttsylvania.
O NO'fIGE 7'U BORROWER: ~'I~S DOCITMENT CONTAINS fiTtOVISIONS FOR A VARIABLE
INTERIST RATE.
D Riders. The,etrvenanls and agreements of each o[ the riders checked below are incorporated into and supplement and
stns of this Seeurtty Ir>strttmant• [Check ail applirabk boxed
^ Condominium Rider D Planned 1Jnit 7)evelop,4nnettt Bider ^ Other ..... ..............................................
^ Additions! Toms.
tit=i cs;sa~mK~ SIiARON c a»rr watol
r•
'~
.,~~~ : r f `G :~ _.......... ..............
(VVknetr)
-> GHF_G JAVARDIAN LAW OFFICE; Page 7
FAX N0.
P. 07/22
lwiuResxl ........................
ACKNOWLEDGIIIEN'1'• /t , , , - , +_ . u ! ~,,
COMMONWEALTH OF Rte:?-9XI+UJI~TFk1 ~R .., I.OUNTY OF .[„r1,fd/IA.K.dK. Ud, ,...J as,
snawR.,q On this. the .,....-?.~k~.1~s...... day of ..At?;Jb)r`ie..sg.R a.29~. ........, before rrre .KRxAf1X...?.~[lA7GXA......,.
tlte~ igned of/icer, soaallY appeared -....'-.-~--f?.~> ::... ...................................................
~ , krmwn to the (ar satisfaetoriiv proven) to be
• ~ ~,yiR~jRdti,Slj~~crsma(s) whose name(s) is snbscn'bcd to the withia instrument, attd acknowledged that he/she executed the saute
S~ ..~s~'.~ ebutnosrs therein tontaineti.
o ~/q~tiylrimcgsyrhereof, i hereunto set my hand and official oral.
.
:' r 4 T
' i~ 'Mrynai~i n expiresr NOTARIAL $F.AL ~f.- f ~ :
~ ~.
. 'iA`~; `tals~ MaryAnnKButcbko,NolaryPnblit: ~~~t•xo~u=~(.~dr. "...7L..~.._.'.~.:~./..........,
'• , '- '~~~~; ~~ Carlisle, Cumberland Cttanty
'•'•..;:~~>...•:` IHycommissione>7tiregtluly27,1898 ~.~JkkL~ ..............................._.........,......,..
'%' ~rrl,~:~~ 'rarrurornrxr
t4~¢•'" city urdficd oral the address of the L,emler within named is: a~..?~. ~e..d4F?~iPX'..~?~.,y............
:,~.4.0.7,.,I4~ir.~~!?~,Y.s..kF.S.t,v..~3R...~:~.IRP...X~YX~F.A..._ ~.Z.9.1.1 ..........................5.. .. .. .. ..
set i'..lt:l$ylvnrtlA 2 ..... . ~l/~~ 'tV`i. ......,.. .
.. • ....
. ,. . ..... {~c:~a.
.t .t:;R'~trtu:Rlirrd~i SS . ,. ., .,..~. Sr~..!1.,~:~lk~` .... :.. ... ........ ..........
] •, ftR:r, tar the rec . •;" !~r~ : •' .. • '+
1 " arding o{ Deckrs'• , ~
A~ Ylst(•i,,,.;,_ri.rnrJ Ca~nfa~. , . ..:• : • ,~ ,d~;.~• •, ; . . ~
,' :://~ ,,,~,~ a o _~ ~ ~R~.;'. ',;:;;~ ;;:: ;:; % aouK1336eace 577
• oroea a.~un KrsRe~.s, me. rK. appww t+ ~i1 ~ m{w txUea~~{ ;' ' _' ~ ~ /p ps lr o/6/
•.,rtaCOrgBr ' • .~,. l.~.'f ••~•I .~ •
Recelvetl: 8/23/99 ~2:3~PM; ~ -> GREG JAVARDIAN LAW OFFICE; Page 8
AUG-23-1999 •MON 09:19 AM FAX N0. P. 08/22
• • NO'M'E •
Iarol IorN Inaa1
,..a~s~.>pxxta~,.~vx. s.~ap'atm. .......................ran.~.zz~z................-..._...,......,......................
ipeawWAdWW
1, BORROWER'S PROMISE TO PAY
In remm fm a lose ehst 1 heave taeived, I ptomim to pay U.B. 5....9.321)Q..09 ..................... <Ws anm,mt Ir
.,.gr+hitM wi .,gplFfl[tYi....J'p9y.'..,1.L°.S4Tilhe.1,c,..Y.!n:R.tv..'y.•...xar:r...-n.:.:.r_:a :.... :.:.:.:.c......,......,....
1 undenlana /hat the [ends rosy vansfer Ibis Note. The Lepdm o< mryone who lakkce drls Note try trortsfu and oho Is
entllled to receive payovate uuda Ibis Note is celled dN; 'Note Holder.'
Z. 1tYTRRE91'
Interest will be charggeedd as unpaid prialpd eml0 Ure full aeaua of principal hw been paid. 1 wUl pay Interest al a
yearly tole o(.......J,2.bS(t..• %. inteteu will be ettarged heginaing on .........kM9V.(?k.7.9,-.?,996..x ....................
The (Merest ree required by th(s Section 2 is ilia rate I wUl pay bah before and a0m any defath described to
Seaton d/B) of rich Hole.
3. PAYMENTS
U) Behedulad Payments
twill pay prlueipsl and Interest by loat:hrg pgyrcaas whrol sehedulcd:
7~7 t will make .._.....3AA ................... payments of 5........9.k3.e~6.......,.._...................... each on the
..~ ......................................................... beglnoln6 on ..C1fk~1:.lA...~.49fi......................
tl I will make peymtmis as (otlows:
Q la addlttan to fie paymatta deae[ihed above, i wUl pay a ^balloon payment' o[ S ...................................
on ......................................... . The Nole Holder will deliver a rwil m me notice prior b lmlurity that
the halloos payment k due. This mWtx will aorta the balloon payment anqunt an4 the dale Ihat it is due.
(B) MatuNty Dale and-Piateof Poymeals '
1 will make them pgymeuu as schWuld atoll I Imve paid all or rim prilxtpd seed interest ant any other charges
deecdlNW below dial I may owe uad1Y this Nok. MY achcduled paymeatss will 6e applied b iMCrat he(oro pelaeipal. If, on
...........ki-341dG..a.9,..::R7.6 .................................... I atilt awe amounts under Ihla Nole, [ wUl pay dtoca atnounlt
is ruU oa Iha< sate. which is called the -ttWUrlty dak." .
1 will make m7r edtedulad yrymrnls M ~x~en..7YC~. (QOxYff~e..^•,es7CiaEas.,(kuBRrdki.Qa .............:........
..R,Qn:]Bit,'.6aSA,.:~7[3.d.tski'....~P.t..5T.1A~ ......................:....................................... or u a ditlcmtt
place if required 6y the Nok Holder.
a, BoRROTi~I'slvclrrTUrREPAv
1 hove',Ihe right to ardk payerana of principal at arty fine before theq are due. A poymtut of principal only is
known as a `ptgwymaot.• When f nudm a prcpaymem, t anYt kli the Nok Hoidor in writing that [ as dohlg ro.
t msy make a fWl psepsyreeM or partial pkpgymenes wUtmut plryiag mY PmpaYment charge. The Noce Haldee will
use sit of myprapaymaas b reduce the anwuM of principal that [ owe under Ibis Note. I[ t make a partid pccpagmem,
there aril 6ano changes In the due date or to the atnount o(roy rnaelWy paytrwrrt unlesc the Nate Holder agree In aTllfog
m tlmre changes.
S. LOAN CHARGI[S
' If a law. Much applies a dill tom and adekh sas maximum tom charges, is fuuUy hnerpreled ~ that the hdaat
or odrer loon'ehargee coUeeled or k bE colltaed In eamKGion with thin lace exceed the petmiUed limits, Oua; (i) any
such Loan ekai'ge skill lx «dtua:d by the smarm tteensaq' le reduce the charge to !be permitted limit; and 01) any sums
already wlleclod from rim ankh exceeded penntttod Ilmita wiU be rcPoadad w tee. fie Now Holder rosy choose to snake
this round by rcduclog ilea princpal 1 evve ender this No[e ar blr making a direa payment m me. If a reNnd reduces
principal, lhe;reduelion wUl ba taeaka as a pastel prepayment.
i. BORROWER'S FAILIIR6 TO PAY AS REQt)IREU
(A) i.ala (:barge ear OveNUe Peyrrtetda
If the'. Nok Holder hat not «alved the Nll amount of any scheduled payment by the end o[ .xQ ...............
relenMr dogs aher NE date U b due, [ will pay a tale chazge m dre Note Holder. Tire moouot aC the charge will be
,,.StSL~,....% of my overdue payment of principal and IMeraL I will pry this lase charge promptly but only enx on each
lak payrtxttt,
(B) DeOtutt
If f dp eat paq the Nll wrtount of as4t scheduled ptrymem on Iho date ie U due, I wUl be In default.
(G) Norkx of DNaull
I[ t am io defsuly dre Note Holder rtwy send me a wrluen mlira; felling rue that i(t da not pay dre overdue amount
by s aerWn data, dm Note Holder mry etsquiro me to pry Imencdlately lire full amonM of princ[pal whirdt hss not been paid
and dl tlx Wtercel mat 1 awe on that amoam, The dale must be at least 30 daps after the dak oil whidr the nmla u
dcllvercd n nlalled m me.
(D) No Welver B)' Nok lioldu
Lean if, al a time when 1 sm 1n defmtll, We Nok Holdtt don sot requite roe to pay tamtaiuuely !n N1I at dueribed
above, Uro Nob holder wUl eWl 4ave the right k do ro if f am m default at a later Ikts.
(E) P'ymmt of Nok Holder's Canoed Expearaa
If the Note Holder hm tegaited me k pay ittuludiatdy In NII os desa(bed above, rbe Note Holder wilt Aave the
NgM Ice be paid barl by me for ail of hs costs aril eapeow to eafoming this Nok to theextem nor prohibited fry
applkadtle law. 7itase tapaaa foeittde, far awmpk, tavomble atmrneya' fee.
MULTIPURP068 FlXED RATE NOTE IMULTIBTATE)
INIIIea9 araraa4 awr B•, cleric. NNNaax n•rro.maMq reglae/rvNnaY1M
4Ye 1e/w
aa°hVnra'gwsmelw_ rm.~.mw _ _ _ r
Received: 9/23/99 t2:37PM;
AUG-23-1999'MON 09 19 AM
~ GREG JAVAR~IAN LAW OFFICE; Page B
FAX N0,
P. 09/22
7. GIVING OF N077CE5
Unlees applles6le law tequlrrs a dlfRrml method, any mice that tnnu 6e given le are meet Ibis Nae will ba give
by ddiverinB h or by nufllttg h by first class mail m me at the PeapMy Address above or ai a dlUarenl address if 1 giv
tiro Naa Holder a aaiee of ryy diffeteal addraa.
Any nodes oral rums be gives eo tt,e Nero Holder under m1s Note will ba given Fy codling it by first ctaes rr®il b
ills Nole Holder at me scares sorted io Section 3(U) oo page I o[ this Nae m al a ditferanl address if 1 nor given a nolia
o[ drat diffowl address. '
g. OBLIGATIONg OF PERSONS UNUP,.P, THIS NOQ'E
If more than oue.petsat signs Wls Note, each petaon is fully cad penotwlly dbiigaed to keep dl of Um promlaet
made in Ibis Nae, including the promise to pay ilro fall ntttottnt sued. Any parson who E a gnaranlor, wetly or elalorsot
of thin Nola is also obligated to do these things. Any parson who takes twat dwo oNigaliow, irmluding the obligMilaN of
a grmmntm, auroty m endorur o[ Ihis.Note. 6 also obligated to f'cR all o[ me pmmiaes male in rhic Nole. The Note
Holder may anforct iu rigMa Hader lldaNOte agaimt eaeb petaon hrdevidnally or aga{In1 all of w togethW. This means dwt
arty one of m may he regaimd W pay all of the amounlx owrA uMer thlr Note.
9. WA1VERg
[ and any odor person who hen ahlfgatlons under alit Note naive the rfgltte of prraetttmstrl and wtiee of dixhonor.
•PraentrMnr• rneaa9 the r+ghr to require the Note Holder to tlamend payment of amounts due. "Netlee at diahotror• arcane
the right to ttaprhe the Hale Holder la glue notice to other persons Wa atwrruts due base test barn peed.
10. SECURED NOTE
In addition to the proltaxeow given to the Noln Holder Hader This Nae, a Mangege, Dad of Ttast m Stratrify
Deed (the 'Seeurhy [mtmmrnt"), dated the wrro date err Wle Nae, prologs the Nota Holder from passible bssrs which
might romp if 1 tb na ktxp the promises whir]t 1 make N Ibis Note. That Seearity lnstrumenl desen'bns boa raJ under
what a011ditiaw 1 ltmy he requited m Hake immtediale paytnem hl full of all etmtmis I OVYC lords this Nae. game of lhoxo
aMitiats am desaihed as Nllows:
Trarefer of the PrapeeiY m a Btate[(rlal Inttss~ M Bortower. !f all m airy part of Iha Progeny m
aaq interwl In it W sad or tlanaPorrod (or if a irotteGeial itrterect in Borrorvm 6 s01d m Irmtsfernd am!
Borrows is na a sauna( pcxao) vrimmd ILdda'a prior w[illen eonsrm, Ltatder orgy, as iu option, regatro
itnmediate paytrtau In full o[ dl sumo soured try thb Saucily [asaumem. IlowtaU, this opQon shall aol 6e
eaeroiad by lrrdu iF exercise ie prohibited by federal law as of dtt date o(this Saurhy Instrument.
U [.ender eaaeisea mis option. Lender shall give Hotsower notice of accefaetien. The rrol(te ahn(1
provide a pulal of not Ins than 30 days from me data the nail is ddivered or rrmilal wilhln which
Bormvrer nines pry sti awes aewte4 by mis Sewrecy, lasWmem. If Boerowa falls to pay these same prior to
ma aspiration o[ this pmiod. Lander may invoke atry remedrea pumittpl by [hie 5muily Inslmmaal wilhoul
Pusher ttolla m demand on Bortowtt.
1 i. BALLOON PAYMRNT AISCLOSURB
iCoraplete the 6eilooa paynreot nala below K Ibis Nae provides Tot a 6slloon pryrneM at Sedlon ](A) on page I
o[ ibis Note.]
TIDS LOAN LS PAYABLE IN F[A.L
........................................................................................................................ i MUSP REFAY TIUi
ENTIR{i PRINCIPAL BALANCE OF THC LOAN AND UNPAID INCBRTfST'IgIEN DIR[, WiDC71 MAY IIII A
1.ARCE PAYMENC. TIIE LBNDCi( IS UNDER NO OBLICATR]N-TO REFI[4ANCETi(E LOAN AT TI(AT
TUNE. 1 WILL, TIIERF.FORE, B~ RS'QUDiEb TO MAKE PAYMIO•il' Otfl' OF OTIILR ASSETS TINT 1 hIAY
OWN, OR [ Witt KAVETO FTND A LRNAAR, W1DCI1 MAY BB TI(E LENDER 11NVE.THLS I:OAN WITH,
WILLING TO LBNA ME TIIE MONEY. IF I REFINANCE THL4 LOAN AT MATURITY,1 MAY IIAVP. TO PAV
SOME OR ALL OP 1'HE CLOSWC COSTS NOkh/At.LY ASSOCIATED WITH A NEW LOAN EVEN IF
ODTAM R6FIINANCING FROM THE SAME LENDER.
W I1NES5 THE HANO(h7 AND sTAL(S) OF THE UNDERSIGN
MNrar BYaYBae,,Ire.aT. eLOee. MN lam~aHaLllreaM,aYAMN aR~.11 •
.. ..... '1~ ..........................:tiw~raw.0.
5)~I C i2C$JI.Sg.~T
............. ~. ..(Seal)
•.aMMi/I
/ffign Ongb+al only)
tyres a arN
-::. - m nw
Received: 8/23/99 t2:3BPM;
> GREG JAVARDIAN I_AW OFFICE; Page t0
AUG-23-1909 •MON 09;20 AM FAX N0. P. 10/22
S
MORTGAGE /. bEED OF TRUST ASSIGNMENT
11695819
For value received, GREEN TREE CONSUMER DISCOUNT CORPORATION ("Assignor"), a
corporation organized and existing under the laws of the State of Pennsylvania, hereby assigns
to FIRST TRUST NATIONAL ASSOCIATION, its successors and assigns, a6 right, Cale, and
interest in and to a certain Mortgage /Deed Of Trust dated August 14, 1996, made by Terry J.
Robinson and Sharon C. Robinson, as mortgagor(s), to Green Tree Consumer Discount
Corparaiinn, as mortgagee, as filed in the offices of the County Recorder, County of
CumbeHand, State of Pennsylvania, together with the Note secured by such mortgage /deed of
trust on the following described properly situated In the above county and state, to wit:
See attached exhbit A for legal description.
Dated this day of 9/90/96.
GREEN TREE CONSUMER. DISCOUNT CORPORATION
sy:
Elaine Hayes, Auth Agent
State of South Dakota}
)~
County of Pennington )
As a Notary Public for the State of South Dakota, l hereby certify That E4-rine Hayes personally
came before me on this dale and acknowledged That she is an Authorized Agehf of Green Tree
Consumer Discount Corporation, a Pennsylvania corporation, and that by authority duly given
and as the act of the corporation, the foregoing instrument was signed in ifs name by her.
Witness my hand and offlaal sea) dated
(Notary Seal)
TNEA TANSSY ~ 36ALt
sots tiauicorn '' •-•
My Ogrrrnisslon F.spires
.aty2:,2ooa
~~~
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
June 1, 2001
TERRY J. ROBINSON SHARON C. ROBINSON
2157 RITNER HIGHWAY 2157 RITNER HIGHWAY
SHIl'PENSBURG, PA 17257 SHIPPENSBURG, PA 17257
THIS FBtM 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI maybe able to help to save
your home This Notice explains how the program works.
To see if HEMAP can helpyou must MEET WTI'H A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet the
Counseline Aeencv.
17ris notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency maybe able to help eacplain it. You may also want to contact an
attorney in your azea. The local baz association maybe able to help you find a lawyer.
LA NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. IS 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 PARR UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): TERRY J. ROBINSON & SHARON C. ROBINSON
PROPERTY ADDRESS: 2157 RITNER HIGHWAY, SHIPPENSBURG, PA 17257
LOAN ACCT. NO.: 6700075788
ORIGINAL LENDER GREEN TREE CONSUMER DISCOUNT COMPANY
CURRENT LENDER/SERVICER: CONSECO FINANCE SERVICING CORP.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of
foreclosure on you mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend aface-to-face meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WTTHIN THE NEXT (301 DAYS. IF YOU DO
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -If you meet with one of the consumer credit
counselinP agencies listed at the end of this notice the lender may NOT take action against you for thirty
Ll davs after the date of this meetine. The names, addresses and telephone numbers of designated
consumer credit counseling agencies for the count~m which the property is located aze set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately
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 tiled and aze 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 Assistance Program Application 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 postmazked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO
NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WII.L BE DENIED.
AGENCY ACTION- Available funds for emergency mortgage assistance aze very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. Tho Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pemssylvania Housing Agency of its decision on you
application.
NOTE; IF YOU ARE CURRENTLY PROTECTEb BY THE FII,ING
OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT
TO COLLECT THE DEBT
(If you have fled bankruptcy you can still apply Cor Emer[rencv Mortnane Acaiatancel
HOW TO CURE YOUR MORTGAGE DEFAULT Brine it un to date)
NATURE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your property located
at: 2157 RITNER HIGHWAY, SHIPPENSBURG, PA 17257 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts aze now past due: 3/8/00 thm S/8/01 at $813.66 per month.
Monthly Payments Plus Late Charges Accrued:
NSF:
Attorney fees:
Insurance:
(Suspense)
TOTAL AMOUNT TO CURE DEFAULT
$12,204.90
$50.00
$12,254.00
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable
lq/A
HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of
this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $12,254.00
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Pavment must be made either by cashier's check certified check or
money order made able and sent to: CONSECO FINANCE SERVICING CORP., 7360 SO. KYRENE,
TEMPE, AZ 85283, ATTENTION: CANTLE HARNETT.
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) N/A.
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THEtTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the moctga eg debt. This means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instinct its attorney to start legal action to
foreclosure unon your mortgage nronertv.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay
off the mortgage debt. L`the lender refers your case to its attomey, but you cure 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 aze started against you, you will
have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount you owe the lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY neriod, you will not be required to pay
attorney's fees.
OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default
within the THIILTY (30) DAY period and foreclosure proceedings have begun, you still have the ri t to
cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale. You may do so by
specified in writing by the lender and by nerformine any other requirements under the morteaee Gtiuing
your default in the rnauuer set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the eazliest date that such a Sheriff s
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of
this Nofice. A nofice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment or acfion will be by contacting the lender.
HOW TO CONTACT THE LENDER-
CONSECO FINANCE SERVICING CORP.
7360 SO. KYRENE
TEMPE, AZ 85283
TEL NO. (888) 315-8733 x 36239
ATTENTION: CANTLE HARNETT
EFFECT OF SHERIF'F'S SALE- You should realize that a Sheriffs Sale will end your ownership of the
mortgage$ 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 _ may or XX 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, chazges and attorney's fees and costs are paid prior to or at the sale that the other requirements
of the mortgage aze satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIltD 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 THIS RIGHT
TO C[ IRE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTffU'fED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED.
Y Yours,
u~
~TTORNEY OR ER
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
1. This is an attempt to collect a debt and any information obtained will be used for
the purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within thirty
(30) days after receipt of this notice, the debt will be assumed to be valid by our
offices.
3. If you notify our offices in writing within thirty (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.
4. If you notify our offices in writing within thirty (30) days of receipt of this notice,
our offices will provide you with the name and address of the original creditor, if
different from the current creditor.
' PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS of Western Pennsylvania, Ina Financial Counseling Services of Franklin
2000 Linglestown Road 31 West 3rd Street
Harrisburg, PA 17102 Waynesboro, PA 17268
(717) 541-1757 (717) 762-3285
Urban League of Metropolitan Harrisburg YMCA of Cazlisle
N. 6s' Street 301 G Street
Harrisburg, PA 17101 Carlisle, PA 17013
(717)234-5925 (717)243-3818
FAX (717) 234-9459 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 Cazlisle Street
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334-8326
PENNYLLVANIA BULLETIN, VOL. 24, N0.23, JUNE S, 1999
VERIFICATION
The undersigned hereby states that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge, information and belief. The
undersigned understands that the statements therein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unswom falsification to authorities.
Ruth Hernandez, Foreclosure Manager
• CONSECO FINANCE CONSUMER In The Court of Common Pleas
DISCOUNT COMPANY
Plaintiff Ctunberland County
v.
TERRY J. ROBINSON No. 01-4552
SHARON C. ROBINSON
Defendants
TO: TERRY J. ROBINSON
SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
DATE OF NOTICE: 8/24/01
NOTICE, RULE 237.1
IMPORTANT NOTICE
You are in default because you have failed to enter a written appeazance personally or by
attorney and file in writing with the court your defenses or objections to the claims se
forth agailist you. U~iless you act widain 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 Bar Association
Lawyer Referen S ice
Z Liberty A n ~
Carlisle, PA 13
(717) 249-3 6
Gregory Javardian, Esquire
44 Second Street Pike, Suite 101
Southampton, Pa 18966
(215) 942-9690
Attorney for Plaintiff
Usted se encuentra en estado de rebeldia por no haber tornado la accion requiida de su
parte en este caso. Al no tomar la accion debida dentro de uu tennino de diez (10) digs de
esta notification, el tribunal podia, sin necesidad de cotnpararecer usted en Corte o
escuchar prueba algwza, dictar sentencia en su contra usted puede perder bienes y otros
derechos importautes. Debe llevar esta notification a un abogado inmlediatemente si
usted no time abogado, o si no time dinero suficiente Para tal servicio, vaya en persona o
Name por telpfono a la oficina, cuya direction se encuentra escrita abajo para averiguar
donde se puede conseguir assistencia legal.
"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"
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. SS669
44 SECOND STREET PIIO;, SUITE 101
SOUTHAMPTON, PA 18966
1215)942-9690
CONSECO FINANCE CONSUMER COURT OF COMMON PLEAS
DISCOUNT COMPANY
CUMBERLAND COUNTY
vs.
TERRX J. ROBINSON
SHARON C. ROBINSON
No.: 01-4552
VERIFICATION OF NON-MiLYTARY SERVICE
GREGORY JAVARDIAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and beliei; he has lrowledge of the
following facts, to wit:
(a) Defendant(s), TERRY d. ROBINSON and SHARON C. ROBINSON, is/are 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 Refief Act of Congress of 1940, as amended.
(b) Defendant, TERRY J. ROBINSON, is over 18 years of age, and resides at 21 S7
RITNER HIGHWAY, SHIPPENSBURG, PA 17257.
(c) Defendant, SHARON C. ROBINSON, is over 18 years of age, and resides at
2157 RITNER HIGHWAY, SHIPPENSBURG, PA 17257.
(d) Plaintiff, CONSECO FINANCE CONSUMER DISCOUNT COMPANY, is an
institution conducing business under the Laws of the Commonwealth of Pennsylvania with an
address of 7360 SO. ICYRENE, TEMPE, AZ 85283.
`This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
mmswom falsification to authorities.
G G Y VARDIAN, ESQUIRE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CONSECO FINANCE CONSUMER
DISCOUNT COMPANY
7360 SO. KYRENE
TEMPE, AZ 85283
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 01-4552
vs.
TERRY 7. ROBINSON
SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHII'PENSBURG, PA 17257
PRAECIPE FOR WRIT OF EXECUTION
MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly issue Writ of Execution in the above matter.
Aunt Due
Interest from 9/21/01 to Date of Sale
@ $14.62 per diem
$88,958.03
Subtotal
(Costs to be added)
ARDIAN, ESQUIRE
44 Second Street P~7ce, Suite 101
Southampton, PA 18966
(ZIS) 942-9690
1 -
ALL that certain tract of land situate in the Village of Stoughstown, North Newton Township,
Cumberland County, Pemisylvania, more particularly bounded and descn`bed as follows:
BEGINNING at a point, a Pazker kalon nail in the centerline of the Ritner Highway (U.S. Route
I i), at corner of lands now or formerly of Sharp S. Jumper; thence along lands now or formerly
of Sharp S. jumper, North eighteen (i$) degrees twenty-eight (28) minutes forty-three (43)
seconds West, two hundred twenty-sic and sixty-five hundredths (226.25) feet (passing tluough
an iron pin on line twemy-five and eleven hundredths (25.11) feet from the aforesaid Parker
kalon nod) to an iron pin; thence along lands now or formerly of Terry J. and Sharon C.
Robinson, South seventy (70) degrees fifty-three (53) minutes thirty-two (32) seconds West, nine
and fifteen hundredths (9.15) feet to an iron pin; thence along lands of same South seventy-one
(71} degrees thirty-two (32) minutes fifty-two (52) seconds West, one hundred one and thirty-
seven hundredths (101.37) feet to an iron pin; thence along lands now or formerly of Allen R.
Williams, South zero (00.00) degrees Si1iy-mne (S9) minutes forty-nine (49) seconds West, forty-
three and seventy-mom huralredths (43.79) feet to an iron pin; tl~nce along lands of same, South
sixteen (16) degrees fifty-nine (59} minutes fifty-six (S6) seconds East, one hundred ninety-one
and severity-one hur~redths (191.71) feet to a Parker kalon nail in the centerline of the Rimer
Highway (LT.S. Route l l) (passing through an iron pin an line twenty-five and eighteen
hundredths (25.18) feet from the aforesaid Parker kakm nail); thence over the centerline of
Ritner Highway (CJ.S. Route 11) North sixty-six (66) minutesthirty-four (34) seconds East, one
hundred thirty and eighty-one hundredths (130.81) feet to a Parker katon nail, the point and place
of $EGINNING.
Containing 29,272 square feet, more or less.
SUBJECT to a fifty (SO) feet wide private right-of--way k-cated immediately adjacent to the
eastern boundary of the lot herein conveyed, for ingress, egress, and regress to a certain parcel of
land consisting of 5.570 acres, more or less, lying immediately to the North of the lot herein
conveyed and being owned by Terry J. and Sharon C. Robinson, husband and wife, through deed
from James W. Robinson dated July 8, I994, and recorded in Cumberland County Deed Book
109, page 092.
The description of the lot herein conveyed was taken from a re-survey of said lot, by Carl D.
Bart, RS., dated March 1, 1995.
BEING known as 2157 Rimer Highway, Shippensburg, PA 17257.
BEING THE SAME PREMISES which Bazbaza L. McMullen, unmarried, by Deed dated
April 19, 1996 and recorded Apri119, I996 in Deed Book 137, page 965, in the Recorder of
Deeds Office in and for Cumberland County, granted aril wnveyed unto Terry L. Robinson and
Sharon C. Robinson, husband and wife.
LAW OFFICES OF GREGORY JAVARDIAN
By; GREGORY JAVARDIAN, ESQilIRE
IDENTIFICATION N0.55669
44 SECOND STREET PIKE, SUITE 10]
SOUfHAMI''I'ON, PA 18966
(2151942-9690
CONSECO FINANCE CONSUMER COURT OF COMMON PLEAS
DISCOUNT COMPANY
CUMBERLAND COUNTY
vs.
No.: 01-4552
TERRY J. ROBINSON
SHARON C. RO$INSON
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TERRY J, ROBINSON
SHARON C. ROBINSON
2I57 RiTNER ffiGHWAY
SHIPPENSBURG, PA 17257
Your house (real estate) at 2157 RI~NE_,~HIGHWAY SHIPPENSBURG,, Ap 17257 is
scheduled to be sold at Sheriffs Sale on MACH 6.2002 at 10:00 A.IvL, in the Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of 588,958.03,
obtained by CONSECO FINANCE CONSUMER I)ISCOI7NT COMPANY, against you.
NOTICE OF OWIVER!S_RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SI~RIFFS SALE
To prevent this Shetifi's Sale, you must take immediate action:
L The sale will be cancelled ifyou pay to the ubrtgagee the hack payments, late charges,
costs and rea~nable attorcey's fees due. To find out how much you must pay, you may call: 2i,1
942-9690.
2. You may be able to stop the sad by filing a petition asking the Court to stn1ce or open the
judgmen, 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. ~ /
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.)
1. If the Sheriffs Sate is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling X2151942-9690.
2. You may be able to petition the Court to set aside the sate ifthe 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 fmd out if tt»s has happened, you may call Gregory Javardian, Esquire at (215) 942-9690.
4. Ifthe amount due from the Buyer is not paid to the Sheri$ you w~71 remain the owner of
the property as ff the sate 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 ~8 legal Proceedings to
evict you.
6. You maybe entitled to a simre of the money which was paid for your house. A schedule
of distribution of the money bid for your house wi71 be filed by the Sheriff. This schedule will state
who wHl be receiving that money. The money wdl be paid out in accordance with this schedule
untess exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within
ten (10) days.
7. You may also have otter rights and defenses, or ways of getting your home back, if you
act immediately a8er tta; sate.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. liF 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 BAR ASSOCIATION
2 LIBERTY AVENUE
CARLL5Y.E, PA 17013
TELEPHONE: (717) 249 3166
(800) 990-9108
,i
-,
ALL that certain tract of ]and situate in the Village of Stoughstown, North Newton Township,
Cumberland County, Pennsylvania, more particularly bounded and descn'bed as follows:
BEGINNING at a poirrt, a Parker kalon nail in the centerline of the Rimer Highway (U.S. Route
11), at corner of lands now or formerly of Sharp S. Jumper; thence along lands now or formerly
of Sharp S. Jumper, North eighteen (1$} degrees twenty-eight (28) minutes forty-three (43)
seconds West, two hundred twenty-six and sixty-five hundredths (226.25) feet (passing through
an iron pin on line twenty-five and eleven hundredths (25.11) feet from the aforesaid Parker
kalon nail) to an iron pin; thence along lands now or formerly of Terry J. and Sharon C.
Robinson, South seventy (70) degrees fifty-three (S3) minutes thirty two (32) seconds West, nine
and fifteen hundredths (9.15) feet to an imn pin; thence along lands of saate Southseventy-one
(71) degrees thirty-two (32) minutes fifty-two (52) seconds West, one hundred one and thirty-
sevenhundredths (101.37) feet to an iron pin; thence along lands now or formerly of Allen R.
Williams, South zero (00,00) degreesfifty-nine (59) minutesforty-nine (49) seconds West, forty-
three and seventy-trine hundredths (43.79) feet to an iron pia; thence along lands of same, South
sixteen (1~ degrees fit13--nine (59) minutes fifty-six (5~ seconds Bast, one hundred tvuety-one
and seventy-one hundredths (191.71) feet to a Parker kalon nail in the centerline of the Ritner
Highway (U.S. Route 11) (passing through an iron pin on line twenty-five and eighteen
hundredths (25.1$) feet from the aforesaid Parker kalon nat3}; thence over the centerline of
Ritnet Highway (U.S. Route 1 I) Notch sixty-six (6~ minutes thirty-four (34) seconds East, one
hundred thirty and eight}-one hundredths (130.$1) feet to a Parker kalon trait, the pohrt and place
ofBEGINNING.
Containing 29,272 square feet, more or less.
SUBJECT to a fifty (50) feet wide private right-of-way located immediately adjacent to the
eastern boundary of the lot herein conveyed, for ingress, egress, and regress to a certain parcel of
land consisting of5.570 acres, mare or less, lying immediately to the North oftln lot herein
conveyed cad being owned by Terry J. and Sharon C. Robinson, husband and wife, through deed
fmm James W. Robinson dated July $, 1994, and recorded in Cutnberlatxi County Deed Book
109, page 092.
The description of the lot herein conveyed was taken from a re-survey of said lot, by Carl D.
Bart, RS., dated March i, 1995.
BEING known as 2157 Rimer highway, Shippensburg, PA 17257.
BEING THE SAME PREMISES which Barbara L. McMullen, unmarried,.by Deed dated
April 19, 1996 and recorded April 19, 1996 in Deed Book 137, page 965, in the Retarder of
Deeds Office in and for Cumberland County, gratrled and conveyed unto Terry L. Robinson and
Sharon C. Robinson, husband and wife.
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIItE
IDENTIFICATION N0.55669
44 SECOND STREET PIICE, SUITE 101
SOUTHAMPTON, PA 18966
~,5) 942-9690
CONSBCO FINANCE CONSUMER
DISCOUNT COMPANY
vs.
COURT OF COMMON PLEAS
CUMBI?ItLAND COUN'T'Y
No.: O1-4552
TERRY J. ROBINSON
SHARON C. ROBINSON
CERTIFICATION TO SIiERIFF OF CUMBERLAND COUNTY
AS TO THE SALE OF REA)e ESTATE
I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action
and further certify this Property is:
() FHA
() Tenant Occupied
O Vacant
() Commercial
() As a result of Complaint in Assumpsit
(7~ Act 91 complied with
ARDIAN, ESQUIRE
CONSECO FINANCE CONSUMER
DISCOUNT COMPANY
vs.
TERRY J. ROBINSON
SHARON C. ROBINSON
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
No.: 01-4552
AFFIDAVIT PURSUANT TO RULE 3129.1
PlaintifT in the above action sets forth as of the date the Praecipe for the Writ of Execution
was filed the following information concerning the real property located at ~ 57 RITNER
I3~G, 3~AY SHIPPENS~URG PA 1727:
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
TERRY J. ROBINSON
SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
2. Name and address of Defendant(s) in the judgment:
TERRY J. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
SHARON C. ROBWSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
3. Name and last known address of every judgment creditor whose judgmern is a record lien on the
real property to be sokl:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
.~
4, Narc~ and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertai~d, pleasesndicate)
Plaintiff.
S. Name and address of every other person who has any record lien on the property:
Nam Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
6. Nam and address of every other person who has auy record interest in the property and whose
interest maybe affected by the sale.
Namc
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland Courny Tax Claim Bureau
Dept. of Pubfie Assistance
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
33 Westminster Drive, P.O. Box S99
Cazlisle, PA 17013-0599
7. Name and address of every other person of 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 indicate)
Tenants(Occupants 2157 RITNER HIGHWAY
SHLPPENSBURG, PA 17257
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, irdornoation awl belief I understand that false statements herein are subject to the
penalties of 18 Pa. GS.A. 4904 relating to unsworn falsification to authorities.
c
G Y J VARDIAN, ESQUIRE
orney f laintiff
September 21, 2001
:,;~._ ,
I.A~V OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDTAI3, ESQUIRE
IDENTIFICATION N0.55669
44 SECOND STREET PIICE, SUITE 101
SOUTHAMPTON, PA 18966
(215)942-9690
CONSECO FINANCE CONSUMER
DISCOUNT COMPANY
COURT OF COMMON PLEAS
vs.
TERRY 7. ROBINSON
SHARON C. ROBINSON
CUMBERLAND COUNTY
No.: 01-4552
AFFIDAVIT OF SERVIC,~ PURSUANT TQ RULE 3129.1
I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants'
certified and regular United States mail and all lien holders or judgment creditors of record as
required by PaR.C.P. by first class United States mail, postage prepaid, on the date set forth below.
(See attached Exhibit "A").
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, PA 17013
TERRY J. ROBINSON
2157 RITN)rR HIGHWAY
SHIPPENSBURG, PA 17257
Cumberland Comity Tax Claim Bureau
1 Courthouse Square
Carlisle, PA 17013-3387
Dept. of Public Assistance
33 Westminster Drive, P.O. Box 599
Carlisle, PA 17013-0599
Tenanta/Occupants
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
Dated: _~-~
SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
GRE Y JAV IAN, ESQUIItE
Atto ey for Plaint'
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September 21, 2001
TO:
OWNER(S):
PLAINTIFF/SELLER:
DEFENDANT(S):
PROPERTY:
CUMBERLAND C.C.P. NO.
NOTICE OF SHF,RIFF'S SALE
OF REAL PROPERTY
ALL PARTIES IN INTEREST AND CLAIMAN'T'S
TERRY J. ROBINSON and SHARON C. ROBINSON
CONSECO FINANCE CONSUMER DISCOUNT COMPANY
TERRY J. ROBINSON and SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBTIRG, PA 17257
01-4552
The above captioned property is scheduled to be sold at Sheriffs Sale on MARCH 6.2002 at
10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. You
may hold a judgment on the property, which may be extinguished by the sale. You may wish to
attend the Sheriffs Sale to protect your interest.
A schedule of distn"bution will be filed by the Sheriff on a date specified by the Sheriff not
later than 30 days after sale. Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the schedule.
Sin ,
~,~.-
gory Javar ' quire
Law Offices of Gregory 7avardian
44 Second Street Pike, Suite 101
Southampton, PA 18966
(215) 942-9690
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIKE
IDE1QTiFICATION N0.55669
44 SECOND STREET PIKE, SUITE 101
SOiTfHAMI•fON, PA 18966
(2151942-9690
CONSECO FINANCE CONSUMER
DISCOUNT COMPANY
7360 SO. KYRENE
TEMPE, AZ SS283
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 01-4552
vs.
TERRY J. ROBINSON
SHARON C. ROBINSON
2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against TERRY J. ROBINSON and
SHARON C. ROBINSON, Defendant, for failure to file an Answer to Plaintiffs Complaint within
20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess
Plaintiffs damages as follows:
As Set forth in Complaint $87,460.43
Interest 114y97~f0
7(19!01 to 9/21/01
TOTAL $88,958.03
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown
above, and (2) that notice has been given in accordance with Rule 237.1, copy attached.
Damages are hereby assessed as indicated.
DATE: C- - d7 -UI
PRO PROTHY
SHERIFF'S RETURN - REGULAR
CASE N0: 2001-04552 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CONSECO FINANCE CNSUMER DIS CO
VS
ROBINSON TERRY J ET AL
DOUGLAS DONSEN
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
TERRY J
DEFENDANT
was served upon
the
at 1957:00 HOURS, on the 31st day of July 2001
at 2157 RITNER HIGHWAY
PPENSBURG. PA 17257
SHARON ROBINSON
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.10
Affidavit .00
Surcharge 10.00
.00
37.10
Sworn and Subscribed to before
me this ~ day of
ab~U/ A.D.
Prothono~ r ~'
So Answers:
~°'~~.~
R. Thomas Kline
08/01/2001
GREGORY JAVARDIAN
By:
Deputy eriff
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-04552 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CONSECO FINANCE CNSUMER DIS CO
VS
ROBINSON TERRY J ET AL
DOUGLAS DONSEN Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ROBINSON SHARON C the
DEFENDANT at 1957:00 HOURS, on the 31st day of July 2001
at 2157 RITNER HIGHWAY
SHIPPENSBURG, PA 17257 by handing to
SHARON ROBINSON
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this L `= day of
P~fo honotary '
So Answers:
..~'
R. Thomas Kline
08/01/2001
GREGORY JAVARDIAN
By~__ ~~ ~.«.
Dep y S eriff