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Home My WebLink About01-05948 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Conseco Bank, Inc. 7360 Kyrene Road Tempe, AZ 85283 v. Linda K. Lawrence 125 W. North Street Carlisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas Number C I - .$f11f' Ci(.)~CJ~ CIVIL ACTION/MORTGAGE FORECLOSURE 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 defenses or objections to the claims set forth against you. You are warned that if you fait 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO Le han demandado a usted en la corte. Si usted qu;ere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plaza al partir de la fecha de la ~emanda y la notificacion. Hace falta asentar una comparencia escrita 0 en persona 0 con un abogado y entregar a La corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, La corte tomara medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de est a demanda. Usted puede perder dinero 0 sus propiedades u otros derechos import antes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIA TAMENTE. SI NO TIENE ABOGADO 0 SINO TIENE ELDINERO SUFICIENTEDEP AGAR TAL SERVICO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 if; -.>'-'- "I' ^ ,'re';;, -'" " ,-"cO, ^ > ... __o,~__ "C~," ~< '" -"'~:"("<'--'"'-"'. ._N'"' ..~H McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Conseco Bank, Inc. 7360 Kyrene Road Tempe, AZ 85283 Cumberland County Court of Common pleas v. Linda K. Lawrence 125 W. North Street Carlisle, PA 17013 Number 01 - Q;u~l~~ CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Conseco Bank, Inc., a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Linda K. Lawrence, who is the mortgagor and real owner of the mortgaged property hereinafter described, and her last-known address is 125 W. North Street, Carlisle, PA 17013. 3. On 6/16/00, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1619, Page 905. 4. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 125 W. North street, Carlisle, PA 17013. -~''''J>_ ;'"'"_',f' :-"'_---:~':_~'-.."'.,-:_'..y___1__r'- .,- '. _ _,' ,_-_,,_'?",,'~'__' "-, I--'~ .'<fi,,_,_ - " < ,-n, " c, ;;.:, '.. ^."n', """_ -, ~ -. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 6/21/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest 5/21/01 through 9/27/01 (Plus $25.09 per diem thereafter) Attorney's Fee Late Charges Penalty Administrative Difference Cost of Suit Appraisal Fee Title Search GRAND TOTAL $85,360.53 $ 2,190.89 $ 4,268.03 $ 755.82 $ 4,519.84 $ 80.18 $ 225.00 $ 125.00 $ 200.00 $97,725.29 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. ~403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular and certified mail. -~J.!~-'~f'~'::'''_~'J'f''___,'),,,,,'~I,,',Pt:,,,,,;~'';_ ,---= ,,-,,,,"_,'.-- ""-'",'"" I, c'_._"" . "--',' -"-,-,,,,< -~, , -~ ''';'',J,; '~~ - "---r ,-~ , WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $97,725.29, together with interest at the rate of $25.09 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~"~~"l~t-:; ",',',-':-~ ~"'~,i-'-''''''-'-' <,'.~b":__ti',:;""v"{,,,.;i-{kO(," ,- :"-~ ^'~'" "I _.,' -, ~-'", -,~ ,__ ".", .' ".'V " ,. ~, _ , ,~ ':~"~: ,_,,' , 0,,"',' ^,""~ _-~ - , <"' - VERIFICATION The undersigned, Terrence J. McCabe, Esquire, hereby certifies that he is the Attorney for the plaintiff in the within action, and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. !l4904 relating to unsworn falsification to authorities. 1'"' -', ^ ~_' _c -,'""_~';,;1; ~,,~'''1''- '. '''''''''' ". '--"1'" -, - -,.- ~ ',- ,,~, -, ""-,'" ----, :'1---"'''- , ~, w"',- ..-.', . -:~"----'--'-':-""~-' " " . .~.- .':" <"" IS~~l .. .- " . . . ' ROBERT P. ZI~GLER RECORDER 0F DEEDS GUMBERLANG COUNTY - PA . 00 ~UN 20 . PI'! 1 ~5 . Commonwealth of PeuosylTauia QT~'s.3a-090 141001 Return. To: COn8l!:l<:'O Finance Attn: 'rrailinq Document. Area This Mortgage secures future advances 7360 south Kyr.p.. Road Tempe. AZ as.2aB . . . June 16, 2000 ~, DATE AND PARTIES. The date of Ibis Mortgage (Secunty InslJ:l\1!llelll) IS ............................................... and the parties. their addresses and tax identification numbers, if required. are as follows: OPEN-END MORTGAGE Spa", AhoT.This Line For IlA:cordillg DIlla Application # 0005176481 Loan # 6907724618 MORTGAGOR: Linda K Lawrence <.- , - ~---, -'~'-..-~ .,..- - -.- ......If ~ecked, refer to lhe attached Addendum incorporated heron, for additional MOrtgagoIS, their signatures and acknowledgments. LENDER: Conseco Bank,. Inc. Cottonwood Corporate Center 2~2S E Cottonwood prky 230 Salt Lake City, UT .84121 .. 2. CONVEYANCE. For gQOd and valuable consideration, the receipt and sufficiency of which is acknowledged. and to seCure lhe Secured Debt (defined below) and Mortgagor's perfoIlIlllllCe under this Security Instnnnent. Mortgagor grantS, bargains. conveys and mortgages to Lender lhe following desl:ribed property: Parcel ID~ 05-20-1798-127 Legal Desc~ipt1OQ: ALL THAT CERTAIN PROPERTY S.ITO'ATBD IN THB BOROUGH OF CARLISLE, ctlMBBRLAND COUNTY AND COMMONWBALTH OP PBNNSYLVANIA BIlING MOllB FULLY DIlSCRIBBD IN DIlBO IlATBD 10/01/96. RECORDED 10/01/96 AND APPIlARING AMONG T\IIl I.AND RECORDS OP T\IIl COllNTY AND STATll SET PORTH llBOVB IN DEED BOOK VOLtlME 146, PAGE 1036 The property is located in ..~~~.7.~~~.............................................. at............................................. . (CllOD\Y) ~25 W North Street Carlisle . 17013 ......................................................... , ................................................ , Pennsylvama ...................... _) (CltJl (ZIPC"') Together with all rights, easements, app1l1'leIlaIll:, royalties, mineral rights, oil and gas rights, all waler and' riparian rights. ditches, and wacer srock and all existing and future improvements, structureS, fixtures. and replacements thar may now, or at any time in the future, be part of the real estate described above (all referred to as "Property"). 3. MAXIMUM OI~~~~~N LIMIT. The total principal amount secured by this Security Instrument ar any one time sbaII not exceed $........:.......:..~............................... . This limitation of amOWll: does not include in!l:fest and other fees and charges validly made pursuant to this seCurity Inst:rumcnt. Also, this limitation does Dot apply to advances made under the terms of this Security Inscrument to protect Lender's security and to perform any of the covenants contained in this Security Insttumem. Form ID #1~11a4 d:5L llood619 PAGE "90S CJT-15-39.090 14100) /JHIge t of 51 PENNSV1.VANIA . MORTQAQE IHOT FOR FNMA. FHLMC. FHA OR VA) Cl ~lU4 en.,. SyatQiIl. l~.. $C. Claud,. UN Fotm GTH-MTGl.AZPA 41812000 { I -"'-<~;"""'~ . = ,,,=~"f \ . "' '-''- .IM. ~.< '"'~_~~""'~"''''''l~~ '" -1--'-"" w'";'~"mi"<."""lr" <,-.' --"'~~ -",,,,,-,",'~~~ , . 4. SECURED DEBT AND FUTIJRE ADY ANCES. The teno "Secured Debt" is defined as follows: A. Debt incurred under the temlS of all promissory note(s), contract(s), guaranry(s) or other evidence of debt described below and all their extensions, renewals, modifications or substitutions. (When referencing the debts below it is suggested that you include items such as borrowers' IUlmes, note amounts, interest rates, I1UllUrity dates, etc.) Note dated June 16, 2000, between Conseco Bank, Inc. and Linda K Lawrence. for $85,500.00, maturing June 21, 2025. i." ..- -" B. All filture advances from Lender to Mortgagor or other furore obligations of Mortgagor to Lender under any promissory note, contract, guaranty, or other evidente of debt executed by Mortgagor in favor of Lender executed after this Security Instrument whether or nOt this Security Instrument is specifically referenced. If more tban one __p.efJiQ!UigandllS .Jhifu'! Secoli-il!'I:!r}~~~ ~_~~'!P..!~ agr;esb.~!._'!1i~.c~~ !~t.!=~!Il_ ~I_~':fe ~1 !O~e ~ ai:lvances tore IgaDons ....t are !liven to or IOcurre,. y anyone or more ,..o~gor, or anyone or more Mortgagor and others. All future advances and other future obligations are secured by this Security Instrument even though all or pan may nOt yet be advanced. All filture advances and other future obligations are secured as if made on the date of this Security Instrument. Nothing in this Security Instrument sball constitute a connnitment to make additional or future loans or advances in any amount. AJ1y such commitment must he agreed to in a separate writing. C. All obligations Mortgagor owes to Lender, which may later arise. to t/Je eXtent not prohibited by law, including, bnt not limited to, liabilities for overdrafts relating to any deposit account agreement between Mortgagor and Lender. D. All additional sums advanced and expenses incurred by 1.ender for insuring, preserving or otherwise protecting the Property and its value and any other sums advanced and expenses incurred by Lender under the terms of this Security Instrument. . This Security Instrument will not secure any other debt if Lender fails to give any required notice of the right of rescission. S. PAYMENTS. Mortgagor agrees that all payments under the Secured nebt will be paid when due and in accordance with the terms of the Secured Debt and this Security Instrument. ,8" 6. WARRANTY OF TITLE. Mortgagor warrants that Mortgagor is or will be.lawfully seized of the estale conveyed by this Security Instrument and has the right to grant, bargain, convey, sell, and mortgage the Property. Mortgagor also warrams that the Property is unencumbered, excepr for encumbrances of record. 7. PRIOR SECURITY INTERESTS. With regard to any other mortgage. deed of trust, security agreement or other lien document that created a prior security interest or encumbrance on the Property, Mortgagor agrees: . A. To make all payments when due and to perforin or comply with all covellallts. B. To promptly deliver to Lender any notices that Mortgagor receives from the holder. C. Not to allow any modification or extension of, nor to request any future advances under any note or agreement secured by the lien document without Lender's prior written consent. CLAIMS AGAINST TITLE. Mortgagor will pay.alltaxes, assessmems, liens, encumbrances; lease payments, ground - - rents, utilitieS, and other charges relating to the Property when due. Le!1der may require Mortgagor'to provide to Lender copies of all notices that such amounts are due and the receipts evidencing Mortgagor's payment. Mortgagor will defend title to the Property against any claiUls that would impair the lien of this Security Insuument. Mortgagor agrees to assign to Lender, as requested by Lender, any rights, claims or defenses Mortgagor may have against parties who supply labor or materials to maimain or improve the Properly. 9. DUE ON SALE OR ENCQMBRANCE. Lender may, at its option, declare the entire balance of the Secured Debt to be immediately due and payable upon the creation of, or contract for the creation of, any lien, encwnbram:e, transfer or sale of the Property. This right is subject to the restrictions impoSed bX federal law (12 C.F.R.. 591), as applicable. This covenant sball run with the Property and sball remain in effect until the Secured Debt is paid in full and this Security Instrument is released. ' 10. PROPERTY CONDmON, ALTERATIONS AND INSPECTION. Mortgagor will keep the Property in good condition . and make all repaits tllat are reasonably necessary. Mortgagor shall not commit or allow any waste, impainnent, or deterioration of the 'Property. Mortgagor will keep the Property free of noxious weeds and grasses. Mortgagor agrees that the nature of the occupancy and use will not substantially change without Lender's prior written consent. Mortgagor will nol pennit any change in any license, restrictive covellallt or easement without Lender's prior written consent. Mortgagor will notify Lender of all demands, proceedings, claims and actions agaiost Mortgagor, and of any,loss or damage to the Property. o ~111'4 BoUIlt_ SyMem.. lr.c.. Sr. ClllUd. MH Fotm OTH-MTGlAz,.A 4181'2000 ~i-/(.L-..., BonK1619 PAGE .906 GT.15-3~090 14/00) (IMP 2 of 61 "!)~~ "Illli\ll . I ~ ~ . ~~ ~-,- - " M'. ,....."''''!''''~__~~~ '1"'1"' -I ~- 'P"i'ili"iltti"i -' :^' - ",- "". - "-",,<!!,.nm~ . Lender or Lender's agents may, at Lender's option, enter the PropertY at any reasonable time for the purpose of inspecting the Property. Lender shall give Mortgagor notice at the time of or before an inspection specifying a reasonable purpose for the inspection. Any inspection of the Propeny shall be entirely for Lender's benefit arul Mortgagor win in no way rely on Lender's inspe.:tion. . 11. AUTHORITY TO PERFORM. U Mortgagor fails to perfonn any duty or any of the covenants contained in this Security InstnnneDt, Lender may, without notice, perfonn or cause them to be perfotmed. Mortgagor appoints Lender as attorney in. fact to sign Mortgagor's name or pay any amount necessary for perfimnance. Lender's right to perfonn for Mortgagor shaD not create an obligation to perfonn, and Lender's failure to perform will not preclude Lender from exercising any of Lender's other rights under the law or this Security Insaument. If any construction on thePro~erty is discontinued or not carried on in a reasollllble manner, Lender may take all steps necessary to protect LendJ:r s security interest in the .. ,Propeny,jnclndingcompletion.ofJ.be.cons~ti.9n.___.. ___'__ ~_.._' .__ __--. ,__ U. ASSIGNMENT OF LEASES AND RENTS. Mortgagor irrevocably grantS, bargains, conveys and mortgages to Lender as additiooal security aD the righI, title and interest in and to any and all existing or future leases, subleases, and any other written or verbal agreements for the use and occupancy of any portion of the Property, including any extensions, renewals, modifications or substitutions of such agreements (all referred to as "Leases") and rents, issues and profits (all referred to as "Rents"). Mortgagor will promptly provide Lender with true and correct copies of all existing arul future Leases. Mortgagor may coUect, receive, enjoy and use the Rents so long as Mortgagor is not in default under !he letms of this Security InstrUment. Mortgagor agrees tl1at this assigwnent is immediately effective between tl1e parties to this Security Instrument. Mortgagor agrees !bat this assignment is effective as to third panies when Lender takes affirmative action prescribed by law. and that this assignment will remain in effect during any redemption period until the Secured Debt is satisfied. Mortgagor agrees !bat Lender may take actual possession of the property witl10ut the necessity of commeocing legal action and !bat actnal possession is deemed to occur when LendJ:r, or its agent, notifies Mortgagor of default and demands !bat any tenant pay all future Rents directly to Lender. On receiving notice of default, Mortgagor will endorse and deliver to Lender any payment of Rents in Mortgagor's possession and will receive any Rents in UUSt for Lender and will not commingle the Rents with any other funds. Any amounts collected will be applied as provided in this Security Instrument. Mortgagor warrants !bat 'no default exists under the Leases or any applicable landlordltenantlaw. Mortgagor also agrees to maintain and require any tenant to comply with the terms of the Leases and applicable law. , 0.. LEASEHOWS; CONDOMINJl~.s; PL..I._lIlNED UNIT DEVELOPMENTS. Mortgagor agrees to comply with lhe . provisions of any lease if this Security Instrument is on a leasehold. If the Property includes a unit in a condominium or a 'planned unit development, Mortgagor will perform all of Mortgagor's duties under the covenants, by-laws, or regWations of the condominium or planned unit development. 14. DEFAULT. Mo~gor will be in default if any party obligated on the Secured Debt fails to make payment when due. Mongagor will be III default if a b.reach occurs lID!ler the terms. of this Security In$trtm!ent or any.othe~ ~'!"!.ent el!:ecuted . for ,the..pwpose of creating,: secunng or guarailtymg the'Secured Debt. A good' faith belief by I.eDder that Wder anny time is Insecure with respect to any person or entity obligated on the Secured Debt or !bat the prospect of any payment or the value of the Property is impaired shall also CODStitute an event of default. IS. REMEDmS ON DEFAULT. In some instances, federal and Stale law will require Lender to provide Mortgagor with notice of the right to cure or other notices and may establish time schedules for foreclosure actions. Subject to these limitations, if any, Lender may accelerate the Secured Debt and foreclose this Security InstrUment in a manner provided by law if Mortgagor is in default. At the option of Lender, all or any part of the agreed fees and charges, accrued interest and principal shall become immediately due lIJld payable. after giving notice if required by law, upon the occurrence of a default or anytime thereafter. In addition, Lender shall be entitled to all the remedies provided by law, the temlS of the Secured Debt. this Security Instrument and any related documents. All remedies are distinct, cumulative and not exclusive, and the Lender is entitled to all remedies provided at law or equity, whether or not exc::::~ set forth. The acceptance by Lender of any sum in payment or partial payment on the Secured Debt after the e is due or is accelerated or after foreclosure proceedings are filed shall not constitute a waiver of Lender's tight to require complete cure of any existing default. By not exercising any remedy on Mortgagor's default, Lender does not waive Lender's right to later consider the event a default if it continues or happeDS again. GT., S.39-090 14100. (p.ge 3 01 8/ c ~198.c a..I:;.... !3vsC__. In~.. St. Cloud, MN Fotn'l GTH.MTGLAlPA 4IB/20OO LJ{k L~ . ,BooK1619 PAGE 907. ~"!~"""''"1 -~ ~ "_"~~~.al~~ -, '~t ~ ~- 'i,_,,:,~:! ~"sv"'''! "'",-_'" ,""~,,, '-"""""""<:<_1 _ . . 16. EXPENSES; ADVANCES ON COVENANTS; ATTORNEYS' FEES; COLLECTION COSTS. Except when prohibited by laW. Mortgagor agrees to pay all of Lender's expenses if Mortgagor breaches any covenant in this Security Instruntent. Mortgagor will also pay on demand amount incurred by Lender for insuring, inspecting, preserving or otherwise protecting the Property and Lender's security interest. These expenses will bear interest from the date of the payment until paid in full at the highest interest rate in effect as provided '" the terms of the Secured Debt. Mortgagor agrees to pay all costs and expenses incurred by Lender in collecting, enforcing or protecting Lender's rights and remedies under this Security Instrument. This amount may include, but is not limited to, attorneys' fees, coun costs, and other legal Oltpenses. This Security Instrument shalt remain in effect unlil released. Mortgagor agrees to pay for any recordation costs of such release. 17. ENVIItONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used in this section, (1) Environmental Law . ~.- means... without. Iimitat!on"the .Comprehensive.Environmental.Response,-Compensation.and.liability.Act-(CERCLA, 42. ' U.S.C. 9601 et scq.), and all other federal, state and local laws, regulations, ordinances, coun orders, attorney general opiDi()llS or interpretive letters concerning the public health, safety, welfare, environment or a hazardous substance; and (2) Hazardous Substance means any toxic, radioactive or hazardous material, waste, pollutant or contaminant which has characrtristics which render the substanCe dangerous or potentially dangerous to the public health, safety, welfare or CDvirooment. The term includes, without limitation, any substances defined as "hazardous material,' "lOne substances,' "hazardous waste" or "hazardous substance" under any Environmental Law. Mortgagor represents, WamnlS and agrees that: A. Except as previously disclosed and acknowledged in writing to Lender, no Hazardous Substance is or will be located, stOred or releaSed on or in the Property. 'This restriction does IlOt apply to small quantities of Hazardous Substances wat are generally recognized to be appropriate for the normal use and maintenance of the Property. B. Except as previously disclosed and acknowledged in writing to Lender, Mortgagor and every tenanl have been, are, and shall remain in full compliance with any applicable Environmental Law. C. Mortgagor shall immediately notify Lender if a release or threatened relc:ase of a Hwrdous Substance oCcurs on, under or about the Property or there is a violation of any Enviroomcntal Law concerning the Property. In such an event, Mortgagor shall take all necessary remedial action m accordance with any Environmental Law. D. Mortgagor slJa11 immediately notify Lender in writing as soon as Mortgagor bas reason to believe there is any pending or threatened investigation, claim, or proceeding relating to the release or threatened release of any Hazardous Substance or the violation of any Environmental Law. 18, CONDlThINATION. Mortgagor will give Lender prompt notice of any pending or threatened action, by private or public entities to purchase or take any or all of the Property through CO"""","orion, eminent domain, or any other means. Mortgagor authorizes Lender to intl:tVene in Mortgagor's name in any of the above described actions or clainIs. Mortgagor assigns to Lender the proceeds of any award or claim for damages connected with.a condemnation or other taJ<ing of all or any pan of the Property. Such proceeds shall be considered paymenlS and will be applied as provided in this Security Instmment. This assignment of proceeds is subject 10 the terms of any prior mortgage, deed of trUSt, security agreem~nt or other ~en document. 1'. INSURANCE. Mortgagor sball keep Property insured against loss by fire, flood, theft and other hazards and risk:; rcasonaDly associated with the Property due to Its type and location. This insurance shall be maintained in the amounts and for the ~ that Lender requires. The insurance carrier providing the illS1lJ3llCC shall be chosen by Mortgagor sul!jcct to Lender s approVal, which shall not be unreasonably withheld. If Mortgagor liills to maintain the coverage deScribed above, !.ender may, at Lender's option, obtain coverage to proleCt Lender's rights in lbe Property according to the lCDDS of this Security Instmment. All insurance policies and renewals. slJall be acceptable to Lender and sha1l include a'standard "mortgage cliwse" and, where applicable, "loss payee claus~." Mortgagor shall immediately IlOtify Lender of cancellation or tenninalion.of the insurance. Lender shall have the right to hold the policies and renewals. If Lender requires, Mort~gor shall immediately glveto Lender all receipts of paid premiwns and renewal notices, Upon loss, Mortgagor shall give .mmP<iiqte IlOtice to the insurance carrier and Lender. Lender may make proof of loss if IlOt made immediately by Mortgagor. Unless otherwise agreed in writing, all insurance proceeds shall be applied to the restoration or repair of the Property or to the Secured Debt, whether or not then due, at Lender's option. Any application of proceeds to principal sball not extend or postpOne the due date of the scheduled payment nor change the amount of any payment. Any excess win be paid to the Mortgagor. If the Property is acquired by Lender, Mortgagor's righllO any illSUtaIlcc policies and proceeds resulting from ~g;. fa the Property before the acquisition sball pass to Lender to the extent of the Secured Debt immcdiately before the acqUISIUOn. ' o ~199. s..... Sy.n_. IncN St. Clo\idl, MN Form QTH.fv'lTGLAZPA 4/8/2000 LK..L. .~ sood619 iji;~ 908 '.. GT~t 5-39-090 (41001 (p"fP3 4 o/6J .."",~.~rlJ'l!l!' ,. ~_ ,~~~. """"...",._""".~ "".., I-! .- ~- 1 ~ ~ ~ ",- '"' ".,,~_ , "'" ,.',,,,,,.,,;,..r ~~ .,_~c~ '_0 . r'<"""'f.;!'l!t'''*''.q~ .. . 20. ESCROW FOR TAXES AND INSURANCE. Unless otherwise provided in a separate agreement, Mottgagor will not be required to pay to Lender funds for taxes and insurance in escrow. 21. FINANCIAL REPO~TS ANp ADOmONAL DOCUMENTS. Mortgagor will provide to ~Dder upon request, any fiDlUlCial statement or mfonnation Lender may deem reasonably necessary. Mortgagor agrees to Slgn, deliver. and file any additional documenrs or cehifications that Lender may consider necessary to penect, continue, and preserve Mortgagor's obligations under this Security InstrtiDlent and Lender's lien status on the Property. 22. JOINT AND INDJ:VIDUAL LIABILITY; CO-SIGNERS; SUCCESSORS AND ASSIGNS BOUND. All duties under this S<:curity IllSlIIIIIlCnt are joint and individual. If Mortgagor signs this Security Instrnment,but does not sign an evidence of debt, Mortgagor does so only to mortgage Mortgagor's interest in the Property to secure payment of the Secured Debt . ".and,Mottgagot.!Igc:s I)Ot,agr~ to.bemmo.nallyJ!a!?le qn.the S~red De1?t. If.this_Se~tyJnstrument,secu!'"5 a~_ between lender and Mortgagor, Mortgagor agrees to waive any rights !bat may prevent Lender from briDg1llg any Knon or claim against Mortgagor or any party indebted under the abligation. These rights may include, but are IlOtlimited to, any anti-dcficiency ar one-action laws. Mortgagor aHtCCS that Lender and any party to this Security Instrnn:Ienl may extend, modify or make any change in the tenns of this Security Instrnment or any evidence of debt without Mortgagor's consent. Such a change will IlOt release Mortgagor from the leIIDS of this Security Instrnment. The duties and benefits of this Security Instrument shall bind and benefit the successors and assigns of Mortgagor and Lender. 23. APPLICABLE LAW; SEVERABn.ITY; INTERPRETATION. This Security Instrument is governed by the laws of the jurisdiction in whiCh Lender is located, except to the extent otherwise required by the laws of the jurisdiction where the Property is located. This Security blsttumenl is complete and fully integrated. This Security lnsttument may 1IOt be amended ar modified by 'oral agreement. AJJ.y section in this Security InstrUment, attachments, or any agreement related lD the Secured Debt that conflicts with applicable law will IlOt be effective. unless that law expressly or impliedly penults the variations by written agreement. If any sectian of this Security Instrument caonot be enforced according to its termS, that section will be severed and willllOt affect the enJforeeability af the remainder af this Security Instrument. Whenever used, the singular sball include the plUIal and the plUIal the singular. The captions and headings af the sections of this Security Instrument are for convenieru:e only and are not to be uSed to interpret ar define the terms af this Security Iostrument. Time is of !he essence in this Security Instrument. . 24. NOTICE. Unless 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 1 of this Security 11IStrnment, ar to any other address designated in writing. Notice to one martgagor will be deemed to be notice to all mortgagors. . ' 25. WAIVERS. Except to the extent prohibited by law, Mortgagor waives any right to appraisement ~lating to the Property. 26. OTHER TERMS. If checked, the following are applicable to this Security Instrument: . ...... Uoe of Credit, The Secored Debt inclndes a revolving line of credit prayision. Although the Secured Debt may be reduced to a zero baIaoce, this Security lnslrwnent will remain in effect llIilir released. .. . -- ...... Construction Loan. This Security Instrnment secures an obligation incurred far the constructian of an improvement on. the Propeny. ...... FIXture F11i"ll. Martgagor grants to lender a security interest in all goods that Mortgagor owns now or in the future and that are or will become fixtureS related to the Property. This Security Instrument suffices as a financing statement and any carbon, photographic or other reproduction may be filed of record far purposes of Article 9 of the Unifonn Commercial Code. ......Purchase Money. This Security Instrument secures advances by Lender used in whole or in part to acquire the Property. Accordingly, this Security Instrument, and the lien hereunder, is and shall be coJlSlrued as a purchase money mortgage with all of the rights; priorities and benefits thereof under the laws of the Cammonwealth of Pennsylvania, ......NOTICE TO BORROWER: THIS DOCUMENT CONTAINS PROVISIONS FOR A VARIABLE INTEREST RATE. " GT-1So3g...090 (4/00) (plIf/eS"fIJJ ~ ~1994 &ricen Sv-fomt. I"..... St. CItNd, ,MN Form GTH-MTG1.AZPA 41612000 ~t.j( L:.- --:;::::> . .Bood619 rAGE9Q9 !. ..."jffi~r~!~!lf1!lI!!~ 1~ ,- "^- I' ~ - - ~~.""..,..,..,..~- "1 ~. , ~ ~~ =~ :;'i;.." ,,,,,-.,,,,,,-,,",,,,,,",~.' - '., -""._,~'""_l,~"'.'_"_.,->,,c",,v,'"_, ,'_ " .. . ...... Riders. The covenants and agreementS of each of the riders checked below are incorpOIated into and supplement and amend the tenDS of this Security Instrument. (Check all applicable items] ...... Condominium Rider ...... Planned Unit Development Rider ...... Other ..................................... N/AAdditional Terms. .- -.....SIGNATURESdly'sigoing.below;...Mortgaglir; inteilding to"be 'IOgally'bowid-herebj, agrees -to .thifrenm aha"coveiwus - . . contained in this Security Instrument and in any attachmeDlS. Mortgagor also acknowledges receipt of a copy of this Security Instrument on the date stated on page 1. ~!...~~........~.-Ih3f.~J (S~) L1noa K ",awre.nce" (D...) .n...........~......................................................... (Sis-no) (Dole) (S~..................iO';;). ..~. . ......... ... ..................................... (W-) , ......... ................... a.. .................. ..~..~.....~....~...... (SJpo...) (n...) ........... ....... ~....... ..~... ",., ."'.. ..........~..,~......~~,.... .....~, (W-> ACKNOWLEDGMENT: . COMMONWEALTH OF ...~~~~X'.~.':':~~~~......... , COUNTY OF .......~.':':~Q:.............} ss. On this, the ......15.......... day of ..........Iune.,...2QOO.............. , befoIe me ...~........E....I?tJ~... . ,........... the widersigned officer, personally appeared .~~~..~..~~::'::.':..............................:.............................. .......................................................................................... , known to me (or satisfal:toriIy proven) to be the person(s) whose ~s) is ~ribed to the within illStrumenl, and acknowl"<!.ged ~~!.!!e1she executed the same for the purposes therein co.otained. I ""~~l"~. . """~':f~e >(~. ' In W;tDess whereof, I bereunto set my haDd and official Sea1~ a".$.~~~.iii~.01!:....z;'''~~ E '. -" .... ~-" "'fe:.' .~. . :"-'<' - My eommission expires: . " '~.. 'Co .iJieO"~ ~\'.03 E , 'F.'~,j. .~. . NOt SEAl ............ ........... ....'.a>>i.......~W~.J>>l.... ROBERT E. KNAUB, Nalary Publlc . .' .."'11- '~Y'Z-<#j Lower Allen Twp., ClimberlandCounty .................... ........... ..... lI!..:;~r:!:9...::~:,l'~:..... My Commission ExpireSApn117, 2004 ThII: ollltllccr '~Jl')" ',.':\7 II is berebyodccme'fied that the address of lhc ~er Within D3IIIed is: .~~~.:?.~~....l.~:::....................................... Cottonwo m:porat.e ~t:or~2!25 E Cctt.onwOod ITky 230, Salt. Lake C:i,l;;y, ur 84121 ..~. ....... .... ... ............... ..~ .. .......~.-............ ......... ........................ ................................... .~............ .-0.. . . Stai&.l1tPeiiiisy)va;iiii................................................... County of Cumberland} ::i~r e~t~~~fice for the recording of Deeds in . I a~~C'PLi:b.rr'nd COUntV.a;;e:. , -Vor.-_p~ eLUJ Wlt . myha . .....TGlAzPA ~~ '. .., of o.e;r, ~ I".go 6.'6/ Boo<<1619 PAGE ..910 . . O~T8lt"'i' ''''''!';''''~ ",?;r.;:.\lji(l~I,j.~~,"_~~,,~ ~,-> '..."""""""_.,," ,"~",~.....- "1",.-. .... ~\), "'f!-. , ~" . "" ."~ '~'",.-,,~-, ,rr"'"___' _"""ho"" ".,,:,,:.,..,.,.,,,,,,,, ~-._-'-,,-- I ~-'-'-=~~~:=l~i!'ilt~:1""~fr-\K"fs:';;:'J1r{T~~'';''f~u:nit:li'fr't\'f':'ltl~'fij~.i~i1'r ~...... ........ ~ ~ ~ t? (:) ~l ..... ?v - D ~ ~ b,. ....c ..t ~ft)() & 8' ~ I I CY :t,.1~ rt J (") C :!'" -om n1Pl Z::tJ z~ -~;~": r:: r-'] <:"".. )>l'-' z' 5>~ ~ ,~~~~",,~r-"'\)~'ff'''''~''~-'~,rJ''(li1i1!'F,,"';\%;i~T~:P]l ~~r.i"'!::~.';''''- o (--, :.,', , ' if) ';-'i'''~)f~'''i,,,jM~:;!)j~~illj'J:-~~ti~~~~\ C> C") -< -.- ~ ~-L~: ~--,:,'! -;..~ <.}1 ,;,,' ."'~ ~j~j;( ~ -0; :.'i] :,~;o :--:::trl"; ,~ -I "'J> 5;:} ..< -0 -,.~ r;:- (J1 '')!;''1~'r~';; ,-~- "".,. .~ ""'~~". SHERIFF'S RETURN - REGULAR CASE NO: 2001-05948 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONSECO BANK INC VS LAWRENCE LINDA K KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LAWRENCE LINDA K the DEFENDANT , at 1800:00 HOURS, on the 16th day of October ,2001 at 125 W NORTH ST CARLISLE, PA 17013 by handing to MARK BALTIMORE ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.25 .00 10.00 .00 31.25 r~~ R. Thomas Kline 10/17/2001 MCCABE WEISBERG CONWAY Sworn and Subscribed to before By: Ms4f- me this /9 ~ day of (J~, :J&1J( A.D. ~'. w-,-"a..~ --. J~prothonotary ~ i\'.'1'!>"'<'i""~.e!, '!'l'>~," ~,~.~ . ,., ..,""",~~ I " l' ~".~"-~~"1-'"'" ~~ ;;:~":"t ". ," -, ~ .~ .. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO BANK, INC. CUMBERLAND COUNTY CUMBERLAND COUNTY COURT OF COMMON PLEAS v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 9/28/01-12/6/01 TOTAL $97,725.29 S 1.731.21 $99,456.50 AND NOW, this 31* \~~. ~0.~~ TERRENCE J. M ABE, ESQUIRE day of ~ , 2001, Judgment is entered in favor of Plaintiff, Conseco Bank, Inc., and against Defendant, Linda K. Lawrence, and damages are assessed in the amount of $99,456.50, plus interest and costs. BY THE PROTHONOTARY: (}~ !<. "0 ~ i~~< 1" -~"~"-~ "." ",~,:"~,,,'~'~' _c':'," -r,5"'"" .,-,,". .,.. 'r'-"__ ,_, '1- "~ ,--' ~!,"""--'" -" , ,-~" ,'--~ " I~ _CO",.", '_""""."'" ."." ,_ """"". ~~,!~Jlljl ,. ^ .~, , ^" ~M , ,.,~ " ".-,- '.'"'' '-";U,~.~., ~ - - L] ~'J1W~' "Mr~'~'"tfi'fi'hl''-:f~'';ff'-o~A~r;::'t:_lWY1tf1lr~_i'~t1'f('~ () c::- -o~ rI1rQ;' <-if ::?;-" OJ :;;~ ~6' $0 :$;0 j '~ <<:;:) c> -q - t::::J !:!.1 , > c.) ,J;J -'rn C:~j :_drt, ~:~~{~~f c5n--, $ -<,' -.. ""1:J -'. _C, ,)j ~.v '.0 _ ..' 'c., ,J~fl[:!~Yl..,;;;~~Ij<:;[>[F"h".j;"%\3W'i:~''''!lf'-I'1f~!1j1!jit'i~"~I;~~~'i\!r"l1,-l:il,~~;ji~~'J',~WJ~,!1r~ 1.:.--''''''''' \.,~,.,.,.. "-, " ~ McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO BANK, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM CERTIFICATION I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of civil Procedure No. 237.1 is attached hereto and marked Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THIS ~ f:j DAY OF /J~ ,2001. ~~ TERRENCE J. Mc E, ESQUIRE Attorney for Pl intiff N1!l11~L!P-- /I. 1/rI~ NOTARIAL SEAL l MlC.HELLE A. HOLAClK, Notary Public Cily of Philadelphia, Phiia. COUII~ ! ~M '" 1 ,"V CqmmlSSlon EXOIres March 28 005" -,~ ~~~_. "n_~~ 'f\~_, . . ."',-;,. 'Y"~'.,';.",.,":~ 'n".~, ."",m,,,,,, " 1"""-- -,. " ''''''. - '7,.'""'," ,~ ~1 ~, --r.1;,~ ,. roT .' ,i ,c-,...'"' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COUNTY COURTHOUSE, CARLISLE, PA 17013 CUMBERLAND LAWRENCE E. WELKER Prothonotary To: Linda K. Lawrence 125 W. North Street Carlisle, PA 17013 Conseco Bank, Inc. v. Linda K. Lawrence November 21, 2001 Cumberland County Court of Common Pleas Number 01-5948 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims set forth against you. Unless you act within ten (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: Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 If you have NOTIFICACION IMPORTANTE Usted se encuentra en est ado de rebeldia por no haber presentado una comparecencia escrita, ya sea personalmente 0 por abogado y por no haber radicado por escrito con este Tribunal sus defensas u objeciones a los reclamos formulados en contra suyo. Al no tomar la accion debida dentro de diez (10) dias de la fecha de esta notificacion, el Tribunal podra, sin necesidad de comparecer usted en corte u air preuba alguna, dictar sentencia en su contra y usted podria perder bienes u otros derechos importantes. Debe llevar est a notificacion a un abogado inmediatamente. 5i usted no tiene abogado, 0 si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina, nombrada para averiguar si puede conseguir asistencia legal. Court Administrator cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 TJM/cf "'....... , :j'>>"-",,,,,,~-,,-~-"; -',"""-, -, -' 11'>I''''''~' c_ J\" Ej~~BUl. n. EXHIBIT "A" , _~; ,I, ,r' ~,,,,,,,..=, "- . McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO BANK, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors I Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Linda K. Lawrence, is over eighteen (18) years of age, and resides at 125 West North Street, Carlisle, PA 17013. SWORN TO AND SUBSCRIBED BEFORE ME THIS (; f!J-- DAY OF /J~, 2001. N~~u!Ac j. )f,/~ I MlCHEllE~TARIALSEAl I . City of Phi'=~~Public . ~~'!1.misSion Exoire's March 28'~05 . ~ . (\ \ 0\J\ ~ Uo ~ ~t e.~Lo- TERRENCE J. McC E, ESQUIRE Attorney for Plalntiff : r:'11~t""i~- --,. - -,,-,1:'~'- """",,, 'c"_V''',."_' ~..," -"i~"~ " " '. . ~'"::., ",,,-'-' , ", , , -I' -- .. ~ :;{"'" VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. CVQ~~ 'vfl~~~ TERRENCE J. McC E, ESQUIRE fhMll"';;r.r- . '.\., c, c-1''-'-,r.~[-I':ry:i"'-'~'' _ "~" ,'.,'_ "_--n"'" _~'I' " .. ',',"'- ,-i'.''''''."'''' -,-' I'~ - {" ~ ~, OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Linda K. Lawrence 125 West North Street Carlisle, PA 17013 CONSECO BANK, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as~ndicat"ZieelOW' ~ (J ~.k., Curtls R. LonCV 0'- Prothonotary XX Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe. Esauire at (215) 790-1010. ~h-..,,, ;-'-'"- :----'~_:_'';:--'0-t''''',_,'''YC' '<,~~'OC-",., ';,1"7>"'> - '"_"_""I~''-'!'_ ,-~ ,-' "",. 1" ,," , -- ~"_ ,_ '" ,o"r..-." _ "',," 0', ~_ -- 1", ,""", ,," "'."""'~ ,. -, = I r,jill'~"""'Wf'1f1'1r"f~iTTffi'W'::n\\ii'*lIrii<iTrrliji"'r:m'T1" ~ ~ ~ ;0:J \......." ' ^ -+" -..J (J-. }-- c! C) ''''-.f\ 'l- ~ 0J ~ C). -.... ,..., \ .jv -. c.. ........ (') 0 " c ~ " ~ 0 ;:gRi P'1 -:?' -r, n .L- .--'", L.) r Z c' 0~~:' '~,-} kC) -ry C} ~..:, - ~~ ;';:r :x !~:f~; z" ,-~c; N ;PC L, Z W ~ :< "1--1 (D =< 1i!Il, _'", . ,~ or.,. ",r~~A "., ,~!'j.''T"_~.~~,,._.,... ill ,_ ~" _, ~-"'~!!'I.,r,__~~~__~.;""""~- __ ill!:'~~-P"Nr.~"i!~_''''-'F~j~i~'f;.'''m~:!!lJMl:.~'WF-M'Tr!5,~~...AA~~-!JR!~~~~.t~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION FILE NO.: 01-5948 CIVIL TERM $99,456.50 CONSECO BANK, INC. AMOUNT DUE: INTEREST: from 12/07/01 v. LINDA K. LAWRENCE ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale I contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 125 West North Street, Carlisle. PA 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of N/A County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ. against the garnishee (s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Signature: Print Name: TERRENCE J. McCABE, ESQUIRE z;Z(;L January 08, 2002 DATE: Address: 123 S. Broad Street, Suite 2080 Philadelphia. PA 19109 Attorney for: plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 I:f~ >'-' -'.'0-'. -"-FfPf_"'-"'_~;=~o_""0~'>Ffi'_"!<" __I' ',' "~ ".,'- '-p_'1' ~- -~ - , '-1 ~"'- ~.m .~'-^ - "'n~ . . . - LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF GROUND WITH BUILDING AND IMPROVEMENTS ERECTED THEREON LOCATED IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY AN ALLEY; ON THE SOUTH BY WEST NORTH STREET; ON THE WEST BY PREMISES NUMBERED 129 WEST NORTH STREET; ON THE NORTH BY AN ALLEY. HAVING THEREON ERECTED A TWO-STORY BRICK DWELLING HOUSE WITH BACK BUILDING KNOWN AS AND NUMBERED 125 WEST NORTH STREET. Parcel ID # 05-20-1798-127 Being Known As: 125 West North Street, Carlisle, PA 17013. ;.bl':ll, I!'IT,.,..,l Y', .'..'" ,.i,j,! 0'. _.,_ '1"" ',__, - - ,e.1'_.' .___.'" _'''0'"''," , ~. t." - , 1" 'M~" ~ . ,- _~_, ';;;~__* "<" 0,' ~~_~ ~. -i.II'. ..II....'''I.~.. rin'rli~11'dll/lilrT""'r:1T'I."flnI'W1'~~ .-....n'."r' ~ """ ..,_ . .. . () ~ ~ c.v ~ (Q. w ..0 ..... !'i i ~ . , 1f :-- ~ & 0 d )U 8 ~ 0 ~ () ~ 0 C) s:; ,'> +l-i 0 , I .;:: .. , r~ Ji!~~; ~ "- ~ 2::::,:, lJ 6} 7r ... (5),; (.J': (). r- , ::: , " r} -<..,7 , -, r;::C ~~ (' .vJ- ~(? 1'::1 , , .:; ....C - " )::;.c.: . .., ~ ;; "- ,,- --I "' ._1 -< F-:5 BH ,.., "", "" ~~-"_7" ". - "..,':c-';!',,,, lJi!!ll:iJIIll!"i I!mJ~~~W~i'~~0:"':_'__.._ ",";,'_ __="t_"_o",..?,,,,_r>'p~,_,-~~:W!~:~~:~~w*1\~~"'-W>'!-1l'!i~~.~, ]~ ~",t'll'iM1~,,, McCABE, WEISBERG AND CONWAY, P.C. BY, TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CONSECO BANK, INC. v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 125 West North Street, Carlisle, PA 17013, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s) Name Address Linda K. Lawrence 125 West North Street, Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Linda K. Lawrence 125 West North Street, Carlisle, PA 17013 ".,.' ,- -, -I "-, '- .,",' ,~-" . "__ 0 .-1' ~- - ,,',~ <' 1- ~ If,.tr'r-~'' "'.""'-," -~,,--. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address plaintiff herein. 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of Plaintiff has knowledge who has may be affected by the sale: every other person of whom the any interest in the property which Name Address Tenant (s)/Occupant (s) 125 West North Street, Carlisle, PA 17013 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. /QuGr: / TERRENCE J. McCABE, E~IRE Attorney for Plaintiff January 08, 2002 DATE '. ""'~-"" ~,- '". "~"--' ~ .,~ ' - , II''''' ~ ~ -~, _70"<,"", ',-' - , _, _" _~, -_j.. 'n', ,. ,,0_'_'"" "_-"'1 _' ",,~r:,:- N ,-., :: ::'::~i~'llIr!- ,.~__ EXHIBIT IlAIl LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF GROUND WITH BUILDING AND IMPROVEMENTS ERECTED THEREON LOCATED IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY AN ALLEY; ON THE SOUTH BY WEST NORTH STREET; ON THE WEST BY PREMISES NUMBERED 129 WEST NORTH STREET; ON THE NORTH BY AN ALLEY. HAVING THEREON ERECTED A TWO-STORY BRICK DWELLING HOUSE WITH BACK BUILDING KNOWN AS AND NUMBERED 125 WEST NORTH STREET. Parcel ID # 05-20-1798-127 Being Known As: 125 West North Street, Carlisle, PA 17013. -"~-'0"~"''''~'~'!'-^'?' -/ <, 0, "'-, , 1_ -'. " ',",_~' ,'_' ,'0 , .,,]~,,",__ ,', __ "I,~ ,,' , ......... '" ,. ", .-...~ ,,,". _,:r_"",,~~~=''''''<~- ,-" -= --',;'<';" __n - ''h - -- ',-.' "t_' ',O~' -rnrnln"'rr:-"~~l_1~<'itl'''Y3f:~f~',t:C'mrrlt'' 1tt '-'11:"":'-' il'':~~\~'ft'~~:tMJli1ltl.:nt'';}ry~'fj~Ti-'r-1~ (') C ;;~ j~f,:'; QirF-: ~,;~" C~~C" ..,:: =-'~:: r~ $~~.' - :el -" ..., C:) N CJ '-I :~.;:; ;:r= (I; f', """'~' ~_ "" "~i~WJf~~r;l-"lfl!")l'Ri1i11fi'~tl~j!!<~-!I'\,!~jl..~~~'I"-f~~!l[!~~~,Ill-,;;>,",, ~""..;~~_~i \f MCCABE, WEISBERG AND CONWAY, P.C. BY, TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CONSECO BANK, INC. v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Linda K. Lawrence 546 Mountain Road Boiling Springs, PA 17007 Your house (real estate) at 125 West North Street, Carlisle, PA 17013, (more fully described as attached) is scheduled to be sold at Sheriff's Sale on June 15, 2002, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $99,456.50 obtained by Conseco Bank, Inc 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 will be canceled if you pay to Conseco Bank, Inc the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790- 1010. , ;,,:~t~,,,,,,,^,,~ _._, ~f^ '-""_",^_,_~~__ _,',,'''''~__'~_' __^~,_ ..> ~,_^~ _ ~^o ___~,_"~_" ,,_ 'n,~ _ ,^ ,_ ' .-_'^'" r-'" . , 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within (30) days of the sale. This schedule will state who will be recei ving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. ?f!'!<f<P". 1,. . .,,~__ -'''''"0: 0._-': ,,_ ',.~ _ 1""1'1-< ~,~,;", '-'.1' , ,-""'-,,--,-<' , ' ~, ~, -~, , '_ c 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 'TiI#i,"~"",_ " ',"_'1 "~c,-,'-^~i,~",.,-,-,, ^""~~J'" , I -,' "-'"Y- ,-,~_ ' ' ,_, '_:' ,_"" , '-~ -',,^ , ~--"'~" -' -'!'~-"'f-' L,,_, >,' 'I'. ~"",-,- -, -"'""''"Thio''--''_ Ii TI' I ruiiTr'1\l~i'fii'IT U rnnllirrT'IIiUUJriT' 0 .-.... C f"-J -0 ff 'c~~ m T~,. 2.:: :i; L~ ,'- ; , (j) j'" en , , .c ~ ':' , C) -', ""D " ~ Coo, __~i L ~-'''' (--, ) >~ ("~ q ~~ --- " " ~j 0:) -< _. _. ,,:,,!_,.J~~;::'e-;<m!!ffi'J~Wf!\!f~l.L~Iil9--~w'j,"'i:$Nr~~~l,~~~~'!lWll'?~~jll,;"liMMt1,;~i\!;~~,~ty~; LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF GROUND WITH BUILDING AND IMPROVEMENTS ERECTED THEREON LOCATED IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, ON THE EAST BY AN ALLEY; ON THE SOUTH BY WEST NORTH STREET; ON THE WEST BY PREMISES NUMBERED 129 WEST NORTH STREET; ON THE NORTH BY AN ALLEY. HAVING THEREON ERECTED A TWO-STORY BRICK DWELLING HOUSE WITH BACK BUILDING KNOWN AS AND NUMBERED 125 WEST NORTH STREET. Parcel ID # 05-20-1798-127 Being Known As, 125 West North Street, Carlisle, PA 17013. ':;~-,,~,~Jr~lt\"=J1,J 0 ",""'~-7 >_o'.,~ -,c,"_,' ""I :- ,--,., ~', "j.- . ~ yo. _~',~" - __=, __,. 1-- !-1 McCABE, WEISBERG AND CONWAY, P.C. BY, TERRENCE J. McCABE, ESQUIRE identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO BANK, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM AFFIDAVIT OF SERVICE 1, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 23rd DAY OF APRIL, 2002, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "AU. Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." ,~.~WOAt-e / TERR E J. McCABE, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE: ME THIS 23rd DAY OF APRIL, 2002. }twiJ/1i d. *~ NOTARY PUBLIC '-NOTARIAlSEA:L"-'--"" :i2HEllE A. HOLACIK. NotarY I1.Jblic I :,J,ItY, of Phl,ladeI, ph, ,i,a. P, hila. County , ,I , Q?~ISS~Jxpires March 28, 2005 i ?;l;~!:,;_,.i.; - ,~-"'".. ,~".",__" "h">'~-, ~d("J~, ,." I-,"~" "~ '", _",W~ " -I - , ,I'''> McCABE, WEISBERG AND CONWAY, P.C. BY, TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO BANK, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 125 West North Street, Carlisle, PA 17013, hereto a copy of the description of said property is attached and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s) : Name Address Linda K. Lawrence 125 West North Street, Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Linda K. Lawrence 125 West North Street, Carlisle, PA 17013 3 . Name whose judgment Name and last known address of every judgment creditor is a record lien on the real property to be sold: Address Plaintiff herein. 4. mortgage Name and address of record: Name of the last recorded holder of every Address Plaintiff herein. 5. Name and address of every other person who has any :record interest in or record lien on the property and whose interest may be affected by the sale: Name None. FXr\\B\l - Address "I\. ~ :!n _J __'_ -" _~~ r, -^ -t--'-~<;-".~,-,~,--? --:"':f'._~'--X- ~ ~, , ,_e '_ ,,_ ',_'m_ _~ " \,=.,,,"- r?iI'" . V,'" 6 . Name and address of Plaintiff has knowledge who has may be affected by the sale: Name every other person of whom the any interest in the property which Address Tenant(s)/Occupant(s) 125 West North Street, Carlisle, PA 17013 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 Commonwealth of Pa Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE ~~Ol~ RR E J. McCABE ,-mfQUIRE Attorney for Plaintiff April 23, 2002 ..' X' H.'- \ B\1 E " i'p\~ "!fj.~L_;._~_____,, __~_" '7''",..-_, _ .,"" ~~ -"I "., -,~. - , ". >~."" ,- i" " -,-, "J r..f" McCABE, WEISBERG AND CONWAY, P.C. BY, TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff CONSECO BANK, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM DATE: April 23, 2002 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Linda K. Lawrence PROPERTY: 125 West North Street, Carlisle, PA 17013 IMPROVEMENTS: A two-story Brick Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on June 05, 2002 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, pennsyl vania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution 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. EXHIBIT usn t~l ", '_~,_">,,,,,,,,,,,_~,,,,__,,!,,, ">,<,_,,, c_", ..--', ,.. ,', "-'..-~ .",~ - ..'- '"U ,-tl lI>w" ;;o.Ot,...... ~ 61 ~i U1 3 ~E w :g. CD :::J~ :;J fa - " )> " ii g " . It ~ o o ~c} gg ~'z o.~ J!lg ,," 00 a- lJ! II . , " , n 0 ,: ~ . i" ~ ~ ! =' '8 g J " ~ z . ~ o ~ a o o ~. ". "', o ~ 0- i S' 1" o ~ III !, ~~~g~.;! l ~;"8S'~1~ ag~:!D (1. 1,..;,3i3 ~ ::'I siS.~=la~ ~~[i~~g ~.....6 g.0'~ a ~Sfi~ 38 e. -,-i~~l' ~ :I:;l.~ ~ :~...IH -,,~~ U [ [H~[if~ ~i~8~~(1. HjHi! ~ii..hl~ !~ii;H ~~h 'in if 11';;: 9 ~ !!!. IiFl!!!!,lajj ~i'~f~!~ ilh:~t~ jl . lHgc; &. ilD~5"i fil!~h 0 aii=~! is 3 ~lr~ m~, ii<t"~ hf.- i3~;i~[ . -.iffflD "2.-< ' !!.!j' " .~ f.- P' co ~~ 2~ ... lotI} e.~!t"2g..ii'L_--. i ~C:':iTO'I~- lij't:lgll.... _slDoil I '""", '-~-""0~W,I%Y..._" _ "r" ~ '" ~I 01<0 ~ '" ~ ~ I , ?, ~ ;;o!~o /;,.. :3 / U)~~,'1) (6 J f/I , ~~ ~r (J I OO~:1: ~ ~ I ~ ~~ I I ~ ~:3 , L Vv:> I 0> I " '" i '" '" r!!!~<9~V l",'t-"f\'( I . I ~ Ie -- :;? Q> ~~ C ~ ! ( ~ S I ~~~ -cG1~ ~ t.P~') S;~~ ;W~ '?uh uJ-f{? !~ i --r I :; i I I , I i I I I I ; I I 1 I i if 3 o m ~ ~ -0 - ~ :e.......,/!!' ~ ~~5Dl;\\E m",O ....c:c: "'l>_:e....Zm :J:iit",-'" ~N...~(j) ~~o~:!~ o -~ - ",6~ -0 -<-00 _ ...Z ~ m(j)Z .... ~ I ~ o I ~ g?8 ~ODOO ~ I " "i9 ~ If's;: I m iP 31 ~g a I t: I ~ ~; J I i ~ )1 d] ...,t i ~. I?J 6" ~;, 0000" ifllh!~;P~ un U(_ 1r1~"'[~ -:::)' h11'l- [ll. ~ ;::j 1 nl m I i 1 ! I l!lI k..kT' g [ j I 1 Ij'~' ~ i ~ i , I u m I' . ' ! "", ~ G I I , I I I li'd'i q ,'" )> ;j' ~!!l.:~ ~ jll co 03og, - (I) ~",,"a.1if ~~m ~i~: ~ o::z: Ql:J ;;;,;-~ '" iir~ fi::i.o..""" -~ :r aa.l;:'t. 'i!'I c]) m,1 <il "'I ",;;i ~~l ~~I 01" o.m <J !!om l "".il ~il Q. =;i1 oerd 00, cal !'ll ;:>01 410, "o;i mol /, 9~ P4" I, IS; ~ .~\ -..,.. '" :c S::-... :. """I'~ C/) 'W ."'i'J 0.. "') ./ 01 \ ".60 L 6 L ~..\'!O"'lr"II.m 0 6 6 ~/./aN~'\. ..;zo n ~d" oSl"OOS 6LOL - / ".LLSH.ZZlld 39VJSOd"s'n OSOL ~- ~,\\~ ~.---~'p". 1 ,1 'TIOO! mIl I 1'TI;:ul EXH"IB1T lj~" I 1;;1 " '1 < ." ~ "~ ~. - :-:-:>':~'.'.':>:'."'.. " 11 ~-~,~ >-~- 111 ,1 II. nn""'lfi Dl ,L~"~',~M;Ii!'ffl~~,"1~"~,~J'_J'il!i!1!!flI;&"" __,,,~~,,,,,-,~~~~"'"i'-''N,''''' '""l._~~'f,''' r""-"" C) .<;' .....-'~ ~~~F< 2' ~!~' ~ r--'t <;0"-"-.., ~~,~S' .;~ -.j -, -".. ""'''_.' T r ;~' '-.,.-' ::r_'l" --_I -,) ::::~ } :,---.) c::, ",-'-, {;:) -c:.'; ~-::J .-< % ";';~:'I.""~,~!,,,,~",,,f!j-f~{i!;;-'t~~~)lh\!l!@~~-lM~~r:,r McCABE, WEISBERG AND CONWAY, P.C. BY, TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Conseco Bank, Inc. CUMBERLAND COUNTY COURT OF COMMON PLEAS v. Linda K. Lawrence NUMBER 01-5948 Civil WAIVER OF NOTICE UNDER PA.R.C.P 3129 AND AFFIDAVIT Terrence J. McCabe, Esquire, attorney for Conseco Bank, Inc. h~reby acknowledges that Conseco Bank, Inc. has received notification under Pa.R.C.P. 3129.2 of the Sheriff's Sale scheduled in this matter for June 5, 2002, and also waives its right to any further notification as junior lien creditor in the above entitled case with regard to premises known as 125 West North Street, Carlisle, PA 17013. J~ 111/e U-i TERRENCE J. McCAB~, ESQUIRE Attorney for Household SWORN TO AND SUBSCRIBED BEFO~_ ME THISJ.LfIJ- DAY OF '/fl~ ' 2002. 1JUt)v IlL a. ~ NOTARY PUBLIC l:~j5l~ ~~" 0,- c:f',..:w'-p ','",C",",,'?-' 1 "','--',-1-- -,-'." '-, ~.. ~, ,,' "^_ 0, _ o-i _C __', ,V.' ,_< ~ '.~__ '",~"'.!'c''':''''' _ -oj ~,",' '- ~'" '.'""'c,,'= """'''''''''''''''''jU'',.''''liIinllI1m[]'II'''"('''r 0 0 (:) C '" .-n $-: ~ -::! -U\.:).'l ;:u:< 10'11'" -< ,,- 2::-:r_" N I'P :ZC' C;' lliS 0) :~:~ (:J '" '1 ~ " 'Ti -:;~ ::.;~ r5 ~,..- ,-n J;> c: Co:? -"',I, :;z: .~ ::;! :D ...J -<' d ~ " '- " '. fS ~ '^"";~_~' "'1,~ Tii,iJ"'~~OO:~!f-ll.-~k,f;.f1!'""W_$>;;':',,""i-'!W"t';1;?,~l".~'l'f.lNli~""!'''If<',~""""l~~-mI1~'I1IW<<,~,,~,_,_lb~,I~JJ!1i . , COMMONWEALTH OF PENNSYL VANTA } COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Conseco Bank Inc is the grantee the same having been sold to. said grantee on the 4th day of September A.D.,:- -12002, under and by virtue of a writ Execution issued on the 15th day ofJan, A.D. )2002, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 5948, at the suit ofConseco Bank Inc against Linda K Lawrence is duly recorded in Sheriffs Deed Book No. 23, Page 3269. IN TESTIMONY WHEREOF, I have hereunto set my hand .~ and seal of said office this day of September, A.D. _2002. ~c-r y Recorder of Deeds i"__T'~O",~=_. " "~~ ." ", " 'I . -, ~ ~ ,-" , Conseco Bank, Inc. VS Linda K. Lawrence In The Court of Common Pleas of Cumberland County, Peunsylvania Writ No. 2001-5948 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named defendants, to wit, Linda K. Lawrence, to her last known address of 420 Cascadilla Street, #4, Ithaca, NY 14850. This letter was mailed under the date of February 21,2002. Linda K. Lawrence received the letter on February 23, 2002. Return receipt card was returned to the Cumberland County Sheriffs Office on March 20,2002 signed by Avis Giles. Note - House located at 125 West North Street, Carlisle, PA 17013 is empty. The Carlisle Post Office provided the above forwarding address for our office. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2002 at 3:10 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 Linda K. Lawrence located at 125 West North Street, Carlisle, 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: Linda K. Lawrence, by regnlar mail to her last known address of 420 Cascadilla Street, #4, Ithaca, NY 14850. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according 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 September 4,2002 at 10:00 o'clock A.M. He sold the same for the sum of $ 1.00 to Attorney Terrance J. McCabe, for Conseco Bank, Inc. It being the highest bid and the best price received for the same Conseco Bank, Inc., of 7360 Kyrene Boulevard, Tempe, AZ 85283, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of $558.05, it being costs. Sheriff s Costs Docketing: 30.00 Poundage 10.94 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00ÿLaw Library .50 Prothonotary 1. 00 "<'-_-<_''','''''''HI,~" ~C' ~_, " I' ~ r - " ~ ~_."" ""- , Milage Certified Mail Levy Surcharge Postpone sale Law Journal Patriot News Share of Bills Dist. of Proceeds Sheriff s Deed 3.45 8.21 15.00 20.00 20.00 163.10 136.15 25.20 25.00 29.50 $558.05 paid by attorney 9/12/02 Sworn and subscribed to before me This ;)o!!< day of Jl;;;~ 2002, A.D. C}/t' 0 JVI1I!hJ,~ r thonotary _'-"--'__'>-""'l'f~"~I'lJ>l~" _,. SOAI;~e~, ~ ~~ r~r't~<.f'..R'~ R. Thomas Kline, Sheriff 1~\',L1 By<-JO '~ Real Esta Deputy v ~ al).;l- jO,lJ1) t? jl$O , a. fiJ'/51 tv, j:l.. 911 z/ , ", -'-' - - 1 _'"lilt >, ,,~, r='--'""'"~ ~~~~ _" .. '~N , i . McCABE, WEISBERG AND CONWAY, P.C. BY, TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CONSECO BANK, INC. v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 " ! I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the " i !'; above action, set forth as of the date the Praecipe for the Writ i! i- i' ,I 'I Ii of Execution was filed the following information concerning the real property located at 125 West North Street, Carlisle, PA :j " 11 17013, a copy of the description of said property is attached i hereto and marked Exhibit "A." ,- " , 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Linda K. Lawrence 125 West North Street, Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Linda K. Lawrence 125 West North Street, Carlisle, PA 17013 : 'i:-\~fHif'),PMiIIV~"~, _ ~, ~ " ~"" ;"'" '-"I "'~ w.. _,. ~~"...,..,. ~.~~ # . 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein. 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. 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 Address Tenant (s)/Occupant (s) 125 West North Street, Carlisle, PA 17013 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~~~ TERRENCE J. McCABE, ESQ IRE Attorney for Plaintiff January 08, 2002 DATE 'f''''),:'''0'~''-<l."W,'''''''''_?="< _", ~, . - ~ , LEGAL DESCRIPTION EXHIBIT "A" ALL THAT CERTAIN TRACT OF GROUND WITH BUILDING AND IMPROVEMENTS ERECTED THEREON LOCATED IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY AN ALLEY; ON THE SOUTH BY WEST NORTH STREET; ON THE WEST BY PREMISES NUMBERED 129 WEST NORTH STREET; ON THE NORTH BY AN ALLEY. HAVING THEREON ERECTED A TWO-STORY BRICK DWELLING HOUSE WITH BACK BUILDING KNOWN AS AND NUMBERED 125 WEST NORTH STREET. Parcel ID # 05-20-1798-127 Being Known As, 125 West North Street, Carlisle, PA 17013. "";;@""',"-;:S-_;'''",''1''''""=,,,,,,,,,, _~, ,""",""' ~ __~ ...._,.~ ~~, ,-,~,~ ~" ~,. ~~- _m" ~ .' ",-", "Jo McCABE, WEISBERG AND CONWAY, P.C. BY, TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CONSECO BANK, INC. v. LINDA K. LAWRENCE NUMBER 01-5948 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Linda K. Lawrence 546 Mountain Road Boiling Springs, PA 17007 Your house (real estate) at 125 West North Street, Carlisle, PA 17013, (more fully described as attached) is scheduled to be sold at Sheriff's Sale on June 5, 2002, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of. the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $99,456.50 obtained by Conseco Bank, Inc against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF J S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Conseco Bank, Inc the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790- 1010. i''"'~W'~ ,,~'" f~"",,"", ,,1__ . , , ~~ H"~ . 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 the following notice' on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the.sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,. the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 'fW::'~'%.-->'!""""""-""'''''-.w' ." ~" ~1 , - .- , 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ,'!-t''''''C''-''~7''''0'~_',,". ,,,,,,,.j~,,, \! ~r' ~, -, ,-.., 1-' I~~' :-,... . LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF GROUND WITH BUILDING AND IMPROVEMENTS ERECTED THEREON LOCATED IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY AN ALLEY; ON THE SOUTH BY WEST NORTH STREET; ON THE WEST BY PREMISES NUMBERED 129 WEST NORTH STREET; ON THE NORTH BY AN ALLEY. HAVING THEREON ERECTED A TWO-STORY BRICK DWELLING HOUSE WITH BACK BUILDING KNOWN AS AND NUMBERED 125 WEST NORTH STREET. Parcel ID # 05-20-1798-127 Being Known As, 125 West North Street, Carlisle, PA 17013. "I ,:,y!r,,"'<""'-t''''-'"'-<'''__'',_~ ,-~ . "'''''~I v ~~.- """'" ~ ~~., ~ "" ~~'!"" "~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-5948 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due CONSECO BANK, INC. PLANTIFF(S) From LINDA K. LAWRENCE, 125 WEST NORTH STREET, CARLISLE, PA 17013 (I) 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 notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to orfor the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has. been added as a garnishee and is enjoined as above stated. Amount Dne $99,456.50 Interest FROM 12/7/01 L.L. $.50 Ally's Corum % Ally Paid $ I 03 .25 Plaintiff Paid Due Prothy $ 1.00 Other Costs Date: JANUARY IS, 2002 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name TERRENCE J. MCCABE, ATTY Address: 123 S. BROAD STREET SUITE 2080 PIDLADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ill No. 16496 ~: bZo~ 0 . [}, ~~ """^"-~'_I""_, " - ,1 - --~ , . ~ ~"'<J'. ".r."~-' ~,"~""'''<c~''''''crli"C''''C'''*''''''~' '['''III''Tli"" []''''''''l11:"IW'' REAL ESTATE SALE No. 21 On February 8, 2002, the sherifflevied upon the defendant's interest in the real property situated in Borough of Carlisle, Cumberland County, P A, lmown and numbered as 125 West North Street, Carlisle and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 8, 2002 By: ",)0 ~ JwCLl:~ Real Estate Deputy ~ ~ ~ ~ c\\\-\1d < ~,'\~, ,; '. C', \i I 'I', i' ",' ," ,I',:, ' ,,'1\ "c c S\ III u<" v " '('II \\6 ",,(I'J ",I ,,<,,\oj() - ,1-'; \.t'. \~'~ ~ ,: \, j\) ... ~ "c;\\" ..1.1"' "ffll!li!,~~,.~].""",~iIfl}i!~~!1il-""~,..~~\t.Il!~l'liiW'M'$r~",,,,:_;~h""T'i'~'-''''''!''1r"<!,1;~!~i'rdi-'''0-'''~!lW'',?i~;~1'f'''"-'''''O-;-''<t''i'~''~ , THE PATRIOT NEWS TUE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and..I!lll Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and Is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds In and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. .~~ ~~~~....~....................................................... . , 17th day 0 ay 2 A.D. Notarial Sear Terry L. Russ~lI, Notary Public Harrisburg, Dauphin County My Commission Expires June 6, 2002 NO ARY PUBLIC Member, PennsyNania Association of Nota~~ commission expires June 6, 2002 PUBLICATION COpy S ALE #21 REAL ESTATE SALE No. 21 Writ No. 2001-5948 Civil Term Conseco Bank, Inc. vs, -- Linda K. Lawrence I _.' ~. -. -6Uy:Terrence J. McCabe DESCRIPTION ALL ,THAT CERTAIN tract of ground with buililiog and improvements erected thereon : ~ Jocated in-Jhe Borough of Carlisle, Cumberland County, Pennsylvania. more particularly bounded ~_descriWasfollows: I, QiLtbe EaSt by an alley; on the south by West ~'NOrth S~t;; on the West by premises numbered 1_- !~9.WestN9rth Street; on the North by an alley. HAVING tl,1~rcon erected a two-story brick dwelling ~~~~ ~ith b_ack building known as and JITimoere.ol23_WestNorthStreet. ParcellD No, 05.20-1798.127. BEING KNOWN AS: 125 W", North Street, Carlisle, PA 17013. L , 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 Probating same Notary Fee(s) Total $ $ $ 134.40 1.75 136.15 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News. newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... .i PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, V1Z: APRIL 26, MAY 3,10,2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the 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. ~ SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 NOTARIAl. , LOm E. SNYDER, Notary PublIc Callilllll Bcro. CumileIIand County My CommI88ion ExpiI9S Man:115. 2005 , '-'1'.",,,,,~,,~,,,,,.,,,%>,~,,",,,,~ .'"',_ _c" < ~'I . r ' . U,._'_ ~ ~m~~~ ~, _ "~~W , _ III,,," "~ llil ' ''I:" ,> ~,,~~-~, ,,,,,,,-,~~,,"- .,,,,,, - ,"', _AiL ES_ SALE N0. 21 Writ No, 2001-5948 Civil Conseco Bank. Inc. vs. Linda K. Lawrence Atty.: Terrence J. McCabe LEGAL DESCRIPTION ALL that certain tract of ground with building and improvements erected thereon located in the Bor- ough of Carlisle. Cumberland Coun- ty. Pennsylvania, more particularly bounded and described as follows: ON the East by an alley; on the South by West North Street; on the West by premises numbered 129 West North Street; on the North by an Alley. HAVING thereon erected a two- story brick dwelling house with back building known as and numbered 125 West North Street. Parcel ID #05-20-1798-127. Being Known As: 125 West North Street, Carlisle. PA 17013. p 1',1 ~."~_.P / B&R 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 546-7400 FAX: 215-985-0169 J' Philadelphia Association of Professional Process Servers Seivices for Professionals Inc. : PLAINTIFFISl : 1.::bnseCij Bank ~ Inc, AFFIDAVIT OF SERVICE CASE NO, 01-5948-Ci v il DATE RECEIVED May 13, 2002 DtFfI;J8~Nf<{~) La"lr e nce SERVE AT I of Cumberland County ~ Notice of Real Estate Sale 420 Casca Dilla Street #4 Ithaca NY 14950 SERVE BY: June 14, 2002 . COMPANY CONTROL NO. CS165384A REFERENCE NO. Ae;e;eI-'LeJ l5y. Served and made known to Linda K. Lawrence on the 11 day of JUNE ,20~,at 9:20 o'clock, A M. 420 CASCADILLA STREET, #4, ITHACA, NY 14850 at iCommonwealth of Pennsylvania, in the manner described below: M Defendantls) personally sarved. "0. Adult family member with whom said Defendant(s) reside(s). Relationship is o Adult in charge of Defendant's residence who refused to give name or relationship. o Manager/Clerk of placing of lodging in which Defendant(s) residers). o Agent or person in charge of Defendant's office or usual place of business. o Posted ~~~PTION AGE 58 HEIGHT 5'5 WEIGHT 220 RACE black SEX female :=======================~~==================================================~========= On the day of _ Defendant not found: 19_, at ___Moved ___Unknown ___No Ans o'clock, _M., ___Vacant ___Other >------------------------------------------------------------------------------------ .------------------------------------------------------------------------------------ DEPUTIZED SERVICE Now, this _____ day of , 19_, I do hereby deputize the Sheriff of County to serve this ___Summons ___Complaint ___Other a return therof and according to Law. By (Competent Adult) County Sheriff's Check $ ;~=================================================================================== *** Special Instructions *** ASAP ! NAME OF SERVER 'Process Server P A TTT.A F'F.r.H1' being duly sworn according to law, ~ deposes and says that he/she is process server herein names; and : that the facts herein set forth above are true and correct to the best of . their knowledge, information and belief. Sworn to & subscribed before me this Notary Public, State 01 New Yor Chemung County No. 01 FE50518 0 Commission Expires Nov. 13, 20 P'fj Ju. w YpUi 11 day of JUNE 20~ Sheriff Process Server I Competent Adult Law Firm T~l I 'Cl11",'C! fh,..Caut::, E;:::,"-Iu":, i:::; AttorneY'sN'l~ 5vuLI, 13, VctJ 5LI ",,,,L ,Address Pli.llctJell-'llict PA 19109 790 1010 Telephone # ; @2000 Philadelphia Assoc. of Professional Process Servers Rev 1 SuiL" Zoeo For Pl6i"l.i rr ATTEST Identification # PRO PROTHY September 4, 2002 DATE ": cT '7<'''W}Aii~.''~' -'p-""',"'~"W!lIB"\f'i-;;~,,' ~,., ,,'" --', '''T' ,"'-o"~"T'<~'~""""""'_"'''Jr''''''':'''' e" ,..,c..,r.'"~~.,, '~--~'~"";"."--- - ..'"'~~'m'"c..,""""'"~"''''''''-=~''''''~~~1':'<_'~"; 'I-"W';-"'"'"I"'O"''''''"--",,,,-,- ~~-~. > .',>, ~"'~x' . - ,,,<,",",,!'-~~.u'~:'''~'ftlJmrn"~ _h]-~lFLJt~'< L'ij""<~rt~'.-tunT;1('lii"fr,,~wY""Wtr~i'-~'~"[(lKYr'If~~~'"i~% " ~ (') 0 0 ) c: N -1'1 ;;::. ~ .-\ -0 OJ A12 tpl'-r. .~ :;4~ .c- .....'" &;s;:; .....J 0 ~.? ~-:-'r' Q:CJ "'0 ::E-"T\'o ~- ~2 :It ....~. 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