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HomeMy WebLinkAbout01-06645 '. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMERICAN GENERAL FINANCE, INC., : Plaintiff vs. NO. 01- l...I...Y-S Gc..>~ l '--r~ ACTION IN MORTGAGE FORECLOSURE DENNIS L. PORTER, Defendant TO: DENNIS L. PORTER PROOF OF SERVICE I, HERBERT p, HENDERSON, II, ESQUIRE, of Reidenbach & Henderson hereby certify that on December 31, 2001 I mailed by first class mail a copy of the Notice of Intention to Take Default Judgment in the above matter upon the following: Dennis L. Porter 27 Back Street plainfield, P A 17081 REIDENBACH & HENDERSON By: l~ / Herbert P. Henderson, II, Esquire Attorney for Plaintiff . Attorney lD. #56304. 36 East King Street Lancaster, PA 17602 (717) 295-9159 '_.)"'F,,~I"'-'WiJ -'1." . .__ ~ " 'I ,". ~ ," " -- ~""...,. - .,.......,,1'1"''>>''''''. IJij~UJf_:i ~ :~j l JIU! ,,- ,~_'d ,._.,,_.,. ,~ .".~-- \If,_~kl~~->f.~~'''~',-;;iUl0'''''';-li'~il!j%*j~V.~-F~H~F,~\(t1t;~!iFW'-;'''''-;l'j1<0 -~,- - 'v,~'>o',I' ~. " ,~~-" - --~H= " , ~H'''''_''''''''' () C) C) ~ N -n t.- .1 .'0 cr' ~~ -("i ['1"1 r"(' --- I~:" :z ;:.- ~;. l___i ~~ .,- . ~ (.~ S~) 'J ~2 ~,:,. ) ~;.~~ , r'0 _:-:, ':?" :.:> ~~: O"i ~, -<. ~..J -::.: i s-- .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMERICAN GENERAL FINANCE, INC., : Plaintiff NO. 61- {P(",if5 ~ ~ vs. ACTION IN MORTGAGE FORECLOSURE DENNIS L. PORTER, Defendant 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. tumbe~ IANel Covni.!.f eAR. AssoeiAtibN a Li 1oe.ld:;'1 AveNUE ,Qt:'I! Carlisle, PA 17013 ( ''In J ~ <f-<J- 31 Ie, Ie, REIDENBACH AND HENDERSON By:JW- ? (?f Herbert P. Henderson, II, Esquire Attorney for Plaintiff Attorney I.D.# 56304 36 East King Street Lancaster, PA 17602 (717) 295-9159 -,"~~",~>jj t _., ",,'-,:U;O',-,-; -" , " -~. ~ ~ ~!\l ~ . IN THE COURT OF COMMON PLEAS OF COMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMERICAN GENERAL FINANCE, INC., Plaintiff NO. 0/- 14I4LfS ~;r~ vs. ACTION IN MORTGAGE FORECLOSURE DENNIS L. PORTER, Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U. S. C. ~ 1601: The Ulldersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the Ulldersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. REIDENBACH AND HENDERSON Herbert P. Henderson, II, Esquire Attorney for Plaintiff Attorney ID# 56304 36 East King Street Lancaster, PA 17602 (717) 295-9159 :;-,,,'1~,,,.,w~._,__,,_,, "f,:'~O - ,-. t.-' --" r_.~ ~, , ~= ~.- - IN THE COURT OF COMMON PLEAS OF CuMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMERICAN GENERAL FINANCE, INC., : Plaintiff NO. o/~ iJt..'f5" ~7~ vs. ACTION IN MORTGAGE FORECLOSURE DENNIS L. PORTER, Defendant COMPLAINT 1. PlaintUfis American General Finance, Inc. 6 South Hanover Street Carlisle, PA 17013 2. The name and last known address of the Defendant is: Dennis L. Porter PO Box 207 Plainfield, P A 17081 who is the Mortgagor and real owner of the property hereinafter described. 3. On November 12,1998, Mortgagor made, executed and delivered a mortgage upon the premises herein after described to AMERICAN GENERAL FINANCE, INC., which mortgage is recorded in the Office ofthe Recorder of Deeds of CUMBERLAND County, in Mortgage Book No. 1497, Page 180. A true and correct copy of the mortgage is attached hereto and incorporated herein by reference and marked as Exhibit "A:' 4. The premises subject to said mortgage is described as attached in the legal description set forth in Exhibit "BOO. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due JUlIe 12, 2000 and each month thereafter are due and UlIpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. <,~.'fl{i!>~~'lr ^ "'~"', '" ~ " __ ~, " -1 '='" ,-- -~ ~~~;~ ,. 6. The following amounts are due on the mortgage: Principal Balance Interest 8~2~ltmoughll~1~1 (per Diem $2.96) Attorney Fees Cost of Title Search TOTAL $ 8,849.94 $ 2,165.28 $ 272.32 $ 1,500.00 $ 110.00 $12,897.54 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 ofa third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. The Combined Notice has been sent to the Defendant by regular and certified mail as required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "C". 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "C"; and/or (ii) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency; or (iii) Subject premises is either a commercial property or is not the Defendants primary residence and therefore the Act does not apply. WHEREFORE, Plaintiff demand an in rem Judgment against Defendant(s) in the smn of $1'1,8'1'1.5"4, and other costs and charges collective under the mortgage and for the foreclosure and sale of the mortgaged property. ~y: REIDENBACH&HENDE~ J.~_,r-(7_IL ~ Herbert P. Henderson, II, Esquire Attorney for Plaintiff PA ID No. 56304 36 East King Street Lancaster, PA 17602 (717) 295-9159 'Y'~,~,_ "-'C',,"., ~_.' ,""H " -'"- 'of -.--- :tj VERIFICATION Herbert P. Henderson, II, Esquire hereby states that his is attorney for Plaintiff in this matter, that he is authorized to make this Verification, and that the statements made in the foregoing Complaint are as related to him by Plaintiff and are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 pa. C. S. Sec. 4904 relating to unsworn falsification to authorities. i lu-({~ / Herbert P. Henderson, II, Esquire Attorney for Plaintiff I.D. # 56304 '-i::",~~~ Account No. '" ~S00 Pl- '. 1"- ,! L ._.", .,. 'j;- JEt~DS , I,~ ~:' ~ ;.; L ,\ t~ D CO U N T Y - P A '9B NOU 13 Prl ~ 58 ~:~l (Space Above This Une For Recording Data) OPEN.END MORTGAGE THIS MORTGAGE SECURES FUTURE ADVANCES To Borrowers whose Revolving Une of Credit Agreement and Disclosure Statement provides for a Une of Credit not exceeding $5O.000-and'.;.: Variable Rate feature: Notice to Borrower: This document contslns provisions for e varlsble Interest rate, THIS OPEN-END MORTGAGE ("Security Instrument") is given on NOVEMBER DENNIS L PORTER 12 ,19 98 . The mortgagor Is (Borrower", (indicate marital status) This Security Instrument is given to AMERICAN GENERAL FINANCE. INC. which is organized and existing under the laws of Pennsylvania, and whose address is 6 SOUTH HANOVER STREET. CARLISLE , Pennsylvania ("Lender). Borrower may incur indebtedness to Lender in amounts fluctuating from time to time up to the principal sum of TEN THOllSAND OOT.T.I\RS *****************",,*************** Dollars (U.S. $ 10 . 000 _ 00 ), which amount constitutes the maximum amol:.lnt of unpaid loan indebtedness, exclusive of interest, thereon. which is secured under this Security Instrument. This debt is evidenced by Borrower's Revolving Una of Credit Agreement and Disclosure Statement dated the same date as this:Security Instrument ("Note'~, which provides for monthly payments, with the full debt. if not paid earlier, due and payable as provided in the Note. This:Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; (c) the perforrriance of Borrower's covenants and agreements under this Security Instrument and the Note; and (d) the unpaid balances of loan advances mad~ after this Security Instrumeht is deliyered to the recorder for record. For this purpose. Borrower does hereby mortgage. grant and convey to lender the following describer propertY located in CUMBERLAND County, Pennsylvania: All that certain property in the VIL~! of Plainfield, TOWNSHI~ of Wagt ?eunBbo~o, COUNTY of Cumberland, ~d COMMONWEALTH of Pennaylv~ia, Pa~cel I. D. #46-18-1394-077, being mo~. fully de.oribed in Dead ~ted 09/10/86, recorded 09/19/66, and appearing among ebe land recorda of the County and State eet forth abov., in Book E-32, page 624. I \~ + C( A\~ eX V\l V'l Prior Instrument Referenco: Mortgage Book No. 187 , Page 453 D38-llOO28 (Rev. 6-96) RovoMng BooK1497rAGE J.80 PENNSYLVANIA ~ : "0'h~,. ~ '_"' if ~ .-- ,. , ,...", "" .. ~-::~-::;:;'M'--J:::LLZ/ D RT ' Borrower DENNIS L PORTER (Sean rt:.wc'~ U '{gk S . \ l ~'A::kQ, KIMBERLY S I (Sean Borrower COMMONWEALTH OF PENNSYLVANIA, COUNTY OF CUMBERLAND so: On this 12TH day of NCJVF.MRRR 19--9L, belore me, BRF.NDA K RTSHOP the undersigned ollicer, personally appeared DENNIS L PORTER , known to me (or satisfactorily proven) to be lite pereon(s) whose name(s) IS $ubscribed to the within instrument and acknowledged that he execUted the same for the purposes (IS/are) therein contained. WITN. E~~ my hand and official seal, the day and year aforesaid. ~,~,"'.IlIIl"" ,>0 . ,~, ""'" ''''''. ". ~""""'''~'Jt!l "<l< ,,",~~...f\.t'~..;'..."H">,~ t",..<. '_~ ~~v .... nJ........ .'.Y# ~ ~ :::.;:;-" ..~ ""P'.:.. !',. -. V ~ (~/',~\ "\,.;'1'\~\ :. i c..,.~\..~~V~;j'~i' "), ....."'1. .: '\~" '''''':e"". ~,.. .... '~"'...." ,,-..,r.vv--.. MY~'''''\~~ Notarial Seat Brenda K. 5ishop, Notary Public Carlisle 50ro, Cumberland Counly My Commission Expires Nov. 20, 2000 Member, PennsyllJania Assoctatlon of Notaries h1?o.N"lo,- rB~ Arx:8 Notary Public of Pennsylva la .. ~ -", , CERTIFICATEQF RESIDENCIi . '" >/'.~ ~.~~-<:4':~~.::~:".~'_.:~~. ~'t~:'. , I, ~ DEANNA R BANKRR'l' 'r~~iI1I"9".';P~JflJtv.lireliojng mortgage, hereby certify that the correct residence address of said Mortgagee Is 6 SOUTH HANOIIER :STREfr:,\'.~I5IlE. ;, , Pennsylvania. Witness my hand, this 12TH day of NOVEMBER .,' !J:~(~~~'~":\\~. :.~ . ,..... --~ I"'" ~'~::;'l2:,cf ~e~~ns~!jvania 1 86 \,' ',..,' z/, \...!,!:i-;::;,~;iland; :g~rvvla 1 ~,~ Agent of Mortgagee BOOK 1497 PAGE. .183 -, ' ,,',k-;',~..>''''''',''''F,!)=fi'j._,- 0 '" = __ ", '" ~ . ".H""~ .~~,~ "_"i ,,_, ';'^,,' ,c"- , -, "..~ - ~'-, . .!e-:'_"~~~---~_"~_i- _~--"_" ,-, -",-. '-'~~." ACCOI"}NT NO lFNOFI::j lWE OUR U&\ MoRE LiNE. . . ........... .....,.......... . nCVVLVlrtU L.lrtC. ufo "'"c.ui 1 ,",unccmcrt' Mnu UI;"""Lu;"",nc;" ''''I cMcl't' - SECOND MORTAGE ($5001.$50,000) BORR'DWERtS) IYOU. YOUR, ,.=.. . .. . . - LIIstN.me FlrstN.me MIdcJIeIM..1 AMERICAN GENERAL FINANCe, INC. T. f (' mmVER STREET LaslName F,rstName Mlddle'n'l.., '-'J Cl\HLISLE . SlteelAddless P.O. RnX n Rlln< 17013 C,Iy Slale Z,. PENNSYLVANIA PLAINFIELD PA 17081 OTHER CHARGES . NOVRMRF.R 17.. l'l'lR Dale 01 Agreement - Appraiser for Appraisal Fee $ NA Date Finance Charge Begins 10 Accrue NOVEMRF.R Hi. l'lqR - Title Exam FeefTitle Insurance $ 55.00 Line 01 Credil $ H) , 000 00 lmlial Advance $ 7,704 4fi Other NA $ Nil Other NA $ NA Nature 01 Security For Advances Made Hereunder Other NA $ Nil Real Estate Mortgage. Deed of Trust. or Similar Secunly Instrument on 27 BACK STREET , PLAINFIELD PA 17081 Paid to Public Officials for Nil $ Nil Paid to Public Officials for Recording, Rling and Releasing Fees $ ?'i 'in $ Nil PAlO TO Nil Mortgage. Deed of Trust or Similar Securoty Instrument prov,des lh<ltluture advances WIll be secured $ Nil PAlO TO Nil thereby $ Mil PAID TO Nil INSURANCE: Credit Life Insurance is not required to obtain credit and willl)otbe provided unless'you sign and agree to pay the additional cost You understand we and our insurance affiliate anticipate profits from the sale of credit insurance, and you corisent thereto if you select such insurance. RIGHTTO RESCIND INSURANCE: Within 15 days alter receipt ola certificate, the borrower has the right to rescind the insurance. To do so, written notice must be given to the Company orthe Creditor. If joint insurance is effective, both borrowers must sign the written notice requesting cancellation. The insurance as to those persons requesting rescission is then void from its effective date. MERIT LIFE INSURANCE CO., 601 N.W. SECONO ST., PO BOX 39, EVANSVillE, IN 47701.0039 (BOO) 325.2147. GROUP CREOIT LIFE INSURANCE APPLICATION TYPE PREMIUM Single Credit Life Insurance Borrower o Co-Borrower . $.705 Joint Credit Life Insurance D . $1.23 'Charge per $1 ,000 average daily balance per month. What is your date of birth? Borrower Co-Borrower I/We represent that the information and answers given on this application are true and complete to the best of They.,will be used to issue the requested insurance. I/We understand th truthful answers may re ult in i Oate / ( /2.. 9 ? Signature 01 Borrower Date Signature of .Co-Borrower Do not sign this applicatjon if any spaces applicable to the Borrower(s) electing the coverage and to the coverage being elected have not been completed. The application will not be used in a contest if the Borrower(s) has not answered the questions applicable to the coverage being applied for and/or if the Borrower(s) has not signed and dated the application. We may require insurance to protect property securing this agreement. You may obtain property insurance from anyone you want, provided the insurance company is acceptable to us. LOAN: We grant you a Une of Credit in the amount stated above, subject to the terms and conditions set forth in this Agreement. You may access your Une of Credit by the checks we issue to you, by contacting our office during normal business hours, or in any other manner we prescribe, and in an amount of at least $100 (the "minimum credit advance") as long as you do not exceed your Line of Credit. You must lake a minimum initial advance of $2,500 on the "Date Finance Charge Begins to Accrue" stated above. ACCESS TO ACCOUNT: Your right to obtain advances under the Agreement expires ~ years from the "Date of Agreement" shown above. This ~ year period is referred to as the Draw Period. The period beginning upon the expiration of the Draw Period and continuing until the account is paid in full is referred to as the Repayment Period. The required Federal Truth.in.Lending disclosures included in this Agreement, such as the "ANNUAL PERCENTAGE RATE" disclosures section, apply to both the Draw Period and the Repayment Period. PROMISE TO PAY; PAYMENTS: You agree to repay 10 us: (a) all amounts advanced to you or on your behalf by us, including amounts in excess of your line. of Credit that we may lend you and amounts that are due under your Mortgage, peed of Trust or Security Instrument; (b) all finance charges and other charges (including insurance charges) applied to your account, and (c) reasonable attorneys fees actually incurred collection costs if and as permitted by applicable law, including court costs. If there is more than one Borrower you are jointly and severally liable for all of these amounts. Payments will be applied in the following order: to other charges (besides insurance charges), to insurance charges, to Periodic Finance Charges, and to the remainder of the unpaid balance (including The Points Finance Charge). You may not use the checks we issue to pay any amounts due under this Agreement. You may repay any part or all of your unpaid balance at any time. Your minimum monthly payment will be'figured as described in the option checked below. o PERCENT OF BALANCE OPTION: You a9",e.to make a minimum monlhly payment equal 10 Ihe sum of NA % of your new balance as shown on your monthly statement, plus any past due amount. The length of the Repayment Period is determined by the amount of the unpaid balance at the beginning of the Repayment Period. Under some circumstances, the minimum monthly payment will not cover the Periodic Finance Charges that accrue and "negative amortization" will occur. Negative amortization will increase the amount that you owe us and reduce your equity in your home (the real property securing this Agreement). 00 ASSUMED TERM OPTION: You agree to make a minimum monthly payment necessary to repay your new balance as shown on your monthly statement over a 10 year periOd (the "Assumed Term"). The length of the Repayment Period is determined by when the later of these events occurs: (a) the end of the billing cycle in which the final advance during the Draw Period is taken or (b) (if your account has a Variable Rate feature) the end of the billing cycle in which the final Annual Percentage Rate change during the Draw Period occurs. During the Draw Period, at the end of each billing cycle in which an advance is taken or_the Annual Percentage Rate changes (if your account has a Variable Rate feature), your minimum monthly payment will be adjusted to amortiZe your new balance as shown on your monthly statement over th~_ -Assumed Term. If your account has a Variable Rate feature, during the Repayment Period your minimum n:':onthl,Y pa_yment ,_~!('-p~~~gt;;t, ~a<?~~;Iif!1_~Jh~ A,~_n,u.ElI_ P_~r~~qti1':a~J=:J~t~.?h<!rge,s, but the final maturity date will remain the same. )1 the mlnlri1iu:Jlt;1nonthly payment.determji'ie'd;iAnder,jelthef'bptlorifl~il8'ss"'th'an':$5b:.'the mfnlmum monthly payment will equal the lesser of $50 or the'unpaid balance on ,.,..". "'......,...,... c...,.....,,"'.'" ......".......... ......."...:,......~.... ",.. ..~~~"...... ....,. .......... ~"..... ~......... ;..~l"......"'~ "... ........,~ ....."'......1., ...."......_.......1 "~.--"!'f\"li;;~r,~'l:;f~!I'f/Ii!J!I!!I\ll!l'~~..111~......N.,.,._'''''....~ l"'I",lIJ'""""''''~I''_~~~~'",, _,~ ~.'"l'JI'!f~~"'l'l~O"--<_~'i'fl1~"'!"""l''-j'"''''''''''"'''~~"'~''''-'''''''''''-'~' ~' monthly payment will change eaCh-.,time-.th,e'_Apnua,' p_eu;en~~;'~~;t;_:,;~~n,g~~;:_,ti~t:'t~J fi~~I:'fY;'~;~I'W~,q,fl-I~'f~;'_I,I,.remal!l,l!J~' ~,~Tp_~,,_,_;,: __ " .. _ :--' ,':,.' _, _ _' _ _ .' .: ' If the minimum -monthly payment determined under either optioh:is .JeskJ:t;um~;$50;:;tn~-miilirr1l1m. rri~ntbly:,p'ay'ment will equal the lesser;of:.$SO;or'tn&unpaid'balance- on your aCcount. Payments must be received at our address by the due date indicated on your monthly statement. FINANCE CHARGE: Finance Charges are the total of: (a) Periodic Finallce Charges a'ld (b) Other Finance Charges. (a) PERIODIC FINANCE CHARGES: We will compute the Periodic Finance Charge in each billing cycle by multiplying the average daily balance of your account times the monthly perici:!ic rate. To get the average daily balance, we take the beginning balaF;!ce of your account each day, add any new advances and other charges, and subtract any payments or credits. This gives us the daily balance. Then we take the sum of all the daily balances and divide the sum by the numberof days in the billillg cycle. This gives us the average daily balance. A Periodic Finance Charge tlegins to accrue on the date that an advance or charge is posted to your aCcount and continues to accrue until the date that the advance or charge is paid in full. (b) OTHER FINANCE CHARGES: These charges are the Point~ Finance Charge and the Annual Credit line Finance Charge. The Points FINANCE CHARGE is $ 300.00 and the Annual Credit Line FINANCE CHARGE for the first year of this Agreement is $50.00. for a totai Other FINANCE CHARGE forthe first year of the Agreement of $ 350.00 . These Finance Charges are due and payable on the "Date Finance Charge Begins to Accrue" stated above. The Annual Credit line FINANCE CHARGE for each subsequent year of this Agreement after the first year is $50.00 and is due and payable annually on such anniversary date. You agree that these Finance Charges may be charged to your account balance. ANNUAL PERCENTAGE RATE: Your Annual Percentage Rate may be a Fixed Rate or a Varjable Rate. There may be an Introductory Rate on your account. The Annual Percentage Rate includes only interest and not other costs. (a) FIXED RATE: (If Checked) 00 The monthly periodic rate is the Annual Percentage Rate divided by 12. Finance Charges are computed by applying a monthly periodic rate 01 1.<Xn/o ( 12.000/0 ANNUAL PERCENTAGE RATE) to the average daily balance. (b) VARIABLE RATE: (It Checked) Notice to borrower: This document contains provisions for a variable interest rate. 0 The monthly periodic rate used in determining your Periodic Finance Charge will be a variable rate which may change annually on each anniversary date of your account. The monthly periodic rate will be the sum of the Index Rate plus, NA percentage points (the "Margin"), divided by 12. The initial monthly periodic rate on your account IS NA % (NA % initial ANNUAL PERCENTAGE RATE). The Index Rate applicable tor each one-year period during which you maintain your account will be the highest prime rate published in the "Money Rates" listing of The Wall Street Journal (the "Index"), a business newspaper, on the first business day after the 14th day of the month preceding the month in which your anniversary date falls. (For example, if your anniversary date is May 9, your Annual Percentage Rate may change each year on May 9, using the Index Rate in effect on the first business day after the 14th day of April.) The new Annual Percentage Rate will apply '0 new advances and charges and to the existing unpaid balance (excluding accrued Periodic Finance Charge) of your account. An increase in the Index Rate Qr the Introductory Rate stated below (at its expiration) may increase the Annual Percentage Rate, Finance Charge, and minimum monthly payment on your account. The maximum annual increase in the ANNUAL PERCENTAGE RATE will not exceed NA percentage points. The maximum ANNUAL PERCENTAGE RATE on your account will nof exceed NA Q/o. In no event will the Annual Percentage Rate exceed that permitted by applicable Jaw. Jf the Index is no longer ayailable, we will change the Index and Margin so that the Annual Percentage Rate produced by the new index and margin is substantially similar to the Annual Percentage Rate in effect when the Index becomes unavailable. (c) INTRODUCTORY RATE: (If Checked) 0 The Annual Percentage Rate on your account is an Introductory Rate. Your Introductory Rate is a monthly periOdic rate of ~ % (...l'!lL % ANNUAL PERCENTAGE RATE). This rate will be In effect for the flrst.NlL.monfhs your account is open (the "lntroduclOry period"J.At the end of the Introductory Period your monthly periOdic rate and Annual Percentage Rate will bethe initial Variable Rate Or the Fixed Rate stated above. If your account has a Variable Ratefeature, the rate that would have been applied during the Introductory Period using the Index and Margin is the initial monthly periodic rate and the initial Annual Percentage Rate stated in "VARIABLE RATE" above. If your account has a Fixed Rate feature, the rate that would have been applied during the Introductory Period is the monthly periodiC rate and theAnnuaJ Percentage Rate stated in "FIXED RATE" above. During any period in which an Introductory Rate applies, your minimum monthly payment will be calculated using the Variable Rate or Fixed Rate stated above, not the IntrOductory Rate. SECURITY: You grant a security interest to us as described in "Nature of Security for Advances Made Hereunder" above and you agree to execute all documents which we deem necessary to create and protect such security interest. GOVERNING LAW: This Agreement is made and entered into under Pennsylvania law. This Agreement covers open-end loans pursuant to the Pennsylvania Secondary Mortgage Loan Act (7 Pa. Stat. Ann. ~~6601 at seq.). If this Agreement is secured by a second lien on your real property, and your account has a Variable Rate feature, this Agreement is also made and entered into under Title VIII of the Federal Garn-St Germain Depository Institutions Act of 1982 (Pub. L. 97-320; 12 U.S.C. ~~3801 at seq.. as amended). If you do not meet your contract obligations, you may lose your home. NOTICE: The terms and conditions on the reverse side are part of this Agreement and are incorporated herein by reference. CAUTI : IT IS IMPORTANT THAT YOU HOROUGHLY REA IS CONTR~CT FO IT. ~:r:cl>N~INANCE' INC. (Borrower)<J/ SIGNHEAE) V DENNIS L PORTER bY" ~ . (Borrower) <::Ii SIGN HEREI (~em~r~nder) ~ 038-00025 (X) PA REVOLVING REAL ESTATE LOAN - SECOND MORTGAGE ($5001 TO $50,000' (7-S8J ~ ,~ I NOTICE: See reverse side for adc:l!itil)nal terms and conditions and important information regarding your rights to dispute billing $rror.. . " ',,,,, ., ,,' >" - ' '. _ .', _ ' ,.. " _.', __ " , .".. ., -, ,;: ,__.~.._ _ ,:, ,__ ,^c--' .,,~ ,__^ - ".- ,'~ :,..,- ,'_ , , \ , , -J J -,,; , " , ,=-1 \ FILE ~ q-20~DI JL() September 20,2001 RE: American General Finance, Inc. TO: Dennis L. Porter PO Box 207 Plainfield, P A 17081 FROM: American General Finance, Inc. 6 South Hanover Street Carlisle, P A 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. Specific information about the nature ofthe default is provided in the attached Dages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM mEMAP) may be able to helD save your home. This notice eXDlains how the orolp:3m works. To see ifHEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TIllS NOTICE. Take this Notice with vou when you meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Agencies serving vour Countv are listed at the end of this Notice. If vou have anv Questions. vou mav call the Pennsv1vania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 781-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORT ANCIA, PUES AFECTA SU DERECHOA CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCIONINMEDIT AMENTELLAMANDO ESTAAGENCIA (PENNSYL VANIA HOUSE FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO E '{V\.\ h,-\- l( " ~ ,f. - -, ~-, '1l'LJi," " ARRIBA. PUEDES SER ELIGIBLE PARA UN. PREStAMO POR ELPROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUESE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME Dennis L. Porter PROPERTY ADDRESS: PO Box 207, Plainfield, P A, 17081 LOAN ACCOUNT NO.: 32622180 ORIGINAL LENDER: American General Finance, Inc. CURRENT LENDER/SERVICER: American General Finance, Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE 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 ASSISTANCE: *IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, *IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PA Y YOUR MORTGAGE PAYMENTS AND, *IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date ofthis Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end ofthis Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses. and telephone numbers of desilffiated consumer credit counselinl! al!encies for the countv in which the oropertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of you intentions. APPLICA nON FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for [mancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, >.""",h."~.~'~' .~~-, . .-' _~ " - -l' ~ . ~_ _' w,.. . _I sign and file 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 postmarked 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 IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION: Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceeding will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT TIlE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring: it uo to date): NATURE OF THE DEFAULT.. The MORTGAGE debt held by the above lender on your property located at: PO Box 207, Plaiofield, PA, 17081, IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTIIL Y MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Account # May 2000 through August 2001- 16 payments of$135.33 = $2,165.28 Other charges (explain/itemize): Past Due Payments: $2,165.28 (Interest included) HOW TO CURE THE DEFAULT - You may cure the default within TIllRTY (30) clays of the date of this Notice BYPA YING TIlE TOTAL AMOUNT PAST DUE TO TIlE LENDER, WHICH IS $2,165.28 plus interest, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclosure uoon vour mort!!a!!ed Drooertv. IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the mortgage debt. Ifthe lender refers your case to its attorney, but you cure the delinquency before the lender begins legal proceedings against you, you will still required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually which may also include other reasonable costs. If vou cure the ,'1'}Nll" J ^__""_,_'_,~"_,~_,,,._, ~" , ,,'] '-"'-' -, - ~ " - '-~ - r__ " ,..,....-,~ .' default within the THIRTY (30) DAY oeriod. 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 TIffi DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ril!ht to cure the default and nrevent the sale at any time up to one hour before the Sheriffs Sale. You may do so bv pavinl! the total amount then past due. D1us any late or other charl!es then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as sDecified in writing: bv the lender and bv Derforminl! any other requirements under the mortl!al!e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A Notice ofthe 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 action will be by contacting the lender. HOW TO CONTACT TIlE LENDER: American General Finance, Inc. 6 South Hanover Street Carlisle, P A 17013 717-243-6055 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. A:;;SUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. YOU MAY ALSO HAVE TIffi RIGHT: * TO SELL TIlE PROPERTY TO OBTAIN MONEY TO PAYOFF TIlE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTIffiR LENDING INSTITUTION TO PAY OFF TIllS DEBT. *TO HAVE TIllS DEF AUL T CURED BY ANY TIlIRD PARTY ACTION ON YOUR BEHALF. *TO HAVE TIlE MORTGAGE RESTORED TO TIlE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE TIlE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) *TO ASSIST THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTIlER LAWSUIT INSTITUTED UNDER TIffi MORTGAGE DOCUMENTS. -;~m.J!:~U;1!TJil ' ,,",__ _",_,~__:,,"'" .-_~,' ---"'i'_'-'~""' ",' -" ,,_ .1-" ,_~_" "L" - r '!11 !iE' . *TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. *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 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 17102 (717) 541-1757 Financial Counseling Services of Franklin 31 West 3"' Street Waynesboro, PA 17268 (717) 762-3285 It is only necessary to schedule one face-to-face meeting. You should advise American General Finance, Inc., immediately of your intentions. Sinc rely, Herbert P. Henderson, II Attorney for Beneficial Consumer Discount Company 36 East King Street Lancaster, PA 17602 (717)295-9159 pc: American General Finance, Inc. 1;$';->"_f__',._".,,, '.,,,.,'-",,,,.,,_. ", r~ H" , , r...........' I,:. , 3S1&1/7 TaxlDNo. MADE THE \Cj {Yo",. of hundred llinely~ci[,lhr (1998) DICED DDfOG~n Ihe year uf 0111' Lonl Ol1e tholls:lnd nine BETWEEN DENNIS L. I'ORTER :Ind DEDRA L. PORTER, husband and Wife, of Clll1lberl:llld County, pennsytvoni;t GRANTORS :md J)I::NNI$ L. PORTER. ofCul11berland County, Pennsylvaltin GRANTlm WlTNESSETH, Ilml in cOI\siJeralioll of One Dollar ($1.00), ill h,lnd politi, (he receipt whercofis hereby acknowledged, the s:\id GraJtrors do hereby brrant and convey 10 the snid Granlt(. his heirs andnssigns: ( ALL THAT CERTAIN ll':tcl or ]01 of ground with lhe improvements [heron erecledsitullle in Ihe Village otPluinticlli, 'fOWllShip ofWesl Pennsbora, County ofCwlIberland. ilnd Slutc of Pennsylvania, and boUlll.l~d ~l\d described as follows: BEGINNINC at a post in the l'o~d from Ml. Rock ,0 Hepburn's Mill (oowcalled Burgl\Cr'S Mill); (hence by said l'o~d South 59 Y: degrees West, 9.54 perches to a post; thence by lot now or formedy of Alben Finkenbinder, North 5 ~ degrees Wes113.S perches 10 a post; thel\ce by lot now or formerly of Samuel Shambaugh, North 82 degrees E~st, 8.72 perches to a post; thence by the snme, south 5 degrees West, 10.04 perches to the place ofllEcrNNINC. Contoining One Hundred and One (101) perches, more or less, and being improved with 0 fmme dwelling house. BEING the some property which Lydia R. Wagner, by her Deed dated September 10, 1986,llllU I'ecorded h1 the Oflice orthe Recorder of Deeds in il.nd for Cumberlp.nd Coumy in Deed book "E", Volume 32, Page 624, gronted and conveyed unto Del1nis L. Porter and Debra L. Porter, Husband ilnd Wi fe. THlS!S A NON-TAXABLE TRANSFER forPemlsylvanin transfer Iii)!; purposes Ii'om husband amI wife fO hu~bnlld, And the s"id Gron!Ors hcr~by conwnant nnu :1grcc that Lhey wilJ WMrflll! sr~ciaJly the prOpl::rly hereby conveyed. r . '07 I','," 453 <Iv,",' ..:.. EX~~D\~ (\ e/ ^;>$i ',P -nwm:~n, 1q IN WITNESS wmm..EOF, the said Grantors have here\mto sel their hands and seals lhe day and year flrsl above written, COMMONWEALTH OFPENNSYLV ANIA ) : SS. COUNfY OF CUMBERLAND ) ON THIS, the ,'it\.... dsyof ()c_~k~(" . 1998,berol"eme,lhe \lndetsiglled officer, personally appet'ored J)ennis L.l'orlcr, known 10 Ole (or satisfactorily proven) to be lhe pCl'son whose na1l1e is subscribed, 10 the within inSm1nlCnt, and ncknowle<lged that he executed the snme for lhe p\lrposCS therein contained. IN WITNESS WHEREOF, 1 hereunlO set my hand :and official seal. ,I- '~~;l~/~~':~ !~, , ':\"'Y:~>/:: h Nl:IllIri31Sul " " Oeniul~,Mllr!onSr..NolaryPublle snver SprmgTwp.. Cumbetlend CounlV My Commlsslon E~plres Oel. 24. 2002 IkmDI!1,f'el\flso,NIIIII ~lmllJOIIol NollItIGfI COMMONWEALTH OF PENNSYLVANIA ) :SS. ) COUNTY OF CUMBERLAND ONTI-nS,the /9*' dl'lyof Oc-b'b~ ,199fl.beforeme,the undersigned officer, perso11911y appeared Debra L. l'OI1er, knOWI\ to me (or satisfllctol'jly -' ,', '.' proven) 10 be the person whose name is subscribed Lo the within instrument, and ackriowl~dged"., thai she executed the same for the purposes therein cOl1tained. , " - j.o', IN WITNESS WHEREOF. 1 hereunto gel my hand and officilll seal. :f :', ~:;;~~-;~~~:",', ., .,.) '>:~'::~ ~/';~::~...' -~J'--"::::::-.. "UI"1 ~ISe.'1 SIlr;:~lslel,J,MortonSr"Nl)larypubliC pn"gTwp.,CulTlbuMsndC ~. My Commission Ewpln..'.I Qel. 24. ~~ Mombllr. I'Mln6t""3nlll ~uodalkln OJ NOla~e$ ~oaK 187 p~G[ 454 ~:, !,.-..~ ,~ ~ . . . C"",!'\W~'m;"",,", \ '- I do hereby eeL1ify that lht:: precise residence ilnd complete post ollice address orthe wilhin- named Gmmee(s) is: Dale: 10\ \"1 \I\'i\ ~o t:JX ?..01 Wk S1 plAIt,mELD, VA ~Jj~. at Auol'11ey for (JR~I-.J11::'E. COMMONWEALTH OFPENN5YLV ANIA ) : 55. COUNTY OF CUMDERLAND ) ReCORDED on lhis --L1.. day of 6e. ,. , A.D, 191-. in the Recorder's Officeoflhe snid County. in Deed Book I'll . V oh,lIne .--w , P:lge 4s3-. Givcn ltlldt::r my hand .lIlt! the seal o(lhe s:iicl Officc. Lhe: dllle above Wl'itlen, ':',~::;':i'.~::~~ ,0 J.j??<-- 'JJ...,{.::,>~ ".1.' ,',,':.'.., \~ "I " I, ,. , ..;:', -~'~~..:~~_'~:'_ ._; ,..-:J ;~ U"l N ", " ,..... .U i.' ,_ :;;~;; :::r- :.;:::.8 ~ " ~~ ....1 ~-' a> ~ ~ ~ = "" 0> nOOK 167 PAGE 455 .. '" , , Recorder ,_ .~w_'"_~"".,..,.. n_~ = ,,-"'M....~~,~ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: -D~VUfLl s L. ~ +~'(- 4er 'PD t::Dx.- 2.C r( vlcUAf\~ld :p~ I ViO~1 ) . , D. 3. Service Type li2'Certified Mail o Registered o Insured Mail o Express Mail e-Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) DYes 2. Article Number (Transferfromservice/abel) 11'l4f/ 3LfDO O()n 3w2.3, (j;g]O PS Form 3811, Ma~ch 2001 Domestic Return Redeipt 102595-01-M-1424 C lr U1 .J] m ru .J] m .m 1,-'1 c o o o ;:t' ITl postage Certified Fee AeturnReceiptFee (Endorsement ReqUIred) Restricted DeliVery, Fee (Endorsement ReqUIred) ,VJL-( Total Postage & Fees $ Postmark H're IT" IT" CJ l"'- ~~~~~~~r:~_~Y~MI1t.i:~~_..______________,___._______.__--- .Street, ipCNo.; or PO Box No. nP!d..~X-n..kO.'I.n.......nn.nm..mn....nmmn.n. -CitYi>tate:~ [)~ ''':": "'., .--',,",", ,-, - ,.~,., --~-_ '-""""IF_. " ~ 0 0 0 " t g ~ c ~ --4 S a H~F ~ -Om ''--0 !'l'lfT1 ..~)m Z::D N ~br) it , -C t1 ,> -.l ,=,,I, ~ ~ "_--:~7 ~1 r:=c. -'r.:-r ~- C'. ".;: .. ~ ~~~~ a:;) :~:~ ",... )J ~ b ...... L_ :.n ::0 -0 () -j (::J -< \B ~ I) '"' - -'= p ~ ~ ___!&W~~_ "_ J. _nllll~_ )'1-\t"m~"'lW!<f>fi;t!~~ ~~,,~"?,~%'$'1!1i_'j'> ..n,!~!It!,,--_~Il~!ll\ UJ::_)l_JflJ!f~~,1 _ SHERIFF'S RETURN - REGULAR CASE NO: 2001-06645 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN GENERAL FINANCE INC VS PORTER DENNIS L SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PORTER DENNIS L the DEFENDANT at 1805:00 HOURS, on the 7th day of December, 2001 at 27 BACK STREET PLAINFIELD, PA 17081 by handing to ROGER SHUGHART, ROOMMATE 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;.N':~-# R. Thomas Kline 12/10/2001 KENNETH REIDE , Sworn and Subscribed to before By: me this l<j\!:: day of )O~",~lu., .2rJ.o{ A.D. 0,., f2 7hd;L<J ~~'f Prothonotary' ,;qc'f:1i'~~'1'!'1i~'t-""_"""'"=,,....,,., ~ ,- ~ ~~r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMERICAN GENERAL FINANCE, INC., : Plaintiff vs. NO. 0[- t,.L,tJS c,:.,; l 't-~ ACTION IN MORTGAGE FORECLOSURE DENNIS L. PORTER, Defendant TO: DENNIS L. PORTER DATE: December 31,2001 IMPORTANT NOTICE YOU ARB IN DEFAULT BECAUSE YOU HA VB FAILED TO TAKE ACTION REQUIRED OF YOU IN TillS CASE. 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 TillS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cmnberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 REIDENBACH & HENDERSON By: Herbert P. Henderson, II, Esquire Attorney for Plaintiff Attorney J.D. #56304 36 East King Street Lancaster, PA 17602 (717) 295-9159 ,^,W~liil;!ifll>-~, .. "~. "'1" - .'-'->~ -,.,.".,.", "IlIlII' ~ ~~~ ,~, '.", ". ~'^~= "'''="''"'~'-'''l ,- . ,- '- ~< 0 a C) C f'....:~ "T1 <: , VG_"f ;;-~, f1-j'''r- Z::,~; '~'7'" """.. Z ~,. (f) .," -< ~~- r:: C,. < ~"Cl )> ,,-~ -!;.. Z ~. j ,', j;: .......... !'C' (= ;:::: (.() ...<~ ()~ Ec Bil L _1~'1J.i[ ~ ~J(!l!III.,.", _~mrlil!:r.llI_~~J!:l!'_~~jI;Jl-jffijll;!IV"0-C0,":'-;ioE;;"_".'" ""n",,!_,,;:, "r,'""'-~j'iy<~'t'r.~il'~Oii".liI1!1\"<,"g,4;;f~i(1'1l1!-0:"j;,,,!!~r~