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Home My WebLink About03-2399BANKERS TRUST COMPANY OF CALIFORNIA, NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A Plaintiff 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. ACTION OF MORTGAGE FORECLOSURE MICHAEL A. LAUGHMAN AND WENONA N. LAUGHMAN Defendants THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of 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 LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERV1DO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA con TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER D1NERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A LIN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BANKERS TRUST COMPANY OF CALIFORNIA NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A, Plaintiff VS. MICHAEL A. LAUGHMAN AND WENONA N. LAUGHMAN, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : C1VIL ACTION LAW : ACTION OF MORTGAGE FORECLOSURE : THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The mount 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 with the said thirty (30) day period that the 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 undersigned 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. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff BANKERS TRUST COMPANY OF CALIFORNIA, NA AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A, Plaintiff VS. MICHAEL A. LAUGHMAN AND WENONA N. LAUGHMAN, Defendants : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, BANKERS TRUST COMPANY OF CALIFORNIA, NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A, is a Corporation, with an address of 8120 Nations Way, Jacksonville, Florida 73126. Defendant, MICHAEL A. LAUGHMAN, is an adult individual, whose last known address is 110 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025. Defendant, WENONA N. LAUGHMAN, is an adult individual, whose last known address is 110 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025. On or about, October 27, 1995, the said Defendants, executed and delivered a Mortgage Note in the sum of $63,500.00 payable to MELLON BANK, NA, which Note is attached hereto and marked Exhibit Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants, made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1288, Page 935 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to BANKERS TRUST COMPANY OF CALIFORNIA, NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A and recorded in the aforesaid County in Mortgage Book 582, Page 1104. The Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 110 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on January 01, 2003 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $56,996.05 Interest at $10.73 per day From 12/01/2002 To 06/01/2003 ( based on contract rate of 6.875%) $2,274.76 Accumulated Late Charges $83.44 Late Charges $20.86 From01/01/2003to06/01/2003 $146.01 Escrow Balance $356.05 Attomey'sFeeat5%ofPrincipal Balance TOTAL $2,849.80 $62,706.11 **Together with interest at the per diem rate noted above after June 01, 2003 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event ora third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to Foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiffhas complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowner's Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. V~tEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.875% ($10.73 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. ~__ j By: PURCELL, KRUG & HALLER Leon P. Hailer, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) NOTE ~ 027/o37 COMPANY NAME: VERIFICATION I verify that the statements made in the foregoing Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated lV~,y lq, 2003 ~. Michele de Cmen Title: Assistant Secretary SHERIFF'S RETURN CASE NO: 2003-02399 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANKERS TRUST CO OF CALIFORNIA VS LAUGHMAN MICHAEL A ET AL - REGULAR DAWN KELL , Cumberland County,Pennsylvania, says, the within COMPLAINT - MORT FORE LORD NICOLE TENANT DEFENDANT , at 1704:00 HOURS, at 110 NORTH ENOLA DRIVE ENOLA, PA 17025 NICOLE LORD a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 22nd day of May by handing to the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /2~~ day of A.D. ~Prot honot ary So Answers: R. Thomas Kline 05/22/2003 PURCELL KRUG HALLER By: Deputy Sheriff SHERIFF'S RETURN CASE NO: 2003-02399 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAiqD - NOT FOUND BANKERS TRUST CO OF CALIFORNIA VS LAUGHMAN MICHAEL A ET AL R. Thomas Kline duly sworn according to law, says, that inquiry for the within named DEFENDANT LAUGHMAN MICHAEL A unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being he made a diligent search and but was He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 110 NORTH ENOLA DRIVE ENOLA, PA 17025 PER CURRENT RESIDENT, MICHAEL LAUGHMAN , NOT FOUND , as to LAUGHMAN MICHAEL A IS IN JAIL IN TEXAS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 10.35 5.00 10.00 .00 43.35 So answer~l~- /L-/ R. Thomas Kline Sheriff of Cumberland County PURCELL KRUG HALLER 05/22/2003 Sworn and subscribed to before me this /2 ~ day of~ ~0]kj A.D. notary SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-02399 P COMMONTWEALTH OF PENNSYLVA/qIA COUNTY OF CUMBERLAND BANKERS TRUST CO OF CALIFORNIA VS LAUGHMAN MICHAEL A ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT IJtUGHMAN WENONA N unable to locate Her in his bailiwick. COMPLAINT - MORT FORE , ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and but was He therefore returns the the within named DEFENDANT 110 NORTH ENOLA DRIVE ENOLA, PA 17025 PER CURRENT RESIDENT, LIVES , LAUGHMAN WENONA N WENONA LAUGHMAN CURRENTLY IN FREDERICKSBURG. NOT FOUND , as to Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 Sheriff of Cumberland County PURCELL KRUG HALLER 05/22/2003 Sworn and subscribed to before me /2 ~-~ day o~ this ~m3-~ A.D. Prothonotary ~ BANKERS TRUST COMPANY OF CALIFORNIA, NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. MICHAEL A. LAUGHMAN AND WENONA N. LAUGHMAN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 - 02399 Civil term IN MORTGAGE FORECLOSURE p RA E C I P E TO THE PROTHONOTARY: Please mark the above action settled ,and discontinued, prejudice. without PURCELL, KRUG & HA~LLER Leon P. Haller ID #15700 Attorney for Plaintiff Purcell, Krug &Haller 15'19 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: July 24, 2003 BANKERS TRUST COMPANY OF CALWORNIA, NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. MICHAEL A. LAUGHMAN AND WENONA N. LAUGHMAN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of 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 LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BANKERS TRUST COMPANY OF CALIFORNIA NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A, Plaintiff VS. MICHAEL A. LAUGHMAN AND WENONA N. LAUGHMAN, Defendants · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned 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 with the said thirty (30) day period that the 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 undersigned 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· PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff BANKERS TRUST COMPANY OF CALIFORNIA, NA AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A, Plaintiff VS. MICHAEL A. LAUGHMAN AND WENONA N. LAUGHMAN, Defendants · IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, BANKERS TRUST COMPANY OF CALIFORNIA, NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A, is a Corporation, with an address of 8120 Nations Way, Jacksonville, Florida 73126. Defendant, MICHAEL A. LAUGHMAN, is an adult individual, whose last known address is 110 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025· Defendant, WENONA N. LAUGHMAN, is an adult individual, whose last known address is 110 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025· On or about, October 27, 1995, the said Defendants, executed and delivered a Mortgage Note in the sum of $63,500.00 payable to MELLON BANK, NA, which Note is attached hereto and marked Exhibit Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants, made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1288, Page 935 conveying to original Mortgagee the subject premises· The Mortgage was subsequently assigned to BANKERS TRUST COMPANY OF CALIFORNIA, NA, AS TRUSTEE OF MELLON CRA MORTGAGE LOAN TRUST 1996-A and recorded in the aforesaid County in Mortgage Book 582, Page 1104. The Said Mortgage and Assignments are incorporated herein by reference· 5. The land subject to the Mortgage is: 110 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on January 01, 2003 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $10.73 per day From 12/01/2002 To 06/01/2003 ( based on contract rate of 6.875%) Accumulated Late Charges Late Charges $20.86 From 01/01/2003 to 06/01/2003 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $56,996.05 $2,274.76 $83.44 $146.01 $356.05 $2,849.8O $62,706.11 **Together with interest at the per diem rate noted above after June 01, 2003 and other charges and costs to date of Sheriff's Sale. 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to Foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowner's Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.875% ($10.73 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. ~/~ //" By: PURCELL, KRUG & HALLER Leon P. Hailer, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) 04/25/2003 14:07 NOTE 0508587243 ~027/037 · NOR?H __110./gRO~ Da, gHO~%, ~IU~$YAVANIA 17025 1. lJOFJ~OwKI~'S PI~OMISE TO PAY In ret~m for u hmn tbt~ Z lmve re.ired, Im. oml~ to pay i~]. $ 63,500.00 i~.~oF~of~n~.~nd~s ~ ~ N.A. ~ ~T ~ ~ b ~ ~ ~npaJd ~fin~ un*O ~b hll nm~.t oFp~ h~ ~ pa~ X ~ p~ ~ I ~ r~o 6.87500 ~ ~r~ rem r~ ~ ~ ~on 2 b th ~ l ~Jl ~y ~th ~ nd ~ff eU d~ ~ ~ ~n l ~ p~ ~t~ ~ h~ ~ making ~te ~ ~th. l~'~ne~oetbe 01~h~a~n~ D~ 01 ,19 9~ NO~. ~ ~u~ pa~ ~ ~ tpplt~ ~ ~ b~ ~. ~, ~ N~R 01 , 2025 ~ ~ ~ ~ X ~ pay t~ ~n~ ~ ~ ~ th~ ~, w~ b ~d t~ "mtt~ ~~~ 6400 F~ ~ ~U~ ~SB~, ~E~x~ 17112 ~at a MY ~n~Y paM ~ b h~ a~nt of U]. S 417.16 Wh~ I ~ a ~t. I wm t~ tho N~ ~ ~ writing that I ~ ~ ~. p~nta to r~ t~ a~ of ~pnl t~ I ~e un~ thia ~ ~ l m.~ a ~ p~ ~ ~ ~ ~u ~ h tM rant of~ ~th~ ~t unlm tb N~o Hold~ ~ h ~ to thou e~ 5, LO~ ~ ~ I ~w, wMch app~ ~ ~ ~ and whkh ~ ~m ~ ch~, b ~ ~d ~ t~ ~ ~ u~ed ~ ~ be e~ in ~tlu wiLb this b~ ~d the ~ ~ ~h~: ~) ~ ~ b~ ~ ~ p~ ~ ~ ~ n ~nd ~ phial, t~ ~bn ~11 ~ t~d ~ m ~ ~pa~ ~ BO~*S F~ ~ FAY ~ ~ ~ N~ ~ h~ Mt ~v~ t~ ~]l ~ ~ a~ ~nt~ p~ by ~e ~d of F~EEN esi~ ~ ~lt h ~ X~ ~ t ~t~p ~ tbN~ b~. ~e a~ of~ ~ ~ 5.000 ~ af~ ~ep~ of N~ ~1~ ~ ~ m ~ ~ ~ly tb ~ u~nt of ~d ~ ~ ~ ~ ~ ~ ~ the ~ ~u~. ~ ~ mu~ ~ ~ hut ~ ~a~ ~ ~ ~ ~ w~h ~ M~ is ~ ~ ~.i1~ ~ ~. ~ ~ N~ H~ bo ~ ~ ~ pay tm~i~ in hll tm d~ ~ ~ N~ ~ ~ h~ ~ ~ V. O~G OF N~ 029012/8~* 04/25/2003 .t4:0? FAX ~028/037 & 09LIOATION~ OF PJ{3{SOI~. ~..~L~L TH~ NOTE '~' '~ore than ~ per~n aisle this No~e0 umch person t~ folly and po~onalJ;F obltjeted, to keel, ail of the pr~mdam made in th~ Note, ,inoludi~ tho prombe to pay th. fi:l] ,moun~ owot ~ay pertain who la a ~zerHt~, surety or endo~nr of*thh Note ia tMnp. An~ p~rson who takes over thes~ obli~t/ons, hehdin[ the oMifat~ons o~s Suart~or, outer7 ~ endoHcr to hep all ~' tJM promi~ nab in thi. Not~ ~he Note H~ld~' nv euhru itl rt~h~n u~dor tMs Note ,rebut ~a~, ~dl ofu together, This memm ~}1(~, amy one O£UB may be required h, p~y aH of the omounta owed. un(let tJtJs l~ote. IM~JuM indiyMu~lly or I sad any other l~lOn who has oblif~one under this Nob waive tim r~M of preeentmemt and M:lee of dishonor. 'Preaentment' memo the r4~ht to reefah the lq'ot~ Holde~ ko demand peTme~ of amounts du~ ~qa~ke ;f 4bJu.mr" memo. the ri~'ht to rcquire the Here lloldar to LiTe no~ce to other p~reone th~ unto-onto due hev~ not boen paid. 1o. UNXFO~X SI~D NOT~ uuder ~his Not~ s Mo~p~, Demi of Tr~tt or 8e,mri~), ])Nd (Lite '*Som~rlW HoMm- ;rom possible buses which mlgh~ ~esul~ ~ ! do nu~ keep ~he dttm~ t]~ o~no h*e ts t~Ls No~e~ pr~-ts ~ho Note pF0lBfma wh~.h ! meko In ~ Note. Thl% ~ how ud under w~m~ mndlt~ms T mv~ be ~qufmd ~0 mske immedJu~e peym~ in hH of LTl ammmt~ ! owe undeF Trmufer °~the lU~rsYora Befmflaldlmt~reet In Bewrewer, If ail or any pe.~t of tho PropertF ar ax~ lntare~ in it fa eoLd or trutnefeL-r~d {or if · beneflt~lal Jllt~raet in ~or~w~r m soM ~ t~neforred and B~f~n~r in no~ t nnl~L-u] perth) Lender'. pr,~ vritton oon.ont, Lender m~, at b otmon, r, qu~v tmmet0ate pn~lm~t in Adl o~ all m~ma oeeured I~' thle 8eeuTlty Znstntmon~ However, thi. option uhail t~ date of this SenLV/ty ~nstrument, ~' Lender e~te~fm ems option, LoudeF shell ~ Borrower nothm of ao~Jere~Jon. The m~eo nha~ provide · lJ~iod ofn~ lees *hah SO da~ from the d~te J,~e notlto in delivered or mellud vlthln whith Borrov~ nm~ p,O' all stms .ocured remedies pe~n{~ted by this Soeuflty In~.trnment withant furth~ uotlea mr d~nend on ~orruwer. ~Tr~Bs8 T]8~ HA_.NO~(S) AND SEAL(S) OF ~ J'~,n u. ~,'lg Puge ! 04/2g/2003 t4:07 FAX ~026/037 ~ S~ ~0 d~s 20 ~u~el B~ 25 f~, 110 NO~ ~a ~i~l ~ ~dly ~ ~e cen~ of ~ ~ition Drip, N~ 10 ~B 20 ~u~ 25 f~, ~ d~Ll~ h~e ~ ag No. 110 No~h ~la Drive, ~la, ~Flv~. ~ ~ w~e, ~ ~ ~ ~ 28, 1993 ~d ~ of ~ ~ff~e ~ ~ ~k ~, Vol, 36, ~ess, to e~n, read.ions, COMPANY NAME: VERIFICATION I verify that the statements made in the foregoing Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated 2003 ~. Michele de Craen Title: Assistam Secretary